{"id":"court_ctb_1592_0","court":"CTB","case_no":"22-50073","doc_number":1592,"sub_number":0,"doc_type":"ORDER","filed_date":"2023-03-24","title":"UNITED STATES BANKRUPTCY COURT DISTRICT OF CONNECTICUT BRIDGEPORT DIVISION | -------------------------------------------","summary_zh":"第11章受托人第四次补充综合调查动议 —— Ho Wan Kwok 破产案（郭文贵 / Guo Wengui / Miles Guo），CTB 22-50073 ECF #1592（2023-03-24立案）。第 11 章受托人 Luc A. Despins 依据《联邦破产诉讼规则》第 2004 条申请法院下令，授权对与债务人关联的更多个人、实体、相关银行及业务往来单位展开资产与财务调查及证据开示。异议截止日期为 2023 年 3 月 31 日。","summary_en":"Chapter 11 Trustee's Fourth Supplemental Omnibus Rule 2004 Discovery Motion — In re Ho Wan Kwok (Miles Guo / Guo Wengui / Ho Wan Kwok), CTB No. 22-50073, ECF No. 1592 (filed March 24, 2023). Chapter 11 Trustee Luc A. Despins moved pursuant to Bankruptcy Rule 2004 and Local Rule 2004-1 for an order authorizing discovery from additional affiliated entities, individuals, banks, and vendors to investigate the debtor's assets. The objection deadline was set for March 31, 2023.","body_en":"# **UNITED STATES BANKRUPTCY COURT DISTRICT OF CONNECTICUT BRIDGEPORT DIVISION**\n\n| ----------------------------------------------------------- | x      |                         |\n|-------------------------------------------------------------|--------|-------------------------|\n| In re:                                                      | :<br>: | Chapter 11              |\n| 1                                                           | :      |                         |\n| HO WAN KWOK,<br>et al.,                                     | :<br>: | Case No. 22-50073 (JAM) |\n| Debtors.                                                    | :<br>: | (Jointly Administered)  |\n| ----------------------------------------------------------- | x      |                         |\n\n# **FOURTH SUPPLEMENTAL OMNIBUS MOTION OF CHAPTER 11 TRUSTEE FOR ENTRY OF ORDER UNDER BANKRUPTCY RULE 2004 AND LOCAL RULE 2004-1 AUTHORIZING DISCOVERY WITH RESPECT TO ADDITIONAL ENTITIES AND INDIVIDUALS AFFILIATED WITH DEBTOR, RELEVANT BANKS AND ENTITIES DOING BUSINESS WITH DEBTOR AND AFFILIATED ENTITIES**\n\nLuc A. Despins, in his capacity as the Chapter 11 Trustee (the \"Trustee\") appointed in the above-captioned chapter 11 case (the \"Case\") of Ho Wan Kwok (the \"Debtor\"), by and through his undersigned counsel, pursuant to Federal Rule of Bankruptcy Procedure 2004(a) (the \"Bankruptcy Rules\") and Local Bankruptcy Rule 2004-1 (the \"Local Rules\"), hereby applies (the \"Application\" or \"Motion\") to conduct the examination of the business associates, professionals, and corporate entities (the \"Related Persons\"), certain banks at which the Trustee believes the Debtor and Related Persons conducted business relevant to the estate (the \"Banks\"), and certain entities doing business with Debtor and/or affiliated entities (the \"Vendors\" and, together with the Related Persons and Banks, the \"Examinees\") of the Debtor, as such Examinees are identified in **Exhibit B**, attached hereto, in the Case. **Please take notice that the deadline to object to this**\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\n**Application is March 31, 2023, and in the absence of a timely filed objection, the proposed order filed herewith as Exhibit A (the \"Proposed Order\") may enter without further notice and hearing.** In support of his Application, the Trustee respectfully states as follows:\n\n#### **PRELIMINARY STATEMENT**\n\n1. The Trustee, in furtherance of his duties and responsibilities under the order authorizing the appointment of a chapter 11 trustee dated July 6, 2022, (*See* ECF. No. 465, at 14, hereinafter referred to as the \"Trustee Order\"), continues his investigation into the Debtor's financial and business affairs to determine whether additional estate assets exist and to recover upon those assets for the benefit of the Debtor's estate.\n\n2. The Trustee's investigation has identified more individuals and entities with possible knowledge of the Debtor's assets and financial activities, and the Trustee seeks to further his investigation through additional Bankruptcy Rule 2004 discovery of these Examinees.\n\n3. The Trustee believes that the Examinees have access to and understandings of information relating to the Debtor's assets, financial affairs, and potential financial interests in various corporate entities related to the Debtor, his family, or his associates. Indeed, the Trustee expects that, to the extent the Debtor has engaged in efforts to hide his wealth through a network of shell companies and otherwise (as the New York Supreme Court has found), the Debtor would likely have needed extensive assistance and aid and participation by the Related Persons.\n\n4. The Trustee has submitted several Bankruptcy Rule 2004 motions granted by the Court, including one directed at legal and financial firms believed to have advised the Debtor and related entities and individuals (ECF No. 637, the \"Advisors 2004 Motion\"), one directed at entities and individuals believed to be affiliated with, controlled by, or otherwise connected to the Debtor (the \"Affiliates 2004 Motion\"), the Trustee's First Supplemental Omnibus Motion dated\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 3 of 1063\n\nSeptember 7, 2022 (the \"First Omnibus Motion\"), the Trustee's Second Supplemental Omnibus Motion dated November 18, 2022 (the \"Second Omnibus Motion\"), and the Trustee's Third Supplemental Omnibus Motion dated December 21, 2022 (the \"Third Omnibus Motion,\" together with the Advisors 2004 Motion, the Affiliates 2004 Motion, the First Omnibus Motion, and the Second Omnibus Motion, collectively, the \"2004 Motions\"), which was granted by Court order dated January 18, 2023 (*See* ECF No. 1339). The discovery requested herein will supplement and augment inquiries the Trustee has already begun, as well as open additional avenues of investigation and potential discovery of assets.\n\n5. In the interest of brevity, the Trustee incorporates the 2004 Motions herein by reference and makes them a part hereof. All capitalized terms not defined herein shall have the meanings ascribed to them in the 2004 Motions.\n\n#### **JURISDICTION AND VENUE**\n\n6. The Court has jurisdiction to entertain this application under 28 U.S.C. §§ 157 and 1334. Venue to hear this Application is proper in accordance with 28 U.S.C. §§ 1408 and 1409.\n\n7. This Application is a core proceeding pursuant to, *inter alia*, 28 U.S.C. § 157(b)(2) (A), (E), and (F).\n\n#### **THE EXAMINEES**\n\n8. The Examinees are additional individuals and entities that may be working for, with, or controlled by the Debtor, or that may otherwise have material information concerning the Debtor's assets and financial condition. Many of the Examinees are related to the web of shell companies described by New York Supreme Court as the Debtor's \"shell game.\" The Examinees further include Related Persons that assisted the Debtor in carrying out the various business\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 4 of 1063\n\nactivities that are subject to the Trustee's investigation as well as parties that may have contracted with or otherwise done business with the Debtor.\n\n9. More specifically, the Examinees are as follows:\n\n**(a)** It has been reported to the Trustee that the Debtor, along with entities and individuals linked to the Debtor, have done business at multiple banking institutions, which may include the Related Persons and transactions described in this Application and the 2004 Motions. The Trustee believes these banking institutions may possess information and documents related to the Debtor's commercial activities and other conduct concerning assets, liabilities, or financial interests potentially relevant to the administration of the Debtor's estate, and may hold assets of the Debtor. These Banks are, among others: (i) **Santander Bank, N. A.**, (ii) **Silvergate Bank**, (iii) **DBS Bank Ltd.**, (iv) **The First Bank of Greenwich,** (v) **Bank of China – New York Branch and/or Bank of China Limited,**  (vi) **U.S. Bank National Association;** (vii) **The Bank of Princeton**; (viii) **Metropolitan Commercial Bank** and/or **Metropolitan Bank Holding Corp.**; (ix) **Medici Bank International LLC**, (x) **Deltec Bank & Trust Limited**, (xi) **Open Bank**; (xii) **National Australia Bank Limited**, and (xiii) **First Republic Bank**;\n\n**(b)** The Trustee understands that the Debtor has encouraged his followers to invest funds in (i) **Hamilton M&A Fund SP**, a segregated portfolio of (ii) **Hamilton Opportunity Fund SPC** (collectively the \"Hamilton Entities\"), in connection with the purchase or contemplated purchase of a controlling equity interest in (iii) **Mercantile Global Holdings, Inc.**, which the Trustee understands owns 100% of the equity of (iv) **Mercantile Bank International Corp.** (collectively the \"Mercantile Entities\")**.** The Trustee understands that one of the directors of Hamilton Opportunity Fund SPC is the\n\nDebtor's associate, William Je (with respect to whom 2004 discovery was granted in connection with the First Omnibus Motion), and the other director Hamilton Opportunity Fund SPC is (v) **David Fallon.** Mr. Fallon, the Hamilton Entities, and the Mercantile Entities are therefore likely in possession of documents relevant to the Trustee's investigation.\n\n## **(c)** (i) **G-EDU Inc.**, (ii) **GFashion Media Group Inc.**, and (iii) **G Translators Pty**\n\n**Ltd** are additional \"G Series\" entities, whose name is inspired by the Debtor, and which are affiliated with the New Federal State of China (\"NFSC\") and/or the Himalaya Exchange, which this Court has found \"serve[s] the purposes of the Debtor, serve[s] as business vehicles for the Debtor, and their members are personally loyal to the Debtor,\" 2 and are therefore likely in possession of documents relevant to the Trustee's investigation;\n\n**(d)** The Debtor has frequently referenced significant real and personal property assets that he or his immediate family members own and control. In furtherance of the Trustee's investigation, the Trustee seeks additional discovery related to residential properties potentially owned or controlled by the Debtor. It is believed (i) that **Emile P de Neree** and (ii) **NRT New England LLC** (DBA **Coldwell Banker Residential Brokerage**) represented the Debtor and/or Debtor-controlled entities in connection with the purchase and sale of 373 Taconic Road, Greenwich, Connecticut 06831 (\"Taconic\"), that (iii) **Martha Jeffery** and (iv) **Sotheby's International Realty Affiliates LLC** represented the Debtor and/or Debtor-controlled entities in connection with the purchase and sale of Taconic, that (v) **Mary \"Muffin\" Dowdle** and (vi) **Ginnel Associates, Inc.** (DBA **Ginnel Real Estate**) represented the Debtor and/or Debtor-controlled entities in connection with\n\n<sup>2</sup> *Corrected Mem. of Decision Granting in Part Mot. for Prelim. Inj.* ¶ 7, Adv. Proc. No. 22-05032 [Docket No. 133].\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 6 of 1063\n\nthe potential purchase of real property in Greenwich, Connecticut, and that (vii) **Zhizhe \"Frank\" Dong** and (viii) **Redfin Corporation** represented the Debtor and/or Debtorcontrolled entities in connection with the potential purchase of real property in Greenwich, Connecticut. Additionally, (ix) **Brown Harris Stevens** assisted the Debtor in connection with the purchase of the Sherry Netherlands condominium located at 781 Fifth Avenue, New York, NY 10022 (apartments 1801 and 1519). Therefore, each may have information, documents, and records related to the transactions, the properties, and Debtor's interest therein;\n\n**(e) Alex Hadjicharalambous** is affiliated with G Club (with respect to which 2004 discovery was granted in connection with the Second Omnibus Motion) and is believed to be employed by Freedom Media Ventures Ltd. and/or and the HCHK Entities (with respect to which 2004 discovery was granted in connection with the Second Omnibus Motion), and all of which are affiliated with the Debtor-affiliated Himalaya Exchange cryptocurrency business, which this Court has found \"serve[s] the purposes of the Debtor, serve[s] as business vehicles for the Debtor, and their members are personally loyal to the Debtor.\"<sup>3</sup> Mr. Hadjicharalambous is therefore likely in possession of documents relevant to the Trustee's investigation;\n\n**(f) Min Yang** (AKA **Yang Min**), is alleged, among other things, to exercise financial control of the Rule of Law Foundation III Inc., which was founded by the Debtor (and with respect to which 2004 discovery was granted in connection with the Affiliates 2004 Motion), and is therefore likely in possession of documents relevant to the Trustee's investigation;\n\n<sup>3</sup> *Corrected Mem. of Decision Granting in Part Mot. for Prelim. Inj.* ¶ 7, Adv. Proc. No. 22-05032 [Docket No. 133].\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 7 of 1063\n\n**(g) Lihong \"Sara\" Wei Lafrenz** is alleged, among other things, to have formed and operated Voice of Guo Media, Inc. (with respect to whom 2004 discovery was granted in connection with the Affiliates 2004 Motion) which, along with GTV Media Group Inc. and Saraca Media Group Inc., was the subject of an Order Instituting Cease-and-Desist Proceedings filed by the U.S. Securities and Exchange Commission (the \"SEC\"), which resulted in an aggregate obligation to pay to the SEC more than \\$539 million in civil penalties, disgorgement, and interest. <sup>4</sup> Accordingly, she is likely to have relevant documents relevant to the Trustee's investigation given her connections to the Debtor's web of entities;\n\n**(h)** (i) **Qing \"Serena\" Cai** and (ii) **Ding G. Wang a/k/a Dinggang Wang** are affiliates of the Debtor who, among other ties, are purported to have resided at 33 Ferncliff Rd., Cos Cob, Connecticut 06807, a residential property previously owned by Greenwich Land LLC (with respect to which 2004 discovery was granted in connection with the Affiliates 2004 Motion), which is purportedly owned by the Debtor's purported wife, Hing Chi Ngok (with respect to which 2004 discovery was granted in connection with the Affiliates 2004 Motion). They are therefore likely in possession of documents relevant to the Trustee's investigation;\n\n**(i) Christodoulos G. Vassiliades & Co. LLC**, is a Cyprus-based law firm that documents have shown transferred significant funds to bank accounts controlled by the Debtor, and is therefore likely in possession of documents relevant to the Trustee's investigation;\n\n<sup>4</sup> *See* U.S. Securities and Exchange Commission, Order, *In the Matter of GTV Media Group, Inc., Saraca Media Group, Inc., and Voice of Guo Media, Inc.*, Admin. Proc. File No. 3-20537, Release No. 10979 (dated Sept. 13, 2021).\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 8 of 1063\n\n**(j) Liberty Jet Management** appears to have provided services to the Debtor and/or Related Persons with respect to private aircraft. Liberty Jet Management is therefore likely in possession of documents relevant to the Trustee's investigation, including documents relating to the Debtor's aircraft, the maintenance of the Debtor's aircraft, expenses associated with the Debtor's aircraft, and revenue generated by the Debtor's aircraft;\n\n**(k)** (i) **Mimaii NZ Limited**, (ii) **Tong Le Internatiional Trading Co., Ltd.**, (iii) **Macaron Limited**, and (iv) **Joyord Sportswear Limited** were disclosed to the Court by the Debtor's counsel as \"intermediary entities\" used to effectuate payment by Qiang Guo, the Debtor's son, of the Debtor's counsel's fees, and are therefore likely in possession of documents relevant to the Trustee's investigation;\n\n**(l)** (i) **Prime Trust LLC** is purported to be a financial infrastructure and transaction technology service company which transferred \\$37 million (currently held in escrow by U.S. Bank National Association in connection with the Lady May) to HK USA's counsel prior to its transfer to U.S. Bank National Association, and which has been alleged to be an intermediate institution which has assisted, among others, (ii) **RBB Bancorp and/or Royal Business Bank** in receiving funds from individuals in connection with the Debtor's cryptocurrency business. Both are therefore likely in possession of documents relevant to the Trustee's investigation;\n\n(**m**) **Marcum LLP** is an accounting and advisory firm which prepared tax returns for HCHK Property Management, Inc., HCHK Technologies, Inc., and Lexington Property and Staffing, Inc. (with respect to which 2004 discovery was granted in connection with the Second Omnibus Motion), entities linked to the Debtor and several Related Persons.\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 9 of 1063\n\nMarcum LLP is therefore likely in possession of documents relevant to the Trustee's investigation;\n\n**(n)** (i) **HHS Capital Inc.**, a Florida based entity, (ii) **Huk Trading Inc.**, a Delaware entity, (iii) **FungWan Trading Inc.**, a Delaware entity, (v) **Pixshow Film Inc.**, a Delaware entity, (vi) **Sirius Networking Inc.**, a Delaware entity, and (vii) **Brent Petro Inc.**, registered in Texas, are all alleged to be intermediary entities that have effectuated payments to ACA Capital Limited, HCHK Property Management Inc., Crane Advisory Group LLC, HCHK Technologies Inc., and/or G Club Operation LLC (with respect to which 2004 discovery was granted in connection with certain 2004 Motions). Therefore, they are likely in possession of documents relevant to the Trustee's investigation;\n\n**(o) Medical Supply System International LLC** is an Arizona-based entity that is believed to have transferred significant funds to bank accounts controlled by the Debtor, which is therefore likely in possession of documents relevant to the Trustee's investigation;\n\n(**p**) **Leading Shine NY Ltd.** is a Delaware entity for which the Debtor's associate and employee Yvette Wang has purported to be an officer and beneficial owner, and which has been involved in numerous transactions that the Trustee believes were undertaken on behalf of the Debtor, including with entities purportedly owned by the Debtor's family members. It is therefore likely in possession of documents relevant to the Trustee's investigation;\n\n(**q**) **Oasis Tech Limited** is a New Zealand-based entity which has been alleged to have been registered by affiliates of the Debtor and to have been involved in the fraudulent transfers or purported cryptocurrency transfers related to the Debtor; it is therefore likely in possession of documents relevant to the Trustee's investigation; and\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 10 of 1063\n\n**(r)** Finally, the Trustee requests authority to issue subpoenas to certain affiliates of prior examinees as to which the Court has already authorized Bankruptcy Rule 2004 Discovery. The Trustee has determined, in serving and/or conferring with the prior examinees, that it may also be fruitful to seek documents and information from these affiliated entities. More specifically, the Trustee requests authority to issue Bankruptcy Rule 2004 subpoenas to: (i) **Manufacturers and Traders Trust Company d/b/a M & T Bank** (the Court authorized the Trustee to subpoena M&T Bank Corporation pursuant to the Third Omnibus Motion), (ii) **Capital One, NA** (the Court authorized the Trustee to subpoena Capital One Financial Corporation pursuant to the Second Omnibus Motion), (iii) **Amazon Web Services LLC** (the Court authorized the Trustee to subpoena Amazon.com, Inc. pursuant to the Second Omnibus Motion), and (iv) **HSBC Bank USA, N.A.** (the Court authorized the Trustee to subpoena HSBC Holdings PLC pursuant to the First Omnibus Motion).\n\n#### **RELIEF REQUESTED**\n\n10. The Trustee seeks entry of an order, in substantially the form of the Proposed Order, pursuant to Bankruptcy Rule 2004(a) and Local Rule 2004-1, authorizing the Trustee to conduct the examination of the Examinees included on Exhibit B.\n\n## **BASIS FOR RELIEF REQUESTED**\n\n11. Pursuant to Rule 2004(a), on application of a party in interest, the Court may order the examination of any person or entity. The scope of an examination authorized under Rule 2004 is exceedingly broad and may relate to the \"acts, conduct, or property or to the liabilities and financial condition of the debtor, or to any matter which may affect the administration of the debtor's estate.\" Fed. R. Bankr. P. 2004(b).\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 11 of 1063\n\n12. \"The purpose of a Rule 2004 examination is to assist a party in interest in determining the nature and extent of the bankruptcy estate, revealing assets, examining transactions and assessing whether wrongdoing has occurred.\" *In re Transmar Commodity Group Ltd.*, 2018 WL 4006324, at \\*4 (Bankr. S.D.N.Y. Aug. 17, 2018) (internal quotation and citation omitted). This includes revealing the nature and extent of the estate and in discovering assets of the debtor that may have been intentionally or unintentionally concealed. *See In re Bennett Funding Group, Inc.*, 203 B.R. 24, 27-28 (Bankr. N.D.N.Y. 1996). *See also In re Millennium Lab Holdings II, LLC*, 562 B.R. 614, 626 (Bankr. D. Del. 2016) (\"Legitimate goals of Rule 2004 examinations include discovering assets, examining transactions, and determining whether wrongdoing has occurred.\" (internal quotation and citation omitted)).\n\n13. In the declaration he submitted on March 20, 2022 in support of the filing of this case, the Debtor represented that among the purposes for filing his chapter 11 case were \"to … (b) afford stakeholders an efficient opportunity to investigate [his] assets, liabilities, and financial affairs, given what [he] perceive[d] to be misunderstandings in that regard; [and] (c) establish what assets are estate property and, in turn, available for distribution to holders of allowed claims . . . .\" (Debtor's Declaration, ¶3). The investigation the Trustee seeks to perform is directly relevant to these stated purposes in that it will help the Trustee identify the Debtor's assets and liabilities in order to make distributions to creditors.\n\n14. The areas for inquiry herein are part of the Trustee's ongoing investigative efforts. As the investigation evolves, new avenues of inquiry become apparent and the need for additional discovery of persons, entities and areas of inquiry arises. Based on all the facts and evidence discussed above and as contained in the 2004 Motions, the Trustee seeks the investigative tools\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 12 of 1063\n\nafforded by Rule 2004 to further establish the true ownership of assets and to explore other potential assets about which the Trustee does not yet have knowledge.\n\n15. The Trustee requests that, in furtherance of his examinations, the Court direct the Examinees to provide documentation to the Trustee's counsel, as requested in the forms annexed hereto<sup>5</sup> and made a part hereof (the \"Proposed Subpoenas\"), within thirty (30) days of the service of a subpoena, substantially similar in form and substance to the Proposed Subpoenas, or such other time as agreed upon by the Trustee. These requests seek documents consisting of, among other things, the Examinees' communications with the Debtor regarding his financial condition, asset transfers, and corporate governance issues. The requests also seek the Examinees' internal files and correspondence on these same topics. 6\n\n16. The type of discovery that the Trustee will obtain from Examinees is well within the scope of Bankruptcy Rule 2004. Bankruptcy courts routinely provide for Rule 2004 discovery against professional firms when the discovery may identify and aid the recovery of assets for the benefit of the estate and creditors. *See, e.g., In re Bame,* 251 B.R. 367 (Bankr. D. Minn. 2000); *In*\n\n<sup>5</sup> Included in Exhibit B is an index of Proposed Subpoenas that would be served on the Examinees if this Motion is granted. The Trustee also attaches hereto as **Exhibits C-1 to C-57** the individualized Proposed Subpoenas, including the topics for discovery directed to each Examinee, which are substantially similar in form and substance.\n\n<sup>6</sup> The *Lady May* is among the topics and potential estate assets with respect to which the Trustee seeks discovery. The Trustee submits that such discovery is appropriate pursuant to Rule 2004 even though an adversary proceeding with respect to the ownership of the *Lady May* is presently pending. The Trustee's proposed discovery related to the *Lady May* relates to the overall pattern of conduct by the Debtor to evade his creditors and is therefore broader than discovery that will likely be sought in the adversary proceeding. It is also more efficient for all parties for the Trustee to take this discovery now given that the Trustee is otherwise seeking Rule 2004 discovery from the same parties on other topics—it would be inefficient for the Trustee to have to take discovery from these same parties twice. Moreover, this is not the classic situation where an adversary plaintiff, through Rule 2004, seeks to undermine the protections provided by the Bankruptcy Rules governing discovery in adversary proceedings. In fact, the pending proceeding doctrine, if it would apply at all (it does not) would not prevent the Trustee from seeking Rule 2004 discovery from individuals or entities who are not parties to the adversary proceeding concerning the *Lady May*. Finally, given the procedural posture of the adversary proceeding, the Trustee may not be able to obtain discovery in that proceeding at present. The Trustee needs its Rule 2004 discovery now, however, to adequately protect and preserve potential assets of the estate.\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 13 of 1063\n\n*re Horvath*, No. 13-34137, 2015 WL 2195060 (Bankr. N.D. Ohio May 7, 2015) (approving discovery related to claims on schedule of assets permissible from individual debtor where obtaining such discovery might increase the value of the debtor's estate).\n\n17. The Trustee submits that the facts set forth above constitute sufficient cause for the Court to order the production of documents pursuant to Rule 2004 from the Examinees. Although the Debtor is a necessary source of information and documents to help the Trustee uncover estate assets, seeking discovery from other parties, including the Examinees, is likely to significantly reduce the costs the estate would otherwise incur in identifying and recovering estate property. Indeed, documents in the possession of the Examinees could be among the most valuable to the Trustee's investigation.<sup>7</sup>\n\n18. Authorization of this Application is critical for the Trustee to fulfill the duties contemplated in the Trustee Order effectively, including specifically his mandate to \"locate the Debtor's assets for the benefit of creditors and the estate\" and \"investigate the Debtor's assets, liabilities, and financial affairs.\" (*See* Trustee Order at 15-16, 18).\n\n19. No party in interest, including the Debtor, shall suffer undue prejudice upon the granting of the relief sought in this Application.\n\n## **NO PRIOR REQUEST**\n\n20. No prior application for the relief requested herein has been made. The Trustee filed the prior 2004 Motions, including the Third Omnibus Motion, which the Court granted; however, those prior motions did not request to take discovery from the Examinees at issue here.\n\n<sup>7</sup> The Trustee also requests authority to serve the Proposed Subpoenas on affiliates or subsidiaries of the Examinees if in the course of the Trustee's investigation it is determined that such affiliates and subsidiaries of the Examinees are the parties in control of documents relating to the Examinees that are relevant to the Trustee's investigation.\n\n## **OBJECTION DEADLINE**\n\n21. The deadline to object to this Application is **March 31, 2023**, and in the absence of\n\na timely filed objection, the Proposed Order may enter without further notice and hearing.\n\n*[The rest of this page is intentionally blank.]*\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 15 of 1063\n\nWHEREFORE, the Trustee respectfully requests that the Court grant this Application and enter the Proposed Order, pursuant to Fed. R. Bankr. P. 2004(a), directing the examination of the Examinees, and directing the production of certain documents as set forth in the Requests for Production of Documents attached to the Proposed Subpoenas, and for such other and further relief as the Court may deem just and proper.\n\nDated: March 24, 2023 LUC A. DESPINS,\n\nNew Haven, Connecticut CHAPTER 11 TRUSTEE\n\nBy: */s/ Patrick R. Linsey \\_* Douglas S. Skalka (ct00616) Patrick R. Linsey (ct29437) NEUBERT, PEPE & MONTEITH, P.C. 195 Church Street, 13th Floor New Haven, Connecticut 06510 (203) 781-2847 dskalka@npmlaw.com plinsey@npmlaw.com\n\n*Counsel for the Chapter 11 Trustee*\n\n# **UNITED STATES BANKRUPTCY COURT DISTRICT OF CONNECTICUT BRIDGEPORT DIVISION**\n\n| ----------------------------------------------------------- | x           |                         |\n|-------------------------------------------------------------|-------------|-------------------------|\n| In re:                                                      | :<br>:      | Chapter 11              |\n| 1<br>HO WAN KWOK,<br>et al.,                                | :<br>:      | Case No. 22-50073 (JAM) |\n| Debtors.                                                    | :<br>:<br>: | (Jointly Administered)  |\n| ----------------------------------------------------------- | x           |                         |\n\n## **NOTICE OF OBJECTION DEADLINE**\n\nLuc Despins, as the appointed Chapter 11 Trustee to the Debtor's Estate (the \"Applicant\"), has filed an Application for Rule 2004 Examination of certain advisors and professionals, family members, business associates, corporate entities, and banking institutions identified in **Exhibit B** (the \"Rule 2004 Examination\") with the U.S. Bankruptcy Court for the District of Connecticut. Notice is hereby given that any objection or response to the Rule 2004 Examination must be filed with the Court no later than March 31, 2023, in accordance with Fed. R. Bankr. P. 2002(a) and 9014 and Local Bankr. R. 2004-1(c). In the absence of a timely filed objection, the proposed order regarding the Rule 2004 Examination *may* enter without further notice and hearing, see 11 U.S.C. section 102(1).\n\n*[THE REMAINDER OF THIS PAGE IS INTENTIONALLY LEFT BLANK.]*\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\nCase 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 17 of 1063\n\nDated: March 24, 2023 LUC A. DESPINS,\n\nNew Haven, Connecticut CHAPTER 11 TRUSTEE\n\nBy: */s/ Patrick R. Linsey* 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 the Chapter 11 Trustee*\n\n## **Exhibit A – Proposed Order**\n\n# **UNITED STATES BANKRUPTCY COURT DISTRICT OF CONNECTICUT BRIDGEPORT DIVISION**\n\n| ----------------------------------------------------------- | x           |                         |\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>:      | (Jointly Administered)  |\n| ----------------------------------------------------------- | x           |                         |\n\n# **[PROPOSED] ORDER GRANTING FOURTH SUPPLEMENTAL OMNIBUS MOTION OF CHAPTER 11 TRUSTEE FOR ENTRY OF ORDER UNDER BANKRUPTCY RULE 2004 AND LOCAL RULE 2004-1 AUTHORIZING DISCOVERY WITH RESPECT TO ADDITIONAL ENTITIES AND INDIVIDUALS AFFILIATED WITH DEBTOR, RELEVANT BANKS AND ENTITIES DOING BUSINESS WITH DEBTOR AND AFFILIATED ENTITIES**\n\nUpon consideration of the Application seeking an order authorizing a Federal Rule of Bankruptcy Procedure 2004 examination of the Examinees listed on Exhibit B thereto (the \"Application\", ECF No. \\_\\_\\_\\_), filed by Luc Despins, as the appointed Chapter 11 Trustee to the Debtor's estate (the \"Applicant\"), after notice and a hearing, see 11 U.S.C. § 102(1), it appearing that cause exists to grant the requested relief as conditioned hereafter; it is hereby\n\n**ORDERED**: The Rule 2004 Motion is granted as set forth below.\n\n**ORDERED**: Neubert, Pepe & Monteith, P.C., as counsel for the Trustee, is hereby authorized to sign Subpoenas in a form substantially similar to the Subpoenas attached to the Rule 2004 Motion as Exhibits C-1 to C-57 and to serve the Subpoenas, along with a copy of this Order, in accordance with Bankruptcy Rule 2004 requiring examination and the production of documents by the Examinees listed on Exhibit B to the Application.\n\n**ORDERED**: Subject to any rights under the Federal Rules of Bankruptcy Procedure, the Federal Rules of Civil Procedure, and applicable Local Rules, and unless otherwise ordered by the Court, the Examinees are hereby directed to produce all documents within 30 days of the service of the Subpoena, or such other time as agreed upon by the Trustee. To the extent an Examinee does not produce any documents requested in the Subpoena on the basis of some privilege, the Examinee is hereby directed to produce to the Trustee a privilege log that comports\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\nCase 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 20 of 1063\n\nwith Fed. R. Civ. P. 45(e)(2), made applicable by Fed. R. Bankr. P. 9016, and D. Conn. L. Civ. R. 26(e), within 30 days of service of the Subpoena, or such other time as agreed upon by the Trustee.\n\n**ORDERED**: The Examinees are hereby directed to ensure that all documents and other information, including without limitation in any electronic format, requested in the Subpoenas or otherwise relevant to the Debtor, his business, assets, liabilities, financial condition, or this Chapter 11 case, are properly maintained, are available for production, inspection and copying, and are not destroyed.\n\n**ORDERED**: Neubert, Pepe & Monteith, P.C., as counsel for the Trustee, is hereby authorized, without further order of this Court, to take the testimony of one or more representatives of any Examinee listed on Exhibit B to the Application by examination under Bankruptcy Rule 2004 either at the offices of Neubert, Pepe & Monteith, 195 Church Street, 13th Floor, New Haven, CT 06510, at the offices of Paul Hastings LLP, 200 Park Avenue, New York, NY 10166, or at such other place that is mutually acceptable to the parties, on a date acceptable to the Trustee, which, at the election of the Trustee, shall be not less than 14 calendar days after the production of documents by the proposed examinee in compliance with the Subpoena and this Order pursuant to Bankruptcy Rule 2004, and such examination shall continue from day to day until completed.\n\nDated: \\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_, 2023\n\nJulie A. Manning, United States Bankruptcy Judge\n\n\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\n\n# **Exhibit B**\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 22 of 1063\n\n| Discovery Party              | Address                                                                                                                                                                                      | Subpoena Index |\n|------------------------------|----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|----------------|\n| G-EDU Inc.                   | c/o Yue Zhou<br>301 West 110 Street, Apt. 8E<br>New York, NY 10026                                                                                                                           | Exhibit C-1    |\n| GFashion Media Group<br>Inc. | 5639 W. Sunset Blvd.<br>Los Angeles, CA 90028                                                                                                                                                | Exhibit C-2    |\n|                              | c/o Corporate Creations Network Inc.<br>5901 W. Century Blvd., #750<br>Los Angeles, CA 90045                                                                                                 |                |\n| G Translators Pty Ltd        | c/o Ya Li<br>Elevated Accounting<br>Ground Floor, 99 Coventry Street<br>Southbank, VIC 3006<br>Australia<br>Shop 1<br>20-24 Ninth Avenue<br>Campsie, NSW 2194<br>Australia                   | Exhibit C-3    |\n| Martha Jeffery               | 80 Northfield St.<br>Greenwich, Connecticut 06830-4618<br>Sotheby's International Realty -<br>Greenwich<br>Brokerage<br>One Pickwick Plaza<br>Greenwich, Connecticut<br>06830, United States | Exhibit C-4    |\n| Emile P de Neree             | 12 Flying Cloud Rd<br>Stamford, Connecticut 06902-7723<br>Compass Real Estate<br>200 Greenwich Ave<br>3rd Floor<br>Greenwich, Connecticut 06830                                              | Exhibit C-5    |\n| Zhizhe \"Frank\"<br>Dong       | 165 Audubon Ave Apt 6,<br>New York, New York 10033-8764<br>44 S. Broadway<br>Ste 100, #225<br>White Plains, New York 10601                                                                   | Exhibit C-6    |\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 23 of 1063\n\n| Discovery Party                           | Address                                                                                                                                                                                                                                                     | Subpoena Index |\n|-------------------------------------------|-------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|----------------|\n| Mary Dowdle<br>(a/k/a<br>Muffin Dowdle)   | 41 Smith Road<br>Sharon, CT 06069-2401                                                                                                                                                                                                                      | Exhibit C-7    |\n| Alex<br>Hadjicharalambous                 | 2318 28th Street<br>Astoria, NY 11105-2802<br>718-545-8889                                                                                                                                                                                                  | Exhibit C-8    |\n| Min Yang                                  | 10740 Queens Blvd.<br>Apt 11G<br>Forest Hills, NY 11375-4211                                                                                                                                                                                                | Exhibit C-9    |\n| Christodoulos G.<br>Vassiliades & Co. LLC | Ledra House<br>15 Agiou Pavlou Street,<br>Agios Andreas, CY-1105<br>Nicosia, Cyprus<br>P.O. Box 24444<br>CY-1704 Nicosia, Cyprus<br>Interconsult (BVI) Limited<br>3rd Floor, Yamraj Building, Market Square<br>Road Town<br>Tortola, British Virgin Islands | Exhibit C-10   |\n| Liberty Jet<br>Management                 | 29 Schaefer Drive<br>Ronkonkoma, NY 11779<br>220 Townsend Square<br>Oyster Bay, NY 11771<br>c/o American Incorporators Ltd.<br>1013 Centre Road, Suite 403-A<br>Wilmington, DE 19805                                                                        | Exhibit C-11   |\n\n| Discovery Party       | Address                                      | Subpoena Index |\n|-----------------------|----------------------------------------------|----------------|\n| Santander Bank, N. A. | 75 State Street Map                          | Exhibit C-12   |\n|                       | Boston, Massachusetts 02109                  |                |\n|                       |                                              |                |\n|                       | Santander Group City<br>Av. de Cantabria s/n |                |\n|                       | 28660 Boadilla<br>del Monte Madrid-Spain     |                |\n| First Republic Bank   | 111 Pine Street                              | Exhibit C-13   |\n|                       | 2nd Floor                                    |                |\n|                       | San Francisco, CA 94111                      |                |\n|                       |                                              |                |\n| Silvergate Bank       | 4250 Executive Square, Suite 300             | Exhibit C-14   |\n|                       | La Jolla, CA 92037                           |                |\n|                       | Attn: John M. Bonino, Chief Legal Officer    |                |\n|                       | c/o CT Corporation System                    |                |\n|                       | 28 Liberty Street                            |                |\n|                       | New York, NY 10005                           |                |\n| The Bank of Princeton | 183 Bayard Lane                              | Exhibit C-15   |\n|                       | Princeton, NJ 08540                          |                |\n|                       | Attn: Daniel J. O'Donnell                    |                |\n|                       | 470 W. Cheltenham Avenue                     |                |\n|                       | Philadelphia, PA 19126                       |                |\n| DBS Bank Ltd.         | c/o Thomas Joseph McCabe                     | Exhibit C-16   |\n|                       | 300 South Grand Avenue                       |                |\n|                       | Suite 3075                                   |                |\n|                       | Los Angeles, CA 90071                        |                |\n|                       | 12 Marina Boulevard                          |                |\n|                       | Marina Bay Financial Centre Tower Three      |                |\n|                       | Singapore 018982                             |                |\n|                       | Singapore                                    |                |\n| The First Bank of     | 444 East Putnam Avenue                       | Exhibit C-17   |\n| Greenwich             | Cos Cob, Connecticut 06807                   |                |\n|                       | c/o Bruno J. Gioffre                         |                |\n|                       | Gioffre and Gioffre, PC                      |                |\n|                       | 2900 Westchester Avenue                      |                |\n|                       | Suite 206                                    |                |\n|                       | Purchase, NY 10577                           |                |\n\n| Discovery Party         | Address                                                     | Subpoena Index |\n|-------------------------|-------------------------------------------------------------|----------------|\n| Mercantile Bank         | 604 Hoare Street                                            | Exhibit C-18   |\n| International Corp.     | Suite 302                                                   |                |\n|                         | San Juan, Puerto Rico 00907-3614                            |                |\n|                         |                                                             |                |\n|                         |                                                             |                |\n| Mercantile Global       | 4306 Yoakum Blvd, Suite 200                                 | Exhibit C-19   |\n| Holdings, Inc.          | Houston, Texas 77006                                        |                |\n|                         |                                                             |                |\n|                         | c/o Harvard Business Services, Inc.                         |                |\n|                         | 16192 Coastal Hwy                                           |                |\n|                         | Lewes, DE 19958                                             |                |\n| Hamilton M&A Fund       | c/o McGrath Tonner Corporate Services                       | Exhibit C-20   |\n| SP                      | Limited<br>P. O. Box 446                                    |                |\n|                         | 5th Floor, Genesis Building                                 |                |\n|                         | Genesis Close                                               |                |\n|                         | George Town KY1-1106                                        |                |\n|                         | Cayman Islands                                              |                |\n| Hamilton Opportunity    | c/o McGrath Tonner Corporate Services                       | Exhibit C-21   |\n| Fund SPC                | Limited                                                     |                |\n|                         | P. O. Box 446                                               |                |\n|                         | 5th Floor, Genesis Building                                 |                |\n|                         | Genesis Close                                               |                |\n|                         | George Town KY1-1106<br>Cayman Islands                      |                |\n|                         |                                                             |                |\n|                         | 71-75 Aurora House                                          |                |\n|                         | Uxbridge Rd                                                 |                |\n|                         | Earling, London, United Kingdom<br>W5 5SL                   |                |\n| Ginnel Associates, Inc. | 493 Bedford Center Road                                     | Exhibit C-22   |\n| (d/b/a<br>Ginnel Real   | Bedford Hills, New York<br>10507                            |                |\n| Estate)                 |                                                             |                |\n|                         | c/o Daniel H. Ginnel                                        |                |\n|                         | 493 Bedford Center Road<br>Bedford Hills, New York<br>10507 |                |\n| Redfin Corporation      | 1099 Stewart Street, Suite 600                              | Exhibit C-23   |\n|                         | Seattle, WA, 98101                                          |                |\n|                         |                                                             |                |\n|                         | c/o Legalinc Corporate Services Inc.                        |                |\n|                         | 30 Old Kings Highway South                                  |                |\n|                         | Darien, Connecticut 06820                                   |                |\n\n| Discovery Party                                                               | Address                                                                                                                                                                                                    | Subpoena Index |\n|-------------------------------------------------------------------------------|------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|----------------|\n|                                                                               | c/o Legalinc Corporate Services Inc.<br>1967 Wehrle Drive, Suite 1 #086<br>Buffalo, NY 143221                                                                                                              |                |\n| Sotheby's International<br>Realty Affiliates LLC                              | 3290 Northside Parkway<br>Suite 200<br>Atlanta, Georgia 30327<br>175 Park Avenue<br>Madison, NJ 07940<br>c/o<br>Corporate Creations Network Inc.<br>600 Mamaroneck Avenue, Suite 400<br>Harrison, NY 10528 | Exhibit C-24   |\n| NRT New England<br>LLC (d/b/a<br>Coldwell<br>Banker Residential<br>Brokerage) | c/o Corporate Creations Network Inc.<br>6 Landmark Square<br>4th Floor<br>Stamford, Connecticut<br>06901                                                                                                   | Exhibit C-25   |\n| David Fallon                                                                  | 71-75 Aurora House<br>Uxbridge Rd<br>Earling, London, United Kingdom W5 5SL                                                                                                                                | Exhibit C-26   |\n| Mimaii NZ Limited                                                             | c/o Wen Soo Lo<br>51 Joseph Banks Drive<br>Whitby, Porirua, 5024 New Zealand                                                                                                                               | Exhibit C-27   |\n| Tong Le Internatiional<br>Trading Co., Ltd.                                   | Office No.<br>12,<br>19/F,<br>Ho King Comm Ctr,<br>NO.<br>2-16 Fa Yuen St,<br>Mongkok, KLN, Hong Kong                                                                                                      | Exhibit C-28   |\n\n| Discovery Party                             | Address                                                                              | Subpoena Index |\n|---------------------------------------------|--------------------------------------------------------------------------------------|----------------|\n| Manufacturers and<br>Traders Trust          | c/o Corporation Service Company<br>251 Little Falls Drive                            | Exhibit C-29   |\n| Company (d/b/a M & T<br>Bank)               | Wilmington, DE 19808                                                                 |                |\n|                                             | c/o Corporation Service Company<br>Goodwin Square                                    |                |\n|                                             | 225 Asylum Street, 20th Floor<br>Hartford, CT, 06103                                 |                |\n| Capital One, NA                             | 1680 Capital One Drive<br>McLean, VA 22102-3407                                      | Exhibit C-30   |\n|                                             | c/o Corporation Service Company<br>100 Shockoe Slip, Fl 2<br>Richmond, VA 23219-4100 |                |\n| Amazon Web Services<br>LLC                  |                                                                                      | Exhibit C-31   |\n|                                             |                                                                                      |                |\n| HSBC Bank USA,<br>N.A.                      | 452 Fifth Avenue<br>New York, NY 10018                                               | Exhibit C-32   |\n|                                             |                                                                                      |                |\n|                                             | 1800 Tysons Blvd.<br>Suite 50                                                        |                |\n|                                             | McLean, VA 22102                                                                     |                |\n|                                             | c/o CT Corporation System                                                            |                |\n|                                             | 67 Burnside Avenue<br>East Hartford, CT, 06108-3408                                  |                |\n| Bank of China –<br>New                      | Bank of China –<br>New York Branch                                                   | Exhibit C-33   |\n| York Branch and/or<br>Bank of China Limited | 1045 Avenue of the Americas<br>New York, New York 10018                              |                |\n|                                             | Bank of China –<br>New York Branch                                                   |                |\n|                                             | 410 Madison Avenue<br>New York, NY 10017                                             |                |\n|                                             | Bank of China Limited<br>7 Bryant Park<br>Lobby A<br>New York, New York, 10018       |                |\n\n| Discovery Party                     | Address                                                                                                                                       | Subpoena Index |\n|-------------------------------------|-----------------------------------------------------------------------------------------------------------------------------------------------|----------------|\n| U.S. Bank National<br>Association   | 800 Nicollet Mall<br>Minneapolis, MN 55402                                                                                                    | Exhibit C-34   |\n|                                     | 425 Walnut St<br>Cincinnati, OH 45202                                                                                                         |                |\n| Macaron Limited                     | The Gas Light Lower Warrengate<br>Wakefield<br>West Yorkshire<br>England WF1 1SA                                                              | Exhibit C-35   |\n| Lihong \"Sara\" Wei<br>Lafrenz        | 14747 N Northsight Blvd<br>Ste 111<br>Scottsdale, Arizona 85260-2633<br>1850 W Orange Grove Rd.<br>Tucson, Arizona 85704                      | Exhibit C-36   |\n| Qing \"Serena\" Cai                   | 7636 Heavenly Peak St.<br>Las Vegas, NV 89166-5202                                                                                            | Exhibit C-37   |\n| Ding G. Wang a/k/a<br>Dinggang Wang | 7636 Heavenly Peak St.<br>Las Vegas, NV 89166-5202                                                                                            | Exhibit C-38   |\n| Prime Trust LLC                     | 330 S Rampart Blvd., Suite 260<br>Las Vegas, NV 89145<br>c/o CT Corporation System<br>3800 N Central Avenue<br>Suite 460<br>Phoenix, AZ 85012 | Exhibit C-39   |\n\n| Discovery Party                                                              | Address                                                                                                                | Subpoena Index |\n|------------------------------------------------------------------------------|------------------------------------------------------------------------------------------------------------------------|----------------|\n| RBB Bancorp and/or<br>Royal Business Bank                                    | 1055 Wilshire Blvd.<br>12th Floor<br>Los Angeles, California 90017                                                     | Exhibit C-40   |\n| Medici Bank<br>International LLC                                             | 1250 Ponce de Leon Avenue<br>San Juan, PR 00907                                                                        | Exhibit C-41   |\n| Deltec Bank & Trust<br>Limited                                               | Deltec House, Lyford Cay<br>Nassau, Bahamas                                                                            | Exhibit C-42   |\n| National Australia<br>Bank Limited                                           | 800 Bourke Street<br>Level 4<br>Docklands, VIC Australia<br>395 Bourke Street<br>Level 28<br>Melbourne, Victoria, 3000 | Exhibit C-43   |\n| Metropolitan<br>Commercial Bank<br>and/or Metropolitan<br>Bank Holding Corp. | 99 Park Avenue<br>12th Floor<br>New York, NY 10016                                                                     | Exhibit C-44   |\n| Open Bank                                                                    | 1000 Wilshire Blvd.<br>#500<br>Los Angeles, CA 90017                                                                   | Exhibit C-45   |\n\n| Discovery Party        | Address                                                                               | Subpoena Index |\n|------------------------|---------------------------------------------------------------------------------------|----------------|\n| Marcum LLP             | 730 3rd Avenue<br>11th Floor<br>New York, NY 10017                                    | Exhibit C-46   |\n| Brent Petro Inc.       | 108 West 13th St<br>Wilmington DE 19801<br>8100 Cambridge St. 128<br>Houston TX 77054 | Exhibit C-47   |\n| Sirius Networking Inc. | 651 N Broad St.<br>Suite 206<br>Middletown,<br>DE 19709                               | Exhibit C-48   |\n| Pixshow Film Inc.      | 108 West 13th St.<br>Wilmington DE 19801                                              | Exhibit C-49   |\n| FungWan Trading Inc.   | 108 West 13th St.<br>Wilmington DE 19801                                              | Exhibit C-50   |\n| Huk Trading Inc.       | 651 N Broad St<br>Suite 206<br>Middletown,<br>DE 19709                                | Exhibit C-51   |\n| HHS Capital Inc.       | 14660 SW 14 St.<br>Pembroke Pines, FL 33027                                           | Exhibit C-52   |\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 31 of 1063\n\n| Discovery Party                            | Address                                                                         | Subpoena Index |\n|--------------------------------------------|---------------------------------------------------------------------------------|----------------|\n| Medical Supply System<br>International LLC | 3101 N. Central Ave<br>Ste 183 #2727<br>Phoenix, Maricopa, AZ 85012             | Exhibit C-53   |\n| Leading Shine NY Ltd.                      | 3411 Silverside Road<br>Tatnall Building #104<br>Wilmington, Delaware<br>19810  | Exhibit C-54   |\n| Oasis Tech Limited                         | 151 Marua Road<br>Mount Wellington<br>Auckland, 1051<br>New Zealand             | Exhibit C-55   |\n| Joyord Sportswear<br>Limited               | Room 1401, Cambridge House<br>26-28 Cameron Road<br>Tsimshatsui, KLN, Hong Kong | Exhibit C-56   |\n| Brown Harris Stevens                       | 445 Park Avenue<br>New York, NY 10022<br>Phone: 212-906-9200                    | Exhibit C-57   |\n\n# **Exhibit C**\n\nCase 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 33 of 1063\n\n# Exhibit C-1\n\n#### B2540 (Form 2540 – Subpoena for Rule 2004 Examination) (12/15) Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 34 of\n\n1063\n\nUNITED STATES BANKRUPTCY COURT\n\n**District of Connecticut**\n\nIn re HO WAN KWOK, *et al*.,\n\n<sup>1</sup> Case No. 22-50073 (JAM) Debtor Chapter 11\n\n(Jointly Administered)\n\n# **SUBPOENA FOR RULE 2004 EXAMINATION**\n\nTo: **G-EDU Inc.**\n\n(*Name of person to whom the subpoena is directed*)\n\n*Testimony:* **YOU ARE COMMANDED** to appear at the time, date, and place set forth below to testify at an examination under Rule 2004, Federal Rules of Bankruptcy Procedure. A copy of the court order authorizing the examination is attached.\n\n| PLACE                    | DATE AND TIME |\n|--------------------------|---------------|\n| Paul Hastings LLP        |               |\n| 200 Park Avenue          | [TBD]         |\n| New York, New York 10166 |               |\n|                          |               |\n\nThe examination will be recorded by this method: **Court reporter/stenographer**\n\n*Production:* You, or your representatives, must also bring with you to the examination the following documents, electronically stored information, or objects, and must permit inspection, copying, testing, or sampling of the material:\n\n#### **See Requests for Production of Documents, attached hereto.**\n\nThe following provisions of Fed. R. Civ. P. 45, made applicable in bankruptcy cases by Fed. R. Bankr. P. 9016, are attached – Rule 45(c), relating to the place of compliance; Rule 45(d), relating to your protection as a person subject to a subpoena; and Rule 45(e) and 45(g), relating to your duty to respond to this subpoena and the potential consequences of not doing so.\n\nDate: **March , 2023**\n\nCLERK OF COURT\n\nOR\n\n*Signature of Clerk or Deputy Clerk Attorney's signature*\n\nThe name, address, email address, and telephone number of the attorney representing Luc A. Despins, Chapter 11 Trustee, who issues or requests this subpoena, are:\n\n**Douglas S. Skalka, Esq.; Neubert, Pepe & Monteith, P.C.; 195 Church Street, New Haven, Connecticut 06510 dskalka@npmlaw.com; (203) 821-2000**\n\n**Notice to the person who issues or requests this subpoena**\n\nIf this subpoena commands the production of documents, electronically stored information, or tangible things, or the inspection of premises before trial, a notice and a copy of this subpoena must be served on each party before it is served on the person to whom it is directed. Fed. R. Civ. P. 45(a)(4).\n\nSoftware Copyright (c) 1996-2022 Best Case, LLC - www.bestcase.com Best Case Bankruptcy 1 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\n#### **PROOF OF SERVICE**\n\n**(This section should not be filed with the court unless required by Fed. R. Civ. P. 45.)**\n\nI received this subpoena for (*name of individual and title, if any*): on (*date*) .\n\nI served the subpoena by delivering a copy to the named person as follows:\n\non *(date)* ; or\n\nI returned the subpoena unexecuted because:\n\nUnless the subpoena was issued on behalf of the United States, or one of its officers or agents, I have also tendered to the witness the fees for one day's attendance, and the mileage allowed by law, in the amount of \\$ .\n\nMy fees are \\$ for travel and \\$ for services, for a total of \\$ .\n\nI declare under penalty of perjury that this information is true and correct.\n\nDate:\n\n*Server's signature*\n\n*Printed name and title*\n\n*Server's address*\n\nAdditional information concerning attempted service, etc.:\n\n#### **Federal Rule of Civil Procedure 45(c), (d), (e), and (g) (Effective 12/1/13) (made applicable in bankruptcy cases by Rule 9016, Federal Rules of Bankruptcy Procedure)**\n\n#### **(c) Place of compliance.**\n\n*(1) For a Trial, Hearing, or Deposition.* A subpoena may command a person to attend a trial, hearing, or deposition only as follows:\n\n(A) within 100 miles of where the person resides, is employed, or regularly transacts business in person; or\n\n(B) within the state where the person resides, is employed, or regularly transacts business in person, if the person\n\n(i) is a party or a party's officer; or\n\n(ii) is commanded to attend a trial and would not incur substantial expense.\n\n*(2) For Other Discovery.* A subpoena may command:\n\n(A) production of documents, or electronically stored information, or things at a place within 100 miles of where the person resides, is employed, or regularly transacts business in person; and\n\n(B) inspection of premises, at the premises to be inspected.\n\n#### **(d) Protecting a Person Subject to a Subpoena; Enforcement.**\n\n*(1) Avoiding Undue Burden or Expense; Sanctions.* A party or attorney responsible for issuing and serving a subpoena must take reasonable steps to avoid imposing undue burden or expense on a person subject to the subpoena. The court for the district where compliance is required must enforce this duty and impose an appropriate sanction which may include lost earnings and reasonable attorney's fees — on a party or attorney who fails to comply.\n\n#### *(2) Command to Produce Materials or Permit Inspection.*\n\n*(A) Appearance Not Required.* A person commanded to produce documents, electronically stored information, or tangible things, or to permit the inspection of premises, need not appear in person at the place of production or inspection unless also commanded to appear for a deposition, hearing, or trial.\n\n*(B) Objections.* A person commanded to produce documents or tangible things or to permit inspection may serve on the party or attorney designated in the subpoena a written objection to inspecting, copying, testing or sampling any or all of the materials or to inspecting the premises — or to producing electronically stored information in the form or forms requested. The objection must be served before the earlier of the time specified for compliance or 14 days after the subpoena is served. If an objection is made, the following rules apply:\n\n(i) At any time, on notice to the commanded person, the serving party may move the court for the district where compliance is required for an order compelling production or inspection.\n\n(ii) These acts may be required only as directed in the order, and the order must protect a person who is neither a party nor a party's officer from significant expense resulting from compliance.\n\n#### *(3) Quashing or Modifying a Subpoena.*\n\n*(A) When Required.* On timely motion, the court for the district where compliance is required must quash or modify a subpoena that:\n\n(i) fails to allow a reasonable time to comply;\n\n(ii) requires a person to comply beyond the geographical limits specified in Rule 45(c);\n\n(iii) requires disclosure of privileged or other protected matter, if no exception or waiver applies; or\n\n(iv) subjects a person to undue burden.\n\n*(B) When Permitted.* To protect a person subject to or affected by a subpoena, the court for the district where compliance is required may, on motion, quash or modify the subpoena if it requires:\n\n(i) disclosing a trade secret or other confidential research, development, or commercial information; or\n\n(ii) disclosing an unretained expert's opinion or information that does not describe specific occurrences in dispute and results from the expert's study that was not requested by a party.\n\n(C) *Specifying Conditions as an Alternative.* In the circumstances described in Rule 45(d)(3)(B), the court may, instead of quashing or modifying a subpoena, order appearance or production under specified conditions if the serving party:\n\n(i) shows a substantial need for the testimony or material that cannot be otherwise met without undue hardship; and\n\n(ii) ensures that the subpoenaed person will be reasonably compensated.\n\n#### **(e) Duties in Responding to a Subpoena.**\n\n*(1) Producing Documents or Electronically Stored Information.* These procedures apply to producing documents or electronically stored information:\n\n*(A) Documents.* A person responding to a subpoena to produce documents must produce them as they are kept in the ordinary course of business or must organize and label them to correspond to the categories in the demand.\n\n*(B) Form for Producing Electronically Stored Information Not Specified.* If a subpoena does not specify a form for producing electronically stored information, the person responding must produce it in a form or forms in which it is ordinarily maintained or in a reasonably usable form or forms.\n\n*(C) Electronically Stored Information Produced in Only One Form.* The person responding need not produce the same electronically stored information in more than one form.\n\n*(D) Inaccessible Electronically Stored Information.* The person responding need not provide discovery of electronically stored information from sources that the person identifies as not reasonably accessible because of undue burden or cost. On motion to compel discovery or for a protective order, the person responding must show that the information is not reasonably accessible because of undue burden or cost. If that showing is made, the court may nonetheless order discovery from such sources if the requesting party shows good cause, considering the limitations of Rule 26(b)(2)(C). The court may specify conditions for the discovery.\n\n#### *(2) Claiming Privilege or Protection.*\n\n*(A) Information Withheld.* A person withholding subpoenaed information under a claim that it is privileged or subject to protection as trial-preparation material must: (i) expressly make the claim; and\n\n(ii) describe the nature of the withheld documents, communications, or tangible things in a manner that, without revealing information itself privileged or protected, will enable the parties to assess the claim.\n\n*(B) Information Produced.* If information produced in response to a subpoena is subject to a claim of privilege or of protection as trial-preparation material, the person making the claim may notify any party that received the information of the claim and the basis for it. After being notified, a party must promptly return, sequester, or destroy the specified information and any copies it has; must not use or disclose the information until the claim is resolved; must take reasonable steps to retrieve the information if the party disclosed it before being notified; and may promptly present the information under seal to the court for the district where compliance is required for a determination of the claim. The person who produced the information must preserve the information until the claim is resolved.\n\n**(g) Contempt.** The court for the district where compliance is required – and also, after a motion is transferred, the issuing court – may hold in contempt a person who, having been served, fails without adequate excuse to obey the subpoena or an order related to it.\n\nFor access to subpoena materials, see Fed.R.Civ.P.45(a) Committee Note (2013)\n\n…\n\n## **Requests for Production of Documents**\n\n## **I. INSTRUCTIONS**\n\n1. Unless otherwise indicated, the requests for documents set forth below, (the \"Requests,\" and each, a \"Request\"), must be responded to separately and specifically. Each Request shall be answered fully unless it is in good faith objected to, in which event the reason for Your objection shall be stated in detail, as set forth below. If an objection pertains only to a portion of a Request, or a word, phrase or clause contained within it, You are required to state Your objection to that portion only and to respond to the remainder of the Requests.\n\n2. Electronically stored information must be produced in accordance with the\n\nfollowing instructions:\n\n- a. Images. Black and white images must be 300 DPI Group IV single-page TIFF files. Color images must be produced in JPEG format. File names cannot contain embedded spaces or special characters (including the comma). Folder names cannot contain embedded spaces or special characters (including the comma). All TIFF image files must have a unique file name, i.e. Bates number. Images must be endorsed with sequential Bates numbers in the lower right corner of each image. The number of TIFF files per folder should not exceed 1000 files. Excel spreadsheets should have a placeholder image named by the Bates number of the file.\n- b. Image Load File\n\t- a. Concordance® Data File. The data file (.DAT) contains all of the fielded information that will be loaded into the Concordance® database. The first line of the .DAT file must be a header row identifying the field names. The .DAT file must use the following Concordance® default delimiters: Comma ASCII character (020) Quote þ ASCII character (254). Date fields should be provided in the format: mm/dd/yyyy. Date and time fields must be two separate fields. If documents includes imaged emails and attachments, the attachment fields must be included to preserve the parent/child relationship between an email and its attachments. An OCRPATH field must be included to provide the file path and name of the extracted text file on the produced storage media. The text file must be named after the FIRSTBATES. Do not include the text in the .DAT file. For Documents with native files, a LINK field must be included to provide the file path and\n\nname of the native file. The native file must be named after the FIRSTBATES.\n\n- b. Concordance Image® OR Opticon Cross-Reference File. The image crossreference file (.LOG or .OPT) links the images to the database records. It should be a comma-delimited file consisting of seven fields per line with a line in the cross-reference file for every image in the database with the following format: ImageID,VolumeLabel,ImageFilePath,DocumentBreak,FolderBreak,Box Break,PageCoun.\n- c. Document Text. Text must be produced as separate text files, not as fields within the .DAT file. The full path to the text file (OCRPATH) should be included in the .DAT file. It is recommended document level ANSI text files, named per the FIRSTBATES/Image Key. Extracted text files must be in a separate folder, and the number of text files per folder should not exceed 1,000 files. There should be no special characters (including commas in the folder names). Text files must be provided on a document level.\n- d. Native Production for Certain File Types. File types that reasonably require viewing in their native format for a full understanding of their content and meaning must be produced in native format. These include, but are not limited to, spreadsheets, spreadsheet-like files (Microsoft Excel, comma separated values, tab separated values, etc.), Microsoft PowerPoint or other special presentation files, database files, and audio/visual files. Provide an image of a Bates numbered slip sheet indicating the presence of a native file, and include the path to the native as a field in the .dat file. Name the produced native file with the Bates number corresponding to the slip sheet for the file. Group native files within incrementally named \"NATIVE\" directories, separate from images directories.\n- e. De-duplication. Produce a single copy of each electronic document for which exact duplicates exist. For email messages, consolidate duplicates based on MD5 hash generated from the BCC, Body, CC, From, IntMsgID, To, and Attach properties. For email attachments and standalone electronic files, consolidate duplicates based on MD5 hash of the entire file.\n- f. Metadata. Produce extracted metadata for each document in the form of a Concordance compliant load file (.dat). The first line of the .DAT file must be a header row identifying the field names. The .DAT file must use the following Concordance default delimiters: Comma , ASCII character (020) Quote þ ASCII character (254)\n\nDate fields should be provided in the format: mm/dd/yyyy. Date and time fields must be two separate fields. Required metadata listed below:\n\n# Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 39 of 1063\n\n| Field Name   | Sample Data              | Description                                                                                  |\n|--------------|--------------------------|----------------------------------------------------------------------------------------------|\n| FIRSTBATES   | EDC0000001               | First Bates number of native file document/email                                             |\n| LASTBATES    | EDC0000001               | Last Bates number of native file document/email<br>**The LASTBATES field should be populated |\n|              |                          | for single page                                                                              |\n| ATTACHRANGE  | EDC0000001<br>-          | Bates number of the first page of the parent                                                 |\n|              | EDC0000015               | document to the Bates number of the last page of                                             |\n|              |                          | the last attachment \"child\" document                                                         |\n| BEGATTACH    | EDC0000001               | First Bates number of attachment range                                                       |\n| ENDATTACH    | EDC0000015               | Last Bates number of attachment range                                                        |\n| CUSTODIAN    | Smith, John              | Email: Mailbox where the email resided                                                       |\n|              |                          | Native: Name of the individual or department                                                 |\n|              |                          | from whose files the document<br>originated                                                  |\n| FROM         | John Smith               | Email: Sender                                                                                |\n|              |                          | Native: Author(s) of document                                                                |\n|              |                          | **semi-colon should be used to separate                                                      |\n|              |                          | multiple entries                                                                             |\n| TO           | Coffman, Janice; LeeW    | Recipient(s)                                                                                 |\n|              | [mailto:LeeW@MSN.com]    | **semi-colon should be used to separate multiple                                             |\n|              |                          | entries                                                                                      |\n| CC           | Frank Thompson [mailto:  | Carbon copy recipient(s)                                                                     |\n|              | frank_Thompson@cdt.com]  | **semi-colon should be used to separate                                                      |\n|              |                          | multiple entries                                                                             |\n| BCC          | John Cain                | Blind carbon copy recipient(s)                                                               |\n|              |                          | **semi-colon should be used to separate                                                      |\n|              |                          | multiple entries                                                                             |\n| SUBJECT      | Board Meeting Minutes    | Email: Subject line of the email Native: Title                                               |\n|              |                          | of document (if available)                                                                   |\n| FILE_NAME    | BoardMeetingMinutes.docx | Native: Name of the original native file,                                                    |\n|              |                          | including extension                                                                          |\n| DATE_SENT    | 10/12/2010               | Email: Date the email was sent                                                               |\n|              |                          | Native: (empty)                                                                              |\n| TIME_SENT/   | 07:05 PM GMT             | Email: Time the email was sent/ Time zone in                                                 |\n| TIME_ZONE    |                          | which the emails were standardized                                                           |\n| TIME_ZONE    | GMT                      | The<br>time zone in which<br>the emails<br>were                                              |\n|              |                          | standardized during conversion.                                                              |\n| LINK         |  EDC0000001.msg   | Hyperlink to the email or native file document                                               |\n|              |                          | **The linked file must be named per the                                                      |\n|              |                          | FIRSTBATES number                                                                            |\n| FILE_EXTEN   | MSG                      | The file type extension                                                                      |\n|              |                          | representing                                                                                 |\n|              |                          | the Email or                                                                                 |\n| AUTHOR       | John Smith               | Email: (empty)                                                                               |\n|              |                          | Native: Author of the document                                                               |\n| DATE_CREATED | 10/10/2010               | Email: (empty)                                                                               |\n|              |                          | Native: Date the document was created                                                        |\n\n# Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 40 of 1063\n\n| TIME_CREATED | 10:25 AM                  | Email: (empty)                                  |\n|--------------|---------------------------|-------------------------------------------------|\n|              |                           | Native: Time the document was created           |\n|              |                           | **This data must be a separate field and cannot |\n|              |                           | be combined with the DATE_CREATED field         |\n| DATE_MOD     | 10/12/2010                | Email: (empty)                                  |\n|              |                           | Native: Date the document was last modified     |\n| TIME_MOD     | 07:00 PM                  | Email: (empty)                                  |\n|              |                           |                                                 |\n|              |                           | Native: Time the document was last modified     |\n|              |                           | **This data must be a separate field and cannot |\n|              |                           | be combined with the DATE_MOD field             |\n| DATE_ACCESSD | 10/12/2010                | Email: (empty)                                  |\n|              |                           | Native: Date the document was last accessed     |\n| TIME_ACCESSD | 07:00 PM                  | Email: (empty)                                  |\n|              |                           | Native: Time the document was last accessed     |\n|              |                           | **This data must be a separate field and cannot |\n|              |                           | be combined with the DATE_ACCESSD field         |\n| FILE_SIZE    | 5,952                     | Size of native file<br>document/email in KB     |\n| PGCOUNT      | 1                         | Number of pages in native file document/email   |\n| PATH         |   | Email: (empty)                                  |\n|              | Agenda.doc                | Native: Path where native file document was     |\n|              |                           | stored including original file name.            |\n| INTFILEPATH  | Personal Folders\\Deleted  | Email: original location of email including     |\n|              | Items\\Board Meeting       | original file name.                             |\n|              | Minutes.msg               | Native: (empty)                                 |\n| INTMSGID     | <000805c2c71b\\$75977050\\$ | Email: Unique Message ID Native: (empty)        |\n|              | cb8306d1@MSN>             |                                                 |\n| MD5HASH      | d131dd02c5e6eec4693d9a0   | MD5 Hash value of the document.                 |\n|              | 698aff95c                 |                                                 |\n|              | 2fcab58712467eab4004583e  |                                                 |\n|              | b8fb7f89                  |                                                 |\n| OCRPATH      | TEXT/001/EDC0000001.txt   | Path to extracted text of the native file       |\n\n3. Each Request operates and should be construed independently and, unless otherwise indicated, no Request limits the scope of any other Request.\n\n4. All Documents are to be produced as kept in the usual course of business or are to be organized and labeled to correspond with the categories in these Requests.\n\n5. Each Request contained herein extends to all Documents: (a) in Your possession, custody, or control; or (b) in the possession, custody, or control of anyone acting on Your behalf,\n\n#### Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 41 of 1063\n\nincluding Your counsel or other representatives and advisors. Each Document shall be produced in its entirety.\n\n6. If You are requested to produce a Document that is no longer in Your possession, custody, or control, then Your response must (a) describe in detail the nature of the document and its contents; (b) identify the person(s) who prepared or authored the Document (and, if applicable, the Person(s) to whom the Document was sent); (c) identify the date on which the document was prepared or created; (d) state whether such Document (i) is missing or lost, (ii) has been destroyed, (iii) has been transferred, voluntarily or involuntarily, to others, or (iv) was otherwise disposed of; (e) state the reason for, and the facts and circumstances surrounding, such disposition; (f) identify the Persons who authorized such disposition; (g) identify the date or approximate date of such disposition; (h) state when the Document was most recently in Your possession, custody or control; and (i) identify the Person, if any, presently in possession, custody, or control of such Document.\n\n7. If You are requested to produce a Document that has been destroyed, then Your response must state, in addition to the information required by the preceding Instruction: (a) the reason for the Document's destruction; (b) the identity of the Person who destroyed the Document; and (c) the identity of the Person who directed that the Document be destroyed.\n\n8. If You claim that a requested Document is privileged or attorney work-product, then Your response must: (a) state (i) a description of the Document adequate to support Your contention that the Document is privileged, (ii) the title of the Document, (iii) the date of the Document, (iv) the author of the Document, (v) the addressee of the Document, (vi) the identity of each Person who received or saw the original or any draft, copy, or reproduction of the Document, (vii) whether the Document itself, or any information contained or referred to in the Document is in the possession, custody, or control of any other Persons, and if so, the identity of\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 42 of 1063\n\nsuch Persons, as well as a statement addressing how the information came into their possession, (viii) the claim of privilege under which the Document is withheld, and (ix) all of the circumstances upon which You will rely to support such claim of privilege; and (b) produce a privilege log containing all of the information requested in Part (a) of this Instruction for each Document withheld on the basis of a claim of privilege in accordance with D. Conn. L. Civ. R. 26(e).\n\n9. If a portion of an otherwise responsive Document contains information subject to a claim of privilege, only that portion of the Document subject to the claim of privilege shall be deleted or redacted from the Document following the instructions above, and the rest shall be produced.\n\n10. The Requests are continuing in nature. You are hereby instructed to (a) supplement or correct any responses later learned to be incomplete or incorrect immediately upon learning that a prior response was incomplete or incorrect; and (b) produce any additional Documents that are called for under the\n\n11. If a Document is in a language other than English, You should provide that Document. If a Document is in a language other than English, and an English translation exists, You should provide both Documents.\n\n12. All references to Entities includes all affiliates thereof.\n\n13. All references to individual names include all alternative names, aliased, or nicknames.\n\n14. Unless otherwise expressly indicated, the period of time covered by the Document Requests is the period from February 5, 2012 to the date responses to the Document Requests are due.\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 43 of 1063\n\n#### **II. RULES OF CONSTRUCTION**\n\n15. The use of (a) any singular noun shall be construed to include the plural, and vice versa, and (b) a verb in any tense shall be construed as the use of the verb in all other tenses.\n\n16. The terms (a) \"and\" and \"or\" shall be construed either conjunctively or disjunctively as necessary to bring within the scope of any request all responses that might otherwise be construed to be outside of its scope, and (b) \"each\" and \"any\" shall be deemed to include and encompass the words \"every\" and \"all.\"\n\n#### **III. DEFINITIONS**\n\nThe definitions supplied by D. Conn. L. Civ. R. 26(c) and the rules of construction supplied by D. Conn. L. Civ. R. 26(d), as incorporated by D. Conn. Bankr. L.R. 2004-1(a), shall apply to the Document Requests. In addition, the following terms used in these Document Requests shall have the following meanings:\n\n1. \"You\" or \"Your\" or \"Yourself\" means and refers to G-EDU Inc., together with all of its affiliates, divisions, agencies, instrumentalities, departments, offices, partners, officers, directors, agents, attorneys, representatives, employees, and/or anyone acting on its behalf.\n\n2. \"Debtor\" means Ho Wan Kwok (a/k/a Miles Kwok, Miles Guo, Guo Wengui, Guo Haoyun, 郭文贵, or any other alias), together with his employees, agents, counsel, advisors, or anyone acting on his behalf.\n\n3. \"Debtor's Son\" means Qiang Guo (a/k/a Mileson Kwok, 郭强, or any other alias), together with his employees, agents, counsel, advisors, or anyone acting on his behalf.\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 44 of 1063\n\n4. \"Debtor's Daughter\" means Mei Guo (a/k/a Mei Gui, 郭美, or any other alias), together with her employees, agents, counsel, advisors, or anyone acting on her behalf.\n\n5. \"Debtor's Purported Wife\" means Hing Chi Ngok (a/k/a Hing Chi Ng, Yue Qingzhi, 岳庆芝, or any other alias), together with her employees, agents, counsel, advisors, or anyone acting on her behalf.\n\n6. \"Debtor's Family\" means, collectively, the Debtor, the Debtor's Son, the Debtor's Daughter, and the Debtor's Purported Wife, and any other familial relation to the Debtor.\n\n7. \"Associated Individuals\" means, individually and collectively, all individuals that (1) hold, control, have custody over, or discretion over assets owned, controlled, or enjoyed by the Debtor or the Debtor's Family; or (2) have been employees, directors, or otherwise are affiliated with one or more Associated Entities, together with the respective employees, agents, counsel, advisors, or anyone acting on behalf of any of the foregoing. Such Associated Individuals shall include, but are not limited to: Daniel Podhaskie, Jason Miller, Steve Bannon, Karin Maistrello, Melissa Francis, Anthony DiBattista, William Gertz, Arethusa Forsyth, Glenn Mellor, Jennifer Mercurio, Eduardo Eurnekian, Wencong Wang, Han Chunguang (a/k/a 韩春光), Qu Guojiao (a/k/a Qu Guo Jiao, 屈国姣), Guo Lijie (a/k/a 郭丽杰), Zhang Wei (a/k/a 张伟\\*), Lihong Wei Lafrenz (a/k/a Sara Wei, 魏丽红), Hao Haidong (a/k/a 郝海东), Ross Heinemeyer, Max Krasner, Kyle Bass, Melissa Mendez, Ya Li (a/k/a 李娅), Dinggang Wang (a/k/a 王定刚), An Hong (a/k/a 安红), Yvette Wang (a/k/a Yanping Wang, Yan Ping Wang, 王雁平), Fiona Yu, Je Kin Ming (a/k/a William Je, Yu Jianming, 余建明), Yaz Qingua, and Lao Jiang (a/k/a Jiang Yunfu, Jiang Yunfu Be, 姜云浮).\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 45 of 1063\n\n8. \"Associated Entities\" means, individually and collectively, all organizations or Entities of any type that (1) have been owned, controlled, or invested in by the Debtor or the Debtor's Family; or (2) have an interest, whether directly or indirectly, in any assets owned, controlled, or enjoyed by the Debtor or the Debtor's Family, together with the respective employees, agents, counsel, advisors, or anyone acting on behalf of any of the foregoing. Such Associated Entities shall include, but are not limited to: 7 Nod Hill LLC, AAGV Limited, ACA Investment Management Limited, ACA Capital Group Limited, Ace Decade Holdings Limited, AI Group Holdings Inc., Alfa Global Ventures Limited, Alfonso Global Limited, Allied Capital Global Limited, Alpine Fiduciaries SA, Anton Development Limited, Assets Sino Limited, Auspicious Coast Limited, Beijing Pangu Investment Co., Beijing Pangu Investment Co. Ltd., Beijing Pangu Investment Inc., Beijing Zenith Holdings Company Limited, Booming Sail New York LLC, Bravo Luck Limited, BSA Strategic Fund I, China Golden Spring (Hong Kong) Limited, Chuang Xin Limited, Crane Advisory Group LLC, Creative Apex Investments Limited, Crystal Breeze Investments Limited, Dawn State Limited, Eastern Profit Corporation Limited, Elite Well Global Limited, Empire Growth Holdings, Freedom Media Ventures Ltd., G Club Operations LLC, G Fashion LLC, G News LLC, GETTR USA, Genever Holdings Corporation, Genever Holdings LLC, Gfashion Media Group Inc., GFNY, Inc., Globalist International Limited, GNews Media Group Inc., Golden Spring (New York) Ltd., Greenwich Land LLC, Guo Media, GTV Media Group, Inc., Hamilton Capital Holdings Inc., HCHK Property Management, Inc., HCHK Technologies, Inc., Head Win Group Limited, Henan Yuda, Himalaya Embassy, Himalaya Exchange, Himalaya Federal Reserve, Himalaya Investment LLC, Himalaya International, Himalaya New World Inc., Himalaya Supervisory Organization, Himalaya Ventures LLC, HK International Funds Investments (USA) Limited LLC, Hong Kong International Funds\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 46 of 1063\n\nInvestments Limited, Hudson Diamond Holding, Infinite Increase Limited, Infinitum Developments Limited, Infinity Treasury Management Inc., Insight Phoenix Fund, Lamp Capital LLC, Leading Shine Limited, Leading Shine NY Limited, Lexington Property and Staffing, Long Gate Limited, Maywind Trading LLC, MOS Himalaya LLC, Next Tycoon Investments Limited, New Federal State of China (a/k/a NFSC), Noble Fame Global Limited, Rosy Acme Ventures Limited, Rule of Law Foundation III, Inc., Rule of Law Foundation IV, Inc., Rule of Law Fund, Rule of Law Society, Rule of Law Society IV, Inc., G-Translators PTY LTD, Saraca Media Group, Inc., Shiny Ace Ltd., Shiny Times Holdings Ltd., Spirit Charter Investment Limited, Stevenson, Wong & Co., Voice of Guo Media, Inc., Well Origin Ltd., World Century Limited, Worldwide Opportunity Holdings Limited, Whitecroft Shore Limited, and ZIBA Limited.\n\n9. \"Including\" or any variant thereof means \"including without limitation.\"\n\n10. \"And\" and \"or\" mean \"and/or,\" and shall be construed both conjunctively as well as disjunctively in order to maximize their scope.\n\n11. \"Any\" and \"all\" and \"each\" mean \"each and every.\"\n\n12. \"Each\" and \"every\" mean \"each and every.\"\n\n13. \"Third Party\" means a Person or Entity other than Yourself.\n\n14. \"Transfer\" shall have the meaning given to it by section 101(54) of the Bankruptcy Code.\n\n15. \"Document\" means any information or thing within the scope of Fed. R. Civ. P. 34, and includes, without limitation, each and every written, recorded, or graphic matter of any kind, type, nature, or description that is or has been in Your Possession, Custody or Control, including all printed and electronic copies of electronic mail, computer files maintained in\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 47 of 1063\n\nelectronic form, electronic communication, text message, social media post, tweet, meta-data, correspondence, memoranda, tapes, stenographic or handwritten notes, written forms of any kind, charts, blueprints, drawings, sketches, graphs, plans, articles, specifications, diaries, letters, telegrams, photographs, minutes, contracts, agreements, surveys, computer printouts, data compilations of any kind, telexes, facsimiles, voice messages, invoices, order forms, checks, drafts, statements, credit memos, reports, position reports, summaries, indices, books, ledgers, notebooks, schedules, transparencies, recordings, catalogs, advertisements, promotional materials, films, video tapes, audio tapes, CDs, computer disks, brochures, pamphlets, punchcards, time-slips, Tweets, social media posts, or any written or recorded materials of any other kind, and all meta-data thereof, however stored (whether in tangible or electronic form), recorded, produced, or reproduced, and also including but not limited to, drafts or copies of any of the foregoing that contain any notes, comments, or markings of any kind not found on the original documents or that are otherwise not identical to the original documents.\n\n16. \"Person(s)\" means an individual, corporation, proprietorship, partnership, association, or any other Entity. \"Person\" also includes any agent, representatives, or expert, including but not limiting to, attorneys or financial advisors.\n\n17. \"Entity\" means any natural Person, corporation, partnership, subsidiary, sole proprietorship, firm, board, joint venture, association, agency, authority, commission or other business entity or juristic Person, as well as any affiliate, agent, parent including but not limited to legal counsel, financial advisors, or any other representative.\n\n18. \"Regarding\" means concerning, describing, comprising, referring to, related to, supporting, favoring, opposing, bolstering, detracting from, located in, considered in connection with, bearing on, evidencing, indicating, reporting on, recording, alluding to, responding to,\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 48 of 1063\n\nconnected with, commenting on, in respect of, about, in relation to, discussing, showing, describing, reflecting, analyzing constituting, and being.\n\n19. \"Relating to,\" \"relate(s) to\" or \"related to,\" when referring to any given subject matter, means, without limitation, any document that constitutes, comprises, involves, contains, embodies, reflects, identifies, states, refers directly or indirectly to, or is in any way relevant to the particular subject matter identified.\n\n20. \"Communication(s)\" means, in the broadest possible sense, and without limitation, any transmittal of information or knowledge (in the form of facts, ideas, inquiries, or otherwise). Communication(s) further refers to all conversations, agreements, inquiries, or replies, whether in person, by telephone, in writing, or by means of electronic transmittal devices, and includes, but is not limited to, all correspondence, emails, recordings, transmittal slips, memoranda, telephone communications, voice messages, telegrams, telefaxes, telecopies, telexes, instant messages, chats, text messages, telephonic notes, or notes transmitted internally or with third parties.\n\n21. \"Asset(s)\" means any item that can be used to produce positive economic value, including but not limited to any resource with economic value that is owned, controlled or is for the benefit of an entity, that is expected to provide a future benefit, including but not limited to, all real and personal property, intangible property, investments, rights to invest or to future revenue, cash, bank accounts, commodities, securities, claims, total or partial control of an entity, and prospective economic opportunities\n\n22. \"Transfer\" shall have the meaning given to it by section 101(54) of the Bankruptcy Code.\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 49 of 1063\n\n#### **IV. DOCUMENTS TO BE PRODUCED**\n\n1. All Documents regarding any income or Asset of the Debtor, the Debtor's estate, or an Associated Entity.\n\n2. All Documents related to the Debtor's financial condition and obligations to his creditors, including without limitation all Documents related to any effort to avoid paying such obligations and All Documents related to this or any other actual or potential bankruptcy or similar insolvency proceeding.\n\n3. All Documents regarding any balance sheet, bank statement, account statement, financial statement, statement of account, wire transfer instructions and/or confirmation, proof of funds, certificate of deposit, certificate of holdings, investment portfolio summary, or similar document relating to the Debtor, the Debtor's Estate, the Debtor's Family, an Associated Entity, or an Associated Individual, including without limitation all Documents sufficient to show all Transfers to any of the foregoing.\n\n4. All Documents regarding any investment, business dealing or transactions made by, with, or on behalf of the Debtor.\n\n5. All Communications with the Debtor, and Documents related to Communications with the Debtor, related to the operation, management, or decision-making of any Entity, including without limitation the Associated Entities.\n\n6. All Documents regarding any Transfer, investment, or other transaction or business dealing made to, by, or with the Debtor, the Debtor's Family, or an Associated Entity.\n\n7. All Documents regarding any property ever occupied or used by the Debtor, including without limitation the *Lady May*; the Sherry Netherland Hotel / Condominium; the\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 50 of 1063\n\nresidential property located in Greenwich, Connecticut at 373 Taconic Rd.; the residential property located in Greenwich, Connecticut at 33 Ferncliff Rd.; and the residential property located in Wilton, Connecticut at 354 Nod Hill Rd.\n\n8. All Documents related to any aircraft owned, controlled, or used by the Debtor, including without limitation the aircraft bearing tail number T7-GQM and any other aircraft registered in San Marino, including without limitation copies of all registration documents and flight manifests showing flights taken by such aircraft and the individuals onboard such flights.\n\n9. All Documents regarding any gifts, benefits or loans, to, from or on behalf of the Debtor, the Debtor's Estate, the Debtor's Family, or the Associated Entities, including without limitation Documents sufficient to show the amounts of such gifts, benefits, or loans; the purposes for which such gifts, benefits, or loans were used; when the gifts, benefits, or loans were provided; and the terms of any loans, all representations and warranties made in connection with any loans, the interest rate on any loans, and all evidence of payments of any loans.\n\n10. All Documents concerning any trust or similar instrument set up by, on behalf of, or for the benefit of the Debtor, the Debtor's Estate, the Debtor's Family, or an Associated Entity, including without limitation Documents sufficient to show when the trust(s) was created, by whom it was created, for whose benefit it was created, and the corpus of the trust.\n\n11. All Documents related to any obligation, claim, liability, or debt associated with any legal dispute involving the Debtor, including but not limited to those relating to any litigation before any local, state, federal, or international body, whether an administrative body, court, panel, or alternative dispute resolution entity.\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 51 of 1063\n\n12. All Documents and communications between any of your outside counsel or other advisors and the Debtor.\n\n13. Documents sufficient to show all of Your Assets and sources of income or funding.\n\n14. For all Assets identified in response to Request 14 having a value of more than \\$50,000, all (i) Documents related to Your acquisition of such Asset and (ii) Communications with the Debtor or the Debtor's Family regarding such Asset.\n\n15. Copies of Your tax returns.\n\n16. Documents sufficient to show all bank accounts and investment accounts within Your possession or control, including the balances of and transfers to and from each such account.\n\n17. All Documents regarding any credit cards used by You, including without limitation monthly statements or other Documents sufficient to show all purchases related thereto for the benefit of the Debtor or an Associated Entity.\n\n18. All corporate governance and organizational Documents, including without limitation by-laws and certificates of incorporation and other Documents sufficient to show Your corporate structure, names of officers and directors, business purpose, and relationship to the Debtor or to any member of the Debtor's Family.\n\n19. All Documents related to any pledge(s) of Your Assets to any other Entity.\n\nCase 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 52 of 1063\n\n# Exhibit C-2\n\n#### B2540 (Form 2540 – Subpoena for Rule 2004 Examination) (12/15) Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 53 of\n\nUNITED STATES BANKRUPTCY COURT 1063\n\n**District of Connecticut**\n\nIn re HO WAN KWOK, *et al*.,\n\n<sup>1</sup> Case No. 22-50073 (JAM)\n\nDebtor Chapter 11\n\n(Jointly Administered)\n\n## **SUBPOENA FOR RULE 2004 EXAMINATION**\n\nTo: **GFashion Media Group Inc.**\n\n(*Name of person to whom the subpoena is directed*)\n\n*Testimony:* **YOU ARE COMMANDED** to appear at the time, date, and place set forth below to testify at an examination under Rule 2004, Federal Rules of Bankruptcy Procedure. A copy of the court order authorizing the examination is attached.\n\n| PLACE                    | DATE AND TIME |\n|--------------------------|---------------|\n| Paul Hastings LLP        |               |\n| 200 Park Avenue          | [TBD]         |\n| New York, New York 10166 |               |\n|                          |               |\n\nThe examination will be recorded by this method: **Court reporter/stenographer**\n\n*Production:* You, or your representatives, must also bring with you to the examination the following documents, electronically stored information, or objects, and must permit inspection, copying, testing, or sampling of the material:\n\n#### **See Requests for Production of Documents, attached hereto.**\n\nThe following provisions of Fed. R. Civ. P. 45, made applicable in bankruptcy cases by Fed. R. Bankr. P. 9016, are attached – Rule 45(c), relating to the place of compliance; Rule 45(d), relating to your protection as a person subject to a subpoena; and Rule 45(e) and 45(g), relating to your duty to respond to this subpoena and the potential consequences of not doing so.\n\nDate: **March , 2023**\n\nCLERK OF COURT\n\nOR\n\n*Signature of Clerk or Deputy Clerk Attorney's signature*\n\nThe name, address, email address, and telephone number of the attorney representing Luc A. Despins, Chapter 11 Trustee, who issues or requests this subpoena, are:\n\n**Douglas S. Skalka, Esq.; Neubert, Pepe & Monteith, P.C.; 195 Church Street, New Haven, Connecticut 06510 dskalka@npmlaw.com; (203) 821-2000**\n\n**Notice to the person who issues or requests this subpoena**\n\nIf this subpoena commands the production of documents, electronically stored information, or tangible things, or the inspection of premises before trial, a notice and a copy of this subpoena must be served on each party before it is served on the person to whom it is directed. Fed. R. Civ. P. 45(a)(4).\n\nSoftware Copyright (c) 1996-2022 Best Case, LLC - www.bestcase.com Best Case Bankruptcy 1 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\n#### **PROOF OF SERVICE**\n\n**(This section should not be filed with the court unless required by Fed. R. Civ. P. 45.)**\n\nI received this subpoena for (*name of individual and title, if any*): on (*date*) .\n\nI served the subpoena by delivering a copy to the named person as follows:\n\non *(date)* ; or\n\nI returned the subpoena unexecuted because:\n\nUnless the subpoena was issued on behalf of the United States, or one of its officers or agents, I have also tendered to the witness the fees for one day's attendance, and the mileage allowed by law, in the amount of \\$ .\n\nMy fees are \\$ for travel and \\$ for services, for a total of \\$ .\n\nI declare under penalty of perjury that this information is true and correct.\n\nDate:\n\n*Server's signature*\n\n*Printed name and title*\n\n*Server's address*\n\nAdditional information concerning attempted service, etc.:\n\n#### **Federal Rule of Civil Procedure 45(c), (d), (e), and (g) (Effective 12/1/13) (made applicable in bankruptcy cases by Rule 9016, Federal Rules of Bankruptcy Procedure)**\n\n#### **(c) Place of compliance.**\n\n*(1) For a Trial, Hearing, or Deposition.* A subpoena may command a person to attend a trial, hearing, or deposition only as follows:\n\n(A) within 100 miles of where the person resides, is employed, or regularly transacts business in person; or\n\n(B) within the state where the person resides, is employed, or regularly transacts business in person, if the person\n\n(i) is a party or a party's officer; or\n\n(ii) is commanded to attend a trial and would not incur substantial expense.\n\n*(2) For Other Discovery.* A subpoena may command:\n\n(A) production of documents, or electronically stored information, or things at a place within 100 miles of where the person resides, is employed, or regularly transacts business in person; and\n\n(B) inspection of premises, at the premises to be inspected.\n\n#### **(d) Protecting a Person Subject to a Subpoena; Enforcement.**\n\n*(1) Avoiding Undue Burden or Expense; Sanctions.* A party or attorney responsible for issuing and serving a subpoena must take reasonable steps to avoid imposing undue burden or expense on a person subject to the subpoena. The court for the district where compliance is required must enforce this duty and impose an appropriate sanction which may include lost earnings and reasonable attorney's fees — on a party or attorney who fails to comply.\n\n#### *(2) Command to Produce Materials or Permit Inspection.*\n\n*(A) Appearance Not Required.* A person commanded to produce documents, electronically stored information, or tangible things, or to permit the inspection of premises, need not appear in person at the place of production or inspection unless also commanded to appear for a deposition, hearing, or trial.\n\n*(B) Objections.* A person commanded to produce documents or tangible things or to permit inspection may serve on the party or attorney designated in the subpoena a written objection to inspecting, copying, testing or sampling any or all of the materials or to inspecting the premises — or to producing electronically stored information in the form or forms requested. The objection must be served before the earlier of the time specified for compliance or 14 days after the subpoena is served. If an objection is made, the following rules apply:\n\n(i) At any time, on notice to the commanded person, the serving party may move the court for the district where compliance is required for an order compelling production or inspection.\n\n(ii) These acts may be required only as directed in the order, and the order must protect a person who is neither a party nor a party's officer from significant expense resulting from compliance.\n\n#### *(3) Quashing or Modifying a Subpoena.*\n\n*(A) When Required.* On timely motion, the court for the district where compliance is required must quash or modify a subpoena that:\n\n(i) fails to allow a reasonable time to comply;\n\n(ii) requires a person to comply beyond the geographical limits specified in Rule 45(c);\n\n(iii) requires disclosure of privileged or other protected matter, if no exception or waiver applies; or\n\n(iv) subjects a person to undue burden.\n\n*(B) When Permitted.* To protect a person subject to or affected by a subpoena, the court for the district where compliance is required may, on motion, quash or modify the subpoena if it requires:\n\n(i) disclosing a trade secret or other confidential research, development, or commercial information; or\n\n(ii) disclosing an unretained expert's opinion or information that does not describe specific occurrences in dispute and results from the expert's study that was not requested by a party.\n\n(C) *Specifying Conditions as an Alternative.* In the circumstances described in Rule 45(d)(3)(B), the court may, instead of quashing or modifying a subpoena, order appearance or production under specified conditions if the serving party:\n\n(i) shows a substantial need for the testimony or material that cannot be otherwise met without undue hardship; and\n\n(ii) ensures that the subpoenaed person will be reasonably compensated.\n\n#### **(e) Duties in Responding to a Subpoena.**\n\n*(1) Producing Documents or Electronically Stored Information.* These procedures apply to producing documents or electronically stored information:\n\n*(A) Documents.* A person responding to a subpoena to produce documents must produce them as they are kept in the ordinary course of business or must organize and label them to correspond to the categories in the demand.\n\n*(B) Form for Producing Electronically Stored Information Not Specified.* If a subpoena does not specify a form for producing electronically stored information, the person responding must produce it in a form or forms in which it is ordinarily maintained or in a reasonably usable form or forms.\n\n*(C) Electronically Stored Information Produced in Only One Form.* The person responding need not produce the same electronically stored information in more than one form.\n\n*(D) Inaccessible Electronically Stored Information.* The person responding need not provide discovery of electronically stored information from sources that the person identifies as not reasonably accessible because of undue burden or cost. On motion to compel discovery or for a protective order, the person responding must show that the information is not reasonably accessible because of undue burden or cost. If that showing is made, the court may nonetheless order discovery from such sources if the requesting party shows good cause, considering the limitations of Rule 26(b)(2)(C). The court may specify conditions for the discovery.\n\n#### *(2) Claiming Privilege or Protection.*\n\n*(A) Information Withheld.* A person withholding subpoenaed information under a claim that it is privileged or subject to protection as trial-preparation material must: (i) expressly make the claim; and\n\n(ii) describe the nature of the withheld documents, communications, or tangible things in a manner that, without revealing information itself privileged or protected, will enable the parties to assess the claim.\n\n*(B) Information Produced.* If information produced in response to a subpoena is subject to a claim of privilege or of protection as trial-preparation material, the person making the claim may notify any party that received the information of the claim and the basis for it. After being notified, a party must promptly return, sequester, or destroy the specified information and any copies it has; must not use or disclose the information until the claim is resolved; must take reasonable steps to retrieve the information if the party disclosed it before being notified; and may promptly present the information under seal to the court for the district where compliance is required for a determination of the claim. The person who produced the information must preserve the information until the claim is resolved.\n\n**(g) Contempt.** The court for the district where compliance is required – and also, after a motion is transferred, the issuing court – may hold in contempt a person who, having been served, fails without adequate excuse to obey the subpoena or an order related to it.\n\nFor access to subpoena materials, see Fed.R.Civ.P.45(a) Committee Note (2013)\n\n…\n\n## **Requests for Production of Documents**\n\n## **I. INSTRUCTIONS**\n\n1. Unless otherwise indicated, the requests for documents set forth below, (the \"Requests,\" and each, a \"Request\"), must be responded to separately and specifically. Each Request shall be answered fully unless it is in good faith objected to, in which event the reason for Your objection shall be stated in detail, as set forth below. If an objection pertains only to a portion of a Request, or a word, phrase or clause contained within it, You are required to state Your objection to that portion only and to respond to the remainder of the Requests.\n\n2. Electronically stored information must be produced in accordance with the\n\nfollowing instructions:\n\n- a. Images. Black and white images must be 300 DPI Group IV single-page TIFF files. Color images must be produced in JPEG format. File names cannot contain embedded spaces or special characters (including the comma). Folder names cannot contain embedded spaces or special characters (including the comma). All TIFF image files must have a unique file name, i.e. Bates number. Images must be endorsed with sequential Bates numbers in the lower right corner of each image. The number of TIFF files per folder should not exceed 1000 files. Excel spreadsheets should have a placeholder image named by the Bates number of the file.\n- b. Image Load File\n\t- a. Concordance® Data File. The data file (.DAT) contains all of the fielded information that will be loaded into the Concordance® database. The first line of the .DAT file must be a header row identifying the field names. The .DAT file must use the following Concordance® default delimiters: Comma ASCII character (020) Quote þ ASCII character (254). Date fields should be provided in the format: mm/dd/yyyy. Date and time fields must be two separate fields. If documents includes imaged emails and attachments, the attachment fields must be included to preserve the parent/child relationship between an email and its attachments. An OCRPATH field must be included to provide the file path and name of the extracted text file on the produced storage media. The text file must be named after the FIRSTBATES. Do not include the text in the .DAT file. For Documents with native files, a LINK field must be included to provide the file path and\n\nname of the native file. The native file must be named after the FIRSTBATES.\n\n- b. Concordance Image® OR Opticon Cross-Reference File. The image crossreference file (.LOG or .OPT) links the images to the database records. It should be a comma-delimited file consisting of seven fields per line with a line in the cross-reference file for every image in the database with the following format: ImageID,VolumeLabel,ImageFilePath,DocumentBreak,FolderBreak,Box Break,PageCoun.\n- c. Document Text. Text must be produced as separate text files, not as fields within the .DAT file. The full path to the text file (OCRPATH) should be included in the .DAT file. It is recommended document level ANSI text files, named per the FIRSTBATES/Image Key. Extracted text files must be in a separate folder, and the number of text files per folder should not exceed 1,000 files. There should be no special characters (including commas in the folder names). Text files must be provided on a document level.\n- d. Native Production for Certain File Types. File types that reasonably require viewing in their native format for a full understanding of their content and meaning must be produced in native format. These include, but are not limited to, spreadsheets, spreadsheet-like files (Microsoft Excel, comma separated values, tab separated values, etc.), Microsoft PowerPoint or other special presentation files, database files, and audio/visual files. Provide an image of a Bates numbered slip sheet indicating the presence of a native file, and include the path to the native as a field in the .dat file. Name the produced native file with the Bates number corresponding to the slip sheet for the file. Group native files within incrementally named \"NATIVE\" directories, separate from images directories.\n- e. De-duplication. Produce a single copy of each electronic document for which exact duplicates exist. For email messages, consolidate duplicates based on MD5 hash generated from the BCC, Body, CC, From, IntMsgID, To, and Attach properties. For email attachments and standalone electronic files, consolidate duplicates based on MD5 hash of the entire file.\n- f. Metadata. Produce extracted metadata for each document in the form of a Concordance compliant load file (.dat). The first line of the .DAT file must be a header row identifying the field names. The .DAT file must use the following Concordance default delimiters: Comma , ASCII character (020) Quote þ ASCII character (254)\n\nDate fields should be provided in the format: mm/dd/yyyy. Date and time fields must be two separate fields. Required metadata listed below:\n\n# Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 58 of 1063\n\n| Field Name   | Sample Data              | Description                                      |\n|--------------|--------------------------|--------------------------------------------------|\n| FIRSTBATES   | EDC0000001               | First Bates number of native file document/email |\n| LASTBATES    | EDC0000001               | Last Bates number of native file document/email  |\n|              |                          | **The LASTBATES field should be populated        |\n|              |                          | for single page                                  |\n| ATTACHRANGE  | EDC0000001<br>-          | Bates number of the first page of the parent     |\n|              | EDC0000015               | document to the Bates number of the last page of |\n|              |                          | the last attachment \"child\" document             |\n| BEGATTACH    | EDC0000001               | First Bates number of attachment range           |\n| ENDATTACH    | EDC0000015               | Last Bates number of attachment range            |\n| CUSTODIAN    | Smith, John              | Email: Mailbox where the email resided           |\n|              |                          | Native: Name of the individual or department     |\n|              |                          | from whose files the document<br>originated      |\n| FROM         | John Smith               | Email: Sender                                    |\n|              |                          | Native: Author(s) of document                    |\n|              |                          | **semi-colon should be used to separate          |\n|              |                          | multiple entries                                 |\n| TO           | Coffman, Janice; LeeW    | Recipient(s)                                     |\n|              | [mailto:LeeW@MSN.com]    | **semi-colon should be used to separate multiple |\n|              |                          | entries                                          |\n| CC           | Frank Thompson [mailto:  | Carbon copy recipient(s)                         |\n|              | frank_Thompson@cdt.com]  | **semi-colon should be used to separate          |\n|              |                          | multiple entries                                 |\n| BCC          | John Cain                | Blind carbon copy recipient(s)                   |\n|              |                          | **semi-colon should be used to separate          |\n|              |                          | multiple entries                                 |\n| SUBJECT      | Board Meeting Minutes    | Email: Subject line of the email Native: Title   |\n|              |                          | of document (if available)                       |\n| FILE_NAME    | BoardMeetingMinutes.docx | Native: Name of the original native file,        |\n|              |                          | including extension                              |\n| DATE_SENT    | 10/12/2010               | Email: Date the email was sent                   |\n|              |                          | Native: (empty)                                  |\n| TIME_SENT/   | 07:05 PM GMT             | Email: Time the email was sent/ Time zone in     |\n| TIME_ZONE    |                          | which the emails were standardized               |\n| TIME_ZONE    | GMT                      | The<br>time zone in which<br>the emails<br>were  |\n|              |                          | standardized during conversion.                  |\n| LINK         |  EDC0000001.msg   | Hyperlink to the email or native file document   |\n|              |                          | **The linked file must be named per the          |\n|              |                          | FIRSTBATES number                                |\n| FILE_EXTEN   | MSG                      | The file type extension                          |\n|              |                          | representing                                     |\n|              |                          | the Email or                                     |\n| AUTHOR       | John Smith               | Email: (empty)                                   |\n|              |                          | Native: Author of the document                   |\n| DATE_CREATED | 10/10/2010               | Email: (empty)                                   |\n|              |                          | Native: Date the document was created            |\n\n# Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 59 of 1063\n\n| TIME_CREATED | 10:25 AM                  | Email: (empty)                                  |\n|--------------|---------------------------|-------------------------------------------------|\n|              |                           | Native: Time the document was created           |\n|              |                           | **This data must be a separate field and cannot |\n|              |                           | be combined with the DATE_CREATED field         |\n| DATE_MOD     | 10/12/2010                | Email: (empty)                                  |\n|              |                           | Native: Date the document was last modified     |\n|              |                           |                                                 |\n| TIME_MOD     | 07:00 PM                  | Email: (empty)                                  |\n|              |                           | Native: Time the document was last modified     |\n|              |                           | **This data must be a separate field and cannot |\n|              |                           | be combined with the DATE_MOD field             |\n| DATE_ACCESSD | 10/12/2010                | Email: (empty)                                  |\n|              |                           | Native: Date the document was last accessed     |\n| TIME_ACCESSD | 07:00 PM                  | Email: (empty)                                  |\n|              |                           | Native: Time the document was last accessed     |\n|              |                           | **This data must be a separate field and cannot |\n|              |                           | be combined with the DATE_ACCESSD field         |\n| FILE_SIZE    | 5,952                     | Size of native file<br>document/email in KB     |\n| PGCOUNT      | 1                         | Number of pages in native file document/email   |\n| PATH         |   | Email: (empty)                                  |\n|              | Agenda.doc                | Native: Path where native file document was     |\n|              |                           | stored including original file name.            |\n| INTFILEPATH  | Personal Folders\\Deleted  | Email: original location of email including     |\n|              | Items\\Board Meeting       | original file name.                             |\n|              | Minutes.msg               | Native: (empty)                                 |\n| INTMSGID     | <000805c2c71b\\$75977050\\$ | Email: Unique Message ID Native: (empty)        |\n|              | cb8306d1@MSN>             |                                                 |\n| MD5HASH      | d131dd02c5e6eec4693d9a0   | MD5 Hash value of the document.                 |\n|              | 698aff95c                 |                                                 |\n|              | 2fcab58712467eab4004583e  |                                                 |\n|              | b8fb7f89                  |                                                 |\n| OCRPATH      | TEXT/001/EDC0000001.txt   | Path to extracted text of the native file       |\n\n3. Each Request operates and should be construed independently and, unless otherwise indicated, no Request limits the scope of any other Request.\n\n4. All Documents are to be produced as kept in the usual course of business or are to be organized and labeled to correspond with the categories in these Requests.\n\n5. Each Request contained herein extends to all Documents: (a) in Your possession, custody, or control; or (b) in the possession, custody, or control of anyone acting on Your behalf,\n\n#### Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 60 of 1063\n\nincluding Your counsel or other representatives and advisors. Each Document shall be produced in its entirety.\n\n6. If You are requested to produce a Document that is no longer in Your possession, custody, or control, then Your response must (a) describe in detail the nature of the document and its contents; (b) identify the person(s) who prepared or authored the Document (and, if applicable, the Person(s) to whom the Document was sent); (c) identify the date on which the document was prepared or created; (d) state whether such Document (i) is missing or lost, (ii) has been destroyed, (iii) has been transferred, voluntarily or involuntarily, to others, or (iv) was otherwise disposed of; (e) state the reason for, and the facts and circumstances surrounding, such disposition; (f) identify the Persons who authorized such disposition; (g) identify the date or approximate date of such disposition; (h) state when the Document was most recently in Your possession, custody or control; and (i) identify the Person, if any, presently in possession, custody, or control of such Document.\n\n7. If You are requested to produce a Document that has been destroyed, then Your response must state, in addition to the information required by the preceding Instruction: (a) the reason for the Document's destruction; (b) the identity of the Person who destroyed the Document; and (c) the identity of the Person who directed that the Document be destroyed.\n\n8. If You claim that a requested Document is privileged or attorney work-product, then Your response must: (a) state (i) a description of the Document adequate to support Your contention that the Document is privileged, (ii) the title of the Document, (iii) the date of the Document, (iv) the author of the Document, (v) the addressee of the Document, (vi) the identity of each Person who received or saw the original or any draft, copy, or reproduction of the Document, (vii) whether the Document itself, or any information contained or referred to in the Document is in the possession, custody, or control of any other Persons, and if so, the identity of\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 61 of 1063\n\nsuch Persons, as well as a statement addressing how the information came into their possession, (viii) the claim of privilege under which the Document is withheld, and (ix) all of the circumstances upon which You will rely to support such claim of privilege; and (b) produce a privilege log containing all of the information requested in Part (a) of this Instruction for each Document withheld on the basis of a claim of privilege in accordance with D. Conn. L. Civ. R. 26(e).\n\n9. If a portion of an otherwise responsive Document contains information subject to a claim of privilege, only that portion of the Document subject to the claim of privilege shall be deleted or redacted from the Document following the instructions above, and the rest shall be produced.\n\n10. The Requests are continuing in nature. You are hereby instructed to (a) supplement or correct any responses later learned to be incomplete or incorrect immediately upon learning that a prior response was incomplete or incorrect; and (b) produce any additional Documents that are called for under the\n\n11. If a Document is in a language other than English, You should provide that Document. If a Document is in a language other than English, and an English translation exists, You should provide both Documents.\n\n12. All references to Entities includes all affiliates thereof.\n\n13. All references to individual names include all alternative names, aliased, or nicknames.\n\n14. Unless otherwise expressly indicated, the period of time covered by the Document Requests is the period from February 5, 2012 to the date responses to the Document Requests are due.\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 62 of 1063\n\n#### **II. RULES OF CONSTRUCTION**\n\n15. The use of (a) any singular noun shall be construed to include the plural, and vice versa, and (b) a verb in any tense shall be construed as the use of the verb in all other tenses.\n\n16. The terms (a) \"and\" and \"or\" shall be construed either conjunctively or disjunctively as necessary to bring within the scope of any request all responses that might otherwise be construed to be outside of its scope, and (b) \"each\" and \"any\" shall be deemed to include and encompass the words \"every\" and \"all.\"\n\n#### **III. DEFINITIONS**\n\nThe definitions supplied by D. Conn. L. Civ. R. 26(c) and the rules of construction supplied by D. Conn. L. Civ. R. 26(d), as incorporated by D. Conn. Bankr. L.R. 2004-1(a), shall apply to the Document Requests. In addition, the following terms used in these Document Requests shall have the following meanings:\n\n1. \"You\" or \"Your\" or \"Yourself\" means and refers to GFashion Media Group Inc., together with all of its affiliates, divisions, agencies, instrumentalities, departments, offices, partners, officers, directors, agents, attorneys, representatives, employees, and/or anyone acting on its behalf.\n\n2. \"Debtor\" means Ho Wan Kwok (a/k/a Miles Kwok, Miles Guo, Guo Wengui, Guo Haoyun, 郭文贵, or any other alias), together with his employees, agents, counsel, advisors, or anyone acting on his behalf.\n\n3. \"Debtor's Son\" means Qiang Guo (a/k/a Mileson Kwok, 郭强, or any other alias), together with his employees, agents, counsel, advisors, or anyone acting on his behalf.\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 63 of 1063\n\n4. \"Debtor's Daughter\" means Mei Guo (a/k/a Mei Gui, 郭美, or any other alias), together with her employees, agents, counsel, advisors, or anyone acting on her behalf.\n\n5. \"Debtor's Purported Wife\" means Hing Chi Ngok (a/k/a Hing Chi Ng, Yue Qingzhi, 岳庆芝, or any other alias), together with her employees, agents, counsel, advisors, or anyone acting on her behalf.\n\n6. \"Debtor's Family\" means, collectively, the Debtor, the Debtor's Son, the Debtor's Daughter, and the Debtor's Purported Wife, and any other familial relation to the Debtor.\n\n7. \"Associated Individuals\" means, individually and collectively, all individuals that (1) hold, control, have custody over, or discretion over assets owned, controlled, or enjoyed by the Debtor or the Debtor's Family; or (2) have been employees, directors, or otherwise are affiliated with one or more Associated Entities, together with the respective employees, agents, counsel, advisors, or anyone acting on behalf of any of the foregoing. Such Associated Individuals shall include, but are not limited to: Daniel Podhaskie, Jason Miller, Steve Bannon, Karin Maistrello, Melissa Francis, Anthony DiBattista, William Gertz, Arethusa Forsyth, Glenn Mellor, Jennifer Mercurio, Eduardo Eurnekian, Wencong Wang, Han Chunguang (a/k/a 韩春光), Qu Guojiao (a/k/a Qu Guo Jiao, 屈国姣), Guo Lijie (a/k/a 郭丽杰), Zhang Wei (a/k/a 张伟\\*), Lihong Wei Lafrenz (a/k/a Sara Wei, 魏丽红), Hao Haidong (a/k/a 郝海东), Ross Heinemeyer, Max Krasner, Kyle Bass, Melissa Mendez, Ya Li (a/k/a 李娅), Dinggang Wang (a/k/a 王定刚), An Hong (a/k/a 安红), Yvette Wang (a/k/a Yanping Wang, Yan Ping Wang, 王雁平), Fiona Yu, Je Kin Ming (a/k/a William Je, Yu Jianming, 余建明), Yaz Qingua, and Lao Jiang (a/k/a Jiang Yunfu, Jiang Yunfu Be, 姜云浮).\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 64 of 1063\n\n8. \"Associated Entities\" means, individually and collectively, all organizations or Entities of any type that (1) have been owned, controlled, or invested in by the Debtor or the Debtor's Family; or (2) have an interest, whether directly or indirectly, in any assets owned, controlled, or enjoyed by the Debtor or the Debtor's Family, together with the respective employees, agents, counsel, advisors, or anyone acting on behalf of any of the foregoing. Such Associated Entities shall include, but are not limited to: 7 Nod Hill LLC, AAGV Limited, ACA Investment Management Limited, ACA Capital Group Limited, Ace Decade Holdings Limited, AI Group Holdings Inc., Alfa Global Ventures Limited, Alfonso Global Limited, Allied Capital Global Limited, Alpine Fiduciaries SA, Anton Development Limited, Assets Sino Limited, Auspicious Coast Limited, Beijing Pangu Investment Co., Beijing Pangu Investment Co. Ltd., Beijing Pangu Investment Inc., Beijing Zenith Holdings Company Limited, Booming Sail New York LLC, Bravo Luck Limited, BSA Strategic Fund I, China Golden Spring (Hong Kong) Limited, Chuang Xin Limited, Crane Advisory Group LLC, Creative Apex Investments Limited, Crystal Breeze Investments Limited, Dawn State Limited, Eastern Profit Corporation Limited, Elite Well Global Limited, Empire Growth Holdings, Freedom Media Ventures Ltd., G Club Operations LLC, G News LLC, GETTR USA, Genever Holdings Corporation, Genever Holdings LLC, GFNY, Inc., Globalist International Limited, GNews Media Group Inc., Golden Spring (New York) Ltd., Greenwich Land LLC, Guo Media, GTV Media Group, Inc., Hamilton Capital Holdings Inc., HCHK Property Management, Inc., HCHK Technologies, Inc., Head Win Group Limited, Henan Yuda, Himalaya Embassy, Himalaya Exchange, Himalaya Federal Reserve, Himalaya Investment LLC, Himalaya International, Himalaya New World Inc., Himalaya Supervisory Organization, Himalaya Ventures LLC, HK International Funds Investments (USA) Limited LLC, Hong Kong International Funds Investments Limited, Hudson Diamond Holding,\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 65 of 1063\n\nInfinite Increase Limited, Infinitum Developments Limited, Infinity Treasury Management Inc., Insight Phoenix Fund, Lamp Capital LLC, Leading Shine Limited, Leading Shine NY Limited, Lexington Property and Staffing, Long Gate Limited, Maywind Trading LLC, MOS Himalaya LLC, Next Tycoon Investments Limited, New Federal State of China (a/k/a NFSC), Noble Fame Global Limited, Rosy Acme Ventures Limited, Rule of Law Foundation III, Inc., Rule of Law Foundation IV, Inc., Rule of Law Fund, Rule of Law Society, Rule of Law Society IV, Inc., G-Translators PTY LTD, Saraca Media Group, Inc., Shiny Ace Ltd., Shiny Times Holdings Ltd., Spirit Charter Investment Limited, Stevenson, Wong & Co., Voice of Guo Media, Inc., Well Origin Ltd., World Century Limited, Worldwide Opportunity Holdings Limited, Whitecroft Shore Limited, and ZIBA Limited.\n\n9. \"Including\" or any variant thereof means \"including without limitation.\"\n\n10. \"And\" and \"or\" mean \"and/or,\" and shall be construed both conjunctively as well as disjunctively in order to maximize their scope.\n\n11. \"Any\" and \"all\" and \"each\" mean \"each and every.\"\n\n12. \"Each\" and \"every\" mean \"each and every.\"\n\n13. \"Third Party\" means a Person or Entity other than Yourself.\n\n14. \"Transfer\" shall have the meaning given to it by section 101(54) of the Bankruptcy Code.\n\n15. \"Document\" means any information or thing within the scope of Fed. R. Civ. P. 34, and includes, without limitation, each and every written, recorded, or graphic matter of any kind, type, nature, or description that is or has been in Your Possession, Custody or Control, including all printed and electronic copies of electronic mail, computer files maintained in\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 66 of 1063\n\nelectronic form, electronic communication, text message, social media post, tweet, meta-data, correspondence, memoranda, tapes, stenographic or handwritten notes, written forms of any kind, charts, blueprints, drawings, sketches, graphs, plans, articles, specifications, diaries, letters, telegrams, photographs, minutes, contracts, agreements, surveys, computer printouts, data compilations of any kind, telexes, facsimiles, voice messages, invoices, order forms, checks, drafts, statements, credit memos, reports, position reports, summaries, indices, books, ledgers, notebooks, schedules, transparencies, recordings, catalogs, advertisements, promotional materials, films, video tapes, audio tapes, CDs, computer disks, brochures, pamphlets, punchcards, time-slips, Tweets, social media posts, or any written or recorded materials of any other kind, and all meta-data thereof, however stored (whether in tangible or electronic form), recorded, produced, or reproduced, and also including but not limited to, drafts or copies of any of the foregoing that contain any notes, comments, or markings of any kind not found on the original documents or that are otherwise not identical to the original documents.\n\n16. \"Person(s)\" means an individual, corporation, proprietorship, partnership, association, or any other Entity. \"Person\" also includes any agent, representatives, or expert, including but not limiting to, attorneys or financial advisors.\n\n17. \"Entity\" means any natural Person, corporation, partnership, subsidiary, sole proprietorship, firm, board, joint venture, association, agency, authority, commission or other business entity or juristic Person, as well as any affiliate, agent, parent including but not limited to legal counsel, financial advisors, or any other representative.\n\n18. \"Regarding\" means concerning, describing, comprising, referring to, related to, supporting, favoring, opposing, bolstering, detracting from, located in, considered in connection with, bearing on, evidencing, indicating, reporting on, recording, alluding to, responding to,\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 67 of 1063\n\nconnected with, commenting on, in respect of, about, in relation to, discussing, showing, describing, reflecting, analyzing constituting, and being.\n\n19. \"Relating to,\" \"relate(s) to\" or \"related to,\" when referring to any given subject matter, means, without limitation, any document that constitutes, comprises, involves, contains, embodies, reflects, identifies, states, refers directly or indirectly to, or is in any way relevant to the particular subject matter identified.\n\n20. \"Communication(s)\" means, in the broadest possible sense, and without limitation, any transmittal of information or knowledge (in the form of facts, ideas, inquiries, or otherwise). Communication(s) further refers to all conversations, agreements, inquiries, or replies, whether in person, by telephone, in writing, or by means of electronic transmittal devices, and includes, but is not limited to, all correspondence, emails, recordings, transmittal slips, memoranda, telephone communications, voice messages, telegrams, telefaxes, telecopies, telexes, instant messages, chats, text messages, telephonic notes, or notes transmitted internally or with third parties.\n\n21. \"Asset(s)\" means any item that can be used to produce positive economic value, including but not limited to any resource with economic value that is owned, controlled or is for the benefit of an entity, that is expected to provide a future benefit, including but not limited to, all real and personal property, intangible property, investments, rights to invest or to future revenue, cash, bank accounts, commodities, securities, claims, total or partial control of an entity, and prospective economic opportunities\n\n22. \"Transfer\" shall have the meaning given to it by section 101(54) of the Bankruptcy Code.\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 68 of 1063\n\n#### **IV. DOCUMENTS TO BE PRODUCED**\n\n1. All Documents regarding any income or Asset of the Debtor, the Debtor's estate, or an Associated Entity.\n\n2. All Documents related to the Debtor's financial condition and obligations to his creditors, including without limitation all Documents related to any effort to avoid paying such obligations and All Documents related to this or any other actual or potential bankruptcy or similar insolvency proceeding.\n\n3. All Documents regarding any balance sheet, bank statement, account statement, financial statement, statement of account, wire transfer instructions and/or confirmation, proof of funds, certificate of deposit, certificate of holdings, investment portfolio summary, or similar document relating to the Debtor, the Debtor's Estate, the Debtor's Family, an Associated Entity, or an Associated Individual, including without limitation all Documents sufficient to show all Transfers to any of the foregoing.\n\n4. All Documents regarding any investment, business dealing or transactions made by, with, or on behalf of the Debtor.\n\n5. All Communications with the Debtor, and Documents related to Communications with the Debtor, related to the operation, management, or decision-making of any Entity, including without limitation the Associated Entities.\n\n6. All Documents regarding any Transfer, investment, or other transaction or business dealing made to, by, or with the Debtor, the Debtor's Family, or an Associated Entity.\n\n7. All Documents regarding any property ever occupied or used by the Debtor, including without limitation the *Lady May*; the Sherry Netherland Hotel / Condominium; the\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 69 of 1063\n\nresidential property located in Greenwich, Connecticut at 373 Taconic Rd.; the residential property located in Greenwich, Connecticut at 33 Ferncliff Rd.; and the residential property located in Wilton, Connecticut at 354 Nod Hill Rd.\n\n8. All Documents related to any aircraft owned, controlled, or used by the Debtor, including without limitation the aircraft bearing tail number T7-GQM and any other aircraft registered in San Marino, including without limitation copies of all registration documents and flight manifests showing flights taken by such aircraft and the individuals onboard such flights.\n\n9. All Documents regarding any gifts, benefits or loans, to, from or on behalf of the Debtor, the Debtor's Estate, the Debtor's Family, or the Associated Entities, including without limitation Documents sufficient to show the amounts of such gifts, benefits, or loans; the purposes for which such gifts, benefits, or loans were used; when the gifts, benefits, or loans were provided; and the terms of any loans, all representations and warranties made in connection with any loans, the interest rate on any loans, and all evidence of payments of any loans.\n\n10. All Documents concerning any trust or similar instrument set up by, on behalf of, or for the benefit of the Debtor, the Debtor's Estate, the Debtor's Family, or an Associated Entity, including without limitation Documents sufficient to show when the trust(s) was created, by whom it was created, for whose benefit it was created, and the corpus of the trust.\n\n11. All Documents related to any obligation, claim, liability, or debt associated with any legal dispute involving the Debtor, including but not limited to those relating to any litigation before any local, state, federal, or international body, whether an administrative body, court, panel, or alternative dispute resolution entity.\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 70 of 1063\n\n12. All Documents and communications between any of your outside counsel or other advisors and the Debtor.\n\n13. Documents sufficient to show all of Your Assets and sources of income or funding.\n\n14. For all Assets identified in response to Request 14 having a value of more than \\$50,000, all (i) Documents related to Your acquisition of such Asset and (ii) Communications with the Debtor or the Debtor's Family regarding such Asset.\n\n15. Copies of Your tax returns.\n\n16. Documents sufficient to show all bank accounts and investment accounts within Your possession or control, including the balances of and transfers to and from each such account.\n\n17. All Documents regarding any credit cards used by You, including without limitation monthly statements or other Documents sufficient to show all purchases related thereto for the benefit of the Debtor or an Associated Entity.\n\n18. All corporate governance and organizational Documents, including without limitation by-laws and certificates of incorporation and other Documents sufficient to show Your corporate structure, names of officers and directors, business purpose, and relationship to the Debtor or to any member of the Debtor's Family.\n\n19. All Documents related to any pledge(s) of Your Assets to any other Entity.\n\nCase 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 71 of 1063\n\n# Exhibit C-3\n\n#### B2540 (Form 2540 – Subpoena for Rule 2004 Examination) (12/15) Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 72 of\n\nUNITED STATES BANKRUPTCY COURT 1063\n\n**District of Connecticut**\n\nIn re HO WAN KWOK, *et al*.,\n\n<sup>1</sup> Case No. 22-50073 (JAM)\n\nDebtor Chapter 11\n\n(Jointly Administered)\n\n## **SUBPOENA FOR RULE 2004 EXAMINATION**\n\nTo: **G Translators Pty Ltd**\n\n(*Name of person to whom the subpoena is directed*)\n\n*Testimony:* **YOU ARE COMMANDED** to appear at the time, date, and place set forth below to testify at an examination under Rule 2004, Federal Rules of Bankruptcy Procedure. A copy of the court order authorizing the examination is attached.\n\n| PLACE                    | DATE AND TIME |\n|--------------------------|---------------|\n| Paul Hastings LLP        |               |\n| 200 Park Avenue          | [TBD]         |\n| New York, New York 10166 |               |\n|                          |               |\n\nThe examination will be recorded by this method: **Court reporter/stenographer**\n\n*Production:* You, or your representatives, must also bring with you to the examination the following documents, electronically stored information, or objects, and must permit inspection, copying, testing, or sampling of the material:\n\n#### **See Requests for Production of Documents, attached hereto.**\n\nThe following provisions of Fed. R. Civ. P. 45, made applicable in bankruptcy cases by Fed. R. Bankr. P. 9016, are attached – Rule 45(c), relating to the place of compliance; Rule 45(d), relating to your protection as a person subject to a subpoena; and Rule 45(e) and 45(g), relating to your duty to respond to this subpoena and the potential consequences of not doing so.\n\nDate: **March , 2023**\n\nCLERK OF COURT\n\nOR\n\n*Signature of Clerk or Deputy Clerk Attorney's signature*\n\nThe name, address, email address, and telephone number of the attorney representing Luc A. Despins, Chapter 11 Trustee, who issues or requests this subpoena, are:\n\n**Douglas S. Skalka, Esq.; Neubert, Pepe & Monteith, P.C.; 195 Church Street, New Haven, Connecticut 06510 dskalka@npmlaw.com; (203) 821-2000**\n\n**Notice to the person who issues or requests this subpoena**\n\nIf this subpoena commands the production of documents, electronically stored information, or tangible things, or the inspection of premises before trial, a notice and a copy of this subpoena must be served on each party before it is served on the person to whom it is directed. Fed. R. Civ. P. 45(a)(4).\n\nSoftware Copyright (c) 1996-2022 Best Case, LLC - www.bestcase.com Best Case Bankruptcy 1 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\n#### **PROOF OF SERVICE**\n\n**(This section should not be filed with the court unless required by Fed. R. Civ. P. 45.)**\n\nI received this subpoena for (*name of individual and title, if any*): on (*date*) .\n\nI served the subpoena by delivering a copy to the named person as follows:\n\non *(date)* ; or\n\nI returned the subpoena unexecuted because:\n\nUnless the subpoena was issued on behalf of the United States, or one of its officers or agents, I have also tendered to the witness the fees for one day's attendance, and the mileage allowed by law, in the amount of \\$ .\n\nMy fees are \\$ for travel and \\$ for services, for a total of \\$ .\n\nI declare under penalty of perjury that this information is true and correct.\n\nDate:\n\n*Server's signature*\n\n*Printed name and title*\n\n*Server's address*\n\nAdditional information concerning attempted service, etc.:\n\n#### **Federal Rule of Civil Procedure 45(c), (d), (e), and (g) (Effective 12/1/13) (made applicable in bankruptcy cases by Rule 9016, Federal Rules of Bankruptcy Procedure)**\n\n#### **(c) Place of compliance.**\n\n*(1) For a Trial, Hearing, or Deposition.* A subpoena may command a person to attend a trial, hearing, or deposition only as follows:\n\n(A) within 100 miles of where the person resides, is employed, or regularly transacts business in person; or\n\n(B) within the state where the person resides, is employed, or regularly transacts business in person, if the person\n\n(i) is a party or a party's officer; or\n\n(ii) is commanded to attend a trial and would not incur substantial expense.\n\n*(2) For Other Discovery.* A subpoena may command:\n\n(A) production of documents, or electronically stored information, or things at a place within 100 miles of where the person resides, is employed, or regularly transacts business in person; and\n\n(B) inspection of premises, at the premises to be inspected.\n\n#### **(d) Protecting a Person Subject to a Subpoena; Enforcement.**\n\n*(1) Avoiding Undue Burden or Expense; Sanctions.* A party or attorney responsible for issuing and serving a subpoena must take reasonable steps to avoid imposing undue burden or expense on a person subject to the subpoena. The court for the district where compliance is required must enforce this duty and impose an appropriate sanction which may include lost earnings and reasonable attorney's fees — on a party or attorney who fails to comply.\n\n#### *(2) Command to Produce Materials or Permit Inspection.*\n\n*(A) Appearance Not Required.* A person commanded to produce documents, electronically stored information, or tangible things, or to permit the inspection of premises, need not appear in person at the place of production or inspection unless also commanded to appear for a deposition, hearing, or trial.\n\n*(B) Objections.* A person commanded to produce documents or tangible things or to permit inspection may serve on the party or attorney designated in the subpoena a written objection to inspecting, copying, testing or sampling any or all of the materials or to inspecting the premises — or to producing electronically stored information in the form or forms requested. The objection must be served before the earlier of the time specified for compliance or 14 days after the subpoena is served. If an objection is made, the following rules apply:\n\n(i) At any time, on notice to the commanded person, the serving party may move the court for the district where compliance is required for an order compelling production or inspection.\n\n(ii) These acts may be required only as directed in the order, and the order must protect a person who is neither a party nor a party's officer from significant expense resulting from compliance.\n\n#### *(3) Quashing or Modifying a Subpoena.*\n\n*(A) When Required.* On timely motion, the court for the district where compliance is required must quash or modify a subpoena that:\n\n(i) fails to allow a reasonable time to comply;\n\n(ii) requires a person to comply beyond the geographical limits specified in Rule 45(c);\n\n(iii) requires disclosure of privileged or other protected matter, if no exception or waiver applies; or\n\n(iv) subjects a person to undue burden.\n\n*(B) When Permitted.* To protect a person subject to or affected by a subpoena, the court for the district where compliance is required may, on motion, quash or modify the subpoena if it requires:\n\n(i) disclosing a trade secret or other confidential research, development, or commercial information; or\n\n(ii) disclosing an unretained expert's opinion or information that does not describe specific occurrences in dispute and results from the expert's study that was not requested by a party.\n\n(C) *Specifying Conditions as an Alternative.* In the circumstances described in Rule 45(d)(3)(B), the court may, instead of quashing or modifying a subpoena, order appearance or production under specified conditions if the serving party:\n\n(i) shows a substantial need for the testimony or material that cannot be otherwise met without undue hardship; and\n\n(ii) ensures that the subpoenaed person will be reasonably compensated.\n\n#### **(e) Duties in Responding to a Subpoena.**\n\n*(1) Producing Documents or Electronically Stored Information.* These procedures apply to producing documents or electronically stored information:\n\n*(A) Documents.* A person responding to a subpoena to produce documents must produce them as they are kept in the ordinary course of business or must organize and label them to correspond to the categories in the demand.\n\n*(B) Form for Producing Electronically Stored Information Not Specified.* If a subpoena does not specify a form for producing electronically stored information, the person responding must produce it in a form or forms in which it is ordinarily maintained or in a reasonably usable form or forms.\n\n*(C) Electronically Stored Information Produced in Only One Form.* The person responding need not produce the same electronically stored information in more than one form.\n\n*(D) Inaccessible Electronically Stored Information.* The person responding need not provide discovery of electronically stored information from sources that the person identifies as not reasonably accessible because of undue burden or cost. On motion to compel discovery or for a protective order, the person responding must show that the information is not reasonably accessible because of undue burden or cost. If that showing is made, the court may nonetheless order discovery from such sources if the requesting party shows good cause, considering the limitations of Rule 26(b)(2)(C). The court may specify conditions for the discovery.\n\n#### *(2) Claiming Privilege or Protection.*\n\n*(A) Information Withheld.* A person withholding subpoenaed information under a claim that it is privileged or subject to protection as trial-preparation material must: (i) expressly make the claim; and\n\n(ii) describe the nature of the withheld documents, communications, or tangible things in a manner that, without revealing information itself privileged or protected, will enable the parties to assess the claim.\n\n*(B) Information Produced.* If information produced in response to a subpoena is subject to a claim of privilege or of protection as trial-preparation material, the person making the claim may notify any party that received the information of the claim and the basis for it. After being notified, a party must promptly return, sequester, or destroy the specified information and any copies it has; must not use or disclose the information until the claim is resolved; must take reasonable steps to retrieve the information if the party disclosed it before being notified; and may promptly present the information under seal to the court for the district where compliance is required for a determination of the claim. The person who produced the information must preserve the information until the claim is resolved.\n\n**(g) Contempt.** The court for the district where compliance is required – and also, after a motion is transferred, the issuing court – may hold in contempt a person who, having been served, fails without adequate excuse to obey the subpoena or an order related to it.\n\nFor access to subpoena materials, see Fed.R.Civ.P.45(a) Committee Note (2013)\n\n…\n\n## **Requests for Production of Documents**\n\n## **I. INSTRUCTIONS**\n\n1. Unless otherwise indicated, the requests for documents set forth below, (the \"Requests,\" and each, a \"Request\"), must be responded to separately and specifically. Each Request shall be answered fully unless it is in good faith objected to, in which event the reason for Your objection shall be stated in detail, as set forth below. If an objection pertains only to a portion of a Request, or a word, phrase or clause contained within it, You are required to state Your objection to that portion only and to respond to the remainder of the Requests.\n\n2. Electronically stored information must be produced in accordance with the\n\nfollowing instructions:\n\n- a. Images. Black and white images must be 300 DPI Group IV single-page TIFF files. Color images must be produced in JPEG format. File names cannot contain embedded spaces or special characters (including the comma). Folder names cannot contain embedded spaces or special characters (including the comma). All TIFF image files must have a unique file name, i.e. Bates number. Images must be endorsed with sequential Bates numbers in the lower right corner of each image. The number of TIFF files per folder should not exceed 1000 files. Excel spreadsheets should have a placeholder image named by the Bates number of the file.\n- b. Image Load File\n\t- a. Concordance® Data File. The data file (.DAT) contains all of the fielded information that will be loaded into the Concordance® database. The first line of the .DAT file must be a header row identifying the field names. The .DAT file must use the following Concordance® default delimiters: Comma ASCII character (020) Quote þ ASCII character (254). Date fields should be provided in the format: mm/dd/yyyy. Date and time fields must be two separate fields. If documents includes imaged emails and attachments, the attachment fields must be included to preserve the parent/child relationship between an email and its attachments. An OCRPATH field must be included to provide the file path and name of the extracted text file on the produced storage media. The text file must be named after the FIRSTBATES. Do not include the text in the .DAT file. For Documents with native files, a LINK field must be included to provide the file path and\n\nname of the native file. The native file must be named after the FIRSTBATES.\n\n- b. Concordance Image® OR Opticon Cross-Reference File. The image crossreference file (.LOG or .OPT) links the images to the database records. It should be a comma-delimited file consisting of seven fields per line with a line in the cross-reference file for every image in the database with the following format: ImageID,VolumeLabel,ImageFilePath,DocumentBreak,FolderBreak,Box Break,PageCoun.\n- c. Document Text. Text must be produced as separate text files, not as fields within the .DAT file. The full path to the text file (OCRPATH) should be included in the .DAT file. It is recommended document level ANSI text files, named per the FIRSTBATES/Image Key. Extracted text files must be in a separate folder, and the number of text files per folder should not exceed 1,000 files. There should be no special characters (including commas in the folder names). Text files must be provided on a document level.\n- d. Native Production for Certain File Types. File types that reasonably require viewing in their native format for a full understanding of their content and meaning must be produced in native format. These include, but are not limited to, spreadsheets, spreadsheet-like files (Microsoft Excel, comma separated values, tab separated values, etc.), Microsoft PowerPoint or other special presentation files, database files, and audio/visual files. Provide an image of a Bates numbered slip sheet indicating the presence of a native file, and include the path to the native as a field in the .dat file. Name the produced native file with the Bates number corresponding to the slip sheet for the file. Group native files within incrementally named \"NATIVE\" directories, separate from images directories.\n- e. De-duplication. Produce a single copy of each electronic document for which exact duplicates exist. For email messages, consolidate duplicates based on MD5 hash generated from the BCC, Body, CC, From, IntMsgID, To, and Attach properties. For email attachments and standalone electronic files, consolidate duplicates based on MD5 hash of the entire file.\n- f. Metadata. Produce extracted metadata for each document in the form of a Concordance compliant load file (.dat). The first line of the .DAT file must be a header row identifying the field names. The .DAT file must use the following Concordance default delimiters: Comma , ASCII character (020) Quote þ ASCII character (254)\n\nDate fields should be provided in the format: mm/dd/yyyy. Date and time fields must be two separate fields. Required metadata listed below:\n\n# Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 77 of 1063\n\n| Field Name   | Sample Data              | Description                                                                                  |\n|--------------|--------------------------|----------------------------------------------------------------------------------------------|\n| FIRSTBATES   | EDC0000001               | First Bates number of native file document/email                                             |\n| LASTBATES    | EDC0000001               | Last Bates number of native file document/email<br>**The LASTBATES field should be populated |\n|              |                          | for single page                                                                              |\n| ATTACHRANGE  | EDC0000001<br>-          | Bates number of the first page of the parent                                                 |\n|              | EDC0000015               | document to the Bates number of the last page of                                             |\n|              |                          | the last attachment \"child\" document                                                         |\n| BEGATTACH    | EDC0000001               | First Bates number of attachment range                                                       |\n| ENDATTACH    | EDC0000015               | Last Bates number of attachment range                                                        |\n| CUSTODIAN    | Smith, John              | Email: Mailbox where the email resided                                                       |\n|              |                          | Native: Name of the individual or department                                                 |\n|              |                          | from whose files the document<br>originated                                                  |\n| FROM         | John Smith               | Email: Sender                                                                                |\n|              |                          | Native: Author(s) of document                                                                |\n|              |                          | **semi-colon should be used to separate                                                      |\n|              |                          | multiple entries                                                                             |\n| TO           | Coffman, Janice; LeeW    | Recipient(s)                                                                                 |\n|              | [mailto:LeeW@MSN.com]    | **semi-colon should be used to separate multiple                                             |\n|              |                          | entries                                                                                      |\n| CC           | Frank Thompson [mailto:  | Carbon copy recipient(s)                                                                     |\n|              | frank_Thompson@cdt.com]  | **semi-colon should be used to separate                                                      |\n|              |                          | multiple entries                                                                             |\n| BCC          | John Cain                | Blind carbon copy recipient(s)                                                               |\n|              |                          | **semi-colon should be used to separate                                                      |\n|              |                          | multiple entries                                                                             |\n| SUBJECT      | Board Meeting Minutes    | Email: Subject line of the email Native: Title                                               |\n|              |                          | of document (if available)                                                                   |\n| FILE_NAME    | BoardMeetingMinutes.docx | Native: Name of the original native file,                                                    |\n|              |                          | including extension                                                                          |\n| DATE_SENT    | 10/12/2010               | Email: Date the email was sent                                                               |\n|              |                          | Native: (empty)                                                                              |\n| TIME_SENT/   | 07:05 PM GMT             | Email: Time the email was sent/ Time zone in                                                 |\n| TIME_ZONE    |                          | which the emails were standardized                                                           |\n| TIME_ZONE    | GMT                      | The<br>time zone in which<br>the emails<br>were                                              |\n|              |                          | standardized during conversion.                                                              |\n| LINK         |  EDC0000001.msg   | Hyperlink to the email or native file document                                               |\n|              |                          | **The linked file must be named per the                                                      |\n|              |                          | FIRSTBATES number                                                                            |\n| FILE_EXTEN   | MSG                      | The file type extension                                                                      |\n|              |                          | representing                                                                                 |\n|              |                          | the Email or                                                                                 |\n| AUTHOR       | John Smith               | Email: (empty)                                                                               |\n|              |                          | Native: Author of the document                                                               |\n| DATE_CREATED | 10/10/2010               | Email: (empty)                                                                               |\n|              |                          | Native: Date the document was created                                                        |\n\n# Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 78 of 1063\n\n| TIME_CREATED | 10:25 AM                  | Email: (empty)                                  |\n|--------------|---------------------------|-------------------------------------------------|\n|              |                           | Native: Time the document was created           |\n|              |                           | **This data must be a separate field and cannot |\n|              |                           | be combined with the DATE_CREATED field         |\n| DATE_MOD     | 10/12/2010                | Email: (empty)                                  |\n|              |                           | Native: Date the document was last modified     |\n| TIME_MOD     | 07:00 PM                  | Email: (empty)                                  |\n|              |                           | Native: Time the document was last modified     |\n|              |                           | **This data must be a separate field and cannot |\n|              |                           | be combined with the DATE_MOD field             |\n|              |                           |                                                 |\n| DATE_ACCESSD | 10/12/2010                | Email: (empty)                                  |\n|              |                           | Native: Date the document was last accessed     |\n| TIME_ACCESSD | 07:00 PM                  | Email: (empty)                                  |\n|              |                           | Native: Time the document was last accessed     |\n|              |                           | **This data must be a separate field and cannot |\n|              |                           | be combined with the DATE_ACCESSD field         |\n| FILE_SIZE    | 5,952                     | Size of native file<br>document/email in KB     |\n| PGCOUNT      | 1                         | Number of pages in native file document/email   |\n| PATH         |   | Email: (empty)                                  |\n|              | Agenda.doc                | Native: Path where native file document was     |\n|              |                           | stored including original file name.            |\n| INTFILEPATH  | Personal Folders\\Deleted  | Email: original location of email including     |\n|              | Items\\Board Meeting       | original file name.                             |\n|              | Minutes.msg               | Native: (empty)                                 |\n| INTMSGID     | <000805c2c71b\\$75977050\\$ | Email: Unique Message ID Native: (empty)        |\n|              | cb8306d1@MSN>             |                                                 |\n| MD5HASH      | d131dd02c5e6eec4693d9a0   | MD5 Hash value of the document.                 |\n|              | 698aff95c                 |                                                 |\n|              | 2fcab58712467eab4004583e  |                                                 |\n|              | b8fb7f89                  |                                                 |\n| OCRPATH      | TEXT/001/EDC0000001.txt   | Path to extracted text of the native file       |\n\n3. Each Request operates and should be construed independently and, unless otherwise indicated, no Request limits the scope of any other Request.\n\n4. All Documents are to be produced as kept in the usual course of business or are to be organized and labeled to correspond with the categories in these Requests.\n\n5. Each Request contained herein extends to all Documents: (a) in Your possession, custody, or control; or (b) in the possession, custody, or control of anyone acting on Your behalf,\n\n#### Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 79 of 1063\n\nincluding Your counsel or other representatives and advisors. Each Document shall be produced in its entirety.\n\n6. If You are requested to produce a Document that is no longer in Your possession, custody, or control, then Your response must (a) describe in detail the nature of the document and its contents; (b) identify the person(s) who prepared or authored the Document (and, if applicable, the Person(s) to whom the Document was sent); (c) identify the date on which the document was prepared or created; (d) state whether such Document (i) is missing or lost, (ii) has been destroyed, (iii) has been transferred, voluntarily or involuntarily, to others, or (iv) was otherwise disposed of; (e) state the reason for, and the facts and circumstances surrounding, such disposition; (f) identify the Persons who authorized such disposition; (g) identify the date or approximate date of such disposition; (h) state when the Document was most recently in Your possession, custody or control; and (i) identify the Person, if any, presently in possession, custody, or control of such Document.\n\n7. If You are requested to produce a Document that has been destroyed, then Your response must state, in addition to the information required by the preceding Instruction: (a) the reason for the Document's destruction; (b) the identity of the Person who destroyed the Document; and (c) the identity of the Person who directed that the Document be destroyed.\n\n8. If You claim that a requested Document is privileged or attorney work-product, then Your response must: (a) state (i) a description of the Document adequate to support Your contention that the Document is privileged, (ii) the title of the Document, (iii) the date of the Document, (iv) the author of the Document, (v) the addressee of the Document, (vi) the identity of each Person who received or saw the original or any draft, copy, or reproduction of the Document, (vii) whether the Document itself, or any information contained or referred to in the Document is in the possession, custody, or control of any other Persons, and if so, the identity of\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 80 of 1063\n\nsuch Persons, as well as a statement addressing how the information came into their possession, (viii) the claim of privilege under which the Document is withheld, and (ix) all of the circumstances upon which You will rely to support such claim of privilege; and (b) produce a privilege log containing all of the information requested in Part (a) of this Instruction for each Document withheld on the basis of a claim of privilege in accordance with D. Conn. L. Civ. R. 26(e).\n\n9. If a portion of an otherwise responsive Document contains information subject to a claim of privilege, only that portion of the Document subject to the claim of privilege shall be deleted or redacted from the Document following the instructions above, and the rest shall be produced.\n\n10. The Requests are continuing in nature. You are hereby instructed to (a) supplement or correct any responses later learned to be incomplete or incorrect immediately upon learning that a prior response was incomplete or incorrect; and (b) produce any additional Documents that are called for under the\n\n11. If a Document is in a language other than English, You should provide that Document. If a Document is in a language other than English, and an English translation exists, You should provide both Documents.\n\n12. All references to Entities includes all affiliates thereof.\n\n13. All references to individual names include all alternative names, aliased, or nicknames.\n\n14. Unless otherwise expressly indicated, the period of time covered by the Document Requests is the period from February 5, 2012 to the date responses to the Document Requests are due.\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 81 of 1063\n\n#### **II. RULES OF CONSTRUCTION**\n\n15. The use of (a) any singular noun shall be construed to include the plural, and vice versa, and (b) a verb in any tense shall be construed as the use of the verb in all other tenses.\n\n16. The terms (a) \"and\" and \"or\" shall be construed either conjunctively or disjunctively as necessary to bring within the scope of any request all responses that might otherwise be construed to be outside of its scope, and (b) \"each\" and \"any\" shall be deemed to include and encompass the words \"every\" and \"all.\"\n\n#### **III. DEFINITIONS**\n\nThe definitions supplied by D. Conn. L. Civ. R. 26(c) and the rules of construction supplied by D. Conn. L. Civ. R. 26(d), as incorporated by D. Conn. Bankr. L.R. 2004-1(a), shall apply to the Document Requests. In addition, the following terms used in these Document Requests shall have the following meanings:\n\n1. \"You\" or \"Your\" or \"Yourself\" means and refers to G Translators Pty Ltd, together with all of its affiliates, divisions, agencies, instrumentalities, departments, offices, partners, officers, directors, agents, attorneys, representatives, employees, and/or anyone acting on its behalf.\n\n2. \"Debtor\" means Ho Wan Kwok (a/k/a Miles Kwok, Miles Guo, Guo Wengui, Guo Haoyun, 郭文贵, or any other alias), together with his employees, agents, counsel, advisors, or anyone acting on his behalf.\n\n3. \"Debtor's Son\" means Qiang Guo (a/k/a Mileson Kwok, 郭强, or any other alias), together with his employees, agents, counsel, advisors, or anyone acting on his behalf.\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 82 of 1063\n\n4. \"Debtor's Daughter\" means Mei Guo (a/k/a Mei Gui, 郭美, or any other alias), together with her employees, agents, counsel, advisors, or anyone acting on her behalf.\n\n5. \"Debtor's Purported Wife\" means Hing Chi Ngok (a/k/a Hing Chi Ng, Yue Qingzhi, 岳庆芝, or any other alias), together with her employees, agents, counsel, advisors, or anyone acting on her behalf.\n\n6. \"Debtor's Family\" means, collectively, the Debtor, the Debtor's Son, the Debtor's Daughter, and the Debtor's Purported Wife, and any other familial relation to the Debtor.\n\n7. \"Associated Individuals\" means, individually and collectively, all individuals that (1) hold, control, have custody over, or discretion over assets owned, controlled, or enjoyed by the Debtor or the Debtor's Family; or (2) have been employees, directors, or otherwise are affiliated with one or more Associated Entities, together with the respective employees, agents, counsel, advisors, or anyone acting on behalf of any of the foregoing. Such Associated Individuals shall include, but are not limited to: Daniel Podhaskie, Jason Miller, Steve Bannon, Karin Maistrello, Melissa Francis, Anthony DiBattista, William Gertz, Arethusa Forsyth, Glenn Mellor, Jennifer Mercurio, Eduardo Eurnekian, Wencong Wang, Han Chunguang (a/k/a 韩春光), Qu Guojiao (a/k/a Qu Guo Jiao, 屈国姣), Guo Lijie (a/k/a 郭丽杰), Zhang Wei (a/k/a 张伟\\*), Lihong Wei Lafrenz (a/k/a Sara Wei, 魏丽红), Hao Haidong (a/k/a 郝海东), Ross Heinemeyer, Max Krasner, Kyle Bass, Melissa Mendez, Ya Li (a/k/a 李娅), Dinggang Wang (a/k/a 王定刚), An Hong (a/k/a 安红), Yvette Wang (a/k/a Yanping Wang, Yan Ping Wang, 王雁平), Fiona Yu, Je Kin Ming (a/k/a William Je, Yu Jianming, 余建明), Yaz Qingua, and Lao Jiang (a/k/a Jiang Yunfu, Jiang Yunfu Be, 姜云浮).\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 83 of 1063\n\n8. \"Associated Entities\" means, individually and collectively, all organizations or Entities of any type that (1) have been owned, controlled, or invested in by the Debtor or the Debtor's Family; or (2) have an interest, whether directly or indirectly, in any assets owned, controlled, or enjoyed by the Debtor or the Debtor's Family, together with the respective employees, agents, counsel, advisors, or anyone acting on behalf of any of the foregoing. Such Associated Entities shall include, but are not limited to: 7 Nod Hill LLC, AAGV Limited, ACA Investment Management Limited, ACA Capital Group Limited, Ace Decade Holdings Limited, AI Group Holdings Inc., Alfa Global Ventures Limited, Alfonso Global Limited, Allied Capital Global Limited, Alpine Fiduciaries SA, Anton Development Limited, Assets Sino Limited, Auspicious Coast Limited, Beijing Pangu Investment Co., Beijing Pangu Investment Co. Ltd., Beijing Pangu Investment Inc., Beijing Zenith Holdings Company Limited, Booming Sail New York LLC, Bravo Luck Limited, BSA Strategic Fund I, China Golden Spring (Hong Kong) Limited, Chuang Xin Limited, Crane Advisory Group LLC, Creative Apex Investments Limited, Crystal Breeze Investments Limited, Dawn State Limited, Eastern Profit Corporation Limited, Elite Well Global Limited, Empire Growth Holdings, Freedom Media Ventures Ltd., G Club Operations LLC, G News LLC, GETTR USA, Genever Holdings Corporation, Genever Holdings LLC, GFNY, Inc., Globalist International Limited, GNews Media Group Inc., Golden Spring (New York) Ltd., Greenwich Land LLC, Guo Media, GTV Media Group, Inc., Hamilton Capital Holdings Inc., HCHK Property Management, Inc., HCHK Technologies, Inc., Head Win Group Limited, Henan Yuda, Himalaya Embassy, Himalaya Exchange, Himalaya Federal Reserve, Himalaya Investment LLC, Himalaya International, Himalaya New World Inc., Himalaya Supervisory Organization, Himalaya Ventures LLC, HK International Funds Investments (USA) Limited LLC, Hong Kong International Funds Investments Limited, Hudson Diamond Holding,\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 84 of 1063\n\nInfinite Increase Limited, Infinitum Developments Limited, Infinity Treasury Management Inc., Insight Phoenix Fund, Lamp Capital LLC, Leading Shine Limited, Leading Shine NY Limited, Lexington Property and Staffing, Long Gate Limited, Maywind Trading LLC, MOS Himalaya LLC, Next Tycoon Investments Limited, New Federal State of China (a/k/a NFSC), Noble Fame Global Limited, Rosy Acme Ventures Limited, Rule of Law Foundation III, Inc., Rule of Law Foundation IV, Inc., Rule of Law Fund, Rule of Law Society, Rule of Law Society IV, Inc., Saraca Media Group, Inc., Shiny Ace Ltd., Shiny Times Holdings Ltd., Spirit Charter Investment Limited, Stevenson, Wong & Co., Voice of Guo Media, Inc., Well Origin Ltd., World Century Limited, Worldwide Opportunity Holdings Limited, Whitecroft Shore Limited, and ZIBA Limited.\n\n9. \"Including\" or any variant thereof means \"including without limitation.\"\n\n10. \"And\" and \"or\" mean \"and/or,\" and shall be construed both conjunctively as well as disjunctively in order to maximize their scope.\n\n11. \"Any\" and \"all\" and \"each\" mean \"each and every.\"\n\n12. \"Each\" and \"every\" mean \"each and every.\"\n\n13. \"Third Party\" means a Person or Entity other than Yourself.\n\n14. \"Transfer\" shall have the meaning given to it by section 101(54) of the Bankruptcy Code.\n\n15. \"Document\" means any information or thing within the scope of Fed. R. Civ. P. 34, and includes, without limitation, each and every written, recorded, or graphic matter of any kind, type, nature, or description that is or has been in Your Possession, Custody or Control, including all printed and electronic copies of electronic mail, computer files maintained in electronic form, electronic communication, text message, social media post, tweet, meta-data,\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 85 of 1063\n\ncorrespondence, memoranda, tapes, stenographic or handwritten notes, written forms of any kind, charts, blueprints, drawings, sketches, graphs, plans, articles, specifications, diaries, letters, telegrams, photographs, minutes, contracts, agreements, surveys, computer printouts, data compilations of any kind, telexes, facsimiles, voice messages, invoices, order forms, checks, drafts, statements, credit memos, reports, position reports, summaries, indices, books, ledgers, notebooks, schedules, transparencies, recordings, catalogs, advertisements, promotional materials, films, video tapes, audio tapes, CDs, computer disks, brochures, pamphlets, punchcards, time-slips, Tweets, social media posts, or any written or recorded materials of any other kind, and all meta-data thereof, however stored (whether in tangible or electronic form), recorded, produced, or reproduced, and also including but not limited to, drafts or copies of any of the foregoing that contain any notes, comments, or markings of any kind not found on the original documents or that are otherwise not identical to the original documents.\n\n16. \"Person(s)\" means an individual, corporation, proprietorship, partnership, association, or any other Entity. \"Person\" also includes any agent, representatives, or expert, including but not limiting to, attorneys or financial advisors.\n\n17. \"Entity\" means any natural Person, corporation, partnership, subsidiary, sole proprietorship, firm, board, joint venture, association, agency, authority, commission or other business entity or juristic Person, as well as any affiliate, agent, parent including but not limited to legal counsel, financial advisors, or any other representative.\n\n18. \"Regarding\" means concerning, describing, comprising, referring to, related to, supporting, favoring, opposing, bolstering, detracting from, located in, considered in connection with, bearing on, evidencing, indicating, reporting on, recording, alluding to, responding to,\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 86 of 1063\n\nconnected with, commenting on, in respect of, about, in relation to, discussing, showing, describing, reflecting, analyzing constituting, and being.\n\n19. \"Relating to,\" \"relate(s) to\" or \"related to,\" when referring to any given subject matter, means, without limitation, any document that constitutes, comprises, involves, contains, embodies, reflects, identifies, states, refers directly or indirectly to, or is in any way relevant to the particular subject matter identified.\n\n20. \"Communication(s)\" means, in the broadest possible sense, and without limitation, any transmittal of information or knowledge (in the form of facts, ideas, inquiries, or otherwise). Communication(s) further refers to all conversations, agreements, inquiries, or replies, whether in person, by telephone, in writing, or by means of electronic transmittal devices, and includes, but is not limited to, all correspondence, emails, recordings, transmittal slips, memoranda, telephone communications, voice messages, telegrams, telefaxes, telecopies, telexes, instant messages, chats, text messages, telephonic notes, or notes transmitted internally or with third parties.\n\n21. \"Asset(s)\" means any item that can be used to produce positive economic value, including but not limited to any resource with economic value that is owned, controlled or is for the benefit of an entity, that is expected to provide a future benefit, including but not limited to, all real and personal property, intangible property, investments, rights to invest or to future revenue, cash, bank accounts, commodities, securities, claims, total or partial control of an entity, and prospective economic opportunities\n\n22. \"Transfer\" shall have the meaning given to it by section 101(54) of the Bankruptcy Code.\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 87 of 1063\n\n#### **IV. DOCUMENTS TO BE PRODUCED**\n\n1. All Documents regarding any income or Asset of the Debtor, the Debtor's estate, or an Associated Entity.\n\n2. All Documents related to the Debtor's financial condition and obligations to his creditors, including without limitation all Documents related to any effort to avoid paying such obligations and All Documents related to this or any other actual or potential bankruptcy or similar insolvency proceeding.\n\n3. All Documents regarding any balance sheet, bank statement, account statement, financial statement, statement of account, wire transfer instructions and/or confirmation, proof of funds, certificate of deposit, certificate of holdings, investment portfolio summary, or similar document relating to the Debtor, the Debtor's Estate, the Debtor's Family, an Associated Entity, or an Associated Individual, including without limitation all Documents sufficient to show all Transfers to any of the foregoing.\n\n4. All Documents regarding any investment, business dealing or transactions made by, with, or on behalf of the Debtor.\n\n5. All Communications with the Debtor, and Documents related to Communications with the Debtor, related to the operation, management, or decision-making of any Entity, including without limitation the Associated Entities.\n\n6. All Documents regarding any Transfer, investment, or other transaction or business dealing made to, by, or with the Debtor, the Debtor's Family, or an Associated Entity.\n\n7. All Documents regarding any property ever occupied or used by the Debtor, including without limitation the *Lady May*; the Sherry Netherland Hotel / Condominium; the\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 88 of 1063\n\nresidential property located in Greenwich, Connecticut at 373 Taconic Rd.; the residential property located in Greenwich, Connecticut at 33 Ferncliff Rd.; and the residential property located in Wilton, Connecticut at 354 Nod Hill Rd.\n\n8. All Documents related to any aircraft owned, controlled, or used by the Debtor, including without limitation the aircraft bearing tail number T7-GQM and any other aircraft registered in San Marino, including without limitation copies of all registration documents and flight manifests showing flights taken by such aircraft and the individuals onboard such flights.\n\n9. All Documents regarding any gifts, benefits or loans, to, from or on behalf of the Debtor, the Debtor's Estate, the Debtor's Family, or the Associated Entities, including without limitation Documents sufficient to show the amounts of such gifts, benefits, or loans; the purposes for which such gifts, benefits, or loans were used; when the gifts, benefits, or loans were provided; and the terms of any loans, all representations and warranties made in connection with any loans, the interest rate on any loans, and all evidence of payments of any loans.\n\n10. All Documents concerning any trust or similar instrument set up by, on behalf of, or for the benefit of the Debtor, the Debtor's Estate, the Debtor's Family, or an Associated Entity, including without limitation Documents sufficient to show when the trust(s) was created, by whom it was created, for whose benefit it was created, and the corpus of the trust.\n\n11. All Documents related to any obligation, claim, liability, or debt associated with any legal dispute involving the Debtor, including but not limited to those relating to any litigation before any local, state, federal, or international body, whether an administrative body, court, panel, or alternative dispute resolution entity.\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 89 of 1063\n\n12. All Documents and communications between any of your outside counsel or other advisors and the Debtor.\n\n13. Documents sufficient to show all of Your Assets and sources of income or funding.\n\n14. For all Assets identified in response to Request 14 having a value of more than \\$50,000, all (i) Documents related to Your acquisition of such Asset and (ii) Communications with the Debtor or the Debtor's Family regarding such Asset.\n\n15. Copies of Your tax returns.\n\n16. Documents sufficient to show all bank accounts and investment accounts within Your possession or control, including the balances of and transfers to and from each such account.\n\n17. All Documents regarding any credit cards used by You, including without limitation monthly statements or other Documents sufficient to show all purchases related thereto for the benefit of the Debtor or an Associated Entity.\n\n18. All corporate governance and organizational Documents, including without limitation by-laws and certificates of incorporation and other Documents sufficient to show Your corporate structure, names of officers and directors, business purpose, and relationship to the Debtor or to any member of the Debtor's Family.\n\n19. All Documents related to any pledge(s) of Your Assets to any other Entity.\n\nCase 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 90 of 1063\n\n# Exhibit C-4\n\n#### B2540 (Form 2540 – Subpoena for Rule 2004 Examination) (12/15) Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 91 of\n\nUNITED STATES BANKRUPTCY COURT 1063\n\n**District of Connecticut**\n\nIn re HO WAN KWOK, *et al*.,\n\n<sup>1</sup> Case No. 22-50073 (JAM)\n\nDebtor Chapter 11\n\n(Jointly Administered)\n\n## **SUBPOENA FOR RULE 2004 EXAMINATION**\n\nTo: **Martha Jeffery**\n\n(*Name of person to whom the subpoena is directed*)\n\n*Testimony:* **YOU ARE COMMANDED** to appear at the time, date, and place set forth below to testify at an examination under Rule 2004, Federal Rules of Bankruptcy Procedure. A copy of the court order authorizing the examination is attached.\n\n| PLACE                    | DATE AND TIME |\n|--------------------------|---------------|\n| Paul Hastings LLP        |               |\n| 200 Park Avenue          | [TBD]         |\n| New York, New York 10166 |               |\n|                          |               |\n\nThe examination will be recorded by this method: **Court reporter/stenographer**\n\n*Production:* You, or your representatives, must also bring with you to the examination the following documents, electronically stored information, or objects, and must permit inspection, copying, testing, or sampling of the material:\n\n#### **See Requests for Production of Documents, attached hereto.**\n\nThe following provisions of Fed. R. Civ. P. 45, made applicable in bankruptcy cases by Fed. R. Bankr. P. 9016, are attached – Rule 45(c), relating to the place of compliance; Rule 45(d), relating to your protection as a person subject to a subpoena; and Rule 45(e) and 45(g), relating to your duty to respond to this subpoena and the potential consequences of not doing so.\n\nDate: **March , 2023**\n\nCLERK OF COURT\n\nOR\n\n*Signature of Clerk or Deputy Clerk Attorney's signature*\n\nThe name, address, email address, and telephone number of the attorney representing Luc A. Despins, Chapter 11 Trustee, who issues or requests this subpoena, are:\n\n**Douglas S. Skalka, Esq.; Neubert, Pepe & Monteith, P.C.; 195 Church Street, New Haven, Connecticut 06510 dskalka@npmlaw.com; (203) 821-2000**\n\n**Notice to the person who issues or requests this subpoena**\n\nIf this subpoena commands the production of documents, electronically stored information, or tangible things, or the inspection of premises before trial, a notice and a copy of this subpoena must be served on each party before it is served on the person to whom it is directed. Fed. R. Civ. P. 45(a)(4).\n\nSoftware Copyright (c) 1996-2022 Best Case, LLC - www.bestcase.com Best Case Bankruptcy 1 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\n#### **PROOF OF SERVICE**\n\n**(This section should not be filed with the court unless required by Fed. R. Civ. P. 45.)**\n\nI received this subpoena for (*name of individual and title, if any*): on (*date*) .\n\nI served the subpoena by delivering a copy to the named person as follows:\n\non *(date)* ; or\n\nI returned the subpoena unexecuted because:\n\nUnless the subpoena was issued on behalf of the United States, or one of its officers or agents, I have also tendered to the witness the fees for one day's attendance, and the mileage allowed by law, in the amount of \\$ .\n\nMy fees are \\$ for travel and \\$ for services, for a total of \\$ .\n\nI declare under penalty of perjury that this information is true and correct.\n\nDate:\n\n*Server's signature*\n\n*Printed name and title*\n\n*Server's address*\n\nAdditional information concerning attempted service, etc.:\n\n#### **Federal Rule of Civil Procedure 45(c), (d), (e), and (g) (Effective 12/1/13) (made applicable in bankruptcy cases by Rule 9016, Federal Rules of Bankruptcy Procedure)**\n\n#### **(c) Place of compliance.**\n\n*(1) For a Trial, Hearing, or Deposition.* A subpoena may command a person to attend a trial, hearing, or deposition only as follows:\n\n(A) within 100 miles of where the person resides, is employed, or regularly transacts business in person; or\n\n(B) within the state where the person resides, is employed, or regularly transacts business in person, if the person\n\n(i) is a party or a party's officer; or\n\n(ii) is commanded to attend a trial and would not incur substantial expense.\n\n*(2) For Other Discovery.* A subpoena may command:\n\n(A) production of documents, or electronically stored information, or things at a place within 100 miles of where the person resides, is employed, or regularly transacts business in person; and\n\n(B) inspection of premises, at the premises to be inspected.\n\n#### **(d) Protecting a Person Subject to a Subpoena; Enforcement.**\n\n*(1) Avoiding Undue Burden or Expense; Sanctions.* A party or attorney responsible for issuing and serving a subpoena must take reasonable steps to avoid imposing undue burden or expense on a person subject to the subpoena. The court for the district where compliance is required must enforce this duty and impose an appropriate sanction which may include lost earnings and reasonable attorney's fees — on a party or attorney who fails to comply.\n\n#### *(2) Command to Produce Materials or Permit Inspection.*\n\n*(A) Appearance Not Required.* A person commanded to produce documents, electronically stored information, or tangible things, or to permit the inspection of premises, need not appear in person at the place of production or inspection unless also commanded to appear for a deposition, hearing, or trial.\n\n*(B) Objections.* A person commanded to produce documents or tangible things or to permit inspection may serve on the party or attorney designated in the subpoena a written objection to inspecting, copying, testing or sampling any or all of the materials or to inspecting the premises — or to producing electronically stored information in the form or forms requested. The objection must be served before the earlier of the time specified for compliance or 14 days after the subpoena is served. If an objection is made, the following rules apply:\n\n(i) At any time, on notice to the commanded person, the serving party may move the court for the district where compliance is required for an order compelling production or inspection.\n\n(ii) These acts may be required only as directed in the order, and the order must protect a person who is neither a party nor a party's officer from significant expense resulting from compliance.\n\n#### *(3) Quashing or Modifying a Subpoena.*\n\n*(A) When Required.* On timely motion, the court for the district where compliance is required must quash or modify a subpoena that:\n\n(i) fails to allow a reasonable time to comply;\n\n(ii) requires a person to comply beyond the geographical limits specified in Rule 45(c);\n\n(iii) requires disclosure of privileged or other protected matter, if no exception or waiver applies; or\n\n(iv) subjects a person to undue burden.\n\n*(B) When Permitted.* To protect a person subject to or affected by a subpoena, the court for the district where compliance is required may, on motion, quash or modify the subpoena if it requires:\n\n(i) disclosing a trade secret or other confidential research, development, or commercial information; or\n\n(ii) disclosing an unretained expert's opinion or information that does not describe specific occurrences in dispute and results from the expert's study that was not requested by a party.\n\n(C) *Specifying Conditions as an Alternative.* In the circumstances described in Rule 45(d)(3)(B), the court may, instead of quashing or modifying a subpoena, order appearance or production under specified conditions if the serving party:\n\n(i) shows a substantial need for the testimony or material that cannot be otherwise met without undue hardship; and\n\n(ii) ensures that the subpoenaed person will be reasonably compensated.\n\n#### **(e) Duties in Responding to a Subpoena.**\n\n*(1) Producing Documents or Electronically Stored Information.* These procedures apply to producing documents or electronically stored information:\n\n*(A) Documents.* A person responding to a subpoena to produce documents must produce them as they are kept in the ordinary course of business or must organize and label them to correspond to the categories in the demand.\n\n*(B) Form for Producing Electronically Stored Information Not Specified.* If a subpoena does not specify a form for producing electronically stored information, the person responding must produce it in a form or forms in which it is ordinarily maintained or in a reasonably usable form or forms.\n\n*(C) Electronically Stored Information Produced in Only One Form.* The person responding need not produce the same electronically stored information in more than one form.\n\n*(D) Inaccessible Electronically Stored Information.* The person responding need not provide discovery of electronically stored information from sources that the person identifies as not reasonably accessible because of undue burden or cost. On motion to compel discovery or for a protective order, the person responding must show that the information is not reasonably accessible because of undue burden or cost. If that showing is made, the court may nonetheless order discovery from such sources if the requesting party shows good cause, considering the limitations of Rule 26(b)(2)(C). The court may specify conditions for the discovery.\n\n#### *(2) Claiming Privilege or Protection.*\n\n*(A) Information Withheld.* A person withholding subpoenaed information under a claim that it is privileged or subject to protection as trial-preparation material must: (i) expressly make the claim; and\n\n(ii) describe the nature of the withheld documents, communications, or tangible things in a manner that, without revealing information itself privileged or protected, will enable the parties to assess the claim.\n\n*(B) Information Produced.* If information produced in response to a subpoena is subject to a claim of privilege or of protection as trial-preparation material, the person making the claim may notify any party that received the information of the claim and the basis for it. After being notified, a party must promptly return, sequester, or destroy the specified information and any copies it has; must not use or disclose the information until the claim is resolved; must take reasonable steps to retrieve the information if the party disclosed it before being notified; and may promptly present the information under seal to the court for the district where compliance is required for a determination of the claim. The person who produced the information must preserve the information until the claim is resolved.\n\n**(g) Contempt.** The court for the district where compliance is required – and also, after a motion is transferred, the issuing court – may hold in contempt a person who, having been served, fails without adequate excuse to obey the subpoena or an order related to it.\n\nFor access to subpoena materials, see Fed.R.Civ.P.45(a) Committee Note (2013)\n\n…\n\n## **Request for Production of Documents**\n\n## **I. INSTRUCTIONS**\n\n1. Unless otherwise indicated, the requests for documents set forth below, (the \"Requests,\" and each, a \"Request\"), must be responded to separately and specifically. Each Request shall be answered fully unless it is in good faith objected to, in which event the reason for Your objection shall be stated in detail, as set forth below. If an objection pertains only to a portion of a Request, or a word, phrase or clause contained within it, You are required to state Your objection to that portion only and to respond to the remainder of the Requests.\n\n2. Electronically stored information must be produced in accordance with the\n\nfollowing instructions:\n\n- a. Images. Black and white images must be 300 DPI Group IV single-page TIFF files. Color images must be produced in JPEG format. File names cannot contain embedded spaces or special characters (including the comma). Folder names cannot contain embedded spaces or special characters (including the comma). All TIFF image files must have a unique file name, i.e. Bates number. Images must be endorsed with sequential Bates numbers in the lower right corner of each image. The number of TIFF files per folder should not exceed 1000 files. Excel spreadsheets should have a placeholder image named by the Bates number of the file.\n- b. Image Load File\n\t- a. Concordance® Data File. The data file (.DAT) contains all of the fielded information that will be loaded into the Concordance® database. The first line of the .DAT file must be a header row identifying the field names. The .DAT file must use the following Concordance® default delimiters: Comma ASCII character (020) Quote þ ASCII character (254). Date fields should be provided in the format: mm/dd/yyyy. Date and time fields must be two separate fields. If documents includes imaged emails and attachments, the attachment fields must be included to preserve the parent/child relationship between an email and its attachments. An OCRPATH field must be included to provide the file path and name of the extracted text file on the produced storage media. The text file must be named after the FIRSTBATES. Do not include the text in the .DAT file. For Documents with native files, a LINK field must be included to provide the file path and\n\nname of the native file. The native file must be named after the FIRSTBATES.\n\n- b. Concordance Image® OR Opticon Cross-Reference File. The image crossreference file (.LOG or .OPT) links the images to the database records. It should be a comma-delimited file consisting of seven fields per line with a line in the cross-reference file for every image in the database with the following format: ImageID,VolumeLabel,ImageFilePath,DocumentBreak,FolderBreak,Box Break,PageCoun.\n- c. Document Text. Text must be produced as separate text files, not as fields within the .DAT file. The full path to the text file (OCRPATH) should be included in the .DAT file. It is recommended document level ANSI text files, named per the FIRSTBATES/Image Key. Extracted text files must be in a separate folder, and the number of text files per folder should not exceed 1,000 files. There should be no special characters (including commas in the folder names). Text files must be provided on a document level.\n- d. Native Production for Certain File Types. File types that reasonably require viewing in their native format for a full understanding of their content and meaning must be produced in native format. These include, but are not limited to, spreadsheets, spreadsheet-like files (Microsoft Excel, comma separated values, tab separated values, etc.), Microsoft PowerPoint or other special presentation files, database files, and audio/visual files. Provide an image of a Bates numbered slip sheet indicating the presence of a native file, and include the path to the native as a field in the .dat file. Name the produced native file with the Bates number corresponding to the slip sheet for the file. Group native files within incrementally named \"NATIVE\" directories, separate from images directories.\n- e. De-duplication. Produce a single copy of each electronic document for which exact duplicates exist. For email messages, consolidate duplicates based on MD5 hash generated from the BCC, Body, CC, From, IntMsgID, To, and Attach properties. For email attachments and standalone electronic files, consolidate duplicates based on MD5 hash of the entire file.\n- f. Metadata. Produce extracted metadata for each document in the form of a Concordance compliant load file (.dat). The first line of the .DAT file must be a header row identifying the field names. The .DAT file must use the following Concordance default delimiters: Comma , ASCII character (020) Quote þ ASCII character (254)\n\nDate fields should be provided in the format: mm/dd/yyyy. Date and time fields must be two separate fields. Required metadata listed below:\n\n# Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 96 of 1063\n\n| Field Name   | Sample Data              | Description                                                                                  |\n|--------------|--------------------------|----------------------------------------------------------------------------------------------|\n| FIRSTBATES   | EDC0000001               | First Bates number of native file document/email                                             |\n| LASTBATES    | EDC0000001               | Last Bates number of native file document/email<br>**The LASTBATES field should be populated |\n|              |                          | for single page                                                                              |\n| ATTACHRANGE  | EDC0000001<br>-          | Bates number of the first page of the parent                                                 |\n|              | EDC0000015               | document to the Bates number of the last page of                                             |\n|              |                          | the last attachment \"child\" document                                                         |\n| BEGATTACH    | EDC0000001               | First Bates number of attachment range                                                       |\n| ENDATTACH    | EDC0000015               | Last Bates number of attachment range                                                        |\n| CUSTODIAN    | Smith, John              | Email: Mailbox where the email resided                                                       |\n|              |                          | Native: Name of the individual or department                                                 |\n|              |                          | from whose files the document<br>originated                                                  |\n| FROM         | John Smith               | Email: Sender                                                                                |\n|              |                          | Native: Author(s) of document                                                                |\n|              |                          | **semi-colon should be used to separate                                                      |\n|              |                          | multiple entries                                                                             |\n| TO           | Coffman, Janice; LeeW    | Recipient(s)                                                                                 |\n|              | [mailto:LeeW@MSN.com]    | **semi-colon should be used to separate multiple                                             |\n|              |                          | entries                                                                                      |\n| CC           | Frank Thompson [mailto:  | Carbon copy recipient(s)                                                                     |\n|              | frank_Thompson@cdt.com]  | **semi-colon should be used to separate                                                      |\n|              |                          | multiple entries                                                                             |\n| BCC          | John Cain                | Blind carbon copy recipient(s)                                                               |\n|              |                          | **semi-colon should be used to separate                                                      |\n|              |                          | multiple entries                                                                             |\n| SUBJECT      | Board Meeting Minutes    | Email: Subject line of the email Native: Title                                               |\n|              |                          | of document (if available)                                                                   |\n| FILE_NAME    | BoardMeetingMinutes.docx | Native: Name of the original native file,                                                    |\n|              |                          | including extension                                                                          |\n| DATE_SENT    | 10/12/2010               | Email: Date the email was sent                                                               |\n|              |                          | Native: (empty)                                                                              |\n| TIME_SENT/   | 07:05 PM GMT             | Email: Time the email was sent/ Time zone in                                                 |\n| TIME_ZONE    |                          | which the emails were standardized                                                           |\n| TIME_ZONE    | GMT                      | The<br>time zone in which<br>the emails<br>were                                              |\n|              |                          | standardized during conversion.                                                              |\n| LINK         |  EDC0000001.msg   | Hyperlink to the email or native file document                                               |\n|              |                          | **The linked file must be named per the                                                      |\n|              |                          | FIRSTBATES number                                                                            |\n| FILE_EXTEN   | MSG                      | The file type extension                                                                      |\n|              |                          | representing                                                                                 |\n|              |                          | the Email or                                                                                 |\n| AUTHOR       | John Smith               | Email: (empty)                                                                               |\n|              |                          | Native: Author of the document                                                               |\n| DATE_CREATED | 10/10/2010               | Email: (empty)                                                                               |\n|              |                          | Native: Date the document was created                                                        |\n\n# Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 97 of 1063\n\n| TIME_CREATED | 10:25 AM                  | Email: (empty)                                  |\n|--------------|---------------------------|-------------------------------------------------|\n|              |                           | Native: Time the document was created           |\n|              |                           | **This data must be a separate field and cannot |\n|              |                           | be combined with the DATE_CREATED field         |\n| DATE_MOD     | 10/12/2010                | Email: (empty)                                  |\n|              |                           | Native: Date the document was last modified     |\n| TIME_MOD     | 07:00 PM                  | Email: (empty)                                  |\n|              |                           | Native: Time the document was last modified     |\n|              |                           | **This data must be a separate field and cannot |\n|              |                           | be combined with the DATE_MOD field             |\n|              |                           |                                                 |\n| DATE_ACCESSD | 10/12/2010                | Email: (empty)                                  |\n|              |                           | Native: Date the document was last accessed     |\n| TIME_ACCESSD | 07:00 PM                  | Email: (empty)                                  |\n|              |                           | Native: Time the document was last accessed     |\n|              |                           | **This data must be a separate field and cannot |\n|              |                           | be combined with the DATE_ACCESSD field         |\n| FILE_SIZE    | 5,952                     | Size of native file<br>document/email in KB     |\n| PGCOUNT      | 1                         | Number of pages in native file document/email   |\n| PATH         |   | Email: (empty)                                  |\n|              | Agenda.doc                | Native: Path where native file document was     |\n|              |                           | stored including original file name.            |\n| INTFILEPATH  | Personal Folders\\Deleted  | Email: original location of email including     |\n|              | Items\\Board Meeting       | original file name.                             |\n|              | Minutes.msg               | Native: (empty)                                 |\n| INTMSGID     | <000805c2c71b\\$75977050\\$ | Email: Unique Message ID Native: (empty)        |\n|              | cb8306d1@MSN>             |                                                 |\n| MD5HASH      | d131dd02c5e6eec4693d9a0   | MD5 Hash value of the document.                 |\n|              | 698aff95c                 |                                                 |\n|              | 2fcab58712467eab4004583e  |                                                 |\n|              | b8fb7f89                  |                                                 |\n| OCRPATH      | TEXT/001/EDC0000001.txt   | Path to extracted text of the native file       |\n\n3. Each Request operates and should be construed independently and, unless otherwise indicated, no Request limits the scope of any other Request.\n\n4. All Documents are to be produced as kept in the usual course of business or are to be organized and labeled to correspond with the categories in these Requests.\n\n5. Each Request contained herein extends to all Documents: (a) in Your possession, custody, or control; or (b) in the possession, custody, or control of anyone acting on Your behalf,\n\n#### Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 98 of 1063\n\nincluding Your counsel or other representatives and advisors. Each Document shall be produced in its entirety.\n\n6. If You are requested to produce a Document that is no longer in Your possession, custody, or control, then Your response must (a) describe in detail the nature of the document and its contents; (b) identify the person(s) who prepared or authored the Document (and, if applicable, the Person(s) to whom the Document was sent); (c) identify the date on which the document was prepared or created; (d) state whether such Document (i) is missing or lost, (ii) has been destroyed, (iii) has been transferred, voluntarily or involuntarily, to others, or (iv) was otherwise disposed of; (e) state the reason for, and the facts and circumstances surrounding, such disposition; (f) identify the Persons who authorized such disposition; (g) identify the date or approximate date of such disposition; (h) state when the Document was most recently in Your possession, custody or control; and (i) identify the Person, if any, presently in possession, custody, or control of such Document.\n\n7. If You are requested to produce a Document that has been destroyed, then Your response must state, in addition to the information required by the preceding Instruction: (a) the reason for the Document's destruction; (b) the identity of the Person who destroyed the Document; and (c) the identity of the Person who directed that the Document be destroyed.\n\n8. If You claim that a requested Document is privileged or attorney work-product, then Your response must: (a) state (i) a description of the Document adequate to support Your contention that the Document is privileged, (ii) the title of the Document, (iii) the date of the Document, (iv) the author of the Document, (v) the addressee of the Document, (vi) the identity of each Person who received or saw the original or any draft, copy, or reproduction of the Document, (vii) whether the Document itself, or any information contained or referred to in the Document is in the possession, custody, or control of any other Persons, and if so, the identity of\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 99 of 1063\n\nsuch Persons, as well as a statement addressing how the information came into their possession, (viii) the claim of privilege under which the Document is withheld, and (ix) all of the circumstances upon which You will rely to support such claim of privilege; and (b) produce a privilege log containing all of the information requested in Part (a) of this Instruction for each Document withheld on the basis of a claim of privilege in accordance with D. Conn. L. Civ. R. 26(e). For any part of a Document Request as to which a claim of privilege or work product is not made, responsive documents should be provided in full.\n\n9. If a portion of an otherwise responsive Document contains information subject to a claim of privilege, only that portion of the Document subject to the claim of privilege shall be deleted or redacted from the Document following the instructions above, and the rest shall be produced.\n\n10. The Requests are continuing in nature. You are hereby instructed to (a) supplement or correct any responses later learned to be incomplete or incorrect immediately upon learning that a prior response was incomplete or incorrect; and (b) produce any additional Documents that are called for under the\n\n11. If a Document is in a language other than English, You should provide that Document. If a Document is in a language other than English, and an English translation exists, You should provide both Documents.\n\n12. All references to Entities includes all affiliates thereof.\n\n13. All references to individual names include all alternative names, aliased, or nicknames.\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 100 of 1063\n\n14. Unless otherwise expressly indicated, the period of time covered by the Document Requests is the period from February 5, 2015 to the date responses to the Document Requests are due.\n\n#### **II. RULES OF CONSTRUCTION**\n\n15. The use of (a) any singular noun shall be construed to include the plural, and vice versa, and (b) a verb in any tense shall be construed as the use of the verb in all other tenses.\n\n16. The terms (a) \"and\" and \"or\" shall be construed either conjunctively or disjunctively as necessary to bring within the scope of any request all responses that might otherwise be construed to be outside of its scope, and (b) \"each\" and \"any\" shall be deemed to include and encompass the words \"every\" and \"all.\"\n\n#### **III. DEFINITIONS**\n\nThe definitions supplied by D. Conn. L. Civ. R. 26(c) and the rules of construction supplied by D. Conn. L. Civ. R. 26(d), as incorporated by D. Conn. Bankr. L.R. 2004-1(a), shall apply to the Document Requests. In addition, the following terms used in these Document Requests shall have the following meanings:\n\n1. \"You\" or \"Your\" or \"Yourself\" means and refers to Martha Jeffery, together with any of their employees, agents, counsel, advisors, or anyone acting on their behalf.\n\n2. \"Debtor\" means Ho Wan Kwok (a/k/a Miles Kwok, Miles Guo, Guo Wengui, Guo Haoyun, 郭文贵, or any other alias), together with his employees, agents, counsel, advisors, or anyone acting on his behalf.\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 101 of 1063\n\n3. \"Debtor's Son\" means Qiang Guo (a/k/a Mileson Kwok, 郭强, or any other alias), together with his employees, agents, counsel, advisors, or anyone acting on his behalf.\n\n4. \"Debtor's Daughter\" means Mei Guo (a/k/a Mei Gui, 郭美, or any other alias), together with her employees, agents, counsel, advisors, or anyone acting on her behalf.\n\n5. \"Debtor's Purported Wife\" means Hing Chi Ngok (a/k/a Hing Chi Ng, Yue Qingzhi, 岳庆芝, or any other alias), together with her employees, agents, counsel, advisors, or anyone acting on her behalf.\n\n6. \"Debtor's Family\" means, collectively, the Debtor, the Debtor's Son, the Debtor's Daughter, and the Debtor's Purported Wife, and any other familial relation to the Debtor.\n\n7. \"Associated Individuals\" means, individually and collectively, all individuals that (1) hold, control, have custody over, or discretion over assets owned, controlled, or enjoyed by the Debtor or the Debtor's Family; or (2) have been employees, directors, or otherwise are affiliated with one or more Associated Entities, together with the respective employees, agents, counsel, advisors, or anyone acting on behalf of any of the foregoing. Such Associated Individuals shall include, but are not limited to: Daniel Podhaskie, Karin Maistrello, Melissa Francis, Anthony DiBattista, Han Chunguang (a/k/a 韩春光), Qu Guojiao (a/k/a Qu Guo Jiao, 屈国姣), Zhang Wei (a/k/a 张伟\\*), Lihong Wei Lafrenz (a/k/a Sara Wei, 魏丽红Max Krasner, Yvette Wang (a/k/a Yanping Wang, Yan Ping Wang, 王雁平), Fiona Yu, and Je Kin Ming (a/k/a William Je, Yu Jianming, 余建明).\n\n8. \"Associated Entities\" means, individually and collectively, all organizations or Entities of any type that (1) have been owned, controlled, or invested in by the Debtor or the Debtor's Family; or (2) have an interest, whether directly or indirectly, in any assets owned,\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 102 of 1063\n\ncontrolled, or enjoyed by the Debtor or the Debtor's Family, together with the respective employees, agents, counsel, advisors, or anyone acting on behalf of any of the foregoing. Such Associated Entities shall include, but are not limited to: 7 Nod Hill LLC, ACA Investment Management Limited, ACA Capital Group Limited, Ace Decade Holdings Limited, AI Group Holdings Inc., Booming Sail New York LLC, Bravo Luck Limited, China Golden Spring (Hong Kong) Limited, Crane Advisory Group LLC, Dawn State Limited, Eastern Profit Corporation Limited, Freedom Media Ventures Ltd., G Club Operations LLC, G Fashion LLC, G News LLC, GETTR USA, Genever Holdings Corporation, Genever Holdings LLC, Gfashion Media Group Inc., GFNY, Inc., Golden Spring (New York) Ltd., Greenwich Land LLC, GTV Media Group, Inc., Hamilton Capital Holdings Inc., HCHK Property Management, Inc., HCHK Technologies, Inc., Himalaya Embassy, Himalaya Exchange, Himalaya Federal Reserve, Himalaya Investment LLC, Himalaya International, Himalaya New World Inc., Himalaya Supervisory Organization, Himalaya Ventures LLC, HK International Funds Investments (USA) Limited LLC, Hong Kong International Funds Investments Limited, Hudson Diamond Holding, Infinity Treasury Management Inc., Lexington Property and Staffing, Long Gate Limited, Maywind Trading LLC, MOS Himalaya LLC, New Federal State of China (a/k/a NFSC), Rule of Law Foundation III, Inc., Rule of Law Foundation IV, Inc., Rule of Law Fund, Rule of Law Society, Rule of Law Society IV, Inc., G-Translators PTY LTD, Saraca Media Group, Inc., Well Origin Ltd., Whitecroft Shore Limited, and ZIBA Limited.\n\n9. \"Including\" or any variant thereof means \"including without limitation.\"\n\n10. \"And\" and \"or\" mean \"and/or,\" and shall be construed both conjunctively as well as disjunctively in order to maximize their scope.\n\n11. \"Any\" and \"all\" and \"each\" mean \"each and every.\"\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 103 of 1063\n\n12. \"Each\" and \"every\" mean \"each and every.\"\n\n13. \"Third Party\" means a Person or Entity other than Yourself.\n\n14. \"Transfer\" shall have the meaning given to it by section 101(54) of the Bankruptcy Code.\n\n15. \"Document\" means any information or thing within the scope of Fed. R. Civ. P. 34, and includes, without limitation, each and every written, recorded, or graphic matter of any kind, type, nature, or description that is or has been in Your possession, custody or control, including all printed and electronic copies of electronic mail, computer files maintained in electronic form, correspondence, memoranda, tapes, stenographic or handwritten notes, written forms of any kind, charts, blueprints, drawings, sketches, graphs, plans, articles, specifications, diaries, letters, telegrams, photographs, minutes, contracts, agreements, surveys, computer printouts, data compilations of any kind, telexes, facsimiles, emails, text messages, instant messages, voice messages, invoices, order forms, checks, drafts, statements, credit memos, reports, position reports, summaries, indices, books, ledgers, notebooks, schedules, transparencies, recordings, catalogs, advertisements, promotional materials, films, video tapes, audio tapes, CDs, computer disks, brochures, pamphlets, punch-cards, time-slips, Tweets, social media posts, or any written or recorded materials of any other kind, and all meta-data thereof, however stored (whether in tangible or electronic form), recorded, produced, or reproduced, and also including but not limited to, drafts or copies of any of the foregoing that contain any notes, comments, or markings of any kind not found on the original documents or that are otherwise not identical to the original documents.\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 104 of 1063\n\n16. \"Person(s)\" means an individual, corporation, proprietorship, partnership, association, or any other Entity. \"Person\" also includes any agent, representatives, or expert, including but not limiting to, attorneys or financial advisors.\n\n17. \"Entity\" means any natural Person, corporation, partnership, subsidiary, sole proprietorship, firm, board, joint venture, association, agency, authority, commission or other business entity or juristic Person, as well as any affiliate, agent, parent including but not limited to counsel, financial advisors, or any other representative.\n\n18. \"Regarding\" means concerning, describing, comprising, referring to, related to, supporting, favoring, opposing, bolstering, detracting from, located in, considered in connection with, bearing on, evidencing, indicating, reporting on, recording, alluding to, responding to, connected with, commenting on, in respect of, about, in relation to, discussing, showing, describing, reflecting, analyzing constituting, and being.\n\n19. \"Relating to,\" \"relate(s) to\" or \"related to,\" when referring to any given subject matter, means, without limitation, any document that constitutes, comprises, involves, contains, embodies, reflects, identifies, states, refers directly or indirectly to, or is in any way relevant to the particular subject matter identified.\n\n20. \"Communication(s)\" means, in the broadest possible sense, and without limitation, any transmittal of information or knowledge (in the form of facts, ideas, inquiries, or otherwise). Communication(s) further refers to all conversations, agreements, inquiries, or replies, whether in person, by telephone, in writing, or by means of electronic transmittal devices, and includes, but is not limited to, all correspondence, emails, recordings, transmittal slips, memoranda, telephone communications, voice messages, telegrams, telefaxes, telecopies, telexes, instant messages, chats, text messages, postings to a message board or group chat, social media posts, tweets, videos\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 105 of 1063\n\nuploaded to any video platform, telephonic notes, or notes transmitted internally or with third parties.\n\n21. \"Asset(s)\" means any item of economic value that is subject to possession, custody, or control. Asset includes all real and personal property, including but limited to, real estate, land, houses, apartments, condominiums, automobiles, yachts, boats, planes, jets, helicopters, cash, bank accounts, cryptocurrencies, securities, accounts receivables, inventory, and other tangible and intangible property.\n\n#### **IV. DOCUMENTS TO BE PRODUCED**\n\n1. All Documents and communications regarding the Sherry Netherland Hotel / Condominium, located at 781 Fifth Avenue, New York, NY 10022 (apartments 1801 and 1519; the residential property located at 373 Taconic Rd., Greenwich, Connecticut 06831; the residential property located at 33 Ferncliff Rd., Cos Cob, Connecticut 06807; the residential property located at 354 Nod Hill Rd., Wilton, Connecticut 06897; the property located in at 32 Chateau Ridge Rd., Greenwich, Connecticut 06831; the property located at 110 Clapboard Ridge Rd., Greenwich, Connecticut 06830; the property located at 66 Sherwood Avenue, Greenwich, Connecticut 06831; the property located at 140 Wallacks Drive, Stamford, Connecticut 06902; the property located at 602 Indian Field Drive, Greenwich, Connecticut 06830; and the property located at 11 Hurlingham Drive, Greenwich, Connecticut 06831.\n\n2. All Documents or communications related to any income or Asset of the Debtor, the Debtor's estate, the Debtor's Family, or Associated Entity, including without limitation any real property located in Connecticut.\n\n### Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 106 of 1063\n\n3. All Documents or communications related to any engagement letter with the Debtor, any member of the Debtor's Family, and/or any Associated Entity, including copy(ies) of such engagement letter(s).\n\n4. All Documents or communications related to the payment of any retainer or commission to You based upon your representation of the Debtor, the Debtor's Family, or an Associated Entity, including documents sufficient to identify the amount of the retainer or commission and its source.\n\n5. All Documents or communications related to any fees, payments, or monies received by You from or on behalf of the Debtor, the Debtor's Family, a Family Related Entity, or an Associated Entity held in escrow or in a client trust account.\n\n6. Documents sufficient to show the amount, date, and source of any payments made to You by, on behalf of, or for the benefit of the Debtor, the Debtor's Family, or an Associated Entity.\n\n7. All Communications between You and, either, the Debtor, the Debtor's Family, or any Associated Individual, agent, employee, or other individual acting on behalf of the Debtor, related to any Transfer, investment, or other transaction or business dealing relating to the Debtor, the Debtor's Estate, the Debtor's Family, or the Associated Entities.\n\n8. All Documents and communications related to any sale, potential sale, acquisition, disposition, purchase, potential purchase, investment, contribution, gift, extension of credit, loan, or Transfer involving the Debtor, the Debtor's Family, or any Associated Entity.\n\n9. All Documents and communications related to the Debtor's use of any Assets belonging to, controlled by, or whose complete or partial ownership is held by the Debtor's Family,\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 107 of 1063\n\nan Associated Entity, or an Associated Individual, including without limitation any real property located in Connecticut.\n\n10. All Documents and communications regarding any balance sheet, bank statement, account statement, financial statement, statement of account, wire transfer instructions and/or confirmation, proof of funds, certificate of deposit, certificate of holdings, investment portfolio summary, or similar document relating to the Debtor, the Debtor's Estate, the Debtor's Family, an Associated Entity, or an Associated Individual, including without limitation all Documents sufficient to show all Transfers to any of the foregoing.\n\nCase 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 108 of 1063\n\n# Exhibit C-5\n\n#### B2540 (Form 2540 – Subpoena for Rule 2004 Examination) (12/15) Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 109 of\n\n1063\n\nUNITED STATES BANKRUPTCY COURT\n\n**District of Connecticut**\n\nIn re HO WAN KWOK, *et al*.,\n\n<sup>1</sup> Case No. 22-50073 (JAM)\n\nDebtor Chapter 11\n\n(Jointly Administered)\n\n# **SUBPOENA FOR RULE 2004 EXAMINATION**\n\nTo: **Emile P de Neree**\n\n(*Name of person to whom the subpoena is directed*)\n\n*Testimony:* **YOU ARE COMMANDED** to appear at the time, date, and place set forth below to testify at an examination under Rule 2004, Federal Rules of Bankruptcy Procedure. A copy of the court order authorizing the examination is attached.\n\n| PLACE                    | DATE AND TIME |\n|--------------------------|---------------|\n| Paul Hastings LLP        |               |\n| 200 Park Avenue          | [TBD]         |\n| New York, New York 10166 |               |\n|                          |               |\n\nThe examination will be recorded by this method: **Court reporter/stenographer**\n\n*Production:* You, or your representatives, must also bring with you to the examination the following documents, electronically stored information, or objects, and must permit inspection, copying, testing, or sampling of the material:\n\n#### **See Requests for Production of Documents, attached hereto.**\n\nThe following provisions of Fed. R. Civ. P. 45, made applicable in bankruptcy cases by Fed. R. Bankr. P. 9016, are attached – Rule 45(c), relating to the place of compliance; Rule 45(d), relating to your protection as a person subject to a subpoena; and Rule 45(e) and 45(g), relating to your duty to respond to this subpoena and the potential consequences of not doing so.\n\nDate: **March , 2023**\n\nCLERK OF COURT\n\nOR\n\n*Signature of Clerk or Deputy Clerk Attorney's signature*\n\nThe name, address, email address, and telephone number of the attorney representing Luc A. Despins, Chapter 11 Trustee, who issues or requests this subpoena, are:\n\n**Douglas S. Skalka, Esq.; Neubert, Pepe & Monteith, P.C.; 195 Church Street, New Haven, Connecticut 06510 dskalka@npmlaw.com; (203) 821-2000**\n\n**Notice to the person who issues or requests this subpoena**\n\nIf this subpoena commands the production of documents, electronically stored information, or tangible things, or the inspection of premises before trial, a notice and a copy of this subpoena must be served on each party before it is served on the person to whom it is directed. Fed. R. Civ. P. 45(a)(4).\n\nSoftware Copyright (c) 1996-2022 Best Case, LLC - www.bestcase.com Best Case Bankruptcy 1 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\n#### **PROOF OF SERVICE**\n\n**(This section should not be filed with the court unless required by Fed. R. Civ. P. 45.)**\n\nI received this subpoena for (*name of individual and title, if any*): on (*date*) .\n\nI served the subpoena by delivering a copy to the named person as follows:\n\non *(date)* ; or\n\nI returned the subpoena unexecuted because:\n\nUnless the subpoena was issued on behalf of the United States, or one of its officers or agents, I have also tendered to the witness the fees for one day's attendance, and the mileage allowed by law, in the amount of \\$ .\n\nMy fees are \\$ for travel and \\$ for services, for a total of \\$ .\n\nI declare under penalty of perjury that this information is true and correct.\n\nDate:\n\n*Server's signature*\n\n*Printed name and title*\n\n*Server's address*\n\nAdditional information concerning attempted service, etc.:\n\n#### **Federal Rule of Civil Procedure 45(c), (d), (e), and (g) (Effective 12/1/13) (made applicable in bankruptcy cases by Rule 9016, Federal Rules of Bankruptcy Procedure)**\n\n#### **(c) Place of compliance.**\n\n*(1) For a Trial, Hearing, or Deposition.* A subpoena may command a person to attend a trial, hearing, or deposition only as follows:\n\n(A) within 100 miles of where the person resides, is employed, or regularly transacts business in person; or\n\n(B) within the state where the person resides, is employed, or regularly transacts business in person, if the person\n\n(i) is a party or a party's officer; or\n\n(ii) is commanded to attend a trial and would not incur substantial expense.\n\n*(2) For Other Discovery.* A subpoena may command:\n\n(A) production of documents, or electronically stored information, or things at a place within 100 miles of where the person resides, is employed, or regularly transacts business in person; and\n\n(B) inspection of premises, at the premises to be inspected.\n\n#### **(d) Protecting a Person Subject to a Subpoena; Enforcement.**\n\n*(1) Avoiding Undue Burden or Expense; Sanctions.* A party or attorney responsible for issuing and serving a subpoena must take reasonable steps to avoid imposing undue burden or expense on a person subject to the subpoena. The court for the district where compliance is required must enforce this duty and impose an appropriate sanction which may include lost earnings and reasonable attorney's fees — on a party or attorney who fails to comply.\n\n#### *(2) Command to Produce Materials or Permit Inspection.*\n\n*(A) Appearance Not Required.* A person commanded to produce documents, electronically stored information, or tangible things, or to permit the inspection of premises, need not appear in person at the place of production or inspection unless also commanded to appear for a deposition, hearing, or trial.\n\n*(B) Objections.* A person commanded to produce documents or tangible things or to permit inspection may serve on the party or attorney designated in the subpoena a written objection to inspecting, copying, testing or sampling any or all of the materials or to inspecting the premises — or to producing electronically stored information in the form or forms requested. The objection must be served before the earlier of the time specified for compliance or 14 days after the subpoena is served. If an objection is made, the following rules apply:\n\n(i) At any time, on notice to the commanded person, the serving party may move the court for the district where compliance is required for an order compelling production or inspection.\n\n(ii) These acts may be required only as directed in the order, and the order must protect a person who is neither a party nor a party's officer from significant expense resulting from compliance.\n\n#### *(3) Quashing or Modifying a Subpoena.*\n\n*(A) When Required.* On timely motion, the court for the district where compliance is required must quash or modify a subpoena that:\n\n(i) fails to allow a reasonable time to comply;\n\n(ii) requires a person to comply beyond the geographical limits specified in Rule 45(c);\n\n(iii) requires disclosure of privileged or other protected matter, if no exception or waiver applies; or\n\n(iv) subjects a person to undue burden.\n\n*(B) When Permitted.* To protect a person subject to or affected by a subpoena, the court for the district where compliance is required may, on motion, quash or modify the subpoena if it requires:\n\n(i) disclosing a trade secret or other confidential research, development, or commercial information; or\n\n(ii) disclosing an unretained expert's opinion or information that does not describe specific occurrences in dispute and results from the expert's study that was not requested by a party.\n\n(C) *Specifying Conditions as an Alternative.* In the circumstances described in Rule 45(d)(3)(B), the court may, instead of quashing or modifying a subpoena, order appearance or production under specified conditions if the serving party:\n\n(i) shows a substantial need for the testimony or material that cannot be otherwise met without undue hardship; and\n\n(ii) ensures that the subpoenaed person will be reasonably compensated.\n\n#### **(e) Duties in Responding to a Subpoena.**\n\n*(1) Producing Documents or Electronically Stored Information.* These procedures apply to producing documents or electronically stored information:\n\n*(A) Documents.* A person responding to a subpoena to produce documents must produce them as they are kept in the ordinary course of business or must organize and label them to correspond to the categories in the demand.\n\n*(B) Form for Producing Electronically Stored Information Not Specified.* If a subpoena does not specify a form for producing electronically stored information, the person responding must produce it in a form or forms in which it is ordinarily maintained or in a reasonably usable form or forms.\n\n*(C) Electronically Stored Information Produced in Only One Form.* The person responding need not produce the same electronically stored information in more than one form.\n\n*(D) Inaccessible Electronically Stored Information.* The person responding need not provide discovery of electronically stored information from sources that the person identifies as not reasonably accessible because of undue burden or cost. On motion to compel discovery or for a protective order, the person responding must show that the information is not reasonably accessible because of undue burden or cost. If that showing is made, the court may nonetheless order discovery from such sources if the requesting party shows good cause, considering the limitations of Rule 26(b)(2)(C). The court may specify conditions for the discovery.\n\n#### *(2) Claiming Privilege or Protection.*\n\n*(A) Information Withheld.* A person withholding subpoenaed information under a claim that it is privileged or subject to protection as trial-preparation material must: (i) expressly make the claim; and\n\n(ii) describe the nature of the withheld documents, communications, or tangible things in a manner that, without revealing information itself privileged or protected, will enable the parties to assess the claim.\n\n*(B) Information Produced.* If information produced in response to a subpoena is subject to a claim of privilege or of protection as trial-preparation material, the person making the claim may notify any party that received the information of the claim and the basis for it. After being notified, a party must promptly return, sequester, or destroy the specified information and any copies it has; must not use or disclose the information until the claim is resolved; must take reasonable steps to retrieve the information if the party disclosed it before being notified; and may promptly present the information under seal to the court for the district where compliance is required for a determination of the claim. The person who produced the information must preserve the information until the claim is resolved.\n\n**(g) Contempt.** The court for the district where compliance is required – and also, after a motion is transferred, the issuing court – may hold in contempt a person who, having been served, fails without adequate excuse to obey the subpoena or an order related to it.\n\nFor access to subpoena materials, see Fed.R.Civ.P.45(a) Committee Note (2013)\n\n…\n\n## **Request for Production of Documents**\n\n## **I. INSTRUCTIONS**\n\n1. Unless otherwise indicated, the requests for documents set forth below, (the \"Requests,\" and each, a \"Request\"), must be responded to separately and specifically. Each Request shall be answered fully unless it is in good faith objected to, in which event the reason for Your objection shall be stated in detail, as set forth below. If an objection pertains only to a portion of a Request, or a word, phrase or clause contained within it, You are required to state Your objection to that portion only and to respond to the remainder of the Requests.\n\n2. Electronically stored information must be produced in accordance with the\n\nfollowing instructions:\n\n- a. Images. Black and white images must be 300 DPI Group IV single-page TIFF files. Color images must be produced in JPEG format. File names cannot contain embedded spaces or special characters (including the comma). Folder names cannot contain embedded spaces or special characters (including the comma). All TIFF image files must have a unique file name, i.e. Bates number. Images must be endorsed with sequential Bates numbers in the lower right corner of each image. The number of TIFF files per folder should not exceed 1000 files. Excel spreadsheets should have a placeholder image named by the Bates number of the file.\n- b. Image Load File\n\t- a. Concordance® Data File. The data file (.DAT) contains all of the fielded information that will be loaded into the Concordance® database. The first line of the .DAT file must be a header row identifying the field names. The .DAT file must use the following Concordance® default delimiters: Comma ASCII character (020) Quote þ ASCII character (254). Date fields should be provided in the format: mm/dd/yyyy. Date and time fields must be two separate fields. If documents includes imaged emails and attachments, the attachment fields must be included to preserve the parent/child relationship between an email and its attachments. An OCRPATH field must be included to provide the file path and name of the extracted text file on the produced storage media. The text file must be named after the FIRSTBATES. Do not include the text in the .DAT file. For Documents with native files, a LINK field must be included to provide the file path and\n\nname of the native file. The native file must be named after the FIRSTBATES.\n\n- b. Concordance Image® OR Opticon Cross-Reference File. The image crossreference file (.LOG or .OPT) links the images to the database records. It should be a comma-delimited file consisting of seven fields per line with a line in the cross-reference file for every image in the database with the following format: ImageID,VolumeLabel,ImageFilePath,DocumentBreak,FolderBreak,Box Break,PageCoun.\n- c. Document Text. Text must be produced as separate text files, not as fields within the .DAT file. The full path to the text file (OCRPATH) should be included in the .DAT file. It is recommended document level ANSI text files, named per the FIRSTBATES/Image Key. Extracted text files must be in a separate folder, and the number of text files per folder should not exceed 1,000 files. There should be no special characters (including commas in the folder names). Text files must be provided on a document level.\n- d. Native Production for Certain File Types. File types that reasonably require viewing in their native format for a full understanding of their content and meaning must be produced in native format. These include, but are not limited to, spreadsheets, spreadsheet-like files (Microsoft Excel, comma separated values, tab separated values, etc.), Microsoft PowerPoint or other special presentation files, database files, and audio/visual files. Provide an image of a Bates numbered slip sheet indicating the presence of a native file, and include the path to the native as a field in the .dat file. Name the produced native file with the Bates number corresponding to the slip sheet for the file. Group native files within incrementally named \"NATIVE\" directories, separate from images directories.\n- e. De-duplication. Produce a single copy of each electronic document for which exact duplicates exist. For email messages, consolidate duplicates based on MD5 hash generated from the BCC, Body, CC, From, IntMsgID, To, and Attach properties. For email attachments and standalone electronic files, consolidate duplicates based on MD5 hash of the entire file.\n- f. Metadata. Produce extracted metadata for each document in the form of a Concordance compliant load file (.dat). The first line of the .DAT file must be a header row identifying the field names. The .DAT file must use the following Concordance default delimiters: Comma , ASCII character (020) Quote þ ASCII character (254)\n\nDate fields should be provided in the format: mm/dd/yyyy. Date and time fields must be two separate fields. Required metadata listed below:\n\n# Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 114 of 1063\n\n| Field Name   | Sample Data              | Description                                      |\n|--------------|--------------------------|--------------------------------------------------|\n| FIRSTBATES   | EDC0000001               | First Bates number of native file document/email |\n| LASTBATES    | EDC0000001               | Last Bates number of native file document/email  |\n|              |                          | **The LASTBATES field should be populated        |\n|              |                          | for single page                                  |\n| ATTACHRANGE  | EDC0000001<br>-          | Bates number of the first page of the parent     |\n|              | EDC0000015               | document to the Bates number of the last page of |\n|              |                          | the last attachment \"child\" document             |\n| BEGATTACH    | EDC0000001               | First Bates number of attachment range           |\n| ENDATTACH    | EDC0000015               | Last Bates number of attachment range            |\n| CUSTODIAN    | Smith, John              | Email: Mailbox where the email resided           |\n|              |                          | Native: Name of the individual or department     |\n|              |                          | from whose files the document<br>originated      |\n| FROM         | John Smith               | Email: Sender                                    |\n|              |                          | Native: Author(s) of document                    |\n|              |                          | **semi-colon should be used to separate          |\n|              |                          | multiple entries                                 |\n| TO           | Coffman, Janice; LeeW    | Recipient(s)                                     |\n|              | [mailto:LeeW@MSN.com]    | **semi-colon should be used to separate multiple |\n|              |                          | entries                                          |\n| CC           | Frank Thompson [mailto:  | Carbon copy recipient(s)                         |\n|              | frank_Thompson@cdt.com]  | **semi-colon should be used to separate          |\n|              |                          | multiple entries                                 |\n| BCC          | John Cain                | Blind carbon copy recipient(s)                   |\n|              |                          | **semi-colon should be used to separate          |\n|              |                          | multiple entries                                 |\n| SUBJECT      | Board Meeting Minutes    | Email: Subject line of the email Native: Title   |\n|              |                          | of document (if available)                       |\n| FILE_NAME    | BoardMeetingMinutes.docx | Native: Name of the original native file,        |\n|              |                          | including extension                              |\n| DATE_SENT    | 10/12/2010               | Email: Date the email was sent                   |\n|              |                          | Native: (empty)                                  |\n| TIME_SENT/   | 07:05 PM GMT             | Email: Time the email was sent/ Time zone in     |\n| TIME_ZONE    |                          | which the emails were standardized               |\n| TIME_ZONE    | GMT                      | The<br>time zone in which<br>the emails<br>were  |\n|              |                          | standardized during conversion.                  |\n| LINK         |  EDC0000001.msg   | Hyperlink to the email or native file document   |\n|              |                          | **The linked file must be named per the          |\n|              |                          | FIRSTBATES number                                |\n| FILE_EXTEN   | MSG                      | The file type extension                          |\n|              |                          | representing                                     |\n|              |                          | the Email or                                     |\n| AUTHOR       | John Smith               | Email: (empty)                                   |\n|              |                          | Native: Author of the document                   |\n| DATE_CREATED | 10/10/2010               | Email: (empty)                                   |\n|              |                          | Native: Date the document was created            |\n\n# Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 115 of 1063\n\n| TIME_CREATED | 10:25 AM                  | Email: (empty)                                  |\n|--------------|---------------------------|-------------------------------------------------|\n|              |                           | Native: Time the document was created           |\n|              |                           | **This data must be a separate field and cannot |\n|              |                           | be combined with the DATE_CREATED field         |\n| DATE_MOD     | 10/12/2010                | Email: (empty)                                  |\n|              |                           | Native: Date the document was last modified     |\n| TIME_MOD     | 07:00 PM                  | Email: (empty)                                  |\n|              |                           | Native: Time the document was last modified     |\n|              |                           | **This data must be a separate field and cannot |\n|              |                           | be combined with the DATE_MOD field             |\n| DATE_ACCESSD | 10/12/2010                | Email: (empty)                                  |\n|              |                           | Native: Date the document was last accessed     |\n| TIME_ACCESSD | 07:00 PM                  | Email: (empty)                                  |\n|              |                           | Native: Time the document was last accessed     |\n|              |                           | **This data must be a separate field and cannot |\n|              |                           | be combined with the DATE_ACCESSD field         |\n| FILE_SIZE    | 5,952                     | Size of native file<br>document/email in KB     |\n| PGCOUNT      | 1                         | Number of pages in native file document/email   |\n| PATH         |   | Email: (empty)                                  |\n|              | Agenda.doc                | Native: Path where native file document was     |\n|              |                           | stored including original file name.            |\n| INTFILEPATH  | Personal Folders\\Deleted  | Email: original location of email including     |\n|              | Items\\Board Meeting       | original file name.                             |\n|              | Minutes.msg               | Native: (empty)                                 |\n| INTMSGID     | <000805c2c71b\\$75977050\\$ | Email: Unique Message ID Native: (empty)        |\n|              | cb8306d1@MSN>             |                                                 |\n| MD5HASH      | d131dd02c5e6eec4693d9a0   | MD5 Hash value of the document.                 |\n|              | 698aff95c                 |                                                 |\n|              | 2fcab58712467eab4004583e  |                                                 |\n|              | b8fb7f89                  |                                                 |\n| OCRPATH      | TEXT/001/EDC0000001.txt   | Path to extracted text of the native file       |\n\n3. Each Request operates and should be construed independently and, unless otherwise indicated, no Request limits the scope of any other Request.\n\n4. All Documents are to be produced as kept in the usual course of business or are to be organized and labeled to correspond with the categories in these Requests.\n\n5. Each Request contained herein extends to all Documents: (a) in Your possession, custody, or control; or (b) in the possession, custody, or control of anyone acting on Your behalf,\n\n#### Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 116 of 1063\n\nincluding Your counsel or other representatives and advisors. Each Document shall be produced in its entirety.\n\n6. If You are requested to produce a Document that is no longer in Your possession, custody, or control, then Your response must (a) describe in detail the nature of the document and its contents; (b) identify the person(s) who prepared or authored the Document (and, if applicable, the Person(s) to whom the Document was sent); (c) identify the date on which the document was prepared or created; (d) state whether such Document (i) is missing or lost, (ii) has been destroyed, (iii) has been transferred, voluntarily or involuntarily, to others, or (iv) was otherwise disposed of; (e) state the reason for, and the facts and circumstances surrounding, such disposition; (f) identify the Persons who authorized such disposition; (g) identify the date or approximate date of such disposition; (h) state when the Document was most recently in Your possession, custody or control; and (i) identify the Person, if any, presently in possession, custody, or control of such Document.\n\n7. If You are requested to produce a Document that has been destroyed, then Your response must state, in addition to the information required by the preceding Instruction: (a) the reason for the Document's destruction; (b) the identity of the Person who destroyed the Document; and (c) the identity of the Person who directed that the Document be destroyed.\n\n8. If You claim that a requested Document is privileged or attorney work-product, then Your response must: (a) state (i) a description of the Document adequate to support Your contention that the Document is privileged, (ii) the title of the Document, (iii) the date of the Document, (iv) the author of the Document, (v) the addressee of the Document, (vi) the identity of each Person who received or saw the original or any draft, copy, or reproduction of the Document, (vii) whether the Document itself, or any information contained or referred to in the Document is in the possession, custody, or control of any other Persons, and if so, the identity of\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 117 of 1063\n\nsuch Persons, as well as a statement addressing how the information came into their possession, (viii) the claim of privilege under which the Document is withheld, and (ix) all of the circumstances upon which You will rely to support such claim of privilege; and (b) produce a privilege log containing all of the information requested in Part (a) of this Instruction for each Document withheld on the basis of a claim of privilege in accordance with D. Conn. L. Civ. R. 26(e). For any part of a Document Request as to which a claim of privilege or work product is not made, responsive documents should be provided in full.\n\n9. If a portion of an otherwise responsive Document contains information subject to a claim of privilege, only that portion of the Document subject to the claim of privilege shall be deleted or redacted from the Document following the instructions above, and the rest shall be produced.\n\n10. The Requests are continuing in nature. You are hereby instructed to (a) supplement or correct any responses later learned to be incomplete or incorrect immediately upon learning that a prior response was incomplete or incorrect; and (b) produce any additional Documents that are called for under the\n\n11. If a Document is in a language other than English, You should provide that Document. If a Document is in a language other than English, and an English translation exists, You should provide both Documents.\n\n12. All references to Entities includes all affiliates thereof.\n\n13. All references to individual names include all alternative names, aliased, or nicknames.\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 118 of 1063\n\n14. Unless otherwise expressly indicated, the period of time covered by the Document Requests is the period from February 5, 2015 to the date responses to the Document Requests are due.\n\n#### **II. RULES OF CONSTRUCTION**\n\n15. The use of (a) any singular noun shall be construed to include the plural, and vice versa, and (b) a verb in any tense shall be construed as the use of the verb in all other tenses.\n\n16. The terms (a) \"and\" and \"or\" shall be construed either conjunctively or disjunctively as necessary to bring within the scope of any request all responses that might otherwise be construed to be outside of its scope, and (b) \"each\" and \"any\" shall be deemed to include and encompass the words \"every\" and \"all.\"\n\n#### **III. DEFINITIONS**\n\nThe definitions supplied by D. Conn. L. Civ. R. 26(c) and the rules of construction supplied by D. Conn. L. Civ. R. 26(d), as incorporated by D. Conn. Bankr. L.R. 2004-1(a), shall apply to the Document Requests. In addition, the following terms used in these Document Requests shall have the following meanings:\n\n1. \"You\" or \"Your\" or \"Yourself\" means and refers to Emile P de Neree, together with any of their employees, agents, counsel, advisors, or anyone acting on their behalf.\n\n2. \"Debtor\" means Ho Wan Kwok (a/k/a Miles Kwok, Miles Guo, Guo Wengui, Guo Haoyun, 郭文贵, or any other alias), together with his employees, agents, counsel, advisors, or anyone acting on his behalf.\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 119 of 1063\n\n3. \"Debtor's Son\" means Qiang Guo (a/k/a Mileson Kwok, 郭强, or any other alias), together with his employees, agents, counsel, advisors, or anyone acting on his behalf.\n\n4. \"Debtor's Daughter\" means Mei Guo (a/k/a Mei Gui, 郭美, or any other alias), together with her employees, agents, counsel, advisors, or anyone acting on her behalf.\n\n5. \"Debtor's Purported Wife\" means Hing Chi Ngok (a/k/a Hing Chi Ng, Yue Qingzhi, 岳庆芝, or any other alias), together with her employees, agents, counsel, advisors, or anyone acting on her behalf.\n\n6. \"Debtor's Family\" means, collectively, the Debtor, the Debtor's Son, the Debtor's Daughter, and the Debtor's Purported Wife, and any other familial relation to the Debtor.\n\n7. \"Associated Individuals\" means, individually and collectively, all individuals that (1) hold, control, have custody over, or discretion over assets owned, controlled, or enjoyed by the Debtor or the Debtor's Family; or (2) have been employees, directors, or otherwise are affiliated with one or more Associated Entities, together with the respective employees, agents, counsel, advisors, or anyone acting on behalf of any of the foregoing. Such Associated Individuals shall include, but are not limited to: Daniel Podhaskie, Karin Maistrello, Melissa Francis, Anthony DiBattista, Han Chunguang (a/k/a 韩春光), Qu Guojiao (a/k/a Qu Guo Jiao, 屈国姣), Zhang Wei (a/k/a 张伟\\*), Lihong Wei Lafrenz (a/k/a Sara Wei, 魏丽红Max Krasner, Yvette Wang (a/k/a Yanping Wang, Yan Ping Wang, 王雁平), Fiona Yu, and Je Kin Ming (a/k/a William Je, Yu Jianming, 余建明).\n\n8. \"Associated Entities\" means, individually and collectively, all organizations or Entities of any type that (1) have been owned, controlled, or invested in by the Debtor or the Debtor's Family; or (2) have an interest, whether directly or indirectly, in any assets owned,\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 120 of 1063\n\ncontrolled, or enjoyed by the Debtor or the Debtor's Family, together with the respective employees, agents, counsel, advisors, or anyone acting on behalf of any of the foregoing. Such Associated Entities shall include, but are not limited to: 7 Nod Hill LLC, ACA Investment Management Limited, ACA Capital Group Limited, Ace Decade Holdings Limited, AI Group Holdings Inc., Booming Sail New York LLC, Bravo Luck Limited, China Golden Spring (Hong Kong) Limited, Crane Advisory Group LLC, Dawn State Limited, Eastern Profit Corporation Limited, Freedom Media Ventures Ltd., G Club Operations LLC, G Fashion LLC, G News LLC, GETTR USA, Genever Holdings Corporation, Genever Holdings LLC, Gfashion Media Group Inc., GFNY, Inc., Golden Spring (New York) Ltd., Greenwich Land LLC, GTV Media Group, Inc., Hamilton Capital Holdings Inc., HCHK Property Management, Inc., HCHK Technologies, Inc., Himalaya Embassy, Himalaya Exchange, Himalaya Federal Reserve, Himalaya Investment LLC, Himalaya International, Himalaya New World Inc., Himalaya Supervisory Organization, Himalaya Ventures LLC, HK International Funds Investments (USA) Limited LLC, Hong Kong International Funds Investments Limited, Hudson Diamond Holding, Infinity Treasury Management Inc., Lexington Property and Staffing, Long Gate Limited, Maywind Trading LLC, MOS Himalaya LLC, New Federal State of China (a/k/a NFSC), Rule of Law Foundation III, Inc., Rule of Law Foundation IV, Inc., Rule of Law Fund, Rule of Law Society, Rule of Law Society IV, Inc., G-Translators PTY LTD, Saraca Media Group, Inc., Well Origin Ltd., Whitecroft Shore Limited, and ZIBA Limited.\n\n9. \"Including\" or any variant thereof means \"including without limitation.\"\n\n10. \"And\" and \"or\" mean \"and/or,\" and shall be construed both conjunctively as well as disjunctively in order to maximize their scope.\n\n11. \"Any\" and \"all\" and \"each\" mean \"each and every.\"\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 121 of 1063\n\n12. \"Each\" and \"every\" mean \"each and every.\"\n\n13. \"Third Party\" means a Person or Entity other than Yourself.\n\n14. \"Transfer\" shall have the meaning given to it by section 101(54) of the Bankruptcy Code.\n\n15. \"Document\" means any information or thing within the scope of Fed. R. Civ. P. 34, and includes, without limitation, each and every written, recorded, or graphic matter of any kind, type, nature, or description that is or has been in Your possession, custody or control, including all printed and electronic copies of electronic mail, computer files maintained in electronic form, correspondence, memoranda, tapes, stenographic or handwritten notes, written forms of any kind, charts, blueprints, drawings, sketches, graphs, plans, articles, specifications, diaries, letters, telegrams, photographs, minutes, contracts, agreements, surveys, computer printouts, data compilations of any kind, telexes, facsimiles, emails, text messages, instant messages, voice messages, invoices, order forms, checks, drafts, statements, credit memos, reports, position reports, summaries, indices, books, ledgers, notebooks, schedules, transparencies, recordings, catalogs, advertisements, promotional materials, films, video tapes, audio tapes, CDs, computer disks, brochures, pamphlets, punch-cards, time-slips, Tweets, social media posts, or any written or recorded materials of any other kind, and all meta-data thereof, however stored (whether in tangible or electronic form), recorded, produced, or reproduced, and also including but not limited to, drafts or copies of any of the foregoing that contain any notes, comments, or markings of any kind not found on the original documents or that are otherwise not identical to the original documents.\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 122 of 1063\n\n16. \"Person(s)\" means an individual, corporation, proprietorship, partnership, association, or any other Entity. \"Person\" also includes any agent, representatives, or expert, including but not limiting to, attorneys or financial advisors.\n\n17. \"Entity\" means any natural Person, corporation, partnership, subsidiary, sole proprietorship, firm, board, joint venture, association, agency, authority, commission or other business entity or juristic Person, as well as any affiliate, agent, parent including but not limited to counsel, financial advisors, or any other representative.\n\n18. \"Regarding\" means concerning, describing, comprising, referring to, related to, supporting, favoring, opposing, bolstering, detracting from, located in, considered in connection with, bearing on, evidencing, indicating, reporting on, recording, alluding to, responding to, connected with, commenting on, in respect of, about, in relation to, discussing, showing, describing, reflecting, analyzing constituting, and being.\n\n19. \"Relating to,\" \"relate(s) to\" or \"related to,\" when referring to any given subject matter, means, without limitation, any document that constitutes, comprises, involves, contains, embodies, reflects, identifies, states, refers directly or indirectly to, or is in any way relevant to the particular subject matter identified.\n\n20. \"Communication(s)\" means, in the broadest possible sense, and without limitation, any transmittal of information or knowledge (in the form of facts, ideas, inquiries, or otherwise). Communication(s) further refers to all conversations, agreements, inquiries, or replies, whether in person, by telephone, in writing, or by means of electronic transmittal devices, and includes, but is not limited to, all correspondence, emails, recordings, transmittal slips, memoranda, telephone communications, voice messages, telegrams, telefaxes, telecopies, telexes, instant messages, chats, text messages, postings to a message board or group chat, social media posts, tweets, videos\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 123 of 1063\n\nuploaded to any video platform, telephonic notes, or notes transmitted internally or with third parties.\n\n21. \"Asset(s)\" means any item of economic value that is subject to possession, custody, or control. Asset includes all real and personal property, including but limited to, real estate, land, houses, apartments, condominiums, automobiles, yachts, boats, planes, jets, helicopters, cash, bank accounts, cryptocurrencies, securities, accounts receivables, inventory, and other tangible and intangible property.\n\n#### **IV. DOCUMENTS TO BE PRODUCED**\n\n1. All Documents and communications regarding the Sherry Netherland Hotel / Condominium, located at 781 Fifth Avenue, New York, NY 10022 (apartments 1801 and 1519; the residential property located at 373 Taconic Rd., Greenwich, Connecticut 06831; the residential property located at 33 Ferncliff Rd., Cos Cob, Connecticut 06807; the residential property located at 354 Nod Hill Rd., Wilton, Connecticut 06897; the property located in at 32 Chateau Ridge Rd., Greenwich, Connecticut 06831; the property located at 110 Clapboard Ridge Rd., Greenwich, Connecticut 06830; the property located at 66 Sherwood Avenue, Greenwich, Connecticut 06831; the property located at 140 Wallacks Drive, Stamford, Connecticut 06902; the property located at 602 Indian Field Drive, Greenwich, Connecticut 06830; and the property located at 11 Hurlingham Drive, Greenwich, Connecticut 06831.\n\n2. All Documents or communications related to any income or Asset of the Debtor, the Debtor's estate, the Debtor's Family, or Associated Entity, including without limitation any real property located in Connecticut.\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 124 of 1063\n\n3. All Documents or communications related to any engagement letter with the Debtor, any member of the Debtor's Family, and/or any Associated Entity, including copy(ies) of such engagement letter(s).\n\n4. All Documents or communications related to the payment of any retainer or commission to You based upon your representation of the Debtor, the Debtor's Family, or an Associated Entity, including documents sufficient to identify the amount of the retainer or commission and its source.\n\n5. All Documents or communications related to any fees, payments, or monies received by You from or on behalf of the Debtor, the Debtor's Family, a Family Related Entity, or an Associated Entity held in escrow or in a client trust account.\n\n6. Documents sufficient to show the amount, date, and source of any payments made to You by, on behalf of, or for the benefit of the Debtor, the Debtor's Family, or an Associated Entity.\n\n7. All Communications between You and, either, the Debtor, the Debtor's Family, or any Associated Individual, agent, employee, or other individual acting on behalf of the Debtor, related to any Transfer, investment, or other transaction or business dealing relating to the Debtor, the Debtor's Estate, the Debtor's Family, or the Associated Entities.\n\n8. All Documents and communications related to any sale, potential sale, acquisition, disposition, purchase, potential purchase, investment, contribution, gift, extension of credit, loan, or Transfer involving the Debtor, the Debtor's Family, or any Associated Entity.\n\n9. All Documents and communications related to the Debtor's use of any Assets belonging to, controlled by, or whose complete or partial ownership is held by the Debtor's Family,\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 125 of 1063\n\nan Associated Entity, or an Associated Individual, including without limitation any real property located in Connecticut.\n\n10. All Documents and communications regarding any balance sheet, bank statement, account statement, financial statement, statement of account, wire transfer instructions and/or confirmation, proof of funds, certificate of deposit, certificate of holdings, investment portfolio summary, or similar document relating to the Debtor, the Debtor's Estate, the Debtor's Family, an Associated Entity, or an Associated Individual, including without limitation all Documents sufficient to show all Transfers to any of the foregoing.\n\nCase 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 126 of 1063\n\n# Exhibit C-6\n\n#### B2540 (Form 2540 – Subpoena for Rule 2004 Examination) (12/15) Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 127 of\n\nUNITED STATES BANKRUPTCY COURT 1063\n\n**District of Connecticut**\n\nIn re HO WAN KWOK, *et al*.,\n\n<sup>1</sup> Case No. 22-50073 (JAM)\n\nDebtor Chapter 11\n\n(Jointly Administered)\n\n## **SUBPOENA FOR RULE 2004 EXAMINATION**\n\nTo: **Zhizhe \"Frank\" Dong**\n\n(*Name of person to whom the subpoena is directed*)\n\n*Testimony:* **YOU ARE COMMANDED** to appear at the time, date, and place set forth below to testify at an examination under Rule 2004, Federal Rules of Bankruptcy Procedure. A copy of the court order authorizing the examination is attached.\n\n| PLACE                    | DATE AND TIME |\n|--------------------------|---------------|\n| Paul Hastings LLP        |               |\n| 200 Park Avenue          | [TBD]         |\n| New York, New York 10166 |               |\n|                          |               |\n\nThe examination will be recorded by this method: **Court reporter/stenographer**\n\n*Production:* You, or your representatives, must also bring with you to the examination the following documents, electronically stored information, or objects, and must permit inspection, copying, testing, or sampling of the material:\n\n#### **See Requests for Production of Documents, attached hereto.**\n\nThe following provisions of Fed. R. Civ. P. 45, made applicable in bankruptcy cases by Fed. R. Bankr. P. 9016, are attached – Rule 45(c), relating to the place of compliance; Rule 45(d), relating to your protection as a person subject to a subpoena; and Rule 45(e) and 45(g), relating to your duty to respond to this subpoena and the potential consequences of not doing so.\n\nDate: **March , 2023**\n\nCLERK OF COURT\n\nOR\n\n*Signature of Clerk or Deputy Clerk Attorney's signature*\n\nThe name, address, email address, and telephone number of the attorney representing Luc A. Despins, Chapter 11 Trustee, who issues or requests this subpoena, are:\n\n**Douglas S. Skalka, Esq.; Neubert, Pepe & Monteith, P.C.; 195 Church Street, New Haven, Connecticut 06510 dskalka@npmlaw.com; (203) 821-2000**\n\n**Notice to the person who issues or requests this subpoena**\n\nIf this subpoena commands the production of documents, electronically stored information, or tangible things, or the inspection of premises before trial, a notice and a copy of this subpoena must be served on each party before it is served on the person to whom it is directed. Fed. R. Civ. P. 45(a)(4).\n\nSoftware Copyright (c) 1996-2022 Best Case, LLC - www.bestcase.com Best Case Bankruptcy 1 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\n#### **PROOF OF SERVICE**\n\n**(This section should not be filed with the court unless required by Fed. R. Civ. P. 45.)**\n\nI received this subpoena for (*name of individual and title, if any*): on (*date*) .\n\nI served the subpoena by delivering a copy to the named person as follows:\n\non *(date)* ; or\n\nI returned the subpoena unexecuted because:\n\nUnless the subpoena was issued on behalf of the United States, or one of its officers or agents, I have also tendered to the witness the fees for one day's attendance, and the mileage allowed by law, in the amount of \\$ .\n\nMy fees are \\$ for travel and \\$ for services, for a total of \\$ .\n\nI declare under penalty of perjury that this information is true and correct.\n\nDate:\n\n*Server's signature*\n\n*Printed name and title*\n\n*Server's address*\n\nAdditional information concerning attempted service, etc.:\n\n#### **Federal Rule of Civil Procedure 45(c), (d), (e), and (g) (Effective 12/1/13) (made applicable in bankruptcy cases by Rule 9016, Federal Rules of Bankruptcy Procedure)**\n\n#### **(c) Place of compliance.**\n\n*(1) For a Trial, Hearing, or Deposition.* A subpoena may command a person to attend a trial, hearing, or deposition only as follows:\n\n(A) within 100 miles of where the person resides, is employed, or regularly transacts business in person; or\n\n(B) within the state where the person resides, is employed, or regularly transacts business in person, if the person\n\n(i) is a party or a party's officer; or\n\n(ii) is commanded to attend a trial and would not incur substantial expense.\n\n*(2) For Other Discovery.* A subpoena may command:\n\n(A) production of documents, or electronically stored information, or things at a place within 100 miles of where the person resides, is employed, or regularly transacts business in person; and\n\n(B) inspection of premises, at the premises to be inspected.\n\n#### **(d) Protecting a Person Subject to a Subpoena; Enforcement.**\n\n*(1) Avoiding Undue Burden or Expense; Sanctions.* A party or attorney responsible for issuing and serving a subpoena must take reasonable steps to avoid imposing undue burden or expense on a person subject to the subpoena. The court for the district where compliance is required must enforce this duty and impose an appropriate sanction which may include lost earnings and reasonable attorney's fees — on a party or attorney who fails to comply.\n\n#### *(2) Command to Produce Materials or Permit Inspection.*\n\n*(A) Appearance Not Required.* A person commanded to produce documents, electronically stored information, or tangible things, or to permit the inspection of premises, need not appear in person at the place of production or inspection unless also commanded to appear for a deposition, hearing, or trial.\n\n*(B) Objections.* A person commanded to produce documents or tangible things or to permit inspection may serve on the party or attorney designated in the subpoena a written objection to inspecting, copying, testing or sampling any or all of the materials or to inspecting the premises — or to producing electronically stored information in the form or forms requested. The objection must be served before the earlier of the time specified for compliance or 14 days after the subpoena is served. If an objection is made, the following rules apply:\n\n(i) At any time, on notice to the commanded person, the serving party may move the court for the district where compliance is required for an order compelling production or inspection.\n\n(ii) These acts may be required only as directed in the order, and the order must protect a person who is neither a party nor a party's officer from significant expense resulting from compliance.\n\n#### *(3) Quashing or Modifying a Subpoena.*\n\n*(A) When Required.* On timely motion, the court for the district where compliance is required must quash or modify a subpoena that:\n\n(i) fails to allow a reasonable time to comply;\n\n(ii) requires a person to comply beyond the geographical limits specified in Rule 45(c);\n\n(iii) requires disclosure of privileged or other protected matter, if no exception or waiver applies; or\n\n(iv) subjects a person to undue burden.\n\n*(B) When Permitted.* To protect a person subject to or affected by a subpoena, the court for the district where compliance is required may, on motion, quash or modify the subpoena if it requires:\n\n(i) disclosing a trade secret or other confidential research, development, or commercial information; or\n\n(ii) disclosing an unretained expert's opinion or information that does not describe specific occurrences in dispute and results from the expert's study that was not requested by a party.\n\n(C) *Specifying Conditions as an Alternative.* In the circumstances described in Rule 45(d)(3)(B), the court may, instead of quashing or modifying a subpoena, order appearance or production under specified conditions if the serving party:\n\n(i) shows a substantial need for the testimony or material that cannot be otherwise met without undue hardship; and\n\n(ii) ensures that the subpoenaed person will be reasonably compensated.\n\n#### **(e) Duties in Responding to a Subpoena.**\n\n*(1) Producing Documents or Electronically Stored Information.* These procedures apply to producing documents or electronically stored information:\n\n*(A) Documents.* A person responding to a subpoena to produce documents must produce them as they are kept in the ordinary course of business or must organize and label them to correspond to the categories in the demand.\n\n*(B) Form for Producing Electronically Stored Information Not Specified.* If a subpoena does not specify a form for producing electronically stored information, the person responding must produce it in a form or forms in which it is ordinarily maintained or in a reasonably usable form or forms.\n\n*(C) Electronically Stored Information Produced in Only One Form.* The person responding need not produce the same electronically stored information in more than one form.\n\n*(D) Inaccessible Electronically Stored Information.* The person responding need not provide discovery of electronically stored information from sources that the person identifies as not reasonably accessible because of undue burden or cost. On motion to compel discovery or for a protective order, the person responding must show that the information is not reasonably accessible because of undue burden or cost. If that showing is made, the court may nonetheless order discovery from such sources if the requesting party shows good cause, considering the limitations of Rule 26(b)(2)(C). The court may specify conditions for the discovery.\n\n#### *(2) Claiming Privilege or Protection.*\n\n*(A) Information Withheld.* A person withholding subpoenaed information under a claim that it is privileged or subject to protection as trial-preparation material must: (i) expressly make the claim; and\n\n(ii) describe the nature of the withheld documents, communications, or tangible things in a manner that, without revealing information itself privileged or protected, will enable the parties to assess the claim.\n\n*(B) Information Produced.* If information produced in response to a subpoena is subject to a claim of privilege or of protection as trial-preparation material, the person making the claim may notify any party that received the information of the claim and the basis for it. After being notified, a party must promptly return, sequester, or destroy the specified information and any copies it has; must not use or disclose the information until the claim is resolved; must take reasonable steps to retrieve the information if the party disclosed it before being notified; and may promptly present the information under seal to the court for the district where compliance is required for a determination of the claim. The person who produced the information must preserve the information until the claim is resolved.\n\n**(g) Contempt.** The court for the district where compliance is required – and also, after a motion is transferred, the issuing court – may hold in contempt a person who, having been served, fails without adequate excuse to obey the subpoena or an order related to it.\n\nFor access to subpoena materials, see Fed.R.Civ.P.45(a) Committee Note (2013)\n\n…\n\n## **Request for Production of Documents**\n\n## **I. INSTRUCTIONS**\n\n1. Unless otherwise indicated, the requests for documents set forth below, (the \"Requests,\" and each, a \"Request\"), must be responded to separately and specifically. Each Request shall be answered fully unless it is in good faith objected to, in which event the reason for Your objection shall be stated in detail, as set forth below. If an objection pertains only to a portion of a Request, or a word, phrase or clause contained within it, You are required to state Your objection to that portion only and to respond to the remainder of the Requests.\n\n2. Electronically stored information must be produced in accordance with the\n\nfollowing instructions:\n\n- a. Images. Black and white images must be 300 DPI Group IV single-page TIFF files. Color images must be produced in JPEG format. File names cannot contain embedded spaces or special characters (including the comma). Folder names cannot contain embedded spaces or special characters (including the comma). All TIFF image files must have a unique file name, i.e. Bates number. Images must be endorsed with sequential Bates numbers in the lower right corner of each image. The number of TIFF files per folder should not exceed 1000 files. Excel spreadsheets should have a placeholder image named by the Bates number of the file.\n- b. Image Load File\n\t- a. Concordance® Data File. The data file (.DAT) contains all of the fielded information that will be loaded into the Concordance® database. The first line of the .DAT file must be a header row identifying the field names. The .DAT file must use the following Concordance® default delimiters: Comma ASCII character (020) Quote þ ASCII character (254). Date fields should be provided in the format: mm/dd/yyyy. Date and time fields must be two separate fields. If documents includes imaged emails and attachments, the attachment fields must be included to preserve the parent/child relationship between an email and its attachments. An OCRPATH field must be included to provide the file path and name of the extracted text file on the produced storage media. The text file must be named after the FIRSTBATES. Do not include the text in the .DAT file. For Documents with native files, a LINK field must be included to provide the file path and\n\nname of the native file. The native file must be named after the FIRSTBATES.\n\n- b. Concordance Image® OR Opticon Cross-Reference File. The image crossreference file (.LOG or .OPT) links the images to the database records. It should be a comma-delimited file consisting of seven fields per line with a line in the cross-reference file for every image in the database with the following format: ImageID,VolumeLabel,ImageFilePath,DocumentBreak,FolderBreak,Box Break,PageCoun.\n- c. Document Text. Text must be produced as separate text files, not as fields within the .DAT file. The full path to the text file (OCRPATH) should be included in the .DAT file. It is recommended document level ANSI text files, named per the FIRSTBATES/Image Key. Extracted text files must be in a separate folder, and the number of text files per folder should not exceed 1,000 files. There should be no special characters (including commas in the folder names). Text files must be provided on a document level.\n- d. Native Production for Certain File Types. File types that reasonably require viewing in their native format for a full understanding of their content and meaning must be produced in native format. These include, but are not limited to, spreadsheets, spreadsheet-like files (Microsoft Excel, comma separated values, tab separated values, etc.), Microsoft PowerPoint or other special presentation files, database files, and audio/visual files. Provide an image of a Bates numbered slip sheet indicating the presence of a native file, and include the path to the native as a field in the .dat file. Name the produced native file with the Bates number corresponding to the slip sheet for the file. Group native files within incrementally named \"NATIVE\" directories, separate from images directories.\n- e. De-duplication. Produce a single copy of each electronic document for which exact duplicates exist. For email messages, consolidate duplicates based on MD5 hash generated from the BCC, Body, CC, From, IntMsgID, To, and Attach properties. For email attachments and standalone electronic files, consolidate duplicates based on MD5 hash of the entire file.\n- f. Metadata. Produce extracted metadata for each document in the form of a Concordance compliant load file (.dat). The first line of the .DAT file must be a header row identifying the field names. The .DAT file must use the following Concordance default delimiters: Comma , ASCII character (020) Quote þ ASCII character (254)\n\nDate fields should be provided in the format: mm/dd/yyyy. Date and time fields must be two separate fields. Required metadata listed below:\n\n# Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 132 of 1063\n\n| Field Name   | Sample Data              | Description                                                                                  |\n|--------------|--------------------------|----------------------------------------------------------------------------------------------|\n| FIRSTBATES   | EDC0000001               | First Bates number of native file document/email                                             |\n| LASTBATES    | EDC0000001               | Last Bates number of native file document/email<br>**The LASTBATES field should be populated |\n|              |                          | for single page                                                                              |\n| ATTACHRANGE  | EDC0000001<br>-          | Bates number of the first page of the parent                                                 |\n|              | EDC0000015               | document to the Bates number of the last page of                                             |\n|              |                          | the last attachment \"child\" document                                                         |\n| BEGATTACH    | EDC0000001               | First Bates number of attachment range                                                       |\n| ENDATTACH    | EDC0000015               | Last Bates number of attachment range                                                        |\n| CUSTODIAN    | Smith, John              | Email: Mailbox where the email resided                                                       |\n|              |                          | Native: Name of the individual or department                                                 |\n|              |                          | from whose files the document<br>originated                                                  |\n| FROM         | John Smith               | Email: Sender                                                                                |\n|              |                          | Native: Author(s) of document                                                                |\n|              |                          | **semi-colon should be used to separate                                                      |\n|              |                          | multiple entries                                                                             |\n| TO           | Coffman, Janice; LeeW    | Recipient(s)                                                                                 |\n|              | [mailto:LeeW@MSN.com]    | **semi-colon should be used to separate multiple                                             |\n|              |                          | entries                                                                                      |\n| CC           | Frank Thompson [mailto:  | Carbon copy recipient(s)                                                                     |\n|              | frank_Thompson@cdt.com]  | **semi-colon should be used to separate                                                      |\n|              |                          | multiple entries                                                                             |\n| BCC          | John Cain                | Blind carbon copy recipient(s)                                                               |\n|              |                          | **semi-colon should be used to separate                                                      |\n|              |                          | multiple entries                                                                             |\n| SUBJECT      | Board Meeting Minutes    | Email: Subject line of the email Native: Title                                               |\n|              |                          | of document (if available)                                                                   |\n| FILE_NAME    | BoardMeetingMinutes.docx | Native: Name of the original native file,                                                    |\n|              |                          | including extension                                                                          |\n| DATE_SENT    | 10/12/2010               | Email: Date the email was sent                                                               |\n|              |                          | Native: (empty)                                                                              |\n| TIME_SENT/   | 07:05 PM GMT             | Email: Time the email was sent/ Time zone in                                                 |\n| TIME_ZONE    |                          | which the emails were standardized                                                           |\n| TIME_ZONE    | GMT                      | The<br>time zone in which<br>the emails<br>were                                              |\n|              |                          | standardized during conversion.                                                              |\n| LINK         |  EDC0000001.msg   | Hyperlink to the email or native file document                                               |\n|              |                          | **The linked file must be named per the                                                      |\n|              |                          | FIRSTBATES number                                                                            |\n| FILE_EXTEN   | MSG                      | The file type extension                                                                      |\n|              |                          | representing                                                                                 |\n|              |                          | the Email or                                                                                 |\n| AUTHOR       | John Smith               | Email: (empty)                                                                               |\n|              |                          | Native: Author of the document                                                               |\n| DATE_CREATED | 10/10/2010               | Email: (empty)                                                                               |\n|              |                          | Native: Date the document was created                                                        |\n\n# Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 133 of 1063\n\n| TIME_CREATED | 10:25 AM                  | Email: (empty)                                  |\n|--------------|---------------------------|-------------------------------------------------|\n|              |                           | Native: Time the document was created           |\n|              |                           | **This data must be a separate field and cannot |\n|              |                           | be combined with the DATE_CREATED field         |\n| DATE_MOD     | 10/12/2010                | Email: (empty)                                  |\n|              |                           | Native: Date the document was last modified     |\n| TIME_MOD     | 07:00 PM                  | Email: (empty)                                  |\n|              |                           | Native: Time the document was last modified     |\n|              |                           | **This data must be a separate field and cannot |\n|              |                           | be combined with the DATE_MOD field             |\n| DATE_ACCESSD | 10/12/2010                | Email: (empty)                                  |\n|              |                           | Native: Date the document was last accessed     |\n| TIME_ACCESSD | 07:00 PM                  | Email: (empty)                                  |\n|              |                           | Native: Time the document was last accessed     |\n|              |                           | **This data must be a separate field and cannot |\n|              |                           | be combined with the DATE_ACCESSD field         |\n| FILE_SIZE    | 5,952                     | Size of native file<br>document/email in KB     |\n| PGCOUNT      | 1                         | Number of pages in native file document/email   |\n| PATH         |   | Email: (empty)                                  |\n|              | Agenda.doc                | Native: Path where native file document was     |\n|              |                           | stored including original file name.            |\n| INTFILEPATH  | Personal Folders\\Deleted  | Email: original location of email including     |\n|              | Items\\Board Meeting       | original file name.                             |\n|              | Minutes.msg               | Native: (empty)                                 |\n| INTMSGID     | <000805c2c71b\\$75977050\\$ | Email: Unique Message ID Native: (empty)        |\n|              | cb8306d1@MSN>             |                                                 |\n| MD5HASH      | d131dd02c5e6eec4693d9a0   | MD5 Hash value of the document.                 |\n|              | 698aff95c                 |                                                 |\n|              | 2fcab58712467eab4004583e  |                                                 |\n|              | b8fb7f89                  |                                                 |\n| OCRPATH      | TEXT/001/EDC0000001.txt   | Path to extracted text of the native file       |\n\n3. Each Request operates and should be construed independently and, unless otherwise indicated, no Request limits the scope of any other Request.\n\n4. All Documents are to be produced as kept in the usual course of business or are to be organized and labeled to correspond with the categories in these Requests.\n\n5. Each Request contained herein extends to all Documents: (a) in Your possession, custody, or control; or (b) in the possession, custody, or control of anyone acting on Your behalf,\n\n#### Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 134 of 1063\n\nincluding Your counsel or other representatives and advisors. Each Document shall be produced in its entirety.\n\n6. If You are requested to produce a Document that is no longer in Your possession, custody, or control, then Your response must (a) describe in detail the nature of the document and its contents; (b) identify the person(s) who prepared or authored the Document (and, if applicable, the Person(s) to whom the Document was sent); (c) identify the date on which the document was prepared or created; (d) state whether such Document (i) is missing or lost, (ii) has been destroyed, (iii) has been transferred, voluntarily or involuntarily, to others, or (iv) was otherwise disposed of; (e) state the reason for, and the facts and circumstances surrounding, such disposition; (f) identify the Persons who authorized such disposition; (g) identify the date or approximate date of such disposition; (h) state when the Document was most recently in Your possession, custody or control; and (i) identify the Person, if any, presently in possession, custody, or control of such Document.\n\n7. If You are requested to produce a Document that has been destroyed, then Your response must state, in addition to the information required by the preceding Instruction: (a) the reason for the Document's destruction; (b) the identity of the Person who destroyed the Document; and (c) the identity of the Person who directed that the Document be destroyed.\n\n8. If You claim that a requested Document is privileged or attorney work-product, then Your response must: (a) state (i) a description of the Document adequate to support Your contention that the Document is privileged, (ii) the title of the Document, (iii) the date of the Document, (iv) the author of the Document, (v) the addressee of the Document, (vi) the identity of each Person who received or saw the original or any draft, copy, or reproduction of the Document, (vii) whether the Document itself, or any information contained or referred to in the Document is in the possession, custody, or control of any other Persons, and if so, the identity of\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 135 of 1063\n\nsuch Persons, as well as a statement addressing how the information came into their possession, (viii) the claim of privilege under which the Document is withheld, and (ix) all of the circumstances upon which You will rely to support such claim of privilege; and (b) produce a privilege log containing all of the information requested in Part (a) of this Instruction for each Document withheld on the basis of a claim of privilege in accordance with D. Conn. L. Civ. R. 26(e). For any part of a Document Request as to which a claim of privilege or work product is not made, responsive documents should be provided in full.\n\n9. If a portion of an otherwise responsive Document contains information subject to a claim of privilege, only that portion of the Document subject to the claim of privilege shall be deleted or redacted from the Document following the instructions above, and the rest shall be produced.\n\n10. The Requests are continuing in nature. You are hereby instructed to (a) supplement or correct any responses later learned to be incomplete or incorrect immediately upon learning that a prior response was incomplete or incorrect; and (b) produce any additional Documents that are called for under the\n\n11. If a Document is in a language other than English, You should provide that Document. If a Document is in a language other than English, and an English translation exists, You should provide both Documents.\n\n12. All references to Entities includes all affiliates thereof.\n\n13. All references to individual names include all alternative names, aliased, or nicknames.\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 136 of 1063\n\n14. Unless otherwise expressly indicated, the period of time covered by the Document Requests is the period from February 5, 2015 to the date responses to the Document Requests are due.\n\n#### **II. RULES OF CONSTRUCTION**\n\n15. The use of (a) any singular noun shall be construed to include the plural, and vice versa, and (b) a verb in any tense shall be construed as the use of the verb in all other tenses.\n\n16. The terms (a) \"and\" and \"or\" shall be construed either conjunctively or disjunctively as necessary to bring within the scope of any request all responses that might otherwise be construed to be outside of its scope, and (b) \"each\" and \"any\" shall be deemed to include and encompass the words \"every\" and \"all.\"\n\n#### **III. DEFINITIONS**\n\nThe definitions supplied by D. Conn. L. Civ. R. 26(c) and the rules of construction supplied by D. Conn. L. Civ. R. 26(d), as incorporated by D. Conn. Bankr. L.R. 2004-1(a), shall apply to the Document Requests. In addition, the following terms used in these Document Requests shall have the following meanings:\n\n1. \"You\" or \"Your\" or \"Yourself\" means and refers to Zhizhe \"Frank\" Dong, together with any of their employees, agents, counsel, advisors, or anyone acting on their behalf.\n\n2. \"Debtor\" means Ho Wan Kwok (a/k/a Miles Kwok, Miles Guo, Guo Wengui, Guo Haoyun, 郭文贵, or any other alias), together with his employees, agents, counsel, advisors, or anyone acting on his behalf.\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 137 of 1063\n\n3. \"Debtor's Son\" means Qiang Guo (a/k/a Mileson Kwok, 郭强, or any other alias), together with his employees, agents, counsel, advisors, or anyone acting on his behalf.\n\n4. \"Debtor's Daughter\" means Mei Guo (a/k/a Mei Gui, 郭美, or any other alias), together with her employees, agents, counsel, advisors, or anyone acting on her behalf.\n\n5. \"Debtor's Purported Wife\" means Hing Chi Ngok (a/k/a Hing Chi Ng, Yue Qingzhi, 岳庆芝, or any other alias), together with her employees, agents, counsel, advisors, or anyone acting on her behalf.\n\n6. \"Debtor's Family\" means, collectively, the Debtor, the Debtor's Son, the Debtor's Daughter, and the Debtor's Purported Wife, and any other familial relation to the Debtor.\n\n7. \"Associated Individuals\" means, individually and collectively, all individuals that (1) hold, control, have custody over, or discretion over assets owned, controlled, or enjoyed by the Debtor or the Debtor's Family; or (2) have been employees, directors, or otherwise are affiliated with one or more Associated Entities, together with the respective employees, agents, counsel, advisors, or anyone acting on behalf of any of the foregoing. Such Associated Individuals shall include, but are not limited to: Daniel Podhaskie, Karin Maistrello, Melissa Francis, Anthony DiBattista, Han Chunguang (a/k/a 韩春光), Qu Guojiao (a/k/a Qu Guo Jiao, 屈国姣), Zhang Wei (a/k/a 张伟\\*), Lihong Wei Lafrenz (a/k/a Sara Wei, 魏丽红Max Krasner, Yvette Wang (a/k/a Yanping Wang, Yan Ping Wang, 王雁平), Fiona Yu, and Je Kin Ming (a/k/a William Je, Yu Jianming, 余建明).\n\n8. \"Associated Entities\" means, individually and collectively, all organizations or Entities of any type that (1) have been owned, controlled, or invested in by the Debtor or the Debtor's Family; or (2) have an interest, whether directly or indirectly, in any assets owned,\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 138 of 1063\n\ncontrolled, or enjoyed by the Debtor or the Debtor's Family, together with the respective employees, agents, counsel, advisors, or anyone acting on behalf of any of the foregoing. Such Associated Entities shall include, but are not limited to: 7 Nod Hill LLC, ACA Investment Management Limited, ACA Capital Group Limited, Ace Decade Holdings Limited, AI Group Holdings Inc., Booming Sail New York LLC, Bravo Luck Limited, China Golden Spring (Hong Kong) Limited, Crane Advisory Group LLC, Dawn State Limited, Eastern Profit Corporation Limited, Freedom Media Ventures Ltd., G Club Operations LLC, G Fashion LLC, G News LLC, GETTR USA, Genever Holdings Corporation, Genever Holdings LLC, Gfashion Media Group Inc., GFNY, Inc., Golden Spring (New York) Ltd., Greenwich Land LLC, GTV Media Group, Inc., Hamilton Capital Holdings Inc., HCHK Property Management, Inc., HCHK Technologies, Inc., Himalaya Embassy, Himalaya Exchange, Himalaya Federal Reserve, Himalaya Investment LLC, Himalaya International, Himalaya New World Inc., Himalaya Supervisory Organization, Himalaya Ventures LLC, HK International Funds Investments (USA) Limited LLC, Hong Kong International Funds Investments Limited, Hudson Diamond Holding, Infinity Treasury Management Inc., Lexington Property and Staffing, Long Gate Limited, Maywind Trading LLC, MOS Himalaya LLC, New Federal State of China (a/k/a NFSC), Rule of Law Foundation III, Inc., Rule of Law Foundation IV, Inc., Rule of Law Fund, Rule of Law Society, Rule of Law Society IV, Inc., G-Translators PTY LTD, Saraca Media Group, Inc., Well Origin Ltd., Whitecroft Shore Limited, and ZIBA Limited.\n\n9. \"Including\" or any variant thereof means \"including without limitation.\"\n\n10. \"And\" and \"or\" mean \"and/or,\" and shall be construed both conjunctively as well as disjunctively in order to maximize their scope.\n\n11. \"Any\" and \"all\" and \"each\" mean \"each and every.\"\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 139 of 1063\n\n12. \"Each\" and \"every\" mean \"each and every.\"\n\n13. \"Third Party\" means a Person or Entity other than Yourself.\n\n14. \"Transfer\" shall have the meaning given to it by section 101(54) of the Bankruptcy Code.\n\n15. \"Document\" means any information or thing within the scope of Fed. R. Civ. P. 34, and includes, without limitation, each and every written, recorded, or graphic matter of any kind, type, nature, or description that is or has been in Your possession, custody or control, including all printed and electronic copies of electronic mail, computer files maintained in electronic form, correspondence, memoranda, tapes, stenographic or handwritten notes, written forms of any kind, charts, blueprints, drawings, sketches, graphs, plans, articles, specifications, diaries, letters, telegrams, photographs, minutes, contracts, agreements, surveys, computer printouts, data compilations of any kind, telexes, facsimiles, emails, text messages, instant messages, voice messages, invoices, order forms, checks, drafts, statements, credit memos, reports, position reports, summaries, indices, books, ledgers, notebooks, schedules, transparencies, recordings, catalogs, advertisements, promotional materials, films, video tapes, audio tapes, CDs, computer disks, brochures, pamphlets, punch-cards, time-slips, Tweets, social media posts, or any written or recorded materials of any other kind, and all meta-data thereof, however stored (whether in tangible or electronic form), recorded, produced, or reproduced, and also including but not limited to, drafts or copies of any of the foregoing that contain any notes, comments, or markings of any kind not found on the original documents or that are otherwise not identical to the original documents.\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 140 of 1063\n\n16. \"Person(s)\" means an individual, corporation, proprietorship, partnership, association, or any other Entity. \"Person\" also includes any agent, representatives, or expert, including but not limiting to, attorneys or financial advisors.\n\n17. \"Entity\" means any natural Person, corporation, partnership, subsidiary, sole proprietorship, firm, board, joint venture, association, agency, authority, commission or other business entity or juristic Person, as well as any affiliate, agent, parent including but not limited to counsel, financial advisors, or any other representative.\n\n18. \"Regarding\" means concerning, describing, comprising, referring to, related to, supporting, favoring, opposing, bolstering, detracting from, located in, considered in connection with, bearing on, evidencing, indicating, reporting on, recording, alluding to, responding to, connected with, commenting on, in respect of, about, in relation to, discussing, showing, describing, reflecting, analyzing constituting, and being.\n\n19. \"Relating to,\" \"relate(s) to\" or \"related to,\" when referring to any given subject matter, means, without limitation, any document that constitutes, comprises, involves, contains, embodies, reflects, identifies, states, refers directly or indirectly to, or is in any way relevant to the particular subject matter identified.\n\n20. \"Communication(s)\" means, in the broadest possible sense, and without limitation, any transmittal of information or knowledge (in the form of facts, ideas, inquiries, or otherwise). Communication(s) further refers to all conversations, agreements, inquiries, or replies, whether in person, by telephone, in writing, or by means of electronic transmittal devices, and includes, but is not limited to, all correspondence, emails, recordings, transmittal slips, memoranda, telephone communications, voice messages, telegrams, telefaxes, telecopies, telexes, instant messages, chats, text messages, postings to a message board or group chat, social media posts, tweets, videos\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 141 of 1063\n\nuploaded to any video platform, telephonic notes, or notes transmitted internally or with third parties.\n\n21. \"Asset(s)\" means any item of economic value that is subject to possession, custody, or control. Asset includes all real and personal property, including but limited to, real estate, land, houses, apartments, condominiums, automobiles, yachts, boats, planes, jets, helicopters, cash, bank accounts, cryptocurrencies, securities, accounts receivables, inventory, and other tangible and intangible property.\n\n#### **IV. DOCUMENTS TO BE PRODUCED**\n\n1. All Documents and communications regarding the Sherry Netherland Hotel / Condominium, located at 781 Fifth Avenue, New York, NY 10022 (apartments 1801 and 1519; the residential property located at 373 Taconic Rd., Greenwich, Connecticut 06831; the residential property located at 33 Ferncliff Rd., Cos Cob, Connecticut 06807; the residential property located at 354 Nod Hill Rd., Wilton, Connecticut 06897; the property located in at 32 Chateau Ridge Rd., Greenwich, Connecticut 06831; the property located at 110 Clapboard Ridge Rd., Greenwich, Connecticut 06830; the property located at 66 Sherwood Avenue, Greenwich, Connecticut 06831; the property located at 140 Wallacks Drive, Stamford, Connecticut 06902; the property located at 602 Indian Field Drive, Greenwich, Connecticut 06830; and the property located at 11 Hurlingham Drive, Greenwich, Connecticut 06831.\n\n2. All Documents or communications related to any income or Asset of the Debtor, the Debtor's estate, the Debtor's Family, or Associated Entity, including without limitation any real property located in Connecticut.\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 142 of 1063\n\n3. All Documents or communications related to any engagement letter with the Debtor, any member of the Debtor's Family, and/or any Associated Entity, including copy(ies) of such engagement letter(s).\n\n4. All Documents or communications related to the payment of any retainer or commission to You based upon your representation of the Debtor, the Debtor's Family, or an Associated Entity, including documents sufficient to identify the amount of the retainer or commission and its source.\n\n5. All Documents or communications related to any fees, payments, or monies received by You from or on behalf of the Debtor, the Debtor's Family, a Family Related Entity, or an Associated Entity held in escrow or in a client trust account.\n\n6. Documents sufficient to show the amount, date, and source of any payments made to You by, on behalf of, or for the benefit of the Debtor, the Debtor's Family, or an Associated Entity.\n\n7. All Communications between You and, either, the Debtor, the Debtor's Family, or any Associated Individual, agent, employee, or other individual acting on behalf of the Debtor, related to any Transfer, investment, or other transaction or business dealing relating to the Debtor, the Debtor's Estate, the Debtor's Family, or the Associated Entities.\n\n8. All Documents and communications related to any sale, potential sale, acquisition, disposition, purchase, potential purchase, investment, contribution, gift, extension of credit, loan, or Transfer involving the Debtor, the Debtor's Family, or any Associated Entity.\n\n9. All Documents and communications related to the Debtor's use of any Assets belonging to, controlled by, or whose complete or partial ownership is held by the Debtor's Family,\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 143 of 1063\n\nan Associated Entity, or an Associated Individual, including without limitation any real property located in Connecticut.\n\n10. All Documents and communications regarding any balance sheet, bank statement, account statement, financial statement, statement of account, wire transfer instructions and/or confirmation, proof of funds, certificate of deposit, certificate of holdings, investment portfolio summary, or similar document relating to the Debtor, the Debtor's Estate, the Debtor's Family, an Associated Entity, or an Associated Individual, including without limitation all Documents sufficient to show all Transfers to any of the foregoing.\n\nCase 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 144 of 1063\n\n# Exhibit C-7\n\n#### B2540 (Form 2540 – Subpoena for Rule 2004 Examination) (12/15) Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 145 of\n\n1063\n\nUNITED STATES BANKRUPTCY COURT\n\n**District of Connecticut**\n\nIn re HO WAN KWOK, *et al*.,\n\n<sup>1</sup> Case No. 22-50073 (JAM) Debtor Chapter 11\n\n(Jointly Administered)\n\n# **SUBPOENA FOR RULE 2004 EXAMINATION**\n\nTo: **Mary Dowdle (a/k/a Muffin Dowdle)**\n\n(*Name of person to whom the subpoena is directed*)\n\n*Testimony:* **YOU ARE COMMANDED** to appear at the time, date, and place set forth below to testify at an examination under Rule 2004, Federal Rules of Bankruptcy Procedure. A copy of the court order authorizing the examination is attached.\n\n| PLACE                    | DATE AND TIME |\n|--------------------------|---------------|\n| Paul Hastings LLP        |               |\n| 200 Park Avenue          | [TBD]         |\n| New York, New York 10166 |               |\n|                          |               |\n\nThe examination will be recorded by this method: **Court reporter/stenographer**\n\n*Production:* You, or your representatives, must also bring with you to the examination the following documents, electronically stored information, or objects, and must permit inspection, copying, testing, or sampling of the material:\n\n#### **See Requests for Production of Documents, attached hereto.**\n\nThe following provisions of Fed. R. Civ. P. 45, made applicable in bankruptcy cases by Fed. R. Bankr. P. 9016, are attached – Rule 45(c), relating to the place of compliance; Rule 45(d), relating to your protection as a person subject to a subpoena; and Rule 45(e) and 45(g), relating to your duty to respond to this subpoena and the potential consequences of not doing so.\n\nDate: **March , 2023**\n\nCLERK OF COURT\n\nOR\n\n*Signature of Clerk or Deputy Clerk Attorney's signature*\n\nThe name, address, email address, and telephone number of the attorney representing Luc A. Despins, Chapter 11 Trustee, who issues or requests this subpoena, are:\n\n**Douglas S. Skalka, Esq.; Neubert, Pepe & Monteith, P.C.; 195 Church Street, New Haven, Connecticut 06510 dskalka@npmlaw.com; (203) 821-2000**\n\n**Notice to the person who issues or requests this subpoena**\n\nIf this subpoena commands the production of documents, electronically stored information, or tangible things, or the inspection of premises before trial, a notice and a copy of this subpoena must be served on each party before it is served on the person to whom it is directed. Fed. R. Civ. P. 45(a)(4).\n\nSoftware Copyright (c) 1996-2022 Best Case, LLC - www.bestcase.com Best Case Bankruptcy 1 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\n#### **PROOF OF SERVICE**\n\n**(This section should not be filed with the court unless required by Fed. R. Civ. P. 45.)**\n\nI received this subpoena for (*name of individual and title, if any*): on (*date*) .\n\nI served the subpoena by delivering a copy to the named person as follows:\n\non *(date)* ; or\n\nI returned the subpoena unexecuted because:\n\nUnless the subpoena was issued on behalf of the United States, or one of its officers or agents, I have also tendered to the witness the fees for one day's attendance, and the mileage allowed by law, in the amount of \\$ .\n\nMy fees are \\$ for travel and \\$ for services, for a total of \\$ .\n\nI declare under penalty of perjury that this information is true and correct.\n\nDate:\n\n*Server's signature*\n\n*Printed name and title*\n\n*Server's address*\n\nAdditional information concerning attempted service, etc.:\n\n#### **Federal Rule of Civil Procedure 45(c), (d), (e), and (g) (Effective 12/1/13) (made applicable in bankruptcy cases by Rule 9016, Federal Rules of Bankruptcy Procedure)**\n\n#### **(c) Place of compliance.**\n\n*(1) For a Trial, Hearing, or Deposition.* A subpoena may command a person to attend a trial, hearing, or deposition only as follows:\n\n(A) within 100 miles of where the person resides, is employed, or regularly transacts business in person; or\n\n(B) within the state where the person resides, is employed, or regularly transacts business in person, if the person\n\n(i) is a party or a party's officer; or\n\n(ii) is commanded to attend a trial and would not incur substantial expense.\n\n*(2) For Other Discovery.* A subpoena may command:\n\n(A) production of documents, or electronically stored information, or things at a place within 100 miles of where the person resides, is employed, or regularly transacts business in person; and\n\n(B) inspection of premises, at the premises to be inspected.\n\n#### **(d) Protecting a Person Subject to a Subpoena; Enforcement.**\n\n*(1) Avoiding Undue Burden or Expense; Sanctions.* A party or attorney responsible for issuing and serving a subpoena must take reasonable steps to avoid imposing undue burden or expense on a person subject to the subpoena. The court for the district where compliance is required must enforce this duty and impose an appropriate sanction which may include lost earnings and reasonable attorney's fees — on a party or attorney who fails to comply.\n\n#### *(2) Command to Produce Materials or Permit Inspection.*\n\n*(A) Appearance Not Required.* A person commanded to produce documents, electronically stored information, or tangible things, or to permit the inspection of premises, need not appear in person at the place of production or inspection unless also commanded to appear for a deposition, hearing, or trial.\n\n*(B) Objections.* A person commanded to produce documents or tangible things or to permit inspection may serve on the party or attorney designated in the subpoena a written objection to inspecting, copying, testing or sampling any or all of the materials or to inspecting the premises — or to producing electronically stored information in the form or forms requested. The objection must be served before the earlier of the time specified for compliance or 14 days after the subpoena is served. If an objection is made, the following rules apply:\n\n(i) At any time, on notice to the commanded person, the serving party may move the court for the district where compliance is required for an order compelling production or inspection.\n\n(ii) These acts may be required only as directed in the order, and the order must protect a person who is neither a party nor a party's officer from significant expense resulting from compliance.\n\n#### *(3) Quashing or Modifying a Subpoena.*\n\n*(A) When Required.* On timely motion, the court for the district where compliance is required must quash or modify a subpoena that:\n\n(i) fails to allow a reasonable time to comply;\n\n(ii) requires a person to comply beyond the geographical limits specified in Rule 45(c);\n\n(iii) requires disclosure of privileged or other protected matter, if no exception or waiver applies; or\n\n(iv) subjects a person to undue burden.\n\n*(B) When Permitted.* To protect a person subject to or affected by a subpoena, the court for the district where compliance is required may, on motion, quash or modify the subpoena if it requires:\n\n(i) disclosing a trade secret or other confidential research, development, or commercial information; or\n\n(ii) disclosing an unretained expert's opinion or information that does not describe specific occurrences in dispute and results from the expert's study that was not requested by a party.\n\n(C) *Specifying Conditions as an Alternative.* In the circumstances described in Rule 45(d)(3)(B), the court may, instead of quashing or modifying a subpoena, order appearance or production under specified conditions if the serving party:\n\n(i) shows a substantial need for the testimony or material that cannot be otherwise met without undue hardship; and\n\n(ii) ensures that the subpoenaed person will be reasonably compensated.\n\n#### **(e) Duties in Responding to a Subpoena.**\n\n*(1) Producing Documents or Electronically Stored Information.* These procedures apply to producing documents or electronically stored information:\n\n*(A) Documents.* A person responding to a subpoena to produce documents must produce them as they are kept in the ordinary course of business or must organize and label them to correspond to the categories in the demand.\n\n*(B) Form for Producing Electronically Stored Information Not Specified.* If a subpoena does not specify a form for producing electronically stored information, the person responding must produce it in a form or forms in which it is ordinarily maintained or in a reasonably usable form or forms.\n\n*(C) Electronically Stored Information Produced in Only One Form.* The person responding need not produce the same electronically stored information in more than one form.\n\n*(D) Inaccessible Electronically Stored Information.* The person responding need not provide discovery of electronically stored information from sources that the person identifies as not reasonably accessible because of undue burden or cost. On motion to compel discovery or for a protective order, the person responding must show that the information is not reasonably accessible because of undue burden or cost. If that showing is made, the court may nonetheless order discovery from such sources if the requesting party shows good cause, considering the limitations of Rule 26(b)(2)(C). The court may specify conditions for the discovery.\n\n#### *(2) Claiming Privilege or Protection.*\n\n*(A) Information Withheld.* A person withholding subpoenaed information under a claim that it is privileged or subject to protection as trial-preparation material must: (i) expressly make the claim; and\n\n(ii) describe the nature of the withheld documents, communications, or tangible things in a manner that, without revealing information itself privileged or protected, will enable the parties to assess the claim.\n\n*(B) Information Produced.* If information produced in response to a subpoena is subject to a claim of privilege or of protection as trial-preparation material, the person making the claim may notify any party that received the information of the claim and the basis for it. After being notified, a party must promptly return, sequester, or destroy the specified information and any copies it has; must not use or disclose the information until the claim is resolved; must take reasonable steps to retrieve the information if the party disclosed it before being notified; and may promptly present the information under seal to the court for the district where compliance is required for a determination of the claim. The person who produced the information must preserve the information until the claim is resolved.\n\n**(g) Contempt.** The court for the district where compliance is required – and also, after a motion is transferred, the issuing court – may hold in contempt a person who, having been served, fails without adequate excuse to obey the subpoena or an order related to it.\n\nFor access to subpoena materials, see Fed.R.Civ.P.45(a) Committee Note (2013)\n\n…\n\n## **Request for Production of Documents**\n\n## **I. INSTRUCTIONS**\n\n1. Unless otherwise indicated, the requests for documents set forth below, (the \"Requests,\" and each, a \"Request\"), must be responded to separately and specifically. Each Request shall be answered fully unless it is in good faith objected to, in which event the reason for Your objection shall be stated in detail, as set forth below. If an objection pertains only to a portion of a Request, or a word, phrase or clause contained within it, You are required to state Your objection to that portion only and to respond to the remainder of the Requests.\n\n2. Electronically stored information must be produced in accordance with the\n\nfollowing instructions:\n\n- a. Images. Black and white images must be 300 DPI Group IV single-page TIFF files. Color images must be produced in JPEG format. File names cannot contain embedded spaces or special characters (including the comma). Folder names cannot contain embedded spaces or special characters (including the comma). All TIFF image files must have a unique file name, i.e. Bates number. Images must be endorsed with sequential Bates numbers in the lower right corner of each image. The number of TIFF files per folder should not exceed 1000 files. Excel spreadsheets should have a placeholder image named by the Bates number of the file.\n- b. Image Load File\n\t- a. Concordance® Data File. The data file (.DAT) contains all of the fielded information that will be loaded into the Concordance® database. The first line of the .DAT file must be a header row identifying the field names. The .DAT file must use the following Concordance® default delimiters: Comma ASCII character (020) Quote þ ASCII character (254). Date fields should be provided in the format: mm/dd/yyyy. Date and time fields must be two separate fields. If documents includes imaged emails and attachments, the attachment fields must be included to preserve the parent/child relationship between an email and its attachments. An OCRPATH field must be included to provide the file path and name of the extracted text file on the produced storage media. The text file must be named after the FIRSTBATES. Do not include the text in the .DAT file. For Documents with native files, a LINK field must be included to provide the file path and\n\nname of the native file. The native file must be named after the FIRSTBATES.\n\n- b. Concordance Image® OR Opticon Cross-Reference File. The image crossreference file (.LOG or .OPT) links the images to the database records. It should be a comma-delimited file consisting of seven fields per line with a line in the cross-reference file for every image in the database with the following format: ImageID,VolumeLabel,ImageFilePath,DocumentBreak,FolderBreak,Box Break,PageCoun.\n- c. Document Text. Text must be produced as separate text files, not as fields within the .DAT file. The full path to the text file (OCRPATH) should be included in the .DAT file. It is recommended document level ANSI text files, named per the FIRSTBATES/Image Key. Extracted text files must be in a separate folder, and the number of text files per folder should not exceed 1,000 files. There should be no special characters (including commas in the folder names). Text files must be provided on a document level.\n- d. Native Production for Certain File Types. File types that reasonably require viewing in their native format for a full understanding of their content and meaning must be produced in native format. These include, but are not limited to, spreadsheets, spreadsheet-like files (Microsoft Excel, comma separated values, tab separated values, etc.), Microsoft PowerPoint or other special presentation files, database files, and audio/visual files. Provide an image of a Bates numbered slip sheet indicating the presence of a native file, and include the path to the native as a field in the .dat file. Name the produced native file with the Bates number corresponding to the slip sheet for the file. Group native files within incrementally named \"NATIVE\" directories, separate from images directories.\n- e. De-duplication. Produce a single copy of each electronic document for which exact duplicates exist. For email messages, consolidate duplicates based on MD5 hash generated from the BCC, Body, CC, From, IntMsgID, To, and Attach properties. For email attachments and standalone electronic files, consolidate duplicates based on MD5 hash of the entire file.\n- f. Metadata. Produce extracted metadata for each document in the form of a Concordance compliant load file (.dat). The first line of the .DAT file must be a header row identifying the field names. The .DAT file must use the following Concordance default delimiters: Comma , ASCII character (020) Quote þ ASCII character (254)\n\nDate fields should be provided in the format: mm/dd/yyyy. Date and time fields must be two separate fields. Required metadata listed below:\n\n# Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 150 of 1063\n\n| Field Name   | Sample Data              | Description                                      |\n|--------------|--------------------------|--------------------------------------------------|\n| FIRSTBATES   | EDC0000001               | First Bates number of native file document/email |\n| LASTBATES    | EDC0000001               | Last Bates number of native file document/email  |\n|              |                          | **The LASTBATES field should be populated        |\n|              |                          | for single page                                  |\n| ATTACHRANGE  | EDC0000001<br>-          | Bates number of the first page of the parent     |\n|              | EDC0000015               | document to the Bates number of the last page of |\n|              |                          | the last attachment \"child\" document             |\n| BEGATTACH    | EDC0000001               | First Bates number of attachment range           |\n| ENDATTACH    | EDC0000015               | Last Bates number of attachment range            |\n| CUSTODIAN    | Smith, John              | Email: Mailbox where the email resided           |\n|              |                          | Native: Name of the individual or department     |\n|              |                          | from whose files the document<br>originated      |\n| FROM         | John Smith               | Email: Sender                                    |\n|              |                          | Native: Author(s) of document                    |\n|              |                          | **semi-colon should be used to separate          |\n|              |                          | multiple entries                                 |\n| TO           | Coffman, Janice; LeeW    | Recipient(s)                                     |\n|              | [mailto:LeeW@MSN.com]    | **semi-colon should be used to separate multiple |\n|              |                          | entries                                          |\n| CC           | Frank Thompson [mailto:  | Carbon copy recipient(s)                         |\n|              | frank_Thompson@cdt.com]  | **semi-colon should be used to separate          |\n|              |                          | multiple entries                                 |\n| BCC          | John Cain                | Blind carbon copy recipient(s)                   |\n|              |                          | **semi-colon should be used to separate          |\n|              |                          | multiple entries                                 |\n| SUBJECT      | Board Meeting Minutes    | Email: Subject line of the email Native: Title   |\n|              |                          | of document (if available)                       |\n| FILE_NAME    | BoardMeetingMinutes.docx | Native: Name of the original native file,        |\n|              |                          | including extension                              |\n| DATE_SENT    | 10/12/2010               | Email: Date the email was sent                   |\n|              |                          | Native: (empty)                                  |\n| TIME_SENT/   | 07:05 PM GMT             | Email: Time the email was sent/ Time zone in     |\n| TIME_ZONE    |                          | which the emails were standardized               |\n| TIME_ZONE    | GMT                      | The<br>time zone in which<br>the emails<br>were  |\n|              |                          | standardized during conversion.                  |\n| LINK         |  EDC0000001.msg   | Hyperlink to the email or native file document   |\n|              |                          | **The linked file must be named per the          |\n|              |                          | FIRSTBATES number                                |\n| FILE_EXTEN   | MSG                      | The file type extension                          |\n|              |                          | representing                                     |\n|              |                          | the Email or                                     |\n| AUTHOR       | John Smith               | Email: (empty)                                   |\n|              |                          | Native: Author of the document                   |\n| DATE_CREATED | 10/10/2010               | Email: (empty)                                   |\n|              |                          | Native: Date the document was created            |\n\n# Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 151 of 1063\n\n| TIME_CREATED | 10:25 AM                  | Email: (empty)                                  |\n|--------------|---------------------------|-------------------------------------------------|\n|              |                           | Native: Time the document was created           |\n|              |                           | **This data must be a separate field and cannot |\n|              |                           | be combined with the DATE_CREATED field         |\n| DATE_MOD     | 10/12/2010                | Email: (empty)                                  |\n|              |                           | Native: Date the document was last modified     |\n| TIME_MOD     | 07:00 PM                  | Email: (empty)                                  |\n|              |                           | Native: Time the document was last modified     |\n|              |                           | **This data must be a separate field and cannot |\n|              |                           | be combined with the DATE_MOD field             |\n| DATE_ACCESSD | 10/12/2010                | Email: (empty)                                  |\n|              |                           | Native: Date the document was last accessed     |\n| TIME_ACCESSD | 07:00 PM                  | Email: (empty)                                  |\n|              |                           | Native: Time the document was last accessed     |\n|              |                           | **This data must be a separate field and cannot |\n|              |                           | be combined with the DATE_ACCESSD field         |\n| FILE_SIZE    | 5,952                     | Size of native file<br>document/email in KB     |\n| PGCOUNT      | 1                         | Number of pages in native file document/email   |\n| PATH         |   | Email: (empty)                                  |\n|              | Agenda.doc                | Native: Path where native file document was     |\n|              |                           | stored including original file name.            |\n| INTFILEPATH  | Personal Folders\\Deleted  | Email: original location of email including     |\n|              | Items\\Board Meeting       | original file name.                             |\n|              | Minutes.msg               | Native: (empty)                                 |\n| INTMSGID     | <000805c2c71b\\$75977050\\$ | Email: Unique Message ID Native: (empty)        |\n|              | cb8306d1@MSN>             |                                                 |\n| MD5HASH      | d131dd02c5e6eec4693d9a0   | MD5 Hash value of the document.                 |\n|              | 698aff95c                 |                                                 |\n|              | 2fcab58712467eab4004583e  |                                                 |\n|              | b8fb7f89                  |                                                 |\n| OCRPATH      | TEXT/001/EDC0000001.txt   | Path to extracted text of the native file       |\n\n3. Each Request operates and should be construed independently and, unless otherwise indicated, no Request limits the scope of any other Request.\n\n4. All Documents are to be produced as kept in the usual course of business or are to be organized and labeled to correspond with the categories in these Requests.\n\n5. Each Request contained herein extends to all Documents: (a) in Your possession, custody, or control; or (b) in the possession, custody, or control of anyone acting on Your behalf,\n\n#### Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 152 of 1063\n\nincluding Your counsel or other representatives and advisors. Each Document shall be produced in its entirety.\n\n6. If You are requested to produce a Document that is no longer in Your possession, custody, or control, then Your response must (a) describe in detail the nature of the document and its contents; (b) identify the person(s) who prepared or authored the Document (and, if applicable, the Person(s) to whom the Document was sent); (c) identify the date on which the document was prepared or created; (d) state whether such Document (i) is missing or lost, (ii) has been destroyed, (iii) has been transferred, voluntarily or involuntarily, to others, or (iv) was otherwise disposed of; (e) state the reason for, and the facts and circumstances surrounding, such disposition; (f) identify the Persons who authorized such disposition; (g) identify the date or approximate date of such disposition; (h) state when the Document was most recently in Your possession, custody or control; and (i) identify the Person, if any, presently in possession, custody, or control of such Document.\n\n7. If You are requested to produce a Document that has been destroyed, then Your response must state, in addition to the information required by the preceding Instruction: (a) the reason for the Document's destruction; (b) the identity of the Person who destroyed the Document; and (c) the identity of the Person who directed that the Document be destroyed.\n\n8. If You claim that a requested Document is privileged or attorney work-product, then Your response must: (a) state (i) a description of the Document adequate to support Your contention that the Document is privileged, (ii) the title of the Document, (iii) the date of the Document, (iv) the author of the Document, (v) the addressee of the Document, (vi) the identity of each Person who received or saw the original or any draft, copy, or reproduction of the Document, (vii) whether the Document itself, or any information contained or referred to in the Document is in the possession, custody, or control of any other Persons, and if so, the identity of\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 153 of 1063\n\nsuch Persons, as well as a statement addressing how the information came into their possession, (viii) the claim of privilege under which the Document is withheld, and (ix) all of the circumstances upon which You will rely to support such claim of privilege; and (b) produce a privilege log containing all of the information requested in Part (a) of this Instruction for each Document withheld on the basis of a claim of privilege in accordance with D. Conn. L. Civ. R. 26(e). For any part of a Document Request as to which a claim of privilege or work product is not made, responsive documents should be provided in full.\n\n9. If a portion of an otherwise responsive Document contains information subject to a claim of privilege, only that portion of the Document subject to the claim of privilege shall be deleted or redacted from the Document following the instructions above, and the rest shall be produced.\n\n10. The Requests are continuing in nature. You are hereby instructed to (a) supplement or correct any responses later learned to be incomplete or incorrect immediately upon learning that a prior response was incomplete or incorrect; and (b) produce any additional Documents that are called for under the\n\n11. If a Document is in a language other than English, You should provide that Document. If a Document is in a language other than English, and an English translation exists, You should provide both Documents.\n\n12. All references to Entities includes all affiliates thereof.\n\n13. All references to individual names include all alternative names, aliased, or nicknames.\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 154 of 1063\n\n14. Unless otherwise expressly indicated, the period of time covered by the Document Requests is the period from February 5, 2015 to the date responses to the Document Requests are due.\n\n#### **II. RULES OF CONSTRUCTION**\n\n15. The use of (a) any singular noun shall be construed to include the plural, and vice versa, and (b) a verb in any tense shall be construed as the use of the verb in all other tenses.\n\n16. The terms (a) \"and\" and \"or\" shall be construed either conjunctively or disjunctively as necessary to bring within the scope of any request all responses that might otherwise be construed to be outside of its scope, and (b) \"each\" and \"any\" shall be deemed to include and encompass the words \"every\" and \"all.\"\n\n#### **III. DEFINITIONS**\n\nThe definitions supplied by D. Conn. L. Civ. R. 26(c) and the rules of construction supplied by D. Conn. L. Civ. R. 26(d), as incorporated by D. Conn. Bankr. L.R. 2004-1(a), shall apply to the Document Requests. In addition, the following terms used in these Document Requests shall have the following meanings:\n\n1. \"You\" or \"Your\" or \"Yourself\" means and refers to Mary \"Muffin\" Dowdle, together with any of their employees, agents, counsel, advisors, or anyone acting on their behalf.\n\n2. \"Debtor\" means Ho Wan Kwok (a/k/a Miles Kwok, Miles Guo, Guo Wengui, Guo Haoyun, 郭文贵, or any other alias), together with his employees, agents, counsel, advisors, or anyone acting on his behalf.\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 155 of 1063\n\n3. \"Debtor's Son\" means Qiang Guo (a/k/a Mileson Kwok, 郭强, or any other alias), together with his employees, agents, counsel, advisors, or anyone acting on his behalf.\n\n4. \"Debtor's Daughter\" means Mei Guo (a/k/a Mei Gui, 郭美, or any other alias), together with her employees, agents, counsel, advisors, or anyone acting on her behalf.\n\n5. \"Debtor's Purported Wife\" means Hing Chi Ngok (a/k/a Hing Chi Ng, Yue Qingzhi, 岳庆芝, or any other alias), together with her employees, agents, counsel, advisors, or anyone acting on her behalf.\n\n6. \"Debtor's Family\" means, collectively, the Debtor, the Debtor's Son, the Debtor's Daughter, and the Debtor's Purported Wife, and any other familial relation to the Debtor.\n\n7. \"Associated Individuals\" means, individually and collectively, all individuals that (1) hold, control, have custody over, or discretion over assets owned, controlled, or enjoyed by the Debtor or the Debtor's Family; or (2) have been employees, directors, or otherwise are affiliated with one or more Associated Entities, together with the respective employees, agents, counsel, advisors, or anyone acting on behalf of any of the foregoing. Such Associated Individuals shall include, but are not limited to: Daniel Podhaskie, Karin Maistrello, Melissa Francis, Anthony DiBattista, Han Chunguang (a/k/a 韩春光), Qu Guojiao (a/k/a Qu Guo Jiao, 屈国姣), Zhang Wei (a/k/a 张伟\\*), Lihong Wei Lafrenz (a/k/a Sara Wei, 魏丽红Max Krasner, Yvette Wang (a/k/a Yanping Wang, Yan Ping Wang, 王雁平), Fiona Yu, and Je Kin Ming (a/k/a William Je, Yu Jianming, 余建明).\n\n8. \"Associated Entities\" means, individually and collectively, all organizations or Entities of any type that (1) have been owned, controlled, or invested in by the Debtor or the Debtor's Family; or (2) have an interest, whether directly or indirectly, in any assets owned,\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 156 of 1063\n\ncontrolled, or enjoyed by the Debtor or the Debtor's Family, together with the respective employees, agents, counsel, advisors, or anyone acting on behalf of any of the foregoing. Such Associated Entities shall include, but are not limited to: 7 Nod Hill LLC, ACA Investment Management Limited, ACA Capital Group Limited, Ace Decade Holdings Limited, AI Group Holdings Inc., Booming Sail New York LLC, Bravo Luck Limited, China Golden Spring (Hong Kong) Limited, Crane Advisory Group LLC, Dawn State Limited, Eastern Profit Corporation Limited, Freedom Media Ventures Ltd., G Club Operations LLC, G Fashion LLC, G News LLC, GETTR USA, Genever Holdings Corporation, Genever Holdings LLC, Gfashion Media Group Inc., GFNY, Inc., Golden Spring (New York) Ltd., Greenwich Land LLC, GTV Media Group, Inc., Hamilton Capital Holdings Inc., HCHK Property Management, Inc., HCHK Technologies, Inc., Himalaya Embassy, Himalaya Exchange, Himalaya Federal Reserve, Himalaya Investment LLC, Himalaya International, Himalaya New World Inc., Himalaya Supervisory Organization, Himalaya Ventures LLC, HK International Funds Investments (USA) Limited LLC, Hong Kong International Funds Investments Limited, Hudson Diamond Holding, Infinity Treasury Management Inc., Lexington Property and Staffing, Long Gate Limited, Maywind Trading LLC, MOS Himalaya LLC, New Federal State of China (a/k/a NFSC), Rule of Law Foundation III, Inc., Rule of Law Foundation IV, Inc., Rule of Law Fund, Rule of Law Society, Rule of Law Society IV, Inc., G-Translators PTY LTD, Saraca Media Group, Inc., Well Origin Ltd., Whitecroft Shore Limited, and ZIBA Limited.\n\n9. \"Including\" or any variant thereof means \"including without limitation.\"\n\n10. \"And\" and \"or\" mean \"and/or,\" and shall be construed both conjunctively as well as disjunctively in order to maximize their scope.\n\n11. \"Any\" and \"all\" and \"each\" mean \"each and every.\"\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 157 of 1063\n\n12. \"Each\" and \"every\" mean \"each and every.\"\n\n13. \"Third Party\" means a Person or Entity other than Yourself.\n\n14. \"Transfer\" shall have the meaning given to it by section 101(54) of the Bankruptcy Code.\n\n15. \"Document\" means any information or thing within the scope of Fed. R. Civ. P. 34, and includes, without limitation, each and every written, recorded, or graphic matter of any kind, type, nature, or description that is or has been in Your possession, custody or control, including all printed and electronic copies of electronic mail, computer files maintained in electronic form, correspondence, memoranda, tapes, stenographic or handwritten notes, written forms of any kind, charts, blueprints, drawings, sketches, graphs, plans, articles, specifications, diaries, letters, telegrams, photographs, minutes, contracts, agreements, surveys, computer printouts, data compilations of any kind, telexes, facsimiles, emails, text messages, instant messages, voice messages, invoices, order forms, checks, drafts, statements, credit memos, reports, position reports, summaries, indices, books, ledgers, notebooks, schedules, transparencies, recordings, catalogs, advertisements, promotional materials, films, video tapes, audio tapes, CDs, computer disks, brochures, pamphlets, punch-cards, time-slips, Tweets, social media posts, or any written or recorded materials of any other kind, and all meta-data thereof, however stored (whether in tangible or electronic form), recorded, produced, or reproduced, and also including but not limited to, drafts or copies of any of the foregoing that contain any notes, comments, or markings of any kind not found on the original documents or that are otherwise not identical to the original documents.\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 158 of 1063\n\n16. \"Person(s)\" means an individual, corporation, proprietorship, partnership, association, or any other Entity. \"Person\" also includes any agent, representatives, or expert, including but not limiting to, attorneys or financial advisors.\n\n17. \"Entity\" means any natural Person, corporation, partnership, subsidiary, sole proprietorship, firm, board, joint venture, association, agency, authority, commission or other business entity or juristic Person, as well as any affiliate, agent, parent including but not limited to counsel, financial advisors, or any other representative.\n\n18. \"Regarding\" means concerning, describing, comprising, referring to, related to, supporting, favoring, opposing, bolstering, detracting from, located in, considered in connection with, bearing on, evidencing, indicating, reporting on, recording, alluding to, responding to, connected with, commenting on, in respect of, about, in relation to, discussing, showing, describing, reflecting, analyzing constituting, and being.\n\n19. \"Relating to,\" \"relate(s) to\" or \"related to,\" when referring to any given subject matter, means, without limitation, any document that constitutes, comprises, involves, contains, embodies, reflects, identifies, states, refers directly or indirectly to, or is in any way relevant to the particular subject matter identified.\n\n20. \"Communication(s)\" means, in the broadest possible sense, and without limitation, any transmittal of information or knowledge (in the form of facts, ideas, inquiries, or otherwise). Communication(s) further refers to all conversations, agreements, inquiries, or replies, whether in person, by telephone, in writing, or by means of electronic transmittal devices, and includes, but is not limited to, all correspondence, emails, recordings, transmittal slips, memoranda, telephone communications, voice messages, telegrams, telefaxes, telecopies, telexes, instant messages, chats, text messages, postings to a message board or group chat, social media posts, tweets, videos\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 159 of 1063\n\nuploaded to any video platform, telephonic notes, or notes transmitted internally or with third parties.\n\n21. \"Asset(s)\" means any item of economic value that is subject to possession, custody, or control. Asset includes all real and personal property, including but limited to, real estate, land, houses, apartments, condominiums, automobiles, yachts, boats, planes, jets, helicopters, cash, bank accounts, cryptocurrencies, securities, accounts receivables, inventory, and other tangible and intangible property.\n\n#### **IV. DOCUMENTS TO BE PRODUCED**\n\n1. All Documents and communications regarding the Sherry Netherland Hotel / Condominium, located at 781 Fifth Avenue, New York, NY 10022 (apartments 1801 and 1519; the residential property located at 373 Taconic Rd., Greenwich, Connecticut 06831; the residential property located at 33 Ferncliff Rd., Cos Cob, Connecticut 06807; the residential property located at 354 Nod Hill Rd., Wilton, Connecticut 06897; the property located in at 32 Chateau Ridge Rd., Greenwich, Connecticut 06831; the property located at 110 Clapboard Ridge Rd., Greenwich, Connecticut 06830; the property located at 66 Sherwood Avenue, Greenwich, Connecticut 06831; the property located at 140 Wallacks Drive, Stamford, Connecticut 06902; the property located at 602 Indian Field Drive, Greenwich, Connecticut 06830; and the property located at 11 Hurlingham Drive, Greenwich, Connecticut 06831.\n\n2. All Documents or communications related to any income or Asset of the Debtor, the Debtor's estate, the Debtor's Family, or Associated Entity, including without limitation any real property located in Connecticut.\n\n### Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 160 of 1063\n\n3. All Documents or communications related to any engagement letter with the Debtor, any member of the Debtor's Family, and/or any Associated Entity, including copy(ies) of such engagement letter(s).\n\n4. All Documents or communications related to the payment of any retainer or commission to You based upon your representation of the Debtor, the Debtor's Family, or an Associated Entity, including documents sufficient to identify the amount of the retainer or commission and its source.\n\n5. All Documents or communications related to any fees, payments, or monies received by You from or on behalf of the Debtor, the Debtor's Family, a Family Related Entity, or an Associated Entity held in escrow or in a client trust account.\n\n6. Documents sufficient to show the amount, date, and source of any payments made to You by, on behalf of, or for the benefit of the Debtor, the Debtor's Family, or an Associated Entity.\n\n7. All Communications between You and, either, the Debtor, the Debtor's Family, or any Associated Individual, agent, employee, or other individual acting on behalf of the Debtor, related to any Transfer, investment, or other transaction or business dealing relating to the Debtor, the Debtor's Estate, the Debtor's Family, or the Associated Entities.\n\n8. All Documents and communications related to any sale, potential sale, acquisition, disposition, purchase, potential purchase, investment, contribution, gift, extension of credit, loan, or Transfer involving the Debtor, the Debtor's Family, or any Associated Entity.\n\n9. All Documents and communications related to the Debtor's use of any Assets belonging to, controlled by, or whose complete or partial ownership is held by the Debtor's Family,\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 161 of 1063\n\nan Associated Entity, or an Associated Individual, including without limitation any real property located in Connecticut.\n\n10. All Documents and communications regarding any balance sheet, bank statement, account statement, financial statement, statement of account, wire transfer instructions and/or confirmation, proof of funds, certificate of deposit, certificate of holdings, investment portfolio summary, or similar document relating to the Debtor, the Debtor's Estate, the Debtor's Family, an Associated Entity, or an Associated Individual, including without limitation all Documents sufficient to show all Transfers to any of the foregoing.\n\nCase 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 162 of 1063\n\n# Exhibit C-8\n\n#### B2540 (Form 2540 – Subpoena for Rule 2004 Examination) (12/15) Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 163 of\n\nUNITED STATES BANKRUPTCY COURT 1063\n\n**District of Connecticut**\n\nIn re HO WAN KWOK, *et al*.,\n\n<sup>1</sup> Case No. 22-50073 (JAM)\n\nDebtor Chapter 11\n\n(Jointly Administered)\n\n## **SUBPOENA FOR RULE 2004 EXAMINATION**\n\nTo: **Alex Hadjicharalambous**\n\n(*Name of person to whom the subpoena is directed*)\n\n*Testimony:* **YOU ARE COMMANDED** to appear at the time, date, and place set forth below to testify at an examination under Rule 2004, Federal Rules of Bankruptcy Procedure. A copy of the court order authorizing the examination is attached.\n\n| PLACE                    | DATE AND TIME |\n|--------------------------|---------------|\n| Paul Hastings LLP        |               |\n| 200 Park Avenue          | [TBD]         |\n| New York, New York 10166 |               |\n|                          |               |\n\nThe examination will be recorded by this method: **Court reporter/stenographer**\n\n*Production:* You, or your representatives, must also bring with you to the examination the following documents, electronically stored information, or objects, and must permit inspection, copying, testing, or sampling of the material:\n\n#### **See Requests for Production of Documents, attached hereto.**\n\nThe following provisions of Fed. R. Civ. P. 45, made applicable in bankruptcy cases by Fed. R. Bankr. P. 9016, are attached – Rule 45(c), relating to the place of compliance; Rule 45(d), relating to your protection as a person subject to a subpoena; and Rule 45(e) and 45(g), relating to your duty to respond to this subpoena and the potential consequences of not doing so.\n\nDate: **March , 2023**\n\nCLERK OF COURT\n\nOR\n\n*Signature of Clerk or Deputy Clerk Attorney's signature*\n\nThe name, address, email address, and telephone number of the attorney representing Luc A. Despins, Chapter 11 Trustee, who issues or requests this subpoena, are:\n\n**Douglas S. Skalka, Esq.; Neubert, Pepe & Monteith, P.C.; 195 Church Street, New Haven, Connecticut 06510 dskalka@npmlaw.com; (203) 821-2000**\n\n**Notice to the person who issues or requests this subpoena**\n\nIf this subpoena commands the production of documents, electronically stored information, or tangible things, or the inspection of premises before trial, a notice and a copy of this subpoena must be served on each party before it is served on the person to whom it is directed. Fed. R. Civ. P. 45(a)(4).\n\nSoftware Copyright (c) 1996-2022 Best Case, LLC - www.bestcase.com Best Case Bankruptcy 1 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\n#### **PROOF OF SERVICE**\n\n**(This section should not be filed with the court unless required by Fed. R. Civ. P. 45.)**\n\nI received this subpoena for (*name of individual and title, if any*): on (*date*) .\n\nI served the subpoena by delivering a copy to the named person as follows:\n\non *(date)* ; or\n\nI returned the subpoena unexecuted because:\n\nUnless the subpoena was issued on behalf of the United States, or one of its officers or agents, I have also tendered to the witness the fees for one day's attendance, and the mileage allowed by law, in the amount of \\$ .\n\nMy fees are \\$ for travel and \\$ for services, for a total of \\$ .\n\nI declare under penalty of perjury that this information is true and correct.\n\nDate:\n\n*Server's signature*\n\n*Printed name and title*\n\n*Server's address*\n\nAdditional information concerning attempted service, etc.:\n\n#### **Federal Rule of Civil Procedure 45(c), (d), (e), and (g) (Effective 12/1/13) (made applicable in bankruptcy cases by Rule 9016, Federal Rules of Bankruptcy Procedure)**\n\n#### **(c) Place of compliance.**\n\n*(1) For a Trial, Hearing, or Deposition.* A subpoena may command a person to attend a trial, hearing, or deposition only as follows:\n\n(A) within 100 miles of where the person resides, is employed, or regularly transacts business in person; or\n\n(B) within the state where the person resides, is employed, or regularly transacts business in person, if the person\n\n(i) is a party or a party's officer; or\n\n(ii) is commanded to attend a trial and would not incur substantial expense.\n\n*(2) For Other Discovery.* A subpoena may command:\n\n(A) production of documents, or electronically stored information, or things at a place within 100 miles of where the person resides, is employed, or regularly transacts business in person; and\n\n(B) inspection of premises, at the premises to be inspected.\n\n#### **(d) Protecting a Person Subject to a Subpoena; Enforcement.**\n\n*(1) Avoiding Undue Burden or Expense; Sanctions.* A party or attorney responsible for issuing and serving a subpoena must take reasonable steps to avoid imposing undue burden or expense on a person subject to the subpoena. The court for the district where compliance is required must enforce this duty and impose an appropriate sanction which may include lost earnings and reasonable attorney's fees — on a party or attorney who fails to comply.\n\n#### *(2) Command to Produce Materials or Permit Inspection.*\n\n*(A) Appearance Not Required.* A person commanded to produce documents, electronically stored information, or tangible things, or to permit the inspection of premises, need not appear in person at the place of production or inspection unless also commanded to appear for a deposition, hearing, or trial.\n\n*(B) Objections.* A person commanded to produce documents or tangible things or to permit inspection may serve on the party or attorney designated in the subpoena a written objection to inspecting, copying, testing or sampling any or all of the materials or to inspecting the premises — or to producing electronically stored information in the form or forms requested. The objection must be served before the earlier of the time specified for compliance or 14 days after the subpoena is served. If an objection is made, the following rules apply:\n\n(i) At any time, on notice to the commanded person, the serving party may move the court for the district where compliance is required for an order compelling production or inspection.\n\n(ii) These acts may be required only as directed in the order, and the order must protect a person who is neither a party nor a party's officer from significant expense resulting from compliance.\n\n#### *(3) Quashing or Modifying a Subpoena.*\n\n*(A) When Required.* On timely motion, the court for the district where compliance is required must quash or modify a subpoena that:\n\n(i) fails to allow a reasonable time to comply;\n\n(ii) requires a person to comply beyond the geographical limits specified in Rule 45(c);\n\n(iii) requires disclosure of privileged or other protected matter, if no exception or waiver applies; or\n\n(iv) subjects a person to undue burden.\n\n*(B) When Permitted.* To protect a person subject to or affected by a subpoena, the court for the district where compliance is required may, on motion, quash or modify the subpoena if it requires:\n\n(i) disclosing a trade secret or other confidential research, development, or commercial information; or\n\n(ii) disclosing an unretained expert's opinion or information that does not describe specific occurrences in dispute and results from the expert's study that was not requested by a party.\n\n(C) *Specifying Conditions as an Alternative.* In the circumstances described in Rule 45(d)(3)(B), the court may, instead of quashing or modifying a subpoena, order appearance or production under specified conditions if the serving party:\n\n(i) shows a substantial need for the testimony or material that cannot be otherwise met without undue hardship; and\n\n(ii) ensures that the subpoenaed person will be reasonably compensated.\n\n#### **(e) Duties in Responding to a Subpoena.**\n\n*(1) Producing Documents or Electronically Stored Information.* These procedures apply to producing documents or electronically stored information:\n\n*(A) Documents.* A person responding to a subpoena to produce documents must produce them as they are kept in the ordinary course of business or must organize and label them to correspond to the categories in the demand.\n\n*(B) Form for Producing Electronically Stored Information Not Specified.* If a subpoena does not specify a form for producing electronically stored information, the person responding must produce it in a form or forms in which it is ordinarily maintained or in a reasonably usable form or forms.\n\n*(C) Electronically Stored Information Produced in Only One Form.* The person responding need not produce the same electronically stored information in more than one form.\n\n*(D) Inaccessible Electronically Stored Information.* The person responding need not provide discovery of electronically stored information from sources that the person identifies as not reasonably accessible because of undue burden or cost. On motion to compel discovery or for a protective order, the person responding must show that the information is not reasonably accessible because of undue burden or cost. If that showing is made, the court may nonetheless order discovery from such sources if the requesting party shows good cause, considering the limitations of Rule 26(b)(2)(C). The court may specify conditions for the discovery.\n\n#### *(2) Claiming Privilege or Protection.*\n\n*(A) Information Withheld.* A person withholding subpoenaed information under a claim that it is privileged or subject to protection as trial-preparation material must: (i) expressly make the claim; and\n\n(ii) describe the nature of the withheld documents, communications, or tangible things in a manner that, without revealing information itself privileged or protected, will enable the parties to assess the claim.\n\n*(B) Information Produced.* If information produced in response to a subpoena is subject to a claim of privilege or of protection as trial-preparation material, the person making the claim may notify any party that received the information of the claim and the basis for it. After being notified, a party must promptly return, sequester, or destroy the specified information and any copies it has; must not use or disclose the information until the claim is resolved; must take reasonable steps to retrieve the information if the party disclosed it before being notified; and may promptly present the information under seal to the court for the district where compliance is required for a determination of the claim. The person who produced the information must preserve the information until the claim is resolved.\n\n**(g) Contempt.** The court for the district where compliance is required – and also, after a motion is transferred, the issuing court – may hold in contempt a person who, having been served, fails without adequate excuse to obey the subpoena or an order related to it.\n\nFor access to subpoena materials, see Fed.R.Civ.P.45(a) Committee Note (2013)\n\n…\n\n## **Requests for Production of Documents**\n\n## **I. INSTRUCTIONS**\n\n1. Unless otherwise indicated, the requests for documents set forth below, (the \"Requests,\" and each, a \"Request\"), must be responded to separately and specifically. Each Request shall be answered fully unless it is in good faith objected to, in which event the reason for Your objection shall be stated in detail, as set forth below. If an objection pertains only to a portion of a Request, or a word, phrase or clause contained within it, You are required to state Your objection to that portion only and to respond to the remainder of the Requests.\n\n2. Electronically stored information must be produced in accordance with the\n\nfollowing instructions:\n\n- a. Images. Black and white images must be 300 DPI Group IV single-page TIFF files. Color images must be produced in JPEG format. File names cannot contain embedded spaces or special characters (including the comma). Folder names cannot contain embedded spaces or special characters (including the comma). All TIFF image files must have a unique file name, i.e. Bates number. Images must be endorsed with sequential Bates numbers in the lower right corner of each image. The number of TIFF files per folder should not exceed 1000 files. Excel spreadsheets should have a placeholder image named by the Bates number of the file.\n- b. Image Load File\n\t- a. Concordance® Data File. The data file (.DAT) contains all of the fielded information that will be loaded into the Concordance® database. The first line of the .DAT file must be a header row identifying the field names. The .DAT file must use the following Concordance® default delimiters: Comma ASCII character (020) Quote þ ASCII character (254). Date fields should be provided in the format: mm/dd/yyyy. Date and time fields must be two separate fields. If documents includes imaged emails and attachments, the attachment fields must be included to preserve the parent/child relationship between an email and its attachments. An OCRPATH field must be included to provide the file path and name of the extracted text file on the produced storage media. The text file must be named after the FIRSTBATES. Do not include the text in the .DAT file. For Documents with native files, a LINK field must be included to provide the file path and\n\nname of the native file. The native file must be named after the FIRSTBATES.\n\n- b. Concordance Image® OR Opticon Cross-Reference File. The image crossreference file (.LOG or .OPT) links the images to the database records. It should be a comma-delimited file consisting of seven fields per line with a line in the cross-reference file for every image in the database with the following format: ImageID,VolumeLabel,ImageFilePath,DocumentBreak,FolderBreak,Box Break,PageCoun.\n- c. Document Text. Text must be produced as separate text files, not as fields within the .DAT file. The full path to the text file (OCRPATH) should be included in the .DAT file. It is recommended document level ANSI text files, named per the FIRSTBATES/Image Key. Extracted text files must be in a separate folder, and the number of text files per folder should not exceed 1,000 files. There should be no special characters (including commas in the folder names). Text files must be provided on a document level.\n- d. Native Production for Certain File Types. File types that reasonably require viewing in their native format for a full understanding of their content and meaning must be produced in native format. These include, but are not limited to, spreadsheets, spreadsheet-like files (Microsoft Excel, comma separated values, tab separated values, etc.), Microsoft PowerPoint or other special presentation files, database files, and audio/visual files. Provide an image of a Bates numbered slip sheet indicating the presence of a native file, and include the path to the native as a field in the .dat file. Name the produced native file with the Bates number corresponding to the slip sheet for the file. Group native files within incrementally named \"NATIVE\" directories, separate from images directories.\n- e. De-duplication. Produce a single copy of each electronic document for which exact duplicates exist. For email messages, consolidate duplicates based on MD5 hash generated from the BCC, Body, CC, From, IntMsgID, To, and Attach properties. For email attachments and standalone electronic files, consolidate duplicates based on MD5 hash of the entire file.\n- f. Metadata. Produce extracted metadata for each document in the form of a Concordance compliant load file (.dat). The first line of the .DAT file must be a header row identifying the field names. The .DAT file must use the following Concordance default delimiters: Comma , ASCII character (020) Quote þ ASCII character (254)\n\nDate fields should be provided in the format: mm/dd/yyyy. Date and time fields must be two separate fields. Required metadata listed below:\n\n# Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 168 of 1063\n\n| Field Name   | Sample Data              | Description                                      |\n|--------------|--------------------------|--------------------------------------------------|\n| FIRSTBATES   | EDC0000001               | First Bates number of native file document/email |\n| LASTBATES    | EDC0000001               | Last Bates number of native file document/email  |\n|              |                          | **The LASTBATES field should be populated        |\n|              |                          | for single page                                  |\n| ATTACHRANGE  | EDC0000001<br>-          | Bates number of the first page of the parent     |\n|              | EDC0000015               | document to the Bates number of the last page of |\n|              |                          | the last attachment \"child\" document             |\n| BEGATTACH    | EDC0000001               | First Bates number of attachment range           |\n| ENDATTACH    | EDC0000015               | Last Bates number of attachment range            |\n| CUSTODIAN    | Smith, John              | Email: Mailbox where the email resided           |\n|              |                          | Native: Name of the individual or department     |\n|              |                          | from whose files the document<br>originated      |\n| FROM         | John Smith               | Email: Sender                                    |\n|              |                          | Native: Author(s) of document                    |\n|              |                          | **semi-colon should be used to separate          |\n|              |                          | multiple entries                                 |\n| TO           | Coffman, Janice; LeeW    | Recipient(s)                                     |\n|              | [mailto:LeeW@MSN.com]    | **semi-colon should be used to separate multiple |\n|              |                          | entries                                          |\n| CC           | Frank Thompson [mailto:  | Carbon copy recipient(s)                         |\n|              | frank_Thompson@cdt.com]  | **semi-colon should be used to separate          |\n|              |                          | multiple entries                                 |\n| BCC          | John Cain                | Blind carbon copy recipient(s)                   |\n|              |                          | **semi-colon should be used to separate          |\n|              |                          | multiple entries                                 |\n| SUBJECT      | Board Meeting Minutes    | Email: Subject line of the email Native: Title   |\n|              |                          | of document (if available)                       |\n| FILE_NAME    | BoardMeetingMinutes.docx | Native: Name of the original native file,        |\n|              |                          | including extension                              |\n| DATE_SENT    | 10/12/2010               | Email: Date the email was sent                   |\n|              |                          | Native: (empty)                                  |\n| TIME_SENT/   | 07:05 PM GMT             | Email: Time the email was sent/ Time zone in     |\n| TIME_ZONE    |                          | which the emails were standardized               |\n| TIME_ZONE    | GMT                      | The<br>time zone in which<br>the emails<br>were  |\n|              |                          | standardized during conversion.                  |\n| LINK         |  EDC0000001.msg   | Hyperlink to the email or native file document   |\n|              |                          | **The linked file must be named per the          |\n|              |                          | FIRSTBATES number                                |\n| FILE_EXTEN   | MSG                      | The file type extension                          |\n|              |                          | representing                                     |\n|              |                          | the Email or                                     |\n| AUTHOR       | John Smith               | Email: (empty)                                   |\n|              |                          | Native: Author of the document                   |\n| DATE_CREATED | 10/10/2010               | Email: (empty)                                   |\n|              |                          | Native: Date the document was created            |\n\n# Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 169 of 1063\n\n| TIME_CREATED | 10:25 AM                  | Email: (empty)                                  |\n|--------------|---------------------------|-------------------------------------------------|\n|              |                           | Native: Time the document was created           |\n|              |                           | **This data must be a separate field and cannot |\n|              |                           | be combined with the DATE_CREATED field         |\n| DATE_MOD     | 10/12/2010                | Email: (empty)                                  |\n|              |                           | Native: Date the document was last modified     |\n| TIME_MOD     | 07:00 PM                  | Email: (empty)                                  |\n|              |                           | Native: Time the document was last modified     |\n|              |                           | **This data must be a separate field and cannot |\n|              |                           | be combined with the DATE_MOD field             |\n| DATE_ACCESSD | 10/12/2010                | Email: (empty)                                  |\n|              |                           | Native: Date the document was last accessed     |\n| TIME_ACCESSD | 07:00 PM                  | Email: (empty)                                  |\n|              |                           | Native: Time the document was last accessed     |\n|              |                           | **This data must be a separate field and cannot |\n|              |                           | be combined with the DATE_ACCESSD field         |\n| FILE_SIZE    | 5,952                     | Size of native file<br>document/email in KB     |\n| PGCOUNT      | 1                         | Number of pages in native file document/email   |\n| PATH         |   | Email: (empty)                                  |\n|              | Agenda.doc                | Native: Path where native file document was     |\n|              |                           | stored including original file name.            |\n| INTFILEPATH  | Personal Folders\\Deleted  | Email: original location of email including     |\n|              | Items\\Board Meeting       | original file name.                             |\n|              | Minutes.msg               | Native: (empty)                                 |\n| INTMSGID     | <000805c2c71b\\$75977050\\$ | Email: Unique Message ID Native: (empty)        |\n|              | cb8306d1@MSN>             |                                                 |\n| MD5HASH      | d131dd02c5e6eec4693d9a0   | MD5 Hash value of the document.                 |\n|              | 698aff95c                 |                                                 |\n|              | 2fcab58712467eab4004583e  |                                                 |\n|              | b8fb7f89                  |                                                 |\n| OCRPATH      | TEXT/001/EDC0000001.txt   | Path to extracted text of the native file       |\n\n3. Each Request operates and should be construed independently and, unless otherwise indicated, no Request limits the scope of any other Request.\n\n4. All Documents are to be produced as kept in the usual course of business or are to be organized and labeled to correspond with the categories in these Requests.\n\n5. Each Request contained herein extends to all Documents: (a) in Your possession, custody, or control; or (b) in the possession, custody, or control of anyone acting on Your behalf,\n\n#### Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 170 of 1063\n\nincluding Your counsel or other representatives and advisors. Each Document shall be produced in its entirety.\n\n6. If You are requested to produce a Document that is no longer in Your possession, custody, or control, then Your response must (a) describe in detail the nature of the document and its contents; (b) identify the person(s) who prepared or authored the Document (and, if applicable, the Person(s) to whom the Document was sent); (c) identify the date on which the document was prepared or created; (d) state whether such Document (i) is missing or lost, (ii) has been destroyed, (iii) has been transferred, voluntarily or involuntarily, to others, or (iv) was otherwise disposed of; (e) state the reason for, and the facts and circumstances surrounding, such disposition; (f) identify the Persons who authorized such disposition; (g) identify the date or approximate date of such disposition; (h) state when the Document was most recently in Your possession, custody or control; and (i) identify the Person, if any, presently in possession, custody, or control of such Document.\n\n7. If You are requested to produce a Document that has been destroyed, then Your response must state, in addition to the information required by the preceding Instruction: (a) the reason for the Document's destruction; (b) the identity of the Person who destroyed the Document; and (c) the identity of the Person who directed that the Document be destroyed.\n\n8. If You claim that a requested Document is privileged or attorney work-product, then Your response must: (a) state (i) a description of the Document adequate to support Your contention that the Document is privileged, (ii) the title of the Document, (iii) the date of the Document, (iv) the author of the Document, (v) the addressee of the Document, (vi) the identity of each Person who received or saw the original or any draft, copy, or reproduction of the Document, (vii) whether the Document itself, or any information contained or referred to in the Document is in the possession, custody, or control of any other Persons, and if so, the identity of\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 171 of 1063\n\nsuch Persons, as well as a statement addressing how the information came into their possession, (viii) the claim of privilege under which the Document is withheld, and (ix) all of the circumstances upon which You will rely to support such claim of privilege; and (b) produce a privilege log containing all of the information requested in Part (a) of this Instruction for each Document withheld on the basis of a claim of privilege in accordance with D. Conn. L. Civ. R. 26(e).\n\n9. If a portion of an otherwise responsive Document contains information subject to a claim of privilege, only that portion of the Document subject to the claim of privilege shall be deleted or redacted from the Document following the instructions above, and the rest shall be produced.\n\n10. The Requests are continuing in nature. You are hereby instructed to (a) supplement or correct any responses later learned to be incomplete or incorrect immediately upon learning that a prior response was incomplete or incorrect; and (b) produce any additional Documents that are called for under the\n\n11. If a Document is in a language other than English, You should provide that Document. If a Document is in a language other than English, and an English translation exists, You should provide both Documents.\n\n12. All references to Entities includes all affiliates thereof.\n\n13. All references to individual names include all alternative names, aliased, or nicknames.\n\n14. Unless otherwise expressly indicated, the period of time covered by the Document Requests is the period from February 5, 2012 to the date responses to the Document Requests are due.\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 172 of 1063\n\n#### **II. RULES OF CONSTRUCTION**\n\n15. The use of (a) any singular noun shall be construed to include the plural, and vice versa, and (b) a verb in any tense shall be construed as the use of the verb in all other tenses.\n\n16. The terms (a) \"and\" and \"or\" shall be construed either conjunctively or disjunctively as necessary to bring within the scope of any request all responses that might otherwise be construed to be outside of its scope, and (b) \"each\" and \"any\" shall be deemed to include and encompass the words \"every\" and \"all.\"\n\n#### **III. DEFINITIONS**\n\nThe definitions supplied by D. Conn. L. Civ. R. 26(c) and the rules of construction supplied by D. Conn. L. Civ. R. 26(d), as incorporated by D. Conn. Bankr. L.R. 2004-1(a), shall apply to the Document Requests. In addition, the following terms used in these Document Requests shall have the following meanings:\n\n1. \"You\" or \"Your\" or \"Yourself\" means and refers to Alex Hadjicharalambous, together with all of his agents, attorneys, representatives, employees, and/or anyone acting on his behalf.\n\n2. \"Debtor\" means Ho Wan Kwok (a/k/a Miles Kwok, Miles Guo, Guo Wengui, Guo Haoyun, 郭文贵, or any other alias), together with his employees, agents, counsel, advisors, or anyone acting on his behalf.\n\n3. \"Debtor's Son\" means Qiang Guo (a/k/a Mileson Kwok, 郭强, or any other alias), together with his employees, agents, counsel, advisors, or anyone acting on his behalf.\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 173 of 1063\n\n4. \"Debtor's Daughter\" means Mei Guo (a/k/a Mei Gui, 郭美, or any other alias), together with her employees, agents, counsel, advisors, or anyone acting on her behalf.\n\n5. \"Debtor's Purported Wife\" means Hing Chi Ngok (a/k/a Hing Chi Ng, Yue Qingzhi, 岳庆芝, or any other alias), together with her employees, agents, counsel, advisors, or anyone acting on her behalf.\n\n6. \"Debtor's Family\" means, collectively, the Debtor, the Debtor's Son, the Debtor's Daughter, and the Debtor's Purported Wife, and any other familial relation to the Debtor.\n\n7. \"Associated Individuals\" means, individually and collectively, all individuals that (1) hold, control, have custody over, or discretion over assets owned, controlled, or enjoyed by the Debtor or the Debtor's Family; or (2) have been employees, directors, or otherwise are affiliated with one or more Associated Entities, together with the respective employees, agents, counsel, advisors, or anyone acting on behalf of any of the foregoing. Such Associated Individuals shall include, but are not limited to: Daniel Podhaskie, Jason Miller, Steve Bannon, Karin Maistrello, Melissa Francis, Anthony DiBattista, William Gertz, Arethusa Forsyth, Glenn Mellor, Jennifer Mercurio, Eduardo Eurnekian, Wencong Wang, Han Chunguang (a/k/a 韩春光), Qu Guojiao (a/k/a Qu Guo Jiao, 屈国姣), Guo Lijie (a/k/a 郭丽杰), Zhang Wei (a/k/a 张伟\\*), Lihong Wei Lafrenz (a/k/a Sara Wei, 魏丽红), Hao Haidong (a/k/a 郝海东), Ross Heinemeyer, Max Krasner, Kyle Bass, Melissa Mendez, Ya Li (a/k/a 李娅), Dinggang Wang (a/k/a 王定刚), An Hong (a/k/a 安红), Yvette Wang (a/k/a Yanping Wang, Yan Ping Wang, 王雁平), Fiona Yu, Je Kin Ming (a/k/a William Je, Yu Jianming, 余建明), Yaz Qingua, and Lao Jiang (a/k/a Jiang Yunfu, Jiang Yunfu Be, 姜云浮).\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 174 of 1063\n\n8. \"Associated Entities\" means, individually and collectively, all organizations or Entities of any type that (1) have been owned, controlled, or invested in by the Debtor or the Debtor's Family; or (2) have an interest, whether directly or indirectly, in any assets owned, controlled, or enjoyed by the Debtor or the Debtor's Family, together with the respective employees, agents, counsel, advisors, or anyone acting on behalf of any of the foregoing. Such Associated Entities shall include, but are not limited to: 7 Nod Hill LLC, AAGV Limited, ACA Investment Management Limited, ACA Capital Group Limited, Ace Decade Holdings Limited, AI Group Holdings Inc., Alfa Global Ventures Limited, Alfonso Global Limited, Allied Capital Global Limited, Alpine Fiduciaries SA, Anton Development Limited, Assets Sino Limited, Auspicious Coast Limited, Beijing Pangu Investment Co., Beijing Pangu Investment Co. Ltd., Beijing Pangu Investment Inc., Beijing Zenith Holdings Company Limited, Booming Sail New York LLC, Bravo Luck Limited, BSA Strategic Fund I, China Golden Spring (Hong Kong) Limited, Chuang Xin Limited, Crane Advisory Group LLC, Creative Apex Investments Limited, Crystal Breeze Investments Limited, Dawn State Limited, Eastern Profit Corporation Limited, Elite Well Global Limited, Empire Growth Holdings, Freedom Media Ventures Ltd., G Club Operations LLC, G Fashion LLC, G News LLC, GETTR USA, Genever Holdings Corporation, Genever Holdings LLC, Gfashion Media Group Inc., GFNY, Inc., Globalist International Limited, GNews Media Group Inc., Golden Spring (New York) Ltd., Greenwich Land LLC, Guo Media, GTV Media Group, Inc., Hamilton Capital Holdings Inc., HCHK Property Management, Inc., HCHK Technologies, Inc., Head Win Group Limited, Henan Yuda, Himalaya Embassy, Himalaya Exchange, Himalaya Federal Reserve, Himalaya Investment LLC, Himalaya International, Himalaya New World Inc., Himalaya Supervisory Organization, Himalaya Ventures LLC, HK International Funds Investments (USA) Limited LLC, Hong Kong International Funds\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 175 of 1063\n\nInvestments Limited, Hudson Diamond Holding, Infinite Increase Limited, Infinitum Developments Limited, Infinity Treasury Management Inc., Insight Phoenix Fund, Lamp Capital LLC, Leading Shine Limited, Leading Shine NY Limited, Lexington Property and Staffing, Long Gate Limited, Maywind Trading LLC, MOS Himalaya LLC, Next Tycoon Investments Limited, New Federal State of China (a/k/a NFSC), Noble Fame Global Limited, Rosy Acme Ventures Limited, Rule of Law Foundation III, Inc., Rule of Law Foundation IV, Inc., Rule of Law Fund, Rule of Law Society, Rule of Law Society IV, Inc., G-Translators PTY LTD, Saraca Media Group, Inc., Shiny Ace Ltd., Shiny Times Holdings Ltd., Spirit Charter Investment Limited, Stevenson, Wong & Co., Voice of Guo Media, Inc., Well Origin Ltd., World Century Limited, Worldwide Opportunity Holdings Limited, Whitecroft Shore Limited, and ZIBA Limited.\n\n9. \"Including\" or any variant thereof means \"including without limitation.\"\n\n10. \"And\" and \"or\" mean \"and/or,\" and shall be construed both conjunctively as well as disjunctively in order to maximize their scope.\n\n11. \"Any\" and \"all\" and \"each\" mean \"each and every.\"\n\n12. \"Each\" and \"every\" mean \"each and every.\"\n\n13. \"Third Party\" means a Person or Entity other than Yourself.\n\n14. \"Transfer\" shall have the meaning given to it by section 101(54) of the Bankruptcy Code.\n\n15. \"Document\" means any information or thing within the scope of Fed. R. Civ. P. 34, and includes, without limitation, each and every written, recorded, or graphic matter of any kind, type, nature, or description that is or has been in Your Possession, Custody or Control, including all printed and electronic copies of electronic mail, computer files maintained in\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 176 of 1063\n\nelectronic form, electronic communication, text message, social media post, tweet, meta-data, correspondence, memoranda, tapes, stenographic or handwritten notes, written forms of any kind, charts, blueprints, drawings, sketches, graphs, plans, articles, specifications, diaries, letters, telegrams, photographs, minutes, contracts, agreements, surveys, computer printouts, data compilations of any kind, telexes, facsimiles, voice messages, invoices, order forms, checks, drafts, statements, credit memos, reports, position reports, summaries, indices, books, ledgers, notebooks, schedules, transparencies, recordings, catalogs, advertisements, promotional materials, films, video tapes, audio tapes, CDs, computer disks, brochures, pamphlets, punchcards, time-slips, Tweets, social media posts, or any written or recorded materials of any other kind, and all meta-data thereof, however stored (whether in tangible or electronic form), recorded, produced, or reproduced, and also including but not limited to, drafts or copies of any of the foregoing that contain any notes, comments, or markings of any kind not found on the original documents or that are otherwise not identical to the original documents.\n\n16. \"Person(s)\" means an individual, corporation, proprietorship, partnership, association, or any other Entity. \"Person\" also includes any agent, representatives, or expert, including but not limiting to, attorneys or financial advisors.\n\n17. \"Entity\" means any natural Person, corporation, partnership, subsidiary, sole proprietorship, firm, board, joint venture, association, agency, authority, commission or other business entity or juristic Person, as well as any affiliate, agent, parent including but not limited to legal counsel, financial advisors, or any other representative.\n\n18. \"Regarding\" means concerning, describing, comprising, referring to, related to, supporting, favoring, opposing, bolstering, detracting from, located in, considered in connection with, bearing on, evidencing, indicating, reporting on, recording, alluding to, responding to,\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 177 of 1063\n\nconnected with, commenting on, in respect of, about, in relation to, discussing, showing, describing, reflecting, analyzing constituting, and being.\n\n19. \"Relating to,\" \"relate(s) to\" or \"related to,\" when referring to any given subject matter, means, without limitation, any document that constitutes, comprises, involves, contains, embodies, reflects, identifies, states, refers directly or indirectly to, or is in any way relevant to the particular subject matter identified.\n\n20. \"Communication(s)\" means, in the broadest possible sense, and without limitation, any transmittal of information or knowledge (in the form of facts, ideas, inquiries, or otherwise). Communication(s) further refers to all conversations, agreements, inquiries, or replies, whether in person, by telephone, in writing, or by means of electronic transmittal devices, and includes, but is not limited to, all correspondence, emails, recordings, transmittal slips, memoranda, telephone communications, voice messages, telegrams, telefaxes, telecopies, telexes, instant messages, chats, text messages, telephonic notes, or notes transmitted internally or with third parties.\n\n21. \"Asset(s)\" means any item that can be used to produce positive economic value, including but not limited to any resource with economic value that is owned, controlled or is for the benefit of an entity, that is expected to provide a future benefit, including but not limited to, all real and personal property, intangible property, investments, rights to invest or to future revenue, cash, bank accounts, commodities, securities, claims, total or partial control of an entity, and prospective economic opportunities\n\n22. \"Transfer\" shall have the meaning given to it by section 101(54) of the Bankruptcy Code.\n\n#### **IV. DOCUMENTS TO BE PRODUCED**\n\n1. All Documents regarding any income or Asset of the Debtor, the Debtor's estate, or an Associated Entity.\n\n2. All Documents related to the Debtor's financial condition and obligations to his creditors, including without limitation all Documents related to any effort to avoid paying such obligations and All Documents related to this or any other actual or potential bankruptcy or similar insolvency proceeding.\n\n3. All Documents regarding any balance sheet, bank statement, account statement, financial statement, statement of account, wire transfer instructions and/or confirmation, proof of funds, certificate of deposit, certificate of holdings, investment portfolio summary, or similar document relating to the Debtor, the Debtor's Estate, the Debtor's Family, an Associated Entity, or an Associated Individual, including without limitation all Documents sufficient to show all Transfers to any of the foregoing.\n\n4. All Documents regarding any investment, business dealing or transactions made by, with, or on behalf of the Debtor.\n\n5. All Communications with the Debtor, and Documents related to Communications with the Debtor, related to the operation, management, or decision-making of any Entity, including without limitation the Associated Entities.\n\n6. All Documents regarding any Transfer, investment, or other transaction or business dealing made to, by, or with the Debtor, the Debtor's Family, or an Associated Entity.\n\n7. All Documents regarding any property ever occupied or used by the Debtor, including without limitation the *Lady May*; the Sherry Netherland Hotel / Condominium; the\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 179 of 1063\n\nresidential property located in Greenwich, Connecticut at 373 Taconic Rd.; the residential property located in Greenwich, Connecticut at 33 Ferncliff Rd.; and the residential property located in Wilton, Connecticut at 354 Nod Hill Rd.\n\n8. All Documents related to any aircraft owned, controlled, or used by the Debtor, including without limitation the aircraft bearing tail number T7-GQM and any other aircraft registered in San Marino, including without limitation copies of all registration documents and flight manifests showing flights taken by such aircraft and the individuals onboard such flights.\n\n9. All Documents regarding any gifts, benefits or loans, to, from or on behalf of the Debtor, the Debtor's Estate, the Debtor's Family, or the Associated Entities, including without limitation Documents sufficient to show the amounts of such gifts, benefits, or loans; the purposes for which such gifts, benefits, or loans were used; when the gifts, benefits, or loans were provided; and the terms of any loans, all representations and warranties made in connection with any loans, the interest rate on any loans, and all evidence of payments of any loans.\n\n10. All Documents concerning any trust or similar instrument set up by, on behalf of, or for the benefit of the Debtor, the Debtor's Estate, the Debtor's Family, or an Associated Entity, including without limitation Documents sufficient to show when the trust(s) was created, by whom it was created, for whose benefit it was created, and the corpus of the trust.\n\n11. All Documents related to any obligation, claim, liability, or debt associated with any legal dispute involving the Debtor, including but not limited to those relating to any litigation before any local, state, federal, or international body, whether an administrative body, court, panel, or alternative dispute resolution entity.\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 180 of 1063\n\n12. All Documents and communications between any of your outside counsel or other advisors and the Debtor.\n\n13. All Documents related to any Associated Entity that You hold or have held an interest in.\n\n14. All Communications with the Debtor, and Documents related to Communications with the Debtor, related to the operation, management, or decision-making of any legal entity, including without limitation the Family Related Entities and the Associated Entities.\n\nCase 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 181 of 1063\n\n# Exhibit C-9\n\n#### B2540 (Form 2540 – Subpoena for Rule 2004 Examination) (12/15) Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 182 of\n\nUNITED STATES BANKRUPTCY COURT 1063\n\n**District of Connecticut**\n\nIn re HO WAN KWOK, *et al*.,\n\n<sup>1</sup> Case No. 22-50073 (JAM)\n\nDebtor Chapter 11\n\n(Jointly Administered)\n\n# **SUBPOENA FOR RULE 2004 EXAMINATION**\n\nTo: **Alex Hadjicharalambous**\n\n(*Name of person to whom the subpoena is directed*)\n\n*Testimony:* **YOU ARE COMMANDED** to appear at the time, date, and place set forth below to testify at an examination under Rule 2004, Federal Rules of Bankruptcy Procedure. A copy of the court order authorizing the examination is attached.\n\n| PLACE                    | DATE AND TIME |\n|--------------------------|---------------|\n| Paul Hastings LLP        |               |\n| 200 Park Avenue          | [TBD]         |\n| New York, New York 10166 |               |\n|                          |               |\n\nThe examination will be recorded by this method: **Court reporter/stenographer**\n\n*Production:* You, or your representatives, must also bring with you to the examination the following documents, electronically stored information, or objects, and must permit inspection, copying, testing, or sampling of the material:\n\n#### **See Requests for Production of Documents, attached hereto.**\n\nThe following provisions of Fed. R. Civ. P. 45, made applicable in bankruptcy cases by Fed. R. Bankr. P. 9016, are attached – Rule 45(c), relating to the place of compliance; Rule 45(d), relating to your protection as a person subject to a subpoena; and Rule 45(e) and 45(g), relating to your duty to respond to this subpoena and the potential consequences of not doing so.\n\nDate: **March , 2023**\n\nCLERK OF COURT\n\nOR\n\n*Signature of Clerk or Deputy Clerk Attorney's signature*\n\nThe name, address, email address, and telephone number of the attorney representing Luc A. Despins, Chapter 11 Trustee, who issues or requests this subpoena, are:\n\n**Douglas S. Skalka, Esq.; Neubert, Pepe & Monteith, P.C.; 195 Church Street, New Haven, Connecticut 06510 dskalka@npmlaw.com; (203) 821-2000**\n\n**Notice to the person who issues or requests this subpoena**\n\nIf this subpoena commands the production of documents, electronically stored information, or tangible things, or the inspection of premises before trial, a notice and a copy of this subpoena must be served on each party before it is served on the person to whom it is directed. Fed. R. Civ. P. 45(a)(4).\n\nSoftware Copyright (c) 1996-2022 Best Case, LLC - www.bestcase.com Best Case Bankruptcy 1 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\n#### **PROOF OF SERVICE**\n\n**(This section should not be filed with the court unless required by Fed. R. Civ. P. 45.)**\n\nI received this subpoena for (*name of individual and title, if any*): on (*date*) .\n\nI served the subpoena by delivering a copy to the named person as follows:\n\non *(date)* ; or\n\nI returned the subpoena unexecuted because:\n\nUnless the subpoena was issued on behalf of the United States, or one of its officers or agents, I have also tendered to the witness the fees for one day's attendance, and the mileage allowed by law, in the amount of \\$ .\n\nMy fees are \\$ for travel and \\$ for services, for a total of \\$ .\n\nI declare under penalty of perjury that this information is true and correct.\n\nDate:\n\n*Server's signature*\n\n*Printed name and title*\n\n*Server's address*\n\nAdditional information concerning attempted service, etc.:\n\n#### **Federal Rule of Civil Procedure 45(c), (d), (e), and (g) (Effective 12/1/13) (made applicable in bankruptcy cases by Rule 9016, Federal Rules of Bankruptcy Procedure)**\n\n#### **(c) Place of compliance.**\n\n*(1) For a Trial, Hearing, or Deposition.* A subpoena may command a person to attend a trial, hearing, or deposition only as follows:\n\n(A) within 100 miles of where the person resides, is employed, or regularly transacts business in person; or\n\n(B) within the state where the person resides, is employed, or regularly transacts business in person, if the person\n\n(i) is a party or a party's officer; or\n\n(ii) is commanded to attend a trial and would not incur substantial expense.\n\n*(2) For Other Discovery.* A subpoena may command:\n\n(A) production of documents, or electronically stored information, or things at a place within 100 miles of where the person resides, is employed, or regularly transacts business in person; and\n\n(B) inspection of premises, at the premises to be inspected.\n\n#### **(d) Protecting a Person Subject to a Subpoena; Enforcement.**\n\n*(1) Avoiding Undue Burden or Expense; Sanctions.* A party or attorney responsible for issuing and serving a subpoena must take reasonable steps to avoid imposing undue burden or expense on a person subject to the subpoena. The court for the district where compliance is required must enforce this duty and impose an appropriate sanction which may include lost earnings and reasonable attorney's fees — on a party or attorney who fails to comply.\n\n#### *(2) Command to Produce Materials or Permit Inspection.*\n\n*(A) Appearance Not Required.* A person commanded to produce documents, electronically stored information, or tangible things, or to permit the inspection of premises, need not appear in person at the place of production or inspection unless also commanded to appear for a deposition, hearing, or trial.\n\n*(B) Objections.* A person commanded to produce documents or tangible things or to permit inspection may serve on the party or attorney designated in the subpoena a written objection to inspecting, copying, testing or sampling any or all of the materials or to inspecting the premises — or to producing electronically stored information in the form or forms requested. The objection must be served before the earlier of the time specified for compliance or 14 days after the subpoena is served. If an objection is made, the following rules apply:\n\n(i) At any time, on notice to the commanded person, the serving party may move the court for the district where compliance is required for an order compelling production or inspection.\n\n(ii) These acts may be required only as directed in the order, and the order must protect a person who is neither a party nor a party's officer from significant expense resulting from compliance.\n\n#### *(3) Quashing or Modifying a Subpoena.*\n\n*(A) When Required.* On timely motion, the court for the district where compliance is required must quash or modify a subpoena that:\n\n(i) fails to allow a reasonable time to comply;\n\n(ii) requires a person to comply beyond the geographical limits specified in Rule 45(c);\n\n(iii) requires disclosure of privileged or other protected matter, if no exception or waiver applies; or\n\n(iv) subjects a person to undue burden.\n\n*(B) When Permitted.* To protect a person subject to or affected by a subpoena, the court for the district where compliance is required may, on motion, quash or modify the subpoena if it requires:\n\n(i) disclosing a trade secret or other confidential research, development, or commercial information; or\n\n(ii) disclosing an unretained expert's opinion or information that does not describe specific occurrences in dispute and results from the expert's study that was not requested by a party.\n\n(C) *Specifying Conditions as an Alternative.* In the circumstances described in Rule 45(d)(3)(B), the court may, instead of quashing or modifying a subpoena, order appearance or production under specified conditions if the serving party:\n\n(i) shows a substantial need for the testimony or material that cannot be otherwise met without undue hardship; and\n\n(ii) ensures that the subpoenaed person will be reasonably compensated.\n\n#### **(e) Duties in Responding to a Subpoena.**\n\n*(1) Producing Documents or Electronically Stored Information.* These procedures apply to producing documents or electronically stored information:\n\n*(A) Documents.* A person responding to a subpoena to produce documents must produce them as they are kept in the ordinary course of business or must organize and label them to correspond to the categories in the demand.\n\n*(B) Form for Producing Electronically Stored Information Not Specified.* If a subpoena does not specify a form for producing electronically stored information, the person responding must produce it in a form or forms in which it is ordinarily maintained or in a reasonably usable form or forms.\n\n*(C) Electronically Stored Information Produced in Only One Form.* The person responding need not produce the same electronically stored information in more than one form.\n\n*(D) Inaccessible Electronically Stored Information.* The person responding need not provide discovery of electronically stored information from sources that the person identifies as not reasonably accessible because of undue burden or cost. On motion to compel discovery or for a protective order, the person responding must show that the information is not reasonably accessible because of undue burden or cost. If that showing is made, the court may nonetheless order discovery from such sources if the requesting party shows good cause, considering the limitations of Rule 26(b)(2)(C). The court may specify conditions for the discovery.\n\n#### *(2) Claiming Privilege or Protection.*\n\n*(A) Information Withheld.* A person withholding subpoenaed information under a claim that it is privileged or subject to protection as trial-preparation material must: (i) expressly make the claim; and\n\n(ii) describe the nature of the withheld documents, communications, or tangible things in a manner that, without revealing information itself privileged or protected, will enable the parties to assess the claim.\n\n*(B) Information Produced.* If information produced in response to a subpoena is subject to a claim of privilege or of protection as trial-preparation material, the person making the claim may notify any party that received the information of the claim and the basis for it. After being notified, a party must promptly return, sequester, or destroy the specified information and any copies it has; must not use or disclose the information until the claim is resolved; must take reasonable steps to retrieve the information if the party disclosed it before being notified; and may promptly present the information under seal to the court for the district where compliance is required for a determination of the claim. The person who produced the information must preserve the information until the claim is resolved.\n\n**(g) Contempt.** The court for the district where compliance is required – and also, after a motion is transferred, the issuing court – may hold in contempt a person who, having been served, fails without adequate excuse to obey the subpoena or an order related to it.\n\nFor access to subpoena materials, see Fed.R.Civ.P.45(a) Committee Note (2013)\n\n…\n\n## **Requests for Production of Documents**\n\n## **I. INSTRUCTIONS**\n\n1. Unless otherwise indicated, the requests for documents set forth below, (the \"Requests,\" and each, a \"Request\"), must be responded to separately and specifically. Each Request shall be answered fully unless it is in good faith objected to, in which event the reason for Your objection shall be stated in detail, as set forth below. If an objection pertains only to a portion of a Request, or a word, phrase or clause contained within it, You are required to state Your objection to that portion only and to respond to the remainder of the Requests.\n\n2. Electronically stored information must be produced in accordance with the\n\nfollowing instructions:\n\n- a. Images. Black and white images must be 300 DPI Group IV single-page TIFF files. Color images must be produced in JPEG format. File names cannot contain embedded spaces or special characters (including the comma). Folder names cannot contain embedded spaces or special characters (including the comma). All TIFF image files must have a unique file name, i.e. Bates number. Images must be endorsed with sequential Bates numbers in the lower right corner of each image. The number of TIFF files per folder should not exceed 1000 files. Excel spreadsheets should have a placeholder image named by the Bates number of the file.\n- b. Image Load File\n\t- a. Concordance® Data File. The data file (.DAT) contains all of the fielded information that will be loaded into the Concordance® database. The first line of the .DAT file must be a header row identifying the field names. The .DAT file must use the following Concordance® default delimiters: Comma ASCII character (020) Quote þ ASCII character (254). Date fields should be provided in the format: mm/dd/yyyy. Date and time fields must be two separate fields. If documents includes imaged emails and attachments, the attachment fields must be included to preserve the parent/child relationship between an email and its attachments. An OCRPATH field must be included to provide the file path and name of the extracted text file on the produced storage media. The text file must be named after the FIRSTBATES. Do not include the text in the .DAT file. For Documents with native files, a LINK field must be included to provide the file path and\n\nname of the native file. The native file must be named after the FIRSTBATES.\n\n- b. Concordance Image® OR Opticon Cross-Reference File. The image crossreference file (.LOG or .OPT) links the images to the database records. It should be a comma-delimited file consisting of seven fields per line with a line in the cross-reference file for every image in the database with the following format: ImageID,VolumeLabel,ImageFilePath,DocumentBreak,FolderBreak,Box Break,PageCoun.\n- c. Document Text. Text must be produced as separate text files, not as fields within the .DAT file. The full path to the text file (OCRPATH) should be included in the .DAT file. It is recommended document level ANSI text files, named per the FIRSTBATES/Image Key. Extracted text files must be in a separate folder, and the number of text files per folder should not exceed 1,000 files. There should be no special characters (including commas in the folder names). Text files must be provided on a document level.\n- d. Native Production for Certain File Types. File types that reasonably require viewing in their native format for a full understanding of their content and meaning must be produced in native format. These include, but are not limited to, spreadsheets, spreadsheet-like files (Microsoft Excel, comma separated values, tab separated values, etc.), Microsoft PowerPoint or other special presentation files, database files, and audio/visual files. Provide an image of a Bates numbered slip sheet indicating the presence of a native file, and include the path to the native as a field in the .dat file. Name the produced native file with the Bates number corresponding to the slip sheet for the file. Group native files within incrementally named \"NATIVE\" directories, separate from images directories.\n- e. De-duplication. Produce a single copy of each electronic document for which exact duplicates exist. For email messages, consolidate duplicates based on MD5 hash generated from the BCC, Body, CC, From, IntMsgID, To, and Attach properties. For email attachments and standalone electronic files, consolidate duplicates based on MD5 hash of the entire file.\n- f. Metadata. Produce extracted metadata for each document in the form of a Concordance compliant load file (.dat). The first line of the .DAT file must be a header row identifying the field names. The .DAT file must use the following Concordance default delimiters: Comma , ASCII character (020) Quote þ ASCII character (254)\n\nDate fields should be provided in the format: mm/dd/yyyy. Date and time fields must be two separate fields. Required metadata listed below:\n\n# Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 187 of 1063\n\n| Field Name   | Sample Data              | Description                                      |\n|--------------|--------------------------|--------------------------------------------------|\n| FIRSTBATES   | EDC0000001               | First Bates number of native file document/email |\n| LASTBATES    | EDC0000001               | Last Bates number of native file document/email  |\n|              |                          | **The LASTBATES field should be populated        |\n|              |                          | for single page                                  |\n| ATTACHRANGE  | EDC0000001<br>-          | Bates number of the first page of the parent     |\n|              | EDC0000015               | document to the Bates number of the last page of |\n|              |                          | the last attachment \"child\" document             |\n| BEGATTACH    | EDC0000001               | First Bates number of attachment range           |\n| ENDATTACH    | EDC0000015               | Last Bates number of attachment range            |\n| CUSTODIAN    | Smith, John              | Email: Mailbox where the email resided           |\n|              |                          | Native: Name of the individual or department     |\n|              |                          | from whose files the document<br>originated      |\n| FROM         | John Smith               | Email: Sender                                    |\n|              |                          | Native: Author(s) of document                    |\n|              |                          | **semi-colon should be used to separate          |\n|              |                          | multiple entries                                 |\n| TO           | Coffman, Janice; LeeW    | Recipient(s)                                     |\n|              | [mailto:LeeW@MSN.com]    | **semi-colon should be used to separate multiple |\n|              |                          | entries                                          |\n| CC           | Frank Thompson [mailto:  | Carbon copy recipient(s)                         |\n|              | frank_Thompson@cdt.com]  | **semi-colon should be used to separate          |\n|              |                          | multiple entries                                 |\n| BCC          | John Cain                | Blind carbon copy recipient(s)                   |\n|              |                          | **semi-colon should be used to separate          |\n|              |                          | multiple entries                                 |\n| SUBJECT      | Board Meeting Minutes    | Email: Subject line of the email Native: Title   |\n|              |                          | of document (if available)                       |\n| FILE_NAME    | BoardMeetingMinutes.docx | Native: Name of the original native file,        |\n|              |                          | including extension                              |\n| DATE_SENT    | 10/12/2010               | Email: Date the email was sent                   |\n|              |                          | Native: (empty)                                  |\n| TIME_SENT/   | 07:05 PM GMT             | Email: Time the email was sent/ Time zone in     |\n| TIME_ZONE    |                          | which the emails were standardized               |\n| TIME_ZONE    | GMT                      | The<br>time zone in which<br>the emails<br>were  |\n|              |                          | standardized during conversion.                  |\n| LINK         |  EDC0000001.msg   | Hyperlink to the email or native file document   |\n|              |                          | **The linked file must be named per the          |\n|              |                          | FIRSTBATES number                                |\n| FILE_EXTEN   | MSG                      | The file type extension                          |\n|              |                          | representing                                     |\n|              |                          | the Email or                                     |\n| AUTHOR       | John Smith               | Email: (empty)                                   |\n|              |                          | Native: Author of the document                   |\n| DATE_CREATED | 10/10/2010               | Email: (empty)                                   |\n|              |                          | Native: Date the document was created            |\n\n# Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 188 of 1063\n\n| TIME_CREATED | 10:25 AM                  | Email: (empty)                                  |\n|--------------|---------------------------|-------------------------------------------------|\n|              |                           | Native: Time the document was created           |\n|              |                           | **This data must be a separate field and cannot |\n|              |                           | be combined with the DATE_CREATED field         |\n| DATE_MOD     | 10/12/2010                | Email: (empty)                                  |\n|              |                           | Native: Date the document was last modified     |\n| TIME_MOD     | 07:00 PM                  | Email: (empty)                                  |\n|              |                           | Native: Time the document was last modified     |\n|              |                           | **This data must be a separate field and cannot |\n|              |                           | be combined with the DATE_MOD field             |\n| DATE_ACCESSD | 10/12/2010                | Email: (empty)                                  |\n|              |                           | Native: Date the document was last accessed     |\n| TIME_ACCESSD | 07:00 PM                  | Email: (empty)                                  |\n|              |                           | Native: Time the document was last accessed     |\n|              |                           | **This data must be a separate field and cannot |\n|              |                           | be combined with the DATE_ACCESSD field         |\n| FILE_SIZE    | 5,952                     | Size of native file<br>document/email in KB     |\n| PGCOUNT      | 1                         | Number of pages in native file document/email   |\n| PATH         |   | Email: (empty)                                  |\n|              | Agenda.doc                | Native: Path where native file document was     |\n|              |                           | stored including original file name.            |\n| INTFILEPATH  | Personal Folders\\Deleted  | Email: original location of email including     |\n|              | Items\\Board Meeting       | original file name.                             |\n|              | Minutes.msg               | Native: (empty)                                 |\n| INTMSGID     | <000805c2c71b\\$75977050\\$ | Email: Unique Message ID Native: (empty)        |\n|              | cb8306d1@MSN>             |                                                 |\n| MD5HASH      | d131dd02c5e6eec4693d9a0   | MD5 Hash value of the document.                 |\n|              | 698aff95c                 |                                                 |\n|              | 2fcab58712467eab4004583e  |                                                 |\n|              | b8fb7f89                  |                                                 |\n| OCRPATH      | TEXT/001/EDC0000001.txt   | Path to extracted text of the native file       |\n\n3. Each Request operates and should be construed independently and, unless otherwise indicated, no Request limits the scope of any other Request.\n\n4. All Documents are to be produced as kept in the usual course of business or are to be organized and labeled to correspond with the categories in these Requests.\n\n5. Each Request contained herein extends to all Documents: (a) in Your possession, custody, or control; or (b) in the possession, custody, or control of anyone acting on Your behalf,\n\n#### Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 189 of 1063\n\nincluding Your counsel or other representatives and advisors. Each Document shall be produced in its entirety.\n\n6. If You are requested to produce a Document that is no longer in Your possession, custody, or control, then Your response must (a) describe in detail the nature of the document and its contents; (b) identify the person(s) who prepared or authored the Document (and, if applicable, the Person(s) to whom the Document was sent); (c) identify the date on which the document was prepared or created; (d) state whether such Document (i) is missing or lost, (ii) has been destroyed, (iii) has been transferred, voluntarily or involuntarily, to others, or (iv) was otherwise disposed of; (e) state the reason for, and the facts and circumstances surrounding, such disposition; (f) identify the Persons who authorized such disposition; (g) identify the date or approximate date of such disposition; (h) state when the Document was most recently in Your possession, custody or control; and (i) identify the Person, if any, presently in possession, custody, or control of such Document.\n\n7. If You are requested to produce a Document that has been destroyed, then Your response must state, in addition to the information required by the preceding Instruction: (a) the reason for the Document's destruction; (b) the identity of the Person who destroyed the Document; and (c) the identity of the Person who directed that the Document be destroyed.\n\n8. If You claim that a requested Document is privileged or attorney work-product, then Your response must: (a) state (i) a description of the Document adequate to support Your contention that the Document is privileged, (ii) the title of the Document, (iii) the date of the Document, (iv) the author of the Document, (v) the addressee of the Document, (vi) the identity of each Person who received or saw the original or any draft, copy, or reproduction of the Document, (vii) whether the Document itself, or any information contained or referred to in the Document is in the possession, custody, or control of any other Persons, and if so, the identity of\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 190 of 1063\n\nsuch Persons, as well as a statement addressing how the information came into their possession, (viii) the claim of privilege under which the Document is withheld, and (ix) all of the circumstances upon which You will rely to support such claim of privilege; and (b) produce a privilege log containing all of the information requested in Part (a) of this Instruction for each Document withheld on the basis of a claim of privilege in accordance with D. Conn. L. Civ. R. 26(e).\n\n9. If a portion of an otherwise responsive Document contains information subject to a claim of privilege, only that portion of the Document subject to the claim of privilege shall be deleted or redacted from the Document following the instructions above, and the rest shall be produced.\n\n10. The Requests are continuing in nature. You are hereby instructed to (a) supplement or correct any responses later learned to be incomplete or incorrect immediately upon learning that a prior response was incomplete or incorrect; and (b) produce any additional Documents that are called for under the\n\n11. If a Document is in a language other than English, You should provide that Document. If a Document is in a language other than English, and an English translation exists, You should provide both Documents.\n\n12. All references to Entities includes all affiliates thereof.\n\n13. All references to individual names include all alternative names, aliased, or nicknames.\n\n14. Unless otherwise expressly indicated, the period of time covered by the Document Requests is the period from February 5, 2012 to the date responses to the Document Requests are due.\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 191 of 1063\n\n#### **II. RULES OF CONSTRUCTION**\n\n15. The use of (a) any singular noun shall be construed to include the plural, and vice versa, and (b) a verb in any tense shall be construed as the use of the verb in all other tenses.\n\n16. The terms (a) \"and\" and \"or\" shall be construed either conjunctively or disjunctively as necessary to bring within the scope of any request all responses that might otherwise be construed to be outside of its scope, and (b) \"each\" and \"any\" shall be deemed to include and encompass the words \"every\" and \"all.\"\n\n#### **III. DEFINITIONS**\n\nThe definitions supplied by D. Conn. L. Civ. R. 26(c) and the rules of construction supplied by D. Conn. L. Civ. R. 26(d), as incorporated by D. Conn. Bankr. L.R. 2004-1(a), shall apply to the Document Requests. In addition, the following terms used in these Document Requests shall have the following meanings:\n\n1. \"You\" or \"Your\" or \"Yourself\" means and refers to Min Yang (a/k/a Yang Min), together with all of her agents, attorneys, representatives, employees, and/or anyone acting on her behalf.\n\n2. \"Debtor\" means Ho Wan Kwok (a/k/a Miles Kwok, Miles Guo, Guo Wengui, Guo Haoyun, 郭文贵, or any other alias), together with his employees, agents, counsel, advisors, or anyone acting on his behalf.\n\n3. \"Debtor's Son\" means Qiang Guo (a/k/a Mileson Kwok, 郭强, or any other alias), together with his employees, agents, counsel, advisors, or anyone acting on his behalf.\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 192 of 1063\n\n4. \"Debtor's Daughter\" means Mei Guo (a/k/a Mei Gui, 郭美, or any other alias), together with her employees, agents, counsel, advisors, or anyone acting on her behalf.\n\n5. \"Debtor's Purported Wife\" means Hing Chi Ngok (a/k/a Hing Chi Ng, Yue Qingzhi, 岳庆芝, or any other alias), together with her employees, agents, counsel, advisors, or anyone acting on her behalf.\n\n6. \"Debtor's Family\" means, collectively, the Debtor, the Debtor's Son, the Debtor's Daughter, and the Debtor's Purported Wife, and any other familial relation to the Debtor.\n\n7. \"Associated Individuals\" means, individually and collectively, all individuals that (1) hold, control, have custody over, or discretion over assets owned, controlled, or enjoyed by the Debtor or the Debtor's Family; or (2) have been employees, directors, or otherwise are affiliated with one or more Associated Entities, together with the respective employees, agents, counsel, advisors, or anyone acting on behalf of any of the foregoing. Such Associated Individuals shall include, but are not limited to: Daniel Podhaskie, Jason Miller, Steve Bannon, Karin Maistrello, Melissa Francis, Anthony DiBattista, William Gertz, Arethusa Forsyth, Glenn Mellor, Jennifer Mercurio, Eduardo Eurnekian, Wencong Wang, Han Chunguang (a/k/a 韩春光), Qu Guojiao (a/k/a Qu Guo Jiao, 屈国姣), Guo Lijie (a/k/a 郭丽杰), Zhang Wei (a/k/a 张伟\\*), Lihong Wei Lafrenz (a/k/a Sara Wei, 魏丽红), Hao Haidong (a/k/a 郝海东), Ross Heinemeyer, Max Krasner, Kyle Bass, Melissa Mendez, Ya Li (a/k/a 李娅), Dinggang Wang (a/k/a 王定刚), An Hong (a/k/a 安红), Yvette Wang (a/k/a Yanping Wang, Yan Ping Wang, 王雁平), Fiona Yu, Je Kin Ming (a/k/a William Je, Yu Jianming, 余建明), Yaz Qingua, and Lao Jiang (a/k/a Jiang Yunfu, Jiang Yunfu Be, 姜云浮).\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 193 of 1063\n\n8. \"Associated Entities\" means, individually and collectively, all organizations or Entities of any type that (1) have been owned, controlled, or invested in by the Debtor or the Debtor's Family; or (2) have an interest, whether directly or indirectly, in any assets owned, controlled, or enjoyed by the Debtor or the Debtor's Family, together with the respective employees, agents, counsel, advisors, or anyone acting on behalf of any of the foregoing. Such Associated Entities shall include, but are not limited to: 7 Nod Hill LLC, AAGV Limited, ACA Investment Management Limited, ACA Capital Group Limited, Ace Decade Holdings Limited, AI Group Holdings Inc., Alfa Global Ventures Limited, Alfonso Global Limited, Allied Capital Global Limited, Alpine Fiduciaries SA, Anton Development Limited, Assets Sino Limited, Auspicious Coast Limited, Beijing Pangu Investment Co., Beijing Pangu Investment Co. Ltd., Beijing Pangu Investment Inc., Beijing Zenith Holdings Company Limited, Booming Sail New York LLC, Bravo Luck Limited, BSA Strategic Fund I, China Golden Spring (Hong Kong) Limited, Chuang Xin Limited, Crane Advisory Group LLC, Creative Apex Investments Limited, Crystal Breeze Investments Limited, Dawn State Limited, Eastern Profit Corporation Limited, Elite Well Global Limited, Empire Growth Holdings, Freedom Media Ventures Ltd., G Club Operations LLC, G Fashion LLC, G News LLC, GETTR USA, Genever Holdings Corporation, Genever Holdings LLC, Gfashion Media Group Inc., GFNY, Inc., Globalist International Limited, GNews Media Group Inc., Golden Spring (New York) Ltd., Greenwich Land LLC, Guo Media, GTV Media Group, Inc., Hamilton Capital Holdings Inc., HCHK Property Management, Inc., HCHK Technologies, Inc., Head Win Group Limited, Henan Yuda, Himalaya Embassy, Himalaya Exchange, Himalaya Federal Reserve, Himalaya Investment LLC, Himalaya International, Himalaya New World Inc., Himalaya Supervisory Organization, Himalaya Ventures LLC, HK International Funds Investments (USA) Limited LLC, Hong Kong International Funds\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 194 of 1063\n\nInvestments Limited, Hudson Diamond Holding, Infinite Increase Limited, Infinitum Developments Limited, Infinity Treasury Management Inc., Insight Phoenix Fund, Lamp Capital LLC, Leading Shine Limited, Leading Shine NY Limited, Lexington Property and Staffing, Long Gate Limited, Maywind Trading LLC, MOS Himalaya LLC, Next Tycoon Investments Limited, New Federal State of China (a/k/a NFSC), Noble Fame Global Limited, Rosy Acme Ventures Limited, Rule of Law Foundation III, Inc., Rule of Law Foundation IV, Inc., Rule of Law Fund, Rule of Law Society, Rule of Law Society IV, Inc., G-Translators PTY LTD, Saraca Media Group, Inc., Shiny Ace Ltd., Shiny Times Holdings Ltd., Spirit Charter Investment Limited, Stevenson, Wong & Co., Voice of Guo Media, Inc., Well Origin Ltd., World Century Limited, Worldwide Opportunity Holdings Limited, Whitecroft Shore Limited, and ZIBA Limited.\n\n9. \"Including\" or any variant thereof means \"including without limitation.\"\n\n10. \"And\" and \"or\" mean \"and/or,\" and shall be construed both conjunctively as well as disjunctively in order to maximize their scope.\n\n11. \"Any\" and \"all\" and \"each\" mean \"each and every.\"\n\n12. \"Each\" and \"every\" mean \"each and every.\"\n\n13. \"Third Party\" means a Person or Entity other than Yourself.\n\n14. \"Transfer\" shall have the meaning given to it by section 101(54) of the Bankruptcy Code.\n\n15. \"Document\" means any information or thing within the scope of Fed. R. Civ. P. 34, and includes, without limitation, each and every written, recorded, or graphic matter of any kind, type, nature, or description that is or has been in Your Possession, Custody or Control, including all printed and electronic copies of electronic mail, computer files maintained in\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 195 of 1063\n\nelectronic form, electronic communication, text message, social media post, tweet, meta-data, correspondence, memoranda, tapes, stenographic or handwritten notes, written forms of any kind, charts, blueprints, drawings, sketches, graphs, plans, articles, specifications, diaries, letters, telegrams, photographs, minutes, contracts, agreements, surveys, computer printouts, data compilations of any kind, telexes, facsimiles, voice messages, invoices, order forms, checks, drafts, statements, credit memos, reports, position reports, summaries, indices, books, ledgers, notebooks, schedules, transparencies, recordings, catalogs, advertisements, promotional materials, films, video tapes, audio tapes, CDs, computer disks, brochures, pamphlets, punchcards, time-slips, Tweets, social media posts, or any written or recorded materials of any other kind, and all meta-data thereof, however stored (whether in tangible or electronic form), recorded, produced, or reproduced, and also including but not limited to, drafts or copies of any of the foregoing that contain any notes, comments, or markings of any kind not found on the original documents or that are otherwise not identical to the original documents.\n\n16. \"Person(s)\" means an individual, corporation, proprietorship, partnership, association, or any other Entity. \"Person\" also includes any agent, representatives, or expert, including but not limiting to, attorneys or financial advisors.\n\n17. \"Entity\" means any natural Person, corporation, partnership, subsidiary, sole proprietorship, firm, board, joint venture, association, agency, authority, commission or other business entity or juristic Person, as well as any affiliate, agent, parent including but not limited to legal counsel, financial advisors, or any other representative.\n\n18. \"Regarding\" means concerning, describing, comprising, referring to, related to, supporting, favoring, opposing, bolstering, detracting from, located in, considered in connection with, bearing on, evidencing, indicating, reporting on, recording, alluding to, responding to,\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 196 of 1063\n\nconnected with, commenting on, in respect of, about, in relation to, discussing, showing, describing, reflecting, analyzing constituting, and being.\n\n19. \"Relating to,\" \"relate(s) to\" or \"related to,\" when referring to any given subject matter, means, without limitation, any document that constitutes, comprises, involves, contains, embodies, reflects, identifies, states, refers directly or indirectly to, or is in any way relevant to the particular subject matter identified.\n\n20. \"Communication(s)\" means, in the broadest possible sense, and without limitation, any transmittal of information or knowledge (in the form of facts, ideas, inquiries, or otherwise). Communication(s) further refers to all conversations, agreements, inquiries, or replies, whether in person, by telephone, in writing, or by means of electronic transmittal devices, and includes, but is not limited to, all correspondence, emails, recordings, transmittal slips, memoranda, telephone communications, voice messages, telegrams, telefaxes, telecopies, telexes, instant messages, chats, text messages, telephonic notes, or notes transmitted internally or with third parties.\n\n21. \"Asset(s)\" means any item that can be used to produce positive economic value, including but not limited to any resource with economic value that is owned, controlled or is for the benefit of an entity, that is expected to provide a future benefit, including but not limited to, all real and personal property, intangible property, investments, rights to invest or to future revenue, cash, bank accounts, commodities, securities, claims, total or partial control of an entity, and prospective economic opportunities\n\n22. \"Transfer\" shall have the meaning given to it by section 101(54) of the Bankruptcy Code.\n\n#### **IV. DOCUMENTS TO BE PRODUCED**\n\n1. All Communications with the Debtor, and Documents related to Communications with the Debtor.\n\n2. All Documents related to Rule of Law Foundation III, Inc. and Rule of Law Society IV, Inc., New Federal State of China, Himalaya Alliance, and Himalaya Farms.\n\n3. All Documents related to transfers of funds related to Rule of Law Foundation III, Inc., Rule of Law Society IV, Inc., New Federal State of China, Himalaya Alliance, Himalaya Farms or any other Associated Entity.\n\n4. All Documents regarding any investment, business dealing or transactions made by, with, or on behalf of the Debtor.\n\n5. All Communications with the Debtor, the Debtor's Family or Associated Individuals, and Documents related to Communications with the Debtor, the Debtor's Family or Associated Individuals, related to the operation, management, or decision-making of any legal entity, including without limitation Rule of Law Foundation III, Inc., Rule of Law Society IV, Inc., New Federal State of China, Himalaya Alliance, Himalaya Farms, the Family Related Entities and the Associated Entities.\n\n# Exhibit C-10\n\n#### B2540 (Form 2540 – Subpoena for Rule 2004 Examination) (12/15) Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 199 of\n\nUNITED STATES BANKRUPTCY COURT 1063\n\n**District of Connecticut**\n\nIn re HO WAN KWOK, *et al*.,\n\n<sup>1</sup> Case No. 22-50073 (JAM)\n\nDebtor Chapter 11\n\n(Jointly Administered)\n\n## **SUBPOENA FOR RULE 2004 EXAMINATION**\n\nTo: **Alex Hadjicharalambous**\n\n(*Name of person to whom the subpoena is directed*)\n\n*Testimony:* **YOU ARE COMMANDED** to appear at the time, date, and place set forth below to testify at an examination under Rule 2004, Federal Rules of Bankruptcy Procedure. A copy of the court order authorizing the examination is attached.\n\n| PLACE                    | DATE AND TIME |\n|--------------------------|---------------|\n| Paul Hastings LLP        |               |\n| 200 Park Avenue          | [TBD]         |\n| New York, New York 10166 |               |\n|                          |               |\n\nThe examination will be recorded by this method: **Court reporter/stenographer**\n\n*Production:* You, or your representatives, must also bring with you to the examination the following documents, electronically stored information, or objects, and must permit inspection, copying, testing, or sampling of the material:\n\n#### **See Requests for Production of Documents, attached hereto.**\n\nThe following provisions of Fed. R. Civ. P. 45, made applicable in bankruptcy cases by Fed. R. Bankr. P. 9016, are attached – Rule 45(c), relating to the place of compliance; Rule 45(d), relating to your protection as a person subject to a subpoena; and Rule 45(e) and 45(g), relating to your duty to respond to this subpoena and the potential consequences of not doing so.\n\nDate: **March , 2023**\n\nCLERK OF COURT\n\nOR\n\n*Signature of Clerk or Deputy Clerk Attorney's signature*\n\nThe name, address, email address, and telephone number of the attorney representing Luc A. Despins, Chapter 11 Trustee, who issues or requests this subpoena, are:\n\n**Douglas S. Skalka, Esq.; Neubert, Pepe & Monteith, P.C.; 195 Church Street, New Haven, Connecticut 06510 dskalka@npmlaw.com; (203) 821-2000**\n\n**Notice to the person who issues or requests this subpoena**\n\nIf this subpoena commands the production of documents, electronically stored information, or tangible things, or the inspection of premises before trial, a notice and a copy of this subpoena must be served on each party before it is served on the person to whom it is directed. Fed. R. Civ. P. 45(a)(4).\n\nSoftware Copyright (c) 1996-2022 Best Case, LLC - www.bestcase.com Best Case Bankruptcy 1 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\n#### **PROOF OF SERVICE**\n\n**(This section should not be filed with the court unless required by Fed. R. Civ. P. 45.)**\n\nI received this subpoena for (*name of individual and title, if any*): on (*date*) .\n\nI served the subpoena by delivering a copy to the named person as follows:\n\non *(date)* ; or\n\nI returned the subpoena unexecuted because:\n\nUnless the subpoena was issued on behalf of the United States, or one of its officers or agents, I have also tendered to the witness the fees for one day's attendance, and the mileage allowed by law, in the amount of \\$ .\n\nMy fees are \\$ for travel and \\$ for services, for a total of \\$ .\n\nI declare under penalty of perjury that this information is true and correct.\n\nDate:\n\n*Server's signature*\n\n*Printed name and title*\n\n*Server's address*\n\nAdditional information concerning attempted service, etc.:\n\n#### **Federal Rule of Civil Procedure 45(c), (d), (e), and (g) (Effective 12/1/13) (made applicable in bankruptcy cases by Rule 9016, Federal Rules of Bankruptcy Procedure)**\n\n#### **(c) Place of compliance.**\n\n*(1) For a Trial, Hearing, or Deposition.* A subpoena may command a person to attend a trial, hearing, or deposition only as follows:\n\n(A) within 100 miles of where the person resides, is employed, or regularly transacts business in person; or\n\n(B) within the state where the person resides, is employed, or regularly transacts business in person, if the person\n\n(i) is a party or a party's officer; or\n\n(ii) is commanded to attend a trial and would not incur substantial expense.\n\n*(2) For Other Discovery.* A subpoena may command:\n\n(A) production of documents, or electronically stored information, or things at a place within 100 miles of where the person resides, is employed, or regularly transacts business in person; and\n\n(B) inspection of premises, at the premises to be inspected.\n\n#### **(d) Protecting a Person Subject to a Subpoena; Enforcement.**\n\n*(1) Avoiding Undue Burden or Expense; Sanctions.* A party or attorney responsible for issuing and serving a subpoena must take reasonable steps to avoid imposing undue burden or expense on a person subject to the subpoena. The court for the district where compliance is required must enforce this duty and impose an appropriate sanction which may include lost earnings and reasonable attorney's fees — on a party or attorney who fails to comply.\n\n#### *(2) Command to Produce Materials or Permit Inspection.*\n\n*(A) Appearance Not Required.* A person commanded to produce documents, electronically stored information, or tangible things, or to permit the inspection of premises, need not appear in person at the place of production or inspection unless also commanded to appear for a deposition, hearing, or trial.\n\n*(B) Objections.* A person commanded to produce documents or tangible things or to permit inspection may serve on the party or attorney designated in the subpoena a written objection to inspecting, copying, testing or sampling any or all of the materials or to inspecting the premises — or to producing electronically stored information in the form or forms requested. The objection must be served before the earlier of the time specified for compliance or 14 days after the subpoena is served. If an objection is made, the following rules apply:\n\n(i) At any time, on notice to the commanded person, the serving party may move the court for the district where compliance is required for an order compelling production or inspection.\n\n(ii) These acts may be required only as directed in the order, and the order must protect a person who is neither a party nor a party's officer from significant expense resulting from compliance.\n\n#### *(3) Quashing or Modifying a Subpoena.*\n\n*(A) When Required.* On timely motion, the court for the district where compliance is required must quash or modify a subpoena that:\n\n(i) fails to allow a reasonable time to comply;\n\n(ii) requires a person to comply beyond the geographical limits specified in Rule 45(c);\n\n(iii) requires disclosure of privileged or other protected matter, if no exception or waiver applies; or\n\n(iv) subjects a person to undue burden.\n\n*(B) When Permitted.* To protect a person subject to or affected by a subpoena, the court for the district where compliance is required may, on motion, quash or modify the subpoena if it requires:\n\n(i) disclosing a trade secret or other confidential research, development, or commercial information; or\n\n(ii) disclosing an unretained expert's opinion or information that does not describe specific occurrences in dispute and results from the expert's study that was not requested by a party.\n\n(C) *Specifying Conditions as an Alternative.* In the circumstances described in Rule 45(d)(3)(B), the court may, instead of quashing or modifying a subpoena, order appearance or production under specified conditions if the serving party:\n\n(i) shows a substantial need for the testimony or material that cannot be otherwise met without undue hardship; and\n\n(ii) ensures that the subpoenaed person will be reasonably compensated.\n\n#### **(e) Duties in Responding to a Subpoena.**\n\n*(1) Producing Documents or Electronically Stored Information.* These procedures apply to producing documents or electronically stored information:\n\n*(A) Documents.* A person responding to a subpoena to produce documents must produce them as they are kept in the ordinary course of business or must organize and label them to correspond to the categories in the demand.\n\n*(B) Form for Producing Electronically Stored Information Not Specified.* If a subpoena does not specify a form for producing electronically stored information, the person responding must produce it in a form or forms in which it is ordinarily maintained or in a reasonably usable form or forms.\n\n*(C) Electronically Stored Information Produced in Only One Form.* The person responding need not produce the same electronically stored information in more than one form.\n\n*(D) Inaccessible Electronically Stored Information.* The person responding need not provide discovery of electronically stored information from sources that the person identifies as not reasonably accessible because of undue burden or cost. On motion to compel discovery or for a protective order, the person responding must show that the information is not reasonably accessible because of undue burden or cost. If that showing is made, the court may nonetheless order discovery from such sources if the requesting party shows good cause, considering the limitations of Rule 26(b)(2)(C). The court may specify conditions for the discovery.\n\n#### *(2) Claiming Privilege or Protection.*\n\n*(A) Information Withheld.* A person withholding subpoenaed information under a claim that it is privileged or subject to protection as trial-preparation material must: (i) expressly make the claim; and\n\n(ii) describe the nature of the withheld documents, communications, or tangible things in a manner that, without revealing information itself privileged or protected, will enable the parties to assess the claim.\n\n*(B) Information Produced.* If information produced in response to a subpoena is subject to a claim of privilege or of protection as trial-preparation material, the person making the claim may notify any party that received the information of the claim and the basis for it. After being notified, a party must promptly return, sequester, or destroy the specified information and any copies it has; must not use or disclose the information until the claim is resolved; must take reasonable steps to retrieve the information if the party disclosed it before being notified; and may promptly present the information under seal to the court for the district where compliance is required for a determination of the claim. The person who produced the information must preserve the information until the claim is resolved.\n\n**(g) Contempt.** The court for the district where compliance is required – and also, after a motion is transferred, the issuing court – may hold in contempt a person who, having been served, fails without adequate excuse to obey the subpoena or an order related to it.\n\nFor access to subpoena materials, see Fed.R.Civ.P.45(a) Committee Note (2013)\n\n…\n\n## **Request for Production of Documents**\n\n## **I. INSTRUCTIONS**\n\n1. Unless otherwise indicated, the requests for documents set forth below, (the \"Requests,\" and each, a \"Request\"), must be responded to separately and specifically. Each Request shall be answered fully unless it is in good faith objected to, in which event the reason for Your objection shall be stated in detail, as set forth below. If an objection pertains only to a portion of a Request, or a word, phrase or clause contained within it, You are required to state Your objection to that portion only and to respond to the remainder of the Requests.\n\n2. Electronically stored information must be produced in accordance with the\n\nfollowing instructions:\n\n- a. Images. Black and white images must be 300 DPI Group IV single-page TIFF files. Color images must be produced in JPEG format. File names cannot contain embedded spaces or special characters (including the comma). Folder names cannot contain embedded spaces or special characters (including the comma). All TIFF image files must have a unique file name, i.e. Bates number. Images must be endorsed with sequential Bates numbers in the lower right corner of each image. The number of TIFF files per folder should not exceed 1000 files. Excel spreadsheets should have a placeholder image named by the Bates number of the file.\n- b. Image Load File\n\t- a. Concordance® Data File. The data file (.DAT) contains all of the fielded information that will be loaded into the Concordance® database. The first line of the .DAT file must be a header row identifying the field names. The .DAT file must use the following Concordance® default delimiters: Comma ASCII character (020) Quote þ ASCII character (254). Date fields should be provided in the format: mm/dd/yyyy. Date and time fields must be two separate fields. If documents includes imaged emails and attachments, the attachment fields must be included to preserve the parent/child relationship between an email and its attachments. An OCRPATH field must be included to provide the file path and name of the extracted text file on the produced storage media. The text file must be named after the FIRSTBATES. Do not include the text in the .DAT file. For Documents with native files, a LINK field must be included to provide the file path and\n\nname of the native file. The native file must be named after the FIRSTBATES.\n\n- b. Concordance Image® OR Opticon Cross-Reference File. The image crossreference file (.LOG or .OPT) links the images to the database records. It should be a comma-delimited file consisting of seven fields per line with a line in the cross-reference file for every image in the database with the following format: ImageID,VolumeLabel,ImageFilePath,DocumentBreak,FolderBreak,Box Break,PageCoun.\n- c. Document Text. Text must be produced as separate text files, not as fields within the .DAT file. The full path to the text file (OCRPATH) should be included in the .DAT file. It is recommended document level ANSI text files, named per the FIRSTBATES/Image Key. Extracted text files must be in a separate folder, and the number of text files per folder should not exceed 1,000 files. There should be no special characters (including commas in the folder names). Text files must be provided on a document level.\n- d. Native Production for Certain File Types. File types that reasonably require viewing in their native format for a full understanding of their content and meaning must be produced in native format. These include, but are not limited to, spreadsheets, spreadsheet-like files (Microsoft Excel, comma separated values, tab separated values, etc.), Microsoft PowerPoint or other special presentation files, database files, and audio/visual files. Provide an image of a Bates numbered slip sheet indicating the presence of a native file, and include the path to the native as a field in the .dat file. Name the produced native file with the Bates number corresponding to the slip sheet for the file. Group native files within incrementally named \"NATIVE\" directories, separate from images directories.\n- e. De-duplication. Produce a single copy of each electronic document for which exact duplicates exist. For email messages, consolidate duplicates based on MD5 hash generated from the BCC, Body, CC, From, IntMsgID, To, and Attach properties. For email attachments and standalone electronic files, consolidate duplicates based on MD5 hash of the entire file.\n- f. Metadata. Produce extracted metadata for each document in the form of a Concordance compliant load file (.dat). The first line of the .DAT file must be a header row identifying the field names. The .DAT file must use the following Concordance default delimiters: Comma , ASCII character (020) Quote þ ASCII character (254)\n\nDate fields should be provided in the format: mm/dd/yyyy. Date and time fields must be two separate fields. Required metadata listed below:\n\n# Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 204 of 1063\n\n| Field Name   | Sample Data              | Description                                      |\n|--------------|--------------------------|--------------------------------------------------|\n| FIRSTBATES   | EDC0000001               | First Bates number of native file document/email |\n| LASTBATES    | EDC0000001               | Last Bates number of native file document/email  |\n|              |                          | **The LASTBATES field should be populated        |\n|              |                          | for single page                                  |\n| ATTACHRANGE  | EDC0000001<br>-          | Bates number of the first page of the parent     |\n|              | EDC0000015               | document to the Bates number of the last page of |\n|              |                          | the last attachment \"child\" document             |\n| BEGATTACH    | EDC0000001               | First Bates number of attachment range           |\n| ENDATTACH    | EDC0000015               | Last Bates number of attachment range            |\n| CUSTODIAN    | Smith, John              | Email: Mailbox where the email resided           |\n|              |                          | Native: Name of the individual or department     |\n|              |                          | from whose files the document<br>originated      |\n| FROM         | John Smith               | Email: Sender                                    |\n|              |                          | Native: Author(s) of document                    |\n|              |                          | **semi-colon should be used to separate          |\n|              |                          | multiple entries                                 |\n| TO           | Coffman, Janice; LeeW    | Recipient(s)                                     |\n|              | [mailto:LeeW@MSN.com]    | **semi-colon should be used to separate multiple |\n|              |                          | entries                                          |\n| CC           | Frank Thompson [mailto:  | Carbon copy recipient(s)                         |\n|              | frank_Thompson@cdt.com]  | **semi-colon should be used to separate          |\n|              |                          | multiple entries                                 |\n| BCC          | John Cain                | Blind carbon copy recipient(s)                   |\n|              |                          | **semi-colon should be used to separate          |\n|              |                          | multiple entries                                 |\n| SUBJECT      | Board Meeting Minutes    | Email: Subject line of the email Native: Title   |\n|              |                          | of document (if available)                       |\n| FILE_NAME    | BoardMeetingMinutes.docx | Native: Name of the original native file,        |\n|              |                          | including extension                              |\n| DATE_SENT    | 10/12/2010               | Email: Date the email was sent                   |\n|              |                          | Native: (empty)                                  |\n| TIME_SENT/   | 07:05 PM GMT             | Email: Time the email was sent/ Time zone in     |\n| TIME_ZONE    |                          | which the emails were standardized               |\n| TIME_ZONE    | GMT                      | The<br>time zone in which<br>the emails<br>were  |\n|              |                          | standardized during conversion.                  |\n| LINK         |  EDC0000001.msg   | Hyperlink to the email or native file document   |\n|              |                          | **The linked file must be named per the          |\n|              |                          | FIRSTBATES number                                |\n| FILE_EXTEN   | MSG                      | The file type extension                          |\n|              |                          | representing                                     |\n|              |                          | the Email or                                     |\n| AUTHOR       | John Smith               | Email: (empty)                                   |\n|              |                          | Native: Author of the document                   |\n| DATE_CREATED | 10/10/2010               | Email: (empty)                                   |\n|              |                          | Native: Date the document was created            |\n\n# Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 205 of 1063\n\n| TIME_CREATED | 10:25 AM                  | Email: (empty)                                  |\n|--------------|---------------------------|-------------------------------------------------|\n|              |                           | Native: Time the document was created           |\n|              |                           | **This data must be a separate field and cannot |\n|              |                           | be combined with the DATE_CREATED field         |\n| DATE_MOD     | 10/12/2010                | Email: (empty)                                  |\n|              |                           | Native: Date the document was last modified     |\n| TIME_MOD     | 07:00 PM                  | Email: (empty)                                  |\n|              |                           | Native: Time the document was last modified     |\n|              |                           | **This data must be a separate field and cannot |\n|              |                           | be combined with the DATE_MOD field             |\n| DATE_ACCESSD | 10/12/2010                | Email: (empty)                                  |\n|              |                           | Native: Date the document was last accessed     |\n| TIME_ACCESSD | 07:00 PM                  | Email: (empty)                                  |\n|              |                           | Native: Time the document was last accessed     |\n|              |                           | **This data must be a separate field and cannot |\n|              |                           | be combined with the DATE_ACCESSD field         |\n| FILE_SIZE    | 5,952                     | Size of native file<br>document/email in KB     |\n| PGCOUNT      | 1                         | Number of pages in native file document/email   |\n| PATH         |   | Email: (empty)                                  |\n|              | Agenda.doc                | Native: Path where native file document was     |\n|              |                           | stored including original file name.            |\n| INTFILEPATH  | Personal Folders\\Deleted  | Email: original location of email including     |\n|              | Items\\Board Meeting       | original file name.                             |\n|              | Minutes.msg               | Native: (empty)                                 |\n| INTMSGID     | <000805c2c71b\\$75977050\\$ | Email: Unique Message ID Native: (empty)        |\n|              | cb8306d1@MSN>             |                                                 |\n| MD5HASH      | d131dd02c5e6eec4693d9a0   | MD5 Hash value of the document.                 |\n|              | 698aff95c                 |                                                 |\n|              | 2fcab58712467eab4004583e  |                                                 |\n|              | b8fb7f89                  |                                                 |\n| OCRPATH      | TEXT/001/EDC0000001.txt   | Path to extracted text of the native file       |\n\n3. Each Request operates and should be construed independently and, unless otherwise indicated, no Request limits the scope of any other Request.\n\n4. All Documents are to be produced as kept in the usual course of business or are to be organized and labeled to correspond with the categories in these Requests.\n\n5. Each Request contained herein extends to all Documents: (a) in Your possession, custody, or control; or (b) in the possession, custody, or control of anyone acting on Your behalf,\n\n#### Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 206 of 1063\n\nincluding Your counsel or other representatives and advisors. Each Document shall be produced in its entirety.\n\n6. If You are requested to produce a Document that is no longer in Your possession, custody, or control, then Your response must (a) describe in detail the nature of the document and its contents; (b) identify the person(s) who prepared or authored the Document (and, if applicable, the Person(s) to whom the Document was sent); (c) identify the date on which the document was prepared or created; (d) state whether such Document (i) is missing or lost, (ii) has been destroyed, (iii) has been transferred, voluntarily or involuntarily, to others, or (iv) was otherwise disposed of; (e) state the reason for, and the facts and circumstances surrounding, such disposition; (f) identify the Persons who authorized such disposition; (g) identify the date or approximate date of such disposition; (h) state when the Document was most recently in Your possession, custody or control; and (i) identify the Person, if any, presently in possession, custody, or control of such Document.\n\n7. If You are requested to produce a Document that has been destroyed, then Your response must state, in addition to the information required by the preceding Instruction: (a) the reason for the Document's destruction; (b) the identity of the Person who destroyed the Document; and (c) the identity of the Person who directed that the Document be destroyed.\n\n8. If You claim that a requested Document is privileged or attorney work-product, then Your response must: (a) state (i) a description of the Document adequate to support Your contention that the Document is privileged, (ii) the title of the Document, (iii) the date of the Document, (iv) the author of the Document, (v) the addressee of the Document, (vi) the identity of each Person who received or saw the original or any draft, copy, or reproduction of the Document, (vii) whether the Document itself, or any information contained or referred to in the Document is in the possession, custody, or control of any other Persons, and if so, the identity of\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 207 of 1063\n\nsuch Persons, as well as a statement addressing how the information came into their possession, (viii) the claim of privilege under which the Document is withheld, and (ix) all of the circumstances upon which You will rely to support such claim of privilege; and (b) produce a privilege log containing all of the information requested in Part (a) of this Instruction for each Document withheld on the basis of a claim of privilege in accordance with D. Conn. L. Civ. R. 26(e). For any part of a Document Request as to which a claim of privilege or work product is not made, responsive documents should be provided in full.\n\n9. If a portion of an otherwise responsive Document contains information subject to a claim of privilege, only that portion of the Document subject to the claim of privilege shall be deleted or redacted from the Document following the instructions above, and the rest shall be produced.\n\n10. The Requests are continuing in nature. You are hereby instructed to (a) supplement or correct any responses later learned to be incomplete or incorrect immediately upon learning that a prior response was incomplete or incorrect; and (b) produce any additional Documents that are called for under the\n\n11. If a Document is in a language other than English, You should provide that Document. If a Document is in a language other than English, and an English translation exists, You should provide both Documents.\n\n12. All references to Entities includes all affiliates thereof.\n\n13. All references to individual names include all alternative names, aliased, or nicknames.\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 208 of 1063\n\n14. Unless otherwise expressly indicated, the period of time covered by the Document Requests is the period from February 5, 2012 to the date responses to the Document Requests are due.\n\n#### **II. RULES OF CONSTRUCTION**\n\n15. The use of (a) any singular noun shall be construed to include the plural, and vice versa, and (b) a verb in any tense shall be construed as the use of the verb in all other tenses.\n\n16. The terms (a) \"and\" and \"or\" shall be construed either conjunctively or disjunctively as necessary to bring within the scope of any request all responses that might otherwise be construed to be outside of its scope, and (b) \"each\" and \"any\" shall be deemed to include and encompass the words \"every\" and \"all.\"\n\n## **III. DEFINITIONS**\n\nThe definitions supplied by D. Conn. L. Civ. R. 26(c) and the rules of construction supplied by D. Conn. L. Civ. R. 26(d), as incorporated by D. Conn. Bankr. L.R. 2004-1(a), shall apply to the Document Requests. In addition, the following terms used in these Document Requests shall have the following meanings:\n\n1. \"You\" or \"Your\" or \"Yourself\" means and refers to Christodoulos G. Vassiliades & Co. LLC, together with any of his employees, agents, counsel, advisors, or anyone acting on its behalf.\n\n2. \"Debtor\" means Ho Wan Kwok (a/k/a Miles Kwok, Miles Guo, Guo Wengui, Guo Haoyun, 郭文贵, or any other alias), together with his employees, agents, counsel, advisors, or anyone acting on his behalf.\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 209 of 1063\n\n3. \"Debtor's Son\" means Qiang Guo (a/k/a Mileson Kwok, 郭强, or any other alias), together with his employees, agents, counsel, advisors, or anyone acting on his behalf.\n\n4. \"Debtor's Daughter\" means Mei Guo (a/k/a Mei Gui, 郭美, or any other alias), together with her employees, agents, counsel, advisors, or anyone acting on her behalf.\n\n5. \"Debtor's Purported Wife\" means Hing Chi Ngok (a/k/a Hing Chi Ng, Yue Qingzhi, 岳庆芝, or any other alias), together with her employees, agents, counsel, advisors, or anyone acting on her behalf.\n\n6. \"Debtor's Family\" means, collectively, the Debtor, the Debtor's Son, the Debtor's Daughter, and the Debtor's Purported Wife, and any other familial relation to the Debtor.\n\n7. \"Associated Individuals\" means, individually and collectively, all individuals that (1) hold, control, have custody over, or discretion over assets owned, controlled, or enjoyed by the Debtor or the Debtor's Family; or (2) have been employees, directors, or otherwise are affiliated with one or more Associated Entities, together with the respective employees, agents, counsel, advisors, or anyone acting on behalf of any of the foregoing. Such Associated Individuals shall include, but are not limited to: Daniel Podhaskie, Jason Miller, Steve Bannon, Karin Maistrello, Melissa Francis, Anthony DiBattista, William Gertz, Arethusa Forsyth, Glenn Mellor, Jennifer Mercurio, Eduardo Eurnekian, Wencong Wang, Han Chunguang (a/k/a 韩春光), Qu Guojiao (a/k/a Qu Guo Jiao, 屈国姣), Guo Lijie (a/k/a 郭丽杰), Zhang Wei (a/k/a 张伟\\*), Lihong Wei Lafrenz (a/k/a Sara Wei, 魏丽红), Hao Haidong (a/k/a 郝海东), Ross Heinemeyer, Max Krasner, Kyle Bass, Melissa Mendez, Ya Li (a/k/a 李娅), Dinggang Wang (a/k/a 王定刚), An Hong (a/k/a 安红), Yvette Wang (a/k/a Yanping Wang, Yan Ping Wang, 王雁平), Fiona Yu, Je Kin Ming\n\n#### Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 210 of 1063\n\n(a/k/a William Je, Yu Jianming, 余建明), Yaz Qingua, and Lao Jiang (a/k/a Jiang Yunfu, Jiang Yunfu Be, 姜云浮).\n\n8. \"Associated Entities\" means, individually and collectively, all organizations or Entities of any type that (1) have been owned, controlled, or invested in by the Debtor or the Debtor's Family; or (2) have an interest, whether directly or indirectly, in any assets owned, controlled, or enjoyed by the Debtor or the Debtor's Family, together with the respective employees, agents, counsel, advisors, or anyone acting on behalf of any of the foregoing. Such Associated Entities shall include, but are not limited to: 7 Nod Hill LLC, AAGV Limited, ACA Investment Management Limited, ACA Capital Group Limited, Ace Decade Holdings Limited, AI Group Holdings Inc., Alfa Global Ventures Limited, Alfonso Global Limited, Allied Capital Global Limited, Alpine Fiduciaries SA, Anton Development Limited, Assets Sino Limited, Auspicious Coast Limited, Beijing Pangu Investment Co., Beijing Pangu Investment Co. Ltd., Beijing Pangu Investment Inc., Beijing Zenith Holdings Company Limited, Booming Sail New York LLC, Bravo Luck Limited, BSA Strategic Fund I, China Golden Spring (Hong Kong) Limited, Chuang Xin Limited, Crane Advisory Group LLC, Creative Apex Investments Limited, Crystal Breeze Investments Limited, Dawn State Limited, Eastern Profit Corporation Limited, Elite Well Global Limited, Empire Growth Holdings, Freedom Media Ventures Ltd., G Club Operations LLC, G Fashion LLC, G News LLC, GETTR USA, Genever Holdings Corporation, Genever Holdings LLC, Gfashion Media Group Inc., GFNY, Inc., Globalist International Limited, GNews Media Group Inc., Golden Spring (New York) Ltd., Greenwich Land LLC, Guo Media, GTV Media Group, Inc., Hamilton Capital Holdings Inc., HCHK Property Management, Inc., HCHK Technologies, Inc., Head Win Group Limited, Henan Yuda, Himalaya Embassy, Himalaya Exchange, Himalaya Federal Reserve, Himalaya Investment LLC, Himalaya International,\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 211 of 1063\n\nHimalaya New World Inc., Himalaya Supervisory Organization, Himalaya Ventures LLC, HK International Funds Investments (USA) Limited LLC, Hong Kong International Funds Investments Limited, Hudson Diamond Holding, Infinite Increase Limited, Infinitum Developments Limited, Infinity Treasury Management Inc., Insight Phoenix Fund, Lamp Capital LLC, Leading Shine Limited, Leading Shine NY Limited, Lexington Property and Staffing, Long Gate Limited, Maywind Trading LLC, MOS Himalaya LLC, Next Tycoon Investments Limited, New Federal State of China (a/k/a NFSC), Noble Fame Global Limited, Rosy Acme Ventures Limited, Rule of Law Foundation III, Inc., Rule of Law Foundation IV, Inc., Rule of Law Fund, Rule of Law Society, Rule of Law Society IV, Inc., G-Translators PTY LTD, Saraca Media Group, Inc., Shiny Ace Ltd., Shiny Times Holdings Ltd., Spirit Charter Investment Limited, Stevenson, Wong & Co., Voice of Guo Media, Inc., Well Origin Ltd., World Century Limited, Worldwide Opportunity Holdings Limited, Whitecroft Shore Limited, and ZIBA Limited.\n\n9. \"Including\" or any variant thereof means \"including without limitation.\"\n\n10. \"And\" and \"or\" mean \"and/or,\" and shall be construed both conjunctively as well as disjunctively in order to maximize their scope.\n\n11. \"Any\" and \"all\" and \"each\" mean \"each and every.\"\n\n12. \"Each\" and \"every\" mean \"each and every.\"\n\n13. \"Third Party\" means a Person or Entity other than Yourself.\n\n14. \"Transfer\" shall have the meaning given to it by section 101(54) of the Bankruptcy Code.\n\n15. \"Document\" means any information or thing within the scope of Fed. R. Civ. P. 34, and includes, without limitation, each and every written, recorded, or graphic matter of any kind,\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 212 of 1063\n\ntype, nature, or description that is or has been in Your Possession, Custody or Control, including all printed and electronic copies of electronic mail, computer files maintained in electronic form, correspondence, memoranda, tapes, stenographic or handwritten notes, written forms of any kind, charts, blueprints, drawings, sketches, graphs, plans, articles, specifications, diaries, letters, telegrams, photographs, minutes, contracts, agreements, surveys, computer printouts, data compilations of any kind, telexes, facsimiles, emails, text messages, instant messages, voice messages, invoices, order forms, checks, drafts, statements, credit memos, reports, position reports, summaries, indices, books, ledgers, notebooks, schedules, transparencies, recordings, catalogs, advertisements, promotional materials, films, video tapes, audio tapes, CDs, computer disks, brochures, pamphlets, punch-cards, time-slips, Tweets, social media posts, or any written or recorded materials of any other kind, and all meta-data thereof, however stored (whether in tangible or electronic form), recorded, produced, or reproduced, and also including but not limited to, drafts or copies of any of the foregoing that contain any notes, comments, or markings of any kind not found on the original documents or that are otherwise not identical to the original documents.\n\n16. \"Person(s)\" means an individual, corporation, proprietorship, partnership, association, or any other Entity. \"Person\" also includes any agent, representatives, or expert, including but not limiting to, attorneys or financial advisors.\n\n17. \"Entity\" means any natural Person, corporation, partnership, subsidiary, sole proprietorship, firm, board, joint venture, association, agency, authority, commission or other business entity or juristic Person, as well as any affiliate, agent, parent including but not limited to counsel, financial advisors, or any other representative.\n\n#### Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 213 of 1063\n\n18. \"Regarding\" means concerning, describing, comprising, referring to, related to, supporting, favoring, opposing, bolstering, detracting from, located in, considered in connection with, bearing on, evidencing, indicating, reporting on, recording, alluding to, responding to, connected with, commenting on, in respect of, about, in relation to, discussing, showing, describing, reflecting, analyzing constituting, and being.\n\n19. \"Relating to,\" \"relate(s) to\" or \"related to,\" when referring to any given subject matter, means, without limitation, any document that constitutes, comprises, involves, contains, embodies, reflects, identifies, states, refers directly or indirectly to, or is in any way relevant to the particular subject matter identified.\n\n20. \"Communication(s)\" means, in the broadest possible sense, and without limitation, any transmittal of information or knowledge (in the form of facts, ideas, inquiries, or otherwise). Communication(s) further refers to all conversations, agreements, inquiries, or replies, whether in person, by telephone, in writing, or by means of electronic transmittal devices, and includes, but is not limited to, all correspondence, emails, recordings, transmittal slips, memoranda, telephone communications, voice messages, telegrams, telefaxes, telecopies, telexes, instant messages, chats, text messages, postings to a message board or group chat, social media posts, tweets, videos uploaded to any video platform, telephonic notes, or notes transmitted internally or with third parties.\n\n21. \"Asset(s)\" means any item of economic value that is subject to Possession, Custody, or Control. Asset includes all real and personal property, including but limited to, real estate, land, houses, apartments, condominiums, automobiles, yachts, boats, planes, jets, helicopters, cash, bank accounts, cryptocurrencies, securities, accounts receivables, inventory, and other tangible and intangible property.\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 214 of 1063\n\n#### **IV. DOCUMENTS TO BE PRODUCED**\n\n1. All Documents related to any income or Asset of the Debtor, the Debtor's estate, the Debtor's Family, or Associated Entity.\n\n2. All Documents related to any engagement letter with the Debtor, any member of the Debtor's Family, and/or any Associated Entity, including copy(ies) of such engagement letter(s).\n\n3. All Documents related to the payment of any retainer to You based upon your representation of the Debtor, the Debtor's Family, or an Associated Entity, including documents sufficient to identify the amount of the retainer and its source.\n\n4. All Documents related to any fees, payments, or monies received by You from or on behalf of the Debtor, the Debtor's Family, a Family Related Entity, or an Associated Entity held in escrow or in a client trust account.\n\n5. Documents sufficient to show the amount, date, and source of any payments made to You by or for the benefit of the Debtor, the Debtor's Family, or an Associated Entity.\n\n6. All Documents related to the Debtor's financial condition and obligations to his creditors, including without limitation all Documents related to any effort to avoid paying such obligations and All Documents related to this or any other actual or potential bankruptcy or similar insolvency proceeding.\n\n7. All Documents related to the Associated Entities, including but not limited to Documents related to their corporate structure, Assets, incorporation information, officers and directors, business purpose, and relationship to the Debtor, to any member of the Debtor's Family, or to any Associated Individual.\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 215 of 1063\n\n8. All Documents regarding any investment or business dealing made by, with, or on behalf of Debtor or the Debtor's Family, on the one hand, and an Associated Entity, on the other hand.\n\n9. All Documents related to any Entity that the Debtor, the Debtor's Estate, the Debtor's Family, or the Associated Entities hold any interest or investment in, including but not limited to the nature and value of that interest or investment; any proceeds or benefits from such Entity that the Debtor, the Debtor's Estate, the Debtor's Family, or the Associated Entities receive on account of such interest or investment; and all Documents relating to any financial reporting or data relating to such Entity, including but not limited to all books and records, financial statements or tax Documents.\n\n10. All Documents regarding the *Lady May*; the Sherry Netherland Hotel / Condominium; the residential property located in Greenwich, Connecticut, at 373 Taconic Rd.; the residential property located in Greenwich, Connecticut, at 33 Ferncliff Rd.; the residential property located in Wilton, Connecticut at 354 Nod Hill Rd.; and any financial interest that the Debtor or the Debtor's estate possesses in any Associated Entity.\n\n11. All Documents related to the purported Declaration of Trust and Agreement, dated February 17, 2015, entered into by the Debtor, as Trustee, Genever Holdings Corporation, and Genever Holdings LLC, in favor of Bravo Luck Limited, as beneficiary.\n\n12. All Documents related to any aircraft owned, controlled, or used by the Debtor, including without limitation the aircraft bearing tail number T7-GQM any other aircraft registered in San Marino, including without limitation copies of all registration documents and flight manifests showing flights taken by such aircraft and the individuals onboard such flights.\n\n#### Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 216 of 1063\n\n13. All Documents related to any investments or trading by the Debtor, the Debtor's Family, or an Associated Entity, in or around July 2020, or at any other time, in crude oil futures or any similar commodity, including without limitation Communications with Jiang Yunfu Be regarding any such investments or trading.\n\n14. All Communications between You and, either, the Debtor, the Debtor's Family, or any Associated Individual, agent, employee, or other individual acting on behalf of the Debtor, related to any Transfer, investment, or other transaction or business dealing relating to the Debtor, the Debtor's Estate, the Debtor's Family, or the Associated Entities.\n\n15. All Documents concerning any trust or similar instrument set up by, on behalf of, or for the benefit of Debtor, Debtor's Estate, Debtor's Family, or Associated Entities, including but not limited to Documents showing when the trust(s) was created, by whom it was created, to whose benefit it was created, and the corpus of the instrument.\n\n16. All Documents related to any sale, acquisition, disposition, purchase, investment, contribution, gift, extension of credit, loan, or Transfer involving the Debtor, the Debtor's Family, or any Associated Entity.\n\n17. All Documents related to any obligation, claim, liability, or debt associated with any legal dispute involving the Debtor, including but not limited to those relating to any litigation before any local, state, federal, or international body, whether an administrative body, court, panel, or alternative dispute resolution entity.\n\n18. All Documents related to any loans or extensions of credit, or applications for the same, to or from the Debtor, the Debtor's Estate, the Debtor's Family or any Associated Entity, including but not limited to (i) the terms of any such loans or extensions of credit, including their\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 217 of 1063\n\nterms of repayment, representations and warranties, and interest rate, and (ii) all evidence of payments of the loans.\n\n19. All Documents related to the Debtor's use of any Assets belonging to, controlled by, or whose complete or partial ownership is held by the Debtor's Family, an Associated Entity, or an Associated Individual.\n\n20. All Documents regarding any balance sheet, bank statement, account statement, financial statement, statement of account, wire transfer instructions and/or confirmation, proof of funds, certificate of deposit, certificate of holdings, investment portfolio summary, or similar document relating to the Debtor, the Debtor's Estate, the Debtor's Family, an Associated Entity, or an Associated Individual, including without limitation all Documents sufficient to show all Transfers to any of the foregoing.\n\n# Exhibit C-11\n\n#### B2540 (Form 2540 – Subpoena for Rule 2004 Examination) (12/15) Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 219 of\n\nUNITED STATES BANKRUPTCY COURT 1063\n\n**District of Connecticut**\n\nIn re HO WAN KWOK, *et al*.,\n\n<sup>1</sup> Case No. 22-50073 (JAM)\n\nDebtor Chapter 11\n\n(Jointly Administered)\n\n## **SUBPOENA FOR RULE 2004 EXAMINATION**\n\nTo: **Liberty Jet Management**\n\n(*Name of person to whom the subpoena is directed*)\n\n*Testimony:* **YOU ARE COMMANDED** to appear at the time, date, and place set forth below to testify at an examination under Rule 2004, Federal Rules of Bankruptcy Procedure. A copy of the court order authorizing the examination is attached.\n\n| PLACE                    | DATE AND TIME |\n|--------------------------|---------------|\n| Paul Hastings LLP        |               |\n| 200 Park Avenue          | [TBD]         |\n| New York, New York 10166 |               |\n|                          |               |\n\nThe examination will be recorded by this method: **Court reporter/stenographer**\n\n*Production:* You, or your representatives, must also bring with you to the examination the following documents, electronically stored information, or objects, and must permit inspection, copying, testing, or sampling of the material:\n\n#### **See Requests for Production of Documents, attached hereto.**\n\nThe following provisions of Fed. R. Civ. P. 45, made applicable in bankruptcy cases by Fed. R. Bankr. P. 9016, are attached – Rule 45(c), relating to the place of compliance; Rule 45(d), relating to your protection as a person subject to a subpoena; and Rule 45(e) and 45(g), relating to your duty to respond to this subpoena and the potential consequences of not doing so.\n\nDate: **March , 2023**\n\nCLERK OF COURT\n\nOR\n\n*Signature of Clerk or Deputy Clerk Attorney's signature*\n\nThe name, address, email address, and telephone number of the attorney representing Luc A. Despins, Chapter 11 Trustee, who issues or requests this subpoena, are:\n\n**Douglas S. Skalka, Esq.; Neubert, Pepe & Monteith, P.C.; 195 Church Street, New Haven, Connecticut 06510 dskalka@npmlaw.com; (203) 821-2000**\n\n**Notice to the person who issues or requests this subpoena**\n\nIf this subpoena commands the production of documents, electronically stored information, or tangible things, or the inspection of premises before trial, a notice and a copy of this subpoena must be served on each party before it is served on the person to whom it is directed. Fed. R. Civ. P. 45(a)(4).\n\nSoftware Copyright (c) 1996-2022 Best Case, LLC - www.bestcase.com Best Case Bankruptcy 1 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\n#### **PROOF OF SERVICE**\n\n**(This section should not be filed with the court unless required by Fed. R. Civ. P. 45.)**\n\nI received this subpoena for (*name of individual and title, if any*): on (*date*) .\n\nI served the subpoena by delivering a copy to the named person as follows:\n\non *(date)* ; or\n\nI returned the subpoena unexecuted because:\n\nUnless the subpoena was issued on behalf of the United States, or one of its officers or agents, I have also tendered to the witness the fees for one day's attendance, and the mileage allowed by law, in the amount of \\$ .\n\nMy fees are \\$ for travel and \\$ for services, for a total of \\$ .\n\nI declare under penalty of perjury that this information is true and correct.\n\nDate:\n\n*Server's signature*\n\n*Printed name and title*\n\n*Server's address*\n\nAdditional information concerning attempted service, etc.:\n\n#### **Federal Rule of Civil Procedure 45(c), (d), (e), and (g) (Effective 12/1/13) (made applicable in bankruptcy cases by Rule 9016, Federal Rules of Bankruptcy Procedure)**\n\n#### **(c) Place of compliance.**\n\n*(1) For a Trial, Hearing, or Deposition.* A subpoena may command a person to attend a trial, hearing, or deposition only as follows:\n\n(A) within 100 miles of where the person resides, is employed, or regularly transacts business in person; or\n\n(B) within the state where the person resides, is employed, or regularly transacts business in person, if the person\n\n(i) is a party or a party's officer; or\n\n(ii) is commanded to attend a trial and would not incur substantial expense.\n\n*(2) For Other Discovery.* A subpoena may command:\n\n(A) production of documents, or electronically stored information, or things at a place within 100 miles of where the person resides, is employed, or regularly transacts business in person; and\n\n(B) inspection of premises, at the premises to be inspected.\n\n#### **(d) Protecting a Person Subject to a Subpoena; Enforcement.**\n\n*(1) Avoiding Undue Burden or Expense; Sanctions.* A party or attorney responsible for issuing and serving a subpoena must take reasonable steps to avoid imposing undue burden or expense on a person subject to the subpoena. The court for the district where compliance is required must enforce this duty and impose an appropriate sanction which may include lost earnings and reasonable attorney's fees — on a party or attorney who fails to comply.\n\n#### *(2) Command to Produce Materials or Permit Inspection.*\n\n*(A) Appearance Not Required.* A person commanded to produce documents, electronically stored information, or tangible things, or to permit the inspection of premises, need not appear in person at the place of production or inspection unless also commanded to appear for a deposition, hearing, or trial.\n\n*(B) Objections.* A person commanded to produce documents or tangible things or to permit inspection may serve on the party or attorney designated in the subpoena a written objection to inspecting, copying, testing or sampling any or all of the materials or to inspecting the premises — or to producing electronically stored information in the form or forms requested. The objection must be served before the earlier of the time specified for compliance or 14 days after the subpoena is served. If an objection is made, the following rules apply:\n\n(i) At any time, on notice to the commanded person, the serving party may move the court for the district where compliance is required for an order compelling production or inspection.\n\n(ii) These acts may be required only as directed in the order, and the order must protect a person who is neither a party nor a party's officer from significant expense resulting from compliance.\n\n#### *(3) Quashing or Modifying a Subpoena.*\n\n*(A) When Required.* On timely motion, the court for the district where compliance is required must quash or modify a subpoena that:\n\n(i) fails to allow a reasonable time to comply;\n\n(ii) requires a person to comply beyond the geographical limits specified in Rule 45(c);\n\n(iii) requires disclosure of privileged or other protected matter, if no exception or waiver applies; or\n\n(iv) subjects a person to undue burden.\n\n*(B) When Permitted.* To protect a person subject to or affected by a subpoena, the court for the district where compliance is required may, on motion, quash or modify the subpoena if it requires:\n\n(i) disclosing a trade secret or other confidential research, development, or commercial information; or\n\n(ii) disclosing an unretained expert's opinion or information that does not describe specific occurrences in dispute and results from the expert's study that was not requested by a party.\n\n(C) *Specifying Conditions as an Alternative.* In the circumstances described in Rule 45(d)(3)(B), the court may, instead of quashing or modifying a subpoena, order appearance or production under specified conditions if the serving party:\n\n(i) shows a substantial need for the testimony or material that cannot be otherwise met without undue hardship; and\n\n(ii) ensures that the subpoenaed person will be reasonably compensated.\n\n#### **(e) Duties in Responding to a Subpoena.**\n\n*(1) Producing Documents or Electronically Stored Information.* These procedures apply to producing documents or electronically stored information:\n\n*(A) Documents.* A person responding to a subpoena to produce documents must produce them as they are kept in the ordinary course of business or must organize and label them to correspond to the categories in the demand.\n\n*(B) Form for Producing Electronically Stored Information Not Specified.* If a subpoena does not specify a form for producing electronically stored information, the person responding must produce it in a form or forms in which it is ordinarily maintained or in a reasonably usable form or forms.\n\n*(C) Electronically Stored Information Produced in Only One Form.* The person responding need not produce the same electronically stored information in more than one form.\n\n*(D) Inaccessible Electronically Stored Information.* The person responding need not provide discovery of electronically stored information from sources that the person identifies as not reasonably accessible because of undue burden or cost. On motion to compel discovery or for a protective order, the person responding must show that the information is not reasonably accessible because of undue burden or cost. If that showing is made, the court may nonetheless order discovery from such sources if the requesting party shows good cause, considering the limitations of Rule 26(b)(2)(C). The court may specify conditions for the discovery.\n\n#### *(2) Claiming Privilege or Protection.*\n\n*(A) Information Withheld.* A person withholding subpoenaed information under a claim that it is privileged or subject to protection as trial-preparation material must: (i) expressly make the claim; and\n\n(ii) describe the nature of the withheld documents, communications, or tangible things in a manner that, without revealing information itself privileged or protected, will enable the parties to assess the claim.\n\n*(B) Information Produced.* If information produced in response to a subpoena is subject to a claim of privilege or of protection as trial-preparation material, the person making the claim may notify any party that received the information of the claim and the basis for it. After being notified, a party must promptly return, sequester, or destroy the specified information and any copies it has; must not use or disclose the information until the claim is resolved; must take reasonable steps to retrieve the information if the party disclosed it before being notified; and may promptly present the information under seal to the court for the district where compliance is required for a determination of the claim. The person who produced the information must preserve the information until the claim is resolved.\n\n**(g) Contempt.** The court for the district where compliance is required – and also, after a motion is transferred, the issuing court – may hold in contempt a person who, having been served, fails without adequate excuse to obey the subpoena or an order related to it.\n\nFor access to subpoena materials, see Fed.R.Civ.P.45(a) Committee Note (2013)\n\n…\n\n## **Request for Production of Documents**\n\n## **I. INSTRUCTIONS**\n\n1. Unless otherwise indicated, the requests for documents set forth below, (the \"Requests,\" and each, a \"Request\"), must be responded to separately and specifically. Each Request shall be answered fully unless it is in good faith objected to, in which event the reason for Your objection shall be stated in detail, as set forth below. If an objection pertains only to a portion of a Request, or a word, phrase or clause contained within it, You are required to state Your objection to that portion only and to respond to the remainder of the Requests.\n\n2. Electronically stored information must be produced in accordance with the\n\nfollowing instructions:\n\n- a. Images. Black and white images must be 300 DPI Group IV single-page TIFF files. Color images must be produced in JPEG format. File names cannot contain embedded spaces or special characters (including the comma). Folder names cannot contain embedded spaces or special characters (including the comma). All TIFF image files must have a unique file name, i.e. Bates number. Images must be endorsed with sequential Bates numbers in the lower right corner of each image. The number of TIFF files per folder should not exceed 1000 files. Excel spreadsheets should have a placeholder image named by the Bates number of the file.\n- b. Image Load File\n\t- a. Concordance® Data File. The data file (.DAT) contains all of the fielded information that will be loaded into the Concordance® database. The first line of the .DAT file must be a header row identifying the field names. The .DAT file must use the following Concordance® default delimiters: Comma ASCII character (020) Quote þ ASCII character (254). Date fields should be provided in the format: mm/dd/yyyy. Date and time fields must be two separate fields. If documents includes imaged emails and attachments, the attachment fields must be included to preserve the parent/child relationship between an email and its attachments. An OCRPATH field must be included to provide the file path and name of the extracted text file on the produced storage media. The text file must be named after the FIRSTBATES. Do not include the text in the .DAT file. For Documents with native files, a LINK field must be included to provide the file path and\n\nname of the native file. The native file must be named after the FIRSTBATES.\n\n- b. Concordance Image® OR Opticon Cross-Reference File. The image crossreference file (.LOG or .OPT) links the images to the database records. It should be a comma-delimited file consisting of seven fields per line with a line in the cross-reference file for every image in the database with the following format: ImageID,VolumeLabel,ImageFilePath,DocumentBreak,FolderBreak,Box Break,PageCoun.\n- c. Document Text. Text must be produced as separate text files, not as fields within the .DAT file. The full path to the text file (OCRPATH) should be included in the .DAT file. It is recommended document level ANSI text files, named per the FIRSTBATES/Image Key. Extracted text files must be in a separate folder, and the number of text files per folder should not exceed 1,000 files. There should be no special characters (including commas in the folder names). Text files must be provided on a document level.\n- d. Native Production for Certain File Types. File types that reasonably require viewing in their native format for a full understanding of their content and meaning must be produced in native format. These include, but are not limited to, spreadsheets, spreadsheet-like files (Microsoft Excel, comma separated values, tab separated values, etc.), Microsoft PowerPoint or other special presentation files, database files, and audio/visual files. Provide an image of a Bates numbered slip sheet indicating the presence of a native file, and include the path to the native as a field in the .dat file. Name the produced native file with the Bates number corresponding to the slip sheet for the file. Group native files within incrementally named \"NATIVE\" directories, separate from images directories.\n- e. De-duplication. Produce a single copy of each electronic document for which exact duplicates exist. For email messages, consolidate duplicates based on MD5 hash generated from the BCC, Body, CC, From, IntMsgID, To, and Attach properties. For email attachments and standalone electronic files, consolidate duplicates based on MD5 hash of the entire file.\n- f. Metadata. Produce extracted metadata for each document in the form of a Concordance compliant load file (.dat). The first line of the .DAT file must be a header row identifying the field names. The .DAT file must use the following Concordance default delimiters: Comma , ASCII character (020) Quote þ ASCII character (254)\n\nDate fields should be provided in the format: mm/dd/yyyy. Date and time fields must be two separate fields. Required metadata listed below:\n\n# Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 224 of 1063\n\n| Field Name   | Sample Data              | Description                                                                                  |\n|--------------|--------------------------|----------------------------------------------------------------------------------------------|\n| FIRSTBATES   | EDC0000001               | First Bates number of native file document/email                                             |\n| LASTBATES    | EDC0000001               | Last Bates number of native file document/email<br>**The LASTBATES field should be populated |\n|              |                          | for single page                                                                              |\n| ATTACHRANGE  | EDC0000001<br>-          | Bates number of the first page of the parent                                                 |\n|              | EDC0000015               | document to the Bates number of the last page of                                             |\n|              |                          | the last attachment \"child\" document                                                         |\n| BEGATTACH    | EDC0000001               | First Bates number of attachment range                                                       |\n| ENDATTACH    | EDC0000015               | Last Bates number of attachment range                                                        |\n| CUSTODIAN    | Smith, John              | Email: Mailbox where the email resided                                                       |\n|              |                          | Native: Name of the individual or department                                                 |\n|              |                          | from whose files the document<br>originated                                                  |\n| FROM         | John Smith               | Email: Sender                                                                                |\n|              |                          | Native: Author(s) of document                                                                |\n|              |                          | **semi-colon should be used to separate                                                      |\n|              |                          | multiple entries                                                                             |\n| TO           | Coffman, Janice; LeeW    | Recipient(s)                                                                                 |\n|              | [mailto:LeeW@MSN.com]    | **semi-colon should be used to separate multiple                                             |\n|              |                          | entries                                                                                      |\n| CC           | Frank Thompson [mailto:  | Carbon copy recipient(s)                                                                     |\n|              | frank_Thompson@cdt.com]  | **semi-colon should be used to separate                                                      |\n|              |                          | multiple entries                                                                             |\n| BCC          | John Cain                | Blind carbon copy recipient(s)                                                               |\n|              |                          | **semi-colon should be used to separate                                                      |\n|              |                          | multiple entries                                                                             |\n| SUBJECT      | Board Meeting Minutes    | Email: Subject line of the email Native: Title                                               |\n|              |                          | of document (if available)                                                                   |\n| FILE_NAME    | BoardMeetingMinutes.docx | Native: Name of the original native file,                                                    |\n|              |                          | including extension                                                                          |\n| DATE_SENT    | 10/12/2010               | Email: Date the email was sent                                                               |\n|              |                          | Native: (empty)                                                                              |\n| TIME_SENT/   | 07:05 PM GMT             | Email: Time the email was sent/ Time zone in                                                 |\n| TIME_ZONE    |                          | which the emails were standardized                                                           |\n| TIME_ZONE    | GMT                      | The<br>time zone in which<br>the emails<br>were                                              |\n|              |                          | standardized during conversion.                                                              |\n| LINK         |  EDC0000001.msg   | Hyperlink to the email or native file document                                               |\n|              |                          | **The linked file must be named per the                                                      |\n|              |                          | FIRSTBATES number                                                                            |\n| FILE_EXTEN   | MSG                      | The file type extension                                                                      |\n|              |                          | representing                                                                                 |\n|              |                          | the Email or                                                                                 |\n| AUTHOR       | John Smith               | Email: (empty)                                                                               |\n|              |                          | Native: Author of the document                                                               |\n| DATE_CREATED | 10/10/2010               | Email: (empty)                                                                               |\n|              |                          | Native: Date the document was created                                                        |\n\n# Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 225 of 1063\n\n| TIME_CREATED | 10:25 AM                  | Email: (empty)                                  |\n|--------------|---------------------------|-------------------------------------------------|\n|              |                           | Native: Time the document was created           |\n|              |                           | **This data must be a separate field and cannot |\n|              |                           | be combined with the DATE_CREATED field         |\n| DATE_MOD     | 10/12/2010                | Email: (empty)                                  |\n|              |                           | Native: Date the document was last modified     |\n| TIME_MOD     | 07:00 PM                  | Email: (empty)                                  |\n|              |                           | Native: Time the document was last modified     |\n|              |                           | **This data must be a separate field and cannot |\n|              |                           | be combined with the DATE_MOD field             |\n| DATE_ACCESSD | 10/12/2010                | Email: (empty)                                  |\n|              |                           | Native: Date the document was last accessed     |\n| TIME_ACCESSD | 07:00 PM                  | Email: (empty)                                  |\n|              |                           | Native: Time the document was last accessed     |\n|              |                           | **This data must be a separate field and cannot |\n|              |                           | be combined with the DATE_ACCESSD field         |\n| FILE_SIZE    | 5,952                     | Size of native file<br>document/email in KB     |\n| PGCOUNT      | 1                         | Number of pages in native file document/email   |\n| PATH         |   | Email: (empty)                                  |\n|              | Agenda.doc                | Native: Path where native file document was     |\n|              |                           | stored including original file name.            |\n| INTFILEPATH  | Personal Folders\\Deleted  | Email: original location of email including     |\n|              | Items\\Board Meeting       | original file name.                             |\n|              | Minutes.msg               | Native: (empty)                                 |\n| INTMSGID     | <000805c2c71b\\$75977050\\$ | Email: Unique Message ID Native: (empty)        |\n|              | cb8306d1@MSN>             |                                                 |\n| MD5HASH      | d131dd02c5e6eec4693d9a0   | MD5 Hash value of the document.                 |\n|              | 698aff95c                 |                                                 |\n|              | 2fcab58712467eab4004583e  |                                                 |\n|              | b8fb7f89                  |                                                 |\n| OCRPATH      | TEXT/001/EDC0000001.txt   | Path to extracted text of the native file       |\n\n3. Each Request operates and should be construed independently and, unless otherwise indicated, no Request limits the scope of any other Request.\n\n4. All Documents are to be produced as kept in the usual course of business or are to be organized and labeled to correspond with the categories in these Requests.\n\n5. Each Request contained herein extends to all Documents: (a) in Your possession, custody, or control; or (b) in the possession, custody, or control of anyone acting on Your behalf,\n\n#### Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 226 of 1063\n\nincluding Your counsel or other representatives and advisors. Each Document shall be produced in its entirety.\n\n6. If You are requested to produce a Document that is no longer in Your possession, custody, or control, then Your response must (a) describe in detail the nature of the document and its contents; (b) identify the person(s) who prepared or authored the Document (and, if applicable, the Person(s) to whom the Document was sent); (c) identify the date on which the document was prepared or created; (d) state whether such Document (i) is missing or lost, (ii) has been destroyed, (iii) has been transferred, voluntarily or involuntarily, to others, or (iv) was otherwise disposed of; (e) state the reason for, and the facts and circumstances surrounding, such disposition; (f) identify the Persons who authorized such disposition; (g) identify the date or approximate date of such disposition; (h) state when the Document was most recently in Your possession, custody or control; and (i) identify the Person, if any, presently in possession, custody, or control of such Document.\n\n7. If You are requested to produce a Document that has been destroyed, then Your response must state, in addition to the information required by the preceding Instruction: (a) the reason for the Document's destruction; (b) the identity of the Person who destroyed the Document; and (c) the identity of the Person who directed that the Document be destroyed.\n\n8. If You claim that a requested Document is privileged or attorney work-product, then Your response must: (a) state (i) a description of the Document adequate to support Your contention that the Document is privileged, (ii) the title of the Document, (iii) the date of the Document, (iv) the author of the Document, (v) the addressee of the Document, (vi) the identity of each Person who received or saw the original or any draft, copy, or reproduction of the Document, (vii) whether the Document itself, or any information contained or referred to in the Document is in the possession, custody, or control of any other Persons, and if so, the identity of\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 227 of 1063\n\nsuch Persons, as well as a statement addressing how the information came into their possession, (viii) the claim of privilege under which the Document is withheld, and (ix) all of the circumstances upon which You will rely to support such claim of privilege; and (b) produce a privilege log containing all of the information requested in Part (a) of this Instruction for each Document withheld on the basis of a claim of privilege in accordance with D. Conn. L. Civ. R. 26(e). For any part of a Document Request as to which a claim of privilege or work product is not made, responsive documents should be provided in full.\n\n9. If a portion of an otherwise responsive Document contains information subject to a claim of privilege, only that portion of the Document subject to the claim of privilege shall be deleted or redacted from the Document following the instructions above, and the rest shall be produced.\n\n10. The Requests are continuing in nature. You are hereby instructed to (a) supplement or correct any responses later learned to be incomplete or incorrect immediately upon learning that a prior response was incomplete or incorrect; and (b) produce any additional Documents that are called for under the\n\n11. If a Document is in a language other than English, You should provide that Document. If a Document is in a language other than English, and an English translation exists, You should provide both Documents.\n\n12. All references to Entities includes all affiliates thereof.\n\n13. All references to individual names include all alternative names, aliased, or nicknames.\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 228 of 1063\n\n14. Unless otherwise expressly indicated, the period of time covered by the Document Requests is the period from February 5, 2012 to the date responses to the Document Requests are due.\n\n#### **II. RULES OF CONSTRUCTION**\n\n15. The use of (a) any singular noun shall be construed to include the plural, and vice versa, and (b) a verb in any tense shall be construed as the use of the verb in all other tenses.\n\n16. The terms (a) \"and\" and \"or\" shall be construed either conjunctively or disjunctively as necessary to bring within the scope of any request all responses that might otherwise be construed to be outside of its scope, and (b) \"each\" and \"any\" shall be deemed to include and encompass the words \"every\" and \"all.\"\n\n#### **III. DEFINITIONS**\n\nThe definitions supplied by D. Conn. L. Civ. R. 26(c) and the rules of construction supplied by D. Conn. L. Civ. R. 26(d), as incorporated by D. Conn. Bankr. L.R. 2004-1(a), shall apply to the Document Requests. In addition, the following terms used in these Document Requests shall have the following meanings:\n\n1. \"You\" or \"Your\" or \"Yourself\" means and refers to Liberty Jet Management, together with any of their employees, agents, counsel, advisors, or anyone acting on its behalf.\n\n2. \"Debtor\" means Ho Wan Kwok (a/k/a Miles Kwok, Miles Guo, Guo Wengui, Guo Haoyun, 郭文贵, or any other alias), together with his employees, agents, counsel, advisors, or anyone acting on his behalf.\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 229 of 1063\n\n3. \"Debtor's Son\" means Qiang Guo (a/k/a Mileson Kwok, 郭强, or any other alias), together with his employees, agents, counsel, advisors, or anyone acting on his behalf.\n\n4. \"Debtor's Daughter\" means Mei Guo (a/k/a Mei Gui, 郭美, or any other alias), together with her employees, agents, counsel, advisors, or anyone acting on her behalf.\n\n5. \"Debtor's Purported Wife\" means Hing Chi Ngok (a/k/a Hing Chi Ng, Yue Qingzhi, 岳庆芝, or any other alias), together with her employees, agents, counsel, advisors, or anyone acting on her behalf.\n\n6. \"Debtor's Family\" means, collectively, the Debtor, the Debtor's Son, the Debtor's Daughter, and the Debtor's Purported Wife, and any other familial relation to the Debtor.\n\n7. \"Associated Individuals\" means, individually and collectively, all individuals that (1) hold, control, have custody over, or discretion over assets owned, controlled, or enjoyed by the Debtor or the Debtor's Family; or (2) have been employees, directors, or otherwise are affiliated with one or more Associated Entities, together with the respective employees, agents, counsel, advisors, or anyone acting on behalf of any of the foregoing. Such Associated Individuals shall include, but are not limited to: Daniel Podhaskie, Jason Miller, Steve Bannon, Karin Maistrello, Melissa Francis, Anthony DiBattista, William Gertz, Arethusa Forsyth, Glenn Mellor, Jennifer Mercurio, Eduardo Eurnekian, Wencong Wang, Han Chunguang (a/k/a 韩春光), Qu Guojiao (a/k/a Qu Guo Jiao, 屈国姣), Guo Lijie (a/k/a 郭丽杰), Zhang Wei (a/k/a 张伟\\*), Lihong Wei Lafrenz (a/k/a Sara Wei, 魏丽红), Hao Haidong (a/k/a 郝海东), Ross Heinemeyer, Max Krasner, Kyle Bass, Melissa Mendez, Ya Li (a/k/a 李娅), Dinggang Wang (a/k/a 王定刚), An Hong (a/k/a 安红), Yvette Wang (a/k/a Yanping Wang, Yan Ping Wang, 王雁平), Fiona Yu, Je Kin Ming\n\n#### Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 230 of 1063\n\n(a/k/a William Je, Yu Jianming, 余建明), Yaz Qingua, and Lao Jiang (a/k/a Jiang Yunfu, Jiang Yunfu Be, 姜云浮)..\n\n8. \"Associated Entities\" means, individually and collectively, all organizations or Entities of any type that (1) have been owned, controlled, or invested in by the Debtor or the Debtor's Family; or (2) have an interest, whether directly or indirectly, in any assets owned, controlled, or enjoyed by the Debtor or the Debtor's Family, together with the respective employees, agents, counsel, advisors, or anyone acting on behalf of any of the foregoing. Such Associated Entities shall include, but are not limited to: 7 Nod Hill LLC, AAGV Limited, ACA Investment Management Limited, ACA Capital Group Limited, Ace Decade Holdings Limited, AI Group Holdings Inc., Alfa Global Ventures Limited, Alfonso Global Limited, Allied Capital Global Limited, Alpine Fiduciaries SA, Anton Development Limited, Assets Sino Limited, Auspicious Coast Limited, Beijing Pangu Investment Co., Beijing Pangu Investment Co. Ltd., Beijing Pangu Investment Inc., Beijing Zenith Holdings Company Limited, Booming Sail New York LLC, Bravo Luck Limited, BSA Strategic Fund I, China Golden Spring (Hong Kong) Limited, Chuang Xin Limited, Crane Advisory Group LLC, Creative Apex Investments Limited, Crystal Breeze Investments Limited, Dawn State Limited, Eastern Profit Corporation Limited, Elite Well Global Limited, Empire Growth Holdings, Freedom Media Ventures Ltd., G Club Operations LLC, G Fashion LLC, G News LLC, GETTR USA, Genever Holdings Corporation, Genever Holdings LLC, Gfashion Media Group Inc., GFNY, Inc., Globalist International Limited, GNews Media Group Inc., Golden Spring (New York) Ltd., Greenwich Land LLC, Guo Media, GTV Media Group, Inc., Hamilton Capital Holdings Inc., HCHK Property Management, Inc., HCHK Technologies, Inc., Head Win Group Limited, Henan Yuda, Himalaya Embassy, Himalaya Exchange, Himalaya Federal Reserve, Himalaya Investment LLC, Himalaya International,\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 231 of 1063\n\nHimalaya New World Inc., Himalaya Supervisory Organization, Himalaya Ventures LLC, HK International Funds Investments (USA) Limited LLC, Hong Kong International Funds Investments Limited, Hudson Diamond Holding, Infinite Increase Limited, Infinitum Developments Limited, Infinity Treasury Management Inc., Insight Phoenix Fund, Lamp Capital LLC, Leading Shine Limited, Leading Shine NY Limited, Lexington Property and Staffing, Long Gate Limited, Maywind Trading LLC, MOS Himalaya LLC, Next Tycoon Investments Limited, New Federal State of China (a/k/a NFSC), Noble Fame Global Limited, Rosy Acme Ventures Limited, Rule of Law Foundation III, Inc., Rule of Law Foundation IV, Inc., Rule of Law Fund, Rule of Law Society, Rule of Law Society IV, Inc., G-Translators PTY LTD, Saraca Media Group, Inc., Shiny Ace Ltd., Shiny Times Holdings Ltd., Spirit Charter Investment Limited, Stevenson, Wong & Co., Voice of Guo Media, Inc., Well Origin Ltd., World Century Limited, Worldwide Opportunity Holdings Limited, Whitecroft Shore Limited, and ZIBA Limited.\n\n9. \"Including\" or any variant thereof means \"including without limitation.\"\n\n10. \"And\" and \"or\" mean \"and/or,\" and shall be construed both conjunctively as well as disjunctively in order to maximize their scope.\n\n11. \"Any\" and \"all\" and \"each\" mean \"each and every.\"\n\n12. \"Each\" and \"every\" mean \"each and every.\"\n\n13. \"Third Party\" means a Person or Entity other than Yourself.\n\n14. \"Transfer\" shall have the meaning given to it by section 101(54) of the Bankruptcy Code.\n\n15. \"Document\" means any information or thing within the scope of Fed. R. Civ. P. 34, and includes, without limitation, each and every written, recorded, or graphic matter of any kind,\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 232 of 1063\n\ntype, nature, or description that is or has been in Your Possession, Custody or Control, including all printed and electronic copies of electronic mail, computer files maintained in electronic form, correspondence, memoranda, tapes, stenographic or handwritten notes, written forms of any kind, charts, blueprints, drawings, sketches, graphs, plans, articles, specifications, diaries, letters, telegrams, photographs, minutes, contracts, agreements, surveys, computer printouts, data compilations of any kind, telexes, facsimiles, emails, text messages, instant messages, voice messages, invoices, order forms, checks, drafts, statements, credit memos, reports, position reports, summaries, indices, books, ledgers, notebooks, schedules, transparencies, recordings, catalogs, advertisements, promotional materials, films, video tapes, audio tapes, CDs, computer disks, brochures, pamphlets, punch-cards, time-slips, Tweets, social media posts, or any written or recorded materials of any other kind, and all meta-data thereof, however stored (whether in tangible or electronic form), recorded, produced, or reproduced, and also including but not limited to, drafts or copies of any of the foregoing that contain any notes, comments, or markings of any kind not found on the original documents or that are otherwise not identical to the original documents.\n\n16. \"Person(s)\" means an individual, corporation, proprietorship, partnership, association, or any other Entity. \"Person\" also includes any agent, representatives, or expert, including but not limiting to, attorneys or financial advisors.\n\n17. \"Entity\" means any natural Person, corporation, partnership, subsidiary, sole proprietorship, firm, board, joint venture, association, agency, authority, commission or other business entity or juristic Person, as well as any affiliate, agent, parent including but not limited to counsel, financial advisors, or any other representative.\n\n#### Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 233 of 1063\n\n18. \"Regarding\" means concerning, describing, comprising, referring to, related to, supporting, favoring, opposing, bolstering, detracting from, located in, considered in connection with, bearing on, evidencing, indicating, reporting on, recording, alluding to, responding to, connected with, commenting on, in respect of, about, in relation to, discussing, showing, describing, reflecting, analyzing constituting, and being.\n\n19. \"Relating to,\" \"relate(s) to\" or \"related to,\" when referring to any given subject matter, means, without limitation, any document that constitutes, comprises, involves, contains, embodies, reflects, identifies, states, refers directly or indirectly to, or is in any way relevant to the particular subject matter identified.\n\n20. \"Communication(s)\" means, in the broadest possible sense, and without limitation, any transmittal of information or knowledge (in the form of facts, ideas, inquiries, or otherwise). Communication(s) further refers to all conversations, agreements, inquiries, or replies, whether in person, by telephone, in writing, or by means of electronic transmittal devices, and includes, but is not limited to, all correspondence, emails, recordings, transmittal slips, memoranda, telephone communications, voice messages, telegrams, telefaxes, telecopies, telexes, instant messages, chats, text messages, postings to a message board or group chat, social media posts, tweets, videos uploaded to any video platform, telephonic notes, or notes transmitted internally or with third parties.\n\n21. \"Asset(s)\" means any item of economic value that is subject to Possession, Custody, or Control. Asset includes all real and personal property, including but limited to, real estate, land, houses, apartments, condominiums, automobiles, yachts, boats, planes, jets, helicopters, cash, bank accounts, cryptocurrencies, securities, accounts receivables, inventory, and other tangible and intangible property.\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 234 of 1063\n\n22. \"Aircraft\" means any vehicle for traveling through the air, including, without limitation, airplanes and helicopters, that are or were at any time owned, used, controlled, purchased, sold, leased, rented, licensed, serviced, maintained, repaired, overhauled, stored, operated, marketed, or inspected by, to, or for the benefit of the Debtor, the Debtor's Family, or any Associated Entity, including, without limitation, any aircraft that are or were ever identified by or associated with the following alphanumeric sequences: T7-GQM, T7-17777, M-GYQM, SN9189, or 9189.\n\n23. \"Aircraft Staff\" means any employee, independent contractor, pilot, co-pilot, mechanic, flight attendant, or individual associated with the maintenance, operation, service, upkeep, or storage of an Aircraft.\n\n#### **IV. DOCUMENTS TO BE PRODUCED**\n\n1. All Documents related to any income or Asset of the Debtor, the Debtor's estate, the Debtor's Family, an Associated Entity, or an Associated Individual.\n\n2. All Documents related to the Debtor, the Debtor's estate, the Debtor's Family, an Associated Entity, or an Associated Individual and any Aircraft, including without limitation (i) ownership or control of any Aircraft; (ii) use of any Aircraft; (iii) lease or rental of any Aircraft; (iv) the purchase, sale, or marketing of any Aircraft; (v) any money or value paid or given related to any Aircraft and the source thereof; (vi) any money or value generated or obtained related to any Aircraft and the disposition thereof; or (vii) operation, maintenance, service, or overhaul, related to any Aircraft\n\n3. All Documents related to any account associated with the Debtor, the Debtor's estate, the Debtor's Family, an Associated Entity, or an Associated Individual.\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 235 of 1063\n\n4. All Documents related to any invoices or payments of expenses related to the Debtor, the Debtor's estate, the Debtor's Family, an Associated Entity, or an Associated Individual.\n\n5. All Documents related to any flight logs, flight plans, or any other recording of any flight information related to travels undertaken, or planned by the Debtor, the Debtor's estate, the Debtor's Family, an Associated Entity, or an Associated Individual.\n\n6. All Documents related to any activates by Aircraft Staff related the Debtor, the Debtor's estate, the Debtor's Family, an Associated Entity, or an Associated Individual.\n\n7. All Documents related to any payments, expenses, transfers or monies related to Aircraft Staff and the Debtor, the Debtor's estate, the Debtor's Family, an Associated Entity, or an Associated Individual.\n\n8. All Documents related to who may have been onboard any Aircraft in use by the Debtor, the Debtor's estate, the Debtor's Family, an Associated Entity, or an Associated Individual, including any flight manifests.\n\n9. All Documents related to any cargo, storage, items for delivery, assets or property on an Aircraft related to the Debtor, the Debtor's estate, the Debtor's Family, an Associated Entity, or an Associated Individual.\n\n10. All Documents related to the location of the Aircraft.\n\n# Exhibit C-12\n\n#### B2540 (Form 2540 – Subpoena for Rule 2004 Examination) (12/15) Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 237 of\n\n1063\n\nUNITED STATES BANKRUPTCY COURT\n\n**District of Connecticut**\n\nIn re HO WAN KWOK, *et al*.,\n\n<sup>1</sup> Case No. 22-50073 (JAM)\n\nDebtor Chapter 11\n\n(Jointly Administered)\n\n# **SUBPOENA FOR RULE 2004 EXAMINATION**\n\nTo: **Santander Bank, N. A.**\n\n(*Name of person to whom the subpoena is directed*)\n\n*Testimony:* **YOU ARE COMMANDED** to appear at the time, date, and place set forth below to testify at an examination under Rule 2004, Federal Rules of Bankruptcy Procedure. A copy of the court order authorizing the examination is attached.\n\n| PLACE                          | DATE AND TIME |\n|--------------------------------|---------------|\n| Neubert, Pepe & Monteith, P.C. |               |\n| 195 Church Street, Floor 13    | [TBD]         |\n| New Haven, Connecticut 06510   |               |\n|                                |               |\n\nThe examination will be recorded by this method: **Court reporter/stenographer**\n\n*Production:* You, or your representatives, must also bring with you to the examination the following documents, electronically stored information, or objects, and must permit inspection, copying, testing, or sampling of the material:\n\n#### **See Requests for Production of Documents, attached hereto.**\n\nThe following provisions of Fed. R. Civ. P. 45, made applicable in bankruptcy cases by Fed. R. Bankr. P. 9016, are attached – Rule 45(c), relating to the place of compliance; Rule 45(d), relating to your protection as a person subject to a subpoena; and Rule 45(e) and 45(g), relating to your duty to respond to this subpoena and the potential consequences of not doing so.\n\nDate: **March , 2023**\n\nCLERK OF COURT\n\nOR\n\n*Signature of Clerk or Deputy Clerk Attorney's signature*\n\nThe name, address, email address, and telephone number of the attorney representing Luc A. Despins, Chapter 11 Trustee, who issues or requests this subpoena, are:\n\n**Douglas S. Skalka, Esq.; Neubert, Pepe & Monteith, P.C.; 195 Church Street, New Haven, Connecticut 06510 dskalka@npmlaw.com; (203) 821-2000**\n\n**Notice to the person who issues or requests this subpoena**\n\nIf this subpoena commands the production of documents, electronically stored information, or tangible things, or the inspection of premises before trial, a notice and a copy of this subpoena must be served on each party before it is served on the person to whom it is directed. Fed. R. Civ. P. 45(a)(4).\n\nSoftware Copyright (c) 1996-2022 Best Case, LLC - www.bestcase.com Best Case Bankruptcy 1 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\n#### **PROOF OF SERVICE**\n\n**(This section should not be filed with the court unless required by Fed. R. Civ. P. 45.)**\n\nI received this subpoena for (*name of individual and title, if any*): on (*date*) .\n\nI served the subpoena by delivering a copy to the named person as follows:\n\non *(date)* ; or\n\nI returned the subpoena unexecuted because:\n\nUnless the subpoena was issued on behalf of the United States, or one of its officers or agents, I have also tendered to the witness the fees for one day's attendance, and the mileage allowed by law, in the amount of \\$ .\n\nMy fees are \\$ for travel and \\$ for services, for a total of \\$ .\n\nI declare under penalty of perjury that this information is true and correct.\n\nDate:\n\n*Server's signature*\n\n*Printed name and title*\n\n*Server's address*\n\nAdditional information concerning attempted service, etc.:\n\n#### **Federal Rule of Civil Procedure 45(c), (d), (e), and (g) (Effective 12/1/13) (made applicable in bankruptcy cases by Rule 9016, Federal Rules of Bankruptcy Procedure)**\n\n#### **(c) Place of compliance.**\n\n*(1) For a Trial, Hearing, or Deposition.* A subpoena may command a person to attend a trial, hearing, or deposition only as follows:\n\n(A) within 100 miles of where the person resides, is employed, or regularly transacts business in person; or\n\n(B) within the state where the person resides, is employed, or regularly transacts business in person, if the person\n\n(i) is a party or a party's officer; or\n\n(ii) is commanded to attend a trial and would not incur substantial expense.\n\n*(2) For Other Discovery.* A subpoena may command:\n\n(A) production of documents, or electronically stored information, or things at a place within 100 miles of where the person resides, is employed, or regularly transacts business in person; and\n\n(B) inspection of premises, at the premises to be inspected.\n\n#### **(d) Protecting a Person Subject to a Subpoena; Enforcement.**\n\n*(1) Avoiding Undue Burden or Expense; Sanctions.* A party or attorney responsible for issuing and serving a subpoena must take reasonable steps to avoid imposing undue burden or expense on a person subject to the subpoena. The court for the district where compliance is required must enforce this duty and impose an appropriate sanction which may include lost earnings and reasonable attorney's fees — on a party or attorney who fails to comply.\n\n#### *(2) Command to Produce Materials or Permit Inspection.*\n\n*(A) Appearance Not Required.* A person commanded to produce documents, electronically stored information, or tangible things, or to permit the inspection of premises, need not appear in person at the place of production or inspection unless also commanded to appear for a deposition, hearing, or trial.\n\n*(B) Objections.* A person commanded to produce documents or tangible things or to permit inspection may serve on the party or attorney designated in the subpoena a written objection to inspecting, copying, testing or sampling any or all of the materials or to inspecting the premises — or to producing electronically stored information in the form or forms requested. The objection must be served before the earlier of the time specified for compliance or 14 days after the subpoena is served. If an objection is made, the following rules apply:\n\n(i) At any time, on notice to the commanded person, the serving party may move the court for the district where compliance is required for an order compelling production or inspection.\n\n(ii) These acts may be required only as directed in the order, and the order must protect a person who is neither a party nor a party's officer from significant expense resulting from compliance.\n\n#### *(3) Quashing or Modifying a Subpoena.*\n\n*(A) When Required.* On timely motion, the court for the district where compliance is required must quash or modify a subpoena that:\n\n(i) fails to allow a reasonable time to comply;\n\n(ii) requires a person to comply beyond the geographical limits specified in Rule 45(c);\n\n(iii) requires disclosure of privileged or other protected matter, if no exception or waiver applies; or\n\n(iv) subjects a person to undue burden.\n\n*(B) When Permitted.* To protect a person subject to or affected by a subpoena, the court for the district where compliance is required may, on motion, quash or modify the subpoena if it requires:\n\n(i) disclosing a trade secret or other confidential research, development, or commercial information; or\n\n(ii) disclosing an unretained expert's opinion or information that does not describe specific occurrences in dispute and results from the expert's study that was not requested by a party.\n\n(C) *Specifying Conditions as an Alternative.* In the circumstances described in Rule 45(d)(3)(B), the court may, instead of quashing or modifying a subpoena, order appearance or production under specified conditions if the serving party:\n\n(i) shows a substantial need for the testimony or material that cannot be otherwise met without undue hardship; and\n\n(ii) ensures that the subpoenaed person will be reasonably compensated.\n\n#### **(e) Duties in Responding to a Subpoena.**\n\n*(1) Producing Documents or Electronically Stored Information.* These procedures apply to producing documents or electronically stored information:\n\n*(A) Documents.* A person responding to a subpoena to produce documents must produce them as they are kept in the ordinary course of business or must organize and label them to correspond to the categories in the demand.\n\n*(B) Form for Producing Electronically Stored Information Not Specified.* If a subpoena does not specify a form for producing electronically stored information, the person responding must produce it in a form or forms in which it is ordinarily maintained or in a reasonably usable form or forms.\n\n*(C) Electronically Stored Information Produced in Only One Form.* The person responding need not produce the same electronically stored information in more than one form.\n\n*(D) Inaccessible Electronically Stored Information.* The person responding need not provide discovery of electronically stored information from sources that the person identifies as not reasonably accessible because of undue burden or cost. On motion to compel discovery or for a protective order, the person responding must show that the information is not reasonably accessible because of undue burden or cost. If that showing is made, the court may nonetheless order discovery from such sources if the requesting party shows good cause, considering the limitations of Rule 26(b)(2)(C). The court may specify conditions for the discovery.\n\n#### *(2) Claiming Privilege or Protection.*\n\n*(A) Information Withheld.* A person withholding subpoenaed information under a claim that it is privileged or subject to protection as trial-preparation material must: (i) expressly make the claim; and\n\n(ii) describe the nature of the withheld documents, communications, or tangible things in a manner that, without revealing information itself privileged or protected, will enable the parties to assess the claim.\n\n*(B) Information Produced.* If information produced in response to a subpoena is subject to a claim of privilege or of protection as trial-preparation material, the person making the claim may notify any party that received the information of the claim and the basis for it. After being notified, a party must promptly return, sequester, or destroy the specified information and any copies it has; must not use or disclose the information until the claim is resolved; must take reasonable steps to retrieve the information if the party disclosed it before being notified; and may promptly present the information under seal to the court for the district where compliance is required for a determination of the claim. The person who produced the information must preserve the information until the claim is resolved.\n\n**(g) Contempt.** The court for the district where compliance is required – and also, after a motion is transferred, the issuing court – may hold in contempt a person who, having been served, fails without adequate excuse to obey the subpoena or an order related to it.\n\nFor access to subpoena materials, see Fed.R.Civ.P.45(a) Committee Note (2013)\n\n…\n\n## **Request for Production of Documents**\n\n## **I. INSTRUCTIONS**\n\n1. Unless otherwise indicated, the requests for documents set forth below, (the \"Requests,\" and each, a \"Request\"), must be responded to separately and specifically. Each Request shall be answered fully unless it is in good faith objected to, in which event the reason for Your objection shall be stated in detail, as set forth below. If an objection pertains only to a portion of a Request, or a word, phrase or clause contained within it, You are required to state Your objection to that portion only and to respond to the remainder of the Requests.\n\n2. Electronically stored information must be produced in accordance with the\n\nfollowing instructions:\n\n- a. Images. Black and white images must be 300 DPI Group IV single-page TIFF files. Color images must be produced in JPEG format. File names cannot contain embedded spaces or special characters (including the comma). Folder names cannot contain embedded spaces or special characters (including the comma). All TIFF image files must have a unique file name, i.e. Bates number. Images must be endorsed with sequential Bates numbers in the lower right corner of each image. The number of TIFF files per folder should not exceed 1000 files. Excel spreadsheets should have a placeholder image named by the Bates number of the file.\n- b. Image Load File\n\t- a. Concordance® Data File. The data file (.DAT) contains all of the fielded information that will be loaded into the Concordance® database. The first line of the .DAT file must be a header row identifying the field names. The .DAT file must use the following Concordance® default delimiters: Comma ASCII character (020) Quote þ ASCII character (254). Date fields should be provided in the format: mm/dd/yyyy. Date and time fields must be two separate fields. If documents includes imaged emails and attachments, the attachment fields must be included to preserve the parent/child relationship between an email and its attachments. An OCRPATH field must be included to provide the file path and name of the extracted text file on the produced storage media. The text file must be named after the FIRSTBATES. Do not include the text in the .DAT file. For Documents with native files, a LINK field must be included to provide the file path and\n\nname of the native file. The native file must be named after the FIRSTBATES.\n\n- b. Concordance Image® OR Opticon Cross-Reference File. The image crossreference file (.LOG or .OPT) links the images to the database records. It should be a comma-delimited file consisting of seven fields per line with a line in the cross-reference file for every image in the database with the following format: ImageID,VolumeLabel,ImageFilePath,DocumentBreak,FolderBreak,Box Break,PageCoun.\n- c. Document Text. Text must be produced as separate text files, not as fields within the .DAT file. The full path to the text file (OCRPATH) should be included in the .DAT file. It is recommended document level ANSI text files, named per the FIRSTBATES/Image Key. Extracted text files must be in a separate folder, and the number of text files per folder should not exceed 1,000 files. There should be no special characters (including commas in the folder names). Text files must be provided on a document level.\n- d. Native Production for Certain File Types. File types that reasonably require viewing in their native format for a full understanding of their content and meaning must be produced in native format. These include, but are not limited to, spreadsheets, spreadsheet-like files (Microsoft Excel, comma separated values, tab separated values, etc.), Microsoft PowerPoint or other special presentation files, database files, and audio/visual files. Provide an image of a Bates numbered slip sheet indicating the presence of a native file, and include the path to the native as a field in the .dat file. Name the produced native file with the Bates number corresponding to the slip sheet for the file. Group native files within incrementally named \"NATIVE\" directories, separate from images directories.\n- e. De-duplication. Produce a single copy of each electronic document for which exact duplicates exist. For email messages, consolidate duplicates based on MD5 hash generated from the BCC, Body, CC, From, IntMsgID, To, and Attach properties. For email attachments and standalone electronic files, consolidate duplicates based on MD5 hash of the entire file.\n- f. Metadata. Produce extracted metadata for each document in the form of a Concordance compliant load file (.dat). The first line of the .DAT file must be a header row identifying the field names. The .DAT file must use the following Concordance default delimiters: Comma , ASCII character (020) Quote þ ASCII character (254)\n\nDate fields should be provided in the format: mm/dd/yyyy. Date and time fields must be two separate fields. Required metadata listed below:\n\n# Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 242 of 1063\n\n| Field Name   | Sample Data              | Description                                      |\n|--------------|--------------------------|--------------------------------------------------|\n| FIRSTBATES   | EDC0000001               | First Bates number of native file document/email |\n| LASTBATES    | EDC0000001               | Last Bates number of native file document/email  |\n|              |                          | **The LASTBATES field should be populated        |\n|              |                          | for single page                                  |\n| ATTACHRANGE  | EDC0000001<br>-          | Bates number of the first page of the parent     |\n|              | EDC0000015               | document to the Bates number of the last page of |\n|              |                          | the last attachment \"child\" document             |\n| BEGATTACH    | EDC0000001               | First Bates number of attachment range           |\n| ENDATTACH    | EDC0000015               | Last Bates number of attachment range            |\n| CUSTODIAN    | Smith, John              | Email: Mailbox where the email resided           |\n|              |                          | Native: Name of the individual or department     |\n|              |                          | from whose files the document<br>originated      |\n| FROM         | John Smith               | Email: Sender                                    |\n|              |                          | Native: Author(s) of document                    |\n|              |                          | **semi-colon should be used to separate          |\n|              |                          | multiple entries                                 |\n| TO           | Coffman, Janice; LeeW    | Recipient(s)                                     |\n|              | [mailto:LeeW@MSN.com]    | **semi-colon should be used to separate multiple |\n|              |                          | entries                                          |\n| CC           | Frank Thompson [mailto:  | Carbon copy recipient(s)                         |\n|              | frank_Thompson@cdt.com]  | **semi-colon should be used to separate          |\n|              |                          | multiple entries                                 |\n| BCC          | John Cain                | Blind carbon copy recipient(s)                   |\n|              |                          | **semi-colon should be used to separate          |\n|              |                          | multiple entries                                 |\n| SUBJECT      | Board Meeting Minutes    | Email: Subject line of the email Native: Title   |\n|              |                          | of document (if available)                       |\n| FILE_NAME    | BoardMeetingMinutes.docx | Native: Name of the original native file,        |\n|              |                          | including extension                              |\n| DATE_SENT    | 10/12/2010               | Email: Date the email was sent                   |\n|              |                          | Native: (empty)                                  |\n| TIME_SENT/   | 07:05 PM GMT             | Email: Time the email was sent/ Time zone in     |\n| TIME_ZONE    |                          | which the emails were standardized               |\n| TIME_ZONE    | GMT                      | The<br>time zone in which<br>the emails<br>were  |\n|              |                          | standardized during conversion.                  |\n| LINK         |  EDC0000001.msg   | Hyperlink to the email or native file document   |\n|              |                          | **The linked file must be named per the          |\n|              |                          | FIRSTBATES number                                |\n| FILE_EXTEN   | MSG                      | The file type extension                          |\n|              |                          | representing                                     |\n|              |                          | the Email or                                     |\n| AUTHOR       | John Smith               | Email: (empty)                                   |\n|              |                          | Native: Author of the document                   |\n| DATE_CREATED | 10/10/2010               | Email: (empty)                                   |\n|              |                          | Native: Date the document was created            |\n\n# Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 243 of 1063\n\n| TIME_CREATED | 10:25 AM                  | Email: (empty)                                  |\n|--------------|---------------------------|-------------------------------------------------|\n|              |                           | Native: Time the document was created           |\n|              |                           | **This data must be a separate field and cannot |\n|              |                           | be combined with the DATE_CREATED field         |\n| DATE_MOD     | 10/12/2010                | Email: (empty)                                  |\n|              |                           | Native: Date the document was last modified     |\n| TIME_MOD     | 07:00 PM                  | Email: (empty)                                  |\n|              |                           | Native: Time the document was last modified     |\n|              |                           | **This data must be a separate field and cannot |\n|              |                           | be combined with the DATE_MOD field             |\n| DATE_ACCESSD | 10/12/2010                | Email: (empty)                                  |\n|              |                           | Native: Date the document was last accessed     |\n| TIME_ACCESSD | 07:00 PM                  | Email: (empty)                                  |\n|              |                           | Native: Time the document was last accessed     |\n|              |                           | **This data must be a separate field and cannot |\n|              |                           | be combined with the DATE_ACCESSD field         |\n| FILE_SIZE    | 5,952                     | Size of native file<br>document/email in KB     |\n| PGCOUNT      | 1                         | Number of pages in native file document/email   |\n| PATH         |   | Email: (empty)                                  |\n|              | Agenda.doc                | Native: Path where native file document was     |\n|              |                           | stored including original file name.            |\n| INTFILEPATH  | Personal Folders\\Deleted  | Email: original location of email including     |\n|              | Items\\Board Meeting       | original file name.                             |\n|              | Minutes.msg               | Native: (empty)                                 |\n| INTMSGID     | <000805c2c71b\\$75977050\\$ | Email: Unique Message ID Native: (empty)        |\n|              | cb8306d1@MSN>             |                                                 |\n| MD5HASH      | d131dd02c5e6eec4693d9a0   | MD5 Hash value of the document.                 |\n|              | 698aff95c                 |                                                 |\n|              | 2fcab58712467eab4004583e  |                                                 |\n|              | b8fb7f89                  |                                                 |\n| OCRPATH      | TEXT/001/EDC0000001.txt   | Path to extracted text of the native file       |\n\n3. Each Request operates and should be construed independently and, unless otherwise indicated, no Request limits the scope of any other Request.\n\n4. All Documents are to be produced as kept in the usual course of business or are to be organized and labeled to correspond with the categories in these Requests.\n\n5. Each Request contained herein extends to all Documents: (a) in Your possession, custody, or control; or (b) in the possession, custody, or control of anyone acting on Your behalf,\n\n#### Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 244 of 1063\n\nincluding Your counsel or other representatives and advisors. Each Document shall be produced in its entirety.\n\n6. If You are requested to produce a Document that is no longer in Your possession, custody, or control, then Your response must (a) describe in detail the nature of the document and its contents; (b) identify the person(s) who prepared or authored the Document (and, if applicable, the Person(s) to whom the Document was sent); (c) identify the date on which the document was prepared or created; (d) state whether such Document (i) is missing or lost, (ii) has been destroyed, (iii) has been transferred, voluntarily or involuntarily, to others, or (iv) was otherwise disposed of; (e) state the reason for, and the facts and circumstances surrounding, such disposition; (f) identify the Persons who authorized such disposition; (g) identify the date or approximate date of such disposition; (h) state when the Document was most recently in Your possession, custody or control; and (i) identify the Person, if any, presently in possession, custody, or control of such Document.\n\n7. If You are requested to produce a Document that has been destroyed, then Your response must state, in addition to the information required by the preceding Instruction: (a) the reason for the Document's destruction; (b) the identity of the Person who destroyed the Document; and (c) the identity of the Person who directed that the Document be destroyed.\n\n8. If You claim that a requested Document is privileged or attorney work-product, then Your response must: (a) state (i) a description of the Document adequate to support Your contention that the Document is privileged, (ii) the title of the Document, (iii) the date of the Document, (iv) the author of the Document, (v) the addressee of the Document, (vi) the identity of each Person who received or saw the original or any draft, copy, or reproduction of the Document, (vii) whether the Document itself, or any information contained or referred to in the Document is in the possession, custody, or control of any other Persons, and if so, the identity of\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 245 of 1063\n\nsuch Persons, as well as a statement addressing how the information came into their possession, (viii) the claim of privilege under which the Document is withheld, and (ix) all of the circumstances upon which You will rely to support such claim of privilege; and (b) produce a privilege log containing all of the information requested in Part (a) of this Instruction for each Document withheld on the basis of a claim of privilege in accordance with D. Conn. L. Civ. R. 26(e). For any part of a Document Request as to which a claim of privilege or work product is not made, responsive documents should be provided in full.\n\n9. If a portion of an otherwise responsive Document contains information subject to a claim of privilege, only that portion of the Document subject to the claim of privilege shall be deleted or redacted from the Document following the instructions above, and the rest shall be produced.\n\n10. The Requests are continuing in nature. You are hereby instructed to (a) supplement or correct any responses later learned to be incomplete or incorrect immediately upon learning that a prior response was incomplete or incorrect; and (b) produce any additional Documents that are called for under the\n\n11. If a Document is in a language other than English, You should provide that Document. If a Document is in a language other than English, and an English translation exists, You should provide both Documents.\n\n12. All references to Entities includes all affiliates thereof.\n\n13. All references to individual names include all alternative names, aliased, or nicknames.\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 246 of 1063\n\n14. Unless otherwise expressly indicated, the period of time covered by the Document Requests is the period from February 5, 2012 to the date responses to the Document Requests are due.\n\n#### **II. RULES OF CONSTRUCTION**\n\n15. The use of (a) any singular noun shall be construed to include the plural, and vice versa, and (b) a verb in any tense shall be construed as the use of the verb in all other tenses.\n\n16. The terms (a) \"and\" and \"or\" shall be construed either conjunctively or disjunctively as necessary to bring within the scope of any request all responses that might otherwise be construed to be outside of its scope, and (b) \"each\" and \"any\" shall be deemed to include and encompass the words \"every\" and \"all.\"\n\n#### **III. DEFINITIONS**\n\nThe definitions supplied by D. Conn. L. Civ. R. 26(c) and the rules of construction supplied by D. Conn. L. Civ. R. 26(d), as incorporated by D. Conn. Bankr. L.R. 2004-1(a), shall apply to the Document Requests. In addition, the following terms used in these Document Requests shall have the following meanings:\n\n1. \"You\" or \"Your\" or \"Yourself\" means and refers, to Santander Bank, N. A., together with all of its affiliates.\n\n2. \"Debtor\" means Ho Wan Kwok (a/k/a Miles Kwok, Miles Guo, Guo Wengui, Guo Haoyun, 郭文贵, or any other alias), together with his employees, agents, counsel, advisors, or anyone acting on his behalf.\n\n#### Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 247 of 1063\n\n3. \"Debtor's Son\" means Qiang Guo (a/k/a Mileson Kwok, 郭强, or any other alias), together with his employees, agents, counsel, advisors, or anyone acting on his behalf.\n\n4. \"Debtor's Daughter\" means Mei Guo (a/k/a Mei Gui, 郭美, or any other alias), together with her employees, agents, counsel, advisors, or anyone acting on her behalf.\n\n5. \"Debtor's Purported Wife\" means Hing Chi Ngok (a/k/a Hing Chi Ng, Yue Qingzhi, 岳庆芝, or any other alias), together with her employees, agents, counsel, advisors, or anyone acting on her behalf.\n\n6. \"Debtor's Family\" means, individually and collectively, the Debtor, the Debtor's Son, the Debtor's Daughter, and the Debtor's Purported Wife, and any other familial relation to the Debtor.\n\n7. \"2004 Discovery Targets\" means, individually and collectively, the Debtor, the Debtor's Family, ACA Capital Group Limited, Himalaya International Financial Group Ltd., Himalaya International Clearing Ltd., Himalaya International Payments Ltd., Himalaya International Reserves Ltd., Jesse Brown, William Je, William Je, Eastern Profit Corporation Limited, HK International Funds Investments (USA) Limited LLC, Bravo Luck Limited, Golden Spring (New York) Ltd., Lamp Capital LLC, Greenwich Land LLC, Qu Guo Jiao, Daniel Thomas Podhaskie, Yvette Wang (a/k/a Yanping Wang, a/k/a Yan Ping Wang), Ace Decade Holdings Limited, Dawn State Limited, Rule of Law Society IV Inc., Rule of Law Foundation III, Inc., Rule of Law Foundation IV, Inc., Rule of Law Fund, Rule of Law Society, GTV Media Group, Inc., Voice of Guo Media, Inc., Saraca Media Group Inc., Genever Holdings Corporation, Genever Holdings LLC, Gnews Media Group Inc., G Fashion LLC, Gmusic LLC, Gnews LLC, Geducation, GFNY, Inc., G-Club Investments Limited, G Club Operations LLC, G Club US Operations Inc., G Club US Operations LLC, G Live, LLC, Gbroadcast, LLC, Gposts LLC, HCHK Property\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 248 of 1063\n\nManagement, Inc., HCHK Technologies, Inc., FMV Ltd./Freedom Media Venture Ltd., Roscalitar 2, Himalaya New World Inc., US Himalaya Capital Inc., Hudson Diamond Holding, Inc., Hudson Diamond Holding LLC, Hudson Diamond NY LLC, Infinity Treasury Management Inc., Lexington Property and Staffing, Inc., AI Group Holdings Inc., Hamilton Capital Holdings Inc., Booming Sail New York LLC, Himalaya Ventures LLC, Himalaya Ventures LLC, Himalaya Investment LLC, New York MOS Himalaya LLC, MOS Himalaya LLC, Crane Advisory Group, Maywind Trading LLC, Gettr USA, Inc., Han Chunguang, Bingshang Jiao, Karin Maistrello, Mary Jiang, Jiaming Liu, and Wencong Wang.\n\n8. \"Including\" or any variant thereof means \"including without limitation.\"\n\n9. \"And\" and \"or\" mean \"and/or,\" and shall be construed both conjunctively as well as disjunctively in order to maximize their scope.\n\n10. \"Any\" and \"all\" and \"each\" mean \"each and every.\"\n\n11. \"Each\" and \"every\" mean \"each and every.\"\n\n12. \"Third Party\" means a Person or Entity other than Yourself.\n\n13. \"Transfer\" shall have the meaning given to it by section 101(54) of the Bankruptcy Code.\n\n14. \"Document\" means any information or thing within the scope of Fed. R. Civ. P. 34, and includes, without limitation, each and every written, recorded, or graphic matter of any kind, type, nature, or description that is or has been in Your Possession, Custody or Control, including all printed and electronic copies of electronic mail, computer files maintained in electronic form, correspondence, memoranda, tapes, stenographic or handwritten notes, written forms of any kind, charts, blueprints, drawings, sketches, graphs, plans, articles, specifications, diaries, letters,\n\n### Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 249 of 1063\n\ntelegrams, photographs, minutes, contracts, agreements, surveys, computer printouts, data compilations of any kind, telexes, facsimiles, emails, text messages, instant messages, voice messages, invoices, order forms, checks, drafts, statements, credit memos, reports, position reports, summaries, indices, books, ledgers, notebooks, schedules, transparencies, recordings, catalogs, advertisements, promotional materials, films, video tapes, audio tapes, CDs, computer disks, brochures, pamphlets, punch-cards, time-slips, Tweets, social media posts, or any written or recorded materials of any other kind, and all meta-data thereof, however stored (whether in tangible or electronic form), recorded, produced, or reproduced, and also including but not limited to, drafts or copies of any of the foregoing that contain any notes, comments, or markings of any kind not found on the original documents or that are otherwise not identical to the original documents.\n\n15. \"Person(s)\" means an individual, corporation, proprietorship, partnership, association, or any other Entity. \"Person\" also includes any agent, representatives, or expert, including but not limiting to, attorneys or financial advisors.\n\n16. \"Entity\" means any natural Person, corporation, partnership, subsidiary, sole proprietorship, firm, board, joint venture, association, agency, authority, commission or other business entity or juristic Person, as well as any affiliate, agent, parent including but not limited to counsel, financial advisors, or any other representative.\n\n17. \"Regarding\" means concerning, describing, comprising, referring to, related to, supporting, favoring, opposing, bolstering, detracting from, located in, considered in connection with, bearing on, evidencing, indicating, reporting on, recording, alluding to, responding to, connected with, commenting on, in respect of, about, in relation to, discussing, showing, describing, reflecting, analyzing constituting, and being.\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 250 of 1063\n\n18. \"Relating to,\" \"relate(s) to\" or \"related to,\" when referring to any given subject matter, means, without limitation, any document that constitutes, comprises, involves, contains, embodies, reflects, identifies, states, refers directly or indirectly to, or is in any way relevant to the particular subject matter identified.\n\n19. \"Communication(s)\" means, in the broadest possible sense, and without limitation, any transmittal of information or knowledge (in the form of facts, ideas, inquiries, or otherwise). Communication(s) further refers to all conversations, agreements, inquiries, or replies, whether in person, by telephone, in writing, or by means of electronic transmittal devices, and includes, but is not limited to, all correspondence, emails, recordings, transmittal slips, memoranda, telephone communications, voice messages, telegrams, telefaxes, telecopies, telexes, instant messages, chats, text messages, postings to a message board or group chat, social media posts, tweets, videos uploaded to any video platform, telephonic notes, or notes transmitted internally or with third parties.\n\n20. \"Asset(s)\" means any item of economic value that is subject to Possession, Custody, or Control. Asset includes all real and personal property, including but limited to, real estate, land, houses, apartments, condominiums, automobiles, yachts, boats, planes, jets, helicopters, cash, bank accounts, cryptocurrencies, securities, accounts receivables, inventory, and other tangible and intangible property.\n\n#### **IV. DOCUMENTS TO BE PRODUCED**\n\n1. All Documents related to any account held by, controlled by, on behalf of, or otherwise related to any of the 2004 Discovery Targets, including any and all account statements, authorizations, power of attorney, trusts, instructions or forms, copies of cancelled checks, correspondence, and wire transfers and related correspondence and instructions.\n\n#### Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 251 of 1063\n\n2. All Documents related to any funds, securities, property, or assets belonging to, held by, controlled by, on behalf of, or otherwise related to any of the 2004 Discovery Targets, including any and all account statements, authorizations, powers of attorney, trusts, instructions or forms, copies of cancelled checks, correspondence, and wire transfers and related correspondence and instructions.\n\n3. All Documents related to any business, commerce or financial transactions, including but not limited to any loan, line of credit, bailment, deposit, swap, securities transactions, mortgage, or ISDA, with any of the 2004 Discovery Targets, including any and all account statements, authorizations, powers of attorney, trusts, instructions or forms, copies of cancelled checks, correspondence, and wire transfers and related correspondence and instructions.\n\n4. All Documents relating to any wire transfer activity relating to the 2004 Discovery Targets, regardless of the existence of any accounts, including but not limited to all wire transfer receipts, account numbers, balances, authorizations, identification information related to the parties to the transfer, correspondence, instructions, or other records.\n\n5. All Documents related to any correspondence and communications between you and the 2004 Discovery Targets.\n\n6. All Documents related to any account with any 2004 Discovery Target relating to opening of the account, authorized users of the account and maintenance of the account.\n\n7. All Documents related to any anti-money laundering, know-your-customer, or other compliance activity relating to any of the 2004 Discovery Targets, including but not limited to any information provided by any of the 2004 Discovery Targets, or learned by You.\n\n8. All Documents relating to any communications with any regulator from any country, including but not limited to the Bank of England, the United States Federal Reserve, the\n\nS.E.C., the CFTC, FINRA, China Securities Regulatory Commission, People's Bank of China, Hong Kong Securities and Futures Commission, and the Hong Kong Monetary Authority relating to any of the 2004 Discovery Targets.\n\n# Exhibit C-13\n\n#### B2540 (Form 2540 – Subpoena for Rule 2004 Examination) (12/15) Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 254 of\n\n1063\n\nUNITED STATES BANKRUPTCY COURT\n\n**District of Connecticut**\n\nIn re HO WAN KWOK, *et al*.,\n\n<sup>1</sup> Case No. 22-50073 (JAM) Debtor Chapter 11\n\n(Jointly Administered)\n\n# **SUBPOENA FOR RULE 2004 EXAMINATION**\n\nTo: **First Republic Bank**\n\n(*Name of person to whom the subpoena is directed*)\n\n*Testimony:* **YOU ARE COMMANDED** to appear at the time, date, and place set forth below to testify at an examination under Rule 2004, Federal Rules of Bankruptcy Procedure. A copy of the court order authorizing the examination is attached.\n\n| PLACE                          | DATE AND TIME |\n|--------------------------------|---------------|\n| Neubert, Pepe & Monteith, P.C. |               |\n| 195 Church Street              | [TBD]         |\n| New Haven, Connecticut 06510   |               |\n|                                |               |\n\nThe examination will be recorded by this method: **Court reporter/stenographer**\n\n*Production:* You, or your representatives, must also bring with you to the examination the following documents, electronically stored information, or objects, and must permit inspection, copying, testing, or sampling of the material:\n\n#### **See Requests for Production of Documents, attached hereto.**\n\nThe following provisions of Fed. R. Civ. P. 45, made applicable in bankruptcy cases by Fed. R. Bankr. P. 9016, are attached – Rule 45(c), relating to the place of compliance; Rule 45(d), relating to your protection as a person subject to a subpoena; and Rule 45(e) and 45(g), relating to your duty to respond to this subpoena and the potential consequences of not doing so.\n\nDate: **March , 2023**\n\nCLERK OF COURT\n\nOR\n\n*Signature of Clerk or Deputy Clerk Attorney's signature*\n\nThe name, address, email address, and telephone number of the attorney representing Luc A. Despins, Chapter 11 Trustee, who issues or requests this subpoena, are:\n\n**Douglas S. Skalka, Esq.; Neubert, Pepe & Monteith, P.C.; 195 Church Street, New Haven, Connecticut 06510 dskalka@npmlaw.com; (203) 821-2000**\n\n**Notice to the person who issues or requests this subpoena**\n\nIf this subpoena commands the production of documents, electronically stored information, or tangible things, or the inspection of premises before trial, a notice and a copy of this subpoena must be served on each party before it is served on the person to whom it is directed. Fed. R. Civ. P. 45(a)(4).\n\nSoftware Copyright (c) 1996-2022 Best Case, LLC - www.bestcase.com Best Case Bankruptcy 1 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\n#### **PROOF OF SERVICE**\n\n**(This section should not be filed with the court unless required by Fed. R. Civ. P. 45.)**\n\nI received this subpoena for (*name of individual and title, if any*): on (*date*) .\n\nI served the subpoena by delivering a copy to the named person as follows:\n\non *(date)* ; or\n\nI returned the subpoena unexecuted because:\n\nUnless the subpoena was issued on behalf of the United States, or one of its officers or agents, I have also tendered to the witness the fees for one day's attendance, and the mileage allowed by law, in the amount of \\$ .\n\nMy fees are \\$ for travel and \\$ for services, for a total of \\$ .\n\nI declare under penalty of perjury that this information is true and correct.\n\nDate:\n\n*Server's signature*\n\n*Printed name and title*\n\n*Server's address*\n\nAdditional information concerning attempted service, etc.:\n\n#### **Federal Rule of Civil Procedure 45(c), (d), (e), and (g) (Effective 12/1/13) (made applicable in bankruptcy cases by Rule 9016, Federal Rules of Bankruptcy Procedure)**\n\n#### **(c) Place of compliance.**\n\n*(1) For a Trial, Hearing, or Deposition.* A subpoena may command a person to attend a trial, hearing, or deposition only as follows:\n\n(A) within 100 miles of where the person resides, is employed, or regularly transacts business in person; or\n\n(B) within the state where the person resides, is employed, or regularly transacts business in person, if the person\n\n(i) is a party or a party's officer; or\n\n(ii) is commanded to attend a trial and would not incur substantial expense.\n\n*(2) For Other Discovery.* A subpoena may command:\n\n(A) production of documents, or electronically stored information, or things at a place within 100 miles of where the person resides, is employed, or regularly transacts business in person; and\n\n(B) inspection of premises, at the premises to be inspected.\n\n#### **(d) Protecting a Person Subject to a Subpoena; Enforcement.**\n\n*(1) Avoiding Undue Burden or Expense; Sanctions.* A party or attorney responsible for issuing and serving a subpoena must take reasonable steps to avoid imposing undue burden or expense on a person subject to the subpoena. The court for the district where compliance is required must enforce this duty and impose an appropriate sanction which may include lost earnings and reasonable attorney's fees — on a party or attorney who fails to comply.\n\n#### *(2) Command to Produce Materials or Permit Inspection.*\n\n*(A) Appearance Not Required.* A person commanded to produce documents, electronically stored information, or tangible things, or to permit the inspection of premises, need not appear in person at the place of production or inspection unless also commanded to appear for a deposition, hearing, or trial.\n\n*(B) Objections.* A person commanded to produce documents or tangible things or to permit inspection may serve on the party or attorney designated in the subpoena a written objection to inspecting, copying, testing or sampling any or all of the materials or to inspecting the premises — or to producing electronically stored information in the form or forms requested. The objection must be served before the earlier of the time specified for compliance or 14 days after the subpoena is served. If an objection is made, the following rules apply:\n\n(i) At any time, on notice to the commanded person, the serving party may move the court for the district where compliance is required for an order compelling production or inspection.\n\n(ii) These acts may be required only as directed in the order, and the order must protect a person who is neither a party nor a party's officer from significant expense resulting from compliance.\n\n#### *(3) Quashing or Modifying a Subpoena.*\n\n*(A) When Required.* On timely motion, the court for the district where compliance is required must quash or modify a subpoena that:\n\n(i) fails to allow a reasonable time to comply;\n\n(ii) requires a person to comply beyond the geographical limits specified in Rule 45(c);\n\n(iii) requires disclosure of privileged or other protected matter, if no exception or waiver applies; or\n\n(iv) subjects a person to undue burden.\n\n*(B) When Permitted.* To protect a person subject to or affected by a subpoena, the court for the district where compliance is required may, on motion, quash or modify the subpoena if it requires:\n\n(i) disclosing a trade secret or other confidential research, development, or commercial information; or\n\n(ii) disclosing an unretained expert's opinion or information that does not describe specific occurrences in dispute and results from the expert's study that was not requested by a party.\n\n(C) *Specifying Conditions as an Alternative.* In the circumstances described in Rule 45(d)(3)(B), the court may, instead of quashing or modifying a subpoena, order appearance or production under specified conditions if the serving party:\n\n(i) shows a substantial need for the testimony or material that cannot be otherwise met without undue hardship; and\n\n(ii) ensures that the subpoenaed person will be reasonably compensated.\n\n#### **(e) Duties in Responding to a Subpoena.**\n\n*(1) Producing Documents or Electronically Stored Information.* These procedures apply to producing documents or electronically stored information:\n\n*(A) Documents.* A person responding to a subpoena to produce documents must produce them as they are kept in the ordinary course of business or must organize and label them to correspond to the categories in the demand.\n\n*(B) Form for Producing Electronically Stored Information Not Specified.* If a subpoena does not specify a form for producing electronically stored information, the person responding must produce it in a form or forms in which it is ordinarily maintained or in a reasonably usable form or forms.\n\n*(C) Electronically Stored Information Produced in Only One Form.* The person responding need not produce the same electronically stored information in more than one form.\n\n*(D) Inaccessible Electronically Stored Information.* The person responding need not provide discovery of electronically stored information from sources that the person identifies as not reasonably accessible because of undue burden or cost. On motion to compel discovery or for a protective order, the person responding must show that the information is not reasonably accessible because of undue burden or cost. If that showing is made, the court may nonetheless order discovery from such sources if the requesting party shows good cause, considering the limitations of Rule 26(b)(2)(C). The court may specify conditions for the discovery.\n\n#### *(2) Claiming Privilege or Protection.*\n\n*(A) Information Withheld.* A person withholding subpoenaed information under a claim that it is privileged or subject to protection as trial-preparation material must: (i) expressly make the claim; and\n\n(ii) describe the nature of the withheld documents, communications, or tangible things in a manner that, without revealing information itself privileged or protected, will enable the parties to assess the claim.\n\n*(B) Information Produced.* If information produced in response to a subpoena is subject to a claim of privilege or of protection as trial-preparation material, the person making the claim may notify any party that received the information of the claim and the basis for it. After being notified, a party must promptly return, sequester, or destroy the specified information and any copies it has; must not use or disclose the information until the claim is resolved; must take reasonable steps to retrieve the information if the party disclosed it before being notified; and may promptly present the information under seal to the court for the district where compliance is required for a determination of the claim. The person who produced the information must preserve the information until the claim is resolved.\n\n**(g) Contempt.** The court for the district where compliance is required – and also, after a motion is transferred, the issuing court – may hold in contempt a person who, having been served, fails without adequate excuse to obey the subpoena or an order related to it.\n\nFor access to subpoena materials, see Fed.R.Civ.P.45(a) Committee Note (2013)\n\n…\n\n## **Request for Production of Documents**\n\n## **I. INSTRUCTIONS**\n\n1. Unless otherwise indicated, the requests for documents set forth below, (the \"Requests,\" and each, a \"Request\"), must be responded to separately and specifically. Each Request shall be answered fully unless it is in good faith objected to, in which event the reason for Your objection shall be stated in detail, as set forth below. If an objection pertains only to a portion of a Request, or a word, phrase or clause contained within it, You are required to state Your objection to that portion only and to respond to the remainder of the Requests.\n\n2. Electronically stored information must be produced in accordance with the\n\nfollowing instructions:\n\n- a. Images. Black and white images must be 300 DPI Group IV single-page TIFF files. Color images must be produced in JPEG format. File names cannot contain embedded spaces or special characters (including the comma). Folder names cannot contain embedded spaces or special characters (including the comma). All TIFF image files must have a unique file name, i.e. Bates number. Images must be endorsed with sequential Bates numbers in the lower right corner of each image. The number of TIFF files per folder should not exceed 1000 files. Excel spreadsheets should have a placeholder image named by the Bates number of the file.\n- b. Image Load File\n\t- a. Concordance® Data File. The data file (.DAT) contains all of the fielded information that will be loaded into the Concordance® database. The first line of the .DAT file must be a header row identifying the field names. The .DAT file must use the following Concordance® default delimiters: Comma ASCII character (020) Quote þ ASCII character (254). Date fields should be provided in the format: mm/dd/yyyy. Date and time fields must be two separate fields. If documents includes imaged emails and attachments, the attachment fields must be included to preserve the parent/child relationship between an email and its attachments. An OCRPATH field must be included to provide the file path and name of the extracted text file on the produced storage media. The text file must be named after the FIRSTBATES. Do not include the text in the .DAT file. For Documents with native files, a LINK field must be included to provide the file path and\n\nname of the native file. The native file must be named after the FIRSTBATES.\n\n- b. Concordance Image® OR Opticon Cross-Reference File. The image crossreference file (.LOG or .OPT) links the images to the database records. It should be a comma-delimited file consisting of seven fields per line with a line in the cross-reference file for every image in the database with the following format: ImageID,VolumeLabel,ImageFilePath,DocumentBreak,FolderBreak,Box Break,PageCoun.\n- c. Document Text. Text must be produced as separate text files, not as fields within the .DAT file. The full path to the text file (OCRPATH) should be included in the .DAT file. It is recommended document level ANSI text files, named per the FIRSTBATES/Image Key. Extracted text files must be in a separate folder, and the number of text files per folder should not exceed 1,000 files. There should be no special characters (including commas in the folder names). Text files must be provided on a document level.\n- d. Native Production for Certain File Types. File types that reasonably require viewing in their native format for a full understanding of their content and meaning must be produced in native format. These include, but are not limited to, spreadsheets, spreadsheet-like files (Microsoft Excel, comma separated values, tab separated values, etc.), Microsoft PowerPoint or other special presentation files, database files, and audio/visual files. Provide an image of a Bates numbered slip sheet indicating the presence of a native file, and include the path to the native as a field in the .dat file. Name the produced native file with the Bates number corresponding to the slip sheet for the file. Group native files within incrementally named \"NATIVE\" directories, separate from images directories.\n- e. De-duplication. Produce a single copy of each electronic document for which exact duplicates exist. For email messages, consolidate duplicates based on MD5 hash generated from the BCC, Body, CC, From, IntMsgID, To, and Attach properties. For email attachments and standalone electronic files, consolidate duplicates based on MD5 hash of the entire file.\n- f. Metadata. Produce extracted metadata for each document in the form of a Concordance compliant load file (.dat). The first line of the .DAT file must be a header row identifying the field names. The .DAT file must use the following Concordance default delimiters: Comma , ASCII character (020) Quote þ ASCII character (254)\n\nDate fields should be provided in the format: mm/dd/yyyy. Date and time fields must be two separate fields. Required metadata listed below:\n\n# Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 259 of 1063\n\n| Field Name   | Sample Data              | Description                                                                                  |\n|--------------|--------------------------|----------------------------------------------------------------------------------------------|\n| FIRSTBATES   | EDC0000001               | First Bates number of native file document/email                                             |\n| LASTBATES    | EDC0000001               | Last Bates number of native file document/email<br>**The LASTBATES field should be populated |\n|              |                          | for single page                                                                              |\n| ATTACHRANGE  | EDC0000001<br>-          | Bates number of the first page of the parent                                                 |\n|              | EDC0000015               | document to the Bates number of the last page of                                             |\n|              |                          | the last attachment \"child\" document                                                         |\n| BEGATTACH    | EDC0000001               | First Bates number of attachment range                                                       |\n| ENDATTACH    | EDC0000015               | Last Bates number of attachment range                                                        |\n| CUSTODIAN    | Smith, John              | Email: Mailbox where the email resided                                                       |\n|              |                          | Native: Name of the individual or department                                                 |\n|              |                          | from whose files the document<br>originated                                                  |\n| FROM         | John Smith               | Email: Sender                                                                                |\n|              |                          | Native: Author(s) of document                                                                |\n|              |                          | **semi-colon should be used to separate                                                      |\n|              |                          | multiple entries                                                                             |\n| TO           | Coffman, Janice; LeeW    | Recipient(s)                                                                                 |\n|              | [mailto:LeeW@MSN.com]    | **semi-colon should be used to separate multiple                                             |\n|              |                          | entries                                                                                      |\n| CC           | Frank Thompson [mailto:  | Carbon copy recipient(s)                                                                     |\n|              | frank_Thompson@cdt.com]  | **semi-colon should be used to separate                                                      |\n|              |                          | multiple entries                                                                             |\n| BCC          | John Cain                | Blind carbon copy recipient(s)                                                               |\n|              |                          | **semi-colon should be used to separate                                                      |\n|              |                          | multiple entries                                                                             |\n| SUBJECT      | Board Meeting Minutes    | Email: Subject line of the email Native: Title                                               |\n|              |                          | of document (if available)                                                                   |\n| FILE_NAME    | BoardMeetingMinutes.docx | Native: Name of the original native file,                                                    |\n|              |                          | including extension                                                                          |\n| DATE_SENT    | 10/12/2010               | Email: Date the email was sent                                                               |\n|              |                          | Native: (empty)                                                                              |\n| TIME_SENT/   | 07:05 PM GMT             | Email: Time the email was sent/ Time zone in                                                 |\n| TIME_ZONE    |                          | which the emails were standardized                                                           |\n| TIME_ZONE    | GMT                      | The<br>time zone in which<br>the emails<br>were                                              |\n|              |                          | standardized during conversion.                                                              |\n| LINK         |  EDC0000001.msg   | Hyperlink to the email or native file document                                               |\n|              |                          | **The linked file must be named per the                                                      |\n|              |                          | FIRSTBATES number                                                                            |\n| FILE_EXTEN   | MSG                      | The file type extension                                                                      |\n|              |                          | representing                                                                                 |\n|              |                          | the Email or                                                                                 |\n| AUTHOR       | John Smith               | Email: (empty)                                                                               |\n|              |                          | Native: Author of the document                                                               |\n| DATE_CREATED | 10/10/2010               | Email: (empty)                                                                               |\n|              |                          | Native: Date the document was created                                                        |\n\n# Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 260 of 1063\n\n| TIME_CREATED | 10:25 AM                  | Email: (empty)                                  |\n|--------------|---------------------------|-------------------------------------------------|\n|              |                           | Native: Time the document was created           |\n|              |                           | **This data must be a separate field and cannot |\n|              |                           | be combined with the DATE_CREATED field         |\n| DATE_MOD     | 10/12/2010                | Email: (empty)                                  |\n|              |                           | Native: Date the document was last modified     |\n| TIME_MOD     | 07:00 PM                  | Email: (empty)                                  |\n|              |                           | Native: Time the document was last modified     |\n|              |                           | **This data must be a separate field and cannot |\n|              |                           | be combined with the DATE_MOD field             |\n| DATE_ACCESSD | 10/12/2010                | Email: (empty)                                  |\n|              |                           | Native: Date the document was last accessed     |\n| TIME_ACCESSD | 07:00 PM                  | Email: (empty)                                  |\n|              |                           | Native: Time the document was last accessed     |\n|              |                           | **This data must be a separate field and cannot |\n|              |                           | be combined with the DATE_ACCESSD field         |\n| FILE_SIZE    | 5,952                     | Size of native file<br>document/email in KB     |\n| PGCOUNT      | 1                         | Number of pages in native file document/email   |\n| PATH         |   | Email: (empty)                                  |\n|              | Agenda.doc                | Native: Path where native file document was     |\n|              |                           | stored including original file name.            |\n| INTFILEPATH  | Personal Folders\\Deleted  | Email: original location of email including     |\n|              | Items\\Board Meeting       | original file name.                             |\n|              | Minutes.msg               | Native: (empty)                                 |\n| INTMSGID     | <000805c2c71b\\$75977050\\$ | Email: Unique Message ID Native: (empty)        |\n|              | cb8306d1@MSN>             |                                                 |\n| MD5HASH      | d131dd02c5e6eec4693d9a0   | MD5 Hash value of the document.                 |\n|              | 698aff95c                 |                                                 |\n|              | 2fcab58712467eab4004583e  |                                                 |\n|              | b8fb7f89                  |                                                 |\n| OCRPATH      | TEXT/001/EDC0000001.txt   | Path to extracted text of the native file       |\n\n3. Each Request operates and should be construed independently and, unless otherwise indicated, no Request limits the scope of any other Request.\n\n4. All Documents are to be produced as kept in the usual course of business or are to be organized and labeled to correspond with the categories in these Requests.\n\n5. Each Request contained herein extends to all Documents: (a) in Your possession, custody, or control; or (b) in the possession, custody, or control of anyone acting on Your behalf,\n\n#### Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 261 of 1063\n\nincluding Your counsel or other representatives and advisors. Each Document shall be produced in its entirety.\n\n6. If You are requested to produce a Document that is no longer in Your possession, custody, or control, then Your response must (a) describe in detail the nature of the document and its contents; (b) identify the person(s) who prepared or authored the Document (and, if applicable, the Person(s) to whom the Document was sent); (c) identify the date on which the document was prepared or created; (d) state whether such Document (i) is missing or lost, (ii) has been destroyed, (iii) has been transferred, voluntarily or involuntarily, to others, or (iv) was otherwise disposed of; (e) state the reason for, and the facts and circumstances surrounding, such disposition; (f) identify the Persons who authorized such disposition; (g) identify the date or approximate date of such disposition; (h) state when the Document was most recently in Your possession, custody or control; and (i) identify the Person, if any, presently in possession, custody, or control of such Document.\n\n7. If You are requested to produce a Document that has been destroyed, then Your response must state, in addition to the information required by the preceding Instruction: (a) the reason for the Document's destruction; (b) the identity of the Person who destroyed the Document; and (c) the identity of the Person who directed that the Document be destroyed.\n\n8. If You claim that a requested Document is privileged or attorney work-product, then Your response must: (a) state (i) a description of the Document adequate to support Your contention that the Document is privileged, (ii) the title of the Document, (iii) the date of the Document, (iv) the author of the Document, (v) the addressee of the Document, (vi) the identity of each Person who received or saw the original or any draft, copy, or reproduction of the Document, (vii) whether the Document itself, or any information contained or referred to in the Document is in the possession, custody, or control of any other Persons, and if so, the identity of\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 262 of 1063\n\nsuch Persons, as well as a statement addressing how the information came into their possession, (viii) the claim of privilege under which the Document is withheld, and (ix) all of the circumstances upon which You will rely to support such claim of privilege; and (b) produce a privilege log containing all of the information requested in Part (a) of this Instruction for each Document withheld on the basis of a claim of privilege in accordance with D. Conn. L. Civ. R. 26(e). For any part of a Document Request as to which a claim of privilege or work product is not made, responsive documents should be provided in full.\n\n9. If a portion of an otherwise responsive Document contains information subject to a claim of privilege, only that portion of the Document subject to the claim of privilege shall be deleted or redacted from the Document following the instructions above, and the rest shall be produced.\n\n10. The Requests are continuing in nature. You are hereby instructed to (a) supplement or correct any responses later learned to be incomplete or incorrect immediately upon learning that a prior response was incomplete or incorrect; and (b) produce any additional Documents that are called for under the\n\n11. If a Document is in a language other than English, You should provide that Document. If a Document is in a language other than English, and an English translation exists, You should provide both Documents.\n\n12. All references to Entities includes all affiliates thereof.\n\n13. All references to individual names include all alternative names, aliased, or nicknames.\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 263 of 1063\n\n14. Unless otherwise expressly indicated, the period of time covered by the Document Requests is the period from February 5, 2012 to the date responses to the Document Requests are due.\n\n#### **II. RULES OF CONSTRUCTION**\n\n15. The use of (a) any singular noun shall be construed to include the plural, and vice versa, and (b) a verb in any tense shall be construed as the use of the verb in all other tenses.\n\n16. The terms (a) \"and\" and \"or\" shall be construed either conjunctively or disjunctively as necessary to bring within the scope of any request all responses that might otherwise be construed to be outside of its scope, and (b) \"each\" and \"any\" shall be deemed to include and encompass the words \"every\" and \"all.\"\n\n#### **III. DEFINITIONS**\n\nThe definitions supplied by D. Conn. L. Civ. R. 26(c) and the rules of construction supplied by D. Conn. L. Civ. R. 26(d), as incorporated by D. Conn. Bankr. L.R. 2004-1(a), shall apply to the Document Requests. In addition, the following terms used in these Document Requests shall have the following meanings:\n\n1. \"You\" or \"Your\" or \"Yourself\" means and refers, to First Republic Bank, together with all of its affiliates.\n\n2. \"Debtor\" means Ho Wan Kwok (a/k/a Miles Kwok, Miles Guo, Guo Wengui, Guo Haoyun, 郭文贵, or any other alias), together with his employees, agents, counsel, advisors, or anyone acting on his behalf.\n\n#### Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 264 of 1063\n\n3. \"Debtor's Son\" means Qiang Guo (a/k/a Mileson Kwok, 郭强, or any other alias), together with his employees, agents, counsel, advisors, or anyone acting on his behalf.\n\n4. \"Debtor's Daughter\" means Mei Guo (a/k/a Mei Gui, 郭美, or any other alias), together with her employees, agents, counsel, advisors, or anyone acting on her behalf.\n\n5. \"Debtor's Purported Wife\" means Hing Chi Ngok (a/k/a Hing Chi Ng, Yue Qingzhi, 岳庆芝, or any other alias), together with her employees, agents, counsel, advisors, or anyone acting on her behalf.\n\n6. \"Debtor's Family\" means, individually and collectively, the Debtor, the Debtor's Son, the Debtor's Daughter, and the Debtor's Purported Wife, and any other familial relation to the Debtor.\n\n7. \"2004 Discovery Targets\" means, individually and collectively, the Debtor, the Debtor's Family, ACA Capital Group Limited, Himalaya International Financial Group Ltd., Himalaya International Clearing Ltd., Himalaya International Payments Ltd., Himalaya International Reserves Ltd., Jesse Brown, William Je, William Je, Eastern Profit Corporation Limited, HK International Funds Investments (USA) Limited LLC, Bravo Luck Limited, Golden Spring (New York) Ltd., Lamp Capital LLC, Greenwich Land LLC, Qu Guo Jiao, Daniel Thomas Podhaskie, Yvette Wang (a/k/a Yanping Wang, a/k/a Yan Ping Wang), Ace Decade Holdings Limited, Dawn State Limited, Rule of Law Society IV Inc., Rule of Law Foundation III, Inc., Rule of Law Foundation IV, Inc., Rule of Law Fund, Rule of Law Society, GTV Media Group, Inc., Voice of Guo Media, Inc., Saraca Media Group Inc., Genever Holdings Corporation, Genever Holdings LLC, Gnews Media Group Inc., G Fashion LLC, Gmusic LLC, Gnews LLC, Geducation, GFNY, Inc., G-Club Investments Limited, G Club Operations LLC, G Club US Operations Inc., G Club US Operations LLC, G Live, LLC, Gbroadcast, LLC, Gposts LLC, HCHK Property\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 265 of 1063\n\nManagement, Inc., HCHK Technologies, Inc., FMV Ltd./Freedom Media Venture Ltd., Roscalitar 2, Himalaya New World Inc., US Himalaya Capital Inc., Hudson Diamond Holding, Inc., Hudson Diamond Holding LLC, Hudson Diamond NY LLC, Infinity Treasury Management Inc., Lexington Property and Staffing, Inc., AI Group Holdings Inc., Hamilton Capital Holdings Inc., Booming Sail New York LLC, Himalaya Ventures LLC, Himalaya Ventures LLC, Himalaya Investment LLC, New York MOS Himalaya LLC, MOS Himalaya LLC, Crane Advisory Group, Maywind Trading LLC, Gettr USA, Inc., Han Chunguang, Bingshang Jiao, Karin Maistrello, Mary Jiang, Jiaming Liu, and Wencong Wang.\n\n8. \"Including\" or any variant thereof means \"including without limitation.\"\n\n9. \"And\" and \"or\" mean \"and/or,\" and shall be construed both conjunctively as well as disjunctively in order to maximize their scope.\n\n10. \"Any\" and \"all\" and \"each\" mean \"each and every.\"\n\n11. \"Each\" and \"every\" mean \"each and every.\"\n\n12. \"Third Party\" means a Person or Entity other than Yourself.\n\n13. \"Transfer\" shall have the meaning given to it by section 101(54) of the Bankruptcy Code.\n\n14. \"Document\" means any information or thing within the scope of Fed. R. Civ. P. 34, and includes, without limitation, each and every written, recorded, or graphic matter of any kind, type, nature, or description that is or has been in Your Possession, Custody or Control, including all printed and electronic copies of electronic mail, computer files maintained in electronic form, correspondence, memoranda, tapes, stenographic or handwritten notes, written forms of any kind, charts, blueprints, drawings, sketches, graphs, plans, articles, specifications, diaries, letters,\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 266 of 1063\n\ntelegrams, photographs, minutes, contracts, agreements, surveys, computer printouts, data compilations of any kind, telexes, facsimiles, emails, text messages, instant messages, voice messages, invoices, order forms, checks, drafts, statements, credit memos, reports, position reports, summaries, indices, books, ledgers, notebooks, schedules, transparencies, recordings, catalogs, advertisements, promotional materials, films, video tapes, audio tapes, CDs, computer disks, brochures, pamphlets, punch-cards, time-slips, Tweets, social media posts, or any written or recorded materials of any other kind, and all meta-data thereof, however stored (whether in tangible or electronic form), recorded, produced, or reproduced, and also including but not limited to, drafts or copies of any of the foregoing that contain any notes, comments, or markings of any kind not found on the original documents or that are otherwise not identical to the original documents.\n\n15. \"Person(s)\" means an individual, corporation, proprietorship, partnership, association, or any other Entity. \"Person\" also includes any agent, representatives, or expert, including but not limiting to, attorneys or financial advisors.\n\n16. \"Entity\" means any natural Person, corporation, partnership, subsidiary, sole proprietorship, firm, board, joint venture, association, agency, authority, commission or other business entity or juristic Person, as well as any affiliate, agent, parent including but not limited to counsel, financial advisors, or any other representative.\n\n17. \"Regarding\" means concerning, describing, comprising, referring to, related to, supporting, favoring, opposing, bolstering, detracting from, located in, considered in connection with, bearing on, evidencing, indicating, reporting on, recording, alluding to, responding to, connected with, commenting on, in respect of, about, in relation to, discussing, showing, describing, reflecting, analyzing constituting, and being.\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 267 of 1063\n\n18. \"Relating to,\" \"relate(s) to\" or \"related to,\" when referring to any given subject matter, means, without limitation, any document that constitutes, comprises, involves, contains, embodies, reflects, identifies, states, refers directly or indirectly to, or is in any way relevant to the particular subject matter identified.\n\n19. \"Communication(s)\" means, in the broadest possible sense, and without limitation, any transmittal of information or knowledge (in the form of facts, ideas, inquiries, or otherwise). Communication(s) further refers to all conversations, agreements, inquiries, or replies, whether in person, by telephone, in writing, or by means of electronic transmittal devices, and includes, but is not limited to, all correspondence, emails, recordings, transmittal slips, memoranda, telephone communications, voice messages, telegrams, telefaxes, telecopies, telexes, instant messages, chats, text messages, postings to a message board or group chat, social media posts, tweets, videos uploaded to any video platform, telephonic notes, or notes transmitted internally or with third parties.\n\n20. \"Asset(s)\" means any item of economic value that is subject to Possession, Custody, or Control. Asset includes all real and personal property, including but limited to, real estate, land, houses, apartments, condominiums, automobiles, yachts, boats, planes, jets, helicopters, cash, bank accounts, cryptocurrencies, securities, accounts receivables, inventory, and other tangible and intangible property.\n\n#### **IV. DOCUMENTS TO BE PRODUCED**\n\n1. All Documents related to any account held by, controlled by, on behalf of, or otherwise related to any of the 2004 Discovery Targets, including any and all account statements, authorizations, power of attorney, trusts, instructions or forms, copies of cancelled checks, correspondence, and wire transfers and related correspondence and instructions.\n\n#### Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 268 of 1063\n\n2. All Documents related to any funds, securities, property, or assets belonging to, held by, controlled by, on behalf of, or otherwise related to any of the 2004 Discovery Targets, including any and all account statements, authorizations, powers of attorney, trusts, instructions or forms, copies of cancelled checks, correspondence, and wire transfers and related correspondence and instructions.\n\n3. All Documents related to any business, commerce or financial transactions, including but not limited to any loan, line of credit, bailment, deposit, swap, securities transactions, mortgage, or ISDA, with any of the 2004 Discovery Targets, including any and all account statements, authorizations, powers of attorney, trusts, instructions or forms, copies of cancelled checks, correspondence, and wire transfers and related correspondence and instructions.\n\n4. All Documents relating to any wire transfer activity relating to the 2004 Discovery Targets, regardless of the existence of any accounts, including but not limited to all wire transfer receipts, account numbers, balances, authorizations, identification information related to the parties to the transfer, correspondence, instructions, or other records.\n\n5. All Documents related to any correspondence and communications between you and the 2004 Discovery Targets.\n\n6. All Documents related to any account with any 2004 Discovery Target relating to opening of the account, authorized users of the account and maintenance of the account.\n\n7. All Documents related to any anti-money laundering, know-your-customer, or other compliance activity relating to any of the 2004 Discovery Targets, including but not limited to any information provided by any of the 2004 Discovery Targets, or learned by You.\n\n8. All Documents relating to any communications with any regulator from any country, including but not limited to the Bank of England, the United States Federal Reserve, the\n\nS.E.C., the CFTC, FINRA, China Securities Regulatory Commission, People's Bank of China, Hong Kong Securities and Futures Commission, and the Hong Kong Monetary Authority relating to any of the 2004 Discovery Targets.\n\n# Exhibit C-14\n\n#### B2540 (Form 2540 – Subpoena for Rule 2004 Examination) (12/15) Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 271 of\n\n1063\n\nUNITED STATES BANKRUPTCY COURT\n\n**District of Connecticut**\n\nIn re HO WAN KWOK, *et al*.,\n\n<sup>1</sup> Case No. 22-50073 (JAM)\n\nDebtor Chapter 11\n\n(Jointly Administered)\n\n# **SUBPOENA FOR RULE 2004 EXAMINATION**\n\nTo: **Signature Bank**\n\n(*Name of person to whom the subpoena is directed*)\n\n*Testimony:* **YOU ARE COMMANDED** to appear at the time, date, and place set forth below to testify at an examination under Rule 2004, Federal Rules of Bankruptcy Procedure. A copy of the court order authorizing the examination is attached.\n\n| PLACE                    | DATE AND TIME |\n|--------------------------|---------------|\n| Paul Hastings LLP        |               |\n| 200 Park Avenue          | [TBD]         |\n| New York, New York 10166 |               |\n|                          |               |\n\nThe examination will be recorded by this method: **Court reporter/stenographer**\n\n*Production:* You, or your representatives, must also bring with you to the examination the following documents, electronically stored information, or objects, and must permit inspection, copying, testing, or sampling of the material:\n\n#### **See Requests for Production of Documents, attached hereto.**\n\nThe following provisions of Fed. R. Civ. P. 45, made applicable in bankruptcy cases by Fed. R. Bankr. P. 9016, are attached – Rule 45(c), relating to the place of compliance; Rule 45(d), relating to your protection as a person subject to a subpoena; and Rule 45(e) and 45(g), relating to your duty to respond to this subpoena and the potential consequences of not doing so.\n\nDate: **March , 2023**\n\nCLERK OF COURT\n\nOR\n\n*Signature of Clerk or Deputy Clerk Attorney's signature*\n\nThe name, address, email address, and telephone number of the attorney representing Luc A. Despins, Chapter 11 Trustee, who issues or requests this subpoena, are:\n\n**Douglas S. Skalka, Esq.; Neubert, Pepe & Monteith, P.C.; 195 Church Street, New Haven, Connecticut 06510 dskalka@npmlaw.com; (203) 821-2000**\n\n**Notice to the person who issues or requests this subpoena**\n\nIf this subpoena commands the production of documents, electronically stored information, or tangible things, or the inspection of premises before trial, a notice and a copy of this subpoena must be served on each party before it is served on the person to whom it is directed. Fed. R. Civ. P. 45(a)(4).\n\nSoftware Copyright (c) 1996-2022 Best Case, LLC - www.bestcase.com Best Case Bankruptcy 1 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\n#### **PROOF OF SERVICE**\n\n**(This section should not be filed with the court unless required by Fed. R. Civ. P. 45.)**\n\nI received this subpoena for (*name of individual and title, if any*): on (*date*) .\n\nI served the subpoena by delivering a copy to the named person as follows:\n\non *(date)* ; or\n\nI returned the subpoena unexecuted because:\n\nUnless the subpoena was issued on behalf of the United States, or one of its officers or agents, I have also tendered to the witness the fees for one day's attendance, and the mileage allowed by law, in the amount of \\$ .\n\nMy fees are \\$ for travel and \\$ for services, for a total of \\$ .\n\nI declare under penalty of perjury that this information is true and correct.\n\nDate:\n\n*Server's signature*\n\n*Printed name and title*\n\n*Server's address*\n\nAdditional information concerning attempted service, etc.:\n\n#### **Federal Rule of Civil Procedure 45(c), (d), (e), and (g) (Effective 12/1/13) (made applicable in bankruptcy cases by Rule 9016, Federal Rules of Bankruptcy Procedure)**\n\n#### **(c) Place of compliance.**\n\n*(1) For a Trial, Hearing, or Deposition.* A subpoena may command a person to attend a trial, hearing, or deposition only as follows:\n\n(A) within 100 miles of where the person resides, is employed, or regularly transacts business in person; or\n\n(B) within the state where the person resides, is employed, or regularly transacts business in person, if the person\n\n(i) is a party or a party's officer; or\n\n(ii) is commanded to attend a trial and would not incur substantial expense.\n\n*(2) For Other Discovery.* A subpoena may command:\n\n(A) production of documents, or electronically stored information, or things at a place within 100 miles of where the person resides, is employed, or regularly transacts business in person; and\n\n(B) inspection of premises, at the premises to be inspected.\n\n#### **(d) Protecting a Person Subject to a Subpoena; Enforcement.**\n\n*(1) Avoiding Undue Burden or Expense; Sanctions.* A party or attorney responsible for issuing and serving a subpoena must take reasonable steps to avoid imposing undue burden or expense on a person subject to the subpoena. The court for the district where compliance is required must enforce this duty and impose an appropriate sanction which may include lost earnings and reasonable attorney's fees — on a party or attorney who fails to comply.\n\n#### *(2) Command to Produce Materials or Permit Inspection.*\n\n*(A) Appearance Not Required.* A person commanded to produce documents, electronically stored information, or tangible things, or to permit the inspection of premises, need not appear in person at the place of production or inspection unless also commanded to appear for a deposition, hearing, or trial.\n\n*(B) Objections.* A person commanded to produce documents or tangible things or to permit inspection may serve on the party or attorney designated in the subpoena a written objection to inspecting, copying, testing or sampling any or all of the materials or to inspecting the premises — or to producing electronically stored information in the form or forms requested. The objection must be served before the earlier of the time specified for compliance or 14 days after the subpoena is served. If an objection is made, the following rules apply:\n\n(i) At any time, on notice to the commanded person, the serving party may move the court for the district where compliance is required for an order compelling production or inspection.\n\n(ii) These acts may be required only as directed in the order, and the order must protect a person who is neither a party nor a party's officer from significant expense resulting from compliance.\n\n#### *(3) Quashing or Modifying a Subpoena.*\n\n*(A) When Required.* On timely motion, the court for the district where compliance is required must quash or modify a subpoena that:\n\n(i) fails to allow a reasonable time to comply;\n\n(ii) requires a person to comply beyond the geographical limits specified in Rule 45(c);\n\n(iii) requires disclosure of privileged or other protected matter, if no exception or waiver applies; or\n\n(iv) subjects a person to undue burden.\n\n*(B) When Permitted.* To protect a person subject to or affected by a subpoena, the court for the district where compliance is required may, on motion, quash or modify the subpoena if it requires:\n\n(i) disclosing a trade secret or other confidential research, development, or commercial information; or\n\n(ii) disclosing an unretained expert's opinion or information that does not describe specific occurrences in dispute and results from the expert's study that was not requested by a party.\n\n(C) *Specifying Conditions as an Alternative.* In the circumstances described in Rule 45(d)(3)(B), the court may, instead of quashing or modifying a subpoena, order appearance or production under specified conditions if the serving party:\n\n(i) shows a substantial need for the testimony or material that cannot be otherwise met without undue hardship; and\n\n(ii) ensures that the subpoenaed person will be reasonably compensated.\n\n#### **(e) Duties in Responding to a Subpoena.**\n\n*(1) Producing Documents or Electronically Stored Information.* These procedures apply to producing documents or electronically stored information:\n\n*(A) Documents.* A person responding to a subpoena to produce documents must produce them as they are kept in the ordinary course of business or must organize and label them to correspond to the categories in the demand.\n\n*(B) Form for Producing Electronically Stored Information Not Specified.* If a subpoena does not specify a form for producing electronically stored information, the person responding must produce it in a form or forms in which it is ordinarily maintained or in a reasonably usable form or forms.\n\n*(C) Electronically Stored Information Produced in Only One Form.* The person responding need not produce the same electronically stored information in more than one form.\n\n*(D) Inaccessible Electronically Stored Information.* The person responding need not provide discovery of electronically stored information from sources that the person identifies as not reasonably accessible because of undue burden or cost. On motion to compel discovery or for a protective order, the person responding must show that the information is not reasonably accessible because of undue burden or cost. If that showing is made, the court may nonetheless order discovery from such sources if the requesting party shows good cause, considering the limitations of Rule 26(b)(2)(C). The court may specify conditions for the discovery.\n\n#### *(2) Claiming Privilege or Protection.*\n\n*(A) Information Withheld.* A person withholding subpoenaed information under a claim that it is privileged or subject to protection as trial-preparation material must: (i) expressly make the claim; and\n\n(ii) describe the nature of the withheld documents, communications, or tangible things in a manner that, without revealing information itself privileged or protected, will enable the parties to assess the claim.\n\n*(B) Information Produced.* If information produced in response to a subpoena is subject to a claim of privilege or of protection as trial-preparation material, the person making the claim may notify any party that received the information of the claim and the basis for it. After being notified, a party must promptly return, sequester, or destroy the specified information and any copies it has; must not use or disclose the information until the claim is resolved; must take reasonable steps to retrieve the information if the party disclosed it before being notified; and may promptly present the information under seal to the court for the district where compliance is required for a determination of the claim. The person who produced the information must preserve the information until the claim is resolved.\n\n**(g) Contempt.** The court for the district where compliance is required – and also, after a motion is transferred, the issuing court – may hold in contempt a person who, having been served, fails without adequate excuse to obey the subpoena or an order related to it.\n\nFor access to subpoena materials, see Fed.R.Civ.P.45(a) Committee Note (2013)\n\n…\n\n## **Request for Production of Documents**\n\n## **I. INSTRUCTIONS**\n\n1. Unless otherwise indicated, the requests for documents set forth below, (the \"Requests,\" and each, a \"Request\"), must be responded to separately and specifically. Each Request shall be answered fully unless it is in good faith objected to, in which event the reason for Your objection shall be stated in detail, as set forth below. If an objection pertains only to a portion of a Request, or a word, phrase or clause contained within it, You are required to state Your objection to that portion only and to respond to the remainder of the Requests.\n\n2. Electronically stored information must be produced in accordance with the\n\nfollowing instructions:\n\n- a. Images. Black and white images must be 300 DPI Group IV single-page TIFF files. Color images must be produced in JPEG format. File names cannot contain embedded spaces or special characters (including the comma). Folder names cannot contain embedded spaces or special characters (including the comma). All TIFF image files must have a unique file name, i.e. Bates number. Images must be endorsed with sequential Bates numbers in the lower right corner of each image. The number of TIFF files per folder should not exceed 1000 files. Excel spreadsheets should have a placeholder image named by the Bates number of the file.\n- b. Image Load File\n\t- a. Concordance® Data File. The data file (.DAT) contains all of the fielded information that will be loaded into the Concordance® database. The first line of the .DAT file must be a header row identifying the field names. The .DAT file must use the following Concordance® default delimiters: Comma ASCII character (020) Quote þ ASCII character (254). Date fields should be provided in the format: mm/dd/yyyy. Date and time fields must be two separate fields. If documents includes imaged emails and attachments, the attachment fields must be included to preserve the parent/child relationship between an email and its attachments. An OCRPATH field must be included to provide the file path and name of the extracted text file on the produced storage media. The text file must be named after the FIRSTBATES. Do not include the text in the .DAT file. For Documents with native files, a LINK field must be included to provide the file path and\n\nname of the native file. The native file must be named after the FIRSTBATES.\n\n- b. Concordance Image® OR Opticon Cross-Reference File. The image crossreference file (.LOG or .OPT) links the images to the database records. It should be a comma-delimited file consisting of seven fields per line with a line in the cross-reference file for every image in the database with the following format: ImageID,VolumeLabel,ImageFilePath,DocumentBreak,FolderBreak,Box Break,PageCoun.\n- c. Document Text. Text must be produced as separate text files, not as fields within the .DAT file. The full path to the text file (OCRPATH) should be included in the .DAT file. It is recommended document level ANSI text files, named per the FIRSTBATES/Image Key. Extracted text files must be in a separate folder, and the number of text files per folder should not exceed 1,000 files. There should be no special characters (including commas in the folder names). Text files must be provided on a document level.\n- d. Native Production for Certain File Types. File types that reasonably require viewing in their native format for a full understanding of their content and meaning must be produced in native format. These include, but are not limited to, spreadsheets, spreadsheet-like files (Microsoft Excel, comma separated values, tab separated values, etc.), Microsoft PowerPoint or other special presentation files, database files, and audio/visual files. Provide an image of a Bates numbered slip sheet indicating the presence of a native file, and include the path to the native as a field in the .dat file. Name the produced native file with the Bates number corresponding to the slip sheet for the file. Group native files within incrementally named \"NATIVE\" directories, separate from images directories.\n- e. De-duplication. Produce a single copy of each electronic document for which exact duplicates exist. For email messages, consolidate duplicates based on MD5 hash generated from the BCC, Body, CC, From, IntMsgID, To, and Attach properties. For email attachments and standalone electronic files, consolidate duplicates based on MD5 hash of the entire file.\n- f. Metadata. Produce extracted metadata for each document in the form of a Concordance compliant load file (.dat). The first line of the .DAT file must be a header row identifying the field names. The .DAT file must use the following Concordance default delimiters: Comma , ASCII character (020) Quote þ ASCII character (254)\n\nDate fields should be provided in the format: mm/dd/yyyy. Date and time fields must be two separate fields. Required metadata listed below:\n\n# Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 276 of 1063\n\n| Field Name   | Sample Data              | Description                                                                                  |\n|--------------|--------------------------|----------------------------------------------------------------------------------------------|\n| FIRSTBATES   | EDC0000001               | First Bates number of native file document/email                                             |\n| LASTBATES    | EDC0000001               | Last Bates number of native file document/email<br>**The LASTBATES field should be populated |\n|              |                          | for single page                                                                              |\n| ATTACHRANGE  | EDC0000001<br>-          | Bates number of the first page of the parent                                                 |\n|              | EDC0000015               | document to the Bates number of the last page of                                             |\n|              |                          | the last attachment \"child\" document                                                         |\n| BEGATTACH    | EDC0000001               | First Bates number of attachment range                                                       |\n| ENDATTACH    | EDC0000015               | Last Bates number of attachment range                                                        |\n| CUSTODIAN    | Smith, John              | Email: Mailbox where the email resided                                                       |\n|              |                          | Native: Name of the individual or department                                                 |\n|              |                          | from whose files the document<br>originated                                                  |\n| FROM         | John Smith               | Email: Sender                                                                                |\n|              |                          | Native: Author(s) of document                                                                |\n|              |                          | **semi-colon should be used to separate                                                      |\n|              |                          | multiple entries                                                                             |\n| TO           | Coffman, Janice; LeeW    | Recipient(s)                                                                                 |\n|              | [mailto:LeeW@MSN.com]    | **semi-colon should be used to separate multiple                                             |\n|              |                          | entries                                                                                      |\n| CC           | Frank Thompson [mailto:  | Carbon copy recipient(s)                                                                     |\n|              | frank_Thompson@cdt.com]  | **semi-colon should be used to separate                                                      |\n|              |                          | multiple entries                                                                             |\n| BCC          | John Cain                | Blind carbon copy recipient(s)                                                               |\n|              |                          | **semi-colon should be used to separate                                                      |\n|              |                          | multiple entries                                                                             |\n| SUBJECT      | Board Meeting Minutes    | Email: Subject line of the email Native: Title                                               |\n|              |                          | of document (if available)                                                                   |\n| FILE_NAME    | BoardMeetingMinutes.docx | Native: Name of the original native file,                                                    |\n|              |                          | including extension                                                                          |\n| DATE_SENT    | 10/12/2010               | Email: Date the email was sent                                                               |\n|              |                          | Native: (empty)                                                                              |\n| TIME_SENT/   | 07:05 PM GMT             | Email: Time the email was sent/ Time zone in                                                 |\n| TIME_ZONE    |                          | which the emails were standardized                                                           |\n| TIME_ZONE    | GMT                      | The<br>time zone in which<br>the emails<br>were                                              |\n|              |                          | standardized during conversion.                                                              |\n| LINK         |  EDC0000001.msg   | Hyperlink to the email or native file document                                               |\n|              |                          | **The linked file must be named per the                                                      |\n|              |                          | FIRSTBATES number                                                                            |\n| FILE_EXTEN   | MSG                      | The file type extension                                                                      |\n|              |                          | representing                                                                                 |\n|              |                          | the Email or                                                                                 |\n| AUTHOR       | John Smith               | Email: (empty)                                                                               |\n|              |                          | Native: Author of the document                                                               |\n| DATE_CREATED | 10/10/2010               | Email: (empty)                                                                               |\n|              |                          | Native: Date the document was created                                                        |\n\n# Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 277 of 1063\n\n| TIME_CREATED | 10:25 AM                  | Email: (empty)                                  |\n|--------------|---------------------------|-------------------------------------------------|\n|              |                           | Native: Time the document was created           |\n|              |                           | **This data must be a separate field and cannot |\n|              |                           | be combined with the DATE_CREATED field         |\n| DATE_MOD     | 10/12/2010                | Email: (empty)                                  |\n|              |                           | Native: Date the document was last modified     |\n| TIME_MOD     | 07:00 PM                  | Email: (empty)                                  |\n|              |                           | Native: Time the document was last modified     |\n|              |                           | **This data must be a separate field and cannot |\n|              |                           | be combined with the DATE_MOD field             |\n| DATE_ACCESSD | 10/12/2010                | Email: (empty)                                  |\n|              |                           | Native: Date the document was last accessed     |\n| TIME_ACCESSD | 07:00 PM                  | Email: (empty)                                  |\n|              |                           | Native: Time the document was last accessed     |\n|              |                           | **This data must be a separate field and cannot |\n|              |                           | be combined with the DATE_ACCESSD field         |\n| FILE_SIZE    | 5,952                     | Size of native file<br>document/email in KB     |\n| PGCOUNT      | 1                         | Number of pages in native file document/email   |\n| PATH         |   | Email: (empty)                                  |\n|              | Agenda.doc                | Native: Path where native file document was     |\n|              |                           | stored including original file name.            |\n| INTFILEPATH  | Personal Folders\\Deleted  | Email: original location of email including     |\n|              | Items\\Board Meeting       | original file name.                             |\n|              | Minutes.msg               | Native: (empty)                                 |\n| INTMSGID     | <000805c2c71b\\$75977050\\$ | Email: Unique Message ID Native: (empty)        |\n|              | cb8306d1@MSN>             |                                                 |\n| MD5HASH      | d131dd02c5e6eec4693d9a0   | MD5 Hash value of the document.                 |\n|              | 698aff95c                 |                                                 |\n|              | 2fcab58712467eab4004583e  |                                                 |\n|              | b8fb7f89                  |                                                 |\n| OCRPATH      | TEXT/001/EDC0000001.txt   | Path to extracted text of the native file       |\n\n3. Each Request operates and should be construed independently and, unless otherwise indicated, no Request limits the scope of any other Request.\n\n4. All Documents are to be produced as kept in the usual course of business or are to be organized and labeled to correspond with the categories in these Requests.\n\n5. Each Request contained herein extends to all Documents: (a) in Your possession, custody, or control; or (b) in the possession, custody, or control of anyone acting on Your behalf,\n\n#### Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 278 of 1063\n\nincluding Your counsel or other representatives and advisors. Each Document shall be produced in its entirety.\n\n6. If You are requested to produce a Document that is no longer in Your possession, custody, or control, then Your response must (a) describe in detail the nature of the document and its contents; (b) identify the person(s) who prepared or authored the Document (and, if applicable, the Person(s) to whom the Document was sent); (c) identify the date on which the document was prepared or created; (d) state whether such Document (i) is missing or lost, (ii) has been destroyed, (iii) has been transferred, voluntarily or involuntarily, to others, or (iv) was otherwise disposed of; (e) state the reason for, and the facts and circumstances surrounding, such disposition; (f) identify the Persons who authorized such disposition; (g) identify the date or approximate date of such disposition; (h) state when the Document was most recently in Your possession, custody or control; and (i) identify the Person, if any, presently in possession, custody, or control of such Document.\n\n7. If You are requested to produce a Document that has been destroyed, then Your response must state, in addition to the information required by the preceding Instruction: (a) the reason for the Document's destruction; (b) the identity of the Person who destroyed the Document; and (c) the identity of the Person who directed that the Document be destroyed.\n\n8. If You claim that a requested Document is privileged or attorney work-product, then Your response must: (a) state (i) a description of the Document adequate to support Your contention that the Document is privileged, (ii) the title of the Document, (iii) the date of the Document, (iv) the author of the Document, (v) the addressee of the Document, (vi) the identity of each Person who received or saw the original or any draft, copy, or reproduction of the Document, (vii) whether the Document itself, or any information contained or referred to in the Document is in the possession, custody, or control of any other Persons, and if so, the identity of\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 279 of 1063\n\nsuch Persons, as well as a statement addressing how the information came into their possession, (viii) the claim of privilege under which the Document is withheld, and (ix) all of the circumstances upon which You will rely to support such claim of privilege; and (b) produce a privilege log containing all of the information requested in Part (a) of this Instruction for each Document withheld on the basis of a claim of privilege in accordance with D. Conn. L. Civ. R. 26(e). For any part of a Document Request as to which a claim of privilege or work product is not made, responsive documents should be provided in full.\n\n9. If a portion of an otherwise responsive Document contains information subject to a claim of privilege, only that portion of the Document subject to the claim of privilege shall be deleted or redacted from the Document following the instructions above, and the rest shall be produced.\n\n10. The Requests are continuing in nature. You are hereby instructed to (a) supplement or correct any responses later learned to be incomplete or incorrect immediately upon learning that a prior response was incomplete or incorrect; and (b) produce any additional Documents that are called for under the\n\n11. If a Document is in a language other than English, You should provide that Document. If a Document is in a language other than English, and an English translation exists, You should provide both Documents.\n\n12. All references to Entities includes all affiliates thereof.\n\n13. All references to individual names include all alternative names, aliased, or nicknames.\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 280 of 1063\n\n14. Unless otherwise expressly indicated, the period of time covered by the Document Requests is the period from February 5, 2012 to the date responses to the Document Requests are due.\n\n#### **II. RULES OF CONSTRUCTION**\n\n15. The use of (a) any singular noun shall be construed to include the plural, and vice versa, and (b) a verb in any tense shall be construed as the use of the verb in all other tenses.\n\n16. The terms (a) \"and\" and \"or\" shall be construed either conjunctively or disjunctively as necessary to bring within the scope of any request all responses that might otherwise be construed to be outside of its scope, and (b) \"each\" and \"any\" shall be deemed to include and encompass the words \"every\" and \"all.\"\n\n#### **III. DEFINITIONS**\n\nThe definitions supplied by D. Conn. L. Civ. R. 26(c) and the rules of construction supplied by D. Conn. L. Civ. R. 26(d), as incorporated by D. Conn. Bankr. L.R. 2004-1(a), shall apply to the Document Requests. In addition, the following terms used in these Document Requests shall have the following meanings:\n\n1. \"You\" or \"Your\" or \"Yourself\" means and refers, to Silvergate Bank, together with all of its affiliates.\n\n2. \"Debtor\" means Ho Wan Kwok (a/k/a Miles Kwok, Miles Guo, Guo Wengui, Guo Haoyun, 郭文贵, or any other alias), together with his employees, agents, counsel, advisors, or anyone acting on his behalf.\n\n#### Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 281 of 1063\n\n3. \"Debtor's Son\" means Qiang Guo (a/k/a Mileson Kwok, 郭强, or any other alias), together with his employees, agents, counsel, advisors, or anyone acting on his behalf.\n\n4. \"Debtor's Daughter\" means Mei Guo (a/k/a Mei Gui, 郭美, or any other alias), together with her employees, agents, counsel, advisors, or anyone acting on her behalf.\n\n5. \"Debtor's Purported Wife\" means Hing Chi Ngok (a/k/a Hing Chi Ng, Yue Qingzhi, 岳庆芝, or any other alias), together with her employees, agents, counsel, advisors, or anyone acting on her behalf.\n\n6. \"Debtor's Family\" means, individually and collectively, the Debtor, the Debtor's Son, the Debtor's Daughter, and the Debtor's Purported Wife, and any other familial relation to the Debtor.\n\n7. \"2004 Discovery Targets\" means, individually and collectively, the Debtor, the Debtor's Family, ACA Capital Group Limited, Himalaya International Financial Group Ltd., Himalaya International Clearing Ltd., Himalaya International Payments Ltd., Himalaya International Reserves Ltd., Jesse Brown, William Je, William Je, Eastern Profit Corporation Limited, HK International Funds Investments (USA) Limited LLC, Bravo Luck Limited, Golden Spring (New York) Ltd., Lamp Capital LLC, Greenwich Land LLC, Qu Guo Jiao, Daniel Thomas Podhaskie, Yvette Wang (a/k/a Yanping Wang, a/k/a Yan Ping Wang), Ace Decade Holdings Limited, Dawn State Limited, Rule of Law Society IV Inc., Rule of Law Foundation III, Inc., Rule of Law Foundation IV, Inc., Rule of Law Fund, Rule of Law Society, GTV Media Group, Inc., Voice of Guo Media, Inc., Saraca Media Group Inc., Genever Holdings Corporation, Genever Holdings LLC, Gnews Media Group Inc., G Fashion LLC, Gmusic LLC, Gnews LLC, Geducation, GFNY, Inc., G-Club Investments Limited, G Club Operations LLC, G Club US Operations Inc., G Club US Operations LLC, G Live, LLC, Gbroadcast, LLC, Gposts LLC, HCHK Property\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 282 of 1063\n\nManagement, Inc., HCHK Technologies, Inc., FMV Ltd./Freedom Media Venture Ltd., Roscalitar 2, Himalaya New World Inc., US Himalaya Capital Inc., Hudson Diamond Holding, Inc., Hudson Diamond Holding LLC, Hudson Diamond NY LLC, Infinity Treasury Management Inc., Lexington Property and Staffing, Inc., AI Group Holdings Inc., Hamilton Capital Holdings Inc., Booming Sail New York LLC, Himalaya Ventures LLC, Himalaya Ventures LLC, Himalaya Investment LLC, New York MOS Himalaya LLC, MOS Himalaya LLC, Crane Advisory Group, Maywind Trading LLC, Gettr USA, Inc., Han Chunguang, Bingshang Jiao, Karin Maistrello, Mary Jiang, Jiaming Liu, and Wencong Wang.\n\n8. \"Including\" or any variant thereof means \"including without limitation.\"\n\n9. \"And\" and \"or\" mean \"and/or,\" and shall be construed both conjunctively as well as disjunctively in order to maximize their scope.\n\n10. \"Any\" and \"all\" and \"each\" mean \"each and every.\"\n\n11. \"Each\" and \"every\" mean \"each and every.\"\n\n12. \"Third Party\" means a Person or Entity other than Yourself.\n\n13. \"Transfer\" shall have the meaning given to it by section 101(54) of the Bankruptcy Code.\n\n14. \"Document\" means any information or thing within the scope of Fed. R. Civ. P. 34, and includes, without limitation, each and every written, recorded, or graphic matter of any kind, type, nature, or description that is or has been in Your Possession, Custody or Control, including all printed and electronic copies of electronic mail, computer files maintained in electronic form, correspondence, memoranda, tapes, stenographic or handwritten notes, written forms of any kind, charts, blueprints, drawings, sketches, graphs, plans, articles, specifications, diaries, letters,\n\n### Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 283 of 1063\n\ntelegrams, photographs, minutes, contracts, agreements, surveys, computer printouts, data compilations of any kind, telexes, facsimiles, emails, text messages, instant messages, voice messages, invoices, order forms, checks, drafts, statements, credit memos, reports, position reports, summaries, indices, books, ledgers, notebooks, schedules, transparencies, recordings, catalogs, advertisements, promotional materials, films, video tapes, audio tapes, CDs, computer disks, brochures, pamphlets, punch-cards, time-slips, Tweets, social media posts, or any written or recorded materials of any other kind, and all meta-data thereof, however stored (whether in tangible or electronic form), recorded, produced, or reproduced, and also including but not limited to, drafts or copies of any of the foregoing that contain any notes, comments, or markings of any kind not found on the original documents or that are otherwise not identical to the original documents.\n\n15. \"Person(s)\" means an individual, corporation, proprietorship, partnership, association, or any other Entity. \"Person\" also includes any agent, representatives, or expert, including but not limiting to, attorneys or financial advisors.\n\n16. \"Entity\" means any natural Person, corporation, partnership, subsidiary, sole proprietorship, firm, board, joint venture, association, agency, authority, commission or other business entity or juristic Person, as well as any affiliate, agent, parent including but not limited to counsel, financial advisors, or any other representative.\n\n17. \"Regarding\" means concerning, describing, comprising, referring to, related to, supporting, favoring, opposing, bolstering, detracting from, located in, considered in connection with, bearing on, evidencing, indicating, reporting on, recording, alluding to, responding to, connected with, commenting on, in respect of, about, in relation to, discussing, showing, describing, reflecting, analyzing constituting, and being.\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 284 of 1063\n\n18. \"Relating to,\" \"relate(s) to\" or \"related to,\" when referring to any given subject matter, means, without limitation, any document that constitutes, comprises, involves, contains, embodies, reflects, identifies, states, refers directly or indirectly to, or is in any way relevant to the particular subject matter identified.\n\n19. \"Communication(s)\" means, in the broadest possible sense, and without limitation, any transmittal of information or knowledge (in the form of facts, ideas, inquiries, or otherwise). Communication(s) further refers to all conversations, agreements, inquiries, or replies, whether in person, by telephone, in writing, or by means of electronic transmittal devices, and includes, but is not limited to, all correspondence, emails, recordings, transmittal slips, memoranda, telephone communications, voice messages, telegrams, telefaxes, telecopies, telexes, instant messages, chats, text messages, postings to a message board or group chat, social media posts, tweets, videos uploaded to any video platform, telephonic notes, or notes transmitted internally or with third parties.\n\n20. \"Asset(s)\" means any item of economic value that is subject to Possession, Custody, or Control. Asset includes all real and personal property, including but limited to, real estate, land, houses, apartments, condominiums, automobiles, yachts, boats, planes, jets, helicopters, cash, bank accounts, cryptocurrencies, securities, accounts receivables, inventory, and other tangible and intangible property.\n\n#### **IV. DOCUMENTS TO BE PRODUCED**\n\n1. All Documents related to any account held by, controlled by, on behalf of, or otherwise related to any of the 2004 Discovery Targets, including any and all account statements, authorizations, power of attorney, trusts, instructions or forms, copies of cancelled checks, correspondence, and wire transfers and related correspondence and instructions.\n\n#### Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 285 of 1063\n\n2. All Documents related to any funds, securities, property, or assets belonging to, held by, controlled by, on behalf of, or otherwise related to any of the 2004 Discovery Targets, including any and all account statements, authorizations, powers of attorney, trusts, instructions or forms, copies of cancelled checks, correspondence, and wire transfers and related correspondence and instructions.\n\n3. All Documents related to any business, commerce or financial transactions, including but not limited to any loan, line of credit, bailment, deposit, swap, securities transactions, mortgage, or ISDA, with any of the 2004 Discovery Targets, including any and all account statements, authorizations, powers of attorney, trusts, instructions or forms, copies of cancelled checks, correspondence, and wire transfers and related correspondence and instructions.\n\n4. All Documents relating to any wire transfer activity relating to the 2004 Discovery Targets, regardless of the existence of any accounts, including but not limited to all wire transfer receipts, account numbers, balances, authorizations, identification information related to the parties to the transfer, correspondence, instructions, or other records.\n\n5. All Documents related to any correspondence and communications between you and the 2004 Discovery Targets.\n\n6. All Documents related to any account with any 2004 Discovery Target relating to opening of the account, authorized users of the account and maintenance of the account.\n\n7. All Documents related to any anti-money laundering, know-your-customer, or other compliance activity relating to any of the 2004 Discovery Targets, including but not limited to any information provided by any of the 2004 Discovery Targets, or learned by You.\n\n8. All Documents relating to any communications with any regulator from any country, including but not limited to the Bank of England, the United States Federal Reserve, the\n\nS.E.C., the CFTC, FINRA, China Securities Regulatory Commission, People's Bank of China, Hong Kong Securities and Futures Commission, and the Hong Kong Monetary Authority relating to any of the 2004 Discovery Targets.\n\nCase 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 287 of 1063\n\n# Exhibit C-15\n\n#### B2540 (Form 2540 – Subpoena for Rule 2004 Examination) (12/15) Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 288 of\n\nUNITED STATES BANKRUPTCY COURT 1063\n\n**District of Connecticut**\n\nIn re HO WAN KWOK, *et al*.,\n\n<sup>1</sup> Case No. 22-50073 (JAM)\n\nDebtor Chapter 11\n\n(Jointly Administered)\n\n## **SUBPOENA FOR RULE 2004 EXAMINATION**\n\nTo: **The Bank of Princeton**\n\n(*Name of person to whom the subpoena is directed*)\n\n*Testimony:* **YOU ARE COMMANDED** to appear at the time, date, and place set forth below to testify at an examination under Rule 2004, Federal Rules of Bankruptcy Procedure. A copy of the court order authorizing the examination is attached.\n\n| PLACE                    | DATE AND TIME |\n|--------------------------|---------------|\n| Paul Hastings LLP        |               |\n| 200 Park Avenue          | [TBD]         |\n| New York, New York 10166 |               |\n|                          |               |\n\nThe examination will be recorded by this method: **Court reporter/stenographer**\n\n*Production:* You, or your representatives, must also bring with you to the examination the following documents, electronically stored information, or objects, and must permit inspection, copying, testing, or sampling of the material:\n\n#### **See Requests for Production of Documents, attached hereto.**\n\nThe following provisions of Fed. R. Civ. P. 45, made applicable in bankruptcy cases by Fed. R. Bankr. P. 9016, are attached – Rule 45(c), relating to the place of compliance; Rule 45(d), relating to your protection as a person subject to a subpoena; and Rule 45(e) and 45(g), relating to your duty to respond to this subpoena and the potential consequences of not doing so.\n\nDate: **March , 2023**\n\nCLERK OF COURT\n\nOR\n\n*Signature of Clerk or Deputy Clerk Attorney's signature*\n\nThe name, address, email address, and telephone number of the attorney representing Luc A. Despins, Chapter 11 Trustee, who issues or requests this subpoena, are:\n\n**Douglas S. Skalka, Esq.; Neubert, Pepe & Monteith, P.C.; 195 Church Street, New Haven, Connecticut 06510 dskalka@npmlaw.com; (203) 821-2000**\n\n**Notice to the person who issues or requests this subpoena**\n\nIf this subpoena commands the production of documents, electronically stored information, or tangible things, or the inspection of premises before trial, a notice and a copy of this subpoena must be served on each party before it is served on the person to whom it is directed. Fed. R. Civ. P. 45(a)(4).\n\nSoftware Copyright (c) 1996-2022 Best Case, LLC - www.bestcase.com Best Case Bankruptcy 1 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\n#### **PROOF OF SERVICE**\n\n**(This section should not be filed with the court unless required by Fed. R. Civ. P. 45.)**\n\nI received this subpoena for (*name of individual and title, if any*): on (*date*) .\n\nI served the subpoena by delivering a copy to the named person as follows:\n\non *(date)* ; or\n\nI returned the subpoena unexecuted because:\n\nUnless the subpoena was issued on behalf of the United States, or one of its officers or agents, I have also tendered to the witness the fees for one day's attendance, and the mileage allowed by law, in the amount of \\$ .\n\nMy fees are \\$ for travel and \\$ for services, for a total of \\$ .\n\nI declare under penalty of perjury that this information is true and correct.\n\nDate:\n\n*Server's signature*\n\n*Printed name and title*\n\n*Server's address*\n\nAdditional information concerning attempted service, etc.:\n\n#### **Federal Rule of Civil Procedure 45(c), (d), (e), and (g) (Effective 12/1/13) (made applicable in bankruptcy cases by Rule 9016, Federal Rules of Bankruptcy Procedure)**\n\n#### **(c) Place of compliance.**\n\n*(1) For a Trial, Hearing, or Deposition.* A subpoena may command a person to attend a trial, hearing, or deposition only as follows:\n\n(A) within 100 miles of where the person resides, is employed, or regularly transacts business in person; or\n\n(B) within the state where the person resides, is employed, or regularly transacts business in person, if the person\n\n(i) is a party or a party's officer; or\n\n(ii) is commanded to attend a trial and would not incur substantial expense.\n\n*(2) For Other Discovery.* A subpoena may command:\n\n(A) production of documents, or electronically stored information, or things at a place within 100 miles of where the person resides, is employed, or regularly transacts business in person; and\n\n(B) inspection of premises, at the premises to be inspected.\n\n#### **(d) Protecting a Person Subject to a Subpoena; Enforcement.**\n\n*(1) Avoiding Undue Burden or Expense; Sanctions.* A party or attorney responsible for issuing and serving a subpoena must take reasonable steps to avoid imposing undue burden or expense on a person subject to the subpoena. The court for the district where compliance is required must enforce this duty and impose an appropriate sanction which may include lost earnings and reasonable attorney's fees — on a party or attorney who fails to comply.\n\n#### *(2) Command to Produce Materials or Permit Inspection.*\n\n*(A) Appearance Not Required.* A person commanded to produce documents, electronically stored information, or tangible things, or to permit the inspection of premises, need not appear in person at the place of production or inspection unless also commanded to appear for a deposition, hearing, or trial.\n\n*(B) Objections.* A person commanded to produce documents or tangible things or to permit inspection may serve on the party or attorney designated in the subpoena a written objection to inspecting, copying, testing or sampling any or all of the materials or to inspecting the premises — or to producing electronically stored information in the form or forms requested. The objection must be served before the earlier of the time specified for compliance or 14 days after the subpoena is served. If an objection is made, the following rules apply:\n\n(i) At any time, on notice to the commanded person, the serving party may move the court for the district where compliance is required for an order compelling production or inspection.\n\n(ii) These acts may be required only as directed in the order, and the order must protect a person who is neither a party nor a party's officer from significant expense resulting from compliance.\n\n#### *(3) Quashing or Modifying a Subpoena.*\n\n*(A) When Required.* On timely motion, the court for the district where compliance is required must quash or modify a subpoena that:\n\n(i) fails to allow a reasonable time to comply;\n\n(ii) requires a person to comply beyond the geographical limits specified in Rule 45(c);\n\n(iii) requires disclosure of privileged or other protected matter, if no exception or waiver applies; or\n\n(iv) subjects a person to undue burden.\n\n*(B) When Permitted.* To protect a person subject to or affected by a subpoena, the court for the district where compliance is required may, on motion, quash or modify the subpoena if it requires:\n\n(i) disclosing a trade secret or other confidential research, development, or commercial information; or\n\n(ii) disclosing an unretained expert's opinion or information that does not describe specific occurrences in dispute and results from the expert's study that was not requested by a party.\n\n(C) *Specifying Conditions as an Alternative.* In the circumstances described in Rule 45(d)(3)(B), the court may, instead of quashing or modifying a subpoena, order appearance or production under specified conditions if the serving party:\n\n(i) shows a substantial need for the testimony or material that cannot be otherwise met without undue hardship; and\n\n(ii) ensures that the subpoenaed person will be reasonably compensated.\n\n#### **(e) Duties in Responding to a Subpoena.**\n\n*(1) Producing Documents or Electronically Stored Information.* These procedures apply to producing documents or electronically stored information:\n\n*(A) Documents.* A person responding to a subpoena to produce documents must produce them as they are kept in the ordinary course of business or must organize and label them to correspond to the categories in the demand.\n\n*(B) Form for Producing Electronically Stored Information Not Specified.* If a subpoena does not specify a form for producing electronically stored information, the person responding must produce it in a form or forms in which it is ordinarily maintained or in a reasonably usable form or forms.\n\n*(C) Electronically Stored Information Produced in Only One Form.* The person responding need not produce the same electronically stored information in more than one form.\n\n*(D) Inaccessible Electronically Stored Information.* The person responding need not provide discovery of electronically stored information from sources that the person identifies as not reasonably accessible because of undue burden or cost. On motion to compel discovery or for a protective order, the person responding must show that the information is not reasonably accessible because of undue burden or cost. If that showing is made, the court may nonetheless order discovery from such sources if the requesting party shows good cause, considering the limitations of Rule 26(b)(2)(C). The court may specify conditions for the discovery.\n\n#### *(2) Claiming Privilege or Protection.*\n\n*(A) Information Withheld.* A person withholding subpoenaed information under a claim that it is privileged or subject to protection as trial-preparation material must: (i) expressly make the claim; and\n\n(ii) describe the nature of the withheld documents, communications, or tangible things in a manner that, without revealing information itself privileged or protected, will enable the parties to assess the claim.\n\n*(B) Information Produced.* If information produced in response to a subpoena is subject to a claim of privilege or of protection as trial-preparation material, the person making the claim may notify any party that received the information of the claim and the basis for it. After being notified, a party must promptly return, sequester, or destroy the specified information and any copies it has; must not use or disclose the information until the claim is resolved; must take reasonable steps to retrieve the information if the party disclosed it before being notified; and may promptly present the information under seal to the court for the district where compliance is required for a determination of the claim. The person who produced the information must preserve the information until the claim is resolved.\n\n**(g) Contempt.** The court for the district where compliance is required – and also, after a motion is transferred, the issuing court – may hold in contempt a person who, having been served, fails without adequate excuse to obey the subpoena or an order related to it.\n\nFor access to subpoena materials, see Fed.R.Civ.P.45(a) Committee Note (2013)\n\n…\n\n## **Request for Production of Documents**\n\n## **I. INSTRUCTIONS**\n\n1. Unless otherwise indicated, the requests for documents set forth below, (the \"Requests,\" and each, a \"Request\"), must be responded to separately and specifically. Each Request shall be answered fully unless it is in good faith objected to, in which event the reason for Your objection shall be stated in detail, as set forth below. If an objection pertains only to a portion of a Request, or a word, phrase or clause contained within it, You are required to state Your objection to that portion only and to respond to the remainder of the Requests.\n\n2. Electronically stored information must be produced in accordance with the\n\nfollowing instructions:\n\n- a. Images. Black and white images must be 300 DPI Group IV single-page TIFF files. Color images must be produced in JPEG format. File names cannot contain embedded spaces or special characters (including the comma). Folder names cannot contain embedded spaces or special characters (including the comma). All TIFF image files must have a unique file name, i.e. Bates number. Images must be endorsed with sequential Bates numbers in the lower right corner of each image. The number of TIFF files per folder should not exceed 1000 files. Excel spreadsheets should have a placeholder image named by the Bates number of the file.\n- b. Image Load File\n\t- a. Concordance® Data File. The data file (.DAT) contains all of the fielded information that will be loaded into the Concordance® database. The first line of the .DAT file must be a header row identifying the field names. The .DAT file must use the following Concordance® default delimiters: Comma ASCII character (020) Quote þ ASCII character (254). Date fields should be provided in the format: mm/dd/yyyy. Date and time fields must be two separate fields. If documents includes imaged emails and attachments, the attachment fields must be included to preserve the parent/child relationship between an email and its attachments. An OCRPATH field must be included to provide the file path and name of the extracted text file on the produced storage media. The text file must be named after the FIRSTBATES. Do not include the text in the .DAT file. For Documents with native files, a LINK field must be included to provide the file path and\n\nname of the native file. The native file must be named after the FIRSTBATES.\n\n- b. Concordance Image® OR Opticon Cross-Reference File. The image crossreference file (.LOG or .OPT) links the images to the database records. It should be a comma-delimited file consisting of seven fields per line with a line in the cross-reference file for every image in the database with the following format: ImageID,VolumeLabel,ImageFilePath,DocumentBreak,FolderBreak,Box Break,PageCoun.\n- c. Document Text. Text must be produced as separate text files, not as fields within the .DAT file. The full path to the text file (OCRPATH) should be included in the .DAT file. It is recommended document level ANSI text files, named per the FIRSTBATES/Image Key. Extracted text files must be in a separate folder, and the number of text files per folder should not exceed 1,000 files. There should be no special characters (including commas in the folder names). Text files must be provided on a document level.\n- d. Native Production for Certain File Types. File types that reasonably require viewing in their native format for a full understanding of their content and meaning must be produced in native format. These include, but are not limited to, spreadsheets, spreadsheet-like files (Microsoft Excel, comma separated values, tab separated values, etc.), Microsoft PowerPoint or other special presentation files, database files, and audio/visual files. Provide an image of a Bates numbered slip sheet indicating the presence of a native file, and include the path to the native as a field in the .dat file. Name the produced native file with the Bates number corresponding to the slip sheet for the file. Group native files within incrementally named \"NATIVE\" directories, separate from images directories.\n- e. De-duplication. Produce a single copy of each electronic document for which exact duplicates exist. For email messages, consolidate duplicates based on MD5 hash generated from the BCC, Body, CC, From, IntMsgID, To, and Attach properties. For email attachments and standalone electronic files, consolidate duplicates based on MD5 hash of the entire file.\n- f. Metadata. Produce extracted metadata for each document in the form of a Concordance compliant load file (.dat). The first line of the .DAT file must be a header row identifying the field names. The .DAT file must use the following Concordance default delimiters: Comma , ASCII character (020) Quote þ ASCII character (254)\n\nDate fields should be provided in the format: mm/dd/yyyy. Date and time fields must be two separate fields. Required metadata listed below:\n\n# Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 293 of 1063\n\n| Field Name   | Sample Data              | Description                                      |\n|--------------|--------------------------|--------------------------------------------------|\n| FIRSTBATES   | EDC0000001               | First Bates number of native file document/email |\n| LASTBATES    | EDC0000001               | Last Bates number of native file document/email  |\n|              |                          | **The LASTBATES field should be populated        |\n|              |                          | for single page                                  |\n| ATTACHRANGE  | EDC0000001<br>-          | Bates number of the first page of the parent     |\n|              | EDC0000015               | document to the Bates number of the last page of |\n|              |                          | the last attachment \"child\" document             |\n| BEGATTACH    | EDC0000001               | First Bates number of attachment range           |\n| ENDATTACH    | EDC0000015               | Last Bates number of attachment range            |\n| CUSTODIAN    | Smith, John              | Email: Mailbox where the email resided           |\n|              |                          | Native: Name of the individual or department     |\n|              |                          | from whose files the document<br>originated      |\n| FROM         | John Smith               | Email: Sender                                    |\n|              |                          | Native: Author(s) of document                    |\n|              |                          | **semi-colon should be used to separate          |\n|              |                          | multiple entries                                 |\n| TO           | Coffman, Janice; LeeW    | Recipient(s)                                     |\n|              | [mailto:LeeW@MSN.com]    | **semi-colon should be used to separate multiple |\n|              |                          | entries                                          |\n| CC           | Frank Thompson [mailto:  | Carbon copy recipient(s)                         |\n|              | frank_Thompson@cdt.com]  | **semi-colon should be used to separate          |\n|              |                          | multiple entries                                 |\n| BCC          | John Cain                | Blind carbon copy recipient(s)                   |\n|              |                          | **semi-colon should be used to separate          |\n|              |                          | multiple entries                                 |\n| SUBJECT      | Board Meeting Minutes    | Email: Subject line of the email Native: Title   |\n|              |                          | of document (if available)                       |\n| FILE_NAME    | BoardMeetingMinutes.docx | Native: Name of the original native file,        |\n|              |                          | including extension                              |\n| DATE_SENT    | 10/12/2010               | Email: Date the email was sent                   |\n|              |                          | Native: (empty)                                  |\n| TIME_SENT/   | 07:05 PM GMT             | Email: Time the email was sent/ Time zone in     |\n| TIME_ZONE    |                          | which the emails were standardized               |\n| TIME_ZONE    | GMT                      | The<br>time zone in which<br>the emails<br>were  |\n|              |                          | standardized during conversion.                  |\n| LINK         |  EDC0000001.msg   | Hyperlink to the email or native file document   |\n|              |                          | **The linked file must be named per the          |\n|              |                          | FIRSTBATES number                                |\n| FILE_EXTEN   | MSG                      | The file type extension                          |\n|              |                          | representing                                     |\n|              |                          | the Email or                                     |\n| AUTHOR       | John Smith               | Email: (empty)                                   |\n|              |                          | Native: Author of the document                   |\n| DATE_CREATED | 10/10/2010               | Email: (empty)                                   |\n|              |                          | Native: Date the document was created            |\n\n# Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 294 of 1063\n\n| TIME_CREATED | 10:25 AM                  | Email: (empty)                                  |\n|--------------|---------------------------|-------------------------------------------------|\n|              |                           | Native: Time the document was created           |\n|              |                           | **This data must be a separate field and cannot |\n|              |                           | be combined with the DATE_CREATED field         |\n| DATE_MOD     | 10/12/2010                | Email: (empty)                                  |\n|              |                           | Native: Date the document was last modified     |\n| TIME_MOD     | 07:00 PM                  | Email: (empty)                                  |\n|              |                           | Native: Time the document was last modified     |\n|              |                           | **This data must be a separate field and cannot |\n|              |                           | be combined with the DATE_MOD field             |\n| DATE_ACCESSD | 10/12/2010                | Email: (empty)                                  |\n|              |                           | Native: Date the document was last accessed     |\n| TIME_ACCESSD | 07:00 PM                  | Email: (empty)                                  |\n|              |                           | Native: Time the document was last accessed     |\n|              |                           | **This data must be a separate field and cannot |\n|              |                           | be combined with the DATE_ACCESSD field         |\n| FILE_SIZE    | 5,952                     | Size of native file<br>document/email in KB     |\n| PGCOUNT      | 1                         | Number of pages in native file document/email   |\n| PATH         |   | Email: (empty)                                  |\n|              | Agenda.doc                | Native: Path where native file document was     |\n|              |                           | stored including original file name.            |\n| INTFILEPATH  | Personal Folders\\Deleted  | Email: original location of email including     |\n|              | Items\\Board Meeting       | original file name.                             |\n|              | Minutes.msg               | Native: (empty)                                 |\n| INTMSGID     | <000805c2c71b\\$75977050\\$ | Email: Unique Message ID Native: (empty)        |\n|              | cb8306d1@MSN>             |                                                 |\n| MD5HASH      | d131dd02c5e6eec4693d9a0   | MD5 Hash value of the document.                 |\n|              | 698aff95c                 |                                                 |\n|              | 2fcab58712467eab4004583e  |                                                 |\n|              | b8fb7f89                  |                                                 |\n| OCRPATH      | TEXT/001/EDC0000001.txt   | Path to extracted text of the native file       |\n\n3. Each Request operates and should be construed independently and, unless otherwise indicated, no Request limits the scope of any other Request.\n\n4. All Documents are to be produced as kept in the usual course of business or are to be organized and labeled to correspond with the categories in these Requests.\n\n5. Each Request contained herein extends to all Documents: (a) in Your possession, custody, or control; or (b) in the possession, custody, or control of anyone acting on Your behalf,\n\n#### Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 295 of 1063\n\nincluding Your counsel or other representatives and advisors. Each Document shall be produced in its entirety.\n\n6. If You are requested to produce a Document that is no longer in Your possession, custody, or control, then Your response must (a) describe in detail the nature of the document and its contents; (b) identify the person(s) who prepared or authored the Document (and, if applicable, the Person(s) to whom the Document was sent); (c) identify the date on which the document was prepared or created; (d) state whether such Document (i) is missing or lost, (ii) has been destroyed, (iii) has been transferred, voluntarily or involuntarily, to others, or (iv) was otherwise disposed of; (e) state the reason for, and the facts and circumstances surrounding, such disposition; (f) identify the Persons who authorized such disposition; (g) identify the date or approximate date of such disposition; (h) state when the Document was most recently in Your possession, custody or control; and (i) identify the Person, if any, presently in possession, custody, or control of such Document.\n\n7. If You are requested to produce a Document that has been destroyed, then Your response must state, in addition to the information required by the preceding Instruction: (a) the reason for the Document's destruction; (b) the identity of the Person who destroyed the Document; and (c) the identity of the Person who directed that the Document be destroyed.\n\n8. If You claim that a requested Document is privileged or attorney work-product, then Your response must: (a) state (i) a description of the Document adequate to support Your contention that the Document is privileged, (ii) the title of the Document, (iii) the date of the Document, (iv) the author of the Document, (v) the addressee of the Document, (vi) the identity of each Person who received or saw the original or any draft, copy, or reproduction of the Document, (vii) whether the Document itself, or any information contained or referred to in the Document is in the possession, custody, or control of any other Persons, and if so, the identity of\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 296 of 1063\n\nsuch Persons, as well as a statement addressing how the information came into their possession, (viii) the claim of privilege under which the Document is withheld, and (ix) all of the circumstances upon which You will rely to support such claim of privilege; and (b) produce a privilege log containing all of the information requested in Part (a) of this Instruction for each Document withheld on the basis of a claim of privilege in accordance with D. Conn. L. Civ. R. 26(e). For any part of a Document Request as to which a claim of privilege or work product is not made, responsive documents should be provided in full.\n\n9. If a portion of an otherwise responsive Document contains information subject to a claim of privilege, only that portion of the Document subject to the claim of privilege shall be deleted or redacted from the Document following the instructions above, and the rest shall be produced.\n\n10. The Requests are continuing in nature. You are hereby instructed to (a) supplement or correct any responses later learned to be incomplete or incorrect immediately upon learning that a prior response was incomplete or incorrect; and (b) produce any additional Documents that are called for under the\n\n11. If a Document is in a language other than English, You should provide that Document. If a Document is in a language other than English, and an English translation exists, You should provide both Documents.\n\n12. All references to Entities includes all affiliates thereof.\n\n13. All references to individual names include all alternative names, aliased, or nicknames.\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 297 of 1063\n\n14. Unless otherwise expressly indicated, the period of time covered by the Document Requests is the period from February 5, 2012 to the date responses to the Document Requests are due.\n\n#### **II. RULES OF CONSTRUCTION**\n\n15. The use of (a) any singular noun shall be construed to include the plural, and vice versa, and (b) a verb in any tense shall be construed as the use of the verb in all other tenses.\n\n16. The terms (a) \"and\" and \"or\" shall be construed either conjunctively or disjunctively as necessary to bring within the scope of any request all responses that might otherwise be construed to be outside of its scope, and (b) \"each\" and \"any\" shall be deemed to include and encompass the words \"every\" and \"all.\"\n\n#### **III. DEFINITIONS**\n\nThe definitions supplied by D. Conn. L. Civ. R. 26(c) and the rules of construction supplied by D. Conn. L. Civ. R. 26(d), as incorporated by D. Conn. Bankr. L.R. 2004-1(a), shall apply to the Document Requests. In addition, the following terms used in these Document Requests shall have the following meanings:\n\n1. \"You\" or \"Your\" or \"Yourself\" means and refers, to The Bank of Princeton, together with all of its affiliates.\n\n2. \"Debtor\" means Ho Wan Kwok (a/k/a Miles Kwok, Miles Guo, Guo Wengui, Guo Haoyun, 郭文贵, or any other alias), together with his employees, agents, counsel, advisors, or anyone acting on his behalf.\n\n#### Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 298 of 1063\n\n3. \"Debtor's Son\" means Qiang Guo (a/k/a Mileson Kwok, 郭强, or any other alias), together with his employees, agents, counsel, advisors, or anyone acting on his behalf.\n\n4. \"Debtor's Daughter\" means Mei Guo (a/k/a Mei Gui, 郭美, or any other alias), together with her employees, agents, counsel, advisors, or anyone acting on her behalf.\n\n5. \"Debtor's Purported Wife\" means Hing Chi Ngok (a/k/a Hing Chi Ng, Yue Qingzhi, 岳庆芝, or any other alias), together with her employees, agents, counsel, advisors, or anyone acting on her behalf.\n\n6. \"Debtor's Family\" means, individually and collectively, the Debtor, the Debtor's Son, the Debtor's Daughter, and the Debtor's Purported Wife, and any other familial relation to the Debtor.\n\n7. \"2004 Discovery Targets\" means, individually and collectively, the Debtor, the Debtor's Family, ACA Capital Group Limited, Himalaya International Financial Group Ltd., Himalaya International Clearing Ltd., Himalaya International Payments Ltd., Himalaya International Reserves Ltd., Jesse Brown, William Je, William Je, Eastern Profit Corporation Limited, HK International Funds Investments (USA) Limited LLC, Bravo Luck Limited, Golden Spring (New York) Ltd., Lamp Capital LLC, Greenwich Land LLC, Qu Guo Jiao, Daniel Thomas Podhaskie, Yvette Wang (a/k/a Yanping Wang, a/k/a Yan Ping Wang), Ace Decade Holdings Limited, Dawn State Limited, Rule of Law Society IV Inc., Rule of Law Foundation III, Inc., Rule of Law Foundation IV, Inc., Rule of Law Fund, Rule of Law Society, GTV Media Group, Inc., Voice of Guo Media, Inc., Saraca Media Group Inc., Genever Holdings Corporation, Genever Holdings LLC, Gnews Media Group Inc., G Fashion LLC, Gmusic LLC, Gnews LLC, Geducation, GFNY, Inc., G-Club Investments Limited, G Club Operations LLC, G Club US Operations Inc., G Club US Operations LLC, G Live, LLC, Gbroadcast, LLC, Gposts LLC, HCHK Property\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 299 of 1063\n\nManagement, Inc., HCHK Technologies, Inc., FMV Ltd./Freedom Media Venture Ltd., Roscalitar 2, Himalaya New World Inc., US Himalaya Capital Inc., Hudson Diamond Holding, Inc., Hudson Diamond Holding LLC, Hudson Diamond NY LLC, Infinity Treasury Management Inc., Lexington Property and Staffing, Inc., AI Group Holdings Inc., Hamilton Capital Holdings Inc., Booming Sail New York LLC, Himalaya Ventures LLC, Himalaya Ventures LLC, Himalaya Investment LLC, New York MOS Himalaya LLC, MOS Himalaya LLC, Crane Advisory Group, Maywind Trading LLC, Gettr USA, Inc., Han Chunguang, Bingshang Jiao, Karin Maistrello, Mary Jiang, Jiaming Liu, and Wencong Wang.\n\n8. \"Including\" or any variant thereof means \"including without limitation.\"\n\n9. \"And\" and \"or\" mean \"and/or,\" and shall be construed both conjunctively as well as disjunctively in order to maximize their scope.\n\n10. \"Any\" and \"all\" and \"each\" mean \"each and every.\"\n\n11. \"Each\" and \"every\" mean \"each and every.\"\n\n12. \"Third Party\" means a Person or Entity other than Yourself.\n\n13. \"Transfer\" shall have the meaning given to it by section 101(54) of the Bankruptcy Code.\n\n14. \"Document\" means any information or thing within the scope of Fed. R. Civ. P. 34, and includes, without limitation, each and every written, recorded, or graphic matter of any kind, type, nature, or description that is or has been in Your Possession, Custody or Control, including all printed and electronic copies of electronic mail, computer files maintained in electronic form, correspondence, memoranda, tapes, stenographic or handwritten notes, written forms of any kind, charts, blueprints, drawings, sketches, graphs, plans, articles, specifications, diaries, letters,\n\n### Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 300 of 1063\n\ntelegrams, photographs, minutes, contracts, agreements, surveys, computer printouts, data compilations of any kind, telexes, facsimiles, emails, text messages, instant messages, voice messages, invoices, order forms, checks, drafts, statements, credit memos, reports, position reports, summaries, indices, books, ledgers, notebooks, schedules, transparencies, recordings, catalogs, advertisements, promotional materials, films, video tapes, audio tapes, CDs, computer disks, brochures, pamphlets, punch-cards, time-slips, Tweets, social media posts, or any written or recorded materials of any other kind, and all meta-data thereof, however stored (whether in tangible or electronic form), recorded, produced, or reproduced, and also including but not limited to, drafts or copies of any of the foregoing that contain any notes, comments, or markings of any kind not found on the original documents or that are otherwise not identical to the original documents.\n\n15. \"Person(s)\" means an individual, corporation, proprietorship, partnership, association, or any other Entity. \"Person\" also includes any agent, representatives, or expert, including but not limiting to, attorneys or financial advisors.\n\n16. \"Entity\" means any natural Person, corporation, partnership, subsidiary, sole proprietorship, firm, board, joint venture, association, agency, authority, commission or other business entity or juristic Person, as well as any affiliate, agent, parent including but not limited to counsel, financial advisors, or any other representative.\n\n17. \"Regarding\" means concerning, describing, comprising, referring to, related to, supporting, favoring, opposing, bolstering, detracting from, located in, considered in connection with, bearing on, evidencing, indicating, reporting on, recording, alluding to, responding to, connected with, commenting on, in respect of, about, in relation to, discussing, showing, describing, reflecting, analyzing constituting, and being.\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 301 of 1063\n\n18. \"Relating to,\" \"relate(s) to\" or \"related to,\" when referring to any given subject matter, means, without limitation, any document that constitutes, comprises, involves, contains, embodies, reflects, identifies, states, refers directly or indirectly to, or is in any way relevant to the particular subject matter identified.\n\n19. \"Communication(s)\" means, in the broadest possible sense, and without limitation, any transmittal of information or knowledge (in the form of facts, ideas, inquiries, or otherwise). Communication(s) further refers to all conversations, agreements, inquiries, or replies, whether in person, by telephone, in writing, or by means of electronic transmittal devices, and includes, but is not limited to, all correspondence, emails, recordings, transmittal slips, memoranda, telephone communications, voice messages, telegrams, telefaxes, telecopies, telexes, instant messages, chats, text messages, postings to a message board or group chat, social media posts, tweets, videos uploaded to any video platform, telephonic notes, or notes transmitted internally or with third parties.\n\n20. \"Asset(s)\" means any item of economic value that is subject to Possession, Custody, or Control. Asset includes all real and personal property, including but limited to, real estate, land, houses, apartments, condominiums, automobiles, yachts, boats, planes, jets, helicopters, cash, bank accounts, cryptocurrencies, securities, accounts receivables, inventory, and other tangible and intangible property.\n\n#### **IV. DOCUMENTS TO BE PRODUCED**\n\n1. All Documents related to any account held by, controlled by, on behalf of, or otherwise related to any of the 2004 Discovery Targets, including any and all account statements, authorizations, power of attorney, trusts, instructions or forms, copies of cancelled checks, correspondence, and wire transfers and related correspondence and instructions.\n\n#### Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 302 of 1063\n\n2. All Documents related to any funds, securities, property, or assets belonging to, held by, controlled by, on behalf of, or otherwise related to any of the 2004 Discovery Targets, including any and all account statements, authorizations, powers of attorney, trusts, instructions or forms, copies of cancelled checks, correspondence, and wire transfers and related correspondence and instructions.\n\n3. All Documents related to any business, commerce or financial transactions, including but not limited to any loan, line of credit, bailment, deposit, swap, securities transactions, mortgage, or ISDA, with any of the 2004 Discovery Targets, including any and all account statements, authorizations, powers of attorney, trusts, instructions or forms, copies of cancelled checks, correspondence, and wire transfers and related correspondence and instructions.\n\n4. All Documents relating to any wire transfer activity relating to the 2004 Discovery Targets, regardless of the existence of any accounts, including but not limited to all wire transfer receipts, account numbers, balances, authorizations, identification information related to the parties to the transfer, correspondence, instructions, or other records.\n\n5. All Documents related to any correspondence and communications between you and the 2004 Discovery Targets.\n\n6. All Documents related to any account with any 2004 Discovery Target relating to opening of the account, authorized users of the account and maintenance of the account.\n\n7. All Documents related to any anti-money laundering, know-your-customer, or other compliance activity relating to any of the 2004 Discovery Targets, including but not limited to any information provided by any of the 2004 Discovery Targets, or learned by You.\n\n8. All Documents relating to any communications with any regulator from any country, including but not limited to the Bank of England, the United States Federal Reserve, the\n\nS.E.C., the CFTC, FINRA, China Securities Regulatory Commission, People's Bank of China, Hong Kong Securities and Futures Commission, and the Hong Kong Monetary Authority relating to any of the 2004 Discovery Targets.\n\n# Exhibit C-16\n\n#### B2540 (Form 2540 – Subpoena for Rule 2004 Examination) (12/15) Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 305 of\n\n1063\n\nUNITED STATES BANKRUPTCY COURT\n\n**District of Connecticut**\n\nIn re HO WAN KWOK, *et al*.,\n\n<sup>1</sup> Case No. 22-50073 (JAM) Debtor Chapter 11\n\n(Jointly Administered)\n\n# **SUBPOENA FOR RULE 2004 EXAMINATION**\n\nTo: **DBS Bank Ltd.**\n\n(*Name of person to whom the subpoena is directed*)\n\n*Testimony:* **YOU ARE COMMANDED** to appear at the time, date, and place set forth below to testify at an examination under Rule 2004, Federal Rules of Bankruptcy Procedure. A copy of the court order authorizing the examination is attached.\n\n| PLACE                          | DATE AND TIME |\n|--------------------------------|---------------|\n| Neubert, Pepe & Monteith, P.C. |               |\n| 195 Church Street, Floor 13    | [TBD]         |\n| New Haven, Connecticut 06510   |               |\n|                                |               |\n\nThe examination will be recorded by this method: **Court reporter/stenographer**\n\n*Production:* You, or your representatives, must also bring with you to the examination the following documents, electronically stored information, or objects, and must permit inspection, copying, testing, or sampling of the material:\n\n#### **See Requests for Production of Documents, attached hereto.**\n\nThe following provisions of Fed. R. Civ. P. 45, made applicable in bankruptcy cases by Fed. R. Bankr. P. 9016, are attached – Rule 45(c), relating to the place of compliance; Rule 45(d), relating to your protection as a person subject to a subpoena; and Rule 45(e) and 45(g), relating to your duty to respond to this subpoena and the potential consequences of not doing so.\n\nDate: **March , 2023**\n\nCLERK OF COURT\n\nOR\n\n*Signature of Clerk or Deputy Clerk Attorney's signature*\n\nThe name, address, email address, and telephone number of the attorney representing Luc A. Despins, Chapter 11 Trustee, who issues or requests this subpoena, are:\n\n**Douglas S. Skalka, Esq.; Neubert, Pepe & Monteith, P.C.; 195 Church Street, New Haven, Connecticut 06510 dskalka@npmlaw.com; (203) 821-2000**\n\n**Notice to the person who issues or requests this subpoena**\n\nIf this subpoena commands the production of documents, electronically stored information, or tangible things, or the inspection of premises before trial, a notice and a copy of this subpoena must be served on each party before it is served on the person to whom it is directed. Fed. R. Civ. P. 45(a)(4).\n\nSoftware Copyright (c) 1996-2022 Best Case, LLC - www.bestcase.com Best Case Bankruptcy 1 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\n#### **PROOF OF SERVICE**\n\n**(This section should not be filed with the court unless required by Fed. R. Civ. P. 45.)**\n\nI received this subpoena for (*name of individual and title, if any*): on (*date*) .\n\nI served the subpoena by delivering a copy to the named person as follows:\n\non *(date)* ; or\n\nI returned the subpoena unexecuted because:\n\nUnless the subpoena was issued on behalf of the United States, or one of its officers or agents, I have also tendered to the witness the fees for one day's attendance, and the mileage allowed by law, in the amount of \\$ .\n\nMy fees are \\$ for travel and \\$ for services, for a total of \\$ .\n\nI declare under penalty of perjury that this information is true and correct.\n\nDate:\n\n*Server's signature*\n\n*Printed name and title*\n\n*Server's address*\n\nAdditional information concerning attempted service, etc.:\n\n#### **Federal Rule of Civil Procedure 45(c), (d), (e), and (g) (Effective 12/1/13) (made applicable in bankruptcy cases by Rule 9016, Federal Rules of Bankruptcy Procedure)**\n\n#### **(c) Place of compliance.**\n\n*(1) For a Trial, Hearing, or Deposition.* A subpoena may command a person to attend a trial, hearing, or deposition only as follows:\n\n(A) within 100 miles of where the person resides, is employed, or regularly transacts business in person; or\n\n(B) within the state where the person resides, is employed, or regularly transacts business in person, if the person\n\n(i) is a party or a party's officer; or\n\n(ii) is commanded to attend a trial and would not incur substantial expense.\n\n*(2) For Other Discovery.* A subpoena may command:\n\n(A) production of documents, or electronically stored information, or things at a place within 100 miles of where the person resides, is employed, or regularly transacts business in person; and\n\n(B) inspection of premises, at the premises to be inspected.\n\n#### **(d) Protecting a Person Subject to a Subpoena; Enforcement.**\n\n*(1) Avoiding Undue Burden or Expense; Sanctions.* A party or attorney responsible for issuing and serving a subpoena must take reasonable steps to avoid imposing undue burden or expense on a person subject to the subpoena. The court for the district where compliance is required must enforce this duty and impose an appropriate sanction which may include lost earnings and reasonable attorney's fees — on a party or attorney who fails to comply.\n\n#### *(2) Command to Produce Materials or Permit Inspection.*\n\n*(A) Appearance Not Required.* A person commanded to produce documents, electronically stored information, or tangible things, or to permit the inspection of premises, need not appear in person at the place of production or inspection unless also commanded to appear for a deposition, hearing, or trial.\n\n*(B) Objections.* A person commanded to produce documents or tangible things or to permit inspection may serve on the party or attorney designated in the subpoena a written objection to inspecting, copying, testing or sampling any or all of the materials or to inspecting the premises — or to producing electronically stored information in the form or forms requested. The objection must be served before the earlier of the time specified for compliance or 14 days after the subpoena is served. If an objection is made, the following rules apply:\n\n(i) At any time, on notice to the commanded person, the serving party may move the court for the district where compliance is required for an order compelling production or inspection.\n\n(ii) These acts may be required only as directed in the order, and the order must protect a person who is neither a party nor a party's officer from significant expense resulting from compliance.\n\n#### *(3) Quashing or Modifying a Subpoena.*\n\n*(A) When Required.* On timely motion, the court for the district where compliance is required must quash or modify a subpoena that:\n\n(i) fails to allow a reasonable time to comply;\n\n(ii) requires a person to comply beyond the geographical limits specified in Rule 45(c);\n\n(iii) requires disclosure of privileged or other protected matter, if no exception or waiver applies; or\n\n(iv) subjects a person to undue burden.\n\n*(B) When Permitted.* To protect a person subject to or affected by a subpoena, the court for the district where compliance is required may, on motion, quash or modify the subpoena if it requires:\n\n(i) disclosing a trade secret or other confidential research, development, or commercial information; or\n\n(ii) disclosing an unretained expert's opinion or information that does not describe specific occurrences in dispute and results from the expert's study that was not requested by a party.\n\n(C) *Specifying Conditions as an Alternative.* In the circumstances described in Rule 45(d)(3)(B), the court may, instead of quashing or modifying a subpoena, order appearance or production under specified conditions if the serving party:\n\n(i) shows a substantial need for the testimony or material that cannot be otherwise met without undue hardship; and\n\n(ii) ensures that the subpoenaed person will be reasonably compensated.\n\n#### **(e) Duties in Responding to a Subpoena.**\n\n*(1) Producing Documents or Electronically Stored Information.* These procedures apply to producing documents or electronically stored information:\n\n*(A) Documents.* A person responding to a subpoena to produce documents must produce them as they are kept in the ordinary course of business or must organize and label them to correspond to the categories in the demand.\n\n*(B) Form for Producing Electronically Stored Information Not Specified.* If a subpoena does not specify a form for producing electronically stored information, the person responding must produce it in a form or forms in which it is ordinarily maintained or in a reasonably usable form or forms.\n\n*(C) Electronically Stored Information Produced in Only One Form.* The person responding need not produce the same electronically stored information in more than one form.\n\n*(D) Inaccessible Electronically Stored Information.* The person responding need not provide discovery of electronically stored information from sources that the person identifies as not reasonably accessible because of undue burden or cost. On motion to compel discovery or for a protective order, the person responding must show that the information is not reasonably accessible because of undue burden or cost. If that showing is made, the court may nonetheless order discovery from such sources if the requesting party shows good cause, considering the limitations of Rule 26(b)(2)(C). The court may specify conditions for the discovery.\n\n#### *(2) Claiming Privilege or Protection.*\n\n*(A) Information Withheld.* A person withholding subpoenaed information under a claim that it is privileged or subject to protection as trial-preparation material must: (i) expressly make the claim; and\n\n(ii) describe the nature of the withheld documents, communications, or tangible things in a manner that, without revealing information itself privileged or protected, will enable the parties to assess the claim.\n\n*(B) Information Produced.* If information produced in response to a subpoena is subject to a claim of privilege or of protection as trial-preparation material, the person making the claim may notify any party that received the information of the claim and the basis for it. After being notified, a party must promptly return, sequester, or destroy the specified information and any copies it has; must not use or disclose the information until the claim is resolved; must take reasonable steps to retrieve the information if the party disclosed it before being notified; and may promptly present the information under seal to the court for the district where compliance is required for a determination of the claim. The person who produced the information must preserve the information until the claim is resolved.\n\n**(g) Contempt.** The court for the district where compliance is required – and also, after a motion is transferred, the issuing court – may hold in contempt a person who, having been served, fails without adequate excuse to obey the subpoena or an order related to it.\n\nFor access to subpoena materials, see Fed.R.Civ.P.45(a) Committee Note (2013)\n\n…\n\n## **Request for Production of Documents**\n\n## **I. INSTRUCTIONS**\n\n1. Unless otherwise indicated, the requests for documents set forth below, (the \"Requests,\" and each, a \"Request\"), must be responded to separately and specifically. Each Request shall be answered fully unless it is in good faith objected to, in which event the reason for Your objection shall be stated in detail, as set forth below. If an objection pertains only to a portion of a Request, or a word, phrase or clause contained within it, You are required to state Your objection to that portion only and to respond to the remainder of the Requests.\n\n2. Electronically stored information must be produced in accordance with the\n\nfollowing instructions:\n\n- a. Images. Black and white images must be 300 DPI Group IV single-page TIFF files. Color images must be produced in JPEG format. File names cannot contain embedded spaces or special characters (including the comma). Folder names cannot contain embedded spaces or special characters (including the comma). All TIFF image files must have a unique file name, i.e. Bates number. Images must be endorsed with sequential Bates numbers in the lower right corner of each image. The number of TIFF files per folder should not exceed 1000 files. Excel spreadsheets should have a placeholder image named by the Bates number of the file.\n- b. Image Load File\n\t- a. Concordance® Data File. The data file (.DAT) contains all of the fielded information that will be loaded into the Concordance® database. The first line of the .DAT file must be a header row identifying the field names. The .DAT file must use the following Concordance® default delimiters: Comma ASCII character (020) Quote þ ASCII character (254). Date fields should be provided in the format: mm/dd/yyyy. Date and time fields must be two separate fields. If documents includes imaged emails and attachments, the attachment fields must be included to preserve the parent/child relationship between an email and its attachments. An OCRPATH field must be included to provide the file path and name of the extracted text file on the produced storage media. The text file must be named after the FIRSTBATES. Do not include the text in the .DAT file. For Documents with native files, a LINK field must be included to provide the file path and\n\nname of the native file. The native file must be named after the FIRSTBATES.\n\n- b. Concordance Image® OR Opticon Cross-Reference File. The image crossreference file (.LOG or .OPT) links the images to the database records. It should be a comma-delimited file consisting of seven fields per line with a line in the cross-reference file for every image in the database with the following format: ImageID,VolumeLabel,ImageFilePath,DocumentBreak,FolderBreak,Box Break,PageCoun.\n- c. Document Text. Text must be produced as separate text files, not as fields within the .DAT file. The full path to the text file (OCRPATH) should be included in the .DAT file. It is recommended document level ANSI text files, named per the FIRSTBATES/Image Key. Extracted text files must be in a separate folder, and the number of text files per folder should not exceed 1,000 files. There should be no special characters (including commas in the folder names). Text files must be provided on a document level.\n- d. Native Production for Certain File Types. File types that reasonably require viewing in their native format for a full understanding of their content and meaning must be produced in native format. These include, but are not limited to, spreadsheets, spreadsheet-like files (Microsoft Excel, comma separated values, tab separated values, etc.), Microsoft PowerPoint or other special presentation files, database files, and audio/visual files. Provide an image of a Bates numbered slip sheet indicating the presence of a native file, and include the path to the native as a field in the .dat file. Name the produced native file with the Bates number corresponding to the slip sheet for the file. Group native files within incrementally named \"NATIVE\" directories, separate from images directories.\n- e. De-duplication. Produce a single copy of each electronic document for which exact duplicates exist. For email messages, consolidate duplicates based on MD5 hash generated from the BCC, Body, CC, From, IntMsgID, To, and Attach properties. For email attachments and standalone electronic files, consolidate duplicates based on MD5 hash of the entire file.\n- f. Metadata. Produce extracted metadata for each document in the form of a Concordance compliant load file (.dat). The first line of the .DAT file must be a header row identifying the field names. The .DAT file must use the following Concordance default delimiters: Comma , ASCII character (020) Quote þ ASCII character (254)\n\nDate fields should be provided in the format: mm/dd/yyyy. Date and time fields must be two separate fields. Required metadata listed below:\n\n# Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 310 of 1063\n\n| Field Name   | Sample Data              | Description                                      |\n|--------------|--------------------------|--------------------------------------------------|\n| FIRSTBATES   | EDC0000001               | First Bates number of native file document/email |\n| LASTBATES    | EDC0000001               | Last Bates number of native file document/email  |\n|              |                          | **The LASTBATES field should be populated        |\n|              |                          | for single page                                  |\n| ATTACHRANGE  | EDC0000001<br>-          | Bates number of the first page of the parent     |\n|              | EDC0000015               | document to the Bates number of the last page of |\n|              |                          | the last attachment \"child\" document             |\n| BEGATTACH    | EDC0000001               | First Bates number of attachment range           |\n| ENDATTACH    | EDC0000015               | Last Bates number of attachment range            |\n| CUSTODIAN    | Smith, John              | Email: Mailbox where the email resided           |\n|              |                          | Native: Name of the individual or department     |\n|              |                          | from whose files the document<br>originated      |\n| FROM         | John Smith               | Email: Sender                                    |\n|              |                          | Native: Author(s) of document                    |\n|              |                          | **semi-colon should be used to separate          |\n|              |                          | multiple entries                                 |\n| TO           | Coffman, Janice; LeeW    | Recipient(s)                                     |\n|              | [mailto:LeeW@MSN.com]    | **semi-colon should be used to separate multiple |\n|              |                          | entries                                          |\n| CC           | Frank Thompson [mailto:  | Carbon copy recipient(s)                         |\n|              | frank_Thompson@cdt.com]  | **semi-colon should be used to separate          |\n|              |                          | multiple entries                                 |\n| BCC          | John Cain                | Blind carbon copy recipient(s)                   |\n|              |                          | **semi-colon should be used to separate          |\n|              |                          | multiple entries                                 |\n| SUBJECT      | Board Meeting Minutes    | Email: Subject line of the email Native: Title   |\n|              |                          | of document (if available)                       |\n| FILE_NAME    | BoardMeetingMinutes.docx | Native: Name of the original native file,        |\n|              |                          | including extension                              |\n| DATE_SENT    | 10/12/2010               | Email: Date the email was sent                   |\n|              |                          | Native: (empty)                                  |\n| TIME_SENT/   | 07:05 PM GMT             | Email: Time the email was sent/ Time zone in     |\n| TIME_ZONE    |                          | which the emails were standardized               |\n| TIME_ZONE    | GMT                      | The<br>time zone in which<br>the emails<br>were  |\n|              |                          | standardized during conversion.                  |\n| LINK         |  EDC0000001.msg   | Hyperlink to the email or native file document   |\n|              |                          | **The linked file must be named per the          |\n|              |                          | FIRSTBATES number                                |\n| FILE_EXTEN   | MSG                      | The file type extension                          |\n|              |                          | representing                                     |\n|              |                          | the Email or                                     |\n| AUTHOR       | John Smith               | Email: (empty)                                   |\n|              |                          | Native: Author of the document                   |\n| DATE_CREATED | 10/10/2010               | Email: (empty)                                   |\n|              |                          | Native: Date the document was created            |\n\n# Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 311 of 1063\n\n| TIME_CREATED | 10:25 AM                  | Email: (empty)                                  |\n|--------------|---------------------------|-------------------------------------------------|\n|              |                           | Native: Time the document was created           |\n|              |                           | **This data must be a separate field and cannot |\n|              |                           | be combined with the DATE_CREATED field         |\n| DATE_MOD     | 10/12/2010                | Email: (empty)                                  |\n|              |                           | Native: Date the document was last modified     |\n| TIME_MOD     | 07:00 PM                  | Email: (empty)                                  |\n|              |                           | Native: Time the document was last modified     |\n|              |                           | **This data must be a separate field and cannot |\n|              |                           | be combined with the DATE_MOD field             |\n| DATE_ACCESSD | 10/12/2010                | Email: (empty)                                  |\n|              |                           | Native: Date the document was last accessed     |\n| TIME_ACCESSD | 07:00 PM                  | Email: (empty)                                  |\n|              |                           | Native: Time the document was last accessed     |\n|              |                           | **This data must be a separate field and cannot |\n|              |                           | be combined with the DATE_ACCESSD field         |\n| FILE_SIZE    | 5,952                     | Size of native file<br>document/email in KB     |\n| PGCOUNT      | 1                         | Number of pages in native file document/email   |\n| PATH         |   | Email: (empty)                                  |\n|              | Agenda.doc                | Native: Path where native file document was     |\n|              |                           | stored including original file name.            |\n| INTFILEPATH  | Personal Folders\\Deleted  | Email: original location of email including     |\n|              | Items\\Board Meeting       | original file name.                             |\n|              | Minutes.msg               | Native: (empty)                                 |\n| INTMSGID     | <000805c2c71b\\$75977050\\$ | Email: Unique Message ID Native: (empty)        |\n|              | cb8306d1@MSN>             |                                                 |\n| MD5HASH      | d131dd02c5e6eec4693d9a0   | MD5 Hash value of the document.                 |\n|              | 698aff95c                 |                                                 |\n|              | 2fcab58712467eab4004583e  |                                                 |\n|              | b8fb7f89                  |                                                 |\n| OCRPATH      | TEXT/001/EDC0000001.txt   | Path to extracted text of the native file       |\n\n3. Each Request operates and should be construed independently and, unless otherwise indicated, no Request limits the scope of any other Request.\n\n4. All Documents are to be produced as kept in the usual course of business or are to be organized and labeled to correspond with the categories in these Requests.\n\n5. Each Request contained herein extends to all Documents: (a) in Your possession, custody, or control; or (b) in the possession, custody, or control of anyone acting on Your behalf,\n\n#### Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 312 of 1063\n\nincluding Your counsel or other representatives and advisors. Each Document shall be produced in its entirety.\n\n6. If You are requested to produce a Document that is no longer in Your possession, custody, or control, then Your response must (a) describe in detail the nature of the document and its contents; (b) identify the person(s) who prepared or authored the Document (and, if applicable, the Person(s) to whom the Document was sent); (c) identify the date on which the document was prepared or created; (d) state whether such Document (i) is missing or lost, (ii) has been destroyed, (iii) has been transferred, voluntarily or involuntarily, to others, or (iv) was otherwise disposed of; (e) state the reason for, and the facts and circumstances surrounding, such disposition; (f) identify the Persons who authorized such disposition; (g) identify the date or approximate date of such disposition; (h) state when the Document was most recently in Your possession, custody or control; and (i) identify the Person, if any, presently in possession, custody, or control of such Document.\n\n7. If You are requested to produce a Document that has been destroyed, then Your response must state, in addition to the information required by the preceding Instruction: (a) the reason for the Document's destruction; (b) the identity of the Person who destroyed the Document; and (c) the identity of the Person who directed that the Document be destroyed.\n\n8. If You claim that a requested Document is privileged or attorney work-product, then Your response must: (a) state (i) a description of the Document adequate to support Your contention that the Document is privileged, (ii) the title of the Document, (iii) the date of the Document, (iv) the author of the Document, (v) the addressee of the Document, (vi) the identity of each Person who received or saw the original or any draft, copy, or reproduction of the Document, (vii) whether the Document itself, or any information contained or referred to in the Document is in the possession, custody, or control of any other Persons, and if so, the identity of\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 313 of 1063\n\nsuch Persons, as well as a statement addressing how the information came into their possession, (viii) the claim of privilege under which the Document is withheld, and (ix) all of the circumstances upon which You will rely to support such claim of privilege; and (b) produce a privilege log containing all of the information requested in Part (a) of this Instruction for each Document withheld on the basis of a claim of privilege in accordance with D. Conn. L. Civ. R. 26(e). For any part of a Document Request as to which a claim of privilege or work product is not made, responsive documents should be provided in full.\n\n9. If a portion of an otherwise responsive Document contains information subject to a claim of privilege, only that portion of the Document subject to the claim of privilege shall be deleted or redacted from the Document following the instructions above, and the rest shall be produced.\n\n10. The Requests are continuing in nature. You are hereby instructed to (a) supplement or correct any responses later learned to be incomplete or incorrect immediately upon learning that a prior response was incomplete or incorrect; and (b) produce any additional Documents that are called for under the\n\n11. If a Document is in a language other than English, You should provide that Document. If a Document is in a language other than English, and an English translation exists, You should provide both Documents.\n\n12. All references to Entities includes all affiliates thereof.\n\n13. All references to individual names include all alternative names, aliased, or nicknames.\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 314 of 1063\n\n14. Unless otherwise expressly indicated, the period of time covered by the Document Requests is the period from February 5, 2012 to the date responses to the Document Requests are due.\n\n#### **II. RULES OF CONSTRUCTION**\n\n15. The use of (a) any singular noun shall be construed to include the plural, and vice versa, and (b) a verb in any tense shall be construed as the use of the verb in all other tenses.\n\n16. The terms (a) \"and\" and \"or\" shall be construed either conjunctively or disjunctively as necessary to bring within the scope of any request all responses that might otherwise be construed to be outside of its scope, and (b) \"each\" and \"any\" shall be deemed to include and encompass the words \"every\" and \"all.\"\n\n#### **III. DEFINITIONS**\n\nThe definitions supplied by D. Conn. L. Civ. R. 26(c) and the rules of construction supplied by D. Conn. L. Civ. R. 26(d), as incorporated by D. Conn. Bankr. L.R. 2004-1(a), shall apply to the Document Requests. In addition, the following terms used in these Document Requests shall have the following meanings:\n\n1. \"You\" or \"Your\" or \"Yourself\" means and refers, to DBS Bank Ltd., together with all of its affiliates.\n\n2. \"Debtor\" means Ho Wan Kwok (a/k/a Miles Kwok, Miles Guo, Guo Wengui, Guo Haoyun, 郭文贵, or any other alias), together with his employees, agents, counsel, advisors, or anyone acting on his behalf.\n\n#### Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 315 of 1063\n\n3. \"Debtor's Son\" means Qiang Guo (a/k/a Mileson Kwok, 郭强, or any other alias), together with his employees, agents, counsel, advisors, or anyone acting on his behalf.\n\n4. \"Debtor's Daughter\" means Mei Guo (a/k/a Mei Gui, 郭美, or any other alias), together with her employees, agents, counsel, advisors, or anyone acting on her behalf.\n\n5. \"Debtor's Purported Wife\" means Hing Chi Ngok (a/k/a Hing Chi Ng, Yue Qingzhi, 岳庆芝, or any other alias), together with her employees, agents, counsel, advisors, or anyone acting on her behalf.\n\n6. \"Debtor's Family\" means, individually and collectively, the Debtor, the Debtor's Son, the Debtor's Daughter, and the Debtor's Purported Wife, and any other familial relation to the Debtor.\n\n7. \"2004 Discovery Targets\" means, individually and collectively, the Debtor, the Debtor's Family, ACA Capital Group Limited, Himalaya International Financial Group Ltd., Himalaya International Clearing Ltd., Himalaya International Payments Ltd., Himalaya International Reserves Ltd., Jesse Brown, William Je, William Je, Eastern Profit Corporation Limited, HK International Funds Investments (USA) Limited LLC, Bravo Luck Limited, Golden Spring (New York) Ltd., Lamp Capital LLC, Greenwich Land LLC, Qu Guo Jiao, Daniel Thomas Podhaskie, Yvette Wang (a/k/a Yanping Wang, a/k/a Yan Ping Wang), Ace Decade Holdings Limited, Dawn State Limited, Rule of Law Society IV Inc., Rule of Law Foundation III, Inc., Rule of Law Foundation IV, Inc., Rule of Law Fund, Rule of Law Society, GTV Media Group, Inc., Voice of Guo Media, Inc., Saraca Media Group Inc., Genever Holdings Corporation, Genever Holdings LLC, Gnews Media Group Inc., G Fashion LLC, Gmusic LLC, Gnews LLC, Geducation, GFNY, Inc., G-Club Investments Limited, G Club Operations LLC, G Club US Operations Inc., G Club US Operations LLC, G Live, LLC, Gbroadcast, LLC, Gposts LLC, HCHK Property\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 316 of 1063\n\nManagement, Inc., HCHK Technologies, Inc., FMV Ltd./Freedom Media Venture Ltd., Roscalitar 2, Himalaya New World Inc., US Himalaya Capital Inc., Hudson Diamond Holding, Inc., Hudson Diamond Holding LLC, Hudson Diamond NY LLC, Infinity Treasury Management Inc., Lexington Property and Staffing, Inc., AI Group Holdings Inc., Hamilton Capital Holdings Inc., Booming Sail New York LLC, Himalaya Ventures LLC, Himalaya Ventures LLC, Himalaya Investment LLC, New York MOS Himalaya LLC, MOS Himalaya LLC, Crane Advisory Group, Maywind Trading LLC, Gettr USA, Inc., Han Chunguang, Bingshang Jiao, Karin Maistrello, Mary Jiang, Jiaming Liu, and Wencong Wang.\n\n8. \"Including\" or any variant thereof means \"including without limitation.\"\n\n9. \"And\" and \"or\" mean \"and/or,\" and shall be construed both conjunctively as well as disjunctively in order to maximize their scope.\n\n10. \"Any\" and \"all\" and \"each\" mean \"each and every.\"\n\n11. \"Each\" and \"every\" mean \"each and every.\"\n\n12. \"Third Party\" means a Person or Entity other than Yourself.\n\n13. \"Transfer\" shall have the meaning given to it by section 101(54) of the Bankruptcy Code.\n\n14. \"Document\" means any information or thing within the scope of Fed. R. Civ. P. 34, and includes, without limitation, each and every written, recorded, or graphic matter of any kind, type, nature, or description that is or has been in Your Possession, Custody or Control, including all printed and electronic copies of electronic mail, computer files maintained in electronic form, correspondence, memoranda, tapes, stenographic or handwritten notes, written forms of any kind, charts, blueprints, drawings, sketches, graphs, plans, articles, specifications, diaries, letters,\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 317 of 1063\n\ntelegrams, photographs, minutes, contracts, agreements, surveys, computer printouts, data compilations of any kind, telexes, facsimiles, emails, text messages, instant messages, voice messages, invoices, order forms, checks, drafts, statements, credit memos, reports, position reports, summaries, indices, books, ledgers, notebooks, schedules, transparencies, recordings, catalogs, advertisements, promotional materials, films, video tapes, audio tapes, CDs, computer disks, brochures, pamphlets, punch-cards, time-slips, Tweets, social media posts, or any written or recorded materials of any other kind, and all meta-data thereof, however stored (whether in tangible or electronic form), recorded, produced, or reproduced, and also including but not limited to, drafts or copies of any of the foregoing that contain any notes, comments, or markings of any kind not found on the original documents or that are otherwise not identical to the original documents.\n\n15. \"Person(s)\" means an individual, corporation, proprietorship, partnership, association, or any other Entity. \"Person\" also includes any agent, representatives, or expert, including but not limiting to, attorneys or financial advisors.\n\n16. \"Entity\" means any natural Person, corporation, partnership, subsidiary, sole proprietorship, firm, board, joint venture, association, agency, authority, commission or other business entity or juristic Person, as well as any affiliate, agent, parent including but not limited to counsel, financial advisors, or any other representative.\n\n17. \"Regarding\" means concerning, describing, comprising, referring to, related to, supporting, favoring, opposing, bolstering, detracting from, located in, considered in connection with, bearing on, evidencing, indicating, reporting on, recording, alluding to, responding to, connected with, commenting on, in respect of, about, in relation to, discussing, showing, describing, reflecting, analyzing constituting, and being.\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 318 of 1063\n\n18. \"Relating to,\" \"relate(s) to\" or \"related to,\" when referring to any given subject matter, means, without limitation, any document that constitutes, comprises, involves, contains, embodies, reflects, identifies, states, refers directly or indirectly to, or is in any way relevant to the particular subject matter identified.\n\n19. \"Communication(s)\" means, in the broadest possible sense, and without limitation, any transmittal of information or knowledge (in the form of facts, ideas, inquiries, or otherwise). Communication(s) further refers to all conversations, agreements, inquiries, or replies, whether in person, by telephone, in writing, or by means of electronic transmittal devices, and includes, but is not limited to, all correspondence, emails, recordings, transmittal slips, memoranda, telephone communications, voice messages, telegrams, telefaxes, telecopies, telexes, instant messages, chats, text messages, postings to a message board or group chat, social media posts, tweets, videos uploaded to any video platform, telephonic notes, or notes transmitted internally or with third parties.\n\n20. \"Asset(s)\" means any item of economic value that is subject to Possession, Custody, or Control. Asset includes all real and personal property, including but limited to, real estate, land, houses, apartments, condominiums, automobiles, yachts, boats, planes, jets, helicopters, cash, bank accounts, cryptocurrencies, securities, accounts receivables, inventory, and other tangible and intangible property.\n\n#### **IV. DOCUMENTS TO BE PRODUCED**\n\n1. All Documents related to any account held by, controlled by, on behalf of, or otherwise related to any of the 2004 Discovery Targets, including any and all account statements, authorizations, power of attorney, trusts, instructions or forms, copies of cancelled checks, correspondence, and wire transfers and related correspondence and instructions.\n\n#### Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 319 of 1063\n\n2. All Documents related to any funds, securities, property, or assets belonging to, held by, controlled by, on behalf of, or otherwise related to any of the 2004 Discovery Targets, including any and all account statements, authorizations, powers of attorney, trusts, instructions or forms, copies of cancelled checks, correspondence, and wire transfers and related correspondence and instructions.\n\n3. All Documents related to any business, commerce or financial transactions, including but not limited to any loan, line of credit, bailment, deposit, swap, securities transactions, mortgage, or ISDA, with any of the 2004 Discovery Targets, including any and all account statements, authorizations, powers of attorney, trusts, instructions or forms, copies of cancelled checks, correspondence, and wire transfers and related correspondence and instructions.\n\n4. All Documents relating to any wire transfer activity relating to the 2004 Discovery Targets, regardless of the existence of any accounts, including but not limited to all wire transfer receipts, account numbers, balances, authorizations, identification information related to the parties to the transfer, correspondence, instructions, or other records.\n\n5. All Documents related to any correspondence and communications between you and the 2004 Discovery Targets.\n\n6. All Documents related to any account with any 2004 Discovery Target relating to opening of the account, authorized users of the account and maintenance of the account.\n\n7. All Documents related to any anti-money laundering, know-your-customer, or other compliance activity relating to any of the 2004 Discovery Targets, including but not limited to any information provided by any of the 2004 Discovery Targets, or learned by You.\n\n8. All Documents relating to any communications with any regulator from any country, including but not limited to the Bank of England, the United States Federal Reserve, the\n\nS.E.C., the CFTC, FINRA, China Securities Regulatory Commission, People's Bank of China, Hong Kong Securities and Futures Commission, and the Hong Kong Monetary Authority relating to any of the 2004 Discovery Targets.\n\nCase 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 321 of 1063\n\n# Exhibit C-17\n\n#### B2540 (Form 2540 – Subpoena for Rule 2004 Examination) (12/15) Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 322 of\n\nUNITED STATES BANKRUPTCY COURT 1063\n\n**District of Connecticut**\n\nIn re HO WAN KWOK, *et al*.,\n\n<sup>1</sup> Case No. 22-50073 (JAM)\n\nDebtor Chapter 11\n\n(Jointly Administered)\n\n# **SUBPOENA FOR RULE 2004 EXAMINATION**\n\nTo: **The First Bank of Greenwich**\n\n(*Name of person to whom the subpoena is directed*)\n\n*Testimony:* **YOU ARE COMMANDED** to appear at the time, date, and place set forth below to testify at an examination under Rule 2004, Federal Rules of Bankruptcy Procedure. A copy of the court order authorizing the examination is attached.\n\n| PLACE                    | DATE AND TIME |\n|--------------------------|---------------|\n| Paul Hastings LLP        |               |\n| 200 Park Avenue          | [TBD]         |\n| New York, New York 10166 |               |\n|                          |               |\n\nThe examination will be recorded by this method: **Court reporter/stenographer**\n\n*Production:* You, or your representatives, must also bring with you to the examination the following documents, electronically stored information, or objects, and must permit inspection, copying, testing, or sampling of the material:\n\n#### **See Requests for Production of Documents, attached hereto.**\n\nThe following provisions of Fed. R. Civ. P. 45, made applicable in bankruptcy cases by Fed. R. Bankr. P. 9016, are attached – Rule 45(c), relating to the place of compliance; Rule 45(d), relating to your protection as a person subject to a subpoena; and Rule 45(e) and 45(g), relating to your duty to respond to this subpoena and the potential consequences of not doing so.\n\nDate: **March , 2023**\n\nCLERK OF COURT\n\nOR\n\n*Signature of Clerk or Deputy Clerk Attorney's signature*\n\nThe name, address, email address, and telephone number of the attorney representing Luc A. Despins, Chapter 11 Trustee, who issues or requests this subpoena, are:\n\n**Douglas S. Skalka, Esq.; Neubert, Pepe & Monteith, P.C.; 195 Church Street, New Haven, Connecticut 06510 dskalka@npmlaw.com; (203) 821-2000**\n\n**Notice to the person who issues or requests this subpoena**\n\nIf this subpoena commands the production of documents, electronically stored information, or tangible things, or the inspection of premises before trial, a notice and a copy of this subpoena must be served on each party before it is served on the person to whom it is directed. Fed. R. Civ. P. 45(a)(4).\n\nSoftware Copyright (c) 1996-2022 Best Case, LLC - www.bestcase.com Best Case Bankruptcy 1 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\n#### **PROOF OF SERVICE**\n\n**(This section should not be filed with the court unless required by Fed. R. Civ. P. 45.)**\n\nI received this subpoena for (*name of individual and title, if any*): on (*date*) .\n\nI served the subpoena by delivering a copy to the named person as follows:\n\non *(date)* ; or\n\nI returned the subpoena unexecuted because:\n\nUnless the subpoena was issued on behalf of the United States, or one of its officers or agents, I have also tendered to the witness the fees for one day's attendance, and the mileage allowed by law, in the amount of \\$ .\n\nMy fees are \\$ for travel and \\$ for services, for a total of \\$ .\n\nI declare under penalty of perjury that this information is true and correct.\n\nDate:\n\n*Server's signature*\n\n*Printed name and title*\n\n*Server's address*\n\nAdditional information concerning attempted service, etc.:\n\n#### **Federal Rule of Civil Procedure 45(c), (d), (e), and (g) (Effective 12/1/13) (made applicable in bankruptcy cases by Rule 9016, Federal Rules of Bankruptcy Procedure)**\n\n#### **(c) Place of compliance.**\n\n*(1) For a Trial, Hearing, or Deposition.* A subpoena may command a person to attend a trial, hearing, or deposition only as follows:\n\n(A) within 100 miles of where the person resides, is employed, or regularly transacts business in person; or\n\n(B) within the state where the person resides, is employed, or regularly transacts business in person, if the person\n\n(i) is a party or a party's officer; or\n\n(ii) is commanded to attend a trial and would not incur substantial expense.\n\n*(2) For Other Discovery.* A subpoena may command:\n\n(A) production of documents, or electronically stored information, or things at a place within 100 miles of where the person resides, is employed, or regularly transacts business in person; and\n\n(B) inspection of premises, at the premises to be inspected.\n\n#### **(d) Protecting a Person Subject to a Subpoena; Enforcement.**\n\n*(1) Avoiding Undue Burden or Expense; Sanctions.* A party or attorney responsible for issuing and serving a subpoena must take reasonable steps to avoid imposing undue burden or expense on a person subject to the subpoena. The court for the district where compliance is required must enforce this duty and impose an appropriate sanction which may include lost earnings and reasonable attorney's fees — on a party or attorney who fails to comply.\n\n#### *(2) Command to Produce Materials or Permit Inspection.*\n\n*(A) Appearance Not Required.* A person commanded to produce documents, electronically stored information, or tangible things, or to permit the inspection of premises, need not appear in person at the place of production or inspection unless also commanded to appear for a deposition, hearing, or trial.\n\n*(B) Objections.* A person commanded to produce documents or tangible things or to permit inspection may serve on the party or attorney designated in the subpoena a written objection to inspecting, copying, testing or sampling any or all of the materials or to inspecting the premises — or to producing electronically stored information in the form or forms requested. The objection must be served before the earlier of the time specified for compliance or 14 days after the subpoena is served. If an objection is made, the following rules apply:\n\n(i) At any time, on notice to the commanded person, the serving party may move the court for the district where compliance is required for an order compelling production or inspection.\n\n(ii) These acts may be required only as directed in the order, and the order must protect a person who is neither a party nor a party's officer from significant expense resulting from compliance.\n\n#### *(3) Quashing or Modifying a Subpoena.*\n\n*(A) When Required.* On timely motion, the court for the district where compliance is required must quash or modify a subpoena that:\n\n(i) fails to allow a reasonable time to comply;\n\n(ii) requires a person to comply beyond the geographical limits specified in Rule 45(c);\n\n(iii) requires disclosure of privileged or other protected matter, if no exception or waiver applies; or\n\n(iv) subjects a person to undue burden.\n\n*(B) When Permitted.* To protect a person subject to or affected by a subpoena, the court for the district where compliance is required may, on motion, quash or modify the subpoena if it requires:\n\n(i) disclosing a trade secret or other confidential research, development, or commercial information; or\n\n(ii) disclosing an unretained expert's opinion or information that does not describe specific occurrences in dispute and results from the expert's study that was not requested by a party.\n\n(C) *Specifying Conditions as an Alternative.* In the circumstances described in Rule 45(d)(3)(B), the court may, instead of quashing or modifying a subpoena, order appearance or production under specified conditions if the serving party:\n\n(i) shows a substantial need for the testimony or material that cannot be otherwise met without undue hardship; and\n\n(ii) ensures that the subpoenaed person will be reasonably compensated.\n\n#### **(e) Duties in Responding to a Subpoena.**\n\n*(1) Producing Documents or Electronically Stored Information.* These procedures apply to producing documents or electronically stored information:\n\n*(A) Documents.* A person responding to a subpoena to produce documents must produce them as they are kept in the ordinary course of business or must organize and label them to correspond to the categories in the demand.\n\n*(B) Form for Producing Electronically Stored Information Not Specified.* If a subpoena does not specify a form for producing electronically stored information, the person responding must produce it in a form or forms in which it is ordinarily maintained or in a reasonably usable form or forms.\n\n*(C) Electronically Stored Information Produced in Only One Form.* The person responding need not produce the same electronically stored information in more than one form.\n\n*(D) Inaccessible Electronically Stored Information.* The person responding need not provide discovery of electronically stored information from sources that the person identifies as not reasonably accessible because of undue burden or cost. On motion to compel discovery or for a protective order, the person responding must show that the information is not reasonably accessible because of undue burden or cost. If that showing is made, the court may nonetheless order discovery from such sources if the requesting party shows good cause, considering the limitations of Rule 26(b)(2)(C). The court may specify conditions for the discovery.\n\n#### *(2) Claiming Privilege or Protection.*\n\n*(A) Information Withheld.* A person withholding subpoenaed information under a claim that it is privileged or subject to protection as trial-preparation material must: (i) expressly make the claim; and\n\n(ii) describe the nature of the withheld documents, communications, or tangible things in a manner that, without revealing information itself privileged or protected, will enable the parties to assess the claim.\n\n*(B) Information Produced.* If information produced in response to a subpoena is subject to a claim of privilege or of protection as trial-preparation material, the person making the claim may notify any party that received the information of the claim and the basis for it. After being notified, a party must promptly return, sequester, or destroy the specified information and any copies it has; must not use or disclose the information until the claim is resolved; must take reasonable steps to retrieve the information if the party disclosed it before being notified; and may promptly present the information under seal to the court for the district where compliance is required for a determination of the claim. The person who produced the information must preserve the information until the claim is resolved.\n\n**(g) Contempt.** The court for the district where compliance is required – and also, after a motion is transferred, the issuing court – may hold in contempt a person who, having been served, fails without adequate excuse to obey the subpoena or an order related to it.\n\nFor access to subpoena materials, see Fed.R.Civ.P.45(a) Committee Note (2013)\n\n…\n\n## **Request for Production of Documents**\n\n## **I. INSTRUCTIONS**\n\n1. Unless otherwise indicated, the requests for documents set forth below, (the \"Requests,\" and each, a \"Request\"), must be responded to separately and specifically. Each Request shall be answered fully unless it is in good faith objected to, in which event the reason for Your objection shall be stated in detail, as set forth below. If an objection pertains only to a portion of a Request, or a word, phrase or clause contained within it, You are required to state Your objection to that portion only and to respond to the remainder of the Requests.\n\n2. Electronically stored information must be produced in accordance with the\n\nfollowing instructions:\n\n- a. Images. Black and white images must be 300 DPI Group IV single-page TIFF files. Color images must be produced in JPEG format. File names cannot contain embedded spaces or special characters (including the comma). Folder names cannot contain embedded spaces or special characters (including the comma). All TIFF image files must have a unique file name, i.e. Bates number. Images must be endorsed with sequential Bates numbers in the lower right corner of each image. The number of TIFF files per folder should not exceed 1000 files. Excel spreadsheets should have a placeholder image named by the Bates number of the file.\n- b. Image Load File\n\t- a. Concordance® Data File. The data file (.DAT) contains all of the fielded information that will be loaded into the Concordance® database. The first line of the .DAT file must be a header row identifying the field names. The .DAT file must use the following Concordance® default delimiters: Comma ASCII character (020) Quote þ ASCII character (254). Date fields should be provided in the format: mm/dd/yyyy. Date and time fields must be two separate fields. If documents includes imaged emails and attachments, the attachment fields must be included to preserve the parent/child relationship between an email and its attachments. An OCRPATH field must be included to provide the file path and name of the extracted text file on the produced storage media. The text file must be named after the FIRSTBATES. Do not include the text in the .DAT file. For Documents with native files, a LINK field must be included to provide the file path and\n\nname of the native file. The native file must be named after the FIRSTBATES.\n\n- b. Concordance Image® OR Opticon Cross-Reference File. The image crossreference file (.LOG or .OPT) links the images to the database records. It should be a comma-delimited file consisting of seven fields per line with a line in the cross-reference file for every image in the database with the following format: ImageID,VolumeLabel,ImageFilePath,DocumentBreak,FolderBreak,Box Break,PageCoun.\n- c. Document Text. Text must be produced as separate text files, not as fields within the .DAT file. The full path to the text file (OCRPATH) should be included in the .DAT file. It is recommended document level ANSI text files, named per the FIRSTBATES/Image Key. Extracted text files must be in a separate folder, and the number of text files per folder should not exceed 1,000 files. There should be no special characters (including commas in the folder names). Text files must be provided on a document level.\n- d. Native Production for Certain File Types. File types that reasonably require viewing in their native format for a full understanding of their content and meaning must be produced in native format. These include, but are not limited to, spreadsheets, spreadsheet-like files (Microsoft Excel, comma separated values, tab separated values, etc.), Microsoft PowerPoint or other special presentation files, database files, and audio/visual files. Provide an image of a Bates numbered slip sheet indicating the presence of a native file, and include the path to the native as a field in the .dat file. Name the produced native file with the Bates number corresponding to the slip sheet for the file. Group native files within incrementally named \"NATIVE\" directories, separate from images directories.\n- e. De-duplication. Produce a single copy of each electronic document for which exact duplicates exist. For email messages, consolidate duplicates based on MD5 hash generated from the BCC, Body, CC, From, IntMsgID, To, and Attach properties. For email attachments and standalone electronic files, consolidate duplicates based on MD5 hash of the entire file.\n- f. Metadata. Produce extracted metadata for each document in the form of a Concordance compliant load file (.dat). The first line of the .DAT file must be a header row identifying the field names. The .DAT file must use the following Concordance default delimiters: Comma , ASCII character (020) Quote þ ASCII character (254)\n\nDate fields should be provided in the format: mm/dd/yyyy. Date and time fields must be two separate fields. Required metadata listed below:\n\n# Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 327 of 1063\n\n| Field Name   | Sample Data              | Description                                                                                  |\n|--------------|--------------------------|----------------------------------------------------------------------------------------------|\n| FIRSTBATES   | EDC0000001               | First Bates number of native file document/email                                             |\n| LASTBATES    | EDC0000001               | Last Bates number of native file document/email<br>**The LASTBATES field should be populated |\n|              |                          | for single page                                                                              |\n| ATTACHRANGE  | EDC0000001<br>-          | Bates number of the first page of the parent                                                 |\n|              | EDC0000015               | document to the Bates number of the last page of                                             |\n|              |                          | the last attachment \"child\" document                                                         |\n| BEGATTACH    | EDC0000001               | First Bates number of attachment range                                                       |\n| ENDATTACH    | EDC0000015               | Last Bates number of attachment range                                                        |\n| CUSTODIAN    | Smith, John              | Email: Mailbox where the email resided                                                       |\n|              |                          | Native: Name of the individual or department                                                 |\n|              |                          | from whose files the document<br>originated                                                  |\n| FROM         | John Smith               | Email: Sender                                                                                |\n|              |                          | Native: Author(s) of document                                                                |\n|              |                          | **semi-colon should be used to separate                                                      |\n|              |                          | multiple entries                                                                             |\n| TO           | Coffman, Janice; LeeW    | Recipient(s)                                                                                 |\n|              | [mailto:LeeW@MSN.com]    | **semi-colon should be used to separate multiple                                             |\n|              |                          | entries                                                                                      |\n| CC           | Frank Thompson [mailto:  | Carbon copy recipient(s)                                                                     |\n|              | frank_Thompson@cdt.com]  | **semi-colon should be used to separate                                                      |\n|              |                          | multiple entries                                                                             |\n| BCC          | John Cain                | Blind carbon copy recipient(s)                                                               |\n|              |                          | **semi-colon should be used to separate                                                      |\n|              |                          | multiple entries                                                                             |\n| SUBJECT      | Board Meeting Minutes    | Email: Subject line of the email Native: Title                                               |\n|              |                          | of document (if available)                                                                   |\n| FILE_NAME    | BoardMeetingMinutes.docx | Native: Name of the original native file,                                                    |\n|              |                          | including extension                                                                          |\n| DATE_SENT    | 10/12/2010               | Email: Date the email was sent                                                               |\n|              |                          | Native: (empty)                                                                              |\n| TIME_SENT/   | 07:05 PM GMT             | Email: Time the email was sent/ Time zone in                                                 |\n| TIME_ZONE    |                          | which the emails were standardized                                                           |\n| TIME_ZONE    | GMT                      | The<br>time zone in which<br>the emails<br>were                                              |\n|              |                          | standardized during conversion.                                                              |\n| LINK         |  EDC0000001.msg   | Hyperlink to the email or native file document                                               |\n|              |                          | **The linked file must be named per the                                                      |\n|              |                          | FIRSTBATES number                                                                            |\n| FILE_EXTEN   | MSG                      | The file type extension                                                                      |\n|              |                          | representing                                                                                 |\n|              |                          | the Email or                                                                                 |\n| AUTHOR       | John Smith               | Email: (empty)                                                                               |\n|              |                          | Native: Author of the document                                                               |\n| DATE_CREATED | 10/10/2010               | Email: (empty)                                                                               |\n|              |                          | Native: Date the document was created                                                        |\n\n# Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 328 of 1063\n\n| TIME_CREATED | 10:25 AM                  | Email: (empty)                                  |\n|--------------|---------------------------|-------------------------------------------------|\n|              |                           | Native: Time the document was created           |\n|              |                           | **This data must be a separate field and cannot |\n|              |                           | be combined with the DATE_CREATED field         |\n| DATE_MOD     | 10/12/2010                | Email: (empty)                                  |\n|              |                           | Native: Date the document was last modified     |\n| TIME_MOD     | 07:00 PM                  | Email: (empty)                                  |\n|              |                           | Native: Time the document was last modified     |\n|              |                           | **This data must be a separate field and cannot |\n|              |                           | be combined with the DATE_MOD field             |\n| DATE_ACCESSD | 10/12/2010                | Email: (empty)                                  |\n|              |                           | Native: Date the document was last accessed     |\n| TIME_ACCESSD | 07:00 PM                  | Email: (empty)                                  |\n|              |                           | Native: Time the document was last accessed     |\n|              |                           | **This data must be a separate field and cannot |\n|              |                           | be combined with the DATE_ACCESSD field         |\n| FILE_SIZE    | 5,952                     | Size of native file<br>document/email in KB     |\n| PGCOUNT      | 1                         | Number of pages in native file document/email   |\n| PATH         |   | Email: (empty)                                  |\n|              | Agenda.doc                | Native: Path where native file document was     |\n|              |                           | stored including original file name.            |\n| INTFILEPATH  | Personal Folders\\Deleted  | Email: original location of email including     |\n|              | Items\\Board Meeting       | original file name.                             |\n|              | Minutes.msg               | Native: (empty)                                 |\n| INTMSGID     | <000805c2c71b\\$75977050\\$ | Email: Unique Message ID Native: (empty)        |\n|              | cb8306d1@MSN>             |                                                 |\n| MD5HASH      | d131dd02c5e6eec4693d9a0   | MD5 Hash value of the document.                 |\n|              | 698aff95c                 |                                                 |\n|              | 2fcab58712467eab4004583e  |                                                 |\n|              | b8fb7f89                  |                                                 |\n| OCRPATH      | TEXT/001/EDC0000001.txt   | Path to extracted text of the native file       |\n\n3. Each Request operates and should be construed independently and, unless otherwise indicated, no Request limits the scope of any other Request.\n\n4. All Documents are to be produced as kept in the usual course of business or are to be organized and labeled to correspond with the categories in these Requests.\n\n5. Each Request contained herein extends to all Documents: (a) in Your possession, custody, or control; or (b) in the possession, custody, or control of anyone acting on Your behalf,\n\n#### Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 329 of 1063\n\nincluding Your counsel or other representatives and advisors. Each Document shall be produced in its entirety.\n\n6. If You are requested to produce a Document that is no longer in Your possession, custody, or control, then Your response must (a) describe in detail the nature of the document and its contents; (b) identify the person(s) who prepared or authored the Document (and, if applicable, the Person(s) to whom the Document was sent); (c) identify the date on which the document was prepared or created; (d) state whether such Document (i) is missing or lost, (ii) has been destroyed, (iii) has been transferred, voluntarily or involuntarily, to others, or (iv) was otherwise disposed of; (e) state the reason for, and the facts and circumstances surrounding, such disposition; (f) identify the Persons who authorized such disposition; (g) identify the date or approximate date of such disposition; (h) state when the Document was most recently in Your possession, custody or control; and (i) identify the Person, if any, presently in possession, custody, or control of such Document.\n\n7. If You are requested to produce a Document that has been destroyed, then Your response must state, in addition to the information required by the preceding Instruction: (a) the reason for the Document's destruction; (b) the identity of the Person who destroyed the Document; and (c) the identity of the Person who directed that the Document be destroyed.\n\n8. If You claim that a requested Document is privileged or attorney work-product, then Your response must: (a) state (i) a description of the Document adequate to support Your contention that the Document is privileged, (ii) the title of the Document, (iii) the date of the Document, (iv) the author of the Document, (v) the addressee of the Document, (vi) the identity of each Person who received or saw the original or any draft, copy, or reproduction of the Document, (vii) whether the Document itself, or any information contained or referred to in the Document is in the possession, custody, or control of any other Persons, and if so, the identity of\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 330 of 1063\n\nsuch Persons, as well as a statement addressing how the information came into their possession, (viii) the claim of privilege under which the Document is withheld, and (ix) all of the circumstances upon which You will rely to support such claim of privilege; and (b) produce a privilege log containing all of the information requested in Part (a) of this Instruction for each Document withheld on the basis of a claim of privilege in accordance with D. Conn. L. Civ. R. 26(e). For any part of a Document Request as to which a claim of privilege or work product is not made, responsive documents should be provided in full.\n\n9. If a portion of an otherwise responsive Document contains information subject to a claim of privilege, only that portion of the Document subject to the claim of privilege shall be deleted or redacted from the Document following the instructions above, and the rest shall be produced.\n\n10. The Requests are continuing in nature. You are hereby instructed to (a) supplement or correct any responses later learned to be incomplete or incorrect immediately upon learning that a prior response was incomplete or incorrect; and (b) produce any additional Documents that are called for under the\n\n11. If a Document is in a language other than English, You should provide that Document. If a Document is in a language other than English, and an English translation exists, You should provide both Documents.\n\n12. All references to Entities includes all affiliates thereof.\n\n13. All references to individual names include all alternative names, aliased, or nicknames.\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 331 of 1063\n\n14. Unless otherwise expressly indicated, the period of time covered by the Document Requests is the period from February 5, 2012 to the date responses to the Document Requests are due.\n\n#### **II. RULES OF CONSTRUCTION**\n\n15. The use of (a) any singular noun shall be construed to include the plural, and vice versa, and (b) a verb in any tense shall be construed as the use of the verb in all other tenses.\n\n16. The terms (a) \"and\" and \"or\" shall be construed either conjunctively or disjunctively as necessary to bring within the scope of any request all responses that might otherwise be construed to be outside of its scope, and (b) \"each\" and \"any\" shall be deemed to include and encompass the words \"every\" and \"all.\"\n\n#### **III. DEFINITIONS**\n\nThe definitions supplied by D. Conn. L. Civ. R. 26(c) and the rules of construction supplied by D. Conn. L. Civ. R. 26(d), as incorporated by D. Conn. Bankr. L.R. 2004-1(a), shall apply to the Document Requests. In addition, the following terms used in these Document Requests shall have the following meanings:\n\n1. \"You\" or \"Your\" or \"Yourself\" means and refers, to The First Bank of Greenwich, together with all of its affiliates.\n\n2. \"Debtor\" means Ho Wan Kwok (a/k/a Miles Kwok, Miles Guo, Guo Wengui, Guo Haoyun, 郭文贵, or any other alias), together with his employees, agents, counsel, advisors, or anyone acting on his behalf.\n\n#### Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 332 of 1063\n\n3. \"Debtor's Son\" means Qiang Guo (a/k/a Mileson Kwok, 郭强, or any other alias), together with his employees, agents, counsel, advisors, or anyone acting on his behalf.\n\n4. \"Debtor's Daughter\" means Mei Guo (a/k/a Mei Gui, 郭美, or any other alias), together with her employees, agents, counsel, advisors, or anyone acting on her behalf.\n\n5. \"Debtor's Purported Wife\" means Hing Chi Ngok (a/k/a Hing Chi Ng, Yue Qingzhi, 岳庆芝, or any other alias), together with her employees, agents, counsel, advisors, or anyone acting on her behalf.\n\n6. \"Debtor's Family\" means, individually and collectively, the Debtor, the Debtor's Son, the Debtor's Daughter, and the Debtor's Purported Wife, and any other familial relation to the Debtor.\n\n7. \"2004 Discovery Targets\" means, individually and collectively, the Debtor, the Debtor's Family, ACA Capital Group Limited, Himalaya International Financial Group Ltd., Himalaya International Clearing Ltd., Himalaya International Payments Ltd., Himalaya International Reserves Ltd., Jesse Brown, William Je, William Je, Eastern Profit Corporation Limited, HK International Funds Investments (USA) Limited LLC, Bravo Luck Limited, Golden Spring (New York) Ltd., Lamp Capital LLC, Greenwich Land LLC, Qu Guo Jiao, Daniel Thomas Podhaskie, Yvette Wang (a/k/a Yanping Wang, a/k/a Yan Ping Wang), Ace Decade Holdings Limited, Dawn State Limited, Rule of Law Society IV Inc., Rule of Law Foundation III, Inc., Rule of Law Foundation IV, Inc., Rule of Law Fund, Rule of Law Society, GTV Media Group, Inc., Voice of Guo Media, Inc., Saraca Media Group Inc., Genever Holdings Corporation, Genever Holdings LLC, Gnews Media Group Inc., G Fashion LLC, Gmusic LLC, Gnews LLC, Geducation, GFNY, Inc., G-Club Investments Limited, G Club Operations LLC, G Club US Operations Inc., G Club US Operations LLC, G Live, LLC, Gbroadcast, LLC, Gposts LLC, HCHK Property\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 333 of 1063\n\nManagement, Inc., HCHK Technologies, Inc., FMV Ltd./Freedom Media Venture Ltd., Roscalitar 2, Himalaya New World Inc., US Himalaya Capital Inc., Hudson Diamond Holding, Inc., Hudson Diamond Holding LLC, Hudson Diamond NY LLC, Infinity Treasury Management Inc., Lexington Property and Staffing, Inc., AI Group Holdings Inc., Hamilton Capital Holdings Inc., Booming Sail New York LLC, Himalaya Ventures LLC, Himalaya Ventures LLC, Himalaya Investment LLC, New York MOS Himalaya LLC, MOS Himalaya LLC, Crane Advisory Group, Maywind Trading LLC, Gettr USA, Inc., Han Chunguang, Bingshang Jiao, Karin Maistrello, Mary Jiang, Jiaming Liu, and Wencong Wang.\n\n8. \"Including\" or any variant thereof means \"including without limitation.\"\n\n9. \"And\" and \"or\" mean \"and/or,\" and shall be construed both conjunctively as well as disjunctively in order to maximize their scope.\n\n10. \"Any\" and \"all\" and \"each\" mean \"each and every.\"\n\n11. \"Each\" and \"every\" mean \"each and every.\"\n\n12. \"Third Party\" means a Person or Entity other than Yourself.\n\n13. \"Transfer\" shall have the meaning given to it by section 101(54) of the Bankruptcy Code.\n\n14. \"Document\" means any information or thing within the scope of Fed. R. Civ. P. 34, and includes, without limitation, each and every written, recorded, or graphic matter of any kind, type, nature, or description that is or has been in Your Possession, Custody or Control, including all printed and electronic copies of electronic mail, computer files maintained in electronic form, correspondence, memoranda, tapes, stenographic or handwritten notes, written forms of any kind, charts, blueprints, drawings, sketches, graphs, plans, articles, specifications, diaries, letters,\n\n### Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 334 of 1063\n\ntelegrams, photographs, minutes, contracts, agreements, surveys, computer printouts, data compilations of any kind, telexes, facsimiles, emails, text messages, instant messages, voice messages, invoices, order forms, checks, drafts, statements, credit memos, reports, position reports, summaries, indices, books, ledgers, notebooks, schedules, transparencies, recordings, catalogs, advertisements, promotional materials, films, video tapes, audio tapes, CDs, computer disks, brochures, pamphlets, punch-cards, time-slips, Tweets, social media posts, or any written or recorded materials of any other kind, and all meta-data thereof, however stored (whether in tangible or electronic form), recorded, produced, or reproduced, and also including but not limited to, drafts or copies of any of the foregoing that contain any notes, comments, or markings of any kind not found on the original documents or that are otherwise not identical to the original documents.\n\n15. \"Person(s)\" means an individual, corporation, proprietorship, partnership, association, or any other Entity. \"Person\" also includes any agent, representatives, or expert, including but not limiting to, attorneys or financial advisors.\n\n16. \"Entity\" means any natural Person, corporation, partnership, subsidiary, sole proprietorship, firm, board, joint venture, association, agency, authority, commission or other business entity or juristic Person, as well as any affiliate, agent, parent including but not limited to counsel, financial advisors, or any other representative.\n\n17. \"Regarding\" means concerning, describing, comprising, referring to, related to, supporting, favoring, opposing, bolstering, detracting from, located in, considered in connection with, bearing on, evidencing, indicating, reporting on, recording, alluding to, responding to, connected with, commenting on, in respect of, about, in relation to, discussing, showing, describing, reflecting, analyzing constituting, and being.\n\n### Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 335 of 1063\n\n18. \"Relating to,\" \"relate(s) to\" or \"related to,\" when referring to any given subject matter, means, without limitation, any document that constitutes, comprises, involves, contains, embodies, reflects, identifies, states, refers directly or indirectly to, or is in any way relevant to the particular subject matter identified.\n\n19. \"Communication(s)\" means, in the broadest possible sense, and without limitation, any transmittal of information or knowledge (in the form of facts, ideas, inquiries, or otherwise). Communication(s) further refers to all conversations, agreements, inquiries, or replies, whether in person, by telephone, in writing, or by means of electronic transmittal devices, and includes, but is not limited to, all correspondence, emails, recordings, transmittal slips, memoranda, telephone communications, voice messages, telegrams, telefaxes, telecopies, telexes, instant messages, chats, text messages, postings to a message board or group chat, social media posts, tweets, videos uploaded to any video platform, telephonic notes, or notes transmitted internally or with third parties.\n\n20. \"Asset(s)\" means any item of economic value that is subject to Possession, Custody, or Control. Asset includes all real and personal property, including but limited to, real estate, land, houses, apartments, condominiums, automobiles, yachts, boats, planes, jets, helicopters, cash, bank accounts, cryptocurrencies, securities, accounts receivables, inventory, and other tangible and intangible property.\n\n#### **IV. DOCUMENTS TO BE PRODUCED**\n\n1. All Documents related to any account held by, controlled by, on behalf of, or otherwise related to any of the 2004 Discovery Targets, including any and all account statements, authorizations, power of attorney, trusts, instructions or forms, copies of cancelled checks, correspondence, and wire transfers and related correspondence and instructions.\n\n#### Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 336 of 1063\n\n2. All Documents related to any funds, securities, property, or assets belonging to, held by, controlled by, on behalf of, or otherwise related to any of the 2004 Discovery Targets, including any and all account statements, authorizations, powers of attorney, trusts, instructions or forms, copies of cancelled checks, correspondence, and wire transfers and related correspondence and instructions.\n\n3. All Documents related to any business, commerce or financial transactions, including but not limited to any loan, line of credit, bailment, deposit, swap, securities transactions, mortgage, or ISDA, with any of the 2004 Discovery Targets, including any and all account statements, authorizations, powers of attorney, trusts, instructions or forms, copies of cancelled checks, correspondence, and wire transfers and related correspondence and instructions.\n\n4. All Documents relating to any wire transfer activity relating to the 2004 Discovery Targets, regardless of the existence of any accounts, including but not limited to all wire transfer receipts, account numbers, balances, authorizations, identification information related to the parties to the transfer, correspondence, instructions, or other records.\n\n5. All Documents related to any correspondence and communications between you and the 2004 Discovery Targets.\n\n6. All Documents related to any account with any 2004 Discovery Target relating to opening of the account, authorized users of the account and maintenance of the account.\n\n7. All Documents related to any anti-money laundering, know-your-customer, or other compliance activity relating to any of the 2004 Discovery Targets, including but not limited to any information provided by any of the 2004 Discovery Targets, or learned by You.\n\n8. All Documents relating to any communications with any regulator from any country, including but not limited to the Bank of England, the United States Federal Reserve, the\n\nS.E.C., the CFTC, FINRA, China Securities Regulatory Commission, People's Bank of China, Hong Kong Securities and Futures Commission, and the Hong Kong Monetary Authority relating to any of the 2004 Discovery Targets.\n\n# Exhibit C-18\n\n#### B2540 (Form 2540 – Subpoena for Rule 2004 Examination) (12/15) Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 339 of\n\n1063\n\nUNITED STATES BANKRUPTCY COURT\n\n**District of Connecticut**\n\nIn re HO WAN KWOK, *et al*.,\n\n<sup>1</sup> Case No. 22-50073 (JAM) Debtor Chapter 11\n\n(Jointly Administered)\n\n# **SUBPOENA FOR RULE 2004 EXAMINATION**\n\nTo: **Mercantile Bank International Corp.**\n\n(*Name of person to whom the subpoena is directed*)\n\n*Testimony:* **YOU ARE COMMANDED** to appear at the time, date, and place set forth below to testify at an examination under Rule 2004, Federal Rules of Bankruptcy Procedure. A copy of the court order authorizing the examination is attached.\n\n| PLACE                    | DATE AND TIME |\n|--------------------------|---------------|\n| Paul Hastings LLP        |               |\n| 200 Park Avenue          | [TBD]         |\n| New York, New York 10166 |               |\n|                          |               |\n\nThe examination will be recorded by this method: **Court reporter/stenographer**\n\n*Production:* You, or your representatives, must also bring with you to the examination the following documents, electronically stored information, or objects, and must permit inspection, copying, testing, or sampling of the material:\n\n#### **See Requests for Production of Documents, attached hereto.**\n\nThe following provisions of Fed. R. Civ. P. 45, made applicable in bankruptcy cases by Fed. R. Bankr. P. 9016, are attached – Rule 45(c), relating to the place of compliance; Rule 45(d), relating to your protection as a person subject to a subpoena; and Rule 45(e) and 45(g), relating to your duty to respond to this subpoena and the potential consequences of not doing so.\n\nDate: **March , 2023**\n\nCLERK OF COURT\n\nOR\n\n*Signature of Clerk or Deputy Clerk Attorney's signature*\n\nThe name, address, email address, and telephone number of the attorney representing Luc A. Despins, Chapter 11 Trustee, who issues or requests this subpoena, are:\n\n**Douglas S. Skalka, Esq.; Neubert, Pepe & Monteith, P.C.; 195 Church Street, New Haven, Connecticut 06510 dskalka@npmlaw.com; (203) 821-2000**\n\n**Notice to the person who issues or requests this subpoena**\n\nIf this subpoena commands the production of documents, electronically stored information, or tangible things, or the inspection of premises before trial, a notice and a copy of this subpoena must be served on each party before it is served on the person to whom it is directed. Fed. R. Civ. P. 45(a)(4).\n\nSoftware Copyright (c) 1996-2022 Best Case, LLC - www.bestcase.com Best Case Bankruptcy 1 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\n#### **PROOF OF SERVICE**\n\n**(This section should not be filed with the court unless required by Fed. R. Civ. P. 45.)**\n\nI received this subpoena for (*name of individual and title, if any*): on (*date*) .\n\nI served the subpoena by delivering a copy to the named person as follows:\n\non *(date)* ; or\n\nI returned the subpoena unexecuted because:\n\nUnless the subpoena was issued on behalf of the United States, or one of its officers or agents, I have also tendered to the witness the fees for one day's attendance, and the mileage allowed by law, in the amount of \\$ .\n\nMy fees are \\$ for travel and \\$ for services, for a total of \\$ .\n\nI declare under penalty of perjury that this information is true and correct.\n\nDate:\n\n*Server's signature*\n\n*Printed name and title*\n\n*Server's address*\n\nAdditional information concerning attempted service, etc.:\n\n#### **Federal Rule of Civil Procedure 45(c), (d), (e), and (g) (Effective 12/1/13) (made applicable in bankruptcy cases by Rule 9016, Federal Rules of Bankruptcy Procedure)**\n\n#### **(c) Place of compliance.**\n\n*(1) For a Trial, Hearing, or Deposition.* A subpoena may command a person to attend a trial, hearing, or deposition only as follows:\n\n(A) within 100 miles of where the person resides, is employed, or regularly transacts business in person; or\n\n(B) within the state where the person resides, is employed, or regularly transacts business in person, if the person\n\n(i) is a party or a party's officer; or\n\n(ii) is commanded to attend a trial and would not incur substantial expense.\n\n*(2) For Other Discovery.* A subpoena may command:\n\n(A) production of documents, or electronically stored information, or things at a place within 100 miles of where the person resides, is employed, or regularly transacts business in person; and\n\n(B) inspection of premises, at the premises to be inspected.\n\n#### **(d) Protecting a Person Subject to a Subpoena; Enforcement.**\n\n*(1) Avoiding Undue Burden or Expense; Sanctions.* A party or attorney responsible for issuing and serving a subpoena must take reasonable steps to avoid imposing undue burden or expense on a person subject to the subpoena. The court for the district where compliance is required must enforce this duty and impose an appropriate sanction which may include lost earnings and reasonable attorney's fees — on a party or attorney who fails to comply.\n\n#### *(2) Command to Produce Materials or Permit Inspection.*\n\n*(A) Appearance Not Required.* A person commanded to produce documents, electronically stored information, or tangible things, or to permit the inspection of premises, need not appear in person at the place of production or inspection unless also commanded to appear for a deposition, hearing, or trial.\n\n*(B) Objections.* A person commanded to produce documents or tangible things or to permit inspection may serve on the party or attorney designated in the subpoena a written objection to inspecting, copying, testing or sampling any or all of the materials or to inspecting the premises — or to producing electronically stored information in the form or forms requested. The objection must be served before the earlier of the time specified for compliance or 14 days after the subpoena is served. If an objection is made, the following rules apply:\n\n(i) At any time, on notice to the commanded person, the serving party may move the court for the district where compliance is required for an order compelling production or inspection.\n\n(ii) These acts may be required only as directed in the order, and the order must protect a person who is neither a party nor a party's officer from significant expense resulting from compliance.\n\n#### *(3) Quashing or Modifying a Subpoena.*\n\n*(A) When Required.* On timely motion, the court for the district where compliance is required must quash or modify a subpoena that:\n\n(i) fails to allow a reasonable time to comply;\n\n(ii) requires a person to comply beyond the geographical limits specified in Rule 45(c);\n\n(iii) requires disclosure of privileged or other protected matter, if no exception or waiver applies; or\n\n(iv) subjects a person to undue burden.\n\n*(B) When Permitted.* To protect a person subject to or affected by a subpoena, the court for the district where compliance is required may, on motion, quash or modify the subpoena if it requires:\n\n(i) disclosing a trade secret or other confidential research, development, or commercial information; or\n\n(ii) disclosing an unretained expert's opinion or information that does not describe specific occurrences in dispute and results from the expert's study that was not requested by a party.\n\n(C) *Specifying Conditions as an Alternative.* In the circumstances described in Rule 45(d)(3)(B), the court may, instead of quashing or modifying a subpoena, order appearance or production under specified conditions if the serving party:\n\n(i) shows a substantial need for the testimony or material that cannot be otherwise met without undue hardship; and\n\n(ii) ensures that the subpoenaed person will be reasonably compensated.\n\n#### **(e) Duties in Responding to a Subpoena.**\n\n*(1) Producing Documents or Electronically Stored Information.* These procedures apply to producing documents or electronically stored information:\n\n*(A) Documents.* A person responding to a subpoena to produce documents must produce them as they are kept in the ordinary course of business or must organize and label them to correspond to the categories in the demand.\n\n*(B) Form for Producing Electronically Stored Information Not Specified.* If a subpoena does not specify a form for producing electronically stored information, the person responding must produce it in a form or forms in which it is ordinarily maintained or in a reasonably usable form or forms.\n\n*(C) Electronically Stored Information Produced in Only One Form.* The person responding need not produce the same electronically stored information in more than one form.\n\n*(D) Inaccessible Electronically Stored Information.* The person responding need not provide discovery of electronically stored information from sources that the person identifies as not reasonably accessible because of undue burden or cost. On motion to compel discovery or for a protective order, the person responding must show that the information is not reasonably accessible because of undue burden or cost. If that showing is made, the court may nonetheless order discovery from such sources if the requesting party shows good cause, considering the limitations of Rule 26(b)(2)(C). The court may specify conditions for the discovery.\n\n#### *(2) Claiming Privilege or Protection.*\n\n*(A) Information Withheld.* A person withholding subpoenaed information under a claim that it is privileged or subject to protection as trial-preparation material must: (i) expressly make the claim; and\n\n(ii) describe the nature of the withheld documents, communications, or tangible things in a manner that, without revealing information itself privileged or protected, will enable the parties to assess the claim.\n\n*(B) Information Produced.* If information produced in response to a subpoena is subject to a claim of privilege or of protection as trial-preparation material, the person making the claim may notify any party that received the information of the claim and the basis for it. After being notified, a party must promptly return, sequester, or destroy the specified information and any copies it has; must not use or disclose the information until the claim is resolved; must take reasonable steps to retrieve the information if the party disclosed it before being notified; and may promptly present the information under seal to the court for the district where compliance is required for a determination of the claim. The person who produced the information must preserve the information until the claim is resolved.\n\n**(g) Contempt.** The court for the district where compliance is required – and also, after a motion is transferred, the issuing court – may hold in contempt a person who, having been served, fails without adequate excuse to obey the subpoena or an order related to it.\n\nFor access to subpoena materials, see Fed.R.Civ.P.45(a) Committee Note (2013)\n\n…\n\n## **Request for Production of Documents**\n\n## **I. INSTRUCTIONS**\n\n1. Unless otherwise indicated, the requests for documents set forth below, (the \"Requests,\" and each, a \"Request\"), must be responded to separately and specifically. Each Request shall be answered fully unless it is in good faith objected to, in which event the reason for Your objection shall be stated in detail, as set forth below. If an objection pertains only to a portion of a Request, or a word, phrase or clause contained within it, You are required to state Your objection to that portion only and to respond to the remainder of the Requests.\n\n2. Electronically stored information must be produced in accordance with the\n\nfollowing instructions:\n\n- a. Images. Black and white images must be 300 DPI Group IV single-page TIFF files. Color images must be produced in JPEG format. File names cannot contain embedded spaces or special characters (including the comma). Folder names cannot contain embedded spaces or special characters (including the comma). All TIFF image files must have a unique file name, i.e. Bates number. Images must be endorsed with sequential Bates numbers in the lower right corner of each image. The number of TIFF files per folder should not exceed 1000 files. Excel spreadsheets should have a placeholder image named by the Bates number of the file.\n- b. Image Load File\n\t- a. Concordance® Data File. The data file (.DAT) contains all of the fielded information that will be loaded into the Concordance® database. The first line of the .DAT file must be a header row identifying the field names. The .DAT file must use the following Concordance® default delimiters: Comma ASCII character (020) Quote þ ASCII character (254). Date fields should be provided in the format: mm/dd/yyyy. Date and time fields must be two separate fields. If documents includes imaged emails and attachments, the attachment fields must be included to preserve the parent/child relationship between an email and its attachments. An OCRPATH field must be included to provide the file path and name of the extracted text file on the produced storage media. The text file must be named after the FIRSTBATES. Do not include the text in the .DAT file. For Documents with native files, a LINK field must be included to provide the file path and\n\nname of the native file. The native file must be named after the FIRSTBATES.\n\n- b. Concordance Image® OR Opticon Cross-Reference File. The image crossreference file (.LOG or .OPT) links the images to the database records. It should be a comma-delimited file consisting of seven fields per line with a line in the cross-reference file for every image in the database with the following format: ImageID,VolumeLabel,ImageFilePath,DocumentBreak,FolderBreak,Box Break,PageCoun.\n- c. Document Text. Text must be produced as separate text files, not as fields within the .DAT file. The full path to the text file (OCRPATH) should be included in the .DAT file. It is recommended document level ANSI text files, named per the FIRSTBATES/Image Key. Extracted text files must be in a separate folder, and the number of text files per folder should not exceed 1,000 files. There should be no special characters (including commas in the folder names). Text files must be provided on a document level.\n- d. Native Production for Certain File Types. File types that reasonably require viewing in their native format for a full understanding of their content and meaning must be produced in native format. These include, but are not limited to, spreadsheets, spreadsheet-like files (Microsoft Excel, comma separated values, tab separated values, etc.), Microsoft PowerPoint or other special presentation files, database files, and audio/visual files. Provide an image of a Bates numbered slip sheet indicating the presence of a native file, and include the path to the native as a field in the .dat file. Name the produced native file with the Bates number corresponding to the slip sheet for the file. Group native files within incrementally named \"NATIVE\" directories, separate from images directories.\n- e. De-duplication. Produce a single copy of each electronic document for which exact duplicates exist. For email messages, consolidate duplicates based on MD5 hash generated from the BCC, Body, CC, From, IntMsgID, To, and Attach properties. For email attachments and standalone electronic files, consolidate duplicates based on MD5 hash of the entire file.\n- f. Metadata. Produce extracted metadata for each document in the form of a Concordance compliant load file (.dat). The first line of the .DAT file must be a header row identifying the field names. The .DAT file must use the following Concordance default delimiters: Comma , ASCII character (020) Quote þ ASCII character (254)\n\nDate fields should be provided in the format: mm/dd/yyyy. Date and time fields must be two separate fields. Required metadata listed below:\n\n# Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 344 of 1063\n\n| Field Name   | Sample Data              | Description                                      |\n|--------------|--------------------------|--------------------------------------------------|\n| FIRSTBATES   | EDC0000001               | First Bates number of native file document/email |\n| LASTBATES    | EDC0000001               | Last Bates number of native file document/email  |\n|              |                          | **The LASTBATES field should be populated        |\n|              |                          | for single page                                  |\n| ATTACHRANGE  | EDC0000001<br>-          | Bates number of the first page of the parent     |\n|              | EDC0000015               | document to the Bates number of the last page of |\n|              |                          | the last attachment \"child\" document             |\n| BEGATTACH    | EDC0000001               | First Bates number of attachment range           |\n| ENDATTACH    | EDC0000015               | Last Bates number of attachment range            |\n| CUSTODIAN    | Smith, John              | Email: Mailbox where the email resided           |\n|              |                          | Native: Name of the individual or department     |\n|              |                          | from whose files the document<br>originated      |\n| FROM         | John Smith               | Email: Sender                                    |\n|              |                          | Native: Author(s) of document                    |\n|              |                          | **semi-colon should be used to separate          |\n|              |                          | multiple entries                                 |\n| TO           | Coffman, Janice; LeeW    | Recipient(s)                                     |\n|              | [mailto:LeeW@MSN.com]    | **semi-colon should be used to separate multiple |\n|              |                          | entries                                          |\n| CC           | Frank Thompson [mailto:  | Carbon copy recipient(s)                         |\n|              | frank_Thompson@cdt.com]  | **semi-colon should be used to separate          |\n|              |                          | multiple entries                                 |\n| BCC          | John Cain                | Blind carbon copy recipient(s)                   |\n|              |                          | **semi-colon should be used to separate          |\n|              |                          | multiple entries                                 |\n| SUBJECT      | Board Meeting Minutes    | Email: Subject line of the email Native: Title   |\n|              |                          | of document (if available)                       |\n| FILE_NAME    | BoardMeetingMinutes.docx | Native: Name of the original native file,        |\n|              |                          | including extension                              |\n| DATE_SENT    | 10/12/2010               | Email: Date the email was sent                   |\n|              |                          | Native: (empty)                                  |\n| TIME_SENT/   | 07:05 PM GMT             | Email: Time the email was sent/ Time zone in     |\n| TIME_ZONE    |                          | which the emails were standardized               |\n| TIME_ZONE    | GMT                      | The<br>time zone in which<br>the emails<br>were  |\n|              |                          | standardized during conversion.                  |\n| LINK         |  EDC0000001.msg   | Hyperlink to the email or native file document   |\n|              |                          | **The linked file must be named per the          |\n|              |                          | FIRSTBATES number                                |\n| FILE_EXTEN   | MSG                      | The file type extension                          |\n|              |                          | representing                                     |\n|              |                          | the Email or                                     |\n| AUTHOR       | John Smith               | Email: (empty)                                   |\n|              |                          | Native: Author of the document                   |\n| DATE_CREATED | 10/10/2010               | Email: (empty)                                   |\n|              |                          | Native: Date the document was created            |\n|              |                          |                                                  |\n\n# Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 345 of 1063\n\n| TIME_CREATED | 10:25 AM                  | Email: (empty)                                  |\n|--------------|---------------------------|-------------------------------------------------|\n|              |                           | Native: Time the document was created           |\n|              |                           | **This data must be a separate field and cannot |\n|              |                           | be combined with the DATE_CREATED field         |\n| DATE_MOD     | 10/12/2010                | Email: (empty)                                  |\n|              |                           | Native: Date the document was last modified     |\n| TIME_MOD     | 07:00 PM                  | Email: (empty)                                  |\n|              |                           | Native: Time the document was last modified     |\n|              |                           | **This data must be a separate field and cannot |\n|              |                           | be combined with the DATE_MOD field             |\n| DATE_ACCESSD | 10/12/2010                | Email: (empty)                                  |\n|              |                           | Native: Date the document was last accessed     |\n| TIME_ACCESSD | 07:00 PM                  | Email: (empty)                                  |\n|              |                           | Native: Time the document was last accessed     |\n|              |                           | **This data must be a separate field and cannot |\n|              |                           | be combined with the DATE_ACCESSD field         |\n| FILE_SIZE    | 5,952                     | Size of native file<br>document/email in KB     |\n| PGCOUNT      | 1                         | Number of pages in native file document/email   |\n| PATH         |   | Email: (empty)                                  |\n|              | Agenda.doc                | Native: Path where native file document was     |\n|              |                           | stored including original file name.            |\n| INTFILEPATH  | Personal Folders\\Deleted  | Email: original location of email including     |\n|              | Items\\Board Meeting       | original file name.                             |\n|              | Minutes.msg               | Native: (empty)                                 |\n| INTMSGID     | <000805c2c71b\\$75977050\\$ | Email: Unique Message ID Native: (empty)        |\n|              | cb8306d1@MSN>             |                                                 |\n| MD5HASH      | d131dd02c5e6eec4693d9a0   | MD5 Hash value of the document.                 |\n|              | 698aff95c                 |                                                 |\n|              | 2fcab58712467eab4004583e  |                                                 |\n|              | b8fb7f89                  |                                                 |\n| OCRPATH      | TEXT/001/EDC0000001.txt   | Path to extracted text of the native file       |\n\n3. Each Request operates and should be construed independently and, unless otherwise indicated, no Request limits the scope of any other Request.\n\n4. All Documents are to be produced as kept in the usual course of business or are to be organized and labeled to correspond with the categories in these Requests.\n\n5. Each Request contained herein extends to all Documents: (a) in Your possession, custody, or control; or (b) in the possession, custody, or control of anyone acting on Your behalf,\n\n#### Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 346 of 1063\n\nincluding Your counsel or other representatives and advisors. Each Document shall be produced in its entirety.\n\n6. If You are requested to produce a Document that is no longer in Your possession, custody, or control, then Your response must (a) describe in detail the nature of the document and its contents; (b) identify the person(s) who prepared or authored the Document (and, if applicable, the Person(s) to whom the Document was sent); (c) identify the date on which the document was prepared or created; (d) state whether such Document (i) is missing or lost, (ii) has been destroyed, (iii) has been transferred, voluntarily or involuntarily, to others, or (iv) was otherwise disposed of; (e) state the reason for, and the facts and circumstances surrounding, such disposition; (f) identify the Persons who authorized such disposition; (g) identify the date or approximate date of such disposition; (h) state when the Document was most recently in Your possession, custody or control; and (i) identify the Person, if any, presently in possession, custody, or control of such Document.\n\n7. If You are requested to produce a Document that has been destroyed, then Your response must state, in addition to the information required by the preceding Instruction: (a) the reason for the Document's destruction; (b) the identity of the Person who destroyed the Document; and (c) the identity of the Person who directed that the Document be destroyed.\n\n8. If You claim that a requested Document is privileged or attorney work-product, then Your response must: (a) state (i) a description of the Document adequate to support Your contention that the Document is privileged, (ii) the title of the Document, (iii) the date of the Document, (iv) the author of the Document, (v) the addressee of the Document, (vi) the identity of each Person who received or saw the original or any draft, copy, or reproduction of the Document, (vii) whether the Document itself, or any information contained or referred to in the Document is in the possession, custody, or control of any other Persons, and if so, the identity of\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 347 of 1063\n\nsuch Persons, as well as a statement addressing how the information came into their possession, (viii) the claim of privilege under which the Document is withheld, and (ix) all of the circumstances upon which You will rely to support such claim of privilege; and (b) produce a privilege log containing all of the information requested in Part (a) of this Instruction for each Document withheld on the basis of a claim of privilege in accordance with D. Conn. L. Civ. R. 26(e). For any part of a Document Request as to which a claim of privilege or work product is not made, responsive documents should be provided in full.\n\n9. If a portion of an otherwise responsive Document contains information subject to a claim of privilege, only that portion of the Document subject to the claim of privilege shall be deleted or redacted from the Document following the instructions above, and the rest shall be produced.\n\n10. The Requests are continuing in nature. You are hereby instructed to (a) supplement or correct any responses later learned to be incomplete or incorrect immediately upon learning that a prior response was incomplete or incorrect; and (b) produce any additional Documents that are called for under the\n\n11. If a Document is in a language other than English, You should provide that Document. If a Document is in a language other than English, and an English translation exists, You should provide both Documents.\n\n12. All references to Entities includes all affiliates thereof.\n\n13. All references to individual names include all alternative names, aliased, or nicknames.\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 348 of 1063\n\n14. Unless otherwise expressly indicated, the period of time covered by the Document Requests is the period from February 5, 2015 to the date responses to the Document Requests are due.\n\n#### **II. RULES OF CONSTRUCTION**\n\n15. The use of (a) any singular noun shall be construed to include the plural, and vice versa, and (b) a verb in any tense shall be construed as the use of the verb in all other tenses.\n\n16. The terms (a) \"and\" and \"or\" shall be construed either conjunctively or disjunctively as necessary to bring within the scope of any request all responses that might otherwise be construed to be outside of its scope, and (b) \"each\" and \"any\" shall be deemed to include and encompass the words \"every\" and \"all.\"\n\n#### **III. DEFINITIONS**\n\nThe definitions supplied by D. Conn. L. Civ. R. 26(c) and the rules of construction supplied by D. Conn. L. Civ. R. 26(d), as incorporated by D. Conn. Bankr. L.R. 2004-1(a), shall apply to the Document Requests. In addition, the following terms used in these Document Requests shall have the following meanings:\n\n1. \"You\" or \"Your\" or \"Yourself\" means and refers, Mercantile Bank International Corp., its employees, agents, counsel, advisors, or anyone acting on its behalf.\n\n2. \"Debtor\" means Ho Wan Kwok (a/k/a Miles Kwok, Miles Guo, Guo Wengui, Guo Haoyun, 郭文贵, or any other alias), together with his employees, agents, counsel, advisors, or anyone acting on his behalf.\n\n#### Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 349 of 1063\n\n3. \"Debtor's Son\" means Qiang Guo (a/k/a Mileson Kwok, 郭强, or any other alias), together with his employees, agents, counsel, advisors, or anyone acting on his behalf.\n\n4. \"Debtor's Daughter\" means Mei Guo (a/k/a Mei Gui, 郭美, or any other alias), together with her employees, agents, counsel, advisors, or anyone acting on her behalf.\n\n5. \"Debtor's Purported Wife\" means Hing Chi Ngok (a/k/a Hing Chi Ng, Yue Qingzhi, 岳庆芝, or any other alias), together with her employees, agents, counsel, advisors, or anyone acting on her behalf.\n\n6. \"Debtor's Family\" means, individually and collectively, the Debtor, the Debtor's Son, the Debtor's Daughter, and the Debtor's Purported Wife, and any other familial relation to the Debtor.\n\n7. \"2004 Discovery Targets\" means, individually and collectively, the Debtor, the Debtor's Family, ACA Capital Group Limited, Himalaya International Financial Group Ltd., Himalaya International Clearing Ltd., Himalaya International Payments Ltd., Himalaya International Reserves Ltd., Jesse Brown, William Je, Eastern Profit Corporation Limited, HK International Funds Investments (USA) Limited LLC, Bravo Luck Limited, Golden Spring (New York) Ltd., Lamp Capital LLC, Greenwich Land LLC, Qu Guo Jiao, Daniel Thomas Podhaskie, Yvette Wang (a/k/a Yanping Wang, a/k/a Yan Ping Wang), Ace Decade Holdings Limited, Dawn State Limited, Rule of Law Society IV Inc., Rule of Law Foundation III, Inc., Rule of Law Foundation IV, Inc., Rule of Law Fund, Rule of Law Society, GTV Media Group, Inc., Voice of Guo Media, Inc., Saraca Media Group Inc., Genever Holdings Corporation, Genever Holdings LLC, Gnews Media Group Inc., G Fashion LLC, Gmusic LLC, Gnews LLC, Geducation, GFNY, Inc., G-Club Investments Limited, G Club Operations LLC, G Club US Operations Inc., G Club US Operations LLC, G Live, LLC, Gbroadcast, LLC, Gposts LLC, HCHK Property Management,\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 350 of 1063\n\nInc., HCHK Technologies, Inc., FMV Ltd./Freedom Media Venture Ltd., Roscalitar 2, Himalaya New World Inc., US Himalaya Capital Inc., Hudson Diamond Holding, Inc., Hudson Diamond Holding LLC, Hudson Diamond NY LLC, Infinity Treasury Management Inc., Lexington Property and Staffing, Inc., AI Group Holdings Inc., Booming Sail New York LLC, Himalaya Ventures LLC, Himalaya Ventures LLC, Himalaya Investment LLC, New York MOS Himalaya LLC, MOS Himalaya LLC, Crane Advisory Group, Maywind Trading LLC, Gettr USA, Inc., Han Chunguang, Bingshang Jiao, Karin Maistrello, Mary Jiang, Jiaming Liu, and Wencong Wang.\n\n8. \"Hamilton Entities\" means Hamilton M&A Fund SP, Hamilton Opportunity Fund SPC, Hamilton Capital Holdings Inc., Hamilton Investment Management Limited, Midvale Avenue Limited, Hamilton Fintech Ltd., and Hamilton Cyber Ltd.\n\n9. \"Including\" or any variant thereof means \"including without limitation.\"\n\n10. \"And\" and \"or\" mean \"and/or,\" and shall be construed both conjunctively as well as disjunctively in order to maximize their scope.\n\n11. \"Any\" and \"all\" and \"each\" mean \"each and every.\"\n\n12. \"Each\" and \"every\" mean \"each and every.\"\n\n13. \"Third Party\" means a Person or Entity other than Yourself.\n\n14. \"Transfer\" shall have the meaning given to it by section 101(54) of the Bankruptcy Code.\n\n15. \"Document\" means any information or thing within the scope of Fed. R. Civ. P. 34, and includes, without limitation, each and every written, recorded, or graphic matter of any kind, type, nature, or description that is or has been in Your Possession, Custody or Control, including all printed and electronic copies of electronic mail, computer files maintained in electronic form,\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 351 of 1063\n\ncorrespondence, memoranda, tapes, stenographic or handwritten notes, written forms of any kind, charts, blueprints, drawings, sketches, graphs, plans, articles, specifications, diaries, letters, telegrams, photographs, minutes, contracts, agreements, surveys, computer printouts, data compilations of any kind, telexes, facsimiles, emails, text messages, instant messages, voice messages, invoices, order forms, checks, drafts, statements, credit memos, reports, position reports, summaries, indices, books, ledgers, notebooks, schedules, transparencies, recordings, catalogs, advertisements, promotional materials, films, video tapes, audio tapes, CDs, computer disks, brochures, pamphlets, punch-cards, time-slips, Tweets, social media posts, or any written or recorded materials of any other kind, and all meta-data thereof, however stored (whether in tangible or electronic form), recorded, produced, or reproduced, and also including but not limited to, drafts or copies of any of the foregoing that contain any notes, comments, or markings of any kind not found on the original documents or that are otherwise not identical to the original documents.\n\n16. \"Person(s)\" means an individual, corporation, proprietorship, partnership, association, or any other Entity. \"Person\" also includes any agent, representatives, or expert, including but not limiting to, attorneys or financial advisors.\n\n17. \"Entity\" means any natural Person, corporation, partnership, subsidiary, sole proprietorship, firm, board, joint venture, association, agency, authority, commission or other business entity or juristic Person, as well as any affiliate, agent, parent including but not limited to counsel, financial advisors, or any other representative.\n\n18. \"Regarding\" means concerning, describing, comprising, referring to, related to, supporting, favoring, opposing, bolstering, detracting from, located in, considered in connection with, bearing on, evidencing, indicating, reporting on, recording, alluding to, responding to,\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 352 of 1063\n\nconnected with, commenting on, in respect of, about, in relation to, discussing, showing, describing, reflecting, analyzing constituting, and being.\n\n19. \"Relating to,\" \"relate(s) to\" or \"related to,\" when referring to any given subject matter, means, without limitation, any document that constitutes, comprises, involves, contains, embodies, reflects, identifies, states, refers directly or indirectly to, or is in any way relevant to the particular subject matter identified.\n\n20. \"Communication(s)\" means, in the broadest possible sense, and without limitation, any transmittal of information or knowledge (in the form of facts, ideas, inquiries, or otherwise). Communication(s) further refers to all conversations, agreements, inquiries, or replies, whether in person, by telephone, in writing, or by means of electronic transmittal devices, and includes, but is not limited to, all correspondence, emails, recordings, transmittal slips, memoranda, telephone communications, voice messages, telegrams, telefaxes, telecopies, telexes, instant messages, chats, text messages, postings to a message board or group chat, social media posts, tweets, videos uploaded to any video platform, telephonic notes, or notes transmitted internally or with third parties.\n\n21. \"Asset(s)\" means any item of economic value that is subject to Possession, Custody, or Control. Asset includes all real and personal property, including but limited to, real estate, land, houses, apartments, condominiums, automobiles, yachts, boats, planes, jets, helicopters, cash, bank accounts, cryptocurrencies, securities, accounts receivables, inventory, and other tangible and intangible property.\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 353 of 1063\n\n## **IV. DOCUMENTS TO BE PRODUCED**\n\n1. All communications between you and the Debtor, Ehsan Masud, David Fallon, the Hamilton Entities, or the 2004 Discovery Targets, including without limitation William Je (a/k/a Je Kin Ming; a/k/a Kin Je; a/k/a William Yu; a/k/a Yu Jianming).\n\n2. All Documents related to any communications between you and the Debtor, Ehsan Masud, David Fallon, the Hamilton Entities, or the 2004 Discovery Targets, including without limitation William Je (a/k/a Je Kin Ming; a/k/a Kin Je; a/k/a William Yu; a/k/a Yu Jianming).\n\n3. All Documents and communications related to any actual, potential, or contemplated investments, business dealings or transactions made by, with, or on behalf of the Debtor, Ehsan Masud, David Fallon, the Hamilton Entities, or the 2004 Discovery Targets, including without limitation William Je (a/k/a Je Kin Ming; a/k/a Kin Je; a/k/a William Yu; a/k/a Yu Jianming).\n\n4. All Documents and communications related to any anti-money laundering, knowyour-customer, or other compliance activity concerning the Debtor, Ehsan Masud, David Fallon, the Hamilton Entities, or the 2004 Discovery Targets, including without limitation William Je (a/k/a Je Kin Ming; a/k/a Kin Je; a/k/a William Yu; a/k/a Yu Jianming), including but not limited to any information provided to You or any regulatory authority from any country, state, locality, law enforcement organization, or sovereign entity, by the Debtor, Ehsan Masud, David Fallon, the Hamilton Entities, or the 2004 Discovery Targets, including without limitation William Je (a/k/a Je Kin Ming; a/k/a Kin Je; a/k/a William Yu; a/k/a Yu Jianming).\n\n5. All Documents and communications relating to: (i) any regulatory authority from any country, state, locality, law enforcement organization, or sovereign entity, including but not limited to the Bank of England, the United States Federal Reserve, the U.S. Securities and\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 354 of 1063\n\nExchange Commission, the Commodities Futures Trading Commission, FINRA, China Securities Regulatory Commission, People's Bank of China, Hong Kong Securities and Futures Commission, and the Hong Kong Monetary Authority, (ii) and the Debtor, Ehsan Masud, David Fallon, the Hamilton Entities, or the 2004 Discovery Targets, including without limitation William Je (a/k/a Je Kin Ming; a/k/a Kin Je; a/k/a William Yu; a/k/a Yu Jianming).\n\nCase 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 355 of 1063\n\n# Exhibit C-19\n\n#### B2540 (Form 2540 – Subpoena for Rule 2004 Examination) (12/15) Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 356 of\n\nUNITED STATES BANKRUPTCY COURT 1063\n\n**District of Connecticut**\n\nIn re HO WAN KWOK, *et al*.,\n\n<sup>1</sup> Case No. 22-50073 (JAM)\n\nDebtor Chapter 11\n\n(Jointly Administered)\n\n## **SUBPOENA FOR RULE 2004 EXAMINATION**\n\nTo: **Mercantile Bank International Corp.**\n\n(*Name of person to whom the subpoena is directed*)\n\n*Testimony:* **YOU ARE COMMANDED** to appear at the time, date, and place set forth below to testify at an examination under Rule 2004, Federal Rules of Bankruptcy Procedure. A copy of the court order authorizing the examination is attached.\n\n| PLACE                    | DATE AND TIME |\n|--------------------------|---------------|\n| Paul Hastings LLP        |               |\n| 200 Park Avenue          | [TBD]         |\n| New York, New York 10166 |               |\n|                          |               |\n\nThe examination will be recorded by this method: **Court reporter/stenographer**\n\n*Production:* You, or your representatives, must also bring with you to the examination the following documents, electronically stored information, or objects, and must permit inspection, copying, testing, or sampling of the material:\n\n#### **See Requests for Production of Documents, attached hereto.**\n\nThe following provisions of Fed. R. Civ. P. 45, made applicable in bankruptcy cases by Fed. R. Bankr. P. 9016, are attached – Rule 45(c), relating to the place of compliance; Rule 45(d), relating to your protection as a person subject to a subpoena; and Rule 45(e) and 45(g), relating to your duty to respond to this subpoena and the potential consequences of not doing so.\n\nDate: **March , 2023**\n\nCLERK OF COURT\n\nOR\n\n*Signature of Clerk or Deputy Clerk Attorney's signature*\n\nThe name, address, email address, and telephone number of the attorney representing Luc A. Despins, Chapter 11 Trustee, who issues or requests this subpoena, are:\n\n**Douglas S. Skalka, Esq.; Neubert, Pepe & Monteith, P.C.; 195 Church Street, New Haven, Connecticut 06510 dskalka@npmlaw.com; (203) 821-2000**\n\n**Notice to the person who issues or requests this subpoena**\n\nIf this subpoena commands the production of documents, electronically stored information, or tangible things, or the inspection of premises before trial, a notice and a copy of this subpoena must be served on each party before it is served on the person to whom it is directed. Fed. R. Civ. P. 45(a)(4).\n\nSoftware Copyright (c) 1996-2022 Best Case, LLC - www.bestcase.com Best Case Bankruptcy 1 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\n#### **PROOF OF SERVICE**\n\n**(This section should not be filed with the court unless required by Fed. R. Civ. P. 45.)**\n\nI received this subpoena for (*name of individual and title, if any*): on (*date*) .\n\nI served the subpoena by delivering a copy to the named person as follows:\n\non *(date)* ; or\n\nI returned the subpoena unexecuted because:\n\nUnless the subpoena was issued on behalf of the United States, or one of its officers or agents, I have also tendered to the witness the fees for one day's attendance, and the mileage allowed by law, in the amount of \\$ .\n\nMy fees are \\$ for travel and \\$ for services, for a total of \\$ .\n\nI declare under penalty of perjury that this information is true and correct.\n\nDate:\n\n*Server's signature*\n\n*Printed name and title*\n\n*Server's address*\n\nAdditional information concerning attempted service, etc.:\n\n#### **Federal Rule of Civil Procedure 45(c), (d), (e), and (g) (Effective 12/1/13) (made applicable in bankruptcy cases by Rule 9016, Federal Rules of Bankruptcy Procedure)**\n\n#### **(c) Place of compliance.**\n\n*(1) For a Trial, Hearing, or Deposition.* A subpoena may command a person to attend a trial, hearing, or deposition only as follows:\n\n(A) within 100 miles of where the person resides, is employed, or regularly transacts business in person; or\n\n(B) within the state where the person resides, is employed, or regularly transacts business in person, if the person\n\n(i) is a party or a party's officer; or\n\n(ii) is commanded to attend a trial and would not incur substantial expense.\n\n*(2) For Other Discovery.* A subpoena may command:\n\n(A) production of documents, or electronically stored information, or things at a place within 100 miles of where the person resides, is employed, or regularly transacts business in person; and\n\n(B) inspection of premises, at the premises to be inspected.\n\n#### **(d) Protecting a Person Subject to a Subpoena; Enforcement.**\n\n*(1) Avoiding Undue Burden or Expense; Sanctions.* A party or attorney responsible for issuing and serving a subpoena must take reasonable steps to avoid imposing undue burden or expense on a person subject to the subpoena. The court for the district where compliance is required must enforce this duty and impose an appropriate sanction which may include lost earnings and reasonable attorney's fees — on a party or attorney who fails to comply.\n\n#### *(2) Command to Produce Materials or Permit Inspection.*\n\n*(A) Appearance Not Required.* A person commanded to produce documents, electronically stored information, or tangible things, or to permit the inspection of premises, need not appear in person at the place of production or inspection unless also commanded to appear for a deposition, hearing, or trial.\n\n*(B) Objections.* A person commanded to produce documents or tangible things or to permit inspection may serve on the party or attorney designated in the subpoena a written objection to inspecting, copying, testing or sampling any or all of the materials or to inspecting the premises — or to producing electronically stored information in the form or forms requested. The objection must be served before the earlier of the time specified for compliance or 14 days after the subpoena is served. If an objection is made, the following rules apply:\n\n(i) At any time, on notice to the commanded person, the serving party may move the court for the district where compliance is required for an order compelling production or inspection.\n\n(ii) These acts may be required only as directed in the order, and the order must protect a person who is neither a party nor a party's officer from significant expense resulting from compliance.\n\n#### *(3) Quashing or Modifying a Subpoena.*\n\n*(A) When Required.* On timely motion, the court for the district where compliance is required must quash or modify a subpoena that:\n\n(i) fails to allow a reasonable time to comply;\n\n(ii) requires a person to comply beyond the geographical limits specified in Rule 45(c);\n\n(iii) requires disclosure of privileged or other protected matter, if no exception or waiver applies; or\n\n(iv) subjects a person to undue burden.\n\n*(B) When Permitted.* To protect a person subject to or affected by a subpoena, the court for the district where compliance is required may, on motion, quash or modify the subpoena if it requires:\n\n(i) disclosing a trade secret or other confidential research, development, or commercial information; or\n\n(ii) disclosing an unretained expert's opinion or information that does not describe specific occurrences in dispute and results from the expert's study that was not requested by a party.\n\n(C) *Specifying Conditions as an Alternative.* In the circumstances described in Rule 45(d)(3)(B), the court may, instead of quashing or modifying a subpoena, order appearance or production under specified conditions if the serving party:\n\n(i) shows a substantial need for the testimony or material that cannot be otherwise met without undue hardship; and\n\n(ii) ensures that the subpoenaed person will be reasonably compensated.\n\n#### **(e) Duties in Responding to a Subpoena.**\n\n*(1) Producing Documents or Electronically Stored Information.* These procedures apply to producing documents or electronically stored information:\n\n*(A) Documents.* A person responding to a subpoena to produce documents must produce them as they are kept in the ordinary course of business or must organize and label them to correspond to the categories in the demand.\n\n*(B) Form for Producing Electronically Stored Information Not Specified.* If a subpoena does not specify a form for producing electronically stored information, the person responding must produce it in a form or forms in which it is ordinarily maintained or in a reasonably usable form or forms.\n\n*(C) Electronically Stored Information Produced in Only One Form.* The person responding need not produce the same electronically stored information in more than one form.\n\n*(D) Inaccessible Electronically Stored Information.* The person responding need not provide discovery of electronically stored information from sources that the person identifies as not reasonably accessible because of undue burden or cost. On motion to compel discovery or for a protective order, the person responding must show that the information is not reasonably accessible because of undue burden or cost. If that showing is made, the court may nonetheless order discovery from such sources if the requesting party shows good cause, considering the limitations of Rule 26(b)(2)(C). The court may specify conditions for the discovery.\n\n#### *(2) Claiming Privilege or Protection.*\n\n*(A) Information Withheld.* A person withholding subpoenaed information under a claim that it is privileged or subject to protection as trial-preparation material must: (i) expressly make the claim; and\n\n(ii) describe the nature of the withheld documents, communications, or tangible things in a manner that, without revealing information itself privileged or protected, will enable the parties to assess the claim.\n\n*(B) Information Produced.* If information produced in response to a subpoena is subject to a claim of privilege or of protection as trial-preparation material, the person making the claim may notify any party that received the information of the claim and the basis for it. After being notified, a party must promptly return, sequester, or destroy the specified information and any copies it has; must not use or disclose the information until the claim is resolved; must take reasonable steps to retrieve the information if the party disclosed it before being notified; and may promptly present the information under seal to the court for the district where compliance is required for a determination of the claim. The person who produced the information must preserve the information until the claim is resolved.\n\n**(g) Contempt.** The court for the district where compliance is required – and also, after a motion is transferred, the issuing court – may hold in contempt a person who, having been served, fails without adequate excuse to obey the subpoena or an order related to it.\n\nFor access to subpoena materials, see Fed.R.Civ.P.45(a) Committee Note (2013)\n\n…\n\n## **Request for Production of Documents**\n\n## **I. INSTRUCTIONS**\n\n1. Unless otherwise indicated, the requests for documents set forth below, (the \"Requests,\" and each, a \"Request\"), must be responded to separately and specifically. Each Request shall be answered fully unless it is in good faith objected to, in which event the reason for Your objection shall be stated in detail, as set forth below. If an objection pertains only to a portion of a Request, or a word, phrase or clause contained within it, You are required to state Your objection to that portion only and to respond to the remainder of the Requests.\n\n2. Electronically stored information must be produced in accordance with the\n\nfollowing instructions:\n\n- a. Images. Black and white images must be 300 DPI Group IV single-page TIFF files. Color images must be produced in JPEG format. File names cannot contain embedded spaces or special characters (including the comma). Folder names cannot contain embedded spaces or special characters (including the comma). All TIFF image files must have a unique file name, i.e. Bates number. Images must be endorsed with sequential Bates numbers in the lower right corner of each image. The number of TIFF files per folder should not exceed 1000 files. Excel spreadsheets should have a placeholder image named by the Bates number of the file.\n- b. Image Load File\n\t- a. Concordance® Data File. The data file (.DAT) contains all of the fielded information that will be loaded into the Concordance® database. The first line of the .DAT file must be a header row identifying the field names. The .DAT file must use the following Concordance® default delimiters: Comma ASCII character (020) Quote þ ASCII character (254). Date fields should be provided in the format: mm/dd/yyyy. Date and time fields must be two separate fields. If documents includes imaged emails and attachments, the attachment fields must be included to preserve the parent/child relationship between an email and its attachments. An OCRPATH field must be included to provide the file path and name of the extracted text file on the produced storage media. The text file must be named after the FIRSTBATES. Do not include the text in the .DAT file. For Documents with native files, a LINK field must be included to provide the file path and\n\nname of the native file. The native file must be named after the FIRSTBATES.\n\n- b. Concordance Image® OR Opticon Cross-Reference File. The image crossreference file (.LOG or .OPT) links the images to the database records. It should be a comma-delimited file consisting of seven fields per line with a line in the cross-reference file for every image in the database with the following format: ImageID,VolumeLabel,ImageFilePath,DocumentBreak,FolderBreak,Box Break,PageCoun.\n- c. Document Text. Text must be produced as separate text files, not as fields within the .DAT file. The full path to the text file (OCRPATH) should be included in the .DAT file. It is recommended document level ANSI text files, named per the FIRSTBATES/Image Key. Extracted text files must be in a separate folder, and the number of text files per folder should not exceed 1,000 files. There should be no special characters (including commas in the folder names). Text files must be provided on a document level.\n- d. Native Production for Certain File Types. File types that reasonably require viewing in their native format for a full understanding of their content and meaning must be produced in native format. These include, but are not limited to, spreadsheets, spreadsheet-like files (Microsoft Excel, comma separated values, tab separated values, etc.), Microsoft PowerPoint or other special presentation files, database files, and audio/visual files. Provide an image of a Bates numbered slip sheet indicating the presence of a native file, and include the path to the native as a field in the .dat file. Name the produced native file with the Bates number corresponding to the slip sheet for the file. Group native files within incrementally named \"NATIVE\" directories, separate from images directories.\n- e. De-duplication. Produce a single copy of each electronic document for which exact duplicates exist. For email messages, consolidate duplicates based on MD5 hash generated from the BCC, Body, CC, From, IntMsgID, To, and Attach properties. For email attachments and standalone electronic files, consolidate duplicates based on MD5 hash of the entire file.\n- f. Metadata. Produce extracted metadata for each document in the form of a Concordance compliant load file (.dat). The first line of the .DAT file must be a header row identifying the field names. The .DAT file must use the following Concordance default delimiters: Comma , ASCII character (020) Quote þ ASCII character (254)\n\nDate fields should be provided in the format: mm/dd/yyyy. Date and time fields must be two separate fields. Required metadata listed below:\n\n# Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 361 of 1063\n\n| Field Name   | Sample Data              | Description                                                                                  |\n|--------------|--------------------------|----------------------------------------------------------------------------------------------|\n| FIRSTBATES   | EDC0000001               | First Bates number of native file document/email                                             |\n| LASTBATES    | EDC0000001               | Last Bates number of native file document/email<br>**The LASTBATES field should be populated |\n|              |                          | for single page                                                                              |\n| ATTACHRANGE  | EDC0000001<br>-          | Bates number of the first page of the parent                                                 |\n|              | EDC0000015               | document to the Bates number of the last page of                                             |\n|              |                          | the last attachment \"child\" document                                                         |\n| BEGATTACH    | EDC0000001               | First Bates number of attachment range                                                       |\n| ENDATTACH    | EDC0000015               | Last Bates number of attachment range                                                        |\n| CUSTODIAN    | Smith, John              | Email: Mailbox where the email resided                                                       |\n|              |                          | Native: Name of the individual or department                                                 |\n|              |                          | from whose files the document<br>originated                                                  |\n| FROM         | John Smith               | Email: Sender                                                                                |\n|              |                          | Native: Author(s) of document                                                                |\n|              |                          | **semi-colon should be used to separate                                                      |\n|              |                          | multiple entries                                                                             |\n| TO           | Coffman, Janice; LeeW    | Recipient(s)                                                                                 |\n|              | [mailto:LeeW@MSN.com]    | **semi-colon should be used to separate multiple                                             |\n|              |                          | entries                                                                                      |\n| CC           | Frank Thompson [mailto:  | Carbon copy recipient(s)                                                                     |\n|              | frank_Thompson@cdt.com]  | **semi-colon should be used to separate                                                      |\n|              |                          | multiple entries                                                                             |\n| BCC          | John Cain                | Blind carbon copy recipient(s)                                                               |\n|              |                          | **semi-colon should be used to separate                                                      |\n|              |                          | multiple entries                                                                             |\n| SUBJECT      | Board Meeting Minutes    | Email: Subject line of the email Native: Title                                               |\n|              |                          | of document (if available)                                                                   |\n| FILE_NAME    | BoardMeetingMinutes.docx | Native: Name of the original native file,                                                    |\n|              |                          | including extension                                                                          |\n| DATE_SENT    | 10/12/2010               | Email: Date the email was sent                                                               |\n|              |                          | Native: (empty)                                                                              |\n| TIME_SENT/   | 07:05 PM GMT             | Email: Time the email was sent/ Time zone in                                                 |\n| TIME_ZONE    |                          | which the emails were standardized                                                           |\n| TIME_ZONE    | GMT                      | The<br>time zone in which<br>the emails<br>were                                              |\n|              |                          | standardized during conversion.                                                              |\n| LINK         |  EDC0000001.msg   | Hyperlink to the email or native file document                                               |\n|              |                          | **The linked file must be named per the                                                      |\n|              |                          | FIRSTBATES number                                                                            |\n| FILE_EXTEN   | MSG                      | The file type extension                                                                      |\n|              |                          | representing                                                                                 |\n|              |                          | the Email or                                                                                 |\n| AUTHOR       | John Smith               | Email: (empty)                                                                               |\n|              |                          | Native: Author of the document                                                               |\n| DATE_CREATED | 10/10/2010               | Email: (empty)                                                                               |\n|              |                          | Native: Date the document was created                                                        |\n\n# Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 362 of 1063\n\n| TIME_CREATED | 10:25 AM                  | Email: (empty)                                  |\n|--------------|---------------------------|-------------------------------------------------|\n|              |                           | Native: Time the document was created           |\n|              |                           | **This data must be a separate field and cannot |\n|              |                           | be combined with the DATE_CREATED field         |\n| DATE_MOD     | 10/12/2010                | Email: (empty)                                  |\n|              |                           | Native: Date the document was last modified     |\n| TIME_MOD     | 07:00 PM                  | Email: (empty)                                  |\n|              |                           | Native: Time the document was last modified     |\n|              |                           | **This data must be a separate field and cannot |\n|              |                           | be combined with the DATE_MOD field             |\n| DATE_ACCESSD | 10/12/2010                | Email: (empty)                                  |\n|              |                           | Native: Date the document was last accessed     |\n| TIME_ACCESSD | 07:00 PM                  | Email: (empty)                                  |\n|              |                           | Native: Time the document was last accessed     |\n|              |                           | **This data must be a separate field and cannot |\n|              |                           | be combined with the DATE_ACCESSD field         |\n| FILE_SIZE    | 5,952                     | Size of native file<br>document/email in KB     |\n| PGCOUNT      | 1                         | Number of pages in native file document/email   |\n| PATH         |   | Email: (empty)                                  |\n|              | Agenda.doc                | Native: Path where native file document was     |\n|              |                           | stored including original file name.            |\n| INTFILEPATH  | Personal Folders\\Deleted  | Email: original location of email including     |\n|              | Items\\Board Meeting       | original file name.                             |\n|              | Minutes.msg               | Native: (empty)                                 |\n| INTMSGID     | <000805c2c71b\\$75977050\\$ | Email: Unique Message ID Native: (empty)        |\n|              | cb8306d1@MSN>             |                                                 |\n| MD5HASH      | d131dd02c5e6eec4693d9a0   | MD5 Hash value of the document.                 |\n|              | 698aff95c                 |                                                 |\n|              | 2fcab58712467eab4004583e  |                                                 |\n|              | b8fb7f89                  |                                                 |\n| OCRPATH      | TEXT/001/EDC0000001.txt   | Path to extracted text of the native file       |\n\n3. Each Request operates and should be construed independently and, unless otherwise indicated, no Request limits the scope of any other Request.\n\n4. All Documents are to be produced as kept in the usual course of business or are to be organized and labeled to correspond with the categories in these Requests.\n\n5. Each Request contained herein extends to all Documents: (a) in Your possession, custody, or control; or (b) in the possession, custody, or control of anyone acting on Your behalf,\n\n#### Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 363 of 1063\n\nincluding Your counsel or other representatives and advisors. Each Document shall be produced in its entirety.\n\n6. If You are requested to produce a Document that is no longer in Your possession, custody, or control, then Your response must (a) describe in detail the nature of the document and its contents; (b) identify the person(s) who prepared or authored the Document (and, if applicable, the Person(s) to whom the Document was sent); (c) identify the date on which the document was prepared or created; (d) state whether such Document (i) is missing or lost, (ii) has been destroyed, (iii) has been transferred, voluntarily or involuntarily, to others, or (iv) was otherwise disposed of; (e) state the reason for, and the facts and circumstances surrounding, such disposition; (f) identify the Persons who authorized such disposition; (g) identify the date or approximate date of such disposition; (h) state when the Document was most recently in Your possession, custody or control; and (i) identify the Person, if any, presently in possession, custody, or control of such Document.\n\n7. If You are requested to produce a Document that has been destroyed, then Your response must state, in addition to the information required by the preceding Instruction: (a) the reason for the Document's destruction; (b) the identity of the Person who destroyed the Document; and (c) the identity of the Person who directed that the Document be destroyed.\n\n8. If You claim that a requested Document is privileged or attorney work-product, then Your response must: (a) state (i) a description of the Document adequate to support Your contention that the Document is privileged, (ii) the title of the Document, (iii) the date of the Document, (iv) the author of the Document, (v) the addressee of the Document, (vi) the identity of each Person who received or saw the original or any draft, copy, or reproduction of the Document, (vii) whether the Document itself, or any information contained or referred to in the Document is in the possession, custody, or control of any other Persons, and if so, the identity of\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 364 of 1063\n\nsuch Persons, as well as a statement addressing how the information came into their possession, (viii) the claim of privilege under which the Document is withheld, and (ix) all of the circumstances upon which You will rely to support such claim of privilege; and (b) produce a privilege log containing all of the information requested in Part (a) of this Instruction for each Document withheld on the basis of a claim of privilege in accordance with D. Conn. L. Civ. R. 26(e). For any part of a Document Request as to which a claim of privilege or work product is not made, responsive documents should be provided in full.\n\n9. If a portion of an otherwise responsive Document contains information subject to a claim of privilege, only that portion of the Document subject to the claim of privilege shall be deleted or redacted from the Document following the instructions above, and the rest shall be produced.\n\n10. The Requests are continuing in nature. You are hereby instructed to (a) supplement or correct any responses later learned to be incomplete or incorrect immediately upon learning that a prior response was incomplete or incorrect; and (b) produce any additional Documents that are called for under the\n\n11. If a Document is in a language other than English, You should provide that Document. If a Document is in a language other than English, and an English translation exists, You should provide both Documents.\n\n12. All references to Entities includes all affiliates thereof.\n\n13. All references to individual names include all alternative names, aliased, or nicknames.\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 365 of 1063\n\n14. Unless otherwise expressly indicated, the period of time covered by the Document Requests is the period from February 5, 2015 to the date responses to the Document Requests are due.\n\n#### **II. RULES OF CONSTRUCTION**\n\n15. The use of (a) any singular noun shall be construed to include the plural, and vice versa, and (b) a verb in any tense shall be construed as the use of the verb in all other tenses.\n\n16. The terms (a) \"and\" and \"or\" shall be construed either conjunctively or disjunctively as necessary to bring within the scope of any request all responses that might otherwise be construed to be outside of its scope, and (b) \"each\" and \"any\" shall be deemed to include and encompass the words \"every\" and \"all.\"\n\n#### **III. DEFINITIONS**\n\nThe definitions supplied by D. Conn. L. Civ. R. 26(c) and the rules of construction supplied by D. Conn. L. Civ. R. 26(d), as incorporated by D. Conn. Bankr. L.R. 2004-1(a), shall apply to the Document Requests. In addition, the following terms used in these Document Requests shall have the following meanings:\n\n1. \"You\" or \"Your\" or \"Yourself\" means and refers, Mercantile Global Holdings, Inc., its employees, agents, counsel, advisors, or anyone acting on its behalf.\n\n2. \"Debtor\" means Ho Wan Kwok (a/k/a Miles Kwok, Miles Guo, Guo Wengui, Guo Haoyun, 郭文贵, or any other alias), together with his employees, agents, counsel, advisors, or anyone acting on his behalf.\n\n#### Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 366 of 1063\n\n3. \"Debtor's Son\" means Qiang Guo (a/k/a Mileson Kwok, 郭强, or any other alias), together with his employees, agents, counsel, advisors, or anyone acting on his behalf.\n\n4. \"Debtor's Daughter\" means Mei Guo (a/k/a Mei Gui, 郭美, or any other alias), together with her employees, agents, counsel, advisors, or anyone acting on her behalf.\n\n5. \"Debtor's Purported Wife\" means Hing Chi Ngok (a/k/a Hing Chi Ng, Yue Qingzhi, 岳庆芝, or any other alias), together with her employees, agents, counsel, advisors, or anyone acting on her behalf.\n\n6. \"Debtor's Family\" means, individually and collectively, the Debtor, the Debtor's Son, the Debtor's Daughter, and the Debtor's Purported Wife, and any other familial relation to the Debtor.\n\n7. \"2004 Discovery Targets\" means, individually and collectively, the Debtor, the Debtor's Family, ACA Capital Group Limited, Himalaya International Financial Group Ltd., Himalaya International Clearing Ltd., Himalaya International Payments Ltd., Himalaya International Reserves Ltd., Jesse Brown, William Je, Eastern Profit Corporation Limited, HK International Funds Investments (USA) Limited LLC, Bravo Luck Limited, Golden Spring (New York) Ltd., Lamp Capital LLC, Greenwich Land LLC, Qu Guo Jiao, Daniel Thomas Podhaskie, Yvette Wang (a/k/a Yanping Wang, a/k/a Yan Ping Wang), Ace Decade Holdings Limited, Dawn State Limited, Rule of Law Society IV Inc., Rule of Law Foundation III, Inc., Rule of Law Foundation IV, Inc., Rule of Law Fund, Rule of Law Society, GTV Media Group, Inc., Voice of Guo Media, Inc., Saraca Media Group Inc., Genever Holdings Corporation, Genever Holdings LLC, Gnews Media Group Inc., G Fashion LLC, Gmusic LLC, Gnews LLC, Geducation, GFNY, Inc., G-Club Investments Limited, G Club Operations LLC, G Club US Operations Inc., G Club US Operations LLC, G Live, LLC, Gbroadcast, LLC, Gposts LLC, HCHK Property Management,\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 367 of 1063\n\nInc., HCHK Technologies, Inc., FMV Ltd./Freedom Media Venture Ltd., Roscalitar 2, Himalaya New World Inc., US Himalaya Capital Inc., Hudson Diamond Holding, Inc., Hudson Diamond Holding LLC, Hudson Diamond NY LLC, Infinity Treasury Management Inc., Lexington Property and Staffing, Inc., AI Group Holdings Inc., Booming Sail New York LLC, Himalaya Ventures LLC, Himalaya Ventures LLC, Himalaya Investment LLC, New York MOS Himalaya LLC, MOS Himalaya LLC, Crane Advisory Group, Maywind Trading LLC, Gettr USA, Inc., Han Chunguang, Bingshang Jiao, Karin Maistrello, Mary Jiang, Jiaming Liu, and Wencong Wang.\n\n8. \"Hamilton Entities\" means Hamilton M&A Fund SP, Hamilton Opportunity Fund SPC, Hamilton Capital Holdings Inc., Hamilton Investment Management Limited, Midvale Avenue Limited, Hamilton Fintech Ltd., and Hamilton Cyber Ltd.\n\n9. \"Including\" or any variant thereof means \"including without limitation.\"\n\n10. \"And\" and \"or\" mean \"and/or,\" and shall be construed both conjunctively as well as disjunctively in order to maximize their scope.\n\n11. \"Any\" and \"all\" and \"each\" mean \"each and every.\"\n\n12. \"Each\" and \"every\" mean \"each and every.\"\n\n13. \"Third Party\" means a Person or Entity other than Yourself.\n\n14. \"Transfer\" shall have the meaning given to it by section 101(54) of the Bankruptcy Code.\n\n15. \"Document\" means any information or thing within the scope of Fed. R. Civ. P. 34, and includes, without limitation, each and every written, recorded, or graphic matter of any kind, type, nature, or description that is or has been in Your Possession, Custody or Control, including all printed and electronic copies of electronic mail, computer files maintained in electronic form,\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 368 of 1063\n\ncorrespondence, memoranda, tapes, stenographic or handwritten notes, written forms of any kind, charts, blueprints, drawings, sketches, graphs, plans, articles, specifications, diaries, letters, telegrams, photographs, minutes, contracts, agreements, surveys, computer printouts, data compilations of any kind, telexes, facsimiles, emails, text messages, instant messages, voice messages, invoices, order forms, checks, drafts, statements, credit memos, reports, position reports, summaries, indices, books, ledgers, notebooks, schedules, transparencies, recordings, catalogs, advertisements, promotional materials, films, video tapes, audio tapes, CDs, computer disks, brochures, pamphlets, punch-cards, time-slips, Tweets, social media posts, or any written or recorded materials of any other kind, and all meta-data thereof, however stored (whether in tangible or electronic form), recorded, produced, or reproduced, and also including but not limited to, drafts or copies of any of the foregoing that contain any notes, comments, or markings of any kind not found on the original documents or that are otherwise not identical to the original documents.\n\n16. \"Person(s)\" means an individual, corporation, proprietorship, partnership, association, or any other Entity. \"Person\" also includes any agent, representatives, or expert, including but not limiting to, attorneys or financial advisors.\n\n17. \"Entity\" means any natural Person, corporation, partnership, subsidiary, sole proprietorship, firm, board, joint venture, association, agency, authority, commission or other business entity or juristic Person, as well as any affiliate, agent, parent including but not limited to counsel, financial advisors, or any other representative.\n\n18. \"Regarding\" means concerning, describing, comprising, referring to, related to, supporting, favoring, opposing, bolstering, detracting from, located in, considered in connection with, bearing on, evidencing, indicating, reporting on, recording, alluding to, responding to,\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 369 of 1063\n\nconnected with, commenting on, in respect of, about, in relation to, discussing, showing, describing, reflecting, analyzing constituting, and being.\n\n19. \"Relating to,\" \"relate(s) to\" or \"related to,\" when referring to any given subject matter, means, without limitation, any document that constitutes, comprises, involves, contains, embodies, reflects, identifies, states, refers directly or indirectly to, or is in any way relevant to the particular subject matter identified.\n\n20. \"Communication(s)\" means, in the broadest possible sense, and without limitation, any transmittal of information or knowledge (in the form of facts, ideas, inquiries, or otherwise). Communication(s) further refers to all conversations, agreements, inquiries, or replies, whether in person, by telephone, in writing, or by means of electronic transmittal devices, and includes, but is not limited to, all correspondence, emails, recordings, transmittal slips, memoranda, telephone communications, voice messages, telegrams, telefaxes, telecopies, telexes, instant messages, chats, text messages, postings to a message board or group chat, social media posts, tweets, videos uploaded to any video platform, telephonic notes, or notes transmitted internally or with third parties.\n\n21. \"Asset(s)\" means any item of economic value that is subject to Possession, Custody, or Control. Asset includes all real and personal property, including but limited to, real estate, land, houses, apartments, condominiums, automobiles, yachts, boats, planes, jets, helicopters, cash, bank accounts, cryptocurrencies, securities, accounts receivables, inventory, and other tangible and intangible property.\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 370 of 1063\n\n## **IV. DOCUMENTS TO BE PRODUCED**\n\n1. All communications between you and the Debtor, Ehsan Masud, David Fallon, the Hamilton Entities, or the 2004 Discovery Targets, including without limitation William Je (a/k/a Je Kin Ming; a/k/a Kin Je; a/k/a William Yu; a/k/a Yu Jianming).\n\n2. All Documents related to any communications between you and the Debtor, Ehsan Masud, David Fallon, the Hamilton Entities, or the 2004 Discovery Targets, including without limitation William Je (a/k/a Je Kin Ming; a/k/a Kin Je; a/k/a William Yu; a/k/a Yu Jianming).\n\n3. All Documents and communications related to any actual, potential, or contemplated investments, business dealings or transactions made by, with, or on behalf of the Debtor, Ehsan Masud, David Fallon, the Hamilton Entities, or the 2004 Discovery Targets, including without limitation William Je (a/k/a Je Kin Ming; a/k/a Kin Je; a/k/a William Yu; a/k/a Yu Jianming).\n\n4. All Documents and communications related to any anti-money laundering, knowyour-customer, or other compliance activity concerning the Debtor, Ehsan Masud, David Fallon, the Hamilton Entities, or the 2004 Discovery Targets, including without limitation William Je (a/k/a Je Kin Ming; a/k/a Kin Je; a/k/a William Yu; a/k/a Yu Jianming), including but not limited to any information provided to You or any regulatory authority from any country, state, locality, law enforcement organization, or sovereign entity, by the Debtor, Ehsan Masud, David Fallon, the Hamilton Entities, or the 2004 Discovery Targets, including without limitation William Je (a/k/a Je Kin Ming; a/k/a Kin Je; a/k/a William Yu; a/k/a Yu Jianming).\n\n5. All Documents and communications relating to: (i) any regulatory authority from any country, state, locality, law enforcement organization, or sovereign entity, including but not limited to the Bank of England, the United States Federal Reserve, the U.S. Securities and\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 371 of 1063\n\nExchange Commission, the Commodities Futures Trading Commission, FINRA, China Securities Regulatory Commission, People's Bank of China, Hong Kong Securities and Futures Commission, and the Hong Kong Monetary Authority, (ii) and the Debtor, Ehsan Masud, David Fallon, the Hamilton Entities, or the 2004 Discovery Targets, including without limitation William Je (a/k/a Je Kin Ming; a/k/a Kin Je; a/k/a William Yu; a/k/a Yu Jianming).\n\n# Exhibit C-20\n\n#### B2540 (Form 2540 – Subpoena for Rule 2004 Examination) (12/15) Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 373 of\n\nUNITED STATES BANKRUPTCY COURT 1063\n\n**District of Connecticut**\n\nIn re HO WAN KWOK, *et al*.,\n\n<sup>1</sup> Case No. 22-50073 (JAM)\n\nDebtor Chapter 11\n\n(Jointly Administered)\n\n## **SUBPOENA FOR RULE 2004 EXAMINATION**\n\nTo: **Hamilton M&A Fund SP**\n\n(*Name of person to whom the subpoena is directed*)\n\n*Testimony:* **YOU ARE COMMANDED** to appear at the time, date, and place set forth below to testify at an examination under Rule 2004, Federal Rules of Bankruptcy Procedure. A copy of the court order authorizing the examination is attached.\n\n| PLACE                    | DATE AND TIME |\n|--------------------------|---------------|\n| Paul Hastings LLP        |               |\n| 200 Park Avenue          | [TBD]         |\n| New York, New York 10166 |               |\n|                          |               |\n\nThe examination will be recorded by this method: **Court reporter/stenographer**\n\n*Production:* You, or your representatives, must also bring with you to the examination the following documents, electronically stored information, or objects, and must permit inspection, copying, testing, or sampling of the material:\n\n#### **See Requests for Production of Documents, attached hereto.**\n\nThe following provisions of Fed. R. Civ. P. 45, made applicable in bankruptcy cases by Fed. R. Bankr. P. 9016, are attached – Rule 45(c), relating to the place of compliance; Rule 45(d), relating to your protection as a person subject to a subpoena; and Rule 45(e) and 45(g), relating to your duty to respond to this subpoena and the potential consequences of not doing so.\n\nDate: **March , 2023**\n\nCLERK OF COURT\n\nOR\n\n*Signature of Clerk or Deputy Clerk Attorney's signature*\n\nThe name, address, email address, and telephone number of the attorney representing Luc A. Despins, Chapter 11 Trustee, who issues or requests this subpoena, are:\n\n**Douglas S. Skalka, Esq.; Neubert, Pepe & Monteith, P.C.; 195 Church Street, New Haven, Connecticut 06510 dskalka@npmlaw.com; (203) 821-2000**\n\n**Notice to the person who issues or requests this subpoena**\n\nIf this subpoena commands the production of documents, electronically stored information, or tangible things, or the inspection of premises before trial, a notice and a copy of this subpoena must be served on each party before it is served on the person to whom it is directed. Fed. R. Civ. P. 45(a)(4).\n\nSoftware Copyright (c) 1996-2022 Best Case, LLC - www.bestcase.com Best Case Bankruptcy 1 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\n#### **PROOF OF SERVICE**\n\n**(This section should not be filed with the court unless required by Fed. R. Civ. P. 45.)**\n\nI received this subpoena for (*name of individual and title, if any*): on (*date*) .\n\nI served the subpoena by delivering a copy to the named person as follows:\n\non *(date)* ; or\n\nI returned the subpoena unexecuted because:\n\nUnless the subpoena was issued on behalf of the United States, or one of its officers or agents, I have also tendered to the witness the fees for one day's attendance, and the mileage allowed by law, in the amount of \\$ .\n\nMy fees are \\$ for travel and \\$ for services, for a total of \\$ .\n\nI declare under penalty of perjury that this information is true and correct.\n\nDate:\n\n*Server's signature*\n\n*Printed name and title*\n\n*Server's address*\n\nAdditional information concerning attempted service, etc.:\n\n#### **Federal Rule of Civil Procedure 45(c), (d), (e), and (g) (Effective 12/1/13) (made applicable in bankruptcy cases by Rule 9016, Federal Rules of Bankruptcy Procedure)**\n\n#### **(c) Place of compliance.**\n\n*(1) For a Trial, Hearing, or Deposition.* A subpoena may command a person to attend a trial, hearing, or deposition only as follows:\n\n(A) within 100 miles of where the person resides, is employed, or regularly transacts business in person; or\n\n(B) within the state where the person resides, is employed, or regularly transacts business in person, if the person\n\n(i) is a party or a party's officer; or\n\n(ii) is commanded to attend a trial and would not incur substantial expense.\n\n*(2) For Other Discovery.* A subpoena may command:\n\n(A) production of documents, or electronically stored information, or things at a place within 100 miles of where the person resides, is employed, or regularly transacts business in person; and\n\n(B) inspection of premises, at the premises to be inspected.\n\n#### **(d) Protecting a Person Subject to a Subpoena; Enforcement.**\n\n*(1) Avoiding Undue Burden or Expense; Sanctions.* A party or attorney responsible for issuing and serving a subpoena must take reasonable steps to avoid imposing undue burden or expense on a person subject to the subpoena. The court for the district where compliance is required must enforce this duty and impose an appropriate sanction which may include lost earnings and reasonable attorney's fees — on a party or attorney who fails to comply.\n\n#### *(2) Command to Produce Materials or Permit Inspection.*\n\n*(A) Appearance Not Required.* A person commanded to produce documents, electronically stored information, or tangible things, or to permit the inspection of premises, need not appear in person at the place of production or inspection unless also commanded to appear for a deposition, hearing, or trial.\n\n*(B) Objections.* A person commanded to produce documents or tangible things or to permit inspection may serve on the party or attorney designated in the subpoena a written objection to inspecting, copying, testing or sampling any or all of the materials or to inspecting the premises — or to producing electronically stored information in the form or forms requested. The objection must be served before the earlier of the time specified for compliance or 14 days after the subpoena is served. If an objection is made, the following rules apply:\n\n(i) At any time, on notice to the commanded person, the serving party may move the court for the district where compliance is required for an order compelling production or inspection.\n\n(ii) These acts may be required only as directed in the order, and the order must protect a person who is neither a party nor a party's officer from significant expense resulting from compliance.\n\n#### *(3) Quashing or Modifying a Subpoena.*\n\n*(A) When Required.* On timely motion, the court for the district where compliance is required must quash or modify a subpoena that:\n\n(i) fails to allow a reasonable time to comply;\n\n(ii) requires a person to comply beyond the geographical limits specified in Rule 45(c);\n\n(iii) requires disclosure of privileged or other protected matter, if no exception or waiver applies; or\n\n(iv) subjects a person to undue burden.\n\n*(B) When Permitted.* To protect a person subject to or affected by a subpoena, the court for the district where compliance is required may, on motion, quash or modify the subpoena if it requires:\n\n(i) disclosing a trade secret or other confidential research, development, or commercial information; or\n\n(ii) disclosing an unretained expert's opinion or information that does not describe specific occurrences in dispute and results from the expert's study that was not requested by a party.\n\n(C) *Specifying Conditions as an Alternative.* In the circumstances described in Rule 45(d)(3)(B), the court may, instead of quashing or modifying a subpoena, order appearance or production under specified conditions if the serving party:\n\n(i) shows a substantial need for the testimony or material that cannot be otherwise met without undue hardship; and\n\n(ii) ensures that the subpoenaed person will be reasonably compensated.\n\n#### **(e) Duties in Responding to a Subpoena.**\n\n*(1) Producing Documents or Electronically Stored Information.* These procedures apply to producing documents or electronically stored information:\n\n*(A) Documents.* A person responding to a subpoena to produce documents must produce them as they are kept in the ordinary course of business or must organize and label them to correspond to the categories in the demand.\n\n*(B) Form for Producing Electronically Stored Information Not Specified.* If a subpoena does not specify a form for producing electronically stored information, the person responding must produce it in a form or forms in which it is ordinarily maintained or in a reasonably usable form or forms.\n\n*(C) Electronically Stored Information Produced in Only One Form.* The person responding need not produce the same electronically stored information in more than one form.\n\n*(D) Inaccessible Electronically Stored Information.* The person responding need not provide discovery of electronically stored information from sources that the person identifies as not reasonably accessible because of undue burden or cost. On motion to compel discovery or for a protective order, the person responding must show that the information is not reasonably accessible because of undue burden or cost. If that showing is made, the court may nonetheless order discovery from such sources if the requesting party shows good cause, considering the limitations of Rule 26(b)(2)(C). The court may specify conditions for the discovery.\n\n#### *(2) Claiming Privilege or Protection.*\n\n*(A) Information Withheld.* A person withholding subpoenaed information under a claim that it is privileged or subject to protection as trial-preparation material must: (i) expressly make the claim; and\n\n(ii) describe the nature of the withheld documents, communications, or tangible things in a manner that, without revealing information itself privileged or protected, will enable the parties to assess the claim.\n\n*(B) Information Produced.* If information produced in response to a subpoena is subject to a claim of privilege or of protection as trial-preparation material, the person making the claim may notify any party that received the information of the claim and the basis for it. After being notified, a party must promptly return, sequester, or destroy the specified information and any copies it has; must not use or disclose the information until the claim is resolved; must take reasonable steps to retrieve the information if the party disclosed it before being notified; and may promptly present the information under seal to the court for the district where compliance is required for a determination of the claim. The person who produced the information must preserve the information until the claim is resolved.\n\n**(g) Contempt.** The court for the district where compliance is required – and also, after a motion is transferred, the issuing court – may hold in contempt a person who, having been served, fails without adequate excuse to obey the subpoena or an order related to it.\n\nFor access to subpoena materials, see Fed.R.Civ.P.45(a) Committee Note (2013)\n\n…\n\n## **Requests for Production of Documents**\n\n## **I. INSTRUCTIONS**\n\n1. Unless otherwise indicated, the requests for documents set forth below, (the \"Requests,\" and each, a \"Request\"), must be responded to separately and specifically. Each Request shall be answered fully unless it is in good faith objected to, in which event the reason for Your objection shall be stated in detail, as set forth below. If an objection pertains only to a portion of a Request, or a word, phrase or clause contained within it, You are required to state Your objection to that portion only and to respond to the remainder of the Requests.\n\n2. Electronically stored information must be produced in accordance with the\n\nfollowing instructions:\n\n- a. Images. Black and white images must be 300 DPI Group IV single-page TIFF files. Color images must be produced in JPEG format. File names cannot contain embedded spaces or special characters (including the comma). Folder names cannot contain embedded spaces or special characters (including the comma). All TIFF image files must have a unique file name, i.e. Bates number. Images must be endorsed with sequential Bates numbers in the lower right corner of each image. The number of TIFF files per folder should not exceed 1000 files. Excel spreadsheets should have a placeholder image named by the Bates number of the file.\n- b. Image Load File\n\t- a. Concordance® Data File. The data file (.DAT) contains all of the fielded information that will be loaded into the Concordance® database. The first line of the .DAT file must be a header row identifying the field names. The .DAT file must use the following Concordance® default delimiters: Comma ASCII character (020) Quote þ ASCII character (254). Date fields should be provided in the format: mm/dd/yyyy. Date and time fields must be two separate fields. If documents includes imaged emails and attachments, the attachment fields must be included to preserve the parent/child relationship between an email and its attachments. An OCRPATH field must be included to provide the file path and name of the extracted text file on the produced storage media. The text file must be named after the FIRSTBATES. Do not include the text in the .DAT file. For Documents with native files, a LINK field must be included to provide the file path and\n\nname of the native file. The native file must be named after the FIRSTBATES.\n\n- b. Concordance Image® OR Opticon Cross-Reference File. The image crossreference file (.LOG or .OPT) links the images to the database records. It should be a comma-delimited file consisting of seven fields per line with a line in the cross-reference file for every image in the database with the following format: ImageID,VolumeLabel,ImageFilePath,DocumentBreak,FolderBreak,Box Break,PageCoun.\n- c. Document Text. Text must be produced as separate text files, not as fields within the .DAT file. The full path to the text file (OCRPATH) should be included in the .DAT file. It is recommended document level ANSI text files, named per the FIRSTBATES/Image Key. Extracted text files must be in a separate folder, and the number of text files per folder should not exceed 1,000 files. There should be no special characters (including commas in the folder names). Text files must be provided on a document level.\n- d. Native Production for Certain File Types. File types that reasonably require viewing in their native format for a full understanding of their content and meaning must be produced in native format. These include, but are not limited to, spreadsheets, spreadsheet-like files (Microsoft Excel, comma separated values, tab separated values, etc.), Microsoft PowerPoint or other special presentation files, database files, and audio/visual files. Provide an image of a Bates numbered slip sheet indicating the presence of a native file, and include the path to the native as a field in the .dat file. Name the produced native file with the Bates number corresponding to the slip sheet for the file. Group native files within incrementally named \"NATIVE\" directories, separate from images directories.\n- e. De-duplication. Produce a single copy of each electronic document for which exact duplicates exist. For email messages, consolidate duplicates based on MD5 hash generated from the BCC, Body, CC, From, IntMsgID, To, and Attach properties. For email attachments and standalone electronic files, consolidate duplicates based on MD5 hash of the entire file.\n- f. Metadata. Produce extracted metadata for each document in the form of a Concordance compliant load file (.dat). The first line of the .DAT file must be a header row identifying the field names. The .DAT file must use the following Concordance default delimiters: Comma , ASCII character (020) Quote þ ASCII character (254)\n\nDate fields should be provided in the format: mm/dd/yyyy. Date and time fields must be two separate fields. Required metadata listed below:\n\n# Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 378 of 1063\n\n| Field Name   | Sample Data              | Description                                      |\n|--------------|--------------------------|--------------------------------------------------|\n| FIRSTBATES   | EDC0000001               | First Bates number of native file document/email |\n| LASTBATES    | EDC0000001               | Last Bates number of native file document/email  |\n|              |                          | **The LASTBATES field should be populated        |\n|              |                          | for single page                                  |\n| ATTACHRANGE  | EDC0000001<br>-          | Bates number of the first page of the parent     |\n|              | EDC0000015               | document to the Bates number of the last page of |\n|              |                          | the last attachment \"child\" document             |\n| BEGATTACH    | EDC0000001               | First Bates number of attachment range           |\n| ENDATTACH    | EDC0000015               | Last Bates number of attachment range            |\n| CUSTODIAN    | Smith, John              | Email: Mailbox where the email resided           |\n|              |                          | Native: Name of the individual or department     |\n|              |                          | from whose files the document<br>originated      |\n| FROM         | John Smith               | Email: Sender                                    |\n|              |                          | Native: Author(s) of document                    |\n|              |                          | **semi-colon should be used to separate          |\n|              |                          | multiple entries                                 |\n| TO           | Coffman, Janice; LeeW    | Recipient(s)                                     |\n|              | [mailto:LeeW@MSN.com]    | **semi-colon should be used to separate multiple |\n|              |                          | entries                                          |\n| CC           | Frank Thompson [mailto:  | Carbon copy recipient(s)                         |\n|              | frank_Thompson@cdt.com]  | **semi-colon should be used to separate          |\n|              |                          | multiple entries                                 |\n| BCC          | John Cain                | Blind carbon copy recipient(s)                   |\n|              |                          | **semi-colon should be used to separate          |\n|              |                          | multiple entries                                 |\n| SUBJECT      | Board Meeting Minutes    | Email: Subject line of the email Native: Title   |\n|              |                          | of document (if available)                       |\n| FILE_NAME    | BoardMeetingMinutes.docx | Native: Name of the original native file,        |\n|              |                          | including extension                              |\n| DATE_SENT    | 10/12/2010               | Email: Date the email was sent                   |\n|              |                          | Native: (empty)                                  |\n| TIME_SENT/   | 07:05 PM GMT             | Email: Time the email was sent/ Time zone in     |\n| TIME_ZONE    |                          | which the emails were standardized               |\n| TIME_ZONE    | GMT                      | The<br>time zone in which<br>the emails<br>were  |\n|              |                          | standardized during conversion.                  |\n| LINK         |  EDC0000001.msg   | Hyperlink to the email or native file document   |\n|              |                          | **The linked file must be named per the          |\n|              |                          | FIRSTBATES number                                |\n| FILE_EXTEN   | MSG                      | The file type extension                          |\n|              |                          | representing                                     |\n|              |                          | the Email or                                     |\n| AUTHOR       | John Smith               | Email: (empty)                                   |\n|              |                          | Native: Author of the document                   |\n| DATE_CREATED | 10/10/2010               | Email: (empty)                                   |\n|              |                          | Native: Date the document was created            |\n|              |                          |                                                  |\n\n# Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 379 of 1063\n\n| TIME_CREATED | 10:25 AM                  | Email: (empty)                                  |\n|--------------|---------------------------|-------------------------------------------------|\n|              |                           | Native: Time the document was created           |\n|              |                           | **This data must be a separate field and cannot |\n|              |                           | be combined with the DATE_CREATED field         |\n| DATE_MOD     | 10/12/2010                | Email: (empty)                                  |\n|              |                           | Native: Date the document was last modified     |\n| TIME_MOD     | 07:00 PM                  | Email: (empty)                                  |\n|              |                           | Native: Time the document was last modified     |\n|              |                           | **This data must be a separate field and cannot |\n|              |                           | be combined with the DATE_MOD field             |\n| DATE_ACCESSD | 10/12/2010                | Email: (empty)                                  |\n|              |                           | Native: Date the document was last accessed     |\n| TIME_ACCESSD | 07:00 PM                  | Email: (empty)                                  |\n|              |                           | Native: Time the document was last accessed     |\n|              |                           | **This data must be a separate field and cannot |\n|              |                           | be combined with the DATE_ACCESSD field         |\n| FILE_SIZE    | 5,952                     | Size of native file<br>document/email in KB     |\n| PGCOUNT      | 1                         | Number of pages in native file document/email   |\n| PATH         |   | Email: (empty)                                  |\n|              | Agenda.doc                | Native: Path where native file document was     |\n|              |                           | stored including original file name.            |\n| INTFILEPATH  | Personal Folders\\Deleted  | Email: original location of email including     |\n|              | Items\\Board Meeting       | original file name.                             |\n|              | Minutes.msg               | Native: (empty)                                 |\n| INTMSGID     | <000805c2c71b\\$75977050\\$ | Email: Unique Message ID Native: (empty)        |\n|              | cb8306d1@MSN>             |                                                 |\n| MD5HASH      | d131dd02c5e6eec4693d9a0   | MD5 Hash value of the document.                 |\n|              | 698aff95c                 |                                                 |\n|              | 2fcab58712467eab4004583e  |                                                 |\n|              | b8fb7f89                  |                                                 |\n| OCRPATH      | TEXT/001/EDC0000001.txt   | Path to extracted text of the native file       |\n\n3. Each Request operates and should be construed independently and, unless otherwise indicated, no Request limits the scope of any other Request.\n\n4. All Documents are to be produced as kept in the usual course of business or are to be organized and labeled to correspond with the categories in these Requests.\n\n5. Each Request contained herein extends to all Documents: (a) in Your possession, custody, or control; or (b) in the possession, custody, or control of anyone acting on Your behalf,\n\n#### Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 380 of 1063\n\nincluding Your counsel or other representatives and advisors. Each Document shall be produced in its entirety.\n\n6. If You are requested to produce a Document that is no longer in Your possession, custody, or control, then Your response must (a) describe in detail the nature of the document and its contents; (b) identify the person(s) who prepared or authored the Document (and, if applicable, the Person(s) to whom the Document was sent); (c) identify the date on which the document was prepared or created; (d) state whether such Document (i) is missing or lost, (ii) has been destroyed, (iii) has been transferred, voluntarily or involuntarily, to others, or (iv) was otherwise disposed of; (e) state the reason for, and the facts and circumstances surrounding, such disposition; (f) identify the Persons who authorized such disposition; (g) identify the date or approximate date of such disposition; (h) state when the Document was most recently in Your possession, custody or control; and (i) identify the Person, if any, presently in possession, custody, or control of such Document.\n\n7. If You are requested to produce a Document that has been destroyed, then Your response must state, in addition to the information required by the preceding Instruction: (a) the reason for the Document's destruction; (b) the identity of the Person who destroyed the Document; and (c) the identity of the Person who directed that the Document be destroyed.\n\n8. If You claim that a requested Document is privileged or attorney work-product, then Your response must: (a) state (i) a description of the Document adequate to support Your contention that the Document is privileged, (ii) the title of the Document, (iii) the date of the Document, (iv) the author of the Document, (v) the addressee of the Document, (vi) the identity of each Person who received or saw the original or any draft, copy, or reproduction of the Document, (vii) whether the Document itself, or any information contained or referred to in the Document is in the possession, custody, or control of any other Persons, and if so, the identity of\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 381 of 1063\n\nsuch Persons, as well as a statement addressing how the information came into their possession, (viii) the claim of privilege under which the Document is withheld, and (ix) all of the circumstances upon which You will rely to support such claim of privilege; and (b) produce a privilege log containing all of the information requested in Part (a) of this Instruction for each Document withheld on the basis of a claim of privilege in accordance with D. Conn. L. Civ. R. 26(e).\n\n9. If a portion of an otherwise responsive Document contains information subject to a claim of privilege, only that portion of the Document subject to the claim of privilege shall be deleted or redacted from the Document following the instructions above, and the rest shall be produced.\n\n10. The Requests are continuing in nature. You are hereby instructed to (a) supplement or correct any responses later learned to be incomplete or incorrect immediately upon learning that a prior response was incomplete or incorrect; and (b) produce any additional Documents that are called for under the\n\n11. If a Document is in a language other than English, You should provide that Document. If a Document is in a language other than English, and an English translation exists, You should provide both Documents.\n\n12. All references to Entities includes all affiliates thereof.\n\n13. All references to individual names include all alternative names, aliased, or nicknames.\n\n14. Unless otherwise expressly indicated, the period of time covered by the Document Requests is the period from February 5, 2012 to the date responses to the Document Requests are due.\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 382 of 1063\n\n#### **II. RULES OF CONSTRUCTION**\n\n15. The use of (a) any singular noun shall be construed to include the plural, and vice versa, and (b) a verb in any tense shall be construed as the use of the verb in all other tenses.\n\n16. The terms (a) \"and\" and \"or\" shall be construed either conjunctively or disjunctively as necessary to bring within the scope of any request all responses that might otherwise be construed to be outside of its scope, and (b) \"each\" and \"any\" shall be deemed to include and encompass the words \"every\" and \"all.\"\n\n#### **III. DEFINITIONS**\n\nThe definitions supplied by D. Conn. L. Civ. R. 26(c) and the rules of construction supplied by D. Conn. L. Civ. R. 26(d), as incorporated by D. Conn. Bankr. L.R. 2004-1(a), shall apply to the Document Requests. In addition, the following terms used in these Document Requests shall have the following meanings:\n\n1. \"You\" or \"Your\" or \"Yourself\" means and refers to Hamilton M&A Fund SP, together with all of its affiliates, divisions, agencies, instrumentalities, departments, offices, partners, officers, directors, agents, attorneys, representatives, employees, and/or anyone acting on its behalf.\n\n2. \"Debtor\" means Ho Wan Kwok (a/k/a Miles Kwok, Miles Guo, Guo Wengui, Guo Haoyun, 郭文贵, or any other alias), together with his employees, agents, counsel, advisors, or anyone acting on his behalf.\n\n3. \"Debtor's Son\" means Qiang Guo (a/k/a Mileson Kwok, 郭强, or any other alias), together with his employees, agents, counsel, advisors, or anyone acting on his behalf.\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 383 of 1063\n\n4. \"Debtor's Daughter\" means Mei Guo (a/k/a Mei Gui, 郭美, or any other alias), together with her employees, agents, counsel, advisors, or anyone acting on her behalf.\n\n5. \"Debtor's Purported Wife\" means Hing Chi Ngok (a/k/a Hing Chi Ng, Yue Qingzhi, 岳庆芝, or any other alias), together with her employees, agents, counsel, advisors, or anyone acting on her behalf.\n\n6. \"Debtor's Family\" means, collectively, the Debtor, the Debtor's Son, the Debtor's Daughter, and the Debtor's Purported Wife, and any other familial relation to the Debtor.\n\n7. \"Associated Individuals\" means, individually and collectively, all individuals that (1) hold, control, have custody over, or discretion over assets owned, controlled, or enjoyed by the Debtor or the Debtor's Family; or (2) have been employees, directors, or otherwise are affiliated with one or more Associated Entities, together with the respective employees, agents, counsel, advisors, or anyone acting on behalf of any of the foregoing. Such Associated Individuals shall include, but are not limited to: Daniel Podhaskie, Jason Miller, Steve Bannon, Karin Maistrello, Melissa Francis, Anthony DiBattista, William Gertz, Arethusa Forsyth, Glenn Mellor, Jennifer Mercurio, Eduardo Eurnekian, Wencong Wang, Han Chunguang (a/k/a 韩春光), Qu Guojiao (a/k/a Qu Guo Jiao, 屈国姣), Guo Lijie (a/k/a 郭丽杰), Zhang Wei (a/k/a 张伟\\*), Lihong Wei Lafrenz (a/k/a Sara Wei, 魏丽红), Hao Haidong (a/k/a 郝海东), Ross Heinemeyer, Max Krasner, Kyle Bass, Melissa Mendez, Ya Li (a/k/a 李娅), Dinggang Wang (a/k/a 王定刚), An Hong (a/k/a 安红), Yvette Wang (a/k/a Yanping Wang, Yan Ping Wang, 王雁平), Fiona Yu, Je Kin Ming (a/k/a William Je, Yu Jianming, 余建明), Yaz Qingua, and Lao Jiang (a/k/a Jiang Yunfu, Jiang Yunfu Be, 姜云浮).\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 384 of 1063\n\n8. \"Associated Entities\" means, individually and collectively, all organizations or Entities of any type that (1) have been owned, controlled, or invested in by the Debtor or the Debtor's Family; or (2) have an interest, whether directly or indirectly, in any assets owned, controlled, or enjoyed by the Debtor or the Debtor's Family, together with the respective employees, agents, counsel, advisors, or anyone acting on behalf of any of the foregoing. Such Associated Entities shall include, but are not limited to: 7 Nod Hill LLC, AAGV Limited, ACA Investment Management Limited, ACA Capital Group Limited, Ace Decade Holdings Limited, AI Group Holdings Inc., Alfa Global Ventures Limited, Alfonso Global Limited, Allied Capital Global Limited, Alpine Fiduciaries SA, Anton Development Limited, Assets Sino Limited, Auspicious Coast Limited, Beijing Pangu Investment Co., Beijing Pangu Investment Co. Ltd., Beijing Pangu Investment Inc., Beijing Zenith Holdings Company Limited, Booming Sail New York LLC, Bravo Luck Limited, BSA Strategic Fund I, China Golden Spring (Hong Kong) Limited, Chuang Xin Limited, Crane Advisory Group LLC, Creative Apex Investments Limited, Crystal Breeze Investments Limited, Dawn State Limited, Eastern Profit Corporation Limited, Elite Well Global Limited, Empire Growth Holdings, Freedom Media Ventures Ltd., G Club Operations LLC, G Fashion LLC, G News LLC, GETTR USA, Genever Holdings Corporation, Genever Holdings LLC, Gfashion Media Group Inc., GFNY, Inc., Globalist International Limited, GNews Media Group Inc., Golden Spring (New York) Ltd., Greenwich Land LLC, Guo Media, GTV Media Group, Inc., Hamilton Capital Holdings Inc., HCHK Property Management, Inc., HCHK Technologies, Inc., Head Win Group Limited, Henan Yuda, Himalaya Embassy, Himalaya Exchange, Himalaya Federal Reserve, Himalaya Investment LLC, Himalaya International, Himalaya New World Inc., Himalaya Supervisory Organization, Himalaya Ventures LLC, HK International Funds Investments (USA) Limited LLC, Hong Kong International Funds\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 385 of 1063\n\nInvestments Limited, Hudson Diamond Holding, Infinite Increase Limited, Infinitum Developments Limited, Infinity Treasury Management Inc., Insight Phoenix Fund, Lamp Capital LLC, Leading Shine Limited, Leading Shine NY Limited, Lexington Property and Staffing, Long Gate Limited, Maywind Trading LLC, MOS Himalaya LLC, Next Tycoon Investments Limited, New Federal State of China (a/k/a NFSC), Noble Fame Global Limited, Rosy Acme Ventures Limited, Rule of Law Foundation III, Inc., Rule of Law Foundation IV, Inc., Rule of Law Fund, Rule of Law Society, Rule of Law Society IV, Inc., G-Translators PTY LTD, Saraca Media Group, Inc., Shiny Ace Ltd., Shiny Times Holdings Ltd., Spirit Charter Investment Limited, Stevenson, Wong & Co., Voice of Guo Media, Inc., Well Origin Ltd., World Century Limited, Worldwide Opportunity Holdings Limited, Whitecroft Shore Limited, and ZIBA Limited.\n\n9. \"Including\" or any variant thereof means \"including without limitation.\"\n\n10. \"And\" and \"or\" mean \"and/or,\" and shall be construed both conjunctively as well as disjunctively in order to maximize their scope.\n\n11. \"Any\" and \"all\" and \"each\" mean \"each and every.\"\n\n12. \"Each\" and \"every\" mean \"each and every.\"\n\n13. \"Third Party\" means a Person or Entity other than Yourself.\n\n14. \"Transfer\" shall have the meaning given to it by section 101(54) of the Bankruptcy Code.\n\n15. \"Document\" means any information or thing within the scope of Fed. R. Civ. P. 34, and includes, without limitation, each and every written, recorded, or graphic matter of any kind, type, nature, or description that is or has been in Your Possession, Custody or Control, including all printed and electronic copies of electronic mail, computer files maintained in\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 386 of 1063\n\nelectronic form, electronic communication, text message, social media post, tweet, meta-data, correspondence, memoranda, tapes, stenographic or handwritten notes, written forms of any kind, charts, blueprints, drawings, sketches, graphs, plans, articles, specifications, diaries, letters, telegrams, photographs, minutes, contracts, agreements, surveys, computer printouts, data compilations of any kind, telexes, facsimiles, voice messages, invoices, order forms, checks, drafts, statements, credit memos, reports, position reports, summaries, indices, books, ledgers, notebooks, schedules, transparencies, recordings, catalogs, advertisements, promotional materials, films, video tapes, audio tapes, CDs, computer disks, brochures, pamphlets, punchcards, time-slips, Tweets, social media posts, or any written or recorded materials of any other kind, and all meta-data thereof, however stored (whether in tangible or electronic form), recorded, produced, or reproduced, and also including but not limited to, drafts or copies of any of the foregoing that contain any notes, comments, or markings of any kind not found on the original documents or that are otherwise not identical to the original documents.\n\n16. \"Person(s)\" means an individual, corporation, proprietorship, partnership, association, or any other Entity. \"Person\" also includes any agent, representatives, or expert, including but not limiting to, attorneys or financial advisors.\n\n17. \"Entity\" means any natural Person, corporation, partnership, subsidiary, sole proprietorship, firm, board, joint venture, association, agency, authority, commission or other business entity or juristic Person, as well as any affiliate, agent, parent including but not limited to legal counsel, financial advisors, or any other representative.\n\n18. \"Regarding\" means concerning, describing, comprising, referring to, related to, supporting, favoring, opposing, bolstering, detracting from, located in, considered in connection with, bearing on, evidencing, indicating, reporting on, recording, alluding to, responding to,\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 387 of 1063\n\nconnected with, commenting on, in respect of, about, in relation to, discussing, showing, describing, reflecting, analyzing constituting, and being.\n\n19. \"Relating to,\" \"relate(s) to\" or \"related to,\" when referring to any given subject matter, means, without limitation, any document that constitutes, comprises, involves, contains, embodies, reflects, identifies, states, refers directly or indirectly to, or is in any way relevant to the particular subject matter identified.\n\n20. \"Communication(s)\" means, in the broadest possible sense, and without limitation, any transmittal of information or knowledge (in the form of facts, ideas, inquiries, or otherwise). Communication(s) further refers to all conversations, agreements, inquiries, or replies, whether in person, by telephone, in writing, or by means of electronic transmittal devices, and includes, but is not limited to, all correspondence, emails, recordings, transmittal slips, memoranda, telephone communications, voice messages, telegrams, telefaxes, telecopies, telexes, instant messages, chats, text messages, telephonic notes, or notes transmitted internally or with third parties.\n\n21. \"Asset(s)\" means any item that can be used to produce positive economic value, including but not limited to any resource with economic value that is owned, controlled or is for the benefit of an entity, that is expected to provide a future benefit, including but not limited to, all real and personal property, intangible property, investments, rights to invest or to future revenue, cash, bank accounts, commodities, securities, claims, total or partial control of an entity, and prospective economic opportunities\n\n22. \"Transfer\" shall have the meaning given to it by section 101(54) of the Bankruptcy Code.\n\n#### **IV. DOCUMENTS TO BE PRODUCED**\n\n1. All Documents regarding any income or Asset of the Debtor, the Debtor's estate, or an Associated Entity.\n\n2. All Documents related to the Debtor's financial condition and obligations to his creditors, including without limitation all Documents related to any effort to avoid paying such obligations and All Documents related to this or any other actual or potential bankruptcy or similar insolvency proceeding.\n\n3. All Documents regarding any balance sheet, bank statement, account statement, financial statement, statement of account, wire transfer instructions and/or confirmation, proof of funds, certificate of deposit, certificate of holdings, investment portfolio summary, or similar document relating to the Debtor, the Debtor's Estate, the Debtor's Family, an Associated Entity, or an Associated Individual, including without limitation all Documents sufficient to show all Transfers to any of the foregoing.\n\n4. All Documents regarding any investment, business dealing or transactions made by, with, or on behalf of the Debtor.\n\n5. All Communications with the Debtor, and Documents related to Communications with the Debtor, related to the operation, management, or decision-making of any Entity, including without limitation the Associated Entities.\n\n6. All Documents regarding any Transfer, investment, or other transaction or business dealing made to, by, or with the Debtor, the Debtor's Family, or an Associated Entity.\n\n7. All Documents regarding any property ever occupied or used by the Debtor, including without limitation the *Lady May*; the Sherry Netherland Hotel / Condominium; the\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 389 of 1063\n\nresidential property located in Greenwich, Connecticut at 373 Taconic Rd.; the residential property located in Greenwich, Connecticut at 33 Ferncliff Rd.; and the residential property located in Wilton, Connecticut at 354 Nod Hill Rd.\n\n8. All Documents related to any aircraft owned, controlled, or used by the Debtor, including without limitation the aircraft bearing tail number T7-GQM and any other aircraft registered in San Marino, including without limitation copies of all registration documents and flight manifests showing flights taken by such aircraft and the individuals onboard such flights.\n\n9. All Documents regarding any gifts, benefits or loans, to, from or on behalf of the Debtor, the Debtor's Estate, the Debtor's Family, or the Associated Entities, including without limitation Documents sufficient to show the amounts of such gifts, benefits, or loans; the purposes for which such gifts, benefits, or loans were used; when the gifts, benefits, or loans were provided; and the terms of any loans, all representations and warranties made in connection with any loans, the interest rate on any loans, and all evidence of payments of any loans.\n\n10. All Documents concerning any trust or similar instrument set up by, on behalf of, or for the benefit of the Debtor, the Debtor's Estate, the Debtor's Family, or an Associated Entity, including without limitation Documents sufficient to show when the trust(s) was created, by whom it was created, for whose benefit it was created, and the corpus of the trust.\n\n11. All Documents related to any obligation, claim, liability, or debt associated with any legal dispute involving the Debtor, including but not limited to those relating to any litigation before any local, state, federal, or international body, whether an administrative body, court, panel, or alternative dispute resolution entity.\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 390 of 1063\n\n12. All Documents and communications between any of your outside counsel or other advisors and the Debtor.\n\n13. Documents sufficient to show all of Your Assets and sources of income or funding.\n\n14. For all Assets identified in response to Request 14 having a value of more than \\$50,000, all (i) Documents related to Your acquisition of such Asset and (ii) Communications with the Debtor or the Debtor's Family regarding such Asset.\n\n15. Copies of Your tax returns.\n\n16. Documents sufficient to show all bank accounts and investment accounts within Your possession or control, including the balances of and transfers to and from each such account.\n\n17. All Documents regarding any credit cards used by You, including without limitation monthly statements or other Documents sufficient to show all purchases related thereto for the benefit of the Debtor or an Associated Entity.\n\n18. All corporate governance and organizational Documents, including without limitation by-laws and certificates of incorporation and other Documents sufficient to show Your corporate structure, names of officers and directors, business purpose, and relationship to the Debtor or to any member of the Debtor's Family.\n\n19. All Documents related to any pledge(s) of Your Assets to any other Entity.\n\nCase 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 391 of 1063\n\n# Exhibit C-21\n\n#### B2540 (Form 2540 – Subpoena for Rule 2004 Examination) (12/15) Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 392 of\n\nUNITED STATES BANKRUPTCY COURT 1063\n\n**District of Connecticut**\n\nIn re HO WAN KWOK, *et al*.,\n\n<sup>1</sup> Case No. 22-50073 (JAM)\n\nDebtor Chapter 11\n\n(Jointly Administered)\n\n## **SUBPOENA FOR RULE 2004 EXAMINATION**\n\nTo: **Hamilton M&A Fund SP**\n\n(*Name of person to whom the subpoena is directed*)\n\n*Testimony:* **YOU ARE COMMANDED** to appear at the time, date, and place set forth below to testify at an examination under Rule 2004, Federal Rules of Bankruptcy Procedure. A copy of the court order authorizing the examination is attached.\n\n| PLACE                    | DATE AND TIME |\n|--------------------------|---------------|\n| Paul Hastings LLP        |               |\n| 200 Park Avenue          | [TBD]         |\n| New York, New York 10166 |               |\n|                          |               |\n\nThe examination will be recorded by this method: **Court reporter/stenographer**\n\n*Production:* You, or your representatives, must also bring with you to the examination the following documents, electronically stored information, or objects, and must permit inspection, copying, testing, or sampling of the material:\n\n#### **See Requests for Production of Documents, attached hereto.**\n\nThe following provisions of Fed. R. Civ. P. 45, made applicable in bankruptcy cases by Fed. R. Bankr. P. 9016, are attached – Rule 45(c), relating to the place of compliance; Rule 45(d), relating to your protection as a person subject to a subpoena; and Rule 45(e) and 45(g), relating to your duty to respond to this subpoena and the potential consequences of not doing so.\n\nDate: **March , 2023**\n\nCLERK OF COURT\n\nOR\n\n*Signature of Clerk or Deputy Clerk Attorney's signature*\n\nThe name, address, email address, and telephone number of the attorney representing Luc A. Despins, Chapter 11 Trustee, who issues or requests this subpoena, are:\n\n**Douglas S. Skalka, Esq.; Neubert, Pepe & Monteith, P.C.; 195 Church Street, New Haven, Connecticut 06510 dskalka@npmlaw.com; (203) 821-2000**\n\n**Notice to the person who issues or requests this subpoena**\n\nIf this subpoena commands the production of documents, electronically stored information, or tangible things, or the inspection of premises before trial, a notice and a copy of this subpoena must be served on each party before it is served on the person to whom it is directed. Fed. R. Civ. P. 45(a)(4).\n\nSoftware Copyright (c) 1996-2022 Best Case, LLC - www.bestcase.com Best Case Bankruptcy 1 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\n#### **PROOF OF SERVICE**\n\n**(This section should not be filed with the court unless required by Fed. R. Civ. P. 45.)**\n\nI received this subpoena for (*name of individual and title, if any*): on (*date*) .\n\nI served the subpoena by delivering a copy to the named person as follows:\n\non *(date)* ; or\n\nI returned the subpoena unexecuted because:\n\nUnless the subpoena was issued on behalf of the United States, or one of its officers or agents, I have also tendered to the witness the fees for one day's attendance, and the mileage allowed by law, in the amount of \\$ .\n\nMy fees are \\$ for travel and \\$ for services, for a total of \\$ .\n\nI declare under penalty of perjury that this information is true and correct.\n\nDate:\n\n*Server's signature*\n\n*Printed name and title*\n\n*Server's address*\n\nAdditional information concerning attempted service, etc.:\n\n#### **Federal Rule of Civil Procedure 45(c), (d), (e), and (g) (Effective 12/1/13) (made applicable in bankruptcy cases by Rule 9016, Federal Rules of Bankruptcy Procedure)**\n\n#### **(c) Place of compliance.**\n\n*(1) For a Trial, Hearing, or Deposition.* A subpoena may command a person to attend a trial, hearing, or deposition only as follows:\n\n(A) within 100 miles of where the person resides, is employed, or regularly transacts business in person; or\n\n(B) within the state where the person resides, is employed, or regularly transacts business in person, if the person\n\n(i) is a party or a party's officer; or\n\n(ii) is commanded to attend a trial and would not incur substantial expense.\n\n*(2) For Other Discovery.* A subpoena may command:\n\n(A) production of documents, or electronically stored information, or things at a place within 100 miles of where the person resides, is employed, or regularly transacts business in person; and\n\n(B) inspection of premises, at the premises to be inspected.\n\n#### **(d) Protecting a Person Subject to a Subpoena; Enforcement.**\n\n*(1) Avoiding Undue Burden or Expense; Sanctions.* A party or attorney responsible for issuing and serving a subpoena must take reasonable steps to avoid imposing undue burden or expense on a person subject to the subpoena. The court for the district where compliance is required must enforce this duty and impose an appropriate sanction which may include lost earnings and reasonable attorney's fees — on a party or attorney who fails to comply.\n\n#### *(2) Command to Produce Materials or Permit Inspection.*\n\n*(A) Appearance Not Required.* A person commanded to produce documents, electronically stored information, or tangible things, or to permit the inspection of premises, need not appear in person at the place of production or inspection unless also commanded to appear for a deposition, hearing, or trial.\n\n*(B) Objections.* A person commanded to produce documents or tangible things or to permit inspection may serve on the party or attorney designated in the subpoena a written objection to inspecting, copying, testing or sampling any or all of the materials or to inspecting the premises — or to producing electronically stored information in the form or forms requested. The objection must be served before the earlier of the time specified for compliance or 14 days after the subpoena is served. If an objection is made, the following rules apply:\n\n(i) At any time, on notice to the commanded person, the serving party may move the court for the district where compliance is required for an order compelling production or inspection.\n\n(ii) These acts may be required only as directed in the order, and the order must protect a person who is neither a party nor a party's officer from significant expense resulting from compliance.\n\n#### *(3) Quashing or Modifying a Subpoena.*\n\n*(A) When Required.* On timely motion, the court for the district where compliance is required must quash or modify a subpoena that:\n\n(i) fails to allow a reasonable time to comply;\n\n(ii) requires a person to comply beyond the geographical limits specified in Rule 45(c);\n\n(iii) requires disclosure of privileged or other protected matter, if no exception or waiver applies; or\n\n(iv) subjects a person to undue burden.\n\n*(B) When Permitted.* To protect a person subject to or affected by a subpoena, the court for the district where compliance is required may, on motion, quash or modify the subpoena if it requires:\n\n(i) disclosing a trade secret or other confidential research, development, or commercial information; or\n\n(ii) disclosing an unretained expert's opinion or information that does not describe specific occurrences in dispute and results from the expert's study that was not requested by a party.\n\n(C) *Specifying Conditions as an Alternative.* In the circumstances described in Rule 45(d)(3)(B), the court may, instead of quashing or modifying a subpoena, order appearance or production under specified conditions if the serving party:\n\n(i) shows a substantial need for the testimony or material that cannot be otherwise met without undue hardship; and\n\n(ii) ensures that the subpoenaed person will be reasonably compensated.\n\n#### **(e) Duties in Responding to a Subpoena.**\n\n*(1) Producing Documents or Electronically Stored Information.* These procedures apply to producing documents or electronically stored information:\n\n*(A) Documents.* A person responding to a subpoena to produce documents must produce them as they are kept in the ordinary course of business or must organize and label them to correspond to the categories in the demand.\n\n*(B) Form for Producing Electronically Stored Information Not Specified.* If a subpoena does not specify a form for producing electronically stored information, the person responding must produce it in a form or forms in which it is ordinarily maintained or in a reasonably usable form or forms.\n\n*(C) Electronically Stored Information Produced in Only One Form.* The person responding need not produce the same electronically stored information in more than one form.\n\n*(D) Inaccessible Electronically Stored Information.* The person responding need not provide discovery of electronically stored information from sources that the person identifies as not reasonably accessible because of undue burden or cost. On motion to compel discovery or for a protective order, the person responding must show that the information is not reasonably accessible because of undue burden or cost. If that showing is made, the court may nonetheless order discovery from such sources if the requesting party shows good cause, considering the limitations of Rule 26(b)(2)(C). The court may specify conditions for the discovery.\n\n#### *(2) Claiming Privilege or Protection.*\n\n*(A) Information Withheld.* A person withholding subpoenaed information under a claim that it is privileged or subject to protection as trial-preparation material must: (i) expressly make the claim; and\n\n(ii) describe the nature of the withheld documents, communications, or tangible things in a manner that, without revealing information itself privileged or protected, will enable the parties to assess the claim.\n\n*(B) Information Produced.* If information produced in response to a subpoena is subject to a claim of privilege or of protection as trial-preparation material, the person making the claim may notify any party that received the information of the claim and the basis for it. After being notified, a party must promptly return, sequester, or destroy the specified information and any copies it has; must not use or disclose the information until the claim is resolved; must take reasonable steps to retrieve the information if the party disclosed it before being notified; and may promptly present the information under seal to the court for the district where compliance is required for a determination of the claim. The person who produced the information must preserve the information until the claim is resolved.\n\n**(g) Contempt.** The court for the district where compliance is required – and also, after a motion is transferred, the issuing court – may hold in contempt a person who, having been served, fails without adequate excuse to obey the subpoena or an order related to it.\n\nFor access to subpoena materials, see Fed.R.Civ.P.45(a) Committee Note (2013)\n\n…\n\n## **Requests for Production of Documents**\n\n## **I. INSTRUCTIONS**\n\n1. Unless otherwise indicated, the requests for documents set forth below, (the \"Requests,\" and each, a \"Request\"), must be responded to separately and specifically. Each Request shall be answered fully unless it is in good faith objected to, in which event the reason for Your objection shall be stated in detail, as set forth below. If an objection pertains only to a portion of a Request, or a word, phrase or clause contained within it, You are required to state Your objection to that portion only and to respond to the remainder of the Requests.\n\n2. Electronically stored information must be produced in accordance with the\n\nfollowing instructions:\n\n- a. Images. Black and white images must be 300 DPI Group IV single-page TIFF files. Color images must be produced in JPEG format. File names cannot contain embedded spaces or special characters (including the comma). Folder names cannot contain embedded spaces or special characters (including the comma). All TIFF image files must have a unique file name, i.e. Bates number. Images must be endorsed with sequential Bates numbers in the lower right corner of each image. The number of TIFF files per folder should not exceed 1000 files. Excel spreadsheets should have a placeholder image named by the Bates number of the file.\n- b. Image Load File\n\t- a. Concordance® Data File. The data file (.DAT) contains all of the fielded information that will be loaded into the Concordance® database. The first line of the .DAT file must be a header row identifying the field names. The .DAT file must use the following Concordance® default delimiters: Comma ASCII character (020) Quote þ ASCII character (254). Date fields should be provided in the format: mm/dd/yyyy. Date and time fields must be two separate fields. If documents includes imaged emails and attachments, the attachment fields must be included to preserve the parent/child relationship between an email and its attachments. An OCRPATH field must be included to provide the file path and name of the extracted text file on the produced storage media. The text file must be named after the FIRSTBATES. Do not include the text in the .DAT file. For Documents with native files, a LINK field must be included to provide the file path and\n\nname of the native file. The native file must be named after the FIRSTBATES.\n\n- b. Concordance Image® OR Opticon Cross-Reference File. The image crossreference file (.LOG or .OPT) links the images to the database records. It should be a comma-delimited file consisting of seven fields per line with a line in the cross-reference file for every image in the database with the following format: ImageID,VolumeLabel,ImageFilePath,DocumentBreak,FolderBreak,Box Break,PageCoun.\n- c. Document Text. Text must be produced as separate text files, not as fields within the .DAT file. The full path to the text file (OCRPATH) should be included in the .DAT file. It is recommended document level ANSI text files, named per the FIRSTBATES/Image Key. Extracted text files must be in a separate folder, and the number of text files per folder should not exceed 1,000 files. There should be no special characters (including commas in the folder names). Text files must be provided on a document level.\n- d. Native Production for Certain File Types. File types that reasonably require viewing in their native format for a full understanding of their content and meaning must be produced in native format. These include, but are not limited to, spreadsheets, spreadsheet-like files (Microsoft Excel, comma separated values, tab separated values, etc.), Microsoft PowerPoint or other special presentation files, database files, and audio/visual files. Provide an image of a Bates numbered slip sheet indicating the presence of a native file, and include the path to the native as a field in the .dat file. Name the produced native file with the Bates number corresponding to the slip sheet for the file. Group native files within incrementally named \"NATIVE\" directories, separate from images directories.\n- e. De-duplication. Produce a single copy of each electronic document for which exact duplicates exist. For email messages, consolidate duplicates based on MD5 hash generated from the BCC, Body, CC, From, IntMsgID, To, and Attach properties. For email attachments and standalone electronic files, consolidate duplicates based on MD5 hash of the entire file.\n- f. Metadata. Produce extracted metadata for each document in the form of a Concordance compliant load file (.dat). The first line of the .DAT file must be a header row identifying the field names. The .DAT file must use the following Concordance default delimiters: Comma , ASCII character (020) Quote þ ASCII character (254)\n\nDate fields should be provided in the format: mm/dd/yyyy. Date and time fields must be two separate fields. Required metadata listed below:\n\n# Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 397 of 1063\n\n| Field Name   | Sample Data              | Description                                      |\n|--------------|--------------------------|--------------------------------------------------|\n| FIRSTBATES   | EDC0000001               | First Bates number of native file document/email |\n| LASTBATES    | EDC0000001               | Last Bates number of native file document/email  |\n|              |                          | **The LASTBATES field should be populated        |\n|              |                          | for single page                                  |\n| ATTACHRANGE  | EDC0000001<br>-          | Bates number of the first page of the parent     |\n|              | EDC0000015               | document to the Bates number of the last page of |\n|              |                          | the last attachment \"child\" document             |\n| BEGATTACH    | EDC0000001               | First Bates number of attachment range           |\n| ENDATTACH    | EDC0000015               | Last Bates number of attachment range            |\n| CUSTODIAN    | Smith, John              | Email: Mailbox where the email resided           |\n|              |                          | Native: Name of the individual or department     |\n|              |                          | from whose files the document<br>originated      |\n| FROM         | John Smith               | Email: Sender                                    |\n|              |                          | Native: Author(s) of document                    |\n|              |                          | **semi-colon should be used to separate          |\n|              |                          | multiple entries                                 |\n| TO           | Coffman, Janice; LeeW    | Recipient(s)                                     |\n|              | [mailto:LeeW@MSN.com]    | **semi-colon should be used to separate multiple |\n|              |                          | entries                                          |\n| CC           | Frank Thompson [mailto:  | Carbon copy recipient(s)                         |\n|              | frank_Thompson@cdt.com]  | **semi-colon should be used to separate          |\n|              |                          | multiple entries                                 |\n| BCC          | John Cain                | Blind carbon copy recipient(s)                   |\n|              |                          | **semi-colon should be used to separate          |\n|              |                          | multiple entries                                 |\n| SUBJECT      | Board Meeting Minutes    | Email: Subject line of the email Native: Title   |\n|              |                          | of document (if available)                       |\n| FILE_NAME    | BoardMeetingMinutes.docx | Native: Name of the original native file,        |\n|              |                          | including extension                              |\n| DATE_SENT    | 10/12/2010               | Email: Date the email was sent                   |\n|              |                          | Native: (empty)                                  |\n| TIME_SENT/   | 07:05 PM GMT             | Email: Time the email was sent/ Time zone in     |\n| TIME_ZONE    |                          | which the emails were standardized               |\n| TIME_ZONE    | GMT                      | The<br>time zone in which<br>the emails<br>were  |\n|              |                          | standardized during conversion.                  |\n| LINK         |  EDC0000001.msg   | Hyperlink to the email or native file document   |\n|              |                          | **The linked file must be named per the          |\n|              |                          | FIRSTBATES number                                |\n| FILE_EXTEN   | MSG                      | The file type extension                          |\n|              |                          | representing                                     |\n|              |                          | the Email or                                     |\n| AUTHOR       | John Smith               | Email: (empty)                                   |\n|              |                          | Native: Author of the document                   |\n| DATE_CREATED | 10/10/2010               | Email: (empty)                                   |\n|              |                          | Native: Date the document was created            |\n\n# Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 398 of 1063\n\n| TIME_CREATED | 10:25 AM                  | Email: (empty)                                  |\n|--------------|---------------------------|-------------------------------------------------|\n|              |                           | Native: Time the document was created           |\n|              |                           | **This data must be a separate field and cannot |\n|              |                           | be combined with the DATE_CREATED field         |\n| DATE_MOD     | 10/12/2010                | Email: (empty)                                  |\n|              |                           | Native: Date the document was last modified     |\n| TIME_MOD     | 07:00 PM                  | Email: (empty)                                  |\n|              |                           | Native: Time the document was last modified     |\n|              |                           | **This data must be a separate field and cannot |\n|              |                           | be combined with the DATE_MOD field             |\n| DATE_ACCESSD | 10/12/2010                | Email: (empty)                                  |\n|              |                           | Native: Date the document was last accessed     |\n| TIME_ACCESSD | 07:00 PM                  | Email: (empty)                                  |\n|              |                           | Native: Time the document was last accessed     |\n|              |                           | **This data must be a separate field and cannot |\n|              |                           | be combined with the DATE_ACCESSD field         |\n| FILE_SIZE    | 5,952                     | Size of native file<br>document/email in KB     |\n| PGCOUNT      | 1                         | Number of pages in native file document/email   |\n| PATH         |   | Email: (empty)                                  |\n|              | Agenda.doc                | Native: Path where native file document was     |\n|              |                           | stored including original file name.            |\n| INTFILEPATH  | Personal Folders\\Deleted  | Email: original location of email including     |\n|              | Items\\Board Meeting       | original file name.                             |\n|              | Minutes.msg               | Native: (empty)                                 |\n| INTMSGID     | <000805c2c71b\\$75977050\\$ | Email: Unique Message ID Native: (empty)        |\n|              | cb8306d1@MSN>             |                                                 |\n| MD5HASH      | d131dd02c5e6eec4693d9a0   | MD5 Hash value of the document.                 |\n|              | 698aff95c                 |                                                 |\n|              | 2fcab58712467eab4004583e  |                                                 |\n|              | b8fb7f89                  |                                                 |\n| OCRPATH      | TEXT/001/EDC0000001.txt   | Path to extracted text of the native file       |\n\n3. Each Request operates and should be construed independently and, unless otherwise indicated, no Request limits the scope of any other Request.\n\n4. All Documents are to be produced as kept in the usual course of business or are to be organized and labeled to correspond with the categories in these Requests.\n\n5. Each Request contained herein extends to all Documents: (a) in Your possession, custody, or control; or (b) in the possession, custody, or control of anyone acting on Your behalf,\n\n#### Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 399 of 1063\n\nincluding Your counsel or other representatives and advisors. Each Document shall be produced in its entirety.\n\n6. If You are requested to produce a Document that is no longer in Your possession, custody, or control, then Your response must (a) describe in detail the nature of the document and its contents; (b) identify the person(s) who prepared or authored the Document (and, if applicable, the Person(s) to whom the Document was sent); (c) identify the date on which the document was prepared or created; (d) state whether such Document (i) is missing or lost, (ii) has been destroyed, (iii) has been transferred, voluntarily or involuntarily, to others, or (iv) was otherwise disposed of; (e) state the reason for, and the facts and circumstances surrounding, such disposition; (f) identify the Persons who authorized such disposition; (g) identify the date or approximate date of such disposition; (h) state when the Document was most recently in Your possession, custody or control; and (i) identify the Person, if any, presently in possession, custody, or control of such Document.\n\n7. If You are requested to produce a Document that has been destroyed, then Your response must state, in addition to the information required by the preceding Instruction: (a) the reason for the Document's destruction; (b) the identity of the Person who destroyed the Document; and (c) the identity of the Person who directed that the Document be destroyed.\n\n8. If You claim that a requested Document is privileged or attorney work-product, then Your response must: (a) state (i) a description of the Document adequate to support Your contention that the Document is privileged, (ii) the title of the Document, (iii) the date of the Document, (iv) the author of the Document, (v) the addressee of the Document, (vi) the identity of each Person who received or saw the original or any draft, copy, or reproduction of the Document, (vii) whether the Document itself, or any information contained or referred to in the Document is in the possession, custody, or control of any other Persons, and if so, the identity of\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 400 of 1063\n\nsuch Persons, as well as a statement addressing how the information came into their possession, (viii) the claim of privilege under which the Document is withheld, and (ix) all of the circumstances upon which You will rely to support such claim of privilege; and (b) produce a privilege log containing all of the information requested in Part (a) of this Instruction for each Document withheld on the basis of a claim of privilege in accordance with D. Conn. L. Civ. R. 26(e).\n\n9. If a portion of an otherwise responsive Document contains information subject to a claim of privilege, only that portion of the Document subject to the claim of privilege shall be deleted or redacted from the Document following the instructions above, and the rest shall be produced.\n\n10. The Requests are continuing in nature. You are hereby instructed to (a) supplement or correct any responses later learned to be incomplete or incorrect immediately upon learning that a prior response was incomplete or incorrect; and (b) produce any additional Documents that are called for under the\n\n11. If a Document is in a language other than English, You should provide that Document. If a Document is in a language other than English, and an English translation exists, You should provide both Documents.\n\n12. All references to Entities includes all affiliates thereof.\n\n13. All references to individual names include all alternative names, aliased, or nicknames.\n\n14. Unless otherwise expressly indicated, the period of time covered by the Document Requests is the period from February 5, 2012 to the date responses to the Document Requests are due.\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 401 of 1063\n\n#### **II. RULES OF CONSTRUCTION**\n\n15. The use of (a) any singular noun shall be construed to include the plural, and vice versa, and (b) a verb in any tense shall be construed as the use of the verb in all other tenses.\n\n16. The terms (a) \"and\" and \"or\" shall be construed either conjunctively or disjunctively as necessary to bring within the scope of any request all responses that might otherwise be construed to be outside of its scope, and (b) \"each\" and \"any\" shall be deemed to include and encompass the words \"every\" and \"all.\"\n\n#### **III. DEFINITIONS**\n\nThe definitions supplied by D. Conn. L. Civ. R. 26(c) and the rules of construction supplied by D. Conn. L. Civ. R. 26(d), as incorporated by D. Conn. Bankr. L.R. 2004-1(a), shall apply to the Document Requests. In addition, the following terms used in these Document Requests shall have the following meanings:\n\n1. \"You\" or \"Your\" or \"Yourself\" means and refers to Hamilton Opportunity Fund SPC, together with all of its affiliates, divisions, agencies, instrumentalities, departments, offices, partners, officers, directors, agents, attorneys, representatives, employees, and/or anyone acting on its behalf.\n\n2. \"Debtor\" means Ho Wan Kwok (a/k/a Miles Kwok, Miles Guo, Guo Wengui, Guo Haoyun, 郭文贵, or any other alias), together with his employees, agents, counsel, advisors, or anyone acting on his behalf.\n\n3. \"Debtor's Son\" means Qiang Guo (a/k/a Mileson Kwok, 郭强, or any other alias), together with his employees, agents, counsel, advisors, or anyone acting on his behalf.\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 402 of 1063\n\n4. \"Debtor's Daughter\" means Mei Guo (a/k/a Mei Gui, 郭美, or any other alias), together with her employees, agents, counsel, advisors, or anyone acting on her behalf.\n\n5. \"Debtor's Purported Wife\" means Hing Chi Ngok (a/k/a Hing Chi Ng, Yue Qingzhi, 岳庆芝, or any other alias), together with her employees, agents, counsel, advisors, or anyone acting on her behalf.\n\n6. \"Debtor's Family\" means, collectively, the Debtor, the Debtor's Son, the Debtor's Daughter, and the Debtor's Purported Wife, and any other familial relation to the Debtor.\n\n7. \"Associated Individuals\" means, individually and collectively, all individuals that (1) hold, control, have custody over, or discretion over assets owned, controlled, or enjoyed by the Debtor or the Debtor's Family; or (2) have been employees, directors, or otherwise are affiliated with one or more Associated Entities, together with the respective employees, agents, counsel, advisors, or anyone acting on behalf of any of the foregoing. Such Associated Individuals shall include, but are not limited to: Daniel Podhaskie, Jason Miller, Steve Bannon, Karin Maistrello, Melissa Francis, Anthony DiBattista, William Gertz, Arethusa Forsyth, Glenn Mellor, Jennifer Mercurio, Eduardo Eurnekian, Wencong Wang, Han Chunguang (a/k/a 韩春光), Qu Guojiao (a/k/a Qu Guo Jiao, 屈国姣), Guo Lijie (a/k/a 郭丽杰), Zhang Wei (a/k/a 张伟\\*), Lihong Wei Lafrenz (a/k/a Sara Wei, 魏丽红), Hao Haidong (a/k/a 郝海东), Ross Heinemeyer, Max Krasner, Kyle Bass, Melissa Mendez, Ya Li (a/k/a 李娅), Dinggang Wang (a/k/a 王定刚), An Hong (a/k/a 安红), Yvette Wang (a/k/a Yanping Wang, Yan Ping Wang, 王雁平), Fiona Yu, Je Kin Ming (a/k/a William Je, Yu Jianming, 余建明), Yaz Qingua, and Lao Jiang (a/k/a Jiang Yunfu, Jiang Yunfu Be, 姜云浮).\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 403 of 1063\n\n8. \"Associated Entities\" means, individually and collectively, all organizations or Entities of any type that (1) have been owned, controlled, or invested in by the Debtor or the Debtor's Family; or (2) have an interest, whether directly or indirectly, in any assets owned, controlled, or enjoyed by the Debtor or the Debtor's Family, together with the respective employees, agents, counsel, advisors, or anyone acting on behalf of any of the foregoing. Such Associated Entities shall include, but are not limited to: 7 Nod Hill LLC, AAGV Limited, ACA Investment Management Limited, ACA Capital Group Limited, Ace Decade Holdings Limited, AI Group Holdings Inc., Alfa Global Ventures Limited, Alfonso Global Limited, Allied Capital Global Limited, Alpine Fiduciaries SA, Anton Development Limited, Assets Sino Limited, Auspicious Coast Limited, Beijing Pangu Investment Co., Beijing Pangu Investment Co. Ltd., Beijing Pangu Investment Inc., Beijing Zenith Holdings Company Limited, Booming Sail New York LLC, Bravo Luck Limited, BSA Strategic Fund I, China Golden Spring (Hong Kong) Limited, Chuang Xin Limited, Crane Advisory Group LLC, Creative Apex Investments Limited, Crystal Breeze Investments Limited, Dawn State Limited, Eastern Profit Corporation Limited, Elite Well Global Limited, Empire Growth Holdings, Freedom Media Ventures Ltd., G Club Operations LLC, G Fashion LLC, G News LLC, GETTR USA, Genever Holdings Corporation, Genever Holdings LLC, Gfashion Media Group Inc., GFNY, Inc., Globalist International Limited, GNews Media Group Inc., Golden Spring (New York) Ltd., Greenwich Land LLC, Guo Media, GTV Media Group, Inc., Hamilton Capital Holdings Inc., HCHK Property Management, Inc., HCHK Technologies, Inc., Head Win Group Limited, Henan Yuda, Himalaya Embassy, Himalaya Exchange, Himalaya Federal Reserve, Himalaya Investment LLC, Himalaya International, Himalaya New World Inc., Himalaya Supervisory Organization, Himalaya Ventures LLC, HK International Funds Investments (USA) Limited LLC, Hong Kong International Funds\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 404 of 1063\n\nInvestments Limited, Hudson Diamond Holding, Infinite Increase Limited, Infinitum Developments Limited, Infinity Treasury Management Inc., Insight Phoenix Fund, Lamp Capital LLC, Leading Shine Limited, Leading Shine NY Limited, Lexington Property and Staffing, Long Gate Limited, Maywind Trading LLC, MOS Himalaya LLC, Next Tycoon Investments Limited, New Federal State of China (a/k/a NFSC), Noble Fame Global Limited, Rosy Acme Ventures Limited, Rule of Law Foundation III, Inc., Rule of Law Foundation IV, Inc., Rule of Law Fund, Rule of Law Society, Rule of Law Society IV, Inc., G-Translators PTY LTD, Saraca Media Group, Inc., Shiny Ace Ltd., Shiny Times Holdings Ltd., Spirit Charter Investment Limited, Stevenson, Wong & Co., Voice of Guo Media, Inc., Well Origin Ltd., World Century Limited, Worldwide Opportunity Holdings Limited, Whitecroft Shore Limited, and ZIBA Limited.\n\n9. \"Including\" or any variant thereof means \"including without limitation.\"\n\n10. \"And\" and \"or\" mean \"and/or,\" and shall be construed both conjunctively as well as disjunctively in order to maximize their scope.\n\n11. \"Any\" and \"all\" and \"each\" mean \"each and every.\"\n\n12. \"Each\" and \"every\" mean \"each and every.\"\n\n13. \"Third Party\" means a Person or Entity other than Yourself.\n\n14. \"Transfer\" shall have the meaning given to it by section 101(54) of the Bankruptcy Code.\n\n15. \"Document\" means any information or thing within the scope of Fed. R. Civ. P. 34, and includes, without limitation, each and every written, recorded, or graphic matter of any kind, type, nature, or description that is or has been in Your Possession, Custody or Control, including all printed and electronic copies of electronic mail, computer files maintained in\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 405 of 1063\n\nelectronic form, electronic communication, text message, social media post, tweet, meta-data, correspondence, memoranda, tapes, stenographic or handwritten notes, written forms of any kind, charts, blueprints, drawings, sketches, graphs, plans, articles, specifications, diaries, letters, telegrams, photographs, minutes, contracts, agreements, surveys, computer printouts, data compilations of any kind, telexes, facsimiles, voice messages, invoices, order forms, checks, drafts, statements, credit memos, reports, position reports, summaries, indices, books, ledgers, notebooks, schedules, transparencies, recordings, catalogs, advertisements, promotional materials, films, video tapes, audio tapes, CDs, computer disks, brochures, pamphlets, punchcards, time-slips, Tweets, social media posts, or any written or recorded materials of any other kind, and all meta-data thereof, however stored (whether in tangible or electronic form), recorded, produced, or reproduced, and also including but not limited to, drafts or copies of any of the foregoing that contain any notes, comments, or markings of any kind not found on the original documents or that are otherwise not identical to the original documents.\n\n16. \"Person(s)\" means an individual, corporation, proprietorship, partnership, association, or any other Entity. \"Person\" also includes any agent, representatives, or expert, including but not limiting to, attorneys or financial advisors.\n\n17. \"Entity\" means any natural Person, corporation, partnership, subsidiary, sole proprietorship, firm, board, joint venture, association, agency, authority, commission or other business entity or juristic Person, as well as any affiliate, agent, parent including but not limited to legal counsel, financial advisors, or any other representative.\n\n18. \"Regarding\" means concerning, describing, comprising, referring to, related to, supporting, favoring, opposing, bolstering, detracting from, located in, considered in connection with, bearing on, evidencing, indicating, reporting on, recording, alluding to, responding to,\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 406 of 1063\n\nconnected with, commenting on, in respect of, about, in relation to, discussing, showing, describing, reflecting, analyzing constituting, and being.\n\n19. \"Relating to,\" \"relate(s) to\" or \"related to,\" when referring to any given subject matter, means, without limitation, any document that constitutes, comprises, involves, contains, embodies, reflects, identifies, states, refers directly or indirectly to, or is in any way relevant to the particular subject matter identified.\n\n20. \"Communication(s)\" means, in the broadest possible sense, and without limitation, any transmittal of information or knowledge (in the form of facts, ideas, inquiries, or otherwise). Communication(s) further refers to all conversations, agreements, inquiries, or replies, whether in person, by telephone, in writing, or by means of electronic transmittal devices, and includes, but is not limited to, all correspondence, emails, recordings, transmittal slips, memoranda, telephone communications, voice messages, telegrams, telefaxes, telecopies, telexes, instant messages, chats, text messages, telephonic notes, or notes transmitted internally or with third parties.\n\n21. \"Asset(s)\" means any item that can be used to produce positive economic value, including but not limited to any resource with economic value that is owned, controlled or is for the benefit of an entity, that is expected to provide a future benefit, including but not limited to, all real and personal property, intangible property, investments, rights to invest or to future revenue, cash, bank accounts, commodities, securities, claims, total or partial control of an entity, and prospective economic opportunities\n\n22. \"Transfer\" shall have the meaning given to it by section 101(54) of the Bankruptcy Code.\n\n#### **IV. DOCUMENTS TO BE PRODUCED**\n\n1. All Documents regarding any income or Asset of the Debtor, the Debtor's estate, or an Associated Entity.\n\n2. All Documents related to the Debtor's financial condition and obligations to his creditors, including without limitation all Documents related to any effort to avoid paying such obligations and All Documents related to this or any other actual or potential bankruptcy or similar insolvency proceeding.\n\n3. All Documents regarding any balance sheet, bank statement, account statement, financial statement, statement of account, wire transfer instructions and/or confirmation, proof of funds, certificate of deposit, certificate of holdings, investment portfolio summary, or similar document relating to the Debtor, the Debtor's Estate, the Debtor's Family, an Associated Entity, or an Associated Individual, including without limitation all Documents sufficient to show all Transfers to any of the foregoing.\n\n4. All Documents regarding any investment, business dealing or transactions made by, with, or on behalf of the Debtor.\n\n5. All Communications with the Debtor, and Documents related to Communications with the Debtor, related to the operation, management, or decision-making of any Entity, including without limitation the Associated Entities.\n\n6. All Documents regarding any Transfer, investment, or other transaction or business dealing made to, by, or with the Debtor, the Debtor's Family, or an Associated Entity.\n\n7. All Documents regarding any property ever occupied or used by the Debtor, including without limitation the *Lady May*; the Sherry Netherland Hotel / Condominium; the\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 408 of 1063\n\nresidential property located in Greenwich, Connecticut at 373 Taconic Rd.; the residential property located in Greenwich, Connecticut at 33 Ferncliff Rd.; and the residential property located in Wilton, Connecticut at 354 Nod Hill Rd.\n\n8. All Documents related to any aircraft owned, controlled, or used by the Debtor, including without limitation the aircraft bearing tail number T7-GQM and any other aircraft registered in San Marino, including without limitation copies of all registration documents and flight manifests showing flights taken by such aircraft and the individuals onboard such flights.\n\n9. All Documents regarding any gifts, benefits or loans, to, from or on behalf of the Debtor, the Debtor's Estate, the Debtor's Family, or the Associated Entities, including without limitation Documents sufficient to show the amounts of such gifts, benefits, or loans; the purposes for which such gifts, benefits, or loans were used; when the gifts, benefits, or loans were provided; and the terms of any loans, all representations and warranties made in connection with any loans, the interest rate on any loans, and all evidence of payments of any loans.\n\n10. All Documents concerning any trust or similar instrument set up by, on behalf of, or for the benefit of the Debtor, the Debtor's Estate, the Debtor's Family, or an Associated Entity, including without limitation Documents sufficient to show when the trust(s) was created, by whom it was created, for whose benefit it was created, and the corpus of the trust.\n\n11. All Documents related to any obligation, claim, liability, or debt associated with any legal dispute involving the Debtor, including but not limited to those relating to any litigation before any local, state, federal, or international body, whether an administrative body, court, panel, or alternative dispute resolution entity.\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 409 of 1063\n\n12. All Documents and communications between any of your outside counsel or other advisors and the Debtor.\n\n13. Documents sufficient to show all of Your Assets and sources of income or funding.\n\n14. For all Assets identified in response to Request 14 having a value of more than \\$50,000, all (i) Documents related to Your acquisition of such Asset and (ii) Communications with the Debtor or the Debtor's Family regarding such Asset.\n\n15. Copies of Your tax returns.\n\n16. Documents sufficient to show all bank accounts and investment accounts within Your possession or control, including the balances of and transfers to and from each such account.\n\n17. All Documents regarding any credit cards used by You, including without limitation monthly statements or other Documents sufficient to show all purchases related thereto for the benefit of the Debtor or an Associated Entity.\n\n18. All corporate governance and organizational Documents, including without limitation by-laws and certificates of incorporation and other Documents sufficient to show Your corporate structure, names of officers and directors, business purpose, and relationship to the Debtor or to any member of the Debtor's Family.\n\n19. All Documents related to any pledge(s) of Your Assets to any other Entity.\n\nCase 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 410 of 1063\n\n# Exhibit C-22\n\n#### B2540 (Form 2540 – Subpoena for Rule 2004 Examination) (12/15) Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 411 of\n\n1063\n\nUNITED STATES BANKRUPTCY COURT\n\n**District of Connecticut**\n\nIn re HO WAN KWOK, *et al*.,\n\n<sup>1</sup> Case No. 22-50073 (JAM) Debtor Chapter 11\n\n(Jointly Administered)\n\n# **SUBPOENA FOR RULE 2004 EXAMINATION**\n\n## To: **Ginnel Associates, Inc. (d/b/a Ginnel Real Estate)**\n\n(*Name of person to whom the subpoena is directed*)\n\n*Testimony:* **YOU ARE COMMANDED** to appear at the time, date, and place set forth below to testify at an examination under Rule 2004, Federal Rules of Bankruptcy Procedure. A copy of the court order authorizing the examination is attached.\n\n| PLACE                    | DATE AND TIME |\n|--------------------------|---------------|\n| Paul Hastings LLP        |               |\n| 200 Park Avenue          | [TBD]         |\n| New York, New York 10166 |               |\n|                          |               |\n\nThe examination will be recorded by this method: **Court reporter/stenographer**\n\n*Production:* You, or your representatives, must also bring with you to the examination the following documents, electronically stored information, or objects, and must permit inspection, copying, testing, or sampling of the material:\n\n#### **See Requests for Production of Documents, attached hereto.**\n\nThe following provisions of Fed. R. Civ. P. 45, made applicable in bankruptcy cases by Fed. R. Bankr. P. 9016, are attached – Rule 45(c), relating to the place of compliance; Rule 45(d), relating to your protection as a person subject to a subpoena; and Rule 45(e) and 45(g), relating to your duty to respond to this subpoena and the potential consequences of not doing so.\n\nDate: **March , 2023**\n\nCLERK OF COURT\n\nOR\n\n*Signature of Clerk or Deputy Clerk Attorney's signature*\n\nThe name, address, email address, and telephone number of the attorney representing Luc A. Despins, Chapter 11 Trustee, who issues or requests this subpoena, are:\n\n**Douglas S. Skalka, Esq.; Neubert, Pepe & Monteith, P.C.; 195 Church Street, New Haven, Connecticut 06510 dskalka@npmlaw.com; (203) 821-2000**\n\n**Notice to the person who issues or requests this subpoena**\n\nIf this subpoena commands the production of documents, electronically stored information, or tangible things, or the inspection of premises before trial, a notice and a copy of this subpoena must be served on each party before it is served on the person to whom it is directed. Fed. R. Civ. P. 45(a)(4).\n\nSoftware Copyright (c) 1996-2022 Best Case, LLC - www.bestcase.com Best Case Bankruptcy 1 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\n#### **PROOF OF SERVICE**\n\n**(This section should not be filed with the court unless required by Fed. R. Civ. P. 45.)**\n\nI received this subpoena for (*name of individual and title, if any*): on (*date*) .\n\nI served the subpoena by delivering a copy to the named person as follows:\n\non *(date)* ; or\n\nI returned the subpoena unexecuted because:\n\nUnless the subpoena was issued on behalf of the United States, or one of its officers or agents, I have also tendered to the witness the fees for one day's attendance, and the mileage allowed by law, in the amount of \\$ .\n\nMy fees are \\$ for travel and \\$ for services, for a total of \\$ .\n\nI declare under penalty of perjury that this information is true and correct.\n\nDate:\n\n*Server's signature*\n\n*Printed name and title*\n\n*Server's address*\n\nAdditional information concerning attempted service, etc.:\n\n#### **Federal Rule of Civil Procedure 45(c), (d), (e), and (g) (Effective 12/1/13) (made applicable in bankruptcy cases by Rule 9016, Federal Rules of Bankruptcy Procedure)**\n\n#### **(c) Place of compliance.**\n\n*(1) For a Trial, Hearing, or Deposition.* A subpoena may command a person to attend a trial, hearing, or deposition only as follows:\n\n(A) within 100 miles of where the person resides, is employed, or regularly transacts business in person; or\n\n(B) within the state where the person resides, is employed, or regularly transacts business in person, if the person\n\n(i) is a party or a party's officer; or\n\n(ii) is commanded to attend a trial and would not incur substantial expense.\n\n*(2) For Other Discovery.* A subpoena may command:\n\n(A) production of documents, or electronically stored information, or things at a place within 100 miles of where the person resides, is employed, or regularly transacts business in person; and\n\n(B) inspection of premises, at the premises to be inspected.\n\n#### **(d) Protecting a Person Subject to a Subpoena; Enforcement.**\n\n*(1) Avoiding Undue Burden or Expense; Sanctions.* A party or attorney responsible for issuing and serving a subpoena must take reasonable steps to avoid imposing undue burden or expense on a person subject to the subpoena. The court for the district where compliance is required must enforce this duty and impose an appropriate sanction which may include lost earnings and reasonable attorney's fees — on a party or attorney who fails to comply.\n\n#### *(2) Command to Produce Materials or Permit Inspection.*\n\n*(A) Appearance Not Required.* A person commanded to produce documents, electronically stored information, or tangible things, or to permit the inspection of premises, need not appear in person at the place of production or inspection unless also commanded to appear for a deposition, hearing, or trial.\n\n*(B) Objections.* A person commanded to produce documents or tangible things or to permit inspection may serve on the party or attorney designated in the subpoena a written objection to inspecting, copying, testing or sampling any or all of the materials or to inspecting the premises — or to producing electronically stored information in the form or forms requested. The objection must be served before the earlier of the time specified for compliance or 14 days after the subpoena is served. If an objection is made, the following rules apply:\n\n(i) At any time, on notice to the commanded person, the serving party may move the court for the district where compliance is required for an order compelling production or inspection.\n\n(ii) These acts may be required only as directed in the order, and the order must protect a person who is neither a party nor a party's officer from significant expense resulting from compliance.\n\n#### *(3) Quashing or Modifying a Subpoena.*\n\n*(A) When Required.* On timely motion, the court for the district where compliance is required must quash or modify a subpoena that:\n\n(i) fails to allow a reasonable time to comply;\n\n(ii) requires a person to comply beyond the geographical limits specified in Rule 45(c);\n\n(iii) requires disclosure of privileged or other protected matter, if no exception or waiver applies; or\n\n(iv) subjects a person to undue burden.\n\n*(B) When Permitted.* To protect a person subject to or affected by a subpoena, the court for the district where compliance is required may, on motion, quash or modify the subpoena if it requires:\n\n(i) disclosing a trade secret or other confidential research, development, or commercial information; or\n\n(ii) disclosing an unretained expert's opinion or information that does not describe specific occurrences in dispute and results from the expert's study that was not requested by a party.\n\n(C) *Specifying Conditions as an Alternative.* In the circumstances described in Rule 45(d)(3)(B), the court may, instead of quashing or modifying a subpoena, order appearance or production under specified conditions if the serving party:\n\n(i) shows a substantial need for the testimony or material that cannot be otherwise met without undue hardship; and\n\n(ii) ensures that the subpoenaed person will be reasonably compensated.\n\n#### **(e) Duties in Responding to a Subpoena.**\n\n*(1) Producing Documents or Electronically Stored Information.* These procedures apply to producing documents or electronically stored information:\n\n*(A) Documents.* A person responding to a subpoena to produce documents must produce them as they are kept in the ordinary course of business or must organize and label them to correspond to the categories in the demand.\n\n*(B) Form for Producing Electronically Stored Information Not Specified.* If a subpoena does not specify a form for producing electronically stored information, the person responding must produce it in a form or forms in which it is ordinarily maintained or in a reasonably usable form or forms.\n\n*(C) Electronically Stored Information Produced in Only One Form.* The person responding need not produce the same electronically stored information in more than one form.\n\n*(D) Inaccessible Electronically Stored Information.* The person responding need not provide discovery of electronically stored information from sources that the person identifies as not reasonably accessible because of undue burden or cost. On motion to compel discovery or for a protective order, the person responding must show that the information is not reasonably accessible because of undue burden or cost. If that showing is made, the court may nonetheless order discovery from such sources if the requesting party shows good cause, considering the limitations of Rule 26(b)(2)(C). The court may specify conditions for the discovery.\n\n#### *(2) Claiming Privilege or Protection.*\n\n*(A) Information Withheld.* A person withholding subpoenaed information under a claim that it is privileged or subject to protection as trial-preparation material must: (i) expressly make the claim; and\n\n(ii) describe the nature of the withheld documents, communications, or tangible things in a manner that, without revealing information itself privileged or protected, will enable the parties to assess the claim.\n\n*(B) Information Produced.* If information produced in response to a subpoena is subject to a claim of privilege or of protection as trial-preparation material, the person making the claim may notify any party that received the information of the claim and the basis for it. After being notified, a party must promptly return, sequester, or destroy the specified information and any copies it has; must not use or disclose the information until the claim is resolved; must take reasonable steps to retrieve the information if the party disclosed it before being notified; and may promptly present the information under seal to the court for the district where compliance is required for a determination of the claim. The person who produced the information must preserve the information until the claim is resolved.\n\n**(g) Contempt.** The court for the district where compliance is required – and also, after a motion is transferred, the issuing court – may hold in contempt a person who, having been served, fails without adequate excuse to obey the subpoena or an order related to it.\n\nFor access to subpoena materials, see Fed.R.Civ.P.45(a) Committee Note (2013)\n\n…\n\n## **Request for Production of Documents**\n\n## **I. INSTRUCTIONS**\n\n1. Unless otherwise indicated, the requests for documents set forth below, (the \"Requests,\" and each, a \"Request\"), must be responded to separately and specifically. Each Request shall be answered fully unless it is in good faith objected to, in which event the reason for Your objection shall be stated in detail, as set forth below. If an objection pertains only to a portion of a Request, or a word, phrase or clause contained within it, You are required to state Your objection to that portion only and to respond to the remainder of the Requests.\n\n2. Electronically stored information must be produced in accordance with the\n\nfollowing instructions:\n\n- a. Images. Black and white images must be 300 DPI Group IV single-page TIFF files. Color images must be produced in JPEG format. File names cannot contain embedded spaces or special characters (including the comma). Folder names cannot contain embedded spaces or special characters (including the comma). All TIFF image files must have a unique file name, i.e. Bates number. Images must be endorsed with sequential Bates numbers in the lower right corner of each image. The number of TIFF files per folder should not exceed 1000 files. Excel spreadsheets should have a placeholder image named by the Bates number of the file.\n- b. Image Load File\n\t- a. Concordance® Data File. The data file (.DAT) contains all of the fielded information that will be loaded into the Concordance® database. The first line of the .DAT file must be a header row identifying the field names. The .DAT file must use the following Concordance® default delimiters: Comma ASCII character (020) Quote þ ASCII character (254). Date fields should be provided in the format: mm/dd/yyyy. Date and time fields must be two separate fields. If documents includes imaged emails and attachments, the attachment fields must be included to preserve the parent/child relationship between an email and its attachments. An OCRPATH field must be included to provide the file path and name of the extracted text file on the produced storage media. The text file must be named after the FIRSTBATES. Do not include the text in the .DAT file. For Documents with native files, a LINK field must be included to provide the file path and\n\nname of the native file. The native file must be named after the FIRSTBATES.\n\n- b. Concordance Image® OR Opticon Cross-Reference File. The image crossreference file (.LOG or .OPT) links the images to the database records. It should be a comma-delimited file consisting of seven fields per line with a line in the cross-reference file for every image in the database with the following format: ImageID,VolumeLabel,ImageFilePath,DocumentBreak,FolderBreak,Box Break,PageCoun.\n- c. Document Text. Text must be produced as separate text files, not as fields within the .DAT file. The full path to the text file (OCRPATH) should be included in the .DAT file. It is recommended document level ANSI text files, named per the FIRSTBATES/Image Key. Extracted text files must be in a separate folder, and the number of text files per folder should not exceed 1,000 files. There should be no special characters (including commas in the folder names). Text files must be provided on a document level.\n- d. Native Production for Certain File Types. File types that reasonably require viewing in their native format for a full understanding of their content and meaning must be produced in native format. These include, but are not limited to, spreadsheets, spreadsheet-like files (Microsoft Excel, comma separated values, tab separated values, etc.), Microsoft PowerPoint or other special presentation files, database files, and audio/visual files. Provide an image of a Bates numbered slip sheet indicating the presence of a native file, and include the path to the native as a field in the .dat file. Name the produced native file with the Bates number corresponding to the slip sheet for the file. Group native files within incrementally named \"NATIVE\" directories, separate from images directories.\n- e. De-duplication. Produce a single copy of each electronic document for which exact duplicates exist. For email messages, consolidate duplicates based on MD5 hash generated from the BCC, Body, CC, From, IntMsgID, To, and Attach properties. For email attachments and standalone electronic files, consolidate duplicates based on MD5 hash of the entire file.\n- f. Metadata. Produce extracted metadata for each document in the form of a Concordance compliant load file (.dat). The first line of the .DAT file must be a header row identifying the field names. The .DAT file must use the following Concordance default delimiters: Comma , ASCII character (020) Quote þ ASCII character (254)\n\nDate fields should be provided in the format: mm/dd/yyyy. Date and time fields must be two separate fields. Required metadata listed below:\n\n# Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 416 of 1063\n\n| Field Name   | Sample Data              | Description                                      |\n|--------------|--------------------------|--------------------------------------------------|\n| FIRSTBATES   | EDC0000001               | First Bates number of native file document/email |\n| LASTBATES    | EDC0000001               | Last Bates number of native file document/email  |\n|              |                          | **The LASTBATES field should be populated        |\n|              |                          | for single page                                  |\n| ATTACHRANGE  | EDC0000001<br>-          | Bates number of the first page of the parent     |\n|              | EDC0000015               | document to the Bates number of the last page of |\n|              |                          | the last attachment \"child\" document             |\n| BEGATTACH    | EDC0000001               | First Bates number of attachment range           |\n| ENDATTACH    | EDC0000015               | Last Bates number of attachment range            |\n| CUSTODIAN    | Smith, John              | Email: Mailbox where the email resided           |\n|              |                          | Native: Name of the individual or department     |\n|              |                          | from whose files the document<br>originated      |\n| FROM         | John Smith               | Email: Sender                                    |\n|              |                          | Native: Author(s) of document                    |\n|              |                          | **semi-colon should be used to separate          |\n|              |                          | multiple entries                                 |\n| TO           | Coffman, Janice; LeeW    | Recipient(s)                                     |\n|              | [mailto:LeeW@MSN.com]    | **semi-colon should be used to separate multiple |\n|              |                          | entries                                          |\n| CC           | Frank Thompson [mailto:  | Carbon copy recipient(s)                         |\n|              | frank_Thompson@cdt.com]  | **semi-colon should be used to separate          |\n|              |                          | multiple entries                                 |\n| BCC          | John Cain                | Blind carbon copy recipient(s)                   |\n|              |                          | **semi-colon should be used to separate          |\n|              |                          | multiple entries                                 |\n| SUBJECT      | Board Meeting Minutes    | Email: Subject line of the email Native: Title   |\n|              |                          | of document (if available)                       |\n| FILE_NAME    | BoardMeetingMinutes.docx | Native: Name of the original native file,        |\n|              |                          | including extension                              |\n| DATE_SENT    | 10/12/2010               | Email: Date the email was sent                   |\n|              |                          | Native: (empty)                                  |\n| TIME_SENT/   | 07:05 PM GMT             | Email: Time the email was sent/ Time zone in     |\n| TIME_ZONE    |                          | which the emails were standardized               |\n| TIME_ZONE    | GMT                      | The<br>time zone in which<br>the emails<br>were  |\n|              |                          | standardized during conversion.                  |\n| LINK         |  EDC0000001.msg   | Hyperlink to the email or native file document   |\n|              |                          | **The linked file must be named per the          |\n|              |                          | FIRSTBATES number                                |\n| FILE_EXTEN   | MSG                      | The file type extension                          |\n|              |                          | representing                                     |\n|              |                          | the Email or                                     |\n| AUTHOR       | John Smith               | Email: (empty)                                   |\n|              |                          | Native: Author of the document                   |\n| DATE_CREATED | 10/10/2010               | Email: (empty)                                   |\n|              |                          | Native: Date the document was created            |\n\n# Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 417 of 1063\n\n| TIME_CREATED | 10:25 AM                  | Email: (empty)                                  |\n|--------------|---------------------------|-------------------------------------------------|\n|              |                           | Native: Time the document was created           |\n|              |                           | **This data must be a separate field and cannot |\n|              |                           | be combined with the DATE_CREATED field         |\n| DATE_MOD     | 10/12/2010                | Email: (empty)                                  |\n|              |                           | Native: Date the document was last modified     |\n| TIME_MOD     | 07:00 PM                  | Email: (empty)                                  |\n|              |                           | Native: Time the document was last modified     |\n|              |                           | **This data must be a separate field and cannot |\n|              |                           | be combined with the DATE_MOD field             |\n| DATE_ACCESSD | 10/12/2010                | Email: (empty)                                  |\n|              |                           | Native: Date the document was last accessed     |\n| TIME_ACCESSD | 07:00 PM                  | Email: (empty)                                  |\n|              |                           | Native: Time the document was last accessed     |\n|              |                           | **This data must be a separate field and cannot |\n|              |                           | be combined with the DATE_ACCESSD field         |\n| FILE_SIZE    | 5,952                     | Size of native file<br>document/email in KB     |\n| PGCOUNT      | 1                         | Number of pages in native file document/email   |\n| PATH         |   | Email: (empty)                                  |\n|              | Agenda.doc                | Native: Path where native file document was     |\n|              |                           | stored including original file name.            |\n| INTFILEPATH  | Personal Folders\\Deleted  | Email: original location of email including     |\n|              | Items\\Board Meeting       | original file name.                             |\n|              | Minutes.msg               | Native: (empty)                                 |\n| INTMSGID     | <000805c2c71b\\$75977050\\$ | Email: Unique Message ID Native: (empty)        |\n|              | cb8306d1@MSN>             |                                                 |\n| MD5HASH      | d131dd02c5e6eec4693d9a0   | MD5 Hash value of the document.                 |\n|              | 698aff95c                 |                                                 |\n|              | 2fcab58712467eab4004583e  |                                                 |\n|              | b8fb7f89                  |                                                 |\n| OCRPATH      | TEXT/001/EDC0000001.txt   | Path to extracted text of the native file       |\n\n3. Each Request operates and should be construed independently and, unless otherwise indicated, no Request limits the scope of any other Request.\n\n4. All Documents are to be produced as kept in the usual course of business or are to be organized and labeled to correspond with the categories in these Requests.\n\n5. Each Request contained herein extends to all Documents: (a) in Your possession, custody, or control; or (b) in the possession, custody, or control of anyone acting on Your behalf,\n\n#### Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 418 of 1063\n\nincluding Your counsel or other representatives and advisors. Each Document shall be produced in its entirety.\n\n6. If You are requested to produce a Document that is no longer in Your possession, custody, or control, then Your response must (a) describe in detail the nature of the document and its contents; (b) identify the person(s) who prepared or authored the Document (and, if applicable, the Person(s) to whom the Document was sent); (c) identify the date on which the document was prepared or created; (d) state whether such Document (i) is missing or lost, (ii) has been destroyed, (iii) has been transferred, voluntarily or involuntarily, to others, or (iv) was otherwise disposed of; (e) state the reason for, and the facts and circumstances surrounding, such disposition; (f) identify the Persons who authorized such disposition; (g) identify the date or approximate date of such disposition; (h) state when the Document was most recently in Your possession, custody or control; and (i) identify the Person, if any, presently in possession, custody, or control of such Document.\n\n7. If You are requested to produce a Document that has been destroyed, then Your response must state, in addition to the information required by the preceding Instruction: (a) the reason for the Document's destruction; (b) the identity of the Person who destroyed the Document; and (c) the identity of the Person who directed that the Document be destroyed.\n\n8. If You claim that a requested Document is privileged or attorney work-product, then Your response must: (a) state (i) a description of the Document adequate to support Your contention that the Document is privileged, (ii) the title of the Document, (iii) the date of the Document, (iv) the author of the Document, (v) the addressee of the Document, (vi) the identity of each Person who received or saw the original or any draft, copy, or reproduction of the Document, (vii) whether the Document itself, or any information contained or referred to in the Document is in the possession, custody, or control of any other Persons, and if so, the identity of\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 419 of 1063\n\nsuch Persons, as well as a statement addressing how the information came into their possession, (viii) the claim of privilege under which the Document is withheld, and (ix) all of the circumstances upon which You will rely to support such claim of privilege; and (b) produce a privilege log containing all of the information requested in Part (a) of this Instruction for each Document withheld on the basis of a claim of privilege in accordance with D. Conn. L. Civ. R. 26(e). For any part of a Document Request as to which a claim of privilege or work product is not made, responsive documents should be provided in full.\n\n9. If a portion of an otherwise responsive Document contains information subject to a claim of privilege, only that portion of the Document subject to the claim of privilege shall be deleted or redacted from the Document following the instructions above, and the rest shall be produced.\n\n10. The Requests are continuing in nature. You are hereby instructed to (a) supplement or correct any responses later learned to be incomplete or incorrect immediately upon learning that a prior response was incomplete or incorrect; and (b) produce any additional Documents that are called for under the\n\n11. If a Document is in a language other than English, You should provide that Document. If a Document is in a language other than English, and an English translation exists, You should provide both Documents.\n\n12. All references to Entities includes all affiliates thereof.\n\n13. All references to individual names include all alternative names, aliased, or nicknames.\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 420 of 1063\n\n14. Unless otherwise expressly indicated, the period of time covered by the Document Requests is the period from February 5, 2015 to the date responses to the Document Requests are due.\n\n#### **II. RULES OF CONSTRUCTION**\n\n15. The use of (a) any singular noun shall be construed to include the plural, and vice versa, and (b) a verb in any tense shall be construed as the use of the verb in all other tenses.\n\n16. The terms (a) \"and\" and \"or\" shall be construed either conjunctively or disjunctively as necessary to bring within the scope of any request all responses that might otherwise be construed to be outside of its scope, and (b) \"each\" and \"any\" shall be deemed to include and encompass the words \"every\" and \"all.\"\n\n## **III. DEFINITIONS**\n\nThe definitions supplied by D. Conn. L. Civ. R. 26(c) and the rules of construction supplied by D. Conn. L. Civ. R. 26(d), as incorporated by D. Conn. Bankr. L.R. 2004-1(a), shall apply to the Document Requests. In addition, the following terms used in these Document Requests shall have the following meanings:\n\n1. \"You\" or \"Your\" or \"Yourself\" means and refers to Ginnel Associates, Inc., together with all of its affiliates, divisions, agencies, instrumentalities, departments, offices, partners, officers, directors, agents, attorneys, representatives, employees, and/or anyone acting on its behalf.\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 421 of 1063\n\n2. \"Debtor\" means Ho Wan Kwok (a/k/a Miles Kwok, Miles Guo, Guo Wengui, Guo Haoyun, 郭文贵, or any other alias), together with his employees, agents, counsel, advisors, or anyone acting on his behalf.\n\n3. \"Debtor's Son\" means Qiang Guo (a/k/a Mileson Kwok, 郭强, or any other alias), together with his employees, agents, counsel, advisors, or anyone acting on his behalf.\n\n4. \"Debtor's Daughter\" means Mei Guo (a/k/a Mei Gui, 郭美, or any other alias), together with her employees, agents, counsel, advisors, or anyone acting on her behalf.\n\n5. \"Debtor's Purported Wife\" means Hing Chi Ngok (a/k/a Hing Chi Ng, Yue Qingzhi, 岳庆芝, or any other alias), together with her employees, agents, counsel, advisors, or anyone acting on her behalf.\n\n6. \"Debtor's Family\" means, collectively, the Debtor, the Debtor's Son, the Debtor's Daughter, and the Debtor's Purported Wife, and any other familial relation to the Debtor.\n\n7. \"Associated Individuals\" means, individually and collectively, all individuals that (1) hold, control, have custody over, or discretion over assets owned, controlled, or enjoyed by the Debtor or the Debtor's Family; or (2) have been employees, directors, or otherwise are affiliated with one or more Associated Entities, together with the respective employees, agents, counsel, advisors, or anyone acting on behalf of any of the foregoing. Such Associated Individuals shall include, but are not limited to: Daniel Podhaskie, Karin Maistrello, Melissa Francis, Anthony DiBattista, Han Chunguang (a/k/a 韩春光), Qu Guojiao (a/k/a Qu Guo Jiao, 屈国姣), Zhang Wei (a/k/a 张伟\\*), Lihong Wei Lafrenz (a/k/a Sara Wei, 魏丽红Max Krasner, Yvette Wang (a/k/a Yanping Wang, Yan Ping Wang, 王雁平), Fiona Yu, and Je Kin Ming (a/k/a William Je, Yu Jianming, 余建明).\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 422 of 1063\n\n8. \"Associated Entities\" means, individually and collectively, all organizations or Entities of any type that (1) have been owned, controlled, or invested in by the Debtor or the Debtor's Family; or (2) have an interest, whether directly or indirectly, in any assets owned, controlled, or enjoyed by the Debtor or the Debtor's Family, together with the respective employees, agents, counsel, advisors, or anyone acting on behalf of any of the foregoing. Such Associated Entities shall include, but are not limited to: 7 Nod Hill LLC, ACA Investment Management Limited, ACA Capital Group Limited, Ace Decade Holdings Limited, AI Group Holdings Inc., Booming Sail New York LLC, Bravo Luck Limited, China Golden Spring (Hong Kong) Limited, Crane Advisory Group LLC, Dawn State Limited, Eastern Profit Corporation Limited, Freedom Media Ventures Ltd., G Club Operations LLC, G Fashion LLC, G News LLC, GETTR USA, Genever Holdings Corporation, Genever Holdings LLC, Gfashion Media Group Inc., GFNY, Inc., Golden Spring (New York) Ltd., Greenwich Land LLC, GTV Media Group, Inc., Hamilton Capital Holdings Inc., HCHK Property Management, Inc., HCHK Technologies, Inc., Himalaya Embassy, Himalaya Exchange, Himalaya Federal Reserve, Himalaya Investment LLC, Himalaya International, Himalaya New World Inc., Himalaya Supervisory Organization, Himalaya Ventures LLC, HK International Funds Investments (USA) Limited LLC, Hong Kong International Funds Investments Limited, Hudson Diamond Holding, Infinity Treasury Management Inc., Lexington Property and Staffing, Long Gate Limited, Maywind Trading LLC, MOS Himalaya LLC, New Federal State of China (a/k/a NFSC), Rule of Law Foundation III, Inc., Rule of Law Foundation IV, Inc., Rule of Law Fund, Rule of Law Society, Rule of Law Society IV, Inc., G-Translators PTY LTD, Saraca Media Group, Inc., Well Origin Ltd., Whitecroft Shore Limited, and ZIBA Limited.\n\n9. \"Including\" or any variant thereof means \"including without limitation.\"\n\n#### Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 423 of 1063\n\n10. \"And\" and \"or\" mean \"and/or,\" and shall be construed both conjunctively as well as disjunctively in order to maximize their scope.\n\n11. \"Any\" and \"all\" and \"each\" mean \"each and every.\"\n\n12. \"Each\" and \"every\" mean \"each and every.\"\n\n13. \"Third Party\" means a Person or Entity other than Yourself.\n\n14. \"Transfer\" shall have the meaning given to it by section 101(54) of the Bankruptcy Code.\n\n15. \"Document\" means any information or thing within the scope of Fed. R. Civ. P. 34, and includes, without limitation, each and every written, recorded, or graphic matter of any kind, type, nature, or description that is or has been in Your possession, custody or control, including all printed and electronic copies of electronic mail, computer files maintained in electronic form, correspondence, memoranda, tapes, stenographic or handwritten notes, written forms of any kind, charts, blueprints, drawings, sketches, graphs, plans, articles, specifications, diaries, letters, telegrams, photographs, minutes, contracts, agreements, surveys, computer printouts, data compilations of any kind, telexes, facsimiles, emails, text messages, instant messages, voice messages, invoices, order forms, checks, drafts, statements, credit memos, reports, position reports, summaries, indices, books, ledgers, notebooks, schedules, transparencies, recordings, catalogs, advertisements, promotional materials, films, video tapes, audio tapes, CDs, computer disks, brochures, pamphlets, punch-cards, time-slips, Tweets, social media posts, or any written or recorded materials of any other kind, and all meta-data thereof, however stored (whether in tangible or electronic form), recorded, produced, or reproduced, and also including but not limited to, drafts or copies of any of the foregoing that contain any notes, comments, or markings of any\n\n#### Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 424 of 1063\n\nkind not found on the original documents or that are otherwise not identical to the original documents.\n\n16. \"Person(s)\" means an individual, corporation, proprietorship, partnership, association, or any other Entity. \"Person\" also includes any agent, representatives, or expert, including but not limiting to, attorneys or financial advisors.\n\n17. \"Entity\" means any natural Person, corporation, partnership, subsidiary, sole proprietorship, firm, board, joint venture, association, agency, authority, commission or other business entity or juristic Person, as well as any affiliate, agent, parent including but not limited to counsel, financial advisors, or any other representative.\n\n18. \"Regarding\" means concerning, describing, comprising, referring to, related to, supporting, favoring, opposing, bolstering, detracting from, located in, considered in connection with, bearing on, evidencing, indicating, reporting on, recording, alluding to, responding to, connected with, commenting on, in respect of, about, in relation to, discussing, showing, describing, reflecting, analyzing constituting, and being.\n\n19. \"Relating to,\" \"relate(s) to\" or \"related to,\" when referring to any given subject matter, means, without limitation, any document that constitutes, comprises, involves, contains, embodies, reflects, identifies, states, refers directly or indirectly to, or is in any way relevant to the particular subject matter identified.\n\n20. \"Communication(s)\" means, in the broadest possible sense, and without limitation, any transmittal of information or knowledge (in the form of facts, ideas, inquiries, or otherwise). Communication(s) further refers to all conversations, agreements, inquiries, or replies, whether in person, by telephone, in writing, or by means of electronic transmittal devices, and includes, but is not limited to, all correspondence, emails, recordings, transmittal slips, memoranda, telephone\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 425 of 1063\n\ncommunications, voice messages, telegrams, telefaxes, telecopies, telexes, instant messages, chats, text messages, postings to a message board or group chat, social media posts, tweets, videos uploaded to any video platform, telephonic notes, or notes transmitted internally or with third parties.\n\n21. \"Asset(s)\" means any item of economic value that is subject to possession, custody, or control. Asset includes all real and personal property, including but limited to, real estate, land, houses, apartments, condominiums, automobiles, yachts, boats, planes, jets, helicopters, cash, bank accounts, cryptocurrencies, securities, accounts receivables, inventory, and other tangible and intangible property.\n\n#### **IV. DOCUMENTS TO BE PRODUCED**\n\n1. All Documents and communications regarding the Sherry Netherland Hotel / Condominium, located at 781 Fifth Avenue, New York, NY 10022 (apartments 1801 and 1519; the residential property located at 373 Taconic Rd., Greenwich, Connecticut 06831; the residential property located at 33 Ferncliff Rd., Cos Cob, Connecticut 06807; the residential property located at 354 Nod Hill Rd., Wilton, Connecticut 06897; the property located in at 32 Chateau Ridge Rd., Greenwich, Connecticut 06831; the property located at 110 Clapboard Ridge Rd., Greenwich, Connecticut 06830; the property located at 66 Sherwood Avenue, Greenwich, Connecticut 06831; the property located at 140 Wallacks Drive, Stamford, Connecticut 06902; the property located at 602 Indian Field Drive, Greenwich, Connecticut 06830; and the property located at 11 Hurlingham Drive, Greenwich, Connecticut 06831.\n\n2. All Documents or communications related to any income or Asset of the Debtor, the Debtor's estate, the Debtor's Family, or Associated Entity, including without limitation any real property located in Connecticut.\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 426 of 1063\n\n3. All Documents or communications related to any engagement letter with the Debtor, any member of the Debtor's Family, and/or any Associated Entity, including copy(ies) of such engagement letter(s).\n\n4. All Documents or communications related to the payment of any retainer or commission to You based upon your representation of the Debtor, the Debtor's Family, or an Associated Entity, including documents sufficient to identify the amount of the retainer or commission and its source.\n\n5. All Documents or communications related to any fees, payments, or monies received by You from or on behalf of the Debtor, the Debtor's Family, a Family Related Entity, or an Associated Entity held in escrow or in a client trust account.\n\n6. Documents sufficient to show the amount, date, and source of any payments made to You by, on behalf of, or for the benefit of the Debtor, the Debtor's Family, or an Associated Entity.\n\n7. All Communications between You and, either, the Debtor, the Debtor's Family, or any Associated Individual, agent, employee, or other individual acting on behalf of the Debtor, related to any Transfer, investment, or other transaction or business dealing relating to the Debtor, the Debtor's Estate, the Debtor's Family, or the Associated Entities.\n\n8. All Documents and communications related to any sale, potential sale, acquisition, disposition, purchase, potential purchase, investment, contribution, gift, extension of credit, loan, or Transfer involving the Debtor, the Debtor's Family, or any Associated Entity.\n\n9. All Documents and communications related to the Debtor's use of any Assets belonging to, controlled by, or whose complete or partial ownership is held by the Debtor's Family,\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 427 of 1063\n\nan Associated Entity, or an Associated Individual, including without limitation any real property located in Connecticut.\n\n10. All Documents and communications regarding any balance sheet, bank statement, account statement, financial statement, statement of account, wire transfer instructions and/or confirmation, proof of funds, certificate of deposit, certificate of holdings, investment portfolio summary, or similar document relating to the Debtor, the Debtor's Estate, the Debtor's Family, an Associated Entity, or an Associated Individual, including without limitation all Documents sufficient to show all Transfers to any of the foregoing.\n\n# Exhibit C-23\n\n#### B2540 (Form 2540 – Subpoena for Rule 2004 Examination) (12/15) Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 429 of\n\n1063\n\nUNITED STATES BANKRUPTCY COURT\n\n**District of Connecticut**\n\nIn re HO WAN KWOK, *et al*.,\n\n<sup>1</sup> Case No. 22-50073 (JAM)\n\nDebtor Chapter 11\n\n(Jointly Administered)\n\n## **SUBPOENA FOR RULE 2004 EXAMINATION**\n\n## To: **Ginnel Associates, Inc. (DBA Ginnel Real Estate)**\n\n(*Name of person to whom the subpoena is directed*)\n\n*Testimony:* **YOU ARE COMMANDED** to appear at the time, date, and place set forth below to testify at an examination under Rule 2004, Federal Rules of Bankruptcy Procedure. A copy of the court order authorizing the examination is attached.\n\n| PLACE                    | DATE AND TIME |\n|--------------------------|---------------|\n| Paul Hastings LLP        |               |\n| 200 Park Avenue          | [TBD]         |\n| New York, New York 10166 |               |\n|                          |               |\n\nThe examination will be recorded by this method: **Court reporter/stenographer**\n\n*Production:* You, or your representatives, must also bring with you to the examination the following documents, electronically stored information, or objects, and must permit inspection, copying, testing, or sampling of the material:\n\n#### **See Requests for Production of Documents, attached hereto.**\n\nThe following provisions of Fed. R. Civ. P. 45, made applicable in bankruptcy cases by Fed. R. Bankr. P. 9016, are attached – Rule 45(c), relating to the place of compliance; Rule 45(d), relating to your protection as a person subject to a subpoena; and Rule 45(e) and 45(g), relating to your duty to respond to this subpoena and the potential consequences of not doing so.\n\nDate: **March , 2023**\n\nCLERK OF COURT\n\nOR\n\n*Signature of Clerk or Deputy Clerk Attorney's signature*\n\nThe name, address, email address, and telephone number of the attorney representing Luc A. Despins, Chapter 11 Trustee, who issues or requests this subpoena, are:\n\n#### **Douglas S. Skalka, Esq.; Neubert, Pepe & Monteith, P.C.; 195 Church Street, New Haven, Connecticut 06510 dskalka@npmlaw.com; (203) 821-2000**\n\n#### **Notice to the person who issues or requests this subpoena**\n\nIf this subpoena commands the production of documents, electronically stored information, or tangible things, or the inspection of premises before trial, a notice and a copy of this subpoena must be served on each party before it is served on the person to whom it is directed. Fed. R. Civ. P. 45(a)(4).\n\nSoftware Copyright (c) 1996-2022 Best Case, LLC - www.bestcase.com Best Case Bankruptcy 1 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\n#### **PROOF OF SERVICE**\n\n**(This section should not be filed with the court unless required by Fed. R. Civ. P. 45.)**\n\nI received this subpoena for (*name of individual and title, if any*): on (*date*) .\n\nI served the subpoena by delivering a copy to the named person as follows:\n\non *(date)* ; or\n\nI returned the subpoena unexecuted because:\n\nUnless the subpoena was issued on behalf of the United States, or one of its officers or agents, I have also tendered to the witness the fees for one day's attendance, and the mileage allowed by law, in the amount of \\$ .\n\nMy fees are \\$ for travel and \\$ for services, for a total of \\$ .\n\nI declare under penalty of perjury that this information is true and correct.\n\nDate:\n\n*Server's signature*\n\n*Printed name and title*\n\n*Server's address*\n\nAdditional information concerning attempted service, etc.:\n\n#### **Federal Rule of Civil Procedure 45(c), (d), (e), and (g) (Effective 12/1/13) (made applicable in bankruptcy cases by Rule 9016, Federal Rules of Bankruptcy Procedure)**\n\n#### **(c) Place of compliance.**\n\n*(1) For a Trial, Hearing, or Deposition.* A subpoena may command a person to attend a trial, hearing, or deposition only as follows:\n\n(A) within 100 miles of where the person resides, is employed, or regularly transacts business in person; or\n\n(B) within the state where the person resides, is employed, or regularly transacts business in person, if the person\n\n(i) is a party or a party's officer; or\n\n(ii) is commanded to attend a trial and would not incur substantial expense.\n\n*(2) For Other Discovery.* A subpoena may command:\n\n(A) production of documents, or electronically stored information, or things at a place within 100 miles of where the person resides, is employed, or regularly transacts business in person; and\n\n(B) inspection of premises, at the premises to be inspected.\n\n#### **(d) Protecting a Person Subject to a Subpoena; Enforcement.**\n\n*(1) Avoiding Undue Burden or Expense; Sanctions.* A party or attorney responsible for issuing and serving a subpoena must take reasonable steps to avoid imposing undue burden or expense on a person subject to the subpoena. The court for the district where compliance is required must enforce this duty and impose an appropriate sanction which may include lost earnings and reasonable attorney's fees — on a party or attorney who fails to comply.\n\n#### *(2) Command to Produce Materials or Permit Inspection.*\n\n*(A) Appearance Not Required.* A person commanded to produce documents, electronically stored information, or tangible things, or to permit the inspection of premises, need not appear in person at the place of production or inspection unless also commanded to appear for a deposition, hearing, or trial.\n\n*(B) Objections.* A person commanded to produce documents or tangible things or to permit inspection may serve on the party or attorney designated in the subpoena a written objection to inspecting, copying, testing or sampling any or all of the materials or to inspecting the premises — or to producing electronically stored information in the form or forms requested. The objection must be served before the earlier of the time specified for compliance or 14 days after the subpoena is served. If an objection is made, the following rules apply:\n\n(i) At any time, on notice to the commanded person, the serving party may move the court for the district where compliance is required for an order compelling production or inspection.\n\n(ii) These acts may be required only as directed in the order, and the order must protect a person who is neither a party nor a party's officer from significant expense resulting from compliance.\n\n#### *(3) Quashing or Modifying a Subpoena.*\n\n*(A) When Required.* On timely motion, the court for the district where compliance is required must quash or modify a subpoena that:\n\n(i) fails to allow a reasonable time to comply;\n\n(ii) requires a person to comply beyond the geographical limits specified in Rule 45(c);\n\n(iii) requires disclosure of privileged or other protected matter, if no exception or waiver applies; or\n\n(iv) subjects a person to undue burden.\n\n*(B) When Permitted.* To protect a person subject to or affected by a subpoena, the court for the district where compliance is required may, on motion, quash or modify the subpoena if it requires:\n\n(i) disclosing a trade secret or other confidential research, development, or commercial information; or\n\n(ii) disclosing an unretained expert's opinion or information that does not describe specific occurrences in dispute and results from the expert's study that was not requested by a party.\n\n(C) *Specifying Conditions as an Alternative.* In the circumstances described in Rule 45(d)(3)(B), the court may, instead of quashing or modifying a subpoena, order appearance or production under specified conditions if the serving party:\n\n(i) shows a substantial need for the testimony or material that cannot be otherwise met without undue hardship; and\n\n(ii) ensures that the subpoenaed person will be reasonably compensated.\n\n#### **(e) Duties in Responding to a Subpoena.**\n\n*(1) Producing Documents or Electronically Stored Information.* These procedures apply to producing documents or electronically stored information:\n\n*(A) Documents.* A person responding to a subpoena to produce documents must produce them as they are kept in the ordinary course of business or must organize and label them to correspond to the categories in the demand.\n\n*(B) Form for Producing Electronically Stored Information Not Specified.* If a subpoena does not specify a form for producing electronically stored information, the person responding must produce it in a form or forms in which it is ordinarily maintained or in a reasonably usable form or forms.\n\n*(C) Electronically Stored Information Produced in Only One Form.* The person responding need not produce the same electronically stored information in more than one form.\n\n*(D) Inaccessible Electronically Stored Information.* The person responding need not provide discovery of electronically stored information from sources that the person identifies as not reasonably accessible because of undue burden or cost. On motion to compel discovery or for a protective order, the person responding must show that the information is not reasonably accessible because of undue burden or cost. If that showing is made, the court may nonetheless order discovery from such sources if the requesting party shows good cause, considering the limitations of Rule 26(b)(2)(C). The court may specify conditions for the discovery.\n\n#### *(2) Claiming Privilege or Protection.*\n\n*(A) Information Withheld.* A person withholding subpoenaed information under a claim that it is privileged or subject to protection as trial-preparation material must: (i) expressly make the claim; and\n\n(ii) describe the nature of the withheld documents, communications, or tangible things in a manner that, without revealing information itself privileged or protected, will enable the parties to assess the claim.\n\n*(B) Information Produced.* If information produced in response to a subpoena is subject to a claim of privilege or of protection as trial-preparation material, the person making the claim may notify any party that received the information of the claim and the basis for it. After being notified, a party must promptly return, sequester, or destroy the specified information and any copies it has; must not use or disclose the information until the claim is resolved; must take reasonable steps to retrieve the information if the party disclosed it before being notified; and may promptly present the information under seal to the court for the district where compliance is required for a determination of the claim. The person who produced the information must preserve the information until the claim is resolved.\n\n**(g) Contempt.** The court for the district where compliance is required – and also, after a motion is transferred, the issuing court – may hold in contempt a person who, having been served, fails without adequate excuse to obey the subpoena or an order related to it.\n\nFor access to subpoena materials, see Fed.R.Civ.P.45(a) Committee Note (2013)\n\n…\n\n## **Request for Production of Documents**\n\n## **I. INSTRUCTIONS**\n\n1. Unless otherwise indicated, the requests for documents set forth below, (the \"Requests,\" and each, a \"Request\"), must be responded to separately and specifically. Each Request shall be answered fully unless it is in good faith objected to, in which event the reason for Your objection shall be stated in detail, as set forth below. If an objection pertains only to a portion of a Request, or a word, phrase or clause contained within it, You are required to state Your objection to that portion only and to respond to the remainder of the Requests.\n\n2. Electronically stored information must be produced in accordance with the\n\nfollowing instructions:\n\n- a. Images. Black and white images must be 300 DPI Group IV single-page TIFF files. Color images must be produced in JPEG format. File names cannot contain embedded spaces or special characters (including the comma). Folder names cannot contain embedded spaces or special characters (including the comma). All TIFF image files must have a unique file name, i.e. Bates number. Images must be endorsed with sequential Bates numbers in the lower right corner of each image. The number of TIFF files per folder should not exceed 1000 files. Excel spreadsheets should have a placeholder image named by the Bates number of the file.\n- b. Image Load File\n\t- a. Concordance® Data File. The data file (.DAT) contains all of the fielded information that will be loaded into the Concordance® database. The first line of the .DAT file must be a header row identifying the field names. The .DAT file must use the following Concordance® default delimiters: Comma ASCII character (020) Quote þ ASCII character (254). Date fields should be provided in the format: mm/dd/yyyy. Date and time fields must be two separate fields. If documents includes imaged emails and attachments, the attachment fields must be included to preserve the parent/child relationship between an email and its attachments. An OCRPATH field must be included to provide the file path and name of the extracted text file on the produced storage media. The text file must be named after the FIRSTBATES. Do not include the text in the .DAT file. For Documents with native files, a LINK field must be included to provide the file path and\n\nname of the native file. The native file must be named after the FIRSTBATES.\n\n- b. Concordance Image® OR Opticon Cross-Reference File. The image crossreference file (.LOG or .OPT) links the images to the database records. It should be a comma-delimited file consisting of seven fields per line with a line in the cross-reference file for every image in the database with the following format: ImageID,VolumeLabel,ImageFilePath,DocumentBreak,FolderBreak,Box Break,PageCoun.\n- c. Document Text. Text must be produced as separate text files, not as fields within the .DAT file. The full path to the text file (OCRPATH) should be included in the .DAT file. It is recommended document level ANSI text files, named per the FIRSTBATES/Image Key. Extracted text files must be in a separate folder, and the number of text files per folder should not exceed 1,000 files. There should be no special characters (including commas in the folder names). Text files must be provided on a document level.\n- d. Native Production for Certain File Types. File types that reasonably require viewing in their native format for a full understanding of their content and meaning must be produced in native format. These include, but are not limited to, spreadsheets, spreadsheet-like files (Microsoft Excel, comma separated values, tab separated values, etc.), Microsoft PowerPoint or other special presentation files, database files, and audio/visual files. Provide an image of a Bates numbered slip sheet indicating the presence of a native file, and include the path to the native as a field in the .dat file. Name the produced native file with the Bates number corresponding to the slip sheet for the file. Group native files within incrementally named \"NATIVE\" directories, separate from images directories.\n- e. De-duplication. Produce a single copy of each electronic document for which exact duplicates exist. For email messages, consolidate duplicates based on MD5 hash generated from the BCC, Body, CC, From, IntMsgID, To, and Attach properties. For email attachments and standalone electronic files, consolidate duplicates based on MD5 hash of the entire file.\n- f. Metadata. Produce extracted metadata for each document in the form of a Concordance compliant load file (.dat). The first line of the .DAT file must be a header row identifying the field names. The .DAT file must use the following Concordance default delimiters: Comma , ASCII character (020) Quote þ ASCII character (254)\n\nDate fields should be provided in the format: mm/dd/yyyy. Date and time fields must be two separate fields. Required metadata listed below:\n\n# Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 434 of 1063\n\n| Field Name   | Sample Data              | Description                                                                                  |\n|--------------|--------------------------|----------------------------------------------------------------------------------------------|\n| FIRSTBATES   | EDC0000001               | First Bates number of native file document/email                                             |\n| LASTBATES    | EDC0000001               | Last Bates number of native file document/email<br>**The LASTBATES field should be populated |\n|              |                          | for single page                                                                              |\n| ATTACHRANGE  | EDC0000001<br>-          | Bates number of the first page of the parent                                                 |\n|              | EDC0000015               | document to the Bates number of the last page of                                             |\n|              |                          | the last attachment \"child\" document                                                         |\n| BEGATTACH    | EDC0000001               | First Bates number of attachment range                                                       |\n| ENDATTACH    | EDC0000015               | Last Bates number of attachment range                                                        |\n| CUSTODIAN    | Smith, John              | Email: Mailbox where the email resided                                                       |\n|              |                          | Native: Name of the individual or department                                                 |\n|              |                          | from whose files the document<br>originated                                                  |\n| FROM         | John Smith               | Email: Sender                                                                                |\n|              |                          | Native: Author(s) of document                                                                |\n|              |                          | **semi-colon should be used to separate                                                      |\n|              |                          | multiple entries                                                                             |\n| TO           | Coffman, Janice; LeeW    | Recipient(s)                                                                                 |\n|              | [mailto:LeeW@MSN.com]    | **semi-colon should be used to separate multiple                                             |\n|              |                          | entries                                                                                      |\n| CC           | Frank Thompson [mailto:  | Carbon copy recipient(s)                                                                     |\n|              | frank_Thompson@cdt.com]  | **semi-colon should be used to separate                                                      |\n|              |                          | multiple entries                                                                             |\n| BCC          | John Cain                | Blind carbon copy recipient(s)                                                               |\n|              |                          | **semi-colon should be used to separate                                                      |\n|              |                          | multiple entries                                                                             |\n| SUBJECT      | Board Meeting Minutes    | Email: Subject line of the email Native: Title                                               |\n|              |                          | of document (if available)                                                                   |\n| FILE_NAME    | BoardMeetingMinutes.docx | Native: Name of the original native file,                                                    |\n|              |                          | including extension                                                                          |\n| DATE_SENT    | 10/12/2010               | Email: Date the email was sent                                                               |\n|              |                          | Native: (empty)                                                                              |\n| TIME_SENT/   | 07:05 PM GMT             | Email: Time the email was sent/ Time zone in                                                 |\n| TIME_ZONE    |                          | which the emails were standardized                                                           |\n| TIME_ZONE    | GMT                      | The<br>time zone in which<br>the emails<br>were                                              |\n|              |                          | standardized during conversion.                                                              |\n| LINK         |  EDC0000001.msg   | Hyperlink to the email or native file document                                               |\n|              |                          | **The linked file must be named per the                                                      |\n|              |                          | FIRSTBATES number                                                                            |\n| FILE_EXTEN   | MSG                      | The file type extension                                                                      |\n|              |                          | representing                                                                                 |\n|              |                          | the Email or                                                                                 |\n| AUTHOR       | John Smith               | Email: (empty)                                                                               |\n|              |                          | Native: Author of the document                                                               |\n| DATE_CREATED | 10/10/2010               | Email: (empty)                                                                               |\n|              |                          | Native: Date the document was created                                                        |\n\n# Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 435 of 1063\n\n| TIME_CREATED | 10:25 AM                  | Email: (empty)                                  |\n|--------------|---------------------------|-------------------------------------------------|\n|              |                           | Native: Time the document was created           |\n|              |                           | **This data must be a separate field and cannot |\n|              |                           | be combined with the DATE_CREATED field         |\n| DATE_MOD     | 10/12/2010                | Email: (empty)                                  |\n|              |                           | Native: Date the document was last modified     |\n| TIME_MOD     | 07:00 PM                  | Email: (empty)                                  |\n|              |                           | Native: Time the document was last modified     |\n|              |                           | **This data must be a separate field and cannot |\n|              |                           | be combined with the DATE_MOD field             |\n| DATE_ACCESSD | 10/12/2010                | Email: (empty)                                  |\n|              |                           | Native: Date the document was last accessed     |\n| TIME_ACCESSD | 07:00 PM                  | Email: (empty)                                  |\n|              |                           | Native: Time the document was last accessed     |\n|              |                           | **This data must be a separate field and cannot |\n|              |                           | be combined with the DATE_ACCESSD field         |\n| FILE_SIZE    | 5,952                     | Size of native file<br>document/email in KB     |\n| PGCOUNT      | 1                         | Number of pages in native file document/email   |\n| PATH         |   | Email: (empty)                                  |\n|              | Agenda.doc                | Native: Path where native file document was     |\n|              |                           | stored including original file name.            |\n| INTFILEPATH  | Personal Folders\\Deleted  | Email: original location of email including     |\n|              | Items\\Board Meeting       | original file name.                             |\n|              | Minutes.msg               | Native: (empty)                                 |\n| INTMSGID     | <000805c2c71b\\$75977050\\$ | Email: Unique Message ID Native: (empty)        |\n|              | cb8306d1@MSN>             |                                                 |\n| MD5HASH      | d131dd02c5e6eec4693d9a0   | MD5 Hash value of the document.                 |\n|              | 698aff95c                 |                                                 |\n|              | 2fcab58712467eab4004583e  |                                                 |\n|              | b8fb7f89                  |                                                 |\n| OCRPATH      | TEXT/001/EDC0000001.txt   | Path to extracted text of the native file       |\n\n3. Each Request operates and should be construed independently and, unless otherwise indicated, no Request limits the scope of any other Request.\n\n4. All Documents are to be produced as kept in the usual course of business or are to be organized and labeled to correspond with the categories in these Requests.\n\n5. Each Request contained herein extends to all Documents: (a) in Your possession, custody, or control; or (b) in the possession, custody, or control of anyone acting on Your behalf,\n\n#### Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 436 of 1063\n\nincluding Your counsel or other representatives and advisors. Each Document shall be produced in its entirety.\n\n6. If You are requested to produce a Document that is no longer in Your possession, custody, or control, then Your response must (a) describe in detail the nature of the document and its contents; (b) identify the person(s) who prepared or authored the Document (and, if applicable, the Person(s) to whom the Document was sent); (c) identify the date on which the document was prepared or created; (d) state whether such Document (i) is missing or lost, (ii) has been destroyed, (iii) has been transferred, voluntarily or involuntarily, to others, or (iv) was otherwise disposed of; (e) state the reason for, and the facts and circumstances surrounding, such disposition; (f) identify the Persons who authorized such disposition; (g) identify the date or approximate date of such disposition; (h) state when the Document was most recently in Your possession, custody or control; and (i) identify the Person, if any, presently in possession, custody, or control of such Document.\n\n7. If You are requested to produce a Document that has been destroyed, then Your response must state, in addition to the information required by the preceding Instruction: (a) the reason for the Document's destruction; (b) the identity of the Person who destroyed the Document; and (c) the identity of the Person who directed that the Document be destroyed.\n\n8. If You claim that a requested Document is privileged or attorney work-product, then Your response must: (a) state (i) a description of the Document adequate to support Your contention that the Document is privileged, (ii) the title of the Document, (iii) the date of the Document, (iv) the author of the Document, (v) the addressee of the Document, (vi) the identity of each Person who received or saw the original or any draft, copy, or reproduction of the Document, (vii) whether the Document itself, or any information contained or referred to in the Document is in the possession, custody, or control of any other Persons, and if so, the identity of\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 437 of 1063\n\nsuch Persons, as well as a statement addressing how the information came into their possession, (viii) the claim of privilege under which the Document is withheld, and (ix) all of the circumstances upon which You will rely to support such claim of privilege; and (b) produce a privilege log containing all of the information requested in Part (a) of this Instruction for each Document withheld on the basis of a claim of privilege in accordance with D. Conn. L. Civ. R. 26(e). For any part of a Document Request as to which a claim of privilege or work product is not made, responsive documents should be provided in full.\n\n9. If a portion of an otherwise responsive Document contains information subject to a claim of privilege, only that portion of the Document subject to the claim of privilege shall be deleted or redacted from the Document following the instructions above, and the rest shall be produced.\n\n10. The Requests are continuing in nature. You are hereby instructed to (a) supplement or correct any responses later learned to be incomplete or incorrect immediately upon learning that a prior response was incomplete or incorrect; and (b) produce any additional Documents that are called for under the\n\n11. If a Document is in a language other than English, You should provide that Document. If a Document is in a language other than English, and an English translation exists, You should provide both Documents.\n\n12. All references to Entities includes all affiliates thereof.\n\n13. All references to individual names include all alternative names, aliased, or nicknames.\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 438 of 1063\n\n14. Unless otherwise expressly indicated, the period of time covered by the Document Requests is the period from February 5, 2015 to the date responses to the Document Requests are due.\n\n#### **II. RULES OF CONSTRUCTION**\n\n15. The use of (a) any singular noun shall be construed to include the plural, and vice versa, and (b) a verb in any tense shall be construed as the use of the verb in all other tenses.\n\n16. The terms (a) \"and\" and \"or\" shall be construed either conjunctively or disjunctively as necessary to bring within the scope of any request all responses that might otherwise be construed to be outside of its scope, and (b) \"each\" and \"any\" shall be deemed to include and encompass the words \"every\" and \"all.\"\n\n## **III. DEFINITIONS**\n\nThe definitions supplied by D. Conn. L. Civ. R. 26(c) and the rules of construction supplied by D. Conn. L. Civ. R. 26(d), as incorporated by D. Conn. Bankr. L.R. 2004-1(a), shall apply to the Document Requests. In addition, the following terms used in these Document Requests shall have the following meanings:\n\n1. \"You\" or \"Your\" or \"Yourself\" means and refers to Redfin Corporation, together with all of its affiliates, divisions, agencies, instrumentalities, departments, offices, partners, officers, directors, agents, attorneys, representatives, employees, and/or anyone acting on its behalf.\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 439 of 1063\n\n2. \"Debtor\" means Ho Wan Kwok (a/k/a Miles Kwok, Miles Guo, Guo Wengui, Guo Haoyun, 郭文贵, or any other alias), together with his employees, agents, counsel, advisors, or anyone acting on his behalf.\n\n3. \"Debtor's Son\" means Qiang Guo (a/k/a Mileson Kwok, 郭强, or any other alias), together with his employees, agents, counsel, advisors, or anyone acting on his behalf.\n\n4. \"Debtor's Daughter\" means Mei Guo (a/k/a Mei Gui, 郭美, or any other alias), together with her employees, agents, counsel, advisors, or anyone acting on her behalf.\n\n5. \"Debtor's Purported Wife\" means Hing Chi Ngok (a/k/a Hing Chi Ng, Yue Qingzhi, 岳庆芝, or any other alias), together with her employees, agents, counsel, advisors, or anyone acting on her behalf.\n\n6. \"Debtor's Family\" means, collectively, the Debtor, the Debtor's Son, the Debtor's Daughter, and the Debtor's Purported Wife, and any other familial relation to the Debtor.\n\n7. \"Associated Individuals\" means, individually and collectively, all individuals that (1) hold, control, have custody over, or discretion over assets owned, controlled, or enjoyed by the Debtor or the Debtor's Family; or (2) have been employees, directors, or otherwise are affiliated with one or more Associated Entities, together with the respective employees, agents, counsel, advisors, or anyone acting on behalf of any of the foregoing. Such Associated Individuals shall include, but are not limited to: Daniel Podhaskie, Karin Maistrello, Melissa Francis, Anthony DiBattista, Han Chunguang (a/k/a 韩春光), Qu Guojiao (a/k/a Qu Guo Jiao, 屈国姣), Zhang Wei (a/k/a 张伟\\*), Lihong Wei Lafrenz (a/k/a Sara Wei, 魏丽红Max Krasner, Yvette Wang (a/k/a Yanping Wang, Yan Ping Wang, 王雁平), Fiona Yu, and Je Kin Ming (a/k/a William Je, Yu Jianming, 余建明).\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 440 of 1063\n\n8. \"Associated Entities\" means, individually and collectively, all organizations or Entities of any type that (1) have been owned, controlled, or invested in by the Debtor or the Debtor's Family; or (2) have an interest, whether directly or indirectly, in any assets owned, controlled, or enjoyed by the Debtor or the Debtor's Family, together with the respective employees, agents, counsel, advisors, or anyone acting on behalf of any of the foregoing. Such Associated Entities shall include, but are not limited to: 7 Nod Hill LLC, ACA Investment Management Limited, ACA Capital Group Limited, Ace Decade Holdings Limited, AI Group Holdings Inc., Booming Sail New York LLC, Bravo Luck Limited, China Golden Spring (Hong Kong) Limited, Crane Advisory Group LLC, Dawn State Limited, Eastern Profit Corporation Limited, Freedom Media Ventures Ltd., G Club Operations LLC, G Fashion LLC, G News LLC, GETTR USA, Genever Holdings Corporation, Genever Holdings LLC, Gfashion Media Group Inc., GFNY, Inc., Golden Spring (New York) Ltd., Greenwich Land LLC, GTV Media Group, Inc., Hamilton Capital Holdings Inc., HCHK Property Management, Inc., HCHK Technologies, Inc., Himalaya Embassy, Himalaya Exchange, Himalaya Federal Reserve, Himalaya Investment LLC, Himalaya International, Himalaya New World Inc., Himalaya Supervisory Organization, Himalaya Ventures LLC, HK International Funds Investments (USA) Limited LLC, Hong Kong International Funds Investments Limited, Hudson Diamond Holding, Infinity Treasury Management Inc., Lexington Property and Staffing, Long Gate Limited, Maywind Trading LLC, MOS Himalaya LLC, New Federal State of China (a/k/a NFSC), Rule of Law Foundation III, Inc., Rule of Law Foundation IV, Inc., Rule of Law Fund, Rule of Law Society, Rule of Law Society IV, Inc., G-Translators PTY LTD, Saraca Media Group, Inc., Well Origin Ltd., Whitecroft Shore Limited, and ZIBA Limited.\n\n9. \"Including\" or any variant thereof means \"including without limitation.\"\n\n#### Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 441 of 1063\n\n10. \"And\" and \"or\" mean \"and/or,\" and shall be construed both conjunctively as well as disjunctively in order to maximize their scope.\n\n11. \"Any\" and \"all\" and \"each\" mean \"each and every.\"\n\n12. \"Each\" and \"every\" mean \"each and every.\"\n\n13. \"Third Party\" means a Person or Entity other than Yourself.\n\n14. \"Transfer\" shall have the meaning given to it by section 101(54) of the Bankruptcy Code.\n\n15. \"Document\" means any information or thing within the scope of Fed. R. Civ. P. 34, and includes, without limitation, each and every written, recorded, or graphic matter of any kind, type, nature, or description that is or has been in Your possession, custody or control, including all printed and electronic copies of electronic mail, computer files maintained in electronic form, correspondence, memoranda, tapes, stenographic or handwritten notes, written forms of any kind, charts, blueprints, drawings, sketches, graphs, plans, articles, specifications, diaries, letters, telegrams, photographs, minutes, contracts, agreements, surveys, computer printouts, data compilations of any kind, telexes, facsimiles, emails, text messages, instant messages, voice messages, invoices, order forms, checks, drafts, statements, credit memos, reports, position reports, summaries, indices, books, ledgers, notebooks, schedules, transparencies, recordings, catalogs, advertisements, promotional materials, films, video tapes, audio tapes, CDs, computer disks, brochures, pamphlets, punch-cards, time-slips, Tweets, social media posts, or any written or recorded materials of any other kind, and all meta-data thereof, however stored (whether in tangible or electronic form), recorded, produced, or reproduced, and also including but not limited to, drafts or copies of any of the foregoing that contain any notes, comments, or markings of any\n\n#### Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 442 of 1063\n\nkind not found on the original documents or that are otherwise not identical to the original documents.\n\n16. \"Person(s)\" means an individual, corporation, proprietorship, partnership, association, or any other Entity. \"Person\" also includes any agent, representatives, or expert, including but not limiting to, attorneys or financial advisors.\n\n17. \"Entity\" means any natural Person, corporation, partnership, subsidiary, sole proprietorship, firm, board, joint venture, association, agency, authority, commission or other business entity or juristic Person, as well as any affiliate, agent, parent including but not limited to counsel, financial advisors, or any other representative.\n\n18. \"Regarding\" means concerning, describing, comprising, referring to, related to, supporting, favoring, opposing, bolstering, detracting from, located in, considered in connection with, bearing on, evidencing, indicating, reporting on, recording, alluding to, responding to, connected with, commenting on, in respect of, about, in relation to, discussing, showing, describing, reflecting, analyzing constituting, and being.\n\n19. \"Relating to,\" \"relate(s) to\" or \"related to,\" when referring to any given subject matter, means, without limitation, any document that constitutes, comprises, involves, contains, embodies, reflects, identifies, states, refers directly or indirectly to, or is in any way relevant to the particular subject matter identified.\n\n20. \"Communication(s)\" means, in the broadest possible sense, and without limitation, any transmittal of information or knowledge (in the form of facts, ideas, inquiries, or otherwise). Communication(s) further refers to all conversations, agreements, inquiries, or replies, whether in person, by telephone, in writing, or by means of electronic transmittal devices, and includes, but is not limited to, all correspondence, emails, recordings, transmittal slips, memoranda, telephone\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 443 of 1063\n\ncommunications, voice messages, telegrams, telefaxes, telecopies, telexes, instant messages, chats, text messages, postings to a message board or group chat, social media posts, tweets, videos uploaded to any video platform, telephonic notes, or notes transmitted internally or with third parties.\n\n21. \"Asset(s)\" means any item of economic value that is subject to possession, custody, or control. Asset includes all real and personal property, including but limited to, real estate, land, houses, apartments, condominiums, automobiles, yachts, boats, planes, jets, helicopters, cash, bank accounts, cryptocurrencies, securities, accounts receivables, inventory, and other tangible and intangible property.\n\n#### **IV. DOCUMENTS TO BE PRODUCED**\n\n1. All Documents and communications regarding the Sherry Netherland Hotel / Condominium, located at 781 Fifth Avenue, New York, NY 10022 (apartments 1801 and 1519; the residential property located at 373 Taconic Rd., Greenwich, Connecticut 06831; the residential property located at 33 Ferncliff Rd., Cos Cob, Connecticut 06807; the residential property located at 354 Nod Hill Rd., Wilton, Connecticut 06897; the property located in at 32 Chateau Ridge Rd., Greenwich, Connecticut 06831; the property located at 110 Clapboard Ridge Rd., Greenwich, Connecticut 06830; the property located at 66 Sherwood Avenue, Greenwich, Connecticut 06831; the property located at 140 Wallacks Drive, Stamford, Connecticut 06902; the property located at 602 Indian Field Drive, Greenwich, Connecticut 06830; and the property located at 11 Hurlingham Drive, Greenwich, Connecticut 06831.\n\n2. All Documents or communications related to any income or Asset of the Debtor, the Debtor's estate, the Debtor's Family, or Associated Entity, including without limitation any real property located in Connecticut.\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 444 of 1063\n\n3. All Documents or communications related to any engagement letter with the Debtor, any member of the Debtor's Family, and/or any Associated Entity, including copy(ies) of such engagement letter(s).\n\n4. All Documents or communications related to the payment of any retainer or commission to You based upon your representation of the Debtor, the Debtor's Family, or an Associated Entity, including documents sufficient to identify the amount of the retainer or commission and its source.\n\n5. All Documents or communications related to any fees, payments, or monies received by You from or on behalf of the Debtor, the Debtor's Family, a Family Related Entity, or an Associated Entity held in escrow or in a client trust account.\n\n6. Documents sufficient to show the amount, date, and source of any payments made to You by, on behalf of, or for the benefit of the Debtor, the Debtor's Family, or an Associated Entity.\n\n7. All Communications between You and, either, the Debtor, the Debtor's Family, or any Associated Individual, agent, employee, or other individual acting on behalf of the Debtor, related to any Transfer, investment, or other transaction or business dealing relating to the Debtor, the Debtor's Estate, the Debtor's Family, or the Associated Entities.\n\n8. All Documents and communications related to any sale, potential sale, acquisition, disposition, purchase, potential purchase, investment, contribution, gift, extension of credit, loan, or Transfer involving the Debtor, the Debtor's Family, or any Associated Entity.\n\n9. All Documents and communications related to the Debtor's use of any Assets belonging to, controlled by, or whose complete or partial ownership is held by the Debtor's Family,\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 445 of 1063\n\nan Associated Entity, or an Associated Individual, including without limitation any real property located in Connecticut.\n\n10. All Documents and communications regarding any balance sheet, bank statement, account statement, financial statement, statement of account, wire transfer instructions and/or confirmation, proof of funds, certificate of deposit, certificate of holdings, investment portfolio summary, or similar document relating to the Debtor, the Debtor's Estate, the Debtor's Family, an Associated Entity, or an Associated Individual, including without limitation all Documents sufficient to show all Transfers to any of the foregoing.\n\n# Exhibit C-24\n\n#### B2540 (Form 2540 – Subpoena for Rule 2004 Examination) (12/15) Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 447 of\n\n1063\n\nUNITED STATES BANKRUPTCY COURT\n\n**District of Connecticut**\n\nIn re HO WAN KWOK, *et al*.,\n\n<sup>1</sup> Case No. 22-50073 (JAM) Debtor Chapter 11\n\n(Jointly Administered)\n\n# **SUBPOENA FOR RULE 2004 EXAMINATION**\n\n## To: **Sotheby's International Realty Affiliates LLC**\n\n(*Name of person to whom the subpoena is directed*)\n\n*Testimony:* **YOU ARE COMMANDED** to appear at the time, date, and place set forth below to testify at an examination under Rule 2004, Federal Rules of Bankruptcy Procedure. A copy of the court order authorizing the examination is attached.\n\n| PLACE                    | DATE AND TIME |\n|--------------------------|---------------|\n| Paul Hastings LLP        |               |\n| 200 Park Avenue          | [TBD]         |\n| New York, New York 10166 |               |\n|                          |               |\n\nThe examination will be recorded by this method: **Court reporter/stenographer**\n\n*Production:* You, or your representatives, must also bring with you to the examination the following documents, electronically stored information, or objects, and must permit inspection, copying, testing, or sampling of the material:\n\n#### **See Requests for Production of Documents, attached hereto.**\n\nThe following provisions of Fed. R. Civ. P. 45, made applicable in bankruptcy cases by Fed. R. Bankr. P. 9016, are attached – Rule 45(c), relating to the place of compliance; Rule 45(d), relating to your protection as a person subject to a subpoena; and Rule 45(e) and 45(g), relating to your duty to respond to this subpoena and the potential consequences of not doing so.\n\nDate: **March , 2023**\n\nCLERK OF COURT\n\nOR\n\n*Signature of Clerk or Deputy Clerk Attorney's signature*\n\nThe name, address, email address, and telephone number of the attorney representing Luc A. Despins, Chapter 11 Trustee, who issues or requests this subpoena, are:\n\n**Douglas S. Skalka, Esq.; Neubert, Pepe & Monteith, P.C.; 195 Church Street, New Haven, Connecticut 06510 dskalka@npmlaw.com; (203) 821-2000**\n\n**Notice to the person who issues or requests this subpoena**\n\nIf this subpoena commands the production of documents, electronically stored information, or tangible things, or the inspection of premises before trial, a notice and a copy of this subpoena must be served on each party before it is served on the person to whom it is directed. Fed. R. Civ. P. 45(a)(4).\n\nSoftware Copyright (c) 1996-2022 Best Case, LLC - www.bestcase.com Best Case Bankruptcy 1 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\n#### **PROOF OF SERVICE**\n\n**(This section should not be filed with the court unless required by Fed. R. Civ. P. 45.)**\n\nI received this subpoena for (*name of individual and title, if any*): on (*date*) .\n\nI served the subpoena by delivering a copy to the named person as follows:\n\non *(date)* ; or\n\nI returned the subpoena unexecuted because:\n\nUnless the subpoena was issued on behalf of the United States, or one of its officers or agents, I have also tendered to the witness the fees for one day's attendance, and the mileage allowed by law, in the amount of \\$ .\n\nMy fees are \\$ for travel and \\$ for services, for a total of \\$ .\n\nI declare under penalty of perjury that this information is true and correct.\n\nDate:\n\n*Server's signature*\n\n*Printed name and title*\n\n*Server's address*\n\nAdditional information concerning attempted service, etc.:\n\n#### **Federal Rule of Civil Procedure 45(c), (d), (e), and (g) (Effective 12/1/13) (made applicable in bankruptcy cases by Rule 9016, Federal Rules of Bankruptcy Procedure)**\n\n#### **(c) Place of compliance.**\n\n*(1) For a Trial, Hearing, or Deposition.* A subpoena may command a person to attend a trial, hearing, or deposition only as follows:\n\n(A) within 100 miles of where the person resides, is employed, or regularly transacts business in person; or\n\n(B) within the state where the person resides, is employed, or regularly transacts business in person, if the person\n\n(i) is a party or a party's officer; or\n\n(ii) is commanded to attend a trial and would not incur substantial expense.\n\n*(2) For Other Discovery.* A subpoena may command:\n\n(A) production of documents, or electronically stored information, or things at a place within 100 miles of where the person resides, is employed, or regularly transacts business in person; and\n\n(B) inspection of premises, at the premises to be inspected.\n\n#### **(d) Protecting a Person Subject to a Subpoena; Enforcement.**\n\n*(1) Avoiding Undue Burden or Expense; Sanctions.* A party or attorney responsible for issuing and serving a subpoena must take reasonable steps to avoid imposing undue burden or expense on a person subject to the subpoena. The court for the district where compliance is required must enforce this duty and impose an appropriate sanction which may include lost earnings and reasonable attorney's fees — on a party or attorney who fails to comply.\n\n#### *(2) Command to Produce Materials or Permit Inspection.*\n\n*(A) Appearance Not Required.* A person commanded to produce documents, electronically stored information, or tangible things, or to permit the inspection of premises, need not appear in person at the place of production or inspection unless also commanded to appear for a deposition, hearing, or trial.\n\n*(B) Objections.* A person commanded to produce documents or tangible things or to permit inspection may serve on the party or attorney designated in the subpoena a written objection to inspecting, copying, testing or sampling any or all of the materials or to inspecting the premises — or to producing electronically stored information in the form or forms requested. The objection must be served before the earlier of the time specified for compliance or 14 days after the subpoena is served. If an objection is made, the following rules apply:\n\n(i) At any time, on notice to the commanded person, the serving party may move the court for the district where compliance is required for an order compelling production or inspection.\n\n(ii) These acts may be required only as directed in the order, and the order must protect a person who is neither a party nor a party's officer from significant expense resulting from compliance.\n\n#### *(3) Quashing or Modifying a Subpoena.*\n\n*(A) When Required.* On timely motion, the court for the district where compliance is required must quash or modify a subpoena that:\n\n(i) fails to allow a reasonable time to comply;\n\n(ii) requires a person to comply beyond the geographical limits specified in Rule 45(c);\n\n(iii) requires disclosure of privileged or other protected matter, if no exception or waiver applies; or\n\n(iv) subjects a person to undue burden.\n\n*(B) When Permitted.* To protect a person subject to or affected by a subpoena, the court for the district where compliance is required may, on motion, quash or modify the subpoena if it requires:\n\n(i) disclosing a trade secret or other confidential research, development, or commercial information; or\n\n(ii) disclosing an unretained expert's opinion or information that does not describe specific occurrences in dispute and results from the expert's study that was not requested by a party.\n\n(C) *Specifying Conditions as an Alternative.* In the circumstances described in Rule 45(d)(3)(B), the court may, instead of quashing or modifying a subpoena, order appearance or production under specified conditions if the serving party:\n\n(i) shows a substantial need for the testimony or material that cannot be otherwise met without undue hardship; and\n\n(ii) ensures that the subpoenaed person will be reasonably compensated.\n\n#### **(e) Duties in Responding to a Subpoena.**\n\n*(1) Producing Documents or Electronically Stored Information.* These procedures apply to producing documents or electronically stored information:\n\n*(A) Documents.* A person responding to a subpoena to produce documents must produce them as they are kept in the ordinary course of business or must organize and label them to correspond to the categories in the demand.\n\n*(B) Form for Producing Electronically Stored Information Not Specified.* If a subpoena does not specify a form for producing electronically stored information, the person responding must produce it in a form or forms in which it is ordinarily maintained or in a reasonably usable form or forms.\n\n*(C) Electronically Stored Information Produced in Only One Form.* The person responding need not produce the same electronically stored information in more than one form.\n\n*(D) Inaccessible Electronically Stored Information.* The person responding need not provide discovery of electronically stored information from sources that the person identifies as not reasonably accessible because of undue burden or cost. On motion to compel discovery or for a protective order, the person responding must show that the information is not reasonably accessible because of undue burden or cost. If that showing is made, the court may nonetheless order discovery from such sources if the requesting party shows good cause, considering the limitations of Rule 26(b)(2)(C). The court may specify conditions for the discovery.\n\n#### *(2) Claiming Privilege or Protection.*\n\n*(A) Information Withheld.* A person withholding subpoenaed information under a claim that it is privileged or subject to protection as trial-preparation material must: (i) expressly make the claim; and\n\n(ii) describe the nature of the withheld documents, communications, or tangible things in a manner that, without revealing information itself privileged or protected, will enable the parties to assess the claim.\n\n*(B) Information Produced.* If information produced in response to a subpoena is subject to a claim of privilege or of protection as trial-preparation material, the person making the claim may notify any party that received the information of the claim and the basis for it. After being notified, a party must promptly return, sequester, or destroy the specified information and any copies it has; must not use or disclose the information until the claim is resolved; must take reasonable steps to retrieve the information if the party disclosed it before being notified; and may promptly present the information under seal to the court for the district where compliance is required for a determination of the claim. The person who produced the information must preserve the information until the claim is resolved.\n\n**(g) Contempt.** The court for the district where compliance is required – and also, after a motion is transferred, the issuing court – may hold in contempt a person who, having been served, fails without adequate excuse to obey the subpoena or an order related to it.\n\nFor access to subpoena materials, see Fed.R.Civ.P.45(a) Committee Note (2013)\n\n…\n\n## **Request for Production of Documents**\n\n## **I. INSTRUCTIONS**\n\n1. Unless otherwise indicated, the requests for documents set forth below, (the \"Requests,\" and each, a \"Request\"), must be responded to separately and specifically. Each Request shall be answered fully unless it is in good faith objected to, in which event the reason for Your objection shall be stated in detail, as set forth below. If an objection pertains only to a portion of a Request, or a word, phrase or clause contained within it, You are required to state Your objection to that portion only and to respond to the remainder of the Requests.\n\n2. Electronically stored information must be produced in accordance with the\n\nfollowing instructions:\n\n- a. Images. Black and white images must be 300 DPI Group IV single-page TIFF files. Color images must be produced in JPEG format. File names cannot contain embedded spaces or special characters (including the comma). Folder names cannot contain embedded spaces or special characters (including the comma). All TIFF image files must have a unique file name, i.e. Bates number. Images must be endorsed with sequential Bates numbers in the lower right corner of each image. The number of TIFF files per folder should not exceed 1000 files. Excel spreadsheets should have a placeholder image named by the Bates number of the file.\n- b. Image Load File\n\t- a. Concordance® Data File. The data file (.DAT) contains all of the fielded information that will be loaded into the Concordance® database. The first line of the .DAT file must be a header row identifying the field names. The .DAT file must use the following Concordance® default delimiters: Comma ASCII character (020) Quote þ ASCII character (254). Date fields should be provided in the format: mm/dd/yyyy. Date and time fields must be two separate fields. If documents includes imaged emails and attachments, the attachment fields must be included to preserve the parent/child relationship between an email and its attachments. An OCRPATH field must be included to provide the file path and name of the extracted text file on the produced storage media. The text file must be named after the FIRSTBATES. Do not include the text in the .DAT file. For Documents with native files, a LINK field must be included to provide the file path and\n\nname of the native file. The native file must be named after the FIRSTBATES.\n\n- b. Concordance Image® OR Opticon Cross-Reference File. The image crossreference file (.LOG or .OPT) links the images to the database records. It should be a comma-delimited file consisting of seven fields per line with a line in the cross-reference file for every image in the database with the following format: ImageID,VolumeLabel,ImageFilePath,DocumentBreak,FolderBreak,Box Break,PageCoun.\n- c. Document Text. Text must be produced as separate text files, not as fields within the .DAT file. The full path to the text file (OCRPATH) should be included in the .DAT file. It is recommended document level ANSI text files, named per the FIRSTBATES/Image Key. Extracted text files must be in a separate folder, and the number of text files per folder should not exceed 1,000 files. There should be no special characters (including commas in the folder names). Text files must be provided on a document level.\n- d. Native Production for Certain File Types. File types that reasonably require viewing in their native format for a full understanding of their content and meaning must be produced in native format. These include, but are not limited to, spreadsheets, spreadsheet-like files (Microsoft Excel, comma separated values, tab separated values, etc.), Microsoft PowerPoint or other special presentation files, database files, and audio/visual files. Provide an image of a Bates numbered slip sheet indicating the presence of a native file, and include the path to the native as a field in the .dat file. Name the produced native file with the Bates number corresponding to the slip sheet for the file. Group native files within incrementally named \"NATIVE\" directories, separate from images directories.\n- e. De-duplication. Produce a single copy of each electronic document for which exact duplicates exist. For email messages, consolidate duplicates based on MD5 hash generated from the BCC, Body, CC, From, IntMsgID, To, and Attach properties. For email attachments and standalone electronic files, consolidate duplicates based on MD5 hash of the entire file.\n- f. Metadata. Produce extracted metadata for each document in the form of a Concordance compliant load file (.dat). The first line of the .DAT file must be a header row identifying the field names. The .DAT file must use the following Concordance default delimiters: Comma , ASCII character (020) Quote þ ASCII character (254)\n\nDate fields should be provided in the format: mm/dd/yyyy. Date and time fields must be two separate fields. Required metadata listed below:\n\n# Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 452 of 1063\n\n| Field Name   | Sample Data              | Description                                      |\n|--------------|--------------------------|--------------------------------------------------|\n| FIRSTBATES   | EDC0000001               | First Bates number of native file document/email |\n| LASTBATES    | EDC0000001               | Last Bates number of native file document/email  |\n|              |                          | **The LASTBATES field should be populated        |\n|              |                          | for single page                                  |\n| ATTACHRANGE  | EDC0000001<br>-          | Bates number of the first page of the parent     |\n|              | EDC0000015               | document to the Bates number of the last page of |\n|              |                          | the last attachment \"child\" document             |\n| BEGATTACH    | EDC0000001               | First Bates number of attachment range           |\n| ENDATTACH    | EDC0000015               | Last Bates number of attachment range            |\n| CUSTODIAN    | Smith, John              | Email: Mailbox where the email resided           |\n|              |                          | Native: Name of the individual or department     |\n|              |                          | from whose files the document<br>originated      |\n| FROM         | John Smith               | Email: Sender                                    |\n|              |                          | Native: Author(s) of document                    |\n|              |                          | **semi-colon should be used to separate          |\n|              |                          | multiple entries                                 |\n| TO           | Coffman, Janice; LeeW    | Recipient(s)                                     |\n|              | [mailto:LeeW@MSN.com]    | **semi-colon should be used to separate multiple |\n|              |                          | entries                                          |\n| CC           | Frank Thompson [mailto:  | Carbon copy recipient(s)                         |\n|              | frank_Thompson@cdt.com]  | **semi-colon should be used to separate          |\n|              |                          | multiple entries                                 |\n| BCC          | John Cain                | Blind carbon copy recipient(s)                   |\n|              |                          | **semi-colon should be used to separate          |\n|              |                          | multiple entries                                 |\n| SUBJECT      | Board Meeting Minutes    | Email: Subject line of the email Native: Title   |\n|              |                          | of document (if available)                       |\n| FILE_NAME    | BoardMeetingMinutes.docx | Native: Name of the original native file,        |\n|              |                          | including extension                              |\n| DATE_SENT    | 10/12/2010               | Email: Date the email was sent                   |\n|              |                          | Native: (empty)                                  |\n| TIME_SENT/   | 07:05 PM GMT             | Email: Time the email was sent/ Time zone in     |\n| TIME_ZONE    |                          | which the emails were standardized               |\n| TIME_ZONE    | GMT                      | The<br>time zone in which<br>the emails<br>were  |\n|              |                          | standardized during conversion.                  |\n| LINK         |  EDC0000001.msg   | Hyperlink to the email or native file document   |\n|              |                          | **The linked file must be named per the          |\n|              |                          | FIRSTBATES number                                |\n| FILE_EXTEN   | MSG                      | The file type extension                          |\n|              |                          | representing                                     |\n|              |                          | the Email or                                     |\n| AUTHOR       | John Smith               | Email: (empty)                                   |\n|              |                          | Native: Author of the document                   |\n| DATE_CREATED | 10/10/2010               | Email: (empty)                                   |\n|              |                          | Native: Date the document was created            |\n\n# Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 453 of 1063\n\n| TIME_CREATED | 10:25 AM                  | Email: (empty)                                  |\n|--------------|---------------------------|-------------------------------------------------|\n|              |                           | Native: Time the document was created           |\n|              |                           | **This data must be a separate field and cannot |\n|              |                           | be combined with the DATE_CREATED field         |\n| DATE_MOD     | 10/12/2010                | Email: (empty)                                  |\n|              |                           | Native: Date the document was last modified     |\n| TIME_MOD     | 07:00 PM                  | Email: (empty)                                  |\n|              |                           | Native: Time the document was last modified     |\n|              |                           | **This data must be a separate field and cannot |\n|              |                           | be combined with the DATE_MOD field             |\n| DATE_ACCESSD | 10/12/2010                | Email: (empty)                                  |\n|              |                           | Native: Date the document was last accessed     |\n| TIME_ACCESSD | 07:00 PM                  | Email: (empty)                                  |\n|              |                           | Native: Time the document was last accessed     |\n|              |                           | **This data must be a separate field and cannot |\n|              |                           | be combined with the DATE_ACCESSD field         |\n| FILE_SIZE    | 5,952                     | Size of native file<br>document/email in KB     |\n| PGCOUNT      | 1                         | Number of pages in native file document/email   |\n| PATH         |   | Email: (empty)                                  |\n|              | Agenda.doc                | Native: Path where native file document was     |\n|              |                           | stored including original file name.            |\n| INTFILEPATH  | Personal Folders\\Deleted  | Email: original location of email including     |\n|              | Items\\Board Meeting       | original file name.                             |\n|              | Minutes.msg               | Native: (empty)                                 |\n| INTMSGID     | <000805c2c71b\\$75977050\\$ | Email: Unique Message ID Native: (empty)        |\n|              | cb8306d1@MSN>             |                                                 |\n| MD5HASH      | d131dd02c5e6eec4693d9a0   | MD5 Hash value of the document.                 |\n|              | 698aff95c                 |                                                 |\n|              | 2fcab58712467eab4004583e  |                                                 |\n|              | b8fb7f89                  |                                                 |\n| OCRPATH      | TEXT/001/EDC0000001.txt   | Path to extracted text of the native file       |\n\n3. Each Request operates and should be construed independently and, unless otherwise indicated, no Request limits the scope of any other Request.\n\n4. All Documents are to be produced as kept in the usual course of business or are to be organized and labeled to correspond with the categories in these Requests.\n\n5. Each Request contained herein extends to all Documents: (a) in Your possession, custody, or control; or (b) in the possession, custody, or control of anyone acting on Your behalf,\n\n#### Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 454 of 1063\n\nincluding Your counsel or other representatives and advisors. Each Document shall be produced in its entirety.\n\n6. If You are requested to produce a Document that is no longer in Your possession, custody, or control, then Your response must (a) describe in detail the nature of the document and its contents; (b) identify the person(s) who prepared or authored the Document (and, if applicable, the Person(s) to whom the Document was sent); (c) identify the date on which the document was prepared or created; (d) state whether such Document (i) is missing or lost, (ii) has been destroyed, (iii) has been transferred, voluntarily or involuntarily, to others, or (iv) was otherwise disposed of; (e) state the reason for, and the facts and circumstances surrounding, such disposition; (f) identify the Persons who authorized such disposition; (g) identify the date or approximate date of such disposition; (h) state when the Document was most recently in Your possession, custody or control; and (i) identify the Person, if any, presently in possession, custody, or control of such Document.\n\n7. If You are requested to produce a Document that has been destroyed, then Your response must state, in addition to the information required by the preceding Instruction: (a) the reason for the Document's destruction; (b) the identity of the Person who destroyed the Document; and (c) the identity of the Person who directed that the Document be destroyed.\n\n8. If You claim that a requested Document is privileged or attorney work-product, then Your response must: (a) state (i) a description of the Document adequate to support Your contention that the Document is privileged, (ii) the title of the Document, (iii) the date of the Document, (iv) the author of the Document, (v) the addressee of the Document, (vi) the identity of each Person who received or saw the original or any draft, copy, or reproduction of the Document, (vii) whether the Document itself, or any information contained or referred to in the Document is in the possession, custody, or control of any other Persons, and if so, the identity of\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 455 of 1063\n\nsuch Persons, as well as a statement addressing how the information came into their possession, (viii) the claim of privilege under which the Document is withheld, and (ix) all of the circumstances upon which You will rely to support such claim of privilege; and (b) produce a privilege log containing all of the information requested in Part (a) of this Instruction for each Document withheld on the basis of a claim of privilege in accordance with D. Conn. L. Civ. R. 26(e). For any part of a Document Request as to which a claim of privilege or work product is not made, responsive documents should be provided in full.\n\n9. If a portion of an otherwise responsive Document contains information subject to a claim of privilege, only that portion of the Document subject to the claim of privilege shall be deleted or redacted from the Document following the instructions above, and the rest shall be produced.\n\n10. The Requests are continuing in nature. You are hereby instructed to (a) supplement or correct any responses later learned to be incomplete or incorrect immediately upon learning that a prior response was incomplete or incorrect; and (b) produce any additional Documents that are called for under the\n\n11. If a Document is in a language other than English, You should provide that Document. If a Document is in a language other than English, and an English translation exists, You should provide both Documents.\n\n12. All references to Entities includes all affiliates thereof.\n\n13. All references to individual names include all alternative names, aliased, or nicknames.\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 456 of 1063\n\n14. Unless otherwise expressly indicated, the period of time covered by the Document Requests is the period from February 5, 2015 to the date responses to the Document Requests are due.\n\n#### **II. RULES OF CONSTRUCTION**\n\n15. The use of (a) any singular noun shall be construed to include the plural, and vice versa, and (b) a verb in any tense shall be construed as the use of the verb in all other tenses.\n\n16. The terms (a) \"and\" and \"or\" shall be construed either conjunctively or disjunctively as necessary to bring within the scope of any request all responses that might otherwise be construed to be outside of its scope, and (b) \"each\" and \"any\" shall be deemed to include and encompass the words \"every\" and \"all.\"\n\n## **III. DEFINITIONS**\n\nThe definitions supplied by D. Conn. L. Civ. R. 26(c) and the rules of construction supplied by D. Conn. L. Civ. R. 26(d), as incorporated by D. Conn. Bankr. L.R. 2004-1(a), shall apply to the Document Requests. In addition, the following terms used in these Document Requests shall have the following meanings:\n\n1. \"You\" or \"Your\" or \"Yourself\" means and refers to Sotheby's International Realty Affiliates LLC, together with all of its affiliates, divisions, agencies, instrumentalities, departments, offices, partners, officers, directors, agents, attorneys, representatives, employees, and/or anyone acting on its behalf.\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 457 of 1063\n\n2. \"Debtor\" means Ho Wan Kwok (a/k/a Miles Kwok, Miles Guo, Guo Wengui, Guo Haoyun, 郭文贵, or any other alias), together with his employees, agents, counsel, advisors, or anyone acting on his behalf.\n\n3. \"Debtor's Son\" means Qiang Guo (a/k/a Mileson Kwok, 郭强, or any other alias), together with his employees, agents, counsel, advisors, or anyone acting on his behalf.\n\n4. \"Debtor's Daughter\" means Mei Guo (a/k/a Mei Gui, 郭美, or any other alias), together with her employees, agents, counsel, advisors, or anyone acting on her behalf.\n\n5. \"Debtor's Purported Wife\" means Hing Chi Ngok (a/k/a Hing Chi Ng, Yue Qingzhi, 岳庆芝, or any other alias), together with her employees, agents, counsel, advisors, or anyone acting on her behalf.\n\n6. \"Debtor's Family\" means, collectively, the Debtor, the Debtor's Son, the Debtor's Daughter, and the Debtor's Purported Wife, and any other familial relation to the Debtor.\n\n7. \"Associated Individuals\" means, individually and collectively, all individuals that (1) hold, control, have custody over, or discretion over assets owned, controlled, or enjoyed by the Debtor or the Debtor's Family; or (2) have been employees, directors, or otherwise are affiliated with one or more Associated Entities, together with the respective employees, agents, counsel, advisors, or anyone acting on behalf of any of the foregoing. Such Associated Individuals shall include, but are not limited to: Daniel Podhaskie, Karin Maistrello, Melissa Francis, Anthony DiBattista, Han Chunguang (a/k/a 韩春光), Qu Guojiao (a/k/a Qu Guo Jiao, 屈国姣), Zhang Wei (a/k/a 张伟\\*), Lihong Wei Lafrenz (a/k/a Sara Wei, 魏丽红Max Krasner, Yvette Wang (a/k/a Yanping Wang, Yan Ping Wang, 王雁平), Fiona Yu, and Je Kin Ming (a/k/a William Je, Yu Jianming, 余建明).\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 458 of 1063\n\n8. \"Associated Entities\" means, individually and collectively, all organizations or Entities of any type that (1) have been owned, controlled, or invested in by the Debtor or the Debtor's Family; or (2) have an interest, whether directly or indirectly, in any assets owned, controlled, or enjoyed by the Debtor or the Debtor's Family, together with the respective employees, agents, counsel, advisors, or anyone acting on behalf of any of the foregoing. Such Associated Entities shall include, but are not limited to: 7 Nod Hill LLC, ACA Investment Management Limited, ACA Capital Group Limited, Ace Decade Holdings Limited, AI Group Holdings Inc., Booming Sail New York LLC, Bravo Luck Limited, China Golden Spring (Hong Kong) Limited, Crane Advisory Group LLC, Dawn State Limited, Eastern Profit Corporation Limited, Freedom Media Ventures Ltd., G Club Operations LLC, G Fashion LLC, G News LLC, GETTR USA, Genever Holdings Corporation, Genever Holdings LLC, Gfashion Media Group Inc., GFNY, Inc., Golden Spring (New York) Ltd., Greenwich Land LLC, GTV Media Group, Inc., Hamilton Capital Holdings Inc., HCHK Property Management, Inc., HCHK Technologies, Inc., Himalaya Embassy, Himalaya Exchange, Himalaya Federal Reserve, Himalaya Investment LLC, Himalaya International, Himalaya New World Inc., Himalaya Supervisory Organization, Himalaya Ventures LLC, HK International Funds Investments (USA) Limited LLC, Hong Kong International Funds Investments Limited, Hudson Diamond Holding, Infinity Treasury Management Inc., Lexington Property and Staffing, Long Gate Limited, Maywind Trading LLC, MOS Himalaya LLC, New Federal State of China (a/k/a NFSC), Rule of Law Foundation III, Inc., Rule of Law Foundation IV, Inc., Rule of Law Fund, Rule of Law Society, Rule of Law Society IV, Inc., G-Translators PTY LTD, Saraca Media Group, Inc., Well Origin Ltd., Whitecroft Shore Limited, and ZIBA Limited.\n\n9. \"Including\" or any variant thereof means \"including without limitation.\"\n\n#### Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 459 of 1063\n\n10. \"And\" and \"or\" mean \"and/or,\" and shall be construed both conjunctively as well as disjunctively in order to maximize their scope.\n\n11. \"Any\" and \"all\" and \"each\" mean \"each and every.\"\n\n12. \"Each\" and \"every\" mean \"each and every.\"\n\n13. \"Third Party\" means a Person or Entity other than Yourself.\n\n14. \"Transfer\" shall have the meaning given to it by section 101(54) of the Bankruptcy Code.\n\n15. \"Document\" means any information or thing within the scope of Fed. R. Civ. P. 34, and includes, without limitation, each and every written, recorded, or graphic matter of any kind, type, nature, or description that is or has been in Your possession, custody or control, including all printed and electronic copies of electronic mail, computer files maintained in electronic form, correspondence, memoranda, tapes, stenographic or handwritten notes, written forms of any kind, charts, blueprints, drawings, sketches, graphs, plans, articles, specifications, diaries, letters, telegrams, photographs, minutes, contracts, agreements, surveys, computer printouts, data compilations of any kind, telexes, facsimiles, emails, text messages, instant messages, voice messages, invoices, order forms, checks, drafts, statements, credit memos, reports, position reports, summaries, indices, books, ledgers, notebooks, schedules, transparencies, recordings, catalogs, advertisements, promotional materials, films, video tapes, audio tapes, CDs, computer disks, brochures, pamphlets, punch-cards, time-slips, Tweets, social media posts, or any written or recorded materials of any other kind, and all meta-data thereof, however stored (whether in tangible or electronic form), recorded, produced, or reproduced, and also including but not limited to, drafts or copies of any of the foregoing that contain any notes, comments, or markings of any\n\n#### Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 460 of 1063\n\nkind not found on the original documents or that are otherwise not identical to the original documents.\n\n16. \"Person(s)\" means an individual, corporation, proprietorship, partnership, association, or any other Entity. \"Person\" also includes any agent, representatives, or expert, including but not limiting to, attorneys or financial advisors.\n\n17. \"Entity\" means any natural Person, corporation, partnership, subsidiary, sole proprietorship, firm, board, joint venture, association, agency, authority, commission or other business entity or juristic Person, as well as any affiliate, agent, parent including but not limited to counsel, financial advisors, or any other representative.\n\n18. \"Regarding\" means concerning, describing, comprising, referring to, related to, supporting, favoring, opposing, bolstering, detracting from, located in, considered in connection with, bearing on, evidencing, indicating, reporting on, recording, alluding to, responding to, connected with, commenting on, in respect of, about, in relation to, discussing, showing, describing, reflecting, analyzing constituting, and being.\n\n19. \"Relating to,\" \"relate(s) to\" or \"related to,\" when referring to any given subject matter, means, without limitation, any document that constitutes, comprises, involves, contains, embodies, reflects, identifies, states, refers directly or indirectly to, or is in any way relevant to the particular subject matter identified.\n\n20. \"Communication(s)\" means, in the broadest possible sense, and without limitation, any transmittal of information or knowledge (in the form of facts, ideas, inquiries, or otherwise). Communication(s) further refers to all conversations, agreements, inquiries, or replies, whether in person, by telephone, in writing, or by means of electronic transmittal devices, and includes, but is not limited to, all correspondence, emails, recordings, transmittal slips, memoranda, telephone\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 461 of 1063\n\ncommunications, voice messages, telegrams, telefaxes, telecopies, telexes, instant messages, chats, text messages, postings to a message board or group chat, social media posts, tweets, videos uploaded to any video platform, telephonic notes, or notes transmitted internally or with third parties.\n\n21. \"Asset(s)\" means any item of economic value that is subject to possession, custody, or control. Asset includes all real and personal property, including but limited to, real estate, land, houses, apartments, condominiums, automobiles, yachts, boats, planes, jets, helicopters, cash, bank accounts, cryptocurrencies, securities, accounts receivables, inventory, and other tangible and intangible property.\n\n#### **IV. DOCUMENTS TO BE PRODUCED**\n\n1. All Documents and communications regarding the Sherry Netherland Hotel / Condominium, located at 781 Fifth Avenue, New York, NY 10022 (apartments 1801 and 1519; the residential property located at 373 Taconic Rd., Greenwich, Connecticut 06831; the residential property located at 33 Ferncliff Rd., Cos Cob, Connecticut 06807; the residential property located at 354 Nod Hill Rd., Wilton, Connecticut 06897; the property located in at 32 Chateau Ridge Rd., Greenwich, Connecticut 06831; the property located at 110 Clapboard Ridge Rd., Greenwich, Connecticut 06830; the property located at 66 Sherwood Avenue, Greenwich, Connecticut 06831; the property located at 140 Wallacks Drive, Stamford, Connecticut 06902; the property located at 602 Indian Field Drive, Greenwich, Connecticut 06830; and the property located at 11 Hurlingham Drive, Greenwich, Connecticut 06831.\n\n2. All Documents or communications related to any income or Asset of the Debtor, the Debtor's estate, the Debtor's Family, or Associated Entity, including without limitation any real property located in Connecticut.\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 462 of 1063\n\n3. All Documents or communications related to any engagement letter with the Debtor, any member of the Debtor's Family, and/or any Associated Entity, including copy(ies) of such engagement letter(s).\n\n4. All Documents or communications related to the payment of any retainer or commission to You based upon your representation of the Debtor, the Debtor's Family, or an Associated Entity, including documents sufficient to identify the amount of the retainer or commission and its source.\n\n5. All Documents or communications related to any fees, payments, or monies received by You from or on behalf of the Debtor, the Debtor's Family, a Family Related Entity, or an Associated Entity held in escrow or in a client trust account.\n\n6. Documents sufficient to show the amount, date, and source of any payments made to You by, on behalf of, or for the benefit of the Debtor, the Debtor's Family, or an Associated Entity.\n\n7. All Communications between You and, either, the Debtor, the Debtor's Family, or any Associated Individual, agent, employee, or other individual acting on behalf of the Debtor, related to any Transfer, investment, or other transaction or business dealing relating to the Debtor, the Debtor's Estate, the Debtor's Family, or the Associated Entities.\n\n8. All Documents and communications related to any sale, potential sale, acquisition, disposition, purchase, potential purchase, investment, contribution, gift, extension of credit, loan, or Transfer involving the Debtor, the Debtor's Family, or any Associated Entity.\n\n9. All Documents and communications related to the Debtor's use of any Assets belonging to, controlled by, or whose complete or partial ownership is held by the Debtor's Family,\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 463 of 1063\n\nan Associated Entity, or an Associated Individual, including without limitation any real property located in Connecticut.\n\n10. All Documents and communications regarding any balance sheet, bank statement, account statement, financial statement, statement of account, wire transfer instructions and/or confirmation, proof of funds, certificate of deposit, certificate of holdings, investment portfolio summary, or similar document relating to the Debtor, the Debtor's Estate, the Debtor's Family, an Associated Entity, or an Associated Individual, including without limitation all Documents sufficient to show all Transfers to any of the foregoing.\n\nCase 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 464 of 1063\n\n# Exhibit C-25\n\n#### B2540 (Form 2540 – Subpoena for Rule 2004 Examination) (12/15) Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 465 of\n\n1063\n\nUNITED STATES BANKRUPTCY COURT\n\n**District of Connecticut**\n\nIn re HO WAN KWOK, *et al*.,\n\n<sup>1</sup> Case No. 22-50073 (JAM)\n\nDebtor Chapter 11\n\n(Jointly Administered)\n\n# **SUBPOENA FOR RULE 2004 EXAMINATION**\n\n## To: **NRT New England LLC (d/b/a Coldwell Banker Residential Brokerage)**\n\n(*Name of person to whom the subpoena is directed*)\n\n*Testimony:* **YOU ARE COMMANDED** to appear at the time, date, and place set forth below to testify at an examination under Rule 2004, Federal Rules of Bankruptcy Procedure. A copy of the court order authorizing the examination is attached.\n\n| PLACE                    | DATE AND TIME |\n|--------------------------|---------------|\n| Paul Hastings LLP        |               |\n| 200 Park Avenue          | [TBD]         |\n| New York, New York 10166 |               |\n|                          |               |\n\nThe examination will be recorded by this method: **Court reporter/stenographer**\n\n*Production:* You, or your representatives, must also bring with you to the examination the following documents, electronically stored information, or objects, and must permit inspection, copying, testing, or sampling of the material:\n\n#### **See Requests for Production of Documents, attached hereto.**\n\nThe following provisions of Fed. R. Civ. P. 45, made applicable in bankruptcy cases by Fed. R. Bankr. P. 9016, are attached – Rule 45(c), relating to the place of compliance; Rule 45(d), relating to your protection as a person subject to a subpoena; and Rule 45(e) and 45(g), relating to your duty to respond to this subpoena and the potential consequences of not doing so.\n\nDate: **March , 2023**\n\nCLERK OF COURT\n\nOR\n\n*Signature of Clerk or Deputy Clerk Attorney's signature*\n\nThe name, address, email address, and telephone number of the attorney representing Luc A. Despins, Chapter 11 Trustee, who issues or requests this subpoena, are:\n\n**Douglas S. Skalka, Esq.; Neubert, Pepe & Monteith, P.C.; 195 Church Street, New Haven, Connecticut 06510 dskalka@npmlaw.com; (203) 821-2000**\n\n**Notice to the person who issues or requests this subpoena**\n\nIf this subpoena commands the production of documents, electronically stored information, or tangible things, or the inspection of premises before trial, a notice and a copy of this subpoena must be served on each party before it is served on the person to whom it is directed. Fed. R. Civ. P. 45(a)(4).\n\nSoftware Copyright (c) 1996-2022 Best Case, LLC - www.bestcase.com Best Case Bankruptcy 1 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\n#### **PROOF OF SERVICE**\n\n**(This section should not be filed with the court unless required by Fed. R. Civ. P. 45.)**\n\nI received this subpoena for (*name of individual and title, if any*): on (*date*) .\n\nI served the subpoena by delivering a copy to the named person as follows:\n\non *(date)* ; or\n\nI returned the subpoena unexecuted because:\n\nUnless the subpoena was issued on behalf of the United States, or one of its officers or agents, I have also tendered to the witness the fees for one day's attendance, and the mileage allowed by law, in the amount of \\$ .\n\nMy fees are \\$ for travel and \\$ for services, for a total of \\$ .\n\nI declare under penalty of perjury that this information is true and correct.\n\nDate:\n\n*Server's signature*\n\n*Printed name and title*\n\n*Server's address*\n\nAdditional information concerning attempted service, etc.:\n\n#### **Federal Rule of Civil Procedure 45(c), (d), (e), and (g) (Effective 12/1/13) (made applicable in bankruptcy cases by Rule 9016, Federal Rules of Bankruptcy Procedure)**\n\n#### **(c) Place of compliance.**\n\n*(1) For a Trial, Hearing, or Deposition.* A subpoena may command a person to attend a trial, hearing, or deposition only as follows:\n\n(A) within 100 miles of where the person resides, is employed, or regularly transacts business in person; or\n\n(B) within the state where the person resides, is employed, or regularly transacts business in person, if the person\n\n(i) is a party or a party's officer; or\n\n(ii) is commanded to attend a trial and would not incur substantial expense.\n\n*(2) For Other Discovery.* A subpoena may command:\n\n(A) production of documents, or electronically stored information, or things at a place within 100 miles of where the person resides, is employed, or regularly transacts business in person; and\n\n(B) inspection of premises, at the premises to be inspected.\n\n#### **(d) Protecting a Person Subject to a Subpoena; Enforcement.**\n\n*(1) Avoiding Undue Burden or Expense; Sanctions.* A party or attorney responsible for issuing and serving a subpoena must take reasonable steps to avoid imposing undue burden or expense on a person subject to the subpoena. The court for the district where compliance is required must enforce this duty and impose an appropriate sanction which may include lost earnings and reasonable attorney's fees — on a party or attorney who fails to comply.\n\n#### *(2) Command to Produce Materials or Permit Inspection.*\n\n*(A) Appearance Not Required.* A person commanded to produce documents, electronically stored information, or tangible things, or to permit the inspection of premises, need not appear in person at the place of production or inspection unless also commanded to appear for a deposition, hearing, or trial.\n\n*(B) Objections.* A person commanded to produce documents or tangible things or to permit inspection may serve on the party or attorney designated in the subpoena a written objection to inspecting, copying, testing or sampling any or all of the materials or to inspecting the premises — or to producing electronically stored information in the form or forms requested. The objection must be served before the earlier of the time specified for compliance or 14 days after the subpoena is served. If an objection is made, the following rules apply:\n\n(i) At any time, on notice to the commanded person, the serving party may move the court for the district where compliance is required for an order compelling production or inspection.\n\n(ii) These acts may be required only as directed in the order, and the order must protect a person who is neither a party nor a party's officer from significant expense resulting from compliance.\n\n#### *(3) Quashing or Modifying a Subpoena.*\n\n*(A) When Required.* On timely motion, the court for the district where compliance is required must quash or modify a subpoena that:\n\n(i) fails to allow a reasonable time to comply;\n\n(ii) requires a person to comply beyond the geographical limits specified in Rule 45(c);\n\n(iii) requires disclosure of privileged or other protected matter, if no exception or waiver applies; or\n\n(iv) subjects a person to undue burden.\n\n*(B) When Permitted.* To protect a person subject to or affected by a subpoena, the court for the district where compliance is required may, on motion, quash or modify the subpoena if it requires:\n\n(i) disclosing a trade secret or other confidential research, development, or commercial information; or\n\n(ii) disclosing an unretained expert's opinion or information that does not describe specific occurrences in dispute and results from the expert's study that was not requested by a party.\n\n(C) *Specifying Conditions as an Alternative.* In the circumstances described in Rule 45(d)(3)(B), the court may, instead of quashing or modifying a subpoena, order appearance or production under specified conditions if the serving party:\n\n(i) shows a substantial need for the testimony or material that cannot be otherwise met without undue hardship; and\n\n(ii) ensures that the subpoenaed person will be reasonably compensated.\n\n#### **(e) Duties in Responding to a Subpoena.**\n\n*(1) Producing Documents or Electronically Stored Information.* These procedures apply to producing documents or electronically stored information:\n\n*(A) Documents.* A person responding to a subpoena to produce documents must produce them as they are kept in the ordinary course of business or must organize and label them to correspond to the categories in the demand.\n\n*(B) Form for Producing Electronically Stored Information Not Specified.* If a subpoena does not specify a form for producing electronically stored information, the person responding must produce it in a form or forms in which it is ordinarily maintained or in a reasonably usable form or forms.\n\n*(C) Electronically Stored Information Produced in Only One Form.* The person responding need not produce the same electronically stored information in more than one form.\n\n*(D) Inaccessible Electronically Stored Information.* The person responding need not provide discovery of electronically stored information from sources that the person identifies as not reasonably accessible because of undue burden or cost. On motion to compel discovery or for a protective order, the person responding must show that the information is not reasonably accessible because of undue burden or cost. If that showing is made, the court may nonetheless order discovery from such sources if the requesting party shows good cause, considering the limitations of Rule 26(b)(2)(C). The court may specify conditions for the discovery.\n\n#### *(2) Claiming Privilege or Protection.*\n\n*(A) Information Withheld.* A person withholding subpoenaed information under a claim that it is privileged or subject to protection as trial-preparation material must: (i) expressly make the claim; and\n\n(ii) describe the nature of the withheld documents, communications, or tangible things in a manner that, without revealing information itself privileged or protected, will enable the parties to assess the claim.\n\n*(B) Information Produced.* If information produced in response to a subpoena is subject to a claim of privilege or of protection as trial-preparation material, the person making the claim may notify any party that received the information of the claim and the basis for it. After being notified, a party must promptly return, sequester, or destroy the specified information and any copies it has; must not use or disclose the information until the claim is resolved; must take reasonable steps to retrieve the information if the party disclosed it before being notified; and may promptly present the information under seal to the court for the district where compliance is required for a determination of the claim. The person who produced the information must preserve the information until the claim is resolved.\n\n**(g) Contempt.** The court for the district where compliance is required – and also, after a motion is transferred, the issuing court – may hold in contempt a person who, having been served, fails without adequate excuse to obey the subpoena or an order related to it.\n\nFor access to subpoena materials, see Fed.R.Civ.P.45(a) Committee Note (2013)\n\n…\n\n## **Request for Production of Documents**\n\n## **I. INSTRUCTIONS**\n\n1. Unless otherwise indicated, the requests for documents set forth below, (the \"Requests,\" and each, a \"Request\"), must be responded to separately and specifically. Each Request shall be answered fully unless it is in good faith objected to, in which event the reason for Your objection shall be stated in detail, as set forth below. If an objection pertains only to a portion of a Request, or a word, phrase or clause contained within it, You are required to state Your objection to that portion only and to respond to the remainder of the Requests.\n\n2. Electronically stored information must be produced in accordance with the\n\nfollowing instructions:\n\n- a. Images. Black and white images must be 300 DPI Group IV single-page TIFF files. Color images must be produced in JPEG format. File names cannot contain embedded spaces or special characters (including the comma). Folder names cannot contain embedded spaces or special characters (including the comma). All TIFF image files must have a unique file name, i.e. Bates number. Images must be endorsed with sequential Bates numbers in the lower right corner of each image. The number of TIFF files per folder should not exceed 1000 files. Excel spreadsheets should have a placeholder image named by the Bates number of the file.\n- b. Image Load File\n\t- a. Concordance® Data File. The data file (.DAT) contains all of the fielded information that will be loaded into the Concordance® database. The first line of the .DAT file must be a header row identifying the field names. The .DAT file must use the following Concordance® default delimiters: Comma ASCII character (020) Quote þ ASCII character (254). Date fields should be provided in the format: mm/dd/yyyy. Date and time fields must be two separate fields. If documents includes imaged emails and attachments, the attachment fields must be included to preserve the parent/child relationship between an email and its attachments. An OCRPATH field must be included to provide the file path and name of the extracted text file on the produced storage media. The text file must be named after the FIRSTBATES. Do not include the text in the .DAT file. For Documents with native files, a LINK field must be included to provide the file path and\n\nname of the native file. The native file must be named after the FIRSTBATES.\n\n- b. Concordance Image® OR Opticon Cross-Reference File. The image crossreference file (.LOG or .OPT) links the images to the database records. It should be a comma-delimited file consisting of seven fields per line with a line in the cross-reference file for every image in the database with the following format: ImageID,VolumeLabel,ImageFilePath,DocumentBreak,FolderBreak,Box Break,PageCoun.\n- c. Document Text. Text must be produced as separate text files, not as fields within the .DAT file. The full path to the text file (OCRPATH) should be included in the .DAT file. It is recommended document level ANSI text files, named per the FIRSTBATES/Image Key. Extracted text files must be in a separate folder, and the number of text files per folder should not exceed 1,000 files. There should be no special characters (including commas in the folder names). Text files must be provided on a document level.\n- d. Native Production for Certain File Types. File types that reasonably require viewing in their native format for a full understanding of their content and meaning must be produced in native format. These include, but are not limited to, spreadsheets, spreadsheet-like files (Microsoft Excel, comma separated values, tab separated values, etc.), Microsoft PowerPoint or other special presentation files, database files, and audio/visual files. Provide an image of a Bates numbered slip sheet indicating the presence of a native file, and include the path to the native as a field in the .dat file. Name the produced native file with the Bates number corresponding to the slip sheet for the file. Group native files within incrementally named \"NATIVE\" directories, separate from images directories.\n- e. De-duplication. Produce a single copy of each electronic document for which exact duplicates exist. For email messages, consolidate duplicates based on MD5 hash generated from the BCC, Body, CC, From, IntMsgID, To, and Attach properties. For email attachments and standalone electronic files, consolidate duplicates based on MD5 hash of the entire file.\n- f. Metadata. Produce extracted metadata for each document in the form of a Concordance compliant load file (.dat). The first line of the .DAT file must be a header row identifying the field names. The .DAT file must use the following Concordance default delimiters: Comma , ASCII character (020) Quote þ ASCII character (254)\n\nDate fields should be provided in the format: mm/dd/yyyy. Date and time fields must be two separate fields. Required metadata listed below:\n\n# Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 470 of 1063\n\n| Field Name   | Sample Data              | Description                                                                                  |\n|--------------|--------------------------|----------------------------------------------------------------------------------------------|\n| FIRSTBATES   | EDC0000001               | First Bates number of native file document/email                                             |\n| LASTBATES    | EDC0000001               | Last Bates number of native file document/email<br>**The LASTBATES field should be populated |\n|              |                          | for single page                                                                              |\n| ATTACHRANGE  | EDC0000001<br>-          | Bates number of the first page of the parent                                                 |\n|              | EDC0000015               | document to the Bates number of the last page of                                             |\n|              |                          | the last attachment \"child\" document                                                         |\n| BEGATTACH    | EDC0000001               | First Bates number of attachment range                                                       |\n| ENDATTACH    | EDC0000015               | Last Bates number of attachment range                                                        |\n| CUSTODIAN    | Smith, John              | Email: Mailbox where the email resided                                                       |\n|              |                          | Native: Name of the individual or department                                                 |\n|              |                          | from whose files the document<br>originated                                                  |\n| FROM         | John Smith               | Email: Sender                                                                                |\n|              |                          | Native: Author(s) of document                                                                |\n|              |                          | **semi-colon should be used to separate                                                      |\n|              |                          | multiple entries                                                                             |\n| TO           | Coffman, Janice; LeeW    | Recipient(s)                                                                                 |\n|              | [mailto:LeeW@MSN.com]    | **semi-colon should be used to separate multiple                                             |\n|              |                          | entries                                                                                      |\n| CC           | Frank Thompson [mailto:  | Carbon copy recipient(s)                                                                     |\n|              | frank_Thompson@cdt.com]  | **semi-colon should be used to separate                                                      |\n|              |                          | multiple entries                                                                             |\n| BCC          | John Cain                | Blind carbon copy recipient(s)                                                               |\n|              |                          | **semi-colon should be used to separate                                                      |\n|              |                          | multiple entries                                                                             |\n| SUBJECT      | Board Meeting Minutes    | Email: Subject line of the email Native: Title                                               |\n|              |                          | of document (if available)                                                                   |\n| FILE_NAME    | BoardMeetingMinutes.docx | Native: Name of the original native file,                                                    |\n|              |                          | including extension                                                                          |\n| DATE_SENT    | 10/12/2010               | Email: Date the email was sent                                                               |\n|              |                          | Native: (empty)                                                                              |\n| TIME_SENT/   | 07:05 PM GMT             | Email: Time the email was sent/ Time zone in                                                 |\n| TIME_ZONE    |                          | which the emails were standardized                                                           |\n| TIME_ZONE    | GMT                      | The<br>time zone in which<br>the emails<br>were                                              |\n|              |                          | standardized during conversion.                                                              |\n| LINK         |  EDC0000001.msg   | Hyperlink to the email or native file document                                               |\n|              |                          | **The linked file must be named per the                                                      |\n|              |                          | FIRSTBATES number                                                                            |\n| FILE_EXTEN   | MSG                      | The file type extension                                                                      |\n|              |                          | representing                                                                                 |\n|              |                          | the Email or                                                                                 |\n| AUTHOR       | John Smith               | Email: (empty)                                                                               |\n|              |                          | Native: Author of the document                                                               |\n| DATE_CREATED | 10/10/2010               | Email: (empty)                                                                               |\n|              |                          | Native: Date the document was created                                                        |\n\n# Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 471 of 1063\n\n| TIME_CREATED | 10:25 AM                  | Email: (empty)                                  |\n|--------------|---------------------------|-------------------------------------------------|\n|              |                           | Native: Time the document was created           |\n|              |                           | **This data must be a separate field and cannot |\n|              |                           | be combined with the DATE_CREATED field         |\n| DATE_MOD     | 10/12/2010                | Email: (empty)                                  |\n|              |                           | Native: Date the document was last modified     |\n| TIME_MOD     | 07:00 PM                  | Email: (empty)                                  |\n|              |                           | Native: Time the document was last modified     |\n|              |                           | **This data must be a separate field and cannot |\n|              |                           | be combined with the DATE_MOD field             |\n| DATE_ACCESSD | 10/12/2010                | Email: (empty)                                  |\n|              |                           | Native: Date the document was last accessed     |\n| TIME_ACCESSD | 07:00 PM                  | Email: (empty)                                  |\n|              |                           | Native: Time the document was last accessed     |\n|              |                           | **This data must be a separate field and cannot |\n|              |                           | be combined with the DATE_ACCESSD field         |\n| FILE_SIZE    | 5,952                     | Size of native file<br>document/email in KB     |\n| PGCOUNT      | 1                         | Number of pages in native file document/email   |\n| PATH         |   | Email: (empty)                                  |\n|              | Agenda.doc                | Native: Path where native file document was     |\n|              |                           | stored including original file name.            |\n| INTFILEPATH  | Personal Folders\\Deleted  | Email: original location of email including     |\n|              | Items\\Board Meeting       | original file name.                             |\n|              | Minutes.msg               | Native: (empty)                                 |\n| INTMSGID     | <000805c2c71b\\$75977050\\$ | Email: Unique Message ID Native: (empty)        |\n|              | cb8306d1@MSN>             |                                                 |\n| MD5HASH      | d131dd02c5e6eec4693d9a0   | MD5 Hash value of the document.                 |\n|              | 698aff95c                 |                                                 |\n|              | 2fcab58712467eab4004583e  |                                                 |\n|              | b8fb7f89                  |                                                 |\n| OCRPATH      | TEXT/001/EDC0000001.txt   | Path to extracted text of the native file       |\n\n3. Each Request operates and should be construed independently and, unless otherwise indicated, no Request limits the scope of any other Request.\n\n4. All Documents are to be produced as kept in the usual course of business or are to be organized and labeled to correspond with the categories in these Requests.\n\n5. Each Request contained herein extends to all Documents: (a) in Your possession, custody, or control; or (b) in the possession, custody, or control of anyone acting on Your behalf,\n\n#### Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 472 of 1063\n\nincluding Your counsel or other representatives and advisors. Each Document shall be produced in its entirety.\n\n6. If You are requested to produce a Document that is no longer in Your possession, custody, or control, then Your response must (a) describe in detail the nature of the document and its contents; (b) identify the person(s) who prepared or authored the Document (and, if applicable, the Person(s) to whom the Document was sent); (c) identify the date on which the document was prepared or created; (d) state whether such Document (i) is missing or lost, (ii) has been destroyed, (iii) has been transferred, voluntarily or involuntarily, to others, or (iv) was otherwise disposed of; (e) state the reason for, and the facts and circumstances surrounding, such disposition; (f) identify the Persons who authorized such disposition; (g) identify the date or approximate date of such disposition; (h) state when the Document was most recently in Your possession, custody or control; and (i) identify the Person, if any, presently in possession, custody, or control of such Document.\n\n7. If You are requested to produce a Document that has been destroyed, then Your response must state, in addition to the information required by the preceding Instruction: (a) the reason for the Document's destruction; (b) the identity of the Person who destroyed the Document; and (c) the identity of the Person who directed that the Document be destroyed.\n\n8. If You claim that a requested Document is privileged or attorney work-product, then Your response must: (a) state (i) a description of the Document adequate to support Your contention that the Document is privileged, (ii) the title of the Document, (iii) the date of the Document, (iv) the author of the Document, (v) the addressee of the Document, (vi) the identity of each Person who received or saw the original or any draft, copy, or reproduction of the Document, (vii) whether the Document itself, or any information contained or referred to in the Document is in the possession, custody, or control of any other Persons, and if so, the identity of\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 473 of 1063\n\nsuch Persons, as well as a statement addressing how the information came into their possession, (viii) the claim of privilege under which the Document is withheld, and (ix) all of the circumstances upon which You will rely to support such claim of privilege; and (b) produce a privilege log containing all of the information requested in Part (a) of this Instruction for each Document withheld on the basis of a claim of privilege in accordance with D. Conn. L. Civ. R. 26(e). For any part of a Document Request as to which a claim of privilege or work product is not made, responsive documents should be provided in full.\n\n9. If a portion of an otherwise responsive Document contains information subject to a claim of privilege, only that portion of the Document subject to the claim of privilege shall be deleted or redacted from the Document following the instructions above, and the rest shall be produced.\n\n10. The Requests are continuing in nature. You are hereby instructed to (a) supplement or correct any responses later learned to be incomplete or incorrect immediately upon learning that a prior response was incomplete or incorrect; and (b) produce any additional Documents that are called for under the\n\n11. If a Document is in a language other than English, You should provide that Document. If a Document is in a language other than English, and an English translation exists, You should provide both Documents.\n\n12. All references to Entities includes all affiliates thereof.\n\n13. All references to individual names include all alternative names, aliased, or nicknames.\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 474 of 1063\n\n14. Unless otherwise expressly indicated, the period of time covered by the Document Requests is the period from February 5, 2015 to the date responses to the Document Requests are due.\n\n#### **II. RULES OF CONSTRUCTION**\n\n15. The use of (a) any singular noun shall be construed to include the plural, and vice versa, and (b) a verb in any tense shall be construed as the use of the verb in all other tenses.\n\n16. The terms (a) \"and\" and \"or\" shall be construed either conjunctively or disjunctively as necessary to bring within the scope of any request all responses that might otherwise be construed to be outside of its scope, and (b) \"each\" and \"any\" shall be deemed to include and encompass the words \"every\" and \"all.\"\n\n## **III. DEFINITIONS**\n\nThe definitions supplied by D. Conn. L. Civ. R. 26(c) and the rules of construction supplied by D. Conn. L. Civ. R. 26(d), as incorporated by D. Conn. Bankr. L.R. 2004-1(a), shall apply to the Document Requests. In addition, the following terms used in these Document Requests shall have the following meanings:\n\n1. \"You\" or \"Your\" or \"Yourself\" means and refers to NRT New England LLC, together with all of its affiliates, divisions, agencies, instrumentalities, departments, offices, partners, officers, directors, agents, attorneys, representatives, employees, and/or anyone acting on its behalf.\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 475 of 1063\n\n2. \"Debtor\" means Ho Wan Kwok (a/k/a Miles Kwok, Miles Guo, Guo Wengui, Guo Haoyun, 郭文贵, or any other alias), together with his employees, agents, counsel, advisors, or anyone acting on his behalf.\n\n3. \"Debtor's Son\" means Qiang Guo (a/k/a Mileson Kwok, 郭强, or any other alias), together with his employees, agents, counsel, advisors, or anyone acting on his behalf.\n\n4. \"Debtor's Daughter\" means Mei Guo (a/k/a Mei Gui, 郭美, or any other alias), together with her employees, agents, counsel, advisors, or anyone acting on her behalf.\n\n5. \"Debtor's Purported Wife\" means Hing Chi Ngok (a/k/a Hing Chi Ng, Yue Qingzhi, 岳庆芝, or any other alias), together with her employees, agents, counsel, advisors, or anyone acting on her behalf.\n\n6. \"Debtor's Family\" means, collectively, the Debtor, the Debtor's Son, the Debtor's Daughter, and the Debtor's Purported Wife, and any other familial relation to the Debtor.\n\n7. \"Associated Individuals\" means, individually and collectively, all individuals that (1) hold, control, have custody over, or discretion over assets owned, controlled, or enjoyed by the Debtor or the Debtor's Family; or (2) have been employees, directors, or otherwise are affiliated with one or more Associated Entities, together with the respective employees, agents, counsel, advisors, or anyone acting on behalf of any of the foregoing. Such Associated Individuals shall include, but are not limited to: Daniel Podhaskie, Karin Maistrello, Melissa Francis, Anthony DiBattista, Han Chunguang (a/k/a 韩春光), Qu Guojiao (a/k/a Qu Guo Jiao, 屈国姣), Zhang Wei (a/k/a 张伟\\*), Lihong Wei Lafrenz (a/k/a Sara Wei, 魏丽红Max Krasner, Yvette Wang (a/k/a Yanping Wang, Yan Ping Wang, 王雁平), Fiona Yu, and Je Kin Ming (a/k/a William Je, Yu Jianming, 余建明).\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 476 of 1063\n\n8. \"Associated Entities\" means, individually and collectively, all organizations or Entities of any type that (1) have been owned, controlled, or invested in by the Debtor or the Debtor's Family; or (2) have an interest, whether directly or indirectly, in any assets owned, controlled, or enjoyed by the Debtor or the Debtor's Family, together with the respective employees, agents, counsel, advisors, or anyone acting on behalf of any of the foregoing. Such Associated Entities shall include, but are not limited to: 7 Nod Hill LLC, ACA Investment Management Limited, ACA Capital Group Limited, Ace Decade Holdings Limited, AI Group Holdings Inc., Booming Sail New York LLC, Bravo Luck Limited, China Golden Spring (Hong Kong) Limited, Crane Advisory Group LLC, Dawn State Limited, Eastern Profit Corporation Limited, Freedom Media Ventures Ltd., G Club Operations LLC, G Fashion LLC, G News LLC, GETTR USA, Genever Holdings Corporation, Genever Holdings LLC, Gfashion Media Group Inc., GFNY, Inc., Golden Spring (New York) Ltd., Greenwich Land LLC, GTV Media Group, Inc., Hamilton Capital Holdings Inc., HCHK Property Management, Inc., HCHK Technologies, Inc., Himalaya Embassy, Himalaya Exchange, Himalaya Federal Reserve, Himalaya Investment LLC, Himalaya International, Himalaya New World Inc., Himalaya Supervisory Organization, Himalaya Ventures LLC, HK International Funds Investments (USA) Limited LLC, Hong Kong International Funds Investments Limited, Hudson Diamond Holding, Infinity Treasury Management Inc., Lexington Property and Staffing, Long Gate Limited, Maywind Trading LLC, MOS Himalaya LLC, New Federal State of China (a/k/a NFSC), Rule of Law Foundation III, Inc., Rule of Law Foundation IV, Inc., Rule of Law Fund, Rule of Law Society, Rule of Law Society IV, Inc., G-Translators PTY LTD, Saraca Media Group, Inc., Well Origin Ltd., Whitecroft Shore Limited, and ZIBA Limited.\n\n9. \"Including\" or any variant thereof means \"including without limitation.\"\n\n#### Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 477 of 1063\n\n10. \"And\" and \"or\" mean \"and/or,\" and shall be construed both conjunctively as well as disjunctively in order to maximize their scope.\n\n11. \"Any\" and \"all\" and \"each\" mean \"each and every.\"\n\n12. \"Each\" and \"every\" mean \"each and every.\"\n\n13. \"Third Party\" means a Person or Entity other than Yourself.\n\n14. \"Transfer\" shall have the meaning given to it by section 101(54) of the Bankruptcy Code.\n\n15. \"Document\" means any information or thing within the scope of Fed. R. Civ. P. 34, and includes, without limitation, each and every written, recorded, or graphic matter of any kind, type, nature, or description that is or has been in Your possession, custody or control, including all printed and electronic copies of electronic mail, computer files maintained in electronic form, correspondence, memoranda, tapes, stenographic or handwritten notes, written forms of any kind, charts, blueprints, drawings, sketches, graphs, plans, articles, specifications, diaries, letters, telegrams, photographs, minutes, contracts, agreements, surveys, computer printouts, data compilations of any kind, telexes, facsimiles, emails, text messages, instant messages, voice messages, invoices, order forms, checks, drafts, statements, credit memos, reports, position reports, summaries, indices, books, ledgers, notebooks, schedules, transparencies, recordings, catalogs, advertisements, promotional materials, films, video tapes, audio tapes, CDs, computer disks, brochures, pamphlets, punch-cards, time-slips, Tweets, social media posts, or any written or recorded materials of any other kind, and all meta-data thereof, however stored (whether in tangible or electronic form), recorded, produced, or reproduced, and also including but not limited to, drafts or copies of any of the foregoing that contain any notes, comments, or markings of any\n\n#### Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 478 of 1063\n\nkind not found on the original documents or that are otherwise not identical to the original documents.\n\n16. \"Person(s)\" means an individual, corporation, proprietorship, partnership, association, or any other Entity. \"Person\" also includes any agent, representatives, or expert, including but not limiting to, attorneys or financial advisors.\n\n17. \"Entity\" means any natural Person, corporation, partnership, subsidiary, sole proprietorship, firm, board, joint venture, association, agency, authority, commission or other business entity or juristic Person, as well as any affiliate, agent, parent including but not limited to counsel, financial advisors, or any other representative.\n\n18. \"Regarding\" means concerning, describing, comprising, referring to, related to, supporting, favoring, opposing, bolstering, detracting from, located in, considered in connection with, bearing on, evidencing, indicating, reporting on, recording, alluding to, responding to, connected with, commenting on, in respect of, about, in relation to, discussing, showing, describing, reflecting, analyzing constituting, and being.\n\n19. \"Relating to,\" \"relate(s) to\" or \"related to,\" when referring to any given subject matter, means, without limitation, any document that constitutes, comprises, involves, contains, embodies, reflects, identifies, states, refers directly or indirectly to, or is in any way relevant to the particular subject matter identified.\n\n20. \"Communication(s)\" means, in the broadest possible sense, and without limitation, any transmittal of information or knowledge (in the form of facts, ideas, inquiries, or otherwise). Communication(s) further refers to all conversations, agreements, inquiries, or replies, whether in person, by telephone, in writing, or by means of electronic transmittal devices, and includes, but is not limited to, all correspondence, emails, recordings, transmittal slips, memoranda, telephone\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 479 of 1063\n\ncommunications, voice messages, telegrams, telefaxes, telecopies, telexes, instant messages, chats, text messages, postings to a message board or group chat, social media posts, tweets, videos uploaded to any video platform, telephonic notes, or notes transmitted internally or with third parties.\n\n21. \"Asset(s)\" means any item of economic value that is subject to possession, custody, or control. Asset includes all real and personal property, including but limited to, real estate, land, houses, apartments, condominiums, automobiles, yachts, boats, planes, jets, helicopters, cash, bank accounts, cryptocurrencies, securities, accounts receivables, inventory, and other tangible and intangible property.\n\n#### **IV. DOCUMENTS TO BE PRODUCED**\n\n1. All Documents and communications regarding the Sherry Netherland Hotel / Condominium, located at 781 Fifth Avenue, New York, NY 10022 (apartments 1801 and 1519; the residential property located at 373 Taconic Rd., Greenwich, Connecticut 06831; the residential property located at 33 Ferncliff Rd., Cos Cob, Connecticut 06807; the residential property located at 354 Nod Hill Rd., Wilton, Connecticut 06897; the property located in at 32 Chateau Ridge Rd., Greenwich, Connecticut 06831; the property located at 110 Clapboard Ridge Rd., Greenwich, Connecticut 06830; the property located at 66 Sherwood Avenue, Greenwich, Connecticut 06831; the property located at 140 Wallacks Drive, Stamford, Connecticut 06902; the property located at 602 Indian Field Drive, Greenwich, Connecticut 06830; and the property located at 11 Hurlingham Drive, Greenwich, Connecticut 06831.\n\n2. All Documents or communications related to any income or Asset of the Debtor, the Debtor's estate, the Debtor's Family, or Associated Entity, including without limitation any real property located in Connecticut.\n\n#### Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 480 of 1063\n\n3. All Documents or communications related to any engagement letter with the Debtor, any member of the Debtor's Family, and/or any Associated Entity, including copy(ies) of such engagement letter(s).\n\n4. All Documents or communications related to the payment of any retainer or commission to You based upon your representation of the Debtor, the Debtor's Family, or an Associated Entity, including documents sufficient to identify the amount of the retainer or commission and its source.\n\n5. All Documents or communications related to any fees, payments, or monies received by You from or on behalf of the Debtor, the Debtor's Family, a Family Related Entity, or an Associated Entity held in escrow or in a client trust account.\n\n6. Documents sufficient to show the amount, date, and source of any payments made to You by, on behalf of, or for the benefit of the Debtor, the Debtor's Family, or an Associated Entity.\n\n7. All Communications between You and, either, the Debtor, the Debtor's Family, or any Associated Individual, agent, employee, or other individual acting on behalf of the Debtor, related to any Transfer, investment, or other transaction or business dealing relating to the Debtor, the Debtor's Estate, the Debtor's Family, or the Associated Entities.\n\n8. All Documents and communications related to any sale, potential sale, acquisition, disposition, purchase, potential purchase, investment, contribution, gift, extension of credit, loan, or Transfer involving the Debtor, the Debtor's Family, or any Associated Entity.\n\n9. All Documents and communications related to the Debtor's use of any Assets belonging to, controlled by, or whose complete or partial ownership is held by the Debtor's Family,\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 481 of 1063\n\nan Associated Entity, or an Associated Individual, including without limitation any real property located in Connecticut.\n\n10. All Documents and communications regarding any balance sheet, bank statement, account statement, financial statement, statement of account, wire transfer instructions and/or confirmation, proof of funds, certificate of deposit, certificate of holdings, investment portfolio summary, or similar document relating to the Debtor, the Debtor's Estate, the Debtor's Family, an Associated Entity, or an Associated Individual, including without limitation all Documents sufficient to show all Transfers to any of the foregoing.\n\nCase 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 482 of 1063\n\n# Exhibit C-26\n\n#### B2540 (Form 2540 – Subpoena for Rule 2004 Examination) (12/15) Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 483 of\n\n1063\n\nUNITED STATES BANKRUPTCY COURT\n\n**District of Connecticut**\n\nIn re HO WAN KWOK, *et al*.,\n\n<sup>1</sup> Case No. 22-50073 (JAM) Debtor Chapter 11\n\n(Jointly Administered)\n\n# **SUBPOENA FOR RULE 2004 EXAMINATION**\n\nTo: **David Fallon**\n\n(*Name of person to whom the subpoena is directed*)\n\n*Testimony:* **YOU ARE COMMANDED** to appear at the time, date, and place set forth below to testify at an examination under Rule 2004, Federal Rules of Bankruptcy Procedure. A copy of the court order authorizing the examination is attached.\n\n| PLACE                    | DATE AND TIME |\n|--------------------------|---------------|\n| Paul Hastings LLP        |               |\n| 200 Park Avenue          | [TBD]         |\n| New York, New York 10166 |               |\n|                          |               |\n\nThe examination will be recorded by this method: **Court reporter/stenographer**\n\n*Production:* You, or your representatives, must also bring with you to the examination the following documents, electronically stored information, or objects, and must permit inspection, copying, testing, or sampling of the material:\n\n#### **See Requests for Production of Documents, attached hereto.**\n\nThe following provisions of Fed. R. Civ. P. 45, made applicable in bankruptcy cases by Fed. R. Bankr. P. 9016, are attached – Rule 45(c), relating to the place of compliance; Rule 45(d), relating to your protection as a person subject to a subpoena; and Rule 45(e) and 45(g), relating to your duty to respond to this subpoena and the potential consequences of not doing so.\n\nDate: **March , 2023**\n\nCLERK OF COURT\n\nOR\n\n*Signature of Clerk or Deputy Clerk Attorney's signature*\n\nThe name, address, email address, and telephone number of the attorney representing Luc A. Despins, Chapter 11 Trustee, who issues or requests this subpoena, are:\n\n**Douglas S. Skalka, Esq.; Neubert, Pepe & Monteith, P.C.; 195 Church Street, New Haven, Connecticut 06510 dskalka@npmlaw.com; (203) 821-2000**\n\n**Notice to the person who issues or requests this subpoena**\n\nIf this subpoena commands the production of documents, electronically stored information, or tangible things, or the inspection of premises before trial, a notice and a copy of this subpoena must be served on each party before it is served on the person to whom it is directed. Fed. R. Civ. P. 45(a)(4).\n\nSoftware Copyright (c) 1996-2022 Best Case, LLC - www.bestcase.com Best Case Bankruptcy 1 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\n#### **PROOF OF SERVICE**\n\n**(This section should not be filed with the court unless required by Fed. R. Civ. P. 45.)**\n\nI received this subpoena for (*name of individual and title, if any*): on (*date*) .\n\nI served the subpoena by delivering a copy to the named person as follows:\n\non *(date)* ; or\n\nI returned the subpoena unexecuted because:\n\nUnless the subpoena was issued on behalf of the United States, or one of its officers or agents, I have also tendered to the witness the fees for one day's attendance, and the mileage allowed by law, in the amount of \\$ .\n\nMy fees are \\$ for travel and \\$ for services, for a total of \\$ .\n\nI declare under penalty of perjury that this information is true and correct.\n\nDate:\n\n*Server's signature*\n\n*Printed name and title*\n\n*Server's address*\n\nAdditional information concerning attempted service, etc.:\n\n#### **Federal Rule of Civil Procedure 45(c), (d), (e), and (g) (Effective 12/1/13) (made applicable in bankruptcy cases by Rule 9016, Federal Rules of Bankruptcy Procedure)**\n\n#### **(c) Place of compliance.**\n\n*(1) For a Trial, Hearing, or Deposition.* A subpoena may command a person to attend a trial, hearing, or deposition only as follows:\n\n(A) within 100 miles of where the person resides, is employed, or regularly transacts business in person; or\n\n(B) within the state where the person resides, is employed, or regularly transacts business in person, if the person\n\n(i) is a party or a party's officer; or\n\n(ii) is commanded to attend a trial and would not incur substantial expense.\n\n*(2) For Other Discovery.* A subpoena may command:\n\n(A) production of documents, or electronically stored information, or things at a place within 100 miles of where the person resides, is employed, or regularly transacts business in person; and\n\n(B) inspection of premises, at the premises to be inspected.\n\n#### **(d) Protecting a Person Subject to a Subpoena; Enforcement.**\n\n*(1) Avoiding Undue Burden or Expense; Sanctions.* A party or attorney responsible for issuing and serving a subpoena must take reasonable steps to avoid imposing undue burden or expense on a person subject to the subpoena. The court for the district where compliance is required must enforce this duty and impose an appropriate sanction which may include lost earnings and reasonable attorney's fees — on a party or attorney who fails to comply.\n\n#### *(2) Command to Produce Materials or Permit Inspection.*\n\n*(A) Appearance Not Required.* A person commanded to produce documents, electronically stored information, or tangible things, or to permit the inspection of premises, need not appear in person at the place of production or inspection unless also commanded to appear for a deposition, hearing, or trial.\n\n*(B) Objections.* A person commanded to produce documents or tangible things or to permit inspection may serve on the party or attorney designated in the subpoena a written objection to inspecting, copying, testing or sampling any or all of the materials or to inspecting the premises — or to producing electronically stored information in the form or forms requested. The objection must be served before the earlier of the time specified for compliance or 14 days after the subpoena is served. If an objection is made, the following rules apply:\n\n(i) At any time, on notice to the commanded person, the serving party may move the court for the district where compliance is required for an order compelling production or inspection.\n\n(ii) These acts may be required only as directed in the order, and the order must protect a person who is neither a party nor a party's officer from significant expense resulting from compliance.\n\n#### *(3) Quashing or Modifying a Subpoena.*\n\n*(A) When Required.* On timely motion, the court for the district where compliance is required must quash or modify a subpoena that:\n\n(i) fails to allow a reasonable time to comply;\n\n(ii) requires a person to comply beyond the geographical limits specified in Rule 45(c);\n\n(iii) requires disclosure of privileged or other protected matter, if no exception or waiver applies; or\n\n(iv) subjects a person to undue burden.\n\n*(B) When Permitted.* To protect a person subject to or affected by a subpoena, the court for the district where compliance is required may, on motion, quash or modify the subpoena if it requires:\n\n(i) disclosing a trade secret or other confidential research, development, or commercial information; or\n\n(ii) disclosing an unretained expert's opinion or information that does not describe specific occurrences in dispute and results from the expert's study that was not requested by a party.\n\n(C) *Specifying Conditions as an Alternative.* In the circumstances described in Rule 45(d)(3)(B), the court may, instead of quashing or modifying a subpoena, order appearance or production under specified conditions if the serving party:\n\n(i) shows a substantial need for the testimony or material that cannot be otherwise met without undue hardship; and\n\n(ii) ensures that the subpoenaed person will be reasonably compensated.\n\n#### **(e) Duties in Responding to a Subpoena.**\n\n*(1) Producing Documents or Electronically Stored Information.* These procedures apply to producing documents or electronically stored information:\n\n*(A) Documents.* A person responding to a subpoena to produce documents must produce them as they are kept in the ordinary course of business or must organize and label them to correspond to the categories in the demand.\n\n*(B) Form for Producing Electronically Stored Information Not Specified.* If a subpoena does not specify a form for producing electronically stored information, the person responding must produce it in a form or forms in which it is ordinarily maintained or in a reasonably usable form or forms.\n\n*(C) Electronically Stored Information Produced in Only One Form.* The person responding need not produce the same electronically stored information in more than one form.\n\n*(D) Inaccessible Electronically Stored Information.* The person responding need not provide discovery of electronically stored information from sources that the person identifies as not reasonably accessible because of undue burden or cost. On motion to compel discovery or for a protective order, the person responding must show that the information is not reasonably accessible because of undue burden or cost. If that showing is made, the court may nonetheless order discovery from such sources if the requesting party shows good cause, considering the limitations of Rule 26(b)(2)(C). The court may specify conditions for the discovery.\n\n#### *(2) Claiming Privilege or Protection.*\n\n*(A) Information Withheld.* A person withholding subpoenaed information under a claim that it is privileged or subject to protection as trial-preparation material must: (i) expressly make the claim; and\n\n(ii) describe the nature of the withheld documents, communications, or tangible things in a manner that, without revealing information itself privileged or protected, will enable the parties to assess the claim.\n\n*(B) Information Produced.* If information produced in response to a subpoena is subject to a claim of privilege or of protection as trial-preparation material, the person making the claim may notify any party that received the information of the claim and the basis for it. After being notified, a party must promptly return, sequester, or destroy the specified information and any copies it has; must not use or disclose the information until the claim is resolved; must take reasonable steps to retrieve the information if the party disclosed it before being notified; and may promptly present the information under seal to the court for the district where compliance is required for a determination of the claim. The person who produced the information must preserve the information until the claim is resolved.\n\n**(g) Contempt.** The court for the district where compliance is required – and also, after a motion is transferred, the issuing court – may hold in contempt a person who, having been served, fails without adequate excuse to obey the subpoena or an order related to it.\n\nFor access to subpoena materials, see Fed.R.Civ.P.45(a) Committee Note (2013)\n\n…\n\n## **Requests for Production of Documents**\n\n## **I. INSTRUCTIONS**\n\n1. Unless otherwise indicated, the requests for documents set forth below, (the \"Requests,\" and each, a \"Request\"), must be responded to separately and specifically. Each Request shall be answered fully unless it is in good faith objected to, in which event the reason for Your objection shall be stated in detail, as set forth below. If an objection pertains only to a portion of a Request, or a word, phrase or clause contained within it, You are required to state Your objection to that portion only and to respond to the remainder of the Requests.\n\n2. Electronically stored information must be produced in accordance with the\n\nfollowing instructions:\n\n- a. Images. Black and white images must be 300 DPI Group IV single-page TIFF files. Color images must be produced in JPEG format. File names cannot contain embedded spaces or special characters (including the comma). Folder names cannot contain embedded spaces or special characters (including the comma). All TIFF image files must have a unique file name, i.e. Bates number. Images must be endorsed with sequential Bates numbers in the lower right corner of each image. The number of TIFF files per folder should not exceed 1000 files. Excel spreadsheets should have a placeholder image named by the Bates number of the file.\n- b. Image Load File\n\t- a. Concordance® Data File. The data file (.DAT) contains all of the fielded information that will be loaded into the Concordance® database. The first line of the .DAT file must be a header row identifying the field names. The .DAT file must use the following Concordance® default delimiters: Comma ASCII character (020) Quote þ ASCII character (254). Date fields should be provided in the format: mm/dd/yyyy. Date and time fields must be two separate fields. If documents includes imaged emails and attachments, the attachment fields must be included to preserve the parent/child relationship between an email and its attachments. An OCRPATH field must be included to provide the file path and name of the extracted text file on the produced storage media. The text file must be named after the FIRSTBATES. Do not include the text in the .DAT file. For Documents with native files, a LINK field must be included to provide the file path and\n\nname of the native file. The native file must be named after the FIRSTBATES.\n\n- b. Concordance Image® OR Opticon Cross-Reference File. The image crossreference file (.LOG or .OPT) links the images to the database records. It should be a comma-delimited file consisting of seven fields per line with a line in the cross-reference file for every image in the database with the following format: ImageID,VolumeLabel,ImageFilePath,DocumentBreak,FolderBreak,Box Break,PageCoun.\n- c. Document Text. Text must be produced as separate text files, not as fields within the .DAT file. The full path to the text file (OCRPATH) should be included in the .DAT file. It is recommended document level ANSI text files, named per the FIRSTBATES/Image Key. Extracted text files must be in a separate folder, and the number of text files per folder should not exceed 1,000 files. There should be no special characters (including commas in the folder names). Text files must be provided on a document level.\n- d. Native Production for Certain File Types. File types that reasonably require viewing in their native format for a full understanding of their content and meaning must be produced in native format. These include, but are not limited to, spreadsheets, spreadsheet-like files (Microsoft Excel, comma separated values, tab separated values, etc.), Microsoft PowerPoint or other special presentation files, database files, and audio/visual files. Provide an image of a Bates numbered slip sheet indicating the presence of a native file, and include the path to the native as a field in the .dat file. Name the produced native file with the Bates number corresponding to the slip sheet for the file. Group native files within incrementally named \"NATIVE\" directories, separate from images directories.\n- e. De-duplication. Produce a single copy of each electronic document for which exact duplicates exist. For email messages, consolidate duplicates based on MD5 hash generated from the BCC, Body, CC, From, IntMsgID, To, and Attach properties. For email attachments and standalone electronic files, consolidate duplicates based on MD5 hash of the entire file.\n- f. Metadata. Produce extracted metadata for each document in the form of a Concordance compliant load file (.dat). The first line of the .DAT file must be a header row identifying the field names. The .DAT file must use the following Concordance default delimiters: Comma , ASCII character (020) Quote þ ASCII character (254)\n\nDate fields should be provided in the format: mm/dd/yyyy. Date and time fields must be two separate fields. Required metadata listed below:\n\n# Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 488 of 1063\n\n| Field Name   | Sample Data              | Description                                      |\n|--------------|--------------------------|--------------------------------------------------|\n| FIRSTBATES   | EDC0000001               | First Bates number of native file document/email |\n| LASTBATES    | EDC0000001               | Last Bates number of native file document/email  |\n|              |                          | **The LASTBATES field should be populated        |\n|              |                          | for single page                                  |\n| ATTACHRANGE  | EDC0000001<br>-          | Bates number of the first page of the parent     |\n|              | EDC0000015               | document to the Bates number of the last page of |\n|              |                          | the last attachment \"child\" document             |\n| BEGATTACH    | EDC0000001               | First Bates number of attachment range           |\n| ENDATTACH    | EDC0000015               | Last Bates number of attachment range            |\n| CUSTODIAN    | Smith, John              | Email: Mailbox where the email resided           |\n|              |                          | Native: Name of the individual or department     |\n|              |                          | from whose files the document<br>originated      |\n| FROM         | John Smith               | Email: Sender                                    |\n|              |                          | Native: Author(s) of document                    |\n|              |                          | **semi-colon should be used to separate          |\n|              |                          | multiple entries                                 |\n| TO           | Coffman, Janice; LeeW    | Recipient(s)                                     |\n|              | [mailto:LeeW@MSN.com]    | **semi-colon should be used to separate multiple |\n|              |                          | entries                                          |\n| CC           | Frank Thompson [mailto:  | Carbon copy recipient(s)                         |\n|              | frank_Thompson@cdt.com]  | **semi-colon should be used to separate          |\n|              |                          | multiple entries                                 |\n| BCC          | John Cain                | Blind carbon copy recipient(s)                   |\n|              |                          | **semi-colon should be used to separate          |\n|              |                          | multiple entries                                 |\n| SUBJECT      | Board Meeting Minutes    | Email: Subject line of the email Native: Title   |\n|              |                          | of document (if available)                       |\n| FILE_NAME    | BoardMeetingMinutes.docx | Native: Name of the original native file,        |\n|              |                          | including extension                              |\n| DATE_SENT    | 10/12/2010               | Email: Date the email was sent                   |\n|              |                          | Native: (empty)                                  |\n| TIME_SENT/   | 07:05 PM GMT             | Email: Time the email was sent/ Time zone in     |\n| TIME_ZONE    |                          | which the emails were standardized               |\n| TIME_ZONE    | GMT                      | The<br>time zone in which<br>the emails<br>were  |\n|              |                          | standardized during conversion.                  |\n| LINK         |  EDC0000001.msg   | Hyperlink to the email or native file document   |\n|              |                          | **The linked file must be named per the          |\n|              |                          | FIRSTBATES number                                |\n| FILE_EXTEN   | MSG                      | The file type extension                          |\n|              |                          | representing                                     |\n|              |                          | the Email or                                     |\n| AUTHOR       | John Smith               | Email: (empty)                                   |\n|              |                          | Native: Author of the document                   |\n| DATE_CREATED | 10/10/2010               | Email: (empty)                                   |\n|              |                          | Native: Date the document was created            |\n\n# Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 489 of 1063\n\n| TIME_CREATED | 10:25 AM                  | Email: (empty)                                  |\n|--------------|---------------------------|-------------------------------------------------|\n|              |                           | Native: Time the document was created           |\n|              |                           | **This data must be a separate field and cannot |\n|              |                           | be combined with the DATE_CREATED field         |\n| DATE_MOD     | 10/12/2010                | Email: (empty)                                  |\n|              |                           | Native: Date the document was last modified     |\n| TIME_MOD     | 07:00 PM                  | Email: (empty)                                  |\n|              |                           | Native: Time the document was last modified     |\n|              |                           | **This data must be a separate field and cannot |\n|              |                           | be combined with the DATE_MOD field             |\n| DATE_ACCESSD | 10/12/2010                | Email: (empty)                                  |\n|              |                           | Native: Date the document was last accessed     |\n| TIME_ACCESSD | 07:00 PM                  | Email: (empty)                                  |\n|              |                           | Native: Time the document was last accessed     |\n|              |                           | **This data must be a separate field and cannot |\n|              |                           | be combined with the DATE_ACCESSD field         |\n| FILE_SIZE    | 5,952                     | Size of native file<br>document/email in KB     |\n| PGCOUNT      | 1                         | Number of pages in native file document/email   |\n| PATH         |   | Email: (empty)                                  |\n|              | Agenda.doc                | Native: Path where native file document was     |\n|              |                           | stored including original file name.            |\n| INTFILEPATH  | Personal Folders\\Deleted  | Email: original location of email including     |\n|              | Items\\Board Meeting       | original file name.                             |\n|              | Minutes.msg               | Native: (empty)                                 |\n| INTMSGID     | <000805c2c71b\\$75977050\\$ | Email: Unique Message ID Native: (empty)        |\n|              | cb8306d1@MSN>             |                                                 |\n| MD5HASH      | d131dd02c5e6eec4693d9a0   | MD5 Hash value of the document.                 |\n|              | 698aff95c                 |                                                 |\n|              | 2fcab58712467eab4004583e  |                                                 |\n|              | b8fb7f89                  |                                                 |\n| OCRPATH      | TEXT/001/EDC0000001.txt   | Path to extracted text of the native file       |\n\n3. Each Request operates and should be construed independently and, unless otherwise indicated, no Request limits the scope of any other Request.\n\n4. All Documents are to be produced as kept in the usual course of business or are to be organized and labeled to correspond with the categories in these Requests.\n\n5. Each Request contained herein extends to all Documents: (a) in Your possession, custody, or control; or (b) in the possession, custody, or control of anyone acting on Your behalf,\n\n#### Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 490 of 1063\n\nincluding Your counsel or other representatives and advisors. Each Document shall be produced in its entirety.\n\n6. If You are requested to produce a Document that is no longer in Your possession, custody, or control, then Your response must (a) describe in detail the nature of the document and its contents; (b) identify the person(s) who prepared or authored the Document (and, if applicable, the Person(s) to whom the Document was sent); (c) identify the date on which the document was prepared or created; (d) state whether such Document (i) is missing or lost, (ii) has been destroyed, (iii) has been transferred, voluntarily or involuntarily, to others, or (iv) was otherwise disposed of; (e) state the reason for, and the facts and circumstances surrounding, such disposition; (f) identify the Persons who authorized such disposition; (g) identify the date or approximate date of such disposition; (h) state when the Document was most recently in Your possession, custody or control; and (i) identify the Person, if any, presently in possession, custody, or control of such Document.\n\n7. If You are requested to produce a Document that has been destroyed, then Your response must state, in addition to the information required by the preceding Instruction: (a) the reason for the Document's destruction; (b) the identity of the Person who destroyed the Document; and (c) the identity of the Person who directed that the Document be destroyed.\n\n8. If You claim that a requested Document is privileged or attorney work-product, then Your response must: (a) state (i) a description of the Document adequate to support Your contention that the Document is privileged, (ii) the title of the Document, (iii) the date of the Document, (iv) the author of the Document, (v) the addressee of the Document, (vi) the identity of each Person who received or saw the original or any draft, copy, or reproduction of the Document, (vii) whether the Document itself, or any information contained or referred to in the Document is in the possession, custody, or control of any other Persons, and if so, the identity of\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 491 of 1063\n\nsuch Persons, as well as a statement addressing how the information came into their possession, (viii) the claim of privilege under which the Document is withheld, and (ix) all of the circumstances upon which You will rely to support such claim of privilege; and (b) produce a privilege log containing all of the information requested in Part (a) of this Instruction for each Document withheld on the basis of a claim of privilege in accordance with D. Conn. L. Civ. R. 26(e).\n\n9. If a portion of an otherwise responsive Document contains information subject to a claim of privilege, only that portion of the Document subject to the claim of privilege shall be deleted or redacted from the Document following the instructions above, and the rest shall be produced.\n\n10. The Requests are continuing in nature. You are hereby instructed to (a) supplement or correct any responses later learned to be incomplete or incorrect immediately upon learning that a prior response was incomplete or incorrect; and (b) produce any additional Documents that are called for under the\n\n11. If a Document is in a language other than English, You should provide that Document. If a Document is in a language other than English, and an English translation exists, You should provide both Documents.\n\n12. All references to Entities includes all affiliates thereof.\n\n13. All references to individual names include all alternative names, aliased, or nicknames.\n\n14. Unless otherwise expressly indicated, the period of time covered by the Document Requests is the period from February 5, 2012 to the date responses to the Document Requests are due.\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 492 of 1063\n\n#### **II. RULES OF CONSTRUCTION**\n\n15. The use of (a) any singular noun shall be construed to include the plural, and vice versa, and (b) a verb in any tense shall be construed as the use of the verb in all other tenses.\n\n16. The terms (a) \"and\" and \"or\" shall be construed either conjunctively or disjunctively as necessary to bring within the scope of any request all responses that might otherwise be construed to be outside of its scope, and (b) \"each\" and \"any\" shall be deemed to include and encompass the words \"every\" and \"all.\"\n\n#### **III. DEFINITIONS**\n\nThe definitions supplied by D. Conn. L. Civ. R. 26(c) and the rules of construction supplied by D. Conn. L. Civ. R. 26(d), as incorporated by D. Conn. Bankr. L.R. 2004-1(a), shall apply to the Document Requests. In addition, the following terms used in these Document Requests shall have the following meanings:\n\n1. \"You\" or \"Your\" or \"Yourself\" means and refers to David Fallon, together with all of his agents, attorneys, representatives, employees, and/or anyone acting on his behalf.\n\n2. \"Debtor\" means Ho Wan Kwok (a/k/a Miles Kwok, Miles Guo, Guo Wengui, Guo Haoyun, 郭文贵, or any other alias), together with his employees, agents, counsel, advisors, or anyone acting on his behalf.\n\n3. \"Debtor's Son\" means Qiang Guo (a/k/a Mileson Kwok, 郭强, or any other alias), together with his employees, agents, counsel, advisors, or anyone acting on his behalf.\n\n4. \"Debtor's Daughter\" means Mei Guo (a/k/a Mei Gui, 郭美, or any other alias), together with her employees, agents, counsel, advisors, or anyone acting on her behalf.\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 493 of 1063\n\n5. \"Debtor's Purported Wife\" means Hing Chi Ngok (a/k/a Hing Chi Ng, Yue Qingzhi, 岳庆芝, or any other alias), together with her employees, agents, counsel, advisors, or anyone acting on her behalf.\n\n6. \"Debtor's Family\" means, collectively, the Debtor, the Debtor's Son, the Debtor's Daughter, and the Debtor's Purported Wife, and any other familial relation to the Debtor.\n\n7. \"Associated Individuals\" means, individually and collectively, all individuals that (1) hold, control, have custody over, or discretion over assets owned, controlled, or enjoyed by the Debtor or the Debtor's Family; or (2) have been employees, directors, or otherwise are affiliated with one or more Associated Entities, together with the respective employees, agents, counsel, advisors, or anyone acting on behalf of any of the foregoing. Such Associated Individuals shall include, but are not limited to: Daniel Podhaskie, Jason Miller, Steve Bannon, Karin Maistrello, Melissa Francis, Anthony DiBattista, William Gertz, Arethusa Forsyth, Glenn Mellor, Jennifer Mercurio, Eduardo Eurnekian, Wencong Wang, Han Chunguang (a/k/a 韩春光), Qu Guojiao (a/k/a Qu Guo Jiao, 屈国姣), Guo Lijie (a/k/a 郭丽杰), Zhang Wei (a/k/a 张伟\\*), Lihong Wei Lafrenz (a/k/a Sara Wei, 魏丽红), Hao Haidong (a/k/a 郝海东), Ross Heinemeyer, Max Krasner, Kyle Bass, Melissa Mendez, Ya Li (a/k/a 李娅), Dinggang Wang (a/k/a 王定刚), An Hong (a/k/a 安红), Yvette Wang (a/k/a Yanping Wang, Yan Ping Wang, 王雁平), Fiona Yu, Je Kin Ming (a/k/a William Je, Yu Jianming, 余建明), Yaz Qingua, and Lao Jiang (a/k/a Jiang Yunfu, Jiang Yunfu Be, 姜云浮).\n\n8. \"Associated Entities\" means, individually and collectively, all organizations or Entities of any type that (1) have been owned, controlled, or invested in by the Debtor or the\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 494 of 1063\n\nDebtor's Family; or (2) have an interest, whether directly or indirectly, in any assets owned, controlled, or enjoyed by the Debtor or the Debtor's Family, together with the respective employees, agents, counsel, advisors, or anyone acting on behalf of any of the foregoing. Such Associated Entities shall include, but are not limited to: 7 Nod Hill LLC, AAGV Limited, ACA Investment Management Limited, ACA Capital Group Limited, Ace Decade Holdings Limited, AI Group Holdings Inc., Alfa Global Ventures Limited, Alfonso Global Limited, Allied Capital Global Limited, Alpine Fiduciaries SA, Anton Development Limited, Assets Sino Limited, Auspicious Coast Limited, Beijing Pangu Investment Co., Beijing Pangu Investment Co. Ltd., Beijing Pangu Investment Inc., Beijing Zenith Holdings Company Limited, Booming Sail New York LLC, Bravo Luck Limited, BSA Strategic Fund I, China Golden Spring (Hong Kong) Limited, Chuang Xin Limited, Crane Advisory Group LLC, Creative Apex Investments Limited, Crystal Breeze Investments Limited, Dawn State Limited, Eastern Profit Corporation Limited, Elite Well Global Limited, Empire Growth Holdings, Freedom Media Ventures Ltd., G Club Operations LLC, G Fashion LLC, G News LLC, GETTR USA, Genever Holdings Corporation, Genever Holdings LLC, Gfashion Media Group Inc., GFNY, Inc., Globalist International Limited, GNews Media Group Inc., Golden Spring (New York) Ltd., Greenwich Land LLC, Guo Media, GTV Media Group, Inc., Hamilton Capital Holdings Inc., HCHK Property Management, Inc., HCHK Technologies, Inc., Head Win Group Limited, Henan Yuda, Himalaya Embassy, Himalaya Exchange, Himalaya Federal Reserve, Himalaya Investment LLC, Himalaya International, Himalaya New World Inc., Himalaya Supervisory Organization, Himalaya Ventures LLC, HK International Funds Investments (USA) Limited LLC, Hong Kong International Funds Investments Limited, Hudson Diamond Holding, Infinite Increase Limited, Infinitum Developments Limited, Infinity Treasury Management Inc., Insight Phoenix Fund, Lamp Capital\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 495 of 1063\n\nLLC, Leading Shine Limited, Leading Shine NY Limited, Lexington Property and Staffing, Long Gate Limited, Maywind Trading LLC, MOS Himalaya LLC, Next Tycoon Investments Limited, New Federal State of China (a/k/a NFSC), Noble Fame Global Limited, Rosy Acme Ventures Limited, Rule of Law Foundation III, Inc., Rule of Law Foundation IV, Inc., Rule of Law Fund, Rule of Law Society, Rule of Law Society IV, Inc., G-Translators PTY LTD, Saraca Media Group, Inc., Shiny Ace Ltd., Shiny Times Holdings Ltd., Spirit Charter Investment Limited, Stevenson, Wong & Co., Voice of Guo Media, Inc., Well Origin Ltd., World Century Limited, Worldwide Opportunity Holdings Limited, Whitecroft Shore Limited, and ZIBA Limited.\n\n9. \"Including\" or any variant thereof means \"including without limitation.\"\n\n10. \"And\" and \"or\" mean \"and/or,\" and shall be construed both conjunctively as well as disjunctively in order to maximize their scope.\n\n11. \"Any\" and \"all\" and \"each\" mean \"each and every.\"\n\n12. \"Each\" and \"every\" mean \"each and every.\"\n\n13. \"Third Party\" means a Person or Entity other than Yourself.\n\n14. \"Transfer\" shall have the meaning given to it by section 101(54) of the Bankruptcy Code.\n\n15. \"Document\" means any information or thing within the scope of Fed. R. Civ. P. 34, and includes, without limitation, each and every written, recorded, or graphic matter of any kind, type, nature, or description that is or has been in Your Possession, Custody or Control, including all printed and electronic copies of electronic mail, computer files maintained in electronic form, electronic communication, text message, social media post, tweet, meta-data, correspondence, memoranda, tapes, stenographic or handwritten notes, written forms of any\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 496 of 1063\n\nkind, charts, blueprints, drawings, sketches, graphs, plans, articles, specifications, diaries, letters, telegrams, photographs, minutes, contracts, agreements, surveys, computer printouts, data compilations of any kind, telexes, facsimiles, voice messages, invoices, order forms, checks, drafts, statements, credit memos, reports, position reports, summaries, indices, books, ledgers, notebooks, schedules, transparencies, recordings, catalogs, advertisements, promotional materials, films, video tapes, audio tapes, CDs, computer disks, brochures, pamphlets, punchcards, time-slips, Tweets, social media posts, or any written or recorded materials of any other kind, and all meta-data thereof, however stored (whether in tangible or electronic form), recorded, produced, or reproduced, and also including but not limited to, drafts or copies of any of the foregoing that contain any notes, comments, or markings of any kind not found on the original documents or that are otherwise not identical to the original documents.\n\n16. \"Person(s)\" means an individual, corporation, proprietorship, partnership, association, or any other Entity. \"Person\" also includes any agent, representatives, or expert, including but not limiting to, attorneys or financial advisors.\n\n17. \"Entity\" means any natural Person, corporation, partnership, subsidiary, sole proprietorship, firm, board, joint venture, association, agency, authority, commission or other business entity or juristic Person, as well as any affiliate, agent, parent including but not limited to legal counsel, financial advisors, or any other representative.\n\n18. \"Regarding\" means concerning, describing, comprising, referring to, related to, supporting, favoring, opposing, bolstering, detracting from, located in, considered in connection with, bearing on, evidencing, indicating, reporting on, recording, alluding to, responding to, connected with, commenting on, in respect of, about, in relation to, discussing, showing, describing, reflecting, analyzing constituting, and being.\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 497 of 1063\n\n19. \"Relating to,\" \"relate(s) to\" or \"related to,\" when referring to any given subject matter, means, without limitation, any document that constitutes, comprises, involves, contains, embodies, reflects, identifies, states, refers directly or indirectly to, or is in any way relevant to the particular subject matter identified.\n\n20. \"Communication(s)\" means, in the broadest possible sense, and without limitation, any transmittal of information or knowledge (in the form of facts, ideas, inquiries, or otherwise). Communication(s) further refers to all conversations, agreements, inquiries, or replies, whether in person, by telephone, in writing, or by means of electronic transmittal devices, and includes, but is not limited to, all correspondence, emails, recordings, transmittal slips, memoranda, telephone communications, voice messages, telegrams, telefaxes, telecopies, telexes, instant messages, chats, text messages, telephonic notes, or notes transmitted internally or with third parties.\n\n21. \"Asset(s)\" means any item that can be used to produce positive economic value, including but not limited to any resource with economic value that is owned, controlled or is for the benefit of an entity, that is expected to provide a future benefit, including but not limited to, all real and personal property, intangible property, investments, rights to invest or to future revenue, cash, bank accounts, commodities, securities, claims, total or partial control of an entity, and prospective economic opportunities\n\n22. \"Transfer\" shall have the meaning given to it by section 101(54) of the Bankruptcy Code.\n\n## **IV. DOCUMENTS TO BE PRODUCED**\n\n1. All Documents regarding any income or Asset of the Debtor, the Debtor's estate, or an Associated Entity.\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 498 of 1063\n\n2. All Documents related to the Debtor's financial condition and obligations to his creditors, including without limitation all Documents related to any effort to avoid paying such obligations and All Documents related to this or any other actual or potential bankruptcy or similar insolvency proceeding.\n\n3. All Documents regarding any balance sheet, bank statement, account statement, financial statement, statement of account, wire transfer instructions and/or confirmation, proof of funds, certificate of deposit, certificate of holdings, investment portfolio summary, or similar document relating to the Debtor, the Debtor's Estate, the Debtor's Family, an Associated Entity, or an Associated Individual, including without limitation all Documents sufficient to show all Transfers to any of the foregoing.\n\n4. All Documents regarding any investment, business dealing or transactions made by, with, or on behalf of the Debtor.\n\n5. All Communications with the Debtor, and Documents related to Communications with the Debtor, related to the operation, management, or decision-making of any Entity, including without limitation the Associated Entities.\n\n6. All Documents regarding any Transfer, investment, or other transaction or business dealing made to, by, or with the Debtor, the Debtor's Family, or an Associated Entity.\n\n7. All Documents regarding any property ever occupied or used by the Debtor, including without limitation the *Lady May*; the Sherry Netherland Hotel / Condominium; the residential property located in Greenwich, Connecticut at 373 Taconic Rd.; the residential property located in Greenwich, Connecticut at 33 Ferncliff Rd.; and the residential property located in Wilton, Connecticut at 354 Nod Hill Rd.\n\n#### Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 499 of 1063\n\n8. All Documents related to any aircraft owned, controlled, or used by the Debtor, including without limitation the aircraft bearing tail number T7-GQM and any other aircraft registered in San Marino, including without limitation copies of all registration documents and flight manifests showing flights taken by such aircraft and the individuals onboard such flights.\n\n9. All Documents regarding any gifts, benefits or loans, to, from or on behalf of the Debtor, the Debtor's Estate, the Debtor's Family, or the Associated Entities, including without limitation Documents sufficient to show the amounts of such gifts, benefits, or loans; the purposes for which such gifts, benefits, or loans were used; when the gifts, benefits, or loans were provided; and the terms of any loans, all representations and warranties made in connection with any loans, the interest rate on any loans, and all evidence of payments of any loans.\n\n10. All Documents concerning any trust or similar instrument set up by, on behalf of, or for the benefit of the Debtor, the Debtor's Estate, the Debtor's Family, or an Associated Entity, including without limitation Documents sufficient to show when the trust(s) was created, by whom it was created, for whose benefit it was created, and the corpus of the trust.\n\n11. All Documents related to any obligation, claim, liability, or debt associated with any legal dispute involving the Debtor, including but not limited to those relating to any litigation before any local, state, federal, or international body, whether an administrative body, court, panel, or alternative dispute resolution entity.\n\n12. All Documents and communications between any of your outside counsel or other advisors and the Debtor.\n\n13. All Documents related to any Associated Entity that You hold or have held an interest in.\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 500 of 1063\n\n14. All Communications with the Debtor, and Documents related to Communications with the Debtor, related to the operation, management, or decision-making of any legal entity, including without limitation the Family Related Entities and the Associated Entities.\n\nCase 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 501 of 1063\n\n# Exhibit C-27\n\n#### B2540 (Form 2540 – Subpoena for Rule 2004 Examination) (12/15) Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 502 of\n\n1063\n\nUNITED STATES BANKRUPTCY COURT\n\n**District of Connecticut**\n\nIn re HO WAN KWOK, *et al*.,\n\n<sup>1</sup> Case No. 22-50073 (JAM)\n\nDebtor Chapter 11\n\n(Jointly Administered)\n\n# **SUBPOENA FOR RULE 2004 EXAMINATION**\n\nTo: **Mimaii NZ Limited**\n\n(*Name of person to whom the subpoena is directed*)\n\n*Testimony:* **YOU ARE COMMANDED** to appear at the time, date, and place set forth below to testify at an examination under Rule 2004, Federal Rules of Bankruptcy Procedure. A copy of the court order authorizing the examination is attached.\n\n| PLACE                    | DATE AND TIME |\n|--------------------------|---------------|\n| Paul Hastings LLP        |               |\n| 200 Park Avenue          | [TBD]         |\n| New York, New York 10166 |               |\n|                          |               |\n\nThe examination will be recorded by this method: **Court reporter/stenographer**\n\n*Production:* You, or your representatives, must also bring with you to the examination the following documents, electronically stored information, or objects, and must permit inspection, copying, testing, or sampling of the material:\n\n#### **See Requests for Production of Documents, attached hereto.**\n\nThe following provisions of Fed. R. Civ. P. 45, made applicable in bankruptcy cases by Fed. R. Bankr. P. 9016, are attached – Rule 45(c), relating to the place of compliance; Rule 45(d), relating to your protection as a person subject to a subpoena; and Rule 45(e) and 45(g), relating to your duty to respond to this subpoena and the potential consequences of not doing so.\n\nDate: **March , 2023**\n\nCLERK OF COURT\n\nOR\n\n*Signature of Clerk or Deputy Clerk Attorney's signature*\n\nThe name, address, email address, and telephone number of the attorney representing Luc A. Despins, Chapter 11 Trustee, who issues or requests this subpoena, are:\n\n**Douglas S. Skalka, Esq.; Neubert, Pepe & Monteith, P.C.; 195 Church Street, New Haven, Connecticut 06510 dskalka@npmlaw.com; (203) 821-2000**\n\n**Notice to the person who issues or requests this subpoena**\n\nIf this subpoena commands the production of documents, electronically stored information, or tangible things, or the inspection of premises before trial, a notice and a copy of this subpoena must be served on each party before it is served on the person to whom it is directed. Fed. R. Civ. P. 45(a)(4).\n\nSoftware Copyright (c) 1996-2022 Best Case, LLC - www.bestcase.com Best Case Bankruptcy 1 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\n#### **PROOF OF SERVICE**\n\n**(This section should not be filed with the court unless required by Fed. R. Civ. P. 45.)**\n\nI received this subpoena for (*name of individual and title, if any*): on (*date*) .\n\nI served the subpoena by delivering a copy to the named person as follows:\n\non *(date)* ; or\n\nI returned the subpoena unexecuted because:\n\nUnless the subpoena was issued on behalf of the United States, or one of its officers or agents, I have also tendered to the witness the fees for one day's attendance, and the mileage allowed by law, in the amount of \\$ .\n\nMy fees are \\$ for travel and \\$ for services, for a total of \\$ .\n\nI declare under penalty of perjury that this information is true and correct.\n\nDate:\n\n*Server's signature*\n\n*Printed name and title*\n\n*Server's address*\n\nAdditional information concerning attempted service, etc.:\n\n#### **Federal Rule of Civil Procedure 45(c), (d), (e), and (g) (Effective 12/1/13) (made applicable in bankruptcy cases by Rule 9016, Federal Rules of Bankruptcy Procedure)**\n\n#### **(c) Place of compliance.**\n\n*(1) For a Trial, Hearing, or Deposition.* A subpoena may command a person to attend a trial, hearing, or deposition only as follows:\n\n(A) within 100 miles of where the person resides, is employed, or regularly transacts business in person; or\n\n(B) within the state where the person resides, is employed, or regularly transacts business in person, if the person\n\n(i) is a party or a party's officer; or\n\n(ii) is commanded to attend a trial and would not incur substantial expense.\n\n*(2) For Other Discovery.* A subpoena may command:\n\n(A) production of documents, or electronically stored information, or things at a place within 100 miles of where the person resides, is employed, or regularly transacts business in person; and\n\n(B) inspection of premises, at the premises to be inspected.\n\n#### **(d) Protecting a Person Subject to a Subpoena; Enforcement.**\n\n*(1) Avoiding Undue Burden or Expense; Sanctions.* A party or attorney responsible for issuing and serving a subpoena must take reasonable steps to avoid imposing undue burden or expense on a person subject to the subpoena. The court for the district where compliance is required must enforce this duty and impose an appropriate sanction which may include lost earnings and reasonable attorney's fees — on a party or attorney who fails to comply.\n\n#### *(2) Command to Produce Materials or Permit Inspection.*\n\n*(A) Appearance Not Required.* A person commanded to produce documents, electronically stored information, or tangible things, or to permit the inspection of premises, need not appear in person at the place of production or inspection unless also commanded to appear for a deposition, hearing, or trial.\n\n*(B) Objections.* A person commanded to produce documents or tangible things or to permit inspection may serve on the party or attorney designated in the subpoena a written objection to inspecting, copying, testing or sampling any or all of the materials or to inspecting the premises — or to producing electronically stored information in the form or forms requested. The objection must be served before the earlier of the time specified for compliance or 14 days after the subpoena is served. If an objection is made, the following rules apply:\n\n(i) At any time, on notice to the commanded person, the serving party may move the court for the district where compliance is required for an order compelling production or inspection.\n\n(ii) These acts may be required only as directed in the order, and the order must protect a person who is neither a party nor a party's officer from significant expense resulting from compliance.\n\n#### *(3) Quashing or Modifying a Subpoena.*\n\n*(A) When Required.* On timely motion, the court for the district where compliance is required must quash or modify a subpoena that:\n\n(i) fails to allow a reasonable time to comply;\n\n(ii) requires a person to comply beyond the geographical limits specified in Rule 45(c);\n\n(iii) requires disclosure of privileged or other protected matter, if no exception or waiver applies; or\n\n(iv) subjects a person to undue burden.\n\n*(B) When Permitted.* To protect a person subject to or affected by a subpoena, the court for the district where compliance is required may, on motion, quash or modify the subpoena if it requires:\n\n(i) disclosing a trade secret or other confidential research, development, or commercial information; or\n\n(ii) disclosing an unretained expert's opinion or information that does not describe specific occurrences in dispute and results from the expert's study that was not requested by a party.\n\n(C) *Specifying Conditions as an Alternative.* In the circumstances described in Rule 45(d)(3)(B), the court may, instead of quashing or modifying a subpoena, order appearance or production under specified conditions if the serving party:\n\n(i) shows a substantial need for the testimony or material that cannot be otherwise met without undue hardship; and\n\n(ii) ensures that the subpoenaed person will be reasonably compensated.\n\n#### **(e) Duties in Responding to a Subpoena.**\n\n*(1) Producing Documents or Electronically Stored Information.* These procedures apply to producing documents or electronically stored information:\n\n*(A) Documents.* A person responding to a subpoena to produce documents must produce them as they are kept in the ordinary course of business or must organize and label them to correspond to the categories in the demand.\n\n*(B) Form for Producing Electronically Stored Information Not Specified.* If a subpoena does not specify a form for producing electronically stored information, the person responding must produce it in a form or forms in which it is ordinarily maintained or in a reasonably usable form or forms.\n\n*(C) Electronically Stored Information Produced in Only One Form.* The person responding need not produce the same electronically stored information in more than one form.\n\n*(D) Inaccessible Electronically Stored Information.* The person responding need not provide discovery of electronically stored information from sources that the person identifies as not reasonably accessible because of undue burden or cost. On motion to compel discovery or for a protective order, the person responding must show that the information is not reasonably accessible because of undue burden or cost. If that showing is made, the court may nonetheless order discovery from such sources if the requesting party shows good cause, considering the limitations of Rule 26(b)(2)(C). The court may specify conditions for the discovery.\n\n#### *(2) Claiming Privilege or Protection.*\n\n*(A) Information Withheld.* A person withholding subpoenaed information under a claim that it is privileged or subject to protection as trial-preparation material must: (i) expressly make the claim; and\n\n(ii) describe the nature of the withheld documents, communications, or tangible things in a manner that, without revealing information itself privileged or protected, will enable the parties to assess the claim.\n\n*(B) Information Produced.* If information produced in response to a subpoena is subject to a claim of privilege or of protection as trial-preparation material, the person making the claim may notify any party that received the information of the claim and the basis for it. After being notified, a party must promptly return, sequester, or destroy the specified information and any copies it has; must not use or disclose the information until the claim is resolved; must take reasonable steps to retrieve the information if the party disclosed it before being notified; and may promptly present the information under seal to the court for the district where compliance is required for a determination of the claim. The person who produced the information must preserve the information until the claim is resolved.\n\n**(g) Contempt.** The court for the district where compliance is required – and also, after a motion is transferred, the issuing court – may hold in contempt a person who, having been served, fails without adequate excuse to obey the subpoena or an order related to it.\n\nFor access to subpoena materials, see Fed.R.Civ.P.45(a) Committee Note (2013)\n\n…\n\n## **Requests for Production of Documents**\n\n## **I. INSTRUCTIONS**\n\n1. Unless otherwise indicated, the requests for documents set forth below, (the \"Requests,\" and each, a \"Request\"), must be responded to separately and specifically. Each Request shall be answered fully unless it is in good faith objected to, in which event the reason for Your objection shall be stated in detail, as set forth below. If an objection pertains only to a portion of a Request, or a word, phrase or clause contained within it, You are required to state Your objection to that portion only and to respond to the remainder of the Requests.\n\n2. Electronically stored information must be produced in accordance with the\n\nfollowing instructions:\n\n- a. Images. Black and white images must be 300 DPI Group IV single-page TIFF files. Color images must be produced in JPEG format. File names cannot contain embedded spaces or special characters (including the comma). Folder names cannot contain embedded spaces or special characters (including the comma). All TIFF image files must have a unique file name, i.e. Bates number. Images must be endorsed with sequential Bates numbers in the lower right corner of each image. The number of TIFF files per folder should not exceed 1000 files. Excel spreadsheets should have a placeholder image named by the Bates number of the file.\n- b. Image Load File\n\t- a. Concordance® Data File. The data file (.DAT) contains all of the fielded information that will be loaded into the Concordance® database. The first line of the .DAT file must be a header row identifying the field names. The .DAT file must use the following Concordance® default delimiters: Comma ASCII character (020) Quote þ ASCII character (254). Date fields should be provided in the format: mm/dd/yyyy. Date and time fields must be two separate fields. If documents includes imaged emails and attachments, the attachment fields must be included to preserve the parent/child relationship between an email and its attachments. An OCRPATH field must be included to provide the file path and name of the extracted text file on the produced storage media. The text file must be named after the FIRSTBATES. Do not include the text in the .DAT file. For Documents with native files, a LINK field must be included to provide the file path and\n\nname of the native file. The native file must be named after the FIRSTBATES.\n\n- b. Concordance Image® OR Opticon Cross-Reference File. The image crossreference file (.LOG or .OPT) links the images to the database records. It should be a comma-delimited file consisting of seven fields per line with a line in the cross-reference file for every image in the database with the following format: ImageID,VolumeLabel,ImageFilePath,DocumentBreak,FolderBreak,Box Break,PageCoun.\n- c. Document Text. Text must be produced as separate text files, not as fields within the .DAT file. The full path to the text file (OCRPATH) should be included in the .DAT file. It is recommended document level ANSI text files, named per the FIRSTBATES/Image Key. Extracted text files must be in a separate folder, and the number of text files per folder should not exceed 1,000 files. There should be no special characters (including commas in the folder names). Text files must be provided on a document level.\n- d. Native Production for Certain File Types. File types that reasonably require viewing in their native format for a full understanding of their content and meaning must be produced in native format. These include, but are not limited to, spreadsheets, spreadsheet-like files (Microsoft Excel, comma separated values, tab separated values, etc.), Microsoft PowerPoint or other special presentation files, database files, and audio/visual files. Provide an image of a Bates numbered slip sheet indicating the presence of a native file, and include the path to the native as a field in the .dat file. Name the produced native file with the Bates number corresponding to the slip sheet for the file. Group native files within incrementally named \"NATIVE\" directories, separate from images directories.\n- e. De-duplication. Produce a single copy of each electronic document for which exact duplicates exist. For email messages, consolidate duplicates based on MD5 hash generated from the BCC, Body, CC, From, IntMsgID, To, and Attach properties. For email attachments and standalone electronic files, consolidate duplicates based on MD5 hash of the entire file.\n- f. Metadata. Produce extracted metadata for each document in the form of a Concordance compliant load file (.dat). The first line of the .DAT file must be a header row identifying the field names. The .DAT file must use the following Concordance default delimiters: Comma , ASCII character (020) Quote þ ASCII character (254)\n\nDate fields should be provided in the format: mm/dd/yyyy. Date and time fields must be two separate fields. Required metadata listed below:\n\n# Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 507 of 1063\n\n| Field Name   | Sample Data              | Description                                                                                  |\n|--------------|--------------------------|----------------------------------------------------------------------------------------------|\n| FIRSTBATES   | EDC0000001               | First Bates number of native file document/email                                             |\n| LASTBATES    | EDC0000001               | Last Bates number of native file document/email<br>**The LASTBATES field should be populated |\n|              |                          | for single page                                                                              |\n| ATTACHRANGE  | EDC0000001<br>-          | Bates number of the first page of the parent                                                 |\n|              | EDC0000015               | document to the Bates number of the last page of                                             |\n|              |                          | the last attachment \"child\" document                                                         |\n| BEGATTACH    | EDC0000001               | First Bates number of attachment range                                                       |\n| ENDATTACH    | EDC0000015               | Last Bates number of attachment range                                                        |\n| CUSTODIAN    | Smith, John              | Email: Mailbox where the email resided                                                       |\n|              |                          | Native: Name of the individual or department                                                 |\n|              |                          | from whose files the document<br>originated                                                  |\n| FROM         | John Smith               | Email: Sender                                                                                |\n|              |                          |                                                                                              |\n|              |                          | Native: Author(s) of document                                                                |\n|              |                          | **semi-colon should be used to separate                                                      |\n|              |                          | multiple entries                                                                             |\n| TO           | Coffman, Janice; LeeW    | Recipient(s)                                                                                 |\n|              | [mailto:LeeW@MSN.com]    | **semi-colon should be used to separate multiple                                             |\n|              |                          | entries                                                                                      |\n| CC           | Frank Thompson [mailto:  | Carbon copy recipient(s)                                                                     |\n|              | frank_Thompson@cdt.com]  | **semi-colon should be used to separate                                                      |\n|              |                          | multiple entries                                                                             |\n| BCC          | John Cain                | Blind carbon copy recipient(s)                                                               |\n|              |                          | **semi-colon should be used to separate                                                      |\n|              |                          | multiple entries                                                                             |\n| SUBJECT      | Board Meeting Minutes    | Email: Subject line of the email Native: Title                                               |\n|              |                          | of document (if available)                                                                   |\n| FILE_NAME    | BoardMeetingMinutes.docx | Native: Name of the original native file,                                                    |\n|              |                          | including extension                                                                          |\n| DATE_SENT    | 10/12/2010               | Email: Date the email was sent                                                               |\n|              |                          | Native: (empty)                                                                              |\n| TIME_SENT/   | 07:05 PM GMT             | Email: Time the email was sent/ Time zone in                                                 |\n| TIME_ZONE    |                          | which the emails were standardized                                                           |\n| TIME_ZONE    | GMT                      | The<br>time zone in which<br>the emails<br>were                                              |\n|              |                          | standardized during conversion.                                                              |\n| LINK         |  EDC0000001.msg   | Hyperlink to the email or native file document                                               |\n|              |                          | **The linked file must be named per the                                                      |\n|              |                          | FIRSTBATES number                                                                            |\n| FILE_EXTEN   | MSG                      | The file type extension                                                                      |\n|              |                          | representing                                                                                 |\n|              |                          | the Email or                                                                                 |\n| AUTHOR       | John Smith               | Email: (empty)                                                                               |\n|              |                          | Native: Author of the document                                                               |\n| DATE_CREATED | 10/10/2010               | Email: (empty)                                                                               |\n|              |                          | Native: Date the document was created                                                        |\n|              |                          |                                                                                              |\n\n# Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 508 of 1063\n\n| TIME_CREATED | 10:25 AM                  | Email: (empty)                                  |\n|--------------|---------------------------|-------------------------------------------------|\n|              |                           | Native: Time the document was created           |\n|              |                           | **This data must be a separate field and cannot |\n|              |                           | be combined with the DATE_CREATED field         |\n| DATE_MOD     | 10/12/2010                | Email: (empty)                                  |\n|              |                           | Native: Date the document was last modified     |\n| TIME_MOD     | 07:00 PM                  | Email: (empty)                                  |\n|              |                           | Native: Time the document was last modified     |\n|              |                           | **This data must be a separate field and cannot |\n|              |                           | be combined with the DATE_MOD field             |\n| DATE_ACCESSD | 10/12/2010                | Email: (empty)                                  |\n|              |                           | Native: Date the document was last accessed     |\n| TIME_ACCESSD | 07:00 PM                  | Email: (empty)                                  |\n|              |                           | Native: Time the document was last accessed     |\n|              |                           | **This data must be a separate field and cannot |\n|              |                           | be combined with the DATE_ACCESSD field         |\n| FILE_SIZE    | 5,952                     | Size of native file<br>document/email in KB     |\n| PGCOUNT      | 1                         | Number of pages in native file document/email   |\n| PATH         |   | Email: (empty)                                  |\n|              | Agenda.doc                | Native: Path where native file document was     |\n|              |                           | stored including original file name.            |\n| INTFILEPATH  | Personal Folders\\Deleted  | Email: original location of email including     |\n|              | Items\\Board Meeting       | original file name.                             |\n|              | Minutes.msg               | Native: (empty)                                 |\n| INTMSGID     | <000805c2c71b\\$75977050\\$ | Email: Unique Message ID Native: (empty)        |\n|              | cb8306d1@MSN>             |                                                 |\n| MD5HASH      | d131dd02c5e6eec4693d9a0   | MD5 Hash value of the document.                 |\n|              | 698aff95c                 |                                                 |\n|              | 2fcab58712467eab4004583e  |                                                 |\n|              | b8fb7f89                  |                                                 |\n| OCRPATH      | TEXT/001/EDC0000001.txt   | Path to extracted text of the native file       |\n\n3. Each Request operates and should be construed independently and, unless otherwise indicated, no Request limits the scope of any other Request.\n\n4. All Documents are to be produced as kept in the usual course of business or are to be organized and labeled to correspond with the categories in these Requests.\n\n5. Each Request contained herein extends to all Documents: (a) in Your possession, custody, or control; or (b) in the possession, custody, or control of anyone acting on Your behalf,\n\n#### Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 509 of 1063\n\nincluding Your counsel or other representatives and advisors. Each Document shall be produced in its entirety.\n\n6. If You are requested to produce a Document that is no longer in Your possession, custody, or control, then Your response must (a) describe in detail the nature of the document and its contents; (b) identify the person(s) who prepared or authored the Document (and, if applicable, the Person(s) to whom the Document was sent); (c) identify the date on which the document was prepared or created; (d) state whether such Document (i) is missing or lost, (ii) has been destroyed, (iii) has been transferred, voluntarily or involuntarily, to others, or (iv) was otherwise disposed of; (e) state the reason for, and the facts and circumstances surrounding, such disposition; (f) identify the Persons who authorized such disposition; (g) identify the date or approximate date of such disposition; (h) state when the Document was most recently in Your possession, custody or control; and (i) identify the Person, if any, presently in possession, custody, or control of such Document.\n\n7. If You are requested to produce a Document that has been destroyed, then Your response must state, in addition to the information required by the preceding Instruction: (a) the reason for the Document's destruction; (b) the identity of the Person who destroyed the Document; and (c) the identity of the Person who directed that the Document be destroyed.\n\n8. If You claim that a requested Document is privileged or attorney work-product, then Your response must: (a) state (i) a description of the Document adequate to support Your contention that the Document is privileged, (ii) the title of the Document, (iii) the date of the Document, (iv) the author of the Document, (v) the addressee of the Document, (vi) the identity of each Person who received or saw the original or any draft, copy, or reproduction of the Document, (vii) whether the Document itself, or any information contained or referred to in the Document is in the possession, custody, or control of any other Persons, and if so, the identity of\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 510 of 1063\n\nsuch Persons, as well as a statement addressing how the information came into their possession, (viii) the claim of privilege under which the Document is withheld, and (ix) all of the circumstances upon which You will rely to support such claim of privilege; and (b) produce a privilege log containing all of the information requested in Part (a) of this Instruction for each Document withheld on the basis of a claim of privilege in accordance with D. Conn. L. Civ. R. 26(e).\n\n9. If a portion of an otherwise responsive Document contains information subject to a claim of privilege, only that portion of the Document subject to the claim of privilege shall be deleted or redacted from the Document following the instructions above, and the rest shall be produced.\n\n10. The Requests are continuing in nature. You are hereby instructed to (a) supplement or correct any responses later learned to be incomplete or incorrect immediately upon learning that a prior response was incomplete or incorrect; and (b) produce any additional Documents that are called for under the\n\n11. If a Document is in a language other than English, You should provide that Document. If a Document is in a language other than English, and an English translation exists, You should provide both Documents.\n\n12. All references to Entities includes all affiliates thereof.\n\n13. All references to individual names include all alternative names, aliased, or nicknames.\n\n14. Unless otherwise expressly indicated, the period of time covered by the Document Requests is the period from February 5, 2012 to the date responses to the Document Requests are due.\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 511 of 1063\n\n#### **II. RULES OF CONSTRUCTION**\n\n15. The use of (a) any singular noun shall be construed to include the plural, and vice versa, and (b) a verb in any tense shall be construed as the use of the verb in all other tenses.\n\n16. The terms (a) \"and\" and \"or\" shall be construed either conjunctively or disjunctively as necessary to bring within the scope of any request all responses that might otherwise be construed to be outside of its scope, and (b) \"each\" and \"any\" shall be deemed to include and encompass the words \"every\" and \"all.\"\n\n#### **III. DEFINITIONS**\n\nThe definitions supplied by D. Conn. L. Civ. R. 26(c) and the rules of construction supplied by D. Conn. L. Civ. R. 26(d), as incorporated by D. Conn. Bankr. L.R. 2004-1(a), shall apply to the Document Requests. In addition, the following terms used in these Document Requests shall have the following meanings:\n\n1. \"You\" or \"Your\" or \"Yourself\" means and refers to Mimaii NZ Limited, together with all of its affiliates, divisions, agencies, instrumentalities, departments, offices, partners, officers, directors, agents, attorneys, representatives, employees, and/or anyone acting on its behalf.\n\n2. \"Debtor\" means Ho Wan Kwok (a/k/a Miles Kwok, Miles Guo, Guo Wengui, Guo Haoyun, 郭文贵, or any other alias), together with his employees, agents, counsel, advisors, or anyone acting on his behalf.\n\n3. \"Debtor's Son\" means Qiang Guo (a/k/a Mileson Kwok, 郭强, or any other alias), together with his employees, agents, counsel, advisors, or anyone acting on his behalf.\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 512 of 1063\n\n4. \"Debtor's Daughter\" means Mei Guo (a/k/a Mei Gui, 郭美, or any other alias), together with her employees, agents, counsel, advisors, or anyone acting on her behalf.\n\n5. \"Debtor's Purported Wife\" means Hing Chi Ngok (a/k/a Hing Chi Ng, Yue Qingzhi, 岳庆芝, or any other alias), together with her employees, agents, counsel, advisors, or anyone acting on her behalf.\n\n6. \"Debtor's Family\" means, collectively, the Debtor, the Debtor's Son, the Debtor's Daughter, and the Debtor's Purported Wife, and any other familial relation to the Debtor.\n\n7. \"Associated Individuals\" means, individually and collectively, all individuals that (1) hold, control, have custody over, or discretion over assets owned, controlled, or enjoyed by the Debtor or the Debtor's Family; or (2) have been employees, directors, or otherwise are affiliated with one or more Associated Entities, together with the respective employees, agents, counsel, advisors, or anyone acting on behalf of any of the foregoing. Such Associated Individuals shall include, but are not limited to: Daniel Podhaskie, Jason Miller, Steve Bannon, Karin Maistrello, Melissa Francis, Anthony DiBattista, William Gertz, Arethusa Forsyth, Glenn Mellor, Jennifer Mercurio, Eduardo Eurnekian, Wencong Wang, Han Chunguang (a/k/a 韩春光), Qu Guojiao (a/k/a Qu Guo Jiao, 屈国姣), Guo Lijie (a/k/a 郭丽杰), Zhang Wei (a/k/a 张伟\\*), Lihong Wei Lafrenz (a/k/a Sara Wei, 魏丽红), Hao Haidong (a/k/a 郝海东), Ross Heinemeyer, Max Krasner, Kyle Bass, Melissa Mendez, Ya Li (a/k/a 李娅), Dinggang Wang (a/k/a 王定刚), An Hong (a/k/a 安红), Yvette Wang (a/k/a Yanping Wang, Yan Ping Wang, 王雁平), Fiona Yu, Je Kin Ming (a/k/a William Je, Yu Jianming, 余建明), Yaz Qingua, and Lao Jiang (a/k/a Jiang Yunfu, Jiang Yunfu Be, 姜云浮).\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 513 of 1063\n\n8. \"Associated Entities\" means, individually and collectively, all organizations or Entities of any type that (1) have been owned, controlled, or invested in by the Debtor or the Debtor's Family; or (2) have an interest, whether directly or indirectly, in any assets owned, controlled, or enjoyed by the Debtor or the Debtor's Family, together with the respective employees, agents, counsel, advisors, or anyone acting on behalf of any of the foregoing. Such Associated Entities shall include, but are not limited to: 7 Nod Hill LLC, AAGV Limited, ACA Investment Management Limited, ACA Capital Group Limited, Ace Decade Holdings Limited, AI Group Holdings Inc., Alfa Global Ventures Limited, Alfonso Global Limited, Allied Capital Global Limited, Alpine Fiduciaries SA, Anton Development Limited, Assets Sino Limited, Auspicious Coast Limited, Beijing Pangu Investment Co., Beijing Pangu Investment Co. Ltd., Beijing Pangu Investment Inc., Beijing Zenith Holdings Company Limited, Booming Sail New York LLC, Bravo Luck Limited, BSA Strategic Fund I, China Golden Spring (Hong Kong) Limited, Chuang Xin Limited, Crane Advisory Group LLC, Creative Apex Investments Limited, Crystal Breeze Investments Limited, Dawn State Limited, Eastern Profit Corporation Limited, Elite Well Global Limited, Empire Growth Holdings, Freedom Media Ventures Ltd., G Club Operations LLC, G Fashion LLC, G News LLC, GETTR USA, Genever Holdings Corporation, Genever Holdings LLC, Gfashion Media Group Inc., GFNY, Inc., Globalist International Limited, GNews Media Group Inc., Golden Spring (New York) Ltd., Greenwich Land LLC, Guo Media, GTV Media Group, Inc., Hamilton Capital Holdings Inc., HCHK Property Management, Inc., HCHK Technologies, Inc., Head Win Group Limited, Henan Yuda, Himalaya Embassy, Himalaya Exchange, Himalaya Federal Reserve, Himalaya Investment LLC, Himalaya International, Himalaya New World Inc., Himalaya Supervisory Organization, Himalaya Ventures LLC, HK International Funds Investments (USA) Limited LLC, Hong Kong International Funds\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 514 of 1063\n\nInvestments Limited, Hudson Diamond Holding, Infinite Increase Limited, Infinitum Developments Limited, Infinity Treasury Management Inc., Insight Phoenix Fund, Lamp Capital LLC, Leading Shine Limited, Leading Shine NY Limited, Lexington Property and Staffing, Long Gate Limited, Maywind Trading LLC, MOS Himalaya LLC, Next Tycoon Investments Limited, New Federal State of China (a/k/a NFSC), Noble Fame Global Limited, Rosy Acme Ventures Limited, Rule of Law Foundation III, Inc., Rule of Law Foundation IV, Inc., Rule of Law Fund, Rule of Law Society, Rule of Law Society IV, Inc., G-Translators PTY LTD, Saraca Media Group, Inc., Shiny Ace Ltd., Shiny Times Holdings Ltd., Spirit Charter Investment Limited, Stevenson, Wong & Co., Voice of Guo Media, Inc., Well Origin Ltd., World Century Limited, Worldwide Opportunity Holdings Limited, Whitecroft Shore Limited, and ZIBA Limited.\n\n9. \"Including\" or any variant thereof means \"including without limitation.\"\n\n10. \"And\" and \"or\" mean \"and/or,\" and shall be construed both conjunctively as well as disjunctively in order to maximize their scope.\n\n11. \"Any\" and \"all\" and \"each\" mean \"each and every.\"\n\n12. \"Each\" and \"every\" mean \"each and every.\"\n\n13. \"Third Party\" means a Person or Entity other than Yourself.\n\n14. \"Transfer\" shall have the meaning given to it by section 101(54) of the Bankruptcy Code.\n\n15. \"Document\" means any information or thing within the scope of Fed. R. Civ. P. 34, and includes, without limitation, each and every written, recorded, or graphic matter of any kind, type, nature, or description that is or has been in Your Possession, Custody or Control, including all printed and electronic copies of electronic mail, computer files maintained in\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 515 of 1063\n\nelectronic form, electronic communication, text message, social media post, tweet, meta-data, correspondence, memoranda, tapes, stenographic or handwritten notes, written forms of any kind, charts, blueprints, drawings, sketches, graphs, plans, articles, specifications, diaries, letters, telegrams, photographs, minutes, contracts, agreements, surveys, computer printouts, data compilations of any kind, telexes, facsimiles, voice messages, invoices, order forms, checks, drafts, statements, credit memos, reports, position reports, summaries, indices, books, ledgers, notebooks, schedules, transparencies, recordings, catalogs, advertisements, promotional materials, films, video tapes, audio tapes, CDs, computer disks, brochures, pamphlets, punchcards, time-slips, Tweets, social media posts, or any written or recorded materials of any other kind, and all meta-data thereof, however stored (whether in tangible or electronic form), recorded, produced, or reproduced, and also including but not limited to, drafts or copies of any of the foregoing that contain any notes, comments, or markings of any kind not found on the original documents or that are otherwise not identical to the original documents.\n\n16. \"Person(s)\" means an individual, corporation, proprietorship, partnership, association, or any other Entity. \"Person\" also includes any agent, representatives, or expert, including but not limiting to, attorneys or financial advisors.\n\n17. \"Entity\" means any natural Person, corporation, partnership, subsidiary, sole proprietorship, firm, board, joint venture, association, agency, authority, commission or other business entity or juristic Person, as well as any affiliate, agent, parent including but not limited to legal counsel, financial advisors, or any other representative.\n\n18. \"Regarding\" means concerning, describing, comprising, referring to, related to, supporting, favoring, opposing, bolstering, detracting from, located in, considered in connection with, bearing on, evidencing, indicating, reporting on, recording, alluding to, responding to,\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 516 of 1063\n\nconnected with, commenting on, in respect of, about, in relation to, discussing, showing, describing, reflecting, analyzing constituting, and being.\n\n19. \"Relating to,\" \"relate(s) to\" or \"related to,\" when referring to any given subject matter, means, without limitation, any document that constitutes, comprises, involves, contains, embodies, reflects, identifies, states, refers directly or indirectly to, or is in any way relevant to the particular subject matter identified.\n\n20. \"Communication(s)\" means, in the broadest possible sense, and without limitation, any transmittal of information or knowledge (in the form of facts, ideas, inquiries, or otherwise). Communication(s) further refers to all conversations, agreements, inquiries, or replies, whether in person, by telephone, in writing, or by means of electronic transmittal devices, and includes, but is not limited to, all correspondence, emails, recordings, transmittal slips, memoranda, telephone communications, voice messages, telegrams, telefaxes, telecopies, telexes, instant messages, chats, text messages, telephonic notes, or notes transmitted internally or with third parties.\n\n21. \"Asset(s)\" means any item that can be used to produce positive economic value, including but not limited to any resource with economic value that is owned, controlled or is for the benefit of an entity, that is expected to provide a future benefit, including but not limited to, all real and personal property, intangible property, investments, rights to invest or to future revenue, cash, bank accounts, commodities, securities, claims, total or partial control of an entity, and prospective economic opportunities\n\n22. \"Transfer\" shall have the meaning given to it by section 101(54) of the Bankruptcy Code.\n\n#### **IV. DOCUMENTS TO BE PRODUCED**\n\n1. All Documents regarding any income or Asset of the Debtor, the Debtor's estate, or an Associated Entity.\n\n2. All Documents related to the Debtor's financial condition and obligations to his creditors, including without limitation all Documents related to any effort to avoid paying such obligations and All Documents related to this or any other actual or potential bankruptcy or similar insolvency proceeding.\n\n3. All Documents regarding any balance sheet, bank statement, account statement, financial statement, statement of account, wire transfer instructions and/or confirmation, proof of funds, certificate of deposit, certificate of holdings, investment portfolio summary, or similar document relating to the Debtor, the Debtor's Estate, the Debtor's Family, an Associated Entity, or an Associated Individual, including without limitation all Documents sufficient to show all Transfers to any of the foregoing.\n\n4. All Documents regarding any investment, business dealing or transactions made by, with, or on behalf of the Debtor.\n\n5. All Communications with the Debtor, and Documents related to Communications with the Debtor, related to the operation, management, or decision-making of any Entity, including without limitation the Associated Entities.\n\n6. All Documents regarding any Transfer, investment, or other transaction or business dealing made to, by, or with the Debtor, the Debtor's Family, or an Associated Entity.\n\n7. All Documents regarding any property ever occupied or used by the Debtor, including without limitation the *Lady May*; the Sherry Netherland Hotel / Condominium; the\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 518 of 1063\n\nresidential property located in Greenwich, Connecticut at 373 Taconic Rd.; the residential property located in Greenwich, Connecticut at 33 Ferncliff Rd.; and the residential property located in Wilton, Connecticut at 354 Nod Hill Rd.\n\n8. All Documents related to any aircraft owned, controlled, or used by the Debtor, including without limitation the aircraft bearing tail number T7-GQM and any other aircraft registered in San Marino, including without limitation copies of all registration documents and flight manifests showing flights taken by such aircraft and the individuals onboard such flights.\n\n9. All Documents regarding any gifts, benefits or loans, to, from or on behalf of the Debtor, the Debtor's Estate, the Debtor's Family, or the Associated Entities, including without limitation Documents sufficient to show the amounts of such gifts, benefits, or loans; the purposes for which such gifts, benefits, or loans were used; when the gifts, benefits, or loans were provided; and the terms of any loans, all representations and warranties made in connection with any loans, the interest rate on any loans, and all evidence of payments of any loans.\n\n10. All Documents concerning any trust or similar instrument set up by, on behalf of, or for the benefit of the Debtor, the Debtor's Estate, the Debtor's Family, or an Associated Entity, including without limitation Documents sufficient to show when the trust(s) was created, by whom it was created, for whose benefit it was created, and the corpus of the trust.\n\n11. All Documents related to any obligation, claim, liability, or debt associated with any legal dispute involving the Debtor, including but not limited to those relating to any litigation before any local, state, federal, or international body, whether an administrative body, court, panel, or alternative dispute resolution entity.\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 519 of 1063\n\n12. All Documents and communications between any of your outside counsel or other advisors and the Debtor.\n\n13. Documents sufficient to show all of Your Assets and sources of income or funding.\n\n14. For all Assets identified in response to Request 14 having a value of more than \\$50,000, all (i) Documents related to Your acquisition of such Asset and (ii) Communications with the Debtor or the Debtor's Family regarding such Asset.\n\n15. Copies of Your tax returns.\n\n16. Documents sufficient to show all bank accounts and investment accounts within Your possession or control, including the balances of and transfers to and from each such account.\n\n17. All Documents regarding any credit cards used by You, including without limitation monthly statements or other Documents sufficient to show all purchases related thereto for the benefit of the Debtor or an Associated Entity.\n\n18. All corporate governance and organizational Documents, including without limitation by-laws and certificates of incorporation and other Documents sufficient to show Your corporate structure, names of officers and directors, business purpose, and relationship to the Debtor or to any member of the Debtor's Family.\n\n19. All Documents related to any pledge(s) of Your Assets to any other Entity.\n\nCase 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 520 of 1063\n\n# Exhibit C-28\n\n#### B2540 (Form 2540 – Subpoena for Rule 2004 Examination) (12/15) Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 521 of\n\n1063\n\nUNITED STATES BANKRUPTCY COURT\n\n**District of Connecticut**\n\nIn re HO WAN KWOK, *et al*.,\n\n<sup>1</sup> Case No. 22-50073 (JAM) Debtor Chapter 11\n\n(Jointly Administered)\n\n# **SUBPOENA FOR RULE 2004 EXAMINATION**\n\nTo: **Tong Le International Trading Co., Ltd.**\n\n(*Name of person to whom the subpoena is directed*)\n\n*Testimony:* **YOU ARE COMMANDED** to appear at the time, date, and place set forth below to testify at an examination under Rule 2004, Federal Rules of Bankruptcy Procedure. A copy of the court order authorizing the examination is attached.\n\n| PLACE                    | DATE AND TIME |\n|--------------------------|---------------|\n| Paul Hastings LLP        |               |\n| 200 Park Avenue          | [TBD]         |\n| New York, New York 10166 |               |\n|                          |               |\n\nThe examination will be recorded by this method: **Court reporter/stenographer**\n\n*Production:* You, or your representatives, must also bring with you to the examination the following documents, electronically stored information, or objects, and must permit inspection, copying, testing, or sampling of the material:\n\n#### **See Requests for Production of Documents, attached hereto.**\n\nThe following provisions of Fed. R. Civ. P. 45, made applicable in bankruptcy cases by Fed. R. Bankr. P. 9016, are attached – Rule 45(c), relating to the place of compliance; Rule 45(d), relating to your protection as a person subject to a subpoena; and Rule 45(e) and 45(g), relating to your duty to respond to this subpoena and the potential consequences of not doing so.\n\nDate: **March , 2023**\n\nCLERK OF COURT\n\nOR\n\n*Signature of Clerk or Deputy Clerk Attorney's signature*\n\nThe name, address, email address, and telephone number of the attorney representing Luc A. Despins, Chapter 11 Trustee, who issues or requests this subpoena, are:\n\n**Douglas S. Skalka, Esq.; Neubert, Pepe & Monteith, P.C.; 195 Church Street, New Haven, Connecticut 06510 dskalka@npmlaw.com; (203) 821-2000**\n\n**Notice to the person who issues or requests this subpoena**\n\nIf this subpoena commands the production of documents, electronically stored information, or tangible things, or the inspection of premises before trial, a notice and a copy of this subpoena must be served on each party before it is served on the person to whom it is directed. Fed. R. Civ. P. 45(a)(4).\n\nSoftware Copyright (c) 1996-2022 Best Case, LLC - www.bestcase.com Best Case Bankruptcy 1 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\n#### **PROOF OF SERVICE**\n\n**(This section should not be filed with the court unless required by Fed. R. Civ. P. 45.)**\n\nI received this subpoena for (*name of individual and title, if any*): on (*date*) .\n\nI served the subpoena by delivering a copy to the named person as follows:\n\non *(date)* ; or\n\nI returned the subpoena unexecuted because:\n\nUnless the subpoena was issued on behalf of the United States, or one of its officers or agents, I have also tendered to the witness the fees for one day's attendance, and the mileage allowed by law, in the amount of \\$ .\n\nMy fees are \\$ for travel and \\$ for services, for a total of \\$ .\n\nI declare under penalty of perjury that this information is true and correct.\n\nDate:\n\n*Server's signature*\n\n*Printed name and title*\n\n*Server's address*\n\nAdditional information concerning attempted service, etc.:\n\n#### **Federal Rule of Civil Procedure 45(c), (d), (e), and (g) (Effective 12/1/13) (made applicable in bankruptcy cases by Rule 9016, Federal Rules of Bankruptcy Procedure)**\n\n#### **(c) Place of compliance.**\n\n*(1) For a Trial, Hearing, or Deposition.* A subpoena may command a person to attend a trial, hearing, or deposition only as follows:\n\n(A) within 100 miles of where the person resides, is employed, or regularly transacts business in person; or\n\n(B) within the state where the person resides, is employed, or regularly transacts business in person, if the person\n\n(i) is a party or a party's officer; or\n\n(ii) is commanded to attend a trial and would not incur substantial expense.\n\n*(2) For Other Discovery.* A subpoena may command:\n\n(A) production of documents, or electronically stored information, or things at a place within 100 miles of where the person resides, is employed, or regularly transacts business in person; and\n\n(B) inspection of premises, at the premises to be inspected.\n\n#### **(d) Protecting a Person Subject to a Subpoena; Enforcement.**\n\n*(1) Avoiding Undue Burden or Expense; Sanctions.* A party or attorney responsible for issuing and serving a subpoena must take reasonable steps to avoid imposing undue burden or expense on a person subject to the subpoena. The court for the district where compliance is required must enforce this duty and impose an appropriate sanction which may include lost earnings and reasonable attorney's fees — on a party or attorney who fails to comply.\n\n#### *(2) Command to Produce Materials or Permit Inspection.*\n\n*(A) Appearance Not Required.* A person commanded to produce documents, electronically stored information, or tangible things, or to permit the inspection of premises, need not appear in person at the place of production or inspection unless also commanded to appear for a deposition, hearing, or trial.\n\n*(B) Objections.* A person commanded to produce documents or tangible things or to permit inspection may serve on the party or attorney designated in the subpoena a written objection to inspecting, copying, testing or sampling any or all of the materials or to inspecting the premises — or to producing electronically stored information in the form or forms requested. The objection must be served before the earlier of the time specified for compliance or 14 days after the subpoena is served. If an objection is made, the following rules apply:\n\n(i) At any time, on notice to the commanded person, the serving party may move the court for the district where compliance is required for an order compelling production or inspection.\n\n(ii) These acts may be required only as directed in the order, and the order must protect a person who is neither a party nor a party's officer from significant expense resulting from compliance.\n\n#### *(3) Quashing or Modifying a Subpoena.*\n\n*(A) When Required.* On timely motion, the court for the district where compliance is required must quash or modify a subpoena that:\n\n(i) fails to allow a reasonable time to comply;\n\n(ii) requires a person to comply beyond the geographical limits specified in Rule 45(c);\n\n(iii) requires disclosure of privileged or other protected matter, if no exception or waiver applies; or\n\n(iv) subjects a person to undue burden.\n\n*(B) When Permitted.* To protect a person subject to or affected by a subpoena, the court for the district where compliance is required may, on motion, quash or modify the subpoena if it requires:\n\n(i) disclosing a trade secret or other confidential research, development, or commercial information; or\n\n(ii) disclosing an unretained expert's opinion or information that does not describe specific occurrences in dispute and results from the expert's study that was not requested by a party.\n\n(C) *Specifying Conditions as an Alternative.* In the circumstances described in Rule 45(d)(3)(B), the court may, instead of quashing or modifying a subpoena, order appearance or production under specified conditions if the serving party:\n\n(i) shows a substantial need for the testimony or material that cannot be otherwise met without undue hardship; and\n\n(ii) ensures that the subpoenaed person will be reasonably compensated.\n\n#### **(e) Duties in Responding to a Subpoena.**\n\n*(1) Producing Documents or Electronically Stored Information.* These procedures apply to producing documents or electronically stored information:\n\n*(A) Documents.* A person responding to a subpoena to produce documents must produce them as they are kept in the ordinary course of business or must organize and label them to correspond to the categories in the demand.\n\n*(B) Form for Producing Electronically Stored Information Not Specified.* If a subpoena does not specify a form for producing electronically stored information, the person responding must produce it in a form or forms in which it is ordinarily maintained or in a reasonably usable form or forms.\n\n*(C) Electronically Stored Information Produced in Only One Form.* The person responding need not produce the same electronically stored information in more than one form.\n\n*(D) Inaccessible Electronically Stored Information.* The person responding need not provide discovery of electronically stored information from sources that the person identifies as not reasonably accessible because of undue burden or cost. On motion to compel discovery or for a protective order, the person responding must show that the information is not reasonably accessible because of undue burden or cost. If that showing is made, the court may nonetheless order discovery from such sources if the requesting party shows good cause, considering the limitations of Rule 26(b)(2)(C). The court may specify conditions for the discovery.\n\n#### *(2) Claiming Privilege or Protection.*\n\n*(A) Information Withheld.* A person withholding subpoenaed information under a claim that it is privileged or subject to protection as trial-preparation material must: (i) expressly make the claim; and\n\n(ii) describe the nature of the withheld documents, communications, or tangible things in a manner that, without revealing information itself privileged or protected, will enable the parties to assess the claim.\n\n*(B) Information Produced.* If information produced in response to a subpoena is subject to a claim of privilege or of protection as trial-preparation material, the person making the claim may notify any party that received the information of the claim and the basis for it. After being notified, a party must promptly return, sequester, or destroy the specified information and any copies it has; must not use or disclose the information until the claim is resolved; must take reasonable steps to retrieve the information if the party disclosed it before being notified; and may promptly present the information under seal to the court for the district where compliance is required for a determination of the claim. The person who produced the information must preserve the information until the claim is resolved.\n\n**(g) Contempt.** The court for the district where compliance is required – and also, after a motion is transferred, the issuing court – may hold in contempt a person who, having been served, fails without adequate excuse to obey the subpoena or an order related to it.\n\nFor access to subpoena materials, see Fed.R.Civ.P.45(a) Committee Note (2013)\n\n…\n\n## **Requests for Production of Documents**\n\n## **I. INSTRUCTIONS**\n\n1. Unless otherwise indicated, the requests for documents set forth below, (the \"Requests,\" and each, a \"Request\"), must be responded to separately and specifically. Each Request shall be answered fully unless it is in good faith objected to, in which event the reason for Your objection shall be stated in detail, as set forth below. If an objection pertains only to a portion of a Request, or a word, phrase or clause contained within it, You are required to state Your objection to that portion only and to respond to the remainder of the Requests.\n\n2. Electronically stored information must be produced in accordance with the\n\nfollowing instructions:\n\n- a. Images. Black and white images must be 300 DPI Group IV single-page TIFF files. Color images must be produced in JPEG format. File names cannot contain embedded spaces or special characters (including the comma). Folder names cannot contain embedded spaces or special characters (including the comma). All TIFF image files must have a unique file name, i.e. Bates number. Images must be endorsed with sequential Bates numbers in the lower right corner of each image. The number of TIFF files per folder should not exceed 1000 files. Excel spreadsheets should have a placeholder image named by the Bates number of the file.\n- b. Image Load File\n\t- a. Concordance® Data File. The data file (.DAT) contains all of the fielded information that will be loaded into the Concordance® database. The first line of the .DAT file must be a header row identifying the field names. The .DAT file must use the following Concordance® default delimiters: Comma ASCII character (020) Quote þ ASCII character (254). Date fields should be provided in the format: mm/dd/yyyy. Date and time fields must be two separate fields. If documents includes imaged emails and attachments, the attachment fields must be included to preserve the parent/child relationship between an email and its attachments. An OCRPATH field must be included to provide the file path and name of the extracted text file on the produced storage media. The text file must be named after the FIRSTBATES. Do not include the text in the .DAT file. For Documents with native files, a LINK field must be included to provide the file path and\n\nname of the native file. The native file must be named after the FIRSTBATES.\n\n- b. Concordance Image® OR Opticon Cross-Reference File. The image crossreference file (.LOG or .OPT) links the images to the database records. It should be a comma-delimited file consisting of seven fields per line with a line in the cross-reference file for every image in the database with the following format: ImageID,VolumeLabel,ImageFilePath,DocumentBreak,FolderBreak,Box Break,PageCoun.\n- c. Document Text. Text must be produced as separate text files, not as fields within the .DAT file. The full path to the text file (OCRPATH) should be included in the .DAT file. It is recommended document level ANSI text files, named per the FIRSTBATES/Image Key. Extracted text files must be in a separate folder, and the number of text files per folder should not exceed 1,000 files. There should be no special characters (including commas in the folder names). Text files must be provided on a document level.\n- d. Native Production for Certain File Types. File types that reasonably require viewing in their native format for a full understanding of their content and meaning must be produced in native format. These include, but are not limited to, spreadsheets, spreadsheet-like files (Microsoft Excel, comma separated values, tab separated values, etc.), Microsoft PowerPoint or other special presentation files, database files, and audio/visual files. Provide an image of a Bates numbered slip sheet indicating the presence of a native file, and include the path to the native as a field in the .dat file. Name the produced native file with the Bates number corresponding to the slip sheet for the file. Group native files within incrementally named \"NATIVE\" directories, separate from images directories.\n- e. De-duplication. Produce a single copy of each electronic document for which exact duplicates exist. For email messages, consolidate duplicates based on MD5 hash generated from the BCC, Body, CC, From, IntMsgID, To, and Attach properties. For email attachments and standalone electronic files, consolidate duplicates based on MD5 hash of the entire file.\n- f. Metadata. Produce extracted metadata for each document in the form of a Concordance compliant load file (.dat). The first line of the .DAT file must be a header row identifying the field names. The .DAT file must use the following Concordance default delimiters: Comma , ASCII character (020) Quote þ ASCII character (254)\n\nDate fields should be provided in the format: mm/dd/yyyy. Date and time fields must be two separate fields. Required metadata listed below:\n\n# Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 526 of 1063\n\n| Field Name   | Sample Data              | Description                                                                                  |\n|--------------|--------------------------|----------------------------------------------------------------------------------------------|\n| FIRSTBATES   | EDC0000001               | First Bates number of native file document/email                                             |\n| LASTBATES    | EDC0000001               | Last Bates number of native file document/email<br>**The LASTBATES field should be populated |\n|              |                          | for single page                                                                              |\n| ATTACHRANGE  | EDC0000001<br>-          | Bates number of the first page of the parent                                                 |\n|              | EDC0000015               | document to the Bates number of the last page of                                             |\n|              |                          | the last attachment \"child\" document                                                         |\n| BEGATTACH    | EDC0000001               | First Bates number of attachment range                                                       |\n| ENDATTACH    | EDC0000015               | Last Bates number of attachment range                                                        |\n| CUSTODIAN    | Smith, John              | Email: Mailbox where the email resided                                                       |\n|              |                          | Native: Name of the individual or department                                                 |\n|              |                          | from whose files the document<br>originated                                                  |\n| FROM         | John Smith               | Email: Sender                                                                                |\n|              |                          | Native: Author(s) of document                                                                |\n|              |                          |                                                                                              |\n|              |                          | **semi-colon should be used to separate                                                      |\n|              |                          | multiple entries                                                                             |\n| TO           | Coffman, Janice; LeeW    | Recipient(s)                                                                                 |\n|              | [mailto:LeeW@MSN.com]    | **semi-colon should be used to separate multiple                                             |\n|              |                          | entries                                                                                      |\n| CC           | Frank Thompson [mailto:  | Carbon copy recipient(s)                                                                     |\n|              | frank_Thompson@cdt.com]  | **semi-colon should be used to separate                                                      |\n|              |                          | multiple entries                                                                             |\n| BCC          | John Cain                | Blind carbon copy recipient(s)                                                               |\n|              |                          | **semi-colon should be used to separate                                                      |\n|              |                          | multiple entries                                                                             |\n| SUBJECT      | Board Meeting Minutes    | Email: Subject line of the email Native: Title                                               |\n|              |                          | of document (if available)                                                                   |\n| FILE_NAME    | BoardMeetingMinutes.docx | Native: Name of the original native file,                                                    |\n|              |                          | including extension                                                                          |\n| DATE_SENT    | 10/12/2010               | Email: Date the email was sent                                                               |\n|              |                          | Native: (empty)                                                                              |\n| TIME_SENT/   | 07:05 PM GMT             | Email: Time the email was sent/ Time zone in                                                 |\n| TIME_ZONE    |                          | which the emails were standardized                                                           |\n| TIME_ZONE    | GMT                      | The<br>time zone in which<br>the emails<br>were                                              |\n|              |                          | standardized during conversion.                                                              |\n| LINK         |  EDC0000001.msg   | Hyperlink to the email or native file document                                               |\n|              |                          | **The linked file must be named per the                                                      |\n|              |                          | FIRSTBATES number                                                                            |\n| FILE_EXTEN   | MSG                      | The file type extension                                                                      |\n|              |                          | representing                                                                                 |\n|              |                          | the Email or                                                                                 |\n| AUTHOR       | John Smith               | Email: (empty)                                                                               |\n|              |                          | Native: Author of the document                                                               |\n| DATE_CREATED | 10/10/2010               | Email: (empty)                                                                               |\n|              |                          | Native: Date the document was created                                                        |\n|              |                          |                                                                                              |\n\n# Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 527 of 1063\n\n| TIME_CREATED | 10:25 AM                  | Email: (empty)                                  |\n|--------------|---------------------------|-------------------------------------------------|\n|              |                           | Native: Time the document was created           |\n|              |                           | **This data must be a separate field and cannot |\n|              |                           | be combined with the DATE_CREATED field         |\n| DATE_MOD     | 10/12/2010                | Email: (empty)                                  |\n|              |                           | Native: Date the document was last modified     |\n| TIME_MOD     | 07:00 PM                  | Email: (empty)                                  |\n|              |                           | Native: Time the document was last modified     |\n|              |                           | **This data must be a separate field and cannot |\n|              |                           | be combined with the DATE_MOD field             |\n| DATE_ACCESSD | 10/12/2010                | Email: (empty)                                  |\n|              |                           | Native: Date the document was last accessed     |\n| TIME_ACCESSD | 07:00 PM                  | Email: (empty)                                  |\n|              |                           | Native: Time the document was last accessed     |\n|              |                           | **This data must be a separate field and cannot |\n|              |                           | be combined with the DATE_ACCESSD field         |\n| FILE_SIZE    | 5,952                     | Size of native file<br>document/email in KB     |\n| PGCOUNT      | 1                         | Number of pages in native file document/email   |\n| PATH         |   | Email: (empty)                                  |\n|              | Agenda.doc                | Native: Path where native file document was     |\n|              |                           | stored including original file name.            |\n| INTFILEPATH  | Personal Folders\\Deleted  | Email: original location of email including     |\n|              | Items\\Board Meeting       | original file name.                             |\n|              | Minutes.msg               | Native: (empty)                                 |\n| INTMSGID     | <000805c2c71b\\$75977050\\$ | Email: Unique Message ID Native: (empty)        |\n|              | cb8306d1@MSN>             |                                                 |\n| MD5HASH      | d131dd02c5e6eec4693d9a0   | MD5 Hash value of the document.                 |\n|              | 698aff95c                 |                                                 |\n|              | 2fcab58712467eab4004583e  |                                                 |\n|              | b8fb7f89                  |                                                 |\n| OCRPATH      | TEXT/001/EDC0000001.txt   | Path to extracted text of the native file       |\n\n3. Each Request operates and should be construed independently and, unless otherwise indicated, no Request limits the scope of any other Request.\n\n4. All Documents are to be produced as kept in the usual course of business or are to be organized and labeled to correspond with the categories in these Requests.\n\n5. Each Request contained herein extends to all Documents: (a) in Your possession, custody, or control; or (b) in the possession, custody, or control of anyone acting on Your behalf,\n\n#### Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 528 of 1063\n\nincluding Your counsel or other representatives and advisors. Each Document shall be produced in its entirety.\n\n6. If You are requested to produce a Document that is no longer in Your possession, custody, or control, then Your response must (a) describe in detail the nature of the document and its contents; (b) identify the person(s) who prepared or authored the Document (and, if applicable, the Person(s) to whom the Document was sent); (c) identify the date on which the document was prepared or created; (d) state whether such Document (i) is missing or lost, (ii) has been destroyed, (iii) has been transferred, voluntarily or involuntarily, to others, or (iv) was otherwise disposed of; (e) state the reason for, and the facts and circumstances surrounding, such disposition; (f) identify the Persons who authorized such disposition; (g) identify the date or approximate date of such disposition; (h) state when the Document was most recently in Your possession, custody or control; and (i) identify the Person, if any, presently in possession, custody, or control of such Document.\n\n7. If You are requested to produce a Document that has been destroyed, then Your response must state, in addition to the information required by the preceding Instruction: (a) the reason for the Document's destruction; (b) the identity of the Person who destroyed the Document; and (c) the identity of the Person who directed that the Document be destroyed.\n\n8. If You claim that a requested Document is privileged or attorney work-product, then Your response must: (a) state (i) a description of the Document adequate to support Your contention that the Document is privileged, (ii) the title of the Document, (iii) the date of the Document, (iv) the author of the Document, (v) the addressee of the Document, (vi) the identity of each Person who received or saw the original or any draft, copy, or reproduction of the Document, (vii) whether the Document itself, or any information contained or referred to in the Document is in the possession, custody, or control of any other Persons, and if so, the identity of\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 529 of 1063\n\nsuch Persons, as well as a statement addressing how the information came into their possession, (viii) the claim of privilege under which the Document is withheld, and (ix) all of the circumstances upon which You will rely to support such claim of privilege; and (b) produce a privilege log containing all of the information requested in Part (a) of this Instruction for each Document withheld on the basis of a claim of privilege in accordance with D. Conn. L. Civ. R. 26(e).\n\n9. If a portion of an otherwise responsive Document contains information subject to a claim of privilege, only that portion of the Document subject to the claim of privilege shall be deleted or redacted from the Document following the instructions above, and the rest shall be produced.\n\n10. The Requests are continuing in nature. You are hereby instructed to (a) supplement or correct any responses later learned to be incomplete or incorrect immediately upon learning that a prior response was incomplete or incorrect; and (b) produce any additional Documents that are called for under the\n\n11. If a Document is in a language other than English, You should provide that Document. If a Document is in a language other than English, and an English translation exists, You should provide both Documents.\n\n12. All references to Entities includes all affiliates thereof.\n\n13. All references to individual names include all alternative names, aliased, or nicknames.\n\n14. Unless otherwise expressly indicated, the period of time covered by the Document Requests is the period from February 5, 2012 to the date responses to the Document Requests are due.\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 530 of 1063\n\n#### **II. RULES OF CONSTRUCTION**\n\n15. The use of (a) any singular noun shall be construed to include the plural, and vice versa, and (b) a verb in any tense shall be construed as the use of the verb in all other tenses.\n\n16. The terms (a) \"and\" and \"or\" shall be construed either conjunctively or disjunctively as necessary to bring within the scope of any request all responses that might otherwise be construed to be outside of its scope, and (b) \"each\" and \"any\" shall be deemed to include and encompass the words \"every\" and \"all.\"\n\n#### **III. DEFINITIONS**\n\nThe definitions supplied by D. Conn. L. Civ. R. 26(c) and the rules of construction supplied by D. Conn. L. Civ. R. 26(d), as incorporated by D. Conn. Bankr. L.R. 2004-1(a), shall apply to the Document Requests. In addition, the following terms used in these Document Requests shall have the following meanings:\n\n1. \"You\" or \"Your\" or \"Yourself\" means and refers to Tong Le Internatiional Trading Co., Ltd., together with all of its affiliates, divisions, agencies, instrumentalities, departments, offices, partners, officers, directors, agents, attorneys, representatives, employees, and/or anyone acting on its behalf.\n\n2. \"Debtor\" means Ho Wan Kwok (a/k/a Miles Kwok, Miles Guo, Guo Wengui, Guo Haoyun, 郭文贵, or any other alias), together with his employees, agents, counsel, advisors, or anyone acting on his behalf.\n\n3. \"Debtor's Son\" means Qiang Guo (a/k/a Mileson Kwok, 郭强, or any other alias), together with his employees, agents, counsel, advisors, or anyone acting on his behalf.\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 531 of 1063\n\n4. \"Debtor's Daughter\" means Mei Guo (a/k/a Mei Gui, 郭美, or any other alias), together with her employees, agents, counsel, advisors, or anyone acting on her behalf.\n\n5. \"Debtor's Purported Wife\" means Hing Chi Ngok (a/k/a Hing Chi Ng, Yue Qingzhi, 岳庆芝, or any other alias), together with her employees, agents, counsel, advisors, or anyone acting on her behalf.\n\n6. \"Debtor's Family\" means, collectively, the Debtor, the Debtor's Son, the Debtor's Daughter, and the Debtor's Purported Wife, and any other familial relation to the Debtor.\n\n7. \"Associated Individuals\" means, individually and collectively, all individuals that (1) hold, control, have custody over, or discretion over assets owned, controlled, or enjoyed by the Debtor or the Debtor's Family; or (2) have been employees, directors, or otherwise are affiliated with one or more Associated Entities, together with the respective employees, agents, counsel, advisors, or anyone acting on behalf of any of the foregoing. Such Associated Individuals shall include, but are not limited to: Daniel Podhaskie, Jason Miller, Steve Bannon, Karin Maistrello, Melissa Francis, Anthony DiBattista, William Gertz, Arethusa Forsyth, Glenn Mellor, Jennifer Mercurio, Eduardo Eurnekian, Wencong Wang, Han Chunguang (a/k/a 韩春光), Qu Guojiao (a/k/a Qu Guo Jiao, 屈国姣), Guo Lijie (a/k/a 郭丽杰), Zhang Wei (a/k/a 张伟\\*), Lihong Wei Lafrenz (a/k/a Sara Wei, 魏丽红), Hao Haidong (a/k/a 郝海东), Ross Heinemeyer, Max Krasner, Kyle Bass, Melissa Mendez, Ya Li (a/k/a 李娅), Dinggang Wang (a/k/a 王定刚), An Hong (a/k/a 安红), Yvette Wang (a/k/a Yanping Wang, Yan Ping Wang, 王雁平), Fiona Yu, Je Kin Ming (a/k/a William Je, Yu Jianming, 余建明), Yaz Qingua, and Lao Jiang (a/k/a Jiang Yunfu, Jiang Yunfu Be, 姜云浮).\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 532 of 1063\n\n8. \"Associated Entities\" means, individually and collectively, all organizations or Entities of any type that (1) have been owned, controlled, or invested in by the Debtor or the Debtor's Family; or (2) have an interest, whether directly or indirectly, in any assets owned, controlled, or enjoyed by the Debtor or the Debtor's Family, together with the respective employees, agents, counsel, advisors, or anyone acting on behalf of any of the foregoing. Such Associated Entities shall include, but are not limited to: 7 Nod Hill LLC, AAGV Limited, ACA Investment Management Limited, ACA Capital Group Limited, Ace Decade Holdings Limited, AI Group Holdings Inc., Alfa Global Ventures Limited, Alfonso Global Limited, Allied Capital Global Limited, Alpine Fiduciaries SA, Anton Development Limited, Assets Sino Limited, Auspicious Coast Limited, Beijing Pangu Investment Co., Beijing Pangu Investment Co. Ltd., Beijing Pangu Investment Inc., Beijing Zenith Holdings Company Limited, Booming Sail New York LLC, Bravo Luck Limited, BSA Strategic Fund I, China Golden Spring (Hong Kong) Limited, Chuang Xin Limited, Crane Advisory Group LLC, Creative Apex Investments Limited, Crystal Breeze Investments Limited, Dawn State Limited, Eastern Profit Corporation Limited, Elite Well Global Limited, Empire Growth Holdings, Freedom Media Ventures Ltd., G Club Operations LLC, G Fashion LLC, G News LLC, GETTR USA, Genever Holdings Corporation, Genever Holdings LLC, Gfashion Media Group Inc., GFNY, Inc., Globalist International Limited, GNews Media Group Inc., Golden Spring (New York) Ltd., Greenwich Land LLC, Guo Media, GTV Media Group, Inc., Hamilton Capital Holdings Inc., HCHK Property Management, Inc., HCHK Technologies, Inc., Head Win Group Limited, Henan Yuda, Himalaya Embassy, Himalaya Exchange, Himalaya Federal Reserve, Himalaya Investment LLC, Himalaya International, Himalaya New World Inc., Himalaya Supervisory Organization, Himalaya Ventures LLC, HK International Funds Investments (USA) Limited LLC, Hong Kong International Funds\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 533 of 1063\n\nInvestments Limited, Hudson Diamond Holding, Infinite Increase Limited, Infinitum Developments Limited, Infinity Treasury Management Inc., Insight Phoenix Fund, Lamp Capital LLC, Leading Shine Limited, Leading Shine NY Limited, Lexington Property and Staffing, Long Gate Limited, Maywind Trading LLC, MOS Himalaya LLC, Next Tycoon Investments Limited, New Federal State of China (a/k/a NFSC), Noble Fame Global Limited, Rosy Acme Ventures Limited, Rule of Law Foundation III, Inc., Rule of Law Foundation IV, Inc., Rule of Law Fund, Rule of Law Society, Rule of Law Society IV, Inc., G-Translators PTY LTD, Saraca Media Group, Inc., Shiny Ace Ltd., Shiny Times Holdings Ltd., Spirit Charter Investment Limited, Stevenson, Wong & Co., Voice of Guo Media, Inc., Well Origin Ltd., World Century Limited, Worldwide Opportunity Holdings Limited, Whitecroft Shore Limited, and ZIBA Limited.\n\n9. \"Including\" or any variant thereof means \"including without limitation.\"\n\n10. \"And\" and \"or\" mean \"and/or,\" and shall be construed both conjunctively as well as disjunctively in order to maximize their scope.\n\n11. \"Any\" and \"all\" and \"each\" mean \"each and every.\"\n\n12. \"Each\" and \"every\" mean \"each and every.\"\n\n13. \"Third Party\" means a Person or Entity other than Yourself.\n\n14. \"Transfer\" shall have the meaning given to it by section 101(54) of the Bankruptcy Code.\n\n15. \"Document\" means any information or thing within the scope of Fed. R. Civ. P. 34, and includes, without limitation, each and every written, recorded, or graphic matter of any kind, type, nature, or description that is or has been in Your Possession, Custody or Control, including all printed and electronic copies of electronic mail, computer files maintained in\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 534 of 1063\n\nelectronic form, electronic communication, text message, social media post, tweet, meta-data, correspondence, memoranda, tapes, stenographic or handwritten notes, written forms of any kind, charts, blueprints, drawings, sketches, graphs, plans, articles, specifications, diaries, letters, telegrams, photographs, minutes, contracts, agreements, surveys, computer printouts, data compilations of any kind, telexes, facsimiles, voice messages, invoices, order forms, checks, drafts, statements, credit memos, reports, position reports, summaries, indices, books, ledgers, notebooks, schedules, transparencies, recordings, catalogs, advertisements, promotional materials, films, video tapes, audio tapes, CDs, computer disks, brochures, pamphlets, punchcards, time-slips, Tweets, social media posts, or any written or recorded materials of any other kind, and all meta-data thereof, however stored (whether in tangible or electronic form), recorded, produced, or reproduced, and also including but not limited to, drafts or copies of any of the foregoing that contain any notes, comments, or markings of any kind not found on the original documents or that are otherwise not identical to the original documents.\n\n16. \"Person(s)\" means an individual, corporation, proprietorship, partnership, association, or any other Entity. \"Person\" also includes any agent, representatives, or expert, including but not limiting to, attorneys or financial advisors.\n\n17. \"Entity\" means any natural Person, corporation, partnership, subsidiary, sole proprietorship, firm, board, joint venture, association, agency, authority, commission or other business entity or juristic Person, as well as any affiliate, agent, parent including but not limited to legal counsel, financial advisors, or any other representative.\n\n18. \"Regarding\" means concerning, describing, comprising, referring to, related to, supporting, favoring, opposing, bolstering, detracting from, located in, considered in connection with, bearing on, evidencing, indicating, reporting on, recording, alluding to, responding to,\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 535 of 1063\n\nconnected with, commenting on, in respect of, about, in relation to, discussing, showing, describing, reflecting, analyzing constituting, and being.\n\n19. \"Relating to,\" \"relate(s) to\" or \"related to,\" when referring to any given subject matter, means, without limitation, any document that constitutes, comprises, involves, contains, embodies, reflects, identifies, states, refers directly or indirectly to, or is in any way relevant to the particular subject matter identified.\n\n20. \"Communication(s)\" means, in the broadest possible sense, and without limitation, any transmittal of information or knowledge (in the form of facts, ideas, inquiries, or otherwise). Communication(s) further refers to all conversations, agreements, inquiries, or replies, whether in person, by telephone, in writing, or by means of electronic transmittal devices, and includes, but is not limited to, all correspondence, emails, recordings, transmittal slips, memoranda, telephone communications, voice messages, telegrams, telefaxes, telecopies, telexes, instant messages, chats, text messages, telephonic notes, or notes transmitted internally or with third parties.\n\n21. \"Asset(s)\" means any item that can be used to produce positive economic value, including but not limited to any resource with economic value that is owned, controlled or is for the benefit of an entity, that is expected to provide a future benefit, including but not limited to, all real and personal property, intangible property, investments, rights to invest or to future revenue, cash, bank accounts, commodities, securities, claims, total or partial control of an entity, and prospective economic opportunities\n\n22. \"Transfer\" shall have the meaning given to it by section 101(54) of the Bankruptcy Code.\n\n#### **IV. DOCUMENTS TO BE PRODUCED**\n\n1. All Documents regarding any income or Asset of the Debtor, the Debtor's estate, or an Associated Entity.\n\n2. All Documents related to the Debtor's financial condition and obligations to his creditors, including without limitation all Documents related to any effort to avoid paying such obligations and All Documents related to this or any other actual or potential bankruptcy or similar insolvency proceeding.\n\n3. All Documents regarding any balance sheet, bank statement, account statement, financial statement, statement of account, wire transfer instructions and/or confirmation, proof of funds, certificate of deposit, certificate of holdings, investment portfolio summary, or similar document relating to the Debtor, the Debtor's Estate, the Debtor's Family, an Associated Entity, or an Associated Individual, including without limitation all Documents sufficient to show all Transfers to any of the foregoing.\n\n4. All Documents regarding any investment, business dealing or transactions made by, with, or on behalf of the Debtor.\n\n5. All Communications with the Debtor, and Documents related to Communications with the Debtor, related to the operation, management, or decision-making of any Entity, including without limitation the Associated Entities.\n\n6. All Documents regarding any Transfer, investment, or other transaction or business dealing made to, by, or with the Debtor, the Debtor's Family, or an Associated Entity.\n\n7. All Documents regarding any property ever occupied or used by the Debtor, including without limitation the *Lady May*; the Sherry Netherland Hotel / Condominium; the\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 537 of 1063\n\nresidential property located in Greenwich, Connecticut at 373 Taconic Rd.; the residential property located in Greenwich, Connecticut at 33 Ferncliff Rd.; and the residential property located in Wilton, Connecticut at 354 Nod Hill Rd.\n\n8. All Documents related to any aircraft owned, controlled, or used by the Debtor, including without limitation the aircraft bearing tail number T7-GQM and any other aircraft registered in San Marino, including without limitation copies of all registration documents and flight manifests showing flights taken by such aircraft and the individuals onboard such flights.\n\n9. All Documents regarding any gifts, benefits or loans, to, from or on behalf of the Debtor, the Debtor's Estate, the Debtor's Family, or the Associated Entities, including without limitation Documents sufficient to show the amounts of such gifts, benefits, or loans; the purposes for which such gifts, benefits, or loans were used; when the gifts, benefits, or loans were provided; and the terms of any loans, all representations and warranties made in connection with any loans, the interest rate on any loans, and all evidence of payments of any loans.\n\n10. All Documents concerning any trust or similar instrument set up by, on behalf of, or for the benefit of the Debtor, the Debtor's Estate, the Debtor's Family, or an Associated Entity, including without limitation Documents sufficient to show when the trust(s) was created, by whom it was created, for whose benefit it was created, and the corpus of the trust.\n\n11. All Documents related to any obligation, claim, liability, or debt associated with any legal dispute involving the Debtor, including but not limited to those relating to any litigation before any local, state, federal, or international body, whether an administrative body, court, panel, or alternative dispute resolution entity.\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 538 of 1063\n\n12. All Documents and communications between any of your outside counsel or other advisors and the Debtor.\n\n13. Documents sufficient to show all of Your Assets and sources of income or funding.\n\n14. For all Assets identified in response to Request 14 having a value of more than \\$50,000, all (i) Documents related to Your acquisition of such Asset and (ii) Communications with the Debtor or the Debtor's Family regarding such Asset.\n\n15. Copies of Your tax returns.\n\n16. Documents sufficient to show all bank accounts and investment accounts within Your possession or control, including the balances of and transfers to and from each such account.\n\n17. All Documents regarding any credit cards used by You, including without limitation monthly statements or other Documents sufficient to show all purchases related thereto for the benefit of the Debtor or an Associated Entity.\n\n18. All corporate governance and organizational Documents, including without limitation by-laws and certificates of incorporation and other Documents sufficient to show Your corporate structure, names of officers and directors, business purpose, and relationship to the Debtor or to any member of the Debtor's Family.\n\n19. All Documents related to any pledge(s) of Your Assets to any other Entity.\n\nCase 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 539 of 1063\n\n# Exhibit C-29\n\n#### B2540 (Form 2540 – Subpoena for Rule 2004 Examination) (12/15) Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 540 of\n\n1063\n\nUNITED STATES BANKRUPTCY COURT\n\n**District of Connecticut**\n\nIn re HO WAN KWOK, *et al*.,\n\n<sup>1</sup> Case No. 22-50073 (JAM)\n\nDebtor Chapter 11\n\n(Jointly Administered)\n\n## **SUBPOENA FOR RULE 2004 EXAMINATION**\n\n## To: **Manufacturers and Traders Trust Company (d/b/a M&T Bank)**\n\n(*Name of person to whom the subpoena is directed*)\n\n*Testimony:* **YOU ARE COMMANDED** to appear at the time, date, and place set forth below to testify at an examination under Rule 2004, Federal Rules of Bankruptcy Procedure. A copy of the court order authorizing the examination is attached.\n\n| PLACE                          | DATE AND TIME |\n|--------------------------------|---------------|\n| Neubert, Pepe & Monteith, P.C. |               |\n| 195 Church Street, Floor 13    | [TBD]         |\n| New Haven, Connecticut 06510   |               |\n|                                |               |\n\nThe examination will be recorded by this method: **Court reporter/stenographer**\n\n*Production:* You, or your representatives, must also bring with you to the examination the following documents, electronically stored information, or objects, and must permit inspection, copying, testing, or sampling of the material:\n\n#### **See Requests for Production of Documents, attached hereto.**\n\nThe following provisions of Fed. R. Civ. P. 45, made applicable in bankruptcy cases by Fed. R. Bankr. P. 9016, are attached – Rule 45(c), relating to the place of compliance; Rule 45(d), relating to your protection as a person subject to a subpoena; and Rule 45(e) and 45(g), relating to your duty to respond to this subpoena and the potential consequences of not doing so.\n\nDate: **March , 2023**\n\nCLERK OF COURT\n\nOR\n\n*Signature of Clerk or Deputy Clerk Attorney's signature*\n\nThe name, address, email address, and telephone number of the attorney representing Luc A. Despins, Chapter 11 Trustee, who issues or requests this subpoena, are:\n\n**Douglas S. Skalka, Esq.; Neubert, Pepe & Monteith, P.C.; 195 Church Street, New Haven, Connecticut 06510 dskalka@npmlaw.com; (203) 821-2000**\n\n**Notice to the person who issues or requests this subpoena**\n\nIf this subpoena commands the production of documents, electronically stored information, or tangible things, or the inspection of premises before trial, a notice and a copy of this subpoena must be served on each party before it is served on the person to whom it is directed. Fed. R. Civ. P. 45(a)(4).\n\nSoftware Copyright (c) 1996-2022 Best Case, LLC - www.bestcase.com Best Case Bankruptcy 1 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\n#### **PROOF OF SERVICE**\n\n**(This section should not be filed with the court unless required by Fed. R. Civ. P. 45.)**\n\nI received this subpoena for (*name of individual and title, if any*): on (*date*) .\n\nI served the subpoena by delivering a copy to the named person as follows:\n\non *(date)* ; or\n\nI returned the subpoena unexecuted because:\n\nUnless the subpoena was issued on behalf of the United States, or one of its officers or agents, I have also tendered to the witness the fees for one day's attendance, and the mileage allowed by law, in the amount of \\$ .\n\nMy fees are \\$ for travel and \\$ for services, for a total of \\$ .\n\nI declare under penalty of perjury that this information is true and correct.\n\nDate:\n\n*Server's signature*\n\n*Printed name and title*\n\n*Server's address*\n\nAdditional information concerning attempted service, etc.:\n\n#### **Federal Rule of Civil Procedure 45(c), (d), (e), and (g) (Effective 12/1/13) (made applicable in bankruptcy cases by Rule 9016, Federal Rules of Bankruptcy Procedure)**\n\n#### **(c) Place of compliance.**\n\n*(1) For a Trial, Hearing, or Deposition.* A subpoena may command a person to attend a trial, hearing, or deposition only as follows:\n\n(A) within 100 miles of where the person resides, is employed, or regularly transacts business in person; or\n\n(B) within the state where the person resides, is employed, or regularly transacts business in person, if the person\n\n(i) is a party or a party's officer; or\n\n(ii) is commanded to attend a trial and would not incur substantial expense.\n\n*(2) For Other Discovery.* A subpoena may command:\n\n(A) production of documents, or electronically stored information, or things at a place within 100 miles of where the person resides, is employed, or regularly transacts business in person; and\n\n(B) inspection of premises, at the premises to be inspected.\n\n#### **(d) Protecting a Person Subject to a Subpoena; Enforcement.**\n\n*(1) Avoiding Undue Burden or Expense; Sanctions.* A party or attorney responsible for issuing and serving a subpoena must take reasonable steps to avoid imposing undue burden or expense on a person subject to the subpoena. The court for the district where compliance is required must enforce this duty and impose an appropriate sanction which may include lost earnings and reasonable attorney's fees — on a party or attorney who fails to comply.\n\n#### *(2) Command to Produce Materials or Permit Inspection.*\n\n*(A) Appearance Not Required.* A person commanded to produce documents, electronically stored information, or tangible things, or to permit the inspection of premises, need not appear in person at the place of production or inspection unless also commanded to appear for a deposition, hearing, or trial.\n\n*(B) Objections.* A person commanded to produce documents or tangible things or to permit inspection may serve on the party or attorney designated in the subpoena a written objection to inspecting, copying, testing or sampling any or all of the materials or to inspecting the premises — or to producing electronically stored information in the form or forms requested. The objection must be served before the earlier of the time specified for compliance or 14 days after the subpoena is served. If an objection is made, the following rules apply:\n\n(i) At any time, on notice to the commanded person, the serving party may move the court for the district where compliance is required for an order compelling production or inspection.\n\n(ii) These acts may be required only as directed in the order, and the order must protect a person who is neither a party nor a party's officer from significant expense resulting from compliance.\n\n#### *(3) Quashing or Modifying a Subpoena.*\n\n*(A) When Required.* On timely motion, the court for the district where compliance is required must quash or modify a subpoena that:\n\n(i) fails to allow a reasonable time to comply;\n\n(ii) requires a person to comply beyond the geographical limits specified in Rule 45(c);\n\n(iii) requires disclosure of privileged or other protected matter, if no exception or waiver applies; or\n\n(iv) subjects a person to undue burden.\n\n*(B) When Permitted.* To protect a person subject to or affected by a subpoena, the court for the district where compliance is required may, on motion, quash or modify the subpoena if it requires:\n\n(i) disclosing a trade secret or other confidential research, development, or commercial information; or\n\n(ii) disclosing an unretained expert's opinion or information that does not describe specific occurrences in dispute and results from the expert's study that was not requested by a party.\n\n(C) *Specifying Conditions as an Alternative.* In the circumstances described in Rule 45(d)(3)(B), the court may, instead of quashing or modifying a subpoena, order appearance or production under specified conditions if the serving party:\n\n(i) shows a substantial need for the testimony or material that cannot be otherwise met without undue hardship; and\n\n(ii) ensures that the subpoenaed person will be reasonably compensated.\n\n#### **(e) Duties in Responding to a Subpoena.**\n\n*(1) Producing Documents or Electronically Stored Information.* These procedures apply to producing documents or electronically stored information:\n\n*(A) Documents.* A person responding to a subpoena to produce documents must produce them as they are kept in the ordinary course of business or must organize and label them to correspond to the categories in the demand.\n\n*(B) Form for Producing Electronically Stored Information Not Specified.* If a subpoena does not specify a form for producing electronically stored information, the person responding must produce it in a form or forms in which it is ordinarily maintained or in a reasonably usable form or forms.\n\n*(C) Electronically Stored Information Produced in Only One Form.* The person responding need not produce the same electronically stored information in more than one form.\n\n*(D) Inaccessible Electronically Stored Information.* The person responding need not provide discovery of electronically stored information from sources that the person identifies as not reasonably accessible because of undue burden or cost. On motion to compel discovery or for a protective order, the person responding must show that the information is not reasonably accessible because of undue burden or cost. If that showing is made, the court may nonetheless order discovery from such sources if the requesting party shows good cause, considering the limitations of Rule 26(b)(2)(C). The court may specify conditions for the discovery.\n\n#### *(2) Claiming Privilege or Protection.*\n\n*(A) Information Withheld.* A person withholding subpoenaed information under a claim that it is privileged or subject to protection as trial-preparation material must: (i) expressly make the claim; and\n\n(ii) describe the nature of the withheld documents, communications, or tangible things in a manner that, without revealing information itself privileged or protected, will enable the parties to assess the claim.\n\n*(B) Information Produced.* If information produced in response to a subpoena is subject to a claim of privilege or of protection as trial-preparation material, the person making the claim may notify any party that received the information of the claim and the basis for it. After being notified, a party must promptly return, sequester, or destroy the specified information and any copies it has; must not use or disclose the information until the claim is resolved; must take reasonable steps to retrieve the information if the party disclosed it before being notified; and may promptly present the information under seal to the court for the district where compliance is required for a determination of the claim. The person who produced the information must preserve the information until the claim is resolved.\n\n**(g) Contempt.** The court for the district where compliance is required – and also, after a motion is transferred, the issuing court – may hold in contempt a person who, having been served, fails without adequate excuse to obey the subpoena or an order related to it.\n\nFor access to subpoena materials, see Fed.R.Civ.P.45(a) Committee Note (2013)\n\n…\n\n## **Request for Production of Documents**\n\n## **I. INSTRUCTIONS**\n\n1. Unless otherwise indicated, the requests for documents set forth below, (the \"Requests,\" and each, a \"Request\"), must be responded to separately and specifically. Each Request shall be answered fully unless it is in good faith objected to, in which event the reason for Your objection shall be stated in detail, as set forth below. If an objection pertains only to a portion of a Request, or a word, phrase or clause contained within it, You are required to state Your objection to that portion only and to respond to the remainder of the Requests.\n\n2. Electronically stored information must be produced in accordance with the\n\nfollowing instructions:\n\n- a. Images. Black and white images must be 300 DPI Group IV single-page TIFF files. Color images must be produced in JPEG format. File names cannot contain embedded spaces or special characters (including the comma). Folder names cannot contain embedded spaces or special characters (including the comma). All TIFF image files must have a unique file name, i.e. Bates number. Images must be endorsed with sequential Bates numbers in the lower right corner of each image. The number of TIFF files per folder should not exceed 1000 files. Excel spreadsheets should have a placeholder image named by the Bates number of the file.\n- b. Image Load File\n\t- a. Concordance® Data File. The data file (.DAT) contains all of the fielded information that will be loaded into the Concordance® database. The first line of the .DAT file must be a header row identifying the field names. The .DAT file must use the following Concordance® default delimiters: Comma ASCII character (020) Quote þ ASCII character (254). Date fields should be provided in the format: mm/dd/yyyy. Date and time fields must be two separate fields. If documents includes imaged emails and attachments, the attachment fields must be included to preserve the parent/child relationship between an email and its attachments. An OCRPATH field must be included to provide the file path and name of the extracted text file on the produced storage media. The text file must be named after the FIRSTBATES. Do not include the text in the .DAT file. For Documents with native files, a LINK field must be included to provide the file path and\n\nname of the native file. The native file must be named after the FIRSTBATES.\n\n- b. Concordance Image® OR Opticon Cross-Reference File. The image crossreference file (.LOG or .OPT) links the images to the database records. It should be a comma-delimited file consisting of seven fields per line with a line in the cross-reference file for every image in the database with the following format: ImageID,VolumeLabel,ImageFilePath,DocumentBreak,FolderBreak,Box Break,PageCoun.\n- c. Document Text. Text must be produced as separate text files, not as fields within the .DAT file. The full path to the text file (OCRPATH) should be included in the .DAT file. It is recommended document level ANSI text files, named per the FIRSTBATES/Image Key. Extracted text files must be in a separate folder, and the number of text files per folder should not exceed 1,000 files. There should be no special characters (including commas in the folder names). Text files must be provided on a document level.\n- d. Native Production for Certain File Types. File types that reasonably require viewing in their native format for a full understanding of their content and meaning must be produced in native format. These include, but are not limited to, spreadsheets, spreadsheet-like files (Microsoft Excel, comma separated values, tab separated values, etc.), Microsoft PowerPoint or other special presentation files, database files, and audio/visual files. Provide an image of a Bates numbered slip sheet indicating the presence of a native file, and include the path to the native as a field in the .dat file. Name the produced native file with the Bates number corresponding to the slip sheet for the file. Group native files within incrementally named \"NATIVE\" directories, separate from images directories.\n- e. De-duplication. Produce a single copy of each electronic document for which exact duplicates exist. For email messages, consolidate duplicates based on MD5 hash generated from the BCC, Body, CC, From, IntMsgID, To, and Attach properties. For email attachments and standalone electronic files, consolidate duplicates based on MD5 hash of the entire file.\n- f. Metadata. Produce extracted metadata for each document in the form of a Concordance compliant load file (.dat). The first line of the .DAT file must be a header row identifying the field names. The .DAT file must use the following Concordance default delimiters: Comma , ASCII character (020) Quote þ ASCII character (254)\n\nDate fields should be provided in the format: mm/dd/yyyy. Date and time fields must be two separate fields. Required metadata listed below:\n\n# Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 545 of 1063\n\n| Field Name   | Sample Data              | Description                                                                                  |\n|--------------|--------------------------|----------------------------------------------------------------------------------------------|\n| FIRSTBATES   | EDC0000001               | First Bates number of native file document/email                                             |\n| LASTBATES    | EDC0000001               | Last Bates number of native file document/email<br>**The LASTBATES field should be populated |\n|              |                          | for single page                                                                              |\n| ATTACHRANGE  | EDC0000001<br>-          | Bates number of the first page of the parent                                                 |\n|              | EDC0000015               | document to the Bates number of the last page of                                             |\n|              |                          | the last attachment \"child\" document                                                         |\n| BEGATTACH    | EDC0000001               | First Bates number of attachment range                                                       |\n| ENDATTACH    | EDC0000015               | Last Bates number of attachment range                                                        |\n| CUSTODIAN    | Smith, John              | Email: Mailbox where the email resided                                                       |\n|              |                          | Native: Name of the individual or department                                                 |\n|              |                          | from whose files the document<br>originated                                                  |\n| FROM         | John Smith               | Email: Sender                                                                                |\n|              |                          | Native: Author(s) of document                                                                |\n|              |                          |                                                                                              |\n|              |                          | **semi-colon should be used to separate                                                      |\n|              |                          | multiple entries                                                                             |\n| TO           | Coffman, Janice; LeeW    | Recipient(s)                                                                                 |\n|              | [mailto:LeeW@MSN.com]    | **semi-colon should be used to separate multiple                                             |\n|              |                          | entries                                                                                      |\n| CC           | Frank Thompson [mailto:  | Carbon copy recipient(s)                                                                     |\n|              | frank_Thompson@cdt.com]  | **semi-colon should be used to separate                                                      |\n|              |                          | multiple entries                                                                             |\n| BCC          | John Cain                | Blind carbon copy recipient(s)                                                               |\n|              |                          | **semi-colon should be used to separate                                                      |\n|              |                          | multiple entries                                                                             |\n| SUBJECT      | Board Meeting Minutes    | Email: Subject line of the email Native: Title                                               |\n|              |                          | of document (if available)                                                                   |\n| FILE_NAME    | BoardMeetingMinutes.docx | Native: Name of the original native file,                                                    |\n|              |                          | including extension                                                                          |\n| DATE_SENT    | 10/12/2010               | Email: Date the email was sent                                                               |\n|              |                          | Native: (empty)                                                                              |\n| TIME_SENT/   | 07:05 PM GMT             | Email: Time the email was sent/ Time zone in                                                 |\n| TIME_ZONE    |                          | which the emails were standardized                                                           |\n| TIME_ZONE    | GMT                      | The<br>time zone in which<br>the emails<br>were                                              |\n|              |                          | standardized during conversion.                                                              |\n| LINK         |  EDC0000001.msg   | Hyperlink to the email or native file document                                               |\n|              |                          | **The linked file must be named per the                                                      |\n|              |                          | FIRSTBATES number                                                                            |\n| FILE_EXTEN   | MSG                      | The file type extension                                                                      |\n|              |                          | representing                                                                                 |\n|              |                          | the Email or                                                                                 |\n| AUTHOR       | John Smith               | Email: (empty)                                                                               |\n|              |                          | Native: Author of the document                                                               |\n| DATE_CREATED | 10/10/2010               | Email: (empty)                                                                               |\n|              |                          | Native: Date the document was created                                                        |\n|              |                          |                                                                                              |\n\n# Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 546 of 1063\n\n| TIME_CREATED | 10:25 AM                  | Email: (empty)                                  |\n|--------------|---------------------------|-------------------------------------------------|\n|              |                           | Native: Time the document was created           |\n|              |                           | **This data must be a separate field and cannot |\n|              |                           | be combined with the DATE_CREATED field         |\n| DATE_MOD     | 10/12/2010                | Email: (empty)                                  |\n|              |                           | Native: Date the document was last modified     |\n| TIME_MOD     | 07:00 PM                  | Email: (empty)                                  |\n|              |                           | Native: Time the document was last modified     |\n|              |                           | **This data must be a separate field and cannot |\n|              |                           | be combined with the DATE_MOD field             |\n| DATE_ACCESSD | 10/12/2010                | Email: (empty)                                  |\n|              |                           | Native: Date the document was last accessed     |\n| TIME_ACCESSD | 07:00 PM                  | Email: (empty)                                  |\n|              |                           | Native: Time the document was last accessed     |\n|              |                           | **This data must be a separate field and cannot |\n|              |                           | be combined with the DATE_ACCESSD field         |\n| FILE_SIZE    | 5,952                     | Size of native file<br>document/email in KB     |\n| PGCOUNT      | 1                         | Number of pages in native file document/email   |\n| PATH         |   | Email: (empty)                                  |\n|              | Agenda.doc                | Native: Path where native file document was     |\n|              |                           | stored including original file name.            |\n| INTFILEPATH  | Personal Folders\\Deleted  | Email: original location of email including     |\n|              | Items\\Board Meeting       | original file name.                             |\n|              | Minutes.msg               | Native: (empty)                                 |\n| INTMSGID     | <000805c2c71b\\$75977050\\$ | Email: Unique Message ID Native: (empty)        |\n|              | cb8306d1@MSN>             |                                                 |\n| MD5HASH      | d131dd02c5e6eec4693d9a0   | MD5 Hash value of the document.                 |\n|              | 698aff95c                 |                                                 |\n|              | 2fcab58712467eab4004583e  |                                                 |\n|              | b8fb7f89                  |                                                 |\n| OCRPATH      | TEXT/001/EDC0000001.txt   | Path to extracted text of the native file       |\n\n3. Each Request operates and should be construed independently and, unless otherwise indicated, no Request limits the scope of any other Request.\n\n4. All Documents are to be produced as kept in the usual course of business or are to be organized and labeled to correspond with the categories in these Requests.\n\n5. Each Request contained herein extends to all Documents: (a) in Your possession, custody, or control; or (b) in the possession, custody, or control of anyone acting on Your behalf,\n\n#### Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 547 of 1063\n\nincluding Your counsel or other representatives and advisors. Each Document shall be produced in its entirety.\n\n6. If You are requested to produce a Document that is no longer in Your possession, custody, or control, then Your response must (a) describe in detail the nature of the document and its contents; (b) identify the person(s) who prepared or authored the Document (and, if applicable, the Person(s) to whom the Document was sent); (c) identify the date on which the document was prepared or created; (d) state whether such Document (i) is missing or lost, (ii) has been destroyed, (iii) has been transferred, voluntarily or involuntarily, to others, or (iv) was otherwise disposed of; (e) state the reason for, and the facts and circumstances surrounding, such disposition; (f) identify the Persons who authorized such disposition; (g) identify the date or approximate date of such disposition; (h) state when the Document was most recently in Your possession, custody or control; and (i) identify the Person, if any, presently in possession, custody, or control of such Document.\n\n7. If You are requested to produce a Document that has been destroyed, then Your response must state, in addition to the information required by the preceding Instruction: (a) the reason for the Document's destruction; (b) the identity of the Person who destroyed the Document; and (c) the identity of the Person who directed that the Document be destroyed.\n\n8. If You claim that a requested Document is privileged or attorney work-product, then Your response must: (a) state (i) a description of the Document adequate to support Your contention that the Document is privileged, (ii) the title of the Document, (iii) the date of the Document, (iv) the author of the Document, (v) the addressee of the Document, (vi) the identity of each Person who received or saw the original or any draft, copy, or reproduction of the Document, (vii) whether the Document itself, or any information contained or referred to in the Document is in the possession, custody, or control of any other Persons, and if so, the identity of\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 548 of 1063\n\nsuch Persons, as well as a statement addressing how the information came into their possession, (viii) the claim of privilege under which the Document is withheld, and (ix) all of the circumstances upon which You will rely to support such claim of privilege; and (b) produce a privilege log containing all of the information requested in Part (a) of this Instruction for each Document withheld on the basis of a claim of privilege in accordance with D. Conn. L. Civ. R. 26(e). For any part of a Document Request as to which a claim of privilege or work product is not made, responsive documents should be provided in full.\n\n9. If a portion of an otherwise responsive Document contains information subject to a claim of privilege, only that portion of the Document subject to the claim of privilege shall be deleted or redacted from the Document following the instructions above, and the rest shall be produced.\n\n10. The Requests are continuing in nature. You are hereby instructed to (a) supplement or correct any responses later learned to be incomplete or incorrect immediately upon learning that a prior response was incomplete or incorrect; and (b) produce any additional Documents that are called for under the\n\n11. If a Document is in a language other than English, You should provide that Document. If a Document is in a language other than English, and an English translation exists, You should provide both Documents.\n\n12. All references to Entities includes all affiliates thereof.\n\n13. All references to individual names include all alternative names, aliased, or nicknames.\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 549 of 1063\n\n14. Unless otherwise expressly indicated, the period of time covered by the Document Requests is the period from February 5, 2012 to the date responses to the Document Requests are due.\n\n#### **II. RULES OF CONSTRUCTION**\n\n15. The use of (a) any singular noun shall be construed to include the plural, and vice versa, and (b) a verb in any tense shall be construed as the use of the verb in all other tenses.\n\n16. The terms (a) \"and\" and \"or\" shall be construed either conjunctively or disjunctively as necessary to bring within the scope of any request all responses that might otherwise be construed to be outside of its scope, and (b) \"each\" and \"any\" shall be deemed to include and encompass the words \"every\" and \"all.\"\n\n#### **III. DEFINITIONS**\n\nThe definitions supplied by D. Conn. L. Civ. R. 26(c) and the rules of construction supplied by D. Conn. L. Civ. R. 26(d), as incorporated by D. Conn. Bankr. L.R. 2004-1(a), shall apply to the Document Requests. In addition, the following terms used in these Document Requests shall have the following meanings:\n\n1. \"You\" or \"Your\" or \"Yourself\" means and refers, to Manufacturers and Traders Trust Company, together with all of its affiliates.\n\n2. \"Debtor\" means Ho Wan Kwok (a/k/a Miles Kwok, Miles Guo, Guo Wengui, Guo Haoyun, 郭文贵, or any other alias), together with his employees, agents, counsel, advisors, or anyone acting on his behalf.\n\n#### Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 550 of 1063\n\n3. \"Debtor's Son\" means Qiang Guo (a/k/a Mileson Kwok, 郭强, or any other alias), together with his employees, agents, counsel, advisors, or anyone acting on his behalf.\n\n4. \"Debtor's Daughter\" means Mei Guo (a/k/a Mei Gui, 郭美, or any other alias), together with her employees, agents, counsel, advisors, or anyone acting on her behalf.\n\n5. \"Debtor's Purported Wife\" means Hing Chi Ngok (a/k/a Hing Chi Ng, Yue Qingzhi, 岳庆芝, or any other alias), together with her employees, agents, counsel, advisors, or anyone acting on her behalf.\n\n6. \"Debtor's Family\" means, individually and collectively, the Debtor, the Debtor's Son, the Debtor's Daughter, and the Debtor's Purported Wife, and any other familial relation to the Debtor.\n\n7. \"2004 Discovery Targets\" means, individually and collectively, the Debtor, the Debtor's Family, ACA Capital Group Limited, Himalaya International Financial Group Ltd., Himalaya International Clearing Ltd., Himalaya International Payments Ltd., Himalaya International Reserves Ltd., Jesse Brown, William Je, William Je, Eastern Profit Corporation Limited, HK International Funds Investments (USA) Limited LLC, Bravo Luck Limited, Golden Spring (New York) Ltd., Lamp Capital LLC, Greenwich Land LLC, Qu Guo Jiao, Daniel Thomas Podhaskie, Yvette Wang (a/k/a Yanping Wang, a/k/a Yan Ping Wang), Ace Decade Holdings Limited, Dawn State Limited, Rule of Law Society IV Inc., Rule of Law Foundation III, Inc., Rule of Law Foundation IV, Inc., Rule of Law Fund, Rule of Law Society, GTV Media Group, Inc., Voice of Guo Media, Inc., Saraca Media Group Inc., Genever Holdings Corporation, Genever Holdings LLC, Gnews Media Group Inc., G Fashion LLC, Gmusic LLC, Gnews LLC, Geducation, GFNY, Inc., G-Club Investments Limited, G Club Operations LLC, G Club US Operations Inc., G Club US Operations LLC, G Live, LLC, Gbroadcast, LLC, Gposts LLC, HCHK Property\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 551 of 1063\n\nManagement, Inc., HCHK Technologies, Inc., FMV Ltd./Freedom Media Venture Ltd., Roscalitar 2, Himalaya New World Inc., US Himalaya Capital Inc., Hudson Diamond Holding, Inc., Hudson Diamond Holding LLC, Hudson Diamond NY LLC, Infinity Treasury Management Inc., Lexington Property and Staffing, Inc., AI Group Holdings Inc., Hamilton Capital Holdings Inc., Booming Sail New York LLC, Himalaya Ventures LLC, Himalaya Ventures LLC, Himalaya Investment LLC, New York MOS Himalaya LLC, MOS Himalaya LLC, Crane Advisory Group, Maywind Trading LLC, Gettr USA, Inc., Han Chunguang, Bingshang Jiao, Karin Maistrello, Mary Jiang, Jiaming Liu, and Wencong Wang.\n\n8. \"Including\" or any variant thereof means \"including without limitation.\"\n\n9. \"And\" and \"or\" mean \"and/or,\" and shall be construed both conjunctively as well as disjunctively in order to maximize their scope.\n\n10. \"Any\" and \"all\" and \"each\" mean \"each and every.\"\n\n11. \"Each\" and \"every\" mean \"each and every.\"\n\n12. \"Third Party\" means a Person or Entity other than Yourself.\n\n13. \"Transfer\" shall have the meaning given to it by section 101(54) of the Bankruptcy Code.\n\n14. \"Document\" means any information or thing within the scope of Fed. R. Civ. P. 34, and includes, without limitation, each and every written, recorded, or graphic matter of any kind, type, nature, or description that is or has been in Your Possession, Custody or Control, including all printed and electronic copies of electronic mail, computer files maintained in electronic form, correspondence, memoranda, tapes, stenographic or handwritten notes, written forms of any kind, charts, blueprints, drawings, sketches, graphs, plans, articles, specifications, diaries, letters,\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 552 of 1063\n\ntelegrams, photographs, minutes, contracts, agreements, surveys, computer printouts, data compilations of any kind, telexes, facsimiles, emails, text messages, instant messages, voice messages, invoices, order forms, checks, drafts, statements, credit memos, reports, position reports, summaries, indices, books, ledgers, notebooks, schedules, transparencies, recordings, catalogs, advertisements, promotional materials, films, video tapes, audio tapes, CDs, computer disks, brochures, pamphlets, punch-cards, time-slips, Tweets, social media posts, or any written or recorded materials of any other kind, and all meta-data thereof, however stored (whether in tangible or electronic form), recorded, produced, or reproduced, and also including but not limited to, drafts or copies of any of the foregoing that contain any notes, comments, or markings of any kind not found on the original documents or that are otherwise not identical to the original documents.\n\n15. \"Person(s)\" means an individual, corporation, proprietorship, partnership, association, or any other Entity. \"Person\" also includes any agent, representatives, or expert, including but not limiting to, attorneys or financial advisors.\n\n16. \"Entity\" means any natural Person, corporation, partnership, subsidiary, sole proprietorship, firm, board, joint venture, association, agency, authority, commission or other business entity or juristic Person, as well as any affiliate, agent, parent including but not limited to counsel, financial advisors, or any other representative.\n\n17. \"Regarding\" means concerning, describing, comprising, referring to, related to, supporting, favoring, opposing, bolstering, detracting from, located in, considered in connection with, bearing on, evidencing, indicating, reporting on, recording, alluding to, responding to, connected with, commenting on, in respect of, about, in relation to, discussing, showing, describing, reflecting, analyzing constituting, and being.\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 553 of 1063\n\n18. \"Relating to,\" \"relate(s) to\" or \"related to,\" when referring to any given subject matter, means, without limitation, any document that constitutes, comprises, involves, contains, embodies, reflects, identifies, states, refers directly or indirectly to, or is in any way relevant to the particular subject matter identified.\n\n19. \"Communication(s)\" means, in the broadest possible sense, and without limitation, any transmittal of information or knowledge (in the form of facts, ideas, inquiries, or otherwise). Communication(s) further refers to all conversations, agreements, inquiries, or replies, whether in person, by telephone, in writing, or by means of electronic transmittal devices, and includes, but is not limited to, all correspondence, emails, recordings, transmittal slips, memoranda, telephone communications, voice messages, telegrams, telefaxes, telecopies, telexes, instant messages, chats, text messages, postings to a message board or group chat, social media posts, tweets, videos uploaded to any video platform, telephonic notes, or notes transmitted internally or with third parties.\n\n20. \"Asset(s)\" means any item of economic value that is subject to Possession, Custody, or Control. Asset includes all real and personal property, including but limited to, real estate, land, houses, apartments, condominiums, automobiles, yachts, boats, planes, jets, helicopters, cash, bank accounts, cryptocurrencies, securities, accounts receivables, inventory, and other tangible and intangible property.\n\n#### **IV. DOCUMENTS TO BE PRODUCED**\n\n1. All Documents related to any account held by, controlled by, on behalf of, or otherwise related to any of the 2004 Discovery Targets, including any and all account statements, authorizations, power of attorney, trusts, instructions or forms, copies of cancelled checks, correspondence, and wire transfers and related correspondence and instructions.\n\n#### Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 554 of 1063\n\n2. All Documents related to any funds, securities, property, or assets belonging to, held by, controlled by, on behalf of, or otherwise related to any of the 2004 Discovery Targets, including any and all account statements, authorizations, powers of attorney, trusts, instructions or forms, copies of cancelled checks, correspondence, and wire transfers and related correspondence and instructions.\n\n3. All Documents related to any business, commerce or financial transactions, including but not limited to any loan, line of credit, bailment, deposit, swap, securities transactions, mortgage, or ISDA, with any of the 2004 Discovery Targets, including any and all account statements, authorizations, powers of attorney, trusts, instructions or forms, copies of cancelled checks, correspondence, and wire transfers and related correspondence and instructions.\n\n4. All Documents relating to any wire transfer activity relating to the 2004 Discovery Targets, regardless of the existence of any accounts, including but not limited to all wire transfer receipts, account numbers, balances, authorizations, identification information related to the parties to the transfer, correspondence, instructions, or other records.\n\n5. All Documents related to any correspondence and communications between you and the 2004 Discovery Targets.\n\n6. All Documents related to any account with any 2004 Discovery Target relating to opening of the account, authorized users of the account and maintenance of the account.\n\n7. All Documents related to any anti-money laundering, know-your-customer, or other compliance activity relating to any of the 2004 Discovery Targets, including but not limited to any information provided by any of the 2004 Discovery Targets, or learned by You.\n\n8. All Documents relating to any communications with any regulator from any country, including but not limited to the Bank of England, the United States Federal Reserve, the\n\nS.E.C., the CFTC, FINRA, China Securities Regulatory Commission, People's Bank of China, Hong Kong Securities and Futures Commission, and the Hong Kong Monetary Authority relating to any of the 2004 Discovery Targets.\n\nCase 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 556 of 1063\n\n# Exhibit C-30\n\n#### B2540 (Form 2540 – Subpoena for Rule 2004 Examination) (12/15) Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 557 of\n\n1063\n\nUNITED STATES BANKRUPTCY COURT\n\n**District of Connecticut**\n\nIn re HO WAN KWOK, *et al*.,\n\n<sup>1</sup> Case No. 22-50073 (JAM) Debtor Chapter 11\n\n(Jointly Administered)\n\n# **SUBPOENA FOR RULE 2004 EXAMINATION**\n\nTo: **Capital One, N.A.**\n\n(*Name of person to whom the subpoena is directed*)\n\n*Testimony:* **YOU ARE COMMANDED** to appear at the time, date, and place set forth below to testify at an examination under Rule 2004, Federal Rules of Bankruptcy Procedure. A copy of the court order authorizing the examination is attached.\n\n| PLACE                          | DATE AND TIME |\n|--------------------------------|---------------|\n| Neubert, Pepe & Monteith, P.C. |               |\n| 195 Church Street, Floor 13    | [TBD]         |\n| New Haven, Connecticut 06510   |               |\n|                                |               |\n\nThe examination will be recorded by this method: **Court reporter/stenographer**\n\n*Production:* You, or your representatives, must also bring with you to the examination the following documents, electronically stored information, or objects, and must permit inspection, copying, testing, or sampling of the material:\n\n#### **See Requests for Production of Documents, attached hereto.**\n\nThe following provisions of Fed. R. Civ. P. 45, made applicable in bankruptcy cases by Fed. R. Bankr. P. 9016, are attached – Rule 45(c), relating to the place of compliance; Rule 45(d), relating to your protection as a person subject to a subpoena; and Rule 45(e) and 45(g), relating to your duty to respond to this subpoena and the potential consequences of not doing so.\n\nDate: **March , 2023**\n\nCLERK OF COURT\n\nOR\n\n*Signature of Clerk or Deputy Clerk Attorney's signature*\n\nThe name, address, email address, and telephone number of the attorney representing Luc A. Despins, Chapter 11 Trustee, who issues or requests this subpoena, are:\n\n**Douglas S. Skalka, Esq.; Neubert, Pepe & Monteith, P.C.; 195 Church Street, New Haven, Connecticut 06510 dskalka@npmlaw.com; (203) 821-2000**\n\n**Notice to the person who issues or requests this subpoena**\n\nIf this subpoena commands the production of documents, electronically stored information, or tangible things, or the inspection of premises before trial, a notice and a copy of this subpoena must be served on each party before it is served on the person to whom it is directed. Fed. R. Civ. P. 45(a)(4).\n\nSoftware Copyright (c) 1996-2022 Best Case, LLC - www.bestcase.com Best Case Bankruptcy 1 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\n#### **PROOF OF SERVICE**\n\n**(This section should not be filed with the court unless required by Fed. R. Civ. P. 45.)**\n\nI received this subpoena for (*name of individual and title, if any*): on (*date*) .\n\nI served the subpoena by delivering a copy to the named person as follows:\n\non *(date)* ; or\n\nI returned the subpoena unexecuted because:\n\nUnless the subpoena was issued on behalf of the United States, or one of its officers or agents, I have also tendered to the witness the fees for one day's attendance, and the mileage allowed by law, in the amount of \\$ .\n\nMy fees are \\$ for travel and \\$ for services, for a total of \\$ .\n\nI declare under penalty of perjury that this information is true and correct.\n\nDate:\n\n*Server's signature*\n\n*Printed name and title*\n\n*Server's address*\n\nAdditional information concerning attempted service, etc.:\n\n#### **Federal Rule of Civil Procedure 45(c), (d), (e), and (g) (Effective 12/1/13) (made applicable in bankruptcy cases by Rule 9016, Federal Rules of Bankruptcy Procedure)**\n\n#### **(c) Place of compliance.**\n\n*(1) For a Trial, Hearing, or Deposition.* A subpoena may command a person to attend a trial, hearing, or deposition only as follows:\n\n(A) within 100 miles of where the person resides, is employed, or regularly transacts business in person; or\n\n(B) within the state where the person resides, is employed, or regularly transacts business in person, if the person\n\n(i) is a party or a party's officer; or\n\n(ii) is commanded to attend a trial and would not incur substantial expense.\n\n*(2) For Other Discovery.* A subpoena may command:\n\n(A) production of documents, or electronically stored information, or things at a place within 100 miles of where the person resides, is employed, or regularly transacts business in person; and\n\n(B) inspection of premises, at the premises to be inspected.\n\n#### **(d) Protecting a Person Subject to a Subpoena; Enforcement.**\n\n*(1) Avoiding Undue Burden or Expense; Sanctions.* A party or attorney responsible for issuing and serving a subpoena must take reasonable steps to avoid imposing undue burden or expense on a person subject to the subpoena. The court for the district where compliance is required must enforce this duty and impose an appropriate sanction which may include lost earnings and reasonable attorney's fees — on a party or attorney who fails to comply.\n\n#### *(2) Command to Produce Materials or Permit Inspection.*\n\n*(A) Appearance Not Required.* A person commanded to produce documents, electronically stored information, or tangible things, or to permit the inspection of premises, need not appear in person at the place of production or inspection unless also commanded to appear for a deposition, hearing, or trial.\n\n*(B) Objections.* A person commanded to produce documents or tangible things or to permit inspection may serve on the party or attorney designated in the subpoena a written objection to inspecting, copying, testing or sampling any or all of the materials or to inspecting the premises — or to producing electronically stored information in the form or forms requested. The objection must be served before the earlier of the time specified for compliance or 14 days after the subpoena is served. If an objection is made, the following rules apply:\n\n(i) At any time, on notice to the commanded person, the serving party may move the court for the district where compliance is required for an order compelling production or inspection.\n\n(ii) These acts may be required only as directed in the order, and the order must protect a person who is neither a party nor a party's officer from significant expense resulting from compliance.\n\n#### *(3) Quashing or Modifying a Subpoena.*\n\n*(A) When Required.* On timely motion, the court for the district where compliance is required must quash or modify a subpoena that:\n\n(i) fails to allow a reasonable time to comply;\n\n(ii) requires a person to comply beyond the geographical limits specified in Rule 45(c);\n\n(iii) requires disclosure of privileged or other protected matter, if no exception or waiver applies; or\n\n(iv) subjects a person to undue burden.\n\n*(B) When Permitted.* To protect a person subject to or affected by a subpoena, the court for the district where compliance is required may, on motion, quash or modify the subpoena if it requires:\n\n(i) disclosing a trade secret or other confidential research, development, or commercial information; or\n\n(ii) disclosing an unretained expert's opinion or information that does not describe specific occurrences in dispute and results from the expert's study that was not requested by a party.\n\n(C) *Specifying Conditions as an Alternative.* In the circumstances described in Rule 45(d)(3)(B), the court may, instead of quashing or modifying a subpoena, order appearance or production under specified conditions if the serving party:\n\n(i) shows a substantial need for the testimony or material that cannot be otherwise met without undue hardship; and\n\n(ii) ensures that the subpoenaed person will be reasonably compensated.\n\n#### **(e) Duties in Responding to a Subpoena.**\n\n*(1) Producing Documents or Electronically Stored Information.* These procedures apply to producing documents or electronically stored information:\n\n*(A) Documents.* A person responding to a subpoena to produce documents must produce them as they are kept in the ordinary course of business or must organize and label them to correspond to the categories in the demand.\n\n*(B) Form for Producing Electronically Stored Information Not Specified.* If a subpoena does not specify a form for producing electronically stored information, the person responding must produce it in a form or forms in which it is ordinarily maintained or in a reasonably usable form or forms.\n\n*(C) Electronically Stored Information Produced in Only One Form.* The person responding need not produce the same electronically stored information in more than one form.\n\n*(D) Inaccessible Electronically Stored Information.* The person responding need not provide discovery of electronically stored information from sources that the person identifies as not reasonably accessible because of undue burden or cost. On motion to compel discovery or for a protective order, the person responding must show that the information is not reasonably accessible because of undue burden or cost. If that showing is made, the court may nonetheless order discovery from such sources if the requesting party shows good cause, considering the limitations of Rule 26(b)(2)(C). The court may specify conditions for the discovery.\n\n#### *(2) Claiming Privilege or Protection.*\n\n*(A) Information Withheld.* A person withholding subpoenaed information under a claim that it is privileged or subject to protection as trial-preparation material must: (i) expressly make the claim; and\n\n(ii) describe the nature of the withheld documents, communications, or tangible things in a manner that, without revealing information itself privileged or protected, will enable the parties to assess the claim.\n\n*(B) Information Produced.* If information produced in response to a subpoena is subject to a claim of privilege or of protection as trial-preparation material, the person making the claim may notify any party that received the information of the claim and the basis for it. After being notified, a party must promptly return, sequester, or destroy the specified information and any copies it has; must not use or disclose the information until the claim is resolved; must take reasonable steps to retrieve the information if the party disclosed it before being notified; and may promptly present the information under seal to the court for the district where compliance is required for a determination of the claim. The person who produced the information must preserve the information until the claim is resolved.\n\n**(g) Contempt.** The court for the district where compliance is required – and also, after a motion is transferred, the issuing court – may hold in contempt a person who, having been served, fails without adequate excuse to obey the subpoena or an order related to it.\n\nFor access to subpoena materials, see Fed.R.Civ.P.45(a) Committee Note (2013)\n\n…\n\n## **Request for Production of Documents**\n\n## **I. INSTRUCTIONS**\n\n1. Unless otherwise indicated, the requests for documents set forth below, (the \"Requests,\" and each, a \"Request\"), must be responded to separately and specifically. Each Request shall be answered fully unless it is in good faith objected to, in which event the reason for Your objection shall be stated in detail, as set forth below. If an objection pertains only to a portion of a Request, or a word, phrase or clause contained within it, You are required to state Your objection to that portion only and to respond to the remainder of the Requests.\n\n2. Electronically stored information must be produced in accordance with the\n\nfollowing instructions:\n\n- a. Images. Black and white images must be 300 DPI Group IV single-page TIFF files. Color images must be produced in JPEG format. File names cannot contain embedded spaces or special characters (including the comma). Folder names cannot contain embedded spaces or special characters (including the comma). All TIFF image files must have a unique file name, i.e. Bates number. Images must be endorsed with sequential Bates numbers in the lower right corner of each image. The number of TIFF files per folder should not exceed 1000 files. Excel spreadsheets should have a placeholder image named by the Bates number of the file.\n- b. Image Load File\n\t- a. Concordance® Data File. The data file (.DAT) contains all of the fielded information that will be loaded into the Concordance® database. The first line of the .DAT file must be a header row identifying the field names. The .DAT file must use the following Concordance® default delimiters: Comma ASCII character (020) Quote þ ASCII character (254). Date fields should be provided in the format: mm/dd/yyyy. Date and time fields must be two separate fields. If documents includes imaged emails and attachments, the attachment fields must be included to preserve the parent/child relationship between an email and its attachments. An OCRPATH field must be included to provide the file path and name of the extracted text file on the produced storage media. The text file must be named after the FIRSTBATES. Do not include the text in the .DAT file. For Documents with native files, a LINK field must be included to provide the file path and\n\nname of the native file. The native file must be named after the FIRSTBATES.\n\n- b. Concordance Image® OR Opticon Cross-Reference File. The image crossreference file (.LOG or .OPT) links the images to the database records. It should be a comma-delimited file consisting of seven fields per line with a line in the cross-reference file for every image in the database with the following format: ImageID,VolumeLabel,ImageFilePath,DocumentBreak,FolderBreak,Box Break,PageCoun.\n- c. Document Text. Text must be produced as separate text files, not as fields within the .DAT file. The full path to the text file (OCRPATH) should be included in the .DAT file. It is recommended document level ANSI text files, named per the FIRSTBATES/Image Key. Extracted text files must be in a separate folder, and the number of text files per folder should not exceed 1,000 files. There should be no special characters (including commas in the folder names). Text files must be provided on a document level.\n- d. Native Production for Certain File Types. File types that reasonably require viewing in their native format for a full understanding of their content and meaning must be produced in native format. These include, but are not limited to, spreadsheets, spreadsheet-like files (Microsoft Excel, comma separated values, tab separated values, etc.), Microsoft PowerPoint or other special presentation files, database files, and audio/visual files. Provide an image of a Bates numbered slip sheet indicating the presence of a native file, and include the path to the native as a field in the .dat file. Name the produced native file with the Bates number corresponding to the slip sheet for the file. Group native files within incrementally named \"NATIVE\" directories, separate from images directories.\n- e. De-duplication. Produce a single copy of each electronic document for which exact duplicates exist. For email messages, consolidate duplicates based on MD5 hash generated from the BCC, Body, CC, From, IntMsgID, To, and Attach properties. For email attachments and standalone electronic files, consolidate duplicates based on MD5 hash of the entire file.\n- f. Metadata. Produce extracted metadata for each document in the form of a Concordance compliant load file (.dat). The first line of the .DAT file must be a header row identifying the field names. The .DAT file must use the following Concordance default delimiters: Comma , ASCII character (020) Quote þ ASCII character (254)\n\nDate fields should be provided in the format: mm/dd/yyyy. Date and time fields must be two separate fields. Required metadata listed below:\n\n# Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 562 of 1063\n\n| Field Name   | Sample Data              | Description                                                                                  |\n|--------------|--------------------------|----------------------------------------------------------------------------------------------|\n| FIRSTBATES   | EDC0000001               | First Bates number of native file document/email                                             |\n| LASTBATES    | EDC0000001               | Last Bates number of native file document/email<br>**The LASTBATES field should be populated |\n|              |                          | for single page                                                                              |\n| ATTACHRANGE  | EDC0000001<br>-          | Bates number of the first page of the parent                                                 |\n|              | EDC0000015               | document to the Bates number of the last page of                                             |\n|              |                          | the last attachment \"child\" document                                                         |\n| BEGATTACH    | EDC0000001               | First Bates number of attachment range                                                       |\n| ENDATTACH    | EDC0000015               | Last Bates number of attachment range                                                        |\n| CUSTODIAN    | Smith, John              | Email: Mailbox where the email resided                                                       |\n|              |                          | Native: Name of the individual or department                                                 |\n|              |                          | from whose files the document<br>originated                                                  |\n| FROM         | John Smith               | Email: Sender                                                                                |\n|              |                          |                                                                                              |\n|              |                          | Native: Author(s) of document                                                                |\n|              |                          | **semi-colon should be used to separate                                                      |\n|              |                          | multiple entries                                                                             |\n| TO           | Coffman, Janice; LeeW    | Recipient(s)                                                                                 |\n|              | [mailto:LeeW@MSN.com]    | **semi-colon should be used to separate multiple                                             |\n|              |                          | entries                                                                                      |\n| CC           | Frank Thompson [mailto:  | Carbon copy recipient(s)                                                                     |\n|              | frank_Thompson@cdt.com]  | **semi-colon should be used to separate                                                      |\n|              |                          | multiple entries                                                                             |\n| BCC          | John Cain                | Blind carbon copy recipient(s)                                                               |\n|              |                          | **semi-colon should be used to separate                                                      |\n|              |                          | multiple entries                                                                             |\n| SUBJECT      | Board Meeting Minutes    | Email: Subject line of the email Native: Title                                               |\n|              |                          | of document (if available)                                                                   |\n| FILE_NAME    | BoardMeetingMinutes.docx | Native: Name of the original native file,                                                    |\n|              |                          | including extension                                                                          |\n| DATE_SENT    | 10/12/2010               | Email: Date the email was sent                                                               |\n|              |                          | Native: (empty)                                                                              |\n| TIME_SENT/   | 07:05 PM GMT             | Email: Time the email was sent/ Time zone in                                                 |\n| TIME_ZONE    |                          | which the emails were standardized                                                           |\n| TIME_ZONE    | GMT                      | The<br>time zone in which<br>the emails<br>were                                              |\n|              |                          | standardized during conversion.                                                              |\n| LINK         |  EDC0000001.msg   | Hyperlink to the email or native file document                                               |\n|              |                          | **The linked file must be named per the                                                      |\n|              |                          | FIRSTBATES number                                                                            |\n| FILE_EXTEN   | MSG                      | The file type extension                                                                      |\n|              |                          | representing                                                                                 |\n|              |                          | the Email or                                                                                 |\n| AUTHOR       | John Smith               | Email: (empty)                                                                               |\n|              |                          | Native: Author of the document                                                               |\n| DATE_CREATED | 10/10/2010               | Email: (empty)                                                                               |\n|              |                          | Native: Date the document was created                                                        |\n|              |                          |                                                                                              |\n\n# Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 563 of 1063\n\n| TIME_CREATED | 10:25 AM                  | Email: (empty)                                  |\n|--------------|---------------------------|-------------------------------------------------|\n|              |                           | Native: Time the document was created           |\n|              |                           | **This data must be a separate field and cannot |\n|              |                           | be combined with the DATE_CREATED field         |\n| DATE_MOD     | 10/12/2010                | Email: (empty)                                  |\n|              |                           | Native: Date the document was last modified     |\n| TIME_MOD     | 07:00 PM                  | Email: (empty)                                  |\n|              |                           | Native: Time the document was last modified     |\n|              |                           | **This data must be a separate field and cannot |\n|              |                           | be combined with the DATE_MOD field             |\n| DATE_ACCESSD | 10/12/2010                | Email: (empty)                                  |\n|              |                           | Native: Date the document was last accessed     |\n| TIME_ACCESSD | 07:00 PM                  | Email: (empty)                                  |\n|              |                           | Native: Time the document was last accessed     |\n|              |                           | **This data must be a separate field and cannot |\n|              |                           | be combined with the DATE_ACCESSD field         |\n| FILE_SIZE    | 5,952                     | Size of native file<br>document/email in KB     |\n| PGCOUNT      | 1                         | Number of pages in native file document/email   |\n| PATH         |   | Email: (empty)                                  |\n|              | Agenda.doc                | Native: Path where native file document was     |\n|              |                           | stored including original file name.            |\n| INTFILEPATH  | Personal Folders\\Deleted  | Email: original location of email including     |\n|              | Items\\Board Meeting       | original file name.                             |\n|              | Minutes.msg               | Native: (empty)                                 |\n| INTMSGID     | <000805c2c71b\\$75977050\\$ | Email: Unique Message ID Native: (empty)        |\n|              | cb8306d1@MSN>             |                                                 |\n| MD5HASH      | d131dd02c5e6eec4693d9a0   | MD5 Hash value of the document.                 |\n|              | 698aff95c                 |                                                 |\n|              | 2fcab58712467eab4004583e  |                                                 |\n|              | b8fb7f89                  |                                                 |\n| OCRPATH      | TEXT/001/EDC0000001.txt   | Path to extracted text of the native file       |\n\n3. Each Request operates and should be construed independently and, unless otherwise indicated, no Request limits the scope of any other Request.\n\n4. All Documents are to be produced as kept in the usual course of business or are to be organized and labeled to correspond with the categories in these Requests.\n\n5. Each Request contained herein extends to all Documents: (a) in Your possession, custody, or control; or (b) in the possession, custody, or control of anyone acting on Your behalf,\n\n#### Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 564 of 1063\n\nincluding Your counsel or other representatives and advisors. Each Document shall be produced in its entirety.\n\n6. If You are requested to produce a Document that is no longer in Your possession, custody, or control, then Your response must (a) describe in detail the nature of the document and its contents; (b) identify the person(s) who prepared or authored the Document (and, if applicable, the Person(s) to whom the Document was sent); (c) identify the date on which the document was prepared or created; (d) state whether such Document (i) is missing or lost, (ii) has been destroyed, (iii) has been transferred, voluntarily or involuntarily, to others, or (iv) was otherwise disposed of; (e) state the reason for, and the facts and circumstances surrounding, such disposition; (f) identify the Persons who authorized such disposition; (g) identify the date or approximate date of such disposition; (h) state when the Document was most recently in Your possession, custody or control; and (i) identify the Person, if any, presently in possession, custody, or control of such Document.\n\n7. If You are requested to produce a Document that has been destroyed, then Your response must state, in addition to the information required by the preceding Instruction: (a) the reason for the Document's destruction; (b) the identity of the Person who destroyed the Document; and (c) the identity of the Person who directed that the Document be destroyed.\n\n8. If You claim that a requested Document is privileged or attorney work-product, then Your response must: (a) state (i) a description of the Document adequate to support Your contention that the Document is privileged, (ii) the title of the Document, (iii) the date of the Document, (iv) the author of the Document, (v) the addressee of the Document, (vi) the identity of each Person who received or saw the original or any draft, copy, or reproduction of the Document, (vii) whether the Document itself, or any information contained or referred to in the Document is in the possession, custody, or control of any other Persons, and if so, the identity of\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 565 of 1063\n\nsuch Persons, as well as a statement addressing how the information came into their possession, (viii) the claim of privilege under which the Document is withheld, and (ix) all of the circumstances upon which You will rely to support such claim of privilege; and (b) produce a privilege log containing all of the information requested in Part (a) of this Instruction for each Document withheld on the basis of a claim of privilege in accordance with D. Conn. L. Civ. R. 26(e). For any part of a Document Request as to which a claim of privilege or work product is not made, responsive documents should be provided in full.\n\n9. If a portion of an otherwise responsive Document contains information subject to a claim of privilege, only that portion of the Document subject to the claim of privilege shall be deleted or redacted from the Document following the instructions above, and the rest shall be produced.\n\n10. The Requests are continuing in nature. You are hereby instructed to (a) supplement or correct any responses later learned to be incomplete or incorrect immediately upon learning that a prior response was incomplete or incorrect; and (b) produce any additional Documents that are called for under the\n\n11. If a Document is in a language other than English, You should provide that Document. If a Document is in a language other than English, and an English translation exists, You should provide both Documents.\n\n12. All references to Entities includes all affiliates thereof.\n\n13. All references to individual names include all alternative names, aliased, or nicknames.\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 566 of 1063\n\n14. Unless otherwise expressly indicated, the period of time covered by the Document Requests is the period from February 5, 2012 to the date responses to the Document Requests are due.\n\n#### **II. RULES OF CONSTRUCTION**\n\n15. The use of (a) any singular noun shall be construed to include the plural, and vice versa, and (b) a verb in any tense shall be construed as the use of the verb in all other tenses.\n\n16. The terms (a) \"and\" and \"or\" shall be construed either conjunctively or disjunctively as necessary to bring within the scope of any request all responses that might otherwise be construed to be outside of its scope, and (b) \"each\" and \"any\" shall be deemed to include and encompass the words \"every\" and \"all.\"\n\n#### **III. DEFINITIONS**\n\nThe definitions supplied by D. Conn. L. Civ. R. 26(c) and the rules of construction supplied by D. Conn. L. Civ. R. 26(d), as incorporated by D. Conn. Bankr. L.R. 2004-1(a), shall apply to the Document Requests. In addition, the following terms used in these Document Requests shall have the following meanings:\n\n1. \"You\" or \"Your\" or \"Yourself\" means and refers, to Capital One, NA, together with all of its affiliates.\n\n2. \"Debtor\" means Ho Wan Kwok (a/k/a Miles Kwok, Miles Guo, Guo Wengui, Guo Haoyun, 郭文贵, or any other alias), together with his employees, agents, counsel, advisors, or anyone acting on his behalf.\n\n#### Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 567 of 1063\n\n3. \"Debtor's Son\" means Qiang Guo (a/k/a Mileson Kwok, 郭强, or any other alias), together with his employees, agents, counsel, advisors, or anyone acting on his behalf.\n\n4. \"Debtor's Daughter\" means Mei Guo (a/k/a Mei Gui, 郭美, or any other alias), together with her employees, agents, counsel, advisors, or anyone acting on her behalf.\n\n5. \"Debtor's Purported Wife\" means Hing Chi Ngok (a/k/a Hing Chi Ng, Yue Qingzhi, 岳庆芝, or any other alias), together with her employees, agents, counsel, advisors, or anyone acting on her behalf.\n\n6. \"Debtor's Family\" means, individually and collectively, the Debtor, the Debtor's Son, the Debtor's Daughter, and the Debtor's Purported Wife, and any other familial relation to the Debtor.\n\n7. \"2004 Discovery Targets\" means, individually and collectively, the Debtor, the Debtor's Family, ACA Capital Group Limited, Himalaya International Financial Group Ltd., Himalaya International Clearing Ltd., Himalaya International Payments Ltd., Himalaya International Reserves Ltd., Jesse Brown, William Je, William Je, Eastern Profit Corporation Limited, HK International Funds Investments (USA) Limited LLC, Bravo Luck Limited, Golden Spring (New York) Ltd., Lamp Capital LLC, Greenwich Land LLC, Qu Guo Jiao, Daniel Thomas Podhaskie, Yvette Wang (a/k/a Yanping Wang, a/k/a Yan Ping Wang), Ace Decade Holdings Limited, Dawn State Limited, Rule of Law Society IV Inc., Rule of Law Foundation III, Inc., Rule of Law Foundation IV, Inc., Rule of Law Fund, Rule of Law Society, GTV Media Group, Inc., Voice of Guo Media, Inc., Saraca Media Group Inc., Genever Holdings Corporation, Genever Holdings LLC, Gnews Media Group Inc., G Fashion LLC, Gmusic LLC, Gnews LLC, Geducation, GFNY, Inc., G-Club Investments Limited, G Club Operations LLC, G Club US Operations Inc., G Club US Operations LLC, G Live, LLC, Gbroadcast, LLC, Gposts LLC, HCHK Property\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 568 of 1063\n\nManagement, Inc., HCHK Technologies, Inc., FMV Ltd./Freedom Media Venture Ltd., Roscalitar 2, Himalaya New World Inc., US Himalaya Capital Inc., Hudson Diamond Holding, Inc., Hudson Diamond Holding LLC, Hudson Diamond NY LLC, Infinity Treasury Management Inc., Lexington Property and Staffing, Inc., AI Group Holdings Inc., Hamilton Capital Holdings Inc., Booming Sail New York LLC, Himalaya Ventures LLC, Himalaya Ventures LLC, Himalaya Investment LLC, New York MOS Himalaya LLC, MOS Himalaya LLC, Crane Advisory Group, Maywind Trading LLC, Gettr USA, Inc., Han Chunguang, Bingshang Jiao, Karin Maistrello, Mary Jiang, Jiaming Liu, and Wencong Wang.\n\n8. \"Including\" or any variant thereof means \"including without limitation.\"\n\n9. \"And\" and \"or\" mean \"and/or,\" and shall be construed both conjunctively as well as disjunctively in order to maximize their scope.\n\n10. \"Any\" and \"all\" and \"each\" mean \"each and every.\"\n\n11. \"Each\" and \"every\" mean \"each and every.\"\n\n12. \"Third Party\" means a Person or Entity other than Yourself.\n\n13. \"Transfer\" shall have the meaning given to it by section 101(54) of the Bankruptcy Code.\n\n14. \"Document\" means any information or thing within the scope of Fed. R. Civ. P. 34, and includes, without limitation, each and every written, recorded, or graphic matter of any kind, type, nature, or description that is or has been in Your Possession, Custody or Control, including all printed and electronic copies of electronic mail, computer files maintained in electronic form, correspondence, memoranda, tapes, stenographic or handwritten notes, written forms of any kind, charts, blueprints, drawings, sketches, graphs, plans, articles, specifications, diaries, letters,\n\n#### Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 569 of 1063\n\ntelegrams, photographs, minutes, contracts, agreements, surveys, computer printouts, data compilations of any kind, telexes, facsimiles, emails, text messages, instant messages, voice messages, invoices, order forms, checks, drafts, statements, credit memos, reports, position reports, summaries, indices, books, ledgers, notebooks, schedules, transparencies, recordings, catalogs, advertisements, promotional materials, films, video tapes, audio tapes, CDs, computer disks, brochures, pamphlets, punch-cards, time-slips, Tweets, social media posts, or any written or recorded materials of any other kind, and all meta-data thereof, however stored (whether in tangible or electronic form), recorded, produced, or reproduced, and also including but not limited to, drafts or copies of any of the foregoing that contain any notes, comments, or markings of any kind not found on the original documents or that are otherwise not identical to the original documents.\n\n15. \"Person(s)\" means an individual, corporation, proprietorship, partnership, association, or any other Entity. \"Person\" also includes any agent, representatives, or expert, including but not limiting to, attorneys or financial advisors.\n\n16. \"Entity\" means any natural Person, corporation, partnership, subsidiary, sole proprietorship, firm, board, joint venture, association, agency, authority, commission or other business entity or juristic Person, as well as any affiliate, agent, parent including but not limited to counsel, financial advisors, or any other representative.\n\n17. \"Regarding\" means concerning, describing, comprising, referring to, related to, supporting, favoring, opposing, bolstering, detracting from, located in, considered in connection with, bearing on, evidencing, indicating, reporting on, recording, alluding to, responding to, connected with, commenting on, in respect of, about, in relation to, discussing, showing, describing, reflecting, analyzing constituting, and being.\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 570 of 1063\n\n18. \"Relating to,\" \"relate(s) to\" or \"related to,\" when referring to any given subject matter, means, without limitation, any document that constitutes, comprises, involves, contains, embodies, reflects, identifies, states, refers directly or indirectly to, or is in any way relevant to the particular subject matter identified.\n\n19. \"Communication(s)\" means, in the broadest possible sense, and without limitation, any transmittal of information or knowledge (in the form of facts, ideas, inquiries, or otherwise). Communication(s) further refers to all conversations, agreements, inquiries, or replies, whether in person, by telephone, in writing, or by means of electronic transmittal devices, and includes, but is not limited to, all correspondence, emails, recordings, transmittal slips, memoranda, telephone communications, voice messages, telegrams, telefaxes, telecopies, telexes, instant messages, chats, text messages, postings to a message board or group chat, social media posts, tweets, videos uploaded to any video platform, telephonic notes, or notes transmitted internally or with third parties.\n\n20. \"Asset(s)\" means any item of economic value that is subject to Possession, Custody, or Control. Asset includes all real and personal property, including but limited to, real estate, land, houses, apartments, condominiums, automobiles, yachts, boats, planes, jets, helicopters, cash, bank accounts, cryptocurrencies, securities, accounts receivables, inventory, and other tangible and intangible property.\n\n#### **IV. DOCUMENTS TO BE PRODUCED**\n\n1. All Documents related to any account held by, controlled by, on behalf of, or otherwise related to any of the 2004 Discovery Targets, including any and all account statements, authorizations, power of attorney, trusts, instructions or forms, copies of cancelled checks, correspondence, and wire transfers and related correspondence and instructions.\n\n#### Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 571 of 1063\n\n2. All Documents related to any funds, securities, property, or assets belonging to, held by, controlled by, on behalf of, or otherwise related to any of the 2004 Discovery Targets, including any and all account statements, authorizations, powers of attorney, trusts, instructions or forms, copies of cancelled checks, correspondence, and wire transfers and related correspondence and instructions.\n\n3. All Documents related to any business, commerce or financial transactions, including but not limited to any loan, line of credit, bailment, deposit, swap, securities transactions, mortgage, or ISDA, with any of the 2004 Discovery Targets, including any and all account statements, authorizations, powers of attorney, trusts, instructions or forms, copies of cancelled checks, correspondence, and wire transfers and related correspondence and instructions.\n\n4. All Documents relating to any wire transfer activity relating to the 2004 Discovery Targets, regardless of the existence of any accounts, including but not limited to all wire transfer receipts, account numbers, balances, authorizations, identification information related to the parties to the transfer, correspondence, instructions, or other records.\n\n5. All Documents related to any correspondence and communications between you and the 2004 Discovery Targets.\n\n6. All Documents related to any account with any 2004 Discovery Target relating to opening of the account, authorized users of the account and maintenance of the account.\n\n7. All Documents related to any anti-money laundering, know-your-customer, or other compliance activity relating to any of the 2004 Discovery Targets, including but not limited to any information provided by any of the 2004 Discovery Targets, or learned by You.\n\n8. All Documents relating to any communications with any regulator from any country, including but not limited to the Bank of England, the United States Federal Reserve, the\n\nS.E.C., the CFTC, FINRA, China Securities Regulatory Commission, People's Bank of China, Hong Kong Securities and Futures Commission, and the Hong Kong Monetary Authority relating to any of the 2004 Discovery Targets.\n\n# Exhibit C-31\n\n#### B2540 (Form 2540 – Subpoena for Rule 2004 Examination) (12/15) Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 574 of\n\nUNITED STATES BANKRUPTCY COURT 1063\n\n**District of Connecticut**\n\nIn re HO WAN KWOK, *et al*.,\n\n<sup>1</sup> Case No. 22-50073 (JAM)\n\nDebtor Chapter 11\n\n(Jointly Administered)\n\n## **SUBPOENA FOR RULE 2004 EXAMINATION**\n\nTo: **Amazon Web Services LLC**\n\n(*Name of person to whom the subpoena is directed*)\n\n*Testimony:* **YOU ARE COMMANDED** to appear at the time, date, and place set forth below to testify at an examination under Rule 2004, Federal Rules of Bankruptcy Procedure. A copy of the court order authorizing the examination is attached.\n\n| PLACE                          | DATE AND TIME |\n|--------------------------------|---------------|\n| Neubert, Pepe & Monteith, P.C. |               |\n| 195 Church Street, Floor 13    | [TBD]         |\n| New Haven, Connecticut 06510   |               |\n|                                |               |\n\nThe examination will be recorded by this method: **Court reporter/stenographer**\n\n*Production:* You, or your representatives, must also bring with you to the examination the following documents, electronically stored information, or objects, and must permit inspection, copying, testing, or sampling of the material:\n\n#### **See Requests for Production of Documents, attached hereto.**\n\nThe following provisions of Fed. R. Civ. P. 45, made applicable in bankruptcy cases by Fed. R. Bankr. P. 9016, are attached – Rule 45(c), relating to the place of compliance; Rule 45(d), relating to your protection as a person subject to a subpoena; and Rule 45(e) and 45(g), relating to your duty to respond to this subpoena and the potential consequences of not doing so.\n\nDate: **March , 2023**\n\nCLERK OF COURT\n\nOR\n\n*Signature of Clerk or Deputy Clerk Attorney's signature*\n\nThe name, address, email address, and telephone number of the attorney representing Luc A. Despins, Chapter 11 Trustee, who issues or requests this subpoena, are:\n\n**Douglas S. Skalka, Esq.; Neubert, Pepe & Monteith, P.C.; 195 Church Street, New Haven, Connecticut 06510 dskalka@npmlaw.com; (203) 821-2000**\n\n**Notice to the person who issues or requests this subpoena**\n\nIf this subpoena commands the production of documents, electronically stored information, or tangible things, or the inspection of premises before trial, a notice and a copy of this subpoena must be served on each party before it is served on the person to whom it is directed. Fed. R. Civ. P. 45(a)(4).\n\nSoftware Copyright (c) 1996-2022 Best Case, LLC - www.bestcase.com Best Case Bankruptcy 1 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\n#### **PROOF OF SERVICE**\n\n**(This section should not be filed with the court unless required by Fed. R. Civ. P. 45.)**\n\nI received this subpoena for (*name of individual and title, if any*): on (*date*) .\n\nI served the subpoena by delivering a copy to the named person as follows:\n\non *(date)* ; or\n\nI returned the subpoena unexecuted because:\n\nUnless the subpoena was issued on behalf of the United States, or one of its officers or agents, I have also tendered to the witness the fees for one day's attendance, and the mileage allowed by law, in the amount of \\$ .\n\nMy fees are \\$ for travel and \\$ for services, for a total of \\$ .\n\nI declare under penalty of perjury that this information is true and correct.\n\nDate:\n\n*Server's signature*\n\n*Printed name and title*\n\n*Server's address*\n\nAdditional information concerning attempted service, etc.:\n\n#### **Federal Rule of Civil Procedure 45(c), (d), (e), and (g) (Effective 12/1/13) (made applicable in bankruptcy cases by Rule 9016, Federal Rules of Bankruptcy Procedure)**\n\n#### **(c) Place of compliance.**\n\n*(1) For a Trial, Hearing, or Deposition.* A subpoena may command a person to attend a trial, hearing, or deposition only as follows:\n\n(A) within 100 miles of where the person resides, is employed, or regularly transacts business in person; or\n\n(B) within the state where the person resides, is employed, or regularly transacts business in person, if the person\n\n(i) is a party or a party's officer; or\n\n(ii) is commanded to attend a trial and would not incur substantial expense.\n\n*(2) For Other Discovery.* A subpoena may command:\n\n(A) production of documents, or electronically stored information, or things at a place within 100 miles of where the person resides, is employed, or regularly transacts business in person; and\n\n(B) inspection of premises, at the premises to be inspected.\n\n#### **(d) Protecting a Person Subject to a Subpoena; Enforcement.**\n\n*(1) Avoiding Undue Burden or Expense; Sanctions.* A party or attorney responsible for issuing and serving a subpoena must take reasonable steps to avoid imposing undue burden or expense on a person subject to the subpoena. The court for the district where compliance is required must enforce this duty and impose an appropriate sanction which may include lost earnings and reasonable attorney's fees — on a party or attorney who fails to comply.\n\n#### *(2) Command to Produce Materials or Permit Inspection.*\n\n*(A) Appearance Not Required.* A person commanded to produce documents, electronically stored information, or tangible things, or to permit the inspection of premises, need not appear in person at the place of production or inspection unless also commanded to appear for a deposition, hearing, or trial.\n\n*(B) Objections.* A person commanded to produce documents or tangible things or to permit inspection may serve on the party or attorney designated in the subpoena a written objection to inspecting, copying, testing or sampling any or all of the materials or to inspecting the premises — or to producing electronically stored information in the form or forms requested. The objection must be served before the earlier of the time specified for compliance or 14 days after the subpoena is served. If an objection is made, the following rules apply:\n\n(i) At any time, on notice to the commanded person, the serving party may move the court for the district where compliance is required for an order compelling production or inspection.\n\n(ii) These acts may be required only as directed in the order, and the order must protect a person who is neither a party nor a party's officer from significant expense resulting from compliance.\n\n#### *(3) Quashing or Modifying a Subpoena.*\n\n*(A) When Required.* On timely motion, the court for the district where compliance is required must quash or modify a subpoena that:\n\n(i) fails to allow a reasonable time to comply;\n\n(ii) requires a person to comply beyond the geographical limits specified in Rule 45(c);\n\n(iii) requires disclosure of privileged or other protected matter, if no exception or waiver applies; or\n\n(iv) subjects a person to undue burden.\n\n*(B) When Permitted.* To protect a person subject to or affected by a subpoena, the court for the district where compliance is required may, on motion, quash or modify the subpoena if it requires:\n\n(i) disclosing a trade secret or other confidential research, development, or commercial information; or\n\n(ii) disclosing an unretained expert's opinion or information that does not describe specific occurrences in dispute and results from the expert's study that was not requested by a party.\n\n(C) *Specifying Conditions as an Alternative.* In the circumstances described in Rule 45(d)(3)(B), the court may, instead of quashing or modifying a subpoena, order appearance or production under specified conditions if the serving party:\n\n(i) shows a substantial need for the testimony or material that cannot be otherwise met without undue hardship; and\n\n(ii) ensures that the subpoenaed person will be reasonably compensated.\n\n#### **(e) Duties in Responding to a Subpoena.**\n\n*(1) Producing Documents or Electronically Stored Information.* These procedures apply to producing documents or electronically stored information:\n\n*(A) Documents.* A person responding to a subpoena to produce documents must produce them as they are kept in the ordinary course of business or must organize and label them to correspond to the categories in the demand.\n\n*(B) Form for Producing Electronically Stored Information Not Specified.* If a subpoena does not specify a form for producing electronically stored information, the person responding must produce it in a form or forms in which it is ordinarily maintained or in a reasonably usable form or forms.\n\n*(C) Electronically Stored Information Produced in Only One Form.* The person responding need not produce the same electronically stored information in more than one form.\n\n*(D) Inaccessible Electronically Stored Information.* The person responding need not provide discovery of electronically stored information from sources that the person identifies as not reasonably accessible because of undue burden or cost. On motion to compel discovery or for a protective order, the person responding must show that the information is not reasonably accessible because of undue burden or cost. If that showing is made, the court may nonetheless order discovery from such sources if the requesting party shows good cause, considering the limitations of Rule 26(b)(2)(C). The court may specify conditions for the discovery.\n\n#### *(2) Claiming Privilege or Protection.*\n\n*(A) Information Withheld.* A person withholding subpoenaed information under a claim that it is privileged or subject to protection as trial-preparation material must: (i) expressly make the claim; and\n\n(ii) describe the nature of the withheld documents, communications, or tangible things in a manner that, without revealing information itself privileged or protected, will enable the parties to assess the claim.\n\n*(B) Information Produced.* If information produced in response to a subpoena is subject to a claim of privilege or of protection as trial-preparation material, the person making the claim may notify any party that received the information of the claim and the basis for it. After being notified, a party must promptly return, sequester, or destroy the specified information and any copies it has; must not use or disclose the information until the claim is resolved; must take reasonable steps to retrieve the information if the party disclosed it before being notified; and may promptly present the information under seal to the court for the district where compliance is required for a determination of the claim. The person who produced the information must preserve the information until the claim is resolved.\n\n**(g) Contempt.** The court for the district where compliance is required – and also, after a motion is transferred, the issuing court – may hold in contempt a person who, having been served, fails without adequate excuse to obey the subpoena or an order related to it.\n\nFor access to subpoena materials, see Fed.R.Civ.P.45(a) Committee Note (2013)\n\n…\n\n## **Request for Production of Documents**\n\n## **I. INSTRUCTIONS**\n\n1. Unless otherwise indicated, the requests for documents set forth below, (the \"Requests,\" and each, a \"Request\"), must be responded to separately and specifically. Each Request shall be answered fully unless it is in good faith objected to, in which event the reason for Your objection shall be stated in detail, as set forth below. If an objection pertains only to a portion of a Request, or a word, phrase or clause contained within it, You are required to state Your objection to that portion only and to respond to the remainder of the Requests.\n\n2. Electronically stored information must be produced in accordance with the\n\nfollowing instructions:\n\n- a. Images. Black and white images must be 300 DPI Group IV single-page TIFF files. Color images must be produced in JPEG format. File names cannot contain embedded spaces or special characters (including the comma). Folder names cannot contain embedded spaces or special characters (including the comma). All TIFF image files must have a unique file name, i.e. Bates number. Images must be endorsed with sequential Bates numbers in the lower right corner of each image. The number of TIFF files per folder should not exceed 1000 files. Excel spreadsheets should have a placeholder image named by the Bates number of the file.\n- b. Image Load File\n\t- a. Concordance® Data File. The data file (.DAT) contains all of the fielded information that will be loaded into the Concordance® database. The first line of the .DAT file must be a header row identifying the field names. The .DAT file must use the following Concordance® default delimiters: Comma ASCII character (020) Quote þ ASCII character (254). Date fields should be provided in the format: mm/dd/yyyy. Date and time fields must be two separate fields. If documents includes imaged emails and attachments, the attachment fields must be included to preserve the parent/child relationship between an email and its attachments. An OCRPATH field must be included to provide the file path and name of the extracted text file on the produced storage media. The text file must be named after the FIRSTBATES. Do not include the text in the .DAT file. For Documents with native files, a LINK field must be included to provide the file path and\n\nname of the native file. The native file must be named after the FIRSTBATES.\n\n- b. Concordance Image® OR Opticon Cross-Reference File. The image crossreference file (.LOG or .OPT) links the images to the database records. It should be a comma-delimited file consisting of seven fields per line with a line in the cross-reference file for every image in the database with the following format: ImageID,VolumeLabel,ImageFilePath,DocumentBreak,FolderBreak,Box Break,PageCoun.\n- c. Document Text. Text must be produced as separate text files, not as fields within the .DAT file. The full path to the text file (OCRPATH) should be included in the .DAT file. It is recommended document level ANSI text files, named per the FIRSTBATES/Image Key. Extracted text files must be in a separate folder, and the number of text files per folder should not exceed 1,000 files. There should be no special characters (including commas in the folder names). Text files must be provided on a document level.\n- d. Native Production for Certain File Types. File types that reasonably require viewing in their native format for a full understanding of their content and meaning must be produced in native format. These include, but are not limited to, spreadsheets, spreadsheet-like files (Microsoft Excel, comma separated values, tab separated values, etc.), Microsoft PowerPoint or other special presentation files, database files, and audio/visual files. Provide an image of a Bates numbered slip sheet indicating the presence of a native file, and include the path to the native as a field in the .dat file. Name the produced native file with the Bates number corresponding to the slip sheet for the file. Group native files within incrementally named \"NATIVE\" directories, separate from images directories.\n- e. De-duplication. Produce a single copy of each electronic document for which exact duplicates exist. For email messages, consolidate duplicates based on MD5 hash generated from the BCC, Body, CC, From, IntMsgID, To, and Attach properties. For email attachments and standalone electronic files, consolidate duplicates based on MD5 hash of the entire file.\n- f. Metadata. Produce extracted metadata for each document in the form of a Concordance compliant load file (.dat). The first line of the .DAT file must be a header row identifying the field names. The .DAT file must use the following Concordance default delimiters: Comma , ASCII character (020) Quote þ ASCII character (254)\n\nDate fields should be provided in the format: mm/dd/yyyy. Date and time fields must be two separate fields. Required metadata listed below:\n\n# Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 579 of 1063\n\n| Field Name   | Sample Data              | Description                                                                                  |\n|--------------|--------------------------|----------------------------------------------------------------------------------------------|\n| FIRSTBATES   | EDC0000001               | First Bates number of native file document/email                                             |\n| LASTBATES    | EDC0000001               | Last Bates number of native file document/email<br>**The LASTBATES field should be populated |\n|              |                          | for single page                                                                              |\n| ATTACHRANGE  | EDC0000001<br>-          | Bates number of the first page of the parent                                                 |\n|              | EDC0000015               | document to the Bates number of the last page of                                             |\n|              |                          | the last attachment \"child\" document                                                         |\n| BEGATTACH    | EDC0000001               | First Bates number of attachment range                                                       |\n| ENDATTACH    | EDC0000015               | Last Bates number of attachment range                                                        |\n| CUSTODIAN    | Smith, John              | Email: Mailbox where the email resided                                                       |\n|              |                          | Native: Name of the individual or department                                                 |\n|              |                          | from whose files the document<br>originated                                                  |\n| FROM         | John Smith               | Email: Sender                                                                                |\n|              |                          | Native: Author(s) of document                                                                |\n|              |                          | **semi-colon should be used to separate                                                      |\n|              |                          | multiple entries                                                                             |\n| TO           | Coffman, Janice; LeeW    | Recipient(s)                                                                                 |\n|              | [mailto:LeeW@MSN.com]    | **semi-colon should be used to separate multiple                                             |\n|              |                          | entries                                                                                      |\n| CC           | Frank Thompson [mailto:  | Carbon copy recipient(s)                                                                     |\n|              | frank_Thompson@cdt.com]  | **semi-colon should be used to separate                                                      |\n|              |                          | multiple entries                                                                             |\n| BCC          | John Cain                | Blind carbon copy recipient(s)                                                               |\n|              |                          | **semi-colon should be used to separate                                                      |\n|              |                          | multiple entries                                                                             |\n| SUBJECT      | Board Meeting Minutes    | Email: Subject line of the email Native: Title                                               |\n|              |                          | of document (if available)                                                                   |\n| FILE_NAME    | BoardMeetingMinutes.docx | Native: Name of the original native file,                                                    |\n|              |                          | including extension                                                                          |\n| DATE_SENT    | 10/12/2010               | Email: Date the email was sent                                                               |\n|              |                          | Native: (empty)                                                                              |\n| TIME_SENT/   | 07:05 PM GMT             | Email: Time the email was sent/ Time zone in                                                 |\n| TIME_ZONE    |                          | which the emails were standardized                                                           |\n| TIME_ZONE    | GMT                      | The<br>time zone in which<br>the emails<br>were                                              |\n|              |                          | standardized during conversion.                                                              |\n| LINK         |  EDC0000001.msg   | Hyperlink to the email or native file document                                               |\n|              |                          | **The linked file must be named per the                                                      |\n|              |                          | FIRSTBATES number                                                                            |\n| FILE_EXTEN   | MSG                      | The file type extension                                                                      |\n|              |                          | representing                                                                                 |\n|              |                          | the Email or                                                                                 |\n| AUTHOR       | John Smith               | Email: (empty)                                                                               |\n|              |                          | Native: Author of the document                                                               |\n| DATE_CREATED | 10/10/2010               | Email: (empty)                                                                               |\n|              |                          | Native: Date the document was created                                                        |\n\n# Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 580 of 1063\n\n| TIME_CREATED | 10:25 AM                  | Email: (empty)                                  |\n|--------------|---------------------------|-------------------------------------------------|\n|              |                           | Native: Time the document was created           |\n|              |                           | **This data must be a separate field and cannot |\n|              |                           | be combined with the DATE_CREATED field         |\n| DATE_MOD     | 10/12/2010                | Email: (empty)                                  |\n|              |                           | Native: Date the document was last modified     |\n| TIME_MOD     | 07:00 PM                  | Email: (empty)                                  |\n|              |                           | Native: Time the document was last modified     |\n|              |                           | **This data must be a separate field and cannot |\n|              |                           | be combined with the DATE_MOD field             |\n| DATE_ACCESSD | 10/12/2010                | Email: (empty)                                  |\n|              |                           | Native: Date the document was last accessed     |\n| TIME_ACCESSD | 07:00 PM                  | Email: (empty)                                  |\n|              |                           | Native: Time the document was last accessed     |\n|              |                           | **This data must be a separate field and cannot |\n|              |                           | be combined with the DATE_ACCESSD field         |\n| FILE_SIZE    | 5,952                     | Size of native file<br>document/email in KB     |\n| PGCOUNT      | 1                         | Number of pages in native file document/email   |\n| PATH         |   | Email: (empty)                                  |\n|              | Agenda.doc                | Native: Path where native file document was     |\n|              |                           | stored including original file name.            |\n| INTFILEPATH  | Personal Folders\\Deleted  | Email: original location of email including     |\n|              | Items\\Board Meeting       | original file name.                             |\n|              | Minutes.msg               | Native: (empty)                                 |\n| INTMSGID     | <000805c2c71b\\$75977050\\$ | Email: Unique Message ID Native: (empty)        |\n|              | cb8306d1@MSN>             |                                                 |\n| MD5HASH      | d131dd02c5e6eec4693d9a0   | MD5 Hash value of the document.                 |\n|              | 698aff95c                 |                                                 |\n|              | 2fcab58712467eab4004583e  |                                                 |\n|              | b8fb7f89                  |                                                 |\n| OCRPATH      | TEXT/001/EDC0000001.txt   | Path to extracted text of the native file       |\n\n3. Each Request operates and should be construed independently and, unless otherwise indicated, no Request limits the scope of any other Request.\n\n4. All Documents are to be produced as kept in the usual course of business or are to be organized and labeled to correspond with the categories in these Requests.\n\n5. Each Request contained herein extends to all Documents: (a) in Your possession, custody, or control; or (b) in the possession, custody, or control of anyone acting on Your behalf,\n\n#### Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 581 of 1063\n\nincluding Your counsel or other representatives and advisors. Each Document shall be produced in its entirety.\n\n6. If You are requested to produce a Document that is no longer in Your possession, custody, or control, then Your response must (a) describe in detail the nature of the document and its contents; (b) identify the person(s) who prepared or authored the Document (and, if applicable, the Person(s) to whom the Document was sent); (c) identify the date on which the document was prepared or created; (d) state whether such Document (i) is missing or lost, (ii) has been destroyed, (iii) has been transferred, voluntarily or involuntarily, to others, or (iv) was otherwise disposed of; (e) state the reason for, and the facts and circumstances surrounding, such disposition; (f) identify the Persons who authorized such disposition; (g) identify the date or approximate date of such disposition; (h) state when the Document was most recently in Your possession, custody or control; and (i) identify the Person, if any, presently in possession, custody, or control of such Document.\n\n7. If You are requested to produce a Document that has been destroyed, then Your response must state, in addition to the information required by the preceding Instruction: (a) the reason for the Document's destruction; (b) the identity of the Person who destroyed the Document; and (c) the identity of the Person who directed that the Document be destroyed.\n\n8. If You claim that a requested Document is privileged or attorney work-product, then Your response must: (a) state (i) a description of the Document adequate to support Your contention that the Document is privileged, (ii) the title of the Document, (iii) the date of the Document, (iv) the author of the Document, (v) the addressee of the Document, (vi) the identity of each Person who received or saw the original or any draft, copy, or reproduction of the Document, (vii) whether the Document itself, or any information contained or referred to in the Document is in the possession, custody, or control of any other Persons, and if so, the identity of\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 582 of 1063\n\nsuch Persons, as well as a statement addressing how the information came into their possession, (viii) the claim of privilege under which the Document is withheld, and (ix) all of the circumstances upon which You will rely to support such claim of privilege; and (b) produce a privilege log containing all of the information requested in Part (a) of this Instruction for each Document withheld on the basis of a claim of privilege in accordance with D. Conn. L. Civ. R. 26(e). For any part of a Document Request as to which a claim of privilege or work product is not made, responsive documents should be provided in full.\n\n9. If a portion of an otherwise responsive Document contains information subject to a claim of privilege, only that portion of the Document subject to the claim of privilege shall be deleted or redacted from the Document following the instructions above, and the rest shall be produced.\n\n10. The Requests are continuing in nature. You are hereby instructed to (a) supplement or correct any responses later learned to be incomplete or incorrect immediately upon learning that a prior response was incomplete or incorrect; and (b) produce any additional Documents that are called for under the\n\n11. If a Document is in a language other than English, You should provide that Document. If a Document is in a language other than English, and an English translation exists, You should provide both Documents.\n\n12. All references to Entities includes all affiliates thereof.\n\n13. All references to individual names include all alternative names, aliased, or nicknames.\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 583 of 1063\n\n14. Unless otherwise expressly indicated, the period of time covered by the Document Requests is the period from February 5, 2012 to the date responses to the Document Requests are due.\n\n#### **II. RULES OF CONSTRUCTION**\n\n15. The use of (a) any singular noun shall be construed to include the plural, and vice versa, and (b) a verb in any tense shall be construed as the use of the verb in all other tenses.\n\n16. The terms (a) \"and\" and \"or\" shall be construed either conjunctively or disjunctively as necessary to bring within the scope of any request all responses that might otherwise be construed to be outside of its scope, and (b) \"each\" and \"any\" shall be deemed to include and encompass the words \"every\" and \"all.\"\n\n#### **III. DEFINITIONS**\n\nThe definitions supplied by D. Conn. L. Civ. R. 26(c) and the rules of construction supplied by D. Conn. L. Civ. R. 26(d), as incorporated by D. Conn. Bankr. L.R. 2004-1(a), shall apply to the Document Requests. In addition, the following terms used in these Document Requests shall have the following meanings:\n\n1. \"You\" or \"Your\" or \"Yourself\" means and refers, to Amazon Web Services, LLC, together with all of its affiliates.\n\n2. \"Debtor\" means Ho Wan Kwok (a/k/a Miles Kwok, Miles Guo, Guo Wengui, Guo Haoyun, 郭文贵, or any other alias), together with his employees, agents, counsel, advisors, or anyone acting on his behalf.\n\n#### Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 584 of 1063\n\n3. \"Debtor's Son\" means Qiang Guo (a/k/a Mileson Kwok, 郭强, or any other alias), together with his employees, agents, counsel, advisors, or anyone acting on his behalf.\n\n4. \"Debtor's Daughter\" means Mei Guo (a/k/a Mei Gui, 郭美, or any other alias), together with her employees, agents, counsel, advisors, or anyone acting on her behalf.\n\n5. \"Debtor's Purported Wife\" means Hing Chi Ngok (a/k/a Hing Chi Ng, Yue Qingzhi, 岳庆芝, or any other alias), together with her employees, agents, counsel, advisors, or anyone acting on her behalf.\n\n6. \"Debtor's Family\" means, individually and collectively, the Debtor, the Debtor's Son, the Debtor's Daughter, and the Debtor's Purported Wife, and any other familial relation to the Debtor.\n\n7. \"2004 Discovery Targets\" means, individually and collectively, the Debtor, the Debtor's Family, ACA Capital Group Limited, Himalaya International Financial Group Ltd., Himalaya International Clearing Ltd., Himalaya International Payments Ltd., Himalaya International Reserves Ltd., Jesse Brown, William Je, William Je, Eastern Profit Corporation Limited, HK International Funds Investments (USA) Limited LLC, Bravo Luck Limited, Golden Spring (New York) Ltd., Lamp Capital LLC, Greenwich Land LLC, Qu Guo Jiao, Daniel Thomas Podhaskie, Yvette Wang (a/k/a Yanping Wang, a/k/a Yan Ping Wang), Ace Decade Holdings Limited, Dawn State Limited, Rule of Law Society IV Inc., Rule of Law Foundation III, Inc., Rule of Law Foundation IV, Inc., Rule of Law Fund, Rule of Law Society, GTV Media Group, Inc., Voice of Guo Media, Inc., Saraca Media Group Inc., Genever Holdings Corporation, Genever Holdings LLC, Gnews Media Group Inc., G Fashion LLC, Gmusic LLC, Gnews LLC, Geducation, GFNY, Inc., G-Club Investments Limited, G Club Operations LLC, G Club US Operations Inc., G Club US Operations LLC, G Live, LLC, Gbroadcast, LLC, Gposts LLC, HCHK Property\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 585 of 1063\n\nManagement, Inc., HCHK Technologies, Inc., FMV Ltd./Freedom Media Venture Ltd., Roscalitar 2, Himalaya New World Inc., US Himalaya Capital Inc., Hudson Diamond Holding, Inc., Hudson Diamond Holding LLC, Hudson Diamond NY LLC, Infinity Treasury Management Inc., Lexington Property and Staffing, Inc., AI Group Holdings Inc., Hamilton Capital Holdings Inc., Booming Sail New York LLC, Himalaya Ventures LLC, Himalaya Ventures LLC, Himalaya Investment LLC, New York MOS Himalaya LLC, MOS Himalaya LLC, Crane Advisory Group, Maywind Trading LLC, Gettr USA, Inc., Han Chunguang, Bingshang Jiao, Karin Maistrello, Mary Jiang, Jiaming Liu, and Wencong Wang.\n\n8. \"Including\" or any variant thereof means \"including without limitation.\"\n\n9. \"And\" and \"or\" mean \"and/or,\" and shall be construed both conjunctively as well as disjunctively in order to maximize their scope.\n\n10. \"Any\" and \"all\" and \"each\" mean \"each and every.\"\n\n11. \"Each\" and \"every\" mean \"each and every.\"\n\n12. \"Third Party\" means a Person or Entity other than Yourself.\n\n13. \"Transfer\" shall have the meaning given to it by section 101(54) of the Bankruptcy Code.\n\n14. \"Document\" means any information or thing within the scope of Fed. R. Civ. P. 34, and includes, without limitation, each and every written, recorded, or graphic matter of any kind, type, nature, or description that is or has been in Your Possession, Custody or Control, including all printed and electronic copies of electronic mail, computer files maintained in electronic form, correspondence, memoranda, tapes, stenographic or handwritten notes, written forms of any kind, charts, blueprints, drawings, sketches, graphs, plans, articles, specifications, diaries, letters,\n\n#### Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 586 of 1063\n\ntelegrams, photographs, minutes, contracts, agreements, surveys, computer printouts, data compilations of any kind, telexes, facsimiles, emails, text messages, instant messages, voice messages, invoices, order forms, checks, drafts, statements, credit memos, reports, position reports, summaries, indices, books, ledgers, notebooks, schedules, transparencies, recordings, catalogs, advertisements, promotional materials, films, video tapes, audio tapes, CDs, computer disks, brochures, pamphlets, punch-cards, time-slips, Tweets, social media posts, or any written or recorded materials of any other kind, and all meta-data thereof, however stored (whether in tangible or electronic form), recorded, produced, or reproduced, and also including but not limited to, drafts or copies of any of the foregoing that contain any notes, comments, or markings of any kind not found on the original documents or that are otherwise not identical to the original documents.\n\n15. \"Person(s)\" means an individual, corporation, proprietorship, partnership, association, or any other Entity. \"Person\" also includes any agent, representatives, or expert, including but not limiting to, attorneys or financial advisors.\n\n16. \"Entity\" means any natural Person, corporation, partnership, subsidiary, sole proprietorship, firm, board, joint venture, association, agency, authority, commission or other business entity or juristic Person, as well as any affiliate, agent, parent including but not limited to counsel, financial advisors, or any other representative.\n\n17. \"Regarding\" means concerning, describing, comprising, referring to, related to, supporting, favoring, opposing, bolstering, detracting from, located in, considered in connection with, bearing on, evidencing, indicating, reporting on, recording, alluding to, responding to, connected with, commenting on, in respect of, about, in relation to, discussing, showing, describing, reflecting, analyzing constituting, and being.\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 587 of 1063\n\n18. \"Relating to,\" \"relate(s) to\" or \"related to,\" when referring to any given subject matter, means, without limitation, any document that constitutes, comprises, involves, contains, embodies, reflects, identifies, states, refers directly or indirectly to, or is in any way relevant to the particular subject matter identified.\n\n19. \"Communication(s)\" means, in the broadest possible sense, and without limitation, any transmittal of information or knowledge (in the form of facts, ideas, inquiries, or otherwise). Communication(s) further refers to all conversations, agreements, inquiries, or replies, whether in person, by telephone, in writing, or by means of electronic transmittal devices, and includes, but is not limited to, all correspondence, emails, recordings, transmittal slips, memoranda, telephone communications, voice messages, telegrams, telefaxes, telecopies, telexes, instant messages, chats, text messages, postings to a message board or group chat, social media posts, tweets, videos uploaded to any video platform, telephonic notes, or notes transmitted internally or with third parties.\n\n#### **IV. DOCUMENTS TO BE PRODUCED**\n\n1. All Documents related to any funds or other value transferred to or received by You by or on behalf of any of the 2004 Discovery Targets.\n\n2. All Documents related to any account held by, controlled by, on behalf of, or otherwise related to any of the 2004 Discovery Targets, including any and all account statements, agreements, authorizations, records of usage, or correspondence.\n\n3. All Documents related to any correspondence and communications between you and the 2004 Discovery Targets.\n\nCase 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 588 of 1063\n\n# Exhibit C-32\n\n#### B2540 (Form 2540 – Subpoena for Rule 2004 Examination) (12/15) Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 589 of\n\nUNITED STATES BANKRUPTCY COURT 1063\n\n**District of Connecticut**\n\nIn re HO WAN KWOK, *et al*.,\n\n<sup>1</sup> Case No. 22-50073 (JAM)\n\nDebtor Chapter 11\n\n(Jointly Administered)\n\n## **SUBPOENA FOR RULE 2004 EXAMINATION**\n\nTo: **HSBC Bank USA, N.A.**\n\n(*Name of person to whom the subpoena is directed*)\n\n*Testimony:* **YOU ARE COMMANDED** to appear at the time, date, and place set forth below to testify at an examination under Rule 2004, Federal Rules of Bankruptcy Procedure. A copy of the court order authorizing the examination is attached.\n\n| PLACE                          | DATE AND TIME |\n|--------------------------------|---------------|\n| Neubert, Pepe & Monteith, P.C. |               |\n| 195 Church Street, Floor 13    | [TBD]         |\n| New Haven, Connecticut 06510   |               |\n|                                |               |\n\nThe examination will be recorded by this method: **Court reporter/stenographer**\n\n*Production:* You, or your representatives, must also bring with you to the examination the following documents, electronically stored information, or objects, and must permit inspection, copying, testing, or sampling of the material:\n\n#### **See Requests for Production of Documents, attached hereto.**\n\nThe following provisions of Fed. R. Civ. P. 45, made applicable in bankruptcy cases by Fed. R. Bankr. P. 9016, are attached – Rule 45(c), relating to the place of compliance; Rule 45(d), relating to your protection as a person subject to a subpoena; and Rule 45(e) and 45(g), relating to your duty to respond to this subpoena and the potential consequences of not doing so.\n\nDate: **March , 2023**\n\nCLERK OF COURT\n\nOR\n\n*Signature of Clerk or Deputy Clerk Attorney's signature*\n\nThe name, address, email address, and telephone number of the attorney representing Luc A. Despins, Chapter 11 Trustee, who issues or requests this subpoena, are:\n\n**Douglas S. Skalka, Esq.; Neubert, Pepe & Monteith, P.C.; 195 Church Street, New Haven, Connecticut 06510 dskalka@npmlaw.com; (203) 821-2000**\n\n**Notice to the person who issues or requests this subpoena**\n\nIf this subpoena commands the production of documents, electronically stored information, or tangible things, or the inspection of premises before trial, a notice and a copy of this subpoena must be served on each party before it is served on the person to whom it is directed. Fed. R. Civ. P. 45(a)(4).\n\nSoftware Copyright (c) 1996-2022 Best Case, LLC - www.bestcase.com Best Case Bankruptcy 1 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\n#### **PROOF OF SERVICE**\n\n**(This section should not be filed with the court unless required by Fed. R. Civ. P. 45.)**\n\nI received this subpoena for (*name of individual and title, if any*): on (*date*) .\n\nI served the subpoena by delivering a copy to the named person as follows:\n\non *(date)* ; or\n\nI returned the subpoena unexecuted because:\n\nUnless the subpoena was issued on behalf of the United States, or one of its officers or agents, I have also tendered to the witness the fees for one day's attendance, and the mileage allowed by law, in the amount of \\$ .\n\nMy fees are \\$ for travel and \\$ for services, for a total of \\$ .\n\nI declare under penalty of perjury that this information is true and correct.\n\nDate:\n\n*Server's signature*\n\n*Printed name and title*\n\n*Server's address*\n\nAdditional information concerning attempted service, etc.:\n\n#### **Federal Rule of Civil Procedure 45(c), (d), (e), and (g) (Effective 12/1/13) (made applicable in bankruptcy cases by Rule 9016, Federal Rules of Bankruptcy Procedure)**\n\n#### **(c) Place of compliance.**\n\n*(1) For a Trial, Hearing, or Deposition.* A subpoena may command a person to attend a trial, hearing, or deposition only as follows:\n\n(A) within 100 miles of where the person resides, is employed, or regularly transacts business in person; or\n\n(B) within the state where the person resides, is employed, or regularly transacts business in person, if the person\n\n(i) is a party or a party's officer; or\n\n(ii) is commanded to attend a trial and would not incur substantial expense.\n\n*(2) For Other Discovery.* A subpoena may command:\n\n(A) production of documents, or electronically stored information, or things at a place within 100 miles of where the person resides, is employed, or regularly transacts business in person; and\n\n(B) inspection of premises, at the premises to be inspected.\n\n#### **(d) Protecting a Person Subject to a Subpoena; Enforcement.**\n\n*(1) Avoiding Undue Burden or Expense; Sanctions.* A party or attorney responsible for issuing and serving a subpoena must take reasonable steps to avoid imposing undue burden or expense on a person subject to the subpoena. The court for the district where compliance is required must enforce this duty and impose an appropriate sanction which may include lost earnings and reasonable attorney's fees — on a party or attorney who fails to comply.\n\n#### *(2) Command to Produce Materials or Permit Inspection.*\n\n*(A) Appearance Not Required.* A person commanded to produce documents, electronically stored information, or tangible things, or to permit the inspection of premises, need not appear in person at the place of production or inspection unless also commanded to appear for a deposition, hearing, or trial.\n\n*(B) Objections.* A person commanded to produce documents or tangible things or to permit inspection may serve on the party or attorney designated in the subpoena a written objection to inspecting, copying, testing or sampling any or all of the materials or to inspecting the premises — or to producing electronically stored information in the form or forms requested. The objection must be served before the earlier of the time specified for compliance or 14 days after the subpoena is served. If an objection is made, the following rules apply:\n\n(i) At any time, on notice to the commanded person, the serving party may move the court for the district where compliance is required for an order compelling production or inspection.\n\n(ii) These acts may be required only as directed in the order, and the order must protect a person who is neither a party nor a party's officer from significant expense resulting from compliance.\n\n#### *(3) Quashing or Modifying a Subpoena.*\n\n*(A) When Required.* On timely motion, the court for the district where compliance is required must quash or modify a subpoena that:\n\n(i) fails to allow a reasonable time to comply;\n\n(ii) requires a person to comply beyond the geographical limits specified in Rule 45(c);\n\n(iii) requires disclosure of privileged or other protected matter, if no exception or waiver applies; or\n\n(iv) subjects a person to undue burden.\n\n*(B) When Permitted.* To protect a person subject to or affected by a subpoena, the court for the district where compliance is required may, on motion, quash or modify the subpoena if it requires:\n\n(i) disclosing a trade secret or other confidential research, development, or commercial information; or\n\n(ii) disclosing an unretained expert's opinion or information that does not describe specific occurrences in dispute and results from the expert's study that was not requested by a party.\n\n(C) *Specifying Conditions as an Alternative.* In the circumstances described in Rule 45(d)(3)(B), the court may, instead of quashing or modifying a subpoena, order appearance or production under specified conditions if the serving party:\n\n(i) shows a substantial need for the testimony or material that cannot be otherwise met without undue hardship; and\n\n(ii) ensures that the subpoenaed person will be reasonably compensated.\n\n#### **(e) Duties in Responding to a Subpoena.**\n\n*(1) Producing Documents or Electronically Stored Information.* These procedures apply to producing documents or electronically stored information:\n\n*(A) Documents.* A person responding to a subpoena to produce documents must produce them as they are kept in the ordinary course of business or must organize and label them to correspond to the categories in the demand.\n\n*(B) Form for Producing Electronically Stored Information Not Specified.* If a subpoena does not specify a form for producing electronically stored information, the person responding must produce it in a form or forms in which it is ordinarily maintained or in a reasonably usable form or forms.\n\n*(C) Electronically Stored Information Produced in Only One Form.* The person responding need not produce the same electronically stored information in more than one form.\n\n*(D) Inaccessible Electronically Stored Information.* The person responding need not provide discovery of electronically stored information from sources that the person identifies as not reasonably accessible because of undue burden or cost. On motion to compel discovery or for a protective order, the person responding must show that the information is not reasonably accessible because of undue burden or cost. If that showing is made, the court may nonetheless order discovery from such sources if the requesting party shows good cause, considering the limitations of Rule 26(b)(2)(C). The court may specify conditions for the discovery.\n\n#### *(2) Claiming Privilege or Protection.*\n\n*(A) Information Withheld.* A person withholding subpoenaed information under a claim that it is privileged or subject to protection as trial-preparation material must: (i) expressly make the claim; and\n\n(ii) describe the nature of the withheld documents, communications, or tangible things in a manner that, without revealing information itself privileged or protected, will enable the parties to assess the claim.\n\n*(B) Information Produced.* If information produced in response to a subpoena is subject to a claim of privilege or of protection as trial-preparation material, the person making the claim may notify any party that received the information of the claim and the basis for it. After being notified, a party must promptly return, sequester, or destroy the specified information and any copies it has; must not use or disclose the information until the claim is resolved; must take reasonable steps to retrieve the information if the party disclosed it before being notified; and may promptly present the information under seal to the court for the district where compliance is required for a determination of the claim. The person who produced the information must preserve the information until the claim is resolved.\n\n**(g) Contempt.** The court for the district where compliance is required – and also, after a motion is transferred, the issuing court – may hold in contempt a person who, having been served, fails without adequate excuse to obey the subpoena or an order related to it.\n\nFor access to subpoena materials, see Fed.R.Civ.P.45(a) Committee Note (2013)\n\n…\n\n## **Request for Production of Documents**\n\n## **I. INSTRUCTIONS**\n\n1. Unless otherwise indicated, the requests for documents set forth below, (the \"Requests,\" and each, a \"Request\"), must be responded to separately and specifically. Each Request shall be answered fully unless it is in good faith objected to, in which event the reason for Your objection shall be stated in detail, as set forth below. If an objection pertains only to a portion of a Request, or a word, phrase or clause contained within it, You are required to state Your objection to that portion only and to respond to the remainder of the Requests.\n\n2. Electronically stored information must be produced in accordance with the\n\nfollowing instructions:\n\n- a. Images. Black and white images must be 300 DPI Group IV single-page TIFF files. Color images must be produced in JPEG format. File names cannot contain embedded spaces or special characters (including the comma). Folder names cannot contain embedded spaces or special characters (including the comma). All TIFF image files must have a unique file name, i.e. Bates number. Images must be endorsed with sequential Bates numbers in the lower right corner of each image. The number of TIFF files per folder should not exceed 1000 files. Excel spreadsheets should have a placeholder image named by the Bates number of the file.\n- b. Image Load File\n\t- a. Concordance® Data File. The data file (.DAT) contains all of the fielded information that will be loaded into the Concordance® database. The first line of the .DAT file must be a header row identifying the field names. The .DAT file must use the following Concordance® default delimiters: Comma ASCII character (020) Quote þ ASCII character (254). Date fields should be provided in the format: mm/dd/yyyy. Date and time fields must be two separate fields. If documents includes imaged emails and attachments, the attachment fields must be included to preserve the parent/child relationship between an email and its attachments. An OCRPATH field must be included to provide the file path and name of the extracted text file on the produced storage media. The text file must be named after the FIRSTBATES. Do not include the text in the .DAT file. For Documents with native files, a LINK field must be included to provide the file path and\n\nname of the native file. The native file must be named after the FIRSTBATES.\n\n- b. Concordance Image® OR Opticon Cross-Reference File. The image crossreference file (.LOG or .OPT) links the images to the database records. It should be a comma-delimited file consisting of seven fields per line with a line in the cross-reference file for every image in the database with the following format: ImageID,VolumeLabel,ImageFilePath,DocumentBreak,FolderBreak,Box Break,PageCoun.\n- c. Document Text. Text must be produced as separate text files, not as fields within the .DAT file. The full path to the text file (OCRPATH) should be included in the .DAT file. It is recommended document level ANSI text files, named per the FIRSTBATES/Image Key. Extracted text files must be in a separate folder, and the number of text files per folder should not exceed 1,000 files. There should be no special characters (including commas in the folder names). Text files must be provided on a document level.\n- d. Native Production for Certain File Types. File types that reasonably require viewing in their native format for a full understanding of their content and meaning must be produced in native format. These include, but are not limited to, spreadsheets, spreadsheet-like files (Microsoft Excel, comma separated values, tab separated values, etc.), Microsoft PowerPoint or other special presentation files, database files, and audio/visual files. Provide an image of a Bates numbered slip sheet indicating the presence of a native file, and include the path to the native as a field in the .dat file. Name the produced native file with the Bates number corresponding to the slip sheet for the file. Group native files within incrementally named \"NATIVE\" directories, separate from images directories.\n- e. De-duplication. Produce a single copy of each electronic document for which exact duplicates exist. For email messages, consolidate duplicates based on MD5 hash generated from the BCC, Body, CC, From, IntMsgID, To, and Attach properties. For email attachments and standalone electronic files, consolidate duplicates based on MD5 hash of the entire file.\n- f. Metadata. Produce extracted metadata for each document in the form of a Concordance compliant load file (.dat). The first line of the .DAT file must be a header row identifying the field names. The .DAT file must use the following Concordance default delimiters: Comma , ASCII character (020) Quote þ ASCII character (254)\n\nDate fields should be provided in the format: mm/dd/yyyy. Date and time fields must be two separate fields. Required metadata listed below:\n\n# Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 594 of 1063\n\n| Field Name   | Sample Data              | Description                                      |\n|--------------|--------------------------|--------------------------------------------------|\n| FIRSTBATES   | EDC0000001               | First Bates number of native file document/email |\n| LASTBATES    | EDC0000001               | Last Bates number of native file document/email  |\n|              |                          | **The LASTBATES field should be populated        |\n|              |                          | for single page                                  |\n| ATTACHRANGE  | EDC0000001<br>-          | Bates number of the first page of the parent     |\n|              | EDC0000015               | document to the Bates number of the last page of |\n|              |                          | the last attachment \"child\" document             |\n| BEGATTACH    | EDC0000001               | First Bates number of attachment range           |\n| ENDATTACH    | EDC0000015               | Last Bates number of attachment range            |\n| CUSTODIAN    | Smith, John              | Email: Mailbox where the email resided           |\n|              |                          | Native: Name of the individual or department     |\n|              |                          | from whose files the document<br>originated      |\n| FROM         | John Smith               | Email: Sender                                    |\n|              |                          | Native: Author(s) of document                    |\n|              |                          | **semi-colon should be used to separate          |\n|              |                          | multiple entries                                 |\n| TO           | Coffman, Janice; LeeW    | Recipient(s)                                     |\n|              | [mailto:LeeW@MSN.com]    | **semi-colon should be used to separate multiple |\n|              |                          | entries                                          |\n| CC           | Frank Thompson [mailto:  | Carbon copy recipient(s)                         |\n|              | frank_Thompson@cdt.com]  | **semi-colon should be used to separate          |\n|              |                          | multiple entries                                 |\n| BCC          | John Cain                | Blind carbon copy recipient(s)                   |\n|              |                          | **semi-colon should be used to separate          |\n|              |                          | multiple entries                                 |\n| SUBJECT      | Board Meeting Minutes    | Email: Subject line of the email Native: Title   |\n|              |                          | of document (if available)                       |\n| FILE_NAME    | BoardMeetingMinutes.docx | Native: Name of the original native file,        |\n|              |                          | including extension                              |\n| DATE_SENT    | 10/12/2010               | Email: Date the email was sent                   |\n|              |                          | Native: (empty)                                  |\n| TIME_SENT/   | 07:05 PM GMT             | Email: Time the email was sent/ Time zone in     |\n| TIME_ZONE    |                          | which the emails were standardized               |\n| TIME_ZONE    | GMT                      | The<br>time zone in which<br>the emails<br>were  |\n|              |                          | standardized during conversion.                  |\n| LINK         |  EDC0000001.msg   | Hyperlink to the email or native file document   |\n|              |                          | **The linked file must be named per the          |\n|              |                          | FIRSTBATES number                                |\n| FILE_EXTEN   | MSG                      | The file type extension                          |\n|              |                          | representing                                     |\n|              |                          | the Email or                                     |\n| AUTHOR       | John Smith               | Email: (empty)                                   |\n|              |                          | Native: Author of the document                   |\n| DATE_CREATED | 10/10/2010               | Email: (empty)                                   |\n|              |                          | Native: Date the document was created            |\n\n# Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 595 of 1063\n\n| TIME_CREATED | 10:25 AM                  | Email: (empty)                                  |\n|--------------|---------------------------|-------------------------------------------------|\n|              |                           | Native: Time the document was created           |\n|              |                           | **This data must be a separate field and cannot |\n|              |                           | be combined with the DATE_CREATED field         |\n| DATE_MOD     | 10/12/2010                | Email: (empty)                                  |\n|              |                           | Native: Date the document was last modified     |\n| TIME_MOD     | 07:00 PM                  | Email: (empty)                                  |\n|              |                           | Native: Time the document was last modified     |\n|              |                           | **This data must be a separate field and cannot |\n|              |                           | be combined with the DATE_MOD field             |\n| DATE_ACCESSD | 10/12/2010                | Email: (empty)                                  |\n|              |                           | Native: Date the document was last accessed     |\n| TIME_ACCESSD | 07:00 PM                  | Email: (empty)                                  |\n|              |                           | Native: Time the document was last accessed     |\n|              |                           | **This data must be a separate field and cannot |\n|              |                           | be combined with the DATE_ACCESSD field         |\n| FILE_SIZE    | 5,952                     | Size of native file<br>document/email in KB     |\n| PGCOUNT      | 1                         | Number of pages in native file document/email   |\n| PATH         |   | Email: (empty)                                  |\n|              | Agenda.doc                | Native: Path where native file document was     |\n|              |                           | stored including original file name.            |\n| INTFILEPATH  | Personal Folders\\Deleted  | Email: original location of email including     |\n|              | Items\\Board Meeting       | original file name.                             |\n|              | Minutes.msg               | Native: (empty)                                 |\n| INTMSGID     | <000805c2c71b\\$75977050\\$ | Email: Unique Message ID Native: (empty)        |\n|              | cb8306d1@MSN>             |                                                 |\n| MD5HASH      | d131dd02c5e6eec4693d9a0   | MD5 Hash value of the document.                 |\n|              | 698aff95c                 |                                                 |\n|              | 2fcab58712467eab4004583e  |                                                 |\n|              | b8fb7f89                  |                                                 |\n| OCRPATH      | TEXT/001/EDC0000001.txt   | Path to extracted text of the native file       |\n\n3. Each Request operates and should be construed independently and, unless otherwise indicated, no Request limits the scope of any other Request.\n\n4. All Documents are to be produced as kept in the usual course of business or are to be organized and labeled to correspond with the categories in these Requests.\n\n5. Each Request contained herein extends to all Documents: (a) in Your possession, custody, or control; or (b) in the possession, custody, or control of anyone acting on Your behalf,\n\n#### Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 596 of 1063\n\nincluding Your counsel or other representatives and advisors. Each Document shall be produced in its entirety.\n\n6. If You are requested to produce a Document that is no longer in Your possession, custody, or control, then Your response must (a) describe in detail the nature of the document and its contents; (b) identify the person(s) who prepared or authored the Document (and, if applicable, the Person(s) to whom the Document was sent); (c) identify the date on which the document was prepared or created; (d) state whether such Document (i) is missing or lost, (ii) has been destroyed, (iii) has been transferred, voluntarily or involuntarily, to others, or (iv) was otherwise disposed of; (e) state the reason for, and the facts and circumstances surrounding, such disposition; (f) identify the Persons who authorized such disposition; (g) identify the date or approximate date of such disposition; (h) state when the Document was most recently in Your possession, custody or control; and (i) identify the Person, if any, presently in possession, custody, or control of such Document.\n\n7. If You are requested to produce a Document that has been destroyed, then Your response must state, in addition to the information required by the preceding Instruction: (a) the reason for the Document's destruction; (b) the identity of the Person who destroyed the Document; and (c) the identity of the Person who directed that the Document be destroyed.\n\n8. If You claim that a requested Document is privileged or attorney work-product, then Your response must: (a) state (i) a description of the Document adequate to support Your contention that the Document is privileged, (ii) the title of the Document, (iii) the date of the Document, (iv) the author of the Document, (v) the addressee of the Document, (vi) the identity of each Person who received or saw the original or any draft, copy, or reproduction of the Document, (vii) whether the Document itself, or any information contained or referred to in the Document is in the possession, custody, or control of any other Persons, and if so, the identity of\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 597 of 1063\n\nsuch Persons, as well as a statement addressing how the information came into their possession, (viii) the claim of privilege under which the Document is withheld, and (ix) all of the circumstances upon which You will rely to support such claim of privilege; and (b) produce a privilege log containing all of the information requested in Part (a) of this Instruction for each Document withheld on the basis of a claim of privilege in accordance with D. Conn. L. Civ. R. 26(e). For any part of a Document Request as to which a claim of privilege or work product is not made, responsive documents should be provided in full.\n\n9. If a portion of an otherwise responsive Document contains information subject to a claim of privilege, only that portion of the Document subject to the claim of privilege shall be deleted or redacted from the Document following the instructions above, and the rest shall be produced.\n\n10. The Requests are continuing in nature. You are hereby instructed to (a) supplement or correct any responses later learned to be incomplete or incorrect immediately upon learning that a prior response was incomplete or incorrect; and (b) produce any additional Documents that are called for under the\n\n11. If a Document is in a language other than English, You should provide that Document. If a Document is in a language other than English, and an English translation exists, You should provide both Documents.\n\n12. All references to Entities includes all affiliates thereof.\n\n13. All references to individual names include all alternative names, aliased, or nicknames.\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 598 of 1063\n\n14. Unless otherwise expressly indicated, the period of time covered by the Document Requests is the period from February 5, 2012 to the date responses to the Document Requests are due.\n\n#### **II. RULES OF CONSTRUCTION**\n\n15. The use of (a) any singular noun shall be construed to include the plural, and vice versa, and (b) a verb in any tense shall be construed as the use of the verb in all other tenses.\n\n16. The terms (a) \"and\" and \"or\" shall be construed either conjunctively or disjunctively as necessary to bring within the scope of any request all responses that might otherwise be construed to be outside of its scope, and (b) \"each\" and \"any\" shall be deemed to include and encompass the words \"every\" and \"all.\"\n\n#### **III. DEFINITIONS**\n\nThe definitions supplied by D. Conn. L. Civ. R. 26(c) and the rules of construction supplied by D. Conn. L. Civ. R. 26(d), as incorporated by D. Conn. Bankr. L.R. 2004-1(a), shall apply to the Document Requests. In addition, the following terms used in these Document Requests shall have the following meanings:\n\n1. \"You\" or \"Your\" or \"Yourself\" means and refers, to HSBC Bank USA, N.A., together with all of its affiliates.\n\n2. \"Debtor\" means Ho Wan Kwok (a/k/a Miles Kwok, Miles Guo, Guo Wengui, Guo Haoyun, 郭文贵, or any other alias), together with his employees, agents, counsel, advisors, or anyone acting on his behalf.\n\n#### Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 599 of 1063\n\n3. \"Debtor's Son\" means Qiang Guo (a/k/a Mileson Kwok, 郭强, or any other alias), together with his employees, agents, counsel, advisors, or anyone acting on his behalf.\n\n4. \"Debtor's Daughter\" means Mei Guo (a/k/a Mei Gui, 郭美, or any other alias), together with her employees, agents, counsel, advisors, or anyone acting on her behalf.\n\n5. \"Debtor's Purported Wife\" means Hing Chi Ngok (a/k/a Hing Chi Ng, Yue Qingzhi, 岳庆芝, or any other alias), together with her employees, agents, counsel, advisors, or anyone acting on her behalf.\n\n6. \"Debtor's Family\" means, individually and collectively, the Debtor, the Debtor's Son, the Debtor's Daughter, and the Debtor's Purported Wife, and any other familial relation to the Debtor.\n\n7. \"2004 Discovery Targets\" means, individually and collectively, the Debtor, the Debtor's Family, ACA Capital Group Limited, Himalaya International Financial Group Ltd., Himalaya International Clearing Ltd., Himalaya International Payments Ltd., Himalaya International Reserves Ltd., Jesse Brown, William Je, William Je, Eastern Profit Corporation Limited, HK International Funds Investments (USA) Limited LLC, Bravo Luck Limited, Golden Spring (New York) Ltd., Lamp Capital LLC, Greenwich Land LLC, Qu Guo Jiao, Daniel Thomas Podhaskie, Yvette Wang (a/k/a Yanping Wang, a/k/a Yan Ping Wang), Ace Decade Holdings Limited, Dawn State Limited, Rule of Law Society IV Inc., Rule of Law Foundation III, Inc., Rule of Law Foundation IV, Inc., Rule of Law Fund, Rule of Law Society, GTV Media Group, Inc., Voice of Guo Media, Inc., Saraca Media Group Inc., Genever Holdings Corporation, Genever Holdings LLC, Gnews Media Group Inc., G Fashion LLC, Gmusic LLC, Gnews LLC, Geducation, GFNY, Inc., G-Club Investments Limited, G Club Operations LLC, G Club US Operations Inc., G Club US Operations LLC, G Live, LLC, Gbroadcast, LLC, Gposts LLC, HCHK Property\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 600 of 1063\n\nManagement, Inc., HCHK Technologies, Inc., FMV Ltd./Freedom Media Venture Ltd., Roscalitar 2, Himalaya New World Inc., US Himalaya Capital Inc., Hudson Diamond Holding, Inc., Hudson Diamond Holding LLC, Hudson Diamond NY LLC, Infinity Treasury Management Inc., Lexington Property and Staffing, Inc., AI Group Holdings Inc., Hamilton Capital Holdings Inc., Booming Sail New York LLC, Himalaya Ventures LLC, Himalaya Ventures LLC, Himalaya Investment LLC, New York MOS Himalaya LLC, MOS Himalaya LLC, Crane Advisory Group, Maywind Trading LLC, Gettr USA, Inc., Han Chunguang, Bingshang Jiao, Karin Maistrello, Mary Jiang, Jiaming Liu, and Wencong Wang.\n\n8. \"Including\" or any variant thereof means \"including without limitation.\"\n\n9. \"And\" and \"or\" mean \"and/or,\" and shall be construed both conjunctively as well as disjunctively in order to maximize their scope.\n\n10. \"Any\" and \"all\" and \"each\" mean \"each and every.\"\n\n11. \"Each\" and \"every\" mean \"each and every.\"\n\n12. \"Third Party\" means a Person or Entity other than Yourself.\n\n13. \"Transfer\" shall have the meaning given to it by section 101(54) of the Bankruptcy Code.\n\n14. \"Document\" means any information or thing within the scope of Fed. R. Civ. P. 34, and includes, without limitation, each and every written, recorded, or graphic matter of any kind, type, nature, or description that is or has been in Your Possession, Custody or Control, including all printed and electronic copies of electronic mail, computer files maintained in electronic form, correspondence, memoranda, tapes, stenographic or handwritten notes, written forms of any kind, charts, blueprints, drawings, sketches, graphs, plans, articles, specifications, diaries, letters,\n\n### Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 601 of 1063\n\ntelegrams, photographs, minutes, contracts, agreements, surveys, computer printouts, data compilations of any kind, telexes, facsimiles, emails, text messages, instant messages, voice messages, invoices, order forms, checks, drafts, statements, credit memos, reports, position reports, summaries, indices, books, ledgers, notebooks, schedules, transparencies, recordings, catalogs, advertisements, promotional materials, films, video tapes, audio tapes, CDs, computer disks, brochures, pamphlets, punch-cards, time-slips, Tweets, social media posts, or any written or recorded materials of any other kind, and all meta-data thereof, however stored (whether in tangible or electronic form), recorded, produced, or reproduced, and also including but not limited to, drafts or copies of any of the foregoing that contain any notes, comments, or markings of any kind not found on the original documents or that are otherwise not identical to the original documents.\n\n15. \"Person(s)\" means an individual, corporation, proprietorship, partnership, association, or any other Entity. \"Person\" also includes any agent, representatives, or expert, including but not limiting to, attorneys or financial advisors.\n\n16. \"Entity\" means any natural Person, corporation, partnership, subsidiary, sole proprietorship, firm, board, joint venture, association, agency, authority, commission or other business entity or juristic Person, as well as any affiliate, agent, parent including but not limited to counsel, financial advisors, or any other representative.\n\n17. \"Regarding\" means concerning, describing, comprising, referring to, related to, supporting, favoring, opposing, bolstering, detracting from, located in, considered in connection with, bearing on, evidencing, indicating, reporting on, recording, alluding to, responding to, connected with, commenting on, in respect of, about, in relation to, discussing, showing, describing, reflecting, analyzing constituting, and being.\n\n### Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 602 of 1063\n\n18. \"Relating to,\" \"relate(s) to\" or \"related to,\" when referring to any given subject matter, means, without limitation, any document that constitutes, comprises, involves, contains, embodies, reflects, identifies, states, refers directly or indirectly to, or is in any way relevant to the particular subject matter identified.\n\n19. \"Communication(s)\" means, in the broadest possible sense, and without limitation, any transmittal of information or knowledge (in the form of facts, ideas, inquiries, or otherwise). Communication(s) further refers to all conversations, agreements, inquiries, or replies, whether in person, by telephone, in writing, or by means of electronic transmittal devices, and includes, but is not limited to, all correspondence, emails, recordings, transmittal slips, memoranda, telephone communications, voice messages, telegrams, telefaxes, telecopies, telexes, instant messages, chats, text messages, postings to a message board or group chat, social media posts, tweets, videos uploaded to any video platform, telephonic notes, or notes transmitted internally or with third parties.\n\n20. \"Asset(s)\" means any item of economic value that is subject to Possession, Custody, or Control. Asset includes all real and personal property, including but limited to, real estate, land, houses, apartments, condominiums, automobiles, yachts, boats, planes, jets, helicopters, cash, bank accounts, cryptocurrencies, securities, accounts receivables, inventory, and other tangible and intangible property.\n\n#### **IV. DOCUMENTS TO BE PRODUCED**\n\n1. All Documents related to any account held by, controlled by, on behalf of, or otherwise related to any of the 2004 Discovery Targets, including any and all account statements, authorizations, power of attorney, trusts, instructions or forms, copies of cancelled checks, correspondence, and wire transfers and related correspondence and instructions.\n\n#### Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 603 of 1063\n\n2. All Documents related to any funds, securities, property, or assets belonging to, held by, controlled by, on behalf of, or otherwise related to any of the 2004 Discovery Targets, including any and all account statements, authorizations, powers of attorney, trusts, instructions or forms, copies of cancelled checks, correspondence, and wire transfers and related correspondence and instructions.\n\n3. All Documents related to any business, commerce or financial transactions, including but not limited to any loan, line of credit, bailment, deposit, swap, securities transactions, mortgage, or ISDA, with any of the 2004 Discovery Targets, including any and all account statements, authorizations, powers of attorney, trusts, instructions or forms, copies of cancelled checks, correspondence, and wire transfers and related correspondence and instructions.\n\n4. All Documents relating to any wire transfer activity relating to the 2004 Discovery Targets, regardless of the existence of any accounts, including but not limited to all wire transfer receipts, account numbers, balances, authorizations, identification information related to the parties to the transfer, correspondence, instructions, or other records.\n\n5. All Documents related to any correspondence and communications between you and the 2004 Discovery Targets.\n\n6. All Documents related to any account with any 2004 Discovery Target relating to opening of the account, authorized users of the account and maintenance of the account.\n\n7. All Documents related to any anti-money laundering, know-your-customer, or other compliance activity relating to any of the 2004 Discovery Targets, including but not limited to any information provided by any of the 2004 Discovery Targets, or learned by You.\n\n8. All Documents relating to any communications with any regulator from any country, including but not limited to the Bank of England, the United States Federal Reserve, the\n\nS.E.C., the CFTC, FINRA, China Securities Regulatory Commission, People's Bank of China, Hong Kong Securities and Futures Commission, and the Hong Kong Monetary Authority relating to any of the 2004 Discovery Targets.\n\nCase 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 605 of 1063\n\n# Exhibit C-33\n\n#### B2540 (Form 2540 – Subpoena for Rule 2004 Examination) (12/15) Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 606 of\n\nUNITED STATES BANKRUPTCY COURT 1063\n\n**District of Connecticut**\n\nIn re HO WAN KWOK, *et al*.,\n\n<sup>1</sup> Case No. 22-50073 (JAM)\n\nDebtor Chapter 11\n\n(Jointly Administered)\n\n## **SUBPOENA FOR RULE 2004 EXAMINATION**\n\nTo: Bank of China – New York Branch and/or Bank of China Limited\n\n(*Name of person to whom the subpoena is directed*)\n\n*Testimony:* **YOU ARE COMMANDED** to appear at the time, date, and place set forth below to testify at an examination under Rule 2004, Federal Rules of Bankruptcy Procedure. A copy of the court order authorizing the examination is attached.\n\n| PLACE                          | DATE AND TIME |\n|--------------------------------|---------------|\n| Neubert, Pepe & Monteith, P.C. |               |\n| 195 Church Street, Floor 13    | [TBD]         |\n| New Haven, Connecticut 06510   |               |\n|                                |               |\n\nThe examination will be recorded by this method: **Court reporter/stenographer**\n\n*Production:* You, or your representatives, must also bring with you to the examination the following documents, electronically stored information, or objects, and must permit inspection, copying, testing, or sampling of the material:\n\n#### **See Requests for Production of Documents, attached hereto.**\n\nThe following provisions of Fed. R. Civ. P. 45, made applicable in bankruptcy cases by Fed. R. Bankr. P. 9016, are attached – Rule 45(c), relating to the place of compliance; Rule 45(d), relating to your protection as a person subject to a subpoena; and Rule 45(e) and 45(g), relating to your duty to respond to this subpoena and the potential consequences of not doing so.\n\nDate: **March , 2023**\n\nCLERK OF COURT\n\nOR\n\n*Signature of Clerk or Deputy Clerk Attorney's signature*\n\nThe name, address, email address, and telephone number of the attorney representing Luc A. Despins, Chapter 11 Trustee, who issues or requests this subpoena, are:\n\n**Douglas S. Skalka, Esq.; Neubert, Pepe & Monteith, P.C.; 195 Church Street, New Haven, Connecticut 06510 dskalka@npmlaw.com; (203) 821-2000**\n\n**Notice to the person who issues or requests this subpoena**\n\nIf this subpoena commands the production of documents, electronically stored information, or tangible things, or the inspection of premises before trial, a notice and a copy of this subpoena must be served on each party before it is served on the person to whom it is directed. Fed. R. Civ. P. 45(a)(4).\n\nSoftware Copyright (c) 1996-2022 Best Case, LLC - www.bestcase.com Best Case Bankruptcy 1 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\n#### **PROOF OF SERVICE**\n\n**(This section should not be filed with the court unless required by Fed. R. Civ. P. 45.)**\n\nI received this subpoena for (*name of individual and title, if any*): on (*date*) .\n\nI served the subpoena by delivering a copy to the named person as follows:\n\non *(date)* ; or\n\nI returned the subpoena unexecuted because:\n\nUnless the subpoena was issued on behalf of the United States, or one of its officers or agents, I have also tendered to the witness the fees for one day's attendance, and the mileage allowed by law, in the amount of \\$ .\n\nMy fees are \\$ for travel and \\$ for services, for a total of \\$ .\n\nI declare under penalty of perjury that this information is true and correct.\n\nDate:\n\n*Server's signature*\n\n*Printed name and title*\n\n*Server's address*\n\nAdditional information concerning attempted service, etc.:\n\n#### **Federal Rule of Civil Procedure 45(c), (d), (e), and (g) (Effective 12/1/13) (made applicable in bankruptcy cases by Rule 9016, Federal Rules of Bankruptcy Procedure)**\n\n#### **(c) Place of compliance.**\n\n*(1) For a Trial, Hearing, or Deposition.* A subpoena may command a person to attend a trial, hearing, or deposition only as follows:\n\n(A) within 100 miles of where the person resides, is employed, or regularly transacts business in person; or\n\n(B) within the state where the person resides, is employed, or regularly transacts business in person, if the person\n\n(i) is a party or a party's officer; or\n\n(ii) is commanded to attend a trial and would not incur substantial expense.\n\n*(2) For Other Discovery.* A subpoena may command:\n\n(A) production of documents, or electronically stored information, or things at a place within 100 miles of where the person resides, is employed, or regularly transacts business in person; and\n\n(B) inspection of premises, at the premises to be inspected.\n\n#### **(d) Protecting a Person Subject to a Subpoena; Enforcement.**\n\n*(1) Avoiding Undue Burden or Expense; Sanctions.* A party or attorney responsible for issuing and serving a subpoena must take reasonable steps to avoid imposing undue burden or expense on a person subject to the subpoena. The court for the district where compliance is required must enforce this duty and impose an appropriate sanction which may include lost earnings and reasonable attorney's fees — on a party or attorney who fails to comply.\n\n#### *(2) Command to Produce Materials or Permit Inspection.*\n\n*(A) Appearance Not Required.* A person commanded to produce documents, electronically stored information, or tangible things, or to permit the inspection of premises, need not appear in person at the place of production or inspection unless also commanded to appear for a deposition, hearing, or trial.\n\n*(B) Objections.* A person commanded to produce documents or tangible things or to permit inspection may serve on the party or attorney designated in the subpoena a written objection to inspecting, copying, testing or sampling any or all of the materials or to inspecting the premises — or to producing electronically stored information in the form or forms requested. The objection must be served before the earlier of the time specified for compliance or 14 days after the subpoena is served. If an objection is made, the following rules apply:\n\n(i) At any time, on notice to the commanded person, the serving party may move the court for the district where compliance is required for an order compelling production or inspection.\n\n(ii) These acts may be required only as directed in the order, and the order must protect a person who is neither a party nor a party's officer from significant expense resulting from compliance.\n\n#### *(3) Quashing or Modifying a Subpoena.*\n\n*(A) When Required.* On timely motion, the court for the district where compliance is required must quash or modify a subpoena that:\n\n(i) fails to allow a reasonable time to comply;\n\n(ii) requires a person to comply beyond the geographical limits specified in Rule 45(c);\n\n(iii) requires disclosure of privileged or other protected matter, if no exception or waiver applies; or\n\n(iv) subjects a person to undue burden.\n\n*(B) When Permitted.* To protect a person subject to or affected by a subpoena, the court for the district where compliance is required may, on motion, quash or modify the subpoena if it requires:\n\n(i) disclosing a trade secret or other confidential research, development, or commercial information; or\n\n(ii) disclosing an unretained expert's opinion or information that does not describe specific occurrences in dispute and results from the expert's study that was not requested by a party.\n\n(C) *Specifying Conditions as an Alternative.* In the circumstances described in Rule 45(d)(3)(B), the court may, instead of quashing or modifying a subpoena, order appearance or production under specified conditions if the serving party:\n\n(i) shows a substantial need for the testimony or material that cannot be otherwise met without undue hardship; and\n\n(ii) ensures that the subpoenaed person will be reasonably compensated.\n\n#### **(e) Duties in Responding to a Subpoena.**\n\n*(1) Producing Documents or Electronically Stored Information.* These procedures apply to producing documents or electronically stored information:\n\n*(A) Documents.* A person responding to a subpoena to produce documents must produce them as they are kept in the ordinary course of business or must organize and label them to correspond to the categories in the demand.\n\n*(B) Form for Producing Electronically Stored Information Not Specified.* If a subpoena does not specify a form for producing electronically stored information, the person responding must produce it in a form or forms in which it is ordinarily maintained or in a reasonably usable form or forms.\n\n*(C) Electronically Stored Information Produced in Only One Form.* The person responding need not produce the same electronically stored information in more than one form.\n\n*(D) Inaccessible Electronically Stored Information.* The person responding need not provide discovery of electronically stored information from sources that the person identifies as not reasonably accessible because of undue burden or cost. On motion to compel discovery or for a protective order, the person responding must show that the information is not reasonably accessible because of undue burden or cost. If that showing is made, the court may nonetheless order discovery from such sources if the requesting party shows good cause, considering the limitations of Rule 26(b)(2)(C). The court may specify conditions for the discovery.\n\n#### *(2) Claiming Privilege or Protection.*\n\n*(A) Information Withheld.* A person withholding subpoenaed information under a claim that it is privileged or subject to protection as trial-preparation material must: (i) expressly make the claim; and\n\n(ii) describe the nature of the withheld documents, communications, or tangible things in a manner that, without revealing information itself privileged or protected, will enable the parties to assess the claim.\n\n*(B) Information Produced.* If information produced in response to a subpoena is subject to a claim of privilege or of protection as trial-preparation material, the person making the claim may notify any party that received the information of the claim and the basis for it. After being notified, a party must promptly return, sequester, or destroy the specified information and any copies it has; must not use or disclose the information until the claim is resolved; must take reasonable steps to retrieve the information if the party disclosed it before being notified; and may promptly present the information under seal to the court for the district where compliance is required for a determination of the claim. The person who produced the information must preserve the information until the claim is resolved.\n\n**(g) Contempt.** The court for the district where compliance is required – and also, after a motion is transferred, the issuing court – may hold in contempt a person who, having been served, fails without adequate excuse to obey the subpoena or an order related to it.\n\nFor access to subpoena materials, see Fed.R.Civ.P.45(a) Committee Note (2013)\n\n…\n\n## **Request for Production of Documents**\n\n## **I. INSTRUCTIONS**\n\n1. Unless otherwise indicated, the requests for documents set forth below, (the \"Requests,\" and each, a \"Request\"), must be responded to separately and specifically. Each Request shall be answered fully unless it is in good faith objected to, in which event the reason for Your objection shall be stated in detail, as set forth below. If an objection pertains only to a portion of a Request, or a word, phrase or clause contained within it, You are required to state Your objection to that portion only and to respond to the remainder of the Requests.\n\n2. Electronically stored information must be produced in accordance with the\n\nfollowing instructions:\n\n- a. Images. Black and white images must be 300 DPI Group IV single-page TIFF files. Color images must be produced in JPEG format. File names cannot contain embedded spaces or special characters (including the comma). Folder names cannot contain embedded spaces or special characters (including the comma). All TIFF image files must have a unique file name, i.e. Bates number. Images must be endorsed with sequential Bates numbers in the lower right corner of each image. The number of TIFF files per folder should not exceed 1000 files. Excel spreadsheets should have a placeholder image named by the Bates number of the file.\n- b. Image Load File\n\t- a. Concordance® Data File. The data file (.DAT) contains all of the fielded information that will be loaded into the Concordance® database. The first line of the .DAT file must be a header row identifying the field names. The .DAT file must use the following Concordance® default delimiters: Comma ASCII character (020) Quote þ ASCII character (254). Date fields should be provided in the format: mm/dd/yyyy. Date and time fields must be two separate fields. If documents includes imaged emails and attachments, the attachment fields must be included to preserve the parent/child relationship between an email and its attachments. An OCRPATH field must be included to provide the file path and name of the extracted text file on the produced storage media. The text file must be named after the FIRSTBATES. Do not include the text in the .DAT file. For Documents with native files, a LINK field must be included to provide the file path and\n\nname of the native file. The native file must be named after the FIRSTBATES.\n\n- b. Concordance Image® OR Opticon Cross-Reference File. The image crossreference file (.LOG or .OPT) links the images to the database records. It should be a comma-delimited file consisting of seven fields per line with a line in the cross-reference file for every image in the database with the following format: ImageID,VolumeLabel,ImageFilePath,DocumentBreak,FolderBreak,Box Break,PageCoun.\n- c. Document Text. Text must be produced as separate text files, not as fields within the .DAT file. The full path to the text file (OCRPATH) should be included in the .DAT file. It is recommended document level ANSI text files, named per the FIRSTBATES/Image Key. Extracted text files must be in a separate folder, and the number of text files per folder should not exceed 1,000 files. There should be no special characters (including commas in the folder names). Text files must be provided on a document level.\n- d. Native Production for Certain File Types. File types that reasonably require viewing in their native format for a full understanding of their content and meaning must be produced in native format. These include, but are not limited to, spreadsheets, spreadsheet-like files (Microsoft Excel, comma separated values, tab separated values, etc.), Microsoft PowerPoint or other special presentation files, database files, and audio/visual files. Provide an image of a Bates numbered slip sheet indicating the presence of a native file, and include the path to the native as a field in the .dat file. Name the produced native file with the Bates number corresponding to the slip sheet for the file. Group native files within incrementally named \"NATIVE\" directories, separate from images directories.\n- e. De-duplication. Produce a single copy of each electronic document for which exact duplicates exist. For email messages, consolidate duplicates based on MD5 hash generated from the BCC, Body, CC, From, IntMsgID, To, and Attach properties. For email attachments and standalone electronic files, consolidate duplicates based on MD5 hash of the entire file.\n- f. Metadata. Produce extracted metadata for each document in the form of a Concordance compliant load file (.dat). The first line of the .DAT file must be a header row identifying the field names. The .DAT file must use the following Concordance default delimiters: Comma , ASCII character (020) Quote þ ASCII character (254)\n\nDate fields should be provided in the format: mm/dd/yyyy. Date and time fields must be two separate fields. Required metadata listed below:\n\n# Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 611 of 1063\n\n| Field Name   | Sample Data              | Description                                                                                  |\n|--------------|--------------------------|----------------------------------------------------------------------------------------------|\n| FIRSTBATES   | EDC0000001               | First Bates number of native file document/email                                             |\n| LASTBATES    | EDC0000001               | Last Bates number of native file document/email<br>**The LASTBATES field should be populated |\n|              |                          | for single page                                                                              |\n| ATTACHRANGE  | EDC0000001<br>-          | Bates number of the first page of the parent                                                 |\n|              | EDC0000015               | document to the Bates number of the last page of                                             |\n|              |                          | the last attachment \"child\" document                                                         |\n| BEGATTACH    | EDC0000001               | First Bates number of attachment range                                                       |\n| ENDATTACH    | EDC0000015               | Last Bates number of attachment range                                                        |\n| CUSTODIAN    | Smith, John              | Email: Mailbox where the email resided                                                       |\n|              |                          | Native: Name of the individual or department                                                 |\n|              |                          | from whose files the document<br>originated                                                  |\n| FROM         | John Smith               | Email: Sender                                                                                |\n|              |                          | Native: Author(s) of document                                                                |\n|              |                          | **semi-colon should be used to separate                                                      |\n|              |                          | multiple entries                                                                             |\n| TO           | Coffman, Janice; LeeW    | Recipient(s)                                                                                 |\n|              | [mailto:LeeW@MSN.com]    | **semi-colon should be used to separate multiple                                             |\n|              |                          | entries                                                                                      |\n| CC           | Frank Thompson [mailto:  | Carbon copy recipient(s)                                                                     |\n|              | frank_Thompson@cdt.com]  | **semi-colon should be used to separate                                                      |\n|              |                          | multiple entries                                                                             |\n| BCC          | John Cain                | Blind carbon copy recipient(s)                                                               |\n|              |                          | **semi-colon should be used to separate                                                      |\n|              |                          | multiple entries                                                                             |\n| SUBJECT      | Board Meeting Minutes    | Email: Subject line of the email Native: Title                                               |\n|              |                          | of document (if available)                                                                   |\n| FILE_NAME    | BoardMeetingMinutes.docx | Native: Name of the original native file,                                                    |\n|              |                          | including extension                                                                          |\n| DATE_SENT    | 10/12/2010               | Email: Date the email was sent                                                               |\n|              |                          | Native: (empty)                                                                              |\n| TIME_SENT/   | 07:05 PM GMT             | Email: Time the email was sent/ Time zone in                                                 |\n| TIME_ZONE    |                          | which the emails were standardized                                                           |\n| TIME_ZONE    | GMT                      | The<br>time zone in which<br>the emails<br>were                                              |\n|              |                          | standardized during conversion.                                                              |\n| LINK         |  EDC0000001.msg   | Hyperlink to the email or native file document                                               |\n|              |                          | **The linked file must be named per the                                                      |\n|              |                          | FIRSTBATES number                                                                            |\n| FILE_EXTEN   | MSG                      | The file type extension                                                                      |\n|              |                          | representing                                                                                 |\n|              |                          | the Email or                                                                                 |\n| AUTHOR       | John Smith               | Email: (empty)                                                                               |\n|              |                          | Native: Author of the document                                                               |\n| DATE_CREATED | 10/10/2010               | Email: (empty)                                                                               |\n|              |                          | Native: Date the document was created                                                        |\n\n# Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 612 of 1063\n\n| TIME_CREATED | 10:25 AM                  | Email: (empty)                                  |\n|--------------|---------------------------|-------------------------------------------------|\n|              |                           | Native: Time the document was created           |\n|              |                           | **This data must be a separate field and cannot |\n|              |                           | be combined with the DATE_CREATED field         |\n| DATE_MOD     | 10/12/2010                | Email: (empty)                                  |\n|              |                           | Native: Date the document was last modified     |\n| TIME_MOD     | 07:00 PM                  | Email: (empty)                                  |\n|              |                           | Native: Time the document was last modified     |\n|              |                           | **This data must be a separate field and cannot |\n|              |                           | be combined with the DATE_MOD field             |\n| DATE_ACCESSD | 10/12/2010                | Email: (empty)                                  |\n|              |                           | Native: Date the document was last accessed     |\n| TIME_ACCESSD | 07:00 PM                  | Email: (empty)                                  |\n|              |                           | Native: Time the document was last accessed     |\n|              |                           | **This data must be a separate field and cannot |\n|              |                           | be combined with the DATE_ACCESSD field         |\n| FILE_SIZE    | 5,952                     | Size of native file<br>document/email in KB     |\n| PGCOUNT      | 1                         | Number of pages in native file document/email   |\n| PATH         |   | Email: (empty)                                  |\n|              | Agenda.doc                | Native: Path where native file document was     |\n|              |                           | stored including original file name.            |\n| INTFILEPATH  | Personal Folders\\Deleted  | Email: original location of email including     |\n|              | Items\\Board Meeting       | original file name.                             |\n|              | Minutes.msg               | Native: (empty)                                 |\n| INTMSGID     | <000805c2c71b\\$75977050\\$ | Email: Unique Message ID Native: (empty)        |\n|              | cb8306d1@MSN>             |                                                 |\n| MD5HASH      | d131dd02c5e6eec4693d9a0   | MD5 Hash value of the document.                 |\n|              | 698aff95c                 |                                                 |\n|              | 2fcab58712467eab4004583e  |                                                 |\n|              | b8fb7f89                  |                                                 |\n| OCRPATH      | TEXT/001/EDC0000001.txt   | Path to extracted text of the native file       |\n\n3. Each Request operates and should be construed independently and, unless otherwise indicated, no Request limits the scope of any other Request.\n\n4. All Documents are to be produced as kept in the usual course of business or are to be organized and labeled to correspond with the categories in these Requests.\n\n5. Each Request contained herein extends to all Documents: (a) in Your possession, custody, or control; or (b) in the possession, custody, or control of anyone acting on Your behalf,\n\n#### Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 613 of 1063\n\nincluding Your counsel or other representatives and advisors. Each Document shall be produced in its entirety.\n\n6. If You are requested to produce a Document that is no longer in Your possession, custody, or control, then Your response must (a) describe in detail the nature of the document and its contents; (b) identify the person(s) who prepared or authored the Document (and, if applicable, the Person(s) to whom the Document was sent); (c) identify the date on which the document was prepared or created; (d) state whether such Document (i) is missing or lost, (ii) has been destroyed, (iii) has been transferred, voluntarily or involuntarily, to others, or (iv) was otherwise disposed of; (e) state the reason for, and the facts and circumstances surrounding, such disposition; (f) identify the Persons who authorized such disposition; (g) identify the date or approximate date of such disposition; (h) state when the Document was most recently in Your possession, custody or control; and (i) identify the Person, if any, presently in possession, custody, or control of such Document.\n\n7. If You are requested to produce a Document that has been destroyed, then Your response must state, in addition to the information required by the preceding Instruction: (a) the reason for the Document's destruction; (b) the identity of the Person who destroyed the Document; and (c) the identity of the Person who directed that the Document be destroyed.\n\n8. If You claim that a requested Document is privileged or attorney work-product, then Your response must: (a) state (i) a description of the Document adequate to support Your contention that the Document is privileged, (ii) the title of the Document, (iii) the date of the Document, (iv) the author of the Document, (v) the addressee of the Document, (vi) the identity of each Person who received or saw the original or any draft, copy, or reproduction of the Document, (vii) whether the Document itself, or any information contained or referred to in the Document is in the possession, custody, or control of any other Persons, and if so, the identity of\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 614 of 1063\n\nsuch Persons, as well as a statement addressing how the information came into their possession, (viii) the claim of privilege under which the Document is withheld, and (ix) all of the circumstances upon which You will rely to support such claim of privilege; and (b) produce a privilege log containing all of the information requested in Part (a) of this Instruction for each Document withheld on the basis of a claim of privilege in accordance with D. Conn. L. Civ. R. 26(e). For any part of a Document Request as to which a claim of privilege or work product is not made, responsive documents should be provided in full.\n\n9. If a portion of an otherwise responsive Document contains information subject to a claim of privilege, only that portion of the Document subject to the claim of privilege shall be deleted or redacted from the Document following the instructions above, and the rest shall be produced.\n\n10. The Requests are continuing in nature. You are hereby instructed to (a) supplement or correct any responses later learned to be incomplete or incorrect immediately upon learning that a prior response was incomplete or incorrect; and (b) produce any additional Documents that are called for under the\n\n11. If a Document is in a language other than English, You should provide that Document. If a Document is in a language other than English, and an English translation exists, You should provide both Documents.\n\n12. All references to Entities includes all affiliates thereof.\n\n13. All references to individual names include all alternative names, aliased, or nicknames.\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 615 of 1063\n\n14. Unless otherwise expressly indicated, the period of time covered by the Document Requests is the period from February 5, 2012 to the date responses to the Document Requests are due.\n\n#### **II. RULES OF CONSTRUCTION**\n\n15. The use of (a) any singular noun shall be construed to include the plural, and vice versa, and (b) a verb in any tense shall be construed as the use of the verb in all other tenses.\n\n16. The terms (a) \"and\" and \"or\" shall be construed either conjunctively or disjunctively as necessary to bring within the scope of any request all responses that might otherwise be construed to be outside of its scope, and (b) \"each\" and \"any\" shall be deemed to include and encompass the words \"every\" and \"all.\"\n\n#### **III. DEFINITIONS**\n\nThe definitions supplied by D. Conn. L. Civ. R. 26(c) and the rules of construction supplied by D. Conn. L. Civ. R. 26(d), as incorporated by D. Conn. Bankr. L.R. 2004-1(a), shall apply to the Document Requests. In addition, the following terms used in these Document Requests shall have the following meanings:\n\n1. \"You\" or \"Your\" or \"Yourself\" means and refers, to Bank of China – New York Branch and/or Bank of China Limited.\n\n2. \"Debtor\" means Ho Wan Kwok (a/k/a Miles Kwok, Miles Guo, Guo Wengui, Guo Haoyun, 郭文贵, or any other alias), together with his employees, agents, counsel, advisors, or anyone acting on his behalf.\n\n#### Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 616 of 1063\n\n3. \"Debtor's Son\" means Qiang Guo (a/k/a Mileson Kwok, 郭强, or any other alias), together with his employees, agents, counsel, advisors, or anyone acting on his behalf.\n\n4. \"Debtor's Daughter\" means Mei Guo (a/k/a Mei Gui, 郭美, or any other alias), together with her employees, agents, counsel, advisors, or anyone acting on her behalf.\n\n5. \"Debtor's Purported Wife\" means Hing Chi Ngok (a/k/a Hing Chi Ng, Yue Qingzhi, 岳庆芝, or any other alias), together with her employees, agents, counsel, advisors, or anyone acting on her behalf.\n\n6. \"Debtor's Family\" means, individually and collectively, the Debtor, the Debtor's Son, the Debtor's Daughter, and the Debtor's Purported Wife, and any other familial relation to the Debtor.\n\n7. \"2004 Discovery Targets\" means, individually and collectively, the Debtor, the Debtor's Family, ACA Capital Group Limited, Himalaya International Financial Group Ltd., Himalaya International Clearing Ltd., Himalaya International Payments Ltd., Himalaya International Reserves Ltd., Jesse Brown, William Je, William Je, Eastern Profit Corporation Limited, HK International Funds Investments (USA) Limited LLC, Bravo Luck Limited, Golden Spring (New York) Ltd., Lamp Capital LLC, Greenwich Land LLC, Qu Guo Jiao, Daniel Thomas Podhaskie, Yvette Wang (a/k/a Yanping Wang, a/k/a Yan Ping Wang), Ace Decade Holdings Limited, Dawn State Limited, Rule of Law Society IV Inc., Rule of Law Foundation III, Inc., Rule of Law Foundation IV, Inc., Rule of Law Fund, Rule of Law Society, GTV Media Group, Inc., Voice of Guo Media, Inc., Saraca Media Group Inc., Genever Holdings Corporation, Genever Holdings LLC, Gnews Media Group Inc., G Fashion LLC, Gmusic LLC, Gnews LLC, Geducation, GFNY, Inc., G-Club Investments Limited, G Club Operations LLC, G Club US Operations Inc., G Club US Operations LLC, G Live, LLC, Gbroadcast, LLC, Gposts LLC, HCHK Property\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 617 of 1063\n\nManagement, Inc., HCHK Technologies, Inc., FMV Ltd./Freedom Media Venture Ltd., Roscalitar 2, Himalaya New World Inc., US Himalaya Capital Inc., Hudson Diamond Holding, Inc., Hudson Diamond Holding LLC, Hudson Diamond NY LLC, Infinity Treasury Management Inc., Lexington Property and Staffing, Inc., AI Group Holdings Inc., Hamilton Capital Holdings Inc., Booming Sail New York LLC, Himalaya Ventures LLC, Himalaya Ventures LLC, Himalaya Investment LLC, New York MOS Himalaya LLC, MOS Himalaya LLC, Crane Advisory Group, Maywind Trading LLC, Gettr USA, Inc., Han Chunguang, Bingshang Jiao, Karin Maistrello, Mary Jiang, Jiaming Liu, and Wencong Wang.\n\n8. \"Including\" or any variant thereof means \"including without limitation.\"\n\n9. \"And\" and \"or\" mean \"and/or,\" and shall be construed both conjunctively as well as disjunctively in order to maximize their scope.\n\n10. \"Any\" and \"all\" and \"each\" mean \"each and every.\"\n\n11. \"Each\" and \"every\" mean \"each and every.\"\n\n12. \"Third Party\" means a Person or Entity other than Yourself.\n\n13. \"Transfer\" shall have the meaning given to it by section 101(54) of the Bankruptcy Code.\n\n14. \"Document\" means any information or thing within the scope of Fed. R. Civ. P. 34, and includes, without limitation, each and every written, recorded, or graphic matter of any kind, type, nature, or description that is or has been in Your Possession, Custody or Control, including all printed and electronic copies of electronic mail, computer files maintained in electronic form, correspondence, memoranda, tapes, stenographic or handwritten notes, written forms of any kind, charts, blueprints, drawings, sketches, graphs, plans, articles, specifications, diaries, letters,\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 618 of 1063\n\ntelegrams, photographs, minutes, contracts, agreements, surveys, computer printouts, data compilations of any kind, telexes, facsimiles, emails, text messages, instant messages, voice messages, invoices, order forms, checks, drafts, statements, credit memos, reports, position reports, summaries, indices, books, ledgers, notebooks, schedules, transparencies, recordings, catalogs, advertisements, promotional materials, films, video tapes, audio tapes, CDs, computer disks, brochures, pamphlets, punch-cards, time-slips, Tweets, social media posts, or any written or recorded materials of any other kind, and all meta-data thereof, however stored (whether in tangible or electronic form), recorded, produced, or reproduced, and also including but not limited to, drafts or copies of any of the foregoing that contain any notes, comments, or markings of any kind not found on the original documents or that are otherwise not identical to the original documents.\n\n15. \"Person(s)\" means an individual, corporation, proprietorship, partnership, association, or any other Entity. \"Person\" also includes any agent, representatives, or expert, including but not limiting to, attorneys or financial advisors.\n\n16. \"Entity\" means any natural Person, corporation, partnership, subsidiary, sole proprietorship, firm, board, joint venture, association, agency, authority, commission or other business entity or juristic Person, as well as any affiliate, agent, parent including but not limited to counsel, financial advisors, or any other representative.\n\n17. \"Regarding\" means concerning, describing, comprising, referring to, related to, supporting, favoring, opposing, bolstering, detracting from, located in, considered in connection with, bearing on, evidencing, indicating, reporting on, recording, alluding to, responding to, connected with, commenting on, in respect of, about, in relation to, discussing, showing, describing, reflecting, analyzing constituting, and being.\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 619 of 1063\n\n18. \"Relating to,\" \"relate(s) to\" or \"related to,\" when referring to any given subject matter, means, without limitation, any document that constitutes, comprises, involves, contains, embodies, reflects, identifies, states, refers directly or indirectly to, or is in any way relevant to the particular subject matter identified.\n\n19. \"Communication(s)\" means, in the broadest possible sense, and without limitation, any transmittal of information or knowledge (in the form of facts, ideas, inquiries, or otherwise). Communication(s) further refers to all conversations, agreements, inquiries, or replies, whether in person, by telephone, in writing, or by means of electronic transmittal devices, and includes, but is not limited to, all correspondence, emails, recordings, transmittal slips, memoranda, telephone communications, voice messages, telegrams, telefaxes, telecopies, telexes, instant messages, chats, text messages, postings to a message board or group chat, social media posts, tweets, videos uploaded to any video platform, telephonic notes, or notes transmitted internally or with third parties.\n\n20. \"Asset(s)\" means any item of economic value that is subject to Possession, Custody, or Control. Asset includes all real and personal property, including but limited to, real estate, land, houses, apartments, condominiums, automobiles, yachts, boats, planes, jets, helicopters, cash, bank accounts, cryptocurrencies, securities, accounts receivables, inventory, and other tangible and intangible property.\n\n#### **IV. DOCUMENTS TO BE PRODUCED**\n\n1. All Documents related to any account held by, controlled by, on behalf of, or otherwise related to any of the 2004 Discovery Targets, including any and all account statements, authorizations, power of attorney, trusts, instructions or forms, copies of cancelled checks, correspondence, and wire transfers and related correspondence and instructions.\n\n#### Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 620 of 1063\n\n2. All Documents related to any funds, securities, property, or assets belonging to, held by, controlled by, on behalf of, or otherwise related to any of the 2004 Discovery Targets, including any and all account statements, authorizations, powers of attorney, trusts, instructions or forms, copies of cancelled checks, correspondence, and wire transfers and related correspondence and instructions.\n\n3. All Documents related to any business, commerce or financial transactions, including but not limited to any loan, line of credit, bailment, deposit, swap, securities transactions, mortgage, or ISDA, with any of the 2004 Discovery Targets, including any and all account statements, authorizations, powers of attorney, trusts, instructions or forms, copies of cancelled checks, correspondence, and wire transfers and related correspondence and instructions.\n\n4. All Documents relating to any wire transfer activity relating to the 2004 Discovery Targets, regardless of the existence of any accounts, including but not limited to all wire transfer receipts, account numbers, balances, authorizations, identification information related to the parties to the transfer, correspondence, instructions, or other records.\n\n5. All Documents related to any correspondence and communications between you and the 2004 Discovery Targets.\n\n6. All Documents related to any account with any 2004 Discovery Target relating to opening of the account, authorized users of the account and maintenance of the account.\n\n7. All Documents related to any anti-money laundering, know-your-customer, or other compliance activity relating to any of the 2004 Discovery Targets, including but not limited to any information provided by any of the 2004 Discovery Targets, or learned by You.\n\n8. All Documents relating to any communications with any regulator from any country, including but not limited to the Bank of England, the United States Federal Reserve, the\n\nS.E.C., the CFTC, FINRA, China Securities Regulatory Commission, People's Bank of China, Hong Kong Securities and Futures Commission, and the Hong Kong Monetary Authority relating to any of the 2004 Discovery Targets.\n\n# Exhibit C-34\n\n#### B2540 (Form 2540 – Subpoena for Rule 2004 Examination) (12/15) Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 623 of\n\nUNITED STATES BANKRUPTCY COURT 1063\n\n**District of Connecticut**\n\nIn re HO WAN KWOK, *et al*.,\n\n<sup>1</sup> Case No. 22-50073 (JAM)\n\nDebtor Chapter 11\n\n(Jointly Administered)\n\n## **SUBPOENA FOR RULE 2004 EXAMINATION**\n\nTo: U.S. Bank National Association\n\n(*Name of person to whom the subpoena is directed*)\n\n*Testimony:* **YOU ARE COMMANDED** to appear at the time, date, and place set forth below to testify at an examination under Rule 2004, Federal Rules of Bankruptcy Procedure. A copy of the court order authorizing the examination is attached.\n\n| PLACE                          | DATE AND TIME |\n|--------------------------------|---------------|\n| Neubert, Pepe & Monteith, P.C. |               |\n| 195 Church Street, Floor 13    | [TBD]         |\n| New Haven, Connecticut 06510   |               |\n|                                |               |\n\nThe examination will be recorded by this method: **Court reporter/stenographer**\n\n*Production:* You, or your representatives, must also bring with you to the examination the following documents, electronically stored information, or objects, and must permit inspection, copying, testing, or sampling of the material:\n\n#### **See Requests for Production of Documents, attached hereto.**\n\nThe following provisions of Fed. R. Civ. P. 45, made applicable in bankruptcy cases by Fed. R. Bankr. P. 9016, are attached – Rule 45(c), relating to the place of compliance; Rule 45(d), relating to your protection as a person subject to a subpoena; and Rule 45(e) and 45(g), relating to your duty to respond to this subpoena and the potential consequences of not doing so.\n\nDate: **March , 2023**\n\nCLERK OF COURT\n\nOR\n\n*Signature of Clerk or Deputy Clerk Attorney's signature*\n\nThe name, address, email address, and telephone number of the attorney representing Luc A. Despins, Chapter 11 Trustee, who issues or requests this subpoena, are:\n\n**Douglas S. Skalka, Esq.; Neubert, Pepe & Monteith, P.C.; 195 Church Street, New Haven, Connecticut 06510 dskalka@npmlaw.com; (203) 821-2000**\n\n**Notice to the person who issues or requests this subpoena**\n\nIf this subpoena commands the production of documents, electronically stored information, or tangible things, or the inspection of premises before trial, a notice and a copy of this subpoena must be served on each party before it is served on the person to whom it is directed. Fed. R. Civ. P. 45(a)(4).\n\nSoftware Copyright (c) 1996-2022 Best Case, LLC - www.bestcase.com Best Case Bankruptcy 1 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\n#### **PROOF OF SERVICE**\n\n**(This section should not be filed with the court unless required by Fed. R. Civ. P. 45.)**\n\nI received this subpoena for (*name of individual and title, if any*): on (*date*) .\n\nI served the subpoena by delivering a copy to the named person as follows:\n\non *(date)* ; or\n\nI returned the subpoena unexecuted because:\n\nUnless the subpoena was issued on behalf of the United States, or one of its officers or agents, I have also tendered to the witness the fees for one day's attendance, and the mileage allowed by law, in the amount of \\$ .\n\nMy fees are \\$ for travel and \\$ for services, for a total of \\$ .\n\nI declare under penalty of perjury that this information is true and correct.\n\nDate:\n\n*Server's signature*\n\n*Printed name and title*\n\n*Server's address*\n\nAdditional information concerning attempted service, etc.:\n\n#### **Federal Rule of Civil Procedure 45(c), (d), (e), and (g) (Effective 12/1/13) (made applicable in bankruptcy cases by Rule 9016, Federal Rules of Bankruptcy Procedure)**\n\n#### **(c) Place of compliance.**\n\n*(1) For a Trial, Hearing, or Deposition.* A subpoena may command a person to attend a trial, hearing, or deposition only as follows:\n\n(A) within 100 miles of where the person resides, is employed, or regularly transacts business in person; or\n\n(B) within the state where the person resides, is employed, or regularly transacts business in person, if the person\n\n(i) is a party or a party's officer; or\n\n(ii) is commanded to attend a trial and would not incur substantial expense.\n\n*(2) For Other Discovery.* A subpoena may command:\n\n(A) production of documents, or electronically stored information, or things at a place within 100 miles of where the person resides, is employed, or regularly transacts business in person; and\n\n(B) inspection of premises, at the premises to be inspected.\n\n#### **(d) Protecting a Person Subject to a Subpoena; Enforcement.**\n\n*(1) Avoiding Undue Burden or Expense; Sanctions.* A party or attorney responsible for issuing and serving a subpoena must take reasonable steps to avoid imposing undue burden or expense on a person subject to the subpoena. The court for the district where compliance is required must enforce this duty and impose an appropriate sanction which may include lost earnings and reasonable attorney's fees — on a party or attorney who fails to comply.\n\n#### *(2) Command to Produce Materials or Permit Inspection.*\n\n*(A) Appearance Not Required.* A person commanded to produce documents, electronically stored information, or tangible things, or to permit the inspection of premises, need not appear in person at the place of production or inspection unless also commanded to appear for a deposition, hearing, or trial.\n\n*(B) Objections.* A person commanded to produce documents or tangible things or to permit inspection may serve on the party or attorney designated in the subpoena a written objection to inspecting, copying, testing or sampling any or all of the materials or to inspecting the premises — or to producing electronically stored information in the form or forms requested. The objection must be served before the earlier of the time specified for compliance or 14 days after the subpoena is served. If an objection is made, the following rules apply:\n\n(i) At any time, on notice to the commanded person, the serving party may move the court for the district where compliance is required for an order compelling production or inspection.\n\n(ii) These acts may be required only as directed in the order, and the order must protect a person who is neither a party nor a party's officer from significant expense resulting from compliance.\n\n#### *(3) Quashing or Modifying a Subpoena.*\n\n*(A) When Required.* On timely motion, the court for the district where compliance is required must quash or modify a subpoena that:\n\n(i) fails to allow a reasonable time to comply;\n\n(ii) requires a person to comply beyond the geographical limits specified in Rule 45(c);\n\n(iii) requires disclosure of privileged or other protected matter, if no exception or waiver applies; or\n\n(iv) subjects a person to undue burden.\n\n*(B) When Permitted.* To protect a person subject to or affected by a subpoena, the court for the district where compliance is required may, on motion, quash or modify the subpoena if it requires:\n\n(i) disclosing a trade secret or other confidential research, development, or commercial information; or\n\n(ii) disclosing an unretained expert's opinion or information that does not describe specific occurrences in dispute and results from the expert's study that was not requested by a party.\n\n(C) *Specifying Conditions as an Alternative.* In the circumstances described in Rule 45(d)(3)(B), the court may, instead of quashing or modifying a subpoena, order appearance or production under specified conditions if the serving party:\n\n(i) shows a substantial need for the testimony or material that cannot be otherwise met without undue hardship; and\n\n(ii) ensures that the subpoenaed person will be reasonably compensated.\n\n#### **(e) Duties in Responding to a Subpoena.**\n\n*(1) Producing Documents or Electronically Stored Information.* These procedures apply to producing documents or electronically stored information:\n\n*(A) Documents.* A person responding to a subpoena to produce documents must produce them as they are kept in the ordinary course of business or must organize and label them to correspond to the categories in the demand.\n\n*(B) Form for Producing Electronically Stored Information Not Specified.* If a subpoena does not specify a form for producing electronically stored information, the person responding must produce it in a form or forms in which it is ordinarily maintained or in a reasonably usable form or forms.\n\n*(C) Electronically Stored Information Produced in Only One Form.* The person responding need not produce the same electronically stored information in more than one form.\n\n*(D) Inaccessible Electronically Stored Information.* The person responding need not provide discovery of electronically stored information from sources that the person identifies as not reasonably accessible because of undue burden or cost. On motion to compel discovery or for a protective order, the person responding must show that the information is not reasonably accessible because of undue burden or cost. If that showing is made, the court may nonetheless order discovery from such sources if the requesting party shows good cause, considering the limitations of Rule 26(b)(2)(C). The court may specify conditions for the discovery.\n\n#### *(2) Claiming Privilege or Protection.*\n\n*(A) Information Withheld.* A person withholding subpoenaed information under a claim that it is privileged or subject to protection as trial-preparation material must: (i) expressly make the claim; and\n\n(ii) describe the nature of the withheld documents, communications, or tangible things in a manner that, without revealing information itself privileged or protected, will enable the parties to assess the claim.\n\n*(B) Information Produced.* If information produced in response to a subpoena is subject to a claim of privilege or of protection as trial-preparation material, the person making the claim may notify any party that received the information of the claim and the basis for it. After being notified, a party must promptly return, sequester, or destroy the specified information and any copies it has; must not use or disclose the information until the claim is resolved; must take reasonable steps to retrieve the information if the party disclosed it before being notified; and may promptly present the information under seal to the court for the district where compliance is required for a determination of the claim. The person who produced the information must preserve the information until the claim is resolved.\n\n**(g) Contempt.** The court for the district where compliance is required – and also, after a motion is transferred, the issuing court – may hold in contempt a person who, having been served, fails without adequate excuse to obey the subpoena or an order related to it.\n\nFor access to subpoena materials, see Fed.R.Civ.P.45(a) Committee Note (2013)\n\n…\n\n## **Request for Production of Documents**\n\n## **I. INSTRUCTIONS**\n\n1. Unless otherwise indicated, the requests for documents set forth below, (the \"Requests,\" and each, a \"Request\"), must be responded to separately and specifically. Each Request shall be answered fully unless it is in good faith objected to, in which event the reason for Your objection shall be stated in detail, as set forth below. If an objection pertains only to a portion of a Request, or a word, phrase or clause contained within it, You are required to state Your objection to that portion only and to respond to the remainder of the Requests.\n\n2. Electronically stored information must be produced in accordance with the\n\nfollowing instructions:\n\n- a. Images. Black and white images must be 300 DPI Group IV single-page TIFF files. Color images must be produced in JPEG format. File names cannot contain embedded spaces or special characters (including the comma). Folder names cannot contain embedded spaces or special characters (including the comma). All TIFF image files must have a unique file name, i.e. Bates number. Images must be endorsed with sequential Bates numbers in the lower right corner of each image. The number of TIFF files per folder should not exceed 1000 files. Excel spreadsheets should have a placeholder image named by the Bates number of the file.\n- b. Image Load File\n\t- a. Concordance® Data File. The data file (.DAT) contains all of the fielded information that will be loaded into the Concordance® database. The first line of the .DAT file must be a header row identifying the field names. The .DAT file must use the following Concordance® default delimiters: Comma ASCII character (020) Quote þ ASCII character (254). Date fields should be provided in the format: mm/dd/yyyy. Date and time fields must be two separate fields. If documents includes imaged emails and attachments, the attachment fields must be included to preserve the parent/child relationship between an email and its attachments. An OCRPATH field must be included to provide the file path and name of the extracted text file on the produced storage media. The text file must be named after the FIRSTBATES. Do not include the text in the .DAT file. For Documents with native files, a LINK field must be included to provide the file path and\n\nname of the native file. The native file must be named after the FIRSTBATES.\n\n- b. Concordance Image® OR Opticon Cross-Reference File. The image crossreference file (.LOG or .OPT) links the images to the database records. It should be a comma-delimited file consisting of seven fields per line with a line in the cross-reference file for every image in the database with the following format: ImageID,VolumeLabel,ImageFilePath,DocumentBreak,FolderBreak,Box Break,PageCoun.\n- c. Document Text. Text must be produced as separate text files, not as fields within the .DAT file. The full path to the text file (OCRPATH) should be included in the .DAT file. It is recommended document level ANSI text files, named per the FIRSTBATES/Image Key. Extracted text files must be in a separate folder, and the number of text files per folder should not exceed 1,000 files. There should be no special characters (including commas in the folder names). Text files must be provided on a document level.\n- d. Native Production for Certain File Types. File types that reasonably require viewing in their native format for a full understanding of their content and meaning must be produced in native format. These include, but are not limited to, spreadsheets, spreadsheet-like files (Microsoft Excel, comma separated values, tab separated values, etc.), Microsoft PowerPoint or other special presentation files, database files, and audio/visual files. Provide an image of a Bates numbered slip sheet indicating the presence of a native file, and include the path to the native as a field in the .dat file. Name the produced native file with the Bates number corresponding to the slip sheet for the file. Group native files within incrementally named \"NATIVE\" directories, separate from images directories.\n- e. De-duplication. Produce a single copy of each electronic document for which exact duplicates exist. For email messages, consolidate duplicates based on MD5 hash generated from the BCC, Body, CC, From, IntMsgID, To, and Attach properties. For email attachments and standalone electronic files, consolidate duplicates based on MD5 hash of the entire file.\n- f. Metadata. Produce extracted metadata for each document in the form of a Concordance compliant load file (.dat). The first line of the .DAT file must be a header row identifying the field names. The .DAT file must use the following Concordance default delimiters: Comma , ASCII character (020) Quote þ ASCII character (254)\n\nDate fields should be provided in the format: mm/dd/yyyy. Date and time fields must be two separate fields. Required metadata listed below:\n\n# Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 628 of 1063\n\n| Field Name   | Sample Data              | Description                                                                                  |\n|--------------|--------------------------|----------------------------------------------------------------------------------------------|\n| FIRSTBATES   | EDC0000001               | First Bates number of native file document/email                                             |\n| LASTBATES    | EDC0000001               | Last Bates number of native file document/email<br>**The LASTBATES field should be populated |\n|              |                          | for single page                                                                              |\n| ATTACHRANGE  | EDC0000001<br>-          | Bates number of the first page of the parent                                                 |\n|              | EDC0000015               | document to the Bates number of the last page of                                             |\n|              |                          | the last attachment \"child\" document                                                         |\n| BEGATTACH    | EDC0000001               | First Bates number of attachment range                                                       |\n| ENDATTACH    | EDC0000015               | Last Bates number of attachment range                                                        |\n| CUSTODIAN    | Smith, John              | Email: Mailbox where the email resided                                                       |\n|              |                          | Native: Name of the individual or department                                                 |\n|              |                          | from whose files the document<br>originated                                                  |\n| FROM         | John Smith               | Email: Sender                                                                                |\n|              |                          | Native: Author(s) of document                                                                |\n|              |                          | **semi-colon should be used to separate                                                      |\n|              |                          | multiple entries                                                                             |\n| TO           | Coffman, Janice; LeeW    | Recipient(s)                                                                                 |\n|              | [mailto:LeeW@MSN.com]    | **semi-colon should be used to separate multiple                                             |\n|              |                          | entries                                                                                      |\n| CC           | Frank Thompson [mailto:  | Carbon copy recipient(s)                                                                     |\n|              | frank_Thompson@cdt.com]  | **semi-colon should be used to separate                                                      |\n|              |                          | multiple entries                                                                             |\n| BCC          | John Cain                | Blind carbon copy recipient(s)                                                               |\n|              |                          | **semi-colon should be used to separate                                                      |\n|              |                          | multiple entries                                                                             |\n| SUBJECT      | Board Meeting Minutes    | Email: Subject line of the email Native: Title                                               |\n|              |                          | of document (if available)                                                                   |\n| FILE_NAME    | BoardMeetingMinutes.docx | Native: Name of the original native file,                                                    |\n|              |                          | including extension                                                                          |\n| DATE_SENT    | 10/12/2010               | Email: Date the email was sent                                                               |\n|              |                          | Native: (empty)                                                                              |\n| TIME_SENT/   | 07:05 PM GMT             | Email: Time the email was sent/ Time zone in                                                 |\n| TIME_ZONE    |                          | which the emails were standardized                                                           |\n| TIME_ZONE    | GMT                      | The<br>time zone in which<br>the emails<br>were                                              |\n|              |                          | standardized during conversion.                                                              |\n| LINK         |  EDC0000001.msg   | Hyperlink to the email or native file document                                               |\n|              |                          | **The linked file must be named per the                                                      |\n|              |                          | FIRSTBATES number                                                                            |\n| FILE_EXTEN   | MSG                      | The file type extension                                                                      |\n|              |                          | representing                                                                                 |\n|              |                          | the Email or                                                                                 |\n| AUTHOR       | John Smith               | Email: (empty)                                                                               |\n|              |                          | Native: Author of the document                                                               |\n| DATE_CREATED | 10/10/2010               | Email: (empty)                                                                               |\n|              |                          | Native: Date the document was created                                                        |\n\n# Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 629 of 1063\n\n| TIME_CREATED | 10:25 AM                  | Email: (empty)                                  |\n|--------------|---------------------------|-------------------------------------------------|\n|              |                           | Native: Time the document was created           |\n|              |                           | **This data must be a separate field and cannot |\n|              |                           | be combined with the DATE_CREATED field         |\n| DATE_MOD     | 10/12/2010                | Email: (empty)                                  |\n|              |                           | Native: Date the document was last modified     |\n| TIME_MOD     | 07:00 PM                  | Email: (empty)                                  |\n|              |                           | Native: Time the document was last modified     |\n|              |                           | **This data must be a separate field and cannot |\n|              |                           | be combined with the DATE_MOD field             |\n| DATE_ACCESSD | 10/12/2010                | Email: (empty)                                  |\n|              |                           | Native: Date the document was last accessed     |\n| TIME_ACCESSD | 07:00 PM                  | Email: (empty)                                  |\n|              |                           | Native: Time the document was last accessed     |\n|              |                           | **This data must be a separate field and cannot |\n|              |                           | be combined with the DATE_ACCESSD field         |\n| FILE_SIZE    | 5,952                     | Size of native file<br>document/email in KB     |\n| PGCOUNT      | 1                         | Number of pages in native file document/email   |\n| PATH         |   | Email: (empty)                                  |\n|              | Agenda.doc                | Native: Path where native file document was     |\n|              |                           | stored including original file name.            |\n| INTFILEPATH  | Personal Folders\\Deleted  | Email: original location of email including     |\n|              | Items\\Board Meeting       | original file name.                             |\n|              | Minutes.msg               | Native: (empty)                                 |\n| INTMSGID     | <000805c2c71b\\$75977050\\$ | Email: Unique Message ID Native: (empty)        |\n|              | cb8306d1@MSN>             |                                                 |\n| MD5HASH      | d131dd02c5e6eec4693d9a0   | MD5 Hash value of the document.                 |\n|              | 698aff95c                 |                                                 |\n|              | 2fcab58712467eab4004583e  |                                                 |\n|              | b8fb7f89                  |                                                 |\n| OCRPATH      | TEXT/001/EDC0000001.txt   | Path to extracted text of the native file       |\n\n3. Each Request operates and should be construed independently and, unless otherwise indicated, no Request limits the scope of any other Request.\n\n4. All Documents are to be produced as kept in the usual course of business or are to be organized and labeled to correspond with the categories in these Requests.\n\n5. Each Request contained herein extends to all Documents: (a) in Your possession, custody, or control; or (b) in the possession, custody, or control of anyone acting on Your behalf,\n\n#### Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 630 of 1063\n\nincluding Your counsel or other representatives and advisors. Each Document shall be produced in its entirety.\n\n6. If You are requested to produce a Document that is no longer in Your possession, custody, or control, then Your response must (a) describe in detail the nature of the document and its contents; (b) identify the person(s) who prepared or authored the Document (and, if applicable, the Person(s) to whom the Document was sent); (c) identify the date on which the document was prepared or created; (d) state whether such Document (i) is missing or lost, (ii) has been destroyed, (iii) has been transferred, voluntarily or involuntarily, to others, or (iv) was otherwise disposed of; (e) state the reason for, and the facts and circumstances surrounding, such disposition; (f) identify the Persons who authorized such disposition; (g) identify the date or approximate date of such disposition; (h) state when the Document was most recently in Your possession, custody or control; and (i) identify the Person, if any, presently in possession, custody, or control of such Document.\n\n7. If You are requested to produce a Document that has been destroyed, then Your response must state, in addition to the information required by the preceding Instruction: (a) the reason for the Document's destruction; (b) the identity of the Person who destroyed the Document; and (c) the identity of the Person who directed that the Document be destroyed.\n\n8. If You claim that a requested Document is privileged or attorney work-product, then Your response must: (a) state (i) a description of the Document adequate to support Your contention that the Document is privileged, (ii) the title of the Document, (iii) the date of the Document, (iv) the author of the Document, (v) the addressee of the Document, (vi) the identity of each Person who received or saw the original or any draft, copy, or reproduction of the Document, (vii) whether the Document itself, or any information contained or referred to in the Document is in the possession, custody, or control of any other Persons, and if so, the identity of\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 631 of 1063\n\nsuch Persons, as well as a statement addressing how the information came into their possession, (viii) the claim of privilege under which the Document is withheld, and (ix) all of the circumstances upon which You will rely to support such claim of privilege; and (b) produce a privilege log containing all of the information requested in Part (a) of this Instruction for each Document withheld on the basis of a claim of privilege in accordance with D. Conn. L. Civ. R. 26(e). For any part of a Document Request as to which a claim of privilege or work product is not made, responsive documents should be provided in full.\n\n9. If a portion of an otherwise responsive Document contains information subject to a claim of privilege, only that portion of the Document subject to the claim of privilege shall be deleted or redacted from the Document following the instructions above, and the rest shall be produced.\n\n10. The Requests are continuing in nature. You are hereby instructed to (a) supplement or correct any responses later learned to be incomplete or incorrect immediately upon learning that a prior response was incomplete or incorrect; and (b) produce any additional Documents that are called for under the\n\n11. If a Document is in a language other than English, You should provide that Document. If a Document is in a language other than English, and an English translation exists, You should provide both Documents.\n\n12. All references to Entities includes all affiliates thereof.\n\n13. All references to individual names include all alternative names, aliased, or nicknames.\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 632 of 1063\n\n14. Unless otherwise expressly indicated, the period of time covered by the Document Requests is the period from February 5, 2012 to the date responses to the Document Requests are due.\n\n#### **II. RULES OF CONSTRUCTION**\n\n15. The use of (a) any singular noun shall be construed to include the plural, and vice versa, and (b) a verb in any tense shall be construed as the use of the verb in all other tenses.\n\n16. The terms (a) \"and\" and \"or\" shall be construed either conjunctively or disjunctively as necessary to bring within the scope of any request all responses that might otherwise be construed to be outside of its scope, and (b) \"each\" and \"any\" shall be deemed to include and encompass the words \"every\" and \"all.\"\n\n#### **III. DEFINITIONS**\n\nThe definitions supplied by D. Conn. L. Civ. R. 26(c) and the rules of construction supplied by D. Conn. L. Civ. R. 26(d), as incorporated by D. Conn. Bankr. L.R. 2004-1(a), shall apply to the Document Requests. In addition, the following terms used in these Document Requests shall have the following meanings:\n\n1. \"You\" or \"Your\" or \"Yourself\" means and refers, to U.S. Bank National Association\n\n2. \"Debtor\" means Ho Wan Kwok (a/k/a Miles Kwok, Miles Guo, Guo Wengui, Guo Haoyun, 郭文贵, or any other alias), together with his employees, agents, counsel, advisors, or anyone acting on his behalf.\n\n#### Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 633 of 1063\n\n3. \"Debtor's Son\" means Qiang Guo (a/k/a Mileson Kwok, 郭强, or any other alias), together with his employees, agents, counsel, advisors, or anyone acting on his behalf.\n\n4. \"Debtor's Daughter\" means Mei Guo (a/k/a Mei Gui, 郭美, or any other alias), together with her employees, agents, counsel, advisors, or anyone acting on her behalf.\n\n5. \"Debtor's Purported Wife\" means Hing Chi Ngok (a/k/a Hing Chi Ng, Yue Qingzhi, 岳庆芝, or any other alias), together with her employees, agents, counsel, advisors, or anyone acting on her behalf.\n\n6. \"Debtor's Family\" means, individually and collectively, the Debtor, the Debtor's Son, the Debtor's Daughter, and the Debtor's Purported Wife, and any other familial relation to the Debtor.\n\n7. \"2004 Discovery Targets\" means, individually and collectively, the Debtor, the Debtor's Family, ACA Capital Group Limited, Himalaya International Financial Group Ltd., Himalaya International Clearing Ltd., Himalaya International Payments Ltd., Himalaya International Reserves Ltd., Jesse Brown, William Je, William Je, Eastern Profit Corporation Limited, HK International Funds Investments (USA) Limited LLC, Bravo Luck Limited, Golden Spring (New York) Ltd., Lamp Capital LLC, Greenwich Land LLC, Qu Guo Jiao, Daniel Thomas Podhaskie, Yvette Wang (a/k/a Yanping Wang, a/k/a Yan Ping Wang), Ace Decade Holdings Limited, Dawn State Limited, Rule of Law Society IV Inc., Rule of Law Foundation III, Inc., Rule of Law Foundation IV, Inc., Rule of Law Fund, Rule of Law Society, GTV Media Group, Inc., Voice of Guo Media, Inc., Saraca Media Group Inc., Genever Holdings Corporation, Genever Holdings LLC, Gnews Media Group Inc., G Fashion LLC, Gmusic LLC, Gnews LLC, Geducation, GFNY, Inc., G-Club Investments Limited, G Club Operations LLC, G Club US Operations Inc., G Club US Operations LLC, G Live, LLC, Gbroadcast, LLC, Gposts LLC, HCHK Property\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 634 of 1063\n\nManagement, Inc., HCHK Technologies, Inc., FMV Ltd./Freedom Media Venture Ltd., Roscalitar 2, Himalaya New World Inc., US Himalaya Capital Inc., Hudson Diamond Holding, Inc., Hudson Diamond Holding LLC, Hudson Diamond NY LLC, Infinity Treasury Management Inc., Lexington Property and Staffing, Inc., AI Group Holdings Inc., Hamilton Capital Holdings Inc., Booming Sail New York LLC, Himalaya Ventures LLC, Himalaya Ventures LLC, Himalaya Investment LLC, New York MOS Himalaya LLC, MOS Himalaya LLC, Crane Advisory Group, Maywind Trading LLC, Gettr USA, Inc., Han Chunguang, Bingshang Jiao, Karin Maistrello, Mary Jiang, Jiaming Liu, and Wencong Wang.\n\n8. \"Including\" or any variant thereof means \"including without limitation.\"\n\n9. \"And\" and \"or\" mean \"and/or,\" and shall be construed both conjunctively as well as disjunctively in order to maximize their scope.\n\n10. \"Any\" and \"all\" and \"each\" mean \"each and every.\"\n\n11. \"Each\" and \"every\" mean \"each and every.\"\n\n12. \"Third Party\" means a Person or Entity other than Yourself.\n\n13. \"Transfer\" shall have the meaning given to it by section 101(54) of the Bankruptcy Code.\n\n14. \"Document\" means any information or thing within the scope of Fed. R. Civ. P. 34, and includes, without limitation, each and every written, recorded, or graphic matter of any kind, type, nature, or description that is or has been in Your Possession, Custody or Control, including all printed and electronic copies of electronic mail, computer files maintained in electronic form, correspondence, memoranda, tapes, stenographic or handwritten notes, written forms of any kind, charts, blueprints, drawings, sketches, graphs, plans, articles, specifications, diaries, letters,\n\n### Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 635 of 1063\n\ntelegrams, photographs, minutes, contracts, agreements, surveys, computer printouts, data compilations of any kind, telexes, facsimiles, emails, text messages, instant messages, voice messages, invoices, order forms, checks, drafts, statements, credit memos, reports, position reports, summaries, indices, books, ledgers, notebooks, schedules, transparencies, recordings, catalogs, advertisements, promotional materials, films, video tapes, audio tapes, CDs, computer disks, brochures, pamphlets, punch-cards, time-slips, Tweets, social media posts, or any written or recorded materials of any other kind, and all meta-data thereof, however stored (whether in tangible or electronic form), recorded, produced, or reproduced, and also including but not limited to, drafts or copies of any of the foregoing that contain any notes, comments, or markings of any kind not found on the original documents or that are otherwise not identical to the original documents.\n\n15. \"Person(s)\" means an individual, corporation, proprietorship, partnership, association, or any other Entity. \"Person\" also includes any agent, representatives, or expert, including but not limiting to, attorneys or financial advisors.\n\n16. \"Entity\" means any natural Person, corporation, partnership, subsidiary, sole proprietorship, firm, board, joint venture, association, agency, authority, commission or other business entity or juristic Person, as well as any affiliate, agent, parent including but not limited to counsel, financial advisors, or any other representative.\n\n17. \"Regarding\" means concerning, describing, comprising, referring to, related to, supporting, favoring, opposing, bolstering, detracting from, located in, considered in connection with, bearing on, evidencing, indicating, reporting on, recording, alluding to, responding to, connected with, commenting on, in respect of, about, in relation to, discussing, showing, describing, reflecting, analyzing constituting, and being.\n\n### Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 636 of 1063\n\n18. \"Relating to,\" \"relate(s) to\" or \"related to,\" when referring to any given subject matter, means, without limitation, any document that constitutes, comprises, involves, contains, embodies, reflects, identifies, states, refers directly or indirectly to, or is in any way relevant to the particular subject matter identified.\n\n19. \"Communication(s)\" means, in the broadest possible sense, and without limitation, any transmittal of information or knowledge (in the form of facts, ideas, inquiries, or otherwise). Communication(s) further refers to all conversations, agreements, inquiries, or replies, whether in person, by telephone, in writing, or by means of electronic transmittal devices, and includes, but is not limited to, all correspondence, emails, recordings, transmittal slips, memoranda, telephone communications, voice messages, telegrams, telefaxes, telecopies, telexes, instant messages, chats, text messages, postings to a message board or group chat, social media posts, tweets, videos uploaded to any video platform, telephonic notes, or notes transmitted internally or with third parties.\n\n20. \"Asset(s)\" means any item of economic value that is subject to Possession, Custody, or Control. Asset includes all real and personal property, including but limited to, real estate, land, houses, apartments, condominiums, automobiles, yachts, boats, planes, jets, helicopters, cash, bank accounts, cryptocurrencies, securities, accounts receivables, inventory, and other tangible and intangible property.\n\n#### **IV. DOCUMENTS TO BE PRODUCED**\n\n1. All Documents related to any account held by, controlled by, on behalf of, or otherwise related to any of the 2004 Discovery Targets, including any and all account statements, authorizations, power of attorney, trusts, instructions or forms, copies of cancelled checks, correspondence, and wire transfers and related correspondence and instructions.\n\n#### Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 637 of 1063\n\n2. All Documents related to any funds, securities, property, or assets belonging to, held by, controlled by, on behalf of, or otherwise related to any of the 2004 Discovery Targets, including any and all account statements, authorizations, powers of attorney, trusts, instructions or forms, copies of cancelled checks, correspondence, and wire transfers and related correspondence and instructions.\n\n3. All Documents related to any business, commerce or financial transactions, including but not limited to any loan, line of credit, bailment, deposit, swap, securities transactions, mortgage, or ISDA, with any of the 2004 Discovery Targets, including any and all account statements, authorizations, powers of attorney, trusts, instructions or forms, copies of cancelled checks, correspondence, and wire transfers and related correspondence and instructions.\n\n4. All Documents relating to any wire transfer activity relating to the 2004 Discovery Targets, regardless of the existence of any accounts, including but not limited to all wire transfer receipts, account numbers, balances, authorizations, identification information related to the parties to the transfer, correspondence, instructions, or other records.\n\n5. All Documents related to any correspondence and communications between you and the 2004 Discovery Targets.\n\n6. All Documents related to any account with any 2004 Discovery Target relating to opening of the account, authorized users of the account and maintenance of the account.\n\n7. All Documents related to any anti-money laundering, know-your-customer, or other compliance activity relating to any of the 2004 Discovery Targets, including but not limited to any information provided by any of the 2004 Discovery Targets, or learned by You.\n\n8. All Documents relating to any communications with any regulator from any country, including but not limited to the Bank of England, the United States Federal Reserve, the\n\nS.E.C., the CFTC, FINRA, China Securities Regulatory Commission, People's Bank of China, Hong Kong Securities and Futures Commission, and the Hong Kong Monetary Authority relating to any of the 2004 Discovery Targets.\n\n# Exhibit C-35\n\n#### B2540 (Form 2540 – Subpoena for Rule 2004 Examination) (12/15) Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 640 of\n\n1063\n\nUNITED STATES BANKRUPTCY COURT\n\n**District of Connecticut**\n\nIn re HO WAN KWOK, *et al*.,\n\n<sup>1</sup> Case No. 22-50073 (JAM) Debtor Chapter 11\n\n(Jointly Administered)\n\n# **SUBPOENA FOR RULE 2004 EXAMINATION**\n\nTo: **Macaron Limited**\n\n(*Name of person to whom the subpoena is directed*)\n\n*Testimony:* **YOU ARE COMMANDED** to appear at the time, date, and place set forth below to testify at an examination under Rule 2004, Federal Rules of Bankruptcy Procedure. A copy of the court order authorizing the examination is attached.\n\n| PLACE                    | DATE AND TIME |\n|--------------------------|---------------|\n| Paul Hastings LLP        |               |\n| 200 Park Avenue          | [TBD]         |\n| New York, New York 10166 |               |\n|                          |               |\n\nThe examination will be recorded by this method: **Court reporter/stenographer**\n\n*Production:* You, or your representatives, must also bring with you to the examination the following documents, electronically stored information, or objects, and must permit inspection, copying, testing, or sampling of the material:\n\n#### **See Requests for Production of Documents, attached hereto.**\n\nThe following provisions of Fed. R. Civ. P. 45, made applicable in bankruptcy cases by Fed. R. Bankr. P. 9016, are attached – Rule 45(c), relating to the place of compliance; Rule 45(d), relating to your protection as a person subject to a subpoena; and Rule 45(e) and 45(g), relating to your duty to respond to this subpoena and the potential consequences of not doing so.\n\nDate: **March , 2023**\n\nCLERK OF COURT\n\nOR\n\n*Signature of Clerk or Deputy Clerk Attorney's signature*\n\nThe name, address, email address, and telephone number of the attorney representing Luc A. Despins, Chapter 11 Trustee, who issues or requests this subpoena, are:\n\n**Douglas S. Skalka, Esq.; Neubert, Pepe & Monteith, P.C.; 195 Church Street, New Haven, Connecticut 06510 dskalka@npmlaw.com; (203) 821-2000**\n\n**Notice to the person who issues or requests this subpoena**\n\nIf this subpoena commands the production of documents, electronically stored information, or tangible things, or the inspection of premises before trial, a notice and a copy of this subpoena must be served on each party before it is served on the person to whom it is directed. Fed. R. Civ. P. 45(a)(4).\n\nSoftware Copyright (c) 1996-2022 Best Case, LLC - www.bestcase.com Best Case Bankruptcy 1 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\n#### **PROOF OF SERVICE**\n\n**(This section should not be filed with the court unless required by Fed. R. Civ. P. 45.)**\n\nI received this subpoena for (*name of individual and title, if any*): on (*date*) .\n\nI served the subpoena by delivering a copy to the named person as follows:\n\non *(date)* ; or\n\nI returned the subpoena unexecuted because:\n\nUnless the subpoena was issued on behalf of the United States, or one of its officers or agents, I have also tendered to the witness the fees for one day's attendance, and the mileage allowed by law, in the amount of \\$ .\n\nMy fees are \\$ for travel and \\$ for services, for a total of \\$ .\n\nI declare under penalty of perjury that this information is true and correct.\n\nDate:\n\n*Server's signature*\n\n*Printed name and title*\n\n*Server's address*\n\nAdditional information concerning attempted service, etc.:\n\n#### **Federal Rule of Civil Procedure 45(c), (d), (e), and (g) (Effective 12/1/13) (made applicable in bankruptcy cases by Rule 9016, Federal Rules of Bankruptcy Procedure)**\n\n#### **(c) Place of compliance.**\n\n*(1) For a Trial, Hearing, or Deposition.* A subpoena may command a person to attend a trial, hearing, or deposition only as follows:\n\n(A) within 100 miles of where the person resides, is employed, or regularly transacts business in person; or\n\n(B) within the state where the person resides, is employed, or regularly transacts business in person, if the person\n\n(i) is a party or a party's officer; or\n\n(ii) is commanded to attend a trial and would not incur substantial expense.\n\n*(2) For Other Discovery.* A subpoena may command:\n\n(A) production of documents, or electronically stored information, or things at a place within 100 miles of where the person resides, is employed, or regularly transacts business in person; and\n\n(B) inspection of premises, at the premises to be inspected.\n\n#### **(d) Protecting a Person Subject to a Subpoena; Enforcement.**\n\n*(1) Avoiding Undue Burden or Expense; Sanctions.* A party or attorney responsible for issuing and serving a subpoena must take reasonable steps to avoid imposing undue burden or expense on a person subject to the subpoena. The court for the district where compliance is required must enforce this duty and impose an appropriate sanction which may include lost earnings and reasonable attorney's fees — on a party or attorney who fails to comply.\n\n#### *(2) Command to Produce Materials or Permit Inspection.*\n\n*(A) Appearance Not Required.* A person commanded to produce documents, electronically stored information, or tangible things, or to permit the inspection of premises, need not appear in person at the place of production or inspection unless also commanded to appear for a deposition, hearing, or trial.\n\n*(B) Objections.* A person commanded to produce documents or tangible things or to permit inspection may serve on the party or attorney designated in the subpoena a written objection to inspecting, copying, testing or sampling any or all of the materials or to inspecting the premises — or to producing electronically stored information in the form or forms requested. The objection must be served before the earlier of the time specified for compliance or 14 days after the subpoena is served. If an objection is made, the following rules apply:\n\n(i) At any time, on notice to the commanded person, the serving party may move the court for the district where compliance is required for an order compelling production or inspection.\n\n(ii) These acts may be required only as directed in the order, and the order must protect a person who is neither a party nor a party's officer from significant expense resulting from compliance.\n\n#### *(3) Quashing or Modifying a Subpoena.*\n\n*(A) When Required.* On timely motion, the court for the district where compliance is required must quash or modify a subpoena that:\n\n(i) fails to allow a reasonable time to comply;\n\n(ii) requires a person to comply beyond the geographical limits specified in Rule 45(c);\n\n(iii) requires disclosure of privileged or other protected matter, if no exception or waiver applies; or\n\n(iv) subjects a person to undue burden.\n\n*(B) When Permitted.* To protect a person subject to or affected by a subpoena, the court for the district where compliance is required may, on motion, quash or modify the subpoena if it requires:\n\n(i) disclosing a trade secret or other confidential research, development, or commercial information; or\n\n(ii) disclosing an unretained expert's opinion or information that does not describe specific occurrences in dispute and results from the expert's study that was not requested by a party.\n\n(C) *Specifying Conditions as an Alternative.* In the circumstances described in Rule 45(d)(3)(B), the court may, instead of quashing or modifying a subpoena, order appearance or production under specified conditions if the serving party:\n\n(i) shows a substantial need for the testimony or material that cannot be otherwise met without undue hardship; and\n\n(ii) ensures that the subpoenaed person will be reasonably compensated.\n\n#### **(e) Duties in Responding to a Subpoena.**\n\n*(1) Producing Documents or Electronically Stored Information.* These procedures apply to producing documents or electronically stored information:\n\n*(A) Documents.* A person responding to a subpoena to produce documents must produce them as they are kept in the ordinary course of business or must organize and label them to correspond to the categories in the demand.\n\n*(B) Form for Producing Electronically Stored Information Not Specified.* If a subpoena does not specify a form for producing electronically stored information, the person responding must produce it in a form or forms in which it is ordinarily maintained or in a reasonably usable form or forms.\n\n*(C) Electronically Stored Information Produced in Only One Form.* The person responding need not produce the same electronically stored information in more than one form.\n\n*(D) Inaccessible Electronically Stored Information.* The person responding need not provide discovery of electronically stored information from sources that the person identifies as not reasonably accessible because of undue burden or cost. On motion to compel discovery or for a protective order, the person responding must show that the information is not reasonably accessible because of undue burden or cost. If that showing is made, the court may nonetheless order discovery from such sources if the requesting party shows good cause, considering the limitations of Rule 26(b)(2)(C). The court may specify conditions for the discovery.\n\n#### *(2) Claiming Privilege or Protection.*\n\n*(A) Information Withheld.* A person withholding subpoenaed information under a claim that it is privileged or subject to protection as trial-preparation material must: (i) expressly make the claim; and\n\n(ii) describe the nature of the withheld documents, communications, or tangible things in a manner that, without revealing information itself privileged or protected, will enable the parties to assess the claim.\n\n*(B) Information Produced.* If information produced in response to a subpoena is subject to a claim of privilege or of protection as trial-preparation material, the person making the claim may notify any party that received the information of the claim and the basis for it. After being notified, a party must promptly return, sequester, or destroy the specified information and any copies it has; must not use or disclose the information until the claim is resolved; must take reasonable steps to retrieve the information if the party disclosed it before being notified; and may promptly present the information under seal to the court for the district where compliance is required for a determination of the claim. The person who produced the information must preserve the information until the claim is resolved.\n\n**(g) Contempt.** The court for the district where compliance is required – and also, after a motion is transferred, the issuing court – may hold in contempt a person who, having been served, fails without adequate excuse to obey the subpoena or an order related to it.\n\nFor access to subpoena materials, see Fed.R.Civ.P.45(a) Committee Note (2013)\n\n…\n\n## **Requests for Production of Documents**\n\n## **I. INSTRUCTIONS**\n\n1. Unless otherwise indicated, the requests for documents set forth below, (the \"Requests,\" and each, a \"Request\"), must be responded to separately and specifically. Each Request shall be answered fully unless it is in good faith objected to, in which event the reason for Your objection shall be stated in detail, as set forth below. If an objection pertains only to a portion of a Request, or a word, phrase or clause contained within it, You are required to state Your objection to that portion only and to respond to the remainder of the Requests.\n\n2. Electronically stored information must be produced in accordance with the\n\nfollowing instructions:\n\n- a. Images. Black and white images must be 300 DPI Group IV single-page TIFF files. Color images must be produced in JPEG format. File names cannot contain embedded spaces or special characters (including the comma). Folder names cannot contain embedded spaces or special characters (including the comma). All TIFF image files must have a unique file name, i.e. Bates number. Images must be endorsed with sequential Bates numbers in the lower right corner of each image. The number of TIFF files per folder should not exceed 1000 files. Excel spreadsheets should have a placeholder image named by the Bates number of the file.\n- b. Image Load File\n\t- a. Concordance® Data File. The data file (.DAT) contains all of the fielded information that will be loaded into the Concordance® database. The first line of the .DAT file must be a header row identifying the field names. The .DAT file must use the following Concordance® default delimiters: Comma ASCII character (020) Quote þ ASCII character (254). Date fields should be provided in the format: mm/dd/yyyy. Date and time fields must be two separate fields. If documents includes imaged emails and attachments, the attachment fields must be included to preserve the parent/child relationship between an email and its attachments. An OCRPATH field must be included to provide the file path and name of the extracted text file on the produced storage media. The text file must be named after the FIRSTBATES. Do not include the text in the .DAT file. For Documents with native files, a LINK field must be included to provide the file path and\n\nname of the native file. The native file must be named after the FIRSTBATES.\n\n- b. Concordance Image® OR Opticon Cross-Reference File. The image crossreference file (.LOG or .OPT) links the images to the database records. It should be a comma-delimited file consisting of seven fields per line with a line in the cross-reference file for every image in the database with the following format: ImageID,VolumeLabel,ImageFilePath,DocumentBreak,FolderBreak,Box Break,PageCoun.\n- c. Document Text. Text must be produced as separate text files, not as fields within the .DAT file. The full path to the text file (OCRPATH) should be included in the .DAT file. It is recommended document level ANSI text files, named per the FIRSTBATES/Image Key. Extracted text files must be in a separate folder, and the number of text files per folder should not exceed 1,000 files. There should be no special characters (including commas in the folder names). Text files must be provided on a document level.\n- d. Native Production for Certain File Types. File types that reasonably require viewing in their native format for a full understanding of their content and meaning must be produced in native format. These include, but are not limited to, spreadsheets, spreadsheet-like files (Microsoft Excel, comma separated values, tab separated values, etc.), Microsoft PowerPoint or other special presentation files, database files, and audio/visual files. Provide an image of a Bates numbered slip sheet indicating the presence of a native file, and include the path to the native as a field in the .dat file. Name the produced native file with the Bates number corresponding to the slip sheet for the file. Group native files within incrementally named \"NATIVE\" directories, separate from images directories.\n- e. De-duplication. Produce a single copy of each electronic document for which exact duplicates exist. For email messages, consolidate duplicates based on MD5 hash generated from the BCC, Body, CC, From, IntMsgID, To, and Attach properties. For email attachments and standalone electronic files, consolidate duplicates based on MD5 hash of the entire file.\n- f. Metadata. Produce extracted metadata for each document in the form of a Concordance compliant load file (.dat). The first line of the .DAT file must be a header row identifying the field names. The .DAT file must use the following Concordance default delimiters: Comma , ASCII character (020) Quote þ ASCII character (254)\n\nDate fields should be provided in the format: mm/dd/yyyy. Date and time fields must be two separate fields. Required metadata listed below:\n\n# Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 645 of 1063\n\n| Field Name   | Sample Data              | Description                                                                                  |\n|--------------|--------------------------|----------------------------------------------------------------------------------------------|\n| FIRSTBATES   | EDC0000001               | First Bates number of native file document/email                                             |\n| LASTBATES    | EDC0000001               | Last Bates number of native file document/email<br>**The LASTBATES field should be populated |\n|              |                          | for single page                                                                              |\n| ATTACHRANGE  | EDC0000001<br>-          | Bates number of the first page of the parent                                                 |\n|              | EDC0000015               | document to the Bates number of the last page of                                             |\n|              |                          | the last attachment \"child\" document                                                         |\n| BEGATTACH    | EDC0000001               | First Bates number of attachment range                                                       |\n| ENDATTACH    | EDC0000015               | Last Bates number of attachment range                                                        |\n| CUSTODIAN    | Smith, John              | Email: Mailbox where the email resided                                                       |\n|              |                          | Native: Name of the individual or department                                                 |\n|              |                          | from whose files the document<br>originated                                                  |\n| FROM         | John Smith               | Email: Sender                                                                                |\n|              |                          | Native: Author(s) of document                                                                |\n|              |                          | **semi-colon should be used to separate                                                      |\n|              |                          | multiple entries                                                                             |\n| TO           | Coffman, Janice; LeeW    | Recipient(s)                                                                                 |\n|              | [mailto:LeeW@MSN.com]    | **semi-colon should be used to separate multiple                                             |\n|              |                          | entries                                                                                      |\n| CC           | Frank Thompson [mailto:  | Carbon copy recipient(s)                                                                     |\n|              | frank_Thompson@cdt.com]  | **semi-colon should be used to separate                                                      |\n|              |                          | multiple entries                                                                             |\n| BCC          | John Cain                | Blind carbon copy recipient(s)                                                               |\n|              |                          | **semi-colon should be used to separate                                                      |\n|              |                          | multiple entries                                                                             |\n| SUBJECT      | Board Meeting Minutes    | Email: Subject line of the email Native: Title                                               |\n|              |                          | of document (if available)                                                                   |\n| FILE_NAME    | BoardMeetingMinutes.docx | Native: Name of the original native file,                                                    |\n|              |                          | including extension                                                                          |\n| DATE_SENT    | 10/12/2010               | Email: Date the email was sent                                                               |\n|              |                          | Native: (empty)                                                                              |\n| TIME_SENT/   | 07:05 PM GMT             | Email: Time the email was sent/ Time zone in                                                 |\n| TIME_ZONE    |                          | which the emails were standardized                                                           |\n| TIME_ZONE    | GMT                      | The<br>time zone in which<br>the emails<br>were                                              |\n|              |                          | standardized during conversion.                                                              |\n| LINK         |  EDC0000001.msg   | Hyperlink to the email or native file document                                               |\n|              |                          | **The linked file must be named per the                                                      |\n|              |                          | FIRSTBATES number                                                                            |\n| FILE_EXTEN   | MSG                      | The file type extension                                                                      |\n|              |                          | representing                                                                                 |\n|              |                          | the Email or                                                                                 |\n| AUTHOR       | John Smith               | Email: (empty)                                                                               |\n|              |                          | Native: Author of the document                                                               |\n| DATE_CREATED | 10/10/2010               | Email: (empty)                                                                               |\n|              |                          | Native: Date the document was created                                                        |\n\n# Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 646 of 1063\n\n| TIME_CREATED | 10:25 AM                  | Email: (empty)                                  |\n|--------------|---------------------------|-------------------------------------------------|\n|              |                           | Native: Time the document was created           |\n|              |                           | **This data must be a separate field and cannot |\n|              |                           | be combined with the DATE_CREATED field         |\n| DATE_MOD     | 10/12/2010                | Email: (empty)                                  |\n|              |                           | Native: Date the document was last modified     |\n| TIME_MOD     | 07:00 PM                  | Email: (empty)                                  |\n|              |                           | Native: Time the document was last modified     |\n|              |                           | **This data must be a separate field and cannot |\n|              |                           | be combined with the DATE_MOD field             |\n| DATE_ACCESSD | 10/12/2010                | Email: (empty)                                  |\n|              |                           | Native: Date the document was last accessed     |\n| TIME_ACCESSD | 07:00 PM                  | Email: (empty)                                  |\n|              |                           | Native: Time the document was last accessed     |\n|              |                           | **This data must be a separate field and cannot |\n|              |                           | be combined with the DATE_ACCESSD field         |\n| FILE_SIZE    | 5,952                     | Size of native file<br>document/email in KB     |\n| PGCOUNT      | 1                         | Number of pages in native file document/email   |\n| PATH         |   | Email: (empty)                                  |\n|              | Agenda.doc                | Native: Path where native file document was     |\n|              |                           | stored including original file name.            |\n| INTFILEPATH  | Personal Folders\\Deleted  | Email: original location of email including     |\n|              | Items\\Board Meeting       | original file name.                             |\n|              | Minutes.msg               | Native: (empty)                                 |\n| INTMSGID     | <000805c2c71b\\$75977050\\$ | Email: Unique Message ID Native: (empty)        |\n|              | cb8306d1@MSN>             |                                                 |\n| MD5HASH      | d131dd02c5e6eec4693d9a0   | MD5 Hash value of the document.                 |\n|              | 698aff95c                 |                                                 |\n|              | 2fcab58712467eab4004583e  |                                                 |\n|              | b8fb7f89                  |                                                 |\n| OCRPATH      | TEXT/001/EDC0000001.txt   | Path to extracted text of the native file       |\n\n3. Each Request operates and should be construed independently and, unless otherwise indicated, no Request limits the scope of any other Request.\n\n4. All Documents are to be produced as kept in the usual course of business or are to be organized and labeled to correspond with the categories in these Requests.\n\n5. Each Request contained herein extends to all Documents: (a) in Your possession, custody, or control; or (b) in the possession, custody, or control of anyone acting on Your behalf,\n\n#### Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 647 of 1063\n\nincluding Your counsel or other representatives and advisors. Each Document shall be produced in its entirety.\n\n6. If You are requested to produce a Document that is no longer in Your possession, custody, or control, then Your response must (a) describe in detail the nature of the document and its contents; (b) identify the person(s) who prepared or authored the Document (and, if applicable, the Person(s) to whom the Document was sent); (c) identify the date on which the document was prepared or created; (d) state whether such Document (i) is missing or lost, (ii) has been destroyed, (iii) has been transferred, voluntarily or involuntarily, to others, or (iv) was otherwise disposed of; (e) state the reason for, and the facts and circumstances surrounding, such disposition; (f) identify the Persons who authorized such disposition; (g) identify the date or approximate date of such disposition; (h) state when the Document was most recently in Your possession, custody or control; and (i) identify the Person, if any, presently in possession, custody, or control of such Document.\n\n7. If You are requested to produce a Document that has been destroyed, then Your response must state, in addition to the information required by the preceding Instruction: (a) the reason for the Document's destruction; (b) the identity of the Person who destroyed the Document; and (c) the identity of the Person who directed that the Document be destroyed.\n\n8. If You claim that a requested Document is privileged or attorney work-product, then Your response must: (a) state (i) a description of the Document adequate to support Your contention that the Document is privileged, (ii) the title of the Document, (iii) the date of the Document, (iv) the author of the Document, (v) the addressee of the Document, (vi) the identity of each Person who received or saw the original or any draft, copy, or reproduction of the Document, (vii) whether the Document itself, or any information contained or referred to in the Document is in the possession, custody, or control of any other Persons, and if so, the identity of\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 648 of 1063\n\nsuch Persons, as well as a statement addressing how the information came into their possession, (viii) the claim of privilege under which the Document is withheld, and (ix) all of the circumstances upon which You will rely to support such claim of privilege; and (b) produce a privilege log containing all of the information requested in Part (a) of this Instruction for each Document withheld on the basis of a claim of privilege in accordance with D. Conn. L. Civ. R. 26(e).\n\n9. If a portion of an otherwise responsive Document contains information subject to a claim of privilege, only that portion of the Document subject to the claim of privilege shall be deleted or redacted from the Document following the instructions above, and the rest shall be produced.\n\n10. The Requests are continuing in nature. You are hereby instructed to (a) supplement or correct any responses later learned to be incomplete or incorrect immediately upon learning that a prior response was incomplete or incorrect; and (b) produce any additional Documents that are called for under the\n\n11. If a Document is in a language other than English, You should provide that Document. If a Document is in a language other than English, and an English translation exists, You should provide both Documents.\n\n12. All references to Entities includes all affiliates thereof.\n\n13. All references to individual names include all alternative names, aliased, or nicknames.\n\n14. Unless otherwise expressly indicated, the period of time covered by the Document Requests is the period from February 5, 2012 to the date responses to the Document Requests are due.\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 649 of 1063\n\n#### **II. RULES OF CONSTRUCTION**\n\n15. The use of (a) any singular noun shall be construed to include the plural, and vice versa, and (b) a verb in any tense shall be construed as the use of the verb in all other tenses.\n\n16. The terms (a) \"and\" and \"or\" shall be construed either conjunctively or disjunctively as necessary to bring within the scope of any request all responses that might otherwise be construed to be outside of its scope, and (b) \"each\" and \"any\" shall be deemed to include and encompass the words \"every\" and \"all.\"\n\n#### **III. DEFINITIONS**\n\nThe definitions supplied by D. Conn. L. Civ. R. 26(c) and the rules of construction supplied by D. Conn. L. Civ. R. 26(d), as incorporated by D. Conn. Bankr. L.R. 2004-1(a), shall apply to the Document Requests. In addition, the following terms used in these Document Requests shall have the following meanings:\n\n1. \"You\" or \"Your\" or \"Yourself\" means and refers to Macaron Limited, together with all of its affiliates, divisions, agencies, instrumentalities, departments, offices, partners, officers, directors, agents, attorneys, representatives, employees, and/or anyone acting on its behalf.\n\n2. \"Debtor\" means Ho Wan Kwok (a/k/a Miles Kwok, Miles Guo, Guo Wengui, Guo Haoyun, 郭文贵, or any other alias), together with his employees, agents, counsel, advisors, or anyone acting on his behalf.\n\n3. \"Debtor's Son\" means Qiang Guo (a/k/a Mileson Kwok, 郭强, or any other alias), together with his employees, agents, counsel, advisors, or anyone acting on his behalf.\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 650 of 1063\n\n4. \"Debtor's Daughter\" means Mei Guo (a/k/a Mei Gui, 郭美, or any other alias), together with her employees, agents, counsel, advisors, or anyone acting on her behalf.\n\n5. \"Debtor's Purported Wife\" means Hing Chi Ngok (a/k/a Hing Chi Ng, Yue Qingzhi, 岳庆芝, or any other alias), together with her employees, agents, counsel, advisors, or anyone acting on her behalf.\n\n6. \"Debtor's Family\" means, collectively, the Debtor, the Debtor's Son, the Debtor's Daughter, and the Debtor's Purported Wife, and any other familial relation to the Debtor.\n\n7. \"Associated Individuals\" means, individually and collectively, all individuals that (1) hold, control, have custody over, or discretion over assets owned, controlled, or enjoyed by the Debtor or the Debtor's Family; or (2) have been employees, directors, or otherwise are affiliated with one or more Associated Entities, together with the respective employees, agents, counsel, advisors, or anyone acting on behalf of any of the foregoing. Such Associated Individuals shall include, but are not limited to: Daniel Podhaskie, Jason Miller, Steve Bannon, Karin Maistrello, Melissa Francis, Anthony DiBattista, William Gertz, Arethusa Forsyth, Glenn Mellor, Jennifer Mercurio, Eduardo Eurnekian, Wencong Wang, Han Chunguang (a/k/a 韩春光), Qu Guojiao (a/k/a Qu Guo Jiao, 屈国姣), Guo Lijie (a/k/a 郭丽杰), Zhang Wei (a/k/a 张伟\\*), Lihong Wei Lafrenz (a/k/a Sara Wei, 魏丽红), Hao Haidong (a/k/a 郝海东), Ross Heinemeyer, Max Krasner, Kyle Bass, Melissa Mendez, Ya Li (a/k/a 李娅), Dinggang Wang (a/k/a 王定刚), An Hong (a/k/a 安红), Yvette Wang (a/k/a Yanping Wang, Yan Ping Wang, 王雁平), Fiona Yu, Je Kin Ming (a/k/a William Je, Yu Jianming, 余建明), Yaz Qingua, and Lao Jiang (a/k/a Jiang Yunfu, Jiang Yunfu Be, 姜云浮).\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 651 of 1063\n\n8. \"Associated Entities\" means, individually and collectively, all organizations or Entities of any type that (1) have been owned, controlled, or invested in by the Debtor or the Debtor's Family; or (2) have an interest, whether directly or indirectly, in any assets owned, controlled, or enjoyed by the Debtor or the Debtor's Family, together with the respective employees, agents, counsel, advisors, or anyone acting on behalf of any of the foregoing. Such Associated Entities shall include, but are not limited to: 7 Nod Hill LLC, AAGV Limited, ACA Investment Management Limited, ACA Capital Group Limited, Ace Decade Holdings Limited, AI Group Holdings Inc., Alfa Global Ventures Limited, Alfonso Global Limited, Allied Capital Global Limited, Alpine Fiduciaries SA, Anton Development Limited, Assets Sino Limited, Auspicious Coast Limited, Beijing Pangu Investment Co., Beijing Pangu Investment Co. Ltd., Beijing Pangu Investment Inc., Beijing Zenith Holdings Company Limited, Booming Sail New York LLC, Bravo Luck Limited, BSA Strategic Fund I, China Golden Spring (Hong Kong) Limited, Chuang Xin Limited, Crane Advisory Group LLC, Creative Apex Investments Limited, Crystal Breeze Investments Limited, Dawn State Limited, Eastern Profit Corporation Limited, Elite Well Global Limited, Empire Growth Holdings, Freedom Media Ventures Ltd., G Club Operations LLC, G Fashion LLC, G News LLC, GETTR USA, Genever Holdings Corporation, Genever Holdings LLC, Gfashion Media Group Inc., GFNY, Inc., Globalist International Limited, GNews Media Group Inc., Golden Spring (New York) Ltd., Greenwich Land LLC, Guo Media, GTV Media Group, Inc., Hamilton Capital Holdings Inc., HCHK Property Management, Inc., HCHK Technologies, Inc., Head Win Group Limited, Henan Yuda, Himalaya Embassy, Himalaya Exchange, Himalaya Federal Reserve, Himalaya Investment LLC, Himalaya International, Himalaya New World Inc., Himalaya Supervisory Organization, Himalaya Ventures LLC, HK International Funds Investments (USA) Limited LLC, Hong Kong International Funds\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 652 of 1063\n\nInvestments Limited, Hudson Diamond Holding, Infinite Increase Limited, Infinitum Developments Limited, Infinity Treasury Management Inc., Insight Phoenix Fund, Lamp Capital LLC, Leading Shine Limited, Leading Shine NY Limited, Lexington Property and Staffing, Long Gate Limited, Maywind Trading LLC, MOS Himalaya LLC, Next Tycoon Investments Limited, New Federal State of China (a/k/a NFSC), Noble Fame Global Limited, Rosy Acme Ventures Limited, Rule of Law Foundation III, Inc., Rule of Law Foundation IV, Inc., Rule of Law Fund, Rule of Law Society, Rule of Law Society IV, Inc., G-Translators PTY LTD, Saraca Media Group, Inc., Shiny Ace Ltd., Shiny Times Holdings Ltd., Spirit Charter Investment Limited, Stevenson, Wong & Co., Voice of Guo Media, Inc., Well Origin Ltd., World Century Limited, Worldwide Opportunity Holdings Limited, Whitecroft Shore Limited, and ZIBA Limited.\n\n9. \"Including\" or any variant thereof means \"including without limitation.\"\n\n10. \"And\" and \"or\" mean \"and/or,\" and shall be construed both conjunctively as well as disjunctively in order to maximize their scope.\n\n11. \"Any\" and \"all\" and \"each\" mean \"each and every.\"\n\n12. \"Each\" and \"every\" mean \"each and every.\"\n\n13. \"Third Party\" means a Person or Entity other than Yourself.\n\n14. \"Transfer\" shall have the meaning given to it by section 101(54) of the Bankruptcy Code.\n\n15. \"Document\" means any information or thing within the scope of Fed. R. Civ. P. 34, and includes, without limitation, each and every written, recorded, or graphic matter of any kind, type, nature, or description that is or has been in Your Possession, Custody or Control, including all printed and electronic copies of electronic mail, computer files maintained in\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 653 of 1063\n\nelectronic form, electronic communication, text message, social media post, tweet, meta-data, correspondence, memoranda, tapes, stenographic or handwritten notes, written forms of any kind, charts, blueprints, drawings, sketches, graphs, plans, articles, specifications, diaries, letters, telegrams, photographs, minutes, contracts, agreements, surveys, computer printouts, data compilations of any kind, telexes, facsimiles, voice messages, invoices, order forms, checks, drafts, statements, credit memos, reports, position reports, summaries, indices, books, ledgers, notebooks, schedules, transparencies, recordings, catalogs, advertisements, promotional materials, films, video tapes, audio tapes, CDs, computer disks, brochures, pamphlets, punchcards, time-slips, Tweets, social media posts, or any written or recorded materials of any other kind, and all meta-data thereof, however stored (whether in tangible or electronic form), recorded, produced, or reproduced, and also including but not limited to, drafts or copies of any of the foregoing that contain any notes, comments, or markings of any kind not found on the original documents or that are otherwise not identical to the original documents.\n\n16. \"Person(s)\" means an individual, corporation, proprietorship, partnership, association, or any other Entity. \"Person\" also includes any agent, representatives, or expert, including but not limiting to, attorneys or financial advisors.\n\n17. \"Entity\" means any natural Person, corporation, partnership, subsidiary, sole proprietorship, firm, board, joint venture, association, agency, authority, commission or other business entity or juristic Person, as well as any affiliate, agent, parent including but not limited to legal counsel, financial advisors, or any other representative.\n\n18. \"Regarding\" means concerning, describing, comprising, referring to, related to, supporting, favoring, opposing, bolstering, detracting from, located in, considered in connection with, bearing on, evidencing, indicating, reporting on, recording, alluding to, responding to,\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 654 of 1063\n\nconnected with, commenting on, in respect of, about, in relation to, discussing, showing, describing, reflecting, analyzing constituting, and being.\n\n19. \"Relating to,\" \"relate(s) to\" or \"related to,\" when referring to any given subject matter, means, without limitation, any document that constitutes, comprises, involves, contains, embodies, reflects, identifies, states, refers directly or indirectly to, or is in any way relevant to the particular subject matter identified.\n\n20. \"Communication(s)\" means, in the broadest possible sense, and without limitation, any transmittal of information or knowledge (in the form of facts, ideas, inquiries, or otherwise). Communication(s) further refers to all conversations, agreements, inquiries, or replies, whether in person, by telephone, in writing, or by means of electronic transmittal devices, and includes, but is not limited to, all correspondence, emails, recordings, transmittal slips, memoranda, telephone communications, voice messages, telegrams, telefaxes, telecopies, telexes, instant messages, chats, text messages, telephonic notes, or notes transmitted internally or with third parties.\n\n21. \"Asset(s)\" means any item that can be used to produce positive economic value, including but not limited to any resource with economic value that is owned, controlled or is for the benefit of an entity, that is expected to provide a future benefit, including but not limited to, all real and personal property, intangible property, investments, rights to invest or to future revenue, cash, bank accounts, commodities, securities, claims, total or partial control of an entity, and prospective economic opportunities\n\n22. \"Transfer\" shall have the meaning given to it by section 101(54) of the Bankruptcy Code.\n\n#### **IV. DOCUMENTS TO BE PRODUCED**\n\n1. All Documents regarding any income or Asset of the Debtor, the Debtor's estate, or an Associated Entity.\n\n2. All Documents related to the Debtor's financial condition and obligations to his creditors, including without limitation all Documents related to any effort to avoid paying such obligations and All Documents related to this or any other actual or potential bankruptcy or similar insolvency proceeding.\n\n3. All Documents regarding any balance sheet, bank statement, account statement, financial statement, statement of account, wire transfer instructions and/or confirmation, proof of funds, certificate of deposit, certificate of holdings, investment portfolio summary, or similar document relating to the Debtor, the Debtor's Estate, the Debtor's Family, an Associated Entity, or an Associated Individual, including without limitation all Documents sufficient to show all Transfers to any of the foregoing.\n\n4. All Documents regarding any investment, business dealing or transactions made by, with, or on behalf of the Debtor.\n\n5. All Communications with the Debtor, and Documents related to Communications with the Debtor, related to the operation, management, or decision-making of any Entity, including without limitation the Associated Entities.\n\n6. All Documents regarding any Transfer, investment, or other transaction or business dealing made to, by, or with the Debtor, the Debtor's Family, or an Associated Entity.\n\n7. All Documents regarding any property ever occupied or used by the Debtor, including without limitation the *Lady May*; the Sherry Netherland Hotel / Condominium; the\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 656 of 1063\n\nresidential property located in Greenwich, Connecticut at 373 Taconic Rd.; the residential property located in Greenwich, Connecticut at 33 Ferncliff Rd.; and the residential property located in Wilton, Connecticut at 354 Nod Hill Rd.\n\n8. All Documents related to any aircraft owned, controlled, or used by the Debtor, including without limitation the aircraft bearing tail number T7-GQM and any other aircraft registered in San Marino, including without limitation copies of all registration documents and flight manifests showing flights taken by such aircraft and the individuals onboard such flights.\n\n9. All Documents regarding any gifts, benefits or loans, to, from or on behalf of the Debtor, the Debtor's Estate, the Debtor's Family, or the Associated Entities, including without limitation Documents sufficient to show the amounts of such gifts, benefits, or loans; the purposes for which such gifts, benefits, or loans were used; when the gifts, benefits, or loans were provided; and the terms of any loans, all representations and warranties made in connection with any loans, the interest rate on any loans, and all evidence of payments of any loans.\n\n10. All Documents concerning any trust or similar instrument set up by, on behalf of, or for the benefit of the Debtor, the Debtor's Estate, the Debtor's Family, or an Associated Entity, including without limitation Documents sufficient to show when the trust(s) was created, by whom it was created, for whose benefit it was created, and the corpus of the trust.\n\n11. All Documents related to any obligation, claim, liability, or debt associated with any legal dispute involving the Debtor, including but not limited to those relating to any litigation before any local, state, federal, or international body, whether an administrative body, court, panel, or alternative dispute resolution entity.\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 657 of 1063\n\n12. All Documents and communications between any of your outside counsel or other advisors and the Debtor.\n\n13. Documents sufficient to show all of Your Assets and sources of income or funding.\n\n14. For all Assets identified in response to Request 14 having a value of more than \\$50,000, all (i) Documents related to Your acquisition of such Asset and (ii) Communications with the Debtor or the Debtor's Family regarding such Asset.\n\n15. Copies of Your tax returns.\n\n16. Documents sufficient to show all bank accounts and investment accounts within Your possession or control, including the balances of and transfers to and from each such account.\n\n17. All Documents regarding any credit cards used by You, including without limitation monthly statements or other Documents sufficient to show all purchases related thereto for the benefit of the Debtor or an Associated Entity.\n\n18. All corporate governance and organizational Documents, including without limitation by-laws and certificates of incorporation and other Documents sufficient to show Your corporate structure, names of officers and directors, business purpose, and relationship to the Debtor or to any member of the Debtor's Family.\n\n19. All Documents related to any pledge(s) of Your Assets to any other Entity.\n\nCase 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 658 of 1063\n\n# Exhibit C-36\n\n#### B2540 (Form 2540 – Subpoena for Rule 2004 Examination) (12/15) Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 659 of\n\nUNITED STATES BANKRUPTCY COURT 1063\n\n**District of Connecticut**\n\nIn re HO WAN KWOK, *et al*.,\n\n<sup>1</sup> Case No. 22-50073 (JAM)\n\nDebtor Chapter 11\n\n(Jointly Administered)\n\n## **SUBPOENA FOR RULE 2004 EXAMINATION**\n\nTo: **Lihong \"Sara\" Wei Lafrenz**\n\n(*Name of person to whom the subpoena is directed*)\n\n*Testimony:* **YOU ARE COMMANDED** to appear at the time, date, and place set forth below to testify at an examination under Rule 2004, Federal Rules of Bankruptcy Procedure. A copy of the court order authorizing the examination is attached.\n\n| PLACE                    | DATE AND TIME |\n|--------------------------|---------------|\n| Paul Hastings LLP        |               |\n| 200 Park Avenue          | [TBD]         |\n| New York, New York 10166 |               |\n|                          |               |\n\nThe examination will be recorded by this method: **Court reporter/stenographer**\n\n*Production:* You, or your representatives, must also bring with you to the examination the following documents, electronically stored information, or objects, and must permit inspection, copying, testing, or sampling of the material:\n\n#### **See Requests for Production of Documents, attached hereto.**\n\nThe following provisions of Fed. R. Civ. P. 45, made applicable in bankruptcy cases by Fed. R. Bankr. P. 9016, are attached – Rule 45(c), relating to the place of compliance; Rule 45(d), relating to your protection as a person subject to a subpoena; and Rule 45(e) and 45(g), relating to your duty to respond to this subpoena and the potential consequences of not doing so.\n\nDate: **March , 2023**\n\nCLERK OF COURT\n\nOR\n\n*Signature of Clerk or Deputy Clerk Attorney's signature*\n\nThe name, address, email address, and telephone number of the attorney representing Luc A. Despins, Chapter 11 Trustee, who issues or requests this subpoena, are:\n\n**Douglas S. Skalka, Esq.; Neubert, Pepe & Monteith, P.C.; 195 Church Street, New Haven, Connecticut 06510 dskalka@npmlaw.com; (203) 821-2000**\n\n**Notice to the person who issues or requests this subpoena**\n\nIf this subpoena commands the production of documents, electronically stored information, or tangible things, or the inspection of premises before trial, a notice and a copy of this subpoena must be served on each party before it is served on the person to whom it is directed. Fed. R. Civ. P. 45(a)(4).\n\nSoftware Copyright (c) 1996-2022 Best Case, LLC - www.bestcase.com Best Case Bankruptcy 1 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\n#### **PROOF OF SERVICE**\n\n**(This section should not be filed with the court unless required by Fed. R. Civ. P. 45.)**\n\nI received this subpoena for (*name of individual and title, if any*): on (*date*) .\n\nI served the subpoena by delivering a copy to the named person as follows:\n\non *(date)* ; or\n\nI returned the subpoena unexecuted because:\n\nUnless the subpoena was issued on behalf of the United States, or one of its officers or agents, I have also tendered to the witness the fees for one day's attendance, and the mileage allowed by law, in the amount of \\$ .\n\nMy fees are \\$ for travel and \\$ for services, for a total of \\$ .\n\nI declare under penalty of perjury that this information is true and correct.\n\nDate:\n\n*Server's signature*\n\n*Printed name and title*\n\n*Server's address*\n\nAdditional information concerning attempted service, etc.:\n\n#### **Federal Rule of Civil Procedure 45(c), (d), (e), and (g) (Effective 12/1/13) (made applicable in bankruptcy cases by Rule 9016, Federal Rules of Bankruptcy Procedure)**\n\n#### **(c) Place of compliance.**\n\n*(1) For a Trial, Hearing, or Deposition.* A subpoena may command a person to attend a trial, hearing, or deposition only as follows:\n\n(A) within 100 miles of where the person resides, is employed, or regularly transacts business in person; or\n\n(B) within the state where the person resides, is employed, or regularly transacts business in person, if the person\n\n(i) is a party or a party's officer; or\n\n(ii) is commanded to attend a trial and would not incur substantial expense.\n\n*(2) For Other Discovery.* A subpoena may command:\n\n(A) production of documents, or electronically stored information, or things at a place within 100 miles of where the person resides, is employed, or regularly transacts business in person; and\n\n(B) inspection of premises, at the premises to be inspected.\n\n#### **(d) Protecting a Person Subject to a Subpoena; Enforcement.**\n\n*(1) Avoiding Undue Burden or Expense; Sanctions.* A party or attorney responsible for issuing and serving a subpoena must take reasonable steps to avoid imposing undue burden or expense on a person subject to the subpoena. The court for the district where compliance is required must enforce this duty and impose an appropriate sanction which may include lost earnings and reasonable attorney's fees — on a party or attorney who fails to comply.\n\n#### *(2) Command to Produce Materials or Permit Inspection.*\n\n*(A) Appearance Not Required.* A person commanded to produce documents, electronically stored information, or tangible things, or to permit the inspection of premises, need not appear in person at the place of production or inspection unless also commanded to appear for a deposition, hearing, or trial.\n\n*(B) Objections.* A person commanded to produce documents or tangible things or to permit inspection may serve on the party or attorney designated in the subpoena a written objection to inspecting, copying, testing or sampling any or all of the materials or to inspecting the premises — or to producing electronically stored information in the form or forms requested. The objection must be served before the earlier of the time specified for compliance or 14 days after the subpoena is served. If an objection is made, the following rules apply:\n\n(i) At any time, on notice to the commanded person, the serving party may move the court for the district where compliance is required for an order compelling production or inspection.\n\n(ii) These acts may be required only as directed in the order, and the order must protect a person who is neither a party nor a party's officer from significant expense resulting from compliance.\n\n#### *(3) Quashing or Modifying a Subpoena.*\n\n*(A) When Required.* On timely motion, the court for the district where compliance is required must quash or modify a subpoena that:\n\n(i) fails to allow a reasonable time to comply;\n\n(ii) requires a person to comply beyond the geographical limits specified in Rule 45(c);\n\n(iii) requires disclosure of privileged or other protected matter, if no exception or waiver applies; or\n\n(iv) subjects a person to undue burden.\n\n*(B) When Permitted.* To protect a person subject to or affected by a subpoena, the court for the district where compliance is required may, on motion, quash or modify the subpoena if it requires:\n\n(i) disclosing a trade secret or other confidential research, development, or commercial information; or\n\n(ii) disclosing an unretained expert's opinion or information that does not describe specific occurrences in dispute and results from the expert's study that was not requested by a party.\n\n(C) *Specifying Conditions as an Alternative.* In the circumstances described in Rule 45(d)(3)(B), the court may, instead of quashing or modifying a subpoena, order appearance or production under specified conditions if the serving party:\n\n(i) shows a substantial need for the testimony or material that cannot be otherwise met without undue hardship; and\n\n(ii) ensures that the subpoenaed person will be reasonably compensated.\n\n#### **(e) Duties in Responding to a Subpoena.**\n\n*(1) Producing Documents or Electronically Stored Information.* These procedures apply to producing documents or electronically stored information:\n\n*(A) Documents.* A person responding to a subpoena to produce documents must produce them as they are kept in the ordinary course of business or must organize and label them to correspond to the categories in the demand.\n\n*(B) Form for Producing Electronically Stored Information Not Specified.* If a subpoena does not specify a form for producing electronically stored information, the person responding must produce it in a form or forms in which it is ordinarily maintained or in a reasonably usable form or forms.\n\n*(C) Electronically Stored Information Produced in Only One Form.* The person responding need not produce the same electronically stored information in more than one form.\n\n*(D) Inaccessible Electronically Stored Information.* The person responding need not provide discovery of electronically stored information from sources that the person identifies as not reasonably accessible because of undue burden or cost. On motion to compel discovery or for a protective order, the person responding must show that the information is not reasonably accessible because of undue burden or cost. If that showing is made, the court may nonetheless order discovery from such sources if the requesting party shows good cause, considering the limitations of Rule 26(b)(2)(C). The court may specify conditions for the discovery.\n\n#### *(2) Claiming Privilege or Protection.*\n\n*(A) Information Withheld.* A person withholding subpoenaed information under a claim that it is privileged or subject to protection as trial-preparation material must: (i) expressly make the claim; and\n\n(ii) describe the nature of the withheld documents, communications, or tangible things in a manner that, without revealing information itself privileged or protected, will enable the parties to assess the claim.\n\n*(B) Information Produced.* If information produced in response to a subpoena is subject to a claim of privilege or of protection as trial-preparation material, the person making the claim may notify any party that received the information of the claim and the basis for it. After being notified, a party must promptly return, sequester, or destroy the specified information and any copies it has; must not use or disclose the information until the claim is resolved; must take reasonable steps to retrieve the information if the party disclosed it before being notified; and may promptly present the information under seal to the court for the district where compliance is required for a determination of the claim. The person who produced the information must preserve the information until the claim is resolved.\n\n**(g) Contempt.** The court for the district where compliance is required – and also, after a motion is transferred, the issuing court – may hold in contempt a person who, having been served, fails without adequate excuse to obey the subpoena or an order related to it.\n\nFor access to subpoena materials, see Fed.R.Civ.P.45(a) Committee Note (2013)\n\n…\n\n## **Requests for Production of Documents**\n\n## **I. INSTRUCTIONS**\n\n1. Unless otherwise indicated, the requests for documents set forth below, (the \"Requests,\" and each, a \"Request\"), must be responded to separately and specifically. Each Request shall be answered fully unless it is in good faith objected to, in which event the reason for Your objection shall be stated in detail, as set forth below. If an objection pertains only to a portion of a Request, or a word, phrase or clause contained within it, You are required to state Your objection to that portion only and to respond to the remainder of the Requests.\n\n2. Electronically stored information must be produced in accordance with the\n\nfollowing instructions:\n\n- a. Images. Black and white images must be 300 DPI Group IV single-page TIFF files. Color images must be produced in JPEG format. File names cannot contain embedded spaces or special characters (including the comma). Folder names cannot contain embedded spaces or special characters (including the comma). All TIFF image files must have a unique file name, i.e. Bates number. Images must be endorsed with sequential Bates numbers in the lower right corner of each image. The number of TIFF files per folder should not exceed 1000 files. Excel spreadsheets should have a placeholder image named by the Bates number of the file.\n- b. Image Load File\n\t- a. Concordance® Data File. The data file (.DAT) contains all of the fielded information that will be loaded into the Concordance® database. The first line of the .DAT file must be a header row identifying the field names. The .DAT file must use the following Concordance® default delimiters: Comma ASCII character (020) Quote þ ASCII character (254). Date fields should be provided in the format: mm/dd/yyyy. Date and time fields must be two separate fields. If documents includes imaged emails and attachments, the attachment fields must be included to preserve the parent/child relationship between an email and its attachments. An OCRPATH field must be included to provide the file path and name of the extracted text file on the produced storage media. The text file must be named after the FIRSTBATES. Do not include the text in the .DAT file. For Documents with native files, a LINK field must be included to provide the file path and\n\nname of the native file. The native file must be named after the FIRSTBATES.\n\n- b. Concordance Image® OR Opticon Cross-Reference File. The image crossreference file (.LOG or .OPT) links the images to the database records. It should be a comma-delimited file consisting of seven fields per line with a line in the cross-reference file for every image in the database with the following format: ImageID,VolumeLabel,ImageFilePath,DocumentBreak,FolderBreak,Box Break,PageCoun.\n- c. Document Text. Text must be produced as separate text files, not as fields within the .DAT file. The full path to the text file (OCRPATH) should be included in the .DAT file. It is recommended document level ANSI text files, named per the FIRSTBATES/Image Key. Extracted text files must be in a separate folder, and the number of text files per folder should not exceed 1,000 files. There should be no special characters (including commas in the folder names). Text files must be provided on a document level.\n- d. Native Production for Certain File Types. File types that reasonably require viewing in their native format for a full understanding of their content and meaning must be produced in native format. These include, but are not limited to, spreadsheets, spreadsheet-like files (Microsoft Excel, comma separated values, tab separated values, etc.), Microsoft PowerPoint or other special presentation files, database files, and audio/visual files. Provide an image of a Bates numbered slip sheet indicating the presence of a native file, and include the path to the native as a field in the .dat file. Name the produced native file with the Bates number corresponding to the slip sheet for the file. Group native files within incrementally named \"NATIVE\" directories, separate from images directories.\n- e. De-duplication. Produce a single copy of each electronic document for which exact duplicates exist. For email messages, consolidate duplicates based on MD5 hash generated from the BCC, Body, CC, From, IntMsgID, To, and Attach properties. For email attachments and standalone electronic files, consolidate duplicates based on MD5 hash of the entire file.\n- f. Metadata. Produce extracted metadata for each document in the form of a Concordance compliant load file (.dat). The first line of the .DAT file must be a header row identifying the field names. The .DAT file must use the following Concordance default delimiters: Comma , ASCII character (020) Quote þ ASCII character (254)\n\nDate fields should be provided in the format: mm/dd/yyyy. Date and time fields must be two separate fields. Required metadata listed below:\n\n# Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 664 of 1063\n\n| Field Name   | Sample Data              | Description                                      |\n|--------------|--------------------------|--------------------------------------------------|\n| FIRSTBATES   | EDC0000001               | First Bates number of native file document/email |\n| LASTBATES    | EDC0000001               | Last Bates number of native file document/email  |\n|              |                          | **The LASTBATES field should be populated        |\n|              |                          | for single page                                  |\n| ATTACHRANGE  | EDC0000001<br>-          | Bates number of the first page of the parent     |\n|              | EDC0000015               | document to the Bates number of the last page of |\n|              |                          | the last attachment \"child\" document             |\n| BEGATTACH    | EDC0000001               | First Bates number of attachment range           |\n| ENDATTACH    | EDC0000015               | Last Bates number of attachment range            |\n| CUSTODIAN    | Smith, John              | Email: Mailbox where the email resided           |\n|              |                          | Native: Name of the individual or department     |\n|              |                          | from whose files the document<br>originated      |\n| FROM         | John Smith               | Email: Sender                                    |\n|              |                          | Native: Author(s) of document                    |\n|              |                          | **semi-colon should be used to separate          |\n|              |                          | multiple entries                                 |\n| TO           | Coffman, Janice; LeeW    | Recipient(s)                                     |\n|              | [mailto:LeeW@MSN.com]    | **semi-colon should be used to separate multiple |\n|              |                          | entries                                          |\n| CC           | Frank Thompson [mailto:  | Carbon copy recipient(s)                         |\n|              | frank_Thompson@cdt.com]  | **semi-colon should be used to separate          |\n|              |                          | multiple entries                                 |\n| BCC          | John Cain                | Blind carbon copy recipient(s)                   |\n|              |                          | **semi-colon should be used to separate          |\n|              |                          | multiple entries                                 |\n| SUBJECT      | Board Meeting Minutes    | Email: Subject line of the email Native: Title   |\n|              |                          | of document (if available)                       |\n| FILE_NAME    | BoardMeetingMinutes.docx | Native: Name of the original native file,        |\n|              |                          | including extension                              |\n| DATE_SENT    | 10/12/2010               | Email: Date the email was sent                   |\n|              |                          | Native: (empty)                                  |\n| TIME_SENT/   | 07:05 PM GMT             | Email: Time the email was sent/ Time zone in     |\n| TIME_ZONE    |                          | which the emails were standardized               |\n| TIME_ZONE    | GMT                      | The<br>time zone in which<br>the emails<br>were  |\n|              |                          | standardized during conversion.                  |\n| LINK         |  EDC0000001.msg   | Hyperlink to the email or native file document   |\n|              |                          | **The linked file must be named per the          |\n|              |                          | FIRSTBATES number                                |\n| FILE_EXTEN   | MSG                      | The file type extension                          |\n|              |                          | representing                                     |\n|              |                          | the Email or                                     |\n| AUTHOR       | John Smith               | Email: (empty)                                   |\n|              |                          | Native: Author of the document                   |\n| DATE_CREATED | 10/10/2010               | Email: (empty)                                   |\n|              |                          | Native: Date the document was created            |\n\n# Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 665 of 1063\n\n| TIME_CREATED | 10:25 AM                  | Email: (empty)                                  |\n|--------------|---------------------------|-------------------------------------------------|\n|              |                           | Native: Time the document was created           |\n|              |                           | **This data must be a separate field and cannot |\n|              |                           | be combined with the DATE_CREATED field         |\n| DATE_MOD     | 10/12/2010                | Email: (empty)                                  |\n|              |                           | Native: Date the document was last modified     |\n| TIME_MOD     | 07:00 PM                  | Email: (empty)                                  |\n|              |                           | Native: Time the document was last modified     |\n|              |                           | **This data must be a separate field and cannot |\n|              |                           | be combined with the DATE_MOD field             |\n| DATE_ACCESSD | 10/12/2010                | Email: (empty)                                  |\n|              |                           | Native: Date the document was last accessed     |\n| TIME_ACCESSD | 07:00 PM                  | Email: (empty)                                  |\n|              |                           | Native: Time the document was last accessed     |\n|              |                           | **This data must be a separate field and cannot |\n|              |                           | be combined with the DATE_ACCESSD field         |\n| FILE_SIZE    | 5,952                     | Size of native file<br>document/email in KB     |\n| PGCOUNT      | 1                         | Number of pages in native file document/email   |\n| PATH         |   | Email: (empty)                                  |\n|              | Agenda.doc                | Native: Path where native file document was     |\n|              |                           | stored including original file name.            |\n| INTFILEPATH  | Personal Folders\\Deleted  | Email: original location of email including     |\n|              | Items\\Board Meeting       | original file name.                             |\n|              | Minutes.msg               | Native: (empty)                                 |\n| INTMSGID     | <000805c2c71b\\$75977050\\$ | Email: Unique Message ID Native: (empty)        |\n|              | cb8306d1@MSN>             |                                                 |\n| MD5HASH      | d131dd02c5e6eec4693d9a0   | MD5 Hash value of the document.                 |\n|              | 698aff95c                 |                                                 |\n|              | 2fcab58712467eab4004583e  |                                                 |\n|              | b8fb7f89                  |                                                 |\n| OCRPATH      | TEXT/001/EDC0000001.txt   | Path to extracted text of the native file       |\n\n3. Each Request operates and should be construed independently and, unless otherwise indicated, no Request limits the scope of any other Request.\n\n4. All Documents are to be produced as kept in the usual course of business or are to be organized and labeled to correspond with the categories in these Requests.\n\n5. Each Request contained herein extends to all Documents: (a) in Your possession, custody, or control; or (b) in the possession, custody, or control of anyone acting on Your behalf,\n\n#### Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 666 of 1063\n\nincluding Your counsel or other representatives and advisors. Each Document shall be produced in its entirety.\n\n6. If You are requested to produce a Document that is no longer in Your possession, custody, or control, then Your response must (a) describe in detail the nature of the document and its contents; (b) identify the person(s) who prepared or authored the Document (and, if applicable, the Person(s) to whom the Document was sent); (c) identify the date on which the document was prepared or created; (d) state whether such Document (i) is missing or lost, (ii) has been destroyed, (iii) has been transferred, voluntarily or involuntarily, to others, or (iv) was otherwise disposed of; (e) state the reason for, and the facts and circumstances surrounding, such disposition; (f) identify the Persons who authorized such disposition; (g) identify the date or approximate date of such disposition; (h) state when the Document was most recently in Your possession, custody or control; and (i) identify the Person, if any, presently in possession, custody, or control of such Document.\n\n7. If You are requested to produce a Document that has been destroyed, then Your response must state, in addition to the information required by the preceding Instruction: (a) the reason for the Document's destruction; (b) the identity of the Person who destroyed the Document; and (c) the identity of the Person who directed that the Document be destroyed.\n\n8. If You claim that a requested Document is privileged or attorney work-product, then Your response must: (a) state (i) a description of the Document adequate to support Your contention that the Document is privileged, (ii) the title of the Document, (iii) the date of the Document, (iv) the author of the Document, (v) the addressee of the Document, (vi) the identity of each Person who received or saw the original or any draft, copy, or reproduction of the Document, (vii) whether the Document itself, or any information contained or referred to in the Document is in the possession, custody, or control of any other Persons, and if so, the identity of\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 667 of 1063\n\nsuch Persons, as well as a statement addressing how the information came into their possession, (viii) the claim of privilege under which the Document is withheld, and (ix) all of the circumstances upon which You will rely to support such claim of privilege; and (b) produce a privilege log containing all of the information requested in Part (a) of this Instruction for each Document withheld on the basis of a claim of privilege in accordance with D. Conn. L. Civ. R. 26(e).\n\n9. If a portion of an otherwise responsive Document contains information subject to a claim of privilege, only that portion of the Document subject to the claim of privilege shall be deleted or redacted from the Document following the instructions above, and the rest shall be produced.\n\n10. The Requests are continuing in nature. You are hereby instructed to (a) supplement or correct any responses later learned to be incomplete or incorrect immediately upon learning that a prior response was incomplete or incorrect; and (b) produce any additional Documents that are called for under the\n\n11. If a Document is in a language other than English, You should provide that Document. If a Document is in a language other than English, and an English translation exists, You should provide both Documents.\n\n12. All references to Entities includes all affiliates thereof.\n\n13. All references to individual names include all alternative names, aliased, or nicknames.\n\n14. Unless otherwise expressly indicated, the period of time covered by the Document Requests is the period from February 5, 2012 to the date responses to the Document Requests are due.\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 668 of 1063\n\n#### **II. RULES OF CONSTRUCTION**\n\n15. The use of (a) any singular noun shall be construed to include the plural, and vice versa, and (b) a verb in any tense shall be construed as the use of the verb in all other tenses.\n\n16. The terms (a) \"and\" and \"or\" shall be construed either conjunctively or disjunctively as necessary to bring within the scope of any request all responses that might otherwise be construed to be outside of its scope, and (b) \"each\" and \"any\" shall be deemed to include and encompass the words \"every\" and \"all.\"\n\n#### **III. DEFINITIONS**\n\nThe definitions supplied by D. Conn. L. Civ. R. 26(c) and the rules of construction supplied by D. Conn. L. Civ. R. 26(d), as incorporated by D. Conn. Bankr. L.R. 2004-1(a), shall apply to the Document Requests. In addition, the following terms used in these Document Requests shall have the following meanings:\n\n1. \"You\" or \"Your\" or \"Yourself\" means and refers to Lihong \"Sara\" Wei Lafrenz, together with all of her agents, attorneys, representatives, employees, and/or anyone acting on her behalf.\n\n2. \"Debtor\" means Ho Wan Kwok (a/k/a Miles Kwok, Miles Guo, Guo Wengui, Guo Haoyun, 郭文贵, or any other alias), together with his employees, agents, counsel, advisors, or anyone acting on his behalf.\n\n3. \"Debtor's Son\" means Qiang Guo (a/k/a Mileson Kwok, 郭强, or any other alias), together with his employees, agents, counsel, advisors, or anyone acting on his behalf.\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 669 of 1063\n\n4. \"Debtor's Daughter\" means Mei Guo (a/k/a Mei Gui, 郭美, or any other alias), together with her employees, agents, counsel, advisors, or anyone acting on her behalf.\n\n5. \"Debtor's Purported Wife\" means Hing Chi Ngok (a/k/a Hing Chi Ng, Yue Qingzhi, 岳庆芝, or any other alias), together with her employees, agents, counsel, advisors, or anyone acting on her behalf.\n\n6. \"Debtor's Family\" means, collectively, the Debtor, the Debtor's Son, the Debtor's Daughter, and the Debtor's Purported Wife, and any other familial relation to the Debtor.\n\n7. \"Associated Individuals\" means, individually and collectively, all individuals that (1) hold, control, have custody over, or discretion over assets owned, controlled, or enjoyed by the Debtor or the Debtor's Family; or (2) have been employees, directors, or otherwise are affiliated with one or more Associated Entities, together with the respective employees, agents, counsel, advisors, or anyone acting on behalf of any of the foregoing. Such Associated Individuals shall include, but are not limited to: Daniel Podhaskie, Jason Miller, Steve Bannon, Karin Maistrello, Melissa Francis, Anthony DiBattista, William Gertz, Arethusa Forsyth, Glenn Mellor, Jennifer Mercurio, Eduardo Eurnekian, Wencong Wang, Han Chunguang (a/k/a 韩春光), Qu Guojiao (a/k/a Qu Guo Jiao, 屈国姣), Guo Lijie (a/k/a 郭丽杰), Zhang Wei (a/k/a 张伟\\*), Lihong Wei Lafrenz (a/k/a Sara Wei, 魏丽红), Hao Haidong (a/k/a 郝海东), Ross Heinemeyer, Max Krasner, Kyle Bass, Melissa Mendez, Ya Li (a/k/a 李娅), Dinggang Wang (a/k/a 王定刚), An Hong (a/k/a 安红), Yvette Wang (a/k/a Yanping Wang, Yan Ping Wang, 王雁平), Fiona Yu, Je Kin Ming (a/k/a William Je, Yu Jianming, 余建明), Yaz Qingua, and Lao Jiang (a/k/a Jiang Yunfu, Jiang Yunfu Be, 姜云浮).\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 670 of 1063\n\n8. \"Associated Entities\" means, individually and collectively, all organizations or Entities of any type that (1) have been owned, controlled, or invested in by the Debtor or the Debtor's Family; or (2) have an interest, whether directly or indirectly, in any assets owned, controlled, or enjoyed by the Debtor or the Debtor's Family, together with the respective employees, agents, counsel, advisors, or anyone acting on behalf of any of the foregoing. Such Associated Entities shall include, but are not limited to: 7 Nod Hill LLC, AAGV Limited, ACA Investment Management Limited, ACA Capital Group Limited, Ace Decade Holdings Limited, AI Group Holdings Inc., Alfa Global Ventures Limited, Alfonso Global Limited, Allied Capital Global Limited, Alpine Fiduciaries SA, Anton Development Limited, Assets Sino Limited, Auspicious Coast Limited, Beijing Pangu Investment Co., Beijing Pangu Investment Co. Ltd., Beijing Pangu Investment Inc., Beijing Zenith Holdings Company Limited, Booming Sail New York LLC, Bravo Luck Limited, BSA Strategic Fund I, China Golden Spring (Hong Kong) Limited, Chuang Xin Limited, Crane Advisory Group LLC, Creative Apex Investments Limited, Crystal Breeze Investments Limited, Dawn State Limited, Eastern Profit Corporation Limited, Elite Well Global Limited, Empire Growth Holdings, Freedom Media Ventures Ltd., G Club Operations LLC, G Fashion LLC, G News LLC, GETTR USA, Genever Holdings Corporation, Genever Holdings LLC, Gfashion Media Group Inc., GFNY, Inc., Globalist International Limited, GNews Media Group Inc., Golden Spring (New York) Ltd., Greenwich Land LLC, Guo Media, GTV Media Group, Inc., Hamilton Capital Holdings Inc., HCHK Property Management, Inc., HCHK Technologies, Inc., Head Win Group Limited, Henan Yuda, Himalaya Embassy, Himalaya Exchange, Himalaya Federal Reserve, Himalaya Investment LLC, Himalaya International, Himalaya New World Inc., Himalaya Supervisory Organization, Himalaya Ventures LLC, HK International Funds Investments (USA) Limited LLC, Hong Kong International Funds\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 671 of 1063\n\nInvestments Limited, Hudson Diamond Holding, Infinite Increase Limited, Infinitum Developments Limited, Infinity Treasury Management Inc., Insight Phoenix Fund, Lamp Capital LLC, Leading Shine Limited, Leading Shine NY Limited, Lexington Property and Staffing, Long Gate Limited, Maywind Trading LLC, MOS Himalaya LLC, Next Tycoon Investments Limited, New Federal State of China (a/k/a NFSC), Noble Fame Global Limited, Rosy Acme Ventures Limited, Rule of Law Foundation III, Inc., Rule of Law Foundation IV, Inc., Rule of Law Fund, Rule of Law Society, Rule of Law Society IV, Inc., G-Translators PTY LTD, Saraca Media Group, Inc., Shiny Ace Ltd., Shiny Times Holdings Ltd., Spirit Charter Investment Limited, Stevenson, Wong & Co., Voice of Guo Media, Inc., Well Origin Ltd., World Century Limited, Worldwide Opportunity Holdings Limited, Whitecroft Shore Limited, and ZIBA Limited.\n\n9. \"Including\" or any variant thereof means \"including without limitation.\"\n\n10. \"And\" and \"or\" mean \"and/or,\" and shall be construed both conjunctively as well as disjunctively in order to maximize their scope.\n\n11. \"Any\" and \"all\" and \"each\" mean \"each and every.\"\n\n12. \"Each\" and \"every\" mean \"each and every.\"\n\n13. \"Third Party\" means a Person or Entity other than Yourself.\n\n14. \"Transfer\" shall have the meaning given to it by section 101(54) of the Bankruptcy Code.\n\n15. \"Document\" means any information or thing within the scope of Fed. R. Civ. P. 34, and includes, without limitation, each and every written, recorded, or graphic matter of any kind, type, nature, or description that is or has been in Your Possession, Custody or Control, including all printed and electronic copies of electronic mail, computer files maintained in\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 672 of 1063\n\nelectronic form, electronic communication, text message, social media post, tweet, meta-data, correspondence, memoranda, tapes, stenographic or handwritten notes, written forms of any kind, charts, blueprints, drawings, sketches, graphs, plans, articles, specifications, diaries, letters, telegrams, photographs, minutes, contracts, agreements, surveys, computer printouts, data compilations of any kind, telexes, facsimiles, voice messages, invoices, order forms, checks, drafts, statements, credit memos, reports, position reports, summaries, indices, books, ledgers, notebooks, schedules, transparencies, recordings, catalogs, advertisements, promotional materials, films, video tapes, audio tapes, CDs, computer disks, brochures, pamphlets, punchcards, time-slips, Tweets, social media posts, or any written or recorded materials of any other kind, and all meta-data thereof, however stored (whether in tangible or electronic form), recorded, produced, or reproduced, and also including but not limited to, drafts or copies of any of the foregoing that contain any notes, comments, or markings of any kind not found on the original documents or that are otherwise not identical to the original documents.\n\n16. \"Person(s)\" means an individual, corporation, proprietorship, partnership, association, or any other Entity. \"Person\" also includes any agent, representatives, or expert, including but not limiting to, attorneys or financial advisors.\n\n17. \"Entity\" means any natural Person, corporation, partnership, subsidiary, sole proprietorship, firm, board, joint venture, association, agency, authority, commission or other business entity or juristic Person, as well as any affiliate, agent, parent including but not limited to legal counsel, financial advisors, or any other representative.\n\n18. \"Regarding\" means concerning, describing, comprising, referring to, related to, supporting, favoring, opposing, bolstering, detracting from, located in, considered in connection with, bearing on, evidencing, indicating, reporting on, recording, alluding to, responding to,\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 673 of 1063\n\nconnected with, commenting on, in respect of, about, in relation to, discussing, showing, describing, reflecting, analyzing constituting, and being.\n\n19. \"Relating to,\" \"relate(s) to\" or \"related to,\" when referring to any given subject matter, means, without limitation, any document that constitutes, comprises, involves, contains, embodies, reflects, identifies, states, refers directly or indirectly to, or is in any way relevant to the particular subject matter identified.\n\n20. \"Communication(s)\" means, in the broadest possible sense, and without limitation, any transmittal of information or knowledge (in the form of facts, ideas, inquiries, or otherwise). Communication(s) further refers to all conversations, agreements, inquiries, or replies, whether in person, by telephone, in writing, or by means of electronic transmittal devices, and includes, but is not limited to, all correspondence, emails, recordings, transmittal slips, memoranda, telephone communications, voice messages, telegrams, telefaxes, telecopies, telexes, instant messages, chats, text messages, telephonic notes, or notes transmitted internally or with third parties.\n\n21. \"Asset(s)\" means any item that can be used to produce positive economic value, including but not limited to any resource with economic value that is owned, controlled or is for the benefit of an entity, that is expected to provide a future benefit, including but not limited to, all real and personal property, intangible property, investments, rights to invest or to future revenue, cash, bank accounts, commodities, securities, claims, total or partial control of an entity, and prospective economic opportunities\n\n22. \"Transfer\" shall have the meaning given to it by section 101(54) of the Bankruptcy Code.\n\n#### **IV. DOCUMENTS TO BE PRODUCED**\n\n1. All Documents regarding any income or Asset of the Debtor, the Debtor's estate, or an Associated Entity.\n\n2. All Documents related to the Debtor's financial condition and obligations to his creditors, including without limitation all Documents related to any effort to avoid paying such obligations and All Documents related to this or any other actual or potential bankruptcy or similar insolvency proceeding.\n\n3. All Documents regarding any balance sheet, bank statement, account statement, financial statement, statement of account, wire transfer instructions and/or confirmation, proof of funds, certificate of deposit, certificate of holdings, investment portfolio summary, or similar document relating to the Debtor, the Debtor's Estate, the Debtor's Family, an Associated Entity, or an Associated Individual, including without limitation all Documents sufficient to show all Transfers to any of the foregoing.\n\n4. All Documents regarding any investment, business dealing or transactions made by, with, or on behalf of the Debtor.\n\n5. All Communications with the Debtor, and Documents related to Communications with the Debtor, related to the operation, management, or decision-making of any Entity, including without limitation the Associated Entities.\n\n6. All Documents regarding any Transfer, investment, or other transaction or business dealing made to, by, or with the Debtor, the Debtor's Family, or an Associated Entity.\n\n7. All Documents regarding any property ever occupied or used by the Debtor, including without limitation the *Lady May*; the Sherry Netherland Hotel / Condominium; the\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 675 of 1063\n\nresidential property located in Greenwich, Connecticut at 373 Taconic Rd.; the residential property located in Greenwich, Connecticut at 33 Ferncliff Rd.; and the residential property located in Wilton, Connecticut at 354 Nod Hill Rd.\n\n8. All Documents related to any aircraft owned, controlled, or used by the Debtor, including without limitation the aircraft bearing tail number T7-GQM and any other aircraft registered in San Marino, including without limitation copies of all registration documents and flight manifests showing flights taken by such aircraft and the individuals onboard such flights.\n\n9. All Documents regarding any gifts, benefits or loans, to, from or on behalf of the Debtor, the Debtor's Estate, the Debtor's Family, or the Associated Entities, including without limitation Documents sufficient to show the amounts of such gifts, benefits, or loans; the purposes for which such gifts, benefits, or loans were used; when the gifts, benefits, or loans were provided; and the terms of any loans, all representations and warranties made in connection with any loans, the interest rate on any loans, and all evidence of payments of any loans.\n\n10. All Documents concerning any trust or similar instrument set up by, on behalf of, or for the benefit of the Debtor, the Debtor's Estate, the Debtor's Family, or an Associated Entity, including without limitation Documents sufficient to show when the trust(s) was created, by whom it was created, for whose benefit it was created, and the corpus of the trust.\n\n11. All Documents related to any obligation, claim, liability, or debt associated with any legal dispute involving the Debtor, including but not limited to those relating to any litigation before any local, state, federal, or international body, whether an administrative body, court, panel, or alternative dispute resolution entity.\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 676 of 1063\n\n12. All Documents and communications between any of your outside counsel or other advisors and the Debtor.\n\n13. All Documents related to any Associated Entity that You hold or have held an interest in.\n\n14. All Communications with the Debtor, and Documents related to Communications with the Debtor, related to the operation, management, or decision-making of any legal entity, including without limitation the Family Related Entities and the Associated Entities.\n\n# Exhibit C-37\n\n#### B2540 (Form 2540 – Subpoena for Rule 2004 Examination) (12/15) Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 678 of\n\n1063\n\nUNITED STATES BANKRUPTCY COURT\n\n**District of Connecticut**\n\nIn re HO WAN KWOK, *et al*.,\n\n<sup>1</sup> Case No. 22-50073 (JAM) Debtor Chapter 11\n\n(Jointly Administered)\n\n# **SUBPOENA FOR RULE 2004 EXAMINATION**\n\nTo: **Qing \"Serena\" Cai**\n\n(*Name of person to whom the subpoena is directed*)\n\n*Testimony:* **YOU ARE COMMANDED** to appear at the time, date, and place set forth below to testify at an examination under Rule 2004, Federal Rules of Bankruptcy Procedure. A copy of the court order authorizing the examination is attached.\n\n| PLACE                    | DATE AND TIME |\n|--------------------------|---------------|\n| Paul Hastings LLP        |               |\n| 200 Park Avenue          | [TBD]         |\n| New York, New York 10166 |               |\n|                          |               |\n\nThe examination will be recorded by this method: **Court reporter/stenographer**\n\n*Production:* You, or your representatives, must also bring with you to the examination the following documents, electronically stored information, or objects, and must permit inspection, copying, testing, or sampling of the material:\n\n#### **See Requests for Production of Documents, attached hereto.**\n\nThe following provisions of Fed. R. Civ. P. 45, made applicable in bankruptcy cases by Fed. R. Bankr. P. 9016, are attached – Rule 45(c), relating to the place of compliance; Rule 45(d), relating to your protection as a person subject to a subpoena; and Rule 45(e) and 45(g), relating to your duty to respond to this subpoena and the potential consequences of not doing so.\n\nDate: **March , 2023**\n\nCLERK OF COURT\n\nOR\n\n*Signature of Clerk or Deputy Clerk Attorney's signature*\n\nThe name, address, email address, and telephone number of the attorney representing Luc A. Despins, Chapter 11 Trustee, who issues or requests this subpoena, are:\n\n**Douglas S. Skalka, Esq.; Neubert, Pepe & Monteith, P.C.; 195 Church Street, New Haven, Connecticut 06510 dskalka@npmlaw.com; (203) 821-2000**\n\n**Notice to the person who issues or requests this subpoena**\n\nIf this subpoena commands the production of documents, electronically stored information, or tangible things, or the inspection of premises before trial, a notice and a copy of this subpoena must be served on each party before it is served on the person to whom it is directed. Fed. R. Civ. P. 45(a)(4).\n\nSoftware Copyright (c) 1996-2022 Best Case, LLC - www.bestcase.com Best Case Bankruptcy 1 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\n#### **PROOF OF SERVICE**\n\n**(This section should not be filed with the court unless required by Fed. R. Civ. P. 45.)**\n\nI received this subpoena for (*name of individual and title, if any*): on (*date*) .\n\nI served the subpoena by delivering a copy to the named person as follows:\n\non *(date)* ; or\n\nI returned the subpoena unexecuted because:\n\nUnless the subpoena was issued on behalf of the United States, or one of its officers or agents, I have also tendered to the witness the fees for one day's attendance, and the mileage allowed by law, in the amount of \\$ .\n\nMy fees are \\$ for travel and \\$ for services, for a total of \\$ .\n\nI declare under penalty of perjury that this information is true and correct.\n\nDate:\n\n*Server's signature*\n\n*Printed name and title*\n\n*Server's address*\n\nAdditional information concerning attempted service, etc.:\n\n#### **Federal Rule of Civil Procedure 45(c), (d), (e), and (g) (Effective 12/1/13) (made applicable in bankruptcy cases by Rule 9016, Federal Rules of Bankruptcy Procedure)**\n\n#### **(c) Place of compliance.**\n\n*(1) For a Trial, Hearing, or Deposition.* A subpoena may command a person to attend a trial, hearing, or deposition only as follows:\n\n(A) within 100 miles of where the person resides, is employed, or regularly transacts business in person; or\n\n(B) within the state where the person resides, is employed, or regularly transacts business in person, if the person\n\n(i) is a party or a party's officer; or\n\n(ii) is commanded to attend a trial and would not incur substantial expense.\n\n*(2) For Other Discovery.* A subpoena may command:\n\n(A) production of documents, or electronically stored information, or things at a place within 100 miles of where the person resides, is employed, or regularly transacts business in person; and\n\n(B) inspection of premises, at the premises to be inspected.\n\n#### **(d) Protecting a Person Subject to a Subpoena; Enforcement.**\n\n*(1) Avoiding Undue Burden or Expense; Sanctions.* A party or attorney responsible for issuing and serving a subpoena must take reasonable steps to avoid imposing undue burden or expense on a person subject to the subpoena. The court for the district where compliance is required must enforce this duty and impose an appropriate sanction which may include lost earnings and reasonable attorney's fees — on a party or attorney who fails to comply.\n\n#### *(2) Command to Produce Materials or Permit Inspection.*\n\n*(A) Appearance Not Required.* A person commanded to produce documents, electronically stored information, or tangible things, or to permit the inspection of premises, need not appear in person at the place of production or inspection unless also commanded to appear for a deposition, hearing, or trial.\n\n*(B) Objections.* A person commanded to produce documents or tangible things or to permit inspection may serve on the party or attorney designated in the subpoena a written objection to inspecting, copying, testing or sampling any or all of the materials or to inspecting the premises — or to producing electronically stored information in the form or forms requested. The objection must be served before the earlier of the time specified for compliance or 14 days after the subpoena is served. If an objection is made, the following rules apply:\n\n(i) At any time, on notice to the commanded person, the serving party may move the court for the district where compliance is required for an order compelling production or inspection.\n\n(ii) These acts may be required only as directed in the order, and the order must protect a person who is neither a party nor a party's officer from significant expense resulting from compliance.\n\n#### *(3) Quashing or Modifying a Subpoena.*\n\n*(A) When Required.* On timely motion, the court for the district where compliance is required must quash or modify a subpoena that:\n\n(i) fails to allow a reasonable time to comply;\n\n(ii) requires a person to comply beyond the geographical limits specified in Rule 45(c);\n\n(iii) requires disclosure of privileged or other protected matter, if no exception or waiver applies; or\n\n(iv) subjects a person to undue burden.\n\n*(B) When Permitted.* To protect a person subject to or affected by a subpoena, the court for the district where compliance is required may, on motion, quash or modify the subpoena if it requires:\n\n(i) disclosing a trade secret or other confidential research, development, or commercial information; or\n\n(ii) disclosing an unretained expert's opinion or information that does not describe specific occurrences in dispute and results from the expert's study that was not requested by a party.\n\n(C) *Specifying Conditions as an Alternative.* In the circumstances described in Rule 45(d)(3)(B), the court may, instead of quashing or modifying a subpoena, order appearance or production under specified conditions if the serving party:\n\n(i) shows a substantial need for the testimony or material that cannot be otherwise met without undue hardship; and\n\n(ii) ensures that the subpoenaed person will be reasonably compensated.\n\n#### **(e) Duties in Responding to a Subpoena.**\n\n*(1) Producing Documents or Electronically Stored Information.* These procedures apply to producing documents or electronically stored information:\n\n*(A) Documents.* A person responding to a subpoena to produce documents must produce them as they are kept in the ordinary course of business or must organize and label them to correspond to the categories in the demand.\n\n*(B) Form for Producing Electronically Stored Information Not Specified.* If a subpoena does not specify a form for producing electronically stored information, the person responding must produce it in a form or forms in which it is ordinarily maintained or in a reasonably usable form or forms.\n\n*(C) Electronically Stored Information Produced in Only One Form.* The person responding need not produce the same electronically stored information in more than one form.\n\n*(D) Inaccessible Electronically Stored Information.* The person responding need not provide discovery of electronically stored information from sources that the person identifies as not reasonably accessible because of undue burden or cost. On motion to compel discovery or for a protective order, the person responding must show that the information is not reasonably accessible because of undue burden or cost. If that showing is made, the court may nonetheless order discovery from such sources if the requesting party shows good cause, considering the limitations of Rule 26(b)(2)(C). The court may specify conditions for the discovery.\n\n#### *(2) Claiming Privilege or Protection.*\n\n*(A) Information Withheld.* A person withholding subpoenaed information under a claim that it is privileged or subject to protection as trial-preparation material must: (i) expressly make the claim; and\n\n(ii) describe the nature of the withheld documents, communications, or tangible things in a manner that, without revealing information itself privileged or protected, will enable the parties to assess the claim.\n\n*(B) Information Produced.* If information produced in response to a subpoena is subject to a claim of privilege or of protection as trial-preparation material, the person making the claim may notify any party that received the information of the claim and the basis for it. After being notified, a party must promptly return, sequester, or destroy the specified information and any copies it has; must not use or disclose the information until the claim is resolved; must take reasonable steps to retrieve the information if the party disclosed it before being notified; and may promptly present the information under seal to the court for the district where compliance is required for a determination of the claim. The person who produced the information must preserve the information until the claim is resolved.\n\n**(g) Contempt.** The court for the district where compliance is required – and also, after a motion is transferred, the issuing court – may hold in contempt a person who, having been served, fails without adequate excuse to obey the subpoena or an order related to it.\n\nFor access to subpoena materials, see Fed.R.Civ.P.45(a) Committee Note (2013)\n\n…\n\n## **Requests for Production of Documents**\n\n## **I. INSTRUCTIONS**\n\n1. Unless otherwise indicated, the requests for documents set forth below, (the \"Requests,\" and each, a \"Request\"), must be responded to separately and specifically. Each Request shall be answered fully unless it is in good faith objected to, in which event the reason for Your objection shall be stated in detail, as set forth below. If an objection pertains only to a portion of a Request, or a word, phrase or clause contained within it, You are required to state Your objection to that portion only and to respond to the remainder of the Requests.\n\n2. Electronically stored information must be produced in accordance with the\n\nfollowing instructions:\n\n- a. Images. Black and white images must be 300 DPI Group IV single-page TIFF files. Color images must be produced in JPEG format. File names cannot contain embedded spaces or special characters (including the comma). Folder names cannot contain embedded spaces or special characters (including the comma). All TIFF image files must have a unique file name, i.e. Bates number. Images must be endorsed with sequential Bates numbers in the lower right corner of each image. The number of TIFF files per folder should not exceed 1000 files. Excel spreadsheets should have a placeholder image named by the Bates number of the file.\n- b. Image Load File\n\t- a. Concordance® Data File. The data file (.DAT) contains all of the fielded information that will be loaded into the Concordance® database. The first line of the .DAT file must be a header row identifying the field names. The .DAT file must use the following Concordance® default delimiters: Comma ASCII character (020) Quote þ ASCII character (254). Date fields should be provided in the format: mm/dd/yyyy. Date and time fields must be two separate fields. If documents includes imaged emails and attachments, the attachment fields must be included to preserve the parent/child relationship between an email and its attachments. An OCRPATH field must be included to provide the file path and name of the extracted text file on the produced storage media. The text file must be named after the FIRSTBATES. Do not include the text in the .DAT file. For Documents with native files, a LINK field must be included to provide the file path and\n\nname of the native file. The native file must be named after the FIRSTBATES.\n\n- b. Concordance Image® OR Opticon Cross-Reference File. The image crossreference file (.LOG or .OPT) links the images to the database records. It should be a comma-delimited file consisting of seven fields per line with a line in the cross-reference file for every image in the database with the following format: ImageID,VolumeLabel,ImageFilePath,DocumentBreak,FolderBreak,Box Break,PageCoun.\n- c. Document Text. Text must be produced as separate text files, not as fields within the .DAT file. The full path to the text file (OCRPATH) should be included in the .DAT file. It is recommended document level ANSI text files, named per the FIRSTBATES/Image Key. Extracted text files must be in a separate folder, and the number of text files per folder should not exceed 1,000 files. There should be no special characters (including commas in the folder names). Text files must be provided on a document level.\n- d. Native Production for Certain File Types. File types that reasonably require viewing in their native format for a full understanding of their content and meaning must be produced in native format. These include, but are not limited to, spreadsheets, spreadsheet-like files (Microsoft Excel, comma separated values, tab separated values, etc.), Microsoft PowerPoint or other special presentation files, database files, and audio/visual files. Provide an image of a Bates numbered slip sheet indicating the presence of a native file, and include the path to the native as a field in the .dat file. Name the produced native file with the Bates number corresponding to the slip sheet for the file. Group native files within incrementally named \"NATIVE\" directories, separate from images directories.\n- e. De-duplication. Produce a single copy of each electronic document for which exact duplicates exist. For email messages, consolidate duplicates based on MD5 hash generated from the BCC, Body, CC, From, IntMsgID, To, and Attach properties. For email attachments and standalone electronic files, consolidate duplicates based on MD5 hash of the entire file.\n- f. Metadata. Produce extracted metadata for each document in the form of a Concordance compliant load file (.dat). The first line of the .DAT file must be a header row identifying the field names. The .DAT file must use the following Concordance default delimiters: Comma , ASCII character (020) Quote þ ASCII character (254)\n\nDate fields should be provided in the format: mm/dd/yyyy. Date and time fields must be two separate fields. Required metadata listed below:\n\n# Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 683 of 1063\n\n| Field Name   | Sample Data              | Description                                                                                  |\n|--------------|--------------------------|----------------------------------------------------------------------------------------------|\n| FIRSTBATES   | EDC0000001               | First Bates number of native file document/email                                             |\n| LASTBATES    | EDC0000001               | Last Bates number of native file document/email<br>**The LASTBATES field should be populated |\n|              |                          | for single page                                                                              |\n| ATTACHRANGE  | EDC0000001<br>-          | Bates number of the first page of the parent                                                 |\n|              | EDC0000015               | document to the Bates number of the last page of                                             |\n|              |                          | the last attachment \"child\" document                                                         |\n| BEGATTACH    | EDC0000001               | First Bates number of attachment range                                                       |\n| ENDATTACH    | EDC0000015               | Last Bates number of attachment range                                                        |\n| CUSTODIAN    | Smith, John              | Email: Mailbox where the email resided                                                       |\n|              |                          | Native: Name of the individual or department                                                 |\n|              |                          | from whose files the document<br>originated                                                  |\n| FROM         | John Smith               | Email: Sender                                                                                |\n|              |                          | Native: Author(s) of document                                                                |\n|              |                          | **semi-colon should be used to separate                                                      |\n|              |                          | multiple entries                                                                             |\n| TO           | Coffman, Janice; LeeW    | Recipient(s)                                                                                 |\n|              | [mailto:LeeW@MSN.com]    | **semi-colon should be used to separate multiple                                             |\n|              |                          | entries                                                                                      |\n| CC           | Frank Thompson [mailto:  | Carbon copy recipient(s)                                                                     |\n|              | frank_Thompson@cdt.com]  | **semi-colon should be used to separate                                                      |\n|              |                          | multiple entries                                                                             |\n| BCC          | John Cain                | Blind carbon copy recipient(s)                                                               |\n|              |                          | **semi-colon should be used to separate                                                      |\n|              |                          | multiple entries                                                                             |\n| SUBJECT      | Board Meeting Minutes    | Email: Subject line of the email Native: Title                                               |\n|              |                          | of document (if available)                                                                   |\n| FILE_NAME    | BoardMeetingMinutes.docx | Native: Name of the original native file,                                                    |\n|              |                          | including extension                                                                          |\n| DATE_SENT    | 10/12/2010               | Email: Date the email was sent                                                               |\n|              |                          | Native: (empty)                                                                              |\n| TIME_SENT/   | 07:05 PM GMT             | Email: Time the email was sent/ Time zone in                                                 |\n| TIME_ZONE    |                          | which the emails were standardized                                                           |\n| TIME_ZONE    | GMT                      | The<br>time zone in which<br>the emails<br>were                                              |\n|              |                          | standardized during conversion.                                                              |\n| LINK         |  EDC0000001.msg   | Hyperlink to the email or native file document                                               |\n|              |                          | **The linked file must be named per the                                                      |\n|              |                          | FIRSTBATES number                                                                            |\n| FILE_EXTEN   | MSG                      | The file type extension                                                                      |\n|              |                          | representing                                                                                 |\n|              |                          | the Email or                                                                                 |\n| AUTHOR       | John Smith               | Email: (empty)                                                                               |\n|              |                          | Native: Author of the document                                                               |\n| DATE_CREATED | 10/10/2010               | Email: (empty)                                                                               |\n|              |                          | Native: Date the document was created                                                        |\n\n# Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 684 of 1063\n\n| TIME_CREATED | 10:25 AM                  | Email: (empty)                                  |\n|--------------|---------------------------|-------------------------------------------------|\n|              |                           | Native: Time the document was created           |\n|              |                           | **This data must be a separate field and cannot |\n|              |                           | be combined with the DATE_CREATED field         |\n| DATE_MOD     | 10/12/2010                | Email: (empty)                                  |\n|              |                           | Native: Date the document was last modified     |\n| TIME_MOD     | 07:00 PM                  | Email: (empty)                                  |\n|              |                           | Native: Time the document was last modified     |\n|              |                           | **This data must be a separate field and cannot |\n|              |                           | be combined with the DATE_MOD field             |\n| DATE_ACCESSD | 10/12/2010                | Email: (empty)                                  |\n|              |                           | Native: Date the document was last accessed     |\n| TIME_ACCESSD | 07:00 PM                  | Email: (empty)                                  |\n|              |                           | Native: Time the document was last accessed     |\n|              |                           | **This data must be a separate field and cannot |\n|              |                           | be combined with the DATE_ACCESSD field         |\n| FILE_SIZE    | 5,952                     | Size of native file<br>document/email in KB     |\n| PGCOUNT      | 1                         | Number of pages in native file document/email   |\n| PATH         |   | Email: (empty)                                  |\n|              | Agenda.doc                | Native: Path where native file document was     |\n|              |                           | stored including original file name.            |\n| INTFILEPATH  | Personal Folders\\Deleted  | Email: original location of email including     |\n|              | Items\\Board Meeting       | original file name.                             |\n|              | Minutes.msg               | Native: (empty)                                 |\n| INTMSGID     | <000805c2c71b\\$75977050\\$ | Email: Unique Message ID Native: (empty)        |\n|              | cb8306d1@MSN>             |                                                 |\n| MD5HASH      | d131dd02c5e6eec4693d9a0   | MD5 Hash value of the document.                 |\n|              | 698aff95c                 |                                                 |\n|              | 2fcab58712467eab4004583e  |                                                 |\n|              | b8fb7f89                  |                                                 |\n| OCRPATH      | TEXT/001/EDC0000001.txt   | Path to extracted text of the native file       |\n\n3. Each Request operates and should be construed independently and, unless otherwise indicated, no Request limits the scope of any other Request.\n\n4. All Documents are to be produced as kept in the usual course of business or are to be organized and labeled to correspond with the categories in these Requests.\n\n5. Each Request contained herein extends to all Documents: (a) in Your possession, custody, or control; or (b) in the possession, custody, or control of anyone acting on Your behalf,\n\n#### Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 685 of 1063\n\nincluding Your counsel or other representatives and advisors. Each Document shall be produced in its entirety.\n\n6. If You are requested to produce a Document that is no longer in Your possession, custody, or control, then Your response must (a) describe in detail the nature of the document and its contents; (b) identify the person(s) who prepared or authored the Document (and, if applicable, the Person(s) to whom the Document was sent); (c) identify the date on which the document was prepared or created; (d) state whether such Document (i) is missing or lost, (ii) has been destroyed, (iii) has been transferred, voluntarily or involuntarily, to others, or (iv) was otherwise disposed of; (e) state the reason for, and the facts and circumstances surrounding, such disposition; (f) identify the Persons who authorized such disposition; (g) identify the date or approximate date of such disposition; (h) state when the Document was most recently in Your possession, custody or control; and (i) identify the Person, if any, presently in possession, custody, or control of such Document.\n\n7. If You are requested to produce a Document that has been destroyed, then Your response must state, in addition to the information required by the preceding Instruction: (a) the reason for the Document's destruction; (b) the identity of the Person who destroyed the Document; and (c) the identity of the Person who directed that the Document be destroyed.\n\n8. If You claim that a requested Document is privileged or attorney work-product, then Your response must: (a) state (i) a description of the Document adequate to support Your contention that the Document is privileged, (ii) the title of the Document, (iii) the date of the Document, (iv) the author of the Document, (v) the addressee of the Document, (vi) the identity of each Person who received or saw the original or any draft, copy, or reproduction of the Document, (vii) whether the Document itself, or any information contained or referred to in the Document is in the possession, custody, or control of any other Persons, and if so, the identity of\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 686 of 1063\n\nsuch Persons, as well as a statement addressing how the information came into their possession, (viii) the claim of privilege under which the Document is withheld, and (ix) all of the circumstances upon which You will rely to support such claim of privilege; and (b) produce a privilege log containing all of the information requested in Part (a) of this Instruction for each Document withheld on the basis of a claim of privilege in accordance with D. Conn. L. Civ. R. 26(e).\n\n9. If a portion of an otherwise responsive Document contains information subject to a claim of privilege, only that portion of the Document subject to the claim of privilege shall be deleted or redacted from the Document following the instructions above, and the rest shall be produced.\n\n10. The Requests are continuing in nature. You are hereby instructed to (a) supplement or correct any responses later learned to be incomplete or incorrect immediately upon learning that a prior response was incomplete or incorrect; and (b) produce any additional Documents that are called for under the\n\n11. If a Document is in a language other than English, You should provide that Document. If a Document is in a language other than English, and an English translation exists, You should provide both Documents.\n\n12. All references to Entities includes all affiliates thereof.\n\n13. All references to individual names include all alternative names, aliased, or nicknames.\n\n14. Unless otherwise expressly indicated, the period of time covered by the Document Requests is the period from February 5, 2012 to the date responses to the Document Requests are due.\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 687 of 1063\n\n#### **II. RULES OF CONSTRUCTION**\n\n15. The use of (a) any singular noun shall be construed to include the plural, and vice versa, and (b) a verb in any tense shall be construed as the use of the verb in all other tenses.\n\n16. The terms (a) \"and\" and \"or\" shall be construed either conjunctively or disjunctively as necessary to bring within the scope of any request all responses that might otherwise be construed to be outside of its scope, and (b) \"each\" and \"any\" shall be deemed to include and encompass the words \"every\" and \"all.\"\n\n#### **III. DEFINITIONS**\n\nThe definitions supplied by D. Conn. L. Civ. R. 26(c) and the rules of construction supplied by D. Conn. L. Civ. R. 26(d), as incorporated by D. Conn. Bankr. L.R. 2004-1(a), shall apply to the Document Requests. In addition, the following terms used in these Document Requests shall have the following meanings:\n\n1. \"You\" or \"Your\" or \"Yourself\" means and refers to Qing \"Serena\" Cai, together with all of her agents, attorneys, representatives, employees, and/or anyone acting on her behalf.\n\n2. \"Debtor\" means Ho Wan Kwok (a/k/a Miles Kwok, Miles Guo, Guo Wengui, Guo Haoyun, 郭文贵, or any other alias), together with his employees, agents, counsel, advisors, or anyone acting on his behalf.\n\n3. \"Debtor's Son\" means Qiang Guo (a/k/a Mileson Kwok, 郭强, or any other alias), together with his employees, agents, counsel, advisors, or anyone acting on his behalf.\n\n4. \"Debtor's Daughter\" means Mei Guo (a/k/a Mei Gui, 郭美, or any other alias), together with her employees, agents, counsel, advisors, or anyone acting on her behalf.\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 688 of 1063\n\n5. \"Debtor's Purported Wife\" means Hing Chi Ngok (a/k/a Hing Chi Ng, Yue Qingzhi, 岳庆芝, or any other alias), together with her employees, agents, counsel, advisors, or anyone acting on her behalf.\n\n6. \"Debtor's Family\" means, collectively, the Debtor, the Debtor's Son, the Debtor's Daughter, and the Debtor's Purported Wife, and any other familial relation to the Debtor.\n\n7. \"Associated Individuals\" means, individually and collectively, all individuals that (1) hold, control, have custody over, or discretion over assets owned, controlled, or enjoyed by the Debtor or the Debtor's Family; or (2) have been employees, directors, or otherwise are affiliated with one or more Associated Entities, together with the respective employees, agents, counsel, advisors, or anyone acting on behalf of any of the foregoing. Such Associated Individuals shall include, but are not limited to: Daniel Podhaskie, Jason Miller, Steve Bannon, Karin Maistrello, Melissa Francis, Anthony DiBattista, William Gertz, Arethusa Forsyth, Glenn Mellor, Jennifer Mercurio, Eduardo Eurnekian, Wencong Wang, Han Chunguang (a/k/a 韩春光), Qu Guojiao (a/k/a Qu Guo Jiao, 屈国姣), Guo Lijie (a/k/a 郭丽杰), Zhang Wei (a/k/a 张伟\\*), Lihong Wei Lafrenz (a/k/a Sara Wei, 魏丽红), Hao Haidong (a/k/a 郝海东), Ross Heinemeyer, Max Krasner, Kyle Bass, Melissa Mendez, Ya Li (a/k/a 李娅), Dinggang Wang (a/k/a 王定刚), An Hong (a/k/a 安红), Yvette Wang (a/k/a Yanping Wang, Yan Ping Wang, 王雁平), Fiona Yu, Je Kin Ming (a/k/a William Je, Yu Jianming, 余建明), Yaz Qingua, and Lao Jiang (a/k/a Jiang Yunfu, Jiang Yunfu Be, 姜云浮).\n\n8. \"Associated Entities\" means, individually and collectively, all organizations or Entities of any type that (1) have been owned, controlled, or invested in by the Debtor or the\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 689 of 1063\n\nDebtor's Family; or (2) have an interest, whether directly or indirectly, in any assets owned, controlled, or enjoyed by the Debtor or the Debtor's Family, together with the respective employees, agents, counsel, advisors, or anyone acting on behalf of any of the foregoing. Such Associated Entities shall include, but are not limited to: 7 Nod Hill LLC, AAGV Limited, ACA Investment Management Limited, ACA Capital Group Limited, Ace Decade Holdings Limited, AI Group Holdings Inc., Alfa Global Ventures Limited, Alfonso Global Limited, Allied Capital Global Limited, Alpine Fiduciaries SA, Anton Development Limited, Assets Sino Limited, Auspicious Coast Limited, Beijing Pangu Investment Co., Beijing Pangu Investment Co. Ltd., Beijing Pangu Investment Inc., Beijing Zenith Holdings Company Limited, Booming Sail New York LLC, Bravo Luck Limited, BSA Strategic Fund I, China Golden Spring (Hong Kong) Limited, Chuang Xin Limited, Crane Advisory Group LLC, Creative Apex Investments Limited, Crystal Breeze Investments Limited, Dawn State Limited, Eastern Profit Corporation Limited, Elite Well Global Limited, Empire Growth Holdings, Freedom Media Ventures Ltd., G Club Operations LLC, G Fashion LLC, G News LLC, GETTR USA, Genever Holdings Corporation, Genever Holdings LLC, Gfashion Media Group Inc., GFNY, Inc., Globalist International Limited, GNews Media Group Inc., Golden Spring (New York) Ltd., Greenwich Land LLC, Guo Media, GTV Media Group, Inc., Hamilton Capital Holdings Inc., HCHK Property Management, Inc., HCHK Technologies, Inc., Head Win Group Limited, Henan Yuda, Himalaya Embassy, Himalaya Exchange, Himalaya Federal Reserve, Himalaya Investment LLC, Himalaya International, Himalaya New World Inc., Himalaya Supervisory Organization, Himalaya Ventures LLC, HK International Funds Investments (USA) Limited LLC, Hong Kong International Funds Investments Limited, Hudson Diamond Holding, Infinite Increase Limited, Infinitum Developments Limited, Infinity Treasury Management Inc., Insight Phoenix Fund, Lamp Capital\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 690 of 1063\n\nLLC, Leading Shine Limited, Leading Shine NY Limited, Lexington Property and Staffing, Long Gate Limited, Maywind Trading LLC, MOS Himalaya LLC, Next Tycoon Investments Limited, New Federal State of China (a/k/a NFSC), Noble Fame Global Limited, Rosy Acme Ventures Limited, Rule of Law Foundation III, Inc., Rule of Law Foundation IV, Inc., Rule of Law Fund, Rule of Law Society, Rule of Law Society IV, Inc., G-Translators PTY LTD, Saraca Media Group, Inc., Shiny Ace Ltd., Shiny Times Holdings Ltd., Spirit Charter Investment Limited, Stevenson, Wong & Co., Voice of Guo Media, Inc., Well Origin Ltd., World Century Limited, Worldwide Opportunity Holdings Limited, Whitecroft Shore Limited, and ZIBA Limited.\n\n9. \"Including\" or any variant thereof means \"including without limitation.\"\n\n10. \"And\" and \"or\" mean \"and/or,\" and shall be construed both conjunctively as well as disjunctively in order to maximize their scope.\n\n11. \"Any\" and \"all\" and \"each\" mean \"each and every.\"\n\n12. \"Each\" and \"every\" mean \"each and every.\"\n\n13. \"Third Party\" means a Person or Entity other than Yourself.\n\n14. \"Transfer\" shall have the meaning given to it by section 101(54) of the Bankruptcy Code.\n\n15. \"Document\" means any information or thing within the scope of Fed. R. Civ. P. 34, and includes, without limitation, each and every written, recorded, or graphic matter of any kind, type, nature, or description that is or has been in Your Possession, Custody or Control, including all printed and electronic copies of electronic mail, computer files maintained in electronic form, electronic communication, text message, social media post, tweet, meta-data, correspondence, memoranda, tapes, stenographic or handwritten notes, written forms of any\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 691 of 1063\n\nkind, charts, blueprints, drawings, sketches, graphs, plans, articles, specifications, diaries, letters, telegrams, photographs, minutes, contracts, agreements, surveys, computer printouts, data compilations of any kind, telexes, facsimiles, voice messages, invoices, order forms, checks, drafts, statements, credit memos, reports, position reports, summaries, indices, books, ledgers, notebooks, schedules, transparencies, recordings, catalogs, advertisements, promotional materials, films, video tapes, audio tapes, CDs, computer disks, brochures, pamphlets, punchcards, time-slips, Tweets, social media posts, or any written or recorded materials of any other kind, and all meta-data thereof, however stored (whether in tangible or electronic form), recorded, produced, or reproduced, and also including but not limited to, drafts or copies of any of the foregoing that contain any notes, comments, or markings of any kind not found on the original documents or that are otherwise not identical to the original documents.\n\n16. \"Person(s)\" means an individual, corporation, proprietorship, partnership, association, or any other Entity. \"Person\" also includes any agent, representatives, or expert, including but not limiting to, attorneys or financial advisors.\n\n17. \"Entity\" means any natural Person, corporation, partnership, subsidiary, sole proprietorship, firm, board, joint venture, association, agency, authority, commission or other business entity or juristic Person, as well as any affiliate, agent, parent including but not limited to legal counsel, financial advisors, or any other representative.\n\n18. \"Regarding\" means concerning, describing, comprising, referring to, related to, supporting, favoring, opposing, bolstering, detracting from, located in, considered in connection with, bearing on, evidencing, indicating, reporting on, recording, alluding to, responding to, connected with, commenting on, in respect of, about, in relation to, discussing, showing, describing, reflecting, analyzing constituting, and being.\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 692 of 1063\n\n19. \"Relating to,\" \"relate(s) to\" or \"related to,\" when referring to any given subject matter, means, without limitation, any document that constitutes, comprises, involves, contains, embodies, reflects, identifies, states, refers directly or indirectly to, or is in any way relevant to the particular subject matter identified.\n\n20. \"Communication(s)\" means, in the broadest possible sense, and without limitation, any transmittal of information or knowledge (in the form of facts, ideas, inquiries, or otherwise). Communication(s) further refers to all conversations, agreements, inquiries, or replies, whether in person, by telephone, in writing, or by means of electronic transmittal devices, and includes, but is not limited to, all correspondence, emails, recordings, transmittal slips, memoranda, telephone communications, voice messages, telegrams, telefaxes, telecopies, telexes, instant messages, chats, text messages, telephonic notes, or notes transmitted internally or with third parties.\n\n21. \"Asset(s)\" means any item that can be used to produce positive economic value, including but not limited to any resource with economic value that is owned, controlled or is for the benefit of an entity, that is expected to provide a future benefit, including but not limited to, all real and personal property, intangible property, investments, rights to invest or to future revenue, cash, bank accounts, commodities, securities, claims, total or partial control of an entity, and prospective economic opportunities\n\n22. \"Transfer\" shall have the meaning given to it by section 101(54) of the Bankruptcy Code.\n\n## **IV. DOCUMENTS TO BE PRODUCED**\n\n1. All Documents regarding any income or Asset of the Debtor, the Debtor's estate, or an Associated Entity.\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 693 of 1063\n\n2. All Documents related to the Debtor's financial condition and obligations to his creditors, including without limitation all Documents related to any effort to avoid paying such obligations and All Documents related to this or any other actual or potential bankruptcy or similar insolvency proceeding.\n\n3. All Documents regarding any balance sheet, bank statement, account statement, financial statement, statement of account, wire transfer instructions and/or confirmation, proof of funds, certificate of deposit, certificate of holdings, investment portfolio summary, or similar document relating to the Debtor, the Debtor's Estate, the Debtor's Family, an Associated Entity, or an Associated Individual, including without limitation all Documents sufficient to show all Transfers to any of the foregoing.\n\n4. All Documents regarding any investment, business dealing or transactions made by, with, or on behalf of the Debtor.\n\n5. All Communications with the Debtor, and Documents related to Communications with the Debtor, related to the operation, management, or decision-making of any Entity, including without limitation the Associated Entities.\n\n6. All Documents regarding any Transfer, investment, or other transaction or business dealing made to, by, or with the Debtor, the Debtor's Family, or an Associated Entity.\n\n7. All Documents regarding any property ever occupied or used by the Debtor, including without limitation the *Lady May*; the Sherry Netherland Hotel / Condominium; the residential property located in Greenwich, Connecticut at 373 Taconic Rd.; the residential property located in Greenwich, Connecticut at 33 Ferncliff Rd.; and the residential property located in Wilton, Connecticut at 354 Nod Hill Rd.\n\n#### Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 694 of 1063\n\n8. All Documents related to any aircraft owned, controlled, or used by the Debtor, including without limitation the aircraft bearing tail number T7-GQM and any other aircraft registered in San Marino, including without limitation copies of all registration documents and flight manifests showing flights taken by such aircraft and the individuals onboard such flights.\n\n9. All Documents regarding any gifts, benefits or loans, to, from or on behalf of the Debtor, the Debtor's Estate, the Debtor's Family, or the Associated Entities, including without limitation Documents sufficient to show the amounts of such gifts, benefits, or loans; the purposes for which such gifts, benefits, or loans were used; when the gifts, benefits, or loans were provided; and the terms of any loans, all representations and warranties made in connection with any loans, the interest rate on any loans, and all evidence of payments of any loans.\n\n10. All Documents concerning any trust or similar instrument set up by, on behalf of, or for the benefit of the Debtor, the Debtor's Estate, the Debtor's Family, or an Associated Entity, including without limitation Documents sufficient to show when the trust(s) was created, by whom it was created, for whose benefit it was created, and the corpus of the trust.\n\n11. All Documents related to any obligation, claim, liability, or debt associated with any legal dispute involving the Debtor, including but not limited to those relating to any litigation before any local, state, federal, or international body, whether an administrative body, court, panel, or alternative dispute resolution entity.\n\n12. All Documents and communications between any of your outside counsel or other advisors and the Debtor.\n\n13. All Documents related to any Associated Entity that You hold or have held an interest in.\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 695 of 1063\n\n14. All Communications with the Debtor, and Documents related to Communications with the Debtor, related to the operation, management, or decision-making of any legal entity, including without limitation the Family Related Entities and the Associated Entities.\n\n# Exhibit C-38\n\n#### B2540 (Form 2540 – Subpoena for Rule 2004 Examination) (12/15) Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 697 of\n\n1063\n\nUNITED STATES BANKRUPTCY COURT\n\n**District of Connecticut**\n\nIn re HO WAN KWOK, *et al*.,\n\n<sup>1</sup> Case No. 22-50073 (JAM) Debtor Chapter 11\n\n(Jointly Administered)\n\n# **SUBPOENA FOR RULE 2004 EXAMINATION**\n\nTo: **Ding G. Wang a/k/a Dinggang Wang**\n\n(*Name of person to whom the subpoena is directed*)\n\n*Testimony:* **YOU ARE COMMANDED** to appear at the time, date, and place set forth below to testify at an examination under Rule 2004, Federal Rules of Bankruptcy Procedure. A copy of the court order authorizing the examination is attached.\n\n| PLACE                    | DATE AND TIME |\n|--------------------------|---------------|\n| Paul Hastings LLP        |               |\n| 200 Park Avenue          | [TBD]         |\n| New York, New York 10166 |               |\n|                          |               |\n\nThe examination will be recorded by this method: **Court reporter/stenographer**\n\n*Production:* You, or your representatives, must also bring with you to the examination the following documents, electronically stored information, or objects, and must permit inspection, copying, testing, or sampling of the material:\n\n#### **See Requests for Production of Documents, attached hereto.**\n\nThe following provisions of Fed. R. Civ. P. 45, made applicable in bankruptcy cases by Fed. R. Bankr. P. 9016, are attached – Rule 45(c), relating to the place of compliance; Rule 45(d), relating to your protection as a person subject to a subpoena; and Rule 45(e) and 45(g), relating to your duty to respond to this subpoena and the potential consequences of not doing so.\n\nDate: **March , 2023**\n\nCLERK OF COURT\n\nOR\n\n*Signature of Clerk or Deputy Clerk Attorney's signature*\n\nThe name, address, email address, and telephone number of the attorney representing Luc A. Despins, Chapter 11 Trustee, who issues or requests this subpoena, are:\n\n**Douglas S. Skalka, Esq.; Neubert, Pepe & Monteith, P.C.; 195 Church Street, New Haven, Connecticut 06510 dskalka@npmlaw.com; (203) 821-2000**\n\n**Notice to the person who issues or requests this subpoena**\n\nIf this subpoena commands the production of documents, electronically stored information, or tangible things, or the inspection of premises before trial, a notice and a copy of this subpoena must be served on each party before it is served on the person to whom it is directed. Fed. R. Civ. P. 45(a)(4).\n\nSoftware Copyright (c) 1996-2022 Best Case, LLC - www.bestcase.com Best Case Bankruptcy 1 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\n#### **PROOF OF SERVICE**\n\n**(This section should not be filed with the court unless required by Fed. R. Civ. P. 45.)**\n\nI received this subpoena for (*name of individual and title, if any*): on (*date*) .\n\nI served the subpoena by delivering a copy to the named person as follows:\n\non *(date)* ; or\n\nI returned the subpoena unexecuted because:\n\nUnless the subpoena was issued on behalf of the United States, or one of its officers or agents, I have also tendered to the witness the fees for one day's attendance, and the mileage allowed by law, in the amount of \\$ .\n\nMy fees are \\$ for travel and \\$ for services, for a total of \\$ .\n\nI declare under penalty of perjury that this information is true and correct.\n\nDate:\n\n*Server's signature*\n\n*Printed name and title*\n\n*Server's address*\n\nAdditional information concerning attempted service, etc.:\n\n#### **Federal Rule of Civil Procedure 45(c), (d), (e), and (g) (Effective 12/1/13) (made applicable in bankruptcy cases by Rule 9016, Federal Rules of Bankruptcy Procedure)**\n\n#### **(c) Place of compliance.**\n\n*(1) For a Trial, Hearing, or Deposition.* A subpoena may command a person to attend a trial, hearing, or deposition only as follows:\n\n(A) within 100 miles of where the person resides, is employed, or regularly transacts business in person; or\n\n(B) within the state where the person resides, is employed, or regularly transacts business in person, if the person\n\n(i) is a party or a party's officer; or\n\n(ii) is commanded to attend a trial and would not incur substantial expense.\n\n*(2) For Other Discovery.* A subpoena may command:\n\n(A) production of documents, or electronically stored information, or things at a place within 100 miles of where the person resides, is employed, or regularly transacts business in person; and\n\n(B) inspection of premises, at the premises to be inspected.\n\n#### **(d) Protecting a Person Subject to a Subpoena; Enforcement.**\n\n*(1) Avoiding Undue Burden or Expense; Sanctions.* A party or attorney responsible for issuing and serving a subpoena must take reasonable steps to avoid imposing undue burden or expense on a person subject to the subpoena. The court for the district where compliance is required must enforce this duty and impose an appropriate sanction which may include lost earnings and reasonable attorney's fees — on a party or attorney who fails to comply.\n\n#### *(2) Command to Produce Materials or Permit Inspection.*\n\n*(A) Appearance Not Required.* A person commanded to produce documents, electronically stored information, or tangible things, or to permit the inspection of premises, need not appear in person at the place of production or inspection unless also commanded to appear for a deposition, hearing, or trial.\n\n*(B) Objections.* A person commanded to produce documents or tangible things or to permit inspection may serve on the party or attorney designated in the subpoena a written objection to inspecting, copying, testing or sampling any or all of the materials or to inspecting the premises — or to producing electronically stored information in the form or forms requested. The objection must be served before the earlier of the time specified for compliance or 14 days after the subpoena is served. If an objection is made, the following rules apply:\n\n(i) At any time, on notice to the commanded person, the serving party may move the court for the district where compliance is required for an order compelling production or inspection.\n\n(ii) These acts may be required only as directed in the order, and the order must protect a person who is neither a party nor a party's officer from significant expense resulting from compliance.\n\n#### *(3) Quashing or Modifying a Subpoena.*\n\n*(A) When Required.* On timely motion, the court for the district where compliance is required must quash or modify a subpoena that:\n\n(i) fails to allow a reasonable time to comply;\n\n(ii) requires a person to comply beyond the geographical limits specified in Rule 45(c);\n\n(iii) requires disclosure of privileged or other protected matter, if no exception or waiver applies; or\n\n(iv) subjects a person to undue burden.\n\n*(B) When Permitted.* To protect a person subject to or affected by a subpoena, the court for the district where compliance is required may, on motion, quash or modify the subpoena if it requires:\n\n(i) disclosing a trade secret or other confidential research, development, or commercial information; or\n\n(ii) disclosing an unretained expert's opinion or information that does not describe specific occurrences in dispute and results from the expert's study that was not requested by a party.\n\n(C) *Specifying Conditions as an Alternative.* In the circumstances described in Rule 45(d)(3)(B), the court may, instead of quashing or modifying a subpoena, order appearance or production under specified conditions if the serving party:\n\n(i) shows a substantial need for the testimony or material that cannot be otherwise met without undue hardship; and\n\n(ii) ensures that the subpoenaed person will be reasonably compensated.\n\n#### **(e) Duties in Responding to a Subpoena.**\n\n*(1) Producing Documents or Electronically Stored Information.* These procedures apply to producing documents or electronically stored information:\n\n*(A) Documents.* A person responding to a subpoena to produce documents must produce them as they are kept in the ordinary course of business or must organize and label them to correspond to the categories in the demand.\n\n*(B) Form for Producing Electronically Stored Information Not Specified.* If a subpoena does not specify a form for producing electronically stored information, the person responding must produce it in a form or forms in which it is ordinarily maintained or in a reasonably usable form or forms.\n\n*(C) Electronically Stored Information Produced in Only One Form.* The person responding need not produce the same electronically stored information in more than one form.\n\n*(D) Inaccessible Electronically Stored Information.* The person responding need not provide discovery of electronically stored information from sources that the person identifies as not reasonably accessible because of undue burden or cost. On motion to compel discovery or for a protective order, the person responding must show that the information is not reasonably accessible because of undue burden or cost. If that showing is made, the court may nonetheless order discovery from such sources if the requesting party shows good cause, considering the limitations of Rule 26(b)(2)(C). The court may specify conditions for the discovery.\n\n#### *(2) Claiming Privilege or Protection.*\n\n*(A) Information Withheld.* A person withholding subpoenaed information under a claim that it is privileged or subject to protection as trial-preparation material must: (i) expressly make the claim; and\n\n(ii) describe the nature of the withheld documents, communications, or tangible things in a manner that, without revealing information itself privileged or protected, will enable the parties to assess the claim.\n\n*(B) Information Produced.* If information produced in response to a subpoena is subject to a claim of privilege or of protection as trial-preparation material, the person making the claim may notify any party that received the information of the claim and the basis for it. After being notified, a party must promptly return, sequester, or destroy the specified information and any copies it has; must not use or disclose the information until the claim is resolved; must take reasonable steps to retrieve the information if the party disclosed it before being notified; and may promptly present the information under seal to the court for the district where compliance is required for a determination of the claim. The person who produced the information must preserve the information until the claim is resolved.\n\n**(g) Contempt.** The court for the district where compliance is required – and also, after a motion is transferred, the issuing court – may hold in contempt a person who, having been served, fails without adequate excuse to obey the subpoena or an order related to it.\n\nFor access to subpoena materials, see Fed.R.Civ.P.45(a) Committee Note (2013)\n\n…\n\n## **Requests for Production of Documents**\n\n## **I. INSTRUCTIONS**\n\n1. Unless otherwise indicated, the requests for documents set forth below, (the \"Requests,\" and each, a \"Request\"), must be responded to separately and specifically. Each Request shall be answered fully unless it is in good faith objected to, in which event the reason for Your objection shall be stated in detail, as set forth below. If an objection pertains only to a portion of a Request, or a word, phrase or clause contained within it, You are required to state Your objection to that portion only and to respond to the remainder of the Requests.\n\n2. Electronically stored information must be produced in accordance with the\n\nfollowing instructions:\n\n- a. Images. Black and white images must be 300 DPI Group IV single-page TIFF files. Color images must be produced in JPEG format. File names cannot contain embedded spaces or special characters (including the comma). Folder names cannot contain embedded spaces or special characters (including the comma). All TIFF image files must have a unique file name, i.e. Bates number. Images must be endorsed with sequential Bates numbers in the lower right corner of each image. The number of TIFF files per folder should not exceed 1000 files. Excel spreadsheets should have a placeholder image named by the Bates number of the file.\n- b. Image Load File\n\t- a. Concordance® Data File. The data file (.DAT) contains all of the fielded information that will be loaded into the Concordance® database. The first line of the .DAT file must be a header row identifying the field names. The .DAT file must use the following Concordance® default delimiters: Comma ASCII character (020) Quote þ ASCII character (254). Date fields should be provided in the format: mm/dd/yyyy. Date and time fields must be two separate fields. If documents includes imaged emails and attachments, the attachment fields must be included to preserve the parent/child relationship between an email and its attachments. An OCRPATH field must be included to provide the file path and name of the extracted text file on the produced storage media. The text file must be named after the FIRSTBATES. Do not include the text in the .DAT file. For Documents with native files, a LINK field must be included to provide the file path and\n\nname of the native file. The native file must be named after the FIRSTBATES.\n\n- b. Concordance Image® OR Opticon Cross-Reference File. The image crossreference file (.LOG or .OPT) links the images to the database records. It should be a comma-delimited file consisting of seven fields per line with a line in the cross-reference file for every image in the database with the following format: ImageID,VolumeLabel,ImageFilePath,DocumentBreak,FolderBreak,Box Break,PageCoun.\n- c. Document Text. Text must be produced as separate text files, not as fields within the .DAT file. The full path to the text file (OCRPATH) should be included in the .DAT file. It is recommended document level ANSI text files, named per the FIRSTBATES/Image Key. Extracted text files must be in a separate folder, and the number of text files per folder should not exceed 1,000 files. There should be no special characters (including commas in the folder names). Text files must be provided on a document level.\n- d. Native Production for Certain File Types. File types that reasonably require viewing in their native format for a full understanding of their content and meaning must be produced in native format. These include, but are not limited to, spreadsheets, spreadsheet-like files (Microsoft Excel, comma separated values, tab separated values, etc.), Microsoft PowerPoint or other special presentation files, database files, and audio/visual files. Provide an image of a Bates numbered slip sheet indicating the presence of a native file, and include the path to the native as a field in the .dat file. Name the produced native file with the Bates number corresponding to the slip sheet for the file. Group native files within incrementally named \"NATIVE\" directories, separate from images directories.\n- e. De-duplication. Produce a single copy of each electronic document for which exact duplicates exist. For email messages, consolidate duplicates based on MD5 hash generated from the BCC, Body, CC, From, IntMsgID, To, and Attach properties. For email attachments and standalone electronic files, consolidate duplicates based on MD5 hash of the entire file.\n- f. Metadata. Produce extracted metadata for each document in the form of a Concordance compliant load file (.dat). The first line of the .DAT file must be a header row identifying the field names. The .DAT file must use the following Concordance default delimiters: Comma , ASCII character (020) Quote þ ASCII character (254)\n\nDate fields should be provided in the format: mm/dd/yyyy. Date and time fields must be two separate fields. Required metadata listed below:\n\n# Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 702 of 1063\n\n| Field Name   | Sample Data              | Description                                      |\n|--------------|--------------------------|--------------------------------------------------|\n| FIRSTBATES   | EDC0000001               | First Bates number of native file document/email |\n| LASTBATES    | EDC0000001               | Last Bates number of native file document/email  |\n|              |                          | **The LASTBATES field should be populated        |\n|              |                          | for single page                                  |\n| ATTACHRANGE  | EDC0000001<br>-          | Bates number of the first page of the parent     |\n|              | EDC0000015               | document to the Bates number of the last page of |\n|              |                          | the last attachment \"child\" document             |\n| BEGATTACH    | EDC0000001               | First Bates number of attachment range           |\n| ENDATTACH    | EDC0000015               | Last Bates number of attachment range            |\n| CUSTODIAN    | Smith, John              | Email: Mailbox where the email resided           |\n|              |                          | Native: Name of the individual or department     |\n|              |                          | from whose files the document<br>originated      |\n| FROM         | John Smith               | Email: Sender                                    |\n|              |                          | Native: Author(s) of document                    |\n|              |                          | **semi-colon should be used to separate          |\n|              |                          | multiple entries                                 |\n| TO           | Coffman, Janice; LeeW    | Recipient(s)                                     |\n|              | [mailto:LeeW@MSN.com]    | **semi-colon should be used to separate multiple |\n|              |                          | entries                                          |\n| CC           | Frank Thompson [mailto:  | Carbon copy recipient(s)                         |\n|              | frank_Thompson@cdt.com]  | **semi-colon should be used to separate          |\n|              |                          | multiple entries                                 |\n| BCC          | John Cain                | Blind carbon copy recipient(s)                   |\n|              |                          | **semi-colon should be used to separate          |\n|              |                          | multiple entries                                 |\n| SUBJECT      | Board Meeting Minutes    | Email: Subject line of the email Native: Title   |\n|              |                          | of document (if available)                       |\n| FILE_NAME    | BoardMeetingMinutes.docx | Native: Name of the original native file,        |\n|              |                          | including extension                              |\n| DATE_SENT    | 10/12/2010               | Email: Date the email was sent                   |\n|              |                          | Native: (empty)                                  |\n| TIME_SENT/   | 07:05 PM GMT             | Email: Time the email was sent/ Time zone in     |\n| TIME_ZONE    |                          | which the emails were standardized               |\n| TIME_ZONE    | GMT                      | The<br>time zone in which<br>the emails<br>were  |\n|              |                          | standardized during conversion.                  |\n| LINK         |  EDC0000001.msg   | Hyperlink to the email or native file document   |\n|              |                          | **The linked file must be named per the          |\n|              |                          | FIRSTBATES number                                |\n| FILE_EXTEN   | MSG                      | The file type extension                          |\n|              |                          | representing                                     |\n|              |                          | the Email or                                     |\n| AUTHOR       | John Smith               | Email: (empty)                                   |\n|              |                          | Native: Author of the document                   |\n| DATE_CREATED | 10/10/2010               | Email: (empty)                                   |\n|              |                          | Native: Date the document was created            |\n\n# Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 703 of 1063\n\n| TIME_CREATED | 10:25 AM                  | Email: (empty)                                  |\n|--------------|---------------------------|-------------------------------------------------|\n|              |                           | Native: Time the document was created           |\n|              |                           | **This data must be a separate field and cannot |\n|              |                           | be combined with the DATE_CREATED field         |\n| DATE_MOD     | 10/12/2010                | Email: (empty)                                  |\n|              |                           | Native: Date the document was last modified     |\n| TIME_MOD     | 07:00 PM                  | Email: (empty)                                  |\n|              |                           | Native: Time the document was last modified     |\n|              |                           | **This data must be a separate field and cannot |\n|              |                           | be combined with the DATE_MOD field             |\n| DATE_ACCESSD | 10/12/2010                | Email: (empty)                                  |\n|              |                           | Native: Date the document was last accessed     |\n| TIME_ACCESSD | 07:00 PM                  | Email: (empty)                                  |\n|              |                           | Native: Time the document was last accessed     |\n|              |                           | **This data must be a separate field and cannot |\n|              |                           | be combined with the DATE_ACCESSD field         |\n| FILE_SIZE    | 5,952                     | Size of native file<br>document/email in KB     |\n| PGCOUNT      | 1                         | Number of pages in native file document/email   |\n| PATH         |   | Email: (empty)                                  |\n|              | Agenda.doc                | Native: Path where native file document was     |\n|              |                           | stored including original file name.            |\n| INTFILEPATH  | Personal Folders\\Deleted  | Email: original location of email including     |\n|              | Items\\Board Meeting       | original file name.                             |\n|              | Minutes.msg               | Native: (empty)                                 |\n| INTMSGID     | <000805c2c71b\\$75977050\\$ | Email: Unique Message ID Native: (empty)        |\n|              | cb8306d1@MSN>             |                                                 |\n| MD5HASH      | d131dd02c5e6eec4693d9a0   | MD5 Hash value of the document.                 |\n|              | 698aff95c                 |                                                 |\n|              | 2fcab58712467eab4004583e  |                                                 |\n|              | b8fb7f89                  |                                                 |\n| OCRPATH      | TEXT/001/EDC0000001.txt   | Path to extracted text of the native file       |\n\n3. Each Request operates and should be construed independently and, unless otherwise indicated, no Request limits the scope of any other Request.\n\n4. All Documents are to be produced as kept in the usual course of business or are to be organized and labeled to correspond with the categories in these Requests.\n\n5. Each Request contained herein extends to all Documents: (a) in Your possession, custody, or control; or (b) in the possession, custody, or control of anyone acting on Your behalf,\n\n#### Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 704 of 1063\n\nincluding Your counsel or other representatives and advisors. Each Document shall be produced in its entirety.\n\n6. If You are requested to produce a Document that is no longer in Your possession, custody, or control, then Your response must (a) describe in detail the nature of the document and its contents; (b) identify the person(s) who prepared or authored the Document (and, if applicable, the Person(s) to whom the Document was sent); (c) identify the date on which the document was prepared or created; (d) state whether such Document (i) is missing or lost, (ii) has been destroyed, (iii) has been transferred, voluntarily or involuntarily, to others, or (iv) was otherwise disposed of; (e) state the reason for, and the facts and circumstances surrounding, such disposition; (f) identify the Persons who authorized such disposition; (g) identify the date or approximate date of such disposition; (h) state when the Document was most recently in Your possession, custody or control; and (i) identify the Person, if any, presently in possession, custody, or control of such Document.\n\n7. If You are requested to produce a Document that has been destroyed, then Your response must state, in addition to the information required by the preceding Instruction: (a) the reason for the Document's destruction; (b) the identity of the Person who destroyed the Document; and (c) the identity of the Person who directed that the Document be destroyed.\n\n8. If You claim that a requested Document is privileged or attorney work-product, then Your response must: (a) state (i) a description of the Document adequate to support Your contention that the Document is privileged, (ii) the title of the Document, (iii) the date of the Document, (iv) the author of the Document, (v) the addressee of the Document, (vi) the identity of each Person who received or saw the original or any draft, copy, or reproduction of the Document, (vii) whether the Document itself, or any information contained or referred to in the Document is in the possession, custody, or control of any other Persons, and if so, the identity of\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 705 of 1063\n\nsuch Persons, as well as a statement addressing how the information came into their possession, (viii) the claim of privilege under which the Document is withheld, and (ix) all of the circumstances upon which You will rely to support such claim of privilege; and (b) produce a privilege log containing all of the information requested in Part (a) of this Instruction for each Document withheld on the basis of a claim of privilege in accordance with D. Conn. L. Civ. R. 26(e).\n\n9. If a portion of an otherwise responsive Document contains information subject to a claim of privilege, only that portion of the Document subject to the claim of privilege shall be deleted or redacted from the Document following the instructions above, and the rest shall be produced.\n\n10. The Requests are continuing in nature. You are hereby instructed to (a) supplement or correct any responses later learned to be incomplete or incorrect immediately upon learning that a prior response was incomplete or incorrect; and (b) produce any additional Documents that are called for under the\n\n11. If a Document is in a language other than English, You should provide that Document. If a Document is in a language other than English, and an English translation exists, You should provide both Documents.\n\n12. All references to Entities includes all affiliates thereof.\n\n13. All references to individual names include all alternative names, aliased, or nicknames.\n\n14. Unless otherwise expressly indicated, the period of time covered by the Document Requests is the period from February 5, 2012 to the date responses to the Document Requests are due.\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 706 of 1063\n\n#### **II. RULES OF CONSTRUCTION**\n\n15. The use of (a) any singular noun shall be construed to include the plural, and vice versa, and (b) a verb in any tense shall be construed as the use of the verb in all other tenses.\n\n16. The terms (a) \"and\" and \"or\" shall be construed either conjunctively or disjunctively as necessary to bring within the scope of any request all responses that might otherwise be construed to be outside of its scope, and (b) \"each\" and \"any\" shall be deemed to include and encompass the words \"every\" and \"all.\"\n\n#### **III. DEFINITIONS**\n\nThe definitions supplied by D. Conn. L. Civ. R. 26(c) and the rules of construction supplied by D. Conn. L. Civ. R. 26(d), as incorporated by D. Conn. Bankr. L.R. 2004-1(a), shall apply to the Document Requests. In addition, the following terms used in these Document Requests shall have the following meanings:\n\n1. \"You\" or \"Your\" or \"Yourself\" means and refers to Ding G. Wang a/k/a Dinggang Wang, together with all of their agents, attorneys, representatives, employees, and/or anyone acting on their behalf.\n\n2. \"Debtor\" means Ho Wan Kwok (a/k/a Miles Kwok, Miles Guo, Guo Wengui, Guo Haoyun, 郭文贵, or any other alias), together with his employees, agents, counsel, advisors, or anyone acting on his behalf.\n\n3. \"Debtor's Son\" means Qiang Guo (a/k/a Mileson Kwok, 郭强, or any other alias), together with his employees, agents, counsel, advisors, or anyone acting on his behalf.\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 707 of 1063\n\n4. \"Debtor's Daughter\" means Mei Guo (a/k/a Mei Gui, 郭美, or any other alias), together with her employees, agents, counsel, advisors, or anyone acting on her behalf.\n\n5. \"Debtor's Purported Wife\" means Hing Chi Ngok (a/k/a Hing Chi Ng, Yue Qingzhi, 岳庆芝, or any other alias), together with her employees, agents, counsel, advisors, or anyone acting on her behalf.\n\n6. \"Debtor's Family\" means, collectively, the Debtor, the Debtor's Son, the Debtor's Daughter, and the Debtor's Purported Wife, and any other familial relation to the Debtor.\n\n7. \"Associated Individuals\" means, individually and collectively, all individuals that (1) hold, control, have custody over, or discretion over assets owned, controlled, or enjoyed by the Debtor or the Debtor's Family; or (2) have been employees, directors, or otherwise are affiliated with one or more Associated Entities, together with the respective employees, agents, counsel, advisors, or anyone acting on behalf of any of the foregoing. Such Associated Individuals shall include, but are not limited to: Daniel Podhaskie, Jason Miller, Steve Bannon, Karin Maistrello, Melissa Francis, Anthony DiBattista, William Gertz, Arethusa Forsyth, Glenn Mellor, Jennifer Mercurio, Eduardo Eurnekian, Wencong Wang, Han Chunguang (a/k/a 韩春光), Qu Guojiao (a/k/a Qu Guo Jiao, 屈国姣), Guo Lijie (a/k/a 郭丽杰), Zhang Wei (a/k/a 张伟\\*), Lihong Wei Lafrenz (a/k/a Sara Wei, 魏丽红), Hao Haidong (a/k/a 郝海东), Ross Heinemeyer, Max Krasner, Kyle Bass, Melissa Mendez, Ya Li (a/k/a 李娅), Dinggang Wang (a/k/a 王定刚), An Hong (a/k/a 安红), Yvette Wang (a/k/a Yanping Wang, Yan Ping Wang, 王雁平), Fiona Yu, Je Kin Ming (a/k/a William Je, Yu Jianming, 余建明), Yaz Qingua, and Lao Jiang (a/k/a Jiang Yunfu, Jiang Yunfu Be, 姜云浮).\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 708 of 1063\n\n8. \"Associated Entities\" means, individually and collectively, all organizations or Entities of any type that (1) have been owned, controlled, or invested in by the Debtor or the Debtor's Family; or (2) have an interest, whether directly or indirectly, in any assets owned, controlled, or enjoyed by the Debtor or the Debtor's Family, together with the respective employees, agents, counsel, advisors, or anyone acting on behalf of any of the foregoing. Such Associated Entities shall include, but are not limited to: 7 Nod Hill LLC, AAGV Limited, ACA Investment Management Limited, ACA Capital Group Limited, Ace Decade Holdings Limited, AI Group Holdings Inc., Alfa Global Ventures Limited, Alfonso Global Limited, Allied Capital Global Limited, Alpine Fiduciaries SA, Anton Development Limited, Assets Sino Limited, Auspicious Coast Limited, Beijing Pangu Investment Co., Beijing Pangu Investment Co. Ltd., Beijing Pangu Investment Inc., Beijing Zenith Holdings Company Limited, Booming Sail New York LLC, Bravo Luck Limited, BSA Strategic Fund I, China Golden Spring (Hong Kong) Limited, Chuang Xin Limited, Crane Advisory Group LLC, Creative Apex Investments Limited, Crystal Breeze Investments Limited, Dawn State Limited, Eastern Profit Corporation Limited, Elite Well Global Limited, Empire Growth Holdings, Freedom Media Ventures Ltd., G Club Operations LLC, G Fashion LLC, G News LLC, GETTR USA, Genever Holdings Corporation, Genever Holdings LLC, Gfashion Media Group Inc., GFNY, Inc., Globalist International Limited, GNews Media Group Inc., Golden Spring (New York) Ltd., Greenwich Land LLC, Guo Media, GTV Media Group, Inc., Hamilton Capital Holdings Inc., HCHK Property Management, Inc., HCHK Technologies, Inc., Head Win Group Limited, Henan Yuda, Himalaya Embassy, Himalaya Exchange, Himalaya Federal Reserve, Himalaya Investment LLC, Himalaya International, Himalaya New World Inc., Himalaya Supervisory Organization, Himalaya Ventures LLC, HK International Funds Investments (USA) Limited LLC, Hong Kong International Funds\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 709 of 1063\n\nInvestments Limited, Hudson Diamond Holding, Infinite Increase Limited, Infinitum Developments Limited, Infinity Treasury Management Inc., Insight Phoenix Fund, Lamp Capital LLC, Leading Shine Limited, Leading Shine NY Limited, Lexington Property and Staffing, Long Gate Limited, Maywind Trading LLC, MOS Himalaya LLC, Next Tycoon Investments Limited, New Federal State of China (a/k/a NFSC), Noble Fame Global Limited, Rosy Acme Ventures Limited, Rule of Law Foundation III, Inc., Rule of Law Foundation IV, Inc., Rule of Law Fund, Rule of Law Society, Rule of Law Society IV, Inc., G-Translators PTY LTD, Saraca Media Group, Inc., Shiny Ace Ltd., Shiny Times Holdings Ltd., Spirit Charter Investment Limited, Stevenson, Wong & Co., Voice of Guo Media, Inc., Well Origin Ltd., World Century Limited, Worldwide Opportunity Holdings Limited, Whitecroft Shore Limited, and ZIBA Limited.\n\n9. \"Including\" or any variant thereof means \"including without limitation.\"\n\n10. \"And\" and \"or\" mean \"and/or,\" and shall be construed both conjunctively as well as disjunctively in order to maximize their scope.\n\n11. \"Any\" and \"all\" and \"each\" mean \"each and every.\"\n\n12. \"Each\" and \"every\" mean \"each and every.\"\n\n13. \"Third Party\" means a Person or Entity other than Yourself.\n\n14. \"Transfer\" shall have the meaning given to it by section 101(54) of the Bankruptcy Code.\n\n15. \"Document\" means any information or thing within the scope of Fed. R. Civ. P. 34, and includes, without limitation, each and every written, recorded, or graphic matter of any kind, type, nature, or description that is or has been in Your Possession, Custody or Control, including all printed and electronic copies of electronic mail, computer files maintained in\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 710 of 1063\n\nelectronic form, electronic communication, text message, social media post, tweet, meta-data, correspondence, memoranda, tapes, stenographic or handwritten notes, written forms of any kind, charts, blueprints, drawings, sketches, graphs, plans, articles, specifications, diaries, letters, telegrams, photographs, minutes, contracts, agreements, surveys, computer printouts, data compilations of any kind, telexes, facsimiles, voice messages, invoices, order forms, checks, drafts, statements, credit memos, reports, position reports, summaries, indices, books, ledgers, notebooks, schedules, transparencies, recordings, catalogs, advertisements, promotional materials, films, video tapes, audio tapes, CDs, computer disks, brochures, pamphlets, punchcards, time-slips, Tweets, social media posts, or any written or recorded materials of any other kind, and all meta-data thereof, however stored (whether in tangible or electronic form), recorded, produced, or reproduced, and also including but not limited to, drafts or copies of any of the foregoing that contain any notes, comments, or markings of any kind not found on the original documents or that are otherwise not identical to the original documents.\n\n16. \"Person(s)\" means an individual, corporation, proprietorship, partnership, association, or any other Entity. \"Person\" also includes any agent, representatives, or expert, including but not limiting to, attorneys or financial advisors.\n\n17. \"Entity\" means any natural Person, corporation, partnership, subsidiary, sole proprietorship, firm, board, joint venture, association, agency, authority, commission or other business entity or juristic Person, as well as any affiliate, agent, parent including but not limited to legal counsel, financial advisors, or any other representative.\n\n18. \"Regarding\" means concerning, describing, comprising, referring to, related to, supporting, favoring, opposing, bolstering, detracting from, located in, considered in connection with, bearing on, evidencing, indicating, reporting on, recording, alluding to, responding to,\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 711 of 1063\n\nconnected with, commenting on, in respect of, about, in relation to, discussing, showing, describing, reflecting, analyzing constituting, and being.\n\n19. \"Relating to,\" \"relate(s) to\" or \"related to,\" when referring to any given subject matter, means, without limitation, any document that constitutes, comprises, involves, contains, embodies, reflects, identifies, states, refers directly or indirectly to, or is in any way relevant to the particular subject matter identified.\n\n20. \"Communication(s)\" means, in the broadest possible sense, and without limitation, any transmittal of information or knowledge (in the form of facts, ideas, inquiries, or otherwise). Communication(s) further refers to all conversations, agreements, inquiries, or replies, whether in person, by telephone, in writing, or by means of electronic transmittal devices, and includes, but is not limited to, all correspondence, emails, recordings, transmittal slips, memoranda, telephone communications, voice messages, telegrams, telefaxes, telecopies, telexes, instant messages, chats, text messages, telephonic notes, or notes transmitted internally or with third parties.\n\n21. \"Asset(s)\" means any item that can be used to produce positive economic value, including but not limited to any resource with economic value that is owned, controlled or is for the benefit of an entity, that is expected to provide a future benefit, including but not limited to, all real and personal property, intangible property, investments, rights to invest or to future revenue, cash, bank accounts, commodities, securities, claims, total or partial control of an entity, and prospective economic opportunities\n\n22. \"Transfer\" shall have the meaning given to it by section 101(54) of the Bankruptcy Code.\n\n#### **IV. DOCUMENTS TO BE PRODUCED**\n\n1. All Documents regarding any income or Asset of the Debtor, the Debtor's estate, or an Associated Entity.\n\n2. All Documents related to the Debtor's financial condition and obligations to his creditors, including without limitation all Documents related to any effort to avoid paying such obligations and All Documents related to this or any other actual or potential bankruptcy or similar insolvency proceeding.\n\n3. All Documents regarding any balance sheet, bank statement, account statement, financial statement, statement of account, wire transfer instructions and/or confirmation, proof of funds, certificate of deposit, certificate of holdings, investment portfolio summary, or similar document relating to the Debtor, the Debtor's Estate, the Debtor's Family, an Associated Entity, or an Associated Individual, including without limitation all Documents sufficient to show all Transfers to any of the foregoing.\n\n4. All Documents regarding any investment, business dealing or transactions made by, with, or on behalf of the Debtor.\n\n5. All Communications with the Debtor, and Documents related to Communications with the Debtor, related to the operation, management, or decision-making of any Entity, including without limitation the Associated Entities.\n\n6. All Documents regarding any Transfer, investment, or other transaction or business dealing made to, by, or with the Debtor, the Debtor's Family, or an Associated Entity.\n\n7. All Documents regarding any property ever occupied or used by the Debtor, including without limitation the *Lady May*; the Sherry Netherland Hotel / Condominium; the\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 713 of 1063\n\nresidential property located in Greenwich, Connecticut at 373 Taconic Rd.; the residential property located in Greenwich, Connecticut at 33 Ferncliff Rd.; and the residential property located in Wilton, Connecticut at 354 Nod Hill Rd.\n\n8. All Documents related to any aircraft owned, controlled, or used by the Debtor, including without limitation the aircraft bearing tail number T7-GQM and any other aircraft registered in San Marino, including without limitation copies of all registration documents and flight manifests showing flights taken by such aircraft and the individuals onboard such flights.\n\n9. All Documents regarding any gifts, benefits or loans, to, from or on behalf of the Debtor, the Debtor's Estate, the Debtor's Family, or the Associated Entities, including without limitation Documents sufficient to show the amounts of such gifts, benefits, or loans; the purposes for which such gifts, benefits, or loans were used; when the gifts, benefits, or loans were provided; and the terms of any loans, all representations and warranties made in connection with any loans, the interest rate on any loans, and all evidence of payments of any loans.\n\n10. All Documents concerning any trust or similar instrument set up by, on behalf of, or for the benefit of the Debtor, the Debtor's Estate, the Debtor's Family, or an Associated Entity, including without limitation Documents sufficient to show when the trust(s) was created, by whom it was created, for whose benefit it was created, and the corpus of the trust.\n\n11. All Documents related to any obligation, claim, liability, or debt associated with any legal dispute involving the Debtor, including but not limited to those relating to any litigation before any local, state, federal, or international body, whether an administrative body, court, panel, or alternative dispute resolution entity.\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 714 of 1063\n\n12. All Documents and communications between any of your outside counsel or other advisors and the Debtor.\n\n13. All Documents related to any Associated Entity that You hold or have held an interest in.\n\n14. All Communications with the Debtor, and Documents related to Communications with the Debtor, related to the operation, management, or decision-making of any legal entity, including without limitation the Family Related Entities and the Associated Entities.\n\n# Exhibit C-39\n\n#### B2540 (Form 2540 – Subpoena for Rule 2004 Examination) (12/15) Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 716 of\n\n1063\n\nUNITED STATES BANKRUPTCY COURT\n\n**District of Connecticut**\n\nIn re HO WAN KWOK, *et al*.,\n\n<sup>1</sup> Case No. 22-50073 (JAM) Debtor Chapter 11\n\n(Jointly Administered)\n\n# **SUBPOENA FOR RULE 2004 EXAMINATION**\n\nTo: **Prime Trust LLC**\n\n(*Name of person to whom the subpoena is directed*)\n\n*Testimony:* **YOU ARE COMMANDED** to appear at the time, date, and place set forth below to testify at an examination under Rule 2004, Federal Rules of Bankruptcy Procedure. A copy of the court order authorizing the examination is attached.\n\n| PLACE                    | DATE AND TIME |\n|--------------------------|---------------|\n| Paul Hastings LLP        |               |\n| 200 Park Avenue          | [TBD]         |\n| New York, New York 10166 |               |\n|                          |               |\n\nThe examination will be recorded by this method: **Court reporter/stenographer**\n\n*Production:* You, or your representatives, must also bring with you to the examination the following documents, electronically stored information, or objects, and must permit inspection, copying, testing, or sampling of the material:\n\n#### **See Requests for Production of Documents, attached hereto.**\n\nThe following provisions of Fed. R. Civ. P. 45, made applicable in bankruptcy cases by Fed. R. Bankr. P. 9016, are attached – Rule 45(c), relating to the place of compliance; Rule 45(d), relating to your protection as a person subject to a subpoena; and Rule 45(e) and 45(g), relating to your duty to respond to this subpoena and the potential consequences of not doing so.\n\nDate: **March , 2023**\n\nCLERK OF COURT\n\nOR\n\n*Signature of Clerk or Deputy Clerk Attorney's signature*\n\nThe name, address, email address, and telephone number of the attorney representing Luc A. Despins, Chapter 11 Trustee, who issues or requests this subpoena, are:\n\n**Douglas S. Skalka, Esq.; Neubert, Pepe & Monteith, P.C.; 195 Church Street, New Haven, Connecticut 06510 dskalka@npmlaw.com; (203) 821-2000**\n\n**Notice to the person who issues or requests this subpoena**\n\nIf this subpoena commands the production of documents, electronically stored information, or tangible things, or the inspection of premises before trial, a notice and a copy of this subpoena must be served on each party before it is served on the person to whom it is directed. Fed. R. Civ. P. 45(a)(4).\n\nSoftware Copyright (c) 1996-2022 Best Case, LLC - www.bestcase.com Best Case Bankruptcy 1 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\n#### **PROOF OF SERVICE**\n\n**(This section should not be filed with the court unless required by Fed. R. Civ. P. 45.)**\n\nI received this subpoena for (*name of individual and title, if any*): on (*date*) .\n\nI served the subpoena by delivering a copy to the named person as follows:\n\non *(date)* ; or\n\nI returned the subpoena unexecuted because:\n\nUnless the subpoena was issued on behalf of the United States, or one of its officers or agents, I have also tendered to the witness the fees for one day's attendance, and the mileage allowed by law, in the amount of \\$ .\n\nMy fees are \\$ for travel and \\$ for services, for a total of \\$ .\n\nI declare under penalty of perjury that this information is true and correct.\n\nDate:\n\n*Server's signature*\n\n*Printed name and title*\n\n*Server's address*\n\nAdditional information concerning attempted service, etc.:\n\n#### **Federal Rule of Civil Procedure 45(c), (d), (e), and (g) (Effective 12/1/13) (made applicable in bankruptcy cases by Rule 9016, Federal Rules of Bankruptcy Procedure)**\n\n#### **(c) Place of compliance.**\n\n*(1) For a Trial, Hearing, or Deposition.* A subpoena may command a person to attend a trial, hearing, or deposition only as follows:\n\n(A) within 100 miles of where the person resides, is employed, or regularly transacts business in person; or\n\n(B) within the state where the person resides, is employed, or regularly transacts business in person, if the person\n\n(i) is a party or a party's officer; or\n\n(ii) is commanded to attend a trial and would not incur substantial expense.\n\n*(2) For Other Discovery.* A subpoena may command:\n\n(A) production of documents, or electronically stored information, or things at a place within 100 miles of where the person resides, is employed, or regularly transacts business in person; and\n\n(B) inspection of premises, at the premises to be inspected.\n\n#### **(d) Protecting a Person Subject to a Subpoena; Enforcement.**\n\n*(1) Avoiding Undue Burden or Expense; Sanctions.* A party or attorney responsible for issuing and serving a subpoena must take reasonable steps to avoid imposing undue burden or expense on a person subject to the subpoena. The court for the district where compliance is required must enforce this duty and impose an appropriate sanction which may include lost earnings and reasonable attorney's fees — on a party or attorney who fails to comply.\n\n#### *(2) Command to Produce Materials or Permit Inspection.*\n\n*(A) Appearance Not Required.* A person commanded to produce documents, electronically stored information, or tangible things, or to permit the inspection of premises, need not appear in person at the place of production or inspection unless also commanded to appear for a deposition, hearing, or trial.\n\n*(B) Objections.* A person commanded to produce documents or tangible things or to permit inspection may serve on the party or attorney designated in the subpoena a written objection to inspecting, copying, testing or sampling any or all of the materials or to inspecting the premises — or to producing electronically stored information in the form or forms requested. The objection must be served before the earlier of the time specified for compliance or 14 days after the subpoena is served. If an objection is made, the following rules apply:\n\n(i) At any time, on notice to the commanded person, the serving party may move the court for the district where compliance is required for an order compelling production or inspection.\n\n(ii) These acts may be required only as directed in the order, and the order must protect a person who is neither a party nor a party's officer from significant expense resulting from compliance.\n\n#### *(3) Quashing or Modifying a Subpoena.*\n\n*(A) When Required.* On timely motion, the court for the district where compliance is required must quash or modify a subpoena that:\n\n(i) fails to allow a reasonable time to comply;\n\n(ii) requires a person to comply beyond the geographical limits specified in Rule 45(c);\n\n(iii) requires disclosure of privileged or other protected matter, if no exception or waiver applies; or\n\n(iv) subjects a person to undue burden.\n\n*(B) When Permitted.* To protect a person subject to or affected by a subpoena, the court for the district where compliance is required may, on motion, quash or modify the subpoena if it requires:\n\n(i) disclosing a trade secret or other confidential research, development, or commercial information; or\n\n(ii) disclosing an unretained expert's opinion or information that does not describe specific occurrences in dispute and results from the expert's study that was not requested by a party.\n\n(C) *Specifying Conditions as an Alternative.* In the circumstances described in Rule 45(d)(3)(B), the court may, instead of quashing or modifying a subpoena, order appearance or production under specified conditions if the serving party:\n\n(i) shows a substantial need for the testimony or material that cannot be otherwise met without undue hardship; and\n\n(ii) ensures that the subpoenaed person will be reasonably compensated.\n\n#### **(e) Duties in Responding to a Subpoena.**\n\n*(1) Producing Documents or Electronically Stored Information.* These procedures apply to producing documents or electronically stored information:\n\n*(A) Documents.* A person responding to a subpoena to produce documents must produce them as they are kept in the ordinary course of business or must organize and label them to correspond to the categories in the demand.\n\n*(B) Form for Producing Electronically Stored Information Not Specified.* If a subpoena does not specify a form for producing electronically stored information, the person responding must produce it in a form or forms in which it is ordinarily maintained or in a reasonably usable form or forms.\n\n*(C) Electronically Stored Information Produced in Only One Form.* The person responding need not produce the same electronically stored information in more than one form.\n\n*(D) Inaccessible Electronically Stored Information.* The person responding need not provide discovery of electronically stored information from sources that the person identifies as not reasonably accessible because of undue burden or cost. On motion to compel discovery or for a protective order, the person responding must show that the information is not reasonably accessible because of undue burden or cost. If that showing is made, the court may nonetheless order discovery from such sources if the requesting party shows good cause, considering the limitations of Rule 26(b)(2)(C). The court may specify conditions for the discovery.\n\n#### *(2) Claiming Privilege or Protection.*\n\n*(A) Information Withheld.* A person withholding subpoenaed information under a claim that it is privileged or subject to protection as trial-preparation material must: (i) expressly make the claim; and\n\n(ii) describe the nature of the withheld documents, communications, or tangible things in a manner that, without revealing information itself privileged or protected, will enable the parties to assess the claim.\n\n*(B) Information Produced.* If information produced in response to a subpoena is subject to a claim of privilege or of protection as trial-preparation material, the person making the claim may notify any party that received the information of the claim and the basis for it. After being notified, a party must promptly return, sequester, or destroy the specified information and any copies it has; must not use or disclose the information until the claim is resolved; must take reasonable steps to retrieve the information if the party disclosed it before being notified; and may promptly present the information under seal to the court for the district where compliance is required for a determination of the claim. The person who produced the information must preserve the information until the claim is resolved.\n\n**(g) Contempt.** The court for the district where compliance is required – and also, after a motion is transferred, the issuing court – may hold in contempt a person who, having been served, fails without adequate excuse to obey the subpoena or an order related to it.\n\nFor access to subpoena materials, see Fed.R.Civ.P.45(a) Committee Note (2013)\n\n…\n\n## **Request for Production of Documents**\n\n## **I. INSTRUCTIONS**\n\n1. Unless otherwise indicated, the requests for documents set forth below, (the \"Requests,\" and each, a \"Request\"), must be responded to separately and specifically. Each Request shall be answered fully unless it is in good faith objected to, in which event the reason for Your objection shall be stated in detail, as set forth below. If an objection pertains only to a portion of a Request, or a word, phrase or clause contained within it, You are required to state Your objection to that portion only and to respond to the remainder of the Requests.\n\n2. Electronically stored information must be produced in accordance with the\n\nfollowing instructions:\n\n- a. Images. Black and white images must be 300 DPI Group IV single-page TIFF files. Color images must be produced in JPEG format. File names cannot contain embedded spaces or special characters (including the comma). Folder names cannot contain embedded spaces or special characters (including the comma). All TIFF image files must have a unique file name, i.e. Bates number. Images must be endorsed with sequential Bates numbers in the lower right corner of each image. The number of TIFF files per folder should not exceed 1000 files. Excel spreadsheets should have a placeholder image named by the Bates number of the file.\n- b. Image Load File\n\t- a. Concordance® Data File. The data file (.DAT) contains all of the fielded information that will be loaded into the Concordance® database. The first line of the .DAT file must be a header row identifying the field names. The .DAT file must use the following Concordance® default delimiters: Comma ASCII character (020) Quote þ ASCII character (254). Date fields should be provided in the format: mm/dd/yyyy. Date and time fields must be two separate fields. If documents includes imaged emails and attachments, the attachment fields must be included to preserve the parent/child relationship between an email and its attachments. An OCRPATH field must be included to provide the file path and name of the extracted text file on the produced storage media. The text file must be named after the FIRSTBATES. Do not include the text in the .DAT file. For Documents with native files, a LINK field must be included to provide the file path and\n\nname of the native file. The native file must be named after the FIRSTBATES.\n\n- b. Concordance Image® OR Opticon Cross-Reference File. The image crossreference file (.LOG or .OPT) links the images to the database records. It should be a comma-delimited file consisting of seven fields per line with a line in the cross-reference file for every image in the database with the following format: ImageID,VolumeLabel,ImageFilePath,DocumentBreak,FolderBreak,Box Break,PageCoun.\n- c. Document Text. Text must be produced as separate text files, not as fields within the .DAT file. The full path to the text file (OCRPATH) should be included in the .DAT file. It is recommended document level ANSI text files, named per the FIRSTBATES/Image Key. Extracted text files must be in a separate folder, and the number of text files per folder should not exceed 1,000 files. There should be no special characters (including commas in the folder names). Text files must be provided on a document level.\n- d. Native Production for Certain File Types. File types that reasonably require viewing in their native format for a full understanding of their content and meaning must be produced in native format. These include, but are not limited to, spreadsheets, spreadsheet-like files (Microsoft Excel, comma separated values, tab separated values, etc.), Microsoft PowerPoint or other special presentation files, database files, and audio/visual files. Provide an image of a Bates numbered slip sheet indicating the presence of a native file, and include the path to the native as a field in the .dat file. Name the produced native file with the Bates number corresponding to the slip sheet for the file. Group native files within incrementally named \"NATIVE\" directories, separate from images directories.\n- e. De-duplication. Produce a single copy of each electronic document for which exact duplicates exist. For email messages, consolidate duplicates based on MD5 hash generated from the BCC, Body, CC, From, IntMsgID, To, and Attach properties. For email attachments and standalone electronic files, consolidate duplicates based on MD5 hash of the entire file.\n- f. Metadata. Produce extracted metadata for each document in the form of a Concordance compliant load file (.dat). The first line of the .DAT file must be a header row identifying the field names. The .DAT file must use the following Concordance default delimiters: Comma , ASCII character (020) Quote þ ASCII character (254)\n\nDate fields should be provided in the format: mm/dd/yyyy. Date and time fields must be two separate fields. Required metadata listed below:\n\n# Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 721 of 1063\n\n| Field Name   | Sample Data              | Description                                                                                  |\n|--------------|--------------------------|----------------------------------------------------------------------------------------------|\n| FIRSTBATES   | EDC0000001               | First Bates number of native file document/email                                             |\n| LASTBATES    | EDC0000001               | Last Bates number of native file document/email<br>**The LASTBATES field should be populated |\n|              |                          | for single page                                                                              |\n| ATTACHRANGE  | EDC0000001<br>-          | Bates number of the first page of the parent                                                 |\n|              | EDC0000015               | document to the Bates number of the last page of                                             |\n|              |                          | the last attachment \"child\" document                                                         |\n| BEGATTACH    | EDC0000001               | First Bates number of attachment range                                                       |\n| ENDATTACH    | EDC0000015               | Last Bates number of attachment range                                                        |\n| CUSTODIAN    | Smith, John              | Email: Mailbox where the email resided                                                       |\n|              |                          | Native: Name of the individual or department                                                 |\n|              |                          | from whose files the document<br>originated                                                  |\n| FROM         | John Smith               | Email: Sender                                                                                |\n|              |                          | Native: Author(s) of document                                                                |\n|              |                          | **semi-colon should be used to separate                                                      |\n|              |                          | multiple entries                                                                             |\n| TO           | Coffman, Janice; LeeW    | Recipient(s)                                                                                 |\n|              | [mailto:LeeW@MSN.com]    | **semi-colon should be used to separate multiple                                             |\n|              |                          | entries                                                                                      |\n| CC           | Frank Thompson [mailto:  | Carbon copy recipient(s)                                                                     |\n|              | frank_Thompson@cdt.com]  | **semi-colon should be used to separate                                                      |\n|              |                          | multiple entries                                                                             |\n| BCC          | John Cain                | Blind carbon copy recipient(s)                                                               |\n|              |                          | **semi-colon should be used to separate                                                      |\n|              |                          | multiple entries                                                                             |\n| SUBJECT      | Board Meeting Minutes    | Email: Subject line of the email Native: Title                                               |\n|              |                          | of document (if available)                                                                   |\n| FILE_NAME    | BoardMeetingMinutes.docx | Native: Name of the original native file,                                                    |\n|              |                          | including extension                                                                          |\n| DATE_SENT    | 10/12/2010               | Email: Date the email was sent                                                               |\n|              |                          | Native: (empty)                                                                              |\n| TIME_SENT/   | 07:05 PM GMT             | Email: Time the email was sent/ Time zone in                                                 |\n| TIME_ZONE    |                          | which the emails were standardized                                                           |\n| TIME_ZONE    | GMT                      | The<br>time zone in which<br>the emails<br>were                                              |\n|              |                          | standardized during conversion.                                                              |\n| LINK         |  EDC0000001.msg   | Hyperlink to the email or native file document                                               |\n|              |                          | **The linked file must be named per the                                                      |\n|              |                          | FIRSTBATES number                                                                            |\n| FILE_EXTEN   | MSG                      | The file type extension                                                                      |\n|              |                          | representing                                                                                 |\n|              |                          | the Email or                                                                                 |\n| AUTHOR       | John Smith               | Email: (empty)                                                                               |\n|              |                          | Native: Author of the document                                                               |\n| DATE_CREATED | 10/10/2010               | Email: (empty)                                                                               |\n|              |                          | Native: Date the document was created                                                        |\n\n# Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 722 of 1063\n\n| TIME_CREATED | 10:25 AM                  | Email: (empty)                                  |\n|--------------|---------------------------|-------------------------------------------------|\n|              |                           | Native: Time the document was created           |\n|              |                           | **This data must be a separate field and cannot |\n|              |                           | be combined with the DATE_CREATED field         |\n| DATE_MOD     | 10/12/2010                | Email: (empty)                                  |\n|              |                           | Native: Date the document was last modified     |\n| TIME_MOD     | 07:00 PM                  | Email: (empty)                                  |\n|              |                           | Native: Time the document was last modified     |\n|              |                           | **This data must be a separate field and cannot |\n|              |                           | be combined with the DATE_MOD field             |\n| DATE_ACCESSD | 10/12/2010                | Email: (empty)                                  |\n|              |                           | Native: Date the document was last accessed     |\n| TIME_ACCESSD | 07:00 PM                  | Email: (empty)                                  |\n|              |                           | Native: Time the document was last accessed     |\n|              |                           | **This data must be a separate field and cannot |\n|              |                           | be combined with the DATE_ACCESSD field         |\n| FILE_SIZE    | 5,952                     | Size of native file<br>document/email in KB     |\n| PGCOUNT      | 1                         | Number of pages in native file document/email   |\n| PATH         |   | Email: (empty)                                  |\n|              | Agenda.doc                | Native: Path where native file document was     |\n|              |                           | stored including original file name.            |\n| INTFILEPATH  | Personal Folders\\Deleted  | Email: original location of email including     |\n|              | Items\\Board Meeting       | original file name.                             |\n|              | Minutes.msg               | Native: (empty)                                 |\n| INTMSGID     | <000805c2c71b\\$75977050\\$ | Email: Unique Message ID Native: (empty)        |\n|              | cb8306d1@MSN>             |                                                 |\n| MD5HASH      | d131dd02c5e6eec4693d9a0   | MD5 Hash value of the document.                 |\n|              | 698aff95c                 |                                                 |\n|              | 2fcab58712467eab4004583e  |                                                 |\n|              | b8fb7f89                  |                                                 |\n| OCRPATH      | TEXT/001/EDC0000001.txt   | Path to extracted text of the native file       |\n\n3. Each Request operates and should be construed independently and, unless otherwise indicated, no Request limits the scope of any other Request.\n\n4. All Documents are to be produced as kept in the usual course of business or are to be organized and labeled to correspond with the categories in these Requests.\n\n5. Each Request contained herein extends to all Documents: (a) in Your possession, custody, or control; or (b) in the possession, custody, or control of anyone acting on Your behalf,\n\n#### Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 723 of 1063\n\nincluding Your counsel or other representatives and advisors. Each Document shall be produced in its entirety.\n\n6. If You are requested to produce a Document that is no longer in Your possession, custody, or control, then Your response must (a) describe in detail the nature of the document and its contents; (b) identify the person(s) who prepared or authored the Document (and, if applicable, the Person(s) to whom the Document was sent); (c) identify the date on which the document was prepared or created; (d) state whether such Document (i) is missing or lost, (ii) has been destroyed, (iii) has been transferred, voluntarily or involuntarily, to others, or (iv) was otherwise disposed of; (e) state the reason for, and the facts and circumstances surrounding, such disposition; (f) identify the Persons who authorized such disposition; (g) identify the date or approximate date of such disposition; (h) state when the Document was most recently in Your possession, custody or control; and (i) identify the Person, if any, presently in possession, custody, or control of such Document.\n\n7. If You are requested to produce a Document that has been destroyed, then Your response must state, in addition to the information required by the preceding Instruction: (a) the reason for the Document's destruction; (b) the identity of the Person who destroyed the Document; and (c) the identity of the Person who directed that the Document be destroyed.\n\n8. If You claim that a requested Document is privileged or attorney work-product, then Your response must: (a) state (i) a description of the Document adequate to support Your contention that the Document is privileged, (ii) the title of the Document, (iii) the date of the Document, (iv) the author of the Document, (v) the addressee of the Document, (vi) the identity of each Person who received or saw the original or any draft, copy, or reproduction of the Document, (vii) whether the Document itself, or any information contained or referred to in the Document is in the possession, custody, or control of any other Persons, and if so, the identity of\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 724 of 1063\n\nsuch Persons, as well as a statement addressing how the information came into their possession, (viii) the claim of privilege under which the Document is withheld, and (ix) all of the circumstances upon which You will rely to support such claim of privilege; and (b) produce a privilege log containing all of the information requested in Part (a) of this Instruction for each Document withheld on the basis of a claim of privilege in accordance with D. Conn. L. Civ. R. 26(e). For any part of a Document Request as to which a claim of privilege or work product is not made, responsive documents should be provided in full.\n\n9. If a portion of an otherwise responsive Document contains information subject to a claim of privilege, only that portion of the Document subject to the claim of privilege shall be deleted or redacted from the Document following the instructions above, and the rest shall be produced.\n\n10. The Requests are continuing in nature. You are hereby instructed to (a) supplement or correct any responses later learned to be incomplete or incorrect immediately upon learning that a prior response was incomplete or incorrect; and (b) produce any additional Documents that are called for under the\n\n11. If a Document is in a language other than English, You should provide that Document. If a Document is in a language other than English, and an English translation exists, You should provide both Documents.\n\n12. All references to Entities includes all affiliates thereof.\n\n13. All references to individual names include all alternative names, aliased, or nicknames.\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 725 of 1063\n\n14. Unless otherwise expressly indicated, the period of time covered by the Document Requests is the period from February 5, 2012 to the date responses to the Document Requests are due.\n\n#### **II. RULES OF CONSTRUCTION**\n\n15. The use of (a) any singular noun shall be construed to include the plural, and vice versa, and (b) a verb in any tense shall be construed as the use of the verb in all other tenses.\n\n16. The terms (a) \"and\" and \"or\" shall be construed either conjunctively or disjunctively as necessary to bring within the scope of any request all responses that might otherwise be construed to be outside of its scope, and (b) \"each\" and \"any\" shall be deemed to include and encompass the words \"every\" and \"all.\"\n\n## **III. DEFINITIONS**\n\nThe definitions supplied by D. Conn. L. Civ. R. 26(c) and the rules of construction supplied by D. Conn. L. Civ. R. 26(d), as incorporated by D. Conn. Bankr. L.R. 2004-1(a), shall apply to the Document Requests. In addition, the following terms used in these Document Requests shall have the following meanings:\n\n1. \"You\" or \"Your\" or \"Yourself\" means and refers, to Prime Trust LLC, together with all of its affiliates, divisions, agencies, instrumentalities, departments, offices, partners, officers, directors, agents, attorneys, representatives, employees, and/or anyone acting on its behalf.\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 726 of 1063\n\n2. \"Debtor\" means Ho Wan Kwok (a/k/a Miles Kwok, Miles Guo, Guo Wengui, Guo Haoyun, 郭文贵, or any other alias), together with his employees, agents, counsel, advisors, or anyone acting on his behalf.\n\n3. \"Debtor's Son\" means Qiang Guo (a/k/a Mileson Kwok, 郭强, or any other alias), together with his employees, agents, counsel, advisors, or anyone acting on his behalf.\n\n4. \"Debtor's Daughter\" means Mei Guo (a/k/a Mei Gui, 郭美, or any other alias), together with her employees, agents, counsel, advisors, or anyone acting on her behalf.\n\n5. \"Debtor's Purported Wife\" means Hing Chi Ngok (a/k/a Hing Chi Ng, Yue Qingzhi, 岳庆芝, or any other alias), together with her employees, agents, counsel, advisors, or anyone acting on her behalf.\n\n6. \"Debtor's Family\" means, individually and collectively, the Debtor, the Debtor's Son, the Debtor's Daughter, and the Debtor's Purported Wife, and any other familial relation to the Debtor.\n\n7. \"2004 Discovery Targets\" means, individually and collectively, the Debtor, the Debtor's Family, RBB Bancorp, Royal Business Bank, U.S. Bank National Association, ACA Capital Group Limited, Himalaya International Financial Group Ltd., Himalaya International Clearing Ltd., Himalaya International Payments Ltd., Himalaya International Reserves Ltd., Jesse Brown, William Je, William Je, Eastern Profit Corporation Limited, HK International Funds Investments (USA) Limited LLC, Bravo Luck Limited, Golden Spring (New York) Ltd., Lamp Capital LLC, Greenwich Land LLC, Qu Guo Jiao, Daniel Thomas Podhaskie, Yvette Wang (a/k/a Yanping Wang, a/k/a Yan Ping Wang), Ace Decade Holdings Limited, Dawn State Limited, Rule of Law Society IV Inc., Rule of Law Foundation III, Inc., Rule of Law Foundation IV, Inc., Rule of Law Fund, Rule of Law Society, GTV Media Group, Inc., Voice of Guo Media, Inc., Saraca\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 727 of 1063\n\nMedia Group Inc., Genever Holdings Corporation, Genever Holdings LLC, Gnews Media Group Inc., G Fashion LLC, Gmusic LLC, Gnews LLC, Geducation, GFNY, Inc., G-Club Investments Limited, G Club Operations LLC, G Club US Operations Inc., G Club US Operations LLC, G Live, LLC, Gbroadcast, LLC, Gposts LLC, HCHK Property Management, Inc., HCHK Technologies, Inc., FMV Ltd./Freedom Media Venture Ltd., Roscalitar 2, Himalaya New World Inc., US Himalaya Capital Inc., Hudson Diamond Holding, Inc., Hudson Diamond Holding LLC, Hudson Diamond NY LLC, Infinity Treasury Management Inc., Lexington Property and Staffing, Inc., AI Group Holdings Inc., Hamilton Capital Holdings Inc., Booming Sail New York LLC, Himalaya Ventures LLC, Himalaya Ventures LLC, Himalaya Investment LLC, New York MOS Himalaya LLC, MOS Himalaya LLC, Crane Advisory Group, Maywind Trading LLC, Gettr USA, Inc., Han Chunguang, Bingshang Jiao, Karin Maistrello, Mary Jiang, Jiaming Liu, and Wencong Wang.\n\n8. \"Including\" or any variant thereof means \"including without limitation.\"\n\n9. \"And\" and \"or\" mean \"and/or,\" and shall be construed both conjunctively as well as disjunctively in order to maximize their scope.\n\n10. \"Any\" and \"all\" and \"each\" mean \"each and every.\"\n\n11. \"Each\" and \"every\" mean \"each and every.\"\n\n12. \"Third Party\" means a Person or Entity other than Yourself.\n\n13. \"Transfer\" shall have the meaning given to it by section 101(54) of the Bankruptcy Code.\n\n14. \"Document\" means any information or thing within the scope of Fed. R. Civ. P. 34, and includes, without limitation, each and every written, recorded, or graphic matter of any kind,\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 728 of 1063\n\ntype, nature, or description that is or has been in Your Possession, Custody or Control, including all printed and electronic copies of electronic mail, computer files maintained in electronic form, correspondence, memoranda, tapes, stenographic or handwritten notes, written forms of any kind, charts, blueprints, drawings, sketches, graphs, plans, articles, specifications, diaries, letters, telegrams, photographs, minutes, contracts, agreements, surveys, computer printouts, data compilations of any kind, telexes, facsimiles, emails, text messages, instant messages, voice messages, invoices, order forms, checks, drafts, statements, credit memos, reports, position reports, summaries, indices, books, ledgers, notebooks, schedules, transparencies, recordings, catalogs, advertisements, promotional materials, films, video tapes, audio tapes, CDs, computer disks, brochures, pamphlets, punch-cards, time-slips, Tweets, social media posts, or any written or recorded materials of any other kind, and all meta-data thereof, however stored (whether in tangible or electronic form), recorded, produced, or reproduced, and also including but not limited to, drafts or copies of any of the foregoing that contain any notes, comments, or markings of any kind not found on the original documents or that are otherwise not identical to the original documents.\n\n15. \"Person(s)\" means an individual, corporation, proprietorship, partnership, association, or any other Entity. \"Person\" also includes any agent, representatives, or expert, including but not limiting to, attorneys or financial advisors.\n\n16. \"Entity\" means any natural Person, corporation, partnership, subsidiary, sole proprietorship, firm, board, joint venture, association, agency, authority, commission or other business entity or juristic Person, as well as any affiliate, agent, parent including but not limited to counsel, financial advisors, or any other representative.\n\n#### Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 729 of 1063\n\n17. \"Regarding\" means concerning, describing, comprising, referring to, related to, supporting, favoring, opposing, bolstering, detracting from, located in, considered in connection with, bearing on, evidencing, indicating, reporting on, recording, alluding to, responding to, connected with, commenting on, in respect of, about, in relation to, discussing, showing, describing, reflecting, analyzing constituting, and being.\n\n18. \"Relating to,\" \"relate(s) to\" or \"related to,\" when referring to any given subject matter, means, without limitation, any document that constitutes, comprises, involves, contains, embodies, reflects, identifies, states, refers directly or indirectly to, or is in any way relevant to the particular subject matter identified.\n\n19. \"Communication(s)\" means, in the broadest possible sense, and without limitation, any transmittal of information or knowledge (in the form of facts, ideas, inquiries, or otherwise). Communication(s) further refers to all conversations, agreements, inquiries, or replies, whether in person, by telephone, in writing, or by means of electronic transmittal devices, and includes, but is not limited to, all correspondence, emails, recordings, transmittal slips, memoranda, telephone communications, voice messages, telegrams, telefaxes, telecopies, telexes, instant messages, chats, text messages, postings to a message board or group chat, social media posts, tweets, videos uploaded to any video platform, telephonic notes, or notes transmitted internally or with third parties.\n\n20. \"Asset(s)\" means any item of economic value that is subject to Possession, Custody, or Control. Asset includes all real and personal property, including but limited to, real estate, land, houses, apartments, condominiums, automobiles, yachts, boats, planes, jets, helicopters, cash, bank accounts, cryptocurrencies, securities, accounts receivables, inventory, and other tangible and intangible property.\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 730 of 1063\n\n#### **IV. DOCUMENTS TO BE PRODUCED**\n\n1. All Documents related to any account held by, controlled by, on behalf of, or otherwise related to any of the 2004 Discovery Targets, including any and all account statements, authorizations, power of attorney, trusts, instructions or forms, copies of cancelled checks, correspondence, and wire transfers and related correspondence and instructions.\n\n2. All Documents related to any funds, cryptocurrencies, securities, property, or assets belonging to, held by, controlled or transferred by, on behalf of, or otherwise related to any of the 2004 Discovery Targets, including any and all account statements, authorizations, powers of attorney, trusts, instructions or forms, copies of cancelled checks, correspondence, and wire transfers and related correspondence and instructions.\n\n3. All Documents related to any business, commerce or financial transactions, including but not limited to any loan, line of credit, bailment, deposit, swap, securities transactions, mortgage, or ISDA, with any of the 2004 Discovery Targets, including any and all account statements, authorizations, powers of attorney, trusts, instructions or forms, copies of cancelled checks, correspondence, and wire transfers and related correspondence and instructions.\n\n4. All Documents relating to any wire transfer activity relating to the 2004 Discovery Targets, regardless of the existence of any accounts, including but not limited to all wire transfer receipts, account numbers, balances, authorizations, identification information related to the parties to the transfer, correspondence, instructions, or other records.\n\n5. All Documents related to any correspondence and communications between you and the 2004 Discovery Targets.\n\n6. All Documents related to any account with any 2004 Discovery Target relating to opening of the account, authorized users of the account and maintenance of the account.\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 731 of 1063\n\n7. All Documents related to any anti-money laundering, know-your-customer, or other compliance activity relating to any of the 2004 Discovery Targets, including but not limited to any information provided by any of the 2004 Discovery Targets, or learned by You.\n\n8. All Documents relating to any communications with any regulator from any country, including but not limited to the Bank of England, the United States Federal Reserve, the S.E.C., the CFTC, FINRA, China Securities Regulatory Commission, People's Bank of China, Hong Kong Securities and Futures Commission, and the Hong Kong Monetary Authority relating to any of the 2004 Discovery Targets.\n\n# Exhibit C-40\n\n#### B2540 (Form 2540 – Subpoena for Rule 2004 Examination) (12/15) Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 733 of\n\n1063\n\nUNITED STATES BANKRUPTCY COURT\n\n**District of Connecticut**\n\nIn re HO WAN KWOK, *et al*.,\n\n<sup>1</sup> Case No. 22-50073 (JAM)\n\nDebtor Chapter 11\n\n(Jointly Administered)\n\n## **SUBPOENA FOR RULE 2004 EXAMINATION**\n\n## To: **RBB Bancorp and/or Royal Business Bank**\n\n(*Name of person to whom the subpoena is directed*)\n\n*Testimony:* **YOU ARE COMMANDED** to appear at the time, date, and place set forth below to testify at an examination under Rule 2004, Federal Rules of Bankruptcy Procedure. A copy of the court order authorizing the examination is attached.\n\n| PLACE                          | DATE AND TIME |\n|--------------------------------|---------------|\n| Neubert, Pepe & Monteith, P.C. |               |\n| 195 Church Street, Floor 13    | [TBD]         |\n| New Haven, Connecticut 06510   |               |\n|                                |               |\n\nThe examination will be recorded by this method: **Court reporter/stenographer**\n\n*Production:* You, or your representatives, must also bring with you to the examination the following documents, electronically stored information, or objects, and must permit inspection, copying, testing, or sampling of the material:\n\n#### **See Requests for Production of Documents, attached hereto.**\n\nThe following provisions of Fed. R. Civ. P. 45, made applicable in bankruptcy cases by Fed. R. Bankr. P. 9016, are attached – Rule 45(c), relating to the place of compliance; Rule 45(d), relating to your protection as a person subject to a subpoena; and Rule 45(e) and 45(g), relating to your duty to respond to this subpoena and the potential consequences of not doing so.\n\nDate: **March , 2023**\n\nCLERK OF COURT\n\nOR\n\n*Signature of Clerk or Deputy Clerk Attorney's signature*\n\nThe name, address, email address, and telephone number of the attorney representing Luc A. Despins, Chapter 11 Trustee, who issues or requests this subpoena, are:\n\n**Douglas S. Skalka, Esq.; Neubert, Pepe & Monteith, P.C.; 195 Church Street, New Haven, Connecticut 06510 dskalka@npmlaw.com; (203) 821-2000**\n\n**Notice to the person who issues or requests this subpoena**\n\nIf this subpoena commands the production of documents, electronically stored information, or tangible things, or the inspection of premises before trial, a notice and a copy of this subpoena must be served on each party before it is served on the person to whom it is directed. Fed. R. Civ. P. 45(a)(4).\n\nSoftware Copyright (c) 1996-2022 Best Case, LLC - www.bestcase.com Best Case Bankruptcy 1 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\n#### **PROOF OF SERVICE**\n\n**(This section should not be filed with the court unless required by Fed. R. Civ. P. 45.)**\n\nI received this subpoena for (*name of individual and title, if any*): on (*date*) .\n\nI served the subpoena by delivering a copy to the named person as follows:\n\non *(date)* ; or\n\nI returned the subpoena unexecuted because:\n\nUnless the subpoena was issued on behalf of the United States, or one of its officers or agents, I have also tendered to the witness the fees for one day's attendance, and the mileage allowed by law, in the amount of \\$ .\n\nMy fees are \\$ for travel and \\$ for services, for a total of \\$ .\n\nI declare under penalty of perjury that this information is true and correct.\n\nDate:\n\n*Server's signature*\n\n*Printed name and title*\n\n*Server's address*\n\nAdditional information concerning attempted service, etc.:\n\n#### **Federal Rule of Civil Procedure 45(c), (d), (e), and (g) (Effective 12/1/13) (made applicable in bankruptcy cases by Rule 9016, Federal Rules of Bankruptcy Procedure)**\n\n#### **(c) Place of compliance.**\n\n*(1) For a Trial, Hearing, or Deposition.* A subpoena may command a person to attend a trial, hearing, or deposition only as follows:\n\n(A) within 100 miles of where the person resides, is employed, or regularly transacts business in person; or\n\n(B) within the state where the person resides, is employed, or regularly transacts business in person, if the person\n\n(i) is a party or a party's officer; or\n\n(ii) is commanded to attend a trial and would not incur substantial expense.\n\n*(2) For Other Discovery.* A subpoena may command:\n\n(A) production of documents, or electronically stored information, or things at a place within 100 miles of where the person resides, is employed, or regularly transacts business in person; and\n\n(B) inspection of premises, at the premises to be inspected.\n\n#### **(d) Protecting a Person Subject to a Subpoena; Enforcement.**\n\n*(1) Avoiding Undue Burden or Expense; Sanctions.* A party or attorney responsible for issuing and serving a subpoena must take reasonable steps to avoid imposing undue burden or expense on a person subject to the subpoena. The court for the district where compliance is required must enforce this duty and impose an appropriate sanction which may include lost earnings and reasonable attorney's fees — on a party or attorney who fails to comply.\n\n#### *(2) Command to Produce Materials or Permit Inspection.*\n\n*(A) Appearance Not Required.* A person commanded to produce documents, electronically stored information, or tangible things, or to permit the inspection of premises, need not appear in person at the place of production or inspection unless also commanded to appear for a deposition, hearing, or trial.\n\n*(B) Objections.* A person commanded to produce documents or tangible things or to permit inspection may serve on the party or attorney designated in the subpoena a written objection to inspecting, copying, testing or sampling any or all of the materials or to inspecting the premises — or to producing electronically stored information in the form or forms requested. The objection must be served before the earlier of the time specified for compliance or 14 days after the subpoena is served. If an objection is made, the following rules apply:\n\n(i) At any time, on notice to the commanded person, the serving party may move the court for the district where compliance is required for an order compelling production or inspection.\n\n(ii) These acts may be required only as directed in the order, and the order must protect a person who is neither a party nor a party's officer from significant expense resulting from compliance.\n\n#### *(3) Quashing or Modifying a Subpoena.*\n\n*(A) When Required.* On timely motion, the court for the district where compliance is required must quash or modify a subpoena that:\n\n(i) fails to allow a reasonable time to comply;\n\n(ii) requires a person to comply beyond the geographical limits specified in Rule 45(c);\n\n(iii) requires disclosure of privileged or other protected matter, if no exception or waiver applies; or\n\n(iv) subjects a person to undue burden.\n\n*(B) When Permitted.* To protect a person subject to or affected by a subpoena, the court for the district where compliance is required may, on motion, quash or modify the subpoena if it requires:\n\n(i) disclosing a trade secret or other confidential research, development, or commercial information; or\n\n(ii) disclosing an unretained expert's opinion or information that does not describe specific occurrences in dispute and results from the expert's study that was not requested by a party.\n\n(C) *Specifying Conditions as an Alternative.* In the circumstances described in Rule 45(d)(3)(B), the court may, instead of quashing or modifying a subpoena, order appearance or production under specified conditions if the serving party:\n\n(i) shows a substantial need for the testimony or material that cannot be otherwise met without undue hardship; and\n\n(ii) ensures that the subpoenaed person will be reasonably compensated.\n\n#### **(e) Duties in Responding to a Subpoena.**\n\n*(1) Producing Documents or Electronically Stored Information.* These procedures apply to producing documents or electronically stored information:\n\n*(A) Documents.* A person responding to a subpoena to produce documents must produce them as they are kept in the ordinary course of business or must organize and label them to correspond to the categories in the demand.\n\n*(B) Form for Producing Electronically Stored Information Not Specified.* If a subpoena does not specify a form for producing electronically stored information, the person responding must produce it in a form or forms in which it is ordinarily maintained or in a reasonably usable form or forms.\n\n*(C) Electronically Stored Information Produced in Only One Form.* The person responding need not produce the same electronically stored information in more than one form.\n\n*(D) Inaccessible Electronically Stored Information.* The person responding need not provide discovery of electronically stored information from sources that the person identifies as not reasonably accessible because of undue burden or cost. On motion to compel discovery or for a protective order, the person responding must show that the information is not reasonably accessible because of undue burden or cost. If that showing is made, the court may nonetheless order discovery from such sources if the requesting party shows good cause, considering the limitations of Rule 26(b)(2)(C). The court may specify conditions for the discovery.\n\n#### *(2) Claiming Privilege or Protection.*\n\n*(A) Information Withheld.* A person withholding subpoenaed information under a claim that it is privileged or subject to protection as trial-preparation material must: (i) expressly make the claim; and\n\n(ii) describe the nature of the withheld documents, communications, or tangible things in a manner that, without revealing information itself privileged or protected, will enable the parties to assess the claim.\n\n*(B) Information Produced.* If information produced in response to a subpoena is subject to a claim of privilege or of protection as trial-preparation material, the person making the claim may notify any party that received the information of the claim and the basis for it. After being notified, a party must promptly return, sequester, or destroy the specified information and any copies it has; must not use or disclose the information until the claim is resolved; must take reasonable steps to retrieve the information if the party disclosed it before being notified; and may promptly present the information under seal to the court for the district where compliance is required for a determination of the claim. The person who produced the information must preserve the information until the claim is resolved.\n\n**(g) Contempt.** The court for the district where compliance is required – and also, after a motion is transferred, the issuing court – may hold in contempt a person who, having been served, fails without adequate excuse to obey the subpoena or an order related to it.\n\nFor access to subpoena materials, see Fed.R.Civ.P.45(a) Committee Note (2013)\n\n…\n\n## **Request for Production of Documents**\n\n## **I. INSTRUCTIONS**\n\n1. Unless otherwise indicated, the requests for documents set forth below, (the \"Requests,\" and each, a \"Request\"), must be responded to separately and specifically. Each Request shall be answered fully unless it is in good faith objected to, in which event the reason for Your objection shall be stated in detail, as set forth below. If an objection pertains only to a portion of a Request, or a word, phrase or clause contained within it, You are required to state Your objection to that portion only and to respond to the remainder of the Requests.\n\n2. Electronically stored information must be produced in accordance with the\n\nfollowing instructions:\n\n- a. Images. Black and white images must be 300 DPI Group IV single-page TIFF files. Color images must be produced in JPEG format. File names cannot contain embedded spaces or special characters (including the comma). Folder names cannot contain embedded spaces or special characters (including the comma). All TIFF image files must have a unique file name, i.e. Bates number. Images must be endorsed with sequential Bates numbers in the lower right corner of each image. The number of TIFF files per folder should not exceed 1000 files. Excel spreadsheets should have a placeholder image named by the Bates number of the file.\n- b. Image Load File\n\t- a. Concordance® Data File. The data file (.DAT) contains all of the fielded information that will be loaded into the Concordance® database. The first line of the .DAT file must be a header row identifying the field names. The .DAT file must use the following Concordance® default delimiters: Comma ASCII character (020) Quote þ ASCII character (254). Date fields should be provided in the format: mm/dd/yyyy. Date and time fields must be two separate fields. If documents includes imaged emails and attachments, the attachment fields must be included to preserve the parent/child relationship between an email and its attachments. An OCRPATH field must be included to provide the file path and name of the extracted text file on the produced storage media. The text file must be named after the FIRSTBATES. Do not include the text in the .DAT file. For Documents with native files, a LINK field must be included to provide the file path and\n\nname of the native file. The native file must be named after the FIRSTBATES.\n\n- b. Concordance Image® OR Opticon Cross-Reference File. The image crossreference file (.LOG or .OPT) links the images to the database records. It should be a comma-delimited file consisting of seven fields per line with a line in the cross-reference file for every image in the database with the following format: ImageID,VolumeLabel,ImageFilePath,DocumentBreak,FolderBreak,Box Break,PageCoun.\n- c. Document Text. Text must be produced as separate text files, not as fields within the .DAT file. The full path to the text file (OCRPATH) should be included in the .DAT file. It is recommended document level ANSI text files, named per the FIRSTBATES/Image Key. Extracted text files must be in a separate folder, and the number of text files per folder should not exceed 1,000 files. There should be no special characters (including commas in the folder names). Text files must be provided on a document level.\n- d. Native Production for Certain File Types. File types that reasonably require viewing in their native format for a full understanding of their content and meaning must be produced in native format. These include, but are not limited to, spreadsheets, spreadsheet-like files (Microsoft Excel, comma separated values, tab separated values, etc.), Microsoft PowerPoint or other special presentation files, database files, and audio/visual files. Provide an image of a Bates numbered slip sheet indicating the presence of a native file, and include the path to the native as a field in the .dat file. Name the produced native file with the Bates number corresponding to the slip sheet for the file. Group native files within incrementally named \"NATIVE\" directories, separate from images directories.\n- e. De-duplication. Produce a single copy of each electronic document for which exact duplicates exist. For email messages, consolidate duplicates based on MD5 hash generated from the BCC, Body, CC, From, IntMsgID, To, and Attach properties. For email attachments and standalone electronic files, consolidate duplicates based on MD5 hash of the entire file.\n- f. Metadata. Produce extracted metadata for each document in the form of a Concordance compliant load file (.dat). The first line of the .DAT file must be a header row identifying the field names. The .DAT file must use the following Concordance default delimiters: Comma , ASCII character (020) Quote þ ASCII character (254)\n\nDate fields should be provided in the format: mm/dd/yyyy. Date and time fields must be two separate fields. Required metadata listed below:\n\n# Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 738 of 1063\n\n| Field Name   | Sample Data              | Description                                      |\n|--------------|--------------------------|--------------------------------------------------|\n| FIRSTBATES   | EDC0000001               | First Bates number of native file document/email |\n| LASTBATES    | EDC0000001               | Last Bates number of native file document/email  |\n|              |                          | **The LASTBATES field should be populated        |\n|              |                          | for single page                                  |\n| ATTACHRANGE  | EDC0000001<br>-          | Bates number of the first page of the parent     |\n|              | EDC0000015               | document to the Bates number of the last page of |\n|              |                          | the last attachment \"child\" document             |\n| BEGATTACH    | EDC0000001               | First Bates number of attachment range           |\n| ENDATTACH    | EDC0000015               | Last Bates number of attachment range            |\n| CUSTODIAN    | Smith, John              | Email: Mailbox where the email resided           |\n|              |                          | Native: Name of the individual or department     |\n|              |                          | from whose files the document<br>originated      |\n| FROM         | John Smith               | Email: Sender                                    |\n|              |                          | Native: Author(s) of document                    |\n|              |                          | **semi-colon should be used to separate          |\n|              |                          | multiple entries                                 |\n| TO           | Coffman, Janice; LeeW    | Recipient(s)                                     |\n|              | [mailto:LeeW@MSN.com]    | **semi-colon should be used to separate multiple |\n|              |                          | entries                                          |\n| CC           | Frank Thompson [mailto:  | Carbon copy recipient(s)                         |\n|              | frank_Thompson@cdt.com]  | **semi-colon should be used to separate          |\n|              |                          | multiple entries                                 |\n| BCC          | John Cain                | Blind carbon copy recipient(s)                   |\n|              |                          | **semi-colon should be used to separate          |\n|              |                          | multiple entries                                 |\n| SUBJECT      | Board Meeting Minutes    | Email: Subject line of the email Native: Title   |\n|              |                          | of document (if available)                       |\n| FILE_NAME    | BoardMeetingMinutes.docx | Native: Name of the original native file,        |\n|              |                          | including extension                              |\n| DATE_SENT    | 10/12/2010               | Email: Date the email was sent                   |\n|              |                          | Native: (empty)                                  |\n| TIME_SENT/   | 07:05 PM GMT             | Email: Time the email was sent/ Time zone in     |\n| TIME_ZONE    |                          | which the emails were standardized               |\n| TIME_ZONE    | GMT                      | The<br>time zone in which<br>the emails<br>were  |\n|              |                          | standardized during conversion.                  |\n| LINK         |  EDC0000001.msg   | Hyperlink to the email or native file document   |\n|              |                          | **The linked file must be named per the          |\n|              |                          | FIRSTBATES number                                |\n| FILE_EXTEN   | MSG                      | The file type extension                          |\n|              |                          | representing                                     |\n|              |                          | the Email or                                     |\n| AUTHOR       | John Smith               | Email: (empty)                                   |\n|              |                          | Native: Author of the document                   |\n| DATE_CREATED | 10/10/2010               | Email: (empty)                                   |\n|              |                          | Native: Date the document was created            |\n\n# Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 739 of 1063\n\n| TIME_CREATED | 10:25 AM                  | Email: (empty)                                  |\n|--------------|---------------------------|-------------------------------------------------|\n|              |                           | Native: Time the document was created           |\n|              |                           | **This data must be a separate field and cannot |\n|              |                           | be combined with the DATE_CREATED field         |\n| DATE_MOD     | 10/12/2010                | Email: (empty)                                  |\n|              |                           | Native: Date the document was last modified     |\n| TIME_MOD     | 07:00 PM                  | Email: (empty)                                  |\n|              |                           | Native: Time the document was last modified     |\n|              |                           | **This data must be a separate field and cannot |\n|              |                           | be combined with the DATE_MOD field             |\n| DATE_ACCESSD | 10/12/2010                | Email: (empty)                                  |\n|              |                           | Native: Date the document was last accessed     |\n| TIME_ACCESSD | 07:00 PM                  | Email: (empty)                                  |\n|              |                           | Native: Time the document was last accessed     |\n|              |                           | **This data must be a separate field and cannot |\n|              |                           | be combined with the DATE_ACCESSD field         |\n| FILE_SIZE    | 5,952                     | Size of native file<br>document/email in KB     |\n| PGCOUNT      | 1                         | Number of pages in native file document/email   |\n| PATH         |   | Email: (empty)                                  |\n|              | Agenda.doc                | Native: Path where native file document was     |\n|              |                           | stored including original file name.            |\n| INTFILEPATH  | Personal Folders\\Deleted  | Email: original location of email including     |\n|              | Items\\Board Meeting       | original file name.                             |\n|              | Minutes.msg               | Native: (empty)                                 |\n| INTMSGID     | <000805c2c71b\\$75977050\\$ | Email: Unique Message ID Native: (empty)        |\n|              | cb8306d1@MSN>             |                                                 |\n| MD5HASH      | d131dd02c5e6eec4693d9a0   | MD5 Hash value of the document.                 |\n|              | 698aff95c                 |                                                 |\n|              | 2fcab58712467eab4004583e  |                                                 |\n|              | b8fb7f89                  |                                                 |\n| OCRPATH      | TEXT/001/EDC0000001.txt   | Path to extracted text of the native file       |\n\n3. Each Request operates and should be construed independently and, unless otherwise indicated, no Request limits the scope of any other Request.\n\n4. All Documents are to be produced as kept in the usual course of business or are to be organized and labeled to correspond with the categories in these Requests.\n\n5. Each Request contained herein extends to all Documents: (a) in Your possession, custody, or control; or (b) in the possession, custody, or control of anyone acting on Your behalf,\n\n#### Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 740 of 1063\n\nincluding Your counsel or other representatives and advisors. Each Document shall be produced in its entirety.\n\n6. If You are requested to produce a Document that is no longer in Your possession, custody, or control, then Your response must (a) describe in detail the nature of the document and its contents; (b) identify the person(s) who prepared or authored the Document (and, if applicable, the Person(s) to whom the Document was sent); (c) identify the date on which the document was prepared or created; (d) state whether such Document (i) is missing or lost, (ii) has been destroyed, (iii) has been transferred, voluntarily or involuntarily, to others, or (iv) was otherwise disposed of; (e) state the reason for, and the facts and circumstances surrounding, such disposition; (f) identify the Persons who authorized such disposition; (g) identify the date or approximate date of such disposition; (h) state when the Document was most recently in Your possession, custody or control; and (i) identify the Person, if any, presently in possession, custody, or control of such Document.\n\n7. If You are requested to produce a Document that has been destroyed, then Your response must state, in addition to the information required by the preceding Instruction: (a) the reason for the Document's destruction; (b) the identity of the Person who destroyed the Document; and (c) the identity of the Person who directed that the Document be destroyed.\n\n8. If You claim that a requested Document is privileged or attorney work-product, then Your response must: (a) state (i) a description of the Document adequate to support Your contention that the Document is privileged, (ii) the title of the Document, (iii) the date of the Document, (iv) the author of the Document, (v) the addressee of the Document, (vi) the identity of each Person who received or saw the original or any draft, copy, or reproduction of the Document, (vii) whether the Document itself, or any information contained or referred to in the Document is in the possession, custody, or control of any other Persons, and if so, the identity of\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 741 of 1063\n\nsuch Persons, as well as a statement addressing how the information came into their possession, (viii) the claim of privilege under which the Document is withheld, and (ix) all of the circumstances upon which You will rely to support such claim of privilege; and (b) produce a privilege log containing all of the information requested in Part (a) of this Instruction for each Document withheld on the basis of a claim of privilege in accordance with D. Conn. L. Civ. R. 26(e). For any part of a Document Request as to which a claim of privilege or work product is not made, responsive documents should be provided in full.\n\n9. If a portion of an otherwise responsive Document contains information subject to a claim of privilege, only that portion of the Document subject to the claim of privilege shall be deleted or redacted from the Document following the instructions above, and the rest shall be produced.\n\n10. The Requests are continuing in nature. You are hereby instructed to (a) supplement or correct any responses later learned to be incomplete or incorrect immediately upon learning that a prior response was incomplete or incorrect; and (b) produce any additional Documents that are called for under the\n\n11. If a Document is in a language other than English, You should provide that Document. If a Document is in a language other than English, and an English translation exists, You should provide both Documents.\n\n12. All references to Entities includes all affiliates thereof.\n\n13. All references to individual names include all alternative names, aliased, or nicknames.\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 742 of 1063\n\n14. Unless otherwise expressly indicated, the period of time covered by the Document Requests is the period from February 5, 2012 to the date responses to the Document Requests are due.\n\n#### **II. RULES OF CONSTRUCTION**\n\n15. The use of (a) any singular noun shall be construed to include the plural, and vice versa, and (b) a verb in any tense shall be construed as the use of the verb in all other tenses.\n\n16. The terms (a) \"and\" and \"or\" shall be construed either conjunctively or disjunctively as necessary to bring within the scope of any request all responses that might otherwise be construed to be outside of its scope, and (b) \"each\" and \"any\" shall be deemed to include and encompass the words \"every\" and \"all.\"\n\n## **III. DEFINITIONS**\n\nThe definitions supplied by D. Conn. L. Civ. R. 26(c) and the rules of construction supplied by D. Conn. L. Civ. R. 26(d), as incorporated by D. Conn. Bankr. L.R. 2004-1(a), shall apply to the Document Requests. In addition, the following terms used in these Document Requests shall have the following meanings:\n\n1. \"You\" or \"Your\" or \"Yourself\" means and refers, to RBB Bancorp and/or Royal Business Bank, together with all of its affiliates, divisions, agencies, instrumentalities, departments, offices, partners, officers, directors, agents, attorneys, representatives, employees, and/or anyone acting on its behalf.\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 743 of 1063\n\n2. \"Debtor\" means Ho Wan Kwok (a/k/a Miles Kwok, Miles Guo, Guo Wengui, Guo Haoyun, 郭文贵, or any other alias), together with his employees, agents, counsel, advisors, or anyone acting on his behalf.\n\n3. \"Debtor's Son\" means Qiang Guo (a/k/a Mileson Kwok, 郭强, or any other alias), together with his employees, agents, counsel, advisors, or anyone acting on his behalf.\n\n4. \"Debtor's Daughter\" means Mei Guo (a/k/a Mei Gui, 郭美, or any other alias), together with her employees, agents, counsel, advisors, or anyone acting on her behalf.\n\n5. \"Debtor's Purported Wife\" means Hing Chi Ngok (a/k/a Hing Chi Ng, Yue Qingzhi, 岳庆芝, or any other alias), together with her employees, agents, counsel, advisors, or anyone acting on her behalf.\n\n6. \"Debtor's Family\" means, individually and collectively, the Debtor, the Debtor's Son, the Debtor's Daughter, and the Debtor's Purported Wife, and any other familial relation to the Debtor.\n\n7. \"2004 Discovery Targets\" means, individually and collectively, the Debtor, the Debtor's Family, Prime Trust LLC, U.S. Bank National Association, ACA Capital Group Limited, Himalaya International Financial Group Ltd., Himalaya International Clearing Ltd., Himalaya International Payments Ltd., Himalaya International Reserves Ltd., Jesse Brown, William Je, William Je, Eastern Profit Corporation Limited, HK International Funds Investments (USA) Limited LLC, Bravo Luck Limited, Golden Spring (New York) Ltd., Lamp Capital LLC, Greenwich Land LLC, Qu Guo Jiao, Daniel Thomas Podhaskie, Yvette Wang (a/k/a Yanping Wang, a/k/a Yan Ping Wang), Ace Decade Holdings Limited, Dawn State Limited, Rule of Law Society IV Inc., Rule of Law Foundation III, Inc., Rule of Law Foundation IV, Inc., Rule of Law Fund, Rule of Law Society, GTV Media Group, Inc., Voice of Guo Media, Inc., Saraca Media\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 744 of 1063\n\nGroup Inc., Genever Holdings Corporation, Genever Holdings LLC, Gnews Media Group Inc., G Fashion LLC, Gmusic LLC, Gnews LLC, Geducation, GFNY, Inc., G-Club Investments Limited, G Club Operations LLC, G Club US Operations Inc., G Club US Operations LLC, G Live, LLC, Gbroadcast, LLC, Gposts LLC, HCHK Property Management, Inc., HCHK Technologies, Inc., FMV Ltd./Freedom Media Venture Ltd., Roscalitar 2, Himalaya New World Inc., US Himalaya Capital Inc., Hudson Diamond Holding, Inc., Hudson Diamond Holding LLC, Hudson Diamond NY LLC, Infinity Treasury Management Inc., Lexington Property and Staffing, Inc., AI Group Holdings Inc., Hamilton Capital Holdings Inc., Booming Sail New York LLC, Himalaya Ventures LLC, Himalaya Ventures LLC, Himalaya Investment LLC, New York MOS Himalaya LLC, MOS Himalaya LLC, Crane Advisory Group, Maywind Trading LLC, Gettr USA, Inc., Han Chunguang, Bingshang Jiao, Karin Maistrello, Mary Jiang, Jiaming Liu, and Wencong Wang.\n\n8. \"Including\" or any variant thereof means \"including without limitation.\"\n\n9. \"And\" and \"or\" mean \"and/or,\" and shall be construed both conjunctively as well as disjunctively in order to maximize their scope.\n\n10. \"Any\" and \"all\" and \"each\" mean \"each and every.\"\n\n11. \"Each\" and \"every\" mean \"each and every.\"\n\n12. \"Third Party\" means a Person or Entity other than Yourself.\n\n13. \"Transfer\" shall have the meaning given to it by section 101(54) of the Bankruptcy Code.\n\n14. \"Document\" means any information or thing within the scope of Fed. R. Civ. P. 34, and includes, without limitation, each and every written, recorded, or graphic matter of any kind, type, nature, or description that is or has been in Your Possession, Custody or Control, including\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 745 of 1063\n\nall printed and electronic copies of electronic mail, computer files maintained in electronic form, correspondence, memoranda, tapes, stenographic or handwritten notes, written forms of any kind, charts, blueprints, drawings, sketches, graphs, plans, articles, specifications, diaries, letters, telegrams, photographs, minutes, contracts, agreements, surveys, computer printouts, data compilations of any kind, telexes, facsimiles, emails, text messages, instant messages, voice messages, invoices, order forms, checks, drafts, statements, credit memos, reports, position reports, summaries, indices, books, ledgers, notebooks, schedules, transparencies, recordings, catalogs, advertisements, promotional materials, films, video tapes, audio tapes, CDs, computer disks, brochures, pamphlets, punch-cards, time-slips, Tweets, social media posts, or any written or recorded materials of any other kind, and all meta-data thereof, however stored (whether in tangible or electronic form), recorded, produced, or reproduced, and also including but not limited to, drafts or copies of any of the foregoing that contain any notes, comments, or markings of any kind not found on the original documents or that are otherwise not identical to the original documents.\n\n15. \"Person(s)\" means an individual, corporation, proprietorship, partnership, association, or any other Entity. \"Person\" also includes any agent, representatives, or expert, including but not limiting to, attorneys or financial advisors.\n\n16. \"Entity\" means any natural Person, corporation, partnership, subsidiary, sole proprietorship, firm, board, joint venture, association, agency, authority, commission or other business entity or juristic Person, as well as any affiliate, agent, parent including but not limited to counsel, financial advisors, or any other representative.\n\n17. \"Regarding\" means concerning, describing, comprising, referring to, related to, supporting, favoring, opposing, bolstering, detracting from, located in, considered in connection\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 746 of 1063\n\nwith, bearing on, evidencing, indicating, reporting on, recording, alluding to, responding to, connected with, commenting on, in respect of, about, in relation to, discussing, showing, describing, reflecting, analyzing constituting, and being.\n\n18. \"Relating to,\" \"relate(s) to\" or \"related to,\" when referring to any given subject matter, means, without limitation, any document that constitutes, comprises, involves, contains, embodies, reflects, identifies, states, refers directly or indirectly to, or is in any way relevant to the particular subject matter identified.\n\n19. \"Communication(s)\" means, in the broadest possible sense, and without limitation, any transmittal of information or knowledge (in the form of facts, ideas, inquiries, or otherwise). Communication(s) further refers to all conversations, agreements, inquiries, or replies, whether in person, by telephone, in writing, or by means of electronic transmittal devices, and includes, but is not limited to, all correspondence, emails, recordings, transmittal slips, memoranda, telephone communications, voice messages, telegrams, telefaxes, telecopies, telexes, instant messages, chats, text messages, postings to a message board or group chat, social media posts, tweets, videos uploaded to any video platform, telephonic notes, or notes transmitted internally or with third parties.\n\n20. \"Asset(s)\" means any item of economic value that is subject to Possession, Custody, or Control. Asset includes all real and personal property, including but limited to, real estate, land, houses, apartments, condominiums, automobiles, yachts, boats, planes, jets, helicopters, cash, bank accounts, cryptocurrencies, securities, accounts receivables, inventory, and other tangible and intangible property.\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 747 of 1063\n\n#### **IV. DOCUMENTS TO BE PRODUCED**\n\n1. All Documents related to any account held by, controlled by, on behalf of, or otherwise related to any of the 2004 Discovery Targets, including any and all account statements, authorizations, power of attorney, trusts, instructions or forms, copies of cancelled checks, correspondence, and wire transfers and related correspondence and instructions.\n\n2. All Documents related to any funds, cryptocurrencies, securities, property, or assets belonging to, held by, controlled by, on behalf of, or otherwise related to any of the 2004 Discovery Targets, including any and all account statements, authorizations, powers of attorney, trusts, instructions or forms, copies of cancelled checks, correspondence, and wire transfers and related correspondence and instructions.\n\n3. All Documents related to any business, commerce or financial transactions, including but not limited to any loan, line of credit, bailment, deposit, swap, securities transactions, mortgage, or ISDA, with any of the 2004 Discovery Targets, including any and all account statements, authorizations, powers of attorney, trusts, instructions or forms, copies of cancelled checks, correspondence, and wire transfers and related correspondence and instructions.\n\n4. All Documents relating to any wire transfer activity relating to the 2004 Discovery Targets, regardless of the existence of any accounts, including but not limited to all wire transfer receipts, account numbers, balances, authorizations, identification information related to the parties to the transfer, correspondence, instructions, or other records.\n\n5. All Documents related to any correspondence and communications between you and the 2004 Discovery Targets.\n\n6. All Documents related to any account with any 2004 Discovery Target relating to opening of the account, authorized users of the account and maintenance of the account.\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 748 of 1063\n\n7. All Documents related to any anti-money laundering, know-your-customer, or other compliance activity relating to any of the 2004 Discovery Targets, including but not limited to any information provided by any of the 2004 Discovery Targets, or learned by You.\n\n8. All Documents relating to any communications with any regulator from any country, including but not limited to the Bank of England, the United States Federal Reserve, the S.E.C., the CFTC, FINRA, China Securities Regulatory Commission, People's Bank of China, Hong Kong Securities and Futures Commission, and the Hong Kong Monetary Authority relating to any of the 2004 Discovery Targets.\n\n# Exhibit C-41\n\n#### B2540 (Form 2540 – Subpoena for Rule 2004 Examination) (12/15) Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 750 of\n\nUNITED STATES BANKRUPTCY COURT 1063\n\n**District of Connecticut**\n\nIn re HO WAN KWOK, *et al*.,\n\n<sup>1</sup> Case No. 22-50073 (JAM)\n\nDebtor Chapter 11\n\n(Jointly Administered)\n\n## **SUBPOENA FOR RULE 2004 EXAMINATION**\n\n## To: **Medici Bank International LLC**\n\n(*Name of person to whom the subpoena is directed*)\n\n*Testimony:* **YOU ARE COMMANDED** to appear at the time, date, and place set forth below to testify at an examination under Rule 2004, Federal Rules of Bankruptcy Procedure. A copy of the court order authorizing the examination is attached.\n\n| PLACE                    | DATE AND TIME |\n|--------------------------|---------------|\n| Paul Hastings LLP        |               |\n| 200 Park Avenue          | [TBD]         |\n| New York, New York 10166 |               |\n|                          |               |\n\nThe examination will be recorded by this method: **Court reporter/stenographer**\n\n*Production:* You, or your representatives, must also bring with you to the examination the following documents, electronically stored information, or objects, and must permit inspection, copying, testing, or sampling of the material:\n\n#### **See Requests for Production of Documents, attached hereto.**\n\nThe following provisions of Fed. R. Civ. P. 45, made applicable in bankruptcy cases by Fed. R. Bankr. P. 9016, are attached – Rule 45(c), relating to the place of compliance; Rule 45(d), relating to your protection as a person subject to a subpoena; and Rule 45(e) and 45(g), relating to your duty to respond to this subpoena and the potential consequences of not doing so.\n\nDate: **March , 2023**\n\nCLERK OF COURT\n\nOR\n\n*Signature of Clerk or Deputy Clerk Attorney's signature*\n\nThe name, address, email address, and telephone number of the attorney representing Luc A. Despins, Chapter 11 Trustee, who issues or requests this subpoena, are:\n\n**Douglas S. Skalka, Esq.; Neubert, Pepe & Monteith, P.C.; 195 Church Street, New Haven, Connecticut 06510 dskalka@npmlaw.com; (203) 821-2000**\n\n**Notice to the person who issues or requests this subpoena**\n\nIf this subpoena commands the production of documents, electronically stored information, or tangible things, or the inspection of premises before trial, a notice and a copy of this subpoena must be served on each party before it is served on the person to whom it is directed. Fed. R. Civ. P. 45(a)(4).\n\nSoftware Copyright (c) 1996-2022 Best Case, LLC - www.bestcase.com Best Case Bankruptcy 1 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\n#### **PROOF OF SERVICE**\n\n**(This section should not be filed with the court unless required by Fed. R. Civ. P. 45.)**\n\nI received this subpoena for (*name of individual and title, if any*): on (*date*) .\n\nI served the subpoena by delivering a copy to the named person as follows:\n\non *(date)* ; or\n\nI returned the subpoena unexecuted because:\n\nUnless the subpoena was issued on behalf of the United States, or one of its officers or agents, I have also tendered to the witness the fees for one day's attendance, and the mileage allowed by law, in the amount of \\$ .\n\nMy fees are \\$ for travel and \\$ for services, for a total of \\$ .\n\nI declare under penalty of perjury that this information is true and correct.\n\nDate:\n\n*Server's signature*\n\n*Printed name and title*\n\n*Server's address*\n\nAdditional information concerning attempted service, etc.:\n\n#### **Federal Rule of Civil Procedure 45(c), (d), (e), and (g) (Effective 12/1/13) (made applicable in bankruptcy cases by Rule 9016, Federal Rules of Bankruptcy Procedure)**\n\n#### **(c) Place of compliance.**\n\n*(1) For a Trial, Hearing, or Deposition.* A subpoena may command a person to attend a trial, hearing, or deposition only as follows:\n\n(A) within 100 miles of where the person resides, is employed, or regularly transacts business in person; or\n\n(B) within the state where the person resides, is employed, or regularly transacts business in person, if the person\n\n(i) is a party or a party's officer; or\n\n(ii) is commanded to attend a trial and would not incur substantial expense.\n\n*(2) For Other Discovery.* A subpoena may command:\n\n(A) production of documents, or electronically stored information, or things at a place within 100 miles of where the person resides, is employed, or regularly transacts business in person; and\n\n(B) inspection of premises, at the premises to be inspected.\n\n#### **(d) Protecting a Person Subject to a Subpoena; Enforcement.**\n\n*(1) Avoiding Undue Burden or Expense; Sanctions.* A party or attorney responsible for issuing and serving a subpoena must take reasonable steps to avoid imposing undue burden or expense on a person subject to the subpoena. The court for the district where compliance is required must enforce this duty and impose an appropriate sanction which may include lost earnings and reasonable attorney's fees — on a party or attorney who fails to comply.\n\n#### *(2) Command to Produce Materials or Permit Inspection.*\n\n*(A) Appearance Not Required.* A person commanded to produce documents, electronically stored information, or tangible things, or to permit the inspection of premises, need not appear in person at the place of production or inspection unless also commanded to appear for a deposition, hearing, or trial.\n\n*(B) Objections.* A person commanded to produce documents or tangible things or to permit inspection may serve on the party or attorney designated in the subpoena a written objection to inspecting, copying, testing or sampling any or all of the materials or to inspecting the premises — or to producing electronically stored information in the form or forms requested. The objection must be served before the earlier of the time specified for compliance or 14 days after the subpoena is served. If an objection is made, the following rules apply:\n\n(i) At any time, on notice to the commanded person, the serving party may move the court for the district where compliance is required for an order compelling production or inspection.\n\n(ii) These acts may be required only as directed in the order, and the order must protect a person who is neither a party nor a party's officer from significant expense resulting from compliance.\n\n#### *(3) Quashing or Modifying a Subpoena.*\n\n*(A) When Required.* On timely motion, the court for the district where compliance is required must quash or modify a subpoena that:\n\n(i) fails to allow a reasonable time to comply;\n\n(ii) requires a person to comply beyond the geographical limits specified in Rule 45(c);\n\n(iii) requires disclosure of privileged or other protected matter, if no exception or waiver applies; or\n\n(iv) subjects a person to undue burden.\n\n*(B) When Permitted.* To protect a person subject to or affected by a subpoena, the court for the district where compliance is required may, on motion, quash or modify the subpoena if it requires:\n\n(i) disclosing a trade secret or other confidential research, development, or commercial information; or\n\n(ii) disclosing an unretained expert's opinion or information that does not describe specific occurrences in dispute and results from the expert's study that was not requested by a party.\n\n(C) *Specifying Conditions as an Alternative.* In the circumstances described in Rule 45(d)(3)(B), the court may, instead of quashing or modifying a subpoena, order appearance or production under specified conditions if the serving party:\n\n(i) shows a substantial need for the testimony or material that cannot be otherwise met without undue hardship; and\n\n(ii) ensures that the subpoenaed person will be reasonably compensated.\n\n#### **(e) Duties in Responding to a Subpoena.**\n\n*(1) Producing Documents or Electronically Stored Information.* These procedures apply to producing documents or electronically stored information:\n\n*(A) Documents.* A person responding to a subpoena to produce documents must produce them as they are kept in the ordinary course of business or must organize and label them to correspond to the categories in the demand.\n\n*(B) Form for Producing Electronically Stored Information Not Specified.* If a subpoena does not specify a form for producing electronically stored information, the person responding must produce it in a form or forms in which it is ordinarily maintained or in a reasonably usable form or forms.\n\n*(C) Electronically Stored Information Produced in Only One Form.* The person responding need not produce the same electronically stored information in more than one form.\n\n*(D) Inaccessible Electronically Stored Information.* The person responding need not provide discovery of electronically stored information from sources that the person identifies as not reasonably accessible because of undue burden or cost. On motion to compel discovery or for a protective order, the person responding must show that the information is not reasonably accessible because of undue burden or cost. If that showing is made, the court may nonetheless order discovery from such sources if the requesting party shows good cause, considering the limitations of Rule 26(b)(2)(C). The court may specify conditions for the discovery.\n\n#### *(2) Claiming Privilege or Protection.*\n\n*(A) Information Withheld.* A person withholding subpoenaed information under a claim that it is privileged or subject to protection as trial-preparation material must: (i) expressly make the claim; and\n\n(ii) describe the nature of the withheld documents, communications, or tangible things in a manner that, without revealing information itself privileged or protected, will enable the parties to assess the claim.\n\n*(B) Information Produced.* If information produced in response to a subpoena is subject to a claim of privilege or of protection as trial-preparation material, the person making the claim may notify any party that received the information of the claim and the basis for it. After being notified, a party must promptly return, sequester, or destroy the specified information and any copies it has; must not use or disclose the information until the claim is resolved; must take reasonable steps to retrieve the information if the party disclosed it before being notified; and may promptly present the information under seal to the court for the district where compliance is required for a determination of the claim. The person who produced the information must preserve the information until the claim is resolved.\n\n**(g) Contempt.** The court for the district where compliance is required – and also, after a motion is transferred, the issuing court – may hold in contempt a person who, having been served, fails without adequate excuse to obey the subpoena or an order related to it.\n\nFor access to subpoena materials, see Fed.R.Civ.P.45(a) Committee Note (2013)\n\n…\n\n## **Request for Production of Documents**\n\n## **I. INSTRUCTIONS**\n\n1. Unless otherwise indicated, the requests for documents set forth below, (the \"Requests,\" and each, a \"Request\"), must be responded to separately and specifically. Each Request shall be answered fully unless it is in good faith objected to, in which event the reason for Your objection shall be stated in detail, as set forth below. If an objection pertains only to a portion of a Request, or a word, phrase or clause contained within it, You are required to state Your objection to that portion only and to respond to the remainder of the Requests.\n\n2. Electronically stored information must be produced in accordance with the\n\nfollowing instructions:\n\n- a. Images. Black and white images must be 300 DPI Group IV single-page TIFF files. Color images must be produced in JPEG format. File names cannot contain embedded spaces or special characters (including the comma). Folder names cannot contain embedded spaces or special characters (including the comma). All TIFF image files must have a unique file name, i.e. Bates number. Images must be endorsed with sequential Bates numbers in the lower right corner of each image. The number of TIFF files per folder should not exceed 1000 files. Excel spreadsheets should have a placeholder image named by the Bates number of the file.\n- b. Image Load File\n\t- a. Concordance® Data File. The data file (.DAT) contains all of the fielded information that will be loaded into the Concordance® database. The first line of the .DAT file must be a header row identifying the field names. The .DAT file must use the following Concordance® default delimiters: Comma ASCII character (020) Quote þ ASCII character (254). Date fields should be provided in the format: mm/dd/yyyy. Date and time fields must be two separate fields. If documents includes imaged emails and attachments, the attachment fields must be included to preserve the parent/child relationship between an email and its attachments. An OCRPATH field must be included to provide the file path and name of the extracted text file on the produced storage media. The text file must be named after the FIRSTBATES. Do not include the text in the .DAT file. For Documents with native files, a LINK field must be included to provide the file path and\n\nname of the native file. The native file must be named after the FIRSTBATES.\n\n- b. Concordance Image® OR Opticon Cross-Reference File. The image crossreference file (.LOG or .OPT) links the images to the database records. It should be a comma-delimited file consisting of seven fields per line with a line in the cross-reference file for every image in the database with the following format: ImageID,VolumeLabel,ImageFilePath,DocumentBreak,FolderBreak,Box Break,PageCoun.\n- c. Document Text. Text must be produced as separate text files, not as fields within the .DAT file. The full path to the text file (OCRPATH) should be included in the .DAT file. It is recommended document level ANSI text files, named per the FIRSTBATES/Image Key. Extracted text files must be in a separate folder, and the number of text files per folder should not exceed 1,000 files. There should be no special characters (including commas in the folder names). Text files must be provided on a document level.\n- d. Native Production for Certain File Types. File types that reasonably require viewing in their native format for a full understanding of their content and meaning must be produced in native format. These include, but are not limited to, spreadsheets, spreadsheet-like files (Microsoft Excel, comma separated values, tab separated values, etc.), Microsoft PowerPoint or other special presentation files, database files, and audio/visual files. Provide an image of a Bates numbered slip sheet indicating the presence of a native file, and include the path to the native as a field in the .dat file. Name the produced native file with the Bates number corresponding to the slip sheet for the file. Group native files within incrementally named \"NATIVE\" directories, separate from images directories.\n- e. De-duplication. Produce a single copy of each electronic document for which exact duplicates exist. For email messages, consolidate duplicates based on MD5 hash generated from the BCC, Body, CC, From, IntMsgID, To, and Attach properties. For email attachments and standalone electronic files, consolidate duplicates based on MD5 hash of the entire file.\n- f. Metadata. Produce extracted metadata for each document in the form of a Concordance compliant load file (.dat). The first line of the .DAT file must be a header row identifying the field names. The .DAT file must use the following Concordance default delimiters: Comma , ASCII character (020) Quote þ ASCII character (254)\n\nDate fields should be provided in the format: mm/dd/yyyy. Date and time fields must be two separate fields. Required metadata listed below:\n\n# Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 755 of 1063\n\n| Field Name   | Sample Data              | Description                                                                                  |\n|--------------|--------------------------|----------------------------------------------------------------------------------------------|\n| FIRSTBATES   | EDC0000001               | First Bates number of native file document/email                                             |\n| LASTBATES    | EDC0000001               | Last Bates number of native file document/email<br>**The LASTBATES field should be populated |\n|              |                          | for single page                                                                              |\n| ATTACHRANGE  | EDC0000001<br>-          | Bates number of the first page of the parent                                                 |\n|              | EDC0000015               | document to the Bates number of the last page of                                             |\n|              |                          | the last attachment \"child\" document                                                         |\n| BEGATTACH    | EDC0000001               | First Bates number of attachment range                                                       |\n| ENDATTACH    | EDC0000015               | Last Bates number of attachment range                                                        |\n| CUSTODIAN    | Smith, John              | Email: Mailbox where the email resided                                                       |\n|              |                          | Native: Name of the individual or department                                                 |\n|              |                          | from whose files the document<br>originated                                                  |\n| FROM         | John Smith               | Email: Sender                                                                                |\n|              |                          | Native: Author(s) of document                                                                |\n|              |                          | **semi-colon should be used to separate                                                      |\n|              |                          | multiple entries                                                                             |\n| TO           | Coffman, Janice; LeeW    | Recipient(s)                                                                                 |\n|              | [mailto:LeeW@MSN.com]    | **semi-colon should be used to separate multiple                                             |\n|              |                          | entries                                                                                      |\n| CC           | Frank Thompson [mailto:  | Carbon copy recipient(s)                                                                     |\n|              | frank_Thompson@cdt.com]  | **semi-colon should be used to separate                                                      |\n|              |                          | multiple entries                                                                             |\n| BCC          | John Cain                | Blind carbon copy recipient(s)                                                               |\n|              |                          | **semi-colon should be used to separate                                                      |\n|              |                          | multiple entries                                                                             |\n| SUBJECT      | Board Meeting Minutes    | Email: Subject line of the email Native: Title                                               |\n|              |                          | of document (if available)                                                                   |\n| FILE_NAME    | BoardMeetingMinutes.docx | Native: Name of the original native file,                                                    |\n|              |                          | including extension                                                                          |\n| DATE_SENT    | 10/12/2010               | Email: Date the email was sent                                                               |\n|              |                          | Native: (empty)                                                                              |\n| TIME_SENT/   | 07:05 PM GMT             | Email: Time the email was sent/ Time zone in                                                 |\n| TIME_ZONE    |                          | which the emails were standardized                                                           |\n| TIME_ZONE    | GMT                      | The<br>time zone in which<br>the emails<br>were                                              |\n|              |                          | standardized during conversion.                                                              |\n| LINK         |  EDC0000001.msg   | Hyperlink to the email or native file document                                               |\n|              |                          | **The linked file must be named per the                                                      |\n|              |                          | FIRSTBATES number                                                                            |\n| FILE_EXTEN   | MSG                      | The file type extension                                                                      |\n|              |                          | representing                                                                                 |\n|              |                          | the Email or                                                                                 |\n| AUTHOR       | John Smith               | Email: (empty)                                                                               |\n|              |                          | Native: Author of the document                                                               |\n| DATE_CREATED | 10/10/2010               | Email: (empty)                                                                               |\n|              |                          | Native: Date the document was created                                                        |\n\n# Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 756 of 1063\n\n| TIME_CREATED | 10:25 AM                  | Email: (empty)                                  |\n|--------------|---------------------------|-------------------------------------------------|\n|              |                           | Native: Time the document was created           |\n|              |                           | **This data must be a separate field and cannot |\n|              |                           | be combined with the DATE_CREATED field         |\n| DATE_MOD     | 10/12/2010                | Email: (empty)                                  |\n|              |                           | Native: Date the document was last modified     |\n| TIME_MOD     | 07:00 PM                  | Email: (empty)                                  |\n|              |                           | Native: Time the document was last modified     |\n|              |                           | **This data must be a separate field and cannot |\n|              |                           | be combined with the DATE_MOD field             |\n| DATE_ACCESSD | 10/12/2010                | Email: (empty)                                  |\n|              |                           | Native: Date the document was last accessed     |\n| TIME_ACCESSD | 07:00 PM                  | Email: (empty)                                  |\n|              |                           | Native: Time the document was last accessed     |\n|              |                           | **This data must be a separate field and cannot |\n|              |                           | be combined with the DATE_ACCESSD field         |\n| FILE_SIZE    | 5,952                     | Size of native file<br>document/email in KB     |\n| PGCOUNT      | 1                         | Number of pages in native file document/email   |\n| PATH         |   | Email: (empty)                                  |\n|              | Agenda.doc                | Native: Path where native file document was     |\n|              |                           | stored including original file name.            |\n| INTFILEPATH  | Personal Folders\\Deleted  | Email: original location of email including     |\n|              | Items\\Board Meeting       | original file name.                             |\n|              | Minutes.msg               | Native: (empty)                                 |\n| INTMSGID     | <000805c2c71b\\$75977050\\$ | Email: Unique Message ID Native: (empty)        |\n|              | cb8306d1@MSN>             |                                                 |\n| MD5HASH      | d131dd02c5e6eec4693d9a0   | MD5 Hash value of the document.                 |\n|              | 698aff95c                 |                                                 |\n|              | 2fcab58712467eab4004583e  |                                                 |\n|              | b8fb7f89                  |                                                 |\n| OCRPATH      | TEXT/001/EDC0000001.txt   | Path to extracted text of the native file       |\n\n3. Each Request operates and should be construed independently and, unless otherwise indicated, no Request limits the scope of any other Request.\n\n4. All Documents are to be produced as kept in the usual course of business or are to be organized and labeled to correspond with the categories in these Requests.\n\n5. Each Request contained herein extends to all Documents: (a) in Your possession, custody, or control; or (b) in the possession, custody, or control of anyone acting on Your behalf,\n\n#### Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 757 of 1063\n\nincluding Your counsel or other representatives and advisors. Each Document shall be produced in its entirety.\n\n6. If You are requested to produce a Document that is no longer in Your possession, custody, or control, then Your response must (a) describe in detail the nature of the document and its contents; (b) identify the person(s) who prepared or authored the Document (and, if applicable, the Person(s) to whom the Document was sent); (c) identify the date on which the document was prepared or created; (d) state whether such Document (i) is missing or lost, (ii) has been destroyed, (iii) has been transferred, voluntarily or involuntarily, to others, or (iv) was otherwise disposed of; (e) state the reason for, and the facts and circumstances surrounding, such disposition; (f) identify the Persons who authorized such disposition; (g) identify the date or approximate date of such disposition; (h) state when the Document was most recently in Your possession, custody or control; and (i) identify the Person, if any, presently in possession, custody, or control of such Document.\n\n7. If You are requested to produce a Document that has been destroyed, then Your response must state, in addition to the information required by the preceding Instruction: (a) the reason for the Document's destruction; (b) the identity of the Person who destroyed the Document; and (c) the identity of the Person who directed that the Document be destroyed.\n\n8. If You claim that a requested Document is privileged or attorney work-product, then Your response must: (a) state (i) a description of the Document adequate to support Your contention that the Document is privileged, (ii) the title of the Document, (iii) the date of the Document, (iv) the author of the Document, (v) the addressee of the Document, (vi) the identity of each Person who received or saw the original or any draft, copy, or reproduction of the Document, (vii) whether the Document itself, or any information contained or referred to in the Document is in the possession, custody, or control of any other Persons, and if so, the identity of\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 758 of 1063\n\nsuch Persons, as well as a statement addressing how the information came into their possession, (viii) the claim of privilege under which the Document is withheld, and (ix) all of the circumstances upon which You will rely to support such claim of privilege; and (b) produce a privilege log containing all of the information requested in Part (a) of this Instruction for each Document withheld on the basis of a claim of privilege in accordance with D. Conn. L. Civ. R. 26(e). For any part of a Document Request as to which a claim of privilege or work product is not made, responsive documents should be provided in full.\n\n9. If a portion of an otherwise responsive Document contains information subject to a claim of privilege, only that portion of the Document subject to the claim of privilege shall be deleted or redacted from the Document following the instructions above, and the rest shall be produced.\n\n10. The Requests are continuing in nature. You are hereby instructed to (a) supplement or correct any responses later learned to be incomplete or incorrect immediately upon learning that a prior response was incomplete or incorrect; and (b) produce any additional Documents that are called for under the\n\n11. If a Document is in a language other than English, You should provide that Document. If a Document is in a language other than English, and an English translation exists, You should provide both Documents.\n\n12. All references to Entities includes all affiliates thereof.\n\n13. All references to individual names include all alternative names, aliased, or nicknames.\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 759 of 1063\n\n14. Unless otherwise expressly indicated, the period of time covered by the Document Requests is the period from February 5, 2012 to the date responses to the Document Requests are due.\n\n#### **II. RULES OF CONSTRUCTION**\n\n15. The use of (a) any singular noun shall be construed to include the plural, and vice versa, and (b) a verb in any tense shall be construed as the use of the verb in all other tenses.\n\n16. The terms (a) \"and\" and \"or\" shall be construed either conjunctively or disjunctively as necessary to bring within the scope of any request all responses that might otherwise be construed to be outside of its scope, and (b) \"each\" and \"any\" shall be deemed to include and encompass the words \"every\" and \"all.\"\n\n#### **III. DEFINITIONS**\n\nThe definitions supplied by D. Conn. L. Civ. R. 26(c) and the rules of construction supplied by D. Conn. L. Civ. R. 26(d), as incorporated by D. Conn. Bankr. L.R. 2004-1(a), shall apply to the Document Requests. In addition, the following terms used in these Document Requests shall have the following meanings:\n\n1. \"You\" or \"Your\" or \"Yourself\" means and refers, to Medici Bank International LLC.\n\n2. \"Debtor\" means Ho Wan Kwok (a/k/a Miles Kwok, Miles Guo, Guo Wengui, Guo Haoyun, 郭文贵, or any other alias), together with his employees, agents, counsel, advisors, or anyone acting on his behalf.\n\n#### Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 760 of 1063\n\n3. \"Debtor's Son\" means Qiang Guo (a/k/a Mileson Kwok, 郭强, or any other alias), together with his employees, agents, counsel, advisors, or anyone acting on his behalf.\n\n4. \"Debtor's Daughter\" means Mei Guo (a/k/a Mei Gui, 郭美, or any other alias), together with her employees, agents, counsel, advisors, or anyone acting on her behalf.\n\n5. \"Debtor's Purported Wife\" means Hing Chi Ngok (a/k/a Hing Chi Ng, Yue Qingzhi, 岳庆芝, or any other alias), together with her employees, agents, counsel, advisors, or anyone acting on her behalf.\n\n6. \"Debtor's Family\" means, individually and collectively, the Debtor, the Debtor's Son, the Debtor's Daughter, and the Debtor's Purported Wife, and any other familial relation to the Debtor.\n\n7. \"2004 Discovery Targets\" means, individually and collectively, the Debtor, the Debtor's Family, ACA Capital Group Limited, Himalaya International Financial Group Ltd., Himalaya International Clearing Ltd., Himalaya International Payments Ltd., Himalaya International Reserves Ltd., Jesse Brown, William Je, William Je, Eastern Profit Corporation Limited, HK International Funds Investments (USA) Limited LLC, Bravo Luck Limited, Golden Spring (New York) Ltd., Lamp Capital LLC, Greenwich Land LLC, Qu Guo Jiao, Daniel Thomas Podhaskie, Yvette Wang (a/k/a Yanping Wang, a/k/a Yan Ping Wang), Ace Decade Holdings Limited, Dawn State Limited, Rule of Law Society IV Inc., Rule of Law Foundation III, Inc., Rule of Law Foundation IV, Inc., Rule of Law Fund, Rule of Law Society, GTV Media Group, Inc., Voice of Guo Media, Inc., Saraca Media Group Inc., Genever Holdings Corporation, Genever Holdings LLC, Gnews Media Group Inc., G Fashion LLC, Gmusic LLC, Gnews LLC, Geducation, GFNY, Inc., G-Club Investments Limited, G Club Operations LLC, G Club US Operations Inc., G Club US Operations LLC, G Live, LLC, Gbroadcast, LLC, Gposts LLC, HCHK Property\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 761 of 1063\n\nManagement, Inc., HCHK Technologies, Inc., FMV Ltd./Freedom Media Venture Ltd., Roscalitar 2, Himalaya New World Inc., US Himalaya Capital Inc., Hudson Diamond Holding, Inc., Hudson Diamond Holding LLC, Hudson Diamond NY LLC, Infinity Treasury Management Inc., Lexington Property and Staffing, Inc., AI Group Holdings Inc., Hamilton Capital Holdings Inc., Booming Sail New York LLC, Himalaya Ventures LLC, Himalaya Ventures LLC, Himalaya Investment LLC, New York MOS Himalaya LLC, MOS Himalaya LLC, Crane Advisory Group, Maywind Trading LLC, Gettr USA, Inc., Han Chunguang, Bingshang Jiao, Karin Maistrello, Mary Jiang, Jiaming Liu, and Wencong Wang.\n\n8. \"Including\" or any variant thereof means \"including without limitation.\"\n\n9. \"And\" and \"or\" mean \"and/or,\" and shall be construed both conjunctively as well as disjunctively in order to maximize their scope.\n\n10. \"Any\" and \"all\" and \"each\" mean \"each and every.\"\n\n11. \"Each\" and \"every\" mean \"each and every.\"\n\n12. \"Third Party\" means a Person or Entity other than Yourself.\n\n13. \"Transfer\" shall have the meaning given to it by section 101(54) of the Bankruptcy Code.\n\n14. \"Document\" means any information or thing within the scope of Fed. R. Civ. P. 34, and includes, without limitation, each and every written, recorded, or graphic matter of any kind, type, nature, or description that is or has been in Your Possession, Custody or Control, including all printed and electronic copies of electronic mail, computer files maintained in electronic form, correspondence, memoranda, tapes, stenographic or handwritten notes, written forms of any kind, charts, blueprints, drawings, sketches, graphs, plans, articles, specifications, diaries, letters,\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 762 of 1063\n\ntelegrams, photographs, minutes, contracts, agreements, surveys, computer printouts, data compilations of any kind, telexes, facsimiles, emails, text messages, instant messages, voice messages, invoices, order forms, checks, drafts, statements, credit memos, reports, position reports, summaries, indices, books, ledgers, notebooks, schedules, transparencies, recordings, catalogs, advertisements, promotional materials, films, video tapes, audio tapes, CDs, computer disks, brochures, pamphlets, punch-cards, time-slips, Tweets, social media posts, or any written or recorded materials of any other kind, and all meta-data thereof, however stored (whether in tangible or electronic form), recorded, produced, or reproduced, and also including but not limited to, drafts or copies of any of the foregoing that contain any notes, comments, or markings of any kind not found on the original documents or that are otherwise not identical to the original documents.\n\n15. \"Person(s)\" means an individual, corporation, proprietorship, partnership, association, or any other Entity. \"Person\" also includes any agent, representatives, or expert, including but not limiting to, attorneys or financial advisors.\n\n16. \"Entity\" means any natural Person, corporation, partnership, subsidiary, sole proprietorship, firm, board, joint venture, association, agency, authority, commission or other business entity or juristic Person, as well as any affiliate, agent, parent including but not limited to counsel, financial advisors, or any other representative.\n\n17. \"Regarding\" means concerning, describing, comprising, referring to, related to, supporting, favoring, opposing, bolstering, detracting from, located in, considered in connection with, bearing on, evidencing, indicating, reporting on, recording, alluding to, responding to, connected with, commenting on, in respect of, about, in relation to, discussing, showing, describing, reflecting, analyzing constituting, and being.\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 763 of 1063\n\n18. \"Relating to,\" \"relate(s) to\" or \"related to,\" when referring to any given subject matter, means, without limitation, any document that constitutes, comprises, involves, contains, embodies, reflects, identifies, states, refers directly or indirectly to, or is in any way relevant to the particular subject matter identified.\n\n19. \"Communication(s)\" means, in the broadest possible sense, and without limitation, any transmittal of information or knowledge (in the form of facts, ideas, inquiries, or otherwise). Communication(s) further refers to all conversations, agreements, inquiries, or replies, whether in person, by telephone, in writing, or by means of electronic transmittal devices, and includes, but is not limited to, all correspondence, emails, recordings, transmittal slips, memoranda, telephone communications, voice messages, telegrams, telefaxes, telecopies, telexes, instant messages, chats, text messages, postings to a message board or group chat, social media posts, tweets, videos uploaded to any video platform, telephonic notes, or notes transmitted internally or with third parties.\n\n20. \"Asset(s)\" means any item of economic value that is subject to Possession, Custody, or Control. Asset includes all real and personal property, including but limited to, real estate, land, houses, apartments, condominiums, automobiles, yachts, boats, planes, jets, helicopters, cash, bank accounts, cryptocurrencies, securities, accounts receivables, inventory, and other tangible and intangible property.\n\n#### **IV. DOCUMENTS TO BE PRODUCED**\n\n1. All Documents related to any account held by, controlled by, on behalf of, or otherwise related to any of the 2004 Discovery Targets, including any and all account statements, authorizations, power of attorney, trusts, instructions or forms, copies of cancelled checks, correspondence, and wire transfers and related correspondence and instructions.\n\n#### Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 764 of 1063\n\n2. All Documents related to any funds, securities, property, or assets belonging to, held by, controlled by, on behalf of, or otherwise related to any of the 2004 Discovery Targets, including any and all account statements, authorizations, powers of attorney, trusts, instructions or forms, copies of cancelled checks, correspondence, and wire transfers and related correspondence and instructions.\n\n3. All Documents related to any business, commerce or financial transactions, including but not limited to any loan, line of credit, bailment, deposit, swap, securities transactions, mortgage, or ISDA, with any of the 2004 Discovery Targets, including any and all account statements, authorizations, powers of attorney, trusts, instructions or forms, copies of cancelled checks, correspondence, and wire transfers and related correspondence and instructions.\n\n4. All Documents relating to any wire transfer activity relating to the 2004 Discovery Targets, regardless of the existence of any accounts, including but not limited to all wire transfer receipts, account numbers, balances, authorizations, identification information related to the parties to the transfer, correspondence, instructions, or other records.\n\n5. All Documents related to any correspondence and communications between you and the 2004 Discovery Targets.\n\n6. All Documents related to any account with any 2004 Discovery Target relating to opening of the account, authorized users of the account and maintenance of the account.\n\n7. All Documents related to any anti-money laundering, know-your-customer, or other compliance activity relating to any of the 2004 Discovery Targets, including but not limited to any information provided by any of the 2004 Discovery Targets, or learned by You.\n\n8. All Documents relating to any communications with any regulator from any country, including but not limited to the Bank of England, the United States Federal Reserve, the\n\nS.E.C., the CFTC, FINRA, China Securities Regulatory Commission, People's Bank of China, Hong Kong Securities and Futures Commission, and the Hong Kong Monetary Authority relating to any of the 2004 Discovery Targets.\n\nCase 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 766 of 1063\n\n# Exhibit C-42\n\n#### B2540 (Form 2540 – Subpoena for Rule 2004 Examination) (12/15) Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 767 of\n\nUNITED STATES BANKRUPTCY COURT 1063\n\n**District of Connecticut**\n\nIn re HO WAN KWOK, *et al*.,\n\n<sup>1</sup> Case No. 22-50073 (JAM)\n\nDebtor Chapter 11\n\n(Jointly Administered)\n\n## **SUBPOENA FOR RULE 2004 EXAMINATION**\n\nTo: **Deltee Bank & Trust Limited**\n\n(*Name of person to whom the subpoena is directed*)\n\n*Testimony:* **YOU ARE COMMANDED** to appear at the time, date, and place set forth below to testify at an examination under Rule 2004, Federal Rules of Bankruptcy Procedure. A copy of the court order authorizing the examination is attached.\n\n| PLACE                          | DATE AND TIME |\n|--------------------------------|---------------|\n| Neubert, Pepe & Monteith, P.C. |               |\n| 195 Church Street, Floor 13    | [TBD]         |\n| New Haven, Connecticut 06510   |               |\n|                                |               |\n\nThe examination will be recorded by this method: **Court reporter/stenographer**\n\n*Production:* You, or your representatives, must also bring with you to the examination the following documents, electronically stored information, or objects, and must permit inspection, copying, testing, or sampling of the material:\n\n#### **See Requests for Production of Documents, attached hereto.**\n\nThe following provisions of Fed. R. Civ. P. 45, made applicable in bankruptcy cases by Fed. R. Bankr. P. 9016, are attached – Rule 45(c), relating to the place of compliance; Rule 45(d), relating to your protection as a person subject to a subpoena; and Rule 45(e) and 45(g), relating to your duty to respond to this subpoena and the potential consequences of not doing so.\n\nDate: **March , 2023**\n\nCLERK OF COURT\n\nOR\n\n*Signature of Clerk or Deputy Clerk Attorney's signature*\n\nThe name, address, email address, and telephone number of the attorney representing Luc A. Despins, Chapter 11 Trustee, who issues or requests this subpoena, are:\n\n**Douglas S. Skalka, Esq.; Neubert, Pepe & Monteith, P.C.; 195 Church Street, New Haven, Connecticut 06510 dskalka@npmlaw.com; (203) 821-2000**\n\n**Notice to the person who issues or requests this subpoena**\n\nIf this subpoena commands the production of documents, electronically stored information, or tangible things, or the inspection of premises before trial, a notice and a copy of this subpoena must be served on each party before it is served on the person to whom it is directed. Fed. R. Civ. P. 45(a)(4).\n\nSoftware Copyright (c) 1996-2022 Best Case, LLC - www.bestcase.com Best Case Bankruptcy 1 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\n#### **PROOF OF SERVICE**\n\n**(This section should not be filed with the court unless required by Fed. R. Civ. P. 45.)**\n\nI received this subpoena for (*name of individual and title, if any*): on (*date*) .\n\nI served the subpoena by delivering a copy to the named person as follows:\n\non *(date)* ; or\n\nI returned the subpoena unexecuted because:\n\nUnless the subpoena was issued on behalf of the United States, or one of its officers or agents, I have also tendered to the witness the fees for one day's attendance, and the mileage allowed by law, in the amount of \\$ .\n\nMy fees are \\$ for travel and \\$ for services, for a total of \\$ .\n\nI declare under penalty of perjury that this information is true and correct.\n\nDate:\n\n*Server's signature*\n\n*Printed name and title*\n\n*Server's address*\n\nAdditional information concerning attempted service, etc.:\n\n#### **Federal Rule of Civil Procedure 45(c), (d), (e), and (g) (Effective 12/1/13) (made applicable in bankruptcy cases by Rule 9016, Federal Rules of Bankruptcy Procedure)**\n\n#### **(c) Place of compliance.**\n\n*(1) For a Trial, Hearing, or Deposition.* A subpoena may command a person to attend a trial, hearing, or deposition only as follows:\n\n(A) within 100 miles of where the person resides, is employed, or regularly transacts business in person; or\n\n(B) within the state where the person resides, is employed, or regularly transacts business in person, if the person\n\n(i) is a party or a party's officer; or\n\n(ii) is commanded to attend a trial and would not incur substantial expense.\n\n*(2) For Other Discovery.* A subpoena may command:\n\n(A) production of documents, or electronically stored information, or things at a place within 100 miles of where the person resides, is employed, or regularly transacts business in person; and\n\n(B) inspection of premises, at the premises to be inspected.\n\n#### **(d) Protecting a Person Subject to a Subpoena; Enforcement.**\n\n*(1) Avoiding Undue Burden or Expense; Sanctions.* A party or attorney responsible for issuing and serving a subpoena must take reasonable steps to avoid imposing undue burden or expense on a person subject to the subpoena. The court for the district where compliance is required must enforce this duty and impose an appropriate sanction which may include lost earnings and reasonable attorney's fees — on a party or attorney who fails to comply.\n\n#### *(2) Command to Produce Materials or Permit Inspection.*\n\n*(A) Appearance Not Required.* A person commanded to produce documents, electronically stored information, or tangible things, or to permit the inspection of premises, need not appear in person at the place of production or inspection unless also commanded to appear for a deposition, hearing, or trial.\n\n*(B) Objections.* A person commanded to produce documents or tangible things or to permit inspection may serve on the party or attorney designated in the subpoena a written objection to inspecting, copying, testing or sampling any or all of the materials or to inspecting the premises — or to producing electronically stored information in the form or forms requested. The objection must be served before the earlier of the time specified for compliance or 14 days after the subpoena is served. If an objection is made, the following rules apply:\n\n(i) At any time, on notice to the commanded person, the serving party may move the court for the district where compliance is required for an order compelling production or inspection.\n\n(ii) These acts may be required only as directed in the order, and the order must protect a person who is neither a party nor a party's officer from significant expense resulting from compliance.\n\n#### *(3) Quashing or Modifying a Subpoena.*\n\n*(A) When Required.* On timely motion, the court for the district where compliance is required must quash or modify a subpoena that:\n\n(i) fails to allow a reasonable time to comply;\n\n(ii) requires a person to comply beyond the geographical limits specified in Rule 45(c);\n\n(iii) requires disclosure of privileged or other protected matter, if no exception or waiver applies; or\n\n(iv) subjects a person to undue burden.\n\n*(B) When Permitted.* To protect a person subject to or affected by a subpoena, the court for the district where compliance is required may, on motion, quash or modify the subpoena if it requires:\n\n(i) disclosing a trade secret or other confidential research, development, or commercial information; or\n\n(ii) disclosing an unretained expert's opinion or information that does not describe specific occurrences in dispute and results from the expert's study that was not requested by a party.\n\n(C) *Specifying Conditions as an Alternative.* In the circumstances described in Rule 45(d)(3)(B), the court may, instead of quashing or modifying a subpoena, order appearance or production under specified conditions if the serving party:\n\n(i) shows a substantial need for the testimony or material that cannot be otherwise met without undue hardship; and\n\n(ii) ensures that the subpoenaed person will be reasonably compensated.\n\n#### **(e) Duties in Responding to a Subpoena.**\n\n*(1) Producing Documents or Electronically Stored Information.* These procedures apply to producing documents or electronically stored information:\n\n*(A) Documents.* A person responding to a subpoena to produce documents must produce them as they are kept in the ordinary course of business or must organize and label them to correspond to the categories in the demand.\n\n*(B) Form for Producing Electronically Stored Information Not Specified.* If a subpoena does not specify a form for producing electronically stored information, the person responding must produce it in a form or forms in which it is ordinarily maintained or in a reasonably usable form or forms.\n\n*(C) Electronically Stored Information Produced in Only One Form.* The person responding need not produce the same electronically stored information in more than one form.\n\n*(D) Inaccessible Electronically Stored Information.* The person responding need not provide discovery of electronically stored information from sources that the person identifies as not reasonably accessible because of undue burden or cost. On motion to compel discovery or for a protective order, the person responding must show that the information is not reasonably accessible because of undue burden or cost. If that showing is made, the court may nonetheless order discovery from such sources if the requesting party shows good cause, considering the limitations of Rule 26(b)(2)(C). The court may specify conditions for the discovery.\n\n#### *(2) Claiming Privilege or Protection.*\n\n*(A) Information Withheld.* A person withholding subpoenaed information under a claim that it is privileged or subject to protection as trial-preparation material must: (i) expressly make the claim; and\n\n(ii) describe the nature of the withheld documents, communications, or tangible things in a manner that, without revealing information itself privileged or protected, will enable the parties to assess the claim.\n\n*(B) Information Produced.* If information produced in response to a subpoena is subject to a claim of privilege or of protection as trial-preparation material, the person making the claim may notify any party that received the information of the claim and the basis for it. After being notified, a party must promptly return, sequester, or destroy the specified information and any copies it has; must not use or disclose the information until the claim is resolved; must take reasonable steps to retrieve the information if the party disclosed it before being notified; and may promptly present the information under seal to the court for the district where compliance is required for a determination of the claim. The person who produced the information must preserve the information until the claim is resolved.\n\n**(g) Contempt.** The court for the district where compliance is required – and also, after a motion is transferred, the issuing court – may hold in contempt a person who, having been served, fails without adequate excuse to obey the subpoena or an order related to it.\n\nFor access to subpoena materials, see Fed.R.Civ.P.45(a) Committee Note (2013)\n\n…\n\n## **Request for Production of Documents**\n\n## **I. INSTRUCTIONS**\n\n1. Unless otherwise indicated, the requests for documents set forth below, (the \"Requests,\" and each, a \"Request\"), must be responded to separately and specifically. Each Request shall be answered fully unless it is in good faith objected to, in which event the reason for Your objection shall be stated in detail, as set forth below. If an objection pertains only to a portion of a Request, or a word, phrase or clause contained within it, You are required to state Your objection to that portion only and to respond to the remainder of the Requests.\n\n2. Electronically stored information must be produced in accordance with the\n\nfollowing instructions:\n\n- a. Images. Black and white images must be 300 DPI Group IV single-page TIFF files. Color images must be produced in JPEG format. File names cannot contain embedded spaces or special characters (including the comma). Folder names cannot contain embedded spaces or special characters (including the comma). All TIFF image files must have a unique file name, i.e. Bates number. Images must be endorsed with sequential Bates numbers in the lower right corner of each image. The number of TIFF files per folder should not exceed 1000 files. Excel spreadsheets should have a placeholder image named by the Bates number of the file.\n- b. Image Load File\n\t- a. Concordance® Data File. The data file (.DAT) contains all of the fielded information that will be loaded into the Concordance® database. The first line of the .DAT file must be a header row identifying the field names. The .DAT file must use the following Concordance® default delimiters: Comma ASCII character (020) Quote þ ASCII character (254). Date fields should be provided in the format: mm/dd/yyyy. Date and time fields must be two separate fields. If documents includes imaged emails and attachments, the attachment fields must be included to preserve the parent/child relationship between an email and its attachments. An OCRPATH field must be included to provide the file path and name of the extracted text file on the produced storage media. The text file must be named after the FIRSTBATES. Do not include the text in the .DAT file. For Documents with native files, a LINK field must be included to provide the file path and\n\nname of the native file. The native file must be named after the FIRSTBATES.\n\n- b. Concordance Image® OR Opticon Cross-Reference File. The image crossreference file (.LOG or .OPT) links the images to the database records. It should be a comma-delimited file consisting of seven fields per line with a line in the cross-reference file for every image in the database with the following format: ImageID,VolumeLabel,ImageFilePath,DocumentBreak,FolderBreak,Box Break,PageCoun.\n- c. Document Text. Text must be produced as separate text files, not as fields within the .DAT file. The full path to the text file (OCRPATH) should be included in the .DAT file. It is recommended document level ANSI text files, named per the FIRSTBATES/Image Key. Extracted text files must be in a separate folder, and the number of text files per folder should not exceed 1,000 files. There should be no special characters (including commas in the folder names). Text files must be provided on a document level.\n- d. Native Production for Certain File Types. File types that reasonably require viewing in their native format for a full understanding of their content and meaning must be produced in native format. These include, but are not limited to, spreadsheets, spreadsheet-like files (Microsoft Excel, comma separated values, tab separated values, etc.), Microsoft PowerPoint or other special presentation files, database files, and audio/visual files. Provide an image of a Bates numbered slip sheet indicating the presence of a native file, and include the path to the native as a field in the .dat file. Name the produced native file with the Bates number corresponding to the slip sheet for the file. Group native files within incrementally named \"NATIVE\" directories, separate from images directories.\n- e. De-duplication. Produce a single copy of each electronic document for which exact duplicates exist. For email messages, consolidate duplicates based on MD5 hash generated from the BCC, Body, CC, From, IntMsgID, To, and Attach properties. For email attachments and standalone electronic files, consolidate duplicates based on MD5 hash of the entire file.\n- f. Metadata. Produce extracted metadata for each document in the form of a Concordance compliant load file (.dat). The first line of the .DAT file must be a header row identifying the field names. The .DAT file must use the following Concordance default delimiters: Comma , ASCII character (020) Quote þ ASCII character (254)\n\nDate fields should be provided in the format: mm/dd/yyyy. Date and time fields must be two separate fields. Required metadata listed below:\n\n# Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 772 of 1063\n\n| Field Name   | Sample Data              | Description                                                                                  |\n|--------------|--------------------------|----------------------------------------------------------------------------------------------|\n| FIRSTBATES   | EDC0000001               | First Bates number of native file document/email                                             |\n| LASTBATES    | EDC0000001               | Last Bates number of native file document/email<br>**The LASTBATES field should be populated |\n|              |                          | for single page                                                                              |\n| ATTACHRANGE  | EDC0000001<br>-          | Bates number of the first page of the parent                                                 |\n|              | EDC0000015               | document to the Bates number of the last page of                                             |\n|              |                          | the last attachment \"child\" document                                                         |\n| BEGATTACH    | EDC0000001               | First Bates number of attachment range                                                       |\n| ENDATTACH    | EDC0000015               | Last Bates number of attachment range                                                        |\n| CUSTODIAN    | Smith, John              | Email: Mailbox where the email resided                                                       |\n|              |                          | Native: Name of the individual or department                                                 |\n|              |                          | from whose files the document<br>originated                                                  |\n| FROM         | John Smith               | Email: Sender                                                                                |\n|              |                          | Native: Author(s) of document                                                                |\n|              |                          | **semi-colon should be used to separate                                                      |\n|              |                          | multiple entries                                                                             |\n| TO           | Coffman, Janice; LeeW    | Recipient(s)                                                                                 |\n|              | [mailto:LeeW@MSN.com]    | **semi-colon should be used to separate multiple                                             |\n|              |                          | entries                                                                                      |\n| CC           | Frank Thompson [mailto:  | Carbon copy recipient(s)                                                                     |\n|              | frank_Thompson@cdt.com]  | **semi-colon should be used to separate                                                      |\n|              |                          | multiple entries                                                                             |\n| BCC          | John Cain                | Blind carbon copy recipient(s)                                                               |\n|              |                          | **semi-colon should be used to separate                                                      |\n|              |                          | multiple entries                                                                             |\n| SUBJECT      | Board Meeting Minutes    | Email: Subject line of the email Native: Title                                               |\n|              |                          | of document (if available)                                                                   |\n| FILE_NAME    | BoardMeetingMinutes.docx | Native: Name of the original native file,                                                    |\n|              |                          | including extension                                                                          |\n| DATE_SENT    | 10/12/2010               | Email: Date the email was sent                                                               |\n|              |                          | Native: (empty)                                                                              |\n| TIME_SENT/   | 07:05 PM GMT             | Email: Time the email was sent/ Time zone in                                                 |\n| TIME_ZONE    |                          | which the emails were standardized                                                           |\n| TIME_ZONE    | GMT                      | The<br>time zone in which<br>the emails<br>were                                              |\n|              |                          | standardized during conversion.                                                              |\n| LINK         |  EDC0000001.msg   | Hyperlink to the email or native file document                                               |\n|              |                          | **The linked file must be named per the                                                      |\n|              |                          | FIRSTBATES number                                                                            |\n| FILE_EXTEN   | MSG                      | The file type extension                                                                      |\n|              |                          | representing                                                                                 |\n|              |                          | the Email or                                                                                 |\n| AUTHOR       | John Smith               | Email: (empty)                                                                               |\n|              |                          | Native: Author of the document                                                               |\n| DATE_CREATED | 10/10/2010               | Email: (empty)                                                                               |\n|              |                          | Native: Date the document was created                                                        |\n\n# Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 773 of 1063\n\n| TIME_CREATED | 10:25 AM                  | Email: (empty)                                  |\n|--------------|---------------------------|-------------------------------------------------|\n|              |                           | Native: Time the document was created           |\n|              |                           | **This data must be a separate field and cannot |\n|              |                           | be combined with the DATE_CREATED field         |\n| DATE_MOD     | 10/12/2010                | Email: (empty)                                  |\n|              |                           | Native: Date the document was last modified     |\n| TIME_MOD     | 07:00 PM                  | Email: (empty)                                  |\n|              |                           | Native: Time the document was last modified     |\n|              |                           | **This data must be a separate field and cannot |\n|              |                           | be combined with the DATE_MOD field             |\n| DATE_ACCESSD | 10/12/2010                | Email: (empty)                                  |\n|              |                           | Native: Date the document was last accessed     |\n| TIME_ACCESSD | 07:00 PM                  | Email: (empty)                                  |\n|              |                           | Native: Time the document was last accessed     |\n|              |                           | **This data must be a separate field and cannot |\n|              |                           | be combined with the DATE_ACCESSD field         |\n| FILE_SIZE    | 5,952                     | Size of native file<br>document/email in KB     |\n| PGCOUNT      | 1                         | Number of pages in native file document/email   |\n| PATH         |   | Email: (empty)                                  |\n|              | Agenda.doc                | Native: Path where native file document was     |\n|              |                           | stored including original file name.            |\n| INTFILEPATH  | Personal Folders\\Deleted  | Email: original location of email including     |\n|              | Items\\Board Meeting       | original file name.                             |\n|              | Minutes.msg               | Native: (empty)                                 |\n| INTMSGID     | <000805c2c71b\\$75977050\\$ | Email: Unique Message ID Native: (empty)        |\n|              | cb8306d1@MSN>             |                                                 |\n| MD5HASH      | d131dd02c5e6eec4693d9a0   | MD5 Hash value of the document.                 |\n|              | 698aff95c                 |                                                 |\n|              | 2fcab58712467eab4004583e  |                                                 |\n|              | b8fb7f89                  |                                                 |\n| OCRPATH      | TEXT/001/EDC0000001.txt   | Path to extracted text of the native file       |\n\n3. Each Request operates and should be construed independently and, unless otherwise indicated, no Request limits the scope of any other Request.\n\n4. All Documents are to be produced as kept in the usual course of business or are to be organized and labeled to correspond with the categories in these Requests.\n\n5. Each Request contained herein extends to all Documents: (a) in Your possession, custody, or control; or (b) in the possession, custody, or control of anyone acting on Your behalf,\n\n#### Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 774 of 1063\n\nincluding Your counsel or other representatives and advisors. Each Document shall be produced in its entirety.\n\n6. If You are requested to produce a Document that is no longer in Your possession, custody, or control, then Your response must (a) describe in detail the nature of the document and its contents; (b) identify the person(s) who prepared or authored the Document (and, if applicable, the Person(s) to whom the Document was sent); (c) identify the date on which the document was prepared or created; (d) state whether such Document (i) is missing or lost, (ii) has been destroyed, (iii) has been transferred, voluntarily or involuntarily, to others, or (iv) was otherwise disposed of; (e) state the reason for, and the facts and circumstances surrounding, such disposition; (f) identify the Persons who authorized such disposition; (g) identify the date or approximate date of such disposition; (h) state when the Document was most recently in Your possession, custody or control; and (i) identify the Person, if any, presently in possession, custody, or control of such Document.\n\n7. If You are requested to produce a Document that has been destroyed, then Your response must state, in addition to the information required by the preceding Instruction: (a) the reason for the Document's destruction; (b) the identity of the Person who destroyed the Document; and (c) the identity of the Person who directed that the Document be destroyed.\n\n8. If You claim that a requested Document is privileged or attorney work-product, then Your response must: (a) state (i) a description of the Document adequate to support Your contention that the Document is privileged, (ii) the title of the Document, (iii) the date of the Document, (iv) the author of the Document, (v) the addressee of the Document, (vi) the identity of each Person who received or saw the original or any draft, copy, or reproduction of the Document, (vii) whether the Document itself, or any information contained or referred to in the Document is in the possession, custody, or control of any other Persons, and if so, the identity of\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 775 of 1063\n\nsuch Persons, as well as a statement addressing how the information came into their possession, (viii) the claim of privilege under which the Document is withheld, and (ix) all of the circumstances upon which You will rely to support such claim of privilege; and (b) produce a privilege log containing all of the information requested in Part (a) of this Instruction for each Document withheld on the basis of a claim of privilege in accordance with D. Conn. L. Civ. R. 26(e). For any part of a Document Request as to which a claim of privilege or work product is not made, responsive documents should be provided in full.\n\n9. If a portion of an otherwise responsive Document contains information subject to a claim of privilege, only that portion of the Document subject to the claim of privilege shall be deleted or redacted from the Document following the instructions above, and the rest shall be produced.\n\n10. The Requests are continuing in nature. You are hereby instructed to (a) supplement or correct any responses later learned to be incomplete or incorrect immediately upon learning that a prior response was incomplete or incorrect; and (b) produce any additional Documents that are called for under the\n\n11. If a Document is in a language other than English, You should provide that Document. If a Document is in a language other than English, and an English translation exists, You should provide both Documents.\n\n12. All references to Entities includes all affiliates thereof.\n\n13. All references to individual names include all alternative names, aliased, or nicknames.\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 776 of 1063\n\n14. Unless otherwise expressly indicated, the period of time covered by the Document Requests is the period from February 5, 2012 to the date responses to the Document Requests are due.\n\n#### **II. RULES OF CONSTRUCTION**\n\n15. The use of (a) any singular noun shall be construed to include the plural, and vice versa, and (b) a verb in any tense shall be construed as the use of the verb in all other tenses.\n\n16. The terms (a) \"and\" and \"or\" shall be construed either conjunctively or disjunctively as necessary to bring within the scope of any request all responses that might otherwise be construed to be outside of its scope, and (b) \"each\" and \"any\" shall be deemed to include and encompass the words \"every\" and \"all.\"\n\n#### **III. DEFINITIONS**\n\nThe definitions supplied by D. Conn. L. Civ. R. 26(c) and the rules of construction supplied by D. Conn. L. Civ. R. 26(d), as incorporated by D. Conn. Bankr. L.R. 2004-1(a), shall apply to the Document Requests. In addition, the following terms used in these Document Requests shall have the following meanings:\n\n1. \"You\" or \"Your\" or \"Yourself\" means and refers, to Deltec Bank & Trust Limited.\n\n2. \"Debtor\" means Ho Wan Kwok (a/k/a Miles Kwok, Miles Guo, Guo Wengui,\n\nGuo Haoyun, 郭文贵, or any other alias), together with his employees, agents, counsel, advisors, or anyone acting on his behalf.\n\n3. \"Debtor's Son\" means Qiang Guo (a/k/a Mileson Kwok, 郭强, or any other alias), together with his employees, agents, counsel, advisors, or anyone acting on his behalf.\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 777 of 1063\n\n4. \"Debtor's Daughter\" means Mei Guo (a/k/a Mei Gui, 郭美, or any other alias),\n\ntogether with her employees, agents, counsel, advisors, or anyone acting on her behalf.\n\n5. \"Debtor's Purported Wife\" means Hing Chi Ngok (a/k/a Hing Chi Ng, Yue Qingzhi, 岳庆芝, or any other alias), together with her employees, agents, counsel, advisors, or anyone acting on her behalf.\n\n6. \"Debtor's Family\" means, individually and collectively, the Debtor, the Debtor's Son, the Debtor's Daughter, and the Debtor's Purported Wife, and any other familial relation to the Debtor.\n\n7. \"2004 Discovery Targets\" means, individually and collectively, the Debtor, the Debtor's Family, ACA Capital Group Limited, Himalaya International Financial Group Ltd., Himalaya International Clearing Ltd., Himalaya International Payments Ltd., Himalaya International Reserves Ltd., Jesse Brown, William Je, William Je, Eastern Profit Corporation Limited, HK International Funds Investments (USA) Limited LLC, Bravo Luck Limited, Golden Spring (New York) Ltd., Lamp Capital LLC, Greenwich Land LLC, Qu Guo Jiao, Daniel Thomas Podhaskie, Yvette Wang (a/k/a Yanping Wang, a/k/a Yan Ping Wang), Ace Decade Holdings Limited, Dawn State Limited, Rule of Law Society IV Inc., Rule of Law Foundation III, Inc., Rule of Law Foundation IV, Inc., Rule of Law Fund, Rule of Law Society, GTV Media Group, Inc., Voice of Guo Media, Inc., Saraca Media Group Inc., Genever Holdings Corporation, Genever Holdings LLC, Gnews Media Group Inc., G Fashion LLC, Gmusic LLC, Gnews LLC, Geducation, GFNY, Inc., G-Club Investments Limited, G Club Operations LLC, G Club US Operations Inc., G Club US Operations LLC, G Live, LLC, Gbroadcast, LLC, Gposts LLC, HCHK Property Management, Inc., HCHK Technologies, Inc., FMV Ltd./Freedom Media Venture Ltd., Roscalitar 2, Himalaya New World Inc., US Himalaya Capital Inc., Hudson Diamond Holding, Inc., Hudson\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 778 of 1063\n\nDiamond Holding LLC, Hudson Diamond NY LLC, Infinity Treasury Management Inc., Lexington Property and Staffing, Inc., AI Group Holdings Inc., Hamilton Capital Holdings Inc., Booming Sail New York LLC, Himalaya Ventures LLC, Himalaya Ventures LLC, Himalaya Investment LLC, New York MOS Himalaya LLC, MOS Himalaya LLC, Crane Advisory Group, Maywind Trading LLC, Gettr USA, Inc., Han Chunguang, Bingshang Jiao, Karin Maistrello, Mary Jiang, Jiaming Liu, and Wencong Wang.\n\n8. \"Including\" or any variant thereof means \"including without limitation.\"\n\n9. \"And\" and \"or\" mean \"and/or,\" and shall be construed both conjunctively as well as disjunctively in order to maximize their scope.\n\n10. \"Any\" and \"all\" and \"each\" mean \"each and every.\"\n\n11. \"Each\" and \"every\" mean \"each and every.\"\n\n12. \"Third Party\" means a Person or Entity other than Yourself.\n\n13. \"Transfer\" shall have the meaning given to it by section 101(54) of the Bankruptcy Code.\n\n14. \"Document\" means any information or thing within the scope of Fed. R. Civ. P. 34, and includes, without limitation, each and every written, recorded, or graphic matter of any kind, type, nature, or description that is or has been in Your Possession, Custody or Control, including all printed and electronic copies of electronic mail, computer files maintained in electronic form, correspondence, memoranda, tapes, stenographic or handwritten notes, written forms of any kind, charts, blueprints, drawings, sketches, graphs, plans, articles, specifications, diaries, letters, telegrams, photographs, minutes, contracts, agreements, surveys, computer printouts, data compilations of any kind, telexes, facsimiles, emails, text messages, instant messages, voice\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 779 of 1063\n\nmessages, invoices, order forms, checks, drafts, statements, credit memos, reports, position reports, summaries, indices, books, ledgers, notebooks, schedules, transparencies, recordings, catalogs, advertisements, promotional materials, films, video tapes, audio tapes, CDs, computer disks, brochures, pamphlets, punch-cards, time-slips, Tweets, social media posts, or any written or recorded materials of any other kind, and all meta-data thereof, however stored (whether in tangible or electronic form), recorded, produced, or reproduced, and also including but not limited to, drafts or copies of any of the foregoing that contain any notes, comments, or markings of any kind not found on the original documents or that are otherwise not identical to the original documents.\n\n15. \"Person(s)\" means an individual, corporation, proprietorship, partnership, association, or any other Entity. \"Person\" also includes any agent, representatives, or expert, including but not limiting to, attorneys or financial advisors.\n\n16. \"Entity\" means any natural Person, corporation, partnership, subsidiary, sole proprietorship, firm, board, joint venture, association, agency, authority, commission or other business entity or juristic Person, as well as any affiliate, agent, parent including but not limited to counsel, financial advisors, or any other representative.\n\n17. \"Regarding\" means concerning, describing, comprising, referring to, related to, supporting, favoring, opposing, bolstering, detracting from, located in, considered in connection with, bearing on, evidencing, indicating, reporting on, recording, alluding to, responding to, connected with, commenting on, in respect of, about, in relation to, discussing, showing, describing, reflecting, analyzing constituting, and being.\n\n18. \"Relating to,\" \"relate(s) to\" or \"related to,\" when referring to any given subject matter, means, without limitation, any document that constitutes, comprises, involves, contains,\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 780 of 1063\n\nembodies, reflects, identifies, states, refers directly or indirectly to, or is in any way relevant to the particular subject matter identified.\n\n19. \"Communication(s)\" means, in the broadest possible sense, and without limitation, any transmittal of information or knowledge (in the form of facts, ideas, inquiries, or otherwise). Communication(s) further refers to all conversations, agreements, inquiries, or replies, whether in person, by telephone, in writing, or by means of electronic transmittal devices, and includes, but is not limited to, all correspondence, emails, recordings, transmittal slips, memoranda, telephone communications, voice messages, telegrams, telefaxes, telecopies, telexes, instant messages, chats, text messages, postings to a message board or group chat, social media posts, tweets, videos uploaded to any video platform, telephonic notes, or notes transmitted internally or with third parties.\n\n20. \"Asset(s)\" means any item of economic value that is subject to Possession, Custody, or Control. Asset includes all real and personal property, including but limited to, real estate, land, houses, apartments, condominiums, automobiles, yachts, boats, planes, jets, helicopters, cash, bank accounts, cryptocurrencies, securities, accounts receivables, inventory, and other tangible and intangible property.\n\n#### **IV. DOCUMENTS TO BE PRODUCED**\n\n1. All Documents related to any account held by, controlled by, on behalf of, or otherwise related to any of the 2004 Discovery Targets, including any and all account statements, authorizations, power of attorney, trusts, instructions or forms, copies of cancelled checks, correspondence, and wire transfers and related correspondence and instructions.\n\n2. All Documents related to any funds, securities, property, or assets belonging to, held by, controlled by, on behalf of, or otherwise related to any of the 2004 Discovery Targets,\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 781 of 1063\n\nincluding any and all account statements, authorizations, powers of attorney, trusts, instructions or forms, copies of cancelled checks, correspondence, and wire transfers and related correspondence and instructions.\n\n3. All Documents related to any business, commerce or financial transactions, including but not limited to any loan, line of credit, bailment, deposit, swap, securities transactions, mortgage, or ISDA, with any of the 2004 Discovery Targets, including any and all account statements, authorizations, powers of attorney, trusts, instructions or forms, copies of cancelled checks, correspondence, and wire transfers and related correspondence and instructions.\n\n4. All Documents relating to any wire transfer activity relating to the 2004 Discovery Targets, regardless of the existence of any accounts, including but not limited to all wire transfer receipts, account numbers, balances, authorizations, identification information related to the parties to the transfer, correspondence, instructions, or other records.\n\n5. All Documents related to any correspondence and communications between you and the 2004 Discovery Targets.\n\n6. All Documents related to any account with any 2004 Discovery Target relating to opening of the account, authorized users of the account and maintenance of the account.\n\n7. All Documents related to any anti-money laundering, know-your-customer, or other compliance activity relating to any of the 2004 Discovery Targets, including but not limited to any information provided by any of the 2004 Discovery Targets, or learned by You.\n\n8. All Documents relating to any communications with any regulator from any country, including but not limited to the Bank of England, the United States Federal Reserve, the S.E.C., the CFTC, FINRA, China Securities Regulatory Commission, People's Bank of China,\n\nHong Kong Securities and Futures Commission, and the Hong Kong Monetary Authority relating to any of the 2004 Discovery Targets.\n\n# Exhibit C-43\n\n#### B2540 (Form 2540 – Subpoena for Rule 2004 Examination) (12/15) Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 784 of\n\nUNITED STATES BANKRUPTCY COURT 1063\n\n**District of Connecticut**\n\nIn re HO WAN KWOK, *et al*.,\n\n<sup>1</sup> Case No. 22-50073 (JAM)\n\nDebtor Chapter 11\n\n(Jointly Administered)\n\n## **SUBPOENA FOR RULE 2004 EXAMINATION**\n\nTo: **National Australia Bank Limited**\n\n(*Name of person to whom the subpoena is directed*)\n\n*Testimony:* **YOU ARE COMMANDED** to appear at the time, date, and place set forth below to testify at an examination under Rule 2004, Federal Rules of Bankruptcy Procedure. A copy of the court order authorizing the examination is attached.\n\n| PLACE                          | DATE AND TIME |\n|--------------------------------|---------------|\n| Neubert, Pepe & Monteith, P.C. |               |\n| 195 Church Street, Floor 13    | [TBD]         |\n| New Haven, Connecticut 06510   |               |\n|                                |               |\n\nThe examination will be recorded by this method: **Court reporter/stenographer**\n\n*Production:* You, or your representatives, must also bring with you to the examination the following documents, electronically stored information, or objects, and must permit inspection, copying, testing, or sampling of the material:\n\n#### **See Requests for Production of Documents, attached hereto.**\n\nThe following provisions of Fed. R. Civ. P. 45, made applicable in bankruptcy cases by Fed. R. Bankr. P. 9016, are attached – Rule 45(c), relating to the place of compliance; Rule 45(d), relating to your protection as a person subject to a subpoena; and Rule 45(e) and 45(g), relating to your duty to respond to this subpoena and the potential consequences of not doing so.\n\nDate: **March , 2023**\n\nCLERK OF COURT\n\nOR\n\n*Signature of Clerk or Deputy Clerk Attorney's signature*\n\nThe name, address, email address, and telephone number of the attorney representing Luc A. Despins, Chapter 11 Trustee, who issues or requests this subpoena, are:\n\n**Douglas S. Skalka, Esq.; Neubert, Pepe & Monteith, P.C.; 195 Church Street, New Haven, Connecticut 06510 dskalka@npmlaw.com; (203) 821-2000**\n\n**Notice to the person who issues or requests this subpoena**\n\nIf this subpoena commands the production of documents, electronically stored information, or tangible things, or the inspection of premises before trial, a notice and a copy of this subpoena must be served on each party before it is served on the person to whom it is directed. Fed. R. Civ. P. 45(a)(4).\n\nSoftware Copyright (c) 1996-2022 Best Case, LLC - www.bestcase.com Best Case Bankruptcy 1 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\n#### **PROOF OF SERVICE**\n\n**(This section should not be filed with the court unless required by Fed. R. Civ. P. 45.)**\n\nI received this subpoena for (*name of individual and title, if any*): on (*date*) .\n\nI served the subpoena by delivering a copy to the named person as follows:\n\non *(date)* ; or\n\nI returned the subpoena unexecuted because:\n\nUnless the subpoena was issued on behalf of the United States, or one of its officers or agents, I have also tendered to the witness the fees for one day's attendance, and the mileage allowed by law, in the amount of \\$ .\n\nMy fees are \\$ for travel and \\$ for services, for a total of \\$ .\n\nI declare under penalty of perjury that this information is true and correct.\n\nDate:\n\n*Server's signature*\n\n*Printed name and title*\n\n*Server's address*\n\nAdditional information concerning attempted service, etc.:\n\n#### **Federal Rule of Civil Procedure 45(c), (d), (e), and (g) (Effective 12/1/13) (made applicable in bankruptcy cases by Rule 9016, Federal Rules of Bankruptcy Procedure)**\n\n#### **(c) Place of compliance.**\n\n*(1) For a Trial, Hearing, or Deposition.* A subpoena may command a person to attend a trial, hearing, or deposition only as follows:\n\n(A) within 100 miles of where the person resides, is employed, or regularly transacts business in person; or\n\n(B) within the state where the person resides, is employed, or regularly transacts business in person, if the person\n\n(i) is a party or a party's officer; or\n\n(ii) is commanded to attend a trial and would not incur substantial expense.\n\n*(2) For Other Discovery.* A subpoena may command:\n\n(A) production of documents, or electronically stored information, or things at a place within 100 miles of where the person resides, is employed, or regularly transacts business in person; and\n\n(B) inspection of premises, at the premises to be inspected.\n\n#### **(d) Protecting a Person Subject to a Subpoena; Enforcement.**\n\n*(1) Avoiding Undue Burden or Expense; Sanctions.* A party or attorney responsible for issuing and serving a subpoena must take reasonable steps to avoid imposing undue burden or expense on a person subject to the subpoena. The court for the district where compliance is required must enforce this duty and impose an appropriate sanction which may include lost earnings and reasonable attorney's fees — on a party or attorney who fails to comply.\n\n#### *(2) Command to Produce Materials or Permit Inspection.*\n\n*(A) Appearance Not Required.* A person commanded to produce documents, electronically stored information, or tangible things, or to permit the inspection of premises, need not appear in person at the place of production or inspection unless also commanded to appear for a deposition, hearing, or trial.\n\n*(B) Objections.* A person commanded to produce documents or tangible things or to permit inspection may serve on the party or attorney designated in the subpoena a written objection to inspecting, copying, testing or sampling any or all of the materials or to inspecting the premises — or to producing electronically stored information in the form or forms requested. The objection must be served before the earlier of the time specified for compliance or 14 days after the subpoena is served. If an objection is made, the following rules apply:\n\n(i) At any time, on notice to the commanded person, the serving party may move the court for the district where compliance is required for an order compelling production or inspection.\n\n(ii) These acts may be required only as directed in the order, and the order must protect a person who is neither a party nor a party's officer from significant expense resulting from compliance.\n\n#### *(3) Quashing or Modifying a Subpoena.*\n\n*(A) When Required.* On timely motion, the court for the district where compliance is required must quash or modify a subpoena that:\n\n(i) fails to allow a reasonable time to comply;\n\n(ii) requires a person to comply beyond the geographical limits specified in Rule 45(c);\n\n(iii) requires disclosure of privileged or other protected matter, if no exception or waiver applies; or\n\n(iv) subjects a person to undue burden.\n\n*(B) When Permitted.* To protect a person subject to or affected by a subpoena, the court for the district where compliance is required may, on motion, quash or modify the subpoena if it requires:\n\n(i) disclosing a trade secret or other confidential research, development, or commercial information; or\n\n(ii) disclosing an unretained expert's opinion or information that does not describe specific occurrences in dispute and results from the expert's study that was not requested by a party.\n\n(C) *Specifying Conditions as an Alternative.* In the circumstances described in Rule 45(d)(3)(B), the court may, instead of quashing or modifying a subpoena, order appearance or production under specified conditions if the serving party:\n\n(i) shows a substantial need for the testimony or material that cannot be otherwise met without undue hardship; and\n\n(ii) ensures that the subpoenaed person will be reasonably compensated.\n\n#### **(e) Duties in Responding to a Subpoena.**\n\n*(1) Producing Documents or Electronically Stored Information.* These procedures apply to producing documents or electronically stored information:\n\n*(A) Documents.* A person responding to a subpoena to produce documents must produce them as they are kept in the ordinary course of business or must organize and label them to correspond to the categories in the demand.\n\n*(B) Form for Producing Electronically Stored Information Not Specified.* If a subpoena does not specify a form for producing electronically stored information, the person responding must produce it in a form or forms in which it is ordinarily maintained or in a reasonably usable form or forms.\n\n*(C) Electronically Stored Information Produced in Only One Form.* The person responding need not produce the same electronically stored information in more than one form.\n\n*(D) Inaccessible Electronically Stored Information.* The person responding need not provide discovery of electronically stored information from sources that the person identifies as not reasonably accessible because of undue burden or cost. On motion to compel discovery or for a protective order, the person responding must show that the information is not reasonably accessible because of undue burden or cost. If that showing is made, the court may nonetheless order discovery from such sources if the requesting party shows good cause, considering the limitations of Rule 26(b)(2)(C). The court may specify conditions for the discovery.\n\n#### *(2) Claiming Privilege or Protection.*\n\n*(A) Information Withheld.* A person withholding subpoenaed information under a claim that it is privileged or subject to protection as trial-preparation material must: (i) expressly make the claim; and\n\n(ii) describe the nature of the withheld documents, communications, or tangible things in a manner that, without revealing information itself privileged or protected, will enable the parties to assess the claim.\n\n*(B) Information Produced.* If information produced in response to a subpoena is subject to a claim of privilege or of protection as trial-preparation material, the person making the claim may notify any party that received the information of the claim and the basis for it. After being notified, a party must promptly return, sequester, or destroy the specified information and any copies it has; must not use or disclose the information until the claim is resolved; must take reasonable steps to retrieve the information if the party disclosed it before being notified; and may promptly present the information under seal to the court for the district where compliance is required for a determination of the claim. The person who produced the information must preserve the information until the claim is resolved.\n\n**(g) Contempt.** The court for the district where compliance is required – and also, after a motion is transferred, the issuing court – may hold in contempt a person who, having been served, fails without adequate excuse to obey the subpoena or an order related to it.\n\nFor access to subpoena materials, see Fed.R.Civ.P.45(a) Committee Note (2013)\n\n…\n\n## **Request for Production of Documents**\n\n## **I. INSTRUCTIONS**\n\n1. Unless otherwise indicated, the requests for documents set forth below, (the \"Requests,\" and each, a \"Request\"), must be responded to separately and specifically. Each Request shall be answered fully unless it is in good faith objected to, in which event the reason for Your objection shall be stated in detail, as set forth below. If an objection pertains only to a portion of a Request, or a word, phrase or clause contained within it, You are required to state Your objection to that portion only and to respond to the remainder of the Requests.\n\n2. Electronically stored information must be produced in accordance with the\n\nfollowing instructions:\n\n- a. Images. Black and white images must be 300 DPI Group IV single-page TIFF files. Color images must be produced in JPEG format. File names cannot contain embedded spaces or special characters (including the comma). Folder names cannot contain embedded spaces or special characters (including the comma). All TIFF image files must have a unique file name, i.e. Bates number. Images must be endorsed with sequential Bates numbers in the lower right corner of each image. The number of TIFF files per folder should not exceed 1000 files. Excel spreadsheets should have a placeholder image named by the Bates number of the file.\n- b. Image Load File\n\t- a. Concordance® Data File. The data file (.DAT) contains all of the fielded information that will be loaded into the Concordance® database. The first line of the .DAT file must be a header row identifying the field names. The .DAT file must use the following Concordance® default delimiters: Comma ASCII character (020) Quote þ ASCII character (254). Date fields should be provided in the format: mm/dd/yyyy. Date and time fields must be two separate fields. If documents includes imaged emails and attachments, the attachment fields must be included to preserve the parent/child relationship between an email and its attachments. An OCRPATH field must be included to provide the file path and name of the extracted text file on the produced storage media. The text file must be named after the FIRSTBATES. Do not include the text in the .DAT file. For Documents with native files, a LINK field must be included to provide the file path and\n\nname of the native file. The native file must be named after the FIRSTBATES.\n\n- b. Concordance Image® OR Opticon Cross-Reference File. The image crossreference file (.LOG or .OPT) links the images to the database records. It should be a comma-delimited file consisting of seven fields per line with a line in the cross-reference file for every image in the database with the following format: ImageID,VolumeLabel,ImageFilePath,DocumentBreak,FolderBreak,Box Break,PageCoun.\n- c. Document Text. Text must be produced as separate text files, not as fields within the .DAT file. The full path to the text file (OCRPATH) should be included in the .DAT file. It is recommended document level ANSI text files, named per the FIRSTBATES/Image Key. Extracted text files must be in a separate folder, and the number of text files per folder should not exceed 1,000 files. There should be no special characters (including commas in the folder names). Text files must be provided on a document level.\n- d. Native Production for Certain File Types. File types that reasonably require viewing in their native format for a full understanding of their content and meaning must be produced in native format. These include, but are not limited to, spreadsheets, spreadsheet-like files (Microsoft Excel, comma separated values, tab separated values, etc.), Microsoft PowerPoint or other special presentation files, database files, and audio/visual files. Provide an image of a Bates numbered slip sheet indicating the presence of a native file, and include the path to the native as a field in the .dat file. Name the produced native file with the Bates number corresponding to the slip sheet for the file. Group native files within incrementally named \"NATIVE\" directories, separate from images directories.\n- e. De-duplication. Produce a single copy of each electronic document for which exact duplicates exist. For email messages, consolidate duplicates based on MD5 hash generated from the BCC, Body, CC, From, IntMsgID, To, and Attach properties. For email attachments and standalone electronic files, consolidate duplicates based on MD5 hash of the entire file.\n- f. Metadata. Produce extracted metadata for each document in the form of a Concordance compliant load file (.dat). The first line of the .DAT file must be a header row identifying the field names. The .DAT file must use the following Concordance default delimiters: Comma , ASCII character (020) Quote þ ASCII character (254)\n\nDate fields should be provided in the format: mm/dd/yyyy. Date and time fields must be two separate fields. Required metadata listed below:\n\n# Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 789 of 1063\n\n| Field Name   | Sample Data              | Description                                      |\n|--------------|--------------------------|--------------------------------------------------|\n| FIRSTBATES   | EDC0000001               | First Bates number of native file document/email |\n| LASTBATES    | EDC0000001               | Last Bates number of native file document/email  |\n|              |                          | **The LASTBATES field should be populated        |\n|              |                          | for single page                                  |\n| ATTACHRANGE  | EDC0000001<br>-          | Bates number of the first page of the parent     |\n|              | EDC0000015               | document to the Bates number of the last page of |\n|              |                          | the last attachment \"child\" document             |\n| BEGATTACH    | EDC0000001               | First Bates number of attachment range           |\n| ENDATTACH    | EDC0000015               | Last Bates number of attachment range            |\n| CUSTODIAN    | Smith, John              | Email: Mailbox where the email resided           |\n|              |                          | Native: Name of the individual or department     |\n|              |                          | from whose files the document<br>originated      |\n| FROM         | John Smith               | Email: Sender                                    |\n|              |                          | Native: Author(s) of document                    |\n|              |                          | **semi-colon should be used to separate          |\n|              |                          | multiple entries                                 |\n| TO           | Coffman, Janice; LeeW    | Recipient(s)                                     |\n|              | [mailto:LeeW@MSN.com]    | **semi-colon should be used to separate multiple |\n|              |                          | entries                                          |\n| CC           | Frank Thompson [mailto:  | Carbon copy recipient(s)                         |\n|              | frank_Thompson@cdt.com]  | **semi-colon should be used to separate          |\n|              |                          | multiple entries                                 |\n| BCC          | John Cain                | Blind carbon copy recipient(s)                   |\n|              |                          | **semi-colon should be used to separate          |\n|              |                          | multiple entries                                 |\n| SUBJECT      | Board Meeting Minutes    | Email: Subject line of the email Native: Title   |\n|              |                          | of document (if available)                       |\n| FILE_NAME    | BoardMeetingMinutes.docx | Native: Name of the original native file,        |\n|              |                          | including extension                              |\n| DATE_SENT    | 10/12/2010               | Email: Date the email was sent                   |\n|              |                          | Native: (empty)                                  |\n| TIME_SENT/   | 07:05 PM GMT             | Email: Time the email was sent/ Time zone in     |\n| TIME_ZONE    |                          | which the emails were standardized               |\n| TIME_ZONE    | GMT                      | The<br>time zone in which<br>the emails<br>were  |\n|              |                          | standardized during conversion.                  |\n| LINK         |  EDC0000001.msg   | Hyperlink to the email or native file document   |\n|              |                          | **The linked file must be named per the          |\n|              |                          | FIRSTBATES number                                |\n| FILE_EXTEN   | MSG                      | The file type extension                          |\n|              |                          | representing                                     |\n|              |                          | the Email or                                     |\n| AUTHOR       | John Smith               | Email: (empty)                                   |\n|              |                          | Native: Author of the document                   |\n| DATE_CREATED | 10/10/2010               | Email: (empty)                                   |\n|              |                          | Native: Date the document was created            |\n\n# Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 790 of 1063\n\n| TIME_CREATED | 10:25 AM                  | Email: (empty)                                  |\n|--------------|---------------------------|-------------------------------------------------|\n|              |                           | Native: Time the document was created           |\n|              |                           | **This data must be a separate field and cannot |\n|              |                           | be combined with the DATE_CREATED field         |\n| DATE_MOD     | 10/12/2010                | Email: (empty)                                  |\n|              |                           | Native: Date the document was last modified     |\n| TIME_MOD     | 07:00 PM                  | Email: (empty)                                  |\n|              |                           | Native: Time the document was last modified     |\n|              |                           | **This data must be a separate field and cannot |\n|              |                           | be combined with the DATE_MOD field             |\n| DATE_ACCESSD | 10/12/2010                | Email: (empty)                                  |\n|              |                           | Native: Date the document was last accessed     |\n| TIME_ACCESSD | 07:00 PM                  | Email: (empty)                                  |\n|              |                           | Native: Time the document was last accessed     |\n|              |                           | **This data must be a separate field and cannot |\n|              |                           | be combined with the DATE_ACCESSD field         |\n| FILE_SIZE    | 5,952                     | Size of native file<br>document/email in KB     |\n| PGCOUNT      | 1                         | Number of pages in native file document/email   |\n| PATH         |   | Email: (empty)                                  |\n|              | Agenda.doc                | Native: Path where native file document was     |\n|              |                           | stored including original file name.            |\n| INTFILEPATH  | Personal Folders\\Deleted  | Email: original location of email including     |\n|              | Items\\Board Meeting       | original file name.                             |\n|              | Minutes.msg               | Native: (empty)                                 |\n| INTMSGID     | <000805c2c71b\\$75977050\\$ | Email: Unique Message ID Native: (empty)        |\n|              | cb8306d1@MSN>             |                                                 |\n| MD5HASH      | d131dd02c5e6eec4693d9a0   | MD5 Hash value of the document.                 |\n|              | 698aff95c                 |                                                 |\n|              | 2fcab58712467eab4004583e  |                                                 |\n|              | b8fb7f89                  |                                                 |\n| OCRPATH      | TEXT/001/EDC0000001.txt   | Path to extracted text of the native file       |\n\n3. Each Request operates and should be construed independently and, unless otherwise indicated, no Request limits the scope of any other Request.\n\n4. All Documents are to be produced as kept in the usual course of business or are to be organized and labeled to correspond with the categories in these Requests.\n\n5. Each Request contained herein extends to all Documents: (a) in Your possession, custody, or control; or (b) in the possession, custody, or control of anyone acting on Your behalf,\n\n#### Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 791 of 1063\n\nincluding Your counsel or other representatives and advisors. Each Document shall be produced in its entirety.\n\n6. If You are requested to produce a Document that is no longer in Your possession, custody, or control, then Your response must (a) describe in detail the nature of the document and its contents; (b) identify the person(s) who prepared or authored the Document (and, if applicable, the Person(s) to whom the Document was sent); (c) identify the date on which the document was prepared or created; (d) state whether such Document (i) is missing or lost, (ii) has been destroyed, (iii) has been transferred, voluntarily or involuntarily, to others, or (iv) was otherwise disposed of; (e) state the reason for, and the facts and circumstances surrounding, such disposition; (f) identify the Persons who authorized such disposition; (g) identify the date or approximate date of such disposition; (h) state when the Document was most recently in Your possession, custody or control; and (i) identify the Person, if any, presently in possession, custody, or control of such Document.\n\n7. If You are requested to produce a Document that has been destroyed, then Your response must state, in addition to the information required by the preceding Instruction: (a) the reason for the Document's destruction; (b) the identity of the Person who destroyed the Document; and (c) the identity of the Person who directed that the Document be destroyed.\n\n8. If You claim that a requested Document is privileged or attorney work-product, then Your response must: (a) state (i) a description of the Document adequate to support Your contention that the Document is privileged, (ii) the title of the Document, (iii) the date of the Document, (iv) the author of the Document, (v) the addressee of the Document, (vi) the identity of each Person who received or saw the original or any draft, copy, or reproduction of the Document, (vii) whether the Document itself, or any information contained or referred to in the Document is in the possession, custody, or control of any other Persons, and if so, the identity of\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 792 of 1063\n\nsuch Persons, as well as a statement addressing how the information came into their possession, (viii) the claim of privilege under which the Document is withheld, and (ix) all of the circumstances upon which You will rely to support such claim of privilege; and (b) produce a privilege log containing all of the information requested in Part (a) of this Instruction for each Document withheld on the basis of a claim of privilege in accordance with D. Conn. L. Civ. R. 26(e). For any part of a Document Request as to which a claim of privilege or work product is not made, responsive documents should be provided in full.\n\n9. If a portion of an otherwise responsive Document contains information subject to a claim of privilege, only that portion of the Document subject to the claim of privilege shall be deleted or redacted from the Document following the instructions above, and the rest shall be produced.\n\n10. The Requests are continuing in nature. You are hereby instructed to (a) supplement or correct any responses later learned to be incomplete or incorrect immediately upon learning that a prior response was incomplete or incorrect; and (b) produce any additional Documents that are called for under the\n\n11. If a Document is in a language other than English, You should provide that Document. If a Document is in a language other than English, and an English translation exists, You should provide both Documents.\n\n12. All references to Entities includes all affiliates thereof.\n\n13. All references to individual names include all alternative names, aliased, or nicknames.\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 793 of 1063\n\n14. Unless otherwise expressly indicated, the period of time covered by the Document Requests is the period from February 5, 2012 to the date responses to the Document Requests are due.\n\n#### **II. RULES OF CONSTRUCTION**\n\n15. The use of (a) any singular noun shall be construed to include the plural, and vice versa, and (b) a verb in any tense shall be construed as the use of the verb in all other tenses.\n\n16. The terms (a) \"and\" and \"or\" shall be construed either conjunctively or disjunctively as necessary to bring within the scope of any request all responses that might otherwise be construed to be outside of its scope, and (b) \"each\" and \"any\" shall be deemed to include and encompass the words \"every\" and \"all.\"\n\n#### **III. DEFINITIONS**\n\nThe definitions supplied by D. Conn. L. Civ. R. 26(c) and the rules of construction supplied by D. Conn. L. Civ. R. 26(d), as incorporated by D. Conn. Bankr. L.R. 2004-1(a), shall apply to the Document Requests. In addition, the following terms used in these Document Requests shall have the following meanings:\n\n1. \"You\" or \"Your\" or \"Yourself\" means and refers, to National Australia Bank Limited.\n\n2. \"Debtor\" means Ho Wan Kwok (a/k/a Miles Kwok, Miles Guo, Guo Wengui, Guo Haoyun, 郭文贵, or any other alias), together with his employees, agents, counsel, advisors, or anyone acting on his behalf.\n\n#### Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 794 of 1063\n\n3. \"Debtor's Son\" means Qiang Guo (a/k/a Mileson Kwok, 郭强, or any other alias), together with his employees, agents, counsel, advisors, or anyone acting on his behalf.\n\n4. \"Debtor's Daughter\" means Mei Guo (a/k/a Mei Gui, 郭美, or any other alias), together with her employees, agents, counsel, advisors, or anyone acting on her behalf.\n\n5. \"Debtor's Purported Wife\" means Hing Chi Ngok (a/k/a Hing Chi Ng, Yue Qingzhi, 岳庆芝, or any other alias), together with her employees, agents, counsel, advisors, or anyone acting on her behalf.\n\n6. \"Debtor's Family\" means, individually and collectively, the Debtor, the Debtor's Son, the Debtor's Daughter, and the Debtor's Purported Wife, and any other familial relation to the Debtor.\n\n7. \"2004 Discovery Targets\" means, individually and collectively, the Debtor, the Debtor's Family, ACA Capital Group Limited, Himalaya International Financial Group Ltd., Himalaya International Clearing Ltd., Himalaya International Payments Ltd., Himalaya International Reserves Ltd., Jesse Brown, William Je, William Je, Eastern Profit Corporation Limited, HK International Funds Investments (USA) Limited LLC, Bravo Luck Limited, Golden Spring (New York) Ltd., Lamp Capital LLC, Greenwich Land LLC, Qu Guo Jiao, Daniel Thomas Podhaskie, Yvette Wang (a/k/a Yanping Wang, a/k/a Yan Ping Wang), Ace Decade Holdings Limited, Dawn State Limited, Rule of Law Society IV Inc., Rule of Law Foundation III, Inc., Rule of Law Foundation IV, Inc., Rule of Law Fund, Rule of Law Society, GTV Media Group, Inc., Voice of Guo Media, Inc., Saraca Media Group Inc., Genever Holdings Corporation, Genever Holdings LLC, Gnews Media Group Inc., G Fashion LLC, Gmusic LLC, Gnews LLC, Geducation, GFNY, Inc., G-Club Investments Limited, G Club Operations LLC, G Club US Operations Inc., G Club US Operations LLC, G Live, LLC, Gbroadcast, LLC, Gposts LLC, HCHK Property\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 795 of 1063\n\nManagement, Inc., HCHK Technologies, Inc., FMV Ltd./Freedom Media Venture Ltd., Roscalitar 2, Himalaya New World Inc., US Himalaya Capital Inc., Hudson Diamond Holding, Inc., Hudson Diamond Holding LLC, Hudson Diamond NY LLC, Infinity Treasury Management Inc., Lexington Property and Staffing, Inc., AI Group Holdings Inc., Hamilton Capital Holdings Inc., Booming Sail New York LLC, Himalaya Ventures LLC, Himalaya Ventures LLC, Himalaya Investment LLC, New York MOS Himalaya LLC, MOS Himalaya LLC, Crane Advisory Group, Maywind Trading LLC, Gettr USA, Inc., Han Chunguang, Bingshang Jiao, Karin Maistrello, Mary Jiang, Jiaming Liu, and Wencong Wang.\n\n8. \"Including\" or any variant thereof means \"including without limitation.\"\n\n9. \"And\" and \"or\" mean \"and/or,\" and shall be construed both conjunctively as well as disjunctively in order to maximize their scope.\n\n10. \"Any\" and \"all\" and \"each\" mean \"each and every.\"\n\n11. \"Each\" and \"every\" mean \"each and every.\"\n\n12. \"Third Party\" means a Person or Entity other than Yourself.\n\n13. \"Transfer\" shall have the meaning given to it by section 101(54) of the Bankruptcy Code.\n\n14. \"Document\" means any information or thing within the scope of Fed. R. Civ. P. 34, and includes, without limitation, each and every written, recorded, or graphic matter of any kind, type, nature, or description that is or has been in Your Possession, Custody or Control, including all printed and electronic copies of electronic mail, computer files maintained in electronic form, correspondence, memoranda, tapes, stenographic or handwritten notes, written forms of any kind, charts, blueprints, drawings, sketches, graphs, plans, articles, specifications, diaries, letters,\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 796 of 1063\n\ntelegrams, photographs, minutes, contracts, agreements, surveys, computer printouts, data compilations of any kind, telexes, facsimiles, emails, text messages, instant messages, voice messages, invoices, order forms, checks, drafts, statements, credit memos, reports, position reports, summaries, indices, books, ledgers, notebooks, schedules, transparencies, recordings, catalogs, advertisements, promotional materials, films, video tapes, audio tapes, CDs, computer disks, brochures, pamphlets, punch-cards, time-slips, Tweets, social media posts, or any written or recorded materials of any other kind, and all meta-data thereof, however stored (whether in tangible or electronic form), recorded, produced, or reproduced, and also including but not limited to, drafts or copies of any of the foregoing that contain any notes, comments, or markings of any kind not found on the original documents or that are otherwise not identical to the original documents.\n\n15. \"Person(s)\" means an individual, corporation, proprietorship, partnership, association, or any other Entity. \"Person\" also includes any agent, representatives, or expert, including but not limiting to, attorneys or financial advisors.\n\n16. \"Entity\" means any natural Person, corporation, partnership, subsidiary, sole proprietorship, firm, board, joint venture, association, agency, authority, commission or other business entity or juristic Person, as well as any affiliate, agent, parent including but not limited to counsel, financial advisors, or any other representative.\n\n17. \"Regarding\" means concerning, describing, comprising, referring to, related to, supporting, favoring, opposing, bolstering, detracting from, located in, considered in connection with, bearing on, evidencing, indicating, reporting on, recording, alluding to, responding to, connected with, commenting on, in respect of, about, in relation to, discussing, showing, describing, reflecting, analyzing constituting, and being.\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 797 of 1063\n\n18. \"Relating to,\" \"relate(s) to\" or \"related to,\" when referring to any given subject matter, means, without limitation, any document that constitutes, comprises, involves, contains, embodies, reflects, identifies, states, refers directly or indirectly to, or is in any way relevant to the particular subject matter identified.\n\n19. \"Communication(s)\" means, in the broadest possible sense, and without limitation, any transmittal of information or knowledge (in the form of facts, ideas, inquiries, or otherwise). Communication(s) further refers to all conversations, agreements, inquiries, or replies, whether in person, by telephone, in writing, or by means of electronic transmittal devices, and includes, but is not limited to, all correspondence, emails, recordings, transmittal slips, memoranda, telephone communications, voice messages, telegrams, telefaxes, telecopies, telexes, instant messages, chats, text messages, postings to a message board or group chat, social media posts, tweets, videos uploaded to any video platform, telephonic notes, or notes transmitted internally or with third parties.\n\n20. \"Asset(s)\" means any item of economic value that is subject to Possession, Custody, or Control. Asset includes all real and personal property, including but limited to, real estate, land, houses, apartments, condominiums, automobiles, yachts, boats, planes, jets, helicopters, cash, bank accounts, cryptocurrencies, securities, accounts receivables, inventory, and other tangible and intangible property.\n\n#### **IV. DOCUMENTS TO BE PRODUCED**\n\n1. All Documents related to any account held by, controlled by, on behalf of, or otherwise related to any of the 2004 Discovery Targets, including any and all account statements, authorizations, power of attorney, trusts, instructions or forms, copies of cancelled checks, correspondence, and wire transfers and related correspondence and instructions.\n\n#### Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 798 of 1063\n\n2. All Documents related to any funds, securities, property, or assets belonging to, held by, controlled by, on behalf of, or otherwise related to any of the 2004 Discovery Targets, including any and all account statements, authorizations, powers of attorney, trusts, instructions or forms, copies of cancelled checks, correspondence, and wire transfers and related correspondence and instructions.\n\n3. All Documents related to any business, commerce or financial transactions, including but not limited to any loan, line of credit, bailment, deposit, swap, securities transactions, mortgage, or ISDA, with any of the 2004 Discovery Targets, including any and all account statements, authorizations, powers of attorney, trusts, instructions or forms, copies of cancelled checks, correspondence, and wire transfers and related correspondence and instructions.\n\n4. All Documents relating to any wire transfer activity relating to the 2004 Discovery Targets, regardless of the existence of any accounts, including but not limited to all wire transfer receipts, account numbers, balances, authorizations, identification information related to the parties to the transfer, correspondence, instructions, or other records.\n\n5. All Documents related to any correspondence and communications between you and the 2004 Discovery Targets.\n\n6. All Documents related to any account with any 2004 Discovery Target relating to opening of the account, authorized users of the account and maintenance of the account.\n\n7. All Documents related to any anti-money laundering, know-your-customer, or other compliance activity relating to any of the 2004 Discovery Targets, including but not limited to any information provided by any of the 2004 Discovery Targets, or learned by You.\n\n8. All Documents relating to any communications with any regulator from any country, including but not limited to the Bank of England, the United States Federal Reserve, the\n\nS.E.C., the CFTC, FINRA, China Securities Regulatory Commission, People's Bank of China, Hong Kong Securities and Futures Commission, and the Hong Kong Monetary Authority relating to any of the 2004 Discovery Targets.\n\nCase 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 800 of 1063\n\n# Exhibit C-44\n\n#### B2540 (Form 2540 – Subpoena for Rule 2004 Examination) (12/15) Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 801 of\n\n1063\n\nUNITED STATES BANKRUPTCY COURT\n\n**District of Connecticut**\n\nIn re HO WAN KWOK, *et al*.,\n\n<sup>1</sup> Case No. 22-50073 (JAM)\n\nDebtor Chapter 11\n\n(Jointly Administered)\n\n# **SUBPOENA FOR RULE 2004 EXAMINATION**\n\n## To: **Metropolitan Commercial Bank and/or Metropolitan Bank Holding Corp.**\n\n(*Name of person to whom the subpoena is directed*)\n\n*Testimony:* **YOU ARE COMMANDED** to appear at the time, date, and place set forth below to testify at an examination under Rule 2004, Federal Rules of Bankruptcy Procedure. A copy of the court order authorizing the examination is attached.\n\n| PLACE                          | DATE AND TIME |\n|--------------------------------|---------------|\n| Neubert, Pepe & Monteith, P.C. |               |\n| 195 Church Street, Floor 13    | [TBD]         |\n| New Haven, Connecticut 06510   |               |\n|                                |               |\n\nThe examination will be recorded by this method: **Court reporter/stenographer**\n\n*Production:* You, or your representatives, must also bring with you to the examination the following documents, electronically stored information, or objects, and must permit inspection, copying, testing, or sampling of the material:\n\n#### **See Requests for Production of Documents, attached hereto.**\n\nThe following provisions of Fed. R. Civ. P. 45, made applicable in bankruptcy cases by Fed. R. Bankr. P. 9016, are attached – Rule 45(c), relating to the place of compliance; Rule 45(d), relating to your protection as a person subject to a subpoena; and Rule 45(e) and 45(g), relating to your duty to respond to this subpoena and the potential consequences of not doing so.\n\nDate: **March , 2023**\n\nCLERK OF COURT\n\nOR\n\n*Signature of Clerk or Deputy Clerk Attorney's signature*\n\nThe name, address, email address, and telephone number of the attorney representing Luc A. Despins, Chapter 11 Trustee, who issues or requests this subpoena, are:\n\n**Douglas S. Skalka, Esq.; Neubert, Pepe & Monteith, P.C.; 195 Church Street, New Haven, Connecticut 06510 dskalka@npmlaw.com; (203) 821-2000**\n\n**Notice to the person who issues or requests this subpoena**\n\nIf this subpoena commands the production of documents, electronically stored information, or tangible things, or the inspection of premises before trial, a notice and a copy of this subpoena must be served on each party before it is served on the person to whom it is directed. Fed. R. Civ. P. 45(a)(4).\n\nSoftware Copyright (c) 1996-2022 Best Case, LLC - www.bestcase.com Best Case Bankruptcy 1 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\n#### **PROOF OF SERVICE**\n\n**(This section should not be filed with the court unless required by Fed. R. Civ. P. 45.)**\n\nI received this subpoena for (*name of individual and title, if any*): on (*date*) .\n\nI served the subpoena by delivering a copy to the named person as follows:\n\non *(date)* ; or\n\nI returned the subpoena unexecuted because:\n\nUnless the subpoena was issued on behalf of the United States, or one of its officers or agents, I have also tendered to the witness the fees for one day's attendance, and the mileage allowed by law, in the amount of \\$ .\n\nMy fees are \\$ for travel and \\$ for services, for a total of \\$ .\n\nI declare under penalty of perjury that this information is true and correct.\n\nDate:\n\n*Server's signature*\n\n*Printed name and title*\n\n*Server's address*\n\nAdditional information concerning attempted service, etc.:\n\n#### **Federal Rule of Civil Procedure 45(c), (d), (e), and (g) (Effective 12/1/13) (made applicable in bankruptcy cases by Rule 9016, Federal Rules of Bankruptcy Procedure)**\n\n#### **(c) Place of compliance.**\n\n*(1) For a Trial, Hearing, or Deposition.* A subpoena may command a person to attend a trial, hearing, or deposition only as follows:\n\n(A) within 100 miles of where the person resides, is employed, or regularly transacts business in person; or\n\n(B) within the state where the person resides, is employed, or regularly transacts business in person, if the person\n\n(i) is a party or a party's officer; or\n\n(ii) is commanded to attend a trial and would not incur substantial expense.\n\n*(2) For Other Discovery.* A subpoena may command:\n\n(A) production of documents, or electronically stored information, or things at a place within 100 miles of where the person resides, is employed, or regularly transacts business in person; and\n\n(B) inspection of premises, at the premises to be inspected.\n\n#### **(d) Protecting a Person Subject to a Subpoena; Enforcement.**\n\n*(1) Avoiding Undue Burden or Expense; Sanctions.* A party or attorney responsible for issuing and serving a subpoena must take reasonable steps to avoid imposing undue burden or expense on a person subject to the subpoena. The court for the district where compliance is required must enforce this duty and impose an appropriate sanction which may include lost earnings and reasonable attorney's fees — on a party or attorney who fails to comply.\n\n#### *(2) Command to Produce Materials or Permit Inspection.*\n\n*(A) Appearance Not Required.* A person commanded to produce documents, electronically stored information, or tangible things, or to permit the inspection of premises, need not appear in person at the place of production or inspection unless also commanded to appear for a deposition, hearing, or trial.\n\n*(B) Objections.* A person commanded to produce documents or tangible things or to permit inspection may serve on the party or attorney designated in the subpoena a written objection to inspecting, copying, testing or sampling any or all of the materials or to inspecting the premises — or to producing electronically stored information in the form or forms requested. The objection must be served before the earlier of the time specified for compliance or 14 days after the subpoena is served. If an objection is made, the following rules apply:\n\n(i) At any time, on notice to the commanded person, the serving party may move the court for the district where compliance is required for an order compelling production or inspection.\n\n(ii) These acts may be required only as directed in the order, and the order must protect a person who is neither a party nor a party's officer from significant expense resulting from compliance.\n\n#### *(3) Quashing or Modifying a Subpoena.*\n\n*(A) When Required.* On timely motion, the court for the district where compliance is required must quash or modify a subpoena that:\n\n(i) fails to allow a reasonable time to comply;\n\n(ii) requires a person to comply beyond the geographical limits specified in Rule 45(c);\n\n(iii) requires disclosure of privileged or other protected matter, if no exception or waiver applies; or\n\n(iv) subjects a person to undue burden.\n\n*(B) When Permitted.* To protect a person subject to or affected by a subpoena, the court for the district where compliance is required may, on motion, quash or modify the subpoena if it requires:\n\n(i) disclosing a trade secret or other confidential research, development, or commercial information; or\n\n(ii) disclosing an unretained expert's opinion or information that does not describe specific occurrences in dispute and results from the expert's study that was not requested by a party.\n\n(C) *Specifying Conditions as an Alternative.* In the circumstances described in Rule 45(d)(3)(B), the court may, instead of quashing or modifying a subpoena, order appearance or production under specified conditions if the serving party:\n\n(i) shows a substantial need for the testimony or material that cannot be otherwise met without undue hardship; and\n\n(ii) ensures that the subpoenaed person will be reasonably compensated.\n\n#### **(e) Duties in Responding to a Subpoena.**\n\n*(1) Producing Documents or Electronically Stored Information.* These procedures apply to producing documents or electronically stored information:\n\n*(A) Documents.* A person responding to a subpoena to produce documents must produce them as they are kept in the ordinary course of business or must organize and label them to correspond to the categories in the demand.\n\n*(B) Form for Producing Electronically Stored Information Not Specified.* If a subpoena does not specify a form for producing electronically stored information, the person responding must produce it in a form or forms in which it is ordinarily maintained or in a reasonably usable form or forms.\n\n*(C) Electronically Stored Information Produced in Only One Form.* The person responding need not produce the same electronically stored information in more than one form.\n\n*(D) Inaccessible Electronically Stored Information.* The person responding need not provide discovery of electronically stored information from sources that the person identifies as not reasonably accessible because of undue burden or cost. On motion to compel discovery or for a protective order, the person responding must show that the information is not reasonably accessible because of undue burden or cost. If that showing is made, the court may nonetheless order discovery from such sources if the requesting party shows good cause, considering the limitations of Rule 26(b)(2)(C). The court may specify conditions for the discovery.\n\n#### *(2) Claiming Privilege or Protection.*\n\n*(A) Information Withheld.* A person withholding subpoenaed information under a claim that it is privileged or subject to protection as trial-preparation material must: (i) expressly make the claim; and\n\n(ii) describe the nature of the withheld documents, communications, or tangible things in a manner that, without revealing information itself privileged or protected, will enable the parties to assess the claim.\n\n*(B) Information Produced.* If information produced in response to a subpoena is subject to a claim of privilege or of protection as trial-preparation material, the person making the claim may notify any party that received the information of the claim and the basis for it. After being notified, a party must promptly return, sequester, or destroy the specified information and any copies it has; must not use or disclose the information until the claim is resolved; must take reasonable steps to retrieve the information if the party disclosed it before being notified; and may promptly present the information under seal to the court for the district where compliance is required for a determination of the claim. The person who produced the information must preserve the information until the claim is resolved.\n\n**(g) Contempt.** The court for the district where compliance is required – and also, after a motion is transferred, the issuing court – may hold in contempt a person who, having been served, fails without adequate excuse to obey the subpoena or an order related to it.\n\nFor access to subpoena materials, see Fed.R.Civ.P.45(a) Committee Note (2013)\n\n…\n\n## **Request for Production of Documents**\n\n## **I. INSTRUCTIONS**\n\n1. Unless otherwise indicated, the requests for documents set forth below, (the \"Requests,\" and each, a \"Request\"), must be responded to separately and specifically. Each Request shall be answered fully unless it is in good faith objected to, in which event the reason for Your objection shall be stated in detail, as set forth below. If an objection pertains only to a portion of a Request, or a word, phrase or clause contained within it, You are required to state Your objection to that portion only and to respond to the remainder of the Requests.\n\n2. Electronically stored information must be produced in accordance with the\n\nfollowing instructions:\n\n- a. Images. Black and white images must be 300 DPI Group IV single-page TIFF files. Color images must be produced in JPEG format. File names cannot contain embedded spaces or special characters (including the comma). Folder names cannot contain embedded spaces or special characters (including the comma). All TIFF image files must have a unique file name, i.e. Bates number. Images must be endorsed with sequential Bates numbers in the lower right corner of each image. The number of TIFF files per folder should not exceed 1000 files. Excel spreadsheets should have a placeholder image named by the Bates number of the file.\n- b. Image Load File\n\t- a. Concordance® Data File. The data file (.DAT) contains all of the fielded information that will be loaded into the Concordance® database. The first line of the .DAT file must be a header row identifying the field names. The .DAT file must use the following Concordance® default delimiters: Comma ASCII character (020) Quote þ ASCII character (254). Date fields should be provided in the format: mm/dd/yyyy. Date and time fields must be two separate fields. If documents includes imaged emails and attachments, the attachment fields must be included to preserve the parent/child relationship between an email and its attachments. An OCRPATH field must be included to provide the file path and name of the extracted text file on the produced storage media. The text file must be named after the FIRSTBATES. Do not include the text in the .DAT file. For Documents with native files, a LINK field must be included to provide the file path and\n\nname of the native file. The native file must be named after the FIRSTBATES.\n\n- b. Concordance Image® OR Opticon Cross-Reference File. The image crossreference file (.LOG or .OPT) links the images to the database records. It should be a comma-delimited file consisting of seven fields per line with a line in the cross-reference file for every image in the database with the following format: ImageID,VolumeLabel,ImageFilePath,DocumentBreak,FolderBreak,Box Break,PageCoun.\n- c. Document Text. Text must be produced as separate text files, not as fields within the .DAT file. The full path to the text file (OCRPATH) should be included in the .DAT file. It is recommended document level ANSI text files, named per the FIRSTBATES/Image Key. Extracted text files must be in a separate folder, and the number of text files per folder should not exceed 1,000 files. There should be no special characters (including commas in the folder names). Text files must be provided on a document level.\n- d. Native Production for Certain File Types. File types that reasonably require viewing in their native format for a full understanding of their content and meaning must be produced in native format. These include, but are not limited to, spreadsheets, spreadsheet-like files (Microsoft Excel, comma separated values, tab separated values, etc.), Microsoft PowerPoint or other special presentation files, database files, and audio/visual files. Provide an image of a Bates numbered slip sheet indicating the presence of a native file, and include the path to the native as a field in the .dat file. Name the produced native file with the Bates number corresponding to the slip sheet for the file. Group native files within incrementally named \"NATIVE\" directories, separate from images directories.\n- e. De-duplication. Produce a single copy of each electronic document for which exact duplicates exist. For email messages, consolidate duplicates based on MD5 hash generated from the BCC, Body, CC, From, IntMsgID, To, and Attach properties. For email attachments and standalone electronic files, consolidate duplicates based on MD5 hash of the entire file.\n- f. Metadata. Produce extracted metadata for each document in the form of a Concordance compliant load file (.dat). The first line of the .DAT file must be a header row identifying the field names. The .DAT file must use the following Concordance default delimiters: Comma , ASCII character (020) Quote þ ASCII character (254)\n\nDate fields should be provided in the format: mm/dd/yyyy. Date and time fields must be two separate fields. Required metadata listed below:\n\n# Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 806 of 1063\n\n| Field Name   | Sample Data              | Description                                      |\n|--------------|--------------------------|--------------------------------------------------|\n| FIRSTBATES   | EDC0000001               | First Bates number of native file document/email |\n| LASTBATES    | EDC0000001               | Last Bates number of native file document/email  |\n|              |                          | **The LASTBATES field should be populated        |\n|              |                          | for single page                                  |\n| ATTACHRANGE  | EDC0000001<br>-          | Bates number of the first page of the parent     |\n|              | EDC0000015               | document to the Bates number of the last page of |\n|              |                          | the last attachment \"child\" document             |\n| BEGATTACH    | EDC0000001               | First Bates number of attachment range           |\n| ENDATTACH    | EDC0000015               | Last Bates number of attachment range            |\n| CUSTODIAN    | Smith, John              | Email: Mailbox where the email resided           |\n|              |                          | Native: Name of the individual or department     |\n|              |                          | from whose files the document<br>originated      |\n| FROM         | John Smith               | Email: Sender                                    |\n|              |                          | Native: Author(s) of document                    |\n|              |                          | **semi-colon should be used to separate          |\n|              |                          | multiple entries                                 |\n| TO           | Coffman, Janice; LeeW    | Recipient(s)                                     |\n|              | [mailto:LeeW@MSN.com]    | **semi-colon should be used to separate multiple |\n|              |                          | entries                                          |\n| CC           | Frank Thompson [mailto:  | Carbon copy recipient(s)                         |\n|              | frank_Thompson@cdt.com]  | **semi-colon should be used to separate          |\n|              |                          | multiple entries                                 |\n| BCC          | John Cain                | Blind carbon copy recipient(s)                   |\n|              |                          | **semi-colon should be used to separate          |\n|              |                          | multiple entries                                 |\n| SUBJECT      | Board Meeting Minutes    | Email: Subject line of the email Native: Title   |\n|              |                          | of document (if available)                       |\n| FILE_NAME    | BoardMeetingMinutes.docx | Native: Name of the original native file,        |\n|              |                          | including extension                              |\n| DATE_SENT    | 10/12/2010               | Email: Date the email was sent                   |\n|              |                          | Native: (empty)                                  |\n| TIME_SENT/   | 07:05 PM GMT             | Email: Time the email was sent/ Time zone in     |\n| TIME_ZONE    |                          | which the emails were standardized               |\n| TIME_ZONE    | GMT                      | The<br>time zone in which<br>the emails<br>were  |\n|              |                          | standardized during conversion.                  |\n| LINK         |  EDC0000001.msg   | Hyperlink to the email or native file document   |\n|              |                          | **The linked file must be named per the          |\n|              |                          | FIRSTBATES number                                |\n| FILE_EXTEN   | MSG                      | The file type extension                          |\n|              |                          | representing                                     |\n|              |                          | the Email or                                     |\n| AUTHOR       | John Smith               | Email: (empty)                                   |\n|              |                          | Native: Author of the document                   |\n| DATE_CREATED | 10/10/2010               | Email: (empty)                                   |\n|              |                          | Native: Date the document was created            |\n\n# Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 807 of 1063\n\n| TIME_CREATED | 10:25 AM                  | Email: (empty)                                  |\n|--------------|---------------------------|-------------------------------------------------|\n|              |                           | Native: Time the document was created           |\n|              |                           | **This data must be a separate field and cannot |\n|              |                           | be combined with the DATE_CREATED field         |\n| DATE_MOD     | 10/12/2010                | Email: (empty)                                  |\n|              |                           | Native: Date the document was last modified     |\n| TIME_MOD     | 07:00 PM                  | Email: (empty)                                  |\n|              |                           | Native: Time the document was last modified     |\n|              |                           | **This data must be a separate field and cannot |\n|              |                           | be combined with the DATE_MOD field             |\n| DATE_ACCESSD | 10/12/2010                | Email: (empty)                                  |\n|              |                           | Native: Date the document was last accessed     |\n| TIME_ACCESSD | 07:00 PM                  | Email: (empty)                                  |\n|              |                           | Native: Time the document was last accessed     |\n|              |                           | **This data must be a separate field and cannot |\n|              |                           | be combined with the DATE_ACCESSD field         |\n| FILE_SIZE    | 5,952                     | Size of native file<br>document/email in KB     |\n| PGCOUNT      | 1                         | Number of pages in native file document/email   |\n| PATH         |   | Email: (empty)                                  |\n|              | Agenda.doc                | Native: Path where native file document was     |\n|              |                           | stored including original file name.            |\n| INTFILEPATH  | Personal Folders\\Deleted  | Email: original location of email including     |\n|              | Items\\Board Meeting       | original file name.                             |\n|              | Minutes.msg               | Native: (empty)                                 |\n| INTMSGID     | <000805c2c71b\\$75977050\\$ | Email: Unique Message ID Native: (empty)        |\n|              | cb8306d1@MSN>             |                                                 |\n| MD5HASH      | d131dd02c5e6eec4693d9a0   | MD5 Hash value of the document.                 |\n|              | 698aff95c                 |                                                 |\n|              | 2fcab58712467eab4004583e  |                                                 |\n|              | b8fb7f89                  |                                                 |\n| OCRPATH      | TEXT/001/EDC0000001.txt   | Path to extracted text of the native file       |\n\n3. Each Request operates and should be construed independently and, unless otherwise indicated, no Request limits the scope of any other Request.\n\n4. All Documents are to be produced as kept in the usual course of business or are to be organized and labeled to correspond with the categories in these Requests.\n\n5. Each Request contained herein extends to all Documents: (a) in Your possession, custody, or control; or (b) in the possession, custody, or control of anyone acting on Your behalf,\n\n#### Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 808 of 1063\n\nincluding Your counsel or other representatives and advisors. Each Document shall be produced in its entirety.\n\n6. If You are requested to produce a Document that is no longer in Your possession, custody, or control, then Your response must (a) describe in detail the nature of the document and its contents; (b) identify the person(s) who prepared or authored the Document (and, if applicable, the Person(s) to whom the Document was sent); (c) identify the date on which the document was prepared or created; (d) state whether such Document (i) is missing or lost, (ii) has been destroyed, (iii) has been transferred, voluntarily or involuntarily, to others, or (iv) was otherwise disposed of; (e) state the reason for, and the facts and circumstances surrounding, such disposition; (f) identify the Persons who authorized such disposition; (g) identify the date or approximate date of such disposition; (h) state when the Document was most recently in Your possession, custody or control; and (i) identify the Person, if any, presently in possession, custody, or control of such Document.\n\n7. If You are requested to produce a Document that has been destroyed, then Your response must state, in addition to the information required by the preceding Instruction: (a) the reason for the Document's destruction; (b) the identity of the Person who destroyed the Document; and (c) the identity of the Person who directed that the Document be destroyed.\n\n8. If You claim that a requested Document is privileged or attorney work-product, then Your response must: (a) state (i) a description of the Document adequate to support Your contention that the Document is privileged, (ii) the title of the Document, (iii) the date of the Document, (iv) the author of the Document, (v) the addressee of the Document, (vi) the identity of each Person who received or saw the original or any draft, copy, or reproduction of the Document, (vii) whether the Document itself, or any information contained or referred to in the Document is in the possession, custody, or control of any other Persons, and if so, the identity of\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 809 of 1063\n\nsuch Persons, as well as a statement addressing how the information came into their possession, (viii) the claim of privilege under which the Document is withheld, and (ix) all of the circumstances upon which You will rely to support such claim of privilege; and (b) produce a privilege log containing all of the information requested in Part (a) of this Instruction for each Document withheld on the basis of a claim of privilege in accordance with D. Conn. L. Civ. R. 26(e). For any part of a Document Request as to which a claim of privilege or work product is not made, responsive documents should be provided in full.\n\n9. If a portion of an otherwise responsive Document contains information subject to a claim of privilege, only that portion of the Document subject to the claim of privilege shall be deleted or redacted from the Document following the instructions above, and the rest shall be produced.\n\n10. The Requests are continuing in nature. You are hereby instructed to (a) supplement or correct any responses later learned to be incomplete or incorrect immediately upon learning that a prior response was incomplete or incorrect; and (b) produce any additional Documents that are called for under the\n\n11. If a Document is in a language other than English, You should provide that Document. If a Document is in a language other than English, and an English translation exists, You should provide both Documents.\n\n12. All references to Entities includes all affiliates thereof.\n\n13. All references to individual names include all alternative names, aliased, or nicknames.\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 810 of 1063\n\n14. Unless otherwise expressly indicated, the period of time covered by the Document Requests is the period from February 5, 2012 to the date responses to the Document Requests are due.\n\n#### **II. RULES OF CONSTRUCTION**\n\n15. The use of (a) any singular noun shall be construed to include the plural, and vice versa, and (b) a verb in any tense shall be construed as the use of the verb in all other tenses.\n\n16. The terms (a) \"and\" and \"or\" shall be construed either conjunctively or disjunctively as necessary to bring within the scope of any request all responses that might otherwise be construed to be outside of its scope, and (b) \"each\" and \"any\" shall be deemed to include and encompass the words \"every\" and \"all.\"\n\n#### **III. DEFINITIONS**\n\nThe definitions supplied by D. Conn. L. Civ. R. 26(c) and the rules of construction supplied by D. Conn. L. Civ. R. 26(d), as incorporated by D. Conn. Bankr. L.R. 2004-1(a), shall apply to the Document Requests. In addition, the following terms used in these Document Requests shall have the following meanings:\n\n1. \"You\" or \"Your\" or \"Yourself\" means and refers, to Metropolitan Commercial Bank and/or Metropolitan Bank Holding Corp.\n\n2. \"Debtor\" means Ho Wan Kwok (a/k/a Miles Kwok, Miles Guo, Guo Wengui, Guo Haoyun, 郭文贵, or any other alias), together with his employees, agents, counsel, advisors, or anyone acting on his behalf.\n\n#### Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 811 of 1063\n\n3. \"Debtor's Son\" means Qiang Guo (a/k/a Mileson Kwok, 郭强, or any other alias), together with his employees, agents, counsel, advisors, or anyone acting on his behalf.\n\n4. \"Debtor's Daughter\" means Mei Guo (a/k/a Mei Gui, 郭美, or any other alias), together with her employees, agents, counsel, advisors, or anyone acting on her behalf.\n\n5. \"Debtor's Purported Wife\" means Hing Chi Ngok (a/k/a Hing Chi Ng, Yue Qingzhi, 岳庆芝, or any other alias), together with her employees, agents, counsel, advisors, or anyone acting on her behalf.\n\n6. \"Debtor's Family\" means, individually and collectively, the Debtor, the Debtor's Son, the Debtor's Daughter, and the Debtor's Purported Wife, and any other familial relation to the Debtor.\n\n7. \"2004 Discovery Targets\" means, individually and collectively, the Debtor, the Debtor's Family, ACA Capital Group Limited, Himalaya International Financial Group Ltd., Himalaya International Clearing Ltd., Himalaya International Payments Ltd., Himalaya International Reserves Ltd., Jesse Brown, William Je, William Je, Eastern Profit Corporation Limited, HK International Funds Investments (USA) Limited LLC, Bravo Luck Limited, Golden Spring (New York) Ltd., Lamp Capital LLC, Greenwich Land LLC, Qu Guo Jiao, Daniel Thomas Podhaskie, Yvette Wang (a/k/a Yanping Wang, a/k/a Yan Ping Wang), Ace Decade Holdings Limited, Dawn State Limited, Rule of Law Society IV Inc., Rule of Law Foundation III, Inc., Rule of Law Foundation IV, Inc., Rule of Law Fund, Rule of Law Society, GTV Media Group, Inc., Voice of Guo Media, Inc., Saraca Media Group Inc., Genever Holdings Corporation, Genever Holdings LLC, Gnews Media Group Inc., G Fashion LLC, Gmusic LLC, Gnews LLC, Geducation, GFNY, Inc., G-Club Investments Limited, G Club Operations LLC, G Club US Operations Inc., G Club US Operations LLC, G Live, LLC, Gbroadcast, LLC, Gposts LLC, HCHK Property\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 812 of 1063\n\nManagement, Inc., HCHK Technologies, Inc., FMV Ltd./Freedom Media Venture Ltd., Roscalitar 2, Himalaya New World Inc., US Himalaya Capital Inc., Hudson Diamond Holding, Inc., Hudson Diamond Holding LLC, Hudson Diamond NY LLC, Infinity Treasury Management Inc., Lexington Property and Staffing, Inc., AI Group Holdings Inc., Hamilton Capital Holdings Inc., Booming Sail New York LLC, Himalaya Ventures LLC, Himalaya Ventures LLC, Himalaya Investment LLC, New York MOS Himalaya LLC, MOS Himalaya LLC, Crane Advisory Group, Maywind Trading LLC, Gettr USA, Inc., Han Chunguang, Bingshang Jiao, Karin Maistrello, Mary Jiang, Jiaming Liu, and Wencong Wang.\n\n8. \"Including\" or any variant thereof means \"including without limitation.\"\n\n9. \"And\" and \"or\" mean \"and/or,\" and shall be construed both conjunctively as well as disjunctively in order to maximize their scope.\n\n10. \"Any\" and \"all\" and \"each\" mean \"each and every.\"\n\n11. \"Each\" and \"every\" mean \"each and every.\"\n\n12. \"Third Party\" means a Person or Entity other than Yourself.\n\n13. \"Transfer\" shall have the meaning given to it by section 101(54) of the Bankruptcy Code.\n\n14. \"Document\" means any information or thing within the scope of Fed. R. Civ. P. 34, and includes, without limitation, each and every written, recorded, or graphic matter of any kind, type, nature, or description that is or has been in Your Possession, Custody or Control, including all printed and electronic copies of electronic mail, computer files maintained in electronic form, correspondence, memoranda, tapes, stenographic or handwritten notes, written forms of any kind, charts, blueprints, drawings, sketches, graphs, plans, articles, specifications, diaries, letters,\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 813 of 1063\n\ntelegrams, photographs, minutes, contracts, agreements, surveys, computer printouts, data compilations of any kind, telexes, facsimiles, emails, text messages, instant messages, voice messages, invoices, order forms, checks, drafts, statements, credit memos, reports, position reports, summaries, indices, books, ledgers, notebooks, schedules, transparencies, recordings, catalogs, advertisements, promotional materials, films, video tapes, audio tapes, CDs, computer disks, brochures, pamphlets, punch-cards, time-slips, Tweets, social media posts, or any written or recorded materials of any other kind, and all meta-data thereof, however stored (whether in tangible or electronic form), recorded, produced, or reproduced, and also including but not limited to, drafts or copies of any of the foregoing that contain any notes, comments, or markings of any kind not found on the original documents or that are otherwise not identical to the original documents.\n\n15. \"Person(s)\" means an individual, corporation, proprietorship, partnership, association, or any other Entity. \"Person\" also includes any agent, representatives, or expert, including but not limiting to, attorneys or financial advisors.\n\n16. \"Entity\" means any natural Person, corporation, partnership, subsidiary, sole proprietorship, firm, board, joint venture, association, agency, authority, commission or other business entity or juristic Person, as well as any affiliate, agent, parent including but not limited to counsel, financial advisors, or any other representative.\n\n17. \"Regarding\" means concerning, describing, comprising, referring to, related to, supporting, favoring, opposing, bolstering, detracting from, located in, considered in connection with, bearing on, evidencing, indicating, reporting on, recording, alluding to, responding to, connected with, commenting on, in respect of, about, in relation to, discussing, showing, describing, reflecting, analyzing constituting, and being.\n\n### Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 814 of 1063\n\n18. \"Relating to,\" \"relate(s) to\" or \"related to,\" when referring to any given subject matter, means, without limitation, any document that constitutes, comprises, involves, contains, embodies, reflects, identifies, states, refers directly or indirectly to, or is in any way relevant to the particular subject matter identified.\n\n19. \"Communication(s)\" means, in the broadest possible sense, and without limitation, any transmittal of information or knowledge (in the form of facts, ideas, inquiries, or otherwise). Communication(s) further refers to all conversations, agreements, inquiries, or replies, whether in person, by telephone, in writing, or by means of electronic transmittal devices, and includes, but is not limited to, all correspondence, emails, recordings, transmittal slips, memoranda, telephone communications, voice messages, telegrams, telefaxes, telecopies, telexes, instant messages, chats, text messages, postings to a message board or group chat, social media posts, tweets, videos uploaded to any video platform, telephonic notes, or notes transmitted internally or with third parties.\n\n20. \"Asset(s)\" means any item of economic value that is subject to Possession, Custody, or Control. Asset includes all real and personal property, including but limited to, real estate, land, houses, apartments, condominiums, automobiles, yachts, boats, planes, jets, helicopters, cash, bank accounts, cryptocurrencies, securities, accounts receivables, inventory, and other tangible and intangible property.\n\n#### **IV. DOCUMENTS TO BE PRODUCED**\n\n1. All Documents related to any account held by, controlled by, on behalf of, or otherwise related to any of the 2004 Discovery Targets, including any and all account statements, authorizations, power of attorney, trusts, instructions or forms, copies of cancelled checks, correspondence, and wire transfers and related correspondence and instructions.\n\n#### Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 815 of 1063\n\n2. All Documents related to any funds, securities, property, or assets belonging to, held by, controlled by, on behalf of, or otherwise related to any of the 2004 Discovery Targets, including any and all account statements, authorizations, powers of attorney, trusts, instructions or forms, copies of cancelled checks, correspondence, and wire transfers and related correspondence and instructions.\n\n3. All Documents related to any business, commerce or financial transactions, including but not limited to any loan, line of credit, bailment, deposit, swap, securities transactions, mortgage, or ISDA, with any of the 2004 Discovery Targets, including any and all account statements, authorizations, powers of attorney, trusts, instructions or forms, copies of cancelled checks, correspondence, and wire transfers and related correspondence and instructions.\n\n4. All Documents relating to any wire transfer activity relating to the 2004 Discovery Targets, regardless of the existence of any accounts, including but not limited to all wire transfer receipts, account numbers, balances, authorizations, identification information related to the parties to the transfer, correspondence, instructions, or other records.\n\n5. All Documents related to any correspondence and communications between you and the 2004 Discovery Targets.\n\n6. All Documents related to any account with any 2004 Discovery Target relating to opening of the account, authorized users of the account and maintenance of the account.\n\n7. All Documents related to any anti-money laundering, know-your-customer, or other compliance activity relating to any of the 2004 Discovery Targets, including but not limited to any information provided by any of the 2004 Discovery Targets, or learned by You.\n\n8. All Documents relating to any communications with any regulator from any country, including but not limited to the Bank of England, the United States Federal Reserve, the\n\nS.E.C., the CFTC, FINRA, China Securities Regulatory Commission, People's Bank of China, Hong Kong Securities and Futures Commission, and the Hong Kong Monetary Authority relating to any of the 2004 Discovery Targets.\n\n# Exhibit C-45\n\n#### B2540 (Form 2540 – Subpoena for Rule 2004 Examination) (12/15) Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 818 of\n\n1063\n\nUNITED STATES BANKRUPTCY COURT\n\n**District of Connecticut**\n\nIn re HO WAN KWOK, *et al*.,\n\n<sup>1</sup> Case No. 22-50073 (JAM) Debtor Chapter 11\n\n(Jointly Administered)\n\n# **SUBPOENA FOR RULE 2004 EXAMINATION**\n\nTo: **Open Bank**\n\n(*Name of person to whom the subpoena is directed*)\n\n*Testimony:* **YOU ARE COMMANDED** to appear at the time, date, and place set forth below to testify at an examination under Rule 2004, Federal Rules of Bankruptcy Procedure. A copy of the court order authorizing the examination is attached.\n\n| PLACE                          | DATE AND TIME |\n|--------------------------------|---------------|\n| Neubert, Pepe & Monteith, P.C. |               |\n| 195 Church Street, Floor 13    | [TBD]         |\n| New Haven, Connecticut 06510   |               |\n|                                |               |\n\nThe examination will be recorded by this method: **Court reporter/stenographer**\n\n*Production:* You, or your representatives, must also bring with you to the examination the following documents, electronically stored information, or objects, and must permit inspection, copying, testing, or sampling of the material:\n\n#### **See Requests for Production of Documents, attached hereto.**\n\nThe following provisions of Fed. R. Civ. P. 45, made applicable in bankruptcy cases by Fed. R. Bankr. P. 9016, are attached – Rule 45(c), relating to the place of compliance; Rule 45(d), relating to your protection as a person subject to a subpoena; and Rule 45(e) and 45(g), relating to your duty to respond to this subpoena and the potential consequences of not doing so.\n\nDate: **March , 2023**\n\nCLERK OF COURT\n\nOR\n\n*Signature of Clerk or Deputy Clerk Attorney's signature*\n\nThe name, address, email address, and telephone number of the attorney representing Luc A. Despins, Chapter 11 Trustee, who issues or requests this subpoena, are:\n\n**Douglas S. Skalka, Esq.; Neubert, Pepe & Monteith, P.C.; 195 Church Street, New Haven, Connecticut 06510 dskalka@npmlaw.com; (203) 821-2000**\n\n**Notice to the person who issues or requests this subpoena**\n\nIf this subpoena commands the production of documents, electronically stored information, or tangible things, or the inspection of premises before trial, a notice and a copy of this subpoena must be served on each party before it is served on the person to whom it is directed. Fed. R. Civ. P. 45(a)(4).\n\nSoftware Copyright (c) 1996-2022 Best Case, LLC - www.bestcase.com Best Case Bankruptcy 1 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\n#### **PROOF OF SERVICE**\n\n**(This section should not be filed with the court unless required by Fed. R. Civ. P. 45.)**\n\nI received this subpoena for (*name of individual and title, if any*): on (*date*) .\n\nI served the subpoena by delivering a copy to the named person as follows:\n\non *(date)* ; or\n\nI returned the subpoena unexecuted because:\n\nUnless the subpoena was issued on behalf of the United States, or one of its officers or agents, I have also tendered to the witness the fees for one day's attendance, and the mileage allowed by law, in the amount of \\$ .\n\nMy fees are \\$ for travel and \\$ for services, for a total of \\$ .\n\nI declare under penalty of perjury that this information is true and correct.\n\nDate:\n\n*Server's signature*\n\n*Printed name and title*\n\n*Server's address*\n\nAdditional information concerning attempted service, etc.:\n\n#### **Federal Rule of Civil Procedure 45(c), (d), (e), and (g) (Effective 12/1/13) (made applicable in bankruptcy cases by Rule 9016, Federal Rules of Bankruptcy Procedure)**\n\n#### **(c) Place of compliance.**\n\n*(1) For a Trial, Hearing, or Deposition.* A subpoena may command a person to attend a trial, hearing, or deposition only as follows:\n\n(A) within 100 miles of where the person resides, is employed, or regularly transacts business in person; or\n\n(B) within the state where the person resides, is employed, or regularly transacts business in person, if the person\n\n(i) is a party or a party's officer; or\n\n(ii) is commanded to attend a trial and would not incur substantial expense.\n\n*(2) For Other Discovery.* A subpoena may command:\n\n(A) production of documents, or electronically stored information, or things at a place within 100 miles of where the person resides, is employed, or regularly transacts business in person; and\n\n(B) inspection of premises, at the premises to be inspected.\n\n#### **(d) Protecting a Person Subject to a Subpoena; Enforcement.**\n\n*(1) Avoiding Undue Burden or Expense; Sanctions.* A party or attorney responsible for issuing and serving a subpoena must take reasonable steps to avoid imposing undue burden or expense on a person subject to the subpoena. The court for the district where compliance is required must enforce this duty and impose an appropriate sanction which may include lost earnings and reasonable attorney's fees — on a party or attorney who fails to comply.\n\n#### *(2) Command to Produce Materials or Permit Inspection.*\n\n*(A) Appearance Not Required.* A person commanded to produce documents, electronically stored information, or tangible things, or to permit the inspection of premises, need not appear in person at the place of production or inspection unless also commanded to appear for a deposition, hearing, or trial.\n\n*(B) Objections.* A person commanded to produce documents or tangible things or to permit inspection may serve on the party or attorney designated in the subpoena a written objection to inspecting, copying, testing or sampling any or all of the materials or to inspecting the premises — or to producing electronically stored information in the form or forms requested. The objection must be served before the earlier of the time specified for compliance or 14 days after the subpoena is served. If an objection is made, the following rules apply:\n\n(i) At any time, on notice to the commanded person, the serving party may move the court for the district where compliance is required for an order compelling production or inspection.\n\n(ii) These acts may be required only as directed in the order, and the order must protect a person who is neither a party nor a party's officer from significant expense resulting from compliance.\n\n#### *(3) Quashing or Modifying a Subpoena.*\n\n*(A) When Required.* On timely motion, the court for the district where compliance is required must quash or modify a subpoena that:\n\n(i) fails to allow a reasonable time to comply;\n\n(ii) requires a person to comply beyond the geographical limits specified in Rule 45(c);\n\n(iii) requires disclosure of privileged or other protected matter, if no exception or waiver applies; or\n\n(iv) subjects a person to undue burden.\n\n*(B) When Permitted.* To protect a person subject to or affected by a subpoena, the court for the district where compliance is required may, on motion, quash or modify the subpoena if it requires:\n\n(i) disclosing a trade secret or other confidential research, development, or commercial information; or\n\n(ii) disclosing an unretained expert's opinion or information that does not describe specific occurrences in dispute and results from the expert's study that was not requested by a party.\n\n(C) *Specifying Conditions as an Alternative.* In the circumstances described in Rule 45(d)(3)(B), the court may, instead of quashing or modifying a subpoena, order appearance or production under specified conditions if the serving party:\n\n(i) shows a substantial need for the testimony or material that cannot be otherwise met without undue hardship; and\n\n(ii) ensures that the subpoenaed person will be reasonably compensated.\n\n#### **(e) Duties in Responding to a Subpoena.**\n\n*(1) Producing Documents or Electronically Stored Information.* These procedures apply to producing documents or electronically stored information:\n\n*(A) Documents.* A person responding to a subpoena to produce documents must produce them as they are kept in the ordinary course of business or must organize and label them to correspond to the categories in the demand.\n\n*(B) Form for Producing Electronically Stored Information Not Specified.* If a subpoena does not specify a form for producing electronically stored information, the person responding must produce it in a form or forms in which it is ordinarily maintained or in a reasonably usable form or forms.\n\n*(C) Electronically Stored Information Produced in Only One Form.* The person responding need not produce the same electronically stored information in more than one form.\n\n*(D) Inaccessible Electronically Stored Information.* The person responding need not provide discovery of electronically stored information from sources that the person identifies as not reasonably accessible because of undue burden or cost. On motion to compel discovery or for a protective order, the person responding must show that the information is not reasonably accessible because of undue burden or cost. If that showing is made, the court may nonetheless order discovery from such sources if the requesting party shows good cause, considering the limitations of Rule 26(b)(2)(C). The court may specify conditions for the discovery.\n\n#### *(2) Claiming Privilege or Protection.*\n\n*(A) Information Withheld.* A person withholding subpoenaed information under a claim that it is privileged or subject to protection as trial-preparation material must: (i) expressly make the claim; and\n\n(ii) describe the nature of the withheld documents, communications, or tangible things in a manner that, without revealing information itself privileged or protected, will enable the parties to assess the claim.\n\n*(B) Information Produced.* If information produced in response to a subpoena is subject to a claim of privilege or of protection as trial-preparation material, the person making the claim may notify any party that received the information of the claim and the basis for it. After being notified, a party must promptly return, sequester, or destroy the specified information and any copies it has; must not use or disclose the information until the claim is resolved; must take reasonable steps to retrieve the information if the party disclosed it before being notified; and may promptly present the information under seal to the court for the district where compliance is required for a determination of the claim. The person who produced the information must preserve the information until the claim is resolved.\n\n**(g) Contempt.** The court for the district where compliance is required – and also, after a motion is transferred, the issuing court – may hold in contempt a person who, having been served, fails without adequate excuse to obey the subpoena or an order related to it.\n\nFor access to subpoena materials, see Fed.R.Civ.P.45(a) Committee Note (2013)\n\n…\n\n## **Request for Production of Documents**\n\n## **I. INSTRUCTIONS**\n\n1. Unless otherwise indicated, the requests for documents set forth below, (the \"Requests,\" and each, a \"Request\"), must be responded to separately and specifically. Each Request shall be answered fully unless it is in good faith objected to, in which event the reason for Your objection shall be stated in detail, as set forth below. If an objection pertains only to a portion of a Request, or a word, phrase or clause contained within it, You are required to state Your objection to that portion only and to respond to the remainder of the Requests.\n\n2. Electronically stored information must be produced in accordance with the\n\nfollowing instructions:\n\n- a. Images. Black and white images must be 300 DPI Group IV single-page TIFF files. Color images must be produced in JPEG format. File names cannot contain embedded spaces or special characters (including the comma). Folder names cannot contain embedded spaces or special characters (including the comma). All TIFF image files must have a unique file name, i.e. Bates number. Images must be endorsed with sequential Bates numbers in the lower right corner of each image. The number of TIFF files per folder should not exceed 1000 files. Excel spreadsheets should have a placeholder image named by the Bates number of the file.\n- b. Image Load File\n\t- a. Concordance® Data File. The data file (.DAT) contains all of the fielded information that will be loaded into the Concordance® database. The first line of the .DAT file must be a header row identifying the field names. The .DAT file must use the following Concordance® default delimiters: Comma ASCII character (020) Quote þ ASCII character (254). Date fields should be provided in the format: mm/dd/yyyy. Date and time fields must be two separate fields. If documents includes imaged emails and attachments, the attachment fields must be included to preserve the parent/child relationship between an email and its attachments. An OCRPATH field must be included to provide the file path and name of the extracted text file on the produced storage media. The text file must be named after the FIRSTBATES. Do not include the text in the .DAT file. For Documents with native files, a LINK field must be included to provide the file path and\n\nname of the native file. The native file must be named after the FIRSTBATES.\n\n- b. Concordance Image® OR Opticon Cross-Reference File. The image crossreference file (.LOG or .OPT) links the images to the database records. It should be a comma-delimited file consisting of seven fields per line with a line in the cross-reference file for every image in the database with the following format: ImageID,VolumeLabel,ImageFilePath,DocumentBreak,FolderBreak,Box Break,PageCoun.\n- c. Document Text. Text must be produced as separate text files, not as fields within the .DAT file. The full path to the text file (OCRPATH) should be included in the .DAT file. It is recommended document level ANSI text files, named per the FIRSTBATES/Image Key. Extracted text files must be in a separate folder, and the number of text files per folder should not exceed 1,000 files. There should be no special characters (including commas in the folder names). Text files must be provided on a document level.\n- d. Native Production for Certain File Types. File types that reasonably require viewing in their native format for a full understanding of their content and meaning must be produced in native format. These include, but are not limited to, spreadsheets, spreadsheet-like files (Microsoft Excel, comma separated values, tab separated values, etc.), Microsoft PowerPoint or other special presentation files, database files, and audio/visual files. Provide an image of a Bates numbered slip sheet indicating the presence of a native file, and include the path to the native as a field in the .dat file. Name the produced native file with the Bates number corresponding to the slip sheet for the file. Group native files within incrementally named \"NATIVE\" directories, separate from images directories.\n- e. De-duplication. Produce a single copy of each electronic document for which exact duplicates exist. For email messages, consolidate duplicates based on MD5 hash generated from the BCC, Body, CC, From, IntMsgID, To, and Attach properties. For email attachments and standalone electronic files, consolidate duplicates based on MD5 hash of the entire file.\n- f. Metadata. Produce extracted metadata for each document in the form of a Concordance compliant load file (.dat). The first line of the .DAT file must be a header row identifying the field names. The .DAT file must use the following Concordance default delimiters: Comma , ASCII character (020) Quote þ ASCII character (254)\n\nDate fields should be provided in the format: mm/dd/yyyy. Date and time fields must be two separate fields. Required metadata listed below:\n\n# Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 823 of 1063\n\n| Field Name   | Sample Data              | Description                                                                                  |\n|--------------|--------------------------|----------------------------------------------------------------------------------------------|\n| FIRSTBATES   | EDC0000001               | First Bates number of native file document/email                                             |\n| LASTBATES    | EDC0000001               | Last Bates number of native file document/email<br>**The LASTBATES field should be populated |\n|              |                          | for single page                                                                              |\n| ATTACHRANGE  | EDC0000001<br>-          | Bates number of the first page of the parent                                                 |\n|              | EDC0000015               | document to the Bates number of the last page of                                             |\n|              |                          | the last attachment \"child\" document                                                         |\n| BEGATTACH    | EDC0000001               | First Bates number of attachment range                                                       |\n| ENDATTACH    | EDC0000015               | Last Bates number of attachment range                                                        |\n| CUSTODIAN    | Smith, John              | Email: Mailbox where the email resided                                                       |\n|              |                          | Native: Name of the individual or department                                                 |\n|              |                          | from whose files the document<br>originated                                                  |\n| FROM         | John Smith               | Email: Sender                                                                                |\n|              |                          | Native: Author(s) of document                                                                |\n|              |                          | **semi-colon should be used to separate                                                      |\n|              |                          | multiple entries                                                                             |\n| TO           | Coffman, Janice; LeeW    | Recipient(s)                                                                                 |\n|              | [mailto:LeeW@MSN.com]    | **semi-colon should be used to separate multiple                                             |\n|              |                          | entries                                                                                      |\n| CC           | Frank Thompson [mailto:  | Carbon copy recipient(s)                                                                     |\n|              | frank_Thompson@cdt.com]  | **semi-colon should be used to separate                                                      |\n|              |                          | multiple entries                                                                             |\n| BCC          | John Cain                | Blind carbon copy recipient(s)                                                               |\n|              |                          | **semi-colon should be used to separate                                                      |\n|              |                          | multiple entries                                                                             |\n| SUBJECT      | Board Meeting Minutes    | Email: Subject line of the email Native: Title                                               |\n|              |                          | of document (if available)                                                                   |\n| FILE_NAME    | BoardMeetingMinutes.docx | Native: Name of the original native file,                                                    |\n|              |                          | including extension                                                                          |\n| DATE_SENT    | 10/12/2010               | Email: Date the email was sent                                                               |\n|              |                          | Native: (empty)                                                                              |\n| TIME_SENT/   | 07:05 PM GMT             | Email: Time the email was sent/ Time zone in                                                 |\n| TIME_ZONE    |                          | which the emails were standardized                                                           |\n| TIME_ZONE    | GMT                      | The<br>time zone in which<br>the emails<br>were                                              |\n|              |                          | standardized during conversion.                                                              |\n| LINK         |  EDC0000001.msg   | Hyperlink to the email or native file document                                               |\n|              |                          | **The linked file must be named per the                                                      |\n|              |                          | FIRSTBATES number                                                                            |\n| FILE_EXTEN   | MSG                      | The file type extension                                                                      |\n|              |                          | representing                                                                                 |\n|              |                          | the Email or                                                                                 |\n| AUTHOR       | John Smith               | Email: (empty)                                                                               |\n|              |                          | Native: Author of the document                                                               |\n| DATE_CREATED | 10/10/2010               | Email: (empty)                                                                               |\n|              |                          | Native: Date the document was created                                                        |\n\n# Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 824 of 1063\n\n| TIME_CREATED | 10:25 AM                  | Email: (empty)                                  |\n|--------------|---------------------------|-------------------------------------------------|\n|              |                           | Native: Time the document was created           |\n|              |                           | **This data must be a separate field and cannot |\n|              |                           | be combined with the DATE_CREATED field         |\n| DATE_MOD     | 10/12/2010                | Email: (empty)                                  |\n|              |                           | Native: Date the document was last modified     |\n| TIME_MOD     | 07:00 PM                  | Email: (empty)                                  |\n|              |                           | Native: Time the document was last modified     |\n|              |                           | **This data must be a separate field and cannot |\n|              |                           | be combined with the DATE_MOD field             |\n| DATE_ACCESSD | 10/12/2010                | Email: (empty)                                  |\n|              |                           | Native: Date the document was last accessed     |\n| TIME_ACCESSD | 07:00 PM                  | Email: (empty)                                  |\n|              |                           | Native: Time the document was last accessed     |\n|              |                           | **This data must be a separate field and cannot |\n|              |                           | be combined with the DATE_ACCESSD field         |\n| FILE_SIZE    | 5,952                     | Size of native file<br>document/email in KB     |\n| PGCOUNT      | 1                         | Number of pages in native file document/email   |\n| PATH         |   | Email: (empty)                                  |\n|              | Agenda.doc                | Native: Path where native file document was     |\n|              |                           | stored including original file name.            |\n| INTFILEPATH  | Personal Folders\\Deleted  | Email: original location of email including     |\n|              | Items\\Board Meeting       | original file name.                             |\n|              | Minutes.msg               | Native: (empty)                                 |\n| INTMSGID     | <000805c2c71b\\$75977050\\$ | Email: Unique Message ID Native: (empty)        |\n|              | cb8306d1@MSN>             |                                                 |\n| MD5HASH      | d131dd02c5e6eec4693d9a0   | MD5 Hash value of the document.                 |\n|              | 698aff95c                 |                                                 |\n|              | 2fcab58712467eab4004583e  |                                                 |\n|              | b8fb7f89                  |                                                 |\n| OCRPATH      | TEXT/001/EDC0000001.txt   | Path to extracted text of the native file       |\n\n3. Each Request operates and should be construed independently and, unless otherwise indicated, no Request limits the scope of any other Request.\n\n4. All Documents are to be produced as kept in the usual course of business or are to be organized and labeled to correspond with the categories in these Requests.\n\n5. Each Request contained herein extends to all Documents: (a) in Your possession, custody, or control; or (b) in the possession, custody, or control of anyone acting on Your behalf,\n\n#### Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 825 of 1063\n\nincluding Your counsel or other representatives and advisors. Each Document shall be produced in its entirety.\n\n6. If You are requested to produce a Document that is no longer in Your possession, custody, or control, then Your response must (a) describe in detail the nature of the document and its contents; (b) identify the person(s) who prepared or authored the Document (and, if applicable, the Person(s) to whom the Document was sent); (c) identify the date on which the document was prepared or created; (d) state whether such Document (i) is missing or lost, (ii) has been destroyed, (iii) has been transferred, voluntarily or involuntarily, to others, or (iv) was otherwise disposed of; (e) state the reason for, and the facts and circumstances surrounding, such disposition; (f) identify the Persons who authorized such disposition; (g) identify the date or approximate date of such disposition; (h) state when the Document was most recently in Your possession, custody or control; and (i) identify the Person, if any, presently in possession, custody, or control of such Document.\n\n7. If You are requested to produce a Document that has been destroyed, then Your response must state, in addition to the information required by the preceding Instruction: (a) the reason for the Document's destruction; (b) the identity of the Person who destroyed the Document; and (c) the identity of the Person who directed that the Document be destroyed.\n\n8. If You claim that a requested Document is privileged or attorney work-product, then Your response must: (a) state (i) a description of the Document adequate to support Your contention that the Document is privileged, (ii) the title of the Document, (iii) the date of the Document, (iv) the author of the Document, (v) the addressee of the Document, (vi) the identity of each Person who received or saw the original or any draft, copy, or reproduction of the Document, (vii) whether the Document itself, or any information contained or referred to in the Document is in the possession, custody, or control of any other Persons, and if so, the identity of\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 826 of 1063\n\nsuch Persons, as well as a statement addressing how the information came into their possession, (viii) the claim of privilege under which the Document is withheld, and (ix) all of the circumstances upon which You will rely to support such claim of privilege; and (b) produce a privilege log containing all of the information requested in Part (a) of this Instruction for each Document withheld on the basis of a claim of privilege in accordance with D. Conn. L. Civ. R. 26(e). For any part of a Document Request as to which a claim of privilege or work product is not made, responsive documents should be provided in full.\n\n9. If a portion of an otherwise responsive Document contains information subject to a claim of privilege, only that portion of the Document subject to the claim of privilege shall be deleted or redacted from the Document following the instructions above, and the rest shall be produced.\n\n10. The Requests are continuing in nature. You are hereby instructed to (a) supplement or correct any responses later learned to be incomplete or incorrect immediately upon learning that a prior response was incomplete or incorrect; and (b) produce any additional Documents that are called for under the\n\n11. If a Document is in a language other than English, You should provide that Document. If a Document is in a language other than English, and an English translation exists, You should provide both Documents.\n\n12. All references to Entities includes all affiliates thereof.\n\n13. All references to individual names include all alternative names, aliased, or nicknames.\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 827 of 1063\n\n14. Unless otherwise expressly indicated, the period of time covered by the Document Requests is the period from February 5, 2012 to the date responses to the Document Requests are due.\n\n#### **II. RULES OF CONSTRUCTION**\n\n15. The use of (a) any singular noun shall be construed to include the plural, and vice versa, and (b) a verb in any tense shall be construed as the use of the verb in all other tenses.\n\n16. The terms (a) \"and\" and \"or\" shall be construed either conjunctively or disjunctively as necessary to bring within the scope of any request all responses that might otherwise be construed to be outside of its scope, and (b) \"each\" and \"any\" shall be deemed to include and encompass the words \"every\" and \"all.\"\n\n#### **III. DEFINITIONS**\n\nThe definitions supplied by D. Conn. L. Civ. R. 26(c) and the rules of construction supplied by D. Conn. L. Civ. R. 26(d), as incorporated by D. Conn. Bankr. L.R. 2004-1(a), shall apply to the Document Requests. In addition, the following terms used in these Document Requests shall have the following meanings:\n\n1. \"You\" or \"Your\" or \"Yourself\" means and refers, to Open Bank.\n\n2. \"Debtor\" means Ho Wan Kwok (a/k/a Miles Kwok, Miles Guo, Guo Wengui, Guo Haoyun, 郭文贵, or any other alias), together with his employees, agents, counsel, advisors, or anyone acting on his behalf.\n\n3. \"Debtor's Son\" means Qiang Guo (a/k/a Mileson Kwok, 郭强, or any other alias), together with his employees, agents, counsel, advisors, or anyone acting on his behalf.\n\n#### Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 828 of 1063\n\n4. \"Debtor's Daughter\" means Mei Guo (a/k/a Mei Gui, 郭美, or any other alias),\n\ntogether with her employees, agents, counsel, advisors, or anyone acting on her behalf.\n\n5. \"Debtor's Purported Wife\" means Hing Chi Ngok (a/k/a Hing Chi Ng, Yue Qingzhi, 岳庆芝, or any other alias), together with her employees, agents, counsel, advisors, or anyone acting on her behalf.\n\n6. \"Debtor's Family\" means, individually and collectively, the Debtor, the Debtor's Son, the Debtor's Daughter, and the Debtor's Purported Wife, and any other familial relation to the Debtor.\n\n7. \"2004 Discovery Targets\" means, individually and collectively, the Debtor, the Debtor's Family, ACA Capital Group Limited, Himalaya International Financial Group Ltd., Himalaya International Clearing Ltd., Himalaya International Payments Ltd., Himalaya International Reserves Ltd., Jesse Brown, William Je, William Je, Eastern Profit Corporation Limited, HK International Funds Investments (USA) Limited LLC, Bravo Luck Limited, Golden Spring (New York) Ltd., Lamp Capital LLC, Greenwich Land LLC, Qu Guo Jiao, Daniel Thomas Podhaskie, Yvette Wang (a/k/a Yanping Wang, a/k/a Yan Ping Wang), Ace Decade Holdings Limited, Dawn State Limited, Rule of Law Society IV Inc., Rule of Law Foundation III, Inc., Rule of Law Foundation IV, Inc., Rule of Law Fund, Rule of Law Society, GTV Media Group, Inc., Voice of Guo Media, Inc., Saraca Media Group Inc., Genever Holdings Corporation, Genever Holdings LLC, Gnews Media Group Inc., G Fashion LLC, Gmusic LLC, Gnews LLC, Geducation, GFNY, Inc., G-Club Investments Limited, G Club Operations LLC, G Club US Operations Inc., G Club US Operations LLC, G Live, LLC, Gbroadcast, LLC, Gposts LLC, HCHK Property Management, Inc., HCHK Technologies, Inc., FMV Ltd./Freedom Media Venture Ltd., Roscalitar 2, Himalaya New World Inc., US Himalaya Capital Inc., Hudson Diamond Holding, Inc., Hudson\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 829 of 1063\n\nDiamond Holding LLC, Hudson Diamond NY LLC, Infinity Treasury Management Inc., Lexington Property and Staffing, Inc., AI Group Holdings Inc., Hamilton Capital Holdings Inc., Booming Sail New York LLC, Himalaya Ventures LLC, Himalaya Ventures LLC, Himalaya Investment LLC, New York MOS Himalaya LLC, MOS Himalaya LLC, Crane Advisory Group, Maywind Trading LLC, Gettr USA, Inc., Han Chunguang, Bingshang Jiao, Karin Maistrello, Mary Jiang, Jiaming Liu, and Wencong Wang.\n\n8. \"Including\" or any variant thereof means \"including without limitation.\"\n\n9. \"And\" and \"or\" mean \"and/or,\" and shall be construed both conjunctively as well as disjunctively in order to maximize their scope.\n\n10. \"Any\" and \"all\" and \"each\" mean \"each and every.\"\n\n11. \"Each\" and \"every\" mean \"each and every.\"\n\n12. \"Third Party\" means a Person or Entity other than Yourself.\n\n13. \"Transfer\" shall have the meaning given to it by section 101(54) of the Bankruptcy Code.\n\n14. \"Document\" means any information or thing within the scope of Fed. R. Civ. P. 34, and includes, without limitation, each and every written, recorded, or graphic matter of any kind, type, nature, or description that is or has been in Your Possession, Custody or Control, including all printed and electronic copies of electronic mail, computer files maintained in electronic form, correspondence, memoranda, tapes, stenographic or handwritten notes, written forms of any kind, charts, blueprints, drawings, sketches, graphs, plans, articles, specifications, diaries, letters, telegrams, photographs, minutes, contracts, agreements, surveys, computer printouts, data compilations of any kind, telexes, facsimiles, emails, text messages, instant messages, voice\n\n### Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 830 of 1063\n\nmessages, invoices, order forms, checks, drafts, statements, credit memos, reports, position reports, summaries, indices, books, ledgers, notebooks, schedules, transparencies, recordings, catalogs, advertisements, promotional materials, films, video tapes, audio tapes, CDs, computer disks, brochures, pamphlets, punch-cards, time-slips, Tweets, social media posts, or any written or recorded materials of any other kind, and all meta-data thereof, however stored (whether in tangible or electronic form), recorded, produced, or reproduced, and also including but not limited to, drafts or copies of any of the foregoing that contain any notes, comments, or markings of any kind not found on the original documents or that are otherwise not identical to the original documents.\n\n15. \"Person(s)\" means an individual, corporation, proprietorship, partnership, association, or any other Entity. \"Person\" also includes any agent, representatives, or expert, including but not limiting to, attorneys or financial advisors.\n\n16. \"Entity\" means any natural Person, corporation, partnership, subsidiary, sole proprietorship, firm, board, joint venture, association, agency, authority, commission or other business entity or juristic Person, as well as any affiliate, agent, parent including but not limited to counsel, financial advisors, or any other representative.\n\n17. \"Regarding\" means concerning, describing, comprising, referring to, related to, supporting, favoring, opposing, bolstering, detracting from, located in, considered in connection with, bearing on, evidencing, indicating, reporting on, recording, alluding to, responding to, connected with, commenting on, in respect of, about, in relation to, discussing, showing, describing, reflecting, analyzing constituting, and being.\n\n18. \"Relating to,\" \"relate(s) to\" or \"related to,\" when referring to any given subject matter, means, without limitation, any document that constitutes, comprises, involves, contains,\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 831 of 1063\n\nembodies, reflects, identifies, states, refers directly or indirectly to, or is in any way relevant to the particular subject matter identified.\n\n19. \"Communication(s)\" means, in the broadest possible sense, and without limitation, any transmittal of information or knowledge (in the form of facts, ideas, inquiries, or otherwise). Communication(s) further refers to all conversations, agreements, inquiries, or replies, whether in person, by telephone, in writing, or by means of electronic transmittal devices, and includes, but is not limited to, all correspondence, emails, recordings, transmittal slips, memoranda, telephone communications, voice messages, telegrams, telefaxes, telecopies, telexes, instant messages, chats, text messages, postings to a message board or group chat, social media posts, tweets, videos uploaded to any video platform, telephonic notes, or notes transmitted internally or with third parties.\n\n20. \"Asset(s)\" means any item of economic value that is subject to Possession, Custody, or Control. Asset includes all real and personal property, including but limited to, real estate, land, houses, apartments, condominiums, automobiles, yachts, boats, planes, jets, helicopters, cash, bank accounts, cryptocurrencies, securities, accounts receivables, inventory, and other tangible and intangible property.\n\n#### **IV. DOCUMENTS TO BE PRODUCED**\n\n1. All Documents related to any account held by, controlled by, on behalf of, or otherwise related to any of the 2004 Discovery Targets, including any and all account statements, authorizations, power of attorney, trusts, instructions or forms, copies of cancelled checks, correspondence, and wire transfers and related correspondence and instructions.\n\n2. All Documents related to any funds, securities, property, or assets belonging to, held by, controlled by, on behalf of, or otherwise related to any of the 2004 Discovery Targets,\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 832 of 1063\n\nincluding any and all account statements, authorizations, powers of attorney, trusts, instructions or forms, copies of cancelled checks, correspondence, and wire transfers and related correspondence and instructions.\n\n3. All Documents related to any business, commerce or financial transactions, including but not limited to any loan, line of credit, bailment, deposit, swap, securities transactions, mortgage, or ISDA, with any of the 2004 Discovery Targets, including any and all account statements, authorizations, powers of attorney, trusts, instructions or forms, copies of cancelled checks, correspondence, and wire transfers and related correspondence and instructions.\n\n4. All Documents relating to any wire transfer activity relating to the 2004 Discovery Targets, regardless of the existence of any accounts, including but not limited to all wire transfer receipts, account numbers, balances, authorizations, identification information related to the parties to the transfer, correspondence, instructions, or other records.\n\n5. All Documents related to any correspondence and communications between you and the 2004 Discovery Targets.\n\n6. All Documents related to any account with any 2004 Discovery Target relating to opening of the account, authorized users of the account and maintenance of the account.\n\n7. All Documents related to any anti-money laundering, know-your-customer, or other compliance activity relating to any of the 2004 Discovery Targets, including but not limited to any information provided by any of the 2004 Discovery Targets, or learned by You.\n\n8. All Documents relating to any communications with any regulator from any country, including but not limited to the Bank of England, the United States Federal Reserve, the S.E.C., the CFTC, FINRA, China Securities Regulatory Commission, People's Bank of China,\n\nHong Kong Securities and Futures Commission, and the Hong Kong Monetary Authority relating to any of the 2004 Discovery Targets.\n\n# Exhibit C-46\n\n#### B2540 (Form 2540 – Subpoena for Rule 2004 Examination) (12/15) Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 835 of\n\n1063\n\nUNITED STATES BANKRUPTCY COURT\n\n**District of Connecticut**\n\nIn re HO WAN KWOK, *et al*.,\n\n<sup>1</sup> Case No. 22-50073 (JAM) Debtor Chapter 11\n\n(Jointly Administered)\n\n# **SUBPOENA FOR RULE 2004 EXAMINATION**\n\nTo: **Marcum LLP**\n\n(*Name of person to whom the subpoena is directed*)\n\n*Testimony:* **YOU ARE COMMANDED** to appear at the time, date, and place set forth below to testify at an examination under Rule 2004, Federal Rules of Bankruptcy Procedure. A copy of the court order authorizing the examination is attached.\n\n| PLACE                    | DATE AND TIME |\n|--------------------------|---------------|\n| Paul Hastings LLP        |               |\n| 200 Park Avenue          | [TBD]         |\n| New York, New York 10166 |               |\n|                          |               |\n\nThe examination will be recorded by this method: **Court reporter/stenographer**\n\n*Production:* You, or your representatives, must also bring with you to the examination the following documents, electronically stored information, or objects, and must permit inspection, copying, testing, or sampling of the material:\n\n#### **See Requests for Production of Documents, attached hereto.**\n\nThe following provisions of Fed. R. Civ. P. 45, made applicable in bankruptcy cases by Fed. R. Bankr. P. 9016, are attached – Rule 45(c), relating to the place of compliance; Rule 45(d), relating to your protection as a person subject to a subpoena; and Rule 45(e) and 45(g), relating to your duty to respond to this subpoena and the potential consequences of not doing so.\n\nDate: **March , 2023**\n\nCLERK OF COURT\n\nOR\n\n*Signature of Clerk or Deputy Clerk Attorney's signature*\n\nThe name, address, email address, and telephone number of the attorney representing Luc A. Despins, Chapter 11 Trustee, who issues or requests this subpoena, are:\n\n**Douglas S. Skalka, Esq.; Neubert, Pepe & Monteith, P.C.; 195 Church Street, New Haven, Connecticut 06510 dskalka@npmlaw.com; (203) 821-2000**\n\n**Notice to the person who issues or requests this subpoena**\n\nIf this subpoena commands the production of documents, electronically stored information, or tangible things, or the inspection of premises before trial, a notice and a copy of this subpoena must be served on each party before it is served on the person to whom it is directed. Fed. R. Civ. P. 45(a)(4).\n\nSoftware Copyright (c) 1996-2022 Best Case, LLC - www.bestcase.com Best Case Bankruptcy 1 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\n#### **PROOF OF SERVICE**\n\n**(This section should not be filed with the court unless required by Fed. R. Civ. P. 45.)**\n\nI received this subpoena for (*name of individual and title, if any*): on (*date*) .\n\nI served the subpoena by delivering a copy to the named person as follows:\n\non *(date)* ; or\n\nI returned the subpoena unexecuted because:\n\nUnless the subpoena was issued on behalf of the United States, or one of its officers or agents, I have also tendered to the witness the fees for one day's attendance, and the mileage allowed by law, in the amount of \\$ .\n\nMy fees are \\$ for travel and \\$ for services, for a total of \\$ .\n\nI declare under penalty of perjury that this information is true and correct.\n\nDate:\n\n*Server's signature*\n\n*Printed name and title*\n\n*Server's address*\n\nAdditional information concerning attempted service, etc.:\n\n#### **Federal Rule of Civil Procedure 45(c), (d), (e), and (g) (Effective 12/1/13) (made applicable in bankruptcy cases by Rule 9016, Federal Rules of Bankruptcy Procedure)**\n\n#### **(c) Place of compliance.**\n\n*(1) For a Trial, Hearing, or Deposition.* A subpoena may command a person to attend a trial, hearing, or deposition only as follows:\n\n(A) within 100 miles of where the person resides, is employed, or regularly transacts business in person; or\n\n(B) within the state where the person resides, is employed, or regularly transacts business in person, if the person\n\n(i) is a party or a party's officer; or\n\n(ii) is commanded to attend a trial and would not incur substantial expense.\n\n*(2) For Other Discovery.* A subpoena may command:\n\n(A) production of documents, or electronically stored information, or things at a place within 100 miles of where the person resides, is employed, or regularly transacts business in person; and\n\n(B) inspection of premises, at the premises to be inspected.\n\n#### **(d) Protecting a Person Subject to a Subpoena; Enforcement.**\n\n*(1) Avoiding Undue Burden or Expense; Sanctions.* A party or attorney responsible for issuing and serving a subpoena must take reasonable steps to avoid imposing undue burden or expense on a person subject to the subpoena. The court for the district where compliance is required must enforce this duty and impose an appropriate sanction which may include lost earnings and reasonable attorney's fees — on a party or attorney who fails to comply.\n\n#### *(2) Command to Produce Materials or Permit Inspection.*\n\n*(A) Appearance Not Required.* A person commanded to produce documents, electronically stored information, or tangible things, or to permit the inspection of premises, need not appear in person at the place of production or inspection unless also commanded to appear for a deposition, hearing, or trial.\n\n*(B) Objections.* A person commanded to produce documents or tangible things or to permit inspection may serve on the party or attorney designated in the subpoena a written objection to inspecting, copying, testing or sampling any or all of the materials or to inspecting the premises — or to producing electronically stored information in the form or forms requested. The objection must be served before the earlier of the time specified for compliance or 14 days after the subpoena is served. If an objection is made, the following rules apply:\n\n(i) At any time, on notice to the commanded person, the serving party may move the court for the district where compliance is required for an order compelling production or inspection.\n\n(ii) These acts may be required only as directed in the order, and the order must protect a person who is neither a party nor a party's officer from significant expense resulting from compliance.\n\n#### *(3) Quashing or Modifying a Subpoena.*\n\n*(A) When Required.* On timely motion, the court for the district where compliance is required must quash or modify a subpoena that:\n\n(i) fails to allow a reasonable time to comply;\n\n(ii) requires a person to comply beyond the geographical limits specified in Rule 45(c);\n\n(iii) requires disclosure of privileged or other protected matter, if no exception or waiver applies; or\n\n(iv) subjects a person to undue burden.\n\n*(B) When Permitted.* To protect a person subject to or affected by a subpoena, the court for the district where compliance is required may, on motion, quash or modify the subpoena if it requires:\n\n(i) disclosing a trade secret or other confidential research, development, or commercial information; or\n\n(ii) disclosing an unretained expert's opinion or information that does not describe specific occurrences in dispute and results from the expert's study that was not requested by a party.\n\n(C) *Specifying Conditions as an Alternative.* In the circumstances described in Rule 45(d)(3)(B), the court may, instead of quashing or modifying a subpoena, order appearance or production under specified conditions if the serving party:\n\n(i) shows a substantial need for the testimony or material that cannot be otherwise met without undue hardship; and\n\n(ii) ensures that the subpoenaed person will be reasonably compensated.\n\n#### **(e) Duties in Responding to a Subpoena.**\n\n*(1) Producing Documents or Electronically Stored Information.* These procedures apply to producing documents or electronically stored information:\n\n*(A) Documents.* A person responding to a subpoena to produce documents must produce them as they are kept in the ordinary course of business or must organize and label them to correspond to the categories in the demand.\n\n*(B) Form for Producing Electronically Stored Information Not Specified.* If a subpoena does not specify a form for producing electronically stored information, the person responding must produce it in a form or forms in which it is ordinarily maintained or in a reasonably usable form or forms.\n\n*(C) Electronically Stored Information Produced in Only One Form.* The person responding need not produce the same electronically stored information in more than one form.\n\n*(D) Inaccessible Electronically Stored Information.* The person responding need not provide discovery of electronically stored information from sources that the person identifies as not reasonably accessible because of undue burden or cost. On motion to compel discovery or for a protective order, the person responding must show that the information is not reasonably accessible because of undue burden or cost. If that showing is made, the court may nonetheless order discovery from such sources if the requesting party shows good cause, considering the limitations of Rule 26(b)(2)(C). The court may specify conditions for the discovery.\n\n#### *(2) Claiming Privilege or Protection.*\n\n*(A) Information Withheld.* A person withholding subpoenaed information under a claim that it is privileged or subject to protection as trial-preparation material must: (i) expressly make the claim; and\n\n(ii) describe the nature of the withheld documents, communications, or tangible things in a manner that, without revealing information itself privileged or protected, will enable the parties to assess the claim.\n\n*(B) Information Produced.* If information produced in response to a subpoena is subject to a claim of privilege or of protection as trial-preparation material, the person making the claim may notify any party that received the information of the claim and the basis for it. After being notified, a party must promptly return, sequester, or destroy the specified information and any copies it has; must not use or disclose the information until the claim is resolved; must take reasonable steps to retrieve the information if the party disclosed it before being notified; and may promptly present the information under seal to the court for the district where compliance is required for a determination of the claim. The person who produced the information must preserve the information until the claim is resolved.\n\n**(g) Contempt.** The court for the district where compliance is required – and also, after a motion is transferred, the issuing court – may hold in contempt a person who, having been served, fails without adequate excuse to obey the subpoena or an order related to it.\n\nFor access to subpoena materials, see Fed.R.Civ.P.45(a) Committee Note (2013)\n\n…\n\n## **Request for Production of Documents**\n\n## **I. INSTRUCTIONS**\n\n1. Unless otherwise indicated, the requests for documents set forth below, (the \"Requests,\" and each, a \"Request\"), must be responded to separately and specifically. Each Request shall be answered fully unless it is in good faith objected to, in which event the reason for Your objection shall be stated in detail, as set forth below. If an objection pertains only to a portion of a Request, or a word, phrase or clause contained within it, You are required to state Your objection to that portion only and to respond to the remainder of the Requests.\n\n2. Electronically stored information must be produced in accordance with the\n\nfollowing instructions:\n\n- a. Images. Black and white images must be 300 DPI Group IV single-page TIFF files. Color images must be produced in JPEG format. File names cannot contain embedded spaces or special characters (including the comma). Folder names cannot contain embedded spaces or special characters (including the comma). All TIFF image files must have a unique file name, i.e. Bates number. Images must be endorsed with sequential Bates numbers in the lower right corner of each image. The number of TIFF files per folder should not exceed 1000 files. Excel spreadsheets should have a placeholder image named by the Bates number of the file.\n- b. Image Load File\n\t- a. Concordance® Data File. The data file (.DAT) contains all of the fielded information that will be loaded into the Concordance® database. The first line of the .DAT file must be a header row identifying the field names. The .DAT file must use the following Concordance® default delimiters: Comma ASCII character (020) Quote þ ASCII character (254). Date fields should be provided in the format: mm/dd/yyyy. Date and time fields must be two separate fields. If documents includes imaged emails and attachments, the attachment fields must be included to preserve the parent/child relationship between an email and its attachments. An OCRPATH field must be included to provide the file path and name of the extracted text file on the produced storage media. The text file must be named after the FIRSTBATES. Do not include the text in the .DAT file. For Documents with native files, a LINK field must be included to provide the file path and\n\nname of the native file. The native file must be named after the FIRSTBATES.\n\n- b. Concordance Image® OR Opticon Cross-Reference File. The image crossreference file (.LOG or .OPT) links the images to the database records. It should be a comma-delimited file consisting of seven fields per line with a line in the cross-reference file for every image in the database with the following format: ImageID,VolumeLabel,ImageFilePath,DocumentBreak,FolderBreak,Box Break,PageCoun.\n- c. Document Text. Text must be produced as separate text files, not as fields within the .DAT file. The full path to the text file (OCRPATH) should be included in the .DAT file. It is recommended document level ANSI text files, named per the FIRSTBATES/Image Key. Extracted text files must be in a separate folder, and the number of text files per folder should not exceed 1,000 files. There should be no special characters (including commas in the folder names). Text files must be provided on a document level.\n- d. Native Production for Certain File Types. File types that reasonably require viewing in their native format for a full understanding of their content and meaning must be produced in native format. These include, but are not limited to, spreadsheets, spreadsheet-like files (Microsoft Excel, comma separated values, tab separated values, etc.), Microsoft PowerPoint or other special presentation files, database files, and audio/visual files. Provide an image of a Bates numbered slip sheet indicating the presence of a native file, and include the path to the native as a field in the .dat file. Name the produced native file with the Bates number corresponding to the slip sheet for the file. Group native files within incrementally named \"NATIVE\" directories, separate from images directories.\n- e. De-duplication. Produce a single copy of each electronic document for which exact duplicates exist. For email messages, consolidate duplicates based on MD5 hash generated from the BCC, Body, CC, From, IntMsgID, To, and Attach properties. For email attachments and standalone electronic files, consolidate duplicates based on MD5 hash of the entire file.\n- f. Metadata. Produce extracted metadata for each document in the form of a Concordance compliant load file (.dat). The first line of the .DAT file must be a header row identifying the field names. The .DAT file must use the following Concordance default delimiters: Comma , ASCII character (020) Quote þ ASCII character (254)\n\nDate fields should be provided in the format: mm/dd/yyyy. Date and time fields must be two separate fields. Required metadata listed below:\n\n# Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 840 of 1063\n\n| Field Name   | Sample Data              | Description                                      |\n|--------------|--------------------------|--------------------------------------------------|\n| FIRSTBATES   | EDC0000001               | First Bates number of native file document/email |\n| LASTBATES    | EDC0000001               | Last Bates number of native file document/email  |\n|              |                          | **The LASTBATES field should be populated        |\n|              |                          | for single page                                  |\n| ATTACHRANGE  | EDC0000001<br>-          | Bates number of the first page of the parent     |\n|              | EDC0000015               | document to the Bates number of the last page of |\n|              |                          | the last attachment \"child\" document             |\n| BEGATTACH    | EDC0000001               | First Bates number of attachment range           |\n| ENDATTACH    | EDC0000015               | Last Bates number of attachment range            |\n| CUSTODIAN    | Smith, John              | Email: Mailbox where the email resided           |\n|              |                          | Native: Name of the individual or department     |\n|              |                          | from whose files the document<br>originated      |\n| FROM         | John Smith               | Email: Sender                                    |\n|              |                          | Native: Author(s) of document                    |\n|              |                          | **semi-colon should be used to separate          |\n|              |                          | multiple entries                                 |\n| TO           | Coffman, Janice; LeeW    | Recipient(s)                                     |\n|              | [mailto:LeeW@MSN.com]    | **semi-colon should be used to separate multiple |\n|              |                          | entries                                          |\n| CC           | Frank Thompson [mailto:  | Carbon copy recipient(s)                         |\n|              | frank_Thompson@cdt.com]  | **semi-colon should be used to separate          |\n|              |                          | multiple entries                                 |\n| BCC          | John Cain                | Blind carbon copy recipient(s)                   |\n|              |                          | **semi-colon should be used to separate          |\n|              |                          | multiple entries                                 |\n| SUBJECT      | Board Meeting Minutes    | Email: Subject line of the email Native: Title   |\n|              |                          | of document (if available)                       |\n| FILE_NAME    | BoardMeetingMinutes.docx | Native: Name of the original native file,        |\n|              |                          | including extension                              |\n| DATE_SENT    | 10/12/2010               | Email: Date the email was sent                   |\n|              |                          | Native: (empty)                                  |\n| TIME_SENT/   | 07:05 PM GMT             | Email: Time the email was sent/ Time zone in     |\n| TIME_ZONE    |                          | which the emails were standardized               |\n| TIME_ZONE    | GMT                      | The<br>time zone in which<br>the emails<br>were  |\n|              |                          | standardized during conversion.                  |\n| LINK         |  EDC0000001.msg   | Hyperlink to the email or native file document   |\n|              |                          | **The linked file must be named per the          |\n|              |                          | FIRSTBATES number                                |\n| FILE_EXTEN   | MSG                      | The file type extension                          |\n|              |                          | representing                                     |\n|              |                          | the Email or                                     |\n| AUTHOR       | John Smith               | Email: (empty)                                   |\n|              |                          | Native: Author of the document                   |\n| DATE_CREATED | 10/10/2010               | Email: (empty)                                   |\n|              |                          | Native: Date the document was created            |\n|              |                          |                                                  |\n\n# Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 841 of 1063\n\n| TIME_CREATED | 10:25 AM                  | Email: (empty)                                  |\n|--------------|---------------------------|-------------------------------------------------|\n|              |                           | Native: Time the document was created           |\n|              |                           | **This data must be a separate field and cannot |\n|              |                           | be combined with the DATE_CREATED field         |\n| DATE_MOD     | 10/12/2010                | Email: (empty)                                  |\n|              |                           | Native: Date the document was last modified     |\n| TIME_MOD     | 07:00 PM                  | Email: (empty)                                  |\n|              |                           | Native: Time the document was last modified     |\n|              |                           | **This data must be a separate field and cannot |\n|              |                           | be combined with the DATE_MOD field             |\n| DATE_ACCESSD | 10/12/2010                | Email: (empty)                                  |\n|              |                           | Native: Date the document was last accessed     |\n| TIME_ACCESSD | 07:00 PM                  | Email: (empty)                                  |\n|              |                           | Native: Time the document was last accessed     |\n|              |                           | **This data must be a separate field and cannot |\n|              |                           | be combined with the DATE_ACCESSD field         |\n| FILE_SIZE    | 5,952                     | Size of native file<br>document/email in KB     |\n| PGCOUNT      | 1                         | Number of pages in native file document/email   |\n| PATH         |   | Email: (empty)                                  |\n|              | Agenda.doc                | Native: Path where native file document was     |\n|              |                           | stored including original file name.            |\n| INTFILEPATH  | Personal Folders\\Deleted  | Email: original location of email including     |\n|              | Items\\Board Meeting       | original file name.                             |\n|              | Minutes.msg               | Native: (empty)                                 |\n| INTMSGID     | <000805c2c71b\\$75977050\\$ | Email: Unique Message ID Native: (empty)        |\n|              | cb8306d1@MSN>             |                                                 |\n| MD5HASH      | d131dd02c5e6eec4693d9a0   | MD5 Hash value of the document.                 |\n|              | 698aff95c                 |                                                 |\n|              | 2fcab58712467eab4004583e  |                                                 |\n|              | b8fb7f89                  |                                                 |\n| OCRPATH      | TEXT/001/EDC0000001.txt   | Path to extracted text of the native file       |\n\n3. Each Request operates and should be construed independently and, unless otherwise indicated, no Request limits the scope of any other Request.\n\n4. All Documents are to be produced as kept in the usual course of business or are to be organized and labeled to correspond with the categories in these Requests.\n\n5. Each Request contained herein extends to all Documents: (a) in Your possession, custody, or control; or (b) in the possession, custody, or control of anyone acting on Your behalf,\n\n#### Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 842 of 1063\n\nincluding Your counsel or other representatives and advisors. Each Document shall be produced in its entirety.\n\n6. If You are requested to produce a Document that is no longer in Your possession, custody, or control, then Your response must (a) describe in detail the nature of the document and its contents; (b) identify the person(s) who prepared or authored the Document (and, if applicable, the Person(s) to whom the Document was sent); (c) identify the date on which the document was prepared or created; (d) state whether such Document (i) is missing or lost, (ii) has been destroyed, (iii) has been transferred, voluntarily or involuntarily, to others, or (iv) was otherwise disposed of; (e) state the reason for, and the facts and circumstances surrounding, such disposition; (f) identify the Persons who authorized such disposition; (g) identify the date or approximate date of such disposition; (h) state when the Document was most recently in Your possession, custody or control; and (i) identify the Person, if any, presently in possession, custody, or control of such Document.\n\n7. If You are requested to produce a Document that has been destroyed, then Your response must state, in addition to the information required by the preceding Instruction: (a) the reason for the Document's destruction; (b) the identity of the Person who destroyed the Document; and (c) the identity of the Person who directed that the Document be destroyed.\n\n8. If You claim that a requested Document is privileged or attorney work-product, then Your response must: (a) state (i) a description of the Document adequate to support Your contention that the Document is privileged, (ii) the title of the Document, (iii) the date of the Document, (iv) the author of the Document, (v) the addressee of the Document, (vi) the identity of each Person who received or saw the original or any draft, copy, or reproduction of the Document, (vii) whether the Document itself, or any information contained or referred to in the Document is in the possession, custody, or control of any other Persons, and if so, the identity of\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 843 of 1063\n\nsuch Persons, as well as a statement addressing how the information came into their possession, (viii) the claim of privilege under which the Document is withheld, and (ix) all of the circumstances upon which You will rely to support such claim of privilege; and (b) produce a privilege log containing all of the information requested in Part (a) of this Instruction for each Document withheld on the basis of a claim of privilege in accordance with D. Conn. L. Civ. R. 26(e). For any part of a Document Request as to which a claim of privilege or work product is not made, responsive documents should be provided in full.\n\n9. If a portion of an otherwise responsive Document contains information subject to a claim of privilege, only that portion of the Document subject to the claim of privilege shall be deleted or redacted from the Document following the instructions above, and the rest shall be produced.\n\n10. The Requests are continuing in nature. You are hereby instructed to (a) supplement or correct any responses later learned to be incomplete or incorrect immediately upon learning that a prior response was incomplete or incorrect; and (b) produce any additional Documents that are called for under the\n\n11. If a Document is in a language other than English, You should provide that Document. If a Document is in a language other than English, and an English translation exists, You should provide both Documents.\n\n12. All references to Entities includes all affiliates thereof.\n\n13. All references to individual names include all alternative names, aliased, or nicknames.\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 844 of 1063\n\n14. Unless otherwise expressly indicated, the period of time covered by the Document Requests is the period from February 5, 2012 to the date responses to the Document Requests are due.\n\n#### **II. RULES OF CONSTRUCTION**\n\n15. The use of (a) any singular noun shall be construed to include the plural, and vice versa, and (b) a verb in any tense shall be construed as the use of the verb in all other tenses.\n\n16. The terms (a) \"and\" and \"or\" shall be construed either conjunctively or disjunctively as necessary to bring within the scope of any request all responses that might otherwise be construed to be outside of its scope, and (b) \"each\" and \"any\" shall be deemed to include and encompass the words \"every\" and \"all.\"\n\n#### **III. DEFINITIONS**\n\nThe definitions supplied by D. Conn. L. Civ. R. 26(c) and the rules of construction supplied by D. Conn. L. Civ. R. 26(d), as incorporated by D. Conn. Bankr. L.R. 2004-1(a), shall apply to the Document Requests. In addition, the following terms used in these Document Requests shall have the following meanings:\n\n1. \"You\" or \"Your\" or \"Yourself\" means and refers to Marcum LLP, together with any of its employees, agents, counsel, advisors, or anyone acting on its behalf.\n\n2. \"Debtor\" means Ho Wan Kwok (a/k/a Miles Kwok, Miles Guo, Guo Wengui, Guo Haoyun, 郭文贵, or any other alias), together with his employees, agents, counsel, advisors, or anyone acting on his behalf.\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 845 of 1063\n\n3. \"Debtor's Son\" means Qiang Guo (a/k/a Mileson Kwok, 郭强, or any other alias), together with his employees, agents, counsel, advisors, or anyone acting on his behalf.\n\n4. \"Debtor's Daughter\" means Mei Guo (a/k/a Mei Gui, 郭美, or any other alias), together with her employees, agents, counsel, advisors, or anyone acting on her behalf.\n\n5. \"Debtor's Purported Wife\" means Hing Chi Ngok (a/k/a Hing Chi Ng, Yue Qingzhi, 岳庆芝, or any other alias), together with her employees, agents, counsel, advisors, or anyone acting on her behalf.\n\n6. \"Debtor's Family\" means, collectively, the Debtor, the Debtor's Son, the Debtor's Daughter, and the Debtor's Purported Wife, and any other familial relation to the Debtor.\n\n7. \"Associated Individuals\" means, individually and collectively, all individuals that (1) hold, control, have custody over, or discretion over assets owned, controlled, or enjoyed by the Debtor or the Debtor's Family; or (2) have been employees, directors, or otherwise are affiliated with one or more Associated Entities, together with the respective employees, agents, counsel, advisors, or anyone acting on behalf of any of the foregoing. Such Associated Individuals shall include, but are not limited to: Daniel Podhaskie, Jason Miller, Steve Bannon, Karin Maistrello, Melissa Francis, Anthony DiBattista, William Gertz, Arethusa Forsyth, Glenn Mellor, Jennifer Mercurio, Eduardo Eurnekian, Wencong Wang, Han Chunguang (a/k/a 韩春光), Qu Guojiao (a/k/a Qu Guo Jiao, 屈国姣), Guo Lijie (a/k/a 郭丽杰), Zhang Wei (a/k/a 张伟\\*), Lihong Wei Lafrenz (a/k/a Sara Wei, 魏丽红), Hao Haidong (a/k/a 郝海东), Ross Heinemeyer, Max Krasner, Kyle Bass, Melissa Mendez, Ya Li (a/k/a 李娅), Dinggang Wang (a/k/a 王定刚), An Hong (a/k/a 安红), Yvette Wang (a/k/a Yanping Wang, Yan Ping Wang, 王雁平), Fiona Yu, Je Kin Ming\n\n#### Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 846 of 1063\n\n(a/k/a William Je, Yu Jianming, 余建明), Yaz Qingua, and Lao Jiang (a/k/a Jiang Yunfu, Jiang Yunfu Be, 姜云浮).\n\n8. \"Associated Entities\" means, individually and collectively, all organizations or Entities of any type that (1) have been owned, controlled, or invested in by the Debtor or the Debtor's Family; or (2) have an interest, whether directly or indirectly, in any assets owned, controlled, or enjoyed by the Debtor or the Debtor's Family, together with the respective employees, agents, counsel, advisors, or anyone acting on behalf of any of the foregoing. Such Associated Entities shall include, but are not limited to: 7 Nod Hill LLC, AAGV Limited, ACA Investment Management Limited, ACA Capital Group Limited, Ace Decade Holdings Limited, AI Group Holdings Inc., Alfa Global Ventures Limited, Alfonso Global Limited, Allied Capital Global Limited, Alpine Fiduciaries SA, Anton Development Limited, Assets Sino Limited, Auspicious Coast Limited, Beijing Pangu Investment Co., Beijing Pangu Investment Co. Ltd., Beijing Pangu Investment Inc., Beijing Zenith Holdings Company Limited, Booming Sail New York LLC, Bravo Luck Limited, BSA Strategic Fund I, China Golden Spring (Hong Kong) Limited, Chuang Xin Limited, Crane Advisory Group LLC, Creative Apex Investments Limited, Crystal Breeze Investments Limited, Dawn State Limited, Eastern Profit Corporation Limited, Elite Well Global Limited, Empire Growth Holdings, Freedom Media Ventures Ltd., G Club Operations LLC, G Fashion LLC, G News LLC, GETTR USA, Genever Holdings Corporation, Genever Holdings LLC, Gfashion Media Group Inc., GFNY, Inc., Globalist International Limited, GNews Media Group Inc., Golden Spring (New York) Ltd., Greenwich Land LLC, Guo Media, GTV Media Group, Inc., Hamilton Capital Holdings Inc., HCHK Property Management, Inc., HCHK Technologies, Inc., Head Win Group Limited, Henan Yuda, Himalaya Embassy, Himalaya Exchange, Himalaya Federal Reserve, Himalaya Investment LLC, Himalaya International,\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 847 of 1063\n\nHimalaya New World Inc., Himalaya Supervisory Organization, Himalaya Ventures LLC, HK International Funds Investments (USA) Limited LLC, Hong Kong International Funds Investments Limited, Hudson Diamond Holding, Infinite Increase Limited, Infinitum Developments Limited, Infinity Treasury Management Inc., Insight Phoenix Fund, Lamp Capital LLC, Leading Shine Limited, Leading Shine NY Limited, Lexington Property and Staffing, Long Gate Limited, Maywind Trading LLC, MOS Himalaya LLC, Next Tycoon Investments Limited, New Federal State of China (a/k/a NFSC), Noble Fame Global Limited, Rosy Acme Ventures Limited, Rule of Law Foundation III, Inc., Rule of Law Foundation IV, Inc., Rule of Law Fund, Rule of Law Society, Rule of Law Society IV, Inc., G-Translators PTY LTD, Saraca Media Group, Inc., Shiny Ace Ltd., Shiny Times Holdings Ltd., Spirit Charter Investment Limited, Stevenson, Wong & Co., Voice of Guo Media, Inc., Well Origin Ltd., World Century Limited, Worldwide Opportunity Holdings Limited, Whitecroft Shore Limited, and ZIBA Limited.\n\n9. \"Including\" or any variant thereof means \"including without limitation.\"\n\n10. \"And\" and \"or\" mean \"and/or,\" and shall be construed both conjunctively as well as disjunctively in order to maximize their scope.\n\n11. \"Any\" and \"all\" and \"each\" mean \"each and every.\"\n\n12. \"Each\" and \"every\" mean \"each and every.\"\n\n13. \"Third Party\" means a Person or Entity other than Yourself.\n\n14. \"Transfer\" shall have the meaning given to it by section 101(54) of the Bankruptcy Code.\n\n15. \"Document\" means any information or thing within the scope of Fed. R. Civ. P. 34, and includes, without limitation, each and every written, recorded, or graphic matter of any kind,\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 848 of 1063\n\ntype, nature, or description that is or has been in Your Possession, Custody or Control, including all printed and electronic copies of electronic mail, computer files maintained in electronic form, correspondence, memoranda, tapes, stenographic or handwritten notes, written forms of any kind, charts, blueprints, drawings, sketches, graphs, plans, articles, specifications, diaries, letters, telegrams, photographs, minutes, contracts, agreements, surveys, computer printouts, data compilations of any kind, telexes, facsimiles, emails, text messages, instant messages, voice messages, invoices, order forms, checks, drafts, statements, credit memos, reports, position reports, summaries, indices, books, ledgers, notebooks, schedules, transparencies, recordings, catalogs, advertisements, promotional materials, films, video tapes, audio tapes, CDs, computer disks, brochures, pamphlets, punch-cards, time-slips, Tweets, social media posts, or any written or recorded materials of any other kind, and all meta-data thereof, however stored (whether in tangible or electronic form), recorded, produced, or reproduced, and also including but not limited to, drafts or copies of any of the foregoing that contain any notes, comments, or markings of any kind not found on the original documents or that are otherwise not identical to the original documents.\n\n16. \"Person(s)\" means an individual, corporation, proprietorship, partnership, association, or any other Entity. \"Person\" also includes any agent, representatives, or expert, including but not limiting to, attorneys or financial advisors.\n\n17. \"Entity\" means any natural Person, corporation, partnership, subsidiary, sole proprietorship, firm, board, joint venture, association, agency, authority, commission or other business entity or juristic Person, as well as any affiliate, agent, parent including but not limited to counsel, financial advisors, or any other representative.\n\n#### Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 849 of 1063\n\n18. \"Regarding\" means concerning, describing, comprising, referring to, related to, supporting, favoring, opposing, bolstering, detracting from, located in, considered in connection with, bearing on, evidencing, indicating, reporting on, recording, alluding to, responding to, connected with, commenting on, in respect of, about, in relation to, discussing, showing, describing, reflecting, analyzing constituting, and being.\n\n19. \"Relating to,\" \"relate(s) to\" or \"related to,\" when referring to any given subject matter, means, without limitation, any document that constitutes, comprises, involves, contains, embodies, reflects, identifies, states, refers directly or indirectly to, or is in any way relevant to the particular subject matter identified.\n\n20. \"Communication(s)\" means, in the broadest possible sense, and without limitation, any transmittal of information or knowledge (in the form of facts, ideas, inquiries, or otherwise). Communication(s) further refers to all conversations, agreements, inquiries, or replies, whether in person, by telephone, in writing, or by means of electronic transmittal devices, and includes, but is not limited to, all correspondence, emails, recordings, transmittal slips, memoranda, telephone communications, voice messages, telegrams, telefaxes, telecopies, telexes, instant messages, chats, text messages, postings to a message board or group chat, social media posts, tweets, videos uploaded to any video platform, telephonic notes, or notes transmitted internally or with third parties.\n\n21. \"Asset(s)\" means any item of economic value that is subject to Possession, Custody, or Control. Asset includes all real and personal property, including but limited to, real estate, land, houses, apartments, condominiums, automobiles, yachts, boats, planes, jets, helicopters, cash, bank accounts, cryptocurrencies, securities, accounts receivables, inventory, and other tangible and intangible property.\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 850 of 1063\n\n#### **IV. DOCUMENTS TO BE PRODUCED**\n\n1. All Documents related to any income or Asset of the Debtor, the Debtor's estate, the Debtor's Family, or Associated Entity.\n\n2. All Documents related to any engagement letter with the Debtor, any member of the Debtor's Family, and/or any Associated Entity, including copy(ies) of such engagement letter(s).\n\n3. All Documents related to the payment of any retainer to You based upon your representation of the Debtor, the Debtor's Family, or an Associated Entity, including documents sufficient to identify the amount of the retainer and its source.\n\n4. All Documents related to any fees, payments, or monies received by You from or on behalf of the Debtor, the Debtor's Family, a Family Related Entity, or an Associated Entity held in escrow or in a client trust account.\n\n5. Documents sufficient to show the amount, date, and source of any payments made to You by or for the benefit of the Debtor, the Debtor's Family, or an Associated Entity.\n\n6. All Documents related to the Debtor's financial condition and obligations to his creditors, including without limitation all Documents related to any effort to avoid paying such obligations and All Documents related to this or any other actual or potential bankruptcy or similar insolvency proceeding.\n\n7. All Documents related to the Associated Entities, including but not limited to Documents related to their corporate structure, Assets, incorporation information, officers and directors, business purpose, and relationship to the Debtor, to any member of the Debtor's Family, or to any Associated Individual.\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 851 of 1063\n\n8. All Documents regarding any investment or business dealing made by, with, or on behalf of Debtor or the Debtor's Family, on the one hand, and an Associated Entity, on the other hand.\n\n9. All Documents related to any Entity that the Debtor, the Debtor's Estate, the Debtor's Family, or the Associated Entities hold any interest or investment in, including but not limited to the nature and value of that interest or investment; any proceeds or benefits from such Entity that the Debtor, the Debtor's Estate, the Debtor's Family, or the Associated Entities receive on account of such interest or investment; and all Documents relating to any financial reporting or data relating to such Entity, including but not limited to all books and records, financial statements or tax Documents.\n\n10. All Documents regarding the *Lady May*; the Sherry Netherland Hotel / Condominium; the residential property located in Greenwich, Connecticut, at 373 Taconic Rd.; the residential property located in Greenwich, Connecticut, at 33 Ferncliff Rd.; the residential property located in Wilton, Connecticut at 354 Nod Hill Rd.; and any financial interest that the Debtor or the Debtor's estate possesses in any Associated Entity.\n\n11. All Documents related to the purported Declaration of Trust and Agreement, dated February 17, 2015, entered into by the Debtor, as Trustee, Genever Holdings Corporation, and Genever Holdings LLC, in favor of Bravo Luck Limited, as beneficiary.\n\n12. All Documents related to any aircraft owned, controlled, or used by the Debtor, including without limitation the aircraft bearing tail number T7-GQM any other aircraft registered in San Marino, including without limitation copies of all registration documents and flight manifests showing flights taken by such aircraft and the individuals onboard such flights.\n\n#### Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 852 of 1063\n\n13. All Documents related to any investments or trading by the Debtor, the Debtor's Family, or an Associated Entity, in or around July 2020, or at any other time, in crude oil futures or any similar commodity, including without limitation Communications with Jiang Yunfu Be regarding any such investments or trading.\n\n14. All Communications between You and, either, the Debtor, the Debtor's Family, or any Associated Individual, agent, employee, or other individual acting on behalf of the Debtor, related to any Transfer, investment, or other transaction or business dealing relating to the Debtor, the Debtor's Estate, the Debtor's Family, or the Associated Entities.\n\n15. All Documents concerning any trust or similar instrument set up by, on behalf of, or for the benefit of Debtor, Debtor's Estate, Debtor's Family, or Associated Entities, including but not limited to Documents showing when the trust(s) was created, by whom it was created, to whose benefit it was created, and the corpus of the instrument.\n\n16. All Documents related to any sale, acquisition, disposition, purchase, investment, contribution, gift, extension of credit, loan, or Transfer involving the Debtor, the Debtor's Family, or any Associated Entity.\n\n17. All Documents related to any obligation, claim, liability, or debt associated with any legal dispute involving the Debtor, including but not limited to those relating to any litigation before any local, state, federal, or international body, whether an administrative body, court, panel, or alternative dispute resolution entity.\n\n18. All Documents related to any loans or extensions of credit, or applications for the same, to or from the Debtor, the Debtor's Estate, the Debtor's Family or any Associated Entity, including but not limited to (i) the terms of any such loans or extensions of credit, including their\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 853 of 1063\n\nterms of repayment, representations and warranties, and interest rate, and (ii) all evidence of payments of the loans.\n\n19. All Documents related to the Debtor's use of any Assets belonging to, controlled by, or whose complete or partial ownership is held by the Debtor's Family, an Associated Entity, or an Associated Individual.\n\n20. All Documents regarding any balance sheet, bank statement, account statement, financial statement, statement of account, wire transfer instructions and/or confirmation, proof of funds, certificate of deposit, certificate of holdings, investment portfolio summary, or similar document relating to the Debtor, the Debtor's Estate, the Debtor's Family, an Associated Entity, or an Associated Individual, including without limitation all Documents sufficient to show all Transfers to any of the foregoing.\n\n21. All Documents related to any pledges of Assets of any Associated Entity, including Bravo Luck Limited, to any other Entity.\n\nCase 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 854 of 1063\n\n# Exhibit C-47\n\n#### B2540 (Form 2540 – Subpoena for Rule 2004 Examination) (12/15) Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 855 of\n\n1063\n\nUNITED STATES BANKRUPTCY COURT\n\n**District of Connecticut**\n\nIn re HO WAN KWOK, *et al*.,\n\n<sup>1</sup> Case No. 22-50073 (JAM) Debtor Chapter 11\n\n(Jointly Administered)\n\n# **SUBPOENA FOR RULE 2004 EXAMINATION**\n\nTo: **Brent Petro Inc.**\n\n(*Name of person to whom the subpoena is directed*)\n\n*Testimony:* **YOU ARE COMMANDED** to appear at the time, date, and place set forth below to testify at an examination under Rule 2004, Federal Rules of Bankruptcy Procedure. A copy of the court order authorizing the examination is attached.\n\n| PLACE                    | DATE AND TIME |\n|--------------------------|---------------|\n| Paul Hastings LLP        |               |\n| 200 Park Avenue          | [TBD]         |\n| New York, New York 10166 |               |\n|                          |               |\n\nThe examination will be recorded by this method: **Court reporter/stenographer**\n\n*Production:* You, or your representatives, must also bring with you to the examination the following documents, electronically stored information, or objects, and must permit inspection, copying, testing, or sampling of the material:\n\n#### **See Requests for Production of Documents, attached hereto.**\n\nThe following provisions of Fed. R. Civ. P. 45, made applicable in bankruptcy cases by Fed. R. Bankr. P. 9016, are attached – Rule 45(c), relating to the place of compliance; Rule 45(d), relating to your protection as a person subject to a subpoena; and Rule 45(e) and 45(g), relating to your duty to respond to this subpoena and the potential consequences of not doing so.\n\nDate: **March , 2023**\n\nCLERK OF COURT\n\nOR\n\n*Signature of Clerk or Deputy Clerk Attorney's signature*\n\nThe name, address, email address, and telephone number of the attorney representing Luc A. Despins, Chapter 11 Trustee, who issues or requests this subpoena, are:\n\n**Douglas S. Skalka, Esq.; Neubert, Pepe & Monteith, P.C.; 195 Church Street, New Haven, Connecticut 06510 dskalka@npmlaw.com; (203) 821-2000**\n\n**Notice to the person who issues or requests this subpoena**\n\nIf this subpoena commands the production of documents, electronically stored information, or tangible things, or the inspection of premises before trial, a notice and a copy of this subpoena must be served on each party before it is served on the person to whom it is directed. Fed. R. Civ. P. 45(a)(4).\n\nSoftware Copyright (c) 1996-2022 Best Case, LLC - www.bestcase.com Best Case Bankruptcy 1 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\n#### **PROOF OF SERVICE**\n\n**(This section should not be filed with the court unless required by Fed. R. Civ. P. 45.)**\n\nI received this subpoena for (*name of individual and title, if any*): on (*date*) .\n\nI served the subpoena by delivering a copy to the named person as follows:\n\non *(date)* ; or\n\nI returned the subpoena unexecuted because:\n\nUnless the subpoena was issued on behalf of the United States, or one of its officers or agents, I have also tendered to the witness the fees for one day's attendance, and the mileage allowed by law, in the amount of \\$ .\n\nMy fees are \\$ for travel and \\$ for services, for a total of \\$ .\n\nI declare under penalty of perjury that this information is true and correct.\n\nDate:\n\n*Server's signature*\n\n*Printed name and title*\n\n*Server's address*\n\nAdditional information concerning attempted service, etc.:\n\n#### **Federal Rule of Civil Procedure 45(c), (d), (e), and (g) (Effective 12/1/13) (made applicable in bankruptcy cases by Rule 9016, Federal Rules of Bankruptcy Procedure)**\n\n#### **(c) Place of compliance.**\n\n*(1) For a Trial, Hearing, or Deposition.* A subpoena may command a person to attend a trial, hearing, or deposition only as follows:\n\n(A) within 100 miles of where the person resides, is employed, or regularly transacts business in person; or\n\n(B) within the state where the person resides, is employed, or regularly transacts business in person, if the person\n\n(i) is a party or a party's officer; or\n\n(ii) is commanded to attend a trial and would not incur substantial expense.\n\n*(2) For Other Discovery.* A subpoena may command:\n\n(A) production of documents, or electronically stored information, or things at a place within 100 miles of where the person resides, is employed, or regularly transacts business in person; and\n\n(B) inspection of premises, at the premises to be inspected.\n\n#### **(d) Protecting a Person Subject to a Subpoena; Enforcement.**\n\n*(1) Avoiding Undue Burden or Expense; Sanctions.* A party or attorney responsible for issuing and serving a subpoena must take reasonable steps to avoid imposing undue burden or expense on a person subject to the subpoena. The court for the district where compliance is required must enforce this duty and impose an appropriate sanction which may include lost earnings and reasonable attorney's fees — on a party or attorney who fails to comply.\n\n#### *(2) Command to Produce Materials or Permit Inspection.*\n\n*(A) Appearance Not Required.* A person commanded to produce documents, electronically stored information, or tangible things, or to permit the inspection of premises, need not appear in person at the place of production or inspection unless also commanded to appear for a deposition, hearing, or trial.\n\n*(B) Objections.* A person commanded to produce documents or tangible things or to permit inspection may serve on the party or attorney designated in the subpoena a written objection to inspecting, copying, testing or sampling any or all of the materials or to inspecting the premises — or to producing electronically stored information in the form or forms requested. The objection must be served before the earlier of the time specified for compliance or 14 days after the subpoena is served. If an objection is made, the following rules apply:\n\n(i) At any time, on notice to the commanded person, the serving party may move the court for the district where compliance is required for an order compelling production or inspection.\n\n(ii) These acts may be required only as directed in the order, and the order must protect a person who is neither a party nor a party's officer from significant expense resulting from compliance.\n\n#### *(3) Quashing or Modifying a Subpoena.*\n\n*(A) When Required.* On timely motion, the court for the district where compliance is required must quash or modify a subpoena that:\n\n(i) fails to allow a reasonable time to comply;\n\n(ii) requires a person to comply beyond the geographical limits specified in Rule 45(c);\n\n(iii) requires disclosure of privileged or other protected matter, if no exception or waiver applies; or\n\n(iv) subjects a person to undue burden.\n\n*(B) When Permitted.* To protect a person subject to or affected by a subpoena, the court for the district where compliance is required may, on motion, quash or modify the subpoena if it requires:\n\n(i) disclosing a trade secret or other confidential research, development, or commercial information; or\n\n(ii) disclosing an unretained expert's opinion or information that does not describe specific occurrences in dispute and results from the expert's study that was not requested by a party.\n\n(C) *Specifying Conditions as an Alternative.* In the circumstances described in Rule 45(d)(3)(B), the court may, instead of quashing or modifying a subpoena, order appearance or production under specified conditions if the serving party:\n\n(i) shows a substantial need for the testimony or material that cannot be otherwise met without undue hardship; and\n\n(ii) ensures that the subpoenaed person will be reasonably compensated.\n\n#### **(e) Duties in Responding to a Subpoena.**\n\n*(1) Producing Documents or Electronically Stored Information.* These procedures apply to producing documents or electronically stored information:\n\n*(A) Documents.* A person responding to a subpoena to produce documents must produce them as they are kept in the ordinary course of business or must organize and label them to correspond to the categories in the demand.\n\n*(B) Form for Producing Electronically Stored Information Not Specified.* If a subpoena does not specify a form for producing electronically stored information, the person responding must produce it in a form or forms in which it is ordinarily maintained or in a reasonably usable form or forms.\n\n*(C) Electronically Stored Information Produced in Only One Form.* The person responding need not produce the same electronically stored information in more than one form.\n\n*(D) Inaccessible Electronically Stored Information.* The person responding need not provide discovery of electronically stored information from sources that the person identifies as not reasonably accessible because of undue burden or cost. On motion to compel discovery or for a protective order, the person responding must show that the information is not reasonably accessible because of undue burden or cost. If that showing is made, the court may nonetheless order discovery from such sources if the requesting party shows good cause, considering the limitations of Rule 26(b)(2)(C). The court may specify conditions for the discovery.\n\n#### *(2) Claiming Privilege or Protection.*\n\n*(A) Information Withheld.* A person withholding subpoenaed information under a claim that it is privileged or subject to protection as trial-preparation material must: (i) expressly make the claim; and\n\n(ii) describe the nature of the withheld documents, communications, or tangible things in a manner that, without revealing information itself privileged or protected, will enable the parties to assess the claim.\n\n*(B) Information Produced.* If information produced in response to a subpoena is subject to a claim of privilege or of protection as trial-preparation material, the person making the claim may notify any party that received the information of the claim and the basis for it. After being notified, a party must promptly return, sequester, or destroy the specified information and any copies it has; must not use or disclose the information until the claim is resolved; must take reasonable steps to retrieve the information if the party disclosed it before being notified; and may promptly present the information under seal to the court for the district where compliance is required for a determination of the claim. The person who produced the information must preserve the information until the claim is resolved.\n\n**(g) Contempt.** The court for the district where compliance is required – and also, after a motion is transferred, the issuing court – may hold in contempt a person who, having been served, fails without adequate excuse to obey the subpoena or an order related to it.\n\nFor access to subpoena materials, see Fed.R.Civ.P.45(a) Committee Note (2013)\n\n…\n\n## **Requests for Production of Documents**\n\n## **I. INSTRUCTIONS**\n\n1. Unless otherwise indicated, the requests for documents set forth below, (the \"Requests,\" and each, a \"Request\"), must be responded to separately and specifically. Each Request shall be answered fully unless it is in good faith objected to, in which event the reason for Your objection shall be stated in detail, as set forth below. If an objection pertains only to a portion of a Request, or a word, phrase or clause contained within it, You are required to state Your objection to that portion only and to respond to the remainder of the Requests.\n\n2. Electronically stored information must be produced in accordance with the\n\nfollowing instructions:\n\n- a. Images. Black and white images must be 300 DPI Group IV single-page TIFF files. Color images must be produced in JPEG format. File names cannot contain embedded spaces or special characters (including the comma). Folder names cannot contain embedded spaces or special characters (including the comma). All TIFF image files must have a unique file name, i.e. Bates number. Images must be endorsed with sequential Bates numbers in the lower right corner of each image. The number of TIFF files per folder should not exceed 1000 files. Excel spreadsheets should have a placeholder image named by the Bates number of the file.\n- b. Image Load File\n\t- a. Concordance® Data File. The data file (.DAT) contains all of the fielded information that will be loaded into the Concordance® database. The first line of the .DAT file must be a header row identifying the field names. The .DAT file must use the following Concordance® default delimiters: Comma ASCII character (020) Quote þ ASCII character (254). Date fields should be provided in the format: mm/dd/yyyy. Date and time fields must be two separate fields. If documents includes imaged emails and attachments, the attachment fields must be included to preserve the parent/child relationship between an email and its attachments. An OCRPATH field must be included to provide the file path and name of the extracted text file on the produced storage media. The text file must be named after the FIRSTBATES. Do not include the text in the .DAT file. For Documents with native files, a LINK field must be included to provide the file path and\n\nname of the native file. The native file must be named after the FIRSTBATES.\n\n- b. Concordance Image® OR Opticon Cross-Reference File. The image crossreference file (.LOG or .OPT) links the images to the database records. It should be a comma-delimited file consisting of seven fields per line with a line in the cross-reference file for every image in the database with the following format: ImageID,VolumeLabel,ImageFilePath,DocumentBreak,FolderBreak,Box Break,PageCoun.\n- c. Document Text. Text must be produced as separate text files, not as fields within the .DAT file. The full path to the text file (OCRPATH) should be included in the .DAT file. It is recommended document level ANSI text files, named per the FIRSTBATES/Image Key. Extracted text files must be in a separate folder, and the number of text files per folder should not exceed 1,000 files. There should be no special characters (including commas in the folder names). Text files must be provided on a document level.\n- d. Native Production for Certain File Types. File types that reasonably require viewing in their native format for a full understanding of their content and meaning must be produced in native format. These include, but are not limited to, spreadsheets, spreadsheet-like files (Microsoft Excel, comma separated values, tab separated values, etc.), Microsoft PowerPoint or other special presentation files, database files, and audio/visual files. Provide an image of a Bates numbered slip sheet indicating the presence of a native file, and include the path to the native as a field in the .dat file. Name the produced native file with the Bates number corresponding to the slip sheet for the file. Group native files within incrementally named \"NATIVE\" directories, separate from images directories.\n- e. De-duplication. Produce a single copy of each electronic document for which exact duplicates exist. For email messages, consolidate duplicates based on MD5 hash generated from the BCC, Body, CC, From, IntMsgID, To, and Attach properties. For email attachments and standalone electronic files, consolidate duplicates based on MD5 hash of the entire file.\n- f. Metadata. Produce extracted metadata for each document in the form of a Concordance compliant load file (.dat). The first line of the .DAT file must be a header row identifying the field names. The .DAT file must use the following Concordance default delimiters: Comma , ASCII character (020) Quote þ ASCII character (254)\n\nDate fields should be provided in the format: mm/dd/yyyy. Date and time fields must be two separate fields. Required metadata listed below:\n\n# Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 860 of 1063\n\n| Field Name   | Sample Data              | Description                                      |\n|--------------|--------------------------|--------------------------------------------------|\n| FIRSTBATES   | EDC0000001               | First Bates number of native file document/email |\n| LASTBATES    | EDC0000001               | Last Bates number of native file document/email  |\n|              |                          | **The LASTBATES field should be populated        |\n|              |                          | for single page                                  |\n| ATTACHRANGE  | EDC0000001<br>-          | Bates number of the first page of the parent     |\n|              | EDC0000015               | document to the Bates number of the last page of |\n|              |                          | the last attachment \"child\" document             |\n| BEGATTACH    | EDC0000001               | First Bates number of attachment range           |\n| ENDATTACH    | EDC0000015               | Last Bates number of attachment range            |\n| CUSTODIAN    | Smith, John              | Email: Mailbox where the email resided           |\n|              |                          | Native: Name of the individual or department     |\n|              |                          | from whose files the document<br>originated      |\n| FROM         | John Smith               | Email: Sender                                    |\n|              |                          | Native: Author(s) of document                    |\n|              |                          | **semi-colon should be used to separate          |\n|              |                          | multiple entries                                 |\n| TO           | Coffman, Janice; LeeW    | Recipient(s)                                     |\n|              | [mailto:LeeW@MSN.com]    | **semi-colon should be used to separate multiple |\n|              |                          | entries                                          |\n| CC           | Frank Thompson [mailto:  | Carbon copy recipient(s)                         |\n|              | frank_Thompson@cdt.com]  | **semi-colon should be used to separate          |\n|              |                          | multiple entries                                 |\n| BCC          | John Cain                | Blind carbon copy recipient(s)                   |\n|              |                          | **semi-colon should be used to separate          |\n|              |                          | multiple entries                                 |\n| SUBJECT      | Board Meeting Minutes    | Email: Subject line of the email Native: Title   |\n|              |                          | of document (if available)                       |\n| FILE_NAME    | BoardMeetingMinutes.docx | Native: Name of the original native file,        |\n|              |                          | including extension                              |\n| DATE_SENT    | 10/12/2010               | Email: Date the email was sent                   |\n|              |                          | Native: (empty)                                  |\n| TIME_SENT/   | 07:05 PM GMT             | Email: Time the email was sent/ Time zone in     |\n| TIME_ZONE    |                          | which the emails were standardized               |\n| TIME_ZONE    | GMT                      | The<br>time zone in which<br>the emails<br>were  |\n|              |                          | standardized during conversion.                  |\n| LINK         |  EDC0000001.msg   | Hyperlink to the email or native file document   |\n|              |                          | **The linked file must be named per the          |\n|              |                          | FIRSTBATES number                                |\n| FILE_EXTEN   | MSG                      | The file type extension                          |\n|              |                          | representing                                     |\n|              |                          | the Email or                                     |\n| AUTHOR       | John Smith               | Email: (empty)                                   |\n|              |                          | Native: Author of the document                   |\n| DATE_CREATED | 10/10/2010               | Email: (empty)                                   |\n|              |                          | Native: Date the document was created            |\n\n# Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 861 of 1063\n\n| TIME_CREATED | 10:25 AM                  | Email: (empty)                                  |\n|--------------|---------------------------|-------------------------------------------------|\n|              |                           | Native: Time the document was created           |\n|              |                           | **This data must be a separate field and cannot |\n|              |                           | be combined with the DATE_CREATED field         |\n| DATE_MOD     | 10/12/2010                | Email: (empty)                                  |\n|              |                           | Native: Date the document was last modified     |\n| TIME_MOD     | 07:00 PM                  | Email: (empty)                                  |\n|              |                           | Native: Time the document was last modified     |\n|              |                           | **This data must be a separate field and cannot |\n|              |                           | be combined with the DATE_MOD field             |\n| DATE_ACCESSD | 10/12/2010                | Email: (empty)                                  |\n|              |                           | Native: Date the document was last accessed     |\n| TIME_ACCESSD | 07:00 PM                  | Email: (empty)                                  |\n|              |                           | Native: Time the document was last accessed     |\n|              |                           | **This data must be a separate field and cannot |\n|              |                           | be combined with the DATE_ACCESSD field         |\n| FILE_SIZE    | 5,952                     | Size of native file<br>document/email in KB     |\n| PGCOUNT      | 1                         | Number of pages in native file document/email   |\n| PATH         |   | Email: (empty)                                  |\n|              | Agenda.doc                | Native: Path where native file document was     |\n|              |                           | stored including original file name.            |\n| INTFILEPATH  | Personal Folders\\Deleted  | Email: original location of email including     |\n|              | Items\\Board Meeting       | original file name.                             |\n|              | Minutes.msg               | Native: (empty)                                 |\n| INTMSGID     | <000805c2c71b\\$75977050\\$ | Email: Unique Message ID Native: (empty)        |\n|              | cb8306d1@MSN>             |                                                 |\n| MD5HASH      | d131dd02c5e6eec4693d9a0   | MD5 Hash value of the document.                 |\n|              | 698aff95c                 |                                                 |\n|              | 2fcab58712467eab4004583e  |                                                 |\n|              | b8fb7f89                  |                                                 |\n| OCRPATH      | TEXT/001/EDC0000001.txt   | Path to extracted text of the native file       |\n\n3. Each Request operates and should be construed independently and, unless otherwise indicated, no Request limits the scope of any other Request.\n\n4. All Documents are to be produced as kept in the usual course of business or are to be organized and labeled to correspond with the categories in these Requests.\n\n5. Each Request contained herein extends to all Documents: (a) in Your possession, custody, or control; or (b) in the possession, custody, or control of anyone acting on Your behalf,\n\n#### Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 862 of 1063\n\nincluding Your counsel or other representatives and advisors. Each Document shall be produced in its entirety.\n\n6. If You are requested to produce a Document that is no longer in Your possession, custody, or control, then Your response must (a) describe in detail the nature of the document and its contents; (b) identify the person(s) who prepared or authored the Document (and, if applicable, the Person(s) to whom the Document was sent); (c) identify the date on which the document was prepared or created; (d) state whether such Document (i) is missing or lost, (ii) has been destroyed, (iii) has been transferred, voluntarily or involuntarily, to others, or (iv) was otherwise disposed of; (e) state the reason for, and the facts and circumstances surrounding, such disposition; (f) identify the Persons who authorized such disposition; (g) identify the date or approximate date of such disposition; (h) state when the Document was most recently in Your possession, custody or control; and (i) identify the Person, if any, presently in possession, custody, or control of such Document.\n\n7. If You are requested to produce a Document that has been destroyed, then Your response must state, in addition to the information required by the preceding Instruction: (a) the reason for the Document's destruction; (b) the identity of the Person who destroyed the Document; and (c) the identity of the Person who directed that the Document be destroyed.\n\n8. If You claim that a requested Document is privileged or attorney work-product, then Your response must: (a) state (i) a description of the Document adequate to support Your contention that the Document is privileged, (ii) the title of the Document, (iii) the date of the Document, (iv) the author of the Document, (v) the addressee of the Document, (vi) the identity of each Person who received or saw the original or any draft, copy, or reproduction of the Document, (vii) whether the Document itself, or any information contained or referred to in the Document is in the possession, custody, or control of any other Persons, and if so, the identity of\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 863 of 1063\n\nsuch Persons, as well as a statement addressing how the information came into their possession, (viii) the claim of privilege under which the Document is withheld, and (ix) all of the circumstances upon which You will rely to support such claim of privilege; and (b) produce a privilege log containing all of the information requested in Part (a) of this Instruction for each Document withheld on the basis of a claim of privilege in accordance with D. Conn. L. Civ. R. 26(e).\n\n9. If a portion of an otherwise responsive Document contains information subject to a claim of privilege, only that portion of the Document subject to the claim of privilege shall be deleted or redacted from the Document following the instructions above, and the rest shall be produced.\n\n10. The Requests are continuing in nature. You are hereby instructed to (a) supplement or correct any responses later learned to be incomplete or incorrect immediately upon learning that a prior response was incomplete or incorrect; and (b) produce any additional Documents that are called for under the\n\n11. If a Document is in a language other than English, You should provide that Document. If a Document is in a language other than English, and an English translation exists, You should provide both Documents.\n\n12. All references to Entities includes all affiliates thereof.\n\n13. All references to individual names include all alternative names, aliased, or nicknames.\n\n14. Unless otherwise expressly indicated, the period of time covered by the Document Requests is the period from February 5, 2012 to the date responses to the Document Requests are due.\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 864 of 1063\n\n#### **II. RULES OF CONSTRUCTION**\n\n15. The use of (a) any singular noun shall be construed to include the plural, and vice versa, and (b) a verb in any tense shall be construed as the use of the verb in all other tenses.\n\n16. The terms (a) \"and\" and \"or\" shall be construed either conjunctively or disjunctively as necessary to bring within the scope of any request all responses that might otherwise be construed to be outside of its scope, and (b) \"each\" and \"any\" shall be deemed to include and encompass the words \"every\" and \"all.\"\n\n#### **III. DEFINITIONS**\n\nThe definitions supplied by D. Conn. L. Civ. R. 26(c) and the rules of construction supplied by D. Conn. L. Civ. R. 26(d), as incorporated by D. Conn. Bankr. L.R. 2004-1(a), shall apply to the Document Requests. In addition, the following terms used in these Document Requests shall have the following meanings:\n\n1. \"You\" or \"Your\" or \"Yourself\" means and refers to Brent Petro Inc., together with all of its affiliates, divisions, agencies, instrumentalities, departments, offices, partners, officers, directors, agents, attorneys, representatives, employees, and/or anyone acting on its behalf.\n\n2. \"Debtor\" means Ho Wan Kwok (a/k/a Miles Kwok, Miles Guo, Guo Wengui, Guo Haoyun, 郭文贵, or any other alias), together with his employees, agents, counsel, advisors, or anyone acting on his behalf.\n\n3. \"Debtor's Son\" means Qiang Guo (a/k/a Mileson Kwok, 郭强, or any other alias), together with his employees, agents, counsel, advisors, or anyone acting on his behalf.\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 865 of 1063\n\n4. \"Debtor's Daughter\" means Mei Guo (a/k/a Mei Gui, 郭美, or any other alias), together with her employees, agents, counsel, advisors, or anyone acting on her behalf.\n\n5. \"Debtor's Purported Wife\" means Hing Chi Ngok (a/k/a Hing Chi Ng, Yue Qingzhi, 岳庆芝, or any other alias), together with her employees, agents, counsel, advisors, or anyone acting on her behalf.\n\n6. \"Debtor's Family\" means, collectively, the Debtor, the Debtor's Son, the Debtor's Daughter, and the Debtor's Purported Wife, and any other familial relation to the Debtor.\n\n7. \"Associated Individuals\" means, individually and collectively, all individuals that (1) hold, control, have custody over, or discretion over assets owned, controlled, or enjoyed by the Debtor or the Debtor's Family; or (2) have been employees, directors, or otherwise are affiliated with one or more Associated Entities, together with the respective employees, agents, counsel, advisors, or anyone acting on behalf of any of the foregoing. Such Associated Individuals shall include, but are not limited to: Daniel Podhaskie, Jason Miller, Steve Bannon, Karin Maistrello, Melissa Francis, Anthony DiBattista, William Gertz, Arethusa Forsyth, Glenn Mellor, Jennifer Mercurio, Eduardo Eurnekian, Wencong Wang, Han Chunguang (a/k/a 韩春光), Qu Guojiao (a/k/a Qu Guo Jiao, 屈国姣), Guo Lijie (a/k/a 郭丽杰), Zhang Wei (a/k/a 张伟\\*), Lihong Wei Lafrenz (a/k/a Sara Wei, 魏丽红), Hao Haidong (a/k/a 郝海东), Ross Heinemeyer, Max Krasner, Kyle Bass, Melissa Mendez, Ya Li (a/k/a 李娅), Dinggang Wang (a/k/a 王定刚), An Hong (a/k/a 安红), Yvette Wang (a/k/a Yanping Wang, Yan Ping Wang, 王雁平), Fiona Yu, Je Kin Ming (a/k/a William Je, Yu Jianming, 余建明), Yaz Qingua, and Lao Jiang (a/k/a Jiang Yunfu, Jiang Yunfu Be, 姜云浮).\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 866 of 1063\n\n8. \"Associated Entities\" means, individually and collectively, all organizations or Entities of any type that (1) have been owned, controlled, or invested in by the Debtor or the Debtor's Family; or (2) have an interest, whether directly or indirectly, in any assets owned, controlled, or enjoyed by the Debtor or the Debtor's Family, together with the respective employees, agents, counsel, advisors, or anyone acting on behalf of any of the foregoing. Such Associated Entities shall include, but are not limited to: 7 Nod Hill LLC, AAGV Limited, ACA Investment Management Limited, ACA Capital Group Limited, Ace Decade Holdings Limited, AI Group Holdings Inc., Alfa Global Ventures Limited, Alfonso Global Limited, Allied Capital Global Limited, Alpine Fiduciaries SA, Anton Development Limited, Assets Sino Limited, Auspicious Coast Limited, Beijing Pangu Investment Co., Beijing Pangu Investment Co. Ltd., Beijing Pangu Investment Inc., Beijing Zenith Holdings Company Limited, Booming Sail New York LLC, Bravo Luck Limited, BSA Strategic Fund I, China Golden Spring (Hong Kong) Limited, Chuang Xin Limited, Crane Advisory Group LLC, Creative Apex Investments Limited, Crystal Breeze Investments Limited, Dawn State Limited, Eastern Profit Corporation Limited, Elite Well Global Limited, Empire Growth Holdings, Freedom Media Ventures Ltd., G Club Operations LLC, G Fashion LLC, G News LLC, GETTR USA, Genever Holdings Corporation, Genever Holdings LLC, Gfashion Media Group Inc., GFNY, Inc., Globalist International Limited, GNews Media Group Inc., Golden Spring (New York) Ltd., Greenwich Land LLC, Guo Media, GTV Media Group, Inc., Hamilton Capital Holdings Inc., HCHK Property Management, Inc., HCHK Technologies, Inc., Head Win Group Limited, Henan Yuda, Himalaya Embassy, Himalaya Exchange, Himalaya Federal Reserve, Himalaya Investment LLC, Himalaya International, Himalaya New World Inc., Himalaya Supervisory Organization, Himalaya Ventures LLC, HK International Funds Investments (USA) Limited LLC, Hong Kong International Funds\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 867 of 1063\n\nInvestments Limited, Hudson Diamond Holding, Infinite Increase Limited, Infinitum Developments Limited, Infinity Treasury Management Inc., Insight Phoenix Fund, Lamp Capital LLC, Leading Shine Limited, Leading Shine NY Limited, Lexington Property and Staffing, Long Gate Limited, Maywind Trading LLC, MOS Himalaya LLC, Next Tycoon Investments Limited, New Federal State of China (a/k/a NFSC), Noble Fame Global Limited, Rosy Acme Ventures Limited, Rule of Law Foundation III, Inc., Rule of Law Foundation IV, Inc., Rule of Law Fund, Rule of Law Society, Rule of Law Society IV, Inc., G-Translators PTY LTD, Saraca Media Group, Inc., Shiny Ace Ltd., Shiny Times Holdings Ltd., Spirit Charter Investment Limited, Stevenson, Wong & Co., Voice of Guo Media, Inc., Well Origin Ltd., World Century Limited, Worldwide Opportunity Holdings Limited, Whitecroft Shore Limited, and ZIBA Limited.\n\n9. \"Including\" or any variant thereof means \"including without limitation.\"\n\n10. \"And\" and \"or\" mean \"and/or,\" and shall be construed both conjunctively as well as disjunctively in order to maximize their scope.\n\n11. \"Any\" and \"all\" and \"each\" mean \"each and every.\"\n\n12. \"Each\" and \"every\" mean \"each and every.\"\n\n13. \"Third Party\" means a Person or Entity other than Yourself.\n\n14. \"Transfer\" shall have the meaning given to it by section 101(54) of the Bankruptcy Code.\n\n15. \"Document\" means any information or thing within the scope of Fed. R. Civ. P. 34, and includes, without limitation, each and every written, recorded, or graphic matter of any kind, type, nature, or description that is or has been in Your Possession, Custody or Control, including all printed and electronic copies of electronic mail, computer files maintained in\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 868 of 1063\n\nelectronic form, electronic communication, text message, social media post, tweet, meta-data, correspondence, memoranda, tapes, stenographic or handwritten notes, written forms of any kind, charts, blueprints, drawings, sketches, graphs, plans, articles, specifications, diaries, letters, telegrams, photographs, minutes, contracts, agreements, surveys, computer printouts, data compilations of any kind, telexes, facsimiles, voice messages, invoices, order forms, checks, drafts, statements, credit memos, reports, position reports, summaries, indices, books, ledgers, notebooks, schedules, transparencies, recordings, catalogs, advertisements, promotional materials, films, video tapes, audio tapes, CDs, computer disks, brochures, pamphlets, punchcards, time-slips, Tweets, social media posts, or any written or recorded materials of any other kind, and all meta-data thereof, however stored (whether in tangible or electronic form), recorded, produced, or reproduced, and also including but not limited to, drafts or copies of any of the foregoing that contain any notes, comments, or markings of any kind not found on the original documents or that are otherwise not identical to the original documents.\n\n16. \"Person(s)\" means an individual, corporation, proprietorship, partnership, association, or any other Entity. \"Person\" also includes any agent, representatives, or expert, including but not limiting to, attorneys or financial advisors.\n\n17. \"Entity\" means any natural Person, corporation, partnership, subsidiary, sole proprietorship, firm, board, joint venture, association, agency, authority, commission or other business entity or juristic Person, as well as any affiliate, agent, parent including but not limited to legal counsel, financial advisors, or any other representative.\n\n18. \"Regarding\" means concerning, describing, comprising, referring to, related to, supporting, favoring, opposing, bolstering, detracting from, located in, considered in connection with, bearing on, evidencing, indicating, reporting on, recording, alluding to, responding to,\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 869 of 1063\n\nconnected with, commenting on, in respect of, about, in relation to, discussing, showing, describing, reflecting, analyzing constituting, and being.\n\n19. \"Relating to,\" \"relate(s) to\" or \"related to,\" when referring to any given subject matter, means, without limitation, any document that constitutes, comprises, involves, contains, embodies, reflects, identifies, states, refers directly or indirectly to, or is in any way relevant to the particular subject matter identified.\n\n20. \"Communication(s)\" means, in the broadest possible sense, and without limitation, any transmittal of information or knowledge (in the form of facts, ideas, inquiries, or otherwise). Communication(s) further refers to all conversations, agreements, inquiries, or replies, whether in person, by telephone, in writing, or by means of electronic transmittal devices, and includes, but is not limited to, all correspondence, emails, recordings, transmittal slips, memoranda, telephone communications, voice messages, telegrams, telefaxes, telecopies, telexes, instant messages, chats, text messages, telephonic notes, or notes transmitted internally or with third parties.\n\n21. \"Asset(s)\" means any item that can be used to produce positive economic value, including but not limited to any resource with economic value that is owned, controlled or is for the benefit of an entity, that is expected to provide a future benefit, including but not limited to, all real and personal property, intangible property, investments, rights to invest or to future revenue, cash, bank accounts, commodities, securities, claims, total or partial control of an entity, and prospective economic opportunities\n\n22. \"Transfer\" shall have the meaning given to it by section 101(54) of the Bankruptcy Code.\n\n#### **IV. DOCUMENTS TO BE PRODUCED**\n\n1. All Documents regarding any income or Asset of the Debtor, the Debtor's estate, or an Associated Entity.\n\n2. All Documents related to the Debtor's financial condition and obligations to his creditors, including without limitation all Documents related to any effort to avoid paying such obligations and All Documents related to this or any other actual or potential bankruptcy or similar insolvency proceeding.\n\n3. All Documents regarding any balance sheet, bank statement, account statement, financial statement, statement of account, wire transfer instructions and/or confirmation, proof of funds, certificate of deposit, certificate of holdings, investment portfolio summary, or similar document relating to the Debtor, the Debtor's Estate, the Debtor's Family, an Associated Entity, or an Associated Individual, including without limitation all Documents sufficient to show all Transfers to any of the foregoing.\n\n4. All Documents regarding any investment, business dealing or transactions made by, with, or on behalf of the Debtor.\n\n5. All Communications with the Debtor, and Documents related to Communications with the Debtor, related to the operation, management, or decision-making of any Entity, including without limitation the Associated Entities.\n\n6. All Documents regarding any Transfer, investment, or other transaction or business dealing made to, by, or with the Debtor, the Debtor's Family, or an Associated Entity.\n\n7. All Documents regarding any property ever occupied or used by the Debtor, including without limitation the *Lady May*; the Sherry Netherland Hotel / Condominium; the\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 871 of 1063\n\nresidential property located in Greenwich, Connecticut at 373 Taconic Rd.; the residential property located in Greenwich, Connecticut at 33 Ferncliff Rd.; and the residential property located in Wilton, Connecticut at 354 Nod Hill Rd.\n\n8. All Documents related to any aircraft owned, controlled, or used by the Debtor, including without limitation the aircraft bearing tail number T7-GQM and any other aircraft registered in San Marino, including without limitation copies of all registration documents and flight manifests showing flights taken by such aircraft and the individuals onboard such flights.\n\n9. All Documents regarding any gifts, benefits or loans, to, from or on behalf of the Debtor, the Debtor's Estate, the Debtor's Family, or the Associated Entities, including without limitation Documents sufficient to show the amounts of such gifts, benefits, or loans; the purposes for which such gifts, benefits, or loans were used; when the gifts, benefits, or loans were provided; and the terms of any loans, all representations and warranties made in connection with any loans, the interest rate on any loans, and all evidence of payments of any loans.\n\n10. All Documents concerning any trust or similar instrument set up by, on behalf of, or for the benefit of the Debtor, the Debtor's Estate, the Debtor's Family, or an Associated Entity, including without limitation Documents sufficient to show when the trust(s) was created, by whom it was created, for whose benefit it was created, and the corpus of the trust.\n\n11. All Documents related to any obligation, claim, liability, or debt associated with any legal dispute involving the Debtor, including but not limited to those relating to any litigation before any local, state, federal, or international body, whether an administrative body, court, panel, or alternative dispute resolution entity.\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 872 of 1063\n\n12. All Documents and communications between any of your outside counsel or other advisors and the Debtor.\n\n13. Documents sufficient to show all of Your Assets and sources of income or funding.\n\n14. For all Assets identified in response to Request 14 having a value of more than \\$50,000, all (i) Documents related to Your acquisition of such Asset and (ii) Communications with the Debtor or the Debtor's Family regarding such Asset.\n\n15. Copies of Your tax returns.\n\n16. Documents sufficient to show all bank accounts and investment accounts within Your possession or control, including the balances of and transfers to and from each such account.\n\n17. All Documents regarding any credit cards used by You, including without limitation monthly statements or other Documents sufficient to show all purchases related thereto for the benefit of the Debtor or an Associated Entity.\n\n18. All corporate governance and organizational Documents, including without limitation by-laws and certificates of incorporation and other Documents sufficient to show Your corporate structure, names of officers and directors, business purpose, and relationship to the Debtor or to any member of the Debtor's Family.\n\n19. All Documents related to any pledge(s) of Your Assets to any other Entity.\n\n# Exhibit C-48\n\n#### B2540 (Form 2540 – Subpoena for Rule 2004 Examination) (12/15) Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 874 of\n\n1063\n\nUNITED STATES BANKRUPTCY COURT\n\n**District of Connecticut**\n\nIn re HO WAN KWOK, *et al*.,\n\n<sup>1</sup> Case No. 22-50073 (JAM) Debtor Chapter 11\n\n(Jointly Administered)\n\n# **SUBPOENA FOR RULE 2004 EXAMINATION**\n\nTo: **Brent Petro Inc.**\n\n(*Name of person to whom the subpoena is directed*)\n\n*Testimony:* **YOU ARE COMMANDED** to appear at the time, date, and place set forth below to testify at an examination under Rule 2004, Federal Rules of Bankruptcy Procedure. A copy of the court order authorizing the examination is attached.\n\n| PLACE                    | DATE AND TIME |\n|--------------------------|---------------|\n| Paul Hastings LLP        |               |\n| 200 Park Avenue          | [TBD]         |\n| New York, New York 10166 |               |\n|                          |               |\n\nThe examination will be recorded by this method: **Court reporter/stenographer**\n\n*Production:* You, or your representatives, must also bring with you to the examination the following documents, electronically stored information, or objects, and must permit inspection, copying, testing, or sampling of the material:\n\n#### **See Requests for Production of Documents, attached hereto.**\n\nThe following provisions of Fed. R. Civ. P. 45, made applicable in bankruptcy cases by Fed. R. Bankr. P. 9016, are attached – Rule 45(c), relating to the place of compliance; Rule 45(d), relating to your protection as a person subject to a subpoena; and Rule 45(e) and 45(g), relating to your duty to respond to this subpoena and the potential consequences of not doing so.\n\nDate: **March , 2023**\n\nCLERK OF COURT\n\nOR\n\n*Signature of Clerk or Deputy Clerk Attorney's signature*\n\nThe name, address, email address, and telephone number of the attorney representing Luc A. Despins, Chapter 11 Trustee, who issues or requests this subpoena, are:\n\n**Douglas S. Skalka, Esq.; Neubert, Pepe & Monteith, P.C.; 195 Church Street, New Haven, Connecticut 06510 dskalka@npmlaw.com; (203) 821-2000**\n\n**Notice to the person who issues or requests this subpoena**\n\nIf this subpoena commands the production of documents, electronically stored information, or tangible things, or the inspection of premises before trial, a notice and a copy of this subpoena must be served on each party before it is served on the person to whom it is directed. Fed. R. Civ. P. 45(a)(4).\n\nSoftware Copyright (c) 1996-2022 Best Case, LLC - www.bestcase.com Best Case Bankruptcy 1 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\n#### **PROOF OF SERVICE**\n\n**(This section should not be filed with the court unless required by Fed. R. Civ. P. 45.)**\n\nI received this subpoena for (*name of individual and title, if any*): on (*date*) .\n\nI served the subpoena by delivering a copy to the named person as follows:\n\non *(date)* ; or\n\nI returned the subpoena unexecuted because:\n\nUnless the subpoena was issued on behalf of the United States, or one of its officers or agents, I have also tendered to the witness the fees for one day's attendance, and the mileage allowed by law, in the amount of \\$ .\n\nMy fees are \\$ for travel and \\$ for services, for a total of \\$ .\n\nI declare under penalty of perjury that this information is true and correct.\n\nDate:\n\n*Server's signature*\n\n*Printed name and title*\n\n*Server's address*\n\nAdditional information concerning attempted service, etc.:\n\n#### **Federal Rule of Civil Procedure 45(c), (d), (e), and (g) (Effective 12/1/13) (made applicable in bankruptcy cases by Rule 9016, Federal Rules of Bankruptcy Procedure)**\n\n#### **(c) Place of compliance.**\n\n*(1) For a Trial, Hearing, or Deposition.* A subpoena may command a person to attend a trial, hearing, or deposition only as follows:\n\n(A) within 100 miles of where the person resides, is employed, or regularly transacts business in person; or\n\n(B) within the state where the person resides, is employed, or regularly transacts business in person, if the person\n\n(i) is a party or a party's officer; or\n\n(ii) is commanded to attend a trial and would not incur substantial expense.\n\n*(2) For Other Discovery.* A subpoena may command:\n\n(A) production of documents, or electronically stored information, or things at a place within 100 miles of where the person resides, is employed, or regularly transacts business in person; and\n\n(B) inspection of premises, at the premises to be inspected.\n\n#### **(d) Protecting a Person Subject to a Subpoena; Enforcement.**\n\n*(1) Avoiding Undue Burden or Expense; Sanctions.* A party or attorney responsible for issuing and serving a subpoena must take reasonable steps to avoid imposing undue burden or expense on a person subject to the subpoena. The court for the district where compliance is required must enforce this duty and impose an appropriate sanction which may include lost earnings and reasonable attorney's fees — on a party or attorney who fails to comply.\n\n#### *(2) Command to Produce Materials or Permit Inspection.*\n\n*(A) Appearance Not Required.* A person commanded to produce documents, electronically stored information, or tangible things, or to permit the inspection of premises, need not appear in person at the place of production or inspection unless also commanded to appear for a deposition, hearing, or trial.\n\n*(B) Objections.* A person commanded to produce documents or tangible things or to permit inspection may serve on the party or attorney designated in the subpoena a written objection to inspecting, copying, testing or sampling any or all of the materials or to inspecting the premises — or to producing electronically stored information in the form or forms requested. The objection must be served before the earlier of the time specified for compliance or 14 days after the subpoena is served. If an objection is made, the following rules apply:\n\n(i) At any time, on notice to the commanded person, the serving party may move the court for the district where compliance is required for an order compelling production or inspection.\n\n(ii) These acts may be required only as directed in the order, and the order must protect a person who is neither a party nor a party's officer from significant expense resulting from compliance.\n\n#### *(3) Quashing or Modifying a Subpoena.*\n\n*(A) When Required.* On timely motion, the court for the district where compliance is required must quash or modify a subpoena that:\n\n(i) fails to allow a reasonable time to comply;\n\n(ii) requires a person to comply beyond the geographical limits specified in Rule 45(c);\n\n(iii) requires disclosure of privileged or other protected matter, if no exception or waiver applies; or\n\n(iv) subjects a person to undue burden.\n\n*(B) When Permitted.* To protect a person subject to or affected by a subpoena, the court for the district where compliance is required may, on motion, quash or modify the subpoena if it requires:\n\n(i) disclosing a trade secret or other confidential research, development, or commercial information; or\n\n(ii) disclosing an unretained expert's opinion or information that does not describe specific occurrences in dispute and results from the expert's study that was not requested by a party.\n\n(C) *Specifying Conditions as an Alternative.* In the circumstances described in Rule 45(d)(3)(B), the court may, instead of quashing or modifying a subpoena, order appearance or production under specified conditions if the serving party:\n\n(i) shows a substantial need for the testimony or material that cannot be otherwise met without undue hardship; and\n\n(ii) ensures that the subpoenaed person will be reasonably compensated.\n\n#### **(e) Duties in Responding to a Subpoena.**\n\n*(1) Producing Documents or Electronically Stored Information.* These procedures apply to producing documents or electronically stored information:\n\n*(A) Documents.* A person responding to a subpoena to produce documents must produce them as they are kept in the ordinary course of business or must organize and label them to correspond to the categories in the demand.\n\n*(B) Form for Producing Electronically Stored Information Not Specified.* If a subpoena does not specify a form for producing electronically stored information, the person responding must produce it in a form or forms in which it is ordinarily maintained or in a reasonably usable form or forms.\n\n*(C) Electronically Stored Information Produced in Only One Form.* The person responding need not produce the same electronically stored information in more than one form.\n\n*(D) Inaccessible Electronically Stored Information.* The person responding need not provide discovery of electronically stored information from sources that the person identifies as not reasonably accessible because of undue burden or cost. On motion to compel discovery or for a protective order, the person responding must show that the information is not reasonably accessible because of undue burden or cost. If that showing is made, the court may nonetheless order discovery from such sources if the requesting party shows good cause, considering the limitations of Rule 26(b)(2)(C). The court may specify conditions for the discovery.\n\n#### *(2) Claiming Privilege or Protection.*\n\n*(A) Information Withheld.* A person withholding subpoenaed information under a claim that it is privileged or subject to protection as trial-preparation material must: (i) expressly make the claim; and\n\n(ii) describe the nature of the withheld documents, communications, or tangible things in a manner that, without revealing information itself privileged or protected, will enable the parties to assess the claim.\n\n*(B) Information Produced.* If information produced in response to a subpoena is subject to a claim of privilege or of protection as trial-preparation material, the person making the claim may notify any party that received the information of the claim and the basis for it. After being notified, a party must promptly return, sequester, or destroy the specified information and any copies it has; must not use or disclose the information until the claim is resolved; must take reasonable steps to retrieve the information if the party disclosed it before being notified; and may promptly present the information under seal to the court for the district where compliance is required for a determination of the claim. The person who produced the information must preserve the information until the claim is resolved.\n\n**(g) Contempt.** The court for the district where compliance is required – and also, after a motion is transferred, the issuing court – may hold in contempt a person who, having been served, fails without adequate excuse to obey the subpoena or an order related to it.\n\nFor access to subpoena materials, see Fed.R.Civ.P.45(a) Committee Note (2013)\n\n…\n\n## **Requests for Production of Documents**\n\n## **I. INSTRUCTIONS**\n\n1. Unless otherwise indicated, the requests for documents set forth below, (the \"Requests,\" and each, a \"Request\"), must be responded to separately and specifically. Each Request shall be answered fully unless it is in good faith objected to, in which event the reason for Your objection shall be stated in detail, as set forth below. If an objection pertains only to a portion of a Request, or a word, phrase or clause contained within it, You are required to state Your objection to that portion only and to respond to the remainder of the Requests.\n\n2. Electronically stored information must be produced in accordance with the\n\nfollowing instructions:\n\n- a. Images. Black and white images must be 300 DPI Group IV single-page TIFF files. Color images must be produced in JPEG format. File names cannot contain embedded spaces or special characters (including the comma). Folder names cannot contain embedded spaces or special characters (including the comma). All TIFF image files must have a unique file name, i.e. Bates number. Images must be endorsed with sequential Bates numbers in the lower right corner of each image. The number of TIFF files per folder should not exceed 1000 files. Excel spreadsheets should have a placeholder image named by the Bates number of the file.\n- b. Image Load File\n\t- a. Concordance® Data File. The data file (.DAT) contains all of the fielded information that will be loaded into the Concordance® database. The first line of the .DAT file must be a header row identifying the field names. The .DAT file must use the following Concordance® default delimiters: Comma ASCII character (020) Quote þ ASCII character (254). Date fields should be provided in the format: mm/dd/yyyy. Date and time fields must be two separate fields. If documents includes imaged emails and attachments, the attachment fields must be included to preserve the parent/child relationship between an email and its attachments. An OCRPATH field must be included to provide the file path and name of the extracted text file on the produced storage media. The text file must be named after the FIRSTBATES. Do not include the text in the .DAT file. For Documents with native files, a LINK field must be included to provide the file path and\n\nname of the native file. The native file must be named after the FIRSTBATES.\n\n- b. Concordance Image® OR Opticon Cross-Reference File. The image crossreference file (.LOG or .OPT) links the images to the database records. It should be a comma-delimited file consisting of seven fields per line with a line in the cross-reference file for every image in the database with the following format: ImageID,VolumeLabel,ImageFilePath,DocumentBreak,FolderBreak,Box Break,PageCoun.\n- c. Document Text. Text must be produced as separate text files, not as fields within the .DAT file. The full path to the text file (OCRPATH) should be included in the .DAT file. It is recommended document level ANSI text files, named per the FIRSTBATES/Image Key. Extracted text files must be in a separate folder, and the number of text files per folder should not exceed 1,000 files. There should be no special characters (including commas in the folder names). Text files must be provided on a document level.\n- d. Native Production for Certain File Types. File types that reasonably require viewing in their native format for a full understanding of their content and meaning must be produced in native format. These include, but are not limited to, spreadsheets, spreadsheet-like files (Microsoft Excel, comma separated values, tab separated values, etc.), Microsoft PowerPoint or other special presentation files, database files, and audio/visual files. Provide an image of a Bates numbered slip sheet indicating the presence of a native file, and include the path to the native as a field in the .dat file. Name the produced native file with the Bates number corresponding to the slip sheet for the file. Group native files within incrementally named \"NATIVE\" directories, separate from images directories.\n- e. De-duplication. Produce a single copy of each electronic document for which exact duplicates exist. For email messages, consolidate duplicates based on MD5 hash generated from the BCC, Body, CC, From, IntMsgID, To, and Attach properties. For email attachments and standalone electronic files, consolidate duplicates based on MD5 hash of the entire file.\n- f. Metadata. Produce extracted metadata for each document in the form of a Concordance compliant load file (.dat). The first line of the .DAT file must be a header row identifying the field names. The .DAT file must use the following Concordance default delimiters: Comma , ASCII character (020) Quote þ ASCII character (254)\n\nDate fields should be provided in the format: mm/dd/yyyy. Date and time fields must be two separate fields. Required metadata listed below:\n\n# Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 879 of 1063\n\n| Field Name   | Sample Data              | Description                                      |\n|--------------|--------------------------|--------------------------------------------------|\n| FIRSTBATES   | EDC0000001               | First Bates number of native file document/email |\n| LASTBATES    | EDC0000001               | Last Bates number of native file document/email  |\n|              |                          | **The LASTBATES field should be populated        |\n|              |                          | for single page                                  |\n| ATTACHRANGE  | EDC0000001<br>-          | Bates number of the first page of the parent     |\n|              | EDC0000015               | document to the Bates number of the last page of |\n|              |                          | the last attachment \"child\" document             |\n| BEGATTACH    | EDC0000001               | First Bates number of attachment range           |\n| ENDATTACH    | EDC0000015               | Last Bates number of attachment range            |\n| CUSTODIAN    | Smith, John              | Email: Mailbox where the email resided           |\n|              |                          | Native: Name of the individual or department     |\n|              |                          | from whose files the document<br>originated      |\n| FROM         | John Smith               | Email: Sender                                    |\n|              |                          | Native: Author(s) of document                    |\n|              |                          | **semi-colon should be used to separate          |\n|              |                          | multiple entries                                 |\n| TO           | Coffman, Janice; LeeW    | Recipient(s)                                     |\n|              | [mailto:LeeW@MSN.com]    | **semi-colon should be used to separate multiple |\n|              |                          | entries                                          |\n| CC           | Frank Thompson [mailto:  | Carbon copy recipient(s)                         |\n|              | frank_Thompson@cdt.com]  | **semi-colon should be used to separate          |\n|              |                          | multiple entries                                 |\n| BCC          | John Cain                | Blind carbon copy recipient(s)                   |\n|              |                          | **semi-colon should be used to separate          |\n|              |                          | multiple entries                                 |\n| SUBJECT      | Board Meeting Minutes    | Email: Subject line of the email Native: Title   |\n|              |                          | of document (if available)                       |\n| FILE_NAME    | BoardMeetingMinutes.docx | Native: Name of the original native file,        |\n|              |                          | including extension                              |\n| DATE_SENT    | 10/12/2010               | Email: Date the email was sent                   |\n|              |                          | Native: (empty)                                  |\n| TIME_SENT/   | 07:05 PM GMT             | Email: Time the email was sent/ Time zone in     |\n| TIME_ZONE    |                          | which the emails were standardized               |\n| TIME_ZONE    | GMT                      | The<br>time zone in which<br>the emails<br>were  |\n|              |                          | standardized during conversion.                  |\n| LINK         |  EDC0000001.msg   | Hyperlink to the email or native file document   |\n|              |                          | **The linked file must be named per the          |\n|              |                          | FIRSTBATES number                                |\n| FILE_EXTEN   | MSG                      | The file type extension                          |\n|              |                          | representing                                     |\n|              |                          | the Email or                                     |\n| AUTHOR       | John Smith               | Email: (empty)                                   |\n|              |                          | Native: Author of the document                   |\n| DATE_CREATED | 10/10/2010               | Email: (empty)                                   |\n|              |                          | Native: Date the document was created            |\n|              |                          |                                                  |\n\n# Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 880 of 1063\n\n| TIME_CREATED | 10:25 AM                  | Email: (empty)                                  |\n|--------------|---------------------------|-------------------------------------------------|\n|              |                           | Native: Time the document was created           |\n|              |                           | **This data must be a separate field and cannot |\n|              |                           | be combined with the DATE_CREATED field         |\n| DATE_MOD     | 10/12/2010                | Email: (empty)                                  |\n|              |                           | Native: Date the document was last modified     |\n| TIME_MOD     | 07:00 PM                  | Email: (empty)                                  |\n|              |                           | Native: Time the document was last modified     |\n|              |                           | **This data must be a separate field and cannot |\n|              |                           | be combined with the DATE_MOD field             |\n| DATE_ACCESSD | 10/12/2010                | Email: (empty)                                  |\n|              |                           | Native: Date the document was last accessed     |\n| TIME_ACCESSD | 07:00 PM                  | Email: (empty)                                  |\n|              |                           | Native: Time the document was last accessed     |\n|              |                           | **This data must be a separate field and cannot |\n|              |                           | be combined with the DATE_ACCESSD field         |\n| FILE_SIZE    | 5,952                     | Size of native file<br>document/email in KB     |\n| PGCOUNT      | 1                         | Number of pages in native file document/email   |\n| PATH         |   | Email: (empty)                                  |\n|              | Agenda.doc                | Native: Path where native file document was     |\n|              |                           | stored including original file name.            |\n| INTFILEPATH  | Personal Folders\\Deleted  | Email: original location of email including     |\n|              | Items\\Board Meeting       | original file name.                             |\n|              | Minutes.msg               | Native: (empty)                                 |\n| INTMSGID     | <000805c2c71b\\$75977050\\$ | Email: Unique Message ID Native: (empty)        |\n|              | cb8306d1@MSN>             |                                                 |\n| MD5HASH      | d131dd02c5e6eec4693d9a0   | MD5 Hash value of the document.                 |\n|              | 698aff95c                 |                                                 |\n|              | 2fcab58712467eab4004583e  |                                                 |\n|              | b8fb7f89                  |                                                 |\n| OCRPATH      | TEXT/001/EDC0000001.txt   | Path to extracted text of the native file       |\n\n3. Each Request operates and should be construed independently and, unless otherwise indicated, no Request limits the scope of any other Request.\n\n4. All Documents are to be produced as kept in the usual course of business or are to be organized and labeled to correspond with the categories in these Requests.\n\n5. Each Request contained herein extends to all Documents: (a) in Your possession, custody, or control; or (b) in the possession, custody, or control of anyone acting on Your behalf,\n\n#### Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 881 of 1063\n\nincluding Your counsel or other representatives and advisors. Each Document shall be produced in its entirety.\n\n6. If You are requested to produce a Document that is no longer in Your possession, custody, or control, then Your response must (a) describe in detail the nature of the document and its contents; (b) identify the person(s) who prepared or authored the Document (and, if applicable, the Person(s) to whom the Document was sent); (c) identify the date on which the document was prepared or created; (d) state whether such Document (i) is missing or lost, (ii) has been destroyed, (iii) has been transferred, voluntarily or involuntarily, to others, or (iv) was otherwise disposed of; (e) state the reason for, and the facts and circumstances surrounding, such disposition; (f) identify the Persons who authorized such disposition; (g) identify the date or approximate date of such disposition; (h) state when the Document was most recently in Your possession, custody or control; and (i) identify the Person, if any, presently in possession, custody, or control of such Document.\n\n7. If You are requested to produce a Document that has been destroyed, then Your response must state, in addition to the information required by the preceding Instruction: (a) the reason for the Document's destruction; (b) the identity of the Person who destroyed the Document; and (c) the identity of the Person who directed that the Document be destroyed.\n\n8. If You claim that a requested Document is privileged or attorney work-product, then Your response must: (a) state (i) a description of the Document adequate to support Your contention that the Document is privileged, (ii) the title of the Document, (iii) the date of the Document, (iv) the author of the Document, (v) the addressee of the Document, (vi) the identity of each Person who received or saw the original or any draft, copy, or reproduction of the Document, (vii) whether the Document itself, or any information contained or referred to in the Document is in the possession, custody, or control of any other Persons, and if so, the identity of\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 882 of 1063\n\nsuch Persons, as well as a statement addressing how the information came into their possession, (viii) the claim of privilege under which the Document is withheld, and (ix) all of the circumstances upon which You will rely to support such claim of privilege; and (b) produce a privilege log containing all of the information requested in Part (a) of this Instruction for each Document withheld on the basis of a claim of privilege in accordance with D. Conn. L. Civ. R. 26(e).\n\n9. If a portion of an otherwise responsive Document contains information subject to a claim of privilege, only that portion of the Document subject to the claim of privilege shall be deleted or redacted from the Document following the instructions above, and the rest shall be produced.\n\n10. The Requests are continuing in nature. You are hereby instructed to (a) supplement or correct any responses later learned to be incomplete or incorrect immediately upon learning that a prior response was incomplete or incorrect; and (b) produce any additional Documents that are called for under the\n\n11. If a Document is in a language other than English, You should provide that Document. If a Document is in a language other than English, and an English translation exists, You should provide both Documents.\n\n12. All references to Entities includes all affiliates thereof.\n\n13. All references to individual names include all alternative names, aliased, or nicknames.\n\n14. Unless otherwise expressly indicated, the period of time covered by the Document Requests is the period from February 5, 2012 to the date responses to the Document Requests are due.\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 883 of 1063\n\n#### **II. RULES OF CONSTRUCTION**\n\n15. The use of (a) any singular noun shall be construed to include the plural, and vice versa, and (b) a verb in any tense shall be construed as the use of the verb in all other tenses.\n\n16. The terms (a) \"and\" and \"or\" shall be construed either conjunctively or disjunctively as necessary to bring within the scope of any request all responses that might otherwise be construed to be outside of its scope, and (b) \"each\" and \"any\" shall be deemed to include and encompass the words \"every\" and \"all.\"\n\n#### **III. DEFINITIONS**\n\nThe definitions supplied by D. Conn. L. Civ. R. 26(c) and the rules of construction supplied by D. Conn. L. Civ. R. 26(d), as incorporated by D. Conn. Bankr. L.R. 2004-1(a), shall apply to the Document Requests. In addition, the following terms used in these Document Requests shall have the following meanings:\n\n1. \"You\" or \"Your\" or \"Yourself\" means and refers to Sirius Networking Inc., together with all of its affiliates, divisions, agencies, instrumentalities, departments, offices, partners, officers, directors, agents, attorneys, representatives, employees, and/or anyone acting on its behalf.\n\n2. \"Debtor\" means Ho Wan Kwok (a/k/a Miles Kwok, Miles Guo, Guo Wengui, Guo Haoyun, 郭文贵, or any other alias), together with his employees, agents, counsel, advisors, or anyone acting on his behalf.\n\n3. \"Debtor's Son\" means Qiang Guo (a/k/a Mileson Kwok, 郭强, or any other alias), together with his employees, agents, counsel, advisors, or anyone acting on his behalf.\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 884 of 1063\n\n4. \"Debtor's Daughter\" means Mei Guo (a/k/a Mei Gui, 郭美, or any other alias), together with her employees, agents, counsel, advisors, or anyone acting on her behalf.\n\n5. \"Debtor's Purported Wife\" means Hing Chi Ngok (a/k/a Hing Chi Ng, Yue Qingzhi, 岳庆芝, or any other alias), together with her employees, agents, counsel, advisors, or anyone acting on her behalf.\n\n6. \"Debtor's Family\" means, collectively, the Debtor, the Debtor's Son, the Debtor's Daughter, and the Debtor's Purported Wife, and any other familial relation to the Debtor.\n\n7. \"Associated Individuals\" means, individually and collectively, all individuals that (1) hold, control, have custody over, or discretion over assets owned, controlled, or enjoyed by the Debtor or the Debtor's Family; or (2) have been employees, directors, or otherwise are affiliated with one or more Associated Entities, together with the respective employees, agents, counsel, advisors, or anyone acting on behalf of any of the foregoing. Such Associated Individuals shall include, but are not limited to: Daniel Podhaskie, Jason Miller, Steve Bannon, Karin Maistrello, Melissa Francis, Anthony DiBattista, William Gertz, Arethusa Forsyth, Glenn Mellor, Jennifer Mercurio, Eduardo Eurnekian, Wencong Wang, Han Chunguang (a/k/a 韩春光), Qu Guojiao (a/k/a Qu Guo Jiao, 屈国姣), Guo Lijie (a/k/a 郭丽杰), Zhang Wei (a/k/a 张伟\\*), Lihong Wei Lafrenz (a/k/a Sara Wei, 魏丽红), Hao Haidong (a/k/a 郝海东), Ross Heinemeyer, Max Krasner, Kyle Bass, Melissa Mendez, Ya Li (a/k/a 李娅), Dinggang Wang (a/k/a 王定刚), An Hong (a/k/a 安红), Yvette Wang (a/k/a Yanping Wang, Yan Ping Wang, 王雁平), Fiona Yu, Je Kin Ming (a/k/a William Je, Yu Jianming, 余建明), Yaz Qingua, and Lao Jiang (a/k/a Jiang Yunfu, Jiang Yunfu Be, 姜云浮).\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 885 of 1063\n\n8. \"Associated Entities\" means, individually and collectively, all organizations or Entities of any type that (1) have been owned, controlled, or invested in by the Debtor or the Debtor's Family; or (2) have an interest, whether directly or indirectly, in any assets owned, controlled, or enjoyed by the Debtor or the Debtor's Family, together with the respective employees, agents, counsel, advisors, or anyone acting on behalf of any of the foregoing. Such Associated Entities shall include, but are not limited to: 7 Nod Hill LLC, AAGV Limited, ACA Investment Management Limited, ACA Capital Group Limited, Ace Decade Holdings Limited, AI Group Holdings Inc., Alfa Global Ventures Limited, Alfonso Global Limited, Allied Capital Global Limited, Alpine Fiduciaries SA, Anton Development Limited, Assets Sino Limited, Auspicious Coast Limited, Beijing Pangu Investment Co., Beijing Pangu Investment Co. Ltd., Beijing Pangu Investment Inc., Beijing Zenith Holdings Company Limited, Booming Sail New York LLC, Bravo Luck Limited, BSA Strategic Fund I, China Golden Spring (Hong Kong) Limited, Chuang Xin Limited, Crane Advisory Group LLC, Creative Apex Investments Limited, Crystal Breeze Investments Limited, Dawn State Limited, Eastern Profit Corporation Limited, Elite Well Global Limited, Empire Growth Holdings, Freedom Media Ventures Ltd., G Club Operations LLC, G Fashion LLC, G News LLC, GETTR USA, Genever Holdings Corporation, Genever Holdings LLC, Gfashion Media Group Inc., GFNY, Inc., Globalist International Limited, GNews Media Group Inc., Golden Spring (New York) Ltd., Greenwich Land LLC, Guo Media, GTV Media Group, Inc., Hamilton Capital Holdings Inc., HCHK Property Management, Inc., HCHK Technologies, Inc., Head Win Group Limited, Henan Yuda, Himalaya Embassy, Himalaya Exchange, Himalaya Federal Reserve, Himalaya Investment LLC, Himalaya International, Himalaya New World Inc., Himalaya Supervisory Organization, Himalaya Ventures LLC, HK International Funds Investments (USA) Limited LLC, Hong Kong International Funds\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 886 of 1063\n\nInvestments Limited, Hudson Diamond Holding, Infinite Increase Limited, Infinitum Developments Limited, Infinity Treasury Management Inc., Insight Phoenix Fund, Lamp Capital LLC, Leading Shine Limited, Leading Shine NY Limited, Lexington Property and Staffing, Long Gate Limited, Maywind Trading LLC, MOS Himalaya LLC, Next Tycoon Investments Limited, New Federal State of China (a/k/a NFSC), Noble Fame Global Limited, Rosy Acme Ventures Limited, Rule of Law Foundation III, Inc., Rule of Law Foundation IV, Inc., Rule of Law Fund, Rule of Law Society, Rule of Law Society IV, Inc., G-Translators PTY LTD, Saraca Media Group, Inc., Shiny Ace Ltd., Shiny Times Holdings Ltd., Spirit Charter Investment Limited, Stevenson, Wong & Co., Voice of Guo Media, Inc., Well Origin Ltd., World Century Limited, Worldwide Opportunity Holdings Limited, Whitecroft Shore Limited, and ZIBA Limited.\n\n9. \"Including\" or any variant thereof means \"including without limitation.\"\n\n10. \"And\" and \"or\" mean \"and/or,\" and shall be construed both conjunctively as well as disjunctively in order to maximize their scope.\n\n11. \"Any\" and \"all\" and \"each\" mean \"each and every.\"\n\n12. \"Each\" and \"every\" mean \"each and every.\"\n\n13. \"Third Party\" means a Person or Entity other than Yourself.\n\n14. \"Transfer\" shall have the meaning given to it by section 101(54) of the Bankruptcy Code.\n\n15. \"Document\" means any information or thing within the scope of Fed. R. Civ. P. 34, and includes, without limitation, each and every written, recorded, or graphic matter of any kind, type, nature, or description that is or has been in Your Possession, Custody or Control, including all printed and electronic copies of electronic mail, computer files maintained in\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 887 of 1063\n\nelectronic form, electronic communication, text message, social media post, tweet, meta-data, correspondence, memoranda, tapes, stenographic or handwritten notes, written forms of any kind, charts, blueprints, drawings, sketches, graphs, plans, articles, specifications, diaries, letters, telegrams, photographs, minutes, contracts, agreements, surveys, computer printouts, data compilations of any kind, telexes, facsimiles, voice messages, invoices, order forms, checks, drafts, statements, credit memos, reports, position reports, summaries, indices, books, ledgers, notebooks, schedules, transparencies, recordings, catalogs, advertisements, promotional materials, films, video tapes, audio tapes, CDs, computer disks, brochures, pamphlets, punchcards, time-slips, Tweets, social media posts, or any written or recorded materials of any other kind, and all meta-data thereof, however stored (whether in tangible or electronic form), recorded, produced, or reproduced, and also including but not limited to, drafts or copies of any of the foregoing that contain any notes, comments, or markings of any kind not found on the original documents or that are otherwise not identical to the original documents.\n\n16. \"Person(s)\" means an individual, corporation, proprietorship, partnership, association, or any other Entity. \"Person\" also includes any agent, representatives, or expert, including but not limiting to, attorneys or financial advisors.\n\n17. \"Entity\" means any natural Person, corporation, partnership, subsidiary, sole proprietorship, firm, board, joint venture, association, agency, authority, commission or other business entity or juristic Person, as well as any affiliate, agent, parent including but not limited to legal counsel, financial advisors, or any other representative.\n\n18. \"Regarding\" means concerning, describing, comprising, referring to, related to, supporting, favoring, opposing, bolstering, detracting from, located in, considered in connection with, bearing on, evidencing, indicating, reporting on, recording, alluding to, responding to,\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 888 of 1063\n\nconnected with, commenting on, in respect of, about, in relation to, discussing, showing, describing, reflecting, analyzing constituting, and being.\n\n19. \"Relating to,\" \"relate(s) to\" or \"related to,\" when referring to any given subject matter, means, without limitation, any document that constitutes, comprises, involves, contains, embodies, reflects, identifies, states, refers directly or indirectly to, or is in any way relevant to the particular subject matter identified.\n\n20. \"Communication(s)\" means, in the broadest possible sense, and without limitation, any transmittal of information or knowledge (in the form of facts, ideas, inquiries, or otherwise). Communication(s) further refers to all conversations, agreements, inquiries, or replies, whether in person, by telephone, in writing, or by means of electronic transmittal devices, and includes, but is not limited to, all correspondence, emails, recordings, transmittal slips, memoranda, telephone communications, voice messages, telegrams, telefaxes, telecopies, telexes, instant messages, chats, text messages, telephonic notes, or notes transmitted internally or with third parties.\n\n21. \"Asset(s)\" means any item that can be used to produce positive economic value, including but not limited to any resource with economic value that is owned, controlled or is for the benefit of an entity, that is expected to provide a future benefit, including but not limited to, all real and personal property, intangible property, investments, rights to invest or to future revenue, cash, bank accounts, commodities, securities, claims, total or partial control of an entity, and prospective economic opportunities\n\n22. \"Transfer\" shall have the meaning given to it by section 101(54) of the Bankruptcy Code.\n\n#### **IV. DOCUMENTS TO BE PRODUCED**\n\n1. All Documents regarding any income or Asset of the Debtor, the Debtor's estate, or an Associated Entity.\n\n2. All Documents related to the Debtor's financial condition and obligations to his creditors, including without limitation all Documents related to any effort to avoid paying such obligations and All Documents related to this or any other actual or potential bankruptcy or similar insolvency proceeding.\n\n3. All Documents regarding any balance sheet, bank statement, account statement, financial statement, statement of account, wire transfer instructions and/or confirmation, proof of funds, certificate of deposit, certificate of holdings, investment portfolio summary, or similar document relating to the Debtor, the Debtor's Estate, the Debtor's Family, an Associated Entity, or an Associated Individual, including without limitation all Documents sufficient to show all Transfers to any of the foregoing.\n\n4. All Documents regarding any investment, business dealing or transactions made by, with, or on behalf of the Debtor.\n\n5. All Communications with the Debtor, and Documents related to Communications with the Debtor, related to the operation, management, or decision-making of any Entity, including without limitation the Associated Entities.\n\n6. All Documents regarding any Transfer, investment, or other transaction or business dealing made to, by, or with the Debtor, the Debtor's Family, or an Associated Entity.\n\n7. All Documents regarding any property ever occupied or used by the Debtor, including without limitation the *Lady May*; the Sherry Netherland Hotel / Condominium; the\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 890 of 1063\n\nresidential property located in Greenwich, Connecticut at 373 Taconic Rd.; the residential property located in Greenwich, Connecticut at 33 Ferncliff Rd.; and the residential property located in Wilton, Connecticut at 354 Nod Hill Rd.\n\n8. All Documents related to any aircraft owned, controlled, or used by the Debtor, including without limitation the aircraft bearing tail number T7-GQM and any other aircraft registered in San Marino, including without limitation copies of all registration documents and flight manifests showing flights taken by such aircraft and the individuals onboard such flights.\n\n9. All Documents regarding any gifts, benefits or loans, to, from or on behalf of the Debtor, the Debtor's Estate, the Debtor's Family, or the Associated Entities, including without limitation Documents sufficient to show the amounts of such gifts, benefits, or loans; the purposes for which such gifts, benefits, or loans were used; when the gifts, benefits, or loans were provided; and the terms of any loans, all representations and warranties made in connection with any loans, the interest rate on any loans, and all evidence of payments of any loans.\n\n10. All Documents concerning any trust or similar instrument set up by, on behalf of, or for the benefit of the Debtor, the Debtor's Estate, the Debtor's Family, or an Associated Entity, including without limitation Documents sufficient to show when the trust(s) was created, by whom it was created, for whose benefit it was created, and the corpus of the trust.\n\n11. All Documents related to any obligation, claim, liability, or debt associated with any legal dispute involving the Debtor, including but not limited to those relating to any litigation before any local, state, federal, or international body, whether an administrative body, court, panel, or alternative dispute resolution entity.\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 891 of 1063\n\n12. All Documents and communications between any of your outside counsel or other advisors and the Debtor.\n\n13. Documents sufficient to show all of Your Assets and sources of income or funding.\n\n14. For all Assets identified in response to Request 14 having a value of more than \\$50,000, all (i) Documents related to Your acquisition of such Asset and (ii) Communications with the Debtor or the Debtor's Family regarding such Asset.\n\n15. Copies of Your tax returns.\n\n16. Documents sufficient to show all bank accounts and investment accounts within Your possession or control, including the balances of and transfers to and from each such account.\n\n17. All Documents regarding any credit cards used by You, including without limitation monthly statements or other Documents sufficient to show all purchases related thereto for the benefit of the Debtor or an Associated Entity.\n\n18. All corporate governance and organizational Documents, including without limitation by-laws and certificates of incorporation and other Documents sufficient to show Your corporate structure, names of officers and directors, business purpose, and relationship to the Debtor or to any member of the Debtor's Family.\n\n19. All Documents related to any pledge(s) of Your Assets to any other Entity.\n\n# Exhibit C-49\n\n#### B2540 (Form 2540 – Subpoena for Rule 2004 Examination) (12/15) Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 893 of\n\n1063\n\nUNITED STATES BANKRUPTCY COURT\n\n**District of Connecticut**\n\nIn re HO WAN KWOK, *et al*.,\n\n<sup>1</sup> Case No. 22-50073 (JAM) Debtor Chapter 11\n\n(Jointly Administered)\n\n# **SUBPOENA FOR RULE 2004 EXAMINATION**\n\nTo: **Pixshow Film Inc.**\n\n(*Name of person to whom the subpoena is directed*)\n\n*Testimony:* **YOU ARE COMMANDED** to appear at the time, date, and place set forth below to testify at an examination under Rule 2004, Federal Rules of Bankruptcy Procedure. A copy of the court order authorizing the examination is attached.\n\n| PLACE                    | DATE AND TIME |\n|--------------------------|---------------|\n| Paul Hastings LLP        |               |\n| 200 Park Avenue          | [TBD]         |\n| New York, New York 10166 |               |\n|                          |               |\n\nThe examination will be recorded by this method: **Court reporter/stenographer**\n\n*Production:* You, or your representatives, must also bring with you to the examination the following documents, electronically stored information, or objects, and must permit inspection, copying, testing, or sampling of the material:\n\n#### **See Requests for Production of Documents, attached hereto.**\n\nThe following provisions of Fed. R. Civ. P. 45, made applicable in bankruptcy cases by Fed. R. Bankr. P. 9016, are attached – Rule 45(c), relating to the place of compliance; Rule 45(d), relating to your protection as a person subject to a subpoena; and Rule 45(e) and 45(g), relating to your duty to respond to this subpoena and the potential consequences of not doing so.\n\nDate: **March , 2023**\n\nCLERK OF COURT\n\nOR\n\n*Signature of Clerk or Deputy Clerk Attorney's signature*\n\nThe name, address, email address, and telephone number of the attorney representing Luc A. Despins, Chapter 11 Trustee, who issues or requests this subpoena, are:\n\n**Douglas S. Skalka, Esq.; Neubert, Pepe & Monteith, P.C.; 195 Church Street, New Haven, Connecticut 06510 dskalka@npmlaw.com; (203) 821-2000**\n\n**Notice to the person who issues or requests this subpoena**\n\nIf this subpoena commands the production of documents, electronically stored information, or tangible things, or the inspection of premises before trial, a notice and a copy of this subpoena must be served on each party before it is served on the person to whom it is directed. Fed. R. Civ. P. 45(a)(4).\n\nSoftware Copyright (c) 1996-2022 Best Case, LLC - www.bestcase.com Best Case Bankruptcy 1 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\n#### **PROOF OF SERVICE**\n\n**(This section should not be filed with the court unless required by Fed. R. Civ. P. 45.)**\n\nI received this subpoena for (*name of individual and title, if any*): on (*date*) .\n\nI served the subpoena by delivering a copy to the named person as follows:\n\non *(date)* ; or\n\nI returned the subpoena unexecuted because:\n\nUnless the subpoena was issued on behalf of the United States, or one of its officers or agents, I have also tendered to the witness the fees for one day's attendance, and the mileage allowed by law, in the amount of \\$ .\n\nMy fees are \\$ for travel and \\$ for services, for a total of \\$ .\n\nI declare under penalty of perjury that this information is true and correct.\n\nDate:\n\n*Server's signature*\n\n*Printed name and title*\n\n*Server's address*\n\nAdditional information concerning attempted service, etc.:\n\n#### **Federal Rule of Civil Procedure 45(c), (d), (e), and (g) (Effective 12/1/13) (made applicable in bankruptcy cases by Rule 9016, Federal Rules of Bankruptcy Procedure)**\n\n#### **(c) Place of compliance.**\n\n*(1) For a Trial, Hearing, or Deposition.* A subpoena may command a person to attend a trial, hearing, or deposition only as follows:\n\n(A) within 100 miles of where the person resides, is employed, or regularly transacts business in person; or\n\n(B) within the state where the person resides, is employed, or regularly transacts business in person, if the person\n\n(i) is a party or a party's officer; or\n\n(ii) is commanded to attend a trial and would not incur substantial expense.\n\n*(2) For Other Discovery.* A subpoena may command:\n\n(A) production of documents, or electronically stored information, or things at a place within 100 miles of where the person resides, is employed, or regularly transacts business in person; and\n\n(B) inspection of premises, at the premises to be inspected.\n\n#### **(d) Protecting a Person Subject to a Subpoena; Enforcement.**\n\n*(1) Avoiding Undue Burden or Expense; Sanctions.* A party or attorney responsible for issuing and serving a subpoena must take reasonable steps to avoid imposing undue burden or expense on a person subject to the subpoena. The court for the district where compliance is required must enforce this duty and impose an appropriate sanction which may include lost earnings and reasonable attorney's fees — on a party or attorney who fails to comply.\n\n#### *(2) Command to Produce Materials or Permit Inspection.*\n\n*(A) Appearance Not Required.* A person commanded to produce documents, electronically stored information, or tangible things, or to permit the inspection of premises, need not appear in person at the place of production or inspection unless also commanded to appear for a deposition, hearing, or trial.\n\n*(B) Objections.* A person commanded to produce documents or tangible things or to permit inspection may serve on the party or attorney designated in the subpoena a written objection to inspecting, copying, testing or sampling any or all of the materials or to inspecting the premises — or to producing electronically stored information in the form or forms requested. The objection must be served before the earlier of the time specified for compliance or 14 days after the subpoena is served. If an objection is made, the following rules apply:\n\n(i) At any time, on notice to the commanded person, the serving party may move the court for the district where compliance is required for an order compelling production or inspection.\n\n(ii) These acts may be required only as directed in the order, and the order must protect a person who is neither a party nor a party's officer from significant expense resulting from compliance.\n\n#### *(3) Quashing or Modifying a Subpoena.*\n\n*(A) When Required.* On timely motion, the court for the district where compliance is required must quash or modify a subpoena that:\n\n(i) fails to allow a reasonable time to comply;\n\n(ii) requires a person to comply beyond the geographical limits specified in Rule 45(c);\n\n(iii) requires disclosure of privileged or other protected matter, if no exception or waiver applies; or\n\n(iv) subjects a person to undue burden.\n\n*(B) When Permitted.* To protect a person subject to or affected by a subpoena, the court for the district where compliance is required may, on motion, quash or modify the subpoena if it requires:\n\n(i) disclosing a trade secret or other confidential research, development, or commercial information; or\n\n(ii) disclosing an unretained expert's opinion or information that does not describe specific occurrences in dispute and results from the expert's study that was not requested by a party.\n\n(C) *Specifying Conditions as an Alternative.* In the circumstances described in Rule 45(d)(3)(B), the court may, instead of quashing or modifying a subpoena, order appearance or production under specified conditions if the serving party:\n\n(i) shows a substantial need for the testimony or material that cannot be otherwise met without undue hardship; and\n\n(ii) ensures that the subpoenaed person will be reasonably compensated.\n\n#### **(e) Duties in Responding to a Subpoena.**\n\n*(1) Producing Documents or Electronically Stored Information.* These procedures apply to producing documents or electronically stored information:\n\n*(A) Documents.* A person responding to a subpoena to produce documents must produce them as they are kept in the ordinary course of business or must organize and label them to correspond to the categories in the demand.\n\n*(B) Form for Producing Electronically Stored Information Not Specified.* If a subpoena does not specify a form for producing electronically stored information, the person responding must produce it in a form or forms in which it is ordinarily maintained or in a reasonably usable form or forms.\n\n*(C) Electronically Stored Information Produced in Only One Form.* The person responding need not produce the same electronically stored information in more than one form.\n\n*(D) Inaccessible Electronically Stored Information.* The person responding need not provide discovery of electronically stored information from sources that the person identifies as not reasonably accessible because of undue burden or cost. On motion to compel discovery or for a protective order, the person responding must show that the information is not reasonably accessible because of undue burden or cost. If that showing is made, the court may nonetheless order discovery from such sources if the requesting party shows good cause, considering the limitations of Rule 26(b)(2)(C). The court may specify conditions for the discovery.\n\n#### *(2) Claiming Privilege or Protection.*\n\n*(A) Information Withheld.* A person withholding subpoenaed information under a claim that it is privileged or subject to protection as trial-preparation material must: (i) expressly make the claim; and\n\n(ii) describe the nature of the withheld documents, communications, or tangible things in a manner that, without revealing information itself privileged or protected, will enable the parties to assess the claim.\n\n*(B) Information Produced.* If information produced in response to a subpoena is subject to a claim of privilege or of protection as trial-preparation material, the person making the claim may notify any party that received the information of the claim and the basis for it. After being notified, a party must promptly return, sequester, or destroy the specified information and any copies it has; must not use or disclose the information until the claim is resolved; must take reasonable steps to retrieve the information if the party disclosed it before being notified; and may promptly present the information under seal to the court for the district where compliance is required for a determination of the claim. The person who produced the information must preserve the information until the claim is resolved.\n\n**(g) Contempt.** The court for the district where compliance is required – and also, after a motion is transferred, the issuing court – may hold in contempt a person who, having been served, fails without adequate excuse to obey the subpoena or an order related to it.\n\nFor access to subpoena materials, see Fed.R.Civ.P.45(a) Committee Note (2013)\n\n…\n\n## **Requests for Production of Documents**\n\n## **I. INSTRUCTIONS**\n\n1. Unless otherwise indicated, the requests for documents set forth below, (the \"Requests,\" and each, a \"Request\"), must be responded to separately and specifically. Each Request shall be answered fully unless it is in good faith objected to, in which event the reason for Your objection shall be stated in detail, as set forth below. If an objection pertains only to a portion of a Request, or a word, phrase or clause contained within it, You are required to state Your objection to that portion only and to respond to the remainder of the Requests.\n\n2. Electronically stored information must be produced in accordance with the\n\nfollowing instructions:\n\n- a. Images. Black and white images must be 300 DPI Group IV single-page TIFF files. Color images must be produced in JPEG format. File names cannot contain embedded spaces or special characters (including the comma). Folder names cannot contain embedded spaces or special characters (including the comma). All TIFF image files must have a unique file name, i.e. Bates number. Images must be endorsed with sequential Bates numbers in the lower right corner of each image. The number of TIFF files per folder should not exceed 1000 files. Excel spreadsheets should have a placeholder image named by the Bates number of the file.\n- b. Image Load File\n\t- a. Concordance® Data File. The data file (.DAT) contains all of the fielded information that will be loaded into the Concordance® database. The first line of the .DAT file must be a header row identifying the field names. The .DAT file must use the following Concordance® default delimiters: Comma ASCII character (020) Quote þ ASCII character (254). Date fields should be provided in the format: mm/dd/yyyy. Date and time fields must be two separate fields. If documents includes imaged emails and attachments, the attachment fields must be included to preserve the parent/child relationship between an email and its attachments. An OCRPATH field must be included to provide the file path and name of the extracted text file on the produced storage media. The text file must be named after the FIRSTBATES. Do not include the text in the .DAT file. For Documents with native files, a LINK field must be included to provide the file path and\n\nname of the native file. The native file must be named after the FIRSTBATES.\n\n- b. Concordance Image® OR Opticon Cross-Reference File. The image crossreference file (.LOG or .OPT) links the images to the database records. It should be a comma-delimited file consisting of seven fields per line with a line in the cross-reference file for every image in the database with the following format: ImageID,VolumeLabel,ImageFilePath,DocumentBreak,FolderBreak,Box Break,PageCoun.\n- c. Document Text. Text must be produced as separate text files, not as fields within the .DAT file. The full path to the text file (OCRPATH) should be included in the .DAT file. It is recommended document level ANSI text files, named per the FIRSTBATES/Image Key. Extracted text files must be in a separate folder, and the number of text files per folder should not exceed 1,000 files. There should be no special characters (including commas in the folder names). Text files must be provided on a document level.\n- d. Native Production for Certain File Types. File types that reasonably require viewing in their native format for a full understanding of their content and meaning must be produced in native format. These include, but are not limited to, spreadsheets, spreadsheet-like files (Microsoft Excel, comma separated values, tab separated values, etc.), Microsoft PowerPoint or other special presentation files, database files, and audio/visual files. Provide an image of a Bates numbered slip sheet indicating the presence of a native file, and include the path to the native as a field in the .dat file. Name the produced native file with the Bates number corresponding to the slip sheet for the file. Group native files within incrementally named \"NATIVE\" directories, separate from images directories.\n- e. De-duplication. Produce a single copy of each electronic document for which exact duplicates exist. For email messages, consolidate duplicates based on MD5 hash generated from the BCC, Body, CC, From, IntMsgID, To, and Attach properties. For email attachments and standalone electronic files, consolidate duplicates based on MD5 hash of the entire file.\n- f. Metadata. Produce extracted metadata for each document in the form of a Concordance compliant load file (.dat). The first line of the .DAT file must be a header row identifying the field names. The .DAT file must use the following Concordance default delimiters: Comma , ASCII character (020) Quote þ ASCII character (254)\n\nDate fields should be provided in the format: mm/dd/yyyy. Date and time fields must be two separate fields. Required metadata listed below:\n\n# Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 898 of 1063\n\n| Field Name   | Sample Data              | Description                                                                                  |\n|--------------|--------------------------|----------------------------------------------------------------------------------------------|\n| FIRSTBATES   | EDC0000001               | First Bates number of native file document/email                                             |\n| LASTBATES    | EDC0000001               | Last Bates number of native file document/email<br>**The LASTBATES field should be populated |\n|              |                          | for single page                                                                              |\n| ATTACHRANGE  | EDC0000001<br>-          | Bates number of the first page of the parent                                                 |\n|              | EDC0000015               | document to the Bates number of the last page of                                             |\n|              |                          | the last attachment \"child\" document                                                         |\n| BEGATTACH    | EDC0000001               | First Bates number of attachment range                                                       |\n| ENDATTACH    | EDC0000015               | Last Bates number of attachment range                                                        |\n| CUSTODIAN    | Smith, John              | Email: Mailbox where the email resided                                                       |\n|              |                          | Native: Name of the individual or department                                                 |\n|              |                          | from whose files the document<br>originated                                                  |\n| FROM         | John Smith               | Email: Sender                                                                                |\n|              |                          | Native: Author(s) of document                                                                |\n|              |                          | **semi-colon should be used to separate                                                      |\n|              |                          | multiple entries                                                                             |\n| TO           | Coffman, Janice; LeeW    | Recipient(s)                                                                                 |\n|              | [mailto:LeeW@MSN.com]    | **semi-colon should be used to separate multiple                                             |\n|              |                          | entries                                                                                      |\n| CC           | Frank Thompson [mailto:  | Carbon copy recipient(s)                                                                     |\n|              | frank_Thompson@cdt.com]  | **semi-colon should be used to separate                                                      |\n|              |                          | multiple entries                                                                             |\n| BCC          | John Cain                | Blind carbon copy recipient(s)                                                               |\n|              |                          | **semi-colon should be used to separate                                                      |\n|              |                          | multiple entries                                                                             |\n| SUBJECT      | Board Meeting Minutes    | Email: Subject line of the email Native: Title                                               |\n|              |                          | of document (if available)                                                                   |\n| FILE_NAME    | BoardMeetingMinutes.docx | Native: Name of the original native file,                                                    |\n|              |                          | including extension                                                                          |\n| DATE_SENT    | 10/12/2010               | Email: Date the email was sent                                                               |\n|              |                          | Native: (empty)                                                                              |\n| TIME_SENT/   | 07:05 PM GMT             | Email: Time the email was sent/ Time zone in                                                 |\n| TIME_ZONE    |                          | which the emails were standardized                                                           |\n| TIME_ZONE    | GMT                      | The<br>time zone in which<br>the emails<br>were                                              |\n|              |                          | standardized during conversion.                                                              |\n| LINK         |  EDC0000001.msg   | Hyperlink to the email or native file document                                               |\n|              |                          | **The linked file must be named per the                                                      |\n|              |                          | FIRSTBATES number                                                                            |\n| FILE_EXTEN   | MSG                      | The file type extension                                                                      |\n|              |                          | representing                                                                                 |\n|              |                          | the Email or                                                                                 |\n| AUTHOR       | John Smith               | Email: (empty)                                                                               |\n|              |                          | Native: Author of the document                                                               |\n| DATE_CREATED | 10/10/2010               | Email: (empty)                                                                               |\n|              |                          | Native: Date the document was created                                                        |\n\n# Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 899 of 1063\n\n| TIME_CREATED | 10:25 AM                  | Email: (empty)                                  |\n|--------------|---------------------------|-------------------------------------------------|\n|              |                           | Native: Time the document was created           |\n|              |                           | **This data must be a separate field and cannot |\n|              |                           | be combined with the DATE_CREATED field         |\n| DATE_MOD     | 10/12/2010                | Email: (empty)                                  |\n|              |                           | Native: Date the document was last modified     |\n| TIME_MOD     | 07:00 PM                  | Email: (empty)                                  |\n|              |                           | Native: Time the document was last modified     |\n|              |                           | **This data must be a separate field and cannot |\n|              |                           | be combined with the DATE_MOD field             |\n| DATE_ACCESSD | 10/12/2010                | Email: (empty)                                  |\n|              |                           | Native: Date the document was last accessed     |\n| TIME_ACCESSD | 07:00 PM                  | Email: (empty)                                  |\n|              |                           | Native: Time the document was last accessed     |\n|              |                           | **This data must be a separate field and cannot |\n|              |                           | be combined with the DATE_ACCESSD field         |\n| FILE_SIZE    | 5,952                     | Size of native file<br>document/email in KB     |\n| PGCOUNT      | 1                         | Number of pages in native file document/email   |\n| PATH         |   | Email: (empty)                                  |\n|              | Agenda.doc                | Native: Path where native file document was     |\n|              |                           | stored including original file name.            |\n| INTFILEPATH  | Personal Folders\\Deleted  | Email: original location of email including     |\n|              | Items\\Board Meeting       | original file name.                             |\n|              | Minutes.msg               | Native: (empty)                                 |\n| INTMSGID     | <000805c2c71b\\$75977050\\$ | Email: Unique Message ID Native: (empty)        |\n|              | cb8306d1@MSN>             |                                                 |\n| MD5HASH      | d131dd02c5e6eec4693d9a0   | MD5 Hash value of the document.                 |\n|              | 698aff95c                 |                                                 |\n|              | 2fcab58712467eab4004583e  |                                                 |\n|              | b8fb7f89                  |                                                 |\n| OCRPATH      | TEXT/001/EDC0000001.txt   | Path to extracted text of the native file       |\n\n3. Each Request operates and should be construed independently and, unless otherwise indicated, no Request limits the scope of any other Request.\n\n4. All Documents are to be produced as kept in the usual course of business or are to be organized and labeled to correspond with the categories in these Requests.\n\n5. Each Request contained herein extends to all Documents: (a) in Your possession, custody, or control; or (b) in the possession, custody, or control of anyone acting on Your behalf,\n\n#### Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 900 of 1063\n\nincluding Your counsel or other representatives and advisors. Each Document shall be produced in its entirety.\n\n6. If You are requested to produce a Document that is no longer in Your possession, custody, or control, then Your response must (a) describe in detail the nature of the document and its contents; (b) identify the person(s) who prepared or authored the Document (and, if applicable, the Person(s) to whom the Document was sent); (c) identify the date on which the document was prepared or created; (d) state whether such Document (i) is missing or lost, (ii) has been destroyed, (iii) has been transferred, voluntarily or involuntarily, to others, or (iv) was otherwise disposed of; (e) state the reason for, and the facts and circumstances surrounding, such disposition; (f) identify the Persons who authorized such disposition; (g) identify the date or approximate date of such disposition; (h) state when the Document was most recently in Your possession, custody or control; and (i) identify the Person, if any, presently in possession, custody, or control of such Document.\n\n7. If You are requested to produce a Document that has been destroyed, then Your response must state, in addition to the information required by the preceding Instruction: (a) the reason for the Document's destruction; (b) the identity of the Person who destroyed the Document; and (c) the identity of the Person who directed that the Document be destroyed.\n\n8. If You claim that a requested Document is privileged or attorney work-product, then Your response must: (a) state (i) a description of the Document adequate to support Your contention that the Document is privileged, (ii) the title of the Document, (iii) the date of the Document, (iv) the author of the Document, (v) the addressee of the Document, (vi) the identity of each Person who received or saw the original or any draft, copy, or reproduction of the Document, (vii) whether the Document itself, or any information contained or referred to in the Document is in the possession, custody, or control of any other Persons, and if so, the identity of\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 901 of 1063\n\nsuch Persons, as well as a statement addressing how the information came into their possession, (viii) the claim of privilege under which the Document is withheld, and (ix) all of the circumstances upon which You will rely to support such claim of privilege; and (b) produce a privilege log containing all of the information requested in Part (a) of this Instruction for each Document withheld on the basis of a claim of privilege in accordance with D. Conn. L. Civ. R. 26(e).\n\n9. If a portion of an otherwise responsive Document contains information subject to a claim of privilege, only that portion of the Document subject to the claim of privilege shall be deleted or redacted from the Document following the instructions above, and the rest shall be produced.\n\n10. The Requests are continuing in nature. You are hereby instructed to (a) supplement or correct any responses later learned to be incomplete or incorrect immediately upon learning that a prior response was incomplete or incorrect; and (b) produce any additional Documents that are called for under the\n\n11. If a Document is in a language other than English, You should provide that Document. If a Document is in a language other than English, and an English translation exists, You should provide both Documents.\n\n12. All references to Entities includes all affiliates thereof.\n\n13. All references to individual names include all alternative names, aliased, or nicknames.\n\n14. Unless otherwise expressly indicated, the period of time covered by the Document Requests is the period from February 5, 2012 to the date responses to the Document Requests are due.\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 902 of 1063\n\n#### **II. RULES OF CONSTRUCTION**\n\n15. The use of (a) any singular noun shall be construed to include the plural, and vice versa, and (b) a verb in any tense shall be construed as the use of the verb in all other tenses.\n\n16. The terms (a) \"and\" and \"or\" shall be construed either conjunctively or disjunctively as necessary to bring within the scope of any request all responses that might otherwise be construed to be outside of its scope, and (b) \"each\" and \"any\" shall be deemed to include and encompass the words \"every\" and \"all.\"\n\n#### **III. DEFINITIONS**\n\nThe definitions supplied by D. Conn. L. Civ. R. 26(c) and the rules of construction supplied by D. Conn. L. Civ. R. 26(d), as incorporated by D. Conn. Bankr. L.R. 2004-1(a), shall apply to the Document Requests. In addition, the following terms used in these Document Requests shall have the following meanings:\n\n1. \"You\" or \"Your\" or \"Yourself\" means and refers to Pixshow Film Inc., together with all of its affiliates, divisions, agencies, instrumentalities, departments, offices, partners, officers, directors, agents, attorneys, representatives, employees, and/or anyone acting on its behalf.\n\n2. \"Debtor\" means Ho Wan Kwok (a/k/a Miles Kwok, Miles Guo, Guo Wengui, Guo Haoyun, 郭文贵, or any other alias), together with his employees, agents, counsel, advisors, or anyone acting on his behalf.\n\n3. \"Debtor's Son\" means Qiang Guo (a/k/a Mileson Kwok, 郭强, or any other alias), together with his employees, agents, counsel, advisors, or anyone acting on his behalf.\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 903 of 1063\n\n4. \"Debtor's Daughter\" means Mei Guo (a/k/a Mei Gui, 郭美, or any other alias), together with her employees, agents, counsel, advisors, or anyone acting on her behalf.\n\n5. \"Debtor's Purported Wife\" means Hing Chi Ngok (a/k/a Hing Chi Ng, Yue Qingzhi, 岳庆芝, or any other alias), together with her employees, agents, counsel, advisors, or anyone acting on her behalf.\n\n6. \"Debtor's Family\" means, collectively, the Debtor, the Debtor's Son, the Debtor's Daughter, and the Debtor's Purported Wife, and any other familial relation to the Debtor.\n\n7. \"Associated Individuals\" means, individually and collectively, all individuals that (1) hold, control, have custody over, or discretion over assets owned, controlled, or enjoyed by the Debtor or the Debtor's Family; or (2) have been employees, directors, or otherwise are affiliated with one or more Associated Entities, together with the respective employees, agents, counsel, advisors, or anyone acting on behalf of any of the foregoing. Such Associated Individuals shall include, but are not limited to: Daniel Podhaskie, Jason Miller, Steve Bannon, Karin Maistrello, Melissa Francis, Anthony DiBattista, William Gertz, Arethusa Forsyth, Glenn Mellor, Jennifer Mercurio, Eduardo Eurnekian, Wencong Wang, Han Chunguang (a/k/a 韩春光), Qu Guojiao (a/k/a Qu Guo Jiao, 屈国姣), Guo Lijie (a/k/a 郭丽杰), Zhang Wei (a/k/a 张伟\\*), Lihong Wei Lafrenz (a/k/a Sara Wei, 魏丽红), Hao Haidong (a/k/a 郝海东), Ross Heinemeyer, Max Krasner, Kyle Bass, Melissa Mendez, Ya Li (a/k/a 李娅), Dinggang Wang (a/k/a 王定刚), An Hong (a/k/a 安红), Yvette Wang (a/k/a Yanping Wang, Yan Ping Wang, 王雁平), Fiona Yu, Je Kin Ming (a/k/a William Je, Yu Jianming, 余建明), Yaz Qingua, and Lao Jiang (a/k/a Jiang Yunfu, Jiang Yunfu Be, 姜云浮).\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 904 of 1063\n\n8. \"Associated Entities\" means, individually and collectively, all organizations or Entities of any type that (1) have been owned, controlled, or invested in by the Debtor or the Debtor's Family; or (2) have an interest, whether directly or indirectly, in any assets owned, controlled, or enjoyed by the Debtor or the Debtor's Family, together with the respective employees, agents, counsel, advisors, or anyone acting on behalf of any of the foregoing. Such Associated Entities shall include, but are not limited to: 7 Nod Hill LLC, AAGV Limited, ACA Investment Management Limited, ACA Capital Group Limited, Ace Decade Holdings Limited, AI Group Holdings Inc., Alfa Global Ventures Limited, Alfonso Global Limited, Allied Capital Global Limited, Alpine Fiduciaries SA, Anton Development Limited, Assets Sino Limited, Auspicious Coast Limited, Beijing Pangu Investment Co., Beijing Pangu Investment Co. Ltd., Beijing Pangu Investment Inc., Beijing Zenith Holdings Company Limited, Booming Sail New York LLC, Bravo Luck Limited, BSA Strategic Fund I, China Golden Spring (Hong Kong) Limited, Chuang Xin Limited, Crane Advisory Group LLC, Creative Apex Investments Limited, Crystal Breeze Investments Limited, Dawn State Limited, Eastern Profit Corporation Limited, Elite Well Global Limited, Empire Growth Holdings, Freedom Media Ventures Ltd., G Club Operations LLC, G Fashion LLC, G News LLC, GETTR USA, Genever Holdings Corporation, Genever Holdings LLC, Gfashion Media Group Inc., GFNY, Inc., Globalist International Limited, GNews Media Group Inc., Golden Spring (New York) Ltd., Greenwich Land LLC, Guo Media, GTV Media Group, Inc., Hamilton Capital Holdings Inc., HCHK Property Management, Inc., HCHK Technologies, Inc., Head Win Group Limited, Henan Yuda, Himalaya Embassy, Himalaya Exchange, Himalaya Federal Reserve, Himalaya Investment LLC, Himalaya International, Himalaya New World Inc., Himalaya Supervisory Organization, Himalaya Ventures LLC, HK International Funds Investments (USA) Limited LLC, Hong Kong International Funds\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 905 of 1063\n\nInvestments Limited, Hudson Diamond Holding, Infinite Increase Limited, Infinitum Developments Limited, Infinity Treasury Management Inc., Insight Phoenix Fund, Lamp Capital LLC, Leading Shine Limited, Leading Shine NY Limited, Lexington Property and Staffing, Long Gate Limited, Maywind Trading LLC, MOS Himalaya LLC, Next Tycoon Investments Limited, New Federal State of China (a/k/a NFSC), Noble Fame Global Limited, Rosy Acme Ventures Limited, Rule of Law Foundation III, Inc., Rule of Law Foundation IV, Inc., Rule of Law Fund, Rule of Law Society, Rule of Law Society IV, Inc., G-Translators PTY LTD, Saraca Media Group, Inc., Shiny Ace Ltd., Shiny Times Holdings Ltd., Spirit Charter Investment Limited, Stevenson, Wong & Co., Voice of Guo Media, Inc., Well Origin Ltd., World Century Limited, Worldwide Opportunity Holdings Limited, Whitecroft Shore Limited, and ZIBA Limited.\n\n9. \"Including\" or any variant thereof means \"including without limitation.\"\n\n10. \"And\" and \"or\" mean \"and/or,\" and shall be construed both conjunctively as well as disjunctively in order to maximize their scope.\n\n11. \"Any\" and \"all\" and \"each\" mean \"each and every.\"\n\n12. \"Each\" and \"every\" mean \"each and every.\"\n\n13. \"Third Party\" means a Person or Entity other than Yourself.\n\n14. \"Transfer\" shall have the meaning given to it by section 101(54) of the Bankruptcy Code.\n\n15. \"Document\" means any information or thing within the scope of Fed. R. Civ. P. 34, and includes, without limitation, each and every written, recorded, or graphic matter of any kind, type, nature, or description that is or has been in Your Possession, Custody or Control, including all printed and electronic copies of electronic mail, computer files maintained in\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 906 of 1063\n\nelectronic form, electronic communication, text message, social media post, tweet, meta-data, correspondence, memoranda, tapes, stenographic or handwritten notes, written forms of any kind, charts, blueprints, drawings, sketches, graphs, plans, articles, specifications, diaries, letters, telegrams, photographs, minutes, contracts, agreements, surveys, computer printouts, data compilations of any kind, telexes, facsimiles, voice messages, invoices, order forms, checks, drafts, statements, credit memos, reports, position reports, summaries, indices, books, ledgers, notebooks, schedules, transparencies, recordings, catalogs, advertisements, promotional materials, films, video tapes, audio tapes, CDs, computer disks, brochures, pamphlets, punchcards, time-slips, Tweets, social media posts, or any written or recorded materials of any other kind, and all meta-data thereof, however stored (whether in tangible or electronic form), recorded, produced, or reproduced, and also including but not limited to, drafts or copies of any of the foregoing that contain any notes, comments, or markings of any kind not found on the original documents or that are otherwise not identical to the original documents.\n\n16. \"Person(s)\" means an individual, corporation, proprietorship, partnership, association, or any other Entity. \"Person\" also includes any agent, representatives, or expert, including but not limiting to, attorneys or financial advisors.\n\n17. \"Entity\" means any natural Person, corporation, partnership, subsidiary, sole proprietorship, firm, board, joint venture, association, agency, authority, commission or other business entity or juristic Person, as well as any affiliate, agent, parent including but not limited to legal counsel, financial advisors, or any other representative.\n\n18. \"Regarding\" means concerning, describing, comprising, referring to, related to, supporting, favoring, opposing, bolstering, detracting from, located in, considered in connection with, bearing on, evidencing, indicating, reporting on, recording, alluding to, responding to,\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 907 of 1063\n\nconnected with, commenting on, in respect of, about, in relation to, discussing, showing, describing, reflecting, analyzing constituting, and being.\n\n19. \"Relating to,\" \"relate(s) to\" or \"related to,\" when referring to any given subject matter, means, without limitation, any document that constitutes, comprises, involves, contains, embodies, reflects, identifies, states, refers directly or indirectly to, or is in any way relevant to the particular subject matter identified.\n\n20. \"Communication(s)\" means, in the broadest possible sense, and without limitation, any transmittal of information or knowledge (in the form of facts, ideas, inquiries, or otherwise). Communication(s) further refers to all conversations, agreements, inquiries, or replies, whether in person, by telephone, in writing, or by means of electronic transmittal devices, and includes, but is not limited to, all correspondence, emails, recordings, transmittal slips, memoranda, telephone communications, voice messages, telegrams, telefaxes, telecopies, telexes, instant messages, chats, text messages, telephonic notes, or notes transmitted internally or with third parties.\n\n21. \"Asset(s)\" means any item that can be used to produce positive economic value, including but not limited to any resource with economic value that is owned, controlled or is for the benefit of an entity, that is expected to provide a future benefit, including but not limited to, all real and personal property, intangible property, investments, rights to invest or to future revenue, cash, bank accounts, commodities, securities, claims, total or partial control of an entity, and prospective economic opportunities\n\n22. \"Transfer\" shall have the meaning given to it by section 101(54) of the Bankruptcy Code.\n\n#### **IV. DOCUMENTS TO BE PRODUCED**\n\n1. All Documents regarding any income or Asset of the Debtor, the Debtor's estate, or an Associated Entity.\n\n2. All Documents related to the Debtor's financial condition and obligations to his creditors, including without limitation all Documents related to any effort to avoid paying such obligations and All Documents related to this or any other actual or potential bankruptcy or similar insolvency proceeding.\n\n3. All Documents regarding any balance sheet, bank statement, account statement, financial statement, statement of account, wire transfer instructions and/or confirmation, proof of funds, certificate of deposit, certificate of holdings, investment portfolio summary, or similar document relating to the Debtor, the Debtor's Estate, the Debtor's Family, an Associated Entity, or an Associated Individual, including without limitation all Documents sufficient to show all Transfers to any of the foregoing.\n\n4. All Documents regarding any investment, business dealing or transactions made by, with, or on behalf of the Debtor.\n\n5. All Communications with the Debtor, and Documents related to Communications with the Debtor, related to the operation, management, or decision-making of any Entity, including without limitation the Associated Entities.\n\n6. All Documents regarding any Transfer, investment, or other transaction or business dealing made to, by, or with the Debtor, the Debtor's Family, or an Associated Entity.\n\n7. All Documents regarding any property ever occupied or used by the Debtor, including without limitation the *Lady May*; the Sherry Netherland Hotel / Condominium; the\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 909 of 1063\n\nresidential property located in Greenwich, Connecticut at 373 Taconic Rd.; the residential property located in Greenwich, Connecticut at 33 Ferncliff Rd.; and the residential property located in Wilton, Connecticut at 354 Nod Hill Rd.\n\n8. All Documents related to any aircraft owned, controlled, or used by the Debtor, including without limitation the aircraft bearing tail number T7-GQM and any other aircraft registered in San Marino, including without limitation copies of all registration documents and flight manifests showing flights taken by such aircraft and the individuals onboard such flights.\n\n9. All Documents regarding any gifts, benefits or loans, to, from or on behalf of the Debtor, the Debtor's Estate, the Debtor's Family, or the Associated Entities, including without limitation Documents sufficient to show the amounts of such gifts, benefits, or loans; the purposes for which such gifts, benefits, or loans were used; when the gifts, benefits, or loans were provided; and the terms of any loans, all representations and warranties made in connection with any loans, the interest rate on any loans, and all evidence of payments of any loans.\n\n10. All Documents concerning any trust or similar instrument set up by, on behalf of, or for the benefit of the Debtor, the Debtor's Estate, the Debtor's Family, or an Associated Entity, including without limitation Documents sufficient to show when the trust(s) was created, by whom it was created, for whose benefit it was created, and the corpus of the trust.\n\n11. All Documents related to any obligation, claim, liability, or debt associated with any legal dispute involving the Debtor, including but not limited to those relating to any litigation before any local, state, federal, or international body, whether an administrative body, court, panel, or alternative dispute resolution entity.\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 910 of 1063\n\n12. All Documents and communications between any of your outside counsel or other advisors and the Debtor.\n\n13. Documents sufficient to show all of Your Assets and sources of income or funding.\n\n14. For all Assets identified in response to Request 14 having a value of more than \\$50,000, all (i) Documents related to Your acquisition of such Asset and (ii) Communications with the Debtor or the Debtor's Family regarding such Asset.\n\n15. Copies of Your tax returns.\n\n16. Documents sufficient to show all bank accounts and investment accounts within Your possession or control, including the balances of and transfers to and from each such account.\n\n17. All Documents regarding any credit cards used by You, including without limitation monthly statements or other Documents sufficient to show all purchases related thereto for the benefit of the Debtor or an Associated Entity.\n\n18. All corporate governance and organizational Documents, including without limitation by-laws and certificates of incorporation and other Documents sufficient to show Your corporate structure, names of officers and directors, business purpose, and relationship to the Debtor or to any member of the Debtor's Family.\n\n19. All Documents related to any pledge(s) of Your Assets to any other Entity.\n\n# Exhibit C-50\n\n#### B2540 (Form 2540 – Subpoena for Rule 2004 Examination) (12/15) Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 912 of\n\nUNITED STATES BANKRUPTCY COURT 1063\n\n**District of Connecticut**\n\nIn re HO WAN KWOK, *et al*.,\n\n<sup>1</sup> Case No. 22-50073 (JAM)\n\nDebtor Chapter 11\n\n(Jointly Administered)\n\n## **SUBPOENA FOR RULE 2004 EXAMINATION**\n\nTo: **Fung Wan Trading Inc.**\n\n(*Name of person to whom the subpoena is directed*)\n\n*Testimony:* **YOU ARE COMMANDED** to appear at the time, date, and place set forth below to testify at an examination under Rule 2004, Federal Rules of Bankruptcy Procedure. A copy of the court order authorizing the examination is attached.\n\n| PLACE                    | DATE AND TIME |\n|--------------------------|---------------|\n| Paul Hastings LLP        |               |\n| 200 Park Avenue          | [TBD]         |\n| New York, New York 10166 |               |\n|                          |               |\n\nThe examination will be recorded by this method: **Court reporter/stenographer**\n\n*Production:* You, or your representatives, must also bring with you to the examination the following documents, electronically stored information, or objects, and must permit inspection, copying, testing, or sampling of the material:\n\n#### **See Requests for Production of Documents, attached hereto.**\n\nThe following provisions of Fed. R. Civ. P. 45, made applicable in bankruptcy cases by Fed. R. Bankr. P. 9016, are attached – Rule 45(c), relating to the place of compliance; Rule 45(d), relating to your protection as a person subject to a subpoena; and Rule 45(e) and 45(g), relating to your duty to respond to this subpoena and the potential consequences of not doing so.\n\nDate: **March , 2023**\n\nCLERK OF COURT\n\nOR\n\n*Signature of Clerk or Deputy Clerk Attorney's signature*\n\nThe name, address, email address, and telephone number of the attorney representing Luc A. Despins, Chapter 11 Trustee, who issues or requests this subpoena, are:\n\n**Douglas S. Skalka, Esq.; Neubert, Pepe & Monteith, P.C.; 195 Church Street, New Haven, Connecticut 06510 dskalka@npmlaw.com; (203) 821-2000**\n\n**Notice to the person who issues or requests this subpoena**\n\nIf this subpoena commands the production of documents, electronically stored information, or tangible things, or the inspection of premises before trial, a notice and a copy of this subpoena must be served on each party before it is served on the person to whom it is directed. Fed. R. Civ. P. 45(a)(4).\n\nSoftware Copyright (c) 1996-2022 Best Case, LLC - www.bestcase.com Best Case Bankruptcy 1 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\n#### **PROOF OF SERVICE**\n\n**(This section should not be filed with the court unless required by Fed. R. Civ. P. 45.)**\n\nI received this subpoena for (*name of individual and title, if any*): on (*date*) .\n\nI served the subpoena by delivering a copy to the named person as follows:\n\non *(date)* ; or\n\nI returned the subpoena unexecuted because:\n\nUnless the subpoena was issued on behalf of the United States, or one of its officers or agents, I have also tendered to the witness the fees for one day's attendance, and the mileage allowed by law, in the amount of \\$ .\n\nMy fees are \\$ for travel and \\$ for services, for a total of \\$ .\n\nI declare under penalty of perjury that this information is true and correct.\n\nDate:\n\n*Server's signature*\n\n*Printed name and title*\n\n*Server's address*\n\nAdditional information concerning attempted service, etc.:\n\n#### **Federal Rule of Civil Procedure 45(c), (d), (e), and (g) (Effective 12/1/13) (made applicable in bankruptcy cases by Rule 9016, Federal Rules of Bankruptcy Procedure)**\n\n#### **(c) Place of compliance.**\n\n*(1) For a Trial, Hearing, or Deposition.* A subpoena may command a person to attend a trial, hearing, or deposition only as follows:\n\n(A) within 100 miles of where the person resides, is employed, or regularly transacts business in person; or\n\n(B) within the state where the person resides, is employed, or regularly transacts business in person, if the person\n\n(i) is a party or a party's officer; or\n\n(ii) is commanded to attend a trial and would not incur substantial expense.\n\n*(2) For Other Discovery.* A subpoena may command:\n\n(A) production of documents, or electronically stored information, or things at a place within 100 miles of where the person resides, is employed, or regularly transacts business in person; and\n\n(B) inspection of premises, at the premises to be inspected.\n\n#### **(d) Protecting a Person Subject to a Subpoena; Enforcement.**\n\n*(1) Avoiding Undue Burden or Expense; Sanctions.* A party or attorney responsible for issuing and serving a subpoena must take reasonable steps to avoid imposing undue burden or expense on a person subject to the subpoena. The court for the district where compliance is required must enforce this duty and impose an appropriate sanction which may include lost earnings and reasonable attorney's fees — on a party or attorney who fails to comply.\n\n#### *(2) Command to Produce Materials or Permit Inspection.*\n\n*(A) Appearance Not Required.* A person commanded to produce documents, electronically stored information, or tangible things, or to permit the inspection of premises, need not appear in person at the place of production or inspection unless also commanded to appear for a deposition, hearing, or trial.\n\n*(B) Objections.* A person commanded to produce documents or tangible things or to permit inspection may serve on the party or attorney designated in the subpoena a written objection to inspecting, copying, testing or sampling any or all of the materials or to inspecting the premises — or to producing electronically stored information in the form or forms requested. The objection must be served before the earlier of the time specified for compliance or 14 days after the subpoena is served. If an objection is made, the following rules apply:\n\n(i) At any time, on notice to the commanded person, the serving party may move the court for the district where compliance is required for an order compelling production or inspection.\n\n(ii) These acts may be required only as directed in the order, and the order must protect a person who is neither a party nor a party's officer from significant expense resulting from compliance.\n\n#### *(3) Quashing or Modifying a Subpoena.*\n\n*(A) When Required.* On timely motion, the court for the district where compliance is required must quash or modify a subpoena that:\n\n(i) fails to allow a reasonable time to comply;\n\n(ii) requires a person to comply beyond the geographical limits specified in Rule 45(c);\n\n(iii) requires disclosure of privileged or other protected matter, if no exception or waiver applies; or\n\n(iv) subjects a person to undue burden.\n\n*(B) When Permitted.* To protect a person subject to or affected by a subpoena, the court for the district where compliance is required may, on motion, quash or modify the subpoena if it requires:\n\n(i) disclosing a trade secret or other confidential research, development, or commercial information; or\n\n(ii) disclosing an unretained expert's opinion or information that does not describe specific occurrences in dispute and results from the expert's study that was not requested by a party.\n\n(C) *Specifying Conditions as an Alternative.* In the circumstances described in Rule 45(d)(3)(B), the court may, instead of quashing or modifying a subpoena, order appearance or production under specified conditions if the serving party:\n\n(i) shows a substantial need for the testimony or material that cannot be otherwise met without undue hardship; and\n\n(ii) ensures that the subpoenaed person will be reasonably compensated.\n\n#### **(e) Duties in Responding to a Subpoena.**\n\n*(1) Producing Documents or Electronically Stored Information.* These procedures apply to producing documents or electronically stored information:\n\n*(A) Documents.* A person responding to a subpoena to produce documents must produce them as they are kept in the ordinary course of business or must organize and label them to correspond to the categories in the demand.\n\n*(B) Form for Producing Electronically Stored Information Not Specified.* If a subpoena does not specify a form for producing electronically stored information, the person responding must produce it in a form or forms in which it is ordinarily maintained or in a reasonably usable form or forms.\n\n*(C) Electronically Stored Information Produced in Only One Form.* The person responding need not produce the same electronically stored information in more than one form.\n\n*(D) Inaccessible Electronically Stored Information.* The person responding need not provide discovery of electronically stored information from sources that the person identifies as not reasonably accessible because of undue burden or cost. On motion to compel discovery or for a protective order, the person responding must show that the information is not reasonably accessible because of undue burden or cost. If that showing is made, the court may nonetheless order discovery from such sources if the requesting party shows good cause, considering the limitations of Rule 26(b)(2)(C). The court may specify conditions for the discovery.\n\n#### *(2) Claiming Privilege or Protection.*\n\n*(A) Information Withheld.* A person withholding subpoenaed information under a claim that it is privileged or subject to protection as trial-preparation material must: (i) expressly make the claim; and\n\n(ii) describe the nature of the withheld documents, communications, or tangible things in a manner that, without revealing information itself privileged or protected, will enable the parties to assess the claim.\n\n*(B) Information Produced.* If information produced in response to a subpoena is subject to a claim of privilege or of protection as trial-preparation material, the person making the claim may notify any party that received the information of the claim and the basis for it. After being notified, a party must promptly return, sequester, or destroy the specified information and any copies it has; must not use or disclose the information until the claim is resolved; must take reasonable steps to retrieve the information if the party disclosed it before being notified; and may promptly present the information under seal to the court for the district where compliance is required for a determination of the claim. The person who produced the information must preserve the information until the claim is resolved.\n\n**(g) Contempt.** The court for the district where compliance is required – and also, after a motion is transferred, the issuing court – may hold in contempt a person who, having been served, fails without adequate excuse to obey the subpoena or an order related to it.\n\nFor access to subpoena materials, see Fed.R.Civ.P.45(a) Committee Note (2013)\n\n…\n\n## **Requests for Production of Documents**\n\n## **I. INSTRUCTIONS**\n\n1. Unless otherwise indicated, the requests for documents set forth below, (the \"Requests,\" and each, a \"Request\"), must be responded to separately and specifically. Each Request shall be answered fully unless it is in good faith objected to, in which event the reason for Your objection shall be stated in detail, as set forth below. If an objection pertains only to a portion of a Request, or a word, phrase or clause contained within it, You are required to state Your objection to that portion only and to respond to the remainder of the Requests.\n\n2. Electronically stored information must be produced in accordance with the\n\nfollowing instructions:\n\n- a. Images. Black and white images must be 300 DPI Group IV single-page TIFF files. Color images must be produced in JPEG format. File names cannot contain embedded spaces or special characters (including the comma). Folder names cannot contain embedded spaces or special characters (including the comma). All TIFF image files must have a unique file name, i.e. Bates number. Images must be endorsed with sequential Bates numbers in the lower right corner of each image. The number of TIFF files per folder should not exceed 1000 files. Excel spreadsheets should have a placeholder image named by the Bates number of the file.\n- b. Image Load File\n\t- a. Concordance® Data File. The data file (.DAT) contains all of the fielded information that will be loaded into the Concordance® database. The first line of the .DAT file must be a header row identifying the field names. The .DAT file must use the following Concordance® default delimiters: Comma ASCII character (020) Quote þ ASCII character (254). Date fields should be provided in the format: mm/dd/yyyy. Date and time fields must be two separate fields. If documents includes imaged emails and attachments, the attachment fields must be included to preserve the parent/child relationship between an email and its attachments. An OCRPATH field must be included to provide the file path and name of the extracted text file on the produced storage media. The text file must be named after the FIRSTBATES. Do not include the text in the .DAT file. For Documents with native files, a LINK field must be included to provide the file path and\n\nname of the native file. The native file must be named after the FIRSTBATES.\n\n- b. Concordance Image® OR Opticon Cross-Reference File. The image crossreference file (.LOG or .OPT) links the images to the database records. It should be a comma-delimited file consisting of seven fields per line with a line in the cross-reference file for every image in the database with the following format: ImageID,VolumeLabel,ImageFilePath,DocumentBreak,FolderBreak,Box Break,PageCoun.\n- c. Document Text. Text must be produced as separate text files, not as fields within the .DAT file. The full path to the text file (OCRPATH) should be included in the .DAT file. It is recommended document level ANSI text files, named per the FIRSTBATES/Image Key. Extracted text files must be in a separate folder, and the number of text files per folder should not exceed 1,000 files. There should be no special characters (including commas in the folder names). Text files must be provided on a document level.\n- d. Native Production for Certain File Types. File types that reasonably require viewing in their native format for a full understanding of their content and meaning must be produced in native format. These include, but are not limited to, spreadsheets, spreadsheet-like files (Microsoft Excel, comma separated values, tab separated values, etc.), Microsoft PowerPoint or other special presentation files, database files, and audio/visual files. Provide an image of a Bates numbered slip sheet indicating the presence of a native file, and include the path to the native as a field in the .dat file. Name the produced native file with the Bates number corresponding to the slip sheet for the file. Group native files within incrementally named \"NATIVE\" directories, separate from images directories.\n- e. De-duplication. Produce a single copy of each electronic document for which exact duplicates exist. For email messages, consolidate duplicates based on MD5 hash generated from the BCC, Body, CC, From, IntMsgID, To, and Attach properties. For email attachments and standalone electronic files, consolidate duplicates based on MD5 hash of the entire file.\n- f. Metadata. Produce extracted metadata for each document in the form of a Concordance compliant load file (.dat). The first line of the .DAT file must be a header row identifying the field names. The .DAT file must use the following Concordance default delimiters: Comma , ASCII character (020) Quote þ ASCII character (254)\n\nDate fields should be provided in the format: mm/dd/yyyy. Date and time fields must be two separate fields. Required metadata listed below:\n\n# Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 917 of 1063\n\n| Field Name   | Sample Data              | Description                                                                                  |\n|--------------|--------------------------|----------------------------------------------------------------------------------------------|\n| FIRSTBATES   | EDC0000001               | First Bates number of native file document/email                                             |\n| LASTBATES    | EDC0000001               | Last Bates number of native file document/email<br>**The LASTBATES field should be populated |\n|              |                          | for single page                                                                              |\n| ATTACHRANGE  | EDC0000001<br>-          | Bates number of the first page of the parent                                                 |\n|              | EDC0000015               | document to the Bates number of the last page of                                             |\n|              |                          | the last attachment \"child\" document                                                         |\n| BEGATTACH    | EDC0000001               | First Bates number of attachment range                                                       |\n| ENDATTACH    | EDC0000015               | Last Bates number of attachment range                                                        |\n| CUSTODIAN    | Smith, John              | Email: Mailbox where the email resided                                                       |\n|              |                          | Native: Name of the individual or department                                                 |\n|              |                          | from whose files the document<br>originated                                                  |\n| FROM         | John Smith               | Email: Sender                                                                                |\n|              |                          | Native: Author(s) of document                                                                |\n|              |                          | **semi-colon should be used to separate                                                      |\n|              |                          | multiple entries                                                                             |\n| TO           | Coffman, Janice; LeeW    | Recipient(s)                                                                                 |\n|              | [mailto:LeeW@MSN.com]    | **semi-colon should be used to separate multiple                                             |\n|              |                          | entries                                                                                      |\n| CC           | Frank Thompson [mailto:  | Carbon copy recipient(s)                                                                     |\n|              | frank_Thompson@cdt.com]  | **semi-colon should be used to separate                                                      |\n|              |                          | multiple entries                                                                             |\n| BCC          | John Cain                | Blind carbon copy recipient(s)                                                               |\n|              |                          | **semi-colon should be used to separate                                                      |\n|              |                          | multiple entries                                                                             |\n| SUBJECT      | Board Meeting Minutes    | Email: Subject line of the email Native: Title                                               |\n|              |                          | of document (if available)                                                                   |\n| FILE_NAME    | BoardMeetingMinutes.docx | Native: Name of the original native file,                                                    |\n|              |                          | including extension                                                                          |\n| DATE_SENT    | 10/12/2010               | Email: Date the email was sent                                                               |\n|              |                          | Native: (empty)                                                                              |\n| TIME_SENT/   | 07:05 PM GMT             | Email: Time the email was sent/ Time zone in                                                 |\n| TIME_ZONE    |                          | which the emails were standardized                                                           |\n| TIME_ZONE    | GMT                      | The<br>time zone in which<br>the emails<br>were                                              |\n|              |                          | standardized during conversion.                                                              |\n| LINK         |  EDC0000001.msg   | Hyperlink to the email or native file document                                               |\n|              |                          | **The linked file must be named per the                                                      |\n|              |                          | FIRSTBATES number                                                                            |\n| FILE_EXTEN   | MSG                      | The file type extension                                                                      |\n|              |                          | representing                                                                                 |\n|              |                          | the Email or                                                                                 |\n| AUTHOR       | John Smith               | Email: (empty)                                                                               |\n|              |                          | Native: Author of the document                                                               |\n| DATE_CREATED | 10/10/2010               | Email: (empty)                                                                               |\n|              |                          | Native: Date the document was created                                                        |\n\n# Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 918 of 1063\n\n| TIME_CREATED | 10:25 AM                  | Email: (empty)                                  |\n|--------------|---------------------------|-------------------------------------------------|\n|              |                           | Native: Time the document was created           |\n|              |                           | **This data must be a separate field and cannot |\n|              |                           | be combined with the DATE_CREATED field         |\n| DATE_MOD     | 10/12/2010                | Email: (empty)                                  |\n|              |                           | Native: Date the document was last modified     |\n| TIME_MOD     | 07:00 PM                  | Email: (empty)                                  |\n|              |                           | Native: Time the document was last modified     |\n|              |                           | **This data must be a separate field and cannot |\n|              |                           | be combined with the DATE_MOD field             |\n| DATE_ACCESSD | 10/12/2010                | Email: (empty)                                  |\n|              |                           | Native: Date the document was last accessed     |\n| TIME_ACCESSD | 07:00 PM                  | Email: (empty)                                  |\n|              |                           | Native: Time the document was last accessed     |\n|              |                           | **This data must be a separate field and cannot |\n|              |                           | be combined with the DATE_ACCESSD field         |\n| FILE_SIZE    | 5,952                     | Size of native file<br>document/email in KB     |\n| PGCOUNT      | 1                         | Number of pages in native file document/email   |\n| PATH         |   | Email: (empty)                                  |\n|              | Agenda.doc                | Native: Path where native file document was     |\n|              |                           | stored including original file name.            |\n| INTFILEPATH  | Personal Folders\\Deleted  | Email: original location of email including     |\n|              | Items\\Board Meeting       | original file name.                             |\n|              | Minutes.msg               | Native: (empty)                                 |\n| INTMSGID     | <000805c2c71b\\$75977050\\$ | Email: Unique Message ID Native: (empty)        |\n|              | cb8306d1@MSN>             |                                                 |\n| MD5HASH      | d131dd02c5e6eec4693d9a0   | MD5 Hash value of the document.                 |\n|              | 698aff95c                 |                                                 |\n|              | 2fcab58712467eab4004583e  |                                                 |\n|              | b8fb7f89                  |                                                 |\n| OCRPATH      | TEXT/001/EDC0000001.txt   | Path to extracted text of the native file       |\n\n3. Each Request operates and should be construed independently and, unless otherwise indicated, no Request limits the scope of any other Request.\n\n4. All Documents are to be produced as kept in the usual course of business or are to be organized and labeled to correspond with the categories in these Requests.\n\n5. Each Request contained herein extends to all Documents: (a) in Your possession, custody, or control; or (b) in the possession, custody, or control of anyone acting on Your behalf,\n\n#### Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 919 of 1063\n\nincluding Your counsel or other representatives and advisors. Each Document shall be produced in its entirety.\n\n6. If You are requested to produce a Document that is no longer in Your possession, custody, or control, then Your response must (a) describe in detail the nature of the document and its contents; (b) identify the person(s) who prepared or authored the Document (and, if applicable, the Person(s) to whom the Document was sent); (c) identify the date on which the document was prepared or created; (d) state whether such Document (i) is missing or lost, (ii) has been destroyed, (iii) has been transferred, voluntarily or involuntarily, to others, or (iv) was otherwise disposed of; (e) state the reason for, and the facts and circumstances surrounding, such disposition; (f) identify the Persons who authorized such disposition; (g) identify the date or approximate date of such disposition; (h) state when the Document was most recently in Your possession, custody or control; and (i) identify the Person, if any, presently in possession, custody, or control of such Document.\n\n7. If You are requested to produce a Document that has been destroyed, then Your response must state, in addition to the information required by the preceding Instruction: (a) the reason for the Document's destruction; (b) the identity of the Person who destroyed the Document; and (c) the identity of the Person who directed that the Document be destroyed.\n\n8. If You claim that a requested Document is privileged or attorney work-product, then Your response must: (a) state (i) a description of the Document adequate to support Your contention that the Document is privileged, (ii) the title of the Document, (iii) the date of the Document, (iv) the author of the Document, (v) the addressee of the Document, (vi) the identity of each Person who received or saw the original or any draft, copy, or reproduction of the Document, (vii) whether the Document itself, or any information contained or referred to in the Document is in the possession, custody, or control of any other Persons, and if so, the identity of\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 920 of 1063\n\nsuch Persons, as well as a statement addressing how the information came into their possession, (viii) the claim of privilege under which the Document is withheld, and (ix) all of the circumstances upon which You will rely to support such claim of privilege; and (b) produce a privilege log containing all of the information requested in Part (a) of this Instruction for each Document withheld on the basis of a claim of privilege in accordance with D. Conn. L. Civ. R. 26(e).\n\n9. If a portion of an otherwise responsive Document contains information subject to a claim of privilege, only that portion of the Document subject to the claim of privilege shall be deleted or redacted from the Document following the instructions above, and the rest shall be produced.\n\n10. The Requests are continuing in nature. You are hereby instructed to (a) supplement or correct any responses later learned to be incomplete or incorrect immediately upon learning that a prior response was incomplete or incorrect; and (b) produce any additional Documents that are called for under the\n\n11. If a Document is in a language other than English, You should provide that Document. If a Document is in a language other than English, and an English translation exists, You should provide both Documents.\n\n12. All references to Entities includes all affiliates thereof.\n\n13. All references to individual names include all alternative names, aliased, or nicknames.\n\n14. Unless otherwise expressly indicated, the period of time covered by the Document Requests is the period from February 5, 2012 to the date responses to the Document Requests are due.\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 921 of 1063\n\n#### **II. RULES OF CONSTRUCTION**\n\n15. The use of (a) any singular noun shall be construed to include the plural, and vice versa, and (b) a verb in any tense shall be construed as the use of the verb in all other tenses.\n\n16. The terms (a) \"and\" and \"or\" shall be construed either conjunctively or disjunctively as necessary to bring within the scope of any request all responses that might otherwise be construed to be outside of its scope, and (b) \"each\" and \"any\" shall be deemed to include and encompass the words \"every\" and \"all.\"\n\n#### **III. DEFINITIONS**\n\nThe definitions supplied by D. Conn. L. Civ. R. 26(c) and the rules of construction supplied by D. Conn. L. Civ. R. 26(d), as incorporated by D. Conn. Bankr. L.R. 2004-1(a), shall apply to the Document Requests. In addition, the following terms used in these Document Requests shall have the following meanings:\n\n1. \"You\" or \"Your\" or \"Yourself\" means and refers to FungWan Trading Inc., together with all of its affiliates, divisions, agencies, instrumentalities, departments, offices, partners, officers, directors, agents, attorneys, representatives, employees, and/or anyone acting on its behalf.\n\n2. \"Debtor\" means Ho Wan Kwok (a/k/a Miles Kwok, Miles Guo, Guo Wengui, Guo Haoyun, 郭文贵, or any other alias), together with his employees, agents, counsel, advisors, or anyone acting on his behalf.\n\n3. \"Debtor's Son\" means Qiang Guo (a/k/a Mileson Kwok, 郭强, or any other alias), together with his employees, agents, counsel, advisors, or anyone acting on his behalf.\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 922 of 1063\n\n4. \"Debtor's Daughter\" means Mei Guo (a/k/a Mei Gui, 郭美, or any other alias), together with her employees, agents, counsel, advisors, or anyone acting on her behalf.\n\n5. \"Debtor's Purported Wife\" means Hing Chi Ngok (a/k/a Hing Chi Ng, Yue Qingzhi, 岳庆芝, or any other alias), together with her employees, agents, counsel, advisors, or anyone acting on her behalf.\n\n6. \"Debtor's Family\" means, collectively, the Debtor, the Debtor's Son, the Debtor's Daughter, and the Debtor's Purported Wife, and any other familial relation to the Debtor.\n\n7. \"Associated Individuals\" means, individually and collectively, all individuals that (1) hold, control, have custody over, or discretion over assets owned, controlled, or enjoyed by the Debtor or the Debtor's Family; or (2) have been employees, directors, or otherwise are affiliated with one or more Associated Entities, together with the respective employees, agents, counsel, advisors, or anyone acting on behalf of any of the foregoing. Such Associated Individuals shall include, but are not limited to: Daniel Podhaskie, Jason Miller, Steve Bannon, Karin Maistrello, Melissa Francis, Anthony DiBattista, William Gertz, Arethusa Forsyth, Glenn Mellor, Jennifer Mercurio, Eduardo Eurnekian, Wencong Wang, Han Chunguang (a/k/a 韩春光), Qu Guojiao (a/k/a Qu Guo Jiao, 屈国姣), Guo Lijie (a/k/a 郭丽杰), Zhang Wei (a/k/a 张伟\\*), Lihong Wei Lafrenz (a/k/a Sara Wei, 魏丽红), Hao Haidong (a/k/a 郝海东), Ross Heinemeyer, Max Krasner, Kyle Bass, Melissa Mendez, Ya Li (a/k/a 李娅), Dinggang Wang (a/k/a 王定刚), An Hong (a/k/a 安红), Yvette Wang (a/k/a Yanping Wang, Yan Ping Wang, 王雁平), Fiona Yu, Je Kin Ming (a/k/a William Je, Yu Jianming, 余建明), Yaz Qingua, and Lao Jiang (a/k/a Jiang Yunfu, Jiang Yunfu Be, 姜云浮).\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 923 of 1063\n\n8. \"Associated Entities\" means, individually and collectively, all organizations or Entities of any type that (1) have been owned, controlled, or invested in by the Debtor or the Debtor's Family; or (2) have an interest, whether directly or indirectly, in any assets owned, controlled, or enjoyed by the Debtor or the Debtor's Family, together with the respective employees, agents, counsel, advisors, or anyone acting on behalf of any of the foregoing. Such Associated Entities shall include, but are not limited to: 7 Nod Hill LLC, AAGV Limited, ACA Investment Management Limited, ACA Capital Group Limited, Ace Decade Holdings Limited, AI Group Holdings Inc., Alfa Global Ventures Limited, Alfonso Global Limited, Allied Capital Global Limited, Alpine Fiduciaries SA, Anton Development Limited, Assets Sino Limited, Auspicious Coast Limited, Beijing Pangu Investment Co., Beijing Pangu Investment Co. Ltd., Beijing Pangu Investment Inc., Beijing Zenith Holdings Company Limited, Booming Sail New York LLC, Bravo Luck Limited, BSA Strategic Fund I, China Golden Spring (Hong Kong) Limited, Chuang Xin Limited, Crane Advisory Group LLC, Creative Apex Investments Limited, Crystal Breeze Investments Limited, Dawn State Limited, Eastern Profit Corporation Limited, Elite Well Global Limited, Empire Growth Holdings, Freedom Media Ventures Ltd., G Club Operations LLC, G Fashion LLC, G News LLC, GETTR USA, Genever Holdings Corporation, Genever Holdings LLC, Gfashion Media Group Inc., GFNY, Inc., Globalist International Limited, GNews Media Group Inc., Golden Spring (New York) Ltd., Greenwich Land LLC, Guo Media, GTV Media Group, Inc., Hamilton Capital Holdings Inc., HCHK Property Management, Inc., HCHK Technologies, Inc., Head Win Group Limited, Henan Yuda, Himalaya Embassy, Himalaya Exchange, Himalaya Federal Reserve, Himalaya Investment LLC, Himalaya International, Himalaya New World Inc., Himalaya Supervisory Organization, Himalaya Ventures LLC, HK International Funds Investments (USA) Limited LLC, Hong Kong International Funds\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 924 of 1063\n\nInvestments Limited, Hudson Diamond Holding, Infinite Increase Limited, Infinitum Developments Limited, Infinity Treasury Management Inc., Insight Phoenix Fund, Lamp Capital LLC, Leading Shine Limited, Leading Shine NY Limited, Lexington Property and Staffing, Long Gate Limited, Maywind Trading LLC, MOS Himalaya LLC, Next Tycoon Investments Limited, New Federal State of China (a/k/a NFSC), Noble Fame Global Limited, Rosy Acme Ventures Limited, Rule of Law Foundation III, Inc., Rule of Law Foundation IV, Inc., Rule of Law Fund, Rule of Law Society, Rule of Law Society IV, Inc., G-Translators PTY LTD, Saraca Media Group, Inc., Shiny Ace Ltd., Shiny Times Holdings Ltd., Spirit Charter Investment Limited, Stevenson, Wong & Co., Voice of Guo Media, Inc., Well Origin Ltd., World Century Limited, Worldwide Opportunity Holdings Limited, Whitecroft Shore Limited, and ZIBA Limited.\n\n9. \"Including\" or any variant thereof means \"including without limitation.\"\n\n10. \"And\" and \"or\" mean \"and/or,\" and shall be construed both conjunctively as well as disjunctively in order to maximize their scope.\n\n11. \"Any\" and \"all\" and \"each\" mean \"each and every.\"\n\n12. \"Each\" and \"every\" mean \"each and every.\"\n\n13. \"Third Party\" means a Person or Entity other than Yourself.\n\n14. \"Transfer\" shall have the meaning given to it by section 101(54) of the Bankruptcy Code.\n\n15. \"Document\" means any information or thing within the scope of Fed. R. Civ. P. 34, and includes, without limitation, each and every written, recorded, or graphic matter of any kind, type, nature, or description that is or has been in Your Possession, Custody or Control, including all printed and electronic copies of electronic mail, computer files maintained in\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 925 of 1063\n\nelectronic form, electronic communication, text message, social media post, tweet, meta-data, correspondence, memoranda, tapes, stenographic or handwritten notes, written forms of any kind, charts, blueprints, drawings, sketches, graphs, plans, articles, specifications, diaries, letters, telegrams, photographs, minutes, contracts, agreements, surveys, computer printouts, data compilations of any kind, telexes, facsimiles, voice messages, invoices, order forms, checks, drafts, statements, credit memos, reports, position reports, summaries, indices, books, ledgers, notebooks, schedules, transparencies, recordings, catalogs, advertisements, promotional materials, films, video tapes, audio tapes, CDs, computer disks, brochures, pamphlets, punchcards, time-slips, Tweets, social media posts, or any written or recorded materials of any other kind, and all meta-data thereof, however stored (whether in tangible or electronic form), recorded, produced, or reproduced, and also including but not limited to, drafts or copies of any of the foregoing that contain any notes, comments, or markings of any kind not found on the original documents or that are otherwise not identical to the original documents.\n\n16. \"Person(s)\" means an individual, corporation, proprietorship, partnership, association, or any other Entity. \"Person\" also includes any agent, representatives, or expert, including but not limiting to, attorneys or financial advisors.\n\n17. \"Entity\" means any natural Person, corporation, partnership, subsidiary, sole proprietorship, firm, board, joint venture, association, agency, authority, commission or other business entity or juristic Person, as well as any affiliate, agent, parent including but not limited to legal counsel, financial advisors, or any other representative.\n\n18. \"Regarding\" means concerning, describing, comprising, referring to, related to, supporting, favoring, opposing, bolstering, detracting from, located in, considered in connection with, bearing on, evidencing, indicating, reporting on, recording, alluding to, responding to,\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 926 of 1063\n\nconnected with, commenting on, in respect of, about, in relation to, discussing, showing, describing, reflecting, analyzing constituting, and being.\n\n19. \"Relating to,\" \"relate(s) to\" or \"related to,\" when referring to any given subject matter, means, without limitation, any document that constitutes, comprises, involves, contains, embodies, reflects, identifies, states, refers directly or indirectly to, or is in any way relevant to the particular subject matter identified.\n\n20. \"Communication(s)\" means, in the broadest possible sense, and without limitation, any transmittal of information or knowledge (in the form of facts, ideas, inquiries, or otherwise). Communication(s) further refers to all conversations, agreements, inquiries, or replies, whether in person, by telephone, in writing, or by means of electronic transmittal devices, and includes, but is not limited to, all correspondence, emails, recordings, transmittal slips, memoranda, telephone communications, voice messages, telegrams, telefaxes, telecopies, telexes, instant messages, chats, text messages, telephonic notes, or notes transmitted internally or with third parties.\n\n21. \"Asset(s)\" means any item that can be used to produce positive economic value, including but not limited to any resource with economic value that is owned, controlled or is for the benefit of an entity, that is expected to provide a future benefit, including but not limited to, all real and personal property, intangible property, investments, rights to invest or to future revenue, cash, bank accounts, commodities, securities, claims, total or partial control of an entity, and prospective economic opportunities\n\n22. \"Transfer\" shall have the meaning given to it by section 101(54) of the Bankruptcy Code.\n\n#### **IV. DOCUMENTS TO BE PRODUCED**\n\n1. All Documents regarding any income or Asset of the Debtor, the Debtor's estate, or an Associated Entity.\n\n2. All Documents related to the Debtor's financial condition and obligations to his creditors, including without limitation all Documents related to any effort to avoid paying such obligations and All Documents related to this or any other actual or potential bankruptcy or similar insolvency proceeding.\n\n3. All Documents regarding any balance sheet, bank statement, account statement, financial statement, statement of account, wire transfer instructions and/or confirmation, proof of funds, certificate of deposit, certificate of holdings, investment portfolio summary, or similar document relating to the Debtor, the Debtor's Estate, the Debtor's Family, an Associated Entity, or an Associated Individual, including without limitation all Documents sufficient to show all Transfers to any of the foregoing.\n\n4. All Documents regarding any investment, business dealing or transactions made by, with, or on behalf of the Debtor.\n\n5. All Communications with the Debtor, and Documents related to Communications with the Debtor, related to the operation, management, or decision-making of any Entity, including without limitation the Associated Entities.\n\n6. All Documents regarding any Transfer, investment, or other transaction or business dealing made to, by, or with the Debtor, the Debtor's Family, or an Associated Entity.\n\n7. All Documents regarding any property ever occupied or used by the Debtor, including without limitation the *Lady May*; the Sherry Netherland Hotel / Condominium; the\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 928 of 1063\n\nresidential property located in Greenwich, Connecticut at 373 Taconic Rd.; the residential property located in Greenwich, Connecticut at 33 Ferncliff Rd.; and the residential property located in Wilton, Connecticut at 354 Nod Hill Rd.\n\n8. All Documents related to any aircraft owned, controlled, or used by the Debtor, including without limitation the aircraft bearing tail number T7-GQM and any other aircraft registered in San Marino, including without limitation copies of all registration documents and flight manifests showing flights taken by such aircraft and the individuals onboard such flights.\n\n9. All Documents regarding any gifts, benefits or loans, to, from or on behalf of the Debtor, the Debtor's Estate, the Debtor's Family, or the Associated Entities, including without limitation Documents sufficient to show the amounts of such gifts, benefits, or loans; the purposes for which such gifts, benefits, or loans were used; when the gifts, benefits, or loans were provided; and the terms of any loans, all representations and warranties made in connection with any loans, the interest rate on any loans, and all evidence of payments of any loans.\n\n10. All Documents concerning any trust or similar instrument set up by, on behalf of, or for the benefit of the Debtor, the Debtor's Estate, the Debtor's Family, or an Associated Entity, including without limitation Documents sufficient to show when the trust(s) was created, by whom it was created, for whose benefit it was created, and the corpus of the trust.\n\n11. All Documents related to any obligation, claim, liability, or debt associated with any legal dispute involving the Debtor, including but not limited to those relating to any litigation before any local, state, federal, or international body, whether an administrative body, court, panel, or alternative dispute resolution entity.\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 929 of 1063\n\n12. All Documents and communications between any of your outside counsel or other advisors and the Debtor.\n\n13. Documents sufficient to show all of Your Assets and sources of income or funding.\n\n14. For all Assets identified in response to Request 14 having a value of more than \\$50,000, all (i) Documents related to Your acquisition of such Asset and (ii) Communications with the Debtor or the Debtor's Family regarding such Asset.\n\n15. Copies of Your tax returns.\n\n16. Documents sufficient to show all bank accounts and investment accounts within Your possession or control, including the balances of and transfers to and from each such account.\n\n17. All Documents regarding any credit cards used by You, including without limitation monthly statements or other Documents sufficient to show all purchases related thereto for the benefit of the Debtor or an Associated Entity.\n\n18. All corporate governance and organizational Documents, including without limitation by-laws and certificates of incorporation and other Documents sufficient to show Your corporate structure, names of officers and directors, business purpose, and relationship to the Debtor or to any member of the Debtor's Family.\n\n19. All Documents related to any pledge(s) of Your Assets to any other Entity.\n\n# Exhibit C-51\n\n#### B2540 (Form 2540 – Subpoena for Rule 2004 Examination) (12/15) Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 931 of\n\n1063\n\nUNITED STATES BANKRUPTCY COURT\n\n**District of Connecticut**\n\nIn re HO WAN KWOK, *et al*.,\n\n<sup>1</sup> Case No. 22-50073 (JAM)\n\nDebtor Chapter 11\n\n(Jointly Administered)\n\n# **SUBPOENA FOR RULE 2004 EXAMINATION**\n\nTo: **Huk Trading Inc.**\n\n(*Name of person to whom the subpoena is directed*)\n\n*Testimony:* **YOU ARE COMMANDED** to appear at the time, date, and place set forth below to testify at an examination under Rule 2004, Federal Rules of Bankruptcy Procedure. A copy of the court order authorizing the examination is attached.\n\n| PLACE                    | DATE AND TIME |\n|--------------------------|---------------|\n| Paul Hastings LLP        |               |\n| 200 Park Avenue          | [TBD]         |\n| New York, New York 10166 |               |\n|                          |               |\n\nThe examination will be recorded by this method: **Court reporter/stenographer**\n\n*Production:* You, or your representatives, must also bring with you to the examination the following documents, electronically stored information, or objects, and must permit inspection, copying, testing, or sampling of the material:\n\n#### **See Requests for Production of Documents, attached hereto.**\n\nThe following provisions of Fed. R. Civ. P. 45, made applicable in bankruptcy cases by Fed. R. Bankr. P. 9016, are attached – Rule 45(c), relating to the place of compliance; Rule 45(d), relating to your protection as a person subject to a subpoena; and Rule 45(e) and 45(g), relating to your duty to respond to this subpoena and the potential consequences of not doing so.\n\nDate: **March , 2023**\n\nCLERK OF COURT\n\nOR\n\n*Signature of Clerk or Deputy Clerk Attorney's signature*\n\nThe name, address, email address, and telephone number of the attorney representing Luc A. Despins, Chapter 11 Trustee, who issues or requests this subpoena, are:\n\n**Douglas S. Skalka, Esq.; Neubert, Pepe & Monteith, P.C.; 195 Church Street, New Haven, Connecticut 06510 dskalka@npmlaw.com; (203) 821-2000**\n\n**Notice to the person who issues or requests this subpoena**\n\nIf this subpoena commands the production of documents, electronically stored information, or tangible things, or the inspection of premises before trial, a notice and a copy of this subpoena must be served on each party before it is served on the person to whom it is directed. Fed. R. Civ. P. 45(a)(4).\n\nSoftware Copyright (c) 1996-2022 Best Case, LLC - www.bestcase.com Best Case Bankruptcy 1 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\n#### **PROOF OF SERVICE**\n\n**(This section should not be filed with the court unless required by Fed. R. Civ. P. 45.)**\n\nI received this subpoena for (*name of individual and title, if any*): on (*date*) .\n\nI served the subpoena by delivering a copy to the named person as follows:\n\non *(date)* ; or\n\nI returned the subpoena unexecuted because:\n\nUnless the subpoena was issued on behalf of the United States, or one of its officers or agents, I have also tendered to the witness the fees for one day's attendance, and the mileage allowed by law, in the amount of \\$ .\n\nMy fees are \\$ for travel and \\$ for services, for a total of \\$ .\n\nI declare under penalty of perjury that this information is true and correct.\n\nDate:\n\n*Server's signature*\n\n*Printed name and title*\n\n*Server's address*\n\nAdditional information concerning attempted service, etc.:\n\n#### **Federal Rule of Civil Procedure 45(c), (d), (e), and (g) (Effective 12/1/13) (made applicable in bankruptcy cases by Rule 9016, Federal Rules of Bankruptcy Procedure)**\n\n#### **(c) Place of compliance.**\n\n*(1) For a Trial, Hearing, or Deposition.* A subpoena may command a person to attend a trial, hearing, or deposition only as follows:\n\n(A) within 100 miles of where the person resides, is employed, or regularly transacts business in person; or\n\n(B) within the state where the person resides, is employed, or regularly transacts business in person, if the person\n\n(i) is a party or a party's officer; or\n\n(ii) is commanded to attend a trial and would not incur substantial expense.\n\n*(2) For Other Discovery.* A subpoena may command:\n\n(A) production of documents, or electronically stored information, or things at a place within 100 miles of where the person resides, is employed, or regularly transacts business in person; and\n\n(B) inspection of premises, at the premises to be inspected.\n\n#### **(d) Protecting a Person Subject to a Subpoena; Enforcement.**\n\n*(1) Avoiding Undue Burden or Expense; Sanctions.* A party or attorney responsible for issuing and serving a subpoena must take reasonable steps to avoid imposing undue burden or expense on a person subject to the subpoena. The court for the district where compliance is required must enforce this duty and impose an appropriate sanction which may include lost earnings and reasonable attorney's fees — on a party or attorney who fails to comply.\n\n#### *(2) Command to Produce Materials or Permit Inspection.*\n\n*(A) Appearance Not Required.* A person commanded to produce documents, electronically stored information, or tangible things, or to permit the inspection of premises, need not appear in person at the place of production or inspection unless also commanded to appear for a deposition, hearing, or trial.\n\n*(B) Objections.* A person commanded to produce documents or tangible things or to permit inspection may serve on the party or attorney designated in the subpoena a written objection to inspecting, copying, testing or sampling any or all of the materials or to inspecting the premises — or to producing electronically stored information in the form or forms requested. The objection must be served before the earlier of the time specified for compliance or 14 days after the subpoena is served. If an objection is made, the following rules apply:\n\n(i) At any time, on notice to the commanded person, the serving party may move the court for the district where compliance is required for an order compelling production or inspection.\n\n(ii) These acts may be required only as directed in the order, and the order must protect a person who is neither a party nor a party's officer from significant expense resulting from compliance.\n\n#### *(3) Quashing or Modifying a Subpoena.*\n\n*(A) When Required.* On timely motion, the court for the district where compliance is required must quash or modify a subpoena that:\n\n(i) fails to allow a reasonable time to comply;\n\n(ii) requires a person to comply beyond the geographical limits specified in Rule 45(c);\n\n(iii) requires disclosure of privileged or other protected matter, if no exception or waiver applies; or\n\n(iv) subjects a person to undue burden.\n\n*(B) When Permitted.* To protect a person subject to or affected by a subpoena, the court for the district where compliance is required may, on motion, quash or modify the subpoena if it requires:\n\n(i) disclosing a trade secret or other confidential research, development, or commercial information; or\n\n(ii) disclosing an unretained expert's opinion or information that does not describe specific occurrences in dispute and results from the expert's study that was not requested by a party.\n\n(C) *Specifying Conditions as an Alternative.* In the circumstances described in Rule 45(d)(3)(B), the court may, instead of quashing or modifying a subpoena, order appearance or production under specified conditions if the serving party:\n\n(i) shows a substantial need for the testimony or material that cannot be otherwise met without undue hardship; and\n\n(ii) ensures that the subpoenaed person will be reasonably compensated.\n\n#### **(e) Duties in Responding to a Subpoena.**\n\n*(1) Producing Documents or Electronically Stored Information.* These procedures apply to producing documents or electronically stored information:\n\n*(A) Documents.* A person responding to a subpoena to produce documents must produce them as they are kept in the ordinary course of business or must organize and label them to correspond to the categories in the demand.\n\n*(B) Form for Producing Electronically Stored Information Not Specified.* If a subpoena does not specify a form for producing electronically stored information, the person responding must produce it in a form or forms in which it is ordinarily maintained or in a reasonably usable form or forms.\n\n*(C) Electronically Stored Information Produced in Only One Form.* The person responding need not produce the same electronically stored information in more than one form.\n\n*(D) Inaccessible Electronically Stored Information.* The person responding need not provide discovery of electronically stored information from sources that the person identifies as not reasonably accessible because of undue burden or cost. On motion to compel discovery or for a protective order, the person responding must show that the information is not reasonably accessible because of undue burden or cost. If that showing is made, the court may nonetheless order discovery from such sources if the requesting party shows good cause, considering the limitations of Rule 26(b)(2)(C). The court may specify conditions for the discovery.\n\n#### *(2) Claiming Privilege or Protection.*\n\n*(A) Information Withheld.* A person withholding subpoenaed information under a claim that it is privileged or subject to protection as trial-preparation material must: (i) expressly make the claim; and\n\n(ii) describe the nature of the withheld documents, communications, or tangible things in a manner that, without revealing information itself privileged or protected, will enable the parties to assess the claim.\n\n*(B) Information Produced.* If information produced in response to a subpoena is subject to a claim of privilege or of protection as trial-preparation material, the person making the claim may notify any party that received the information of the claim and the basis for it. After being notified, a party must promptly return, sequester, or destroy the specified information and any copies it has; must not use or disclose the information until the claim is resolved; must take reasonable steps to retrieve the information if the party disclosed it before being notified; and may promptly present the information under seal to the court for the district where compliance is required for a determination of the claim. The person who produced the information must preserve the information until the claim is resolved.\n\n**(g) Contempt.** The court for the district where compliance is required – and also, after a motion is transferred, the issuing court – may hold in contempt a person who, having been served, fails without adequate excuse to obey the subpoena or an order related to it.\n\nFor access to subpoena materials, see Fed.R.Civ.P.45(a) Committee Note (2013)\n\n…\n\n## **Requests for Production of Documents**\n\n## **I. INSTRUCTIONS**\n\n1. Unless otherwise indicated, the requests for documents set forth below, (the \"Requests,\" and each, a \"Request\"), must be responded to separately and specifically. Each Request shall be answered fully unless it is in good faith objected to, in which event the reason for Your objection shall be stated in detail, as set forth below. If an objection pertains only to a portion of a Request, or a word, phrase or clause contained within it, You are required to state Your objection to that portion only and to respond to the remainder of the Requests.\n\n2. Electronically stored information must be produced in accordance with the\n\nfollowing instructions:\n\n- a. Images. Black and white images must be 300 DPI Group IV single-page TIFF files. Color images must be produced in JPEG format. File names cannot contain embedded spaces or special characters (including the comma). Folder names cannot contain embedded spaces or special characters (including the comma). All TIFF image files must have a unique file name, i.e. Bates number. Images must be endorsed with sequential Bates numbers in the lower right corner of each image. The number of TIFF files per folder should not exceed 1000 files. Excel spreadsheets should have a placeholder image named by the Bates number of the file.\n- b. Image Load File\n\t- a. Concordance® Data File. The data file (.DAT) contains all of the fielded information that will be loaded into the Concordance® database. The first line of the .DAT file must be a header row identifying the field names. The .DAT file must use the following Concordance® default delimiters: Comma ASCII character (020) Quote þ ASCII character (254). Date fields should be provided in the format: mm/dd/yyyy. Date and time fields must be two separate fields. If documents includes imaged emails and attachments, the attachment fields must be included to preserve the parent/child relationship between an email and its attachments. An OCRPATH field must be included to provide the file path and name of the extracted text file on the produced storage media. The text file must be named after the FIRSTBATES. Do not include the text in the .DAT file. For Documents with native files, a LINK field must be included to provide the file path and\n\nname of the native file. The native file must be named after the FIRSTBATES.\n\n- b. Concordance Image® OR Opticon Cross-Reference File. The image crossreference file (.LOG or .OPT) links the images to the database records. It should be a comma-delimited file consisting of seven fields per line with a line in the cross-reference file for every image in the database with the following format: ImageID,VolumeLabel,ImageFilePath,DocumentBreak,FolderBreak,Box Break,PageCoun.\n- c. Document Text. Text must be produced as separate text files, not as fields within the .DAT file. The full path to the text file (OCRPATH) should be included in the .DAT file. It is recommended document level ANSI text files, named per the FIRSTBATES/Image Key. Extracted text files must be in a separate folder, and the number of text files per folder should not exceed 1,000 files. There should be no special characters (including commas in the folder names). Text files must be provided on a document level.\n- d. Native Production for Certain File Types. File types that reasonably require viewing in their native format for a full understanding of their content and meaning must be produced in native format. These include, but are not limited to, spreadsheets, spreadsheet-like files (Microsoft Excel, comma separated values, tab separated values, etc.), Microsoft PowerPoint or other special presentation files, database files, and audio/visual files. Provide an image of a Bates numbered slip sheet indicating the presence of a native file, and include the path to the native as a field in the .dat file. Name the produced native file with the Bates number corresponding to the slip sheet for the file. Group native files within incrementally named \"NATIVE\" directories, separate from images directories.\n- e. De-duplication. Produce a single copy of each electronic document for which exact duplicates exist. For email messages, consolidate duplicates based on MD5 hash generated from the BCC, Body, CC, From, IntMsgID, To, and Attach properties. For email attachments and standalone electronic files, consolidate duplicates based on MD5 hash of the entire file.\n- f. Metadata. Produce extracted metadata for each document in the form of a Concordance compliant load file (.dat). The first line of the .DAT file must be a header row identifying the field names. The .DAT file must use the following Concordance default delimiters: Comma , ASCII character (020) Quote þ ASCII character (254)\n\nDate fields should be provided in the format: mm/dd/yyyy. Date and time fields must be two separate fields. Required metadata listed below:\n\n# Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 936 of 1063\n\n| Field Name   | Sample Data              | Description                                                                                  |\n|--------------|--------------------------|----------------------------------------------------------------------------------------------|\n| FIRSTBATES   | EDC0000001               | First Bates number of native file document/email                                             |\n| LASTBATES    | EDC0000001               | Last Bates number of native file document/email<br>**The LASTBATES field should be populated |\n|              |                          | for single page                                                                              |\n| ATTACHRANGE  | EDC0000001<br>-          | Bates number of the first page of the parent                                                 |\n|              | EDC0000015               | document to the Bates number of the last page of                                             |\n|              |                          | the last attachment \"child\" document                                                         |\n| BEGATTACH    | EDC0000001               | First Bates number of attachment range                                                       |\n| ENDATTACH    | EDC0000015               | Last Bates number of attachment range                                                        |\n| CUSTODIAN    | Smith, John              | Email: Mailbox where the email resided                                                       |\n|              |                          | Native: Name of the individual or department                                                 |\n|              |                          | from whose files the document<br>originated                                                  |\n| FROM         | John Smith               | Email: Sender                                                                                |\n|              |                          | Native: Author(s) of document                                                                |\n|              |                          | **semi-colon should be used to separate                                                      |\n|              |                          | multiple entries                                                                             |\n| TO           | Coffman, Janice; LeeW    | Recipient(s)                                                                                 |\n|              | [mailto:LeeW@MSN.com]    | **semi-colon should be used to separate multiple                                             |\n|              |                          | entries                                                                                      |\n| CC           | Frank Thompson [mailto:  | Carbon copy recipient(s)                                                                     |\n|              | frank_Thompson@cdt.com]  | **semi-colon should be used to separate                                                      |\n|              |                          | multiple entries                                                                             |\n| BCC          | John Cain                | Blind carbon copy recipient(s)                                                               |\n|              |                          | **semi-colon should be used to separate                                                      |\n|              |                          | multiple entries                                                                             |\n| SUBJECT      | Board Meeting Minutes    | Email: Subject line of the email Native: Title                                               |\n|              |                          | of document (if available)                                                                   |\n| FILE_NAME    | BoardMeetingMinutes.docx | Native: Name of the original native file,                                                    |\n|              |                          | including extension                                                                          |\n| DATE_SENT    | 10/12/2010               | Email: Date the email was sent                                                               |\n|              |                          | Native: (empty)                                                                              |\n| TIME_SENT/   | 07:05 PM GMT             | Email: Time the email was sent/ Time zone in                                                 |\n| TIME_ZONE    |                          | which the emails were standardized                                                           |\n| TIME_ZONE    | GMT                      | The<br>time zone in which<br>the emails<br>were                                              |\n|              |                          | standardized during conversion.                                                              |\n| LINK         |  EDC0000001.msg   | Hyperlink to the email or native file document                                               |\n|              |                          | **The linked file must be named per the                                                      |\n|              |                          | FIRSTBATES number                                                                            |\n| FILE_EXTEN   | MSG                      | The file type extension                                                                      |\n|              |                          | representing                                                                                 |\n|              |                          | the Email or                                                                                 |\n| AUTHOR       | John Smith               | Email: (empty)                                                                               |\n|              |                          | Native: Author of the document                                                               |\n| DATE_CREATED | 10/10/2010               | Email: (empty)                                                                               |\n|              |                          | Native: Date the document was created                                                        |\n\n# Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 937 of 1063\n\n| TIME_CREATED | 10:25 AM                  | Email: (empty)                                  |\n|--------------|---------------------------|-------------------------------------------------|\n|              |                           | Native: Time the document was created           |\n|              |                           | **This data must be a separate field and cannot |\n|              |                           | be combined with the DATE_CREATED field         |\n| DATE_MOD     | 10/12/2010                | Email: (empty)                                  |\n|              |                           | Native: Date the document was last modified     |\n| TIME_MOD     | 07:00 PM                  | Email: (empty)                                  |\n|              |                           | Native: Time the document was last modified     |\n|              |                           | **This data must be a separate field and cannot |\n|              |                           | be combined with the DATE_MOD field             |\n| DATE_ACCESSD | 10/12/2010                | Email: (empty)                                  |\n|              |                           | Native: Date the document was last accessed     |\n| TIME_ACCESSD | 07:00 PM                  | Email: (empty)                                  |\n|              |                           | Native: Time the document was last accessed     |\n|              |                           | **This data must be a separate field and cannot |\n|              |                           | be combined with the DATE_ACCESSD field         |\n| FILE_SIZE    | 5,952                     | Size of native file<br>document/email in KB     |\n| PGCOUNT      | 1                         | Number of pages in native file document/email   |\n| PATH         |   | Email: (empty)                                  |\n|              | Agenda.doc                | Native: Path where native file document was     |\n|              |                           | stored including original file name.            |\n| INTFILEPATH  | Personal Folders\\Deleted  | Email: original location of email including     |\n|              | Items\\Board Meeting       | original file name.                             |\n|              | Minutes.msg               | Native: (empty)                                 |\n| INTMSGID     | <000805c2c71b\\$75977050\\$ | Email: Unique Message ID Native: (empty)        |\n|              | cb8306d1@MSN>             |                                                 |\n| MD5HASH      | d131dd02c5e6eec4693d9a0   | MD5 Hash value of the document.                 |\n|              | 698aff95c                 |                                                 |\n|              | 2fcab58712467eab4004583e  |                                                 |\n|              | b8fb7f89                  |                                                 |\n| OCRPATH      | TEXT/001/EDC0000001.txt   | Path to extracted text of the native file       |\n\n3. Each Request operates and should be construed independently and, unless otherwise indicated, no Request limits the scope of any other Request.\n\n4. All Documents are to be produced as kept in the usual course of business or are to be organized and labeled to correspond with the categories in these Requests.\n\n5. Each Request contained herein extends to all Documents: (a) in Your possession, custody, or control; or (b) in the possession, custody, or control of anyone acting on Your behalf,\n\n#### Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 938 of 1063\n\nincluding Your counsel or other representatives and advisors. Each Document shall be produced in its entirety.\n\n6. If You are requested to produce a Document that is no longer in Your possession, custody, or control, then Your response must (a) describe in detail the nature of the document and its contents; (b) identify the person(s) who prepared or authored the Document (and, if applicable, the Person(s) to whom the Document was sent); (c) identify the date on which the document was prepared or created; (d) state whether such Document (i) is missing or lost, (ii) has been destroyed, (iii) has been transferred, voluntarily or involuntarily, to others, or (iv) was otherwise disposed of; (e) state the reason for, and the facts and circumstances surrounding, such disposition; (f) identify the Persons who authorized such disposition; (g) identify the date or approximate date of such disposition; (h) state when the Document was most recently in Your possession, custody or control; and (i) identify the Person, if any, presently in possession, custody, or control of such Document.\n\n7. If You are requested to produce a Document that has been destroyed, then Your response must state, in addition to the information required by the preceding Instruction: (a) the reason for the Document's destruction; (b) the identity of the Person who destroyed the Document; and (c) the identity of the Person who directed that the Document be destroyed.\n\n8. If You claim that a requested Document is privileged or attorney work-product, then Your response must: (a) state (i) a description of the Document adequate to support Your contention that the Document is privileged, (ii) the title of the Document, (iii) the date of the Document, (iv) the author of the Document, (v) the addressee of the Document, (vi) the identity of each Person who received or saw the original or any draft, copy, or reproduction of the Document, (vii) whether the Document itself, or any information contained or referred to in the Document is in the possession, custody, or control of any other Persons, and if so, the identity of\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 939 of 1063\n\nsuch Persons, as well as a statement addressing how the information came into their possession, (viii) the claim of privilege under which the Document is withheld, and (ix) all of the circumstances upon which You will rely to support such claim of privilege; and (b) produce a privilege log containing all of the information requested in Part (a) of this Instruction for each Document withheld on the basis of a claim of privilege in accordance with D. Conn. L. Civ. R. 26(e).\n\n9. If a portion of an otherwise responsive Document contains information subject to a claim of privilege, only that portion of the Document subject to the claim of privilege shall be deleted or redacted from the Document following the instructions above, and the rest shall be produced.\n\n10. The Requests are continuing in nature. You are hereby instructed to (a) supplement or correct any responses later learned to be incomplete or incorrect immediately upon learning that a prior response was incomplete or incorrect; and (b) produce any additional Documents that are called for under the\n\n11. If a Document is in a language other than English, You should provide that Document. If a Document is in a language other than English, and an English translation exists, You should provide both Documents.\n\n12. All references to Entities includes all affiliates thereof.\n\n13. All references to individual names include all alternative names, aliased, or nicknames.\n\n14. Unless otherwise expressly indicated, the period of time covered by the Document Requests is the period from February 5, 2012 to the date responses to the Document Requests are due.\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 940 of 1063\n\n#### **II. RULES OF CONSTRUCTION**\n\n15. The use of (a) any singular noun shall be construed to include the plural, and vice versa, and (b) a verb in any tense shall be construed as the use of the verb in all other tenses.\n\n16. The terms (a) \"and\" and \"or\" shall be construed either conjunctively or disjunctively as necessary to bring within the scope of any request all responses that might otherwise be construed to be outside of its scope, and (b) \"each\" and \"any\" shall be deemed to include and encompass the words \"every\" and \"all.\"\n\n#### **III. DEFINITIONS**\n\nThe definitions supplied by D. Conn. L. Civ. R. 26(c) and the rules of construction supplied by D. Conn. L. Civ. R. 26(d), as incorporated by D. Conn. Bankr. L.R. 2004-1(a), shall apply to the Document Requests. In addition, the following terms used in these Document Requests shall have the following meanings:\n\n1. \"You\" or \"Your\" or \"Yourself\" means and refers to Huk Trading Inc., together with all of its affiliates, divisions, agencies, instrumentalities, departments, offices, partners, officers, directors, agents, attorneys, representatives, employees, and/or anyone acting on its behalf.\n\n2. \"Debtor\" means Ho Wan Kwok (a/k/a Miles Kwok, Miles Guo, Guo Wengui, Guo Haoyun, 郭文贵, or any other alias), together with his employees, agents, counsel, advisors, or anyone acting on his behalf.\n\n3. \"Debtor's Son\" means Qiang Guo (a/k/a Mileson Kwok, 郭强, or any other alias), together with his employees, agents, counsel, advisors, or anyone acting on his behalf.\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 941 of 1063\n\n4. \"Debtor's Daughter\" means Mei Guo (a/k/a Mei Gui, 郭美, or any other alias), together with her employees, agents, counsel, advisors, or anyone acting on her behalf.\n\n5. \"Debtor's Purported Wife\" means Hing Chi Ngok (a/k/a Hing Chi Ng, Yue Qingzhi, 岳庆芝, or any other alias), together with her employees, agents, counsel, advisors, or anyone acting on her behalf.\n\n6. \"Debtor's Family\" means, collectively, the Debtor, the Debtor's Son, the Debtor's Daughter, and the Debtor's Purported Wife, and any other familial relation to the Debtor.\n\n7. \"Associated Individuals\" means, individually and collectively, all individuals that (1) hold, control, have custody over, or discretion over assets owned, controlled, or enjoyed by the Debtor or the Debtor's Family; or (2) have been employees, directors, or otherwise are affiliated with one or more Associated Entities, together with the respective employees, agents, counsel, advisors, or anyone acting on behalf of any of the foregoing. Such Associated Individuals shall include, but are not limited to: Daniel Podhaskie, Jason Miller, Steve Bannon, Karin Maistrello, Melissa Francis, Anthony DiBattista, William Gertz, Arethusa Forsyth, Glenn Mellor, Jennifer Mercurio, Eduardo Eurnekian, Wencong Wang, Han Chunguang (a/k/a 韩春光), Qu Guojiao (a/k/a Qu Guo Jiao, 屈国姣), Guo Lijie (a/k/a 郭丽杰), Zhang Wei (a/k/a 张伟\\*), Lihong Wei Lafrenz (a/k/a Sara Wei, 魏丽红), Hao Haidong (a/k/a 郝海东), Ross Heinemeyer, Max Krasner, Kyle Bass, Melissa Mendez, Ya Li (a/k/a 李娅), Dinggang Wang (a/k/a 王定刚), An Hong (a/k/a 安红), Yvette Wang (a/k/a Yanping Wang, Yan Ping Wang, 王雁平), Fiona Yu, Je Kin Ming (a/k/a William Je, Yu Jianming, 余建明), Yaz Qingua, and Lao Jiang (a/k/a Jiang Yunfu, Jiang Yunfu Be, 姜云浮).\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 942 of 1063\n\n8. \"Associated Entities\" means, individually and collectively, all organizations or Entities of any type that (1) have been owned, controlled, or invested in by the Debtor or the Debtor's Family; or (2) have an interest, whether directly or indirectly, in any assets owned, controlled, or enjoyed by the Debtor or the Debtor's Family, together with the respective employees, agents, counsel, advisors, or anyone acting on behalf of any of the foregoing. Such Associated Entities shall include, but are not limited to: 7 Nod Hill LLC, AAGV Limited, ACA Investment Management Limited, ACA Capital Group Limited, Ace Decade Holdings Limited, AI Group Holdings Inc., Alfa Global Ventures Limited, Alfonso Global Limited, Allied Capital Global Limited, Alpine Fiduciaries SA, Anton Development Limited, Assets Sino Limited, Auspicious Coast Limited, Beijing Pangu Investment Co., Beijing Pangu Investment Co. Ltd., Beijing Pangu Investment Inc., Beijing Zenith Holdings Company Limited, Booming Sail New York LLC, Bravo Luck Limited, BSA Strategic Fund I, China Golden Spring (Hong Kong) Limited, Chuang Xin Limited, Crane Advisory Group LLC, Creative Apex Investments Limited, Crystal Breeze Investments Limited, Dawn State Limited, Eastern Profit Corporation Limited, Elite Well Global Limited, Empire Growth Holdings, Freedom Media Ventures Ltd., G Club Operations LLC, G Fashion LLC, G News LLC, GETTR USA, Genever Holdings Corporation, Genever Holdings LLC, Gfashion Media Group Inc., GFNY, Inc., Globalist International Limited, GNews Media Group Inc., Golden Spring (New York) Ltd., Greenwich Land LLC, Guo Media, GTV Media Group, Inc., Hamilton Capital Holdings Inc., HCHK Property Management, Inc., HCHK Technologies, Inc., Head Win Group Limited, Henan Yuda, Himalaya Embassy, Himalaya Exchange, Himalaya Federal Reserve, Himalaya Investment LLC, Himalaya International, Himalaya New World Inc., Himalaya Supervisory Organization, Himalaya Ventures LLC, HK International Funds Investments (USA) Limited LLC, Hong Kong International Funds\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 943 of 1063\n\nInvestments Limited, Hudson Diamond Holding, Infinite Increase Limited, Infinitum Developments Limited, Infinity Treasury Management Inc., Insight Phoenix Fund, Lamp Capital LLC, Leading Shine Limited, Leading Shine NY Limited, Lexington Property and Staffing, Long Gate Limited, Maywind Trading LLC, MOS Himalaya LLC, Next Tycoon Investments Limited, New Federal State of China (a/k/a NFSC), Noble Fame Global Limited, Rosy Acme Ventures Limited, Rule of Law Foundation III, Inc., Rule of Law Foundation IV, Inc., Rule of Law Fund, Rule of Law Society, Rule of Law Society IV, Inc., G-Translators PTY LTD, Saraca Media Group, Inc., Shiny Ace Ltd., Shiny Times Holdings Ltd., Spirit Charter Investment Limited, Stevenson, Wong & Co., Voice of Guo Media, Inc., Well Origin Ltd., World Century Limited, Worldwide Opportunity Holdings Limited, Whitecroft Shore Limited, and ZIBA Limited.\n\n9. \"Including\" or any variant thereof means \"including without limitation.\"\n\n10. \"And\" and \"or\" mean \"and/or,\" and shall be construed both conjunctively as well as disjunctively in order to maximize their scope.\n\n11. \"Any\" and \"all\" and \"each\" mean \"each and every.\"\n\n12. \"Each\" and \"every\" mean \"each and every.\"\n\n13. \"Third Party\" means a Person or Entity other than Yourself.\n\n14. \"Transfer\" shall have the meaning given to it by section 101(54) of the Bankruptcy Code.\n\n15. \"Document\" means any information or thing within the scope of Fed. R. Civ. P. 34, and includes, without limitation, each and every written, recorded, or graphic matter of any kind, type, nature, or description that is or has been in Your Possession, Custody or Control, including all printed and electronic copies of electronic mail, computer files maintained in\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 944 of 1063\n\nelectronic form, electronic communication, text message, social media post, tweet, meta-data, correspondence, memoranda, tapes, stenographic or handwritten notes, written forms of any kind, charts, blueprints, drawings, sketches, graphs, plans, articles, specifications, diaries, letters, telegrams, photographs, minutes, contracts, agreements, surveys, computer printouts, data compilations of any kind, telexes, facsimiles, voice messages, invoices, order forms, checks, drafts, statements, credit memos, reports, position reports, summaries, indices, books, ledgers, notebooks, schedules, transparencies, recordings, catalogs, advertisements, promotional materials, films, video tapes, audio tapes, CDs, computer disks, brochures, pamphlets, punchcards, time-slips, Tweets, social media posts, or any written or recorded materials of any other kind, and all meta-data thereof, however stored (whether in tangible or electronic form), recorded, produced, or reproduced, and also including but not limited to, drafts or copies of any of the foregoing that contain any notes, comments, or markings of any kind not found on the original documents or that are otherwise not identical to the original documents.\n\n16. \"Person(s)\" means an individual, corporation, proprietorship, partnership, association, or any other Entity. \"Person\" also includes any agent, representatives, or expert, including but not limiting to, attorneys or financial advisors.\n\n17. \"Entity\" means any natural Person, corporation, partnership, subsidiary, sole proprietorship, firm, board, joint venture, association, agency, authority, commission or other business entity or juristic Person, as well as any affiliate, agent, parent including but not limited to legal counsel, financial advisors, or any other representative.\n\n18. \"Regarding\" means concerning, describing, comprising, referring to, related to, supporting, favoring, opposing, bolstering, detracting from, located in, considered in connection with, bearing on, evidencing, indicating, reporting on, recording, alluding to, responding to,\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 945 of 1063\n\nconnected with, commenting on, in respect of, about, in relation to, discussing, showing, describing, reflecting, analyzing constituting, and being.\n\n19. \"Relating to,\" \"relate(s) to\" or \"related to,\" when referring to any given subject matter, means, without limitation, any document that constitutes, comprises, involves, contains, embodies, reflects, identifies, states, refers directly or indirectly to, or is in any way relevant to the particular subject matter identified.\n\n20. \"Communication(s)\" means, in the broadest possible sense, and without limitation, any transmittal of information or knowledge (in the form of facts, ideas, inquiries, or otherwise). Communication(s) further refers to all conversations, agreements, inquiries, or replies, whether in person, by telephone, in writing, or by means of electronic transmittal devices, and includes, but is not limited to, all correspondence, emails, recordings, transmittal slips, memoranda, telephone communications, voice messages, telegrams, telefaxes, telecopies, telexes, instant messages, chats, text messages, telephonic notes, or notes transmitted internally or with third parties.\n\n21. \"Asset(s)\" means any item that can be used to produce positive economic value, including but not limited to any resource with economic value that is owned, controlled or is for the benefit of an entity, that is expected to provide a future benefit, including but not limited to, all real and personal property, intangible property, investments, rights to invest or to future revenue, cash, bank accounts, commodities, securities, claims, total or partial control of an entity, and prospective economic opportunities\n\n22. \"Transfer\" shall have the meaning given to it by section 101(54) of the Bankruptcy Code.\n\n#### **IV. DOCUMENTS TO BE PRODUCED**\n\n1. All Documents regarding any income or Asset of the Debtor, the Debtor's estate, or an Associated Entity.\n\n2. All Documents related to the Debtor's financial condition and obligations to his creditors, including without limitation all Documents related to any effort to avoid paying such obligations and All Documents related to this or any other actual or potential bankruptcy or similar insolvency proceeding.\n\n3. All Documents regarding any balance sheet, bank statement, account statement, financial statement, statement of account, wire transfer instructions and/or confirmation, proof of funds, certificate of deposit, certificate of holdings, investment portfolio summary, or similar document relating to the Debtor, the Debtor's Estate, the Debtor's Family, an Associated Entity, or an Associated Individual, including without limitation all Documents sufficient to show all Transfers to any of the foregoing.\n\n4. All Documents regarding any investment, business dealing or transactions made by, with, or on behalf of the Debtor.\n\n5. All Communications with the Debtor, and Documents related to Communications with the Debtor, related to the operation, management, or decision-making of any Entity, including without limitation the Associated Entities.\n\n6. All Documents regarding any Transfer, investment, or other transaction or business dealing made to, by, or with the Debtor, the Debtor's Family, or an Associated Entity.\n\n7. All Documents regarding any property ever occupied or used by the Debtor, including without limitation the *Lady May*; the Sherry Netherland Hotel / Condominium; the\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 947 of 1063\n\nresidential property located in Greenwich, Connecticut at 373 Taconic Rd.; the residential property located in Greenwich, Connecticut at 33 Ferncliff Rd.; and the residential property located in Wilton, Connecticut at 354 Nod Hill Rd.\n\n8. All Documents related to any aircraft owned, controlled, or used by the Debtor, including without limitation the aircraft bearing tail number T7-GQM and any other aircraft registered in San Marino, including without limitation copies of all registration documents and flight manifests showing flights taken by such aircraft and the individuals onboard such flights.\n\n9. All Documents regarding any gifts, benefits or loans, to, from or on behalf of the Debtor, the Debtor's Estate, the Debtor's Family, or the Associated Entities, including without limitation Documents sufficient to show the amounts of such gifts, benefits, or loans; the purposes for which such gifts, benefits, or loans were used; when the gifts, benefits, or loans were provided; and the terms of any loans, all representations and warranties made in connection with any loans, the interest rate on any loans, and all evidence of payments of any loans.\n\n10. All Documents concerning any trust or similar instrument set up by, on behalf of, or for the benefit of the Debtor, the Debtor's Estate, the Debtor's Family, or an Associated Entity, including without limitation Documents sufficient to show when the trust(s) was created, by whom it was created, for whose benefit it was created, and the corpus of the trust.\n\n11. All Documents related to any obligation, claim, liability, or debt associated with any legal dispute involving the Debtor, including but not limited to those relating to any litigation before any local, state, federal, or international body, whether an administrative body, court, panel, or alternative dispute resolution entity.\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 948 of 1063\n\n12. All Documents and communications between any of your outside counsel or other advisors and the Debtor.\n\n13. Documents sufficient to show all of Your Assets and sources of income or funding.\n\n14. For all Assets identified in response to Request 14 having a value of more than \\$50,000, all (i) Documents related to Your acquisition of such Asset and (ii) Communications with the Debtor or the Debtor's Family regarding such Asset.\n\n15. Copies of Your tax returns.\n\n16. Documents sufficient to show all bank accounts and investment accounts within Your possession or control, including the balances of and transfers to and from each such account.\n\n17. All Documents regarding any credit cards used by You, including without limitation monthly statements or other Documents sufficient to show all purchases related thereto for the benefit of the Debtor or an Associated Entity.\n\n18. All corporate governance and organizational Documents, including without limitation by-laws and certificates of incorporation and other Documents sufficient to show Your corporate structure, names of officers and directors, business purpose, and relationship to the Debtor or to any member of the Debtor's Family.\n\n19. All Documents related to any pledge(s) of Your Assets to any other Entity.\n\nCase 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 949 of 1063\n\n# Exhibit C-52\n\n#### B2540 (Form 2540 – Subpoena for Rule 2004 Examination) (12/15) Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 950 of\n\n1063\n\nUNITED STATES BANKRUPTCY COURT\n\n**District of Connecticut**\n\nIn re HO WAN KWOK, *et al*.,\n\n<sup>1</sup> Case No. 22-50073 (JAM) Debtor Chapter 11\n\n(Jointly Administered)\n\n# **SUBPOENA FOR RULE 2004 EXAMINATION**\n\nTo: **HHS Capital Inc.**\n\n(*Name of person to whom the subpoena is directed*)\n\n*Testimony:* **YOU ARE COMMANDED** to appear at the time, date, and place set forth below to testify at an examination under Rule 2004, Federal Rules of Bankruptcy Procedure. A copy of the court order authorizing the examination is attached.\n\n| PLACE                    | DATE AND TIME |\n|--------------------------|---------------|\n| Paul Hastings LLP        |               |\n| 200 Park Avenue          | [TBD]         |\n| New York, New York 10166 |               |\n|                          |               |\n\nThe examination will be recorded by this method: **Court reporter/stenographer**\n\n*Production:* You, or your representatives, must also bring with you to the examination the following documents, electronically stored information, or objects, and must permit inspection, copying, testing, or sampling of the material:\n\n#### **See Requests for Production of Documents, attached hereto.**\n\nThe following provisions of Fed. R. Civ. P. 45, made applicable in bankruptcy cases by Fed. R. Bankr. P. 9016, are attached – Rule 45(c), relating to the place of compliance; Rule 45(d), relating to your protection as a person subject to a subpoena; and Rule 45(e) and 45(g), relating to your duty to respond to this subpoena and the potential consequences of not doing so.\n\nDate: **March , 2023**\n\nCLERK OF COURT\n\nOR\n\n*Signature of Clerk or Deputy Clerk Attorney's signature*\n\nThe name, address, email address, and telephone number of the attorney representing Luc A. Despins, Chapter 11 Trustee, who issues or requests this subpoena, are:\n\n**Douglas S. Skalka, Esq.; Neubert, Pepe & Monteith, P.C.; 195 Church Street, New Haven, Connecticut 06510 dskalka@npmlaw.com; (203) 821-2000**\n\n**Notice to the person who issues or requests this subpoena**\n\nIf this subpoena commands the production of documents, electronically stored information, or tangible things, or the inspection of premises before trial, a notice and a copy of this subpoena must be served on each party before it is served on the person to whom it is directed. Fed. R. Civ. P. 45(a)(4).\n\nSoftware Copyright (c) 1996-2022 Best Case, LLC - www.bestcase.com Best Case Bankruptcy 1 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\n#### **PROOF OF SERVICE**\n\n**(This section should not be filed with the court unless required by Fed. R. Civ. P. 45.)**\n\nI received this subpoena for (*name of individual and title, if any*): on (*date*) .\n\nI served the subpoena by delivering a copy to the named person as follows:\n\non *(date)* ; or\n\nI returned the subpoena unexecuted because:\n\nUnless the subpoena was issued on behalf of the United States, or one of its officers or agents, I have also tendered to the witness the fees for one day's attendance, and the mileage allowed by law, in the amount of \\$ .\n\nMy fees are \\$ for travel and \\$ for services, for a total of \\$ .\n\nI declare under penalty of perjury that this information is true and correct.\n\nDate:\n\n*Server's signature*\n\n*Printed name and title*\n\n*Server's address*\n\nAdditional information concerning attempted service, etc.:\n\n#### **Federal Rule of Civil Procedure 45(c), (d), (e), and (g) (Effective 12/1/13) (made applicable in bankruptcy cases by Rule 9016, Federal Rules of Bankruptcy Procedure)**\n\n#### **(c) Place of compliance.**\n\n*(1) For a Trial, Hearing, or Deposition.* A subpoena may command a person to attend a trial, hearing, or deposition only as follows:\n\n(A) within 100 miles of where the person resides, is employed, or regularly transacts business in person; or\n\n(B) within the state where the person resides, is employed, or regularly transacts business in person, if the person\n\n(i) is a party or a party's officer; or\n\n(ii) is commanded to attend a trial and would not incur substantial expense.\n\n*(2) For Other Discovery.* A subpoena may command:\n\n(A) production of documents, or electronically stored information, or things at a place within 100 miles of where the person resides, is employed, or regularly transacts business in person; and\n\n(B) inspection of premises, at the premises to be inspected.\n\n#### **(d) Protecting a Person Subject to a Subpoena; Enforcement.**\n\n*(1) Avoiding Undue Burden or Expense; Sanctions.* A party or attorney responsible for issuing and serving a subpoena must take reasonable steps to avoid imposing undue burden or expense on a person subject to the subpoena. The court for the district where compliance is required must enforce this duty and impose an appropriate sanction which may include lost earnings and reasonable attorney's fees — on a party or attorney who fails to comply.\n\n#### *(2) Command to Produce Materials or Permit Inspection.*\n\n*(A) Appearance Not Required.* A person commanded to produce documents, electronically stored information, or tangible things, or to permit the inspection of premises, need not appear in person at the place of production or inspection unless also commanded to appear for a deposition, hearing, or trial.\n\n*(B) Objections.* A person commanded to produce documents or tangible things or to permit inspection may serve on the party or attorney designated in the subpoena a written objection to inspecting, copying, testing or sampling any or all of the materials or to inspecting the premises — or to producing electronically stored information in the form or forms requested. The objection must be served before the earlier of the time specified for compliance or 14 days after the subpoena is served. If an objection is made, the following rules apply:\n\n(i) At any time, on notice to the commanded person, the serving party may move the court for the district where compliance is required for an order compelling production or inspection.\n\n(ii) These acts may be required only as directed in the order, and the order must protect a person who is neither a party nor a party's officer from significant expense resulting from compliance.\n\n#### *(3) Quashing or Modifying a Subpoena.*\n\n*(A) When Required.* On timely motion, the court for the district where compliance is required must quash or modify a subpoena that:\n\n(i) fails to allow a reasonable time to comply;\n\n(ii) requires a person to comply beyond the geographical limits specified in Rule 45(c);\n\n(iii) requires disclosure of privileged or other protected matter, if no exception or waiver applies; or\n\n(iv) subjects a person to undue burden.\n\n*(B) When Permitted.* To protect a person subject to or affected by a subpoena, the court for the district where compliance is required may, on motion, quash or modify the subpoena if it requires:\n\n(i) disclosing a trade secret or other confidential research, development, or commercial information; or\n\n(ii) disclosing an unretained expert's opinion or information that does not describe specific occurrences in dispute and results from the expert's study that was not requested by a party.\n\n(C) *Specifying Conditions as an Alternative.* In the circumstances described in Rule 45(d)(3)(B), the court may, instead of quashing or modifying a subpoena, order appearance or production under specified conditions if the serving party:\n\n(i) shows a substantial need for the testimony or material that cannot be otherwise met without undue hardship; and\n\n(ii) ensures that the subpoenaed person will be reasonably compensated.\n\n#### **(e) Duties in Responding to a Subpoena.**\n\n*(1) Producing Documents or Electronically Stored Information.* These procedures apply to producing documents or electronically stored information:\n\n*(A) Documents.* A person responding to a subpoena to produce documents must produce them as they are kept in the ordinary course of business or must organize and label them to correspond to the categories in the demand.\n\n*(B) Form for Producing Electronically Stored Information Not Specified.* If a subpoena does not specify a form for producing electronically stored information, the person responding must produce it in a form or forms in which it is ordinarily maintained or in a reasonably usable form or forms.\n\n*(C) Electronically Stored Information Produced in Only One Form.* The person responding need not produce the same electronically stored information in more than one form.\n\n*(D) Inaccessible Electronically Stored Information.* The person responding need not provide discovery of electronically stored information from sources that the person identifies as not reasonably accessible because of undue burden or cost. On motion to compel discovery or for a protective order, the person responding must show that the information is not reasonably accessible because of undue burden or cost. If that showing is made, the court may nonetheless order discovery from such sources if the requesting party shows good cause, considering the limitations of Rule 26(b)(2)(C). The court may specify conditions for the discovery.\n\n#### *(2) Claiming Privilege or Protection.*\n\n*(A) Information Withheld.* A person withholding subpoenaed information under a claim that it is privileged or subject to protection as trial-preparation material must: (i) expressly make the claim; and\n\n(ii) describe the nature of the withheld documents, communications, or tangible things in a manner that, without revealing information itself privileged or protected, will enable the parties to assess the claim.\n\n*(B) Information Produced.* If information produced in response to a subpoena is subject to a claim of privilege or of protection as trial-preparation material, the person making the claim may notify any party that received the information of the claim and the basis for it. After being notified, a party must promptly return, sequester, or destroy the specified information and any copies it has; must not use or disclose the information until the claim is resolved; must take reasonable steps to retrieve the information if the party disclosed it before being notified; and may promptly present the information under seal to the court for the district where compliance is required for a determination of the claim. The person who produced the information must preserve the information until the claim is resolved.\n\n**(g) Contempt.** The court for the district where compliance is required – and also, after a motion is transferred, the issuing court – may hold in contempt a person who, having been served, fails without adequate excuse to obey the subpoena or an order related to it.\n\nFor access to subpoena materials, see Fed.R.Civ.P.45(a) Committee Note (2013)\n\n…\n\n## **Requests for Production of Documents**\n\n## **I. INSTRUCTIONS**\n\n1. Unless otherwise indicated, the requests for documents set forth below, (the \"Requests,\" and each, a \"Request\"), must be responded to separately and specifically. Each Request shall be answered fully unless it is in good faith objected to, in which event the reason for Your objection shall be stated in detail, as set forth below. If an objection pertains only to a portion of a Request, or a word, phrase or clause contained within it, You are required to state Your objection to that portion only and to respond to the remainder of the Requests.\n\n2. Electronically stored information must be produced in accordance with the\n\nfollowing instructions:\n\n- a. Images. Black and white images must be 300 DPI Group IV single-page TIFF files. Color images must be produced in JPEG format. File names cannot contain embedded spaces or special characters (including the comma). Folder names cannot contain embedded spaces or special characters (including the comma). All TIFF image files must have a unique file name, i.e. Bates number. Images must be endorsed with sequential Bates numbers in the lower right corner of each image. The number of TIFF files per folder should not exceed 1000 files. Excel spreadsheets should have a placeholder image named by the Bates number of the file.\n- b. Image Load File\n\t- a. Concordance® Data File. The data file (.DAT) contains all of the fielded information that will be loaded into the Concordance® database. The first line of the .DAT file must be a header row identifying the field names. The .DAT file must use the following Concordance® default delimiters: Comma ASCII character (020) Quote þ ASCII character (254). Date fields should be provided in the format: mm/dd/yyyy. Date and time fields must be two separate fields. If documents includes imaged emails and attachments, the attachment fields must be included to preserve the parent/child relationship between an email and its attachments. An OCRPATH field must be included to provide the file path and name of the extracted text file on the produced storage media. The text file must be named after the FIRSTBATES. Do not include the text in the .DAT file. For Documents with native files, a LINK field must be included to provide the file path and\n\nname of the native file. The native file must be named after the FIRSTBATES.\n\n- b. Concordance Image® OR Opticon Cross-Reference File. The image crossreference file (.LOG or .OPT) links the images to the database records. It should be a comma-delimited file consisting of seven fields per line with a line in the cross-reference file for every image in the database with the following format: ImageID,VolumeLabel,ImageFilePath,DocumentBreak,FolderBreak,Box Break,PageCoun.\n- c. Document Text. Text must be produced as separate text files, not as fields within the .DAT file. The full path to the text file (OCRPATH) should be included in the .DAT file. It is recommended document level ANSI text files, named per the FIRSTBATES/Image Key. Extracted text files must be in a separate folder, and the number of text files per folder should not exceed 1,000 files. There should be no special characters (including commas in the folder names). Text files must be provided on a document level.\n- d. Native Production for Certain File Types. File types that reasonably require viewing in their native format for a full understanding of their content and meaning must be produced in native format. These include, but are not limited to, spreadsheets, spreadsheet-like files (Microsoft Excel, comma separated values, tab separated values, etc.), Microsoft PowerPoint or other special presentation files, database files, and audio/visual files. Provide an image of a Bates numbered slip sheet indicating the presence of a native file, and include the path to the native as a field in the .dat file. Name the produced native file with the Bates number corresponding to the slip sheet for the file. Group native files within incrementally named \"NATIVE\" directories, separate from images directories.\n- e. De-duplication. Produce a single copy of each electronic document for which exact duplicates exist. For email messages, consolidate duplicates based on MD5 hash generated from the BCC, Body, CC, From, IntMsgID, To, and Attach properties. For email attachments and standalone electronic files, consolidate duplicates based on MD5 hash of the entire file.\n- f. Metadata. Produce extracted metadata for each document in the form of a Concordance compliant load file (.dat). The first line of the .DAT file must be a header row identifying the field names. The .DAT file must use the following Concordance default delimiters: Comma , ASCII character (020) Quote þ ASCII character (254)\n\nDate fields should be provided in the format: mm/dd/yyyy. Date and time fields must be two separate fields. Required metadata listed below:\n\n# Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 955 of 1063\n\n| Field Name   | Sample Data              | Description                                                                                  |\n|--------------|--------------------------|----------------------------------------------------------------------------------------------|\n| FIRSTBATES   | EDC0000001               | First Bates number of native file document/email                                             |\n| LASTBATES    | EDC0000001               | Last Bates number of native file document/email<br>**The LASTBATES field should be populated |\n|              |                          | for single page                                                                              |\n| ATTACHRANGE  | EDC0000001<br>-          | Bates number of the first page of the parent                                                 |\n|              | EDC0000015               | document to the Bates number of the last page of                                             |\n|              |                          | the last attachment \"child\" document                                                         |\n| BEGATTACH    | EDC0000001               | First Bates number of attachment range                                                       |\n| ENDATTACH    | EDC0000015               | Last Bates number of attachment range                                                        |\n| CUSTODIAN    | Smith, John              | Email: Mailbox where the email resided                                                       |\n|              |                          | Native: Name of the individual or department                                                 |\n|              |                          | from whose files the document<br>originated                                                  |\n| FROM         | John Smith               | Email: Sender                                                                                |\n|              |                          | Native: Author(s) of document                                                                |\n|              |                          | **semi-colon should be used to separate                                                      |\n|              |                          | multiple entries                                                                             |\n| TO           | Coffman, Janice; LeeW    | Recipient(s)                                                                                 |\n|              | [mailto:LeeW@MSN.com]    | **semi-colon should be used to separate multiple                                             |\n|              |                          | entries                                                                                      |\n| CC           | Frank Thompson [mailto:  | Carbon copy recipient(s)                                                                     |\n|              | frank_Thompson@cdt.com]  | **semi-colon should be used to separate                                                      |\n|              |                          | multiple entries                                                                             |\n| BCC          | John Cain                | Blind carbon copy recipient(s)                                                               |\n|              |                          | **semi-colon should be used to separate                                                      |\n|              |                          | multiple entries                                                                             |\n| SUBJECT      | Board Meeting Minutes    | Email: Subject line of the email Native: Title                                               |\n|              |                          | of document (if available)                                                                   |\n| FILE_NAME    | BoardMeetingMinutes.docx | Native: Name of the original native file,                                                    |\n|              |                          | including extension                                                                          |\n| DATE_SENT    | 10/12/2010               | Email: Date the email was sent                                                               |\n|              |                          | Native: (empty)                                                                              |\n| TIME_SENT/   | 07:05 PM GMT             | Email: Time the email was sent/ Time zone in                                                 |\n| TIME_ZONE    |                          | which the emails were standardized                                                           |\n| TIME_ZONE    | GMT                      | The<br>time zone in which<br>the emails<br>were                                              |\n|              |                          | standardized during conversion.                                                              |\n| LINK         |  EDC0000001.msg   | Hyperlink to the email or native file document                                               |\n|              |                          | **The linked file must be named per the                                                      |\n|              |                          | FIRSTBATES number                                                                            |\n| FILE_EXTEN   | MSG                      | The file type extension                                                                      |\n|              |                          | representing                                                                                 |\n|              |                          | the Email or                                                                                 |\n| AUTHOR       | John Smith               | Email: (empty)                                                                               |\n|              |                          | Native: Author of the document                                                               |\n| DATE_CREATED | 10/10/2010               | Email: (empty)                                                                               |\n|              |                          | Native: Date the document was created                                                        |\n\n# Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 956 of 1063\n\n| TIME_CREATED | 10:25 AM                  | Email: (empty)                                  |\n|--------------|---------------------------|-------------------------------------------------|\n|              |                           | Native: Time the document was created           |\n|              |                           | **This data must be a separate field and cannot |\n|              |                           | be combined with the DATE_CREATED field         |\n| DATE_MOD     | 10/12/2010                | Email: (empty)                                  |\n|              |                           | Native: Date the document was last modified     |\n| TIME_MOD     | 07:00 PM                  | Email: (empty)                                  |\n|              |                           | Native: Time the document was last modified     |\n|              |                           | **This data must be a separate field and cannot |\n|              |                           | be combined with the DATE_MOD field             |\n| DATE_ACCESSD | 10/12/2010                | Email: (empty)                                  |\n|              |                           | Native: Date the document was last accessed     |\n| TIME_ACCESSD | 07:00 PM                  | Email: (empty)                                  |\n|              |                           | Native: Time the document was last accessed     |\n|              |                           | **This data must be a separate field and cannot |\n|              |                           | be combined with the DATE_ACCESSD field         |\n| FILE_SIZE    | 5,952                     | Size of native file<br>document/email in KB     |\n| PGCOUNT      | 1                         | Number of pages in native file document/email   |\n| PATH         |   | Email: (empty)                                  |\n|              | Agenda.doc                | Native: Path where native file document was     |\n|              |                           | stored including original file name.            |\n| INTFILEPATH  | Personal Folders\\Deleted  | Email: original location of email including     |\n|              | Items\\Board Meeting       | original file name.                             |\n|              | Minutes.msg               | Native: (empty)                                 |\n| INTMSGID     | <000805c2c71b\\$75977050\\$ | Email: Unique Message ID Native: (empty)        |\n|              | cb8306d1@MSN>             |                                                 |\n| MD5HASH      | d131dd02c5e6eec4693d9a0   | MD5 Hash value of the document.                 |\n|              | 698aff95c                 |                                                 |\n|              | 2fcab58712467eab4004583e  |                                                 |\n|              | b8fb7f89                  |                                                 |\n| OCRPATH      | TEXT/001/EDC0000001.txt   | Path to extracted text of the native file       |\n\n3. Each Request operates and should be construed independently and, unless otherwise indicated, no Request limits the scope of any other Request.\n\n4. All Documents are to be produced as kept in the usual course of business or are to be organized and labeled to correspond with the categories in these Requests.\n\n5. Each Request contained herein extends to all Documents: (a) in Your possession, custody, or control; or (b) in the possession, custody, or control of anyone acting on Your behalf,\n\n#### Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 957 of 1063\n\nincluding Your counsel or other representatives and advisors. Each Document shall be produced in its entirety.\n\n6. If You are requested to produce a Document that is no longer in Your possession, custody, or control, then Your response must (a) describe in detail the nature of the document and its contents; (b) identify the person(s) who prepared or authored the Document (and, if applicable, the Person(s) to whom the Document was sent); (c) identify the date on which the document was prepared or created; (d) state whether such Document (i) is missing or lost, (ii) has been destroyed, (iii) has been transferred, voluntarily or involuntarily, to others, or (iv) was otherwise disposed of; (e) state the reason for, and the facts and circumstances surrounding, such disposition; (f) identify the Persons who authorized such disposition; (g) identify the date or approximate date of such disposition; (h) state when the Document was most recently in Your possession, custody or control; and (i) identify the Person, if any, presently in possession, custody, or control of such Document.\n\n7. If You are requested to produce a Document that has been destroyed, then Your response must state, in addition to the information required by the preceding Instruction: (a) the reason for the Document's destruction; (b) the identity of the Person who destroyed the Document; and (c) the identity of the Person who directed that the Document be destroyed.\n\n8. If You claim that a requested Document is privileged or attorney work-product, then Your response must: (a) state (i) a description of the Document adequate to support Your contention that the Document is privileged, (ii) the title of the Document, (iii) the date of the Document, (iv) the author of the Document, (v) the addressee of the Document, (vi) the identity of each Person who received or saw the original or any draft, copy, or reproduction of the Document, (vii) whether the Document itself, or any information contained or referred to in the Document is in the possession, custody, or control of any other Persons, and if so, the identity of\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 958 of 1063\n\nsuch Persons, as well as a statement addressing how the information came into their possession, (viii) the claim of privilege under which the Document is withheld, and (ix) all of the circumstances upon which You will rely to support such claim of privilege; and (b) produce a privilege log containing all of the information requested in Part (a) of this Instruction for each Document withheld on the basis of a claim of privilege in accordance with D. Conn. L. Civ. R. 26(e).\n\n9. If a portion of an otherwise responsive Document contains information subject to a claim of privilege, only that portion of the Document subject to the claim of privilege shall be deleted or redacted from the Document following the instructions above, and the rest shall be produced.\n\n10. The Requests are continuing in nature. You are hereby instructed to (a) supplement or correct any responses later learned to be incomplete or incorrect immediately upon learning that a prior response was incomplete or incorrect; and (b) produce any additional Documents that are called for under the\n\n11. If a Document is in a language other than English, You should provide that Document. If a Document is in a language other than English, and an English translation exists, You should provide both Documents.\n\n12. All references to Entities includes all affiliates thereof.\n\n13. All references to individual names include all alternative names, aliased, or nicknames.\n\n14. Unless otherwise expressly indicated, the period of time covered by the Document Requests is the period from February 5, 2012 to the date responses to the Document Requests are due.\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 959 of 1063\n\n#### **II. RULES OF CONSTRUCTION**\n\n15. The use of (a) any singular noun shall be construed to include the plural, and vice versa, and (b) a verb in any tense shall be construed as the use of the verb in all other tenses.\n\n16. The terms (a) \"and\" and \"or\" shall be construed either conjunctively or disjunctively as necessary to bring within the scope of any request all responses that might otherwise be construed to be outside of its scope, and (b) \"each\" and \"any\" shall be deemed to include and encompass the words \"every\" and \"all.\"\n\n#### **III. DEFINITIONS**\n\nThe definitions supplied by D. Conn. L. Civ. R. 26(c) and the rules of construction supplied by D. Conn. L. Civ. R. 26(d), as incorporated by D. Conn. Bankr. L.R. 2004-1(a), shall apply to the Document Requests. In addition, the following terms used in these Document Requests shall have the following meanings:\n\n1. \"You\" or \"Your\" or \"Yourself\" means and refers to HHS Capital Inc., together with all of its affiliates, divisions, agencies, instrumentalities, departments, offices, partners, officers, directors, agents, attorneys, representatives, employees, and/or anyone acting on its behalf.\n\n2. \"Debtor\" means Ho Wan Kwok (a/k/a Miles Kwok, Miles Guo, Guo Wengui, Guo Haoyun, 郭文贵, or any other alias), together with his employees, agents, counsel, advisors, or anyone acting on his behalf.\n\n3. \"Debtor's Son\" means Qiang Guo (a/k/a Mileson Kwok, 郭强, or any other alias), together with his employees, agents, counsel, advisors, or anyone acting on his behalf.\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 960 of 1063\n\n4. \"Debtor's Daughter\" means Mei Guo (a/k/a Mei Gui, 郭美, or any other alias), together with her employees, agents, counsel, advisors, or anyone acting on her behalf.\n\n5. \"Debtor's Purported Wife\" means Hing Chi Ngok (a/k/a Hing Chi Ng, Yue Qingzhi, 岳庆芝, or any other alias), together with her employees, agents, counsel, advisors, or anyone acting on her behalf.\n\n6. \"Debtor's Family\" means, collectively, the Debtor, the Debtor's Son, the Debtor's Daughter, and the Debtor's Purported Wife, and any other familial relation to the Debtor.\n\n7. \"Associated Individuals\" means, individually and collectively, all individuals that (1) hold, control, have custody over, or discretion over assets owned, controlled, or enjoyed by the Debtor or the Debtor's Family; or (2) have been employees, directors, or otherwise are affiliated with one or more Associated Entities, together with the respective employees, agents, counsel, advisors, or anyone acting on behalf of any of the foregoing. Such Associated Individuals shall include, but are not limited to: Daniel Podhaskie, Jason Miller, Steve Bannon, Karin Maistrello, Melissa Francis, Anthony DiBattista, William Gertz, Arethusa Forsyth, Glenn Mellor, Jennifer Mercurio, Eduardo Eurnekian, Wencong Wang, Han Chunguang (a/k/a 韩春光), Qu Guojiao (a/k/a Qu Guo Jiao, 屈国姣), Guo Lijie (a/k/a 郭丽杰), Zhang Wei (a/k/a 张伟\\*), Lihong Wei Lafrenz (a/k/a Sara Wei, 魏丽红), Hao Haidong (a/k/a 郝海东), Ross Heinemeyer, Max Krasner, Kyle Bass, Melissa Mendez, Ya Li (a/k/a 李娅), Dinggang Wang (a/k/a 王定刚), An Hong (a/k/a 安红), Yvette Wang (a/k/a Yanping Wang, Yan Ping Wang, 王雁平), Fiona Yu, Je Kin Ming (a/k/a William Je, Yu Jianming, 余建明), Yaz Qingua, and Lao Jiang (a/k/a Jiang Yunfu, Jiang Yunfu Be, 姜云浮).\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 961 of 1063\n\n8. \"Associated Entities\" means, individually and collectively, all organizations or Entities of any type that (1) have been owned, controlled, or invested in by the Debtor or the Debtor's Family; or (2) have an interest, whether directly or indirectly, in any assets owned, controlled, or enjoyed by the Debtor or the Debtor's Family, together with the respective employees, agents, counsel, advisors, or anyone acting on behalf of any of the foregoing. Such Associated Entities shall include, but are not limited to: 7 Nod Hill LLC, AAGV Limited, ACA Investment Management Limited, ACA Capital Group Limited, Ace Decade Holdings Limited, AI Group Holdings Inc., Alfa Global Ventures Limited, Alfonso Global Limited, Allied Capital Global Limited, Alpine Fiduciaries SA, Anton Development Limited, Assets Sino Limited, Auspicious Coast Limited, Beijing Pangu Investment Co., Beijing Pangu Investment Co. Ltd., Beijing Pangu Investment Inc., Beijing Zenith Holdings Company Limited, Booming Sail New York LLC, Bravo Luck Limited, BSA Strategic Fund I, China Golden Spring (Hong Kong) Limited, Chuang Xin Limited, Crane Advisory Group LLC, Creative Apex Investments Limited, Crystal Breeze Investments Limited, Dawn State Limited, Eastern Profit Corporation Limited, Elite Well Global Limited, Empire Growth Holdings, Freedom Media Ventures Ltd., G Club Operations LLC, G Fashion LLC, G News LLC, GETTR USA, Genever Holdings Corporation, Genever Holdings LLC, Gfashion Media Group Inc., GFNY, Inc., Globalist International Limited, GNews Media Group Inc., Golden Spring (New York) Ltd., Greenwich Land LLC, Guo Media, GTV Media Group, Inc., Hamilton Capital Holdings Inc., HCHK Property Management, Inc., HCHK Technologies, Inc., Head Win Group Limited, Henan Yuda, Himalaya Embassy, Himalaya Exchange, Himalaya Federal Reserve, Himalaya Investment LLC, Himalaya International, Himalaya New World Inc., Himalaya Supervisory Organization, Himalaya Ventures LLC, HK International Funds Investments (USA) Limited LLC, Hong Kong International Funds\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 962 of 1063\n\nInvestments Limited, Hudson Diamond Holding, Infinite Increase Limited, Infinitum Developments Limited, Infinity Treasury Management Inc., Insight Phoenix Fund, Lamp Capital LLC, Leading Shine Limited, Leading Shine NY Limited, Lexington Property and Staffing, Long Gate Limited, Maywind Trading LLC, MOS Himalaya LLC, Next Tycoon Investments Limited, New Federal State of China (a/k/a NFSC), Noble Fame Global Limited, Rosy Acme Ventures Limited, Rule of Law Foundation III, Inc., Rule of Law Foundation IV, Inc., Rule of Law Fund, Rule of Law Society, Rule of Law Society IV, Inc., G-Translators PTY LTD, Saraca Media Group, Inc., Shiny Ace Ltd., Shiny Times Holdings Ltd., Spirit Charter Investment Limited, Stevenson, Wong & Co., Voice of Guo Media, Inc., Well Origin Ltd., World Century Limited, Worldwide Opportunity Holdings Limited, Whitecroft Shore Limited, and ZIBA Limited.\n\n9. \"Including\" or any variant thereof means \"including without limitation.\"\n\n10. \"And\" and \"or\" mean \"and/or,\" and shall be construed both conjunctively as well as disjunctively in order to maximize their scope.\n\n11. \"Any\" and \"all\" and \"each\" mean \"each and every.\"\n\n12. \"Each\" and \"every\" mean \"each and every.\"\n\n13. \"Third Party\" means a Person or Entity other than Yourself.\n\n14. \"Transfer\" shall have the meaning given to it by section 101(54) of the Bankruptcy Code.\n\n15. \"Document\" means any information or thing within the scope of Fed. R. Civ. P. 34, and includes, without limitation, each and every written, recorded, or graphic matter of any kind, type, nature, or description that is or has been in Your Possession, Custody or Control, including all printed and electronic copies of electronic mail, computer files maintained in\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 963 of 1063\n\nelectronic form, electronic communication, text message, social media post, tweet, meta-data, correspondence, memoranda, tapes, stenographic or handwritten notes, written forms of any kind, charts, blueprints, drawings, sketches, graphs, plans, articles, specifications, diaries, letters, telegrams, photographs, minutes, contracts, agreements, surveys, computer printouts, data compilations of any kind, telexes, facsimiles, voice messages, invoices, order forms, checks, drafts, statements, credit memos, reports, position reports, summaries, indices, books, ledgers, notebooks, schedules, transparencies, recordings, catalogs, advertisements, promotional materials, films, video tapes, audio tapes, CDs, computer disks, brochures, pamphlets, punchcards, time-slips, Tweets, social media posts, or any written or recorded materials of any other kind, and all meta-data thereof, however stored (whether in tangible or electronic form), recorded, produced, or reproduced, and also including but not limited to, drafts or copies of any of the foregoing that contain any notes, comments, or markings of any kind not found on the original documents or that are otherwise not identical to the original documents.\n\n16. \"Person(s)\" means an individual, corporation, proprietorship, partnership, association, or any other Entity. \"Person\" also includes any agent, representatives, or expert, including but not limiting to, attorneys or financial advisors.\n\n17. \"Entity\" means any natural Person, corporation, partnership, subsidiary, sole proprietorship, firm, board, joint venture, association, agency, authority, commission or other business entity or juristic Person, as well as any affiliate, agent, parent including but not limited to legal counsel, financial advisors, or any other representative.\n\n18. \"Regarding\" means concerning, describing, comprising, referring to, related to, supporting, favoring, opposing, bolstering, detracting from, located in, considered in connection with, bearing on, evidencing, indicating, reporting on, recording, alluding to, responding to,\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 964 of 1063\n\nconnected with, commenting on, in respect of, about, in relation to, discussing, showing, describing, reflecting, analyzing constituting, and being.\n\n19. \"Relating to,\" \"relate(s) to\" or \"related to,\" when referring to any given subject matter, means, without limitation, any document that constitutes, comprises, involves, contains, embodies, reflects, identifies, states, refers directly or indirectly to, or is in any way relevant to the particular subject matter identified.\n\n20. \"Communication(s)\" means, in the broadest possible sense, and without limitation, any transmittal of information or knowledge (in the form of facts, ideas, inquiries, or otherwise). Communication(s) further refers to all conversations, agreements, inquiries, or replies, whether in person, by telephone, in writing, or by means of electronic transmittal devices, and includes, but is not limited to, all correspondence, emails, recordings, transmittal slips, memoranda, telephone communications, voice messages, telegrams, telefaxes, telecopies, telexes, instant messages, chats, text messages, telephonic notes, or notes transmitted internally or with third parties.\n\n21. \"Asset(s)\" means any item that can be used to produce positive economic value, including but not limited to any resource with economic value that is owned, controlled or is for the benefit of an entity, that is expected to provide a future benefit, including but not limited to, all real and personal property, intangible property, investments, rights to invest or to future revenue, cash, bank accounts, commodities, securities, claims, total or partial control of an entity, and prospective economic opportunities\n\n22. \"Transfer\" shall have the meaning given to it by section 101(54) of the Bankruptcy Code.\n\n#### **IV. DOCUMENTS TO BE PRODUCED**\n\n1. All Documents regarding any income or Asset of the Debtor, the Debtor's estate, or an Associated Entity.\n\n2. All Documents related to the Debtor's financial condition and obligations to his creditors, including without limitation all Documents related to any effort to avoid paying such obligations and All Documents related to this or any other actual or potential bankruptcy or similar insolvency proceeding.\n\n3. All Documents regarding any balance sheet, bank statement, account statement, financial statement, statement of account, wire transfer instructions and/or confirmation, proof of funds, certificate of deposit, certificate of holdings, investment portfolio summary, or similar document relating to the Debtor, the Debtor's Estate, the Debtor's Family, an Associated Entity, or an Associated Individual, including without limitation all Documents sufficient to show all Transfers to any of the foregoing.\n\n4. All Documents regarding any investment, business dealing or transactions made by, with, or on behalf of the Debtor.\n\n5. All Communications with the Debtor, and Documents related to Communications with the Debtor, related to the operation, management, or decision-making of any Entity, including without limitation the Associated Entities.\n\n6. All Documents regarding any Transfer, investment, or other transaction or business dealing made to, by, or with the Debtor, the Debtor's Family, or an Associated Entity.\n\n7. All Documents regarding any property ever occupied or used by the Debtor, including without limitation the *Lady May*; the Sherry Netherland Hotel / Condominium; the\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 966 of 1063\n\nresidential property located in Greenwich, Connecticut at 373 Taconic Rd.; the residential property located in Greenwich, Connecticut at 33 Ferncliff Rd.; and the residential property located in Wilton, Connecticut at 354 Nod Hill Rd.\n\n8. All Documents related to any aircraft owned, controlled, or used by the Debtor, including without limitation the aircraft bearing tail number T7-GQM and any other aircraft registered in San Marino, including without limitation copies of all registration documents and flight manifests showing flights taken by such aircraft and the individuals onboard such flights.\n\n9. All Documents regarding any gifts, benefits or loans, to, from or on behalf of the Debtor, the Debtor's Estate, the Debtor's Family, or the Associated Entities, including without limitation Documents sufficient to show the amounts of such gifts, benefits, or loans; the purposes for which such gifts, benefits, or loans were used; when the gifts, benefits, or loans were provided; and the terms of any loans, all representations and warranties made in connection with any loans, the interest rate on any loans, and all evidence of payments of any loans.\n\n10. All Documents concerning any trust or similar instrument set up by, on behalf of, or for the benefit of the Debtor, the Debtor's Estate, the Debtor's Family, or an Associated Entity, including without limitation Documents sufficient to show when the trust(s) was created, by whom it was created, for whose benefit it was created, and the corpus of the trust.\n\n11. All Documents related to any obligation, claim, liability, or debt associated with any legal dispute involving the Debtor, including but not limited to those relating to any litigation before any local, state, federal, or international body, whether an administrative body, court, panel, or alternative dispute resolution entity.\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 967 of 1063\n\n12. All Documents and communications between any of your outside counsel or other advisors and the Debtor.\n\n13. Documents sufficient to show all of Your Assets and sources of income or funding.\n\n14. For all Assets identified in response to Request 14 having a value of more than \\$50,000, all (i) Documents related to Your acquisition of such Asset and (ii) Communications with the Debtor or the Debtor's Family regarding such Asset.\n\n15. Copies of Your tax returns.\n\n16. Documents sufficient to show all bank accounts and investment accounts within Your possession or control, including the balances of and transfers to and from each such account.\n\n17. All Documents regarding any credit cards used by You, including without limitation monthly statements or other Documents sufficient to show all purchases related thereto for the benefit of the Debtor or an Associated Entity.\n\n18. All corporate governance and organizational Documents, including without limitation by-laws and certificates of incorporation and other Documents sufficient to show Your corporate structure, names of officers and directors, business purpose, and relationship to the Debtor or to any member of the Debtor's Family.\n\n19. All Documents related to any pledge(s) of Your Assets to any other Entity.\n\nCase 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 968 of 1063\n\n# Exhibit C-53\n\n#### B2540 (Form 2540 – Subpoena for Rule 2004 Examination) (12/15) Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 969 of\n\n1063\n\nUNITED STATES BANKRUPTCY COURT\n\n**District of Connecticut**\n\nIn re HO WAN KWOK, *et al*.,\n\n<sup>1</sup> Case No. 22-50073 (JAM) Debtor Chapter 11\n\n(Jointly Administered)\n\n## **SUBPOENA FOR RULE 2004 EXAMINATION**\n\nTo: **Medical Supply System International LLC**\n\n(*Name of person to whom the subpoena is directed*)\n\n*Testimony:* **YOU ARE COMMANDED** to appear at the time, date, and place set forth below to testify at an examination under Rule 2004, Federal Rules of Bankruptcy Procedure. A copy of the court order authorizing the examination is attached.\n\n| PLACE                    | DATE AND TIME |\n|--------------------------|---------------|\n| Paul Hastings LLP        |               |\n| 200 Park Avenue          | [TBD]         |\n| New York, New York 10166 |               |\n|                          |               |\n\nThe examination will be recorded by this method: **Court reporter/stenographer**\n\n*Production:* You, or your representatives, must also bring with you to the examination the following documents, electronically stored information, or objects, and must permit inspection, copying, testing, or sampling of the material:\n\n#### **See Requests for Production of Documents, attached hereto.**\n\nThe following provisions of Fed. R. Civ. P. 45, made applicable in bankruptcy cases by Fed. R. Bankr. P. 9016, are attached – Rule 45(c), relating to the place of compliance; Rule 45(d), relating to your protection as a person subject to a subpoena; and Rule 45(e) and 45(g), relating to your duty to respond to this subpoena and the potential consequences of not doing so.\n\nDate: **March , 2023**\n\nCLERK OF COURT\n\nOR\n\n*Signature of Clerk or Deputy Clerk Attorney's signature*\n\nThe name, address, email address, and telephone number of the attorney representing Luc A. Despins, Chapter 11 Trustee, who issues or requests this subpoena, are:\n\n**Douglas S. Skalka, Esq.; Neubert, Pepe & Monteith, P.C.; 195 Church Street, New Haven, Connecticut 06510 dskalka@npmlaw.com; (203) 821-2000**\n\n**Notice to the person who issues or requests this subpoena**\n\nIf this subpoena commands the production of documents, electronically stored information, or tangible things, or the inspection of premises before trial, a notice and a copy of this subpoena must be served on each party before it is served on the person to whom it is directed. Fed. R. Civ. P. 45(a)(4).\n\nSoftware Copyright (c) 1996-2022 Best Case, LLC - www.bestcase.com Best Case Bankruptcy 1 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\n#### **PROOF OF SERVICE**\n\n**(This section should not be filed with the court unless required by Fed. R. Civ. P. 45.)**\n\nI received this subpoena for (*name of individual and title, if any*): on (*date*) .\n\nI served the subpoena by delivering a copy to the named person as follows:\n\non *(date)* ; or\n\nI returned the subpoena unexecuted because:\n\nUnless the subpoena was issued on behalf of the United States, or one of its officers or agents, I have also tendered to the witness the fees for one day's attendance, and the mileage allowed by law, in the amount of \\$ .\n\nMy fees are \\$ for travel and \\$ for services, for a total of \\$ .\n\nI declare under penalty of perjury that this information is true and correct.\n\nDate:\n\n*Server's signature*\n\n*Printed name and title*\n\n*Server's address*\n\nAdditional information concerning attempted service, etc.:\n\n#### **Federal Rule of Civil Procedure 45(c), (d), (e), and (g) (Effective 12/1/13) (made applicable in bankruptcy cases by Rule 9016, Federal Rules of Bankruptcy Procedure)**\n\n#### **(c) Place of compliance.**\n\n*(1) For a Trial, Hearing, or Deposition.* A subpoena may command a person to attend a trial, hearing, or deposition only as follows:\n\n(A) within 100 miles of where the person resides, is employed, or regularly transacts business in person; or\n\n(B) within the state where the person resides, is employed, or regularly transacts business in person, if the person\n\n(i) is a party or a party's officer; or\n\n(ii) is commanded to attend a trial and would not incur substantial expense.\n\n*(2) For Other Discovery.* A subpoena may command:\n\n(A) production of documents, or electronically stored information, or things at a place within 100 miles of where the person resides, is employed, or regularly transacts business in person; and\n\n(B) inspection of premises, at the premises to be inspected.\n\n#### **(d) Protecting a Person Subject to a Subpoena; Enforcement.**\n\n*(1) Avoiding Undue Burden or Expense; Sanctions.* A party or attorney responsible for issuing and serving a subpoena must take reasonable steps to avoid imposing undue burden or expense on a person subject to the subpoena. The court for the district where compliance is required must enforce this duty and impose an appropriate sanction which may include lost earnings and reasonable attorney's fees — on a party or attorney who fails to comply.\n\n#### *(2) Command to Produce Materials or Permit Inspection.*\n\n*(A) Appearance Not Required.* A person commanded to produce documents, electronically stored information, or tangible things, or to permit the inspection of premises, need not appear in person at the place of production or inspection unless also commanded to appear for a deposition, hearing, or trial.\n\n*(B) Objections.* A person commanded to produce documents or tangible things or to permit inspection may serve on the party or attorney designated in the subpoena a written objection to inspecting, copying, testing or sampling any or all of the materials or to inspecting the premises — or to producing electronically stored information in the form or forms requested. The objection must be served before the earlier of the time specified for compliance or 14 days after the subpoena is served. If an objection is made, the following rules apply:\n\n(i) At any time, on notice to the commanded person, the serving party may move the court for the district where compliance is required for an order compelling production or inspection.\n\n(ii) These acts may be required only as directed in the order, and the order must protect a person who is neither a party nor a party's officer from significant expense resulting from compliance.\n\n#### *(3) Quashing or Modifying a Subpoena.*\n\n*(A) When Required.* On timely motion, the court for the district where compliance is required must quash or modify a subpoena that:\n\n(i) fails to allow a reasonable time to comply;\n\n(ii) requires a person to comply beyond the geographical limits specified in Rule 45(c);\n\n(iii) requires disclosure of privileged or other protected matter, if no exception or waiver applies; or\n\n(iv) subjects a person to undue burden.\n\n*(B) When Permitted.* To protect a person subject to or affected by a subpoena, the court for the district where compliance is required may, on motion, quash or modify the subpoena if it requires:\n\n(i) disclosing a trade secret or other confidential research, development, or commercial information; or\n\n(ii) disclosing an unretained expert's opinion or information that does not describe specific occurrences in dispute and results from the expert's study that was not requested by a party.\n\n(C) *Specifying Conditions as an Alternative.* In the circumstances described in Rule 45(d)(3)(B), the court may, instead of quashing or modifying a subpoena, order appearance or production under specified conditions if the serving party:\n\n(i) shows a substantial need for the testimony or material that cannot be otherwise met without undue hardship; and\n\n(ii) ensures that the subpoenaed person will be reasonably compensated.\n\n#### **(e) Duties in Responding to a Subpoena.**\n\n*(1) Producing Documents or Electronically Stored Information.* These procedures apply to producing documents or electronically stored information:\n\n*(A) Documents.* A person responding to a subpoena to produce documents must produce them as they are kept in the ordinary course of business or must organize and label them to correspond to the categories in the demand.\n\n*(B) Form for Producing Electronically Stored Information Not Specified.* If a subpoena does not specify a form for producing electronically stored information, the person responding must produce it in a form or forms in which it is ordinarily maintained or in a reasonably usable form or forms.\n\n*(C) Electronically Stored Information Produced in Only One Form.* The person responding need not produce the same electronically stored information in more than one form.\n\n*(D) Inaccessible Electronically Stored Information.* The person responding need not provide discovery of electronically stored information from sources that the person identifies as not reasonably accessible because of undue burden or cost. On motion to compel discovery or for a protective order, the person responding must show that the information is not reasonably accessible because of undue burden or cost. If that showing is made, the court may nonetheless order discovery from such sources if the requesting party shows good cause, considering the limitations of Rule 26(b)(2)(C). The court may specify conditions for the discovery.\n\n#### *(2) Claiming Privilege or Protection.*\n\n*(A) Information Withheld.* A person withholding subpoenaed information under a claim that it is privileged or subject to protection as trial-preparation material must: (i) expressly make the claim; and\n\n(ii) describe the nature of the withheld documents, communications, or tangible things in a manner that, without revealing information itself privileged or protected, will enable the parties to assess the claim.\n\n*(B) Information Produced.* If information produced in response to a subpoena is subject to a claim of privilege or of protection as trial-preparation material, the person making the claim may notify any party that received the information of the claim and the basis for it. After being notified, a party must promptly return, sequester, or destroy the specified information and any copies it has; must not use or disclose the information until the claim is resolved; must take reasonable steps to retrieve the information if the party disclosed it before being notified; and may promptly present the information under seal to the court for the district where compliance is required for a determination of the claim. The person who produced the information must preserve the information until the claim is resolved.\n\n**(g) Contempt.** The court for the district where compliance is required – and also, after a motion is transferred, the issuing court – may hold in contempt a person who, having been served, fails without adequate excuse to obey the subpoena or an order related to it.\n\nFor access to subpoena materials, see Fed.R.Civ.P.45(a) Committee Note (2013)\n\n…\n\n## **Requests for Production of Documents**\n\n## **I. INSTRUCTIONS**\n\n1. Unless otherwise indicated, the requests for documents set forth below, (the \"Requests,\" and each, a \"Request\"), must be responded to separately and specifically. Each Request shall be answered fully unless it is in good faith objected to, in which event the reason for Your objection shall be stated in detail, as set forth below. If an objection pertains only to a portion of a Request, or a word, phrase or clause contained within it, You are required to state Your objection to that portion only and to respond to the remainder of the Requests.\n\n2. Electronically stored information must be produced in accordance with the\n\nfollowing instructions:\n\n- a. Images. Black and white images must be 300 DPI Group IV single-page TIFF files. Color images must be produced in JPEG format. File names cannot contain embedded spaces or special characters (including the comma). Folder names cannot contain embedded spaces or special characters (including the comma). All TIFF image files must have a unique file name, i.e. Bates number. Images must be endorsed with sequential Bates numbers in the lower right corner of each image. The number of TIFF files per folder should not exceed 1000 files. Excel spreadsheets should have a placeholder image named by the Bates number of the file.\n- b. Image Load File\n\t- a. Concordance® Data File. The data file (.DAT) contains all of the fielded information that will be loaded into the Concordance® database. The first line of the .DAT file must be a header row identifying the field names. The .DAT file must use the following Concordance® default delimiters: Comma ASCII character (020) Quote þ ASCII character (254). Date fields should be provided in the format: mm/dd/yyyy. Date and time fields must be two separate fields. If documents includes imaged emails and attachments, the attachment fields must be included to preserve the parent/child relationship between an email and its attachments. An OCRPATH field must be included to provide the file path and name of the extracted text file on the produced storage media. The text file must be named after the FIRSTBATES. Do not include the text in the .DAT file. For Documents with native files, a LINK field must be included to provide the file path and\n\nname of the native file. The native file must be named after the FIRSTBATES.\n\n- b. Concordance Image® OR Opticon Cross-Reference File. The image crossreference file (.LOG or .OPT) links the images to the database records. It should be a comma-delimited file consisting of seven fields per line with a line in the cross-reference file for every image in the database with the following format: ImageID,VolumeLabel,ImageFilePath,DocumentBreak,FolderBreak,Box Break,PageCoun.\n- c. Document Text. Text must be produced as separate text files, not as fields within the .DAT file. The full path to the text file (OCRPATH) should be included in the .DAT file. It is recommended document level ANSI text files, named per the FIRSTBATES/Image Key. Extracted text files must be in a separate folder, and the number of text files per folder should not exceed 1,000 files. There should be no special characters (including commas in the folder names). Text files must be provided on a document level.\n- d. Native Production for Certain File Types. File types that reasonably require viewing in their native format for a full understanding of their content and meaning must be produced in native format. These include, but are not limited to, spreadsheets, spreadsheet-like files (Microsoft Excel, comma separated values, tab separated values, etc.), Microsoft PowerPoint or other special presentation files, database files, and audio/visual files. Provide an image of a Bates numbered slip sheet indicating the presence of a native file, and include the path to the native as a field in the .dat file. Name the produced native file with the Bates number corresponding to the slip sheet for the file. Group native files within incrementally named \"NATIVE\" directories, separate from images directories.\n- e. De-duplication. Produce a single copy of each electronic document for which exact duplicates exist. For email messages, consolidate duplicates based on MD5 hash generated from the BCC, Body, CC, From, IntMsgID, To, and Attach properties. For email attachments and standalone electronic files, consolidate duplicates based on MD5 hash of the entire file.\n- f. Metadata. Produce extracted metadata for each document in the form of a Concordance compliant load file (.dat). The first line of the .DAT file must be a header row identifying the field names. The .DAT file must use the following Concordance default delimiters: Comma , ASCII character (020) Quote þ ASCII character (254)\n\nDate fields should be provided in the format: mm/dd/yyyy. Date and time fields must be two separate fields. Required metadata listed below:\n\n# Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 974 of 1063\n\n| Field Name   | Sample Data              | Description                                                                                  |\n|--------------|--------------------------|----------------------------------------------------------------------------------------------|\n| FIRSTBATES   | EDC0000001               | First Bates number of native file document/email                                             |\n| LASTBATES    | EDC0000001               | Last Bates number of native file document/email<br>**The LASTBATES field should be populated |\n|              |                          | for single page                                                                              |\n| ATTACHRANGE  | EDC0000001<br>-          | Bates number of the first page of the parent                                                 |\n|              | EDC0000015               | document to the Bates number of the last page of<br>the last attachment \"child\" document     |\n| BEGATTACH    | EDC0000001               | First Bates number of attachment range                                                       |\n| ENDATTACH    | EDC0000015               | Last Bates number of attachment range                                                        |\n| CUSTODIAN    | Smith, John              | Email: Mailbox where the email resided                                                       |\n|              |                          | Native: Name of the individual or department                                                 |\n|              |                          | from whose files the document<br>originated                                                  |\n| FROM         | John Smith               | Email: Sender                                                                                |\n|              |                          | Native: Author(s) of document                                                                |\n|              |                          | **semi-colon should be used to separate                                                      |\n|              |                          | multiple entries                                                                             |\n| TO           | Coffman, Janice; LeeW    | Recipient(s)                                                                                 |\n|              | [mailto:LeeW@MSN.com]    | **semi-colon should be used to separate multiple                                             |\n|              |                          | entries                                                                                      |\n| CC           | Frank Thompson [mailto:  | Carbon copy recipient(s)                                                                     |\n|              | frank_Thompson@cdt.com]  | **semi-colon should be used to separate                                                      |\n|              |                          | multiple entries                                                                             |\n| BCC          | John Cain                | Blind carbon copy recipient(s)                                                               |\n|              |                          | **semi-colon should be used to separate                                                      |\n|              |                          | multiple entries                                                                             |\n| SUBJECT      | Board Meeting Minutes    | Email: Subject line of the email Native: Title                                               |\n|              |                          | of document (if available)                                                                   |\n| FILE_NAME    | BoardMeetingMinutes.docx | Native: Name of the original native file,                                                    |\n|              |                          | including extension                                                                          |\n| DATE_SENT    | 10/12/2010               | Email: Date the email was sent                                                               |\n|              |                          | Native: (empty)                                                                              |\n| TIME_SENT/   | 07:05 PM GMT             | Email: Time the email was sent/ Time zone in                                                 |\n| TIME_ZONE    |                          | which the emails were standardized                                                           |\n| TIME_ZONE    | GMT                      | The<br>time zone in which<br>the emails<br>were                                              |\n|              |                          | standardized during conversion.                                                              |\n| LINK         |  EDC0000001.msg   | Hyperlink to the email or native file document                                               |\n|              |                          | **The linked file must be named per the                                                      |\n|              |                          | FIRSTBATES number                                                                            |\n| FILE_EXTEN   | MSG                      | The file type extension                                                                      |\n|              |                          | representing                                                                                 |\n|              |                          | the Email or                                                                                 |\n| AUTHOR       | John Smith               | Email: (empty)                                                                               |\n|              |                          | Native: Author of the document                                                               |\n| DATE_CREATED | 10/10/2010               | Email: (empty)                                                                               |\n|              |                          | Native: Date the document was created                                                        |\n\n# Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 975 of 1063\n\n| TIME_CREATED | 10:25 AM                  | Email: (empty)                                  |\n|--------------|---------------------------|-------------------------------------------------|\n|              |                           | Native: Time the document was created           |\n|              |                           | **This data must be a separate field and cannot |\n|              |                           | be combined with the DATE_CREATED field         |\n| DATE_MOD     | 10/12/2010                | Email: (empty)                                  |\n|              |                           | Native: Date the document was last modified     |\n| TIME_MOD     | 07:00 PM                  | Email: (empty)                                  |\n|              |                           | Native: Time the document was last modified     |\n|              |                           | **This data must be a separate field and cannot |\n|              |                           | be combined with the DATE_MOD field             |\n| DATE_ACCESSD | 10/12/2010                | Email: (empty)                                  |\n|              |                           | Native: Date the document was last accessed     |\n| TIME_ACCESSD | 07:00 PM                  | Email: (empty)                                  |\n|              |                           | Native: Time the document was last accessed     |\n|              |                           | **This data must be a separate field and cannot |\n|              |                           | be combined with the DATE_ACCESSD field         |\n| FILE_SIZE    | 5,952                     | Size of native file<br>document/email in KB     |\n| PGCOUNT      | 1                         | Number of pages in native file document/email   |\n| PATH         |   | Email: (empty)                                  |\n|              | Agenda.doc                | Native: Path where native file document was     |\n|              |                           | stored including original file name.            |\n| INTFILEPATH  | Personal Folders\\Deleted  | Email: original location of email including     |\n|              | Items\\Board Meeting       | original file name.                             |\n|              | Minutes.msg               | Native: (empty)                                 |\n| INTMSGID     | <000805c2c71b\\$75977050\\$ | Email: Unique Message ID Native: (empty)        |\n|              | cb8306d1@MSN>             |                                                 |\n| MD5HASH      | d131dd02c5e6eec4693d9a0   | MD5 Hash value of the document.                 |\n|              | 698aff95c                 |                                                 |\n|              | 2fcab58712467eab4004583e  |                                                 |\n|              | b8fb7f89                  |                                                 |\n| OCRPATH      | TEXT/001/EDC0000001.txt   | Path to extracted text of the native file       |\n\n3. Each Request operates and should be construed independently and, unless otherwise indicated, no Request limits the scope of any other Request.\n\n4. All Documents are to be produced as kept in the usual course of business or are to be organized and labeled to correspond with the categories in these Requests.\n\n5. Each Request contained herein extends to all Documents: (a) in Your possession, custody, or control; or (b) in the possession, custody, or control of anyone acting on Your behalf,\n\n#### Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 976 of 1063\n\nincluding Your counsel or other representatives and advisors. Each Document shall be produced in its entirety.\n\n6. If You are requested to produce a Document that is no longer in Your possession, custody, or control, then Your response must (a) describe in detail the nature of the document and its contents; (b) identify the person(s) who prepared or authored the Document (and, if applicable, the Person(s) to whom the Document was sent); (c) identify the date on which the document was prepared or created; (d) state whether such Document (i) is missing or lost, (ii) has been destroyed, (iii) has been transferred, voluntarily or involuntarily, to others, or (iv) was otherwise disposed of; (e) state the reason for, and the facts and circumstances surrounding, such disposition; (f) identify the Persons who authorized such disposition; (g) identify the date or approximate date of such disposition; (h) state when the Document was most recently in Your possession, custody or control; and (i) identify the Person, if any, presently in possession, custody, or control of such Document.\n\n7. If You are requested to produce a Document that has been destroyed, then Your response must state, in addition to the information required by the preceding Instruction: (a) the reason for the Document's destruction; (b) the identity of the Person who destroyed the Document; and (c) the identity of the Person who directed that the Document be destroyed.\n\n8. If You claim that a requested Document is privileged or attorney work-product, then Your response must: (a) state (i) a description of the Document adequate to support Your contention that the Document is privileged, (ii) the title of the Document, (iii) the date of the Document, (iv) the author of the Document, (v) the addressee of the Document, (vi) the identity of each Person who received or saw the original or any draft, copy, or reproduction of the Document, (vii) whether the Document itself, or any information contained or referred to in the Document is in the possession, custody, or control of any other Persons, and if so, the identity of\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 977 of 1063\n\nsuch Persons, as well as a statement addressing how the information came into their possession, (viii) the claim of privilege under which the Document is withheld, and (ix) all of the circumstances upon which You will rely to support such claim of privilege; and (b) produce a privilege log containing all of the information requested in Part (a) of this Instruction for each Document withheld on the basis of a claim of privilege in accordance with D. Conn. L. Civ. R. 26(e).\n\n9. If a portion of an otherwise responsive Document contains information subject to a claim of privilege, only that portion of the Document subject to the claim of privilege shall be deleted or redacted from the Document following the instructions above, and the rest shall be produced.\n\n10. The Requests are continuing in nature. You are hereby instructed to (a) supplement or correct any responses later learned to be incomplete or incorrect immediately upon learning that a prior response was incomplete or incorrect; and (b) produce any additional Documents that are called for under the\n\n11. If a Document is in a language other than English, You should provide that Document. If a Document is in a language other than English, and an English translation exists, You should provide both Documents.\n\n12. All references to Entities includes all affiliates thereof.\n\n13. All references to individual names include all alternative names, aliased, or nicknames.\n\n14. Unless otherwise expressly indicated, the period of time covered by the Document Requests is the period from February 5, 2012 to the date responses to the Document Requests are due.\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 978 of 1063\n\n#### **II. RULES OF CONSTRUCTION**\n\n15. The use of (a) any singular noun shall be construed to include the plural, and vice versa, and (b) a verb in any tense shall be construed as the use of the verb in all other tenses.\n\n16. The terms (a) \"and\" and \"or\" shall be construed either conjunctively or disjunctively as necessary to bring within the scope of any request all responses that might otherwise be construed to be outside of its scope, and (b) \"each\" and \"any\" shall be deemed to include and encompass the words \"every\" and \"all.\"\n\n#### **III. DEFINITIONS**\n\nThe definitions supplied by D. Conn. L. Civ. R. 26(c) and the rules of construction supplied by D. Conn. L. Civ. R. 26(d), as incorporated by D. Conn. Bankr. L.R. 2004-1(a), shall apply to the Document Requests. In addition, the following terms used in these Document Requests shall have the following meanings:\n\n1. \"You\" or \"Your\" or \"Yourself\" means and refers to Medical Supply System International LLC, together with all of its affiliates, divisions, agencies, instrumentalities, departments, offices, partners, officers, directors, agents, attorneys, representatives, employees, and/or anyone acting on its behalf.\n\n2. \"Debtor\" means Ho Wan Kwok (a/k/a Miles Kwok, Miles Guo, Guo Wengui, Guo Haoyun, 郭文贵, or any other alias), together with his employees, agents, counsel, advisors, or anyone acting on his behalf.\n\n3. \"Debtor's Son\" means Qiang Guo (a/k/a Mileson Kwok, 郭强, or any other alias), together with his employees, agents, counsel, advisors, or anyone acting on his behalf.\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 979 of 1063\n\n4. \"Debtor's Daughter\" means Mei Guo (a/k/a Mei Gui, 郭美, or any other alias), together with her employees, agents, counsel, advisors, or anyone acting on her behalf.\n\n5. \"Debtor's Purported Wife\" means Hing Chi Ngok (a/k/a Hing Chi Ng, Yue Qingzhi, 岳庆芝, or any other alias), together with her employees, agents, counsel, advisors, or anyone acting on her behalf.\n\n6. \"Debtor's Family\" means, collectively, the Debtor, the Debtor's Son, the Debtor's Daughter, and the Debtor's Purported Wife, and any other familial relation to the Debtor.\n\n7. \"Associated Individuals\" means, individually and collectively, all individuals that (1) hold, control, have custody over, or discretion over assets owned, controlled, or enjoyed by the Debtor or the Debtor's Family; or (2) have been employees, directors, or otherwise are affiliated with one or more Associated Entities, together with the respective employees, agents, counsel, advisors, or anyone acting on behalf of any of the foregoing. Such Associated Individuals shall include, but are not limited to: Daniel Podhaskie, Jason Miller, Steve Bannon, Karin Maistrello, Melissa Francis, Anthony DiBattista, William Gertz, Arethusa Forsyth, Glenn Mellor, Jennifer Mercurio, Eduardo Eurnekian, Wencong Wang, Han Chunguang (a/k/a 韩春光), Qu Guojiao (a/k/a Qu Guo Jiao, 屈国姣), Guo Lijie (a/k/a 郭丽杰), Zhang Wei (a/k/a 张伟\\*), Lihong Wei Lafrenz (a/k/a Sara Wei, 魏丽红), Hao Haidong (a/k/a 郝海东), Ross Heinemeyer, Max Krasner, Kyle Bass, Melissa Mendez, Ya Li (a/k/a 李娅), Dinggang Wang (a/k/a 王定刚), An Hong (a/k/a 安红), Yvette Wang (a/k/a Yanping Wang, Yan Ping Wang, 王雁平), Fiona Yu, Je Kin Ming (a/k/a William Je, Yu Jianming, 余建明), Yaz Qingua, and Lao Jiang (a/k/a Jiang Yunfu, Jiang Yunfu Be, 姜云浮).\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 980 of 1063\n\n8. \"Associated Entities\" means, individually and collectively, all organizations or Entities of any type that (1) have been owned, controlled, or invested in by the Debtor or the Debtor's Family; or (2) have an interest, whether directly or indirectly, in any assets owned, controlled, or enjoyed by the Debtor or the Debtor's Family, together with the respective employees, agents, counsel, advisors, or anyone acting on behalf of any of the foregoing. Such Associated Entities shall include, but are not limited to: 7 Nod Hill LLC, AAGV Limited, ACA Investment Management Limited, ACA Capital Group Limited, Ace Decade Holdings Limited, AI Group Holdings Inc., Alfa Global Ventures Limited, Alfonso Global Limited, Allied Capital Global Limited, Alpine Fiduciaries SA, Anton Development Limited, Assets Sino Limited, Auspicious Coast Limited, Beijing Pangu Investment Co., Beijing Pangu Investment Co. Ltd., Beijing Pangu Investment Inc., Beijing Zenith Holdings Company Limited, Booming Sail New York LLC, Bravo Luck Limited, BSA Strategic Fund I, China Golden Spring (Hong Kong) Limited, Chuang Xin Limited, Crane Advisory Group LLC, Creative Apex Investments Limited, Crystal Breeze Investments Limited, Dawn State Limited, Eastern Profit Corporation Limited, Elite Well Global Limited, Empire Growth Holdings, Freedom Media Ventures Ltd., G Club Operations LLC, G Fashion LLC, G News LLC, GETTR USA, Genever Holdings Corporation, Genever Holdings LLC, Gfashion Media Group Inc., GFNY, Inc., Globalist International Limited, GNews Media Group Inc., Golden Spring (New York) Ltd., Greenwich Land LLC, Guo Media, GTV Media Group, Inc., Hamilton Capital Holdings Inc., HCHK Property Management, Inc., HCHK Technologies, Inc., Head Win Group Limited, Henan Yuda, Himalaya Embassy, Himalaya Exchange, Himalaya Federal Reserve, Himalaya Investment LLC, Himalaya International, Himalaya New World Inc., Himalaya Supervisory Organization, Himalaya Ventures LLC, HK International Funds Investments (USA) Limited LLC, Hong Kong International Funds\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 981 of 1063\n\nInvestments Limited, Hudson Diamond Holding, Infinite Increase Limited, Infinitum Developments Limited, Infinity Treasury Management Inc., Insight Phoenix Fund, Lamp Capital LLC, Leading Shine Limited, Leading Shine NY Limited, Lexington Property and Staffing, Long Gate Limited, Maywind Trading LLC, MOS Himalaya LLC, Next Tycoon Investments Limited, New Federal State of China (a/k/a NFSC), Noble Fame Global Limited, Rosy Acme Ventures Limited, Rule of Law Foundation III, Inc., Rule of Law Foundation IV, Inc., Rule of Law Fund, Rule of Law Society, Rule of Law Society IV, Inc., G-Translators PTY LTD, Saraca Media Group, Inc., Shiny Ace Ltd., Shiny Times Holdings Ltd., Spirit Charter Investment Limited, Stevenson, Wong & Co., Voice of Guo Media, Inc., Well Origin Ltd., World Century Limited, Worldwide Opportunity Holdings Limited, Whitecroft Shore Limited, and ZIBA Limited.\n\n9. \"Including\" or any variant thereof means \"including without limitation.\"\n\n10. \"And\" and \"or\" mean \"and/or,\" and shall be construed both conjunctively as well as disjunctively in order to maximize their scope.\n\n11. \"Any\" and \"all\" and \"each\" mean \"each and every.\"\n\n12. \"Each\" and \"every\" mean \"each and every.\"\n\n13. \"Third Party\" means a Person or Entity other than Yourself.\n\n14. \"Transfer\" shall have the meaning given to it by section 101(54) of the Bankruptcy Code.\n\n15. \"Document\" means any information or thing within the scope of Fed. R. Civ. P. 34, and includes, without limitation, each and every written, recorded, or graphic matter of any kind, type, nature, or description that is or has been in Your Possession, Custody or Control, including all printed and electronic copies of electronic mail, computer files maintained in\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 982 of 1063\n\nelectronic form, electronic communication, text message, social media post, tweet, meta-data, correspondence, memoranda, tapes, stenographic or handwritten notes, written forms of any kind, charts, blueprints, drawings, sketches, graphs, plans, articles, specifications, diaries, letters, telegrams, photographs, minutes, contracts, agreements, surveys, computer printouts, data compilations of any kind, telexes, facsimiles, voice messages, invoices, order forms, checks, drafts, statements, credit memos, reports, position reports, summaries, indices, books, ledgers, notebooks, schedules, transparencies, recordings, catalogs, advertisements, promotional materials, films, video tapes, audio tapes, CDs, computer disks, brochures, pamphlets, punchcards, time-slips, Tweets, social media posts, or any written or recorded materials of any other kind, and all meta-data thereof, however stored (whether in tangible or electronic form), recorded, produced, or reproduced, and also including but not limited to, drafts or copies of any of the foregoing that contain any notes, comments, or markings of any kind not found on the original documents or that are otherwise not identical to the original documents.\n\n16. \"Person(s)\" means an individual, corporation, proprietorship, partnership, association, or any other Entity. \"Person\" also includes any agent, representatives, or expert, including but not limiting to, attorneys or financial advisors.\n\n17. \"Entity\" means any natural Person, corporation, partnership, subsidiary, sole proprietorship, firm, board, joint venture, association, agency, authority, commission or other business entity or juristic Person, as well as any affiliate, agent, parent including but not limited to legal counsel, financial advisors, or any other representative.\n\n18. \"Regarding\" means concerning, describing, comprising, referring to, related to, supporting, favoring, opposing, bolstering, detracting from, located in, considered in connection with, bearing on, evidencing, indicating, reporting on, recording, alluding to, responding to,\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 983 of 1063\n\nconnected with, commenting on, in respect of, about, in relation to, discussing, showing, describing, reflecting, analyzing constituting, and being.\n\n19. \"Relating to,\" \"relate(s) to\" or \"related to,\" when referring to any given subject matter, means, without limitation, any document that constitutes, comprises, involves, contains, embodies, reflects, identifies, states, refers directly or indirectly to, or is in any way relevant to the particular subject matter identified.\n\n20. \"Communication(s)\" means, in the broadest possible sense, and without limitation, any transmittal of information or knowledge (in the form of facts, ideas, inquiries, or otherwise). Communication(s) further refers to all conversations, agreements, inquiries, or replies, whether in person, by telephone, in writing, or by means of electronic transmittal devices, and includes, but is not limited to, all correspondence, emails, recordings, transmittal slips, memoranda, telephone communications, voice messages, telegrams, telefaxes, telecopies, telexes, instant messages, chats, text messages, telephonic notes, or notes transmitted internally or with third parties.\n\n21. \"Asset(s)\" means any item that can be used to produce positive economic value, including but not limited to any resource with economic value that is owned, controlled or is for the benefit of an entity, that is expected to provide a future benefit, including but not limited to, all real and personal property, intangible property, investments, rights to invest or to future revenue, cash, bank accounts, commodities, securities, claims, total or partial control of an entity, and prospective economic opportunities\n\n22. \"Transfer\" shall have the meaning given to it by section 101(54) of the Bankruptcy Code.\n\n#### **IV. DOCUMENTS TO BE PRODUCED**\n\n1. All Documents regarding any income or Asset of the Debtor, the Debtor's estate, or an Associated Entity.\n\n2. All Documents related to the Debtor's financial condition and obligations to his creditors, including without limitation all Documents related to any effort to avoid paying such obligations and All Documents related to this or any other actual or potential bankruptcy or similar insolvency proceeding.\n\n3. All Documents regarding any balance sheet, bank statement, account statement, financial statement, statement of account, wire transfer instructions and/or confirmation, proof of funds, certificate of deposit, certificate of holdings, investment portfolio summary, or similar document relating to the Debtor, the Debtor's Estate, the Debtor's Family, an Associated Entity, or an Associated Individual, including without limitation all Documents sufficient to show all Transfers to any of the foregoing.\n\n4. All Documents regarding any investment, business dealing or transactions made by, with, or on behalf of the Debtor.\n\n5. All Communications with the Debtor, and Documents related to Communications with the Debtor, related to the operation, management, or decision-making of any Entity, including without limitation the Associated Entities.\n\n6. All Documents regarding any Transfer, investment, or other transaction or business dealing made to, by, or with the Debtor, the Debtor's Family, or an Associated Entity.\n\n7. All Documents regarding any property ever occupied or used by the Debtor, including without limitation the *Lady May*; the Sherry Netherland Hotel / Condominium; the\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 985 of 1063\n\nresidential property located in Greenwich, Connecticut at 373 Taconic Rd.; the residential property located in Greenwich, Connecticut at 33 Ferncliff Rd.; and the residential property located in Wilton, Connecticut at 354 Nod Hill Rd.\n\n8. All Documents related to any aircraft owned, controlled, or used by the Debtor, including without limitation the aircraft bearing tail number T7-GQM and any other aircraft registered in San Marino, including without limitation copies of all registration documents and flight manifests showing flights taken by such aircraft and the individuals onboard such flights.\n\n9. All Documents regarding any gifts, benefits or loans, to, from or on behalf of the Debtor, the Debtor's Estate, the Debtor's Family, or the Associated Entities, including without limitation Documents sufficient to show the amounts of such gifts, benefits, or loans; the purposes for which such gifts, benefits, or loans were used; when the gifts, benefits, or loans were provided; and the terms of any loans, all representations and warranties made in connection with any loans, the interest rate on any loans, and all evidence of payments of any loans.\n\n10. All Documents concerning any trust or similar instrument set up by, on behalf of, or for the benefit of the Debtor, the Debtor's Estate, the Debtor's Family, or an Associated Entity, including without limitation Documents sufficient to show when the trust(s) was created, by whom it was created, for whose benefit it was created, and the corpus of the trust.\n\n11. All Documents related to any obligation, claim, liability, or debt associated with any legal dispute involving the Debtor, including but not limited to those relating to any litigation before any local, state, federal, or international body, whether an administrative body, court, panel, or alternative dispute resolution entity.\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 986 of 1063\n\n12. All Documents and communications between any of your outside counsel or other advisors and the Debtor.\n\n13. Documents sufficient to show all of Your Assets and sources of income or funding.\n\n14. For all Assets identified in response to Request 14 having a value of more than \\$50,000, all (i) Documents related to Your acquisition of such Asset and (ii) Communications with the Debtor or the Debtor's Family regarding such Asset.\n\n15. Copies of Your tax returns.\n\n16. Documents sufficient to show all bank accounts and investment accounts within Your possession or control, including the balances of and transfers to and from each such account.\n\n17. All Documents regarding any credit cards used by You, including without limitation monthly statements or other Documents sufficient to show all purchases related thereto for the benefit of the Debtor or an Associated Entity.\n\n18. All corporate governance and organizational Documents, including without limitation by-laws and certificates of incorporation and other Documents sufficient to show Your corporate structure, names of officers and directors, business purpose, and relationship to the Debtor or to any member of the Debtor's Family.\n\n19. All Documents related to any pledge(s) of Your Assets to any other Entity.\n\nCase 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 987 of 1063\n\n# Exhibit C-54\n\n#### B2540 (Form 2540 – Subpoena for Rule 2004 Examination) (12/15) Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 988 of\n\nUNITED STATES BANKRUPTCY COURT 1063\n\n**District of Connecticut**\n\nIn re HO WAN KWOK, *et al*.,\n\n<sup>1</sup> Case No. 22-50073 (JAM)\n\nDebtor Chapter 11\n\n(Jointly Administered)\n\n## **SUBPOENA FOR RULE 2004 EXAMINATION**\n\nTo: **Leading Shine NY Ltd.**\n\n(*Name of person to whom the subpoena is directed*)\n\n*Testimony:* **YOU ARE COMMANDED** to appear at the time, date, and place set forth below to testify at an examination under Rule 2004, Federal Rules of Bankruptcy Procedure. A copy of the court order authorizing the examination is attached.\n\n| PLACE                    | DATE AND TIME |\n|--------------------------|---------------|\n| Paul Hastings LLP        |               |\n| 200 Park Avenue          | [TBD]         |\n| New York, New York 10166 |               |\n|                          |               |\n\nThe examination will be recorded by this method: **Court reporter/stenographer**\n\n*Production:* You, or your representatives, must also bring with you to the examination the following documents, electronically stored information, or objects, and must permit inspection, copying, testing, or sampling of the material:\n\n#### **See Requests for Production of Documents, attached hereto.**\n\nThe following provisions of Fed. R. Civ. P. 45, made applicable in bankruptcy cases by Fed. R. Bankr. P. 9016, are attached – Rule 45(c), relating to the place of compliance; Rule 45(d), relating to your protection as a person subject to a subpoena; and Rule 45(e) and 45(g), relating to your duty to respond to this subpoena and the potential consequences of not doing so.\n\nDate: **March , 2023**\n\nCLERK OF COURT\n\nOR\n\n*Signature of Clerk or Deputy Clerk Attorney's signature*\n\nThe name, address, email address, and telephone number of the attorney representing Luc A. Despins, Chapter 11 Trustee, who issues or requests this subpoena, are:\n\n**Douglas S. Skalka, Esq.; Neubert, Pepe & Monteith, P.C.; 195 Church Street, New Haven, Connecticut 06510 dskalka@npmlaw.com; (203) 821-2000**\n\n**Notice to the person who issues or requests this subpoena**\n\nIf this subpoena commands the production of documents, electronically stored information, or tangible things, or the inspection of premises before trial, a notice and a copy of this subpoena must be served on each party before it is served on the person to whom it is directed. Fed. R. Civ. P. 45(a)(4).\n\nSoftware Copyright (c) 1996-2022 Best Case, LLC - www.bestcase.com Best Case Bankruptcy 1 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\n#### **PROOF OF SERVICE**\n\n**(This section should not be filed with the court unless required by Fed. R. Civ. P. 45.)**\n\nI received this subpoena for (*name of individual and title, if any*): on (*date*) .\n\nI served the subpoena by delivering a copy to the named person as follows:\n\non *(date)* ; or\n\nI returned the subpoena unexecuted because:\n\nUnless the subpoena was issued on behalf of the United States, or one of its officers or agents, I have also tendered to the witness the fees for one day's attendance, and the mileage allowed by law, in the amount of \\$ .\n\nMy fees are \\$ for travel and \\$ for services, for a total of \\$ .\n\nI declare under penalty of perjury that this information is true and correct.\n\nDate:\n\n*Server's signature*\n\n*Printed name and title*\n\n*Server's address*\n\nAdditional information concerning attempted service, etc.:\n\n#### **Federal Rule of Civil Procedure 45(c), (d), (e), and (g) (Effective 12/1/13) (made applicable in bankruptcy cases by Rule 9016, Federal Rules of Bankruptcy Procedure)**\n\n#### **(c) Place of compliance.**\n\n*(1) For a Trial, Hearing, or Deposition.* A subpoena may command a person to attend a trial, hearing, or deposition only as follows:\n\n(A) within 100 miles of where the person resides, is employed, or regularly transacts business in person; or\n\n(B) within the state where the person resides, is employed, or regularly transacts business in person, if the person\n\n(i) is a party or a party's officer; or\n\n(ii) is commanded to attend a trial and would not incur substantial expense.\n\n*(2) For Other Discovery.* A subpoena may command:\n\n(A) production of documents, or electronically stored information, or things at a place within 100 miles of where the person resides, is employed, or regularly transacts business in person; and\n\n(B) inspection of premises, at the premises to be inspected.\n\n#### **(d) Protecting a Person Subject to a Subpoena; Enforcement.**\n\n*(1) Avoiding Undue Burden or Expense; Sanctions.* A party or attorney responsible for issuing and serving a subpoena must take reasonable steps to avoid imposing undue burden or expense on a person subject to the subpoena. The court for the district where compliance is required must enforce this duty and impose an appropriate sanction which may include lost earnings and reasonable attorney's fees — on a party or attorney who fails to comply.\n\n#### *(2) Command to Produce Materials or Permit Inspection.*\n\n*(A) Appearance Not Required.* A person commanded to produce documents, electronically stored information, or tangible things, or to permit the inspection of premises, need not appear in person at the place of production or inspection unless also commanded to appear for a deposition, hearing, or trial.\n\n*(B) Objections.* A person commanded to produce documents or tangible things or to permit inspection may serve on the party or attorney designated in the subpoena a written objection to inspecting, copying, testing or sampling any or all of the materials or to inspecting the premises — or to producing electronically stored information in the form or forms requested. The objection must be served before the earlier of the time specified for compliance or 14 days after the subpoena is served. If an objection is made, the following rules apply:\n\n(i) At any time, on notice to the commanded person, the serving party may move the court for the district where compliance is required for an order compelling production or inspection.\n\n(ii) These acts may be required only as directed in the order, and the order must protect a person who is neither a party nor a party's officer from significant expense resulting from compliance.\n\n#### *(3) Quashing or Modifying a Subpoena.*\n\n*(A) When Required.* On timely motion, the court for the district where compliance is required must quash or modify a subpoena that:\n\n(i) fails to allow a reasonable time to comply;\n\n(ii) requires a person to comply beyond the geographical limits specified in Rule 45(c);\n\n(iii) requires disclosure of privileged or other protected matter, if no exception or waiver applies; or\n\n(iv) subjects a person to undue burden.\n\n*(B) When Permitted.* To protect a person subject to or affected by a subpoena, the court for the district where compliance is required may, on motion, quash or modify the subpoena if it requires:\n\n(i) disclosing a trade secret or other confidential research, development, or commercial information; or\n\n(ii) disclosing an unretained expert's opinion or information that does not describe specific occurrences in dispute and results from the expert's study that was not requested by a party.\n\n(C) *Specifying Conditions as an Alternative.* In the circumstances described in Rule 45(d)(3)(B), the court may, instead of quashing or modifying a subpoena, order appearance or production under specified conditions if the serving party:\n\n(i) shows a substantial need for the testimony or material that cannot be otherwise met without undue hardship; and\n\n(ii) ensures that the subpoenaed person will be reasonably compensated.\n\n#### **(e) Duties in Responding to a Subpoena.**\n\n*(1) Producing Documents or Electronically Stored Information.* These procedures apply to producing documents or electronically stored information:\n\n*(A) Documents.* A person responding to a subpoena to produce documents must produce them as they are kept in the ordinary course of business or must organize and label them to correspond to the categories in the demand.\n\n*(B) Form for Producing Electronically Stored Information Not Specified.* If a subpoena does not specify a form for producing electronically stored information, the person responding must produce it in a form or forms in which it is ordinarily maintained or in a reasonably usable form or forms.\n\n*(C) Electronically Stored Information Produced in Only One Form.* The person responding need not produce the same electronically stored information in more than one form.\n\n*(D) Inaccessible Electronically Stored Information.* The person responding need not provide discovery of electronically stored information from sources that the person identifies as not reasonably accessible because of undue burden or cost. On motion to compel discovery or for a protective order, the person responding must show that the information is not reasonably accessible because of undue burden or cost. If that showing is made, the court may nonetheless order discovery from such sources if the requesting party shows good cause, considering the limitations of Rule 26(b)(2)(C). The court may specify conditions for the discovery.\n\n#### *(2) Claiming Privilege or Protection.*\n\n*(A) Information Withheld.* A person withholding subpoenaed information under a claim that it is privileged or subject to protection as trial-preparation material must: (i) expressly make the claim; and\n\n(ii) describe the nature of the withheld documents, communications, or tangible things in a manner that, without revealing information itself privileged or protected, will enable the parties to assess the claim.\n\n*(B) Information Produced.* If information produced in response to a subpoena is subject to a claim of privilege or of protection as trial-preparation material, the person making the claim may notify any party that received the information of the claim and the basis for it. After being notified, a party must promptly return, sequester, or destroy the specified information and any copies it has; must not use or disclose the information until the claim is resolved; must take reasonable steps to retrieve the information if the party disclosed it before being notified; and may promptly present the information under seal to the court for the district where compliance is required for a determination of the claim. The person who produced the information must preserve the information until the claim is resolved.\n\n**(g) Contempt.** The court for the district where compliance is required – and also, after a motion is transferred, the issuing court – may hold in contempt a person who, having been served, fails without adequate excuse to obey the subpoena or an order related to it.\n\nFor access to subpoena materials, see Fed.R.Civ.P.45(a) Committee Note (2013)\n\n…\n\n## **Requests for Production of Documents**\n\n## **I. INSTRUCTIONS**\n\n1. Unless otherwise indicated, the requests for documents set forth below, (the \"Requests,\" and each, a \"Request\"), must be responded to separately and specifically. Each Request shall be answered fully unless it is in good faith objected to, in which event the reason for Your objection shall be stated in detail, as set forth below. If an objection pertains only to a portion of a Request, or a word, phrase or clause contained within it, You are required to state Your objection to that portion only and to respond to the remainder of the Requests.\n\n2. Electronically stored information must be produced in accordance with the\n\nfollowing instructions:\n\n- a. Images. Black and white images must be 300 DPI Group IV single-page TIFF files. Color images must be produced in JPEG format. File names cannot contain embedded spaces or special characters (including the comma). Folder names cannot contain embedded spaces or special characters (including the comma). All TIFF image files must have a unique file name, i.e. Bates number. Images must be endorsed with sequential Bates numbers in the lower right corner of each image. The number of TIFF files per folder should not exceed 1000 files. Excel spreadsheets should have a placeholder image named by the Bates number of the file.\n- b. Image Load File\n\t- a. Concordance® Data File. The data file (.DAT) contains all of the fielded information that will be loaded into the Concordance® database. The first line of the .DAT file must be a header row identifying the field names. The .DAT file must use the following Concordance® default delimiters: Comma ASCII character (020) Quote þ ASCII character (254). Date fields should be provided in the format: mm/dd/yyyy. Date and time fields must be two separate fields. If documents includes imaged emails and attachments, the attachment fields must be included to preserve the parent/child relationship between an email and its attachments. An OCRPATH field must be included to provide the file path and name of the extracted text file on the produced storage media. The text file must be named after the FIRSTBATES. Do not include the text in the .DAT file. For Documents with native files, a LINK field must be included to provide the file path and\n\nname of the native file. The native file must be named after the FIRSTBATES.\n\n- b. Concordance Image® OR Opticon Cross-Reference File. The image crossreference file (.LOG or .OPT) links the images to the database records. It should be a comma-delimited file consisting of seven fields per line with a line in the cross-reference file for every image in the database with the following format: ImageID,VolumeLabel,ImageFilePath,DocumentBreak,FolderBreak,Box Break,PageCoun.\n- c. Document Text. Text must be produced as separate text files, not as fields within the .DAT file. The full path to the text file (OCRPATH) should be included in the .DAT file. It is recommended document level ANSI text files, named per the FIRSTBATES/Image Key. Extracted text files must be in a separate folder, and the number of text files per folder should not exceed 1,000 files. There should be no special characters (including commas in the folder names). Text files must be provided on a document level.\n- d. Native Production for Certain File Types. File types that reasonably require viewing in their native format for a full understanding of their content and meaning must be produced in native format. These include, but are not limited to, spreadsheets, spreadsheet-like files (Microsoft Excel, comma separated values, tab separated values, etc.), Microsoft PowerPoint or other special presentation files, database files, and audio/visual files. Provide an image of a Bates numbered slip sheet indicating the presence of a native file, and include the path to the native as a field in the .dat file. Name the produced native file with the Bates number corresponding to the slip sheet for the file. Group native files within incrementally named \"NATIVE\" directories, separate from images directories.\n- e. De-duplication. Produce a single copy of each electronic document for which exact duplicates exist. For email messages, consolidate duplicates based on MD5 hash generated from the BCC, Body, CC, From, IntMsgID, To, and Attach properties. For email attachments and standalone electronic files, consolidate duplicates based on MD5 hash of the entire file.\n- f. Metadata. Produce extracted metadata for each document in the form of a Concordance compliant load file (.dat). The first line of the .DAT file must be a header row identifying the field names. The .DAT file must use the following Concordance default delimiters: Comma , ASCII character (020) Quote þ ASCII character (254)\n\nDate fields should be provided in the format: mm/dd/yyyy. Date and time fields must be two separate fields. Required metadata listed below:\n\n# Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 993 of 1063\n\n| Field Name   | Sample Data              | Description                                                                                  |\n|--------------|--------------------------|----------------------------------------------------------------------------------------------|\n| FIRSTBATES   | EDC0000001               | First Bates number of native file document/email                                             |\n| LASTBATES    | EDC0000001               | Last Bates number of native file document/email<br>**The LASTBATES field should be populated |\n|              |                          | for single page                                                                              |\n| ATTACHRANGE  | EDC0000001<br>-          | Bates number of the first page of the parent                                                 |\n|              | EDC0000015               | document to the Bates number of the last page of                                             |\n|              |                          | the last attachment \"child\" document                                                         |\n| BEGATTACH    | EDC0000001               | First Bates number of attachment range                                                       |\n| ENDATTACH    | EDC0000015               | Last Bates number of attachment range                                                        |\n| CUSTODIAN    | Smith, John              | Email: Mailbox where the email resided                                                       |\n|              |                          | Native: Name of the individual or department                                                 |\n|              |                          | from whose files the document<br>originated                                                  |\n| FROM         | John Smith               | Email: Sender                                                                                |\n|              |                          | Native: Author(s) of document                                                                |\n|              |                          | **semi-colon should be used to separate                                                      |\n|              |                          | multiple entries                                                                             |\n| TO           | Coffman, Janice; LeeW    | Recipient(s)                                                                                 |\n|              | [mailto:LeeW@MSN.com]    | **semi-colon should be used to separate multiple                                             |\n|              |                          | entries                                                                                      |\n| CC           | Frank Thompson [mailto:  | Carbon copy recipient(s)                                                                     |\n|              | frank_Thompson@cdt.com]  | **semi-colon should be used to separate                                                      |\n|              |                          | multiple entries                                                                             |\n| BCC          | John Cain                | Blind carbon copy recipient(s)                                                               |\n|              |                          | **semi-colon should be used to separate                                                      |\n|              |                          | multiple entries                                                                             |\n| SUBJECT      | Board Meeting Minutes    | Email: Subject line of the email Native: Title                                               |\n|              |                          | of document (if available)                                                                   |\n| FILE_NAME    | BoardMeetingMinutes.docx | Native: Name of the original native file,                                                    |\n|              |                          | including extension                                                                          |\n| DATE_SENT    | 10/12/2010               | Email: Date the email was sent                                                               |\n|              |                          | Native: (empty)                                                                              |\n| TIME_SENT/   | 07:05 PM GMT             | Email: Time the email was sent/ Time zone in                                                 |\n| TIME_ZONE    |                          | which the emails were standardized                                                           |\n| TIME_ZONE    | GMT                      | The<br>time zone in which<br>the emails<br>were                                              |\n|              |                          | standardized during conversion.                                                              |\n| LINK         |  EDC0000001.msg   | Hyperlink to the email or native file document                                               |\n|              |                          | **The linked file must be named per the                                                      |\n|              |                          | FIRSTBATES number                                                                            |\n| FILE_EXTEN   | MSG                      | The file type extension                                                                      |\n|              |                          | representing                                                                                 |\n|              |                          | the Email or                                                                                 |\n| AUTHOR       | John Smith               | Email: (empty)                                                                               |\n|              |                          | Native: Author of the document                                                               |\n| DATE_CREATED | 10/10/2010               | Email: (empty)                                                                               |\n|              |                          | Native: Date the document was created                                                        |\n\n# Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 994 of 1063\n\n| TIME_CREATED | 10:25 AM                  | Email: (empty)                                  |\n|--------------|---------------------------|-------------------------------------------------|\n|              |                           | Native: Time the document was created           |\n|              |                           | **This data must be a separate field and cannot |\n|              |                           | be combined with the DATE_CREATED field         |\n| DATE_MOD     | 10/12/2010                | Email: (empty)                                  |\n|              |                           | Native: Date the document was last modified     |\n| TIME_MOD     | 07:00 PM                  | Email: (empty)                                  |\n|              |                           | Native: Time the document was last modified     |\n|              |                           | **This data must be a separate field and cannot |\n|              |                           | be combined with the DATE_MOD field             |\n| DATE_ACCESSD | 10/12/2010                | Email: (empty)                                  |\n|              |                           | Native: Date the document was last accessed     |\n| TIME_ACCESSD | 07:00 PM                  | Email: (empty)                                  |\n|              |                           | Native: Time the document was last accessed     |\n|              |                           | **This data must be a separate field and cannot |\n|              |                           | be combined with the DATE_ACCESSD field         |\n| FILE_SIZE    | 5,952                     | Size of native file<br>document/email in KB     |\n| PGCOUNT      | 1                         | Number of pages in native file document/email   |\n| PATH         |   | Email: (empty)                                  |\n|              | Agenda.doc                | Native: Path where native file document was     |\n|              |                           | stored including original file name.            |\n| INTFILEPATH  | Personal Folders\\Deleted  | Email: original location of email including     |\n|              | Items\\Board Meeting       | original file name.                             |\n|              | Minutes.msg               | Native: (empty)                                 |\n| INTMSGID     | <000805c2c71b\\$75977050\\$ | Email: Unique Message ID Native: (empty)        |\n|              | cb8306d1@MSN>             |                                                 |\n| MD5HASH      | d131dd02c5e6eec4693d9a0   | MD5 Hash value of the document.                 |\n|              | 698aff95c                 |                                                 |\n|              | 2fcab58712467eab4004583e  |                                                 |\n|              | b8fb7f89                  |                                                 |\n| OCRPATH      | TEXT/001/EDC0000001.txt   | Path to extracted text of the native file       |\n\n3. Each Request operates and should be construed independently and, unless otherwise indicated, no Request limits the scope of any other Request.\n\n4. All Documents are to be produced as kept in the usual course of business or are to be organized and labeled to correspond with the categories in these Requests.\n\n5. Each Request contained herein extends to all Documents: (a) in Your possession, custody, or control; or (b) in the possession, custody, or control of anyone acting on Your behalf,\n\n#### Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 995 of 1063\n\nincluding Your counsel or other representatives and advisors. Each Document shall be produced in its entirety.\n\n6. If You are requested to produce a Document that is no longer in Your possession, custody, or control, then Your response must (a) describe in detail the nature of the document and its contents; (b) identify the person(s) who prepared or authored the Document (and, if applicable, the Person(s) to whom the Document was sent); (c) identify the date on which the document was prepared or created; (d) state whether such Document (i) is missing or lost, (ii) has been destroyed, (iii) has been transferred, voluntarily or involuntarily, to others, or (iv) was otherwise disposed of; (e) state the reason for, and the facts and circumstances surrounding, such disposition; (f) identify the Persons who authorized such disposition; (g) identify the date or approximate date of such disposition; (h) state when the Document was most recently in Your possession, custody or control; and (i) identify the Person, if any, presently in possession, custody, or control of such Document.\n\n7. If You are requested to produce a Document that has been destroyed, then Your response must state, in addition to the information required by the preceding Instruction: (a) the reason for the Document's destruction; (b) the identity of the Person who destroyed the Document; and (c) the identity of the Person who directed that the Document be destroyed.\n\n8. If You claim that a requested Document is privileged or attorney work-product, then Your response must: (a) state (i) a description of the Document adequate to support Your contention that the Document is privileged, (ii) the title of the Document, (iii) the date of the Document, (iv) the author of the Document, (v) the addressee of the Document, (vi) the identity of each Person who received or saw the original or any draft, copy, or reproduction of the Document, (vii) whether the Document itself, or any information contained or referred to in the Document is in the possession, custody, or control of any other Persons, and if so, the identity of\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 996 of 1063\n\nsuch Persons, as well as a statement addressing how the information came into their possession, (viii) the claim of privilege under which the Document is withheld, and (ix) all of the circumstances upon which You will rely to support such claim of privilege; and (b) produce a privilege log containing all of the information requested in Part (a) of this Instruction for each Document withheld on the basis of a claim of privilege in accordance with D. Conn. L. Civ. R. 26(e).\n\n9. If a portion of an otherwise responsive Document contains information subject to a claim of privilege, only that portion of the Document subject to the claim of privilege shall be deleted or redacted from the Document following the instructions above, and the rest shall be produced.\n\n10. The Requests are continuing in nature. You are hereby instructed to (a) supplement or correct any responses later learned to be incomplete or incorrect immediately upon learning that a prior response was incomplete or incorrect; and (b) produce any additional Documents that are called for under the\n\n11. If a Document is in a language other than English, You should provide that Document. If a Document is in a language other than English, and an English translation exists, You should provide both Documents.\n\n12. All references to Entities includes all affiliates thereof.\n\n13. All references to individual names include all alternative names, aliased, or nicknames.\n\n14. Unless otherwise expressly indicated, the period of time covered by the Document Requests is the period from February 5, 2012 to the date responses to the Document Requests are due.\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 997 of 1063\n\n#### **II. RULES OF CONSTRUCTION**\n\n15. The use of (a) any singular noun shall be construed to include the plural, and vice versa, and (b) a verb in any tense shall be construed as the use of the verb in all other tenses.\n\n16. The terms (a) \"and\" and \"or\" shall be construed either conjunctively or disjunctively as necessary to bring within the scope of any request all responses that might otherwise be construed to be outside of its scope, and (b) \"each\" and \"any\" shall be deemed to include and encompass the words \"every\" and \"all.\"\n\n#### **III. DEFINITIONS**\n\nThe definitions supplied by D. Conn. L. Civ. R. 26(c) and the rules of construction supplied by D. Conn. L. Civ. R. 26(d), as incorporated by D. Conn. Bankr. L.R. 2004-1(a), shall apply to the Document Requests. In addition, the following terms used in these Document Requests shall have the following meanings:\n\n1. \"You\" or \"Your\" or \"Yourself\" means and refers to Leading Shine NY Ltd., together with all of its affiliates, divisions, agencies, instrumentalities, departments, offices, partners, officers, directors, agents, attorneys, representatives, employees, and/or anyone acting on its behalf.\n\n2. \"Debtor\" means Ho Wan Kwok (a/k/a Miles Kwok, Miles Guo, Guo Wengui, Guo Haoyun, 郭文贵, or any other alias), together with his employees, agents, counsel, advisors, or anyone acting on his behalf.\n\n3. \"Debtor's Son\" means Qiang Guo (a/k/a Mileson Kwok, 郭强, or any other alias), together with his employees, agents, counsel, advisors, or anyone acting on his behalf.\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 998 of 1063\n\n4. \"Debtor's Daughter\" means Mei Guo (a/k/a Mei Gui, 郭美, or any other alias), together with her employees, agents, counsel, advisors, or anyone acting on her behalf.\n\n5. \"Debtor's Purported Wife\" means Hing Chi Ngok (a/k/a Hing Chi Ng, Yue Qingzhi, 岳庆芝, or any other alias), together with her employees, agents, counsel, advisors, or anyone acting on her behalf.\n\n6. \"Debtor's Family\" means, collectively, the Debtor, the Debtor's Son, the Debtor's Daughter, and the Debtor's Purported Wife, and any other familial relation to the Debtor.\n\n7. \"Associated Individuals\" means, individually and collectively, all individuals that (1) hold, control, have custody over, or discretion over assets owned, controlled, or enjoyed by the Debtor or the Debtor's Family; or (2) have been employees, directors, or otherwise are affiliated with one or more Associated Entities, together with the respective employees, agents, counsel, advisors, or anyone acting on behalf of any of the foregoing. Such Associated Individuals shall include, but are not limited to: Daniel Podhaskie, Jason Miller, Steve Bannon, Karin Maistrello, Melissa Francis, Anthony DiBattista, William Gertz, Arethusa Forsyth, Glenn Mellor, Jennifer Mercurio, Eduardo Eurnekian, Wencong Wang, Han Chunguang (a/k/a 韩春光), Qu Guojiao (a/k/a Qu Guo Jiao, 屈国姣), Guo Lijie (a/k/a 郭丽杰), Zhang Wei (a/k/a 张伟\\*), Lihong Wei Lafrenz (a/k/a Sara Wei, 魏丽红), Hao Haidong (a/k/a 郝海东), Ross Heinemeyer, Max Krasner, Kyle Bass, Melissa Mendez, Ya Li (a/k/a 李娅), Dinggang Wang (a/k/a 王定刚), An Hong (a/k/a 安红), Yvette Wang (a/k/a Yanping Wang, Yan Ping Wang, 王雁平), Fiona Yu, Je Kin Ming (a/k/a William Je, Yu Jianming, 余建明), Yaz Qingua, and Lao Jiang (a/k/a Jiang Yunfu, Jiang Yunfu Be, 姜云浮).\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 999 of 1063\n\n8. \"Associated Entities\" means, individually and collectively, all organizations or Entities of any type that (1) have been owned, controlled, or invested in by the Debtor or the Debtor's Family; or (2) have an interest, whether directly or indirectly, in any assets owned, controlled, or enjoyed by the Debtor or the Debtor's Family, together with the respective employees, agents, counsel, advisors, or anyone acting on behalf of any of the foregoing. Such Associated Entities shall include, but are not limited to: 7 Nod Hill LLC, AAGV Limited, ACA Investment Management Limited, ACA Capital Group Limited, Ace Decade Holdings Limited, AI Group Holdings Inc., Alfa Global Ventures Limited, Alfonso Global Limited, Allied Capital Global Limited, Alpine Fiduciaries SA, Anton Development Limited, Assets Sino Limited, Auspicious Coast Limited, Beijing Pangu Investment Co., Beijing Pangu Investment Co. Ltd., Beijing Pangu Investment Inc., Beijing Zenith Holdings Company Limited, Booming Sail New York LLC, Bravo Luck Limited, BSA Strategic Fund I, China Golden Spring (Hong Kong) Limited, Chuang Xin Limited, Crane Advisory Group LLC, Creative Apex Investments Limited, Crystal Breeze Investments Limited, Dawn State Limited, Eastern Profit Corporation Limited, Elite Well Global Limited, Empire Growth Holdings, Freedom Media Ventures Ltd., G Club Operations LLC, G Fashion LLC, G News LLC, GETTR USA, Genever Holdings Corporation, Genever Holdings LLC, Gfashion Media Group Inc., GFNY, Inc., Globalist International Limited, GNews Media Group Inc., Golden Spring (New York) Ltd., Greenwich Land LLC, Guo Media, GTV Media Group, Inc., Hamilton Capital Holdings Inc., HCHK Property Management, Inc., HCHK Technologies, Inc., Head Win Group Limited, Henan Yuda, Himalaya Embassy, Himalaya Exchange, Himalaya Federal Reserve, Himalaya Investment LLC, Himalaya International, Himalaya New World Inc., Himalaya Supervisory Organization, Himalaya Ventures LLC, HK International Funds Investments (USA) Limited LLC, Hong Kong International Funds\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 1000 of 1063\n\nInvestments Limited, Hudson Diamond Holding, Infinite Increase Limited, Infinitum Developments Limited, Infinity Treasury Management Inc., Insight Phoenix Fund, Lamp Capital LLC, Leading Shine Limited, Leading Shine NY Limited, Lexington Property and Staffing, Long Gate Limited, Maywind Trading LLC, MOS Himalaya LLC, Next Tycoon Investments Limited, New Federal State of China (a/k/a NFSC), Noble Fame Global Limited, Rosy Acme Ventures Limited, Rule of Law Foundation III, Inc., Rule of Law Foundation IV, Inc., Rule of Law Fund, Rule of Law Society, Rule of Law Society IV, Inc., G-Translators PTY LTD, Saraca Media Group, Inc., Shiny Ace Ltd., Shiny Times Holdings Ltd., Spirit Charter Investment Limited, Stevenson, Wong & Co., Voice of Guo Media, Inc., Well Origin Ltd., World Century Limited, Worldwide Opportunity Holdings Limited, Whitecroft Shore Limited, and ZIBA Limited.\n\n9. \"Including\" or any variant thereof means \"including without limitation.\"\n\n10. \"And\" and \"or\" mean \"and/or,\" and shall be construed both conjunctively as well as disjunctively in order to maximize their scope.\n\n11. \"Any\" and \"all\" and \"each\" mean \"each and every.\"\n\n12. \"Each\" and \"every\" mean \"each and every.\"\n\n13. \"Third Party\" means a Person or Entity other than Yourself.\n\n14. \"Transfer\" shall have the meaning given to it by section 101(54) of the Bankruptcy Code.\n\n15. \"Document\" means any information or thing within the scope of Fed. R. Civ. P. 34, and includes, without limitation, each and every written, recorded, or graphic matter of any kind, type, nature, or description that is or has been in Your Possession, Custody or Control, including all printed and electronic copies of electronic mail, computer files maintained in\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 1001 of 1063\n\nelectronic form, electronic communication, text message, social media post, tweet, meta-data, correspondence, memoranda, tapes, stenographic or handwritten notes, written forms of any kind, charts, blueprints, drawings, sketches, graphs, plans, articles, specifications, diaries, letters, telegrams, photographs, minutes, contracts, agreements, surveys, computer printouts, data compilations of any kind, telexes, facsimiles, voice messages, invoices, order forms, checks, drafts, statements, credit memos, reports, position reports, summaries, indices, books, ledgers, notebooks, schedules, transparencies, recordings, catalogs, advertisements, promotional materials, films, video tapes, audio tapes, CDs, computer disks, brochures, pamphlets, punchcards, time-slips, Tweets, social media posts, or any written or recorded materials of any other kind, and all meta-data thereof, however stored (whether in tangible or electronic form), recorded, produced, or reproduced, and also including but not limited to, drafts or copies of any of the foregoing that contain any notes, comments, or markings of any kind not found on the original documents or that are otherwise not identical to the original documents.\n\n16. \"Person(s)\" means an individual, corporation, proprietorship, partnership, association, or any other Entity. \"Person\" also includes any agent, representatives, or expert, including but not limiting to, attorneys or financial advisors.\n\n17. \"Entity\" means any natural Person, corporation, partnership, subsidiary, sole proprietorship, firm, board, joint venture, association, agency, authority, commission or other business entity or juristic Person, as well as any affiliate, agent, parent including but not limited to legal counsel, financial advisors, or any other representative.\n\n18. \"Regarding\" means concerning, describing, comprising, referring to, related to, supporting, favoring, opposing, bolstering, detracting from, located in, considered in connection with, bearing on, evidencing, indicating, reporting on, recording, alluding to, responding to,\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 1002 of 1063\n\nconnected with, commenting on, in respect of, about, in relation to, discussing, showing, describing, reflecting, analyzing constituting, and being.\n\n19. \"Relating to,\" \"relate(s) to\" or \"related to,\" when referring to any given subject matter, means, without limitation, any document that constitutes, comprises, involves, contains, embodies, reflects, identifies, states, refers directly or indirectly to, or is in any way relevant to the particular subject matter identified.\n\n20. \"Communication(s)\" means, in the broadest possible sense, and without limitation, any transmittal of information or knowledge (in the form of facts, ideas, inquiries, or otherwise). Communication(s) further refers to all conversations, agreements, inquiries, or replies, whether in person, by telephone, in writing, or by means of electronic transmittal devices, and includes, but is not limited to, all correspondence, emails, recordings, transmittal slips, memoranda, telephone communications, voice messages, telegrams, telefaxes, telecopies, telexes, instant messages, chats, text messages, telephonic notes, or notes transmitted internally or with third parties.\n\n21. \"Asset(s)\" means any item that can be used to produce positive economic value, including but not limited to any resource with economic value that is owned, controlled or is for the benefit of an entity, that is expected to provide a future benefit, including but not limited to, all real and personal property, intangible property, investments, rights to invest or to future revenue, cash, bank accounts, commodities, securities, claims, total or partial control of an entity, and prospective economic opportunities\n\n22. \"Transfer\" shall have the meaning given to it by section 101(54) of the Bankruptcy Code.\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 1003 of 1063\n\n#### **IV. DOCUMENTS TO BE PRODUCED**\n\n1. All Documents regarding any income or Asset of the Debtor, the Debtor's estate, or an Associated Entity.\n\n2. All Documents related to the Debtor's financial condition and obligations to his creditors, including without limitation all Documents related to any effort to avoid paying such obligations and All Documents related to this or any other actual or potential bankruptcy or similar insolvency proceeding.\n\n3. All Documents regarding any balance sheet, bank statement, account statement, financial statement, statement of account, wire transfer instructions and/or confirmation, proof of funds, certificate of deposit, certificate of holdings, investment portfolio summary, or similar document relating to the Debtor, the Debtor's Estate, the Debtor's Family, an Associated Entity, or an Associated Individual, including without limitation all Documents sufficient to show all Transfers to any of the foregoing.\n\n4. All Documents regarding any investment, business dealing or transactions made by, with, or on behalf of the Debtor.\n\n5. All Communications with the Debtor, and Documents related to Communications with the Debtor, related to the operation, management, or decision-making of any Entity, including without limitation the Associated Entities.\n\n6. All Documents regarding any Transfer, investment, or other transaction or business dealing made to, by, or with the Debtor, the Debtor's Family, or an Associated Entity.\n\n7. All Documents regarding any property ever occupied or used by the Debtor, including without limitation the *Lady May*; the Sherry Netherland Hotel / Condominium; the\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 1004 of 1063\n\nresidential property located in Greenwich, Connecticut at 373 Taconic Rd.; the residential property located in Greenwich, Connecticut at 33 Ferncliff Rd.; and the residential property located in Wilton, Connecticut at 354 Nod Hill Rd.\n\n8. All Documents related to any aircraft owned, controlled, or used by the Debtor, including without limitation the aircraft bearing tail number T7-GQM and any other aircraft registered in San Marino, including without limitation copies of all registration documents and flight manifests showing flights taken by such aircraft and the individuals onboard such flights.\n\n9. All Documents regarding any gifts, benefits or loans, to, from or on behalf of the Debtor, the Debtor's Estate, the Debtor's Family, or the Associated Entities, including without limitation Documents sufficient to show the amounts of such gifts, benefits, or loans; the purposes for which such gifts, benefits, or loans were used; when the gifts, benefits, or loans were provided; and the terms of any loans, all representations and warranties made in connection with any loans, the interest rate on any loans, and all evidence of payments of any loans.\n\n10. All Documents concerning any trust or similar instrument set up by, on behalf of, or for the benefit of the Debtor, the Debtor's Estate, the Debtor's Family, or an Associated Entity, including without limitation Documents sufficient to show when the trust(s) was created, by whom it was created, for whose benefit it was created, and the corpus of the trust.\n\n11. All Documents related to any obligation, claim, liability, or debt associated with any legal dispute involving the Debtor, including but not limited to those relating to any litigation before any local, state, federal, or international body, whether an administrative body, court, panel, or alternative dispute resolution entity.\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 1005 of 1063\n\n12. All Documents and communications between any of your outside counsel or other advisors and the Debtor.\n\n13. Documents sufficient to show all of Your Assets and sources of income or funding.\n\n14. For all Assets identified in response to Request 14 having a value of more than \\$50,000, all (i) Documents related to Your acquisition of such Asset and (ii) Communications with the Debtor or the Debtor's Family regarding such Asset.\n\n15. Copies of Your tax returns.\n\n16. Documents sufficient to show all bank accounts and investment accounts within Your possession or control, including the balances of and transfers to and from each such account.\n\n17. All Documents regarding any credit cards used by You, including without limitation monthly statements or other Documents sufficient to show all purchases related thereto for the benefit of the Debtor or an Associated Entity.\n\n18. All corporate governance and organizational Documents, including without limitation by-laws and certificates of incorporation and other Documents sufficient to show Your corporate structure, names of officers and directors, business purpose, and relationship to the Debtor or to any member of the Debtor's Family.\n\n19. All Documents related to any pledge(s) of Your Assets to any other Entity.\n\nCase 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 1006 of 1063\n\n# Exhibit C-55\n\n#### B2540 (Form 2540 – Subpoena for Rule 2004 Examination) (12/15) Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 1007 of\n\nUNITED STATES BANKRUPTCY COURT 1063\n\n**District of Connecticut**\n\nIn re HO WAN KWOK, *et al*.,\n\n<sup>1</sup> Case No. 22-50073 (JAM) Debtor Chapter 11\n\n(Jointly Administered)\n\n# **SUBPOENA FOR RULE 2004 EXAMINATION**\n\nTo: **Oasis Tech Limited**\n\n(*Name of person to whom the subpoena is directed*)\n\n*Testimony:* **YOU ARE COMMANDED** to appear at the time, date, and place set forth below to testify at an examination under Rule 2004, Federal Rules of Bankruptcy Procedure. A copy of the court order authorizing the examination is attached.\n\n| PLACE                    | DATE AND TIME |\n|--------------------------|---------------|\n| Paul Hastings LLP        |               |\n| 200 Park Avenue          | [TBD]         |\n| New York, New York 10166 |               |\n|                          |               |\n\nThe examination will be recorded by this method: **Court reporter/stenographer**\n\n*Production:* You, or your representatives, must also bring with you to the examination the following documents, electronically stored information, or objects, and must permit inspection, copying, testing, or sampling of the material:\n\n#### **See Requests for Production of Documents, attached hereto.**\n\nThe following provisions of Fed. R. Civ. P. 45, made applicable in bankruptcy cases by Fed. R. Bankr. P. 9016, are attached – Rule 45(c), relating to the place of compliance; Rule 45(d), relating to your protection as a person subject to a subpoena; and Rule 45(e) and 45(g), relating to your duty to respond to this subpoena and the potential consequences of not doing so.\n\nDate: **March , 2023**\n\nCLERK OF COURT\n\nOR\n\n*Signature of Clerk or Deputy Clerk Attorney's signature*\n\nThe name, address, email address, and telephone number of the attorney representing Luc A. Despins, Chapter 11 Trustee, who issues or requests this subpoena, are:\n\n**Douglas S. Skalka, Esq.; Neubert, Pepe & Monteith, P.C.; 195 Church Street, New Haven, Connecticut 06510 dskalka@npmlaw.com; (203) 821-2000**\n\n**Notice to the person who issues or requests this subpoena**\n\nIf this subpoena commands the production of documents, electronically stored information, or tangible things, or the inspection of premises before trial, a notice and a copy of this subpoena must be served on each party before it is served on the person to whom it is directed. Fed. R. Civ. P. 45(a)(4).\n\nSoftware Copyright (c) 1996-2022 Best Case, LLC - www.bestcase.com Best Case Bankruptcy 1 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\n#### **PROOF OF SERVICE**\n\n**(This section should not be filed with the court unless required by Fed. R. Civ. P. 45.)**\n\nI received this subpoena for (*name of individual and title, if any*): on (*date*) .\n\nI served the subpoena by delivering a copy to the named person as follows:\n\non *(date)* ; or\n\nI returned the subpoena unexecuted because:\n\nUnless the subpoena was issued on behalf of the United States, or one of its officers or agents, I have also tendered to the witness the fees for one day's attendance, and the mileage allowed by law, in the amount of \\$ .\n\nMy fees are \\$ for travel and \\$ for services, for a total of \\$ .\n\nI declare under penalty of perjury that this information is true and correct.\n\nDate:\n\n*Server's signature*\n\n*Printed name and title*\n\n*Server's address*\n\nAdditional information concerning attempted service, etc.:\n\n#### **Federal Rule of Civil Procedure 45(c), (d), (e), and (g) (Effective 12/1/13) (made applicable in bankruptcy cases by Rule 9016, Federal Rules of Bankruptcy Procedure)**\n\n#### **(c) Place of compliance.**\n\n*(1) For a Trial, Hearing, or Deposition.* A subpoena may command a person to attend a trial, hearing, or deposition only as follows:\n\n(A) within 100 miles of where the person resides, is employed, or regularly transacts business in person; or\n\n(B) within the state where the person resides, is employed, or regularly transacts business in person, if the person\n\n(i) is a party or a party's officer; or\n\n(ii) is commanded to attend a trial and would not incur substantial expense.\n\n*(2) For Other Discovery.* A subpoena may command:\n\n(A) production of documents, or electronically stored information, or things at a place within 100 miles of where the person resides, is employed, or regularly transacts business in person; and\n\n(B) inspection of premises, at the premises to be inspected.\n\n#### **(d) Protecting a Person Subject to a Subpoena; Enforcement.**\n\n*(1) Avoiding Undue Burden or Expense; Sanctions.* A party or attorney responsible for issuing and serving a subpoena must take reasonable steps to avoid imposing undue burden or expense on a person subject to the subpoena. The court for the district where compliance is required must enforce this duty and impose an appropriate sanction which may include lost earnings and reasonable attorney's fees — on a party or attorney who fails to comply.\n\n#### *(2) Command to Produce Materials or Permit Inspection.*\n\n*(A) Appearance Not Required.* A person commanded to produce documents, electronically stored information, or tangible things, or to permit the inspection of premises, need not appear in person at the place of production or inspection unless also commanded to appear for a deposition, hearing, or trial.\n\n*(B) Objections.* A person commanded to produce documents or tangible things or to permit inspection may serve on the party or attorney designated in the subpoena a written objection to inspecting, copying, testing or sampling any or all of the materials or to inspecting the premises — or to producing electronically stored information in the form or forms requested. The objection must be served before the earlier of the time specified for compliance or 14 days after the subpoena is served. If an objection is made, the following rules apply:\n\n(i) At any time, on notice to the commanded person, the serving party may move the court for the district where compliance is required for an order compelling production or inspection.\n\n(ii) These acts may be required only as directed in the order, and the order must protect a person who is neither a party nor a party's officer from significant expense resulting from compliance.\n\n#### *(3) Quashing or Modifying a Subpoena.*\n\n*(A) When Required.* On timely motion, the court for the district where compliance is required must quash or modify a subpoena that:\n\n(i) fails to allow a reasonable time to comply;\n\n(ii) requires a person to comply beyond the geographical limits specified in Rule 45(c);\n\n(iii) requires disclosure of privileged or other protected matter, if no exception or waiver applies; or\n\n(iv) subjects a person to undue burden.\n\n*(B) When Permitted.* To protect a person subject to or affected by a subpoena, the court for the district where compliance is required may, on motion, quash or modify the subpoena if it requires:\n\n(i) disclosing a trade secret or other confidential research, development, or commercial information; or\n\n(ii) disclosing an unretained expert's opinion or information that does not describe specific occurrences in dispute and results from the expert's study that was not requested by a party.\n\n(C) *Specifying Conditions as an Alternative.* In the circumstances described in Rule 45(d)(3)(B), the court may, instead of quashing or modifying a subpoena, order appearance or production under specified conditions if the serving party:\n\n(i) shows a substantial need for the testimony or material that cannot be otherwise met without undue hardship; and\n\n(ii) ensures that the subpoenaed person will be reasonably compensated.\n\n#### **(e) Duties in Responding to a Subpoena.**\n\n*(1) Producing Documents or Electronically Stored Information.* These procedures apply to producing documents or electronically stored information:\n\n*(A) Documents.* A person responding to a subpoena to produce documents must produce them as they are kept in the ordinary course of business or must organize and label them to correspond to the categories in the demand.\n\n*(B) Form for Producing Electronically Stored Information Not Specified.* If a subpoena does not specify a form for producing electronically stored information, the person responding must produce it in a form or forms in which it is ordinarily maintained or in a reasonably usable form or forms.\n\n*(C) Electronically Stored Information Produced in Only One Form.* The person responding need not produce the same electronically stored information in more than one form.\n\n*(D) Inaccessible Electronically Stored Information.* The person responding need not provide discovery of electronically stored information from sources that the person identifies as not reasonably accessible because of undue burden or cost. On motion to compel discovery or for a protective order, the person responding must show that the information is not reasonably accessible because of undue burden or cost. If that showing is made, the court may nonetheless order discovery from such sources if the requesting party shows good cause, considering the limitations of Rule 26(b)(2)(C). The court may specify conditions for the discovery.\n\n#### *(2) Claiming Privilege or Protection.*\n\n*(A) Information Withheld.* A person withholding subpoenaed information under a claim that it is privileged or subject to protection as trial-preparation material must: (i) expressly make the claim; and\n\n(ii) describe the nature of the withheld documents, communications, or tangible things in a manner that, without revealing information itself privileged or protected, will enable the parties to assess the claim.\n\n*(B) Information Produced.* If information produced in response to a subpoena is subject to a claim of privilege or of protection as trial-preparation material, the person making the claim may notify any party that received the information of the claim and the basis for it. After being notified, a party must promptly return, sequester, or destroy the specified information and any copies it has; must not use or disclose the information until the claim is resolved; must take reasonable steps to retrieve the information if the party disclosed it before being notified; and may promptly present the information under seal to the court for the district where compliance is required for a determination of the claim. The person who produced the information must preserve the information until the claim is resolved.\n\n**(g) Contempt.** The court for the district where compliance is required – and also, after a motion is transferred, the issuing court – may hold in contempt a person who, having been served, fails without adequate excuse to obey the subpoena or an order related to it.\n\nFor access to subpoena materials, see Fed.R.Civ.P.45(a) Committee Note (2013)\n\n…\n\n## **Requests for Production of Documents**\n\n## **I. INSTRUCTIONS**\n\n1. Unless otherwise indicated, the requests for documents set forth below, (the \"Requests,\" and each, a \"Request\"), must be responded to separately and specifically. Each Request shall be answered fully unless it is in good faith objected to, in which event the reason for Your objection shall be stated in detail, as set forth below. If an objection pertains only to a portion of a Request, or a word, phrase or clause contained within it, You are required to state Your objection to that portion only and to respond to the remainder of the Requests.\n\n2. Electronically stored information must be produced in accordance with the\n\nfollowing instructions:\n\n- a. Images. Black and white images must be 300 DPI Group IV single-page TIFF files. Color images must be produced in JPEG format. File names cannot contain embedded spaces or special characters (including the comma). Folder names cannot contain embedded spaces or special characters (including the comma). All TIFF image files must have a unique file name, i.e. Bates number. Images must be endorsed with sequential Bates numbers in the lower right corner of each image. The number of TIFF files per folder should not exceed 1000 files. Excel spreadsheets should have a placeholder image named by the Bates number of the file.\n- b. Image Load File\n\t- a. Concordance® Data File. The data file (.DAT) contains all of the fielded information that will be loaded into the Concordance® database. The first line of the .DAT file must be a header row identifying the field names. The .DAT file must use the following Concordance® default delimiters: Comma ASCII character (020) Quote þ ASCII character (254). Date fields should be provided in the format: mm/dd/yyyy. Date and time fields must be two separate fields. If documents includes imaged emails and attachments, the attachment fields must be included to preserve the parent/child relationship between an email and its attachments. An OCRPATH field must be included to provide the file path and name of the extracted text file on the produced storage media. The text file must be named after the FIRSTBATES. Do not include the text in the .DAT file. For Documents with native files, a LINK field must be included to provide the file path and\n\nname of the native file. The native file must be named after the FIRSTBATES.\n\n- b. Concordance Image® OR Opticon Cross-Reference File. The image crossreference file (.LOG or .OPT) links the images to the database records. It should be a comma-delimited file consisting of seven fields per line with a line in the cross-reference file for every image in the database with the following format: ImageID,VolumeLabel,ImageFilePath,DocumentBreak,FolderBreak,Box Break,PageCoun.\n- c. Document Text. Text must be produced as separate text files, not as fields within the .DAT file. The full path to the text file (OCRPATH) should be included in the .DAT file. It is recommended document level ANSI text files, named per the FIRSTBATES/Image Key. Extracted text files must be in a separate folder, and the number of text files per folder should not exceed 1,000 files. There should be no special characters (including commas in the folder names). Text files must be provided on a document level.\n- d. Native Production for Certain File Types. File types that reasonably require viewing in their native format for a full understanding of their content and meaning must be produced in native format. These include, but are not limited to, spreadsheets, spreadsheet-like files (Microsoft Excel, comma separated values, tab separated values, etc.), Microsoft PowerPoint or other special presentation files, database files, and audio/visual files. Provide an image of a Bates numbered slip sheet indicating the presence of a native file, and include the path to the native as a field in the .dat file. Name the produced native file with the Bates number corresponding to the slip sheet for the file. Group native files within incrementally named \"NATIVE\" directories, separate from images directories.\n- e. De-duplication. Produce a single copy of each electronic document for which exact duplicates exist. For email messages, consolidate duplicates based on MD5 hash generated from the BCC, Body, CC, From, IntMsgID, To, and Attach properties. For email attachments and standalone electronic files, consolidate duplicates based on MD5 hash of the entire file.\n- f. Metadata. Produce extracted metadata for each document in the form of a Concordance compliant load file (.dat). The first line of the .DAT file must be a header row identifying the field names. The .DAT file must use the following Concordance default delimiters: Comma , ASCII character (020) Quote þ ASCII character (254)\n\nDate fields should be provided in the format: mm/dd/yyyy. Date and time fields must be two separate fields. Required metadata listed below:\n\n# Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 1012 of 1063\n\n| Field Name   | Sample Data              | Description                                      |\n|--------------|--------------------------|--------------------------------------------------|\n| FIRSTBATES   | EDC0000001               | First Bates number of native file document/email |\n| LASTBATES    | EDC0000001               | Last Bates number of native file document/email  |\n|              |                          | **The LASTBATES field should be populated        |\n|              |                          | for single page                                  |\n| ATTACHRANGE  | EDC0000001<br>-          | Bates number of the first page of the parent     |\n|              | EDC0000015               | document to the Bates number of the last page of |\n|              |                          | the last attachment \"child\" document             |\n| BEGATTACH    | EDC0000001               | First Bates number of attachment range           |\n| ENDATTACH    | EDC0000015               | Last Bates number of attachment range            |\n| CUSTODIAN    | Smith, John              | Email: Mailbox where the email resided           |\n|              |                          | Native: Name of the individual or department     |\n|              |                          | from whose files the document<br>originated      |\n| FROM         | John Smith               | Email: Sender                                    |\n|              |                          | Native: Author(s) of document                    |\n|              |                          | **semi-colon should be used to separate          |\n|              |                          | multiple entries                                 |\n| TO           | Coffman, Janice; LeeW    | Recipient(s)                                     |\n|              | [mailto:LeeW@MSN.com]    | **semi-colon should be used to separate multiple |\n|              |                          | entries                                          |\n| CC           | Frank Thompson [mailto:  | Carbon copy recipient(s)                         |\n|              | frank_Thompson@cdt.com]  | **semi-colon should be used to separate          |\n|              |                          | multiple entries                                 |\n| BCC          | John Cain                | Blind carbon copy recipient(s)                   |\n|              |                          | **semi-colon should be used to separate          |\n|              |                          | multiple entries                                 |\n| SUBJECT      | Board Meeting Minutes    | Email: Subject line of the email Native: Title   |\n|              |                          | of document (if available)                       |\n| FILE_NAME    | BoardMeetingMinutes.docx | Native: Name of the original native file,        |\n|              |                          | including extension                              |\n| DATE_SENT    | 10/12/2010               | Email: Date the email was sent                   |\n|              |                          | Native: (empty)                                  |\n| TIME_SENT/   | 07:05 PM GMT             | Email: Time the email was sent/ Time zone in     |\n| TIME_ZONE    |                          | which the emails were standardized               |\n| TIME_ZONE    | GMT                      | The<br>time zone in which<br>the emails<br>were  |\n|              |                          | standardized during conversion.                  |\n| LINK         |  EDC0000001.msg   | Hyperlink to the email or native file document   |\n|              |                          | **The linked file must be named per the          |\n|              |                          | FIRSTBATES number                                |\n| FILE_EXTEN   | MSG                      | The file type extension                          |\n|              |                          | representing                                     |\n|              |                          | the Email or                                     |\n| AUTHOR       | John Smith               | Email: (empty)                                   |\n|              |                          | Native: Author of the document                   |\n| DATE_CREATED | 10/10/2010               | Email: (empty)                                   |\n|              |                          | Native: Date the document was created            |\n\n# Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 1013 of 1063\n\n| TIME_CREATED | 10:25 AM                  | Email: (empty)                                  |\n|--------------|---------------------------|-------------------------------------------------|\n|              |                           | Native: Time the document was created           |\n|              |                           | **This data must be a separate field and cannot |\n|              |                           | be combined with the DATE_CREATED field         |\n| DATE_MOD     | 10/12/2010                | Email: (empty)                                  |\n|              |                           | Native: Date the document was last modified     |\n| TIME_MOD     | 07:00 PM                  | Email: (empty)                                  |\n|              |                           | Native: Time the document was last modified     |\n|              |                           | **This data must be a separate field and cannot |\n|              |                           | be combined with the DATE_MOD field             |\n| DATE_ACCESSD | 10/12/2010                | Email: (empty)                                  |\n|              |                           | Native: Date the document was last accessed     |\n| TIME_ACCESSD | 07:00 PM                  | Email: (empty)                                  |\n|              |                           | Native: Time the document was last accessed     |\n|              |                           | **This data must be a separate field and cannot |\n|              |                           | be combined with the DATE_ACCESSD field         |\n| FILE_SIZE    | 5,952                     | Size of native file<br>document/email in KB     |\n| PGCOUNT      | 1                         | Number of pages in native file document/email   |\n| PATH         |   | Email: (empty)                                  |\n|              | Agenda.doc                | Native: Path where native file document was     |\n|              |                           | stored including original file name.            |\n| INTFILEPATH  | Personal Folders\\Deleted  | Email: original location of email including     |\n|              | Items\\Board Meeting       | original file name.                             |\n|              | Minutes.msg               | Native: (empty)                                 |\n| INTMSGID     | <000805c2c71b\\$75977050\\$ | Email: Unique Message ID Native: (empty)        |\n|              | cb8306d1@MSN>             |                                                 |\n| MD5HASH      | d131dd02c5e6eec4693d9a0   | MD5 Hash value of the document.                 |\n|              | 698aff95c                 |                                                 |\n|              | 2fcab58712467eab4004583e  |                                                 |\n|              | b8fb7f89                  |                                                 |\n| OCRPATH      | TEXT/001/EDC0000001.txt   | Path to extracted text of the native file       |\n\n3. Each Request operates and should be construed independently and, unless otherwise indicated, no Request limits the scope of any other Request.\n\n4. All Documents are to be produced as kept in the usual course of business or are to be organized and labeled to correspond with the categories in these Requests.\n\n5. Each Request contained herein extends to all Documents: (a) in Your possession, custody, or control; or (b) in the possession, custody, or control of anyone acting on Your behalf,\n\n#### Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 1014 of 1063\n\nincluding Your counsel or other representatives and advisors. Each Document shall be produced in its entirety.\n\n6. If You are requested to produce a Document that is no longer in Your possession, custody, or control, then Your response must (a) describe in detail the nature of the document and its contents; (b) identify the person(s) who prepared or authored the Document (and, if applicable, the Person(s) to whom the Document was sent); (c) identify the date on which the document was prepared or created; (d) state whether such Document (i) is missing or lost, (ii) has been destroyed, (iii) has been transferred, voluntarily or involuntarily, to others, or (iv) was otherwise disposed of; (e) state the reason for, and the facts and circumstances surrounding, such disposition; (f) identify the Persons who authorized such disposition; (g) identify the date or approximate date of such disposition; (h) state when the Document was most recently in Your possession, custody or control; and (i) identify the Person, if any, presently in possession, custody, or control of such Document.\n\n7. If You are requested to produce a Document that has been destroyed, then Your response must state, in addition to the information required by the preceding Instruction: (a) the reason for the Document's destruction; (b) the identity of the Person who destroyed the Document; and (c) the identity of the Person who directed that the Document be destroyed.\n\n8. If You claim that a requested Document is privileged or attorney work-product, then Your response must: (a) state (i) a description of the Document adequate to support Your contention that the Document is privileged, (ii) the title of the Document, (iii) the date of the Document, (iv) the author of the Document, (v) the addressee of the Document, (vi) the identity of each Person who received or saw the original or any draft, copy, or reproduction of the Document, (vii) whether the Document itself, or any information contained or referred to in the Document is in the possession, custody, or control of any other Persons, and if so, the identity of\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 1015 of 1063\n\nsuch Persons, as well as a statement addressing how the information came into their possession, (viii) the claim of privilege under which the Document is withheld, and (ix) all of the circumstances upon which You will rely to support such claim of privilege; and (b) produce a privilege log containing all of the information requested in Part (a) of this Instruction for each Document withheld on the basis of a claim of privilege in accordance with D. Conn. L. Civ. R. 26(e).\n\n9. If a portion of an otherwise responsive Document contains information subject to a claim of privilege, only that portion of the Document subject to the claim of privilege shall be deleted or redacted from the Document following the instructions above, and the rest shall be produced.\n\n10. The Requests are continuing in nature. You are hereby instructed to (a) supplement or correct any responses later learned to be incomplete or incorrect immediately upon learning that a prior response was incomplete or incorrect; and (b) produce any additional Documents that are called for under the\n\n11. If a Document is in a language other than English, You should provide that Document. If a Document is in a language other than English, and an English translation exists, You should provide both Documents.\n\n12. All references to Entities includes all affiliates thereof.\n\n13. All references to individual names include all alternative names, aliased, or nicknames.\n\n14. Unless otherwise expressly indicated, the period of time covered by the Document Requests is the period from February 5, 2012 to the date responses to the Document Requests are due.\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 1016 of 1063\n\n#### **II. RULES OF CONSTRUCTION**\n\n15. The use of (a) any singular noun shall be construed to include the plural, and vice versa, and (b) a verb in any tense shall be construed as the use of the verb in all other tenses.\n\n16. The terms (a) \"and\" and \"or\" shall be construed either conjunctively or disjunctively as necessary to bring within the scope of any request all responses that might otherwise be construed to be outside of its scope, and (b) \"each\" and \"any\" shall be deemed to include and encompass the words \"every\" and \"all.\"\n\n#### **III. DEFINITIONS**\n\nThe definitions supplied by D. Conn. L. Civ. R. 26(c) and the rules of construction supplied by D. Conn. L. Civ. R. 26(d), as incorporated by D. Conn. Bankr. L.R. 2004-1(a), shall apply to the Document Requests. In addition, the following terms used in these Document Requests shall have the following meanings:\n\n1. \"You\" or \"Your\" or \"Yourself\" means and refers to Oasis Tech Limited, together with all of its affiliates, divisions, agencies, instrumentalities, departments, offices, partners, officers, directors, agents, attorneys, representatives, employees, and/or anyone acting on its behalf.\n\n2. \"Debtor\" means Ho Wan Kwok (a/k/a Miles Kwok, Miles Guo, Guo Wengui, Guo Haoyun, 郭文贵, or any other alias), together with his employees, agents, counsel, advisors, or anyone acting on his behalf.\n\n3. \"Debtor's Son\" means Qiang Guo (a/k/a Mileson Kwok, 郭强, or any other alias), together with his employees, agents, counsel, advisors, or anyone acting on his behalf.\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 1017 of 1063\n\n4. \"Debtor's Daughter\" means Mei Guo (a/k/a Mei Gui, 郭美, or any other alias), together with her employees, agents, counsel, advisors, or anyone acting on her behalf.\n\n5. \"Debtor's Purported Wife\" means Hing Chi Ngok (a/k/a Hing Chi Ng, Yue Qingzhi, 岳庆芝, or any other alias), together with her employees, agents, counsel, advisors, or anyone acting on her behalf.\n\n6. \"Debtor's Family\" means, collectively, the Debtor, the Debtor's Son, the Debtor's Daughter, and the Debtor's Purported Wife, and any other familial relation to the Debtor.\n\n7. \"Associated Individuals\" means, individually and collectively, all individuals that (1) hold, control, have custody over, or discretion over assets owned, controlled, or enjoyed by the Debtor or the Debtor's Family; or (2) have been employees, directors, or otherwise are affiliated with one or more Associated Entities, together with the respective employees, agents, counsel, advisors, or anyone acting on behalf of any of the foregoing. Such Associated Individuals shall include, but are not limited to: Daniel Podhaskie, Jason Miller, Steve Bannon, Karin Maistrello, Melissa Francis, Anthony DiBattista, William Gertz, Arethusa Forsyth, Glenn Mellor, Jennifer Mercurio, Eduardo Eurnekian, Wencong Wang, Han Chunguang (a/k/a 韩春光), Qu Guojiao (a/k/a Qu Guo Jiao, 屈国姣), Guo Lijie (a/k/a 郭丽杰), Zhang Wei (a/k/a 张伟\\*), Lihong Wei Lafrenz (a/k/a Sara Wei, 魏丽红), Hao Haidong (a/k/a 郝海东), Ross Heinemeyer, Max Krasner, Kyle Bass, Melissa Mendez, Ya Li (a/k/a 李娅), Dinggang Wang (a/k/a 王定刚), An Hong (a/k/a 安红), Yvette Wang (a/k/a Yanping Wang, Yan Ping Wang, 王雁平), Fiona Yu, Je Kin Ming (a/k/a William Je, Yu Jianming, 余建明), Yaz Qingua, and Lao Jiang (a/k/a Jiang Yunfu, Jiang Yunfu Be, 姜云浮).\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 1018 of 1063\n\n8. \"Associated Entities\" means, individually and collectively, all organizations or Entities of any type that (1) have been owned, controlled, or invested in by the Debtor or the Debtor's Family; or (2) have an interest, whether directly or indirectly, in any assets owned, controlled, or enjoyed by the Debtor or the Debtor's Family, together with the respective employees, agents, counsel, advisors, or anyone acting on behalf of any of the foregoing. Such Associated Entities shall include, but are not limited to: 7 Nod Hill LLC, AAGV Limited, ACA Investment Management Limited, ACA Capital Group Limited, Ace Decade Holdings Limited, AI Group Holdings Inc., Alfa Global Ventures Limited, Alfonso Global Limited, Allied Capital Global Limited, Alpine Fiduciaries SA, Anton Development Limited, Assets Sino Limited, Auspicious Coast Limited, Beijing Pangu Investment Co., Beijing Pangu Investment Co. Ltd., Beijing Pangu Investment Inc., Beijing Zenith Holdings Company Limited, Booming Sail New York LLC, Bravo Luck Limited, BSA Strategic Fund I, China Golden Spring (Hong Kong) Limited, Chuang Xin Limited, Crane Advisory Group LLC, Creative Apex Investments Limited, Crystal Breeze Investments Limited, Dawn State Limited, Eastern Profit Corporation Limited, Elite Well Global Limited, Empire Growth Holdings, Freedom Media Ventures Ltd., G Club Operations LLC, G Fashion LLC, G News LLC, GETTR USA, Genever Holdings Corporation, Genever Holdings LLC, Gfashion Media Group Inc., GFNY, Inc., Globalist International Limited, GNews Media Group Inc., Golden Spring (New York) Ltd., Greenwich Land LLC, Guo Media, GTV Media Group, Inc., Hamilton Capital Holdings Inc., HCHK Property Management, Inc., HCHK Technologies, Inc., Head Win Group Limited, Henan Yuda, Himalaya Embassy, Himalaya Exchange, Himalaya Federal Reserve, Himalaya Investment LLC, Himalaya International, Himalaya New World Inc., Himalaya Supervisory Organization, Himalaya Ventures LLC, HK International Funds Investments (USA) Limited LLC, Hong Kong International Funds\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 1019 of 1063\n\nInvestments Limited, Hudson Diamond Holding, Infinite Increase Limited, Infinitum Developments Limited, Infinity Treasury Management Inc., Insight Phoenix Fund, Lamp Capital LLC, Leading Shine Limited, Leading Shine NY Limited, Lexington Property and Staffing, Long Gate Limited, Maywind Trading LLC, MOS Himalaya LLC, Next Tycoon Investments Limited, New Federal State of China (a/k/a NFSC), Noble Fame Global Limited, Rosy Acme Ventures Limited, Rule of Law Foundation III, Inc., Rule of Law Foundation IV, Inc., Rule of Law Fund, Rule of Law Society, Rule of Law Society IV, Inc., G-Translators PTY LTD, Saraca Media Group, Inc., Shiny Ace Ltd., Shiny Times Holdings Ltd., Spirit Charter Investment Limited, Stevenson, Wong & Co., Voice of Guo Media, Inc., Well Origin Ltd., World Century Limited, Worldwide Opportunity Holdings Limited, Whitecroft Shore Limited, and ZIBA Limited.\n\n9. \"Including\" or any variant thereof means \"including without limitation.\"\n\n10. \"And\" and \"or\" mean \"and/or,\" and shall be construed both conjunctively as well as disjunctively in order to maximize their scope.\n\n11. \"Any\" and \"all\" and \"each\" mean \"each and every.\"\n\n12. \"Each\" and \"every\" mean \"each and every.\"\n\n13. \"Third Party\" means a Person or Entity other than Yourself.\n\n14. \"Transfer\" shall have the meaning given to it by section 101(54) of the Bankruptcy Code.\n\n15. \"Document\" means any information or thing within the scope of Fed. R. Civ. P. 34, and includes, without limitation, each and every written, recorded, or graphic matter of any kind, type, nature, or description that is or has been in Your Possession, Custody or Control, including all printed and electronic copies of electronic mail, computer files maintained in\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 1020 of 1063\n\nelectronic form, electronic communication, text message, social media post, tweet, meta-data, correspondence, memoranda, tapes, stenographic or handwritten notes, written forms of any kind, charts, blueprints, drawings, sketches, graphs, plans, articles, specifications, diaries, letters, telegrams, photographs, minutes, contracts, agreements, surveys, computer printouts, data compilations of any kind, telexes, facsimiles, voice messages, invoices, order forms, checks, drafts, statements, credit memos, reports, position reports, summaries, indices, books, ledgers, notebooks, schedules, transparencies, recordings, catalogs, advertisements, promotional materials, films, video tapes, audio tapes, CDs, computer disks, brochures, pamphlets, punchcards, time-slips, Tweets, social media posts, or any written or recorded materials of any other kind, and all meta-data thereof, however stored (whether in tangible or electronic form), recorded, produced, or reproduced, and also including but not limited to, drafts or copies of any of the foregoing that contain any notes, comments, or markings of any kind not found on the original documents or that are otherwise not identical to the original documents.\n\n16. \"Person(s)\" means an individual, corporation, proprietorship, partnership, association, or any other Entity. \"Person\" also includes any agent, representatives, or expert, including but not limiting to, attorneys or financial advisors.\n\n17. \"Entity\" means any natural Person, corporation, partnership, subsidiary, sole proprietorship, firm, board, joint venture, association, agency, authority, commission or other business entity or juristic Person, as well as any affiliate, agent, parent including but not limited to legal counsel, financial advisors, or any other representative.\n\n18. \"Regarding\" means concerning, describing, comprising, referring to, related to, supporting, favoring, opposing, bolstering, detracting from, located in, considered in connection with, bearing on, evidencing, indicating, reporting on, recording, alluding to, responding to,\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 1021 of 1063\n\nconnected with, commenting on, in respect of, about, in relation to, discussing, showing, describing, reflecting, analyzing constituting, and being.\n\n19. \"Relating to,\" \"relate(s) to\" or \"related to,\" when referring to any given subject matter, means, without limitation, any document that constitutes, comprises, involves, contains, embodies, reflects, identifies, states, refers directly or indirectly to, or is in any way relevant to the particular subject matter identified.\n\n20. \"Communication(s)\" means, in the broadest possible sense, and without limitation, any transmittal of information or knowledge (in the form of facts, ideas, inquiries, or otherwise). Communication(s) further refers to all conversations, agreements, inquiries, or replies, whether in person, by telephone, in writing, or by means of electronic transmittal devices, and includes, but is not limited to, all correspondence, emails, recordings, transmittal slips, memoranda, telephone communications, voice messages, telegrams, telefaxes, telecopies, telexes, instant messages, chats, text messages, telephonic notes, or notes transmitted internally or with third parties.\n\n21. \"Asset(s)\" means any item that can be used to produce positive economic value, including but not limited to any resource with economic value that is owned, controlled or is for the benefit of an entity, that is expected to provide a future benefit, including but not limited to, all real and personal property, intangible property, investments, rights to invest or to future revenue, cash, bank accounts, commodities, securities, claims, total or partial control of an entity, and prospective economic opportunities\n\n22. \"Transfer\" shall have the meaning given to it by section 101(54) of the Bankruptcy Code.\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 1022 of 1063\n\n#### **IV. DOCUMENTS TO BE PRODUCED**\n\n1. All Documents regarding any income or Asset of the Debtor, the Debtor's estate, or an Associated Entity.\n\n2. All Documents related to the Debtor's financial condition and obligations to his creditors, including without limitation all Documents related to any effort to avoid paying such obligations and All Documents related to this or any other actual or potential bankruptcy or similar insolvency proceeding.\n\n3. All Documents regarding any balance sheet, bank statement, account statement, financial statement, statement of account, wire transfer instructions and/or confirmation, proof of funds, certificate of deposit, certificate of holdings, investment portfolio summary, or similar document relating to the Debtor, the Debtor's Estate, the Debtor's Family, an Associated Entity, or an Associated Individual, including without limitation all Documents sufficient to show all Transfers to any of the foregoing.\n\n4. All Documents regarding any investment, business dealing or transactions made by, with, or on behalf of the Debtor.\n\n5. All Communications with the Debtor, and Documents related to Communications with the Debtor, related to the operation, management, or decision-making of any Entity, including without limitation the Associated Entities.\n\n6. All Documents regarding any Transfer, investment, or other transaction or business dealing made to, by, or with the Debtor, the Debtor's Family, or an Associated Entity.\n\n7. All Documents regarding any property ever occupied or used by the Debtor, including without limitation the *Lady May*; the Sherry Netherland Hotel / Condominium; the\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 1023 of 1063\n\nresidential property located in Greenwich, Connecticut at 373 Taconic Rd.; the residential property located in Greenwich, Connecticut at 33 Ferncliff Rd.; and the residential property located in Wilton, Connecticut at 354 Nod Hill Rd.\n\n8. All Documents related to any aircraft owned, controlled, or used by the Debtor, including without limitation the aircraft bearing tail number T7-GQM and any other aircraft registered in San Marino, including without limitation copies of all registration documents and flight manifests showing flights taken by such aircraft and the individuals onboard such flights.\n\n9. All Documents regarding any gifts, benefits or loans, to, from or on behalf of the Debtor, the Debtor's Estate, the Debtor's Family, or the Associated Entities, including without limitation Documents sufficient to show the amounts of such gifts, benefits, or loans; the purposes for which such gifts, benefits, or loans were used; when the gifts, benefits, or loans were provided; and the terms of any loans, all representations and warranties made in connection with any loans, the interest rate on any loans, and all evidence of payments of any loans.\n\n10. All Documents concerning any trust or similar instrument set up by, on behalf of, or for the benefit of the Debtor, the Debtor's Estate, the Debtor's Family, or an Associated Entity, including without limitation Documents sufficient to show when the trust(s) was created, by whom it was created, for whose benefit it was created, and the corpus of the trust.\n\n11. All Documents related to any obligation, claim, liability, or debt associated with any legal dispute involving the Debtor, including but not limited to those relating to any litigation before any local, state, federal, or international body, whether an administrative body, court, panel, or alternative dispute resolution entity.\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 1024 of 1063\n\n12. All Documents and communications between any of your outside counsel or other advisors and the Debtor.\n\n13. Documents sufficient to show all of Your Assets and sources of income or funding.\n\n14. For all Assets identified in response to Request 14 having a value of more than \\$50,000, all (i) Documents related to Your acquisition of such Asset and (ii) Communications with the Debtor or the Debtor's Family regarding such Asset.\n\n15. Copies of Your tax returns.\n\n16. Documents sufficient to show all bank accounts and investment accounts within Your possession or control, including the balances of and transfers to and from each such account.\n\n17. All Documents regarding any credit cards used by You, including without limitation monthly statements or other Documents sufficient to show all purchases related thereto for the benefit of the Debtor or an Associated Entity.\n\n18. All corporate governance and organizational Documents, including without limitation by-laws and certificates of incorporation and other Documents sufficient to show Your corporate structure, names of officers and directors, business purpose, and relationship to the Debtor or to any member of the Debtor's Family.\n\n19. All Documents related to any pledge(s) of Your Assets to any other Entity.\n\nCase 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 1025 of 1063\n\n# Exhibit C-56\n\n#### B2540 (Form 2540 – Subpoena for Rule 2004 Examination) (12/15) Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 1026 of\n\nUNITED STATES BANKRUPTCY COURT 1063\n\n**District of Connecticut**\n\nIn re HO WAN KWOK, *et al*.,\n\n<sup>1</sup> Case No. 22-50073 (JAM)\n\nDebtor Chapter 11\n\n(Jointly Administered)\n\n# **SUBPOENA FOR RULE 2004 EXAMINATION**\n\nTo: **Joyord Sportswear Limited**\n\n(*Name of person to whom the subpoena is directed*)\n\n*Testimony:* **YOU ARE COMMANDED** to appear at the time, date, and place set forth below to testify at an examination under Rule 2004, Federal Rules of Bankruptcy Procedure. A copy of the court order authorizing the examination is attached.\n\n| PLACE                    | DATE AND TIME |\n|--------------------------|---------------|\n| Paul Hastings LLP        |               |\n| 200 Park Avenue          | [TBD]         |\n| New York, New York 10166 |               |\n|                          |               |\n\nThe examination will be recorded by this method: **Court reporter/stenographer**\n\n*Production:* You, or your representatives, must also bring with you to the examination the following documents, electronically stored information, or objects, and must permit inspection, copying, testing, or sampling of the material:\n\n#### **See Requests for Production of Documents, attached hereto.**\n\nThe following provisions of Fed. R. Civ. P. 45, made applicable in bankruptcy cases by Fed. R. Bankr. P. 9016, are attached – Rule 45(c), relating to the place of compliance; Rule 45(d), relating to your protection as a person subject to a subpoena; and Rule 45(e) and 45(g), relating to your duty to respond to this subpoena and the potential consequences of not doing so.\n\nDate: **March , 2023**\n\nCLERK OF COURT\n\nOR\n\n*Signature of Clerk or Deputy Clerk Attorney's signature*\n\nThe name, address, email address, and telephone number of the attorney representing Luc A. Despins, Chapter 11 Trustee, who issues or requests this subpoena, are:\n\n**Douglas S. Skalka, Esq.; Neubert, Pepe & Monteith, P.C.; 195 Church Street, New Haven, Connecticut 06510 dskalka@npmlaw.com; (203) 821-2000**\n\n**Notice to the person who issues or requests this subpoena**\n\nIf this subpoena commands the production of documents, electronically stored information, or tangible things, or the inspection of premises before trial, a notice and a copy of this subpoena must be served on each party before it is served on the person to whom it is directed. Fed. R. Civ. P. 45(a)(4).\n\nSoftware Copyright (c) 1996-2022 Best Case, LLC - www.bestcase.com Best Case Bankruptcy 1 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\n#### **PROOF OF SERVICE**\n\n**(This section should not be filed with the court unless required by Fed. R. Civ. P. 45.)**\n\nI received this subpoena for (*name of individual and title, if any*): on (*date*) .\n\nI served the subpoena by delivering a copy to the named person as follows:\n\non *(date)* ; or\n\nI returned the subpoena unexecuted because:\n\nUnless the subpoena was issued on behalf of the United States, or one of its officers or agents, I have also tendered to the witness the fees for one day's attendance, and the mileage allowed by law, in the amount of \\$ .\n\nMy fees are \\$ for travel and \\$ for services, for a total of \\$ .\n\nI declare under penalty of perjury that this information is true and correct.\n\nDate:\n\n*Server's signature*\n\n*Printed name and title*\n\n*Server's address*\n\nAdditional information concerning attempted service, etc.:\n\n#### **Federal Rule of Civil Procedure 45(c), (d), (e), and (g) (Effective 12/1/13) (made applicable in bankruptcy cases by Rule 9016, Federal Rules of Bankruptcy Procedure)**\n\n#### **(c) Place of compliance.**\n\n*(1) For a Trial, Hearing, or Deposition.* A subpoena may command a person to attend a trial, hearing, or deposition only as follows:\n\n(A) within 100 miles of where the person resides, is employed, or regularly transacts business in person; or\n\n(B) within the state where the person resides, is employed, or regularly transacts business in person, if the person\n\n(i) is a party or a party's officer; or\n\n(ii) is commanded to attend a trial and would not incur substantial expense.\n\n*(2) For Other Discovery.* A subpoena may command:\n\n(A) production of documents, or electronically stored information, or things at a place within 100 miles of where the person resides, is employed, or regularly transacts business in person; and\n\n(B) inspection of premises, at the premises to be inspected.\n\n#### **(d) Protecting a Person Subject to a Subpoena; Enforcement.**\n\n*(1) Avoiding Undue Burden or Expense; Sanctions.* A party or attorney responsible for issuing and serving a subpoena must take reasonable steps to avoid imposing undue burden or expense on a person subject to the subpoena. The court for the district where compliance is required must enforce this duty and impose an appropriate sanction which may include lost earnings and reasonable attorney's fees — on a party or attorney who fails to comply.\n\n#### *(2) Command to Produce Materials or Permit Inspection.*\n\n*(A) Appearance Not Required.* A person commanded to produce documents, electronically stored information, or tangible things, or to permit the inspection of premises, need not appear in person at the place of production or inspection unless also commanded to appear for a deposition, hearing, or trial.\n\n*(B) Objections.* A person commanded to produce documents or tangible things or to permit inspection may serve on the party or attorney designated in the subpoena a written objection to inspecting, copying, testing or sampling any or all of the materials or to inspecting the premises — or to producing electronically stored information in the form or forms requested. The objection must be served before the earlier of the time specified for compliance or 14 days after the subpoena is served. If an objection is made, the following rules apply:\n\n(i) At any time, on notice to the commanded person, the serving party may move the court for the district where compliance is required for an order compelling production or inspection.\n\n(ii) These acts may be required only as directed in the order, and the order must protect a person who is neither a party nor a party's officer from significant expense resulting from compliance.\n\n#### *(3) Quashing or Modifying a Subpoena.*\n\n*(A) When Required.* On timely motion, the court for the district where compliance is required must quash or modify a subpoena that:\n\n(i) fails to allow a reasonable time to comply;\n\n(ii) requires a person to comply beyond the geographical limits specified in Rule 45(c);\n\n(iii) requires disclosure of privileged or other protected matter, if no exception or waiver applies; or\n\n(iv) subjects a person to undue burden.\n\n*(B) When Permitted.* To protect a person subject to or affected by a subpoena, the court for the district where compliance is required may, on motion, quash or modify the subpoena if it requires:\n\n(i) disclosing a trade secret or other confidential research, development, or commercial information; or\n\n(ii) disclosing an unretained expert's opinion or information that does not describe specific occurrences in dispute and results from the expert's study that was not requested by a party.\n\n(C) *Specifying Conditions as an Alternative.* In the circumstances described in Rule 45(d)(3)(B), the court may, instead of quashing or modifying a subpoena, order appearance or production under specified conditions if the serving party:\n\n(i) shows a substantial need for the testimony or material that cannot be otherwise met without undue hardship; and\n\n(ii) ensures that the subpoenaed person will be reasonably compensated.\n\n#### **(e) Duties in Responding to a Subpoena.**\n\n*(1) Producing Documents or Electronically Stored Information.* These procedures apply to producing documents or electronically stored information:\n\n*(A) Documents.* A person responding to a subpoena to produce documents must produce them as they are kept in the ordinary course of business or must organize and label them to correspond to the categories in the demand.\n\n*(B) Form for Producing Electronically Stored Information Not Specified.* If a subpoena does not specify a form for producing electronically stored information, the person responding must produce it in a form or forms in which it is ordinarily maintained or in a reasonably usable form or forms.\n\n*(C) Electronically Stored Information Produced in Only One Form.* The person responding need not produce the same electronically stored information in more than one form.\n\n*(D) Inaccessible Electronically Stored Information.* The person responding need not provide discovery of electronically stored information from sources that the person identifies as not reasonably accessible because of undue burden or cost. On motion to compel discovery or for a protective order, the person responding must show that the information is not reasonably accessible because of undue burden or cost. If that showing is made, the court may nonetheless order discovery from such sources if the requesting party shows good cause, considering the limitations of Rule 26(b)(2)(C). The court may specify conditions for the discovery.\n\n#### *(2) Claiming Privilege or Protection.*\n\n*(A) Information Withheld.* A person withholding subpoenaed information under a claim that it is privileged or subject to protection as trial-preparation material must: (i) expressly make the claim; and\n\n(ii) describe the nature of the withheld documents, communications, or tangible things in a manner that, without revealing information itself privileged or protected, will enable the parties to assess the claim.\n\n*(B) Information Produced.* If information produced in response to a subpoena is subject to a claim of privilege or of protection as trial-preparation material, the person making the claim may notify any party that received the information of the claim and the basis for it. After being notified, a party must promptly return, sequester, or destroy the specified information and any copies it has; must not use or disclose the information until the claim is resolved; must take reasonable steps to retrieve the information if the party disclosed it before being notified; and may promptly present the information under seal to the court for the district where compliance is required for a determination of the claim. The person who produced the information must preserve the information until the claim is resolved.\n\n**(g) Contempt.** The court for the district where compliance is required – and also, after a motion is transferred, the issuing court – may hold in contempt a person who, having been served, fails without adequate excuse to obey the subpoena or an order related to it.\n\nFor access to subpoena materials, see Fed.R.Civ.P.45(a) Committee Note (2013)\n\n…\n\n## **Requests for Production of Documents**\n\n## **I. INSTRUCTIONS**\n\n1. Unless otherwise indicated, the requests for documents set forth below, (the \"Requests,\" and each, a \"Request\"), must be responded to separately and specifically. Each Request shall be answered fully unless it is in good faith objected to, in which event the reason for Your objection shall be stated in detail, as set forth below. If an objection pertains only to a portion of a Request, or a word, phrase or clause contained within it, You are required to state Your objection to that portion only and to respond to the remainder of the Requests.\n\n2. Electronically stored information must be produced in accordance with the\n\nfollowing instructions:\n\n- a. Images. Black and white images must be 300 DPI Group IV single-page TIFF files. Color images must be produced in JPEG format. File names cannot contain embedded spaces or special characters (including the comma). Folder names cannot contain embedded spaces or special characters (including the comma). All TIFF image files must have a unique file name, i.e. Bates number. Images must be endorsed with sequential Bates numbers in the lower right corner of each image. The number of TIFF files per folder should not exceed 1000 files. Excel spreadsheets should have a placeholder image named by the Bates number of the file.\n- b. Image Load File\n\t- a. Concordance® Data File. The data file (.DAT) contains all of the fielded information that will be loaded into the Concordance® database. The first line of the .DAT file must be a header row identifying the field names. The .DAT file must use the following Concordance® default delimiters: Comma ASCII character (020) Quote þ ASCII character (254). Date fields should be provided in the format: mm/dd/yyyy. Date and time fields must be two separate fields. If documents includes imaged emails and attachments, the attachment fields must be included to preserve the parent/child relationship between an email and its attachments. An OCRPATH field must be included to provide the file path and name of the extracted text file on the produced storage media. The text file must be named after the FIRSTBATES. Do not include the text in the .DAT file. For Documents with native files, a LINK field must be included to provide the file path and\n\nname of the native file. The native file must be named after the FIRSTBATES.\n\n- b. Concordance Image® OR Opticon Cross-Reference File. The image crossreference file (.LOG or .OPT) links the images to the database records. It should be a comma-delimited file consisting of seven fields per line with a line in the cross-reference file for every image in the database with the following format: ImageID,VolumeLabel,ImageFilePath,DocumentBreak,FolderBreak,Box Break,PageCoun.\n- c. Document Text. Text must be produced as separate text files, not as fields within the .DAT file. The full path to the text file (OCRPATH) should be included in the .DAT file. It is recommended document level ANSI text files, named per the FIRSTBATES/Image Key. Extracted text files must be in a separate folder, and the number of text files per folder should not exceed 1,000 files. There should be no special characters (including commas in the folder names). Text files must be provided on a document level.\n- d. Native Production for Certain File Types. File types that reasonably require viewing in their native format for a full understanding of their content and meaning must be produced in native format. These include, but are not limited to, spreadsheets, spreadsheet-like files (Microsoft Excel, comma separated values, tab separated values, etc.), Microsoft PowerPoint or other special presentation files, database files, and audio/visual files. Provide an image of a Bates numbered slip sheet indicating the presence of a native file, and include the path to the native as a field in the .dat file. Name the produced native file with the Bates number corresponding to the slip sheet for the file. Group native files within incrementally named \"NATIVE\" directories, separate from images directories.\n- e. De-duplication. Produce a single copy of each electronic document for which exact duplicates exist. For email messages, consolidate duplicates based on MD5 hash generated from the BCC, Body, CC, From, IntMsgID, To, and Attach properties. For email attachments and standalone electronic files, consolidate duplicates based on MD5 hash of the entire file.\n- f. Metadata. Produce extracted metadata for each document in the form of a Concordance compliant load file (.dat). The first line of the .DAT file must be a header row identifying the field names. The .DAT file must use the following Concordance default delimiters: Comma , ASCII character (020) Quote þ ASCII character (254)\n\nDate fields should be provided in the format: mm/dd/yyyy. Date and time fields must be two separate fields. Required metadata listed below:\n\n# Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 1031 of 1063\n\n| Field Name   | Sample Data               | Description                                                 |\n|--------------|---------------------------|-------------------------------------------------------------|\n| FIRSTBATES   | EDC0000001                | First Bates number of native file document/email            |\n| LASTBATES    | EDC0000001                | Last Bates number of native file document/email             |\n|              |                           | **The LASTBATES field should be populated                   |\n|              |                           | for single page                                             |\n|              |                           |                                                             |\n| ATTACHRANGE  | EDC0000001<br>-           | Bates number of the first page of the parent                |\n|              | EDC0000015                | document to the Bates number of the last page of            |\n|              |                           | the last attachment \"child\" document                        |\n| BEGATTACH    | EDC0000001                | First Bates number of attachment range                      |\n| ENDATTACH    | EDC0000015                | Last Bates number of attachment range                       |\n| CUSTODIAN    | Smith, John               | Email: Mailbox where the email resided                      |\n|              |                           | Native: Name of the individual or department                |\n|              |                           | from whose files the document<br>originated                 |\n| FROM         | John Smith                | Email: Sender                                               |\n|              |                           | Native: Author(s) of document                               |\n|              |                           | **semi-colon should be used to separate                     |\n|              |                           | multiple entries                                            |\n| TO           | Coffman, Janice; LeeW     | Recipient(s)                                                |\n|              | [mailto:LeeW@MSN.com]     | **semi-colon should be used to separate multiple            |\n|              |                           | entries                                                     |\n| CC           | Frank Thompson [mailto:   | Carbon copy recipient(s)                                    |\n|              | frank_Thompson@cdt.com]   | **semi-colon should be used to separate                     |\n|              |                           | multiple entries                                            |\n| BCC          | John Cain                 | Blind carbon copy recipient(s)                              |\n|              |                           | **semi-colon should be used to separate                     |\n|              |                           | multiple entries                                            |\n| SUBJECT      | Board Meeting Minutes     | Email: Subject line of the email Native: Title              |\n|              |                           | of document (if available)                                  |\n| FILE_NAME    | BoardMeetingMinutes.docx  | Native: Name of the original native file,                   |\n|              |                           | including extension                                         |\n| DATE_SENT    | 10/12/2010                | Email: Date the email was sent                              |\n|              |                           | Native: (empty)                                             |\n| TIME_SENT/   | 07:05 PM GMT              | Email: Time the email was sent/ Time zone in                |\n| TIME_ZONE    |                           | which the emails were standardized                          |\n| TIME_ZONE    | GMT                       | The<br>time<br>zone<br>in<br>which<br>the<br>emails<br>were |\n|              |                           | standardized during conversion.                             |\n| LINK         | >EDC0000001.msg | Hyperlink to the email or native file document              |\n|              |                           | **The linked file must be named per the                     |\n|              |                           | FIRSTBATES number                                           |\n| FILE_EXTEN   | MSG                       | The file type extension                                     |\n|              |                           | representing                                                |\n|              |                           | the Email or                                                |\n| AUTHOR       | John Smith                | Email: (empty)                                              |\n|              |                           | Native: Author of the document                              |\n| DATE_CREATED | 10/10/2010                | Email: (empty)                                              |\n|              |                           | Native: Date the document was created                       |\n|              |                           |                                                             |\n\n# Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 1032 of 1063\n\n| TIME_CREATED | 10:25 AM                  | Email: (empty)                                  |\n|--------------|---------------------------|-------------------------------------------------|\n|              |                           | Native: Time the document was created           |\n|              |                           | **This data must be a separate field and cannot |\n|              |                           | be combined with the DATE_CREATED field         |\n| DATE_MOD     | 10/12/2010                | Email: (empty)                                  |\n|              |                           | Native: Date the document was last modified     |\n| TIME_MOD     | 07:00 PM                  | Email: (empty)                                  |\n|              |                           | Native: Time the document was last modified     |\n|              |                           | **This data must be a separate field and cannot |\n|              |                           | be combined with the DATE_MOD field             |\n| DATE_ACCESSD | 10/12/2010                | Email: (empty)                                  |\n|              |                           | Native: Date the document was last accessed     |\n| TIME_ACCESSD | 07:00 PM                  | Email: (empty)                                  |\n|              |                           | Native: Time the document was last accessed     |\n|              |                           | **This data must be a separate field and cannot |\n|              |                           | be combined with the DATE_ACCESSD field         |\n| FILE_SIZE    | 5,952                     | Size of native file document/email in KB        |\n| PGCOUNT      | 1                         | Number of pages in native file document/email   |\n| PATH         |   | Email: (empty)                                  |\n|              | Agenda.doc                | Native: Path where native file document was     |\n|              |                           | stored including original file name.            |\n| INTFILEPATH  | Personal Folders\\Deleted  | Email: original location of email including     |\n|              | Items\\Board Meeting       | original file name.                             |\n|              | Minutes.msg               | Native: (empty)                                 |\n| INTMSGID     | <000805c2c71b\\$75977050\\$ | Email: Unique Message ID Native: (empty)        |\n|              | cb8306d1@MSN>             |                                                 |\n| MD5HASH      | d131dd02c5e6eec4693d9a0   | MD5 Hash value of the document.                 |\n|              | 698aff95c                 |                                                 |\n|              | 2fcab58712467eab4004583e  |                                                 |\n|              | b8fb7f89                  |                                                 |\n| OCRPATH      | TEXT/001/EDC0000001.txt   | Path to extracted text of the native file       |\n\n3. Each Request operates and should be construed independently and, unless otherwise indicated, no Request limits the scope of any other Request.\n\n4. All Documents are to be produced as kept in the usual course of business or are to be organized and labeled to correspond with the categories in these Requests.\n\n5. Each Request contained herein extends to all Documents: (a) in Your possession, custody, or control; or (b) in the possession, custody, or control of anyone acting on Your behalf,\n\n#### Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 1033 of 1063\n\nincluding Your counsel or other representatives and advisors. Each Document shall be produced in its entirety.\n\n6. If You are requested to produce a Document that is no longer in Your possession, custody, or control, then Your response must (a) describe in detail the nature of the document and its contents; (b) identify the person(s) who prepared or authored the Document (and, if applicable, the Person(s) to whom the Document was sent); (c) identify the date on which the document was prepared or created; (d) state whether such Document (i) is missing or lost, (ii) has been destroyed, (iii) has been transferred, voluntarily or involuntarily, to others, or (iv) was otherwise disposed of; (e) state the reason for, and the facts and circumstances surrounding, such disposition; (f) identify the Persons who authorized such disposition; (g) identify the date or approximate date of such disposition; (h)state when the Document was most recently in Your possession, custody or control; and (i) identify the Person, if any, presently in possession, custody, or control of such Document.\n\n7. If You are requested to produce a Document that has been destroyed, then Your response must state, in addition to the information required by the preceding Instruction: (a) the reason for the Document's destruction; (b) the identity of the Person who destroyed the Document; and (c) the identity of the Person who directed that the Document be destroyed.\n\n8. If You claim that a requested Document is privileged or attorney work-product, then Your response must: (a) state (i) a description of the Document adequate to support Your contention that the Document is privileged, (ii) the title of the Document, (iii) the date of the Document, (iv) the author of the Document, (v) the addressee of the Document, (vi) the identity of each Person who received or saw the original or any draft, copy, or reproduction of the Document, (vii) whether the Document itself, or any information contained or referred to in the Document is in the possession, custody, or control of any other Persons, and if so, the identity of\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 1034 of 1063\n\nsuch Persons, as well as a statement addressing how the information came into their possession, (viii) the claim of privilege under which the Document is withheld, and (ix) all of the circumstances upon which You will rely to support such claim of privilege; and (b) produce a privilege log containing all of the information requested in Part (a) of this Instruction for each Document withheld on the basis of a claim of privilege in accordance with D. Conn. L. Civ. R. 26(e).\n\n9. If a portion of an otherwise responsive Document contains information subject to a claim of privilege, only that portion of the Document subject to the claim of privilege shall be deleted or redacted from the Document following the instructions above, and the rest shall be produced.\n\n10. The Requests are continuing in nature. You are hereby instructed to (a) supplement or correct any responses later learned to be incomplete or incorrect immediately upon learning that a prior response was incomplete or incorrect; and (b) produce any additional Documents that are called for under the\n\n11. If a Document is in a language other than English, You should provide that Document. If a Document is in a language other than English, and an English translation exists, You should provide both Documents.\n\n12. All references to Entities includes all affiliates thereof.\n\n13. All references to individual names include all alternative names, aliased, or nicknames.\n\n14. Unless otherwise expressly indicated, the period of time covered by the Document Requests is the period from February 5, 2012 to the date responses to the Document Requests are due.\n\n### Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 1035 of 1063\n\n#### **II. RULES OF CONSTRUCTION**\n\n15. The use of (a) any singular noun shall be construed to include the plural, and vice versa, and (b) a verb in any tense shall be construed as the use of the verb in all othertenses.\n\n16. The terms (a) \"and\" and \"or\" shall be construed either conjunctively or disjunctively as necessary to bring within the scope of any request all responses that might otherwise be construed to be outside of its scope, and (b) \"each\" and \"any\" shall be deemed to include and encompass the words \"every\" and \"all.\"\n\n## **III. DEFINITIONS**\n\nThe definitions supplied by D. Conn. L. Civ. R. 26(c) and the rules of construction supplied by D. Conn. L. Civ. R. 26(d), as incorporated by D. Conn. Bankr. L.R. 2004-1(a), shall apply to the Document Requests. In addition, the following terms used in these Document Requests shall have the following meanings:\n\n1. \"You\" or \"Your\" or \"Yourself\" means and refers to Joyord Sportswear Limited, together with all of its affiliates, divisions, agencies, instrumentalities, departments, offices, partners, officers, directors, agents, attorneys, representatives, employees, and/or anyone acting on its behalf.\n\n2. \"Debtor\" means Ho Wan Kwok (a/k/a Miles Kwok, Miles Guo, Guo Wengui, Guo Haoyun, 郭文贵, or any other alias), together with his employees, agents, counsel, advisors, or anyone acting on his behalf.\n\n3. \"Debtor's Son\" means Qiang Guo (a/k/a Mileson Kwok, 郭强, or any other alias), together with his employees, agents, counsel, advisors, or anyone acting on his behalf.\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 1036 of 1063\n\n4. \"Debtor's Daughter\" means Mei Guo (a/k/a Mei Gui, 郭美, or any other alias), together with her employees, agents, counsel, advisors, or anyone acting on her behalf.\n\n5. \"Debtor's Purported Wife\" means Hing Chi Ngok (a/k/a Hing Chi Ng, Yue Qingzhi, 岳庆芝, or any other alias), together with her employees, agents, counsel, advisors, or anyone acting on her behalf.\n\n6. \"Debtor's Family\" means, collectively, the Debtor, the Debtor's Son, the Debtor's Daughter, and the Debtor's Purported Wife, and any other familial relation to the Debtor.\n\n7. \"Associated Individuals\" means, individually and collectively, all individuals that (1) hold, control, have custody over, or discretion over assets owned, controlled, or enjoyed by the Debtor or the Debtor's Family; or (2) have been employees, directors, or otherwise are affiliated with one or more Associated Entities, together with the respective employees, agents, counsel, advisors, or anyone acting on behalf of any of the foregoing. Such Associated Individuals shall include, but are not limited to: Daniel Podhaskie, Jason Miller, Steve Bannon, Karin Maistrello, Melissa Francis, Anthony DiBattista, William Gertz, Arethusa Forsyth, Glenn Mellor, Jennifer Mercurio, Eduardo Eurnekian, Wencong Wang, Han Chunguang (a/k/a 韩春光), Qu Guojiao (a/k/a Qu Guo Jiao, 屈国姣), Guo Lijie (a/k/a 郭丽杰), Zhang Wei (a/k/a 张伟\\*), Lihong Wei Lafrenz (a/k/a Sara Wei, 魏丽红), Hao Haidong (a/k/a 郝海东), Ross Heinemeyer, Max Krasner, Kyle Bass, Melissa Mendez, Ya Li (a/k/a 李娅), Dinggang Wang (a/k/a 王定刚), An Hong (a/k/a 安红), Yvette Wang (a/k/a Yanping Wang, Yan Ping Wang, 王雁平), Fiona Yu, Je Kin Ming (a/k/a William Je, Yu Jianming, 余建明), Yaz Qingua, and Lao Jiang (a/k/a Jiang Yunfu, Jiang Yunfu Be, 姜云浮).\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 1037 of 1063\n\n8. \"Associated Entities\" means, individually and collectively, all organizations or Entities of any type that (1) have been owned, controlled, or invested in by the Debtor or the Debtor's Family; or (2) have an interest, whether directly or indirectly, in any assets owned, controlled, or enjoyed by the Debtor or the Debtor's Family, together with the respective employees, agents, counsel, advisors, or anyone acting on behalf of any of the foregoing. Such Associated Entities shall include, but are not limited to: 7 Nod Hill LLC, AAGV Limited, ACA Investment Management Limited, ACA Capital Group Limited, Ace Decade Holdings Limited, AI Group Holdings Inc., Alfa Global Ventures Limited, Alfonso Global Limited, Allied Capital Global Limited, Alpine Fiduciaries SA, Anton Development Limited, Assets Sino Limited, Auspicious Coast Limited, Beijing Pangu Investment Co., Beijing Pangu Investment Co. Ltd., Beijing Pangu Investment Inc., Beijing Zenith Holdings Company Limited, Booming Sail New York LLC, Bravo Luck Limited, BSA Strategic Fund I, China Golden Spring (Hong Kong) Limited, Chuang Xin Limited, Crane Advisory Group LLC, Creative Apex Investments Limited, Crystal Breeze Investments Limited, Dawn State Limited, Eastern Profit Corporation Limited, Elite Well Global Limited, Empire Growth Holdings, Freedom Media Ventures Ltd., G Club Operations LLC, G Fashion LLC, G News LLC, GETTR USA, Genever Holdings Corporation, Genever Holdings LLC, Gfashion Media Group Inc., GFNY, Inc., Globalist International Limited, GNews Media Group Inc., Golden Spring (New York) Ltd., Greenwich Land LLC, Guo Media, GTV Media Group, Inc., Hamilton Capital Holdings Inc., HCHK Property Management, Inc., HCHK Technologies, Inc., Head Win Group Limited, Henan Yuda, Himalaya Embassy, Himalaya Exchange, Himalaya Federal Reserve, Himalaya Investment LLC, Himalaya International, Himalaya New World Inc., Himalaya Supervisory Organization, Himalaya Ventures LLC, HK International Funds Investments (USA) Limited LLC, Hong Kong International Funds\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 1038 of 1063\n\nInvestments Limited, Hudson Diamond Holding, Infinite Increase Limited, Infinitum Developments Limited, Infinity Treasury Management Inc., Insight Phoenix Fund, Lamp Capital LLC, Leading Shine Limited, Leading Shine NY Limited, Lexington Property and Staffing, Long Gate Limited, Maywind Trading LLC, MOS Himalaya LLC, Next Tycoon Investments Limited, New Federal State of China (a/k/a NFSC), Noble Fame Global Limited, Rosy Acme Ventures Limited, Rule of Law Foundation III, Inc., Rule of Law Foundation IV, Inc., Rule of Law Fund, Rule of Law Society, Rule of Law Society IV, Inc., G-Translators PTY LTD, Saraca Media Group, Inc., Shiny Ace Ltd., Shiny Times Holdings Ltd., Spirit Charter Investment Limited, Stevenson, Wong & Co., Voice of Guo Media, Inc., Well Origin Ltd., World Century Limited, Worldwide Opportunity Holdings Limited, Whitecroft Shore Limited, and ZIBA Limited.\n\n9. \"Including\" or any variant thereof means \"including without limitation.\"\n\n10. \"And\" and \"or\" mean \"and/or,\" and shall be construed both conjunctively as well as disjunctively in order to maximize their scope.\n\n11. \"Any\" and \"all\" and \"each\" mean \"each and every.\"\n\n12. \"Each\" and \"every\" mean \"each and every.\"\n\n13. \"Third Party\" means a Person or Entity other than Yourself.\n\n14. \"Transfer\" shall have the meaning given to it by section 101(54) of the Bankruptcy Code.\n\n15. \"Document\" means any information or thing within the scope of Fed. R. Civ. P. 34, and includes, without limitation, each and every written, recorded, or graphic matter of any kind, type, nature, or description that is or has been in Your Possession, Custody or Control, including all printed and electronic copies of electronic mail, computer files maintained in\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 1039 of 1063\n\nelectronic form, electronic communication, text message, social media post, tweet, meta-data, correspondence, memoranda, tapes, stenographic or handwritten notes, written forms of any kind, charts, blueprints, drawings, sketches, graphs, plans, articles, specifications, diaries, letters, telegrams, photographs, minutes, contracts, agreements, surveys, computer printouts, data compilations of any kind, telexes, facsimiles, voice messages, invoices, order forms, checks, drafts, statements, credit memos, reports, position reports, summaries, indices, books, ledgers, notebooks, schedules, transparencies, recordings, catalogs, advertisements, promotional materials, films, video tapes, audio tapes, CDs, computer disks, brochures, pamphlets, punchcards, time-slips, Tweets, social media posts, or any written or recorded materials of any other kind, and all meta-data thereof, however stored (whether in tangible or electronic form), recorded, produced, or reproduced, and also including but not limited to, drafts or copies of any of the foregoing that contain any notes, comments, or markings of any kind not found on the original documents or that are otherwise not identical to the original documents.\n\n16. \"Person(s)\" means an individual, corporation, proprietorship, partnership, association, or any other Entity. \"Person\" also includes any agent, representatives, or expert, including but not limiting to, attorneys or financial advisors.\n\n17. \"Entity\" means any natural Person, corporation, partnership, subsidiary, sole proprietorship, firm, board, joint venture, association, agency, authority, commission or other business entity or juristic Person, as well as any affiliate, agent, parent including but not limited to legal counsel, financial advisors, or any other representative.\n\n18. \"Regarding\" means concerning, describing, comprising, referring to, related to, supporting, favoring, opposing, bolstering, detracting from, located in, considered in connection with, bearing on, evidencing, indicating, reporting on, recording, alluding to, responding to,\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 1040 of 1063\n\nconnected with, commenting on, in respect of, about, in relation to, discussing, showing, describing, reflecting, analyzing constituting, and being.\n\n19. \"Relating to,\" \"relate(s) to\" or \"related to,\" when referring to any given subject matter, means, without limitation, any document that constitutes, comprises, involves, contains, embodies, reflects, identifies, states, refers directly or indirectly to, or is in any way relevant to the particular subject matter identified.\n\n20. \"Communication(s)\" means, in the broadest possible sense, and without limitation, any transmittal of information or knowledge (in the form of facts, ideas, inquiries, or otherwise). Communication(s) further refers to all conversations, agreements, inquiries, or replies, whether in person, by telephone, in writing, or by means of electronic transmittal devices, and includes, but is not limited to, all correspondence, emails, recordings, transmittal slips, memoranda, telephone communications, voice messages, telegrams, telefaxes, telecopies, telexes, instant messages, chats, text messages, telephonic notes, or notes transmitted internally or with third parties.\n\n21. \"Asset(s)\" means any item that can be used to produce positive economic value, including but not limited to any resource with economic value that is owned, controlled or is for the benefit of an entity, that is expected to provide a future benefit, including but not limited to, all real and personal property, intangible property, investments, rights to invest or to future revenue, cash, bank accounts, commodities, securities, claims, total or partial control of an entity, and prospective economic opportunities\n\n22. \"Transfer\" shall have the meaning given to it by section 101(54) of the Bankruptcy Code.\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 1041 of 1063\n\n#### **IV. DOCUMENTS TO BE PRODUCED**\n\n1. All Documents regarding any income or Asset of the Debtor, the Debtor's estate, or an Associated Entity.\n\n2. All Documents related to the Debtor's financial condition and obligations to his creditors, including without limitation all Documents related to any effort to avoid paying such obligations and All Documents related to this or any other actual or potential bankruptcy or similar insolvency proceeding.\n\n3. All Documents regarding any balance sheet, bank statement, account statement, financial statement, statement of account, wire transfer instructions and/or confirmation, proof of funds, certificate of deposit, certificate of holdings, investment portfolio summary, or similar document relating to the Debtor, the Debtor's Estate, the Debtor's Family, an Associated Entity, or an Associated Individual, including without limitation all Documents sufficient to show all Transfers to any of the foregoing.\n\n4. All Documents regarding any investment, business dealing or transactions made by, with, or on behalf of the Debtor.\n\n5. All Communications with the Debtor, and Documents related to Communications with the Debtor, related to the operation, management, or decision-making of any Entity, including without limitation the Associated Entities.\n\n6. All Documents regarding any Transfer, investment, or other transaction or business dealing made to, by, or with the Debtor, the Debtor's Family, or an Associated Entity.\n\n7. All Documents regarding any property ever occupied or used by the Debtor, including without limitation the *Lady May*; the Sherry Netherland Hotel / Condominium; the\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 1042 of 1063\n\nresidential property located in Greenwich, Connecticut at 373 Taconic Rd.; the residential property located in Greenwich, Connecticut at 33 Ferncliff Rd.; and the residential property located in Wilton, Connecticut at 354 Nod Hill Rd.\n\n8. All Documents related to any aircraft owned, controlled, or used by the Debtor, including without limitation the aircraft bearing tail number T7-GQM and any other aircraft registered in San Marino, including without limitation copies of all registration documents and flight manifests showing flights taken by such aircraft and the individuals onboard such flights.\n\n9. All Documents regarding any gifts, benefits or loans, to, from or on behalf of the Debtor, the Debtor's Estate, the Debtor's Family, or the Associated Entities, including without limitation Documents sufficient to show the amounts of such gifts, benefits, or loans; the purposes for which such gifts, benefits, or loans were used; when the gifts, benefits, or loans were provided; and the terms of any loans, all representations and warranties made in connection with any loans, the interest rate on any loans, and all evidence of payments of any loans.\n\n10. All Documents concerning any trust or similar instrument set up by, on behalf of, or for the benefit of the Debtor, the Debtor's Estate, the Debtor's Family, or an Associated Entity, including without limitation Documents sufficient to show when the trust(s) was created, by whom it was created, for whose benefit it was created, and the corpus of the trust.\n\n11. All Documents related to any obligation, claim, liability, or debt associated with any legal dispute involving the Debtor, including but not limited to those relating to any litigation before any local, state, federal, or international body, whether an administrative body, court, panel, or alternative dispute resolution entity.\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 1043 of 1063\n\n12. All Documents and communications between any of your outside counsel or other advisors and the Debtor.\n\n13. Documents sufficient to show all of Your Assets and sources of income or funding.\n\n14. For all Assets identified in response to Request 14 having a value of more than \\$50,000, all (i) Documents related to Your acquisition of such Asset and (ii) Communications with the Debtor or the Debtor's Family regarding such Asset.\n\n15. Copies of Your tax returns.\n\n16. Documents sufficient to show all bank accounts and investment accounts within Your possession or control, including the balances of and transfers to and from each such account.\n\n17. All Documents regarding any credit cards used by You, including without limitation monthly statements or other Documents sufficient to show all purchases related thereto for the benefit of the Debtor or an Associated Entity.\n\n18. All corporate governance and organizational Documents, including without limitation by-laws and certificates of incorporation and other Documents sufficient to show Your corporate structure, names of officers and directors, business purpose, and relationship to the Debtor or to any member of the Debtor's Family.\n\n19. All Documents related to any pledge(s) of Your Assets to any other Entity.\n\nCase 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 1044 of 1063\n\n# Exhibit C-57\n\n#### B2540 (Form 2540 – Subpoena for Rule 2004 Examination) (12/15) Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 1045 of\n\nUNITED STATES BANKRUPTCY COURT 1063\n\n**District of Connecticut**\n\nIn re HO WAN KWOK, *et al*.,\n\n<sup>1</sup> Case No. 22-50073 (JAM)\n\nDebtor Chapter 11\n\n(Jointly Administered)\n\n## **SUBPOENA FOR RULE 2004 EXAMINATION**\n\nTo: **Brown Harris Stevens**\n\n(*Name of person to whom the subpoena is directed*)\n\n*Testimony:* **YOU ARE COMMANDED** to appear at the time, date, and place set forth below to testify at an examination under Rule 2004, Federal Rules of Bankruptcy Procedure. A copy of the court order authorizing the examination is attached.\n\n| PLACE                    | DATE AND TIME |\n|--------------------------|---------------|\n| Paul Hastings LLP        |               |\n| 200 Park Avenue          | [TBD]         |\n| New York, New York 10166 |               |\n|                          |               |\n\nThe examination will be recorded by this method: **Court reporter/stenographer**\n\n*Production:* You, or your representatives, must also bring with you to the examination the following documents, electronically stored information, or objects, and must permit inspection, copying, testing, or sampling of the material:\n\n#### **See Requests for Production of Documents, attached hereto.**\n\nThe following provisions of Fed. R. Civ. P. 45, made applicable in bankruptcy cases by Fed. R. Bankr. P. 9016, are attached – Rule 45(c), relating to the place of compliance; Rule 45(d), relating to your protection as a person subject to a subpoena; and Rule 45(e) and 45(g), relating to your duty to respond to this subpoena and the potential consequences of not doing so.\n\nDate: **March , 2023**\n\nCLERK OF COURT\n\nOR\n\n*Signature of Clerk or Deputy Clerk Attorney's signature*\n\nThe name, address, email address, and telephone number of the attorney representing Luc A. Despins, Chapter 11 Trustee, who issues or requests this subpoena, are:\n\n**Douglas S. Skalka, Esq.; Neubert, Pepe & Monteith, P.C.; 195 Church Street, New Haven, Connecticut 06510 dskalka@npmlaw.com; (203) 821-2000**\n\n**Notice to the person who issues or requests this subpoena**\n\nIf this subpoena commands the production of documents, electronically stored information, or tangible things, or the inspection of premises before trial, a notice and a copy of this subpoena must be served on each party before it is served on the person to whom it is directed. Fed. R. Civ. P. 45(a)(4).\n\nSoftware Copyright (c) 1996-2022 Best Case, LLC - www.bestcase.com Best Case Bankruptcy 1 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\n#### **PROOF OF SERVICE**\n\n**(This section should not be filed with the court unless required by Fed. R. Civ. P. 45.)**\n\nI received this subpoena for (*name of individual and title, if any*): on (*date*) .\n\nI served the subpoena by delivering a copy to the named person as follows:\n\non *(date)* ; or\n\nI returned the subpoena unexecuted because:\n\nUnless the subpoena was issued on behalf of the United States, or one of its officers or agents, I have also tendered to the witness the fees for one day's attendance, and the mileage allowed by law, in the amount of \\$ .\n\nMy fees are \\$ for travel and \\$ for services, for a total of \\$ .\n\nI declare under penalty of perjury that this information is true and correct.\n\nDate:\n\n*Server's signature*\n\n*Printed name and title*\n\n*Server's address*\n\nAdditional information concerning attempted service, etc.:\n\n#### **Federal Rule of Civil Procedure 45(c), (d), (e), and (g) (Effective 12/1/13) (made applicable in bankruptcy cases by Rule 9016, Federal Rules of Bankruptcy Procedure)**\n\n#### **(c) Place of compliance.**\n\n*(1) For a Trial, Hearing, or Deposition.* A subpoena may command a person to attend a trial, hearing, or deposition only as follows:\n\n(A) within 100 miles of where the person resides, is employed, or regularly transacts business in person; or\n\n(B) within the state where the person resides, is employed, or regularly transacts business in person, if the person\n\n(i) is a party or a party's officer; or\n\n(ii) is commanded to attend a trial and would not incur substantial expense.\n\n*(2) For Other Discovery.* A subpoena may command:\n\n(A) production of documents, or electronically stored information, or things at a place within 100 miles of where the person resides, is employed, or regularly transacts business in person; and\n\n(B) inspection of premises, at the premises to be inspected.\n\n#### **(d) Protecting a Person Subject to a Subpoena; Enforcement.**\n\n*(1) Avoiding Undue Burden or Expense; Sanctions.* A party or attorney responsible for issuing and serving a subpoena must take reasonable steps to avoid imposing undue burden or expense on a person subject to the subpoena. The court for the district where compliance is required must enforce this duty and impose an appropriate sanction which may include lost earnings and reasonable attorney's fees — on a party or attorney who fails to comply.\n\n#### *(2) Command to Produce Materials or Permit Inspection.*\n\n*(A) Appearance Not Required.* A person commanded to produce documents, electronically stored information, or tangible things, or to permit the inspection of premises, need not appear in person at the place of production or inspection unless also commanded to appear for a deposition, hearing, or trial.\n\n*(B) Objections.* A person commanded to produce documents or tangible things or to permit inspection may serve on the party or attorney designated in the subpoena a written objection to inspecting, copying, testing or sampling any or all of the materials or to inspecting the premises — or to producing electronically stored information in the form or forms requested. The objection must be served before the earlier of the time specified for compliance or 14 days after the subpoena is served. If an objection is made, the following rules apply:\n\n(i) At any time, on notice to the commanded person, the serving party may move the court for the district where compliance is required for an order compelling production or inspection.\n\n(ii) These acts may be required only as directed in the order, and the order must protect a person who is neither a party nor a party's officer from significant expense resulting from compliance.\n\n#### *(3) Quashing or Modifying a Subpoena.*\n\n*(A) When Required.* On timely motion, the court for the district where compliance is required must quash or modify a subpoena that:\n\n(i) fails to allow a reasonable time to comply;\n\n(ii) requires a person to comply beyond the geographical limits specified in Rule 45(c);\n\n(iii) requires disclosure of privileged or other protected matter, if no exception or waiver applies; or\n\n(iv) subjects a person to undue burden.\n\n*(B) When Permitted.* To protect a person subject to or affected by a subpoena, the court for the district where compliance is required may, on motion, quash or modify the subpoena if it requires:\n\n(i) disclosing a trade secret or other confidential research, development, or commercial information; or\n\n(ii) disclosing an unretained expert's opinion or information that does not describe specific occurrences in dispute and results from the expert's study that was not requested by a party.\n\n(C) *Specifying Conditions as an Alternative.* In the circumstances described in Rule 45(d)(3)(B), the court may, instead of quashing or modifying a subpoena, order appearance or production under specified conditions if the serving party:\n\n(i) shows a substantial need for the testimony or material that cannot be otherwise met without undue hardship; and\n\n(ii) ensures that the subpoenaed person will be reasonably compensated.\n\n#### **(e) Duties in Responding to a Subpoena.**\n\n*(1) Producing Documents or Electronically Stored Information.* These procedures apply to producing documents or electronically stored information:\n\n*(A) Documents.* A person responding to a subpoena to produce documents must produce them as they are kept in the ordinary course of business or must organize and label them to correspond to the categories in the demand.\n\n*(B) Form for Producing Electronically Stored Information Not Specified.* If a subpoena does not specify a form for producing electronically stored information, the person responding must produce it in a form or forms in which it is ordinarily maintained or in a reasonably usable form or forms.\n\n*(C) Electronically Stored Information Produced in Only One Form.* The person responding need not produce the same electronically stored information in more than one form.\n\n*(D) Inaccessible Electronically Stored Information.* The person responding need not provide discovery of electronically stored information from sources that the person identifies as not reasonably accessible because of undue burden or cost. On motion to compel discovery or for a protective order, the person responding must show that the information is not reasonably accessible because of undue burden or cost. If that showing is made, the court may nonetheless order discovery from such sources if the requesting party shows good cause, considering the limitations of Rule 26(b)(2)(C). The court may specify conditions for the discovery.\n\n#### *(2) Claiming Privilege or Protection.*\n\n*(A) Information Withheld.* A person withholding subpoenaed information under a claim that it is privileged or subject to protection as trial-preparation material must: (i) expressly make the claim; and\n\n(ii) describe the nature of the withheld documents, communications, or tangible things in a manner that, without revealing information itself privileged or protected, will enable the parties to assess the claim.\n\n*(B) Information Produced.* If information produced in response to a subpoena is subject to a claim of privilege or of protection as trial-preparation material, the person making the claim may notify any party that received the information of the claim and the basis for it. After being notified, a party must promptly return, sequester, or destroy the specified information and any copies it has; must not use or disclose the information until the claim is resolved; must take reasonable steps to retrieve the information if the party disclosed it before being notified; and may promptly present the information under seal to the court for the district where compliance is required for a determination of the claim. The person who produced the information must preserve the information until the claim is resolved.\n\n**(g) Contempt.** The court for the district where compliance is required – and also, after a motion is transferred, the issuing court – may hold in contempt a person who, having been served, fails without adequate excuse to obey the subpoena or an order related to it.\n\nFor access to subpoena materials, see Fed.R.Civ.P.45(a) Committee Note (2013)\n\n…\n\n## **Request for Production of Documents**\n\n## **I. INSTRUCTIONS**\n\n1. Unless otherwise indicated, the requests for documents set forth below, (the \"Requests,\" and each, a \"Request\"), must be responded to separately and specifically. Each Request shall be answered fully unless it is in good faith objected to, in which event the reason for Your objection shall be stated in detail, as set forth below. If an objection pertains only to a portion of a Request, or a word, phrase or clause contained within it, You are required to state Your objection to that portion only and to respond to the remainder of the Requests.\n\n2. Electronically stored information must be produced in accordance with the\n\nfollowing instructions:\n\n- a. Images. Black and white images must be 300 DPI Group IV single-page TIFF files. Color images must be produced in JPEG format. File names cannot contain embedded spaces or special characters (including the comma). Folder names cannot contain embedded spaces or special characters (including the comma). All TIFF image files must have a unique file name, i.e. Bates number. Images must be endorsed with sequential Bates numbers in the lower right corner of each image. The number of TIFF files per folder should not exceed 1000 files. Excel spreadsheets should have a placeholder image named by the Bates number of the file.\n- b. Image Load File\n\t- a. Concordance® Data File. The data file (.DAT) contains all of the fielded information that will be loaded into the Concordance® database. The first line of the .DAT file must be a header row identifying the field names. The .DAT file must use the following Concordance® default delimiters: Comma ASCII character (020) Quote þ ASCII character (254). Date fields should be provided in the format: mm/dd/yyyy. Date and time fields must be two separate fields. If documents includes imaged emails and attachments, the attachment fields must be included to preserve the parent/child relationship between an email and its attachments. An OCRPATH field must be included to provide the file path and name of the extracted text file on the produced storage media. The text file must be named after the FIRSTBATES. Do not include the text in the .DAT file. For Documents with native files, a LINK field must be included to provide the file path and\n\nname of the native file. The native file must be named after the FIRSTBATES.\n\n- b. Concordance Image® OR Opticon Cross-Reference File. The image crossreference file (.LOG or .OPT) links the images to the database records. It should be a comma-delimited file consisting of seven fields per line with a line in the cross-reference file for every image in the database with the following format: ImageID,VolumeLabel,ImageFilePath,DocumentBreak,FolderBreak,Box Break,PageCoun.\n- c. Document Text. Text must be produced as separate text files, not as fields within the .DAT file. The full path to the text file (OCRPATH) should be included in the .DAT file. It is recommended document level ANSI text files, named per the FIRSTBATES/Image Key. Extracted text files must be in a separate folder, and the number of text files per folder should not exceed 1,000 files. There should be no special characters (including commas in the folder names). Text files must be provided on a document level.\n- d. Native Production for Certain File Types. File types that reasonably require viewing in their native format for a full understanding of their content and meaning must be produced in native format. These include, but are not limited to, spreadsheets, spreadsheet-like files (Microsoft Excel, comma separated values, tab separated values, etc.), Microsoft PowerPoint or other special presentation files, database files, and audio/visual files. Provide an image of a Bates numbered slip sheet indicating the presence of a native file, and include the path to the native as a field in the .dat file. Name the produced native file with the Bates number corresponding to the slip sheet for the file. Group native files within incrementally named \"NATIVE\" directories, separate from images directories.\n- e. De-duplication. Produce a single copy of each electronic document for which exact duplicates exist. For email messages, consolidate duplicates based on MD5 hash generated from the BCC, Body, CC, From, IntMsgID, To, and Attach properties. For email attachments and standalone electronic files, consolidate duplicates based on MD5 hash of the entire file.\n- f. Metadata. Produce extracted metadata for each document in the form of a Concordance compliant load file (.dat). The first line of the .DAT file must be a header row identifying the field names. The .DAT file must use the following Concordance default delimiters: Comma , ASCII character (020) Quote þ ASCII character (254)\n\nDate fields should be provided in the format: mm/dd/yyyy. Date and time fields must be two separate fields. Required metadata listed below:\n\n# Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 1050 of 1063\n\n| Field Name   | Sample Data               | Description                                                 |\n|--------------|---------------------------|-------------------------------------------------------------|\n| FIRSTBATES   | EDC0000001                | First Bates number of native file document/email            |\n| LASTBATES    | EDC0000001                | Last Bates number of native file document/email             |\n|              |                           | **The LASTBATES field should be populated                   |\n|              |                           | for single page                                             |\n| ATTACHRANGE  | EDC0000001<br>-           | Bates number of the first page of the parent                |\n|              | EDC0000015                | document to the Bates number of the last page of            |\n|              |                           | the last attachment \"child\" document                        |\n| BEGATTACH    | EDC0000001                | First Bates number of attachment range                      |\n|              |                           |                                                             |\n| ENDATTACH    | EDC0000015                | Last Bates number of attachment range                       |\n| CUSTODIAN    | Smith, John               | Email: Mailbox where the email resided                      |\n|              |                           | Native: Name of the individual or department                |\n|              |                           | from whose files the document<br>originated                 |\n| FROM         | John Smith                | Email: Sender                                               |\n|              |                           | Native: Author(s) of document                               |\n|              |                           | **semi-colon should be used to separate                     |\n|              |                           | multiple entries                                            |\n| TO           | Coffman, Janice; LeeW     | Recipient(s)                                                |\n|              | [mailto:LeeW@MSN.com]     | **semi-colon should be used to separate multiple            |\n|              |                           | entries                                                     |\n| CC           | Frank Thompson [mailto:   | Carbon copy recipient(s)                                    |\n|              | frank_Thompson@cdt.com]   | **semi-colon should be used to separate                     |\n|              |                           | multiple entries                                            |\n| BCC          | John Cain                 | Blind carbon copy recipient(s)                              |\n|              |                           | **semi-colon should be used to separate                     |\n|              |                           | multiple entries                                            |\n| SUBJECT      | Board Meeting Minutes     | Email: Subject line of the email Native: Title              |\n|              |                           | of document (if available)                                  |\n| FILE_NAME    | BoardMeetingMinutes.docx  | Native: Name of the original native file,                   |\n|              |                           | including extension                                         |\n| DATE_SENT    | 10/12/2010                | Email: Date the email was sent                              |\n|              |                           | Native: (empty)                                             |\n| TIME_SENT/   | 07:05 PM GMT              | Email: Time the email was sent/ Time zone in                |\n| TIME_ZONE    |                           | which the emails were standardized                          |\n| TIME_ZONE    | GMT                       | The<br>time<br>zone<br>in<br>which<br>the<br>emails<br>were |\n|              |                           | standardized during conversion.                             |\n| LINK         | >EDC0000001.msg | Hyperlink to the email or native file document              |\n|              |                           | **The linked file must be named per the                     |\n|              |                           | FIRSTBATES number                                           |\n| FILE_EXTEN   | MSG                       | The file type extension                                     |\n|              |                           | representing                                                |\n|              |                           | the Email or                                                |\n| AUTHOR       | John Smith                | Email: (empty)                                              |\n|              |                           | Native: Author of the document                              |\n| DATE_CREATED | 10/10/2010                | Email: (empty)                                              |\n|              |                           | Native: Date the document was created                       |\n|              |                           |                                                             |\n\n# Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 1051 of 1063\n\n| TIME_CREATED | 10:25 AM                  | Email: (empty)                                  |\n|--------------|---------------------------|-------------------------------------------------|\n|              |                           | Native: Time the document was created           |\n|              |                           | **This data must be a separate field and cannot |\n|              |                           | be combined with the DATE_CREATED field         |\n| DATE_MOD     | 10/12/2010                | Email: (empty)                                  |\n|              |                           | Native: Date the document was last modified     |\n| TIME_MOD     | 07:00 PM                  | Email: (empty)                                  |\n|              |                           | Native: Time the document was last modified     |\n|              |                           | **This data must be a separate field and cannot |\n|              |                           | be combined with the DATE_MOD field             |\n| DATE_ACCESSD | 10/12/2010                | Email: (empty)                                  |\n|              |                           | Native: Date the document was last accessed     |\n| TIME_ACCESSD | 07:00 PM                  | Email: (empty)                                  |\n|              |                           | Native: Time the document was last accessed     |\n|              |                           | **This data must be a separate field and cannot |\n|              |                           | be combined with the DATE_ACCESSD field         |\n| FILE_SIZE    | 5,952                     | Size of native file document/email in KB        |\n| PGCOUNT      | 1                         | Number of pages in native file document/email   |\n| PATH         |   | Email: (empty)                                  |\n|              | Agenda.doc                | Native: Path where native file document was     |\n|              |                           | stored including original file name.            |\n| INTFILEPATH  | Personal Folders\\Deleted  | Email: original location of email including     |\n|              | Items\\Board Meeting       | original file name.                             |\n|              | Minutes.msg               | Native: (empty)                                 |\n| INTMSGID     | <000805c2c71b\\$75977050\\$ | Email: Unique Message ID Native: (empty)        |\n|              | cb8306d1@MSN>             |                                                 |\n| MD5HASH      | d131dd02c5e6eec4693d9a0   | MD5 Hash value of the document.                 |\n|              | 698aff95c                 |                                                 |\n|              | 2fcab58712467eab4004583e  |                                                 |\n|              | b8fb7f89                  |                                                 |\n| OCRPATH      | TEXT/001/EDC0000001.txt   | Path to extracted text of the native file       |\n\n3. Each Request operates and should be construed independently and, unless otherwise indicated, no Request limits the scope of any other Request.\n\n4. All Documents are to be produced as kept in the usual course of business or are to be organized and labeled to correspond with the categories in these Requests.\n\n5. Each Request contained herein extends to all Documents: (a) in Your possession, custody, or control; or (b) in the possession, custody, or control of anyone acting on Your behalf,\n\n#### Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 1052 of 1063\n\nincluding Your counsel or other representatives and advisors. Each Document shall be produced in its entirety.\n\n6. If You are requested to produce a Document that is no longer in Your possession, custody, or control, then Your response must (a) describe in detail the nature of the document and its contents; (b) identify the person(s) who prepared or authored the Document (and, if applicable, the Person(s) to whom the Document was sent); (c) identify the date on which the document was prepared or created; (d) state whether such Document (i) is missing or lost, (ii) has been destroyed, (iii) has been transferred, voluntarily or involuntarily, to others, or (iv) was otherwise disposed of; (e) state the reason for, and the facts and circumstances surrounding, such disposition; (f) identify the Persons who authorized such disposition; (g) identify the date or approximate date of such disposition; (h)state when the Document was most recently in Your possession, custody or control; and (i) identify the Person, if any, presently in possession, custody, or control of such Document.\n\n7. If You are requested to produce a Document that has been destroyed, then Your response must state, in addition to the information required by the preceding Instruction: (a) the reason for the Document's destruction; (b) the identity of the Person who destroyed the Document; and (c) the identity of the Person who directed that the Document be destroyed.\n\n8. If You claim that a requested Document is privileged or attorney work-product, then Your response must: (a) state (i) a description of the Document adequate to support Your contention that the Document is privileged, (ii) the title of the Document, (iii) the date of the Document, (iv) the author of the Document, (v) the addressee of the Document, (vi) the identity of each Person who received or saw the original or any draft, copy, or reproduction of the Document, (vii) whether the Document itself, or any information contained or referred to in the Document is in the possession, custody, or control of any other Persons, and if so, the identity of\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 1053 of 1063\n\nsuch Persons, as well as a statement addressing how the information came into their possession, (viii) the claim of privilege under which the Document is withheld, and (ix) all of the circumstances upon which You will rely to support such claim of privilege; and (b) produce a privilege log containing all of the information requested in Part (a) of this Instruction for each Document withheld on the basis of a claim of privilege in accordance with D. Conn. L. Civ. R. 26(e). For any part of a Document Request as to which a claim of privilege or work product is not made, responsive documents should be provided in full.\n\n9. If a portion of an otherwise responsive Document contains information subject to a claim of privilege, only that portion of the Document subject to the claim of privilege shall be deleted or redacted from the Document following the instructions above, and the rest shall be produced.\n\n10. The Requests are continuing in nature. You are hereby instructed to (a) supplement or correct any responses later learned to be incomplete or incorrect immediately upon learning that a prior response was incomplete or incorrect; and (b) produce any additional Documents that are called for under the\n\n11. If a Document is in a language other than English, You should provide that Document. If a Document is in a language other than English, and an English translation exists, You should provide both Documents.\n\n12. All references to Entities includes all affiliates thereof.\n\n13. All references to individual names include all alternative names, aliased, or nicknames.\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 1054 of 1063\n\n14. Unless otherwise expressly indicated, the period of time covered by the Document Requests is the period from February 5, 2012 to the date responses to the Document Requests are due.\n\n#### **II. RULES OF CONSTRUCTION**\n\n15. The use of (a) any singular noun shall be construed to include the plural, and vice versa, and (b) a verb in any tense shall be construed as the use of the verb in all othertenses.\n\n16. The terms (a) \"and\" and \"or\" shall be construed either conjunctively or disjunctively as necessary to bring within the scope of any request all responses that might otherwise be construed to be outside of its scope, and (b) \"each\" and \"any\" shall be deemed to include and encompass the words \"every\" and \"all.\"\n\n## **III. DEFINITIONS**\n\nThe definitions supplied by D. Conn. L. Civ. R. 26(c) and the rules of construction supplied by D. Conn. L. Civ. R. 26(d), as incorporated by D. Conn. Bankr. L.R. 2004-1(a), shall apply to the Document Requests. In addition, the following terms used in these Document Requests shall have the following meanings:\n\n1. \"You\" or \"Your\" or \"Yourself\" means and refers to Brown Harris Stevens, together with any of its affiliates, subsidiaries, employees, agents, counsel, advisors, or anyone acting on its behalf.\n\n2. \"Debtor\" means Ho Wan Kwok (a/k/a Miles Kwok, Miles Guo, Guo Wengui, Guo Haoyun, 郭文贵, or any other alias), together with his employees, agents, counsel, advisors, or anyone acting on his behalf.\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 1055 of 1063\n\n3. \"Debtor's Son\" means Qiang Guo (a/k/a Mileson Kwok, 郭强, or any other alias), together with his employees, agents, counsel, advisors, or anyone acting on his behalf.\n\n4. \"Debtor's Daughter\" means Mei Guo (a/k/a Mei Gui, 郭美, or any other alias), together with her employees, agents, counsel, advisors, or anyone acting on her behalf.\n\n5. \"Debtor's Purported Wife\" means Hing Chi Ngok (a/k/a Hing Chi Ng, Yue Qingzhi, 岳庆芝, or any other alias), together with her employees, agents, counsel, advisors, or anyone acting on her behalf.\n\n6. \"Debtor's Family\" means, collectively, the Debtor, the Debtor's Son, the Debtor's Daughter, and the Debtor's Purported Wife, and any other familial relation to the Debtor.\n\n7. \"Associated Individuals\" means, individually and collectively, all individuals that (1) hold, control, have custody over, or discretion over assets owned, controlled, or enjoyed by the Debtor or the Debtor's Family; or (2) have been employees, directors, or otherwise are affiliated with one or more Associated Entities, together with the respective employees, agents, counsel, advisors, or anyone acting on behalf of any of the foregoing. Such Associated Individuals shall include, but are not limited to: Daniel Podhaskie, Jason Miller, Steve Bannon, Karin Maistrello, Melissa Francis, William Gertz, Arethusa Forsyth, Glenn Mellor, Jennifer Mercurio, Eduardo Eurnekian, Han Chunguang (a/k/a 韩春光), Qu Guojiao (a/k/a Qu Guo Jiao, 屈国姣), Guo Lijie (a/k/a 郭丽杰), Zhang Wei (a/k/a 张伟\\*), Lihong Wei Lafrenz (a/k/a Sara Wei, 魏丽红), Hao Haidong (a/k/a 郝海东), Ross Heinemeyer, Max Krasner, Kyle Bass, Melissa Mendez, Ya Li (a/k/a 李娅), Dinggang Wang (a/k/a 王定刚), An Hong (a/k/a 安红), Yvette Wang (a/k/a Yanping Wang, Yan Ping Wang, 王雁平), Fiona Yu, Je Kin Ming (a/k/a William Je, Yu Jianming, 余建明 ), Yaz Qingua, and Lao Jiang (a/k/a Jiang Yunfu, Jiang Yunfu Be, 姜云浮).\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 1056 of 1063\n\n8. \"Associated Entities\" means, individually and collectively, all organizations or Entities of any type that (1) have been owned, controlled, or invested in by the Debtor or the Debtor's Family; or (2) have an interest, whether directly or indirectly, in any assets owned, controlled, or enjoyed by the Debtor or the Debtor's Family, together with the respective employees, agents, counsel, advisors, or anyone acting on behalf of any of the foregoing. Such Associated Entities shall include, but are not limited to: 7 Nod Hill LLC, AAGV Limited, ACA Investment Management Limited, ACA Capital Group Limited, Ace Decade Holdings Limited, AI Group Holdings Inc., Alfa Global Ventures Limited, Alfonso Global Limited, Allied Capital Global Limited, Alpine Fiduciaries SA, Anton Development Limited, Assets Sino Limited, Auspicious Coast Limited, Beijing Pangu Investment Co., Beijing Pangu Investment Co. Ltd., Beijing Pangu Investment Inc., Beijing Zenith Holdings Company Limited, Bravo Luck Limited, BSA Strategic Fund I, China Golden Spring (Hong Kong) Limited, Chuang Xin Limited, Crane Advisory Group LLC, Creative Apex Investments Limited, Crystal Breeze Investments Limited, Dawn State Limited, Eastern Profit Corporation Limited, Elite Well Global Limited, Empire Growth Holdings, G Club Operations LLC, G Fashion LLC, G News LLC, GETTR USA, Genever Holdings Corporation, Genever Holdings LLC, GFASHION MEDIA GROUP INC., GFNY, Inc., Globalist International Limited, GNews Media Group Inc., Golden Spring (New York) Ltd., Greenwich Land LLC, Guo Media, GTV Media Group, Inc., Hamilton Capital Holdings Inc., Head Win Group Limited, Henan Yuda, Himalaya Embassy, Himalaya Exchange, Himalaya Federal Reserve, Himalaya Supervisory Organization, HK International Funds Investments (USA) Limited LLC, Hong Kong International Funds Investments Limited, Infinite Increase Limited, Infinitum Developments Limited, Insight Phoenix Fund, Lamp Capital LLC, Leading Shine Limited, Leading Shine NY Limited, Long Gate Limited, Next Tycoon Investments Limited, New\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 1057 of 1063\n\nFederal State of China (a/k/a NFSC), Noble Fame Global Limited, Rosy Acme Ventures Limited, Rule of Law Foundation III, Inc., Rule of Law Foundation IV, Inc., Rule of Law Fund, Rule of Law Society, Rule of Law Society IV, Inc., G-Translators PTY LTD, Saraca Media Group, Inc., Shiny Ace Ltd., Shiny Times Holdings Ltd., Spirit Charter Investment Limited, Stevenson, Wong & Co., Voice of Guo Media, Inc., Well Origin Ltd., World Century Limited, Worldwide Opportunity Holdings Limited, Whitecroft Shore Limited, and ZIBA Limited.\n\n9. \"Including\" or any variant thereof means \"including without limitation.\"\n\n10. \"And\" and \"or\" mean \"and/or,\" and shall be construed both conjunctively as well as disjunctively in order to maximize their scope.\n\n11. \"Any\" and \"all\" and \"each\" mean \"each and every.\"\n\n12. \"Each\" and \"every\" mean \"each and every.\"\n\n13. \"Third Party\" means a Person or Entity other than Yourself.\n\n14. \"Transfer\" shall have the meaning given to it by section 101(54) of the Bankruptcy Code.\n\n15. \"Document\" means any information or thing within the scope of Fed. R. Civ. P. 34, and includes, without limitation, each and every written, recorded, or graphic matter of any kind, type, nature, or description that is or has been in Your Possession, Custody or Control, including all printed and electronic copies of electronic mail, computer files maintained in electronic form, correspondence, memoranda, tapes, stenographic or handwritten notes, written forms of any kind, charts, blueprints, drawings, sketches, graphs, plans, articles, specifications, diaries, letters, telegrams, photographs, minutes, contracts, agreements, surveys, computer printouts, data compilations of any kind, telexes, facsimiles, emails, text messages, instant messages, voice\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 1058 of 1063\n\nmessages, invoices, order forms, checks, drafts, statements, credit memos, reports, position reports, summaries, indices, books, ledgers, notebooks, schedules, transparencies, recordings, catalogs, advertisements, promotional materials, films, video tapes, audio tapes, CDs, computer disks, brochures, pamphlets, punch-cards, time-slips, Tweets, social media posts, or any written or recorded materials of any other kind, and all meta-data thereof, however stored (whether in tangible or electronic form), recorded, produced, or reproduced, and also including but not limited to, drafts or copies of any of the foregoing that contain any notes, comments, or markings of any kind not found on the original documents or that are otherwise not identical to the original documents.\n\n16. \"Person(s)\" means an individual, corporation, proprietorship, partnership, association, or any other Entity. \"Person\" also includes any agent, representatives, or expert, including but not limiting to, attorneys or financial advisors.\n\n17. \"Entity\" means any natural Person, corporation, partnership, subsidiary, sole proprietorship, firm, board, joint venture, association, agency, authority, commission or other business entity or juristic Person, as well as any affiliate, agent, parent including but not limited to counsel, financial advisors, or any other representative.\n\n18. \"Regarding\" means concerning, describing, comprising, referring to, related to, supporting, favoring, opposing, bolstering, detracting from, located in, considered in connection with, bearing on, evidencing, indicating, reporting on, recording, alluding to, responding to, connected with, commenting on, in respect of, about, in relation to, discussing, showing, describing, reflecting, analyzing constituting, and being.\n\n19. \"Relating to,\" \"relate(s) to\" or \"related to,\" when referring to any given subject matter, means, without limitation, any document that constitutes, comprises, involves, contains,\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 1059 of 1063\n\nembodies, reflects, identifies, states, refers directly or indirectly to, or is in any way relevant to the particular subject matter identified.\n\n20. \"Communication(s)\" means, in the broadest possible sense, and without limitation, any transmittal of information or knowledge (in the form of facts, ideas, inquiries, or otherwise). Communication(s) further refers to all conversations, agreements, inquiries, or replies, whether in person, by telephone, in writing, or by means of electronic transmittal devices, and includes, but is not limited to, all correspondence, emails, recordings, transmittal slips, memoranda, telephone communications, voice messages, telegrams, telefaxes, telecopies, telexes, instant messages, chats, text messages, postings to a message board or group chat, social media posts, tweets, videos uploaded to any video platform, telephonic notes, or notes transmitted internally or with third parties.\n\n21. \"Asset(s)\" means any item of economic value that is subject to Possession, Custody, or Control. Asset includes all real and personal property, including but limited to, real estate, land, houses, apartments, condominiums, automobiles, yachts, boats, planes, jets, helicopters, cash, bank accounts, cryptocurrencies, securities, accounts receivables, inventory, and other tangible and intangible property.\n\n#### **IV. DOCUMENTS TO BE PRODUCED**\n\n1. All Documents related to any income or Asset of the Debtor, the Debtor's estate, the Debtor's Family, or Associated Entity.\n\n2. All Documents related to any engagement letter with the Debtor, any member of the Debtor's Family, and/or any Associated Entity, including copy(ies) of such engagement letter(s).\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 1060 of 1063\n\n3. All Documents related to the payment of any retainer to You based upon your representation of the Debtor, the Debtor's Family, or an Associated Entity, including documents sufficient to identify the amount of the retainer and its source.\n\n4. All Documents related to any fees, payments, or monies received by You from or on behalf of the Debtor, the Debtor's Family, a Family Related Entity, or an Associated Entity held in escrow or in a client trust account.\n\n5. Documents sufficient to show the amount, date, and source of any payments made to You by or for the benefit of the Debtor, the Debtor's Family, or an Associated Entity.\n\n6. All Documents related to the Debtor's financial condition and obligations to his creditors, including without limitation all Documents related to any effort to avoid paying such obligations and All Documents related to this or any other actual or potential bankruptcy or similar insolvency proceeding.\n\n7. All Documents related to the Associated Entities, including but not limited to Documents related to their corporate structure, Assets, incorporation information, officers and directors, business purpose, and relationship to the Debtor, to any member of the Debtor's Family, or to any Associated Individual.\n\n8. All Documents regarding any investment or business dealing made by, with, or on behalf of Debtor or the Debtor's Family, on the one hand, and an Associated Entity, on the other hand.\n\n9. All Documents related to any Entity that the Debtor, the Debtor's Estate, the Debtor's Family, or the Associated Entities hold any interest or investment in, including but not limited to the nature and value of that interest or investment; any proceeds or benefits from such\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 1061 of 1063\n\nEntity that the Debtor, the Debtor's Estate, the Debtor's Family, or the Associated Entities receive on account of such interest or investment; and all Documents relating to any financial reporting or data relating to such Entity, including but not limited to all books and records, financial statements or tax Documents.\n\n10. All Documents regarding the *Lady May*; the Sherry Netherland Hotel / Condominium; the residential property located in Greenwich, Connecticut, at 373 Taconic Rd.; the residential property located in Greenwich, Connecticut, at 33 Ferncliff Rd.; the residential property located in Wilton, Connecticut at 354 Nod Hill Rd.; and any financial interest that the Debtor or the Debtor's estate possesses in any Associated Entity.\n\n11. All Documents related to the purported Declaration of Trust and Agreement, dated February 17, 2015, entered into by the Debtor, as Trustee, Genever Holdings Corporation, and Genever Holdings LLC, in favor of Bravo Luck Limited, as beneficiary.\n\n12. All Documents related to any aircraft owned, controlled, or used by the Debtor, including without limitation the aircraft bearing tail number T7-GQM any other aircraft registered in San Marino, including without limitation copies of all registration documents and flight manifests showing flights taken by such aircraft and the individuals onboard such flights.\n\n13. All Documents related to any investments or trading by the Debtor, the Debtor's Family, or an Associated Entity, in or around July 2020, or at any other time, in crude oil futures or any similar commodity, including without limitation Communications with Jiang Yunfu Be regarding any such investments or trading.\n\n14. All Communications between You and, either, the Debtor, the Debtor's Family, or any Associated Individual, agent, employee, or other individual acting on behalf of the Debtor,\n\n#### Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 1062 of 1063\n\nrelated to any Transfer, investment, or other transaction or business dealing relating to the Debtor, the Debtor's Estate, the Debtor's Family, or the Associated Entities.\n\n15. All Documents concerning any trust or similar instrument set up by, on behalf of, or for the benefit of Debtor, Debtor's Estate, Debtor's Family, or Associated Entities, including but not limited to Documents showing when the trust(s) was created, by whom it was created, to whose benefit it was created, and the corpus of the instrument.\n\n16. All Documents related to any sale, acquisition, disposition, purchase, investment, contribution, gift, extension of credit, loan, or Transfer involving the Debtor, the Debtor's Family, or any Associated Entity.\n\n17. All Documents related to any obligation, claim, liability, or debt associated with any legal dispute involving the Debtor, including but not limited to those relating to any litigation before any local, state, federal, or international body, whether an administrative body, court, panel, or alternative dispute resolution entity.\n\n18. All Documents related to any loans or extensions of credit, or applications for the same, to or from the Debtor, the Debtor's Estate, the Debtor's Family or any Associated Entity, including but not limited to (i) the terms of any such loans or extensions of credit, including their terms of repayment, representations and warranties, and interest rate, and (ii) all evidence of payments of the loans.\n\n19. All Documents related to the Debtor's use of any Assets belonging to, controlled by, or whose complete or partial ownership is held by the Debtor's Family, an Associated Entity, or an Associated Individual.\n\n## Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 1063 of 1063\n\n20. All Documents regarding any balance sheet, bank statement, account statement, financial statement, statement of account, wire transfer instructions and/or confirmation, proof of funds, certificate of deposit, certificate of holdings, investment portfolio summary, or similar document relating to the Debtor, the Debtor's Estate, the Debtor's Family, an Associated Entity, or an Associated Individual, including without limitation all Documents sufficient to show all Transfers to any of the foregoing.\n\n21. All Documents related to any pledges of Assets of any Associated Entity, including Bravo Luck Limited, to any other Entity.","body_zh":"美利坚合众国破产法院\n康涅狄格州地区法院\n布里奇波特分院\n\n-----------------------------------------------------------　x\n\n关于：　:\n:　第11章\n1　:\nHO WAN KWOK（郭文贵）,\n等　:\n:　案件编号：22-50073 (JAM)\n债务人。　:\n:　（合并管理）\n-----------------------------------------------------------　x\n\n第11章受托人关于依据《破产程序规则》第2004条和地方法则第2004-1条准许就与债务人有关联的额外实体和个人、相关银行以及与债务人和关联实体开展业务的实体进行证据开示而作出命令的第四份补充综合动议\n\nLuc A. Despins（卢克·A·德斯平斯）作为在上述标题所列 Ho Wan Kwok（郭文贵）（下称“债务人”）第11章案件（下称“本案”）中获任命的第11章受托人（下称“受托人”），通过其下列署名律师，依据《联邦破产程序规则》第2004(a)条（下称“《破产规则》”）和《地方破产规则》第2004-1条（下称“《地方法则》”），特此申请（下称“本申请”或“本动议”）对债务人的商业伙伴、专业人士和公司实体（下称“关联人士”）、受托人认为债务人和关联人士曾在其中开展与破产财产相关业务的若干银行（下称“银行”），以及与债务人和/或关联实体开展业务的若干实体（下称“供应商”，与关联人士和银行合称“受询问对象”）进行询问，该等受询问对象载于随附本案的附件B。特此通知，对本申请提出异议的截止日期为 March 31, 2023；如未及时提交异议，随附提交的附件A所载拟议命令（下称“拟议命令”）可在无需进一步通知和听证的情况下作出。为支持其申请，受托人谨陈述如下：\n\n1　本第11章案件中的债务人为 Ho Wan Kwok（郭文贵）（又名 Guo Wengui、Miles Guo 和 Miles Kwok，以及众多其他别名）（税务识别号后四位：9595）、Genever Holdings LLC（税务识别号后四位：8202）及 Genever Holdings Corporation。受托人、Genever Holdings LLC 和 Genever Holdings Corporation 的邮寄地址为 Paul Hastings LLP, 200 Park Avenue, New York, NY 10166，收件人为 Luc A. Despins，以 Ho Wan Kwok 遗产受托人身份（仅为通知和通信之目的）。\n\n初步陈述\n\n1. 为履行其根据日期为 July 6, 2022 的准许任命第11章受托人的命令所承担的职责和责任（见 ECF. No. 465，第14页，以下简称“受托人命令”），受托人继续调查债务人的财务和商业事务，以确定是否存在额外的破产财产资产，并为债务人破产财产的利益追收该等资产。\n\n2. 受托人的调查已发现更多可能知悉债务人资产和财务活动的个人和实体，受托人寻求通过对这些受询问对象进行额外的《破产规则》第2004条证据开示，以进一步推进其调查。\n\n3. 受托人认为，受询问对象能够获得并了解与债务人的资产、财务事务，以及债务人在与债务人、其家人或其伙伴有关的各类公司实体中可能拥有的财务权益相关的信息。事实上，如债务人确曾通过空壳公司网络及其他方式从事隐匿其财富的行为（正如纽约州最高法院已认定），债务人很可能需要关联人士提供广泛协助、帮助及参与。\n\n4. 受托人已提交数项获法院准许的《破产规则》第2004条动议，包括一项针对被认为曾向债务人及相关实体和个人提供建议的法律和金融公司的动议（ECF No. 637，下称“顾问2004动议”）、一项针对被认为与债务人有关联、受债务人控制或以其他方式与债务人有关联的实体和个人的动议（下称“关联方2004动议”）、受托人日期为 September 7, 2022 的第一份补充综合动议（下称“第一份综合动议”）、受托人日期为 November 18, 2022 的第二份补充综合动议（下称“第二份综合动议”），以及受托人日期为 December 21, 2022 的第三份补充综合动议（下称“第三份综合动议”，与顾问2004动议、关联方2004动议、第一份综合动议和第二份综合动议合称“2004动议”）；该第三份补充综合动议已由法院日期为 January 18, 2023 的命令准许（见 ECF No. 1339）。本申请所请求的证据开示将补充和扩展受托人已开始的调查，并开辟额外的调查途径和发现资产的可能性。\n\n5. 为简明起见，受托人将2004动议通过援引纳入本申请，并使其构成本申请的一部分。本申请中未定义的所有首字母大写术语，均具有2004动议中赋予其的含义。\n\n管辖权和审判地\n\n6. 法院依据 28 U.S.C. §§ 157 和 1334 对审理本申请具有管辖权。依据 28 U.S.C. §§ 1408 和 1409，在本法院审理本申请的审判地适当。\n\n7. 本申请构成根据包括但不限于 28 U.S.C. § 157(b)(2) (A)、(E) 和 (F) 在内的规定所称的核心程序。\n\n受询问对象\n\n8. 受询问对象是可能为债务人工作、与债务人合作、受债务人控制，或可能以其他方式掌握有关债务人资产和财务状况的重要信息的额外个人和实体。许多受询问对象与纽约州最高法院所述债务人的“空壳游戏”所涉空壳公司网络有关。受询问对象还包括协助债务人实施受托人正在调查的各项商业活动的关联人士，以及可能已与债务人订立合同或以其他方式与债务人开展业务的当事方。\n\n9. 更具体而言，受询问对象如下：\n\n(a) 据向受托人报告，债务人以及与债务人有关联的实体和个人曾在多家银行机构开展业务，其中可能涉及本申请和2004动议所述的关联人士及交易。受托人认为，这些银行机构可能持有与债务人的商业活动及其他涉及资产、负债或可能与债务人破产财产管理有关的财务权益的行为相关的信息和文件，并且可能持有债务人的资产。这些银行包括但不限于：(i) Santander Bank, N. A.（桑坦德银行，全国协会），(ii) Silvergate Bank（银门银行），(iii) DBS Bank Ltd.（星展银行有限公司），(iv) The First Bank of Greenwich（格林尼治第一银行），(v) Bank of China – New York Branch（中国银行纽约分行）和/或 Bank of China Limited（中国银行股份有限公司），(vi) U.S. Bank National Association（美国银行全国协会）；(vii) The Bank of Princeton（普林斯顿银行）；(viii) Metropolitan Commercial Bank（大都会商业银行）和/或 Metropolitan Bank Holding Corp.（大都会银行控股公司）；(ix) Medici Bank International LLC（美第奇国际银行有限责任公司），(x) Deltec Bank & Trust Limited（德尔泰克银行信托有限公司），(xi) Open Bank（开放银行）；(xii) National Australia Bank Limited（澳大利亚国民银行有限公司），以及 (xiii) First Republic Bank（第一共和银行）；\n\n(b) 受托人了解到，债务人曾鼓励其追随者向 (i) Hamilton M&A Fund SP（汉密尔顿并购基金SP）投资，该基金为 (ii) Hamilton Opportunity Fund SPC（汉密尔顿机会基金SPC）的一个独立投资组合（合称“汉密尔顿实体”），以购买或拟议购买 (iii) Mercantile Global Holdings, Inc.（默坎特尔全球控股公司）的控股股权；受托人了解到，该公司拥有 (iv) Mercantile Bank International Corp.（默坎特尔国际银行公司）100%的股权（合称“默坎特尔实体”）。受托人了解到，Hamilton Opportunity Fund SPC 的其中一名董事为债务人的伙伴 William Je（威廉·杰）（就其而言，已就第一份综合动议准许进行2004证据开示），而 Hamilton Opportunity Fund SPC 的另一名董事为 (v) David Fallon（大卫·法伦）。因此，Fallon 先生、汉密尔顿实体和默坎特尔实体很可能持有与受托人调查相关的文件。\n\n(c) (i) G-EDU Inc.、(ii) GFashion Media Group Inc. 和 (iii) G Translators Pty Ltd 是另外的“G系列”实体，其名称受债务人启发，并且与 New Federal State of China（新中国联邦）(“NFSC”) 和/或 Himalaya Exchange（喜马拉雅交易所）有关联；本法院已认定后者“服务于债务人的目的，作为债务人的商业工具，其成员在个人上忠于债务人”，2 因此很可能持有与受托人调查相关的文件；\n\n(d) 债务人经常提及其本人或其直系家庭成员拥有和控制的重要不动产和动产资产。为推进受托人的调查，受托人寻求与可能由债务人拥有或控制的住宅物业有关的额外证据开示。据认为，(i) Emile P de Neree（埃米尔·P·德·内雷）和 (ii) NRT New England LLC（NRT新英格兰有限责任公司）（以 Coldwell Banker Residential Brokerage（科德威尔银行住宅经纪）名义营业）曾就位于 373 Taconic Road, Greenwich, Connecticut 06831 的物业（下称“Taconic”）的买卖代理债务人和/或债务人控制的实体；(iii) Martha Jeffery（玛莎·杰弗里）和 (iv) Sotheby's International Realty Affiliates LLC（苏富比国际房地产加盟商有限责任公司）曾就 Taconic 的买卖代理债务人和/或债务人控制的实体；(v) Mary “Muffin” Dowdle（玛丽“玛芬”·道德尔）和 (vi) Ginnel Associates, Inc.（金内尔联合公司）（以 Ginnel Real Estate（金内尔房地产）名义营业）曾就位于 Greenwich, Connecticut 的不动产可能购买事宜代理债务人和/或债务人控制的实体；以及 (vii) Zhizhe “Frank” Dong（董志哲“弗兰克”）和 (viii) Redfin Corporation（红鳍公司）曾就位于 Greenwich, Connecticut 的不动产可能购买事宜代理债务人和/或债务人控制的实体。此外，(ix) Brown Harris Stevens（布朗·哈里斯·史蒂文斯）曾协助债务人购买位于 781 Fifth Avenue, New York, NY 10022 的 Sherry Netherlands（谢里荷兰）公寓（1801号和1519号公寓）。因此，上述各方均可能掌握与该等交易、该等物业及债务人在其中权益相关的信息、文件和记录；\n\n2　Corrected Mem. of Decision Granting in Part Mot. for Prelim. Inj. ¶ 7, Adv. Proc. No. 22-05032 [Docket No. 133]（部分准许初步禁令动议的更正决定备忘录，第7段，对抗程序案号 22-05032 [案卷编号 133]）。\n\n(e) Alex Hadjicharalambous（亚历克斯·哈吉查兰博斯）与 G Club（G俱乐部）有关联（就 G Club 而言，已就第二份综合动议准许进行2004证据开示），并被认为受雇于 Freedom Media Ventures Ltd.（自由媒体创投有限公司）和/或 HCHK Entities（HCHK实体）（就 HCHK实体而言，已就第二份综合动议准许进行2004证据开示）；上述各方均与债务人关联的 Himalaya Exchange 加密货币业务有关联，本法院已认定该业务“服务于债务人的目的，作为债务人的商业工具，其成员在个人上忠于债务人”。3 因此，Hadjicharalambous 先生很可能持有与受托人调查相关的文件；\n\n(f) Min Yang（闵阳，又名 Yang Min）被指控，除其他事项外，对由债务人创立的 Rule of Law Foundation III Inc.（法治基金会III公司）行使财务控制权（就该公司而言，已就关联方2004动议准许进行2004证据开示），因此很可能持有与受托人调查相关的文件；\n\n3　Corrected Mem. of Decision Granting in Part Mot. for Prelim. Inj. ¶ 7, Adv. Proc. No. 22-05032 [Docket No. 133]（部分准许初步禁令动议的更正决定备忘录，第7段，对抗程序案号 22-05032 [案卷编号 133]）。\n\n(g) 据称，Lihong \"Sara\" Wei Lafrenz（李红“萨拉”魏·拉弗伦茨）曾设立并运营 Voice of Guo Media, Inc.（郭之声媒体公司）（就该公司而言，法院已就 Affiliates 2004 Motion（关联方第2004条动议）准许第2004条取证）；该公司与 GTV Media Group Inc.（GTV媒体集团公司）及 Saraca Media Group Inc.（萨拉卡媒体集团公司）一同，是 U.S. Securities and Exchange Commission（美国证券交易委员会，以下简称“SEC”）提交的《启动停止及终止程序命令》的对象，该程序导致其合计负有向 SEC 支付逾 $539 million 民事罚款、返还非法所得及利息的义务。4 因此，鉴于其与债务人实体网络的关联，她很可能持有与受托人调查有关的文件；\n\n(h) (i) Qing \"Serena\" Cai（蔡青“塞雷娜”）及 (ii) Ding G. Wang a/k/a Dinggang Wang（王丁刚，又名 Dinggang Wang）均为债务人的关联方；除其他关联外，据称其曾居住于 33 Ferncliff Rd., Cos Cob, Connecticut 06807，该住宅物业此前由 Greenwich Land LLC（格林尼治土地有限责任公司）所有（就该公司而言，法院已就 Affiliates 2004 Motion（关联方第2004条动议）准许第2004条取证），而该公司据称由债务人据称的妻子 Hing Chi Ngok（邢志乐）所有（就其而言，法院已就 Affiliates 2004 Motion（关联方第2004条动议）准许第2004条取证）。因此，他们很可能持有与受托人调查有关的文件；\n\n(i) Christodoulos G. Vassiliades & Co. LLC（克里斯托杜洛斯·G·瓦西利亚德斯律师事务所有限责任公司）是一家总部位于塞浦路斯的律师事务所；文件显示，该所曾向债务人控制的银行账户转移大额资金，因此其很可能持有与受托人调查有关的文件；\n\n4 参见 U.S. Securities and Exchange Commission（美国证券交易委员会），Order（命令），In the Matter of GTV Media Group, Inc., Saraca Media Group, Inc., and Voice of Guo Media, Inc., Admin. Proc. File No. 3-20537, Release No. 10979 (dated Sept. 13, 2021)。\n\n案件 22-50073 文件 1592 提交于 03/24/23 登记于 03/24/23 10:57:37 第 8 页，共 1063 页\n\n(j) Liberty Jet Management（自由喷气机管理公司）似乎曾就私人飞机向债务人和/或关联人士提供服务。因此，Liberty Jet Management 很可能持有与受托人调查有关的文件，包括与债务人的飞机、债务人飞机的维护、与债务人飞机有关的费用以及债务人飞机产生的收入有关的文件；\n\n(k) (i) Mimaii NZ Limited（Mimaii新西兰有限公司）、(ii) Tong Le Internatiional Trading Co., Ltd.（通乐国际贸易有限公司）、(iii) Macaron Limited（马卡龙有限公司）及 (iv) Joyord Sportswear Limited（乔约德运动服饰有限公司），均由债务人的律师向法院披露为用于实现债务人之子 Qiang Guo（郭强）支付债务人律师费用的“中介实体”，因此很可能持有与受托人调查有关的文件；\n\n(l) (i) Prime Trust LLC（普莱姆信托有限责任公司）据称是一家金融基础设施及交易技术服务公司；该公司在向 U.S. Bank National Association（美国合众银行全国协会）转移之前，曾向 HK USA 的律师转移 $37 million（目前与 Lady May（“Lady May”号）有关而由 U.S. Bank National Association 托管），并且据称为曾协助包括 (ii) RBB Bancorp（RBB银行控股公司）和/或 Royal Business Bank（皇家商业银行）在内的机构，接收个人就债务人加密货币业务支付的资金的中间机构。因此，两者很可能持有与受托人调查有关的文件；\n\n(m) Marcum LLP（马库姆有限责任合伙企业）是一家会计及咨询公司，曾为 HCHK Property Management, Inc.（HCHK物业管理公司）、HCHK Technologies, Inc.（HCHK技术公司）及 Lexington Property and Staffing, Inc.（列克星敦物业及人力服务公司）编制纳税申报表（就该等公司而言，法院已就 Second Omnibus Motion（第二项综合动议）准许第2004条取证）；该等实体与债务人及若干关联人士有关联。\n\n案件 22-50073 文件 1592 提交于 03/24/23 登记于 03/24/23 10:57:37 第 9 页，共 1063 页\n\n因此，Marcum LLP 很可能持有与受托人调查有关的文件；\n\n(n) (i) HHS Capital Inc.（HHS资本公司），一家佛罗里达州实体，(ii) Huk Trading Inc.（胡克贸易公司），一家特拉华州实体，(iii) FungWan Trading Inc.（丰万贸易公司），一家特拉华州实体，(v) Pixshow Film Inc.（皮克斯秀电影公司），一家特拉华州实体，(vi) Sirius Networking Inc.（天狼星网络公司），一家特拉华州实体，及 (vii) Brent Petro Inc.（布伦特石油公司），一家在得克萨斯州注册的实体，均被指称为已促成向 ACA Capital Limited（ACA资本有限公司）、HCHK Property Management Inc.（HCHK物业管理公司）、Crane Advisory Group LLC（克兰咨询集团有限责任公司）、HCHK Technologies Inc.（HCHK技术公司）和/或 G Club Operation LLC（G俱乐部运营有限责任公司）付款的中介实体（就该等实体而言，法院已就某些第2004条动议准许第2004条取证）。因此，它们很可能持有与受托人调查有关的文件；\n\n(o) Medical Supply System International LLC（医疗供应系统国际有限责任公司）是一家总部位于亚利桑那州的实体，据信其曾向债务人控制的银行账户转移大额资金，因此其很可能持有与受托人调查有关的文件；\n\n(p) Leading Shine NY Ltd.（领先闪耀纽约有限公司）是一家特拉华州实体；债务人的同事及雇员 Yvette Wang（王伊薇）据称为该实体的高级管理人员及受益所有人，该实体还参与了受托人认为代表债务人进行的大量交易，包括与据称由债务人家庭成员拥有的实体进行的交易。因此，其很可能持有与受托人调查有关的文件；\n\n(q) Oasis Tech Limited（绿洲科技有限公司）是一家总部位于新西兰的实体，据称由债务人的关联方注册，并参与了与债务人有关的欺诈性转移或据称的加密货币转移；因此，其很可能持有与受托人调查有关的文件；以及\n\n案件 22-50073 文件 1592 提交于 03/24/23 登记于 03/24/23 10:57:37 第 10 页，共 1063 页\n\n(r) 最后，受托人请求获授权就某些先前受审查对象的关联方发出传票，法院此前已授权对该等先前受审查对象进行《破产程序规则》第2004条取证。受托人在向先前受审查对象送达文件和/或与其协商时已确定，向这些关联实体寻求文件和信息也可能富有成效。更具体而言，受托人请求获授权向以下主体发出《破产程序规则》第2004条传票：(i) Manufacturers and Traders Trust Company d/b/a M & T Bank（制造商和贸易商信托公司，以 M & T Bank 名义营业）（法院已根据 Third Omnibus Motion（第三项综合动议）授权受托人向 M&T Bank Corporation 发出传票），(ii) Capital One, NA（第一资本全国协会）（法院已根据 Second Omnibus Motion（第二项综合动议）授权受托人向 Capital One Financial Corporation 发出传票），(iii) Amazon Web Services LLC（亚马逊云服务有限责任公司）（法院已根据 Second Omnibus Motion（第二项综合动议）授权受托人向 Amazon.com, Inc. 发出传票），以及 (iv) HSBC Bank USA, N.A.（汇丰美国银行，全国协会）（法院已根据 First Omnibus Motion（第一项综合动议）授权受托人向 HSBC Holdings PLC 发出传票）。\n\n请求的救济\n\n10. 受托人根据《破产程序规则》第2004(a)条及 Local Rule 2004-1（地方法院规则第2004-1条），请求作出一项与 Proposed Order（拟议命令）形式实质上相同的命令，授权受托人对 Exhibit B（附件B）所列的受审查对象进行审查。\n\n请求救济的依据\n\n11. 根据第2004(a)条，经利害关系人申请，法院可以命令对任何个人或实体进行审查。根据第2004条获授权的审查范围极为广泛，可以涉及“债务人的行为、活动或财产，或者债务人的负债及财务状况，或者可能影响债务人财产管理的任何事项。”Fed. R. Bankr. P. 2004(b).\n\n案件 22-50073 文件 1592 提交于 03/24/23 登记于 03/24/23 10:57:37 第 11 页，共 1063 页\n\n12. “第2004条审查的目的，是协助利害关系人确定破产财产的性质和范围、查明资产、审查交易，并评估是否发生了不当行为。”In re Transmar Commodity Group Ltd., 2018 WL 4006324, at *4 (Bankr. S.D.N.Y. Aug. 17, 2018)（省略内部引文及引证）。这包括揭示财产的性质和范围，以及发现可能被故意或非故意隐匿的债务人资产。参见 In re Bennett Funding Group, Inc., 203 B.R. 24, 27-28 (Bankr. N.D.N.Y. 1996)。另参见 In re Millennium Lab Holdings II, LLC, 562 B.R. 614, 626 (Bankr. D. Del. 2016)（“第2004条审查的正当目标包括发现资产、审查交易，以及确定是否发生了不当行为。”（省略内部引文及引证））。\n\n13. 债务人在为支持提起本案而于 March 20, 2022 提交的声明中陈述，其提起第11章案件的目的包括“……(b) 鉴于[其]认为在该等事项上存在误解，为利益相关方提供高效的机会，以调查[其]资产、负债及财务事务；[以及] (c) 确定哪些资产属于破产财产，并进而可供向获准债权的持有人分配……。”（债务人声明，第3段）。受托人拟进行的调查与这些陈述的目的直接相关，因为该调查将协助受托人识别债务人的资产及负债，以便向债权人进行分配。\n\n14. 本文所涉的调查领域属于受托人持续调查工作的一部分。随着调查的演进，新的调查途径变得明显，因而产生了对更多个人、实体及调查领域进行取证的需要。根据上文所讨论的全部事实和证据，以及第2004条动议中所载的事实和证据，受托人寻求第2004条赋予的调查工具，以进一步确定资产的真实所有权，并探索受托人目前尚未知悉的其他潜在资产。\n\n案件 22-50073 文件 1592 提交于 03/24/23 登记于 03/24/23 10:57:37 第 12 页，共 1063 页\n\n15. 受托人请求，为推进其审查，法院指示受审查对象在传票送达后 thirty (30) 日内，或在受托人同意的其他期限内，按照随附于本文件5并构成本文件一部分的表格中所要求的内容，向受托人的律师提供与 Proposed Subpoenas（拟议传票）形式和实质基本相同的文件。这些请求除其他事项外，要求提供受审查对象与债务人就其财务状况、资产转移及公司治理问题进行沟通的文件。这些请求还要求提供受审查对象就同一等议题的内部档案和通信。\n\n16. 受托人将从受审查对象处获得的取证类型完全属于《破产程序规则》第2004条的范围。当相关取证可能识别资产并有助于为破产财产及债权人的利益追回资产时，破产法院通常准许针对专业事务所进行第2004条取证。参见，例如，In re Bame, 251 B.R. 367 (Bankr. D. Minn. 2000); In\n\n5 Exhibit B（附件B）载有拟议传票索引；如本动议获准，该等传票将向受审查对象送达。受托人还将针对各受审查对象的个别拟议传票作为 Exhibits C-1 to C-57（附件C-1至C-57）随附于本文件，其中包括针对各受审查对象的取证事项，且其形式和实质基本相同。\n\n6. Lady May 是受托人就其寻求调查取证的事项及潜在破产财产之一。受托人主张，即使目前有关 Lady May 所有权的对抗程序正在审理中，根据第 2004 条规则进行该等调查取证仍属适当。受托人拟议的与 Lady May 有关的调查取证涉及债务人为逃避其债权人而实施的整体行为模式，因此其范围大于可能在该对抗程序中寻求的调查取证。鉴于受托人正就其他事项向相同当事人寻求第 2004 条规则下的调查取证，由受托人现在进行该等调查取证对所有当事人而言也更为高效——要求受托人向相同当事人进行两次调查取证将是低效的。此外，这并非对抗程序原告通过第 2004 条规则试图规避《破产程序规则》就对抗程序中的调查取证所提供保护的典型情形。事实上，即使在审程序原则适用（其并不适用），其亦不会阻止受托人向并非涉及 Lady May 的对抗程序当事人的个人或实体寻求第 2004 条规则下的调查取证。最后，鉴于该对抗程序的程序状态，受托人目前可能无法在该程序中获得调查取证。然而，受托人现在需要其第 2004 条规则下的调查取证，以充分保护和保存潜在的破产财产。\n\n案件 22-50073 文件 1592 提交于 03/24/23 录入于 03/24/23 10:57:37 第 13 页，共 1063 页\n\nIn re Horvath（霍尔瓦特）, No. 13-34137, 2015 WL 2195060 (Bankr. N.D. Ohio May 7, 2015)（批准个人债务人就资产清单中所列债权进行调查取证，因取得该等调查取证可能增加债务人破产财产的价值）。\n\n17. 受托人主张，上述事实构成法院命令被审查人根据第 2004 条规则提交文件的充分理由。尽管债务人是协助受托人发现破产财产的信息和文件的必要来源，但向包括被审查人在内的其他当事人寻求调查取证，很可能显著降低破产财产为识别和追回破产财产而原本将承担的成本。事实上，被审查人持有的文件可能属于对受托人调查最有价值的文件。7\n\n18. 批准本申请对于受托人有效履行《受托人命令》所设想的职责至关重要，具体包括其“为债权人和破产财产的利益查找债务人资产”以及“调查债务人的资产、负债及财务事务”的授权。（见《受托人命令》第 15-16、18 页）。\n\n19. 批准本申请所请求的救济不会使包括债务人在内的任何利害关系方遭受不当损害。\n无先前申请\n\n20. 此前未曾提出本文件所请求救济的申请。受托人曾提交先前的第 2004 条动议，包括第三项综合动议，且法院已予批准；但该等先前动议并未请求向本案所涉被审查人进行调查取证。\n\n7. 受托人还请求授权，如在受托人调查过程中确定被审查人的该等关联方或子公司为控制与被审查人有关且与受托人调查相关文件的当事方，则向该等关联方或子公司送达拟议传票。\n异议期限\n\n21. 对本申请提出异议的截止日期为 March 31, 2023；如未及时提交异议，\n\n则拟议命令可在无进一步通知和听证的情况下生效。\n\n【本页其余部分特意留白。】\n\n案件 22-50073 文件 1592 提交于 03/24/23 录入于 03/24/23 10:57:37 第 15 页，共 1063 页\n\n因此，受托人谨请求法院批准本申请，并根据 Fed. R. Bankr. P. 2004(a) 作出拟议命令，指令对被审查人进行审查，并指令提交拟议传票所附《文件提交请求》中列明的特定文件，以及作出法院认为公正、适当的其他及进一步救济。\n\n日期：March 24, 2023　LUC A. DESPINS（吕克·A·德斯平），\n\nNew Haven, Connecticut　CHAPTER 11 TRUSTEE（第 11 章受托人）\n\n代理人：/s/ Patrick R. Linsey\nDouglas S. Skalka（道格拉斯·S·斯卡尔卡）(ct00616)\nPatrick R. Linsey（帕特里克·R·林赛）(ct29437)\nNEUBERT, PEPE & MONTEITH, P.C.（纽伯特、佩佩和蒙蒂思律师事务所）\n195 Church Street, 13th Floor\nNew Haven, Connecticut 06510\n(203) 781-2847\ndskalka@npmlaw.com\nplinsey@npmlaw.com\n\n第 11 章受托人代理律师\nUNITED STATES BANKRUPTCY COURT（美国破产法院）\nDISTRICT OF CONNECTICUT（康涅狄格地区）\nBRIDGEPORT DIVISION（布里奇波特分庭）\n\n-----------------------------------------------------------　x\n\n关于：　：\n：　第 11 章\n\nHO WAN KWOK（郭文贵），\n等，　：\n：　案件编号 22-50073 (JAM)\n债务人。　：\n：\n：　（合并管理）\n-----------------------------------------------------------　x\n异议期限通知\n\nLuc Despins（吕克·德斯平）作为获任命的债务人破产财产第 11 章受托人（“申请人”），已向 U.S. Bankruptcy Court for the District of Connecticut（美国康涅狄格地区破产法院）提交申请，请求对附件 B 所列的特定顾问和专业人士、家庭成员、商业伙伴、公司实体及银行机构进行第 2004 条规则审查（“第 2004 条规则审查”）。特此通知，任何对第 2004 条规则审查提出的异议或答复，必须根据 Fed. R. Bankr. P. 2002(a) 和 9014 及 Local Bankr. R. 2004-1(c)，不迟于 March 31, 2023 向法院提交。如未及时提交异议，有关第 2004 条规则审查的拟议命令可在无进一步通知和听证的情况下生效，见 11 U.S.C. section 102(1)。\n\n【本页其余部分特意留白。】\n\n1. 本第 11 章案件中的债务人为 Ho Wan Kwok（郭文贵）（亦称 Guo Wengui、Miles Guo 和 Miles Kwok，以及众多其他别名）（税务识别号码后四位：9595）、Genever Holdings LLC（税务识别号码后四位：8202）以及 Genever Holdings Corporation。受托人、Genever Holdings LLC 和 Genever Holdings Corporation 的邮寄地址为 Paul Hastings LLP（保罗·黑斯廷斯律师事务所）, 200 Park Avenue, New York, NY 10166，转交 Luc A. Despins（吕克·A·德斯平），作为 Ho Wan Kwok（郭文贵）破产财产的受托人（仅用于通知和通信目的）。\n\n案件 22-50073 文件 1592 提交于 03/24/23 录入于 03/24/23 10:57:37 第 17 页，共 1063 页\n\n日期：March 24, 2023　LUC A. DESPINS（吕克·A·德斯平），\n\nNew Haven, Connecticut　CHAPTER 11 TRUSTEE（第 11 章受托人）\n\n代理人：/s/ Patrick R. Linsey\nDouglas S. Skalka（道格拉斯·S·斯卡尔卡）(ct00616)\nPatrick R. Linsey（帕特里克·R·林赛）(ct29437)\nNEUBERT, PEPE & MONTEITH, P.C.（纽伯特、佩佩和蒙蒂思律师事务所）\n195 Church Street, 13th Floor\nNew Haven, Connecticut 06510\n(203) 821-2000\ndskalka@npmlaw.com\nplinsey@npmlaw.com\n\n第 11 章受托人代理律师\n附件 A——拟议命令\nUNITED STATES BANKRUPTCY COURT（美国破产法院）\nDISTRICT OF CONNECTICUT（康涅狄格地区）\nBRIDGEPORT DIVISION（布里奇波特分庭）\n\n-----------------------------------------------------------　x\n\n关于：　：\n：　第 11 章\n\nHO WAN KWOK（郭文贵），\n等，　：\n：\n：　案件编号 22-50073 (JAM)\n债务人。　：\n：　（合并管理）\n-----------------------------------------------------------　x\n【拟议】命令：批准第 11 章受托人提出的第四项补充综合动议，根据《破产程序规则》第 2004 条及地方法则 2004-1 作出命令，授权就与债务人、相关银行及与债务人和关联实体有业务往来的实体有关联的其他实体和个人进行调查取证\n\n经审议 Luc Despins（吕克·德斯平）作为获任命的债务人破产财产第 11 章受托人（“申请人”）提交的申请（“申请”，ECF No. _____），该申请寻求作出命令，授权根据《联邦破产程序规则》第 2004 条对其附件 B 所列被审查人进行审查；在通知和听证后，见 11 U.S.C. § 102(1)；鉴于显见存在按下文条件批准所请求救济的理由；特此\n\n命令：如下文所述，批准第 2004 条规则动议。\n\n命令：特此授权 Neubert, Pepe & Monteith, P.C.（纽伯特、佩佩和蒙蒂思律师事务所）作为受托人代理律师，以与作为第 2004 条规则动议附件 C-1 至 C-57 所附传票实质相似的形式签署传票，并根据《破产程序规则》第 2004 条，连同本命令副本一并送达传票，以要求对本申请附件 B 所列被审查人进行审查并提交文件。\n\n命令：在不影响《联邦破产程序规则》《联邦民事诉讼规则》及适用地方法则项下任何权利的前提下，且除非法院另有命令，特此指令被审查人在传票送达后 30 日内，或在受托人同意的其他期限内，提交所有文件。如被审查人基于某项特权而未提交传票所要求的任何文件，特此指令该被审查人在传票送达后 30 日内，或在受托人同意的其他期限内，向受托人提交符合 Fed. R. Civ. P. 45(e)(2)（经 Fed. R. Bankr. P. 9016 适用）及 D. Conn. L. Civ. R. 26(e) 的特权日志。\n\n1. 本第 11 章案件中的债务人为 Ho Wan Kwok（郭文贵）（亦称 Guo Wengui、Miles Guo 和 Miles Kwok，以及众多其他别名）（税务识别号码后四位：9595）、Genever Holdings LLC（税务识别号码后四位：8202）以及 Genever Holdings Corporation。受托人、Genever Holdings LLC 和 Genever Holdings Corporation 的邮寄地址为 Paul Hastings LLP（保罗·黑斯廷斯律师事务所）, 200 Park Avenue, New York, NY 10166，转交 Luc A. Despins（吕克·A·德斯平），作为 Ho Wan Kwok（郭文贵）破产财产的受托人（仅用于通知和通信目的）。\n\n案件 22-50073 文件 1592 提交于 03/24/23 录入于 03/24/23 10:57:37 第 20 页，共 1063 页\n\n命令：特此指令被审查人确保，传票所要求的或以其他方式与债务人、其业务、资产、负债、财务状况或本第 11 章案件相关的所有文件及其他信息，包括但不限于任何电子格式的信息，均得到适当保存，可供提交、查阅和复制，且不得被销毁。\n\n命令：特此授权 Neubert, Pepe & Monteith, P.C.（纽伯特、佩佩和蒙蒂思律师事务所）作为受托人代理律师，无需本法院进一步命令，即可根据《破产程序规则》第 2004 条，在 Neubert, Pepe & Monteith, 195 Church Street, 13th Floor, New Haven, CT 06510 的办公室、Paul Hastings LLP（保罗·黑斯廷斯律师事务所）, 200 Park Avenue, New York, NY 10166 的办公室，或双方可接受的其他地点，于受托人可接受的日期，对本申请附件 B 所列任何被审查人的一名或多名代表进行审查；由受托人选择，该日期不得早于拟议被审查人依照《破产程序规则》第 2004 条、传票及本命令提交文件后 14 个日历日，且该审查应逐日持续，直至完成。\n\n日期：____________, 2023\n\nJulie A. Manning（朱莉·A·曼宁），美国破产法官\n\n____________________________________________________________\n附件 B\n案件 22-50073 文件 1592 提交于 03/24/23 录入于 03/24/23 10:57:37 第 22 页，共 1063 页\n\n调查取证当事人　地址　传票索引\n\nG-EDU Inc.（G-EDU公司）　转交：Yue Zhou（周悦）\n301 West 110 Street, Apt. 8E\nNew York, NY 10026　附件 C-1\nGFashion Media Group\nInc.（GFashion传媒集团公司）　5639 W. Sunset Blvd.\nLos Angeles, CA 90028　附件 C-2\n转交：Corporate Creations Network Inc.（Corporate Creations Network公司）\n5901 W. Century Blvd., #750\nLos Angeles, CA 90045\nG Translators Pty Ltd（G翻译有限公司）　转交：Ya Li（李娅）\nElevated Accounting\nGround Floor, 99 Coventry Street\nSouthbank, VIC 3006\nAustralia\nShop 1\n20-24 Ninth Avenue\nCampsie, NSW 2194\nAustralia　附件 C-3\nMartha Jeffery（玛莎·杰弗里）　80 Northfield St.\nGreenwich, Connecticut 06830-4618\nSotheby's International Realty -\nGreenwich\nBrokerage（苏富比国际地产—格林尼治经纪公司）\nOne Pickwick Plaza\nGreenwich, Connecticut\n06830, United States　附件 C-4\nEmile P de Neree（埃米尔·P·德·内雷）　12 Flying Cloud Rd\nStamford, Connecticut 06902-7723\nCompass Real Estate（康帕斯房地产公司）\n200 Greenwich Ave\n3rd Floor\nGreenwich, Connecticut 06830　附件 C-5\nZhizhe \"Frank\"\nDong（董志哲“弗兰克”）　165 Audubon Ave Apt 6,\nNew York, New York 10033-8764\n44 S. Broadway\nSte 100, #225\nWhite Plains, New York 10601　附件 C-6\n案件 22-50073　文件 1592　提交于 03/24/23　录入于 03/24/23 10:57:37　第 23 页，共 1063 页\n\n证据开示对象　地址　传票索引\n\nMary Dowdle\n（又名\nMuffin Dowdle）（玛丽·道德尔，又名马芬·道德尔）　41 Smith Road\nSharon, CT 06069-2401　附件 C-7\nAlex\nHadjicharalambous（亚历克斯·哈吉查拉兰布斯）　2318 28th Street\nAstoria, NY 11105-2802\n718-545-8889　附件 C-8\nMin Yang（杨敏）　10740 Queens Blvd.\nApt 11G\nForest Hills, NY 11375-4211　附件 C-9\nChristodoulos G.\nVassiliades & Co. LLC（克里斯托杜洛斯·G·瓦西利亚德斯律师事务所有限责任公司）　Ledra House\n15 Agiou Pavlou Street,\nAgios Andreas, CY-1105\nNicosia, Cyprus\nP.O. Box 24444\nCY-1704 Nicosia, Cyprus\nInterconsult (BVI) Limited（Interconsult〔BVI〕有限公司）\n3rd Floor, Yamraj Building, Market Square\nRoad Town\nTortola, British Virgin Islands　附件 C-10\nLiberty Jet\nManagement（自由喷气机管理公司）　29 Schaefer Drive\nRonkonkoma, NY 11779\n220 Townsend Square\nOyster Bay, NY 11771\n转交：American Incorporators Ltd.（美国公司设立服务有限公司）\n1013 Centre Road, Suite 403-A\nWilmington, DE 19805　附件 C-11\n\n证据开示对象　地址　传票索引\n\nSantander Bank, N. A.（桑坦德银行，全国协会）　75 State Street Map　附件 C-12\nBoston, Massachusetts 02109\n\nSantander Group City\nAv. de Cantabria s/n\n28660 Boadilla\ndel Monte Madrid-Spain\nFirst Republic Bank（第一共和银行）　111 Pine Street　附件 C-13\n2nd Floor\nSan Francisco, CA 94111\n\nSilvergate Bank（银门银行）　4250 Executive Square, Suite 300　附件 C-14\nLa Jolla, CA 92037\n收件人：John M. Bonino（约翰·M·博尼诺），首席法务官\n转交：CT Corporation System（CT公司服务系统）\n28 Liberty Street\nNew York, NY 10005\nThe Bank of Princeton（普林斯顿银行）　183 Bayard Lane　附件 C-15\nPrinceton, NJ 08540\n收件人：Daniel J. O'Donnell（丹尼尔·J·奥唐奈尔）\n470 W. Cheltenham Avenue\nPhiladelphia, PA 19126\nDBS Bank Ltd.（星展银行有限公司）　转交：Thomas Joseph McCabe（托马斯·约瑟夫·麦凯布）　附件 C-16\n300 South Grand Avenue\nSuite 3075\nLos Angeles, CA 90071\n12 Marina Boulevard\nMarina Bay Financial Centre Tower Three\nSingapore 018982\nSingapore\nThe First Bank of\nGreenwich（格林尼治第一银行）　444 East Putnam Avenue　附件 C-17\nCos Cob, Connecticut 06807\n转交：Bruno J. Gioffre（布鲁诺·J·焦弗雷）\nGioffre and Gioffre, PC（焦弗雷和焦弗雷专业公司）\n2900 Westchester Avenue\nSuite 206\nPurchase, NY 10577\n\n证据开示对象　地址　传票索引\n\nMercantile Bank\nInternational Corp.（商业国际银行公司）　604 Hoare Street　附件 C-18\nSuite 302\nSan Juan, Puerto Rico 00907-3614\n\nMercantile Global\nHoldings, Inc.（商业全球控股公司）　4306 Yoakum Blvd, Suite 200　附件 C-19\nHouston, Texas 77006\n\n转交：Harvard Business Services, Inc.（哈佛商业服务公司）\n16192 Coastal Hwy\nLewes, DE 19958\nHamilton M&A Fund\nSP　Limited（汉密尔顿并购基金SP有限公司）　转交：McGrath Tonner Corporate Services（麦格拉思·托纳公司服务机构）　附件 C-20\nP. O. Box 446\n5th Floor, Genesis Building\nGenesis Close\nGeorge Town KY1-1106\nCayman Islands\nHamilton Opportunity\nFund SPC　Limited（汉密尔顿机会基金SPC有限公司）　转交：McGrath Tonner Corporate Services（麦格拉思·托纳公司服务机构）　附件 C-21\nP. O. Box 446\n5th Floor, Genesis Building\nGenesis Close\nGeorge Town KY1-1106\nCayman Islands\n\n71-75 Aurora House\nUxbridge Rd\nEarling, London, United Kingdom\nW5 5SL\nGinnel Associates, Inc.（金内尔联合公司）　493 Bedford Center Road　附件 C-22\n（经营名称为\nGinnel Real　Bedford Hills, New York\n\nEstate）（金内尔房地产）\n转交：Daniel H. Ginnel（丹尼尔·H·金内尔）\n493 Bedford Center Road\nBedford Hills, New York\n\nRedfin Corporation（红鳍公司）　1099 Stewart Street, Suite 600　附件 C-23\nSeattle, WA, 98101\n\n转交：Legalinc Corporate Services Inc.（Legalinc公司服务公司）\n30 Old Kings Highway South\nDarien, Connecticut 06820\n\n证据开示对象　地址　传票索引\n\n转交：Legalinc Corporate Services Inc.（Legalinc公司服务公司）\n1967 Wehrle Drive, Suite 1 #086\nBuffalo, NY 143221\nSotheby's International\nRealty Affiliates LLC（苏富比国际地产关联有限责任公司）　3290 Northside Parkway\nSuite 200\nAtlanta, Georgia 30327\n175 Park Avenue\nMadison, NJ 07940\n转交：\nCorporate Creations Network Inc.（Corporate Creations Network公司）\n600 Mamaroneck Avenue, Suite 400\nHarrison, NY 10528　附件 C-24\nNRT New England\nLLC（经营名称为\nColdwell\nBanker Residential\nBrokerage）（NRT新英格兰有限责任公司〔经营名称为高纬环球住宅经纪公司〕）　转交：Corporate Creations Network Inc.（Corporate Creations Network公司）\n6 Landmark Square\n4th Floor\nStamford, Connecticut\n06901　附件 C-25\nDavid Fallon（大卫·法伦）　71-75 Aurora House\nUxbridge Rd\nEarling, London, United Kingdom W5 5SL　附件 C-26\nMimaii NZ Limited（Mimaii新西兰有限公司）　转交：Wen Soo Lo（罗文素）\n51 Joseph Banks Drive\nWhitby, Porirua, 5024 New Zealand　附件 C-27\nTong Le Internatiional\nTrading Co., Ltd.（同乐国际贸易有限公司）　Office No.\n12,\n19/F,\nHo King Comm Ctr,\nNO.\n2-16 Fa Yuen St,\nMongkok, KLN, Hong Kong　附件 C-28\n\n证据开示对象　地址　传票索引\n\nManufacturers and\nTraders Trust\nCompany（经营名称为 M & T\nBank）（制造商和贸易商信托公司〔经营名称为M & T银行〕）　转交：Corporation Service Company（公司服务公司）\n251 Little Falls Drive　附件 C-29\nWilmington, DE 19808\n转交：Corporation Service Company（公司服务公司）\nGoodwin Square\n225 Asylum Street, 20th Floor\nHartford, CT, 06103\nCapital One, NA（第一资本银行，全国协会）　1680 Capital One Drive\nMcLean, VA 22102-3407　附件 C-30\n转交：Corporation Service Company（公司服务公司）\n100 Shockoe Slip, Fl 2\nRichmond, VA 23219-4100\nAmazon Web Services\nLLC（亚马逊网络服务有限责任公司）　附件 C-31\n\nHSBC Bank USA,\nN.A.（汇丰银行美国，全国协会）　452 Fifth Avenue\nNew York, NY 10018　附件 C-32\n\n1800 Tysons Blvd.\nSuite 50\nMcLean, VA 22102\n转交：CT Corporation System（CT公司服务系统）\n67 Burnside Avenue\nEast Hartford, CT, 06108-3408\nBank of China –\nNew　Bank of China –\nNew York Branch（中国银行—纽约分行）　附件 C-33\nYork Branch and/or\nBank of China Limited（中国银行股份有限公司）　1045 Avenue of the Americas\nNew York, New York 10018\nBank of China –\nNew York Branch（中国银行—纽约分行）\n410 Madison Avenue\nNew York, NY 10017\nBank of China Limited（中国银行股份有限公司）\n7 Bryant Park\nLobby A\nNew York, New York, 10018\n\n证据开示对象　地址　传票索引\n\nU.S. Bank National\nAssociation（美国银行全国协会）　800 Nicollet Mall\nMinneapolis, MN 55402　附件 C-34\n425 Walnut St\nCincinnati, OH 45202\nMacaron Limited（马卡龙有限公司）　The Gas Light Lower Warrengate\nWakefield\nWest Yorkshire\nEngland WF1 1SA　附件 C-35\nLihong \"Sara\" Wei\nLafrenz（魏丽红“萨拉”·拉弗伦茨）　14747 N Northsight Blvd\nSte 111\nScottsdale, Arizona 85260-2633\n1850 W Orange Grove Rd.\nTucson, Arizona 85704　附件 C-36\nQing \"Serena\" Cai（蔡青“塞雷娜”）　7636 Heavenly Peak St.\nLas Vegas, NV 89166-5202　附件 C-37\nDing G. Wang（又名\nDinggang Wang）（王丁刚，又名王丁刚）　7636 Heavenly Peak St.\nLas Vegas, NV 89166-5202　附件 C-38\nPrime Trust LLC（Prime Trust有限责任公司）　330 S Rampart Blvd., Suite 260\nLas Vegas, NV 89145\n转交：CT Corporation System（CT公司服务系统）\n3800 N Central Avenue\nSuite 460\nPhoenix, AZ 85012　附件 C-39\n\n证据开示对象　地址　传票索引\n\nRBB Bancorp and/or\nRoyal Business Bank（RBB银行控股公司和/或皇家商业银行）　1055 Wilshire Blvd.\n12th Floor\nLos Angeles, California 90017　附件 C-40\nMedici Bank\nInternational LLC（美第奇国际银行有限责任公司）　1250 Ponce de Leon Avenue\nSan Juan, PR 00907　附件 C-41\nDeltec Bank & Trust\nLimited（德尔泰克银行与信托有限公司）　Deltec House, Lyford Cay\nNassau, Bahamas　附件 C-42\nNational Australia\nBank Limited（澳大利亚国民银行有限公司）　800 Bourke Street\nLevel 4\nDocklands, VIC Australia\n395 Bourke Street\nLevel 28\nMelbourne, Victoria, 3000　附件 C-43\nMetropolitan\nCommercial Bank\nand/or Metropolitan\nBank Holding Corp.（大都会商业银行和/或大都会银行控股公司）　99 Park Avenue\n12th Floor\nNew York, NY 10016　附件 C-44\nOpen Bank（开放银行）　1000 Wilshire Blvd.\n#500\nLos Angeles, CA 90017　附件 C-45\n\n证据开示对象　地址　传票索引\n\nMarcum LLP（马库姆有限责任合伙企业）　730 3rd Avenue\n11th Floor\nNew York, NY 10017　附件 C-46\nBrent Petro Inc.（布伦特石油公司）　108 West 13th St\nWilmington DE 19801\n8100 Cambridge St. 128\nHouston TX 77054　附件 C-47\nSirius Networking Inc.（天狼星网络公司）　651 N Broad St.\nSuite 206\nMiddletown,\nDE 19709　附件 C-48\nPixshow Film Inc.（Pixshow电影公司）　108 West 13th St.\nWilmington DE 19801　附件 C-49\nFungWan Trading Inc.（风云贸易公司）　108 West 13th St.\nWilmington DE 19801　附件 C-50\nHuk Trading Inc.（Huk贸易公司）　651 N Broad St\nSuite 206\nMiddletown,\nDE 19709　附件 C-51\nHHS Capital Inc.（HHS资本公司）　14660 SW 14 St.\nPembroke Pines, FL 33027　附件 C-52\n案件 22-50073　文件 1592　提交于 03/24/23　录入于 03/24/23 10:57:37　第 31 页，共 1063 页\n\n证据开示对象　地址　传票索引\n\nMedical Supply System\nInternational LLC（医疗供应系统国际有限责任公司）　3101 N. Central Ave\nSte 183 #2727\nPhoenix, Maricopa, AZ 85012　附件 C-53\nLeading Shine NY Ltd.（Leading Shine纽约有限公司）　3411 Silverside Road\nTatnall Building #104\nWilmington, Delaware\n19810　附件 C-54\nOasis Tech Limited（绿洲科技有限公司）　151 Marua Road\nMount Wellington\nAuckland, 1051\nNew Zealand　附件 C-55\nJoyord Sportswear\nLimited（Joyord运动服饰有限公司）　Room 1401, Cambridge House\n26-28 Cameron Road\nTsimshatsui, KLN, Hong Kong　附件 C-56\nBrown Harris Stevens（布朗哈里斯史蒂文斯公司）　445 Park Avenue\nNew York, NY 10022\n电话：212-906-9200　附件 C-57\n附件 C\n\n案件 22-50073　文件 1592　提交于 03/24/23　录入于 03/24/23 10:57:37　第 33 页，共 1063 页\n附件 C-1\nB2540（表格2540—Rule 2004审查传票）（12/15）案件 22-50073　文件 1592　提交于 03/24/23　录入于 03/24/23 10:57:37　第 34 页，共\n\n美利坚合众国破产法院\n\nDistrict of Connecticut（康涅狄格地区）\n\n关于 HO WAN KWOK（郭文贵）等人的案件，\n\n1 案件编号 22-50073 (JAM)　债务人　第11章\n\n（合并管理）\nRule 2004 审查传票\n\n致：G-EDU Inc.（G-EDU公司）\n\n（传票所指向人员的姓名）\n\n证言：现命令你于下列规定的时间、日期和地点到场，就《联邦破产程序规则》Rule 2004项下的审查作证。随附授权该审查的法院命令副本。\n\n地点　日期和时间\n\nPaul Hastings LLP（普衡律师事务所）\n200 Park Avenue　[TBD]\nNew York, New York 10166\n\n该审查将以以下方式记录：法庭记录员/速记员\n\n提交：你或你的代表还必须在审查时携带下列文件、电子存储信息或物品，并必须允许对该材料进行检查、复制、测试或抽样：\n见随附的文件提交请求。\n\n《联邦民事诉讼规则》Rule 45的下列规定，依《联邦破产程序规则》Rule 9016适用于破产案件，现随附于后——与履行地点有关的Rule 45(c)；与你作为传票对象所受保护有关的Rule 45(d)；以及与你回应本传票的义务和不予回应可能导致的后果有关的Rule 45(e)和45(g)。\n\n日期：March , 2023\n\n法院书记员\n\n或\n\n书记员或副书记员签名　律师签名\n\n签发或请求本传票、代表第11章受托人 Luc A. Despins（吕克·A·德斯平）行事的律师姓名、地址、电子邮件地址和电话号码如下：\n\nDouglas S. Skalka, Esq.（道格拉斯·S·斯卡尔卡，律师）；Neubert, Pepe & Monteith, P.C.（诺伊伯特、佩佩及蒙蒂斯专业公司）；195 Church Street, New Haven, Connecticut 06510 dskalka@npmlaw.com；(203) 821-2000\n\n致签发或请求本传票之人的通知\n\n如本传票命令在审判前提交文件、电子存储信息或有形物品，或检查场所，则在向传票所指向人员送达之前，必须向各方送达通知及本传票副本。Fed. R. Civ. P. 45(a)(4)。\n\n软件版权（c）1996-2022 Best Case, LLC（Best Case有限责任公司）- www.bestcase.com Best Case Bankruptcy（Best Case破产软件） 1 本第11章案件中的债务人为 Ho Wan Kwok（郭文贵）（亦称 Guo Wengui（郭文贵）、Miles Guo（郭文贵）和 Miles Kwok（郭文贵），以及多个其他别名）（税务识别号后四位：9595）、Genever Holdings LLC（Genever Holdings有限责任公司）（税务识别号后四位：8202）及 Genever Holdings Corporation（Genever Holdings公司）。受托人、Genever Holdings LLC及Genever Holdings Corporation的邮寄地址为 Paul Hastings LLP（普衡律师事务所），200 Park Avenue, New York, NY 10166，转交 Luc A. Despins（吕克·A·德斯平），作为 Ho Wan Kwok（郭文贵）遗产的受托人（仅为通知和通信之目的）。\n\n送达证明\n\n（除非 Fed. R. Civ. P. 45 要求，否则本节不应向法院提交。）\n\n我于（日期）收到向（个人姓名及职务〔如有〕）发出的本传票。\n\n我按下述方式，通过向指定人员交付副本送达了传票：\n\n于（日期）；或\n\n我未执行传票即予以退回，原因如下：\n\n除非本传票系代表美国或其官员或代理人签发，我还已向证人支付一天出席费及法律允许的里程费，金额为 \\$ 。\n\n我的差旅费用为 \\$，服务费用为 \\$，合计为 \\$ 。\n\n本人在伪证处罚的约束下声明，本信息真实且准确。\n\n日期：\n\n送达人的签名\n\n正楷姓名及职务\n\n送达人的地址\n\n有关尝试送达等事项的补充信息：\n《联邦民事诉讼规则》第45(c)、(d)、(e)及(g)条（2013年12月1日生效）（依据《联邦破产程序规则》第9016条适用于破产案件）\n(c) 履行地点。\n\n(1) 审判、听证或证言录取。传票仅可按下列规定命令某人出席审判、听证或证言录取：\n\n(A) 在该人居住地、受雇地或经常亲自从事营业活动地100英里以内；或\n\n(B) 在该人居住、受雇或经常亲自从事营业活动所在州内，若该人\n\n(i) 为当事人或当事人的高级职员；或\n\n(ii) 被命令出席审判且不会产生重大费用。\n\n(2) 其他证据开示。传票可以命令：\n\n(A) 在该人居住地、受雇地或经常亲自从事营业活动地100英里以内的地点提交文件、电子存储信息或物品；以及\n\n(B) 在待检查的不动产处检查该不动产。\n(d) 保护受传票约束的人；执行。\n\n(1) 避免不当负担或费用；制裁。负责签发及送达传票的当事人或律师，必须采取合理措施，避免对受传票约束的人施加不当负担或费用。要求履行义务所在地区的法院必须执行该义务，并对未遵守该义务的当事人或律师施加适当制裁，其中可包括收入损失和合理的律师费。\n(2) 命令提交材料或准许检查。\n\n(A) 无须出席。被命令提交文件、电子存储信息或有形物品，或准许检查不动产的人，无须亲自到提交或检查地点出席，除非同时被命令出席证言录取、听证或审判。\n\n(B) 异议。被命令提交文件或有形物品，或准许检查的人，可向传票中指定的当事人或律师送达书面异议，反对检查、复制、测试或抽样全部或部分材料，或反对检查不动产，或反对以所请求的一种或多种形式提交电子存储信息。异议必须在规定的履行时间之前，或传票送达后14日内（以较早者为准）送达。如提出异议，则适用下列规则：\n\n(i) 送达方可在任何时候通知被命令人后，向要求履行义务所在地区的法院提出动议，请求作出强制提交或检查的命令。\n\n(ii) 仅可按该命令所指示的方式要求实施这些行为，且该命令必须保护并非当事人或当事人高级职员的人免于承担因履行而产生的重大费用。\n(3) 撤销或修改传票。\n\n(A) 必须撤销或修改的情形。经及时动议，要求履行义务所在地区的法院必须撤销或修改符合下列情形的传票：\n\n(i) 未给予合理的履行时间；\n\n(ii) 要求某人在第45(c)条规定的地理范围限制之外履行；\n\n(iii) 要求披露享有特权或受其他保护的事项，且不存在适用的例外或豁免；或\n\n(iv) 对某人施加不当负担。\n\n(B) 可以撤销或修改的情形。为保护受传票约束或受传票影响的人，要求履行义务所在地区的法院可经动议撤销或修改要求下列事项的传票：\n\n(i) 披露商业秘密或其他保密的研究、开发或商业信息；或\n\n(ii) 披露未受聘专家的意见或信息，该意见或信息未描述争议中的特定事件，且系该专家未应任何当事人请求所进行研究的结果。\n\n(C) 规定条件作为替代方案。在第45(d)(3)(B)条所述情形下，如送达方：\n\n(i) 证明其对该证言或材料具有重大需要，且若不承受不当困难则无法通过其他方式满足该需要；并且\n\n(ii) 确保被传唤人将获得合理补偿，\n\n法院可不撤销或修改传票，而是命令在规定条件下出席或提交。\n(e) 回应传票时的义务。\n\n(1) 提交文件或电子存储信息。下列程序适用于提交文件或电子存储信息：\n\n(A) 文件。回应提交文件传票的人，必须按照文件在正常营业过程中保存的方式提交，或必须将文件整理并标注，以对应请求中所列类别。\n\n(B) 未规定电子存储信息的提交形式。如传票未规定提交电子存储信息的形式，回应人必须以其通常保存的一种或多种形式，或以一种或多种合理可用的形式提交。\n\n(C) 电子存储信息仅以一种形式提交。回应人无须以一种以上形式提交相同的电子存储信息。\n\n(D) 不可合理访问的电子存储信息。回应人无须就其认定因不当负担或费用而无法合理访问的来源中的电子存储信息提供证据开示。对于强制证据开示的动议或保护令动议，回应人必须证明该信息因不当负担或费用而无法合理访问。如作出该证明，在考虑第26(b)(2)(C)条限制的情况下，若请求方证明存在正当理由，法院仍可命令从该等来源进行证据开示。法院可为该证据开示规定条件。\n(2) 主张特权或保护。\n\n(A) 扣留的信息。依据该信息享有特权或作为审判准备材料受保护的主张而扣留被传唤信息的人，必须：(i) 明确提出该主张；并且\n\n(ii) 在不披露本身享有特权或受保护的信息的情况下，以足以使各方评估该主张的方式描述被扣留文件、通信或有形物品的性质。\n\n(B) 已提交的信息。如为回应传票而提交的信息受到特权主张或作为审判准备材料受保护的主张，提出主张的人可将该主张及其依据通知收到该信息的任何一方。收到通知后，当事人必须立即返还、隔离或销毁所指明的信息及其持有的任何副本；在该主张得到解决前不得使用或披露该信息；如该当事人在收到通知前已披露该信息，必须采取合理措施追回该信息；并可立即将该信息密封提交给要求履行义务所在地区的法院，以裁定该主张。提交该信息的人必须在该主张得到解决前保存该信息。\n\n(g) 藐视法庭。要求履行义务所在地区的法院，以及在动议移送后签发传票的法院，均可认定已被送达但无充分理由不遵守传票或与其相关命令的人构成藐视法庭。\n\n有关获取传票材料，请参见《联邦民事诉讼规则》第45(a)条委员会注释（2013年）\n\n……\n\n文件提交请求\nI. 指示\n\n1. 除非另有说明，下列文件请求（统称“请求”，每一项称为“一项请求”）必须分别且具体地作出答复。除非善意提出异议，否则每项请求均应得到完整答复；如提出异议，应按如下规定详细说明贵方异议的理由。如异议仅涉及某项请求的一部分，或其中包含的某个词语、短语或条款，贵方须仅对该部分说明异议，并答复其余请求。\n\n2. 电子存储信息必须依照下列指示提交：\n\na. 图像。黑白图像必须为300 DPI Group IV单页TIFF文件。彩色图像必须以JPEG格式提交。文件名不得包含嵌入空格或特殊字符（包括逗号）。文件夹名称不得包含嵌入空格或特殊字符（包括逗号）。所有TIFF图像文件必须具有唯一文件名，即Bates编号。每张图像右下角必须加注连续的Bates编号。每个文件夹内的TIFF文件数量不得超过1000个文件。Excel电子表格应具有以该文件Bates编号命名的占位图像。\n\nb. 图像加载文件\n\na. Concordance® 数据文件。数据文件（.DAT）包含将加载到Concordance®数据库的全部字段化信息。.DAT文件的第一行必须为标明字段名称的标题行。.DAT文件必须使用下列Concordance®默认分隔符：逗号 ASCII 字符（020）引号 þ ASCII 字符（254）。日期字段应按以下格式提供：mm/dd/yyyy。日期字段和时间字段必须为两个独立字段。如文件包括已成像的电子邮件及附件，必须包括附件字段，以保留电子邮件与其附件之间的父/子关系。必须包括OCRPATH字段，以提供所提交存储介质上提取文本文件的文件路径及名称。文本文件必须以FIRSTBATES命名。不得将文本包含在.DAT文件中。对于具有原生文件的文件，必须包括LINK字段，以提供原生文件的文件路径及\n\n名称。原生文件必须以FIRSTBATES命名。\n\n- b. Concordance Image® 或 Opticon 交叉引用文件。图像交叉引用文件（.LOG 或 .OPT）将图像与数据库记录关联。该文件应为逗号分隔文件，每行由七个字段组成，并应针对数据库中的每一图像在交叉引用文件中包含一行，格式如下：ImageID,VolumeLabel,ImageFilePath,DocumentBreak,FolderBreak,Box Break,PageCount。\n\n- c. 文档文本。文本必须作为单独的文本文件提供，而非作为 .DAT 文件中的字段。应在 .DAT 文件中包含文本文件的完整路径（OCRPATH）。建议提供以 FIRSTBATES/Image Key 命名的文档级 ANSI 文本文件。提取的文本文件必须存放在单独的文件夹中，每个文件夹中的文本文件数量不得超过 1,000 个。文件夹名称中不得包含特殊字符（包括逗号）。文本文件必须按文档级别提供。\n\n- d. 特定文件类型的原生格式提供。为充分理解其内容和含义而合理需要以原生格式查看的文件类型，必须以原生格式提供。这些包括但不限于：电子表格、类电子表格文件（Microsoft Excel、逗号分隔值、制表符分隔值等）、Microsoft PowerPoint 或其他特殊演示文件、数据库文件以及音频/视频文件。应提供一张带 Bates 编号的分隔页图像，以表明存在原生文件，并将原生文件路径作为 .dat 文件中的一个字段。提供的原生文件应以与该文件分隔页相对应的 Bates 编号命名。原生文件应归入按顺序命名的“NATIVE”目录中，与图像目录分开。\n\n- e. 去重。对于存在完全重复件的每一电子文档，仅提供一份副本。对于电子邮件，应根据由 BCC、Body、CC、From、IntMsgID、To 和 Attach 属性生成的 MD5 哈希值合并重复件。对于电子邮件附件和独立电子文件，应根据整个文件的 MD5 哈希值合并重复件。\n\n- f. 元数据。应以符合 Concordance 标准的加载文件（.dat）形式提供每份文档的提取元数据。.DAT 文件的第一行必须为标明字段名称的标题行。.DAT 文件必须使用以下 Concordance 默认分隔符：逗号 , ASCII 字符（020）引号 þ ASCII 字符（254）\n\n日期字段应采用以下格式提供：mm/dd/yyyy。日期和时间字段必须为两个单独的字段。所需元数据如下：\nCase 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 39 of 1063\n\n字段名称　示例数据　说明\n\nFIRSTBATES　EDC0000001　原生文件文档/电子邮件的第一个 Bates 编号\nLASTBATES　EDC0000001　原生文件文档/电子邮件的最后一个 Bates 编号\nLASTBATES 字段应针对单页文档填写\nATTACHRANGE　EDC0000001\n-　父文档第一页的 Bates 编号至最后一个附件“子”文档最后一页的 Bates 编号\nEDC0000015\nBEGATTACH　EDC0000001　附件范围的第一个 Bates 编号\nENDATTACH　EDC0000015　附件范围的最后一个 Bates 编号\nCUSTODIAN　Smith, John　电子邮件：电子邮件所在的邮箱\n原生文件：文档源自其文件的个人或部门的名称\nFROM　John Smith　电子邮件：发件人\n原生文件：文档作者\n多个条目之间应使用分号分隔\nTO　Coffman, Janice; LeeW　收件人\n[mailto:LeeW@MSN.com]　多个条目之间应使用分号分隔\nCC　Frank Thompson [mailto:　抄送收件人\nfrank_Thompson@cdt.com]　多个条目之间应使用分号分隔\nBCC　John Cain　密送收件人\n多个条目之间应使用分号分隔\nSUBJECT　Board Meeting Minutes　电子邮件：电子邮件主题行 原生文件：文档标题（如有）\nFILE_NAME　BoardMeetingMinutes.docx　原生文件：原始原生文件的名称，包括扩展名\nDATE_SENT　10/12/2010　电子邮件：电子邮件发送日期\n原生文件：（空）\nTIME_SENT/　07:05 PM GMT　电子邮件：电子邮件发送时间/电子邮件标准化所采用时区内的时间\nTIME_ZONE\nTIME_ZONE　GMT　在转换过程中对电子邮件进行标准化所采用的时区。\nLINK　EDC0000001.msg　电子邮件或原生文件文档的超链接\n链接文件必须按 FIRSTBATES 编号命名\nFILE_EXTEN　MSG　代表电子邮件或原生文件的文件类型扩展名\nAUTHOR　John Smith　电子邮件：（空）\n原生文件：文档作者\nDATE_CREATED　10/10/2010　电子邮件：（空）\n原生文件：文档创建日期\nCase 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 40 of 1063\n\nTIME_CREATED　10:25 AM　电子邮件：（空）\n\n原生文件：文档创建时间\n该数据必须为单独字段，不得与 DATE_CREATED 字段合并\nDATE_MOD　10/12/2010　电子邮件：（空）\n原生文件：文档最后修改日期\nTIME_MOD　07:00 PM　电子邮件：（空）\n\n原生文件：文档最后修改时间\n该数据必须为单独字段，不得与 DATE_MOD 字段合并\nDATE_ACCESSD　10/12/2010　电子邮件：（空）\n原生文件：最后访问文档的日期\nTIME_ACCESSD　07:00 PM　电子邮件：（空）\n原生文件：最后访问文档的时间\n该数据必须为单独字段，不得与 DATE_ACCESSD 字段合并\nFILE_SIZE　5,952　原生文件文档/电子邮件的大小，以 KB 为单位\nPGCOUNT　1　原生文件文档/电子邮件中的页数\nPATH　电子邮件：（空）\nAgenda.doc　原生文件：存储原生文件文档的路径，包括原始文件名称。\nINTFILEPATH　Personal Folders\\Deleted　电子邮件：电子邮件的原始位置，包括原始文件名称。\nItems\\Board Meeting\nMinutes.msg　原生文件：（空）\nINTMSGID　<000805c2c71b\\$75977050\\$　电子邮件：唯一消息 ID 原生文件：（空）\ncb8306d1@MSN>\nMD5HASH　d131dd02c5e6eec4693d9a0　文档的 MD5 哈希值。\n698aff95c\n2fcab58712467eab4004583e\nb8fb7f89\nOCRPATH　TEXT/001/EDC0000001.txt　原生文件提取文本的路径\n\n3. 每项请求均独立运行并应独立解释；除非另有说明，任何请求均不限制任何其他请求的范围。\n\n4. 所有文档均应按照通常业务过程中保存的方式提供，或者应予以整理和标注，以对应本请求中的类别。\n\n5. 本文件中的每项请求均延及所有文档：（a）由您占有、保管或控制的文档；或（b）由任何代表您行事的人占有、保管或控制的文档，\nCase 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 41 of 1063\n\n包括您的律师或其他代表及顾问。每份文档均应完整提供。\n\n6. 如要求您提供一份已不再由您占有、保管或控制的文档，则您的答复必须：（a）详细说明该文档的性质及其内容；（b）确定编制或撰写该文档的人员（以及，如适用，该文档的送达对象）；（c）确定该文档编制或创建的日期；（d）说明该文档是否：（i）遗失或丢失；（ii）已被销毁；（iii）已自愿或非自愿转让给他人；或（iv）以其他方式被处置；（e）说明该处置的理由以及相关事实和情形；（f）确定授权该处置的人员；（g）确定该处置的日期或大致日期；（h）说明该文档最后一次由您占有、保管或控制的时间；以及（i）确定目前占有、保管或控制该文档的人员（如有）。\n\n7. 如要求您提供一份已被销毁的文档，则除前述指示所要求的信息外，您的答复还必须说明：（a）销毁该文档的原因；（b）销毁该文档的人员身份；以及（c）指示销毁该文档的人员身份。\n\n8. 如您主张所请求的文档享有特权或属于律师工作成果，则您的答复必须：（a）说明：（i）足以支持您关于该文档享有特权之主张的文档描述；（ii）文档标题；（iii）文档日期；（iv）文档作者；（v）文档收件人；（vi）收到或阅览该文档原件或任何草稿、副本或复制件的每名人员身份；（vii）该文档本身或该文档所载或所涉任何信息是否由任何其他人员占有、保管或控制，如是，则确定\nCase 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 42 of 1063\n\n该等人员的身份，并说明该等信息如何由其占有；（viii）据以扣留该文档的特权主张；以及（ix）您将据以支持该特权主张的所有情形；并且（b）根据 D. Conn. L. Civ. R. 26(e)，就每份基于特权主张而扣留的文档，提供一份特权清单，其中包含本指示第（a）部分所要求的全部信息。\n\n9. 如一份本应回应请求的文档的一部分包含受特权主张约束的信息，则仅应按照上述指示从该文档中删除或遮盖受特权主张约束的该部分，其余部分应予提供。\n\n10. 本请求具有持续性。现指示您：（a）一旦获悉先前答复不完整或不正确，应立即补充或更正任何后来发现不完整或不正确的答复；以及（b）提供根据下列内容所要求的任何额外文档\n\n11. 如一份文档使用英语以外的语言，您应提供该文档。如一份文档使用英语以外的语言，且存在英文译本，您应同时提供两份文档。\n\n12. 对实体的所有提及均包括其所有关联方。\n\n13. 对个人姓名的所有提及均包括所有替代姓名、别名或昵称。\n\n14. 除非另有明确说明，文档请求所涵盖的期间为自 February 5, 2012 起至文档请求答复到期之日止。\nCase 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 43 of 1063\nII. 解释规则\n\n15. （a）任何单数名词的使用应解释为包括复数，反之亦然；以及（b）任何时态动词的使用应解释为包括该动词所有其他时态的使用。\n\n16. （a）“and”和“or”应视需要解释为连词或选择连词，以使原本可能被解释为不在任何请求范围内的所有答复均纳入该请求范围；以及（b）“each”和“any”应被视为包括并涵盖“every”和“all”。\nIII. 定义\n\n根据 D. Conn. Bankr. L.R. 2004-1(a) 纳入的 D. Conn. L. Civ. R. 26(c) 所规定的定义，以及 D. Conn. L. Civ. R. 26(d) 所规定的解释规则，应适用于文档请求。此外，本文件请求中使用的下列术语应具有下列含义：\n\n1. “您”或“您的”或“您本人”系指并指代 G-EDU Inc.（G-EDU公司），连同其所有关联方、部门、机构、工具部门、科室、办公室、合伙人、高级职员、董事、代理人、律师、代表、雇员，及/或任何代表其行事的人。\n\n2. “债务人”系指 Ho Wan Kwok（郭文贵）（又名 Miles Kwok、Miles Guo、Guo Wengui、Guo Haoyun、郭文贵或任何其他别名），连同其雇员、代理人、律师、顾问或任何代表其行事的人。\n\n3. “债务人之子”系指 Qiang Guo（郭强）（又名 Mileson Kwok、郭强或任何其他别名），连同其雇员、代理人、律师、顾问或任何代表其行事的人。\nCase 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 44 of 1063\n\n4. “债务人的女儿”系指Mei Guo（又名Mei Gui、郭美或任何其他别名），以及其雇员、代理人、法律顾问、顾问或任何代表其行事之人。\n\n5. “债务人声称的妻子”系指Hing Chi Ngok（又名Hing Chi Ng、Yue Qingzhi、岳庆芝或任何其他别名），以及其雇员、代理人、法律顾问、顾问或任何代表其行事之人。\n\n6. “债务人的家属”统称债务人、债务人的儿子、债务人的女儿及债务人声称的妻子，以及与债务人有任何其他亲属关系之人。\n\n7. “关联个人”单独及统称所有符合下列条件的个人：(1)持有、控制、保管债务人或债务人的家属所拥有、控制或享有的资产，或者对该等资产拥有酌处权；或(2)曾担任一个或多个关联实体的雇员、董事，或以其他方式与一个或多个关联实体有关联；并包括前述任何个人各自的雇员、代理人、法律顾问、顾问或任何代表其行事之人。该等关联个人应包括但不限于：Daniel Podhaskie、Jason Miller、Steve Bannon、Karin Maistrello、Melissa Francis、Anthony DiBattista、William Gertz、Arethusa Forsyth、Glenn Mellor、Jennifer Mercurio、Eduardo Eurnekian、Wencong Wang、Han Chunguang（又名韩春光）、Qu Guojiao（又名Qu Guo Jiao、屈国姣）、Guo Lijie（又名郭丽杰）、Zhang Wei（又名张伟*）、Lihong Wei Lafrenz（又名Sara Wei、魏丽红）、Hao Haidong（又名郝海东）、Ross Heinemeyer、Max Krasner、Kyle Bass、Melissa Mendez、Ya Li（又名李娅）、Dinggang Wang（又名王定刚）、An Hong（又名安红）、Yvette Wang（又名Yanping Wang、Yan Ping Wang、王雁平）、Fiona Yu、Je Kin Ming（又名William Je、Yu Jianming、余建明）、Yaz Qingua及Lao Jiang（又名Jiang Yunfu、Jiang Yunfu Be、姜云浮）。\n\n案号 22-50073 文件 1592 提交日期 03/24/23 录入日期 03/24/23 10:57:37 第45页，共1063页\n\n8. “关联实体”单独及统称所有符合下列条件的任何类型组织或实体：(1)曾由债务人或债务人的家属拥有、控制或投资；或(2)直接或间接对债务人或债务人的家属所拥有、控制或享有的任何资产拥有权益；并包括前述任何实体各自的雇员、代理人、法律顾问、顾问或任何代表其行事之人。该等关联实体应包括但不限于：7 Nod Hill LLC、AAGV Limited、ACA Investment Management Limited、ACA Capital Group Limited、Ace Decade Holdings Limited、AI Group Holdings Inc.、Alfa Global Ventures Limited、Alfonso Global Limited、Allied Capital Global Limited、Alpine Fiduciaries SA、Anton Development Limited、Assets Sino Limited、Auspicious Coast Limited、Beijing Pangu Investment Co.、Beijing Pangu Investment Co. Ltd.、Beijing Pangu Investment Inc.、Beijing Zenith Holdings Company Limited、Booming Sail New York LLC、Bravo Luck Limited、BSA Strategic Fund I、China Golden Spring (Hong Kong) Limited、Chuang Xin Limited、Crane Advisory Group LLC、Creative Apex Investments Limited、Crystal Breeze Investments Limited、Dawn State Limited、Eastern Profit Corporation Limited、Elite Well Global Limited、Empire Growth Holdings、Freedom Media Ventures Ltd.、G Club Operations LLC、G Fashion LLC、G News LLC、GETTR USA、Genever Holdings Corporation、Genever Holdings LLC、Gfashion Media Group Inc.、GFNY, Inc.、Globalist International Limited、GNews Media Group Inc.、Golden Spring (New York) Ltd.、Greenwich Land LLC、Guo Media、GTV Media Group, Inc.、Hamilton Capital Holdings Inc.、HCHK Property Management, Inc.、HCHK Technologies, Inc.、Head Win Group Limited、Henan Yuda、Himalaya Embassy、Himalaya Exchange、Himalaya Federal Reserve、Himalaya Investment LLC、Himalaya International、Himalaya New World Inc.、Himalaya Supervisory Organization、Himalaya Ventures LLC、HK International Funds Investments (USA) Limited LLC、Hong Kong International Funds\n\n案号 22-50073 文件 1592 提交日期 03/24/23 录入日期 03/24/23 10:57:37 第46页，共1063页\n\nInvestments Limited、Hudson Diamond Holding、Infinite Increase Limited、Infinitum Developments Limited、Infinity Treasury Management Inc.、Insight Phoenix Fund、Lamp Capital LLC、Leading Shine Limited、Leading Shine NY Limited、Lexington Property and Staffing、Long Gate Limited、Maywind Trading LLC、MOS Himalaya LLC、Next Tycoon Investments Limited、New Federal State of China（又名NFSC）、Noble Fame Global Limited、Rosy Acme Ventures Limited、Rule of Law Foundation III, Inc.、Rule of Law Foundation IV, Inc.、Rule of Law Fund、Rule of Law Society、Rule of Law Society IV, Inc.、G-Translators PTY LTD、Saraca Media Group, Inc.、Shiny Ace Ltd.、Shiny Times Holdings Ltd.、Spirit Charter Investment Limited、Stevenson, Wong & Co.、Voice of Guo Media, Inc.、Well Origin Ltd.、World Century Limited、Worldwide Opportunity Holdings Limited、Whitecroft Shore Limited及ZIBA Limited。\n\n9. “包括”或其任何变体，系指“包括但不限于”。\n\n10. “及”和“或”系指“及/或”，并应为最大限度扩大其范围而同时作连言及选言解释。\n\n11. “任何”和“所有”及“每一”均系指“每一个及全部”。\n\n12. “每一”和“每个”均系指“每一个及全部”。\n\n13. “第三方”系指除您以外的个人或实体。\n\n14. “转让”具有《破产法》第101(54)条赋予该词的含义。\n\n15. “文件”系指Fed. R. Civ. P. 34范围内的任何信息或物件，并包括但不限于处于或曾处于您占有、保管或控制之下的每一项任何种类、类型、性质或描述的书面、记录或图形资料，包括电子邮件的所有纸质及电子副本、以电子形式保存的计算机文件、电子通信、短信、社交媒体帖子、推文、元数据、通信函件、备忘录、磁带、速记或手写笔记、任何种类的书面表格、图表、蓝图、图纸、草图、曲线图、计划、文章、规格说明、日记、信函、电报、照片、会议记录、合同、协议、调查、计算机打印件、任何种类的数据汇编、电传、传真、语音留言、发票、订单、支票、汇票、对账单、贷项通知单、报告、持仓报告、摘要、索引、书籍、分类账簿、笔记本、时间表、透明片、录音、目录、广告、宣传材料、电影、录像带、录音带、CD、计算机磁盘、宣传册、小册子、穿孔卡、工时单、推文、社交媒体帖子或任何其他种类的书面或记录材料，以及其所有元数据；无论以何种方式储存（无论为有形形式或电子形式）、记录、制作或复制；并且还包括但不限于前述任何文件的草稿或副本，如其中包含原始文件上不存在的任何种类的笔记、评论或标记，或以其他方式与原始文件不完全相同。\n\n案号 22-50073 文件 1592 提交日期 03/24/23 录入日期 03/24/23 10:57:37 第47页，共1063页\n\n16. “个人”系指个人、公司、独资企业、合伙企业、协会或任何其他实体。“个人”还包括任何代理人、代表或专家，包括但不限于律师或财务顾问。\n\n17. “实体”系指任何自然人、公司、合伙企业、子公司、独资企业、商号、董事会、合资企业、协会、机构、主管机关、委员会或其他商业实体或法人，以及任何关联方、代理人、母公司，包括但不限于法律顾问、财务顾问或任何其他代表。\n\n18. “关于”系指涉及、描述、构成、提及、与之相关、支持、有利于、反对、加强、减损、位于其中、结合其予以考虑、与之有关、证明、表明、报告、记录、暗示、回应、\n\n案号 22-50073 文件 1592 提交日期 03/24/23 录入日期 03/24/23 10:57:37 第48页，共1063页\n\n与之连接、评论、就其而言、有关、与之相关、讨论、展示、描述、反映、分析、构成及属于。\n\n19. 就任何特定主题而言，“与……有关”“与……有关联”或“相关”，系指但不限于构成、包含、涉及、含有、体现、反映、识别、陈述、直接或间接提及，或以任何方式与所识别的特定主题相关的任何文件。\n\n20. “通信”系指以最广义且不限于此的方式传递任何信息或知识（以事实、观点、询问或其他形式）。通信还指所有谈话、协议、询问或答复，无论是当面、通过电话、以书面形式，还是借助电子传输设备进行，并包括但不限于所有通信函件、电子邮件、录音、传送单、备忘录、电话通信、语音留言、电报、传真、电传副本、电传、即时消息、聊天、短信、电话笔记或在内部或与第三方之间传送的笔记。\n\n21. “资产”系指可用于产生正经济价值的任何项目，包括但不限于由某一实体拥有、控制或为其利益而存在，并预期提供未来利益的任何具有经济价值的资源，包括但不限于所有不动产和动产、无形财产、投资、投资权或未来收益权、现金、银行账户、商品、证券、债权、对某一实体的全部或部分控制权，以及预期经济机会。\n\n22. “转让”具有《破产法》第101(54)条赋予该词的含义。\n\n案号 22-50073 文件 1592 提交日期 03/24/23 录入日期 03/24/23 10:57:37 第49页，共1063页\n\nIV. 应提交的文件\n\n1. 关于债务人、债务人财产或关联实体的任何收入或资产的所有文件。\n\n2. 与债务人的财务状况及其对债权人的义务有关的所有文件，包括但不限于与任何试图规避支付该等义务的行为有关的所有文件，以及与本次或任何其他实际或潜在破产程序或类似无力偿债程序有关的所有文件。\n\n3. 关于与债务人、债务人财产、债务人的家属、关联实体或关联个人有关的任何资产负债表、银行对账单、账户对账单、财务报表、账户报表、电汇指示及/或确认、资金证明、存款证明、持有证明、投资组合摘要或类似文件的所有文件，包括但不限于足以显示向前述任何主体进行的所有转让的所有文件。\n\n4. 关于由债务人作出、与债务人进行或代表债务人作出的任何投资、商业交易或交易事项的所有文件。\n\n5. 与债务人的所有通信，以及与债务人的通信有关、涉及任何实体（包括但不限于关联实体）的运营、管理或决策的文件。\n\n6. 关于向债务人、债务人的家属或关联实体作出、由其作出或与其进行的任何转让、投资或其他交易或商业往来的所有文件。\n\n7. 关于债务人曾占用或使用的任何财产的所有文件，包括但不限于Lady May；Sherry Netherland Hotel / Condominium；位于康涅狄格州格林尼治373 Taconic Rd.的住宅物业；位于康涅狄格州格林尼治33 Ferncliff Rd.的住宅物业；以及位于康涅狄格州威尔顿354 Nod Hill Rd.的住宅物业。\n\n8. 与债务人拥有、控制或使用的任何航空器有关的所有文件，包括但不限于尾号为 T7-GQM 的航空器以及在 San Marino（圣马力诺）登记的任何其他航空器，包括但不限于所有登记文件副本，以及显示该等航空器所执行航班及该等航班机上人员的飞行舱单。\n\n9. 关于向债务人、债务人的破产财产、债务人的家属或关联实体提供、从其获得或代表其提供的任何赠与、利益或贷款的所有文件，包括但不限于足以显示该等赠与、利益或贷款金额的文件；该等赠与、利益或贷款的用途；提供该等赠与、利益或贷款的时间；以及任何贷款的条款、就任何贷款作出的所有陈述和保证、任何贷款的利率以及任何贷款付款的全部证明。\n\n10. 关于由债务人、代表债务人或为债务人、债务人的破产财产、债务人的家属或关联实体的利益而设立的任何信托或类似文件的所有文件，包括但不限于足以显示信托设立时间、设立人、受益人及信托财产的文件。\n\n11. 与涉及债务人的任何法律争议相关的任何义务、请求权、责任或债务有关的所有文件，包括但不限于与任何地方、州、联邦或国际机构之前的任何诉讼有关的文件，无论该机构为行政机构、法院、合议庭或替代性争议解决实体。\n案号 22-50073 文件 1592 于 03/24/23 提交 于 03/24/23 10:57:37 录入 第 51 页，共 1063 页\n\n12. 您的任何外聘律师或其他顾问与债务人之间的所有文件及通信。\n\n13. 足以显示您的全部资产以及收入或资金来源的文件。\n\n14. 对于就第 14 项请求作出的答复中所识别、价值超过 $50,000 的所有资产，提供：(i) 与您取得该等资产有关的所有文件，以及 (ii) 您与债务人或债务人家属之间关于该等资产的通信。\n\n15. 您的纳税申报表副本。\n\n16. 足以显示您持有或控制的所有银行账户及投资账户的文件，包括各该账户的余额以及向该账户转入和从该账户转出的款项。\n\n17. 关于您使用的任何信用卡的所有文件，包括但不限于月度对账单或足以显示为债务人或关联实体利益而进行的与此相关全部购买的其他文件。\n\n18. 所有公司治理及组织文件，包括但不限于公司章程细则、公司设立证书，以及足以显示您的公司结构、高级职员及董事姓名、经营目的以及与债务人或债务人任何家属关系的其他文件。\n\n19. 与将您的任何资产质押给任何其他实体有关的所有文件。\n\n案号 22-50073 文件 1592 于 03/24/23 提交 于 03/24/23 10:57:37 录入 第 52 页，共 1063 页\n\n附件 C-2\n\nB2540（表格 2540——规则 2004 审查传票）（12/15）案号 22-50073 文件 1592 于 03/24/23 提交 于 03/24/23 10:57:37 录入 第 53 页，共 1063 页\n\nUNITED STATES BANKRUPTCY COURT（美国破产法院）\n\nDistrict of Connecticut（康涅狄格区）\n\n关于 HO WAN KWOK（郭文贵）等人，\n\n1 案号 22-50073 (JAM)\n\n债务人 第 11 章\n\n（联合管理）\n规则 2004 审查传票\n\n致：GFashion Media Group Inc.（GFashion传媒集团公司）\n\n（传票所指向人员的姓名）\n\n作证：兹命令您于下列规定的时间、日期和地点出席，根据《联邦破产程序规则》第 2004 条进行审查并作证。随附准许该审查的法院命令副本。\n\n地点　日期和时间\n\nPaul Hastings LLP（保罗·黑斯廷斯律师事务所）\n200 Park Avenue　[待定]\nNew York, New York 10166（纽约州纽约市 10166）\n\n审查将通过以下方式记录：法庭记录员/速记员\n\n提交材料：您或您的代表还必须携带下列文件、电子存储信息或物品参加审查，并必须允许对该等材料进行检查、复制、测试或取样：\n\n见随附的文件提交请求。\n\n《联邦民事诉讼规则》第 45 条的下列规定，依《联邦破产程序规则》第 9016 条适用于破产案件，现随附于后——关于履行地点的第 45(c) 条；关于作为传票对象人员之保护的第 45(d) 条；以及关于您回应本传票的义务和不回应可能后果的第 45(e) 条及第 45(g) 条。\n\n日期：2023 年 3 月\n\n法院书记员\n\n或\n\n书记员或副书记员签名　律师签名\n\n签发或请求签发本传票的、代表第 11 章受托人 Luc A. Despins（卢克·A·德斯平斯）的律师的姓名、地址、电子邮件地址和电话号码如下：\n\nDouglas S. Skalka, Esq.（道格拉斯·S·斯卡尔卡律师）；Neubert, Pepe & Monteith, P.C.（纽伯特、佩佩及蒙蒂思律师事务所）；195 Church Street, New Haven, Connecticut 06510；dskalka@npmlaw.com；(203) 821-2000\n\n致签发或请求签发本传票之人员的通知\n\n如本传票命令在审判前提交文件、电子存储信息或有形物品，或者检查场所，则必须在向传票所指向人员送达之前，向每一当事人送达通知及本传票副本。《联邦民事诉讼规则》第 45(a)(4) 条。\n\n软件版权 (c) 1996-2022 Best Case, LLC（贝斯特凯斯有限责任公司）- www.bestcase.com Best Case Bankruptcy（贝斯特凯斯破产软件） 1 本第 11 章案件中的债务人为 Ho Wan Kwok（郭文贵，亦称 Guo Wengui、Miles Guo 和 Miles Kwok，以及众多其他别名）（税务识别号码后四位：9595）、Genever Holdings LLC（税务识别号码后四位：8202）及 Genever Holdings Corporation。受托人、Genever Holdings LLC 及 Genever Holdings Corporation 的邮寄地址为：Paul Hastings LLP, 200 Park Avenue, New York, NY 10166，收件人为作为 Ho Wan Kwok 破产财产受托人的 Luc A. Despins（仅为通知及通信之目的）。\n\n送达证明\n\n（除非《联邦民事诉讼规则》第 45 条要求，否则本节不应向法院提交。）\n\n我于（日期）收到向（个人姓名及职务，如有）送达的本传票。\n\n我通过按以下方式向具名人员交付副本送达本传票：\n\n于（日期）；或\n\n我未执行即退还本传票，原因如下：\n\n除非本传票代表美国或其官员或代理人签发，我还已向证人支付一天出席费用及法律准许的里程费，金额为 $。\n\n我的差旅费用为 $，服务费用为 $，合计为 $。\n\n我在伪证处罚下声明，本信息真实且正确。\n\n日期：\n\n送达人员签名\n\n正楷姓名及职务\n\n送达人员地址\n\n关于尝试送达等的补充信息：\n\n《联邦民事诉讼规则》第 45(c)、(d)、(e) 及 (g) 条（自 12/1/13 起生效）（依《联邦破产程序规则》第 9016 条适用于破产案件）\n\n(c) 履行地点。\n\n(1) 审判、听证或证言记录。传票仅可按下列方式命令某人出席审判、听证或证言记录：\n\n(A) 在该人居住、受雇或经常亲自从事商业活动地点 100 英里范围内；或\n\n(B) 在该人居住、受雇或经常亲自从事商业活动所在州内，前提是该人：\n\n(i) 为当事人或当事人的高级职员；或\n\n(ii) 被命令出席审判且不会产生重大费用。\n\n(2) 其他证据开示。传票可以命令：\n\n(A) 在该人居住、受雇或经常亲自从事商业活动地点 100 英里范围内的地点提交文件、电子存储信息或物品；以及\n\n(B) 在待检查场所进行场所检查。\n\n(d) 对作为传票对象人员的保护；执行。\n\n(1) 避免不当负担或费用；制裁。负责签发及送达传票的当事人或律师必须采取合理措施，避免对作为传票对象的人员施加不当负担或费用。要求履行的地区法院必须执行该义务，并对未遵守该义务的当事人或律师施加适当制裁，该制裁可包括损失的收入和合理的律师费。\n\n(2) 命令提交材料或准许检查。\n\n(A) 无须出席。被命令提交文件、电子存储信息或有形物品，或准许检查场所的人员，无须亲自出席提交或检查地点，除非同时被命令出席证言记录、听证或审判。\n\n(B) 异议。被命令提交文件或有形物品，或准许检查的人员，可向传票中指定的当事人或律师送达书面异议，反对检查、复制、测试或取样任何或全部材料，或反对检查场所，或反对以所请求的一种或多种形式提交电子存储信息。异议必须于规定的履行时间之前或传票送达后 14 日之前（以较早者为准）送达。如提出异议，适用以下规则：\n\n(i) 送达方可随时通知被命令人员后，向要求履行的地区法院提出动议，请求作出强制提交或检查的命令。\n\n(ii) 仅可依命令指示要求实施该等行为，且该命令必须保护非当事人亦非当事人高级职员的人员免于承担因履行而产生的重大费用。\n\n(3) 撤销或修改传票。\n\n(A) 必须撤销或修改的情形。经及时动议，要求履行的地区法院必须撤销或修改以下传票：\n\n(i) 未留出合理履行时间；\n\n(ii) 要求某人在第 45(c) 条规定的地理范围之外履行；\n\n(iii) 在不适用例外或豁免的情况下，要求披露享有特权或受其他保护的事项；或\n\n(iv) 对某人施加不当负担。\n\n(B) 可以撤销或修改的情形。为保护作为传票对象或受传票影响的人员，要求履行的地区法院可经动议撤销或修改要求下列事项的传票：\n\n(i) 披露商业秘密或其他保密的研究、开发或商业信息；或\n\n(ii) 披露未受聘专家的意见或信息，该等意见或信息并非描述争议中的具体事件，且源于当事人未请求进行的该专家研究。\n\n(C) 以规定条件作为替代。在第 45(d)(3)(B) 条所述情形下，如送达方：\n\n(i) 证明对该证言或材料具有实质性需要，且不遭受不当困难即无法通过其他方式满足该需要；并且\n\n(ii) 确保被传唤人员将获得合理补偿，\n\n法院可不撤销或修改传票，而是命令在规定条件下出席或提交。\n\n(e) 回应传票的义务。\n\n(1) 提交文件或电子存储信息。下列程序适用于提交文件或电子存储信息：\n\n(A) 文件。回应要求提交文件的传票的人员，必须按该等文件在通常业务过程中保存的方式提交，或者将其整理并标注以对应请求中的类别。\n\n(B) 未规定电子存储信息的提交形式。如传票未规定提交电子存储信息的形式，回应人员必须以其通常保存的一种或多种形式，或以合理可用的一种或多种形式提交。\n\n(C) 电子存储信息仅以一种形式提交。回应人员无须以一种以上形式提交同一电子存储信息。\n\n(D) 无法电子访问的存储信息。作出回应的人无需就其认定因不当负担或费用而无法合理访问的来源中的电子存储信息提供证据开示。在提出强制证据开示动议或保护令动议时，作出回应的人必须证明该信息因不当负担或费用而无法合理访问。如作出该证明，若提出请求的一方在考虑第 26(b)(2)(C) 条的限制后证明存在正当理由，法院仍可命令对该等来源进行证据开示。法院可就该证据开示规定条件。\n\n(2) 主张特权或保护。\n\n(A) 被扣留的信息。依据该信息享有特权或受审判准备材料保护的主张而扣留被传唤信息的人必须：(i) 明确提出该主张；以及\n\n(ii) 以一种在不披露本身享有特权或受保护信息的情况下，使各方能够评估该主张的方式，描述被扣留文件、通信或有形物品的性质。\n\n(B) 已提供的信息。如为回应传票而提供的信息受特权主张或审判准备材料保护主张所约束，提出该主张的人可将该主张及其依据通知任何收到该信息的一方。收到通知后，一方必须立即返还、隔离或销毁所指定的信息及其持有的任何副本；在该主张得到解决前，不得使用或披露该信息；如该方在收到通知前已披露该信息，必须采取合理措施收回该信息；并可立即将该信息密封提交至要求履行义务所在地区的法院，以裁定该主张。提供该信息的人必须在该主张得到解决前保存该信息。\n\n(g) 蔑视法庭。要求履行义务所在地区的法院——以及在动议被移送后，发出传票的法院——可认定已被送达但无充分理由未遵从传票或与其相关命令的人构成蔑视法庭。\n\n关于获取传票材料，见 Fed.R.Civ.P.45(a) 委员会注释（2013）\n\n……\n\n文件提交请求\n\nI. 指示\n\n1. 除非另有说明，下列文件请求（以下简称“请求”，各称“一项请求”）必须分别且具体地作出回应。每项请求均应得到完整答复，除非善意提出异议；如提出异议，则应按如下所述详细说明贵方异议的理由。如异议仅涉及某项请求的一部分，或其中包含的某个词语、短语或条款，贵方仅须就该部分说明异议，并对其余请求作出回应。\n\n2. 电子存储信息必须依照下列指示提供：\n\na. 图像。黑白图像必须为 300 DPI Group IV 单页 TIFF 文件。彩色图像必须以 JPEG 格式提供。文件名不得包含嵌入空格或特殊字符（包括逗号）。文件夹名称不得包含嵌入空格或特殊字符（包括逗号）。所有 TIFF 图像文件必须具有唯一文件名，即 Bates 编号。每张图像右下角必须标注连续的 Bates 编号。每个文件夹中的 TIFF 文件不得超过 1000 个。Excel 电子表格应具有以该文件 Bates 编号命名的占位图像。\n\nb. 图像载入文件\n\na. Concordance® 数据文件。数据文件（.DAT）包含将载入 Concordance® 数据库的所有字段信息。.DAT 文件的第一行必须为标明字段名称的标题行。.DAT 文件必须使用以下 Concordance® 默认分隔符：逗号 ASCII 字符（020）；引号 þ ASCII 字符（254）。日期字段应采用以下格式：mm/dd/yyyy。日期和时间字段必须为两个独立字段。如文件包括已成像的电子邮件及附件，必须包含附件字段，以保留电子邮件与其附件之间的父项/子项关系。必须包含 OCRPATH 字段，以提供所提供存储介质上提取文本文件的文件路径及名称。文本文件必须以 FIRSTBATES 命名。不得将文本包含在 .DAT 文件中。对于含有原生文件的文件，必须包含 LINK 字段，以提供原生文件的文件路径及名称。原生文件必须以 FIRSTBATES 命名。\n\nb. Concordance Image® 或 Opticon 交叉引用文件。图像交叉引用文件（.LOG 或 .OPT）将图像链接至数据库记录。其应为逗号分隔文件，每行包含七个字段，并且数据库中每张图像均应在交叉引用文件中有一行，格式如下：ImageID,VolumeLabel,ImageFilePath,DocumentBreak,FolderBreak,Box Break,PageCoun。\n\nc. 文件文本。文本必须作为单独的文本文件提供，而非作为 .DAT 文件内的字段。文本文件的完整路径（OCRPATH）应包含在 .DAT 文件中。建议提供以 FIRSTBATES/Image Key 命名、文件级别的 ANSI 文本文件。提取的文本文件必须置于单独文件夹中，每个文件夹中的文本文件不得超过 1,000 个。文件夹名称中不得有特殊字符（包括逗号）。文本文件必须按文件级别提供。\n\nd. 特定文件类型的原生格式提供。为充分理解其内容和含义而合理需要以原生格式查看的文件类型，必须以原生格式提供。这些包括但不限于电子表格、类似电子表格的文件（Microsoft Excel、逗号分隔值、制表符分隔值等）、Microsoft PowerPoint 或其他特殊演示文件、数据库文件及音频/视频文件。应提供一张带 Bates 编号的分隔页图像，说明存在原生文件，并在 .dat 文件中将原生文件的路径作为字段列入。所提供的原生文件应以与该文件分隔页相对应的 Bates 编号命名。原生文件应按递增名称归入“NATIVE”目录，并与图像目录分开。\n\ne. 去重。对于存在完全重复件的每一电子文件，仅提供一份副本。对于电子邮件信息，应依据由 BCC、Body、CC、From、IntMsgID、To 和 Attach 属性生成的 MD5 哈希值合并重复件。对于电子邮件附件及独立电子文件，应依据整个文件的 MD5 哈希值合并重复件。\n\nf. 元数据。应以符合 Concordance 要求的载入文件（.dat）形式，提供每份文件的提取元数据。.DAT 文件的第一行必须为标明字段名称的标题行。.DAT 文件必须使用以下 Concordance 默认分隔符：逗号 , ASCII 字符（020）；引号 þ ASCII 字符（254）。\n\n日期字段应采用以下格式：mm/dd/yyyy。日期和时间字段必须为两个独立字段。以下为所需元数据：\n\nCase 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 58 of 1063\n\n字段名称　示例数据　说明\n\nFIRSTBATES　EDC0000001　原生文件文件/电子邮件的第一个 Bates 编号\n\nLASTBATES　EDC0000001　原生文件文件/电子邮件的最后一个 Bates 编号\n\n对于单页文件，应填写 LASTBATES 字段。\n\nATTACHRANGE　EDC0000001\n-　父项文件第一页的 Bates 编号至最后一个附件“子项”文件最后一页的 Bates 编号\nEDC0000015\n\nBEGATTACH　EDC0000001　附件范围的第一个 Bates 编号\n\nENDATTACH　EDC0000015　附件范围的最后一个 Bates 编号\n\nCUSTODIAN　Smith, John（约翰·史密斯）　电子邮件：电子邮件所在的邮箱\n原生文件：文件来源的个人或部门名称\n\nFROM　John Smith（约翰·史密斯）　电子邮件：发件人\n原生文件：文件作者\n多个条目应以分号分隔\n\nTO　Coffman, Janice（贾尼斯·科夫曼）；LeeW　收件人\n[mailto:LeeW@MSN.com]　多个条目应以分号分隔\n\nCC　Frank Thompson（弗兰克·汤普森）[mailto:　抄送收件人\nfrank_Thompson@cdt.com]　多个条目应以分号分隔\n\nBCC　John Cain（约翰·凯恩）　密送收件人\n多个条目应以分号分隔\n\nSUBJECT　Board Meeting Minutes　电子邮件：电子邮件主题行；原生文件：文件标题（如有）\n\nFILE_NAME　BoardMeetingMinutes.docx　原生文件：原始原生文件名称，包括扩展名\n\nDATE_SENT　10/12/2010　电子邮件：电子邮件发送日期\n原生文件：（空）\n\nTIME_SENT/\nTIME_ZONE　07:05 PM GMT　电子邮件：电子邮件发送时间/电子邮件标准化所采用的时区\n\nTIME_ZONE　GMT　在转换期间电子邮件标准化所采用的时区。\n\nLINK　EDC0000001.msg　电子邮件或原生文件文件的超链接\n链接文件必须以 FIRSTBATES 编号命名\n\nFILE_EXTEN　MSG　代表电子邮件或原生文件的文件类型扩展名\n\nAUTHOR　John Smith　电子邮件：（空）\n原生文件：文件作者\n\nDATE_CREATED　10/10/2010　电子邮件：（空）\n原生文件：文件创建日期\n\nCase 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 59 of 1063\n\nTIME_CREATED　10:25 AM　电子邮件：（空）\n原生文件：文件创建时间\n该数据必须为独立字段，不得与 DATE_CREATED 字段合并\n\nDATE_MOD　10/12/2010　电子邮件：（空）\n原生文件：文件最后修改日期\n\nTIME_MOD　07:00 PM　电子邮件：（空）\n原生文件：文件最后修改时间\n该数据必须为独立字段，不得与 DATE_MOD 字段合并\n\nDATE_ACCESSD　10/12/2010　电子邮件：（空）\n原生文件：文件最后访问日期\n\nTIME_ACCESSD　07:00 PM　电子邮件：（空）\n原生文件：文件最后访问时间\n该数据必须为独立字段，不得与 DATE_ACCESSD 字段合并\n\nFILE_SIZE　5,952　原生文件文件/电子邮件的大小，以 KB 为单位\n\nPGCOUNT　1　原生文件文件/电子邮件中的页数\n\nPATH　电子邮件：（空）\nAgenda.doc　原生文件：原生文件文件的存储路径，包括原始文件名。\n\nINTFILEPATH　Personal Folders\\Deleted　电子邮件：电子邮件的原始位置，包括原始文件名。\nItems\\Board Meeting　原生文件：（空）\nMinutes.msg\n\nINTMSGID　<000805c2c71b\\$75977050\\$　电子邮件：唯一信息 ID；原生文件：（空）\ncb8306d1@MSN>\n\nMD5HASH　d131dd02c5e6eec4693d9a0　文件的 MD5 哈希值。\n698aff95c\n2fcab58712467eab4004583e\nb8fb7f89\n\nOCRPATH　TEXT/001/EDC0000001.txt　原生文件提取文本的路径\n\n3. 每项请求独立运作并应独立解释，除非另有说明，任何请求均不限制任何其他请求的范围。\n\n4. 所有文件应按日常业务过程中保存的方式提供，或者应加以组织和标记，以对应于这些请求中的类别。\n\n5. 本文所载每项请求延及所有文件：(a) 在贵方占有、保管或控制之下的文件；或 (b) 在任何代表贵方行事之人占有、保管或控制之下的文件，\n\nCase 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 60 of 1063\n\n包括贵方律师或其他代表及顾问。每份文件均应完整提供。\n\n6. 如要求贵方提供一份已不再由贵方占有、保管或控制的文件，则贵方的答复必须：(a) 详细说明该文件的性质及其内容；(b) 指明编制或撰写该文件的人员（以及，如适用，文件发送对象）；(c) 指明该文件编制或形成的日期；(d) 说明该文件是否：(i) 下落不明或遗失，(ii) 已被销毁，(iii) 已自愿或非自愿地转移给他人，或 (iv) 以其他方式处置；(e) 说明该等处置的理由以及与之有关的事实和情形；(f) 指明授权该等处置的人员；(g) 指明该等处置的日期或大致日期；(h) 说明该文件最后一次由贵方占有、保管或控制的时间；以及 (i) 指明目前占有、保管或控制该文件的人员（如有）。\n\n7. 如要求贵方提供一份已被销毁的文件，则除前项指示所要求的信息外，贵方的答复还必须说明：(a) 销毁该文件的理由；(b) 销毁该文件的人员身份；以及 (c) 指示销毁该文件的人员身份。\n\n8. 如贵方主张所要求的文件享有特权或属于律师工作成果，则贵方的答复必须：(a) 说明：(i) 足以支持贵方关于该文件享有特权之主张的文件描述，(ii) 文件标题，(iii) 文件日期，(iv) 文件作者，(v) 文件收件人，(vi) 收到或阅览该文件原件或任何草稿、副本或复制件的每一人员身份，(vii) 该文件本身或其中包含或提及的任何信息是否由任何其他人员占有、保管或控制；如是，则说明该等人员的身份，以及说明该信息如何进入其占有范围，(viii) 据以拒绝提供该文件的特权主张，以及 (ix) 贵方将据以支持该等特权主张的全部情形；以及 (b) 就依据 D. Conn. L. Civ. R. 26(e) 的特权主张而拒绝提供的每份文件，制作一份特权日志，其中载明本指示第 (a) 部分所要求的全部信息。\n\n案号 22-50073 文书 1592 于 03/24/23 提交 于 03/24/23 10:57:37 登记 第 61 页，共 1063 页\n\n9. 如一份原本应予答复的文件的一部分含有受特权主张约束的信息，则仅应按照上述指示从该文件中删除或遮蔽受该特权主张约束的部分，其余部分应予提供。\n\n10. 本文件请求具有持续性。现指示贵方：(a) 一旦得知先前答复不完整或不正确，应立即补充或更正任何后来发现不完整或不正确的答复；以及 (b) 提供根据该等请求所要求的任何额外文件。\n\n11. 如文件使用英语以外的语言，贵方应提供该文件。如文件使用英语以外的语言且存在英文译本，贵方应同时提供两份文件。\n\n12. 对实体的所有提述均包括其所有关联方。\n\n13. 对个人姓名的所有提述均包括所有其他姓名、别名或昵称。\n\n14. 除非另有明确说明，文件请求所涵盖的期间为自 February 5, 2012 起至文件请求答复到期之日止。\n\n案号 22-50073 文书 1592 于 03/24/23 提交 于 03/24/23 10:57:37 登记 第 62 页，共 1063 页\n\nII. 解释规则\n\n15. (a) 任何单数名词的使用应解释为包括复数，反之亦然；以及 (b) 任何时态动词的使用应解释为该动词所有其他时态的使用。\n\n16. (a) “和”及“或”应根据需要解释为连词关系或选择关系，以使任何请求的范围涵盖本可能被解释为在其范围之外的所有答复；以及 (b) “每一”及“任何”应视为包括并涵盖“每一个”及“所有”二词。\n\nIII. 定义\n\n经 D. Conn. Bankr. L.R. 2004-1(a) 纳入的 D. Conn. L. Civ. R. 26(c) 所提供的定义及 D. Conn. L. Civ. R. 26(d) 所提供的解释规则，应适用于文件请求。此外，本文件请求中使用的下列术语具有下列含义：\n\n1. “贵方”或“贵方的”或“贵方自身”系指 GFashion Media Group Inc.（郭媒体时尚集团公司），连同其所有关联方、部门、机构、工具机构、处室、办事处、合伙人、高级职员、董事、代理人、律师、代表、雇员和／或任何代表其行事之人。\n\n2. “债务人”系指 Ho Wan Kwok（郭文贵）（又名 Miles Kwok、Miles Guo、Guo Wengui、Guo Haoyun、郭文贵，或任何其他别名），连同其雇员、代理人、法律顾问、顾问或任何代表其行事之人。\n\n3. “债务人之子”系指 Qiang Guo（郭强）（又名 Mileson Kwok、郭强，或任何其他别名），连同其雇员、代理人、法律顾问、顾问或任何代表其行事之人。\n\n案号 22-50073 文书 1592 于 03/24/23 提交 于 03/24/23 10:57:37 登记 第 63 页，共 1063 页\n\n4. “债务人之女”系指 Mei Guo（郭美）（又名 Mei Gui、郭美，或任何其他别名），连同其雇员、代理人、法律顾问、顾问或任何代表其行事之人。\n\n5. “债务人所谓的妻子”系指 Hing Chi Ngok（岳庆芝）（又名 Hing Chi Ng、Yue Qingzhi、岳庆芝，或任何其他别名），连同其雇员、代理人、法律顾问、顾问或任何代表其行事之人。\n\n6. “债务人家属”统称债务人、债务人之子、债务人之女及债务人所谓的妻子，以及与债务人存在任何其他家庭关系之人。\n\n7. “关联个人”系指单独及共同符合下列情形的所有个人：(1) 持有、控制、保管或对债务人或债务人家属所拥有、控制或享有的资产具有处置权；或 (2) 曾为一个或多个关联实体的雇员、董事，或以其他方式与一个或多个关联实体有关联；并包括前述各方各自的雇员、代理人、法律顾问、顾问或任何代表前述任何一方行事之人。该等关联个人包括但不限于：Daniel Podhaskie（丹尼尔·波德哈斯基）、Jason Miller（杰森·米勒）、Steve Bannon（史蒂夫·班农）、Karin Maistrello（卡琳·梅斯特雷洛）、Melissa Francis（梅利莎·弗朗西斯）、Anthony DiBattista（安东尼·迪巴蒂斯塔）、William Gertz（威廉·格茨）、Arethusa Forsyth（阿瑞图莎·福赛思）、Glenn Mellor（格伦·梅勒）、Jennifer Mercurio（詹妮弗·默库里奥）、Eduardo Eurnekian（爱德华多·厄内基安）、Wencong Wang（王文聪）、Han Chunguang（韩春光）（又名 韩春光）、Qu Guojiao（屈国姣）（又名 Qu Guo Jiao、屈国姣）、Guo Lijie（郭丽杰）（又名 郭丽杰）、Zhang Wei（张伟）（又名 张伟*）、Lihong Wei Lafrenz（魏丽红）（又名 Sara Wei、魏丽红）、Hao Haidong（郝海东）（又名 郝海东）、Ross Heinemeyer（罗斯·海内迈耶）、Max Krasner（马克斯·克拉斯纳）、Kyle Bass（凯尔·巴斯）、Melissa Mendez（梅利莎·门德斯）、Ya Li（李娅）（又名 李娅）、Dinggang Wang（王定刚）（又名 王定刚）、An Hong（安红）（又名 安红）、Yvette Wang（王雁平）（又名 Yanping Wang、Yan Ping Wang、王雁平）、Fiona Yu（菲奥娜·余）、Je Kin Ming（余建明）（又名 William Je、Yu Jianming、余建明）、Yaz Qingua（亚兹·钦瓜）及 Lao Jiang（姜云浮）（又名 Jiang Yunfu、Jiang Yunfu Be、姜云浮）。\n\n案号 22-50073 文书 1592 于 03/24/23 提交 于 03/24/23 10:57:37 登记 第 64 页，共 1063 页\n\n8. “关联实体”系指单独及共同符合下列情形的所有任何类型组织或实体：(1) 曾由债务人或债务人家属拥有、控制或投资；或 (2) 对债务人或债务人家属所拥有、控制或享有的任何资产直接或间接享有权益；并包括前述各方各自的雇员、代理人、法律顾问、顾问或任何代表前述任何一方行事之人。该等关联实体包括但不限于：7 Nod Hill LLC（七诺德山有限责任公司）、AAGV Limited（AAGV有限公司）、ACA Investment Management Limited（ACA投资管理有限公司）、ACA Capital Group Limited（ACA资本集团有限公司）、Ace Decade Holdings Limited（艾斯十年控股有限公司）、AI Group Holdings Inc.（AI集团控股公司）、Alfa Global Ventures Limited（阿尔法全球风险投资有限公司）、Alfonso Global Limited（阿方索全球有限公司）、Allied Capital Global Limited（联合资本全球有限公司）、Alpine Fiduciaries SA（阿尔卑斯受托人股份公司）、Anton Development Limited（安东发展有限公司）、Assets Sino Limited（中资资产有限公司）、Auspicious Coast Limited（吉祥海岸有限公司）、Beijing Pangu Investment Co.（北京盘古投资公司）、Beijing Pangu Investment Co. Ltd.（北京盘古投资有限公司）、Beijing Pangu Investment Inc.（北京盘古投资股份有限公司）、Beijing Zenith Holdings Company Limited（北京鼎峰控股有限公司）、Booming Sail New York LLC（纽约兴帆有限责任公司）、Bravo Luck Limited（好运有限公司）、BSA Strategic Fund I（BSA战略基金I）、China Golden Spring (Hong Kong) Limited（中国金泉〈香港〉有限公司）、Chuang Xin Limited（创新有限公司）、Crane Advisory Group LLC（鹤顾问集团有限责任公司）、Creative Apex Investments Limited（创意顶峰投资有限公司）、Crystal Breeze Investments Limited（水晶微风投资有限公司）、Dawn State Limited（黎明州有限公司）、Eastern Profit Corporation Limited（东方利润有限公司）、Elite Well Global Limited（精英环球有限公司）、Empire Growth Holdings（帝国增长控股）、Freedom Media Ventures Ltd.（自由媒体风险投资有限公司）、G Club Operations LLC（G俱乐部运营有限责任公司）、G News LLC（G新闻有限责任公司）、GETTR USA（GETTR美国）、Genever Holdings Corporation（Genever控股公司）、Genever Holdings LLC（Genever控股有限责任公司）、GFNY, Inc.（GFNY公司）、Globalist International Limited（全球主义者国际有限公司）、GNews Media Group Inc.（GNews媒体集团公司）、Golden Spring (New York) Ltd.（金泉〈纽约〉有限公司）、Greenwich Land LLC（格林尼治土地有限责任公司）、Guo Media（郭媒体）、GTV Media Group, Inc.（GTV媒体集团公司）、Hamilton Capital Holdings Inc.（汉密尔顿资本控股公司）、HCHK Property Management, Inc.（HCHK物业管理公司）、HCHK Technologies, Inc.（HCHK科技公司）、Head Win Group Limited（首胜集团有限公司）、Henan Yuda（河南裕达）、Himalaya Embassy（喜马拉雅大使馆）、Himalaya Exchange（喜马拉雅交易所）、Himalaya Federal Reserve（喜马拉雅联邦储备）、Himalaya Investment LLC（喜马拉雅投资有限责任公司）、Himalaya International（喜马拉雅国际）、Himalaya New World Inc.（喜马拉雅新世界公司）、Himalaya Supervisory Organization（喜马拉雅监督组织）、Himalaya Ventures LLC（喜马拉雅风险投资有限责任公司）、HK International Funds Investments (USA) Limited LLC（香港国际基金投资〈美国〉有限责任公司）、Hong Kong International Funds Investments Limited（香港国际基金投资有限公司）、Hudson Diamond Holding（哈德逊钻石控股）、\n\n案号 22-50073 文书 1592 于 03/24/23 提交 于 03/24/23 10:57:37 登记 第 65 页，共 1063 页\n\nInfinite Increase Limited（无限增长有限公司）、Infinitum Developments Limited（无限发展有限公司）、Infinity Treasury Management Inc.（无限财资管理公司）、Insight Phoenix Fund（洞察凤凰基金）、Lamp Capital LLC（灯资本有限责任公司）、Leading Shine Limited（领耀有限公司）、Leading Shine NY Limited（领耀纽约有限公司）、Lexington Property and Staffing（列克星敦物业及人力服务）、Long Gate Limited（长龙门有限公司）、Maywind Trading LLC（五月风贸易有限责任公司）、MOS Himalaya LLC（MOS喜马拉雅有限责任公司）、Next Tycoon Investments Limited（下一大亨投资有限公司）、New Federal State of China（中国新联邦国）（又名 NFSC）、Noble Fame Global Limited（全球显赫有限公司）、Rosy Acme Ventures Limited（玫瑰顶峰风险投资有限公司）、Rule of Law Foundation III, Inc.（法治基金会III公司）、Rule of Law Foundation IV, Inc.（法治基金会IV公司）、Rule of Law Fund（法治基金）、Rule of Law Society（法治协会）、Rule of Law Society IV, Inc.（法治协会IV公司）、G-Translators PTY LTD（G翻译员有限公司）、Saraca Media Group, Inc.（无忧树媒体集团公司）、Shiny Ace Ltd.（闪耀王牌有限公司）、Shiny Times Holdings Ltd.（闪耀时代控股有限公司）、Spirit Charter Investment Limited（精神宪章投资有限公司）、Stevenson, Wong & Co.（史蒂文森、黄及公司）、Voice of Guo Media, Inc.（郭媒体之声公司）、Well Origin Ltd.（良源有限公司）、World Century Limited（世界世纪有限公司）、Worldwide Opportunity Holdings Limited（全球机遇控股有限公司）、Whitecroft Shore Limited（白克罗夫特海岸有限公司）及 ZIBA Limited（ZIBA有限公司）。\n\n9. “包括”或其任何变体，意为“包括但不限于”。\n\n10. “和”及“或”意为“和／或”，并应同时解释为连词关系及选择关系，以最大限度扩大其范围。\n\n11. “任何”、“所有”及“每一”意为“每一个”。\n\n12. “每一”及“每个”意为“每一个”。\n\n13. “第三方”系指贵方以外的人员或实体。\n\n14. “转移”具有《破产法典》第 101(54) 条赋予该词的含义。\n\n15. “文件”系指属于 Fed. R. Civ. P. 34 范围内的任何信息或物品，并包括但不限于任何种类、类型、性质或描述的每一书面、记录或图示材料，只要该等材料现由或曾由贵方占有、保管或控制，包括电子邮件的所有印刷件和电子副本、保存在计算机文件中的所有印刷件和电子副本。\n\n案号 22-50073 文书 1592 于 03/24/23 提交 于 03/24/23 10:57:37 登记 第 66 页，共 1063 页\n\n电子形式、电子通信、短信、社交媒体帖子、推文、元数据、通信函件、备忘录、磁带、速记或手写笔记、任何种类的书面表格、图表、蓝图、图纸、草图、曲线图、计划、文章、规格说明书、日记、信件、电报、照片、会议记录、合同、协议、调查报告、计算机打印件、任何种类的数据汇编、电传、电传传真、语音留言、发票、订购单、支票、汇票、对账单、贷项通知单、报告、立场报告、摘要、索引、书籍、分类账、笔记本、时间表、投影片、录音、目录、广告、宣传材料、电影、录像带、录音带、CD、计算机磁盘、宣传册、小册子、穿孔卡、工时单、推文、社交媒体帖子或任何其他种类的书面或记录材料，以及其所有元数据，无论以何种方式存储（无论为有形形式或电子形式）、记录、制作或复制，亦包括但不限于前述任何文件的草稿或副本，如该等草稿或副本包含原始文件中未见的任何种类的注释、评论或标记，或在其他方面与原始文件不一致。\n\n16. “人”系指个人、公司、独资企业、合伙企业、协会或任何其他实体。“人”还包括任何代理人、代表或专家，包括但不限于律师或财务顾问。\n\n17. “实体”系指任何自然人、公司、合伙企业、子公司、独资企业、商号、董事会、合资企业、协会、机构、主管机关、委员会或其他商业实体或法人，以及任何关联方、代理人、母公司，包括但不限于法律顾问、财务顾问或任何其他代表。\n\n18. “关于”系指涉及、描述、组成、提及、与之相关、支持、赞成、反对、加强、减损、位于、结合考虑、影响、证明、表明、报告、记录、暗指、回应、\n\n案号 22-50073 文件 1592 提交于 03/24/23 录入于 03/24/23 10:57:37 第 67 页，共 1063 页\n\n与之相连、评论、就其而言、有关、与之相关、讨论、展示、描述、反映、分析、构成及属于。\n\n19. “与……有关”、“涉及”或“相关”，在提及任何特定主题事项时，系指但不限于构成、组成、涉及、包含、体现、反映、识别、陈述、直接或间接提及该特定主题事项，或以任何方式与该特定主题事项相关的任何文书。\n\n20. “通信”系指在最广泛可能意义上且不限于任何信息或知识的传递（以事实、观点、询问或其他形式）。通信还指所有面谈、协议、询问或回复，无论是当面、通过电话、以书面形式，还是通过电子传输设备，并包括但不限于所有通信函件、电子邮件、录音、传送单、备忘录、电话通信、语音留言、电报、电传传真、复印传真、电传、即时消息、聊天记录、短信、电话笔记或与内部人员或第三方传送的笔记。\n\n21. “资产”系指可用于产生正面经济价值的任何项目，包括但不限于由某一实体拥有、控制或为其利益而持有的、预期将提供未来利益的任何具有经济价值的资源，包括但不限于所有不动产和动产、无形财产、投资、投资权或未来收入权、现金、银行账户、商品、证券、债权、对某一实体的全部或部分控制权，以及预期经济机会。\n\n22. “转让”应具有《破产法》第101(54)条赋予该术语的含义。\n\n案号 22-50073 文件 1592 提交于 03/24/23 录入于 03/24/23 10:57:37 第 68 页，共 1063 页\n\nIV. 应提交的文书\n\n1. 关于债务人、债务人财产或关联实体的任何收入或资产的所有文书。\n\n2. 与债务人的财务状况及其对债权人的义务有关的所有文书，包括但不限于与任何试图避免支付该等义务的行为有关的所有文书，以及与本次或任何其他实际或潜在破产或类似无力偿债程序有关的所有文书。\n\n3. 关于与债务人、债务人财产、债务人家庭成员、关联实体或关联个人有关的任何资产负债表、银行对账单、账户结单、财务报表、账户报表、电汇指示和/或确认书、资金证明、存款证、持仓证明、投资组合摘要或类似文书的所有文书，包括但不限于足以显示向前述任何一方作出的所有转让的所有文书。\n\n4. 关于由债务人作出、与债务人作出或代表债务人作出的任何投资、商业交易或交易事项的所有文书。\n\n5. 与债务人之间的所有通信，以及与债务人之间的通信有关的文书，涉及任何实体的运营、管理或决策，包括但不限于关联实体。\n\n6. 关于向债务人、债务人家庭成员或关联实体作出、由其作出或与其进行的任何转让、投资或其他交易或商业往来的所有文书。\n\n7. 关于债务人曾占用或使用的任何财产的所有文书，包括但不限于 Lady May；Sherry Netherland Hotel / Condominium；位于康涅狄格州格林尼治市 373 Taconic Rd. 的住宅物业；位于康涅狄格州格林尼治市 33 Ferncliff Rd. 的住宅物业；以及位于康涅狄格州威尔顿市 354 Nod Hill Rd. 的住宅物业。\n\n案号 22-50073 文件 1592 提交于 03/24/23 录入于 03/24/23 10:57:37 第 69 页，共 1063 页\n\n8. 与债务人拥有、控制或使用的任何航空器有关的所有文书，包括但不限于尾号为 T7-GQM 的航空器及在圣马力诺注册的任何其他航空器，包括但不限于所有登记文件副本以及显示该等航空器所执行航班和该等航班上乘员的飞行清单。\n\n9. 关于向债务人、债务人财产、债务人家庭成员或关联实体提供、由其提供或代表其提供的任何赠与、利益或贷款的所有文书，包括但不限于足以显示该等赠与、利益或贷款的金额；该等赠与、利益或贷款的使用目的；提供该等赠与、利益或贷款的时间；以及任何贷款的条款、就任何贷款作出的所有陈述与保证、任何贷款的利率及任何贷款付款的所有证据的文书。\n\n10. 关于由债务人、债务人财产、债务人家庭成员或关联实体设立、代表其设立或为其利益设立的任何信托或类似工具的所有文书，包括但不限于足以显示该等信托设立时间、设立人、为谁的利益设立以及信托本金的文书。\n\n11. 与涉及债务人的任何法律争议相关的任何义务、债权、责任或债务有关的所有文书，包括但不限于与任何地方、州、联邦或国际机构（无论为行政机构、法院、合议庭或替代性争议解决实体）前的任何诉讼有关的文书。\n\n案号 22-50073 文件 1592 提交于 03/24/23 录入于 03/24/23 10:57:37 第 70 页，共 1063 页\n\n12. 您的任何外部法律顾问或其他顾问与债务人之间的所有文书和通信。\n\n13. 足以显示您的所有资产以及收入或资金来源的文书。\n\n14. 对于就第14项请求作出的答复中确认的、价值超过 \\$50,000 的所有资产，提交：(i) 与您取得该等资产有关的所有文书；以及 (ii) 您与债务人或债务人家庭成员就该等资产进行的通信。\n\n15. 您的纳税申报表副本。\n\n16. 足以显示由您持有或控制的所有银行账户和投资账户的文书，包括每一该等账户的余额以及向该等账户转入和从该等账户转出的款项。\n\n17. 关于您使用的任何信用卡的所有文书，包括但不限于月度结单或足以显示为债务人或关联实体利益而进行的与其有关的所有购买的其他文书。\n\n18. 所有公司治理及组织文书，包括但不限于章程细则和公司注册证书，以及足以显示您的公司结构、高级职员和董事姓名、经营目的及与债务人或债务人家庭任何成员之间关系的其他文书。\n\n19. 与将您的任何资产质押给任何其他实体有关的所有文书。\n\n案号 22-50073 文件 1592 提交于 03/24/23 录入于 03/24/23 10:57:37 第 71 页，共 1063 页\n\n附件 C-3\n\nB2540（表格 2540－规则 2004 审查传票）（12/15）案号 22-50073 文件 1592 提交于 03/24/23 录入于 03/24/23 10:57:37 第 72 页，共\n\n美国破产法院 1063\n\n康涅狄格州联邦地区\n\n关于 HO WAN KWOK（郭文贵）等人，\n\n1 案号 22-50073 (JAM)\n\n债务人 第11章\n\n（合并管理）\n规则 2004 审查传票\n\n致：G Translators Pty Ltd（G翻译有限公司）\n\n（传票指向人员的姓名）\n\n证言：现命令您于下列规定的时间、日期和地点出席，并根据《联邦破产程序规则》第2004条接受审查并作证。随附准许进行该审查的法院命令副本。\n\n地点　日期和时间\n\nPaul Hastings LLP（保罗·黑斯廷斯律师事务所）\n200 Park Avenue　[TBD]\nNew York, New York 10166\n\n审查将通过以下方式记录：法庭记录员/速记员\n\n提交：您或您的代表还必须携带下列文书、电子存储信息或物品参加审查，并必须允许对该等材料进行检查、复制、测试或取样：\n见随附的文书提交请求。\n\n《联邦民事诉讼规则》第45条的下列规定，经《联邦破产程序规则》第9016条适用于破产案件，现随附于此——关于履行地点的第45(c)条；关于您作为受传票约束人员所受保护的第45(d)条；以及关于您对本传票作出回应的义务及未作出回应可能后果的第45(e)条和第45(g)条。\n\n日期：2023年3月\n\n法院书记员\n\n或\n\n书记员或副书记员签名　律师签名\n\n代表发出或请求本传票的第11章受托人 Luc A. Despins（卢克·A·德斯平斯）的律师姓名、地址、电子邮件地址和电话号码如下：\n\nDouglas S. Skalka, Esq.（道格拉斯·S·斯卡尔卡，律师）；Neubert, Pepe & Monteith, P.C.（纽伯特、佩佩和蒙蒂斯律师事务所）；195 Church Street, New Haven, Connecticut 06510；dskalka@npmlaw.com；(203) 821-2000\n\n致发出或请求本传票之人员的通知\n\n如本传票命令在审判前提交文书、电子存储信息或有形物品，或检查场所，则必须在向传票指向人员送达之前，向每一方当事人送达通知及本传票副本。《联邦民事诉讼规则》第45(a)(4)条。\n\n软件版权 (c) 1996-2022 Best Case, LLC - www.bestcase.com Best Case Bankruptcy 1 本第11章案件中的债务人为 Ho Wan Kwok（郭文贵，亦称 Guo Wengui、Miles Guo 和 Miles Kwok，以及其他多个别名）（税务识别号末四位：9595）、Genever Holdings LLC（Genever Holdings有限责任公司）（税务识别号末四位：8202）及 Genever Holdings Corporation（Genever Holdings股份有限公司）。受托人、Genever Holdings LLC 和 Genever Holdings Corporation 的邮寄地址为 Paul Hastings LLP（保罗·黑斯廷斯律师事务所）, 200 Park Avenue, New York, NY 10166，c/o Luc A. Despins，作为 Ho Wan Kwok 财产的受托人（仅为通知和通信之目的）。\n\n送达证明\n\n（除非 Fed. R. Civ. P. 45 要求，否则本节不得向法院提交。）\n\n我于（日期）收到向以下人员（个人姓名及职务，如有）送达的本传票：\n\n我通过如下方式向被指定人员交付副本，完成本传票的送达：\n\n于（日期）；或\n\n我未予执行而退回本传票，原因为：\n\n除非本传票系代表美国或其官员或代理人签发，我还已向证人支付一天的出席费用及法律允许的里程费用，金额为 \\$ 。\n\n我的差旅费用为 \\$ ，服务费用为 \\$ ，合计 \\$ 。\n\n我在伪证处罚的约束下声明，本信息真实且准确。\n\n日期：\n\n送达人签名\n\n正楷姓名及职务\n\n送达人地址\n\n关于尝试送达等事项的补充信息：\n《联邦民事诉讼规则》第45(c)、(d)、(e)及(g)条（2013年12月1日生效）（依据《联邦破产程序规则》第9016条适用于破产案件）\n(c) 履行地点。\n\n(1) 审判、听证或证言录取。传票仅可在下列情形命令某人出席审判、听证或证言录取：\n\n(A) 在该人居住、受雇或经常亲自从事营业之地100英里以内；或\n\n(B) 在该人居住、受雇或经常亲自从事营业所在州内，且该人\n\n(i) 是当事人或当事人的高级职员；或\n\n(ii) 被命令出席审判且不会产生重大费用。\n\n(2) 其他证据开示。传票可以命令：\n\n(A) 在该人居住、受雇或经常亲自从事营业之地100英里以内的地点提交文件、电子存储信息或物品；以及\n\n(B) 在拟检查的场所检查该场所。\n(d) 保护受传票约束者；执行。\n\n(1) 避免不当负担或费用；制裁。负责签发和送达传票的当事人或律师必须采取合理措施，避免对受传票约束者施加不当负担或费用。要求履行的地区法院必须执行该义务，并对未遵守该义务的当事人或律师施加适当制裁，包括损失的收入和合理的律师费。\n\n(2) 命令提交材料或允许检查。\n\n(A) 无须出席。被命令提交文件、电子存储信息或有形物品，或允许检查场所的人，无须亲自到提交或检查地点出席，除非还被命令出席证言录取、听证或审判。\n\n(B) 异议。被命令提交文件或有形物品，或允许检查的人，可以向传票中指定的当事人或律师送达书面异议，反对检查、复制、测试或抽样任何或全部材料，或反对检查场所，或反对以所请求的一种或多种形式提交电子存储信息。异议必须在规定的履行时间届满前或传票送达后14日内（以较早者为准）送达。提出异议后，适用下列规则：\n\n(i) 送达人可在任何时候通知被命令人后，向要求履行的地区法院提出动议，请求作出强制提交或检查的命令。\n\n(ii) 仅可依命令所指示要求实施该等行为，且该命令必须保护并非当事人或当事人高级职员的人免受因履行而产生的重大费用。\n\n(3) 撤销或修改传票。\n\n(A) 必须撤销或修改的情形。经及时动议，要求履行的地区法院必须撤销或修改具有下列情形的传票：\n\n(i) 未给予合理的履行时间；\n\n(ii) 要求某人在第45(c)条规定的地域范围以外履行；\n\n(iii) 要求披露享有特权或受其他保护的事项，且不存在适用的例外或豁免；或\n\n(iv) 对某人施加不当负担。\n\n(B) 可以撤销或修改的情形。为保护受传票约束或受传票影响的人，要求履行的地区法院可经动议撤销或修改要求下列事项的传票：\n\n(i) 披露商业秘密或其他保密的研究、开发或商业信息；或\n\n(ii) 披露未经聘用的专家的意见或信息，该等意见或信息并未描述争议中的具体事件，且系该专家并非应当事人请求而进行的研究所得。\n\n(C) 以规定条件作为替代。在第45(d)(3)(B)条所述情形下，如送达方：\n\n(i) 证明其对该证言或材料具有重大需要，且不承受不当困难即无法通过其他方式满足该需要；并且\n\n(ii) 确保被传唤者将获得合理补偿，\n\n法院可以不撤销或修改传票，而命令在规定条件下出席或提交。\n(e) 回应传票的义务。\n\n(1) 提交文件或电子存储信息。下列程序适用于提交文件或电子存储信息：\n\n(A) 文件。响应提交文件传票的人，必须按照文件在正常业务过程中保存的方式提交文件，或者必须对文件进行整理和标注，使之对应于请求中的类别。\n\n(B) 未规定电子存储信息的提交形式。如传票未规定电子存储信息的提交形式，响应人必须以其通常保存的一种或多种形式，或以一种或多种合理可用的形式提交。\n\n(C) 电子存储信息仅以一种形式提交。响应人无须以一种以上形式提交相同的电子存储信息。\n\n(D) 无法合理获取的电子存储信息。响应人无须就其认定因不当负担或费用而无法合理获取的来源中的电子存储信息提供证据开示。对于强制证据开示或保护令的动议，响应人必须证明该信息因不当负担或费用而无法合理获取。如作出该证明，法院在考虑第26(b)(2)(C)条的限制后，如请求方证明具有正当理由，仍可命令从该等来源进行证据开示。法院可为该证据开示规定条件。\n\n(2) 主张特权或保护。\n\n(A) 扣留的信息。以享有特权或作为审判准备材料受到保护为由扣留被传唤信息的人必须：(i) 明确提出该主张；以及\n\n(ii) 在不披露本身享有特权或受保护的信息的情况下，以足以使当事人评估该主张的方式说明被扣留文件、通信或有形物品的性质。\n\n(B) 已提交的信息。如为响应传票而提交的信息受特权主张或审判准备材料保护主张约束，提出该主张的人可以通知任何收到该信息的当事人该主张及其依据。收到通知后，当事人必须立即返还、隔离或销毁指定信息及其持有的任何副本；在该主张得到解决前不得使用或披露该信息；如该当事人在收到通知前已披露该信息，必须采取合理措施取回该信息；并可立即将该信息密封提交给要求履行的地区法院，以裁定该主张。提交该信息的人必须在该主张得到解决前保存该信息。\n\n(g) 藐视法庭。要求履行的地区法院，以及在动议移送后签发传票的法院，均可认定已被送达但无充分理由不遵守传票或相关命令的人构成藐视法庭。\n\n有关查阅传票材料，请参见 Fed.R.Civ.P.45(a) 委员会说明（2013年）\n\n……\n\n文件提交请求\nI. 指示\n\n1. 除非另有说明，下列文件请求（“请求”，每一项均称为“一项请求”）必须分别且具体地作出回应。除非贵方善意提出异议，否则必须对每项请求作出完整答复；如提出异议，则必须按如下规定详细说明贵方异议的理由。如异议仅涉及某项请求的一部分，或其中所含的一个词语、短语或条款，贵方仅须说明对该部分的异议，并对其余请求作出回应。\n\n2. 电子存储信息必须依照下列指示提交：\n\na. 图像。黑白图像必须为300 DPI的 Group IV 单页 TIFF 文件。彩色图像必须以 JPEG 格式提交。文件名不得含有嵌入空格或特殊字符（包括逗号）。文件夹名称不得含有嵌入空格或特殊字符（包括逗号）。所有 TIFF 图像文件必须具有唯一的文件名，即 Bates 编号。每张图像的右下角必须标注连续的 Bates 编号。每个文件夹中的 TIFF 文件数量不应超过1000个文件。Excel 电子表格应具有一个以该文件 Bates 编号命名的占位图像。\n\nb. 图像加载文件\n\na. Concordance® 数据文件。数据文件（.DAT）包含将被加载到 Concordance® 数据库中的所有分字段信息。.DAT 文件的第一行必须为标明字段名称的标题行。.DAT 文件必须使用以下 Concordance® 默认分隔符：逗号 ASCII 字符（020）引号 þ ASCII 字符（254）。日期字段应以以下格式提供：mm/dd/yyyy。日期字段和时间字段必须为两个独立字段。如文件包括已制成图像的电子邮件及附件，必须包括附件字段，以保留电子邮件与其附件之间的父/子关系。必须包括 OCRPATH 字段，以提供所提交存储介质上提取文本文件的文件路径和名称。文本文件必须以 FIRSTBATES 命名。不得在 .DAT 文件中包含文本。对于具有原生文件的文件，必须包括 LINK 字段，以提供原生文件的文件路径和名称。原生文件必须以 FIRSTBATES 命名。\n\nb. Concordance Image® 或 Opticon 交叉引用文件。图像交叉引用文件（.LOG 或 .OPT）将图像链接至数据库记录。该文件应为逗号分隔文件，每行包含七个字段，且数据库中的每张图像均应在交叉引用文件中对应一行，格式如下：ImageID,VolumeLabel,ImageFilePath,DocumentBreak,FolderBreak,Box Break,PageCoun。\n\nc. 文档文本。文本必须作为单独的文本文件提供，而不得作为 .DAT 文件中的字段提供。文本文件的完整路径（OCRPATH）应包含在 .DAT 文件中。建议提供文档级 ANSI 文本文件，并按照 FIRSTBATES/Image Key 命名。提取的文本文件必须置于单独文件夹中，每个文件夹中的文本文件数量不得超过 1,000 个。文件夹名称中不得包含特殊字符（包括逗号）。文本文件必须按文档级别提供。\n\nd. 特定文件类型的原生格式提供。为充分理解其内容和含义而合理需要以原生格式查看的文件类型，必须以原生格式提供。这些文件包括但不限于：电子表格、类似电子表格的文件（Microsoft Excel、逗号分隔值、制表符分隔值等）、Microsoft PowerPoint 或其他特殊演示文件、数据库文件以及音频/视频文件。应提供一张带有 Bates 编号的插页图像，表明存在原生文件，并将原生文件的路径作为 .dat 文件中的一个字段。所提供的原生文件应以与该文件插页相对应的 Bates 编号命名。原生文件应归入按递增方式命名的“NATIVE”目录中，并与图像目录分开。\n\ne. 去重。对于存在完全重复件的每份电子文档，仅提供一份副本。对于电子邮件，应根据由 BCC、Body、CC、From、IntMsgID、To 和 Attach 属性生成的 MD5 哈希值合并重复件。对于电子邮件附件和独立电子文件，应根据整个文件的 MD5 哈希值合并重复件。\n\nf. 元数据。应以符合 Concordance 要求的加载文件（.dat）形式提供每份文档的提取元数据。 .DAT 文件的第一行必须为标明字段名称的标题行。 .DAT 文件必须使用以下 Concordance 默认分隔符：逗号 , ASCII 字符（020） 引号 þ ASCII 字符（254）\n\n日期字段应采用以下格式提供：mm/dd/yyyy。日期和时间字段必须为两个独立字段。下列为必填元数据：\nCase 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 77 of 1063\n\n字段名称　示例数据　说明\n\nFIRSTBATES　EDC0000001　原生文件文档/电子邮件的第一个 Bates 编号\nLASTBATES　EDC0000001　原生文件文档/电子邮件的最后一个 Bates 编号\nLASTBATES 字段应针对单页填写\nATTACHRANGE　EDC0000001\n-　父文档第一页的 Bates 编号至最后一个附件“子”文档最后一页的 Bates 编号\nEDC0000015\nBEGATTACH　EDC0000001　附件范围的第一个 Bates 编号\nENDATTACH　EDC0000015　附件范围的最后一个 Bates 编号\nCUSTODIAN　Smith, John　电子邮件：该电子邮件所在的邮箱\n原生文件：文档来源文件所属个人或部门的名称\nFROM　John Smith　电子邮件：发件人\n原生文件：文档作者\n多个条目应以分号分隔\nTO　Coffman, Janice; LeeW　收件人\n[mailto:LeeW@MSN.com]　多个条目应以分号分隔\nCC　Frank Thompson [mailto:　抄送收件人\nfrank_Thompson@cdt.com]　多个条目应以分号分隔\nBCC　John Cain　密送收件人\n多个条目应以分号分隔\nSUBJECT　Board Meeting Minutes　电子邮件：电子邮件主题行 原生文件：文档标题（如有）\nFILE_NAME　BoardMeetingMinutes.docx　原生文件：原始原生文件名称，包括扩展名\nDATE_SENT　10/12/2010　电子邮件：电子邮件发送日期\n原生文件：（空）\nTIME_SENT/　07:05 PM GMT　电子邮件：电子邮件发送时间/电子邮件标准化时所采用的时区\nTIME_ZONE\nTIME_ZONE　GMT　在转换过程中电子邮件被标准化所采用的时区。\nLINK　EDC0000001.msg　电子邮件或原生文件文档的超链接\n链接文件必须按照 FIRSTBATES 编号命名\nFILE_EXTEN　MSG　代表电子邮件或原生文件文档的文件类型扩展名\nAUTHOR　John Smith　电子邮件：（空）\n原生文件：文档作者\nDATE_CREATED　10/10/2010　电子邮件：（空）\n原生文件：文档创建日期\nCase 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 78 of 1063\n\nTIME_CREATED　10:25 AM　电子邮件：（空）\n\n原生文件：文档创建时间\n该数据必须为独立字段，且不得与 DATE_CREATED 字段合并\nDATE_MOD　10/12/2010　电子邮件：（空）\n原生文件：文档最后修改日期\nTIME_MOD　07:00 PM　电子邮件：（空）\n原生文件：文档最后修改时间\n该数据必须为独立字段，且不得与 DATE_MOD 字段合并\n\nDATE_ACCESSD　10/12/2010　电子邮件：（空）\n原生文件：文档最后访问日期\nTIME_ACCESSD　07:00 PM　电子邮件：（空）\n原生文件：文档最后访问时间\n该数据必须为独立字段，且不得与 DATE_ACCESSD 字段合并\nFILE_SIZE　5,952　原生文件文档/电子邮件的大小，单位为 KB\nPGCOUNT　1　原生文件文档/电子邮件的页数\nPATH　电子邮件：（空）\nAgenda.doc　原生文件：存储原生文件文档的路径，包括原始文件名称。\nINTFILEPATH　Personal Folders\\Deleted　电子邮件：电子邮件的原始位置，包括原始文件名称。\nItems\\Board Meeting\nMinutes.msg　原生文件：（空）\nINTMSGID　<000805c2c71b\\$75977050\\$　电子邮件：唯一邮件 ID 原生文件：（空）\ncb8306d1@MSN>\nMD5HASH　d131dd02c5e6eec4693d9a0　文档的 MD5 哈希值。\n698aff95c\n2fcab58712467eab4004583e\nb8fb7f89\nOCRPATH　TEXT/001/EDC0000001.txt　原生文件提取文本的路径\n\n3. 各项请求独立适用并应独立解释，除非另有说明，任何一项请求均不限制任何其他请求的范围。\n\n4. 所有文档均应按其在正常业务过程中保存的方式提供，或者应进行组织和标记，以对应本请求中的类别。\n\n5. 本文所载各项请求均延及下列所有文档：（a）由您占有、保管或控制的文档；或（b）由代表您行事的任何人占有、保管或控制的文档，\nCase 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 79 of 1063\n\n包括您的律师或其他代表及顾问。每份文档均应完整提供。\n\n6. 如要求您提供已不再由您占有、保管或控制的文档，则您的答复必须：（a）详细描述该文档的性质及其内容；（b）确定编制或撰写该文档的人员（以及，如适用，向其发送该文档的人员）；（c）确定该文档编制或创建的日期；（d）说明该文档是否（i）遗失或丢失，（ii）已被销毁，（iii）自愿或非自愿地转交他人，或（iv）以其他方式处置；（e）说明该等处置的理由，以及围绕该等处置的事实和情形；（f）确定授权该等处置的人员；（g）确定该等处置的日期或大致日期；（h）说明该文档最近一次由您占有、保管或控制的时间；以及（i）确定当前占有、保管或控制该文档的人员（如有）。\n\n7. 如要求您提供已被销毁的文档，则除前述指示所要求的信息外，您的答复还必须说明：（a）销毁该文档的理由；（b）销毁该文档的人员身份；以及（c）指示销毁该文档的人员身份。\n\n8. 如您主张所请求的文档享有特权或属于律师工作成果，则您的答复必须：（a）说明：（i）足以支持您关于该文档享有特权之主张的文档描述；（ii）文档标题；（iii）文档日期；（iv）文档作者；（v）文档收件人；（vi）收到或阅览该文档原件或任何草稿、副本或复制件的每一人员身份；（vii）该文档本身，或文档中所含或所提及的任何信息，是否由任何其他人员占有、保管或控制，如是，则应确定该等人员身份，\nCase 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 80 of 1063\n\n并说明该等信息如何为其占有；（viii）据以扣留该文档的特权主张；以及（ix）您将据以支持该等特权主张的一切情形；以及（b）根据 D. Conn. L. Civ. R. 26(e)，就每份基于特权主张而扣留的文档，制作一份特权日志，其中包含本指示第（a）部分所要求的全部信息。\n\n9. 如一份原本应提供的文档中有部分包含受特权主张约束的信息，则仅应依照上述指示从该文档中删除或涂黑受特权主张约束的部分，其余部分应予提供。\n\n10. 本请求具有持续性。特此指示您：（a）一经得知先前答复不完整或不正确，立即补充或更正后来得知不完整或不正确的任何答复；以及（b）提供根据本请求所要求的任何补充文档。\n\n11. 如文档使用英语以外的语言，您应提供该文档。如文档使用英语以外的语言，且存在英文译本，您应同时提供两份文档。\n\n12. 对实体的所有提述均包括其所有关联方。\n\n13. 对个人姓名的所有提述均包括所有其他名称、别名或昵称。\n\n14. 除非另有明确说明，文档请求所涵盖的期间为自 February 5, 2012 起至文档请求答复到期之日止。\nCase 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 81 of 1063\n\nII. 解释规则\n\n15. （a）任何单数名词的使用均应解释为包括复数，反之亦然；以及（b）任何时态动词的使用均应解释为该动词在所有其他时态下的使用。\n\n16. （a）“and”和“or”应在必要时解释为连词或析取词，以使本应被解释为不在任何请求范围内的所有答复均纳入该请求范围；以及（b）“each”和“any”应视为包括并涵盖“every”和“all”二词。\n\nIII. 定义\n\n经 D. Conn. Bankr. L.R. 2004-1(a) 纳入的 D. Conn. L. Civ. R. 26(c) 所提供的定义以及 D. Conn. L. Civ. R. 26(d) 所提供的解释规则，适用于文档请求。此外，本文件请求中使用的下列术语具有以下含义：\n\n1. “您”或“您的”或“您本人”是指并包括 G Translators Pty Ltd，以及其所有关联方、分部、机构、工具部门、部门、办事处、合伙人、高级职员、董事、代理人、律师、代表、雇员，和/或任何代表其行事之人。\n\n2. “债务人”是指 Ho Wan Kwok（郭文贵）（又名 Miles Kwok、Miles Guo、Guo Wengui、Guo Haoyun、郭文贵，或任何其他别名），以及其雇员、代理人、律师、顾问或任何代表其行事之人。\n\n3. “债务人之子”系指 Qiang Guo（又名 Mileson Kwok、郭强或任何其他别名），以及其雇员、代理人、律师、顾问或代表其行事的任何人。\n案件 22-50073 文件 1592 提交于 03/24/23 录入于 03/24/23 10:57:37 第 82 页，共 1063 页\n\n4. “债务人之女”系指 Mei Guo（又名 Mei Gui、郭美或任何其他别名），以及其雇员、代理人、律师、顾问或代表其行事的任何人。\n\n5. “债务人之名义妻子”系指 Hing Chi Ngok（又名 Hing Chi Ng、Yue Qingzhi、岳庆芝或任何其他别名），以及其雇员、代理人、律师、顾问或代表其行事的任何人。\n\n6. “债务人家属”统称债务人、债务人之子、债务人之女及债务人之名义妻子，以及与债务人具有任何其他亲属关系的人。\n\n7. “关联个人”单独及共同指：(1) 持有、控制、保管对债务人或债务人家属拥有、控制或享有的资产，或对该等资产拥有处置权的所有个人；或 (2) 曾为一个或多个关联实体的雇员、董事，或以其他方式与其有关联的所有个人，以及前述各方各自的雇员、代理人、律师、顾问或代表前述任何一方行事的任何人。该等关联个人包括但不限于：Daniel Podhaskie、Jason Miller、Steve Bannon、Karin Maistrello、Melissa Francis、Anthony DiBattista、William Gertz、Arethusa Forsyth、Glenn Mellor、Jennifer Mercurio、Eduardo Eurnekian、Wencong Wang、Han Chunguang（又名韩春光）、Qu Guojiao（又名 Qu Guo Jiao、屈国姣）、Guo Lijie（又名郭丽杰）、Zhang Wei（又名张伟*）、Lihong Wei Lafrenz（又名 Sara Wei、魏丽红）、Hao Haidong（又名郝海东）、Ross Heinemeyer、Max Krasner、Kyle Bass、Melissa Mendez、Ya Li（又名李娅）、Dinggang Wang（又名王定刚）、An Hong（又名安红）、Yvette Wang（又名 Yanping Wang、Yan Ping Wang、王雁平）、Fiona Yu、Je Kin Ming（又名 William Je、Yu Jianming、余建明）、Yaz Qingua，以及 Lao Jiang（又名 Jiang Yunfu、Jiang Yunfu Be、姜云浮）。\n案件 22-50073 文件 1592 提交于 03/24/23 录入于 03/24/23 10:57:37 第 83 页，共 1063 页\n\n8. “关联实体”单独及共同指：(1) 曾由债务人或债务人家属拥有、控制或投资的所有各种类型组织或实体；或 (2) 对债务人或债务人家属拥有、控制或享有的任何资产直接或间接拥有权益的所有各种类型组织或实体，以及前述各方各自的雇员、代理人、律师、顾问或代表前述任何一方行事的任何人。该等关联实体包括但不限于：7 Nod Hill LLC、AAGV Limited、ACA Investment Management Limited、ACA Capital Group Limited、Ace Decade Holdings Limited、AI Group Holdings Inc.、Alfa Global Ventures Limited、Alfonso Global Limited、Allied Capital Global Limited、Alpine Fiduciaries SA、Anton Development Limited、Assets Sino Limited、Auspicious Coast Limited、Beijing Pangu Investment Co.、Beijing Pangu Investment Co. Ltd.、Beijing Pangu Investment Inc.、Beijing Zenith Holdings Company Limited、Booming Sail New York LLC、Bravo Luck Limited、BSA Strategic Fund I、China Golden Spring (Hong Kong) Limited、Chuang Xin Limited、Crane Advisory Group LLC、Creative Apex Investments Limited、Crystal Breeze Investments Limited、Dawn State Limited、Eastern Profit Corporation Limited、Elite Well Global Limited、Empire Growth Holdings、Freedom Media Ventures Ltd.、G Club Operations LLC、G News LLC、GETTR USA、Genever Holdings Corporation、Genever Holdings LLC、GFNY, Inc.、Globalist International Limited、GNews Media Group Inc.、Golden Spring (New York) Ltd.、Greenwich Land LLC、Guo Media、GTV Media Group, Inc.、Hamilton Capital Holdings Inc.、HCHK Property Management, Inc.、HCHK Technologies, Inc.、Head Win Group Limited、Henan Yuda、Himalaya Embassy、Himalaya Exchange、Himalaya Federal Reserve、Himalaya Investment LLC、Himalaya International、Himalaya New World Inc.、Himalaya Supervisory Organization、Himalaya Ventures LLC、HK International Funds Investments (USA) Limited LLC、Hong Kong International Funds Investments Limited、Hudson Diamond Holding，\n案件 22-50073 文件 1592 提交于 03/24/23 录入于 03/24/23 10:57:37 第 84 页，共 1063 页\n\nInfinite Increase Limited、Infinitum Developments Limited、Infinity Treasury Management Inc.、Insight Phoenix Fund、Lamp Capital LLC、Leading Shine Limited、Leading Shine NY Limited、Lexington Property and Staffing、Long Gate Limited、Maywind Trading LLC、MOS Himalaya LLC、Next Tycoon Investments Limited、New Federal State of China（又名 NFSC）、Noble Fame Global Limited、Rosy Acme Ventures Limited、Rule of Law Foundation III, Inc.、Rule of Law Foundation IV, Inc.、Rule of Law Fund、Rule of Law Society、Rule of Law Society IV, Inc.、Saraca Media Group, Inc.、Shiny Ace Ltd.、Shiny Times Holdings Ltd.、Spirit Charter Investment Limited、Stevenson, Wong & Co.、Voice of Guo Media, Inc.、Well Origin Ltd.、World Century Limited、Worldwide Opportunity Holdings Limited、Whitecroft Shore Limited，以及 ZIBA Limited。\n\n9. “包括”或其任何变体，系指“包括但不限于”。\n\n10. “和”及“或”系指“和/或”，并应为最大限度扩大其范围而同时按连词及选择连词解释。\n\n11. “任何”及“所有”及“每一”系指“每一个及全部”。\n\n12. “每一”及“每个”系指“每一个及全部”。\n\n13. “第三方”系指除您之外的个人或实体。\n\n14. “转让”应具有《破产法典》第 101(54) 条赋予其的含义。\n\n15. “文件”系指属于 Fed. R. Civ. P. 34 范围内的任何信息或物品，并包括但不限于在您的占有、保管或控制之下或曾在您的占有、保管或控制之下的任何种类、类型、性质或描述的每一份书面、记录或图形材料，包括电子邮件的所有打印及电子副本、以电子形式保存的计算机文件、电子通信、短信、社交媒体帖子、推文、元数据、\n案件 22-50073 文件 1592 提交于 03/24/23 录入于 03/24/23 10:57:37 第 85 页，共 1063 页\n\n通信函件、备忘录、磁带、速记或手写笔记、任何种类的书面表格、图表、蓝图、图纸、草图、曲线图、计划、文章、规格说明、日记、信函、电报、照片、会议记录、合同、协议、调查、计算机打印输出、任何种类的数据汇编、电传、电传传真、语音留言、发票、订单表格、支票、汇票、对账单、贷项通知单、报告、职位报告、摘要、索引、书籍、总账、笔记本、明细表、透明胶片、录音、目录、广告、宣传材料、电影、录像带、录音带、CD、计算机磁盘、小册子、传单、穿孔卡、工时单、推文、社交媒体帖子或任何其他种类的书面或记录材料，以及其所有元数据，无论以何种方式储存（无论为有形形式或电子形式）、记录、制作或复制；还包括但不限于前述任何材料的草稿或副本，若该等草稿或副本载有原始文件中未出现的任何种类笔记、评论或标记，或在其他方面与原始文件不完全相同。\n\n16. “个人”系指个人、公司、独资企业、合伙企业、协会或任何其他实体。“个人”还包括任何代理人、代表或专家，包括但不限于律师或财务顾问。\n\n17. “实体”系指任何自然人、公司、合伙企业、子公司、独资企业、商号、委员会、合资企业、协会、机构、主管机关、委员会或其他商业实体或法人，以及任何关联方、代理人、母公司，包括但不限于法律顾问、财务顾问或任何其他代表。\n\n18. “关于”系指涉及、描述、构成、提及、与之相关、支持、赞成、反对、加强、减损、位于其中、结合其加以考虑、与之有关、证明、表明、报告、记录、暗示、答复、\n案件 22-50073 文件 1592 提交于 03/24/23 录入于 03/24/23 10:57:37 第 86 页，共 1063 页\n\n与之相连、评论、就其而言、有关、与之相关、讨论、显示、描述、反映、分析、构成及属于。\n\n19. 就任何特定主题而言，“与……有关”、“与……有关联”或“相关于”系指，包括但不限于，构成、包含、涉及、载有、体现、反映、识别、陈述、直接或间接提及该特定主题，或以任何方式与所识别的特定主题相关的任何文件。\n\n20. “通信”系指以最广泛可能的意义且不限于任何形式的任何信息或知识传递（以事实、观点、询问或其他形式）。通信还指所有面谈、协议、询问或答复，无论是当面、通过电话、书面方式，还是通过电子传输设备进行，并包括但不限于所有函件、电子邮件、录音、传送单、备忘录、电话通信、语音留言、电报、电话传真、传真件、电传、即时消息、聊天、短信、电话笔记或在内部或与第三方传送的笔记。\n\n21. “资产”系指任何可用于产生正向经济价值的项目，包括但不限于由某一实体拥有、控制或为其利益而持有并预期将提供未来利益的任何具有经济价值的资源，包括但不限于所有不动产和动产、无形财产、投资、投资权或未来收入权、现金、银行账户、商品、证券、债权、对某一实体的全部或部分控制权，以及预期经济机会。\n\n22. “转让”应具有《破产法典》第 101(54) 条赋予其的含义。\n案件 22-50073 文件 1592 提交于 03/24/23 录入于 03/24/23 10:57:37 第 87 页，共 1063 页\n\nIV. 应提交的文件\n\n1. 关于债务人、债务人财产或关联实体的任何收入或资产的所有文件。\n\n2. 与债务人的财务状况及其对债权人所负义务有关的所有文件，包括但不限于与任何规避支付该等义务的努力有关的所有文件，以及与本案或任何其他实际或潜在破产或类似无力偿债程序有关的所有文件。\n\n3. 关于与债务人、债务人财产、债务人家属、关联实体或关联个人有关的任何资产负债表、银行对账单、账户对账单、财务报表、账户报表、电汇指示和/或确认、资金证明、存款证、持有证明、投资组合摘要或类似文件的所有文件，包括但不限于足以显示向前述任何一方作出的所有转让的所有文件。\n\n4. 关于债务人作出、与债务人进行或代表债务人进行的任何投资、业务往来或交易的所有文件。\n\n5. 与债务人的所有通信，以及与债务人的通信有关、涉及任何实体（包括但不限于关联实体）的运营、管理或决策的文件。\n\n6. 关于向债务人、债务人家属或关联实体作出、由其作出或与其进行的任何转让、投资或其他交易或业务往来的所有文件。\n\n7. 关于债务人曾占用或使用过的任何财产的所有文件，包括但不限于 Lady May；Sherry Netherland Hotel / Condominium；位于康涅狄格州格林尼治 373 Taconic Rd. 的住宅物业；位于康涅狄格州格林尼治 33 Ferncliff Rd. 的住宅物业；以及位于康涅狄格州威尔顿 354 Nod Hill Rd. 的住宅物业。\n\n8. 与债务人拥有、控制或使用的任何飞机有关的所有文件，包括但不限于尾号为 T7-GQM 的飞机以及在圣马力诺登记的任何其他飞机，包括但不限于所有登记文件副本及显示该等飞机所执行航班和该等航班机上人员的飞行清单。\n\n9. 关于向债务人、债务人遗产、债务人家属或关联实体提供、由其提供或代表其提供的任何赠与、利益或贷款的所有文件，包括但不限于足以显示该等赠与、利益或贷款金额的文件；该等赠与、利益或贷款的用途；提供该等赠与、利益或贷款的时间；以及任何贷款的条款、就任何贷款作出的所有陈述与保证、任何贷款的利率，以及任何贷款的全部付款证据。\n\n10. 关于由债务人、代表债务人或为债务人利益，或由、代表或为债务人遗产、债务人家属或关联实体的利益而设立的任何信托或类似文书的所有文件，包括但不限于足以显示信托设立时间、设立人、受益人及信托本金的文件。\n\n11. 与涉及债务人的任何法律争议有关的任何义务、请求权、责任或债务相关的所有文件，包括但不限于与在任何地方、州、联邦或国际机构（无论为行政机构、法院、合议机构或替代性争议解决实体）进行的任何诉讼有关的文件。\n案号 22-50073 文件 1592 提交于 03/24/23 录入于 03/24/23 10:57:37 第 89 页，共 1063 页\n\n12. 您的任何外聘律师或其他顾问与债务人之间的所有文件及通信。\n\n13. 足以显示您的全部资产以及收入或资金来源的文件。\n\n14. 对于就第14项请求所识别的、价值超过 $50,000 的所有资产，提供：(i) 与您取得该等资产有关的所有文件；以及 (ii) 与债务人或债务人家属就该等资产进行的通信。\n\n15. 您的纳税申报表副本。\n\n16. 足以显示由您持有或控制的所有银行账户及投资账户的文件，包括每一该等账户的余额及转入和转出款项。\n\n17. 关于您使用的任何信用卡的所有文件，包括但不限于月度对账单或足以显示为债务人或关联实体利益而进行的与此相关的所有购买的其他文件。\n\n18. 所有公司治理及组织文件，包括但不限于章程细则、公司注册证书，以及足以显示您的公司结构、高级管理人员和董事姓名、经营目的及与债务人或债务人任何家属之关系的其他文件。\n\n19. 与您向任何其他实体质押您的资产有关的所有文件。\n\n案号 22-50073 文件 1592 提交于 03/24/23 录入于 03/24/23 10:57:37 第 90 页，共 1063 页\n附件 C-4\nB2540（表格 2540——依据规则 2004 进行审查的传票）（12/15）案号 22-50073 文件 1592 提交于 03/24/23 录入于 03/24/23 10:57:37 第 91 页，共\n\n美国破产法院 1063\n\n康涅狄格地区\n\n关于 HO WAN KWOK（郭文贵）等人，\n\n1 案号 22-50073 (JAM)\n\n债务人 第11章\n\n（合并管理）\n依据规则 2004 进行审查的传票\n\n致：Martha Jeffery（玛莎·杰弗里）\n\n（传票所针对人员的姓名）\n\n证言：兹命令您于下列规定的时间、日期和地点出席，并根据《联邦破产程序规则》规则 2004 接受审查并作证。随附准许该审查的法院命令副本。\n\n地点　日期和时间\n\nPaul Hastings LLP\n200 Park Avenue　[TBD]\nNew York, New York 10166\n\n审查将通过以下方式记录：法庭记录员/速记员\n\n提交：您或您的代表还必须携带下列文件、电子存储信息或物品参加审查，并必须允许对该等材料进行检查、复制、测试或抽样：\n见随附的文件提交请求。\n\n根据《联邦破产程序规则》规则 9016 适用于破产案件的《联邦民事诉讼规则》规则 45 的下列规定随附于此——关于履行地点的规则 45(c)；关于您作为受传票约束人员之保护的规则 45(d)；以及关于您回应本传票之义务和未履行该义务可能后果的规则 45(e) 和 45(g)。\n\n日期：March , 2023\n\n法院书记官\n\n或\n\n书记官或副书记官签名　律师签名\n\n代表发出或申请本传票的第11章受托人 Luc A. Despins（卢克·A·德斯平斯）的律师姓名、地址、电子邮件地址及电话号码如下：\n\nDouglas S. Skalka, Esq.（道格拉斯·S·斯卡尔卡律师）；Neubert, Pepe & Monteith, P.C.；195 Church Street, New Haven, Connecticut 06510 dskalka@npmlaw.com；(203) 821-2000\n\n致发出或申请本传票之人的通知\n\n如本传票命令在审判前提交文件、电子存储信息或有形物品，或检查场所，则必须在向传票所指向人员送达之前，向每一方当事人送达通知和本传票副本。《联邦民事诉讼规则》规则 45(a)(4)。\n\n软件版权 (c) 1996-2022 Best Case, LLC - www.bestcase.com Best Case Bankruptcy 1 本第11章案件中的债务人为 Ho Wan Kwok（郭文贵）（亦称 Guo Wengui、Miles Guo 和 Miles Kwok，以及众多其他别名）（税务识别号码后四位：9595）、Genever Holdings LLC（税务识别号码后四位：8202）及 Genever Holdings Corporation。受托人、Genever Holdings LLC 和 Genever Holdings Corporation 的邮寄地址为 Paul Hastings LLP, 200 Park Avenue, New York, NY 10166，转交 Luc A. Despins，作为 Ho Wan Kwok 遗产受托人（仅为通知和通信之目的）。\n\n送达证明\n\n（除非《联邦民事诉讼规则》规则 45 要求，否则本节不应向法院提交。）\n\n我于（日期）收到向（个人姓名及职务，如有）送达的本传票。\n\n我按如下方式将副本交付给被指名人员，以送达本传票：\n\n于（日期）；或\n\n我未执行本传票即予退回，原因如下：\n\n除非本传票系代表美国或其官员或代理人发出，我还已向证人支付一天出席费用及法律允许的里程费，金额为 $ 。\n\n我的差旅费用为 $，服务费用为 $，合计为 $。\n\n我依伪证处罚之责声明，该等信息真实且正确。\n\n日期：\n\n送达人员签名\n\n正楷姓名及职务\n\n送达人员地址\n\n关于尝试送达等事项的附加信息：\n《联邦民事诉讼规则》规则 45(c)、(d)、(e) 和 (g)（自 12/1/13 起生效）（依据《联邦破产程序规则》规则 9016 适用于破产案件）\n(c) 履行地点。\n\n(1) 审判、听证或证言录取。传票仅可按下列方式命令人员出席审判、听证或证言录取：\n\n(A) 在该人员居住、受雇或经常亲自办理业务地点的 100 英里范围内；或\n\n(B) 在该人员居住、受雇或经常亲自办理业务所在州内，若该人员\n\n(i) 是一方当事人或一方当事人的高级职员；或\n\n(ii) 被命令出席审判且不会产生重大费用。\n\n(2) 其他证据开示。传票可命令：\n\n(A) 在该人员居住、受雇或经常亲自办理业务地点的 100 英里范围内的地点提交文件、电子存储信息或物品；以及\n\n(B) 在拟检查的场所对其进行检查。\n(d) 对受传票约束人员的保护；执行。\n\n(1) 避免不当负担或费用；制裁。负责发出和送达传票的一方当事人或律师必须采取合理措施，以避免对受传票约束人员施加不当负担或费用。要求履行义务所在地区的法院必须执行该义务，并对未遵守者的一方当事人或律师施加适当制裁，该制裁可包括损失的收入及合理的律师费。\n\n(2) 命令提交材料或允许检查。\n\n(A) 无须出席。被命令提交文件、电子存储信息或有形物品，或允许检查场所的人员，除非同时被命令出席证言录取、听证或审判，否则无须亲自到达提交或检查地点。\n\n(B) 异议。被命令提交文件或有形物品，或允许检查的人员，可向传票中指定的一方当事人或律师送达书面异议，反对检查、复制、测试或抽样任何或全部材料，或反对检查场所，或反对以所要求的一种或多种形式提交电子存储信息。异议必须在规定的履行时间之前或传票送达后 14 日内（以较早者为准）送达。如提出异议，下列规则适用：\n\n(i) 在任何时候，经通知被命令人员，送达方可向要求履行义务所在地区的法院提出动议，请求作出强制提交或检查的命令。\n\n(ii) 仅可依照命令的指示要求实施该等行为，且该命令必须保护并非一方当事人或一方当事人高级职员的人员免于承担因履行义务产生的重大费用。\n(3) 撤销或修改传票。\n\n(A) 必须撤销或修改的情形。经及时动议，要求履行义务所在地区的法院必须撤销或修改具有下列情形的传票：\n\n(i) 未给予合理履行时间；\n\n(ii) 要求人员在规则 45(c) 规定的地理范围之外履行；\n\n(iii) 要求披露享有特权或受其他保护的事项，且不适用任何例外或豁免；或\n\n(iv) 对人员造成不当负担。\n\n(B) 可以撤销或修改的情形。为保护受传票约束或受其影响的人员，经动议，要求履行义务所在地区的法院可以撤销或修改要求下列事项的传票：\n\n(i) 披露商业秘密或其他保密的研究、开发或商业信息；或\n\n(ii) 披露未经聘用的专家的意见或信息，该等意见或信息并非描述争议中的具体事件，且源于并非由一方当事人请求的该专家研究。\n\n(C) 以规定条件作为替代。在规则 45(d)(3)(B) 所述情形下，如送达方：\n\n(i) 证明其对证言或材料具有重大需要，且如不造成不当困难则无法以其他方式满足该需要；以及\n\n(ii) 确保受传票人员将获得合理补偿，\n\n法院可以不撤销或修改传票，而是命令在规定条件下出席或提交。\n(e) 回应传票的义务。\n\n(1) 提交文件或电子存储信息。下列程序适用于提交文件或电子存储信息：\n\n(A) 文件。回应要求提交文件之传票的人员，必须按文件在日常业务过程中保存的方式提交，或必须将其整理并标注，以对应请求中的类别。\n\n(B) 未指定电子存储信息的提交形式。如传票未指定电子存储信息的提交形式，回应人员必须以其通常保存的一种或多种形式，或以合理可用的一种或多种形式提交。\n\n(C) 电子存储信息仅以一种形式提交。回应人员无须以多于一种形式提交相同的电子存储信息。\n\n(D) 无法合理获取的电子存储信息。答复人无需就其认定因不当负担或费用而无法合理获取的来源中的电子存储信息提供证据开示。在提出强制证据开示动议或保护令动议时，答复人必须证明该信息因不当负担或费用而无法合理获取。如作出该证明，若请求方考虑到 Rule 26(b)(2)(C) 的限制后证明存在正当理由，法院仍可命令从该等来源进行证据开示。法院可规定该证据开示的条件。\n\n(2) 主张特权或保护。\n\n(A) 扣留的信息。根据该信息享有特权或作为审判准备材料受到保护的主张而扣留被传唤信息的人，必须：(i) 明确提出该主张；并且\n\n(ii) 以一种在不披露本身享有特权或受保护的信息的情况下，能够使各方评估该主张的方式，说明被扣留文件、通信或有形物品的性质。\n\n(B) 已提供的信息。如为响应传票而提供的信息受到特权主张或作为审判准备材料受保护的主张，提出该主张的人可将该主张及其依据通知收到该信息的任何一方。收到通知后，一方必须立即返还、隔离或销毁所指定的信息及其持有的任何副本；在该主张得到解决前，不得使用或披露该信息；如该方在收到通知前已披露该信息，必须采取合理措施追回该信息；并可立即将该信息密封提交至要求履行义务所在地区的法院，以裁定该主张。提供该信息的人必须在该主张得到解决前保存该信息。\n\n(g) 藐视法庭。要求履行义务所在地区的法院，以及在动议移送后签发传票的法院，可对已被送达但无正当理由不遵守传票或与其有关命令的人认定为藐视法庭。\n\n有关获取传票材料，请参见 Fed.R.Civ.P.45(a) Committee Note (2013)\n\n……\n\n文件出示请求\n\nI. 指示\n\n1. 除非另有说明，下列文件请求（统称“请求”，单项称“一项请求”）必须分别且具体地作出答复。每项请求均应得到完整答复，除非基于诚信提出异议；如提出异议，必须依下文规定详细说明你方异议的理由。如异议仅涉及某项请求的一部分，或其中包含的某个词语、短语或条款，你方仅须对该部分提出异议，并答复请求的其余部分。\n\n2. 电子存储信息必须依照下列指示提供：\n\na. 图像。黑白图像必须为 300 DPI Group IV 单页 TIFF 文件。彩色图像必须以 JPEG 格式提供。文件名不得包含嵌入式空格或特殊字符（包括逗号）。文件夹名称不得包含嵌入式空格或特殊字符（包括逗号）。所有 TIFF 图像文件必须具有唯一的文件名，即 Bates 编号。每张图像的右下角必须标注连续的 Bates 编号。每个文件夹中的 TIFF 文件数量不得超过 1000 个。Excel 电子表格应具有以该文件 Bates 编号命名的占位图像。\n\nb. 图像加载文件\n\na. Concordance® 数据文件。数据文件（.DAT）包含将被加载至 Concordance® 数据库的全部字段化信息。.DAT 文件的第一行必须为标识字段名称的标题行。.DAT 文件必须使用以下 Concordance® 默认分隔符：逗号 ASCII 字符（020）引号 þ ASCII 字符（254）。日期字段应采用以下格式：mm/dd/yyyy。日期和时间字段必须为两个独立字段。如文件包括图像化的电子邮件及附件，必须包含附件字段，以保留电子邮件与其附件之间的父/子关系。必须包含 OCRPATH 字段，以提供所提供存储介质上提取文本文件的文件路径和名称。文本文件必须以 FIRSTBATES 命名。不得将文本包含在 .DAT 文件中。对于具有原生文件的文件，必须包含 LINK 字段，以提供原生文件的文件路径和\n\n名称。原生文件必须以 FIRSTBATES 命名。\n\nb. Concordance Image® 或 Opticon 交叉引用文件。图像交叉引用文件（.LOG 或 .OPT）将图像链接至数据库记录。其应为逗号分隔文件，每行由七个字段组成；数据库中的每张图像均应在交叉引用文件中有一行，格式如下：ImageID,VolumeLabel,ImageFilePath,DocumentBreak,FolderBreak,Box Break,PageCoun。\n\nc. 文件文本。文本必须作为单独的文本文件提供，而非作为 .DAT 文件内的字段。文本文件的完整路径（OCRPATH）应包含在 .DAT 文件中。建议提供以 FIRSTBATES/Image Key 命名的文件级 ANSI 文本文件。提取的文本文件必须置于单独文件夹内，且每个文件夹内的文本文件数量不得超过 1,000 个。文件夹名称中不得有特殊字符（包括逗号）。文本文件必须按文件级别提供。\n\nd. 特定文件类型的原生格式提供。为充分理解其内容及含义而合理需要以原生格式查看的文件类型，必须以原生格式提供。这些包括但不限于电子表格、类电子表格文件（Microsoft Excel、逗号分隔值、制表符分隔值等）、Microsoft PowerPoint 或其他特殊演示文件、数据库文件，以及音频/视频文件。应提供一张带 Bates 编号的分隔页图像，表明存在原生文件，并在 .dat 文件中将原生文件路径作为一个字段列入。所提供原生文件应以对应于该文件分隔页的 Bates 编号命名。将原生文件归入按递增方式命名的“NATIVE”目录，并与图像目录分开。\n\ne. 去重。对于存在完全重复件的每一电子文件，仅提供一份。对于电子邮件，依据由 BCC、Body、CC、From、IntMsgID、To 和 Attach 属性生成的 MD5 哈希值合并重复件。对于电子邮件附件和独立电子文件，依据整个文件的 MD5 哈希值合并重复件。\n\nf. 元数据。以符合 Concordance 要求的加载文件（.dat）形式提供每份文件的提取元数据。.DAT 文件的第一行必须为标识字段名称的标题行。.DAT 文件必须使用以下 Concordance 默认分隔符：逗号 , ASCII 字符（020）引号 þ ASCII 字符（254）\n\n日期字段应采用以下格式：mm/dd/yyyy。日期和时间字段必须为两个独立字段。以下为所要求的元数据：\nCase 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 96 of 1063\n\n字段名称　示例数据　说明\n\nFIRSTBATES　EDC0000001　原生文件文件/电子邮件的第一个 Bates 编号\nLASTBATES　EDC0000001　原生文件文件/电子邮件的最后一个 Bates 编号\nLASTBATES 字段应针对单页文件予以填充\nATTACHRANGE　EDC0000001\n-　父文件第一页的 Bates 编号至最后一个附件“子”文件最后一页的 Bates 编号\nEDC0000015\nBEGATTACH　EDC0000001　附件范围的第一个 Bates 编号\nENDATTACH　EDC0000015　附件范围的最后一个 Bates 编号\nCUSTODIAN　Smith, John（约翰·史密斯）　电子邮件：该电子邮件所在的邮箱\n原生文件：文件来源的个人或部门名称\nFROM　John Smith（约翰·史密斯）　电子邮件：发件人\n原生文件：文件作者\n多个条目应以分号分隔\nTO　Coffman, Janice（贾妮斯·科夫曼）; LeeW　收件人\n[mailto:LeeW@MSN.com]　多个条目应以分号分隔\nCC　Frank Thompson（弗兰克·汤普森） [mailto:　抄送收件人\nfrank_Thompson@cdt.com]　多个条目应以分号分隔\nBCC　John Cain（约翰·凯恩）　密送收件人\n多个条目应以分号分隔\nSUBJECT　Board Meeting Minutes　电子邮件：电子邮件主题行 原生文件：文件标题\n（如有）\nFILE_NAME　BoardMeetingMinutes.docx　原生文件：原始原生文件名称，\n包括扩展名\nDATE_SENT　10/12/2010　电子邮件：电子邮件发送日期\n原生文件：（空）\nTIME_SENT/\nTIME_ZONE　07:05 PM GMT　电子邮件：电子邮件发送时间/电子邮件标准化所采用的时区\nTIME_ZONE　GMT　转换期间电子邮件被标准化所采用的时区。\nLINK　EDC0000001.msg　电子邮件或原生文件文件的超链接\n所链接文件必须以 FIRSTBATES 编号命名\nFILE_EXTEN　MSG　代表电子邮件或\nAUTHOR　John Smith　电子邮件：（空）\n原生文件：文件作者\nDATE_CREATED　10/10/2010　电子邮件：（空）\n原生文件：文件创建日期\nCase 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 97 of 1063\n\nTIME_CREATED　10:25 AM　电子邮件：（空）\n\n原生文件：文件创建时间\n该数据必须为独立字段，不得与 DATE_CREATED 字段合并\nDATE_MOD　10/12/2010　电子邮件：（空）\n原生文件：文件最后修改日期\nTIME_MOD　07:00 PM　电子邮件：（空）\n原生文件：文件最后修改时间\n该数据必须为独立字段，不得与 DATE_MOD 字段合并\n\nDATE_ACCESSD　10/12/2010　电子邮件：（空）\n原生文件：文件最后访问日期\nTIME_ACCESSD　07:00 PM　电子邮件：（空）\n原生文件：文件最后访问时间\n该数据必须为独立字段，不得与 DATE_ACCESSD 字段合并\nFILE_SIZE　5,952　原生文件文件/电子邮件的大小，以 KB 计\nPGCOUNT　1　原生文件文件/电子邮件中的页数\nPATH　电子邮件：（空）\nAgenda.doc　原生文件：存储原生文件文件的路径，包括原始文件名称。\nINTFILEPATH　Personal Folders\\Deleted　电子邮件：电子邮件的原始位置，包括\nItems\\Board Meeting　原始文件名称。\nMinutes.msg　原生文件：（空）\nINTMSGID　<000805c2c71b\\$75977050\\$　电子邮件：唯一邮件 ID 原生文件：（空）\ncb8306d1@MSN>\nMD5HASH　d131dd02c5e6eec4693d9a0　文件的 MD5 哈希值。\n698aff95c\n2fcab58712467eab4004583e\nb8fb7f89\nOCRPATH　TEXT/001/EDC0000001.txt　原生文件提取文本的路径\n\n3. 每项请求均独立适用并应独立解释，且除非另有说明，任何一项请求均不限制任何其他请求的范围。\n\n4. 所有文件应按通常业务过程中保存的方式提供，或应加以整理和标注，以对应本请求中的类别。\n\n5. 本文所载每项请求延及所有文件：(a) 在你方占有、保管或控制之下；或 (b) 在代表你方行事的任何人占有、保管或控制之下，\nCase 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 98 of 1063\n\n包括你方律师或其他代表和顾问。每份文件均应完整提供。\n\n6. 如要求您提交一份已不再由您占有、保管或控制的文件，则您的答复必须：(a) 详细说明该文件的性质及其内容；(b) 确定编制或撰写该文件的人员（以及，如适用，文件发送给的人员）；(c) 确定该文件编制或创建的日期；(d) 说明该文件是否：(i) 遗失或丢失，(ii) 已被销毁，(iii) 已自愿或非自愿地转交他人，或 (iv) 以其他方式处置；(e) 说明该等处置的理由以及相关事实和情形；(f) 确定授权该等处置的人员；(g) 确定该等处置的日期或大致日期；(h) 说明该文件最后一次由您占有、保管或控制的时间；以及 (i) 确定目前占有、保管或控制该文件的人员（如有）。\n\n7. 如要求您提交一份已被销毁的文件，则除前一项指示所要求的信息外，您的答复还必须说明：(a) 销毁该文件的理由；(b) 销毁该文件的人员身份；以及 (c) 指示销毁该文件的人员身份。\n\n8. 如您主张所请求的文件享有特权或属于律师工作成果，则您的答复必须：(a) 说明：(i) 足以支持您关于该文件享有特权之主张的文件描述，(ii) 文件标题，(iii) 文件日期，(iv) 文件作者，(v) 文件收件人，(vi) 收到或阅览该文件原件或任何草稿、副本或复制件的每一人员身份，(vii) 该文件本身或文件中载有或提及的任何信息是否由任何其他人员占有、保管或控制；如是，则确定该等人员的身份，并说明该信息如何进入其占有，(viii) 据以扣留该文件的特权主张，以及 (ix) 您将据以支持该等特权主张的所有情形；以及 (b) 依照 D. Conn. L. Civ. R. 26(e)，就基于特权主张而扣留的每一文件，提交一份载有本指示第 (a) 部分所要求全部信息的特权日志。对于文件请求中未主张特权或工作成果保护的任何部分，应完整提供相应文件。\n\n案件 22-50073 文书 1592 于 03/24/23 提交并于 03/24/23 10:57:37 登记 第 99 页，共 1063 页\n\n9. 如一份原本应提交的文件中的一部分载有受特权主张保护的信息，则仅应依照上述指示从该文件中删除或遮盖受特权主张保护的部分，其余部分应予提交。\n\n10. 该等请求具有持续性。现指示您：(a) 一旦得知先前答复不完整或不正确，应立即补充或更正任何后来得知不完整或不正确的答复；以及 (b) 提交根据下列规定所要求的任何其他文件\n\n11. 如文件使用英语以外的语言，您应提供该文件。如文件使用英语以外的语言，且存在英文译本，您应同时提供两份文件。\n\n12. 对实体的所有提及均包括其所有关联方。\n\n13. 对个人姓名的所有提及均包括所有替代姓名、别名或昵称。\n\n案件 22-50073 文书 1592 于 03/24/23 提交并于 03/24/23 10:57:37 登记 第 100 页，共 1063 页\n\n14. 除非另有明确说明，文件请求所涵盖的期间为自 February 5, 2015 起至文件请求答复到期之日止。\n\nII. 解释规则\n\n15. (a) 任何单数名词的使用应解释为包括复数，反之亦然；以及 (b) 任何时态动词的使用应解释为该动词在所有其他时态中的使用。\n\n16. (a) “and”和“or”应视需要作连言或选言解释，以使原本可能被解释为不在任何请求范围内的所有答复均纳入该请求范围；以及 (b) “each”和“any”应视为包括并涵盖“every”和“all”两词。\n\nIII. 定义\n\n经 D. Conn. Bankr. L.R. 2004-1(a) 纳入的 D. Conn. L. Civ. R. 26(c) 所提供的定义及 D. Conn. L. Civ. R. 26(d) 所提供的解释规则，适用于该等文件请求。此外，本文件请求中使用的下列术语具有以下含义：\n\n1. “You”、“Your”或“Yourself”系指 Martha Jeffery，以及其任何雇员、代理人、律师、顾问或代表其行事的任何人。\n\n2. “Debtor”系指 Ho Wan Kwok（郭文贵）（亦称 Miles Kwok、Miles Guo、Guo Wengui、Guo Haoyun、郭文贵，或任何其他别名），以及其雇员、代理人、律师、顾问或代表其行事的任何人。\n\n案件 22-50073 文书 1592 于 03/24/23 提交并于 03/24/23 10:57:37 登记 第 101 页，共 1063 页\n\n3. “Debtor's Son”系指 Qiang Guo（郭强）（亦称 Mileson Kwok、郭强，或任何其他别名），以及其雇员、代理人、律师、顾问或代表其行事的任何人。\n\n4. “Debtor's Daughter”系指 Mei Guo（郭美）（亦称 Mei Gui、郭美，或任何其他别名），以及其雇员、代理人、律师、顾问或代表其行事的任何人。\n\n5. “Debtor's Purported Wife”系指 Hing Chi Ngok（岳庆芝）（亦称 Hing Chi Ng、Yue Qingzhi、岳庆芝，或任何其他别名），以及其雇员、代理人、律师、顾问或代表其行事的任何人。\n\n6. “Debtor's Family”统称债务人、债务人之子、债务人之女及债务人据称的妻子，以及与债务人有任何其他亲属关系的人。\n\n7. “Associated Individuals”单独及统称所有符合下列任一条件的个人：(1) 持有、控制、保管或对债务人或债务人家属拥有、控制或享有的资产具有酌处权；或 (2) 曾为一个或多个关联实体的雇员、董事，或以其他方式与其有关联；并包括前述任何人员各自的雇员、代理人、律师、顾问或代表其行事的任何人。该等关联个人包括但不限于：Daniel Podhaskie、Karin Maistrello、Melissa Francis、Anthony DiBattista、Han Chunguang（韩春光）（亦称 韩春光）、Qu Guojiao（屈国姣）（亦称 Qu Guo Jiao、屈国姣）、Zhang Wei（张伟）（亦称 张伟*）、Lihong Wei Lafrenz（魏丽红）（亦称 Sara Wei、魏丽红）、Max Krasner、Yvette Wang（王雁平）（亦称 Yanping Wang、Yan Ping Wang、王雁平）、Fiona Yu，以及 Je Kin Ming（余建明）（亦称 William Je、Yu Jianming、余建明）。\n\n8. “Associated Entities”单独及统称所有符合下列任一条件的组织或任何类型的实体：(1) 曾由债务人或债务人家属拥有、控制或投资；或 (2) 对债务人或债务人家属拥有、控制或享有的任何资产直接或间接拥有权益；并包括前述任何实体各自的雇员、代理人、律师、顾问或代表其行事的任何人。该等关联实体包括但不限于：7 Nod Hill LLC、ACA Investment Management Limited、ACA Capital Group Limited、Ace Decade Holdings Limited、AI Group Holdings Inc.、Booming Sail New York LLC、Bravo Luck Limited、China Golden Spring (Hong Kong) Limited、Crane Advisory Group LLC、Dawn State Limited、Eastern Profit Corporation Limited、Freedom Media Ventures Ltd.、G Club Operations LLC、G Fashion LLC、G News LLC、GETTR USA、Genever Holdings Corporation、Genever Holdings LLC、Gfashion Media Group Inc.、GFNY, Inc.、Golden Spring (New York) Ltd.、Greenwich Land LLC、GTV Media Group, Inc.、Hamilton Capital Holdings Inc.、HCHK Property Management, Inc.、HCHK Technologies, Inc.、Himalaya Embassy、Himalaya Exchange、Himalaya Federal Reserve、Himalaya Investment LLC、Himalaya International、Himalaya New World Inc.、Himalaya Supervisory Organization、Himalaya Ventures LLC、HK International Funds Investments (USA) Limited LLC、Hong Kong International Funds Investments Limited、Hudson Diamond Holding、Infinity Treasury Management Inc.、Lexington Property and Staffing、Long Gate Limited、Maywind Trading LLC、MOS Himalaya LLC、New Federal State of China（亦称 NFSC）、Rule of Law Foundation III, Inc.、Rule of Law Foundation IV, Inc.、Rule of Law Fund、Rule of Law Society、Rule of Law Society IV, Inc.、G-Translators PTY LTD、Saraca Media Group, Inc.、Well Origin Ltd.、Whitecroft Shore Limited，以及 ZIBA Limited。\n\n9. “Including”或其任何变体，系指“包括但不限于”。\n\n10. “And”和“or”均指“and/or”，并应同时作连言及选言解释，以最大限度扩大其范围。\n\n11. “Any”、“all”和“each”均指“每一及全部”。\n\n案件 22-50073 文书 1592 于 03/24/23 提交并于 03/24/23 10:57:37 登记 第 103 页，共 1063 页\n\n12. “Each”和“every”均指“每一及全部”。\n\n13. “Third Party”系指您本人以外的个人或实体。\n\n14. “Transfer”应具有《破产法》section 101(54) 赋予该词的含义。\n\n15. “Document”系指属于 Fed. R. Civ. P. 34 范围内的任何信息或物件，并包括但不限于曾处于或现处于您占有、保管或控制之下的每一及全部任何种类、类型、性质或描述的书面、记录或图形资料，包括电子邮件的所有印刷及电子副本、以电子形式保存的计算机文件、信函、备忘录、磁带、速记或手写笔记、任何种类的书面表格、图表、蓝图、图纸、草图、曲线图、计划、文章、规格书、日记、信件、电报、照片、会议记录、合同、协议、调查资料、计算机打印件、任何种类的数据汇编、电传、传真、电子邮件、短信、即时消息、语音留言、发票、订购单、支票、汇票、对账单、贷项通知单、报告、头寸报告、摘要、索引、书籍、账簿、笔记本、日程表、透明胶片、录音、目录、广告、宣传材料、胶片、录像带、录音带、CD、计算机磁盘、小册子、宣传册、穿孔卡、工时单、Tweets、社交媒体帖子或任何其他种类的书面或记录材料，以及其所有元数据；无论其以何种方式存储（无论为有形或电子形式）、记录、制作或复制；还包括但不限于前述任何资料的草稿或副本，如其中载有原始文件中不存在的任何种类笔记、评论或标记，或者其在其他方面与原始文件并不相同。\n\n案件 22-50073 文书 1592 于 03/24/23 提交并于 03/24/23 10:57:37 登记 第 104 页，共 1063 页\n\n16. “Person(s)”系指个人、公司、独资企业、合伙企业、协会或任何其他实体。“Person”还包括任何代理人、代表或专家，包括但不限于律师或财务顾问。\n\n17. “Entity”系指任何自然人、公司、合伙企业、子公司、独资企业、商号、董事会、合资企业、协会、机构、主管机关、委员会或其他商业实体或法人，以及任何关联方、代理人、母公司，包括但不限于律师、财务顾问或任何其他代表。\n\n18. “Regarding”系指关于、描述、包含、提及、相关、支持、赞成、反对、强化、减损、载于、结合考虑、涉及、证明、表明、报告、记录、暗指、回应、关联、评论、就……而言、有关、与……有关、讨论、显示、描述、反映、分析、构成及属于。\n\n19. “关于”、“涉及”或“相关”，在提及任何特定事项时，系指但不限于构成、包含、涉及、载有、体现、反映、识别、陈述、直接或间接提及该特定事项，或以任何方式与所识别的特定事项相关的任何文件。\n\n20. “通信”系指，在最广泛可能的意义上且不受限制地，任何信息或知识的传递（以事实、观点、询问或其他形式）。通信还指所有谈话、协议、询问或答复，无论是当面、通过电话、以书面形式，还是通过电子传输设备进行，并包括但不限于所有函件、电子邮件、录音、传送单、备忘录、电话通信、语音留言、电报、电传、传真、电传打字、即时消息、聊天记录、短信、发布至留言板或群聊的信息、社交媒体帖子、推文、上传至任何视频平台的视频、电话笔记，或在内部或与第三方之间传送的笔记。\n案件 22-50073 文书 1592 提交日期 03/24/23 登记日期 03/24/23 10:57:37 第 105 页，共 1063 页\n\n21. “资产”系指受占有、保管或控制的任何具有经济价值的项目。资产包括所有不动产和动产，包括但不限于房地产、土地、房屋、公寓、共管公寓、汽车、游艇、船只、飞机、喷气式飞机、直升机、现金、银行账户、加密货币、证券、应收账款、库存及其他有形和无形财产。\n\nIV. 应提交的文件\n\n1. 与位于 781 Fifth Avenue, New York, NY 10022 的 Sherry Netherland Hotel / Condominium（谢里荷兰酒店／共管公寓）（公寓 1801 和 1519）；位于 373 Taconic Rd., Greenwich, Connecticut 06831 的住宅房产；位于 33 Ferncliff Rd., Cos Cob, Connecticut 06807 的住宅房产；位于 354 Nod Hill Rd., Wilton, Connecticut 06897 的住宅房产；位于 32 Chateau Ridge Rd., Greenwich, Connecticut 06831 的房产；位于 110 Clapboard Ridge Rd., Greenwich, Connecticut 06830 的房产；位于 66 Sherwood Avenue, Greenwich, Connecticut 06831 的房产；位于 140 Wallacks Drive, Stamford, Connecticut 06902 的房产；位于 602 Indian Field Drive, Greenwich, Connecticut 06830 的房产；以及位于 11 Hurlingham Drive, Greenwich, Connecticut 06831 的房产有关的所有文件和通信。\n\n2. 与债务人、债务人财产、债务人家属或关联实体的任何收入或资产有关的所有文件或通信，包括但不限于位于 Connecticut（康涅狄格州）的任何不动产。\n案件 22-50073 文书 1592 提交日期 03/24/23 登记日期 03/24/23 10:57:37 第 106 页，共 1063 页\n\n3. 与债务人、债务人家属的任何成员及／或任何关联实体签订的任何委托书有关的所有文件或通信，包括该等委托书的副本。\n\n4. 与因您代理债务人、债务人家属或关联实体而向您支付任何预付费用或佣金有关的所有文件或通信，包括足以识别该预付费用或佣金的金额及其来源的文件。\n\n5. 与您从债务人、债务人家属、家属关联实体或关联实体处或代表其收取的，并存入托管或客户信托账户的任何费用、付款或款项有关的所有文件或通信。\n\n6. 足以显示债务人、债务人家属或关联实体向您支付、代表其向您支付或为其利益向您支付的任何款项的金额、日期和来源的文件。\n\n7. 您与债务人、债务人家属，或代表债务人行事的任何关联个人、代理人、雇员或其他个人之间，就与债务人、债务人财产、债务人家属或关联实体有关的任何转让、投资或其他交易或商业往来所进行的所有通信。\n\n8. 与涉及债务人、债务人家属或任何关联实体的任何出售、潜在出售、取得、处置、购买、潜在购买、投资、出资、赠与、信贷延期、贷款或转让有关的所有文件和通信。\n\n9. 与债务人使用属于、受债务人家属、关联实体或关联个人控制，或其全部或部分所有权由债务人家属、关联实体或关联个人持有的任何资产有关的所有文件和通信，包括但不限于位于 Connecticut（康涅狄格州）的任何不动产。\n案件 22-50073 文书 1592 提交日期 03/24/23 登记日期 03/24/23 10:57:37 第 107 页，共 1063 页\n\n10. 与债务人、债务人财产、债务人家属、关联实体或关联个人有关的任何资产负债表、银行对账单、账户对账单、财务报表、账目报表、电汇指示及／或确认函、资金证明、存款证、持有证明、投资组合摘要或类似文件有关的所有文件和通信，包括但不限于足以显示向上述任何一方进行的所有转让的全部文件。\n\n案件 22-50073 文书 1592 提交日期 03/24/23 登记日期 03/24/23 10:57:37 第 108 页，共 1063 页\n\n附件 C-5\n\nB2540（表格 2540－规则 2004 审查传票）（12/15）案件 22-50073 文书 1592 提交日期 03/24/23 登记日期 03/24/23 10:57:37 第 109 页，共\n\nUNITED STATES BANKRUPTCY COURT（美国破产法院）\n\nDistrict of Connecticut（康涅狄格地区）\n\n关于 HO WAN KWOK（郭文贵）等人，\n\n1 案号 22-50073 (JAM)\n\n债务人 第 11 章\n\n（合并管理）\n\n规则 2004 审查传票\n\n致：Emile P de Neree（埃米尔·P·德·内雷）\n\n（传票所指向人员的姓名）\n\n证言：特此命令您于下文规定的时间、日期及地点出席，并根据 Federal Rules of Bankruptcy Procedure（联邦破产程序规则）第 2004 条规则的审查作证。随附准许该审查的法院命令副本。\n\n地点　日期和时间\n\nPaul Hastings LLP（普衡律师事务所）\n200 Park Avenue　[TBD]\nNew York, New York 10166（纽约州纽约市 10166）\n\n审查将通过以下方式记录：法庭记录员／速记员\n\n提交材料：您或您的代理人还必须在审查时携带下列文件、电子存储信息或物品，并必须允许对该等材料进行检查、复制、测试或取样：\n\n见随附的文件提交请求。\n\nFed. R. Civ. P. 45 的下列规定根据 Fed. R. Bankr. P. 9016 适用于破产案件，现随附如下——关于履行地点的第 45(c) 条规则；关于对作为传票对象的您的保护的第 45(d) 条规则；以及关于您回应本传票的义务及不予回应的潜在后果的第 45(e) 条和第 45(g) 条规则。\n\n日期：March , 2023\n\n法院书记员\n\n或\n\n书记员或副书记员签名　律师签名\n\n签发或请求签发本传票、代表第 11 章受托人 Luc A. Despins（吕克·A·德斯平）的律师的姓名、地址、电子邮件地址和电话号码如下：\n\nDouglas S. Skalka, Esq.（道格拉斯·S·斯卡尔卡，律师）；Neubert, Pepe & Monteith, P.C.（诺伊伯特、佩佩及蒙蒂思专业公司）；195 Church Street, New Haven, Connecticut 06510 dskalka@npmlaw.com；(203) 821-2000\n\n致签发或请求签发本传票之人的通知\n\n如本传票命令在审判前提交文件、电子存储信息或有形物品，或检查场所，则必须在向传票所指向人员送达之前，向各方送达通知及本传票副本。Fed. R. Civ. P. 45(a)(4)。\n\n软件版权 (c) 1996-2022 Best Case, LLC（贝斯特凯斯有限责任公司）- www.bestcase.com Best Case Bankruptcy（贝斯特凯斯破产软件） 1 本第 11 章案件中的债务人为 Ho Wan Kwok（郭文贵）（又名 Guo Wengui（郭文贵）、Miles Guo（郭文贵）和 Miles Kwok（郭文贵），以及众多其他别名）（税务识别号码后四位：9595）、Genever Holdings LLC（Genever控股有限责任公司）（税务识别号码后四位：8202）及 Genever Holdings Corporation（Genever控股公司）。受托人、Genever Holdings LLC 和 Genever Holdings Corporation 的邮寄地址为 Paul Hastings LLP（普衡律师事务所）, 200 Park Avenue, New York, NY 10166，由 Luc A. Despins（吕克·A·德斯平）作为 Ho Wan Kwok（郭文贵）财产受托人收件（仅为通知和通信之目的）。\n\n送达证明\n\n（除非 Fed. R. Civ. P. 45 要求，否则本节不应向法院提交。）\n\n我于（日期）收到向（个人姓名及职务，如有）签发的本传票。\n\n我以下列方式将传票副本递送给具名人员，从而完成送达：\n\n于（日期）送达；或\n\n我未执行传票即予退回，原因如下：\n\n除非本传票代表 United States（美国）或其官员或代理人签发，我还已向证人支付一天的出席费用及法律允许的里程费，金额为 \\$ 。\n\n我的差旅费用为 \\$，服务费用为 \\$，合计 \\$ 。\n\n我在伪证处罚的约束下声明，本信息真实且正确。\n\n日期：\n\n送达人员签名\n\n印刷体姓名及职务\n\n送达人员地址\n\n有关尝试送达等情况的补充信息：\n\nFederal Rule of Civil Procedure 45(c), (d), (e), and (g)（Effective 12/1/13）（根据 Federal Rules of Bankruptcy Procedure（联邦破产程序规则）第 9016 条规则适用于破产案件）\n\n(c) 履行地点。\n\n(1) 审判、听证或证言录取。传票仅可按下列方式命令某人出席审判、听证或证言录取：\n\n(A) 在该人居住、受雇或经常亲自从事商业活动地点 100 英里范围内；或\n\n(B) 在该人居住、受雇或经常亲自从事商业活动所在州内，如该人\n\n(i) 是当事人或当事人的高级职员；或\n\n(ii) 被命令出席审判且不会产生重大费用。\n\n(2) 其他证据开示。传票可以命令：\n\n(A) 在该人居住、受雇或经常亲自从事商业活动地点 100 英里范围内的地点提交文件、电子存储信息或物品；以及\n\n(B) 在被检查场所进行场所检查。\n\n(d) 保护作为传票对象的人员；执行。\n\n(1) 避免不当负担或费用；制裁。负责签发和送达传票的当事人或律师必须采取合理措施，以避免给传票所指向人员施加不当负担或费用。要求履行的地区法院必须执行该义务，并对未遵守者——当事人或律师——施加适当制裁，其中可包括收入损失和合理的律师费。\n\n(2) 命令提交材料或允许检查。\n\n(A) 无须出席。被命令提交文件、电子存储信息或有形物品，或允许检查场所的人员，无须亲自到提交或检查地点出席，除非同时被命令出席证言录取、听证或审判。\n\n(B) 异议。被命令提交文件或有形物品，或允许检查的人员，可以向传票中指定的当事人或律师送达书面异议，反对检查、复制、测试或取样任何或全部材料，反对检查场所，或反对以所要求的一种或多种形式提交电子存储信息。异议必须在规定的履行时间或传票送达后 14 日（以较早者为准）之前送达。如提出异议，适用下列规则：\n\n(i) 在任何时候，经通知被命令人员，送达人可以向要求履行的地区法院提出动议，请求作出强制提交或检查的命令。\n\n(ii) 仅可依命令所指示要求实施该等行为，且该命令必须保护并非当事人或当事人高级职员的人员，免于承担因履行而产生的重大费用。\n\n(3) 撤销或修改传票。\n\n(A) 何时必须。经及时提出动议，要求履行的地区法院必须撤销或修改具有下列情形的传票：\n\n(i) 未留出合理的履行时间；\n\n(ii) 要求某人在《规则》45(c)规定的地域限制之外履行；\n\n(iii) 要求披露享有特权或受其他保护的事项，且不存在任何适用的例外或放弃；或\n\n(iv) 使某人承受不当负担。\n\n(B) 何时可以。为保护受传票约束或受其影响的人，要求履行的地区法院可以应动议撤销或修改传票，如该传票要求：\n\n(i) 披露商业秘密或其他保密的研究、开发或商业信息；或\n\n(ii) 披露未受聘专家的意见或信息，该等意见或信息并未描述争议中的具体事件，且系该专家未应任何一方请求所进行研究的结果。\n\n(C) 将规定条件作为替代方案。在《规则》45(d)(3)(B)所述情形下，如送达方：\n\n(i) 证明其对证言或材料具有重大需要，且如不承受不当困难即无法通过其他方式满足该需要；并且\n\n(ii) 确保被传唤人将获得合理补偿，\n\n法院可以不撤销或修改传票，而是命令在规定条件下出庭或提供材料。\n\n(e) 回应传票的义务。\n\n(1) 提供文件或电子存储信息。下列程序适用于提供文件或电子存储信息：\n\n(A) 文件。回应要求提供文件的传票的人，必须按照文件在通常业务过程中保存的方式提供文件，或者必须对文件进行整理和标记，使其对应于请求中的类别。\n\n(B) 未指定电子存储信息提供形式。如传票未指定提供电子存储信息的形式，回应人必须以其通常保存的一种或多种形式，或者以一种或多种合理可用的形式提供该等信息。\n\n(C) 电子存储信息仅以一种形式提供。回应人无需以一种以上的形式提供相同的电子存储信息。\n\n(D) 无法访问的电子存储信息。回应人无需就其认定因不当负担或费用而无法合理访问的来源中的电子存储信息提供证据开示。在强制证据开示动议或保护令动议中，回应人必须证明该信息因不当负担或费用而无法合理访问。如作出该证明，法院在考虑《规则》26(b)(2)(C)的限制后，如请求方证明存在正当理由，仍可命令从该等来源进行证据开示。法院可以规定证据开示的条件。\n\n(2) 主张特权或保护。\n\n(A) 扣留的信息。以信息享有特权或作为审判准备材料受保护为由扣留被传唤信息的人必须：(i) 明确提出该主张；并且\n\n(ii) 以一种方式描述被扣留文件、通信或有形物的性质，使各方无需披露本身享有特权或受保护的信息，即可评估该主张。\n\n(B) 已提供的信息。如为回应传票而提供的信息受特权主张或作为审判准备材料受保护的主张约束，提出该主张的人可以将该主张及其依据通知任何收到该信息的一方。收到通知后，一方必须立即返还、隔离或销毁所指定的信息及其持有的任何副本；在该主张得到解决前，不得使用或披露该信息；如该方在收到通知前已披露该信息，必须采取合理措施取回该信息；并且可立即向要求履行的地区法院密封提交该信息，以裁定该主张。提供该信息的人必须在该主张得到解决前保存该信息。\n\n(g) 藐视法庭。要求履行的地区法院——以及在动议被移送后，签发传票的法院——可以认定已被送达但无充分理由不遵守传票或与之相关命令的人构成藐视法庭。\n\n如需查阅传票材料，参见 Fed.R.Civ.P.45(a) Committee Note (2013)\n\n……\n\n文件提供请求\nI. 指示\n\n1. 除非另有说明，下列文件请求（以下称“请求”，各称“一项请求”）必须分别且具体地作出回应。每项请求均应得到完整答复，除非对其善意提出异议；在此情形下，应如下文所述详细说明贵方异议的理由。如异议仅涉及某项请求的一部分，或其中包含的某一词语、短语或条款，贵方须仅就该部分说明异议，并对其余请求作出回应。\n\n2. 电子存储信息必须依照下列指示提供：\n\na. 图像。黑白图像必须为300 DPI Group IV单页TIFF文件。彩色图像必须以JPEG格式提供。文件名不得包含嵌入空格或特殊字符（包括逗号）。文件夹名称不得包含嵌入空格或特殊字符（包括逗号）。所有TIFF图像文件必须具有唯一文件名，即Bates编号。图像必须在每张图像的右下角标注连续的Bates编号。每个文件夹中的TIFF文件数量不应超过1000个。Excel电子表格应具有一个以该文件的Bates编号命名的占位图像。\n\nb. 图像加载文件\n\na. Concordance® 数据文件。数据文件（.DAT）包含将加载至Concordance®数据库的所有字段化信息。.DAT文件的第一行必须为标识字段名称的标题行。.DAT文件必须使用下列Concordance®默认分隔符：逗号 ASCII字符（020）引号 þ ASCII字符（254）。日期字段应以如下格式提供：mm/dd/yyyy。日期和时间字段必须为两个独立字段。如文件包括已成像的电子邮件及附件，必须包含附件字段，以保留电子邮件与其附件之间的父/子关系。必须包含OCRPATH字段，以提供所提供存储介质上提取文本文件的文件路径和名称。文本文件必须以FIRSTBATES命名。不得在.DAT文件中包含文本。对于具有原生文件的文件，必须包含LINK字段，以提供原生文件的文件路径和名称。原生文件必须以FIRSTBATES命名。\n\nb. Concordance Image® 或Opticon交叉引用文件。图像交叉引用文件（.LOG或.OPT）将图像链接至数据库记录。其应为逗号分隔文件，每行由七个字段组成；数据库中的每一图像均应在交叉引用文件中有一行，格式如下：ImageID,VolumeLabel,ImageFilePath,DocumentBreak,FolderBreak,Box Break,PageCoun。\n\nc. 文件文本。文本必须作为独立文本文件提供，而非作为.DAT文件内的字段。文本文件的完整路径（OCRPATH）应包含在.DAT文件中。建议提供文件级ANSI文本文件，并按照FIRSTBATES/Image Key命名。提取的文本文件必须置于单独的文件夹中，每个文件夹中的文本文件数量不应超过1,000个。文件夹名称中不得有特殊字符（包括逗号）。文本文件必须按文件级别提供。\n\nd. 特定文件类型的原生格式提供。为充分理解其内容和含义而合理需要以原生格式查看的文件类型，必须以原生格式提供。该等文件包括但不限于电子表格、类似电子表格的文件（Microsoft Excel、逗号分隔值、制表符分隔值等）、Microsoft PowerPoint或其他特殊演示文件、数据库文件以及音频/视频文件。提供一张带有Bates编号的分隔页图像，注明存在原生文件，并将原生文件的路径作为字段包含在.dat文件中。所提供的原生文件应以与该文件分隔页相对应的Bates编号命名。将原生文件归入以递增方式命名的“NATIVE”目录中，并与图像目录分开。\n\ne. 去重。对于存在完全重复件的每份电子文件，仅提供一份副本。对于电子邮件，以根据BCC、Body、CC、From、IntMsgID、To和Attach属性生成的MD5哈希值为依据合并重复件。对于电子邮件附件和独立电子文件，以整个文件的MD5哈希值为依据合并重复件。\n\nf. 元数据。以符合Concordance要求的加载文件（.dat）形式提供每份文件的提取元数据。.DAT文件的第一行必须为标识字段名称的标题行。.DAT文件必须使用下列Concordance默认分隔符：逗号 , ASCII字符（020）引号 þ ASCII字符（254）\n\n日期字段应以如下格式提供：mm/dd/yyyy。日期和时间字段必须为两个独立字段。以下列出所需元数据：\nCase 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 114 of 1063\n\n字段名称　示例数据　说明\n\nFIRSTBATES　EDC0000001　原生文件文件/电子邮件的第一个Bates编号\n\nLASTBATES　EDC0000001　原生文件文件/电子邮件的最后一个Bates编号\n\n注：对于单页文件，应填写LASTBATES字段\n\nATTACHRANGE　EDC0000001\n-　父文件首页的Bates编号至最后一个附件“子”文件最后一页的Bates编号\nEDC0000015\n\nBEGATTACH　EDC0000001　附件范围的第一个Bates编号\n\nENDATTACH　EDC0000015　附件范围的最后一个Bates编号\n\nCUSTODIAN　Smith, John　电子邮件：电子邮件所在的邮箱\n原生文件：文件来源的个人或部门名称\n\nFROM　John Smith　电子邮件：发件人\n原生文件：文件作者\n注：应使用分号分隔多个条目\n\nTO　Coffman, Janice; LeeW　收件人\n[mailto:LeeW@MSN.com]　注：应使用分号分隔多个条目\n\nCC　Frank Thompson [mailto:　抄送收件人\nfrank_Thompson@cdt.com]　注：应使用分号分隔多个条目\n\nBCC　John Cain　密送收件人\n注：应使用分号分隔多个条目\n\nSUBJECT　Board Meeting Minutes　电子邮件：电子邮件的主题行；原生文件：文件标题（如有）\n\nFILE_NAME　BoardMeetingMinutes.docx　原生文件：原始原生文件的名称，包括扩展名\n\nDATE_SENT　10/12/2010　电子邮件：电子邮件发送日期\n原生文件：（空）\n\nTIME_SENT/\nTIME_ZONE　07:05 PM GMT　电子邮件：电子邮件发送时间/电子邮件标准化时所在的时区\n\nTIME_ZONE　GMT　在转换过程中电子邮件被标准化时所在的时区。\n\nLINK　EDC0000001.msg　电子邮件或原生文件文件的超链接\n注：链接文件必须按照FIRSTBATES编号命名\n\nFILE_EXTEN　MSG　表示电子邮件或文件的文件类型扩展名\n\nAUTHOR　John Smith　电子邮件：（空）\n原生文件：文件作者\n\nDATE_CREATED　10/10/2010　电子邮件：（空）\n原生文件：文件创建日期\n\nCase 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 115 of 1063\n\nTIME_CREATED　10:25 AM　电子邮件：（空）\n\n原始：文件创建时间\n**该数据必须为单独字段，且不得\n与 DATE_CREATED 字段合并\nDATE_MOD　10/12/2010　电子邮件：（空）\n原始：文件最后修改日期\nTIME_MOD　07:00 PM　电子邮件：（空）\n原始：文件最后修改时间\n**该数据必须为单独字段，且不得\n与 DATE_MOD 字段合并\nDATE_ACCESSD　10/12/2010　电子邮件：（空）\n原始：文件最后访问日期\nTIME_ACCESSD　07:00 PM　电子邮件：（空）\n原始：文件最后访问时间\n**该数据必须为单独字段，且不得\n与 DATE_ACCESSD 字段合并\nFILE_SIZE　5,952　原始文件\n文件/电子邮件的大小，单位为 KB\nPGCOUNT　1　原始文件文件/电子邮件中的页数\nPATH　电子邮件：（空）\nAgenda.doc　原始：存储原始文件文件的路径，\n包括原始文件名。\nINTFILEPATH　Personal Folders\\Deleted　电子邮件：电子邮件的原始位置，包括\nItems\\Board Meeting　原始文件名。\nMinutes.msg　原始：（空）\nINTMSGID　<000805c2c71b\\$75977050\\$　电子邮件：唯一邮件 ID 原始：（空）\ncb8306d1@MSN>\nMD5HASH　d131dd02c5e6eec4693d9a0　文件的 MD5 哈希值。\n698aff95c\n2fcab58712467eab4004583e\nb8fb7f89\nOCRPATH　TEXT/001/EDC0000001.txt　原始文件提取文本的路径\n\n3. 每项请求均独立运作并应独立解释，除非另有说明，任何请求均不限制任何其他请求的范围。\n\n4. 所有文件应按其在正常业务过程中保存的方式提供，或者应进行整理和标注，以对应本请求中的类别。\n\n5. 本文件所载的每项请求均延伸至所有文件：(a) 由您占有、保管或控制的文件；或 (b) 由代表您行事的任何人占有、保管或控制的文件，\nCase 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 116 of 1063\n包括您的律师或其他代表及顾问。每份文件均应完整提供。\n\n6. 如要求您提供一份已不再由您占有、保管或控制的文件，则您的答复必须：(a) 详细说明该文件的性质及其内容；(b) 识别准备或撰写该文件的人员（以及，如适用，该文件被发送给的人员）；(c) 识别该文件准备或创建的日期；(d) 说明该文件是否：(i) 遗失或丢失，(ii) 已被销毁，(iii) 已自愿或非自愿地转移给他人，或 (iv) 已以其他方式处置；(e) 说明该等处置的理由及其相关事实和情形；(f) 识别授权该等处置的人员；(g) 识别该等处置的日期或大致日期；(h) 说明该文件最近一次由您占有、保管或控制的时间；以及 (i) 识别现时占有、保管或控制该文件的人员，如有。\n\n7. 如要求您提供一份已被销毁的文件，则除前述指示所要求的信息外，您的答复还必须说明：(a) 销毁该文件的理由；(b) 销毁该文件的人员身份；以及 (c) 指示销毁该文件的人员身份。\n\n8. 如您主张所请求的文件享有特权或属于律师工作成果，则您的答复必须：(a) 说明：(i) 足以支持您关于该文件享有特权之主张的文件描述，(ii) 文件标题，(iii) 文件日期，(iv) 文件作者，(v) 文件收件人，(vi) 收到或看过该文件原件或任何草稿、副本或复制件的每一人员身份，(vii) 该文件本身或该文件所含或所提及的任何信息是否由任何其他人员占有、保管或控制；如是，则说明该等人员的身份，并说明该等信息如何进入其占有，\nCase 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 117 of 1063\n(viii) 据以扣留该文件的特权主张，以及 (ix) 您将依赖以支持该等特权主张的所有情形；以及 (b) 就依据特权主张而扣留的每份文件，根据 D. Conn. L. Civ. R. 26(e)，提供一份特权清单，载明本指示第 (a) 部分要求的全部信息。对于文件请求中未提出特权或工作成果主张的任何部分，应完整提供相关文件。\n\n9. 如一份原本应予提供的文件中有部分内容包含受特权主张约束的信息，则仅应按照上述指示从该文件中删除或涂黑受特权主张约束的部分，其余部分应予提供。\n\n10. 本请求具有持续性。特此指示您：(a) 一旦得知先前答复不完整或不正确，应立即补充或更正其后得知为不完整或不正确的任何答复；以及 (b) 提供根据下列规定所要求的任何补充文件\n\n11. 如文件使用英语以外的语言，您应提供该文件。如文件使用英语以外的语言，且存在英文译本，您应同时提供两份文件。\n\n12. 对实体的一切提及均包括其所有关联方。\n\n13. 对个人姓名的一切提及均包括所有其他姓名、别名或昵称。\nCase 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 118 of 1063\n\n14. 除非另有明确说明，文件请求所涵盖的期间为自 February 5, 2015 起至文件请求答复到期之日止。\n\nII. 解释规则\n\n15. (a) 任何单数名词的使用应解释为包括复数，反之亦然；以及 (b) 任何时态动词的使用应解释为在所有其他时态中使用该动词。\n\n16. (a) “and”和“or”应在必要时解释为连词关系或选择关系，以使原本可能被解释为不在任何请求范围内的所有答复均纳入该请求范围；以及 (b) “each”和“any”应视为包括并涵盖“every”和“all”二词。\n\nIII. 定义\n\n经 D. Conn. Bankr. L.R. 2004-1(a) 纳入的 D. Conn. L. Civ. R. 26(c) 所提供的定义以及 D. Conn. L. Civ. R. 26(d) 所提供的解释规则，应适用于文件请求。此外，本文件请求中使用的下列术语具有以下含义：\n\n1. “You”、“Your”或“Yourself”系指 Emile P de Neree（埃米尔·P·德·内雷），连同其任何雇员、代理人、律师、顾问或代表其行事的任何人。\n\n2. “Debtor（债务人）”系指 Ho Wan Kwok（郭文贵）（又名 Miles Kwok、Miles Guo、Guo Wengui、Guo Haoyun、郭文贵或任何其他别名），连同其雇员、代理人、律师、顾问或代表其行事的任何人。\nCase 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 119 of 1063\n\n3. “Debtor's Son（债务人之子）”系指 Qiang Guo（郭强）（又名 Mileson Kwok、郭强或任何其他别名），连同其雇员、代理人、律师、顾问或代表其行事的任何人。\n\n4. “Debtor's Daughter（债务人之女）”系指 Mei Guo（郭美）（又名 Mei Gui、郭美或任何其他别名），连同其雇员、代理人、律师、顾问或代表其行事的任何人。\n\n5. “Debtor's Purported Wife（债务人声称的妻子）”系指 Hing Chi Ngok（岳庆芝）（又名 Hing Chi Ng、Yue Qingzhi、岳庆芝或任何其他别名），连同其雇员、代理人、律师、顾问或代表其行事的任何人。\n\n6. “Debtor's Family（债务人家庭成员）”统指债务人、债务人之子、债务人之女和债务人声称的妻子，以及与债务人具有任何其他亲属关系者。\n\n7. “Associated Individuals（关联个人）”单独及共同指所有符合以下情形的个人：(1) 持有、控制、保管或对债务人或债务人家庭成员拥有、控制或享有的资产具有酌处权；或 (2) 曾为一家或多家关联实体的雇员、董事，或以其他方式与其关联，连同上述各方各自的雇员、代理人、律师、顾问或代表其行事的任何人。该等关联个人包括但不限于：Daniel Podhaskie（丹尼尔·波达斯基）、Karin Maistrello（卡琳·迈斯特雷洛）、Melissa Francis（梅丽莎·弗朗西斯）、Anthony DiBattista（安东尼·迪巴蒂斯塔）、Han Chunguang（韩春光）（又名 韩春光）、Qu Guojiao（屈国姣）（又名 Qu Guo Jiao、屈国姣）、Zhang Wei（张伟）（又名 张伟*）、Lihong Wei Lafrenz（魏丽红）（又名 Sara Wei、魏丽红Max Krasner（马克斯·克拉斯纳）、Yvette Wang（王雁平）（又名 Yanping Wang、Yan Ping Wang、王雁平）、Fiona Yu（菲奥娜·余）及 Je Kin Ming（余建明）（又名 William Je、Yu Jianming、余建明）。\n\n8. “Associated Entities（关联实体）”单独及共同指所有符合以下情形的任何类型组织或实体：(1) 曾由债务人或债务人家庭成员拥有、控制或投资；或 (2) 对债务人或债务人家庭成员拥有、控制或享有的任何资产直接或间接享有权益，连同上述各方各自的雇员、代理人、律师、顾问或代表其行事的任何人。该等关联实体包括但不限于：7 Nod Hill LLC（7 Nod Hill 有限责任公司）、ACA Investment Management Limited（ACA 投资管理有限公司）、ACA Capital Group Limited（ACA 资本集团有限公司）、Ace Decade Holdings Limited（Ace Decade 控股有限公司）、AI Group Holdings Inc.（AI 集团控股公司）、Booming Sail New York LLC（Booming Sail New York 有限责任公司）、Bravo Luck Limited（Bravo Luck 有限公司）、China Golden Spring (Hong Kong) Limited（中国金泉〈香港〉有限公司）、Crane Advisory Group LLC（Crane 顾问集团有限责任公司）、Dawn State Limited（Dawn State 有限公司）、Eastern Profit Corporation Limited（Eastern Profit Corporation 有限公司）、Freedom Media Ventures Ltd.（Freedom Media Ventures 有限公司）、G Club Operations LLC（G Club Operations 有限责任公司）、G Fashion LLC（G Fashion 有限责任公司）、G News LLC（G News 有限责任公司）、GETTR USA（GETTR 美国）、Genever Holdings Corporation（Genever 控股公司）、Genever Holdings LLC（Genever 控股有限责任公司）、Gfashion Media Group Inc.（Gfashion 媒体集团公司）、GFNY, Inc.（GFNY 公司）、Golden Spring (New York) Ltd.（Golden Spring〈纽约〉有限公司）、Greenwich Land LLC（Greenwich Land 有限责任公司）、GTV Media Group, Inc.（GTV 媒体集团公司）、Hamilton Capital Holdings Inc.（Hamilton Capital Holdings 公司）、HCHK Property Management, Inc.（HCHK 物业管理公司）、HCHK Technologies, Inc.（HCHK 科技公司）、Himalaya Embassy（Himalaya Embassy）、Himalaya Exchange（Himalaya Exchange）、Himalaya Federal Reserve（Himalaya Federal Reserve）、Himalaya Investment LLC（Himalaya Investment 有限责任公司）、Himalaya International（Himalaya International）、Himalaya New World Inc.（Himalaya New World 公司）、Himalaya Supervisory Organization（Himalaya Supervisory Organization）、Himalaya Ventures LLC（Himalaya Ventures 有限责任公司）、HK International Funds Investments (USA) Limited LLC（HK International Funds Investments〈USA〉Limited 有限责任公司）、Hong Kong International Funds Investments Limited（Hong Kong International Funds Investments 有限公司）、Hudson Diamond Holding（Hudson Diamond Holding）、Infinity Treasury Management Inc.（Infinity Treasury Management 公司）、Lexington Property and Staffing（Lexington Property and Staffing）、Long Gate Limited（Long Gate 有限公司）、Maywind Trading LLC（Maywind Trading 有限责任公司）、MOS Himalaya LLC（MOS Himalaya 有限责任公司）、New Federal State of China（中国新联邦国）（又名 NFSC）、Rule of Law Foundation III, Inc.（Rule of Law Foundation III 公司）、Rule of Law Foundation IV, Inc.（Rule of Law Foundation IV 公司）、Rule of Law Fund（Rule of Law Fund）、Rule of Law Society（Rule of Law Society）、Rule of Law Society IV, Inc.（Rule of Law Society IV 公司）、G-Translators PTY LTD（G-Translators PTY LTD）、Saraca Media Group, Inc.（Saraca Media Group 公司）、Well Origin Ltd.（Well Origin 有限公司）、Whitecroft Shore Limited（Whitecroft Shore 有限公司）及 ZIBA Limited（ZIBA 有限公司）。\nCase 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 120 of 1063\n\n9. “Including”或其任何变体意为“包括但不限于”。\n\n10. “And”和“or”意为“和/或”，并应同时解释为连词关系及选择关系，以最大限度扩大其范围。\n\n11. “Any”、“all”和“each”意为“每一及全部”。\nCase 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 121 of 1063\n\n12. “Each”和“every”意为“每一及全部”。\n\n13. “Third Party（第三方）”系指您本人以外的个人或实体。\n\n14. “Transfer（转让）”应具有《破产法典》第 101(54) 条赋予该词的含义。\n\n15. “文件”系指属于 Fed. R. Civ. P. 34 范围内的任何信息或物件，并包括但不限于任何种类、类型、性质或描述的、现由或曾由您占有、保管或控制的每一份书面、记录或图形材料，包括电子邮件的所有打印副本和电子副本、以电子形式保存的计算机文件、函件、备忘录、磁带、速记或手写笔记、各种书面表格、图表、蓝图、绘图、草图、图形、计划、文章、规格说明、日记、信函、电报、照片、会议记录、合同、协议、调查材料、计算机打印件、各种数据汇编、电传、传真、电子邮件、短信、即时消息、语音留言、发票、订购单、支票、汇票、对账单、贷项通知单、报告、立场报告、摘要、索引、书籍、分类账、笔记本、日程表、透明胶片、录音记录、目录、广告、宣传材料、胶片、录像带、录音带、CD、计算机磁盘、宣传册、小册子、穿孔卡、工时单、推文、社交媒体帖子或任何其他种类的书面或记录材料，以及其所有元数据，无论以何种方式存储（无论为有形形式还是电子形式）、记录、制作或复制；还包括但不限于前述任何材料的草稿或副本，如其包含原始文件中不存在的任何种类笔记、评论或标记，或者其在其他方面与原始文件不相同。\n\n案号 22-50073 文件 1592 提交于 03/24/23 登记于 03/24/23 10:57:37 第 122 页，共 1063 页\n\n16. “人员”系指个人、公司、独资企业、合伙企业、协会或任何其他实体。“人员”还包括任何代理人、代表或专家，包括但不限于律师或财务顾问。\n\n17. “实体”系指任何自然人、公司、合伙企业、子公司、独资企业、商号、董事会、合资企业、协会、机构、主管机关、委员会或其他商业实体或法人，以及任何关联方、代理人、母公司，包括但不限于法律顾问、财务顾问或任何其他代表。\n\n18. “关于”系指涉及、描述、包含、提及、与之相关、支持、赞成、反对、加强、削弱、位于其中、结合考虑、对其有影响、证明、表明、报告、记录、暗示、回应、与之联系、评论、就其而言、有关、与之相关、讨论、展示、描述、反映、分析、构成及作为。\n\n19. “与……有关”、“涉及”或“相关”，在提及任何特定事项时，系指但不限于构成、包含、涉及、含有、体现、反映、识别、陈述、直接或间接提及该特定事项，或以任何方式与所识别的特定事项相关的任何文件。\n\n20. “通信”系指以最广泛的可能含义且不限于此的任何信息或知识传递（以事实、观点、询问或其他形式）。通信还指所有谈话、协议、询问或答复，无论是当面、通过电话、书面方式，还是通过电子传输设备进行，并包括但不限于所有函件、电子邮件、录音记录、传递单、备忘录、电话通信、语音留言、电报、电话传真、传真副本、电传、即时消息、聊天、短信、发布至留言板或群聊的内容、社交媒体帖子、推文、视频\n\n案号 22-50073 文件 1592 提交于 03/24/23 登记于 03/24/23 10:57:37 第 123 页，共 1063 页\n\n上传至任何视频平台的视频、电话笔记，或在内部或与第三方之间传递的笔记。\n\n21. “资产”系指受占有、保管或控制的具有经济价值的任何项目。资产包括所有不动产和动产，包括但不限于房地产、土地、房屋、公寓、共管公寓、汽车、游艇、船只、飞机、喷气机、直升机、现金、银行账户、加密货币、证券、应收账款、存货及其他有形和无形财产。\n\nIV. 应提交的文件\n\n1. 与位于 781 Fifth Avenue, New York, NY 10022 的 Sherry Netherland Hotel / Condominium（谢里荷兰酒店/共管公寓）（1801 室和 1519 室）；位于 373 Taconic Rd., Greenwich, Connecticut 06831 的住宅房产；位于 33 Ferncliff Rd., Cos Cob, Connecticut 06807 的住宅房产；位于 354 Nod Hill Rd., Wilton, Connecticut 06897 的住宅房产；位于 32 Chateau Ridge Rd., Greenwich, Connecticut 06831 的房产；位于 110 Clapboard Ridge Rd., Greenwich, Connecticut 06830 的房产；位于 66 Sherwood Avenue, Greenwich, Connecticut 06831 的房产；位于 140 Wallacks Drive, Stamford, Connecticut 06902 的房产；位于 602 Indian Field Drive, Greenwich, Connecticut 06830 的房产；以及位于 11 Hurlingham Drive, Greenwich, Connecticut 06831 的房产有关的所有文件和通信。\n\n2. 与债务人、债务人财产、债务人家庭成员或关联实体的任何收入或资产有关的所有文件或通信，包括但不限于位于 Connecticut 的任何不动产。\n\n案号 22-50073 文件 1592 提交于 03/24/23 登记于 03/24/23 10:57:37 第 124 页，共 1063 页\n\n3. 与债务人、债务人家庭成员的任何成员和/或任何关联实体签订的任何聘用函有关的所有文件或通信，包括该等聘用函的副本。\n\n4. 与基于您对债务人、债务人家庭成员或关联实体的代理而向您支付任何预付费用或佣金有关的所有文件或通信，包括足以识别预付费用或佣金金额及其来源的文件。\n\n5. 与您从债务人、债务人家庭成员、家庭关联实体或关联实体处或代表其收取，并存放于托管账户或客户信托账户中的任何费用、付款或款项有关的所有文件或通信。\n\n6. 足以显示债务人、债务人家庭成员或关联实体向您作出、代表其作出或为其利益作出的任何付款的金额、日期及来源的文件。\n\n7. 您与债务人、债务人家庭成员，或代表债务人行事的任何关联个人、代理人、雇员或其他个人之间，就与债务人、债务人财产、债务人家庭成员或关联实体有关的任何转让、投资或其他交易或商业往来所进行的所有通信。\n\n8. 与涉及债务人、债务人家庭成员或任何关联实体的任何出售、潜在出售、取得、处置、购买、潜在购买、投资、出资、赠与、信用展期、贷款或转让有关的所有文件和通信。\n\n9. 与债务人使用属于、受债务人家庭成员控制，或其全部或部分所有权由债务人家庭成员持有的任何资产有关的所有文件和通信，\n\n案号 22-50073 文件 1592 提交于 03/24/23 登记于 03/24/23 10:57:37 第 125 页，共 1063 页\n\n关联实体或关联个人，包括但不限于位于 Connecticut 的任何不动产。\n\n10. 与债务人、债务人财产、债务人家庭成员、关联实体或关联个人有关的任何资产负债表、银行对账单、账户对账单、财务报表、账户报表、电汇指示和/或确认函、资金证明、存款证、持仓证明、投资组合摘要或类似文件有关的所有文件和通信，包括但不限于足以显示向前述任何主体作出的所有转让的全部文件。\n\n案号 22-50073 文件 1592 提交于 03/24/23 登记于 03/24/23 10:57:37 第 126 页，共 1063 页\n\n附件 C-6\n\nB2540（表格 2540——Rule 2004 审查传票）（12/15）案号 22-50073 文件 1592 提交于 03/24/23 登记于 03/24/23 10:57:37 第 127 页，共\n\n美国破产法院 1063\n\nConnecticut District（康涅狄格地区）\n\n关于 HO WAN KWOK（郭文贵）等人，\n\n1 案号 22-50073 (JAM)\n\n债务人 第 11 章\n\n（联合管理）\nRule 2004 审查传票\n\n致：Zhizhe “Frank” Dong（董志哲）\n\n（传票所指向人员的姓名）\n\n证言：兹命令您于下列规定的时间、日期和地点出席，根据《联邦破产程序规则》Rule 2004 接受审查并作证。随附授权该审查的法院命令副本。\n\n地点　日期和时间\n\nPaul Hastings LLP\n200 Park Avenue　[TBD]\nNew York, New York 10166\n\n审查将采用以下方式记录：法庭记录员/速记员\n\n提交：您或您的代表还必须携带下列文件、电子存储信息或物件参加审查，并必须允许对该等材料进行检查、复制、测试或抽样：\n见随附的文件提交请求。\n\nFed. R. Civ. P. 45 的下列规定已附上，并依 Fed. R. Bankr. P. 9016 适用于破产案件：关于履行地点的 Rule 45(c)；关于作为受传票约束之人员的保护的 Rule 45(d)；以及关于您回应本传票的义务及未回应的潜在后果的 Rule 45(e) 和 45(g)。\n\n日期：March , 2023\n\n法院书记官\n\n或\n\n书记官或副书记官签名　律师签名\n\n签发或请求本传票、代表 Chapter 11 受托人 Luc A. Despins（吕克·A·德斯平斯）的律师的姓名、地址、电子邮件地址和电话号码如下：\n\nDouglas S. Skalka, Esq.（道格拉斯·S·斯卡尔卡）；Neubert, Pepe & Monteith, P.C.；195 Church Street, New Haven, Connecticut 06510 dskalka@npmlaw.com；(203) 821-2000\n\n致签发或请求本传票之人的通知\n\n如本传票命令在审判前提交文件、电子存储信息或有形物件，或检查场所，则必须在向受传票指向之人送达前，向每一方当事人送达通知及本传票副本。Fed. R. Civ. P. 45(a)(4)。\n\n软件版权 (c) 1996-2022 Best Case, LLC - www.bestcase.com Best Case Bankruptcy 1 本 Chapter 11 案件中的债务人为 Ho Wan Kwok（郭文贵，亦称 Guo Wengui、Miles Guo 和 Miles Kwok，以及众多其他别名）（税务识别号码后四位：9595）、Genever Holdings LLC（税务识别号码后四位：8202）及 Genever Holdings Corporation。受托人、Genever Holdings LLC 和 Genever Holdings Corporation 的邮寄地址为 Paul Hastings LLP, 200 Park Avenue, New York, NY 10166，转交 Ho Wan Kwok 财产受托人 Luc A. Despins（仅限用于通知和通信）。\n\n送达证明\n\n（除非 Fed. R. Civ. P. 45 要求，否则本节不应向法院提交。）\n\n本人于（日期）收到向（个人姓名及职务，如有）签发的本传票。\n\n本人以下列方式向指定人员送达本传票副本：\n\n于（日期）送达；或\n\n本人未执行而退回本传票，原因如下：\n\n除非本传票代表 United States（美国）或其官员或代理人签发，本人还已向证人支付出席一天的费用及法律允许的里程费，金额为 \\$ 。\n\n本人的差旅费用为 \\$ ，服务费用为 \\$ ，合计 \\$ 。\n\n本人在伪证处罚的约束下声明，该等信息真实且正确。\n\n日期：\n\n送达人签名\n\n印刷体姓名及职务\n\n送达人地址\n\n关于尝试送达等事项的补充信息：\n\n《联邦民事诉讼规则》Rule 45(c)、(d)、(e) 和 (g)（自 12/1/13 生效）（依《联邦破产程序规则》Rule 9016 适用于破产案件）\n\n(c) 履行地点。\n\n(1) 审判、听证或证言录取。传票仅可在下列地点命令某人出席审判、听证或证言录取：\n\n(A) 距该人居住、受雇或经常亲自从事业务之地 100 英里以内；或\n\n(B) 在该人居住、受雇或经常亲自从事业务所在州内，条件是该人\n\n(i) 为当事人或当事人的高级职员；或\n\n(ii) 被命令出席审判，且不会产生重大费用。\n\n(2) 其他证据开示。传票可命令：\n\n(A) 在距该人居住、受雇或经常亲自从事业务之地 100 英里以内的地点提供文件、以电子方式存储的信息或物品；以及\n\n(B) 在待检查场所对该场所进行检查。\n\n(d) 对受传票约束之人的保护；执行。\n\n(1) 避免不当负担或费用；制裁。负责签发和送达传票的当事人或律师必须采取合理措施，避免对受传票约束之人施加不当负担或费用。要求履行传票的地区法院必须执行该项义务，并对未遵守该义务的当事人或律师施加适当制裁，该制裁可包括损失的收入和合理的律师费。\n\n(2) 命令提供材料或准许检查。\n\n(A) 无须出庭。被命令提供文件、以电子方式存储的信息或有形物品，或准许检查场所之人，无须亲自到提供或检查地点出席，除非同时被命令出席证言录取、听证或审判。\n\n(B) 异议。被命令提供文件或有形物品，或准许检查的人，可就检查、复制、测试或抽样全部或部分材料，或检查场所，或以所要求的一种或多种形式提供以电子方式存储的信息，向传票中指定的当事人或律师送达书面异议。异议必须在规定履行时间届满前或传票送达后 14 天内（以较早者为准）送达。如提出异议，适用下列规则：\n\n(i) 送达方可在任何时候，在通知被命令人后，向要求履行传票的地区法院提出动议，请求作出强制提供或检查的命令。\n\n(ii) 仅可按照该命令的指示要求实施这些行为，并且该命令必须保护既非当事人亦非当事人高级职员之人，免受因履行而产生的重大费用。\n\n(3) 撤销或修改传票。\n\n(A) 必须撤销或修改的情形。经及时动议，要求履行传票的地区法院必须撤销或修改符合下列情形的传票：\n\n(i) 未给予合理的履行时间；\n\n(ii) 要求某人在 Rule 45(c) 规定的地域限制以外履行；\n\n(iii) 要求披露享有特权或受其他保护的事项，且不存在适用的例外或放弃；或\n\n(iv) 对某人施加不当负担。\n\n(B) 可撤销或修改的情形。为保护受传票约束或受其影响之人，要求履行传票的地区法院可经动议撤销或修改要求下列事项的传票：\n\n(i) 披露商业秘密或其他保密的研究、开发或商业信息；或\n\n(ii) 披露未受聘专家的意见或信息，该等意见或信息既非对争议中具体事件的描述，亦非源自任何当事人请求该专家进行的研究。\n\n(C) 将规定条件作为替代措施。在 Rule 45(d)(3)(B) 所述情形下，如送达方：\n\n(i) 证明其对该证言或材料具有重大需要，且如不造成不当困难则无法通过其他方式满足该需要；并且\n\n(ii) 确保受传票人将获得合理补偿，\n\n法院可不撤销或修改传票，而是在规定条件下命令出席或提供材料。\n\n(e) 回应传票的义务。\n\n(1) 提供文件或以电子方式存储的信息。下列程序适用于提供文件或以电子方式存储的信息：\n\n(A) 文件。回应提供文件传票之人，必须按照文件在正常业务过程中保存的方式提供文件，或者必须将文件整理并标注，以对应请求中的类别。\n\n(B) 未规定提供以电子方式存储的信息的形式。如传票未规定提供以电子方式存储的信息的形式，回应之人必须以该信息通常保存的一种或多种形式，或以合理可用的一种或多种形式提供该信息。\n\n(C) 以电子方式存储的信息仅须以一种形式提供。回应之人无须以一种以上形式提供相同的以电子方式存储的信息。\n\n(D) 无法访问的以电子方式存储的信息。回应之人无须对其认定因不当负担或费用而无法合理访问的来源中的以电子方式存储的信息进行证据开示。对于强制证据开示或保护令的动议，回应之人必须证明该信息因不当负担或费用而无法合理访问。如作出该证明，法院仍可在请求方证明具有正当理由时，考虑 Rule 26(b)(2)(C) 的限制后，命令从该等来源进行证据开示。法院可就该证据开示规定条件。\n\n(2) 主张特权或保护。\n\n(A) 扣留的信息。根据该信息享有特权或作为审判准备材料受到保护的主张而扣留被传唤信息之人，必须：(i) 明确提出该主张；以及\n\n(ii) 在不披露本身享有特权或受保护的信息的情况下，以足以使当事人评估该主张的方式，描述被扣留的文件、通信或有形物品的性质。\n\n(B) 已提供的信息。如为回应传票而提供的信息受到特权主张或作为审判准备材料受保护的主张约束，提出该主张之人可将该主张及其依据通知任何收到该信息的当事人。收到通知后，当事人必须立即返还、隔离或销毁所指明的信息及其持有的任何副本；在该主张得到解决前不得使用或披露该信息；如该当事人在收到通知前已披露该信息，必须采取合理措施取回该信息；并可立即将该信息密封提交给要求履行传票的地区法院，以裁定该主张。提供该信息之人必须在该主张得到解决前保存该信息。\n\n(g) 藐视法庭。要求履行传票的地区法院，以及在动议被移送后签发传票的法院，均可对已被送达但无充分理由不遵守传票或与之相关命令之人，以藐视法庭论处。\n\n有关获取传票材料，请参见 Fed.R.Civ.P.45(a) Committee Note (2013)\n\n…\n\n文件提供请求\n\nI. 指示\n\n1. 除非另有说明，下述文件请求（以下称“请求”，每一项称“一项请求”）必须分别且具体地作出答复。每项请求均应得到完整答复，除非基于善意提出异议；在此情形下，应按如下规定详细说明贵方异议的理由。如异议仅涉及某项请求的一部分，或其中所含的某一词语、短语或条款，贵方仅须就该部分说明异议，并答复其余请求。\n\n2. 以电子方式存储的信息必须按照下列指示提供：\n\na．图像。黑白图像必须为 300 DPI Group IV 单页 TIFF 文件。彩色图像必须以 JPEG 格式提供。文件名不得包含内嵌空格或特殊字符（包括逗号）。文件夹名称不得包含内嵌空格或特殊字符（包括逗号）。所有 TIFF 图像文件必须具有唯一文件名，即 Bates 编号。每幅图像右下角必须标注连续的 Bates 编号。每个文件夹中的 TIFF 文件数量不应超过 1000 个文件。Excel 电子表格应具有以该文件 Bates 编号命名的占位图像。\n\nb．图像加载文件\n\n(a) Concordance® 数据文件。数据文件（.DAT）包含将被加载至 Concordance® 数据库的所有字段信息。.DAT 文件的第一行必须为标识字段名称的标题行。.DAT 文件必须使用以下 Concordance® 默认分隔符：逗号 ASCII 字符 (020)；引号 þ ASCII 字符 (254)。日期字段应以 mm/dd/yyyy 格式提供。日期和时间字段必须为两个独立字段。如文件包括已成像的电子邮件及附件，则必须包括附件字段，以保留电子邮件及其附件之间的父项/子项关系。必须包括 OCRPATH 字段，以提供所提供存储介质上提取文本文件的文件路径及名称。文本文件必须以 FIRSTBATES 命名。请勿在 .DAT 文件中包含文本。对于含有原生文件的文件，必须包括 LINK 字段，以提供原生文件的文件路径及名称。原生文件必须以 FIRSTBATES 命名。\n\n(b) Concordance Image® 或 Opticon 交叉引用文件。图像交叉引用文件（.LOG 或 .OPT）将图像链接至数据库记录。该文件应为逗号分隔文件，每行由七个字段组成，并应就数据库中的每一幅图像在交叉引用文件中设置一行，格式如下：ImageID,VolumeLabel,ImageFilePath,DocumentBreak,FolderBreak,BoxBreak,PageCount。\n\nc．文件文本。文本必须作为独立文本文件提供，而不得作为 .DAT 文件中的字段提供。文本文件的完整路径（OCRPATH）应包括在 .DAT 文件中。建议提供以 FIRSTBATES/Image Key 命名的文件级 ANSI 文本文件。提取的文本文件必须置于单独的文件夹中，每个文件夹中的文本文件数量不应超过 1,000 个文件。文件夹名称中不得含有特殊字符（包括逗号）。文本文件必须按文件级别提供。\n\nd．特定文件类型的原生文件提供。为充分理解其内容和含义而合理需要以原生格式查看的文件类型，必须以原生格式提供。这些文件包括但不限于电子表格、类电子表格文件（Microsoft Excel、逗号分隔值、制表符分隔值等）、Microsoft PowerPoint 或其他特殊演示文件、数据库文件以及音频/视频文件。应提供一幅标注 Bates 编号的分隔页图像，以表明存在原生文件，并将原生文件的路径作为字段列入 .dat 文件。所提供的原生文件应以与该文件分隔页相对应的 Bates 编号命名。原生文件应归入按递增方式命名的“NATIVE”目录中，并与图像目录分开。\n\ne．去重。对于存在完全重复件的每份电子文件，仅提供一份副本。对于电子邮件信息，应根据由 BCC、Body、CC、From、IntMsgID、To 和 Attach 属性生成的 MD5 哈希值合并重复件。对于电子邮件附件和独立电子文件，应根据整个文件的 MD5 哈希值合并重复件。\n\nf．元数据。以符合 Concordance 要求的加载文件（.dat）形式，提供每份文件的提取元数据。.DAT 文件的第一行必须为标识字段名称的标题行。.DAT 文件必须使用以下 Concordance 默认分隔符：逗号 , ASCII 字符 (020)；引号 þ ASCII 字符 (254)\n\n日期字段应采用以下格式提供：mm/dd/yyyy。日期字段和时间字段必须为两个单独的字段。下列必填元数据：\n\n案件 22-50073 文书 1592 提交日期 03/24/23 登记日期 03/24/23 10:57:37 第 132 页，共 1063 页\n\n字段名称　示例数据　说明\n\nFIRSTBATES　EDC0000001　原生文件文档/电子邮件的首个 Bates 编号\nLASTBATES　EDC0000001　原生文件文档/电子邮件的最后一个 Bates 编号\n**对于单页文件，应填写 LASTBATES 字段\nATTACHRANGE　EDC0000001\n-　父文档第一页的 Bates 编号至\nEDC0000015　最后一个附件“子”文档最后一页的 Bates 编号\nBEGATTACH　EDC0000001　附件范围的首个 Bates 编号\nENDATTACH　EDC0000015　附件范围的最后一个 Bates 编号\nCUSTODIAN　Smith, John　电子邮件：电子邮件所在的邮箱\n原生文件：文档来源的个人或部门名称\nFROM　John Smith　电子邮件：发件人\n原生文件：文档作者\n**多个条目之间应以分号分隔\nTO　Coffman, Janice; LeeW　收件人\n[mailto:LeeW@MSN.com]　**多个条目之间应以分号分隔\nCC　Frank Thompson [mailto:　抄送收件人\nfrank_Thompson@cdt.com]　**多个条目之间应以分号分隔\nBCC　John Cain　密送收件人\n**多个条目之间应以分号分隔\nSUBJECT　Board Meeting Minutes　电子邮件：电子邮件主题行；原生文件：文档标题（如有）\nFILE_NAME　BoardMeetingMinutes.docx　原生文件：原始原生文件的名称，包括扩展名\nDATE_SENT　10/12/2010　电子邮件：电子邮件发送日期\n原生文件：（空）\nTIME_SENT/\nTIME_ZONE　07:05 PM GMT　电子邮件：电子邮件发送时间/电子邮件标准化所采用的时区\nTIME_ZONE　GMT　在转换过程中电子邮件被标准化所采用的时区。\nLINK　EDC0000001.msg　电子邮件或原生文件文档的超链接\n**链接文件必须按 FIRSTBATES 编号命名\nFILE_EXTEN　MSG　表示电子邮件或的文件类型扩展名\nAUTHOR　John Smith　电子邮件：（空）\n原生文件：文档作者\nDATE_CREATED　10/10/2010　电子邮件：（空）\n原生文件：文档创建日期\n\n案件 22-50073 文书 1592 提交日期 03/24/23 登记日期 03/24/23 10:57:37 第 133 页，共 1063 页\n\nTIME_CREATED　10:25 AM　电子邮件：（空）\n\n原生文件：文档创建时间\n**该数据必须为单独字段，不得与 DATE_CREATED 字段合并\nDATE_MOD　10/12/2010　电子邮件：（空）\n原生文件：文档最后修改日期\nTIME_MOD　07:00 PM　电子邮件：（空）\n原生文件：文档最后修改时间\n**该数据必须为单独字段，不得与 DATE_MOD 字段合并\nDATE_ACCESSD　10/12/2010　电子邮件：（空）\n原生文件：文档最后访问日期\nTIME_ACCESSD　07:00 PM　电子邮件：（空）\n原生文件：文档最后访问时间\n**该数据必须为单独字段，不得与 DATE_ACCESSD 字段合并\nFILE_SIZE　5,952　原生文件文档/电子邮件的大小，以 KB 计\nPGCOUNT　1　原生文件文档/电子邮件的页数\nPATH　电子邮件：（空）\nAgenda.doc　原生文件：存储原生文件文档的路径，包括原始文件名。\nINTFILEPATH　Personal Folders\\Deleted　电子邮件：电子邮件的原始位置，包括\nItems\\Board Meeting　原始文件名。\nMinutes.msg　原生文件：（空）\nINTMSGID　<000805c2c71b\\$75977050\\$　电子邮件：唯一邮件 ID；原生文件：（空）\ncb8306d1@MSN>\nMD5HASH　d131dd02c5e6eec4693d9a0　文档的 MD5 哈希值。\n698aff95c\n2fcab58712467eab4004583e\nb8fb7f89\nOCRPATH　TEXT/001/EDC0000001.txt　原生文件提取文本的路径\n\n3. 每项请求均独立适用并应独立解释；除非另有说明，任何请求均不限制任何其他请求的范围。\n\n4. 所有文档均应按照其在正常业务过程中保存的方式提供，或应予整理和标注，以对应于本请求中的类别。\n\n5. 本文所载每项请求均延伸至所有文档：(a) 在您的占有、保管或控制之下；或 (b) 在任何代表您行事之人的占有、保管或控制之下，\n\n案件 22-50073 文书 1592 提交日期 03/24/23 登记日期 03/24/23 10:57:37 第 134 页，共 1063 页\n\n包括您的律师或其他代表和顾问。每份文档均应完整提供。\n\n6. 如要求您提供已不再由您占有、保管或控制的文档，则您的答复必须：(a) 详细说明该文档的性质及其内容；(b) 识别编制或撰写该文档的人员（以及，如适用，文档被发送给的人员）；(c) 识别该文档编制或创建的日期；(d) 说明该文档是否 (i) 缺失或遗失，(ii) 已被销毁，(iii) 已自愿或非自愿转交给他人，或 (iv) 以其他方式被处置；(e) 说明该等处置的原因以及相关事实和情形；(f) 识别授权该等处置的人员；(g) 识别该等处置的日期或大致日期；(h) 说明该文档最近一次处于您的占有、保管或控制之下的时间；及 (i) 识别现时占有、保管或控制该文档的人员（如有）。\n\n7. 如要求您提供已被销毁的文档，则除前述指示所要求的信息外，您的答复还必须说明：(a) 该文档被销毁的原因；(b) 销毁该文档的人员身份；及 (c) 指示销毁该文档的人员身份。\n\n8. 如您主张所请求的文档享有特权或属于律师工作成果，则您的答复必须：(a) 说明 (i) 足以支持您关于该文档享有特权之主张的文档说明，(ii) 文档标题，(iii) 文档日期，(iv) 文档作者，(v) 文档收件人，(vi) 收到或阅览文档原件或任何草稿、副本或复制件的每一人员身份，(vii) 该文档本身或文档所载或提及的任何信息是否处于任何其他人员的占有、保管或控制之下；如是，则说明该等人员身份，\n\n案件 22-50073 文书 1592 提交日期 03/24/23 登记日期 03/24/23 10:57:37 第 135 页，共 1063 页\n\n以及说明该信息如何进入其占有范围，(viii) 据以扣留该文档的特权主张，及 (ix) 您将据以支持该等特权主张的全部情形；及 (b) 依照 D. Conn. L. Civ. R. 26(e)，就基于特权主张而扣留的每份文档，制作一份载有本指示第 (a) 部分要求的全部信息的特权日志。对于文档请求中未主张特权或工作成果的任何部分，应完整提供响应性文档。\n\n9. 如原本具有响应性的文档的一部分包含受特权主张约束的信息，则仅应按照上述指示从该文档中删除或遮盖受特权主张约束的该部分，其余部分应予提供。\n\n10. 该等请求具有持续性。特此指示您：(a) 一旦获知先前答复不完整或不正确，应立即补充或更正其后获知不完整或不正确的任何答复；及 (b) 提供根据该等请求所要求的任何补充文档。\n\n11. 如文档使用英语以外的语言，您应提供该文档。如文档使用英语以外的语言，且存在英文译本，您应同时提供两份文档。\n\n12. 对实体的所有提及均包括其所有关联方。\n\n13. 对个人姓名的所有提及均包括所有替代姓名、别名或昵称。\n\n案件 22-50073 文书 1592 提交日期 03/24/23 登记日期 03/24/23 10:57:37 第 136 页，共 1063 页\n\n14. 除非另有明确说明，文档请求涵盖的期间为自 February 5, 2015 起至文档请求答复到期之日止。\n\nII. 解释规则\n\n15. (a) 任何单数名词的使用应解释为包括复数，反之亦然；及 (b) 任何时态动词的使用应解释为使用该动词的所有其他时态。\n\n16. (a) “和”及“或”应视需要作连词或析取词解释，以将所有原本可能被解释为超出任何请求范围的答复纳入该请求范围；及 (b) “每一”及“任何”应视为包括并涵盖“每个”及“所有”二词。\n\nIII. 定义\n\n经 D. Conn. Bankr. L.R. 2004-1(a) 纳入的 D. Conn. L. Civ. R. 26(c) 所规定的定义以及 D. Conn. L. Civ. R. 26(d) 所规定的解释规则，应适用于文档请求。此外，本文件请求中使用的下列术语具有如下含义：\n\n1. “您”或“您的”或“您本人”系指 Zhizhe “Frank” Dong（董志哲），以及其任何雇员、代理人、律师、顾问或任何代表其行事之人。\n\n2. “债务人”系指 Ho Wan Kwok（郭文贵）（又名 Miles Kwok、Miles Guo、Guo Wengui、Guo Haoyun、郭文贵或任何其他别名），以及其雇员、代理人、律师、顾问或任何代表其行事之人。\n\n案件 22-50073 文书 1592 提交日期 03/24/23 登记日期 03/24/23 10:57:37 第 137 页，共 1063 页\n\n3. “债务人之子”系指 Qiang Guo（郭强）（又名 Mileson Kwok、郭强或任何其他别名），以及其雇员、代理人、律师、顾问或任何代表其行事之人。\n\n4. “债务人之女”系指 Mei Guo（郭美）（又名 Mei Gui、郭美或任何其他别名），以及其雇员、代理人、律师、顾问或任何代表其行事之人。\n\n5. “债务人所谓的妻子”系指 Hing Chi Ngok（岳庆芝）（又名 Hing Chi Ng、Yue Qingzhi、岳庆芝或任何其他别名），以及其雇员、代理人、律师、顾问或任何代表其行事之人。\n\n6. “债务人家庭成员”统称债务人、债务人之子、债务人之女及债务人所谓的妻子，以及与债务人具有任何其他家庭关系的人。\n\n7. “关联个人”单独或统称所有符合下列情形的个人：(1) 持有、控制、保管债务人或债务人家庭成员拥有、控制或享有的资产，或对该等资产拥有酌处权；或 (2) 曾为一个或多个关联实体的雇员、董事，或以其他方式与其有关联者，以及前述各方各自的雇员、代理人、律师、顾问或任何代表前述任何一方行事之人。该等关联个人包括但不限于：Daniel Podhaskie（丹尼尔·波德哈斯基）、Karin Maistrello（卡琳·迈斯特雷洛）、Melissa Francis（梅利莎·弗朗西斯）、Anthony DiBattista（安东尼·迪巴蒂斯塔）、Han Chunguang（韩春光）（又名 韩春光）、Qu Guojiao（屈国姣）（又名 Qu Guo Jiao、屈国姣）、Zhang Wei（张伟）（又名 张伟*）、Lihong Wei Lafrenz（魏丽红）（又名 Sara Wei、魏丽红）、Max Krasner（马克斯·克拉斯纳）、Yvette Wang（王雁平）（又名 Yanping Wang、Yan Ping Wang、王雁平）、Fiona Yu（菲奥娜·余）及 Je Kin Ming（余建明）（又名 William Je、Yu Jianming、余建明）。\n\n8. “关联实体”单独或统称所有符合下列情形的任何类型组织或实体：(1) 曾由债务人或债务人家庭成员拥有、控制或投资；或 (2) 对任何由其拥有的资产直接或间接享有权益，\n\n案件 22-50073 文书 1592 提交日期 03/24/23 登记日期 03/24/23 10:57:37 第 138 页，共 1063 页\n\n由债务人或债务人家庭控制或享有的，并包括各自的雇员、代理人、法律顾问、顾问或代表前述任何一方行事的任何人。此类关联实体包括但不限于：7 Nod Hill LLC（7诺德山有限责任公司）、ACA Investment Management Limited（ACA投资管理有限公司）、ACA Capital Group Limited（ACA资本集团有限公司）、Ace Decade Holdings Limited（王牌十年控股有限公司）、AI Group Holdings Inc.（AI集团控股公司）、Booming Sail New York LLC（扬帆纽约有限责任公司）、Bravo Luck Limited（幸运喝彩有限公司）、China Golden Spring (Hong Kong) Limited（中国金泉〔香港〕有限公司）、Crane Advisory Group LLC（鹤顾问集团有限责任公司）、Dawn State Limited（黎明州有限公司）、Eastern Profit Corporation Limited（东方利润有限公司）、Freedom Media Ventures Ltd.（自由媒体创投有限公司）、G Club Operations LLC（G俱乐部运营有限责任公司）、G Fashion LLC（G时尚有限责任公司）、G News LLC（G新闻有限责任公司）、GETTR USA（GETTR美国）、Genever Holdings Corporation（吉尼维尔控股公司）、Genever Holdings LLC（吉尼维尔控股有限责任公司）、Gfashion Media Group Inc.（G时尚媒体集团公司）、GFNY, Inc.（GFNY公司）、Golden Spring (New York) Ltd.（金泉〔纽约〕有限公司）、Greenwich Land LLC（格林尼治土地有限责任公司）、GTV Media Group, Inc.（GTV媒体集团公司）、Hamilton Capital Holdings Inc.（汉密尔顿资本控股公司）、HCHK Property Management, Inc.（HCHK物业管理公司）、HCHK Technologies, Inc.（HCHK科技公司）、Himalaya Embassy（喜马拉雅大使馆）、Himalaya Exchange（喜马拉雅交易所）、Himalaya Federal Reserve（喜马拉雅联邦储备）、Himalaya Investment LLC（喜马拉雅投资有限责任公司）、Himalaya International（喜马拉雅国际）、Himalaya New World Inc.（喜马拉雅新世界公司）、Himalaya Supervisory Organization（喜马拉雅监督组织）、Himalaya Ventures LLC（喜马拉雅创投有限责任公司）、HK International Funds Investments (USA) Limited LLC（香港国际基金投资〔美国〕有限责任公司）、Hong Kong International Funds Investments Limited（香港国际基金投资有限公司）、Hudson Diamond Holding（哈德逊钻石控股）、Infinity Treasury Management Inc.（无限资金管理公司）、Lexington Property and Staffing（列克星敦物业及人力配置）、Long Gate Limited（龙门有限公司）、Maywind Trading LLC（五月风贸易有限责任公司）、MOS Himalaya LLC（MOS喜马拉雅有限责任公司）、New Federal State of China（中国新联邦国，亦称 NFSC）、Rule of Law Foundation III, Inc.（法治基金会III公司）、Rule of Law Foundation IV, Inc.（法治基金会IV公司）、Rule of Law Fund（法治基金）、Rule of Law Society（法治协会）、Rule of Law Society IV, Inc.（法治协会IV公司）、G-Translators PTY LTD（G-翻译员有限公司）、Saraca Media Group, Inc.（娑罗传媒集团公司）、Well Origin Ltd.（良好起源有限公司）、Whitecroft Shore Limited（怀特克罗夫特海岸有限公司）及 ZIBA Limited（ZIBA有限公司）。\n\n9. “包括”或其任何变体，是指“包括但不限于”。\n\n10. “和”与“或”是指“和/或”，并应以连词和析取词两种方式解释，以最大限度地扩大其范围。\n\n11. “任何”和“所有”及“每一”是指“每一及全部”。\n\n案件 22-50073 文件 1592 于 03/24/23 提交 于 03/24/23 10:57:37 登记 第 139 页，共 1063 页\n\n12. “每一”和“全部”是指“每一及全部”。\n\n13. “第三方”是指除您本人以外的个人或实体。\n\n14. “转让”应具有《破产法典》第 101(54) 条赋予其的含义。\n\n15. “文档”是指属于《联邦民事诉讼规则》第 34 条范围内的任何信息或物品，并包括但不限于任何种类、类型、性质或描述的、现处于或曾处于您占有、保管或控制之下的每一份书面、记录或图形材料，包括电子邮件的所有印刷及电子副本、以电子形式保存的计算机文件、信函、备忘录、磁带、速记或手写笔记、任何种类的书面表格、图表、蓝图、绘图、草图、曲线图、计划、文章、规格、日记、信件、电报、照片、会议记录、合同、协议、调查资料、计算机打印件、任何种类的数据汇编、电传、传真、电子邮件、短信、即时消息、语音留言、发票、订购单、支票、汇票、对账单、贷项通知单、报告、头寸报告、摘要、索引、书籍、账簿、笔记本、附表、透明胶片、录音、目录、广告、宣传材料、胶片、录像带、录音带、CD、计算机磁盘、宣传册、小册子、穿孔卡、工时单、推文、社交媒体帖子或任何其他种类的书面或记录材料，以及其所有元数据，无论以何种方式存储（无论为有形或电子形式）、记录、制作或复制；还包括但不限于前述任何材料的草稿或副本，如其中包含原始文档中不存在的任何种类的笔记、评论或标记，或在其他方面与原始文档不相同。\n\n案件 22-50073 文件 1592 于 03/24/23 提交 于 03/24/23 10:57:37 登记 第 140 页，共 1063 页\n\n16. “个人”是指个人、公司、独资企业、合伙企业、协会或任何其他实体。“个人”还包括任何代理人、代表或专家，包括但不限于律师或财务顾问。\n\n17. “实体”是指任何自然人、公司、合伙企业、子公司、独资企业、商号、董事会、合资企业、协会、机构、主管机关、委员会或其他商业实体或法人，以及任何关联方、代理人、母公司，包括但不限于法律顾问、财务顾问或任何其他代表。\n\n18. “关于”是指涉及、描述、构成、提及、与之有关、支持、有利于、反对、强化、削弱、载于、结合考虑、与之相关、证明、表明、报告、记录、暗示、回应、与之连接、评论、就其而言、有关、与之相关、讨论、显示、描述、反映、分析、构成及为。\n\n19. “与……有关”、“与……相关”或“相关的”，在提及任何特定主题事项时，是指但不限于构成、包括、涉及、包含、体现、反映、识别、陈述、直接或间接提及或以任何方式与所识别的特定主题事项相关的任何文档。\n\n20. “通信”是指在最广泛可能的意义上且不受限制地传递任何信息或知识（以事实、观点、询问或其他形式）。通信还指所有谈话、协议、询问或答复，无论是当面、通过电话、书面方式或通过电子传输设备进行，并包括但不限于所有信函、电子邮件、录音、传送单、备忘录、电话通信、语音留言、电报、传真、电传、即时消息、聊天、短信、向留言板或群聊发布的帖子、社交媒体帖子、推文、视频\n\n案件 22-50073 文件 1592 于 03/24/23 提交 于 03/24/23 10:57:37 登记 第 141 页，共 1063 页\n\n上传至任何视频平台、电话记录，或在内部或与第三方传送的笔记。\n\n21. “资产”是指受占有、保管或控制的任何具有经济价值的项目。资产包括所有不动产和动产，包括但不限于房地产、土地、房屋、公寓、共管公寓、汽车、游艇、船只、飞机、喷气机、直升机、现金、银行账户、加密货币、证券、应收账款、存货及其他有形和无形财产。\n\nIV. 应提交的文档\n\n1. 关于位于 781 Fifth Avenue, New York, NY 10022 的 Sherry Netherland Hotel / Condominium（雪莉荷兰酒店/共管公寓）（公寓 1801 和 1519）；位于 373 Taconic Rd., Greenwich, Connecticut 06831 的住宅房产；位于 33 Ferncliff Rd., Cos Cob, Connecticut 06807 的住宅房产；位于 354 Nod Hill Rd., Wilton, Connecticut 06897 的住宅房产；位于 32 Chateau Ridge Rd., Greenwich, Connecticut 06831 的房产；位于 110 Clapboard Ridge Rd., Greenwich, Connecticut 06830 的房产；位于 66 Sherwood Avenue, Greenwich, Connecticut 06831 的房产；位于 140 Wallacks Drive, Stamford, Connecticut 06902 的房产；位于 602 Indian Field Drive, Greenwich, Connecticut 06830 的房产；以及位于 11 Hurlingham Drive, Greenwich, Connecticut 06831 的房产的所有文档和通信。\n\n2. 与债务人、债务人财产、债务人家庭或关联实体的任何收入或资产有关的所有文档或通信，包括但不限于位于 Connecticut 的任何不动产。\n\n案件 22-50073 文件 1592 于 03/24/23 提交 于 03/24/23 10:57:37 登记 第 142 页，共 1063 页\n\n3. 与债务人、债务人家庭的任何成员和/或任何关联实体签订的任何聘用函有关的所有文档或通信，包括该等聘用函的副本。\n\n4. 与基于您对债务人、债务人家庭或关联实体的代理而向您支付任何预付费用或佣金有关的所有文档或通信，包括足以识别该预付费用或佣金的金额及其来源的文档。\n\n5. 与您从债务人、债务人家庭、家庭关联实体或关联实体收取或代表其收取，并存放于托管账户或客户信托账户中的任何费用、付款或款项有关的所有文档或通信。\n\n6. 足以显示债务人、债务人家庭或关联实体向您支付、代表其向您支付或为其利益向您支付的任何款项的金额、日期及来源的文档。\n\n7. 您与债务人、债务人家庭或任何关联个人、代理人、雇员或代表债务人行事的其他个人之间，就与债务人、债务人财产、债务人家庭或关联实体有关的任何转让、投资或其他交易或业务往来所进行的所有通信。\n\n8. 与涉及债务人、债务人家庭或任何关联实体的任何出售、潜在出售、收购、处置、购买、潜在购买、投资、出资、赠与、授信、贷款或转让有关的所有文档和通信。\n\n9. 与债务人使用属于债务人家庭、关联实体或关联个人、由其控制或其拥有全部或部分所有权的任何资产有关的所有文档和通信，\n\n案件 22-50073 文件 1592 于 03/24/23 提交 于 03/24/23 10:57:37 登记 第 143 页，共 1063 页\n\n包括但不限于位于 Connecticut 的任何不动产。\n\n10. 关于与债务人、债务人财产、债务人家庭、关联实体或关联个人有关的任何资产负债表、银行对账单、账户对账单、财务报表、账户报表、电汇指示和/或确认、资金证明、存款证、持有证明、投资组合摘要或类似文档的所有文档和通信，包括但不限于足以显示向前述任何一方进行的所有转让的全部文档。\n\n案件 22-50073 文件 1592 于 03/24/23 提交 于 03/24/23 10:57:37 登记 第 144 页，共 1063 页\n\n附件 C-7\n\nB2540（表格 2540——《规则 2004 审查传票》）（12/15）案件 22-50073 文件 1592 于 03/24/23 提交 于 03/24/23 10:57:37 登记 第 145 页，共\n\n美国破产法院\n\nConnecticut District（康涅狄格地区）\n\n关于 HO WAN KWOK（郭文贵）等人，\n\n1 案件编号 22-50073 (JAM) 债务人 第 11 章\n\n（合并管理）\n\n规则 2004 审查传票\n\n致：Mary Dowdle（玛丽·道德尔，亦称 Muffin Dowdle〔玛芬·道德尔〕）\n\n（传票送达对象姓名）\n\n证言：兹命令您于下列规定的时间、日期和地点出席，并根据《联邦破产程序规则》第 2004 条接受审查并作证。随附准许该项审查的法院命令副本。\n\n地点　日期和时间\n\nPaul Hastings LLP（保罗·黑斯廷斯律师事务所）\n200 Park Avenue　[TBD]\nNew York, New York 10166\n\n审查将以以下方式记录：法庭书记员/速记员\n\n提交：您或您的代表还必须携带下列文档、电子存储信息或物品参加审查，并必须允许对该等材料进行检查、复制、测试或抽样：\n\n见随附的《文档提交请求》。\n\n以下《联邦民事诉讼规则》第 45 条规定已附上；该条通过《联邦破产程序规则》第 9016 条适用于破产案件——有关履行地点的第 45(c) 条；有关您作为传票所涉人员之保护的第 45(d) 条；以及有关您答复本传票的义务及未作答复可能后果的第 45(e) 条和第 45(g) 条。\n\n日期：March , 2023\n\n法院书记员\n\n或\n\n书记员或副书记员签名　律师签名\n\n签发或请求签发本传票、代表第 11 章受托人 Luc A. Despins（卢克·A·德斯平斯）的律师之姓名、地址、电子邮件地址及电话号码如下：\n\nDouglas S. Skalka, Esq.；Neubert, Pepe & Monteith, P.C.；195 Church Street, New Haven, Connecticut 06510；dskalka@npmlaw.com；(203) 821-2000\n\n向签发或请求本传票之人的通知\n\n如本传票要求在审判前提交文件、电子存储信息或有形物品，或检查场所，则必须在向本传票所指向之人送达之前，向各方当事人送达通知及本传票副本。Fed. R. Civ. P. 45(a)(4)。\n\n软件版权所有 (c) 1996-2022 Best Case, LLC（贝斯特凯斯有限责任公司）- www.bestcase.com Best Case Bankruptcy 1 本第11章案件中的债务人为 Ho Wan Kwok（郭文贵）（亦称 Guo Wengui、Miles Guo 和 Miles Kwok，以及众多其他别名）（税务识别号码后四位：9595）、Genever Holdings LLC（Genever控股有限责任公司）（税务识别号码后四位：8202）及 Genever Holdings Corporation（Genever控股公司）。受托人、Genever Holdings LLC 及 Genever Holdings Corporation 的邮寄地址为 Paul Hastings LLP（普衡律师事务所），200 Park Avenue, New York, NY 10166，c/o Luc A. Despins，作为 Ho Wan Kwok 遗产的受托人（仅限通知及通信之目的）。\n\n送达证明\n\n（除非 Fed. R. Civ. P. 45 要求，否则本节不应向法院提交。）\n\n本人于（日期）收到向（个人姓名及职务，如有）发出的本传票。\n\n本人以下列方式向所列明之人交付副本，送达本传票：\n\n于（日期）；或\n\n本人未执行而退回本传票，原因如下：\n\n除非本传票系代表美国或其官员或代理人签发，本人还已向证人支付一天出席费用及法律允许的里程费，金额为 $ 。\n\n本人的费用为差旅费 $ 及服务费 $，合计 $ 。\n\n本人在伪证处罚的约束下声明，该等信息真实且正确。\n\n日期：\n\n送达人员签名\n\n印刷体姓名及职务\n\n送达人员地址\n\n有关尝试送达等事项的补充信息：\n《联邦民事诉讼规则》第45(c)、(d)、(e)及(g)条（自12/1/13起生效）（根据《联邦破产程序规则》第9016条适用于破产案件）\n(c) 履行地点。\n\n(1) 审判、听证或证言录取。传票仅可按下列方式命令某人出席审判、听证或证言录取：\n\n(A) 在该人居住、受雇或经常亲自从事商业活动地点100英里以内；或\n\n(B) 在该人居住、受雇或经常亲自从事商业活动所在州内，若该人：\n\n(i) 为当事人或当事人的高级职员；或\n\n(ii) 被命令出席审判，且不会产生重大费用。\n\n(2) 其他证据开示。传票可命令：\n\n(A) 在该人居住、受雇或经常亲自从事商业活动地点100英里以内的地点提交文件、电子存储信息或物品；以及\n\n(B) 在应检查的场所检查场所。\n(d) 对受传票约束之人的保护；执行。\n\n(1) 避免不当负担或费用；制裁。负责签发及送达传票的一方当事人或律师，必须采取合理措施，避免对受传票约束之人施加不当负担或费用。要求履行的地区法院必须执行该义务，并对未遵守者施加适当制裁，该制裁可包括损失的收入及合理的律师费。\n\n(2) 命令提交材料或允许检查。\n\n(A) 无须出庭。被命令提交文件、电子存储信息或有形物品，或允许检查场所之人，无须亲自到提交或检查地点出庭，除非同时被命令出席证言录取、听证或审判。\n\n(B) 异议。被命令提交文件或有形物品或允许检查之人，可向传票指定的当事人或律师送达书面异议，反对检查、复制、测试或抽样任何或全部材料，或反对检查场所，或反对以所要求的形式提交电子存储信息。异议必须在规定履行时间届满前或传票送达后14日内（以较早者为准）送达。如提出异议，适用下列规则：\n\n(i) 送达人可随时通知被命令之人，并向要求履行的地区法院提出动议，请求作出强制提交或检查的命令。\n\n(ii) 仅可依命令指示要求实施该等行为，且该命令必须保护非当事人亦非当事人高级职员之人，使其免受因履行而产生的重大费用。\n(3) 撤销或修改传票。\n\n(A) 必须撤销或修改的情形。经及时动议，要求履行的地区法院必须撤销或修改具有下列情形的传票：\n\n(i) 未给予合理的履行时间；\n\n(ii) 要求人在第45(c)条规定的地域限制以外履行；\n\n(iii) 在无适用例外或豁免的情况下，要求披露享有特权或受其他保护的事项；或\n\n(iv) 对某人施加不当负担。\n\n(B) 可以撤销或修改的情形。为保护受传票约束或受其影响之人，要求履行的地区法院可经动议，在传票要求下列事项时撤销或修改传票：\n\n(i) 披露商业秘密或其他保密的研究、开发或商业信息；或\n\n(ii) 披露未受聘专家的意见或信息，该等意见或信息并非描述争议中的特定事件，且源自未由当事人请求的该专家研究。\n\n(C) 以规定条件作为替代方案。在第45(d)(3)(B)条所述情形中，如送达方：\n\n(i) 证明其对证言或材料具有实质性需要，且不承受不当困难即无法通过其他方式满足该需要；并且\n\n(ii) 确保被传唤之人将获得合理报酬，\n\n法院可不撤销或修改传票，而是命令在规定条件下出庭或提交。\n(e) 对传票作出回应时的义务。\n\n(1) 提交文件或电子存储信息。下列程序适用于提交文件或电子存储信息：\n\n(A) 文件。回应提交文件传票之人，必须按文件在正常业务过程中保存的方式提交，或必须对文件进行整理和标记，使其与请求中的类别相对应。\n\n(B) 未规定电子存储信息的提交形式。如传票未规定电子存储信息的提交形式，回应之人必须以其通常保存的某一形式或多种形式，或以合理可用的某一形式或多种形式提交。\n\n(C) 电子存储信息仅以一种形式提交。回应之人无须以一种以上形式提交相同的电子存储信息。\n\n(D) 无法访问的电子存储信息。回应之人无须从其认定因不当负担或费用而无法合理访问的来源，提供电子存储信息的证据开示。对于强制证据开示动议或保护令动议，回应之人必须证明该信息因不当负担或费用而无法合理访问。如作出该证明，法院在考虑第26(b)(2)(C)条的限制后，如请求方证明有正当理由，仍可命令从该等来源进行证据开示。法院可为该证据开示规定条件。\n\n(2) 主张特权或保护。\n\n(A) 被扣留的信息。以该信息享有特权或作为审判准备材料受到保护为由扣留被传唤信息之人，必须：(i) 明确提出该主张；并且\n\n(ii) 以在不披露本身享有特权或受保护信息的前提下，使当事人能够评估该主张的方式，说明被扣留文件、通信或有形物品的性质。\n\n(B) 已提交的信息。如为回应传票而提交的信息受到特权主张或作为审判准备材料受保护的主张约束，提出该主张之人可将该主张及其依据通知任何收到该信息的当事人。收到通知后，当事人必须迅速返还、隔离或销毁指定信息及其持有的任何副本；在该主张得到解决前不得使用或披露该信息；如该当事人在收到通知前已披露该信息，必须采取合理措施取回该信息；并可迅速将该信息密封提交至要求履行的地区法院，以裁定该主张。提交该信息之人必须在该主张得到解决前保存该信息。\n\n(g) 藐视法庭。要求履行的地区法院，以及在动议被移送后签发传票的法院，可对已被送达但无充分理由不遵守传票或相关命令之人，以藐视法庭论处。\n\n有关查阅传票材料，请参见 Fed.R.Civ.P.45(a) 委员会说明（2013）\n\n……\n\n文件提交请求\nI. 指示\n\n1. 除非另有说明，下列文件请求（统称“请求”，每一项称为“一项请求”）必须分别并具体作出回应。每项请求均应得到完整答复，除非善意提出异议；如提出异议，应依下文规定详细说明贵方异议的理由。如异议仅涉及某项请求的一部分，或其中包含的某一词语、短语或条款，贵方仅须说明对该部分的异议，并对其余请求作出回应。\n\n2. 电子存储信息必须按照下列指示提交：\n\na. 图像。黑白图像必须为300 DPI Group IV 单页 TIFF 文件。彩色图像必须以 JPEG 格式提交。文件名不得包含嵌入空格或特殊字符（包括逗号）。文件夹名称不得包含嵌入空格或特殊字符（包括逗号）。所有 TIFF 图像文件必须具有唯一文件名，即 Bates 编号。图像必须在每张图像右下角标注连续的 Bates 编号。每个文件夹中的 TIFF 文件数量不得超过1000个文件。Excel 电子表格应具有以该文件的 Bates 编号命名的占位图像。\n\nb. 图像加载文件\na. Concordance® 数据文件。数据文件（.DAT）包含将加载到 Concordance® 数据库中的所有字段信息。.DAT 文件第一行必须为标明字段名称的标题行。.DAT 文件必须使用以下 Concordance® 默认分隔符：逗号 ASCII 字符（020）引号 þ ASCII 字符（254）。日期字段应按以下格式提供：mm/dd/yyyy。日期和时间字段必须为两个单独字段。如文件包括已成像的电子邮件及附件，则必须包括附件字段，以保留电子邮件与其附件之间的父子关系。必须包括 OCRPATH 字段，以提供已提交存储介质上提取文本文件的文件路径及名称。文本文件必须以 FIRSTBATES 命名。不得在 .DAT 文件中包括文本。对于含有原生文件的文件，必须包括 LINK 字段，以提供原生文件的文件路径及名称。原生文件必须以 FIRSTBATES 命名。\n\nb. Concordance Image® 或 Opticon 交叉引用文件。图像交叉引用文件（.LOG 或 .OPT）将图像与数据库记录关联。该文件应为以逗号分隔的文件，每行由七个字段组成，且数据库中的每个图像均应在交叉引用文件中对应一行，格式如下：ImageID,VolumeLabel,ImageFilePath,DocumentBreak,FolderBreak,Box Break,PageCount。\n\nc. 文档文本。文本必须作为独立的文本文件提供，而非作为 .DAT 文件中的字段。应在 .DAT 文件中包含文本文件的完整路径（OCRPATH）。建议提供以 FIRSTBATES/Image Key 命名的文档级 ANSI 文本文件。提取的文本文件必须置于单独文件夹中，且每个文件夹中的文本文件数量不得超过 1,000 个。文件夹名称中不得含有特殊字符（包括逗号）。文本文件必须按文档级别提供。\n\nd. 特定文件类型的原生文件提供。为完整理解其内容和含义而合理需要以原生格式查看的文件类型，必须以原生格式提供。这些文件包括但不限于：电子表格、类电子表格文件（Microsoft Excel、逗号分隔值、制表符分隔值等）、Microsoft PowerPoint 或其他特殊演示文稿文件、数据库文件以及音频/视频文件。应提供一张带有 Bates 编号的分隔页图像，以表明原生文件的存在，并在 .dat 文件中将原生文件路径作为一个字段列入。所提供的原生文件应以与该文件分隔页相对应的 Bates 编号命名。原生文件应归入按递增方式命名的“NATIVE”目录中，并与图像目录分开。\n\ne. 去重。对于存在完全重复副本的每一电子文档，应仅提供一份副本。对于电子邮件，应根据由 BCC、Body、CC、From、IntMsgID、To 和 Attach 属性生成的 MD5 哈希值合并重复项。对于电子邮件附件和独立电子文件，应根据整个文件的 MD5 哈希值合并重复项。\n\nf. 元数据。应以符合 Concordance 要求的加载文件（.dat）形式提供每份文档的提取元数据。.DAT 文件的第一行必须为标识字段名称的标题行。.DAT 文件必须使用以下 Concordance 默认分隔符：逗号 , ASCII 字符（020）引号 þ ASCII 字符（254）\n\n日期字段应按如下格式提供：mm/dd/yyyy。日期和时间字段必须为两个独立字段。以下列出所需元数据：\nCase 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 150 of 1063\n\n字段名称　示例数据　说明\n\nFIRSTBATES　EDC0000001　原生文件文档/电子邮件的第一个 Bates 编号\n\nLASTBATES　EDC0000001　原生文件文档/电子邮件的最后一个 Bates 编号\n\n单页文档应填写 LASTBATES 字段\n\nATTACHRANGE　EDC0000001\n-　父文档第一页的 Bates 编号至最后一个附件“子”文档最后一页的 Bates 编号\nEDC0000015\n\nBEGATTACH　EDC0000001　附件范围的第一个 Bates 编号\n\nENDATTACH　EDC0000015　附件范围的最后一个 Bates 编号\n\nCUSTODIAN　Smith, John　电子邮件：电子邮件所在的邮箱\n原生文件：文档源自其文件的个人或部门名称\n\nFROM　John Smith　电子邮件：发件人\n原生文件：文档作者\n多个条目应以分号分隔\n\nTO　Coffman, Janice; LeeW　收件人\n[mailto:LeeW@MSN.com]　多个条目应以分号分隔\n\nCC　Frank Thompson [mailto:　抄送收件人\nfrank_Thompson@cdt.com]　多个条目应以分号分隔\n\nBCC　John Cain　密送收件人\n多个条目应以分号分隔\n\nSUBJECT　Board Meeting Minutes　电子邮件：电子邮件主题行 原生文件：文档标题（如有）\n\nFILE_NAME　BoardMeetingMinutes.docx　原生文件：原始原生文件名称，包括扩展名\n\nDATE_SENT　10/12/2010　电子邮件：电子邮件发送日期\n原生文件：（空）\n\nTIME_SENT/\nTIME_ZONE　07:05 PM GMT　电子邮件：电子邮件发送时间/电子邮件标准化所采用的时区\n\nTIME_ZONE　GMT　在转换期间电子邮件被标准化所采用的时区。\n\nLINK　EDC0000001.msg　电子邮件或原生文件文档的超链接\n链接文件必须按 FIRSTBATES 编号命名\n\nFILE_EXTEN　MSG　代表电子邮件或原生文件的文件类型扩展名\n\nAUTHOR　John Smith　电子邮件：（空）\n原生文件：文档作者\n\nDATE_CREATED　10/10/2010　电子邮件：（空）\n原生文件：文档创建日期\nCase 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 151 of 1063\n\nTIME_CREATED　10:25 AM　电子邮件：（空）\n原生文件：文档创建时间\n该数据必须为独立字段，不得与 DATE_CREATED 字段合并\n\nDATE_MOD　10/12/2010　电子邮件：（空）\n原生文件：文档最后修改日期\n\nTIME_MOD　07:00 PM　电子邮件：（空）\n原生文件：文档最后修改时间\n该数据必须为独立字段，不得与 DATE_MOD 字段合并\n\nDATE_ACCESSD　10/12/2010　电子邮件：（空）\n原生文件：文档最后访问日期\n\nTIME_ACCESSD　07:00 PM　电子邮件：（空）\n原生文件：文档最后访问时间\n该数据必须为独立字段，不得与 DATE_ACCESSD 字段合并\n\nFILE_SIZE　5,952　原生文件文档/电子邮件的大小，单位为 KB\n\nPGCOUNT　1　原生文件文档/电子邮件的页数\n\nPATH　电子邮件：（空）\nAgenda.doc　原生文件：存储原生文件文档的路径，包括原始文件名。\n\nINTFILEPATH　Personal Folders\\Deleted　电子邮件：电子邮件的原始位置，包括原始文件名。\nItems\\Board Meeting　原生文件：（空）\nMinutes.msg\n\nINTMSGID　<000805c2c71b\\$75977050\\$　电子邮件：唯一消息 ID 原生文件：（空）\ncb8306d1@MSN>\n\nMD5HASH　d131dd02c5e6eec4693d9a0　文档的 MD5 哈希值。\n698aff95c\n2fcab58712467eab4004583e\nb8fb7f89\n\nOCRPATH　TEXT/001/EDC0000001.txt　原生文件提取文本的路径\n\n3. 每项请求均独立适用并应独立解释，除非另有说明，任何一项请求均不限制任何其他请求的范围。\n\n4. 所有文档均应按通常业务过程中保存的方式提供，或应予以整理和标记以对应于本请求中的类别。\n\n5. 本文所载每项请求均延及所有文档：(a) 由您占有、保管或控制的文档；或 (b) 由任何代表您行事之人占有、保管或控制的文档，\nCase 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 152 of 1063\n\n包括您的律师或其他代表及顾问。每份文档均应完整提供。\n\n6. 如要求您提供一份已不再由您占有、保管或控制的文档，则您的答复必须：(a) 详细描述该文档的性质及其内容；(b) 指明准备或撰写该文档的人员（以及，如适用，向其发送该文档的人员）；(c) 指明该文档准备或创建的日期；(d) 说明该文档是否：(i) 缺失或遗失，(ii) 已被销毁，(iii) 已自愿或非自愿地转让给他人，或 (iv) 以其他方式被处置；(e) 说明该处置的原因，以及有关该处置的事实和情形；(f) 指明授权该处置的人员；(g) 指明该处置的日期或大致日期；(h) 说明该文档最近一次由您占有、保管或控制的时间；以及 (i) 指明目前占有、保管或控制该文档的人员（如有）。\n\n7. 如要求您提供一份已被销毁的文档，则除前述指示所要求的信息外，您的答复还必须说明：(a) 该文档被销毁的原因；(b) 销毁该文档的人员身份；以及 (c) 指示销毁该文档的人员身份。\n\n8. 如您主张所请求的文档享有特权或律师工作成果保护，则您的答复必须：(a) 陈述：(i) 足以支持您关于该文档享有特权之主张的文档描述，(ii) 文档标题，(iii) 文档日期，(iv) 文档作者，(v) 文档收件人，(vi) 收到或阅览过原件或任何草稿、副本或复制件的每一人员身份，(vii) 该文档本身或该文档中载有或提及的任何信息是否由任何其他人员占有、保管或控制，如是，则该等人员的身份，以及说明该等信息如何进入其占有范围的陈述，(viii) 据以扣留该文档的特权主张，以及 (ix) 您将依赖以支持该特权主张的所有情形；以及 (b) 就基于特权主张而扣留的每份文档，依照 D. Conn. L. Civ. R. 26(e)，提供一份特权清单，其中载明本指示第 (a) 部分所要求的全部信息。对于未主张特权或工作成果保护的任何文档请求部分，应完整提供响应性文档。\n\n9. 如一份原本具有响应性的文档的一部分含有受特权主张约束的信息，则仅应依照上述指示从该文档中删除或遮蔽受该特权主张约束的部分，其余部分应予提供。\n\n10. 本请求具有持续性。现指示您：(a) 在获知先前答复不完整或不正确后，立即补充或更正任何后来发现不完整或不正确的答复；以及 (b) 提供根据以下规定所要求的任何补充文档\n\n11. 如一份文档使用英语以外的语言，您应提供该文档。如一份文档使用英语以外的语言，且存在英文译本，您应同时提供两份文档。\n\n12. 对实体的所有提述均包括其所有关联方。\n\n13. 对个人姓名的所有提述均包括所有替代姓名、别名或昵称。\nCase 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 154 of 1063\n\n14. 除非另有明确说明，文档请求所涵盖的期间为自 February 5, 2015 起至应提交文档请求答复之日止。\n\nII. 解释规则\n\n15. (a) 任何单数名词的使用应解释为包括复数，反之亦然；以及 (b) 任何时态动词的使用应解释为包括该动词所有其他时态的使用。\n\n16. (a) “and”和“or”应视需要解释为连词或选择连词，以使原本可能被解释为不在任何请求范围内的所有答复均纳入该请求范围；以及 (b) “each”和“any”应被视为包括并涵盖“every”和“all”二词。\n\nIII. 定义\n\nD. Conn. L. Civ. R. 26(c) 所提供的定义以及 D. Conn. L. Civ. R. 26(d) 所提供的解释规则，经 D. Conn. Bankr. L.R. 2004-1(a) 纳入后，适用于文档请求。此外，本文件请求中使用的下列术语具有如下含义：\n\n1. “您”或“您的”或“您本人”系指 Mary “Muffin” Dowdle（玛丽·“马芬”·道德尔），以及其任何雇员、代理人、律师、顾问或任何代表其行事之人。\n\n2. “债务人”系指 Ho Wan Kwok（郭文贵）（又名 Miles Kwok、Miles Guo、Guo Wengui、Guo Haoyun、郭文贵或任何其他别名），以及其雇员、代理人、律师、顾问或任何代表其行事之人。\nCase 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 155 of 1063\n\n3. “债务人之子”系指Qiang Guo（又名 Mileson Kwok、郭强，或任何其他别名），以及其雇员、代理人、律师、顾问或任何代表其行事之人。\n\n4. “债务人之女”系指Mei Guo（又名 Mei Gui、郭美，或任何其他别名），以及其雇员、代理人、律师、顾问或任何代表其行事之人。\n\n5. “债务人自称的妻子”系指Hing Chi Ngok（又名 Hing Chi Ng、Yue Qingzhi、岳庆芝，或任何其他别名），以及其雇员、代理人、律师、顾问或任何代表其行事之人。\n\n6. “债务人的家庭成员”统称债务人、债务人之子、债务人之女、债务人自称的妻子，以及与债务人具有任何其他家庭关系之人。\n\n7. “关联个人”单独及统称指以下所有个人：（1）持有、控制、保管或对由债务人或债务人的家庭成员拥有、控制或享有的资产具有酌处权；或（2）曾担任一个或多个关联实体的雇员、董事，或以其他方式与其有关联，以及前述各方各自的雇员、代理人、律师、顾问或任何代表前述任何一方行事之人。该等关联个人包括但不限于：Daniel Podhaskie、Karin Maistrello、Melissa Francis、Anthony DiBattista、Han Chunguang（又名韩春光）、Qu Guojiao（又名 Qu Guo Jiao、屈国姣）、Zhang Wei（又名张伟*）、Lihong Wei Lafrenz（又名 Sara Wei、魏丽红）、Max Krasner、Yvette Wang（又名 Yanping Wang、Yan Ping Wang、王雁平）、Fiona Yu和Je Kin Ming（又名 William Je、Yu Jianming、余建明）。\n\n8. “关联实体”单独及统称指以下所有类型的组织或实体：（1）曾由债务人或债务人的家庭成员拥有、控制或投资；或（2）对由债务人或债务人的家庭成员拥有、控制或享有的任何资产直接或间接拥有权益，以及前述各方各自的雇员、代理人、律师、顾问或任何代表前述任何一方行事之人。该等关联实体包括但不限于：7 Nod Hill LLC、ACA Investment Management Limited、ACA Capital Group Limited、Ace Decade Holdings Limited、AI Group Holdings Inc.、Booming Sail New York LLC、Bravo Luck Limited、China Golden Spring (Hong Kong) Limited、Crane Advisory Group LLC、Dawn State Limited、Eastern Profit Corporation Limited、Freedom Media Ventures Ltd.、G Club Operations LLC、G Fashion LLC、G News LLC、GETTR USA、Genever Holdings Corporation、Genever Holdings LLC、Gfashion Media Group Inc.、GFNY, Inc.、Golden Spring (New York) Ltd.、Greenwich Land LLC、GTV Media Group, Inc.、Hamilton Capital Holdings Inc.、HCHK Property Management, Inc.、HCHK Technologies, Inc.、Himalaya Embassy、Himalaya Exchange、Himalaya Federal Reserve、Himalaya Investment LLC、Himalaya International、Himalaya New World Inc.、Himalaya Supervisory Organization、Himalaya Ventures LLC、HK International Funds Investments (USA) Limited LLC、Hong Kong International Funds Investments Limited、Hudson Diamond Holding、Infinity Treasury Management Inc.、Lexington Property and Staffing、Long Gate Limited、Maywind Trading LLC、MOS Himalaya LLC、New Federal State of China（又名 NFSC）、Rule of Law Foundation III, Inc.、Rule of Law Foundation IV, Inc.、Rule of Law Fund、Rule of Law Society、Rule of Law Society IV, Inc.、G-Translators PTY LTD、Saraca Media Group, Inc.、Well Origin Ltd.、Whitecroft Shore Limited和ZIBA Limited。\n\n9. “包括”或其任何变体，系指“包括但不限于”。\n\n10. “和”及“或”系指“和/或”，并应为最大化其涵盖范围而同时按连词及析取词解释。\n\n11. “任何”及“所有”及“每一”系指“每一个和所有”。\n\n12. “每一”及“每个”系指“每一个和所有”。\n\n13. “第三方”系指除您以外的个人或实体。\n\n14. “转让”应具有《破产法》第101(54)条赋予其的含义。\n\n15. “文件”系指属于Fed. R. Civ. P. 34范围内的任何信息或物品，并包括但不限于任何种类、类型、性质或描述的每一项书面、记录或图形资料，而该等资料现由或曾由您占有、保管或控制，包括电子邮件、以电子形式保存的计算机文件、通信函件、备忘录、磁带、速记或手写笔记、任何种类的书面表格、图表、蓝图、图纸、草图、曲线图、计划、文章、规格说明、日记、信函、电报、照片、会议记录、合同、协议、调查、计算机打印件、任何种类的数据汇编、电传、传真、电子邮件、短信、即时消息、语音留言、发票、订购单、支票、汇票、对账单、贷项通知单、报告、头寸报告、摘要、索引、书籍、分类账、笔记本、附表、透明胶片、录音、目录、广告、宣传材料、胶片、录像带、录音带、CD、计算机磁盘、宣传册、小册子、穿孔卡、工时单、推文、社交媒体帖子或任何其他种类的书面或记录材料的所有印刷及电子副本，以及其所有元数据，无论以何种方式存储（无论为有形或电子形式）、记录、制作或复制；还包括但不限于前述任何资料的草稿或副本，如其包含原始文件中未载有的任何种类的笔记、评论或标记，或在其他方面与原始文件并不相同。\n\n16. “个人”系指个人、公司、独资企业、合伙企业、协会或任何其他实体。“个人”还包括任何代理人、代表或专家，包括但不限于律师或财务顾问。\n\n17. “实体”系指任何自然人、公司、合伙企业、子公司、独资企业、商号、董事会、合资企业、协会、机构、主管机关、委员会或其他商业实体或法人，以及任何关联方、代理人、母公司，包括但不限于律师、财务顾问或任何其他代表。\n\n18. “关于”系指涉及、描述、构成、提及、与之有关、支持、赞成、反对、加强、减损、位于其中、与之相关地予以考虑、对其有影响、证明、表明、报告、记录、暗示、回应、与之连接、评论、就其而言、关于、与之相关、讨论、显示、描述、反映、分析、构成及属于。\n\n19. 当“有关”“涉及”或“相关”用于指称任何特定主题事项时，系指包括但不限于构成、包含、涉及、载有、体现、反映、识别、陈述、直接或间接提及，或以任何方式与所识别的特定主题事项相关的任何文件。\n\n20. “通信”系指以最广泛可能的含义且不限于任何信息或知识的传递（以事实、观点、询问或其他形式）。通信还指所有对话、协议、询问或答复，无论是当面、通过电话、以书面形式，还是通过电子传输设备进行，并包括但不限于所有通信函件、电子邮件、录音、传送单、备忘录、电话通信、语音留言、电报、电话传真、传真副本、电传、即时消息、聊天、短信、发布至留言板或群聊的帖子、社交媒体帖子、推文、上传至任何视频平台的视频、电话笔记，或在内部或与第三方之间传递的笔记。\n\n21. “资产”系指受占有、保管或控制的任何具有经济价值的项目。资产包括所有不动产和动产，包括但不限于房地产、土地、房屋、公寓、共管公寓、汽车、游艇、船舶、飞机、喷气机、直升机、现金、银行账户、加密货币、证券、应收账款、存货及其他有形和无形财产。\n\nIV. 待提交的文件\n\n1. 关于位于781 Fifth Avenue, New York, NY 10022的Sherry Netherland Hotel / Condominium（Sherry Netherland酒店/共管公寓）（1801号和1519号公寓）；位于373 Taconic Rd., Greenwich, Connecticut 06831的住宅物业；位于33 Ferncliff Rd., Cos Cob, Connecticut 06807的住宅物业；位于354 Nod Hill Rd., Wilton, Connecticut 06897的住宅物业；位于32 Chateau Ridge Rd., Greenwich, Connecticut 06831的物业；位于110 Clapboard Ridge Rd., Greenwich, Connecticut 06830的物业；位于66 Sherwood Avenue, Greenwich, Connecticut 06831的物业；位于140 Wallacks Drive, Stamford, Connecticut 06902的物业；位于602 Indian Field Drive, Greenwich, Connecticut 06830的物业；以及位于11 Hurlingham Drive, Greenwich, Connecticut 06831的物业的所有文件和通信。\n\n2. 与债务人、债务人财产、债务人的家庭成员或关联实体的任何收入或资产有关的所有文件或通信，包括但不限于位于Connecticut的任何不动产。\n\n3. 与债务人、债务人的任何家庭成员及/或任何关联实体的任何委托函有关的所有文件或通信，包括该等委托函的副本。\n\n4. 与基于您对债务人、债务人的家庭成员或关联实体的代理而向您支付任何预付费用或佣金有关的所有文件或通信，包括足以识别该预付费用或佣金的金额及其来源的文件。\n\n5. 与您从债务人、债务人的家庭成员、家庭关联实体或关联实体处或代表其收取，并存放于托管账户或客户信托账户中的任何费用、付款或款项有关的所有文件或通信。\n\n6. 足以显示债务人、债务人的家庭成员或关联实体向您、代表您或为您的利益支付的任何款项的金额、日期及来源的文件。\n\n7. 您与债务人、债务人的家庭成员或任何关联个人、代理人、雇员或其他代表债务人行事之人之间，就与债务人、债务人财产、债务人的家庭成员或关联实体有关的任何转让、投资或其他交易或商业往来所进行的全部通信。\n\n8. 与涉及债务人、债务人的家庭成员或任何关联实体的任何出售、潜在出售、取得、处分、购买、潜在购买、投资、出资、赠与、授信、贷款或转让有关的所有文件和通信。\n\n9. 与债务人使用属于、由其控制或其完整或部分所有权由债务人的家庭成员、关联实体或关联个人持有的任何资产有关的所有文件和通信，包括但不限于位于Connecticut的任何不动产。\n\n10. 关于与债务人、债务人财产、债务人的家庭成员、关联实体或关联个人有关的任何资产负债表、银行对账单、账户对账单、财务报表、账目报表、电汇指示及/或确认、资金证明、存款证、持有证明、投资组合摘要或类似文件的所有文件和通信，包括但不限于足以显示向前述任何一方进行的所有转让的全部文件。\n\n案件 22-50073 文件 1592 提交于 03/24/23 录入于 03/24/23 10:57:37 第 162 页，共 1063 页\n\n附件 C-8\n\nB2540（表格 2540——依破产程序规则第 2004 条进行审查的传票）（12/15）案件 22-50073 文件 1592 提交于 03/24/23 录入于 03/24/23 10:57:37 第 163 页，共 1063 页\n\n美国破产法院\n\n康涅狄格州地区\n\n关于 HO WAN KWOK（郭文贵）等人，\n\n1 案号 22-50073 (JAM)\n\n债务人 第 11 章\n\n（合并管理）\n依破产程序规则第 2004 条进行审查的传票\n\n致：Alex Hadjicharalambous（亚历克斯·哈吉查拉兰布斯）\n\n（传票所指向之人的姓名）\n\n证言：现命令您于下列规定的时间、日期和地点出席，并根据《联邦破产程序规则》第 2004 条接受审查并作证。随附准许该审查的法院命令副本。\n\n地点　日期及时间\n\nPaul Hastings LLP（保罗·黑斯廷斯律师事务所）\n200 Park Avenue　[TBD]\nNew York, New York 10166\n\n审查将通过以下方式记录：法庭记录员／速记员\n\n提交材料：您或您的代表还必须携带下列文件、电子存储信息或物品参加审查，并必须准许对该等材料进行检查、复制、测试或取样：\n见随附的文件提交请求。\n\n根据《联邦破产程序规则》第 9016 条适用于破产案件的《联邦民事诉讼规则》第 45 条下列规定随附于此——有关履行地点的第 45(c) 条；有关对作为传票对象之人的保护的第 45(d) 条；以及有关您对本传票的答复义务及不答复的潜在后果的第 45(e) 条和第 45(g) 条。\n\n日期：March , 2023\n\n法院书记官\n\n或\n\n书记官或副书记官签名　律师签名\n\n签发或请求本传票、代理第 11 章受托人 Luc A. Despins（卢克·A·德斯平斯）的律师姓名、地址、电子邮件地址及电话号码如下：\n\nDouglas S. Skalka, Esq.（道格拉斯·S·斯卡尔卡律师）；Neubert, Pepe & Monteith, P.C.（纽伯特、佩佩与蒙蒂斯律师事务所）；195 Church Street, New Haven, Connecticut 06510 dskalka@npmlaw.com；(203) 821-2000\n\n致签发或请求本传票之人的通知\n\n如本传票命令在审判前提交文件、电子存储信息或有形物品，或检查场所，则必须在向传票所指向之人送达之前，向各方送达通知及本传票副本。Fed. R. Civ. P. 45(a)(4)。\n\n软件版权 (c) 1996-2022 Best Case, LLC - www.bestcase.com Best Case Bankruptcy 1 本第 11 章案件的债务人为 Ho Wan Kwok（又名 Guo Wengui、Miles Guo 和 Miles Kwok，以及众多其他别名）（税务识别号码后四位：9595）、Genever Holdings LLC（税务识别号码后四位：8202）及 Genever Holdings Corporation。受托人、Genever Holdings LLC 及 Genever Holdings Corporation 的邮寄地址为 Paul Hastings LLP, 200 Park Avenue, New York, NY 10166，c/o Luc A. Despins，作为 Ho Wan Kwok 财产的受托人（仅为通知和通信之目的）。\n\n送达证明\n\n（除非 Fed. R. Civ. P. 45 要求，否则本节不应向法院提交。）\n\n本人于（日期）收到向（个人姓名及职务，如有）发出的本传票。\n\n本人以下列方式向所列明之人交付副本以送达本传票：\n\n于（日期）；或\n\n本人未执行即退回本传票，原因如下：\n\n除非本传票代表美国或其官员或代理人签发，本人还已向证人支付出席一天的费用及法律允许的里程费，金额为 \\$ 。\n\n本人的差旅费用为 \\$，服务费用为 \\$，合计为 \\$。\n\n本人在伪证处罚的约束下声明，该等信息真实且正确。\n\n日期：\n\n送达人员签名\n\n印刷姓名及职务\n\n送达人员地址\n\n关于尝试送达等的补充信息：\n\n《联邦民事诉讼规则》第 45(c)、(d)、(e) 及 (g) 条（Effective 12/1/13）（根据《联邦破产程序规则》第 9016 条适用于破产案件）\n\n(c) 履行地点。\n\n(1) 审判、听证或证言录取。传票仅可按下列规定命令某人出席审判、听证或证言录取：\n\n(A) 在该人居住、受雇或经常亲自从事商业活动地点 100 英里范围内；或\n\n(B) 在该人居住、受雇或经常亲自从事商业活动所在州内，如该人\n\n(i) 是当事人或当事人的高级职员；或\n\n(ii) 被命令出席审判且不会产生重大费用。\n\n(2) 其他证据开示。传票可以命令：\n\n(A) 在该人居住、受雇或经常亲自从事商业活动地点 100 英里范围内的地点提交文件、电子存储信息或物品；以及\n\n(B) 在待检查场所对该场所进行检查。\n\n(d) 对作为传票对象之人的保护；执行。\n\n(1) 避免不当负担或费用；制裁。负责签发和送达传票的当事人或律师必须采取合理步骤，避免对作为传票对象之人施加不当负担或费用。要求履行的地区法院必须执行该义务，并对未遵守者——当事人或律师——施加适当制裁，该制裁可包括损失的收入及合理的律师费。\n(2) 提交材料或准许检查的命令。\n\n(A) 无须出席。被命令提交文件、电子存储信息或有形物品，或准许检查场所之人，无须亲自到提交或检查地点出席，除非同时被命令出席证言录取、听证或审判。\n\n(B) 异议。被命令提交文件或有形物品，或准许检查之人，可以向传票中指定的当事人或律师送达书面异议，反对检查、复制、测试或取样任何或全部材料，或反对检查场所——或反对以所要求的一种或多种形式提交电子存储信息。异议必须在规定履行的时间或传票送达后 14 天中较早者之前送达。如提出异议，则适用下列规则：\n\n(i) 送达方可随时在通知被命令之人后，向要求履行的地区法院提出动议，请求作出强制提交或检查的命令。\n\n(ii) 仅可依命令的指示要求实施该等行为，且该命令必须保护既非当事人亦非当事人高级职员之人，免于因履行而产生的重大费用。\n(3) 撤销或修改传票。\n\n(A) 必须撤销或修改的情形。经及时动议，要求履行的地区法院必须撤销或修改有下列情形的传票：\n\n(i) 未给予合理的履行时间；\n\n(ii) 要求某人在第 45(c) 条规定的地域限制之外履行；\n\n(iii) 要求披露享有特权或受其他保护的事项，且不适用任何例外或放弃；或\n\n(iv) 使某人承受不当负担。\n\n(B) 可以撤销或修改的情形。为保护作为传票对象或受传票影响之人，要求履行的地区法院可经动议撤销或修改要求下列事项的传票：\n\n(i) 披露商业秘密或其他保密研究、开发或商业信息；或\n\n(ii) 披露未受聘专家的意见或信息，该等意见或信息未描述争议中的特定事件，且源于当事人未请求的该专家研究。\n\n(C) 规定条件作为替代方式。在第 45(d)(3)(B) 条所述情形下，如送达方：\n\n(i) 证明对该证言或材料具有重大需求，且若不承受不当困难则无法以其他方式满足该需求；并且\n\n(ii) 确保被传唤之人将获得合理补偿，\n\n法院可以不撤销或修改传票，而是命令在规定条件下出席或提交材料。\n(e) 答复传票的义务。\n\n(1) 提交文件或电子存储信息。下列程序适用于提交文件或电子存储信息：\n\n(A) 文件。答复要求提交文件之传票的人必须按文件在正常营业过程中保存的方式提交，或必须将文件整理并标记，以对应请求中的类别。\n\n(B) 未规定电子存储信息的提交形式。如传票未规定电子存储信息的提交形式，答复之人必须以其通常保存的一种或多种形式，或以合理可用的一种或多种形式提交。\n\n(C) 电子存储信息仅以一种形式提交。答复之人无须以一种以上形式提交相同的电子存储信息。\n\n(D) 无法合理获取的电子存储信息。答复之人无须从其认定因不当负担或费用而无法合理获取的来源提供电子存储信息的证据开示。对于强制证据开示或保护令的动议，答复之人必须证明该信息因不当负担或费用而无法合理获取。如作出该证明，法院仍可在请求方证明具有正当理由时，考虑第 26(b)(2)(C) 条的限制，命令从该等来源进行证据开示。法院可以规定证据开示的条件。\n(2) 主张特权或保护。\n\n(A) 被扣留的信息。以信息享有特权或作为审判准备材料受到保护为由扣留传票所要求信息之人，必须：(i) 明确提出该主张；以及\n\n(ii) 以一种在不披露本身享有特权或受保护信息的情况下，能够使各方评估该主张的方式，说明被扣留文件、通信或有形物品的性质。\n\n(B) 已提交的信息。如为答复传票而提交的信息受到特权或作为审判准备材料受到保护的主张约束，提出该主张之人可以将该主张及其依据通知任何收到该信息的当事人。收到通知后，当事人必须立即返还、隔离或销毁所指定的信息及其持有的任何副本；在该主张得到解决前不得使用或披露该信息；如当事人在收到通知前已披露该信息，必须采取合理步骤取回该信息；并可立即将该信息密封提交给要求履行的地区法院，以裁定该主张。提交该信息之人必须在该主张得到解决前保存该信息。\n\n(g) 藐视法庭。要求履行的地区法院——以及在动议被移送后，签发法院——可认定已被送达但无充分理由未遵从传票或与之相关命令之人构成藐视法庭。\n\n如需查阅传票材料，见 Fed.R.Civ.P.45(a) Committee Note (2013)\n\n……\n\n文件提交请求\n\nI. 指示\n\n1. 除非另有说明，下列文件请求（以下简称“请求”，各称“一项请求”）必须分别且具体地作出答复。每项请求均应得到完整答复，除非善意地提出异议；在此情形下，应按下文规定详细陈述您提出异议的理由。如异议仅涉及某项请求的一部分，或其中包含的一个词语、短语或条款，您须仅就该部分陈述您的异议，并答复其余请求。\n\n2. 电子存储信息必须依照下列指示提交：\n\na. 图像。黑白图像必须为 300 DPI Group IV 单页 TIFF 文件。彩色图像必须以 JPEG 格式提供。文件名不得包含嵌入空格或特殊字符（包括逗号）。文件夹名称不得包含嵌入空格或特殊字符（包括逗号）。所有 TIFF 图像文件必须具有唯一文件名，即 Bates 编号。每张图像均须在其右下角标注连续的 Bates 编号。每个文件夹中的 TIFF 文件数量不得超过 1000 个文件。Excel 电子表格应具有以该文件 Bates 编号命名的占位图像。\n\nb. 图像加载文件\n\na. Concordance®（康考丹斯）数据文件。数据文件（.DAT）包含将加载至 Concordance® 数据库的所有字段化信息。.DAT 文件的第一行必须为标识字段名称的标题行。.DAT 文件必须使用以下 Concordance® 默认分隔符：逗号 ASCII 字符（020）；引号 þ ASCII 字符（254）。日期字段应采用以下格式提供：mm/dd/yyyy。日期和时间字段必须为两个独立字段。如文件包括已成像的电子邮件及附件，则必须包含附件字段，以保留电子邮件与其附件之间的父项/子项关系。必须包含 OCRPATH 字段，以提供所提取文本文件在已提供存储介质上的文件路径和名称。文本文件必须以 FIRSTBATES 命名。不得将文本包含在 .DAT 文件中。对于包含原生文件的文件，必须包含 LINK 字段，以提供原生文件的文件路径和名称。原生文件必须以 FIRSTBATES 命名。\n\nb. Concordance Image®（康考丹斯图像）或 Opticon（奥普蒂康）交叉引用文件。图像交叉引用文件（.LOG 或 .OPT）将图像链接至数据库记录。其应为逗号分隔文件，每行由七个字段组成，并且数据库中的每一图像均应在交叉引用文件中具有一行，格式如下：ImageID,VolumeLabel,ImageFilePath,DocumentBreak,FolderBreak,BoxBreak,PageCount。\n\nc. 文件文本。文本必须作为单独的文本文件提供，而不得作为 .DAT 文件中的字段提供。文本文件的完整路径（OCRPATH）应包含在 .DAT 文件中。建议提供文件级 ANSI 文本文件，并按照 FIRSTBATES/Image Key 命名。提取的文本文件必须置于单独的文件夹中，每个文件夹中的文本文件数量不得超过 1,000 个文件。文件夹名称中不得包含特殊字符（包括逗号）。文本文件必须按文件级别提供。\n\nd. 特定文件类型的原生格式提供。为充分理解其内容和含义而合理需要以原生格式查看的文件类型，必须以原生格式提供。该等文件包括但不限于电子表格、类似电子表格的文件（Microsoft Excel（微软 Excel）、逗号分隔值、制表符分隔值等）、Microsoft PowerPoint（微软 PowerPoint）或其他特殊演示文件、数据库文件以及音频/视频文件。应提供一张带有 Bates 编号的分隔页图像，注明存在原生文件，并在 .dat 文件中将原生文件路径作为一个字段列入。所提供的原生文件应以与该文件分隔页相对应的 Bates 编号命名。原生文件应归入以递增方式命名的“NATIVE”目录中，并与图像目录分开。\n\ne. 去重。对于存在完全重复件的每份电子文件，仅提供一份副本。对于电子邮件，应根据由 BCC、Body、CC、From、IntMsgID、To 和 Attach 属性生成的 MD5 哈希值合并重复件。对于电子邮件附件和独立电子文件，应根据整个文件的 MD5 哈希值合并重复件。\n\nf. 元数据。应以符合 Concordance 要求的加载文件（.dat）形式提供每份文件的提取元数据。.DAT 文件的第一行必须为标识字段名称的标题行。.DAT 文件必须使用以下 Concordance 默认分隔符：逗号 , ASCII 字符（020）；引号 þ ASCII 字符（254）。\n\n日期字段应采用以下格式提供：mm/dd/yyyy。日期和时间字段必须为两个独立字段。以下列出必需的元数据：\n\n案号 22-50073 文件 1592 提交日期 03/24/23 录入日期 03/24/23 10:57:37 第 168 页，共 1063 页\n\n字段名称　示例数据　说明\n\nFIRSTBATES　EDC0000001　原生文件文件/电子邮件的第一个 Bates 编号\nLASTBATES　EDC0000001　原生文件文件/电子邮件的最后一个 Bates 编号\nLASTBATES 字段应针对单页文件填写\nATTACHRANGE　EDC0000001\n-　父文件第一页的 Bates 编号至最后一个附件“子”文件最后一页的 Bates 编号\nEDC0000015\nBEGATTACH　EDC0000001　附件范围的第一个 Bates 编号\nENDATTACH　EDC0000015　附件范围的最后一个 Bates 编号\nCUSTODIAN　Smith, John（史密斯，约翰）　电子邮件：电子邮件所在的邮箱\n原生文件：文件来源的个人或部门名称\nFROM　John Smith（约翰·史密斯）　电子邮件：发件人\n原生文件：文件作者\n多个条目应以分号分隔\nTO　Coffman, Janice（科夫曼，贾尼斯）；LeeW（李W）\n[mailto:LeeW@MSN.com]　收件人\n多个条目应以分号分隔\nCC　Frank Thompson（弗兰克·汤普森）[mailto:\nfrank_Thompson@cdt.com]　抄送收件人\n多个条目应以分号分隔\nBCC　John Cain（约翰·凯恩）　密送收件人\n多个条目应以分号分隔\nSUBJECT　Board Meeting Minutes　电子邮件：电子邮件主题行；原生文件：文件标题（如有）\nFILE_NAME　BoardMeetingMinutes.docx　原生文件：原始原生文件的名称，包括扩展名\nDATE_SENT　10/12/2010　电子邮件：电子邮件发送日期\n原生文件：（空）\nTIME_SENT/\nTIME_ZONE　07:05 PM GMT　电子邮件：电子邮件发送时间/电子邮件标准化时所采用的时区\nTIME_ZONE　GMT　在转换期间电子邮件被标准化所采用的时区。\nLINK　EDC0000001.msg　指向电子邮件或原生文件文件的超链接\n链接文件必须按照 FIRSTBATES 编号命名\nFILE_EXTEN　MSG　表示电子邮件或原生文件的文件类型扩展名\nAUTHOR　John Smith（约翰·史密斯）　电子邮件：（空）\n原生文件：文件作者\nDATE_CREATED　10/10/2010　电子邮件：（空）\n原生文件：文件创建日期\n\n案号 22-50073 文件 1592 提交日期 03/24/23 录入日期 03/24/23 10:57:37 第 169 页，共 1063 页\n\nTIME_CREATED　10:25 AM　电子邮件：（空）\n原生文件：文件创建时间\n该数据必须为单独字段，且不得与 DATE_CREATED 字段合并\nDATE_MOD　10/12/2010　电子邮件：（空）\n原生文件：文件最后修改日期\nTIME_MOD　07:00 PM　电子邮件：（空）\n原生文件：文件最后修改时间\n该数据必须为单独字段，且不得与 DATE_MOD 字段合并\nDATE_ACCESSD　10/12/2010　电子邮件：（空）\n原生文件：文件最后访问日期\nTIME_ACCESSD　07:00 PM　电子邮件：（空）\n原生文件：文件最后访问时间\n该数据必须为单独字段，且不得与 DATE_ACCESSD 字段合并\nFILE_SIZE　5,952　原生文件文件/电子邮件的大小，以 KB 计\nPGCOUNT　1　原生文件文件/电子邮件的页数\nPATH　电子邮件：（空）\nAgenda.doc　原生文件：原生文件文件的存储路径，包括原始文件名。\nINTFILEPATH　Personal Folders\\Deleted\nItems\\Board Meeting\nMinutes.msg　电子邮件：电子邮件的原始位置，包括原始文件名。\n原生文件：（空）\nINTMSGID　<000805c2c71b\\$75977050\\$\ncb8306d1@MSN>　电子邮件：唯一邮件 ID；原生文件：（空）\nMD5HASH　d131dd02c5e6eec4693d9a0\n698aff95c\n2fcab58712467eab4004583e\nb8fb7f89　文件的 MD5 哈希值。\nOCRPATH　TEXT/001/EDC0000001.txt　原生文件提取文本的路径\n\n3. 每项请求均独立运作并应被独立解释，除非另有说明，任何一项请求均不限制任何其他请求的范围。\n\n4. 所有文件应按其在通常业务过程中保存的方式提供，或者应进行整理和标识，以对应于这些请求中的类别。\n\n5. 本文件所载的每项请求均延及所有文件：（a）由您占有、保管或控制的文件；或（b）由代表您行事的任何人占有、保管或控制的文件，\n\n案号 22-50073 文件 1592 提交日期 03/24/23 录入日期 03/24/23 10:57:37 第 170 页，共 1063 页\n\n包括您的律师或其他代表和顾问。每份文件均应完整提供。\n\n6. 如要求您提供的文件已不再由您占有、保管或控制，则您的答复必须：（a）详细说明该文件的性质及其内容；（b）确定编制或撰写该文件的人员（以及，如适用，该文件的收件人员）；（c）确定该文件编制或创建的日期；（d）说明该文件是否（i）遗失或丢失，（ii）已被销毁，（iii）自愿或非自愿地转移给他人，或（iv）以其他方式处置；（e）说明该等处置的原因以及相关事实和情形；（f）确定授权该等处置的人员；（g）确定该等处置的日期或大致日期；（h）说明该文件最近一次由您占有、保管或控制的时间；以及（i）确定目前占有、保管或控制该文件的人员（如有）。\n\n7. 如要求您提供的文件已被销毁，则除前述指示所要求的信息外，您的答复还必须说明：（a）该文件被销毁的原因；（b）销毁该文件的人员身份；以及（c）指示销毁该文件的人员身份。\n\n8. 如您主张所请求的文件享有特权或律师工作成果保护，则您的答复必须：（a）说明：（i）足以支持您关于该文件享有特权之主张的文件描述；（ii）文件标题；（iii）文件日期；（iv）文件作者；（v）文件收件人；（vi）收到或阅览该文件原件或任何草稿、副本或复制件的每一人员身份；（vii）该文件本身，或该文件中载有或提及的任何信息，是否由任何其他人员占有、保管或控制，如是，则确定该等人员的身份，\n\n案号 22-50073 文件 1592 提交日期 03/24/23 录入日期 03/24/23 10:57:37 第 171 页，共 1063 页\n\n以及说明该等信息如何进入其占有；（viii）据以扣留该文件的特权主张；以及（ix）您将据以支持该等特权主张的所有情形；以及（b）根据 D. Conn. L. Civ. R. 26(e)，就每份基于特权主张而扣留的文件，提供一份特权日志，其中载明本指示第（a）部分所要求的全部信息。\n\n9. 如一份原本具有响应性的文件的一部分包含受特权主张约束的信息，则仅应依照上述指示从该文件中删除或遮盖受该特权主张约束的部分，其余部分应予提供。\n\n10. 该等请求具有持续性。现指示您：（a）一旦得知先前答复不完整或不正确，立即补充或更正其后得知不完整或不正确的任何答复；以及（b）提供根据下列规定所要求的任何额外文件。\n\n11. 如文件为英语以外的语言，您应提供该文件。如文件为英语以外的语言，并且存在英文译本，您应同时提供两份文件。\n\n12. 对实体的所有提述均包括其所有关联方。\n\n13. 对个人姓名的所有提述均包括所有替代姓名、化名或昵称。\n\n14. 除非另有明确说明，文件请求所涵盖的期间为自 February 5, 2012 起至对文件请求作出答复的到期日止。\n\n案号 22-50073 文书 1592 提交日期 03/24/23 登记日期 03/24/23 10:57:37 第 172 页，共 1063 页\n\nII. 解释规则\n\n15. (a) 任何单数名词的使用均应解释为包括复数，反之亦然；以及 (b) 任何时态动词的使用均应解释为该动词在所有其他时态下的使用。\n\n16. (a) “和”及“或”应在必要时解释为连词或选择连词，以使任何请求的范围涵盖所有否则可能被解释为不在其范围内的答复；以及 (b) “每一”及“任何”应被视为包括并涵盖“每个”及“所有”二词。\n\nIII. 定义\n\n根据 D. Conn. L. Civ. R. 26(c) 提供的定义，以及根据 D. Conn. Bankr. L.R. 2004-1(a) 纳入的 D. Conn. L. Civ. R. 26(d) 提供的解释规则，均适用于文件请求。此外，本文件请求中使用的下列术语具有以下含义：\n\n1. “您”或“您的”或“您本人”系指 Alex Hadjicharalambous，以及其所有代理人、律师、代表、雇员和/或任何代表其行事的人。\n\n2. “债务人”系指 Ho Wan Kwok（郭文贵）（又名 Miles Kwok、Miles Guo、Guo Wengui、Guo Haoyun、郭文贵或任何其他别名），以及其雇员、代理人、法律顾问、顾问或任何代表其行事的人。\n\n3. “债务人之子”系指 Qiang Guo（郭强）（又名 Mileson Kwok、郭强或任何其他别名），以及其雇员、代理人、法律顾问、顾问或任何代表其行事的人。\n\n案号 22-50073 文书 1592 提交日期 03/24/23 登记日期 03/24/23 10:57:37 第 173 页，共 1063 页\n\n4. “债务人之女”系指 Mei Guo（郭美）（又名 Mei Gui、郭美或任何其他别名），以及其雇员、代理人、法律顾问、顾问或任何代表其行事的人。\n\n5. “债务人声称的妻子”系指 Hing Chi Ngok（岳庆芝）（又名 Hing Chi Ng、Yue Qingzhi、岳庆芝或任何其他别名），以及其雇员、代理人、法律顾问、顾问或任何代表其行事的人。\n\n6. “债务人家属”统称债务人、债务人之子、债务人之女及债务人声称的妻子，以及与债务人有任何其他亲属关系的人。\n\n7. “关联个人”单独及统称指：(1) 持有、控制、保管或对债务人或债务人家属拥有、控制或享有的资产具有处置权的所有个人；或 (2) 曾为一个或多个关联实体的雇员、董事或以其他方式与其关联的所有个人，以及前述任何一方各自的雇员、代理人、法律顾问、顾问或代表其行事的任何人。此类关联个人包括但不限于：Daniel Podhaskie、Jason Miller、Steve Bannon、Karin Maistrello、Melissa Francis、Anthony DiBattista、William Gertz、Arethusa Forsyth、Glenn Mellor、Jennifer Mercurio、Eduardo Eurnekian、Wencong Wang、Han Chunguang（韩春光）（又名 韩春光）、Qu Guojiao（屈国姣）（又名 Qu Guo Jiao、屈国姣）、Guo Lijie（郭丽杰）（又名 郭丽杰）、Zhang Wei（张伟）（又名 张伟*）、Lihong Wei Lafrenz（魏丽红）（又名 Sara Wei、魏丽红）、Hao Haidong（郝海东）（又名 郝海东）、Ross Heinemeyer、Max Krasner、Kyle Bass、Melissa Mendez、Ya Li（李娅）（又名 李娅）、Dinggang Wang（王定刚）（又名 王定刚）、An Hong（安红）（又名 安红）、Yvette Wang（王雁平）（又名 Yanping Wang、Yan Ping Wang、王雁平）、Fiona Yu、Je Kin Ming（余建明）（又名 William Je、Yu Jianming、余建明）、Yaz Qingua 及 Lao Jiang（姜云浮）（又名 Jiang Yunfu、Jiang Yunfu Be、姜云浮）。\n\n案号 22-50073 文书 1592 提交日期 03/24/23 登记日期 03/24/23 10:57:37 第 174 页，共 1063 页\n\n8. “关联实体”单独及统称指：(1) 债务人或债务人家属曾拥有、控制或投资的所有任何类型组织或实体；或 (2) 对债务人或债务人家属拥有、控制或享有的任何资产直接或间接拥有权益的所有任何类型组织或实体，以及前述任何一方各自的雇员、代理人、法律顾问、顾问或代表其行事的任何人。此类关联实体包括但不限于：7 Nod Hill LLC、AAGV Limited、ACA Investment Management Limited、ACA Capital Group Limited、Ace Decade Holdings Limited、AI Group Holdings Inc.、Alfa Global Ventures Limited、Alfonso Global Limited、Allied Capital Global Limited、Alpine Fiduciaries SA、Anton Development Limited、Assets Sino Limited、Auspicious Coast Limited、Beijing Pangu Investment Co.、Beijing Pangu Investment Co. Ltd.、Beijing Pangu Investment Inc.、Beijing Zenith Holdings Company Limited、Booming Sail New York LLC、Bravo Luck Limited、BSA Strategic Fund I、China Golden Spring (Hong Kong) Limited、Chuang Xin Limited、Crane Advisory Group LLC、Creative Apex Investments Limited、Crystal Breeze Investments Limited、Dawn State Limited、Eastern Profit Corporation Limited、Elite Well Global Limited、Empire Growth Holdings、Freedom Media Ventures Ltd.、G Club Operations LLC、G Fashion LLC、G News LLC、GETTR USA、Genever Holdings Corporation、Genever Holdings LLC、Gfashion Media Group Inc.、GFNY, Inc.、Globalist International Limited、GNews Media Group Inc.、Golden Spring (New York) Ltd.、Greenwich Land LLC、Guo Media、GTV Media Group, Inc.、Hamilton Capital Holdings Inc.、HCHK Property Management, Inc.、HCHK Technologies, Inc.、Head Win Group Limited、Henan Yuda、Himalaya Embassy、Himalaya Exchange、Himalaya Federal Reserve、Himalaya Investment LLC、Himalaya International、Himalaya New World Inc.、Himalaya Supervisory Organization、Himalaya Ventures LLC、HK International Funds Investments (USA) Limited LLC、Hong Kong International Funds\n\n案号 22-50073 文书 1592 提交日期 03/24/23 登记日期 03/24/23 10:57:37 第 175 页，共 1063 页\n\nInvestments Limited、Hudson Diamond Holding、Infinite Increase Limited、Infinitum Developments Limited、Infinity Treasury Management Inc.、Insight Phoenix Fund、Lamp Capital LLC、Leading Shine Limited、Leading Shine NY Limited、Lexington Property and Staffing、Long Gate Limited、Maywind Trading LLC、MOS Himalaya LLC、Next Tycoon Investments Limited、New Federal State of China（新中国联邦）（又名 NFSC）、Noble Fame Global Limited、Rosy Acme Ventures Limited、Rule of Law Foundation III, Inc.、Rule of Law Foundation IV, Inc.、Rule of Law Fund、Rule of Law Society、Rule of Law Society IV, Inc.、G-Translators PTY LTD、Saraca Media Group, Inc.、Shiny Ace Ltd.、Shiny Times Holdings Ltd.、Spirit Charter Investment Limited、Stevenson, Wong & Co.、Voice of Guo Media, Inc.、Well Origin Ltd.、World Century Limited、Worldwide Opportunity Holdings Limited、Whitecroft Shore Limited 及 ZIBA Limited。\n\n9. “包括”或其任何变体，系指“包括但不限于”。\n\n10. “和”及“或”系指“和/或”，并应同时解释为连词及选择连词，以最大限度扩大其范围。\n\n11. “任何”、“所有”及“每一”均系指“每一个及所有”。\n\n12. “每一”及“每个”均系指“每一个及所有”。\n\n13. “第三方”系指您本人以外的个人或实体。\n\n14. “转让”具有《破产法典》第 101(54) 条赋予其的含义。\n\n15. “文件”系指属于 Fed. R. Civ. P. 34 范围内的任何信息或物品，并包括但不限于每一份任何种类、类型、性质或描述的书面、记录或图形材料，该等材料现由或曾由您占有、保管或控制，包括电子邮件的所有打印及电子副本、以电子形式保存的计算机文件、\n\n案号 22-50073 文书 1592 提交日期 03/24/23 登记日期 03/24/23 10:57:37 第 176 页，共 1063 页\n\n电子通信、短信、社交媒体帖子、推文、元数据、通信函件、备忘录、磁带、速记或手写笔记、任何种类的书面表格、图表、蓝图、图纸、草图、曲线图、计划、文章、规格、日记、信函、电报、照片、会议记录、合同、协议、调查、计算机打印件、任何种类的数据汇编、电传、传真、语音留言、发票、订单表格、支票、汇票、账单、贷项通知单、报告、状况报告、摘要、索引、书籍、分类账、笔记本、附表、透明胶片、录音、目录、广告、宣传材料、电影、录像带、录音带、CD、计算机磁盘、手册、小册子、穿孔卡、工时单、推文、社交媒体帖子或任何其他种类的书面或记录材料，以及其所有元数据，无论以何种方式存储（无论为有形或电子形式）、记录、制作或复制；还包括但不限于前述任何文件的草稿或副本，如其包含原始文件中不存在的任何种类笔记、评论或标记，或其在其他方面与原始文件不相同。\n\n16. “个人”系指自然人、公司、独资企业、合伙企业、协会或任何其他实体。“个人”还包括任何代理人、代表或专家，包括但不限于律师或财务顾问。\n\n17. “实体”系指任何自然人、公司、合伙企业、子公司、独资企业、商号、董事会、合资企业、协会、机构、主管机关、委员会或其他商业实体或法人，以及任何关联方、代理人、母公司，包括但不限于法律顾问、财务顾问或任何其他代表。\n\n18. “关于”系指涉及、描述、构成、提及、与之相关、支持、赞成、反对、加强、减损、位于其中、与之联系考虑、与之有关、证明、表明、报告、记录、暗指、答复、\n\n案号 22-50073 文书 1592 提交日期 03/24/23 登记日期 03/24/23 10:57:37 第 177 页，共 1063 页\n\n与之连接、评论、就其而言、有关、与之相关、讨论、显示、描述、反映、分析、构成及属于。\n\n19. 当“与……相关”、“涉及”或“有关”指向任何特定事项时，系指但不限于构成、包含、涉及、含有、体现、反映、识别、陈述、直接或间接提及该特定事项，或以任何方式与所识别的特定事项相关的任何文件。\n\n20. “通信”在最广泛可能意义上且不受限制地系指任何信息或知识的传递（以事实、想法、询问或其他形式）。通信还指所有谈话、协议、询问或答复，无论系当面、通过电话、以书面形式或借助电子传输装置进行，并包括但不限于所有通信函件、电子邮件、录音、传送单、备忘录、电话通信、语音留言、电报、电话传真、传真副本、电传、即时消息、聊天信息、短信、电话笔记或在内部或与第三方传送的笔记。\n\n21. “资产”系指任何可用于产生正面经济价值的项目，包括但不限于由某一实体拥有、控制或为其利益而持有，且预期可提供未来利益的任何具有经济价值的资源，包括但不限于所有不动产和动产、无形财产、投资、投资权或未来收入权、现金、银行账户、商品、证券、债权、对某一实体的全部或部分控制权，以及预期经济机会。\n\n22. “转让”具有《破产法典》第 101(54) 条赋予其的含义。\n\nIV. 应提交的文件\n\n1. 与债务人、债务人财产或关联实体的任何收入或资产有关的所有文件。\n\n2. 与债务人的财务状况及其对债权人所负义务有关的所有文件，包括但不限于与任何试图规避支付该等义务的努力有关的所有文件，以及与本次或任何其他实际或潜在破产或类似资不抵债程序有关的所有文件。\n\n3. 所有与债务人、债务人财产、债务人家庭成员、关联实体或关联个人有关的资产负债表、银行对账单、账户对账单、财务报表、账户结单、电汇指示和/或确认、资金证明、存款证明、持有证明、投资组合摘要或类似文件，包括但不限于足以显示向前述任何主体作出的所有转移的全部文件。\n\n4. 所有关于债务人作出、与债务人进行或代表债务人作出的任何投资、业务往来或交易的文件。\n\n5. 与债务人进行的所有通信，以及与债务人的通信有关、涉及任何实体（包括但不限于关联实体）运营、管理或决策的文件。\n\n6. 所有关于向债务人、债务人家庭成员或关联实体作出、由其作出或与其进行的任何转移、投资或其他交易或业务往来的文件。\n\n7. 所有关于债务人曾占用或使用的任何财产的文件，包括但不限于 Lady May；Sherry Netherland Hotel / Condominium（雪莉·荷兰酒店／公寓）；位于 Connecticut（康涅狄格州）Greenwich（格林尼治）373 Taconic Rd. 的住宅物业；位于 Connecticut（康涅狄格州）Greenwich（格林尼治）33 Ferncliff Rd. 的住宅物业；以及位于 Connecticut（康涅狄格州）Wilton（威尔顿）354 Nod Hill Rd. 的住宅物业。\n\nCase 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 179 of 1063\n\n8. 所有与债务人拥有、控制或使用的任何航空器有关的文件，包括但不限于尾号为 T7-GQM 的航空器以及在 San Marino（圣马力诺）注册的任何其他航空器，包括但不限于所有登记文件副本和飞行记录单，该等飞行记录单显示该等航空器所执行的航班及搭乘该等航班的人员。\n\n9. 所有关于向债务人、债务人财产、债务人家庭成员或关联实体提供、由其提供或代表其提供的任何赠与、利益或贷款的文件，包括但不限于足以显示该等赠与、利益或贷款金额；该等赠与、利益或贷款的用途；提供该等赠与、利益或贷款的时间；以及任何贷款的条款、与任何贷款有关作出的所有陈述与保证、任何贷款的利率及任何贷款的所有付款证据的文件。\n\n10. 所有关于由债务人、代表债务人或为债务人、债务人财产、债务人家庭成员或关联实体的利益而设立的任何信托或类似文书的文件，包括但不限于足以显示信托设立时间、设立人、受益人以及信托本金的文件。\n\n11. 所有与涉及债务人的任何法律争议相关的任何义务、请求权、责任或债务有关的文件，包括但不限于与任何地方、州、联邦或国际机构（无论为行政机构、法院、合议庭或替代性争议解决实体）进行的任何诉讼有关的文件。\n\nCase 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 180 of 1063\n\n12. 您的任何外聘律师或其他顾问与债务人之间的所有文件及通信。\n\n13. 所有与您持有或曾持有权益的任何关联实体有关的文件。\n\n14. 与债务人进行的所有通信，以及与债务人的通信有关、涉及任何法律实体（包括但不限于家族关联实体和关联实体）运营、管理或决策的文件。\n\nCase 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 181 of 1063\n\n附件 C-9\n\nB2540（表格 2540－Rule 2004 审查传票）（12/15）Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 182 of 1063\n\nUNITED STATES BANKRUPTCY COURT（美国破产法院）1063\n\nDistrict of Connecticut（康涅狄格州地区）\n\n关于 HO WAN KWOK（郭文贵）等人，\n\n1 案号 22-50073 (JAM)\n\n债务人 第 11 章\n\n（合并管理）\nRULE 2004 审查传票\n\n致：Alex Hadjicharalambous（亚历克斯·哈吉查拉兰布斯）\n\n（传票所指向人员的姓名）\n\n作证：兹命令您于下列规定的时间、日期和地点出席，并根据《联邦破产程序规则》Rule 2004 在审查中作证。授权该审查的法院命令副本随附。\n\n地点　日期和时间\n\nPaul Hastings LLP（保罗·黑斯廷斯律师事务所）\n200 Park Avenue　[TBD]\nNew York, New York 10166\n\n审查将以以下方式记录：法庭记录员／速记员\n\n提交：您或您的代表还必须携带下列文件、电子存储信息或物品参加审查，并必须允许对该等材料进行查验、复制、测试或取样：\n\n见随附的文件提交请求。\n\n根据《联邦破产程序规则》Fed. R. Bankr. P. 9016 适用于破产案件的 Fed. R. Civ. P. 45 下列规定随附：关于履行地点的 Rule 45(c)；关于对作为传票对象人员的保护的 Rule 45(d)；以及关于您对本传票的回应义务及未回应的潜在后果的 Rule 45(e) 和 45(g)。\n\n日期：March , 2023\n\n法院书记员\n\n或\n\n书记员或副书记员签名　律师签名\n\n签发或请求本传票、代表第 11 章受托人 Luc A. Despins（卢克·A·德斯平斯）的律师姓名、地址、电子邮箱地址和电话号码如下：\n\nDouglas S. Skalka, Esq.（道格拉斯·S·斯卡尔卡律师）；Neubert, Pepe & Monteith, P.C.（诺伊伯特、佩佩及蒙蒂思律师事务所）；195 Church Street, New Haven, Connecticut 06510 dskalka@npmlaw.com；(203) 821-2000\n\n致签发或请求本传票的人员的通知\n\n如果本传票要求在审判前提交文件、电子存储信息或有形物品，或查验场所，则必须在向传票所指向人员送达前，向每一当事人送达通知及本传票副本。Fed. R. Civ. P. 45(a)(4)。\n\nSoftware Copyright (c) 1996-2022 Best Case, LLC（百斯特凯斯有限责任公司）- www.bestcase.com Best Case Bankruptcy 1 本第 11 章案件中的债务人为 Ho Wan Kwok（郭文贵）（又称 Guo Wengui、Miles Guo 和 Miles Kwok，以及众多其他别名）（税务识别号码后四位：9595）、Genever Holdings LLC（税务识别号码后四位：8202）及 Genever Holdings Corporation。受托人、Genever Holdings LLC 及 Genever Holdings Corporation 的邮寄地址为 Paul Hastings LLP, 200 Park Avenue, New York, NY 10166，转交作为 Ho Wan Kwok 财产受托人的 Luc A. Despins（仅用于通知和通信目的）。\n\n送达证明\n\n（除非 Fed. R. Civ. P. 45 要求，否则本节不应提交法院。）\n\n本人于（日期）收到向（个人姓名及职务，如有）送达的本传票。\n\n本人以下列方式向具名人员交付副本，完成本传票的送达：\n\n于（日期）；或\n\n本人因下列原因未予执行而退回本传票：\n\n除非本传票代表 United States（美国）或其官员或代理人签发，本人亦已向证人支付一天出席费用及法律允许的里程费，金额为 $ 。\n\n本人差旅费为 $，服务费为 $，合计为 $。\n\n本人在伪证罪处罚下声明，上述信息真实且正确。\n\n日期：\n\n送达人签名\n\n正楷姓名及职务\n\n送达人地址\n\n关于尝试送达等的补充信息：\n\nFederal Rule of Civil Procedure 45(c)、(d)、(e) 和 (g)（Effective 12/1/13）（根据《联邦破产程序规则》Rule 9016 适用于破产案件）\n\n(c) 履行地点。\n\n(1) 关于审判、听证或证言记录。传票仅可按下列规定命令人员出席审判、听证或证言记录：\n\n(A) 在该人员居住、受雇或定期亲自从事商业活动地点 100 英里以内；或\n\n(B) 在该人员居住、受雇或定期亲自从事商业活动所在州内，若该人员：\n\n(i) 为当事人或当事人的高级职员；或\n\n(ii) 被命令出席审判且不会产生重大费用。\n\n(2) 关于其他证据开示。传票可命令：\n\n(A) 在该人员居住、受雇或定期亲自从事商业活动地点 100 英里以内的地点提交文件、电子存储信息或物品；以及\n\n(B) 在待查验场所对场所进行查验。\n\n(d) 保护作为传票对象的人员；执行。\n\n(1) 避免不当负担或费用；制裁。负责签发和送达传票的当事人或律师必须采取合理措施，避免对作为传票对象的人员施加不当负担或费用。要求履行的地区法院必须执行该义务，并对未遵守该义务的当事人或律师施加适当制裁，其中可包括损失的收入和合理的律师费。\n\n(2) 命令提交材料或允许查验。\n\n(A) 无须出席。被命令提交文件、电子存储信息或有形物品，或允许查验场所的人员，无须亲自出席提交或查验地点，除非亦被命令出席证言记录、听证或审判。\n\n(B) 异议。被命令提交文件或有形物品，或允许查验的人员，可向传票中指定的当事人或律师送达书面异议，反对查验、复制、测试或取样任何或全部材料，或反对查验场所，或反对以所请求的一种或多种形式提交电子存储信息。异议必须在规定履行时间之前或传票送达后 14 日之前（以较早者为准）送达。如提出异议，适用下列规则：\n\n(i) 送达方可随时在通知被命令人员后，向要求履行的地区法院提出动议，请求作出强制提交或查验的命令。\n\n(ii) 仅可依照命令的指示要求实施该等行为，且该命令必须保护非当事人亦非当事人高级职员的人员免受因履行而产生的重大费用。\n\n(3) 撤销或修改传票。\n\n(A) 必须撤销或修改的情形。经及时动议，要求履行的地区法院必须撤销或修改以下传票：\n\n(i) 未给予合理履行时间；\n\n(ii) 要求人员在超出 Rule 45(c) 规定的地域限制之外履行；\n\n(iii) 要求披露享有特权或受其他保护的事项，且不适用任何例外或豁免；或\n\n(iv) 对人员施加不当负担。\n\n(B) 可以撤销或修改的情形。为保护作为传票对象或受传票影响的人员，要求履行的地区法院可经动议撤销或修改要求下列事项的传票：\n\n(i) 披露商业秘密或其他保密的研究、开发或商业信息；或\n\n(ii) 披露未受聘专家的意见或信息，该等意见或信息并非描述争议中的特定事件，且源自当事人未请求该专家进行的研究。\n\n(C) 以规定条件作为替代方案。在 Rule 45(d)(3)(B) 所述情形下，如送达方：\n\n(i) 证明其对该证言或材料具有重大需要，且如不承受不当困难即无法以其他方式满足该需要；并且\n\n(ii) 确保被传唤人员将获得合理补偿，\n\n法院可不撤销或修改传票，而是命令在规定条件下出席或提交。\n\n(e) 回应传票的义务。\n\n(1) 提交文件或电子存储信息。下列程序适用于提交文件或电子存储信息：\n\n(A) 文档。对要求提交文档的传票作出回应的人，必须按照文档在日常业务过程中保存的方式提交文档，或者必须对文档进行整理和标注，使其与请求中的类别相对应。\n\n(B) 未指定的电子存储信息提交形式。如果传票未指定提交电子存储信息的形式，作出回应的人必须以其通常保存的一种或多种形式，或者以一种或多种合理可用的形式提交该信息。\n\n(C) 电子存储信息仅以一种形式提交。作出回应的人无需以一种以上的形式提交同一电子存储信息。\n\n(D) 不可访问的电子存储信息。作出回应的人无需从其认定因不当负担或费用而无法合理访问的来源提供电子存储信息的证据开示。在提出强制证据开示动议或保护令动议时，作出回应的人必须证明该信息因不当负担或费用而无法合理访问。如果作出该证明，若请求方在考虑到规则26(b)(2)(C)的限制后证明有正当理由，法院仍可命令从该等来源进行证据开示。法院可以规定证据开示的条件。\n\n(2) 主张特权或保护。\n\n(A) 被拒绝提供的信息。以该信息享有特权或受审判准备材料保护为由拒绝提供传票所要求信息的人必须：(i) 明确提出该主张；以及\n\n(ii) 以在不披露本身享有特权或受保护信息的情况下，足以使各方能够评估该主张的方式，说明被拒绝提供的文件、通信或有形物品的性质。\n\n(B) 已提交的信息。如果为回应传票而提交的信息存在特权主张或审判准备材料保护主张，提出该主张的人可以将该主张及其依据通知任何收到该信息的一方。收到通知后，一方必须立即返还、隔离或销毁该指定信息及其持有的任何副本；在该主张得到解决之前，不得使用或披露该信息；如果该方在收到通知前已披露该信息，必须采取合理措施予以追回；并且可以立即将该信息密封提交给要求履行的地区法院，以裁定该主张。提交该信息的人必须在该主张得到解决前保存该信息。\n\n(g) 藐视法庭。要求履行的地区法院——以及在动议被移送后，签发法院——可以认定已被送达但无正当理由未遵守传票或与之相关命令的人构成藐视法庭。\n\n有关获得传票材料的信息，参见 Fed.R.Civ.P.45(a) 委员会说明（2013）\n\n……\n\n文件提交请求\n\n一、指示\n\n1. 除非另有说明，下列文件请求（以下简称“请求”，每一项称为“一项请求”）必须分别且具体地予以答复。除非善意地提出异议，否则应完整答复每项请求；如提出异议，应按照下文规定详细说明你方异议的理由。如果异议仅涉及某项请求的一部分，或其中包含的某个词语、短语或条款，你方仅须说明对该部分的异议，并对请求的其余部分作出答复。\n\n2. 必须按照下列指示提交电子存储信息：\n\na. 图像。黑白图像必须为300 DPI Group IV单页 TIFF 文件。彩色图像必须以 JPEG 格式提交。文件名不得包含嵌入空格或特殊字符（包括逗号）。文件夹名称不得包含嵌入空格或特殊字符（包括逗号）。所有 TIFF 图像文件必须具有唯一文件名，即 Bates 编号。图像必须在每张图像的右下角加盖连续的 Bates 编号。每个文件夹中的 TIFF 文件数量不得超过1000个文件。Excel（微软 Excel）电子表格应具有以该文件 Bates 编号命名的占位图像。\n\nb. 图像加载文件\n\na. Concordance® 数据文件。数据文件（.DAT）包含将被加载至 Concordance® 数据库的所有字段化信息。.DAT 文件的第一行必须为标识字段名称的标题行。.DAT 文件必须使用下列 Concordance® 默认分隔符：逗号 ASCII 字符（020）；引号 þ ASCII 字符（254）。日期字段应采用以下格式提供：mm/dd/yyyy。日期和时间字段必须为两个独立字段。如果文件包括已成像的电子邮件及附件，则必须包括附件字段，以保留电子邮件与其附件之间的父项/子项关系。必须包括 OCRPATH 字段，以提供提交存储介质上提取文本文件的文件路径和名称。文本文件必须以 FIRSTBATES 命名。不得将文本包含在 .DAT 文件中。对于包含原生文件的文件，必须包括 LINK 字段，以提供原生文件的文件路径和名称。原生文件必须以 FIRSTBATES 命名。\n\nb. Concordance Image® 或 Opticon 交叉引用文件。图像交叉引用文件（.LOG 或 .OPT）将图像与数据库记录连接。其应为逗号分隔文件，每行由七个字段组成，且数据库中的每张图像均应在交叉引用文件中有一行，格式如下：ImageID,VolumeLabel,ImageFilePath,DocumentBreak,FolderBreak,BoxBreak,PageCount。\n\nc. 文档文本。文本必须作为单独的文本文件提交，而非作为 .DAT 文件内的字段。文本文件的完整路径（OCRPATH）应包含在 .DAT 文件中。建议提供按 FIRSTBATES/Image Key 命名的文档级 ANSI 文本文件。提取的文本文件必须置于单独文件夹中，每个文件夹内的文本文件数量不得超过1,000个文件。文件夹名称中不得有特殊字符（包括逗号）。文本文件必须按文档级别提供。\n\nd. 特定文件类型的原生提交。为完整理解其内容和含义而合理需要以原生格式查看的文件类型，必须以原生格式提交。这些包括但不限于电子表格、类似电子表格的文件（Microsoft Excel（微软 Excel）、逗号分隔值、制表符分隔值等）、Microsoft PowerPoint（微软 PowerPoint）或其他特殊演示文件、数据库文件以及音频/视频文件。应提供一张带有 Bates 编号的分隔页图像，以表明原生文件的存在，并将该原生文件的路径作为 .dat 文件中的字段包含在内。提交的原生文件应以与该文件分隔页对应的 Bates 编号命名。原生文件应归入递增命名的“NATIVE”目录中，并与图像目录分开。\n\ne. 去重。对于存在完全重复件的每份电子文档，提交一份副本。对于电子邮件，基于从 BCC、Body、CC、From、IntMsgID、To 和 Attach 属性生成的 MD5 哈希值合并重复件。对于电子邮件附件和独立电子文件，基于整个文件的 MD5 哈希值合并重复件。\n\nf. 元数据。以符合 Concordance 标准的加载文件（.dat）形式提交每份文档的提取元数据。.DAT 文件的第一行必须为标识字段名称的标题行。.DAT 文件必须使用下列 Concordance 默认分隔符：逗号 , ASCII 字符（020）；引号 þ ASCII 字符（254）。\n\n日期字段应采用以下格式提供：mm/dd/yyyy。日期和时间字段必须为两个独立字段。所需元数据如下：\n\nCase 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 187 of 1063\n\n字段名称　示例数据　说明\n\nFIRSTBATES　EDC0000001　原生文件文档/电子邮件的第一个 Bates 编号\n\nLASTBATES　EDC0000001　原生文件文档/电子邮件的最后一个 Bates 编号\n\nLASTBATES 字段应针对单页填写\n\nATTACHRANGE　EDC0000001 - EDC0000015　父文档第一页的 Bates 编号至最后一个附件“子”文档最后一页的 Bates 编号\n\nBEGATTACH　EDC0000001　附件范围的第一个 Bates 编号\n\nENDATTACH　EDC0000015　附件范围的最后一个 Bates 编号\n\nCUSTODIAN　Smith, John　电子邮件：电子邮件所在的邮箱\n\n原生文件：文档源自其文件的个人或部门名称\n\nFROM　John Smith　电子邮件：发件人\n\n原生文件：文档作者\n\n多个条目之间应使用分号分隔\n\nTO　Coffman, Janice; LeeW [mailto:LeeW@MSN.com]　收件人\n\n多个条目之间应使用分号分隔\n\nCC　Frank Thompson [mailto:frank_Thompson@cdt.com]　抄送收件人\n\n多个条目之间应使用分号分隔\n\nBCC　John Cain　密送收件人\n\n多个条目之间应使用分号分隔\n\nSUBJECT　Board Meeting Minutes　电子邮件：电子邮件主题行\n\n原生文件：文档标题（如有）\n\nFILE_NAME　BoardMeetingMinutes.docx　原生文件：原始原生文件的名称，包括扩展名\n\nDATE_SENT　10/12/2010　电子邮件：电子邮件发送日期\n\n原生文件：（空）\n\nTIME_SENT/TIME_ZONE　07:05 PM GMT　电子邮件：电子邮件发送时间/电子邮件标准化时所采用的时区\n\nTIME_ZONE　GMT　在转换过程中电子邮件被标准化时所采用的时区。\n\nLINK　EDC0000001.msg　电子邮件或原生文件文档的超链接\n\n链接文件必须按 FIRSTBATES 编号命名\n\nFILE_EXTEN　MSG　表示电子邮件或原生文件的文件类型扩展名\n\nAUTHOR　John Smith　电子邮件：（空）\n\n原生文件：文档作者\n\nDATE_CREATED　10/10/2010　电子邮件：（空）\n\n原生文件：文档创建日期\n\nCase 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 188 of 1063\n\nTIME_CREATED　10:25 AM　电子邮件：（空）\n\n原生文件：文档创建时间\n\n该数据必须为独立字段，不得与 DATE_CREATED 字段合并\n\nDATE_MOD　10/12/2010　电子邮件：（空）\n\n原生文件：文档最后修改日期\n\nTIME_MOD　07:00 PM　电子邮件：（空）\n\n原生文件：文档最后修改时间\n\n该数据必须为独立字段，不得与 DATE_MOD 字段合并\n\nDATE_ACCESSD　10/12/2010　电子邮件：（空）\n\n原生文件：文档最后访问日期\n\nTIME_ACCESSD　07:00 PM　电子邮件：（空）\n\n原生文件：文档最后访问时间\n\n该数据必须为独立字段，不得与 DATE_ACCESSD 字段合并\n\nFILE_SIZE　5,952　原生文件文档/电子邮件的大小，单位为 KB\n\nPGCOUNT　1　原生文件文档/电子邮件的页数\n\nPATH　Email: (empty) Agenda.doc　电子邮件：（空）\n\n原生文件：原生文件文档的存储路径，包括原始文件名称。\n\nINTFILEPATH　Personal Folders\\Deleted Items\\Board Meeting Minutes.msg　电子邮件：电子邮件的原始位置，包括原始文件名称。\n\n原生文件：（空）\n\nINTMSGID　<000805c2c71b\\$75977050\\$cb8306d1@MSN>　电子邮件：唯一邮件 ID\n\n原生文件：（空）\n\nMD5HASH　d131dd02c5e6eec4693d9a0698aff95c2fcab58712467eab4004583eb8fb7f89　文档的 MD5 哈希值。\n\nOCRPATH　TEXT/001/EDC0000001.txt　原生文件提取文本的路径\n\n3. 每项请求独立运作并应被独立解释；除非另有说明，任何请求均不限制任何其他请求的范围。\n\n4. 所有文件均应按其在通常业务过程中的保存方式提交，或者应予整理和标注，以对应于这些请求中的类别。\n\n5. 本文所载每项请求均延及所有文件：(a) 由你方占有、保管或控制的文件；或 (b) 由代表你方行事的任何人占有、保管或控制的文件，\n\nCase 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 189 of 1063\n\n包括你方律师或其他代表及顾问。每份文件均应完整提交。\n\n6. 如果要求您提供一份已不再由您占有、保管或控制的文件，则您的答复必须：(a) 详细说明该文件的性质及其内容；(b) 确定编制或起草该文件的人士（以及，如适用，文件的收件人）；(c) 确定该文件编制或创建的日期；(d) 说明该文件是否：(i) 遗失或丢失，(ii) 已被销毁，(iii) 已自愿或非自愿地转交给他人，或(iv) 已以其他方式处置；(e) 说明该等处置的理由，以及围绕该等处置的事实和情况；(f) 确定授权该等处置的人士；(g) 确定该等处置的日期或约计日期；(h) 说明该文件最近一次由您占有、保管或控制的时间；以及(i) 确定目前占有、保管或控制该文件的人士（如有）。\n\n7. 如果要求您提供一份已被销毁的文件，则除前述指示所要求的信息外，您的答复还必须说明：(a) 销毁该文件的理由；(b) 销毁该文件的人士的身份；以及(c) 指示销毁该文件的人士的身份。\n\n8. 如果您主张所要求的文件享有特权或属于律师工作成果，则您的答复必须：(a) 说明：(i) 足以支持您关于该文件享有特权之主张的文件描述，(ii) 文件标题，(iii) 文件日期，(iv) 文件作者，(v) 文件收件人，(vi) 收到或阅览该文件原件或任何草稿、副本或复制件的每一人士的身份，(vii) 该文件本身或该文件中包含或提及的任何信息是否由任何其他人士占有、保管或控制，如是，则应确定该等人士的身份；\n案件 22-50073 文件 1592 提交日期 03/24/23 登记日期 03/24/23 10:57:37 第 190 页，共 1063 页\n\n以及说明该等信息如何进入其占有范围，(viii) 据以扣留该文件的特权主张，以及(ix) 您将据以支持该特权主张的所有情况；以及(b) 就每一份根据符合 D. Conn. L. Civ. R. 26(e) 的特权主张而被扣留的文件，制作一份特权清单，载明本指示第(a)部分所要求的全部信息。\n\n9. 如果一份本应作出回应的文件的一部分含有受特权主张约束的信息，则仅应按照上述指示从该文件中删除或涂黑受特权主张约束的该部分，其余部分应予提供。\n\n10. 本文件请求具有持续性。特此指示您：(a) 一旦得知先前答复不完整或不正确，应立即补充或更正任何后来得知不完整或不正确的答复；以及(b) 提供根据以下规定所要求的任何额外文件\n\n11. 如果文件使用英语以外的语言，您应提供该文件。如果文件使用英语以外的语言，且存在英文译本，您应同时提供两份文件。\n\n12. 对实体的所有提述均包括其所有关联方。\n\n13. 对个人姓名的所有提述均包括所有其他姓名、别名或昵称。\n\n14. 除非另有明确说明，文件请求所涵盖的期间为自 February 5, 2012 起至文件请求答复到期之日止。\n案件 22-50073 文件 1592 提交日期 03/24/23 登记日期 03/24/23 10:57:37 第 191 页，共 1063 页\n\nII. 解释规则\n\n15. (a) 任何单数名词的使用应解释为包括复数，反之亦然；以及(b) 任何时态动词的使用应解释为包括该动词所有其他时态的使用。\n\n16. (a) “和”及“或”应根据需要解释为连词意义或选择意义，以使任何请求的范围涵盖所有原本可能被解释为超出其范围的答复；以及(b) “每一”及“任何”应视为包括并涵盖“每一个”及“所有”二词。\n\nIII. 定义\n\n经 D. Conn. Bankr. L.R. 2004-1(a) 纳入的 D. Conn. L. Civ. R. 26(c) 所提供的定义及 D. Conn. L. Civ. R. 26(d) 所提供的解释规则，应适用于文件请求。此外，本文件请求中所使用的下列术语具有下列含义：\n\n1. “您”或“您的”或“您本人”是指并包括 Min Yang（杨敏）（又名 Yang Min），以及其所有代理人、律师、代表、雇员和/或任何代表其行事的人。\n\n2. “债务人”是指 Ho Wan Kwok（郭文贵）（又名 Miles Kwok、Miles Guo、Guo Wengui、Guo Haoyun、郭文贵或任何其他别名），以及其雇员、代理人、律师、顾问或任何代表其行事的人。\n\n3. “债务人的儿子”是指 Qiang Guo（郭强）（又名 Mileson Kwok、郭强或任何其他别名），以及其雇员、代理人、律师、顾问或任何代表其行事的人。\n案件 22-50073 文件 1592 提交日期 03/24/23 登记日期 03/24/23 10:57:37 第 192 页，共 1063 页\n\n4. “债务人的女儿”是指 Mei Guo（郭美）（又名 Mei Gui、郭美或任何其他别名），以及其雇员、代理人、律师、顾问或任何代表其行事的人。\n\n5. “债务人所称的妻子”是指 Hing Chi Ngok（岳庆芝）（又名 Hing Chi Ng、Yue Qingzhi、岳庆芝或任何其他别名），以及其雇员、代理人、律师、顾问或任何代表其行事的人。\n\n6. “债务人的家庭成员”统称债务人、债务人的儿子、债务人的女儿以及债务人所称的妻子，及与债务人具有任何其他家庭关系的人。\n\n7. “关联个人”单独及共同指下列所有个人：(1) 持有、控制、保管或对债务人或债务人的家庭成员所拥有、控制或享有的资产拥有酌处权；或(2) 曾为一项或多项关联实体的雇员、董事，或以其他方式与其有关联；并包括前述各方各自的雇员、代理人、律师、顾问或任何代表前述任何一方行事的人。该等关联个人包括但不限于：Daniel Podhaskie（丹尼尔·波德哈斯基）、Jason Miller（杰森·米勒）、Steve Bannon（史蒂夫·班农）、Karin Maistrello（卡琳·迈斯特雷洛）、Melissa Francis（梅丽莎·弗朗西斯）、Anthony DiBattista（安东尼·迪巴蒂斯塔）、William Gertz（威廉·格茨）、Arethusa Forsyth（阿瑞图萨·福赛斯）、Glenn Mellor（格伦·梅勒）、Jennifer Mercurio（珍妮弗·默库里奥）、Eduardo Eurnekian（爱德华多·尤尔内基安）、Wencong Wang（王文聪）、Han Chunguang（韩春光）（又名 韩春光）、Qu Guojiao（屈国姣）（又名 Qu Guo Jiao、屈国姣）、Guo Lijie（郭丽杰）（又名 郭丽杰）、Zhang Wei（张伟）（又名 张伟*）、Lihong Wei Lafrenz（魏丽红）（又名 Sara Wei、魏丽红）、Hao Haidong（郝海东）（又名 郝海东）、Ross Heinemeyer（罗斯·海内迈耶）、Max Krasner（马克斯·克拉斯纳）、Kyle Bass（凯尔·巴斯）、Melissa Mendez（梅丽莎·门德斯）、Ya Li（李娅）（又名 李娅）、Dinggang Wang（王定刚）（又名 王定刚）、An Hong（安红）（又名 安红）、Yvette Wang（王雁平）（又名 Yanping Wang、Yan Ping Wang、王雁平）、Fiona Yu（菲奥娜·余）、Je Kin Ming（余建明）（又名 William Je、Yu Jianming、余建明）、Yaz Qingua（亚兹·钦瓜）以及 Lao Jiang（姜云浮）（又名 Jiang Yunfu、Jiang Yunfu Be、姜云浮）。\n案件 22-50073 文件 1592 提交日期 03/24/23 登记日期 03/24/23 10:57:37 第 193 页，共 1063 页\n\n8. “关联实体”单独及共同指下列所有类型的组织或实体：(1) 曾由债务人或债务人的家庭成员拥有、控制或投资；或(2) 对债务人或债务人的家庭成员所拥有、控制或享有的任何资产直接或间接享有权益；并包括前述各方各自的雇员、代理人、律师、顾问或任何代表前述任何一方行事的人。该等关联实体包括但不限于：7 Nod Hill LLC（七诺德山有限责任公司）、AAGV Limited（AAGV 有限公司）、ACA Investment Management Limited（ACA 投资管理有限公司）、ACA Capital Group Limited（ACA 资本集团有限公司）、Ace Decade Holdings Limited（艾斯十年控股有限公司）、AI Group Holdings Inc.（AI 集团控股公司）、Alfa Global Ventures Limited（阿尔法全球创投有限公司）、Alfonso Global Limited（阿方索全球有限公司）、Allied Capital Global Limited（联合资本全球有限公司）、Alpine Fiduciaries SA（阿尔卑斯受托人股份公司）、Anton Development Limited（安东开发有限公司）、Assets Sino Limited（中资资产有限公司）、Auspicious Coast Limited（吉祥海岸有限公司）、Beijing Pangu Investment Co.（北京盘古投资公司）、Beijing Pangu Investment Co. Ltd.（北京盘古投资有限公司）、Beijing Pangu Investment Inc.（北京盘古投资股份有限公司）、Beijing Zenith Holdings Company Limited（北京鼎峰控股有限公司）、Booming Sail New York LLC（繁荣帆纽约有限责任公司）、Bravo Luck Limited（好运有限公司）、BSA Strategic Fund I（BSA 战略基金 I）、China Golden Spring (Hong Kong) Limited（中国金泉〈香港〉有限公司）、Chuang Xin Limited（创新有限公司）、Crane Advisory Group LLC（克兰咨询集团有限责任公司）、Creative Apex Investments Limited（创意顶峰投资有限公司）、Crystal Breeze Investments Limited（水晶微风投资有限公司）、Dawn State Limited（黎明州有限公司）、Eastern Profit Corporation Limited（东方利润有限公司）、Elite Well Global Limited（精英环球有限公司）、Empire Growth Holdings（帝国成长控股）、Freedom Media Ventures Ltd.（自由媒体创投有限公司）、G Club Operations LLC（G Club 运营有限责任公司）、G Fashion LLC（G Fashion 有限责任公司）、G News LLC（G News 有限责任公司）、GETTR USA（GETTR 美国）、Genever Holdings Corporation（Genever 控股公司）、Genever Holdings LLC（Genever 控股有限责任公司）、Gfashion Media Group Inc.（Gfashion 媒体集团公司）、GFNY, Inc.（GFNY 公司）、Globalist International Limited（环球主义者国际有限公司）、GNews Media Group Inc.（GNews 媒体集团公司）、Golden Spring (New York) Ltd.（金泉〈纽约〉有限公司）、Greenwich Land LLC（格林威治土地有限责任公司）、Guo Media（郭媒体）、GTV Media Group, Inc.（GTV 媒体集团公司）、Hamilton Capital Holdings Inc.（汉密尔顿资本控股公司）、HCHK Property Management, Inc.（HCHK 物业管理公司）、HCHK Technologies, Inc.（HCHK 科技公司）、Head Win Group Limited（领赢集团有限公司）、Henan Yuda（河南裕达）、Himalaya Embassy（喜马拉雅大使馆）、Himalaya Exchange（喜马拉雅交易所）、Himalaya Federal Reserve（喜马拉雅联邦储备）、Himalaya Investment LLC（喜马拉雅投资有限责任公司）、Himalaya International（喜马拉雅国际）、Himalaya New World Inc.（喜马拉雅新世界公司）、Himalaya Supervisory Organization（喜马拉雅监督组织）、Himalaya Ventures LLC（喜马拉雅创投有限责任公司）、HK International Funds Investments (USA) Limited LLC（香港国际基金投资〈美国〉有限责任公司）、Hong Kong International Funds\n案件 22-50073 文件 1592 提交日期 03/24/23 登记日期 03/24/23 10:57:37 第 194 页，共 1063 页\n\nInvestments Limited（香港国际基金投资有限公司）、Hudson Diamond Holding（哈德逊钻石控股）、Infinite Increase Limited（无限增长有限公司）、Infinitum Developments Limited（无限开发有限公司）、Infinity Treasury Management Inc.（无限财资管理公司）、Insight Phoenix Fund（洞察凤凰基金）、Lamp Capital LLC（灯资本有限责任公司）、Leading Shine Limited（领先光辉有限公司）、Leading Shine NY Limited（领先光辉纽约有限公司）、Lexington Property and Staffing（列克星敦物业及人事）、Long Gate Limited（长龙门有限公司）、Maywind Trading LLC（五月风贸易有限责任公司）、MOS Himalaya LLC（MOS 喜马拉雅有限责任公司）、Next Tycoon Investments Limited（下一大亨投资有限公司）、New Federal State of China（中国新联邦国）（又名 NFSC）、Noble Fame Global Limited（卓名环球有限公司）、Rosy Acme Ventures Limited（蔷薇顶峰创投有限公司）、Rule of Law Foundation III, Inc.（法治基金会 III 公司）、Rule of Law Foundation IV, Inc.（法治基金会 IV 公司）、Rule of Law Fund（法治基金）、Rule of Law Society（法治协会）、Rule of Law Society IV, Inc.（法治协会 IV 公司）、G-Translators PTY LTD（G-译者私人有限公司）、Saraca Media Group, Inc.（萨拉卡媒体集团公司）、Shiny Ace Ltd.（闪耀王牌有限公司）、Shiny Times Holdings Ltd.（闪耀时代控股有限公司）、Spirit Charter Investment Limited（精神宪章投资有限公司）、Stevenson, Wong & Co.（史蒂文森、黄及公司）、Voice of Guo Media, Inc.（郭媒体之声公司）、Well Origin Ltd.（良好起源有限公司）、World Century Limited（世界世纪有限公司）、Worldwide Opportunity Holdings Limited（全球机遇控股有限公司）、Whitecroft Shore Limited（白克罗夫特海岸有限公司）以及 ZIBA Limited（ZIBA 有限公司）。\n\n9. “包括”或其任何变体，意为“包括但不限于”。\n\n10. “和”及“或”意为“和/或”，并应解释为同时具有连词意义及选择意义，以最大限度扩大其范围。\n\n11. “任何”、“所有”及“每一”意为“每一个和所有”。\n\n12. “每一”及“每个”意为“每一个和所有”。\n\n13. “第三方”是指您本人以外的人士或实体。\n\n14. “转让”具有《破产法典》第 101(54) 条赋予其的含义。\n\n15. “文件”是指属于 Fed. R. Civ. P. 34 范围内的任何信息或物品，并包括但不限于现由或曾由您占有、保管或控制的任何种类、类型、性质或描述的每一书面、记录或图形材料，包括电子邮件的所有印刷及电子副本、保存在\n案件 22-50073 文件 1592 提交日期 03/24/23 登记日期 03/24/23 10:57:37 第 195 页，共 1063 页\n\n电子形式、电子通信、短信、社交媒体帖子、推文、元数据、信函、备忘录、磁带、速记或手写笔记、任何种类的书面表格、图表、蓝图、绘图、草图、曲线图、计划、文章、规格说明、日记、信件、电报、照片、会议记录、合同、协议、调查资料、计算机打印件、任何种类的数据汇编、电传、传真、语音留言、发票、订单、支票、汇票、对账单、信用备忘录、报告、状况报告、摘要、索引、书籍、账簿、笔记本、附表、透明胶片、录音资料、目录、广告、宣传材料、影片、录像带、录音带、CD、计算机磁盘、小册子、传单、穿孔卡、工时单、推文、社交媒体帖子，或任何其他种类的书面或录制材料，以及其所有元数据，无论以何种方式存储（无论为有形形式还是电子形式）、记录、制作或复制；还包括但不限于前述任何文件的草稿或副本，如其包含原始文件中未载有的任何种类的笔记、评论或标记，或其在其他方面与原始文件不完全相同。\n\n16. “人员”系指个人、公司、独资企业、合伙企业、协会或任何其他实体。“人员”还包括任何代理人、代表或专家，包括但不限于律师或财务顾问。\n\n17. “实体”系指任何自然人、公司、合伙企业、子公司、独资企业、商号、董事会、合资企业、协会、机构、主管机关、委员会或其他商业实体或法人，以及任何关联方、代理人、母公司，包括但不限于法律顾问、财务顾问或任何其他代表。\n\n18. “关于”系指涉及、描述、构成、提及、与之相关、支持、赞成、反对、强化、削弱、位于其中、与之相关联地考虑、对其有影响、证明、表明、报告、记录、暗示、回应、\n\n案件 22-50073 文档 1592 提交于 03/24/23 登记于 03/24/23 10:57:37 第 196 页，共 1063 页\n\n与之关联、评论、就其而言、关于、与之有关、讨论、显示、描述、反映、分析、构成及为其组成部分。\n\n19. 就任何特定主题而言，“与……有关”、“关联至”或“相关”系指但不限于构成、包含、涉及、载有、体现、反映、识别、陈述、直接或间接提及，或以任何方式与所识别的特定主题相关的任何文件。\n\n20. “通信”系指以最广泛可能的含义且不限于任何信息或知识的传递（以事实、思想、询问或其他形式）。通信还指所有谈话、协议、询问或答复，无论是当面、通过电话、以书面形式，还是通过电子传输设备，并包括但不限于所有函件、电子邮件、录音、传送单、备忘录、电话通信、语音留言、电报、电话传真、传真副本、电传、即时消息、聊天、短信、电话笔记，或在内部或与第三方传送的笔记。\n\n21. “资产”系指任何可用于产生正向经济价值的项目，包括但不限于由某一实体拥有、控制或为其利益而设的任何具有经济价值的资源，且预期将提供未来利益，包括但不限于所有不动产和动产、无形财产、投资、投资权或未来收入权、现金、银行账户、商品、证券、债权、对某一实体的全部或部分控制权，以及预期的经济机会。\n\n22. “转让”应具有《破产法典》第 101(54) 条赋予其的含义。\n\n四、应提交的文件\n\n1. 与债务人之间的所有通信，以及与债务人通信有关的文件。\n\n2. 与 Rule of Law Foundation III, Inc.（法治基金会 III 公司）、Rule of Law Society IV, Inc.（法治协会 IV 公司）、New Federal State of China（中国新联邦国家）、Himalaya Alliance（喜马拉雅联盟）及 Himalaya Farms（喜马拉雅农场）有关的所有文件。\n\n3. 与 Rule of Law Foundation III, Inc.（法治基金会 III 公司）、Rule of Law Society IV, Inc.（法治协会 IV 公司）、New Federal State of China（中国新联邦国家）、Himalaya Alliance（喜马拉雅联盟）、Himalaya Farms（喜马拉雅农场）或任何其他关联实体有关的资金转让有关的所有文件。\n\n4. 关于由债务人作出、与债务人进行或代表债务人进行的任何投资、商业交易或交易事项的所有文件。\n\n5. 与债务人、债务人的家庭成员或关联个人之间的所有通信，以及与债务人、债务人的家庭成员或关联个人之间的通信有关、并与任何法律实体的运营、管理或决策有关的文件，包括但不限于 Rule of Law Foundation III, Inc.（法治基金会 III 公司）、Rule of Law Society IV, Inc.（法治协会 IV 公司）、New Federal State of China（中国新联邦国家）、Himalaya Alliance（喜马拉雅联盟）、Himalaya Farms（喜马拉雅农场）、家庭关联实体及关联实体。\n\n附件 C-10\n\nB2540（表格 2540——规则 2004 审查传票）（12/15）案件 22-50073 文档 1592 提交于 03/24/23 登记于 03/24/23 10:57:37 第 199 页，共 1063 页\n\nUNITED STATES BANKRUPTCY COURT（美国破产法院）\n\nDistrict of Connecticut（康涅狄格地区）\n\n关于 HO WAN KWOK（郭文贵）等人，\n\n1 案件编号 22-50073 (JAM)\n\n债务人 第 11 章\n\n（合并管理）\n\n规则 2004 审查传票\n\n致：Alex Hadjicharalambous（亚历克斯·哈吉查拉兰布斯）\n\n（传票所指向人员的姓名）\n\n证言：兹命令你于下列载明的时间、日期和地点出席，并根据《联邦破产程序规则》第 2004 条接受审查并作证。随附准许该审查的法院命令副本。\n\n地点　日期和时间\n\nPaul Hastings LLP（普衡律师事务所）\n200 Park Avenue　[TBD]\nNew York, New York 10166（纽约州纽约市 10166）\n\n审查将以以下方式记录：法庭记录员/速记员\n\n提交：你或你的代表还必须在审查时携带下列文件、电子存储信息或物品，并必须允许对该材料进行检查、复制、测试或抽样：\n\n见随附的文件提交请求。\n\n《联邦民事诉讼规则》第 45 条的下列规定，经《联邦破产程序规则》第 9016 条适用于破产案件，现随附——第 45(c) 条，关于履行地点；第 45(d) 条，关于对作为传票对象人员的保护；以及第 45(e) 条和第 45(g) 条，关于你对本传票作出回应的义务以及未作出回应的潜在后果。\n\n日期：March , 2023\n\n法院书记官\n\n或\n\n书记官或副书记官签名　律师签名\n\n签发或请求本传票、代表第 11 章受托人 Luc A. Despins（吕克·A·德斯平斯）的律师的姓名、地址、电子邮件地址和电话号码如下：\n\nDouglas S. Skalka, Esq.（道格拉斯·S·斯卡尔卡，律师）；Neubert, Pepe & Monteith, P.C.；195 Church Street, New Haven, Connecticut 06510；dskalka@npmlaw.com；(203) 821-2000\n\n致签发或请求本传票之人的通知\n\n如本传票要求在审判前提交文件、电子存储信息或有形物品，或检查场所，则必须在本传票送达给其所指向之人之前，向每一方送达通知及本传票副本。《联邦民事诉讼规则》第 45(a)(4) 条。\n\n软件版权 (c) 1996-2022 Best Case, LLC - www.bestcase.com Best Case Bankruptcy 1 本第 11 章案件中的债务人为 Ho Wan Kwok（郭文贵，亦称 Guo Wengui、Miles Guo 和 Miles Kwok，以及众多其他别名）（税务识别号码后四位：9595）、Genever Holdings LLC（税务识别号码后四位：8202）及 Genever Holdings Corporation。受托人、Genever Holdings LLC 及 Genever Holdings Corporation 的邮寄地址为 Paul Hastings LLP（普衡律师事务所），200 Park Avenue, New York, NY 10166，转交 Luc A. Despins（吕克·A·德斯平斯），作为 Ho Wan Kwok（郭文贵）遗产的受托人（仅为通知和通信之目的）。\n\n送达证明\n\n（除非《联邦民事诉讼规则》第 45 条要求，否则本节不应向法院提交。）\n\n本人于（日期）收到向（个人姓名及职务，如有）发出的本传票。\n\n本人以下列方式向所列人员送达传票副本：\n\n于（日期）送达；或\n\n本人未执行而退回本传票，原因如下：\n\n除非本传票代表美国或其官员或代理人签发，本人亦已向证人支付一天出席费用及法律允许的里程费，金额为 \\$ 。\n\n本人差旅费用为 \\$，服务费用为 \\$，合计为 \\$ 。\n\n本人在伪证处罚的约束下声明，上述信息真实且正确。\n\n日期：\n\n送达人员签名\n\n正楷姓名及职务\n\n送达人员地址\n\n关于尝试送达等的补充信息：\n\n《联邦民事诉讼规则》第 45(c)、(d)、(e) 及 (g) 条（自 12/1/13 生效）（经《联邦破产程序规则》第 9016 条适用于破产案件）\n\n(c) 履行地点。\n\n(1) 关于审判、听证或证言录取。传票仅可要求某人按以下方式出席审判、听证或证言录取：\n\n(A) 在该人员居住、受雇或经常亲自从事商业活动地点 100 英里范围内；或\n\n(B) 在该人员居住、受雇或经常亲自从事商业活动所在州内，如该人员\n\n(i) 是当事人或当事人的高级职员；或\n\n(ii) 被命令出席审判且不会产生重大费用。\n\n(2) 关于其他证据开示。传票可要求：\n\n(A) 在该人员居住、受雇或经常亲自从事商业活动地点 100 英里范围内的地点提交文件、电子存储信息或物品；以及\n\n(B) 在拟检查的场所检查场所。\n\n(d) 对作为传票对象人员的保护；执行。\n\n(1) 避免不当负担或费用；制裁。负责签发及送达传票的当事人或律师必须采取合理措施，避免给作为传票对象的人员施加不当负担或费用。要求履行的地区法院必须执行该义务，并对未遵守者的当事人或律师施加适当制裁，其中可包括损失的收入和合理的律师费。\n\n(2) 要求提交材料或准许检查。\n\n(A) 无须出席。被要求提交文件、电子存储信息或有形物品，或准许检查场所的人员，除非同时被要求出席证言录取、听证或审判，无须亲自到提交或检查地点出席。\n\n(B) 异议。被要求提交文件或有形物品，或准许检查的人员，可以向传票中指定的当事人或律师送达书面异议，反对检查、复制、测试或抽样部分或全部材料，或反对检查场所，或者反对以所要求的一种或多种形式提交电子存储信息。异议必须在规定履行时间之前或传票送达后 14 日内（以较早者为准）送达。如提出异议，适用以下规则：\n\n(i) 经通知被命令人员后，送达方可随时向要求履行的地区法院提出动议，请求作出强制提交或检查的命令。\n\n(ii) 仅可依命令所指示要求实施上述行为，且该命令必须保护既非当事人亦非当事人高级职员的人员免受因履行而产生的重大费用。\n\n(3) 撤销或修改传票。\n\n(A) 必须撤销或修改的情形。经及时动议，要求履行的地区法院必须撤销或修改具有下列情形的传票：\n\n(i) 未给予合理的履行时间；\n\n(ii) 要求某人在第 45(c) 条规定的地理范围限制之外履行；\n\n(iii) 要求披露享有特权或受其他保护的事项，而不存在任何适用的例外或豁免；\n\n(iv) 使某人承受不当负担。\n\n(B) 准许情形。为保护受传票约束或受其影响的人，要求履行地所在地区的法院可依动议撤销或修改传票，如该传票要求：\n\n(i) 披露商业秘密或其他保密的研究、开发或商业信息；或\n\n(ii) 披露未受聘专家的意见或信息，且该意见或信息并未描述争议中的具体事件，并且系该专家在未受一方当事人请求的情况下进行研究所得。\n\n(C) 将规定条件作为替代方案。在规则45(d)(3)(B)所述情形下，如送达方：\n\n(i) 证明其对该证词或材料具有重大需要，且如不承受不当困难便无法通过其他方式满足该需要；并且\n\n(ii) 确保被传唤人将获得合理报酬，\n\n法院可不撤销或修改传票，而命令在规定条件下出庭或提交材料。\n\n(e) 对传票作出回应的义务。\n\n(1) 提交文件或电子存储信息。下列程序适用于提交文件或电子存储信息：\n\n(A) 文件。对要求提交文件的传票作出回应的人，必须按照文件在日常业务过程中保存的方式提交，或者必须将文件整理并标注，以对应请求中的类别。\n\n(B) 未规定电子存储信息提交形式。如果传票未规定电子存储信息的提交形式，作出回应的人必须按照其通常保存的形式或以合理可用的形式提交。\n\n(C) 电子存储信息仅以一种形式提交。作出回应的人无需以一种以上的形式提交同一电子存储信息。\n\n(D) 无法访问的电子存储信息。作出回应的人无需就其认定因不当负担或费用而无法合理访问的来源中的电子存储信息提供证据开示。对于强制证据开示动议或保护令动议，作出回应的人必须证明该信息因不当负担或费用而无法合理访问。如作出该证明，法院仍可在请求方证明有正当理由的情况下，考虑规则26(b)(2)(C)的限制，命令从该等来源进行证据开示。法院可为该证据开示规定条件。\n\n(2) 主张特权或保护。\n\n(A) 被扣留的信息。以该信息享有特权或作为审判准备材料受保护为由扣留被传唤信息的人必须：(i) 明确提出该主张；并且\n\n(ii) 以一种方式说明被扣留文件、通信或有形物品的性质，使当事人在不披露本身享有特权或受保护的信息的情况下，能够评估该主张。\n\n(B) 已提交的信息。如为回应传票而提交的信息受到特权主张或作为审判准备材料受保护主张的约束，提出该主张的人可将该主张及其依据通知任何收到该信息的当事人。收到通知后，当事人必须立即返还、隔离或销毁所指明的信息及其持有的任何副本；在该主张得到解决前不得使用或披露该信息；如该当事人在收到通知前已披露该信息，必须采取合理步骤追回该信息；并且可立即将该信息密封提交给要求履行地所在地区的法院，以裁定该主张。提交该信息的人必须在该主张得到解决前保存该信息。\n\n(g) 藐视法庭。要求履行地所在地区的法院——以及在动议被移送后，签发法院——可对已被送达但无充分理由不遵守传票或与之相关命令的人认定藐视法庭。\n\n有关获取传票材料的信息，参见 Fed.R.Civ.P.45(a) 委员会说明（2013）\n\n……\n\n文件提交请求\nI. 指示\n\n1. 除非另有说明，下列文件请求（以下简称“请求”，每一项称为“一项请求”）必须分别并具体作出回应。除非善意提出异议，否则必须完整答复每一项请求；如提出异议，应按如下规定详细说明异议理由。如异议仅涉及一项请求的一部分，或其中所含的一个词、短语或条款，您仅须说明对该部分的异议，并对其余请求作出回应。\n\n2. 电子存储信息必须依照下列指示提交：\n\na. 图像。黑白图像必须为300 DPI Group IV 单页 TIFF 文件。彩色图像必须以 JPEG 格式提交。文件名不得含有嵌入空格或特殊字符（包括逗号）。文件夹名称不得含有嵌入空格或特殊字符（包括逗号）。所有 TIFF 图像文件必须具有唯一文件名，即 Bates 编号。每张图像右下角必须标注连续的 Bates 编号。每个文件夹内的 TIFF 文件数量不得超过1000个。Excel 电子表格应具有以该文件的 Bates 编号命名的占位图像。\n\nb. 图像加载文件\n\na. Concordance® 数据文件。数据文件（.DAT）包含将加载至 Concordance® 数据库的所有字段信息。.DAT 文件的第一行必须为标明字段名称的标题行。.DAT 文件必须使用以下 Concordance® 默认分隔符：逗号 ASCII 字符（020）引号 þ ASCII 字符（254）。日期字段应采用以下格式提供：mm/dd/yyyy。日期和时间字段必须为两个单独字段。如文件包括图像化的电子邮件及附件，必须包含附件字段，以保留电子邮件与其附件之间的父/子关系。必须包含 OCRPATH 字段，以提供已提交存储介质上提取文本文件的文件路径和名称。文本文件必须以 FIRSTBATES 命名。不得在 .DAT 文件中包含文本。对于含有原生文件的文件，必须包含 LINK 字段，以提供原生文件的文件路径和名称。原生文件必须以 FIRSTBATES 命名。\n\nb. Concordance Image® 或 Opticon 交叉引用文件。图像交叉引用文件（.LOG 或 .OPT）将图像链接至数据库记录。该文件应为逗号分隔文件，每行由七个字段组成，并且数据库中的每张图像均应在交叉引用文件中有一行，格式如下：ImageID,VolumeLabel,ImageFilePath,DocumentBreak,FolderBreak,Box Break,PageCoun。\n\nc. 文件文本。文本必须作为单独的文本文件提交，而非作为 .DAT 文件内的字段。文本文件的完整路径（OCRPATH）应包含在 .DAT 文件中。建议使用以 FIRSTBATES/Image Key 命名的文件级 ANSI 文本文件。提取的文本文件必须置于单独的文件夹中，每个文件夹内的文本文件数量不得超过1,000个。文件夹名称中不得含有特殊字符（包括逗号）。文本文件必须按文件级别提供。\n\nd. 特定文件类型的原生提交。为充分理解其内容和含义而合理需要以原生格式查看的文件类型，必须以原生格式提交。这些文件包括但不限于电子表格、类电子表格文件（Microsoft Excel、逗号分隔值、制表符分隔值等）、Microsoft PowerPoint 或其他特殊演示文件、数据库文件和音频/视频文件。应提供一张标有 Bates 编号的插页图像，以表明原生文件的存在，并将原生文件路径作为字段包含在 .dat 文件中。提交的原生文件应以与该文件插页相对应的 Bates 编号命名。原生文件应归入按递增方式命名的“NATIVE”目录中，与图像目录分开。\n\ne. 去重。对于存在完全重复件的每一电子文件，仅提交一份副本。对于电子邮件，应根据由 BCC、Body、CC、From、IntMsgID、To 和 Attach 属性生成的 MD5 哈希值合并重复件。对于电子邮件附件和独立电子文件，应根据整个文件的 MD5 哈希值合并重复件。\n\nf. 元数据。应以符合 Concordance 要求的加载文件（.dat）形式提交每份文件的提取元数据。.DAT 文件的第一行必须为标明字段名称的标题行。.DAT 文件必须使用以下 Concordance 默认分隔符：逗号 , ASCII 字符（020）引号 þ ASCII 字符（254）\n\n日期字段应采用以下格式提供：mm/dd/yyyy。日期和时间字段必须为两个单独字段。下列为必需元数据：\n\nCase 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 204 of 1063\n\n字段名称　示例数据　说明\n\nFIRSTBATES　EDC0000001　原生文件文件/电子邮件的第一个 Bates 编号\n\nLASTBATES　EDC0000001　原生文件文件/电子邮件的最后一个 Bates 编号\n\nLASTBATES 字段应针对单页予以填写\n\nATTACHRANGE　EDC0000001　父文件第一页的 Bates 编号至最后一个附件“子”文件最后一页的 Bates 编号\n-　EDC0000015\n\nBEGATTACH　EDC0000001　附件范围的第一个 Bates 编号\n\nENDATTACH　EDC0000015　附件范围的最后一个 Bates 编号\n\nCUSTODIAN　Smith, John　电子邮件：电子邮件所在的邮箱\n原生文件：文件来源的个人或部门名称\n\nFROM　John Smith　电子邮件：发件人\n原生文件：文件作者\n多个条目之间应使用分号分隔\n\nTO　Coffman, Janice; LeeW　收件人\n[mailto:LeeW@MSN.com]　多个条目之间应使用分号分隔\n\nCC　Frank Thompson [mailto:　抄送收件人\nfrank_Thompson@cdt.com]　多个条目之间应使用分号分隔\n\nBCC　John Cain　密送收件人\n多个条目之间应使用分号分隔\n\nSUBJECT　Board Meeting Minutes　电子邮件：电子邮件主题行 原生文件：文件标题（如有）\n\nFILE_NAME　BoardMeetingMinutes.docx　原生文件：原始原生文件名称，包括扩展名\n\nDATE_SENT　10/12/2010　电子邮件：电子邮件发送日期\n原生文件：（空）\n\nTIME_SENT/　07:05 PM GMT　电子邮件：电子邮件发送时间/电子邮件标准化所采用的时区\nTIME_ZONE\n\nTIME_ZONE　GMT　在转换过程中电子邮件被标准化所采用的时区。\n\nLINK　EDC0000001.msg　电子邮件或原生文件文件的超链接\n链接文件必须按 FIRSTBATES 编号命名\n\nFILE_EXTEN　MSG　表示电子邮件或文件的文件类型扩展名\n\nAUTHOR　John Smith　电子邮件：（空）\n原生文件：文件作者\n\nDATE_CREATED　10/10/2010　电子邮件：（空）\n原生文件：文件创建日期\n\nCase 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 205 of 1063\n\nTIME_CREATED　10:25 AM　电子邮件：（空）\n\n原生：文档创建时间\n此数据必须为单独字段，且不得与 DATE_CREATED 字段合并\nDATE_MOD　10/12/2010　电子邮件：（空）\n原生：文档最后修改日期\nTIME_MOD　07:00 PM　电子邮件：（空）\n原生：文档最后修改时间\n此数据必须为单独字段，且不得与 DATE_MOD 字段合并\nDATE_ACCESSD　10/12/2010　电子邮件：（空）\n原生：文档最后访问日期\nTIME_ACCESSD　07:00 PM　电子邮件：（空）\n原生：文档最后访问时间\n此数据必须为单独字段，且不得与 DATE_ACCESSD 字段合并\nFILE_SIZE　5,952　原生文件文档/电子邮件的大小（KB）\nPGCOUNT　1　原生文件文档/电子邮件的页数\nPATH　电子邮件：（空）\nAgenda.doc　原生：存储原生文件文档的路径，包括原始文件名。\nINTFILEPATH　Personal Folders\\Deleted Items\\Board Meeting Minutes.msg　电子邮件：电子邮件的原始位置，包括原始文件名。\n原生：（空）\nINTMSGID　<000805c2c71b\\$75977050\\$cb8306d1@MSN>　电子邮件：唯一消息 ID　原生：（空）\nMD5HASH　d131dd02c5e6eec4693d9a0698aff95c2fcab58712467eab4004583eb8fb7f89　文档的 MD5 哈希值。\nOCRPATH　TEXT/001/EDC0000001.txt　原生文件提取文本的路径\n\n3. 每项请求均独立适用并应独立解释，除非另有说明，任何一项请求均不限制任何其他请求的范围。\n\n4. 所有文件均应按其在日常业务过程中保存的方式提供，或者应予以整理并加贴标签，以对应本请求中的类别。\n\n5. 本文所载每项请求均延及下列所有文件：(a) 由您占有、保管或控制的文件；或 (b) 由任何代表您行事之人占有、保管或控制的文件，\n案件 22-50073 文书 1592 提交日期 03/24/23 录入日期 03/24/23 10:57:37 第 206 页，共 1063 页\n\n包括您的律师或其他代表及顾问。每份文件均应完整提供。\n\n6. 如要求您提供的文件已不再由您占有、保管或控制，则您的答复必须：(a) 详细说明该文件的性质及其内容；(b) 确认编制或撰写该文件的人员（以及，如适用，向其发送该文件的人员）；(c) 确认该文件编制或创建的日期；(d) 说明该文件是否：(i) 遗失或丢失，(ii) 已被销毁，(iii) 已自愿或非自愿转移给他人，或 (iv) 已以其他方式处置；(e) 说明该等处置的理由，以及与该等处置有关的事实和情形；(f) 确认授权该等处置的人员；(g) 确认该等处置的日期或大致日期；(h) 说明该文件最近一次由您占有、保管或控制的时间；以及 (i) 确认目前占有、保管或控制该文件的人员，如有。\n\n7. 如要求您提供的文件已被销毁，则除前述指示所要求的信息外，您的答复还必须说明：(a) 该文件被销毁的理由；(b) 销毁该文件的人员身份；以及 (c) 指示销毁该文件的人员身份。\n\n8. 如您主张所请求的文件享有特权或属于律师工作成果，则您的答复必须：(a) 陈述：(i) 对该文件作出足以支持您关于该文件享有特权之主张的说明，(ii) 该文件的标题，(iii) 该文件的日期，(iv) 该文件的作者，(v) 该文件的收件人，(vi) 收到或阅览过该文件原件或任何草稿、副本或复制件的每一人员身份，(vii) 该文件本身或该文件所载或提及的任何信息是否由任何其他人员占有、保管或控制；如是，则确认该等人员的身份，\n案件 22-50073 文书 1592 提交日期 03/24/23 录入日期 03/24/23 10:57:37 第 207 页，共 1063 页\n\n以及说明该等信息如何进入其占有状态，(viii) 据以拒绝提供该文件的特权主张，以及 (ix) 您将据以支持该特权主张的所有情形；以及 (b) 就根据 D. Conn. L. Civ. R. 26(e) 因主张特权而拒绝提供的每份文件，制作一份特权清单，其中载明本指示第 (a) 部分所要求的全部信息。对于文件请求中未主张特权或工作成果保护的任何部分，应完整提供相应文件。\n\n9. 如一份本应提供的文件的一部分含有受特权主张约束的信息，则仅应依照上述指示，从该文件中删除或涂黑受特权主张约束的该部分，其余部分应予提供。\n\n10. 各项请求具有持续性。特此指示您：(a) 在得知先前答复不完整或不正确后，立即补充或更正任何后来得知不完整或不正确的答复；以及 (b) 提供根据下列规定所要求的任何补充文件\n\n11. 如文件为英语以外的语言，您应提供该文件。如文件为英语以外的语言，且存在英文译本，您应同时提供两份文件。\n\n12. 对实体的所有提及均包括其所有关联方。\n\n13. 对个人姓名的所有提及均包括所有别名、化名或昵称。\n案件 22-50073 文书 1592 提交日期 03/24/23 录入日期 03/24/23 10:57:37 第 208 页，共 1063 页\n\n14. 除非另有明确说明，文件请求所涵盖的期间为自 February 5, 2012 起至应提交文件请求答复之日止。\nII. 解释规则\n\n15. (a) 任何单数名词的使用，应解释为包括复数，反之亦然；以及 (b) 任何时态动词的使用，应解释为包括该动词所有其他时态的使用。\n\n16. (a) “和”与“或”应视需要作连词性或选择性解释，以将所有原本可能被解释为在任何请求范围之外的答复纳入该请求范围；以及 (b) “每一”与“任何”应视为包括并涵盖“每一个”与“所有”。\nIII. 定义\n\n经 D. Conn. Bankr. L.R. 2004-1(a) 纳入的 D. Conn. L. Civ. R. 26(c) 所规定的定义，以及 D. Conn. L. Civ. R. 26(d) 所规定的解释规则，适用于文件请求。此外，本文件请求中使用的下列术语具有以下含义：\n\n1. “您”或“您的”或“您本人”是指并包括 Christodoulos G. Vassiliades & Co. LLC（克里斯托杜洛斯·G·瓦西利阿季斯律师事务所有限责任公司），以及其任何雇员、代理人、律师、顾问，或任何代表其行事之人。\n\n2. “债务人”是指 Ho Wan Kwok（郭文贵）（又名 Miles Kwok、Miles Guo、Guo Wengui、Guo Haoyun、郭文贵或任何其他别名），以及其雇员、代理人、律师、顾问，或任何代表其行事之人。\n案件 22-50073 文书 1592 提交日期 03/24/23 录入日期 03/24/23 10:57:37 第 209 页，共 1063 页\n\n3. “债务人之子”是指 Qiang Guo（郭强）（又名 Mileson Kwok、郭强或任何其他别名），以及其雇员、代理人、律师、顾问，或任何代表其行事之人。\n\n4. “债务人之女”是指 Mei Guo（郭美）（又名 Mei Gui、郭美或任何其他别名），以及其雇员、代理人、律师、顾问，或任何代表其行事之人。\n\n5. “债务人所谓的妻子”是指 Hing Chi Ngok（岳庆芝）（又名 Hing Chi Ng、Yue Qingzhi、岳庆芝或任何其他别名），以及其雇员、代理人、律师、顾问，或任何代表其行事之人。\n\n6. “债务人家属”系指债务人、债务人之子、债务人之女及债务人所谓的妻子，以及与债务人有任何其他亲属关系的人。\n\n7. “关联个人”系指单独或共同符合下列情形的所有个人：(1) 持有、控制、保管或有权酌情处分由债务人或债务人家属拥有、控制或享有的资产；或 (2) 曾任一家或多家关联实体的雇员、董事，或以其他方式与一家或多家关联实体有关联，以及前述任何人员各自的雇员、代理人、律师、顾问，或任何代表前述任何人员行事之人。该等关联个人包括但不限于：Daniel Podhaskie（丹尼尔·波德哈斯基）、Jason Miller（杰森·米勒）、Steve Bannon（史蒂夫·班农）、Karin Maistrello（卡琳·迈斯特雷洛）、Melissa Francis（梅利莎·弗朗西斯）、Anthony DiBattista（安东尼·迪巴蒂斯塔）、William Gertz（威廉·格茨）、Arethusa Forsyth（阿瑞修莎·福赛思）、Glenn Mellor（格伦·梅勒）、Jennifer Mercurio（詹妮弗·梅尔库里奥）、Eduardo Eurnekian（爱德华多·厄尔内基安）、Wencong Wang（王文聪）、Han Chunguang（韩春光）（又名 韩春光）、Qu Guojiao（屈国姣）（又名 Qu Guo Jiao、屈国姣）、Guo Lijie（郭丽杰）（又名 郭丽杰）、Zhang Wei（张伟）（又名 张伟*）、Lihong Wei Lafrenz（魏丽红）（又名 Sara Wei、魏丽红）、Hao Haidong（郝海东）（又名 郝海东）、Ross Heinemeyer（罗斯·海内迈耶）、Max Krasner（马克斯·克拉斯纳）、Kyle Bass（凯尔·巴斯）、Melissa Mendez（梅利莎·门德斯）、Ya Li（李娅）（又名 李娅）、Dinggang Wang（王定刚）（又名 王定刚）、An Hong（安红）（又名 安红）、Yvette Wang（王雁平）（又名 Yanping Wang、Yan Ping Wang、王雁平）、Fiona Yu（菲奥娜·于）、Je Kin Ming\n案件 22-50073 文书 1592 提交日期 03/24/23 录入日期 03/24/23 10:57:37 第 210 页，共 1063 页\n\n（又名 William Je、Yu Jianming、余建明）、Yaz Qingua（亚兹·钦瓜）及 Lao Jiang（姜云浮）（又名 Jiang Yunfu、Jiang Yunfu Be、姜云浮）。\n\n8. “关联实体”系指单独或共同符合下列情形的所有各类组织或实体：(1) 曾由债务人或债务人家属拥有、控制或投资；或 (2) 对债务人或债务人家属拥有、控制或享有的任何资产直接或间接享有权益，以及前述任何实体各自的雇员、代理人、律师、顾问，或任何代表前述任何实体行事之人。该等关联实体包括但不限于：7 Nod Hill LLC（7诺德山有限责任公司）、AAGV Limited（AAGV有限公司）、ACA Investment Management Limited（ACA投资管理有限公司）、ACA Capital Group Limited（ACA资本集团有限公司）、Ace Decade Holdings Limited（艾斯十年控股有限公司）、AI Group Holdings Inc.（AI集团控股公司）、Alfa Global Ventures Limited（阿尔法全球创投有限公司）、Alfonso Global Limited（阿方索全球有限公司）、Allied Capital Global Limited（联合资本全球有限公司）、Alpine Fiduciaries SA（阿尔卑斯信托受托人股份公司）、Anton Development Limited（安东开发有限公司）、Assets Sino Limited（中资产有限公司）、Auspicious Coast Limited（吉祥海岸有限公司）、Beijing Pangu Investment Co.（北京盘古投资公司）、Beijing Pangu Investment Co. Ltd.（北京盘古投资有限公司）、Beijing Pangu Investment Inc.（北京盘古投资股份公司）、Beijing Zenith Holdings Company Limited（北京泽尼思控股有限公司）、Booming Sail New York LLC（纽约兴帆有限责任公司）、Bravo Luck Limited（百瑞幸运有限公司）、BSA Strategic Fund I（BSA战略基金I）、China Golden Spring (Hong Kong) Limited（中国金泉〈香港〉有限公司）、Chuang Xin Limited（创新有限公司）、Crane Advisory Group LLC（克兰咨询集团有限责任公司）、Creative Apex Investments Limited（创意顶峰投资有限公司）、Crystal Breeze Investments Limited（水晶微风投资有限公司）、Dawn State Limited（黎明州有限公司）、Eastern Profit Corporation Limited（东方利润有限公司）、Elite Well Global Limited（精英环球有限公司）、Empire Growth Holdings（帝国增长控股）、Freedom Media Ventures Ltd.（自由媒体创投有限公司）、G Club Operations LLC（G Club运营有限责任公司）、G Fashion LLC（G时尚有限责任公司）、G News LLC（G新闻有限责任公司）、GETTR USA（GETTR美国）、Genever Holdings Corporation（吉尼弗控股公司）、Genever Holdings LLC（吉尼弗控股有限责任公司）、Gfashion Media Group Inc.（G时尚媒体集团公司）、GFNY, Inc.（GFNY公司）、Globalist International Limited（全球主义者国际有限公司）、GNews Media Group Inc.（GNews媒体集团公司）、Golden Spring (New York) Ltd.（金泉〈纽约〉有限公司）、Greenwich Land LLC（格林尼治地产有限责任公司）、Guo Media（郭媒体）、GTV Media Group, Inc.（GTV媒体集团公司）、Hamilton Capital Holdings Inc.（汉密尔顿资本控股公司）、HCHK Property Management, Inc.（HCHK物业管理公司）、HCHK Technologies, Inc.（HCHK技术公司）、Head Win Group Limited（领赢集团有限公司）、Henan Yuda（河南裕达）、Himalaya Embassy（喜马拉雅使馆）、Himalaya Exchange（喜马拉雅交易所）、Himalaya Federal Reserve（喜马拉雅联邦储备）、Himalaya Investment LLC（喜马拉雅投资有限责任公司）、Himalaya International（喜马拉雅国际）、\n案件 22-50073 文书 1592 提交日期 03/24/23 录入日期 03/24/23 10:57:37 第 211 页，共 1063 页\n\nHimalaya New World Inc.（喜马拉雅新世界公司）、Himalaya Supervisory Organization（喜马拉雅监督组织）、Himalaya Ventures LLC（喜马拉雅创投有限责任公司）、HK International Funds Investments (USA) Limited LLC（HK国际基金投资（美国）有限责任公司）、Hong Kong International Funds Investments Limited（香港国际基金投资有限公司）、Hudson Diamond Holding（哈德逊钻石控股）、Infinite Increase Limited（无限增长有限公司）、Infinitum Developments Limited（无限开发有限公司）、Infinity Treasury Management Inc.（无限资金管理公司）、Insight Phoenix Fund（洞见凤凰基金）、Lamp Capital LLC（灯塔资本有限责任公司）、Leading Shine Limited（领先光辉有限公司）、Leading Shine NY Limited（领先光辉纽约有限公司）、Lexington Property and Staffing（列克星敦房地产及人事服务公司）、Long Gate Limited（长龙门有限公司）、Maywind Trading LLC（五月风贸易有限责任公司）、MOS Himalaya LLC（MOS喜马拉雅有限责任公司）、Next Tycoon Investments Limited（下一个大亨投资有限公司）、New Federal State of China (a/k/a NFSC)（新中国联邦，亦称NFSC）、Noble Fame Global Limited（高贵名誉环球有限公司）、Rosy Acme Ventures Limited（玫瑰顶峰创投有限公司）、Rule of Law Foundation III, Inc.（法治基金会III公司）、Rule of Law Foundation IV, Inc.（法治基金会IV公司）、Rule of Law Fund（法治基金）、Rule of Law Society（法治协会）、Rule of Law Society IV, Inc.（法治协会IV公司）、G-Translators PTY LTD（G-译者有限公司）、Saraca Media Group, Inc.（萨拉卡媒体集团公司）、Shiny Ace Ltd.（闪耀王牌有限公司）、Shiny Times Holdings Ltd.（闪耀时代控股有限公司）、Spirit Charter Investment Limited（精神特许投资有限公司）、Stevenson, Wong & Co.（史蒂文森、黄及公司）、Voice of Guo Media, Inc.（郭之声媒体公司）、Well Origin Ltd.（良好起源有限公司）、World Century Limited（世界世纪有限公司）、Worldwide Opportunity Holdings Limited（全球机遇控股有限公司）、Whitecroft Shore Limited（怀特克罗夫特海岸有限公司）及ZIBA Limited（ZIBA有限公司）。\n\n9. “Including”及其任何变体意为“包括但不限于”。\n\n10. “And”和“or”意为“和/或”，并应同时按合取关系及析取关系解释，以最大化其范围。\n\n11. “Any”、“all”和“each”均意为“每一个及所有”。\n\n12. “Each”和“every”均意为“每一个及所有”。\n\n13. “Third Party”意为除您本人以外的个人或实体。\n\n14. “Transfer”应具有《破产法典》第101(54)条所赋予的含义。\n\n15. “Document”意为属于Fed. R. Civ. P. 34范围内的任何信息或物品，并包括但不限于处于或曾处于您占有、保管或控制之下的各种类别、类型、性质或描述的每一项书面、记录或图形材料，包括所有电子邮件、以电子形式保存的计算机文件、通信函件、备忘录、磁带、速记或手写笔记、任何种类的书面表格、图表、蓝图、图纸、草图、曲线图、计划、文章、规格说明、日记、信件、电报、照片、会议记录、合同、协议、调查报告、计算机打印件、任何种类的数据汇编、电传、传真、电子邮件、短信、即时消息、语音留言、发票、订购单、支票、汇票、对账单、贷项通知单、报告、头寸报告、摘要、索引、账簿、分类账、笔记本、明细表、透明胶片、录音、目录、广告、宣传材料、胶片、录像带、录音带、CD、计算机磁盘、小册子、宣传册、穿孔卡、工时单、推文、社交媒体帖子或任何其他种类的书面或记录材料的所有印刷及电子副本，以及其所有元数据，无论其以何种方式储存（无论为有形形式还是电子形式）、记录、制作或复制；还包括但不限于前述任何材料的草稿或副本，如该等草稿或副本载有原始文件中未见的任何种类的笔记、评论或标记，或在其他方面与原始文件不相同。\n\nCase 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 212 of 1063\n\n16. “Person(s)”意为个人、公司、独资企业、合伙企业、协会或任何其他实体。“Person”还包括任何代理人、代表或专家，包括但不限于律师或财务顾问。\n\n17. “Entity”意为任何自然人、公司、合伙企业、子公司、独资企业、商号、董事会、合资企业、协会、机构、主管机关、委员会或其他商业实体或法人，以及任何关联方、代理人、母公司，包括但不限于法律顾问、财务顾问或任何其他代表。\n\nCase 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 213 of 1063\n\n18. “Regarding”意为涉及、描述、构成、提及、与之有关、支持、赞成、反对、加强、削弱、位于其中、结合考虑、对其有影响、证明、表明、报告、记录、暗示、回应、与之相连、评论、就其而言、关于、与之相关、讨论、显示、描述、反映、分析、构成及为其。\n\n19. 当“Relating to”、“relate(s) to”或“related to”用于指代任何特定主题事项时，意为包括但不限于任何构成、包含、涉及、含有、体现、反映、识别、陈述、直接或间接提及，或以任何方式与所识别的特定主题事项相关的文件。\n\n20. “Communication(s)”在最广义且不受限制的意义上，意为任何信息或知识的传递（以事实、观点、询问或其他形式）。Communication(s)还指所有谈话、协议、询问或答复，无论是当面、通过电话、以书面形式，还是通过电子传输设备进行，并包括但不限于所有通信函件、电子邮件、录音、传送单、备忘录、电话通信、语音留言、电报、电传传真、影印传真、电传、即时消息、聊天、短信、留言板或群聊中的帖子、社交媒体帖子、推文、上传至任何视频平台的视频、电话笔记，或在内部或与第三方之间传递的笔记。\n\n21. “Asset(s)”意为受占有、保管或控制的任何具有经济价值的项目。Asset包括所有不动产和动产，包括但不限于房地产、土地、房屋、公寓、共管公寓、汽车、游艇、船舶、飞机、喷气式飞机、直升机、现金、银行账户、加密货币、证券、应收账款、存货及其他有形和无形财产。\n\nCase 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 214 of 1063\n\nIV. 应提交的文件\n\n1. 所有与债务人、债务人财产、债务人家庭成员或关联实体的任何收入或资产有关的文件。\n\n2. 所有与债务人、债务人任何家庭成员和/或任何关联实体签订的任何委聘函有关的文件，包括该等委聘函的副本。\n\n3. 所有与您因代理债务人、债务人家庭成员或关联实体而收取任何预付聘金有关的文件，包括足以识别该预付聘金金额及其来源的文件。\n\n4. 所有与您从债务人、债务人家庭成员、家庭关联实体或关联实体处或代表其收取并存放于托管账户或客户信托账户中的任何费用、付款或款项有关的文件。\n\n5. 足以显示债务人、债务人家庭成员或关联实体向您支付或为其利益向您支付的任何款项的金额、日期及来源的文件。\n\n6. 所有与债务人的财务状况及其对债权人所负义务有关的文件，包括但不限于所有与任何试图逃避支付该等义务的行为有关的文件，以及所有与本次或任何其他实际或可能的破产或类似无力偿债程序有关的文件。\n\n7. 所有与关联实体有关的文件，包括但不限于与其公司结构、资产、注册信息、高级职员及董事、经营目的，以及其与债务人、债务人任何家庭成员或任何关联个人之间关系有关的文件。\n\nCase 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 215 of 1063\n\n8. 所有关于债务人或债务人家庭成员一方与关联实体另一方之间作出、进行或代表其作出的任何投资或商业交易的文件。\n\n9. 所有与债务人、债务人财产、债务人家庭成员或关联实体在其中持有任何权益或投资的任何实体有关的文件，包括但不限于该等权益或投资的性质及价值；债务人、债务人财产、债务人家庭成员或关联实体因该等权益或投资而从该实体获得的任何收益或利益；以及所有与该实体有关的任何财务报告或数据有关的文件，包括但不限于所有账簿和记录、财务报表或税务文件。\n\n10. 所有关于Lady May（梅夫人号）、Sherry Netherland Hotel / Condominium（谢里荷兰酒店／共管公寓）、位于Connecticut（康涅狄格州）Greenwich（格林威治）373 Taconic Rd.的住宅物业、位于Connecticut（康涅狄格州）Greenwich（格林威治）33 Ferncliff Rd.的住宅物业、位于Connecticut（康涅狄格州）Wilton（威尔顿）354 Nod Hill Rd.的住宅物业，以及债务人或债务人财产在任何关联实体中持有的任何财务权益的文件。\n\n11. 所有与债务人作为受托人、Genever Holdings Corporation（Genever控股公司）及Genever Holdings LLC（Genever控股有限责任公司）于February 17, 2015订立、以Bravo Luck Limited（好运有限公司）为受益人的所谓《信托声明及协议》有关的文件。\n\n12. 所有与债务人拥有、控制或使用的任何航空器有关的文件，包括但不限于尾号为T7-GQM的航空器以及在San Marino（圣马力诺）注册的任何其他航空器，包括但不限于所有注册文件副本及显示该等航空器所进行飞行和该等飞行机上人员的飞行舱单。\n\nCase 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 216 of 1063\n\n13. 所有与债务人、债务人家庭成员或关联实体于或约于July 2020或任何其他时间进行的原油期货或任何类似商品投资或交易有关的文件，包括但不限于与Jiang Yunfu（蒋云福）就该等投资或交易进行的通信。\n\n14. 您与债务人、债务人家庭成员或任何代表债务人行事的关联个人、代理人、雇员或其他个人之间，就与债务人、债务人财产、债务人家庭成员或关联实体有关的任何转让、投资或其他交易或商业往来所进行的所有通信。\n\n15. 所有关于由债务人、债务人财产、债务人家庭成员或关联实体设立、代表其设立或为其利益设立的任何信托或类似文书的文件，包括但不限于显示该等信托于何时设立、由谁设立、为谁的利益设立以及该文书信托财产的文件。\n\n16. 所有与涉及债务人、债务人家庭成员或任何关联实体的任何出售、取得、处置、购买、投资、出资、赠与、授信、贷款或转让有关的文件。\n\n17. 所有与涉及债务人的任何法律争议相关的任何义务、请求权、责任或债务有关的文件，包括但不限于与任何地方、州、联邦或国际机构（无论为行政机构、法院、合议庭或替代性争议解决实体）审理的任何诉讼有关的文件。\n\n18. 所有与向债务人、债务人财产、债务人家庭成员或任何关联实体提供或由其提供的任何贷款或授信，或就该等贷款或授信提出的申请有关的文件，包括但不限于：(i) 任何该等贷款或授信的条款，包括其偿还条款、陈述与保证及利率；以及(ii) 证明贷款付款的所有证据。\n\nCase 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 217 of 1063\n\n19. 所有与债务人使用任何属于、受控制于或其全部或部分所有权由债务人家庭成员、关联实体或关联个人持有的资产有关的文件。\n\n20. 关于与债务人、债务人财产、债务人家庭成员、关联实体或关联个人有关的任何资产负债表、银行对账单、账户对账单、财务报表、账户报表、电汇指示和/或确认书、资金证明、存款证、持仓证明、投资组合摘要或类似文件的所有文件，包括但不限于足以显示向上述任何一方进行的所有转让的所有文件。\n\n附件 C-11\n\nB2540（表格 2540——Rule 2004 审查传票）（12/15）案号 22-50073 文件 1592 于 03/24/23 提交，于 03/24/23 10:57:37 登记，第 219 页，共 1063 页\n\n美国破产法院\n\n康涅狄格地区\n\n关于 HO WAN KWOK（郭文贵）等人，\n\n1 案号 22-50073 (JAM)\n\n债务人 第 11 章\n\n（共同管理）\n\nRule 2004 审查传票\n\n致：Liberty Jet Management（自由喷气管理公司）\n\n（传票所指向人员的姓名）\n\n证言：兹命令你于下列规定的时间、日期及地点出席，根据《联邦破产程序规则》Rule 2004 进行审查并作证。随附准许该审查的法院命令副本。\n\n地点　日期和时间\n\nPaul Hastings LLP（保罗·黑斯廷斯律师事务所）\n200 Park Avenue　[TBD]\nNew York, New York 10166\n\n该审查将通过以下方式记录：法庭记录员/速记员\n\n提交：你或你的代表还必须在审查时携带下列文件、电子存储信息或物品，并必须允许对该材料进行检查、复制、测试或抽样：\n\n见随附的文件提交请求。\n\n以下《联邦民事诉讼规则》Rule 45 的规定，根据《联邦破产程序规则》Rule 9016 适用于破产案件，现附于本传票之后——关于履行地点的 Rule 45(c)；关于作为传票对象的你所受保护的 Rule 45(d)；以及关于你回应本传票的义务和未回应的潜在后果的 Rule 45(e) 和 45(g)。\n\n日期：March , 2023\n\n法院书记员\n\n或\n\n书记员或副书记员签名　律师签名\n\n签发或申请本传票、代表第 11 章受托人 Luc A. Despins（吕克·A·德斯平斯）的律师的姓名、地址、电子邮件地址及电话号码如下：\n\nDouglas S. Skalka, Esq.（道格拉斯·S·斯卡尔卡律师）；Neubert, Pepe & Monteith, P.C.（纽伯特、佩佩及蒙蒂斯专业公司）；195 Church Street, New Haven, Connecticut 06510 dskalka@npmlaw.com；(203) 821-2000\n\n致签发或申请本传票之人的通知\n\n如本传票命令在审判前提交文件、电子存储信息或有形物品，或检查场所，则必须在向传票所指向之人送达之前，向每一方当事人送达通知及本传票副本。《联邦民事诉讼规则》Rule 45(a)(4)。\n\n软件版权 (c) 1996-2022 Best Case, LLC - www.bestcase.com Best Case Bankruptcy 1 本第 11 章案件中的债务人为 Ho Wan Kwok（又名 Guo Wengui、Miles Guo 和 Miles Kwok，以及众多其他别名）（税务识别号码后四位：9595）、Genever Holdings LLC（税务识别号码后四位：8202）及 Genever Holdings Corporation。受托人、Genever Holdings LLC 和 Genever Holdings Corporation 的邮寄地址为 Paul Hastings LLP, 200 Park Avenue, New York, NY 10166，转交 Luc A. Despins，作为 Ho Wan Kwok 财产的受托人（仅为通知和通信之目的）。\n\n送达证明\n\n（除非《联邦民事诉讼规则》Rule 45 要求，否则本节不应向法院提交。）\n\n我于（日期）收到向（个人姓名及职务，如有）送达的本传票。\n\n我以下列方式通过向被指名人员交付副本送达本传票：\n\n于（日期）；或\n\n我未执行本传票即予退回，原因如下：\n\n除非本传票代表 United States（美国）或其官员或代理人之一签发，我还已向证人支付一天出席的费用及法律允许的里程费，金额为 \\$ 。\n\n我的差旅费用为 \\$，服务费用为 \\$，合计 \\$ 。\n\n我依伪证处罚之规定声明，该等信息真实且正确。\n\n日期：\n\n送达人签名\n\n正楷姓名及职务\n\n送达人地址\n\n关于尝试送达等的补充信息：\n\n《联邦民事诉讼规则》Rule 45(c)、(d)、(e) 和 (g)（于 12/1/13 生效）（根据《联邦破产程序规则》Rule 9016 适用于破产案件）\n\n(c) 履行地点。\n\n(1) 审判、听证或证言录取。传票仅可按下列方式命令某人出席审判、听证或证言录取：\n\n(A) 在该人居住、受雇或经常亲自从事营业活动地点 100 英里以内；或\n\n(B) 在该人居住、受雇或经常亲自从事营业活动所在州内，如该人：\n\n(i) 为当事人或当事人的高级职员；或\n\n(ii) 被命令出席审判且不会产生重大费用。\n\n(2) 为其他证据开示。传票可命令：\n\n(A) 在该人居住、受雇或经常亲自从事营业活动地点 100 英里以内的地点提交文件、电子存储信息或物品；以及\n\n(B) 在被检查场所进行场所检查。\n\n(d) 对作为传票对象之人的保护；执行。\n\n(1) 避免不当负担或费用；制裁。负责签发和送达传票的当事人或律师必须采取合理措施，避免对作为传票对象之人施加不当负担或费用。要求履行的地区法院必须执行该义务，并对未遵守者的当事人或律师施加适当制裁，制裁可包括损失的收入和合理的律师费。\n\n(2) 命令提交材料或允许检查。\n\n(A) 无须出庭。被命令提交文件、电子存储信息或有形物品，或允许检查场所之人，无须亲自到提交或检查地点出席，除非其亦被命令出席证言录取、听证或审判。\n\n(B) 异议。被命令提交文件或有形物品，或允许检查之人，可以向传票中指定的当事人或律师送达书面异议，反对检查、复制、测试或抽样全部或部分材料，或反对检查场所——或反对以所要求的一种或多种形式提交电子存储信息。异议必须在规定履行时间届至前或传票送达后 14 日内（以较早者为准）送达。如提出异议，适用下列规则：\n\n(i) 送达传票的一方可随时在通知被命令之人后，向要求履行的地区法院提出动议，请求作出强制提交或检查的命令。\n\n(ii) 仅可按该命令指示要求进行该等行为，且该命令必须保护既非当事人亦非当事人高级职员之人，使其免于因履行而产生的重大费用。\n\n(3) 撤销或修改传票。\n\n(A) 必须撤销或修改的情形。经及时动议，要求履行的地区法院必须撤销或修改具有下列情形的传票：\n\n(i) 未给予合理的履行时间；\n\n(ii) 要求某人在 Rule 45(c) 规定的地理范围以外履行；\n\n(iii) 要求披露享有特权或受其他保护的事项，且不适用任何例外或豁免；或\n\n(iv) 对某人施加不当负担。\n\n(B) 可以撤销或修改的情形。为保护作为传票对象或受其影响之人，要求履行的地区法院可经动议撤销或修改要求下列事项的传票：\n\n(i) 披露商业秘密或其他保密研究、开发或商业信息；或\n\n(ii) 披露未受聘专家的意见或信息，该等意见或信息并未描述争议中的具体事件，且源自该专家未经当事人请求进行的研究。\n\n(C) 以规定条件作为替代措施。在 Rule 45(d)(3)(B) 所述情形下，如送达传票的一方：\n\n(i) 证明对该证言或材料具有重大需要，且如不遭受不当困难即无法以其他方式满足该需要；并且\n\n(ii) 确保被传唤之人将获得合理补偿，\n\n法院可不撤销或修改传票，而命令在规定条件下出席或提交。\n\n(e) 回应传票的义务。\n\n(1) 提交文件或电子存储信息。下列程序适用于提交文件或电子存储信息：\n\n(A) 文件。回应要求提交文件之传票的人，必须按该等文件在正常业务过程中保存的方式提交，或必须将其整理并标记，以对应请求中的类别。\n\n(B) 未规定电子存储信息的提交形式。如传票未规定电子存储信息的提交形式，回应之人必须以其通常保存的一种或多种形式，或以一种或多种合理可用的形式提交。\n\n(C) 电子存储信息仅以一种形式提交。回应之人无须以一种以上形式提交相同的电子存储信息。\n\n(D) 无法访问的电子存储信息。回应之人无须就其认定因不当负担或费用而无法合理访问的来源中的电子存储信息提供证据开示。对于强制证据开示动议或保护令动议，回应之人必须证明该信息因不当负担或费用而无法合理访问。如作出该证明，法院在考虑 Rule 26(b)(2)(C) 的限制后，如请求方证明有正当理由，仍可命令从该等来源进行证据开示。法院可为该证据开示规定条件。\n\n(2) 主张特权或保护。\n\n(A) 扣留的信息。以该信息享有特权或作为审判准备材料而受保护为由扣留被传唤信息之人，必须：(i) 明确提出该主张；并且\n\n(ii) 以一种在不披露本身享有特权或受保护的信息的情况下，能够使当事人评估该主张的方式，描述被扣留文件、通信或有形物品的性质。\n\n(B) 已提交的信息。如为回应传票而提交的信息被主张享有特权或作为审判准备材料而受保护，提出该主张之人可将该主张及其依据通知收到该信息的任何当事人。收到通知后，当事人必须立即返还、隔离或销毁所指定的信息及其持有的任何副本；在该主张得到解决前不得使用或披露该信息；如该当事人在收到通知前已披露该信息，必须采取合理措施取回该信息；并可立即向要求履行的地区法院密封提交该信息，以裁定该主张。提交该信息之人必须保存该信息，直至该主张得到解决。\n\n(g) 藐视法庭。要求履行的地区法院——以及在动议被移送后，签发传票的法院——可认定已被送达但无充分理由不遵守传票或与之相关命令之人构成藐视法庭。\n\n如需获取传票材料，见 Fed.R.Civ.P.45(a) 委员会注释（2013）\n\n……\n\n文件提交请求\n\nI. 指示\n\n英文>>>\n\n1. 除非另有说明，下述文件请求（以下简称“请求”，每项称“一项请求”）必须分别并具体作答。每项请求均应得到完整答复，除非贵方本着诚信提出异议；在此情形下，贵方应按下文所述详细说明贵方异议的理由。如异议仅涉及一项请求的一部分，或其中所含的一个词、短语或条款，贵方须仅对该部分提出异议，并对其余请求作答。\n\n2. 电子存储信息必须依照下列说明提供：\na. 图像。黑白图像必须为 300 DPI Group IV 单页 TIFF 文件。彩色图像必须以 JPEG 格式提供。文件名不得包含嵌入空格或特殊字符（包括逗号）。文件夹名称不得包含嵌入空格或特殊字符（包括逗号）。所有 TIFF 图像文件必须具有唯一文件名，即 Bates 编号。每张图像的右下角必须标注连续的 Bates 编号。每个文件夹中的 TIFF 文件不得超过 1000 个。Excel 电子表格应具有以该文件的 Bates 编号命名的占位图像。\nb. 图像加载文件\na. Concordance® 数据文件。数据文件（.DAT）包含将加载至 Concordance® 数据库的所有字段信息。.DAT 文件的第一行必须为标明字段名称的标题行。.DAT 文件必须使用以下 Concordance® 默认分隔符：逗号 ASCII 字符（020）引号 þ ASCII 字符（254）。日期字段应采用以下格式提供：mm/dd/yyyy。日期和时间字段必须为两个单独字段。如文件包括已成像的电子邮件及附件，则必须包括附件字段，以保留电子邮件与其附件之间的父/子关系。必须包括 OCRPATH 字段，以提供所提取文本文件在所提供存储介质上的文件路径和名称。文本文件必须以 FIRSTBATES 命名。不得在 .DAT 文件中包括文本。对于含有原生文件的文件，必须包括 LINK 字段，以提供原生文件的文件路径和名称。原生文件必须以 FIRSTBATES 命名。\nb. Concordance Image® 或 Opticon 交叉引用文件。图像交叉引用文件（.LOG 或 .OPT）将图像链接至数据库记录。该文件应为逗号分隔文件，每行由七个字段组成，并且数据库中每张图像均应在交叉引用文件中具有一行，格式如下：ImageID,VolumeLabel,ImageFilePath,DocumentBreak,FolderBreak,BoxBreak,PageCount。\nc. 文件文本。文本必须作为单独的文本文件提供，而非作为 .DAT 文件中的字段提供。文本文件的完整路径（OCRPATH）应包含于 .DAT 文件中。建议提供按 FIRSTBATES/Image Key 命名的文件级 ANSI 文本文件。提取的文本文件必须置于单独文件夹中，每个文件夹中的文本文件不得超过 1,000 个。文件夹名称中不得有特殊字符（包括逗号）。文本文件必须按文件级别提供。\nd. 某些文件类型的原生格式提供。为完整理解其内容和含义而合理需要以原生格式查看的文件类型，必须以原生格式提供。这些包括但不限于电子表格、类电子表格文件（Microsoft Excel、逗号分隔值、制表符分隔值等）、Microsoft PowerPoint 或其他特殊演示文件、数据库文件以及音频/视频文件。应提供一张带有 Bates 编号的分隔页图像，注明存在原生文件，并在 .dat 文件中将原生文件的路径作为字段列入。所提供的原生文件应以与该文件分隔页相对应的 Bates 编号命名。原生文件应归入按递增方式命名的“NATIVE”目录，并与图像目录分开。\ne. 去重。对于存在完全重复件的每份电子文件，仅提供一份副本。对于电子邮件，根据由 BCC、Body、CC、From、IntMsgID、To 和 Attach 属性生成的 MD5 哈希值合并重复件。对于电子邮件附件和独立电子文件，根据整个文件的 MD5 哈希值合并重复件。\nf. 元数据。应以符合 Concordance 要求的加载文件（.dat）形式提供每份文件的提取元数据。.DAT 文件的第一行必须为标明字段名称的标题行。.DAT 文件必须使用以下 Concordance 默认分隔符：逗号 , ASCII 字符（020）引号 þ ASCII 字符（254）。日期字段应采用以下格式提供：mm/dd/yyyy。日期和时间字段必须为两个单独字段。下列为必需元数据：\nCase 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 224 of 1063\n字段名称　样本数据　说明\nFIRSTBATES　EDC0000001　原生文件文件/电子邮件的首个 Bates 编号\nLASTBATES　EDC0000001　原生文件文件/电子邮件的最后一个 Bates 编号\n单页文件亦应填写 LASTBATES 字段\nATTACHRANGE　EDC0000001 - EDC0000015　父文件第一页的 Bates 编号至最后一个附件“子”文件最后一页的 Bates 编号\nBEGATTACH　EDC0000001　附件范围的首个 Bates 编号\nENDATTACH　EDC0000015　附件范围的最后一个 Bates 编号\nCUSTODIAN　Smith, John（约翰·史密斯）　电子邮件：电子邮件所在的邮箱。原生文件：该文件来源的个人或部门名称\nFROM　John Smith　电子邮件：发件人。原生文件：文件作者\n多个条目之间应使用分号分隔\nTO　Coffman, Janice（贾尼斯·科夫曼）; LeeW（李W） [mailto:LeeW@MSN.com]　收件人\n多个条目之间应使用分号分隔\nCC　Frank Thompson（弗兰克·汤普森） [mailto:frank_Thompson@cdt.com]　抄送收件人\n多个条目之间应使用分号分隔\nBCC　John Cain（约翰·凯恩）　密送收件人\n多个条目之间应使用分号分隔\nSUBJECT　董事会会议纪要　电子邮件：电子邮件主题行。原生文件：文件标题（如有）\nFILE_NAME　BoardMeetingMinutes.docx　原生文件：原始原生文件的名称，包括扩展名\nDATE_SENT　10/12/2010　电子邮件：电子邮件发送日期。原生文件：（空）\nTIME_SENT/TIME_ZONE　07:05 PM GMT　电子邮件：电子邮件发送时间/电子邮件标准化所采用的时区\nTIME_ZONE　GMT　在转换过程中电子邮件被标准化所采用的时区。\nLINK　EDC0000001.msg　指向电子邮件或原生文件的超链接\n所链接文件必须按 FIRSTBATES 编号命名\nFILE_EXTEN　MSG　表示电子邮件或原生文件的文件类型扩展名\nAUTHOR　John Smith　电子邮件：（空）。原生文件：文件作者\nDATE_CREATED　10/10/2010　电子邮件：（空）。原生文件：文件创建日期\nCase 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 225 of 1063\nTIME_CREATED　10:25 AM　电子邮件：（空）。原生文件：文件创建时间\n该数据必须为单独字段，不得与 DATE_CREATED 字段合并\nDATE_MOD　10/12/2010　电子邮件：（空）。原生文件：文件最后修改日期\nTIME_MOD　07:00 PM　电子邮件：（空）。原生文件：文件最后修改时间\n该数据必须为单独字段，不得与 DATE_MOD 字段合并\nDATE_ACCESSD　10/12/2010　电子邮件：（空）。原生文件：文件最后访问日期\nTIME_ACCESSD　07:00 PM　电子邮件：（空）。原生文件：文件最后访问时间\n该数据必须为单独字段，不得与 DATE_ACCESSD 字段合并\nFILE_SIZE　5,952　原生文件文件/电子邮件的大小，以 KB 计\nPGCOUNT　1　原生文件文件/电子邮件中的页数\nPATH　电子邮件：（空）Agenda.doc　原生文件：原生文件文件的存储路径，包括原始文件名。\nINTFILEPATH　Personal Folders\\Deleted Items\\Board Meeting Minutes.msg　电子邮件：电子邮件的原始位置，包括原始文件名。原生文件：（空）\nINTMSGID　<000805c2c71b\\$75977050\\$cb8306d1@MSN>　电子邮件：唯一邮件 ID。原生文件：（空）\nMD5HASH　d131dd02c5e6eec4693d9a0698aff95c2fcab58712467eab4004583eb8fb7f89　文件的 MD5 哈希值。\nOCRPATH　TEXT/001/EDC0000001.txt　原生文件提取文本的路径\n\n3. 每项请求均独立适用并应独立解释，且除非另有说明，任何一项请求均不限制任何其他请求的范围。\n\n4. 所有文件均应按其在通常业务过程中保存的方式提供，或者应予整理和标注，以对应于本请求中的类别。\n\n5. 本文所载每项请求均延及所有文件：（a）由贵方占有、保管或控制的文件；或（b）由任何代表贵方行事之人占有、保管或控制的文件，\nCase 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 226 of 1063\n包括贵方的律师或其他代表和顾问。每份文件均应完整提供。\n\n6. 如要求贵方提供的文件已不再由贵方占有、保管或控制，则贵方的答复必须：（a）详细描述该文件的性质及其内容；（b）指明编制或起草该文件的人员（以及，如适用，文件被发送给的人员）；（c）指明该文件编制或创建的日期；（d）说明该文件是否（i）遗失或丢失，（ii）已被销毁，（iii）已自愿或非自愿转移给他人，或（iv）以其他方式被处置；（e）说明该等处置的原因及围绕该等处置的事实和情形；（f）指明授权该等处置的人员；（g）指明该等处置的日期或约略日期；（h）说明该文件最近一次由贵方占有、保管或控制的时间；以及（i）指明目前占有、保管或控制该文件的人员（如有）。\n\n7. 如要求贵方提供的文件已被销毁，则除前述指示所要求的信息外，贵方的答复还必须说明：（a）该文件被销毁的原因；（b）销毁该文件的人员身份；以及（c）指示销毁该文件的人员身份。\n\n8. 如贵方主张所要求的文件享有特权或属于律师工作成果，则贵方的答复必须：（a）说明（i）足以支持贵方关于该文件享有特权之主张的文件描述，（ii）文件标题，（iii）文件日期，（iv）文件作者，（v）文件收件人，（vi）收到或看过该文件原件、任何草稿、副本或复制件的每一人员身份，（vii）该文件本身或文件中所含或提及的任何信息是否由其他任何人员占有、保管或控制；如是，则指明该等人员身份，并说明该信息如何由其占有，（viii）据以扣留该文件的特权主张，以及（ix）贵方将据以支持该等特权主张的全部情形；以及（b）根据 D. Conn. L. Civ. R. 26(e)，就每份基于特权主张而被扣留的文件，制作一份特权日志，其中包含本指示第（a）部分所要求的全部信息。对于文件请求中未主张特权或工作成果的任何部分，应完整提供响应性文件。\nCase 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 227 of 1063\n\n9. 如一份本应提供的文件中的一部分含有受特权主张约束的信息，则仅应按照上述指示从该文件中删除或遮蔽受特权主张约束的该部分，其余部分应予提供。\n\n10. 本请求具有持续性。特此指示您：(a) 一旦得知先前答复不完整或不正确，应立即补充或更正任何后来发现不完整或不正确的答复；以及 (b) 提供根据下文所要求的任何额外文件。\n\n11. 如某文件使用英语以外的语言，您应提供该文件。如某文件使用英语以外的语言，且存在英文译本，您应同时提供两份文件。\n\n12. 对实体的所有提述均包括其所有关联方。\n\n13. 对个人姓名的所有提述均包括所有其他姓名、别名或昵称。\nCase 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 228 of 1063\n\n14. 除非另有明确说明，文件请求所涵盖的期间为自 February 5, 2012 起至文件请求答复到期之日止。\n\nII. 解释规则\n\n15. (a) 使用任何单数名词应解释为包括复数，反之亦然；以及 (b) 使用任何时态的动词应解释为使用该动词的所有其他时态。\n\n16. (a) “and”和“or”应根据需要作连词性或选择性解释，以将原本可能被解释为不在任何请求范围内的所有答复纳入其范围；以及 (b) “each”和“any”应视为包括并涵盖“every”和“all”。\nIII. 定义\n\n经 D. Conn. L. Civ. R. 26(c) 提供并由 D. Conn. Bankr. L.R. 2004-1(a) 纳入的定义，以及经 D. Conn. L. Civ. R. 26(d) 提供的解释规则，适用于文件请求。此外，本文件请求中所使用的下列术语具有如下含义：\n\n1. “您”或“您的”或“您本人”系指 Liberty Jet Management，以及其任何雇员、代理人、律师、顾问，或任何代表其行事的人。\n\n2. “债务人”系指 Ho Wan Kwok（郭文贵）（又名 Miles Kwok、Miles Guo、Guo Wengui、Guo Haoyun、郭文贵或任何其他别名），以及其雇员、代理人、律师、顾问，或任何代表其行事的人。\nCase 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 229 of 1063\n\n3. “债务人之子”系指 Qiang Guo（郭强）（又名 Mileson Kwok、郭强或任何其他别名），以及其雇员、代理人、律师、顾问，或任何代表其行事的人。\n\n4. “债务人之女”系指 Mei Guo（郭美）（又名 Mei Gui、郭美或任何其他别名），以及其雇员、代理人、律师、顾问，或任何代表其行事的人。\n\n5. “债务人所谓的妻子”系指 Hing Chi Ngok（岳庆芝）（又名 Hing Chi Ng、Yue Qingzhi、岳庆芝或任何其他别名），以及其雇员、代理人、律师、顾问，或任何代表其行事的人。\n\n6. “债务人家属”统称债务人、债务人之子、债务人之女及债务人所谓的妻子，以及与债务人具有任何其他家庭关系的人。\n\n7. “关联个人”单独及共同系指以下所有个人：(1) 持有、控制、保管债务人或债务人家属拥有、控制或享有的资产，或对该等资产具有处置权；或 (2) 曾担任一个或多个关联实体的雇员、董事，或以其他方式与其关联，以及前述任何人士各自的雇员、代理人、律师、顾问，或任何代表其行事的人。该等关联个人包括但不限于：Daniel Podhaskie、Jason Miller、Steve Bannon、Karin Maistrello、Melissa Francis、Anthony DiBattista、William Gertz、Arethusa Forsyth、Glenn Mellor、Jennifer Mercurio、Eduardo Eurnekian、Wencong Wang、Han Chunguang（又名 韩春光）、Qu Guojiao（又名 Qu Guo Jiao、屈国姣）、Guo Lijie（又名 郭丽杰）、Zhang Wei（又名 张伟*）、Lihong Wei Lafrenz（又名 Sara Wei、魏丽红）、Hao Haidong（又名 郝海东）、Ross Heinemeyer、Max Krasner、Kyle Bass、Melissa Mendez、Ya Li（又名 李娅）、Dinggang Wang（又名 王定刚）、An Hong（又名 安红）、Yvette Wang（又名 Yanping Wang、Yan Ping Wang、王雁平）、Fiona Yu、Je Kin Ming\nCase 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 230 of 1063\n\n（又名 William Je、Yu Jianming、余建明）、Yaz Qingua，以及 Lao Jiang（又名 Jiang Yunfu、Jiang Yunfu Be、姜云浮）。。\n\n8. “关联实体”单独及共同系指以下所有各种类型的组织或实体：(1) 曾由债务人或债务人家属拥有、控制或投资；或 (2) 对债务人或债务人家属拥有、控制或享有的任何资产直接或间接享有权益，以及前述任何实体各自的雇员、代理人、律师、顾问，或任何代表其行事的人。该等关联实体包括但不限于：7 Nod Hill LLC、AAGV Limited、ACA Investment Management Limited、ACA Capital Group Limited、Ace Decade Holdings Limited、AI Group Holdings Inc.、Alfa Global Ventures Limited、Alfonso Global Limited、Allied Capital Global Limited、Alpine Fiduciaries SA、Anton Development Limited、Assets Sino Limited、Auspicious Coast Limited、Beijing Pangu Investment Co.、Beijing Pangu Investment Co. Ltd.、Beijing Pangu Investment Inc.、Beijing Zenith Holdings Company Limited、Booming Sail New York LLC、Bravo Luck Limited、BSA Strategic Fund I、China Golden Spring (Hong Kong) Limited、Chuang Xin Limited、Crane Advisory Group LLC、Creative Apex Investments Limited、Crystal Breeze Investments Limited、Dawn State Limited、Eastern Profit Corporation Limited、Elite Well Global Limited、Empire Growth Holdings、Freedom Media Ventures Ltd.、G Club Operations LLC、G Fashion LLC、G News LLC、GETTR USA、Genever Holdings Corporation、Genever Holdings LLC、Gfashion Media Group Inc.、GFNY, Inc.、Globalist International Limited、GNews Media Group Inc.、Golden Spring (New York) Ltd.、Greenwich Land LLC、Guo Media、GTV Media Group, Inc.、Hamilton Capital Holdings Inc.、HCHK Property Management, Inc.、HCHK Technologies, Inc.、Head Win Group Limited、Henan Yuda、Himalaya Embassy、Himalaya Exchange、Himalaya Federal Reserve、Himalaya Investment LLC、Himalaya International、\nCase 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 231 of 1063\n\nHimalaya New World Inc.、Himalaya Supervisory Organization、Himalaya Ventures LLC、HK International Funds Investments (USA) Limited LLC、Hong Kong International Funds Investments Limited、Hudson Diamond Holding、Infinite Increase Limited、Infinitum Developments Limited、Infinity Treasury Management Inc.、Insight Phoenix Fund、Lamp Capital LLC、Leading Shine Limited、Leading Shine NY Limited、Lexington Property and Staffing、Long Gate Limited、Maywind Trading LLC、MOS Himalaya LLC、Next Tycoon Investments Limited、New Federal State of China（又名 NFSC）、Noble Fame Global Limited、Rosy Acme Ventures Limited、Rule of Law Foundation III, Inc.、Rule of Law Foundation IV, Inc.、Rule of Law Fund、Rule of Law Society、Rule of Law Society IV, Inc.、G-Translators PTY LTD、Saraca Media Group, Inc.、Shiny Ace Ltd.、Shiny Times Holdings Ltd.、Spirit Charter Investment Limited、Stevenson, Wong & Co.、Voice of Guo Media, Inc.、Well Origin Ltd.、World Century Limited、Worldwide Opportunity Holdings Limited、Whitecroft Shore Limited，以及 ZIBA Limited。\n\n9. “Including”或其任何变体意为“包括但不限于”。\n\n10. “And”和“or”意为“and/or”，并应同时作连词性及选择性解释，以最大限度扩大其范围。\n\n11. “Any”、“all”和“each”意为“每一及所有”。\n\n12. “Each”和“every”意为“每一及所有”。\n\n13. “第三方”系指您本人以外的个人或实体。\n\n14. “转让”具有《破产法》section 101(54) 赋予该术语的含义。\n\n15. “文件”系指属于 Fed. R. Civ. P. 34 范围内的任何信息或物品，并包括但不限于任何种类、\nCase 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 232 of 1063\n\n类型、性质或描述的、现由或曾由您占有、保管或控制的每一及所有书面、记录或图形材料，包括电子邮件的所有印刷及电子副本、以电子形式保存的计算机文件、信函、备忘录、磁带、速记或手写笔记、任何种类的书面表格、图表、蓝图、绘图、草图、曲线图、计划、文章、规格、日记、信件、电报、照片、会议记录、合同、协议、调查、计算机打印件、任何种类的数据汇编、电传、传真、电子邮件、短信、即时消息、语音留言、发票、订购单、支票、汇票、对账单、贷项通知单、报告、头寸报告、摘要、索引、书籍、账簿、笔记本、明细表、透明胶片、录音、目录、广告、宣传材料、影片、录像带、录音带、CD、计算机磁盘、宣传册、小册子、穿孔卡、工时单、推文、社交媒体帖子或任何其他种类的书面或记录材料，以及其所有元数据，无论以何种方式储存（无论为有形形式还是电子形式）、记录、制作或复制；还包括但不限于前述任何材料的草稿或副本，其中包含原始文件中未载有的任何种类的笔记、评论或标记，或在其他方面与原始文件不完全相同。\n\n16. “个人”系指自然人、公司、独资企业、合伙企业、协会或任何其他实体。“个人”还包括任何代理人、代表或专家，包括但不限于律师或财务顾问。\n\n17. “实体”系指任何自然人、公司、合伙企业、子公司、独资企业、商号、委员会、合资企业、协会、机构、主管机关、委员会或其他商业实体或法人，以及任何关联方、代理人、母公司，包括但不限于律师、财务顾问或任何其他代表。\nCase 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 233 of 1063\n\n18. “Regarding”意为关于、描述、包括、提及、与……有关、支持、赞成、反对、强化、削弱、位于、结合……考虑、对……有影响、证明、表明、报告、记录、暗示、答复、与……相联系、评论、就……而言、关于、与……有关、讨论、显示、描述、反映、分析、构成及为。\n\n19. 就任何特定事项而言，“Relating to”、“relate(s) to”或“related to”意为包括但不限于构成、包括、涉及、含有、体现、反映、识别、陈述、直接或间接提及，或以任何方式与所识别的特定事项相关的任何文件。\n\n20. “通信”在最广义且不受限制的意义上，系指任何信息或知识的传递（以事实、观点、询问或其他形式）。通信还指所有谈话、协议、询问或答复，无论是当面、通过电话、以书面方式，或通过电子传输设备进行，并包括但不限于所有信函、电子邮件、录音、传送单、备忘录、电话通信、语音留言、电报、电传传真、复印传真、电传、即时消息、聊天、短信、在留言板或群聊中发布的帖子、社交媒体帖子、推文、上传至任何视频平台的视频、电话笔记，或在内部或与第三方之间传送的笔记。\n\n21. “资产”系指受占有、保管或控制的任何具有经济价值的项目。资产包括所有不动产和动产，包括但不限于房地产、土地、房屋、公寓、共管公寓、汽车、游艇、船舶、飞机、喷气式飞机、直升机、现金、银行账户、加密货币、证券、应收账款、存货及其他有形和无形财产。\n案号 22-50073 文件 1592 提交日期 03/24/23 录入日期 03/24/23 10:57:37 第 234 页，共 1063 页\n\n22. “航空器”系指任何用于空中旅行的交通工具，包括但不限于由、向或为债务人、债务人家庭成员或任何关联实体拥有、使用、控制、购买、出售、租赁、出租、许可、服务、维护、修理、大修、存放、操作、营销或检查，或者曾在任何时候由、向或为其利益而进行上述活动的飞机和直升机；包括但不限于曾经以或关联于以下字母数字序列识别的任何航空器：T7-GQM、T7-17777、M-GYQM、SN9189 或 9189。\n\n23. “航空器工作人员”系指与航空器的维护、操作、服务、保养或存放有关的任何雇员、独立承包人、飞行员、副飞行员、机械师、空乘人员或个人。\n\n四、应提交的文件\n\n1. 与债务人、债务人财产、债务人家庭成员、关联实体或关联个人的任何收入或资产有关的所有文件。\n\n2. 与债务人、债务人财产、债务人家庭成员、关联实体或关联个人及任何航空器有关的所有文件，包括但不限于：(i) 任何航空器的所有权或控制权；(ii) 任何航空器的使用；(iii) 任何航空器的租赁或出租；(iv) 任何航空器的购买、出售或营销；(v) 与任何航空器有关的任何已支付或给予的金钱或价值及其来源；(vi) 与任何航空器有关的任何产生或取得的金钱或价值及其处置；或 (vii) 与任何航空器有关的操作、维护、服务或大修。\n\n3. 与债务人、债务人财产、债务人家庭成员、关联实体或关联个人有关联的任何账户有关的所有文件。\n案号 22-50073 文件 1592 提交日期 03/24/23 录入日期 03/24/23 10:57:37 第 235 页，共 1063 页\n\n4. 与债务人、债务人财产、债务人家庭成员、关联实体或关联个人有关的任何发票或费用付款有关的所有文件。\n\n5. 与债务人、债务人财产、债务人家庭成员、关联实体或关联个人已进行或计划进行的旅行有关的任何飞行日志、飞行计划或任何其他飞行信息记录有关的所有文件。\n\n6. 与航空器工作人员就债务人、债务人财产、债务人家庭成员、关联实体或关联个人所进行的任何活动有关的所有文件。\n\n7. 与航空器工作人员以及债务人、债务人财产、债务人家庭成员、关联实体或关联个人有关的任何付款、费用、转移或款项有关的所有文件。\n\n8. 与债务人、债务人财产、债务人家庭成员、关联实体或关联个人使用的任何航空器上可能搭乘的人员有关的所有文件，包括任何飞行清单。\n\n9. 与航空器上与债务人、债务人财产、债务人家庭成员、关联实体或关联个人有关的任何货物、存放物、待交付物品、资产或财产有关的所有文件。\n\n10. 与航空器所在地有关的所有文件。\n\n证物 C-12\n\nB2540（表格 2540－规则 2004 审查传票）（12/15）案号 22-50073 文件 1592 提交日期 03/24/23 录入日期 03/24/23 10:57:37 第 237 页，共\n\n美国破产法院\n\n康涅狄格区\n\n关于 HO WAN KWOK（郭文贵）等人案，\n\n1 案号 22-50073 (JAM)\n\n债务人 第 11 章\n\n（合并管理）\n规则 2004 审查传票\n\n致：Santander Bank, N. A.（桑坦德银行，全国协会）\n\n（传票送达对象的姓名）\n\n证言：特此命令您于下列规定的时间、日期和地点出席，并根据《联邦破产程序规则》第 2004 条接受审查并作证。随附准许该审查的法院命令副本。\n\n地点　日期和时间\n\nNeubert, Pepe & Monteith, P.C.（纽伯特、佩佩与蒙泰思专业公司）\n195 Church Street, Floor 13　[TBD]\nNew Haven, Connecticut 06510（康涅狄格州纽黑文市 06510）\n\n审查将通过以下方式记录：法庭记录员／速记员\n\n提交：您或您的代表还必须在审查时携带下列文件、电子存储信息或物品，并必须允许对该等材料进行检查、复制、测试或抽样：\n见随附的《文件提交请求》。\n\n下列《联邦民事诉讼规则》第 45 条的规定，依据《联邦破产程序规则》第 9016 条适用于破产案件，现随附于此——有关履行地点的第 45(c) 条；有关作为传票对象之人的保护的第 45(d) 条；以及有关您对本传票作出回应的义务及未作出回应的潜在后果的第 45(e) 条和第 45(g) 条。\n\n日期：March , 2023\n\n法院书记员\n\n或\n\n书记员或副书记员签名　律师签名\n\n签发或请求本传票的代表第 11 章受托人 Luc A. Despins（吕克·A·德斯平斯）的律师姓名、地址、电子邮件地址和电话号码如下：\n\nDouglas S. Skalka, Esq.（道格拉斯·S·斯卡尔卡律师）；Neubert, Pepe & Monteith, P.C.（纽伯特、佩佩与蒙泰思专业公司）；195 Church Street, New Haven, Connecticut 06510（康涅狄格州纽黑文市 06510）dskalka@npmlaw.com；(203) 821-2000\n\n致签发或请求本传票之人的通知\n\n如本传票命令在审判前提交文件、电子存储信息或有形物品，或检查场所，则必须在向传票所指向之人送达前，向每一当事人送达通知及本传票副本。《联邦民事诉讼规则》第 45(a)(4) 条。\n\n软件版权 (c) 1996-2022 Best Case, LLC（最佳案件有限责任公司）- www.bestcase.com Best Case Bankruptcy（最佳案件破产）1 本第 11 章案件中的债务人为 Ho Wan Kwok（郭文贵）（亦称 Guo Wengui、Miles Guo 和 Miles Kwok，以及众多其他别名）（税务识别号后四位：9595）、Genever Holdings LLC（税务识别号后四位：8202）及 Genever Holdings Corporation。受托人、Genever Holdings LLC 和 Genever Holdings Corporation 的邮寄地址为 Paul Hastings LLP（普衡律师事务所），200 Park Avenue, New York, NY 10166，转交 Luc A. Despins，作为 Ho Wan Kwok 财产的受托人（仅为通知和通信之目的）。\n\n送达证明\n\n（除非《联邦民事诉讼规则》第 45 条要求，否则本节不应向法院提交。）\n\n本人于（日期）收到向（个人姓名及职务，如有）发出的本传票。\n\n本人通过以下方式向所列明之人交付副本，送达本传票：\n\n于（日期）；或\n\n本人未予执行而退回本传票，原因是：\n\n除非本传票代表美国或其官员或代理人签发，本人亦已向证人支付出席一日的费用及法律准许的里程费，金额为 \\$ 。\n\n本人的旅费为 \\$，服务费为 \\$，合计为 \\$。\n\n本人依伪证罪处罚之规定声明，该等信息真实且正确。\n\n日期：\n\n送达人签名\n\n正楷姓名及职务\n\n送达人地址\n\n有关尝试送达等事项的补充信息：\n\n《联邦民事诉讼规则》第 45(c)、(d)、(e) 和 (g) 条（Effective 12/1/13）（依据《联邦破产程序规则》第 9016 条适用于破产案件）\n\n(c) 履行地点。\n\n(1) 审判、听证或证言录取。传票仅可按下列方式命令某人出席审判、听证或证言录取：\n\n(A) 在该人居住、受雇或经常亲自从事营业之地 100 英里范围内；或\n\n(B) 在该人居住、受雇或经常亲自从事营业所在州内，前提是该人\n\n(i) 为当事人或当事人的高级职员；或\n\n(ii) 被命令出席审判且不会产生重大费用。\n\n(2) 其他取证。传票可以命令：\n\n(A) 在该人居住、受雇或经常亲自从事营业之地 100 英里范围内的地点提交文件、电子存储信息或物品；及\n\n(B) 在被检查场所进行场所检查。\n\n(d) 对传票对象的保护；执行。\n\n(1) 避免不当负担或费用；制裁。负责签发和送达传票的当事人或律师必须采取合理措施，以避免对传票对象施加不当负担或费用。要求履行的地区法院必须执行该义务，并对未遵守者的当事人或律师施加适当制裁，其中可包括损失的收入和合理的律师费。\n\n(2) 命令提交材料或准许检查。\n\n(A) 无须出席。被命令提交文件、电子存储信息或有形物品，或准许检查场所的人，无须亲自到提交或检查地点出席，除非同时被命令出席证言录取、听证或审判。\n\n(B) 异议。被命令提交文件或有形物品，或准许检查的人，可以向传票中指定的当事人或律师送达书面异议，反对检查、复制、测试或抽样任何或全部材料，或反对检查场所，或反对以所要求的一种或多种形式提交电子存储信息。异议必须在指定的履行时间届满前或传票送达后 14 日内（以较早者为准）送达。如提出异议，适用下列规则：\n\n(i) 送达传票的当事人可在任何时候，在通知被命令之人后，向要求履行的地区法院提出动议，请求作出强制提交或检查的命令。\n\n(ii) 仅可按照命令所指示的方式要求实施该等行为，该命令必须保护既非当事人亦非当事人高级职员的人免受因履行而产生的重大费用。\n\n(3) 撤销或修改传票。\n\n(A) 必须撤销或修改的情形。应及时提出的动议，要求履行的地区法院必须撤销或修改具有下列情形的传票：\n\n(i) 未给予合理的履行时间；\n\n(ii) 要求某人在第 45(c) 条规定的地理范围以外履行；\n\n(iii) 要求披露享有特权或受其他保护的事项，且不存在适用的例外或放弃；或\n\n(iv) 对某人施加不当负担。\n\n(B) 可以撤销或修改的情形。为保护受传票约束或受其影响的人，要求履行的地区法院可依动议撤销或修改要求下列事项的传票：\n\n(i) 披露商业秘密或其他机密研究、开发或商业信息；或\n\n(ii) 披露未受聘专家的意见或信息，该等意见或信息并非描述争议中的具体事件，且系该专家未经任何当事人请求而进行研究所得。\n\n(C) 以规定条件作为替代。在第 45(d)(3)(B) 条所述情形下，如送达传票的当事人：\n\n(i) 证明对该证言或材料具有重大需要，且若不承受不当困难则无法通过其他方式满足该需要；及\n\n(ii) 确保被传唤之人将获得合理补偿，\n\n法院可以不撤销或修改传票，而命令在规定条件下出席或提交。\n\n(e) 回应传票的义务。\n\n(1) 提交文件或电子存储信息。下列程序适用于提交文件或电子存储信息：\n\n(A) 文件。回应要求提交文件的传票之人，必须按照文件在日常业务过程中保存的方式提交，或者必须将其整理并标注，以对应请求中的类别。\n\n(B) 未指定的电子存储信息提供形式。如传票未指定电子存储信息的提供形式，答复人必须以其通常保存的一种或多种形式，或以一种或多种合理可用的形式提供该信息。\n\n(C) 仅以一种形式提供的电子存储信息。答复人无须以一种以上的形式提供相同的电子存储信息。\n\n(D) 无法合理获取的电子存储信息。答复人无须对其认定因不当负担或费用而无法合理获取的来源中的电子存储信息进行证据开示。就强制证据开示动议或保护令动议而言，答复人必须证明该信息因不当负担或费用而无法合理获取。如作出该证明，法院在考虑第 26(b)(2)(C) 条限制的情况下，如请求方证明存在正当理由，仍可命令从该等来源进行证据开示。法院可规定该证据开示的条件。\n\n(2) 主张特权或保护。\n\n(A) 扣留的信息。依据该信息享有特权或作为审判准备材料受保护的主张而扣留被传唤信息的人必须：(i) 明确提出该主张；并且\n\n(ii) 以一种在不披露本身享有特权或受保护的信息的情况下，能够使各方评估该主张的方式，说明被扣留文件、通信或有形物品的性质。\n\n(B) 已提供的信息。如为响应传票而提供的信息受到特权主张或作为审判准备材料受保护的主张约束，提出该主张的人可将该主张及其依据通知任何收到该信息的一方。收到通知后，一方必须立即返还、隔离或销毁所指定的信息及其持有的任何副本；在该主张得到解决前，不得使用或披露该信息；如该方在收到通知前已披露该信息，必须采取合理措施追回该信息；并且可立即将该信息密封提交给要求履行义务所在地区的法院，以裁定该主张。提供该信息的人必须在该主张得到解决前保存该信息。\n\n(g) 藐视法庭。要求履行义务所在地区的法院，以及在动议移送后签发传票的法院，均可对已被送达但无充分理由不遵守传票或相关命令的人作出藐视法庭认定。\n\n关于获取传票材料，见 Fed.R.Civ.P.45(a) 委员会注释（2013）\n\n……\n\n文件提供请求\nI. 指示\n\n1. 除非另有说明，下列文件请求（统称“请求”，单称“某项请求”）必须分别且具体地作出答复。除非善意提出异议，否则必须完整答复每项请求；如提出异议，必须按下文规定详细说明异议理由。如异议仅涉及某项请求的一部分，或其中包含的某一词语、短语或条款，您仅须说明对该部分的异议，并答复其余请求。\n\n2. 电子存储信息必须依照以下指示提供：\n\na. 图像。黑白图像必须为 300 DPI Group IV 单页 TIFF 文件。彩色图像必须以 JPEG 格式提供。文件名不得包含嵌入空格或特殊字符（包括逗号）。文件夹名称不得包含嵌入空格或特殊字符（包括逗号）。所有 TIFF 图像文件必须具有唯一文件名，即 Bates 编号。每幅图像右下角必须加注连续的 Bates 编号。每个文件夹中的 TIFF 文件数量不得超过 1000 个。Excel 电子表格应附有以该文件 Bates 编号命名的占位图像。\n\nb. 图像加载文件\n\na. Concordance® 数据文件。数据文件（.DAT）包含将加载至 Concordance® 数据库的所有字段信息。.DAT 文件的第一行必须为标明字段名称的标题行。.DAT 文件必须使用以下 Concordance® 默认分隔符：逗号 ASCII 字符（020）引号 þ ASCII 字符（254）。日期字段应按如下格式提供：mm/dd/yyyy。日期和时间字段必须为两个独立字段。如文件包括已成像的电子邮件及附件，则必须包括附件字段，以保留电子邮件与其附件之间的父/子关系。必须包括 OCRPATH 字段，以提供所提供存储介质上提取文本文件的文件路径和名称。文本文件必须以 FIRSTBATES 命名。不得在 .DAT 文件中包括文本。对于含有原生文件的文件，必须包括 LINK 字段，以提供原生文件的文件路径和名称。原生文件必须以 FIRSTBATES 命名。\n\nb. Concordance Image® 或 Opticon 交叉引用文件。图像交叉引用文件（.LOG 或 .OPT）将图像链接至数据库记录。其应为以逗号分隔的文件，每行包含七个字段，数据库中每幅图像均应在交叉引用文件中有一行，格式如下：ImageID,VolumeLabel,ImageFilePath,DocumentBreak,FolderBreak,BoxBreak,PageCount。\n\nc. 文件文本。文本必须作为独立文本文件提供，而非作为 .DAT 文件内的字段提供。文本文件的完整路径（OCRPATH）应包括在 .DAT 文件中。建议提供以 FIRSTBATES/Image Key 命名的文件级 ANSI 文本文件。提取的文本文件必须置于单独文件夹中，每个文件夹内的文本文件数量不得超过 1,000 个。文件夹名称中不得有特殊字符（包括逗号）。文本文件必须按文件级别提供。\n\nd. 特定文件类型的原生格式提供。为充分理解其内容和含义而合理需要以原生格式查看的文件类型，必须以原生格式提供。此类文件包括但不限于电子表格、类电子表格文件（Microsoft Excel（微软 Excel）、逗号分隔值、制表符分隔值等）、Microsoft PowerPoint（微软 PowerPoint）或其他特殊演示文件、数据库文件及音频/视频文件。应提供一幅带有 Bates 编号的分隔页图像，表明存在原生文件，并将原生文件的路径作为字段包括在 .dat 文件中。所提供的原生文件须以与该文件分隔页相对应的 Bates 编号命名。原生文件应归入按递增方式命名的“NATIVE”目录，并与图像目录分开。\n\ne. 去重。对于存在完全重复件的每份电子文件，仅提供一份副本。对于电子邮件，根据由 BCC、Body、CC、From、IntMsgID、To 和 Attach 属性生成的 MD5 哈希值合并重复件。对于电子邮件附件和独立电子文件，根据整个文件的 MD5 哈希值合并重复件。\n\nf. 元数据。以符合 Concordance 要求的加载文件（.dat）形式，为每份文件提供提取的元数据。.DAT 文件的第一行必须为标明字段名称的标题行。.DAT 文件必须使用以下 Concordance 默认分隔符：逗号 , ASCII 字符（020）引号 þ ASCII 字符（254）\n\n日期字段应按如下格式提供：mm/dd/yyyy。日期和时间字段必须为两个独立字段。所需元数据如下：\nCase 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 242 of 1063\n\n字段名称　示例数据　说明\n\nFIRSTBATES　EDC0000001　原生文件文件/电子邮件的首个 Bates 编号\nLASTBATES　EDC0000001　原生文件文件/电子邮件的最后一个 Bates 编号\n**LASTBATES 字段应就单页文件填写\nATTACHRANGE　EDC0000001\n-　父文件首页的 Bates 编号至最后一个附件“子”文件最后一页的 Bates 编号\nEDC0000015\nBEGATTACH　EDC0000001　附件范围的首个 Bates 编号\nENDATTACH　EDC0000015　附件范围的最后一个 Bates 编号\nCUSTODIAN　Smith, John　电子邮件：电子邮件所在的邮箱\n原生文件：文件来源个人或部门的名称\nFROM　John Smith　电子邮件：发件人\n原生文件：文件作者\n**多个条目之间应使用分号分隔\nTO　Coffman, Janice; LeeW　收件人\n[mailto:LeeW@MSN.com]　**多个条目之间应使用分号分隔\nCC　Frank Thompson [mailto:　抄送收件人\nfrank_Thompson@cdt.com]　**多个条目之间应使用分号分隔\nBCC　John Cain　密送收件人\n**多个条目之间应使用分号分隔\nSUBJECT　Board Meeting Minutes　电子邮件：电子邮件主题行 原生文件：文件标题（如有）\nFILE_NAME　BoardMeetingMinutes.docx　原生文件：原始原生文件名称，包括扩展名\nDATE_SENT　10/12/2010　电子邮件：电子邮件发送日期\n原生文件：（空）\nTIME_SENT/\nTIME_ZONE　07:05 PM GMT　电子邮件：电子邮件发送时间/电子邮件被标准化时所在的时区\nTIME_ZONE　GMT　在转换过程中电子邮件被标准化时所在的时区。\nLINK　EDC0000001.msg　指向电子邮件或原生文件文件的超链接\n**所链接文件必须按 FIRSTBATES 编号命名\nFILE_EXTEN　MSG　代表电子邮件或原生文件的文件类型扩展名\nAUTHOR　John Smith　电子邮件：（空）\n原生文件：文件作者\nDATE_CREATED　10/10/2010　电子邮件：（空）\n原生文件：文件创建日期\nCase 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 243 of 1063\n\nTIME_CREATED　10:25 AM　电子邮件：（空）\n原生文件：文件创建时间\n**该数据必须为单独字段，不得与 DATE_CREATED 字段合并\nDATE_MOD　10/12/2010　电子邮件：（空）\n原生文件：文件最后修改日期\nTIME_MOD　07:00 PM　电子邮件：（空）\n原生文件：文件最后修改时间\n**该数据必须为单独字段，不得与 DATE_MOD 字段合并\nDATE_ACCESSD　10/12/2010　电子邮件：（空）\n原生文件：文件最后访问日期\nTIME_ACCESSD　07:00 PM　电子邮件：（空）\n原生文件：文件最后访问时间\n**该数据必须为单独字段，不得与 DATE_ACCESSD 字段合并\nFILE_SIZE　5,952　原生文件文件/电子邮件的大小，以 KB 计\nPGCOUNT　1　原生文件文件/电子邮件的页数\nPATH　电子邮件：（空）\nAgenda.doc　原生文件：储存原生文件文件的路径，包括原始文件名称。\nINTFILEPATH　Personal Folders\\Deleted　电子邮件：电子邮件的原始位置，包括原始文件名称。\nItems\\Board Meeting\nMinutes.msg　原生文件：（空）\nINTMSGID　<000805c2c71b\\$75977050\\$　电子邮件：唯一消息 ID 原生文件：（空）\ncb8306d1@MSN>\nMD5HASH　d131dd02c5e6eec4693d9a0　文件的 MD5 哈希值。\n698aff95c\n2fcab58712467eab4004583e\nb8fb7f89\nOCRPATH　TEXT/001/EDC0000001.txt　原生文件提取文本的路径\n\n3. 每项请求均独立适用并应独立解释，且除非另有说明，任何请求均不限制任何其他请求的范围。\n\n4. 所有文件均应按其在通常业务过程中保存的方式提供，或应予以整理和标记，以对应本请求中的类别。\n\n5. 本文所载每项请求均延及所有文件：(a) 由您占有、保管或控制的；或 (b) 由任何代表您行事的人占有、保管或控制的，\nCase 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 244 of 1063\n\n包括您的律师或其他代表及顾问。每份文件均应完整提供。\n\n6. 如要求贵方提交已不再由贵方占有、保管或控制的文件，则贵方的答复必须：(a) 详细说明该文件的性质及其内容；(b) 确定编制或撰写该文件的人员（以及，如适用，文件被发送至的人员）；(c) 确定该文件编制或创建的日期；(d) 说明该文件是否：(i) 遗失或丢失，(ii) 已被销毁，(iii) 已自愿或非自愿地转移给他人，或(iv) 以其他方式处置；(e) 说明该等处置的理由以及有关事实和情形；(f) 确定授权该等处置的人员；(g) 确定该等处置的日期或大致日期；(h) 说明该文件最近一次由贵方占有、保管或控制的时间；以及(i) 确定目前占有、保管或控制该文件的人员（如有）。\n\n7. 如要求贵方提交已被销毁的文件，则除前述指示所要求的信息外，贵方的答复还必须说明：(a) 该文件被销毁的理由；(b) 销毁该文件的人员身份；以及(c) 指示销毁该文件的人员身份。\n\n8. 如贵方主张所要求的文件享有特权或属于律师工作成果，则贵方的答复必须：(a) 说明：(i) 足以支持贵方关于该文件享有特权之主张的文件描述，(ii) 文件标题，(iii) 文件日期，(iv) 文件作者，(v) 文件收件人，(vi) 收到或阅览该文件原件或任何草稿、副本或复制件的每一人员身份，(vii) 该文件本身或其中载有或提及的任何信息是否由任何其他人员占有、保管或控制，如是，则确定该等人员的身份；\n\n案号 22-50073，文书 1592，提交于 03/24/23，录入于 03/24/23 10:57:37，第 245 页，共 1063 页\n\n该等人员，以及说明该信息如何进入其占有范围，(viii) 据以拒绝提交该文件的特权主张，及(ix) 贵方将据以支持该特权主张的所有情形；以及(b) 就每一份基于特权主张而被拒绝提交的文件，依照 D. Conn. L. Civ. R. 26(e)，提交一份特权清单，其中载明本指示第(a)部分所要求的全部信息。对于文件请求中未就其提出特权或工作成果主张的任何部分，应完整提供相应文件。\n\n9. 如一份原本应提交的文件的一部分载有受特权主张约束的信息，则仅应依照上述指示从该文件中删除或遮盖受特权主张约束的部分，其余部分应予提交。\n\n10. 该等请求具有持续性。现指示贵方：(a) 一旦得知先前答复不完整或不正确，应立即补充或更正其后得知不完整或不正确的任何答复；以及(b) 提交根据下列规定所要求的任何补充文件。\n\n11. 如文件使用英语以外的语言，贵方应提供该文件。如文件使用英语以外的语言，且存在英文译本，贵方应同时提供两份文件。\n\n12. 对实体的所有提述均包括其所有关联方。\n\n13. 对个人姓名的所有提述均包括所有别名、化名或昵称。\n\n案号 22-50073，文书 1592，提交于 03/24/23，录入于 03/24/23 10:57:37，第 246 页，共 1063 页\n\n14. 除非另有明确说明，文件请求所涵盖的期间为自 February 5, 2012 起至文件请求答复到期之日止。\n\nII. 解释规则\n\n15. (a) 任何单数名词的使用均应解释为包括复数，反之亦然；以及(b) 任何时态的动词均应解释为使用该动词的所有其他时态。\n\n16. (a) “and”和“or”应视必要作连词或选择连词解释，以将所有本可能被解释为超出任何请求范围的答复纳入该请求范围内；以及(b) “each”和“any”应视为包括并涵盖“every”和“all”二词。\n\nIII. 定义\n\n经 D. Conn. Bankr. L.R. 2004-1(a) 纳入的 D. Conn. L. Civ. R. 26(c) 所规定的定义，以及 D. Conn. L. Civ. R. 26(d) 所规定的解释规则，适用于文件请求。此外，本文件请求中使用的下列术语具有下列含义：\n\n1. “You”、“Your”或“Yourself”系指 Santander Bank, N. A.（桑坦德银行，全国协会）及其所有关联方。\n\n2. “Debtor”系指 Ho Wan Kwok（郭文贵）（又名 Miles Kwok、Miles Guo、Guo Wengui、Guo Haoyun、郭文贵或任何其他别名），以及其雇员、代理人、律师、顾问或任何代表其行事之人。\n\n案号 22-50073，文书 1592，提交于 03/24/23，录入于 03/24/23 10:57:37，第 247 页，共 1063 页\n\n3. “Debtor's Son”系指 Qiang Guo（郭强）（又名 Mileson Kwok、郭强或任何其他别名），以及其雇员、代理人、律师、顾问或任何代表其行事之人。\n\n4. “Debtor's Daughter”系指 Mei Guo（郭美）（又名 Mei Gui、郭美或任何其他别名），以及其雇员、代理人、律师、顾问或任何代表其行事之人。\n\n5. “Debtor's Purported Wife”系指 Hing Chi Ngok（岳庆芝）（又名 Hing Chi Ng、Yue Qingzhi、岳庆芝或任何其他别名），以及其雇员、代理人、律师、顾问或任何代表其行事之人。\n\n6. “Debtor's Family”单独及合称系指债务人、债务人之子、债务人之女及债务人所谓的妻子，以及与债务人具有任何其他亲属关系之人。\n\n7. “2004 Discovery Targets”单独及合称系指债务人、债务人家属、ACA Capital Group Limited（ACA资本集团有限公司）、Himalaya International Financial Group Ltd.（喜马拉雅国际金融集团有限公司）、Himalaya International Clearing Ltd.（喜马拉雅国际清算有限公司）、Himalaya International Payments Ltd.（喜马拉雅国际支付有限公司）、Himalaya International Reserves Ltd.（喜马拉雅国际储备有限公司）、Jesse Brown（杰西·布朗）、William Je（威廉·杰）、William Je、Eastern Profit Corporation Limited（东方利润有限公司）、HK International Funds Investments (USA) Limited LLC（香港国际基金投资（美国）有限责任公司）、Bravo Luck Limited（好运有限公司）、Golden Spring (New York) Ltd.（金泉（纽约）有限公司）、Lamp Capital LLC（兰普资本有限责任公司）、Greenwich Land LLC（格林尼治土地有限责任公司）、Qu Guo Jiao（郭娇）、Daniel Thomas Podhaskie（丹尼尔·托马斯·波达斯基）、Yvette Wang（王艳萍）（又名 Yanping Wang、又名 Yan Ping Wang）、Ace Decade Holdings Limited（艾斯十年控股有限公司）、Dawn State Limited（黎明州有限公司）、Rule of Law Society IV Inc.（法治协会IV公司）、Rule of Law Foundation III, Inc.（法治基金会III公司）、Rule of Law Foundation IV, Inc.（法治基金会IV公司）、Rule of Law Fund（法治基金）、Rule of Law Society（法治协会）、GTV Media Group, Inc.（GTV媒体集团公司）、Voice of Guo Media, Inc.（郭媒体之声公司）、Saraca Media Group Inc.（萨拉卡媒体集团公司）、Genever Holdings Corporation（热内韦控股公司）、Genever Holdings LLC（热内韦控股有限责任公司）、Gnews Media Group Inc.（Gnews媒体集团公司）、G Fashion LLC（G时尚有限责任公司）、Gmusic LLC（G音乐有限责任公司）、Gnews LLC（Gnews有限责任公司）、Geducation（G教育）、GFNY, Inc.（GFNY公司）、G-Club Investments Limited（G-Club投资有限公司）、G Club Operations LLC（G Club运营有限责任公司）、G Club US Operations Inc.（G Club美国运营公司）、G Club US Operations LLC（G Club美国运营有限责任公司）、G Live, LLC（G直播有限责任公司）、Gbroadcast, LLC（G广播有限责任公司）、Gposts LLC（G帖文有限责任公司）、HCHK Property\n\n案号 22-50073，文书 1592，提交于 03/24/23，录入于 03/24/23 10:57:37，第 248 页，共 1063 页\n\nManagement, Inc.（HCHK物业管理公司）、HCHK Technologies, Inc.（HCHK技术公司）、FMV Ltd./Freedom Media Venture Ltd.（FMV有限公司／自由媒体创业有限公司）、Roscalitar 2（罗斯卡利塔尔2）、Himalaya New World Inc.（喜马拉雅新世界公司）、US Himalaya Capital Inc.（美国喜马拉雅资本公司）、Hudson Diamond Holding, Inc.（哈德逊钻石控股公司）、Hudson Diamond Holding LLC（哈德逊钻石控股有限责任公司）、Hudson Diamond NY LLC（哈德逊钻石纽约有限责任公司）、Infinity Treasury Management Inc.（无限资金管理公司）、Lexington Property and Staffing, Inc.（列克星敦物业及人力服务公司）、AI Group Holdings Inc.（AI集团控股公司）、Hamilton Capital Holdings Inc.（汉密尔顿资本控股公司）、Booming Sail New York LLC（兴旺帆船纽约有限责任公司）、Himalaya Ventures LLC（喜马拉雅创业有限责任公司）、Himalaya Ventures LLC、Himalaya Investment LLC（喜马拉雅投资有限责任公司）、New York MOS Himalaya LLC（纽约MOS喜马拉雅有限责任公司）、MOS Himalaya LLC（MOS喜马拉雅有限责任公司）、Crane Advisory Group（克兰咨询集团）、Maywind Trading LLC（五月风贸易有限责任公司）、Gettr USA, Inc.（Gettr美国公司）、Han Chunguang（韩春光）、Bingshang Jiao（焦冰上）、Karin Maistrello（卡琳·迈斯特雷洛）、Mary Jiang（江玛丽）、Jiaming Liu（刘佳明）及 Wencong Wang（王文聪）。\n\n8. “Including”或其任何变体意为“包括但不限于”。\n\n9. “And”和“or”意为“and/or”，并应同时作连词及选择连词解释，以最大限度扩大其范围。\n\n10. “Any”、“all”和“each”意为“每一及所有”。\n\n11. “Each”和“every”意为“每一及所有”。\n\n12. “Third Party”系指贵方以外的个人或实体。\n\n13. “Transfer”具有《破产法典》第 101(54) 条赋予其的含义。\n\n14. “Document”系指 Fed. R. Civ. P. 34 范围内的任何信息或物件，并包括但不限于现由或曾由贵方占有、保管或控制的任何种类、类型、性质或描述的每一书面、记录或图形材料，包括电子邮件的所有打印件和电子副本、以电子形式保存的计算机文件、通信函件、备忘录、磁带、速记或手写笔记、任何种类的书面表格、图表、蓝图、绘图、草图、曲线图、计划、文章、规格说明、日记、信件、\n\n案号 22-50073，文书 1592，提交于 03/24/23，录入于 03/24/23 10:57:37，第 249 页，共 1063 页\n\n电报、照片、会议记录、合同、协议、调查资料、计算机打印件、任何种类的数据汇编、电传、传真、电子邮件、短信、即时消息、语音消息、发票、订购单、支票、汇票、对账单、贷项通知单、报告、头寸报告、摘要、索引、账簿、分类账、笔记本、日程表、透明胶片、录音、目录、广告、宣传材料、电影、录像带、录音带、CD、计算机磁盘、宣传册、小册子、穿孔卡、工时单、推文、社交媒体帖子或任何其他种类的书面或记录材料，以及其所有元数据，无论以何种方式存储（无论以有形或电子形式）、记录、制作或复制，亦包括但不限于前述任何材料的草稿或副本，该等草稿或副本载有原始文件中未见的任何种类笔记、评论或标记，或在其他方面与原始文件不相同。\n\n15. “Person(s)”系指个人、公司、独资企业、合伙企业、协会或任何其他实体。“Person”还包括任何代理人、代表或专家，包括但不限于律师或财务顾问。\n\n16. “Entity”系指任何自然人、公司、合伙企业、子公司、独资企业、商号、董事会、合资企业、协会、机构、主管机关、委员会或其他商业实体或法人，以及任何关联方、代理人、母公司，包括但不限于律师、财务顾问或任何其他代表。\n\n17. “Regarding”系指关于、描述、构成、提及、与之相关、支持、赞成、反对、加强、削弱、位于其中、结合其予以考虑、对其具有影响、证明、表明、报告、记录、暗指、答复、与之相连、评论、就其而言、有关、与之相关、讨论、展示、描述、反映、分析、构成及属于。\n\n案号 22-50073，文书 1592，提交于 03/24/23，录入于 03/24/23 10:57:37，第 250 页，共 1063 页\n\n18. 就任何特定主题事项而言，“Relating to”、“relate(s) to”或“related to”系指包括但不限于构成、包含、涉及、含有、体现、反映、确定、直接或间接提及或以任何方式与所确定的特定主题事项相关的任何文件。\n\n19．“通信”系指，在最广义且不受任何限制的意义上，任何信息或知识的传递（以事实、观点、询问或其他形式）。通信还指所有谈话、协议、询问或答复，无论是当面、通过电话、以书面形式，还是通过电子传输设备进行，并包括但不限于所有函件、电子邮件、录音、传送单、备忘录、电话通信、语音留言、电报、传真、电传副本、电传、即时消息、聊天、短信、在留言板或群聊中的发布、社交媒体帖子、推文、上传至任何视频平台的视频、电话记录，或在内部或与第三方之间传送的记录。\n\n20．“资产”系指受占有、保管或控制的任何具有经济价值的项目。资产包括所有不动产和动产，包括但不限于房地产、土地、房屋、公寓、共管公寓、汽车、游艇、船只、飞机、喷气式飞机、直升机、现金、银行账户、加密货币、证券、应收账款、存货及其他有形和无形财产。\n\nIV. 应提交的文件\n\n1．与由任何2004年调查对象持有、控制、代表其持有或以其他方式与其相关的任何账户有关的所有文件，包括任何及所有账户对账单、授权书、委托书、信托、指示或表格、已注销支票副本、函件，以及电汇和相关函件及指示。\n\n案件 22-50073 文件 1592 提交于 03/24/23 录入于 03/24/23 10:57:37 第 251 页，共 1063 页\n\n2．与属于任何2004年调查对象、由其持有、控制、代表其持有或以其他方式与其相关的任何资金、证券、财产或资产有关的所有文件，包括任何及所有账户对账单、授权书、委托书、信托、指示或表格、已注销支票副本、函件，以及电汇和相关函件及指示。\n\n3．与同任何2004年调查对象进行的任何商业、贸易或金融交易有关的所有文件，包括但不限于任何贷款、信贷额度、寄托、存款、掉期、证券交易、抵押贷款或ISDA，以及任何及所有账户对账单、授权书、委托书、信托、指示或表格、已注销支票副本、函件，以及电汇和相关函件及指示。\n\n4．与2004年调查对象有关的任何电汇活动有关的所有文件，无论是否存在任何账户，包括但不限于所有电汇收据、账号、余额、授权、与转账各方有关的身份识别信息、函件、指示或其他记录。\n\n5．与贵方和2004年调查对象之间的任何函件和通信有关的所有文件。\n\n6．与任何2004年调查对象的任何账户有关的所有文件，包括与开立账户、账户获授权使用人及账户维护有关的文件。\n\n7．与任何2004年调查对象有关的任何反洗钱、了解你的客户或其他合规活动有关的所有文件，包括但不限于任何2004年调查对象提供的任何信息，或贵方获悉的任何信息。\n\n8．与任何国家的任何监管机构之间、涉及任何2004年调查对象的任何通信有关的所有文件，包括但不限于与Bank of England（英格兰银行）、United States Federal Reserve（美国联邦储备系统）、S.E.C.（美国证券交易委员会）、CFTC（美国商品期货交易委员会）、FINRA（美国金融业监管局）、China Securities Regulatory Commission（中国证券监督管理委员会）、People's Bank of China（中国人民银行）、Hong Kong Securities and Futures Commission（香港证券及期货事务监察委员会）及Hong Kong Monetary Authority（香港金融管理局）的通信。\n\n附件 C-13\n\nB2540（表格2540——规则2004审查传票）（12/15）案件 22-50073 文件 1592 提交于 03/24/23 录入于 03/24/23 10:57:37 第 254 页，共\n\nUNITED STATES BANKRUPTCY COURT（美国破产法院）\n\nDistrict of Connecticut（康涅狄格州地区）\n\n关于 HO WAN KWOK（郭文贵）等人的事项，\n\n1 案号 22-50073 (JAM) 债务人 第11章\n\n（合并管理）\n\n规则2004审查传票\n\n致：First Republic Bank（第一共和银行）\n\n（传票所指向之人的姓名）\n\n证言：现命令贵方于下列规定的时间、日期和地点出席，并根据《联邦破产程序规则》规则2004接受审查时作证。随附准许该审查的法院命令副本。\n\n地点　日期和时间\n\nNeubert, Pepe & Monteith, P.C.（诺伊贝特、佩佩和蒙蒂思律师事务所）\n195 Church Street　[待定]\nNew Haven, Connecticut 06510\n\n审查将通过以下方式记录：法庭书记员/速记员\n\n提交：贵方或贵方代表还必须携带下列文件、电子存储信息或物件出席审查，并必须允许对该材料进行检查、复制、测试或取样：\n\n见随附的文件提交请求。\n\n下列 Fed. R. Civ. P. 45 条款根据 Fed. R. Bankr. P. 9016 适用于破产案件，现随附于后：有关履行地点的 Rule 45(c)；有关对作为传票对象之人的保护的 Rule 45(d)；以及有关贵方回应本传票的义务及不回应的潜在后果的 Rule 45(e) 和 45(g)。\n\n日期：March , 2023\n\n法院书记员\n\n或\n\n书记员或副书记员签名　律师签名\n\n签发或请求本传票的 Luc A. Despins（卢克·A·德斯平斯）第11章受托人的代理律师姓名、地址、电子邮箱地址及电话号码如下：\n\nDouglas S. Skalka, Esq.（道格拉斯·S·斯卡尔卡律师）；Neubert, Pepe & Monteith, P.C.（诺伊贝特、佩佩和蒙蒂思律师事务所）；195 Church Street, New Haven, Connecticut 06510 dskalka@npmlaw.com；(203) 821-2000\n\n致签发或请求本传票之人的通知\n\n如本传票命令在审判前提交文件、电子存储信息或有形物品，或检查场所，则必须在向传票所指向之人送达之前，向每一方送达通知及本传票副本。Fed. R. Civ. P. 45(a)(4)。\n\n软件版权 (c) 1996-2022 Best Case, LLC（Best Case有限责任公司）- www.bestcase.com Best Case Bankruptcy 1 本第11章案件中的债务人为 Ho Wan Kwok（亦称 Guo Wengui、Miles Guo 和 Miles Kwok，以及众多其他别名）（税务识别号码末四位：9595）、Genever Holdings LLC（吉尼弗控股有限责任公司）（税务识别号码末四位：8202）及 Genever Holdings Corporation（吉尼弗控股公司）。受托人、Genever Holdings LLC 和 Genever Holdings Corporation 的邮寄地址为 Paul Hastings LLP（保尔·哈斯廷斯律师事务所），200 Park Avenue, New York, NY 10166，转交 Luc A. Despins，作为 Ho Wan Kwok 破产财产的受托人（仅为通知和通信之目的）。\n\n送达证明\n\n（除非 Fed. R. Civ. P. 45 要求，否则本节不应向法院提交。）\n\n本人于（日期）收到向（个人姓名及职务，如有）送达的本传票。\n\n本人通过按如下方式向具名人士交付副本而送达本传票：\n\n于（日期）；或\n\n本人未执行即退回本传票，原因如下：\n\n除非本传票系代表美国或其官员或代理人签发，本人亦已向证人支付一天出席费用及法律允许的里程费，金额为 $ 。\n\n本人的旅费为 $，服务费为 $，合计为 $。\n\n本人在伪证处罚的约束下声明，该等信息真实且正确。\n\n日期：\n\n送达人签名\n\n正楷姓名及职务\n\n送达人地址\n\n有关尝试送达等的补充信息：\n\nFederal Rule of Civil Procedure 45(c), (d), (e), and (g)（Effective 12/1/13）（根据 Federal Rules of Bankruptcy Procedure Rule 9016 适用于破产案件）\n\n(c) 履行地点。\n\n（1）审判、听证或证言录取。传票仅可按如下规定命令一人出席审判、听证或证言录取：\n\n（A）在该人居住、受雇或经常亲自从事商业活动地点的100英里范围内；或\n\n（B）在该人居住、受雇或经常亲自从事商业活动所在州内，如该人：\n\n（i）为当事人或当事人的高级职员；或\n\n（ii）被命令出席审判且不会产生重大费用。\n\n（2）其他证据开示。传票可以命令：\n\n（A）在该人居住、受雇或经常亲自从事商业活动地点的100英里范围内的地点提交文件、电子存储信息或物品；以及\n\n（B）在待检查场所对其进行检查。\n\n(d) 对作为传票对象之人的保护；执行。\n\n（1）避免不当负担或费用；制裁。负责签发和送达传票的一方或律师必须采取合理措施，以避免对作为传票对象之人施加不当负担或费用。要求履行义务所在地区的法院必须执行该义务，并对未遵守者一方或律师施加适当制裁，其中可能包括收入损失和合理的律师费。\n\n（2）命令提交材料或准许检查。\n\n（A）无需出席。被命令提交文件、电子存储信息或有形物品，或准许检查场所的人，无需亲自出席提交或检查地点，除非其还被命令出席证言录取、听证或审判。\n\n（B）异议。被命令提交文件或有形物品，或准许检查的人，可以向传票中指定的一方或律师送达书面异议，反对检查、复制、测试或取样全部或部分材料，或反对检查场所，或者反对以要求的形式或多种形式提交电子存储信息。异议必须在规定履行时间或传票送达后14日之中较早者之前送达。如提出异议，则适用以下规则：\n\n（i）送达方可随时通知被命令之人，向要求履行义务所在地区的法院提出动议，请求作出强制提交或检查的命令。\n\n（ii）仅可依命令所指示要求实施这些行为，且该命令必须保护并非当事人或当事人高级职员之人免于因履行而产生的重大费用。\n\n（3）撤销或修改传票。\n\n（A）必须撤销或修改的情形。经及时动议，要求履行义务所在地区的法院必须撤销或修改具有下列情形的传票：\n\n（i）未给予合理履行时间；\n\n（ii）要求一人在 Rule 45(c) 规定的地理范围之外履行；\n\n（iii）要求披露享有特权或受其他保护的事项，且不适用任何例外或豁免；或\n\n（iv）使一人承受不当负担。\n\n（B）可以撤销或修改的情形。为保护作为传票对象或受传票影响之人，要求履行义务所在地区的法院可以经动议撤销或修改要求下列事项的传票：\n\n（i）披露商业秘密或其他保密研究、开发或商业信息；或\n\n（ii）披露未受聘专家的意见或信息，该等意见或信息并未描述争议中的具体事件，且源于该专家未经一方请求进行的研究。\n\n（C）作为替代方案规定条件。在 Rule 45(d)(3)(B) 所述情形下，如送达方：\n\n（i）证明对该证言或材料具有实质需要，且不遭受过度困难即无法以其他方式满足该需要；以及\n\n（ii）确保被传唤之人将获得合理补偿，\n\n则法院可以不撤销或修改传票，而命令在规定条件下出席或提交。\n\n(e) 回应传票的义务。\n\n（1）提交文件或电子存储信息。下列程序适用于提交文件或电子存储信息：\n\n(A) 文件。对要求提交文件的传票作出回应的人，必须按照文件在正常业务过程中保存的方式提交文件，或者必须对文件进行整理和标注，使其与要求中所列类别相对应。\n\n(B) 未规定电子存储信息提交形式。传票未规定电子存储信息的提交形式的，作出回应的人必须以其通常保存的一种或多种形式，或者以一种或多种合理可用的形式提交该信息。\n\n(C) 电子存储信息仅以一种形式提交。作出回应的人无需以一种以上的形式提交同一电子存储信息。\n\n(D) 无法访问的电子存储信息。对于该人认定因过度负担或费用而无法合理访问的来源中的电子存储信息，作出回应的人无需提供证据开示。在提出强制证据开示动议或保护令动议时，作出回应的人必须证明该信息因过度负担或费用而无法合理访问。如作出该证明，法院在考虑 Rule 26(b)(2)(C) 的限制后，如提出请求的一方证明有正当理由，仍可命令从该等来源进行证据开示。法院可以规定该证据开示的条件。\n\n(2) 主张特权或保护。\n\n(A) 被扣留的信息。依据该信息享有特权或作为审判准备材料受保护的主张而扣留传票所要求信息的人，必须：(i) 明确提出该主张；以及\n\n(ii) 以一种方式说明被扣留文件、通信或有形物的性质，使各方在不披露本身享有特权或受保护信息的情况下，能够评估该主张。\n\n(B) 已提交的信息。若为回应传票而提交的信息受到特权主张或作为审判准备材料受保护的主张约束，提出该主张的人可将该主张及其依据通知任何收到该信息的一方。收到通知后，一方必须立即返还、隔离或销毁所指明的信息及其持有的任何副本；在该主张得到解决前，不得使用或披露该信息；如该方在收到通知前已披露该信息，必须采取合理措施予以追回；并可立即将该信息密封提交给要求履行义务所在地区的法院，以裁定该主张。提交该信息的人必须在该主张得到解决前保存该信息。\n\n(g) 藐视法庭。要求履行义务所在地区的法院——以及在动议移送后，发出传票的法院——可对已被送达但无充分理由未遵从传票或与其相关命令的人处以藐视法庭。\n\n有关获取传票材料，见 Fed.R.Civ.P.45(a) Committee Note (2013)\n\n……\n\n文件提交请求\nI. 指示\n\n1. 除非另有说明，下列文件请求（以下简称“请求”，每一项称为“一项请求”）必须分别且具体地作出回应。除非出于善意提出异议，否则必须对每项请求作出完整答复；如提出异议，必须如下文所述详细说明贵方异议的理由。如异议仅涉及某项请求的一部分，或其中包含的某一词语、短语或条款，贵方仅须说明对该部分的异议，并对其余请求作出回应。\n\n2. 电子存储信息必须按照以下指示提交：\n\na. 图像。黑白图像必须为 300 DPI Group IV 单页 TIFF 文件。彩色图像必须以 JPEG 格式提交。文件名不得包含嵌入的空格或特殊字符（包括逗号）。文件夹名称不得包含嵌入的空格或特殊字符（包括逗号）。所有 TIFF 图像文件必须具有唯一的文件名，即 Bates 编号。每张图像右下角必须加注连续的 Bates 编号。每个文件夹中的 TIFF 文件数量不得超过 1000 个。Excel 电子表格应具有一个以该文件 Bates 编号命名的占位图像。\n\nb. 图像加载文件\n\na. Concordance® 数据文件。数据文件（.DAT）包含将加载到 Concordance® 数据库中的全部字段信息。.DAT 文件的第一行必须为标识字段名称的标题行。.DAT 文件必须使用以下 Concordance® 默认分隔符：逗号 ASCII 字符（020）引号 þ ASCII 字符（254）。日期字段应采用如下格式提供：mm/dd/yyyy。日期和时间字段必须为两个独立字段。如文件包括已成像的电子邮件和附件，则必须包括附件字段，以保留电子邮件与其附件之间的父项/子项关系。必须包括 OCRPATH 字段，以提供已提交存储介质上提取文本文件的文件路径和名称。文本文件必须以 FIRSTBATES 命名。不得在 .DAT 文件中包含文本。对于含有原生文件的文件，必须包括 LINK 字段，以提供原生文件的文件路径和名称。原生文件必须以 FIRSTBATES 命名。\n\nb. Concordance Image® 或 Opticon 交叉引用文件。图像交叉引用文件（.LOG 或 .OPT）将图像与数据库记录连接。该文件应为逗号分隔文件，每行包含七个字段，并且数据库中的每张图像均应在交叉引用文件中有一行，格式如下：ImageID,VolumeLabel,ImageFilePath,DocumentBreak,FolderBreak,Box Break,PageCoun。\n\nc. 文件文本。文本必须作为单独的文本文件提交，而不得作为 .DAT 文件中的字段提交。文本文件的完整路径（OCRPATH）应包括在 .DAT 文件中。建议提供以 FIRSTBATES/Image Key 命名的文件级 ANSI 文本文件。提取的文本文件必须置于单独的文件夹中，每个文件夹中的文本文件数量不得超过 1,000 个。文件夹名称中不得有特殊字符（包括逗号）。文本文件必须按文件级别提供。\n\nd. 某些文件类型的原生格式提交。为充分理解其内容和含义而合理需要以原生格式查看的文件类型，必须以原生格式提交。这些文件包括但不限于电子表格、类电子表格文件（Microsoft Excel、逗号分隔值、制表符分隔值等）、Microsoft PowerPoint 或其他特殊演示文件、数据库文件以及音频/视频文件。应提供一张带有 Bates 编号的分隔页图像，表明原生文件的存在，并在 .dat 文件中将原生文件路径作为一个字段列入。提交的原生文件应以与该文件分隔页相对应的 Bates 编号命名。原生文件应归入按递增方式命名的“NATIVE”目录中，并与图像目录分开。\n\ne. 去重。对于存在完全重复件的每份电子文件，仅提交一份副本。对于电子邮件，应基于由 BCC、Body、CC、From、IntMsgID、To 和 Attach 属性生成的 MD5 哈希值合并重复件。对于电子邮件附件和独立电子文件，应基于整个文件的 MD5 哈希值合并重复件。\n\nf. 元数据。以符合 Concordance 的加载文件（.dat）形式提交每份文件的提取元数据。.DAT 文件的第一行必须为标识字段名称的标题行。.DAT 文件必须使用以下 Concordance 默认分隔符：逗号 , ASCII 字符（020）引号 þ ASCII 字符（254）\n\n日期字段应采用如下格式提供：mm/dd/yyyy。日期和时间字段必须为两个独立字段。下列为必需元数据：\nCase 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 259 of 1063\n\n字段名称　示例数据　说明\n\nFIRSTBATES　EDC0000001　原生文件文件/电子邮件的第一个 Bates 编号\n\nLASTBATES　EDC0000001　原生文件文件/电子邮件的最后一个 Bates 编号\n\nLASTBATES 字段应针对单页文件填写\n\nATTACHRANGE　EDC0000001\n-　父项文件第一页的 Bates 编号至最后一个附件“子项”文件最后一页的 Bates 编号\nEDC0000015\n\nBEGATTACH　EDC0000001　附件范围的第一个 Bates 编号\n\nENDATTACH　EDC0000015　附件范围的最后一个 Bates 编号\n\nCUSTODIAN　Smith, John　电子邮件：电子邮件所在的邮箱\n原生文件：文件来源的个人或部门名称\n\nFROM　John Smith　电子邮件：发件人\n原生文件：文件作者\n多个条目之间应使用分号分隔\n\nTO　Coffman, Janice; LeeW　收件人\n[mailto:LeeW@MSN.com]　多个条目之间应使用分号分隔\n\nCC　Frank Thompson [mailto:　抄送收件人\nfrank_Thompson@cdt.com]　多个条目之间应使用分号分隔\n\nBCC　John Cain　密送收件人\n多个条目之间应使用分号分隔\n\nSUBJECT　Board Meeting Minutes　电子邮件：电子邮件主题行\n原生文件：文件标题（如有）\n\nFILE_NAME　BoardMeetingMinutes.docx　原生文件：原始原生文件的名称，包括扩展名\n\nDATE_SENT　10/12/2010　电子邮件：电子邮件发送日期\n原生文件：（空）\n\nTIME_SENT/\nTIME_ZONE　07:05 PM GMT　电子邮件：电子邮件发送时间/电子邮件标准化所采用的时区\n\nTIME_ZONE　GMT　在转换过程中电子邮件被标准化所采用的时区。\n\nLINK　EDC0000001.msg　指向电子邮件或原生文件文件的超链接\n所链接文件必须以 FIRSTBATES 编号命名\n\nFILE_EXTEN　MSG　表示电子邮件或原生文件文件的文件类型扩展名\n\nAUTHOR　John Smith　电子邮件：（空）\n原生文件：文件作者\n\nDATE_CREATED　10/10/2010　电子邮件：（空）\n原生文件：文件创建日期\nCase 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 260 of 1063\n\nTIME_CREATED　10:25 AM　电子邮件：（空）\n原生文件：文件创建时间\n该数据必须为独立字段，不得与 DATE_CREATED 字段合并\n\nDATE_MOD　10/12/2010　电子邮件：（空）\n原生文件：文件最后修改日期\n\nTIME_MOD　07:00 PM　电子邮件：（空）\n原生文件：文件最后修改时间\n该数据必须为独立字段，不得与 DATE_MOD 字段合并\n\nDATE_ACCESSD　10/12/2010　电子邮件：（空）\n原生文件：文件最后访问日期\n\nTIME_ACCESSD　07:00 PM　电子邮件：（空）\n原生文件：文件最后访问时间\n该数据必须为独立字段，不得与 DATE_ACCESSD 字段合并\n\nFILE_SIZE　5,952　原生文件文件/电子邮件的大小，以 KB 计\n\nPGCOUNT　1　原生文件文件/电子邮件的页数\n\nPATH　电子邮件：（空）\nAgenda.doc　原生文件：原生文件文件的存储路径，包括原始文件名。\n\nINTFILEPATH　Personal Folders\\Deleted　电子邮件：电子邮件的原始位置，包括原始文件名。\nItems\\Board Meeting\nMinutes.msg　原生文件：（空）\n\nINTMSGID　<000805c2c71b\\$75977050\\$　电子邮件：唯一消息 ID 原生文件：（空）\ncb8306d1@MSN>\n\nMD5HASH　d131dd02c5e6eec4693d9a0　文件的 MD5 哈希值。\n698aff95c\n2fcab58712467eab4004583e\nb8fb7f89\n\nOCRPATH　TEXT/001/EDC0000001.txt　原生文件提取文本的路径\n\n3. 每项请求均独立适用并应独立解释，除非另有说明，任何一项请求均不限制任何其他请求的范围。\n\n4. 所有文件均应按照其在正常业务过程中保存的方式提交，或者应进行整理和标注，以与本请求中的类别相对应。\n\n5. 本文所载每项请求均延及下列所有文件：(a) 由贵方占有、保管或控制的文件；或 (b) 由代表贵方行事的任何人占有、保管或控制的文件，\nCase 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 261 of 1063\n\n包括贵方的律师或其他代表和顾问。每份文件均应完整提交。\n\n6. 如要求你方提交一份已不再由你方占有、保管或控制的文件，则你方的答复必须：(a) 详细说明该文件的性质及其内容；(b) 确认编制或撰写该文件的人员（以及，如适用，文件的收件人员）；(c) 确认该文件编制或创建的日期；(d) 说明该文件是否：(i) 遗失或丢失，(ii) 已被销毁，(iii) 已自愿或非自愿地转移给他人，或 (iv) 以其他方式处置；(e) 说明该等处置的理由以及相关事实和情形；(f) 确认授权该等处置的人员；(g) 确认该等处置的日期或大致日期；(h) 说明该文件最近一次由你方占有、保管或控制的时间；以及 (i) 确认目前占有、保管或控制该文件的人员（如有）。\n\n7. 如要求你方提交一份已被销毁的文件，则除前述指示所要求的信息外，你方的答复还必须说明：(a) 销毁该文件的理由；(b) 销毁该文件的人员身份；以及 (c) 指示销毁该文件的人员身份。\n\n8. 如你方主张某一被要求提供的文件受特权或律师工作成果保护，则你方的答复必须：(a) 说明：(i) 足以支持你方关于该文件受特权保护之主张的文件描述，(ii) 该文件的标题，(iii) 该文件的日期，(iv) 该文件的作者，(v) 该文件的收件人，(vi) 收到或查看该文件原件或任何草稿、副本或复制件的每一人员身份，(vii) 该文件本身，或该文件所载或所提及的任何信息，是否由任何其他人员占有、保管或控制；如是，则确认该等人员的身份，\n\n案件 22-50073 文书 1592 已提交 03/24/23 登记 03/24/23 10:57:37 第 262 页，共 1063 页\n\n并说明该等人员如何取得该信息，(viii) 据以拒绝提交该文件的特权主张，以及 (ix) 你方将据以支持该等特权主张的所有情形；以及 (b) 就依据特权主张而拒绝提交的每一文件，根据 D. Conn. L. Civ. R. 26(e)，提交一份特权日志，其中载明本指示第 (a) 部分所要求的全部信息。对于文件请求中未提出特权或工作成果主张的任何部分，应完整提供相应文件。\n\n9. 如一份本应提交的文件的一部分含有受特权主张约束的信息，则仅应依照上述指示从该文件中删除或遮盖受特权主张约束的部分，其余部分应予提交。\n\n10. 该等请求具有持续性质。现指示你方：(a) 一旦获悉先前答复不完整或不正确，立即补充或更正任何后来得知不完整或不正确的答复；以及 (b) 提交根据下述规定所要求的任何额外文件。\n\n11. 如文件使用英语以外的语言，你方应提供该文件。如文件使用英语以外的语言，且存在英文译本，你方应同时提供两份文件。\n\n12. 对实体的一切提及均包括其所有关联方。\n\n13. 对个人姓名的一切提及均包括所有其他名称、别名或昵称。\n\n案件 22-50073 文书 1592 已提交 03/24/23 登记 03/24/23 10:57:37 第 263 页，共 1063 页\n\n14. 除非另有明确说明，文件请求所涵盖的期间为自 February 5, 2012 起至应提交文件请求答复之日止。\n\nII. 解释规则\n\n15. (a) 任何单数名词的使用应解释为包括复数，反之亦然；以及 (b) 任何时态动词的使用应解释为在所有其他时态中使用该动词。\n\n16. (a) “和”及“或”应视必要解释为并列或选择关系，以使原本可能被解释为不在任何请求范围内的所有答复均纳入该请求范围；以及 (b) “每一”及“任何”应视为包括并涵盖“每个”及“所有”二词。\n\nIII. 定义\n\n经 D. Conn. Bankr. L.R. 2004-1(a) 纳入的 D. Conn. L. Civ. R. 26(c) 所规定的定义，以及 D. Conn. L. Civ. R. 26(d) 所规定的解释规则，适用于该等文件请求。此外，本文件请求中使用的下列术语具有下列含义：\n\n1. “你方”或“你的”或“你本人”系指 First Republic Bank（第一共和银行）及其所有关联方。\n\n2. “债务人”系指 Ho Wan Kwok（郭文贵）（又名 Miles Kwok、Miles Guo、Guo Wengui、Guo Haoyun、郭文贵，或任何其他别名），以及其雇员、代理人、律师、顾问或任何代表其行事之人。\n\n案件 22-50073 文书 1592 已提交 03/24/23 登记 03/24/23 10:57:37 第 264 页，共 1063 页\n\n3. “债务人之子”系指 Qiang Guo（郭强）（又名 Mileson Kwok、郭强，或任何其他别名），以及其雇员、代理人、律师、顾问或任何代表其行事之人。\n\n4. “债务人之女”系指 Mei Guo（郭美）（又名 Mei Gui、郭美，或任何其他别名），以及其雇员、代理人、律师、顾问或任何代表其行事之人。\n\n5. “债务人所谓妻子”系指 Hing Chi Ngok（岳庆芝）（又名 Hing Chi Ng、Yue Qingzhi、岳庆芝，或任何其他别名），以及其雇员、代理人、律师、顾问或任何代表其行事之人。\n\n6. “债务人家属”单独及合并系指债务人、债务人之子、债务人之女及债务人所谓妻子，以及与债务人具有任何其他家庭关系之人。\n\n7. “2004 取证对象”单独及合并系指债务人、债务人家属、ACA Capital Group Limited、Himalaya International Financial Group Ltd.、Himalaya International Clearing Ltd.、Himalaya International Payments Ltd.、Himalaya International Reserves Ltd.、Jesse Brown、William Je、William Je、Eastern Profit Corporation Limited、HK International Funds Investments (USA) Limited LLC、Bravo Luck Limited、Golden Spring (New York) Ltd.、Lamp Capital LLC、Greenwich Land LLC、Qu Guo Jiao、Daniel Thomas Podhaskie、Yvette Wang（又名 Yanping Wang，又名 Yan Ping Wang）、Ace Decade Holdings Limited、Dawn State Limited、Rule of Law Society IV Inc.、Rule of Law Foundation III, Inc.、Rule of Law Foundation IV, Inc.、Rule of Law Fund、Rule of Law Society、GTV Media Group, Inc.、Voice of Guo Media, Inc.、Saraca Media Group Inc.、Genever Holdings Corporation、Genever Holdings LLC、Gnews Media Group Inc.、G Fashion LLC、Gmusic LLC、Gnews LLC、Geducation、GFNY, Inc.、G-Club Investments Limited、G Club Operations LLC、G Club US Operations Inc.、G Club US Operations LLC、G Live, LLC、Gbroadcast, LLC、Gposts LLC、HCHK Property\n\n案件 22-50073 文书 1592 已提交 03/24/23 登记 03/24/23 10:57:37 第 265 页，共 1063 页\n\nManagement, Inc.、HCHK Technologies, Inc.、FMV Ltd./Freedom Media Venture Ltd.、Roscalitar 2、Himalaya New World Inc.、US Himalaya Capital Inc.、Hudson Diamond Holding, Inc.、Hudson Diamond Holding LLC、Hudson Diamond NY LLC、Infinity Treasury Management Inc.、Lexington Property and Staffing, Inc.、AI Group Holdings Inc.、Hamilton Capital Holdings Inc.、Booming Sail New York LLC、Himalaya Ventures LLC、Himalaya Ventures LLC、Himalaya Investment LLC、New York MOS Himalaya LLC、MOS Himalaya LLC、Crane Advisory Group、Maywind Trading LLC、Gettr USA, Inc.、Han Chunguang、Bingshang Jiao、Karin Maistrello、Mary Jiang、Jiaming Liu 及 Wencong Wang。\n\n8. “包括”或其任何变体意指“包括但不限于”。\n\n9. “和”及“或”意指“和/或”，并应为最大限度扩大其范围而同时解释为并列关系及选择关系。\n\n10. “任何”、“所有”及“每一”意指“每一及所有”。\n\n11. “每一”及“每个”意指“每一及所有”。\n\n12. “第三方”系指你本人以外的人员或实体。\n\n13. “转让”应具有《破产法》第 101(54) 条赋予该术语的含义。\n\n14. “文件”系指属于 Fed. R. Civ. P. 34 范围内的任何信息或物品，并包括但不限于任何种类、类型、性质或描述的每一书面、记录或图形资料，而该等资料现由或曾由你方占有、保管或控制，包括电子邮件的所有打印件和电子副本、以电子形式保存的计算机文件、函件、备忘录、磁带、速记或手写笔记、任何种类的书面表格、图表、蓝图、绘图、草图、曲线图、计划、文章、规格说明书、日记、信函、\n\n案件 22-50073 文书 1592 已提交 03/24/23 登记 03/24/23 10:57:37 第 266 页，共 1063 页\n\n电报、照片、会议记录、合同、协议、调查资料、计算机打印输出、任何种类的数据汇编、电传、传真、电子邮件、短信、即时消息、语音留言、发票、订单、支票、汇票、对账单、贷项通知单、报告、持仓报告、摘要、索引、书籍、账簿、笔记本、附表、透明胶片、录音、目录、广告、宣传材料、胶片、录像带、录音带、CD、计算机磁盘、宣传册、小册子、穿孔卡、工时单、推文、社交媒体帖子或任何其他种类的书面或记录资料，以及其所有元数据；无论其以何种方式存储（无论为有形或电子形式）、记录、制作或复制；亦包括但不限于前述任何资料的草稿或副本，如其中含有原始文件中未载的任何种类笔记、评论或标记，或在其他方面与原始文件不相同。\n\n15. “人员”系指个人、公司、独资企业、合伙企业、协会或任何其他实体。“人员”亦包括任何代理人、代表或专家，包括但不限于律师或财务顾问。\n\n16. “实体”系指任何自然人、公司、合伙企业、子公司、独资企业、商号、董事会、合资企业、协会、机构、主管机关、委员会或其他商业实体或法人，以及任何关联方、代理人、母公司，包括但不限于律师、财务顾问或任何其他代表。\n\n17. “关于”意指涉及、描述、包含、提及、与之相关、支持、有利于、反对、加强、减损、载于、结合考虑、与之有关、证明、表明、报告、记录、暗示、答复、连接、评论、就其而言、有关、与之相关、讨论、展示、描述、反映、分析、构成及为。\n\n案件 22-50073 文书 1592 已提交 03/24/23 登记 03/24/23 10:57:37 第 267 页，共 1063 页\n\n18. 当涉及任何特定主题事项时，“与……有关”、“涉及”或“相关”意指，包括但不限于，构成、包含、涉及、含有、体现、反映、识别、陈述、直接或间接提及，或以任何方式与所识别的特定主题事项有关的任何文件。\n\n19. “通信”系指在最广泛可能意义上且不受限制的任何信息或知识的传递（以事实、观点、询问或其他形式）。通信还指所有谈话、协议、询问或答复，无论是当面、通过电话、书面形式，还是通过电子传输设备进行，并包括但不限于所有函件、电子邮件、录音、传输单、备忘录、电话通信、语音留言、电报、传真、电传副本、电传、即时消息、聊天、短信、发布至留言板或群聊的信息、社交媒体帖子、推文、上传至任何视频平台的视频、电话记录，或在内部或与第三方传送的记录。\n\n20. “资产”系指受占有、保管或控制的任何具有经济价值的项目。资产包括所有不动产和动产，包括但不限于房地产、土地、房屋、公寓、产权公寓、汽车、游艇、船舶、飞机、喷气机、直升机、现金、银行账户、加密货币、证券、应收账款、存货及其他有形和无形财产。\n\nIV. 应提交的文件\n\n1. 与由任何 2004 取证对象持有、控制、代表其持有或以其他方式与其相关的任何账户有关的所有文件，包括任何及所有账户对账单、授权书、委托书、信托、指示或表格、已注销支票副本、函件，以及电汇及相关函件和指示。\n\n案件 22-50073 文件 1592 提交日期 03/24/23 录入日期 03/24/23 10:57:37 第 268 页，共 1063 页\n\n2. 与属于任何 2004 取证对象、由其持有、控制、代表其持有或以其他方式与其相关的任何资金、证券、财产或资产有关的所有文件，包括任何及所有账户对账单、授权书、委托书、信托、指示或表格、已注销支票副本、函件，以及电汇及相关函件和指示。\n\n3. 与同任何 2004 取证对象进行的任何商业、贸易或金融交易有关的所有文件，包括但不限于任何贷款、信用额度、寄托、存款、互换、证券交易、抵押贷款或 ISDA，包括任何及所有账户对账单、授权书、委托书、信托、指示或表格、已注销支票副本、函件，以及电汇及相关函件和指示。\n\n4. 与 2004 取证对象有关的任何电汇活动有关的所有文件，不论是否存在任何账户，包括但不限于所有电汇收据、账户号码、余额、授权书、与转账各方有关的身份识别信息、函件、指示或其他记录。\n\n5. 与贵方和 2004 取证对象之间的任何函件和通信有关的所有文件。\n\n6. 与任何 2004 取证对象的任何账户有关的所有文件，涉及账户开立、账户获授权使用人及账户维护。\n\n7. 与任何 2004 取证对象有关的任何反洗钱、了解你的客户或其他合规活动有关的所有文件，包括但不限于任何 2004 取证对象提供的信息，或贵方获悉的信息。\n\n8. 与来自任何国家的任何监管机构的任何通信有关的所有文件，包括但不限于 Bank of England（英格兰银行）、United States Federal Reserve（美国联邦储备系统）、\n\nS.E.C.（美国证券交易委员会）、CFTC（美国商品期货交易委员会）、FINRA（美国金融业监管局）、China Securities Regulatory Commission（中国证券监督管理委员会）、People's Bank of China（中国人民银行）、Hong Kong Securities and Futures Commission（香港证券及期货事务监察委员会）及 Hong Kong Monetary Authority（香港金融管理局），涉及任何 2004 取证对象。\n\n附件 C-14\n\nB2540（表格 2540——规则 2004 审查传票）（12/15）案件 22-50073 文件 1592 提交日期 03/24/23 录入日期 03/24/23 10:57:37 第 271 页，共\n\nUNITED STATES BANKRUPTCY COURT（美国破产法院）\n\nDistrict of Connecticut（康涅狄格区）\n\n关于 HO WAN KWOK（郭文贵）等人案，\n\n1 案件编号 22-50073 (JAM)\n\n债务人 第 11 章\n\n（合并管理）\n\n规则 2004 审查传票\n\n致：Signature Bank（签名银行）\n\n（传票所指向之人的姓名）\n\n作证：兹命令贵方于下列规定的时间、日期及地点出席，根据《联邦破产程序规则》第 2004 条进行的审查并作证。随附准许该审查的法院命令副本。\n\n地点　日期及时间\n\nPaul Hastings LLP\n200 Park Avenue　[待定]\nNew York, New York 10166\n\n审查将采用以下方式记录：法庭记录员/速记员\n\n提交：贵方或贵方代表还必须携带下列文件、电子存储信息或物品参加审查，并必须允许对该材料进行检查、复制、测试或抽样：\n\n见随附的文件提交请求。\n\n《联邦民事诉讼规则》第 45 条的下列规定，经《联邦破产程序规则》第 9016 条适用于破产案件，随附于后——第 45(c) 条，关于履行地点；第 45(d) 条，关于贵方作为传票对象所受的保护；以及第 45(e) 条和第 45(g) 条，关于贵方对本传票作出回应的义务及未作出回应的潜在后果。\n\n日期：2023 年 3 月\n\n法院书记官\n\n或\n\n书记官或副书记官签名　律师签名\n\n代表发出或请求本传票的第 11 章受托人 Luc A. Despins（卢克·A·德斯平斯）的律师姓名、地址、电子邮件地址及电话号码如下：\n\nDouglas S. Skalka, Esq.（道格拉斯·S·斯卡尔卡律师）；Neubert, Pepe & Monteith, P.C.（纽伯特、佩佩与蒙蒂思律师事务所）；195 Church Street, New Haven, Connecticut 06510；dskalka@npmlaw.com；(203) 821-2000\n\n致发出或请求本传票之人的通知\n\n如本传票命令在审判前提交文件、电子存储信息或有形物品，或检查场所，则必须在向传票所指向之人送达之前，向每一方送达通知及本传票副本。Fed. R. Civ. P. 45(a)(4)。\n\n软件版权 (c) 1996-2022 Best Case, LLC - www.bestcase.com Best Case Bankruptcy 1 本第 11 章案件中的债务人为 Ho Wan Kwok（郭文贵，亦称 Guo Wengui、Miles Guo 和 Miles Kwok，以及众多其他别名）（税务识别号码后四位：9595）、Genever Holdings LLC（税务识别号码后四位：8202）及 Genever Holdings Corporation。受托人、Genever Holdings LLC 及 Genever Holdings Corporation 的邮寄地址为 Paul Hastings LLP，200 Park Avenue, New York, NY 10166，转交 Luc A. Despins，作为 Ho Wan Kwok 遗产的受托人（仅为通知和通信之目的）。\n\n送达证明\n\n（除非 Fed. R. Civ. P. 45 要求，否则本节不应向法院提交。）\n\n本人于（日期）收到向（个人姓名及职务，如有）发出的本传票。\n\n本人按如下方式向具名人员交付副本，以送达本传票：\n\n于（日期）；或\n\n本人未执行即退回本传票，原因如下：\n\n除非本传票系代表 United States（美国）或其官员或代理人发出，本人还已向证人支付一天出席费用及法律允许的里程费，金额为 \\$ 。\n\n本人因差旅收取的费用为 \\$，因服务收取的费用为 \\$，合计 \\$。\n\n本人在伪证处罚的约束下声明，该信息真实且正确。\n\n日期：\n\n送达人员签名\n\n正楷姓名及职务\n\n送达人员地址\n\n关于尝试送达等的补充信息：\n\n《联邦民事诉讼规则》第 45(c)、(d)、(e) 及 (g) 条（自 12/1/13 起生效）（经《联邦破产程序规则》第 9016 条适用于破产案件）\n\n(c) 履行地点。\n\n(1) 审判、听证或证言录取。传票仅可按下列方式命令某人出席审判、听证或证言录取：\n\n(A) 在该人居住、受雇或经常亲自从事商业活动地点的 100 英里范围内；或\n\n(B) 在该人居住、受雇或经常亲自从事商业活动所在州内，如该人\n\n(i) 为当事人或当事人的高级职员；或\n\n(ii) 被命令出席审判且不会产生重大费用。\n\n(2) 其他取证。传票可命令：\n\n(A) 在该人居住、受雇或经常亲自从事商业活动地点的 100 英里范围内某一地点提交文件、电子存储信息或物品；以及\n\n(B) 在被检查场所对该场所进行检查。\n\n(d) 对传票对象的保护；执行。\n\n(1) 避免不当负担或费用；制裁。负责发出和送达传票的一方当事人或律师必须采取合理措施，避免对传票对象施加不当负担或费用。要求履行的地区法院必须执行此项义务，并对未遵守者——当事人或律师——施加适当制裁，其中可包括收入损失和合理的律师费。\n\n(2) 命令提交材料或允许检查。\n\n(A) 无须出席。被命令提交文件、电子存储信息或有形物品，或允许检查场所的人，无须亲自出席提交或检查地点，除非其还被命令出席证言录取、听证或审判。\n\n(B) 异议。被命令提交文件或有形物品，或允许检查的人，可以向传票中指定的当事人或律师送达书面异议，反对对任何或全部材料进行检查、复制、测试或抽样，或反对检查场所——或反对以所要求的一种或多种形式提交电子存储信息。异议必须在规定的履行时间之前，或传票送达后 14 日之前（以较早者为准）送达。如提出异议，适用下列规则：\n\n(i) 送达方可随时在通知被命令人的情况下，向要求履行的地区法院提出动议，请求作出强制提交或检查的命令。\n\n(ii) 仅可按该命令所指示要求实施这些行为，且该命令必须保护非当事人亦非当事人高级职员的人免于承担因履行而产生的重大费用。\n\n(3) 撤销或修改传票。\n\n(A) 必须撤销或修改的情形。经及时动议，要求履行的地区法院必须撤销或修改具有下列情形的传票：\n\n(i) 未给予合理的履行时间；\n\n(ii) 要求某人在第 45(c) 条规定的地理范围之外履行；\n\n(iii) 要求披露享有特权或受其他保护的事项，且不存在适用的例外或豁免；或\n\n(iv) 对某人造成不当负担。\n\n(B) 可以撤销或修改的情形。为保护传票对象或受传票影响之人，要求履行的地区法院可经动议撤销或修改具有下列要求的传票：\n\n(i) 披露商业秘密或其他机密研究、开发或商业信息；或\n\n(ii) 披露未受聘专家的意见或信息，该意见或信息并非描述争议中的具体事件，且系该专家未经任何一方请求所作研究的结果。\n\n(C) 以规定条件作为替代。在第 45(d)(3)(B) 条所述情形下，如送达方：\n\n(i) 证明对证言或材料具有重大需要，且如无不当困难则无法通过其他方式满足该需要；以及\n\n(ii) 确保将对被传唤人给予合理报酬，\n\n法院可不撤销或修改传票，而命令在规定条件下出席或提交。\n\n(e) 对传票作出回应的义务。\n\n(1) 提交文件或电子存储信息。下列程序适用于提交文件或电子存储信息：\n\n(A) 文件。对要求提交文件的传票作出回应的人，必须按照该等文件在通常业务过程中保存的方式提交，或者必须对其进行整理和标注，以对应请求中的类别。\n\n(B) 未指定电子存储信息提交形式时的形式。如传票未指定电子存储信息的提交形式，作出回应的人必须以其通常保存的一种或多种形式，或者以一种或多种合理可用的形式提交该等信息。\n\n(C) 电子存储信息仅以一种形式提交。作出回应的人无需以一种以上形式提交相同的电子存储信息。\n\n(D) 不可访问的电子存储信息。作出回应的人无需对其确定因不当负担或费用而无法合理访问的来源中的电子存储信息提供证据开示。在提出强制证据开示动议或保护令动议时，作出回应的人必须证明该信息因不当负担或费用而无法合理访问。如作出该等证明，法院在考虑 Rule 26(b)(2)(C) 的限制后，如请求方证明存在正当理由，仍可命令对该等来源进行证据开示。法院可规定该证据开示的条件。\n\n(2) 主张特权或保护。\n\n(A) 扣留的信息。基于信息享有特权或作为审判准备材料受保护而扣留被传唤信息的人，必须：(i) 明确提出该主张；以及\n\n(ii) 以一种方式描述被扣留文件、通信或有形物的性质，使各方在不披露本身享有特权或受保护的信息的情况下，能够评估该主张。\n\n(B) 已提交的信息。如为回应传票而提交的信息受到特权主张或作为审判准备材料受保护的主张，提出该主张的人可将该主张及其依据通知任何收到该信息的当事人。收到通知后，当事人必须立即返还、隔离或销毁所指明的信息及其持有的任何副本；在该主张得到解决前，不得使用或披露该信息；如该当事人在收到通知前已披露该信息，必须采取合理措施追回该信息；并且可立即将该信息密封提交给要求履行义务所在地区的法院，以裁定该主张。提交该信息的人必须在该主张得到解决前保全该信息。\n\n(g) 藐视法庭。要求履行义务所在地区的法院——以及在动议移送后，签发传票的法院——可对已被送达但无充分理由未遵守传票或与其相关命令的人作出藐视法庭认定。\n\n关于取得传票材料，见 Fed.R.Civ.P.45(a) Committee Note (2013)\n\n……\n\n文件提交请求\n\nI. 指示\n\n1. 除非另有说明，下列文件请求（统称“请求”，各称“一项请求”）必须分别且具体作出答复。除非基于善意提出异议，否则必须完整答复每项请求；如提出异议，必须依照下文规定详细说明贵方异议的理由。如异议仅涉及某项请求的一部分，或其中包含的某个词语、短语或条款，贵方仅须说明对该部分的异议，并对请求的其余部分作出答复。\n\n2. 电子存储信息必须依照下列指示提交：\n\n- a. 图像。黑白图像必须为 300 DPI Group IV 单页 TIFF 文件。彩色图像必须以 JPEG 格式提交。文件名不得包含嵌入空格或特殊字符（包括逗号）。文件夹名称不得包含嵌入空格或特殊字符（包括逗号）。所有 TIFF 图像文件必须具有唯一文件名，即 Bates 编号。每张图像右下角必须标注连续的 Bates 编号。每个文件夹中的 TIFF 文件数量不得超过 1000 个文件。Excel 电子表格应具有以该文件 Bates 编号命名的占位图像。\n\n- b. 图像加载文件\n\n- a. Concordance® 数据文件。数据文件（.DAT）包含将加载至 Concordance® 数据库的所有字段信息。.DAT 文件的第一行必须是标明字段名称的标题行。.DAT 文件必须使用下列 Concordance® 默认分隔符：逗号 ASCII 字符（020）引号 þ ASCII 字符（254）。日期字段应以如下格式提供：mm/dd/yyyy。日期和时间字段必须为两个独立字段。如文件包括已成像的电子邮件及附件，则必须包括附件字段，以保留电子邮件与其附件之间的父项/子项关系。必须包括 OCRPATH 字段，以提供所提交存储介质上提取文本文件的文件路径和名称。文本文件必须以 FIRSTBATES 命名。不得在 .DAT 文件中包含文本。对于包含原生文件的文件，必须包括 LINK 字段，以提供原生文件的文件路径和名称。原生文件必须以 FIRSTBATES 命名。\n\n- b. Concordance Image® 或 Opticon 交叉引用文件。图像交叉引用文件（.LOG 或 .OPT）将图像链接至数据库记录。其应为逗号分隔文件，每行由七个字段组成，数据库中的每幅图像均应在交叉引用文件中对应一行，格式如下：ImageID,VolumeLabel,ImageFilePath,DocumentBreak,FolderBreak,Box Break,PageCoun。\n\n- c. 文件文本。文本必须作为独立文本文件提交，而非作为 .DAT 文件内的字段。文本文件的完整路径（OCRPATH）应包括在 .DAT 文件中。建议提供文件级 ANSI 文本文件，并按照 FIRSTBATES/Image Key 命名。提取的文本文件必须置于单独文件夹中，每个文件夹中的文本文件数量不得超过 1,000 个文件。文件夹名称中不得含有特殊字符（包括逗号）。文本文件必须按文件级提供。\n\n- d. 特定文件类型的原生提交。为完整理解其内容和含义而合理需要以原生格式查看的文件类型，必须以原生格式提交。此类文件包括但不限于电子表格、类电子表格文件（Microsoft Excel、逗号分隔值、制表符分隔值等）、Microsoft PowerPoint 或其他特殊演示文件、数据库文件及音频/视频文件。提供一张带有 Bates 编号的分隔页图像，说明存在原生文件，并在 .dat 文件中将原生文件路径作为字段列入。所提交的原生文件应以与该文件分隔页相对应的 Bates 编号命名。原生文件应归入按递增方式命名的“NATIVE”目录中，并与图像目录分开。\n\n- e. 去重。对于存在完全重复件的每份电子文件，仅提交一份副本。对于电子邮件，应根据由 BCC、Body、CC、From、IntMsgID、To 和 Attach 属性生成的 MD5 哈希值合并重复件。对于电子邮件附件和独立电子文件，应根据整个文件的 MD5 哈希值合并重复件。\n\n- f. 元数据。以符合 Concordance 要求的加载文件（.dat）形式，为每份文件提交提取的元数据。.DAT 文件的第一行必须是标明字段名称的标题行。.DAT 文件必须使用下列 Concordance 默认分隔符：逗号 , ASCII 字符（020）引号 þ ASCII 字符（254）。\n\n日期字段应以如下格式提供：mm/dd/yyyy。日期和时间字段必须为两个独立字段。下列为必需元数据：\nCase 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 276 of 1063\n\n字段名称　示例数据　说明\n\nFIRSTBATES　EDC0000001　原生文件文件/电子邮件的首个 Bates 编号\nLASTBATES　EDC0000001　原生文件文件/电子邮件的最后 Bates 编号\nLASTBATES 字段应针对单页予以填充\nATTACHRANGE　EDC0000001\n-　父文件第一页的 Bates 编号至最后一个附件“子”文件最后一页的 Bates 编号\nEDC0000015\nBEGATTACH　EDC0000001　附件范围的首个 Bates 编号\nENDATTACH　EDC0000015　附件范围的最后 Bates 编号\nCUSTODIAN　Smith, John　电子邮件：电子邮件所在的邮箱\n原生文件：该文件源自其文件的个人或部门名称\nFROM　John Smith　电子邮件：发件人\n原生文件：文件作者\n多个条目之间应使用分号分隔\nTO　Coffman, Janice; LeeW　收件人\n[mailto:LeeW@MSN.com]　多个条目之间应使用分号分隔\nCC　Frank Thompson [mailto:　抄送收件人\nfrank_Thompson@cdt.com]　多个条目之间应使用分号分隔\nBCC　John Cain　密送收件人\n多个条目之间应使用分号分隔\nSUBJECT　Board Meeting Minutes　电子邮件：电子邮件主题行；原生文件：文件标题（如有）\nFILE_NAME　BoardMeetingMinutes.docx　原生文件：原始原生文件的名称，包括扩展名\nDATE_SENT　10/12/2010　电子邮件：电子邮件发送日期\n原生文件：（空）\nTIME_SENT/\nTIME_ZONE　07:05 PM GMT　电子邮件：电子邮件发送时间/电子邮件标准化所用的时区\nTIME_ZONE　GMT　在转换过程中电子邮件被标准化所用的时区\nLINK　EDC0000001.msg　电子邮件或原生文件文件的超链接\n所链接文件必须按照 FIRSTBATES 编号命名\nFILE_EXTEN　MSG　表示电子邮件或的文件类型扩展名\nAUTHOR　John Smith　电子邮件：（空）\n原生文件：文件作者\nDATE_CREATED　10/10/2010　电子邮件：（空）\n原生文件：文件创建日期\nCase 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 277 of 1063\n\nTIME_CREATED　10:25 AM　电子邮件：（空）\n原生文件：文件创建时间\n该数据必须为独立字段，不得与 DATE_CREATED 字段合并\nDATE_MOD　10/12/2010　电子邮件：（空）\n原生文件：文件最后修改日期\nTIME_MOD　07:00 PM　电子邮件：（空）\n原生文件：文件最后修改时间\n该数据必须为独立字段，不得与 DATE_MOD 字段合并\nDATE_ACCESSD　10/12/2010　电子邮件：（空）\n原生文件：文件最后访问日期\nTIME_ACCESSD　07:00 PM　电子邮件：（空）\n原生文件：文件最后访问时间\n该数据必须为独立字段，不得与 DATE_ACCESSD 字段合并\nFILE_SIZE　5,952　原生文件文件/电子邮件的大小，以 KB 计\nPGCOUNT　1　原生文件文件/电子邮件的页数\nPATH　电子邮件：（空）\nAgenda.doc　原生文件：原生文件文件的存储路径，包括原始文件名。\nINTFILEPATH　Personal Folders\\Deleted　电子邮件：电子邮件的原始位置，包括原始文件名。\nItems\\Board Meeting　原生文件：（空）\nMinutes.msg\nINTMSGID　<000805c2c71b\\$75977050\\$　电子邮件：唯一信息 ID；原生文件：（空）\ncb8306d1@MSN>\nMD5HASH　d131dd02c5e6eec4693d9a0　文件的 MD5 哈希值。\n698aff95c\n2fcab58712467eab4004583e\nb8fb7f89\nOCRPATH　TEXT/001/EDC0000001.txt　原生文件提取文本的路径\n\n3. 每项请求独立生效并应独立解释，除非另有说明，任何请求均不限制任何其他请求的范围。\n\n4. 所有文件均应按照其在通常业务过程中保存的方式提交，或者应予整理和标注，以对应本请求中的类别。\n\n5. 本文件所载每项请求均扩及下列所有文件：(a) 由贵方占有、保管或控制的文件；或 (b) 由代表贵方行事的任何人占有、保管或控制的文件，\nCase 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 278 of 1063\n\n包括贵方的律师或其他代表和顾问。每份文件均应完整提交。\n\n6. 如要求您提供一份已不再由您占有、保管或控制的文件，则您的答复必须：(a) 详细描述该文件的性质及其内容；(b) 指明编制或撰写该文件的人员（以及，如适用，文件被发送给的人员）；(c) 指明该文件编制或形成的日期；(d) 说明该文件是否：(i) 遗失或丢失，(ii) 已被销毁，(iii) 已自愿或非自愿地转移给他人，或(iv) 以其他方式处置；(e) 说明该等处置的理由，以及围绕该等处置的事实和情形；(f) 指明授权该等处置的人员；(g) 指明该等处置的日期或大致日期；(h) 说明该文件最近一次处于您的占有、保管或控制之下的时间；以及(i) 指明目前占有、保管或控制该文件的人员（如有）。\n\n7. 如要求您提供一份已被销毁的文件，则除前述指示所要求的信息外，您的答复还必须说明：(a) 销毁该文件的理由；(b) 销毁该文件的人员身份；以及(c) 指示销毁该文件的人员身份。\n\n8. 如您主张某一被要求提供的文件受特权或律师工作成果保护，则您的答复必须：(a) 说明：(i) 足以支持您关于该文件享有特权之主张的文件描述，(ii) 文件标题，(iii) 文件日期，(iv) 文件作者，(v) 文件收件人，(vi) 收到或阅览该文件原件或任何草稿、副本或复制件的每一人员身份，(vii) 该文件本身或文件中载有或提及的任何信息是否处于任何其他人员的占有、保管或控制之下，如是，则指明该等人员的身份，并说明该等信息如何进入其占有范围，(viii) 据以拒绝提供该文件的特权主张，及(ix) 您将据以支持该等特权主张的全部情形；以及(b) 就每一份基于特权主张而拒绝提供的文件，依照 D. Conn. L. Civ. R. 26(e)，制作一份包含本指示第(a)部分所要求全部信息的特权清单。对于文件请求中未主张特权或工作成果保护的任何部分，应完整提供相应文件。\n\nCase 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 279 of 1063\n\n9. 如一份原本应予提供的文件的部分内容含有受特权主张保护的信息，则仅应依照上述指示从该文件中删除或遮蔽受特权主张保护的部分，其余部分应予提供。\n\n10. 该等请求具有持续性。现指示您：(a) 在得知先前答复不完整或不正确后，立即补充或更正任何后来得知不完整或不正确的答复；以及(b) 提供根据以下规定所要求的任何补充文件\n\n11. 如一份文件使用英语以外的语言，您应提供该文件。如一份文件使用英语以外的语言，且存在英文译本，您应同时提供两份文件。\n\n12. 对实体的所有提及均包括其全部关联方。\n\n13. 对个人姓名的所有提及均包括所有其他名称、化名或昵称。\n\nCase 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 280 of 1063\n\n14. 除非另有明确说明，文件请求所涵盖的期间为自 February 5, 2012 起至应提交文件请求答复之日止。\n\nII. 解释规则\n\n15. (a) 使用任何单数名词应解释为包括复数，反之亦然；及(b) 使用任何时态的动词应解释为使用该动词的所有其他时态。\n\n16. (a) “and”和“or”应在必要时解释为连词或选择词，以使任何请求的范围涵盖本可能被解释为不在其范围内的所有答复；及(b) “each”和“any”应视为包括并涵盖“every”和“all”二词。\n\nIII. 定义\n\n经 D. Conn. Bankr. L.R. 2004-1(a) 纳入的 D. Conn. L. Civ. R. 26(c) 所规定的定义及 D. Conn. L. Civ. R. 26(d) 所规定的解释规则，适用于文件请求。此外，本文件请求中使用的下列术语具有下列含义：\n\n1. “您”或“您的”或“您本人”系指 Silvergate Bank（Silvergate 银行）及其全部关联方。\n\n2. “债务人”系指 Ho Wan Kwok（郭文贵）（又名 Miles Kwok、Miles Guo、Guo Wengui、Guo Haoyun、郭文贵或任何其他化名），以及其雇员、代理人、律师、顾问或任何代表其行事之人。\n\nCase 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 281 of 1063\n\n3. “债务人之子”系指 Qiang Guo（郭强）（又名 Mileson Kwok、郭强或任何其他化名），以及其雇员、代理人、律师、顾问或任何代表其行事之人。\n\n4. “债务人之女”系指 Mei Guo（郭美）（又名 Mei Gui、郭美或任何其他化名），以及其雇员、代理人、律师、顾问或任何代表其行事之人。\n\n5. “债务人所谓妻子”系指 Hing Chi Ngok（岳庆芝）（又名 Hing Chi Ng、Yue Qingzhi、岳庆芝或任何其他化名），以及其雇员、代理人、律师、顾问或任何代表其行事之人。\n\n6. “债务人家属”系指债务人、债务人之子、债务人之女及债务人所谓妻子，以及与债务人具有任何其他家庭关系之人，分别及合称。\n\n7. “2004 年调查对象”系指债务人、债务人家属、ACA Capital Group Limited（ACA资本集团有限公司）、Himalaya International Financial Group Ltd.（喜马拉雅国际金融集团有限公司）、Himalaya International Clearing Ltd.（喜马拉雅国际清算有限公司）、Himalaya International Payments Ltd.（喜马拉雅国际支付有限公司）、Himalaya International Reserves Ltd.（喜马拉雅国际储备有限公司）、Jesse Brown（杰西·布朗）、William Je（威廉·杰）、William Je（威廉·杰）、Eastern Profit Corporation Limited（东方盈利有限公司）、HK International Funds Investments (USA) Limited LLC（香港国际基金投资〈美国〉有限责任公司）、Bravo Luck Limited（鸿运有限公司）、Golden Spring (New York) Ltd.（金泉〈纽约〉有限公司）、Lamp Capital LLC（蓝普资本有限责任公司）、Greenwich Land LLC（格林尼治地产有限责任公司）、Qu Guo Jiao（郭骄）、Daniel Thomas Podhaskie（丹尼尔·托马斯·波德哈斯基）、Yvette Wang（王燕平）（又名 Yanping Wang、Yan Ping Wang）、Ace Decade Holdings Limited（艾斯十年控股有限公司）、Dawn State Limited（黎明州有限公司）、Rule of Law Society IV Inc.（法治协会IV公司）、Rule of Law Foundation III, Inc.（法治基金会III公司）、Rule of Law Foundation IV, Inc.（法治基金会IV公司）、Rule of Law Fund（法治基金）、Rule of Law Society（法治协会）、GTV Media Group, Inc.（GTV媒体集团公司）、Voice of Guo Media, Inc.（郭媒体之声公司）、Saraca Media Group Inc.（萨拉卡媒体集团公司）、Genever Holdings Corporation（热内维尔控股公司）、Genever Holdings LLC（热内维尔控股有限责任公司）、Gnews Media Group Inc.（Gnews媒体集团公司）、G Fashion LLC（G时尚有限责任公司）、Gmusic LLC（G音乐有限责任公司）、Gnews LLC（Gnews有限责任公司）、Geducation（G教育）、GFNY, Inc.（GFNY公司）、G-Club Investments Limited（G俱乐部投资有限公司）、G Club Operations LLC（G俱乐部运营有限责任公司）、G Club US Operations Inc.（G俱乐部美国运营公司）、G Club US Operations LLC（G俱乐部美国运营有限责任公司）、G Live, LLC（G直播有限责任公司）、Gbroadcast, LLC（G广播有限责任公司）、Gposts LLC（G帖子有限责任公司）、HCHK Property\n\nCase 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 282 of 1063\n\nManagement, Inc.（HCHK物业管理公司）、HCHK Technologies, Inc.（HCHK科技公司）、FMV Ltd./Freedom Media Venture Ltd.（FMV有限公司/自由媒体创投有限公司）、Roscalitar 2（罗斯卡利塔尔2）、Himalaya New World Inc.（喜马拉雅新世界公司）、US Himalaya Capital Inc.（美国喜马拉雅资本公司）、Hudson Diamond Holding, Inc.（哈德逊钻石控股公司）、Hudson Diamond Holding LLC（哈德逊钻石控股有限责任公司）、Hudson Diamond NY LLC（哈德逊钻石纽约有限责任公司）、Infinity Treasury Management Inc.（无限资金管理公司）、Lexington Property and Staffing, Inc.（列克星敦物业与人事公司）、AI Group Holdings Inc.（AI集团控股公司）、Hamilton Capital Holdings Inc.（汉密尔顿资本控股公司）、Booming Sail New York LLC（兴盛帆船纽约有限责任公司）、Himalaya Ventures LLC（喜马拉雅创投有限责任公司）、Himalaya Ventures LLC（喜马拉雅创投有限责任公司）、Himalaya Investment LLC（喜马拉雅投资有限责任公司）、New York MOS Himalaya LLC（纽约MOS喜马拉雅有限责任公司）、MOS Himalaya LLC（MOS喜马拉雅有限责任公司）、Crane Advisory Group（克兰咨询集团）、Maywind Trading LLC（五月风贸易有限责任公司）、Gettr USA, Inc.（Gettr美国公司）、Han Chunguang（韩春光）、Bingshang Jiao（焦冰上）、Karin Maistrello（卡琳·迈斯特雷洛）、Mary Jiang（江玛丽）、Jiaming Liu（刘佳明）及 Wencong Wang（王文聪），分别及合称。\n\n8. “包括”或其任何变体，意为“包括但不限于”。\n\n9. “和”及“或”意为“和/或”，并应同时解释为连词及选择词，以最大限度扩大其范围。\n\n10. “任何”、“全部”及“每一”均意为“每一及全部”。\n\n11. “每一”及“每个”均意为“每一及全部”。\n\n12. “第三方”系指您本人以外的个人或实体。\n\n13. “转让”具有《破产法》第 101(54) 条所赋予的含义。\n\n14. “文件”系指属于 Fed. R. Civ. P. 34 范围内的任何信息或物品，并包括但不限于曾处于或现处于您的占有、保管或控制之下的任何种类、类型、性质或描述的每一份书面、记录或图形材料，包括电子邮件的所有纸质及电子副本、以电子形式保存的计算机文件、通信函件、备忘录、磁带、速记或手写笔记、任何种类的书面表格、图表、蓝图、图纸、草图、曲线图、计划、文章、规格、日记、信函、\n\nCase 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 283 of 1063\n\n电报、照片、会议记录、合同、协议、调查资料、计算机打印件、任何种类的数据汇编、电传、传真、电子邮件、短信、即时消息、语音消息、发票、订购单、支票、汇票、结算单、贷项通知单、报告、头寸报告、摘要、索引、书籍、账簿、笔记本、时间表、透明胶片、录音、目录、广告、宣传材料、影片、录像带、录音带、CD、计算机磁盘、宣传册、小册子、穿孔卡、工时单、推文、社交媒体帖子或任何其他种类的书面或记录材料，以及其全部元数据，无论其以何种方式存储（无论为有形形式或电子形式）、记录、制作或复制；还包括但不限于前述任何文件的草稿或副本，如其中载有原始文件中未载有的任何种类的笔记、评论或标记，或以其他方式与原始文件不相同。\n\n15. “人员”系指个人、公司、独资企业、合伙企业、协会或任何其他实体。“人员”还包括任何代理人、代表或专家，包括但不限于律师或财务顾问。\n\n16. “实体”系指任何自然人、公司、合伙企业、子公司、独资企业、商号、董事会、合资企业、协会、机构、主管机关、委员会或其他商业实体或法人，以及任何关联方、代理人、母公司，包括但不限于律师、财务顾问或任何其他代表。\n\n17. “关于”系指涉及、描述、构成、提及、与之相关、支持、赞成、反对、加强、削弱、载于、结合考虑、与之有关、证明、表明、报告、记录、暗指、回应、与之相连、评论、就其而言、有关、与之相关、讨论、展示、描述、反映、分析、构成及属于。\n\nCase 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 284 of 1063\n\n18. 当提及任何特定事项时，“与……有关”、“涉及”或“相关”系指，包括但不限于，构成、组成、涉及、包含、体现、反映、识别、陈述、直接或间接提及，或以任何方式与所识别的特定事项相关的任何文件。\n\n19. “通信”系指以最广义且不限于任何形式的信息或知识传递（包括事实、观点、询问或其他形式）。通信还指所有面对面、通过电话、书面或借助电子传输设备进行的谈话、协议、询问或答复，包括但不限于所有信函、电子邮件、录音、传输单、备忘录、电话通信、语音留言、电报、传真、影印传真、电传、即时消息、聊天、短信、在留言板或群聊中的发布、社交媒体帖子、推文、上传至任何视频平台的视频、电话记录，或在内部或与第三方之间传送的记录。\n\n20. “资产”系指任何受占有、保管或控制的具有经济价值的项目。资产包括所有不动产和动产，包括但不限于房地产、土地、房屋、公寓、共管公寓、汽车、游艇、船只、飞机、喷气式飞机、直升机、现金、银行账户、加密货币、证券、应收账款、存货以及其他有形和无形财产。\n\nIV. 应提交的文件\n\n1. 与由任何2004年调查对象持有、控制、代表其持有或以其他方式与其相关的任何账户有关的所有文件，包括任何及所有账户对账单、授权书、授权委托书、信托、指示或表格、已注销支票副本、通信，以及电汇和相关通信及指示。\n\nCase 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 285 of 1063\n\n2. 与属于、由任何2004年调查对象持有、控制、代表其持有或以其他方式与其相关的任何资金、证券、财产或资产有关的所有文件，包括任何及所有账户对账单、授权书、授权委托书、信托、指示或表格、已注销支票副本、通信，以及电汇和相关通信及指示。\n\n3. 与同任何2004年调查对象进行的任何商业、贸易或金融交易有关的所有文件，包括但不限于任何贷款、信贷额度、寄托、存款、掉期、证券交易、抵押贷款或ISDA，包括任何及所有账户对账单、授权书、授权委托书、信托、指示或表格、已注销支票副本、通信，以及电汇和相关通信及指示。\n\n4. 与2004年调查对象有关的任何电汇活动有关的所有文件，不论是否存在任何账户，包括但不限于所有电汇收据、账号、余额、授权、与转账当事方有关的身份识别信息、通信、指示或其他记录。\n\n5. 与您和2004年调查对象之间的任何函件及通信有关的所有文件。\n\n6. 与任何2004年调查对象开立账户、账户获授权使用人及账户维护有关的任何账户的所有文件。\n\n7. 与任何2004年调查对象有关的任何反洗钱、了解你的客户或其他合规活动有关的所有文件，包括但不限于任何2004年调查对象提供的信息，或您所获知的信息。\n\n8. 与任何国家的任何监管机构就任何2004年调查对象进行的通信有关的所有文件，包括但不限于英格兰银行、美国联邦储备系统、美国证券交易委员会、美国商品期货交易委员会、美国金融业监管局、中国证券监督管理委员会、中国人民银行、香港证券及期货事务监察委员会及香港金融管理局。\n\nCase 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 287 of 1063\n\n附件C-15\n\nB2540（表格2540——规则2004审查传票）（12/15）Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 288 of 1063\n\nUNITED STATES BANKRUPTCY COURT（美国破产法院）\n\nDistrict of Connecticut（康涅狄格州联邦地区）\n\n关于 HO WAN KWOK（郭文贵）等人案，\n\n1 Case No. 22-50073 (JAM)\n\n债务人 第11章\n\n（联合管理）\n\n规则2004审查传票\n\n致：The Bank of Princeton（普林斯顿银行）\n\n（传票所指向人员的姓名）\n\n证言：兹命令您于下列载明的时间、日期和地点出席，根据《联邦破产程序规则》第2004条接受审查并作证。随附授权进行该审查的法院命令副本。\n\n地点　日期和时间\n\nPaul Hastings LLP（保罗·哈斯廷斯律师事务所）\n200 Park Avenue　[TBD]\nNew York, New York 10166\n\n审查将采用以下方式记录：法院记录员/速记员\n\n提交：您或您的代表还必须在审查时随身携带下列文件、电子存储信息或物品，并须允许对该材料进行检查、复制、测试或取样：\n\n见随附的文件提交请求。\n\n《联邦民事诉讼规则》第45条的下列规定，经《联邦破产程序规则》第9016条规定适用于破产案件，随附于此——关于履行地点的第45(c)条；关于作为传票对象的您所受保护的第45(d)条；以及关于您回应本传票的义务和未作回应的潜在后果的第45(e)条和第45(g)条。\n\n日期：March , 2023\n\n法院书记官\n\n或\n\n书记官或副书记官签名　律师签名\n\n签发或请求本传票、代表第11章受托人 Luc A. Despins（卢克·A·德斯平斯）的律师姓名、地址、电子邮件地址和电话号码如下：\n\nDouglas S. Skalka, Esq.（道格拉斯·S·斯卡尔卡律师）；Neubert, Pepe & Monteith, P.C.（诺伊伯特、佩佩和蒙蒂思专业公司）；195 Church Street, New Haven, Connecticut 06510 dskalka@npmlaw.com；(203) 821-2000\n\n致签发或请求本传票者的通知\n\n如本传票命令在审判前提交文件、电子存储信息或有形物品，或检查场所，则必须在向传票所指向人员送达之前，向各方送达通知及本传票副本。Fed. R. Civ. P. 45(a)(4)。\n\n软件版权（c）1996-2022 Best Case, LLC（贝斯特凯斯有限责任公司）- www.bestcase.com Best Case Bankruptcy 1 本第11章案件中的债务人为 Ho Wan Kwok（郭文贵，亦称 Guo Wengui、Miles Guo 和 Miles Kwok，以及诸多其他别名）（税务识别号码末四位：9595）、Genever Holdings LLC（税务识别号码末四位：8202）及 Genever Holdings Corporation。受托人、Genever Holdings LLC 和 Genever Holdings Corporation 的邮寄地址为 Paul Hastings LLP, 200 Park Avenue, New York, NY 10166，转交作为 Ho Wan Kwok 遗产受托人的 Luc A. Despins（仅为通知和通信之目的）。\n\n送达证明\n\n（除非 Fed. R. Civ. P. 45 要求，否则本节不应向法院提交。）\n\n我于（日期）收到向（个人姓名及职务，如有）送达的本传票。\n\n我通过如下方式将传票副本交付给具名人员，完成送达：\n\n于（日期）；或\n\n我未执行传票即予退回，原因如下：\n\n除非该传票代表美国或其官员或代理人签发，我还已向证人支付一天出席费用及法律允许的里程费用，金额为 \\$ 。\n\n我的差旅费用为 \\$，服务费用为 \\$，合计 \\$ 。\n\n我在伪证罪处罚下声明，该信息真实且正确。\n\n日期：\n\n送达人签名\n\n正楷姓名及职务\n\n送达人地址\n\n有关尝试送达等事项的补充信息：\n\n《联邦民事诉讼规则》第45(c)、(d)、(e)和(g)条（Effective 12/1/13）（经《联邦破产程序规则》第9016条规定适用于破产案件）\n\n(c) 履行地点。\n\n(1) 审判、听证或证言录取。传票仅可按下列方式命令人员出席审判、听证或证言录取：\n\n(A) 在该人员居住、受雇或经常亲自从事业务所在地100英里范围内；或\n\n(B) 在该人员居住、受雇或经常亲自从事业务所在州内，如该人员：\n\n(i) 为当事人或当事人的高级职员；或\n\n(ii) 被命令出席审判，且不会产生重大费用。\n\n(2) 其他调查取证。传票可命令：\n\n(A) 在该人员居住、受雇或经常亲自从事业务所在地100英里范围内的地点提交文件、电子存储信息或物品；以及\n\n(B) 在待检查场所对其进行检查。\n\n(d) 对作为传票对象的人员的保护；执行。\n\n(1) 避免不当负担或费用；制裁。负责签发和送达传票的当事人或律师必须采取合理措施，避免对传票对象施加不当负担或费用。要求履行的地区法院必须执行该义务，并对未遵守者——当事人或律师——施加适当制裁，其中可包括收入损失和合理的律师费。\n\n(2) 命令提交材料或允许检查。\n\n(A) 无须出席。被命令提交文件、电子存储信息或有形物品，或允许检查场所的人员，无须亲自出现在提交或检查地点，除非同时被命令出席证言录取、听证或审判。\n\n(B) 异议。被命令提交文件或有形物品，或允许检查的人员，可以向传票中指定的当事人或律师送达书面异议，反对检查、复制、测试或取样任何或全部材料，或反对检查场所，或反对以所要求的一种或多种形式提交电子存储信息。异议必须在规定履行时间届满前或传票送达后14日内（以较早者为准）送达。如提出异议，适用下列规则：\n\n(i) 送达方可随时在通知被命令人员后，向要求履行的地区法院提出动议，申请命令强制提交或检查。\n\n(ii) 只有依命令指示方可要求实施这些行为，且该命令必须保护非当事人亦非当事人高级职员的人员，使其免受因履行而产生的重大费用。\n\n(3) 撤销或修改传票。\n\n(A) 必须撤销或修改的情形。经及时动议，要求履行的地区法院必须撤销或修改符合下列情形的传票：\n\n(i) 未给予合理的履行时间；\n\n(ii) 要求人员在第45(c)条规定的地域限制以外履行；\n\n(iii) 要求披露享有特权或受其他保护的事项，且不适用任何例外或放弃；或\n\n(iv) 对人员施加不当负担。\n\n(B) 可以撤销或修改的情形。为保护作为传票对象或受传票影响的人员，要求履行的地区法院可依动议撤销或修改要求下列事项的传票：\n\n(i) 披露商业秘密或其他保密的研究、开发或商业信息；或\n\n(ii) 披露未受聘专家的意见或信息，该等意见或信息并未描述争议中的具体事件，且源于未经当事人请求的该专家研究。\n\n(C) 规定条件作为替代措施。在第45(d)(3)(B)条所述情形下，如送达方：\n\n(i) 证明其对该证言或材料具有重大需要，且无法在不遭受不当困难的情况下以其他方式满足该需要；以及\n\n(ii) 确保被传唤人员将获得合理补偿，\n\n法院可不撤销或修改传票，而命令在规定条件下出席或提交。\n\n(e) 回应传票的义务。\n\n(1) 提交文件或电子存储信息。下列程序适用于提交文件或电子存储信息：\n\n(A) 文件。对要求提供文件的传票作出回应的人，必须按照文件在正常业务过程中保存的方式提供文件，或者必须将文件整理并标记，以对应请求中的类别。\n\n(B) 未指定的电子存储信息提供形式。如果传票未指定提供电子存储信息的形式，作出回应的人必须以其通常保存的某一种或多种形式，或以一种或多种合理可用的形式提供该信息。\n\n(C) 电子存储信息仅以一种形式提供。作出回应的人无需以一种以上的形式提供相同的电子存储信息。\n\n(D) 无法访问的电子存储信息。作出回应的人无需就其认定因不当负担或成本而无法合理访问的来源中的电子存储信息提供证据开示。在提出强制证据开示动议或申请保护令时，作出回应的人必须证明该信息因不当负担或成本而无法合理访问。如果作出该等证明，法院在考虑 Rule 26(b)(2)(C) 的限制后，如请求方证明具有正当理由，仍可命令从该等来源进行证据开示。法院可以规定证据开示的条件。\n(2) 主张特权或保护。\n\n(A) 扣留的信息。依据该信息享有特权或作为审判准备材料受到保护的主张而扣留被传唤信息的人，必须：(i) 明确提出该主张；并且\n\n(ii) 以一种在不披露本身享有特权或受保护信息的情况下，足以使各方评估该主张的方式，描述被扣留文件、通信或有形物品的性质。\n\n(B) 已提供的信息。如果为响应传票而提供的信息受到特权主张或作为审判准备材料受到保护的主张约束，提出该主张的人可以将该主张及其依据通知任何收到该信息的一方。收到通知后，一方必须立即返还、隔离或销毁所指明的信息及其持有的任何副本；在该主张得到解决前，不得使用或披露该信息；如该方在收到通知前已披露该信息，必须采取合理措施追回该信息；并且可以立即将该信息密封提交给要求履行所在地区的法院，以裁定该主张。提供该信息的人必须在该主张得到解决前保存该信息。\n\n(g) 藐视法庭。要求履行所在地区的法院，以及在动议移送后作出传票的法院，均可对已被送达但无充分理由未遵守传票或与之相关命令的人以藐视法庭论处。\n\n有关传票材料的查阅，请参见 Fed.R.Civ.P.45(a) Committee Note (2013)\n\n…\n\n文件提供请求\nI. 指示\n\n1. 除非另有说明，下列文件请求（以下简称“请求”，单称为“一项请求”）必须分别且具体地作出回应。除非善意地提出异议，否则必须对每项请求作出完整答复；如提出异议，应按如下规定详细说明贵方异议的理由。如果异议仅涉及一项请求的一部分，或其中包含的一个词、短语或条款，贵方仅须说明对该部分的异议，并对其余请求作出回应。\n\n2. 电子存储信息必须依照下列指示提供：\n\na. 图像。黑白图像必须为 300 DPI Group IV 单页 TIFF 文件。彩色图像必须以 JPEG 格式提供。文件名不得包含嵌入空格或特殊字符（包括逗号）。文件夹名称不得包含嵌入空格或特殊字符（包括逗号）。所有 TIFF 图像文件必须具有唯一的文件名，即 Bates 编号。每幅图像的右下角必须加注连续的 Bates 编号。每个文件夹中的 TIFF 文件数量不得超过 1000 个。Excel 电子表格应具有以该文件的 Bates 编号命名的占位图像。\n\nb. 图像加载文件\n\na. Concordance® 数据文件。数据文件（.DAT）包含将被加载至 Concordance® 数据库的所有字段化信息。.DAT 文件的第一行必须为标识字段名称的标题行。.DAT 文件必须使用以下 Concordance® 默认分隔符：逗号 ASCII 字符（020）；引号 þ ASCII 字符（254）。日期字段应以如下格式提供：mm/dd/yyyy。日期和时间字段必须为两个独立字段。如文件包括已成像的电子邮件及附件，必须包括附件字段，以保留电子邮件与其附件之间的父项/子项关系。必须包括 OCRPATH 字段，以提供所提供存储介质上提取文本文件的文件路径和名称。文本文件必须以 FIRSTBATES 命名。不得在 .DAT 文件中包括文本。对于带有原生文件的文件，必须包括 LINK 字段，以提供原生文件的文件路径和\n\n名称。原生文件必须以 FIRSTBATES 命名。\n\nb. Concordance Image® 或 Opticon 交叉引用文件。图像交叉引用文件（.LOG 或 .OPT）将图像链接至数据库记录。该文件应为逗号分隔文件，每行由七个字段构成，并且数据库中的每幅图像均应在交叉引用文件中有一行，格式如下：ImageID,VolumeLabel,ImageFilePath,DocumentBreak,FolderBreak,Box Break,PageCoun。\n\nc. 文件文本。文本必须作为单独的文本文件提供，而非作为 .DAT 文件内的字段。文本文件的完整路径（OCRPATH）应包括在 .DAT 文件中。建议提供文件级 ANSI 文本文件，并按 FIRSTBATES/Image Key 命名。提取的文本文件必须置于单独文件夹内，每个文件夹中的文本文件数量不得超过 1,000 个。文件夹名称中不得包含特殊字符（包括逗号）。必须在文件级别提供文本文件。\n\nd. 特定文件类型的原生文件提供。为充分理解其内容和含义而合理需要以原生格式查看的文件类型，必须以原生格式提供。这些文件包括但不限于电子表格、类似电子表格的文件（Microsoft Excel、逗号分隔值、制表符分隔值等）、Microsoft PowerPoint 或其他特殊演示文件、数据库文件以及音频/视频文件。应提供一幅带有 Bates 编号的提示页图像，以表明原生文件的存在，并将原生文件路径作为字段包括在 .dat 文件中。所提供的原生文件应以与该文件提示页相对应的 Bates 编号命名。应将原生文件归入按递增方式命名的“NATIVE”目录，与图像目录分开。\n\ne. 去重。对于存在完全相同副本的每份电子文件，仅提供一份副本。对于电子邮件，应基于从 BCC、Body、CC、From、IntMsgID、To 和 Attach 属性生成的 MD5 哈希值合并重复件。对于电子邮件附件和独立电子文件，应基于整个文件的 MD5 哈希值合并重复件。\n\nf. 元数据。以符合 Concordance 的加载文件（.dat）形式提供每份文件的提取元数据。.DAT 文件的第一行必须为标识字段名称的标题行。.DAT 文件必须使用以下 Concordance 默认分隔符：逗号 , ASCII 字符（020）；引号 þ ASCII 字符（254）\n\n日期字段应以如下格式提供：mm/dd/yyyy。日期和时间字段必须为两个独立字段。以下列出必需的元数据：\nCase 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 293 of 1063\n\n字段名称　示例数据　说明\n\nFIRSTBATES　EDC0000001　原生文件文件/电子邮件的第一个 Bates 编号\nLASTBATES　EDC0000001　原生文件文件/电子邮件的最后一个 Bates 编号\nLASTBATES 字段应针对单页文件填写\nATTACHRANGE　EDC0000001\n-　父文件第一页的 Bates 编号至最后一个附件“子项”文件最后一页的 Bates 编号\nEDC0000015\nBEGATTACH　EDC0000001　附件范围的第一个 Bates 编号\nENDATTACH　EDC0000015　附件范围的最后一个 Bates 编号\nCUSTODIAN　Smith, John　电子邮件：电子邮件所在的邮箱\n原生文件：文件来源的个人或部门名称\nFROM　John Smith　电子邮件：发件人\n原生文件：文件作者\n应使用分号分隔多个条目\nTO　Coffman, Janice; LeeW　收件人\n[mailto:LeeW@MSN.com]　应使用分号分隔多个条目\nCC　Frank Thompson [mailto:　抄送收件人\nfrank_Thompson@cdt.com]　应使用分号分隔多个条目\nBCC　John Cain　密送收件人\n应使用分号分隔多个条目\nSUBJECT　Board Meeting Minutes　电子邮件：电子邮件主题行；原生文件：文件标题（如有）\nFILE_NAME　BoardMeetingMinutes.docx　原生文件：原始原生文件的名称，包括扩展名\nDATE_SENT　10/12/2010　电子邮件：电子邮件发送日期\n原生文件：（空）\nTIME_SENT/\nTIME_ZONE　07:05 PM GMT　电子邮件：电子邮件发送时间/电子邮件标准化所采用的时区\nTIME_ZONE　GMT　在转换过程中电子邮件被标准化所采用的时区。\nLINK　EDC0000001.msg　电子邮件或原生文件文件的超链接\n链接文件必须按 FIRSTBATES 编号命名\nFILE_EXTEN　MSG　表示电子邮件或原生文件的文件类型扩展名\nAUTHOR　John Smith　电子邮件：（空）\n原生文件：文件作者\nDATE_CREATED　10/10/2010　电子邮件：（空）\n原生文件：文件创建日期\nCase 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 294 of 1063\n\nTIME_CREATED　10:25 AM　电子邮件：（空）\n\n原生文件：文件创建时间\n该数据必须为独立字段，不得与 DATE_CREATED 字段合并\nDATE_MOD　10/12/2010　电子邮件：（空）\n原生文件：文件最后修改日期\nTIME_MOD　07:00 PM　电子邮件：（空）\n原生文件：文件最后修改时间\n该数据必须为独立字段，不得与 DATE_MOD 字段合并\nDATE_ACCESSD　10/12/2010　电子邮件：（空）\n原生文件：文件最后访问日期\nTIME_ACCESSD　07:00 PM　电子邮件：（空）\n原生文件：文件最后访问时间\n该数据必须为独立字段，不得与 DATE_ACCESSD 字段合并\nFILE_SIZE　5,952　原生文件文件/电子邮件的大小，以 KB 计\nPGCOUNT　1　原生文件文件/电子邮件中的页数\nPATH　电子邮件：（空）\nAgenda.doc　原生文件：存储原生文件文件的路径，包括原始文件名。\nINTFILEPATH　Personal Folders\\Deleted　电子邮件：电子邮件的原始位置，包括原始文件名。\nItems\\Board Meeting\nMinutes.msg　原生文件：（空）\nINTMSGID　<000805c2c71b\\$75977050\\$　电子邮件：唯一邮件 ID；原生文件：（空）\ncb8306d1@MSN>\nMD5HASH　d131dd02c5e6eec4693d9a0　文件的 MD5 哈希值。\n698aff95c\n2fcab58712467eab4004583e\nb8fb7f89\nOCRPATH　TEXT/001/EDC0000001.txt　原生文件提取文本的路径\n\n3. 每项请求均独立适用并应独立解释，除非另有说明，任何一项请求均不限制任何其他请求的范围。\n\n4. 所有文件应按照其在通常业务过程中保存的方式提供，或者应予以整理并标记，以对应本请求中的类别。\n\n5. 本文所载每项请求均延及所有文件：(a) 由贵方占有、保管或控制的文件；或 (b) 由代表贵方行事的任何人占有、保管或控制的文件，\nCase 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 295 of 1063\n\n包括贵方的律师或其他代表和顾问。每份文件均应完整提供。\n\n6. 如要求贵方提交一份已不再由贵方占有、保管或控制的文件，则贵方的答复必须：(a) 详细描述该文件的性质及其内容；(b) 确定编制或撰写该文件的人员（以及，如适用，该文件被发送至的人员）；(c) 确定该文件编制或形成的日期；(d) 说明该文件是否：(i) 遗失或丢失，(ii) 已被销毁，(iii) 已自愿或非自愿地转交他人，或 (iv) 以其他方式被处置；(e) 说明该等处置的理由，以及围绕该等处置的事实和情形；(f) 确定授权该等处置的人员；(g) 确定该等处置的日期或约略日期；(h) 说明该文件最近一次由贵方占有、保管或控制的时间；以及 (i) 确定目前占有、保管或控制该文件的人员（如有）。\n\n7. 如要求贵方提交一份已被销毁的文件，则除前述指示所要求的信息外，贵方的答复还必须说明：(a) 销毁该文件的理由；(b) 销毁该文件的人员身份；以及 (c) 指示销毁该文件的人员身份。\n\n8. 如贵方主张某一被请求的文件享有特权或属于律师工作成果，则贵方的答复必须：(a) 说明：(i) 足以支持贵方关于该文件享有特权之主张的文件描述，(ii) 文件标题，(iii) 文件日期，(iv) 文件作者，(v) 文件收件人，(vi) 收到或阅览该文件原件或任何草稿、副本或复制件的每一人员身份，(vii) 该文件本身或文件所载或所提及的任何信息是否由任何其他人员占有、保管或控制；如是，则该等人员的身份，\n案件 22-50073 文件 1592 于 03/24/23 提交，于 03/24/23 10:57:37 登记，第 296 页，共 1063 页\n以及说明该等信息如何进入其占有范围，(viii) 据以不提交该文件的特权主张，以及 (ix) 贵方将据以支持该等特权主张的所有情形；以及 (b) 就根据 D. Conn. L. Civ. R. 26(e) 基于特权主张而不予提交的每一文件，提交一份载有本指示第 (a) 部分所要求全部信息的特权日志。对于文件请求中未主张特权或工作成果的任何部分，应完整提供符合请求的文件。\n\n9. 如一份原本符合请求的文件的一部分包含受特权主张约束的信息，则仅应按照上述指示从该文件中删除或遮蔽受该特权主张约束的部分，其余部分应予提交。\n\n10. 该等请求具有持续性。特此指示贵方：(a) 一旦得知先前答复不完整或不正确，应立即补充或更正任何后来得知不完整或不正确的答复；以及 (b) 提交根据下述规定所要求的任何额外文件。\n\n11. 如一份文件使用英语以外的语言，贵方应提供该文件。如一份文件使用英语以外的语言，且存在英文译本，贵方应同时提供两份文件。\n\n12. 对实体的所有提及均包括其所有关联方。\n\n13. 对个人姓名的所有提及均包括所有其他姓名、别名或昵称。\n案件 22-50073 文件 1592 于 03/24/23 提交，于 03/24/23 10:57:37 登记，第 297 页，共 1063 页\n\n14. 除非另有明确说明，文件请求所涵盖的期间为自 February 5, 2012 起至文件请求答复到期之日止。\n\nII. 解释规则\n\n15. (a) 任何单数名词的使用应解释为包括复数，反之亦然；以及 (b) 任何时态动词的使用应解释为该动词所有其他时态的使用。\n\n16. (a) “and”和“or”应在必要时解释为连言或选言，以将原本可能被解释为超出任何请求范围的所有答复纳入该请求范围；以及 (b) “each”和“any”应视为包括并涵盖“every”和“all”二词。\n\nIII. 定义\n\n经 D. Conn. Bankr. L.R. 2004-1(a) 纳入的 D. Conn. L. Civ. R. 26(c) 所规定的定义，以及 D. Conn. L. Civ. R. 26(d) 所规定的解释规则，适用于该等文件请求。此外，本文件请求中使用的下列术语具有以下含义：\n\n1. “You”或“Your”或“Yourself”是指 The Bank of Princeton（普林斯顿银行）及其所有关联方。\n\n2. “Debtor”是指 Ho Wan Kwok（郭文贵）（又名 Miles Kwok（郭文贵）、Miles Guo（郭文贵）、Guo Wengui（郭文贵）、Guo Haoyun、郭文贵或任何其他别名），及其雇员、代理人、律师、顾问或任何代表其行事的人。\n\n案件 22-50073 文件 1592 于 03/24/23 提交，于 03/24/23 10:57:37 登记，第 298 页，共 1063 页\n\n3. “Debtor's Son”是指 Qiang Guo（郭强）（又名 Mileson Kwok（郭强）、郭强或任何其他别名），及其雇员、代理人、律师、顾问或任何代表其行事的人。\n\n4. “Debtor's Daughter”是指 Mei Guo（郭美）（又名 Mei Gui（郭美）、郭美或任何其他别名），及其雇员、代理人、律师、顾问或任何代表其行事的人。\n\n5. “Debtor's Purported Wife”是指 Hing Chi Ngok（岳庆芝）（又名 Hing Chi Ng、Yue Qingzhi（岳庆芝）、岳庆芝或任何其他别名），及其雇员、代理人、律师、顾问或任何代表其行事的人。\n\n6. “Debtor's Family”单独及共同地指债务人、债务人之子、债务人之女及债务人所谓的妻子，以及与债务人具有其他亲属关系的任何人。\n\n7. “2004 Discovery Targets”单独及共同地指债务人、债务人家属、ACA Capital Group Limited（ACA资本集团有限公司）、Himalaya International Financial Group Ltd.（喜马拉雅国际金融集团有限公司）、Himalaya International Clearing Ltd.（喜马拉雅国际清算有限公司）、Himalaya International Payments Ltd.（喜马拉雅国际支付有限公司）、Himalaya International Reserves Ltd.（喜马拉雅国际储备有限公司）、Jesse Brown（杰西·布朗）、William Je（威廉·杰）、William Je（威廉·杰）、Eastern Profit Corporation Limited（东方利润有限公司）、HK International Funds Investments (USA) Limited LLC（香港国际基金投资〈美国〉有限责任公司）、Bravo Luck Limited（好运有限公司）、Golden Spring (New York) Ltd.（金泉〈纽约〉有限公司）、Lamp Capital LLC（兰普资本有限责任公司）、Greenwich Land LLC（格林尼治土地有限责任公司）、Qu Guo Jiao、Daniel Thomas Podhaskie（丹尼尔·托马斯·波德哈斯基）、Yvette Wang（王燕平）（又名 Yanping Wang（王燕平）、又名 Yan Ping Wang（王燕平））、Ace Decade Holdings Limited（王牌十年控股有限公司）、Dawn State Limited（黎明州有限公司）、Rule of Law Society IV Inc.（法治协会IV公司）、Rule of Law Foundation III, Inc.（法治基金会III公司）、Rule of Law Foundation IV, Inc.（法治基金会IV公司）、Rule of Law Fund（法治基金）、Rule of Law Society（法治协会）、GTV Media Group, Inc.（GTV媒体集团公司）、Voice of Guo Media, Inc.（郭之声媒体公司）、Saraca Media Group Inc.（萨拉卡媒体集团公司）、Genever Holdings Corporation（吉尼弗控股公司）、Genever Holdings LLC（吉尼弗控股有限责任公司）、Gnews Media Group Inc.（Gnews媒体集团公司）、G Fashion LLC（G时尚有限责任公司）、Gmusic LLC（G音乐有限责任公司）、Gnews LLC（Gnews有限责任公司）、Geducation（G教育）、GFNY, Inc.（GFNY公司）、G-Club Investments Limited（G俱乐部投资有限公司）、G Club Operations LLC（G俱乐部运营有限责任公司）、G Club US Operations Inc.（G俱乐部美国运营公司）、G Club US Operations LLC（G俱乐部美国运营有限责任公司）、G Live, LLC（G直播有限责任公司）、Gbroadcast, LLC（G广播有限责任公司）、Gposts LLC（G帖子有限责任公司）、HCHK Property\n案件 22-50073 文件 1592 于 03/24/23 提交，于 03/24/23 10:57:37 登记，第 299 页，共 1063 页\nManagement, Inc.（HCHK物业管理公司）、HCHK Technologies, Inc.（HCHK科技公司）、FMV Ltd./Freedom Media Venture Ltd.（FMV有限公司／自由媒体创投有限公司）、Roscalitar 2、Himalaya New World Inc.（喜马拉雅新世界公司）、US Himalaya Capital Inc.（美国喜马拉雅资本公司）、Hudson Diamond Holding, Inc.（哈德逊钻石控股公司）、Hudson Diamond Holding LLC（哈德逊钻石控股有限责任公司）、Hudson Diamond NY LLC（哈德逊钻石纽约有限责任公司）、Infinity Treasury Management Inc.（无限财务管理公司）、Lexington Property and Staffing, Inc.（列克星敦物业及人力配置公司）、AI Group Holdings Inc.（AI集团控股公司）、Hamilton Capital Holdings Inc.（汉密尔顿资本控股公司）、Booming Sail New York LLC（兴盛航帆纽约有限责任公司）、Himalaya Ventures LLC（喜马拉雅创投有限责任公司）、Himalaya Ventures LLC（喜马拉雅创投有限责任公司）、Himalaya Investment LLC（喜马拉雅投资有限责任公司）、New York MOS Himalaya LLC（纽约MOS喜马拉雅有限责任公司）、MOS Himalaya LLC（MOS喜马拉雅有限责任公司）、Crane Advisory Group（克兰咨询集团）、Maywind Trading LLC（五月风贸易有限责任公司）、Gettr USA, Inc.（Gettr美国公司）、Han Chunguang（韩春光）、Bingshang Jiao、Karin Maistrello、Mary Jiang、Jiaming Liu、以及 Wencong Wang。\n\n8. “Including”或其任何变体意为“包括但不限于”。\n\n9. “And”和“or”意为“and/or”，并应被解释为既可连言亦可选言，以最大限度扩大其范围。\n\n10. “Any”、“all”和“each”意为“每一个和所有”。\n\n11. “Each”和“every”意为“每一个和所有”。\n\n12. “Third Party”是指贵方以外的人员或实体。\n\n13. “Transfer”具有《破产法》第 101(54) 条赋予该词的含义。\n\n14. “Document”是指属于 Fed. R. Civ. P. 34 范围内的任何信息或物品，并包括但不限于贵方曾经或目前占有、保管或控制的任何种类、类型、性质或描述的每一项书面、记录或图形材料，包括电子邮件的所有纸质和电子副本、以电子形式保存的计算机文件、通信函件、备忘录、磁带、速记或手写笔记、任何种类的书面表格、图表、蓝图、绘图、草图、图形、计划、文章、规格、日记、信函、\n案件 22-50073 文件 1592 于 03/24/23 提交，于 03/24/23 10:57:37 登记，第 300 页，共 1063 页\n电报、照片、会议记录、合同、协议、调查、计算机打印件、任何种类的数据汇编、电传、传真、电子邮件、短信、即时消息、语音消息、发票、订购单、支票、汇票、对账单、贷项通知单、报告、头寸报告、摘要、索引、书籍、账簿、笔记本、附表、透明胶片、录音、目录、广告、宣传材料、电影、录像带、录音带、CD、计算机磁盘、小册子、宣传册、穿孔卡、工时单、推文、社交媒体帖子或任何其他种类的书面或记录材料，以及其所有元数据，无论以何种方式存储（无论为有形或电子形式）、记录、制作或复制；还包括但不限于前述任何文件的草稿或副本，如其包含原件中未见的任何种类的笔记、评论或标记，或在其他方面与原件不相同。\n\n15. “Person(s)”是指个人、公司、独资企业、合伙企业、协会或任何其他实体。“Person”还包括任何代理人、代表或专家，包括但不限于律师或财务顾问。\n\n16. “Entity”是指任何自然人、公司、合伙企业、子公司、独资企业、商号、董事会、合资企业、协会、机构、主管机关、委员会或其他商业实体或法人，以及任何关联方、代理人、母公司，包括但不限于律师、财务顾问或任何其他代表。\n\n17. “Regarding”是指有关、描述、包含、提及、与之相关、支持、有利于、反对、加强、削弱、位于、结合考虑、对其具有影响、证明、表明、报告、记录、暗指、答复、与之关联、评论、就其而言、关于、与之有关、讨论、显示、描述、反映、分析、构成及属于。\n案件 22-50073 文件 1592 于 03/24/23 提交，于 03/24/23 10:57:37 登记，第 301 页，共 1063 页\n\n18. 在提及任何特定主题时，“Relating to”、“relate(s) to”或“related to”是指，包括但不限于，构成、包含、涉及、载有、体现、反映、确定、直接或间接提及，或以任何方式与所确定的特定主题相关的任何文件。\n\n19. “通信”系指在最广泛可能的意义上且不受限制地，任何信息或知识的传递（以事实、观点、询问或其他形式）。通信还指所有谈话、协议、询问或答复，无论是当面、通过电话、以书面形式，或通过电子传输设备进行，并包括但不限于所有信函、电子邮件、录音、传送单、备忘录、电话通信、语音留言、电报、电传传真、复印传真、电传、即时消息、聊天、短信、向留言板或群聊发布的帖子、社交媒体帖子、推文、上传至任何视频平台的视频、电话记录，或在内部或与第三方之间传送的记录。\n\n20. “资产”系指受占有、保管或控制的任何具有经济价值的项目。资产包括所有不动产和动产，包括但不限于房地产、土地、房屋、公寓、共管公寓、汽车、游艇、船只、飞机、喷气式飞机、直升机、现金、银行账户、加密货币、证券、应收账款、存货以及其他有形和无形财产。\n\nIV. 应提交的文件\n\n1. 与任何由任何 2004 调查目标持有、控制、代表其持有或以其他方式与其相关的账户有关的所有文件，包括任何及所有账户对账单、授权书、委托书、信托、指示或表格、已注销支票副本、信函、电汇，以及相关信函和指示。\n\n案件 22-50073 文件 1592 提交日期 03/24/23 录入日期 03/24/23 10:57:37 第 302 页，共 1063 页\n\n2. 与任何属于任何 2004 调查目标、由其持有、控制、代表其持有或以其他方式与其相关的资金、证券、财产或资产有关的所有文件，包括任何及所有账户对账单、授权书、委托书、信托、指示或表格、已注销支票副本、信函、电汇，以及相关信函和指示。\n\n3. 与任何同任何 2004 调查目标进行的商业、贸易或金融交易有关的所有文件，包括但不限于任何贷款、信贷额度、寄托、存款、互换、证券交易、抵押贷款或 ISDA，包括任何及所有账户对账单、授权书、委托书、信托、指示或表格、已注销支票副本、信函、电汇，以及相关信函和指示。\n\n4. 与涉及 2004 调查目标的任何电汇活动有关的所有文件，无论是否存在任何账户，包括但不限于所有电汇收据、账户号码、余额、授权、与转账当事人有关的身份识别信息、信函、指示或其他记录。\n\n5. 与您和 2004 调查目标之间任何信函和通信有关的所有文件。\n\n6. 与任何 2004 调查目标的任何账户有关的所有文件，涉及该账户的开立、该账户的授权使用人及该账户的维护。\n\n7. 与任何 2004 调查目标有关的任何反洗钱、了解你的客户或其他合规活动有关的所有文件，包括但不限于任何 2004 调查目标提供的任何信息，或您获悉的任何信息。\n\n8. 与任何国家的任何监管机构就任何 2004 调查目标进行的任何通信有关的所有文件，包括但不限于 Bank of England（英格兰银行）、United States Federal Reserve（美国联邦储备系统）、S.E.C.（美国证券交易委员会）、CFTC（美国商品期货交易委员会）、FINRA（美国金融业监管局）、China Securities Regulatory Commission（中国证券监督管理委员会）、People's Bank of China（中国人民银行）、Hong Kong Securities and Futures Commission（香港证券及期货事务监察委员会）和 Hong Kong Monetary Authority（香港金融管理局）。\n\n附件 C-16\n\nB2540（表格 2540——依破产程序规则 2004 审查传票）（12/15）案件 22-50073 文件 1592 提交日期 03/24/23 录入日期 03/24/23 10:57:37 第 305 页，共\n\nUNITED STATES BANKRUPTCY COURT（美国破产法院）\n\nDistrict of Connecticut（康涅狄格地区）\n\n关于 HO WAN KWOK（郭文贵）等人，\n\n1 案件编号 22-50073 (JAM) 债务人 第 11 章\n\n（合并管理）\n\n依规则 2004 审查传票\n\n致：DBS Bank Ltd.（星展银行有限公司）\n\n（传票所指向之人的姓名）\n\n证言：兹命令您于下列载明的时间、日期和地点出席，并根据《联邦破产程序规则》规则 2004 的审查作证。随附准许该审查的法院命令副本。\n\n地点　日期和时间\n\nNeubert, Pepe & Monteith, P.C.（纽伯特、佩佩与蒙蒂思专业公司）\n195 Church Street, Floor 13　[TBD]\nNew Haven, Connecticut 06510（康涅狄格州纽黑文市 06510）\n\n审查将以下述方式记录：法庭记录员/速记员\n\n提交：您或您的代表还必须在审查时携带下列文件、电子存储信息或物品，并必须准许对该等材料进行查阅、复制、测试或抽样：\n\n见随附的文件提交请求。\n\n下列《联邦民事诉讼规则》规则 45 的规定，依《联邦破产程序规则》规则 9016 适用于破产案件，现随附——有关履行地点的规则 45(c)；有关您作为受传票约束之人的保护的规则 45(d)；以及有关您回应本传票的义务及不回应的潜在后果的规则 45(e) 和 45(g)。\n\n日期：March , 2023\n\n法院书记员\n\n或\n\n书记员或副书记员签名　律师签名\n\n代表第 11 章受托人 Luc A. Despins（吕克·A·德斯平斯）并签发或请求本传票的律师之姓名、地址、电子邮件地址和电话号码如下：\n\nDouglas S. Skalka, Esq.（道格拉斯·S·斯卡尔卡，律师）；Neubert, Pepe & Monteith, P.C.（纽伯特、佩佩与蒙蒂思专业公司）；195 Church Street, New Haven, Connecticut 06510 dskalka@npmlaw.com；(203) 821-2000\n\n致签发或请求本传票之人的通知\n\n如本传票命令在审判前提交文件、电子存储信息或有形物品，或检查场所，则必须在向本传票所指向之人送达之前，向每一方送达通知及本传票副本。《联邦民事诉讼规则》规则 45(a)(4)。\n\n软件版权 (c) 1996-2022 Best Case, LLC（贝斯特凯斯有限责任公司）- www.bestcase.com Best Case Bankruptcy 1 本第 11 章案件中的债务人为 Ho Wan Kwok（郭文贵）（又称 Guo Wengui、Miles Guo 和 Miles Kwok，以及众多其他别名）（税务识别号码后四位：9595）、Genever Holdings LLC（Genever 控股有限责任公司）（税务识别号码后四位：8202）及 Genever Holdings Corporation（Genever 控股公司）。受托人、Genever Holdings LLC 和 Genever Holdings Corporation 的邮寄地址为 Paul Hastings LLP（保罗·黑斯廷斯律师事务所），200 Park Avenue, New York, NY 10166，由 Luc A. Despins 代收，其作为 Ho Wan Kwok 遗产的受托人（仅为通知和通信之目的）。\n\n送达证明\n\n（除非《联邦民事诉讼规则》规则 45 要求，否则本节不应向法院提交。）\n\n本人于（日期）收到向（个人姓名及职务，如有）发出的本传票。\n\n本人以如下方式向具名之人交付副本而送达本传票：\n\n于（日期）；或\n\n本人未予执行而退回本传票，原因如下：\n\n除非本传票代表美国或其官员或代理人签发，本人还已向证人支付一日出席费用及法律允许的里程费，金额为 $ 。\n\n本人的旅费为 $，服务费为 $，合计 $。\n\n本人声明，如有伪证，愿受处罚；上述信息真实且正确。\n\n日期：\n\n送达人员签名\n\n正楷姓名及职务\n\n送达人员地址\n\n关于尝试送达等的补充信息：\n\n《联邦民事诉讼规则》规则 45(c)、(d)、(e) 和 (g)（于 12/1/13 生效）（依《联邦破产程序规则》规则 9016 适用于破产案件）\n\n(c) 履行地点。\n\n(1) 审判、听证或证言录取。传票仅可按以下方式命令某人出席审判、听证或证言录取：\n\n(A) 在该人居住、受雇或经常亲自从事商业活动地点 100 英里以内；或\n\n(B) 在该人居住、受雇或经常亲自从事商业活动所在州内，如该人\n\n(i) 为当事人或当事人的高级职员；或\n\n(ii) 被命令出席审判且不会产生重大费用。\n\n(2) 其他证据开示。传票可命令：\n\n(A) 在该人居住、受雇或经常亲自从事商业活动地点 100 英里以内的地点，提交文件、电子存储信息或物品；以及\n\n(B) 在被检查场所对该场所进行检查。\n\n(d) 对受传票约束之人的保护；执行。\n\n(1) 避免不当负担或费用；制裁。负责签发和送达传票的当事人或律师，必须采取合理措施，避免对受传票约束之人施加不当负担或费用。要求履行的地区法院必须执行该义务，并对未遵守者的当事人或律师施加适当制裁，该制裁可包括收入损失和合理律师费。\n\n(2) 命令提交材料或准许检查。\n\n(A) 无须出席。被命令提交文件、电子存储信息或有形物品，或准许检查场所之人，无须亲自出席提交或检查地点，除非同时被命令出席证言录取、听证或审判。\n\n(B) 异议。被命令提交文件或有形物品，或准许检查之人，可以向传票指定的当事人或律师送达书面异议，反对检查、复制、测试或抽样任何或全部材料，或反对检查场所——或反对以所要求的一种或多种形式提交电子存储信息。异议必须在规定履行时间届满前或传票送达后 14 日内（以较早者为准）送达。提出异议后，适用下列规则：\n\n(i) 送达方可随时在通知被命令之人后，向要求履行的地区法院提出动议，请求作出强制提交或检查的命令。\n\n(ii) 仅可依照该命令的指示要求进行该等行为，且该命令必须保护既非当事人亦非当事人高级职员之人免于因履行而产生的重大费用。\n\n(3) 撤销或修改传票。\n\n(A) 必须撤销或修改的情形。经及时动议，要求履行的地区法院必须撤销或修改下列传票：\n\n(i) 未给予合理履行时间；\n\n(ii) 要求某人在规则 45(c) 规定的地域限制以外履行；\n\n(iii) 要求披露享有特权或受其他保护的事项，且不存在适用的例外或豁免；或\n\n(iv) 使某人承受不当负担。\n\n(B) 可以撤销或修改的情形。为保护受传票约束或受其影响之人，要求履行的地区法院可经动议撤销或修改要求下列事项的传票：\n\n(i) 披露商业秘密或其他保密研究、开发或商业信息；或\n\n(ii) 披露未受聘专家的意见或信息，该等意见或信息并非描述争议中的具体事件，且源于该专家并非应一方请求所进行的研究。\n\n(C) 将规定条件作为替代办法。在规则 45(d)(3)(B) 所述情形下，如送达方：\n\n(i) 证明其对该证言或材料具有重大需要，且如不遭受不当困难便无法以其他方式满足该需要；以及\n\n(ii) 确保被传唤之人将获得合理报酬，\n\n法院可不撤销或修改传票，而命令在规定条件下出席或提交。\n\n(e) 回应传票的义务。\n\n(1) 提交文件或电子存储信息。下列程序适用于提交文件或电子存储信息：\n\n(A) 文件。对要求提交文件的传票作出回应的人，必须按其在正常业务过程中保存的方式提交文件，或者将文件整理并标注，以对应请求中的类别。\n\n(B) 未指定电子存储信息提交形式。如传票未指定电子存储信息的提交形式，作出回应的人必须以该信息通常保存的一种或多种形式，或者以一种或多种合理可用的形式提交。\n\n(C) 电子存储信息仅以一种形式提交。作出回应的人无需以一种以上的形式提交相同的电子存储信息。\n\n(D) 无法获取的电子存储信息。作出回应的人无需就其认定为因不当负担或费用而无法合理获取的来源中的电子存储信息提供证据开示。在提出强制证据开示动议或保护令动议时，作出回应的人必须证明该信息因不当负担或费用而无法合理获取。如作出该证明，法院仍可在提出请求的一方证明具有正当理由的情况下，考虑第26(b)(2)(C)条的限制，对该等来源命令进行证据开示。法院可规定该证据开示的条件。\n\n(2) 主张特权或保护。\n\n(A) 被扣留的信息。依据该信息享有特权或作为审判准备材料受到保护的主张而扣留被传唤信息的人，必须：(i) 明确提出该主张；以及\n\n(ii) 以一种在不披露本身享有特权或受保护的信息的情况下，能够使各方评估该主张的方式，说明被扣留文件、通信或有形物的性质。\n\n(B) 已提交的信息。如为回应传票而提交的信息受特权主张或作为审判准备材料受保护的主张所约束，提出该主张的人可以将该主张及其依据通知任何收到该信息的当事人。收到通知后，当事人必须立即返还、隔离或销毁所指定的信息及其持有的任何副本；在该主张得到解决前，不得使用或披露该信息；如该当事人在收到通知前已披露该信息，必须采取合理措施追回该信息；并可立即将该信息密封提交至要求履行义务所在地区的法院，以裁定该主张。提交该信息的人必须保存该信息，直至该主张得到解决。\n\n(g) 藐视法庭。要求履行义务所在地区的法院——以及在动议被移送后，签发传票的法院——可认定已被送达但无充分理由未遵守传票或与之相关命令的人构成藐视法庭。\n\n有关获取传票材料，请参见 Fed.R.Civ.P.45(a) 委员会说明（2013）\n\n……\n\n文件提交请求\nI. 指示\n\n1. 除非另有说明，下列文件请求（统称“请求”，单称“一项请求”）必须分别并具体作出回应。除非基于善意提出异议，否则必须完整答复每项请求；如提出异议，必须按如下所述详细说明您提出异议的理由。如异议仅涉及某项请求的一部分，或其中包含的某个词语、短语或条款，您仅须说明对该部分的异议，并对其余请求作出回应。\n\n2. 必须按照以下指示提交电子存储信息：\n\n- a. 图像。黑白图像必须为 300 DPI Group IV 单页 TIFF 文件。彩色图像必须以 JPEG 格式提交。文件名不得包含嵌入的空格或特殊字符（包括逗号）。文件夹名称不得包含嵌入的空格或特殊字符（包括逗号）。所有 TIFF 图像文件必须具有唯一文件名，即 Bates 编号。每幅图像右下角必须加注连续的 Bates 编号。每个文件夹中的 TIFF 文件数量不得超过 1000 个文件。Excel 电子表格应具有以该文件 Bates 编号命名的占位图像。\n- b. 图像加载文件\n\t- a. Concordance® 数据文件。数据文件（.DAT）包含将加载至 Concordance® 数据库的所有字段化信息。.DAT 文件的第一行必须为标识字段名称的标题行。.DAT 文件必须使用以下 Concordance® 默认分隔符：逗号 ASCII 字符（020）引号 þ ASCII 字符（254）。日期字段应以如下格式提供：mm/dd/yyyy。日期和时间字段必须为两个独立字段。如文件包括已成像的电子邮件及附件，则必须包含附件字段，以保留电子邮件及其附件之间的父项/子项关系。必须包含 OCRPATH 字段，以提供已提取文本文件在所提交存储介质上的文件路径和名称。文本文件必须以 FIRSTBATES 命名。不得在 .DAT 文件中包含文本。对于含有原生文件的文件，必须包含 LINK 字段，以提供原生文件的文件路径和\n\n名称。原生文件必须以 FIRSTBATES 命名。\n\n- b. Concordance Image® 或 Opticon 交叉引用文件。图像交叉引用文件（.LOG 或 .OPT）将图像链接至数据库记录。其应为逗号分隔文件，每行由七个字段构成，数据库中每幅图像均应在交叉引用文件中有一行，格式如下：ImageID,VolumeLabel,ImageFilePath,DocumentBreak,FolderBreak,Box Break,PageCoun。\n- c. 文件文本。文本必须作为独立文本文件提交，而非作为 .DAT 文件内的字段提交。文本文件的完整路径（OCRPATH）应包含于 .DAT 文件中。建议使用按 FIRSTBATES/Image Key 命名的文件级 ANSI 文本文件。提取的文本文件必须置于单独文件夹内，每个文件夹中的文本文件数量不得超过 1,000 个文件。文件夹名称中不得有特殊字符（包括逗号）。必须按文件级别提供文本文件。\n- d. 某些文件类型的原生格式提交。为充分理解其内容和含义而合理需要以原生格式查看的文件类型，必须以原生格式提交。这些文件包括但不限于电子表格、类电子表格文件（Microsoft Excel、逗号分隔值、制表符分隔值等）、Microsoft PowerPoint 或其他特殊演示文件、数据库文件以及音频/视频文件。应提供一张标有 Bates 编号的隔页图像，注明存在原生文件，并将原生文件的路径作为字段包含于 .dat 文件中。提交的原生文件应以与该文件隔页对应的 Bates 编号命名。将原生文件归入名称递增的“NATIVE”目录中，并与图像目录分开。\n- e. 去重。对于存在完全重复件的每一电子文件，仅提交一份副本。对于电子邮件，依据由 BCC、Body、CC、From、IntMsgID、To 和 Attach 属性生成的 MD5 哈希值合并重复件。对于电子邮件附件及独立电子文件，依据整个文件的 MD5 哈希值合并重复件。\n- f. 元数据。以符合 Concordance 的加载文件（.dat）形式，提交每份文件的提取元数据。.DAT 文件的第一行必须为标识字段名称的标题行。.DAT 文件必须使用以下 Concordance 默认分隔符：逗号 , ASCII 字符（020）引号 þ ASCII 字符（254）\n\n日期字段应以如下格式提供：mm/dd/yyyy。日期和时间字段必须为两个独立字段。所需元数据如下：\nCase 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 310 of 1063\n\n字段名称　示例数据　说明\n\nFIRSTBATES　EDC0000001　原生文件文件/电子邮件的首个 Bates 编号\nLASTBATES　EDC0000001　原生文件文件/电子邮件的最后一个 Bates 编号\n**对于单页文件，应填写 LASTBATES 字段\nATTACHRANGE　EDC0000001\n-　父项文件第一页的 Bates 编号至最后一个附件“子项”文件最后一页的 Bates 编号\nEDC0000015　\nBEGATTACH　EDC0000001　附件范围的首个 Bates 编号\nENDATTACH　EDC0000015　附件范围的最后一个 Bates 编号\nCUSTODIAN　Smith, John　电子邮件：电子邮件所在的邮箱\n原生文件：文件来源个人或部门的名称\nFROM　John Smith　电子邮件：发件人\n原生文件：文件作者\n**多个条目之间应使用分号分隔\nTO　Coffman, Janice; LeeW　收件人\n[mailto:LeeW@MSN.com]　**多个条目之间应使用分号分隔\nCC　Frank Thompson [mailto:　抄送收件人\nfrank_Thompson@cdt.com]　**多个条目之间应使用分号分隔\nBCC　John Cain　密送收件人\n**多个条目之间应使用分号分隔\nSUBJECT　Board Meeting Minutes　电子邮件：电子邮件主题行 原生文件：文件标题\n（如有）\nFILE_NAME　BoardMeetingMinutes.docx　原生文件：原始原生文件的名称，\n包括扩展名\nDATE_SENT　10/12/2010　电子邮件：电子邮件发送日期\n原生文件：（空）\nTIME_SENT/　07:05 PM GMT　电子邮件：电子邮件发送时间/电子邮件统一标准化时所在的时区\nTIME_ZONE　\nTIME_ZONE　GMT　在转换期间电子邮件被统一标准化的时区。\nLINK　EDC0000001.msg　电子邮件或原生文件文件的超链接\n**链接文件必须按 FIRSTBATES 编号命名\nFILE_EXTEN　MSG　表示电子邮件或\n文件的文件类型扩展名\nAUTHOR　John Smith　电子邮件：（空）\n原生文件：文件作者\nDATE_CREATED　10/10/2010　电子邮件：（空）\n原生文件：文件创建日期\nCase 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 311 of 1063\n\nTIME_CREATED　10:25 AM　电子邮件：（空）\n\n原生文件：文件创建时间\n**该数据必须为独立字段，不得与 DATE_CREATED 字段合并\nDATE_MOD　10/12/2010　电子邮件：（空）\n原生文件：文件最后修改日期\nTIME_MOD　07:00 PM　电子邮件：（空）\n原生文件：文件最后修改时间\n**该数据必须为独立字段，不得与 DATE_MOD 字段合并\nDATE_ACCESSD　10/12/2010　电子邮件：（空）\n原生文件：文件最后访问日期\nTIME_ACCESSD　07:00 PM　电子邮件：（空）\n原生文件：文件最后访问时间\n**该数据必须为独立字段，不得与 DATE_ACCESSD 字段合并\nFILE_SIZE　5,952　原生文件\n文件/电子邮件的大小，单位为 KB\nPGCOUNT　1　原生文件文件/电子邮件的页数\nPATH　电子邮件：（空）\nAgenda.doc　原生文件：原生文件文件的存储路径，\n包括原始文件名。\nINTFILEPATH　Personal Folders\\Deleted　电子邮件：电子邮件的原始位置，\nItems\\Board Meeting　包括原始文件名。\nMinutes.msg　原生文件：（空）\nINTMSGID　<000805c2c71b\\$75977050\\$　电子邮件：唯一邮件 ID 原生文件：（空）\ncb8306d1@MSN>\nMD5HASH　d131dd02c5e6eec4693d9a0　文件的 MD5 哈希值。\n698aff95c\n2fcab58712467eab4004583e\nb8fb7f89\nOCRPATH　TEXT/001/EDC0000001.txt　原生文件提取文本的路径\n\n3. 每项请求独立运作并应被独立解释，且除非另有说明，任何一项请求均不限制任何其他请求的范围。\n\n4. 所有文件均应按其在正常业务过程中保存的方式提交，或者应予整理并标注，以对应这些请求中的类别。\n\n5. 本文所载的每项请求均延及以下所有文件：(a) 由您占有、保管或控制的文件；或 (b) 由代表您行事的任何人占有、保管或控制的文件，\nCase 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 312 of 1063\n\n包括您的律师或其他代表及顾问。每份文件均应完整提交。\n\n6. 如要求贵方提供已不再由贵方占有、保管或控制的文件，则贵方的答复必须：(a) 详细说明该文件的性质及其内容；(b) 确认编制或撰写该文件的人员（以及，如适用，该文件的接收人员）；(c) 确认该文件编制或创建的日期；(d) 说明该文件是否：(i) 缺失或遗失，(ii) 已被销毁，(iii) 已自愿或非自愿地转交他人，或(iv) 以其他方式处置；(e) 说明该等处置的理由以及相关事实和情形；(f) 确认授权该等处置的人员；(g) 确认该等处置的日期或大致日期；(h) 说明该文件最后一次由贵方占有、保管或控制的时间；以及(i) 确认目前占有、保管或控制该文件的人员（如有）。\n\n7. 如要求贵方提供已被销毁的文件，则除前一项指示所要求的信息外，贵方的答复还必须说明：(a) 销毁该文件的理由；(b) 销毁该文件的人员身份；以及(c) 指示销毁该文件的人员身份。\n\n8. 如贵方主张所要求的文件享有特权或属于律师工作成果，则贵方的答复必须：(a) 说明：(i) 足以支持贵方关于该文件享有特权之主张的文件描述，(ii) 文件标题，(iii) 文件日期，(iv) 文件作者，(v) 文件收件人，(vi) 收到或阅览该文件原件或任何草稿、副本或复制件的每一人员身份，(vii) 该文件本身，或文件中所含或所提及的任何信息，是否由任何其他人员占有、保管或控制；如是，则确认该等人员身份，并说明该信息如何进入其占有范围，(viii) 据以拒绝提供该文件的特权主张，以及(ix) 贵方将据以支持该特权主张的所有情形；以及(b) 就根据 D. Conn. L. Civ. R. 26(e) 基于特权主张而拒绝提供的每一文件，制作一份载有本项指示第(a)部分所要求全部信息的特权清单。对于文件请求中未主张特权或工作成果保护的任何部分，应完整提供相应文件。\n\n案件 22-50073 文书 1592 提交 03/24/23 录入 03/24/23 10:57:37 第 313 页，共 1063 页\n\n9. 如本应提供的文件的一部分包含受特权主张保护的信息，则仅应按照上述指示从该文件中删除或遮蔽受特权主张保护的部分，其余部分应予提供。\n\n10. 该等请求具有持续性。现指示贵方：(a) 一旦得知先前答复不完整或不正确，应立即补充或更正其后得知不完整或不正确的任何答复；以及(b) 提供根据下述内容所要求的任何额外文件。\n\n11. 如文件使用英语以外的语言，贵方应提供该文件。如文件使用英语以外的语言，且存在英文译本，贵方应同时提供两份文件。\n\n12. 对实体的所有提及均包括其全部关联方。\n\n13. 对个人姓名的所有提及均包括所有其他名称、化名或昵称。\n\n案件 22-50073 文书 1592 提交 03/24/23 录入 03/24/23 10:57:37 第 314 页，共 1063 页\n\n14. 除非另有明确说明，文件请求所涵盖的期间为自 February 5, 2012 起至文件请求答复到期之日止。\nII. 解释规则\n\n15. (a) 使用任何单数名词应解释为包括复数，反之亦然；以及(b) 使用任何时态的动词应解释为使用该动词的所有其他时态。\n\n16. (a) “and”和“or”应视必要情况解释为连词或选择连词，以将否则可能被解释为超出任何请求范围的所有答复纳入该请求范围内；以及(b) “each”和“any”应被视为包括并涵盖“every”和“all”。\nIII. 定义\n\n经 D. Conn. Bankr. L.R. 2004-1(a) 纳入的 D. Conn. L. Civ. R. 26(c) 所提供的定义及 D. Conn. L. Civ. R. 26(d) 所提供的解释规则，适用于该等文件请求。此外，本文件请求中所使用的下列术语具有下列含义：\n\n1. “You”、“Your”或“Yourself”系指 DBS Bank Ltd.（星展银行有限公司）及其全部关联方。\n\n2. “Debtor（债务人）”系指 Ho Wan Kwok（郭文贵）（又名 Miles Kwok、Miles Guo、Guo Wengui、Guo Haoyun、郭文贵或任何其他化名）及其雇员、代理人、律师、顾问或任何代表其行事的人。\n\n案件 22-50073 文书 1592 提交 03/24/23 录入 03/24/23 10:57:37 第 315 页，共 1063 页\n\n3. “Debtor's Son（债务人之子）”系指 Qiang Guo（郭强）（又名 Mileson Kwok、郭强或任何其他化名）及其雇员、代理人、律师、顾问或任何代表其行事的人。\n\n4. “Debtor's Daughter（债务人之女）”系指 Mei Guo（郭美）（又名 Mei Gui、郭美或任何其他化名）及其雇员、代理人、律师、顾问或任何代表其行事的人。\n\n5. “Debtor's Purported Wife（债务人所谓妻子）”系指 Hing Chi Ngok（岳庆芝）（又名 Hing Chi Ng、Yue Qingzhi、岳庆芝或任何其他化名）及其雇员、代理人、律师、顾问或任何代表其行事的人。\n\n6. “Debtor's Family（债务人家属）”单独及合称系指债务人、债务人之子、债务人之女及债务人所谓妻子，以及与债务人有任何其他亲属关系的人。\n\n7. “2004 Discovery Targets（2004 调查取证对象）”单独及合称系指债务人、债务人家属、ACA Capital Group Limited（ACA资本集团有限公司）、Himalaya International Financial Group Ltd.（喜马拉雅国际金融集团有限公司）、Himalaya International Clearing Ltd.（喜马拉雅国际清算有限公司）、Himalaya International Payments Ltd.（喜马拉雅国际支付有限公司）、Himalaya International Reserves Ltd.（喜马拉雅国际储备有限公司）、Jesse Brown（杰西·布朗）、William Je（威廉·杰）、William Je、Eastern Profit Corporation Limited（东方利润有限公司）、HK International Funds Investments (USA) Limited LLC（香港国际基金投资〔美国〕有限责任公司）、Bravo Luck Limited（好运有限公司）、Golden Spring (New York) Ltd.（金泉〔纽约〕有限公司）、Lamp Capital LLC（蓝普资本有限责任公司）、Greenwich Land LLC（格林尼治地产有限责任公司）、Qu Guo Jiao（郭娇）、Daniel Thomas Podhaskie（丹尼尔·托马斯·波德哈斯基）、Yvette Wang（王燕萍）（又名 Yanping Wang、又名 Yan Ping Wang）、Ace Decade Holdings Limited（王牌十年控股有限公司）、Dawn State Limited（黎明州有限公司）、Rule of Law Society IV Inc.（法治协会IV公司）、Rule of Law Foundation III, Inc.（法治基金会III公司）、Rule of Law Foundation IV, Inc.（法治基金会IV公司）、Rule of Law Fund（法治基金）、Rule of Law Society（法治协会）、GTV Media Group, Inc.（GTV媒体集团公司）、Voice of Guo Media, Inc.（郭媒体之声公司）、Saraca Media Group Inc.（萨拉卡媒体集团公司）、Genever Holdings Corporation（吉尼弗控股公司）、Genever Holdings LLC（吉尼弗控股有限责任公司）、Gnews Media Group Inc.（Gnews媒体集团公司）、G Fashion LLC（G时尚有限责任公司）、Gmusic LLC（G音乐有限责任公司）、Gnews LLC（Gnews有限责任公司）、Geducation（G教育）、GFNY, Inc.（GFNY公司）、G-Club Investments Limited（G俱乐部投资有限公司）、G Club Operations LLC（G俱乐部运营有限责任公司）、G Club US Operations Inc.（G俱乐部美国运营公司）、G Club US Operations LLC（G俱乐部美国运营有限责任公司）、G Live, LLC（G直播有限责任公司）、Gbroadcast, LLC（G广播有限责任公司）、Gposts LLC（G帖文有限责任公司）、HCHK Property Management, Inc.（HCHK物业管理公司）、HCHK Technologies, Inc.（HCHK科技公司）、FMV Ltd./Freedom Media Venture Ltd.（FMV有限公司／自由媒体创业有限公司）、Roscalitar 2（罗斯卡利塔尔2）、Himalaya New World Inc.（喜马拉雅新世界公司）、US Himalaya Capital Inc.（美国喜马拉雅资本公司）、Hudson Diamond Holding, Inc.（哈德逊钻石控股公司）、Hudson Diamond Holding LLC（哈德逊钻石控股有限责任公司）、Hudson Diamond NY LLC（哈德逊钻石纽约有限责任公司）、Infinity Treasury Management Inc.（无限资金管理公司）、Lexington Property and Staffing, Inc.（列克星敦物业与人事公司）、AI Group Holdings Inc.（AI集团控股公司）、Hamilton Capital Holdings Inc.（汉密尔顿资本控股公司）、Booming Sail New York LLC（纽约兴帆有限责任公司）、Himalaya Ventures LLC（喜马拉雅创投有限责任公司）、Himalaya Ventures LLC、Himalaya Investment LLC（喜马拉雅投资有限责任公司）、New York MOS Himalaya LLC（纽约MOS喜马拉雅有限责任公司）、MOS Himalaya LLC（MOS喜马拉雅有限责任公司）、Crane Advisory Group（克兰咨询集团）、Maywind Trading LLC（五月风贸易有限责任公司）、Gettr USA, Inc.（Gettr美国公司）、Han Chunguang（韩春光）、Bingshang Jiao（焦冰霜）、Karin Maistrello（卡琳·迈斯特雷洛）、Mary Jiang（江梅）、Jiaming Liu（刘嘉明）及 Wencong Wang（王文聪）。\n\n8. “Including”或其任何变体意为“包括但不限于”。\n\n9. “And”和“or”意为“and/or”，并应同时解释为连词及选择连词，以最大限度扩大其范围。\n\n10. “Any”、“all”和“each”意为“每一及全部”。\n\n11. “Each”和“every”意为“每一及全部”。\n\n12. “Third Party（第三方）”系指贵方以外的个人或实体。\n\n13. “Transfer（转让）”具有《破产法典》第 101(54) 条赋予该词的含义。\n\n14. “Document（文件）”系指属于 Fed. R. Civ. P. 34 范围内的任何信息或物品，并包括但不限于，现由或曾由贵方占有、保管或控制的每一及全部任何种类、类型、性质或描述的书面、记录或图形材料，包括电子邮件的所有印刷及电子副本、以电子形式保存的计算机文件、通信函件、备忘录、磁带、速记或手写笔记、任何种类的书面表格、图表、蓝图、图纸、草图、曲线图、计划、文章、规格说明书、日记、信函、\n\n案件 22-50073 文书 1592 提交 03/24/23 录入 03/24/23 10:57:37 第 317 页，共 1063 页\n\n电报、照片、会议记录、合同、协议、调查资料、计算机打印件、任何种类的数据汇编、电传、电传传真、电子邮件、短信、即时消息、语音消息、发票、订购单、支票、汇票、对账单、贷项通知单、报告、仓位报告、摘要、索引、书籍、账簿、笔记本、明细表、透明胶片、录音、目录、广告、宣传材料、影片、录像带、录音带、CD、计算机磁盘、宣传册、小册子、穿孔卡、工时单、推文、社交媒体帖文或任何其他种类的书面或记录材料，以及其全部元数据，无论以何种方式存储（无论为有形或电子形式）、记录、制作或复制；还包括但不限于前述任何文件的草稿或副本，如其中包含原始文件中没有的任何种类的笔记、评论或标记，或在其他方面与原始文件不相同。\n\n15. “Person(s)（人员）”系指个人、公司、独资企业、合伙企业、协会或任何其他实体。“Person”还包括任何代理人、代表或专家，包括但不限于律师或财务顾问。\n\n16. “Entity（实体）”系指任何自然人、公司、合伙企业、子公司、独资企业、商号、董事会、合资企业、协会、机构、主管机关、委员会或其他商业实体或法人，以及任何关联方、代理人、母公司，包括但不限于律师、财务顾问或任何其他代表。\n\n17. “Regarding（关于）”意为涉及、描述、构成、提及、与之相关、支持、赞成、反对、加强、减损、位于其中、结合考虑、对其具有影响、证明、表明、报告、记录、暗指、回应、与之连接、评论、就其而言、关于、与之有关、讨论、显示、描述、反映、分析、构成及为。\n\n案件 22-50073 文书 1592 提交 03/24/23 录入 03/24/23 10:57:37 第 318 页，共 1063 页\n\n18. “Relating to”、“relate(s) to”或“related to”在指称任何特定主题时，意为包括但不限于构成、包含、涉及、含有、体现、反映、确认、陈述、直接或间接提及，或以任何方式与所确认的特定主题相关的任何文件。\n\n19. “通信”系指，以最广泛的可能含义且不受限制地，任何信息或知识的传递（以事实、理念、询问或其他形式）。通信还指所有面对面、通过电话、书面或通过电子传输设备进行的谈话、协议、询问或答复，并包括但不限于所有函件、电子邮件、录音、传送单、备忘录、电话通信、语音留言、电报、传真、电传副本、电传、即时消息、聊天记录、短信、在留言板或群聊中的帖子、社交媒体帖子、推文、上传至任何视频平台的视频、电话记录或在内部或与第三方之间传送的记录。\n\n20. “资产”系指任何受占有、保管或控制的具有经济价值的项目。资产包括所有不动产和动产，包括但不限于房地产、土地、房屋、公寓、共管公寓、汽车、游艇、船只、飞机、喷气式飞机、直升机、现金、银行账户、加密货币、证券、应收账款、存货及其他有形和无形财产。\n\nIV. 应提交的文件\n\n1. 与任何由任何2004取证对象持有、控制、代其持有或以其他方式与其相关的账户有关的所有文件，包括任何及所有账户对账单、授权书、委托书、信托文件、指示或表格、已注销支票副本、函件以及电汇及相关函件和指示。\n\n案件 22-50073 文书 1592 提交日期 03/24/23 录入日期 03/24/23 10:57:37 第319页，共1063页\n\n2. 与任何属于任何2004取证对象、由其持有、控制、代其持有或以其他方式与其相关的资金、证券、财产或资产有关的所有文件，包括任何及所有账户对账单、授权书、委托书、信托文件、指示或表格、已注销支票副本、函件以及电汇及相关函件和指示。\n\n3. 与任何同任何2004取证对象进行的商业、贸易或金融交易有关的所有文件，包括但不限于任何贷款、信贷额度、寄托、存款、互换、证券交易、抵押贷款或ISDA，包括任何及所有账户对账单、授权书、委托书、信托文件、指示或表格、已注销支票副本、函件以及电汇及相关函件和指示。\n\n4. 与2004取证对象有关的任何电汇活动相关的所有文件，无论是否存在任何账户，包括但不限于所有电汇收据、账户号码、余额、授权书、与转账各方相关的身份识别信息、函件、指示或其他记录。\n\n5. 与贵方和2004取证对象之间的任何函件及通信有关的所有文件。\n\n6. 与任何2004取证对象的任何账户有关的所有文件，涉及该账户的开立、该账户的获授权使用人及该账户的维护。\n\n7. 与任何2004取证对象有关的任何反洗钱、了解你的客户或其他合规活动有关的所有文件，包括但不限于任何2004取证对象提供的任何信息，或贵方获悉的任何信息。\n\n8. 与来自任何国家的任何监管机构就任何2004取证对象进行的任何通信有关的所有文件，包括但不限于英格兰银行、美国联邦储备系统、美国证券交易委员会、美国商品期货交易委员会、美国金融业监管局、中国证券监督管理委员会、中国人民银行、香港证券及期货事务监察委员会及香港金融管理局。\n\n案件 22-50073 文书 1592 提交日期 03/24/23 录入日期 03/24/23 10:57:37 第321页，共1063页\n\n附件C-17\n\nB2540（表格2540——规则2004审查传票）（12/15）案件 22-50073 文书 1592 提交日期 03/24/23 录入日期 03/24/23 10:57:37 第322页，共\n\n美国破产法院 1063\n\n康涅狄格区\n\n关于 HO WAN KWOK（郭文贵）等人，\n\n1 案件编号 22-50073 (JAM)\n\n债务人 第11章\n\n（合并管理）\n规则2004审查传票\n\n致：The First Bank of Greenwich（格林尼治第一银行）\n\n（传票所指向人员的姓名）\n\n证言：现命令贵方于下列载明的时间、日期及地点出席，并根据《联邦破产程序规则》第2004条接受审查并作证。随附准许该审查的法院命令副本。\n\n地点　日期和时间\n\nPaul Hastings LLP（普衡律师事务所）\n200 Park Avenue　[待定]\nNew York, New York 10166\n\n审查将通过以下方式记录：法庭记录员/速记员\n\n提交：贵方或贵方代表还必须在审查时携带下列文件、电子存储信息或物品，并必须允许对该等材料进行检查、复制、测试或取样：\n见随附的文件提交请求。\n\n《联邦民事诉讼规则》第45条的下列规定，通过《联邦破产程序规则》第9016条适用于破产案件，现随附于后——有关履行地点的第45(c)条；有关对作为传票对象的贵方进行保护的第45(d)条；以及有关贵方答复本传票的义务及未如此行事的潜在后果的第45(e)条和第45(g)条。\n\n日期：March ，2023\n\n法院书记员\n\n或\n\n书记员或副书记员签名　律师签名\n\n代表签发或请求本传票的第11章受托人 Luc A. Despins（卢克·A·德斯平斯）的律师的姓名、地址、电子邮件地址及电话号码如下：\n\nDouglas S. Skalka, Esq.（道格拉斯·S·斯卡尔卡，律师）；Neubert, Pepe & Monteith, P.C.（诺伊伯特、佩佩及蒙蒂斯律师事务所）；195 Church Street, New Haven, Connecticut 06510；dskalka@npmlaw.com；(203) 821-2000\n\n致签发或请求本传票之人的通知\n\n如本传票命令在审判前提交文件、电子存储信息或有形物品，或命令检查场所，则必须在向传票所指向之人送达之前，向每一方送达通知及本传票副本。《联邦民事诉讼规则》第45(a)(4)条。\n\n软件版权 (c) 1996-2022 Best Case, LLC - www.bestcase.com Best Case Bankruptcy 1 本第11章案件中的债务人为 Ho Wan Kwok（郭文贵，亦称 Guo Wengui、Miles Guo 和 Miles Kwok，以及众多其他别名）（税务识别号码后四位：9595）、Genever Holdings LLC（税务识别号码后四位：8202）及 Genever Holdings Corporation。受托人、Genever Holdings LLC 及 Genever Holdings Corporation 的邮寄地址为 Paul Hastings LLP，200 Park Avenue，New York，NY 10166，转交作为 Ho Wan Kwok（郭文贵）遗产受托人的 Luc A. Despins（仅为通知和通信之目的）。\n\n送达证明\n\n（除非《联邦民事诉讼规则》第45条要求，否则本节不应向法院提交。）\n\n我于（日期）收到向（个人姓名及职务，如有）送达的本传票。\n\n我通过以下方式向所列人员交付副本，以送达本传票：\n\n于（日期）；或\n\n我未执行本传票即予退回，原因如下：\n\n除非本传票代表美国或其官员或代理人签发，我还已向证人支付出席一天的费用以及法律允许的里程费，金额为$ 。\n\n我的旅费为$ ，服务费为$ ，合计为$ 。\n\n我在伪证罪处罚的约束下声明，本信息真实且正确。\n\n日期：\n\n送达人员签名\n\n正楷姓名及职务\n\n送达人员地址\n\n有关尝试送达等的补充信息：\n\n《联邦民事诉讼规则》第45(c)、(d)、(e)及(g)条（自12/1/13起生效）（根据《联邦破产程序规则》第9016条适用于破产案件）\n\n(c) 履行地点。\n\n(1) 审判、听证或证言录取。传票仅可按下列方式命令某人出席审判、听证或证言录取：\n\n(A) 在该人居住、受雇或经常亲自从事商业活动地点100英里范围内；或\n\n(B) 在该人居住、受雇或经常亲自从事商业活动所在州内，如该人\n\n(i) 为一方当事人或一方当事人的高级职员；或\n\n(ii) 被命令出席审判且不会产生重大费用。\n\n(2) 其他取证。传票可以命令：\n\n(A) 在该人居住、受雇或经常亲自从事商业活动地点100英里范围内的地点提交文件、电子存储信息或物品；以及\n\n(B) 在被检查的场所检查该场所。\n\n(d) 对作为传票对象之人的保护；执行。\n\n(1) 避免不当负担或费用；制裁。负责签发和送达传票的一方当事人或律师必须采取合理措施，避免对作为传票对象之人施加不当负担或费用。要求履行的地区法院必须执行此项义务，并对未遵守者的一方当事人或律师施加适当制裁，该制裁可包括损失的收入和合理的律师费。\n\n(2) 命令提交材料或允许检查。\n\n(A) 无须出席。被命令提交文件、电子存储信息或有形物品，或允许检查场所之人，无须亲自到提交或检查地点出席，除非同时被命令出席证言录取、听证或审判。\n\n(B) 异议。被命令提交文件或有形物品，或允许检查之人，可以向传票指定的一方当事人或律师送达书面异议，反对对任何或全部材料进行检查、复制、测试或取样，或反对检查场所——或反对以所要求的一种或多种形式提交电子存储信息。异议必须在规定的履行时间之前或传票送达后14日内（以较早者为准）送达。如提出异议，适用下列规则：\n\n(i) 送达方可随时在通知被命令之人后，向要求履行的地区法院提出动议，请求作出强制提交或检查的命令。\n\n(ii) 只有按照命令指示方可要求实施这些行为，且该命令必须保护并非一方当事人或一方当事人高级职员之人免于承担因履行而产生的重大费用。\n\n(3) 撤销或修改传票。\n\n(A) 必须撤销或修改的情形。经及时动议，要求履行的地区法院必须撤销或修改存在下列情形的传票：\n\n(i) 未给予合理的履行时间；\n\n(ii) 要求某人在第45(c)条规定的地域限制之外履行；\n\n(iii) 要求披露享有特权或以其他方式受保护的事项，而不存在任何适用的例外或放弃；或\n\n(iv) 对某人造成不当负担。\n\n(B) 可以撤销或修改的情形。为保护作为传票对象或受传票影响之人，要求履行的地区法院可以依动议撤销或修改要求下列事项的传票：\n\n(i) 披露商业秘密或其他保密的研究、开发或商业信息；或\n\n(ii) 披露未受聘专家的意见或信息，该等意见或信息并不描述争议中的具体事件，且源于任何一方当事人未请求进行的该专家研究。\n\n(C) 以规定条件作为替代。在第45(d)(3)(B)条所述情形下，如送达方：\n\n(i) 证明其对证言或材料具有重大需要，且不造成不当困难即无法通过其他方式满足该需要；以及\n\n(ii) 确保被传唤之人将获得合理补偿，\n\n法院可以不撤销或修改传票，而命令在规定条件下出席或提交。\n\n(e) 答复传票的义务。\n\n(1) 提交文件或电子存储信息。下列程序适用于提交文件或电子存储信息：\n\n(A) 文件。对要求提交文件的传票作出回应的人员，必须按其在正常业务过程中保存的方式提交文件，或者必须对文件进行整理和标注，使其与请求中的类别相对应。\n\n(B) 未指定电子存储信息提交形式的情形。如传票未指定提交电子存储信息的形式，作出回应的人员必须按该信息通常保存的一种或多种形式，或者按一种或多种合理可用的形式提交。\n\n(C) 电子存储信息仅以一种形式提交。作出回应的人员无需以一种以上形式提交同一电子存储信息。\n\n(D) 无法访问的电子存储信息。作出回应的人员无需对其认定为因不当负担或费用而无法合理访问的来源中的电子存储信息提供证据开示。在提出强制证据开示动议或保护令动议时，作出回应的人员必须证明该信息因不当负担或费用而无法合理访问。如果作出该证明，法院在考虑 Rule 26(b)(2)(C) 的限制后，如提出请求的一方证明存在正当理由，仍可命令从该等来源进行证据开示。法院可为该证据开示规定条件。\n\n(2) 主张特权或保护。\n\n(A) 扣留的信息。根据该信息享有特权或作为审判准备材料受到保护的主张而扣留被传唤信息的人员，必须：(i) 明确提出该主张；并且\n\n(ii) 以一种在不披露本身享有特权或受保护的信息的情况下，能够使各方评估该主张的方式，说明被扣留文件、通信或有形物的性质。\n\n(B) 已提交的信息。如为回应传票而提交的信息受到特权主张或作为审判准备材料受保护的主张的约束，提出该主张的人员可以将该主张及其依据通知收到该信息的任何一方。收到通知后，一方必须立即返还、隔离或销毁所指定的信息及其所持有的任何副本；在该主张得到解决前不得使用或披露该信息；如该方在收到通知前披露了该信息，必须采取合理措施追回该信息；并且可以立即将该信息密封提交给要求履行义务所在地区的法院，以裁定该主张。提交该信息的人员必须在该主张得到解决前保存该信息。\n\n(g) 藐视法庭。要求履行义务所在地区的法院——以及在动议移送后，签发传票的法院——可以认定已被送达但无充分理由不遵从传票或与其相关命令的人员构成藐视法庭。\n\n关于获取传票材料，请参见 Fed.R.Civ.P.45(a) Committee Note (2013)\n\n……\n\n文件提交请求\nI. 指示\n\n1. 除非另有说明，下述文件请求（以下简称“请求”，每一项称为“一项请求”）必须分别且具体地作出回应。除非善意地提出异议，否则必须对每项请求作出完整答复；如提出异议，则必须按下述规定详细说明您提出异议的理由。如异议仅涉及某项请求的一部分，或者其中所含的某个词语、短语或条款，您仅须说明对该部分的异议，并对请求的其余部分作出回应。\n\n2. 电子存储信息必须依照下列指示提交：\n\na. 图像。黑白图像必须为 300 DPI Group IV 单页 TIFF 文件。彩色图像必须以 JPEG 格式提交。文件名不得包含嵌入空格或特殊字符（包括逗号）。文件夹名称不得包含嵌入空格或特殊字符（包括逗号）。所有 TIFF 图像文件必须具有唯一文件名，即 Bates 编号。每张图像的右下角必须标注连续的 Bates 编号。每个文件夹中的 TIFF 文件数量不应超过 1000 个文件。Excel 电子表格应有一张以该文件 Bates 编号命名的占位图像。\n\nb. 图像加载文件\n\na. Concordance® 数据文件。数据文件（.DAT）包含将加载至 Concordance® 数据库的所有字段信息。 .DAT 文件的第一行必须为标明字段名称的标题行。 .DAT 文件必须使用以下 Concordance® 默认分隔符：逗号 ASCII 字符（020）引号 þ ASCII 字符（254）。日期字段应采用以下格式提供：mm/dd/yyyy。日期和时间字段必须为两个独立字段。如文件包括已生成图像的电子邮件及附件，则必须包括附件字段，以保留电子邮件及其附件之间的父/子关系。必须包括 OCRPATH 字段，以提供所提交存储介质上提取文本文件的文件路径和名称。文本文件必须以 FIRSTBATES 命名。不得在 .DAT 文件中包含文本。对于包含原生文件的文件，必须包括 LINK 字段，以提供原生文件的文件路径和名称。原生文件必须以 FIRSTBATES 命名。\n\nb. Concordance Image® 或 Opticon 交叉引用文件。图像交叉引用文件（.LOG 或 .OPT）将图像链接至数据库记录。其应为逗号分隔文件，每行由七个字段组成，并且数据库中每张图像均应在交叉引用文件中有一行，格式如下：ImageID,VolumeLabel,ImageFilePath,DocumentBreak,FolderBreak,Box Break,PageCoun。\n\nc. 文件文本。文本必须作为独立文本文件提交，而非作为 .DAT 文件内的字段。通往文本文件的完整路径（OCRPATH）应包含在 .DAT 文件中。建议使用以 FIRSTBATES/Image Key 命名的文件级 ANSI 文本文件。提取的文本文件必须置于单独的文件夹中，每个文件夹中的文本文件数量不应超过 1,000 个文件。文件夹名称中不得有特殊字符（包括逗号）。必须按文件级别提供文本文件。\n\nd. 某些文件类型的原生格式提交。为全面理解其内容和含义而合理需要以原生格式查看的文件类型，必须以原生格式提交。这些包括但不限于电子表格、类似电子表格的文件（Microsoft Excel、逗号分隔值、制表符分隔值等）、Microsoft PowerPoint 或其他特殊演示文件、数据库文件以及音频/视频文件。提供一张带有 Bates 编号的分隔页图像，表明存在原生文件，并在 .dat 文件中以字段形式包括该原生文件的路径。所提交的原生文件应以与该文件分隔页相对应的 Bates 编号命名。将原生文件归入按递增方式命名的“NATIVE”目录中，并与图像目录分开。\n\ne. 去重。对于存在完全重复件的每份电子文件，提交单一副本。对于电子邮件，基于由 BCC、Body、CC、From、IntMsgID、To 和 Attach 属性生成的 MD5 哈希值合并重复件。对于电子邮件附件和独立电子文件，基于整个文件的 MD5 哈希值合并重复件。\n\nf. 元数据。以符合 Concordance 要求的加载文件（.dat）形式提交每份文件的提取元数据。 .DAT 文件的第一行必须为标明字段名称的标题行。 .DAT 文件必须使用以下 Concordance 默认分隔符：逗号 , ASCII 字符（020）引号 þ ASCII 字符（254）\n\n日期字段应采用以下格式提供：mm/dd/yyyy。日期和时间字段必须为两个独立字段。以下为所要求的元数据：\nCase 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 327 of 1063\n\n字段名称　样本数据　说明\n\nFIRSTBATES　EDC0000001　原生文件文件/电子邮件的首个 Bates 编号\nLASTBATES　EDC0000001　原生文件文件/电子邮件的最后一个 Bates 编号\n**对于单页文件，应填写 LASTBATES 字段\nATTACHRANGE　EDC0000001\n-　父文件第一页的 Bates 编号至最后一个附件“子”文件最后一页的 Bates 编号\nEDC0000015\nBEGATTACH　EDC0000001　附件范围的首个 Bates 编号\nENDATTACH　EDC0000015　附件范围的最后一个 Bates 编号\nCUSTODIAN　Smith, John（约翰·史密斯）　电子邮件：电子邮件所在的邮箱\n原生文件：文件来源的个人或部门名称\nFROM　约翰·史密斯　电子邮件：发件人\n原生文件：文件作者\n**多个条目之间应使用分号分隔\nTO　Coffman, Janice（珍妮斯·科夫曼）；LeeW [mailto:LeeW@MSN.com]　收件人\n**多个条目之间应使用分号分隔\nCC　Frank Thompson（弗兰克·汤普森）[mailto:frank_Thompson@cdt.com]　抄送收件人\n**多个条目之间应使用分号分隔\nBCC　John Cain（约翰·凯恩）　密送收件人\n**多个条目之间应使用分号分隔\nSUBJECT　董事会会议纪要　电子邮件：电子邮件主题行 原生文件：文件标题（如有）\nFILE_NAME　BoardMeetingMinutes.docx　原生文件：原始原生文件的名称，包括扩展名\nDATE_SENT　10/12/2010　电子邮件：电子邮件发送日期\n原生文件：（空）\nTIME_SENT/\nTIME_ZONE　07:05 PM GMT　电子邮件：电子邮件发送时间/电子邮件标准化所采用的时区\nTIME_ZONE　GMT　在转换过程中对电子邮件进行标准化所采用的时区。\nLINK　EDC0000001.msg　通往电子邮件或原生文件文件的超链接\n**链接文件必须按 FIRSTBATES 编号命名\nFILE_EXTEN　MSG　表示电子邮件或原生文件的文件类型扩展名\nAUTHOR　约翰·史密斯　电子邮件：（空）\n原生文件：文件作者\nDATE_CREATED　10/10/2010　电子邮件：（空）\n原生文件：文件创建日期\nCase 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 328 of 1063\n\nTIME_CREATED　10:25 AM　电子邮件：（空）\n原生文件：文件创建时间\n**该数据必须为独立字段，不得与 DATE_CREATED 字段合并\nDATE_MOD　10/12/2010　电子邮件：（空）\n原生文件：文件最后修改日期\nTIME_MOD　07:00 PM　电子邮件：（空）\n原生文件：文件最后修改时间\n**该数据必须为独立字段，不得与 DATE_MOD 字段合并\nDATE_ACCESSD　10/12/2010　电子邮件：（空）\n原生文件：文件最后访问日期\nTIME_ACCESSD　07:00 PM　电子邮件：（空）\n原生文件：文件最后访问时间\n**该数据必须为独立字段，不得与 DATE_ACCESSD 字段合并\nFILE_SIZE　5,952　原生文件文件/电子邮件的大小，单位为 KB\nPGCOUNT　1　原生文件文件/电子邮件的页数\nPATH　电子邮件：（空）\nAgenda.doc　原生文件：原生文件文件的存储路径，包括原始文件名。\nINTFILEPATH　Personal Folders\\Deleted\nItems\\Board Meeting\nMinutes.msg　电子邮件：电子邮件的原始位置，包括原始文件名。\n原生文件：（空）\nINTMSGID　<000805c2c71b\\$75977050\\$\ncb8306d1@MSN>　电子邮件：唯一邮件 ID 原生文件：（空）\nMD5HASH　d131dd02c5e6eec4693d9a0\n698aff95c\n2fcab58712467eab4004583e\nb8fb7f89　文件的 MD5 哈希值。\nOCRPATH　TEXT/001/EDC0000001.txt　原生文件提取文本的路径\n\n3. 每项请求独立适用并应独立解释；除非另有说明，任何一项请求均不限制任何其他请求的范围。\n\n4. 所有文件应按其在通常业务过程中保存的方式提交，或者应进行整理和标注，使其与这些请求中的类别相对应。\n\n5. 本文件所载每项请求延及所有文件：(a) 由您占有、保管或控制的文件；或 (b) 由代表您行事的任何人占有、保管或控制的文件，\nCase 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 329 of 1063\n\n包括您的律师或其他代表和顾问。每份文件均应完整提交。\n\n6. 如要求您提交一份已不再由您占有、保管或控制的文件，则您的答复必须：(a) 详细说明该文件的性质及其内容；(b) 确认编制或撰写该文件的人员（以及，如适用，文件被发送给的人员）；(c) 确认该文件编制或创建的日期；(d) 说明该文件是否：(i) 遗失或丢失，(ii) 已被销毁，(iii) 已自愿或非自愿地转交他人，或(iv) 以其他方式处置；(e) 说明该等处置的理由，以及与该等处置有关的事实和情况；(f) 确认授权该等处置的人员；(g) 确认该等处置的日期或大致日期；(h) 说明该文件最近一次由您占有、保管或控制的时间；以及(i) 确认目前占有、保管或控制该文件的人员（如有）。\n\n7. 如要求您提交一份已被销毁的文件，则除前述指示所要求的信息外，您的答复还必须说明：(a) 该文件被销毁的理由；(b) 销毁该文件的人员身份；以及(c) 指示销毁该文件的人员身份。\n\n8. 如您主张一份被要求提交的文件享有特权或属于律师工作成果，则您的答复必须：(a) 说明：(i) 足以支持您关于该文件享有特权之主张的文件描述，(ii) 文件标题，(iii) 文件日期，(iv) 文件作者，(v) 文件收件人，(vi) 收到或阅览原件或该文件任何草稿、副本或复制件的每一人员身份，(vii) 该文件本身或文件所载或所涉的任何信息是否处于任何其他人员的占有、保管或控制之下，如是，则确认该等人员的身份，\n\n案件 22-50073 文书 1592 提交于 03/24/23 录入于 03/24/23 10:57:37 第 330 页，共 1063 页\n\n以及说明该等信息如何进入其占有；(viii) 据以拒绝提交该文件的特权主张；以及(ix) 您将据以支持该等特权主张的全部情况；以及(b) 就每一份基于特权主张而被扣留的文件，依照 D. Conn. L. Civ. R. 26(e)，提交一份载有本指示第(a)部分所要求全部信息的特权日志。对于文件请求中未提出特权或工作成果主张的任何部分，应完整提供响应性文件。\n\n9. 如一份原本具有响应性的文件中的一部分包含受特权主张约束的信息，则仅应按照上述指示从该文件中删除或遮盖受该特权主张约束的部分，其余部分应予提交。\n\n10. 该等请求具有持续性。现指示您：(a) 在知悉先前答复不完整或不正确后，立即补充或更正任何后来发现不完整或不正确的答复；以及(b) 提交根据以下规定所要求的任何补充文件\n\n11. 如文件使用英语以外的语言，您应提供该文件。如文件使用英语以外的语言，且存在英文译本，您应同时提供两份文件。\n\n12. 对实体的所有提及均包括其全部关联方。\n\n13. 对个人姓名的所有提及均包括所有其他名称、别名或昵称。\n\n案件 22-50073 文书 1592 提交于 03/24/23 录入于 03/24/23 10:57:37 第 331 页，共 1063 页\n\n14. 除非另有明确说明，文件请求所涵盖的期间为自 February 5, 2012 起至应提交文件请求答复之日止。\n\nII. 解释规则\n\n15. (a) 任何单数名词的使用应解释为包括复数，反之亦然；以及(b) 任何时态动词的使用应解释为包括该动词所有其他时态的使用。\n\n16. (a) “and”和“or”应根据需要解释为连词或析取词，以使任何请求的范围包括原本可能被解释为处于其范围之外的所有答复；以及(b) “each”和“any”应视为包括并涵盖“every”和“all”二词。\n\nIII. 定义\n\n依照 D. Conn. Bankr. L.R. 2004-1(a) 纳入的 D. Conn. L. Civ. R. 26(c) 所提供的定义及 D. Conn. L. Civ. R. 26(d) 所提供的解释规则，适用于该等文件请求。此外，本文件请求中使用的下列术语具有下列含义：\n\n1. “You”、“Your”或“Yourself”系指 The First Bank of Greenwich（格林尼治第一银行）及其所有关联方。\n\n2. “Debtor”系指 Ho Wan Kwok（郭文贵）（又名 Miles Kwok、Miles Guo、Guo Wengui、Guo Haoyun、郭文贵或任何其他别名），以及其雇员、代理人、律师、顾问或任何代表其行事之人。\n\n案件 22-50073 文书 1592 提交于 03/24/23 录入于 03/24/23 10:57:37 第 332 页，共 1063 页\n\n3. “Debtor’s Son”系指 Qiang Guo（郭强）（又名 Mileson Kwok、郭强或任何其他别名），以及其雇员、代理人、律师、顾问或任何代表其行事之人。\n\n4. “Debtor’s Daughter”系指 Mei Guo（郭美）（又名 Mei Gui、郭美或任何其他别名），以及其雇员、代理人、律师、顾问或任何代表其行事之人。\n\n5. “Debtor’s Purported Wife”系指 Hing Chi Ngok（岳庆芝）（又名 Hing Chi Ng、Yue Qingzhi、岳庆芝或任何其他别名），以及其雇员、代理人、律师、顾问或任何代表其行事之人。\n\n6. “Debtor’s Family”单独及统称系指债务人、债务人之子、债务人之女及债务人之据称妻子，以及与债务人具有任何其他家庭关系之人。\n\n7. “2004 Discovery Targets”单独及统称系指债务人、债务人家属、ACA Capital Group Limited（ACA资本集团有限公司）、Himalaya International Financial Group Ltd.（喜马拉雅国际金融集团有限公司）、Himalaya International Clearing Ltd.（喜马拉雅国际清算有限公司）、Himalaya International Payments Ltd.（喜马拉雅国际支付有限公司）、Himalaya International Reserves Ltd.（喜马拉雅国际储备有限公司）、Jesse Brown（杰西·布朗）、William Je（威廉·杰）、William Je（威廉·杰）、Eastern Profit Corporation Limited（东方利润有限公司）、HK International Funds Investments (USA) Limited LLC（香港国际基金投资〈美国〉有限责任公司）、Bravo Luck Limited（好运有限公司）、Golden Spring (New York) Ltd.（金泉〈纽约〉有限公司）、Lamp Capital LLC（灯资本有限责任公司）、Greenwich Land LLC（格林尼治土地有限责任公司）、Qu Guo Jiao（郭娇）、Daniel Thomas Podhaskie（丹尼尔·托马斯·波德哈斯基）、Yvette Wang（王艳萍）（又名 Yanping Wang，又名 Yan Ping Wang）、Ace Decade Holdings Limited（王牌十年控股有限公司）、Dawn State Limited（黎明州有限公司）、Rule of Law Society IV Inc.（法治协会IV公司）、Rule of Law Foundation III, Inc.（法治基金会III公司）、Rule of Law Foundation IV, Inc.（法治基金会IV公司）、Rule of Law Fund（法治基金）、Rule of Law Society（法治协会）、GTV Media Group, Inc.（GTV媒体集团公司）、Voice of Guo Media, Inc.（郭媒体之声公司）、Saraca Media Group Inc.（萨拉卡媒体集团公司）、Genever Holdings Corporation（杰尼弗控股公司）、Genever Holdings LLC（杰尼弗控股有限责任公司）、Gnews Media Group Inc.（Gnews媒体集团公司）、G Fashion LLC（G时尚有限责任公司）、Gmusic LLC（G音乐有限责任公司）、Gnews LLC（Gnews有限责任公司）、Geducation（G教育）、GFNY, Inc.（GFNY公司）、G-Club Investments Limited（G俱乐部投资有限公司）、G Club Operations LLC（G俱乐部运营有限责任公司）、G Club US Operations Inc.（G俱乐部美国运营公司）、G Club US Operations LLC（G俱乐部美国运营有限责任公司）、G Live, LLC（G直播有限责任公司）、Gbroadcast, LLC（G广播有限责任公司）、Gposts LLC（G帖子有限责任公司）、HCHK Property\n\n案件 22-50073 文书 1592 提交于 03/24/23 录入于 03/24/23 10:57:37 第 333 页，共 1063 页\n\nManagement, Inc.（HCHK物业管理公司）、HCHK Technologies, Inc.（HCHK技术公司）、FMV Ltd./Freedom Media Venture Ltd.（FMV有限公司/自由媒体创投有限公司）、Roscalitar 2（罗斯卡利塔尔2）、Himalaya New World Inc.（喜马拉雅新世界公司）、US Himalaya Capital Inc.（美国喜马拉雅资本公司）、Hudson Diamond Holding, Inc.（哈德逊钻石控股公司）、Hudson Diamond Holding LLC（哈德逊钻石控股有限责任公司）、Hudson Diamond NY LLC（哈德逊钻石纽约有限责任公司）、Infinity Treasury Management Inc.（无限资金管理公司）、Lexington Property and Staffing, Inc.（列克星敦物业和人事公司）、AI Group Holdings Inc.（AI集团控股公司）、Hamilton Capital Holdings Inc.（汉密尔顿资本控股公司）、Booming Sail New York LLC（繁荣帆船纽约有限责任公司）、Himalaya Ventures LLC（喜马拉雅创投有限责任公司）、Himalaya Ventures LLC（喜马拉雅创投有限责任公司）、Himalaya Investment LLC（喜马拉雅投资有限责任公司）、New York MOS Himalaya LLC（纽约MOS喜马拉雅有限责任公司）、MOS Himalaya LLC（MOS喜马拉雅有限责任公司）、Crane Advisory Group（鹤顾问集团）、Maywind Trading LLC（五月风贸易有限责任公司）、Gettr USA, Inc.（Gettr美国公司）、Han Chunguang（韩春光）、Bingshang Jiao（焦冰爽）、Karin Maistrello（卡琳·梅斯特雷洛）、Mary Jiang（江玛丽）、Jiaming Liu（刘佳明）及 Wencong Wang（王文聪）。\n\n8. “Including”或其任何变体意为“包括但不限于”。\n\n9. “And”和“or”意为“and/or”，并应解释为既具有连词含义，也具有析取词含义，以最大限度扩大其范围。\n\n10. “Any”、“all”和“each”意为“每一及全部”。\n\n11. “Each”和“every”意为“每一及全部”。\n\n12. “Third Party”系指您本人以外的个人或实体。\n\n13. “Transfer”具有《破产法》第 101(54) 条赋予其的含义。\n\n14. “Document”系指 Fed. R. Civ. P. 34 范围内的任何信息或物品，并包括但不限于曾经或目前处于您占有、保管或控制之下的各种、各类、各种性质或描述的每一书面、记录或图形材料，包括电子邮件的所有印刷版和电子副本、以电子形式保存的计算机文件、通信函件、备忘录、磁带、速记或手写笔记、任何种类的书面表格、图表、蓝图、绘图、草图、图形、计划、文章、规格、日记、信件、\n\n案件 22-50073 文书 1592 提交于 03/24/23 录入于 03/24/23 10:57:37 第 334 页，共 1063 页\n\n电报、照片、会议记录、合同、协议、调查、计算机打印件、任何种类的数据汇编、电传、传真、电子邮件、短信、即时消息、语音消息、发票、订单表格、支票、汇票、对账单、贷项通知单、报告、头寸报告、摘要、索引、书籍、账簿、笔记本、日程表、透明胶片、录音、目录、广告、宣传材料、电影、录像带、录音带、CD、计算机磁盘、宣传册、小册子、穿孔卡、工时单、Tweets、社交媒体帖子或任何其他种类的书面或记录材料，以及其全部元数据，无论以何种方式存储（无论为有形或电子形式）、记录、制作或复制；还包括但不限于上述任何文件的草稿或副本，如其中含有原件中不存在的任何种类的笔记、评论或标记，或以其他方式与原件不相同。\n\n15. “Person(s)”系指个人、公司、独资企业、合伙企业、协会或任何其他实体。“Person”还包括任何代理人、代表或专家，包括但不限于律师或财务顾问。\n\n16. “Entity”系指任何自然人、公司、合伙企业、子公司、独资企业、商号、董事会、合资企业、协会、机构、主管机关、委员会或其他商业实体或法人，以及任何关联方、代理人、母公司，包括但不限于律师、财务顾问或任何其他代表。\n\n17. “Regarding”意为涉及、描述、包含、提及、与之相关、支持、赞成、反对、加强、削弱、位于其中、结合其考虑、与之有关、证明、表明、报告、记录、暗指、回应、与之连接、评论、就其而言、关于、与之有关、讨论、显示、描述、反映、分析、构成及为。\n\n案件 22-50073 文书 1592 提交于 03/24/23 录入于 03/24/23 10:57:37 第 335 页，共 1063 页\n\n18. 就任何特定主题而言，“Relating to”、“relate(s) to”或“related to”意为，包括但不限于，构成、包含、涉及、含有、体现、反映、识别、陈述、直接或间接提及，或以任何方式与所确定的特定主题相关的任何文件。\n\n19. “通信”系指以最广泛的意义且不受任何限制的任何信息或知识的传递（以事实、观点、询问或其他形式）。通信还指所有当面、通过电话、书面或借助电子传输设备进行的谈话、协议、询问或答复，包括但不限于所有信函、电子邮件、录音、传输单、备忘录、电话通信、语音留言、电报、传真、电传复印件、电传、即时消息、聊天、短信、在留言板或群聊中的发布、社交媒体帖子、推文、上传至任何视频平台的视频、电话记录或向内部人员或第三方传送的记录。\n\n20. “资产”系指受占有、保管或控制的任何具有经济价值的项目。资产包括所有不动产和动产，包括但不限于房地产、土地、房屋、公寓、共管公寓、汽车、游艇、船只、飞机、喷气式飞机、直升机、现金、银行账户、加密货币、证券、应收账款、存货以及其他有形和无形财产。\n\nIV. 应提交的文件\n\n1. 与由任何2004证据开示对象持有、控制、代表其持有或以其他方式与其有关的任何账户有关的所有文件，包括任何及所有账户对账单、授权书、委托书、信托、指示或表格、已注销支票副本、通信，以及电汇及相关通信和指示。\n案号 22-50073 文件 1592 提交日期 03/24/23 录入日期 03/24/23 10:57:37 第 336 页，共 1063 页\n\n2. 与属于任何2004证据开示对象、由其持有、控制、代表其持有或以其他方式与其有关的任何资金、证券、财产或资产有关的所有文件，包括任何及所有账户对账单、授权书、委托书、信托、指示或表格、已注销支票副本、通信，以及电汇及相关通信和指示。\n\n3. 与同任何2004证据开示对象进行的任何商业、贸易或金融交易有关的所有文件，包括但不限于任何贷款、信贷额度、寄托、存款、互换、证券交易、抵押贷款或ISDA，包括任何及所有账户对账单、授权书、委托书、信托、指示或表格、已注销支票副本、通信，以及电汇及相关通信和指示。\n\n4. 与有关2004证据开示对象的任何电汇活动有关的所有文件，不论是否存在任何账户，包括但不限于所有电汇收据、账号、余额、授权、与转账当事人有关的身份识别信息、通信、指示或其他记录。\n\n5. 与您和2004证据开示对象之间的任何信函及通信有关的所有文件。\n\n6. 与任何2004证据开示对象的任何账户有关的所有文件，涉及账户开立、账户获授权使用人及账户维护。\n\n7. 与有关任何2004证据开示对象的任何反洗钱、了解你的客户或其他合规活动有关的所有文件，包括但不限于任何2004证据开示对象提供或您获悉的任何信息。\n\n8. 与来自任何国家的任何监管机构进行的、有关任何2004证据开示对象的任何通信有关的所有文件，包括但不限于英格兰银行、美国联邦储备系统、美国证券交易委员会、商品期货交易委员会、金融业监管局、中国证券监督管理委员会、中国人民银行、香港证券及期货事务监察委员会和香港金融管理局。\n附件 C-18\nB2540（表格2540——规则2004审查传票）（12/15）案号 22-50073 文件 1592 提交日期 03/24/23 录入日期 03/24/23 10:57:37 第 339 页，共\n\n美国破产法院\n\n康涅狄格地区\n\n关于 HO WAN KWOK（郭文贵）等人，\n\n1 案号 22-50073 (JAM) 债务人 第11章\n\n（合并管理）\n规则2004审查传票\n\n致：Mercantile Bank International Corp.（国际商业银行公司）\n\n（传票所指向之人的姓名）\n\n证言：兹命令您于下列规定的时间、日期和地点出席，并根据《联邦破产程序规则》第2004条接受审查并作证。随附准许该审查的法院命令副本。\n\n地点　日期和时间\n\nPaul Hastings LLP\n200 Park Avenue　[TBD]\nNew York, New York 10166\n\n审查将以以下方式记录：法庭记录员/速记员\n\n提交：您或您的代表还必须携带下列文件、电子存储信息或物品参加审查，并必须允许对该材料进行查验、复制、测试或取样：\n见随附的文件提交请求。\n\n下列《联邦民事诉讼规则》第45条规定，经《联邦破产程序规则》第9016条适用于破产案件，随附于此——第45(c)条，涉及履行地点；第45(d)条，涉及作为受传票约束之人的保护；以及第45(e)条和第45(g)条，涉及您对本传票的答复义务及未答复的潜在后果。\n\n日期：March , 2023\n\n法院书记官\n\n或\n\n书记官或副书记官签名　律师签名\n\n代表发出或请求本传票的第11章受托人 Luc A. Despins（卢克·A·德斯平斯）的律师姓名、地址、电子邮件地址和电话号码如下：\n\nDouglas S. Skalka, Esq.; Neubert, Pepe & Monteith, P.C.; 195 Church Street, New Haven, Connecticut 06510 dskalka@npmlaw.com; (203) 821-2000\n\n致发出或请求本传票之人的通知\n\n如本传票命令在审判前提交文件、电子存储信息或有形物品，或查验场所，则必须在向传票所指向之人送达前，向每一方当事人送达通知及本传票副本。《联邦民事诉讼规则》第45(a)(4)条。\n\n软件版权 (c) 1996-2022 Best Case, LLC - www.bestcase.com Best Case Bankruptcy 1 本第11章案件中的债务人为 Ho Wan Kwok（又名 Guo Wengui、Miles Guo 和 Miles Kwok，以及许多其他别名）（税务识别号码后四位：9595）、Genever Holdings LLC（税务识别号码后四位：8202）及 Genever Holdings Corporation。受托人、Genever Holdings LLC 和 Genever Holdings Corporation 的邮寄地址为 Paul Hastings LLP, 200 Park Avenue, New York, NY 10166，转交 Ho Wan Kwok 遗产的受托人 Luc A. Despins（仅为通知和通信之目的）。\n\n送达证明\n\n（除非《联邦民事诉讼规则》第45条要求，否则本节不应向法院提交。）\n\n我于（日期）收到本传票，受送达人为（个人姓名及职务，如有）：。\n\n我通过如下方式向被指定之人交付副本，送达本传票：\n\n于（日期）；或\n\n我未执行传票即予退回，原因如下：\n\n除非该传票代表美国或其官员或代理人发出，我还已向证人支付一天出席费用及法律允许的里程费，金额为 \\$ 。\n\n我的差旅费用为 \\$，服务费用为 \\$，合计 \\$。\n\n我在伪证罪处罚下声明，本信息真实且正确。\n\n日期：\n\n送达人员签名\n\n印刷姓名及职务\n\n送达人员地址\n\n有关尝试送达等的补充信息：\n《联邦民事诉讼规则》第45(c)、(d)、(e)及(g)条（Effective 12/1/13）（经《联邦破产程序规则》第9016条适用于破产案件）\n(c) 履行地点。\n\n(1) 审判、听证或证言录取。传票仅可按如下方式命令一人出席审判、听证或证言录取：\n\n(A) 在该人居住、受雇或经常亲自从事商业活动地点100英里范围内；或\n\n(B) 在该人居住、受雇或经常亲自从事商业活动所在州内，如该人\n\n(i) 是当事人或当事人的高级职员；或\n\n(ii) 被命令出席审判且不会产生重大费用。\n\n(2) 其他证据开示。传票可命令：\n\n(A) 在该人居住、受雇或经常亲自从事商业活动地点100英里范围内的地点提交文件、电子存储信息或物品；以及\n\n(B) 在被查验场所进行场所查验。\n(d) 对受传票约束之人的保护；执行。\n\n(1) 避免不当负担或费用；制裁。负责发出和送达传票的当事人或律师必须采取合理措施，避免对受传票约束之人施加不当负担或费用。要求履行的地区法院必须执行该义务，并对未遵守者的当事人或律师施加适当制裁，该制裁可包括损失的收入和合理的律师费。\n\n(2) 命令提交材料或允许查验。\n\n(A) 无须出席。被命令提交文件、电子存储信息或有形物品，或允许查验场所之人，无须亲自到达提交或查验地点，除非还被命令出席证言录取、听证或审判。\n\n(B) 异议。被命令提交文件或有形物品，或允许查验之人，可以向传票中指定的当事人或律师送达书面异议，反对查验、复制、测试或取样任何或全部材料，或反对查验场所，或反对以所要求的一种或多种形式提交电子存储信息。异议必须在规定履行时间届满前或传票送达后14日内（以较早者为准）送达。如提出异议，适用下列规则：\n\n(i) 送达方可随时在通知被命令之人后，向要求履行的地区法院提出动议，请求作出强制提交或查验的命令。\n\n(ii) 仅可按照命令所指示的方式要求实施该等行为，且命令必须保护非当事人亦非当事人高级职员之人免于因履行而产生的重大费用。\n\n(3) 撤销或修改传票。\n\n(A) 必须撤销或修改的情形。经及时动议，要求履行的地区法院必须撤销或修改具有下列情形的传票：\n\n(i) 未给予合理履行时间；\n\n(ii) 要求一人在第45(c)条规定的地域限制以外履行；\n\n(iii) 要求披露享有特权或以其他方式受保护的事项，且不存在适用的例外或豁免；或\n\n(iv) 使一人承受不当负担。\n\n(B) 可撤销或修改的情形。为保护受传票约束或受传票影响之人，要求履行的地区法院可经动议撤销或修改要求下列事项的传票：\n\n(i) 披露商业秘密或其他保密的研究、开发或商业信息；或\n\n(ii) 披露未受聘专家的意见或信息，该等意见或信息并非描述争议中的具体事件，且源于并非当事人请求的该专家研究。\n\n(C) 作为替代方案规定条件。在第45(d)(3)(B)条所述情形下，如送达方：\n\n(i) 证明对该证言或材料具有重大需要，且若不承受不当困难则无法以其他方式满足该需要；并且\n\n(ii) 确保受传票人将获得合理补偿，\n\n法院可以不撤销或修改传票，而命令在特定条件下出席或提交。\n\n(e) 答复传票时的义务。\n\n(1) 提交文件或电子存储信息。下列程序适用于提交文件或电子存储信息：\n\n(A) 文书。对要求提供文书的传票作出回应的人，必须按照文书在通常业务过程中保存的方式提供文书，或者必须对文书进行整理和标注，使其与要求中所列类别相对应。\n\n(B) 未指定的电子存储信息提供形式。如传票未指定提供电子存储信息的形式，作出回应的人必须以其通常保存的一种或多种形式，或以一种或多种合理可用的形式提供该信息。\n\n(C) 电子存储信息仅以一种形式提供。作出回应的人无需以多于一种形式提供相同的电子存储信息。\n\n(D) 无法合理获取的电子存储信息。作出回应的人无需就其认定因不当负担或费用而无法合理获取的来源中的电子存储信息提供证据开示。在提出强制证据开示动议或保护令动议时，作出回应的人必须证明该信息因不当负担或费用而无法合理获取。如作出该证明，法院仍可在提出请求的一方证明存在正当理由时，命令从该等来源进行证据开示，并应考虑 Rule 26(b)(2)(C) 的限制。法院可为该证据开示规定条件。\n\n(2) 主张特权或保护。\n\n(A) 被扣留的信息。以该信息享有特权或作为审判准备材料受到保护为由扣留传票所要求的信息的人，必须：(i) 明确提出该主张；以及\n\n(ii) 以一种方式说明被扣留的文书、通信或有形物的性质，使各方能够评估该主张，同时不披露本身享有特权或受保护的信息。\n\n(B) 已提供的信息。如为回应传票而提供的信息受到特权主张或作为审判准备材料受保护的主张约束，提出该主张的人可以将该主张及其依据通知任何收到该信息的一方。收到通知后，一方必须立即返还、隔离或销毁所指定的信息及其持有的任何副本；在该主张解决前，不得使用或披露该信息；如该方在收到通知前已披露该信息，必须采取合理措施追回该信息；并可立即将该信息密封提交至要求履行所在地辖区的法院，以裁定该主张。提供该信息的人必须保存该信息，直至该主张得到解决。\n\n(g) 藐视法庭。要求履行所在地辖区的法院——以及在动议移送后签发传票的法院——可对已获送达但无充分理由不遵守传票或与其相关命令的人，以藐视法庭论处。\n\n有关传票材料的获取，请参见 Fed.R.Civ.P.45(a) Committee Note (2013)\n\n……\n\n文书提供请求\n\nI. 指示\n\n1. 除非另有说明，下列文书请求（以下简称“请求”，每一项以下简称“一项请求”）必须分别且具体地作出回应。除非基于诚信提出异议，否则必须完整答复每项请求；如提出异议，则必须按如下规定详细说明贵方异议的理由。如异议仅涉及一项请求的一部分，或其中包含的某一词语、短语或条款，贵方仅须说明对该部分的异议，并对请求的其余部分作出回应。\n\n2. 电子存储信息必须依照下列指示提供：\n\na. 图像。黑白图像必须为 300 DPI Group IV 单页 TIFF 文件。彩色图像必须以 JPEG 格式提供。文件名不得含有嵌入的空格或特殊字符（包括逗号）。文件夹名称不得含有嵌入的空格或特殊字符（包括逗号）。所有 TIFF 图像文件必须具有唯一文件名，即 Bates 编号。每张图像右下角必须加注连续的 Bates 编号。每个文件夹中的 TIFF 文件数量不应超过 1000 个文件。Excel 电子表格应具有以该文件 Bates 编号命名的占位图像。\n\nb. 图像加载文件\n\na. Concordance® 数据文件。数据文件（.DAT）包含将加载至 Concordance® 数据库的所有字段信息。.DAT 文件的第一行必须为标明字段名称的标题行。.DAT 文件必须使用以下 Concordance® 默认分隔符：逗号 ASCII 字符（020）引号 þ ASCII 字符（254）。日期字段应以如下格式提供：mm/dd/yyyy。日期和时间字段必须为两个独立字段。如文书包括已成像的电子邮件及附件，则必须包括附件字段，以保持电子邮件与其附件之间的父项/子项关系。必须包括 OCRPATH 字段，以提供已提供存储介质上提取文本文件的文件路径和名称。文本文件必须以 FIRSTBATES 命名。不得在 .DAT 文件中包括文本。对于含有原生文件的文书，必须包括 LINK 字段，以提供原生文件的文件路径和名称。原生文件必须以 FIRSTBATES 命名。\n\nb. Concordance Image® 或 Opticon 交叉引用文件。图像交叉引用文件（.LOG 或 .OPT）将图像链接至数据库记录。其应为以逗号分隔的文件，每行由七个字段组成，数据库中每张图像均应在交叉引用文件中对应一行，格式如下：ImageID,VolumeLabel,ImageFilePath,DocumentBreak,FolderBreak,Box Break,PageCoun。\n\nc. 文书文本。文本必须作为单独的文本文件提供，而非作为 .DAT 文件中的字段提供。文本文件的完整路径（OCRPATH）应包括在 .DAT 文件中。建议提供以 FIRSTBATES/Image Key 命名的文书级 ANSI 文本文件。提取的文本文件必须置于单独文件夹中，每个文件夹中的文本文件数量不应超过 1,000 个文件。文件夹名称中不得有特殊字符（包括逗号）。文本文件必须按文书级别提供。\n\nd. 特定文件类型的原生格式提供。为完整理解其内容和含义而合理需要以原生格式查看的文件类型，必须以原生格式提供。这些文件包括但不限于电子表格、类似电子表格的文件（Microsoft Excel、逗号分隔值、制表符分隔值等）、Microsoft PowerPoint 或其他特殊演示文件、数据库文件及音频/视频文件。提供一张带有 Bates 编号的分隔页图像，以表明存在原生文件，并在 .dat 文件中将该原生文件路径作为一个字段列入。所提供的原生文件应以与该文件分隔页相对应的 Bates 编号命名。原生文件应按递增命名方式归入“NATIVE”目录，并与图像目录分开。\n\ne. 去重。对于存在完全重复件的每份电子文书，仅提供一份副本。对于电子邮件，应基于从 BCC、Body、CC、From、IntMsgID、To 和 Attach 属性生成的 MD5 哈希值合并重复件。对于电子邮件附件及独立电子文件，应基于整个文件的 MD5 哈希值合并重复件。\n\nf. 元数据。以符合 Concordance 的加载文件（.dat）形式，提供每份文书的提取元数据。.DAT 文件的第一行必须为标明字段名称的标题行。.DAT 文件必须使用以下 Concordance 默认分隔符：逗号 , ASCII 字符（020）引号 þ ASCII 字符（254）\n\n日期字段应以如下格式提供：mm/dd/yyyy。日期和时间字段必须为两个独立字段。所要求的元数据如下：\n\n案号 22-50073 文档 1592 提交 03/24/23 录入 03/24/23 10:57:37 第 344 页，共 1063 页\n\n字段名称　示例数据　说明\n\nFIRSTBATES　EDC0000001　原生文件文书/电子邮件的第一个 Bates 编号\nLASTBATES　EDC0000001　原生文件文书/电子邮件的最后一个 Bates 编号\nLASTBATES 字段应针对单页填写\nATTACHRANGE　EDC0000001\n-　父文书第一页的 Bates 编号至最后一个附件“子”文书最后一页的 Bates 编号\nEDC0000015\nBEGATTACH　EDC0000001　附件范围的第一个 Bates 编号\nENDATTACH　EDC0000015　附件范围的最后一个 Bates 编号\nCUSTODIAN　Smith, John　电子邮件：电子邮件所在的邮箱\n原生文件：文书来源的个人或部门名称\nFROM　John Smith　电子邮件：发件人\n原生文件：文书作者\n应使用分号分隔多个条目\nTO　Coffman, Janice; LeeW　收件人\n[mailto:LeeW@MSN.com]　应使用分号分隔多个条目\nCC　Frank Thompson [mailto:　抄送收件人\nfrank_Thompson@cdt.com]　应使用分号分隔多个条目\nBCC　John Cain　密送收件人\n应使用分号分隔多个条目\nSUBJECT　Board Meeting Minutes　电子邮件：电子邮件主题行 原生文件：文书标题（如有）\nFILE_NAME　BoardMeetingMinutes.docx　原生文件：原始原生文件名称，包括扩展名\nDATE_SENT　10/12/2010　电子邮件：电子邮件发送日期\n原生文件：（空）\nTIME_SENT/　07:05 PM GMT　电子邮件：电子邮件发送时间/电子邮件标准化所采用的时区\nTIME_ZONE\nTIME_ZONE　GMT　在转换过程中电子邮件被标准化所采用的时区。\nLINK　EDC0000001.msg　电子邮件或原生文件文书的超链接\n所链接的文件必须按照 FIRSTBATES 编号命名\nFILE_EXTEN　MSG　表示电子邮件或原生文件的文件类型扩展名\nAUTHOR　John Smith　电子邮件：（空）\n原生文件：文书作者\nDATE_CREATED　10/10/2010　电子邮件：（空）\n原生文件：文书创建日期\n\n案号 22-50073 文档 1592 提交 03/24/23 录入 03/24/23 10:57:37 第 345 页，共 1063 页\n\nTIME_CREATED　10:25 AM　电子邮件：（空）\n\n原生文件：文书创建时间\n该数据必须为独立字段，且不得与 DATE_CREATED 字段合并\nDATE_MOD　10/12/2010　电子邮件：（空）\n原生文件：文书最后修改日期\nTIME_MOD　07:00 PM　电子邮件：（空）\n原生文件：文书最后修改时间\n该数据必须为独立字段，且不得与 DATE_MOD 字段合并\nDATE_ACCESSD　10/12/2010　电子邮件：（空）\n原生文件：文书最后访问日期\nTIME_ACCESSD　07:00 PM　电子邮件：（空）\n原生文件：文书最后访问时间\n该数据必须为独立字段，且不得与 DATE_ACCESSD 字段合并\nFILE_SIZE　5,952　原生文件文书/电子邮件的大小，以 KB 为单位\nPGCOUNT　1　原生文件文书/电子邮件的页数\nPATH　电子邮件：（空）\nAgenda.doc　原生文件：原生文件文书的存储路径，包括原始文件名。\nINTFILEPATH　Personal Folders\\Deleted　电子邮件：电子邮件的原始位置，包括原始文件名。\nItems\\Board Meeting　原生文件：（空）\nMinutes.msg\nINTMSGID　<000805c2c71b\\$75977050\\$　电子邮件：唯一消息 ID 原生文件：（空）\ncb8306d1@MSN>\nMD5HASH　d131dd02c5e6eec4693d9a0　文书的 MD5 哈希值。\n698aff95c\n2fcab58712467eab4004583e\nb8fb7f89\nOCRPATH　TEXT/001/EDC0000001.txt　原生文件提取文本的路径\n\n3. 每项请求独立运作并应独立解释，且除非另有说明，任何请求均不限制任何其他请求的范围。\n\n4. 所有文书均应按照其在通常业务过程中保存的方式提供，或应进行整理和标注，使其与本请求中的类别相对应。\n\n5. 本文所载每项请求均延及所有下列文书：(a) 由贵方占有、保管或控制的文书；或 (b) 由代表贵方行事的任何人占有、保管或控制的文书，\n\n案号 22-50073 文档 1592 提交 03/24/23 录入 03/24/23 10:57:37 第 346 页，共 1063 页\n\n包括贵方律师或其他代表和顾问。每份文书均应完整提供。\n\n6. 如要求您提交的某一文件已不再由您占有、保管或控制，则您的答复必须：(a) 详细说明该文件的性质及其内容；(b) 指明编制或撰写该文件的人员（以及，如适用，文件被发送至的人员）；(c) 指明该文件编制或创建的日期；(d) 说明该文件是否：(i) 遗失或丢失，(ii) 已被销毁，(iii) 已自愿或非自愿地转移给他人，或 (iv) 以其他方式处置；(e) 说明该等处置的理由，以及围绕该等处置的事实和情形；(f) 指明授权该等处置的人员；(g) 指明该等处置的日期或约略日期；(h) 说明该文件最近一次由您占有、保管或控制的时间；以及 (i) 指明目前占有、保管或控制该文件的人员（如有）。\n\n7. 如要求您提交的某一文件已被销毁，则除前一指示所要求的信息外，您的答复还必须说明：(a) 该文件被销毁的理由；(b) 销毁该文件的人员身份；以及 (c) 指示销毁该文件的人员身份。\n\n8. 如您主张所请求的文件享有特权或属于律师工作成果，则您的答复必须：(a) 说明：(i) 足以支持您关于该文件享有特权之主张的文件描述，(ii) 文件标题，(iii) 文件日期，(iv) 文件作者，(v) 文件收件人，(vi) 收到或阅览该文件原件或任何草稿、副本或复制件的每一人员身份，(vii) 该文件本身或文件中所载或所提及的任何信息，是否由任何其他人员占有、保管或控制；如是，则说明该等人员的身份，以及说明该等信息如何进入其占有、保管或控制之中的陈述，(viii) 据以拒绝提交该文件的特权主张，以及 (ix) 您将据以支持该等特权主张的所有情形；以及 (b) 就每一份基于特权主张而被拒绝提交的文件，依照 D. Conn. L. Civ. R. 26(e)，制作一份特权日志，其中载明本指示第 (a) 部分要求的所有信息。对于文件请求中未提出特权或工作成果主张的任何部分，应完整提供相应文件。\nCase 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 347 of 1063\n\n9. 如本应提交文件的一部分包含受特权主张约束的信息，则仅应依照上述指示从该文件中删除或遮盖受特权主张约束的部分，其余部分应予提交。\n\n10. 该等请求具有持续性。现指示您：(a) 一旦得知先前答复不完整或不正确，应立即补充或更正任何后来发现不完整或不正确的答复；以及 (b) 提交根据以下规定所要求的任何额外文件\n\n11. 如某一文件使用英语以外的语言，您应提供该文件。如某一文件使用英语以外的语言，且存在英文译本，您应同时提供两份文件。\n\n12. 对实体的一切提及均包括其所有关联方。\n\n13. 对个人姓名的一切提及均包括所有别名、化名或昵称。\nCase 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 348 of 1063\n\n14. 除非另有明确说明，文件请求所涵盖的期间为自 February 5, 2015 起至文件请求答复到期之日止。\n\nII. 解释规则\n\n15. (a) 对任何单数名词的使用，应解释为包括复数，反之亦然；以及 (b) 对任何时态动词的使用，应解释为在所有其他时态中使用该动词。\n\n16. (a) “and”和“or”应视为必要时按连词或析取词解释，以使任何请求的范围包括原本可能被解释为不在其范围内的所有答复；以及 (b) “each”和“any”应视为包括并涵盖“every”和“all”二词。\n\nIII. 定义\n\n根据 D. Conn. Bankr. L.R. 2004-1(a) 纳入的 D. Conn. L. Civ. R. 26(c) 所提供的定义及 D. Conn. L. Civ. R. 26(d) 所提供的解释规则，适用于文件请求。此外，本文件请求中所使用的下列术语具有如下含义：\n\n1. “您”或“您的”或“您本人”系指 Mercantile Bank International Corp.（国际商业银行公司）、其雇员、代理人、律师、顾问或任何代表其行事之人。\n\n2. “债务人”系指 Ho Wan Kwok（郭文贵）（又名 Miles Kwok、Miles Guo、Guo Wengui、Guo Haoyun、郭文贵，或任何其他别名），以及其雇员、代理人、律师、顾问或任何代表其行事之人。\nCase 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 349 of 1063\n\n3. “债务人之子”系指 Qiang Guo（郭强）（又名 Mileson Kwok、郭强或任何其他别名），以及其雇员、代理人、律师、顾问或任何代表其行事之人。\n\n4. “债务人之女”系指 Mei Guo（郭美）（又名 Mei Gui、郭美或任何其他别名），以及其雇员、代理人、律师、顾问或任何代表其行事之人。\n\n5. “债务人之自称妻子”系指 Hing Chi Ngok（岳庆芝）（又名 Hing Chi Ng、Yue Qingzhi、岳庆芝或任何其他别名），以及其雇员、代理人、律师、顾问或任何代表其行事之人。\n\n6. “债务人家属”单独及合称指债务人、债务人之子、债务人之女及债务人之自称妻子，以及与债务人有任何其他亲属关系之人。\n\n7. “2004 年取证对象”单独及合称指债务人、债务人家属、ACA Capital Group Limited、Himalaya International Financial Group Ltd.、Himalaya International Clearing Ltd.、Himalaya International Payments Ltd.、Himalaya International Reserves Ltd.、Jesse Brown、William Je、Eastern Profit Corporation Limited、HK International Funds Investments (USA) Limited LLC、Bravo Luck Limited、Golden Spring (New York) Ltd.、Lamp Capital LLC、Greenwich Land LLC、Qu Guo Jiao、Daniel Thomas Podhaskie、Yvette Wang（又名 Yanping Wang，又名 Yan Ping Wang）、Ace Decade Holdings Limited、Dawn State Limited、Rule of Law Society IV Inc.、Rule of Law Foundation III, Inc.、Rule of Law Foundation IV, Inc.、Rule of Law Fund、Rule of Law Society、GTV Media Group, Inc.、Voice of Guo Media, Inc.、Saraca Media Group Inc.、Genever Holdings Corporation、Genever Holdings LLC、Gnews Media Group Inc.、G Fashion LLC、Gmusic LLC、Gnews LLC、Geducation、GFNY, Inc.、G-Club Investments Limited、G Club Operations LLC、G Club US Operations Inc.、G Club US Operations LLC、G Live, LLC、Gbroadcast, LLC、Gposts LLC、HCHK Property Management、\nCase 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 350 of 1063\n\nInc.、HCHK Technologies, Inc.、FMV Ltd./Freedom Media Venture Ltd.、Roscalitar 2、Himalaya New World Inc.、US Himalaya Capital Inc.、Hudson Diamond Holding, Inc.、Hudson Diamond Holding LLC、Hudson Diamond NY LLC、Infinity Treasury Management Inc.、Lexington Property and Staffing, Inc.、AI Group Holdings Inc.、Booming Sail New York LLC、Himalaya Ventures LLC、Himalaya Ventures LLC、Himalaya Investment LLC、New York MOS Himalaya LLC、MOS Himalaya LLC、Crane Advisory Group、Maywind Trading LLC、Gettr USA, Inc.、Han Chunguang、Bingshang Jiao、Karin Maistrello、Mary Jiang、Jiaming Liu 及 Wencong Wang。\n\n8. “Hamilton 实体”系指 Hamilton M&A Fund SP、Hamilton Opportunity Fund SPC、Hamilton Capital Holdings Inc.、Hamilton Investment Management Limited、Midvale Avenue Limited、Hamilton Fintech Ltd. 及 Hamilton Cyber Ltd.\n\n9. “包括”或其任何变体，意为“包括但不限于”。\n\n10. “and”和“or”意为“and/or”，并应同时按连词及析取词解释，以最大限度扩大其范围。\n\n11. “any”、“all”和“each”意为“每一及所有”。\n\n12. “each”和“every”意为“每一及所有”。\n\n13. “第三方”系指您本人以外的个人或实体。\n\n14. “转移”具有《破产法典》第 101(54) 条赋予该词的含义。\n\n15. “文件”系指属于 Fed. R. Civ. P. 34 范围内的任何信息或物品，并包括但不限于目前或曾经由您占有、保管或控制的各种、各类、任何性质或描述的每一项书面、记录或图形材料，包括电子邮件的所有印刷和电子副本、以电子形式保存的计算机文件、\nCase 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 351 of 1063\n\n通信函件、备忘录、磁带、速记或手写笔记、任何种类的书面表格、图表、蓝图、图纸、草图、曲线图、计划、文章、规格说明、日记、信函、电报、照片、会议记录、合同、协议、调查、计算机打印输出、各种数据汇编、电传、传真、电子邮件、短信、即时消息、语音信息、发票、订购单、支票、汇票、对账单、贷项通知单、报告、头寸报告、摘要、索引、书籍、账簿、笔记本、日程表、透明胶片、录音、目录、广告、宣传材料、影片、录像带、录音带、CD、计算机磁盘、宣传册、小册子、穿孔卡、工时单、推文、社交媒体帖子，或任何其他种类的书面或记录材料，以及其所有元数据；无论以何种方式存储（无论为有形或电子形式）、记录、制作或复制；还包括但不限于上述任何材料的草稿或副本，如其中包含原始文件中不存在的任何种类笔记、评论或标记，或在其他方面与原始文件不相同。\n\n16. “人员”系指个人、公司、独资企业、合伙企业、协会或任何其他实体。“人员”还包括任何代理人、代表或专家，包括但不限于律师或财务顾问。\n\n17. “实体”系指任何自然人、公司、合伙企业、子公司、独资企业、商号、董事会、合资企业、协会、机构、主管机关、委员会或其他商业实体或法人，以及任何关联方、代理人、母公司，包括但不限于律师、财务顾问或任何其他代表。\n\n18. “关于”意为涉及、描述、构成、提及、与之相关、支持、有利于、反对、加强、削弱、载于、结合考虑、对……有影响、证明、表明、报告、记录、暗指、回应、\nCase 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 352 of 1063\n\n与之连接、评论、就……而言、有关、与……相关、讨论、展示、描述、反映、分析、构成及为。\n\n19. “与……有关”、“涉及”或“相关”，在提及任何特定主题事项时，意为包括但不限于构成、包含、涉及、含有、体现、反映、识别、陈述、直接或间接提及，或以任何方式与所识别的特定主题事项相关的任何文件。\n\n20. “通信”系指在最广义且不受任何限制的意义上，任何信息或知识的传递（以事实、观点、询问或其他形式）。通信还指所有谈话、协议、询问或答复，无论是当面、通过电话、以书面形式，还是通过电子传输设备进行，并包括但不限于所有信函、电子邮件、录音、传送单、备忘录、电话通信、语音留言、电报、传真、电传副本、电传、即时消息、聊天、短信、留言板或群聊中的帖子、社交媒体帖子、推文、上传至任何视频平台的视频、电话记录，或在内部或与第三方之间传送的记录。\n\n21. “资产”系指受占有、保管或控制的任何具有经济价值的项目。资产包括所有不动产和动产，包括但不限于房地产、土地、房屋、公寓、产权公寓、汽车、游艇、船舶、飞机、喷气机、直升机、现金、银行账户、加密货币、证券、应收账款、存货及其他有形和无形财产。\n\n案件 22-50073 文件 1592 提交日期 03/24/23 登记日期 03/24/23 10:57:37 第 353 页，共 1063 页\n\n四、应提交的文件\n\n1. 您与债务人、Ehsan Masud（艾赫桑·马苏德）、David Fallon（大卫·法伦）、Hamilton Entities（Hamilton实体）或2004取证对象之间的所有通信，包括但不限于William Je（威廉·杰，亦称Je Kin Ming；亦称Kin Je；亦称William Yu；亦称Yu Jianming）。\n\n2. 与您和债务人、Ehsan Masud、David Fallon、Hamilton实体或2004取证对象之间任何通信有关的所有文件，包括但不限于William Je（亦称Je Kin Ming；亦称Kin Je；亦称William Yu；亦称Yu Jianming）。\n\n3. 与债务人、Ehsan Masud、David Fallon、Hamilton实体或2004取证对象作出、与其进行或代表其作出的任何实际、潜在或拟议投资、商业往来或交易有关的所有文件和通信，包括但不限于William Je（亦称Je Kin Ming；亦称Kin Je；亦称William Yu；亦称Yu Jianming）。\n\n4. 与涉及债务人、Ehsan Masud、David Fallon、Hamilton实体或2004取证对象的任何反洗钱、了解你的客户或其他合规活动有关的所有文件和通信，包括但不限于William Je（亦称Je Kin Ming；亦称Kin Je；亦称William Yu；亦称Yu Jianming），包括但不限于债务人、Ehsan Masud、David Fallon、Hamilton实体或2004取证对象（包括但不限于William Je［亦称Je Kin Ming；亦称Kin Je；亦称William Yu；亦称Yu Jianming］）向您或任何国家、州、地方、执法组织或主权实体的任何监管机构提供的任何信息。\n\n5. 与下列事项有关的所有文件和通信：(i) 任何国家、州、地方、执法组织或主权实体的任何监管机构，包括但不限于英格兰银行、美国联邦储备系统、美国证券和\n\n案件 22-50073 文件 1592 提交日期 03/24/23 登记日期 03/24/23 10:57:37 第 354 页，共 1063 页\n\n交易委员会、商品期货交易委员会、FINRA、中国证券监督管理委员会、中国人民银行、香港证券及期货事务监察委员会及香港金融管理局，(ii) 债务人、Ehsan Masud、David Fallon、Hamilton实体或2004取证对象，包括但不限于William Je（亦称Je Kin Ming；亦称Kin Je；亦称William Yu；亦称Yu Jianming）。\n\n案件 22-50073 文件 1592 提交日期 03/24/23 登记日期 03/24/23 10:57:37 第 355 页，共 1063 页\n\n附件 C-19\n\nB2540（表格2540——规则2004审查传票）（12/15）案件 22-50073 文件 1592 提交日期 03/24/23 登记日期 03/24/23 10:57:37 第 356 页，共\n\n美国破产法院 1063\n\n康涅狄格地区\n\n关于 HO WAN KWOK（郭文贵）等人之案，\n\n1 案件编号 22-50073 (JAM)\n\n债务人 第11章\n\n（联合管理）\n规则2004审查传票\n\n致：Mercantile Bank International Corp.（国际商业银行公司）\n\n（传票指向的人员名称）\n\n证言：兹命令您于下列规定的时间、日期和地点出席，并根据《联邦破产程序规则》第2004条接受审查并作证。随附一份授权该审查的法院命令副本。\n\n地点　日期和时间\n\nPaul Hastings LLP（保罗·黑斯廷斯律师事务所）\n200 Park Avenue　[待定]\nNew York, New York 10166\n\n审查将通过以下方式记录：法庭记录员／速记员\n\n提交：您或您的代表还必须在审查时携带下列文件、电子存储信息或物品，并必须允许对该等材料进行检查、复制、测试或取样：\n\n见随附的文件提交请求。\n\n《联邦民事诉讼规则》第45条的下列规定，依《联邦破产程序规则》第9016条适用于破产案件，现随附于后——有关履行地点的第45(c)条；有关您作为受传票约束者所受保护的第45(d)条；以及有关您对本传票作出回应的义务及不作回应可能后果的第45(e)条和第45(g)条。\n\n日期：March , 2023\n\n法院书记员\n\n或\n\n书记员或副书记员签名　律师签名\n\n签发或请求本传票的、代表第11章受托人Luc A. Despins（卢克·A·德斯平斯）的律师姓名、地址、电子邮件地址和电话号码如下：\n\nDouglas S. Skalka, Esq.（道格拉斯·S·斯卡尔卡律师）；Neubert, Pepe & Monteith, P.C.（诺伊伯特、佩佩及蒙蒂思专业公司）；195 Church Street, New Haven, Connecticut 06510；dskalka@npmlaw.com；(203) 821-2000\n\n致签发或请求本传票者的通知\n\n如本传票命令在审判前提交文件、电子存储信息或有形物品，或检查场所，则必须在向被指向之人送达之前，向每一当事人送达通知及本传票副本。《联邦民事诉讼规则》第45(a)(4)条。\n\n软件版权 (c) 1996-2022 Best Case, LLC - www.bestcase.com Best Case Bankruptcy 1 本第11章案件中的债务人为Ho Wan Kwok（亦称Guo Wengui、Miles Guo和Miles Kwok，以及众多其他别名）（税务识别号码后四位：9595）、Genever Holdings LLC（Genever控股有限责任公司，税务识别号码后四位：8202）及Genever Holdings Corporation（Genever控股公司）。受托人、Genever Holdings LLC及Genever Holdings Corporation的邮寄地址为Paul Hastings LLP，200 Park Avenue，New York，NY 10166，转交Luc A. Despins，作为Ho Wan Kwok破产财产的受托人（仅为通知和通信之目的）。\n\n送达证明\n\n（除非《联邦民事诉讼规则》第45条要求，否则本节不应向法院提交。）\n\n我于（日期）收到向（个人姓名及职务，如有）发出的本传票。\n\n我通过如下方式向被指名人员交付副本，以送达本传票：\n\n于（日期）；或\n\n我未予执行而退回本传票，原因如下：\n\n除非本传票系代表美国或其官员或代理人签发，我还已向证人支付一天出席的费用及法律允许的里程费，金额为$ 。\n\n我的旅费为$，服务费为$，合计$。\n\n我在伪证处罚下声明，本信息真实且正确。\n\n日期：\n\n送达人签名\n\n印刷姓名及职务\n\n送达人地址\n\n有关尝试送达等事项的补充信息：\n\n《联邦民事诉讼规则》第45(c)、(d)、(e)及(g)条（生效日期12/1/13）（依《联邦破产程序规则》第9016条适用于破产案件）\n\n(c) 履行地点。\n\n(1) 审判、听证或证言录取。传票仅可按下列方式命令某人出席审判、听证或证言录取：\n\n(A) 在该人居住、受雇或经常亲自开展业务地点的100英里以内；或\n\n(B) 在该人居住、受雇或经常亲自开展业务所在州内，如该人\n\n(i) 是当事人或当事人的高级职员；或\n\n(ii) 被命令出席审判且不会产生重大费用。\n\n(2) 其他取证。传票可命令：\n\n(A) 在该人居住、受雇或经常亲自开展业务地点100英里以内的地点提交文件、电子存储信息或物品；以及\n\n(B) 在被检查场所对该场所进行检查。\n\n(d) 对受传票约束者的保护；执行。\n\n(1) 避免不当负担或费用；制裁。负责签发及送达传票的当事人或律师，必须采取合理措施，避免向受传票约束者施加不当负担或费用。要求履行的地区法院必须执行该义务，并对未遵守者的当事人或律师施加适当制裁，该制裁可包括损失的收入和合理的律师费。\n\n(2) 命令提交材料或允许检查。\n\n(A) 无须出席。被命令提交文件、电子存储信息或有形物品，或允许检查场所的人，无须亲自到提交或检查地点出席，除非同时被命令出席证言录取、听证或审判。\n\n(B) 异议。被命令提交文件或有形物品，或允许检查的人，可以向传票指定的当事人或律师送达书面异议，反对检查、复制、测试或取样任何或全部材料，或反对检查场所——或反对以所要求的一种或多种形式提交电子存储信息。异议必须在规定履行时间届满前或传票送达后14日内（以较早者为准）送达。如提出异议，适用下列规则：\n\n(i) 送达方可随时通知被命令之人，向要求履行的地区法院提出动议，请求命令强制提交或检查。\n\n(ii) 仅可依照命令所指示的方式要求实施该等行为，且该命令必须保护既非当事人亦非当事人高级职员的人免于承担因履行而产生的重大费用。\n\n(3) 撤销或修改传票。\n\n(A) 必须撤销或修改的情形。经及时提出动议，要求履行的地区法院必须撤销或修改具有下列情形的传票：\n\n(i) 未给予合理的履行时间；\n\n(ii) 要求某人在第45(c)条规定的地域限制之外履行；\n\n(iii) 要求披露享有特权或受其他保护的事项，且不存在适用的例外或放弃；或\n\n(iv) 对某人施加不当负担。\n\n(B) 可以撤销或修改的情形。为保护受传票约束或受其影响的人，要求履行的地区法院可以根据动议撤销或修改要求下列事项的传票：\n\n(i) 披露商业秘密或其他保密的研究、开发或商业信息；或\n\n(ii) 披露未受聘专家的意见或信息，而该等意见或信息并非描述争议中的特定事件，且系该专家未经当事人请求所进行研究的结果。\n\n(C) 以规定条件作为替代办法。在第45(d)(3)(B)条所述情形下，如送达方：\n\n(i) 证明对证言或材料具有实质需要，且若不承受不当困难即无法以其他方式满足该需要；并且\n\n(ii) 确保受传票人将获得合理补偿，\n\n法院可以不撤销或修改传票，而是在规定条件下命令出席或提交。\n\n(e) 回应传票的义务。\n\n(1) 提交文件或电子存储信息。下列程序适用于提交文件或电子存储信息：\n\n(A) 文件。对要求提交文件的传票作出回应的人，必须按其在通常业务过程中保存的方式提交文件，或者必须对文件进行组织和标注，使其对应于要求中的类别。\n\n(B) 未指定的电子存储信息提交形式。如传票未指定电子存储信息的提交形式，作出回应的人必须以其通常保存的一种或多种形式，或以一种或多种合理可用的形式提交该信息。\n\n(C) 仅以一种形式提交电子存储信息。作出回应的人无需以超过一种形式提交相同的电子存储信息。\n\n(D) 不可访问的电子存储信息。作出回应的人无需对其认定因不当负担或费用而无法合理访问的来源中的电子存储信息提供证据开示。在提出强制证据开示动议或申请保护令时，作出回应的人必须证明该信息因不当负担或费用而无法合理访问。如作出该证明，若请求方考虑到 Rule 26(b)(2)(C) 的限制后证明存在正当理由，法院仍可命令对该等来源进行证据开示。法院可规定该证据开示的条件。\n\n(2) 主张特权或保护。\n\n(A) 被扣留的信息。基于该信息享有特权或作为审判准备材料受保护而扣留被传票要求提供的信息的人，必须：(i) 明确提出该主张；以及\n\n(ii) 以一种在不披露本身享有特权或受保护的信息的情况下，能够使各方评估该主张的方式，说明被扣留文件、通信或有形物品的性质。\n\n(B) 已提交的信息。如为回应传票而提交的信息受到特权主张或作为审判准备材料受保护的主张约束，提出该主张的人可以将该主张及其依据通知收到该信息的任何一方。收到通知后，一方必须立即返还、隔离或销毁所指定的信息及其持有的任何副本；在该主张得到解决前，不得使用或披露该信息；如该方在收到通知前已披露该信息，必须采取合理措施追回该信息；并且可以立即将该信息密封提交至要求遵从所在地区的法院，以裁定该主张。提交该信息的人必须保存该信息，直至该主张得到解决。\n\n(g) 蔑视法庭。要求遵从所在地区的法院——以及在动议移送后，签发传票的法院——可认定已被送达但无充分理由不遵从传票或与之相关命令的人构成蔑视法庭。\n\n如需查阅传票材料，见 Fed.R.Civ.P.45(a) Committee Note (2013)\n\n……\n\n文件提交请求\n\nI. 指示\n\n1. 除非另有说明，下列文件请求（以下简称“请求”，每一项称为“一项请求”）必须分别并具体作出回应。除非出于善意提出异议，否则必须完整回答每一项请求；如提出异议，必须如下文所述详细说明贵方异议的理由。如异议仅涉及一项请求的一部分，或其中包含的某一词语、短语或条款，贵方仅须说明对该部分的异议，并对其余请求作出回应。\n\n2. 电子存储信息必须依照下列指示提交：\n\na. 图像。黑白图像必须为 300 DPI Group IV 单页 TIFF 文件。彩色图像必须以 JPEG 格式提交。文件名不得包含嵌入空格或特殊字符（包括逗号）。文件夹名称不得包含嵌入空格或特殊字符（包括逗号）。所有 TIFF 图像文件必须具有唯一的文件名，即 Bates 编号。每一图像的右下角必须加盖连续的 Bates 编号。每个文件夹中的 TIFF 文件数量不得超过 1000 个文件。Excel 电子表格应具有一个以该文件 Bates 编号命名的占位图像。\n\nb. 图像加载文件\n\na. Concordance® 数据文件。数据文件（.DAT）包含将被加载至 Concordance® 数据库的所有字段化信息。.DAT 文件的第一行必须为标明字段名称的标题行。.DAT 文件必须使用下列 Concordance® 默认分隔符：逗号 ASCII 字符（020）引号 þ ASCII 字符（254）。日期字段应以 mm/dd/yyyy 格式提供。日期和时间字段必须为两个独立字段。如文件包括已生成图像的电子邮件及附件，必须包含附件字段，以保留电子邮件与其附件之间的父/子关系。必须包含 OCRPATH 字段，以提供所提交存储介质上提取文本文件的文件路径和名称。文本文件必须以 FIRSTBATES 命名。不得将文本包含在 .DAT 文件中。对于含有原生文件的文件，必须包含 LINK 字段，以提供原生文件的文件路径和名称。原生文件必须以 FIRSTBATES 命名。\n\nb. Concordance Image® 或 Opticon 交叉引用文件。图像交叉引用文件（.LOG 或 .OPT）将图像链接至数据库记录。其应为以逗号分隔的文件，每行由七个字段组成；数据库中的每一图像均应在交叉引用文件中有一行，格式如下：ImageID,VolumeLabel,ImageFilePath,DocumentBreak,FolderBreak,Box Break,PageCount。\n\nc. 文件文本。文本必须作为单独的文本文件提交，而非作为 .DAT 文件中的字段提交。通往文本文件的完整路径（OCRPATH）应包含于 .DAT 文件中。建议使用以 FIRSTBATES/Image Key 命名的文件级 ANSI 文本文件。提取的文本文件必须置于单独文件夹中，且每个文件夹中的文本文件数量不得超过 1,000 个文件。文件夹名称中不得有特殊字符（包括逗号）。文本文件必须按文件级别提供。\n\nd. 特定文件类型的原生提交。为充分理解其内容和含义而合理需要以原生格式查看的文件类型，必须以原生格式提交。这些包括但不限于电子表格、类似电子表格的文件（Microsoft Excel、逗号分隔值、制表符分隔值等）、Microsoft PowerPoint 或其他特殊演示文件、数据库文件以及音频/视频文件。提供一张带有 Bates 编号的分隔页图像，表明存在原生文件，并在 .dat 文件中将通往原生文件的路径作为字段列入。所提交的原生文件须以与该文件分隔页相对应的 Bates 编号命名。将原生文件归入按递增方式命名的“NATIVE”目录中，并与图像目录分开。\n\ne. 去重。对于存在完全重复件的每一电子文件，仅提交一份副本。对于电子邮件，应根据由 BCC、Body、CC、From、IntMsgID、To 和 Attach 属性生成的 MD5 哈希值合并重复件。对于电子邮件附件和独立电子文件，应根据整个文件的 MD5 哈希值合并重复件。\n\nf. 元数据。以符合 Concordance 标准的加载文件（.dat）形式提交每份文件的提取元数据。.DAT 文件的第一行必须为标明字段名称的标题行。.DAT 文件必须使用下列 Concordance 默认分隔符：逗号 , ASCII 字符（020）引号 þ ASCII 字符（254）。\n\n日期字段应以 mm/dd/yyyy 格式提供。日期和时间字段必须为两个独立字段。下列为必需元数据：\n\nCase 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 361 of 1063\n\n字段名称　示例数据　说明\n\nFIRSTBATES　EDC0000001　原生文件文件/电子邮件的第一个 Bates 编号\n\nLASTBATES　EDC0000001　原生文件文件/电子邮件的最后一个 Bates 编号\n\n**LASTBATES 字段应针对单页文件填写\n\nATTACHRANGE　EDC0000001 - EDC0000015　父文件首页的 Bates 编号至最后一个附件“子”文件最后一页的 Bates 编号\n\nBEGATTACH　EDC0000001　附件范围的第一个 Bates 编号\n\nENDATTACH　EDC0000015　附件范围的最后一个 Bates 编号\n\nCUSTODIAN　Smith, John（约翰·史密斯）　电子邮件：电子邮件所在的邮箱\n原生文件：文件来源的个人或部门名称\n\nFROM　John Smith（约翰·史密斯）　电子邮件：发件人\n原生文件：文件作者\n**多个条目应以分号分隔\n\nTO　Coffman, Janice（珍妮丝·科夫曼）; LeeW（李W） [mailto:LeeW@MSN.com]　收件人\n**多个条目应以分号分隔\n\nCC　Frank Thompson（弗兰克·汤普森） [mailto:frank_Thompson@cdt.com]　抄送收件人\n**多个条目应以分号分隔\n\nBCC　John Cain（约翰·凯恩）　密送收件人\n**多个条目应以分号分隔\n\nSUBJECT　Board Meeting Minutes（董事会会议纪要）　电子邮件：电子邮件主题行 原生文件：文件标题（如有）\n\nFILE_NAME　BoardMeetingMinutes.docx　原生文件：原始原生文件名称，包括扩展名\n\nDATE_SENT　10/12/2010　电子邮件：发送电子邮件的日期\n原生文件：（空）\n\nTIME_SENT/TIME_ZONE　07:05 PM GMT　电子邮件：发送电子邮件的时间/电子邮件标准化所采用的时区\n\nTIME_ZONE　GMT　在转换过程中电子邮件被标准化所采用的时区。\n\nLINK　EDC0000001.msg　电子邮件或原生文件文件的超链接\n**链接文件必须按 FIRSTBATES 编号命名\n\nFILE_EXTEN　MSG　代表电子邮件或原生文件的文件类型扩展名\n\nAUTHOR　John Smith（约翰·史密斯）　电子邮件：（空）\n原生文件：文件作者\n\nDATE_CREATED　10/10/2010　电子邮件：（空）\n原生文件：文件创建日期\n\nCase 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 362 of 1063\n\nTIME_CREATED　10:25 AM　电子邮件：（空）\n原生文件：文件创建时间\n**该数据必须为单独字段，且不得与 DATE_CREATED 字段合并\n\nDATE_MOD　10/12/2010　电子邮件：（空）\n原生文件：文件最后修改日期\n\nTIME_MOD　07:00 PM　电子邮件：（空）\n原生文件：文件最后修改时间\n**该数据必须为单独字段，且不得与 DATE_MOD 字段合并\n\nDATE_ACCESSD　10/12/2010　电子邮件：（空）\n原生文件：最后访问文件的日期\n\nTIME_ACCESSD　07:00 PM　电子邮件：（空）\n原生文件：最后访问文件的时间\n**该数据必须为单独字段，且不得与 DATE_ACCESSD 字段合并\n\nFILE_SIZE　5,952　原生文件文件/电子邮件的大小，以 KB 计\n\nPGCOUNT　1　原生文件文件/电子邮件中的页数\n\nPATH　Email:（电子邮件：）（空）\nAgenda.doc　原生文件：原生文件文件的存储路径，包括原始文件名称。\n\nINTFILEPATH　Personal Folders\\Deleted Items\\Board Meeting Minutes.msg　电子邮件：电子邮件的原始位置，包括原始文件名称。\n原生文件：（空）\n\nINTMSGID　<000805c2c71b\\$75977050\\$cb8306d1@MSN>　电子邮件：唯一消息 ID 原生文件：（空）\n\nMD5HASH　d131dd02c5e6eec4693d9a0698aff95c2fcab58712467eab4004583eb8fb7f89　文件的 MD5 哈希值。\n\nOCRPATH　TEXT/001/EDC0000001.txt　原生文件提取文本的路径\n\n3. 每一项请求均独立适用并应独立解释，除非另有说明，任何请求均不限制任何其他请求的范围。\n\n4. 所有文件均应按照通常业务过程中保存的方式提交，或者应进行组织和标注以对应于这些请求中的类别。\n\n5. 本文所含每一项请求均延及所有文件：(a) 由贵方占有、保管或控制的文件；或 (b) 由任何代表贵方行事的人占有、保管或控制的文件，\n\nCase 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 363 of 1063\n\n包括贵方的律师或其他代表和顾问。每份文件均应完整提交。\n\n6. 如要求贵方提供已不再由贵方占有、保管或控制的文件，则贵方的答复必须：(a) 详细说明该文件的性质及其内容；(b) 指明编制或撰写该文件的人士（以及，如适用，该文件被发送给的人士）；(c) 指明该文件编制或创建的日期；(d) 说明该文件是否：(i) 遗失或丢失，(ii) 已被销毁，(iii) 已自愿或非自愿地转交他人，或 (iv) 以其他方式处置；(e) 说明该等处置的理由，以及围绕该等处置的事实和情形；(f) 指明授权该等处置的人士；(g) 指明该等处置的日期或大致日期；(h) 说明该文件最近一次由贵方占有、保管或控制的时间；以及 (i) 指明目前占有、保管或控制该文件的人士（如有）。\n\n7. 如要求贵方提供已被销毁的文件，则除前述指示所要求的信息外，贵方的答复还必须说明：(a) 该文件被销毁的理由；(b) 销毁该文件的人士的身份；以及 (c) 指示销毁该文件的人士的身份。\n\n8. 如贵方主张所要求的文件享有特权或属于律师工作成果，则贵方的答复必须：(a) 说明：(i) 足以支持贵方关于该文件享有特权之主张的文件描述，(ii) 文件标题，(iii) 文件日期，(iv) 文件作者，(v) 文件收件人，(vi) 收到或阅览该文件原件或任何草稿、副本或复制件的每一人士的身份，(vii) 该文件本身或该文件中包含或提及的任何信息是否由任何其他人士占有、保管或控制；如是，则应指明该等人士的身份，\n案件 22-50073 文件 1592 于 03/24/23 提交 于 03/24/23 10:57:37 登记 第 364 页，共 1063 页\n\n并说明该等人士如何取得该信息，(viii) 据以拒绝提供该文件的特权主张，以及 (ix) 贵方将据以支持该等特权主张的所有情形；以及 (b) 就根据 D. Conn. L. Civ. R. 26(e) 主张特权而拒绝提供的每份文件，制作一份特权日志，其中载有本指示第 (a) 部分所要求的全部信息。对于文件请求中未提出特权或工作成果主张的任何部分，应完整提供回应性文件。\n\n9. 如一份原本具有回应性的文件的一部分包含受特权主张约束的信息，则仅应依照上述指示从该文件中删除或遮盖受特权主张约束的部分，其余部分应予提供。\n\n10. 该等请求具有持续性。现指示贵方：(a) 在获悉先前答复不完整或不正确后，立即补充或更正其后得知不完整或不正确的任何答复；以及 (b) 提供根据以下规定所要求的任何额外文件\n\n11. 如文件为英语以外的语言，贵方应提供该文件。如文件为英语以外的语言，且存在英文译本，贵方应同时提供两份文件。\n\n12. 对实体的一切提及均包括其所有关联方。\n\n13. 对个人姓名的一切提及均包括所有别名、化名或昵称。\n案件 22-50073 文件 1592 于 03/24/23 提交 于 03/24/23 10:57:37 登记 第 365 页，共 1063 页\n\n14. 除非另有明确说明，文件请求所涵盖的期间为自 February 5, 2015 起至文件请求答复到期之日止。\n\nII. 解释规则\n\n15. (a) 任何单数名词的使用，应解释为包括复数，反之亦然；以及 (b) 任何时态动词的使用，应解释为包括该动词所有其他时态的使用。\n\n16. (a) “和”及“或”应在必要时解释为连词或选择词，以使任何请求涵盖原本可能被解释为不在其范围内的所有答复；以及 (b) “每一”及“任何”应视为包括并涵盖“每个”及“所有”二词。\n\nIII. 定义\n\n经 D. Conn. Bankr. L.R. 2004-1(a) 纳入的 D. Conn. L. Civ. R. 26(c) 所规定的定义，以及 D. Conn. L. Civ. R. 26(d) 所规定的解释规则，适用于该等文件请求。此外，本文件请求中使用的下列术语具有下列含义：\n\n1. “贵方”或“贵方的”或“贵方本人”系指并包括 Mercantile Global Holdings, Inc.（环球商业控股公司）、其雇员、代理人、律师、顾问或任何代表其行事的人士。\n\n2. “债务人”系指 Ho Wan Kwok（郭文贵）（又名 Miles Kwok、Miles Guo、Guo Wengui、Guo Haoyun、郭文贵，或任何其他化名），连同其雇员、代理人、律师、顾问或任何代表其行事的人士。\n案件 22-50073 文件 1592 于 03/24/23 提交 于 03/24/23 10:57:37 登记 第 366 页，共 1063 页\n\n3. “债务人之子”系指 Qiang Guo（郭强）（又名 Mileson Kwok、郭强，或任何其他化名），连同其雇员、代理人、律师、顾问或任何代表其行事的人士。\n\n4. “债务人之女”系指 Mei Guo（郭美）（又名 Mei Gui、郭美，或任何其他化名），连同其雇员、代理人、律师、顾问或任何代表其行事的人士。\n\n5. “债务人所谓妻子”系指 Hing Chi Ngok（岳庆芝）（又名 Hing Chi Ng、Yue Qingzhi、岳庆芝，或任何其他化名），连同其雇员、代理人、律师、顾问或任何代表其行事的人士。\n\n6. “债务人家属”系指单独及共同而言的债务人、债务人之子、债务人之女及债务人所谓妻子，以及与债务人有任何其他亲属关系的人士。\n\n7. “2004 取证对象”系指单独及共同而言的债务人、债务人家属、ACA Capital Group Limited（ACA资本集团有限公司）、Himalaya International Financial Group Ltd.（喜马拉雅国际金融集团有限公司）、Himalaya International Clearing Ltd.（喜马拉雅国际清算有限公司）、Himalaya International Payments Ltd.（喜马拉雅国际支付有限公司）、Himalaya International Reserves Ltd.（喜马拉雅国际储备有限公司）、Jesse Brown（杰西·布朗）、William Je（威廉·杰）、Eastern Profit Corporation Limited（东方利润有限公司）、HK International Funds Investments (USA) Limited LLC（香港国际基金投资〈美国〉有限责任公司）、Bravo Luck Limited（好运有限公司）、Golden Spring (New York) Ltd.（金泉〈纽约〉有限公司）、Lamp Capital LLC（蓝普资本有限责任公司）、Greenwich Land LLC（格林威治土地有限责任公司）、Qu Guo Jiao（郭娇）、Daniel Thomas Podhaskie（丹尼尔·托马斯·波达斯基）、Yvette Wang（王燕萍）（又名 Yanping Wang，又名 Yan Ping Wang）、Ace Decade Holdings Limited（王牌十年控股有限公司）、Dawn State Limited（黎明州有限公司）、Rule of Law Society IV Inc.（法治协会IV公司）、Rule of Law Foundation III, Inc.（法治基金会III公司）、Rule of Law Foundation IV, Inc.（法治基金会IV公司）、Rule of Law Fund（法治基金）、Rule of Law Society（法治协会）、GTV Media Group, Inc.（GTV媒体集团公司）、Voice of Guo Media, Inc.（郭之声媒体公司）、Saraca Media Group Inc.（萨拉卡媒体集团公司）、Genever Holdings Corporation（吉尼弗控股公司）、Genever Holdings LLC（吉尼弗控股有限责任公司）、Gnews Media Group Inc.（Gnews媒体集团公司）、G Fashion LLC（G时尚有限责任公司）、Gmusic LLC（G音乐有限责任公司）、Gnews LLC（Gnews有限责任公司）、Geducation（G教育）、GFNY, Inc.（GFNY公司）、G-Club Investments Limited（G俱乐部投资有限公司）、G Club Operations LLC（G俱乐部运营有限责任公司）、G Club US Operations Inc.（G俱乐部美国运营公司）、G Club US Operations LLC（G俱乐部美国运营有限责任公司）、G Live, LLC（G直播有限责任公司）、Gbroadcast, LLC（G广播有限责任公司）、Gposts LLC（G帖子有限责任公司）、HCHK Property Management，\n案件 22-50073 文件 1592 于 03/24/23 提交 于 03/24/23 10:57:37 登记 第 367 页，共 1063 页\n\nInc.（HCHK物业管理公司）、HCHK Technologies, Inc.（HCHK科技公司）、FMV Ltd./Freedom Media Venture Ltd.（FMV有限公司／自由媒体创投有限公司）、Roscalitar 2（Roscalitar 2）、Himalaya New World Inc.（喜马拉雅新世界公司）、US Himalaya Capital Inc.（美国喜马拉雅资本公司）、Hudson Diamond Holding, Inc.（哈德逊钻石控股公司）、Hudson Diamond Holding LLC（哈德逊钻石控股有限责任公司）、Hudson Diamond NY LLC（哈德逊钻石纽约有限责任公司）、Infinity Treasury Management Inc.（无限财资管理公司）、Lexington Property and Staffing, Inc.（列克星敦物业与人力公司）、AI Group Holdings Inc.（AI集团控股公司）、Booming Sail New York LLC（兴盛帆纽约有限责任公司）、Himalaya Ventures LLC（喜马拉雅创投有限责任公司）、Himalaya Ventures LLC（喜马拉雅创投有限责任公司）、Himalaya Investment LLC（喜马拉雅投资有限责任公司）、New York MOS Himalaya LLC（纽约MOS喜马拉雅有限责任公司）、MOS Himalaya LLC（MOS喜马拉雅有限责任公司）、Crane Advisory Group（克兰咨询集团）、Maywind Trading LLC（五月风贸易有限责任公司）、Gettr USA, Inc.（Gettr美国公司）、Han Chunguang（韩春光）、Bingshang Jiao（焦冰上）、Karin Maistrello（卡琳·迈斯特雷洛）、Mary Jiang（江玛丽）、Jiaming Liu（刘佳明）及 Wencong Wang（王文聪）。\n\n8. “Hamilton 实体”系指 Hamilton M&A Fund SP（汉密尔顿并购基金SP）、Hamilton Opportunity Fund SPC（汉密尔顿机会基金SPC）、Hamilton Capital Holdings Inc.（汉密尔顿资本控股公司）、Hamilton Investment Management Limited（汉密尔顿投资管理有限公司）、Midvale Avenue Limited（米德维尔大道有限公司）、Hamilton Fintech Ltd.（汉密尔顿金融科技有限公司）及 Hamilton Cyber Ltd.（汉密尔顿网络有限公司）。\n\n9. “包括”或其任何变体，系指“包括但不限于”。\n\n10. “和”及“或”系指“和／或”，并应同时作连词及选择词解释，以最大限度扩大其范围。\n\n11. “任何”、“所有”及“每一”系指“每一个及每一个”。\n\n12. “每一”及“每个”系指“每一个及每一个”。\n\n13. “第三方”系指贵方本人以外的人士或实体。\n\n14. “转让”具有《破产法》section 101(54) 赋予该词的含义。\n\n15. “文件”系指属于 Fed. R. Civ. P. 34 范围内的任何信息或物品，并包括但不限于贵方占有、保管或控制之中或曾经处于贵方占有、保管或控制之中的各种、各类、各种性质或描述的每一书面、记录或图形材料，包括电子邮件的所有印刷及电子副本、以电子形式保存的计算机文件、\n案件 22-50073 文件 1592 于 03/24/23 提交 于 03/24/23 10:57:37 登记 第 368 页，共 1063 页\n\n通信、备忘录、磁带、速记或手写笔记、各种书面表格、图表、蓝图、图纸、草图、曲线图、计划、文章、规格说明、日记、信函、电报、照片、会议记录、合同、协议、调查、计算机打印件、各种数据汇编、电传、传真、电子邮件、短信、即时消息、语音消息、发票、订单表格、支票、汇票、对账单、贷项通知单、报告、持仓报告、摘要、索引、账簿、分类账、笔记本、附表、透明胶片、录音、目录、广告、宣传材料、影片、录像带、录音带、CD、计算机磁盘、宣传册、小册子、穿孔卡、工时单、推文、社交媒体帖子或任何其他种类的书面或记录材料，以及其所有元数据，无论以何种方式存储（无论为有形或电子形式）、记录、制作或复制；亦包括但不限于上述任何材料的草稿或副本，如其中含有原始文件中未见的任何种类笔记、评论或标记，或在其他方面与原始文件不相同。\n\n16. “人士”系指个人、公司、独资企业、合伙企业、协会或任何其他实体。“人士”亦包括任何代理人、代表或专家，包括但不限于律师或财务顾问。\n\n17. “实体”系指任何自然人、公司、合伙企业、子公司、独资企业、商号、董事会、合资企业、协会、机构、主管机关、委员会或其他商业实体或法人，以及任何关联方、代理人、母公司，包括但不限于律师、财务顾问或任何其他代表。\n\n18. “关于”系指涉及、描述、构成、提及、与之相关、支持、赞成、反对、强化、削弱、位于其中、结合其予以考虑、与之有关、证明、表明、报告、记录、暗指、答复、与之相连、评论、就其而言、关于、与之有关、讨论、显示、描述、反映、分析、构成及属于。\n案件 22-50073 文件 1592 于 03/24/23 提交 于 03/24/23 10:57:37 登记 第 369 页，共 1063 页\n\n19. 就任何特定主题而言，“与……有关”、“涉及”或“相关”系指但不限于构成、包括、涉及、载有、体现、反映、识别、陈述、直接或间接提及，或以任何方式与所识别的特定主题相关的任何文件。\n\n20. “通信”系指，在最广义且不限于此，任何信息或知识（以事实、观点、询问或其他形式）的传递。“通信”还指所有会谈、协议、询问或答复，无论是当面、通过电话、书面形式，还是通过电子传输设备，并包括但不限于所有信函、电子邮件、录音、传输单、备忘录、电话通信、语音留言、电报、传真、影印传真、电传、即时消息、聊天、短信、发布至留言板或群聊的内容、社交媒体帖子、推文、上传至任何视频平台的视频、电话记录，或内部传送或与第三方传送的记录。\n\n21. “资产”系指受占有、保管或控制的任何具有经济价值的项目。资产包括所有不动产和动产，包括但不限于房地产、土地、房屋、公寓、共管公寓、汽车、游艇、船只、飞机、喷气式飞机、直升机、现金、银行账户、加密货币、证券、应收账款、存货及其他有形和无形财产。\n案件 22-50073 文书 1592 提交于 03/24/23 录入于 03/24/23 10:57:37 第 370 页，共 1063 页\n\nIV. 须提交的文件\n\n1. 贵方与债务人、Ehsan Masud（艾赫桑·马苏德）、David Fallon（戴维·法伦）、Hamilton Entities（汉密尔顿实体）或 2004 Discovery Targets（2004 证据开示对象）之间的所有通信，包括但不限于 William Je（叶简明，亦称 Je Kin Ming；亦称 Kin Je；亦称 William Yu；亦称 Yu Jianming）。\n\n2. 与贵方和债务人、Ehsan Masud、David Fallon、Hamilton Entities 或 2004 Discovery Targets 之间任何通信有关的所有文件，包括但不限于 William Je（亦称 Je Kin Ming；亦称 Kin Je；亦称 William Yu；亦称 Yu Jianming）。\n\n3. 与债务人、Ehsan Masud、David Fallon、Hamilton Entities 或 2004 Discovery Targets 作出、与其进行或代表其进行的任何实际、潜在或拟议投资、商业往来或交易有关的所有文件和通信，包括但不限于 William Je（亦称 Je Kin Ming；亦称 Kin Je；亦称 William Yu；亦称 Yu Jianming）。\n\n4. 与涉及债务人、Ehsan Masud、David Fallon、Hamilton Entities 或 2004 Discovery Targets 的任何反洗钱、了解你的客户或其他合规活动有关的所有文件和通信，包括但不限于 William Je（亦称 Je Kin Ming；亦称 Kin Je；亦称 William Yu；亦称 Yu Jianming），包括但不限于债务人、Ehsan Masud、David Fallon、Hamilton Entities 或 2004 Discovery Targets 向贵方或任何国家、州、地方、执法组织或主权实体的任何监管机构提供的任何信息，包括但不限于 William Je（亦称 Je Kin Ming；亦称 Kin Je；亦称 William Yu；亦称 Yu Jianming）。\n\n5. 与下列事项有关的所有文件和通信：(i) 任何国家、州、地方、执法组织或主权实体的任何监管机构，包括但不限于 Bank of England（英格兰银行）、United States Federal Reserve（美国联邦储备系统）、U.S. Securities and\n案件 22-50073 文书 1592 提交于 03/24/23 录入于 03/24/23 10:57:37 第 371 页，共 1063 页\n\nExchange Commission（美国证券交易委员会）、Commodities Futures Trading Commission（商品期货交易委员会）、FINRA（美国金融业监管局）、China Securities Regulatory Commission（中国证券监督管理委员会）、People's Bank of China（中国人民银行）、Hong Kong Securities and Futures Commission（香港证券及期货事务监察委员会）及 Hong Kong Monetary Authority（香港金融管理局），(ii) 债务人、Ehsan Masud、David Fallon、Hamilton Entities 或 2004 Discovery Targets，包括但不限于 William Je（亦称 Je Kin Ming；亦称 Kin Je；亦称 William Yu；亦称 Yu Jianming）。\n附件 C-20\nB2540（表格 2540——《规则 2004 审查传票》）（12/15）案件 22-50073 文书 1592 提交于 03/24/23 录入于 03/24/23 10:57:37 第 373 页，共\n\n美国破产法院 1063\n\n康涅狄格地区\n\n关于 HO WAN KWOK（郭文贵）等人的案件，\n\n1 案号 22-50073 (JAM)\n\n债务人 第 11 章\n\n（合并管理）\n规则 2004 审查传票\n\n致：Hamilton M&A Fund SP（汉密尔顿并购基金 SP）\n\n（传票所指向人员的姓名）\n\n证言：特此命令贵方于下列规定的时间、日期和地点出席，并根据《联邦破产程序规则》第 2004 条接受审查并作证。随附授权进行该审查的法院命令副本。\n\n地点　日期和时间\n\nPaul Hastings LLP（普衡律师事务所）\n200 Park Avenue　[TBD]\nNew York, New York 10166\n\n审查将以下列方式记录：法庭书记员／速记员\n\n提交：贵方或贵方代表还必须携带下列文件、电子存储信息或物品参加审查，并必须允许对该材料进行检查、复制、测试或取样：\n见随附的文件提交请求。\n\n下列《联邦民事诉讼规则》第 45 条的规定，经《联邦破产程序规则》第 9016 条适用于破产案件，现随附于后——关于履行地点的第 45(c) 条；关于对作为传票对象的人员之保护的第 45(d) 条；以及关于贵方回应本传票之义务及不予回应的潜在后果的第 45(e) 条和第 45(g) 条。\n\n日期：March , 2023\n\n法院书记员\n\n或\n\n书记员或副书记员签名　律师签名\n\n代表发出或请求本传票的第 11 章受托人 Luc A. Despins（卢克·A·德斯平斯）的律师姓名、地址、电子邮件地址和电话号码如下：\n\nDouglas S. Skalka, Esq.（道格拉斯·S·斯卡尔卡，律师）；Neubert, Pepe & Monteith, P.C.（诺伊伯特、佩佩及蒙泰斯专业公司）；195 Church Street, New Haven, Connecticut 06510；dskalka@npmlaw.com；(203) 821-2000\n\n向发出或请求本传票之人的通知\n\n如本传票要求在审判前提交文件、电子存储信息或有形物品，或检查场所，则必须在向传票所指向人员送达之前，向各方送达通知及本传票副本。Fed. R. Civ. P. 45(a)(4)。\n\n软件版权 (c) 1996-2022 Best Case, LLC - www.bestcase.com Best Case Bankruptcy 1 本第 11 章案件中的债务人为 Ho Wan Kwok（亦称 Guo Wengui、Miles Guo 和 Miles Kwok，以及许多其他别名）（税务识别号码后四位：9595）、Genever Holdings LLC（杰尼弗控股有限责任公司）（税务识别号码后四位：8202）以及 Genever Holdings Corporation（杰尼弗控股公司）。受托人、Genever Holdings LLC 及 Genever Holdings Corporation 的邮寄地址为 Paul Hastings LLP, 200 Park Avenue, New York, NY 10166，转交 Luc A. Despins，作为 Ho Wan Kwok 财产的受托人（仅为通知和通信之目的）。\n\n送达证明\n\n（除非 Fed. R. Civ. P. 45 要求，否则本节不应向法院提交。）\n\n本人于（日期）收到向（个人姓名及职务，如有）发出的本传票。\n\n本人以下列方式向被指定人员交付副本以送达本传票：\n\n于（日期）送达；或者\n\n本人因下列原因未执行而退回本传票：\n\n除非本传票代表美国或其官员或代理人发出，本人还已向证人支付一天出席费用及法律准许的里程费，金额为 \\$ 。\n\n本人的差旅费用为 \\$，服务费用为 \\$，合计 \\$ 。\n\n本人在伪证处罚的约束下声明，该等信息真实、正确。\n\n日期：\n\n送达人员签名\n\n正楷姓名及职务\n\n送达人员地址\n\n有关尝试送达等事项的补充信息：\n《联邦民事诉讼规则》第 45(c)、(d)、(e) 和 (g) 条（自 12/1/13 起生效）（经《联邦破产程序规则》第 9016 条适用于破产案件）\n(c) 履行地点。\n\n(1) 审判、听证或证言记录。传票仅可按如下方式命令人员出席审判、听证或证言记录：\n\n(A) 在该人员居住、受雇或经常亲自从事商业活动地点的 100 英里范围内；或者\n\n(B) 在该人员居住、受雇或经常亲自从事商业活动所在州内，如该人员\n\n(i) 是当事人或当事人的高级职员；或者\n\n(ii) 被命令出席审判且不会产生重大费用。\n\n(2) 其他证据开示。传票可命令：\n\n(A) 在该人员居住、受雇或经常亲自从事商业活动地点的 100 英里范围内某地点提交文件、电子存储信息或物品；以及\n\n(B) 在待检查场所进行场所检查。\n(d) 对作为传票对象人员的保护；执行。\n\n(1) 避免不当负担或费用；制裁。负责发出和送达传票的当事人或律师必须采取合理措施，避免对作为传票对象的人员施加不当负担或费用。要求履行的地区法院必须执行该义务，并对未遵守该义务的当事人或律师施加适当制裁，其中可包括收入损失和合理的律师费。\n\n(2) 命令提交材料或允许检查。\n\n(A) 无须出席。被命令提交文件、电子存储信息或有形物品，或允许检查场所的人员，无须亲自出席提交或检查地点，除非同时被命令出席证言记录、听证或审判。\n\n(B) 异议。被命令提交文件或有形物品，或允许检查的人员，可以就检查、复制、测试或取样任何或全部材料，或检查场所，或以所请求的一种或多种形式提交电子存储信息，向传票指定的当事人或律师送达书面异议。异议必须在规定履行时间或传票送达后 14 日中较早者之前送达。如提出异议，适用下列规则：\n\n(i) 在任何时候，送达方可在通知被命令人员后，向要求履行的地区法院提出动议，请求作出强制提交或检查的命令。\n\n(ii) 仅可按照命令所指示的方式要求实施该等行为，且该命令必须保护既非当事人亦非当事人高级职员的人员，使其免受因履行而产生的重大费用。\n\n(3) 撤销或修改传票。\n\n(A) 必须撤销或修改的情形。应及时提出的动议，要求履行的地区法院必须撤销或修改下列传票：\n\n(i) 未留出合理履行时间；\n\n(ii) 要求人员在第 45(c) 条规定的地理范围以外履行；\n\n(iii) 要求披露享有特权或受其他保护的事项，且不存在适用的例外或豁免；或者\n\n(iv) 对人员施加不当负担。\n\n(B) 可以撤销或修改的情形。为保护作为传票对象或受传票影响的人员，要求履行的地区法院可以根据动议撤销或修改要求下列事项的传票：\n\n(i) 披露商业秘密或其他保密的研究、开发或商业信息；或者\n\n(ii) 披露未受聘专家的意见或信息，该等意见或信息并非描述争议中的具体事件，且源自并非任何当事人要求该专家进行的研究。\n\n(C) 以规定条件作为替代办法。在第 45(d)(3)(B) 条所述情形中，如送达方：\n\n(i) 证明对该证言或材料具有重大需要，且无法在不造成不当困难的情况下以其他方式满足该需要；以及\n\n(ii) 确保被传唤人员将获得合理补偿，\n\n法院可以不撤销或修改传票，而命令在规定条件下出席或提交。\n(e) 回应传票的义务。\n\n(1) 提交文件或电子存储信息。下列程序适用于提交文件或电子存储信息：\n\n(A) 文件。回应要求提交文件的传票的人员，必须按照文件在正常业务过程中保存的方式提交，或者必须将文件整理并标注，以对应请求中的类别。\n\n(B) 未指定的电子存储信息提供形式。如传票未指定提供电子存储信息的形式，作出回应的人必须以其通常保存的一种或多种形式，或以一种或多种合理可用的形式提供该信息。\n\n(C) 仅以一种形式提供的电子存储信息。作出回应的人无需以一种以上的形式提供同一电子存储信息。\n\n(D) 无法合理访问的电子存储信息。作出回应的人无需提供来自其认定为因不当负担或费用而无法合理访问的来源的电子存储信息的证据开示。在要求强制证据开示的动议或保护令动议中，作出回应的人必须证明该信息因不当负担或费用而无法合理访问。如作出该等证明，若提出请求的一方在考虑第26(b)(2)(C)条的限制后证明有正当理由，法院仍可命令对该等来源进行证据开示。法院可为该证据开示规定条件。\n\n(2) 主张特权或保护。\n\n(A) 被扣留的信息。根据该信息享有特权或作为审判准备材料受保护的主张而扣留被传唤信息的人必须：(i) 明确提出该主张；并且\n\n(ii) 以一种方式描述被扣留文件、通信或有形物的性质，该方式在不披露本身享有特权或受保护的信息的情况下，使当事人能够评估该主张。\n\n(B) 已提供的信息。如为回应传票而提供的信息受到特权主张或作为审判准备材料受保护的主张约束，提出该主张的人可将该主张及其依据通知收到该信息的任何一方。收到通知后，一方必须立即返还、隔离或销毁所指明的信息及其持有的任何副本；在该主张得到解决前，不得使用或披露该信息；如该方在收到通知前已披露该信息，必须采取合理措施追回该信息；并可立即将该信息密封提交给要求履行义务所在地区的法院，以裁定该主张。提供该信息的人必须保存该信息，直至该主张得到解决。\n\n(g) 藐视法庭。要求履行义务所在地区的法院——以及在动议被移送后，发出传票的法院——可认定已被送达但无充分理由不遵守传票或与其有关命令的人构成藐视法庭。\n\n有关获取传票材料，请参见 Fed.R.Civ.P.45(a) 委员会说明（2013）\n\n……\n\n文件出示请求\n\nI. 指示\n\n1. 除非另有说明，下列文件请求（统称“请求”，单称“一项请求”）必须分别且具体地作出答复。除非善意地提出异议，否则必须完整答复每项请求；如提出异议，则应如下文所述详细说明您提出异议的理由。如异议仅涉及一项请求的一部分，或其中所含的某个词语、短语或条款，您仅须说明对该部分的异议，并答复请求的其余部分。\n\n2. 电子存储信息必须依照下列指示提供：\n\n- a. 图像。黑白图像必须为300 DPI Group IV 单页 TIFF 文件。彩色图像必须以 JPEG 格式提供。文件名不得包含嵌入的空格或特殊字符（包括逗号）。文件夹名称不得包含嵌入的空格或特殊字符（包括逗号）。所有 TIFF 图像文件必须具有唯一文件名，即 Bates 编号。每幅图像右下角必须标注连续的 Bates 编号。每个文件夹中的 TIFF 文件数量不得超过1000个。Excel 电子表格应具有以该文件的 Bates 编号命名的占位图像。\n\n- b. 图像加载文件\n\n\t- a. Concordance® 数据文件。数据文件（.DAT）包含将被加载至 Concordance® 数据库的所有字段化信息。.DAT 文件的第一行必须为标识字段名称的标题行。.DAT 文件必须使用以下 Concordance® 默认分隔符：逗号 ASCII 字符（020） 引号 þ ASCII 字符（254）。日期字段应按以下格式提供：mm/dd/yyyy。日期和时间字段必须为两个独立字段。如文件包括已成像的电子邮件及附件，则必须包括附件字段，以保留电子邮件与其附件之间的父项/子项关系。必须包括 OCRPATH 字段，以提供所提供存储介质上提取文本文件的文件路径和名称。文本文件必须以 FIRSTBATES 命名。不得将文本包含在 .DAT 文件中。对于含有原生文件的文件，必须包括 LINK 字段，以提供原生文件的文件路径和\n\n名称。原生文件必须以 FIRSTBATES 命名。\n\n- b. Concordance Image® 或 Opticon 交叉引用文件。图像交叉引用文件（.LOG 或 .OPT）将图像与数据库记录链接。该文件应为逗号分隔文件，每行由七个字段组成，数据库中每幅图像均应在交叉引用文件中有一行，格式如下：ImageID,VolumeLabel,ImageFilePath,DocumentBreak,FolderBreak,Box Break,PageCoun。\n\n- c. 文件文本。文本必须作为独立文本文件提供，而非作为 .DAT 文件内的字段提供。文本文件的完整路径（OCRPATH）应包含在 .DAT 文件中。建议提供按 FIRSTBATES/Image Key 命名的文件级 ANSI 文本文件。提取的文本文件必须置于单独文件夹内，每个文件夹中的文本文件数量不得超过1,000个。文件夹名称中不得有特殊字符（包括逗号）。文本文件必须按文件级别提供。\n\n- d. 某些文件类型的原生格式提供。为完整理解其内容和含义而合理需要以原生格式查看的文件类型，必须以原生格式提供。这些包括但不限于电子表格、类似电子表格的文件（Microsoft Excel、逗号分隔值、制表符分隔值等）、Microsoft PowerPoint 或其他特殊演示文件、数据库文件及音频/视频文件。应提供一张带有 Bates 编号的分隔页图像，标明原生文件的存在，并在 .dat 文件中将原生文件路径作为字段列入。所提供的原生文件应以与该文件分隔页相对应的 Bates 编号命名。原生文件应归入按递增方式命名的“NATIVE”目录中，并与图像目录分开。\n\n- e. 去重。对于存在完全重复件的每份电子文件，仅提供一份副本。对于电子邮件，应基于由 BCC、Body、CC、From、IntMsgID、To 及 Attach 属性生成的 MD5 哈希值合并重复件。对于电子邮件附件和独立电子文件，应基于整个文件的 MD5 哈希值合并重复件。\n\n- f. 元数据。以符合 Concordance 要求的加载文件（.dat）形式提供每份文件的提取元数据。.DAT 文件的第一行必须为标识字段名称的标题行。.DAT 文件必须使用以下 Concordance 默认分隔符：逗号 , ASCII 字符（020） 引号 þ ASCII 字符（254）\n\n日期字段应按以下格式提供：mm/dd/yyyy。日期和时间字段必须为两个独立字段。下列为必需的元数据：\n\nCase 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 378 of 1063\n\n字段名称　示例数据　说明\n\nFIRSTBATES　EDC0000001　原生文件文件/电子邮件的首个 Bates 编号\n\nLASTBATES　EDC0000001　原生文件文件/电子邮件的最后一个 Bates 编号\nLASTBATES 字段应针对单页予以填写\n\nATTACHRANGE　EDC0000001\n-　父文件首页的 Bates 编号至最后一个附件“子”文件最后一页的 Bates 编号\nEDC0000015\n\nBEGATTACH　EDC0000001　附件范围的首个 Bates 编号\n\nENDATTACH　EDC0000015　附件范围的最后一个 Bates 编号\n\nCUSTODIAN　Smith, John　电子邮件：电子邮件所在的邮箱\n原生文件：该文件源自其文件的个人或部门的名称\n\nFROM　John Smith　电子邮件：发件人\n原生文件：文件作者\n多个条目应以分号分隔\n\nTO　Coffman, Janice; LeeW　收件人\n[mailto:LeeW@MSN.com]　多个条目应以分号分隔\n\nCC　Frank Thompson [mailto:　抄送收件人\nfrank_Thompson@cdt.com]　多个条目应以分号分隔\n\nBCC　John Cain　密送收件人\n多个条目应以分号分隔\n\nSUBJECT　Board Meeting Minutes　电子邮件：电子邮件主题行 原生文件：文件标题（如有）\n\nFILE_NAME　BoardMeetingMinutes.docx　原生文件：原始原生文件的名称，包括扩展名\n\nDATE_SENT　10/12/2010　电子邮件：电子邮件发送日期\n原生文件：（空）\n\nTIME_SENT/\nTIME_ZONE　07:05 PM GMT　电子邮件：电子邮件发送时间/电子邮件被标准化时所采用的时区\n\nTIME_ZONE　GMT　在转换期间电子邮件被标准化时所采用的时区。\n\nLINK　EDC0000001.msg　电子邮件或原生文件文件的超链接\n所链接文件必须按 FIRSTBATES 编号命名\n\nFILE_EXTEN　MSG　代表电子邮件或原生文件的文件类型扩展名\n\nAUTHOR　John Smith　电子邮件：（空）\n原生文件：文件作者\n\nDATE_CREATED　10/10/2010　电子邮件：（空）\n原生文件：文件创建日期\n\nCase 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 379 of 1063\n\nTIME_CREATED　10:25 AM　电子邮件：（空）\n原生文件：文件创建时间\n该数据必须为独立字段，不得与 DATE_CREATED 字段合并\n\nDATE_MOD　10/12/2010　电子邮件：（空）\n原生文件：文件最后修改日期\n\nTIME_MOD　07:00 PM　电子邮件：（空）\n原生文件：文件最后修改时间\n该数据必须为独立字段，不得与 DATE_MOD 字段合并\n\nDATE_ACCESSD　10/12/2010　电子邮件：（空）\n原生文件：文件最后访问日期\n\nTIME_ACCESSD　07:00 PM　电子邮件：（空）\n原生文件：文件最后访问时间\n该数据必须为独立字段，不得与 DATE_ACCESSD 字段合并\n\nFILE_SIZE　5,952　原生文件文件/电子邮件的大小，以 KB 计\n\nPGCOUNT　1　原生文件文件/电子邮件的页数\n\nPATH　电子邮件：（空）\nAgenda.doc　原生文件：原生文件文件的存储路径，包括原始文件名。\n\nINTFILEPATH　Personal Folders\\Deleted　电子邮件：电子邮件的原始位置，包括原始文件名。\nItems\\Board Meeting\nMinutes.msg　原生文件：（空）\n\nINTMSGID　<000805c2c71b\\$75977050\\$　电子邮件：唯一消息 ID 原生文件：（空）\ncb8306d1@MSN>\n\nMD5HASH　d131dd02c5e6eec4693d9a0　文件的 MD5 哈希值。\n698aff95c\n2fcab58712467eab4004583e\nb8fb7f89\n\nOCRPATH　TEXT/001/EDC0000001.txt　原生文件提取文本的路径\n\n3. 每项请求独立适用并应独立解释，除非另有说明，任何一项请求均不限制任何其他请求的范围。\n\n4. 所有文件应按通常业务过程中的保存方式提供，或应组织并标记为与这些请求中的类别相对应。\n\n5. 本文所载每项请求延及所有文件：(a) 由您占有、保管或控制的；或 (b) 由任何代表您行事的人占有、保管或控制的，\n\nCase 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 380 of 1063\n\n包括您的律师或其他代表及顾问。每份文件均应完整提供。\n\n6. 如要求您提交一份已不再由您占有、保管或控制的文件，则您的答复必须：(a) 详细说明该文件的性质及其内容；(b) 确认编制或撰写该文件的人员（以及，如适用，该文件发送给的人员）；(c) 确认该文件编制或创建的日期；(d) 说明该文件是否：(i) 缺失或遗失，(ii) 已被销毁，(iii) 已自愿或非自愿地转交他人，或(iv) 以其他方式处置；(e) 说明该等处置的原因以及与之相关的事实和情况；(f) 确认授权进行该等处置的人员；(g) 确认该等处置的日期或大致日期；(h) 说明该文件最近一次由您占有、保管或控制的时间；以及(i) 确认目前占有、保管或控制该文件的人员（如有）。\n\n7. 如要求您提交一份已被销毁的文件，则除前一项指示所要求的信息外，您的答复还必须说明：(a) 该文件被销毁的原因；(b) 销毁该文件的人员身份；以及(c) 指示销毁该文件的人员身份。\n\n8. 如您主张所要求的文件享有特权或属于律师工作成果，则您的答复必须：(a) 说明：(i) 足以支持您关于该文件享有特权之主张的文件描述，(ii) 文件标题，(iii) 文件日期，(iv) 文件作者，(v) 文件收件人，(vi) 收到或阅览该文件原件或任何草稿、副本或复制件的每一人员身份，(vii) 该文件本身或该文件中包含或提及的任何信息是否由任何其他人员占有、保管或控制，如是，该等人员的身份，以及说明该等信息如何为其所占有的陈述，(viii) 据以拒绝提交该文件的特权主张，以及(ix) 您将据以支持该等特权主张的全部情形；以及(b) 就根据 D. Conn. L. Civ. R. 26(e) 以特权主张为由拒绝提交的每份文件，制作一份特权清单，其中包含本项指示第(a)部分所要求的全部信息。\n\n案件 22-50073 文件 1592 于 03/24/23 提交 于 03/24/23 10:57:37 登记 第 381 页，共 1063 页\n\n该等人员，以及说明该等信息如何为其所占有的陈述，(viii) 据以拒绝提交该文件的特权主张，以及(ix) 您将据以支持该等特权主张的全部情形；以及(b) 就根据 D. Conn. L. Civ. R. 26(e) 以特权主张为由拒绝提交的每份文件，制作一份特权清单，其中包含本项指示第(a)部分所要求的全部信息。\n\n9. 如一份原本应予提交的文件的一部分包含受特权主张约束的信息，则仅应依照上述指示从该文件中删除或遮盖受特权主张约束的该部分，其余部分应予提交。\n\n10. 该等请求具有持续性。现指示您：(a) 在获悉先前答复不完整或不正确后，立即补充或更正任何后来得知不完整或不正确的答复；以及(b) 提交根据下列要求所要求的任何其他文件\n\n11. 如文件使用英语以外的语言，您应提供该文件。如文件使用英语以外的语言，且存在英文译本，您应同时提供两份文件。\n\n12. 对实体的所有提及均包括其全部关联方。\n\n13. 对个人姓名的所有提及均包括所有别名、化名或昵称。\n\n14. 除非另有明确说明，文件请求所涵盖的期间为自 February 5, 2012 起至提交文件请求答复到期之日止。\n\n案件 22-50073 文件 1592 于 03/24/23 提交 于 03/24/23 10:57:37 登记 第 382 页，共 1063 页\n\nII. 解释规则\n\n15. (a) 任何单数名词的使用应解释为包括复数，反之亦然；以及(b) 任何时态动词的使用应解释为该动词在所有其他时态中的使用。\n\n16. (a) “和”及“或”应视需要解释为连词或选择词，以使原本可能被解释为超出任何请求范围的所有答复均纳入该请求范围；以及(b) “每一”及“任何”应视为包括并涵盖“每一个”及“所有”二词。\n\nIII. 定义\n\n经 D. Conn. Bankr. L.R. 2004-1(a) 纳入的 D. Conn. L. Civ. R. 26(c) 所规定的定义以及 D. Conn. L. Civ. R. 26(d) 所规定的解释规则，适用于该等文件请求。此外，本文件请求中使用的下列术语具有下列含义：\n\n1. “您”或“您的”或“您本人”是指 Hamilton M&A Fund SP（汉密尔顿并购基金特别合伙），连同其全部关联方、部门、机构、法定机构、处室、办事处、合伙人、高级职员、董事、代理人、律师、代表、雇员及/或代表其行事的任何人。\n\n2. “债务人”是指 Ho Wan Kwok（郭文贵，亦称 Miles Kwok、Miles Guo、Guo Wengui、Guo Haoyun、郭文贵或任何其他别名），连同其雇员、代理人、律师、顾问或代表其行事的任何人。\n\n3. “债务人之子”是指 Qiang Guo（郭强，亦称 Mileson Kwok、郭强或任何其他别名），连同其雇员、代理人、律师、顾问或代表其行事的任何人。\n\n案件 22-50073 文件 1592 于 03/24/23 提交 于 03/24/23 10:57:37 登记 第 383 页，共 1063 页\n\n4. “债务人之女”是指 Mei Guo（郭美，亦称 Mei Gui、郭美或任何其他别名），连同其雇员、代理人、律师、顾问或代表其行事的任何人。\n\n5. “债务人所谓妻子”是指 Hing Chi Ngok（岳庆芝，亦称 Hing Chi Ng、Yue Qingzhi、岳庆芝或任何其他别名），连同其雇员、代理人、律师、顾问或代表其行事的任何人。\n\n6. “债务人家属”统称债务人、债务人之子、债务人之女及债务人所谓妻子，以及与债务人具有任何其他亲属关系的人。\n\n7. “关联个人”单独及共同地指下列所有个人：(1) 持有、控制、保管或对债务人或债务人家属拥有、控制或享有的资产具有处置权；或(2) 曾为一个或多个关联实体的雇员、董事，或以其他方式与一个或多个关联实体有关联，连同前述各方各自的雇员、代理人、律师、顾问或代表前述任何一方行事的任何人。该等关联个人包括但不限于：Daniel Podhaskie（丹尼尔·波达斯基）、Jason Miller（杰森·米勒）、Steve Bannon（史蒂夫·班农）、Karin Maistrello（卡琳·迈斯特雷洛）、Melissa Francis（梅丽莎·弗朗西斯）、Anthony DiBattista（安东尼·迪巴蒂斯塔）、William Gertz（威廉·格茨）、Arethusa Forsyth（阿瑞苏莎·福赛斯）、Glenn Mellor（格伦·梅勒）、Jennifer Mercurio（珍妮弗·梅库里奥）、Eduardo Eurnekian（爱德华多·厄内基安）、Wencong Wang（王文聪）、Han Chunguang（韩春光，亦称 韩春光）、Qu Guojiao（屈国姣，亦称 Qu Guo Jiao、屈国姣）、Guo Lijie（郭丽杰，亦称 郭丽杰）、Zhang Wei（张伟，亦称 张伟*）、Lihong Wei Lafrenz（魏丽红，亦称 Sara Wei、魏丽红）、Hao Haidong（郝海东，亦称 郝海东）、Ross Heinemeyer（罗斯·海内迈耶）、Max Krasner（马克斯·克拉斯纳）、Kyle Bass（凯尔·巴斯）、Melissa Mendez（梅丽莎·门德斯）、Ya Li（李娅，亦称 李娅）、Dinggang Wang（王定刚，亦称 王定刚）、An Hong（安红，亦称 安红）、Yvette Wang（王雁平，亦称 Yanping Wang、Yan Ping Wang、王雁平）、Fiona Yu（菲奥娜·余）、Je Kin Ming（余建明，亦称 William Je、Yu Jianming、余建明）、Yaz Qingua（亚兹·钦瓜）及 Lao Jiang（姜云浮，亦称 Jiang Yunfu、Jiang Yunfu Be、姜云浮）。\n\n案件 22-50073 文件 1592 于 03/24/23 提交 于 03/24/23 10:57:37 登记 第 384 页，共 1063 页\n\n8. “关联实体”单独及共同地指下列任何类型的所有组织或实体：(1) 曾由债务人或债务人家属拥有、控制或投资；或(2) 直接或间接对债务人或债务人家属拥有、控制或享有的任何资产具有权益，连同前述各方各自的雇员、代理人、律师、顾问或代表前述任何一方行事的任何人。该等关联实体包括但不限于：7 Nod Hill LLC（七节点山有限责任公司）、AAGV Limited（AAGV有限公司）、ACA Investment Management Limited（ACA投资管理有限公司）、ACA Capital Group Limited（ACA资本集团有限公司）、Ace Decade Holdings Limited（王牌十年控股有限公司）、AI Group Holdings Inc.（AI集团控股公司）、Alfa Global Ventures Limited（阿尔法全球创投有限公司）、Alfonso Global Limited（阿方索全球有限公司）、Allied Capital Global Limited（联合资本全球有限公司）、Alpine Fiduciaries SA（阿尔卑斯信托股份公司）、Anton Development Limited（安东开发有限公司）、Assets Sino Limited（中资资产有限公司）、Auspicious Coast Limited（吉祥海岸有限公司）、Beijing Pangu Investment Co.（北京盘古投资公司）、Beijing Pangu Investment Co. Ltd.（北京盘古投资有限公司）、Beijing Pangu Investment Inc.（北京盘古投资股份公司）、Beijing Zenith Holdings Company Limited（北京鼎峰控股有限公司）、Booming Sail New York LLC（纽约兴帆有限责任公司）、Bravo Luck Limited（鸿运有限公司）、BSA Strategic Fund I（BSA战略基金I）、China Golden Spring (Hong Kong) Limited（中国金泉〈香港〉有限公司）、Chuang Xin Limited（创新有限公司）、Crane Advisory Group LLC（鹤咨询集团有限责任公司）、Creative Apex Investments Limited（创意巅峰投资有限公司）、Crystal Breeze Investments Limited（水晶清风投资有限公司）、Dawn State Limited（黎明州有限公司）、Eastern Profit Corporation Limited（东方利润有限公司）、Elite Well Global Limited（精英环球有限公司）、Empire Growth Holdings（帝国增长控股）、Freedom Media Ventures Ltd.（自由媒体创投有限公司）、G Club Operations LLC（G俱乐部运营有限责任公司）、G Fashion LLC（G时尚有限责任公司）、G News LLC（G新闻有限责任公司）、GETTR USA（GETTR美国）、Genever Holdings Corporation（Genever控股公司）、Genever Holdings LLC（Genever控股有限责任公司）、Gfashion Media Group Inc.（G时尚媒体集团公司）、GFNY, Inc.（GFNY公司）、Globalist International Limited（全球主义者国际有限公司）、GNews Media Group Inc.（G新闻媒体集团公司）、Golden Spring (New York) Ltd.（金泉〈纽约〉有限公司）、Greenwich Land LLC（格林尼治地产有限责任公司）、Guo Media（郭媒体）、GTV Media Group, Inc.（GTV媒体集团公司）、Hamilton Capital Holdings Inc.（汉密尔顿资本控股公司）、HCHK Property Management, Inc.（HCHK物业管理公司）、HCHK Technologies, Inc.（HCHK科技公司）、Head Win Group Limited（领胜集团有限公司）、Henan Yuda（河南裕达）、Himalaya Embassy（喜马拉雅大使馆）、Himalaya Exchange（喜马拉雅交易所）、Himalaya Federal Reserve（喜马拉雅联邦储备）、Himalaya Investment LLC（喜马拉雅投资有限责任公司）、Himalaya International（喜马拉雅国际）、Himalaya New World Inc.（喜马拉雅新世界公司）、Himalaya Supervisory Organization（喜马拉雅监督组织）、Himalaya Ventures LLC（喜马拉雅创投有限责任公司）、HK International Funds Investments (USA) Limited LLC（香港国际基金投资〈美国〉有限责任公司）、Hong Kong International Funds\n\n案件 22-50073 文件 1592 于 03/24/23 提交 于 03/24/23 10:57:37 登记 第 385 页，共 1063 页\n\nInvestments Limited（香港国际基金投资有限公司）、Hudson Diamond Holding（哈德逊钻石控股）、Infinite Increase Limited（无限增长有限公司）、Infinitum Developments Limited（无限发展有限公司）、Infinity Treasury Management Inc.（无限财资管理公司）、Insight Phoenix Fund（洞察凤凰基金）、Lamp Capital LLC（灯塔资本有限责任公司）、Leading Shine Limited（领先光辉有限公司）、Leading Shine NY Limited（领先光辉纽约有限公司）、Lexington Property and Staffing（莱辛顿房地产及人力服务）、Long Gate Limited（长龙门有限公司）、Maywind Trading LLC（五月风贸易有限责任公司）、MOS Himalaya LLC（MOS喜马拉雅有限责任公司）、Next Tycoon Investments Limited（下一个大亨投资有限公司）、New Federal State of China（中国新联邦国，亦称 NFSC）、Noble Fame Global Limited（显赫名誉环球有限公司）、Rosy Acme Ventures Limited（玫瑰巅峰创投有限公司）、Rule of Law Foundation III, Inc.（法治基金会III公司）、Rule of Law Foundation IV, Inc.（法治基金会IV公司）、Rule of Law Fund（法治基金）、Rule of Law Society（法治协会）、Rule of Law Society IV, Inc.（法治协会IV公司）、G-Translators PTY LTD（G翻译员私人有限公司）、Saraca Media Group, Inc.（娑罗树媒体集团公司）、Shiny Ace Ltd.（闪耀王牌有限公司）、Shiny Times Holdings Ltd.（闪耀时代控股有限公司）、Spirit Charter Investment Limited（精神宪章投资有限公司）、Stevenson, Wong & Co.（史蒂文森、黄及公司）、Voice of Guo Media, Inc.（郭媒体之声公司）、Well Origin Ltd.（良好起源有限公司）、World Century Limited（世界世纪有限公司）、Worldwide Opportunity Holdings Limited（全球机会控股有限公司）、Whitecroft Shore Limited（怀特克罗夫特海岸有限公司）及 ZIBA Limited（ZIBA有限公司）。\n\n9. “包括”或其任何变体，意为“包括但不限于”。\n\n10. “和”及“或”意为“和/或”，并应同时解释为连词及选择词，以最大限度扩大其范围。\n\n11. “任何”、“所有”及“每一”意为“每一个及所有”。\n\n12. “每一”及“每个”意为“每一个及所有”。\n\n13. “第三方”是指您本人以外的人员或实体。\n\n14. “转让”具有《破产法》第 101(54) 条赋予该词的含义。\n\n15. “文件”是指属于 Fed. R. Civ. P. 34 范围内的任何信息或物品，包括但不限于目前或曾由您占有、保管或控制的任何种类、类型、性质或描述的每一项书面、记录或图形材料，包括所有电子邮件的印刷及电子副本、保存在计算机文件中的全部电子副本。\n\n案件 22-50073 文件 1592 于 03/24/23 提交 于 03/24/23 10:57:37 登记 第 386 页，共 1063 页\n\n电子形式、电子通信、短信、社交媒体帖子、推文、元数据、通信函件、备忘录、磁带、速记或手写笔记、任何种类的书面表格、图表、蓝图、绘图、草图、图形、计划、文章、规格说明、日记、信件、电报、照片、会议记录、合同、协议、调查报告、计算机打印件、任何种类的数据汇编、电传、传真、语音留言、发票、订购单、支票、汇票、对账单、贷项通知单、报告、立场报告、摘要、索引、书籍、账簿、笔记本、附表、透明胶片、录音录像、目录、广告、宣传材料、电影、录像带、录音带、CD、计算机磁盘、小册子、宣传册、穿孔卡、工时单、推文、社交媒体帖子，或任何其他种类的书面或录制材料，以及其全部元数据，无论以何种方式储存（无论为有形或电子形式）、记录、制作或复制，亦包括但不限于前述任何文件的草稿或副本，如其中包含原始文件中不存在的任何种类的笔记、评论或标记，或在其他方面与原始文件不相同。\n\n16. “人员”系指个人、公司、独资企业、合伙企业、协会或任何其他实体。“人员”亦包括任何代理人、代表或专家，包括但不限于律师或财务顾问。\n\n17. “实体”系指任何自然人、公司、合伙企业、子公司、独资企业、商号、董事会、合资企业、协会、机构、主管机关、委员会或其他商业实体或法人，以及任何关联方、代理人、母公司，包括但不限于法律顾问、财务顾问或任何其他代表。\n\n18. “关于”系指涉及、描述、构成、提及、与之相关、支持、赞成、反对、加强、削弱、载于、结合考虑、影响、证明、表明、报告、记录、暗指、回应、\n\n案件 22-50073 文件 1592 提交于 03/24/23 登记于 03/24/23 10:57:37 第387页，共1063页\n\n与之有关、评论、就其而言、关于、与之有关、讨论、显示、描述、反映、分析、构成及属于。\n\n19. 在提及任何特定事项时，“涉及”、“涉及到”或“相关”系指，包括但不限于，构成、包含、涉及、含有、体现、反映、识别、陈述、直接或间接提及，或以任何方式与所识别的特定事项相关的任何文件。\n\n20. “通信”系指以最广泛可能的含义且不限于任何形式，对信息或知识（以事实、观点、询问或其他形式）的任何传递。“通信”还指所有谈话、协议、询问或答复，无论是当面、通过电话、书面方式，或通过电子传输设备进行，并包括但不限于所有通信函件、电子邮件、录音录像、传送单、备忘录、电话通信、语音留言、电报、传真、电传、即时消息、聊天信息、短信、电话笔记，或在内部或与第三方传送的笔记。\n\n21. “资产”系指可用于产生正面经济价值的任何项目，包括但不限于由某一实体拥有、控制或为其利益而持有的、预期将提供未来利益的任何具有经济价值的资源，包括但不限于所有不动产和动产、无形财产、投资、投资权或未来收益权、现金、银行账户、商品、证券、请求权、对实体的全部或部分控制权，以及预期经济机会。\n\n22. “转让”应具有《破产法》第101(54)条赋予该词的含义。\n\nIV. 应提交的文件\n\n1. 关于债务人、债务人财产或关联实体任何收入或资产的所有文件。\n\n2. 与债务人的财务状况及其对债权人承担的义务有关的所有文件，包括但不限于与任何试图避免支付该等义务的行为有关的所有文件，以及与本次或任何其他实际或潜在破产或类似资不抵债程序有关的所有文件。\n\n3. 关于与债务人、债务人财产、债务人家庭成员、关联实体或关联个人有关的任何资产负债表、银行对账单、账户对账单、财务报表、账目报表、电汇指示及／或确认、资金证明、存款证明、持仓证明、投资组合摘要或类似文件的所有文件，包括但不限于足以显示向上述任何主体进行的所有转让的所有文件。\n\n4. 关于债务人作出、与债务人进行或代表债务人作出的任何投资、商业交易或交易行为的所有文件。\n\n5. 与债务人的所有通信，以及与债务人的通信有关、涉及任何实体（包括但不限于关联实体）的运营、管理或决策的文件。\n\n6. 关于向债务人、由债务人或与债务人、债务人家庭成员或关联实体进行的任何转让、投资或其他交易或商业往来的所有文件。\n\n7. 关于债务人曾占用或使用的任何财产的所有文件，包括但不限于 Lady May；Sherry Netherland Hotel / Condominium；位于 Connecticut（康涅狄格州）Greenwich（格林尼治）373 Taconic Rd. 的住宅物业；位于康涅狄格州格林尼治 33 Ferncliff Rd. 的住宅物业；以及位于康涅狄格州 Wilton（威尔顿）354 Nod Hill Rd. 的住宅物业。\n\n案件 22-50073 文件 1592 提交于 03/24/23 登记于 03/24/23 10:57:37 第389页，共1063页\n\n8. 与债务人拥有、控制或使用的任何飞机有关的所有文件，包括但不限于机尾编号为 T7-GQM 的飞机及在 San Marino（圣马力诺）登记的任何其他飞机，包括但不限于所有登记文件副本及显示该等飞机所执行航班和该等航班机上人员的飞行清单。\n\n9. 关于向债务人、债务人财产、债务人家庭成员或关联实体提供、从其取得或代表其取得的任何赠与、利益或贷款的所有文件，包括但不限于足以显示该等赠与、利益或贷款金额；该等赠与、利益或贷款所使用的目的；提供该等赠与、利益或贷款的时间；以及任何贷款的条款、就任何贷款作出的所有陈述和保证、任何贷款的利率，以及任何贷款付款的所有证据的文件。\n\n10. 关于由债务人、代表债务人或为债务人、债务人财产、债务人家庭成员或关联实体利益而设立的任何信托或类似文书的所有文件，包括但不限于足以显示该等信托设立时间、设立人、为谁的利益而设立及信托本金的文件。\n\n11. 与涉及债务人的任何法律争议相关的任何义务、请求权、责任或债务有关的所有文件，包括但不限于与在任何地方、州、联邦或国际机构前进行的任何诉讼有关的文件，无论该机构为行政机关、法院、合议庭或替代性争议解决实体。\n\n案件 22-50073 文件 1592 提交于 03/24/23 登记于 03/24/23 10:57:37 第390页，共1063页\n\n12. 您的任何外部法律顾问或其他顾问与债务人之间的所有文件和通信。\n\n13. 足以显示您的全部资产及收入或资金来源的文件。\n\n14. 对于就请求第14项所识别的、价值超过 \\$50,000 的所有资产，所有与以下事项有关的文件：(i) 您取得该等资产；以及 (ii) 与债务人或债务人家庭成员就该等资产进行的通信。\n\n15. 您的纳税申报表副本。\n\n16. 足以显示处于您占有或控制之下的所有银行账户和投资账户的文件，包括每一该等账户的余额以及向该等账户进行和从该等账户作出的转让。\n\n17. 关于您使用的任何信用卡的所有文件，包括但不限于月度对账单或足以显示为债务人或关联实体利益而进行的与此相关的所有购买的其他文件。\n\n18. 所有公司治理和组织文件，包括但不限于章程细则和公司注册证书，以及足以显示您的公司结构、高级管理人员和董事姓名、经营目的，以及与债务人或债务人任何家庭成员关系的其他文件。\n\n19. 与将您的任何资产质押给任何其他实体有关的所有文件。\n\n案件 22-50073 文件 1592 提交于 03/24/23 登记于 03/24/23 10:57:37 第391页，共1063页\n\n附件 C-21\n\nB2540（表格 2540——Rule 2004 审查传票）（12/15）案件 22-50073 文件 1592 提交于 03/24/23 登记于 03/24/23 10:57:37 第392页，共\n\n美国破产法院 1063\n\n康涅狄格州地区\n\n关于 HO WAN KWOK（郭文贵）等人，\n\n1 案件编号 22-50073 (JAM)\n\n债务人 第11章\n\n（合并管理）\nRule 2004 审查传票\n\n致：Hamilton M&A Fund SP（汉密尔顿并购基金 SP）\n\n（传票所指向人员的姓名）\n\n作证：兹命令您于下列规定的时间、日期和地点出席，根据《联邦破产程序规则》Rule 2004 进行的审查并作证。随附准许该审查的法院命令副本。\n\n地点　日期和时间\n\nPaul Hastings LLP（保尔·黑斯廷斯律师事务所）\n200 Park Avenue　[TBD]\nNew York, New York 10166\n\n审查将通过以下方式记录：法庭记录员／速记员\n\n提交：您或您的代表还必须在审查时携带下列文件、电子储存信息或物品，并必须允许对该材料进行查验、复制、测试或取样：\n见随附的文件提交请求。\n\n根据《联邦破产程序规则》Fed. R. Bankr. P. 9016 适用于破产案件的《联邦民事诉讼规则》Fed. R. Civ. P. 45 的下列规定随附于后——关于履行地点的 Rule 45(c)；关于您作为受传票约束人员的保护的 Rule 45(d)；以及关于您回应本传票的义务和不履行该义务的潜在后果的 Rule 45(e) 和 45(g)。\n\n日期：March , 2023\n\n法院书记员\n\n或\n\n书记员或副书记员签名　律师签名\n\n签发或请求本传票的 Luc A. Despins（卢克·A·德斯平斯）第11章受托人的代理律师姓名、地址、电子邮件地址和电话号码如下：\n\nDouglas S. Skalka, Esq.（道格拉斯·S·斯卡尔卡律师）；Neubert, Pepe & Monteith, P.C.（诺伊伯特、佩佩及蒙泰思律师事务所）；195 Church Street, New Haven, Connecticut 06510 dskalka@npmlaw.com；(203) 821-2000\n\n向签发或请求本传票者的通知\n\n如本传票命令在审判前提交文件、电子储存信息或有形物品，或查验场所，则必须在向传票所指向人员送达之前，向每一当事人送达通知及本传票副本。Fed. R. Civ. P. 45(a)(4)。\n\n软件版权 (c) 1996-2022 Best Case, LLC（最佳案件有限责任公司）- www.bestcase.com Best Case Bankruptcy 1 本第11章案件中的债务人为 Ho Wan Kwok（亦称 Guo Wengui、Miles Guo 和 Miles Kwok，以及众多其他别名）（税务识别号码后四位：9595）、Genever Holdings LLC（税务识别号码后四位：8202）以及 Genever Holdings Corporation。受托人、Genever Holdings LLC 和 Genever Holdings Corporation 的邮寄地址为 Paul Hastings LLP，200 Park Avenue, New York, NY 10166，转交 Luc A. Despins，作为 Ho Wan Kwok 财产的受托人（仅为通知和通信之目的）。\n\n送达证明\n\n（除非 Fed. R. Civ. P. 45 要求，否则本节不应向法院提交。）\n\n本人于（日期）收到针对（个人姓名及职务，如有）的本传票：\n\n本人已通过如下方式向被点名人士交付一份副本，以送达本传票：\n\n于（日期）；或\n\n本人退回未执行的传票，理由如下：\n\n除非本传票系代表 United States（美国）或其官员或代理人签发，本人亦已向证人支付一天出庭费用及法律允许的里程费，金额为 \\$ 。\n\n本人旅费为 \\$ ，服务费为 \\$ ，合计为 \\$ 。\n\n本人在伪证罪处罚的约束下声明，此信息真实且正确。\n\n日期：\n\n送达人签名\n\n正楷姓名及职务\n\n送达人地址\n\n关于尝试送达等的补充信息：\n《联邦民事诉讼规则》第45(c)、(d)、(e)和(g)条（2013年12月1日生效）（根据《联邦破产程序规则》第9016条适用于破产案件）\n(c) 履行地点。\n\n(1) 审判、听证或证言录取。传票仅可按如下方式命令某人出席审判、听证或证言录取：\n\n(A) 在该人居住、受雇或经常亲自开展业务地点100英里以内；或\n\n(B) 在该人居住、受雇或经常亲自开展业务所在州内，如果该人\n\n(i) 是一方当事人或当事人的高级职员；或\n\n(ii) 被命令出席审判且不会产生重大费用。\n\n(2) 其他证据开示。传票可以命令：\n\n(A) 在该人居住、受雇或经常亲自开展业务地点100英里以内的地点提交文件、电子存储信息或物品；以及\n\n(B) 在待检查场所进行场所检查。\n(d) 保护受传票约束之人；执行。\n\n(1) 避免不当负担或费用；制裁。负责签发和送达传票的当事人或律师必须采取合理措施，避免对受传票约束之人施加不当负担或费用。要求履行的地区法院必须执行该义务，并对未遵守者的当事人或律师施加适当制裁，其中可包括损失的收入和合理的律师费。\n\n(2) 命令提交材料或允许检查。\n\n(A) 无需出席。被命令提交文件、电子存储信息或有形物品，或允许检查场所之人，无需亲自到提交或检查地点出席，除非其同时被命令出席证言录取、听证或审判。\n\n(B) 异议。被命令提交文件或有形物品，或允许检查之人，可以向传票中指定的当事人或律师送达书面异议，反对检查、复制、测试或抽样任何或全部材料，或反对检查场所，或反对以所要求的一种或多种形式提交电子存储信息。异议必须在指定履行时间或传票送达后14日中较早者之前送达。如提出异议，适用下列规则：\n\n(i) 送达方可随时在通知被命令人后，向要求履行的地区法院提出动议，请求作出强制提交或检查的命令。\n\n(ii) 仅可依命令指示要求实施这些行为，且该命令必须保护并非当事人或当事人高级职员之人免于因履行而产生的重大费用。\n(3) 撤销或修改传票。\n\n(A) 必须撤销或修改的情形。经及时动议，要求履行的地区法院必须撤销或修改具有下列情形的传票：\n\n(i) 未留出合理履行时间；\n\n(ii) 要求某人在第45(c)条规定的地域限制之外履行；\n\n(iii) 要求披露享有特权或受其他保护的事项，且不存在适用的例外或豁免；或\n\n(iv) 使某人承受不当负担。\n\n(B) 可以撤销或修改的情形。为保护受传票约束或受其影响之人，要求履行的地区法院可以依动议撤销或修改要求下列事项的传票：\n\n(i) 披露商业秘密或其他保密研究、开发或商业信息；或\n\n(ii) 披露未受聘专家的意见或信息，该等意见或信息不描述争议中的具体事件，且源于并非由一方当事人请求的该专家研究。\n\n(C) 以规定条件作为替代。在第45(d)(3)(B)条所述情形下，如送达方：\n\n(i) 证明其对证言或材料有重大需要，且不造成不当困难即无法以其他方式满足该需要；并且\n\n(ii) 确保受传票人将获得合理补偿，\n\n法院可不撤销或修改传票，而命令在规定条件下出席或提交材料。\n(e) 答复传票的义务。\n\n(1) 提交文件或电子存储信息。下列程序适用于提交文件或电子存储信息：\n\n(A) 文件。答复提交文件传票之人必须按该等文件在正常业务过程中保存的方式提交，或者必须将其整理并标记为与请求中的类别相对应。\n\n(B) 未指定电子存储信息的提交形式。如传票未指定电子存储信息的提交形式，答复人必须以其通常保存的一种或多种形式，或以一种或多种合理可用的形式提交。\n\n(C) 电子存储信息仅以一种形式提交。答复人无需以一种以上形式提交相同的电子存储信息。\n\n(D) 无法获取的电子存储信息。答复人无需就其认定因不当负担或费用而无法合理获取的来源中的电子存储信息提供证据开示。在强制证据开示或保护令动议中，答复人必须证明该信息因不当负担或费用而无法合理获取。如作出该证明，法院仍可在请求方考虑第26(b)(2)(C)条限制后证明有正当理由时，命令从该等来源进行证据开示。法院可为该证据开示规定条件。\n(2) 主张特权或保护。\n\n(A) 扣留的信息。以该信息享有特权或作为审判准备材料受到保护为由扣留被传票要求提供的信息之人必须：(i) 明确提出该主张；并且\n\n(ii) 以一种在不披露本身享有特权或受保护信息的情况下，使各方能够评估该主张的方式，说明被扣留文件、通信或有形物品的性质。\n\n(B) 已提交的信息。如为答复传票而提交的信息受到特权主张或作为审判准备材料受保护的主张约束，提出该主张之人可将该主张及其依据通知收到该信息的任何一方。收到通知后，当事人必须立即返还、隔离或销毁所指定的信息及其持有的任何副本；在该主张得到解决前不得使用或披露该信息；如该当事人在收到通知前已披露该信息，必须采取合理措施予以取回；并可立即将该信息密封提交给要求履行的地区法院，以裁定该主张。提交该信息之人必须保存该信息，直至该主张得到解决。\n\n(g) 藐视法庭。要求履行的地区法院，以及在动议移送后签发传票的法院，可以认定已被送达却无充分理由不遵守传票或相关命令之人构成藐视法庭。\n\n关于获取传票材料，参见 Fed.R.Civ.P.45(a) Committee Note (2013)\n\n……\n\n文件提交请求\nI. 指示\n\n1. 除非另有说明，下列文件请求（以下简称“请求”，每一项以下简称“一项请求”）必须分别且具体地予以答复。每项请求均应得到完整答复，除非基于善意提出异议；如提出异议，贵方异议的理由应按下文规定详细说明。如异议仅涉及一项请求的一部分，或其中包含的一个词、短语或条款，贵方仅须说明对该部分的异议，并答复其余请求。\n\n2. 电子存储信息必须按照下列指示提交：\n\na. 图像。黑白图像必须为300 DPI Group IV 单页 TIFF 文件。彩色图像必须以 JPEG 格式提交。文件名不得包含嵌入空格或特殊字符（包括逗号）。文件夹名称不得包含嵌入空格或特殊字符（包括逗号）。所有 TIFF 图像文件必须具有唯一文件名，即 Bates 编号。每幅图像的右下角必须加盖连续的 Bates 编号。每个文件夹中的 TIFF 文件数量不得超过1000个文件。Excel 电子表格应具有以该文件 Bates 编号命名的占位图像。\n\nb. 图像加载文件\n\na. Concordance® 数据文件。数据文件（.DAT）包含将加载至 Concordance® 数据库的所有字段信息。.DAT 文件的第一行必须是标明字段名称的标题行。.DAT 文件必须使用下列 Concordance® 默认分隔符：逗号 ASCII 字符（020）引号 þ ASCII 字符（254）。日期字段应以如下格式提供：mm/dd/yyyy。日期字段和时间字段必须为两个单独字段。如文件包括已成像的电子邮件及附件，必须包括附件字段，以保留电子邮件及其附件之间的父/子关系。必须包括 OCRPATH 字段，以提供已提交存储介质上提取文本文件的文件路径和名称。文本文件必须以 FIRSTBATES 命名。不得在 .DAT 文件中包括文本。对于含有原生文件的文件，必须包括 LINK 字段，以提供原生文件的文件路径和\n\n名称。原生文件必须以 FIRSTBATES 命名。\n\n- b. Concordance Image® 或 Opticon 交叉引用文件。图像交叉引用文件（.LOG 或 .OPT）将图像链接至数据库记录。该文件应为逗号分隔文件，每行包含七个字段，并且数据库中的每个图像均应在交叉引用文件中有一行，格式如下：ImageID,VolumeLabel,ImageFilePath,DocumentBreak,FolderBreak,BoxBreak,PageCount。\n\n- c. 文档文本。文本必须作为单独的文本文件提供，而非作为 .DAT 文件中的字段提供。文本文件的完整路径（OCRPATH）应包含在 .DAT 文件中。建议按 FIRSTBATES/Image Key 命名的文档级 ANSI 文本文件。提取的文本文件必须置于单独文件夹中，每个文件夹中的文本文件数量不得超过 1,000 个。文件夹名称中不得含有特殊字符（包括逗号）。文本文件必须按文档级别提供。\n\n- d. 特定文件类型的原生格式提供。为充分理解其内容和含义而合理需要以原生格式查看的文件类型，必须以原生格式提供。此类文件包括但不限于电子表格、类似电子表格的文件（Microsoft Excel、逗号分隔值、制表符分隔值等）、Microsoft PowerPoint 或其他特殊演示文件、数据库文件以及音频/视频文件。应提供一张带有 Bates 编号的分隔页图像，以表明存在原生文件，并在 .dat 文件中以字段形式列入该原生文件的路径。所提供的原生文件应以与该文件分隔页相对应的 Bates 编号命名。原生文件应归入按递增方式命名的“NATIVE”目录中，并与图像目录分开。\n\n- e. 去重。对于存在完全重复件的每份电子文档，仅提供一份副本。对于电子邮件，根据由 BCC、Body、CC、From、IntMsgID、To 和 Attach 属性生成的 MD5 哈希值合并重复件。对于电子邮件附件及独立电子文件，根据整个文件的 MD5 哈希值合并重复件。\n\n- f. 元数据。以符合 Concordance 规范的加载文件（.dat）形式提供每份文档的提取元数据。.DAT 文件的第一行必须为标识字段名称的标题行。.DAT 文件必须使用以下 Concordance 默认分隔符：逗号 , ASCII 字符（020）引号 þ ASCII 字符（254）\n\n日期字段应按以下格式提供：mm/dd/yyyy。日期和时间字段必须为两个单独字段。以下列示所需元数据：\nCase 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 397 of 1063\n\n字段名称　示例数据　说明\n\nFIRSTBATES　EDC0000001　原生文件文档/电子邮件的第一个 Bates 编号\nLASTBATES　EDC0000001　原生文件文档/电子邮件的最后一个 Bates 编号\nLASTBATES 字段应针对单页予以填写\nATTACHRANGE　EDC0000001\n-　父文档第一页的 Bates 编号至最后一个附件“子”文档最后一页的 Bates 编号\nEDC0000015\nBEGATTACH　EDC0000001　附件范围的第一个 Bates 编号\nENDATTACH　EDC0000015　附件范围的最后一个 Bates 编号\nCUSTODIAN　Smith, John　电子邮件：电子邮件所在的邮箱\n原生文件：文档来源个人或部门的名称\nFROM　John Smith　电子邮件：发件人\n原生文件：文档作者\n多个条目应以分号分隔\nTO　Coffman, Janice; LeeW　收件人\n[mailto:LeeW@MSN.com]　多个条目应以分号分隔\nCC　Frank Thompson [mailto:　抄送收件人\nfrank_Thompson@cdt.com]　多个条目应以分号分隔\nBCC　John Cain　密送收件人\n多个条目应以分号分隔\nSUBJECT　Board Meeting Minutes　电子邮件：电子邮件主题行 原生文件：文档标题（如有）\nFILE_NAME　BoardMeetingMinutes.docx　原生文件：原始原生文件名称，包括扩展名\nDATE_SENT　10/12/2010　电子邮件：电子邮件发送日期\n原生文件：（空）\nTIME_SENT/　07:05 PM GMT　电子邮件：电子邮件发送时间/电子邮件标准化所采用时区内的时间\nTIME_ZONE\nTIME_ZONE　GMT　在转换过程中电子邮件被标准化所采用的时区。\nLINK　EDC0000001.msg　指向电子邮件或原生文件文档的超链接\n所链接文件必须按 FIRSTBATES 编号命名\nFILE_EXTEN　MSG　代表电子邮件或原生文件的文件类型扩展名\nAUTHOR　John Smith　电子邮件：（空）\n原生文件：文档作者\nDATE_CREATED　10/10/2010　电子邮件：（空）\n原生文件：文档创建日期\nCase 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 398 of 1063\n\nTIME_CREATED　10:25 AM　电子邮件：（空）\n原生文件：文档创建时间\n该数据必须为单独字段，不得与 DATE_CREATED 字段合并\nDATE_MOD　10/12/2010　电子邮件：（空）\n原生文件：文档最后修改日期\nTIME_MOD　07:00 PM　电子邮件：（空）\n原生文件：文档最后修改时间\n该数据必须为单独字段，不得与 DATE_MOD 字段合并\nDATE_ACCESSD　10/12/2010　电子邮件：（空）\n原生文件：文档最后访问日期\nTIME_ACCESSD　07:00 PM　电子邮件：（空）\n原生文件：文档最后访问时间\n该数据必须为单独字段，不得与 DATE_ACCESSD 字段合并\nFILE_SIZE　5,952　原生文件文档/电子邮件的大小，单位为 KB\nPGCOUNT　1　原生文件文档/电子邮件的页数\nPATH　电子邮件：（空）\nAgenda.doc　原生文件：存储原生文件文档的路径，包括原始文件名称。\nINTFILEPATH　Personal Folders\\Deleted　电子邮件：电子邮件的原始位置，包括原始文件名称。\nItems\\Board Meeting\nMinutes.msg　原生文件：（空）\nINTMSGID　<000805c2c71b\\$75977050\\$　电子邮件：唯一邮件 ID 原生文件：（空）\ncb8306d1@MSN>\nMD5HASH　d131dd02c5e6eec4693d9a0　文档的 MD5 哈希值。\n698aff95c\n2fcab58712467eab4004583e\nb8fb7f89\nOCRPATH　TEXT/001/EDC0000001.txt　原生文件提取文本的路径\n\n3. 每项请求均独立适用并应独立解释，除非另有说明，任何请求均不限制任何其他请求的范围。\n\n4. 所有文档均应按其在通常业务过程中保存的方式提供，或者应加以组织和标记以对应于这些请求中的类别。\n\n5. 每项载于本文件中的请求均延及以下所有文档：(a) 由您占有、保管或控制的文档；或 (b) 由代表您行事的任何人占有、保管或控制的文档，\nCase 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 399 of 1063\n\n包括您的律师或其他代表及顾问。每份文档均应完整提供。\n\n6. 如要求您提供一份已不再由您占有、保管或控制的文档，则您的答复必须：(a) 详细说明该文档的性质及其内容；(b) 确认编制或撰写该文档的人员（以及，如适用，文档被发送至的人员）；(c) 确认该文档编制或创建的日期；(d) 说明该文档是否：(i) 遗失或丢失，(ii) 已被销毁，(iii) 已自愿或非自愿地转交给他人，或 (iv) 已以其他方式处置；(e) 说明该等处置的理由以及相关事实和情形；(f) 确认授权该等处置的人员；(g) 确认该等处置的日期或大致日期；(h) 说明该文档最近一次由您占有、保管或控制的时间；以及 (i) 确认目前占有、保管或控制该文档的人员（如有）。\n\n7. 如要求您提供一份已被销毁的文档，则除前述指示所要求的信息外，您的答复还必须说明：(a) 销毁该文档的理由；(b) 销毁该文档的人员身份；以及 (c) 指示销毁该文档的人员身份。\n\n8. 如您主张某一被请求的文档享有特权或律师工作成果保护，则您的答复必须：(a) 说明：(i) 足以支持您关于该文档享有特权之主张的文档描述，(ii) 文档标题，(iii) 文档日期，(iv) 文档作者，(v) 文档收件人，(vi) 收到或查看该文档原件或任何草稿、副本或复制件的每一人员身份，(vii) 该文档本身或文档中包含或提及的任何信息是否由任何其他人员占有、保管或控制，如是，则确认该等人员身份，并说明该等信息如何进入其占有范围，(viii) 据以扣留该文档的特权主张，以及 (ix) 您将据以支持该等特权主张的所有情形；以及 (b) 根据 D. Conn. L. Civ. R. 26(e)，就基于特权主张而扣留的每份文档，提供一份特权清单，其中载明本指示第 (a) 部分所要求的全部信息。\nCase 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 400 of 1063\n\n9. 如一份原本具有响应性的文档的一部分包含受特权主张约束的信息，则仅应依照上述指示从该文档中删除或遮盖受特权主张约束的该部分，其余部分应予提供。\n\n10. 该等请求具有持续性质。兹指示您：(a) 一旦得知先前答复不完整或不正确，立即补充或更正后来发现不完整或不正确的任何答复；以及 (b) 提供根据以下内容所要求的任何额外文档\n\n11. 如一份文档使用英语以外的语言，您应提供该文档。如一份文档使用英语以外的语言，且存在英文译本，您应同时提供两份文档。\n\n12. 对实体的所有提及均包括其所有关联方。\n\n13. 对个人姓名的所有提及均包括所有替代名称、别名或昵称。\n\n14. 除非另有明确说明，文档请求所涵盖的期间为自 February 5, 2012 起至文档请求答复到期之日止。\nCase 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 401 of 1063\n\nII. 解释规则\n\n15. (a) 任何单数名词的使用应解释为包括复数，反之亦然；且 (b) 任何时态动词的使用应解释为包括该动词所有其他时态的使用。\n\n16. (a) “and”和“or”应视需要解释为连词或析取词，以将本可被解释为超出任何请求范围的所有答复纳入该请求范围；且 (b) “each”和“any”应视为包括并涵盖“every”和“all”。\nIII. 定义\n\nD. Conn. L. Civ. R. 26(c) 所提供的定义以及 D. Conn. L. Civ. R. 26(d) 所提供的解释规则（经由 D. Conn. Bankr. L.R. 2004-1(a) 纳入）适用于文档请求。此外，本文件档请求中使用的以下术语具有如下含义：\n\n1. “您”或“您的”或“您本人”是指并涵盖 Hamilton Opportunity Fund SPC（汉密尔顿机会基金 SPC）及其所有关联方、分支机构、代理机构、机构部门、部门、办公室、合伙人、高级职员、董事、代理人、律师、代表、雇员和/或代表其行事的任何人。\n\n2. “债务人”是指 Ho Wan Kwok（郭文贵）（又名 Miles Kwok、Miles Guo、Guo Wengui、Guo Haoyun、郭文贵或任何其他别名）及其雇员、代理人、律师、顾问或代表其行事的任何人。\n\n3. “债务人之子”系指 Qiang Guo（郭强，又名 Mileson Kwok，或任何其他别名），以及其雇员、代理人、法律顾问、顾问或任何代表其行事之人。\n案件 22-50073 文书 1592 于 03/24/23 提交，于 03/24/23 10:57:37 登记，第 402 页，共 1063 页\n\n4. “债务人之女”系指 Mei Guo（郭美，又名 Mei Gui，或任何其他别名），以及其雇员、代理人、法律顾问、顾问或任何代表其行事之人。\n\n5. “债务人之所谓妻子”系指 Hing Chi Ngok（岳庆芝，又名 Hing Chi Ng、Yue Qingzhi，或任何其他别名），以及其雇员、代理人、法律顾问、顾问或任何代表其行事之人。\n\n6. “债务人家属”统称债务人、债务人之子、债务人之女及债务人之所谓妻子，以及与债务人存在任何其他家庭关系之人。\n\n7. “关联个人”系指单独或合并符合以下条件的所有个人：(1) 持有、控制、保管或对债务人或债务人家属拥有、控制或享有的资产享有处置权；或 (2) 曾为一个或多个关联实体的雇员、董事，或以其他方式与其有关联，以及前述各方各自的雇员、代理人、法律顾问、顾问或任何代表前述任一方行事之人。该等关联个人包括但不限于：Daniel Podhaskie（丹尼尔·波达斯基）、Jason Miller（杰森·米勒）、Steve Bannon（史蒂夫·班农）、Karin Maistrello（卡琳·迈斯特雷洛）、Melissa Francis（梅丽莎·弗朗西斯）、Anthony DiBattista（安东尼·迪巴蒂斯塔）、William Gertz（威廉·格茨）、Arethusa Forsyth（阿雷图萨·福赛思）、Glenn Mellor（格伦·梅勒）、Jennifer Mercurio（詹妮弗·默丘里奥）、Eduardo Eurnekian（爱德华多·欧尔内基安）、Wencong Wang（王文聪）、Han Chunguang（韩春光，又名 韩春光）、Qu Guojiao（屈国姣，又名 Qu Guo Jiao，屈国姣）、Guo Lijie（郭丽杰，又名 郭丽杰）、Zhang Wei（张伟，又名 张伟*）、Lihong Wei Lafrenz（魏丽红，又名 Sara Wei，魏丽红）、Hao Haidong（郝海东，又名 郝海东）、Ross Heinemeyer（罗斯·海因迈耶）、Max Krasner（马克斯·克拉斯纳）、Kyle Bass（凯尔·巴斯）、Melissa Mendez（梅丽莎·门德斯）、Ya Li（李娅，又名 李娅）、Dinggang Wang（王定刚，又名 王定刚）、An Hong（安红，又名 安红）、Yvette Wang（王雁平，又名 Yanping Wang、Yan Ping Wang，王雁平）、Fiona Yu（菲奥娜·余）、Je Kin Ming（余建明，又名 William Je、Yu Jianming，余建明）、Yaz Qingua（亚兹·青瓜）及 Lao Jiang（姜云浮，又名 Jiang Yunfu、Jiang Yunfu Be，姜云浮）。\n案件 22-50073 文书 1592 于 03/24/23 提交，于 03/24/23 10:57:37 登记，第 403 页，共 1063 页\n\n8. “关联实体”系指单独或合并符合以下条件的任何类型的所有组织或实体：(1) 曾由债务人或债务人家属拥有、控制或投资；或 (2) 对债务人或债务人家属拥有、控制或享有的任何资产直接或间接享有权益，以及前述各方各自的雇员、代理人、法律顾问、顾问或任何代表前述任一方行事之人。该等关联实体包括但不限于：7 Nod Hill LLC（7诺德山有限责任公司）、AAGV Limited（AAGV有限公司）、ACA Investment Management Limited（ACA投资管理有限公司）、ACA Capital Group Limited（ACA资本集团有限公司）、Ace Decade Holdings Limited（艾斯十年控股有限公司）、AI Group Holdings Inc.（AI集团控股公司）、Alfa Global Ventures Limited（阿尔法全球创投有限公司）、Alfonso Global Limited（阿方索全球有限公司）、Allied Capital Global Limited（联合资本全球有限公司）、Alpine Fiduciaries SA（阿尔卑斯受托人股份公司）、Anton Development Limited（安东开发有限公司）、Assets Sino Limited（华资有限公司）、Auspicious Coast Limited（吉祥海岸有限公司）、Beijing Pangu Investment Co.（北京盘古投资公司）、Beijing Pangu Investment Co. Ltd.（北京盘古投资有限公司）、Beijing Pangu Investment Inc.（北京盘古投资公司）、Beijing Zenith Holdings Company Limited（北京泽尼思控股有限公司）、Booming Sail New York LLC（兴帆纽约有限责任公司）、Bravo Luck Limited（鸿运有限公司）、BSA Strategic Fund I（BSA战略基金I）、China Golden Spring (Hong Kong) Limited（中国金泉〈香港〉有限公司）、Chuang Xin Limited（创新有限公司）、Crane Advisory Group LLC（鹤咨询集团有限责任公司）、Creative Apex Investments Limited（创意顶峰投资有限公司）、Crystal Breeze Investments Limited（水晶微风投资有限公司）、Dawn State Limited（曙光州有限公司）、Eastern Profit Corporation Limited（东方利润有限公司）、Elite Well Global Limited（精英环球有限公司）、Empire Growth Holdings（帝国增长控股）、Freedom Media Ventures Ltd.（自由媒体创投有限公司）、G Club Operations LLC（G俱乐部运营有限责任公司）、G Fashion LLC（G时尚有限责任公司）、G News LLC（G新闻有限责任公司）、GETTR USA（GETTR美国）、Genever Holdings Corporation（Genever控股公司）、Genever Holdings LLC（Genever控股有限责任公司）、Gfashion Media Group Inc.（Gfashion媒体集团公司）、GFNY, Inc.（GFNY公司）、Globalist International Limited（环球主义者国际有限公司）、GNews Media Group Inc.（GNews媒体集团公司）、Golden Spring (New York) Ltd.（金泉〈纽约〉有限公司）、Greenwich Land LLC（格林威治土地有限责任公司）、Guo Media（郭媒体）、GTV Media Group, Inc.（GTV媒体集团公司）、Hamilton Capital Holdings Inc.（汉密尔顿资本控股公司）、HCHK Property Management, Inc.（HCHK物业管理公司）、HCHK Technologies, Inc.（HCHK科技公司）、Head Win Group Limited（领先集团有限公司）、Henan Yuda（河南裕达）、Himalaya Embassy（喜马拉雅使馆）、Himalaya Exchange（喜马拉雅交易所）、Himalaya Federal Reserve（喜马拉雅联邦储备）、Himalaya Investment LLC（喜马拉雅投资有限责任公司）、Himalaya International（喜马拉雅国际）、Himalaya New World Inc.（喜马拉雅新世界公司）、Himalaya Supervisory Organization（喜马拉雅监督组织）、Himalaya Ventures LLC（喜马拉雅创投有限责任公司）、HK International Funds Investments (USA) Limited LLC（香港国际基金投资〈美国〉有限责任公司）、Hong Kong International Funds\n案件 22-50073 文书 1592 于 03/24/23 提交，于 03/24/23 10:57:37 登记，第 404 页，共 1063 页\n\nInvestments Limited（香港国际基金投资有限公司）、Hudson Diamond Holding（哈德逊钻石控股）、Infinite Increase Limited（无限增长有限公司）、Infinitum Developments Limited（无限发展有限公司）、Infinity Treasury Management Inc.（无限财资管理公司）、Insight Phoenix Fund（洞见凤凰基金）、Lamp Capital LLC（兰普资本有限责任公司）、Leading Shine Limited（领先光辉有限公司）、Leading Shine NY Limited（领先光辉纽约有限公司）、Lexington Property and Staffing（列克星敦物业及人力配置）、Long Gate Limited（长门有限公司）、Maywind Trading LLC（五月风贸易有限责任公司）、MOS Himalaya LLC（MOS喜马拉雅有限责任公司）、Next Tycoon Investments Limited（下一大亨投资有限公司）、New Federal State of China（中国新联邦国，又名 NFSC）、Noble Fame Global Limited（高贵名声环球有限公司）、Rosy Acme Ventures Limited（玫瑰顶峰创投有限公司）、Rule of Law Foundation III, Inc.（法治基金会III公司）、Rule of Law Foundation IV, Inc.（法治基金会IV公司）、Rule of Law Fund（法治基金）、Rule of Law Society（法治协会）、Rule of Law Society IV, Inc.（法治协会IV公司）、G-Translators PTY LTD（G-翻译者私人有限公司）、Saraca Media Group, Inc.（无忧树媒体集团公司）、Shiny Ace Ltd.（闪耀王牌有限公司）、Shiny Times Holdings Ltd.（光辉时代控股有限公司）、Spirit Charter Investment Limited（精神宪章投资有限公司）、Stevenson, Wong & Co.（Stevenson, Wong & Co.）、Voice of Guo Media, Inc.（郭媒体之声公司）、Well Origin Ltd.（良好起源有限公司）、World Century Limited（世界世纪有限公司）、Worldwide Opportunity Holdings Limited（全球机会控股有限公司）、Whitecroft Shore Limited（怀特克罗夫特海岸有限公司）及 ZIBA Limited（ZIBA有限公司）。\n\n9. “包括”或其任何变体，系指“包括但不限于”。\n\n10. “和”及“或”均系指“和/或”，并应作连词及析取词两种解释，以最大化其适用范围。\n\n11. “任何”、“所有”及“每一”均系指“每一及全部”。\n\n12. “每一”及“每个”均系指“每一及全部”。\n\n13. “第三方”系指除您本人以外的个人或实体。\n\n14. “转让”应具有《破产法典》第 101(54) 条所赋予的含义。\n\n15. “文件”系指属于《联邦民事诉讼规则》第 34 条范围内的任何信息或物品，包括但不限于现由或曾由您占有、保管或控制的每一及全部任何种类、类型、性质或描述的书面、记录或图形材料，包括电子邮件的所有印刷及电子副本、以电子形式保存的计算机文件、电子通信、短信、社交媒体帖子、推文、元数据、信函、备忘录、磁带、速记或手写笔记、任何种类的书面表格、图表、蓝图、图纸、草图、曲线图、计划、文章、规格、日记、信件、电报、照片、会议记录、合同、协议、调查、计算机打印件、任何种类的数据汇编、电传、传真、语音留言、发票、订单表格、支票、汇票、对账单、贷项通知单、报告、持仓报告、摘要、索引、书籍、分类账、笔记本、时间表、透明胶片、录音、目录、广告、宣传材料、影片、录像带、录音带、CD、计算机磁盘、宣传册、小册子、穿孔卡、工时单、Tweets、社交媒体帖子，或任何其他种类的书面或记录材料，以及其所有元数据，无论以何种方式储存（无论为有形或电子形式）、记录、制作或复制；还包括但不限于前述任何材料的草稿或副本，如其中含有原始文件未载有的任何种类笔记、评论或标记，或在其他方面与原始文件不相同。\n案件 22-50073 文书 1592 于 03/24/23 提交，于 03/24/23 10:57:37 登记，第 405 页，共 1063 页\n\n16. “个人”系指个人、公司、独资企业、合伙企业、协会或任何其他实体。“个人”还包括任何代理人、代表或专家，包括但不限于律师或财务顾问。\n\n17. “实体”系指任何自然人、公司、合伙企业、子公司、独资企业、商号、董事会、合资企业、协会、机构、主管机关、委员会或其他商业实体或法人，以及任何关联方、代理人、母公司，包括但不限于法律顾问、财务顾问或任何其他代表。\n\n18. “关于”系指涉及、描述、包含、提及、与……有关、支持、有利于、反对、加强、减损、位于、结合……予以考虑、对……有影响、证明、表明、报告、记录、暗指、答复、\n案件 22-50073 文书 1592 于 03/24/23 提交，于 03/24/23 10:57:37 登记，第 406 页，共 1063 页\n\n与……关联、评论、就……而言、有关、与……相关、讨论、显示、描述、反映、分析、构成及属于。\n\n19. “与……相关”、“与……有关”或“相关于”，在指称任何特定事项时，系指包括但不限于构成、包含、涉及、载有、体现、反映、识别、陈述、直接或间接提及该特定事项，或以任何方式与所确定的特定事项有关的任何文件。\n\n20. “通信”系指在可能的最广泛意义上且不限于任何信息或知识的传递（以事实、观点、询问或其他形式）。通信还指所有谈话、协议、询问或答复，无论是当面、通过电话、以书面形式，或借助电子传输设备进行，并包括但不限于所有信函、电子邮件、录音、传送单、备忘录、电话通信、语音留言、电报、电传传真、影印传真、电传、即时消息、聊天、短信、电话笔记，或在内部或与第三方之间传送的笔记。\n\n21. “资产”系指可用于产生正向经济价值的任何项目，包括但不限于由实体拥有、控制或为实体利益而存在的、预期将提供未来利益的任何具有经济价值的资源，包括但不限于所有不动产及动产、无形财产、投资、投资权或未来收入权、现金、银行账户、商品、证券、请求权、对实体的全部或部分控制权及预期经济机会。\n\n22. “转让”应具有《破产法典》第 101(54) 条所赋予的含义。\n\nIV. 应提交的文件\n\n1. 关于债务人、债务人遗产或关联实体任何收入或资产的所有文件。\n\n2. 与债务人的财务状况及其对债权人的义务有关的所有文件，包括但不限于与任何试图避免支付该等义务的行为有关的所有文件，以及与本次或任何其他实际或潜在破产或类似无力偿债程序有关的所有文件。\n\n3. 关于债务人、债务人遗产、债务人家属、关联实体或关联个人的任何资产负债表、银行对账单、账户对账单、财务报表、账户结单、电汇指示及/或确认、资金证明、存款证、持仓证明、投资组合摘要或类似文件的所有文件，包括但不限于足以显示向前述任何一方作出的所有转让的所有文件。\n\n4. 关于由债务人作出、与债务人进行或代表债务人作出的任何投资、商业交易或交易的所有文件。\n\n5. 与债务人的所有通信，以及与债务人的通信有关并涉及任何实体（包括但不限于关联实体）的运营、管理或决策的文件。\n\n6. 关于向债务人、债务人家属或关联实体作出、由其作出或与其进行的任何转让、投资或其他交易或商业往来的所有文件。\n\n7. 关于债务人曾占用或使用的任何财产的所有文件，包括但不限于 Lady May（梅夫人号）；Sherry Netherland Hotel / Condominium（雪莉荷兰酒店／共管公寓）；位于 Connecticut（康涅狄格州）Greenwich（格林威治）373 Taconic Rd. 的住宅物业；位于 Connecticut（康涅狄格州）Greenwich（格林威治）33 Ferncliff Rd. 的住宅物业；以及位于 Connecticut（康涅狄格州）Wilton（威尔顿）354 Nod Hill Rd. 的住宅物业。\n\n8. 与债务人拥有、控制或使用的任何航空器有关的所有文件，包括但不限于尾号为 T7-GQM 的航空器以及在 San Marino（圣马力诺）注册的任何其他航空器，包括但不限于所有登记文件副本，以及显示该等航空器所执行航班和该等航班机上人员的飞行舱单。\n\n9. 关于向债务人、债务人财产、债务人家庭成员或关联实体提供、由其提供或代表其提供的任何赠与、利益或贷款的所有文件，包括但不限于足以显示该等赠与、利益或贷款金额的文件；该等赠与、利益或贷款的用途；提供该等赠与、利益或贷款的时间；以及任何贷款的条款、就任何贷款作出的所有陈述与保证、任何贷款的利率，以及任何贷款付款的所有证据。\n\n10. 关于由债务人、代表债务人或为债务人利益，为债务人财产、债务人家庭成员或关联实体设立的任何信托或类似文书的所有文件，包括但不限于足以显示该等信托设立时间、设立人、受益人及信托本金的文件。\n\n11. 与涉及债务人的任何法律争议相关的任何义务、请求权、责任或债务有关的所有文件，包括但不限于与在任何地方、州、联邦或国际机构（无论是行政机构、法院、合议庭或替代性争议解决机构）进行的任何诉讼有关的文件。\n案号 22-50073 文件 1592 提交日期 03/24/23 录入日期 03/24/23 10:57:37 第 409 页，共 1063 页\n\n12. 您的任何外部律师或其他顾问与债务人之间的所有文件和通信。\n\n13. 足以显示您的所有资产以及收入或资金来源的文件。\n\n14. 对于就第 14 项请求所确认的、价值超过 \\$50,000 的所有资产，提供：(i) 与您取得该等资产有关的所有文件，以及 (ii) 与债务人或债务人家庭成员就该等资产进行的通信。\n\n15. 您的纳税申报表副本。\n\n16. 足以显示由您持有或控制的所有银行账户和投资账户的文件，包括每一该等账户的余额以及向该等账户转入和自该等账户转出的款项。\n\n17. 关于您使用的任何信用卡的所有文件，包括但不限于月度对账单或足以显示为债务人或关联实体利益而进行的所有相关购买的其他文件。\n\n18. 所有公司治理及组织文件，包括但不限于章程细则、公司注册证书以及足以显示您的公司结构、高级职员和董事姓名、经营宗旨，以及与债务人或债务人任何家庭成员关系的其他文件。\n\n19. 与将您的任何资产质押给任何其他实体有关的所有文件。\n\n案号 22-50073 文件 1592 提交日期 03/24/23 录入日期 03/24/23 10:57:37 第 410 页，共 1063 页\n\n附件 C-22\n\nB2540（表格 2540——规则 2004 审查传票）（12/15）案号 22-50073 文件 1592 提交日期 03/24/23 录入日期 03/24/23 10:57:37 第 411 页，共\n\n美国破产法院\n\n康涅狄格地区\n\n关于 HO WAN KWOK（郭文贵）等人案，\n\n1 案号 22-50073 (JAM) 债务人 第 11 章\n\n（合并管理）\n规则 2004 审查传票\n\n致：Ginnel Associates, Inc.（Ginnel Associates, Inc.，以 Ginnel Real Estate 名义营业）\n\n（传票送达对象姓名）\n\n证言：兹命令您于下述时间、日期及地点出席，并根据《联邦破产程序规则》规则 2004 接受审查并作证。随附授权该审查的法院命令副本。\n\n地点　日期及时间\n\nPaul Hastings LLP（保罗·黑斯廷斯律师事务所）\n200 Park Avenue　[TBD]\nNew York, New York 10166（纽约州纽约市 10166）\n\n审查将通过以下方式记录：法庭记录员/速记员\n\n提交：您或您的代表还必须在审查时携带下列文件、电子存储信息或物品，并必须允许对该等材料进行查验、复制、测试或抽样：\n见随附的文件提交请求。\n\n《联邦民事诉讼规则》规则 45 的下列条款（根据《联邦破产程序规则》规则 9016 适用于破产案件）随附于后——关于履行地点的规则 45(c)；关于作为传票对象的您所受保护的规则 45(d)；以及关于您对本传票的回应义务及未回应可能后果的规则 45(e) 和 45(g)。\n\n日期：March , 2023\n\n法院书记员\n\n或\n\n书记员或副书记员签名　律师签名\n\n代表签发或请求本传票的第 11 章受托人 Luc A. Despins（Luc A. Despins）的律师姓名、地址、电子邮箱地址及电话号码如下：\n\nDouglas S. Skalka, Esq.（Douglas S. Skalka 律师）；Neubert, Pepe & Monteith, P.C.（Neubert, Pepe & Monteith, P.C.）；195 Church Street, New Haven, Connecticut 06510（康涅狄格州纽黑文市 Church Street 195 号，邮编 06510）dskalka@npmlaw.com；(203) 821-2000\n\n致签发或请求本传票之人的通知\n\n如本传票要求在审判前提交文件、电子存储信息或有形物品，或查验场所，则必须在向传票所指向之人送达前，向各方当事人送达通知及本传票副本。《联邦民事诉讼规则》规则 45(a)(4)。\n\n软件版权 (c) 1996-2022 Best Case, LLC（Best Case, LLC）- www.bestcase.com Best Case Bankruptcy（Best Case 破产软件） 1 本第 11 章案件中的债务人为 Ho Wan Kwok（郭文贵，亦称 Guo Wengui、Miles Guo 和 Miles Kwok，以及众多其他别名）（税务识别号码末四位：9595）、Genever Holdings LLC（Genever Holdings LLC，税务识别号码末四位：8202）及 Genever Holdings Corporation（Genever Holdings Corporation）。受托人、Genever Holdings LLC 及 Genever Holdings Corporation 的邮寄地址为 Paul Hastings LLP（保罗·黑斯廷斯律师事务所），200 Park Avenue, New York, NY 10166（纽约州纽约市 Park Avenue 200 号，邮编 10166），转交 Luc A. Despins，作为 Ho Wan Kwok（郭文贵）财产的受托人（仅用于通知和通信）。\n\n送达证明\n\n（除非《联邦民事诉讼规则》规则 45 要求，否则本节不应向法院提交。）\n\n我于（日期）收到向（个人姓名及职务，如有）送达的本传票。\n\n我通过如下方式向所列明人员交付副本以送达传票：\n\n于（日期）送达；或\n\n我未执行本传票即予退回，原因如下：\n\n除非本传票代表美国或其官员或代理人签发，我还已向证人支付一天出席费用及法律允许的里程费用，金额为 \\$ 。\n\n我的差旅费用为 \\$ ，服务费用为 \\$ ，合计为 \\$ 。\n\n本人谨在伪证处罚的约束下声明，上述信息真实、准确。\n\n日期：\n\n送达人员签名\n\n正楷姓名及职务\n\n送达人员地址\n\n关于尝试送达等的补充信息：\n《联邦民事诉讼规则》规则 45(c)、(d)、(e) 及 (g)（自 12/1/13 起生效）（根据《联邦破产程序规则》规则 9016 适用于破产案件）\n\n(c) 履行地点。\n\n(1) 审判、听证或证言录取。传票仅可按以下方式命令某人出席审判、听证或证言录取：\n\n(A) 在该人居住、受雇或经常亲自从事商业活动地点 100 英里以内；或\n\n(B) 在该人居住、受雇或经常亲自从事商业活动所在州内，条件是该人：\n\n(i) 为当事人或当事人的高级职员；或\n\n(ii) 被命令出席审判且不会产生重大费用。\n\n(2) 其他取证。传票可命令：\n\n(A) 在该人居住、受雇或经常亲自从事商业活动地点 100 英里以内的地点提交文件、电子存储信息或物品；以及\n\n(B) 在拟查验场所进行场所查验。\n\n(d) 对作为传票对象之人的保护；执行。\n\n(1) 避免不当负担或费用；制裁。负责签发和送达传票的当事人或律师必须采取合理措施，避免对传票对象施加不当负担或费用。要求履行的地区法院必须执行该义务，并对未遵守者的当事人或律师施加适当制裁，制裁可包括误工损失和合理律师费。\n\n(2) 提交材料或允许查验的命令。\n\n(A) 无需出席。被命令提交文件、电子存储信息或有形物品，或允许查验场所的人，无需亲自出现在提交或查验地点，除非同时被命令出席证言录取、听证或审判。\n\n(B) 异议。被命令提交文件或有形物品，或允许查验的人，可以向传票中指定的当事人或律师送达书面异议，反对查验、复制、测试或抽样任何或全部材料，或反对查验场所，或反对以所要求的一种或多种形式提交电子存储信息。异议必须在指定履行时间或传票送达后 14 日中较早者之前送达。如提出异议，适用下列规则：\n\n(i) 在任何时候，经通知被命令人后，送达方可以向要求履行的地区法院提出动议，请求作出强制提交或查验的命令。\n\n(ii) 仅可按照命令的指示要求实施该等行为，且该命令必须保护既非当事人亦非当事人高级职员之人免于承担因履行而产生的重大费用。\n\n(3) 撤销或修改传票。\n\n(A) 必须撤销或修改的情形。经及时动议，要求履行的地区法院必须撤销或修改具有下列情形的传票：\n\n(i) 未给予合理的履行时间；\n\n(ii) 要求某人在规则 45(c) 规定的地域限制之外履行；\n\n(iii) 要求披露享有特权或受其他保护的事项，且不适用任何例外或豁免；或\n\n(iv) 对某人施加不当负担。\n\n(B) 可以撤销或修改的情形。为保护作为传票对象或受传票影响之人，经动议，要求履行的地区法院可以撤销或修改要求下列事项的传票：\n\n(i) 披露商业秘密或其他保密的研究、开发或商业信息；或\n\n(ii) 披露未受聘专家的意见或信息，该等意见或信息并非描述争议中的具体事件，且源于并非由当事人请求的该专家研究。\n\n(C) 以规定条件作为替代方案。在规则 45(d)(3)(B) 所述情形下，如送达方：\n\n(i) 证明其对该证言或材料具有实质性需要，且如不承受不当困难便无法以其他方式满足该需要；并且\n\n(ii) 确保被传唤之人将获得合理补偿，\n\n则法院可以不撤销或修改传票，而命令在规定条件下出席或提交。\n\n(e) 回应传票的义务。\n\n(1) 提交文件或电子存储信息。下列程序适用于提交文件或电子存储信息：\n\n(A) 文件。回应提交文件传票的人必须按文件在通常业务过程中保存的方式提交，或者必须整理并标注文件，以对应请求中的类别。\n\n(B) 未指定提交电子存储信息的形式。如传票未指定提交电子存储信息的形式，回应人必须以其通常保存的一种或多种形式，或者以一种或多种合理可用的形式提交。\n\n(C) 电子存储信息仅以一种形式提交。回应人无需以超过一种形式提交相同的电子存储信息。\n\n(D) 无法合理获取的电子存储信息。答复人无需提供其认定因不当负担或费用而无法合理获取来源的电子存储信息的证据开示。在强制证据开示动议或保护令动议中，答复人必须证明该信息因不当负担或费用而无法合理获取。如作出该证明，法院仍可在请求方根据 Rule 26(b)(2)(C) 的限制条件证明存在正当理由时，下令从该等来源进行证据开示。法院可规定该证据开示的条件。\n\n(2) 主张特权或保护。\n\n(A) 扣留的信息。以该信息享有特权或作为审判准备材料受保护为由扣留经传唤的信息的人必须：(i) 明确提出该主张；以及\n\n(ii) 以一种不会披露本身享有特权或受保护的信息、但能使各方评估该主张的方式，说明被扣留的文件、通信或有形物品的性质。\n\n(B) 已提供的信息。如为响应传票而提供的信息被主张享有特权或作为审判准备材料受保护，提出该主张的人可将该主张及其依据通知收到该信息的任何一方。收到通知后，当事人必须立即返还、隔离或销毁所指明的信息及其持有的任何副本；在该主张得到解决前，不得使用或披露该信息；如当事人在收到通知前已披露该信息，必须采取合理措施追回该信息；并可立即将该信息密封提交给要求履行义务所在地区的法院，以裁定该主张。提供该信息的人必须在该主张得到解决前保存该信息。\n\n(g) 藐视法庭。要求履行义务所在地区的法院——以及在动议移送后，签发传票的法院——可认定已被送达但无充分理由不遵守传票或相关命令的人构成藐视法庭。\n\n有关获取传票材料，参见 Fed.R.Civ.P.45(a) Committee Note (2013)\n\n……\n\n文件出示请求\nI. 指示\n\n1. 除非另有说明，下列文件请求（统称“请求”，单称“一项请求”）必须分别且具体地作出答复。每项请求均应得到完整答复，除非基于善意提出异议；在此情况下，应按下述规定详细说明您提出异议的理由。如异议仅涉及某项请求的一部分，或其中包含的一个词、短语或条款，您仅须说明对该部分的异议，并对其余请求作出答复。\n\n2. 电子存储信息必须按照以下指示提供：\n\na. 图像。黑白图像必须为 300 DPI Group IV 单页 TIFF 文件。彩色图像必须以 JPEG 格式提供。文件名不得包含嵌入空格或特殊字符（包括逗号）。文件夹名称不得包含嵌入空格或特殊字符（包括逗号）。所有 TIFF 图像文件必须具有唯一的文件名，即 Bates 编号。每幅图像右下角必须标注连续的 Bates 编号。每个文件夹内的 TIFF 文件数不得超过 1000 个文件。Excel 电子表格应包含以该文件 Bates 编号命名的占位图像。\n\nb. 图像加载文件\n\na. Concordance® 数据文件。数据文件（.DAT）包含将加载至 Concordance® 数据库的所有字段化信息。.DAT 文件的第一行必须为标明字段名称的标题行。.DAT 文件必须使用以下 Concordance® 默认分隔符：逗号 ASCII 字符（020）；引号 þ ASCII 字符（254）。日期字段应以如下格式提供：mm/dd/yyyy。日期和时间字段必须为两个单独字段。如文件包括图像化的电子邮件及附件，则必须包括附件字段，以保存电子邮件与其附件之间的父项/子项关系。必须包括 OCRPATH 字段，以提供所提供存储介质上提取文本文件的文件路径及名称。文本文件必须以 FIRSTBATES 命名。不得将文本包含在 .DAT 文件中。对于含有原生文件的文件，必须包括 LINK 字段，以提供原生文件的文件路径及名称。原生文件必须以 FIRSTBATES 命名。\n\nb. Concordance Image® 或 Opticon 交叉引用文件。图像交叉引用文件（.LOG 或 .OPT）将图像链接至数据库记录。该文件应为逗号分隔文件，每行由七个字段组成，数据库中的每幅图像均应在交叉引用文件中有一行，格式如下：ImageID,VolumeLabel,ImageFilePath,DocumentBreak,FolderBreak,Box Break,PageCoun。\n\nc. 文件文本。文本必须作为独立文本文件提供，不得作为 .DAT 文件中的字段提供。文本文件的完整路径（OCRPATH）应包含在 .DAT 文件中。建议提供以 FIRSTBATES/Image Key 命名的文件级 ANSI 文本文件。提取的文本文件必须置于单独文件夹中，且每个文件夹中的文本文件数不得超过 1,000 个文件。文件夹名称不得包含特殊字符（包括逗号）。文本文件必须按文件级别提供。\n\nd. 特定文件类型的原生格式提供。为充分理解其内容和含义而合理需要以原生格式查看的文件类型，必须以原生格式提供。该等文件包括但不限于电子表格、类电子表格文件（Microsoft Excel、逗号分隔值、制表符分隔值等）、Microsoft PowerPoint 或其他特殊演示文件、数据库文件及音频/视频文件。提供一张标有 Bates 编号的分隔页图像，说明存在原生文件，并将原生文件的路径作为字段包含在 .dat 文件中。所提供的原生文件应以与该文件分隔页相对应的 Bates 编号命名。将原生文件归入按递增方式命名的“NATIVE”目录，并与图像目录分开。\n\ne. 去重。对于存在完全相同副本的每份电子文件，仅提供一份副本。对于电子邮件，应根据从 BCC、Body、CC、From、IntMsgID、To 和 Attach 属性生成的 MD5 哈希值合并重复文件。对于电子邮件附件和独立电子文件，应根据整个文件的 MD5 哈希值合并重复文件。\n\nf. 元数据。以符合 Concordance 的加载文件（.dat）形式提供每份文件的提取元数据。.DAT 文件的第一行必须为标明字段名称的标题行。.DAT 文件必须使用以下 Concordance 默认分隔符：逗号 , ASCII 字符（020）；引号 þ ASCII 字符（254）。\n\n日期字段应以如下格式提供：mm/dd/yyyy。日期和时间字段必须为两个单独字段。以下列出所需元数据：\nCase 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 416 of 1063\n\n字段名称　示例数据　说明\n\nFIRSTBATES　EDC0000001　原生文件文件/电子邮件的第一个 Bates 编号\nLASTBATES　EDC0000001　原生文件文件/电子邮件的最后一个 Bates 编号\nLASTBATES 字段应针对单页填写\nATTACHRANGE　EDC0000001\n-　父项文件第一页的 Bates 编号至最后一个附件“子项”文件最后一页的 Bates 编号\nEDC0000015\nBEGATTACH　EDC0000001　附件范围的第一个 Bates 编号\nENDATTACH　EDC0000015　附件范围的最后一个 Bates 编号\nCUSTODIAN　Smith, John（约翰·史密斯）　电子邮件：电子邮件所在的邮箱\n原生文件：文件来源个人或部门的名称\nFROM　John Smith（约翰·史密斯）　电子邮件：发件人\n原生文件：文件作者\n多个条目应使用分号分隔\nTO　Coffman, Janice（贾尼斯·科夫曼）; LeeW　收件人\n[mailto:LeeW@MSN.com]　多个条目应使用分号分隔\nCC　Frank Thompson（弗兰克·汤普森） [mailto:　抄送收件人\nfrank_Thompson@cdt.com]　多个条目应使用分号分隔\nBCC　John Cain（约翰·凯恩）　密送收件人\n多个条目应使用分号分隔\nSUBJECT　Board Meeting Minutes　电子邮件：电子邮件主题行；原生文件：文件标题（如有）\nFILE_NAME　BoardMeetingMinutes.docx　原生文件：原始原生文件的名称，包括扩展名\nDATE_SENT　10/12/2010　电子邮件：电子邮件发送日期\n原生文件：（空）\nTIME_SENT/\nTIME_ZONE　07:05 PM GMT　电子邮件：电子邮件发送时间/电子邮件标准化所使用的时区\nTIME_ZONE　GMT　在转换期间电子邮件被标准化所使用的时区。\nLINK　EDC0000001.msg　电子邮件或原生文件文件的超链接\n所链接文件必须以 FIRSTBATES 编号命名\nFILE_EXTEN　MSG　代表电子邮件或原生文件的文件类型扩展名\nAUTHOR　John Smith（约翰·史密斯）　电子邮件：（空）\n原生文件：文件作者\nDATE_CREATED　10/10/2010　电子邮件：（空）\n原生文件：文件创建日期\nCase 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 417 of 1063\n\nTIME_CREATED　10:25 AM　电子邮件：（空）\n原生文件：文件创建时间\n该数据必须为单独字段，不得与 DATE_CREATED 字段合并\nDATE_MOD　10/12/2010　电子邮件：（空）\n原生文件：文件最后修改日期\nTIME_MOD　07:00 PM　电子邮件：（空）\n原生文件：文件最后修改时间\n该数据必须为单独字段，不得与 DATE_MOD 字段合并\nDATE_ACCESSD　10/12/2010　电子邮件：（空）\n原生文件：文件最后访问日期\nTIME_ACCESSD　07:00 PM　电子邮件：（空）\n原生文件：文件最后访问时间\n该数据必须为单独字段，不得与 DATE_ACCESSD 字段合并\nFILE_SIZE　5,952　原生文件文件/电子邮件的大小，以 KB 计\nPGCOUNT　1　原生文件文件/电子邮件的页数\nPATH　电子邮件：（空）\nAgenda.doc　原生文件：存储原生文件文件的路径，包括原始文件名。\nINTFILEPATH　Personal Folders\\Deleted　电子邮件：电子邮件的原始位置，包括原始文件名。\nItems\\Board Meeting\nMinutes.msg　原生文件：（空）\nINTMSGID　<000805c2c71b\\$75977050\\$　电子邮件：唯一消息 ID；原生文件：（空）\ncb8306d1@MSN>\nMD5HASH　d131dd02c5e6eec4693d9a0　文件的 MD5 哈希值。\n698aff95c\n2fcab58712467eab4004583e\nb8fb7f89\nOCRPATH　TEXT/001/EDC0000001.txt　原生文件提取文本的路径\n\n3. 每项请求独立运作并应独立解释，且除非另有说明，任何请求均不限制任何其他请求的范围。\n\n4. 所有文件均应按其在通常业务过程中保存的方式提供，或应予以整理和标记，以对应本请求中的类别。\n\n5. 本文所载每项请求均延及所有文件：(a) 由您占有、保管或控制的文件；或 (b) 由代表您行事的任何人占有、保管或控制的文件，\nCase 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 418 of 1063\n\n包括您的律师或其他代表及顾问。每份文件均应完整提供。\n\n6. 如要求贵方提供已不再由贵方占有、保管或控制的文件，则贵方的答复必须：(a) 详细描述该文件的性质及其内容；(b) 确定编制或撰写该文件的人员（以及，如适用，该文件被发送给的人员）；(c) 确定该文件编制或制作的日期；(d) 说明该文件是否：(i) 遗失或丢失，(ii) 已被销毁，(iii) 自愿或非自愿地转交给他人，或(iv) 以其他方式处置；(e) 说明该等处置的原因，以及与该等处置有关的事实和情形；(f) 确定授权该等处置的人员；(g) 确定该等处置的日期或大致日期；(h) 说明该文件最近一次处于贵方占有、保管或控制之下的时间；以及(i) 确定现时占有、保管或控制该文件的人员（如有）。\n\n7. 如要求贵方提供已被销毁的文件，则除前述指示所要求的信息外，贵方的答复还必须说明：(a) 销毁该文件的原因；(b) 销毁该文件的人员身份；以及(c) 指示销毁该文件的人员身份。\n\n8. 如贵方主张所要求的文件享有特权或属于律师工作成果，则贵方的答复必须：(a) 说明：(i) 对该文件作出足以支持贵方关于该文件享有特权之主张的描述，(ii) 该文件的标题，(iii) 该文件的日期，(iv) 该文件的作者，(v) 该文件的收件人，(vi) 收到或阅览该文件原件或任何草稿、副本或复制件的每一人员的身份，(vii) 该文件本身或该文件所载或提及的任何信息是否处于任何其他人员的占有、保管或控制之下；如是，则说明该等人员的身份，以及说明该等信息如何进入其占有，(viii) 据以扣留该文件的特权主张，以及(ix) 贵方将据以支持该等特权主张的一切情形；以及(b) 就依据特权主张而扣留的每一文件，按照 D. Conn. L. Civ. R. 26(e)，制作一份载有本指示第(a)部分所要求全部信息的特权日志。对于文件请求中未提出特权或工作成果主张的任何部分，应完整提供相应文件。\n\n案件 22-50073 文件 1592 提交日期 03/24/23 录入日期 03/24/23 10:57:37 第 419 页，共 1063 页\n\n9. 如本应提交的文件的一部分含有受特权主张约束的信息，则仅应依照上述指示从该文件中删除或遮蔽受特权主张约束的该部分，其余部分应予提供。\n\n10. 该等请求具有持续性。现指示贵方：(a) 一旦得知先前答复不完整或不正确，应立即补充或更正任何后来得知不完整或不正确的答复；以及(b) 提供根据该等请求所要求的任何额外文件。\n\n11. 如某文件使用英语以外的语言，贵方应提供该文件。如某文件使用英语以外的语言，且存在英文译本，贵方应同时提供两份文件。\n\n12. 对实体的一切提述均包括其所有关联方。\n\n13. 对个人姓名的一切提述均包括所有替代姓名、别名或昵称。\n\n案件 22-50073 文件 1592 提交日期 03/24/23 录入日期 03/24/23 10:57:37 第 420 页，共 1063 页\n\n14. 除非另有明确说明，文件请求所涵盖的期间为自 February 5, 2015 起至应提交文件请求答复之日止。\n\nII. 解释规则\n\n15. (a) 对任何单数名词的使用应解释为包括复数，反之亦然；以及(b) 对任何时态动词的使用应解释为包括该动词所有其他时态的使用。\n\n16. (a) “and”和“or”应按必要情况解释为合取或析取，以使原本可能被解释为在任何请求范围之外的所有答复均纳入该请求的范围；以及(b) “each”和“any”应视为包括并涵盖“every”和“all”二词。\n\nIII. 定义\n\n经 D. Conn. Bankr. L.R. 2004-1(a) 纳入的 D. Conn. L. Civ. R. 26(c) 所规定的定义，以及 D. Conn. L. Civ. R. 26(d) 所规定的解释规则，适用于该等文件请求。此外，本文件请求中使用的下列术语具有如下含义：\n\n1. “You”或“Your”或“Yourself”系指 Ginnel Associates, Inc.（金内尔联合公司），连同其所有关联方、部门、机构、工具、处室、办事处、合伙人、高级职员、董事、代理人、律师、代表、雇员和/或代表其行事的任何人。\n\n案件 22-50073 文件 1592 提交日期 03/24/23 录入日期 03/24/23 10:57:37 第 421 页，共 1063 页\n\n2. “Debtor”系指 Ho Wan Kwok（郭文贵）（又名 Miles Kwok、Miles Guo、Guo Wengui、Guo Haoyun、郭文贵或任何其他别名），连同其雇员、代理人、法律顾问、顾问或代表其行事的任何人。\n\n3. “Debtor's Son”系指 Qiang Guo（郭强）（又名 Mileson Kwok、郭强或任何其他别名），连同其雇员、代理人、法律顾问、顾问或代表其行事的任何人。\n\n4. “Debtor's Daughter”系指 Mei Guo（郭美）（又名 Mei Gui、郭美或任何其他别名），连同其雇员、代理人、法律顾问、顾问或代表其行事的任何人。\n\n5. “Debtor's Purported Wife”系指 Hing Chi Ngok（岳庆芝）（又名 Hing Chi Ng、Yue Qingzhi、岳庆芝或任何其他别名），连同其雇员、代理人、法律顾问、顾问或代表其行事的任何人。\n\n6. “Debtor's Family”统称债务人、债务人之子、债务人之女及债务人所谓的妻子，以及与债务人有任何其他亲属关系的人。\n\n7. “Associated Individuals”单独及统称：(1) 持有、控制、保管或对债务人或债务人家属拥有、控制或享用的资产享有酌处权的所有个人；或(2) 曾为一个或多个关联实体的雇员、董事，或以其他方式与一个或多个关联实体有关联的所有个人，连同前述各方各自的雇员、代理人、法律顾问、顾问或代表其行事的任何人。该等关联个人包括但不限于：Daniel Podhaskie（丹尼尔·波德哈斯基）、Karin Maistrello（卡琳·迈斯特雷洛）、Melissa Francis（梅丽莎·弗朗西斯）、Anthony DiBattista（安东尼·迪巴蒂斯塔）、Han Chunguang（韩春光）（又名韩春光）、Qu Guojiao（屈国姣）（又名 Qu Guo Jiao、屈国姣）、Zhang Wei（张伟）（又名张伟*）、Lihong Wei Lafrenz（魏丽红）（又名 Sara Wei、魏丽红）、Max Krasner（马克斯·克拉斯纳）、Yvette Wang（王雁平）（又名 Yanping Wang、Yan Ping Wang、王雁平）、Fiona Yu（菲奥娜·余）及 Je Kin Ming（余建明）（又名 William Je、Yu Jianming、余建明）。\n\n案件 22-50073 文件 1592 提交日期 03/24/23 录入日期 03/24/23 10:57:37 第 422 页，共 1063 页\n\n8. “Associated Entities”单独及统称：(1) 曾由债务人或债务人家属拥有、控制或投资的任何类型的所有组织或实体；或(2) 对债务人或债务人家属拥有、控制或享用的任何资产直接或间接享有权益的所有组织或实体，连同前述各方各自的雇员、代理人、法律顾问、顾问或代表其行事的任何人。该等关联实体包括但不限于：7 Nod Hill LLC（七诺德山有限责任公司）、ACA Investment Management Limited（ACA投资管理有限公司）、ACA Capital Group Limited（ACA资本集团有限公司）、Ace Decade Holdings Limited（王牌十年控股有限公司）、AI Group Holdings Inc.（AI集团控股公司）、Booming Sail New York LLC（兴盛帆纽约有限责任公司）、Bravo Luck Limited（好运有限公司）、China Golden Spring (Hong Kong) Limited（中国金泉〈香港〉有限公司）、Crane Advisory Group LLC（鹤顾问集团有限责任公司）、Dawn State Limited（黎明州有限公司）、Eastern Profit Corporation Limited（东方利润有限公司）、Freedom Media Ventures Ltd.（自由媒体创投有限公司）、G Club Operations LLC（G俱乐部运营有限责任公司）、G Fashion LLC（G时尚有限责任公司）、G News LLC（G新闻有限责任公司）、GETTR USA（GETTR美国）、Genever Holdings Corporation（吉尼弗控股公司）、Genever Holdings LLC（吉尼弗控股有限责任公司）、Gfashion Media Group Inc.（G时尚媒体集团公司）、GFNY, Inc.（GFNY公司）、Golden Spring (New York) Ltd.（金泉〈纽约〉有限公司）、Greenwich Land LLC（格林尼治土地有限责任公司）、GTV Media Group, Inc.（GTV媒体集团公司）、Hamilton Capital Holdings Inc.（汉密尔顿资本控股公司）、HCHK Property Management, Inc.（HCHK物业管理公司）、HCHK Technologies, Inc.（HCHK科技公司）、Himalaya Embassy（喜马拉雅大使馆）、Himalaya Exchange（喜马拉雅交易所）、Himalaya Federal Reserve（喜马拉雅联邦储备）、Himalaya Investment LLC（喜马拉雅投资有限责任公司）、Himalaya International（喜马拉雅国际）、Himalaya New World Inc.（喜马拉雅新世界公司）、Himalaya Supervisory Organization（喜马拉雅监督组织）、Himalaya Ventures LLC（喜马拉雅创投有限责任公司）、HK International Funds Investments (USA) Limited LLC（香港国际基金投资〈美国〉有限责任公司）、Hong Kong International Funds Investments Limited（香港国际基金投资有限公司）、Hudson Diamond Holding（哈德逊钻石控股）、Infinity Treasury Management Inc.（无限财务管理公司）、Lexington Property and Staffing（列克星敦物业与人事）、Long Gate Limited（长龙门有限公司）、Maywind Trading LLC（五月风贸易有限责任公司）、MOS Himalaya LLC（MOS喜马拉雅有限责任公司）、New Federal State of China（中国新联邦国）（又名 NFSC）、Rule of Law Foundation III, Inc.（法治基金会III公司）、Rule of Law Foundation IV, Inc.（法治基金会IV公司）、Rule of Law Fund（法治基金）、Rule of Law Society（法治协会）、Rule of Law Society IV, Inc.（法治协会IV公司）、G-Translators PTY LTD（G译者有限公司）、Saraca Media Group, Inc.（萨拉卡媒体集团公司）、Well Origin Ltd.（良源有限公司）、Whitecroft Shore Limited（怀特克罗夫特海岸有限公司）及 ZIBA Limited（ZIBA有限公司）。\n\n9. “Including”或其任何变体，意为“包括但不限于”。\n\n案件 22-50073 文件 1592 提交日期 03/24/23 录入日期 03/24/23 10:57:37 第 423 页，共 1063 页\n\n10. “And”和“or”意为“and/or”，并应按合取及析取两种方式解释，以最大限度扩大其范围。\n\n11. “Any”、“all”和“each”意为“each and every”。\n\n12. “Each”和“every”意为“each and every”。\n\n13. “Third Party”系指贵方以外的人员或实体。\n\n14. “Transfer”具有《破产法》section 101(54) 赋予该词的含义。\n\n15. “Document”系指属于 Fed. R. Civ. P. 34 范围内的任何信息或物品，并包括但不限于：现由或曾由贵方占有、保管或控制的任何种类、类型、性质或描述的每一书面、记录或图形材料，包括电子邮件的所有纸质和电子副本、以电子形式保存的计算机文件、往来函件、备忘录、磁带、速记或手写笔记、任何种类的书面表格、图表、蓝图、图纸、草图、图形、计划、文章、规格、日记、信函、电报、照片、会议记录、合同、协议、调查资料、计算机打印件、任何种类的数据汇编、电传、传真、电子邮件、短信、即时消息、语音留言、发票、订单表、支票、汇票、对账单、贷项通知单、报告、头寸报告、摘要、索引、书籍、账簿、笔记本、清单、透明胶片、录音、目录、广告、宣传材料、影片、录像带、录音带、CD、计算机磁盘、宣传册、小册子、穿孔卡、工时单、推文、社交媒体帖子或任何其他种类的书面或记录材料，以及其所有元数据，无论以何种方式存储（无论为有形或电子形式）、记录、制作或复制；亦包括但不限于前述任何文件的草稿或副本，如其中载有原始文件中未见的任何种类笔记、评论或标记，或以其他方式与原始文件不完全相同。\n\n案件 22-50073 文件 1592 提交日期 03/24/23 录入日期 03/24/23 10:57:37 第 424 页，共 1063 页\n\n16. “Person(s)”系指个人、公司、独资企业、合伙企业、协会或任何其他实体。“Person”亦包括任何代理人、代表或专家，包括但不限于律师或财务顾问。\n\n17. “Entity”系指任何自然人、公司、合伙企业、子公司、独资企业、商号、董事会、合资企业、协会、机构、机关、委员会或其他商业实体或法人，以及任何关联方、代理人、母公司，包括但不限于法律顾问、财务顾问或任何其他代表。\n\n18. “关于”系指涉及、描述、包括、提及、与之相关、支持、有利于、反对、强化、减损、位于、结合考虑、对……具有影响、证明、表明、报道、记录、暗示、回应、与……相连、评论、就……而言、关于、与……有关、讨论、显示、描述、反映、分析、构成及属于。\n\n19. 就任何特定事项而言，“与……有关”、“涉及”或“相关”系指但不限于构成、包括、涉及、包含、体现、反映、识别、陈述、直接或间接提及该特定事项，或以任何方式与所确定的特定事项有关的任何文档。\n\n20. “通信”系指以最广泛的含义且不限于任何信息或知识的传递（以事实、观点、询问或其他形式）。通信还指所有谈话、协议、询问或答复，无论是当面、通过电话、书面方式，还是通过电子传输设备进行，并包括但不限于所有信函、电子邮件、录音、传送单、备忘录、电话通信、语音留言、电报、传真、电传副本、电传、即时消息、聊天、短信、发布至留言板或群聊的信息、社交媒体帖子、推文、上传至任何视频平台的视频、电话记录，或在内部或与第三方之间传送的记录。\n\nCase 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 425 of 1063\n\n21. “资产”系指受占有、保管或控制的任何具有经济价值的项目。资产包括所有不动产和动产，包括但不限于房地产、土地、房屋、公寓、产权公寓、汽车、游艇、船只、飞机、喷气式飞机、直升机、现金、银行账户、加密货币、证券、应收账款、存货以及其他有形和无形财产。\n\n四、应提交的文档\n\n1. 与位于 781 Fifth Avenue, New York, NY 10022 的 Sherry Netherland Hotel / Condominium（雪莉荷兰酒店／产权公寓）（1801 号及 1519 号公寓）；位于 373 Taconic Rd., Greenwich, Connecticut 06831 的住宅物业；位于 33 Ferncliff Rd., Cos Cob, Connecticut 06807 的住宅物业；位于 354 Nod Hill Rd., Wilton, Connecticut 06897 的住宅物业；位于 32 Chateau Ridge Rd., Greenwich, Connecticut 06831 的物业；位于 110 Clapboard Ridge Rd., Greenwich, Connecticut 06830 的物业；位于 66 Sherwood Avenue, Greenwich, Connecticut 06831 的物业；位于 140 Wallacks Drive, Stamford, Connecticut 06902 的物业；位于 602 Indian Field Drive, Greenwich, Connecticut 06830 的物业；以及位于 11 Hurlingham Drive, Greenwich, Connecticut 06831 的物业有关的所有文档和通信。\n\n2. 与债务人、债务人财产、债务人家属或关联实体的任何收入或资产有关的所有文档或通信，包括但不限于位于 Connecticut 的任何不动产。\n\nCase 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 426 of 1063\n\n3. 与债务人、债务人家属的任何成员和／或任何关联实体签订的任何聘用函有关的所有文档或通信，包括该等聘用函的副本。\n\n4. 与因你代理债务人、债务人家属或关联实体而向你支付任何预付费用或佣金有关的所有文档或通信，包括足以识别该预付费用或佣金的金额及其来源的文档。\n\n5. 与你从债务人、债务人家属、家属关联实体或关联实体处或代表其收取的、存放于托管账户或客户信托账户中的任何费用、付款或款项有关的所有文档或通信。\n\n6. 足以显示债务人、债务人家属或关联实体以其名义、代表其或为其利益向你作出的任何付款的金额、日期及来源的文档。\n\n7. 你与债务人、债务人家属，或代表债务人行事的任何关联个人、代理人、雇员或其他个人之间，就与债务人、债务人财产、债务人家属或关联实体有关的任何转让、投资或其他交易或商业往来所进行的所有通信。\n\n8. 与涉及债务人、债务人家属或任何关联实体的任何出售、潜在出售、取得、处分、购买、潜在购买、投资、出资、赠与、信用展期、贷款或转让有关的所有文档和通信。\n\n9. 与债务人使用属于、受债务人家属、关联实体或关联个人控制，或其全部或部分所有权由债务人家属、关联实体或关联个人持有的任何资产有关的所有文档和通信，包括但不限于位于 Connecticut 的任何不动产。\n\nCase 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 427 of 1063\n\n10. 与债务人、债务人财产、债务人家属、关联实体或关联个人有关的任何资产负债表、银行对账单、账户对账单、财务报表、账户结单、电汇指示和／或确认、资金证明、存款证、持仓证明、投资组合摘要或类似文档有关的所有文档和通信，包括但不限于足以显示向上述任何主体作出的所有转让的全部文档。\n\n附件 C-23\n\nB2540（表格 2540——规则 2004 审查传票）（12/15）Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 429 of\n\n美国破产法院\n\nConnecticut District（康涅狄格地区）\n\n关于 HO WAN KWOK（郭文贵）等人，\n\n1 Case No. 22-50073 (JAM)\n\n债务人 第 11 章\n\n（合并管理）\n\n规则 2004 审查传票\n\n致：Ginnel Associates, Inc.（Ginnel Real Estate 名下经营）\n\n（传票所指向之人的姓名）\n\n证言：兹命令你于下文规定的时间、日期和地点出席，并根据《联邦破产程序规则》第 2004 条接受审查并作证。随附授权该审查的法院命令副本。\n\n地点　日期和时间\n\nPaul Hastings LLP（普衡律师事务所）\n200 Park Avenue　[TBD]\nNew York, New York 10166\n\n审查将通过以下方式记录：法庭记录员／速记员\n\n提交：你或你的代表还必须在审查时携带下列文档、电子存储信息或物品，并必须允许对该等材料进行检查、复制、测试或取样：\n\n见随附的文档提交请求。\n\n《联邦民事诉讼规则》第 45 条的下列规定，经《联邦破产程序规则》第 9016 条适用于破产案件，现随附于后——有关履行地点的第 45(c) 条；有关对作为传票对象之人的保护的第 45(d) 条；以及有关你回应本传票的义务及未予回应的潜在后果的第 45(e) 条和第 45(g) 条。\n\n日期：March , 2023\n\n法院书记员\n\n或\n\n书记员或副书记员签名　律师签名\n\n签发或请求本传票并代理第 11 章受托人 Luc A. Despins（卢克·A·德斯平斯）的律师姓名、地址、电子邮件地址和电话号码如下：\n\nDouglas S. Skalka, Esq.（道格拉斯·S·斯卡尔卡律师）；Neubert, Pepe & Monteith, P.C.（诺伊伯特、佩佩及蒙蒂思专业公司）；195 Church Street, New Haven, Connecticut 06510；dskalka@npmlaw.com；(203) 821-2000\n\n致签发或请求本传票之人的通知\n\n如本传票命令在审判前提交文档、电子存储信息或有形物品，或者检查场所，则必须在向传票所指向之人送达之前，向各方送达通知及本传票副本。Fed. R. Civ. P. 45(a)(4)。\n\n软件版权 (c) 1996-2022 Best Case, LLC - www.bestcase.com Best Case Bankruptcy 1 本第 11 章案件中的债务人为 Ho Wan Kwok（郭文贵，亦称 Guo Wengui、Miles Guo 和 Miles Kwok，以及众多其他别名）（税务识别号码后四位：9595）、Genever Holdings LLC（税务识别号码后四位：8202）及 Genever Holdings Corporation。受托人、Genever Holdings LLC 和 Genever Holdings Corporation 的邮寄地址为 Paul Hastings LLP, 200 Park Avenue, New York, NY 10166，收件人为作为 Ho Wan Kwok 财产受托人的 Luc A. Despins（仅用于通知和通信）。\n\n送达证明\n\n（除非 Fed. R. Civ. P. 45 要求，本节不应向法院提交。）\n\n我于（日期）收到向（个人姓名及职务，如有）送达的本传票。\n\n我通过如下方式向被点名之人交付副本而送达本传票：\n\n于（日期）；或\n\n我未执行而退回本传票，原因如下：\n\n除非本传票代表 United States（美国）或其官员或代理人签发，我还已向证人支付一天出席的费用及法律允许的里程费，金额为 $ 。\n\n我的旅费为 $ ，服务费为 $ ，合计为 $ 。\n\n我在伪证罪处罚下声明，该等信息真实且正确。\n\n日期：\n\n送达人员签名\n\n印刷体姓名及职务\n\n送达人员地址\n\n有关尝试送达等事项的附加信息：\n\n《联邦民事诉讼规则》第 45(c)、(d)、(e) 和 (g) 条（Effective 12/1/13）（经《联邦破产程序规则》第 9016 条适用于破产案件）\n\n(c) 履行地点。\n\n(1) 审判、听证或证言录取。传票仅可按如下方式命令某人出席审判、听证或证言录取：\n\n(A) 在该人居住、受雇或经常亲自从事商业活动地点 100 英里范围内；或\n\n(B) 在该人居住、受雇或经常亲自从事商业活动所在州内，如果该人\n\n(i) 为当事人或当事人的高级职员；或\n\n(ii) 被命令出席审判且不会产生重大费用。\n\n(2) 其他证据开示。传票可以命令：\n\n(A) 在该人居住、受雇或经常亲自从事商业活动地点 100 英里范围内的地点提交文档、电子存储信息或物品；以及\n\n(B) 在拟检查的场所检查场所。\n\n(d) 对作为传票对象之人的保护；执行。\n\n(1) 避免不当负担或费用；制裁。负责签发和送达传票的当事人或律师必须采取合理措施，避免对作为传票对象之人施加不当负担或费用。要求履行的地区法院必须执行该义务，并对未遵守者的当事人或律师施加适当制裁，该制裁可包括损失的收入和合理的律师费。\n\n(2) 命令提交材料或允许检查。\n\n(A) 无需出席。被命令提交文档、电子存储信息或有形物品，或允许检查场所的人，无需亲自出席提交或检查地点，除非同时被命令出席证言录取、听证或审判。\n\n(B) 异议。被命令提交文档或有形物品，或允许检查的人，可以就检查、复制、测试或取样任何或全部材料、检查场所，或以所要求的一种或多种形式提交电子存储信息，向传票中指定的当事人或律师送达书面异议。异议必须在规定的履行时间或传票送达后 14 日中较早者之前送达。如提出异议，适用下列规则：\n\n(i) 在任何时候，送达方均可在通知被传唤人的情况下，向要求履行地所在地区的法院提出动议，请求作出强制提交或检查的命令。\n\n(ii) 仅可依命令所指示的方式要求实施该等行为，且该命令必须保护并非当事人或当事人高级职员的人，使其免于因履行而产生重大费用。\n(3) 撤销或修改传票。\n\n(A) 必须撤销或修改的情形。应及时提出的动议，要求履行地所在地区的法院必须撤销或修改具有下列情形的传票：\n\n(i) 未给予合理的履行时间；\n\n(ii) 要求某人在《规则》45(c)规定的地域范围以外履行；\n\n(iii) 要求披露享有特权或以其他方式受保护的事项，且不适用任何例外或豁免；或\n\n(iv) 使某人承受不当负担。\n\n(B) 允许撤销或修改的情形。为保护受传票约束或受其影响的人，要求履行地所在地区的法院可依动议撤销或修改传票，如果该传票要求：\n\n(i) 披露商业秘密或其他保密的研究、开发或商业信息；或\n\n(ii) 披露未受聘专家的意见或信息，该等意见或信息并未描述争议中的具体事件，且源自未经当事人请求而进行的专家研究。\n\n(C) 将规定条件作为替代方案。在《规则》45(d)(3)(B)所述情形下，如送达方：\n\n(i) 证明其对证言或材料具有重大需要，且如不承受不当困难即无法通过其他方式满足该需要；并且\n\n(ii) 确保被传唤人将获得合理补偿，\n\n法院可不撤销或修改传票，而命令在规定条件下出庭或提交材料。\n(e) 回应传票的义务。\n\n(1) 提交文件或电子存储信息。下列程序适用于提交文件或电子存储信息：\n\n(A) 文件。回应要求提交文件的传票的人，必须按照该等文件在正常业务过程中保存的方式提交，或者必须将其整理和标记，以对应请求中的类别。\n\n(B) 未规定电子存储信息提交形式。如传票未规定提交电子存储信息的形式，回应人必须以其通常保存的一种或多种形式，或者以一种或多种合理可用的形式提交。\n\n(C) 电子存储信息仅以一种形式提交。回应人无需以一种以上形式提交相同的电子存储信息。\n\n(D) 无法获取的电子存储信息。回应人无需就其认定因不当负担或费用而无法合理获取的来源中的电子存储信息提供证据开示。就强制证据开示动议或保护令动议而言，回应人必须证明该信息因不当负担或费用而无法合理获取。如作出该证明，法院仍可在请求方证明具有正当理由的情况下，考虑《规则》26(b)(2)(C)的限制，命令从该等来源进行证据开示。法院可为该证据开示规定条件。\n(2) 主张特权或保护。\n\n(A) 扣留的信息。以信息享有特权或作为审判准备材料受到保护为由扣留被传唤信息的人必须：(i) 明确提出该主张；并且\n\n(ii) 以一种在不披露本身享有特权或受保护信息的情况下，足以使当事人评估该主张的方式，说明被扣留文件、通信或有形物品的性质。\n\n(B) 已提交的信息。如为回应传票而提交的信息受到特权主张或作为审判准备材料受保护的主张约束，提出该主张的人可将该主张及其依据通知任何收到该信息的当事人。收到通知后，当事人必须立即返还、隔离或销毁所指明的信息及其持有的任何副本；在该主张得到解决前不得使用或披露该信息；如该当事人在收到通知前已披露该信息，必须采取合理措施予以取回；并可立即将该信息密封提交给要求履行地所在地区的法院，以裁定该主张。提交该信息的人必须在该主张得到解决前保存该信息。\n\n(g) 藐视法庭。要求履行地所在地区的法院——以及在动议被移送后，签发法院——可认定已被送达但无充分理由未遵守传票或与其有关命令的人构成藐视法庭。\n\n有关获取传票材料，见 Fed.R.Civ.P.45(a) Committee Note (2013)\n\n……\n\n文件提交请求\nI. 指示\n\n1. 除非另有说明，下列文件请求（以下简称“请求”，每一项称为“一项请求”）必须分别且具体地予以回应。除非基于善意提出异议，否则必须对每项请求作出完整答复；如提出异议，则必须按如下规定详细说明贵方异议的理由。如异议仅涉及某项请求的一部分，或其中所载的某个词、短语或条款，贵方仅须说明对该部分的异议，并回应请求的其余部分。\n\n2. 电子存储信息必须按照下列指示提交：\n\n- a. 图像。黑白图像必须为300 DPI Group IV单页TIFF文件。彩色图像必须以JPEG格式提交。文件名不得包含嵌入空格或特殊字符（包括逗号）。文件夹名称不得包含嵌入空格或特殊字符（包括逗号）。所有TIFF图像文件必须具有唯一文件名，即Bates编号。每张图像右下角必须标注连续的Bates编号。每个文件夹中的TIFF文件数量不得超过1000个文件。Excel电子表格应具有以该文件Bates编号命名的占位图像。\n- b. 图像加载文件\n\t- a. Concordance®数据文件。数据文件（.DAT）包含将加载至Concordance®数据库的所有字段化信息。.DAT文件的第一行必须为标识字段名称的标题行。.DAT文件必须使用下列Concordance®默认分隔符：逗号 ASCII字符（020）引号 þ ASCII字符（254）。日期字段应采用如下格式：mm/dd/yyyy。日期和时间字段必须为两个独立字段。如文件包括经图像化处理的电子邮件及附件，必须包含附件字段，以保留电子邮件与其附件之间的父/子关系。必须包含OCRPATH字段，以提供所提交存储介质上提取文本文件的文件路径及名称。文本文件必须以FIRSTBATES命名。不得在.DAT文件中包含文本。对于含有原生文件的文件，必须包含LINK字段，以提供原生文件的文件路径及\n\n名称。原生文件必须以FIRSTBATES命名。\n\n- b. Concordance Image® 或 Opticon交叉引用文件。图像交叉引用文件（.LOG或.OPT）将图像链接至数据库记录。该文件应为以逗号分隔的文件，每行由七个字段组成，并且数据库中的每张图像均应在交叉引用文件中有一行，格式如下：ImageID,VolumeLabel,ImageFilePath,DocumentBreak,FolderBreak,Box Break,PageCoun。\n- c. 文件文本。文本必须作为单独的文本文件提交，而非作为.DAT文件内的字段。文本文件的完整路径（OCRPATH）应包含在.DAT文件中。建议使用文件级ANSI文本文件，并按FIRSTBATES/Image Key命名。提取的文本文件必须置于单独文件夹中，且每个文件夹中的文本文件数量不得超过1,000个文件。文件夹名称中不得包含特殊字符（包括逗号）。文本文件必须按文件级别提供。\n- d. 特定文件类型的原生提交。为充分理解其内容和含义而合理需要以原生格式查看的文件类型，必须以原生格式提交。这些文件包括但不限于电子表格、类似电子表格的文件（Microsoft Excel、逗号分隔值、制表符分隔值等）、Microsoft PowerPoint或其他特殊演示文稿文件、数据库文件以及音频/视频文件。提供一张带有Bates编号的分隔页图像，注明存在原生文件，并将原生文件路径作为字段列入.dat文件。提交的原生文件应以与该文件分隔页相对应的Bates编号命名。将原生文件归入按递增方式命名的“NATIVE”目录中，与图像目录分开。\n- e. 去重。对于存在完全重复件的每一电子文件，仅提交一份副本。对于电子邮件，依据由BCC、Body、CC、From、IntMsgID、To及Attach属性生成的MD5哈希值合并重复件。对于电子邮件附件及独立电子文件，依据整个文件的MD5哈希值合并重复件。\n- f. 元数据。以符合Concordance规范的加载文件（.dat）形式，为每份文件提交提取的元数据。.DAT文件的第一行必须为标识字段名称的标题行。.DAT文件必须使用下列Concordance默认分隔符：逗号 , ASCII字符（020）引号 þ ASCII字符（254）\n\n日期字段应采用如下格式：mm/dd/yyyy。日期和时间字段必须为两个独立字段。下列为必需元数据：\nCase 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 434 of 1063\n\n字段名称　示例数据　说明\n\nFIRSTBATES　EDC0000001　原生文件文件/电子邮件的首个Bates编号\nLASTBATES　EDC0000001　原生文件文件/电子邮件的最后一个Bates编号\n**对于单页文件，应填写LASTBATES字段\nATTACHRANGE　EDC0000001\n-　父文件第一页的Bates编号至最后一个附件“子”文件最后一页的Bates编号\nEDC0000015　\nBEGATTACH　EDC0000001　附件范围的首个Bates编号\nENDATTACH　EDC0000015　附件范围的最后一个Bates编号\nCUSTODIAN　Smith, John　电子邮件：该电子邮件所在的邮箱\n原生文件：文件来源的个人或部门名称\nFROM　John Smith　电子邮件：发件人\n原生文件：文件作者\n**多个条目应使用分号分隔\nTO　Coffman, Janice; LeeW　收件人\n[mailto:LeeW@MSN.com]　**多个条目应使用分号分隔\nCC　Frank Thompson [mailto:　抄送收件人\nfrank_Thompson@cdt.com]　**多个条目应使用分号分隔\nBCC　John Cain　密送收件人\n**多个条目应使用分号分隔\nSUBJECT　Board Meeting Minutes　电子邮件：电子邮件主题行 原生文件：文件标题（如有）\nFILE_NAME　BoardMeetingMinutes.docx　原生文件：原始原生文件名称，包括扩展名\nDATE_SENT　10/12/2010　电子邮件：电子邮件发送日期\n原生文件：（空）\nTIME_SENT/　07:05 PM GMT　电子邮件：电子邮件发送时间/电子邮件标准化所使用的时区\nTIME_ZONE　\nTIME_ZONE　GMT　转换期间电子邮件被标准化所使用的时区。\nLINK　EDC0000001.msg　电子邮件或原生文件文件的超链接\n**链接文件必须按FIRSTBATES编号命名\nFILE_EXTEN　MSG　代表电子邮件或原生文件的文件类型扩展名\nAUTHOR　John Smith　电子邮件：（空）\n原生文件：文件作者\nDATE_CREATED　10/10/2010　电子邮件：（空）\n原生文件：文件创建日期\nCase 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 435 of 1063\n\nTIME_CREATED　10:25 AM　电子邮件：（空）\n\n原生文件：文档创建时间\n该数据必须为单独字段，且不得与 DATE_CREATED 字段合并\nDATE_MOD　10/12/2010　电子邮件：（空）\n原生文件：文档最后修改日期\nTIME_MOD　07:00 PM　电子邮件：（空）\n原生文件：文档最后修改时间\n该数据必须为单独字段，且不得与 DATE_MOD 字段合并\nDATE_ACCESSD　10/12/2010　电子邮件：（空）\n原生文件：文档最后访问日期\nTIME_ACCESSD　07:00 PM　电子邮件：（空）\n原生文件：文档最后访问时间\n该数据必须为单独字段，且不得与 DATE_ACCESSD 字段合并\nFILE_SIZE　5,952　原生文件文档/电子邮件的大小，单位为 KB\nPGCOUNT　1　原生文件文档/电子邮件中的页数\nPATH　电子邮件：（空）\nAgenda.doc　原生文件：存储原生文件文档的路径，包括原始文件名。\nINTFILEPATH　Personal Folders\\Deleted　电子邮件：电子邮件的原始位置，包括\nItems\\Board Meeting　原始文件名。\nMinutes.msg　原生文件：（空）\nINTMSGID　<000805c2c71b\\$75977050\\$　电子邮件：唯一消息 ID 原生文件：（空）\ncb8306d1@MSN>\nMD5HASH　d131dd02c5e6eec4693d9a0　文档的 MD5 哈希值。\n698aff95c\n2fcab58712467eab4004583e\nb8fb7f89\nOCRPATH　TEXT/001/EDC0000001.txt　提取自原生文件的文本路径\n\n3. 各项请求均独立运作并应被独立解释；除非另有说明，任何请求均不限制任何其他请求的范围。\n\n4. 所有文件应按照通常业务过程中的保存方式提供，或应予以整理并加注标签，以对应本请求中的类别。\n\n5. 本文所载每项请求均延及所有文件：(a) 由您占有、保管或控制的文件；或 (b) 由代表您行事的任何人占有、保管或控制的文件，\n案件 22-50073 文件 1592 提交于 03/24/23 登记于 03/24/23 10:57:37 第 436 页，共 1063 页\n\n包括您的律师或其他代表和顾问。各文件均应完整提供。\n\n6. 如要求您提供一份已不再由您占有、保管或控制的文件，则您的答复必须：(a) 详细描述该文件的性质及其内容；(b) 确定编制或撰写该文件的人员（以及，如适用，确定该文件被发送给的人员）；(c) 确定该文件编制或创建的日期；(d) 说明该文件是否 (i) 缺失或遗失，(ii) 已被销毁，(iii) 已自愿或非自愿地转移给他人，或 (iv) 以其他方式被处置；(e) 说明该等处置的理由，以及与该等处置有关的事实和情形；(f) 确定授权该等处置的人员；(g) 确定该等处置的日期或大致日期；(h) 说明该文件最近一次由您占有、保管或控制的时间；以及 (i) 确定目前占有、保管或控制该文件的人员（如有）。\n\n7. 如要求您提供一份已被销毁的文件，则除前述指示所要求的信息外，您的答复还必须说明：(a) 销毁该文件的理由；(b) 销毁该文件的人员身份；以及 (c) 指示销毁该文件的人员身份。\n\n8. 如您主张所请求的文件享有特权或属于律师工作成果，则您的答复必须：(a) 说明 (i) 足以支持您关于该文件享有特权之主张的文件描述，(ii) 文件标题，(iii) 文件日期，(iv) 文件作者，(v) 文件收件人，(vi) 收到或阅览该文件原件、任何草稿、副本或复制件的每一人员身份，(vii) 该文件本身或该文件所载或所提及的任何信息是否由任何其他人员占有、保管或控制，如是，则确定\n案件 22-50073 文件 1592 提交于 03/24/23 登记于 03/24/23 10:57:37 第 437 页，共 1063 页\n\n该等人员的身份，并说明该等信息如何进入其占有范围，(viii) 据以扣留该文件的特权主张，以及 (ix) 您将据以支持该等特权主张的所有情形；以及 (b) 对于根据 D. Conn. L. Civ. R. 26(e) 以特权主张为由扣留的每份文件，提供一份特权清单，其中载明本指示第 (a) 部分所要求的全部信息。对于文件请求中未就其提出特权或工作成果主张的任何部分，应完整提供响应文件。\n\n9. 如一份本应响应的文件的一部分包含受特权主张约束的信息，则仅应依照上述指示从该文件中删除或涂黑受该特权主张约束的部分，其余部分应予提供。\n\n10. 本请求具有持续性。现指示您：(a) 一旦得知先前答复不完整或不正确，应立即补充或更正任何后来得知不完整或不正确的答复；以及 (b) 提供根据以下规定要求提供的任何额外文件\n\n11. 如一份文件使用英语以外的语言，您应提供该文件。如一份文件使用英语以外的语言，且存在英文译本，您应同时提供两份文件。\n\n12. 对实体的所有提及均包括其所有关联方。\n\n13. 对个人姓名的所有提及均包括所有替代姓名、化名或昵称。\n案件 22-50073 文件 1592 提交于 03/24/23 登记于 03/24/23 10:57:37 第 438 页，共 1063 页\n\n14. 除非另有明确说明，文件请求所涵盖的期间为自 February 5, 2015 起至文件请求答复到期之日止。\nII. 解释规则\n\n15. (a) 任何单数名词的使用应解释为包括复数，反之亦然；以及 (b) 任何时态动词的使用应解释为包括该动词所有其他时态的使用。\n\n16. (a) “和”与“或”应按必要情况解释为连词或选择词，以将否则可能被解释为不属于任何请求范围内的所有答复纳入该请求范围；以及 (b) “每一”和“任何”应视为包括并涵盖“每一”及“全部”二词。\nIII. 定义\n\n经 D. Conn. Bankr. L.R. 2004-1(a) 纳入的 D. Conn. L. Civ. R. 26(c) 所规定的定义，以及 D. Conn. L. Civ. R. 26(d) 所规定的解释规则，适用于文件请求。此外，本文件请求中使用的下列术语具有下列含义：\n\n1. “您”或“您的”或“您本人”系指 Redfin Corporation（Redfin 公司），连同其所有关联方、部门、机构、工具、科室、办事处、合伙人、高级职员、董事、代理人、律师、代表、雇员和/或代表其行事的任何人。\n案件 22-50073 文件 1592 提交于 03/24/23 登记于 03/24/23 10:57:37 第 439 页，共 1063 页\n\n2. “债务人”系指 Ho Wan Kwok（郭文贵）（又名 Miles Kwok、Miles Guo、Guo Wengui、Guo Haoyun、郭文贵或任何其他化名），连同其雇员、代理人、律师、顾问或代表其行事的任何人。\n\n3. “债务人之子”系指 Qiang Guo（郭强）（又名 Mileson Kwok、郭强或任何其他化名），连同其雇员、代理人、律师、顾问或代表其行事的任何人。\n\n4. “债务人之女”系指 Mei Guo（郭美）（又名 Mei Gui、郭美或任何其他化名），连同其雇员、代理人、律师、顾问或代表其行事的任何人。\n\n5. “债务人所谓的妻子”系指 Hing Chi Ngok（岳庆芝）（又名 Hing Chi Ng、Yue Qingzhi、岳庆芝或任何其他化名），连同其雇员、代理人、律师、顾问或代表其行事的任何人。\n\n6. “债务人家属”统称债务人、债务人之子、债务人之女及债务人所谓的妻子，以及与债务人有任何其他家庭关系的人。\n\n7. “关联个人”单独及统称：(1) 持有、控制、保管或对债务人或债务人家属所拥有、控制或享有的资产拥有酌处权的所有个人；或 (2) 曾为一个或多个关联实体的雇员、董事或以其他方式与之有关联的所有个人，连同前述各方各自的雇员、代理人、律师、顾问或代表其行事的任何人。该等关联个人包括但不限于：Daniel Podhaskie（丹尼尔·波达斯基）、Karin Maistrello（卡琳·迈斯特雷洛）、Melissa Francis（梅利莎·弗朗西斯）、Anthony DiBattista（安东尼·迪巴蒂斯塔）、Han Chunguang（韩春光）（又名韩春光）、Qu Guojiao（屈国姣）（又名 Qu Guo Jiao、屈国姣）、Zhang Wei（张伟）（又名张伟）、Lihong Wei Lafrenz（魏丽红）（又名 Sara Wei、魏丽红）、Max Krasner（马克斯·克拉斯纳）、Yvette Wang（王雁平）（又名 Yanping Wang、Yan Ping Wang、王雁平）、Fiona Yu（菲奥娜·于）及 Je Kin Ming（余建明）（又名 William Je、Yu Jianming、余建明）。\n案件 22-50073 文件 1592 提交于 03/24/23 登记于 03/24/23 10:57:37 第 440 页，共 1063 页\n\n8. “关联实体”单独及统称：(1) 曾由债务人或债务人家属拥有、控制或投资的所有任何类型的组织或实体；或 (2) 对债务人或债务人家属所拥有、控制或享有的任何资产直接或间接拥有权益的所有任何类型的组织或实体，连同前述各方各自的雇员、代理人、律师、顾问或代表其行事的任何人。该等关联实体包括但不限于：7 Nod Hill LLC（7 Nod Hill 有限责任公司）、ACA Investment Management Limited（ACA 投资管理有限公司）、ACA Capital Group Limited（ACA 资本集团有限公司）、Ace Decade Holdings Limited（Ace Decade 控股有限公司）、AI Group Holdings Inc.（AI 集团控股公司）、Booming Sail New York LLC（Booming Sail New York 有限责任公司）、Bravo Luck Limited（Bravo Luck 有限公司）、China Golden Spring (Hong Kong) Limited（China Golden Spring〔Hong Kong〕有限公司）、Crane Advisory Group LLC（Crane Advisory Group 有限责任公司）、Dawn State Limited（Dawn State 有限公司）、Eastern Profit Corporation Limited（Eastern Profit Corporation 有限公司）、Freedom Media Ventures Ltd.（Freedom Media Ventures 有限公司）、G Club Operations LLC（G Club Operations 有限责任公司）、G Fashion LLC（G Fashion 有限责任公司）、G News LLC（G News 有限责任公司）、GETTR USA（GETTR 美国）、Genever Holdings Corporation（Genever Holdings 公司）、Genever Holdings LLC（Genever Holdings 有限责任公司）、Gfashion Media Group Inc.（Gfashion Media Group 公司）、GFNY, Inc.（GFNY 公司）、Golden Spring (New York) Ltd.（Golden Spring〔New York〕有限公司）、Greenwich Land LLC（Greenwich Land 有限责任公司）、GTV Media Group, Inc.（GTV Media Group 公司）、Hamilton Capital Holdings Inc.（Hamilton Capital Holdings 公司）、HCHK Property Management, Inc.（HCHK Property Management 公司）、HCHK Technologies, Inc.（HCHK Technologies 公司）、Himalaya Embassy（Himalaya Embassy）、Himalaya Exchange（Himalaya Exchange）、Himalaya Federal Reserve（Himalaya Federal Reserve）、Himalaya Investment LLC（Himalaya Investment 有限责任公司）、Himalaya International（Himalaya International）、Himalaya New World Inc.（Himalaya New World 公司）、Himalaya Supervisory Organization（Himalaya Supervisory Organization）、Himalaya Ventures LLC（Himalaya Ventures 有限责任公司）、HK International Funds Investments (USA) Limited LLC（HK International Funds Investments〔USA〕Limited 有限责任公司）、Hong Kong International Funds Investments Limited（Hong Kong International Funds Investments 有限公司）、Hudson Diamond Holding（Hudson Diamond Holding）、Infinity Treasury Management Inc.（Infinity Treasury Management 公司）、Lexington Property and Staffing（Lexington Property and Staffing）、Long Gate Limited（Long Gate 有限公司）、Maywind Trading LLC（Maywind Trading 有限责任公司）、MOS Himalaya LLC（MOS Himalaya 有限责任公司）、New Federal State of China（中国新联邦国）（又名 NFSC）、Rule of Law Foundation III, Inc.（Rule of Law Foundation III 公司）、Rule of Law Foundation IV, Inc.（Rule of Law Foundation IV 公司）、Rule of Law Fund（Rule of Law Fund）、Rule of Law Society（Rule of Law Society）、Rule of Law Society IV, Inc.（Rule of Law Society IV 公司）、G-Translators PTY LTD（G-Translators PTY LTD）、Saraca Media Group, Inc.（Saraca Media Group 公司）、Well Origin Ltd.（Well Origin 有限公司）、Whitecroft Shore Limited（Whitecroft Shore 有限公司）及 ZIBA Limited（ZIBA 有限公司）。\n\n9. “包括”或其任何变体系指“包括但不限于”。\n案件 22-50073 文件 1592 提交于 03/24/23 登记于 03/24/23 10:57:37 第 441 页，共 1063 页\n\n10. “和”与“或”系指“和/或”，并应同时按连词和选择词解释，以最大限度扩大其范围。\n\n11. “任何”、“全部”及“每一”系指“每一及全部”。\n\n12. “每一”及“每个”系指“每一及全部”。\n\n13. “第三方”系指您本人以外的个人或实体。\n\n14. “转让”具有《破产法》第 101(54) 条赋予该词的含义。\n\n15. “文件”是指属于 Fed. R. Civ. P. 34 范围内的任何信息或物品，包括但不限于：目前或曾经由您占有、保管或控制的每一项及全部任何种类、类型、性质或描述的书面、记录或图示材料，包括电子邮件、以电子形式保存的计算机文件、通信函件、备忘录、磁带、速记或手写笔记、任何种类的书面表格、图表、蓝图、绘图、草图、曲线图、计划、文章、规格说明书、日记、信函、电报、照片、会议记录、合同、协议、调查、计算机打印件、任何种类的数据汇编、电传、传真、电子邮件、短信、即时消息、语音留言、发票、订单表格、支票、汇票、对账单、贷项通知单、报告、立场报告、摘要、索引、书籍、分类账、笔记本、日程表、透明胶片、录音、目录、广告、宣传材料、影片、录像带、录音带、CD、计算机磁盘、宣传册、小册子、穿孔卡、工时单、推文、社交媒体帖子或任何其他种类的书面或记录材料的所有印刷及电子副本，以及无论以何种方式存储（无论为有形或电子形式）、记录、制作或复制的其全部元数据；还包括但不限于前述任何材料的草稿或副本，如其中含有原始文件中不存在的任何种类的笔记、评论或标记，或在其他方面与原始文件不完全相同。\n\n案号 22-50073 文书 1592 提交日期 03/24/23 登记日期 03/24/23 10:57:37 第 442 页，共 1063 页\n\n16. “人员”是指个人、公司、独资企业、合伙企业、协会或任何其他实体。“人员”还包括任何代理人、代表或专家，包括但不限于律师或财务顾问。\n\n17. “实体”是指任何自然人、公司、合伙企业、子公司、独资企业、商号、董事会、合资企业、协会、机构、主管机关、委员会或其他商业实体或法人，以及任何关联方、代理人、母公司，包括但不限于法律顾问、财务顾问或任何其他代表。\n\n18. “关于”是指涉及、描述、构成、提及、与之有关、支持、赞成、反对、加强、削弱、位于、结合考虑、对其有影响、证明、表明、报告、记录、暗指、回应、与之相连、评论、就其而言、有关、与之相关、讨论、显示、描述、反映、分析、构成及属于。\n\n19. 当提及任何特定主题事项时，“与……有关”、“涉及”或“相关”是指，包括但不限于，构成、包含、涉及、含有、体现、反映、识别、陈述、直接或间接提及该特定主题事项，或以任何方式与所识别的特定主题事项有关的任何文件。\n\n20. “通信”系以最广泛的可能含义，且不受限制地，指任何信息或知识的传递（以事实、观点、询问或其他形式）。通信还指所有谈话、协议、询问或答复，无论是当面、通过电话、以书面形式，还是借助电子传输设备，并包括但不限于所有通信函件、电子邮件、录音、传送单、备忘录、电话\n\n案号 22-50073 文书 1592 提交日期 03/24/23 登记日期 03/24/23 10:57:37 第 443 页，共 1063 页\n\n通信、语音留言、电报、传真、影印传真、电传、即时消息、聊天、短信、发布至留言板或群聊的帖子、社交媒体帖子、推文、上传至任何视频平台的视频、电话笔记，或在内部或与第三方之间传递的笔记。\n\n21. “资产”是指可由人占有、保管或控制的任何具有经济价值的项目。资产包括全部不动产和动产，包括但不限于房地产、土地、房屋、公寓、共管公寓、汽车、游艇、船舶、飞机、喷气式飞机、直升机、现金、银行账户、加密货币、证券、应收账款、库存及其他有形和无形财产。\n\nIV. 应提交的文件\n\n1. 与位于 781 Fifth Avenue, New York, NY 10022 的 Sherry Netherland Hotel / Condominium（雪梨荷兰酒店／共管公寓）（公寓 1801 和 1519）；位于 373 Taconic Rd., Greenwich, Connecticut 06831 的住宅物业；位于 33 Ferncliff Rd., Cos Cob, Connecticut 06807 的住宅物业；位于 354 Nod Hill Rd., Wilton, Connecticut 06897 的住宅物业；位于 32 Chateau Ridge Rd., Greenwich, Connecticut 06831 的物业；位于 110 Clapboard Ridge Rd., Greenwich, Connecticut 06830 的物业；位于 66 Sherwood Avenue, Greenwich, Connecticut 06831 的物业；位于 140 Wallacks Drive, Stamford, Connecticut 06902 的物业；位于 602 Indian Field Drive, Greenwich, Connecticut 06830 的物业；以及位于 11 Hurlingham Drive, Greenwich, Connecticut 06831 的物业有关的全部文件和通信。\n\n2. 与债务人、债务人破产财产、债务人家庭成员或关联实体的任何收入或资产有关的全部文件或通信，包括但不限于位于 Connecticut 的任何不动产。\n\n案号 22-50073 文书 1592 提交日期 03/24/23 登记日期 03/24/23 10:57:37 第 444 页，共 1063 页\n\n3. 与债务人、债务人任何家庭成员和／或任何关联实体订立的任何聘任函有关的全部文件或通信，包括该等聘任函的副本。\n\n4. 与基于您对债务人、债务人家庭成员或关联实体的代理而向您支付任何预付聘用费或佣金有关的全部文件或通信，包括足以识别该预付聘用费或佣金的金额及其来源的文件。\n\n5. 与您从债务人、债务人家庭成员、家庭关联实体或关联实体处或代表其收取，并存放于托管账户或客户信托账户中的任何费用、付款或款项有关的全部文件或通信。\n\n6. 足以显示债务人、债务人家庭成员或关联实体向您支付、代表其向您支付或为其利益向您支付的任何款项之金额、日期和来源的文件。\n\n7. 您与债务人、债务人家庭成员，或代表债务人行事的任何关联个人、代理人、雇员或其他个人之间，就与债务人、债务人破产财产、债务人家庭成员或关联实体有关的任何转让、投资或其他交易或商业往来所进行的全部通信。\n\n8. 与涉及债务人、债务人家庭成员或任何关联实体的任何出售、潜在出售、取得、处分、购买、潜在购买、投资、出资、赠与、信用延期、贷款或转让有关的全部文件和通信。\n\n9. 与债务人使用属于、由债务人家庭成员控制，或由债务人家庭成员、\n\n案号 22-50073 文书 1592 提交日期 03/24/23 登记日期 03/24/23 10:57:37 第 445 页，共 1063 页\n\n关联实体或关联个人完全或部分拥有的任何资产有关的全部文件和通信，包括但不限于位于 Connecticut 的任何不动产。\n\n10. 与债务人、债务人破产财产、债务人家庭成员、关联实体或关联个人有关的任何资产负债表、银行对账单、账户对账单、财务报表、账户结单、电汇指示和／或确认、资金证明、存款证、持有证明、投资组合摘要或类似文件有关的全部文件和通信，包括但不限于足以显示向前述任何一方进行的所有转让的全部文件。\n\n附件 C-24\n\nB2540（表格 2540——Rule 2004 审查传票）（12/15）案号 22-50073 文书 1592 提交日期 03/24/23 登记日期 03/24/23 10:57:37 第 447 页，共\n\n美国破产法院（United States Bankruptcy Court）\n\nConnecticut 区（District of Connecticut）\n\n关于 HO WAN KWOK（郭文贵）等人，\n\n1 案号 22-50073 (JAM) 债务人 第 11 章\n\n（合并管理）\n\nRULE 2004 审查传票\n\n致：Sotheby's International Realty Affiliates LLC（苏富比国际房地产加盟有限责任公司）\n\n（传票所指向人员的姓名）\n\n证言：兹命令您于下列载明的时间、日期和地点出席，并根据《联邦破产程序规则》Rule 2004 规定接受审查并作证。随附准许该审查的法院命令副本。\n\n地点　日期和时间\n\nPaul Hastings LLP（博浩律师事务所）\n200 Park Avenue　[待定]\nNew York, New York 10166\n\n审查将通过以下方式记录：法庭记录员／速记员\n\n提交：您或您的代表还必须在审查时携带下列文件、电子存储信息或物品，并必须允许对该等材料进行检查、复制、测试或抽样：\n\n见随附的文件提交请求。\n\n下列 Fed. R. Civ. P. 45 条款，经 Fed. R. Bankr. P. 9016 规定适用于破产案件，随附于本传票之后——关于履行地点的 Rule 45(c)；关于作为传票对象的人员所受保护的 Rule 45(d)；以及关于您回应本传票的义务及未予回应的潜在后果的 Rule 45(e) 和 45(g)。\n\n日期：March , 2023\n\n法院书记员\n\n或\n\n书记员或副书记员签名　律师签名\n\n签发或请求本传票、代表第 11 章受托人 Luc A. Despins（Luc A. Despins）的律师姓名、地址、电子邮件地址和电话号码如下：\n\nDouglas S. Skalka, Esq.（Douglas S. Skalka 律师）；Neubert, Pepe & Monteith, P.C.（Neubert, Pepe & Monteith, P.C.）；195 Church Street, New Haven, Connecticut 06510；dskalka@npmlaw.com；(203) 821-2000\n\n致签发或请求本传票者的通知\n\n如本传票命令在审判前提交文件、电子存储信息或有形物品，或检查场所，则必须在向传票所指向人员送达之前，向每一方当事人送达通知及本传票副本。Fed. R. Civ. P. 45(a)(4)。\n\n软件版权 (c) 1996-2022 Best Case, LLC（Best Case, LLC）- www.bestcase.com Best Case Bankruptcy 1 本第 11 章案件中的债务人为 Ho Wan Kwok（郭文贵）（又名 Guo Wengui、Miles Guo 和 Miles Kwok，以及众多其他别名）（税务识别号码后四位：9595）、Genever Holdings LLC（税务识别号码后四位：8202）及 Genever Holdings Corporation。受托人、Genever Holdings LLC 和 Genever Holdings Corporation 的邮寄地址为 Paul Hastings LLP, 200 Park Avenue, New York, NY 10166，转交 Ho Wan Kwok 破产财产受托人 Luc A. Despins（仅为通知和通信之目的）。\n\n送达证明\n\n（除非 Fed. R. Civ. P. 45 要求，否则本节不应向法院提交。）\n\n本人于（日期）收到为（个人姓名及职务，如有）签发的本传票。\n\n本人已按如下方式向所列名人员交付副本以送达本传票：\n\n于（日期）送达；或\n\n本人未执行而退回本传票，原因为：\n\n除非本传票系代表 United States（美国）或其官员或代理人签发，本人还已向证人支付一天出席费用及法律允许的里程费，金额为 \\$ 。\n\n本人的差旅费用为 \\$ ，服务费用为 \\$ ，合计 \\$ 。\n\n本人在伪证处罚的约束下声明，本信息真实且正确。\n\n日期：\n\n送达人签名\n\n正楷姓名及职务\n\n送达人地址\n\n有关尝试送达等事项的补充信息：\n\n《联邦民事诉讼规则》45(c)、(d)、(e) 和 (g)（生效日期 12/1/13）（经《联邦破产程序规则》Rule 9016 规定适用于破产案件）\n\n(c) 履行地点。\n\n(1) 审判、听证或证言录取。传票仅可按如下规定命令某人出席审判、听证或证言录取：\n\n（A）在该人居住、受雇或经常亲自办理业务地点的 100 英里范围内；或\n\n（B）在该人居住、受雇或经常亲自办理业务所在的州内，如该人\n\n（i）为当事人或当事人的高级职员；或\n\n（ii）被命令出席审判且不会产生重大费用。\n\n（2）为其他证据开示。传票可命令：\n\n（A）在该人居住、受雇或经常亲自办理业务地点的 100 英里范围内某一地点提交文件、电子存储信息或物品；以及\n\n（B）在拟检查的不动产处检查该不动产。\n\n（d）保护受传票约束之人；执行。\n\n（1）避免不当负担或费用；制裁。负责签发和送达传票的当事人或律师必须采取合理措施，避免对受传票约束之人施加不当负担或费用。要求履行传票的地区所属法院必须执行此项义务，并对未遵守者的当事人或律师施加适当制裁，该制裁可包括损失的收入和合理的律师费。\n\n（2）命令提交材料或允许检查。\n\n（A）无需出席。被命令提交文件、电子存储信息或有形物品，或允许检查不动产之人，无需亲自到提交或检查地点出席，除非同时被命令出席证言录取、听证或审判。\n\n（B）异议。被命令提交文件或有形物品，或允许检查之人，可向传票指定的当事人或律师送达书面异议，反对检查、复制、测试或抽样任何或全部材料，或反对检查不动产，或反对以所要求的一种或多种形式提交电子存储信息。异议必须在规定履行时间届满前或传票送达后 14 日内（以较早者为准）送达。如提出异议，适用下列规则：\n\n（i）送达方当事人可随时在通知被命令之人后，向要求履行传票的地区所属法院提出动议，请求作出强制提交或检查的命令。\n\n（ii）仅可依命令所指示的方式要求实施该等行为，且该命令必须保护既非当事人亦非当事人高级职员之人，使其免于因履行而产生重大费用。\n\n（3）撤销或修改传票。\n\n（A）必须撤销或修改的情形。经及时提出动议，要求履行传票的地区所属法院必须撤销或修改符合下列情形的传票：\n\n（i）未留出合理的履行时间；\n\n（ii）要求某人在《规则》45(c)规定的地域限制以外履行；\n\n（iii）要求披露享有特权或受其他保护的事项，而不存在适用的例外或放弃；或\n\n（iv）使某人承受不当负担。\n\n（B）可以撤销或修改的情形。为保护受传票约束或受其影响之人，要求履行传票的地区所属法院可依动议撤销或修改要求下列事项的传票：\n\n（i）披露商业秘密或其他保密研究、开发或商业信息；或\n\n（ii）披露未受聘专家的意见或信息，该等意见或信息并非描述争议中的具体事件，且系该专家进行的、未由当事人请求的研究所得。\n\n（C）规定条件作为替代措施。在《规则》45(d)(3)(B)所述情形下，如送达方当事人：\n\n（i）证明其对该证言或材料具有重大需要，且如不承受不当困难即无法通过其他方式满足该需要；并且\n\n（ii）确保受传票传唤之人将获得合理补偿，\n\n法院可不撤销或修改传票，而命令在规定条件下出席或提交。\n\n（e）回应传票的义务。\n\n（1）提交文件或电子存储信息。下列程序适用于提交文件或电子存储信息：\n\n（A）文件。回应要求提交文件之传票的人必须按照其在通常业务过程中保存的方式提交文件，或者必须对其进行整理和标记，以对应请求中的类别。\n\n（B）未规定电子存储信息的提交形式。如传票未规定电子存储信息的提交形式，回应之人必须以其通常保存的一种或多种形式，或以合理可用的一种或多种形式提交。\n\n（C）电子存储信息仅以一种形式提交。回应之人无需以一种以上形式提交相同的电子存储信息。\n\n（D）无法合理取得的电子存储信息。回应之人无需就其认定因不当负担或费用而无法合理取得来源中的电子存储信息提供证据开示。在请求强制证据开示或请求保护令的动议中，回应之人必须证明该信息因不当负担或费用而无法合理取得。如作出该证明，法院在考虑《规则》26(b)(2)(C)的限制后，如请求方当事人证明有正当理由，仍可命令从该等来源进行证据开示。法院可规定证据开示的条件。\n\n（2）主张特权或保护。\n\n（A）扣留的信息。以信息享有特权或作为审判准备材料受到保护为由扣留受传票要求的信息之人，必须：（i）明确提出该主张；并且\n\n（ii）以一种在不披露本身享有特权或受保护信息的情况下，足以使当事人评估该主张的方式，说明被扣留文件、通信或有形物品的性质。\n\n（B）已提交的信息。如为回应传票而提交的信息受特权主张或作为审判准备材料受保护主张的约束，提出该主张之人可通知任何收到该信息的当事人该主张及其依据。收到通知后，当事人必须立即返还、隔离或销毁所指定的信息及其持有的任何副本；在该主张获得解决前不得使用或披露该信息；如该当事人在收到通知前已披露该信息，必须采取合理措施取回该信息；并可立即将该信息密封提交给要求履行传票的地区所属法院，以裁定该主张。提交该信息之人必须保全该信息，直至该主张获得解决。\n\n（g）藐视法庭。要求履行传票的地区所属法院，以及在动议移送后签发传票的法院，均可认定已被送达但无充分理由不遵从传票或相关命令之人构成藐视法庭。\n\n查阅传票材料，见 Fed.R.Civ.P.45(a) Committee Note (2013)\n\n……\n\n文件提交请求\nI. 指示\n\n1. 除非另有说明，下列文件请求（统称“请求”，单项称“一项请求”）必须分别且具体地予以回应。除非善意提出异议，否则必须完整答复每项请求；如提出异议，必须按下文所述详细说明贵方异议的理由。如异议仅涉及一项请求的一部分，或其中包含的一个词语、短语或条款，贵方仅须说明对该部分的异议，并回应请求的其余部分。\n\n2. 电子存储信息必须按照下列指示提交：\n\na. 图像。黑白图像必须为 300 DPI Group IV 单页 TIFF 文件。彩色图像必须以 JPEG 格式提交。文件名不得包含嵌入空格或特殊字符（包括逗号）。文件夹名称不得包含嵌入空格或特殊字符（包括逗号）。所有 TIFF 图像文件必须具有唯一文件名，即 Bates 编号。每幅图像右下角必须加盖连续的 Bates 编号。每个文件夹中的 TIFF 文件数量不得超过 1000 个文件。Excel 电子表格应包含一幅占位图像，该图像以该文件的 Bates 编号命名。\n\nb. 图像加载文件\n\na. Concordance® 数据文件。数据文件（.DAT）包含将加载至 Concordance® 数据库的全部字段信息。.DAT 文件第一行必须为识别字段名称的标题行。.DAT 文件必须使用下列 Concordance® 默认分隔符：逗号 ASCII 字符（020）引号 þ ASCII 字符（254）。日期字段应以 mm/dd/yyyy 格式提供。日期和时间字段必须为两个独立字段。如文件包括已成像的电子邮件及附件，必须包括附件字段，以保留电子邮件与其附件之间的父子关系。必须包括 OCRPATH 字段，以提供所提交存储介质上提取文本文件的文件路径和名称。文本文件必须以 FIRSTBATES 命名。不得在 .DAT 文件中包含文本。对于含有原生文件的文件，必须包括 LINK 字段，以提供原生文件的文件路径和名称。原生文件必须以 FIRSTBATES 命名。\n\nb. Concordance Image® 或 Opticon 交叉引用文件。图像交叉引用文件（.LOG 或 .OPT）将图像链接至数据库记录。该文件应为以逗号分隔的文件，每行由七个字段组成，数据库中每幅图像均应在交叉引用文件中有一行，格式如下：ImageID,VolumeLabel,ImageFilePath,DocumentBreak,FolderBreak,Box Break,PageCoun。\n\nc. 文件文本。文本必须作为单独的文本文件提交，不得作为 .DAT 文件中的字段。文本文件的完整路径（OCRPATH）应包含在 .DAT 文件中。建议提供按 FIRSTBATES/Image Key 命名的文件级 ANSI 文本文件。提取的文本文件必须置于单独文件夹中，每个文件夹中的文本文件数量不得超过 1,000 个文件。文件夹名称中不得有特殊字符（包括逗号）。必须按文件级别提供文本文件。\n\nd. 特定文件类型的原生提交。为充分理解其内容和含义而合理需要以原生格式查看的文件类型，必须以原生格式提交。此类文件包括但不限于电子表格、类似电子表格的文件（Microsoft Excel、逗号分隔值、制表符分隔值等）、Microsoft PowerPoint 或其他特殊演示文件、数据库文件及音频/视频文件。应提供一幅带有 Bates 编号的插页图像，表明存在原生文件，并在 .dat 文件中将原生文件路径作为字段包含在内。提交的原生文件应以与该文件插页相对应的 Bates 编号命名。原生文件应归入按递增方式命名的“NATIVE”目录中，并与图像目录分开。\n\ne. 去重。对于存在完全重复件的每份电子文件，仅提交一份副本。对于电子邮件，依据由 BCC、Body、CC、From、IntMsgID、To 和 Attach 属性生成的 MD5 哈希值合并重复件。对于电子邮件附件和独立电子文件，依据整个文件的 MD5 哈希值合并重复件。\n\nf. 元数据。以符合 Concordance 要求的加载文件（.dat）形式，提交每份文件的提取元数据。.DAT 文件第一行必须为识别字段名称的标题行。.DAT 文件必须使用下列 Concordance 默认分隔符：逗号 , ASCII 字符（020）引号 þ ASCII 字符（254）\n\n日期字段应以 mm/dd/yyyy 格式提供。日期和时间字段必须为两个独立字段。以下列出必需的元数据：\n\nCase 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 452 of 1063\n\n字段名称　示例数据　说明\nENGLISH>>>\n\nFIRSTBATES　EDC0000001　原生文件文档/电子邮件的首个 Bates 编号\nLASTBATES　EDC0000001　原生文件文档/电子邮件的最后一个 Bates 编号\nLASTBATES 字段应予填写\n对于单页文件\nATTACHRANGE　EDC0000001\n-　母文档首页的 Bates 编号\nEDC0000015　至最后一个附件“子”文档最后一页的 Bates 编号\nBEGATTACH　EDC0000001　附件范围的首个 Bates 编号\nENDATTACH　EDC0000015　附件范围的最后一个 Bates 编号\nCUSTODIAN　Smith, John（约翰·史密斯）　电子邮件：该电子邮件所在的邮箱\n原生文件：文件来源个人或部门的名称\nFROM　John Smith（约翰·史密斯）　电子邮件：发件人\n原生文件：文件作者\n多个条目应使用分号分隔\nTO　Coffman, Janice（珍妮丝·科夫曼）；LeeW　收件人\n[mailto:LeeW@MSN.com]　多个条目应使用分号分隔\nCC　Frank Thompson（弗兰克·汤普森）[mailto:　抄送收件人\nfrank_Thompson@cdt.com]　多个条目应使用分号分隔\nBCC　John Cain（约翰·凯恩）　密送收件人\n多个条目应使用分号分隔\nSUBJECT　Board Meeting Minutes　电子邮件：电子邮件主题行；原生文件：文档标题（如有）\nFILE_NAME　BoardMeetingMinutes.docx　原生文件：原始原生文件的名称，包括扩展名\nDATE_SENT　10/12/2010　电子邮件：电子邮件发送日期\n原生文件：（空）\nTIME_SENT/　07:05 PM GMT　电子邮件：电子邮件发送时间/电子邮件标准化所采用时区的时间\nTIME_ZONE　电子邮件在转换过程中被标准化所采用的时区。\nTIME_ZONE　GMT　电子邮件在转换过程中被标准化所采用的时区。\nLINK　EDC0000001.msg　电子邮件或原生文件文档的超链接\n链接文件必须按照 FIRSTBATES 编号命名\nFILE_EXTEN　MSG　表示电子邮件或原生文件的文件类型扩展名\nAUTHOR　John Smith（约翰·史密斯）　电子邮件：（空）\n原生文件：文档作者\nDATE_CREATED　10/10/2010　电子邮件：（空）\n原生文件：文档创建日期\nCase 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 453 of 1063\n\nTIME_CREATED　10:25 AM　电子邮件：（空）\n\n原生文件：文档创建时间\n该数据必须为单独字段，不得与 DATE_CREATED 字段合并\nDATE_MOD　10/12/2010　电子邮件：（空）\n原生文件：文档最后修改日期\nTIME_MOD　07:00 PM　电子邮件：（空）\n原生文件：文档最后修改时间\n该数据必须为单独字段，不得与 DATE_MOD 字段合并\nDATE_ACCESSD　10/12/2010　电子邮件：（空）\n原生文件：文档最后访问日期\nTIME_ACCESSD　07:00 PM　电子邮件：（空）\n原生文件：文档最后访问时间\n该数据必须为单独字段，不得与 DATE_ACCESSD 字段合并\nFILE_SIZE　5,952　原生文件文档/电子邮件的大小（KB）\nPGCOUNT　1　原生文件文档/电子邮件的页数\nPATH　电子邮件：（空）\nAgenda.doc　原生文件：存储原生文件文档的路径，包括原始文件名。\nINTFILEPATH　Personal Folders\\Deleted　电子邮件：电子邮件的原始位置，包括\nItems\\Board Meeting　原始文件名。\nMinutes.msg　原生文件：（空）\nINTMSGID　<000805c2c71b\\$75977050\\$　电子邮件：唯一邮件 ID；原生文件：（空）\ncb8306d1@MSN>\nMD5HASH　d131dd02c5e6eec4693d9a0　文档的 MD5 哈希值。\n698aff95c\n2fcab58712467eab4004583e\nb8fb7f89\nOCRPATH　TEXT/001/EDC0000001.txt　提取自原生文件的文本路径\n\n3. 每项请求均独立适用并应独立解释，除非另有说明，任何一项请求均不限制任何其他请求的范围。\n\n4. 所有文件应按其在日常业务过程中保存的方式提供，或应予整理并标注，以对应本请求中的类别。\n\n5. 本文所载每项请求均延及所有文件：(a) 由您占有、保管或控制的文件；或 (b) 由代表您行事的任何人占有、保管或控制的文件，\nCase 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 454 of 1063\n\n包括您的律师或其他代表及顾问。每份文件均应完整提供。\n\n6. 如要求您提供的文件已不再由您占有、保管或控制，则您的答复必须：(a) 详细描述该文件的性质及其内容；(b) 确认编制或撰写该文件的人员（以及，如适用，文件发送对象）；(c) 确认该文件编制或创建的日期；(d) 说明该文件是否：(i) 遗失或丢失，(ii) 已被销毁，(iii) 已自愿或非自愿转交他人，或 (iv) 以其他方式被处置；(e) 说明该处置的理由以及相关事实和情形；(f) 确认授权该处置的人员；(g) 确认该处置的日期或约略日期；(h) 说明该文件最近一次由您占有、保管或控制的时间；以及 (i) 确认现时占有、保管或控制该文件的人员（如有）。\n\n7. 如要求您提供的文件已被销毁，则除前述指示要求的信息外，您的答复还必须说明：(a) 销毁该文件的理由；(b) 销毁该文件的人员身份；以及 (c) 指示销毁该文件的人员身份。\n\n8. 如您主张被请求文件享有特权或律师工作成果保护，则您的答复必须：(a) 说明：(i) 足以支持您关于该文件享有特权之主张的文件描述，(ii) 文件标题，(iii) 文件日期，(iv) 文件作者，(v) 文件收件人，(vi) 收到或看过原件或任何草稿、副本或复制件的每名人员身份，(vii) 该文件本身或文件所载或提及的任何信息是否由任何其他人员占有、保管或控制；如是，则应确认该等人员身份，并说明该等信息如何进入其占有范围，(viii) 据以扣留该文件的特权主张，以及 (ix) 您将据以支持该特权主张的所有情形；以及 (b) 依照 D. Conn. L. Civ. R. 26(e)，就每份基于特权主张而扣留的文件，提供一份特权日志，其中包含本指示第 (a) 部分所要求的全部信息。对于文件请求中未提出特权或工作成果主张的任何部分，应完整提供回应性文件。\n\n9. 如一份原本具有回应性的文件中有一部分包含受特权主张保护的信息，则仅应按照上述指示，从该文件中删除或遮盖受特权主张保护的该部分，其余部分应予提供。\n\n10. 本请求具有持续性。特此指示您：(a) 一旦得知先前答复不完整或不正确，立即补充或更正任何后来发现不完整或不正确的答复；以及 (b) 提供根据下列规定所要求的任何补充文件\n\n11. 如文件使用英语以外的语言，您应提供该文件。如文件使用英语以外的语言且存在英文译本，您应同时提供两份文件。\n\n12. 对实体的一切提及均包括其所有关联方。\n\n13. 对个人姓名的一切提及均包括所有替代姓名、别名或昵称。\nCase 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 456 of 1063\n\n14. 除非另有明确说明，文件请求涵盖的期间为自 February 5, 2015 起至文件请求答复到期之日止。\nII. 解释规则\n\n15. (a) 对任何单数名词的使用应解释为包括复数，反之亦然；以及 (b) 对任何时态动词的使用应解释为包括该动词的所有其他时态。\n\n16. (a) “and”和“or”应按必要情形解释为连词或析取词，以使本应被解释为超出任何请求范围的所有答复均纳入该请求范围；以及 (b) “each”和“any”应视为包括并涵盖“every”和“all”二词。\nIII. 定义\n\n经 D. Conn. Bankr. L.R. 2004-1(a) 纳入的 D. Conn. L. Civ. R. 26(c) 所规定的定义，以及 D. Conn. L. Civ. R. 26(d) 所规定的解释规则，适用于文件请求。此外，本文件请求中所使用的下列术语具有下列含义：\n\n1. “您”或“您的”或“您本人”是指 Sotheby's International Realty Affiliates LLC（苏富比国际房地产附属机构有限责任公司），连同其所有关联方、部门、机构、分支、工具机构、处室、办公室、合伙人、高级职员、董事、代理人、律师、代表、雇员，及/或任何代表其行事的人。\nCase 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 457 of 1063\n\n2. “债务人”是指 Ho Wan Kwok（郭文贵）（又名 Miles Kwok、Miles Guo、Guo Wengui、Guo Haoyun、郭文贵，或任何其他别名），连同其雇员、代理人、律师、顾问或任何代表其行事的人。\n\n3. “债务人之子”是指 Qiang Guo（郭强）（又名 Mileson Kwok、郭强，或任何其他别名），连同其雇员、代理人、律师、顾问或任何代表其行事的人。\n\n4. “债务人之女”是指 Mei Guo（郭美）（又名 Mei Gui、郭美，或任何其他别名），连同其雇员、代理人、律师、顾问或任何代表其行事的人。\n\n5. “债务人所谓妻子”是指 Hing Chi Ngok（岳庆芝）（又名 Hing Chi Ng、Yue Qingzhi、岳庆芝，或任何其他别名），连同其雇员、代理人、律师、顾问或任何代表其行事的人。\n\n6. “债务人家属”是指债务人、债务人之子、债务人之女及债务人所谓妻子的统称，以及与债务人有任何其他亲属关系的人。\n\n7. “关联个人”单独及统称指所有下列个人：(1) 持有、控制、保管或对债务人或债务人家属拥有、控制或享有的资产拥有自由裁量权；或 (2) 曾为一项或多项关联实体的雇员、董事，或以其他方式与其有关联；并包括前述任何人的各自雇员、代理人、律师、顾问或任何代表其行事的人。该等关联个人包括但不限于：Daniel Podhaskie（丹尼尔·波达斯基）、Karin Maistrello（卡琳·迈斯特雷洛）、Melissa Francis（梅利莎·弗朗西斯）、Anthony DiBattista（安东尼·迪巴蒂斯塔）、Han Chunguang（韩春光）（又名 韩春光）、Qu Guojiao（屈国姣）（又名 Qu Guo Jiao、屈国姣）、Zhang Wei（张伟）（又名 张伟*）、Lihong Wei Lafrenz（魏丽红）（又名 Sara Wei、魏丽红）、Max Krasner（马克斯·克拉斯纳）、Yvette Wang（王雁平）（又名 Yanping Wang、Yan Ping Wang、王雁平）、Fiona Yu（菲奥娜·余）以及 Je Kin Ming（余建明）（又名 William Je、Yu Jianming、余建明）。\nCase 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 458 of 1063\n\n8. “关联实体”系指，单独及共同而言，所有符合下列情形的任何类型组织或实体：(1) 曾由债务人或债务人家庭成员拥有、控制或投资；或 (2) 对债务人或债务人家庭成员拥有、控制或享有的任何资产直接或间接享有权益，连同前述各方各自的雇员、代理人、法律顾问、顾问或代表前述任何一方行事的任何人。该等关联实体包括但不限于：7 Nod Hill LLC（七诺德山有限责任公司）、ACA Investment Management Limited（ACA投资管理有限公司）、ACA Capital Group Limited（ACA资本集团有限公司）、Ace Decade Holdings Limited（王牌十年控股有限公司）、AI Group Holdings Inc.（AI集团控股公司）、Booming Sail New York LLC（纽约繁荣帆船有限责任公司）、Bravo Luck Limited（好运有限公司）、China Golden Spring (Hong Kong) Limited（中国金泉〈香港〉有限公司）、Crane Advisory Group LLC（鹤顾问集团有限责任公司）、Dawn State Limited（黎明州有限公司）、Eastern Profit Corporation Limited（东方利润有限公司）、Freedom Media Ventures Ltd.（自由媒体风险投资有限公司）、G Club Operations LLC（G俱乐部运营有限责任公司）、G Fashion LLC（G时尚有限责任公司）、G News LLC（G新闻有限责任公司）、GETTR USA（GETTR美国）、Genever Holdings Corporation（Genever控股公司）、Genever Holdings LLC（Genever控股有限责任公司）、Gfashion Media Group Inc.（G时尚媒体集团公司）、GFNY, Inc.（GFNY公司）、Golden Spring (New York) Ltd.（金泉〈纽约〉有限公司）、Greenwich Land LLC（格林尼治土地有限责任公司）、GTV Media Group, Inc.（GTV媒体集团公司）、Hamilton Capital Holdings Inc.（汉密尔顿资本控股公司）、HCHK Property Management, Inc.（HCHK物业管理公司）、HCHK Technologies, Inc.（HCHK技术公司）、Himalaya Embassy（喜马拉雅大使馆）、Himalaya Exchange（喜马拉雅交易所）、Himalaya Federal Reserve（喜马拉雅联邦储备）、Himalaya Investment LLC（喜马拉雅投资有限责任公司）、Himalaya International（喜马拉雅国际）、Himalaya New World Inc.（喜马拉雅新世界公司）、Himalaya Supervisory Organization（喜马拉雅监督组织）、Himalaya Ventures LLC（喜马拉雅风险投资有限责任公司）、HK International Funds Investments (USA) Limited LLC（香港国际基金投资〈美国〉有限责任公司）、Hong Kong International Funds Investments Limited（香港国际基金投资有限公司）、Hudson Diamond Holding（哈德逊钻石控股）、Infinity Treasury Management Inc.（无限资金管理公司）、Lexington Property and Staffing（列克星敦物业及人力配备）、Long Gate Limited（长龙门有限公司）、Maywind Trading LLC（五月风贸易有限责任公司）、MOS Himalaya LLC（MOS喜马拉雅有限责任公司）、New Federal State of China（中国新联邦国，亦称 NFSC）、Rule of Law Foundation III, Inc.（法治基金会III公司）、Rule of Law Foundation IV, Inc.（法治基金会IV公司）、Rule of Law Fund（法治基金）、Rule of Law Society（法治协会）、Rule of Law Society IV, Inc.（法治协会IV公司）、G-Translators PTY LTD（G-翻译员有限公司）、Saraca Media Group, Inc.（萨拉卡媒体集团公司）、Well Origin Ltd.（良好起源有限公司）、Whitecroft Shore Limited（怀特克罗夫特海岸有限公司）以及 ZIBA Limited（ZIBA有限公司）。\n\n9. “包括”或其任何变体，系指“包括但不限于”。\n\nCase 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 459 of 1063\n\n10. “和”及“或”系指“和/或”，并应同时按连词及选择连词解释，以最大限度扩大其范围。\n\n11. “任何”和“所有”及“每一”系指“每一个及所有”。\n\n12. “每一”及“每个”系指“每一个及所有”。\n\n13. “第三方”系指除您本人以外的个人或实体。\n\n14. “转让”应具有《破产法典》第 101(54) 条赋予该词的含义。\n\n15. “文件”系指属于 Fed. R. Civ. P. 34 范围内的任何信息或物品，包括但不限于，现由或曾由您占有、保管或控制的各种、各类、任何性质或描述的每一份书面、录制或图形材料，包括电子邮件的所有印刷及电子副本、以电子形式保存的计算机文件、通信函件、备忘录、磁带、速记或手写笔记、任何种类的书面表格、图表、蓝图、绘图、草图、曲线图、计划、文章、规格说明、日记、信件、电报、照片、会议记录、合同、协议、调查、计算机打印输出、任何种类的数据汇编、电传、电传传真、电子邮件、短信、即时消息、语音留言、发票、订单、支票、汇票、对账单、贷项通知单、报告、持仓报告、摘要、索引、书籍、分类账、笔记本、附表、透明胶片、录音、目录、广告、宣传材料、影片、录像带、录音带、CD、计算机磁盘、小册子、宣传册、穿孔卡、工时单、推文、社交媒体帖子或任何其他种类的书面或录制材料，以及其所有元数据，无论以何种方式存储（无论以有形或电子形式）、记录、制作或复制，并且还包括但不限于，前述任何文件的草稿或副本，其中包含原始文件中不存在的任何种类笔记、评论或标记，或在其他方面与原始文件不相同的草稿或副本。\n\nCase 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 460 of 1063\n\n16. “个人”系指个人、公司、独资企业、合伙企业、协会或任何其他实体。“个人”亦包括任何代理人、代表或专家，包括但不限于律师或财务顾问。\n\n17. “实体”系指任何自然人、公司、合伙企业、子公司、独资企业、商号、董事会、合资企业、协会、机构、机关、委员会或其他商业实体或法人，以及任何关联方、代理人、母公司，包括但不限于法律顾问、财务顾问或任何其他代表。\n\n18. “关于”系指涉及、描述、包含、提及、与之有关、支持、有利于、反对、加强、削弱、位于、结合考虑、影响、证明、表明、报告、记录、暗指、答复、与之相连、评论、就其而言、有关、与之相关、讨论、显示、描述、反映、分析、构成及属于。\n\n19. 当提及任何特定主题事项时，“与……有关”、“与……相关”或“相关于”系指，包括但不限于，构成、包含、涉及、载有、体现、反映、识别、陈述、直接或间接提及，或以任何方式与所识别的特定主题事项有关的任何文件。\n\n20. “通信”系指，以最广义且不受限制的方式，任何信息或知识的传递（以事实、观点、询问或其他形式）。通信还指所有面谈、协议、询问或答复，无论是当面、通过电话、书面方式或通过电子传输设备，并且包括但不限于所有通信函件、电子邮件、录音、传送单、备忘录、电话通信、语音留言、电报、传真、电传副本、电传、即时消息、聊天、短信、在留言板或群聊中的帖子、社交媒体帖子、推文、上传至任何视频平台的视频、电话笔记，或内部传送或与第三方传送的笔记。\n\nCase 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 461 of 1063\n\n21. “资产”系指受占有、保管或控制的任何具有经济价值的项目。资产包括所有不动产和动产，包括但不限于房地产、土地、房屋、公寓、共管公寓、汽车、游艇、船只、飞机、喷气机、直升机、现金、银行账户、加密货币、证券、应收账款、存货及其他有形和无形财产。\n\nIV. 应提交的文件\n\n1. 与位于 781 Fifth Avenue, New York, NY 10022 的 Sherry Netherland Hotel / Condominium（雪莉荷兰酒店／共管公寓）（公寓 1801 和 1519）；位于 373 Taconic Rd., Greenwich, Connecticut 06831 的住宅物业；位于 33 Ferncliff Rd., Cos Cob, Connecticut 06807 的住宅物业；位于 354 Nod Hill Rd., Wilton, Connecticut 06897 的住宅物业；位于 32 Chateau Ridge Rd., Greenwich, Connecticut 06831 的物业；位于 110 Clapboard Ridge Rd., Greenwich, Connecticut 06830 的物业；位于 66 Sherwood Avenue, Greenwich, Connecticut 06831 的物业；位于 140 Wallacks Drive, Stamford, Connecticut 06902 的物业；位于 602 Indian Field Drive, Greenwich, Connecticut 06830 的物业；以及位于 11 Hurlingham Drive, Greenwich, Connecticut 06831 的物业有关的所有文件及通信。\n\n2. 与债务人、债务人财产、债务人家庭成员或关联实体的任何收入或资产有关的所有文件或通信，包括但不限于位于 Connecticut（康涅狄格州）的任何不动产。\n\nCase 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 462 of 1063\n\n3. 与债务人、债务人家庭成员的任何成员和/或任何关联实体订立的任何委托函有关的所有文件或通信，包括该等委托函的副本。\n\n4. 与基于您代表债务人、债务人家庭成员或关联实体而向您支付的任何预付聘用费或佣金有关的所有文件或通信，包括足以识别该预付聘用费或佣金的金额及其来源的文件。\n\n5. 与您从债务人、债务人家庭成员、家庭关联实体或关联实体处，或代表其收取的，并存放于托管账户或客户信托账户中的任何费用、付款或款项有关的所有文件或通信。\n\n6. 足以显示债务人、债务人家庭成员或关联实体为您、代表您或为您的利益向您作出的任何付款的金额、日期及来源的文件。\n\n7. 您与债务人、债务人家庭成员或任何关联个人、代理人、雇员或代表债务人行事的其他个人之间，就与债务人、债务人财产、债务人家庭成员或关联实体有关的任何转让、投资或其他交易或商业往来所进行的所有通信。\n\n8. 与涉及债务人、债务人家庭成员或任何关联实体的任何出售、潜在出售、取得、处置、购买、潜在购买、投资、出资、赠与、信贷展期、贷款或转让有关的所有文件及通信。\n\n9. 与债务人使用属于、由其控制或其完整或部分所有权由债务人家庭成员、关联实体或关联个人持有的任何资产有关的所有文件及通信，包括但不限于位于 Connecticut（康涅狄格州）的任何不动产。\n\nCase 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 463 of 1063\n\n10. 与债务人、债务人财产、债务人家庭成员、关联实体或关联个人有关的任何资产负债表、银行对账单、账户对账单、财务报表、账户报表、电汇指示和/或确认、资金证明、存款证、持有证明、投资组合摘要或类似文件有关的所有文件及通信，包括但不限于足以显示向前述任何一方进行的所有转让的所有文件。\n\nCase 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 464 of 1063\n\n附件 C-25\n\nB2540（表格 2540——Rule 2004 审查传票）（12/15）Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 465 of\n\nUNITED STATES BANKRUPTCY COURT（美国破产法院）\n\nDistrict of Connecticut（康涅狄格地区）\n\n关于 HO WAN KWOK（郭文贵）等人的事项，\n\n1 Case No. 22-50073 (JAM)\n\n债务人 Chapter 11\n\n（合并管理）\n\nRULE 2004 审查传票\n\n致：NRT New England LLC（以 Coldwell Banker Residential Brokerage 之名经营）\n\n（传票送达对象姓名）\n\n证言：兹命令您于下列载明的时间、日期和地点出席，并依《联邦破产程序规则》Rule 2004 接受审查并作证。随附准许该项审查的法院命令副本。\n\n地点　日期和时间\n\nPaul Hastings LLP（博钦律师事务所）\n200 Park Avenue　[TBD]\nNew York, New York 10166\n\n审查将以下列方式记录：法庭记录员/速记员\n\n提交：您或您的代表还必须在审查时携带下列文件、电子存储信息或物品，并必须准许对该等材料进行检查、复制、测试或取样：\n\n见随附的文件提交请求。\n\n下列 Fed. R. Civ. P. 45 的规定，依据 Fed. R. Bankr. P. 9016 适用于破产案件，现随附于此——有关履行地点的 Rule 45(c)；有关作为传票对象的您所受保护的 Rule 45(d)；以及有关您对本传票的答复义务及不答复的潜在后果的 Rule 45(e) 和 45(g)。\n\n日期：March , 2023\n\n法院书记官\n\n或\n\n书记官或副书记官签名　律师签名\n\n代表发出或请求本传票的第11章受托人 Luc A. Despins（卢克·A·德斯平斯）的律师的姓名、地址、电子邮件地址和电话号码如下：\n\nDouglas S. Skalka, Esq.（道格拉斯·S·斯卡尔卡，律师）；Neubert, Pepe & Monteith, P.C.（纽伯特、佩佩及蒙蒂思专业公司）；195 Church Street, New Haven, Connecticut 06510；dskalka@npmlaw.com；(203) 821-2000\n\n致发出或请求本传票的人之通知\n\n如果本传票命令在审判前提交文件、以电子方式存储的信息或有形物品，或检查场所，则必须在向本传票所指向的人送达之前，向各方送达通知及本传票副本。Fed. R. Civ. P. 45(a)(4)。\n\n软件版权 (c) 1996-2022 Best Case, LLC（百斯特凯斯有限责任公司）- www.bestcase.com Best Case Bankruptcy（百斯特凯斯破产软件）1 本第11章案件中的债务人为 Ho Wan Kwok（郭文贵）（亦称 Guo Wengui（郭文贵）、Miles Guo（郭文贵）及 Miles Kwok（郭文贵），以及众多其他别名）（税务识别号后四位：9595）、Genever Holdings LLC（吉尼弗控股有限责任公司）（税务识别号后四位：8202）及 Genever Holdings Corporation（吉尼弗控股公司）。受托人、Genever Holdings LLC 及 Genever Holdings Corporation 的邮寄地址为 Paul Hastings LLP（普衡律师事务所），200 Park Avenue, New York, NY 10166，转交 Luc A. Despins，作为 Ho Wan Kwok 遗产的受托人（仅为通知和通信之目的）。\n\n送达证明\n\n（除非 Fed. R. Civ. P. 45 要求，否则本节不应向法院提交。）\n\n我于（日期）收到向（个人姓名及职务，如有）发出的本传票。\n\n我按以下方式向被指定人交付副本以送达本传票：\n\n于（日期）；或\n\n我未执行传票即予退回，原因是：\n\n除非传票代表美国或其官员或代理人发出，否则我还已向证人支付一天出席费及法律允许的里程费，金额为 $ 。\n\n我的差旅费为 $ ，服务费为 $ ，合计为 $ 。\n\n我在伪证罪处罚下声明，该等信息真实且准确。\n\n日期：\n\n送达人签名\n\n正楷姓名及职务\n\n送达人地址\n\n关于尝试送达等的补充信息：\n\n《联邦民事诉讼规则》第45条(c)、(d)、(e)和(g)项（自12/1/13起生效）（根据《联邦破产程序规则》第9016条适用于破产案件）\n\n(c) 履行地点。\n\n(1) 审判、听证或证言录取。传票仅可按以下方式命令某人出席审判、听证或证言录取：\n\n(A) 在该人居住、受雇或经常亲自开展业务所在地100英里范围内；或\n\n(B) 在该人居住、受雇或经常亲自开展业务所在州内，如果该人\n\n(i) 是一方当事人或一方当事人的高级职员；或\n\n(ii) 被命令出席审判，且不会产生巨额费用。\n\n(2) 其他证据开示。传票可以命令：\n\n(A) 在该人居住、受雇或经常亲自开展业务所在地100英里范围内的地点提交文件、以电子方式存储的信息或物品；以及\n\n(B) 在拟检查的场所对该场所进行检查。\n\n(d) 对受传票约束者的保护；执行。\n\n(1) 避免不当负担或费用；制裁。负责发出和送达传票的一方当事人或律师必须采取合理措施，避免对受传票约束的人施加不当负担或费用。要求履行的地区法院必须执行该义务，并对未遵守该义务的一方当事人或律师施加适当制裁，其中可包括损失的收入和合理的律师费。\n\n(2) 命令提交材料或允许检查。\n\n(A) 无须出庭。被命令提交文件、以电子方式存储的信息或有形物品，或允许检查场所的人，无须亲自到提交或检查地点出庭，除非其还被命令出席证言录取、听证或审判。\n\n(B) 异议。被命令提交文件或有形物品，或允许检查的人，可以向传票中指定的一方当事人或律师送达书面异议，反对检查、复制、测试或抽样任何或全部材料，或者反对检查场所，或者反对以所要求的一种或多种形式提交以电子方式存储的信息。异议必须在规定履行时间或传票送达后14日（以较早者为准）之前送达。如提出异议，则适用下列规则：\n\n(i) 在任何时候，经通知被命令人后，送达方可以向要求履行的地区法院提出动议，请求作出强制提交或检查的命令。\n\n(ii) 仅可依照命令所指示的方式要求实施这些行为，且该命令必须保护既非当事人亦非当事人高级职员的人免受因履行而产生的重大费用。\n\n(3) 撤销或修改传票。\n\n(A) 必须撤销或修改的情形。经及时动议，要求履行的地区法院必须撤销或修改有下列情形的传票：\n\n(i) 未给予合理的履行时间；\n\n(ii) 要求某人在第45条(c)项规定的地理范围以外履行；\n\n(iii) 要求披露享有特权或受其他保护的事项，且不存在适用的例外或豁免；或\n\n(iv) 对某人施加不当负担。\n\n(B) 可以撤销或修改的情形。为保护受传票约束或受其影响的人，若传票要求：\n\n(i) 披露商业秘密或其他保密的研究、开发或商业信息；或\n\n(ii) 披露非受聘专家的意见或信息，且该意见或信息并未描述争议中的具体事件，并源于该专家未经任何一方当事人请求所进行的研究，\n\n要求履行的地区法院可以依动议撤销或修改传票。\n\n(C) 作为替代方案规定条件。在第45条(d)(3)(B)项所述情形下，如送达方：\n\n(i) 证明对证言或材料具有重大需要，且不遭受不当困难即无法通过其他方式满足该需要；并且\n\n(ii) 确保被传唤人将获得合理补偿，\n\n法院可以不撤销或修改传票，而是命令在指定条件下出庭或提交材料。\n\n(e) 回应传票时的义务。\n\n(1) 提交文件或以电子方式存储的信息。下列程序适用于提交文件或以电子方式存储的信息：\n\n(A) 文件。响应提交文件传票的人必须按照文件在正常业务过程中保存的方式提交，或者必须将其整理并标记为与请求中的类别相对应。\n\n(B) 未规定提交以电子方式存储的信息的形式。如果传票未规定提交以电子方式存储的信息的形式，响应人必须以其通常保存的一种或多种形式，或者以合理可使用的一种或多种形式提交。\n\n(C) 以电子方式存储的信息仅须以一种形式提交。响应人无须以一种以上形式提交相同的以电子方式存储的信息。\n\n(D) 无法合理获取的以电子方式存储的信息。响应人无须就其认定因不当负担或费用而无法合理获取的来源中的以电子方式存储的信息提供证据开示。就强制证据开示的动议或保护令动议，响应人必须证明该信息因不当负担或费用而无法合理获取。如作出该证明，若请求方在考虑第26条(b)(2)(C)项的限制后证明存在正当理由，法院仍可命令从该等来源进行证据开示。法院可以为该证据开示规定条件。\n\n(2) 主张特权或保护。\n\n(A) 被扣留的信息。根据其享有特权或作为审判准备材料受到保护的主张而扣留被传唤信息的人必须：(i) 明确提出该主张；并且\n\n(ii) 以不披露本身享有特权或受保护的信息、但足以使各方当事人评估该主张的方式，说明被扣留文件、通信或有形物品的性质。\n\n(B) 已提交的信息。如为响应传票而提交的信息受到特权主张或作为审判准备材料受到保护的主张约束，提出主张的人可以通知收到该信息的任何一方当事人该主张及其依据。收到通知后，一方当事人必须立即返还、隔离或销毁所指定的信息及其持有的任何副本；在该主张得到解决之前，不得使用或披露该信息；如该方在收到通知前已披露该信息，必须采取合理措施予以取回；并可立即将该信息密封提交给要求履行的地区法院，以裁定该主张。提交信息的人必须保存该信息，直至该主张得到解决。\n\n(g) 藐视法庭。要求履行的地区法院——以及在动议被移送后，发出传票的法院——可以以藐视法庭论处已被送达但无充分理由不遵守传票或与之相关命令的人。\n\n有关查阅传票材料，请参见 Fed.R.Civ.P.45(a) Committee Note (2013)\n\n……\n\n文件提交请求\n\n一、指示\n\n1. 除非另有说明，下列文件请求（以下简称“请求”，每一项称为“一项请求”）必须分别且具体地作出答复。每一项请求均应得到完整答复，除非贵方善意提出异议；在此情况下，贵方异议的理由应按下文规定详细说明。如异议仅涉及某项请求的一部分，或其中包含的某个词语、短语或条款，贵方仅须说明对该部分的异议，并对其余请求作出答复。\n\n2. 以电子方式存储的信息必须按照下列指示提交：\n\na. 图像。黑白图像必须为300 DPI Group IV单页 TIFF 文件。彩色图像必须以 JPEG 格式提交。文件名不得含有嵌入空格或特殊字符（包括逗号）。文件夹名称不得含有嵌入空格或特殊字符（包括逗号）。所有 TIFF 图像文件必须具有唯一文件名，即 Bates 编号。每张图像的右下角必须标注连续的 Bates 编号。每个文件夹中的 TIFF 文件数量不应超过1000个文件。Excel 电子表格应具有以该文件 Bates 编号命名的占位图像。\n\nb. 图像加载文件\n\na. Concordance® 数据文件。数据文件（.DAT）包含将加载至 Concordance® 数据库的所有字段信息。.DAT 文件的第一行必须为标识字段名称的标题行。.DAT 文件必须使用以下 Concordance® 默认分隔符：逗号 ASCII 字符（020）引号 ASCII 字符（254）。日期字段应以 mm/dd/yyyy 格式提供。日期和时间字段必须为两个单独字段。如文件包括已成像的电子邮件及附件，则必须包括附件字段，以保留电子邮件与其附件之间的父/子关系。必须包括 OCRPATH 字段，以提供已提取文本文件在所提交存储介质上的文件路径和名称。文本文件必须以 FIRSTBATES 命名。不得在 .DAT 文件中包含文本。对于具有原生文件的文件，必须包括 LINK 字段，以提供原生文件的文件路径和名称。原生文件必须以 FIRSTBATES 命名。\n\n- b. Concordance Image® 或 Opticon 交叉引用文件。图像交叉引用文件（.LOG 或 .OPT）将图像与数据库记录链接起来。该文件应为逗号分隔文件，每行由七个字段组成，并且数据库中的每张图像均应在交叉引用文件中有一行，格式如下：ImageID,VolumeLabel,ImageFilePath,DocumentBreak,FolderBreak,Box Break,PageCount。\n\n- c. 文档文本。文本必须作为单独的文本文件提供，而非作为 .DAT 文件中的字段。文本文件的完整路径（OCRPATH）应载入 .DAT 文件。建议提供以 FIRSTBATES/Image Key 命名的文档级 ANSI 文本文件。提取的文本文件必须存放在单独的文件夹中，且每个文件夹中的文本文件数量不得超过 1,000 个。文件夹名称中不得含有特殊字符（包括逗号）。文本文件必须按文档级别提供。\n\n- d. 特定文件类型的原生格式提供。为充分理解其内容和含义而合理需要以原生格式查看的文件类型，必须以原生格式提供。此类文件包括但不限于：电子表格、类电子表格文件（Microsoft Excel、逗号分隔值、制表符分隔值等）、Microsoft PowerPoint 或其他特殊演示文稿文件、数据库文件以及音频/视频文件。应提供一张带有 Bates 编号的分隔页图像，注明原生文件的存在，并将原生文件路径作为 .dat 文件中的一个字段载入。所提供的原生文件应以与该文件分隔页对应的 Bates 编号命名。原生文件应归入按递增方式命名的“NATIVE”目录，并与图像目录分开存放。\n\n- e. 去重。对于存在完全重复件的每份电子文档，仅提供一份副本。对于电子邮件，应依据由 BCC、Body、CC、From、IntMsgID、To 和 Attach 属性生成的 MD5 哈希值合并重复件。对于电子邮件附件和独立电子文件，应依据整个文件的 MD5 哈希值合并重复件。\n\n- f. 元数据。应以符合 Concordance 要求的载入文件（.dat）形式，为每份文档提供提取的元数据。.DAT 文件的第一行必须为标识字段名称的标题行。.DAT 文件必须使用以下 Concordance 默认分隔符：逗号 , ASCII 字符（020）引号 þ ASCII 字符（254）\n\n日期字段应采用以下格式提供：mm/dd/yyyy。日期和时间字段必须为两个独立字段。下列为必需的元数据：\nCase 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 470 of 1063\n\n字段名称　示例数据　说明\n\nFIRSTBATES　EDC0000001　原生文件文档/电子邮件的第一个 Bates 编号\nLASTBATES　EDC0000001　原生文件文档/电子邮件的最后一个 Bates 编号\nLASTBATES 字段应针对单页予以填充\nATTACHRANGE　EDC0000001\n-　父文档首页的 Bates 编号至最后一个\nEDC0000015　附件“子”文档最后一页的 Bates 编号\nBEGATTACH　EDC0000001　附件范围的第一个 Bates 编号\nENDATTACH　EDC0000015　附件范围的最后一个 Bates 编号\nCUSTODIAN　Smith, John　电子邮件：该电子邮件所在的邮箱\n原生文件：文档来源文件所属个人或部门的名称\nFROM　John Smith　电子邮件：发件人\n原生文件：文档作者\n应使用分号分隔多个条目\nTO　Coffman, Janice; LeeW　收件人\n[mailto:LeeW@MSN.com]　应使用分号分隔多个条目\nCC　Frank Thompson [mailto:　抄送收件人\nfrank_Thompson@cdt.com]　应使用分号分隔多个条目\nBCC　John Cain　密送收件人\n应使用分号分隔多个条目\nSUBJECT　Board Meeting Minutes　电子邮件：电子邮件主题行 原生文件：文档标题\n（如有）\nFILE_NAME　BoardMeetingMinutes.docx　原生文件：原始原生文件名称，\n包括扩展名\nDATE_SENT　10/12/2010　电子邮件：电子邮件发送日期\n原生文件：（空）\nTIME_SENT/　07:05 PM GMT　电子邮件：电子邮件发送时间/电子邮件被标准化\nTIME_ZONE　所采用的时区\nTIME_ZONE　GMT　在转换过程中电子邮件被标准化所采用的时区。\nLINK　EDC0000001.msg　指向电子邮件或原生文件文档的超链接\n所链接的文件必须按 FIRSTBATES 编号命名\nFILE_EXTEN　MSG　表示电子邮件或原生文件的文件类型扩展名\nAUTHOR　John Smith　电子邮件：（空）\n原生文件：文档作者\nDATE_CREATED　10/10/2010　电子邮件：（空）\n原生文件：文档创建日期\nCase 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 471 of 1063\n\nTIME_CREATED　10:25 AM　电子邮件：（空）\n\n原生文件：文档创建时间\n该数据必须为单独字段，且不得与 DATE_CREATED 字段合并\nDATE_MOD　10/12/2010　电子邮件：（空）\n原生文件：文档最后修改日期\nTIME_MOD　07:00 PM　电子邮件：（空）\n原生文件：文档最后修改时间\n该数据必须为单独字段，且不得与 DATE_MOD 字段合并\nDATE_ACCESSD　10/12/2010　电子邮件：（空）\n原生文件：文档最后访问日期\nTIME_ACCESSD　07:00 PM　电子邮件：（空）\n原生文件：文档最后访问时间\n该数据必须为单独字段，且不得与 DATE_ACCESSD 字段合并\nFILE_SIZE　5,952　原生文件文档/电子邮件的大小，以 KB 计\nPGCOUNT　1　原生文件文档/电子邮件的页数\nPATH　电子邮件：（空）\nAgenda.doc　原生文件：存储原生文件文档的路径，\n包括原始文件名称。\nINTFILEPATH　Personal Folders\\Deleted　电子邮件：电子邮件的原始位置，包括\nItems\\Board Meeting　原始文件名称。\nMinutes.msg　原生文件：（空）\nINTMSGID　<000805c2c71b\\$75977050\\$　电子邮件：唯一消息 ID 原生文件：（空）\ncb8306d1@MSN>\nMD5HASH　d131dd02c5e6eec4693d9a0　文档的 MD5 哈希值。\n698aff95c\n2fcab58712467eab4004583e\nb8fb7f89\nOCRPATH　TEXT/001/EDC0000001.txt　原生文件提取文本的路径\n\n3. 每项请求均独立运行并应独立解释，除非另有说明，任何请求均不限制任何其他请求的范围。\n\n4. 所有文档应按其在正常业务过程中保存的方式提供，或者应予以组织和标注，以对应本请求中的类别。\n\n5. 本文件所载每项请求均延及所有文档：（a）由贵方占有、保管或控制的；或（b）由任何代表贵方行事之人占有、保管或控制的，\nCase 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 472 of 1063\n\n包括贵方律师或其他代表和顾问。每份文档均应完整提供。\n\n6. 如要求贵方提供一份已不再由贵方占有、保管或控制的文档，则贵方的答复必须：（a）详细说明该文档的性质及其内容；（b）确定编制或撰写该文档的人员（以及，如适用，确定该文档被发送给的人员）；（c）确定该文档编制或创建的日期；（d）说明该文档是否（i）缺失或遗失，（ii）已被销毁，（iii）已自愿或非自愿转交他人，或（iv）以其他方式被处置；（e）说明该等处置的理由以及围绕该等处置的事实和情形；（f）确定授权该等处置的人员；（g）确定该等处置的日期或大致日期；（h）说明该文档最近一次由贵方占有、保管或控制的时间；以及（i）确定目前占有、保管或控制该文档的人员（如有）。\n\n7. 如要求贵方提供一份已被销毁的文档，则除前述指示所要求的信息外，贵方的答复还必须说明：（a）该文档被销毁的理由；（b）销毁该文档的人员身份；以及（c）指示销毁该文档的人员身份。\n\n8. 如贵方主张所请求的文档受特权或律师工作成果保护，则贵方的答复必须：（a）说明（i）足以支持贵方关于该文档受特权保护之主张的文档描述，（ii）该文档的标题，（iii）该文档的日期，（iv）该文档的作者，（v）该文档的收件人，（vi）收到或阅览该文档原件或任何草稿、副本或复制件的每一人员身份，（vii）该文档本身或该文档所含或所提及的任何信息是否由任何其他人员占有、保管或控制，如是，则确定\nCase 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 473 of 1063\n\n该等人员身份，并说明该信息如何进入其占有范围，（viii）据以扣留该文档的特权主张，以及（ix）贵方将据以支持该等特权主张的所有情形；并且（b）依照 D. Conn. L. Civ. R. 26(e)，就基于特权主张而被扣留的每份文档，制作一份特权日志，其中载明本指示第（a）部分所要求的全部信息。对于未提出特权或工作成果主张的任何文档请求部分，应完整提供回应性文档。\n\n9. 如一份本应回应请求的文档的一部分含有受特权主张约束的信息，则仅应依照上述指示从该文档中删除或遮蔽受特权主张约束的该部分，其余部分应予提供。\n\n10. 本请求具有持续性。现指示贵方：（a）一旦知悉先前答复不完整或不正确，应立即补充或更正后来发现不完整或不正确的任何答复；以及（b）提供根据该项所要求的任何其他文档\n\n11. 如一份文档使用英语以外的语言，贵方应提供该文档。如一份文档使用英语以外的语言，且存在英文译本，贵方应同时提供两份文档。\n\n12. 对实体的所有提及均包括其所有关联方。\n\n13. 对个人姓名的所有提及均包括所有替代姓名、别名或昵称。\nCase 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 474 of 1063\n\n14. 除非另有明确说明，文档请求涵盖的期间为自 February 5, 2015 起至文档请求答复到期之日止。\nII. 解释规则\n\n15. （a）任何单数名词的使用应解释为包括复数，反之亦然；（b）任何时态的动词使用应解释为该动词所有其他时态的使用。\n\n16. （a）“and”和“or”应视需要解释为连词或析取词，以将原本可能被解释为不属于任何请求范围的所有答复纳入该请求范围；以及（b）“each”和“any”应视为包括并涵盖“every”和“all”二词。\nIII. 定义\n\n经 D. Conn. Bankr. L.R. 2004-1(a) 纳入的 D. Conn. L. Civ. R. 26(c) 所提供的定义，以及 D. Conn. L. Civ. R. 26(d) 所提供的解释规则，适用于文档请求。此外，本文件档请求中使用的下列术语具有以下含义：\n\n1. “贵方”或“贵方的”或“贵方自身”是指并包括 NRT New England LLC（新英格兰有限责任公司），连同其所有关联方、部门、机构、工具机构、处室、办事机构、合伙人、高级职员、董事、代理人、律师、代表、雇员和/或任何代表其行事之人。\nCase 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 475 of 1063\n\n2. “债务人”是指 Ho Wan Kwok（郭文贵）（又名 Miles Kwok、Miles Guo、Guo Wengui、Guo Haoyun、郭文贵，或任何其他别名），连同其雇员、代理人、律师、顾问或任何代表其行事之人。\n\n3. “债务人之子”系指 Qiang Guo（郭强，亦称 Mileson Kwok，或任何其他化名），以及其雇员、代理人、律师、顾问或任何代表其行事之人。\n\n4. “债务人之女”系指 Mei Guo（郭美，亦称 Mei Gui，或任何其他化名），以及其雇员、代理人、律师、顾问或任何代表其行事之人。\n\n5. “债务人之所谓妻子”系指 Hing Chi Ngok（岳庆芝，亦称 Hing Chi Ng、Yue Qingzhi，或任何其他化名），以及其雇员、代理人、律师、顾问或任何代表其行事之人。\n\n6. “债务人家属”统称债务人、债务人之子、债务人之女及债务人之所谓妻子，以及与债务人存在任何其他亲属关系之人。\n\n7. “关联个人”单独及统称所有下列个人：(1) 持有、控制、保管或对债务人或债务人家属拥有、控制或享有的资产具有酌处权者；或 (2) 曾任一个或多个关联实体的雇员、董事，或以其他方式与其有关联者，以及前述任何人员各自的雇员、代理人、律师、顾问或任何代表其行事之人。此类关联个人包括但不限于：Daniel Podhaskie、Karin Maistrello、Melissa Francis、Anthony DiBattista、Han Chunguang（韩春光）、Qu Guojiao（屈国姣，亦称 Qu Guo Jiao）、Zhang Wei（张伟*）、Lihong Wei Lafrenz（魏丽红，亦称 Sara Wei）、Max Krasner、Yvette Wang（王雁平，亦称 Yanping Wang、Yan Ping Wang）、Fiona Yu，以及 Je Kin Ming（余建明，亦称 William Je、Yu Jianming）。\n案件 22-50073，文件 1592，提交日期 03/24/23，录入日期 03/24/23 10:57:37，第 476 页，共 1063 页\n\n8. “关联实体”单独及统称任何类型的所有组织或实体：(1) 曾由债务人或债务人家属拥有、控制或投资；或 (2) 直接或间接对债务人或债务人家属拥有、控制或享有的任何资产享有权益，以及前述任何实体各自的雇员、代理人、律师、顾问或任何代表其行事之人。此类关联实体包括但不限于：7 Nod Hill LLC、ACA Investment Management Limited、ACA Capital Group Limited、Ace Decade Holdings Limited、AI Group Holdings Inc.、Booming Sail New York LLC、Bravo Luck Limited、China Golden Spring (Hong Kong) Limited、Crane Advisory Group LLC、Dawn State Limited、Eastern Profit Corporation Limited、Freedom Media Ventures Ltd.、G Club Operations LLC、G Fashion LLC、G News LLC、GETTR USA、Genever Holdings Corporation、Genever Holdings LLC、Gfashion Media Group Inc.、GFNY, Inc.、Golden Spring (New York) Ltd.、Greenwich Land LLC、GTV Media Group, Inc.、Hamilton Capital Holdings Inc.、HCHK Property Management, Inc.、HCHK Technologies, Inc.、Himalaya Embassy、Himalaya Exchange、Himalaya Federal Reserve、Himalaya Investment LLC、Himalaya International、Himalaya New World Inc.、Himalaya Supervisory Organization、Himalaya Ventures LLC、HK International Funds Investments (USA) Limited LLC、Hong Kong International Funds Investments Limited、Hudson Diamond Holding、Infinity Treasury Management Inc.、Lexington Property and Staffing、Long Gate Limited、Maywind Trading LLC、MOS Himalaya LLC、New Federal State of China（亦称 NFSC）、Rule of Law Foundation III, Inc.、Rule of Law Foundation IV, Inc.、Rule of Law Fund、Rule of Law Society、Rule of Law Society IV, Inc.、G-Translators PTY LTD、Saraca Media Group, Inc.、Well Origin Ltd.、Whitecroft Shore Limited，以及 ZIBA Limited。\n\n9. “包括”或其任何变体，系指“包括但不限于”。\n案件 22-50073，文件 1592，提交日期 03/24/23，录入日期 03/24/23 10:57:37，第 477 页，共 1063 页\n\n10. “和”及“或”系指“和/或”，并应以连词及选择连词两种方式解释，以最大限度扩大其范围。\n\n11. “任何”及“所有”及“每一”系指“每一个及所有”。\n\n12. “每一”及“每个”系指“每一个及所有”。\n\n13. “第三方”系指除你方以外的个人或实体。\n\n14. “转让”应具有《破产法》第 101(54) 条赋予该术语的含义。\n\n15. “文件”系指属于 Fed. R. Civ. P. 34 范围内的任何信息或物品，并包括但不限于你方现在或曾经占有、保管或控制的每一项任何种类、类型、性质或描述的书面、记录或图形资料，包括电子邮件的所有纸质及电子副本、以电子形式保存的计算机文件、函件、备忘录、磁带、速记或手写笔记、任何种类的书面表格、图表、蓝图、绘图、草图、图形、计划、文章、规格、日记、信件、电报、照片、会议记录、合同、协议、调查资料、计算机打印件、任何种类的数据汇编、电传、传真、电子邮件、短信、即时消息、语音留言、发票、订购单、支票、汇票、对账单、贷项通知单、报告、头寸报告、摘要、索引、簿册、分类账、笔记本、附表、透明胶片、录音、目录、广告、宣传材料、影片、录像带、录音带、CD、计算机磁盘、宣传册、小册子、穿孔卡、工时单、推文、社交媒体帖子或任何其他种类的书面或记录材料，以及其所有元数据，无论以何种方式储存（无论为有形或电子形式）、记录、制作或复制，且还包括但不限于前述任何文件的草稿或副本，如其包含原始文件中不存在的任何种类笔记、评论或标记，或以其他方式与原始文件不完全相同。\n案件 22-50073，文件 1592，提交日期 03/24/23，录入日期 03/24/23 10:57:37，第 478 页，共 1063 页\n\n16. “个人”系指个人、公司、独资企业、合伙企业、协会或任何其他实体。“个人”还包括任何代理人、代表或专家，包括但不限于律师或财务顾问。\n\n17. “实体”系指任何自然人、公司、合伙企业、子公司、独资企业、商号、董事会、合资企业、协会、机构、主管机关、委员会或其他商业实体或法人，以及任何关联方、代理人、母公司，包括但不限于律师、财务顾问或任何其他代表。\n\n18. “关于”系指涉及、描述、构成、提及、与之相关、支持、赞成、反对、强化、减损、位于其中、结合考虑、对其有影响、证明、表明、报告、记录、暗指、回应、与之连接、评论、就其而言、关于、与之有关、讨论、显示、描述、反映、分析、构成及属于。\n\n19. “与……有关”、“有关”或“相关”，在提及任何特定事项时，系指但不限于构成、包含、涉及、载有、体现、反映、识别、陈述、直接或间接提及，或以任何方式与所识别的特定事项相关的任何文件。\n\n20. “通信”系指在最广泛可能意义上的任何信息或知识传递（以事实、观点、询问或其他形式）。通信还指所有谈话、协议、询问或答复，无论是当面、通过电话、书面方式，还是通过电子传输设备，并包括但不限于所有函件、电子邮件、录音、传送单、备忘录、电话通信、\n案件 22-50073，文件 1592，提交日期 03/24/23，录入日期 03/24/23 10:57:37，第 479 页，共 1063 页\n\n语音留言、电报、电传传真、传真副本、电传、即时消息、聊天、短信、在留言板或群聊中的发布内容、社交媒体帖子、推文、上传至任何视频平台的视频、电话笔记，或在内部或与第三方之间传递的笔记。\n\n21. “资产”系指受占有、保管或控制的任何具有经济价值的项目。资产包括所有不动产和动产，包括但不限于房地产、土地、房屋、公寓、共有公寓、汽车、游艇、船只、飞机、喷气式飞机、直升机、现金、银行账户、加密货币、证券、应收账款、存货及其他有形和无形财产。\n\nIV. 应提交的文件\n\n1. 关于位于 781 Fifth Avenue, New York, NY 10022 的 Sherry Netherland Hotel / Condominium（公寓 1801 和 1519）；位于 373 Taconic Rd., Greenwich, Connecticut 06831 的住宅物业；位于 33 Ferncliff Rd., Cos Cob, Connecticut 06807 的住宅物业；位于 354 Nod Hill Rd., Wilton, Connecticut 06897 的住宅物业；位于 32 Chateau Ridge Rd., Greenwich, Connecticut 06831 的物业；位于 110 Clapboard Ridge Rd., Greenwich, Connecticut 06830 的物业；位于 66 Sherwood Avenue, Greenwich, Connecticut 06831 的物业；位于 140 Wallacks Drive, Stamford, Connecticut 06902 的物业；位于 602 Indian Field Drive, Greenwich, Connecticut 06830 的物业；以及位于 11 Hurlingham Drive, Greenwich, Connecticut 06831 的物业的所有文件和通信。\n\n2. 与债务人、债务人财产、债务人家属或关联实体的任何收入或资产有关的所有文件或通信，包括但不限于位于 Connecticut 的任何不动产。\n案件 22-50073，文件 1592，提交日期 03/24/23，录入日期 03/24/23 10:57:37，第 480 页，共 1063 页\n\n3. 与债务人、债务人家属的任何成员和/或任何关联实体签订的任何委托函有关的所有文件或通信，包括该等委托函的副本。\n\n4. 与基于你方代理债务人、债务人家属或关联实体而向你方支付的任何预付聘金或佣金有关的所有文件或通信，包括足以识别该预付聘金或佣金金额及其来源的文件。\n\n5. 与你方从债务人、债务人家属、家属关联实体或关联实体处或代表其收到，并存放于第三方托管账户或客户信托账户中的任何费用、付款或款项有关的所有文件或通信。\n\n6. 足以显示债务人、债务人家属或关联实体为其、代表其或为其利益而向你方支付的任何款项的金额、日期及来源的文件。\n\n7. 你方与债务人、债务人家属或任何关联个人、代理人、雇员或其他代表债务人行事之个人之间，就与债务人、债务人财产、债务人家属或关联实体有关的任何转让、投资或其他交易或商业往来所进行的所有通信。\n\n8. 与涉及债务人、债务人家属或任何关联实体的任何出售、潜在出售、取得、处分、购买、潜在购买、投资、出资、赠与、信贷展期、贷款或转让有关的所有文件和通信。\n\n9. 与债务人使用任何属于、由其控制或其全部或部分所有权由债务人家属、\n案件 22-50073，文件 1592，提交日期 03/24/23，录入日期 03/24/23 10:57:37，第 481 页，共 1063 页\n\n关联实体或关联个人持有的资产有关的所有文件和通信，包括但不限于位于 Connecticut 的任何不动产。\n\n10. 关于与债务人、债务人财产、债务人家属、关联实体或关联个人有关的任何资产负债表、银行对账单、账户对账单、财务报表、账户报表、电汇指示和/或确认、资金证明、存款证明、持仓证明、投资组合摘要或类似文件的所有文件和通信，包括但不限于足以显示向前述任何一方进行的所有转让的全部文件。\n\n案号 22-50073 文书 1592 提交于 03/24/23 录入于 03/24/23 10:57:37 第 482 页，共 1063 页\n\n附件 C-26\n\nB2540（表格 2540——规则 2004 审查传票）（12/15）案号 22-50073 文书 1592 提交于 03/24/23 录入于 03/24/23 10:57:37 第 483 页，共\n\nUNITED STATES BANKRUPTCY COURT（美国破产法院）\n\nDistrict of Connecticut（康涅狄格州地区）\n\n关于 HO WAN KWOK（郭文贵）等人，\n\n1 案号 22-50073 (JAM) 债务人 第11章\n\n（合并管理）\n\n规则 2004 审查传票\n\n致：David Fallon（戴维·法伦）\n\n（传票所指向人员的姓名）\n\n证言：兹命令你于下列规定的时间、日期和地点出席，并根据《联邦破产程序规则》规则 2004 接受审查并作证。随附准许该审查的法院命令副本。\n\n地点　日期和时间\n\nPaul Hastings LLP（保罗·黑斯廷斯律师事务所）\n200 Park Avenue　[TBD]\nNew York, New York 10166\n\n审查将通过以下方式记录：法庭记录员／速记员\n\n提交：你或你的代表还必须在审查时携带下列文件、电子存储信息或物件，并必须准许对该等材料进行查验、复制、测试或抽样：\n\n见随附的文件提交请求。\n\n以下《联邦民事诉讼规则》45 条的规定，依《联邦破产程序规则》9016 条适用于破产案件，现随附于此——有关履行地点的规则 45(c)；有关作为传票对象的你所受保护的规则 45(d)；以及有关你对本传票的答复义务及未答复之潜在后果的规则 45(e) 和 45(g)。\n\n日期：March , 2023\n\n法院书记员\n\n或\n\n书记员或副书记员签名　律师签名\n\n签发或申请本传票、代表第11章受托人 Luc A. Despins（卢克·A·德斯平斯）的律师的姓名、地址、电子邮件地址和电话号码如下：\n\nDouglas S. Skalka, Esq.（道格拉斯·S·斯卡尔卡，律师）；Neubert, Pepe & Monteith, P.C.（纽伯特、佩佩及蒙蒂思专业公司）；195 Church Street, New Haven, Connecticut 06510；dskalka@npmlaw.com；(203) 821-2000\n\n向签发或申请本传票之人的通知\n\n如本传票命令在审判前提交文件、电子存储信息或有形物品，或查验场所，则在向传票所指向人员送达之前，必须向每一方送达通知及本传票副本。Fed. R. Civ. P. 45(a)(4)。\n\n软件版权 (c) 1996-2022 Best Case, LLC（百斯特凯斯有限责任公司）- www.bestcase.com Best Case Bankruptcy 1 本第11章案件中的债务人为 Ho Wan Kwok（亦称 Guo Wengui、Miles Guo 和 Miles Kwok，以及众多其他别名）（税务识别号码后四位：9595）、Genever Holdings LLC（杰尼弗控股有限责任公司）（税务识别号码后四位：8202）以及 Genever Holdings Corporation（杰尼弗控股公司）。受托人、Genever Holdings LLC 和 Genever Holdings Corporation 的邮寄地址为 Paul Hastings LLP, 200 Park Avenue, New York, NY 10166，转交 Luc A. Despins，作为 Ho Wan Kwok 财产的受托人（仅为通知和通信之目的）。\n\n送达证明\n\n（除非 Fed. R. Civ. P. 45 要求，否则本节不应向法院提交。）\n\n我于（日期）收到向（个人姓名及职务，如有）送达的本传票。\n\n我通过如下方式向具名人员交付副本送达本传票：\n\n于（日期）；或\n\n我未执行而退回本传票，原因如下：\n\n除非本传票系代表美国或其官员或代理人签发，我还已向证人支付一天出席费用及法律允许的里程费，金额为 \\$ 。\n\n我的差旅费用为 \\$ ，服务费用为 \\$ ，合计 \\$ 。\n\n我在伪证处罚下声明，该等信息真实、正确。\n\n日期：\n\n送达人签名\n\n正楷姓名及职务\n\n送达人地址\n\n关于尝试送达等的附加信息：\n\n《联邦民事诉讼规则》45(c)、(d)、(e) 及 (g)（生效于 12/1/13）（依《联邦破产程序规则》规则 9016 适用于破产案件）\n\n(c) 履行地点。\n\n(1) 审判、听证或证言录取。传票仅可按下列方式命令某人出席审判、听证或证言录取：\n\n(A) 在该人居住、受雇或经常亲自进行营业活动地点的 100 英里以内；或\n\n(B) 在该人居住、受雇或经常亲自进行营业活动所在州内，若该人：\n\n(i) 为当事人或当事人的高级职员；或\n\n(ii) 被命令出席审判且不会产生重大费用。\n\n(2) 其他证据开示。传票可命令：\n\n(A) 在该人居住、受雇或经常亲自进行营业活动地点的 100 英里以内的地点提交文件、电子存储信息或物品；以及\n\n(B) 在拟查验的场所查验场所。\n\n(d) 对作为传票对象的人员的保护；执行。\n\n(1) 避免不当负担或费用；制裁。负责签发及送达传票的当事人或律师必须采取合理措施，避免对作为传票对象的人员施加不当负担或费用。要求履行的地区法院必须执行该义务，并对未遵守者的当事人或律师施加适当制裁，其中可包括损失的收入及合理的律师费。\n\n(2) 命令提交材料或准许查验。\n\n(A) 无须出席。被命令提交文件、电子存储信息或有形物品，或准许查验场所的人员，除非同时被命令出席证言录取、听证或审判，无须亲自到提交或查验地点出席。\n\n(B) 异议。被命令提交文件或有形物品，或准许查验的人员，可向传票中指定的当事人或律师送达书面异议，反对对任何或全部材料进行查验、复制、测试或抽样，或反对查验场所，或反对以所请求的一种或多种形式提交电子存储信息。异议必须在规定履行时间或传票送达后 14 日届满两者中较早的时间之前送达。如提出异议，则适用下列规则：\n\n(i) 送达方可随时在通知被命令人员后，向要求履行的地区法院提出动议，请求作出强制提交或查验的命令。\n\n(ii) 仅可依命令所指示要求实施该等行为，且该命令必须保护既非当事人亦非当事人高级职员的人员，使其免于因履行而产生重大费用。\n\n(3) 撤销或修改传票。\n\n(A) 必须撤销或修改的情形。经及时提出动议，要求履行的地区法院必须撤销或修改具有下列情形的传票：\n\n(i) 未留出合理履行时间；\n\n(ii) 要求某人在规则 45(c) 规定的地域限制之外履行；\n\n(iii) 要求披露享有特权或受其他保护的事项，且无适用的例外或放弃；或\n\n(iv) 对某人施加不当负担。\n\n(B) 可撤销或修改的情形。为保护作为传票对象或受传票影响的人员，经动议，要求履行的地区法院可撤销或修改要求下列事项的传票：\n\n(i) 披露商业秘密或其他保密的研究、开发或商业信息；或\n\n(ii) 披露未受聘专家的意见或信息，该等意见或信息未描述争议中的具体事件，并源于并非由一方当事人请求的该专家研究。\n\n(C) 作为替代方案规定条件。在规则 45(d)(3)(B) 所述情形下，如送达方：\n\n(i) 证明对证言或材料具有重大需要，且不造成不当困难即无法以其他方式满足该需要；并且\n\n(ii) 确保被传唤人员将获得合理补偿，\n\n法院可不撤销或修改传票，而是命令在规定条件下出席或提交。\n\n(e) 答复传票的义务。\n\n(1) 提交文件或电子存储信息。下列程序适用于提交文件或电子存储信息：\n\n(A) 文件。答复要求提交文件的传票的人员，必须按文件在通常业务过程中保存的方式提交，或必须将其整理并标注为与请求中的类别相对应。\n\n(B) 未规定电子存储信息的提交形式。如传票未规定提交电子存储信息的形式，答复人员必须以其通常保存的一种或多种形式，或以合理可用的一种或多种形式提交。\n\n(C) 电子存储信息仅以一种形式提交。答复人员无须以超过一种形式提交同一电子存储信息。\n\n(D) 无法合理取得的电子存储信息。答复人员无须提供来自其认定为因不当负担或费用而无法合理取得的来源的电子存储信息的证据开示。就强制证据开示动议或保护令动议，答复人员必须证明该信息因不当负担或费用而无法合理取得。如作出该证明，若请求方在考虑规则 26(b)(2)(C) 的限制后证明存在正当理由，法院仍可命令从该等来源进行证据开示。法院可就证据开示规定条件。\n\n(2) 主张特权或保护。\n\n(A) 扣留的信息。以信息享有特权或作为审判准备材料受保护为由扣留被传唤信息的人员必须：(i) 明确提出该主张；以及\n\n(ii) 以一种方式说明被扣留文件、通信或有形物品的性质，该方式在不披露本身享有特权或受保护的信息的情况下，使各方能够评估该主张。\n\n(B) 已提交的信息。如为答复传票而提交的信息受到特权主张或作为审判准备材料受保护的主张，提出主张的人员可将该主张及其依据通知收到该信息的任何一方。收到通知后，当事人必须立即返还、隔离或销毁所指明的信息及其持有的任何副本；在该主张解决前不得使用或披露该信息；如当事人在收到通知前已披露该信息，必须采取合理措施取回该信息；并可立即将该信息密封提交给要求履行的地区法院，以裁定该主张。提交该信息的人员必须保存该信息，直至该主张得到解决。\n\n(g) 藐视法庭。要求履行的地区法院——以及在动议被移送后签发传票的法院——可判定已被送达但无充分理由不遵守传票或相关命令的人员构成藐视法庭。\n\n关于取得传票材料，见 Fed.R.Civ.P.45(a) Committee Note (2013)\n\n……\n\n文件提交请求\n\nI. 指示\n\n1. 除非另有说明，下述文件请求（以下简称“请求”，各称“一项请求”）必须分别且具体地予以答复。除非基于善意提出异议，否则每项请求均应得到完整答复；如提出异议，则应按如下规定详细说明你提出异议的理由。如异议仅涉及某项请求的一部分，或其中所含的一个词、短语或条款，你仅须说明对该部分的异议，并答复其余请求。\n\n2. 电子存储信息必须依照以下指示提交：\n\n- a. 图像。黑白图像必须为 300 DPI Group IV 单页 TIFF 文件。彩色图像必须以 JPEG 格式制作。文件名不得包含嵌入空格或特殊字符（包括逗号）。文件夹名称不得包含嵌入空格或特殊字符（包括逗号）。所有 TIFF 图像文件必须具有唯一文件名，即 Bates 编号。每一图像右下角必须加注连续的 Bates 编号。每个文件夹中的 TIFF 文件数量不应超过 1000 个文件。Excel 电子表格应具有以该文件 Bates 编号命名的占位图像。\n\n- b. 图像加载文件\n\t- a. Concordance® 数据文件。数据文件（.DAT）包含将加载至 Concordance® 数据库的所有字段化信息。.DAT 文件的第一行必须为标明字段名称的标题行。.DAT 文件必须使用以下 Concordance® 默认分隔符：逗号 ASCII 字符（020）；引号 þ ASCII 字符（254）。日期字段应采用以下格式提供：mm/dd/yyyy。日期和时间字段必须为两个独立字段。如文件包括已制作图像的电子邮件及附件，则必须包括附件字段，以保留电子邮件与其附件之间的父/子关系。必须包括 OCRPATH 字段，以提供所提取文本文件在已制作存储介质上的文件路径和名称。文本文件必须以 FIRSTBATES 命名。不得在 .DAT 文件中包括文本。对于含有原生文件的文件，必须包括 LINK 字段，以提供原生文件的文件路径和名称。原生文件必须以 FIRSTBATES 命名。\n\n- b. Concordance Image® 或 Opticon 交叉引用文件。图像交叉引用文件（.LOG 或 .OPT）将图像与数据库记录关联。其应为以逗号分隔的文件，每行由七个字段组成，并且数据库中的每一图像均应在交叉引用文件中对应一行，格式如下：ImageID,VolumeLabel,ImageFilePath,DocumentBreak,FolderBreak,Box Break,PageCoun。\n\n- c. 文件文本。文本必须作为独立文本文件提供，而不得作为 .DAT 文件内的字段提供。文本文件的完整路径（OCRPATH）应包括在 .DAT 文件中。建议提供按 FIRSTBATES/Image Key 命名的文件级 ANSI 文本文件。提取的文本文件必须置于单独文件夹中，每个文件夹中的文本文件数量不应超过 1,000 个文件。文件夹名称中不得有特殊字符（包括逗号）。文本文件必须按文件级别提供。\n\n- d. 特定文件类型的原生格式制作。为充分理解其内容和含义而合理需要以原生格式查看的文件类型，必须以原生格式提供。这些包括但不限于电子表格、类电子表格文件（Microsoft Excel、逗号分隔值、制表符分隔值等）、Microsoft PowerPoint 或其他特殊演示文件、数据库文件以及音频/视频文件。应提供一张带有 Bates 编号的分隔页图像，表明存在原生文件，并将原生文件路径作为字段包括在 .dat 文件中。所提供的原生文件应以对应于该文件分隔页的 Bates 编号命名。将原生文件归入按递增方式命名的“NATIVE”目录中，并与图像目录分开。\n\n- e. 去重。对于存在完全重复件的每一电子文件，仅提供一份副本。对于电子邮件信息，应根据由 BCC、Body、CC、From、IntMsgID、To 和 Attach 属性生成的 MD5 哈希值合并重复件。对于电子邮件附件和独立电子文件，应根据整个文件的 MD5 哈希值合并重复件。\n\n- f. 元数据。以符合 Concordance 要求的加载文件（.dat）形式，为每一文件提供提取的元数据。.DAT 文件的第一行必须为标明字段名称的标题行。.DAT 文件必须使用以下 Concordance 默认分隔符：逗号 , ASCII 字符（020）；引号 þ ASCII 字符（254）。\n\n日期字段应采用以下格式提供：mm/dd/yyyy。日期和时间字段必须为两个独立字段。以下列出所需元数据：\n\n案件 22-50073 文件 1592 提交于 03/24/23 录入于 03/24/23 10:57:37 第 488 页，共 1063 页\n\n字段名称　示例数据　说明\n\nFIRSTBATES　EDC0000001　原生文件文件/电子邮件的首个 Bates 编号\n\nLASTBATES　EDC0000001　原生文件文件/电子邮件的最后一个 Bates 编号\n\n**对于单页文件，LASTBATES 字段应予填充\n\nATTACHRANGE　EDC0000001\n-　母文件首页的 Bates 编号至最后一个附件“子”文件最后一页的 Bates 编号\nEDC0000015\n\nBEGATTACH　EDC0000001　附件范围的首个 Bates 编号\n\nENDATTACH　EDC0000015　附件范围的最后一个 Bates 编号\n\nCUSTODIAN　Smith, John　电子邮件：该电子邮件所在的邮箱\n原生文件：文件来源的个人或部门名称\n\nFROM　John Smith　电子邮件：发件人\n原生文件：文件作者\n**应使用分号分隔多个条目\n\nTO　Coffman, Janice; LeeW　收件人\n[mailto:LeeW@MSN.com]　**应使用分号分隔多个条目\n\nCC　Frank Thompson [mailto:　抄送收件人\nfrank_Thompson@cdt.com]　**应使用分号分隔多个条目\n\nBCC　John Cain　密送收件人\n**应使用分号分隔多个条目\n\nSUBJECT　Board Meeting Minutes　电子邮件：电子邮件主题行；原生文件：文件标题（如有）\n\nFILE_NAME　BoardMeetingMinutes.docx　原生文件：原始原生文件的名称，包括扩展名\n\nDATE_SENT　10/12/2010　电子邮件：电子邮件发送日期\n原生文件：（空）\n\nTIME_SENT/\nTIME_ZONE　07:05 PM GMT　电子邮件：电子邮件发送时间/电子邮件标准化所在的时区\n\nTIME_ZONE　GMT　在转换过程中电子邮件被标准化的时区。\n\nLINK　EDC0000001.msg　电子邮件或原生文件文件的超链接\n**所链接文件必须按 FIRSTBATES 编号命名\n\nFILE_EXTEN　MSG　代表电子邮件或原生文件的文件类型扩展名\n\nAUTHOR　John Smith　电子邮件：（空）\n原生文件：文件作者\n\nDATE_CREATED　10/10/2010　电子邮件：（空）\n原生文件：文件创建日期\n\n案件 22-50073 文件 1592 提交于 03/24/23 录入于 03/24/23 10:57:37 第 489 页，共 1063 页\n\nTIME_CREATED　10:25 AM　电子邮件：（空）\n原生文件：文件创建时间\n**此数据必须为独立字段，不得与 DATE_CREATED 字段合并\n\nDATE_MOD　10/12/2010　电子邮件：（空）\n原生文件：文件最后修改日期\n\nTIME_MOD　07:00 PM　电子邮件：（空）\n原生文件：文件最后修改时间\n**此数据必须为独立字段，不得与 DATE_MOD 字段合并\n\nDATE_ACCESSD　10/12/2010　电子邮件：（空）\n原生文件：文件最后访问日期\n\nTIME_ACCESSD　07:00 PM　电子邮件：（空）\n原生文件：文件最后访问时间\n**此数据必须为独立字段，不得与 DATE_ACCESSD 字段合并\n\nFILE_SIZE　5,952　原生文件文件/电子邮件的大小，以 KB 计\n\nPGCOUNT　1　原生文件文件/电子邮件的页数\n\nPATH　电子邮件：（空）\nAgenda.doc　原生文件：存储原生文件文件的路径，包括原始文件名。\n\nINTFILEPATH　Personal Folders\\Deleted　电子邮件：电子邮件的原始位置，包括原始文件名。\nItems\\Board Meeting\nMinutes.msg　原生文件：（空）\n\nINTMSGID　<000805c2c71b\\$75977050\\$　电子邮件：唯一信息 ID；原生文件：（空）\ncb8306d1@MSN>\n\nMD5HASH　d131dd02c5e6eec4693d9a0　文件的 MD5 哈希值。\n698aff95c\n2fcab58712467eab4004583e\nb8fb7f89\n\nOCRPATH　TEXT/001/EDC0000001.txt　原生文件提取文本的路径\n\n3. 每项请求独立适用并应独立解释，除非另有说明，任何请求均不限制任何其他请求的范围。\n\n4. 所有文件均应按其在正常业务过程中保存的方式提供，或应组织和标注以对应于本请求中的类别。\n\n5. 每项载于本文件中的请求均延及以下所有文件：(a) 由您占有、保管或控制的文件；或 (b) 由代表您行事的任何人占有、保管或控制的文件，\n\n案件 22-50073 文件 1592 提交于 03/24/23 录入于 03/24/23 10:57:37 第 490 页，共 1063 页\n\n包括您的律师或其他代表和顾问。每份文件均应完整提供。\n\n6. 如果要求您提供一份已不再由您占有、保管或控制的文件，则您的答复必须：(a) 详细说明该文件的性质及其内容；(b) 识别编制或撰写该文件的人员（以及，如适用，该文件被发送给的人员）；(c) 识别该文件编制或创建的日期；(d) 说明该文件是否 (i) 下落不明或遗失，(ii) 已被销毁，(iii) 已自愿或非自愿地转交给他人，或 (iv) 以其他方式被处置；(e) 说明该等处置的理由，以及有关该等处置的事实和情形；(f) 识别授权该等处置的人员；(g) 识别该等处置的日期或大致日期；(h) 说明该文件最近一次由您占有、保管或控制的时间；以及 (i) 识别目前占有、保管或控制该文件的人员（如有）。\n\n7. 如果要求您提供一份已被销毁的文件，则除前项指示所要求的信息外，您的答复还必须说明：(a) 该文件被销毁的理由；(b) 销毁该文件的人员身份；以及 (c) 指示销毁该文件的人员身份。\n\n8. 如果您主张所请求的文件享有特权或属于律师工作成果，则您的答复必须：(a) 说明 (i) 足以支持您关于该文件享有特权之主张的文件描述，(ii) 文件标题，(iii) 文件日期，(iv) 文件作者，(v) 文件收件人，(vi) 收到或阅览该文件原件或任何草稿、副本或复制件的每一人员身份，(vii) 该文件本身或文件中所载或所提及的任何信息是否由任何其他人员占有、保管或控制；如是，则说明该等人员身份，\n\n案件 22-50073 文件 1592 提交于 03/24/23 录入于 03/24/23 10:57:37 第 491 页，共 1063 页\n\n以及说明该等信息如何进入其占有范围，(viii) 据以扣留该文件的特权主张，以及 (ix) 您将据以支持该等特权主张的所有情形；并且 (b) 根据 D. Conn. L. Civ. R. 26(e)，就基于特权主张而扣留的每一文件，提供一份载有本指示第 (a) 部分所要求全部信息的特权清单。\n\n9. 如果一份原本应予提供的文件的一部分包含受特权主张约束的信息，则仅应依照上述指示从该文件中删除或遮蔽受特权主张约束的部分，其余部分应予提供。\n\n10. 本请求具有持续性。特此指示您：(a) 一旦知悉先前答复不完整或不正确，即立即补充或更正任何后来发现不完整或不正确的答复；以及 (b) 提供根据下列要求所要求的任何额外文件。\n\n11. 如果文件使用英语以外的语言，您应提供该文件。如果文件使用英语以外的语言，且存在英文译本，您应同时提供两份文件。\n\n12. 所有对实体的提及均包括其所有关联方。\n\n13. 所有对个人姓名的提及均包括所有替代姓名、别名或昵称。\n\n14. 除非另有明确说明，文件请求所涵盖的期间为自 February 5, 2012 起至文件请求答复到期之日止的期间。\n\n案号 22-50073 文书 1592 于 03/24/23 提交，于 03/24/23 10:57:37 登记 第 492 页，共 1063 页\n\nII. 解释规则\n\n15. (a) 任何单数名词的使用，应解释为包括复数，反之亦然；以及 (b) 任何时态动词的使用，应解释为该动词在所有其他时态下的使用。\n\n16. (a) “and”和“or”应根据需要作合取或析取解释，以使任何请求的范围涵盖原本可能被解释为不在其范围内的所有答复；以及 (b) “each”和“any”应视为包括并涵盖“every”和“all”二词。\n\nIII. 定义\n\n根据 D. Conn. Bankr. L.R. 2004-1(a) 纳入的 D. Conn. L. Civ. R. 26(c) 所提供的定义以及 D. Conn. L. Civ. R. 26(d) 所提供的解释规则，适用于文件请求。此外，本文件请求中使用的下列术语具有下列含义：\n\n1. “You”、“Your”或“Yourself”指 David Fallon（大卫·法伦），以及其所有代理人、律师、代表、雇员和/或任何代表其行事之人。\n\n2. “Debtor”指 Ho Wan Kwok（郭文贵）（又名 Miles Kwok、Miles Guo、Guo Wengui、Guo Haoyun、郭文贵或任何其他别名），以及其雇员、代理人、法律顾问、顾问或任何代表其行事之人。\n\n3. “Debtor's Son”指 Qiang Guo（郭强）（又名 Mileson Kwok、郭强或任何其他别名），以及其雇员、代理人、法律顾问、顾问或任何代表其行事之人。\n\n4. “Debtor's Daughter”指 Mei Guo（郭美）（又名 Mei Gui、郭美或任何其他别名），以及其雇员、代理人、法律顾问、顾问或任何代表其行事之人。\n\n案号 22-50073 文书 1592 于 03/24/23 提交，于 03/24/23 10:57:37 登记 第 493 页，共 1063 页\n\n5. “Debtor's Purported Wife”指 Hing Chi Ngok（岳庆芝）（又名 Hing Chi Ng、Yue Qingzhi、岳庆芝或任何其他别名），以及其雇员、代理人、法律顾问、顾问或任何代表其行事之人。\n\n6. “Debtor's Family”统指债务人、债务人之子、债务人之女及债务人所谓的妻子，以及债务人的任何其他亲属关系人。\n\n7. “Associated Individuals”单独及共同指下列所有个人：(1) 持有、控制、保管或对债务人或债务人家庭所拥有、控制或享有的资产拥有处置权者；或 (2) 曾为一个或多个关联实体的雇员、董事，或以其他方式与一个或多个关联实体有关联者，以及前述任何人的各自雇员、代理人、法律顾问、顾问或任何代表其行事之人。该等关联个人包括但不限于：Daniel Podhaskie（丹尼尔·波德哈斯基）、Jason Miller（杰森·米勒）、Steve Bannon（史蒂夫·班农）、Karin Maistrello（卡琳·迈斯特雷洛）、Melissa Francis（梅丽莎·弗朗西斯）、Anthony DiBattista（安东尼·迪巴蒂斯塔）、William Gertz（威廉·格茨）、Arethusa Forsyth（阿瑞苏莎·福赛思）、Glenn Mellor（格伦·梅勒）、Jennifer Mercurio（詹妮弗·默丘里奥）、Eduardo Eurnekian（爱德华多·尤尔内基安）、Wencong Wang（王文聪）、Han Chunguang（韩春光）（又名 韩春光）、Qu Guojiao（屈国姣）（又名 Qu Guo Jiao、屈国姣）、Guo Lijie（郭丽杰）（又名 郭丽杰）、Zhang Wei（张伟）（又名 张伟*）、Lihong Wei Lafrenz（魏丽红）（又名 Sara Wei、魏丽红）、Hao Haidong（郝海东）（又名 郝海东）、Ross Heinemeyer（罗斯·海内迈耶）、Max Krasner（马克斯·克拉斯纳）、Kyle Bass（凯尔·巴斯）、Melissa Mendez（梅丽莎·门德斯）、Ya Li（李娅）（又名 李娅）、Dinggang Wang（王定刚）（又名 王定刚）、An Hong（安红）（又名 安红）、Yvette Wang（王雁平）（又名 Yanping Wang、Yan Ping Wang、王雁平）、Fiona Yu（余菲奥娜）、Je Kin Ming（余建明）（又名 William Je、Yu Jianming、余建明）、Yaz Qingua（亚兹·青瓜）及 Lao Jiang（姜云浮）（又名 Jiang Yunfu、Jiang Yunfu Be、姜云浮）。\n\n8. “Associated Entities”单独及共同指下列所有任何类型的组织或实体：(1) 曾由债务人或\n\n案号 22-50073 文书 1592 于 03/24/23 提交，于 03/24/23 10:57:37 登记 第 494 页，共 1063 页\n\n债务人家庭拥有、控制或投资的组织或实体；或 (2) 对债务人或债务人家庭拥有、控制或享有的任何资产直接或间接拥有权益的组织或实体，以及前述任何实体的各自雇员、代理人、法律顾问、顾问或任何代表其行事之人。该等关联实体包括但不限于：7 Nod Hill LLC（七诺德山有限责任公司）、AAGV Limited（AAGV有限公司）、ACA Investment Management Limited（ACA投资管理有限公司）、ACA Capital Group Limited（ACA资本集团有限公司）、Ace Decade Holdings Limited（王牌十年控股有限公司）、AI Group Holdings Inc.（AI集团控股公司）、Alfa Global Ventures Limited（阿尔法全球风险投资有限公司）、Alfonso Global Limited（阿方索全球有限公司）、Allied Capital Global Limited（联合资本全球有限公司）、Alpine Fiduciaries SA（阿尔卑斯受托人股份公司）、Anton Development Limited（安东开发有限公司）、Assets Sino Limited（中资资产有限公司）、Auspicious Coast Limited（吉祥海岸有限公司）、Beijing Pangu Investment Co.（北京盘古投资公司）、Beijing Pangu Investment Co. Ltd.（北京盘古投资有限公司）、Beijing Pangu Investment Inc.（北京盘古投资股份公司）、Beijing Zenith Holdings Company Limited（北京鼎峰控股有限公司）、Booming Sail New York LLC（纽约兴帆有限责任公司）、Bravo Luck Limited（福运有限公司）、BSA Strategic Fund I（BSA战略基金I）、China Golden Spring (Hong Kong) Limited（中国金泉〈香港〉有限公司）、Chuang Xin Limited（创新有限公司）、Crane Advisory Group LLC（鹤顾问集团有限责任公司）、Creative Apex Investments Limited（创意顶峰投资有限公司）、Crystal Breeze Investments Limited（水晶微风投资有限公司）、Dawn State Limited（曙光州有限公司）、Eastern Profit Corporation Limited（东方利润有限公司）、Elite Well Global Limited（精英井全球有限公司）、Empire Growth Holdings（帝国增长控股）、Freedom Media Ventures Ltd.（自由媒体风险投资有限公司）、G Club Operations LLC（G俱乐部运营有限责任公司）、G Fashion LLC（G时尚有限责任公司）、G News LLC（G新闻有限责任公司）、GETTR USA（GETTR美国）、Genever Holdings Corporation（Genever控股公司）、Genever Holdings LLC（Genever控股有限责任公司）、Gfashion Media Group Inc.（G时尚媒体集团公司）、GFNY, Inc.（GFNY公司）、Globalist International Limited（全球主义者国际有限公司）、GNews Media Group Inc.（G新闻媒体集团公司）、Golden Spring (New York) Ltd.（金泉〈纽约〉有限公司）、Greenwich Land LLC（格林尼治土地有限责任公司）、Guo Media（郭媒体）、GTV Media Group, Inc.（GTV媒体集团公司）、Hamilton Capital Holdings Inc.（汉密尔顿资本控股公司）、HCHK Property Management, Inc.（HCHK物业管理公司）、HCHK Technologies, Inc.（HCHK技术公司）、Head Win Group Limited（首赢集团有限公司）、Henan Yuda（河南裕达）、Himalaya Embassy（喜马拉雅大使馆）、Himalaya Exchange（喜马拉雅交易所）、Himalaya Federal Reserve（喜马拉雅联邦储备）、Himalaya Investment LLC（喜马拉雅投资有限责任公司）、Himalaya International（喜马拉雅国际）、Himalaya New World Inc.（喜马拉雅新世界公司）、Himalaya Supervisory Organization（喜马拉雅监督组织）、Himalaya Ventures LLC（喜马拉雅风险投资有限责任公司）、HK International Funds Investments (USA) Limited LLC（香港国际基金投资〈美国〉有限责任公司）、Hong Kong International Funds Investments Limited（香港国际基金投资有限公司）、Hudson Diamond Holding（哈德逊钻石控股）、Infinite Increase Limited（无限增长有限公司）、Infinitum Developments Limited（无尽发展有限公司）、Infinity Treasury Management Inc.（无限财政管理公司）、Insight Phoenix Fund（洞察凤凰基金）、Lamp Capital\n\n案号 22-50073 文书 1592 于 03/24/23 提交，于 03/24/23 10:57:37 登记 第 495 页，共 1063 页\n\nLLC（灯资本有限责任公司）、Leading Shine Limited（领先光辉有限公司）、Leading Shine NY Limited（领先光辉纽约有限公司）、Lexington Property and Staffing（列克星敦物业与人力配置）、Long Gate Limited（长龙门有限公司）、Maywind Trading LLC（五月风贸易有限责任公司）、MOS Himalaya LLC（MOS喜马拉雅有限责任公司）、Next Tycoon Investments Limited（下一大亨投资有限公司）、New Federal State of China（中国新联邦国）（又名 NFSC）、Noble Fame Global Limited（高贵名望全球有限公司）、Rosy Acme Ventures Limited（玫瑰顶峰风险投资有限公司）、Rule of Law Foundation III, Inc.（法治基金会III公司）、Rule of Law Foundation IV, Inc.（法治基金会IV公司）、Rule of Law Fund（法治基金）、Rule of Law Society（法治协会）、Rule of Law Society IV, Inc.（法治协会IV公司）、G-Translators PTY LTD（G-译者私人有限公司）、Saraca Media Group, Inc.（萨拉卡媒体集团公司）、Shiny Ace Ltd.（闪耀王牌有限公司）、Shiny Times Holdings Ltd.（闪耀时代控股有限公司）、Spirit Charter Investment Limited（精神宪章投资有限公司）、Stevenson, Wong & Co.（史蒂文森、黄及公司）、Voice of Guo Media, Inc.（郭媒体之声公司）、Well Origin Ltd.（良好起源有限公司）、World Century Limited（世界世纪有限公司）、Worldwide Opportunity Holdings Limited（全球机遇控股有限公司）、Whitecroft Shore Limited（怀特克罗夫特海岸有限公司）及 ZIBA Limited（ZIBA有限公司）。\n\n9. “Including”或其任何变体，意为“包括但不限于”。\n\n10. “And”和“or”意为“and/or”，并应作合取及析取解释，以最大限度扩大其范围。\n\n11. “Any”、“all”和“each”意为“each and every”。\n\n12. “Each”和“every”意为“each and every”。\n\n13. “Third Party”指除您本人以外的个人或实体。\n\n14. “Transfer”具有《破产法典》第 101(54) 条赋予该词的含义。\n\n15. “Document”指属于 Fed. R. Civ. P. 34 范围内的任何信息或物品，并包括但不限于任何种类、类型、性质或描述的、现由或曾由您占有、保管或控制的每一项书面、记录或图形材料，包括电子邮件的所有印刷及电子副本、以电子形式保存的计算机文件、电子通信、短信、社交媒体帖子、推文、元数据、通信函件、备忘录、磁带、速记或手写笔记、任何种类的书面表格、图表、蓝图、绘图、草图、图形、计划、文章、规格说明、日记、信函、电报、照片、会议记录、合同、协议、调查、计算机打印件、任何种类的数据汇编、电传、传真、语音留言、发票、订购单、支票、汇票、对账单、贷项通知单、报告、持仓报告、摘要、索引、书籍、分类账、笔记本、附表、透明胶片、录音、目录、广告、宣传材料、胶片、录像带、录音带、CD、计算机磁盘、宣传册、小册子、穿孔卡、工时单、推文、社交媒体帖子或任何其他种类的书面或记录材料，以及其所有元数据，无论以何种方式存储（无论为有形或电子形式）、记录、制作或复制；还包括但不限于前述任何材料的草稿或副本，如其中含有原始文件中未见的任何种类的笔记、评论或标记，或在其他方面与原始文件不相同。\n\n案号 22-50073 文书 1592 于 03/24/23 提交，于 03/24/23 10:57:37 登记 第 496 页，共 1063 页\n\n16. “Person(s)”指个人、公司、独资企业、合伙企业、协会或任何其他实体。“Person”亦包括任何代理人、代表或专家，包括但不限于律师或财务顾问。\n\n17. “Entity”指任何自然人、公司、合伙企业、子公司、独资企业、商号、董事会、合资企业、协会、机构、主管机关、委员会或其他商业实体或法人，以及任何关联方、代理人、母公司，包括但不限于法律顾问、财务顾问或任何其他代表。\n\n18. “Regarding”意为有关、描述、构成、提及、与之相关、支持、赞成、反对、加强、削弱、位于其中、结合其予以考虑、对其具有影响、证明、表明、报告、记录、暗指、答复、与之相连、评论、就其而言、关于、与之有关、讨论、显示、描述、反映、分析、构成及属于。\n\n案号 22-50073 文书 1592 于 03/24/23 提交，于 03/24/23 10:57:37 登记 第 497 页，共 1063 页\n\n19. 在提及任何特定事项时，“Relating to”、“relate(s) to”或“related to”意为包括但不限于构成、包括、涉及、载有、体现、反映、识别、陈述、直接或间接提及该特定事项，或以任何方式与所确定的特定事项有关的任何文件。\n\n20. “Communication(s)”系在最广义上且不限于指任何信息或知识的传递（以事实、想法、询问或其他形式）。Communication(s)还指所有面对面、电话、书面或通过电子传输设备进行的谈话、协议、询问或答复，并包括但不限于所有通信函件、电子邮件、录音、传送单、备忘录、电话通信、语音留言、电报、电子传真、传真副本、电传、即时消息、聊天、短信、电话笔记或在内部或与第三方之间传送的笔记。\n\n21. “Asset(s)”指可用于产生正向经济价值的任何项目，包括但不限于由某一实体拥有、控制或为其利益而持有，并预期提供未来利益的任何具有经济价值的资源，包括但不限于所有不动产和动产、无形财产、投资、投资权或未来收入权、现金、银行账户、商品、证券、债权、对某一实体的全部或部分控制权，以及预期的经济机会。\n\n22. “Transfer”具有《破产法典》第 101(54) 条赋予该词的含义。\n\nIV. 应提交的文件\n\n1. 与债务人、债务人财产或关联实体的任何收入或资产有关的所有文件。\n\n案号 22-50073 文书 1592 于 03/24/23 提交，于 03/24/23 10:57:37 登记 第 498 页，共 1063 页\n\n2. 与债务人的财务状况及其对债权人的义务有关的所有文件，包括但不限于与任何规避支付该等义务的努力有关的所有文件，以及与本案或任何其他实际或可能的破产或类似无力偿债程序有关的所有文件。\n\n3. 与债务人、债务人的破产财产、债务人的家庭成员、关联实体或关联个人有关的任何资产负债表、银行对账单、账户对账单、财务报表、账目报表、电汇指示和／或确认书、资金证明、存款证明、持仓证明、投资组合摘要或类似文件的全部文件，包括但不限于足以显示向前述任何一方作出的所有转移的全部文件。\n\n4. 与债务人作出、与债务人进行或代表债务人作出的任何投资、商业交易或交易有关的全部文件。\n\n5. 与债务人的全部通讯，以及与债务人的通讯有关、涉及任何实体（包括但不限于关联实体）的运营、管理或决策的文件。\n\n6. 与向债务人、债务人的家庭成员或关联实体作出、由其作出或与其进行的任何转移、投资或其他交易或商业往来有关的全部文件。\n\n7. 与债务人曾经占用或使用的任何财产有关的全部文件，包括但不限于 Lady May（“梅夫人”号）；Sherry Netherland Hotel / Condominium（雪莉荷兰人酒店／公寓）；位于 Connecticut（康涅狄格州）Greenwich（格林尼治）373 Taconic Rd. 的住宅房产；位于康涅狄格州格林尼治 33 Ferncliff Rd. 的住宅房产；以及位于康涅狄格州 Wilton（威尔顿）354 Nod Hill Rd. 的住宅房产。\nCase 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 499 of 1063\n\n8. 与债务人拥有、控制或使用的任何航空器有关的全部文件，包括但不限于尾号为 T7-GQM 的航空器，以及在 San Marino（圣马力诺）登记的任何其他航空器；包括但不限于所有登记文件副本和飞行记录单，该等飞行记录单显示该等航空器所执行的航班以及乘坐该等航班的人员。\n\n9. 与向债务人、债务人的破产财产、债务人的家庭成员或关联实体提供、由其提供或代表其提供的任何赠与、利益或贷款有关的全部文件，包括但不限于足以显示该等赠与、利益或贷款的金额；该等赠与、利益或贷款的使用目的；提供该等赠与、利益或贷款的时间；以及任何贷款的条款、就任何贷款作出的所有陈述与保证、任何贷款的利率以及任何贷款的所有付款证据的文件。\n\n10. 与由债务人、代表债务人或为债务人、债务人的破产财产、债务人的家庭成员或关联实体之利益设立的任何信托或类似文书有关的全部文件，包括但不限于足以显示该等信托何时设立、由谁设立、为谁的利益设立以及信托财产的文件。\n\n11. 与涉及债务人的任何法律争议相关的任何义务、请求权、责任或债务有关的全部文件，包括但不限于与任何地方、州、联邦或国际机构之前的任何诉讼有关的文件；无论该机构为行政机构、法院、合议庭或替代性争议解决实体。\n\n12. 你方任何外聘律师或其他顾问与债务人之间的全部文件和通讯。\n\n13. 与你方持有或曾持有权益的任何关联实体有关的全部文件。\nCase 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 500 of 1063\n\n14. 与债务人的全部通讯，以及与债务人的通讯有关、涉及任何法人实体（包括但不限于家庭关联实体和关联实体）的运营、管理或决策的文件。\n\nCase 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 501 of 1063\n附件 C-27\nB2540（表格 2540－规则 2004 审查传票）（12/15）Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 502 of 1063\n\n美国破产法院\n\nConnecticut District（康涅狄格区）\n\n关于 HO WAN KWOK（郭文贵）等人案，\n\n1 Case No. 22-50073 (JAM)\n\n债务人 第 11 章\n\n（联合管理）\n规则 2004 审查传票\n\n致：Mimaii NZ Limited（米迈新西兰有限公司）\n\n（传票指向之人员名称）\n\n证言：现命令你方于下列载明的时间、日期和地点出席，并根据《联邦破产程序规则》第 2004 条接受审查并作证。随附授权该审查的法院命令副本。\n\n地点　日期和时间\n\nPaul Hastings LLP（普衡律师事务所）\n200 Park Avenue　[TBD]\nNew York, New York 10166（纽约州纽约市 10166）\n\n审查将通过以下方式记录：法庭记录员／速记员\n\n提交：你方或你方代表还必须在审查时携带下列文件、电子存储信息或物品，并必须允许对该等材料进行检查、复制、测试或抽样：\n见随附的文件提交请求。\n\n下列《联邦民事诉讼规则》第 45 条规定，依据《联邦破产程序规则》第 9016 条适用于破产案件，现随附于后——与履行地点有关的第 45(c) 条；与作为传票对象之人员的保护有关的第 45(d) 条；以及与你方回应本传票的义务及未回应的潜在后果有关的第 45(e) 条和第 45(g) 条。\n\n日期：March , 2023\n\n法院书记官\n\n或\n\n书记官或副书记官签名　律师签名\n\n签发或请求本传票、代表第 11 章受托人 Luc A. Despins（吕克·A·德斯平斯）的律师的姓名、地址、电子邮箱地址和电话号码如下：\n\nDouglas S. Skalka, Esq.（道格拉斯·S·斯卡尔卡律师）；Neubert, Pepe & Monteith, P.C.（纽伯特、佩佩和蒙蒂斯专业公司）；195 Church Street, New Haven, Connecticut 06510 dskalka@npmlaw.com; (203) 821-2000\n\n致签发或请求本传票之人员的通知\n\n如本传票命令在审判前提交文件、电子存储信息或有形物品，或检查场所，则必须在向传票指向之人员送达之前，向每一方当事人送达通知及本传票副本。《联邦民事诉讼规则》第 45(a)(4) 条。\n\n软件版权 (c) 1996-2022 Best Case, LLC - www.bestcase.com Best Case Bankruptcy 1 本第 11 章案件中的债务人为 Ho Wan Kwok（郭文贵，亦称 Guo Wengui、Miles Guo 和 Miles Kwok，以及众多其他别名）（税务识别号码后四位：9595）、Genever Holdings LLC（杰尼弗控股有限责任公司）（税务识别号码后四位：8202）及 Genever Holdings Corporation（杰尼弗控股公司）。受托人、Genever Holdings LLC 和 Genever Holdings Corporation 的邮寄地址为 Paul Hastings LLP, 200 Park Avenue, New York, NY 10166，收件人：Luc A. Despins，作为 Ho Wan Kwok 破产财产的受托人（仅为通知和通讯之目的）。\n送达证明\n\n（除非《联邦民事诉讼规则》第 45 条要求，否则本节不应向法院提交。）\n\n本人于（日期）收到向（个人姓名及职务，如有）发出的本传票。\n\n本人以下列方式向被指定人员交付副本，以送达本传票：\n\n于（日期）；或\n\n本人未执行本传票即予退回，原因如下：\n\n除非本传票代表 United States（美国）或其官员或代理人签发，本人还已向证人支付一天出席费用及法律允许的里程费，金额为 \\$ 。\n\n本人的差旅费用为 \\$ ，服务费用为 \\$ ，合计为 \\$ 。\n\n本人依伪证罪处罚之规定声明，该等信息真实且正确。\n\n日期：\n\n送达人员签名\n\n正楷姓名及职务\n\n送达人员地址\n\n有关尝试送达等的补充信息：\n《联邦民事诉讼规则》第 45(c)、(d)、(e) 和 (g) 条（自 12/1/13 起生效）（依据《联邦破产程序规则》第 9016 条适用于破产案件）\n(c) 履行地点。\n\n(1) 审判、听证或证言录取。传票仅可按下列方式命令人员出席审判、听证或证言录取：\n\n(A) 在该人员居住、受雇或经常亲自从事商业活动地点 100 英里以内；或\n\n(B) 在该人员居住、受雇或经常亲自从事商业活动所在州内，如该人员\n\n(i) 为当事人或当事人的高级职员；或\n\n(ii) 被命令出席审判且不会产生重大费用。\n\n(2) 其他证据开示。传票可以命令：\n\n(A) 在该人员居住、受雇或经常亲自从事商业活动地点 100 英里以内的地点提交文件、电子存储信息或物品；以及\n\n(B) 在拟检查的场所进行场所检查。\n(d) 对作为传票对象之人员的保护；执行。\n\n(1) 避免不当负担或费用；制裁。负责签发和送达传票的当事人或律师必须采取合理步骤，避免给作为传票对象之人员施加不当负担或费用。要求履行的地区法院必须执行该项义务，并对未遵守者的当事人或律师施加适当制裁；该制裁可包括损失的收入和合理的律师费。\n(2) 命令提交材料或允许检查。\n\n(A) 无须出席。被命令提交文件、电子存储信息或有形物品，或允许检查场所的人员，无须亲自到提交或检查地点出席，除非其还被命令出席证言录取、听证或审判。\n\n(B) 异议。被命令提交文件或有形物品，或允许检查的人员，可向传票中指定的当事人或律师送达书面异议，反对对任何或全部材料进行检查、复制、测试或抽样，或反对检查场所，或反对以所要求的一种或多种形式提交电子存储信息。异议必须在规定的履行时间之前或传票送达后 14 日内（以较早者为准）送达。如提出异议，则适用以下规则：\n\n(i) 送达方可随时在通知被命令人员后，向要求履行的地区法院申请命令强制提交或检查。\n\n(ii) 仅可依命令指示要求实施该等行为，并且该命令必须保护既非当事人亦非当事人高级职员的人员，免受因履行而产生的重大费用。\n(3) 撤销或修改传票。\n\n(A) 必须撤销或修改的情形。经及时动议，要求履行的地区法院必须撤销或修改具有下列情形的传票：\n\n(i) 未给予合理履行时间；\n\n(ii) 要求人员在第 45(c) 条规定的地域限制以外履行；\n\n(iii) 要求披露享有特权或受其他保护的事项，且未适用例外或豁免；或\n\n(iv) 使人员承受不当负担。\n\n(B) 可以撤销或修改的情形。为保护作为传票对象或受传票影响的人员，要求履行的地区法院可经动议撤销或修改要求下列事项的传票：\n\n(i) 披露商业秘密或其他保密的研究、开发或商业信息；或\n\n(ii) 披露未经聘用的专家的意见或信息，该等意见或信息并未描述争议中的具体事件，且源于该专家未经当事人请求而进行的研究。\n\n(C) 作为替代方案规定条件。在第 45(d)(3)(B) 条所述情形下，如送达方：\n\n(i) 证明对该证言或材料具有重大需要，且若不造成不当困难则无法以其他方式满足该需要；并且\n\n(ii) 确保被传唤人员将获得合理补偿，\n\n法院可不撤销或修改传票，而命令在规定条件下出席或提交。\n(e) 回应传票的义务。\n\n(1) 提交文件或电子存储信息。下列程序适用于提交文件或电子存储信息：\n\n(A) 文档。对要求提交文档的传票作出回应的人，必须按照文档在正常业务过程中保存的原状提交，或者按照请求中的类别对其进行整理和标注。\n\n(B) 未指定电子存储信息提交形式。如传票未指定电子存储信息的提交形式，作出回应的人必须以其通常保存的一种或多种形式，或者以一种或多种合理可用的形式提交。\n\n(C) 仅以一种形式提交的电子存储信息。作出回应的人无需以超过一种形式提交相同的电子存储信息。\n\n(D) 无法访问的电子存储信息。作出回应的人无需提供来自其认定为因不当负担或费用而无法合理访问的来源的电子存储信息的证据开示。在要求强制证据开示或申请保护令的动议中，作出回应的人必须证明该信息因不当负担或费用而无法合理访问。如作出该证明，法院仍可在请求方证明存在正当理由的情况下，命令对该等来源进行证据开示，并应考虑规则26(b)(2)(C)的限制。法院可规定该证据开示的条件。\n\n(2) 主张特权或保护。\n\n(A) 扣留的信息。以该信息享有特权或作为审判准备材料受保护为由扣留被传唤信息的人，必须：(i) 明确提出该主张；以及\n\n(ii) 以一种不会披露本身享有特权或受保护的信息、但能使各方评估该主张的方式，说明被扣留文档、通信或有形物品的性质。\n\n(B) 已提交的信息。如为回应传票而提交的信息受到特权主张或作为审判准备材料受保护的主张，提出该主张的人可将该主张及其依据通知收到该信息的任何一方。收到通知后，一方必须立即返还、隔离或销毁所指定的信息及其持有的任何副本；在该主张解决之前不得使用或披露该信息；如该方在收到通知前已披露该信息，必须采取合理措施追回该信息；并可立即将该信息密封提交至要求履行义务所在地区的法院，以裁定该主张。提交该信息的人必须保全该信息，直至该主张得到解决。\n\n(g) 藐视法庭。要求履行义务所在地区的法院——以及在动议被移送后，签发传票的法院——可认定已被送达但无充分理由不遵守传票或与之相关命令的人构成藐视法庭。\n\n关于获取传票材料，见 Fed.R.Civ.P.45(a) 委员会注释（2013）\n\n…\n\n文档提交请求\n\nI. 指示\n\n1. 除非另有说明，下列文档请求（以下简称“请求”，每一项以下简称“一项请求”）必须分别且具体地作出回应。每项请求均应得到完整答复，除非基于善意提出异议；在此情形下，应按照下文规定详细说明您提出异议的理由。如异议仅涉及一项请求的一部分，或其中包含的某一词语、短语或条款，您仅须说明对该部分的异议，并对请求的其余部分作出回应。\n\n2. 电子存储信息必须按照以下指示提交：\n\na. 图像。黑白图像必须为300 DPI Group IV单页 TIFF 文件。彩色图像必须以 JPEG 格式提交。文件名不得包含嵌入空格或特殊字符（包括逗号）。文件夹名称不得包含嵌入空格或特殊字符（包括逗号）。所有 TIFF 图像文件必须具有唯一的文件名，即 Bates 编号。每幅图像的右下角必须加注连续的 Bates 编号。每个文件夹中的 TIFF 文件数量不应超过1000个文件。Excel 电子表格应具有以该文件 Bates 编号命名的占位图像。\n\nb. 图像加载文件\n\na. Concordance® 数据文件。数据文件（.DAT）包含将被加载到 Concordance® 数据库中的全部字段化信息。.DAT 文件的第一行必须为标明字段名称的标题行。.DAT 文件必须使用以下 Concordance® 默认分隔符：逗号 ASCII 字符（020） 引号 þ ASCII 字符（254）。日期字段应采用以下格式提供：mm/dd/yyyy。日期和时间字段必须为两个独立字段。如文档包括图像化电子邮件及附件，必须包括附件字段，以保留电子邮件与其附件之间的父/子关系。必须包括 OCRPATH 字段，以提供所提交存储介质上提取文本文件的文件路径和名称。文本文件必须以 FIRSTBATES 命名。不得在 .DAT 文件中包含文本。对于包含原生文件的文档，必须包括 LINK 字段，以提供原生文件的文件路径和名称。原生文件必须以 FIRSTBATES 命名。\n\nb. Concordance Image® 或 Opticon 交叉引用文件。图像交叉引用文件（.LOG 或 .OPT）将图像链接至数据库记录。其应为逗号分隔的文件，每行由七个字段构成，并且数据库中的每幅图像均应在交叉引用文件中有一行，格式如下：ImageID,VolumeLabel,ImageFilePath,DocumentBreak,FolderBreak,Box Break,PageCoun。\n\nc. 文档文本。文本必须作为单独的文本文件提交，而非作为 .DAT 文件中的字段。应在 .DAT 文件中包含文本文件的完整路径（OCRPATH）。建议提供以 FIRSTBATES/Image Key 命名的文档级 ANSI 文本文件。提取的文本文件必须置于单独文件夹中，每个文件夹中的文本文件数量不应超过1,000个文件。文件夹名称中不得有特殊字符（包括逗号）。必须在文档级别提供文本文件。\n\nd. 特定文件类型的原生提交。为充分理解其内容和含义而合理需要以原生格式查看的文件类型，必须以原生格式提交。这些文件包括但不限于电子表格、类似电子表格的文件（Microsoft Excel、逗号分隔值、制表符分隔值等）、Microsoft PowerPoint 或其他特殊演示文件、数据库文件及音频/视频文件。应提供一张带有 Bates 编号的分隔页图像，表明原生文件的存在，并在 .dat 文件中以字段形式包括原生文件的路径。所提交的原生文件应以与该文件分隔页相对应的 Bates 编号命名。原生文件应集中置于按顺序命名的“NATIVE”目录中，并与图像目录分开。\n\ne. 去重。对于存在完全重复件的每一电子文档，提交一份副本。对于电子邮件，应根据从 BCC、Body、CC、From、IntMsgID、To 和 Attach 属性生成的 MD5 哈希值合并重复件。对于电子邮件附件和独立电子文件，应根据整个文件的 MD5 哈希值合并重复件。\n\nf. 元数据。以符合 Concordance 的加载文件（.dat）形式提交每份文档的提取元数据。.DAT 文件的第一行必须为标明字段名称的标题行。.DAT 文件必须使用以下 Concordance 默认分隔符：逗号 , ASCII 字符（020） 引号 þ ASCII 字符（254）\n\n日期字段应采用以下格式提供：mm/dd/yyyy。日期和时间字段必须为两个独立字段。以下列出所需元数据：\nCase 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 507 of 1063\n\n字段名称　示例数据　说明\n\nFIRSTBATES　EDC0000001　原生文件文档/电子邮件的首个 Bates 编号\nLASTBATES　EDC0000001　原生文件文档/电子邮件的最后一个 Bates 编号\nLASTBATES 字段应针对单页填写\nATTACHRANGE　EDC0000001\n-　父文档第一页的 Bates 编号至最后一个附件“子”文档最后一页的 Bates 编号\nEDC0000015\nBEGATTACH　EDC0000001　附件范围的首个 Bates 编号\nENDATTACH　EDC0000015　附件范围的最后一个 Bates 编号\nCUSTODIAN　Smith, John　电子邮件：该电子邮件所在的邮箱\n原生文件：文档源自其文件的个人或部门名称\nFROM　John Smith　电子邮件：发件人\n原生文件：文档作者\n应使用分号分隔多个条目\nTO　Coffman, Janice; LeeW　收件人\n[mailto:LeeW@MSN.com]　应使用分号分隔多个条目\nCC　Frank Thompson [mailto:　抄送收件人\nfrank_Thompson@cdt.com]　应使用分号分隔多个条目\nBCC　John Cain　密送收件人\n应使用分号分隔多个条目\nSUBJECT　Board Meeting Minutes　电子邮件：电子邮件主题行 原生文件：文档标题（如有）\nFILE_NAME　BoardMeetingMinutes.docx　原生文件：原始原生文件的名称，包括扩展名\nDATE_SENT　10/12/2010　电子邮件：电子邮件发送日期\n原生文件：（空）\nTIME_SENT/　07:05 PM GMT　电子邮件：电子邮件发送时间/电子邮件在其中被标准化的时区\nTIME_ZONE\nTIME_ZONE　GMT　在转换过程中电子邮件被标准化所使用的时区。\nLINK　EDC0000001.msg　电子邮件或原生文件文档的超链接\n链接文件必须以 FIRSTBATES 编号命名\nFILE_EXTEN　MSG　表示电子邮件或的文件类型扩展名\nAUTHOR　John Smith　电子邮件：（空）\n原生文件：文档作者\nDATE_CREATED　10/10/2010　电子邮件：（空）\n原生文件：文档创建日期\nCase 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 508 of 1063\n\nTIME_CREATED　10:25 AM　电子邮件：（空）\n原生文件：文档创建时间\n该数据必须为独立字段，且不得与 DATE_CREATED 字段合并\nDATE_MOD　10/12/2010　电子邮件：（空）\n原生文件：文档最后修改日期\nTIME_MOD　07:00 PM　电子邮件：（空）\n原生文件：文档最后修改时间\n该数据必须为独立字段，且不得与 DATE_MOD 字段合并\nDATE_ACCESSD　10/12/2010　电子邮件：（空）\n原生文件：文档最后访问日期\nTIME_ACCESSD　07:00 PM　电子邮件：（空）\n原生文件：文档最后访问时间\n该数据必须为独立字段，且不得与 DATE_ACCESSD 字段合并\nFILE_SIZE　5,952　原生文件文档/电子邮件的大小，以 KB 计\nPGCOUNT　1　原生文件文档/电子邮件的页数\nPATH　电子邮件：（空）\nAgenda.doc　原生文件：保存原生文件文档的路径，包括原始文件名称。\nINTFILEPATH　Personal Folders\\Deleted　电子邮件：电子邮件的原始位置，包括原始文件名称。\nItems\\Board Meeting\nMinutes.msg　原生文件：（空）\nINTMSGID　<000805c2c71b\\$75977050\\$　电子邮件：唯一消息 ID 原生文件：（空）\ncb8306d1@MSN>\nMD5HASH　d131dd02c5e6eec4693d9a0　文档的 MD5 哈希值。\n698aff95c\n2fcab58712467eab4004583e\nb8fb7f89\nOCRPATH　TEXT/001/EDC0000001.txt　原生文件提取文本的路径\n\n3. 每项请求独立运作并应被独立解释，且除非另有说明，任何请求均不限制其他任何请求的范围。\n\n4. 所有文档均应按照在通常业务过程中保存的原状提交，或应加以整理和标注以对应这些请求中的类别。\n\n5. 本文所载每项请求均延及以下所有文档：(a) 由您占有、保管或控制的文档；或 (b) 由代表您行事的任何人占有、保管或控制的文档，\nCase 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 509 of 1063\n\n包括您的律师或其他代表和顾问。每份文档均应完整提交。\n\n6. 如要求贵方提供已不再由贵方占有、保管或控制的文件，则贵方的答复必须：(a) 详细说明该文件的性质及其内容；(b) 指明编制或撰写该文件的人员（以及，如适用，该文件发送给的人员）；(c) 指明该文件编制或创建的日期；(d) 说明该文件是否：(i) 遗失或丢失；(ii) 已被销毁；(iii) 已自愿或非自愿地转交给他人；或 (iv) 以其他方式处置；(e) 说明该等处置的理由，以及与该等处置有关的事实和情形；(f) 指明授权该等处置的人员；(g) 指明该等处置的日期或大致日期；(h) 说明该文件最近一次由贵方占有、保管或控制的时间；以及 (i) 指明目前占有、保管或控制该文件的人员（如有）。\n\n7. 如要求贵方提供已被销毁的文件，则除前述指示所要求的信息外，贵方的答复还必须说明：(a) 销毁该文件的理由；(b) 销毁该文件的人员身份；以及 (c) 指示销毁该文件的人员身份。\n\n8. 如贵方主张所要求的文件享有特权或属于律师工作成果，则贵方的答复必须：(a) 说明：(i) 足以支持贵方关于该文件享有特权之主张的文件描述，(ii) 文件标题，(iii) 文件日期，(iv) 文件作者，(v) 文件收件人，(vi) 收到或阅览该文件原件或任何草稿、副本或复制件的每一人员身份，(vii) 该文件本身或该文件所载或提及的任何信息是否由任何其他人员占有、保管或控制，如是，则该等人员的身份，以及说明该等信息如何进入其占有范围的陈述，(viii) 据以扣留该文件的特权主张，以及 (ix) 贵方将据以支持该等特权主张的所有情形；以及 (b) 就每一份基于特权主张而被扣留的文件，根据 D. Conn. L. Civ. R. 26(e)，提供一份载有本指示第 (a) 部分所要求全部信息的特权日志。\n\n案件 22-50073 文书 1592 提交于 03/24/23 录入于 03/24/23 10:57:37 第 510 页，共 1063 页\n\n9. 如一份本应响应要求的文件中有部分内容包含受特权主张约束的信息，则仅应按照上述指示从该文件中删除或涂黑受特权主张约束的部分，其余部分应予提供。\n\n10. 本文件请求具有持续性。现指示贵方：(a) 一旦知悉先前答复不完整或不正确，应立即补充或更正其后发现不完整或不正确的任何答复；以及 (b) 提供根据下列规定所要求的任何补充文件。\n\n11. 如文件使用英语以外的语言，贵方应提供该文件。如文件使用英语以外的语言，且存在英文译本，贵方应同时提供两份文件。\n\n12. 对实体的所有提及均包括其所有关联方。\n\n13. 对个人姓名的所有提及均包括所有别名、化名或昵称。\n\n14. 除非另有明确说明，文件请求所涵盖的期间为自 February 5, 2012 起至文件请求答复到期之日止。\n\n案件 22-50073 文书 1592 提交于 03/24/23 录入于 03/24/23 10:57:37 第 511 页，共 1063 页\n\nII. 解释规则\n\n15. (a) 任何单数名词的使用应解释为包括复数，反之亦然；以及 (b) 任何时态动词的使用应解释为包括该动词所有其他时态的使用。\n\n16. (a) “和”及“或”应视为必要时以连词关系或选择关系解释，以使本可被解释为不在任何请求范围内的所有答复均纳入该请求范围；以及 (b) “每一”及“任何”应被视为包括并涵盖“每个”及“全部”二词。\n\nIII. 定义\n\n根据 D. Conn. Bankr. L.R. 2004-1(a) 纳入的 D. Conn. L. Civ. R. 26(c) 所提供的定义，以及 D. Conn. L. Civ. R. 26(d) 所提供的解释规则，适用于文件请求。此外，本文件请求中使用的下列术语具有下列含义：\n\n1. “贵方”或“贵方自身”系指 Mimaii NZ Limited（Mimaii NZ有限公司），连同其所有关联方、部门、机构、职能部门、科室、办公室、合伙人、高级管理人员、董事、代理人、律师、代表、雇员，及／或任何代表其行事的人。\n\n2. “债务人”系指 Ho Wan Kwok（郭文贵）（又名 Miles Kwok、Miles Guo、Guo Wengui、Guo Haoyun、郭文贵，或任何其他别名），连同其雇员、代理人、律师、顾问，或任何代表其行事的人。\n\n3. “债务人之子”系指 Qiang Guo（郭强）（又名 Mileson Kwok、郭强，或任何其他别名），连同其雇员、代理人、律师、顾问，或任何代表其行事的人。\n\n案件 22-50073 文书 1592 提交于 03/24/23 录入于 03/24/23 10:57:37 第 512 页，共 1063 页\n\n4. “债务人之女”系指 Mei Guo（郭美）（又名 Mei Gui、郭美，或任何其他别名），连同其雇员、代理人、律师、顾问，或任何代表其行事的人。\n\n5. “债务人声称的妻子”系指 Hing Chi Ngok（岳庆芝）（又名 Hing Chi Ng、Yue Qingzhi、岳庆芝，或任何其他别名），连同其雇员、代理人、律师、顾问，或任何代表其行事的人。\n\n6. “债务人家庭成员”统称债务人、债务人之子、债务人之女及债务人声称的妻子，以及与债务人有任何其他亲属关系的人。\n\n7. “关联个人”系指个别及共同而言，所有符合下列任一情形的个人：(1) 持有、控制、保管或对债务人或债务人家庭成员所拥有、控制或享有的资产拥有酌处权；或 (2) 曾为一个或多个关联实体的雇员、董事，或以其他方式与一个或多个关联实体有关联，连同前述各方各自的雇员、代理人、律师、顾问，或任何代表前述任何一方行事的人。该等关联个人包括但不限于：Daniel Podhaskie（丹尼尔·波达斯基）、Jason Miller（贾森·米勒）、Steve Bannon（史蒂夫·班农）、Karin Maistrello（卡琳·迈斯特雷洛）、Melissa Francis（梅丽莎·弗朗西斯）、Anthony DiBattista（安东尼·迪巴蒂斯塔）、William Gertz（威廉·格茨）、Arethusa Forsyth（阿瑞苏莎·福赛思）、Glenn Mellor（格伦·梅勒）、Jennifer Mercurio（詹妮弗·默库里奥）、Eduardo Eurnekian（爱德华多·欧尔内基安）、Wencong Wang（王文聪）、Han Chunguang（韩春光）（又名 韩春光）、Qu Guojiao（屈国姣）（又名 Qu Guo Jiao、屈国姣）、Guo Lijie（郭丽杰）（又名 郭丽杰）、Zhang Wei（张伟）（又名 张伟*）、Lihong Wei Lafrenz（魏丽红）（又名 Sara Wei、魏丽红）、Hao Haidong（郝海东）（又名 郝海东）、Ross Heinemeyer（罗斯·海内迈耶）、Max Krasner（马克斯·克拉斯纳）、Kyle Bass（凯尔·巴斯）、Melissa Mendez（梅丽莎·门德斯）、Ya Li（李娅）（又名 李娅）、Dinggang Wang（王定刚）（又名 王定刚）、An Hong（安红）（又名 安红）、Yvette Wang（王雁平）（又名 Yanping Wang、Yan Ping Wang、王雁平）、Fiona Yu（菲奥娜·余）、Je Kin Ming（余建明）（又名 William Je、Yu Jianming、余建明）、Yaz Qingua（亚兹·青瓜）及 Lao Jiang（姜云浮）（又名 Jiang Yunfu、Jiang Yunfu Be、姜云浮）。\n\n案件 22-50073 文书 1592 提交于 03/24/23 录入于 03/24/23 10:57:37 第 513 页，共 1063 页\n\n8. “关联实体”系指个别及共同而言，所有符合下列任一情形的各类组织或实体：(1) 曾由债务人或债务人家庭成员拥有、控制或投资；或 (2) 对债务人或债务人家庭成员所拥有、控制或享有的任何资产直接或间接拥有权益，连同前述各方各自的雇员、代理人、律师、顾问，或任何代表前述任何一方行事的人。该等关联实体包括但不限于：7 Nod Hill LLC（7诺德山有限责任公司）、AAGV Limited（AAGV有限公司）、ACA Investment Management Limited（ACA投资管理有限公司）、ACA Capital Group Limited（ACA资本集团有限公司）、Ace Decade Holdings Limited（艾斯十年控股有限公司）、AI Group Holdings Inc.（AI集团控股公司）、Alfa Global Ventures Limited（阿尔法全球创投有限公司）、Alfonso Global Limited（阿方索全球有限公司）、Allied Capital Global Limited（联合资本全球有限公司）、Alpine Fiduciaries SA（阿尔卑斯受托人SA）、Anton Development Limited（安东开发有限公司）、Assets Sino Limited（中资资产有限公司）、Auspicious Coast Limited（吉祥海岸有限公司）、Beijing Pangu Investment Co.（北京盘古投资公司）、Beijing Pangu Investment Co. Ltd.（北京盘古投资有限公司）、Beijing Pangu Investment Inc.（北京盘古投资公司）、Beijing Zenith Holdings Company Limited（北京泽尼思控股有限公司）、Booming Sail New York LLC（纽约兴帆有限责任公司）、Bravo Luck Limited（好运有限公司）、BSA Strategic Fund I（BSA战略基金I）、China Golden Spring (Hong Kong) Limited（中国金泉〈香港〉有限公司）、Chuang Xin Limited（创新有限公司）、Crane Advisory Group LLC（克兰咨询集团有限责任公司）、Creative Apex Investments Limited（创意顶峰投资有限公司）、Crystal Breeze Investments Limited（水晶微风投资有限公司）、Dawn State Limited（黎明州有限公司）、Eastern Profit Corporation Limited（东方利润有限公司）、Elite Well Global Limited（精英环球有限公司）、Empire Growth Holdings（帝国增长控股）、Freedom Media Ventures Ltd.（自由媒体创投有限公司）、G Club Operations LLC（G俱乐部运营有限责任公司）、G Fashion LLC（G时尚有限责任公司）、G News LLC（G新闻有限责任公司）、GETTR USA（GETTR美国）、Genever Holdings Corporation（Genever控股公司）、Genever Holdings LLC（Genever控股有限责任公司）、Gfashion Media Group Inc.（G时尚媒体集团公司）、GFNY, Inc.（GFNY公司）、Globalist International Limited（环球主义者国际有限公司）、GNews Media Group Inc.（G新闻媒体集团公司）、Golden Spring (New York) Ltd.（金泉〈纽约〉有限公司）、Greenwich Land LLC（格林尼治土地有限责任公司）、Guo Media（郭媒体）、GTV Media Group, Inc.（GTV媒体集团公司）、Hamilton Capital Holdings Inc.（汉密尔顿资本控股公司）、HCHK Property Management, Inc.（HCHK物业管理公司）、HCHK Technologies, Inc.（HCHK科技公司）、Head Win Group Limited（领赢集团有限公司）、Henan Yuda（河南裕达）、Himalaya Embassy（喜马拉雅大使馆）、Himalaya Exchange（喜马拉雅交易所）、Himalaya Federal Reserve（喜马拉雅联邦储备）、Himalaya Investment LLC（喜马拉雅投资有限责任公司）、Himalaya International（喜马拉雅国际）、Himalaya New World Inc.（喜马拉雅新世界公司）、Himalaya Supervisory Organization（喜马拉雅监督组织）、Himalaya Ventures LLC（喜马拉雅创投有限责任公司）、HK International Funds Investments (USA) Limited LLC（香港国际基金投资〈美国〉有限责任公司）、Hong Kong International Funds\n\n案件 22-50073 文书 1592 提交于 03/24/23 录入于 03/24/23 10:57:37 第 514 页，共 1063 页\n\nInvestments Limited（香港国际基金投资有限公司）、Hudson Diamond Holding（哈德逊钻石控股）、Infinite Increase Limited（无限增长有限公司）、Infinitum Developments Limited（无限开发有限公司）、Infinity Treasury Management Inc.（无限国库管理公司）、Insight Phoenix Fund（洞察凤凰基金）、Lamp Capital LLC（兰普资本有限责任公司）、Leading Shine Limited（领耀有限公司）、Leading Shine NY Limited（领耀纽约有限公司）、Lexington Property and Staffing（列克星敦物业与人力派遣）、Long Gate Limited（龙门有限公司）、Maywind Trading LLC（五月风贸易有限责任公司）、MOS Himalaya LLC（MOS喜马拉雅有限责任公司）、Next Tycoon Investments Limited（下一大亨投资有限公司）、New Federal State of China（新中国联邦）（又名 NFSC）、Noble Fame Global Limited（高名环球有限公司）、Rosy Acme Ventures Limited（玫瑰顶峰创投有限公司）、Rule of Law Foundation III, Inc.（法治基金会III公司）、Rule of Law Foundation IV, Inc.（法治基金会IV公司）、Rule of Law Fund（法治基金）、Rule of Law Society（法治协会）、Rule of Law Society IV, Inc.（法治协会IV公司）、G-Translators PTY LTD（G翻译者有限公司）、Saraca Media Group, Inc.（萨拉卡媒体集团公司）、Shiny Ace Ltd.（闪耀王牌有限公司）、Shiny Times Holdings Ltd.（闪耀时代控股有限公司）、Spirit Charter Investment Limited（精神宪章投资有限公司）、Stevenson, Wong & Co.（史蒂文森、黄及公司）、Voice of Guo Media, Inc.（郭媒体之声公司）、Well Origin Ltd.（良源有限公司）、World Century Limited（世界世纪有限公司）、Worldwide Opportunity Holdings Limited（全球机遇控股有限公司）、Whitecroft Shore Limited（怀特克罗夫特海岸有限公司）及 ZIBA Limited（ZIBA有限公司）。\n\n9. “包括”或其任何变体，系指“包括但不限于”。\n\n10. “和”及“或”系指“和／或”，并应同时按连词关系及选择关系解释，以最大限度扩大其范围。\n\n11. “任何”、“全部”及“每一”均系指“每一个”。\n\n12. “每一”及“每个”均系指“每一个”。\n\n13. “第三方”系指贵方自身以外的个人或实体。\n\n14. “转让”具有《破产法》section 101(54) 赋予该词的含义。\n\n15. “文件”系指属于 Fed. R. Civ. P. 34 范围内的任何信息或物品，包括但不限于贵方占有、保管或控制中的、或曾由贵方占有、保管或控制的各种、各类、任何性质或描述的每一书面、记录或图形材料，包括电子邮件的所有印刷及电子副本、保存在计算机文件中的\n\n电子形式、电子通信、短信、社交媒体帖子、推文、元数据、函件、备忘录、录音带、速记笔记或手写笔记、任何种类的书面表格、图表、蓝图、绘图、草图、曲线图、计划、文章、规格、日记、信件、电报、照片、会议记录、合同、协议、调查、计算机打印件、任何种类的数据汇编、电传、传真、语音留言、发票、订单表格、支票、汇票、结算单、贷项通知单、报告、立场报告、摘要、索引、书籍、账簿、笔记本、日程表、透明胶片、录音、目录、广告、宣传材料、胶片、录像带、录音带、CD、计算机磁盘、宣传册、小册子、穿孔卡、工时单、推文、社交媒体帖子，或任何其他种类的书面或录制材料，以及其全部元数据，无论以何种方式储存（无论为有形形式或电子形式）、记录、制作或复制，且还包括但不限于上述任何材料的草稿或副本，如该等草稿或副本载有原始文件中未见的任何种类的笔记、评论或标记，或在其他方面与原始文件不相同。\n\n16. “人员”是指个人、公司、独资企业、合伙企业、协会或任何其他实体。“人员”还包括任何代理人、代表或专家，包括但不限于律师或财务顾问。\n\n17. “实体”是指任何自然人、公司、合伙企业、子公司、独资企业、商号、董事会、合资企业、协会、机构、主管机关、委员会或其他商业实体或法人，以及任何关联方、代理人、母公司，包括但不限于法律顾问、财务顾问或任何其他代表。\n\n18. “关于”是指涉及、描述、构成、提及、与之相关、支持、赞成、反对、强化、削弱、位于、结合考虑、对……有影响、证明、表明、报告、记录、暗指、回应，\n案件 22-50073 文书 1592 提交日期 03/24/23 录入日期 03/24/23 10:57:37 第 516 页，共 1063 页\n\n与之相连、评论、就……而言、关于、与……有关、讨论、显示、描述、反映、分析、构成以及属于。\n\n19. 在提及任何特定事项时，“与……相关”“相关”或“有关”是指，不受限制地，构成、包含、涉及、含有、体现、反映、识别、陈述、直接或间接提及该特定事项，或以任何方式与所识别的特定事项有关的任何文件。\n\n20. “通信”在最广泛的意义上且不受限制地，是指任何信息或知识的传递（以事实、观点、询问或其他形式）。通信还指所有谈话、协议、询问或答复，无论是当面、通过电话、书面方式，或借助电子传输设备进行，并包括但不限于所有函件、电子邮件、录音、传送单、备忘录、电话通信、语音留言、电报、传真、电传、即时消息、聊天记录、短信、电话笔记，或在内部或与第三方之间传送的笔记。\n\n21. “资产”是指任何可用于产生正面经济价值的项目，包括但不限于由某一实体拥有、控制或使其受益，并预期提供未来利益的任何具有经济价值的资源，包括但不限于所有不动产和动产、无形财产、投资、投资权利或未来收入权利、现金、银行账户、商品、证券、债权、对某一实体的全部或部分控制权，以及预期的经济机会。\n\n22. “转让”应具有《破产法》第 101(54) 条赋予该词的含义。\n\n四、应提交的文件\n\n1. 与债务人、债务人财产或关联实体的任何收入或资产有关的全部文件。\n\n2. 与债务人的财务状况及其对债权人所负义务有关的全部文件，包括但不限于与任何试图避免偿付该等义务的行为有关的全部文件，以及与本次或任何其他实际或潜在破产或类似资不抵债程序有关的全部文件。\n\n3. 与债务人、债务人财产、债务人家属、关联实体或关联个人有关的任何资产负债表、银行对账单、账户对账单、财务报表、账目报表、电汇指示及／或确认函、资金证明、存款证明、持仓证明、投资组合摘要或类似文件有关的全部文件，包括但不限于足以显示向上述任何一方进行的全部转让的文件。\n\n4. 与债务人作出、与债务人进行或代表债务人作出的任何投资、商业交易或交易有关的全部文件。\n\n5. 与债务人之间的全部通信，以及与债务人之间通信有关的文件，该等通信涉及任何实体的运营、管理或决策，包括但不限于关联实体。\n\n6. 与向债务人、由债务人或与债务人、债务人家属或关联实体进行的任何转让、投资或其他交易或商业往来有关的全部文件。\n\n7. 与债务人曾占用或使用的任何财产有关的全部文件，包括但不限于 Lady May（梅夫人号）；Sherry Netherland Hotel / Condominium（雪莉荷兰酒店／公寓）；位于康涅狄格州格林尼治 373 Taconic Rd. 的住宅物业；位于康涅狄格州格林尼治 33 Ferncliff Rd. 的住宅物业；以及位于康涅狄格州威尔顿 354 Nod Hill Rd. 的住宅物业。\n案件 22-50073 文书 1592 提交日期 03/24/23 录入日期 03/24/23 10:57:37 第 518 页，共 1063 页\n\n8. 与债务人拥有、控制或使用的任何航空器有关的全部文件，包括但不限于尾号为 T7-GQM 的航空器以及在圣马力诺登记的任何其他航空器，包括但不限于所有登记文件的副本，以及显示该等航空器所执行航班及该等航班机上人员的飞行清单。\n\n9. 与向债务人、债务人财产、债务人家属或关联实体提供、由其提供或代表其提供的任何赠与、利益或贷款有关的全部文件，包括但不限于足以显示该等赠与、利益或贷款的金额；该等赠与、利益或贷款的用途；提供该等赠与、利益或贷款的时间；以及任何贷款的条款、就任何贷款作出的所有陈述和保证、任何贷款的利率及任何贷款全部付款证据的文件。\n\n10. 与由债务人、代表债务人或为债务人、债务人财产、债务人家属或关联实体的利益而设立的任何信托或类似文书有关的全部文件，包括但不限于足以显示该等信托何时设立、由何人设立、为谁的利益而设立及信托本金的文件。\n\n11. 与涉及债务人的任何法律争议相关的任何义务、债权、责任或债务有关的全部文件，包括但不限于与在任何地方、州、联邦或国际机构面前进行的任何诉讼有关的文件，无论该机构为行政机构、法院、合议庭或替代性争议解决实体。\n案件 22-50073 文书 1592 提交日期 03/24/23 录入日期 03/24/23 10:57:37 第 519 页，共 1063 页\n\n12. 贵方的任何外部法律顾问或其他顾问与债务人之间的全部文件和通信。\n\n13. 足以显示贵方全部资产以及收入或资金来源的文件。\n\n14. 对于为回应请求第 14 项而识别出的、价值超过 \\$50,000 的全部资产：（i）与贵方取得该等资产有关的全部文件；以及（ii）与债务人或债务人家属就该等资产进行的通信。\n\n15. 贵方纳税申报表的副本。\n\n16. 足以显示由贵方持有或控制的全部银行账户和投资账户的文件，包括每一该等账户的余额及向其转入和从其转出的款项。\n\n17. 与贵方使用的任何信用卡有关的全部文件，包括但不限于月度对账单或足以显示为债务人或关联实体利益而作出的与此有关全部购买的其他文件。\n\n18. 全部公司治理和组织文件，包括但不限于章程细则、公司设立证明以及足以显示贵方公司结构、高管和董事姓名、经营目的及与债务人或债务人任何家属关系的其他文件。\n\n19. 与贵方向任何其他实体质押任何资产有关的全部文件。\n\n案件 22-50073 文书 1592 提交日期 03/24/23 录入日期 03/24/23 10:57:37 第 520 页，共 1063 页\n\n附件 C-28\n\nB2540（表格 2540——规则 2004 审查传票）（12/15）案件 22-50073 文书 1592 提交日期 03/24/23 录入日期 03/24/23 10:57:37 第 521 页，共\n\n美国破产法院\n\n康涅狄格州地区\n\n关于 HO WAN KWOK（郭文贵）等人，\n\n1 案件编号 22-50073 (JAM) 债务人 第 11 章\n\n（合并管理）\n\n规则 2004 审查传票\n\n致：Tong Le International Trading Co., Ltd.（通乐国际贸易有限公司）\n\n（传票所指向人员的姓名）\n\n证言：兹命令贵方在下列规定的时间、日期和地点出席，并根据《联邦破产程序规则》规则 2004 就审查作证。随附授权进行该审查的法院命令副本。\n\n地点　日期和时间\n\nPaul Hastings LLP（保尔·黑斯廷斯律师事务所）\n200 Park Avenue　[TBD]\nNew York, New York 10166（纽约州纽约市 10166）\n\n审查将通过以下方式记录：法庭记录员／速记员\n\n提交：贵方或贵方代表还必须携带下列文件、电子存储信息或物件出席审查，并必须允许对该等材料进行查验、复制、测试或取样：\n\n见随附的文件提交请求。\n\n《联邦民事诉讼规则》规则 45 的下列规定，经《联邦破产程序规则》规则 9016 适用于破产案件，现随附于后——关于履行地点的规则 45(c)；关于贵方作为受传票约束人员之保护的规则 45(d)；以及关于贵方回应本传票的义务和未予回应的潜在后果的规则 45(e) 和 45(g)。\n\n日期：March , 2023\n\n法院书记官\n\n或\n\n书记官或副书记官签名　律师签名\n\n签发或请求本传票、代表第 11 章受托人 Luc A. Despins（吕克·A·德斯平）的律师姓名、地址、电子邮件地址和电话号码如下：\n\nDouglas S. Skalka, Esq.（道格拉斯·S·斯卡尔卡律师）；Neubert, Pepe & Monteith, P.C.（诺伊伯特、佩佩和蒙蒂思律师事务所）；195 Church Street, New Haven, Connecticut 06510；dskalka@npmlaw.com；(203) 821-2000\n\n致签发或请求本传票的人员的通知\n\n如本传票命令在审判前提交文件、电子存储信息或有形物品，或查验场所，则必须在向传票所指向人员送达之前，向每一方当事人送达通知及本传票副本。Fed. R. Civ. P. 45(a)(4)。\n\n软件版权 (c) 1996-2022 Best Case, LLC - www.bestcase.com Best Case Bankruptcy 1 本第 11 章案件中的债务人为 Ho Wan Kwok（郭文贵，亦称 Guo Wengui、Miles Guo 和 Miles Kwok，以及众多其他别名）（税务识别号码后四位：9595）、Genever Holdings LLC（税务识别号码后四位：8202）以及 Genever Holdings Corporation。受托人、Genever Holdings LLC 和 Genever Holdings Corporation 的邮寄地址为 Paul Hastings LLP, 200 Park Avenue, New York, NY 10166，转交 Luc A. Despins，作为 Ho Wan Kwok 财产的受托人（仅为通知和通信之目的）。\n\n送达证明\n\n（除非 Fed. R. Civ. P. 45 要求，否则本节不应向法院提交。）\n\n本人于（日期）收到向（个人姓名及职务，如有）发出的本传票。\n\n本人已按以下方式将传票副本交付给被指名人，从而送达本传票：\n\n于（日期）；或者\n\n本人未予执行而退回本传票，原因如下：\n\n除非本传票系代表美国或其官员或代理人发出，本人还已向证人支付一天出席费用及法律允许的里程费，金额为 \\$。\n\n本人的差旅费用为 \\$，服务费用为 \\$，合计为 \\$。\n\n本人在伪证罪处罚的约束下声明，本信息真实、准确。\n\n日期：\n\n送达人签名\n\n正楷姓名及职务\n\n送达人地址\n\n关于尝试送达等的补充信息：\n《联邦民事诉讼规则》第45(c)、(d)、(e)和(g)条（2013年12月1日生效）（根据《联邦破产程序规则》第9016条适用于破产案件）\n(c) 履行地点。\n\n(1) 审判、听证或证言录取。传票仅可按以下规定命令某人出席审判、听证或证言录取：\n\n(A) 在该人居住、受雇或经常亲自从事营业活动地点100英里以内；或者\n\n(B) 在该人居住、受雇或经常亲自从事营业活动所在州内，前提是该人：\n\n(i) 为当事人或当事人的高级职员；或者\n\n(ii) 被命令出席审判且不会产生重大费用。\n\n(2) 其他证据开示。传票可命令：\n\n(A) 在该人居住、受雇或经常亲自从事营业活动地点100英里以内的地点提交文件、以电子方式存储的信息或物品；以及\n\n(B) 在待检查的不动产处检查不动产。\n(d) 保护受传票约束的人；执行。\n\n(1) 避免不当负担或费用；制裁。负责发出和送达传票的当事人或律师必须采取合理措施，避免对受传票约束的人施加不当负担或费用。要求履行义务的地区的法院必须执行该义务，并对未遵守者的当事人或律师施加适当制裁，该制裁可包括损失的收入和合理的律师费。\n(2) 命令提交材料或允许检查。\n\n(A) 无须出庭。被命令提交文件、以电子方式存储的信息或有形物品，或允许检查不动产的人，无须亲自到提交或检查地点出庭，除非其同时被命令出席证言录取、听证或审判。\n\n(B) 异议。被命令提交文件或有形物品，或允许检查的人，可向传票中指定的当事人或律师送达书面异议，反对检查、复制、测试或抽样任何或全部材料，或反对检查不动产，或反对以所要求的一种或多种形式提交以电子方式存储的信息。异议必须在指定履行时间或传票送达后14日中较早者之前送达。如提出异议，适用下列规则：\n\n(i) 送达方可随时在通知被命令人后，向要求履行义务的地区的法院提出动议，请求作出强制提交或检查的命令。\n\n(ii) 仅可依照命令所指示的方式要求实施这些行为，且该命令必须保护非当事人或非当事人高级职员的人免受因履行而产生的重大费用。\n(3) 撤销或修改传票。\n\n(A) 必须撤销或修改的情形。经及时动议，要求履行义务的地区的法院必须撤销或修改以下传票：\n\n(i) 未给予合理履行时间；\n\n(ii) 要求某人在第45(c)条规定的地域限制之外履行；\n\n(iii) 要求披露享有特权或受其他保护的事项，且不适用任何例外或弃权；或者\n\n(iv) 对某人施加不当负担。\n\n(B) 可以撤销或修改的情形。为保护受传票约束或受其影响的人，若传票要求：\n\n(i) 披露商业秘密或其他保密的研究、开发或商业信息；或者\n\n(ii) 披露未经聘任的专家的意见或信息，且该意见或信息并未描述争议中的具体事件，并且源自该专家未经任何当事人请求而进行的研究，\n\n要求履行义务的地区的法院可依动议撤销或修改传票。\n\n(C) 以规定条件作为替代办法。在第45(d)(3)(B)条所述情形下，如送达方：\n\n(i) 证明其对该证言或材料具有重大需求，且如不遭受不当困难即无法以其他方式满足该需求；并且\n\n(ii) 确保被传唤人将获得合理补偿，\n\n法院可不撤销或修改传票，而命令在规定条件下出庭或提交材料。\n(e) 回应传票的义务。\n\n(1) 提交文件或以电子方式存储的信息。下列程序适用于提交文件或以电子方式存储的信息：\n\n(A) 文件。回应提交文件传票的人必须按文件在正常业务过程中保存的方式提交，或者必须将其整理并标记为与请求中的类别相对应。\n\n(B) 未指定提交以电子方式存储的信息的形式。如传票未指定提交以电子方式存储的信息的形式，回应人必须以其通常保存的一种或多种形式，或以合理可用的一种或多种形式提交。\n\n(C) 以电子方式存储的信息仅需以一种形式提交。回应人无须以一种以上形式提交相同的以电子方式存储的信息。\n\n(D) 无法合理访问的以电子方式存储的信息。回应人无须提供来自其认定为因不当负担或费用而无法合理访问的来源的以电子方式存储的信息的证据开示。对于强制证据开示动议或保护令动议，回应人必须证明该信息因不当负担或费用而无法合理访问。如作出该证明，在考虑第26(b)(2)(C)条限制的情况下，如请求方证明存在正当理由，法院仍可命令对该等来源进行证据开示。法院可为该证据开示规定条件。\n(2) 主张特权或保护。\n\n(A) 扣留的信息。以该信息享有特权或作为审判准备材料受到保护为由而扣留被传唤信息的人必须：(i) 明确提出该主张；并且\n\n(ii) 以一种在不披露本身享有特权或受保护的信息的情况下，能够使当事人评估该主张的方式，描述被扣留文件、通信或有形物品的性质。\n\n(B) 已提交的信息。如为回应传票而提交的信息受到特权主张或作为审判准备材料受到保护的主张，提出该主张的人可将该主张及其依据通知任何收到该信息的当事人。收到通知后，当事人必须立即返还、隔离或销毁所指定的信息及其持有的任何副本；在该主张得到解决前不得使用或披露该信息；如当事人在收到通知前已披露该信息，必须采取合理措施追回该信息；并可立即将该信息密封提交给要求履行义务的地区的法院，以裁定该主张。提交该信息的人必须在该主张得到解决前保存该信息。\n\n(g) 藐视法庭。要求履行义务的地区的法院，以及在动议被移送后发出传票的法院，均可认定已被送达但无充分理由不遵守传票或与其相关命令的人构成藐视法庭。\n\n有关传票材料的获取，请参见 Fed.R.Civ.P.45(a) 委员会说明（2013年）\n\n……\n\n文件提交请求\nI. 指示\n\n1. 除非另有说明，下列文件请求（以下简称“请求”，每一项称为“一项请求”）必须分别且具体地作出回应。除非贵方基于善意提出异议，否则必须完整回答每项请求；如提出异议，贵方必须如下文所述详细说明异议理由。如异议仅涉及某项请求的一部分，或其中所含的一个词语、短语或条款，贵方仅须说明对该部分的异议，并回应请求的其余部分。\n\n2. 必须按照下列指示提交以电子方式存储的信息：\n\na. 图像。黑白图像必须为300 DPI Group IV 单页 TIFF 文件。彩色图像必须以 JPEG 格式提交。文件名不得包含嵌入的空格或特殊字符（包括逗号）。文件夹名称不得包含嵌入的空格或特殊字符（包括逗号）。所有 TIFF 图像文件必须具有唯一的文件名，即 Bates 编号。每份图像右下角必须加注连续的 Bates 编号。每个文件夹内的 TIFF 文件数量不得超过1000个文件。Excel 电子表格应具有以该文件的 Bates 编号命名的占位图像。\n\nb. 图像加载文件\n\na. Concordance® 数据文件。数据文件（.DAT）包含将被加载至 Concordance® 数据库的所有字段信息。.DAT 文件的第一行必须为标识字段名称的标题行。.DAT 文件必须使用下列 Concordance® 默认分隔符：逗号 ASCII 字符（020）引号 þ ASCII 字符（254）。日期字段应以如下格式提供：mm/dd/yyyy。日期字段和时间字段必须为两个独立字段。如文件包括已成像的电子邮件及附件，则必须包括附件字段，以保留电子邮件与其附件之间的父项/子项关系。必须包括 OCRPATH 字段，以提供已提交存储介质上所提取文本文件的文件路径和名称。文本文件必须以 FIRSTBATES 命名。不得在 .DAT 文件中包括文本。对于含有原生文件的文件，必须包括 LINK 字段，以提供原生文件的文件路径和名称。原生文件必须以 FIRSTBATES 命名。\n\nb. Concordance Image® 或 Opticon 交叉引用文件。图像交叉引用文件（.LOG 或 .OPT）将图像链接至数据库记录。其应为以逗号分隔的文件，每行由七个字段组成，数据库中的每张图像在交叉引用文件中均应有一行，格式如下：ImageID,VolumeLabel,ImageFilePath,DocumentBreak,FolderBreak,Box Break,PageCoun。\n\nc. 文件文本。文本必须作为单独的文本文件提供，而非作为 .DAT 文件中的字段。文本文件的完整路径（OCRPATH）应包含在 .DAT 文件中。建议提供以 FIRSTBATES/Image Key 命名的文件级 ANSI 文本文件。提取的文本文件必须置于单独文件夹中，且每个文件夹中的文本文件数量不得超过 1,000 个。文件夹名称中不得包含特殊字符（包括逗号）。文本文件必须按文件级别提供。\n\nd. 某些文件类型的原生格式提供。为充分理解其内容和含义而合理需要以原生格式查看的文件类型，必须以原生格式提供。该等文件包括但不限于电子表格、类电子表格文件（Microsoft Excel、逗号分隔值、制表符分隔值等）、Microsoft PowerPoint 或其他特殊演示文件、数据库文件以及音频/视频文件。应提供一张带有 Bates 编号的分隔页图像，以表明原生文件的存在，并将原生文件路径作为 .dat 文件中的一个字段。所提供的原生文件应以与该文件分隔页相对应的 Bates 编号命名。原生文件应归入按递增方式命名的“NATIVE”目录中，并与图像目录分开。\n\ne. 去重。对于存在完全重复件的每份电子文件，仅提供一份副本。对于电子邮件，应根据由 BCC、Body、CC、From、IntMsgID、To 和 Attach 属性生成的 MD5 哈希值合并重复件。对于电子邮件附件及独立电子文件，应根据整个文件的 MD5 哈希值合并重复件。\n\nf. 元数据。应以符合 Concordance 要求的加载文件（.dat）形式为每份文件提供提取的元数据。.DAT 文件的第一行必须为标识字段名称的标题行。.DAT 文件必须使用以下 Concordance 默认分隔符：逗号 , ASCII 字符（020）引号 þ ASCII 字符（254）\n\n日期字段应采用以下格式提供：mm/dd/yyyy。日期和时间字段必须为两个单独字段。以下为所需元数据：\n\n案号 22-50073 文件 1592 提交日期 03/24/23 登记日期 03/24/23 10:57:37 第 526 页，共 1063 页\n\n字段名称　示例数据　说明\n\nFIRSTBATES　EDC0000001　原生文件文件/电子邮件的第一个 Bates 编号\n\nLASTBATES　EDC0000001　原生文件文件/电子邮件的最后一个 Bates 编号\n\n对于单页文件，应填写 LASTBATES 字段。\n\nATTACHRANGE　EDC0000001\n-　父文件第一页的 Bates 编号至最后一个附件“子”文件最后一页的 Bates 编号\nEDC0000015\n\nBEGATTACH　EDC0000001　附件范围的第一个 Bates 编号\n\nENDATTACH　EDC0000015　附件范围的最后一个 Bates 编号\n\nCUSTODIAN　Smith, John　电子邮件：电子邮件所在的邮箱\n原生文件：文件来源的个人或部门名称\n\nFROM　John Smith　电子邮件：发件人\n原生文件：文件作者\n\n应使用分号分隔多个条目。\n\nTO　Coffman, Janice; LeeW　收件人\n[mailto:LeeW@MSN.com]　应使用分号分隔多个条目\n\nCC　Frank Thompson [mailto:　抄送收件人\nfrank_Thompson@cdt.com]　应使用分号分隔多个条目\n\nBCC　John Cain　密送收件人\n应使用分号分隔多个条目\n\nSUBJECT　Board Meeting Minutes　电子邮件：电子邮件主题行 原生文件：文件标题（如有）\n\nFILE_NAME　BoardMeetingMinutes.docx　原生文件：原始原生文件的名称，包括扩展名\n\nDATE_SENT　10/12/2010　电子邮件：电子邮件发送日期\n原生文件：（空）\n\nTIME_SENT/\nTIME_ZONE　07:05 PM GMT　电子邮件：电子邮件发送时间/电子邮件标准化所采用的时区\n\nTIME_ZONE　GMT　在转换过程中对电子邮件进行标准化所采用的时区。\n\nLINK　EDC0000001.msg　指向电子邮件或原生文件文件的超链接\n所链接文件必须按 FIRSTBATES 编号命名。\n\nFILE_EXTEN　MSG　代表电子邮件或原生文件的文件类型扩展名\n\nAUTHOR　John Smith　电子邮件：（空）\n原生文件：文件作者\n\nDATE_CREATED　10/10/2010　电子邮件：（空）\n原生文件：文件创建日期\n\n案号 22-50073 文件 1592 提交日期 03/24/23 登记日期 03/24/23 10:57:37 第 527 页，共 1063 页\n\nTIME_CREATED　10:25 AM　电子邮件：（空）\n原生文件：文件创建时间\n该数据必须为单独字段，且不得与 DATE_CREATED 字段合并。\n\nDATE_MOD　10/12/2010　电子邮件：（空）\n原生文件：文件最后修改日期\n\nTIME_MOD　07:00 PM　电子邮件：（空）\n原生文件：文件最后修改时间\n该数据必须为单独字段，且不得与 DATE_MOD 字段合并。\n\nDATE_ACCESSD　10/12/2010　电子邮件：（空）\n原生文件：文件最后访问日期\n\nTIME_ACCESSD　07:00 PM　电子邮件：（空）\n原生文件：文件最后访问时间\n该数据必须为单独字段，且不得与 DATE_ACCESSD 字段合并。\n\nFILE_SIZE　5,952　原生文件文件/电子邮件的大小，单位为 KB\n\nPGCOUNT　1　原生文件文件/电子邮件的页数\n\nPATH　电子邮件：（空）\nAgenda.doc　原生文件：存储原生文件文件的路径，包括原始文件名称。\n\nINTFILEPATH　Personal Folders\\Deleted　电子邮件：电子邮件的原始位置，包括原始文件名称。\nItems\\Board Meeting　原生文件：（空）\nMinutes.msg\n\nINTMSGID　<000805c2c71b\\$75977050\\$　电子邮件：唯一邮件 ID 原生文件：（空）\ncb8306d1@MSN>\n\nMD5HASH　d131dd02c5e6eec4693d9a0　文件的 MD5 哈希值。\n698aff95c\n2fcab58712467eab4004583e\nb8fb7f89\n\nOCRPATH　TEXT/001/EDC0000001.txt　原生文件提取文本的路径\n\n3. 每项请求均独立运作并应独立解释，除非另有说明，任何一项请求均不限制任何其他请求的范围。\n\n4. 所有文件应按通常业务过程中保存的方式提供，或应予组织和标记，以对应本请求中的类别。\n\n5. 本文所载每项请求均延及所有文件：(a) 由您占有、保管或控制的文件；或 (b) 由任何代表您行事的人占有、保管或控制的文件，\n\n案号 22-50073 文件 1592 提交日期 03/24/23 登记日期 03/24/23 10:57:37 第 528 页，共 1063 页\n\n包括您的律师或其他代表及顾问。每份文件均应完整提供。\n\n6. 如要求您提供已不再由您占有、保管或控制的文件，则您的答复必须：(a) 详细描述该文件的性质及其内容；(b) 确认编制或撰写该文件的人士（以及，如适用，确认该文件被发送给的人士）；(c) 确认该文件编制或创建的日期；(d) 说明该文件是否：(i) 下落不明或遗失，(ii) 已被销毁，(iii) 已自愿或非自愿地转交他人，或 (iv) 已以其他方式处置；(e) 说明该等处置的理由，以及围绕该等处置的事实和情形；(f) 确认授权该等处置的人士；(g) 确认该等处置的日期或大致日期；(h) 说明该文件最近一次由您占有、保管或控制的时间；以及 (i) 确认目前占有、保管或控制该文件的人士（如有）。\n\n7. 如要求您提供已被销毁的文件，则除前述指示所要求的信息外，您的答复还必须说明：(a) 销毁该文件的理由；(b) 销毁该文件的人士身份；以及 (c) 指示销毁该文件的人士身份。\n\n8. 如您主张被请求的文件享有特权或属于律师工作成果，则您的答复必须：(a) 说明：(i) 足以支持您关于该文件享有特权之主张的文件描述，(ii) 该文件的标题，(iii) 该文件的日期，(iv) 该文件的作者，(v) 该文件的收件人，(vi) 收到或阅览该文件原件或任何草稿、副本或复制件的每一人士身份，(vii) 该文件本身或该文件所载或提及的任何信息是否由任何其他人士占有、保管或控制；如是，确认该等人士身份，并说明该等信息如何进入其占有范围，(viii) 据以拒绝提供该文件的特权主张，以及 (ix) 您将据以支持该等特权主张的全部情形；以及 (b) 根据 D. Conn. L. Civ. R. 26(e)，就每份基于特权主张而拒绝提供的文件，制作一份特权清单，其中载明本指示第 (a) 部分要求的全部信息。\n\n案号 22-50073 文件 1592 提交日期 03/24/23 登记日期 03/24/23 10:57:37 第 529 页，共 1063 页\n\n9. 如一份原本应提供的文件的一部分包含受特权主张约束的信息，则仅应依照上述指示从该文件中删除或遮蔽受该特权主张约束的部分，其余部分应予提供。\n\n10. 本请求具有持续性。现指示您：(a) 在知悉先前答复不完整或不正确后，立即补充或更正任何后来发现不完整或不正确的答复；以及 (b) 提供根据本请求所要求的任何额外文件。\n\n11. 如文件所用语言并非英语，您应提供该文件。如文件所用语言并非英语，且存在英语译文，您应同时提供两份文件。\n\n12. 对实体的一切提述均包括其全部关联方。\n\n13. 对个人姓名的一切提述均包括所有其他名称、别名或昵称。\n\n14. 除非另有明确说明，文件请求涵盖的期间为自 February 5, 2012 起至文件请求答复到期之日止。\n\n案号 22-50073 文件 1592 提交日期 03/24/23 登记日期 03/24/23 10:57:37 第 530 页，共 1063 页\n\nII. 解释规则\n\n15. (a) 任何单数名词的使用应解释为包括复数，反之亦然；以及 (b) 任何时态动词的使用应解释为在所有其他时态中使用该动词。\n\n16. (a) “and”和“or”应视必要情况分别解释为连词或析取词，以将原本可能被解释为超出任何请求范围的所有答复纳入该请求范围；以及 (b) “each”和“any”应视为包括并涵盖“every”和“all”二词。\n\nIII. 定义\n\n由 D. Conn. L. Civ. R. 26(c) 提供的定义及由 D. Conn. L. Civ. R. 26(d) 提供的解释规则，经 D. Conn. Bankr. L.R. 2004-1(a) 纳入后，适用于文件请求。此外，本文件请求中使用的下列术语具有以下含义：\n\n1. “You”或“Your”或“Yourself”是指 Tong Le Internatiional Trading Co., Ltd.，以及其所有关联方、部门、机构、工具、科室、办事处、合伙人、高级职员、董事、代理人、律师、代表、雇员和/或任何代表其行事的人。\n\n2. “Debtor”是指 Ho Wan Kwok（郭文贵）（又名 Miles Kwok、Miles Guo、Guo Wengui、Guo Haoyun、郭文贵或任何其他别名），以及其雇员、代理人、律师、顾问或任何代表其行事的人。\n\n3. “债务人的儿子”系指 Qiang Guo（郭强，亦称 Mileson Kwok 或任何其他别名），以及其雇员、代理人、律师、顾问或任何代表其行事之人。\n案号 22-50073 文书 1592 提交于 03/24/23 登记于 03/24/23 10:57:37 第 531 页，共 1063 页\n\n4. “债务人的女儿”系指 Mei Guo（郭美，亦称 Mei Gui 或任何其他别名），以及其雇员、代理人、律师、顾问或任何代表其行事之人。\n\n5. “债务人的所谓妻子”系指 Hing Chi Ngok（岳庆芝，亦称 Hing Chi Ng、Yue Qingzhi 或任何其他别名），以及其雇员、代理人、律师、顾问或任何代表其行事之人。\n\n6. “债务人的家属”统称债务人、债务人的儿子、债务人的女儿及债务人的所谓妻子，以及与债务人有任何其他亲属关系之人。\n\n7. “关联个人”单独及共同系指下列所有个人：(1) 持有、控制、保管或对债务人或债务人的家属拥有、控制或享有的资产具有处置权；或 (2) 曾为一个或多个关联实体的雇员、董事，或以其他方式与其存在关联者，以及前述各方各自的雇员、代理人、律师、顾问或任何代表前述任何一方行事之人。该等关联个人包括但不限于：Daniel Podhaskie、Jason Miller、Steve Bannon、Karin Maistrello、Melissa Francis、Anthony DiBattista、William Gertz、Arethusa Forsyth、Glenn Mellor、Jennifer Mercurio、Eduardo Eurnekian、Wencong Wang、Han Chunguang（韩春光）、Qu Guojiao（屈国姣，亦称 Qu Guo Jiao）、Guo Lijie（郭丽杰）、Zhang Wei（张伟*）、Lihong Wei Lafrenz（魏丽红，亦称 Sara Wei）、Hao Haidong（郝海东）、Ross Heinemeyer、Max Krasner、Kyle Bass、Melissa Mendez、Ya Li（李娅）、Dinggang Wang（王定刚）、An Hong（安红）、Yvette Wang（王雁平，亦称 Yanping Wang、Yan Ping Wang）、Fiona Yu、Je Kin Ming（余建明，亦称 William Je、Yu Jianming）、Yaz Qingua，以及 Lao Jiang（姜云浮，亦称 Jiang Yunfu、Jiang Yunfu Be）。\n案号 22-50073 文书 1592 提交于 03/24/23 登记于 03/24/23 10:57:37 第 532 页，共 1063 页\n\n8. “关联实体”单独及共同系指下列所有类型的组织或实体：(1) 曾由债务人或债务人的家属拥有、控制或投资；或 (2) 对债务人或债务人的家属拥有、控制或享有的任何资产直接或间接拥有权益，以及前述各方各自的雇员、代理人、律师、顾问或任何代表前述任何一方行事之人。该等关联实体包括但不限于：7 Nod Hill LLC、AAGV Limited、ACA Investment Management Limited、ACA Capital Group Limited、Ace Decade Holdings Limited、AI Group Holdings Inc.、Alfa Global Ventures Limited、Alfonso Global Limited、Allied Capital Global Limited、Alpine Fiduciaries SA、Anton Development Limited、Assets Sino Limited、Auspicious Coast Limited、Beijing Pangu Investment Co.、Beijing Pangu Investment Co. Ltd.、Beijing Pangu Investment Inc.、Beijing Zenith Holdings Company Limited、Booming Sail New York LLC、Bravo Luck Limited、BSA Strategic Fund I、China Golden Spring (Hong Kong) Limited、Chuang Xin Limited、Crane Advisory Group LLC、Creative Apex Investments Limited、Crystal Breeze Investments Limited、Dawn State Limited、Eastern Profit Corporation Limited、Elite Well Global Limited、Empire Growth Holdings、Freedom Media Ventures Ltd.、G Club Operations LLC、G Fashion LLC、G News LLC、GETTR USA、Genever Holdings Corporation、Genever Holdings LLC、Gfashion Media Group Inc.、GFNY, Inc.、Globalist International Limited、GNews Media Group Inc.、Golden Spring (New York) Ltd.、Greenwich Land LLC、Guo Media、GTV Media Group, Inc.、Hamilton Capital Holdings Inc.、HCHK Property Management, Inc.、HCHK Technologies, Inc.、Head Win Group Limited、Henan Yuda、Himalaya Embassy、Himalaya Exchange、Himalaya Federal Reserve、Himalaya Investment LLC、Himalaya International、Himalaya New World Inc.、Himalaya Supervisory Organization、Himalaya Ventures LLC、HK International Funds Investments (USA) Limited LLC、Hong Kong International Funds\n案号 22-50073 文书 1592 提交于 03/24/23 登记于 03/24/23 10:57:37 第 533 页，共 1063 页\n\nInvestments Limited、Hudson Diamond Holding、Infinite Increase Limited、Infinitum Developments Limited、Infinity Treasury Management Inc.、Insight Phoenix Fund、Lamp Capital LLC、Leading Shine Limited、Leading Shine NY Limited、Lexington Property and Staffing、Long Gate Limited、Maywind Trading LLC、MOS Himalaya LLC、Next Tycoon Investments Limited、New Federal State of China（亦称 NFSC）、Noble Fame Global Limited、Rosy Acme Ventures Limited、Rule of Law Foundation III, Inc.、Rule of Law Foundation IV, Inc.、Rule of Law Fund、Rule of Law Society、Rule of Law Society IV, Inc.、G-Translators PTY LTD、Saraca Media Group, Inc.、Shiny Ace Ltd.、Shiny Times Holdings Ltd.、Spirit Charter Investment Limited、Stevenson, Wong & Co.、Voice of Guo Media, Inc.、Well Origin Ltd.、World Century Limited、Worldwide Opportunity Holdings Limited、Whitecroft Shore Limited，以及 ZIBA Limited。\n\n9. “包括”或其任何变体，系指“包括但不限于”。\n\n10. “和”及“或”系指“和/或”，并应为最大限度扩大其范围而同时作连言及选言解释。\n\n11. “任何”及“全部”和“每一”均系指“每一及全部”。\n\n12. “每一”及“每个”均系指“每一及全部”。\n\n13. “第三方”系指除您本人以外的个人或实体。\n\n14. “转让”具有《破产法典》第 101(54) 条赋予该词的含义。\n\n15. “文件”系指属于 Fed. R. Civ. P. 34 范围内的任何信息或物品，并包括但不限于，现由或曾由您占有、保管或控制的任何种类、类型、性质或描述的每一及全部书面、记录或图形材料，包括电子邮件的所有纸质及电子副本、以电子形式保存的计算机文件、电子通信、短信、社交媒体帖子、推文、元数据、往来函件、备忘录、磁带、速记或手写笔记、任何种类的书面表格、图表、蓝图、图纸、草图、曲线图、计划、文章、规格说明、日记、信函、电报、照片、会议记录、合同、协议、调查、计算机打印件、任何种类的数据汇编、电传、传真、语音信息、发票、订单表、支票、汇票、对账单、贷项通知单、报告、头寸报告、摘要、索引、账簿、总账、笔记本、明细表、透明胶片、录音、目录、广告、宣传材料、影片、录像带、录音带、CD、计算机磁盘、宣传册、小册子、穿孔卡、工时单、推文、社交媒体帖子或任何其他种类的书面或记录材料，以及其全部元数据，无论其以何种方式存储（无论为有形或电子形式）、记录、制作或复制；亦包括但不限于前述任何文件的草稿或副本，如该等草稿或副本含有原始文件中不存在的任何种类的笔记、评论或标记，或在其他方面与原始文件不相同。\n案号 22-50073 文书 1592 提交于 03/24/23 登记于 03/24/23 10:57:37 第 534 页，共 1063 页\n\n16. “个人”系指个人、公司、独资企业、合伙企业、协会或任何其他实体。“个人”亦包括任何代理人、代表或专家，包括但不限于律师或财务顾问。\n\n17. “实体”系指任何自然人、公司、合伙企业、子公司、独资企业、商号、董事会、合资企业、协会、机构、主管机关、委员会或其他商业实体或法人，以及任何关联方、代理人、母公司，包括但不限于法律顾问、财务顾问或任何其他代表。\n\n18. “关于”系指涉及、描述、构成、提及、与之有关、支持、赞成、反对、加强、减损、位于其中、与之相关地考虑、对其有影响、证明、表明、报告、记录、暗示、答复、\n案号 22-50073 文书 1592 提交于 03/24/23 登记于 03/24/23 10:57:37 第 535 页，共 1063 页\n\n与之相连、评论、就其而言、有关、与之相关、讨论、显示、描述、反映、分析、构成及为。\n\n19. “与……有关”“与……相关”或“有关联”，在指涉任何特定主题事项时，系指但不限于构成、包含、涉及、载有、体现、反映、识别、陈述、直接或间接提及，或以任何方式与所确定的特定主题事项相关的任何文件。\n\n20. “通信”在最广义且不受限制的意义上，系指任何信息或知识的传递（以事实、观点、询问或其他形式）。通信还指所有谈话、协议、询问或答复，无论是当面、通过电话、书面方式或通过电子传输设备进行，并包括但不限于所有往来函件、电子邮件、录音、传送单、备忘录、电话通信、语音信息、电报、电传传真、传真副本、电传、即时消息、聊天、短信、电话笔记或在内部或与第三方之间传送的笔记。\n\n21. “资产”系指任何可用于产生正向经济价值的项目，包括但不限于由某一实体拥有、控制或为其利益而存在的、预期将提供未来利益的任何具有经济价值的资源，包括但不限于所有不动产和动产、无形财产、投资、投资权或未来收入权、现金、银行账户、商品、证券、债权、对某一实体的全部或部分控制权，以及预期经济机会。\n\n22. “转让”具有《破产法典》第 101(54) 条赋予该词的含义。\n\nIV. 应提交的文件\n\n1. 关于债务人、债务人破产财产或关联实体的任何收入或资产的全部文件。\n\n2. 与债务人的财务状况及其对债权人的义务有关的全部文件，包括但不限于与任何规避支付该等义务的努力有关的全部文件，以及与本次或任何其他实际或潜在破产或类似资不抵债程序有关的全部文件。\n\n3. 关于与债务人、债务人破产财产、债务人的家属、关联实体或关联个人有关的任何资产负债表、银行对账单、账户对账单、财务报表、账户报表、电汇指示和/或确认、资金证明、存款证明、持有证明、投资组合摘要或类似文件的全部文件，包括但不限于足以显示向前述任何一方进行的全部转让的全部文件。\n\n4. 关于债务人作出、与债务人进行或代表债务人作出的任何投资、商业交易或交易的全部文件。\n\n5. 与债务人的全部通信，以及与债务人的通信有关、涉及任何实体的运营、管理或决策的文件，包括但不限于关联实体。\n\n6. 关于向债务人、债务人的家属或关联实体作出、由其作出或与其进行的任何转让、投资、其他交易或商业交易的全部文件。\n\n7. 关于债务人曾占用或使用的任何财产的全部文件，包括但不限于 Lady May；Sherry Netherland Hotel / Condominium；位于 Connecticut（康涅狄格州）Greenwich（格林尼治）373 Taconic Rd. 的住宅物业；位于 Connecticut（康涅狄格州）Greenwich（格林尼治）33 Ferncliff Rd. 的住宅物业；以及位于 Connecticut（康涅狄格州）Wilton（威尔顿）354 Nod Hill Rd. 的住宅物业。\n\n8. 与债务人拥有、控制或使用的任何航空器有关的所有文件，包括但不限于尾号为 T7-GQM 的航空器以及在圣马力诺登记的任何其他航空器，包括但不限于所有登记文件副本和飞行清单，该等飞行清单显示该等航空器所执行的航班及乘坐该等航班的个人。\n\n9. 有关向债务人、债务人的破产财产、债务人的家庭成员或关联实体提供、由其提供或代表其提供的任何赠与、利益或贷款的所有文件，包括但不限于足以显示该等赠与、利益或贷款的金额；该等赠与、利益或贷款所用于的目的；提供该等赠与、利益或贷款的时间；以及任何贷款的条款、就任何贷款作出的所有陈述与保证、任何贷款的利率，以及任何贷款付款的所有证据的文件。\n\n10. 有关由债务人、代表债务人或为债务人、债务人的破产财产、债务人的家庭成员或关联实体的利益而设立的任何信托或类似文书的所有文件，包括但不限于足以显示该等信托设立的时间、设立人、为谁的利益而设立以及信托本金的文件。\n\n11. 与涉及债务人的任何法律争议相关的任何义务、请求权、责任或债务有关的所有文件，包括但不限于与在任何地方、州、联邦或国际机构（无论是行政机构、法院、合议机构还是替代性争议解决实体）前进行的任何诉讼有关的文件。\n案号 22-50073 文件 1592 提交日期 03/24/23 录入日期 03/24/23 10:57:37 第 538 页，共 1063 页\n\n12. 你方的任何外聘律师或其他顾问与债务人之间的所有文件及通信。\n\n13. 足以显示你方的所有资产以及收入或资金来源的文件。\n\n14. 对于就第 14 项请求作出答复时确认的、价值超过 \\$50,000 的所有资产，(i) 与你方取得该等资产有关的所有文件，以及 (ii) 与债务人或债务人的家庭成员就该等资产进行的通信。\n\n15. 你方纳税申报表的副本。\n\n16. 足以显示由你方持有或控制的所有银行账户和投资账户的文件，包括每个该等账户的余额以及向其转入和从其转出的款项。\n\n17. 有关你方使用的任何信用卡的所有文件，包括但不限于月度对账单或足以显示为债务人或关联实体利益而进行的与此有关的所有购买的其他文件。\n\n18. 所有公司治理和组织文件，包括但不限于章程细则、公司注册证书，以及足以显示你方公司结构、高级职员和董事姓名、经营目的以及与债务人或债务人任何家庭成员关系的其他文件。\n\n19. 与将你方任何资产质押给任何其他实体有关的所有文件。\n\n案号 22-50073 文件 1592 提交日期 03/24/23 录入日期 03/24/23 10:57:37 第 539 页，共 1063 页\n\n附件 C-29\n\nB2540（表格 2540——规则 2004 审查传票）(12/15) 案号 22-50073 文件 1592 提交日期 03/24/23 录入日期 03/24/23 10:57:37 第 540 页，共\n\nUNITED STATES BANKRUPTCY COURT（美国破产法院）\n\nDistrict of Connecticut（康涅狄格地区）\n\n关于 HO WAN KWOK（郭文贵）等人，\n\n1 案号 22-50073 (JAM)\n\n债务人 第 11 章\n\n（合并管理）\n规则 2004 审查传票\n\n致：Manufacturers and Traders Trust Company（制造商与交易商信托公司），以 M&T Bank 名义营业\n\n（传票所指向人员的姓名）\n\n证言：兹命令你方于下列规定的时间、日期和地点出席，根据《联邦破产程序规则》规则 2004 进行审查并作证。随附准许进行该审查的法院命令副本。\n\n地点　日期和时间\n\nNeubert, Pepe & Monteith, P.C.（诺伊伯特、佩佩与蒙蒂斯专业公司）\n195 Church Street, Floor 13　[待定]\nNew Haven, Connecticut 06510\n\n审查将采用以下方式记录：法庭记录员/速记员\n\n提交：你方或你方代表还必须在审查时随身携带下列文件、电子存储信息或物品，并必须准许对该等材料进行查验、复制、测试或抽样：\n见随附的文件提交请求。\n\n《联邦民事诉讼规则》规则 45 的下列规定，经《联邦破产程序规则》规则 9016 适用于破产案件，随附于后——关于履行地点的规则 45(c)；关于你方作为受传票约束人员所受保护的规则 45(d)；以及关于你方回应本传票的义务和未履行该义务的潜在后果的规则 45(e) 和 45(g)。\n\n日期：2023 年 3 月\n\n法院书记官\n\n或\n\n书记官或副书记官签名　律师签名\n\n签发或请求本传票并代理第 11 章受托人 Luc A. Despins（吕克·A·德斯平）的律师的姓名、地址、电子邮箱地址和电话号码如下：\n\nDouglas S. Skalka, Esq.（道格拉斯·S·斯卡尔卡，律师）；Neubert, Pepe & Monteith, P.C.（诺伊伯特、佩佩与蒙蒂斯专业公司）；195 Church Street, New Haven, Connecticut 06510；dskalka@npmlaw.com；(203) 821-2000\n\n向签发或请求本传票之人的通知\n\n如本传票命令在审判前提交文件、电子存储信息或有形物品，或查验场所，则必须在向被指向人员送达之前，向每一方当事人送达通知及本传票副本。Fed. R. Civ. P. 45(a)(4)。\n\n软件版权 (c) 1996-2022 Best Case, LLC（贝斯特凯斯有限责任公司）- www.bestcase.com Best Case Bankruptcy 1 本第 11 章案件中的债务人为 Ho Wan Kwok（亦称 Guo Wengui、Miles Guo 和 Miles Kwok，以及众多其他别名）（税务识别号码后四位：9595）、Genever Holdings LLC（税务识别号码后四位：8202）和 Genever Holdings Corporation。受托人、Genever Holdings LLC 和 Genever Holdings Corporation 的邮寄地址为 Paul Hastings LLP（普衡律师事务所），200 Park Avenue, New York, NY 10166，转交 Luc A. Despins，作为 Ho Wan Kwok 破产财产的受托人（仅为通知和通信之目的）。\n\n送达证明\n\n（除非 Fed. R. Civ. P. 45 要求，否则本节不应向法院提交。）\n\n本人于（日期）收到向（个人姓名及职务，如有）发出的本传票。\n\n本人以下列方式通过向被指定人员交付副本送达本传票：\n\n于（日期）；或\n\n本人未予执行而退回本传票，原因为：\n\n除非本传票系代表美国或其官员或代理人签发，本人亦已向证人支付一天出席费用及法律允许的里程费，金额为 \\$。\n\n本人的差旅费用为 \\$，服务费用为 \\$，合计 \\$。\n\n本人在伪证处罚的约束下声明，该等信息真实且正确。\n\n日期：\n\n送达人签名\n\n正楷姓名及职务\n\n送达人地址\n\n有关尝试送达等事项的补充信息：\n\n《联邦民事诉讼规则》规则 45(c)、(d)、(e) 和 (g)（自 12/1/13 起生效）（经《联邦破产程序规则》规则 9016 适用于破产案件）\n\n(c) 履行地点。\n\n(1) 审判、听证或证言录取。传票仅可按以下方式命令某人出席审判、听证或证言录取：\n\n(A) 在该人居住、受雇或经常亲自从事商业活动地点 100 英里以内；或\n\n(B) 在该人居住、受雇或经常亲自从事商业活动所在州内，如该人\n\n(i) 为当事人或当事人的高级职员；或\n\n(ii) 被命令出席审判且不会产生重大费用。\n\n(2) 其他证据开示。传票可以命令：\n\n(A) 在该人居住、受雇或经常亲自从事商业活动地点 100 英里以内的地点提交文件、电子存储信息或物品；以及\n\n(B) 在待查验场所进行场所查验。\n\n(d) 对受传票约束人员的保护；执行。\n\n(1) 避免不当负担或费用；制裁。负责签发和送达传票的一方当事人或律师必须采取合理措施，避免对受传票约束人员施加不当负担或费用。要求履行的地区法院必须执行该义务，并对未予遵守的当事人或律师施加适当制裁，其中可包括损失的收入和合理的律师费。\n\n(2) 命令提交材料或准许查验。\n\n(A) 无须出席。被命令提交文件、电子存储信息或有形物品，或者准许查验场所的人员，无须亲自到提交或查验地点出席，除非同时被命令出席证言录取、听证或审判。\n\n(B) 异议。被命令提交文件或有形物品，或者准许查验的人员，可以就查验、复制、测试或抽样全部或部分材料，或者查验场所，或以所要求的一种或多种形式提交电子存储信息，向传票中指定的当事人或律师送达书面异议。异议必须在规定的履行时间之前或在传票送达后 14 日内（以较早者为准）送达。如提出异议，适用下列规则：\n\n(i) 送达人可在任何时间向被命令人员发出通知后，向要求履行的地区法院申请强制提交或查验的命令。\n\n(ii) 仅可按照该命令的指示要求采取该等行为，且该命令必须保护既非当事人亦非当事人高级职员的人员，使其免受因履行而产生的重大费用。\n\n(3) 撤销或修改传票。\n\n(A) 必须撤销或修改的情形。经及时动议，要求履行的地区法院必须撤销或修改具有下列情形的传票：\n\n(i) 未给予合理的履行时间；\n\n(ii) 要求某人在规则 45(c) 规定的地域限制之外履行；\n\n(iii) 要求披露特权事项或其他受保护事项，且不适用任何例外或豁免；或\n\n(iv) 对某人造成不当负担。\n\n(B) 可以撤销或修改的情形。为保护受传票约束或受其影响的人员，要求履行的地区法院可以依动议撤销或修改要求下列事项的传票：\n\n(i) 披露商业秘密或其他机密研究、开发或商业信息；或\n\n(ii) 披露未受聘专家的意见或信息，该等意见或信息并非描述争议中的特定事件，且系该专家未经任何一方当事人请求而进行的研究所得。\n\n(C) 以规定条件作为替代。在规则 45(d)(3)(B) 所述情形下，如送达人：\n\n(i) 证明对该证言或材料具有实质性需要，且不遭受不当困难便无法通过其他方式满足该需要；以及\n\n(ii) 确保受传票人员将获得合理补偿，\n\n法院可不撤销或修改传票，而命令在规定条件下出席或提交。\n\n(e) 回应传票的义务。\n\n(1) 提交文件或电子存储信息。下列程序适用于提交文件或电子存储信息：\n\n(A) 文件。回应要求提交文件的传票的人员，必须按照文件在通常业务过程中保存的方式提交，或者将文件整理并标注，以对应请求中的类别。\n\n(B) 未规定提交电子存储信息的形式。如传票未规定提交电子存储信息的形式，回应人员必须以其通常保存的一种或多种形式，或以一种或多种合理可用的形式提交。\n\n(C) 电子存储信息仅以一种形式提交。回应人员无须以超过一种形式提交相同的电子存储信息。\n\n(D) 无法以电子方式获取的存储信息。作出答复的人无需从其认定为因不当负担或费用而无法合理获取的来源提供电子存储信息的发现材料。在提出强制发现动议或申请保护令时，作出答复的人必须证明该信息因不当负担或费用而无法合理获取。如果作出该证明，法院仍可在提出请求的一方证明存在正当理由时，命令从该等来源进行发现，并应考虑 Rule 26(b)(2)(C) 的限制。法院可对该发现规定条件。\n\n(2) 主张特权或保护。\n\n(A) 扣留的信息。任何人如以所传唤的信息享有特权或作为审判准备材料受到保护为由扣留该信息，必须：(i) 明确提出该主张；以及\n\n(ii) 以一种在不披露本身享有特权或受保护信息的情况下足以使各方评估该主张的方式，说明被扣留的文件、通信或有形物品的性质。\n\n(B) 已提交的信息。如为响应传票而提交的信息受到特权主张或作为审判准备材料受保护的主张约束，提出该主张的人可以将该主张及其依据通知收到该信息的任何一方。收到通知后，一方必须立即返还、隔离或销毁所指明的信息及其持有的任何副本；在该主张得到解决前，不得使用或披露该信息；如该方在收到通知前已披露该信息，必须采取合理步骤取回该信息；并且可以立即将该信息密封提交给履行义务所在地辖区的法院，以裁定该主张。提交该信息的人必须在该主张得到解决前保存该信息。\n\n(g) 藐视法庭。履行义务所在地辖区的法院——以及在动议被移送后，签发传票的法院——可对已被送达但无充分理由不遵守传票或与之相关命令的人，认定其藐视法庭。\n\n有关获取传票材料的信息，参见 Fed.R.Civ.P.45(a) Committee Note (2013)\n\n……\n\n文件提交请求\nI. 指示\n\n1. 除非另有说明，下列文件请求（以下简称“请求”，每一项以下简称“一项请求”）必须分别且具体地作出答复。除非出于善意提出异议，否则必须对每项请求作出完整答复；如提出异议，必须按如下规定详细说明你方异议的理由。如异议仅涉及某项请求的一部分，或其中包含的某一词语、短语或条款，你方仅须对该部分提出异议，并对其余请求作出答复。\n\n2. 电子存储信息必须依照以下指示提交：\n\na. 图像。黑白图像必须为 300 DPI Group IV 单页 TIFF 文件。彩色图像必须以 JPEG 格式提交。文件名不得包含嵌入空格或特殊字符（包括逗号）。文件夹名称不得包含嵌入空格或特殊字符（包括逗号）。所有 TIFF 图像文件必须具有唯一文件名，即 Bates 编号。每张图像右下角必须标注连续的 Bates 编号。每个文件夹中的 TIFF 文件数量不得超过 1000 个文件。Excel 电子表格应具有以该文件的 Bates 编号命名的占位图像。\n\nb. 图像加载文件\n\na. Concordance® 数据文件。数据文件（.DAT）包含将加载至 Concordance® 数据库的全部字段化信息。.DAT 文件的第一行必须为标明字段名称的标题行。.DAT 文件必须使用以下 Concordance® 默认分隔符：逗号 ASCII 字符（020）引号 þ ASCII 字符（254）。日期字段应采用以下格式提供：mm/dd/yyyy。日期和时间字段必须为两个单独字段。如文件包括已成像的电子邮件及附件，必须包括附件字段，以保留电子邮件与其附件之间的父项/子项关系。必须包括 OCRPATH 字段，以提供所提交存储介质上提取文本文件的文件路径及名称。文本文件必须以 FIRSTBATES 命名。不得将文本包含在 .DAT 文件中。对于包含原生文件的文件，必须包括 LINK 字段，以提供原生文件的文件路径及\n\n名称。原生文件必须以 FIRSTBATES 命名。\n\nb. Concordance Image® 或 Opticon 交叉引用文件。图像交叉引用文件（.LOG 或 .OPT）将图像链接至数据库记录。其应为以逗号分隔的文件，每行由七个字段组成，数据库中的每张图像均应在交叉引用文件中对应一行，格式如下：ImageID,VolumeLabel,ImageFilePath,DocumentBreak,FolderBreak,Box Break,PageCount。\n\nc. 文件文本。文本必须作为单独的文本文件提交，不得作为 .DAT 文件中的字段。文本文件的完整路径（OCRPATH）应包含在 .DAT 文件中。建议提供文件级 ANSI 文本文件，并按 FIRSTBATES/Image Key 命名。提取的文本文件必须置于单独的文件夹中，每个文件夹中的文本文件数量不得超过 1,000 个文件。文件夹名称中不得含有特殊字符（包括逗号）。必须按文件级别提供文本文件。\n\nd. 特定文件类型的原生提交。为充分理解其内容及含义而合理需要以原生格式查看的文件类型，必须以原生格式提交。这些文件包括但不限于：电子表格、类似电子表格的文件（Microsoft Excel、逗号分隔值、制表符分隔值等）、Microsoft PowerPoint 或其他特殊演示文件、数据库文件以及音频/视频文件。提供一张标有 Bates 编号的分隔页图像，以表明存在原生文件，并在 .dat 文件中将原生文件路径列为一个字段。所提交的原生文件必须以与该文件分隔页相对应的 Bates 编号命名。将原生文件归入按递增方式命名的“NATIVE”目录中，并与图像目录分开。\n\ne. 去重。对于存在完全重复件的每份电子文件，提交一份副本。对于电子邮件，以根据 BCC、Body、CC、From、IntMsgID、To 和 Attach 属性生成的 MD5 哈希值为基础合并重复件。对于电子邮件附件和独立电子文件，以整个文件的 MD5 哈希值为基础合并重复件。\n\nf. 元数据。以符合 Concordance 的加载文件（.dat）形式，为每份文件提交提取的元数据。.DAT 文件的第一行必须为标明字段名称的标题行。.DAT 文件必须使用以下 Concordance 默认分隔符：逗号 , ASCII 字符（020）引号 þ ASCII 字符（254）\n\n日期字段应采用以下格式提供：mm/dd/yyyy。日期和时间字段必须为两个单独字段。以下列出所要求的元数据：\nCase 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 545 of 1063\n\n字段名称　示例数据　说明\n\nFIRSTBATES　EDC0000001　原生文件文件/电子邮件的第一个 Bates 编号\nLASTBATES　EDC0000001　原生文件文件/电子邮件的最后一个 Bates 编号\n对于单页文件，应填写 LASTBATES 字段\nATTACHRANGE　EDC0000001\n-　父文件首页的 Bates 编号至最后一个附件“子项”文件最后一页的 Bates 编号\nEDC0000015\nBEGATTACH　EDC0000001　附件范围的第一个 Bates 编号\nENDATTACH　EDC0000015　附件范围的最后一个 Bates 编号\nCUSTODIAN　Smith, John（约翰·史密斯）　电子邮件：电子邮件所在的邮箱\n原生文件：文件来源个人或部门的名称\nFROM　John Smith　电子邮件：发件人\n原生文件：文件作者\n\n多个条目应以分号分隔\nTO　Coffman, Janice（贾尼斯·科夫曼）；LeeW　收件人\n[mailto:LeeW@MSN.com]　多个条目应以分号分隔\nCC　Frank Thompson（弗兰克·汤普森） [mailto:　抄送收件人\nfrank_Thompson@cdt.com]　多个条目应以分号分隔\nBCC　John Cain（约翰·凯恩）　密送收件人\n多个条目应以分号分隔\nSUBJECT　Board Meeting Minutes　电子邮件：电子邮件主题行 原生文件：文件标题（如有）\nFILE_NAME　BoardMeetingMinutes.docx　原生文件：原始原生文件名称，包括扩展名\nDATE_SENT　10/12/2010　电子邮件：电子邮件发送日期\n原生文件：（空）\nTIME_SENT/　07:05 PM GMT　电子邮件：电子邮件发送时间/电子邮件标准化所采用的时区\nTIME_ZONE\nTIME_ZONE　GMT　在转换过程中电子邮件被标准化所采用的时区。\nLINK　EDC0000001.msg　电子邮件或原生文件文件的超链接\n所链接的文件必须按 FIRSTBATES 编号命名\nFILE_EXTEN　MSG　代表电子邮件或原生文件的文件类型扩展名\nAUTHOR　John Smith　电子邮件：（空）\n原生文件：文件作者\nDATE_CREATED　10/10/2010　电子邮件：（空）\n原生文件：文件创建日期\n\nCase 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 546 of 1063\n\nTIME_CREATED　10:25 AM　电子邮件：（空）\n原生文件：文件创建时间\n该数据必须为单独字段，不得与 DATE_CREATED 字段合并\nDATE_MOD　10/12/2010　电子邮件：（空）\n原生文件：文件最后修改日期\nTIME_MOD　07:00 PM　电子邮件：（空）\n原生文件：文件最后修改时间\n该数据必须为单独字段，不得与 DATE_MOD 字段合并\nDATE_ACCESSD　10/12/2010　电子邮件：（空）\n原生文件：文件最后访问日期\nTIME_ACCESSD　07:00 PM　电子邮件：（空）\n原生文件：文件最后访问时间\n该数据必须为单独字段，不得与 DATE_ACCESSD 字段合并\nFILE_SIZE　5,952　原生文件文件/电子邮件的大小，以 KB 计\nPGCOUNT　1　原生文件文件/电子邮件的页数\nPATH　电子邮件：（空）\nAgenda.doc　原生文件：存储原生文件文件的路径，包括原始文件名称。\nINTFILEPATH　Personal Folders\\Deleted　电子邮件：电子邮件的原始位置，包括原始文件名称。\nItems\\Board Meeting\nMinutes.msg　原生文件：（空）\nINTMSGID　<000805c2c71b\\$75977050\\$　电子邮件：唯一邮件 ID 原生文件：（空）\ncb8306d1@MSN>\nMD5HASH　d131dd02c5e6eec4693d9a0　文件的 MD5 哈希值。\n698aff95c\n2fcab58712467eab4004583e\nb8fb7f89\nOCRPATH　TEXT/001/EDC0000001.txt　原生文件提取文本的路径\n\n3. 每项请求独立适用并应独立解释，除非另有说明，任何一项请求均不限制任何其他请求的范围。\n\n4. 所有文件均应按其在通常业务过程中保存的方式提交，或者应加以整理和标识，以对应本请求中的类别。\n\n5. 本文所载的每项请求均延及以下所有文件：(a) 由你方占有、保管或控制的文件；或 (b) 由代表你方行事的任何人占有、保管或控制的文件，\nCase 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 547 of 1063\n\n包括你方律师或其他代表和顾问。每份文件均应完整提交。\n\n6. 如要求您提交已不再由您占有、保管或控制的文件，则您的答复必须：(a) 详细说明该文件的性质及其内容；(b) 指明编制或撰写该文件的人员（以及，如适用，文件发送给的人员）；(c) 指明该文件编制或创建的日期；(d) 说明该文件是否：(i) 遗失或丢失，(ii) 已被销毁，(iii) 已自愿或非自愿地转移给他人，或 (iv) 已以其他方式处置；(e) 说明该等处置的理由及相关事实和情形；(f) 指明授权该等处置的人员；(g) 指明该等处置的日期或大致日期；(h) 说明该文件最后一次由您占有、保管或控制的时间；以及 (i) 指明目前占有、保管或控制该文件的人员（如有）。\n\n7. 如要求您提交已被销毁的文件，则除前述指示所要求的信息外，您的答复还必须说明：(a) 销毁该文件的理由；(b) 销毁该文件的人员身份；以及 (c) 指示销毁该文件的人员身份。\n\n8. 如您主张所要求的文件享有特权或属于律师工作成果，则您的答复必须：(a) 说明：(i) 足以支持您关于该文件享有特权之主张的文件描述，(ii) 文件标题，(iii) 文件日期，(iv) 文件作者，(v) 文件收件人，(vi) 收到或阅览该文件原件、任何草稿、副本或复制件的每一人员身份，(vii) 该文件本身或该文件所载或提及的任何信息是否由任何其他人员占有、保管或控制；如是，则说明该等人员的身份，以及关于该等信息如何进入其占有范围的陈述，(viii) 据以拒绝提交该文件的特权主张，及 (ix) 您将据以支持该特权主张的所有情形；以及 (b) 根据 D. Conn. L. Civ. R. 26(e)，就基于特权主张而拒绝提交的每一文件，制作一份特权清单，其中载明本指示第 (a) 部分要求的全部信息。对于文件请求中未提出特权或工作成果主张的任何部分，应完整提供相关文件。\n\n案号 22-50073 文件 1592 提交日期 03/24/23 录入日期 03/24/23 10:57:37 第 548 页，共 1063 页\n\n该等人员的身份，以及关于该等信息如何进入其占有范围的陈述，(viii) 据以拒绝提交该文件的特权主张，及 (ix) 您将据以支持该特权主张的所有情形；以及 (b) 根据 D. Conn. L. Civ. R. 26(e)，就基于特权主张而拒绝提交的每一文件，制作一份特权清单，其中载明本指示第 (a) 部分要求的全部信息。对于文件请求中未提出特权或工作成果主张的任何部分，应完整提供相关文件。\n\n9. 如另行具有回应性的文件的一部分含有受特权主张约束的信息，则仅应依照上述指示从该文件中删除或遮蔽受该特权主张约束的部分，其余部分应予提交。\n\n10. 该等请求具有持续性。现指示您：(a) 一旦得知先前答复不完整或不正确，应立即补充或更正任何后来得知不完整或不正确的答复；以及 (b) 提交根据以下规定所要求的任何额外文件\n\n11. 如文件使用英语以外的语言，您应提供该文件。如文件使用英语以外的语言且存在英文译本，您应同时提供两份文件。\n\n12. 对实体的一切提及均包括其所有关联方。\n\n13. 对个人姓名的一切提及均包括所有替代姓名、别名或昵称。\n\n案号 22-50073 文件 1592 提交日期 03/24/23 录入日期 03/24/23 10:57:37 第 549 页，共 1063 页\n\n14. 除非另有明确说明，文件请求所涵盖的期间为自 February 5, 2012 起至文件请求答复到期之日止。\n\nII. 解释规则\n\n15. (a) 任何单数名词的使用应解释为包括复数，反之亦然；以及 (b) 任何时态动词的使用应解释为包括该动词所有其他时态的使用。\n\n16. (a) “和”及“或”应视需要解释为连词或析取词，以使本可能被解释为不在任何请求范围内的所有答复均纳入该请求范围；以及 (b) “每一”及“任何”应视为包括并涵盖“每个”和“所有”二词。\n\nIII. 定义\n\n经 D. Conn. Bankr. L.R. 2004-1(a) 纳入的 D. Conn. L. Civ. R. 26(c) 所规定的定义及 D. Conn. L. Civ. R. 26(d) 所规定的解释规则，适用于该等文件请求。此外，本文件请求中使用的下列术语具有下列含义：\n\n1. “您”或“您的”或“您本人”系指 Manufacturers and Traders Trust Company（制造商和贸易商信托公司）及其所有关联方。\n\n2. “债务人”系指 Ho Wan Kwok（郭文贵，亦称 Miles Kwok、Miles Guo、Guo Wengui、Guo Haoyun、郭文贵，或任何其他别名）及其雇员、代理人、律师、顾问或任何代表其行事之人。\n\n案号 22-50073 文件 1592 提交日期 03/24/23 录入日期 03/24/23 10:57:37 第 550 页，共 1063 页\n\n3. “债务人之子”系指 Qiang Guo（郭强，亦称 Mileson Kwok、郭强或任何其他别名）及其雇员、代理人、律师、顾问或任何代表其行事之人。\n\n4. “债务人之女”系指 Mei Guo（郭美，亦称 Mei Gui、郭美或任何其他别名）及其雇员、代理人、律师、顾问或任何代表其行事之人。\n\n5. “债务人所谓妻子”系指 Hing Chi Ngok（岳庆芝，亦称 Hing Chi Ng、Yue Qingzhi、岳庆芝或任何其他别名）及其雇员、代理人、律师、顾问或任何代表其行事之人。\n\n6. “债务人家属”单独及合称指债务人、债务人之子、债务人之女及债务人所谓妻子，以及与债务人具有任何其他亲属关系之人。\n\n7. “2004 年调查取证对象”单独及合称指债务人、债务人家属、ACA Capital Group Limited、Himalaya International Financial Group Ltd.、Himalaya International Clearing Ltd.、Himalaya International Payments Ltd.、Himalaya International Reserves Ltd.、Jesse Brown、William Je、William Je、Eastern Profit Corporation Limited、HK International Funds Investments (USA) Limited LLC、Bravo Luck Limited、Golden Spring (New York) Ltd.、Lamp Capital LLC、Greenwich Land LLC、Qu Guo Jiao、Daniel Thomas Podhaskie、Yvette Wang（亦称 Yanping Wang、亦称 Yan Ping Wang）、Ace Decade Holdings Limited、Dawn State Limited、Rule of Law Society IV Inc.、Rule of Law Foundation III, Inc.、Rule of Law Foundation IV, Inc.、Rule of Law Fund、Rule of Law Society、GTV Media Group, Inc.、Voice of Guo Media, Inc.、Saraca Media Group Inc.、Genever Holdings Corporation、Genever Holdings LLC、Gnews Media Group Inc.、G Fashion LLC、Gmusic LLC、Gnews LLC、Geducation、GFNY, Inc.、G-Club Investments Limited、G Club Operations LLC、G Club US Operations Inc.、G Club US Operations LLC、G Live, LLC、Gbroadcast, LLC、Gposts LLC、HCHK Property\n\n案号 22-50073 文件 1592 提交日期 03/24/23 录入日期 03/24/23 10:57:37 第 551 页，共 1063 页\n\nManagement, Inc.、HCHK Technologies, Inc.、FMV Ltd./Freedom Media Venture Ltd.、Roscalitar 2、Himalaya New World Inc.、US Himalaya Capital Inc.、Hudson Diamond Holding, Inc.、Hudson Diamond Holding LLC、Hudson Diamond NY LLC、Infinity Treasury Management Inc.、Lexington Property and Staffing, Inc.、AI Group Holdings Inc.、Hamilton Capital Holdings Inc.、Booming Sail New York LLC、Himalaya Ventures LLC、Himalaya Ventures LLC、Himalaya Investment LLC、New York MOS Himalaya LLC、MOS Himalaya LLC、Crane Advisory Group、Maywind Trading LLC、Gettr USA, Inc.、Han Chunguang、Bingshang Jiao、Karin Maistrello、Mary Jiang、Jiaming Liu 及 Wencong Wang。\n\n8. “包括”或其任何变体，系指“包括但不限于”。\n\n9. “和”及“或”系指“和/或”，并应同时解释为连词及析取词，以最大限度扩大其范围。\n\n10. “任何”“所有”及“每一”均系指“每一个及全部”。\n\n11. “每一”及“每个”均系指“每一个及全部”。\n\n12. “第三方”系指您本人以外的人员或实体。\n\n13. “转让”具有《破产法典》第 101(54) 条所赋予的含义。\n\n14. “文件”系指属于 Fed. R. Civ. P. 34 范围内的任何信息或物品，并包括但不限于由您占有、保管或控制的、现在或曾经存在的任何种类、类型、性质或描述的每一书面、记录或图形材料，包括电子邮件的所有印刷及电子副本、以电子形式保存的计算机文件、通信函件、备忘录、磁带、速记或手写笔记、任何种类的书面表格、图表、蓝图、绘图、草图、曲线图、计划、文章、规格、日记、信件、\n\n案号 22-50073 文件 1592 提交日期 03/24/23 录入日期 03/24/23 10:57:37 第 552 页，共 1063 页\n\n电报、照片、会议记录、合同、协议、调查资料、计算机打印件、任何种类的数据汇编、电传、传真、电子邮件、短信、即时消息、语音消息、发票、订单表格、支票、汇票、对账单、贷项通知单、报告、持仓报告、摘要、索引、书籍、账簿、笔记本、清单、投影片、录音、目录、广告、宣传材料、影片、录像带、录音带、CD、计算机磁盘、宣传册、小册子、穿孔卡、工时单、推文、社交媒体帖子或任何其他种类的书面或记录材料，以及其全部元数据；无论以何种方式储存（无论为有形或电子形式）、记录、制作或复制；还包括但不限于前述任何文件的草稿或副本，只要其中含有原始文件未载的任何笔记、评论或标记，或其在其他方面与原始文件不完全相同。\n\n15. “人员”系指个人、公司、独资企业、合伙企业、协会或任何其他实体。“人员”亦包括任何代理人、代表或专家，包括但不限于律师或财务顾问。\n\n16. “实体”系指任何自然人、公司、合伙企业、子公司、独资企业、商号、董事会、合资企业、协会、机构、主管机关、委员会或其他商业实体或法人，以及任何关联方、代理人、母公司，包括但不限于律师、财务顾问或任何其他代表。\n\n17. “关于”系指涉及、描述、构成、提及、相关、支持、赞成、反对、加强、减损、位于、结合考虑、影响、证明、表明、报告、记录、暗示、回应、关联、评论、就……而言、有关、与……相关、讨论、显示、描述、反映、分析、构成以及为。\n\n案号 22-50073 文件 1592 提交日期 03/24/23 录入日期 03/24/23 10:57:37 第 553 页，共 1063 页\n\n18. 就任何既定主题事项而言，“与……有关”“涉及”或“相关”系指包括但不限于构成、包括、涉及、包含、体现、反映、识别、陈述、直接或间接提及该特定已识别主题事项，或以任何方式与其相关的任何文件。\n\n19. “通信”系指以最广义且不受限制的方式传递的任何信息或知识（以事实、思想、询问或其他形式）。通信还指所有对话、协议、询问或答复，无论是当面、通过电话、书面方式，或借助电子传输设备进行，并包括但不限于所有函件、电子邮件、录音、传输单、备忘录、电话通信、语音留言、电报、传真、影印传真、电传、即时消息、聊天记录、短信、在留言板或群聊中发布的内容、社交媒体帖子、推文、上传至任何视频平台的视频、电话记录，或在内部或与第三方之间传送的记录。\n\n20. “资产”系指受占有、保管或控制的任何具有经济价值的项目。资产包括所有不动产和动产，包括但不限于房地产、土地、房屋、公寓、产权公寓、汽车、游艇、船只、飞机、喷气式飞机、直升机、现金、银行账户、加密货币、证券、应收账款、存货及其他有形和无形财产。\n\nIV. 应提交的文件\n\n1. 与任何由任何2004取证对象持有、控制、代表其持有，或以其他方式与其相关的账户有关的所有文件，包括任何及所有账户对账单、授权书、委托书、信托文件、指示或表格、已注销支票副本、函件，以及电汇及相关函件和指示。\n\n案件 22-50073 文件 1592 提交日期 03/24/23 录入日期 03/24/23 10:57:37 第 554 页，共 1063 页\n\n2. 与属于任何2004取证对象、由其持有、控制、代表其持有，或以其他方式与其相关的任何资金、证券、财产或资产有关的所有文件，包括任何及所有账户对账单、授权书、委托书、信托文件、指示或表格、已注销支票副本、函件，以及电汇及相关函件和指示。\n\n3. 与同任何2004取证对象进行的任何商业、贸易或金融交易有关的所有文件，包括但不限于任何贷款、信贷额度、寄托、存款、互换、证券交易、抵押贷款或ISDA，包括任何及所有账户对账单、授权书、委托书、信托文件、指示或表格、已注销支票副本、函件，以及电汇及相关函件和指示。\n\n4. 与2004取证对象有关的任何电汇活动有关的所有文件，无论是否存在任何账户，包括但不限于所有电汇收据、账号、余额、授权书、与转账各方有关的身份识别信息、函件、指示或其他记录。\n\n5. 与贵方和2004取证对象之间的任何函件及通信有关的所有文件。\n\n6. 与任何2004取证对象的任何账户有关的所有文件，涉及账户开立、账户获授权使用人及账户维护。\n\n7. 与任何2004取证对象有关的任何反洗钱、了解你的客户或其他合规活动有关的所有文件，包括但不限于任何2004取证对象提供的或贵方获悉的任何信息。\n\n8. 与来自任何国家任何监管机构的通信有关的所有文件，包括但不限于英格兰银行、美国联邦储备系统、证券交易委员会（S.E.C.）、商品期货交易委员会（CFTC）、金融业监管局（FINRA）、中国证券监督管理委员会、中国人民银行、香港证券及期货事务监察委员会及香港金融管理局，涉及任何2004取证对象的通信。\n\n案件 22-50073 文件 1592 提交日期 03/24/23 录入日期 03/24/23 10:57:37 第 556 页，共 1063 页\n\n附件 C-30\n\nB2540（表格2540－规则2004审查传票）（12/15）案件 22-50073 文件 1592 提交日期 03/24/23 录入日期 03/24/23 10:57:37 第 557 页，共\n\n美国破产法院\n\n康涅狄格地区\n\n关于 HO WAN KWOK（郭文贵）等人，\n\n1 案号 22-50073 (JAM) 债务人 第11章\n\n（联合管理）\n\n规则2004审查传票\n\n致：Capital One, N.A.（第一资本银行）\n\n（传票所指向人员的姓名）\n\n证言：现命令贵方于下列规定的时间、日期和地点出席，并根据《联邦破产程序规则》第2004条接受审查并作证。随附授权该审查的法院命令副本。\n\n地点　日期和时间\n\nNeubert, Pepe & Monteith, P.C.（纽伯特、佩佩及蒙蒂斯律师事务所）\n195 Church Street, Floor 13　[TBD]\nNew Haven, Connecticut 06510\n\n审查将通过以下方式记录：法庭记录员/速记员\n\n提交：贵方或贵方代表还必须在审查时携带下列文件、电子存储信息或物品，并必须允许对该材料进行检查、复制、测试或抽样：\n见随附的文件提交请求。\n\n下列《联邦民事诉讼规则》第45条的规定，经《联邦破产程序规则》第9016条适用于破产案件，现随附于后——第45(c)条，关于履行地点；第45(d)条，关于作为传票对象的贵方所受保护；以及第45(e)条和第45(g)条，关于贵方对本传票作出回应的义务及未作回应的潜在后果。\n\n日期：March , 2023\n\n法院书记官\n\n或\n\n书记官或副书记官签名　律师签名\n\n代表发出或请求本传票的第11章受托人 Luc A. Despins（卢克·A·德斯平斯）的律师姓名、地址、电子邮件地址及电话号码如下：\n\nDouglas S. Skalka, Esq.（道格拉斯·S·斯卡尔卡，律师）；Neubert, Pepe & Monteith, P.C.（纽伯特、佩佩及蒙蒂斯律师事务所）；195 Church Street, New Haven, Connecticut 06510 dskalka@npmlaw.com；(203) 821-2000\n\n致发出或请求本传票之人的通知\n\n如本传票要求在审判前提交文件、电子存储信息或有形物品，或检查场所，则在向传票所指向之人送达之前，必须向每一方送达通知及本传票副本。Fed. R. Civ. P. 45(a)(4)。\n\n软件版权 (c) 1996-2022 Best Case, LLC（贝斯特凯斯有限责任公司）- www.bestcase.com Best Case Bankruptcy 1 本第11章案件中的债务人为 Ho Wan Kwok（郭文贵）（又名 Guo Wengui、Miles Guo 和 Miles Kwok，以及众多其他别名）（税务识别号码后四位：9595）、Genever Holdings LLC（税务识别号码后四位：8202）及 Genever Holdings Corporation。受托人、Genever Holdings LLC 及 Genever Holdings Corporation 的邮寄地址为 Paul Hastings LLP（普衡律师事务所），200 Park Avenue, New York, NY 10166，转交 Luc A. Despins，作为 Ho Wan Kwok 财产的受托人（仅为通知和通信之目的）。\n\n送达证明\n\n（除非 Fed. R. Civ. P. 45 要求，否则本节不应向法院提交。）\n\n本人于（日期）收到向（个人姓名及职务，如有）发出的本传票。\n\n本人以下列方式向所列明之人递交副本送达本传票：\n\n于（日期）；或\n\n本人未执行本传票即予退回，原因如下：\n\n除非本传票代表美国或其官员或代理人发出，本人还已向证人支付一天出席费用及法律允许的里程费用，金额为 $ 。\n\n本人差旅费用为 $ ，服务费用为 $ ，合计 $ 。\n\n本人在伪证处罚下声明，该等信息真实且正确。\n\n日期：\n\n送达人签名\n\n正楷姓名及职务\n\n送达人地址\n\n关于尝试送达等的补充信息：\n\n《联邦民事诉讼规则》第45(c)、(d)、(e)及(g)条（自12/1/13生效）（经《联邦破产程序规则》第9016条适用于破产案件）\n\n(c) 履行地点。\n\n(1) 审判、听证或证言记录。传票仅可按下列方式命令某人出席审判、听证或证言记录：\n\n(A) 在该人居住、受雇或经常亲自从事商业活动地点的100英里范围内；或\n\n(B) 在该人居住、受雇或经常亲自从事商业活动所在州内，如果该人\n\n(i) 是当事人或当事人的高级职员；或\n\n(ii) 被命令出席审判且不会产生重大费用。\n\n(2) 其他取证。传票可命令：\n\n(A) 在该人居住、受雇或经常亲自从事商业活动地点的100英里范围内的地点提交文件、电子存储信息或物品；以及\n\n(B) 在应检查的场所检查场所。\n\n(d) 对作为传票对象之人的保护；执行。\n\n(1) 避免不当负担或费用；制裁。负责发出和送达传票的一方或律师必须采取合理措施，避免对作为传票对象之人施加不当负担或费用。要求履行的地区法院必须执行此项义务，并对未遵守者的一方或律师施加适当制裁，该制裁可包括收入损失及合理律师费。\n\n(2) 命令提交材料或允许检查。\n\n(A) 无须出席。被命令提交文件、电子存储信息或有形物品，或允许检查场所之人，无须亲自出席提交或检查地点，除非同时被命令出席证言记录、听证或审判。\n\n(B) 异议。被命令提交文件或有形物品，或允许检查之人，可以就检查、复制、测试或抽样任何或全部材料、检查场所，或以被要求的一种或多种形式提交电子存储信息，向传票指定的一方或律师送达书面异议。异议必须在规定履行时间或传票送达后14日届满两者中较早者之前送达。如提出异议，适用下列规则：\n\n(i) 送达方可在任何时候，通知被命令之人后，向要求履行的地区法院提出动议，请求作出强制提交或检查的命令。\n\n(ii) 仅可依照该命令所指示的方式要求实施这些行为，且该命令必须保护既非当事人亦非当事人高级职员之人，免受因履行而产生的重大费用。\n\n(3) 撤销或修改传票。\n\n(A) 必须撤销或修改的情形。经及时动议，要求履行的地区法院必须撤销或修改符合下列情形的传票：\n\n(i) 未给予合理履行时间；\n\n(ii) 要求某人在第45(c)条规定的地域限制以外履行；\n\n(iii) 要求披露享有特权或受其他保护的事项，而无任何适用的例外或豁免；或\n\n(iv) 对某人施加不当负担。\n\n(B) 可以撤销或修改的情形。为保护作为传票对象或受传票影响之人，要求履行的地区法院可经动议撤销或修改要求下列事项的传票：\n\n(i) 披露商业秘密或其他保密研究、开发或商业信息；或\n\n(ii) 披露未受聘专家的意见或信息，该等意见或信息既不描述争议中的具体事件，亦源于该专家未应任何一方请求而进行的研究。\n\n(C) 规定条件作为替代方案。在第45(d)(3)(B)条所述情形下，如送达方：\n\n(i) 证明对该证言或材料具有重大需要，且若不承受不当困难则无法以其他方式满足该需要；并且\n\n(ii) 确保被传唤之人将获得合理补偿，\n\n法院可不撤销或修改传票，而命令在规定条件下出席或提交。\n\n(e) 对传票作出回应的义务。\n\n(1) 提交文件或电子存储信息。下列程序适用于提交文件或电子存储信息：\n\n(A) 文书。对要求出示文书的传票作出回应的人，必须按照文书在日常业务过程中保存的原样出示，或者必须对其进行整理和标注，以对应请求中的类别。\n\n(B) 未指定的电子存储信息出示形式。如传票未指定电子存储信息的出示形式，作出回应的人必须以其通常保存的某一种或多种形式，或者以一种或多种合理可用的形式出示该信息。\n\n(C) 仅以一种形式出示的电子存储信息。作出回应的人无需以一种以上的形式出示相同的电子存储信息。\n\n(D) 无法合理访问的电子存储信息。作出回应的人无需就其认定因不当负担或费用而无法合理访问的来源中的电子存储信息提供证据开示。在提出强制证据开示动议或保护令动议时，作出回应的人必须证明该信息因不当负担或费用而无法合理访问。如作出该证明，法院仍可在提出请求的一方证明存在正当理由时，命令从此类来源进行证据开示，并应考虑 Rule 26(b)(2)(C) 的限制。法院可以规定证据开示的条件。\n\n(2) 主张特权或保护。\n\n(A) 被扣留的信息。基于该信息享有特权或作为审判准备材料受到保护的主张而扣留被传唤信息的人，必须：(i) 明确提出该主张；以及\n\n(ii) 以一种在不披露本身享有特权或受保护的信息的情况下，能够使各方评估该主张的方式，说明被扣留文书、通信或有形物的性质。\n\n(B) 已出示的信息。如为回应传票而出示的信息受到特权主张或作为审判准备材料受到保护的主张，提出该主张的人可以将该主张及其依据通知任何收到该信息的一方。收到通知后，一方必须立即返还、隔离或销毁所指明的信息及其持有的任何副本；在该主张得到解决前，不得使用或披露该信息；如该方在收到通知前已披露该信息，必须采取合理措施追回该信息；并可以立即将该信息密封提交给要求履行传票的地区的法院，以裁定该主张。出示该信息的人必须在该主张得到解决前保存该信息。\n\n(g) 藐视法庭。要求履行传票的地区的法院——以及在动议被移送后，签发传票的法院——可以对已被送达但无充分理由未遵从传票或与其有关命令的人，以藐视法庭论处。\n\n有关查阅传票材料，见 Fed.R.Civ.P.45(a) 委员会说明（2013）\n\n……\n\n文书出示请求\nI. 指示\n\n1. 除非另有说明，下述文书请求（统称“请求”，单称“一项请求”）必须分别且具体地作出回应。除非出于善意提出异议，否则必须对每项请求作出完整答复；如提出异议，必须如下文所述详细说明贵方异议的理由。如异议仅涉及某项请求的一部分，或其中包含的某个词、短语或条款，贵方必须仅就该部分说明异议，并对其余请求作出回应。\n\n2. 电子存储信息必须依照以下指示出示：\n\n- a. 图像。黑白图像必须为 300 DPI Group IV 单页 TIFF 文件。彩色图像必须以 JPEG 格式出示。文件名不得包含嵌入空格或特殊字符（包括逗号）。文件夹名称不得包含嵌入空格或特殊字符（包括逗号）。所有 TIFF 图像文件必须具有唯一文件名，即 Bates 编号。图像必须在每张图像的右下角标注连续的 Bates 编号。每个文件夹中的 TIFF 文件数量不应超过 1000 个文件。Excel（微软 Excel）电子表格应具有一个以该文件 Bates 编号命名的占位图像。\n- b. 图像加载文件\n\t- a. Concordance®（康科丹斯）数据文件。数据文件（.DAT）包含将加载至 Concordance® 数据库的所有字段化信息。.DAT 文件的第一行必须为标明字段名称的标题行。.DAT 文件必须使用以下 Concordance® 默认分隔符：逗号 ASCII 字符（020） 引号 þ ASCII 字符（254）。日期字段应以 mm/dd/yyyy 格式提供。日期字段和时间字段必须为两个单独字段。如文书包括已成像的电子邮件及附件，则必须包括附件字段，以保留电子邮件与其附件之间的父项/子项关系。必须包括 OCRPATH 字段，以提供已出示存储介质上提取文本文件的文件路径和名称。文本文件必须以 FIRSTBATES 命名。不得在 .DAT 文件中包括文本。对于含有原生文件的文书，必须包括 LINK 字段，以提供原生文件的文件路径和\n\n名称。原生文件必须以 FIRSTBATES 命名。\n\n- b. Concordance Image®（康科丹斯图像）或 Opticon（奥普蒂康）交叉引用文件。图像交叉引用文件（.LOG 或 .OPT）将图像与数据库记录关联。该文件应为逗号分隔文件，每行包含七个字段，并且数据库中每一图像均应在交叉引用文件中有一行，格式如下：ImageID,VolumeLabel,ImageFilePath,DocumentBreak,FolderBreak,Box Break,PageCoun。\n- c. 文书文本。文本必须作为单独的文本文件出示，而不得作为 .DAT 文件中的字段。文本文件的完整路径（OCRPATH）应包括在 .DAT 文件中。建议提供以 FIRSTBATES/Image Key 命名的文书级 ANSI 文本文件。提取的文本文件必须位于单独的文件夹中，每个文件夹内的文本文件数量不应超过 1,000 个文件。文件夹名称中不得有特殊字符（包括逗号）。文本文件必须按文书级别提供。\n- d. 特定文件类型的原生出示。为完整理解其内容和含义而合理需要以原生格式查看的文件类型，必须以原生格式出示。这些包括但不限于电子表格、类电子表格文件（Microsoft Excel（微软 Excel）、逗号分隔值、制表符分隔值等）、Microsoft PowerPoint（微软 PowerPoint）或其他特殊演示文件、数据库文件以及音频/视频文件。应提供一张标有 Bates 编号的分隔页图像，以表明原生文件的存在，并在 .dat 文件中以字段形式包括原生文件的路径。所出示的原生文件应以与该文件分隔页对应的 Bates 编号命名。将原生文件归入按递增方式命名的“NATIVE”目录中，并与图像目录分开。\n- e. 去重。对于存在完全重复件的每一电子文书，出示单一副本。对于电子邮件，根据由 BCC、Body、CC、From、IntMsgID、To 和 Attach 属性生成的 MD5 哈希值合并重复件。对于电子邮件附件和独立电子文件，根据整个文件的 MD5 哈希值合并重复件。\n- f. 元数据。以符合 Concordance 的加载文件（.dat）形式出示每份文书的提取元数据。.DAT 文件的第一行必须为标明字段名称的标题行。.DAT 文件必须使用以下 Concordance 默认分隔符：逗号 , ASCII 字符（020） 引号 þ ASCII 字符（254）\n\n日期字段应以 mm/dd/yyyy 格式提供。日期字段和时间字段必须为两个单独字段。以下列出所需元数据：\nCase 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 562 of 1063\n\n字段名称　样本数据　说明\n\nFIRSTBATES　EDC0000001　原生文件文书/电子邮件的第一个 Bates 编号\nLASTBATES　EDC0000001　原生文件文书/电子邮件的最后一个 Bates 编号\n**对于单页文件，\nLASTBATES 字段应予填写\nATTACHRANGE　EDC0000001\n-　父文书第一页的 Bates 编号至\nEDC0000015　最后一份“子”附件文书最后一页的 Bates 编号\nBEGATTACH　EDC0000001　附件范围的第一个 Bates 编号\nENDATTACH　EDC0000015　附件范围的最后一个 Bates 编号\nCUSTODIAN　Smith, John　电子邮件：电子邮件所在的邮箱\n原生文件：文书来源的个人或部门名称\nFROM　John Smith　电子邮件：发件人\n\n原生文件：文书作者\n**多个条目应以分号分隔\nTO　Coffman, Janice; LeeW　收件人\n[mailto:LeeW@MSN.com]　**多个条目应以分号分隔\nCC　Frank Thompson [mailto:　抄送收件人\nfrank_Thompson@cdt.com]　**多个条目应以分号分隔\nBCC　John Cain　密送收件人\n**多个条目应以分号分隔\nSUBJECT　Board Meeting Minutes　电子邮件：电子邮件主题行 原生文件：文书标题\n（如有）\nFILE_NAME　BoardMeetingMinutes.docx　原生文件：原始原生文件名称，\n包括扩展名\nDATE_SENT　10/12/2010　电子邮件：电子邮件发送日期\n原生文件：（空）\nTIME_SENT/\nTIME_ZONE　07:05 PM GMT　电子邮件：电子邮件发送时间/电子邮件标准化所采用的时区\nTIME_ZONE　GMT　在转换期间电子邮件被标准化所采用的时区。\nLINK　EDC0000001.msg　电子邮件或原生文件文书的超链接\n**链接文件必须按 FIRSTBATES 编号命名\nFILE_EXTEN　MSG　表示电子邮件或原生文件的文件类型扩展名\nAUTHOR　John Smith　电子邮件：（空）\n原生文件：文书作者\nDATE_CREATED　10/10/2010　电子邮件：（空）\n原生文件：文书创建日期\n\nCase 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 563 of 1063\n\nTIME_CREATED　10:25 AM　电子邮件：（空）\n\n原生文件：文书创建时间\n**该数据必须为单独字段，不得与 DATE_CREATED 字段合并\nDATE_MOD　10/12/2010　电子邮件：（空）\n原生文件：文书最后修改日期\nTIME_MOD　07:00 PM　电子邮件：（空）\n原生文件：文书最后修改时间\n**该数据必须为单独字段，不得与 DATE_MOD 字段合并\nDATE_ACCESSD　10/12/2010　电子邮件：（空）\n原生文件：文书最后访问日期\nTIME_ACCESSD　07:00 PM　电子邮件：（空）\n原生文件：文书最后访问时间\n**该数据必须为单独字段，不得与 DATE_ACCESSD 字段合并\nFILE_SIZE　5,952　原生文件文书/电子邮件的大小，单位为 KB\nPGCOUNT　1　原生文件文书/电子邮件的页数\nPATH　电子邮件：（空）\nAgenda.doc　原生文件：原生文件文书的存储路径，包括原始文件名称。\nINTFILEPATH　Personal Folders\\Deleted　电子邮件：电子邮件的原始位置，包括\nItems\\Board Meeting　原始文件名称。\nMinutes.msg　原生文件：（空）\nINTMSGID　<000805c2c71b\\$75977050\\$　电子邮件：唯一消息 ID 原生文件：（空）\ncb8306d1@MSN>\nMD5HASH　d131dd02c5e6eec4693d9a0　文书的 MD5 哈希值。\n698aff95c\n2fcab58712467eab4004583e\nb8fb7f89\nOCRPATH　TEXT/001/EDC0000001.txt　原生文件提取文本的路径\n\n3. 每项请求独立运作且应独立解释，除非另有说明，任何请求均不限制任何其他请求的范围。\n\n4. 所有文书均应按其在通常业务过程中保存的原样出示，或者应进行整理和标注，以对应本请求中的类别。\n\n5. 本文件所载每项请求均延及所有文书：(a) 由贵方占有、保管或控制的；或 (b) 由任何代表贵方行事的人占有、保管或控制的，\nCase 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 564 of 1063\n\n包括贵方律师或其他代表及顾问。每份文书均应完整出示。\n\n6. 如要求您提供一份已不再由您持有、保管或控制的文件，则您的答复必须：(a) 详细描述该文件的性质及其内容；(b) 确定编制或撰写该文件的人员（以及，如适用，向其发送该文件的人员）；(c) 确定该文件编制或创建的日期；(d) 说明该文件是否：(i) 遗失或丢失；(ii) 已被销毁；(iii) 已自愿或非自愿地转交给他人；或 (iv) 以其他方式处置；(e) 说明该等处置的理由以及围绕该等处置的事实和情形；(f) 确定授权该等处置的人员；(g) 确定该等处置的日期或大致日期；(h) 说明该文件最后一次由您持有、保管或控制的时间；以及 (i) 确定目前持有、保管或控制该文件的人员（如有）。\n\n7. 如要求您提供一份已被销毁的文件，则除前述指示所要求的信息外，您的答复还必须说明：(a) 该文件被销毁的理由；(b) 销毁该文件的人员身份；以及 (c) 指示销毁该文件的人员身份。\n\n8. 如您主张所要求的文件享有特权或属于律师工作成果，则您的答复必须：(a) 说明：(i) 足以支持您关于该文件享有特权之主张的文件描述；(ii) 文件标题；(iii) 文件日期；(iv) 文件作者；(v) 文件收件人；(vi) 收到或阅览该文件原件或任何草稿、副本或复制件的每一人员身份；(vii) 该文件本身，或文件中包含或提及的任何信息，是否由任何其他人员持有、保管或控制；如是，则说明该等人员的身份，以及说明该信息如何进入其持有范围；(viii) 据以拒绝提供该文件的特权主张；以及 (ix) 您将据以支持该等特权主张的所有情形；以及 (b) 就依据 D. Conn. L. Civ. R. 26(e) 提出特权主张而拒绝提供的每一文件，制作一份特权日志，其中载明本指示第(a)部分所要求的全部信息。对于文件请求中未就其提出特权或工作成果主张的任何部分，应完整提供相应文件。\n\nCase 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 565 of 1063\n\n9. 如一份原本应予提供的文件的一部分包含受特权主张约束的信息，则仅应按照上述指示从该文件中删除或涂黑受特权主张约束的该部分，其余部分应予提供。\n\n10. 该等请求具有持续性质。现指示您：(a) 一旦得知先前答复不完整或不正确，应立即补充或更正任何后来得知不完整或不正确的答复；以及 (b) 提供根据以下规定所要求的任何额外文件\n\n11. 如文件使用英语以外的语言，您应提供该文件。如文件使用英语以外的语言，且存在英文译本，您应同时提供两份文件。\n\n12. 对实体的所有提述均包括其所有关联方。\n\n13. 对个人姓名的所有提述均包括所有其他姓名、别名或昵称。\n\nCase 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 566 of 1063\n\n14. 除非另有明确说明，文件请求所涵盖的期间为自 February 5, 2012 起至应提交文件请求答复之日止。\n\nII. 解释规则\n\n15. (a) 任何单数名词的使用应解释为包括复数，反之亦然；以及 (b) 任何时态动词的使用应解释为该动词在所有其他时态下的使用。\n\n16. (a) “and”和“or”应视必要情况分别解释为连词或选择词，以使原本可能被解释为超出任何请求范围的所有答复均纳入该请求范围；以及 (b) “each”和“any”应视为包括并涵盖“every”和“all”二词。\n\nIII. 定义\n\n经 D. Conn. Bankr. L.R. 2004-1(a) 纳入的 D. Conn. L. Civ. R. 26(c) 所提供的定义以及 D. Conn. L. Civ. R. 26(d) 所提供的解释规则，适用于该等文件请求。此外，该等文件请求中使用的下列术语具有下列含义：\n\n1. “您”或“您的”或“您本人”系指 Capital One, NA（第一资本银行，全国协会）及其所有关联方。\n\n2. “债务人”系指 Ho Wan Kwok（郭文贵）（又名 Miles Kwok（郭文贵）、Miles Guo（郭文贵）、Guo Wengui（郭文贵）、Guo Haoyun（郭浩云）、郭文贵，或任何其他别名），以及其雇员、代理人、律师、顾问或任何代表其行事的人。\n\nCase 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 567 of 1063\n\n3. “债务人之子”系指 Qiang Guo（郭强）（又名 Mileson Kwok（郭强）、郭强，或任何其他别名），以及其雇员、代理人、律师、顾问或任何代表其行事的人。\n\n4. “债务人之女”系指 Mei Guo（郭美）（又名 Mei Gui（郭美）、郭美，或任何其他别名），以及其雇员、代理人、律师、顾问或任何代表其行事的人。\n\n5. “债务人所谓之妻”系指 Hing Chi Ngok（岳庆芝）（又名 Hing Chi Ng（岳庆芝）、Yue Qingzhi（岳庆芝）、岳庆芝，或任何其他别名），以及其雇员、代理人、律师、顾问或任何代表其行事的人。\n\n6. “债务人家庭成员”系指单独及合称的债务人、债务人之子、债务人之女及债务人所谓之妻，以及与债务人具有任何其他家庭关系的人。\n\n7. “2004 取证对象”系指单独及合称的债务人、债务人家庭成员、ACA Capital Group Limited（ACA资本集团有限公司）、Himalaya International Financial Group Ltd.（喜马拉雅国际金融集团有限公司）、Himalaya International Clearing Ltd.（喜马拉雅国际清算有限公司）、Himalaya International Payments Ltd.（喜马拉雅国际支付有限公司）、Himalaya International Reserves Ltd.（喜马拉雅国际储备有限公司）、Jesse Brown（杰西·布朗）、William Je（威廉·杰）、William Je（威廉·杰）、Eastern Profit Corporation Limited（东方利润有限公司）、HK International Funds Investments (USA) Limited LLC（香港国际基金投资〈美国〉有限责任公司）、Bravo Luck Limited（鸿运有限公司）、Golden Spring (New York) Ltd.（金泉〈纽约〉有限公司）、Lamp Capital LLC（兰普资本有限责任公司）、Greenwich Land LLC（格林尼治土地有限责任公司）、Qu Guo Jiao（郭娇）、Daniel Thomas Podhaskie（丹尼尔·托马斯·波达斯基）、Yvette Wang（王燕萍）（又名 Yanping Wang（王燕萍）、又名 Yan Ping Wang（王燕萍））、Ace Decade Holdings Limited（艾斯十年控股有限公司）、Dawn State Limited（黎明州有限公司）、Rule of Law Society IV Inc.（法治协会IV公司）、Rule of Law Foundation III, Inc.（法治基金会III公司）、Rule of Law Foundation IV, Inc.（法治基金会IV公司）、Rule of Law Fund（法治基金）、Rule of Law Society（法治协会）、GTV Media Group, Inc.（GTV传媒集团公司）、Voice of Guo Media, Inc.（郭之声传媒公司）、Saraca Media Group Inc.（萨拉卡传媒集团公司）、Genever Holdings Corporation（吉尼弗控股公司）、Genever Holdings LLC（吉尼弗控股有限责任公司）、Gnews Media Group Inc.（Gnews传媒集团公司）、G Fashion LLC（G时尚有限责任公司）、Gmusic LLC（G音乐有限责任公司）、Gnews LLC（Gnews有限责任公司）、Geducation（G教育）、GFNY, Inc.（GFNY公司）、G-Club Investments Limited（G俱乐部投资有限公司）、G Club Operations LLC（G俱乐部运营有限责任公司）、G Club US Operations Inc.（G俱乐部美国运营公司）、G Club US Operations LLC（G俱乐部美国运营有限责任公司）、G Live, LLC（G直播有限责任公司）、Gbroadcast, LLC（G广播有限责任公司）、Gposts LLC（G帖子有限责任公司）、HCHK Property\n\nCase 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 568 of 1063\n\nManagement, Inc.（HCHK物业管理公司）、HCHK Technologies, Inc.（HCHK科技公司）、FMV Ltd./Freedom Media Venture Ltd.（FMV有限公司/自由传媒风投有限公司）、Roscalitar 2（罗斯卡利塔尔2）、Himalaya New World Inc.（喜马拉雅新世界公司）、US Himalaya Capital Inc.（美国喜马拉雅资本公司）、Hudson Diamond Holding, Inc.（哈德逊钻石控股公司）、Hudson Diamond Holding LLC（哈德逊钻石控股有限责任公司）、Hudson Diamond NY LLC（哈德逊钻石纽约有限责任公司）、Infinity Treasury Management Inc.（无限财资管理公司）、Lexington Property and Staffing, Inc.（列克星敦物业与人力配置公司）、AI Group Holdings Inc.（AI集团控股公司）、Hamilton Capital Holdings Inc.（汉密尔顿资本控股公司）、Booming Sail New York LLC（兴盛帆船纽约有限责任公司）、Himalaya Ventures LLC（喜马拉雅创投有限责任公司）、Himalaya Ventures LLC（喜马拉雅创投有限责任公司）、Himalaya Investment LLC（喜马拉雅投资有限责任公司）、New York MOS Himalaya LLC（纽约MOS喜马拉雅有限责任公司）、MOS Himalaya LLC（MOS喜马拉雅有限责任公司）、Crane Advisory Group（克兰咨询集团）、Maywind Trading LLC（五月风贸易有限责任公司）、Gettr USA, Inc.（GETTR美国公司）、Han Chunguang（韩春光）、Bingshang Jiao（焦冰上）、Karin Maistrello（卡琳·迈斯特雷洛）、Mary Jiang（江玛丽）、Jiaming Liu（刘嘉明）及 Wencong Wang（王文聪）。\n\n8. “包括”或其任何变体意为“包括但不限于”。\n\n9. “and”和“or”意为“and/or”，并应同时解释为连词和选择词，以最大限度扩大其范围。\n\n10. “any”、“all”和“each”意为“每一个和所有”。\n\n11. “each”和“every”意为“每一个和所有”。\n\n12. “第三方”系指您本人以外的人员或实体。\n\n13. “转让”具有《破产法》第 101(54) 条赋予该词的含义。\n\n14. “文件”系指属于 Fed. R. Civ. P. 34 范围内的任何信息或物品，并包括但不限于目前或曾经由您持有、保管或控制的任何种类、类型、性质或描述的每一书面、记录或图形材料，包括电子邮件的所有打印件和电子副本、以电子形式保存的计算机文件、通信函件、备忘录、磁带、速记或手写笔记、任何种类的书面表格、图表、蓝图、绘图、草图、图形、计划、文章、规格、日记、信件、\n\nCase 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 569 of 1063\n\n电报、照片、会议记录、合同、协议、调查资料、计算机打印件、任何种类的数据汇编、电传、传真、电子邮件、短信、即时消息、语音消息、发票、订购单、支票、汇票、对账单、贷项通知单、报告、持仓报告、摘要、索引、书籍、分类账、笔记本、日程表、透明胶片、录音制品、目录、广告、宣传材料、影片、录像带、录音带、CD、计算机磁盘、宣传册、小册子、穿孔卡、工时单、推文、社交媒体帖子或任何其他种类的书面或记录材料，以及其所有元数据，无论以何种方式储存（无论为有形或电子形式）、记录、制作或复制；并且还包括但不限于上述任何材料的草稿或副本，如其中包含原始文件中未见的任何种类笔记、评论或标记，或在其他方面与原始文件并不相同。\n\n15. “人员”系指个人、公司、独资企业、合伙企业、协会或任何其他实体。“人员”还包括任何代理人、代表或专家，包括但不限于律师或财务顾问。\n\n16. “实体”系指任何自然人、公司、合伙企业、子公司、独资企业、商号、董事会、合资企业、协会、机构、主管机关、委员会或其他商业实体或法人，以及任何关联方、代理人、母公司，包括但不限于律师、财务顾问或任何其他代表。\n\n17. “关于”意为涉及、描述、构成、提及、有关、支持、赞成、反对、加强、削弱、位于、结合考虑、影响、证明、表明、报告、记录、暗示、回应、连接、评论、就……而言、有关、与……相关、讨论、显示、描述、反映、分析、构成及属于。\n\nCase 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 570 of 1063\n\n18. 就任何特定事项而言，“与……有关”、“涉及”或“相关”意为，包括但不限于，构成、包含、涉及、含有、体现、反映、确认、陈述、直接或间接提及，或以任何方式与所确定的特定事项相关的任何文件。\n\n19. “通信”系指，以最广泛的可能含义且不受限制地，任何信息或知识的传递（以事实、观点、询问或其他形式）。通信还指所有谈话、协议、询问或答复，无论是当面、通过电话、书面方式，还是通过电子传输设备进行，并包括但不限于所有信函、电子邮件、录音、传输单、备忘录、电话通信、语音留言、电报、传真、电传副本、电传、即时消息、聊天、短信、发布至留言板或群聊的内容、社交媒体帖子、推文、上传至任何视频平台的视频、电话记录，或在内部或与第三方之间传递的记录。\n\n20. “资产”系指任何处于占有、保管或控制之下的具有经济价值的项目。资产包括所有不动产和动产，包括但不限于房地产、土地、房屋、公寓、共管公寓、汽车、游艇、船只、飞机、喷气式飞机、直升机、现金、银行账户、加密货币、证券、应收账款、存货以及其他有形和无形财产。\n\nIV. 应提交的文件\n\n1. 与由任何 2004 取证对象持有、控制、代表其持有或以其他方式与其有关的任何账户有关的所有文件，包括任何及所有账户对账单、授权书、委托书、信托、指示或表格、已注销支票副本、通信，以及电汇和相关通信及指示。\n\n案号 22-50073 文件 1592 提交日期 03/24/23 录入日期 03/24/23 10:57:37 第 571 页，共 1063 页\n\n2. 与属于任何 2004 取证对象、由其持有、控制、代表其持有或以其他方式与其有关的任何资金、证券、财产或资产有关的所有文件，包括任何及所有账户对账单、授权书、委托书、信托、指示或表格、已注销支票副本、通信，以及电汇和相关通信及指示。\n\n3. 与同任何 2004 取证对象进行的任何商业、贸易或金融交易有关的所有文件，包括但不限于任何贷款、信贷额度、寄托、存款、掉期、证券交易、抵押贷款或 ISDA，包括任何及所有账户对账单、授权书、委托书、信托、指示或表格、已注销支票副本、通信，以及电汇和相关通信及指示。\n\n4. 与涉及 2004 取证对象的任何电汇活动有关的所有文件，不论是否存在任何账户，包括但不限于所有电汇收据、账户号码、余额、授权、与转账各方有关的身份识别信息、通信、指示或其他记录。\n\n5. 与你方和 2004 取证对象之间的任何信函和通信有关的所有文件。\n\n6. 与任何 2004 取证对象的任何账户有关的所有文件，涉及账户开立、账户获授权用户及账户维护。\n\n7. 与涉及任何 2004 取证对象的任何反洗钱、了解你的客户或其他合规活动有关的所有文件，包括但不限于任何 2004 取证对象提供的信息，或你方获知的信息。\n\n8. 与同任何国家的任何监管机构进行的任何通信有关的所有文件，包括但不限于英格兰银行（Bank of England）、美国联邦储备系统（United States Federal Reserve）、S.E.C.（美国证券交易委员会）、CFTC（美国商品期货交易委员会）、FINRA（美国金融业监管局）、中国证券监督管理委员会（China Securities Regulatory Commission）、中国人民银行（People's Bank of China）、香港证券及期货事务监察委员会（Hong Kong Securities and Futures Commission）及香港金融管理局（Hong Kong Monetary Authority），且涉及任何 2004 取证对象。\n\n附件 C-31\n\nB2540（表格 2540——规则 2004 审查传票）（12/15）案号 22-50073 文件 1592 提交日期 03/24/23 录入日期 03/24/23 10:57:37 第 574 页，共\n\n美国破产法院 1063\n\n康涅狄格地区\n\n关于 HO WAN KWOK（郭文贵）等人，\n\n1 案号 22-50073 (JAM)\n\n债务人 第 11 章\n\n（合并管理）\n\n规则 2004 审查传票\n\n致：Amazon Web Services LLC（亚马逊云服务有限责任公司）\n\n（传票所指向人员的姓名）\n\n证言：兹命令你方于下列规定的时间、日期和地点出席，以根据《联邦破产程序规则》第 2004 条接受审查并作证。随附准许该审查的法院命令副本。\n\n地点　日期和时间\n\nNeubert, Pepe & Monteith, P.C.（纽伯特、佩佩与蒙泰思专业公司）\n195 Church Street, Floor 13　[TBD]\nNew Haven, Connecticut 06510\n\n审查将采用以下方式记录：法庭记录员/速记员\n\n提交：你方或你方代表还必须将下列文件、电子存储信息或物品携带至审查现场，并必须允许对该材料进行检查、复制、测试或抽样：\n\n见随附的文件提交请求。\n\n下列 Fed. R. Civ. P. 45 条款，经 Fed. R. Bankr. P. 9016 规定适用于破产案件，随附于后——有关履行地点的 Rule 45(c)；有关你方作为传票对象所受保护的 Rule 45(d)；以及有关你方回应本传票的义务及未回应的潜在后果的 Rule 45(e) 和 45(g)。\n\n日期：March , 2023\n\n法院书记员\n\n或\n\n书记员或副书记员签名　律师签名\n\n签发或申请本传票并代表第 11 章受托人 Luc A. Despins（卢克·A·德斯平斯）的律师姓名、地址、电子邮件地址及电话号码如下：\n\nDouglas S. Skalka, Esq.（道格拉斯·S·斯卡尔卡律师）；Neubert, Pepe & Monteith, P.C.（纽伯特、佩佩与蒙泰思专业公司）；195 Church Street, New Haven, Connecticut 06510；dskalka@npmlaw.com；(203) 821-2000\n\n致签发或申请本传票者的通知\n\n如本传票命令在审判前提交文件、电子存储信息或有形物品，或检查场所，则必须在向本传票所指向人员送达之前，向每一方当事人送达通知及本传票副本。Fed. R. Civ. P. 45(a)(4)。\n\n软件版权所有 (c) 1996-2022 Best Case, LLC（最佳案件有限责任公司）- www.bestcase.com Best Case Bankruptcy 1 本第 11 章案件中的债务人为 Ho Wan Kwok（郭文贵）（又名 Guo Wengui、Miles Guo 和 Miles Kwok，以及众多其他别名）（税务识别号码后四位：9595）、Genever Holdings LLC（税务识别号码后四位：8202）及 Genever Holdings Corporation。受托人、Genever Holdings LLC 和 Genever Holdings Corporation 的邮寄地址为 Paul Hastings LLP（普衡律师事务所）, 200 Park Avenue, New York, NY 10166，转交 Luc A. Despins，作为 Ho Wan Kwok 遗产的受托人（仅为通知和通信之目的）。\n\n送达证明\n\n（除非 Fed. R. Civ. P. 45 要求，否则本节不应向法院提交。）\n\n我于（日期）收到向（个人姓名及职务，如有）发出的本传票。\n\n我按如下方式向具名人员交付副本，从而送达本传票：\n\n于（日期）送达；或\n\n我未执行本传票即予退回，原因如下：\n\n除非本传票系代表美国或其官员或代理人签发，我还已向证人支付一天出席的费用及法律允许的里程费，金额为 \\$ 。\n\n我的差旅费用为 \\$ ，服务费用为 \\$ ，合计为 \\$ 。\n\n我在伪证罪处罚下声明，该信息真实且准确。\n\n日期：\n\n送达人员签名\n\n正楷姓名及职务\n\n送达人员地址\n\n有关尝试送达等的补充信息：\n\n《联邦民事诉讼规则》45(c)、(d)、(e) 和 (g)（自 12/1/13 生效）（经《联邦破产程序规则》9016 规定适用于破产案件）\n\n(c) 履行地点。\n\n(1) 审判、听证或证言录取。传票仅可按如下规定命令某人出席审判、听证或证言录取：\n\n(A) 在该人居住、受雇或经常亲自从事商业活动地点的 100 英里以内；或\n\n(B) 在该人居住、受雇或经常亲自从事商业活动所在州内，如果该人\n\n(i) 是一方当事人或一方当事人的高级人员；或\n\n(ii) 被命令出席审判且不会产生重大费用。\n\n(2) 其他取证。传票可以命令：\n\n(A) 在该人居住、受雇或经常亲自从事商业活动地点的 100 英里以内的地点提交文件、电子存储信息或物品；以及\n\n(B) 在被检查的场所检查场所。\n\n(d) 保护受传票约束人员；执行。\n\n(1) 避免不当负担或费用；制裁。负责签发及送达传票的一方当事人或律师必须采取合理措施，避免对受传票约束的人施加不当负担或费用。要求履行的地区法院必须执行该义务，并对未遵守者的一方当事人或律师施加适当制裁，该制裁可包括收入损失和合理的律师费。\n\n(2) 命令提交材料或允许检查。\n\n(A) 无须出席。被命令提交文件、电子存储信息或有形物品，或允许检查场所的人，无须亲自到达提交或检查地点，除非同时被命令出席证言录取、听证或审判。\n\n(B) 异议。被命令提交文件或有形物品，或允许检查的人，可以向传票中指定的一方当事人或律师送达书面异议，反对检查、复制、测试或抽样任何或全部材料，或反对检查场所，或反对以所要求的一种或多种形式提交电子存储信息。异议必须在规定履行时间届满之前或传票送达后 14 天之前两者中较早的时间送达。如提出异议，适用下列规则：\n\n(i) 送达方可在任何时候通知被命令人员后，向要求履行的地区法院提出动议，请求作出强制提交或检查的命令。\n\n(ii) 仅可依照该命令的指示要求实施这些行为，且该命令必须保护并非一方当事人或一方当事人高级人员的人免于承担因履行而产生的重大费用。\n\n(3) 撤销或修改传票。\n\n(A) 必须撤销或修改的情形。经及时动议，要求履行的地区法院必须撤销或修改具有下列情形的传票：\n\n(i) 未给予合理的履行时间；\n\n(ii) 要求某人在 Rule 45(c) 规定的地域限制以外履行；\n\n(iii) 要求披露享有特权或受其他保护的事项，且不适用任何例外或放弃；或\n\n(iv) 对某人施加不当负担。\n\n(B) 可以撤销或修改的情形。为保护受传票约束或受其影响的人，要求履行的地区法院可以依动议撤销或修改要求下列事项的传票：\n\n(i) 披露商业秘密或其他保密的研究、开发或商业信息；或\n\n(ii) 披露未受聘专家的意见或信息，该意见或信息并非描述争议中的具体事件，且源于该专家未经任何一方当事人请求所进行的研究。\n\n(C) 以规定条件作为替代。在 Rule 45(d)(3)(B) 所述情形下，如送达方：\n\n(i) 证明对证言或材料具有重大需要，且若不遭受不当困难则无法以其他方式满足该需要；并且\n\n(ii) 确保受传票人员将获得合理报酬，\n\n法院可以不撤销或修改传票，而命令在规定条件下出席或提交。\n\n(e) 回应传票的义务。\n\n(1) 提交文件或电子存储信息。下列程序适用于提交文件或电子存储信息：\n\n(A) 文件。对要求提交文件的传票作出回应的人员，必须按照其在日常业务过程中保存的方式提交文件，或者必须对文件进行整理和标记，使其与要求中的类别相对应。\n\n(B) 未指定的电子存储信息提交形式。如果传票未指定提交电子存储信息的形式，作出回应的人员必须以其通常保存的一种或多种形式，或者以一种或多种合理可用的形式提交该等信息。\n\n(C) 电子存储信息仅以一种形式提交。作出回应的人员无需以超过一种形式提交同一电子存储信息。\n\n(D) 无法访问的电子存储信息。作出回应的人员无需就其认定因不当负担或费用而无法合理访问的来源中的电子存储信息提供证据开示。在提出强制证据开示动议或保护令动议时，作出回应的人员必须证明该等信息因不当负担或费用而无法合理访问。如果作出该等证明，法院在考虑 Rule 26(b)(2)(C) 的限制后，如请求方证明具有正当理由，仍可命令对该等来源进行证据开示。法院可规定证据开示的条件。\n\n(2) 主张特权或保护。\n\n(A) 被扣留的信息。基于该信息享有特权或作为审判准备材料受到保护的主张而扣留传票所要求信息的人员，必须：(i) 明确提出该主张；以及\n\n(ii) 以一种不披露本身享有特权或受保护信息的方式，描述被扣留文件、通信或有形物的性质，使各方能够评估该主张。\n\n(B) 已提交的信息。如果为回应传票而提交的信息受到特权主张或作为审判准备材料受保护主张的约束，提出该主张的人员可以将该主张及其依据通知任何收到该信息的一方。收到通知后，一方必须立即返还、隔离或销毁所指定的信息及其持有的任何副本；在该主张得到解决之前，不得使用或披露该信息；如果该方在收到通知前披露了该信息，必须采取合理步骤追回该信息；并且可以立即向要求遵从所在地区的法院密封提交该信息，以裁定该主张。提交该信息的人员必须在该主张得到解决之前保存该信息。\n\n(g) 藐视法庭。要求遵从所在地区的法院——以及在动议被移送后，签发传票的法院——可以认定已被送达但无充分理由未遵从传票或与其有关命令的人员构成藐视法庭。\n\n如需查阅传票材料，参见 Fed.R.Civ.P.45(a) Committee Note (2013)\n\n……\n\n文件提交请求\n\nI. 指示\n\n1. 除非另有说明，下述文件请求（以下简称“请求”，单称“一项请求”）必须分别且具体地作出回应。除非出于善意提出异议，否则必须完整回答每项请求；如提出异议，必须按下文规定详细说明贵方异议的理由。如果异议仅涉及一项请求的一部分，或其中包含的某个词、短语或条款，贵方仅须说明对该部分的异议，并对其余请求作出回应。\n\n2. 电子存储信息必须依照以下指示提交：\n\na. 图像。黑白图像必须为 300 DPI Group IV 单页 TIFF 文件。彩色图像必须以 JPEG 格式提交。文件名不得包含嵌入空格或特殊字符（包括逗号）。文件夹名称不得包含嵌入空格或特殊字符（包括逗号）。所有 TIFF 图像文件必须具有唯一文件名，即 Bates 编号。每幅图像的右下角必须标注连续的 Bates 编号。每个文件夹中的 TIFF 文件数量不应超过 1000 个。Excel 电子表格应具有以该文件的 Bates 编号命名的占位图像。\n\nb. 图像加载文件\n\na. Concordance® 数据文件。数据文件（.DAT）包含将加载至 Concordance® 数据库的所有字段信息。.DAT 文件的第一行必须为标明字段名称的标题行。.DAT 文件必须使用以下 Concordance® 默认分隔符：逗号 ASCII 字符 (020)；引号 þ ASCII 字符 (254)。日期字段应采用以下格式提供：mm/dd/yyyy。日期和时间字段必须为两个单独字段。如果文件包括图像化的电子邮件及附件，则必须包含附件字段，以保留电子邮件与其附件之间的父项/子项关系。必须包含 OCRPATH 字段，以提供所提交存储介质上提取文本文件的文件路径和名称。文本文件必须以 FIRSTBATES 命名。不得在 .DAT 文件中包含文本。对于包含原生文件的文件，必须包含 LINK 字段，以提供原生文件的文件路径和名称。原生文件必须以 FIRSTBATES 命名。\n\nb. Concordance Image® 或 Opticon 交叉引用文件。图像交叉引用文件（.LOG 或 .OPT）将图像与数据库记录关联。该文件应为以逗号分隔的文件，每行由七个字段组成，数据库中的每幅图像均应在交叉引用文件中有一行，格式如下：ImageID,VolumeLabel,ImageFilePath,DocumentBreak,FolderBreak,Box Break,PageCoun。\n\nc. 文件文本。文本必须作为单独的文本文件提交，而非作为 .DAT 文件中的字段提交。文本文件的完整路径（OCRPATH）应包含在 .DAT 文件中。建议使用以 FIRSTBATES/Image Key 命名的文件级 ANSI 文本文件。提取的文本文件必须置于单独的文件夹中，每个文件夹中的文本文件数量不应超过 1,000 个。文件夹名称中不得包含特殊字符（包括逗号）。文本文件必须按文件级别提供。\n\nd. 特定文件类型的原生提交。为充分理解其内容和含义而合理需要以原生格式查看的文件类型，必须以原生格式提交。这些文件包括但不限于电子表格、类似电子表格的文件（Microsoft Excel（微软 Excel）、逗号分隔值、制表符分隔值等）、Microsoft PowerPoint（微软 PowerPoint）或其他特殊演示文件、数据库文件以及音频/视频文件。应提供一份标有 Bates 编号的分隔页图像，表明存在原生文件，并在 .dat 文件中以字段形式包含原生文件的路径。提交的原生文件应以与该文件分隔页相对应的 Bates 编号命名。原生文件应归入名称递增的“NATIVE”目录中，与图像目录分开。\n\ne. 去重。对于存在完全相同副本的每份电子文件，仅提交一个副本。对于电子邮件，根据由 BCC、Body、CC、From、IntMsgID、To 和 Attach 属性生成的 MD5 哈希值合并重复项。对于电子邮件附件和独立电子文件，根据整个文件的 MD5 哈希值合并重复项。\n\nf. 元数据。以符合 Concordance 要求的加载文件（.dat）形式提交每份文件的提取元数据。.DAT 文件的第一行必须为标明字段名称的标题行。.DAT 文件必须使用以下 Concordance 默认分隔符：逗号 , ASCII 字符 (020)；引号 þ ASCII 字符 (254)。\n\n日期字段应采用以下格式提供：mm/dd/yyyy。日期和时间字段必须为两个单独字段。以下列出所需元数据：\n\n案件 22-50073 文件 1592 提交于 03/24/23 录入于 03/24/23 10:57:37 第 579 页，共 1063 页\n\n字段名称　示例数据　说明\n\nFIRSTBATES　EDC0000001　原生文件文件/电子邮件的第一个 Bates 编号\nLASTBATES　EDC0000001　原生文件文件/电子邮件的最后一个 Bates 编号\nLASTBATES 字段应针对单页予以填充\nATTACHRANGE　EDC0000001\n-　父项文件第一页的 Bates 编号至最后一个附件“子项”文件最后一页的 Bates 编号\nEDC0000015\nBEGATTACH　EDC0000001　附件范围的第一个 Bates 编号\nENDATTACH　EDC0000015　附件范围的最后一个 Bates 编号\nCUSTODIAN　Smith, John（约翰·史密斯）　电子邮件：电子邮件所在的邮箱\n原生文件：文件来源个人或部门的名称\nFROM　John Smith　电子邮件：发件人\n原生文件：文件作者\n应使用分号分隔多个条目\nTO　Coffman, Janice（贾尼斯·科夫曼）; LeeW　收件人\n[mailto:LeeW@MSN.com]　应使用分号分隔多个条目\nCC　Frank Thompson（弗兰克·汤普森） [mailto:　抄送收件人\nfrank_Thompson@cdt.com]　应使用分号分隔多个条目\nBCC　John Cain（约翰·凯恩）　密送收件人\n应使用分号分隔多个条目\nSUBJECT　Board Meeting Minutes　电子邮件：电子邮件主题行；原生文件：文件标题（如有）\nFILE_NAME　BoardMeetingMinutes.docx　原生文件：原始原生文件名称，包括扩展名\nDATE_SENT　10/12/2010　电子邮件：电子邮件发送日期\n原生文件：（空）\nTIME_SENT/\nTIME_ZONE　07:05 PM GMT　电子邮件：电子邮件发送时间/电子邮件标准化所采用的时区\nTIME_ZONE　GMT　转换期间电子邮件被标准化所采用的时区。\nLINK　EDC0000001.msg　电子邮件或原生文件文件的超链接\n所链接文件必须按 FIRSTBATES 编号命名\nFILE_EXTEN　MSG　表示电子邮件或原生文件的文件类型扩展名\nAUTHOR　John Smith　电子邮件：（空）\n原生文件：文件作者\nDATE_CREATED　10/10/2010　电子邮件：（空）\n原生文件：文件创建日期\n\n案件 22-50073 文件 1592 提交于 03/24/23 录入于 03/24/23 10:57:37 第 580 页，共 1063 页\n\nTIME_CREATED　10:25 AM　电子邮件：（空）\n原生文件：文件创建时间\n该数据必须为单独字段，不得与 DATE_CREATED 字段合并\nDATE_MOD　10/12/2010　电子邮件：（空）\n原生文件：文件最后修改日期\nTIME_MOD　07:00 PM　电子邮件：（空）\n原生文件：文件最后修改时间\n该数据必须为单独字段，不得与 DATE_MOD 字段合并\nDATE_ACCESSD　10/12/2010　电子邮件：（空）\n原生文件：文件最后访问日期\nTIME_ACCESSD　07:00 PM　电子邮件：（空）\n原生文件：文件最后访问时间\n该数据必须为单独字段，不得与 DATE_ACCESSD 字段合并\nFILE_SIZE　5,952　原生文件文件/电子邮件的大小，单位为 KB\nPGCOUNT　1　原生文件文件/电子邮件的页数\nPATH　电子邮件：（空）\nAgenda.doc　原生文件：原生文件文件的存储路径，包括原始文件名称。\nINTFILEPATH　Personal Folders\\Deleted　电子邮件：电子邮件的原始位置，包括原始文件名称。\nItems\\Board Meeting\nMinutes.msg　原生文件：（空）\nINTMSGID　<000805c2c71b\\$75977050\\$　电子邮件：唯一信息 ID；原生文件：（空）\ncb8306d1@MSN>\nMD5HASH　d131dd02c5e6eec4693d9a0　文件的 MD5 哈希值。\n698aff95c\n2fcab58712467eab4004583e\nb8fb7f89\nOCRPATH　TEXT/001/EDC0000001.txt　原生文件提取文本的路径\n\n3. 每项请求均独立适用并应独立解释，且除非另有说明，任何一项请求均不限制任何其他请求的范围。\n\n4. 所有文件均应按照日常业务过程中保存的方式提交，或者应进行整理和标记，使其与这些请求中的类别相对应。\n\n5. 本文所载每项请求均延及以下所有文件：(a) 贵方占有、保管或控制的文件；或 (b) 任何代表贵方行事之人占有、保管或控制的文件，\n\n案件 22-50073 文件 1592 提交于 03/24/23 录入于 03/24/23 10:57:37 第 581 页，共 1063 页\n\n包括贵方律师或其他代表和顾问。每份文件均应完整提交。\n\n6. 如要求您提供一份已不再由您占有、保管或控制的文件，则您的答复必须：(a) 详细说明该文件的性质及其内容；(b) 识别编制或撰写该文件的人员（以及，如适用，文件发送给的人员）；(c) 识别该文件编制或制作的日期；(d) 说明该文件是否(i) 遗失或丢失，(ii) 已被销毁，(iii) 已自愿或非自愿地转交给他人，或(iv) 以其他方式处置；(e) 说明该等处置的理由以及围绕该等处置的事实和情况；(f) 识别授权该等处置的人员；(g) 识别该等处置的日期或大致日期；(h) 说明该文件最后一次由您占有、保管或控制的时间；以及(i) 识别目前占有、保管或控制该文件的人员（如有）。\n\n7. 如要求您提供一份已被销毁的文件，则除前一项指示所要求的信息外，您的答复还必须说明：(a) 销毁该文件的理由；(b) 销毁该文件的人员身份；以及(c) 指示销毁该文件的人员身份。\n\n8. 如您主张某一被要求提供的文件享有特权或属于律师工作成果，则您的答复必须：(a) 说明(i) 足以支持您主张该文件享有特权的文件描述，(ii) 文件标题，(iii) 文件日期，(iv) 文件作者，(v) 文件收件人，(vi) 收到或阅览该文件原件或任何草稿、副本或复制件的每一人员的身份，(vii) 该文件本身或文件中载有或提及的任何信息是否由任何其他人员占有、保管或控制；如是，则说明该等人员的身份，并陈述说明该等信息如何进入其占有范围，(viii) 据以扣留该文件的特权主张，以及(ix) 您将依赖以支持该等特权主张的所有情形；以及(b) 就根据 D. Conn. L. Civ. R. 26(e) 因主张特权而被扣留的每一文件，制作一份载有本项指示第(a)部分所要求全部信息的特权日志。对于文件请求中未主张特权或工作成果保护的任何部分，应完整提供响应性文件。\n\nCase 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 582 of 1063\n\n9. 如一份原本具有响应性的文件的一部分包含受特权主张约束的信息，则仅应按照上述指示从该文件中删除或遮盖受特权主张约束的该部分，其余部分应予提供。\n\n10. 该等请求具有持续性。现指示您：(a) 一旦知悉先前答复不完整或不正确，应立即补充或更正任何后来获悉为不完整或不正确的答复；以及(b) 提供根据该等请求所要求的任何补充文件。\n\n11. 如文件使用英语以外的语言，您应提供该文件。如文件使用英语以外的语言且存在英文译本，您应同时提供两份文件。\n\n12. 对实体的所有提及均包括其全部关联方。\n\n13. 对个人姓名的所有提及均包括所有其他姓名、别名或昵称。\n\nCase 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 583 of 1063\n\n14. 除非另有明确说明，文件请求所涵盖的期间为自 February 5, 2012 起至文件请求答复到期之日止。\n\nII. 解释规则\n\n15. (a) 任何单数名词的使用应解释为包括复数，反之亦然；且(b) 任何时态动词的使用应解释为包括该动词所有其他时态的使用。\n\n16. (a) “and”和“or”应根据需要解释为连词或选择连词，以使任何请求的范围涵盖原本可能被解释为不在其范围内的所有答复；且(b) “each”和“any”应视为包括并涵盖“every”和“all”二词。\n\nIII. 定义\n\n经 D. Conn. Bankr. L.R. 2004-1(a) 纳入的 D. Conn. L. Civ. R. 26(c) 所提供的定义及 D. Conn. L. Civ. R. 26(d) 所提供的解释规则，适用于该等文件请求。此外，本文件请求中使用的下列术语具有下列含义：\n\n1. “您”或“您的”或“您本人”是指 Amazon Web Services, LLC（亚马逊云服务有限责任公司）及其所有关联方。\n\n2. “债务人”是指 Ho Wan Kwok（郭文贵，亦称 Miles Kwok、Miles Guo、Guo Wengui、Guo Haoyun 或任何其他别名）及其雇员、代理人、律师、顾问或任何代表其行事的人。\n\nCase 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 584 of 1063\n\n3. “债务人之子”是指 Qiang Guo（郭强，亦称 Mileson Kwok 或任何其他别名）及其雇员、代理人、律师、顾问或任何代表其行事的人。\n\n4. “债务人之女”是指 Mei Guo（郭美，亦称 Mei Gui 或任何其他别名）及其雇员、代理人、律师、顾问或任何代表其行事的人。\n\n5. “债务人声称的妻子”是指 Hing Chi Ngok（岳庆芝，亦称 Hing Chi Ng、Yue Qingzhi 或任何其他别名）及其雇员、代理人、律师、顾问或任何代表其行事的人。\n\n6. “债务人家属”是指，个别及统称，债务人、债务人之子、债务人之女和债务人声称的妻子，以及与债务人具有任何其他家庭关系的人。\n\n7. “2004 调查对象”是指，个别及统称，债务人、债务人家属、ACA Capital Group Limited（ACA资本集团有限公司）、Himalaya International Financial Group Ltd.（喜马拉雅国际金融集团有限公司）、Himalaya International Clearing Ltd.（喜马拉雅国际清算有限公司）、Himalaya International Payments Ltd.（喜马拉雅国际支付有限公司）、Himalaya International Reserves Ltd.（喜马拉雅国际储备有限公司）、Jesse Brown（杰西·布朗）、William Je（威廉·杰）、William Je（威廉·杰）、Eastern Profit Corporation Limited（东方盈利有限公司）、HK International Funds Investments (USA) Limited LLC（香港国际基金投资〈美国〉有限责任公司）、Bravo Luck Limited（卓运有限公司）、Golden Spring (New York) Ltd.（金泉〈纽约〉有限公司）、Lamp Capital LLC（兰普资本有限责任公司）、Greenwich Land LLC（格林尼治土地有限责任公司）、Qu Guo Jiao（郭娇）、Daniel Thomas Podhaskie（丹尼尔·托马斯·波德哈斯基）、Yvette Wang（王艳萍，亦称 Yanping Wang、Yan Ping Wang）、Ace Decade Holdings Limited（艾斯十年控股有限公司）、Dawn State Limited（曙光国度有限公司）、Rule of Law Society IV Inc.（法治协会IV公司）、Rule of Law Foundation III, Inc.（法治基金会III公司）、Rule of Law Foundation IV, Inc.（法治基金会IV公司）、Rule of Law Fund（法治基金）、Rule of Law Society（法治协会）、GTV Media Group, Inc.（GTV媒体集团公司）、Voice of Guo Media, Inc.（郭媒体之声公司）、Saraca Media Group Inc.（萨拉卡媒体集团公司）、Genever Holdings Corporation（热内弗控股公司）、Genever Holdings LLC（热内弗控股有限责任公司）、Gnews Media Group Inc.（Gnews媒体集团公司）、G Fashion LLC（G时尚有限责任公司）、Gmusic LLC（G音乐有限责任公司）、Gnews LLC（Gnews有限责任公司）、Geducation（G教育）、GFNY, Inc.（GFNY公司）、G-Club Investments Limited（G俱乐部投资有限公司）、G Club Operations LLC（G俱乐部运营有限责任公司）、G Club US Operations Inc.（G俱乐部美国运营公司）、G Club US Operations LLC（G俱乐部美国运营有限责任公司）、G Live, LLC（G直播有限责任公司）、Gbroadcast, LLC（G广播有限责任公司）、Gposts LLC（G帖文有限责任公司）、HCHK Property Management, Inc.（HCHK物业管理公司）、HCHK Technologies, Inc.（HCHK技术公司）、FMV Ltd./Freedom Media Venture Ltd.（FMV有限公司／自由媒体创投有限公司）、Roscalitar 2（罗斯卡利塔尔2）、Himalaya New World Inc.（喜马拉雅新世界公司）、US Himalaya Capital Inc.（美国喜马拉雅资本公司）、Hudson Diamond Holding, Inc.（哈德逊钻石控股公司）、Hudson Diamond Holding LLC（哈德逊钻石控股有限责任公司）、Hudson Diamond NY LLC（哈德逊钻石纽约有限责任公司）、Infinity Treasury Management Inc.（无限财资管理公司）、Lexington Property and Staffing, Inc.（列克星敦物业及人事公司）、AI Group Holdings Inc.（AI集团控股公司）、Hamilton Capital Holdings Inc.（汉密尔顿资本控股公司）、Booming Sail New York LLC（扬帆纽约有限责任公司）、Himalaya Ventures LLC（喜马拉雅创投有限责任公司）、Himalaya Ventures LLC（喜马拉雅创投有限责任公司）、Himalaya Investment LLC（喜马拉雅投资有限责任公司）、New York MOS Himalaya LLC（纽约MOS喜马拉雅有限责任公司）、MOS Himalaya LLC（MOS喜马拉雅有限责任公司）、Crane Advisory Group（克兰咨询集团）、Maywind Trading LLC（五月风贸易有限责任公司）、Gettr USA, Inc.（Gettr美国公司）、Han Chunguang（韩春光）、Bingshang Jiao（焦冰上）、Karin Maistrello（卡琳·梅斯特雷洛）、Mary Jiang（江玛丽）、Jiaming Liu（刘家明）以及 Wencong Wang（王文聪）。\n\nCase 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 585 of 1063\n\n8. “Including”或其任何变体是指“包括但不限于”。\n\n9. “And”和“or”是指“and/or”，且应同时解释为连词和选择连词，以最大限度扩大其范围。\n\n10. “Any”、“all”和“each”是指“每一及所有”。\n\n11. “Each”和“every”是指“每一及所有”。\n\n12. “第三方”是指您本人以外的人员或实体。\n\n13. “转让”具有《破产法典》第 101(54) 条赋予该词的含义。\n\n14. “文件”是指属于 Fed. R. Civ. P. 34 范围内的任何信息或物品，并包括但不限于现由或曾由您占有、保管或控制的各种、各类、任何性质或描述的每一份书面、记录或图形材料，包括电子邮件的所有印刷及电子副本、以电子形式保存的计算机文件、通信、备忘录、磁带、速记或手写笔记、任何种类的书面表格、图表、蓝图、图纸、草图、曲线图、计划、文章、规格说明、日记、信件、\n\nCase 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 586 of 1063\n\n电报、照片、会议记录、合同、协议、调查资料、计算机打印件、任何种类的数据汇编、电传、传真、电子邮件、短信、即时消息、语音消息、发票、订单表格、支票、汇票、对账单、贷项通知单、报告、持仓报告、摘要、索引、书籍、分类账、笔记本、日程表、透明胶片、录音、目录、广告、宣传材料、电影、录像带、录音带、CD、计算机磁盘、宣传册、小册子、穿孔卡、工时单、推文、社交媒体帖子或任何其他种类的书面或记录材料，以及其全部元数据，无论以何种方式存储（无论为有形或电子形式）、记录、制作或复制；还包括但不限于任何前述材料的草稿或副本，如其包含原件中未载有的任何种类的笔记、评论或标记，或其在其他方面与原件不相同。\n\n15. “人员”是指个人、公司、独资企业、合伙企业、协会或任何其他实体。“人员”还包括任何代理人、代表或专家，包括但不限于律师或财务顾问。\n\n16. “实体”是指任何自然人、公司、合伙企业、子公司、独资企业、商号、董事会、合资企业、协会、机构、主管机关、委员会或其他商业实体或法人，以及任何关联方、代理人、母公司，包括但不限于律师、财务顾问或任何其他代表。\n\n17. “关于”是指涉及、描述、构成、提及、与之相关、支持、赞成、反对、加强、削弱、位于其中、结合其考虑、对其有影响、证明、表明、报告、记录、暗示、答复、与之关联、评论、就其而言、关于、与之有关、讨论、展示、描述、反映、分析、构成以及属于。\n\nCase 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 587 of 1063\n\n18. 就任何特定主题而言，“relating to”、“relate(s) to”或“related to”是指，包括但不限于，构成、包含、涉及、载有、体现、反映、识别、陈述、直接或间接提及，或以任何方式与所识别特定主题相关的任何文件。\n\n19．“通信”系指，就最广义而言且不限于，任何信息或知识的传递（以事实、观点、询问或其他形式）。通信还指所有谈话、协议、询问或答复，无论是当面、电话、书面，还是通过电子传输设备进行，并包括但不限于所有信函、电子邮件、录音、传输单、备忘录、电话通信、语音留言、电报、传真、电传副本、电传、即时消息、聊天、短信、在留言板或群聊中的发布内容、社交媒体帖子、推文、上传至任何视频平台的视频、电话记录，或在内部或与第三方传送的记录。\n\nIV．应提交的文书\n\n1．所有与2004取证对象中的任何一方由您或代表您向其转移或从其接收的任何资金或其他有价值物有关的文书。\n\n2．所有与由2004取证对象中的任何一方持有、控制、代表其持有或以其他方式与其有关的任何账户有关的文书，包括任何及所有账户对账单、协议、授权、使用记录或通信。\n\n3．所有与您与2004取证对象之间的任何信函往来和通信有关的文书。\n\n案件 22-50073 文书 1592 提交于 03/24/23 录入于 03/24/23 10:57:37 第 588 页，共 1063 页\n\n附件 C-32\n\nB2540（表格 2540－第2004条审查传票）（12/15）案件 22-50073 文书 1592 提交于 03/24/23 录入于 03/24/23 10:57:37 第 589 页，共 1063 页\n\nUNITED STATES BANKRUPTCY COURT（美国破产法院）\n\nDistrict of Connecticut（康涅狄格地区）\n\n关于 HO WAN KWOK（郭文贵）等人，\n\n1 案号 22-50073 (JAM)\n\n债务人 第11章\n\n（合并管理）\n\n第2004条审查传票\n\n致：HSBC Bank USA, N.A.（汇丰银行美国全国协会）\n\n（传票所指向之人的姓名）\n\n证言：现命令您于下列规定的时间、日期和地点出席，并根据《联邦破产程序规则》第2004条接受审查并作证。随附授权该审查的法院命令副本。\n\n地点　日期和时间\n\nNeubert, Pepe & Monteith, P.C.（纽伯特、佩佩与蒙蒂斯职业公司）\n195 Church Street, Floor 13　[TBD]\nNew Haven, Connecticut 06510\n\n审查将通过以下方式记录：法庭记录员/速记员\n\n提交：您或您的代表还必须在审查时携带下列文书、电子存储信息或物品，并必须允许对该等材料进行检查、复制、测试或取样：\n\n见随附的文书提交请求。\n\n以下 Fed. R. Civ. P. 45 条款已随附；该规则通过 Fed. R. Bankr. P. 9016 适用于破产案件，包括关于履行地点的第45(c)条、关于作为受传票约束之人所受保护的第45(d)条，以及关于您答复本传票的义务及未答复的潜在后果的第45(e)条和第45(g)条。\n\n日期：March , 2023\n\n法庭书记官\n\n或\n\n书记官或副书记官签名　律师签名\n\n签发或请求本传票、代表第11章受托人 Luc A. Despins（卢克·A·德斯平斯）的律师姓名、地址、电子邮件地址和电话号码如下：\n\nDouglas S. Skalka, Esq.（道格拉斯·S·斯卡尔卡律师）；Neubert, Pepe & Monteith, P.C.（纽伯特、佩佩与蒙蒂斯职业公司）；195 Church Street, New Haven, Connecticut 06510；dskalka@npmlaw.com；(203) 821-2000\n\n致签发或请求本传票之人的通知\n\n如本传票命令在审判前提交文书、电子存储信息或有形物品，或检查场所，则必须在向本传票所指向之人送达之前，向每一方送达通知及本传票副本。Fed. R. Civ. P. 45(a)(4)。\n\n软件版权 (c) 1996-2022 Best Case, LLC（贝斯特凯斯有限责任公司）- www.bestcase.com Best Case Bankruptcy 1 本第11章案件的债务人为 Ho Wan Kwok（郭文贵）（又名 Guo Wengui、Miles Guo 和 Miles Kwok，以及众多其他别名）（税务识别号后四位：9595）、Genever Holdings LLC（吉尼弗控股有限责任公司）（税务识别号后四位：8202）及 Genever Holdings Corporation（吉尼弗控股公司）。受托人、Genever Holdings LLC 及 Genever Holdings Corporation 的邮寄地址为 Paul Hastings LLP（普衡律师事务所），200 Park Avenue, New York, NY 10166，收件人为作为 Ho Wan Kwok 遗产受托人的 Luc A. Despins（仅为通知和通信之目的）。\n\n送达证明\n\n（除非 Fed. R. Civ. P. 45 要求，否则本节不应向法院提交。）\n\n我于（日期）收到向（个人姓名及职务，如有）发出的本传票。\n\n我通过如下方式向所列明之人交付副本以送达本传票：\n\n于（日期）；或\n\n我未执行本传票即予退回，原因如下：\n\n除非本传票系代表 United States（美国）或其官员或代理人签发，我还已向证人支付一日出庭费及法律允许的里程费，金额为 $ 。\n\n我的差旅费用为 $ ，服务费用为 $ ，合计为 $ 。\n\n我在伪证处罚的惩罚下声明，该等信息真实且正确。\n\n日期：\n\n送达人签名\n\n正楷姓名及职务\n\n送达人地址\n\n关于尝试送达等的补充信息：\n\n《联邦民事诉讼规则》第45(c)、(d)、(e)及(g)条（Effective 12/1/13）（通过《联邦破产程序规则》第9016条适用于破产案件）\n\n(c) 履行地点。\n\n(1) 审判、听证或证言录取。传票仅可按如下方式命令某人出席审判、听证或证言录取：\n\n(A) 在该人居住、受雇或经常亲自从事业务之地100英里以内；或\n\n(B) 在该人居住、受雇或经常亲自从事业务所在州内，如果该人\n\n(i) 是当事人或当事人的高级职员；或\n\n(ii) 被命令出席审判且不会产生重大费用。\n\n(2) 其他取证。传票可以命令：\n\n(A) 在距该人居住、受雇或经常亲自从事业务之地100英里以内的地点提交文书、电子存储信息或物品；以及\n\n(B) 在被检查的场所对场所进行检查。\n\n(d) 对受传票约束之人的保护；执行。\n\n(1) 避免不当负担或费用；制裁。负责签发和送达传票的当事人或律师必须采取合理措施，避免向受传票约束之人施加不当负担或费用。要求履行的地区法院必须执行该义务，并对未遵守该义务的当事人或律师施加适当制裁，该制裁可包括损失的收入和合理的律师费。\n\n(2) 命令提交材料或允许检查。\n\n(A) 无须出席。被命令提交文书、电子存储信息或有形物品，或允许检查场所之人，无须亲自到提交或检查地点出席，除非同时被命令出席证言录取、听证或审判。\n\n(B) 异议。被命令提交文书或有形物品，或允许检查之人，可以向传票中指定的当事人或律师送达书面异议，反对检查、复制、测试或取样任何或全部材料，或反对检查场所，或反对以所请求的一种或多种形式提交电子存储信息。异议必须在规定的履行时间或传票送达后14日两者中较早者之前送达。如提出异议，适用下列规则：\n\n(i) 送达方可随时在通知被命令之人后，向要求履行的地区法院提出动议，请求作出强制提交或检查的命令。\n\n(ii) 仅可按照该命令的指示要求实施该等行为，且该命令必须保护既非当事人亦非当事人高级职员之人，免于承担因履行而产生的重大费用。\n\n(3) 撤销或修改传票。\n\n(A) 必须撤销或修改的情形。经及时提出动议，要求履行的地区法院必须撤销或修改具有下列情形的传票：\n\n(i) 未给予合理的履行时间；\n\n(ii) 要求某人在第45(c)条规定的地理限制之外履行；\n\n(iii) 要求披露享有特权或受其他保护的事项，且不存在适用的例外或放弃；或\n\n(iv) 使某人承受不当负担。\n\n(B) 可以撤销或修改的情形。为保护受传票约束或受其影响之人，要求履行的地区法院可经动议撤销或修改要求下列事项的传票：\n\n(i) 披露商业秘密或其他保密的研究、开发或商业信息；或\n\n(ii) 披露未受聘专家的意见或信息，该等意见或信息并未描述争议中的具体事件，且系该专家未经当事人请求而进行研究所得。\n\n(C) 以规定条件作为替代。在第45(d)(3)(B)条所述情形下，如送达方：\n\n(i) 证明其对该证言或材料具有实质性需要，且若不遭受不当困难则无法以其他方式满足该需要；并且\n\n(ii) 确保受传票人将获得合理补偿，\n\n法院可以不撤销或修改传票，而命令在规定条件下出席或提交。\n\n(e) 答复传票的义务。\n\n(1) 提交文书或电子存储信息。以下程序适用于提交文书或电子存储信息：\n\n(A) 文书。答复提交文书传票之人，必须按照该等文书在正常业务过程中保存的方式提交，或者必须整理并标注该等文书，使其与要求中的类别相对应。\n\n(B) 未指定电子存储信息的提交形式。如传票未指定电子存储信息的提交形式，答复之人必须以其通常保存的一种或多种形式，或以合理可用的一种或多种形式提交。\n\n(C) 电子存储信息仅以一种形式提交。答复之人无须以超过一种形式提交相同的电子存储信息。\n\n(D) 无法获取的电子存储信息。答复之人无须就其认定因不当负担或费用而无法合理获取之来源中的电子存储信息提供取证。在提出强制取证动议或保护令动议时，答复之人必须证明该信息因不当负担或费用而无法合理获取。如作出该证明，法院仍可在请求方证明有正当理由时，命令从该等来源进行取证，并应考虑第26(b)(2)(C)条的限制。法院可规定取证条件。\n\n(2) 主张特权或保护。\n\n(A) 被扣留的信息。以该信息享有特权或作为审判准备材料受到保护为由扣留传票所要求信息之人，必须：(i) 明确提出该主张；并且\n\n(ii) 以一种在不披露本身享有特权或受保护的信息的情况下，能够使各方评估该主张的方式，描述被扣留文书、通信或有形物品的性质。\n\n(B) 已出示的信息。若为响应传票而出示的信息受特权主张或审判准备材料保护主张的约束，提出该主张的人可以将该主张及其依据通知收到该信息的任何一方。接到通知后，一方必须立即返还、隔离或销毁所指明的信息及其持有的任何副本；在该主张得到解决前，不得使用或披露该信息；若该方在接到通知前已披露该信息，必须采取合理措施追回该信息；并且可以立即将该信息密封提交至要求履行义务所在地区的法院，以裁定该主张。出示该信息的人必须在该主张得到解决前保存该信息。\n\n(g) 藐视法庭。要求履行义务所在地区的法院——以及在动议移送后，签发传票的法院——可以对已经送达但无正当理由不遵守传票或与之相关命令的人作出藐视法庭处罚。\n\n有关获取传票材料，参见 Fed.R.Civ.P.45(a) 委员会注释（2013）\n\n……\n\n文件出示请求\n\nI. 指示\n\n1. 除非另有说明，下述文件请求（以下简称“请求”，每一项以下简称“一项请求”）必须分别并具体作出答复。每项请求均应得到完整答复，除非贵方出于善意提出异议；在此情况下，贵方应按照下文规定详细说明异议理由。若异议仅涉及某项请求的一部分，或其中包含的一个词语、短语或条款，贵方仅须说明对该部分的异议，并对其余请求作出答复。\n\n2. 电子存储信息必须按照下列指示出示：\n\na. 图像。黑白图像必须为 300 DPI Group IV 单页 TIFF 文件。彩色图像必须以 JPEG 格式出示。文件名不得包含嵌入空格或特殊字符（包括逗号）。文件夹名称不得包含嵌入空格或特殊字符（包括逗号）。所有 TIFF 图像文件必须具有唯一文件名，即 Bates 编号。每张图像右下角必须加注连续的 Bates 编号。每个文件夹中的 TIFF 文件数量不得超过 1000 个。Excel 电子表格应具有以该文件 Bates 编号命名的占位图像。\n\nb. 图像加载文件\n\na. Concordance® 数据文件。数据文件（.DAT）包含将加载至 Concordance® 数据库的所有字段信息。.DAT 文件的第一行必须为标识字段名称的标题行。.DAT 文件必须使用以下 Concordance® 默认分隔符：逗号 ASCII 字符（020）；引号 þ ASCII 字符（254）。日期字段应以如下格式提供：mm/dd/yyyy。日期和时间字段必须为两个单独字段。若文件包含已成像的电子邮件及附件，则必须包括附件字段，以保持电子邮件与其附件之间的父/子关系。必须包括 OCRPATH 字段，以提供出示存储介质上提取文本文件的文件路径和名称。文本文件必须以 FIRSTBATES 命名。不得将文本包含在 .DAT 文件中。对于具有原生文件的文件，必须包括 LINK 字段，以提供原生文件的文件路径和名称。原生文件必须以 FIRSTBATES 命名。\n\nb. Concordance Image® 或 Opticon 交叉引用文件。图像交叉引用文件（.LOG 或 .OPT）将图像链接至数据库记录。该文件应为逗号分隔文件，每行由七个字段组成，数据库中每张图像均应在交叉引用文件中对应一行，格式如下：ImageID,VolumeLabel,ImageFilePath,DocumentBreak,FolderBreak,Box Break,PageCount。\n\nc. 文件文本。文本必须作为单独的文本文件出示，而非作为 .DAT 文件中的字段。文本文件的完整路径（OCRPATH）应包含在 .DAT 文件中。建议提供以 FIRSTBATES/Image Key 命名的文件级 ANSI 文本文件。提取的文本文件必须置于单独的文件夹中，每个文件夹中的文本文件数量不得超过 1,000 个。文件夹名称中不得含有特殊字符（包括逗号）。文本文件必须按文件级别提供。\n\nd. 特定文件类型的原生格式出示。为完整理解其内容和含义而合理需要以原生格式查看的文件类型，必须以原生格式出示。此类文件包括但不限于电子表格、类似电子表格的文件（Microsoft Excel、逗号分隔值、制表符分隔值等）、Microsoft PowerPoint 或其他特殊演示文件、数据库文件以及音频/视频文件。应提供一张带 Bates 编号的分隔页图像，注明存在原生文件，并将原生文件的路径作为字段包含在 .dat 文件中。出示的原生文件应以与该文件分隔页相对应的 Bates 编号命名。原生文件应按递增命名的“NATIVE”目录归组，与图像目录分开。\n\ne. 去重。对于存在完全重复副本的每一电子文件，仅出示一份副本。对于电子邮件，根据由 BCC、Body、CC、From、IntMsgID、To 和 Attach 属性生成的 MD5 哈希值合并重复项。对于电子邮件附件和独立电子文件，根据整个文件的 MD5 哈希值合并重复项。\n\nf. 元数据。以符合 Concordance 要求的加载文件（.dat）形式，为每份文件出示提取的元数据。.DAT 文件的第一行必须为标识字段名称的标题行。.DAT 文件必须使用以下 Concordance 默认分隔符：逗号 , ASCII 字符（020）；引号 þ ASCII 字符（254）。\n\n日期字段应以如下格式提供：mm/dd/yyyy。日期和时间字段必须为两个单独字段。所需元数据如下：\n\nCase 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 594 of 1063\n\n字段名称　示例数据　说明\n\nFIRSTBATES　EDC0000001　原生文件文件/电子邮件的第一个 Bates 编号\n\nLASTBATES　EDC0000001　原生文件文件/电子邮件的最后一个 Bates 编号\n\n对于单页文件，应填写 LASTBATES 字段\n\nATTACHRANGE　EDC0000001\n-　父文件首页的 Bates 编号至最后一个附件“子”文件最后一页的 Bates 编号\nEDC0000015\n\nBEGATTACH　EDC0000001　附件范围的第一个 Bates 编号\n\nENDATTACH　EDC0000015　附件范围的最后一个 Bates 编号\n\nCUSTODIAN　Smith, John　电子邮件：电子邮件所在的邮箱\n原生文件：文件来源的个人或部门名称\n\nFROM　John Smith　电子邮件：发件人\n原生文件：文件作者\n多个条目应以分号分隔\n\nTO　Coffman, Janice; LeeW　收件人\n[mailto:LeeW@MSN.com]　多个条目应以分号分隔\n\nCC　Frank Thompson [mailto:　抄送收件人\nfrank_Thompson@cdt.com]　多个条目应以分号分隔\n\nBCC　John Cain　密送收件人\n多个条目应以分号分隔\n\nSUBJECT　Board Meeting Minutes　电子邮件：电子邮件主题行；原生文件：文件标题（如有）\n\nFILE_NAME　BoardMeetingMinutes.docx　原生文件：原始原生文件名称，包括扩展名\n\nDATE_SENT　10/12/2010　电子邮件：电子邮件发送日期\n原生文件：（空）\n\nTIME_SENT/\nTIME_ZONE　07:05 PM GMT　电子邮件：电子邮件发送时间/电子邮件标准化所采用的时区\n\nTIME_ZONE　GMT　在转换期间电子邮件被标准化所采用的时区。\n\nLINK　EDC0000001.msg　电子邮件或原生文件文件的超链接\n链接文件必须以 FIRSTBATES 编号命名\n\nFILE_EXTEN　MSG　表示电子邮件或的文件类型扩展名\n\nAUTHOR　John Smith　电子邮件：（空）\n原生文件：文件作者\n\nDATE_CREATED　10/10/2010　电子邮件：（空）\n原生文件：文件创建日期\n\nCase 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 595 of 1063\n\nTIME_CREATED　10:25 AM　电子邮件：（空）\n原生文件：文件创建时间\n该数据必须为单独字段，不得与 DATE_CREATED 字段合并\n\nDATE_MOD　10/12/2010　电子邮件：（空）\n原生文件：文件最后修改日期\n\nTIME_MOD　07:00 PM　电子邮件：（空）\n原生文件：文件最后修改时间\n该数据必须为单独字段，不得与 DATE_MOD 字段合并\n\nDATE_ACCESSD　10/12/2010　电子邮件：（空）\n原生文件：文件最后访问日期\n\nTIME_ACCESSD　07:00 PM　电子邮件：（空）\n原生文件：文件最后访问时间\n该数据必须为单独字段，不得与 DATE_ACCESSD 字段合并\n\nFILE_SIZE　5,952　原生文件文件/电子邮件的大小，以 KB 计\n\nPGCOUNT　1　原生文件文件/电子邮件的页数\n\nPATH　电子邮件：（空）\nAgenda.doc　原生文件：原生文件文件的存储路径，包括原始文件名称。\n\nINTFILEPATH　Personal Folders\\Deleted　电子邮件：电子邮件的原始位置，包括原始文件名称。\nItems\\Board Meeting\nMinutes.msg　原生文件：（空）\n\nINTMSGID　<000805c2c71b\\$75977050\\$　电子邮件：唯一邮件 ID；原生文件：（空）\ncb8306d1@MSN>\n\nMD5HASH　d131dd02c5e6eec4693d9a0　文件的 MD5 哈希值。\n698aff95c\n2fcab58712467eab4004583e\nb8fb7f89\n\nOCRPATH　TEXT/001/EDC0000001.txt　原生文件提取文本的路径\n\n3. 每项请求独立适用并应独立解释，除非另有说明，任何一项请求均不限制任何其他请求的范围。\n\n4. 所有文件均应按照其在通常业务过程中保存的方式出示，或应予组织和标注，以对应这些请求中的类别。\n\n5. 本文所载每项请求均延伸至所有文件：(a) 由贵方占有、保管或控制的文件；或 (b) 由代表贵方行事的任何人占有、保管或控制的文件，\n\nCase 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 596 of 1063\n\n包括贵方的律师或其他代表及顾问。每份文件均应完整出示。\n\n6. 若要求贵方出示一份已不再由贵方占有、保管或控制的文件，则贵方的答复必须：(a) 详细说明该文件的性质及其内容；(b) 识别编制或撰写该文件的人（以及，如适用，识别文件被发送给的人）；(c) 识别该文件编制或创建的日期；(d) 说明该文件是否 (i) 遗失或丢失，(ii) 已被销毁，(iii) 已自愿或非自愿转移给他人，或 (iv) 已以其他方式处置；(e) 说明该等处置的原因，以及围绕该等处置的事实和情形；(f) 识别授权该等处置的人；(g) 识别该等处置的日期或大致日期；(h) 说明该文件最近一次由贵方占有、保管或控制的时间；以及 (i) 识别目前占有、保管或控制该文件的人（如有）。\n\n7. 若要求贵方出示一份已被销毁的文件，则除前述指示要求的信息外，贵方的答复还必须说明：(a) 销毁该文件的原因；(b) 销毁该文件的人的身份；以及 (c) 指示销毁该文件的人的身份。\n\n8. 如您主张某一被要求提供的文件享有特权或受律师工作成果保护，则您的答复必须：(a) 说明：(i) 对该文件作出足以支持您关于该文件享有特权之主张的描述，(ii) 该文件的标题，(iii) 该文件的日期，(iv) 该文件的作者，(v) 该文件的收件人，(vi) 收到或阅览该文件原件或任何草稿、副本或复制件的每一人员的身份，(vii) 该文件本身，或该文件所含或所提及的任何信息，是否由任何其他人员占有、保管或控制；如是，则说明该等人员的身份，以及说明该等信息如何进入其占有范围，(viii) 据以扣留该文件的特权主张，以及 (ix) 您将据以支持该等特权主张的所有情形；以及 (b) 就每一份基于特权主张而被扣留的文件，根据 D. Conn. L. Civ. R. 26(e)，提供一份特权清单，其中载明本指示第(a)部分所要求的全部信息。对于文件请求中未提出特权或律师工作成果主张的任何部分，应完整提供相应文件。\nCase 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 597 of 1063\n该等人员的身份，以及说明该等信息如何进入其占有范围，(viii) 据以扣留该文件的特权主张，以及 (ix) 您将据以支持该等特权主张的所有情形；以及 (b) 就每一份基于特权主张而被扣留的文件，根据 D. Conn. L. Civ. R. 26(e)，提供一份特权清单，其中载明本指示第(a)部分所要求的全部信息。对于文件请求中未提出特权或律师工作成果主张的任何部分，应完整提供相应文件。\n\n9. 如一份本应作出答复的文件的一部分包含受到特权主张约束的信息，则仅应依照上述指示从该文件中删除或遮蔽受到特权主张约束的该部分，其余部分应予提供。\n\n10. 本请求具有持续性。特此指示您：(a) 一旦得知先前答复不完整或不正确，立即补充或更正任何后来得知不完整或不正确的答复；以及 (b) 提供根据下列内容所要求的任何补充文件。\n\n11. 如文件使用英语以外的语言，您应提供该文件。如文件使用英语以外的语言，且存在英文译本，您应同时提供两份文件。\n\n12. 对实体的所有提述均包括其所有关联方。\n\n13. 对个人姓名的所有提述均包括所有其他姓名、别名或昵称。\nCase 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 598 of 1063\n\n14. 除非另有明确说明，文件请求所涵盖的期间为自 February 5, 2012 起至文件请求答复到期之日止。\n\nII. 解释规则\n\n15. (a) 对任何单数名词的使用，应解释为包括复数，反之亦然；以及 (b) 对任何时态动词的使用，应解释为包括该动词的所有其他时态。\n\n16. (a) “and”和“or”应视必要而分别作合取或析取解释，以将原本可能被解释为不在任何请求范围内的所有答复纳入该请求范围；以及 (b) “each”和“any”应视为包括并涵盖“every”和“all”二词。\n\nIII. 定义\n\n根据 D. Conn. Bankr. L.R. 2004-1(a) 纳入的 D. Conn. L. Civ. R. 26(c) 所规定的定义以及 D. Conn. L. Civ. R. 26(d) 所规定的解释规则，应适用于文件请求。此外，本文件请求中使用的下列术语具有以下含义：\n\n1. “You”或“Your”或“Yourself”系指 HSBC Bank USA, N.A.（汇丰银行美国全国协会）及其所有关联方。\n\n2. “Debtor”系指 Ho Wan Kwok（郭文贵）（又名 Miles Kwok、Miles Guo、Guo Wengui、Guo Haoyun、郭文贵，或任何其他别名），以及其雇员、代理人、律师、顾问或任何代表其行事之人。\nCase 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 599 of 1063\n\n3. “Debtor's Son”系指 Qiang Guo（郭强）（又名 Mileson Kwok、郭强，或任何其他别名），以及其雇员、代理人、律师、顾问或任何代表其行事之人。\n\n4. “Debtor's Daughter”系指 Mei Guo（郭美）（又名 Mei Gui、郭美，或任何其他别名），以及其雇员、代理人、律师、顾问或任何代表其行事之人。\n\n5. “Debtor's Purported Wife”系指 Hing Chi Ngok（岳庆芝）（又名 Hing Chi Ng、Yue Qingzhi、岳庆芝，或任何其他别名），以及其雇员、代理人、律师、顾问或任何代表其行事之人。\n\n6. “Debtor's Family”单独及合称指债务人、债务人之子、债务人之女及债务人据称的妻子，以及与债务人存在任何其他家庭关系之人。\n\n7. “2004 Discovery Targets”单独及合称指债务人、债务人家庭成员、ACA Capital Group Limited、Himalaya International Financial Group Ltd.、Himalaya International Clearing Ltd.、Himalaya International Payments Ltd.、Himalaya International Reserves Ltd.、Jesse Brown、William Je、William Je、Eastern Profit Corporation Limited、HK International Funds Investments (USA) Limited LLC、Bravo Luck Limited、Golden Spring (New York) Ltd.、Lamp Capital LLC、Greenwich Land LLC、Qu Guo Jiao、Daniel Thomas Podhaskie、Yvette Wang（又名 Yanping Wang、又名 Yan Ping Wang）、Ace Decade Holdings Limited、Dawn State Limited、Rule of Law Society IV Inc.、Rule of Law Foundation III, Inc.、Rule of Law Foundation IV, Inc.、Rule of Law Fund、Rule of Law Society、GTV Media Group, Inc.、Voice of Guo Media, Inc.、Saraca Media Group Inc.、Genever Holdings Corporation、Genever Holdings LLC、Gnews Media Group Inc.、G Fashion LLC、Gmusic LLC、Gnews LLC、Geducation、GFNY, Inc.、G-Club Investments Limited、G Club Operations LLC、G Club US Operations Inc.、G Club US Operations LLC、G Live, LLC、Gbroadcast, LLC、Gposts LLC、HCHK Property\nCase 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 600 of 1063\nManagement, Inc.、HCHK Technologies, Inc.、FMV Ltd./Freedom Media Venture Ltd.、Roscalitar 2、Himalaya New World Inc.、US Himalaya Capital Inc.、Hudson Diamond Holding, Inc.、Hudson Diamond Holding LLC、Hudson Diamond NY LLC、Infinity Treasury Management Inc.、Lexington Property and Staffing, Inc.、AI Group Holdings Inc.、Hamilton Capital Holdings Inc.、Booming Sail New York LLC、Himalaya Ventures LLC、Himalaya Ventures LLC、Himalaya Investment LLC、New York MOS Himalaya LLC、MOS Himalaya LLC、Crane Advisory Group、Maywind Trading LLC、Gettr USA, Inc.、Han Chunguang、Bingshang Jiao、Karin Maistrello、Mary Jiang、Jiaming Liu 及 Wencong Wang。\n\n8. “Including”或其任何变体，系指“包括但不限于”。\n\n9. “And”和“or”系指“and/or”，并应同时作合取及析取解释，以最大限度扩大其范围。\n\n10. “Any”、“all”和“each”系指“每一及所有”。\n\n11. “Each”和“every”系指“每一及所有”。\n\n12. “Third Party”系指您本人以外的人员或实体。\n\n13. “Transfer”具有《破产法典》第 101(54) 条所赋予的含义。\n\n14. “Document”系指 Fed. R. Civ. P. 34 范围内的任何信息或物品，包括但不限于任何种类、类型、性质或描述的每一份书面、录制或图形材料，而该等材料现由或曾由您占有、保管或控制，包括电子邮件的所有打印件和电子副本、以电子形式保存的计算机文件、函件、备忘录、录音带、速记或手写笔记、任何种类的书面表格、图表、蓝图、图纸、草图、曲线图、计划、文章、规格说明、日记、信件、\nCase 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 601 of 1063\n电报、照片、会议记录、合同、协议、调查资料、计算机打印输出、任何种类的数据汇编、电传、传真、电子邮件、短信、即时消息、语音消息、发票、订购单、支票、汇票、对账单、贷项通知单、报告、持仓报告、摘要、索引、书籍、分类账、笔记本、时间表、透明胶片、录音、目录、广告、宣传材料、电影、录像带、录音带、CD、计算机磁盘、宣传册、小册子、穿孔卡、工时单、推文、社交媒体帖子或任何其他种类的书面或录制材料，以及其全部元数据，无论以何种方式存储（无论为有形或电子形式）、记录、制作或复制；还包括但不限于上述任何文件的草稿或副本，如其含有原始文件中不存在的任何种类笔记、评论或标记，或者在其他方面与原始文件不完全相同。\n\n15. “Person(s)”系指个人、公司、独资企业、合伙企业、协会或任何其他实体。“Person”还包括任何代理人、代表或专家，包括但不限于律师或财务顾问。\n\n16. “Entity”系指任何自然人、公司、合伙企业、子公司、独资企业、商号、董事会、合资企业、协会、机构、主管机关、委员会或其他商业实体或法人，以及任何关联方、代理人、母公司，包括但不限于律师、财务顾问或任何其他代表。\n\n17. “Regarding”系指有关、描述、包含、提及、与之相关、支持、赞成、反对、强化、削弱、载于、在关联中考虑、涉及、证明、表明、报告、记录、暗指、答复、与之相连、评论、就其而言、关于、与之有关、讨论、显示、描述、反映、分析、构成及属于。\nCase 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 602 of 1063\n\n18. 就任何特定事项而言，“Relating to”、“relate(s) to”或“related to”系指包括但不限于构成、包含、涉及、含有、体现、反映、识别、陈述、直接或间接提及，或以任何方式与所确定的特定事项相关的任何文件。\n\n19. “Communication(s)”系指以最广泛可能的含义且不限于此的任何信息或知识传递（以事实、观点、询问或其他形式）。Communication(s)还指所有谈话、协议、询问或答复，无论是当面、通过电话、书面方式，还是通过电子传输设备，并包括但不限于所有函件、电子邮件、录音、传送单、备忘录、电话通信、语音消息、电报、电话传真、传真副本、电传、即时消息、聊天、短信、在留言板或群聊中的发布内容、社交媒体帖子、推文、上传至任何视频平台的视频、电话笔记，或在内部或与第三方之间传送的笔记。\n\n20. “Asset(s)”系指受占有、保管或控制的具有经济价值的任何项目。资产包括所有不动产和动产，包括但不限于房地产、土地、房屋、公寓、共管公寓、汽车、游艇、船只、飞机、喷气式飞机、直升机、现金、银行账户、加密货币、证券、应收账款、存货及其他有形和无形财产。\n\nIV. 应提供的文件\n\n1. 与由任何 2004 Discovery Targets 持有、控制、代表其持有，或以其他方式与其相关的任何账户有关的所有文件，包括任何及所有账户对账单、授权书、委托书、信托文件、指示或表格、已注销支票副本、函件，以及电汇及相关函件和指示。\nCase 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 603 of 1063\n\n2. 与属于、由任何 2004 证据开示对象持有、控制、代表其持有或以其他方式与其相关的任何资金、证券、财产或资产有关的所有文件，包括但不限于任何及所有账户对账单、授权书、委托书、信托文件、指示或表格、已注销支票副本、通信函件，以及电汇及相关函件和指示。\n\n3. 与同任何 2004 证据开示对象进行的任何商业、贸易或金融交易有关的所有文件，包括但不限于任何贷款、信贷额度、寄存、存款、掉期、证券交易、抵押贷款或 ISDA，包括任何及所有账户对账单、授权书、委托书、信托文件、指示或表格、已注销支票副本、通信函件，以及电汇及相关函件和指示。\n\n4. 与 2004 证据开示对象有关的任何电汇活动相关的所有文件，无论是否存在任何账户，包括但不限于所有电汇收据、账号、余额、授权书、与转账各方有关的身份识别信息、通信函件、指示或其他记录。\n\n5. 与您和 2004 证据开示对象之间的任何往来函件及通信有关的所有文件。\n\n6. 与任何 2004 证据开示对象的任何账户有关的所有文件，包括与账户开立、账户获授权使用人及账户维护有关的文件。\n\n7. 与任何 2004 证据开示对象有关的任何反洗钱、了解你的客户或其他合规活动相关的所有文件，包括但不限于任何 2004 证据开示对象提供的信息，或您获知的信息。\n\n8. 与来自任何国家的任何监管机构的任何通信有关、且涉及任何 2004 证据开示对象的所有文件，包括但不限于英格兰银行（Bank of England）、美国联邦储备系统（United States Federal Reserve）、美国证券交易委员会（S.E.C.）、美国商品期货交易委员会（CFTC）、美国金融业监管局（FINRA）、中国证券监督管理委员会（China Securities Regulatory Commission）、中国人民银行（People's Bank of China）、香港证券及期货事务监察委员会（Hong Kong Securities and Futures Commission）及香港金融管理局（Hong Kong Monetary Authority）。\n\nCase 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 605 of 1063\n\n附件 C-33\n\nB2540（表格 2540——《规则 2004 审查传票》）（12/15）Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 606 of\n\n美国破产法院（UNITED STATES BANKRUPTCY COURT）1063\n\n康涅狄格地区（District of Connecticut）\n\n关于 HO WAN KWOK（郭文贵）等人，\n\n1 案号：22-50073 (JAM)\n\n债务人 第 11 章\n\n（合并管理）\n规则 2004 审查传票\n\n致：中国银行纽约分行（Bank of China – New York Branch）和/或中国银行股份有限公司（Bank of China Limited）\n\n（传票所指向人员的姓名）\n\n证言：现命令您于下列载明的时间、日期和地点出席，根据《联邦破产程序规则》第 2004 条进行的审查并作证。随附准许该审查的法院命令副本。\n\n地点　日期和时间\n\nNeubert, Pepe & Monteith, P.C.\n195 Church Street, Floor 13　[TBD]\nNew Haven, Connecticut 06510\n\n审查将通过以下方式记录：法庭书记员/速记员\n\n提交：您或您的代表还必须在审查时携带下列文件、电子存储信息或物件，并准许对该等材料进行查验、复制、测试或取样：\n见随附的《文件提交请求》。\n\n以下《联邦民事诉讼规则》第 45 条的规定，根据《联邦破产程序规则》第 9016 条适用于破产案件，现随附于此——第 45(c) 条，关于履行地点；第 45(d) 条，关于作为传票对象的您所受保护；以及第 45(e) 条和第 45(g) 条，关于您回应本传票的义务及不予回应的潜在后果。\n\n日期：March , 2023\n\n法院书记官\n\n或\n\n书记官或副书记官签名　律师签名\n\n签发或请求本传票的、代表第 11 章受托人 Luc A. Despins（Luc A. Despins）的律师的姓名、地址、电子邮件地址和电话号码如下：\n\nDouglas S. Skalka, Esq.; Neubert, Pepe & Monteith, P.C.; 195 Church Street, New Haven, Connecticut 06510 dskalka@npmlaw.com; (203) 821-2000\n\n致签发或请求本传票的人之通知\n\n如本传票要求在审判前提交文件、电子存储信息或有形物品，或查验场所，则必须在向本传票所指向之人送达之前，向各方送达通知及本传票副本。Fed. R. Civ. P. 45(a)(4)。\n\n软件版权 (c) 1996-2022 Best Case, LLC - www.bestcase.com Best Case Bankruptcy 1 本第 11 章案件中的债务人为 Ho Wan Kwok（郭文贵）（亦称 Guo Wengui、Miles Guo 和 Miles Kwok，以及众多其他化名）（税务识别号码后四位：9595）、Genever Holdings LLC（税务识别号码后四位：8202）及 Genever Holdings Corporation。受托人、Genever Holdings LLC 及 Genever Holdings Corporation 的邮寄地址为 Paul Hastings LLP, 200 Park Avenue, New York, NY 10166，转交 Luc A. Despins，作为 Ho Wan Kwok 遗产的受托人（仅为通知及通信之目的）。\n\n送达证明\n\n（除非 Fed. R. Civ. P. 45 要求，否则本节不应提交法院。）\n\n我于（日期）收到向（个人姓名及职务，如有）发出的本传票。\n\n我按如下方式向被指名人交付副本，以送达本传票：\n\n于（日期）；或\n\n我未予执行即退回本传票，原因如下：\n\n除非本传票代表美国或其官员或代理人签发，我还已向证人支付一天出席费用及法律允许的里程费，金额为 \\$ 。\n\n我的差旅费用为 \\$，服务费用为 \\$，合计 \\$ 。\n\n我在伪证处罚的约束下声明，该等信息真实、正确。\n\n日期：\n\n送达人签名\n\n正楷姓名及职务\n\n送达人地址\n\n有关尝试送达等事项的补充信息：\n\n《联邦民事诉讼规则》第 45(c)、(d)、(e) 及 (g) 条（Effective 12/1/13）（根据《联邦破产程序规则》第 9016 条适用于破产案件）\n\n(c) 履行地点。\n\n(1) 审判、听证或证言录取。传票仅可按下列方式命令某人出席审判、听证或证言录取：\n\n(A) 在该人居住、受雇或经常亲自从事商业活动地点的 100 英里范围内；或\n\n(B) 在该人居住、受雇或经常亲自从事商业活动所在州内，如该人：\n\n(i) 是当事人或当事人的高级职员；或\n\n(ii) 被命令出席审判且不会产生重大费用。\n\n(2) 其他证据开示。传票可以命令：\n\n(A) 在该人居住、受雇或经常亲自从事商业活动地点的 100 英里范围内的地点提交文件、电子存储信息或物品；以及\n\n(B) 在待查验场所进行场所查验。\n\n(d) 对作为传票对象之人的保护；执行。\n\n(1) 避免不当负担或费用；制裁。负责签发及送达传票的当事人或律师必须采取合理措施，避免对作为传票对象之人施加不当负担或费用。要求履行的地区法院必须执行该义务，并对未遵守者的当事人或律师施加适当制裁，该制裁可包括损失的收入及合理的律师费。\n\n(2) 要求提交材料或准许查验的命令。\n\n(A) 无需出席。被命令提交文件、电子存储信息或有形物品，或准许查验场所之人，无须亲自到提交或查验地点出席，除非同时被命令出席证言录取、听证或审判。\n\n(B) 异议。被命令提交文件或有形物品，或准许查验之人，可以向传票中指定的当事人或律师送达书面异议，反对对全部或部分材料进行查验、复制、测试或取样，或反对查验场所，或反对以所要求的一种或多种形式提交电子存储信息。异议必须在规定履行时间之前或传票送达后 14 日之前（以较早者为准）送达。如提出异议，适用下列规则：\n\n(i) 在任何时候，经通知被命令人，送达人可以向要求履行的地区法院提出动议，请求作出强制提交或查验的命令。\n\n(ii) 仅可依该命令所指示要求实施这些行为，且该命令必须保护并非当事人亦非当事人高级职员之人，免受因履行而产生的重大费用。\n\n(3) 撤销或修改传票。\n\n(A) 必须撤销或修改的情形。经及时提出动议，要求履行的地区法院必须撤销或修改具有下列情形的传票：\n\n(i) 未给予合理履行时间；\n\n(ii) 要求某人在第 45(c) 条规定的地域限制之外履行；\n\n(iii) 要求披露享有特权或受其他保护的事项，且不存在适用的例外或豁免；或\n\n(iv) 对某人施加不当负担。\n\n(B) 可以撤销或修改的情形。为保护作为传票对象或受传票影响之人，要求履行的地区法院如经动议，可以撤销或修改要求下列事项的传票：\n\n(i) 披露商业秘密或其他保密研究、开发或商业信息；或\n\n(ii) 披露未受聘专家的意见或信息，该意见或信息并非描述争议中的特定事件，且源于未经任何一方请求的该专家研究。\n\n(C) 规定条件作为替代办法。在第 45(d)(3)(B) 条所述情形下，如送达人：\n\n(i) 证明对该证言或材料具有实质需要，且若不遭受不当困难则无法以其他方式满足该需要；以及\n\n(ii) 确保被传唤之人将获得合理补偿，\n\n法院可以不撤销或修改传票，而命令在规定条件下出席或提交。\n\n(e) 回应传票的义务。\n\n(1) 提交文件或电子存储信息。下列程序适用于提交文件或电子存储信息：\n\n(A) 文件。回应要求提交文件的传票之人，必须按照文件在通常业务过程中的保存方式提交，或者必须将文件整理并标记为与请求中的类别相对应。\n\n(B) 未规定提交电子存储信息的形式。如传票未规定提交电子存储信息的形式，回应之人必须以其通常保存的一种或多种形式，或以合理可用的一种或多种形式提交。\n\n(C) 电子存储信息仅以一种形式提交。回应之人无需以一种以上形式提交相同的电子存储信息。\n\n(D) 无法获取的电子存储信息。回应之人无需就其认定因不当负担或费用而无法合理获取的来源中的电子存储信息提供证据开示。在强制证据开示动议或保护令动议中，回应之人必须证明该信息因不当负担或费用而无法合理获取。如作出该证明，法院在考虑第 26(b)(2)(C) 条限制的情况下，如请求方证明存在正当理由，仍可命令从该等来源进行证据开示。法院可以规定证据开示的条件。\n\n(2) 主张特权或保护。\n\n(A) 被扣留的信息。以该信息享有特权或作为审判准备材料受保护为由扣留被传唤信息之人，必须：(i) 明确提出该主张；以及\n\n(ii) 以一种在不披露本身享有特权或受保护的信息的情况下，能够使各方评估该主张的方式，说明被扣留的文件、通信或有形物品的性质。\n\n(B) 已提供的信息。如为响应传票而提供的信息受到特权主张或审判准备材料保护主张的约束，提出该主张的人可以将该主张及其依据通知任何收到该信息的当事人。收到通知后，当事人必须立即返还、隔离或销毁所指定的信息及其所持有的任何副本；在该主张得到解决之前，不得使用或披露该信息；如果当事人在收到通知前披露了该信息，必须采取合理措施追回该信息；并且可以立即将该信息密封提交给要求履行义务所在地区的法院，以裁定该主张。提供该信息的人必须在该主张得到解决之前保存该信息。\n\n(g) 藐视法庭。要求履行义务所在地区的法院——以及在动议移送后，发出传票的法院——可以对已被送达但无充分理由不遵守传票或与其有关命令的人处以藐视法庭。\n\n有关查阅传票材料，请参见 Fed.R.Civ.P.45(a) Committee Note (2013)\n\n……\n\n文件出示请求\n\nI. 指示\n\n1. 除非另有说明，下列文件请求（统称“请求”，每一项称为“一项请求”）必须分别且具体地作出答复。除非出于善意提出异议，否则必须对每项请求作出完整答复；如提出异议，必须按照下文规定详细说明贵方异议的理由。如异议仅涉及某项请求的一部分，或其中包含的某个词语、短语或条款，贵方仅须说明对该部分的异议，并对其余请求作出答复。\n\n2. 电子存储信息必须依照下列指示提供：\n\na. 图像。黑白图像必须为 300 DPI Group IV 单页 TIFF 文件。彩色图像必须以 JPEG 格式提供。文件名不得包含嵌入空格或特殊字符（包括逗号）。文件夹名称不得包含嵌入空格或特殊字符（包括逗号）。所有 TIFF 图像文件必须具有唯一文件名，即 Bates 编号。每张图像的右下角必须标注连续的 Bates 编号。每个文件夹中的 TIFF 文件数量不应超过 1000 个。Excel 电子表格应具有以该文件 Bates 编号命名的占位图像。\n\nb. 图像加载文件\n\na. Concordance® 数据文件。数据文件（.DAT）包含将加载至 Concordance® 数据库的所有字段信息。.DAT 文件的第一行必须为标识字段名称的标题行。.DAT 文件必须使用以下 Concordance® 默认分隔符：逗号 ASCII 字符（020）引号 þ ASCII 字符（254）。日期字段应以如下格式提供：mm/dd/yyyy。日期和时间字段必须为两个单独的字段。如文件包括已成像的电子邮件及附件，则必须包括附件字段，以保留电子邮件与其附件之间的父/子关系。必须包括 OCRPATH 字段，以提供所提供存储介质上提取文本文件的文件路径和名称。文本文件必须以 FIRSTBATES 命名。不得在 .DAT 文件中包含文本。对于包含本机文件的文件，必须包括 LINK 字段，以提供本机文件的文件路径和名称。本机文件必须以 FIRSTBATES 命名。\n\nb. Concordance Image® 或 Opticon 交叉引用文件。图像交叉引用文件（.LOG 或 .OPT）将图像链接至数据库记录。该文件应为逗号分隔文件，每行由七个字段组成，并且数据库中的每幅图像均应在交叉引用文件中有一行，格式如下：ImageID,VolumeLabel,ImageFilePath,DocumentBreak,FolderBreak,Box Break,PageCoun。\n\nc. 文件文本。文本必须作为单独的文本文件提供，而非作为 .DAT 文件内的字段。应在 .DAT 文件中包括文本文件的完整路径（OCRPATH）。建议提供文件级 ANSI 文本文件，并按 FIRSTBATES/Image Key 命名。提取的文本文件必须置于单独的文件夹中，每个文件夹中的文本文件数量不应超过 1,000 个。文件夹名称中不得有特殊字符（包括逗号）。必须按文件级别提供文本文件。\n\nd. 特定文件类型的本机格式提供。为充分理解其内容和含义而合理需要以本机格式查看的文件类型，必须以本机格式提供。这些包括但不限于电子表格、类似电子表格的文件（Microsoft Excel、逗号分隔值、制表符分隔值等）、Microsoft PowerPoint 或其他特殊演示文件、数据库文件以及音频/视频文件。提供一份标有 Bates 编号的分隔页图像，表明存在本机文件，并将本机文件的路径作为 .dat 文件中的字段包括在内。所提供的本机文件应以与该文件分隔页相对应的 Bates 编号命名。将本机文件归入按递增方式命名的“NATIVE”目录中，并与图像目录分开。\n\ne. 去重。对于存在完全重复件的每份电子文件，仅提供一份副本。对于电子邮件，应基于从 BCC、Body、CC、From、IntMsgID、To 和 Attach 属性生成的 MD5 哈希值合并重复件。对于电子邮件附件和独立电子文件，应基于整个文件的 MD5 哈希值合并重复件。\n\nf. 元数据。以符合 Concordance 要求的加载文件（.dat）形式，为每份文件提供提取的元数据。.DAT 文件的第一行必须为标识字段名称的标题行。.DAT 文件必须使用以下 Concordance 默认分隔符：逗号 , ASCII 字符（020）引号 þ ASCII 字符（254）。\n\n日期字段应以如下格式提供：mm/dd/yyyy。日期和时间字段必须为两个单独的字段。下列为所需元数据：\n\n案件 22-50073 文书 1592 提交 03/24/23 登记 03/24/23 10:57:37 第 611 页，共 1063 页\n\n字段名称　示例数据　说明\n\nFIRSTBATES　EDC0000001　本机文件文件/电子邮件的第一个 Bates 编号\n\nLASTBATES　EDC0000001　本机文件文件/电子邮件的最后一个 Bates 编号\n\n对于单页，应填充 LASTBATES 字段\n\nATTACHRANGE　EDC0000001 - EDC0000015　父文件第一页的 Bates 编号至最后一个附件“子”文件最后一页的 Bates 编号\n\nBEGATTACH　EDC0000001　附件范围的第一个 Bates 编号\n\nENDATTACH　EDC0000015　附件范围的最后一个 Bates 编号\n\nCUSTODIAN　Smith, John　电子邮件：电子邮件所在的邮箱\n\n本机文件：文件来源的个人或部门名称\n\nFROM　John Smith　电子邮件：发件人\n\n本机文件：文件作者\n\n多个条目应以分号分隔\n\nTO　Coffman, Janice; LeeW [mailto:LeeW@MSN.com]　收件人\n\n多个条目应以分号分隔\n\nCC　Frank Thompson [mailto:frank_Thompson@cdt.com]　抄送收件人\n\n多个条目应以分号分隔\n\nBCC　John Cain　密送收件人\n\n多个条目应以分号分隔\n\nSUBJECT　Board Meeting Minutes　电子邮件：电子邮件主题行　本机文件：文件标题（如有）\n\nFILE_NAME　BoardMeetingMinutes.docx　本机文件：原始本机文件名称，包括扩展名\n\nDATE_SENT　10/12/2010　电子邮件：电子邮件发送日期\n\n本机文件：（空）\n\nTIME_SENT/TIME_ZONE　07:05 PM GMT　电子邮件：电子邮件发送时间/电子邮件标准化所在的时区\n\nTIME_ZONE　GMT　在转换过程中电子邮件被标准化所在的时区。\n\nLINK　EDC0000001.msg　指向电子邮件或本机文件文件的超链接\n\n链接文件必须按 FIRSTBATES 编号命名\n\nFILE_EXTEN　MSG　表示电子邮件或本机文件的文件类型扩展名\n\nAUTHOR　John Smith　电子邮件：（空）\n\n本机文件：文件作者\n\nDATE_CREATED　10/10/2010　电子邮件：（空）\n\n本机文件：文件创建日期\n\n案件 22-50073 文书 1592 提交 03/24/23 登记 03/24/23 10:57:37 第 612 页，共 1063 页\n\nTIME_CREATED　10:25 AM　电子邮件：（空）\n\n本机文件：文件创建时间\n\n该数据必须为单独字段，不得与 DATE_CREATED 字段合并\n\nDATE_MOD　10/12/2010　电子邮件：（空）\n\n本机文件：文件最后修改日期\n\nTIME_MOD　07:00 PM　电子邮件：（空）\n\n本机文件：文件最后修改时间\n\n该数据必须为单独字段，不得与 DATE_MOD 字段合并\n\nDATE_ACCESSD　10/12/2010　电子邮件：（空）\n\n本机文件：文件最后访问日期\n\nTIME_ACCESSD　07:00 PM　电子邮件：（空）\n\n本机文件：文件最后访问时间\n\n该数据必须为单独字段，不得与 DATE_ACCESSD 字段合并\n\nFILE_SIZE　5,952　本机文件文件/电子邮件的大小，单位为 KB\n\nPGCOUNT　1　本机文件文件/电子邮件中的页数\n\nPATH　Email: (empty) Agenda.doc　电子邮件：（空）\n\n本机文件：存储本机文件文件的路径，包括原始文件名。\n\nINTFILEPATH　Personal Folders\\Deleted Items\\Board Meeting Minutes.msg　电子邮件：电子邮件的原始位置，包括原始文件名。\n\n本机文件：（空）\n\nINTMSGID　<000805c2c71b\\$75977050\\$cb8306d1@MSN>　电子邮件：唯一消息 ID　本机文件：（空）\n\nMD5HASH　d131dd02c5e6eec4693d9a0698aff95c2fcab58712467eab4004583eb8fb7f89　文件的 MD5 哈希值。\n\nOCRPATH　TEXT/001/EDC0000001.txt　本机文件提取文本的路径\n\n3. 每项请求均独立适用并应独立解释，且除非另有说明，任何请求均不限制任何其他请求的范围。\n\n4. 所有文件均应按其在日常业务过程中保存的方式提供，或者应予组织和标记，以对应这些请求中的类别。\n\n5. 本文所载每项请求均延及所有文件：(a) 由贵方占有、保管或控制的文件；或 (b) 由任何代表贵方行事的人占有、保管或控制的文件，\n\n案件 22-50073 文书 1592 提交 03/24/23 登记 03/24/23 10:57:37 第 613 页，共 1063 页\n\n包括贵方律师或其他代表和顾问。每份文件均应完整提供。\n\n6. 如要求贵方提供的文件已不再由贵方占有、保管或控制，则贵方的答复必须：(a) 详细说明该文件的性质及其内容；(b) 确认编制或撰写该文件的人（以及在适用情况下该文件发送给的人）；(c) 确认该文件编制或创建的日期；(d) 说明该文件是否：(i) 遗失或丢失，(ii) 已被销毁，(iii) 已自愿或非自愿地转移给他人，或 (iv) 已以其他方式处置；(e) 说明该处置的原因以及相关事实和情形；(f) 确认授权该处置的人；(g) 确认该处置的日期或大致日期；(h) 说明该文件最近一次由贵方占有、保管或控制的时间；以及 (i) 确认目前占有、保管或控制该文件的人（如有）。\n\n7. 如要求贵方提供的文件已被销毁，则除前述指示所要求的信息外，贵方的答复还必须说明：(a) 销毁该文件的原因；(b) 销毁该文件的人的身份；以及 (c) 指示销毁该文件的人的身份。\n\n8. 如贵方主张所请求的某一文件享有特权或律师工作成果保护，则贵方的答复必须：(a) 说明：(i) 对该文件作出足以支持贵方关于该文件享有特权之主张的描述；(ii) 该文件的标题；(iii) 该文件的日期；(iv) 该文件的作者；(v) 该文件的收件人；(vi) 收到或见到该文件原件或任何草稿、副本或复制件的每一人的身份；(vii) 该文件本身，或该文件中载有或提及的任何信息，是否由任何其他人占有、保管或控制；如是，该等人员的身份，以及说明该等信息如何进入其占有范围的陈述；(viii) 据以扣留该文件的特权主张；以及 (ix) 贵方将据以支持该等特权主张的所有情形；并且 (b) 就基于特权主张而被扣留的每一文件，根据 D. Conn. L. Civ. R. 26(e)，制作一份特权清单，其中包含本指示第 (a) 部分所要求的全部信息。对于文件请求中未提出特权或工作成果主张的任何部分，应完整提供相关文件。\n\n案号 22-50073 文件 1592 提交日期 03/24/23 录入日期 03/24/23 10:57:37 第 614 页，共 1063 页\n\n9. 如本应予提供的文件的一部分包含受特权主张约束的信息，则仅应按照上述指示从该文件中删除或遮蔽受特权主张约束的该部分，其余部分应予提供。\n\n10. 本请求具有持续性。现指示贵方：(a) 在得知先前答复不完整或不正确后，立即补充或更正任何后来得知不完整或不正确的答复；以及 (b) 提供根据以下规定所要求的任何额外文件。\n\n11. 如某一文件使用英语以外的语言，贵方应提供该文件。如某一文件使用英语以外的语言，且存在英文译本，贵方应同时提供两份文件。\n\n12. 对实体的所有提及均包括其所有关联方。\n\n13. 对个人姓名的所有提及均包括所有替代姓名、别名或昵称。\n\n案号 22-50073 文件 1592 提交日期 03/24/23 录入日期 03/24/23 10:57:37 第 615 页，共 1063 页\n\n14. 除非另有明确说明，文件请求涵盖的期间为自 February 5, 2012 起至文件请求答复到期之日止。\n\nII. 解释规则\n\n15. (a) 任何单数名词的使用应解释为包括复数，反之亦然；以及 (b) 任何时态的动词应解释为该动词所有其他时态的使用。\n\n16. (a) “and”和“or”应视为必要时按连词关系或选择关系解释，以使任何请求的范围包括否则可能被解释为在其范围之外的所有答复；以及 (b) “each”和“any”应视为包括并涵盖“every”和“all”二词。\n\nIII. 定义\n\nD. Conn. L. Civ. R. 26(c) 所规定的定义，以及经 D. Conn. Bankr. L.R. 2004-1(a) 纳入的 D. Conn. L. Civ. R. 26(d) 所规定的解释规则，适用于文件请求。此外，本文件请求中使用的下列术语具有以下含义：\n\n1. “You”或“Your”或“Yourself”系指中国银行纽约分行（Bank of China – New York Branch）和/或中国银行股份有限公司（Bank of China Limited）。\n\n2. “Debtor”系指 Ho Wan Kwok（郭文贵，亦称 Miles Kwok、Miles Guo、Guo Wengui、Guo Haoyun、郭文贵或任何其他别名），连同其雇员、代理人、律师、顾问或任何代表其行事的人员。\n\n案号 22-50073 文件 1592 提交日期 03/24/23 录入日期 03/24/23 10:57:37 第 616 页，共 1063 页\n\n3. “Debtor's Son”系指 Qiang Guo（郭强，亦称 Mileson Kwok、郭强或任何其他别名），连同其雇员、代理人、律师、顾问或任何代表其行事的人员。\n\n4. “Debtor's Daughter”系指 Mei Guo（郭美，亦称 Mei Gui、郭美或任何其他别名），连同其雇员、代理人、律师、顾问或任何代表其行事的人员。\n\n5. “Debtor's Purported Wife”系指 Hing Chi Ngok（岳庆芝，亦称 Hing Chi Ng、Yue Qingzhi、岳庆芝或任何其他别名），连同其雇员、代理人、律师、顾问或任何代表其行事的人员。\n\n6. “Debtor's Family”系指单独及共同的债务人、债务人的儿子、债务人的女儿及债务人声称的妻子，以及与债务人有任何其他亲属关系的人员。\n\n7. “2004 Discovery Targets”系指单独及共同的债务人、债务人家庭成员、ACA Capital Group Limited、Himalaya International Financial Group Ltd.、Himalaya International Clearing Ltd.、Himalaya International Payments Ltd.、Himalaya International Reserves Ltd.、Jesse Brown、William Je、William Je、Eastern Profit Corporation Limited、HK International Funds Investments (USA) Limited LLC、Bravo Luck Limited、Golden Spring (New York) Ltd.、Lamp Capital LLC、Greenwich Land LLC、Qu Guo Jiao、Daniel Thomas Podhaskie、Yvette Wang（亦称 Yanping Wang、Yan Ping Wang）、Ace Decade Holdings Limited、Dawn State Limited、Rule of Law Society IV Inc.、Rule of Law Foundation III, Inc.、Rule of Law Foundation IV, Inc.、Rule of Law Fund、Rule of Law Society、GTV Media Group, Inc.、Voice of Guo Media, Inc.、Saraca Media Group Inc.、Genever Holdings Corporation、Genever Holdings LLC、Gnews Media Group Inc.、G Fashion LLC、Gmusic LLC、Gnews LLC、Geducation、GFNY, Inc.、G-Club Investments Limited、G Club Operations LLC、G Club US Operations Inc.、G Club US Operations LLC、G Live, LLC、Gbroadcast, LLC、Gposts LLC、HCHK Property Management, Inc.、HCHK Technologies, Inc.、FMV Ltd./Freedom Media Venture Ltd.、Roscalitar 2、Himalaya New World Inc.、US Himalaya Capital Inc.、Hudson Diamond Holding, Inc.、Hudson Diamond Holding LLC、Hudson Diamond NY LLC、Infinity Treasury Management Inc.、Lexington Property and Staffing, Inc.、AI Group Holdings Inc.、Hamilton Capital Holdings Inc.、Booming Sail New York LLC、Himalaya Ventures LLC、Himalaya Ventures LLC、Himalaya Investment LLC、New York MOS Himalaya LLC、MOS Himalaya LLC、Crane Advisory Group、Maywind Trading LLC、Gettr USA, Inc.、Han Chunguang、Bingshang Jiao、Karin Maistrello、Mary Jiang、Jiaming Liu及 Wencong Wang。\n\n案号 22-50073 文件 1592 提交日期 03/24/23 录入日期 03/24/23 10:57:37 第 617 页，共 1063 页\n\n8. “Including”或其任何变体意为“包括但不限于”。\n\n9. “And”和“or”意为“和/或”，并应按连词关系和选择关系解释，以最大限度扩大其范围。\n\n10. “Any”和“all”以及“each”意为“每一及所有”。\n\n11. “Each”和“every”意为“每一及所有”。\n\n12. “Third Party”系指贵方以外的个人或实体。\n\n13. “Transfer”具有《破产法典》（Bankruptcy Code）第 101(54) 条赋予该词的含义。\n\n14. “Document”系指属于 Fed. R. Civ. P. 34 范围内的任何信息或物品，包括但不限于每一及所有已由或曾由贵方占有、保管或控制的任何种类、类型、性质或描述的书面、记录或图形材料，包括电子邮件的所有印刷件和电子副本、以电子形式保存的计算机文件、信函、备忘录、磁带、速记或手写笔记、任何种类的书面表格、图表、蓝图、绘图、草图、曲线图、计划、文章、规格说明、日记、信件、\n\n案号 22-50073 文件 1592 提交日期 03/24/23 录入日期 03/24/23 10:57:37 第 618 页，共 1063 页\n\n电报、照片、会议记录、合同、协议、调查资料、计算机打印件、任何种类的数据汇编、电传、传真、电子邮件、短信、即时消息、语音消息、发票、订购单、支票、汇票、对账单、贷项通知单、报告、头寸报告、摘要、索引、书籍、账簿、笔记本、日程表、透明胶片、录音、目录、广告、宣传材料、电影、录像带、录音带、CD、计算机磁盘、宣传册、小册子、穿孔卡、工时单、推文、社交媒体帖子或任何其他种类的书面或记录材料，以及其全部元数据，无论其以何种方式存储（无论为有形形式或电子形式）、记录、制作或复制；还包括但不限于前述任何文件的草稿或副本，如该等草稿或副本包含原始文件中未载有的任何种类的笔记、评论或标记，或以其他方式与原始文件不完全相同。\n\n15. “Person(s)”系指个人、公司、独资企业、合伙企业、协会或任何其他实体。“Person”还包括任何代理人、代表或专家，包括但不限于律师或财务顾问。\n\n16. “Entity”系指任何自然人、公司、合伙企业、子公司、独资企业、商号、董事会、合资企业、协会、机构、主管机关、委员会或其他商业实体或法人，以及任何关联方、代理人、母公司，包括但不限于律师、财务顾问或任何其他代表。\n\n17. “Regarding”意为关于、描述、构成、提及、与之相关、支持、有利于、反对、加强、削弱、位于其中、结合其予以考虑、与之有关、证明、表明、报告、记录、暗指、答复、与之连接、评论、就其而言、关于、与之有关、讨论、展示、描述、反映、分析、构成及是。\n\n案号 22-50073 文件 1592 提交日期 03/24/23 录入日期 03/24/23 10:57:37 第 619 页，共 1063 页\n\n18. 当提及任何特定主题事项时，“Relating to”、“relate(s) to”或“related to”意为包括但不限于构成、包括、涉及、包含、体现、反映、识别、陈述、直接或间接提及，或以任何方式与所识别的特定主题事项相关的任何文件。\n\n19. “Communication(s)”在最广义上且不限于此，系指任何信息或知识的传递（以事实、观点、询问或其他形式）。Communication(s)还系指所有谈话、协议、询问或答复，无论是当面、通过电话、以书面形式或通过电子传输设备，并包括但不限于所有信函、电子邮件、录音、传送单、备忘录、电话通信、语音消息、电报、电话传真、传真件、电传、即时消息、聊天、短信、在留言板或群聊中的帖子、社交媒体帖子、推文、上传至任何视频平台的视频、电话笔记，或内部传送或与第三方传送的笔记。\n\n20. “Asset(s)”系指受占有、保管或控制的任何具有经济价值的项目。资产包括所有不动产和动产，包括但不限于房地产、土地、房屋、公寓、共管公寓、汽车、游艇、船舶、飞机、喷气机、直升机、现金、银行账户、加密货币、证券、应收账款、存货及其他有形和无形财产。\n\nIV. 应提供的文件\n\n1. 与由任何 2004 取证对象持有、控制、代为持有或以其他方式与其相关的任何账户有关的所有文件，包括任何及所有账户对账单、授权书、委托书、信托文件、指示或表格、已注销支票副本、信函，以及电汇及相关信函和指示。\n\n案号 22-50073 文件 1592 提交日期 03/24/23 录入日期 03/24/23 10:57:37 第 620 页，共 1063 页\n\n2. 与属于、由任何 2004 审查取证对象持有、控制、代表其持有，或以其他方式与任何 2004 审查取证对象有关的任何资金、证券、财产或资产相关的所有文件，包括但不限于任何及所有账户对账单、授权书、委托书、信托文件、指示或表格、已注销支票副本、通信函件，以及电汇及相关通信函件和指示。\n\n3. 与任何 2004 审查取证对象进行的任何商业、贸易或金融交易相关的所有文件，包括但不限于任何贷款、信贷额度、寄托、存款、互换、证券交易、抵押贷款或 ISDA，包括任何及所有账户对账单、授权书、委托书、信托文件、指示或表格、已注销支票副本、通信函件，以及电汇及相关通信函件和指示。\n\n4. 与 2004 审查取证对象有关的任何电汇活动相关的所有文件，不论是否存在任何账户，包括但不限于所有电汇收据、账户号码、余额、授权、与转账当事人有关的身份识别信息、通信函件、指示或其他记录。\n\n5. 与您和 2004 审查取证对象之间的任何函件往来和通信相关的所有文件。\n\n6. 与任何 2004 审查取证对象的任何账户相关的所有文件，涉及该账户的开立、该账户的获授权使用人及该账户的维护。\n\n7. 与涉及任何 2004 审查取证对象的任何反洗钱、了解你的客户或其他合规活动相关的所有文件，包括但不限于由任何 2004 审查取证对象提供或由您获悉的任何信息。\n\n8. 与就任何 2004 审查取证对象而与任何国家的任何监管机构进行的任何通信有关的所有文件，包括但不限于英格兰银行（Bank of England）、美国联邦储备系统（United States Federal Reserve）、\n\n美国证券交易委员会（S.E.C.）、美国商品期货交易委员会（CFTC）、美国金融业监管局（FINRA）、中国证券监督管理委员会（China Securities Regulatory Commission）、中国人民银行（People's Bank of China）、香港证券及期货事务监察委员会（Hong Kong Securities and Futures Commission）及香港金融管理局（Hong Kong Monetary Authority）。\n附件 C-34\nB2540（表格 2540——规则 2004 审查传票）（12/15）案号 22-50073 文件 1592 提交日期 03/24/23 录入日期 03/24/23 10:57:37 第 623 页，共\n\n美国破产法院（UNITED STATES BANKRUPTCY COURT）1063\n\n康涅狄格州地区（District of Connecticut）\n\n关于 HO WAN KWOK（郭文贵）等人，\n\n1 案号 22-50073 (JAM)\n\n债务人 第 11 章\n\n（合并管理）\n规则 2004 审查传票\n\n致：U.S. Bank National Association（美国合众银行全国协会）\n\n（传票所指向之人的姓名）\n\n证言：兹命令您于下列规定的时间、日期和地点出席，依据《联邦破产程序规则》（Federal Rules of Bankruptcy Procedure）规则 2004 接受审查并作证。随附准许该审查的法院命令副本。\n\n地点　日期和时间\n\nNeubert, Pepe & Monteith, P.C.\n195 Church Street, Floor 13　[待定]\nNew Haven, Connecticut 06510\n\n审查将通过以下方式记录：法院记录员/速记员\n\n提交：您或您的代表还必须携带下列文件、电子存储信息或物件参加审查，并必须准许对该材料进行检查、复制、测试或取样：\n见随附的文件提交请求。\n\n《联邦民事诉讼规则》（Fed. R. Civ. P.）第 45 条的下列规定，经《联邦破产程序规则》（Fed. R. Bankr. P.）第 9016 条适用于破产案件，现随附于后——与履行地点有关的第 45(c) 条；与作为传票对象的您所受保护有关的第 45(d) 条；以及与您答复本传票的义务和未予答复的潜在后果有关的第 45(e) 条和第 45(g) 条。\n\n日期：March , 2023\n\n法院书记官\n\n或\n\n书记官或副书记官签名　律师签名\n\n签发或申请本传票的第 11 章受托人 Luc A. Despins（Luc A. Despins）的代理律师姓名、地址、电子邮件地址和电话号码如下：\n\nDouglas S. Skalka, Esq.; Neubert, Pepe & Monteith, P.C.; 195 Church Street, New Haven, Connecticut 06510 dskalka@npmlaw.com; (203) 821-2000\n\n致签发或申请本传票之人的通知\n\n如本传票命令在审判前提交文件、电子存储信息或有形物品，或检查场所，则必须在向传票所指向之人送达前，向各方当事人送达通知及本传票副本。Fed. R. Civ. P. 45(a)(4)。\n\n软件版权 (c) 1996-2022 Best Case, LLC - www.bestcase.com Best Case Bankruptcy 1 本第 11 章案件中的债务人为 Ho Wan Kwok（郭文贵）（亦称 Guo Wengui、Miles Guo 和 Miles Kwok，以及众多其他别名）（税务识别号码后四位：9595）、Genever Holdings LLC（税务识别号码后四位：8202）及 Genever Holdings Corporation。受托人、Genever Holdings LLC 及 Genever Holdings Corporation 的邮寄地址为 Paul Hastings LLP, 200 Park Avenue, New York, NY 10166，收件人为 Luc A. Despins，作为 Ho Wan Kwok 财产的受托人（仅为通知和通信之目的）。\n\n送达证明\n\n（除非 Fed. R. Civ. P. 45 要求，否则本节不应向法院提交。）\n\n本人于（日期）收到向（个人姓名及职务，如有）发出的本传票。\n\n本人以下列方式向所列明之人交付副本，以送达本传票：\n\n于（日期）；或\n\n本人退回未执行的传票，原因是：\n\n除非本传票系代表美国或其官员或代理人签发，本人亦已向证人支付一天出席费用及法律允许的里程费，金额为 \\$ 。\n\n本人就差旅费用收取 \\$，就服务费用收取 \\$，合计 \\$ 。\n\n本人依伪证罪处罚之规定声明，该等信息真实且正确。\n\n日期：\n\n送达人员签名\n\n正楷姓名及职务\n\n送达人员地址\n\n关于尝试送达等的补充信息：\n《联邦民事诉讼规则》第 45(c)、(d)、(e) 和 (g) 条（Effective 12/1/13）（经《联邦破产程序规则》第 9016 条适用于破产案件）\n(c) 履行地点。\n\n(1) 审判、听证或证言录取。传票仅可按下列方式命令某人出席审判、听证或证言录取：\n\n(A) 在该人居住、受雇或经常亲自进行商业活动地点的 100 英里范围内；或\n\n(B) 在该人居住、受雇或经常亲自进行商业活动所在州内，若该人\n\n(i) 为当事人或当事人的高级职员；或\n\n(ii) 被命令出席审判且不会产生重大费用。\n\n(2) 其他取证。传票可以命令：\n\n(A) 在该人居住、受雇或经常亲自进行商业活动地点的 100 英里范围内某地点提交文件、电子存储信息或物品；以及\n\n(B) 在待检查场所对该场所进行检查。\n(d) 对作为传票对象之人的保护；执行。\n\n(1) 避免不当负担或费用；制裁。负责签发和送达传票的当事人或律师必须采取合理措施，避免对作为传票对象之人施加不当负担或费用。要求履行义务所在地区的法院必须执行该义务，并对未遵守者的当事人或律师施加适当制裁，其中可包括损失的收入和合理的律师费。\n(2) 命令提交材料或准许检查。\n\n(A) 无需出席。被命令提交文件、电子存储信息或有形物品，或准许检查场所之人，无须亲自到提交或检查地点出席，除非同时被命令出席证言录取、听证或审判。\n\n(B) 异议。被命令提交文件或有形物品，或准许检查之人，可向传票中指定的当事人或律师送达书面异议，反对检查、复制、测试或取样任何或全部材料，或反对检查场所——或反对以所请求的一种或多种形式提交电子存储信息。异议必须在规定履行时间之前或传票送达后 14 日之前（以较早者为准）送达。如提出异议，适用下列规则：\n\n(i) 送达人可随时在通知被命令之人后，向要求履行义务所在地区的法院提出动议，请求作出强制提交或检查的命令。\n\n(ii) 仅可依命令所指示的方式要求实施该等行为，且该命令必须保护既非当事人亦非当事人高级职员之人免于承担因履行而产生的重大费用。\n(3) 撤销或修改传票。\n\n(A) 必须撤销或修改的情形。经及时动议，要求履行义务所在地区的法院必须撤销或修改符合下列情形的传票：\n\n(i) 未给予合理的履行时间；\n\n(ii) 要求某人在第 45(c) 条规定的地理范围之外履行；\n\n(iii) 要求披露享有特权或受其他保护的事项，且不适用任何例外或豁免；或\n\n(iv) 使某人承受不当负担。\n\n(B) 可撤销或修改的情形。为保护作为传票对象或受传票影响之人，经动议，要求履行义务所在地区的法院可以撤销或修改要求下列事项的传票：\n\n(i) 披露商业秘密或其他机密研究、开发或商业信息；或\n\n(ii) 披露未受聘专家的意见或信息，该等意见或信息并非描述争议中的具体事件，且源自并非由当事人请求进行的该专家研究。\n\n(C) 以规定条件作为替代。在第 45(d)(3)(B) 条所述情形中，如送达人：\n\n(i) 证明对证言或材料具有重大需要，且若不承受不当困难则无法以其他方式满足该需要；以及\n\n(ii) 确保被传唤之人将获得合理补偿，\n\n则法院可以不撤销或修改传票，而是命令在规定条件下出席或提交。\n(e) 答复传票的义务。\n\n(1) 提交文件或电子存储信息。下列程序适用于提交文件或电子存储信息：\n\n(A) 文件。答复要求提交文件之传票的人必须按文件在正常业务过程中保存的方式提交，或必须将其整理并标注，以对应请求中的类别。\n\n(B) 未规定电子存储信息的提交形式。如传票未规定电子存储信息的提交形式，答复之人必须以其通常保存的一种或多种形式，或以合理可用的一种或多种形式提交。\n\n(C) 电子存储信息仅以一种形式提交。答复之人无须以多于一种形式提交相同的电子存储信息。\n\n(D) 无法访问的电子存储信息。答复之人无须从其认定因不当负担或费用而无法合理访问的来源提供电子存储信息的取证。对于强制取证动议或保护令动议，答复之人必须证明该信息因不当负担或费用而无法合理访问。如作出该证明，法院在考虑第 26(b)(2)(C) 条的限制后，如请求方证明有正当理由，仍可命令从该等来源进行取证。法院可以规定该取证的条件。\n(2) 主张特权或保护。\n\n(A) 被扣留的信息。基于被传唤信息享有特权或作为审判准备材料受到保护而扣留该信息之人必须：(i) 明确提出该主张；以及\n\n(ii) 以一种在不披露本身享有特权或受保护的信息的情况下，能够使各方评估该主张的方式，说明被扣留的文件、通信或有形物品的性质。\n\n(B) 已提交的信息。如为响应传票而提交的信息受到特权主张或作为审判准备材料受保护的主张约束，提出该主张的人可以将该主张及其依据通知任何收到该信息的一方。接到通知后，一方必须立即返还、隔离或销毁所指明的信息及其持有的任何副本；在该主张得到解决之前，不得使用或披露该信息；如该方在接到通知前已披露该信息，必须采取合理措施追回该信息；并且可以立即向要求履行义务所在地区的法院密封提交该信息，以裁定该主张。提交该信息的人必须保存该信息，直至该主张得到解决。\n\n(g) 藐视法庭。要求履行义务所在地区的法院——以及在动议被移送后，签发传票的法院——可以认定已被送达但无正当理由未遵守传票或与其相关命令的人构成藐视法庭。\n\n有关获取传票材料，见 Fed.R.Civ.P.45(a) Committee Note (2013)\n\n……\n\n文件提交请求\nI. 指示\n\n1. 除非另有说明，下列文件请求（统称“请求”，各称“一项请求”）必须分别且具体地作出回应。除非善意提出异议，否则必须完整答复每项请求；如提出异议，必须按照下文规定详细说明贵方异议的理由。如异议仅涉及某项请求的一部分，或其中包含的某一词语、短语或条款，贵方仅须说明对该部分的异议，并答复其余请求。\n\n2. 电子存储信息必须依照下列指示提交：\n\na. 图像。黑白图像必须为 300 DPI Group IV 单页 TIFF 文件。彩色图像必须以 JPEG 格式提交。文件名不得包含嵌入的空格或特殊字符（包括逗号）。文件夹名称不得包含嵌入的空格或特殊字符（包括逗号）。所有 TIFF 图像文件必须具有唯一文件名，即 Bates 编号。每张图像的右下角必须标注连续的 Bates 编号。每个文件夹中的 TIFF 文件数量不得超过 1000 个文件。Excel 电子表格应具有以该文件的 Bates 编号命名的占位图像。\n\nb. 图像加载文件\n\na. Concordance® 数据文件。数据文件（.DAT）包含将被加载至 Concordance® 数据库的所有字段信息。.DAT 文件的第一行必须为标明字段名称的标题行。.DAT 文件必须使用下列 Concordance® 默认分隔符：逗号 ASCII 字符（020）；引号 þ ASCII 字符（254）。日期字段应以 mm/dd/yyyy 格式提供。日期和时间字段必须为两个独立字段。如文件包括经图像化处理的电子邮件及附件，必须包括附件字段，以保留电子邮件与其附件之间的父/子关系。必须包括 OCRPATH 字段，以提供已提交存储介质上提取文本文件的文件路径及名称。文本文件必须以 FIRSTBATES 命名。不得在 .DAT 文件中包含文本。对于含有原生文件的文件，必须包括 LINK 字段，以提供原生文件的文件路径及名称。原生文件必须以 FIRSTBATES 命名。\n\nb. Concordance Image® 或 Opticon 交叉引用文件。图像交叉引用文件（.LOG 或 .OPT）将图像链接至数据库记录。其应为以逗号分隔的文件，每行由七个字段组成，数据库中的每张图像均应在交叉引用文件中有一行，格式如下：ImageID,VolumeLabel,ImageFilePath,DocumentBreak,FolderBreak,Box Break,PageCoun。\n\nc. 文件文本。文本必须作为独立文本文件提交，而不得作为 .DAT 文件中的字段提交。文本文件的完整路径（OCRPATH）应包括在 .DAT 文件中。建议提供文件级 ANSI 文本文件，并以 FIRSTBATES/Image Key 命名。提取的文本文件必须置于单独文件夹中，每个文件夹中的文本文件数量不得超过 1,000 个文件。文件夹名称中不得有特殊字符（包括逗号）。文本文件必须按文件级别提供。\n\nd. 某些文件类型的原生格式提交。为充分理解其内容和含义而合理需要以原生格式查看的文件类型，必须以原生格式提交。此类文件包括但不限于电子表格、类似电子表格的文件（Microsoft Excel、逗号分隔值、制表符分隔值等）、Microsoft PowerPoint 或其他特殊演示文件、数据库文件以及音频/视频文件。提供一张标有 Bates 编号的隔页图像，表明存在原生文件，并将原生文件的路径作为字段包括在 .dat 文件中。提交的原生文件应以与该文件隔页相对应的 Bates 编号命名。将原生文件归入按递增方式命名的“NATIVE”目录中，并与图像目录分开。\n\ne. 去重。对于存在完全重复件的每份电子文件，仅提交一份副本。对于电子邮件，根据由 BCC、Body、CC、From、IntMsgID、To 和 Attach 属性生成的 MD5 哈希值合并重复件。对于电子邮件附件及独立电子文件，根据整个文件的 MD5 哈希值合并重复件。\n\nf. 元数据。以符合 Concordance 的加载文件（.dat）形式，为每份文件提交提取的元数据。.DAT 文件的第一行必须为标明字段名称的标题行。.DAT 文件必须使用下列 Concordance 默认分隔符：逗号 , ASCII 字符（020）；引号 þ ASCII 字符（254）。\n\n日期字段应以 mm/dd/yyyy 格式提供。日期和时间字段必须为两个独立字段。以下列出所需元数据：\nCase 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 628 of 1063\n\n字段名称　示例数据　说明\n\nFIRSTBATES　EDC0000001　原生文件文件/电子邮件的第一个 Bates 编号\nLASTBATES　EDC0000001　原生文件文件/电子邮件的最后一个 Bates 编号\n对于单页文件，应填写 LASTBATES 字段。\nATTACHRANGE　EDC0000001\n-　父文件第一页的 Bates 编号至最后一个附件“子”文件最后一页的 Bates 编号\nEDC0000015\nBEGATTACH　EDC0000001　附件范围的第一个 Bates 编号\nENDATTACH　EDC0000015　附件范围的最后一个 Bates 编号\nCUSTODIAN　Smith, John（约翰·史密斯）　电子邮件：电子邮件所在的邮箱\n原生文件：文件来源的个人或部门名称\nFROM　John Smith（约翰·史密斯）　电子邮件：发件人\n原生文件：文件作者\n多个条目之间应以分号分隔。\nTO　Coffman, Janice（贾尼斯·科夫曼）; LeeW　收件人\n[mailto:LeeW@MSN.com]　多个条目之间应以分号分隔。\nCC　Frank Thompson（弗兰克·汤普森） [mailto:　抄送收件人\nfrank_Thompson@cdt.com]　多个条目之间应以分号分隔。\nBCC　John Cain（约翰·凯恩）　密送收件人\n多个条目之间应以分号分隔。\nSUBJECT　Board Meeting Minutes　电子邮件：电子邮件主题行\n原生文件：文件标题（如有）\nFILE_NAME　BoardMeetingMinutes.docx　原生文件：原始原生文件的名称，包括扩展名\nDATE_SENT　10/12/2010　电子邮件：电子邮件发送日期\n原生文件：（空）\nTIME_SENT/\nTIME_ZONE　07:05 PM GMT　电子邮件：电子邮件发送时间/电子邮件标准化所使用的时区\nTIME_ZONE　GMT　在转换期间电子邮件被标准化所使用的时区。\nLINK　EDC0000001.msg　电子邮件或原生文件文件的超链接\n链接文件必须以 FIRSTBATES 编号命名。\nFILE_EXTEN　MSG　表示电子邮件或原生文件的文件类型扩展名\nAUTHOR　John Smith　电子邮件：（空）\n原生文件：文件作者\nDATE_CREATED　10/10/2010　电子邮件：（空）\n原生文件：文件创建日期\nCase 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 629 of 1063\n\nTIME_CREATED　10:25 AM　电子邮件：（空）\n原生文件：文件创建时间\n该数据必须为独立字段，且不得与 DATE_CREATED 字段合并。\nDATE_MOD　10/12/2010　电子邮件：（空）\n原生文件：文件最后修改日期\nTIME_MOD　07:00 PM　电子邮件：（空）\n原生文件：文件最后修改时间\n该数据必须为独立字段，且不得与 DATE_MOD 字段合并。\nDATE_ACCESSD　10/12/2010　电子邮件：（空）\n原生文件：文件最后访问日期\nTIME_ACCESSD　07:00 PM　电子邮件：（空）\n原生文件：文件最后访问时间\n该数据必须为独立字段，且不得与 DATE_ACCESSD 字段合并。\nFILE_SIZE　5,952　原生文件文件/电子邮件的大小，以 KB 计\nPGCOUNT　1　原生文件文件/电子邮件的页数\nPATH　电子邮件：（空）\nAgenda.doc　原生文件：原生文件文件的存储路径，包括原始文件名。\nINTFILEPATH　Personal Folders\\Deleted　电子邮件：电子邮件的原始位置，包括原始文件名。\nItems\\Board Meeting\nMinutes.msg　原生文件：（空）\nINTMSGID　<000805c2c71b\\$75977050\\$　电子邮件：唯一消息 ID；原生文件：（空）\ncb8306d1@MSN>\nMD5HASH　d131dd02c5e6eec4693d9a0　文件的 MD5 哈希值。\n698aff95c\n2fcab58712467eab4004583e\nb8fb7f89\nOCRPATH　TEXT/001/EDC0000001.txt　原生文件提取文本的路径\n\n3. 每项请求独立运作并应独立解释，除非另有说明，任何一项请求均不限制任何其他请求的范围。\n\n4. 所有文件均应按其在正常业务过程中保存的方式提交，或应整理并标注，以对应这些请求中的类别。\n\n5. 本文所载每项请求均延及所有文件：(a) 由贵方占有、保管或控制的文件；或 (b) 由代表贵方行事的任何人占有、保管或控制的文件，\nCase 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 630 of 1063\n\n包括贵方律师或其他代表及顾问。每份文件均应完整提交。\n\n6. 如要求贵方提交一份已不再由贵方占有、保管或控制的文件，则贵方的答复必须：(a) 详细说明该文件的性质及其内容；(b) 确认编制或撰写该文件的人，以及（如适用）该文件被发送给的人；(c) 确认该文件编制或创建的日期；(d) 说明该文件是否：(i) 遗失或丢失，(ii) 已被销毁，(iii) 已自愿或非自愿地转移给他人，或 (iv) 已以其他方式处置；(e) 说明该处置的理由，以及围绕该处置的事实和情形；(f) 确认授权该处置的人；(g) 确认该处置的日期或大致日期；(h) 说明该文件最近一次由贵方占有、保管或控制的时间；以及 (i) 确认现时占有、保管或控制该文件的人（如有）。\n\n7. 如要求贵方提交一份已被销毁的文件，则除前述指示所要求的信息外，贵方的答复还必须说明：(a) 销毁该文件的理由；(b) 销毁该文件的人的身份；以及 (c) 指示销毁该文件的人的身份。\n\n8. 如贵方主张所要求的某一文件享有特权或律师工作成果保护，则贵方的答复必须：(a)说明：(i)对该文件作出足以支持贵方关于该文件享有特权之主张的描述，(ii)该文件的标题，(iii)该文件的日期，(iv)该文件的作者，(v)该文件的收件人，(vi)收到或阅览该文件原件或任何草稿、副本或复制件的每一人员的身份，(vii)该文件本身，或该文件中包含或提及的任何信息，是否处于任何其他人员的占有、保管或控制之中；如是，该等人员的身份，\n\n案件 22-50073　文书 1592　提交日期 03/24/23　录入日期 03/24/23 10:57:37　第 631 页，共 1063 页\n\n以及说明该等信息如何进入其占有之中的陈述，(viii)据以扣留该文件的特权主张，以及 (ix)贵方将据以支持该等特权主张的所有情形；及 (b)依照 D. Conn. L. Civ. R. 26(e)，就基于特权主张而被扣留的每一文件，制作一份包含本指示第 (a) 部分所要求全部信息的特权日志。对于文件请求中未就其提出特权或工作成果主张的任何部分，应完整提供响应性文件。\n\n9. 如一份原本具有响应性的文件的一部分包含受特权主张保护的信息，则仅应依照上述指示从该文件中删除或遮蔽受该特权主张保护的部分，其余部分应予提供。\n\n10. 该等请求具有持续性。兹指示贵方：(a)一旦知悉先前答复不完整或不正确，应立即补充或更正其后发现不完整或不正确的任何答复；及 (b)提供根据下文所要求的任何补充文件。\n\n11. 如某文件使用英语以外的语言，贵方应提供该文件。如某文件使用英语以外的语言，且存在英文译本，贵方应同时提供两份文件。\n\n12. 对实体的所有提述均包括其全部关联方。\n\n13. 对个人姓名的所有提述均包括所有其他姓名、别名或昵称。\n\n案件 22-50073　文书 1592　提交日期 03/24/23　录入日期 03/24/23 10:57:37　第 632 页，共 1063 页\n\n14. 除非另有明确说明，文件请求所涵盖的期间为自 February 5, 2012 起至文件请求答复到期之日止。\n\nII. 解释规则\n\n15. (a)任何单数名词的使用应解释为包括复数，反之亦然；及 (b)任何时态动词的使用应解释为在所有其他时态中使用该动词。\n\n16. (a)“and”和“or”应视需要解释为连词或析取词，以将原本可能被解释为不在任何请求范围内的所有答复纳入该请求范围；及 (b)“each”和“any”应视为包括并涵盖“every”和“all”二词。\n\nIII. 定义\n\n经 D. Conn. Bankr. L.R. 2004-1(a) 纳入的 D. Conn. L. Civ. R. 26(c) 所提供的定义及 D. Conn. L. Civ. R. 26(d) 所提供的解释规则，适用于文件请求。此外，本文件请求中使用的下列术语具有下列含义：\n\n1. “You”或“Your”或“Yourself”系指 U.S. Bank National Association（美国合众银行全国协会）。\n\n2. “Debtor”系指 Ho Wan Kwok（郭文贵）（亦称 Miles Kwok（郭文贵）、Miles Guo（郭文贵）、Guo Wengui（郭文贵）、Guo Haoyun（郭浩云）、郭文贵或任何其他别名），连同其雇员、代理人、律师、顾问或代表其行事的任何人。\n\n案件 22-50073　文书 1592　提交日期 03/24/23　录入日期 03/24/23 10:57:37　第 633 页，共 1063 页\n\n3. “Debtor's Son”系指 Qiang Guo（郭强）（亦称 Mileson Kwok（郭强）、郭强或任何其他别名），连同其雇员、代理人、律师、顾问或代表其行事的任何人。\n\n4. “Debtor's Daughter”系指 Mei Guo（郭美）（亦称 Mei Gui（郭美）、郭美或任何其他别名），连同其雇员、代理人、律师、顾问或代表其行事的任何人。\n\n5. “Debtor's Purported Wife”系指 Hing Chi Ngok（岳庆芝）（亦称 Hing Chi Ng（岳庆芝）、Yue Qingzhi（岳庆芝）、岳庆芝或任何其他别名），连同其雇员、代理人、律师、顾问或代表其行事的任何人。\n\n6. “Debtor's Family”系指单独及共同而言的债务人、债务人之子、债务人之女及债务人所谓的妻子，以及与债务人有任何其他亲属关系的人。\n\n7. “2004 Discovery Targets”系指单独及共同而言的债务人、债务人家属、ACA Capital Group Limited、Himalaya International Financial Group Ltd.、Himalaya International Clearing Ltd.、Himalaya International Payments Ltd.、Himalaya International Reserves Ltd.、Jesse Brown、William Je、William Je、Eastern Profit Corporation Limited、HK International Funds Investments (USA) Limited LLC、Bravo Luck Limited、Golden Spring (New York) Ltd.、Lamp Capital LLC、Greenwich Land LLC、Qu Guo Jiao、Daniel Thomas Podhaskie、Yvette Wang（亦称 Yanping Wang，亦称 Yan Ping Wang）、Ace Decade Holdings Limited、Dawn State Limited、Rule of Law Society IV Inc.、Rule of Law Foundation III, Inc.、Rule of Law Foundation IV, Inc.、Rule of Law Fund、Rule of Law Society、GTV Media Group, Inc.、Voice of Guo Media, Inc.、Saraca Media Group Inc.、Genever Holdings Corporation、Genever Holdings LLC、Gnews Media Group Inc.、G Fashion LLC、Gmusic LLC、Gnews LLC、Geducation、GFNY, Inc.、G-Club Investments Limited、G Club Operations LLC、G Club US Operations Inc.、G Club US Operations LLC、G Live, LLC、Gbroadcast, LLC、Gposts LLC、HCHK Property\n\n案件 22-50073　文书 1592　提交日期 03/24/23　录入日期 03/24/23 10:57:37　第 634 页，共 1063 页\n\nManagement, Inc.、HCHK Technologies, Inc.、FMV Ltd./Freedom Media Venture Ltd.、Roscalitar 2、Himalaya New World Inc.、US Himalaya Capital Inc.、Hudson Diamond Holding, Inc.、Hudson Diamond Holding LLC、Hudson Diamond NY LLC、Infinity Treasury Management Inc.、Lexington Property and Staffing, Inc.、AI Group Holdings Inc.、Hamilton Capital Holdings Inc.、Booming Sail New York LLC、Himalaya Ventures LLC、Himalaya Ventures LLC、Himalaya Investment LLC、New York MOS Himalaya LLC、MOS Himalaya LLC、Crane Advisory Group、Maywind Trading LLC、Gettr USA, Inc.、Han Chunguang、Bingshang Jiao、Karin Maistrello、Mary Jiang、Jiaming Liu 及 Wencong Wang。\n\n8. “Including”或其任何变体意为“包括但不限于”。\n\n9. “And”和“or”意为“和/或”，并应解释为既可连用亦可析取，以最大化其范围。\n\n10. “Any”、“all”及“each”意为“每一及所有”。\n\n11. “Each”及“every”意为“每一及所有”。\n\n12. “Third Party”系指贵方以外的人员或实体。\n\n13. “Transfer”具有《破产法》section 101(54)赋予其的含义。\n\n14. “Document”系指属于 Fed. R. Civ. P. 34 范围内的任何信息或物品，并包括但不限于处于或曾处于贵方占有、保管或控制之中的各种、各类、各种性质或描述的每一书面、记录或图形材料，包括电子邮件的所有印刷及电子副本、以电子形式保存的计算机文件、通信函件、备忘录、磁带、速记或手写笔记、任何种类的书面表格、图表、蓝图、图纸、草图、曲线图、计划、文章、规格、日记、信函、\n\n案件 22-50073　文书 1592　提交日期 03/24/23　录入日期 03/24/23 10:57:37　第 635 页，共 1063 页\n\n电报、照片、会议记录、合同、协议、调查资料、计算机打印件、任何种类的数据汇编、电传、电传传真、电子邮件、短信、即时消息、语音消息、发票、订购单、支票、汇票、对账单、贷项通知单、报告、头寸报告、摘要、索引、账簿、分类账、笔记本、清单、透明片、录音、目录、广告、宣传材料、胶片、录像带、录音带、CD、计算机磁盘、宣传册、小册子、穿孔卡、工时单、推文、社交媒体帖子或任何其他种类的书面或记录材料，以及其所有元数据，无论其以何种方式储存（无论为有形或电子形式）、记录、制作或复制，亦包括但不限于上述任何材料的草稿或副本，如其中含有原始文件中不存在的任何种类笔记、评论或标记，或在其他方面与原始文件不相同。\n\n15. “Person(s)”系指个人、公司、独资企业、合伙企业、协会或任何其他实体。“Person”亦包括任何代理人、代表或专家，包括但不限于律师或财务顾问。\n\n16. “Entity”系指任何自然人、公司、合伙企业、子公司、独资企业、商号、董事会、合资企业、协会、机构、主管机关、委员会或其他商业实体或法人，以及任何关联方、代理人、母公司，包括但不限于律师、财务顾问或任何其他代表。\n\n17. “Regarding”意为涉及、描述、包含、提及、与之有关、支持、有利于、反对、加强、削弱、位于其中、结合考虑、与之相关、证明、表明、报告、记录、暗指、回应、与之相连、评论、就其而言、关于、与之相关、讨论、显示、描述、反映、分析、构成及为。\n\n案件 22-50073　文书 1592　提交日期 03/24/23　录入日期 03/24/23 10:57:37　第 636 页，共 1063 页\n\n18. 就任何特定主题而言，“Relating to”、“relate(s) to”或“related to”意为，包括但不限于，构成、包含、涉及、含有、体现、反映、识别、陈述、直接或间接提及，或以任何方式与所识别的特定主题有关的任何文件。\n\n19. “Communication(s)”系指以最广泛的可能意义且不受限制地传递任何信息或知识（以事实、观点、询问或其他形式）。Communication(s)还指所有谈话、协议、询问或答复，无论是当面、通过电话、书面方式还是通过电子传输设备，并包括但不限于所有通信函件、电子邮件、录音、传送单、备忘录、电话通信、语音消息、电报、电传传真、影印传真、电传、即时消息、聊天、短信、发布至留言板或群聊的信息、社交媒体帖子、推文、上传至任何视频平台的视频、电话笔记，或在内部或与第三方传送的笔记。\n\n20. “Asset(s)”系指受占有、保管或控制的任何具有经济价值的物品。资产包括所有不动产和动产，包括但不限于房地产、土地、房屋、公寓、共管公寓、汽车、游艇、船只、飞机、喷气式飞机、直升机、现金、银行账户、加密货币、证券、应收账款、存货及其他有形和无形财产。\n\nIV. 应提供的文件\n\n1. 与由任何 2004 Discovery Targets 持有、控制、代为持有或以其他方式与其相关的任何账户有关的所有文件，包括任何及所有账户对账单、授权书、委托书、信托文件、指示或表格、已注销支票副本、通信函件，以及电汇及相关通信函件和指示。\n\n案件 22-50073　文书 1592　提交日期 03/24/23　录入日期 03/24/23 10:57:37　第 637 页，共 1063 页\n\n2. 与属于、由……持有、由……控制、代表……持有或以其他方式与任何2004证据开示对象有关的任何资金、证券、财产或资产相关的所有文件，包括任何及所有账户对账单、授权书、委托书、信托文件、指示或表格、已注销支票副本、通信函件，以及电汇和相关通信函件及指示。\n\n3. 与同任何2004证据开示对象进行的任何商业、贸易或金融交易有关的所有文件，包括但不限于任何贷款、信贷额度、寄托、存款、互换、证券交易、抵押贷款或ISDA，以及任何及所有账户对账单、授权书、委托书、信托文件、指示或表格、已注销支票副本、通信函件，以及电汇和相关通信函件及指示。\n\n4. 与2004证据开示对象有关的任何电汇活动相关的所有文件，无论是否存在任何账户，包括但不限于所有电汇收据、账号、余额、授权、与转账当事人有关的身份识别信息、通信函件、指示或其他记录。\n\n5. 与您和2004证据开示对象之间的任何函件往来及通信相关的所有文件。\n\n6. 与任何2004证据开示对象的任何账户有关的所有文件，涉及账户开立、账户获授权使用人及账户维护。\n\n7. 与任何2004证据开示对象有关的任何反洗钱、了解你的客户或其他合规活动相关的所有文件，包括但不限于任何2004证据开示对象提供的任何信息，或您获悉的任何信息。\n\n8. 与任何国家的任何监管机构进行的、与任何2004证据开示对象有关的任何通信相关的所有文件，包括但不限于英格兰银行（Bank of England）、美国联邦储备系统（United States Federal Reserve）、证券交易委员会（S.E.C.）、商品期货交易委员会（CFTC）、金融业监管局（FINRA）、中国证券监督管理委员会（China Securities Regulatory Commission）、中国人民银行（People's Bank of China）、香港证券及期货事务监察委员会（Hong Kong Securities and Futures Commission）以及香港金融管理局（Hong Kong Monetary Authority）。\n\n附件 C-35\n\nB2540（表格2540——规则2004审查传票）（12/15）案件 22-50073 文件 1592 于 03/24/23 提交 于 03/24/23 10:57:37 登记 第 640 页，共\n\nUNITED STATES BANKRUPTCY COURT（美国破产法院）\n\nDistrict of Connecticut（康涅狄格州地区）\n\n关于 HO WAN KWOK（郭文贵）等人，\n\n1 案件编号 22-50073 (JAM) 债务人 第11章\n\n（合并管理）\n\n规则2004审查传票\n\n致：Macaron Limited（马卡龙有限公司）\n\n（传票所指向之人的姓名）\n\n证言：现命令您于下文规定的时间、日期和地点出席，并根据《联邦破产程序规则》第2004条接受审查并作证。随附授权该审查的法院命令副本。\n\n地点　日期及时间\n\nPaul Hastings LLP（普衡律师事务所）\n200 Park Avenue　[TBD]\nNew York, New York 10166\n\n审查将以以下方式记录：法庭记录员/速记员\n\n提交：您或您的代表还必须携带下列文件、电子存储信息或物品参加审查，并必须允许对该材料进行查验、复制、测试或取样：\n\n见随附的文件提交请求。\n\n《联邦民事诉讼规则》第45条的下列规定，根据《联邦破产程序规则》第9016条适用于破产案件，现随附于后——有关履行地点的第45(c)条；有关对作为传票对象之人的保护的第45(d)条；以及有关您对本传票作出回应的义务及未作出回应的潜在后果的第45(e)条和第45(g)条。\n\n日期：March , 2023\n\n法院书记官\n\n或\n\n书记官或副书记官签名　律师签名\n\n签发或请求本传票的代表第11章受托人 Luc A. Despins（卢克·A·德斯平斯）的律师姓名、地址、电子邮件地址和电话号码如下：\n\nDouglas S. Skalka, Esq.（道格拉斯·S·斯卡尔卡，律师）；Neubert, Pepe & Monteith, P.C.（纽伯特、佩佩及蒙蒂思律师事务所）；195 Church Street, New Haven, Connecticut 06510 dskalka@npmlaw.com；(203) 821-2000\n\n致签发或请求本传票之人的通知\n\n如本传票要求在审判前提交文件、电子存储信息或有形物品，或查验场所，则必须在向本传票所指向之人送达之前，向每一方当事人送达通知及本传票副本。《联邦民事诉讼规则》第45(a)(4)条。\n\n软件版权 (c) 1996-2022 Best Case, LLC - www.bestcase.com Best Case Bankruptcy 1 本第11章案件中的债务人为 Ho Wan Kwok（郭文贵，亦称 Guo Wengui、Miles Guo 和 Miles Kwok，以及众多其他别名）（税务识别号后四位：9595）、Genever Holdings LLC（税务识别号后四位：8202）及 Genever Holdings Corporation。受托人、Genever Holdings LLC 和 Genever Holdings Corporation 的邮寄地址为 Paul Hastings LLP（普衡律师事务所），200 Park Avenue, New York, NY 10166，转交 Luc A. Despins，作为 Ho Wan Kwok 遗产的受托人（仅为通知和通信之目的）。\n\n送达证明\n\n（除非《联邦民事诉讼规则》第45条要求，否则本节不应向法院提交。）\n\n我于（日期）收到向（个人姓名及职务，如有）送达的本传票。\n\n我通过如下方式向具名人士交付副本，以送达本传票：\n\n于（日期）；或\n\n我未执行而退还本传票，原因如下：\n\n除非本传票系代表美国或其官员或代理人签发，我还已向证人支付一日出席费用及法律允许的里程费用，金额为 \\$ 。\n\n我的差旅费用为 \\$，服务费用为 \\$，合计为 \\$ 。\n\n我在伪证处罚的约束下声明，该等信息真实且正确。\n\n日期：\n\n送达人员签名\n\n印刷体姓名及职务\n\n送达人员地址\n\n关于尝试送达等的补充信息：\n\n《联邦民事诉讼规则》第45(c)、(d)、(e)及(g)条（自12/1/13生效）（根据《联邦破产程序规则》第9016条适用于破产案件）\n\n(c) 履行地点。\n\n(1) 审判、听证或证言记录。传票仅可按如下方式命令某人出席审判、听证或证言记录：\n\n(A) 在该人居住、受雇或定期亲自办理业务地点100英里以内；或\n\n(B) 在该人居住、受雇或定期亲自办理业务所在的州内，如该人\n\n(i) 为当事人或当事人的高级职员；或\n\n(ii) 被命令出席审判且不会产生重大费用。\n\n(2) 其他证据开示。传票可命令：\n\n(A) 在该人居住、受雇或定期亲自办理业务地点100英里以内的地点提交文件、电子存储信息或物品；以及\n\n(B) 在应受查验的场所进行场所查验。\n\n(d) 对作为传票对象之人的保护；执行。\n\n(1) 避免不当负担或费用；制裁。负责签发和送达传票的一方当事人或律师必须采取合理措施，避免向作为传票对象之人施加不当负担或费用。要求履行的地区法院必须执行该义务，并对未遵守者——当事人或律师——施加适当制裁，该制裁可包括损失的收入和合理的律师费。\n\n(2) 命令提交材料或允许查验。\n\n(A) 无须出席。被命令提交文件、电子存储信息或有形物品，或允许查验场所之人，无须亲自出席提交或查验地点，除非其亦被命令出席证言记录、听证或审判。\n\n(B) 异议。被命令提交文件或有形物品，或允许查验之人，可以向传票指定的当事人或律师送达书面异议，反对查验、复制、测试或取样任何或全部材料，或反对查验场所——或反对以所要求的一种或多种形式提交电子存储信息。异议必须在规定履行时间或传票送达后14日中较早的时间之前送达。如提出异议，适用下列规则：\n\n(i) 送达方当事人可随时在通知被命令之人后，向要求履行的地区法院提出动议，请求作出强制提交或查验的命令。\n\n(ii) 仅可依命令指示要求实施该等行为，且该命令必须保护并非当事人或当事人高级职员之人免于承担因履行产生的重大费用。\n\n(3) 撤销或修改传票。\n\n(A) 必须撤销或修改的情形。经及时动议，要求履行的地区法院必须撤销或修改具有下列情形的传票：\n\n(i) 未给予合理履行时间；\n\n(ii) 要求某人在第45(c)条规定的地域限制之外履行；\n\n(iii) 要求披露享有特权或受其他保护的事项，且不适用任何例外或豁免；或\n\n(iv) 使某人承受不当负担。\n\n(B) 可以撤销或修改的情形。为保护作为传票对象或受传票影响之人，要求履行的地区法院可以根据动议，撤销或修改要求下列事项的传票：\n\n(i) 披露商业秘密或其他保密研究、开发或商业信息；或\n\n(ii) 披露未经聘任专家的意见或信息，该等意见或信息并非描述争议中的具体事件，且源自未经任何一方当事人请求的该专家研究。\n\n(C) 以规定条件作为替代。在第45(d)(3)(B)条所述情形下，如送达方当事人：\n\n(i) 证明对该证言或材料具有重大需要，且无法在不造成不当困难的情况下通过其他方式满足该需要；并且\n\n(ii) 确保被传唤之人将获得合理补偿，\n\n法院可不撤销或修改传票，而命令在规定条件下出席或提交。\n\n(e) 回应传票的义务。\n\n(1) 提交文件或电子存储信息。下列程序适用于提交文件或电子存储信息：\n\n(A) 文件。回应要求提交文件的传票之人，必须按照文件在正常业务过程中保存的方式提交文件，或必须将其整理和标注，以对应请求中的类别。\n\n(B) 未指定电子存储信息提交形式。如传票未指定电子存储信息的提交形式，回应之人必须以其通常保存的一种或多种形式，或以合理可用的一种或多种形式提交。\n\n(C) 电子存储信息仅以一种形式提交。回应之人无须以一种以上形式提交相同的电子存储信息。\n\n(D) 无法访问的电子存储信息。回应之人无须提供来自其认定因不当负担或费用而无法合理访问的信息来源中的电子存储信息作为证据开示。在请求强制证据开示或保护令的动议中，回应之人必须证明该信息因不当负担或费用而无法合理访问。如作出该证明，法院在考虑第26(b)(2)(C)条的限制后，如请求方当事人证明有充分理由，仍可命令对该等来源进行证据开示。法院可为该证据开示规定条件。\n\n(2) 主张特权或保护。\n\n(A) 被扣留的信息。以该信息享有特权或受审判准备材料保护为由扣留传票所要求信息之人必须：(i) 明确提出该主张；以及\n\n(ii) 以一种在不披露本身享有特权或受保护信息的情况下，仍能使各方评估该项主张的方式，说明被扣留文件、通信或有形物品的性质。\n\n(B) 已提供的信息。若为响应传票而提供的信息受到特权主张或作为审判准备材料受保护的主张约束，提出该主张的人可以将该主张及其依据通知收到该信息的任何一方。收到通知后，一方必须立即返还、隔离或销毁所指定的信息及其所持有的任何副本；在该主张得到解决之前，不得使用或披露该信息；如该方在收到通知前已披露该信息，必须采取合理措施取回该信息；并可立即将该信息密封提交至要求遵从的地区所属法院，以裁定该主张。提供该信息的人必须在该主张得到解决前保存该信息。\n\n(g) 蔑视法庭。要求遵从的地区所属法院，以及在动议移送后签发传票的法院，均可对已被送达但无充分理由未遵从传票或与其有关命令的人处以蔑视法庭。\n\n有关获取传票材料，参见 Fed.R.Civ.P.45(a) 委员会说明（2013）\n\n……\n\n文件出示请求\nI. 指示\n\n1. 除非另有说明，下列文件请求（以下简称“请求”，每一项称为“一项请求”）必须分别且具体地作出回应。除非基于善意提出异议，否则必须完整答复每项请求；如提出异议，应按如下规定详细说明贵方异议的理由。如异议仅涉及某项请求的一部分，或其中包含的某个词语、短语或条款，贵方仅须对该部分说明异议，并对其余请求作出回应。\n\n2. 电子存储信息必须依照下列指示提供：\n\na. 图像。黑白图像必须为 300 DPI Group IV 单页 TIFF 文件。彩色图像必须以 JPEG 格式提供。文件名不得含有嵌入空格或特殊字符（包括逗号）。文件夹名称不得含有嵌入空格或特殊字符（包括逗号）。所有 TIFF 图像文件必须具有唯一文件名，即 Bates 编号。每张图像的右下角必须标注连续的 Bates 编号。每个文件夹中的 TIFF 文件数量不应超过 1000 个。Excel 电子表格应有一张以该文件 Bates 编号命名的占位图像。\n\nb. 图像加载文件\n\na. Concordance® 数据文件。数据文件（.DAT）包含将被加载至 Concordance® 数据库的全部字段信息。.DAT 文件的第一行必须为标明字段名称的标题行。.DAT 文件必须使用下列 Concordance® 默认分隔符：逗号 ASCII 字符（020）；引号 þ ASCII 字符（254）。日期字段应按下列格式提供：mm/dd/yyyy。日期和时间字段必须为两个独立字段。如文件包括已成像的电子邮件及附件，则必须包括附件字段，以保留电子邮件与其附件之间的父/子关系。必须包括 OCRPATH 字段，以提供已提取文本文件在所提供存储介质上的文件路径及名称。文本文件必须以 FIRSTBATES 命名。不得将文本纳入 .DAT 文件。对于含有原生文件的文件，必须包括 LINK 字段，以提供原生文件的文件路径及名称。原生文件必须以 FIRSTBATES 命名。\n\nb. Concordance Image® 或 Opticon 交叉引用文件。图像交叉引用文件（.LOG 或 .OPT）将图像链接至数据库记录。该文件应为以逗号分隔的文件，每行由七个字段组成，且数据库中的每张图像均应在交叉引用文件中有一行，格式如下：ImageID,VolumeLabel,ImageFilePath,DocumentBreak,FolderBreak,Box Break,PageCoun。\n\nc. 文件文本。文本必须作为独立文本文件提供，而非作为 .DAT 文件中的字段提供。文本文件的完整路径（OCRPATH）应列入 .DAT 文件。建议提供文件级 ANSI 文本文件，并按 FIRSTBATES/Image Key 命名。提取的文本文件必须置于独立文件夹中，每个文件夹中的文本文件数量不应超过 1,000 个。文件夹名称中不得含有特殊字符（包括逗号）。必须按文件级别提供文本文件。\n\nd. 特定文件类型的原生文件提供。为完整理解其内容和含义而合理需要以原生格式查看的文件类型，必须以原生格式提供。这些文件包括但不限于电子表格、类似电子表格的文件（Microsoft Excel、逗号分隔值、制表符分隔值等）、Microsoft PowerPoint 或其他特殊演示文件、数据库文件以及音频/视频文件。应提供一张标有 Bates 编号的分隔页图像，以表明存在原生文件，并在 .dat 文件中将原生文件路径作为字段列入。所提供的原生文件应以与该文件分隔页相对应的 Bates 编号命名。原生文件应归入按递增方式命名的“NATIVE”目录，并与图像目录分开。\n\ne. 去重。对于存在完全重复件的每份电子文件，仅提供一份副本。对于电子邮件，应根据由 BCC、Body、CC、From、IntMsgID、To 和 Attach 属性生成的 MD5 哈希值合并重复件。对于电子邮件附件及独立电子文件，应根据整个文件的 MD5 哈希值合并重复件。\n\nf. 元数据。应以符合 Concordance 要求的加载文件（.dat）形式，为每份文件提供提取的元数据。.DAT 文件的第一行必须为标明字段名称的标题行。.DAT 文件必须使用下列 Concordance 默认分隔符：逗号 , ASCII 字符（020）；引号 þ ASCII 字符（254）。\n\n日期字段应按下列格式提供：mm/dd/yyyy。日期和时间字段必须为两个独立字段。下列为必需元数据：\nCase 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 645 of 1063\n\n字段名称　示例数据　说明\n\nFIRSTBATES　EDC0000001　原生文件文件/电子邮件的首个 Bates 编号\nLASTBATES　EDC0000001　原生文件文件/电子邮件的最后一个 Bates 编号\nLASTBATES 字段应针对单页文件填写\nATTACHRANGE　EDC0000001\n-　父文件首页的 Bates 编号至最后一个\nEDC0000015　附件“子”文件最后一页的 Bates 编号\nBEGATTACH　EDC0000001　附件范围的首个 Bates 编号\nENDATTACH　EDC0000015　附件范围的最后一个 Bates 编号\nCUSTODIAN　Smith, John　电子邮件：该电子邮件所在的邮箱\n原生文件：该文件源自其文件的个人或部门名称\nFROM　John Smith　电子邮件：发件人\n原生文件：文件作者\n多个条目之间应使用分号分隔\nTO　Coffman, Janice; LeeW　收件人\n[mailto:LeeW@MSN.com]　多个条目之间应使用分号分隔\nCC　Frank Thompson [mailto:　抄送收件人\nfrank_Thompson@cdt.com]　多个条目之间应使用分号分隔\nBCC　John Cain　密送收件人\n多个条目之间应使用分号分隔\nSUBJECT　Board Meeting Minutes　电子邮件：电子邮件主题行；原生文件：文件标题（如有）\nFILE_NAME　BoardMeetingMinutes.docx　原生文件：原始原生文件名称，包括扩展名\nDATE_SENT　10/12/2010　电子邮件：电子邮件发送日期\n原生文件：（空）\nTIME_SENT/\nTIME_ZONE　07:05 PM GMT　电子邮件：电子邮件发送时间/电子邮件标准化所采用时区中的时间\nTIME_ZONE　GMT　在转换过程中电子邮件被标准化所采用的时区。\nLINK　EDC0000001.msg　电子邮件或原生文件文件的超链接\n链接文件必须按 FIRSTBATES 编号命名\nFILE_EXTEN　MSG　表示电子邮件或原生文件的文件类型扩展名\nAUTHOR　John Smith　电子邮件：（空）\n原生文件：文件作者\nDATE_CREATED　10/10/2010　电子邮件：（空）\n原生文件：文件创建日期\nCase 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 646 of 1063\n\nTIME_CREATED　10:25 AM　电子邮件：（空）\n\n原生文件：文件创建时间\n该数据必须为独立字段，不得与 DATE_CREATED 字段合并\nDATE_MOD　10/12/2010　电子邮件：（空）\n原生文件：文件最后修改日期\nTIME_MOD　07:00 PM　电子邮件：（空）\n原生文件：文件最后修改时间\n该数据必须为独立字段，不得与 DATE_MOD 字段合并\nDATE_ACCESSD　10/12/2010　电子邮件：（空）\n原生文件：最后访问文件的日期\nTIME_ACCESSD　07:00 PM　电子邮件：（空）\n原生文件：最后访问文件的时间\n该数据必须为独立字段，不得与 DATE_ACCESSD 字段合并\nFILE_SIZE　5,952　原生文件文件/电子邮件的大小，以 KB 计\nPGCOUNT　1　原生文件文件/电子邮件的页数\nPATH　电子邮件：（空）\nAgenda.doc　原生文件：存储原生文件文件的路径，包括原始文件名。\nINTFILEPATH　Personal Folders\\Deleted　电子邮件：电子邮件的原始位置，包括\nItems\\Board Meeting　原始文件名。\nMinutes.msg　原生文件：（空）\nINTMSGID　<000805c2c71b\\$75977050\\$　电子邮件：唯一消息 ID；原生文件：（空）\ncb8306d1@MSN>\nMD5HASH　d131dd02c5e6eec4693d9a0　文件的 MD5 哈希值。\n698aff95c\n2fcab58712467eab4004583e\nb8fb7f89\nOCRPATH　TEXT/001/EDC0000001.txt　原生文件提取文本的路径\n\n3. 每项请求均独立运作并应独立解释，且除非另有说明，任何一项请求均不限制其他任何请求的范围。\n\n4. 所有文件应按其在通常业务过程中保存的方式提供，或者应予以整理和标记，以与本请求中的类别相对应。\n\n5. 本文所载每项请求均延及以下所有文件：（a）由贵方占有、保管或控制的文件；或（b）由任何代表贵方行事的人占有、保管或控制的文件，\nCase 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 647 of 1063\n\n包括贵方的律师或其他代表及顾问。每份文件均应完整提供。\n\n6. 如要求贵方提供一份已不再由贵方占有、保管或控制的文件，则贵方的回应必须：（a）详细说明该文件的性质及其内容；（b）确定编制或撰写该文件的人（以及，如适用，该文件被发送给的人）；（c）确定该文件编制或创建的日期；（d）说明该文件是否（i）遗失或丢失，（ii）已被销毁，（iii）已自愿或非自愿地转移给他人，或（iv）以其他方式被处置；（e）说明该等处置的理由，以及围绕该等处置的事实和情况；（f）确定授权该等处置的人员；（g）确定该等处置的日期或大致日期；（h）说明该文件最近一次由贵方占有、保管或控制的时间；以及（i）确定目前占有、保管或控制该文件的人员（如有）。\n\n7. 如要求贵方提供一份已被销毁的文件，则除前述指示所要求的信息外，贵方的回应还必须说明：（a）销毁该文件的理由；（b）销毁该文件的人员身份；以及（c）指示销毁该文件的人员身份。\n\n8. 如贵方主张所请求的文件受特权保护或属于律师工作成果，则贵方的答复必须：(a) 说明：(i) 足以支持贵方关于该文件受特权保护之主张的文件描述；(ii) 文件标题；(iii) 文件日期；(iv) 文件作者；(v) 文件收件人；(vi) 收到或阅览该文件原件或任何草稿、副本或复制件的每一人士的身份；(vii) 该文件本身或其中载有或提及的任何信息是否由任何其他人士占有、保管或控制，以及如是，该等人士的身份，\n\n案件 22-50073 文件 1592 于 03/24/23 提交 于 03/24/23 10:57:37 登记 第 648 页，共 1063 页\n\n以及说明该等信息如何进入其占有之中；(viii) 据以扣留该文件的特权主张；以及 (ix) 贵方将据以支持该等特权主张的所有情形；并且 (b) 应根据 D. Conn. L. Civ. R. 26(e)，就每一份基于特权主张而被扣留的文件，制作一份载有本指示第 (a) 部分所要求全部信息的特权日志。\n\n9. 如一份原本应予提供的文件的一部分含有受特权主张约束的信息，则仅应按照上述指示从该文件中删除或遮盖受特权主张约束的该部分，其余部分应予提供。\n\n10. 该等请求具有持续性。特此指示贵方：(a) 在获悉先前答复不完整或不正确后，立即补充或更正其后获悉为不完整或不正确的任何答复；以及 (b) 提供根据以下规定所要求的任何额外文件\n\n11. 如文件使用英语以外的语言，贵方应提供该文件。如文件使用英语以外的语言，且存在英文译本，贵方应同时提供两份文件。\n\n12. 对实体的所有提述包括其全部关联方。\n\n13. 对个人姓名的所有提述包括所有其他名称、别名或昵称。\n\n14. 除非另有明确说明，文件请求所涵盖的期间为自 February 5, 2012 起至文件请求答复到期之日止。\n\n案件 22-50073 文件 1592 于 03/24/23 提交 于 03/24/23 10:57:37 登记 第 649 页，共 1063 页\n\nII. 解释规则\n\n15. (a) 任何单数名词的使用应解释为包括复数，反之亦然；以及 (b) 任何时态的动词应解释为在所有其他时态下使用该动词。\n\n16. (a) “and”和“or”应视需要作连言或选言解释，以使原本可能被解释为超出任何请求范围的所有答复均纳入该请求范围内；以及 (b) “each”和“any”应被视为包括并涵盖“every”和“all”这两个词。\n\nIII. 定义\n\n由 D. Conn. L. Civ. R. 26(c) 提供的定义，以及由 D. Conn. L. Civ. R. 26(d) 提供并经 D. Conn. Bankr. L.R. 2004-1(a) 纳入的解释规则，适用于该等文件请求。此外，本文件请求中使用的下列术语具有下列含义：\n\n1. “You”或“Your”或“Yourself”系指并指向 Macaron Limited（马卡龙有限公司），连同其全部关联方、部门、机构、工具机构、处室、办事处、合伙人、高级职员、董事、代理人、律师、代表、雇员和/或任何代表其行事之人。\n\n2. “Debtor”系指 Ho Wan Kwok（郭文贵）（又名 Miles Kwok、Miles Guo、Guo Wengui、Guo Haoyun、郭文贵或任何其他别名），连同其雇员、代理人、律师、顾问或任何代表其行事之人。\n\n3. “Debtor's Son”系指 Qiang Guo（郭强）（又名 Mileson Kwok、郭强或任何其他别名），连同其雇员、代理人、律师、顾问或任何代表其行事之人。\n\n案件 22-50073 文件 1592 于 03/24/23 提交 于 03/24/23 10:57:37 登记 第 650 页，共 1063 页\n\n4. “Debtor's Daughter”系指 Mei Guo（郭美）（又名 Mei Gui、郭美或任何其他别名），连同其雇员、代理人、律师、顾问或任何代表其行事之人。\n\n5. “Debtor's Purported Wife”系指 Hing Chi Ngok（岳庆芝）（又名 Hing Chi Ng、Yue Qingzhi、岳庆芝或任何其他别名），连同其雇员、代理人、律师、顾问或任何代表其行事之人。\n\n6. “Debtor's Family”统称债务人、债务人之子、债务人之女及债务人所谓的妻子，以及与债务人有任何其他亲属关系者。\n\n7. “Associated Individuals”单独及统称所有以下个人：(1) 持有、控制、保管或对债务人或债务人家族所拥有、控制或享有的资产拥有裁量权者；或 (2) 曾为一个或多个关联实体的雇员、董事或以其他方式与其关联者，连同前述各方各自的雇员、代理人、律师、顾问或任何代表其行事之人。该等关联个人包括但不限于：Daniel Podhaskie、Jason Miller、Steve Bannon、Karin Maistrello、Melissa Francis、Anthony DiBattista、William Gertz、Arethusa Forsyth、Glenn Mellor、Jennifer Mercurio、Eduardo Eurnekian、Wencong Wang、Han Chunguang（又名 韩春光）、Qu Guojiao（又名 Qu Guo Jiao、屈国姣）、Guo Lijie（又名 郭丽杰）、Zhang Wei（又名 张伟*）、Lihong Wei Lafrenz（又名 Sara Wei、魏丽红）、Hao Haidong（又名 郝海东）、Ross Heinemeyer、Max Krasner、Kyle Bass、Melissa Mendez、Ya Li（又名 李娅）、Dinggang Wang（又名 王定刚）、An Hong（又名 安红）、Yvette Wang（又名 Yanping Wang、Yan Ping Wang、王雁平）、Fiona Yu、Je Kin Ming（又名 William Je、Yu Jianming、余建明）、Yaz Qingua，以及 Lao Jiang（又名 Jiang Yunfu、Jiang Yunfu Be、姜云浮）。\n\n案件 22-50073 文件 1592 于 03/24/23 提交 于 03/24/23 10:57:37 登记 第 651 页，共 1063 页\n\n8. “Associated Entities”单独及统称所有以下任何类型的组织或实体：(1) 曾由债务人或债务人家族拥有、控制或投资的组织或实体；或 (2) 直接或间接对债务人或债务人家族所拥有、控制或享有的任何资产享有权益的组织或实体，连同前述各方各自的雇员、代理人、律师、顾问或任何代表其行事之人。该等关联实体包括但不限于：7 Nod Hill LLC、AAGV Limited、ACA Investment Management Limited、ACA Capital Group Limited、Ace Decade Holdings Limited、AI Group Holdings Inc.、Alfa Global Ventures Limited、Alfonso Global Limited、Allied Capital Global Limited、Alpine Fiduciaries SA、Anton Development Limited、Assets Sino Limited、Auspicious Coast Limited、Beijing Pangu Investment Co.、Beijing Pangu Investment Co. Ltd.、Beijing Pangu Investment Inc.、Beijing Zenith Holdings Company Limited、Booming Sail New York LLC、Bravo Luck Limited、BSA Strategic Fund I、China Golden Spring (Hong Kong) Limited、Chuang Xin Limited、Crane Advisory Group LLC、Creative Apex Investments Limited、Crystal Breeze Investments Limited、Dawn State Limited、Eastern Profit Corporation Limited、Elite Well Global Limited、Empire Growth Holdings、Freedom Media Ventures Ltd.、G Club Operations LLC、G Fashion LLC、G News LLC、GETTR USA、Genever Holdings Corporation、Genever Holdings LLC、Gfashion Media Group Inc.、GFNY, Inc.、Globalist International Limited、GNews Media Group Inc.、Golden Spring (New York) Ltd.、Greenwich Land LLC、Guo Media、GTV Media Group, Inc.、Hamilton Capital Holdings Inc.、HCHK Property Management, Inc.、HCHK Technologies, Inc.、Head Win Group Limited、Henan Yuda、Himalaya Embassy、Himalaya Exchange、Himalaya Federal Reserve、Himalaya Investment LLC、Himalaya International、Himalaya New World Inc.、Himalaya Supervisory Organization、Himalaya Ventures LLC、HK International Funds Investments (USA) Limited LLC、Hong Kong International Funds\n\n案件 22-50073 文件 1592 于 03/24/23 提交 于 03/24/23 10:57:37 登记 第 652 页，共 1063 页\n\nInvestments Limited、Hudson Diamond Holding、Infinite Increase Limited、Infinitum Developments Limited、Infinity Treasury Management Inc.、Insight Phoenix Fund、Lamp Capital LLC、Leading Shine Limited、Leading Shine NY Limited、Lexington Property and Staffing、Long Gate Limited、Maywind Trading LLC、MOS Himalaya LLC、Next Tycoon Investments Limited、New Federal State of China（又名 NFSC）、Noble Fame Global Limited、Rosy Acme Ventures Limited、Rule of Law Foundation III, Inc.、Rule of Law Foundation IV, Inc.、Rule of Law Fund、Rule of Law Society、Rule of Law Society IV, Inc.、G-Translators PTY LTD、Saraca Media Group, Inc.、Shiny Ace Ltd.、Shiny Times Holdings Ltd.、Spirit Charter Investment Limited、Stevenson, Wong & Co.、Voice of Guo Media, Inc.、Well Origin Ltd.、World Century Limited、Worldwide Opportunity Holdings Limited、Whitecroft Shore Limited，以及 ZIBA Limited。\n\n9. “Including”或其任何变体，系指“包括但不限于”。\n\n10. “And”和“or”系指“and/or”，并应同时作连言和选言解释，以最大限度扩大其范围。\n\n11. “Any”、“all”和“each”系指“每一及全部”。\n\n12. “Each”和“every”系指“每一及全部”。\n\n13. “Third Party”系指贵方以外的个人或实体。\n\n14. “Transfer”具有《破产法》第 101(54) 条赋予其的含义。\n\n15. “Document”系指属于 Fed. R. Civ. P. 34 范围内的任何信息或物品，并包括但不限于贵方占有、保管或控制之内或曾在其内的每一项任何种类、类型、性质或描述的书面、记录或图形材料，包括电子邮件的所有纸质和电子副本、以电子形式保存的计算机文件、\n\n案件 22-50073 文件 1592 于 03/24/23 提交 于 03/24/23 10:57:37 登记 第 653 页，共 1063 页\n\n电子通信、短信、社交媒体帖子、推文、元数据、信函、备忘录、磁带、速记或手写笔记、任何种类的书面表格、图表、蓝图、绘图、草图、曲线图、计划、文章、规格、日记、信件、电报、照片、会议记录、合同、协议、调查、计算机打印件、任何种类的数据汇编、电传、传真、语音信息、发票、订购单、支票、汇票、对账单、贷项通知单、报告、头寸报告、摘要、索引、书籍、账簿、笔记本、日程表、透明胶片、录音、目录、广告、宣传材料、影片、录像带、录音带、CD、计算机磁盘、小册子、宣传册、穿孔卡、工时单、推文、社交媒体帖子或任何其他种类的书面或记录材料，以及其全部元数据，无论以何种方式存储（无论为有形或电子形式）、记录、制作或复制，亦包括但不限于前述任何材料的草稿或副本，如其载有原始文件中未见的任何种类的笔记、评论或标记，或以其他方式与原始文件不相同。\n\n16. “Person(s)”系指个人、公司、独资企业、合伙企业、协会或任何其他实体。“Person”亦包括任何代理人、代表或专家，包括但不限于律师或财务顾问。\n\n17. “Entity”系指任何自然人、公司、合伙企业、子公司、独资企业、商号、董事会、合资企业、协会、机构、主管机关、委员会或其他商业实体或法人，以及任何关联方、代理人、母公司，包括但不限于法律顾问、财务顾问或任何其他代表。\n\n18. “Regarding”系指有关、描述、包含、提及、与之相关、支持、赞成、反对、加强、减损、位于其中、与之相关地考虑、对其有影响、证明、表明、报告、记录、暗示、答复，\n\n案件 22-50073 文件 1592 于 03/24/23 提交 于 03/24/23 10:57:37 登记 第 654 页，共 1063 页\n\n与……有关联，就……发表评论，关于，就……而言，涉及，讨论，展示，描述，反映，分析，构成，以及属于。\n\n19. “涉及”、“涉及到”或“与……有关”，在指任何特定事项时，系指但不限于任何构成、包含、涉及、含有、体现、反映、识别、陈述、直接或间接提及该特定事项，或以任何方式与所识别的特定事项相关的文件。\n\n20. “通信”系指，在最广义且不限于此，任何信息或知识的传递（以事实、观点、询问或其他形式）。通信还指所有谈话、协议、询问或答复，无论是当面、通过电话、以书面形式，还是通过电子传输设备进行，并包括但不限于所有往来函件、电子邮件、录音、传送单、备忘录、电话通信、语音留言、电报、传真、电传副本、电传、即时消息、聊天信息、短信、电话记录，或在内部或与第三方之间传递的记录。\n\n21. “资产”系指任何可用于产生正向经济价值的项目，包括但不限于由某一实体拥有、控制或为其利益而持有，并预期将提供未来利益的任何具有经济价值的资源，包括但不限于所有不动产和动产、无形财产、投资、投资权或取得未来收入的权利、现金、银行账户、商品、证券、债权、对某一实体的全部或部分控制权，以及预期的经济机会。\n\n22. “转让”应具有《破产法》第101(54)条赋予该词的含义。\n\n四、应提交的文件\n\n1. 有关债务人、债务人破产财团或关联实体的任何收入或资产的所有文件。\n\n2. 与债务人的财务状况及其对债权人所负义务有关的所有文件，包括但不限于与任何试图避免支付该等义务的行为有关的所有文件，以及与本案或任何其他实际或潜在破产或类似无力偿债程序有关的所有文件。\n\n3. 有关债务人、债务人破产财团、债务人家庭成员、关联实体或关联个人的任何资产负债表、银行对账单、账户对账单、财务报表、账户结单、电汇指示和/或确认书、资金证明、存款证明、持仓证明、投资组合摘要或类似文件的所有文件，包括但不限于足以显示向前述任何一方作出的所有转让的所有文件。\n\n4. 有关由债务人作出、与债务人进行或代表债务人进行的任何投资、商业往来或交易的所有文件。\n\n5. 与债务人的所有通信，以及与债务人的通信有关、涉及任何实体（包括但不限于关联实体）的运营、管理或决策的文件。\n\n6. 有关向债务人、由债务人或与债务人，债务人家庭成员或关联实体作出的任何转让、投资或其他交易或商业往来的所有文件。\n\n7. 有关债务人曾占用或使用的任何财产的所有文件，包括但不限于 Lady May；Sherry Netherland Hotel / Condominium（雪莉荷兰酒店／公寓）；位于 Connecticut（康涅狄格州）Greenwich（格林尼治）373 Taconic Rd. 的住宅房产；位于 Connecticut（康涅狄格州）Greenwich（格林尼治）33 Ferncliff Rd. 的住宅房产；以及位于 Connecticut（康涅狄格州）Wilton（威尔顿）354 Nod Hill Rd. 的住宅房产。\n案件 22-50073 文件 1592 提交日期 03/24/23 录入日期 03/24/23 10:57:37 第 656 页，共 1063 页\n\n8. 与债务人拥有、控制或使用的任何航空器有关的所有文件，包括但不限于尾号为 T7-GQM 的航空器及在 San Marino（圣马力诺）注册的任何其他航空器，包括但不限于所有登记文件的副本，以及显示该等航空器所执行航班及该等航班机上人员的所有飞行清单。\n\n9. 有关向债务人、债务人破产财团、债务人家庭成员或关联实体提供、从其取得或代表其提供的任何赠与、利益或贷款的所有文件，包括但不限于足以显示该等赠与、利益或贷款的金额；该等赠与、利益或贷款的用途；提供该等赠与、利益或贷款的时间；以及任何贷款的条款、就任何贷款作出的所有陈述和保证、任何贷款的利率，以及任何贷款付款的所有证据的文件。\n\n10. 有关由债务人、代表债务人或为债务人，债务人破产财团、债务人家庭成员或关联实体的利益而设立的任何信托或类似文书的所有文件，包括但不限于足以显示该等信托何时设立、由谁设立、为谁的利益设立及信托财产的文件。\n\n11. 与涉及债务人的任何法律争议有关的任何义务、请求权、责任或债务相关的所有文件，包括但不限于与任何地方、州、联邦或国际机构（无论是行政机构、法院、合议机构或替代性争议解决实体）审理的任何诉讼有关的文件。\n案件 22-50073 文件 1592 提交日期 03/24/23 录入日期 03/24/23 10:57:37 第 657 页，共 1063 页\n\n12. 您的任何外聘律师或其他顾问与债务人之间的所有文件和通信。\n\n13. 足以显示您的全部资产以及收入或资金来源的文件。\n\n14. 对于就第14项请求所识别且价值超过 $50,000 的所有资产，(i) 与您取得该等资产有关的所有文件，以及 (ii) 您与债务人或债务人家庭成员就该等资产进行的通信。\n\n15. 您的纳税申报表副本。\n\n16. 足以显示由您持有或控制的所有银行账户和投资账户的文件，包括每一该等账户的余额及向该等账户转入和从该等账户转出的款项。\n\n17. 有关您使用的任何信用卡的所有文件，包括但不限于月度对账单或足以显示为债务人或关联实体利益而进行的所有相关购买的其他文件。\n\n18. 所有公司治理及组织文件，包括但不限于公司章程细则和公司注册证书，以及足以显示您的公司结构、高级管理人员和董事姓名、经营目的，以及与债务人或债务人任何家庭成员之间关系的其他文件。\n\n19. 与将您的任何资产质押给任何其他实体有关的所有文件。\n\n案件 22-50073 文件 1592 提交日期 03/24/23 录入日期 03/24/23 10:57:37 第 658 页，共 1063 页\n\n附件 C-36\n\nB2540（表格 2540－依据第2004条规则审查的传票）（12/15）案件 22-50073 文件 1592 提交日期 03/24/23 录入日期 03/24/23 10:57:37 第 659 页，共\n\n美国破产法院 1063\n\nConnecticut District（康涅狄格区）\n\n关于 HO WAN KWOK（郭文贵）等人，\n\n1 案件编号 22-50073 (JAM)\n\n债务人 第11章\n\n（合并管理）\n依据第2004条规则审查的传票\n\n致：Lihong “Sara” Wei Lafrenz（魏丽红“莎拉”·拉弗伦茨）\n\n（传票所指向的人员姓名）\n\n证言：兹命令您于下列规定的时间、日期和地点出席，并根据《联邦破产程序规则》第2004条接受审查并作证。随附准许该审查的法院命令副本。\n\n地点　日期和时间\n\nPaul Hastings LLP（宝盛律师事务所）\n200 Park Avenue　[待定]\nNew York, New York 10166\n\n审查将通过以下方式记录：法庭记录员／速记员\n\n提交：您或您的代表还必须携带下列文件、电子存储信息或物品参加审查，并必须允许对该等材料进行查验、复制、测试或抽样：\n\n见随附的文件提交请求。\n\n下列《联邦民事诉讼规则》第45条的规定，依据《联邦破产程序规则》第9016条适用于破产案件，现随附：与履行地点有关的第45(c)条；与作为受传票约束人员所享保护有关的第45(d)条；以及与您回应本传票的义务及不履行该义务可能产生的后果有关的第45(e)条和第45(g)条。\n\n日期：March , 2023\n\n法院书记员\n\n或\n\n书记员或副书记员签名　律师签名\n\n签发或申请本传票、代理第11章受托人 Luc A. Despins（吕克·A·德斯潘斯）的律师姓名、地址、电子邮件地址和电话号码如下：\n\nDouglas S. Skalka, Esq.（道格拉斯·S·斯卡尔卡律师）；Neubert, Pepe & Monteith, P.C.（纽伯特、佩佩和蒙蒂斯律师事务所）；195 Church Street, New Haven, Connecticut 06510；dskalka@npmlaw.com；(203) 821-2000\n\n致签发或申请本传票之人的通知\n\n如本传票命令在审判前提交文件、电子存储信息或有形物品，或检查场所，则必须在向本传票所指向人员送达之前，向每一方当事人送达通知及本传票副本。《联邦民事诉讼规则》第45(a)(4)条。\n\n软件版权 (c) 1996-2022 Best Case, LLC（百思凯斯有限责任公司）- www.bestcase.com Best Case Bankruptcy 1 本第11章案件中的债务人为 Ho Wan Kwok（郭文贵）（亦称 Guo Wengui、Miles Guo 和 Miles Kwok，以及众多其他别名）（税务识别号码后四位：9595）、Genever Holdings LLC（税务识别号码后四位：8202）及 Genever Holdings Corporation。受托人、Genever Holdings LLC 和 Genever Holdings Corporation 的邮寄地址为 Paul Hastings LLP（宝盛律师事务所），200 Park Avenue, New York, NY 10166，转交 Luc A. Despins（吕克·A·德斯潘斯），作为 Ho Wan Kwok（郭文贵）破产财团的受托人（仅为通知和通信之目的）。\n\n送达证明\n\n（除非《联邦民事诉讼规则》第45条要求，否则本节不应向法院提交。）\n\n我于（日期）收到向（个人姓名及职务，如有）发出的本传票。\n\n我通过如下方式向被指定人员交付副本而送达本传票：\n\n于（日期）送达；或\n\n我未执行本传票即予退回，原因如下：\n\n除非本传票代表美国或其官员或代理人签发，我还已向证人支付一天出席费用及法律允许的里程费，金额为 $ 。\n\n我的差旅费用为 $ ，服务费用为 $ ，合计为 $ 。\n\n我在伪证罪处罚下声明，该等信息真实无误。\n\n日期：\n\n送达人签名\n\n正楷姓名及职务\n\n送达人地址\n\n关于尝试送达等的补充信息：\n\n《联邦民事诉讼规则》第45(c)、(d)、(e)和(g)条（自 12/1/13 起生效）（依据《联邦破产程序规则》第9016条适用于破产案件）\n\n(c) 履行地点。\n\n(1) 审判、听证或证言录取。传票仅可在下列地点命令某人出席审判、听证或证言录取：\n\n(A) 距该人居住、受雇或经常亲自从事商业活动之地100英里以内；或\n\n(B) 在该人居住、受雇或经常亲自从事商业活动所在州内，如该人\n\n(i) 为当事人或当事人的高级管理人员；或\n\n(ii) 被命令出席审判且不会产生重大费用。\n\n(2) 其他证据开示。传票可命令：\n\n(A) 在距该人居住、受雇或经常亲自从事商业活动之地100英里以内的地点提交文件、电子存储信息或物品；以及\n\n(B) 在被检查场所进行场所检查。\n\n(d) 保护受传票约束人员；执行。\n\n(1) 避免不当负担或费用；制裁。负责签发和送达传票的一方当事人或律师必须采取合理步骤，避免对受传票约束的人施加不当负担或费用。要求履行义务所在地区的法院必须执行该义务，并对未遵守该义务的一方当事人或律师施加适当制裁，该制裁可包括损失的收入和合理的律师费。\n\n(2) 要求提交材料或允许检查。\n\n(A) 无须出庭。被要求提交文件、以电子方式存储的信息或有形物品，或者允许检查场所的人，无须亲自到提交或检查地点出庭，除非其亦被要求为证言录取、听证或审判而出庭。\n\n(B) 异议。被要求提交文件或有形物品，或者允许检查的人，可以向传票中指定的一方当事人或律师送达书面异议，反对检查、复制、测试或抽样任何或全部材料，或反对检查场所，或反对按所要求的一种或多种形式提交以电子方式存储的信息。异议必须在规定履行的时间或传票送达后14日两者中较早者之前送达。如提出异议，则适用以下规则：\n\n(i) 在任何时候，经通知被要求履行之人，送达传票的一方当事人可以向要求履行义务所在地区的法院提出动议，请求作出强制提交或检查的命令。\n\n(ii) 仅可按照该命令的指示要求实施这些行为，并且该命令必须保护并非当事人亦非当事人高级职员之人，免于因履行而产生的重大费用。\n\n(3) 撤销或修改传票。\n\n(A) 必须撤销或修改的情形。经及时动议，要求履行义务所在地区的法院必须撤销或修改具有下列情形的传票：\n\n(i) 未给予合理的履行时间；\n\n(ii) 要求某人在Rule 45(c)规定的地理限制以外履行；\n\n(iii) 要求披露享有特权或受其他保护的事项，且不存在适用的例外或放弃；或\n\n(iv) 对某人施加不当负担。\n\n(B) 可以撤销或修改的情形。为保护受传票约束或受其影响之人，要求履行义务所在地区的法院可以依动议撤销或修改要求下列事项的传票：\n\n(i) 披露商业秘密或其他保密的研究、开发或商业信息；或\n\n(ii) 披露未受聘专家的意见或信息，该等意见或信息并非描述争议中的具体事件，且系该专家未受任何一方当事人请求进行的研究所得。\n\n(C) 将规定条件作为替代措施。在Rule 45(d)(3)(B)所述情形下，如送达传票的一方当事人：\n\n(i) 证明其对该证言或材料具有实质性需要，且若不遭受不当困难便无法以其他方式满足该需要；且\n\n(ii) 确保受传票传唤之人将获得合理补偿，\n\n法院可以不撤销或修改传票，而是命令在规定条件下出庭或提交材料。\n\n(e) 对传票作出回应时的义务。\n\n(1) 提交文件或以电子方式存储的信息。下列程序适用于提交文件或以电子方式存储的信息：\n\n(A) 文件。回应要求提交文件之传票的人，必须按该等文件在正常业务过程中保存的方式提交，或者必须将其整理和标记，以对应请求中列明的类别。\n\n(B) 未规定提交以电子方式存储的信息的形式。如传票未规定提交以电子方式存储的信息的形式，回应之人必须以该信息通常保存的一种或多种形式，或以一种或多种合理可用的形式提交。\n\n(C) 以电子方式存储的信息仅以一种形式提交。回应之人无须以一种以上形式提交相同的以电子方式存储的信息。\n\n(D) 无法访问的以电子方式存储的信息。回应之人无须提供来自其认定因不当负担或费用而无法合理访问的来源的以电子方式存储的信息的证据开示。对于强制证据开示或保护令的动议，回应之人必须证明该信息因不当负担或费用而无法合理访问。如作出该证明，法院在考虑Rule 26(b)(2)(C)的限制后，如请求方当事人证明有正当理由，仍可命令从该等来源进行证据开示。法院可以规定证据开示的条件。\n\n(2) 主张特权或保护。\n\n(A) 被扣留的信息。以该信息享有特权或作为审判准备材料受保护为由扣留被传票要求的信息之人，必须：(i) 明确提出该主张；以及\n\n(ii) 以一种方式说明被扣留文件、通信或有形物品的性质，使各方当事人在不披露本身享有特权或受保护的信息的情况下，能够评估该主张。\n\n(B) 已提交的信息。如为回应传票而提交的信息受到特权主张或作为审判准备材料受保护的主张约束，提出该主张之人可以将该主张及其依据通知任何收到该信息的一方当事人。收到通知后，一方当事人必须立即返还、隔离或销毁指定的信息及其所持有的任何副本；在该主张获得解决之前不得使用或披露该信息；如该方当事人在收到通知前已披露该信息，必须采取合理步骤追回该信息；并可立即将该信息密封提交至要求履行义务所在地区的法院，以裁定该主张。提交该信息之人必须保存该信息，直至该主张获得解决。\n\n(g) 藐视法庭。要求履行义务所在地区的法院——以及在动议被移送后，签发传票的法院——可以认定已被送达但无充分理由未遵守传票或与之相关命令之人构成藐视法庭。\n\n关于获取传票材料，见Fed.R.Civ.P.45(a) Committee Note (2013)\n\n……\n\n文件提交请求\nI. 指示\n\n1. 除非另有说明，下列文件请求（简称“请求”，每项称“一项请求”）必须分别并具体作出回应。除非基于善意提出异议，否则每项请求均应得到完整答复；如提出异议，则应按下文所述详细陈述您提出异议的理由。如异议仅涉及一项请求的一部分，或其中包含的一个词语、短语或条款，您仅须陈述对该部分的异议，并回应其余请求。\n\n2. 以电子方式存储的信息必须按照以下指示提交：\n\na. 图像。黑白图像必须为300 DPI Group IV单页TIFF文件。彩色图像必须以JPEG格式提交。文件名不得包含嵌入空格或特殊字符（包括逗号）。文件夹名称不得包含嵌入空格或特殊字符（包括逗号）。所有TIFF图像文件必须具有唯一的文件名，即Bates编号。每张图像右下角必须标注连续的Bates编号。每个文件夹中的TIFF文件不得超过1000个。Excel电子表格应具有以该文件Bates编号命名的占位图像。\n\nb. 图像加载文件\n\na. Concordance®数据文件。数据文件（.DAT）包含将加载至Concordance®数据库的所有字段化信息。.DAT文件的第一行必须为标识字段名称的标题行。.DAT文件必须使用以下Concordance®默认分隔符：逗号 ASCII字符（020）引号 þ ASCII字符（254）。日期字段应采用以下格式提供：mm/dd/yyyy。日期和时间字段必须为两个独立字段。如文件包括已生成图像的电子邮件及附件，则必须包括附件字段，以保留电子邮件及其附件之间的父/子关系。必须包括OCRPATH字段，以提供所提交存储介质上提取文本文件的文件路径和名称。文本文件必须以FIRSTBATES命名。不得在.DAT文件中包含文本。对于具有原生文件的文件，必须包括LINK字段，以提供该原生文件的文件路径和\n\n名称。原生文件必须以FIRSTBATES命名。\n\nb. Concordance Image®或Opticon交叉引用文件。图像交叉引用文件（.LOG或.OPT）将图像链接至数据库记录。该文件应为以逗号分隔的文件，每行由七个字段组成，并应就数据库中的每一图像在交叉引用文件中设置一行，格式如下：ImageID,VolumeLabel,ImageFilePath,DocumentBreak,FolderBreak,Box Break,PageCoun。\n\nc. 文件文本。文本必须作为单独的文本文件提交，而不得作为.DAT文件内的字段提交。文本文件的完整路径（OCRPATH）应包括在.DAT文件中。建议提供以FIRSTBATES/Image Key命名的文件级ANSI文本文件。提取的文本文件必须存放在单独的文件夹中，每个文件夹中的文本文件不得超过1,000个。文件夹名称中不得有特殊字符（包括逗号）。文本文件必须按文件级别提供。\n\nd. 特定文件类型的原生格式提交。为充分理解其内容和含义而合理需要以原生格式查看的文件类型，必须以原生格式提交。该等文件包括但不限于电子表格、类似电子表格的文件（Microsoft Excel、逗号分隔值、制表符分隔值等）、Microsoft PowerPoint或其他特殊演示文件、数据库文件及音频/视频文件。提供一张标有Bates编号的提示页图像，注明存在原生文件，并将原生文件的路径作为字段包括在.dat文件中。所提交的原生文件应以与该文件提示页相对应的Bates编号命名。将原生文件归入按递增方式命名的“NATIVE”目录中，并与图像目录分开。\n\ne. 去重。对存在完全重复件的每一电子文件，提交单一副本。对于电子邮件，根据由BCC、Body、CC、From、IntMsgID、To和Attach属性生成的MD5哈希值合并重复件。对于电子邮件附件及独立电子文件，根据整个文件的MD5哈希值合并重复件。\n\nf. 元数据。以符合Concordance要求的加载文件（.dat）形式，提交每份文件的提取元数据。.DAT文件的第一行必须为标识字段名称的标题行。.DAT文件必须使用以下Concordance默认分隔符：逗号 , ASCII字符（020）引号 þ ASCII字符（254）\n\n日期字段应采用以下格式提供：mm/dd/yyyy。日期和时间字段必须为两个独立字段。下列为所需元数据：\nCase 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 664 of 1063\n\n字段名称　示例数据　说明\n\nFIRSTBATES　EDC0000001　原生文件文档/电子邮件的首个 Bates 编号\nLASTBATES　EDC0000001　原生文件文档/电子邮件的最后一个 Bates 编号\nLASTBATES 字段应予填写\n适用于单页文件\nATTACHRANGE　EDC0000001\n-　母文档第一页的 Bates 编号\nEDC0000015　至最后一个附件“子”文档最后一页的 Bates 编号\nBEGATTACH　EDC0000001　附件范围的首个 Bates 编号\nENDATTACH　EDC0000015　附件范围的最后一个 Bates 编号\nCUSTODIAN　Smith, John　电子邮件：电子邮件所在的邮箱\n原生文件：文档来源个人或部门的名称\nFROM　John Smith　电子邮件：发件人\n原生文件：文档作者\n多个条目应以分号分隔\nTO　Coffman, Janice; LeeW　收件人\n[mailto:LeeW@MSN.com]　多个条目应以分号分隔\nCC　Frank Thompson [mailto:　抄送收件人\nfrank_Thompson@cdt.com]　多个条目应以分号分隔\nBCC　John Cain　密送收件人\n多个条目应以分号分隔\nSUBJECT　Board Meeting Minutes　电子邮件：电子邮件主题行；原生文件：文档标题（如有）\nFILE_NAME　BoardMeetingMinutes.docx　原始原生文件的名称，包括扩展名\nDATE_SENT　10/12/2010　电子邮件：电子邮件发送日期\n原生文件：（空）\nTIME_SENT/　07:05 PM GMT　电子邮件：电子邮件发送时间/电子邮件标准化所采用时区的时间\nTIME_ZONE　GMT　电子邮件在转换过程中进行标准化所采用的时区。\nLINK　EDC0000001.msg　指向电子邮件或原生文件文档的超链接\n链接文件必须按照 FIRSTBATES 编号命名\nFILE_EXTEN　MSG　表示电子邮件或的文件类型扩展名\nAUTHOR　John Smith　电子邮件：（空）\n原生文件：文档作者\nDATE_CREATED　10/10/2010　电子邮件：（空）\n原生文件：文档创建日期\nCase 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 665 of 1063\n\nTIME_CREATED　10:25 AM　电子邮件：（空）\n\n原生文件：文档创建时间\n该数据必须为单独字段，不得与 DATE_CREATED 字段合并\nDATE_MOD　10/12/2010　电子邮件：（空）\n原生文件：文档最后修改日期\nTIME_MOD　07:00 PM　电子邮件：（空）\n原生文件：文档最后修改时间\n该数据必须为单独字段，不得与 DATE_MOD 字段合并\nDATE_ACCESSD　10/12/2010　电子邮件：（空）\n原生文件：文档最后访问日期\nTIME_ACCESSD　07:00 PM　电子邮件：（空）\n原生文件：文档最后访问时间\n该数据必须为单独字段，不得与 DATE_ACCESSD 字段合并\nFILE_SIZE　5,952　原生文件文档/电子邮件的大小，以 KB 计\nPGCOUNT　1　原生文件文档/电子邮件中的页数\nPATH　电子邮件：（空）\nAgenda.doc　原生文件：原生文件文档存储的路径，包括原始文件名。\nINTFILEPATH　Personal Folders\\Deleted　电子邮件：包括原始文件名在内的电子邮件原始位置。\nItems\\Board Meeting　原生文件：（空）\nMinutes.msg\nINTMSGID　<000805c2c71b\\$75977050\\$　电子邮件：唯一邮件 ID；原生文件：（空）\ncb8306d1@MSN>\nMD5HASH　d131dd02c5e6eec4693d9a0　文档的 MD5 哈希值。\n698aff95c\n2fcab58712467eab4004583e\nb8fb7f89\nOCRPATH　TEXT/001/EDC0000001.txt　原生文件提取文本的路径\n\n3. 每一项请求均独立适用并应独立解释，除非另有说明，任何请求均不限制任何其他请求的范围。\n\n4. 所有文档均应按通常业务过程中的保存方式提供，或者应予整理和标注，以对应本请求中的类别。\n\n5. 本文件所载每项请求均延及以下所有文档：(a) 由您占有、保管或控制的文档；或 (b) 由任何代表您行事之人占有、保管或控制的文档，\nCase 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 666 of 1063\n\n包括您的律师或其他代表及顾问。每份文档均应完整提供。\n\n6. 如要求您提供一份已不再由您占有、保管或控制的文档，则您的答复必须：(a) 详细说明该文档的性质及其内容；(b) 指明编制或撰写该文档之人员（以及，如适用，该文档被发送给的人员）；(c) 指明该文档编制或创建的日期；(d) 说明该文档是否 (i) 遗失或丢失，(ii) 已被销毁，(iii) 已自愿或非自愿地转移给他人，或 (iv) 以其他方式被处置；(e) 说明该等处置的理由及相关事实和情形；(f) 指明授权该等处置的人员；(g) 指明该等处置的日期或大致日期；(h) 说明该文档最后一次由您占有、保管或控制的时间；以及 (i) 指明目前占有、保管或控制该文档的人员（如有）。\n\n7. 如要求您提供一份已被销毁的文档，则除前述指示所要求的信息外，您的答复还必须说明：(a) 销毁该文档的理由；(b) 销毁该文档的人员身份；以及 (c) 指示销毁该文档的人员身份。\n\n8. 如您主张所请求的文档享有特权或属于律师工作成果，则您的答复必须：(a) 说明 (i) 对该文档作出足以支持您关于该文档享有特权之主张的描述，(ii) 该文档的标题，(iii) 该文档的日期，(iv) 该文档的作者，(v) 该文档的收件人，(vi) 收到或阅览该文档原件或任何草稿、副本或复制件的每一人员身份，(vii) 该文档本身或其中载有或提及的任何信息是否由任何其他人员占有、保管或控制，如是，则指明\nCase 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 667 of 1063\n\n该等人员的身份，以及说明该等信息如何进入其占有状态，(viii) 据以扣留该文档的特权主张，及 (ix) 您将据以支持该等特权主张的所有情形；以及 (b) 根据 D. Conn. L. Civ. R. 26(e)，就基于特权主张而扣留的每一份文档，制作一份特权日志，其中包含本指示第 (a) 部分所要求的全部信息。\n\n9. 如本应提供的文档的一部分含有受特权主张约束的信息，则仅应依照上述指示从该文档中删除或遮盖受特权主张约束的部分，其余部分应予提供。\n\n10. 本请求具有持续性。特此指示您：(a) 一旦获悉先前答复不完整或不正确，应立即补充或更正任何后来发现不完整或不正确的答复；以及 (b) 提供根据以下规定所要求的任何额外文档\n\n11. 如一份文档采用英语以外的语言，您应提供该文档。如一份文档采用英语以外的语言，且存在英文译本，您应同时提供两份文档。\n\n12. 对实体的一切提及均包括其所有关联方。\n\n13. 对个人姓名的一切提及均包括所有替代姓名、别名或昵称。\n\n14. 除非另有明确说明，文档请求所涵盖的期间为自 February 5, 2012 起至文档请求答复到期之日止。\nCase 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 668 of 1063\nII. 解释规则\n\n15. (a) 任何单数名词的使用应解释为包括复数，反之亦然；以及 (b) 任何时态动词的使用应解释为包括该动词所有其他时态的使用。\n\n16. (a) “and”和“or”应根据需要解释为连词或选择连词，以使任何请求的范围包括原本可能被解释为不在其范围内的所有答复；以及 (b) “each”和“any”应视为包括并涵盖“every”和“all”。\nIII. 定义\n\n经 D. Conn. Bankr. L.R. 2004-1(a) 纳入的 D. Conn. L. Civ. R. 26(c) 所规定的定义及 D. Conn. L. Civ. R. 26(d) 所规定的解释规则，适用于文档请求。此外，本文件档请求中使用的下列术语具有如下含义：\n\n1. “您”或“您的”或“您本人”系指 Lihong “Sara” Wei Lafrenz（魏丽红），及其所有代理人、律师、代表、雇员和/或任何代表其行事之人。\n\n2. “债务人”系指 Ho Wan Kwok（郭文贵）（又名 Miles Kwok、Miles Guo、Guo Wengui、Guo Haoyun、郭文贵，或任何其他别名），及其雇员、代理人、律师、顾问或任何代表其行事之人。\n\n3. “债务人之子”系指 Qiang Guo（郭强）（又名 Mileson Kwok、郭强，或任何其他别名），及其雇员、代理人、律师、顾问或任何代表其行事之人。\nCase 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 669 of 1063\n\n4. “债务人之女”系指 Mei Guo（郭美）（又名 Mei Gui、郭美，或任何其他别名），及其雇员、代理人、律师、顾问或任何代表其行事之人。\n\n5. “债务人之所谓妻子”系指 Hing Chi Ngok（岳庆芝）（又名 Hing Chi Ng、Yue Qingzhi、岳庆芝，或任何其他别名），及其雇员、代理人、律师、顾问或任何代表其行事之人。\n\n6. “债务人家属”统称债务人、债务人之子、债务人之女及债务人之所谓妻子，以及与债务人具有任何其他亲属关系之人。\n\n7. “关联个人”单独及共同系指以下所有个人：(1) 持有、控制、保管或对债务人或债务人家属拥有、控制或享有的资产具有处置权者；或 (2) 曾为一个或多个关联实体的雇员、董事，或以其他方式与之关联者，以及前述任何人的各自雇员、代理人、律师、顾问或任何代表其行事之人。该等关联个人包括但不限于：Daniel Podhaskie（丹尼尔·波德哈斯基）、Jason Miller（杰森·米勒）、Steve Bannon（史蒂夫·班农）、Karin Maistrello（卡琳·迈斯特雷洛）、Melissa Francis（梅利莎·弗朗西斯）、Anthony DiBattista（安东尼·迪巴蒂斯塔）、William Gertz（威廉·格茨）、Arethusa Forsyth（阿瑞修莎·福赛思）、Glenn Mellor（格伦·梅勒）、Jennifer Mercurio（詹妮弗·默丘里奥）、Eduardo Eurnekian（爱德华多·厄内基安）、Wencong Wang（王文聪）、Han Chunguang（韩春光）（又名 韩春光）、Qu Guojiao（屈国姣）（又名 Qu Guo Jiao、屈国姣）、Guo Lijie（郭丽杰）（又名 郭丽杰）、Zhang Wei（张伟）（又名 张伟*）、Lihong Wei Lafrenz（魏丽红）（又名 Sara Wei、魏丽红）、Hao Haidong（郝海东）（又名 郝海东）、Ross Heinemeyer（罗斯·海涅迈耶）、Max Krasner（马克斯·克拉斯纳）、Kyle Bass（凯尔·巴斯）、Melissa Mendez（梅利莎·门德斯）、Ya Li（李娅）（又名 李娅）、Dinggang Wang（王定刚）（又名 王定刚）、An Hong（安红）（又名 安红）、Yvette Wang（王雁平）（又名 Yanping Wang、Yan Ping Wang、王雁平）、Fiona Yu（菲奥娜·余）、Je Kin Ming（余建明）（又名 William Je、Yu Jianming、余建明）、Yaz Qingua（亚兹·钦瓜）及 Lao Jiang（姜云浮）（又名 Jiang Yunfu、Jiang Yunfu Be、姜云浮）。\nCase 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 670 of 1063\n\n8. “关联实体”系指单独或合并而言，所有符合以下条件的任何类型组织或实体：(1) 曾由债务人或债务人的家庭成员拥有、控制或投资；或(2) 对债务人或债务人的家庭成员拥有、控制或享有的任何资产直接或间接拥有权益，连同前述任何一方各自的雇员、代理人、法律顾问、顾问或代表其行事的任何人。该等关联实体包括但不限于：7 Nod Hill LLC（7 Nod Hill 有限责任公司）、AAGV Limited（AAGV有限公司）、ACA Investment Management Limited（ACA投资管理有限公司）、ACA Capital Group Limited（ACA资本集团有限公司）、Ace Decade Holdings Limited（Ace Decade控股有限公司）、AI Group Holdings Inc.（AI集团控股公司）、Alfa Global Ventures Limited（Alfa全球创投有限公司）、Alfonso Global Limited（Alfonso全球有限公司）、Allied Capital Global Limited（联合资本全球有限公司）、Alpine Fiduciaries SA（Alpine受托人股份公司）、Anton Development Limited（Anton开发有限公司）、Assets Sino Limited（华夏资产有限公司）、Auspicious Coast Limited（吉祥海岸有限公司）、Beijing Pangu Investment Co.（北京盘古投资公司）、Beijing Pangu Investment Co. Ltd.（北京盘古投资有限公司）、Beijing Pangu Investment Inc.（北京盘古投资股份有限公司）、Beijing Zenith Holdings Company Limited（北京鼎峰控股有限公司）、Booming Sail New York LLC（Booming Sail纽约有限责任公司）、Bravo Luck Limited（Bravo Luck有限公司）、BSA Strategic Fund I（BSA战略基金I）、China Golden Spring (Hong Kong) Limited（中国金泉〈香港〉有限公司）、Chuang Xin Limited（创新有限公司）、Crane Advisory Group LLC（Crane顾问集团有限责任公司）、Creative Apex Investments Limited（Creative Apex投资有限公司）、Crystal Breeze Investments Limited（Crystal Breeze投资有限公司）、Dawn State Limited（Dawn State有限公司）、Eastern Profit Corporation Limited（东方利润有限公司）、Elite Well Global Limited（Elite Well全球有限公司）、Empire Growth Holdings（Empire Growth控股公司）、Freedom Media Ventures Ltd.（Freedom Media Ventures有限公司）、G Club Operations LLC（G Club运营有限责任公司）、G Fashion LLC（G Fashion有限责任公司）、G News LLC（G News有限责任公司）、GETTR USA（GETTR美国）、Genever Holdings Corporation（Genever控股公司）、Genever Holdings LLC（Genever控股有限责任公司）、Gfashion Media Group Inc.（Gfashion媒体集团公司）、GFNY, Inc.（GFNY公司）、Globalist International Limited（Globalist International有限公司）、GNews Media Group Inc.（GNews媒体集团公司）、Golden Spring (New York) Ltd.（Golden Spring〈纽约〉有限公司）、Greenwich Land LLC（Greenwich Land有限责任公司）、Guo Media（Guo Media）、GTV Media Group, Inc.（GTV媒体集团公司）、Hamilton Capital Holdings Inc.（Hamilton Capital控股公司）、HCHK Property Management, Inc.（HCHK物业管理公司）、HCHK Technologies, Inc.（HCHK科技公司）、Head Win Group Limited（Head Win集团有限公司）、Henan Yuda（河南裕达）、Himalaya Embassy（Himalaya大使馆）、Himalaya Exchange（Himalaya交易所）、Himalaya Federal Reserve（Himalaya联邦储备）、Himalaya Investment LLC（Himalaya投资有限责任公司）、Himalaya International（Himalaya International）、Himalaya New World Inc.（Himalaya New World公司）、Himalaya Supervisory Organization（Himalaya监督组织）、Himalaya Ventures LLC（Himalaya Ventures有限责任公司）、HK International Funds Investments (USA) Limited LLC（香港国际基金投资〈美国〉有限责任公司）、Hong Kong International Funds Investments Limited（香港国际基金投资有限公司）、Hudson Diamond Holding（Hudson Diamond控股公司）、Infinite Increase Limited（Infinite Increase有限公司）、Infinitum Developments Limited（Infinitum开发有限公司）、Infinity Treasury Management Inc.（Infinity财资管理公司）、Insight Phoenix Fund（Insight Phoenix基金）、Lamp Capital LLC（Lamp Capital有限责任公司）、Leading Shine Limited（Leading Shine有限公司）、Leading Shine NY Limited（Leading Shine纽约有限公司）、Lexington Property and Staffing（Lexington物业及人力配置公司）、Long Gate Limited（Long Gate有限公司）、Maywind Trading LLC（Maywind Trading有限责任公司）、MOS Himalaya LLC（MOS Himalaya有限责任公司）、Next Tycoon Investments Limited（Next Tycoon投资有限公司）、New Federal State of China (a/k/a NFSC)（中国新联邦国，亦称NFSC）、Noble Fame Global Limited（Noble Fame Global有限公司）、Rosy Acme Ventures Limited（Rosy Acme Ventures有限公司）、Rule of Law Foundation III, Inc.（法治基金会III公司）、Rule of Law Foundation IV, Inc.（法治基金会IV公司）、Rule of Law Fund（法治基金）、Rule of Law Society（法治协会）、Rule of Law Society IV, Inc.（法治协会IV公司）、G-Translators PTY LTD（G-Translators私人有限公司）、Saraca Media Group, Inc.（Saraca媒体集团公司）、Shiny Ace Ltd.（Shiny Ace有限公司）、Shiny Times Holdings Ltd.（Shiny Times控股有限公司）、Spirit Charter Investment Limited（Spirit Charter投资有限公司）、Stevenson, Wong & Co.（Stevenson, Wong & Co.）、Voice of Guo Media, Inc.（郭媒体之声公司）、Well Origin Ltd.（Well Origin有限公司）、World Century Limited（World Century有限公司）、Worldwide Opportunity Holdings Limited（Worldwide Opportunity控股有限公司）、Whitecroft Shore Limited（Whitecroft Shore有限公司）及ZIBA Limited（ZIBA有限公司）。\n\n案件 22-50073 文书 1592 提交日期 03/24/23 录入日期 03/24/23 10:57:37 第 671 页，共 1063 页\n\n9. “包括”或其任何变体系指“包括但不限于”。\n\n10. “和”及“或”系指“和/或”，并应作连词及析取词解释，以最大限度地扩大其范围。\n\n11. “任何”及“所有”及“每一”均系指“每一个及全部”。\n\n12. “每一”及“每个”均系指“每一个及全部”。\n\n13. “第三方”系指除贵方以外的个人或实体。\n\n14. “转让”具有《破产法》第101(54)条赋予该术语的含义。\n\n15. “文件”系指属于Fed. R. Civ. P. 34范围内的任何信息或物品，并包括但不限于由贵方占有、保管或控制的，或曾由贵方占有、保管或控制的任何种类、类型、性质或描述的每一项书面、记录或图形资料，包括所有电子邮件的打印副本和电子副本、以电子形式保存的计算机文件、电子通信、短信、社交媒体帖子、推文、元数据、往来函件、备忘录、磁带、速记或手写笔记、任何种类的书面表格、图表、蓝图、绘图、草图、图形、计划、文章、规格说明、日记、信件、电报、照片、会议记录、合同、协议、调查、计算机打印件、任何种类的数据汇编、电传、传真、语音留言、发票、订购单、支票、汇票、对账单、贷项通知单、报告、持仓报告、摘要、索引、账簿、分类账、笔记本、明细表、透明胶片、录制物、目录、广告、宣传材料、影片、录像带、录音带、CD、计算机磁盘、宣传册、小册子、穿孔卡、工时单、推文、社交媒体帖子或任何其他种类的书面或记录材料，以及其全部元数据，无论以何种方式储存（无论以有形形式或电子形式）、记录、制作或复制；还包括但不限于前述任何资料的草稿或副本，凡其载有原始文件中没有的任何种类笔记、评论或标记，或在其他方面与原始文件不相同者。\n\n案件 22-50073 文书 1592 提交日期 03/24/23 录入日期 03/24/23 10:57:37 第 672 页，共 1063 页\n\n16. “个人”系指个人、公司、独资企业、合伙企业、协会或任何其他实体。“个人”还包括任何代理人、代表或专家，包括但不限于律师或财务顾问。\n\n17. “实体”系指任何自然人、公司、合伙企业、子公司、独资企业、商号、董事会、合资企业、协会、机构、主管机关、委员会或其他商业实体或法人，以及任何关联方、代理人、母公司，包括但不限于法律顾问、财务顾问或任何其他代表。\n\n18. “关于”系指涉及、描述、包含、提及、与之相关、支持、有利于、反对、加强、减损、位于、结合考虑、与之有关、证明、表明、报告、记录、暗示、答复、与之连接、评论、就其而言、有关、与之相关、讨论、显示、描述、反映、分析、构成及属于。\n\n案件 22-50073 文书 1592 提交日期 03/24/23 录入日期 03/24/23 10:57:37 第 673 页，共 1063 页\n\n19. 在提及任何特定主题事项时，“与……有关”、“涉及”或“相关”系指，包括但不限于，构成、包含、涉及、含有、体现、反映、识别、陈述、直接或间接提及，或以任何方式与所确定的特定主题事项有关的任何文件。\n\n20. “通信”系指在最广泛可能意义上且不受限制的任何信息或知识传递（以事实、观点、询问或其他形式）。通信还指所有对话、协议、询问或答复，无论是当面、通过电话、以书面形式，还是借助电子传输设备进行，并包括但不限于所有往来函件、电子邮件、录音、传输单、备忘录、电话通信、语音留言、电报、电话传真、传真副本、电传、即时消息、聊天信息、短信、电话笔记或在内部或与第三方之间传输的笔记。\n\n21. “资产”系指可用于产生正向经济价值的任何项目，包括但不限于由某一实体拥有、控制或为其利益而持有的、预期将提供未来利益的任何具有经济价值的资源，包括但不限于所有不动产和动产、无形财产、投资、投资权或未来收入权、现金、银行账户、商品、证券、债权、对实体的全部或部分控制权以及预期经济机会。\n\n22. “转让”具有《破产法》第101(54)条赋予该术语的含义。\n\nIV. 应提交的文件\n\n1. 关于债务人、债务人破产财产或关联实体的任何收入或资产的所有文件。\n\n2. 与债务人的财务状况及其对债权人的义务有关的所有文件，包括但不限于与任何规避支付该等义务的努力有关的所有文件，以及与本次或任何其他实际或潜在破产或类似无力偿债程序有关的所有文件。\n\n3. 关于与债务人、债务人破产财产、债务人的家庭成员、关联实体或关联个人有关的任何资产负债表、银行对账单、账户对账单、财务报表、账户报表、电汇指示和/或确认、资金证明、存款证、持仓证明、投资组合摘要或类似文件的所有文件，包括但不限于足以显示向前述任何一方作出的所有转让的所有文件。\n\n4. 关于由债务人作出、与债务人进行或代表债务人作出的任何投资、商业交易或交易事项的所有文件。\n\n5. 与债务人的所有通信，以及与债务人通信有关的文件，该等通信与任何实体的运营、管理或决策有关，包括但不限于关联实体。\n\n6. 关于向债务人、债务人的家庭成员或关联实体作出、由其作出或与其进行的任何转让、投资或其他交易或商业交易的所有文件。\n\n7. 关于债务人曾经占用或使用的任何财产的所有文件，包括但不限于Lady May（Lady May号）；Sherry Netherland Hotel / Condominium（Sherry Netherland酒店／公寓）；位于Connecticut（康涅狄格州）Greenwich（格林尼治）373 Taconic Rd.的住宅物业；位于Connecticut（康涅狄格州）Greenwich（格林尼治）33 Ferncliff Rd.的住宅物业；以及位于Connecticut（康涅狄格州）Wilton（威尔顿）354 Nod Hill Rd.的住宅物业。\n\n案件 22-50073 文书 1592 提交日期 03/24/23 录入日期 03/24/23 10:57:37 第 675 页，共 1063 页\n\n8. 与债务人拥有、控制或使用的任何航空器有关的所有文件，包括但不限于尾号为T7-GQM的航空器及在San Marino（圣马力诺）登记的任何其他航空器，包括但不限于所有登记文件副本，以及显示该等航空器所进行航班及该等航班机上人员的飞行清单。\n\n9. 关于向债务人、债务人破产财产、债务人的家庭成员或关联实体提供、由其提供或代表其提供的任何赠与、利益或贷款的所有文件，包括但不限于足以显示该等赠与、利益或贷款的金额；该等赠与、利益或贷款的用途；提供该等赠与、利益或贷款的时间；以及任何贷款的条款、就任何贷款作出的所有陈述和保证、任何贷款的利率及任何贷款付款的全部证据的文件。\n\n10. 关于由债务人、债务人破产财产、债务人的家庭成员或关联实体设立、代表其设立或为其利益而设立的任何信托或类似文书的所有文件，包括但不限于足以显示该等信托的设立时间、设立人、为谁的利益而设立及信托本金的文件。\n\n11. 与涉及债务人的任何法律争议相关的任何义务、债权、责任或债务有关的所有文件，包括但不限于与任何地方、州、联邦或国际机构前的任何诉讼有关的文件，无论该机构为行政机构、法院、合议庭或替代性争议解决实体。\n\n案件 22-50073 文书 1592 提交日期 03/24/23 录入日期 03/24/23 10:57:37 第 676 页，共 1063 页\n\n12. 贵方的任何外部法律顾问或其他顾问与债务人之间的所有文件和通信。\n\n13. 与贵方持有或曾经持有权益的任何关联实体有关的所有文件。\n\n14. 与债务人之间的所有通信，以及与债务人之间通信有关的文件，该等通信涉及任何法律实体的运营、管理或决策，包括但不限于家庭关联实体和关联实体。\n\n附件 C-37\n\nB2540（表格 2540——依《破产程序规则》第 2004 条进行审查的传票）（12/15）案件 22-50073 文件 1592 于 03/24/23 提交 于 03/24/23 10:57:37 登记 第 678 页，共\n\n美国破产法院\n\n康涅狄格地区\n\n关于 HO WAN KWOK（郭文贵）等人之案，\n\n1 案号 22-50073 (JAM) 债务人 第 11 章\n\n（合并管理）\n依《规则》第 2004 条进行审查的传票\n\n致：Qing \"Serena\" Cai（蔡青“Serena”）\n\n（传票所指向之人员姓名）\n\n证言：现命令你于下列载明的时间、日期和地点出席，根据《联邦破产程序规则》第 2004 条接受审查并作证。随附准许该审查的法院命令副本。\n\n地点　日期和时间\n\nPaul Hastings LLP\n200 Park Avenue　[TBD]\nNew York, New York 10166\n\n审查将通过以下方式记录：法庭书记员/速记员\n\n提交：你或你的代表还必须在审查时携带下列文件、电子存储信息或物品，并允许对该等材料进行检查、复制、测试或取样：\n\n见随附的文件提交请求。\n\n《联邦民事诉讼规则》第 45 条的以下规定，通过《联邦破产程序规则》第 9016 条适用于破产案件，现随附——关于履行地点的第 45(c) 条；关于作为传票对象人员之保护的第 45(d) 条；以及关于你对本传票的答复义务和未答复之潜在后果的第 45(e) 条和第 45(g) 条。\n\n日期：March , 2023\n\n法院书记员\n\n或\n\n书记员或副书记员签名　律师签名\n\n签发或请求本传票的 Luc A. Despins（Luc A. Despins）第 11 章受托人的代理律师姓名、地址、电子邮件地址和电话号码如下：\n\nDouglas S. Skalka, Esq.; Neubert, Pepe & Monteith, P.C.（Neubert, Pepe & Monteith, P.C. 律师事务所）；195 Church Street, New Haven, Connecticut 06510 dskalka@npmlaw.com; (203) 821-2000\n\n致签发或请求本传票之人的通知\n\n如本传票命令在审判前提交文件、电子存储信息或有形物品，或检查场所，则必须在向传票所指向之人送达之前，向每一方送达通知及本传票副本。《联邦民事诉讼规则》第 45(a)(4) 条。\n\n软件版权 (c) 1996-2022 Best Case, LLC（Best Case, LLC）- www.bestcase.com Best Case Bankruptcy 1 本第 11 章案件中的债务人为 Ho Wan Kwok（郭文贵，亦称 Guo Wengui、Miles Guo 和 Miles Kwok，以及众多其他别名）（税务识别号后四位：9595）、Genever Holdings LLC（Genever Holdings LLC）（税务识别号后四位：8202）及 Genever Holdings Corporation（Genever Holdings Corporation）。受托人、Genever Holdings LLC 及 Genever Holdings Corporation 的邮寄地址为 Paul Hastings LLP，200 Park Avenue, New York, NY 10166，转交 Luc A. Despins，作为 Ho Wan Kwok 遗产的受托人（仅用于通知和通信目的）。\n\n送达证明\n\n（除非《联邦民事诉讼规则》第 45 条要求，否则本节不应向法院提交。）\n\n我于（日期）收到向（个人姓名及职务，如有）送达的本传票。\n\n我通过以下方式向所列名人员交付副本而送达本传票：\n\n于（日期）；或\n\n我未执行传票即予退回，原因如下：\n\n除非该传票代表美国或其官员或代理人签发，我还已向证人支付一天出席费用及法律允许的里程费，金额为 \\$。\n\n我的差旅费用为 \\$，服务费用为 \\$，合计 \\$。\n\n我在伪证处罚的约束下声明，该等信息真实且正确。\n\n日期：\n\n送达人员签名\n\n印刷体姓名及职务\n\n送达人员地址\n\n关于尝试送达等的补充信息：\n\n《联邦民事诉讼规则》第 45(c)、(d)、(e) 及 (g) 条（自 12/1/13 生效）（通过《联邦破产程序规则》第 9016 条适用于破产案件）\n\n(c) 履行地点。\n\n(1) 审判、听证或证言录取。传票仅可按如下方式命令某人出席审判、听证或证言录取：\n\n(A) 在该人员居住、受雇或经常亲自从事商业活动地点的 100 英里范围内；或\n\n(B) 在该人员居住、受雇或经常亲自从事商业活动所在州内，前提是该人员\n\n(i) 是一方当事人或一方当事人的高级职员；或\n\n(ii) 被命令出席审判且不会产生重大费用。\n\n(2) 其他证据开示。传票可以命令：\n\n(A) 在该人员居住、受雇或经常亲自从事商业活动地点的 100 英里范围内的某一地点提交文件、电子存储信息或物品；以及\n\n(B) 在待检查的场所进行场所检查。\n\n(d) 对作为传票对象人员的保护；执行。\n\n(1) 避免不当负担或费用；制裁。负责签发和送达传票的一方当事人或律师必须采取合理措施，避免对作为传票对象的人员施加不当负担或费用。要求履行的地区法院必须执行该义务，并对未遵守者的一方当事人或律师施加适当制裁，该制裁可包括损失的收入和合理的律师费。\n\n(2) 命令提交材料或准许检查。\n\n(A) 无须出席。被命令提交文件、电子存储信息或有形物品，或准许检查场所的人员，无须亲自出现在提交或检查地点，除非同时被命令出席证言录取、听证或审判。\n\n(B) 异议。被命令提交文件或有形物品，或准许检查的人员，可以向传票中指定的一方当事人或律师送达书面异议，反对检查、复制、测试或取样全部或部分材料，或反对检查场所，或反对以所请求的一种或多种形式提交电子存储信息。异议必须在规定履行时间届满前或传票送达后 14 天内（以较早者为准）送达。如提出异议，适用以下规则：\n\n(i) 送达方可在任何时候，经通知被命令人员后，向要求履行的地区法院申请强制提交或检查的命令。\n\n(ii) 仅可依命令所指示的方式要求采取该等行为，且该命令必须保护并非一方当事人或一方当事人高级职员的人员，使其免受因履行所产生的重大费用。\n\n(3) 撤销或修改传票。\n\n(A) 必须撤销或修改的情形。经及时动议，要求履行的地区法院必须撤销或修改具有下列情形的传票：\n\n(i) 未给予合理的履行时间；\n\n(ii) 要求某人在第 45(c) 条规定的地域限制之外履行；\n\n(iii) 要求披露享有特权或受其他保护的事项，而不存在适用的例外或豁免；或\n\n(iv) 对某人施加不当负担。\n\n(B) 可以撤销或修改的情形。为保护作为传票对象或受传票影响的人员，如传票要求：\n\n(i) 披露商业秘密或其他保密的研究、开发或商业信息；或\n\n(ii) 披露未受聘专家的意见或信息，且该等意见或信息并非描述争议中的具体事件，而是源于该专家未经一方当事人请求进行的研究，\n\n要求履行的地区法院可依动议撤销或修改传票。\n\n(C) 将规定条件作为替代办法。在第 45(d)(3)(B) 条所述情形下，如送达方：\n\n(i) 证明其对该证言或材料具有重大需要，且不承受不当困难即无法以其他方式满足该需要；以及\n\n(ii) 确保被传唤人员将获得合理补偿，\n\n法院可以不撤销或修改传票，而命令在指定条件下出席或提交。\n\n(e) 答复传票的义务。\n\n(1) 提交文件或电子存储信息。下列程序适用于提交文件或电子存储信息：\n\n(A) 文件。答复要求提交文件的传票的人员，必须按照其在通常业务过程中保存的方式提交文件，或者必须将文件整理并标示，使其与请求中的类别相对应。\n\n(B) 未指定提交电子存储信息的形式。如传票未指定提交电子存储信息的形式，答复人员必须以通常保存该等信息的一种或多种形式，或以一种或多种合理可用的形式提交。\n\n(C) 电子存储信息仅以一种形式提交。答复人员无须以一种以上形式提交相同的电子存储信息。\n\n(D) 无法访问的电子存储信息。答复人员无须从其认定因不当负担或费用而无法合理访问的来源提供电子存储信息的证据开示。就强制证据开示或保护令的动议，答复人员必须证明该信息因不当负担或费用而无法合理访问。如作出该证明，法院仍可在请求方证明具有正当理由时，命令从该等来源进行证据开示，并考虑第 26(b)(2)(C) 条的限制。法院可以规定证据开示的条件。\n\n(2) 主张特权或保护。\n\n(A) 扣留的信息。因主张被传唤信息享有特权或作为审判准备材料受保护而扣留该信息的人员必须：(i) 明确提出该主张；以及\n\n(ii) 以一种在不披露本身享有特权或受保护信息的情况下，能够使各方当事人评估该主张的方式，说明被扣留文件、通信或有形物品的性质。\n\n(B) 已提交的信息。如为答复传票而提交的信息受特权主张或作为审判准备材料受保护主张的约束，提出该主张的人员可以将该主张及其依据通知收到该信息的任何一方当事人。收到通知后，一方当事人必须迅速返还、隔离或销毁所指定的信息及其持有的任何副本；在该主张解决前不得使用或披露该信息；如该方在收到通知前已披露该信息，必须采取合理措施收回该信息；并可迅速将该信息密封提交给要求履行的地区法院，以裁定该主张。提交信息的人员必须在该主张解决前保存该信息。\n\n(g) 藐视法庭。要求履行的地区法院——并且在动议移送后，签发法院亦然——可以认定已被送达但无充分理由不遵守传票或相关命令的人员构成藐视法庭。\n\n关于查阅传票材料，见 Fed.R.Civ.P.45(a) 委员会说明（2013）\n\n……\n\n文件提交请求\n\n一、指示\n\n1. 除非另有说明，下列文件请求（以下简称“请求”，每一项称为“一项请求”）必须分别且具体地予以答复。除非你出于善意提出异议，否则必须完整答复每一项请求；如提出异议，则必须按照下文规定详细说明你提出异议的理由。如异议仅涉及某项请求的一部分，或其中包含的某个词语、短语或条款，你仅须就该部分说明异议，并答复其余请求。\n\n2. 电子存储信息必须按照以下指示提交：\n\na. 图像。黑白图像必须为 300 DPI Group IV 单页 TIFF 文件。彩色图像必须采用 JPEG 格式制作。文件名不得包含嵌入空格或特殊字符（包括逗号）。文件夹名称不得包含嵌入空格或特殊字符（包括逗号）。所有 TIFF 图像文件必须具有唯一文件名，即 Bates 编号。图像必须在每张图像的右下角标注连续的 Bates 编号。每个文件夹中的 TIFF 文件数量不得超过 1000 个。Excel 电子表格应具有以该文件 Bates 编号命名的占位图像。\n\nb. 图像加载文件\n\na. Concordance® 数据文件。数据文件（.DAT）包含将加载到 Concordance® 数据库中的所有字段化信息。.DAT 文件的第一行必须为标识字段名称的标题行。.DAT 文件必须使用以下 Concordance® 默认分隔符：逗号 ASCII 字符（020）引号 þ ASCII 字符（254）。日期字段应以以下格式提供：mm/dd/yyyy。日期和时间字段必须为两个独立字段。如文件包括已成像的电子邮件及附件，必须包括附件字段，以保持电子邮件与其附件之间的父项/子项关系。必须包括 OCRPATH 字段，以提供所提取文本文件在已提供存储介质上的文件路径和名称。文本文件必须以 FIRSTBATES 命名。不得在 .DAT 文件中包含文本。对于带有原生文件的文件，必须包括 LINK 字段，以提供原生文件的文件路径和\n\n名称。原生文件必须以 FIRSTBATES 命名。\n\nb. Concordance Image® 或 Opticon 交叉引用文件。图像交叉引用文件（.LOG 或 .OPT）将图像链接至数据库记录。其应为逗号分隔文件，每行由七个字段组成，数据库中的每个图像均应在交叉引用文件中有一行，并采用以下格式：ImageID,VolumeLabel,ImageFilePath,DocumentBreak,FolderBreak,Box Break,PageCount。\n\nc. 文件文本。文本必须作为独立文本文件提供，而非作为 .DAT 文件内的字段提供。文本文件的完整路径（OCRPATH）应包含在 .DAT 文件中。建议提供以 FIRSTBATES/Image Key 命名的文件级 ANSI 文本文件。提取的文本文件必须置于单独文件夹中，每个文件夹中的文本文件数量不得超过 1,000 个。文件夹名称中不得含有特殊字符（包括逗号）。文本文件必须按文件级别提供。\n\nd. 特定文件类型的原生文件提供。为充分理解其内容及含义而合理需要以原生格式查看的文件类型，必须以原生格式提供。这些文件包括但不限于电子表格、类电子表格文件（Microsoft Excel、逗号分隔值、制表符分隔值等）、Microsoft PowerPoint 或其他特殊演示文件、数据库文件，以及音频/视频文件。提供一张带有 Bates 编号的分隔页图像，注明存在原生文件，并在 .dat 文件中将原生文件路径列为一个字段。所提供的原生文件应以与该文件分隔页相对应的 Bates 编号命名。将原生文件归入按递增方式命名的 “NATIVE” 目录中，与图像目录分开。\n\ne. 去重。对于存在完全重复件的每一电子文件，仅提供一份副本。对于电子邮件，应根据由 BCC、Body、CC、From、IntMsgID、To 和 Attach 属性生成的 MD5 哈希值合并重复件。对于电子邮件附件和独立电子文件，应根据整个文件的 MD5 哈希值合并重复件。\n\nf. 元数据。以符合 Concordance 的加载文件（.dat）形式提供每份文件的提取元数据。.DAT 文件的第一行必须为标识字段名称的标题行。.DAT 文件必须使用以下 Concordance 默认分隔符：逗号 , ASCII 字符（020）引号 þ ASCII 字符（254）。\n\n日期字段应以以下格式提供：mm/dd/yyyy。日期和时间字段必须为两个独立字段。以下列出所需元数据：\n\n案件 22-50073 文件 1592 提交 03/24/23 录入 03/24/23 10:57:37 第 683 页，共 1063 页\n\n字段名称　示例数据　说明\n\nFIRSTBATES　EDC0000001　原生文件文件/电子邮件的第一个 Bates 编号\nLASTBATES　EDC0000001　原生文件文件/电子邮件的最后一个 Bates 编号\nLASTBATES 字段应针对单页填写\nATTACHRANGE　EDC0000001\n-　父文件第一页的 Bates 编号至最后一个附件“子项”文件最后一页的 Bates 编号\nEDC0000015\nBEGATTACH　EDC0000001　附件范围的第一个 Bates 编号\nENDATTACH　EDC0000015　附件范围的最后一个 Bates 编号\nCUSTODIAN　Smith, John　电子邮件：电子邮件所在的邮箱\n原生文件：该文件来源的个人或部门名称\nFROM　John Smith　电子邮件：发件人\n原生文件：文件作者\n应使用分号分隔多个条目\nTO　Coffman, Janice; LeeW　收件人\n[mailto:LeeW@MSN.com]　应使用分号分隔多个条目\nCC　Frank Thompson [mailto:　抄送收件人\nfrank_Thompson@cdt.com]　应使用分号分隔多个条目\nBCC　John Cain　密送收件人\n应使用分号分隔多个条目\nSUBJECT　Board Meeting Minutes　电子邮件：电子邮件主题行 原生文件：文件标题（如有）\nFILE_NAME　BoardMeetingMinutes.docx　原生文件：原始原生文件的名称，包括扩展名\nDATE_SENT　10/12/2010　电子邮件：电子邮件发送日期\n原生文件：（空）\nTIME_SENT/\nTIME_ZONE　07:05 PM GMT　电子邮件：电子邮件发送时间/电子邮件标准化所采用时区内的时间\nTIME_ZONE　GMT　在转换期间电子邮件被标准化所采用的时区。\nLINK　EDC0000001.msg　电子邮件或原生文件文件的超链接\n所链接的文件必须按 FIRSTBATES 编号命名\nFILE_EXTEN　MSG　代表电子邮件或原生文件的文件类型扩展名\nAUTHOR　John Smith　电子邮件：（空）\n原生文件：文件作者\nDATE_CREATED　10/10/2010　电子邮件：（空）\n原生文件：文件创建日期\n\n案件 22-50073 文件 1592 提交 03/24/23 录入 03/24/23 10:57:37 第 684 页，共 1063 页\n\nTIME_CREATED　10:25 AM　电子邮件：（空）\n原生文件：文件创建时间\n该数据必须为独立字段，不得与 DATE_CREATED 字段合并\nDATE_MOD　10/12/2010　电子邮件：（空）\n原生文件：文件最后修改日期\nTIME_MOD　07:00 PM　电子邮件：（空）\n原生文件：文件最后修改时间\n该数据必须为独立字段，不得与 DATE_MOD 字段合并\nDATE_ACCESSD　10/12/2010　电子邮件：（空）\n原生文件：文件最后访问日期\nTIME_ACCESSD　07:00 PM　电子邮件：（空）\n原生文件：文件最后访问时间\n该数据必须为独立字段，不得与 DATE_ACCESSD 字段合并\nFILE_SIZE　5,952　原生文件文件/电子邮件的大小，以 KB 计\nPGCOUNT　1　原生文件文件/电子邮件的页数\nPATH　电子邮件：（空）\nAgenda.doc　原生文件：存储原生文件文件的路径，包括原始文件名。\nINTFILEPATH　Personal Folders\\Deleted　电子邮件：电子邮件的原始位置，包括原始文件名。\nItems\\Board Meeting\nMinutes.msg　原生文件：（空）\nINTMSGID　<000805c2c71b\\$75977050\\$　电子邮件：唯一邮件 ID 原生文件：（空）\ncb8306d1@MSN>\nMD5HASH　d131dd02c5e6eec4693d9a0　文件的 MD5 哈希值。\n698aff95c\n2fcab58712467eab4004583e\nb8fb7f89\nOCRPATH　TEXT/001/EDC0000001.txt　原生文件提取文本的路径\n\n3. 每项请求均独立运作并应独立解释，除非另有说明，任何一项请求均不限制任何其他请求的范围。\n\n4. 所有文件均应按通常业务过程中保存的方式提供，或应组织并标注以对应这些请求中的类别。\n\n5. 本文所含每项请求均延伸至所有文件：（a）由您占有、保管或控制的文件；或（b）由代表您行事的任何人占有、保管或控制的文件，\n\n案件 22-50073 文件 1592 提交 03/24/23 录入 03/24/23 10:57:37 第 685 页，共 1063 页\n\n包括您的律师或其他代表及顾问。每份文件均应完整提供。\n\n6. 如要求您提供一份已不再由您占有、保管或控制的文件，则您的答复必须：（a）详细说明该文件的性质及内容；（b）确认制作或撰写该文件的人员（以及，如适用，该文件被发送给的人员）；（c）确认该文件制作或创建的日期；（d）说明该文件是否：（i）遗失或丢失；（ii）已被销毁；（iii）已自愿或非自愿地转移给他人；或（iv）以其他方式被处置；（e）说明该等处置的原因，以及围绕该等处置的事实和情形；（f）确认授权该等处置的人员；（g）确认该等处置的日期或大致日期；（h）说明该文件最近一次由您占有、保管或控制的时间；以及（i）确认目前占有、保管或控制该文件的人员（如有）。\n\n7. 如要求您提供一份已被销毁的文件，则除前述指示所要求的信息外，您的答复还必须说明：（a）该文件被销毁的原因；（b）销毁该文件的人员身份；以及（c）指示销毁该文件的人员身份。\n\n8. 如您主张所要求的文件享有特权或律师工作成果保护，则您的答复必须：（a）说明：（i）足以支持您关于该文件享有特权之主张的文件描述；（ii）该文件的标题；（iii）该文件的日期；（iv）该文件的作者；（v）该文件的收件人；（vi）收到或阅览该文件原件或任何草稿、副本或复制件的每一人员身份；（vii）该文件本身，或该文件所含或提及的任何信息，是否由任何其他人员占有、保管或控制；如是，则确认该等人员身份，并说明该等信息如何由其取得；\n\n案件 22-50073 文件 1592 提交 03/24/23 录入 03/24/23 10:57:37 第 686 页，共 1063 页\n\n（viii）据以扣留该文件的特权主张；以及（ix）您将依赖以支持该等特权主张的所有情形；以及（b）根据 D. Conn. L. Civ. R. 26(e)，针对基于特权主张而扣留的每份文件，制作一份特权日志，其中包含本指示第（a）部分要求的所有信息。\n\n9. 如一份原本应予答复的文件的一部分包含受特权主张约束的信息，则仅应按照上述指示从该文件中删除或遮盖受特权主张约束的部分，其余部分应予提供。\n\n10. 各项请求具有持续性。特此指示您：（a）一旦得知先前答复不完整或不正确，立即补充或更正任何后来得知不完整或不正确的答复；以及（b）提供根据以下内容所要求的任何补充文件\n\n11. 如文件为英语以外的语言，您应提供该文件。如文件为英语以外的语言且存在英文译文，您应同时提供两份文件。\n\n12. 对实体的所有提及均包括其所有关联方。\n\n13. 对个人姓名的所有提及均包括所有其他姓名、别名或昵称。\n\n14. 除非另有明确说明，文件请求所涵盖的期间为自 February 5, 2012 起至文件请求答复到期之日止。\n\n案号 22-50073 文件 1592 于 03/24/23 提交 于 03/24/23 10:57:37 登记 第 687 页，共 1063 页\n\nII. 解释规则\n\n15. （a）任何单数名词的使用应解释为包括复数，反之亦然；（b）任何时态动词的使用应解释为该动词在所有其他时态中的使用。\n\n16. （a）“and”和“or”应视需要解释为连词或选择词，以使任何请求的范围涵盖所有原本可能被解释为超出其范围的答复；（b）“each”和“any”应视为包括并涵盖“every”和“all”二词。\n\nIII. 定义\n\n经 D. Conn. Bankr. L.R. 2004-1(a) 纳入的 D. Conn. L. Civ. R. 26(c) 所规定的定义，以及 D. Conn. L. Civ. R. 26(d) 所规定的解释规则，适用于文件请求。此外，本文件请求中使用的下列术语具有以下含义：\n\n1. “You”、“Your”或“Yourself”系指 Qing “Serena” Cai（蔡青“Serena”），以及其所有代理人、律师、代表、雇员和/或任何代表其行事之人。\n\n2. “Debtor”系指 Ho Wan Kwok（郭文贵，亦称 Miles Kwok、Miles Guo、Guo Wengui、Guo Haoyun、郭文贵或任何其他别名），以及其雇员、代理人、律师、顾问或任何代表其行事之人。\n\n3. “Debtor's Son”系指 Qiang Guo（郭强，亦称 Mileson Kwok、郭强或任何其他别名），以及其雇员、代理人、律师、顾问或任何代表其行事之人。\n\n4. “Debtor's Daughter”系指 Mei Guo（郭美，亦称 Mei Gui、郭美或任何其他别名），以及其雇员、代理人、律师、顾问或任何代表其行事之人。\n\n案号 22-50073 文件 1592 于 03/24/23 提交 于 03/24/23 10:57:37 登记 第 688 页，共 1063 页\n\n5. “Debtor's Purported Wife”系指 Hing Chi Ngok（岳庆芝，亦称 Hing Chi Ng、Yue Qingzhi、岳庆芝或任何其他别名），以及其雇员、代理人、律师、顾问或任何代表其行事之人。\n\n6. “Debtor's Family”统称债务人、债务人之子、债务人之女及债务人所谓的妻子，以及与债务人具有任何其他亲属关系的人。\n\n7. “Associated Individuals”单独及统称指以下所有个人：（1）持有、控制、保管或对债务人或债务人家庭拥有、控制或享有的资产具有处置权；或（2）曾为一个或多个关联实体的雇员、董事，或以其他方式与一个或多个关联实体有关联；并包括前述任何人员各自的雇员、代理人、律师、顾问或任何代表其行事之人。此类关联个人包括但不限于：Daniel Podhaskie、Jason Miller、Steve Bannon、Karin Maistrello、Melissa Francis、Anthony DiBattista、William Gertz、Arethusa Forsyth、Glenn Mellor、Jennifer Mercurio、Eduardo Eurnekian、Wencong Wang、Han Chunguang（亦称 韩春光）、Qu Guojiao（亦称 Qu Guo Jiao、屈国姣）、Guo Lijie（亦称 郭丽杰）、Zhang Wei（亦称 张伟*）、Lihong Wei Lafrenz（亦称 Sara Wei、魏丽红）、Hao Haidong（亦称 郝海东）、Ross Heinemeyer、Max Krasner、Kyle Bass、Melissa Mendez、Ya Li（亦称 李娅）、Dinggang Wang（亦称 王定刚）、An Hong（亦称 安红）、Yvette Wang（亦称 Yanping Wang、Yan Ping Wang、王雁平）、Fiona Yu、Je Kin Ming（亦称 William Je、Yu Jianming、余建明）、Yaz Qingua，以及 Lao Jiang（亦称 Jiang Yunfu、Jiang Yunfu Be、姜云浮）。\n\n8. “Associated Entities”单独及统称指以下所有类型的组织或实体：（1）曾由债务人或\n\n案号 22-50073 文件 1592 于 03/24/23 提交 于 03/24/23 10:57:37 登记 第 689 页，共 1063 页\n\n债务人家庭拥有、控制或投资的；或（2）直接或间接对债务人或债务人家庭拥有、控制或享有的任何资产享有权益的；并包括前述任何实体各自的雇员、代理人、律师、顾问或任何代表其行事之人。此类关联实体包括但不限于：7 Nod Hill LLC、AAGV Limited、ACA Investment Management Limited、ACA Capital Group Limited、Ace Decade Holdings Limited、AI Group Holdings Inc.、Alfa Global Ventures Limited、Alfonso Global Limited、Allied Capital Global Limited、Alpine Fiduciaries SA、Anton Development Limited、Assets Sino Limited、Auspicious Coast Limited、Beijing Pangu Investment Co.、Beijing Pangu Investment Co. Ltd.、Beijing Pangu Investment Inc.、Beijing Zenith Holdings Company Limited、Booming Sail New York LLC、Bravo Luck Limited、BSA Strategic Fund I、China Golden Spring (Hong Kong) Limited、Chuang Xin Limited、Crane Advisory Group LLC、Creative Apex Investments Limited、Crystal Breeze Investments Limited、Dawn State Limited、Eastern Profit Corporation Limited、Elite Well Global Limited、Empire Growth Holdings、Freedom Media Ventures Ltd.、G Club Operations LLC、G Fashion LLC、G News LLC、GETTR USA、Genever Holdings Corporation、Genever Holdings LLC、Gfashion Media Group Inc.、GFNY, Inc.、Globalist International Limited、GNews Media Group Inc.、Golden Spring (New York) Ltd.、Greenwich Land LLC、Guo Media、GTV Media Group, Inc.、Hamilton Capital Holdings Inc.、HCHK Property Management, Inc.、HCHK Technologies, Inc.、Head Win Group Limited、Henan Yuda、Himalaya Embassy、Himalaya Exchange、Himalaya Federal Reserve、Himalaya Investment LLC、Himalaya International、Himalaya New World Inc.、Himalaya Supervisory Organization、Himalaya Ventures LLC、HK International Funds Investments (USA) Limited LLC、Hong Kong International Funds Investments Limited、Hudson Diamond Holding、Infinite Increase Limited、Infinitum Developments Limited、Infinity Treasury Management Inc.、Insight Phoenix Fund、Lamp Capital\n\n案号 22-50073 文件 1592 于 03/24/23 提交 于 03/24/23 10:57:37 登记 第 690 页，共 1063 页\n\nLLC、Leading Shine Limited、Leading Shine NY Limited、Lexington Property and Staffing、Long Gate Limited、Maywind Trading LLC、MOS Himalaya LLC、Next Tycoon Investments Limited、New Federal State of China（亦称 NFSC）、Noble Fame Global Limited、Rosy Acme Ventures Limited、Rule of Law Foundation III, Inc.、Rule of Law Foundation IV, Inc.、Rule of Law Fund、Rule of Law Society、Rule of Law Society IV, Inc.、G-Translators PTY LTD、Saraca Media Group, Inc.、Shiny Ace Ltd.、Shiny Times Holdings Ltd.、Spirit Charter Investment Limited、Stevenson, Wong & Co.、Voice of Guo Media, Inc.、Well Origin Ltd.、World Century Limited、Worldwide Opportunity Holdings Limited、Whitecroft Shore Limited，以及 ZIBA Limited。\n\n9. “Including”或其任何变体，意指“包括但不限于”。\n\n10. “And”和“or”意指“and/or”，并应同时解释为连词和选择词，以最大限度扩大其范围。\n\n11. “Any”、“all”和“each”意指“每一个及所有”。\n\n12. “Each”和“every”意指“每一个及所有”。\n\n13. “Third Party”系指除您本人以外的个人或实体。\n\n14. “Transfer”应具有《破产法》第 101(54) 条所赋予的含义。\n\n15. “Document”系指属于 Fed. R. Civ. P. 34 范围内的任何信息或物品，并包括但不限于在您的占有、保管或控制之下或曾在您的占有、保管或控制之下的各种、各类、各种性质或描述的每一项书面、记录或图形资料，包括电子邮件的所有纸质及电子副本、以电子形式保存的计算机文件、电子通信、短信、社交媒体帖子、推文、元数据、通信函件、备忘录、磁带、速记或手写笔记、任何种类的书面表格、图表、蓝图、图纸、草图、曲线图、计划、文章、规格说明、日记、信函、电报、照片、会议记录、合同、协议、调查资料、计算机打印件、任何种类的数据汇编、电传、传真、语音留言、发票、订单表、支票、汇票、对账单、贷项通知单、报告、仓位报告、摘要、索引、账簿、分类账、笔记本、附表、透明胶片、录音、目录、广告、宣传材料、胶片、录像带、录音带、CD、计算机磁盘、宣传册、小册子、穿孔卡、工时单、推文、社交媒体帖子或任何其他种类的书面或记录材料，以及其所有元数据，无论以何种方式存储（无论为有形或电子形式）、记录、制作或复制；还包括但不限于前述任何材料的草稿或副本，如其含有原始文件中不存在的任何种类笔记、评论或标记，或在其他方面与原始文件不完全相同。\n\n案号 22-50073 文件 1592 于 03/24/23 提交 于 03/24/23 10:57:37 登记 第 691 页，共 1063 页\n\n16. “Person(s)”系指个人、公司、独资企业、合伙企业、协会或任何其他实体。“Person”还包括任何代理人、代表或专家，包括但不限于律师或财务顾问。\n\n17. “Entity”系指任何自然人、公司、合伙企业、子公司、独资企业、商号、董事会、合资企业、协会、机构、机关、委员会或其他商业实体或法人，以及任何关联方、代理人、母公司，包括但不限于法律顾问、财务顾问或任何其他代表。\n\n18. “Regarding”系指有关、描述、构成、提及、与之相关、支持、赞成、反对、强化、贬损、位于其中、结合其加以考虑、对其具有影响、证明、表明、报告、记录、暗指、答复、与之相连、评论、就其而言、关于、与之有关、讨论、显示、描述、反映、分析、构成及为。\n\n案号 22-50073 文件 1592 于 03/24/23 提交 于 03/24/23 10:57:37 登记 第 692 页，共 1063 页\n\n19. 在指称任何特定事项时，“Relating to”、“relate(s) to”或“related to”系指但不限于构成、包含、涉及、含有、体现、反映、识别、陈述、直接或间接提及或以任何方式与所识别的特定事项相关的任何文件。\n\n20. “Communication(s)”在最广泛的含义上且不限于此，系指任何信息或知识的传递（以事实、想法、询问或其他形式）。通信还指所有谈话、协议、询问或答复，无论是当面、通过电话、书面方式，还是借助电子传输设备进行，并包括但不限于所有通信函件、电子邮件、录音、传送单、备忘录、电话通信、语音留言、电报、电话传真、复印传真、电传、即时消息、聊天、短信、电话笔记，或在内部或与第三方之间传递的笔记。\n\n21. “Asset(s)”系指可用于产生正经济价值的任何项目，包括但不限于由某一实体拥有、控制或为其利益而持有，并预期提供未来利益的任何具有经济价值的资源，包括但不限于所有不动产和动产、无形财产、投资、投资权或未来收入权、现金、银行账户、商品、证券、债权、对实体的全部或部分控制权，以及预期经济机会。\n\n22. “Transfer”应具有《破产法》第 101(54) 条所赋予的含义。\n\nIV. 应提交的文件\n\n1. 有关债务人、债务人破产财产或关联实体任何收入或资产的所有文件。\n\n案号 22-50073 文件 1592 于 03/24/23 提交 于 03/24/23 10:57:37 登记 第 693 页，共 1063 页\n\n2. 与债务人的财务状况及其对债权人所负义务有关的所有文件，包括但不限于与任何规避支付该等义务的努力有关的所有文件，以及与本次或任何其他实际或可能发生的破产或类似无力偿债程序有关的所有文件。\n\n3. 关于与债务人、债务人财产、债务人家属、关联实体或关联个人有关的任何资产负债表、银行对账单、账户对账单、财务报表、账户结单、电汇指示和/或确认函、资金证明、存款证明、持仓证明、投资组合摘要或类似文件的所有文件，包括但不限于足以显示向前述任何一方进行的所有转移的所有文件。\n\n4. 关于由债务人作出、与债务人进行或代表债务人作出的任何投资、商业往来或交易的所有文件。\n\n5. 与债务人的所有通信，以及与债务人的通信有关的文件，涉及任何实体的运营、管理或决策，包括但不限于关联实体。\n\n6. 关于向债务人、债务人家属或关联实体作出、由其作出或与其进行的任何转移、投资或其他交易或商业往来的所有文件。\n\n7. 关于债务人曾占用或使用的任何财产的所有文件，包括但不限于 Lady May；Sherry Netherland Hotel / Condominium；位于 Connecticut（康涅狄格州）Greenwich（格林尼治）373 Taconic Rd. 的住宅房产；位于 Connecticut（康涅狄格州）Greenwich（格林尼治）33 Ferncliff Rd. 的住宅房产；以及位于 Connecticut（康涅狄格州）Wilton（威尔顿）354 Nod Hill Rd. 的住宅房产。\n案号 22-50073 文件 1592 提交日期 03/24/23 录入日期 03/24/23 10:57:37 第 694 页，共 1063 页\n\n8. 与债务人拥有、控制或使用的任何航空器有关的所有文件，包括但不限于尾号为 T7-GQM 的航空器以及在 San Marino（圣马力诺）登记的任何其他航空器，包括但不限于所有登记文件及飞行舱单副本，该等文件显示该等航空器所进行的航班及该等航班上的人员。\n\n9. 关于向债务人、债务人财产、债务人家属或关联实体提供、由其提供或代表其提供的任何赠与、利益或贷款的所有文件，包括但不限于足以显示该等赠与、利益或贷款金额的文件；该等赠与、利益或贷款的使用目的；提供该等赠与、利益或贷款的时间；以及任何贷款的条款、就任何贷款作出的所有陈述与保证、任何贷款的利率以及任何贷款付款的所有证据。\n\n10. 关于由债务人、债务人财产、债务人家属或关联实体设立、代表其设立或为其利益设立的任何信托或类似文书的所有文件，包括但不限于足以显示该等信托设立时间、设立人、设立受益人以及信托本金的文件。\n\n11. 与涉及债务人的任何法律争议有关的任何义务、请求权、责任或债务的所有文件，包括但不限于与任何地方、州、联邦或国际机构之前的任何诉讼有关的文件，无论该机构为行政机构、法院、合议庭或替代性争议解决实体。\n\n12. 你方任何外部律师或其他顾问与债务人之间的所有文件和通信。\n\n13. 与你方目前或曾经持有权益的任何关联实体有关的所有文件。\n案号 22-50073 文件 1592 提交日期 03/24/23 录入日期 03/24/23 10:57:37 第 695 页，共 1063 页\n\n14. 与债务人的所有通信，以及与债务人的通信有关的文件，涉及任何法人实体的运营、管理或决策，包括但不限于家族关联实体和关联实体。\n附件 C-38\nB2540（表格 2540－Rule 2004 审查传票）（12/15）案号 22-50073 文件 1592 提交日期 03/24/23 录入日期 03/24/23 10:57:37 第 697 页，共\n\nUNITED STATES BANKRUPTCY COURT（美国破产法院）\n\nDistrict of Connecticut（康涅狄格区）\n\n关于 HO WAN KWOK（郭文贵）等人之案，\n\n1 案号 22-50073 (JAM) 债务人 第 11 章\n\n（联合管理）\nRule 2004 审查传票\n\n致：Ding G. Wang a/k/a Dinggang Wang（王定刚）\n\n（传票所指向人员的姓名）\n\n证言：兹命令你于下列规定的时间、日期和地点出席，并根据《联邦破产程序规则》Rule 2004 接受审查并作证。随附授权该审查的法院命令副本。\n\n地点　日期和时间\n\nPaul Hastings LLP（博钦律师事务所）\n200 Park Avenue　[TBD]\nNew York, New York 10166（纽约州纽约市 10166）\n\n审查将通过以下方式记录：法庭书记员/速记员\n\n提交：你或你的代表还必须携带下列文件、电子存储信息或物品参加审查，并必须允许对该等材料进行查验、复制、测试或取样：\n见随附的文件提交请求。\n\n《联邦民事诉讼规则》Fed. R. Civ. P. 45 的下列规定，经《联邦破产程序规则》Fed. R. Bankr. P. 9016 适用于破产案件，现随附：有关履行地点的 Rule 45(c)；有关你作为受传票约束人员之保护的 Rule 45(d)；以及有关你对本传票的答复义务及不答复可能后果的 Rule 45(e) 和 45(g)。\n\n日期：March , 2023\n\n法院书记员\n\n或\n\n书记员或副书记员签名　律师签名\n\n签发或请求本传票、代表第 11 章受托人 Luc A. Despins（卢克·A·德斯平斯）的律师的姓名、地址、电子邮件地址和电话号码如下：\n\nDouglas S. Skalka, Esq.（道格拉斯·S·斯卡尔卡律师）；Neubert, Pepe & Monteith, P.C.（纽伯特、佩佩及蒙泰斯律师事务所）；195 Church Street, New Haven, Connecticut 06510（康涅狄格州纽黑文市教堂街195号）dskalka@npmlaw.com；(203) 821-2000\n\n致签发或请求本传票之人的通知\n\n如本传票命令在审判前提交文件、电子存储信息或有形物品，或检查场所，则必须在向被指向人员送达本传票之前，向各方送达通知及本传票副本。Fed. R. Civ. P. 45(a)(4)。\n\n软件版权 (c) 1996-2022 Best Case, LLC（最佳案例有限责任公司）- www.bestcase.com Best Case Bankruptcy 1 本第 11 章案件中的债务人为 Ho Wan Kwok（郭文贵）（亦称 Guo Wengui、Miles Guo 和 Miles Kwok，以及众多其他别名）（税务识别号码后四位：9595）、Genever Holdings LLC（税务识别号码后四位：8202）及 Genever Holdings Corporation。受托人、Genever Holdings LLC 和 Genever Holdings Corporation 的邮寄地址为 Paul Hastings LLP（博钦律师事务所），200 Park Avenue, New York, NY 10166 c/o Luc A. Despins，作为 Ho Wan Kwok（郭文贵）财产的受托人（仅为通知和通信之目的）。\n\n送达证明\n\n（除非 Fed. R. Civ. P. 45 要求，否则本部分不应向法院提交。）\n\n我于（日期）收到向（个人姓名及职务，如有）送达的本传票。\n\n我通过如下方式向被列名人员交付副本以送达传票：\n\n于（日期）；或\n\n我未执行而退回本传票，原因是：\n\n除非本传票代表 United States（美国）或其官员或代理人签发，我还已向证人支付一天出席费用及法律允许的里程费，金额为 $ 。\n\n我的差旅费用为 $，服务费用为 $，合计 $。\n\n我在伪证处罚下声明，本信息真实且正确。\n\n日期：\n\n送达人签名\n\n正楷姓名及职务\n\n送达人地址\n\n有关尝试送达等的补充信息：\n《联邦民事诉讼规则》Rule 45(c)、(d)、(e) 和 (g)（自 12/1/13 起生效）（经《联邦破产程序规则》Rule 9016 适用于破产案件）\n(c) 履行地点。\n\n(1) 审判、听证或证言记录。传票仅可按下列方式命令某人出席审判、听证或证言记录：\n\n(A) 在该人居住、受雇或经常亲自办理业务地点 100 英里以内；或\n\n(B) 在该人居住、受雇或经常亲自办理业务所在州内，如该人\n\n(i) 为当事人或当事人的高级职员；或\n\n(ii) 被命令出席审判且不会产生重大费用。\n\n(2) 其他证据开示。传票可命令：\n\n(A) 在该人居住、受雇或经常亲自办理业务地点 100 英里以内的地点提交文件、电子存储信息或物品；以及\n\n(B) 在待检查场所对该场所进行检查。\n(d) 对受传票约束人员的保护；执行。\n\n(1) 避免不当负担或费用；制裁。负责签发和送达传票的当事人或律师必须采取合理措施，避免对受传票约束人员施加不当负担或费用。要求履行义务地区的法院必须执行该义务，并对未遵守者的当事人或律师施加适当制裁，该制裁可包括损失的收入和合理的律师费。\n(2) 命令提交材料或允许检查。\n\n(A) 无须出席。被命令提交文件、电子存储信息或有形物品，或允许检查场所的人员，无须亲自出席提交或检查地点，除非同时被命令出席证言记录、听证或审判。\n\n(B) 异议。被命令提交文件或有形物品或允许检查的人员，可以向传票中指定的当事人或律师送达书面异议，反对检查、复制、测试或取样任何或全部材料，或反对检查场所，或反对以所请求的一种或多种形式提交电子存储信息。异议必须在规定履行时间或传票送达后 14 天两者中较早者之前送达。如提出异议，适用以下规则：\n\n(i) 送达方可随时在通知被命令人员后，向要求履行义务地区的法院申请强制提交或检查的命令。\n\n(ii) 仅可依命令所指示要求实施该等行为，且该命令必须保护既非当事人亦非当事人高级职员的人员，免受因履行而产生的重大费用。\n(3) 撤销或修改传票。\n\n(A) 必须撤销或修改的情形。根据及时提出的动议，要求履行义务地区的法院必须撤销或修改存在下列情形的传票：\n\n(i) 未给予合理的履行时间；\n\n(ii) 要求某人在 Rule 45(c) 规定的地理范围以外履行；\n\n(iii) 要求披露享有特权或受其他保护的事项，且不存在适用的例外或豁免；或\n\n(iv) 对某人造成不当负担。\n\n(B) 可撤销或修改的情形。为保护受传票约束或受其影响的人员，要求履行义务地区的法院可经动议，在传票要求下列事项时撤销或修改传票：\n\n(i) 披露商业秘密或其他保密研究、开发或商业信息；或\n\n(ii) 披露未经聘用的专家的意见或信息，该等意见或信息不描述争议中的具体事件，且源于任何当事人未请求的该专家研究。\n\n(C) 以规定条件作为替代。在 Rule 45(d)(3)(B) 所述情形下，如送达方：\n\n(i) 证明其对该证言或材料具有重大需要，且不遭受不当困难即无法以其他方式满足该需要；且\n\n(ii) 确保向受传票约束人员提供合理补偿，\n\n法院可不撤销或修改传票，而命令其在规定条件下出席或提交材料。\n(e) 答复传票的义务。\n\n(1) 提交文件或电子存储信息。下列程序适用于提交文件或电子存储信息：\n\n(A) 文件。答复要求提交文件的传票的人员，必须按该等文件在日常业务过程中保存的方式提交，或者必须将其整理并标注，使之与请求中的类别相对应。\n\n（B）未指定的电子存储信息出示形式。如传票未指定电子存储信息的出示形式，作出回应的人必须以其通常保存的一种或多种形式，或以一种或多种合理可用的形式出示该信息。\n\n（C）仅以一种形式出示的电子存储信息。作出回应的人无需以一种以上的形式出示相同的电子存储信息。\n\n（D）不可访问的电子存储信息。作出回应的人无需从其认定因不当负担或费用而无法合理访问的信息源中提供电子存储信息的证据开示。在提出强制证据开示动议或保护令动议时，作出回应的人必须证明该信息因不当负担或费用而无法合理访问。如作出该证明，法院在考虑 Rule 26(b)(2)(C) 的限制后，如请求方证明存在正当理由，仍可命令从该等信息源进行证据开示。法院可规定证据开示的条件。\n\n（2）主张特权或保护。\n\n（A）被扣留的信息。根据该信息享有特权或作为审判准备材料受到保护的主张而扣留被传唤信息的人必须：（i）明确提出该主张；并且\n\n（ii）以一种在不披露本身享有特权或受保护的信息的情况下，能够使各方评估该主张的方式，说明被扣留文件、通信或有形物品的性质。\n\n（B）已出示的信息。如为回应传票而出示的信息受到特权主张或作为审判准备材料受保护的主张所约束，提出该主张的人可将该主张及其依据通知收到该信息的任何一方。收到通知后，一方必须立即返还、隔离或销毁所指明的信息及其持有的任何副本；在该主张得到解决之前，不得使用或披露该信息；如该方在收到通知前已披露该信息，必须采取合理措施追回该信息；并可立即将该信息密封提交给要求履行义务所在地区的法院，以裁定该主张。出示该信息的人必须在该主张得到解决前保存该信息。\n\n（g）藐视法庭。要求履行义务所在地区的法院——以及在动议被移送后，发出传票的法院——可认定已被送达但无充分理由不遵守传票或相关命令的人构成藐视法庭。\n\n关于查阅传票材料，参见 Fed.R.Civ.P.45(a) Committee Note (2013)\n\n……\n\n文件出示请求\n\nI. 指示\n\n1. 除非另有说明，下列文件请求（“请求”，单项称“一项请求”）必须分别且具体地作出回应。每项请求均应得到完整答复，除非基于善意提出异议；如提出异议，则应如下文所述详细说明贵方异议的理由。如异议仅涉及某项请求的一部分，或其中包含的某一词语、短语或条款，贵方仅须就该部分陈述异议，并对请求的其余部分作出回应。\n\n2. 电子存储信息必须依照下列指示出示：\n\na. 图像。黑白图像必须为 300 DPI Group IV 单页 TIFF 文件。彩色图像必须以 JPEG 格式出示。文件名不得包含嵌入式空格或特殊字符（包括逗号）。文件夹名称不得包含嵌入式空格或特殊字符（包括逗号）。所有 TIFF 图像文件必须具有唯一文件名，即 Bates 编号。每幅图像右下角必须标注连续的 Bates 编号。每个文件夹中的 TIFF 文件数量不应超过 1000 个文件。Excel 电子表格应具有以该文件的 Bates 编号命名的占位图像。\n\nb. 图像加载文件\n\na. Concordance® 数据文件。数据文件（.DAT）包含将加载至 Concordance® 数据库的全部字段信息。.DAT 文件的第一行必须为标明字段名称的标题行。.DAT 文件必须使用下列 Concordance® 默认分隔符：逗号 ASCII 字符（020）引号 þ ASCII 字符（254）。日期字段应采用下列格式：mm/dd/yyyy。日期和时间字段必须为两个独立字段。如文件包括已成像的电子邮件及附件，则必须包括附件字段，以保留电子邮件与其附件之间的父项/子项关系。必须包括 OCRPATH 字段，以提供所出示存储介质上提取文本文件的文件路径和名称。文本文件必须以 FIRSTBATES 命名。不得在 .DAT 文件中包含文本。对于具有原生文件的文件，必须包括 LINK 字段，以提供原生文件的文件路径和名称。原生文件必须以 FIRSTBATES 命名。\n\nb. Concordance Image® 或 Opticon 交叉引用文件。图像交叉引用文件（.LOG 或 .OPT）将图像链接至数据库记录。该文件应为以逗号分隔的文件，每行包含七个字段，并且数据库中的每幅图像均应在交叉引用文件中有一行，格式如下：ImageID,VolumeLabel,ImageFilePath,DocumentBreak,FolderBreak,Box Break,PageCount。\n\nc. 文件文本。文本必须作为独立文本文件出示，而不得作为 .DAT 文件内的字段。通往文本文件的完整路径（OCRPATH）应包含在 .DAT 文件中。建议提供以 FIRSTBATES/Image Key 命名的文件级 ANSI 文本文件。提取的文本文件必须置于单独的文件夹中，每个文件夹中的文本文件数量不应超过 1,000 个文件。文件夹名称中不得有特殊字符（包括逗号）。文本文件必须按文件级别提供。\n\nd. 某些文件类型的原生文件出示。为完整理解其内容和含义而合理需要以原生格式查看的文件类型，必须以原生格式出示。这些文件包括但不限于电子表格、类似电子表格的文件（Microsoft Excel、逗号分隔值、制表符分隔值等）、Microsoft PowerPoint 或其他特殊演示文稿文件、数据库文件以及音频/视频文件。提供一张带有 Bates 编号的分隔页图像，表明存在原生文件，并在 .dat 文件中将通往原生文件的路径作为字段列入。所出示的原生文件应以对应于该文件分隔页的 Bates 编号命名。将原生文件归入按递增方式命名的“NATIVE”目录中，并与图像目录分开。\n\ne. 去重。对于存在完全重复件的每份电子文件，出示一份副本。对于电子邮件，根据从 BCC、Body、CC、From、IntMsgID、To 和 Attach 属性生成的 MD5 哈希值合并重复件。对于电子邮件附件和独立电子文件，根据整个文件的 MD5 哈希值合并重复件。\n\nf. 元数据。以符合 Concordance 标准的加载文件（.dat）形式，为每份文件出示提取的元数据。.DAT 文件的第一行必须为标明字段名称的标题行。.DAT 文件必须使用下列 Concordance 默认分隔符：逗号 , ASCII 字符（020）引号 þ ASCII 字符（254）\n\n日期字段应采用下列格式：mm/dd/yyyy。日期和时间字段必须为两个独立字段。下列为必需的元数据：\n\nCase 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 702 of 1063\n\n字段名称　示例数据　说明\n\nFIRSTBATES　EDC0000001　原生文件文件/电子邮件的第一个 Bates 编号\n\nLASTBATES　EDC0000001　原生文件文件/电子邮件的最后一个 Bates 编号\n\n对于单页文件，应填写 LASTBATES 字段\n\nATTACHRANGE　EDC0000001\n-　父项文件第一页的 Bates 编号至最后一个附件“子项”文件最后一页的 Bates 编号\nEDC0000015\n\nBEGATTACH　EDC0000001　附件范围的第一个 Bates 编号\n\nENDATTACH　EDC0000015　附件范围的最后一个 Bates 编号\n\nCUSTODIAN　Smith, John　电子邮件：电子邮件所在的邮箱\n原生文件：文件源自其文件的个人或部门名称\n\nFROM　John Smith　电子邮件：发件人\n原生文件：文件作者\n多个条目应以分号分隔\n\nTO　Coffman, Janice; LeeW　收件人\n[mailto:LeeW@MSN.com]　多个条目应以分号分隔\n\nCC　Frank Thompson [mailto:　抄送收件人\nfrank_Thompson@cdt.com]　多个条目应以分号分隔\n\nBCC　John Cain　密送收件人\n多个条目应以分号分隔\n\nSUBJECT　Board Meeting Minutes　电子邮件：电子邮件主题行 原生文件：文件标题（如有）\n\nFILE_NAME　BoardMeetingMinutes.docx　原生文件：原始原生文件名称，包括扩展名\n\nDATE_SENT　10/12/2010　电子邮件：电子邮件发送日期\n原生文件：（空）\n\nTIME_SENT/\nTIME_ZONE　07:05 PM GMT　电子邮件：电子邮件发送时间/电子邮件标准化所使用的时区\n\nTIME_ZONE　GMT　在转换过程中电子邮件被标准化所使用的时区。\n\nLINK　EDC0000001.msg　电子邮件或原生文件文件的超链接\n链接文件必须以 FIRSTBATES 编号命名\n\nFILE_EXTEN　MSG　代表电子邮件或原生文件的文件类型扩展名\n\nAUTHOR　John Smith　电子邮件：（空）\n原生文件：文件作者\n\nDATE_CREATED　10/10/2010　电子邮件：（空）\n原生文件：文件创建日期\n\nCase 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 703 of 1063\n\nTIME_CREATED　10:25 AM　电子邮件：（空）\n原生文件：文件创建时间\n该数据必须为独立字段，不得与 DATE_CREATED 字段合并\n\nDATE_MOD　10/12/2010　电子邮件：（空）\n原生文件：文件最后修改日期\n\nTIME_MOD　07:00 PM　电子邮件：（空）\n原生文件：文件最后修改时间\n该数据必须为独立字段，不得与 DATE_MOD 字段合并\n\nDATE_ACCESSD　10/12/2010　电子邮件：（空）\n原生文件：文件最后访问日期\n\nTIME_ACCESSD　07:00 PM　电子邮件：（空）\n原生文件：文件最后访问时间\n该数据必须为独立字段，不得与 DATE_ACCESSD 字段合并\n\nFILE_SIZE　5,952　原生文件文件/电子邮件的大小，单位为 KB\n\nPGCOUNT　1　原生文件文件/电子邮件中的页数\n\nPATH　电子邮件：（空）\nAgenda.doc　原生文件：保存原生文件文件的路径，包括原始文件名。\n\nINTFILEPATH　Personal Folders\\Deleted　电子邮件：电子邮件的原始位置，包括原始文件名。\nItems\\Board Meeting　原生文件：（空）\nMinutes.msg\n\nINTMSGID　<000805c2c71b\\$75977050\\$　电子邮件：唯一消息 ID 原生文件：（空）\ncb8306d1@MSN>\n\nMD5HASH　d131dd02c5e6eec4693d9a0　文件的 MD5 哈希值。\n698aff95c\n2fcab58712467eab4004583e\nb8fb7f89\n\nOCRPATH　TEXT/001/EDC0000001.txt　原生文件提取文本的路径\n\n3. 每项请求独立适用并应独立解释；除非另有说明，任何请求均不限制任何其他请求的范围。\n\n4. 所有文件应按通常业务过程中保存的方式出示，或者应组织和标注以对应本请求中的类别。\n\n5. 本文所含的每项请求延及所有文件：（a）由贵方占有、保管或控制的文件；或（b）由任何代表贵方行事的人占有、保管或控制的文件，\n\nCase 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 704 of 1063\n\n包括贵方律师或其他代表及顾问。每份文件均应完整出示。\n\n6. 如要求您提供一份已不再由您占有、保管或控制的文件，则您的答复必须：(a) 详细描述该文件的性质及其内容；(b) 确认编制或撰写该文件的人员（以及，如适用，该文件发送给的人员）；(c) 确认该文件编制或创建的日期；(d) 说明该文件是否：(i) 遗失或丢失，(ii) 已被销毁，(iii) 自愿或非自愿地转交给他人，或 (iv) 以其他方式处置；(e) 说明该等处置的理由及其相关事实和情形；(f) 确认授权该等处置的人员；(g) 确认该等处置的日期或大约日期；(h) 说明该文件最近一次由您占有、保管或控制的时间；以及 (i) 确认目前占有、保管或控制该文件的人员（如有）。\n\n7. 如要求您提供一份已被销毁的文件，则除前一指令要求提供的信息外，您的答复还必须说明：(a) 该文件被销毁的原因；(b) 销毁该文件的人员身份；以及 (c) 指示销毁该文件的人员身份。\n\n8. 如您主张某一被要求提供的文件享有特权或属于律师工作成果，则您的答复必须：(a) 说明：(i) 足以支持您关于该文件享有特权之主张的文件描述，(ii) 文件标题，(iii) 文件日期，(iv) 文件作者，(v) 文件收件人，(vi) 收到或见到该文件原件或任何草稿、副本或复制件的每一人员身份，(vii) 该文件本身或该文件中包含或提及的任何信息是否由任何其他人员占有、保管或控制；如是，则确认\n案号 Case 22-50073 文件 1592 提交于 03/24/23 录入于 03/24/23 10:57:37 第 705 页，共 1063 页\n\n该等人员的身份，并说明该信息如何进入其占有范围，(viii) 据以扣留该文件的特权主张，以及 (ix) 您将据以支持该等特权主张的全部情形；以及 (b) 就根据 D. Conn. L. Civ. R. 26(e) 主张特权而扣留的每一文件，制作一份载有本指令第 (a) 部分所要求全部信息的特权清单。\n\n9. 如一份原本应予提供的文件的一部分包含受特权主张约束的信息，则仅应按照上述指令从该文件中删除或遮盖受特权主张约束的部分，其余部分应予提供。\n\n10. 该等请求具有持续性。现指示您：(a) 在获悉先前答复不完整或不正确后，立即补充或更正任何后来得知不完整或不正确的答复；以及 (b) 提供根据下列规定所要求的任何其他文件\n\n11. 如一份文件使用英语以外的语言，您应提供该文件。如一份文件使用英语以外的语言，且存在英文译本，您应同时提供两份文件。\n\n12. 对实体的所有提及均包括其所有关联方。\n\n13. 对个人姓名的所有提及均包括所有其他名称、别名或昵称。\n\n14. 除非另有明确说明，文件请求所涵盖的期间为自 February 5, 2012 起至应提交文件请求答复之日止。\n案号 Case 22-50073 文件 1592 提交于 03/24/23 录入于 03/24/23 10:57:37 第 706 页，共 1063 页\nII. 解释规则\n\n15. (a) 任何单数名词的使用应解释为包括复数，反之亦然；以及 (b) 任何时态动词的使用应解释为包括该动词所有其他时态的使用。\n\n16. (a) “和”及“或”应视必要作合取或析取解释，以使任何请求的范围包括原本可能被解释为不在其范围内的所有答复；以及 (b) “每一”及“任何”应视为包括并涵盖“每个”及“所有”二词。\nIII. 定义\n\n经 D. Conn. Bankr. L.R. 2004-1(a) 纳入的 D. Conn. L. Civ. R. 26(c) 所规定的定义以及 D. Conn. L. Civ. R. 26(d) 所规定的解释规则，适用于该等文件请求。此外，本文件请求中使用的下列术语具有如下含义：\n\n1. “您”或“您的”或“您本人”是指 Ding G. Wang（王定刚），又名 Dinggang Wang（王定刚），以及其所有代理人、律师、代表、雇员和/或任何代表其行事之人。\n\n2. “债务人”是指 Ho Wan Kwok（郭文贵），又名 Miles Kwok、Miles Guo、Guo Wengui、Guo Haoyun、郭文贵，或任何其他别名，以及其雇员、代理人、法律顾问、顾问或任何代表其行事之人。\n\n3. “债务人之子”是指 Qiang Guo（郭强），又名 Mileson Kwok、郭强，或任何其他别名，以及其雇员、代理人、法律顾问、顾问或任何代表其行事之人。\n案号 Case 22-50073 文件 1592 提交于 03/24/23 录入于 03/24/23 10:57:37 第 707 页，共 1063 页\n\n4. “债务人之女”是指 Mei Guo（郭美），又名 Mei Gui、郭美，或任何其他别名，以及其雇员、代理人、法律顾问、顾问或任何代表其行事之人。\n\n5. “债务人所谓之妻”是指 Hing Chi Ngok（岳庆芝），又名 Hing Chi Ng、Yue Qingzhi、岳庆芝，或任何其他别名，以及其雇员、代理人、法律顾问、顾问或任何代表其行事之人。\n\n6. “债务人家属”统称债务人、债务人之子、债务人之女及债务人所谓之妻，以及与债务人有任何其他亲属关系者。\n\n7. “关联个人”单独及共同是指以下所有个人：(1) 持有、控制、保管或对债务人或债务人家属拥有、控制或享有的资产具有酌处权者；或 (2) 曾为一个或多个关联实体的雇员、董事，或以其他方式与其有关联者，以及前述任何人的各自雇员、代理人、法律顾问、顾问或任何代表其行事之人。该等关联个人包括但不限于：Daniel Podhaskie（丹尼尔·波德哈斯基）、Jason Miller（贾森·米勒）、Steve Bannon（史蒂夫·班农）、Karin Maistrello（卡琳·迈斯特雷洛）、Melissa Francis（梅利莎·弗朗西斯）、Anthony DiBattista（安东尼·迪巴蒂斯塔）、William Gertz（威廉·格茨）、Arethusa Forsyth（阿雷图萨·福赛思）、Glenn Mellor（格伦·梅勒）、Jennifer Mercurio（珍妮弗·梅库里奥）、Eduardo Eurnekian（爱德华多·欧内基安）、Wencong Wang（王文聪）、Han Chunguang（韩春光），又名 韩春光、Qu Guojiao（屈国姣），又名 Qu Guo Jiao、屈国姣、Guo Lijie（郭丽杰），又名 郭丽杰、Zhang Wei（张伟），又名 张伟*、Lihong Wei Lafrenz（魏丽红），又名 Sara Wei、魏丽红、Hao Haidong（郝海东），又名 郝海东、Ross Heinemeyer（罗斯·海内迈耶）、Max Krasner（马克斯·克拉斯纳）、Kyle Bass（凯尔·巴斯）、Melissa Mendez（梅利莎·门德斯）、Ya Li（李娅），又名 李娅、Dinggang Wang（王定刚），又名 王定刚、An Hong（安红），又名 安红、Yvette Wang（王雁平），又名 Yanping Wang、Yan Ping Wang、王雁平、Fiona Yu（菲奥娜·余）、Je Kin Ming（余建明），又名 William Je、Yu Jianming、余建明、Yaz Qingua（亚兹·钦瓜），以及 Lao Jiang（姜云浮），又名 Jiang Yunfu、Jiang Yunfu Be、姜云浮。\n案号 Case 22-50073 文件 1592 提交于 03/24/23 录入于 03/24/23 10:57:37 第 708 页，共 1063 页\n\n8. “关联实体”单独及共同是指以下所有任何类型的组织或实体：(1) 曾由债务人或债务人家属拥有、控制或投资的；或 (2) 对债务人或债务人家属拥有、控制或享有的任何资产直接或间接享有权益的；以及前述任何实体的各自雇员、代理人、法律顾问、顾问或任何代表其行事之人。该等关联实体包括但不限于：7 Nod Hill LLC（7诺德山有限责任公司）、AAGV Limited（AAGV有限公司）、ACA Investment Management Limited（ACA投资管理有限公司）、ACA Capital Group Limited（ACA资本集团有限公司）、Ace Decade Holdings Limited（艾斯十年控股有限公司）、AI Group Holdings Inc.（AI集团控股公司）、Alfa Global Ventures Limited（阿尔法全球风险投资有限公司）、Alfonso Global Limited（阿方索全球有限公司）、Allied Capital Global Limited（联合资本全球有限公司）、Alpine Fiduciaries SA（阿尔卑斯受托人股份公司）、Anton Development Limited（安东开发有限公司）、Assets Sino Limited（华夏资产有限公司）、Auspicious Coast Limited（吉祥海岸有限公司）、Beijing Pangu Investment Co.（北京盘古投资公司）、Beijing Pangu Investment Co. Ltd.（北京盘古投资有限公司）、Beijing Pangu Investment Inc.（北京盘古投资股份有限公司）、Beijing Zenith Holdings Company Limited（北京泽尼思控股有限公司）、Booming Sail New York LLC（纽约兴帆有限责任公司）、Bravo Luck Limited（卓运有限公司）、BSA Strategic Fund I（BSA战略基金I）、China Golden Spring (Hong Kong) Limited（中国金泉〈香港〉有限公司）、Chuang Xin Limited（创新有限公司）、Crane Advisory Group LLC（克兰咨询集团有限责任公司）、Creative Apex Investments Limited（创意顶峰投资有限公司）、Crystal Breeze Investments Limited（水晶微风投资有限公司）、Dawn State Limited（黎明州有限公司）、Eastern Profit Corporation Limited（东方利润有限公司）、Elite Well Global Limited（精英全球有限公司）、Empire Growth Holdings（帝国增长控股）、Freedom Media Ventures Ltd.（自由媒体风险投资有限公司）、G Club Operations LLC（G俱乐部运营有限责任公司）、G Fashion LLC（G时尚有限责任公司）、G News LLC（G新闻有限责任公司）、GETTR USA（GETTR美国）、Genever Holdings Corporation（热尼弗控股公司）、Genever Holdings LLC（热尼弗控股有限责任公司）、Gfashion Media Group Inc.（G时尚媒体集团公司）、GFNY, Inc.（GFNY公司）、Globalist International Limited（全球主义者国际有限公司）、GNews Media Group Inc.（G新闻媒体集团公司）、Golden Spring (New York) Ltd.（金泉〈纽约〉有限公司）、Greenwich Land LLC（格林尼治土地有限责任公司）、Guo Media（郭媒体）、GTV Media Group, Inc.（GTV媒体集团公司）、Hamilton Capital Holdings Inc.（汉密尔顿资本控股公司）、HCHK Property Management, Inc.（HCHK物业管理公司）、HCHK Technologies, Inc.（HCHK科技公司）、Head Win Group Limited（海德温集团有限公司）、Henan Yuda（河南裕达）、Himalaya Embassy（喜马拉雅大使馆）、Himalaya Exchange（喜马拉雅交易所）、Himalaya Federal Reserve（喜马拉雅联邦储备）、Himalaya Investment LLC（喜马拉雅投资有限责任公司）、Himalaya International（喜马拉雅国际）、Himalaya New World Inc.（喜马拉雅新世界公司）、Himalaya Supervisory Organization（喜马拉雅监督组织）、Himalaya Ventures LLC（喜马拉雅风险投资有限责任公司）、HK International Funds Investments (USA) Limited LLC（香港国际基金投资〈美国〉有限责任公司）、Hong Kong International Funds\n案号 Case 22-50073 文件 1592 提交于 03/24/23 录入于 03/24/23 10:57:37 第 709 页，共 1063 页\n\nInvestments Limited（香港国际基金投资有限公司）、Hudson Diamond Holding（哈德逊钻石控股）、Infinite Increase Limited（无限增长有限公司）、Infinitum Developments Limited（无限发展有限公司）、Infinity Treasury Management Inc.（无限财资管理公司）、Insight Phoenix Fund（洞察凤凰基金）、Lamp Capital LLC（兰普资本有限责任公司）、Leading Shine Limited（领耀有限公司）、Leading Shine NY Limited（领耀纽约有限公司）、Lexington Property and Staffing（列克星敦物业及人力配置）、Long Gate Limited（长龙门有限公司）、Maywind Trading LLC（五月风贸易有限责任公司）、MOS Himalaya LLC（MOS喜马拉雅有限责任公司）、Next Tycoon Investments Limited（下一大亨投资有限公司）、New Federal State of China（中国新联邦国），又名 NFSC、Noble Fame Global Limited（高誉全球有限公司）、Rosy Acme Ventures Limited（玫瑰顶峰风险投资有限公司）、Rule of Law Foundation III, Inc.（法治基金会III公司）、Rule of Law Foundation IV, Inc.（法治基金会IV公司）、Rule of Law Fund（法治基金）、Rule of Law Society（法治协会）、Rule of Law Society IV, Inc.（法治协会IV公司）、G-Translators PTY LTD（G翻译服务有限公司）、Saraca Media Group, Inc.（萨拉卡媒体集团公司）、Shiny Ace Ltd.（闪耀王牌有限公司）、Shiny Times Holdings Ltd.（闪耀时代控股有限公司）、Spirit Charter Investment Limited（精神宪章投资有限公司）、Stevenson, Wong & Co.（史蒂文森、黄及合伙公司）、Voice of Guo Media, Inc.（郭媒体之声公司）、Well Origin Ltd.（良源有限公司）、World Century Limited（世界世纪有限公司）、Worldwide Opportunity Holdings Limited（全球机遇控股有限公司）、Whitecroft Shore Limited（怀特克罗夫特海岸有限公司），以及 ZIBA Limited（ZIBA有限公司）。\n\n9. “包括”或其任何变体，意为“包括但不限于”。\n\n10. “和”及“或”意为“和/或”，并应同时作合取及析取解释，以最大限度扩大其范围。\n\n11. “任何”、“所有”及“每一”意为“每一个及所有”。\n\n12. “每一”及“每个”意为“每一个及所有”。\n\n13. “第三方”是指您本人以外的人员或实体。\n\n14. “转让”具有《破产法》section 101(54) 赋予该词的含义。\n\n15. “文件”是指属于 Fed. R. Civ. P. 34 范围内的任何信息或物件，包括但不限于任何种类、类型、性质或描述的、现由或曾由您占有、保管或控制的每一书面、记录或图形材料，包括所有电子邮件的印刷及电子副本、保存在计算机文件中的\n案号 Case 22-50073 文件 1592 提交于 03/24/23 录入于 03/24/23 10:57:37 第 710 页，共 1063 页\n\n电子形式、电子通信、短信、社交媒体帖子、推文、元数据、函件、备忘录、录音带、速记或手写笔记、任何种类的书面表格、图表、蓝图、图纸、草图、曲线图、计划、文章、规格说明、日记、信函、电报、照片、会议记录、合同、协议、调查、计算机打印件、任何种类的数据汇编、电传、传真、语音留言、发票、订购单、支票、汇票、对账单、贷项通知单、报告、情况报告、摘要、索引、书籍、分类账、笔记本、日程表、透明胶片、录音、目录、广告、宣传材料、胶片、录像带、录音带、CD、计算机磁盘、宣传册、小册子、穿孔卡、工时单、推文、社交媒体帖子，或任何其他种类的书面或记录材料，以及其所有元数据，无论以何种方式存储（无论为有形形式或电子形式）、记录、制作或复制；还包括但不限于前述任何材料的草稿或副本，如其中含有原始文件中未见的任何种类的笔记、评论或标记，或在其他方面与原始文件不完全相同。\n\n16. “人员”是指个人、公司、独资企业、合伙企业、协会或任何其他实体。“人员”还包括任何代理人、代表或专家，包括但不限于律师或财务顾问。\n\n17. “实体”是指任何自然人、公司、合伙企业、子公司、独资企业、商号、董事会、合资企业、协会、机构、主管机关、委员会或其他商业实体或法人，以及任何关联方、代理人、母公司，包括但不限于法律顾问、财务顾问或任何其他代表。\n\n18. “关于”是指涉及、描述、包括、提及、与之相关、支持、赞成、反对、加强、贬损、位于其中、结合考虑、与之有关、证明、表明、报告、记录、暗指、答复、\n\n案件 22-50073　文件 1592　提交于 03/24/23　登记于 03/24/23 10:57:37　第 711 页，共 1063 页\n\n与之相连、评论、就其而言、有关、与之相关、讨论、显示、描述、反映、分析、构成及属于。\n\n19. 在指称任何特定事项时，“与……有关”、“涉及”或“相关”系指但不限于构成、包括、涉及、包含、体现、反映、识别、陈述、直接或间接提及，或以任何方式与所识别的特定事项相关的任何文件。\n\n20. “通信”在最广泛的可能意义上且不限于此，是指任何信息或知识的传递（以事实、观念、询问或其他形式）。通信还指所有谈话、协议、询问或答复，无论是当面、通过电话、书面方式，还是通过电子传输设备，并包括但不限于所有函件、电子邮件、录音、传输单、备忘录、电话通信、语音留言、电报、电传传真、复印传真、电传、即时消息、聊天、短信、电话笔记，或在内部或与第三方之间传送的笔记。\n\n21. “资产”是指可用于产生正面经济价值的任何项目，包括但不限于由某一实体拥有、控制或为其利益而持有的具有经济价值且预期将提供未来利益的任何资源，包括但不限于所有不动产和动产、无形财产、投资、投资权或未来收入权、现金、银行账户、商品、证券、债权、对某一实体的全部或部分控制权，以及预期经济机会。\n\n22. “转让”应具有《Bankruptcy Code》section 101(54)赋予其的含义。\n\n四、应提交的文件\n\n1. 关于债务人、债务人财产或关联实体的任何收入或资产的所有文件。\n\n2. 与债务人的财务状况及其对债权人所负义务有关的所有文件，包括但不限于与任何试图规避支付该等义务的行为有关的所有文件，以及与本次或任何其他实际或潜在破产或类似无力偿债程序有关的所有文件。\n\n3. 关于任何与债务人、债务人财产、债务人家庭成员、关联实体或关联个人有关的资产负债表、银行对账单、账户对账单、财务报表、账户结单、电汇指令和／或确认函、资金证明、存款证明、持仓证明、投资组合摘要或类似文件的所有文件，包括但不限于足以显示向前述任何一方作出的所有转让的所有文件。\n\n4. 关于债务人作出、与债务人进行或代表债务人作出的任何投资、商业交易或交易事项的所有文件。\n\n5. 与债务人的所有通信，以及与债务人的通信有关且涉及任何实体的运营、管理或决策的文件，包括但不限于关联实体。\n\n6. 关于向债务人、由债务人或与债务人、债务人家庭成员或关联实体进行的任何转让、投资或其他交易或商业交易的所有文件。\n\n7. 关于债务人曾经占用或使用的任何财产的所有文件，包括但不限于 Lady May；Sherry Netherland Hotel / Condominium（雪莉荷兰酒店／共管公寓）；位于 Connecticut（康涅狄格州）Greenwich（格林尼治）373 Taconic Rd. 的住宅物业；位于 Connecticut（康涅狄格州）Greenwich（格林尼治）33 Ferncliff Rd. 的住宅物业；以及位于 Connecticut（康涅狄格州）Wilton（威尔顿）354 Nod Hill Rd. 的住宅物业。\n\n8. 与债务人拥有、控制或使用的任何航空器有关的所有文件，包括但不限于尾号为 T7-GQM 的航空器以及在 San Marino（圣马力诺）注册的任何其他航空器，包括但不限于所有登记文件及飞行清单的副本，该等飞行清单应显示该等航空器所执行的航班及搭乘该等航班的人员。\n\n9. 关于向债务人、债务人财产、债务人家庭成员或关联实体提供、由其提供或代表其提供的任何赠与、利益或贷款的所有文件，包括但不限于足以显示该等赠与、利益或贷款金额；该等赠与、利益或贷款的使用目的；提供该等赠与、利益或贷款的时间；以及任何贷款的条款、就任何贷款作出的所有陈述与保证、任何贷款的利率，以及任何贷款付款的所有证据的文件。\n\n10. 关于由债务人、债务人财产、债务人家庭成员或关联实体设立、代表其设立或为其利益设立的任何信托或类似文书的所有文件，包括但不限于足以显示设立该等信托的时间、设立人、为谁的利益而设立，以及信托本金的文件。\n\n11. 与涉及债务人的任何法律争议有关的任何义务、债权、责任或债务有关的所有文件，包括但不限于与在任何地方、州、联邦或国际机构（无论是行政机构、法院、审裁小组或替代性争议解决实体）前进行的任何诉讼有关的文件。\n\n案件 22-50073　文件 1592　提交于 03/24/23　登记于 03/24/23 10:57:37　第 714 页，共 1063 页\n\n12. 贵方任何外部法律顾问或其他顾问与债务人之间的所有文件和通信。\n\n13. 与贵方现持有或曾持有权益的任何关联实体有关的所有文件。\n\n14. 与债务人的所有通信，以及与债务人的通信有关且涉及任何法人实体的运营、管理或决策的文件，包括但不限于家庭关联实体和关联实体。\n\n附件 C-39\n\nB2540（表格 2540 — Rule 2004 审查传票）（12/15）案件 22-50073　文件 1592　提交于 03/24/23　登记于 03/24/23 10:57:37　第 716 页，共\n\nUNITED STATES BANKRUPTCY COURT（美国破产法院）\n\nDistrict of Connecticut（康涅狄格区）\n\n关于 HO WAN KWOK（郭文贵）等人的事项，\n\n1　案件编号 22-50073 (JAM)　债务人　第 11 章\n\n（联合管理）\nRULE 2004 审查传票\n\n致：Prime Trust LLC（Prime Trust有限责任公司）\n\n（传票所指向人员的姓名）\n\n作证：兹命令贵方于下列规定的时间、日期和地点出席，并根据 Federal Rules of Bankruptcy Procedure（《联邦破产程序规则》）Rule 2004 接受审查并作证。随附授权该审查的法院命令副本。\n\n地点　日期和时间\n\nPaul Hastings LLP（博钦律师事务所）\n200 Park Avenue　[TBD]\nNew York, New York 10166（纽约州纽约市 10166）\n\n审查将通过以下方式记录：法庭记录员／速记员\n\n提交文件：贵方或贵方代表还必须携带下列文件、电子存储信息或物品出席审查，并必须允许对该等材料进行检查、复制、测试或取样：\n\n见随附的文件提交请求。\n\nFed. R. Civ. P. 45 的下列规定，经 Fed. R. Bankr. P. 9016 适用于破产案件，随附于本传票之后——有关履行地点的 Rule 45(c)；有关作为受传票约束人员之保护的 Rule 45(d)；以及有关贵方对本传票作出回应的义务和未作出回应的潜在后果的 Rule 45(e) 和 45(g)。\n\n日期：March , 2023\n\n法院书记员\n\n或\n\n书记员或副书记员签名　律师签名\n\n签发或请求本传票、代表 Chapter 11 受托人 Luc A. Despins（卢克·A·德斯平斯）的律师的姓名、地址、电子邮件地址和电话号码如下：\n\nDouglas S. Skalka, Esq.（道格拉斯·S·斯卡尔卡，律师）；Neubert, Pepe & Monteith, P.C.（Neubert、Pepe & Monteith专业公司）；195 Church Street, New Haven, Connecticut 06510（康涅狄格州纽黑文市教堂街195号） dskalka@npmlaw.com；(203) 821-2000\n\n致签发或请求本传票之人的通知\n\n如本传票命令在审判前提交文件、电子存储信息或有形物品，或检查场所，则必须在向传票所指向人员送达之前，向每一方当事人送达通知及本传票副本。Fed. R. Civ. P. 45(a)(4)。\n\n软件版权 (c) 1996-2022 Best Case, LLC（Best Case有限责任公司） - www.bestcase.com Best Case Bankruptcy 1 本第 11 章案件中的债务人为 Ho Wan Kwok（郭文贵）（又称 Guo Wengui（郭文贵）、Miles Guo（郭文贵）和 Miles Kwok（郭文贵），以及众多其他别名）（税务识别号后四位：9595）、Genever Holdings LLC（Genever Holdings有限责任公司）（税务识别号后四位：8202）及 Genever Holdings Corporation（Genever Holdings公司）。受托人、Genever Holdings LLC 及 Genever Holdings Corporation 的邮寄地址为 Paul Hastings LLP（博钦律师事务所），200 Park Avenue, New York, NY 10166，由 Luc A. Despins（卢克·A·德斯平斯）转交，其作为 Ho Wan Kwok（郭文贵）财产的受托人（仅为通知和通信之目的）。\n\n送达证明\n\n（除非 Fed. R. Civ. P. 45 要求，否则本节不应向法院提交。）\n\n本人于（日期）收到向（个人姓名及职务，如有）送达的本传票。\n\n本人以下列方式向所列明人员交付副本以送达本传票：\n\n于（日期）送达；或\n\n本人因下列原因未执行而退回本传票：\n\n除非本传票代表 United States（美国）或其官员或代理人签发，本人还已向证人支付一日出席费用及法律允许的里程费，金额为 $ 。\n\n本人的差旅费用为 $ ，服务费用为 $ ，合计为 $ 。\n\n本人在伪证罪处罚的约束下声明，该等信息真实、正确。\n\n日期：\n\n送达人员签名\n\n正楷姓名及职务\n\n送达人员地址\n\n有关尝试送达等的补充信息：\n\nFederal Rule of Civil Procedure 45(c)、(d)、(e) 和 (g)（Effective 12/1/13）（经 Federal Rules of Bankruptcy Procedure Rule 9016 适用于破产案件）\n\n(c) 履行地点。\n\n(1) 用于审判、听证或证言记录。传票仅可按下列方式命令某人出席审判、听证或证言记录：\n\n(A) 在该人居住、受雇或经常亲自办理业务地点的 100 英里范围内；或\n\n(B) 在该人居住、受雇或经常亲自办理业务所在州内，若该人\n\n(i) 为当事人或当事人的高级职员；或\n\n(ii) 被命令出席审判，且不会产生重大费用。\n\n(2) 用于其他证据开示。传票可以命令：\n\n(A) 在该人居住、受雇或经常亲自办理业务地点的 100 英里范围内某一地点提交文件、电子存储信息或物品；以及\n\n(B) 在被检查处所进行处所检查。\n\n(d) 保护受传票约束之人；执行。\n\n(1) 避免不当负担或费用；制裁。负责签发和送达传票的当事人或律师必须采取合理措施，避免向受传票约束之人施加不当负担或费用。要求履行传票的地区法院必须执行该义务，并对未遵守该义务的当事人或律师施加适当制裁，该制裁可包括损失的收入和合理的律师费。\n\n(2) 命令提交材料或允许检查。\n\n(A) 无须出席。被命令提交文件、电子存储信息或有形物品，或允许检查处所之人，无须亲自出席提交或检查地点，除非同时被命令出席证言记录、听证或审判。\n\n(B) 异议。被命令提交文件或有形物品，或允许检查之人，可以就检查、复制、测试或抽样全部或部分材料，或检查处所，或以所要求的格式提交电子存储信息，向传票中指定的当事人或律师送达书面异议。异议必须在规定的履行时间或传票送达后 14 日届满两者中较早者之前送达。如提出异议，适用下列规则：\n\n(i) 送达方可随时在通知被命令人的情况下，向要求履行传票的地区法院提出动议，请求作出强制提交或检查的命令。\n\n(ii) 仅可依照该命令的指示要求实施该等行为，且该命令必须保护既非当事人亦非当事人高级职员之人免受因履行而产生的重大费用。\n\n(3) 撤销或修改传票。\n\n(A) 必须撤销或修改的情形。经及时提出动议，要求履行传票的地区法院必须撤销或修改具有下列情形的传票：\n\n(i) 未给予合理的履行时间；\n\n(ii) 要求某人在 Rule 45(c) 规定的地理范围之外履行；\n\n(iii) 要求披露享有特权或受其他保护的事项，且不适用任何例外或放弃；或\n\n(iv) 对某人施加不当负担。\n\n(B) 可以撤销或修改的情形。为保护受传票约束或受其影响之人，要求履行传票的地区法院可经动议，在传票要求下列事项时撤销或修改该传票：\n\n(i) 披露商业秘密或其他保密的研究、开发或商业信息；或\n\n(ii) 披露未受聘专家的意见或信息，该等意见或信息并非描述争议中的特定事件，且源于未由当事人要求进行的该专家研究。\n\n(C) 以规定条件作为替代。在 Rule 45(d)(3)(B) 所述情形下，如送达方：\n\n(i) 证明对证言或材料具有实质需要，且如不承受不当困难即无法以其他方式满足该需要；并且\n\n(ii) 确保被传唤之人将获得合理补偿，\n\n法院可以不撤销或修改传票，而命令在规定条件下出席或提交。\n\n(e) 回应传票的义务。\n\n(1) 提交文件或电子存储信息。下列程序适用于提交文件或电子存储信息：\n\n(A) 文件。回应提交文件传票之人必须按其通常业务过程中保存的方式提交文件，或必须将文件整理并标记为与请求中的类别相对应。\n\n(B) 未指定电子存储信息的提交格式。如传票未指定提交电子存储信息的格式，回应之人必须以其通常保存的格式，或以合理可用的格式提交。\n\n(C) 电子存储信息仅以一种格式提交。回应之人无须以一种以上格式提交同一电子存储信息。\n\n(D) 不可合理获取的电子存储信息。回应之人无须对其认定因不当负担或费用而不可合理获取的来源中的电子存储信息提供证据开示。在提出强制证据开示动议或保护令动议时，回应之人必须证明该信息因不当负担或费用而不可合理获取。如作出该证明，若请求方在考虑 Rule 26(b)(2)(C) 的限制后证明具有正当理由，法院仍可命令从该等来源进行证据开示。法院可以对该证据开示规定条件。\n\n(2) 主张特权或保护。\n\n(A) 扣留的信息。以信息享有特权或作为审判准备材料受到保护为由扣留被传唤信息之人，必须：(i) 明确提出该主张；并且\n\n(ii) 以一种在不披露本身享有特权或受保护的信息的情况下，能够使各当事人评估该主张的方式，说明被扣留文件、通信或有形物品的性质。\n\n(B) 已提交的信息。如为回应传票而提交的信息受特权主张或作为审判准备材料受保护的主张约束，提出该主张之人可以通知任何收到该信息的当事人该主张及其依据。收到通知后，当事人必须迅速返还、隔离或销毁所指定的信息及其持有的任何副本；在该主张得到解决前不得使用或披露该信息；如该当事人在收到通知前已披露该信息，必须采取合理措施追回该信息；并可以迅速向要求履行传票的地区法院密封提交该信息，以裁定该主张。提交该信息之人必须在该主张得到解决前保存该信息。\n\n(g) 藐视法庭。要求履行传票的地区法院，以及在动议移送后签发传票的法院，均可认定已被送达但无充分理由不遵守传票或与之相关命令之人构成藐视法庭。\n\n有关获取传票材料，请参见 Fed.R.Civ.P.45(a) Committee Note (2013)\n\n……\n\n文件提交请求\n\nI. 指示\n\n1. 除非另有说明，下文所列文件提交请求（以下称“请求”，单称“一项请求”）必须分别且具体地予以回应。除非善意提出异议，否则必须对每项请求作出完整答复；如提出异议，必须按照下文规定详细说明您方异议的理由。如异议仅涉及一项请求的一部分，或其中包含的某个词、短语或条款，您方仅须就该部分说明异议，并回应其余请求。\n\n2. 电子存储信息必须依照下列指示提交：\n\na. 图像。黑白图像必须为 300 DPI Group IV 单页 TIFF 文件。彩色图像必须以 JPEG 格式提交。文件名不得含有嵌入空格或特殊字符（包括逗号）。文件夹名称不得含有嵌入空格或特殊字符（包括逗号）。所有 TIFF 图像文件必须具有唯一文件名，即 Bates 编号。图像必须在每张图像的右下角加盖连续的 Bates 编号。每个文件夹中的 TIFF 文件数量不得超过 1000 个文件。Excel 电子表格应具有以该文件 Bates 编号命名的占位图像。\n\nb. 图像加载文件\n\na. Concordance®（康科丹斯®）数据文件。数据文件（.DAT）包含将加载至 Concordance® 数据库的全部字段信息。.DAT 文件的第一行必须为标明字段名称的标题行。.DAT 文件必须使用下列 Concordance® 默认分隔符：逗号 ASCII 字符（020）引号 þ ASCII 字符（254）。日期字段应采用如下格式提供：mm/dd/yyyy。日期和时间字段必须为两个独立字段。如文件包括图像化电子邮件及附件，必须包括附件字段，以保留电子邮件与其附件之间的父子关系。必须包括 OCRPATH 字段，以提供已提交存储介质上提取文本文件的文件路径和名称。文本文件必须以 FIRSTBATES 命名。不得在 .DAT 文件中包含文本。对于含有原生文件的文件，必须包括 LINK 字段，以提供原生文件的文件路径和名称。原生文件必须以 FIRSTBATES 命名。\n\nb. Concordance Image®（康科丹斯图像®）或 Opticon（奥普蒂康）交叉引用文件。图像交叉引用文件（.LOG 或 .OPT）将图像链接至数据库记录。该文件应为逗号分隔文件，每行由七个字段组成，数据库中的每个图像均应在交叉引用文件中对应一行，格式如下：ImageID,VolumeLabel,ImageFilePath,DocumentBreak,FolderBreak,Box Break,PageCount。\n\nc. 文件文本。文本必须作为独立文本文件提交，而非作为 .DAT 文件中的字段提交。文本文件的完整路径（OCRPATH）应包含在 .DAT 文件中。建议使用按 FIRSTBATES/Image Key 命名的文件级 ANSI 文本文件。提取的文本文件必须置于单独文件夹内，每个文件夹中的文本文件数量不得超过 1,000 个文件。文件夹名称中不得含有特殊字符（包括逗号）。必须按文件级别提供文本文件。\n\nd. 特定文件类型的原生格式提交。为充分理解其内容和含义而合理需要以原生格式查看的文件类型，必须以原生格式提交。该等文件包括但不限于电子表格、类似电子表格的文件（Microsoft Excel（微软 Excel）、逗号分隔值、制表符分隔值等）、Microsoft PowerPoint（微软 PowerPoint）或其他特殊演示文件、数据库文件以及音频/视频文件。应提供一张带有 Bates 编号的分隔页图像，标明原生文件的存在，并在 .dat 文件中以字段形式载明原生文件路径。提交的原生文件应以与该文件分隔页相对应的 Bates 编号命名。原生文件应归入按递增方式命名的“NATIVE”目录中，并与图像目录分开。\n\ne. 去重。对于存在完全重复件的每份电子文件，提交一份副本。对于电子邮件，应依据从 BCC、Body、CC、From、IntMsgID、To 和 Attach 属性生成的 MD5 哈希值合并重复件。对于电子邮件附件和独立电子文件，应依据整个文件的 MD5 哈希值合并重复件。\n\nf. 元数据。应以符合 Concordance 标准的加载文件（.dat）形式提交每份文件的提取元数据。.DAT 文件的第一行必须为标明字段名称的标题行。.DAT 文件必须使用下列 Concordance 默认分隔符：逗号 , ASCII 字符（020）引号 þ ASCII 字符（254）\n\n日期字段应采用以下格式：mm/dd/yyyy。日期和时间字段必须为两个独立字段。以下列出必需的元数据：\n\n案号 22-50073 文书 1592 提交 03/24/23 录入 03/24/23 10:57:37 第 721 页，共 1063 页\n\n字段名称　示例数据　说明\nFIRSTBATES　EDC0000001　原生文件文档/电子邮件的首个 Bates 编号\nLASTBATES　EDC0000001　原生文件文档/电子邮件的最后一个 Bates 编号\n对于单页文档，应填写 LASTBATES 字段\nATTACHRANGE　EDC0000001\n-　母文件的第一页 Bates 编号至最后一个附件“子”文件的最后一页 Bates 编号\nEDC0000015\nBEGATTACH　EDC0000001　附件范围的首个 Bates 编号\nENDATTACH　EDC0000015　附件范围的最后一个 Bates 编号\nCUSTODIAN　Smith, John　电子邮件：该电子邮件所在的邮箱\n原生文件：文件来源个人或部门的名称\nFROM　John Smith　电子邮件：发件人\n原生文件：文件作者\n多个条目应以分号分隔\nTO　Coffman, Janice; LeeW　收件人\n[mailto:LeeW@MSN.com]　多个条目应以分号分隔\nCC　Frank Thompson [mailto:　抄送收件人\nfrank_Thompson@cdt.com]　多个条目应以分号分隔\nBCC　John Cain　密送收件人\n多个条目应以分号分隔\nSUBJECT　Board Meeting Minutes　电子邮件：电子邮件的主题行 原生文件：文件标题（如有）\nFILE_NAME　BoardMeetingMinutes.docx　原生文件：原始原生文件的名称，包括扩展名\nDATE_SENT　10/12/2010　电子邮件：电子邮件发送日期\n原生文件：（空）\nTIME_SENT/\nTIME_ZONE　07:05 PM GMT　电子邮件：电子邮件发送时间/电子邮件标准化所采用的时区\nTIME_ZONE　GMT　在转换期间对电子邮件进行标准化所采用的时区。\nLINK　EDC0000001.msg　电子邮件或原生文件文档的超链接\n链接文件必须按照 FIRSTBATES 编号命名\nFILE_EXTEN　MSG　表示电子邮件或原生文件文档的文件类型扩展名\nAUTHOR　John Smith　电子邮件：（空）\n原生文件：文件作者\nDATE_CREATED　10/10/2010　电子邮件：（空）\n原生文件：文件创建日期\n\n案号 22-50073 文书 1592 提交 03/24/23 录入 03/24/23 10:57:37 第 722 页，共 1063 页\n\nTIME_CREATED　10:25 AM　电子邮件：（空）\n原生文件：文件创建时间\n该数据必须为独立字段，不得与 DATE_CREATED 字段合并\nDATE_MOD　10/12/2010　电子邮件：（空）\n原生文件：文件最后修改日期\nTIME_MOD　07:00 PM　电子邮件：（空）\n原生文件：文件最后修改时间\n该数据必须为独立字段，不得与 DATE_MOD 字段合并\nDATE_ACCESSD　10/12/2010　电子邮件：（空）\n原生文件：文件最后访问日期\nTIME_ACCESSD　07:00 PM　电子邮件：（空）\n原生文件：文件最后访问时间\n该数据必须为独立字段，不得与 DATE_ACCESSD 字段合并\nFILE_SIZE　5,952　原生文件文档/电子邮件的大小，以 KB 计\nPGCOUNT　1　原生文件文档/电子邮件的页数\nPATH　电子邮件：（空）\nAgenda.doc　原生文件：原生文件文档的存储路径，包括原始文件名。\nINTFILEPATH　Personal Folders\\Deleted　电子邮件：电子邮件的原始位置，包括原始文件名。\nItems\\Board Meeting\nMinutes.msg　原生文件：（空）\nINTMSGID　<000805c2c71b\\$75977050\\$　电子邮件：唯一邮件 ID 原生文件：（空）\ncb8306d1@MSN>\nMD5HASH　d131dd02c5e6eec4693d9a0　文件的 MD5 哈希值。\n698aff95c\n2fcab58712467eab4004583e\nb8fb7f89\nOCRPATH　TEXT/001/EDC0000001.txt　原生文件提取文本的路径\n\n3. 每项请求均独立适用并应独立解释；除非另有说明，任何一项请求均不限制任何其他请求的范围。\n\n4. 所有文件应按其在正常业务过程中保存的方式提交，或者应进行整理并加贴标签，以对应本请求中的类别。\n\n5. 每项载于本文的请求均延及所有文件：(a) 在贵方占有、保管或控制之下的文件；或 (b) 在代表贵方行事的任何人占有、保管或控制之下的文件，\n\n案号 22-50073 文书 1592 提交 03/24/23 录入 03/24/23 10:57:37 第 723 页，共 1063 页\n\n包括贵方律师或其他代表和顾问。每份文件均应完整提交。\n\n6. 如要求贵方提交一份已不再由贵方占有、保管或控制的文件，则贵方的答复必须：(a) 详细说明该文件的性质及其内容；(b) 识别编制或撰写该文件的人员（以及，如适用，接收该文件的人员）；(c) 识别该文件编制或创建的日期；(d) 说明该文件是否 (i) 遗失或丢失，(ii) 已被销毁，(iii) 已自愿或非自愿地转移给他人，或 (iv) 以其他方式被处置；(e) 说明该等处置的理由，以及与该等处置有关的事实和情形；(f) 识别授权该等处置的人员；(g) 识别该等处置的日期或约略日期；(h) 说明该文件最近一次由贵方占有、保管或控制的时间；以及 (i) 识别目前占有、保管或控制该文件的人员（如有）。\n\n7. 如要求贵方提交一份已被销毁的文件，则除前述指示所要求的信息外，贵方的答复还必须说明：(a) 销毁该文件的理由；(b) 销毁该文件的人员身份；以及 (c) 指示销毁该文件的人员身份。\n\n8. 如贵方主张所请求的文件享有特权或属于律师工作成果，则贵方的答复必须：(a) 说明：(i) 足以支持贵方关于该文件享有特权之主张的文件描述，(ii) 文件标题，(iii) 文件日期，(iv) 文件作者，(v) 文件收件人，(vi) 收到或阅览该文件原件或任何草稿、副本或复制件的每一人员身份，(vii) 该文件本身或该文件所载或提及的任何信息是否由任何其他人员占有、保管或控制；如是，则说明该等人员的身份，\n\n案号 22-50073 文书 1592 提交 03/24/23 录入 03/24/23 10:57:37 第 724 页，共 1063 页\n\n以及说明该等信息如何进入其占有范围，(viii) 据以不提交该文件的特权主张，以及 (ix) 贵方将赖以支持该特权主张的所有情形；以及 (b) 依照 D. Conn. L. Civ. R. 26(e)，就每一份基于特权主张而不提交的文件，提交一份特权日志，其中载明本指示第 (a) 部分所要求的全部信息。对于文件请求中未主张特权或工作成果的任何部分，应完整提供回应性文件。\n\n9. 如一份原本具有回应性的文件的一部分含有受特权主张约束的信息，则仅应依照上述指示从该文件中删除或遮蔽受特权主张约束的该部分，且应提交其余部分。\n\n10. 本请求具有持续性。现指示贵方：(a) 一旦知悉先前答复不完整或不正确，应立即补充或更正任何后来发现不完整或不正确的答复；以及 (b) 提交根据下文所要求的任何额外文件。\n\n11. 如文件以英语以外的语言写成，贵方应提供该文件。如文件以英语以外的语言写成，且存在英文译本，贵方应同时提供两份文件。\n\n12. 对实体的所有提及均包括其所有关联方。\n\n13. 对个人姓名的所有提及均包括所有其他姓名、别名或昵称。\n\n案号 22-50073 文书 1592 提交 03/24/23 录入 03/24/23 10:57:37 第 725 页，共 1063 页\n\n14. 除非另有明确说明，文件请求涵盖的期间为自 February 5, 2012 起至文件请求答复到期之日止。\n\nII. 解释规则\n\n15. (a) 任何单数名词的使用应解释为包括复数，反之亦然；以及 (b) 任何时态动词的使用应解释为在所有其他时态下使用该动词。\n\n16. (a) “and”和“or”应视必要情况作连词或选择连词解释，以将本可被解释为超出任何请求范围的所有答复纳入该请求范围；以及 (b) “each”和“any”应视为包括并涵盖“every”和“all”二词。\n\nIII. 定义\n\n经 D. Conn. Bankr. L.R. 2004-1(a) 纳入的 D. Conn. L. Civ. R. 26(c) 所规定的定义，以及 D. Conn. L. Civ. R. 26(d) 所规定的解释规则，适用于文件请求。此外，本文件请求中使用的下列术语具有下列含义：\n\n1. “贵方”或“贵方的”或“贵方自身”是指 Prime Trust LLC（普莱姆信托有限责任公司），连同其所有关联方、部门、机构、办事机构、部门、办公室、合伙人、高级职员、董事、代理人、律师、代表、雇员和/或代表其行事的任何人。\n\n案号 22-50073 文书 1592 提交 03/24/23 录入 03/24/23 10:57:37 第 726 页，共 1063 页\n\n2. “债务人”是指 Ho Wan Kwok（郭文贵）（又名 Miles Kwok、Miles Guo、Guo Wengui、Guo Haoyun、郭文贵或任何其他别名），连同其雇员、代理人、律师、顾问或代表其行事的任何人。\n\n3. “债务人之子”是指 Qiang Guo（郭强）（又名 Mileson Kwok、郭强或任何其他别名），连同其雇员、代理人、律师、顾问或代表其行事的任何人。\n\n4. “债务人之女”是指 Mei Guo（郭美）（又名 Mei Gui、郭美或任何其他别名），连同其雇员、代理人、律师、顾问或代表其行事的任何人。\n\n5. “债务人的所谓妻子”是指 Hing Chi Ngok（岳庆芝）（又名 Hing Chi Ng、Yue Qingzhi、岳庆芝或任何其他别名），连同其雇员、代理人、律师、顾问或代表其行事的任何人。\n\n6. “债务人家属”单独及统称是指债务人、债务人之子、债务人之女和债务人的所谓妻子，以及与债务人具有任何其他家庭关系者。\n\n7. “2004 年调查对象”单独及统称是指债务人、债务人家属、RBB Bancorp（RBB 银行控股公司）、Royal Business Bank（皇家商业银行）、U.S. Bank National Association（美国合众银行全国协会）、ACA Capital Group Limited（ACA 资本集团有限公司）、Himalaya International Financial Group Ltd.（喜马拉雅国际金融集团有限公司）、Himalaya International Clearing Ltd.（喜马拉雅国际清算有限公司）、Himalaya International Payments Ltd.（喜马拉雅国际支付有限公司）、Himalaya International Reserves Ltd.（喜马拉雅国际储备有限公司）、Jesse Brown（杰西·布朗）、William Je（威廉·杰）、William Je、Eastern Profit Corporation Limited（东方盈利有限公司）、HK International Funds Investments (USA) Limited LLC（香港国际基金投资〈美国〉有限责任公司）、Bravo Luck Limited（鸿运有限公司）、Golden Spring (New York) Ltd.（黄金泉〈纽约〉有限公司）、Lamp Capital LLC（灯塔资本有限责任公司）、Greenwich Land LLC（格林尼治地产有限责任公司）、Qu Guo Jiao（曲国娇）、Daniel Thomas Podhaskie（丹尼尔·托马斯·波德哈斯基）、Yvette Wang（王燕平）（又名 Yanping Wang、又名 Yan Ping Wang）、Ace Decade Holdings Limited（十年王牌控股有限公司）、Dawn State Limited（曙光州有限公司）、Rule of Law Society IV Inc.（法治协会 IV 公司）、Rule of Law Foundation III, Inc.（法治基金会 III 公司）、Rule of Law Foundation IV, Inc.（法治基金会 IV 公司）、Rule of Law Fund（法治基金）、Rule of Law Society（法治协会）、GTV Media Group, Inc.（GTV 媒体集团公司）、Voice of Guo Media, Inc.（郭媒体之声公司）、Saraca（萨拉卡）\n\n案号 22-50073 文书 1592 提交 03/24/23 录入 03/24/23 10:57:37 第 727 页，共 1063 页\n\nMedia Group Inc.（媒体集团公司）、Genever Holdings Corporation（Genever控股公司）、Genever Holdings LLC（Genever控股有限责任公司）、Gnews Media Group Inc.（G新闻媒体集团公司）、G Fashion LLC（G时尚有限责任公司）、Gmusic LLC（G音乐有限责任公司）、Gnews LLC（G新闻有限责任公司）、Geducation（G教育）、GFNY, Inc.（GFNY公司）、G-Club Investments Limited（G俱乐部投资有限公司）、G Club Operations LLC（G俱乐部运营有限责任公司）、G Club US Operations Inc.（G俱乐部美国运营公司）、G Club US Operations LLC（G俱乐部美国运营有限责任公司）、G Live, LLC（G直播有限责任公司）、Gbroadcast, LLC（G广播有限责任公司）、Gposts LLC（G帖子有限责任公司）、HCHK Property Management, Inc.（HCHK物业管理公司）、HCHK Technologies, Inc.（HCHK科技公司）、FMV Ltd./Freedom Media Venture Ltd.（FMV有限公司／自由媒体风险投资有限公司）、Roscalitar 2（罗丝卡利塔尔2）、Himalaya New World Inc.（喜马拉雅新世界公司）、US Himalaya Capital Inc.（美国喜马拉雅资本公司）、Hudson Diamond Holding, Inc.（哈德逊钻石控股公司）、Hudson Diamond Holding LLC（哈德逊钻石控股有限责任公司）、Hudson Diamond NY LLC（哈德逊钻石纽约有限责任公司）、Infinity Treasury Management Inc.（无限资金管理公司）、Lexington Property and Staffing, Inc.（列克星敦物业与人力配置公司）、AI Group Holdings Inc.（AI集团控股公司）、Hamilton Capital Holdings Inc.（汉密尔顿资本控股公司）、Booming Sail New York LLC（兴旺帆船纽约有限责任公司）、Himalaya Ventures LLC（喜马拉雅风险投资有限责任公司）、Himalaya Ventures LLC、Himalaya Investment LLC（喜马拉雅投资有限责任公司）、New York MOS Himalaya LLC（纽约MOS喜马拉雅有限责任公司）、MOS Himalaya LLC（MOS喜马拉雅有限责任公司）、Crane Advisory Group（克兰咨询集团）、Maywind Trading LLC（五月风贸易有限责任公司）、Gettr USA, Inc.（GETTR美国公司）、Han Chunguang（韩春光）、Bingshang Jiao（焦冰爽）、Karin Maistrello（卡琳·梅斯特雷洛）、Mary Jiang（玛丽·江）、Jiaming Liu（刘嘉明）及 Wencong Wang（王文聪）。\n\n8. “Including”或其任何变体，意为“包括但不限于”。\n\n9. “And”和“or”意为“and/or”，并应同时按合取及析取方式解释，以最大化其范围。\n\n10. “Any”、“all”和“each”意为“每一及所有”。\n\n11. “Each”和“every”意为“每一及所有”。\n\n12. “Third Party”意为除您本人以外的个人或实体。\n\n13. “Transfer”应具有《破产法典》第101(54)条赋予该词的含义。\n\n14. “Document”意为属于 Fed. R. Civ. P. 34 范围内的任何信息或物品，并包括但不限于任何种类、类型、性质或描述的每一项书面、录制或图形材料，\n\n案件 22-50073 文件 1592 于 03/24/23 提交，于 03/24/23 10:57:37 登记 第728页，共1063页\n\n其现时或曾经处于您的占有、保管或控制之下，包括电子邮件的所有纸质及电子副本、以电子形式保存的计算机文件、通信函件、备忘录、磁带、速记或手写笔记、任何种类的书面表格、图表、蓝图、绘图、草图、曲线图、计划、文章、规格说明、日记、信件、电报、照片、会议记录、合同、协议、调查、计算机打印件、任何种类的数据汇编、电传、传真、电子邮件、短信、即时消息、语音留言、发票、订购单、支票、汇票、对账单、贷项通知单、报告、头寸报告、摘要、索引、账簿、分类账、笔记本、明细表、透明胶片、录音、目录、广告、宣传材料、影片、录像带、录音带、CD、计算机磁盘、宣传册、小册子、穿孔卡、工时单、推文、社交媒体帖子或任何其他种类的书面或录制材料，以及其所有元数据，无论以何种方式存储（无论为有形或电子形式）、录制、制作或复制；还包括但不限于上述任何材料的草稿或副本，如其包含原始文件中没有的任何种类的笔记、评论或标记，或者在其他方面与原始文件不相同。\n\n15. “Person(s)”意为个人、公司、独资企业、合伙企业、协会或任何其他实体。“Person”还包括任何代理人、代表或专家，包括但不限于律师或财务顾问。\n\n16. “Entity”意为任何自然人、公司、合伙企业、子公司、独资企业、商号、董事会、合资企业、协会、机构、主管机关、委员会或其他商业实体或法人，以及任何关联方、代理人、母公司，包括但不限于法律顾问、财务顾问或任何其他代表。\n\n案件 22-50073 文件 1592 于 03/24/23 提交，于 03/24/23 10:57:37 登记 第729页，共1063页\n\n17. “Regarding”意为有关、描述、构成、提及、与之相关、支持、有利于、反对、加强、减损、位于、结合考虑、对其有影响、证明、表明、报告、记录、暗指、回应、与之相连、评论、就其而言、关于、与之有关、讨论、显示、描述、反映、分析、构成及属于。\n\n18. 就任何特定主题而言，“Relating to”、“relate(s) to”或“related to”意为，包括但不限于，构成、包含、涉及、载有、体现、反映、识别、陈述、直接或间接提及，或以任何方式与所识别的特定主题相关的任何文件。\n\n19. “Communication(s)”在最广泛可能的意义上且不受限制地意为任何信息或知识的传递（以事实、想法、询问或其他形式）。Communication(s)还指所有谈话、协议、询问或答复，无论是当面、通过电话、书面形式或借助电子传输设备，并包括但不限于所有函件、电子邮件、录音、传送单、备忘录、电话通信、语音留言、电报、电传传真、电传复印件、电传、即时消息、聊天信息、短信、在留言板或群聊中的帖子、社交媒体帖子、推文、上传至任何视频平台的视频、电话笔记，或在内部或与第三方之间传送的笔记。\n\n20. “Asset(s)”意为受占有、保管或控制的任何具有经济价值的项目。Asset包括所有不动产和动产，包括但不限于房地产、土地、房屋、公寓、共管公寓、汽车、游艇、船只、飞机、喷气机、直升机、现金、银行账户、加密货币、证券、应收账款、存货及其他有形和无形财产。\n\n案件 22-50073 文件 1592 于 03/24/23 提交，于 03/24/23 10:57:37 登记 第730页，共1063页\n\nIV. 应提交的文件\n\n1. 与由任何2004取证对象持有、控制、代表其持有或以其他方式与其有关的任何账户相关的所有文件，包括任何及所有账户对账单、授权书、委托书、信托、指示或表格、已注销支票副本、通信函件，以及电汇和相关通信函件及指示。\n\n2. 与属于、由任何2004取证对象持有、控制或转移、代表其持有、控制或转移，或以其他方式与其有关的任何资金、加密货币、证券、财产或资产相关的所有文件，包括任何及所有账户对账单、授权书、委托书、信托、指示或表格、已注销支票副本、通信函件，以及电汇和相关通信函件及指示。\n\n3. 与同任何2004取证对象进行的任何商业、贸易或金融交易相关的所有文件，包括但不限于任何贷款、信用额度、保管、存款、掉期、证券交易、抵押贷款或 ISDA，包括任何及所有账户对账单、授权书、委托书、信托、指示或表格、已注销支票副本、通信函件，以及电汇和相关通信函件及指示。\n\n4. 与2004取证对象有关的任何电汇活动相关的所有文件，无论是否存在任何账户，包括但不限于所有电汇收据、账号、余额、授权书、与转账当事人相关的身份识别信息、通信函件、指示或其他记录。\n\n5. 与您和2004取证对象之间的任何函件及通信相关的所有文件。\n\n6. 与任何2004取证对象的任何账户相关、涉及开立该账户、该账户获授权用户及该账户维护的所有文件。\n\n案件 22-50073 文件 1592 于 03/24/23 提交，于 03/24/23 10:57:37 登记 第731页，共1063页\n\n7. 与任何2004取证对象有关的任何反洗钱、了解你的客户或其他合规活动相关的所有文件，包括但不限于任何2004取证对象提供的任何信息，或您获知的任何信息。\n\n8. 与来自任何国家的任何监管机构进行的、涉及任何2004取证对象的任何通信相关的所有文件，包括但不限于 Bank of England（英格兰银行）、United States Federal Reserve（美国联邦储备系统）、S.E.C.（美国证券交易委员会）、CFTC（美国商品期货交易委员会）、FINRA（美国金融业监管局）、China Securities Regulatory Commission（中国证券监督管理委员会）、People's Bank of China（中国人民银行）、Hong Kong Securities and Futures Commission（香港证券及期货事务监察委员会）及 Hong Kong Monetary Authority（香港金融管理局）。\n\n附件 C-40\n\nB2540（表格2540——Rule 2004 审查传票）（12/15）案件 22-50073 文件 1592 于 03/24/23 提交，于 03/24/23 10:57:37 登记 第733页，共1063页\n\n美国破产法院\n\n康涅狄格地区\n\n关于 HO WAN KWOK（郭文贵）等人，\n\n1 案件编号 22-50073 (JAM)\n\n债务人 第11章\n\n（联合管理）\n\nRule 2004 审查传票\n\n致：RBB Bancorp（RBB银行控股公司）和／或 Royal Business Bank（皇家商业银行）\n\n（传票所指向之人的姓名）\n\n证言：兹命令您于下列规定的时间、日期和地点出席，依《联邦破产程序规则》Rule 2004 接受审查并作证。随附授权该审查的法院命令副本。\n\n地点　日期和时间\n\nNeubert, Pepe & Monteith, P.C.（诺伊伯特、佩佩及蒙特律师事务所）\n195 Church Street, Floor 13　[TBD]\nNew Haven, Connecticut 06510\n\n审查将通过以下方式记录：法庭记录员／速记员\n\n提交：您或您的代表还必须携带以下文件、电子存储信息或物品参加审查，并必须允许对该材料进行检查、复制、测试或取样：\n\n见随附的文件提交请求。\n\n下列 Fed. R. Civ. P. 45 规定已附上；该规定通过 Fed. R. Bankr. P. 9016 适用于破产案件——关于履行地点的 Rule 45(c)；关于作为受传票约束之人所受保护的 Rule 45(d)；以及关于您回应本传票的义务及不予回应的潜在后果的 Rule 45(e) 和 45(g)。\n\n日期：March , 2023\n\n法院书记员\n\n或\n\n书记员或副书记员签名　律师签名\n\n签发或请求签发本传票、代表第11章受托人 Luc A. Despins（卢克·A.·德斯平斯）的律师的姓名、地址、电子邮件地址和电话号码如下：\n\nDouglas S. Skalka, Esq.（道格拉斯·S.·斯卡尔卡律师）；Neubert, Pepe & Monteith, P.C.；195 Church Street, New Haven, Connecticut 06510 dskalka@npmlaw.com；(203) 821-2000\n\n致签发或请求签发本传票之人的通知\n\n如本传票命令在审判前提交文件、电子存储信息或有形物品，或检查场所，则必须在向传票所指向之人送达前，向每一方送达通知及本传票副本。Fed. R. Civ. P. 45(a)(4)。\n\n软件版权所有 (c) 1996-2022 Best Case, LLC - www.bestcase.com Best Case Bankruptcy 1 本第11章案件中的债务人为 Ho Wan Kwok（郭文贵，亦称 Guo Wengui、Miles Guo 和 Miles Kwok，以及众多其他别名）（税务识别号码后四位：9595）、Genever Holdings LLC（税务识别号码后四位：8202）及 Genever Holdings Corporation。受托人、Genever Holdings LLC 及 Genever Holdings Corporation 的邮寄地址为 Paul Hastings LLP（普衡律师事务所），200 Park Avenue, New York, NY 10166，转交 Luc A. Despins，作为 Ho Wan Kwok 财产的受托人（仅为通知和通信之目的）。\n\n送达证明\n\n（除非 Fed. R. Civ. P. 45 要求，否则本节不应向法院提交。）\n\n我于（日期）收到针对（个人姓名及职务，如有）的本传票。\n\n我按如下方式向所列人员交付副本以送达本传票：\n\n于（日期）；或\n\n我未执行传票即予退回，原因如下：\n\n除非本传票代表美国或其官员或代理人之一签发，我还已向证人预付一天出席费用及法律允许的里程费，金额为 $ 。\n\n我的差旅费用为 $ ，服务费用为 $ ，合计为 $ 。\n\n本人谨以伪证罪处罚之责任声明，该信息真实且正确。\n\n日期：\n\n送达人签名\n\n正楷姓名及职务\n\n送达人地址\n\n关于尝试送达等事项的补充信息：\n《联邦民事诉讼规则》第45(c)、(d)、(e)及(g)条（2013年12月1日生效）（根据《联邦破产程序规则》第9016条适用于破产案件）\n(c) 履行地点。\n\n(1) 审判、听证或证言录取。传票仅可按如下规定命令某人出席审判、听证或证言录取：\n\n(A) 在该人居住、受雇或经常亲自从事商业活动地点的100英里以内；或\n\n(B) 在该人居住、受雇或经常亲自从事商业活动所在州内，且该人\n\n(i) 为当事人或当事人的高级职员；或\n\n(ii) 被命令出席审判且不会产生重大费用。\n\n(2) 其他证据开示。传票可以命令：\n\n(A) 在该人居住、受雇或经常亲自从事商业活动地点的100英里以内某一地点，提交文件、电子存储信息或物品；以及\n\n(B) 在拟检查的不动产处检查该不动产。\n(d) 保护受传票约束之人；执行。\n\n(1) 避免不当负担或费用；制裁。负责签发和送达传票的当事人或律师，必须采取合理步骤，避免对受传票约束之人施加不当负担或费用。要求履行的地区法院必须执行该义务，并对未遵守该义务的当事人或律师施加适当制裁，制裁可包括损失的收入及合理的律师费。\n(2) 命令提交材料或允许检查。\n\n(A) 无须出席。被命令提交文件、电子存储信息或有形物品，或允许检查不动产的人，无须亲自到提交或检查地点出席，除非其同时被命令出席证言录取、听证或审判。\n\n(B) 异议。被命令提交文件或有形物品，或允许检查的人，可以向传票中指定的当事人或律师送达书面异议，反对检查、复制、测试或抽样任何或全部材料，或反对检查不动产，或反对以所要求的一种或多种形式提交电子存储信息。异议必须在指定履行时间或传票送达后14日（以较早者为准）之前送达。如提出异议，适用下列规则：\n\n(i) 送达方可在任何时候，在通知被命令之人后，向要求履行的地区法院提出动议，请求作出强制提交或检查的命令。\n\n(ii) 仅可依照命令所指示的方式要求实施该等行为，并且该命令必须保护既非当事人亦非当事人高级职员之人，免受因履行而产生的重大费用。\n(3) 撤销或修改传票。\n\n(A) 必须撤销或修改的情形。经及时动议，要求履行的地区法院必须撤销或修改具有下列情形的传票：\n\n(i) 未给予合理的履行时间；\n\n(ii) 要求某人在第45(c)条规定的地域限制以外履行；\n\n(iii) 要求披露享有特权或受其他保护的事项，且不适用任何例外或豁免；或\n\n(iv) 对某人施加不当负担。\n\n(B) 可以撤销或修改的情形。为保护受传票约束或受传票影响之人，要求履行的地区法院可经动议，在传票要求下列事项时撤销或修改传票：\n\n(i) 披露商业秘密或其他保密的研究、开发或商业信息；或\n\n(ii) 披露未受聘专家的意见或信息，该等意见或信息既未描述争议中的具体事件，也源于未经当事人请求的该专家研究。\n\n(C) 以规定条件作为替代方案。在第45(d)(3)(B)条所述情形下，如送达方：\n\n(i) 证明对该证言或材料具有重大需要，且不遭受不当困难便无法以其他方式满足该需要；并且\n\n(ii) 确保受传票传唤之人将获得合理补偿，\n\n法院可不撤销或修改传票，而命令在规定条件下出席或提交材料。\n(e) 对传票作出回应时的义务。\n\n(1) 提交文件或电子存储信息。以下程序适用于提交文件或电子存储信息：\n\n(A) 文件。回应提交文件传票之人必须按照文件在日常业务过程中保存的方式提交，或者必须将文件整理并标注，以对应请求中的类别。\n\n(B) 未指定电子存储信息的提交形式。如传票未指定提交电子存储信息的形式，回应之人必须以其通常保存的一种或多种形式，或以合理可用的一种或多种形式提交。\n\n(C) 电子存储信息仅以一种形式提交。回应之人无须以一种以上形式提交相同的电子存储信息。\n\n(D) 无法获取的电子存储信息。回应之人无须从其认定为因不当负担或费用而无法合理获取的来源提供电子存储信息的证据开示。对于强制证据开示动议或保护令动议，回应之人必须证明该信息因不当负担或费用而无法合理获取。如作出该证明，法院在考虑第26(b)(2)(C)条的限制后，如请求方证明存在正当理由，仍可命令从该等来源进行证据开示。法院可为该证据开示规定条件。\n(2) 主张特权或保护。\n\n(A) 扣留的信息。基于该信息享有特权或作为审判准备材料受到保护而扣留被传票要求的信息之人，必须：(i) 明确提出该主张；并且\n\n(ii) 在不披露本身享有特权或受保护信息的情况下，以足以使当事人评估该主张的方式，描述被扣留文件、通信或有形物品的性质。\n\n(B) 已提交的信息。如为回应传票而提交的信息受特权主张或作为审判准备材料受保护的主张约束，提出该主张之人可将该主张及其依据通知任何收到该信息的当事人。收到通知后，当事人必须立即返还、隔离或销毁指定信息及其持有的任何副本；在该主张得到解决前不得使用或披露该信息；如该当事人在收到通知前已披露该信息，必须采取合理步骤予以追回；并且可立即将该信息密封提交给要求履行的地区法院，以裁定该主张。提交该信息之人必须在该主张得到解决前保存该信息。\n\n(g) 藐视法庭。要求履行的地区法院，以及在动议被移送后签发传票的法院，均可对已被送达但无充分理由不遵守传票或与其有关命令之人作出藐视法庭处罚。\n\n如需查阅传票材料，参见Fed.R.Civ.P.45(a)委员会说明（2013年）\n\n……\n\n文件提交请求\nI. 指示\n\n1. 除非另有说明，下列文件请求（以下简称“请求”，每一项称为“一项请求”）必须分别且具体地作出回应。除非基于诚信提出异议，否则必须对每项请求作出完整答复；如提出异议，则必须按如下规定详细说明贵方异议的理由。如异议仅涉及某项请求的一部分，或者其中的某一词语、短语或条款，贵方必须仅对该部分提出异议，并对其余请求作出回应。\n\n2. 电子存储信息必须依照以下指示提交：\n\na. 图像。黑白图像必须为300 DPI Group IV单页TIFF文件。彩色图像必须以JPEG格式提交。文件名不得含有嵌入空格或特殊字符（包括逗号）。文件夹名称不得含有嵌入空格或特殊字符（包括逗号）。所有TIFF图像文件必须具有唯一文件名，即Bates编号。每张图像的右下角必须标注连续的Bates编号。每个文件夹中的TIFF文件数量不得超过1000个。Excel电子表格应具有以该文件的Bates编号命名的占位图像。\n\nb. 图像加载文件\n\na. Concordance®数据文件。数据文件（.DAT）包含将被加载至Concordance®数据库的所有字段信息。.DAT文件的第一行必须为识别字段名称的标题行。.DAT文件必须使用以下Concordance®默认分隔符：逗号ASCII字符（020）引号þ ASCII字符（254）。日期字段应以如下格式提供：mm/dd/yyyy。日期和时间字段必须为两个独立字段。如文件包括已成像的电子邮件及附件，则必须包括附件字段，以保留电子邮件及其附件之间的父/子关系。必须包括OCRPATH字段，以提供在所提交存储介质上提取文本文件的文件路径及名称。文本文件必须以FIRSTBATES命名。不得在.DAT文件中包含文本。对于含有原生文件的文件，必须包括LINK字段，以提供原生文件的文件路径及名称。原生文件必须以FIRSTBATES命名。\n\nb. Concordance Image® 或 Opticon 交叉引用文件。图像交叉引用文件（.LOG 或 .OPT）将图像链接至数据库记录。该文件应为逗号分隔文件，每行由七个字段组成；数据库中的每一幅图像均应在交叉引用文件中有一行，格式如下：ImageID,VolumeLabel,ImageFilePath,DocumentBreak,FolderBreak,Box Break,PageCount。\n\nc. 文档文本。文本必须作为单独的文本文件提供，而非作为 .DAT 文件内的字段提供。文本文件的完整路径（OCRPATH）应载于 .DAT 文件中。建议提供文档级 ANSI 文本文件，并按 FIRSTBATES/Image Key 命名。提取的文本文件必须存放于单独的文件夹中，每个文件夹中的文本文件数量不得超过 1,000 个。文件夹名称中不得包含特殊字符（包括逗号）。文本文件必须按文档级提供。\n\nd. 某些文件类型的原生格式提供。为充分理解其内容和含义而合理需要以原生格式查看的文件类型，必须以原生格式提供。该等文件包括但不限于电子表格、类似电子表格的文件（Microsoft Excel、逗号分隔值、制表符分隔值等）、Microsoft PowerPoint 或其他特殊演示文件、数据库文件以及音频/视频文件。应提供一张带有 Bates 编号的提示页图像，以表明存在原生文件，并在 .dat 文件中将原生文件的路径列为一个字段。提供的原生文件应以与该文件提示页相对应的 Bates 编号命名。原生文件应归入按递增方式命名的“NATIVE”目录中，并与图像目录分开。\n\ne. 去重。对于存在完全重复件的每一电子文档，仅提供一份副本。对于电子邮件，应根据由 BCC、Body、CC、From、IntMsgID、To 和 Attach 属性生成的 MD5 哈希值合并重复件。对于电子邮件附件及独立电子文件，应根据整个文件的 MD5 哈希值合并重复件。\n\nf. 元数据。应以符合 Concordance 标准的载入文件（.dat）形式，为每一文档提供提取的元数据。.DAT 文件的第一行必须为标识字段名称的标题行。.DAT 文件必须使用以下 Concordance 默认分隔符：逗号 , ASCII 字符（020）引号 þ ASCII 字符（254）\n\n日期字段应按以下格式提供：mm/dd/yyyy。日期和时间字段必须为两个单独字段。下列为必需元数据：\n\nCase 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 738 of 1063\n\n字段名称　示例数据　说明\n\nFIRSTBATES　EDC0000001　原生文件文档/电子邮件的第一个 Bates 编号\n\nLASTBATES　EDC0000001　原生文件文档/电子邮件的最后一个 Bates 编号\n\nLASTBATES 字段应针对单页文件予以填写\n\nATTACHRANGE　EDC0000001\n-　父文档首页的 Bates 编号至最后一个附件“子”文档最后一页的 Bates 编号\nEDC0000015\n\nBEGATTACH　EDC0000001　附件范围的第一个 Bates 编号\n\nENDATTACH　EDC0000015　附件范围的最后一个 Bates 编号\n\nCUSTODIAN　Smith, John　电子邮件：该电子邮件所在的邮箱\n原生文件：文档来源的个人或部门名称\n\nFROM　John Smith　电子邮件：发件人\n原生文件：文档作者\n多个条目应以分号分隔\n\nTO　Coffman, Janice; LeeW　收件人\n[mailto:LeeW@MSN.com]　多个条目应以分号分隔\n\nCC　Frank Thompson [mailto:　抄送收件人\nfrank_Thompson@cdt.com]　多个条目应以分号分隔\n\nBCC　John Cain　密送收件人\n多个条目应以分号分隔\n\nSUBJECT　Board Meeting Minutes　电子邮件：电子邮件主题行 原生文件：文档标题（如有）\n\nFILE_NAME　BoardMeetingMinutes.docx　原生文件：原始原生文件的名称，包括扩展名\n\nDATE_SENT　10/12/2010　电子邮件：电子邮件发送日期\n原生文件：（空）\n\nTIME_SENT/\nTIME_ZONE　07:05 PM GMT　电子邮件：电子邮件发送时间/电子邮件被标准化所使用的时区\n\nTIME_ZONE　GMT　在转换过程中电子邮件被标准化所使用的时区。\n\nLINK　EDC0000001.msg　指向电子邮件或原生文件文档的超链接\n链接文件必须按 FIRSTBATES 编号命名\n\nFILE_EXTEN　MSG　表示电子邮件或原生文件文档的文件类型扩展名\n\nAUTHOR　John Smith　电子邮件：（空）\n原生文件：文档作者\n\nDATE_CREATED　10/10/2010　电子邮件：（空）\n原生文件：文档创建日期\n\nCase 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 739 of 1063\n\nTIME_CREATED　10:25 AM　电子邮件：（空）\n原生文件：文档创建时间\n该数据必须为单独字段，不得与 DATE_CREATED 字段合并\n\nDATE_MOD　10/12/2010　电子邮件：（空）\n原生文件：文档最后修改日期\n\nTIME_MOD　07:00 PM　电子邮件：（空）\n原生文件：文档最后修改时间\n该数据必须为单独字段，不得与 DATE_MOD 字段合并\n\nDATE_ACCESSD　10/12/2010　电子邮件：（空）\n原生文件：文档最后访问日期\n\nTIME_ACCESSD　07:00 PM　电子邮件：（空）\n原生文件：文档最后访问时间\n该数据必须为单独字段，不得与 DATE_ACCESSD 字段合并\n\nFILE_SIZE　5,952　原生文件文档/电子邮件的大小，以 KB 计\n\nPGCOUNT　1　原生文件文档/电子邮件的页数\n\nPATH　电子邮件：（空）\nAgenda.doc　原生文件：存储原生文件文档的路径，包括原始文件名称。\n\nINTFILEPATH　Personal Folders\\Deleted　电子邮件：电子邮件的原始位置，包括原始文件名称。\nItems\\Board Meeting　原生文件：（空）\nMinutes.msg\n\nINTMSGID　<000805c2c71b$75977050$　电子邮件：唯一消息 ID 原生文件：（空）\ncb8306d1@MSN>\n\nMD5HASH　d131dd02c5e6eec4693d9a0698aff95c2fcab58712467eab4004583eb8fb7f89　文档的 MD5 哈希值。\n\nOCRPATH　TEXT/001/EDC0000001.txt　原生文件提取文本的路径\n\n3. 每项请求均独立运作并应独立解释，除非另有说明，任何请求均不限制任何其他请求的范围。\n\n4. 所有文档应按其在日常业务过程中保存的方式提供，或应予以组织和标记，以对应于本请求中的类别。\n\n5. 本文所载每项请求均延伸至所有文档：（a）由您占有、保管或控制的文档；或（b）由代表您行事的任何人占有、保管或控制的文档，\n\nCase 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 740 of 1063\n\n包括您的律师或其他代表及顾问。每份文档均应完整提供。\n\n6. 如要求您提供的某份文档已不再由您占有、保管或控制，则您的答复必须：（a）详细说明该文档的性质及其内容；（b）确认编制或撰写该文档的人（以及，如适用，该文档的发送对象）；（c）确认该文档编制或创建的日期；（d）说明该文档是否（i）缺失或遗失、（ii）已被销毁、（iii）自愿或非自愿地转移给他人，或（iv）以其他方式处置；（e）说明该等处置的原因及相关事实和情形；（f）确认授权该等处置的人员；（g）确认该等处置的日期或大致日期；（h）说明该文档最近一次由您占有、保管或控制的时间；以及（i）确认目前占有、保管或控制该文档的人员（如有）。\n\n7. 如要求您提供的某份文档已被销毁，则除前述指示所要求的信息外，您的答复还必须说明：（a）销毁该文档的原因；（b）销毁该文档的人员身份；以及（c）指示销毁该文档的人员身份。\n\n8. 如您主张所请求的文档享有特权或属于律师工作成果，则您的答复必须：（a）说明（i）足以支持您关于该文档享有特权之主张的文档描述、（ii）文档标题、（iii）文档日期、（iv）文档作者、（v）文档收件人、（vi）收到或见到该文档原件或任何草稿、副本或复制件的每一人员身份、（vii）该文档本身或该文档中包含或提及的任何信息是否由任何其他人员占有、保管或控制，如是，则确认该等人员身份，并说明该等人员如何取得该信息、（viii）据以扣留该文档的特权主张，以及（ix）您将依赖以支持该等特权主张的所有情形；以及（b）根据 D. Conn. L. Civ. R. 26(e)，就基于特权主张而扣留的每一文档，提供一份特权清单，载明本指示第（a）部分所要求的全部信息。对于文档请求中未提出特权或工作成果主张的任何部分，应完整提供响应性文档。\n\nCase 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 741 of 1063\n\n9. 如一份原本具有响应性的文档的一部分包含受特权主张约束的信息，则仅应依照上述指示从该文档中删除或遮盖受特权主张约束的该部分，其余部分应予提供。\n\n10. 本请求具有持续性。特此指示您：（a）在获悉先前答复不完整或不正确后，立即补充或更正任何后来获悉为不完整或不正确的答复；以及（b）提供根据下列内容所要求的任何补充文档\n\n11. 如某份文档使用英语以外的语言，您应提供该文档。如某份文档使用英语以外的语言，且存在英文译本，您应同时提供两份文档。\n\n12. 凡提及实体，均包括其所有关联方。\n\n13. 凡提及个人姓名，均包括所有别名、化名或昵称。\n\nCase 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 742 of 1063\n\n14. 除非另有明确说明，文档请求所涵盖的期间为自 February 5, 2012 起至文档请求答复到期之日止。\nII. 解释规则\n\n15. （a）任何单数名词的使用应解释为包括复数，反之亦然；以及（b）任何时态动词的使用应解释为包括该动词所有其他时态的使用。\n\n16. （a）“and”和“or”应在必要时解释为连词或析取词，以使原本可能被解释为不在任何请求范围内的所有答复均纳入该请求范围；以及（b）“each”和“any”应视为包括并涵盖“every”和“all”。\nIII. 定义\n\n经 D. Conn. Bankr. L.R. 2004-1(a) 纳入的 D. Conn. L. Civ. R. 26(c) 所规定的定义及 D. Conn. L. Civ. R. 26(d) 所规定的解释规则，适用于文档请求。此外，本文件请求中使用的下列术语具有以下含义：\n\n1. “You”“Your”或“Yourself”系指 RBB Bancorp 和/或 Royal Business Bank（皇家商业银行），连同其所有关联方、部门、机构、工具机构、处室、办事处、合伙人、高级职员、董事、代理人、律师、代表、雇员和/或代表其行事的任何人。\n\nCase 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 743 of 1063\n\n2. “债务人”系指 Ho Wan Kwok（郭文贵，亦称 Miles Kwok、Miles Guo、Guo Wengui、Guo Haoyun、郭文贵或任何其他别名），连同其雇员、代理人、律师、顾问或任何代表其行事之人。\n\n3. “债务人之子”系指 Qiang Guo（郭强，亦称 Mileson Kwok、郭强或任何其他别名），连同其雇员、代理人、律师、顾问或任何代表其行事之人。\n\n4. “债务人之女”系指 Mei Guo（郭美，亦称 Mei Gui、郭美或任何其他别名），连同其雇员、代理人、律师、顾问或任何代表其行事之人。\n\n5. “债务人所谓的妻子”系指 Hing Chi Ngok（岳庆芝，亦称 Hing Chi Ng、Yue Qingzhi、岳庆芝或任何其他别名），连同其雇员、代理人、律师、顾问或任何代表其行事之人。\n\n6. “债务人家庭成员”系指，单独及合称，债务人、债务人之子、债务人之女及债务人所谓的妻子，以及与债务人有任何其他亲属关系之人。\n\n7. “2004规则取证对象”系指，单独及合称，债务人、债务人家庭成员、Prime Trust LLC（信托优选有限责任公司）、U.S. Bank National Association（美国合众银行全国协会）、ACA Capital Group Limited（ACA资本集团有限公司）、Himalaya International Financial Group Ltd.（喜马拉雅国际金融集团有限公司）、Himalaya International Clearing Ltd.（喜马拉雅国际清算有限公司）、Himalaya International Payments Ltd.（喜马拉雅国际支付有限公司）、Himalaya International Reserves Ltd.（喜马拉雅国际储备有限公司）、Jesse Brown（杰西·布朗）、William Je（威廉·杰）、William Je（威廉·杰）、Eastern Profit Corporation Limited（东方利润有限公司）、HK International Funds Investments (USA) Limited LLC（香港国际基金投资〈美国〉有限责任公司）、Bravo Luck Limited（鸿运有限公司）、Golden Spring (New York) Ltd.（金泉〈纽约〉有限公司）、Lamp Capital LLC（蓝普资本有限责任公司）、Greenwich Land LLC（格林威治土地有限责任公司）、Qu Guo Jiao（郭娇）、Daniel Thomas Podhaskie（丹尼尔·托马斯·波德哈斯基）、Yvette Wang（王艳萍，亦称 Yanping Wang、Yan Ping Wang）、Ace Decade Holdings Limited（王牌十年控股有限公司）、Dawn State Limited（曙光州有限公司）、Rule of Law Society IV Inc.（法治协会IV公司）、Rule of Law Foundation III, Inc.（法治基金会III公司）、Rule of Law Foundation IV, Inc.（法治基金会IV公司）、Rule of Law Fund（法治基金）、Rule of Law Society（法治协会）、GTV Media Group, Inc.（GTV媒体集团公司）、Voice of Guo Media, Inc.（郭媒体之声公司）、Saraca Media\n\n案号 22-50073 文件1592 提交日期 03/24/23 登记日期 03/24/23 10:57:37 第744页，共1063页\n\nGroup Inc.（Saraca媒体集团公司）、Genever Holdings Corporation（Genever控股公司）、Genever Holdings LLC（Genever控股有限责任公司）、Gnews Media Group Inc.（Gnews媒体集团公司）、G Fashion LLC（G时尚有限责任公司）、Gmusic LLC（G音乐有限责任公司）、Gnews LLC（G新闻有限责任公司）、Geducation（G教育）、GFNY, Inc.（GFNY公司）、G-Club Investments Limited（G-Club投资有限公司）、G Club Operations LLC（G Club运营有限责任公司）、G Club US Operations Inc.（G Club美国运营公司）、G Club US Operations LLC（G Club美国运营有限责任公司）、G Live, LLC（G Live有限责任公司）、Gbroadcast, LLC（G广播有限责任公司）、Gposts LLC（G帖子有限责任公司）、HCHK Property Management, Inc.（HCHK物业管理公司）、HCHK Technologies, Inc.（HCHK技术公司）、FMV Ltd./Freedom Media Venture Ltd.（FMV有限公司／自由媒体创投有限公司）、Roscalitar 2（Roscalitar 2）、Himalaya New World Inc.（喜马拉雅新世界公司）、US Himalaya Capital Inc.（美国喜马拉雅资本公司）、Hudson Diamond Holding, Inc.（哈德逊钻石控股公司）、Hudson Diamond Holding LLC（哈德逊钻石控股有限责任公司）、Hudson Diamond NY LLC（哈德逊钻石纽约有限责任公司）、Infinity Treasury Management Inc.（无限财资管理公司）、Lexington Property and Staffing, Inc.（列克星敦物业与人力公司）、AI Group Holdings Inc.（AI集团控股公司）、Hamilton Capital Holdings Inc.（汉密尔顿资本控股公司）、Booming Sail New York LLC（兴帆纽约有限责任公司）、Himalaya Ventures LLC（喜马拉雅创投有限责任公司）、Himalaya Ventures LLC（喜马拉雅创投有限责任公司）、Himalaya Investment LLC（喜马拉雅投资有限责任公司）、New York MOS Himalaya LLC（纽约MOS喜马拉雅有限责任公司）、MOS Himalaya LLC（MOS喜马拉雅有限责任公司）、Crane Advisory Group（克兰咨询集团）、Maywind Trading LLC（五月风贸易有限责任公司）、Gettr USA, Inc.（Gettr美国公司）、Han Chunguang（韩春光）、Bingshang Jiao（焦冰尚）、Karin Maistrello（卡琳·迈斯特雷洛）、Mary Jiang（江玛丽）、Jiaming Liu（刘家明）及 Wencong Wang（王文聪）。\n\n8. “包括”或其任何变体，系指“包括但不限于”。\n\n9. “和”及“或”系指“和／或”，且应作连言及选言解释，以最大限度地扩展其范围。\n\n10. “任何”及“全部”及“每一”系指“每一个及所有”。\n\n11. “每一”及“每个”系指“每一个及所有”。\n\n12. “第三方”系指除贵方以外的个人或实体。\n\n13. “转让”应具有《破产法典》第101(54)条赋予该词的含义。\n\n14. “文件”系指属于《联邦民事诉讼规则》第34条范围内的任何信息或物品，并包括但不限于现由或曾由贵方占有、保管或控制的、任何种类、类型、性质或描述的每一份书面、记录或图形材料，包括\n\n案号 22-50073 文件1592 提交日期 03/24/23 登记日期 03/24/23 10:57:37 第745页，共1063页\n\n电子邮件的所有纸质及电子副本、以电子形式保存的计算机文件、通信函件、备忘录、磁带、速记或手写笔记、任何种类的书面表格、图表、蓝图、绘图、草图、图形、计划、文章、规格说明、日记、信函、电报、照片、会议记录、合同、协议、调查资料、计算机打印件、任何种类的数据汇编、电传、传真、电子邮件、短信、即时消息、语音留言、发票、订单表格、支票、汇票、对账单、贷项通知单、报告、持仓报告、摘要、索引、账簿、分类账、笔记本、日程表、透明片、录音、目录、广告、宣传材料、电影、录像带、录音带、CD、计算机磁盘、宣传册、小册子、穿孔卡、工时单、推文、社交媒体帖子或任何其他种类的书面或记录材料，以及其全部元数据，无论以何种方式存储（无论为有形或电子形式）、记录、制作或复制；还包括但不限于前述任何材料的草稿或副本，如其中载有原始文件中不存在的任何种类笔记、评论或标记，或其在其他方面与原始文件不一致。\n\n15. “个人”系指个人、公司、独资企业、合伙企业、协会或任何其他实体。“个人”还包括任何代理人、代表或专家，包括但不限于律师或财务顾问。\n\n16. “实体”系指任何自然人、公司、合伙企业、子公司、独资企业、商号、董事会、合资企业、协会、机构、主管机关、委员会或其他商业实体或法人，以及任何关联方、代理人、母公司，包括但不限于法律顾问、财务顾问或任何其他代表。\n\n17. “关于”系指涉及、描述、构成、提及、与之相关、支持、赞成、反对、强化、减损、位于其中、结合其予以考虑、对其有影响、证明、表明、报告、记录、暗示、回应、与之连接、评论、就其而言、有关、与之相关、讨论、展示、描述、反映、分析、构成及属于。\n\n案号 22-50073 文件1592 提交日期 03/24/23 登记日期 03/24/23 10:57:37 第746页，共1063页\n\n18. 就任何特定事项而言，“与……有关”、“涉及”或“相关”系指，包括但不限于，构成、包含、涉及、含有、体现、反映、识别、陈述、直接或间接提及所识别的特定事项，或以任何方式与该特定事项有关的任何文件。\n\n19. “通信”系指，在最广泛可能意义上且不受限制地，任何信息或知识的传递（以事实、观点、询问或其他形式）。通信还系指所有谈话、协议、询问或答复，无论是当面、通过电话、以书面形式，还是通过电子传输设备，并包括但不限于所有通信函件、电子邮件、录音、传递单、备忘录、电话通信、语音留言、电报、电话传真、影印传真、电传、即时消息、聊天、短信、在留言板或群聊中的帖子、社交媒体帖子、推文、上传至任何视频平台的视频、电话笔记，或在内部或与第三方之间传递的笔记。\n\n20. “资产”系指受占有、保管或控制的任何具有经济价值的项目。资产包括所有不动产和动产，包括但不限于房地产、土地、房屋、公寓、共管公寓、汽车、游艇、船只、飞机、喷气机、直升机、现金、银行账户、加密货币、证券、应收账款、存货及其他有形和无形财产。\n\n案号 22-50073 文件1592 提交日期 03/24/23 登记日期 03/24/23 10:57:37 第747页，共1063页\n\nIV. 应提交的文件\n\n1. 与由任何2004规则取证对象持有、控制、为其利益持有或以其他方式与其有关的任何账户有关的全部文件，包括任何及所有账户对账单、授权书、委托书、信托文件、指示或表格、已注销支票副本、通信函件、电汇以及相关通信函件和指示。\n\n2. 与属于、由任何2004规则取证对象持有、控制、为其利益持有或以其他方式与其有关的任何资金、加密货币、证券、财产或资产有关的全部文件，包括任何及所有账户对账单、授权书、委托书、信托文件、指示或表格、已注销支票副本、通信函件、电汇以及相关通信函件和指示。\n\n3. 与同任何2004规则取证对象进行的任何商业、贸易或金融交易有关的全部文件，包括但不限于任何贷款、信贷额度、寄托、存款、掉期、证券交易、抵押或ISDA，包括任何及所有账户对账单、授权书、委托书、信托文件、指示或表格、已注销支票副本、通信函件、电汇以及相关通信函件和指示。\n\n4. 与涉及2004规则取证对象的任何电汇活动有关的全部文件，不论是否存在任何账户，包括但不限于全部电汇收据、账号、余额、授权、与转账当事人有关的身份识别信息、通信函件、指示或其他记录。\n\n5. 与贵方和2004规则取证对象之间的任何往来函件及通信有关的全部文件。\n\n6. 与任何2004规则取证对象的任何账户有关的全部文件，涉及账户开立、账户获授权用户及账户维护。\n\n案号 22-50073 文件1592 提交日期 03/24/23 登记日期 03/24/23 10:57:37 第748页，共1063页\n\n7. 与涉及任何2004规则取证对象的任何反洗钱、了解你的客户或其他合规活动有关的全部文件，包括但不限于任何2004规则取证对象提供的或贵方获知的任何信息。\n\n8. 与就任何2004规则取证对象而同任何国家的任何监管机构进行的任何通信有关的全部文件，包括但不限于 Bank of England（英格兰银行）、United States Federal Reserve（美国联邦储备系统）、S.E.C.（美国证券交易委员会）、CFTC（美国商品期货交易委员会）、FINRA（美国金融业监管局）、China Securities Regulatory Commission（中国证券监督管理委员会）、People's Bank of China（中国人民银行）、Hong Kong Securities and Futures Commission（香港证券及期货事务监察委员会）及 Hong Kong Monetary Authority（香港金融管理局）。\n\n附件C-41\n\nB2540（表格2540－2004规则审查传票）（12/15）案号 22-50073 文件1592 提交日期 03/24/23 登记日期 03/24/23 10:57:37 第750页，共\n\n美国破产法院 1063\n\n康涅狄格地区\n\n关于 HO WAN KWOK（郭文贵）等人，\n\n1 案号 22-50073 (JAM)\n\n债务人 第11章\n\n（合并管理）\n\n2004规则审查传票\n\n致：Medici Bank International LLC（梅迪奇国际银行有限责任公司）\n\n（传票送达对象姓名）\n\n证言：兹命令贵方于下列载明的时间、日期及地点出席，并根据《联邦破产程序规则》第2004条接受审查并作证。随附授权该审查的法院命令副本。\n\n地点　日期及时间\n\nPaul Hastings LLP（博浩律师事务所）\n200 Park Avenue　[TBD]\nNew York, New York 10166（纽约州纽约市10166）\n\n审查将以如下方式记录：法庭记录员／速记员\n\n提交：贵方或贵方代表还必须于审查时携带下列文件、电子存储信息或物品，并必须允许对该等材料进行查验、复制、测试或取样：\n\n见随附的文件提交请求。\n\n以下《联邦民事诉讼规则》第45条规定，根据《联邦破产程序规则》第9016条适用于破产案件，现随附：关于履行地点的第45(c)条；关于作为传票对象的贵方所获保护的第45(d)条；以及关于贵方回应本传票的义务及不予回应的可能后果的第45(e)条和第45(g)条。\n\n日期：March , 2023\n\n法院书记员\n\n或\n\n书记员或副书记员签名　律师签名\n\n代表签发或请求本传票的第11章受托人 Luc A. Despins（卢克·A·德斯平斯）的律师的姓名、地址、电子邮箱地址及电话号码如下：\n\nDouglas S. Skalka, Esq.（道格拉斯·S·斯卡尔卡律师）；Neubert, Pepe & Monteith, P.C.（纽伯特、佩佩与蒙蒂斯专业公司）；195 Church Street, New Haven, Connecticut 06510；dskalka@npmlaw.com；(203) 821-2000\n\n致签发或请求本传票之人的通知\n\n如本传票要求在审判前提交文件、电子存储信息或有形物品，或者检查场所，则必须在向被指定之人送达之前，向各方送达本传票的通知及副本。Fed. R. Civ. P. 45(a)(4)。\n\n软件版权 (c) 1996-2022 Best Case, LLC（百斯特凯斯有限责任公司）- www.bestcase.com Best Case Bankruptcy 1 本第11章案件中的债务人为 Ho Wan Kwok（郭文贵）（又名 Guo Wengui、Miles Guo 和 Miles Kwok，以及众多其他别名）（税务识别号码后四位：9595）、Genever Holdings LLC（Genever Holdings有限责任公司）（税务识别号码后四位：8202）以及 Genever Holdings Corporation（Genever Holdings公司）。受托人、Genever Holdings LLC 及 Genever Holdings Corporation 的邮寄地址为 Paul Hastings LLP（保罗·黑斯廷斯律师事务所），200 Park Avenue, New York, NY 10166，收件人为 Luc A. Despins，作为 Ho Wan Kwok 遗产的受托人（仅为通知和通讯之目的）。\n\n送达证明\n\n（除非 Fed. R. Civ. P. 45 要求，否则本部分不应向法院提交。）\n\n我于（日 期）收到向（个人姓名及职务，如有）发出的本传票。\n\n我通过如下方式向被指名之人交付副本，送达本传票：\n\n于（日 期）；或\n\n我未执行而退回本传票，原因如下：\n\n除非本传票系代表美国或其官员或代理人签发，我还已向证人支付一天出席费用及法律允许的里程费，金额为 $。\n\n我的差旅费用为 $，服务费用为 $，合计为 $。\n\n我在伪证处罚的约束下声明，该等信息真实且正确。\n\n日期：\n\n送达人员签名\n\n正楷姓名及职务\n\n送达人员地址\n\n关于尝试送达等事项的补充信息：\n\n《联邦民事诉讼规则》第45(c)、(d)、(e)及(g)条（自 12/1/13 起生效）（根据《联邦破产程序规则》第9016条适用于破产案件）\n\n(c) 履行地点。\n\n(1) 审判、听证或证言录取。传票仅可按如下方式要求一人出席审判、听证或证言录取：\n\n(A) 在该人居住、受雇或经常亲自从事商业活动地点的 100 英里以内；或\n\n(B) 在该人居住、受雇或经常亲自从事商业活动所在州内，如该人\n\n(i) 为一方当事人或一方当事人的高级职员；或\n\n(ii) 被要求出席审判且不会产生重大费用。\n\n(2) 其他证据开示。传票可以要求：\n\n(A) 在该人居住、受雇或经常亲自从事商业活动地点的 100 英里以内的地点提交文件、电子存储信息或物品；以及\n\n(B) 在应受检查的场所检查场所。\n\n(d) 对受传票约束之人的保护；执行。\n\n(1) 避免不当负担或费用；制裁。负责签发及送达传票的一方当事人或律师必须采取合理措施，避免对受传票约束之人施加不当负担或费用。要求履行的地区法院必须执行此项义务，并对未遵守者的一方当事人或律师施加适当制裁，该制裁可包括损失的收入和合理的律师费。\n\n(2) 要求提交材料或准许检查。\n\n(A) 无需出席。被要求提交文件、电子存储信息或有形物品，或准许检查场所之人，无须亲自出席提交或检查地点，除非同时被要求出席证言录取、听证或审判。\n\n(B) 异议。被要求提交文件或有形物品，或准许检查之人，可向传票中指定的一方当事人或律师送达书面异议，反对检查、复制、测试或抽样全部或部分材料，或反对检查场所，或反对以所要求的一种或多种形式提交电子存储信息。异议必须在指定履行时间之前或传票送达后 14 天之前（以较早者为准）送达。如提出异议，适用以下规则：\n\n(i) 送达方可在任何时候，经通知被要求之人后，向要求履行的地区法院提出动议，申请作出强制提交或检查的命令。\n\n(ii) 仅可按命令所指示的方式要求实施该等行为，且该命令必须保护并非一方当事人或一方当事人高级职员之人，使其免受因履行而产生的重大费用。\n\n(3) 撤销或修改传票。\n\n(A) 必须撤销或修改的情形。经及时动议，要求履行的地区法院必须撤销或修改以下传票：\n\n(i) 未给予合理履行时间；\n\n(ii) 要求一人在第45(c)条规定的地域范围以外履行；\n\n(iii) 要求披露享有特权或受其他保护的事项，而不存在适用的例外或豁免；或\n\n(iv) 使一人承受不当负担。\n\n(B) 可以撤销或修改的情形。为保护受传票约束或受其影响之人，要求履行的地区法院可以根据动议，在传票要求以下事项时撤销或修改传票：\n\n(i) 披露商业秘密或其他保密的研究、开发或商业信息；或\n\n(ii) 披露未受聘专家的意见或信息，该等意见或信息并未说明争议中的具体事件，且系该专家未应一方当事人请求所进行研究的结果。\n\n(C) 作为替代方案规定条件。在第45(d)(3)(B)条所述情形下，如送达方：\n\n(i) 证明其对证言或材料具有重大需要，且在不造成不当困难的情况下无法以其他方式满足该需要；并且\n\n(ii) 确保被传唤之人将获得合理补偿，\n\n则法院可以不撤销或修改传票，而命令在规定条件下出席或提交。\n\n(e) 对传票作出回应的义务。\n\n(1) 提交文件或电子存储信息。以下程序适用于提交文件或电子存储信息：\n\n(A) 文件。回应要求提交文件之传票的人必须按文件在正常业务过程中保存的方式提交，或者必须将文件整理并标记，以对应请求中的类别。\n\n(B) 未指定电子存储信息的提交形式。如传票未指定电子存储信息的提交形式，回应之人必须以其通常保存的一种或多种形式，或者以合理可使用的一种或多种形式提交。\n\n(C) 电子存储信息仅以一种形式提交。回应之人无须以一种以上形式提交同一电子存储信息。\n\n(D) 无法访问的电子存储信息。回应之人无须就其确定因不当负担或费用而无法合理访问的来源中的电子存储信息提供证据开示。在申请强制证据开示或保护令的动议中，回应之人必须证明该信息因不当负担或费用而无法合理访问。如作出该证明，若请求方在考虑第26(b)(2)(C)条限制后证明存在正当理由，法院仍可命令对该等来源进行证据开示。法院可以对该证据开示规定条件。\n\n(2) 主张特权或保护。\n\n(A) 扣留的信息。以该信息享有特权或作为审判准备材料受保护为由扣留被传唤信息之人，必须：(i) 明确提出该主张；并且\n\n(ii) 以一种在不披露本身享有特权或受保护信息的情况下，足以使各方当事人评估该主张的方式，说明被扣留文件、通讯或有形物品的性质。\n\n(B) 已提交的信息。如为回应传票而提交的信息受到特权主张或作为审判准备材料受保护的主张，提出该主张之人可将该主张及其依据通知任何收到该信息的一方当事人。收到通知后，一方当事人必须立即返还、隔离或销毁所指定的信息及其持有的任何副本；在该主张得到解决前不得使用或披露该信息；如该方当事人在收到通知前已披露该信息，必须采取合理措施取回该信息；并可立即将该信息密封提交给要求履行的地区法院，以裁定该主张。提交该信息之人必须在该主张得到解决前保存该信息。\n\n(g) 藐视法庭。要求履行的地区法院——并且在动议被移送后，签发法院——可以认定已被送达但无充分理由不遵守传票或相关命令之人构成藐视法庭。\n\n有关获取传票材料，见 Fed.R.Civ.P.45(a) Committee Note (2013)\n\n…\n\n文件提交请求\n\n一、指示\n\n1. 除非另有说明，下列文件请求（以下简称“请求”，各称“一项请求”）必须分别且具体地作出回应。除非基于善意提出异议，否则必须完整答复每项请求；如提出异议，则必须按照下文规定详细说明贵方异议的理由。如异议仅涉及某项请求的一部分，或其中所含的某个词语、短语或条款，贵方仅须说明对该部分的异议，并回应请求的其余部分。\n\n2. 电子存储信息必须按照以下指示提交：\n\na. 图像。黑白图像必须为 300 DPI Group IV 单页 TIFF 文件。彩色图像必须以 JPEG 格式提交。文件名不得含有嵌入空格或特殊字符（包括逗号）。文件夹名称不得含有嵌入空格或特殊字符（包括逗号）。所有 TIFF 图像文件必须具有唯一文件名，即 Bates 编号。每幅图像右下角必须标注连续的 Bates 编号。每个文件夹中的 TIFF 文件数量不得超过 1000 个文件。Excel 电子表格应具有以该文件的 Bates 编号命名的占位图像。\n\nb. 图像加载文件\n\na. Concordance® 数据文件。数据文件（.DAT）包含将加载至 Concordance® 数据库的全部字段信息。.DAT 文件的第一行必须为识别字段名称的标题行。.DAT 文件必须使用以下 Concordance® 默认分隔符：逗号 ASCII 字符（020）引号 þ ASCII 字符（254）。日期字段应按 mm/dd/yyyy 格式提供。日期和时间字段必须为两个独立字段。如文件包括已生成图像的电子邮件及附件，则必须包括附件字段，以保留电子邮件与其附件之间的父/子关系。必须包括 OCRPATH 字段，以提供所提交存储介质上提取文本文件的文件路径及名称。文本文件必须以 FIRSTBATES 命名。不得在 .DAT 文件中包含文本。对于含有原生文件的文件，必须包括 LINK 字段，以提供原生文件的文件路径及名称。原生文件必须以 FIRSTBATES 命名。\n\nb. Concordance Image® 或 Opticon 交叉引用文件。图像交叉引用文件（.LOG 或 .OPT）将图像链接至数据库记录。该文件应为逗号分隔文件，每行由七个字段组成，并且数据库中的每一图像均应在交叉引用文件中对应一行，格式如下：ImageID,VolumeLabel,ImageFilePath,DocumentBreak,FolderBreak,BoxBreak,PageCount。\n\nc. 文件文本。文本必须作为单独的文本文件提供，不得作为 .DAT 文件中的字段提供。文本文件的完整路径（OCRPATH）应包括在 .DAT 文件中。建议提供以 FIRSTBATES/Image Key 命名的文档级 ANSI 文本文件。提取的文本文件必须存放于单独文件夹内，每个文件夹中的文本文件数量不得超过 1,000 个。文件夹名称中不得包含特殊字符（包括逗号）。必须按文档级别提供文本文件。\n\nd. 特定文件类型的原生格式提供。为充分理解其内容和含义而合理需要以原生格式查看的文件类型，必须以原生格式提供。该等文件包括但不限于电子表格、类电子表格文件（Microsoft Excel、逗号分隔值、制表符分隔值等）、Microsoft PowerPoint 或其他特殊演示文件、数据库文件以及音频/视频文件。应提供一张带有 Bates 编号的分隔页图像，表明存在原生文件，并将原生文件路径作为 .dat 文件中的字段列入。所提供的原生文件应以与该文件分隔页相对应的 Bates 编号命名。原生文件应归入按递增方式命名的“NATIVE”目录中，并与图像目录分开。\n\ne. 去重。对于存在完全重复件的每一电子文件，仅提供一份副本。对于电子邮件，应根据由 BCC、Body、CC、From、IntMsgID、To 和 Attach 属性生成的 MD5 哈希值合并重复件。对于电子邮件附件和独立电子文件，应根据整个文件的 MD5 哈希值合并重复件。\n\nf. 元数据。应以符合 Concordance 要求的加载文件（.dat）形式，为每一文件提供提取的元数据。 .DAT 文件的第一行必须为标识字段名称的标题行。 .DAT 文件必须使用以下 Concordance 默认分隔符：逗号 , ASCII 字符（020）引号 þ ASCII 字符（254）\n\n日期字段应采用以下格式提供：mm/dd/yyyy。日期和时间字段必须为两个独立字段。以下为必需元数据：\n案号 22-50073 文件 1592 提交于 03/24/23 录入于 03/24/23 10:57:37 第 755 页，共 1063 页\n\n字段名称　示例数据　说明\n\nFIRSTBATES　EDC0000001　原生文件文件/电子邮件的第一个 Bates 编号\nLASTBATES　EDC0000001　原生文件文件/电子邮件的最后一个 Bates 编号\n**对于单页文件，应填写 LASTBATES 字段\nATTACHRANGE　EDC0000001\n-　从父文件第一页的 Bates 编号至\nEDC0000015　最后一个附件“子”文件最后一页的 Bates 编号\nBEGATTACH　EDC0000001　附件范围的第一个 Bates 编号\nENDATTACH　EDC0000015　附件范围的最后一个 Bates 编号\nCUSTODIAN　Smith, John（约翰·史密斯）　电子邮件：该电子邮件所在的邮箱\n原生文件：文件来源的个人或部门名称\nFROM　John Smith（约翰·史密斯）　电子邮件：发件人\n原生文件：文件作者\n**多个条目之间应使用分号分隔\nTO　Coffman, Janice（珍妮丝·科夫曼）; LeeW\n[mailto:LeeW@MSN.com]　收件人\n**多个条目之间应使用分号分隔\nCC　Frank Thompson（弗兰克·汤普森） [mailto:\nfrank_Thompson@cdt.com]　抄送收件人\n**多个条目之间应使用分号分隔\nBCC　John Cain（约翰·凯恩）　密送收件人\n**多个条目之间应使用分号分隔\nSUBJECT　Board Meeting Minutes　电子邮件：电子邮件主题行 原生文件：文件标题（如有）\nFILE_NAME　BoardMeetingMinutes.docx　原生文件：原始原生文件名称，包括扩展名\nDATE_SENT　10/12/2010　电子邮件：电子邮件发送日期\n原生文件：（空）\nTIME_SENT/\nTIME_ZONE　07:05 PM GMT　电子邮件：电子邮件发送时间/电子邮件标准化所采用的时区\nTIME_ZONE　GMT　在转换过程中电子邮件被标准化所采用的时区。\nLINK　EDC0000001.msg　指向电子邮件或原生文件文件的超链接\n**链接文件必须以 FIRSTBATES 编号命名\nFILE_EXTEN　MSG　表示电子邮件或原生文件的文件类型扩展名\nAUTHOR　John Smith（约翰·史密斯）　电子邮件：（空）\n原生文件：文件作者\nDATE_CREATED　10/10/2010　电子邮件：（空）\n原生文件：文件创建日期\n案号 22-50073 文件 1592 提交于 03/24/23 录入于 03/24/23 10:57:37 第 756 页，共 1063 页\n\nTIME_CREATED　10:25 AM　电子邮件：（空）\n原生文件：文件创建时间\n**该数据必须为独立字段，不得与 DATE_CREATED 字段合并\nDATE_MOD　10/12/2010　电子邮件：（空）\n原生文件：文件最后修改日期\nTIME_MOD　07:00 PM　电子邮件：（空）\n原生文件：文件最后修改时间\n**该数据必须为独立字段，不得与 DATE_MOD 字段合并\nDATE_ACCESSD　10/12/2010　电子邮件：（空）\n原生文件：文件最后访问日期\nTIME_ACCESSD　07:00 PM　电子邮件：（空）\n原生文件：文件最后访问时间\n**该数据必须为独立字段，不得与 DATE_ACCESSD 字段合并\nFILE_SIZE　5,952　原生文件文件/电子邮件的大小，单位为 KB\nPGCOUNT　1　原生文件文件/电子邮件的页数\nPATH　电子邮件：（空）\nAgenda.doc　原生文件：存储原生文件文件的路径，包括原始文件名。\nINTFILEPATH　Personal Folders\\Deleted\nItems\\Board Meeting\nMinutes.msg　电子邮件：电子邮件的原始位置，包括原始文件名。\n原生文件：（空）\nINTMSGID　<000805c2c71b\\$75977050\\$\ncb8306d1@MSN>　电子邮件：唯一邮件 ID 原生文件：（空）\nMD5HASH　d131dd02c5e6eec4693d9a0\n698aff95c\n2fcab58712467eab4004583e\nb8fb7f89　文件的 MD5 哈希值。\nOCRPATH　TEXT/001/EDC0000001.txt　原生文件提取文本的路径\n\n3. 每项请求均独立运作并应独立解释；除非另有说明，任何请求均不限制任何其他请求的范围。\n\n4. 所有文件均应按照其在通常业务过程中保存的方式提供，或应进行整理和标注，以对应本请求中的类别。\n\n5. 本文件所载每项请求均延伸至所有文件：（a）由贵方占有、保管或控制的文件；或（b）由代表贵方行事的任何人占有、保管或控制的文件，\n案号 22-50073 文件 1592 提交于 03/24/23 录入于 03/24/23 10:57:37 第 757 页，共 1063 页\n\n包括贵方律师或其他代表及顾问。每一文件均应完整提供。\n\n6. 如要求贵方提供已不再由贵方占有、保管或控制的文件，则贵方的答复必须：（a）详细说明该文件的性质及其内容；（b）确认制作或撰写该文件的人员（以及，如适用，该文件发送给的人员）；（c）确认该文件制作或创建的日期；（d）说明该文件是否（i）遗失或丢失、（ii）已被销毁、（iii）已自愿或非自愿地转移给他人，或（iv）以其他方式处置；（e）说明该等处置的原因，以及与该等处置有关的事实和情形；（f）确认授权进行该等处置的人员；（g）确认该等处置的日期或大约日期；（h）说明该文件最后一次由贵方占有、保管或控制的时间；以及（i）确认现时占有、保管或控制该文件的人员（如有）。\n\n7. 如要求贵方提供已被销毁的文件，则除前述指示所要求的信息外，贵方的答复还必须说明：（a）销毁该文件的原因；（b）销毁该文件的人员身份；以及（c）指示销毁该文件的人员身份。\n\n8. 如贵方主张所请求的文件享有特权或属于律师工作成果，则贵方的答复必须：（a）说明（i）足以支持贵方关于该文件享有特权之主张的文件描述；（ii）文件标题；（iii）文件日期；（iv）文件作者；（v）文件收件人；（vi）收到或查阅该文件原件或任何草稿、副本或复制件的每一人员身份；（vii）该文件本身或该文件所载或提及的任何信息是否由任何其他人员占有、保管或控制，如是，则确认该等人员身份，并说明该等信息如何由其取得；（viii）据以扣留该文件的特权主张；以及（ix）贵方将据以支持该特权主张的所有情形；以及（b）就根据 D. Conn. L. Civ. R. 26(e) 基于特权主张而扣留的每一文件，提供一份特权日志，其中载明本指示第（a）部分所要求的全部信息。对于文件请求中未主张特权或工作成果的任何部分，应完整提供响应性文件。\n\n9. 如本应响应的文件的一部分包含受特权主张约束的信息，则仅应依照上述指示从该文件中删除或遮蔽受特权主张约束的部分，并应提供其余部分。\n\n10. 本请求具有持续性。兹指示贵方：（a）一旦得知先前答复不完整或不正确，立即补充或更正任何后来发现不完整或不正确的答复；以及（b）提供根据本请求所要求的任何额外文件。\n\n11. 如文件使用英语以外的语言，贵方应提供该文件。如文件使用英语以外的语言，且存在英文译本，贵方应同时提供两份文件。\n\n12. 对实体的一切提及均包括其所有关联方。\n\n13. 对个人姓名的一切提及均包括所有替代姓名、别名或昵称。\n案号 22-50073 文件 1592 提交于 03/24/23 录入于 03/24/23 10:57:37 第 759 页，共 1063 页\n\n14. 除非另有明确说明，文件请求所涵盖的期间为自 February 5, 2012 起至文件请求答复到期之日止。\n\nII. 解释规则\n\n15. （a）任何单数名词的使用应解释为包括复数，反之亦然；以及（b）任何时态动词的使用应解释为在所有其他时态中使用该动词。\n\n16. （a）“and”和“or”应视需要解释为连词或析取词，以使任何请求的范围包括原本可能被解释为不在其范围内的所有答复；以及（b）“each”和“any”应被视为包括并涵盖“every”和“all”二词。\n\nIII. 定义\n\n经 D. Conn. Bankr. L.R. 2004-1(a) 纳入的 D. Conn. L. Civ. R. 26(c) 所规定的定义，以及 D. Conn. L. Civ. R. 26(d) 所规定的解释规则，适用于文件请求。此外，本文件请求中使用的下列术语具有如下含义：\n\n1. “You”或“Your”或“Yourself”系指 Medici Bank International LLC（梅第奇国际银行有限责任公司）。\n\n2. “Debtor”系指 Ho Wan Kwok（郭文贵）（又名 Miles Kwok、Miles Guo、Guo Wengui、Guo Haoyun、郭文贵或任何其他别名），以及其雇员、代理人、律师、顾问或代表其行事的任何人。\n案号 22-50073 文件 1592 提交于 03/24/23 录入于 03/24/23 10:57:37 第 760 页，共 1063 页\n\n3. “Debtor’s Son”系指 Qiang Guo（郭强）（又名 Mileson Kwok、郭强或任何其他别名），以及其雇员、代理人、律师、顾问或代表其行事的任何人。\n\n4. “债务人的女儿”是指 Mei Guo（郭美；又名 Mei Gui 或任何其他别名），连同其雇员、代理人、法律顾问、顾问或任何代表其行事之人。\n\n5. “债务人的所谓妻子”是指 Hing Chi Ngok（岳庆芝；又名 Hing Chi Ng、Yue Qingzhi 或任何其他别名），连同其雇员、代理人、法律顾问、顾问或任何代表其行事之人。\n\n6. “债务人的家庭成员”是指，单独及共同而言，债务人、债务人的儿子、债务人的女儿及债务人的所谓妻子，以及与债务人具有任何其他家庭关系之人。\n\n7. “2004 取证对象”是指，单独及共同而言，债务人、债务人的家庭成员、ACA Capital Group Limited、Himalaya International Financial Group Ltd.、Himalaya International Clearing Ltd.、Himalaya International Payments Ltd.、Himalaya International Reserves Ltd.、Jesse Brown、William Je、William Je、Eastern Profit Corporation Limited、HK International Funds Investments (USA) Limited LLC、Bravo Luck Limited、Golden Spring (New York) Ltd.、Lamp Capital LLC、Greenwich Land LLC、Qu Guo Jiao、Daniel Thomas Podhaskie、Yvette Wang（又名 Yanping Wang，又名 Yan Ping Wang）、Ace Decade Holdings Limited、Dawn State Limited、Rule of Law Society IV Inc.、Rule of Law Foundation III, Inc.、Rule of Law Foundation IV, Inc.、Rule of Law Fund、Rule of Law Society、GTV Media Group, Inc.、Voice of Guo Media, Inc.、Saraca Media Group Inc.、Genever Holdings Corporation、Genever Holdings LLC、Gnews Media Group Inc.、G Fashion LLC、Gmusic LLC、Gnews LLC、Geducation、GFNY, Inc.、G-Club Investments Limited、G Club Operations LLC、G Club US Operations Inc.、G Club US Operations LLC、G Live, LLC、Gbroadcast, LLC、Gposts LLC、HCHK Property\n\n案件 22-50073 文件 1592 提交 03/24/23 录入 03/24/23 10:57:37 第 761 页，共 1063 页\n\nManagement, Inc.、HCHK Technologies, Inc.、FMV Ltd./Freedom Media Venture Ltd.、Roscalitar 2、Himalaya New World Inc.、US Himalaya Capital Inc.、Hudson Diamond Holding, Inc.、Hudson Diamond Holding LLC、Hudson Diamond NY LLC、Infinity Treasury Management Inc.、Lexington Property and Staffing, Inc.、AI Group Holdings Inc.、Hamilton Capital Holdings Inc.、Booming Sail New York LLC、Himalaya Ventures LLC、Himalaya Ventures LLC、Himalaya Investment LLC、New York MOS Himalaya LLC、MOS Himalaya LLC、Crane Advisory Group、Maywind Trading LLC、Gettr USA, Inc.、Han Chunguang、Bingshang Jiao、Karin Maistrello、Mary Jiang、Jiaming Liu 及 Wencong Wang。\n\n8. “包括”或其任何变体，是指“包括但不限于”。\n\n9. “和”及“或”是指“和/或”，并应同时按合取及析取方式解释，以最大限度扩大其范围。\n\n10. “任何”及“所有”以及“每一”是指“每一个及所有”。\n\n11. “每一”及“每个”是指“每一个及所有”。\n\n12. “第三方”是指除你方以外的个人或实体。\n\n13. “转让”应具有《破产法典》第 101(54) 条赋予该词的含义。\n\n14. “文件”是指属于 Fed. R. Civ. P. 34 范围内的任何信息或物品，并包括但不限于所有任何种类、类型、性质或描述的书面、记录或图形材料，只要该等材料现由或曾由你方占有、保管或控制，包括电子邮件的所有印刷及电子副本、以电子形式保存的计算机文件、函件、备忘录、磁带、速记或手写笔记、任何种类的书面表格、图表、蓝图、图纸、草图、曲线图、计划、文章、规格说明书、日记、信函、\n\n案件 22-50073 文件 1592 提交 03/24/23 录入 03/24/23 10:57:37 第 762 页，共 1063 页\n\n电报、照片、会议记录、合同、协议、调查资料、计算机打印件、任何种类的数据汇编、电传、传真、电子邮件、短信、即时消息、语音留言、发票、订购单、支票、汇票、对账单、贷项通知单、报告、头寸报告、摘要、索引、账簿、分类账、笔记本、清单、透明胶片、录音、目录、广告、宣传材料、影片、录像带、录音带、CD、计算机磁盘、小册子、传单、穿孔卡、工时单、推文、社交媒体帖子或任何其他种类的书面或记录材料，以及其所有元数据，无论以何种方式存储（无论为有形或电子形式）、记录、制作或复制；还包括但不限于上述任何材料的草稿或副本，如其中包含原始文件中未见的任何种类的注释、评论或标记，或在其他方面与原始文件不完全相同。\n\n15. “个人”是指个人、公司、独资企业、合伙企业、协会或任何其他实体。“个人”还包括任何代理人、代表或专家，包括但不限于律师或财务顾问。\n\n16. “实体”是指任何自然人、公司、合伙企业、子公司、独资企业、商号、董事会、合资企业、协会、机构、主管机关、委员会或其他商业实体或法人，以及任何关联方、代理人、母公司，包括但不限于法律顾问、财务顾问或任何其他代表。\n\n17. “关于”是指涉及、描述、包含、提及、与之相关、支持、赞成、反对、加强、贬损、位于其中、结合其考虑、影响、证明、表明、报告、记录、暗示、回应、与之相连、评论、就其而言、有关、与之相关、讨论、显示、描述、反映、分析、构成及为之。\n\n案件 22-50073 文件 1592 提交 03/24/23 录入 03/24/23 10:57:37 第 763 页，共 1063 页\n\n18. 在提及任何特定事项时，“与……有关”、“涉及”或“相关”是指，但不限于，构成、包含、涉及、含有、体现、反映、识别、陈述、直接或间接提及，或以任何方式与所识别的特定事项相关的任何文件。\n\n19. “通信”是指，以最广泛的可能含义且不限于此，对信息或知识（以事实、理念、询问或其他形式）的任何传递。通信还指所有交谈、协议、询问或答复，无论是当面、通过电话、以书面形式，或通过电子传输设备，并包括但不限于所有函件、电子邮件、录音、传输单、备忘录、电话通信、语音留言、电报、电话传真、传真副本、电传、即时消息、聊天、短信、向留言板或群聊发布的帖子、社交媒体帖子、推文、上传至任何视频平台的视频、电话笔记，或在内部或与第三方之间传递的笔记。\n\n20. “资产”是指受占有、保管或控制的任何具有经济价值的项目。资产包括所有不动产及动产，包括但不限于房地产、土地、房屋、公寓、共管公寓、汽车、游艇、船只、飞机、喷气式飞机、直升机、现金、银行账户、加密货币、证券、应收账款、存货及其他有形和无形财产。\n\nIV. 应提交的文件\n\n1. 与由任何 2004 取证对象持有、控制、代表其持有或以其他方式与其相关的任何账户有关的所有文件，包括任何及所有账户对账单、授权书、授权委托书、信托、指示或表格、已注销支票副本、函件，以及电汇及相关函件和指示。\n\n案件 22-50073 文件 1592 提交 03/24/23 录入 03/24/23 10:57:37 第 764 页，共 1063 页\n\n2. 与属于任何 2004 取证对象、由其持有、控制、代表其持有或以其他方式与其相关的任何资金、证券、财产或资产有关的所有文件，包括任何及所有账户对账单、授权书、授权委托书、信托、指示或表格、已注销支票副本、函件，以及电汇及相关函件和指示。\n\n3. 与任何 2004 取证对象之间的任何商业、贸易或金融交易有关的所有文件，包括但不限于任何贷款、信贷额度、寄托、存款、互换、证券交易、抵押贷款或 ISDA，包括任何及所有账户对账单、授权书、授权委托书、信托、指示或表格、已注销支票副本、函件，以及电汇及相关函件和指示。\n\n4. 与 2004 取证对象有关的任何电汇活动有关的所有文件，不论是否存在任何账户，包括但不限于所有电汇收据、账户号码、余额、授权书、与转账当事人有关的身份识别信息、函件、指示或其他记录。\n\n5. 与你方及 2004 取证对象之间的任何函件及通信有关的所有文件。\n\n6. 与任何 2004 取证对象开立账户、账户获授权使用人及账户维护有关的任何账户的所有文件。\n\n7. 与任何 2004 取证对象有关的任何反洗钱、了解你的客户或其他合规活动有关的所有文件，包括但不限于任何 2004 取证对象提供的任何信息，或你方获悉的任何信息。\n\n8. 与任何国家的任何监管机构之间、且与任何 2004 取证对象有关的任何通信有关的所有文件，包括但不限于英格兰银行（Bank of England）、美国联邦储备系统（United States Federal Reserve）、\n\nS.E.C.、CFTC、FINRA、中国证券监督管理委员会（China Securities Regulatory Commission）、中国人民银行（People's Bank of China）、香港证券及期货事务监察委员会（Hong Kong Securities and Futures Commission）及香港金融管理局（Hong Kong Monetary Authority）。\n\n案件 22-50073 文件 1592 提交 03/24/23 录入 03/24/23 10:57:37 第 766 页，共 1063 页\n\n附件 C-42\n\nB2540（表格 2540——规则 2004 审查传票）（12/15）案件 22-50073 文件 1592 提交 03/24/23 录入 03/24/23 10:57:37 第 767 页，共\n\n美国破产法院 1063\n\n康涅狄格地区\n\n关于 HO WAN KWOK（郭文贵）等人，\n\n1 案件编号 22-50073 (JAM)\n\n债务人 第 11 章\n\n（合并管理）\n\n规则 2004 审查传票\n\n致：Deltee Bank & Trust Limited\n\n（传票指向之人的姓名）\n\n证言：兹命令你方于下文规定的时间、日期及地点出席，并根据《联邦破产程序规则》规则 2004 的审查作证。随附准许该审查的法院命令副本。\n\n地点　日期和时间\n\nNeubert, Pepe & Monteith, P.C.\n195 Church Street, Floor 13　[TBD]\nNew Haven, Connecticut 06510\n\n审查将以如下方式记录：法庭记录员/速记员\n\n提交：你方或你方代表还必须携带下列文件、电子存储信息或物品参加审查，并必须允许对该等材料进行检查、复制、测试或取样：\n见随附的文件提交请求。\n\n下列 Fed. R. Civ. P. 45 条款，依 Fed. R. Bankr. P. 9016 适用于破产案件，随附于后——与履行地点有关的规则 45(c)；与对作为传票对象之人的保护有关的规则 45(d)；以及与你方回应本传票的义务及未回应的潜在后果有关的规则 45(e) 和 45(g)。\n\n日期：March , 2023\n\n法院书记官\n\n或\n\n书记官或副书记官签名　律师签名\n\n签发或请求本传票、代理第 11 章受托人 Luc A. Despins 的律师姓名、地址、电子邮件地址及电话号码如下：\n\nDouglas S. Skalka, Esq.; Neubert, Pepe & Monteith, P.C.; 195 Church Street, New Haven, Connecticut 06510 dskalka@npmlaw.com; (203) 821-2000\n\n致签发或请求本传票之人的通知\n\n如本传票要求在审判前提交文件、电子存储信息或有形物品，或检查场所，则必须在向本传票所指向之人送达之前，向各方当事人送达通知及本传票副本。Fed. R. Civ. P. 45(a)(4).\n\n软件版权 (c) 1996-2022 Best Case, LLC（Best Case有限责任公司）- www.bestcase.com Best Case Bankruptcy 1 本第11章案件中的债务人为 Ho Wan Kwok（郭文贵）（又名 Guo Wengui、Miles Guo 和 Miles Kwok，以及众多其他别名）（税务识别号码后四位：9595）、Genever Holdings LLC（Genever控股有限责任公司）（税务识别号码后四位：8202）及 Genever Holdings Corporation（Genever控股公司）。受托人、Genever Holdings LLC 及 Genever Holdings Corporation 的邮寄地址为：Paul Hastings LLP（普衡律师事务所），200 Park Avenue, New York, NY 10166，转交 Luc A. Despins，作为 Ho Wan Kwok 遗产的受托人（仅用于通知和通信之目的）。\n\n送达证明\n\n（除非 Fed. R. Civ. P. 45 要求，否则本节不应向法院提交。）\n\n本人于（日期）收到向以下人士发出的本传票（个人姓名及职务，如有）：\n\n本人通过如下方式向被指定人士交付副本，送达本传票：\n\n于（日期）；或\n\n本人未执行本传票即予退回，原因如下：\n\n除非本传票系代表美国或其官员或代理人发出，本人还已向证人支付一天出席的费用及法律允许的里程费，金额为 $。\n\n本人的差旅费用为 $，服务费用为 $，合计为 $。\n\n本人在伪证处罚的约束下声明，本信息真实、准确。\n\n日期：\n\n送达人签名\n\n正楷姓名及职务\n\n送达人地址\n\n有关尝试送达等事项的附加信息：\n\n《联邦民事诉讼规则》第45(c)、(d)、(e)及(g)条（自12/1/13起生效）（根据《联邦破产程序规则》第9016条适用于破产案件）\n\n(c) 履行地点。\n\n(1) 审判、听证或证言录取。传票仅可按下列方式命令某人出席审判、听证或证言录取：\n\n(A) 在该人居住、受雇或经常亲自从事商业活动地点的100英里范围内；或\n\n(B) 在该人居住、受雇或经常亲自从事商业活动所在州内，条件是该人：\n\n(i) 为当事人或当事人的高级职员；或\n\n(ii) 被命令出席审判且不会产生重大费用。\n\n(2) 为其他取证。传票可命令：\n\n(A) 在该人居住、受雇或经常亲自从事商业活动地点的100英里范围内的某地点提交文件、电子存储信息或物品；以及\n\n(B) 在待检查场所进行场所检查。\n\n(d) 保护受传票约束之人；执行。\n\n(1) 避免不当负担或费用；制裁。负责发出及送达传票的当事人或律师必须采取合理措施，避免对受传票约束之人施加不当负担或费用。要求履行传票的地区法院必须执行该义务，并对未遵守该义务的当事人或律师施加适当制裁，该制裁可包括收入损失及合理的律师费。\n\n(2) 要求提交材料或准许检查。\n\n(A) 无须出席。被命令提交文件、电子存储信息或有形物品，或准许检查场所之人，无须亲自到提交或检查地点出席，除非其亦被命令出席证言录取、听证或审判。\n\n(B) 异议。被命令提交文件或有形物品，或准许检查之人，可向传票中指定的当事人或律师送达书面异议，反对检查、复制、测试或抽样全部或部分材料，或反对检查场所，或反对以所要求的一种或多种形式提交电子存储信息。异议必须在规定履行时间届满前或传票送达后14日内（以较早者为准）送达。如提出异议，适用下列规则：\n\n(i) 送达方可随时在通知被命令之人后，向要求履行传票的地区法院提出动议，请求作出强制提交或检查的命令。\n\n(ii) 此等行为仅可依命令所指示的方式要求进行，且该命令必须保护非当事人亦非当事人高级职员之人免受因履行而产生的重大费用。\n\n(3) 撤销或修改传票。\n\n(A) 必须撤销或修改的情形。经及时动议，要求履行传票的地区法院必须撤销或修改有下列情形的传票：\n\n(i) 未给予合理的履行时间；\n\n(ii) 要求某人在第45(c)条规定的地域限制以外履行；\n\n(iii) 要求披露享有特权或受其他保护的事项，且不适用任何例外或弃权；或\n\n(iv) 对某人造成不当负担。\n\n(B) 可以撤销或修改的情形。为保护受传票约束或受其影响之人，要求履行传票的地区法院可依动议撤销或修改具有下列要求的传票：\n\n(i) 披露商业秘密或其他保密研究、开发或商业信息；或\n\n(ii) 披露未受聘专家的意见或信息，该等意见或信息并未描述争议中的具体事件，且源自未经任何当事人请求而进行的该专家研究。\n\n(C) 以规定条件作为替代。在第45(d)(3)(B)条所述情形下，如送达方：\n\n(i) 证明其对该证言或材料具有重大需要，且如不承受不当困难便无法以其他方式满足该需要；并且\n\n(ii) 确保被传唤之人将获得合理补偿，\n\n法院可不撤销或修改传票，而命令在规定条件下出席或提交。\n\n(e) 回应传票的义务。\n\n(1) 提交文件或电子存储信息。以下程序适用于提交文件或电子存储信息：\n\n(A) 文件。回应要求提交文件之传票的人，必须按该等文件在日常业务过程中保存的方式提交，或者必须整理并标注该等文件，使其对应于请求中的类别。\n\n(B) 未规定提交电子存储信息的形式。如传票未规定提交电子存储信息的形式，回应之人必须以其通常保存的一种或多种形式，或以合理可用的一种或多种形式提交。\n\n(C) 电子存储信息仅以一种形式提交。回应之人无须以一种以上形式提交同一电子存储信息。\n\n(D) 无法合理获取的电子存储信息。回应之人无须就其认定因不当负担或费用而无法合理获取的来源中的电子存储信息提供取证。在请求强制取证或保护令的动议中，回应之人必须证明该信息因不当负担或费用而无法合理获取。如作出该证明，法院在考虑第26(b)(2)(C)条的限制后，如请求方证明有正当理由，仍可命令从该等来源进行取证。法院可为该取证规定条件。\n\n(2) 主张特权或保护。\n\n(A) 被扣留的信息。以该信息享有特权或作为审判准备材料受到保护为由扣留被传唤信息之人，必须：(i) 明确提出该主张；并且\n\n(ii) 以一种在不披露本身享有特权或受保护信息的情况下，足以使各方当事人评估该主张的方式，描述被扣留文件、通信或有形物品的性质。\n\n(B) 已提交的信息。如为回应传票而提交的信息受到特权主张或作为审判准备材料受保护的主张约束，提出该主张之人可将该主张及其依据通知任何收到该信息的当事人。收到通知后，当事人必须立即返还、隔离或销毁所指定的信息及其持有的任何副本；在该主张得到解决前不得使用或披露该信息；如该当事人在收到通知前已披露该信息，必须采取合理措施追回该信息；并可立即将该信息密封提交给要求履行传票的地区法院，以裁定该主张。提交该信息之人必须在该主张得到解决前保存该信息。\n\n(g) 藐视法庭。要求履行传票的地区法院，以及在动议移送后发出传票的法院，均可认定已被送达但无充分理由不遵守传票或相关命令之人构成藐视法庭。\n\n有关获取传票材料，请参见 Fed.R.Civ.P.45(a) 委员会说明（2013年）\n\n……\n\n文件提交请求\n\n一、指示\n\n1. 除非另有说明，下列文件请求（以下简称“请求”，每一项称为“一项请求”）必须分别且具体地作出回应。除非善意提出异议，每项请求均应得到完整答复；如提出异议，则必须如下文所述详细说明贵方异议的理由。如异议仅涉及一项请求的一部分，或其中包含的一个词语、短语或条款，贵方仅须说明对该部分的异议，并对其余请求作出回应。\n\n2. 电子存储信息必须依照下列指示提交：\n\na. 图像。黑白图像必须为300 DPI Group IV 单页 TIFF 文件。彩色图像必须以 JPEG 格式提交。文件名不得含有嵌入式空格或特殊字符（包括逗号）。文件夹名称不得含有嵌入式空格或特殊字符（包括逗号）。所有 TIFF 图像文件必须具有唯一文件名，即 Bates 编号。每幅图像右下角必须加注连续的 Bates 编号。每个文件夹内的 TIFF 文件数量不应超过1000个文件。Excel 电子表格应具有以该文件的 Bates 编号命名的占位图像。\n\nb. 图像加载文件\n\na. Concordance® 数据文件。数据文件（.DAT）包含将被加载至 Concordance® 数据库的所有字段信息。.DAT 文件的第一行必须为标明字段名称的标题行。.DAT 文件必须使用下列 Concordance® 默认分隔符：逗号 ASCII 字符（020）引号 þ ASCII 字符（254）。日期字段应按以下格式提供：mm/dd/yyyy。日期字段和时间字段必须为两个单独字段。如文件包括已成像的电子邮件及附件，则必须包括附件字段，以保留电子邮件与其附件之间的父项/子项关系。必须包括 OCRPATH 字段，以提供所提交存储介质上提取文本文件的文件路径及名称。文本文件必须以 FIRSTBATES 命名。不得在 .DAT 文件中包含文本。对于含有原生文件的文件，必须包括 LINK 字段，以提供原生文件的文件路径及名称。原生文件必须以 FIRSTBATES 命名。\n\nb. Concordance Image® 或 Opticon 交叉引用文件。图像交叉引用文件（.LOG 或 .OPT）将图像链接至数据库记录。其应为以逗号分隔的文件，每行由七个字段组成，且数据库中的每一图像均应在交叉引用文件中对应一行，格式如下：ImageID,VolumeLabel,ImageFilePath,DocumentBreak,FolderBreak,BoxBreak,PageCount。\n\nc. 文档文本。文本必须作为独立文本文件提供，而非作为 .DAT 文件中的字段。文本文件的完整路径（OCRPATH）应包含在 .DAT 文件中。建议提供以 FIRSTBATES/Image Key 命名的文档级 ANSI 文本文件。提取的文本文件必须置于单独文件夹中，且每个文件夹中的文本文件数量不得超过 1,000 个。文件夹名称中不得包含特殊字符（包括逗号）。文本文件必须按文档级别提供。\n\nd. 特定文件类型的原生格式提供。为充分理解其内容和含义而合理需要以原生格式查看的文件类型，必须以原生格式提供。此类文件包括但不限于：电子表格、类似电子表格的文件（Microsoft Excel、逗号分隔值、制表符分隔值等）、Microsoft PowerPoint 或其他特殊演示文件、数据库文件及音频/视频文件。应提供一张带有 Bates 编号的隔页纸图像，标明存在原生文件，并在 .dat 文件中以字段形式包含该原生文件的路径。所提供的原生文件应以对应于该文件隔页纸的 Bates 编号命名。原生文件应归入按递增方式命名的“NATIVE”目录中，并与图像目录分开。\n\ne. 去重。对于存在完全重复件的每一电子文档，仅提供一份副本。对于电子邮件，应根据由 BCC、Body、CC、From、IntMsgID、To 和 Attach 属性生成的 MD5 哈希值合并重复件。对于电子邮件附件及独立电子文件，应根据整个文件的 MD5 哈希值合并重复件。\n\nf. 元数据。应以符合 Concordance 规范的加载文件（.dat）形式提供每份文档的提取元数据。.DAT 文件的第一行必须为标识字段名称的标题行。.DAT 文件必须使用以下 Concordance 默认分隔符：逗号 , ASCII 字符（020）；引号 þ ASCII 字符（254）。\n\n日期字段应采用以下格式提供：mm/dd/yyyy。日期和时间字段必须为两个独立字段。以下为必需元数据：\nCase 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 772 of 1063\n\n字段名称　示例数据　说明\n\nFIRSTBATES　EDC0000001　原生文件文档/电子邮件的第一个 Bates 编号\n\nLASTBATES　EDC0000001　原生文件文档/电子邮件的最后一个 Bates 编号\n对于单页文档，应填写 LASTBATES 字段。\n\nATTACHRANGE　EDC0000001\n-　父文档第一页的 Bates 编号至最后一个附件“子”文档最后一页的 Bates 编号\nEDC0000015\n\nBEGATTACH　EDC0000001　附件范围的第一个 Bates 编号\n\nENDATTACH　EDC0000015　附件范围的最后一个 Bates 编号\n\nCUSTODIAN　Smith, John　电子邮件：电子邮件所在的邮箱\n原生文件：文档来源个人或部门的名称\n\nFROM　John Smith　电子邮件：发件人\n原生文件：文档作者\n多个条目应使用分号分隔。\n\nTO　Coffman, Janice; LeeW　收件人\n[mailto:LeeW@MSN.com]　多个条目应使用分号分隔。\n\nCC　Frank Thompson [mailto:　抄送收件人\nfrank_Thompson@cdt.com]　多个条目应使用分号分隔。\n\nBCC　John Cain　密送收件人\n多个条目应使用分号分隔。\n\nSUBJECT　Board Meeting Minutes　电子邮件：电子邮件主题行；原生文件：文档标题（如有）\n\nFILE_NAME　BoardMeetingMinutes.docx　原生文件：原始原生文件的名称，包括扩展名\n\nDATE_SENT　10/12/2010　电子邮件：电子邮件发送日期\n原生文件：（空）\n\nTIME_SENT/\nTIME_ZONE　07:05 PM GMT　电子邮件：电子邮件发送时间/电子邮件标准化所采用的时区\n\nTIME_ZONE　GMT　在转换过程中电子邮件被标准化所采用的时区。\n\nLINK　EDC0000001.msg　指向电子邮件或原生文件文档的超链接\n链接文件必须按照 FIRSTBATES 编号命名。\n\nFILE_EXTEN　MSG　表示电子邮件或原生文件的文件类型扩展名\n\nAUTHOR　John Smith　电子邮件：（空）\n原生文件：文档作者\n\nDATE_CREATED　10/10/2010　电子邮件：（空）\n原生文件：文档创建日期\nCase 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 773 of 1063\n\nTIME_CREATED　10:25 AM　电子邮件：（空）\n原生文件：文档创建时间\n该数据必须为独立字段，不得与 DATE_CREATED 字段合并。\n\nDATE_MOD　10/12/2010　电子邮件：（空）\n原生文件：文档最后修改日期\n\nTIME_MOD　07:00 PM　电子邮件：（空）\n原生文件：文档最后修改时间\n该数据必须为独立字段，不得与 DATE_MOD 字段合并。\n\nDATE_ACCESSD　10/12/2010　电子邮件：（空）\n原生文件：文档最后访问日期\n\nTIME_ACCESSD　07:00 PM　电子邮件：（空）\n原生文件：文档最后访问时间\n该数据必须为独立字段，不得与 DATE_ACCESSD 字段合并。\n\nFILE_SIZE　5,952　原生文件文档/电子邮件的大小，以 KB 为单位\n\nPGCOUNT　1　原生文件文档/电子邮件的页数\n\nPATH　电子邮件：（空）\nAgenda.doc　原生文件：存储原生文件文档的路径，包括原始文件名称。\n\nINTFILEPATH　Personal Folders\\Deleted　电子邮件：电子邮件的原始位置，包括原始文件名称。\nItems\\Board Meeting\nMinutes.msg　原生文件：（空）\n\nINTMSGID　<000805c2c71b\\$75977050\\$　电子邮件：唯一消息 ID；原生文件：（空）\ncb8306d1@MSN>\n\nMD5HASH　d131dd02c5e6eec4693d9a0　文档的 MD5 哈希值。\n698aff95c\n2fcab58712467eab4004583e\nb8fb7f89\n\nOCRPATH　TEXT/001/EDC0000001.txt　原生文件提取文本的路径\n\n3. 每一项请求均独立适用并应独立解释，除非另有说明，任何一项请求均不限制任何其他请求的范围。\n\n4. 所有文件均应按通常业务过程中保存的方式提供，或应进行整理和标记以对应于本文件请求中的类别。\n\n5. 本文件中的每一项请求均延及所有文件：(a) 由您占有、保管或控制的文件；或 (b) 由代表您行事的任何人占有、保管或控制的文件，\nCase 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 774 of 1063\n\n包括您的律师或其他代表及顾问。每份文件均应完整提供。\n\n6. 如要求您提供的文件已不再由您占有、保管或控制，则您的答复必须：(a) 详细说明该文件的性质及其内容；(b) 确认准备或撰写该文件的人员（以及，如适用，该文件被发送给的人员）；(c) 确认该文件被准备或创建的日期；(d) 说明该文件是否：(i) 缺失或遗失，(ii) 已被销毁，(iii) 已自愿或非自愿地转移给他人，或 (iv) 已以其他方式处置；(e) 说明该等处置的理由以及围绕该等处置的事实和情况；(f) 确认授权该等处置的人员；(g) 确认该等处置的日期或大致日期；(h) 说明该文件最后一次由您占有、保管或控制的时间；以及 (i) 确认目前占有、保管或控制该文件的人员（如有）。\n\n7. 如要求您提供的文件已被销毁，则除前一项指示所要求的信息外，您的答复还必须说明：(a) 销毁该文件的理由；(b) 销毁该文件的人员身份；以及 (c) 指示销毁该文件的人员身份。\n\n8. 如您主张被请求提供的文件享有特权或律师工作成果保护，则您的答复必须：(a) 说明：(i) 对该文件作出足以支持您关于该文件享有特权之主张的描述，(ii) 该文件的标题，(iii) 该文件的日期，(iv) 该文件的作者，(v) 该文件的收件人，(vi) 收到或阅览该文件原件或任何草稿、副本或复制件的每一人员的身份，(vii) 该文件本身或该文件中包含或提及的任何信息是否由任何其他人员占有、保管或控制；如是，则确认该等人员的身份，并说明该等信息如何进入其占有范围，(viii) 据以扣留该文件的特权主张，以及 (ix) 您将依赖以支持该等特权主张的所有情形；以及 (b) 依照 D. Conn. L. Civ. R. 26(e)，就基于特权主张而扣留的每份文件，提供一份特权清单，其中包含本指示第 (a) 部分所要求的全部信息。对于未主张特权或工作成果保护的文件请求部分，应完整提供相关文件。\n\n9. 如一份原本应予提供的文件的一部分包含受特权主张约束的信息，则仅应依照上述指示从该文件中删除或遮蔽受该特权主张约束的部分，其余部分应予提供。\n\n10. 该等请求具有持续性。现指示您：(a) 一旦得知先前答复不完整或不正确，应立即补充或更正其后发现不完整或不正确的任何答复；以及 (b) 提供根据以下规定所要求的任何补充文件\n\n11. 如文件使用英语以外的语言，您应提供该文件。如文件使用英语以外的语言，且存在英文译本，您应同时提供两份文件。\n\n12. 对实体的一切提述均包括其所有关联方。\n\n13. 对个人姓名的一切提述均包括所有替代姓名、别名或昵称。\nCase 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 776 of 1063\n\n14. 除非另有明确说明，文件请求所涵盖的期间为自 February 5, 2012 起至文件请求答复到期之日止。\n\nII. 解释规则\n\n15. (a) 任何单数名词的使用应解释为包括复数，反之亦然；以及 (b) 任何时态动词的使用应解释为在所有其他时态中使用该动词。\n\n16. (a) “and”和“or”应在必要时解释为连词关系或析取关系，以将原本可能被解释为不在任何请求范围内的所有答复纳入该请求范围；以及 (b) “each”和“any”应视为包括并涵盖“every”和“all”二词。\n\nIII. 定义\n\n经 D. Conn. Bankr. L.R. 2004-1(a) 纳入的 D. Conn. L. Civ. R. 26(c) 所规定的定义及 D. Conn. L. Civ. R. 26(d) 所规定的解释规则，应适用于文件请求。此外，本文件请求中使用的下列术语具有以下含义：\n\n1. “您”或“您的”或“您本人”系指 Deltec Bank & Trust Limited（德尔特克银行与信托有限公司）。\n\n2. “债务人”系指 Ho Wan Kwok（郭文贵）（又名 Miles Kwok、Miles Guo、Guo Wengui、Guo Haoyun、郭文贵或任何其他别名），以及其雇员、代理人、律师、顾问或任何代表其行事的人。\n\n3. “债务人之子”系指 Qiang Guo（郭强）（又名 Mileson Kwok、郭强或任何其他别名），以及其雇员、代理人、律师、顾问或任何代表其行事的人。\nCase 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 777 of 1063\n\n4. “债务人之女”是指 Mei Guo（郭美，又名 Mei Gui，或任何其他别名），连同其雇员、代理人、律师、顾问或任何代表其行事的人。\n\n5. “债务人之名义妻子”是指 Hing Chi Ngok（岳庆芝，又名 Hing Chi Ng、Yue Qingzhi，或任何其他别名），连同其雇员、代理人、律师、顾问或任何代表其行事的人。\n\n6. “债务人家属”是指，单独及合并而言，债务人、债务人之子、债务人之女及债务人之名义妻子，以及与债务人有任何其他家庭关系的人。\n\n7. “2004 审查取证对象”是指，单独及合并而言，债务人、债务人家属、ACA Capital Group Limited（ACA 资本集团有限公司）、Himalaya International Financial Group Ltd.（喜马拉雅国际金融集团有限公司）、Himalaya International Clearing Ltd.（喜马拉雅国际清算有限公司）、Himalaya International Payments Ltd.（喜马拉雅国际支付有限公司）、Himalaya International Reserves Ltd.（喜马拉雅国际储备有限公司）、Jesse Brown（杰西·布朗）、William Je（威廉·杰）、William Je（威廉·杰）、Eastern Profit Corporation Limited（东方利润有限公司）、HK International Funds Investments (USA) Limited LLC（香港国际基金投资〔美国〕有限责任公司）、Bravo Luck Limited（好运有限公司）、Golden Spring (New York) Ltd.（金泉〔纽约〕有限公司）、Lamp Capital LLC（兰普资本有限责任公司）、Greenwich Land LLC（格林尼治土地有限责任公司）、Qu Guo Jiao（郭娇）、Daniel Thomas Podhaskie（丹尼尔·托马斯·波达斯基）、Yvette Wang（王燕萍，又名 Yanping Wang，又名 Yan Ping Wang）、Ace Decade Holdings Limited（艾斯十年控股有限公司）、Dawn State Limited（黎明州有限公司）、Rule of Law Society IV Inc.（法治协会 IV 公司）、Rule of Law Foundation III, Inc.（法治基金会 III 公司）、Rule of Law Foundation IV, Inc.（法治基金会 IV 公司）、Rule of Law Fund（法治基金）、Rule of Law Society（法治协会）、GTV Media Group, Inc.（GTV 媒体集团公司）、Voice of Guo Media, Inc.（郭之声媒体公司）、Saraca Media Group Inc.（萨拉卡媒体集团公司）、Genever Holdings Corporation（吉尼弗控股公司）、Genever Holdings LLC（吉尼弗控股有限责任公司）、Gnews Media Group Inc.（Gnews 媒体集团公司）、G Fashion LLC（G 时尚有限责任公司）、Gmusic LLC（G 音乐有限责任公司）、Gnews LLC（Gnews 有限责任公司）、Geducation（G 教育）、GFNY, Inc.（GFNY 公司）、G-Club Investments Limited（G-Club 投资有限公司）、G Club Operations LLC（G Club 运营有限责任公司）、G Club US Operations Inc.（G Club 美国运营公司）、G Club US Operations LLC（G Club 美国运营有限责任公司）、G Live, LLC（G Live 有限责任公司）、Gbroadcast, LLC（Gbroadcast 有限责任公司）、Gposts LLC（Gposts 有限责任公司）、HCHK Property Management, Inc.（HCHK 物业管理公司）、HCHK Technologies, Inc.（HCHK 技术公司）、FMV Ltd./Freedom Media Venture Ltd.（FMV 有限公司/自由媒体创投有限公司）、Roscalitar 2（罗斯卡利塔尔 2）、Himalaya New World Inc.（喜马拉雅新世界公司）、US Himalaya Capital Inc.（美国喜马拉雅资本公司）、Hudson Diamond Holding, Inc.（哈德逊钻石控股公司）、Hudson\nCase 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 778 of 1063\n\nDiamond Holding LLC（哈德逊钻石控股有限责任公司）、Hudson Diamond NY LLC（哈德逊钻石纽约有限责任公司）、Infinity Treasury Management Inc.（无限财资管理公司）、Lexington Property and Staffing, Inc.（列克星敦物业与人力配置公司）、AI Group Holdings Inc.（AI 集团控股公司）、Hamilton Capital Holdings Inc.（汉密尔顿资本控股公司）、Booming Sail New York LLC（兴帆纽约有限责任公司）、Himalaya Ventures LLC（喜马拉雅创投有限责任公司）、Himalaya Ventures LLC（喜马拉雅创投有限责任公司）、Himalaya Investment LLC（喜马拉雅投资有限责任公司）、New York MOS Himalaya LLC（纽约 MOS 喜马拉雅有限责任公司）、MOS Himalaya LLC（MOS 喜马拉雅有限责任公司）、Crane Advisory Group（克兰咨询集团）、Maywind Trading LLC（五月风贸易有限责任公司）、Gettr USA, Inc.（Gettr 美国公司）、Han Chunguang（韩春光）、Bingshang Jiao（焦秉尚）、Karin Maistrello（卡琳·迈斯特雷洛）、Mary Jiang（江玛丽）、Jiaming Liu（刘佳明）及 Wencong Wang（王文聪）。\n\n8. “包括”或其任何变体，是指“包括但不限于”。\n\n9. “和”及“或”是指“和/或”，并应作连词和析取词两种解释，以最大限度扩大其范围。\n\n10. “任何”及“全部”及“每一”是指“每一个及所有”。\n\n11. “每一”及“每个”是指“每一个及所有”。\n\n12. “第三方”是指除您以外的个人或实体。\n\n13. “转让”应具有《破产法》section 101(54) 赋予该词的含义。\n\n14. “文件”是指属于 Fed. R. Civ. P. 34 范围内的任何信息或物品，包括但不限于由您占有、保管或控制的任何种类、类型、性质或描述的每一项书面、录制或图形资料，包括电子邮件的所有印刷件和电子副本、以电子形式保存的计算机文件、函件、备忘录、磁带、速记或手写笔记、任何种类的书面表格、图表、蓝图、绘图、草图、图形、计划、文章、规格说明、日记、信件、电报、照片、会议记录、合同、协议、调查、计算机打印件、任何种类的数据汇编、电传、传真、电子邮件、短信、即时消息、语音\nCase 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 779 of 1063\n\n信息、发票、订货单、支票、汇票、对账单、贷项通知单、报告、头寸报告、摘要、索引、账簿、分类账、笔记本、附表、投影片、录音制品、目录、广告、促销材料、影片、录像带、录音带、CD、计算机磁盘、宣传册、小册子、穿孔卡、工时单、推文、社交媒体帖子或任何其他种类的书面或录制材料，以及其所有元数据，不论以何种方式存储（无论为有形形式或电子形式）、记录、制作或复制；还包括但不限于上述任何文件的草稿或副本，如其中载有原始文件中未见的任何种类笔记、评论或标记，或在其他方面与原始文件不完全相同。\n\n15. “个人”是指自然人、公司、独资企业、合伙企业、协会或任何其他实体。“个人”还包括任何代理人、代表或专家，包括但不限于律师或财务顾问。\n\n16. “实体”是指任何自然人、公司、合伙企业、子公司、独资企业、商号、董事会、合资企业、协会、机构、主管机关、委员会或其他商业实体或法人，以及任何关联方、代理人、母公司，包括但不限于律师、财务顾问或任何其他代表。\n\n17. “关于”是指涉及、描述、构成、提及、与之相关、支持、赞成、反对、加强、削弱、位于其中、结合其予以考虑、对其有影响、证明、表明、报告、记录、暗指、答复、与之相连、评论、就其而言、有关、与之相关、讨论、显示、描述、反映、分析、构成及成为。\n\n18. 当提及任何特定事项时，“与……有关”、“涉及”或“相关”，是指包括但不限于构成、包含、涉及、载有、体现、反映、识别、陈述、直接或间接提及该特定事项，或以任何方式与已识别的该特定事项有关的任何文件。\nCase 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 780 of 1063\n\n19. “通信”是指以最广泛可能的含义且不受限制地传递任何信息或知识（以事实、想法、询问或其他形式）。通信还指所有谈话、协议、询问或答复，无论是当面、通过电话、书面方式，还是通过电子传输设备进行，并包括但不限于所有函件、电子邮件、录音、传送单、备忘录、电话通信、语音信息、电报、电传传真、电传复印件、电传、即时消息、聊天、短信、发布至留言板或群聊的帖子、社交媒体帖子、推文、上传至任何视频平台的视频、电话记录，或内部传递或与第三方传递的笔记。\n\n20. “资产”是指受占有、保管或控制的任何具有经济价值的项目。资产包括所有不动产和动产，包括但不限于房地产、土地、房屋、公寓、共有产权公寓、汽车、游艇、船只、飞机、喷气式飞机、直升机、现金、银行账户、加密货币、证券、应收账款、存货及其他有形和无形财产。\n\nIV. 应提交的文件\n\n1. 与任何由任何 2004 审查取证对象持有、控制、代为持有或以其他方式与其有关的账户有关的所有文件，包括任何及所有账户对账单、授权书、委托书、信托文件、指示或表格、已注销支票副本、函件、电汇以及相关函件和指示。\n\n2. 与属于任何 2004 审查取证对象、由其持有、控制、代为持有或以其他方式与其有关的任何资金、证券、财产或资产有关的所有文件，包括任何及所有账户对账单、授权书、委托书、信托文件、指示或表格、已注销支票副本、函件、电汇以及相关函件和指示。\nCase 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 781 of 1063\n\n3. 与任何 2004 审查取证对象进行的任何商业、贸易或金融交易有关的所有文件，包括但不限于任何贷款、信贷额度、寄托、存款、掉期、证券交易、抵押贷款或 ISDA，包括任何及所有账户对账单、授权书、委托书、信托文件、指示或表格、已注销支票副本、函件、电汇以及相关函件和指示。\n\n4. 与 2004 审查取证对象有关的任何电汇活动有关的所有文件，不论是否存在任何账户，包括但不限于所有电汇收据、账号、余额、授权书、与转账当事人有关的身份识别信息、函件、指示或其他记录。\n\n5. 与您和 2004 审查取证对象之间的任何函件和通信有关的所有文件。\n\n6. 与任何 2004 审查取证对象的任何账户有关的所有文件，涉及账户开立、账户获授权使用人及账户维护。\n\n7. 与涉及任何 2004 审查取证对象的任何反洗钱、了解你的客户或其他合规活动有关的所有文件，包括但不限于由任何 2004 审查取证对象提供或由您获知的任何信息。\n\n8. 与就任何 2004 审查取证对象同任何国家的任何监管机构进行的任何通信有关的所有文件，包括但不限于 Bank of England（英格兰银行）、United States Federal Reserve（美国联邦储备系统）、S.E.C.（美国证券交易委员会）、CFTC（美国商品期货交易委员会）、FINRA（美国金融业监管局）、China Securities Regulatory Commission（中国证券监督管理委员会）、People's Bank of China（中国人民银行）、\nHong Kong Securities and Futures Commission（香港证券及期货事务监察委员会）及 Hong Kong Monetary Authority（香港金融管理局）。\n\n附件 C-43\n\nB2540（表格 2540 — Rule 2004 审查传票）（12/15）Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 784 of\n\nUNITED STATES BANKRUPTCY COURT（美国破产法院）1063\n\nDistrict of Connecticut（康涅狄格联邦地区）\n\n关于 HO WAN KWOK（郭文贵）等人案，\n\n1 Case No. 22-50073 (JAM)\n\n债务人 Chapter 11\n\n（合并管理）\nRULE 2004 审查传票\n\n致：National Australia Bank Limited（澳大利亚国民银行有限公司）\n\n（传票所指向之人的姓名）\n\n证言：现命令您于下列规定的时间、日期及地点出席，并就依据《联邦破产程序规则》Rule 2004 进行的审查作证。现随附准许该审查的法院命令副本。\n\n地点　日期及时间\n\nNeubert, Pepe & Monteith, P.C.（纽伯特、佩佩与蒙蒂思律师事务所）\n195 Church Street, Floor 13　[TBD]\nNew Haven, Connecticut 06510（康涅狄格州纽黑文 06510）\n\n审查将以如下方式记录：法庭记录员/速记员\n\n提交：您或您的代表还必须在审查时携带下列文件、电子存储信息或物品，并必须允许对该等材料进行检查、复制、测试或取样：\n见随附的文件提交请求。\n\n下列 Fed. R. Civ. P. 45 条款经 Fed. R. Bankr. P. 9016 适用于破产案件，现予附上——关于履行地点的 Rule 45(c)；关于您作为受传票约束之人的保护的 Rule 45(d)；以及关于您答复本传票之义务及未答复的潜在后果的 Rule 45(e) 和 45(g)。\n\n日期：March , 2023\n\n法院书记官\n\n或\n\n书记官或副书记官签名　律师签名\n\n签发或请求本传票的代表 Chapter 11 Trustee（第 11 章受托人）Luc A. Despins（吕克·A·德斯平）之律师的姓名、地址、电子邮件地址及电话号码如下：\n\nDouglas S. Skalka, Esq.（道格拉斯·S·斯卡尔卡，律师）；Neubert, Pepe & Monteith, P.C.（纽伯特、佩佩与蒙蒂思律师事务所）；195 Church Street, New Haven, Connecticut 06510（康涅狄格州纽黑文教堂街 195 号，邮编 06510）dskalka@npmlaw.com；(203) 821-2000\n\n致签发或请求本传票之人的通知\n\n如果本传票要求在审判前提交文件、以电子方式存储的信息或有形物品，或检查场所，则必须在向传票所指向之人送达本传票之前，向各方送达通知及本传票副本。Fed. R. Civ. P. 45(a)(4)。\n\n软件版权 (c) 1996-2022 Best Case, LLC（Best Case 有限责任公司）- www.bestcase.com Best Case Bankruptcy 1 本第 11 章案件中的债务人为 Ho Wan Kwok（郭文贵）（又名 Guo Wengui、Miles Guo 和 Miles Kwok，以及众多其他别名）（税务识别号码后四位：9595）、Genever Holdings LLC（Genever Holdings 有限责任公司）（税务识别号码后四位：8202）及 Genever Holdings Corporation（Genever Holdings 公司）。信托管理人、Genever Holdings LLC 及 Genever Holdings Corporation 的邮寄地址为 Paul Hastings LLP（保罗·黑斯廷斯律师事务所），200 Park Avenue, New York, NY 10166，转交 Luc A. Despins（卢克·A·德斯平斯），作为 Ho Wan Kwok 财产的信托管理人（仅为通知和通信之目的）。\n\n送达证明\n\n（除非 Fed. R. Civ. P. 45 要求，否则本节不应向法院提交。）\n\n本人于（日期）收到向（个人姓名及职务，如有）发出的本传票。\n\n本人通过如下方式向被指名之人交付副本，以送达本传票：\n\n于（日期）；或\n\n本人未执行传票即予退回，原因如下：\n\n除非传票系代表美国或其官员或代理人发出，本人亦已向证人支付一天出席费用及法律允许的里程费，金额为 $ 。\n\n本人的旅费为 $ ，服务费为 $ ，合计 $ 。\n\n本人在伪证处罚的约束下声明，本信息真实且正确。\n\n日期：\n\n送达人签名\n\n正楷姓名及职务\n\n送达人地址\n\n关于尝试送达等事项的补充信息：\n\n《联邦民事诉讼规则》第45条(c)、(d)、(e)及(g)项（自 12/1/13 起生效）（根据《联邦破产程序规则》第9016条适用于破产案件）\n\n(c) 履行地点。\n\n(1) 审判、听证或证言录取。传票仅可按如下方式命令某人出席审判、听证或证言录取：\n\n(A) 在该人居住、受雇或经常亲自从事营业之地 100 英里范围内；或\n\n(B) 在该人居住、受雇或经常亲自从事营业所在州内，若该人\n\n(i) 为当事人或当事人的高级职员；或\n\n(ii) 被命令出席审判且不会产生重大费用。\n\n(2) 其他证据开示。传票可命令：\n\n(A) 在该人居住、受雇或经常亲自从事营业之地 100 英里范围内的地点提交文件、以电子方式存储的信息或物品；及\n\n(B) 在拟检查的场所检查场所。\n\n(d) 保护受传票约束之人；执行。\n\n(1) 避免不当负担或费用；制裁。负责签发及送达传票的当事人或律师必须采取合理措施，避免对受传票约束之人施加不当负担或费用。要求履行的地区所属法院必须执行该义务，并对未遵守者的当事人或律师施加适当制裁，制裁可包括误工损失及合理律师费。\n\n(2) 命令提交材料或允许检查。\n\n(A) 无须出席。被命令提交文件、以电子方式存储的信息或有形物品，或允许检查场所之人，无须亲自到达提交或检查地点，除非同时被命令出席证言录取、听证或审判。\n\n(B) 异议。被命令提交文件或有形物品，或允许检查之人，可以就检查、复制、测试或抽样全部或部分材料，或检查场所，或以所要求的一种或多种形式提交以电子方式存储的信息，向传票中指定的当事人或律师送达书面异议。异议必须在规定的履行时间或传票送达后 14 天两者中较早者之前送达。如提出异议，适用以下规则：\n\n(i) 在任何时候，送达方经通知被命令之人后，可向要求履行的地区所属法院提出动议，请求作出强制提交或检查的命令。\n\n(ii) 仅可依命令所指示要求实施该等行为，且该命令必须保护并非当事人或当事人高级职员之人免受因履行而产生的重大费用。\n\n(3) 撤销或修改传票。\n\n(A) 必须撤销或修改的情形。经及时动议，要求履行的地区所属法院必须撤销或修改具有下列情形的传票：\n\n(i) 未给予合理的履行时间；\n\n(ii) 要求某人在第45条(c)项规定的地理范围以外履行；\n\n(iii) 要求披露享有特权或受其他保护的事项，且不适用任何例外或豁免；或\n\n(iv) 对某人施加不当负担。\n\n(B) 可以撤销或修改的情形。为保护受传票约束或受其影响之人，要求履行的地区所属法院可依动议撤销或修改要求下列事项的传票：\n\n(i) 披露商业秘密或其他保密的研究、开发或商业信息；或\n\n(ii) 披露未受聘专家的意见或信息，而该意见或信息并非描述争议中的具体事件，且系该专家在未经当事人请求的研究中所得。\n\n(C) 以指定条件作为替代方案。在第45条(d)(3)(B)项所述情形下，如送达方：\n\n(i) 证明其对该证言或材料具有无法在不造成不当困难的情况下以其他方式满足的重大需要；且\n\n(ii) 确保受传票人将获得合理补偿，\n\n法院可以不撤销或修改传票，而是在指定条件下命令出席或提交。\n\n(e) 回应传票的义务。\n\n(1) 提交文件或以电子方式存储的信息。以下程序适用于提交文件或以电子方式存储的信息：\n\n(A) 文件。回应提交文件传票之人必须按文件在正常业务过程中保存的方式提交，或者必须整理并标注文件，使其对应于请求中的类别。\n\n(B) 未指定提交以电子方式存储的信息的形式。如传票未指定提交以电子方式存储的信息的形式，回应之人必须以其通常保存的一种或多种形式，或以一种或多种合理可用的形式提交。\n\n(C) 以电子方式存储的信息仅以一种形式提交。回应之人无须以多于一种形式提交同一以电子方式存储的信息。\n\n(D) 无法合理获取的以电子方式存储的信息。回应之人无须就其认定因不当负担或费用而无法合理获取的来源中的以电子方式存储的信息提供证据开示。就强制证据开示或保护令提出动议时，回应之人必须证明该信息因不当负担或费用而无法合理获取。如作出该证明，法院在考虑第26条(b)(2)(C)项的限制后，如请求方证明有正当理由，仍可命令从该等来源进行证据开示。法院可为该证据开示指定条件。\n\n(2) 主张特权或保护。\n\n(A) 被扣留的信息。以该信息享有特权或作为审判准备材料受保护为由而扣留被传唤信息之人必须：(i) 明确提出该主张；并且\n\n(ii) 以一种在不披露本身享有特权或受保护信息的前提下，使当事人能够评估该主张的方式，描述被扣留文件、通信或有形物品的性质。\n\n(B) 已提交的信息。如为回应传票而提交的信息受到特权主张或作为审判准备材料受保护的主张，提出该主张之人可将该主张及其依据通知收到该信息的任何当事人。收到通知后，当事人必须立即返还、隔离或销毁所指定的信息及其拥有的任何副本；在该主张得到解决之前不得使用或披露该信息；如该当事人在收到通知前已披露该信息，必须采取合理措施取回该信息；并可立即将该信息密封提交给要求履行的地区所属法院，以裁定该主张。提交信息之人必须保存该信息，直至该主张得到解决。\n\n(g) 藐视法庭。要求履行的地区所属法院，以及在动议移送后签发传票的法院，可以对经送达后无充分理由不遵守传票或与其相关命令之人处以藐视法庭。\n\n有关获取传票材料，请参见 Fed.R.Civ.P.45(a) Committee Note (2013)\n\n……\n\n文件提交请求\n\nI. 指示\n\n1. 除非另有说明，下列文件请求（统称“请求”，每一项称为“一项请求”）必须分别且具体地作出回应。除非基于善意提出异议，否则必须完整答复每一项请求；如提出异议，必须按下文所述详细说明贵方异议的理由。如异议仅涉及某项请求的一部分，或其中所含的某个词语、短语或条款，贵方仅须说明对该部分的异议，并对其余请求作出回应。\n\n2. 必须按照下列指示提交以电子方式存储的信息：\n\na. 图像。黑白图像必须为 300 DPI Group IV 单页 TIFF 文件。彩色图像必须以 JPEG 格式提交。文件名不得包含嵌入空格或特殊字符（包括逗号）。文件夹名称不得包含嵌入空格或特殊字符（包括逗号）。所有 TIFF 图像文件必须具有唯一文件名，即 Bates 编号。图像必须在每张图像的右下角标注连续的 Bates 编号。每个文件夹中的 TIFF 文件数量不应超过 1000 个文件。Excel 电子表格应具有以文件的 Bates 编号命名的占位图像。\n\nb. 图像载入文件\n\na. Concordance® 数据文件。数据文件（.DAT）包含将载入 Concordance® 数据库的全部字段信息。.DAT 文件的第一行必须是标识字段名称的标题行。.DAT 文件必须使用以下 Concordance® 默认分隔符：逗号 ASCII 字符 (020) 引号 þ ASCII 字符 (254)。日期字段应按以下格式提供：mm/dd/yyyy。日期和时间字段必须为两个单独字段。如文件包括图像化电子邮件及附件，则必须包括附件字段，以保留电子邮件与其附件之间的父子关系。必须包括 OCRPATH 字段，以提供已提取文本文件在所提交存储介质上的文件路径和名称。文本文件必须以 FIRSTBATES 命名。不得在 .DAT 文件中包括文本。对于具有原生文件的文件，必须包括 LINK 字段，以提供原生文件的文件路径和名称。原生文件必须以 FIRSTBATES 命名。\n\n- b. Concordance Image® 或 Opticon 交叉引用文件。图像交叉引用文件（.LOG 或 .OPT）将图像链接至数据库记录。其应为以逗号分隔的文件，每行包含七个字段，并且数据库中的每个图像在交叉引用文件中均应有一行，格式如下：ImageID,VolumeLabel,ImageFilePath,DocumentBreak,FolderBreak,Box Break,PageCoun。\n\n- c. 文件文本。文本必须作为单独的文本文件提供，而非作为 .DAT 文件中的字段。文本文件的完整路径（OCRPATH）应包含在 .DAT 文件中。建议提供文件级 ANSI 文本文件，并按 FIRSTBATES/Image Key 命名。提取的文本文件必须置于单独的文件夹中，且每个文件夹中的文本文件数量不得超过 1,000 个。文件夹名称中不得含有特殊字符（包括逗号）。文本文件必须按文件级别提供。\n\n- d. 特定文件类型的原生格式提供。为完整理解其内容和含义而合理需要以其原生格式查看的文件类型，必须以原生格式提供。这些文件包括但不限于：电子表格、类电子表格文件（Microsoft Excel、逗号分隔值、制表符分隔值等）、Microsoft PowerPoint 或其他特殊演示文件、数据库文件以及音频/视频文件。应提供一张带有 Bates 编号的分隔页图像，以表明原生文件的存在，并在 .dat 文件中将原生文件路径作为一个字段列入。所提供的原生文件应以该文件分隔页对应的 Bates 编号命名。原生文件应归入按递增方式命名的“NATIVE”目录中，并与图像目录分开。\n\n- e. 去重。对于存在完全重复件的每一电子文件，仅提供一份副本。对于电子邮件，应根据由 BCC、Body、CC、From、IntMsgID、To 和 Attach 属性生成的 MD5 哈希值合并重复件。对于电子邮件附件和独立电子文件，应根据整个文件的 MD5 哈希值合并重复件。\n\n- f. 元数据。应以符合 Concordance 要求的加载文件（.dat）形式提供每份文件的提取元数据。.DAT 文件的第一行必须为标识字段名称的标题行。.DAT 文件必须使用以下 Concordance 默认分隔符：逗号 , ASCII 字符（020）引号 þ ASCII 字符（254）\n\n日期字段应采用以下格式提供：mm/dd/yyyy。日期和时间字段必须为两个单独字段。以下为必需的元数据：\n案件 22-50073 文件 1592 提交日期 03/24/23 录入日期 03/24/23 10:57:37 第 789 页，共 1063 页\n\n字段名称　示例数据　说明\n\nFIRSTBATES　EDC0000001　原生文件文件/电子邮件的第一个 Bates 编号\nLASTBATES　EDC0000001　原生文件文件/电子邮件的最后一个 Bates 编号\nLASTBATES 字段应针对单页文件填入\nATTACHRANGE　EDC0000001\n-　父文件第一页的 Bates 编号至\nEDC0000015　最后一个附件“子”文件最后一页的 Bates 编号\nBEGATTACH　EDC0000001　附件范围的第一个 Bates 编号\nENDATTACH　EDC0000015　附件范围的最后一个 Bates 编号\nCUSTODIAN　Smith, John　电子邮件：该电子邮件所在的邮箱\n原生文件：文件来源的个人或部门名称\nFROM　John Smith　电子邮件：发件人\n原生文件：文件作者\n应使用分号分隔多个条目\nTO　Coffman, Janice; LeeW　收件人\n[mailto:LeeW@MSN.com]　应使用分号分隔多个条目\nCC　Frank Thompson [mailto:　抄送收件人\nfrank_Thompson@cdt.com]　应使用分号分隔多个条目\nBCC　John Cain　密送收件人\n应使用分号分隔多个条目\nSUBJECT　Board Meeting Minutes　电子邮件：电子邮件主题行 原生文件：文件标题（如有）\nFILE_NAME　BoardMeetingMinutes.docx　原生文件：原始原生文件的名称，包括扩展名\nDATE_SENT　10/12/2010　电子邮件：电子邮件发送日期\n原生文件：（空）\nTIME_SENT/　07:05 PM GMT　电子邮件：电子邮件发送时间/电子邮件标准化所采用的时区\nTIME_ZONE\nTIME_ZONE　GMT　在转换过程中电子邮件被标准化所采用的时区。\nLINK　EDC0000001.msg　电子邮件或原生文件文件的超链接\n链接文件必须按 FIRSTBATES 编号命名\nFILE_EXTEN　MSG　代表电子邮件或原生文件的文件类型扩展名\nAUTHOR　John Smith　电子邮件：（空）\n原生文件：文件作者\nDATE_CREATED　10/10/2010　电子邮件：（空）\n原生文件：文件创建日期\n案件 22-50073 文件 1592 提交日期 03/24/23 录入日期 03/24/23 10:57:37 第 790 页，共 1063 页\n\nTIME_CREATED　10:25 AM　电子邮件：（空）\n原生文件：文件创建时间\n该数据必须为单独字段，不得与 DATE_CREATED 字段合并\nDATE_MOD　10/12/2010　电子邮件：（空）\n原生文件：文件最后修改日期\nTIME_MOD　07:00 PM　电子邮件：（空）\n原生文件：文件最后修改时间\n该数据必须为单独字段，不得与 DATE_MOD 字段合并\nDATE_ACCESSD　10/12/2010　电子邮件：（空）\n原生文件：文件最后访问日期\nTIME_ACCESSD　07:00 PM　电子邮件：（空）\n原生文件：文件最后访问时间\n该数据必须为单独字段，不得与 DATE_ACCESSD 字段合并\nFILE_SIZE　5,952　原生文件文件/电子邮件的大小，以 KB 计\nPGCOUNT　1　原生文件文件/电子邮件的页数\nPATH　电子邮件：（空）\nAgenda.doc　原生文件：存储原生文件文件的路径，包括原始文件名称。\nINTFILEPATH　Personal Folders\\Deleted　电子邮件：电子邮件的原始位置，包括原始文件名称。\nItems\\Board Meeting\nMinutes.msg　原生文件：（空）\nINTMSGID　<000805c2c71b\\$75977050\\$　电子邮件：唯一邮件 ID 原生文件：（空）\ncb8306d1@MSN>\nMD5HASH　d131dd02c5e6eec4693d9a0　文件的 MD5 哈希值。\n698aff95c\n2fcab58712467eab4004583e\nb8fb7f89\nOCRPATH　TEXT/001/EDC0000001.txt　原生文件提取文本的路径\n\n3. 各项请求均独立适用并应独立解释；除非另有说明，任何一项请求均不限制任何其他请求的范围。\n\n4. 所有文件均应按通常业务过程中保存的方式提供，或者应加以组织和标记，以对应于本请求中的类别。\n\n5. 本文所载每项请求均延伸至所有文件：(a) 由您占有、保管或控制的文件；或 (b) 由任何代表您行事的人占有、保管或控制的文件，\n案件 22-50073 文件 1592 提交日期 03/24/23 录入日期 03/24/23 10:57:37 第 791 页，共 1063 页\n\n包括您的律师或其他代表和顾问。每份文件均应完整提供。\n\n6. 如要求您提供一份已不再由您占有、保管或控制的文件，则您的答复必须：(a) 详细说明该文件的性质及其内容；(b) 确定编制或撰写该文件的人士（以及，如适用，接收该文件的人士）；(c) 确定该文件编制或创建的日期；(d) 说明该文件是否：(i) 遗失或丢失，(ii) 已被销毁，(iii) 已自愿或非自愿地转移给他人，或 (iv) 以其他方式被处置；(e) 说明该等处置的理由，以及围绕该等处置的事实和情形；(f) 确定授权该等处置的人士；(g) 确定该等处置的日期或大致日期；(h) 说明该文件最近一次由您占有、保管或控制的时间；以及 (i) 确定现时占有、保管或控制该文件的人士（如有）。\n\n7. 如要求您提供一份已被销毁的文件，则除前一项指示所要求的信息外，您的答复还必须说明：(a) 销毁该文件的理由；(b) 销毁该文件的人士身份；以及 (c) 指示销毁该文件的人士身份。\n\n8. 如您主张所请求的文件受特权或律师工作成果保护，则您的答复必须：(a) 说明：(i) 对该文件作出足以支持您关于该文件受特权保护之主张的描述，(ii) 该文件的标题，(iii) 该文件的日期，(iv) 该文件的作者，(v) 该文件的收件人，(vi) 接收或阅览该文件原件或任何草稿、副本或复制件的每名人士的身份，(vii) 该文件本身或文件所载或提及的任何信息是否由任何其他人士占有、保管或控制；如是，则说明该等人士的身份，\n案件 22-50073 文件 1592 提交日期 03/24/23 录入日期 03/24/23 10:57:37 第 792 页，共 1063 页\n\n以及说明该等信息如何进入其占有范围，(viii) 据以扣留该文件的特权主张，及 (ix) 您将依赖以支持该等特权主张的所有情形；以及 (b) 对于基于特权主张而扣留的每份文件，依照 D. Conn. L. Civ. R. 26(e)，提供一份特权日志，其中载明本指示第 (a) 部分所要求的全部信息。对于文件请求中未提出特权或工作成果主张的任何部分，应完整提供响应性文件。\n\n9. 如原本具有响应性的文件中有一部分包含受特权主张约束的信息，则仅应依照上述指示从该文件中删除或遮盖受特权主张约束的该部分，其余部分应予提供。\n\n10. 各项请求具有持续性。现指示您：(a) 一旦得知先前答复不完整或不正确，应立即补充或更正任何后来发现不完整或不正确的答复；以及 (b) 提供根据各项请求所要求的任何额外文件。\n\n11. 如文件使用英语以外的语言，您应提供该文件。如文件使用英语以外的语言，且存在英文译本，您应同时提供两份文件。\n\n12. 对实体的一切提述均包括其所有关联方。\n\n13. 对个人姓名的一切提述均包括所有替代姓名、别名或昵称。\n案件 22-50073 文件 1592 提交日期 03/24/23 录入日期 03/24/23 10:57:37 第 793 页，共 1063 页\n\n14. 除非另有明确说明，文件请求所涵盖的期间为自 February 5, 2012 起至应提交文件请求答复之日止。\nII. 解释规则\n\n15. (a) 任何单数名词的使用应解释为包括复数，反之亦然；及 (b) 任何时态的动词应解释为使用该动词的所有其他时态。\n\n16. (a) 术语“and”和“or”应视需要解释为连词或析取词，以将原本可能被解释为不在任何请求范围内的所有答复纳入该请求范围；及 (b) “each”和“any”应被视为包括并涵盖“every”和“all”。\nIII. 定义\n\nD. Conn. L. Civ. R. 26(c) 所提供的定义以及 D. Conn. L. Civ. R. 26(d) 所提供的解释规则，并经 D. Conn. Bankr. L.R. 2004-1(a) 纳入，均适用于文件请求。此外，本文件请求中使用的下列术语具有如下含义：\n\n1. “您”或“您的”或“您本人”系指 National Australia Bank Limited（澳大利亚国民银行有限公司）。\n\n2. “债务人”系指 Ho Wan Kwok（郭文贵）（又名 Miles Kwok、Miles Guo、Guo Wengui、Guo Haoyun、郭文贵或任何其他别名），连同其雇员、代理人、律师、顾问或任何代表其行事之人。\n案件 22-50073 文件 1592 提交日期 03/24/23 录入日期 03/24/23 10:57:37 第 794 页，共 1063 页\n\n3. “债务人之子”系指 Qiang Guo（郭强）（又名 Mileson Kwok、郭强或任何其他别名），连同其雇员、代理人、律师、顾问或任何代表其行事之人。\n\n4. “债务人的女儿”系指 Mei Guo（郭美，亦称 Mei Gui、郭美或任何其他别名），以及其雇员、代理人、律师、顾问或任何代表其行事的人。\n\n5. “债务人声称的妻子”系指 Hing Chi Ngok（岳庆芝，亦称 Hing Chi Ng、Yue Qingzhi、岳庆芝或任何其他别名），以及其雇员、代理人、律师、顾问或任何代表其行事的人。\n\n6. “债务人家属”单独及共同系指债务人、债务人的儿子、债务人的女儿及债务人声称的妻子，以及与债务人具有任何其他家庭关系的人。\n\n7. “2004 调查对象”单独及共同系指债务人、债务人家属、ACA Capital Group Limited（ACA资本集团有限公司）、Himalaya International Financial Group Ltd.（喜马拉雅国际金融集团有限公司）、Himalaya International Clearing Ltd.（喜马拉雅国际清算有限公司）、Himalaya International Payments Ltd.（喜马拉雅国际支付有限公司）、Himalaya International Reserves Ltd.（喜马拉雅国际储备有限公司）、Jesse Brown（杰西·布朗）、William Je（威廉·杰）、William Je（威廉·杰）、Eastern Profit Corporation Limited（东方利润有限公司）、HK International Funds Investments (USA) Limited LLC（香港国际基金投资〈美国〉有限责任公司）、Bravo Luck Limited（瑞福有限公司）、Golden Spring (New York) Ltd.（金泉〈纽约〉有限公司）、Lamp Capital LLC（兰普资本有限责任公司）、Greenwich Land LLC（格林尼治土地有限责任公司）、Qu Guo Jiao（瞿国娇）、Daniel Thomas Podhaskie（丹尼尔·托马斯·波德哈斯基）、Yvette Wang（王艳萍，亦称 Yanping Wang、Yan Ping Wang）、Ace Decade Holdings Limited（艾斯十年控股有限公司）、Dawn State Limited（黎明州有限公司）、Rule of Law Society IV Inc.（法治协会IV有限公司）、Rule of Law Foundation III, Inc.（法治基金会III有限公司）、Rule of Law Foundation IV, Inc.（法治基金会IV有限公司）、Rule of Law Fund（法治基金）、Rule of Law Society（法治协会）、GTV Media Group, Inc.（GTV媒体集团有限公司）、Voice of Guo Media, Inc.（郭媒体之声有限公司）、Saraca Media Group Inc.（萨拉卡媒体集团有限公司）、Genever Holdings Corporation（吉尼弗控股公司）、Genever Holdings LLC（吉尼弗控股有限责任公司）、Gnews Media Group Inc.（Gnews媒体集团有限公司）、G Fashion LLC（G时尚有限责任公司）、Gmusic LLC（G音乐有限责任公司）、Gnews LLC（Gnews有限责任公司）、Geducation（G教育）、GFNY, Inc.（GFNY有限公司）、G-Club Investments Limited（G-Club投资有限公司）、G Club Operations LLC（G Club运营有限责任公司）、G Club US Operations Inc.（G Club美国运营有限公司）、G Club US Operations LLC（G Club美国运营有限责任公司）、G Live, LLC（G直播有限责任公司）、Gbroadcast, LLC（G广播有限责任公司）、Gposts LLC（G帖子有限责任公司）、HCHK Property\n\n案件 22-50073 文档 1592 提交日期 03/24/23 录入日期 03/24/23 10:57:37 第 795 页，共 1063 页\n\nManagement, Inc.（HCHK物业管理有限公司）、HCHK Technologies, Inc.（HCHK技术有限公司）、FMV Ltd./Freedom Media Venture Ltd.（FMV有限公司／自由媒体风险投资有限公司）、Roscalitar 2（Roscalitar 2）、Himalaya New World Inc.（喜马拉雅新世界有限公司）、US Himalaya Capital Inc.（美国喜马拉雅资本有限公司）、Hudson Diamond Holding, Inc.（哈德逊钻石控股有限公司）、Hudson Diamond Holding LLC（哈德逊钻石控股有限责任公司）、Hudson Diamond NY LLC（哈德逊钻石纽约有限责任公司）、Infinity Treasury Management Inc.（无限资金管理有限公司）、Lexington Property and Staffing, Inc.（列克星敦物业及人力配置有限公司）、AI Group Holdings Inc.（AI集团控股有限公司）、Hamilton Capital Holdings Inc.（汉密尔顿资本控股有限公司）、Booming Sail New York LLC（繁荣帆船纽约有限责任公司）、Himalaya Ventures LLC（喜马拉雅风投有限责任公司）、Himalaya Ventures LLC（喜马拉雅风投有限责任公司）、Himalaya Investment LLC（喜马拉雅投资有限责任公司）、New York MOS Himalaya LLC（纽约MOS喜马拉雅有限责任公司）、MOS Himalaya LLC（MOS喜马拉雅有限责任公司）、Crane Advisory Group（克兰咨询集团）、Maywind Trading LLC（五月风贸易有限责任公司）、Gettr USA, Inc.（Gettr美国有限公司）、Han Chunguang（韩春光）、Bingshang Jiao（焦冰上）、Karin Maistrello（卡琳·迈斯特雷洛）、Mary Jiang（姜玛丽）、Jiaming Liu（刘家明）及 Wencong Wang（王文聪）。\n\n8. “包括”或其任何变体，系指“包括但不限于”。\n\n9. “和”及“或”系指“和／或”，并应以连词及选择连词两种方式解释，以最大限度扩大其范围。\n\n10. “任何”及“所有”以及“每一”均系指“每一个及全部”。\n\n11. “每一”及“每个”均系指“每一个及全部”。\n\n12. “第三方”系指除贵方以外的个人或实体。\n\n13. “转让”应具有《破产法》第 101(54) 条赋予该词的含义。\n\n14. “文件”系指属于 Fed. R. Civ. P. 34 范围内的任何信息或物品，并包括但不限于目前或曾经由贵方占有、保管或控制的各种、各种类型、性质或描述的每一项书面、记录或图形材料，包括电子邮件的所有打印及电子副本、以电子形式保存的计算机文件、函件、备忘录、磁带、速记或手写笔记、任何种类的书面表格、图表、蓝图、绘图、草图、曲线图、计划、文章、规格、日记、信件、\n\n案件 22-50073 文档 1592 提交日期 03/24/23 录入日期 03/24/23 10:57:37 第 796 页，共 1063 页\n\n电报、照片、会议记录、合同、协议、调查资料、计算机打印输出、任何种类的数据汇编、电传、传真、电子邮件、短信、即时消息、语音信息、发票、订单表格、支票、汇票、对账单、贷项通知单、报告、头寸报告、摘要、索引、书籍、分类账、笔记本、清单、透明胶片、录音、目录、广告、宣传材料、影片、录像带、录音带、CD、计算机磁盘、宣传册、小册子、穿孔卡、工时单、推文、社交媒体帖子，或任何其他种类的书面或记录材料，以及其全部元数据，无论以何种方式储存（无论以有形或电子形式）、记录、制作或复制；还包括但不限于上述任何文件的草稿或副本，其中包含原始文件中不存在的任何种类笔记、评论或标记，或在其他方面与原始文件不完全相同的草稿或副本。\n\n15. “个人”系指个人、公司、独资企业、合伙企业、协会或任何其他实体。“个人”还包括任何代理人、代表或专家，包括但不限于律师或财务顾问。\n\n16. “实体”系指任何自然人、公司、合伙企业、子公司、独资企业、商号、董事会、合资企业、协会、机构、主管机关、委员会或其他商业实体或法人，以及任何关联方、代理人、母公司，包括但不限于律师、财务顾问或任何其他代表。\n\n17. “关于”系指涉及、描述、构成、提及、与之相关、支持、有利于、反对、强化、削弱、位于、结合考虑、对其有影响、证明、表明、报告、记录、暗指、回应、与之相连、评论、就其而言、有关、与之相关、讨论、显示、描述、反映、分析、构成及属于。\n\n案件 22-50073 文档 1592 提交日期 03/24/23 录入日期 03/24/23 10:57:37 第 797 页，共 1063 页\n\n18. 就任何特定主题而言，“与……有关”“涉及”或“相关”，系指但不限于构成、包含、涉及、载有、体现、反映、识别、陈述、直接或间接提及该特定主题，或以任何方式与所识别的特定主题相关的任何文件。\n\n19. “通信”在最广泛可能的意义上且不受限制地系指任何信息或知识的传递（以事实、观点、询问或其他形式）。通信还指所有谈话、协议、询问或答复，无论是当面、通过电话、以书面方式，还是借助电子传输设备进行，并包括但不限于所有函件、电子邮件、录音、传送单、备忘录、电话通信、语音信息、电报、电传传真、复印传真、电传、即时消息、聊天、短信、留言板或群聊中的帖子、社交媒体帖子、推文、上传至任何视频平台的视频、电话笔记，或在内部或与第三方传送的笔记。\n\n20. “资产”系指受占有、保管或控制的任何具有经济价值的项目。资产包括所有不动产和动产，包括但不限于房地产、土地、房屋、公寓、共管公寓、汽车、游艇、船舶、飞机、喷气式飞机、直升机、现金、银行账户、加密货币、证券、应收账款、存货及其他有形和无形财产。\n\nIV. 应提交的文件\n\n1. 与由任何 2004 调查对象持有、控制、代表其持有，或以其他方式与其有关的任何账户相关的全部文件，包括任何及所有账户对账单、授权书、委托书、信托文件、指示或表格、已注销支票副本、函件以及电汇及其相关函件和指示。\n\n案件 22-50073 文档 1592 提交日期 03/24/23 录入日期 03/24/23 10:57:37 第 798 页，共 1063 页\n\n2. 与属于任何 2004 调查对象、由其持有、控制、代表其持有，或以其他方式与其有关的任何资金、证券、财产或资产相关的全部文件，包括任何及所有账户对账单、授权书、委托书、信托文件、指示或表格、已注销支票副本、函件以及电汇及其相关函件和指示。\n\n3. 与任何 2004 调查对象进行的任何商业、贸易或金融交易相关的全部文件，包括但不限于任何贷款、授信额度、寄托、存款、互换、证券交易、抵押贷款或 ISDA，包括任何及所有账户对账单、授权书、委托书、信托文件、指示或表格、已注销支票副本、函件以及电汇及其相关函件和指示。\n\n4. 与 2004 调查对象有关的任何电汇活动相关的全部文件，不论是否存在任何账户，包括但不限于所有电汇收据、账号、余额、授权书、与转账当事人有关的身份识别信息、函件、指示或其他记录。\n\n5. 与贵方和 2004 调查对象之间的任何函件和通信相关的全部文件。\n\n6. 与贵方在任何 2004 调查对象处开立的任何账户相关的全部文件，包括与账户开立、账户获授权用户及账户维护有关的文件。\n\n7. 与任何 2004 调查对象有关的任何反洗钱、了解你的客户或其他合规活动相关的全部文件，包括但不限于任何 2004 调查对象提供给贵方或贵方获悉的任何信息。\n\n8. 与任何国家的任何监管机构进行的、与任何 2004 调查对象有关的任何通信相关的全部文件，包括但不限于 Bank of England（英格兰银行）、United States Federal Reserve（美国联邦储备系统）、\n\nS.E.C.（美国证券交易委员会）、CFTC（美国商品期货交易委员会）、FINRA（美国金融业监管局）、China Securities Regulatory Commission（中国证券监督管理委员会）、People's Bank of China（中国人民银行）、Hong Kong Securities and Futures Commission（香港证券及期货事务监察委员会）及 Hong Kong Monetary Authority（香港金融管理局）。\n\n案件 22-50073 文档 1592 提交日期 03/24/23 录入日期 03/24/23 10:57:37 第 800 页，共 1063 页\n\n附件 C-44\n\nB2540（表格 2540－Rule 2004 审查传票）（12/15）案件 22-50073 文档 1592 提交日期 03/24/23 录入日期 03/24/23 10:57:37 第 801 页，共\n\nUNITED STATES BANKRUPTCY COURT（美国破产法院）\n\nDistrict of Connecticut（康涅狄格地区）\n\n关于 HO WAN KWOK（郭文贵）等人，\n\n1 案号 22-50073 (JAM)\n\n债务人 第 11 章\n\n（合并管理）\n\nRule 2004 审查传票\n\n致：Metropolitan Commercial Bank（大都会商业银行）及／或 Metropolitan Bank Holding Corp.（大都会银行控股公司）\n\n（传票所指向人员的姓名）\n\n证言：兹命令贵方于下列规定的时间、日期及地点出席，并依据《联邦破产程序规则》Rule 2004 就审查作证。随附授权进行该审查的法院命令副本。\n\n地点　日期及时间\n\nNeubert, Pepe & Monteith, P.C.（诺伊伯特、佩佩及蒙蒂思律师事务所）\n195 Church Street, Floor 13　[TBD]\nNew Haven, Connecticut 06510\n\n审查将以下列方式记录：法庭记录员／速记员\n\n提交：贵方或贵方代表还必须携带下列文件、电子储存信息或物品出席审查，并必须允许对该等材料进行检查、复制、测试或取样：\n\n见随附的文件提交请求。\n\n下列 Fed. R. Civ. P. 45 条款，根据 Fed. R. Bankr. P. 9016 适用于破产案件，随附于后——有关履行地点的 Rule 45(c)；有关作为传票对象的贵方所受保护的 Rule 45(d)；以及有关贵方回应本传票的义务及未履行该义务可能后果的 Rule 45(e) 和 45(g)。\n\n日期：March , 2023\n\n法院书记员\n\n或\n\n书记员或副书记员签名　律师签名\n\n签发或请求本传票、代表第 11 章受托人 Luc A. Despins（卢克·A·德斯平斯）的律师姓名、地址、电子邮箱地址及电话号码如下：\n\nDouglas S. Skalka, Esq.（道格拉斯·S·斯卡尔卡律师）；Neubert, Pepe & Monteith, P.C.（诺伊伯特、佩佩及蒙蒂思律师事务所）；195 Church Street, New Haven, Connecticut 06510；dskalka@npmlaw.com；(203) 821-2000\n\n向签发或请求本传票之人的通知\n\n如果本传票要求在审判前提交文件、电子存储信息或有形物品，或检查场所，则必须在向受送达人送达本传票之前，向每一当事人送达通知及本传票副本。Fed. R. Civ. P. 45(a)(4)。\n\n软件版权所有 (c) 1996-2022 Best Case, LLC（Best Case 有限责任公司）- www.bestcase.com Best Case Bankruptcy 1 本第11章案件中的债务人为 Ho Wan Kwok（郭文贵，亦称 Guo Wengui、Miles Guo 和 Miles Kwok，以及众多其他别名）（税务识别号码后四位：9595）、Genever Holdings LLC（Genever Holdings 有限责任公司）（税务识别号码后四位：8202）及 Genever Holdings Corporation（Genever Holdings 公司）。受托人、Genever Holdings LLC 和 Genever Holdings Corporation 的邮寄地址为 Paul Hastings LLP（普衡律师事务所），200 Park Avenue, New York, NY 10166，c/o Luc A. Despins，作为 Ho Wan Kwok 遗产的受托人（仅为通知和通信之目的）。\n\n送达证明\n\n（除非 Fed. R. Civ. P. 45 要求，否则本节不应向法院提交。）\n\n本人于（日期）收到向（个人姓名及职务，如有）发出的本传票。\n\n本人已按以下方式向指定人员交付副本，从而送达本传票：\n\n于（日期）；或\n\n本人未执行而退回本传票，原因如下：\n\n除非本传票系代表美国或其官员或代理人发出，本人还已向证人预付其一天出席费用及法律允许的里程费用，金额为 \\$ 。\n\n本人的旅费为 \\$，服务费为 \\$，合计 \\$ 。\n\n本人在伪证处罚的约束下声明，该等信息真实且正确。\n\n日期：\n\n送达人员签名\n\n印刷姓名及职务\n\n送达人员地址\n\n有关尝试送达等事项的补充信息：\n\n《联邦民事诉讼规则》第45(c)、(d)、(e)和(g)项（自12/1/13起生效）（根据《联邦破产程序规则》第9016条适用于破产案件）\n\n(c) 履行地点。\n\n(1) 审判、听证或证言录取。传票仅可按以下方式命令某人出席审判、听证或证言录取：\n\n(A) 在该人居住、受雇或经常亲自从事商业活动地点的100英里范围内；或\n\n(B) 在该人居住、受雇或经常亲自从事商业活动所在州内，如该人\n\n(i) 为当事人或当事人的高级职员；或\n\n(ii) 被命令出席审判且不会产生重大费用。\n\n(2) 其他证据开示。传票可以命令：\n\n(A) 在该人居住、受雇或经常亲自从事商业活动地点的100英里范围内某一地点提交文件、电子存储信息或物品；以及\n\n(B) 在待检查的场所检查场所。\n\n(d) 保护受传票约束之人；执行。\n\n(1) 避免不当负担或费用；制裁。负责签发和送达传票的当事人或律师必须采取合理措施，避免对受传票约束之人施加不当负担或费用。要求履行义务所在地辖区的法院必须执行该义务，并对未遵守该义务的当事人或律师施加适当制裁，该制裁可包括损失的收入及合理的律师费。\n\n(2) 命令提交材料或允许检查。\n\n(A) 无须出席。被命令提交文件、电子存储信息或有形物品，或允许检查场所之人，无须亲自到提交或检查地点出席，除非同时被命令出席证言录取、听证或审判。\n\n(B) 异议。被命令提交文件或有形物品，或允许检查之人，可以向传票中指定的当事人或律师送达书面异议，反对检查、复制、测试或抽样任何或全部材料，或反对检查场所，或反对以所要求的一种或多种形式提交电子存储信息。异议必须在规定履行时间届满前或传票送达后14日内（以较早者为准）送达。如提出异议，适用下列规则：\n\n(i) 在任何时间，经通知被命令人，送达方可以向要求履行义务所在地辖区的法院提出动议，请求作出强制提交或检查的命令。\n\n(ii) 仅可按照命令所指示的方式要求实施该等行为，并且该命令必须保护并非当事人或当事人高级职员之人免于因履行义务而产生的重大费用。\n\n(3) 撤销或修改传票。\n\n(A) 必须撤销或修改的情形。经及时提出动议，要求履行义务所在地辖区的法院必须撤销或修改具有下列情形的传票：\n\n(i) 未给予合理履行时间；\n\n(ii) 要求某人在第45(c)项规定的地理范围之外履行义务；\n\n(iii) 要求披露享有特权或受其他保护的事项，而不存在适用的例外或豁免；或\n\n(iv) 对某人施加不当负担。\n\n(B) 可以撤销或修改的情形。为保护受传票约束或受传票影响之人，要求履行义务所在地辖区的法院可以依动议撤销或修改要求下列事项的传票：\n\n(i) 披露商业秘密或其他保密研究、开发或商业信息；或\n\n(ii) 披露未经聘用专家的意见或信息，该等意见或信息并非描述争议中的特定事件，且源于当事人未请求进行的专家研究。\n\n(C) 以规定条件作为替代办法。在第45(d)(3)(B)项所述情形下，如送达方：\n\n(i) 证明对该证言或材料具有重大需要，且无法在不遭受不当困难的情况下以其他方式满足该需要；并且\n\n(ii) 确保受传票人将获得合理补偿，\n\n法院可以不撤销或修改传票，而是命令在规定条件下出席或提交。\n\n(e) 回应传票的义务。\n\n(1) 提交文件或电子存储信息。下列程序适用于提交文件或电子存储信息：\n\n(A) 文件。回应提交文件传票之人必须按照其在正常业务过程中保存的方式提交文件，或者必须对其进行整理和标记，以对应请求中的类别。\n\n(B) 未规定电子存储信息的提交形式。如传票未规定电子存储信息的提交形式，回应之人必须以其通常保存的一种或多种形式，或者以合理可用的一种或多种形式提交。\n\n(C) 电子存储信息仅以一种形式提交。回应之人无须以一种以上形式提交相同的电子存储信息。\n\n(D) 无法访问的电子存储信息。回应之人无须就其认定因不当负担或费用而无法合理访问的来源中的电子存储信息提供证据开示。在要求强制证据开示或保护令的动议中，回应之人必须证明该信息因不当负担或费用而无法合理访问。如作出该证明，在考虑第26(b)(2)(C)项的限制后，如请求方证明具有正当理由，法院仍可命令从该等来源进行证据开示。法院可以规定证据开示的条件。\n\n(2) 主张特权或保护。\n\n(A) 扣留的信息。以该信息享有特权或作为审判准备材料受保护为由扣留传票要求的信息之人必须：(i) 明确提出该主张；以及\n\n(ii) 以一种不披露本身享有特权或受保护信息的方式，描述被扣留文件、通信或有形物品的性质，使当事人能够评估该主张。\n\n(B) 已提交的信息。如为回应传票而提交的信息受到特权主张或作为审判准备材料受保护的主张约束，提出主张之人可以将该主张及其依据通知收到该信息的任何当事人。收到通知后，当事人必须立即返还、隔离或销毁指定信息及其持有的任何副本；在主张得到解决前不得使用或披露该信息；如当事人在收到通知前已披露该信息，必须采取合理措施追回该信息；并可以立即将该信息密封提交给要求履行义务所在地辖区的法院，以裁定该主张。提交该信息之人必须在该主张得到解决前保存该信息。\n\n(g) 藐视法庭。要求履行义务所在地辖区的法院，以及在动议移送后签发传票的法院，可以认定已被送达但无充分理由不遵守传票或与其相关命令之人构成藐视法庭。\n\n有关获取传票材料，请参见 Fed.R.Civ.P.45(a) Committee Note (2013)\n\n……\n\n文件提交请求\n\nI. 指示\n\n1. 除非另有说明，下列文件请求（以下简称“请求”，每一项称为“一项请求”）必须分别且具体地作出回应。除非善意提出异议，否则每项请求均应完整答复；如提出异议，则必须按照下文所述详细说明您提出异议的理由。如异议仅涉及某项请求的一部分，或其中所含的某个词语、短语或条款，您仅须说明对该部分的异议，并回应请求的其余部分。\n\n2. 电子存储信息必须按照下列指示提交：\n\na. 图像。黑白图像必须为300 DPI Group IV 单页 TIFF 文件。彩色图像必须以 JPEG 格式提交。文件名不得包含嵌入空格或特殊字符（包括逗号）。文件夹名称不得包含嵌入空格或特殊字符（包括逗号）。所有 TIFF 图像文件必须具有唯一文件名，即 Bates 编号。每张图像的右下角必须标注连续的 Bates 编号。每个文件夹中的 TIFF 文件数量不应超过1000个文件。Excel 电子表格应具有一个以该文件 Bates 编号命名的占位图像。\n\nb. 图像加载文件\n\na. Concordance® 数据文件。数据文件（.DAT）包含将加载到 Concordance® 数据库中的所有字段信息。.DAT 文件的第一行必须为标识字段名称的标题行。.DAT 文件必须使用以下 Concordance® 默认分隔符：逗号 ASCII 字符（020）引号 þ ASCII 字符（254）。日期字段应以如下格式提供：mm/dd/yyyy。日期和时间字段必须为两个独立字段。如文件包括图像化的电子邮件及附件，则必须包括附件字段，以保留电子邮件与其附件之间的父/子关系。必须包括 OCRPATH 字段，以提供所提交存储介质上提取文本文件的文件路径和名称。文本文件必须以 FIRSTBATES 命名。不得在 .DAT 文件中包含文本。对于包含原生文件的文件，必须包括 LINK 字段，以提供原生文件的文件路径和\n\n名称。原生文件必须以 FIRSTBATES 命名。\n\nb. Concordance Image® 或 Opticon 交叉引用文件。图像交叉引用文件（.LOG 或 .OPT）将图像链接至数据库记录。该文件应为逗号分隔文件，每行由七个字段组成，并且数据库中的每个图像在交叉引用文件中均应有一行，格式如下：ImageID,VolumeLabel,ImageFilePath,DocumentBreak,FolderBreak,Box Break,PageCoun。\n\nc. 文档文本。文本必须作为单独的文本文件提供，而非作为 .DAT 文件中的字段提供。文本文件的完整路径（OCRPATH）应包含在 .DAT 文件中。建议提供以 FIRSTBATES/Image Key 命名的文档级 ANSI 文本文件。提取的文本文件必须置于单独的文件夹中，每个文件夹中的文本文件数量不得超过 1,000 个。文件夹名称中不得含有特殊字符（包括逗号）。必须按文档级别提供文本文件。\n\nd. 特定文件类型的原生格式提供。为完整理解其内容及含义而合理需要以原生格式查看的文件类型，必须以原生格式提供。该等文件包括但不限于：电子表格、类电子表格文件（Microsoft Excel、逗号分隔值、制表符分隔值等）、Microsoft PowerPoint 或其他特殊演示文件、数据库文件及音频/视频文件。应提供一张带有 Bates 编号的隔页纸图像，注明原生文件的存在，并将原生文件的路径作为 .dat 文件中的一个字段。所提供的原生文件应以与该文件隔页纸相对应的 Bates 编号命名。原生文件应归入按递增方式命名的“NATIVE”目录中，并与图像目录分开。\n\ne. 去重。对于存在完全重复件的每份电子文档，仅提供一份副本。对于电子邮件，根据由 BCC、Body、CC、From、IntMsgID、To 和 Attach 属性生成的 MD5 哈希值合并重复件。对于电子邮件附件和独立电子文件，根据整个文件的 MD5 哈希值合并重复件。\n\nf. 元数据。以符合 Concordance 要求的加载文件（.dat）形式提供每份文档的提取元数据。.DAT 文件的第一行必须为标识字段名称的标题行。.DAT 文件必须使用以下 Concordance 默认分隔符：逗号 , ASCII 字符（020）引号 þ ASCII 字符（254）\n\n日期字段应以如下格式提供：mm/dd/yyyy。日期和时间字段必须为两个单独字段。以下为所需元数据：\n\n案件 22-50073 文档 1592 提交 03/24/23 录入 03/24/23 10:57:37 第 806 页，共 1063 页\n\n字段名称　示例数据　说明\n\nFIRSTBATES　EDC0000001　原生文件文档/电子邮件的第一个 Bates 编号\n\nLASTBATES　EDC0000001　原生文件文档/电子邮件的最后一个 Bates 编号\n\nLASTBATES 字段应就单页文档填写\n\nATTACHRANGE　EDC0000001 - EDC0000015　母文档第一页的 Bates 编号至最后一份“子”附件文档最后一页的 Bates 编号\n\nBEGATTACH　EDC0000001　附件范围的第一个 Bates 编号\n\nENDATTACH　EDC0000015　附件范围的最后一个 Bates 编号\n\nCUSTODIAN　Smith, John　电子邮件：该电子邮件所在的邮箱\n原生文件：该文档源自其文件的个人或部门名称\n\nFROM　John Smith　电子邮件：发件人\n原生文件：文档作者\n多个条目之间应使用分号分隔\n\nTO　Coffman, Janice; LeeW [mailto:LeeW@MSN.com]　收件人\n多个条目之间应使用分号分隔\n\nCC　Frank Thompson [mailto:frank_Thompson@cdt.com]　抄送收件人\n多个条目之间应使用分号分隔\n\nBCC　John Cain　密送收件人\n多个条目之间应使用分号分隔\n\nSUBJECT　Board Meeting Minutes　电子邮件：电子邮件的主题行 原生文件：文档标题（如有）\n\nFILE_NAME　BoardMeetingMinutes.docx　原生文件：原始原生文件的名称，包括扩展名\n\nDATE_SENT　10/12/2010　电子邮件：电子邮件发送日期\n原生文件：（空）\n\nTIME_SENT/TIME_ZONE　07:05 PM GMT　电子邮件：电子邮件发送时间/电子邮件标准化所采用的时区\n\nTIME_ZONE　GMT　在转换过程中电子邮件被标准化所采用的时区。\n\nLINK　EDC0000001.msg　指向电子邮件或原生文件文档的超链接\n链接文件必须按照 FIRSTBATES 编号命名\n\nFILE_EXTEN　MSG　代表电子邮件或文件的文件类型扩展名\n\nAUTHOR　John Smith　电子邮件：（空）\n原生文件：文档作者\n\nDATE_CREATED　10/10/2010　电子邮件：（空）\n原生文件：文档创建日期\n\n案件 22-50073 文档 1592 提交 03/24/23 录入 03/24/23 10:57:37 第 807 页，共 1063 页\n\nTIME_CREATED　10:25 AM　电子邮件：（空）\n原生文件：文档创建时间\n该数据必须为单独字段，不得与 DATE_CREATED 字段合并\n\nDATE_MOD　10/12/2010　电子邮件：（空）\n原生文件：文档最后修改日期\n\nTIME_MOD　07:00 PM　电子邮件：（空）\n原生文件：文档最后修改时间\n该数据必须为单独字段，不得与 DATE_MOD 字段合并\n\nDATE_ACCESSD　10/12/2010　电子邮件：（空）\n原生文件：文档最后访问日期\n\nTIME_ACCESSD　07:00 PM　电子邮件：（空）\n原生文件：文档最后访问时间\n该数据必须为单独字段，不得与 DATE_ACCESSD 字段合并\n\nFILE_SIZE　5,952　原生文件文档/电子邮件的大小，以 KB 计\n\nPGCOUNT　1　原生文件文档/电子邮件的页数\n\nPATH　电子邮件：（空）\nAgenda.doc　原生文件：储存原生文件文档的路径，包括原始文件名。\n\nINTFILEPATH　Personal Folders\\Deleted Items\\Board Meeting Minutes.msg　电子邮件：电子邮件的原始位置，包括原始文件名。\n原生文件：（空）\n\nINTMSGID　<000805c2c71b\\$75977050\\$cb8306d1@MSN>　电子邮件：唯一邮件 ID 原生文件：（空）\n\nMD5HASH　d131dd02c5e6eec4693d9a0698aff95c2fcab58712467eab4004583eb8fb7f89　文档的 MD5 哈希值。\n\nOCRPATH　TEXT/001/EDC0000001.txt　原生文件提取文本的路径\n\n3. 每一项请求均独立运作并应被独立解释，除非另有说明，任何请求均不限制任何其他请求的范围。\n\n4. 所有文档应按其在日常业务过程中保存的方式提供，或者应加以组织和标注，以对应本请求中的类别。\n\n5. 本文件所载的每一项请求均延及以下所有文档：(a) 由您占有、保管或控制的文档；或 (b) 由任何代表您行事之人占有、保管或控制的文档，\n\n案件 22-50073 文档 1592 提交 03/24/23 录入 03/24/23 10:57:37 第 808 页，共 1063 页\n\n包括您的律师或其他代表及顾问。每份文档均应完整提供。\n\n6. 如要求您提供已不再由您占有、保管或控制的文档，则您的答复必须：(a) 详细说明该文档的性质及内容；(b) 指明编制或撰写该文档的人员（以及如适用，接收该文档的人员）；(c) 指明该文档编制或创建的日期；(d) 说明该文档是否：(i) 缺失或遗失，(ii) 已被销毁，(iii) 已自愿或非自愿地转让给他人，或 (iv) 已以其他方式处置；(e) 说明该等处置的原因以及相关事实和情况；(f) 指明授权进行该等处置的人员；(g) 指明该等处置的日期或大致日期；(h) 说明该文档最近一次由您占有、保管或控制的时间；以及 (i) 指明目前占有、保管或控制该文档的人员（如有）。\n\n7. 如要求您提供已被销毁的文档，则除前述指示所要求的信息外，您的答复还必须说明：(a) 销毁该文档的原因；(b) 销毁该文档的人员身份；以及 (c) 指示销毁该文档的人员身份。\n\n8. 如您主张所要求的文档享有特权或属于律师工作成果，则您的答复必须：(a) 说明：(i) 足以支持您关于该文档享有特权之主张的文档描述，(ii) 文档标题，(iii) 文档日期，(iv) 文档作者，(v) 文档收件人，(vi) 收到或看过该文档原件、任何草稿、副本或复制件的每一人员身份，(vii) 该文档本身或该文档所载或所提及的任何信息是否由任何其他人员占有、保管或控制；如是，则说明该等人员的身份，以及说明该等信息如何进入其占有状态的陈述，(viii) 据以扣留该文档的特权主张，以及 (ix) 您将依赖以支持该等特权主张的所有情形；以及 (b) 就根据 D. Conn. L. Civ. R. 26(e) 因主张特权而扣留的每份文档，制作一份特权日志，其中包含本指示第 (a) 部分所要求的全部信息。对于文档请求中未主张特权或工作成果保护的任何部分，应完整提供回应性文档。\n\n案件 22-50073 文档 1592 提交 03/24/23 录入 03/24/23 10:57:37 第 809 页，共 1063 页\n\n9. 如原本具有回应性的文档的一部分包含受特权主张保护的信息，则仅应按照上述指示从该文档中删除或遮盖受特权主张保护的部分，其余部分应予提供。\n\n10. 请求具有持续性。特此指示您：(a) 一旦知悉先前答复不完整或不正确，应立即补充或更正任何后来发现不完整或不正确的答复；以及 (b) 提供根据下列规定所要求的任何额外文档\n\n11. 如文档为英语以外的语言，您应提供该文档。如文档为英语以外的语言，且存在英文译本，您应同时提供两份文档。\n\n12. 对实体的一切提及均包括其所有关联方。\n\n13. 对个人姓名的一切提及均包括所有替代姓名、别名或昵称。\n\n案件 22-50073 文档 1592 提交 03/24/23 录入 03/24/23 10:57:37 第 810 页，共 1063 页\n\n14. 除非另有明确说明，文档请求所涵盖的期间为自 February 5, 2012 起至文档请求答复到期之日止。\nII. 解释规则\n\n15. (a) 任何单数名词的使用应被解释为包括复数，反之亦然；以及 (b) 任何时态动词的使用应被解释为使用该动词的所有其他时态。\n\n16. (a) “和”与“或”应在必要时被解释为连词关系或选择关系，以使本应被解释为不在任何请求范围内的所有答复均纳入该请求范围；以及 (b) “每一”与“任何”应被视为包括并涵盖“每个”与“所有”二词。\nIII. 定义\n\n经 D. Conn. Bankr. L.R. 2004-1(a) 纳入的 D. Conn. L. Civ. R. 26(c) 所提供的定义，以及 D. Conn. L. Civ. R. 26(d) 所提供的解释规则，适用于文档请求。此外，本文件文档请求中使用的下列术语具有以下含义：\n\n1. “您”或“您的”或“您本人”系指 Metropolitan Commercial Bank 和/或 Metropolitan Bank Holding Corp.\n\n2. “债务人”系指 Ho Wan Kwok（又名 Miles Kwok、Miles Guo、Guo Wengui、Guo Haoyun、郭文贵或任何其他别名），以及其雇员、代理人、律师、顾问或任何代表其行事之人。\n\n案件 22-50073 文档 1592 提交 03/24/23 录入 03/24/23 10:57:37 第 811 页，共 1063 页\n\n3. “债务人的儿子”系指 Qiang Guo（又名 Mileson Kwok、郭强或任何其他别名），以及其雇员、代理人、律师、顾问或任何代表其行事之人。\n\n4. “债务人的女儿”系指 Mei Guo（郭美，亦称 Mei Gui 或任何其他别名），连同其雇员、代理人、律师、顾问或任何代表其行事之人。\n\n5. “债务人的所谓妻子”系指 Hing Chi Ngok（岳庆芝，亦称 Hing Chi Ng、Yue Qingzhi 或任何其他别名），连同其雇员、代理人、律师、顾问或任何代表其行事之人。\n\n6. “债务人的家庭成员”单独及共同系指债务人、债务人的儿子、债务人的女儿及债务人的所谓妻子，以及与债务人存在任何其他亲属关系之人。\n\n7. “2004 规则调查对象”单独及共同系指债务人、债务人的家庭成员、ACA Capital Group Limited、Himalaya International Financial Group Ltd.、Himalaya International Clearing Ltd.、Himalaya International Payments Ltd.、Himalaya International Reserves Ltd.、Jesse Brown、William Je、William Je、Eastern Profit Corporation Limited、HK International Funds Investments (USA) Limited LLC、Bravo Luck Limited、Golden Spring (New York) Ltd.、Lamp Capital LLC、Greenwich Land LLC、Qu Guo Jiao、Daniel Thomas Podhaskie、Yvette Wang（亦称 Yanping Wang、Yan Ping Wang）、Ace Decade Holdings Limited、Dawn State Limited、Rule of Law Society IV Inc.、Rule of Law Foundation III, Inc.、Rule of Law Foundation IV, Inc.、Rule of Law Fund、Rule of Law Society、GTV Media Group, Inc.、Voice of Guo Media, Inc.、Saraca Media Group Inc.、Genever Holdings Corporation、Genever Holdings LLC、Gnews Media Group Inc.、G Fashion LLC、Gmusic LLC、Gnews LLC、Geducation、GFNY, Inc.、G-Club Investments Limited、G Club Operations LLC、G Club US Operations Inc.、G Club US Operations LLC、G Live, LLC、Gbroadcast, LLC、Gposts LLC、HCHK Property\n案号 22-50073 文书 1592 于 03/24/23 提交 于 03/24/23 10:57:37 登记 第 812 页，共 1063 页\n\nManagement, Inc.、HCHK Technologies, Inc.、FMV Ltd./Freedom Media Venture Ltd.、Roscalitar 2、Himalaya New World Inc.、US Himalaya Capital Inc.、Hudson Diamond Holding, Inc.、Hudson Diamond Holding LLC、Hudson Diamond NY LLC、Infinity Treasury Management Inc.、Lexington Property and Staffing, Inc.、AI Group Holdings Inc.、Hamilton Capital Holdings Inc.、Booming Sail New York LLC、Himalaya Ventures LLC、Himalaya Ventures LLC、Himalaya Investment LLC、New York MOS Himalaya LLC、MOS Himalaya LLC、Crane Advisory Group、Maywind Trading LLC、Gettr USA, Inc.、Han Chunguang、Bingshang Jiao、Karin Maistrello、Mary Jiang、Jiaming Liu 及 Wencong Wang。\n\n8. “包括”或其任何变体，系指“包括但不限于”。\n\n9. “及”和“或”系指“及/或”，并应为最大限度扩大其范围而作连言及选言解释。\n\n10. “任何”和“全部”及“每一”系指“每一及全部”。\n\n11. “每一”和“每个”系指“每一及全部”。\n\n12. “第三方”系指除贵方自身以外的个人或实体。\n\n13. “转让”应具有《破产法》section 101(54) 所赋予的含义。\n\n14. “文件”系指属于 Fed. R. Civ. P. 34 范围内的任何信息或物品，并包括但不限于每一及全部任何种类、类型、性质或描述的书面、录制或图形材料，该等材料现由或曾由贵方占有、保管或控制，包括电子邮件的所有纸质及电子副本、以电子形式保存的计算机文件、通信函件、备忘录、磁带、速记或手写笔记、任何种类的书面表格、图表、蓝图、绘图、草图、曲线图、计划、文章、规格说明、日记、信函、\n案号 22-50073 文书 1592 于 03/24/23 提交 于 03/24/23 10:57:37 登记 第 813 页，共 1063 页\n\n电报、照片、会议记录、合同、协议、调查资料、计算机打印件、任何种类的数据汇编、电传、传真、电子邮件、短信、即时消息、语音留言、发票、订购单、支票、汇票、对账单、贷项通知单、报告、头寸报告、摘要、索引、账簿、总账、笔记本、清单、透明胶片、录音、目录、广告、宣传材料、影片、录像带、录音带、CD、计算机磁盘、宣传册、小册子、穿孔卡、工时单、Tweets、社交媒体帖子或任何其他种类的书面或录制材料，以及其所有元数据，无论以何种方式存储（无论以有形或电子形式）、记录、制作或复制；还包括但不限于前述任何材料的草稿或副本，如其中含有原始文件中未见的任何种类笔记、评论或标记，或在其他方面与原始文件不相同。\n\n15. “个人”系指个人、公司、独资企业、合伙企业、协会或任何其他实体。“个人”还包括任何代理人、代表或专家，包括但不限于律师或财务顾问。\n\n16. “实体”系指任何自然人、公司、合伙企业、子公司、独资企业、商号、董事会、合资企业、协会、机构、主管机关、委员会或其他商业实体或法人，以及任何关联方、代理人、母公司，包括但不限于律师、财务顾问或任何其他代表。\n\n17. “关于”系指涉及、描述、构成、提及、与之相关、支持、有利于、反对、加强、削弱、位于其中、结合其予以考虑、与其有关、证明、表明、报告、记录、暗指、回应、与之相连、评论、就其而言、有关、与之相关、讨论、显示、描述、反映、分析、构成及属于。\n案号 22-50073 文书 1592 于 03/24/23 提交 于 03/24/23 10:57:37 登记 第 814 页，共 1063 页\n\n18. 就任何特定事项而言，“与……有关”“与……有关联”或“相关”，系指但不限于构成、包含、涉及、含有、体现、反映、识别、陈述、直接或间接提及该特定事项，或以任何方式与所识别的特定事项相关的任何文件。\n\n19. “通信”系指以最广义且不限于任何形式传递信息或知识（以事实、观点、询问或其他形式）。通信还指所有交谈、协议、询问或答复，无论是当面、通过电话、以书面形式或借助电子传输设备，并包括但不限于所有函件、电子邮件、录音、传送单、备忘录、电话通信、语音留言、电报、电传传真、电传复印件、电传、即时消息、聊天记录、短信、发布至留言板或群聊的帖子、社交媒体帖子、tweets、上传至任何视频平台的视频、电话笔记或内部传送或与第三方传送的笔记。\n\n20. “资产”系指受占有、保管或控制的任何具有经济价值的项目。资产包括所有不动产和动产，包括但不限于房地产、土地、房屋、公寓、共有公寓、汽车、游艇、船舶、飞机、喷气式飞机、直升机、现金、银行账户、加密货币、证券、应收账款、存货及其他有形和无形财产。\n\nIV. 应提交的文件\n\n1. 与任何由任何 2004 规则调查对象持有、控制、代为持有或以其他方式与其相关的账户有关的全部文件，包括任何及全部账户对账单、授权书、委托书、信托文件、指示或表格、已注销支票副本、函件以及电汇和相关函件及指示。\n案号 22-50073 文书 1592 于 03/24/23 提交 于 03/24/23 10:57:37 登记 第 815 页，共 1063 页\n\n2. 与任何属于任何 2004 规则调查对象、由其持有、控制、代为持有或以其他方式与其相关的资金、证券、财产或资产有关的全部文件，包括任何及全部账户对账单、授权书、委托书、信托文件、指示或表格、已注销支票副本、函件以及电汇和相关函件及指示。\n\n3. 与同任何 2004 规则调查对象进行的任何商业、贸易或金融交易有关的全部文件，包括但不限于任何贷款、信贷额度、寄托、存款、掉期、证券交易、抵押贷款或 ISDA，包括任何及全部账户对账单、授权书、委托书、信托文件、指示或表格、已注销支票副本、函件以及电汇和相关函件及指示。\n\n4. 与 2004 规则调查对象有关的任何电汇活动有关的全部文件，不论是否存在任何账户，包括但不限于所有电汇收据、账号、余额、授权书、与转账当事人有关的身份识别信息、函件、指示或其他记录。\n\n5. 与贵方和 2004 规则调查对象之间任何函件往来及通信有关的全部文件。\n\n6. 与任何 2004 规则调查对象开立账户、该账户授权使用人及该账户维护有关的任何账户的全部文件。\n\n7. 与任何 2004 规则调查对象有关的任何反洗钱、了解你的客户或其他合规活动有关的全部文件，包括但不限于任何 2004 规则调查对象提供的信息，或贵方获悉的信息。\n\n8. 与来自任何国家的任何监管机构的通信有关的全部文件，包括但不限于英格兰银行、美国联邦储备系统、S.E.C.、CFTC、FINRA、中国证券监督管理委员会、中国人民银行、香港证券及期货事务监察委员会及香港金融管理局，并涉及任何 2004 规则调查对象的文件。\n\n附件 C-45\n\nB2540（表格 2540——Rule 2004 审查传票）（12/15）案号 22-50073 文书 1592 于 03/24/23 提交 于 03/24/23 10:57:37 登记 第 818 页，共\n\n美国破产法院\n\nDistrict of Connecticut（康涅狄格区）\n\n关于 HO WAN KWOK（郭文贵）等人，\n\n1 案号 22-50073 (JAM) 债务人 第 11 章\n\n（合并管理）\n\nRule 2004 审查传票\n\n致：Open Bank\n\n（传票所指向人员的姓名）\n\n证言：兹命令贵方于下列规定的时间、日期及地点出席，根据《联邦破产程序规则》Rule 2004 接受审查并作证。随附准许该审查的法院命令副本。\n\n地点　日期和时间\n\nNeubert, Pepe & Monteith, P.C.\n195 Church Street, Floor 13　[TBD]\nNew Haven, Connecticut 06510\n\n审查将以如下方式记录：法庭记录员/速记员\n\n提交：贵方或贵方代表还必须携带下列文件、电子存储信息或物品参加审查，并必须允许对该等材料进行检查、复制、测试或抽样：\n\n见随附的文件提交请求。\n\nFed. R. Civ. P. 45 的下列规定，经由 Fed. R. Bankr. P. 9016 适用于破产案件，现附后——关于履行地点的 Rule 45(c)；关于保护作为传票对象之人员的 Rule 45(d)；以及关于贵方回应本传票的义务及未作回应的潜在后果的 Rule 45(e) 和 45(g)。\n\n日期：March , 2023\n\n法院书记员\n\n或\n\n书记员或副书记员签名　律师签名\n\n签发或请求本传票的代表第 11 章受托人 Luc A. Despins 的律师姓名、地址、电子邮件地址及电话号码如下：\n\nDouglas S. Skalka, Esq.; Neubert, Pepe & Monteith, P.C.; 195 Church Street, New Haven, Connecticut 06510 dskalka@npmlaw.com; (203) 821-2000\n\n向签发或请求本传票之人的通知\n\n如本传票命令在审判前提交文件、电子存储信息或有形物品，或检查场所，则必须在向本传票所指向之人送达前，向每一方当事人送达通知及本传票副本。Fed. R. Civ. P. 45(a)(4)。\n\n软件版权所有 (c) 1996-2022 Best Case, LLC（百事凯斯有限责任公司）- www.bestcase.com Best Case Bankruptcy 1 本第11章案件中的债务人为 Ho Wan Kwok（郭文贵，亦称 Guo Wengui、Miles Guo 和 Miles Kwok，以及众多其他别名）（税务识别号码后四位：9595）、Genever Holdings LLC（税务识别号码后四位：8202）以及 Genever Holdings Corporation。受托人、Genever Holdings LLC 和 Genever Holdings Corporation 的邮寄地址为 Paul Hastings LLP（普衡律师事务所）, 200 Park Avenue, New York, NY 10166，转交 Luc A. Despins，作为 Ho Wan Kwok 遗产的受托人（仅为通知和通信之目的）。\n\n送达证明\n\n（除非 Fed. R. Civ. P. 45 要求，否则本节不应向法院提交。）\n\n本人于（日期）收到向以下人士（个人姓名及职务，如有）发出的本传票：。\n\n本人通过以下方式向该具名人士交付副本以送达本传票：\n\n于（日期）；或\n\n本人未执行本传票即予退回，原因如下：\n\n除非本传票系代表美国或其官员或代理人发出，本人亦已向证人支付出席一天的费用及法律允许的里程费，金额为 \\$ 。\n\n本人的差旅费用为 \\$，服务费用为 \\$，合计 \\$ 。\n\n本人在伪证处罚的惩罚下声明，上述信息真实且正确。\n\n日期：\n\n送达人签名\n\n正楷姓名及职务\n\n送达人地址\n\n关于尝试送达等事项的补充信息：\n\n《联邦民事诉讼规则》第45(c)、(d)、(e)及(g)条（2013年12月1日生效）（依《联邦破产程序规则》第9016条适用于破产案件）\n\n(c) 履行地点。\n\n(1) 审判、听证或证言录取。传票仅可按下列方式命令某人出席审判、听证或证言录取：\n\n(A) 在该人居住、受雇或经常亲自从事营业之地点100英里范围内；或\n\n(B) 在该人居住、受雇或经常亲自从事营业所在州内，如该人\n\n(i) 为当事人或当事人的高级职员；或\n\n(ii) 被命令出席审判且不会产生重大费用。\n\n(2) 其他证据开示。传票可以命令：\n\n(A) 在该人居住、受雇或经常亲自从事营业之地点100英里范围内的地点提交文件、电子存储信息或物品；以及\n\n(B) 在拟检查的场所检查场所。\n\n(d) 对受传票约束之人的保护；执行。\n\n(1) 避免不当负担或费用；制裁。负责发出和送达传票的当事人或律师必须采取合理措施，以避免对受传票约束之人施加不当负担或费用。要求履行的地区法院必须执行该义务，并对未遵守者的当事人或律师施加适当制裁，其中可包括收入损失和合理的律师费。\n\n(2) 命令提交材料或允许检查。\n\n(A) 无须出庭。被命令提交文件、电子存储信息或有形物品，或允许检查场所的人，除非亦被命令出席证言录取、听证或审判，否则无须亲自到提交或检查地点出席。\n\n(B) 异议。被命令提交文件或有形物品，或允许检查的人，可以就检查、复制、测试或抽样全部或部分材料，或检查场所，或以所要求的一种或多种形式提交电子存储信息，向传票中指定的当事人或律师送达书面异议。异议必须在规定履行时间或传票送达后14日两者中较早者之前送达。如提出异议，则适用下列规则：\n\n(i) 经通知被命令之人，送达方可随时向要求履行的地区法院提出动议，请求作出强制提交或检查的命令。\n\n(ii) 仅可按命令所指示的方式要求实施该等行为，且该命令必须保护并非当事人或当事人高级职员的人免于因履行而产生的重大费用。\n\n(3) 撤销或修改传票。\n\n(A) 必须撤销或修改的情形。经及时提出动议，要求履行的地区法院必须撤销或修改具有下列情形的传票：\n\n(i) 未给予合理的履行时间；\n\n(ii) 要求某人在第45(c)条规定的地域限制以外履行；\n\n(iii) 要求披露享有特权或受其他保护的事项，而不存在适用的例外或豁免；或\n\n(iv) 对某人施加不当负担。\n\n(B) 可撤销或修改的情形。为保护受传票约束或受其影响之人，要求履行的地区法院可依动议撤销或修改要求下列事项的传票：\n\n(i) 披露商业秘密或其他保密的研究、开发或商业信息；或\n\n(ii) 披露未经聘用的专家的意见或信息，该等意见或信息并非描述争议中的特定事件，且源自未由当事人请求进行的该专家研究。\n\n(C) 以规定条件作为替代方案。在第45(d)(3)(B)条所述情形下，如送达方：\n\n(i) 证明其对证言或材料具有重大需要，且不承受不当困难即无法通过其他方式满足该需要；并且\n\n(ii) 确保被传唤之人将获得合理补偿，\n\n法院可不撤销或修改传票，而是命令在规定条件下出席或提交。\n\n(e) 对传票作出回应的义务。\n\n(1) 提交文件或电子存储信息。下列程序适用于提交文件或电子存储信息：\n\n(A) 文件。回应提交文件传票的人必须按照文件在通常业务过程中保存的方式提交，或必须将其整理并标注，以对应请求中的类别。\n\n(B) 未规定电子存储信息的提交形式。如传票未规定提交电子存储信息的形式，回应人必须以其通常保存的一种或多种形式，或以合理可用的一种或多种形式提交。\n\n(C) 电子存储信息仅以一种形式提交。回应人无须以一种以上形式提交同一电子存储信息。\n\n(D) 无法合理获取的电子存储信息。回应人无须就其确定因不当负担或费用而无法合理获取的来源中的电子存储信息提供证据开示。就强制证据开示或保护令提出动议时，回应人必须证明该信息因不当负担或费用而无法合理获取。如作出该证明，若请求方在考虑第26(b)(2)(C)条限制的情况下证明有正当理由，法院仍可命令从该等来源进行证据开示。法院可规定该证据开示的条件。\n\n(2) 主张特权或保护。\n\n(A) 扣留的信息。以该信息享有特权或作为审判准备材料受到保护为由扣留传票所要求信息的人必须：(i) 明确提出该主张；并且\n\n(ii) 以一种在不披露本身享有特权或受保护信息的情况下，能够使当事人评估该主张的方式，说明所扣留文件、通信或有形物品的性质。\n\n(B) 已提交的信息。如为回应传票而提交的信息受特权主张或作为审判准备材料受保护的主张约束，提出该主张的人可以将该主张及其依据通知收到该信息的任何当事人。收到通知后，当事人必须立即返还、隔离或销毁特定信息及其所持有的任何副本；在该主张获得解决前不得使用或披露该信息；如该当事人在收到通知前已披露该信息，必须采取合理措施取回该信息；并可立即将该信息密封提交给要求履行的地区法院，以裁定该主张。提交该信息的人必须保存该信息，直至该主张获得解决。\n\n(g) 藐视法庭。要求履行的地区法院，以及在动议被移送后发出传票的法院，可以认定已被送达而无充分理由不遵守传票或与之相关命令的人构成藐视法庭。\n\n欲查阅传票材料，见 Fed.R.Civ.P.45(a) 委员会说明（2013）\n\n……\n\n文件提交请求\n\n一、指示\n\n1. 除非另有说明，下列文件请求（统称“请求”，每一项称“一项请求”）必须分别且具体地作出回应。除非你方基于善意提出异议，否则必须完整答复每项请求；如提出异议，则应如下文所述详细说明你方异议的理由。如异议仅涉及某项请求的一部分，或其中包含的某一词语、短语或条款，你方仅须陈述对该部分的异议，并对请求的其余部分作出回应。\n\n2. 电子存储信息必须按照下列指示提交：\n\na. 图像。黑白图像必须为300 DPI Group IV 单页 TIFF 文件。彩色图像必须以 JPEG 格式提交。文件名称不得包含嵌入空格或特殊字符（包括逗号）。文件夹名称不得包含嵌入空格或特殊字符（包括逗号）。所有 TIFF 图像文件必须具有唯一文件名，即 Bates 编号。每一图像的右下角必须标注连续的 Bates 编号。每个文件夹中的 TIFF 文件数量不应超过1000个文件。Excel 电子表格应具有以该文件 Bates 编号命名的占位图像。\n\nb. 图像加载文件\n\na. Concordance® 数据文件。数据文件（.DAT）包含将被加载至 Concordance® 数据库的所有字段信息。.DAT 文件的第一行必须为标明字段名称的标题行。.DAT 文件必须使用以下 Concordance® 默认分隔符：逗号 ASCII 字符（020）引号 þ ASCII 字符（254）。日期字段应以如下格式提供：mm/dd/yyyy。日期和时间字段必须为两个单独字段。如文件包括已成像的电子邮件及附件，必须包括附件字段，以保留电子邮件与其附件之间的父项/子项关系。必须包括 OCRPATH 字段，以提供已提交存储介质上提取文本文件的文件路径和名称。文本文件必须以 FIRSTBATES 命名。不得在 .DAT 文件中包含文本。对于含有原生文件的文件，必须包括 LINK 字段，以提供原生文件的文件路径和名称。原生文件必须以 FIRSTBATES 命名。\n\n- b. Concordance Image® 或 Opticon 交叉引用文件。图像交叉引用文件（.LOG 或 .OPT）将图像链接至数据库记录。该文件应为逗号分隔文件，每行由七个字段组成，且数据库中的每幅图像均应在交叉引用文件中占一行，格式如下：ImageID,VolumeLabel,ImageFilePath,DocumentBreak,FolderBreak,Box Break,PageCoun。\n\n- c. 文档文本。文本必须作为单独的文本文件提供，不得作为 .DAT 文件中的字段提供。应在 .DAT 文件中包含文本文件的完整路径（OCRPATH）。建议提供以 FIRSTBATES/Image Key 命名的文档级 ANSI 文本文件。提取的文本文件必须置于单独的文件夹中，每个文件夹中的文本文件数量不得超过 1,000 个。文件夹名称中不得含有特殊字符（包括逗号）。文本文件必须按文档级别提供。\n\n- d. 特定文件类型的原生格式提供。为充分理解其内容和含义而合理需要以原生格式查看的文件类型，必须以原生格式提供。这些文件包括但不限于电子表格、类电子表格文件（Microsoft Excel、逗号分隔值、制表符分隔值等）、Microsoft PowerPoint 或其他特殊演示文件、数据库文件以及音频/视频文件。应提供一张带有 Bates 编号的提示页图像，注明存在原生文件，并将原生文件的路径作为 .dat 文件中的一个字段。提供的原生文件应以与该文件提示页相对应的 Bates 编号命名。原生文件应归入依次命名的“NATIVE”目录中，并与图像目录分开。\n\n- e. 去重。对于存在完全重复件的每一电子文档，仅提供一份副本。对于电子邮件，应根据由 BCC、Body、CC、From、IntMsgID、To 和 Attach 属性生成的 MD5 哈希值合并重复件。对于电子邮件附件和独立电子文件，应根据整个文件的 MD5 哈希值合并重复件。\n\n- f. 元数据。应以符合 Concordance 的加载文件（.dat）形式提供每份文档的提取元数据。.DAT 文件的第一行必须为标识字段名称的标题行。.DAT 文件必须使用以下 Concordance 默认分隔符：逗号 , ASCII 字符（020）引号 þ ASCII 字符（254）\n\n日期字段应采用以下格式提供：mm/dd/yyyy。日期和时间字段必须为两个独立字段。所需元数据如下：\n案号 22-50073 文书 1592 提交日期 03/24/23 录入日期 03/24/23 10:57:37 第 823 页，共 1063 页\n\n字段名称　示例数据　说明\n\nFIRSTBATES　EDC0000001　原生文件文档/电子邮件的第一个 Bates 编号\n\nLASTBATES　EDC0000001　原生文件文档/电子邮件的最后一个 Bates 编号\n\nLASTBATES 字段应针对单页予以填充\n\nATTACHRANGE　EDC0000001\n-　父文档第一页的 Bates 编号至最后一个附件“子”文档最后一页的 Bates 编号\nEDC0000015\n\nBEGATTACH　EDC0000001　附件范围的第一个 Bates 编号\n\nENDATTACH　EDC0000015　附件范围的最后一个 Bates 编号\n\nCUSTODIAN　Smith, John　电子邮件：电子邮件所在的邮箱\n原生文件：文档来源的个人或部门名称\n\nFROM　John Smith　电子邮件：发件人\n原生文件：文档作者\n\n多个条目之间应使用分号分隔\n\nTO　Coffman, Janice; LeeW　收件人\n[mailto:LeeW@MSN.com]　多个条目之间应使用分号分隔\n\nCC　Frank Thompson [mailto:　抄送收件人\nfrank_Thompson@cdt.com]　多个条目之间应使用分号分隔\n\nBCC　John Cain　密送收件人\n多个条目之间应使用分号分隔\n\nSUBJECT　Board Meeting Minutes　电子邮件：电子邮件主题行 原生文件：文档标题（如有）\n\nFILE_NAME　BoardMeetingMinutes.docx　原生文件：原始原生文件的名称，包括扩展名\n\nDATE_SENT　10/12/2010　电子邮件：电子邮件发送日期\n原生文件：（空）\n\nTIME_SENT/\nTIME_ZONE　07:05 PM GMT　电子邮件：电子邮件发送时间/电子邮件统一标准化时所采用的时区\n\nTIME_ZONE　GMT　转换过程中电子邮件被标准化所采用的时区。\n\nLINK　EDC0000001.msg　指向电子邮件或原生文件文档的超链接\n\n链接文件必须按 FIRSTBATES 编号命名\n\nFILE_EXTEN　MSG　代表电子邮件或原生文件的文件类型扩展名\n\nAUTHOR　John Smith　电子邮件：（空）\n原生文件：文档作者\n\nDATE_CREATED　10/10/2010　电子邮件：（空）\n原生文件：文档创建日期\n案号 22-50073 文书 1592 提交日期 03/24/23 录入日期 03/24/23 10:57:37 第 824 页，共 1063 页\n\nTIME_CREATED　10:25 AM　电子邮件：（空）\n\n原生文件：文档创建时间\n\n该数据必须为独立字段，不得与 DATE_CREATED 字段合并\n\nDATE_MOD　10/12/2010　电子邮件：（空）\n原生文件：文档最后修改日期\n\nTIME_MOD　07:00 PM　电子邮件：（空）\n原生文件：文档最后修改时间\n\n该数据必须为独立字段，不得与 DATE_MOD 字段合并\n\nDATE_ACCESSD　10/12/2010　电子邮件：（空）\n原生文件：文档最后访问日期\n\nTIME_ACCESSD　07:00 PM　电子邮件：（空）\n原生文件：文档最后访问时间\n\n该数据必须为独立字段，不得与 DATE_ACCESSD 字段合并\n\nFILE_SIZE　5,952　原生文件文档/电子邮件的大小，以 KB 计\n\nPGCOUNT　1　原生文件文档/电子邮件的页数\n\nPATH　电子邮件：（空）\nAgenda.doc　原生文件：存储原生文件文档的路径，包括原始文件名。\n\nINTFILEPATH　Personal Folders\\Deleted　电子邮件：电子邮件的原始位置，包括原始文件名。\nItems\\Board Meeting\nMinutes.msg　原生文件：（空）\n\nINTMSGID　<000805c2c71b\\$75977050\\$　电子邮件：唯一消息 ID 原生文件：（空）\ncb8306d1@MSN>\n\nMD5HASH　d131dd02c5e6eec4693d9a0　文档的 MD5 哈希值。\n698aff95c\n2fcab58712467eab4004583e\nb8fb7f89\n\nOCRPATH　TEXT/001/EDC0000001.txt　原生文件提取文本的路径\n\n3. 各项请求独立运行并应独立解释；除非另有说明，任何一项请求均不限制任何其他请求的范围。\n\n4. 所有文档均应按其在通常业务过程中保存的方式提供，或者应予以整理和标记，以对应本请求中的类别。\n\n5. 各项请求适用于所有文档：（a）由您占有、保管或控制的；或（b）由代表您行事的任何人占有、保管或控制的，\n案号 22-50073 文书 1592 提交日期 03/24/23 录入日期 03/24/23 10:57:37 第 825 页，共 1063 页\n\n包括您的律师或其他代表及顾问。每份文档均应完整提供。\n\n6. 如要求您提供一份已不再由您占有、保管或控制的文档，则您的答复必须：（a）详细说明该文档的性质及其内容；（b）指明编制或撰写该文档的人员（以及，如适用，向其发送该文档的人员）；（c）指明该文档编制或创建的日期；（d）说明该文档是否（i）遗失或丢失，（ii）已被销毁，（iii）已自愿或非自愿地转移给他人，或（iv）以其他方式被处置；（e）说明该等处置的原因以及相关事实和情形；（f）指明授权该等处置的人员；（g）指明该等处置的日期或大致日期；（h）说明该文档最近一次由您占有、保管或控制的时间；以及（i）指明目前占有、保管或控制该文档的人员（如有）。\n\n7. 如要求您提供一份已被销毁的文档，则除前述指示所要求的信息外，您的答复还必须说明：（a）该文档被销毁的原因；（b）销毁该文档的人员身份；以及（c）指示销毁该文档的人员身份。\n\n8. 如您主张某一被请求的文档享有特权或属于律师工作成果，则您的答复必须：（a）说明（i）足以支持您关于该文档享有特权之主张的文档描述，（ii）文档标题，（iii）文档日期，（iv）文档作者，（v）文档收件人，（vi）收到或阅览该文档原件或任何草稿、副本或复制件的每一人员身份，（vii）该文档本身或该文档所含或提及的任何信息是否由任何其他人员占有、保管或控制，如是，则说明该等人员的身份，以及说明该信息如何进入其占有范围的陈述，（viii）据以不提供该文档的特权主张，以及（ix）您将据以支持该等特权主张的所有情形；以及（b）根据 D. Conn. L. Civ. R. 26(e)，针对每一份基于特权主张而不予提供的文档，提供一份特权清单，其中载明本指示第（a）部分要求的全部信息。对于文档请求中未主张特权或工作成果的任何部分，应完整提供回应性文档。\n案号 22-50073 文书 1592 提交日期 03/24/23 录入日期 03/24/23 10:57:37 第 826 页，共 1063 页\n\n9. 如一份原本具有回应性的文档的一部分含有受特权主张约束的信息，则仅可依照上述指示从该文档中删除或遮盖受特权主张约束的部分，其余部分应予提供。\n\n10. 本请求具有持续性。现指示您：（a）在知悉先前答复不完整或不正确后，立即补充或更正其后获知为不完整或不正确的任何答复；以及（b）提供根据以下规定所要求的任何补充文档\n\n11. 如文档使用英语以外的语言，您应提供该文档。如文档使用英语以外的语言且存在英文译本，您应同时提供两份文档。\n\n12. 对实体的一切提及包括其所有关联方。\n\n13. 对个人姓名的一切提及包括所有其他姓名、别名或昵称。\n案号 22-50073 文书 1592 提交日期 03/24/23 录入日期 03/24/23 10:57:37 第 827 页，共 1063 页\n\n14. 除非另有明确说明，文档请求所涵盖的期间为自 February 5, 2012 起至文档请求答复到期之日止。\n\nII. 解释规则\n\n15. （a）任何单数名词的使用应解释为包括复数，反之亦然；以及（b）任何时态动词的使用应解释为在所有其他时态中使用该动词。\n\n16. （a）“and”和“or”应视需要解释为连词关系或选择关系，以使原本可能被解释为不在任何请求范围内的所有答复均纳入其范围；以及（b）“each”和“any”应视为包括并涵盖“every”和“all”二词。\n\nIII. 定义\n\n经 D. Conn. Bankr. L.R. 2004-1(a) 纳入的 D. Conn. L. Civ. R. 26(c) 所规定的定义及 D. Conn. L. Civ. R. 26(d) 所规定的解释规则，应适用于文档请求。此外，本文件请求中使用的下列术语具有以下含义：\n\n1. “您”或“您的”或“您本人”系指 Open Bank（Open Bank）。\n\n2. “债务人”系指 Ho Wan Kwok（郭文贵，亦称 Miles Kwok、Miles Guo、Guo Wengui、Guo Haoyun、郭文贵，或任何其他别名），连同其雇员、代理人、律师、顾问或任何代表其行事之人。\n\n3. “债务人之子”系指 Qiang Guo（郭强，亦称 Mileson Kwok、郭强，或任何其他别名），连同其雇员、代理人、律师、顾问或任何代表其行事之人。\n案号 22-50073 文书 1592 提交日期 03/24/23 录入日期 03/24/23 10:57:37 第 828 页，共 1063 页\n\n4. “债务人的女儿”系指 Mei Guo（郭美，亦名 Mei Gui，或任何其他别名），以及其雇员、代理人、律师、顾问或任何代表其行事之人。\n\n5. “债务人据称的妻子”系指 Hing Chi Ngok（岳庆芝，亦名 Hing Chi Ng、Yue Qingzhi，或任何其他别名），以及其雇员、代理人、律师、顾问或任何代表其行事之人。\n\n6. “债务人的家属”系指，个别及合称，债务人、债务人的儿子、债务人的女儿和债务人据称的妻子，以及与债务人具有任何其他亲属关系之人。\n\n7. “2004 取证对象”系指，个别及合称，债务人、债务人的家属、ACA Capital Group Limited（ACA 资本集团有限公司）、Himalaya International Financial Group Ltd.（喜马拉雅国际金融集团有限公司）、Himalaya International Clearing Ltd.（喜马拉雅国际清算有限公司）、Himalaya International Payments Ltd.（喜马拉雅国际支付有限公司）、Himalaya International Reserves Ltd.（喜马拉雅国际储备有限公司）、Jesse Brown、William Je、William Je、Eastern Profit Corporation Limited（东方盈利有限公司）、HK International Funds Investments (USA) Limited LLC（香港国际基金投资〈美国〉有限责任公司）、Bravo Luck Limited（鸿运有限公司）、Golden Spring (New York) Ltd.（金泉〈纽约〉有限公司）、Lamp Capital LLC（蓝普资本有限责任公司）、Greenwich Land LLC（格林威治土地有限责任公司）、Qu Guo Jiao、Daniel Thomas Podhaskie、Yvette Wang（王燕平，亦名 Yanping Wang、Yan Ping Wang）、Ace Decade Holdings Limited（艾斯十年控股有限公司）、Dawn State Limited（曙光州有限公司）、Rule of Law Society IV Inc.（法治协会 IV 公司）、Rule of Law Foundation III, Inc.（法治基金会 III 公司）、Rule of Law Foundation IV, Inc.（法治基金会 IV 公司）、Rule of Law Fund（法治基金）、Rule of Law Society（法治协会）、GTV Media Group, Inc.（GTV 媒体集团有限公司）、Voice of Guo Media, Inc.（郭之声媒体有限公司）、Saraca Media Group Inc.（萨拉卡媒体集团有限公司）、Genever Holdings Corporation（吉尼弗控股公司）、Genever Holdings LLC（吉尼弗控股有限责任公司）、Gnews Media Group Inc.（Gnews 媒体集团有限公司）、G Fashion LLC（G 时尚有限责任公司）、Gmusic LLC（G 音乐有限责任公司）、Gnews LLC（Gnews 有限责任公司）、Geducation（G 教育）、GFNY, Inc.（GFNY 公司）、G-Club Investments Limited（G-Club 投资有限公司）、G Club Operations LLC（G Club 运营有限责任公司）、G Club US Operations Inc.（G Club 美国运营公司）、G Club US Operations LLC（G Club 美国运营有限责任公司）、G Live, LLC（G Live 有限责任公司）、Gbroadcast, LLC（Gbroadcast 有限责任公司）、Gposts LLC（Gposts 有限责任公司）、HCHK Property Management, Inc.（HCHK 物业管理有限公司）、HCHK Technologies, Inc.（HCHK 科技有限公司）、FMV Ltd./Freedom Media Venture Ltd.（FMV 有限公司／自由媒体创投有限公司）、Roscalitar 2、Himalaya New World Inc.（喜马拉雅新世界公司）、US Himalaya Capital Inc.（美国喜马拉雅资本公司）、Hudson Diamond Holding, Inc.（哈德逊钻石控股公司）、Hudson\n\n案件 22-50073 文书 1592 提交日期 03/24/23 登记日期 03/24/23 10:57:37 第 829 页，共 1063 页\n\nDiamond Holding LLC（哈德逊钻石控股有限责任公司）、Hudson Diamond NY LLC（哈德逊钻石纽约有限责任公司）、Infinity Treasury Management Inc.（无限资金管理公司）、Lexington Property and Staffing, Inc.（列克星敦物业和人事公司）、AI Group Holdings Inc.（AI 集团控股公司）、Hamilton Capital Holdings Inc.（汉密尔顿资本控股公司）、Booming Sail New York LLC（兴帆纽约有限责任公司）、Himalaya Ventures LLC（喜马拉雅创投有限责任公司）、Himalaya Ventures LLC（喜马拉雅创投有限责任公司）、Himalaya Investment LLC（喜马拉雅投资有限责任公司）、New York MOS Himalaya LLC（纽约 MOS 喜马拉雅有限责任公司）、MOS Himalaya LLC（MOS 喜马拉雅有限责任公司）、Crane Advisory Group（克兰咨询集团）、Maywind Trading LLC（五月风贸易有限责任公司）、Gettr USA, Inc.（Gettr 美国公司）、Han Chunguang、Bingshang Jiao、Karin Maistrello、Mary Jiang、Jiaming Liu 和 Wencong Wang。\n\n8. “包括”或其任何变体，系指“包括但不限于”。\n\n9. “和”及“或”系指“和／或”，并应同时作连词性及选择性解释，以最大限度扩大其范围。\n\n10. “任何”及“所有”及“每一”系指“每一及全部”。\n\n11. “每一”及“每个”系指“每一及全部”。\n\n12. “第三方”系指除您本人以外的自然人或实体。\n\n13. “转让”应具有《破产法》section 101(54) 赋予该词的含义。\n\n14. “文件”系指属于 Fed. R. Civ. P. 34 范围内的任何信息或物品，并包括但不限于在您占有、保管或控制之下或曾在您占有、保管或控制之下的各种类别、类型、性质或描述的每一及全部书面、记录或图形资料，包括电子邮件的所有纸质和电子副本、以电子形式保存的计算机文件、信函、备忘录、磁带、速记或手写笔记、各种书面表格、图表、蓝图、绘图、草图、曲线图、计划、文章、规格说明书、日记、信件、电报、照片、会议记录、合同、协议、调查报告、计算机打印件、任何种类的数据汇编、电传、传真、电子邮件、短信、即时消息、语音\n\n案件 22-50073 文书 1592 提交日期 03/24/23 登记日期 03/24/23 10:57:37 第 830 页，共 1063 页\n\n信息、发票、订购单、支票、汇票、对账单、贷项通知单、报告、头寸报告、摘要、索引、账簿、分类账、笔记本、清单、透明胶片、录音、目录、广告、宣传材料、影片、录像带、录音带、CD、计算机磁盘、宣传册、小册子、穿孔卡、工时单、Tweets、社交媒体帖子，或任何其他种类的书面或记录资料，以及其所有元数据，无论以何种方式存储（无论为有形形式或电子形式）、记录、制作或复制；亦包括但不限于上述任何资料的草稿或副本，如其含有原始文件中未载的任何类型笔记、评论或标记，或在其他方面与原始文件不相同。\n\n15. “自然人”系指个人、公司、独资企业、合伙企业、协会或任何其他实体。“自然人”亦包括任何代理人、代表或专家，包括但不限于律师或财务顾问。\n\n16. “实体”系指任何自然人、公司、合伙企业、子公司、独资企业、商号、董事会、合资企业、协会、机构、主管机关、委员会或其他商业实体或法人，以及任何关联方、代理人、母公司，包括但不限于律师、财务顾问或任何其他代表。\n\n17. “关于”系指涉及、描述、构成、提及、与之有关、支持、赞成、反对、强化、削弱、位于其中、结合其予以考虑、对其有影响、证明、表明、就其报告、记录、暗指、答复、与之相连、评论、就其而言、关于、与之有关、讨论、显示、描述、反映、分析、构成以及为。\n\n18. 在提及任何特定事项时，“与……有关”、“涉及”或“相关”，系指但不限于构成、组成、涉及、包含、\n\n案件 22-50073 文书 1592 提交日期 03/24/23 登记日期 03/24/23 10:57:37 第 831 页，共 1063 页\n\n体现、反映、识别、陈述、直接或间接提及或以任何方式与所识别特定事项有关的任何文件。\n\n19. “通信”系指以最广义且不限于此的方式传递任何信息或知识（以事实、构想、询问或其他形式）。通信还指所有对话、协议、询问或答复，无论系当面、通过电话、以书面形式或借助电子传输设备进行，并包括但不限于所有信函、电子邮件、录音、传送单、备忘录、电话通信、语音信息、电报、电传、传真复制件、电传、即时消息、聊天记录、短信、留言板或群聊中的帖子、社交媒体帖子、推文、上传至任何视频平台的视频、电话笔记或在内部或与第三方之间传送的笔记。\n\n20. “资产”系指受占有、保管或控制的任何具有经济价值的项目。资产包括所有不动产和动产，包括但不限于房地产、土地、房屋、公寓、共管公寓、汽车、游艇、船舶、飞机、喷气式飞机、直升机、现金、银行账户、加密货币、证券、应收账款、存货以及其他有形和无形财产。\n\nIV. 应提交的文件\n\n1. 与任何由任何 2004 取证对象持有、控制、为其利益持有或以其他方式与其有关的账户有关的所有文件，包括任何及全部账户对账单、授权书、委托书、信托文件、指示或表格、已付款支票副本、通信记录，以及电汇及相关通信和指示。\n\n2. 与任何属于任何 2004 取证对象、由其持有、控制、为其利益持有或以其他方式与其有关的资金、证券、财产或资产有关的所有文件，\n\n案件 22-50073 文书 1592 提交日期 03/24/23 登记日期 03/24/23 10:57:37 第 832 页，共 1063 页\n\n包括任何及全部账户对账单、授权书、委托书、信托文件、指示或表格、已付款支票副本、通信记录，以及电汇及相关通信和指示。\n\n3. 与同任何 2004 取证对象进行的任何商业、贸易或金融交易有关的所有文件，包括但不限于任何贷款、信贷额度、寄托、存款、掉期、证券交易、抵押或 ISDA，以及任何及全部账户对账单、授权书、委托书、信托文件、指示或表格、已付款支票副本、通信记录，以及电汇及相关通信和指示。\n\n4. 与涉及 2004 取证对象的任何电汇活动有关的所有文件，不论是否存在任何账户，包括但不限于所有电汇收据、账户号码、余额、授权文件、与转账当事人有关的身份识别信息、通信记录、指示或其他记录。\n\n5. 与您和 2004 取证对象之间的任何信函往来和通信有关的所有文件。\n\n6. 与您在任何 2004 取证对象处开立的任何账户有关的所有文件，包括与账户开立、账户获授权使用人及账户维护有关的文件。\n\n7. 与涉及任何 2004 取证对象的任何反洗钱、了解你的客户或其他合规活动有关的所有文件，包括但不限于任何由任何 2004 取证对象提供的信息，或您获悉的信息。\n\n8. 与来自任何国家的任何监管机构进行的、涉及任何 2004 取证对象的任何通信有关的所有文件，包括但不限于 Bank of England（英格兰银行）、United States Federal Reserve（美国联邦储备系统）、S.E.C.（美国证券交易委员会）、CFTC（美国商品期货交易委员会）、FINRA（美国金融业监管局）、China Securities Regulatory Commission（中国证券监督管理委员会）、People's Bank of China（中国人民银行）、\n\nHong Kong Securities and Futures Commission（香港证券及期货事务监察委员会）和 Hong Kong Monetary Authority（香港金融管理局）。\n\n附件 C-46\n\nB2540（表格 2540－Rule 2004 审查传票）（12/15）案件 22-50073 文书 1592 提交日期 03/24/23 登记日期 03/24/23 10:57:37 第 835 页，共\n\nUNITED STATES BANKRUPTCY COURT（美国破产法院）\n\nDistrict of Connecticut（康涅狄格联邦地区）\n\n关于 HO WAN KWOK（郭文贵）等人，\n\n1 案件编号 22-50073 (JAM) 债务人 第 11 章\n\n（合并管理）\n\nRule 2004 审查传票\n\n致：Marcum LLP（马库姆有限责任合伙）\n\n（传票指向之人的姓名）\n\n作证：现命令您于下列规定的时间、日期及地点出席，并依《联邦破产程序规则》Rule 2004 审查作证。随附授权该审查的法院命令副本。\n\n地点　日期和时间\n\nPaul Hastings LLP（普衡律师事务所）\n200 Park Avenue　[TBD]\nNew York, New York 10166\n\n审查将以以下方式记录：法庭记录员／速记员\n\n提交：您或您的代表还必须携带下列文件、电子存储信息或物品参加审查，并必须允许对该等材料进行查验、复制、测试或抽样：\n见随附的文件提交请求。\n\n下列 Fed. R. Civ. P. 45 条款，根据 Fed. R. Bankr. P. 9016 适用于破产案件，随附于后——有关履行地点的 Rule 45(c)；有关您作为受传票约束之人的保护的 Rule 45(d)；以及有关您对本传票的答复义务及未履行该义务可能后果的 Rule 45(e) 和 45(g)。\n\n日期：March , 2023\n\n法院书记员\n\n或\n\n书记员或副书记员签名　律师签名\n\n签发或请求本传票的、代表第 11 章受托人 Luc A. Despins（吕克·A·德斯平斯）的律师之姓名、地址、电子邮件地址和电话号码如下：\n\nDouglas S. Skalka, Esq.（道格拉斯·S·斯卡尔卡律师）；Neubert, Pepe & Monteith, P.C.（纽伯特、佩佩与蒙蒂思专业公司）；195 Church Street, New Haven, Connecticut 06510；dskalka@npmlaw.com；(203) 821-2000\n\n致签发或请求本传票之人的通知\n\n如果本传票要求在审判前提交文件、电子存储信息或有形物品，或检查场所，则必须在向被指定接收传票的人送达之前，向各方当事人送达通知及本传票副本。Fed. R. Civ. P. 45(a)(4)。\n\n软件著作权（c）1996-2022 Best Case, LLC（贝斯特凯斯有限责任公司）- www.bestcase.com Best Case Bankruptcy 1 本第11章案件中的债务人为 Ho Wan Kwok（郭文贵）（亦称 Guo Wengui、Miles Guo 和 Miles Kwok，以及其他众多别名）（税务识别号码后四位：9595）、Genever Holdings LLC（Genever Holdings有限责任公司）（税务识别号码后四位：8202）以及 Genever Holdings Corporation（Genever Holdings公司）。受托人、Genever Holdings LLC 和 Genever Holdings Corporation 的邮寄地址为 Paul Hastings LLP（保罗·黑斯廷斯律师事务所），200 Park Avenue, New York, NY 10166，转交 Luc A. Despins（吕克·A·德斯平斯），作为 Ho Wan Kwok 遗产的受托人（仅用于通知和通信）。\n\n送达证明\n\n（除非 Fed. R. Civ. P. 45 要求，否则本节不应向法院提交。）\n\n我于（日期）收到向（个人姓名及职务，如有）发出的本传票。\n\n我已按以下方式将传票副本交付给所列明人员，以送达本传票：\n\n于（日期）；或者\n\n我未执行传票即予退回，原因如下：\n\n除非该传票代表美国或其官员或代理人发出，我还已向证人支付一天出庭费用及法律允许的里程费，金额为 \\$ 。\n\n我的差旅费用为 \\$，服务费用为 \\$，合计为 \\$。\n\n我在伪证罪处罚的约束下声明，该等信息真实且正确。\n\n日期：\n\n送达人员签名\n\n印刷体姓名及职务\n\n送达人员地址\n\n关于尝试送达等的补充信息：\n联邦民事诉讼规则45(c)、(d)、(e)及(g)（生效日期：12/1/13）（根据联邦破产程序规则9016适用于破产案件）\n(c) 履行地点。\n\n(1) 审判、听证或证言录取。传票仅可按以下方式命令某人出席审判、听证或证言录取：\n\n(A) 在该人居住、受雇或经常亲自从事商业活动地点的100英里范围内；或者\n\n(B) 在该人居住、受雇或经常亲自从事商业活动所在州内，但前提是该人\n\n(i) 为当事人或当事人的高级职员；或者\n\n(ii) 被命令出席审判，且不会产生重大费用。\n\n(2) 其他证据开示。传票可命令：\n\n(A) 在该人居住、受雇或经常亲自从事商业活动地点的100英里范围内的地点提交文件、电子存储信息或物品；以及\n\n(B) 在待检查场所进行场所检查。\n(d) 对受传票约束人员的保护；执行。\n\n(1) 避免不当负担或费用；制裁。负责签发和送达传票的当事人或律师必须采取合理措施，避免对受传票约束的人施加不当负担或费用。要求履行的地区法院必须执行该义务，并对未遵守者的当事人或律师施加适当制裁，该制裁可包括损失的收入和合理的律师费。\n\n(2) 提交材料或准许检查的命令。\n\n(A) 无须出席。被命令提交文件、电子存储信息或有形物品，或准许检查场所的人，无须亲自出席提交或检查地点，除非同时被命令出席证言录取、听证或审判。\n\n(B) 异议。被命令提交文件或有形物品，或准许检查的人，可以向传票中指定的当事人或律师送达书面异议，反对检查、复制、测试或抽样任何或全部材料，或反对检查场所，或反对以所要求的一种或多种形式提交电子存储信息。异议必须在规定履行时间届满前或传票送达后14日内（以较早者为准）送达。提出异议后，适用下列规则：\n\n(i) 送达方可随时在通知被命令人员后，向要求履行的地区法院提出动议，请求作出强制提交或检查的命令。\n\n(ii) 仅可按照命令所指示的方式要求实施该等行为，且该命令必须保护并非当事人或当事人高级职员的人免于承担因履行而产生的重大费用。\n\n(3) 撤销或修改传票。\n\n(A) 必须撤销或修改的情形。经及时动议，要求履行的地区法院必须撤销或修改具有下列情形的传票：\n\n(i) 未给予合理的履行时间；\n\n(ii) 要求某人在规则45(c)规定的地域限制之外履行；\n\n(iii) 要求披露享有特权或受其他保护的事项，且不适用例外或豁免；或者\n\n(iv) 对某人施加不当负担。\n\n(B) 可撤销或修改的情形。为保护受传票约束或受其影响的人，经动议，要求履行的地区法院可以撤销或修改要求下列事项的传票：\n\n(i) 披露商业秘密或其他保密的研究、开发或商业信息；或者\n\n(ii) 披露未经聘用的专家就争议中的具体事件未作说明、且源于非由当事人请求的专家研究的意见或信息。\n\n(C) 以规定条件作为替代。在规则45(d)(3)(B)所述情形下，如送达方：\n\n(i) 证明对该证言或材料具有重大需要，且无法在不造成不当困难的情况下通过其他方式满足该需要；并且\n\n(ii) 确保被传唤人员将获得合理补偿，\n\n法院可以不撤销或修改传票，而命令在规定条件下出席或提交材料。\n(e) 回应传票的义务。\n\n(1) 提交文件或电子存储信息。下列程序适用于提交文件或电子存储信息：\n\n(A) 文件。回应要求提交文件的传票的人，必须按照文件在通常业务过程中的保存方式提交，或必须将其整理和标记，以对应请求中的类别。\n\n(B) 未指定电子存储信息的提交形式。如传票未指定提交电子存储信息的形式，回应人必须以其通常保存的一种或多种形式，或以一种或多种合理可用的形式提交。\n\n(C) 电子存储信息仅以一种形式提交。回应人无须以一种以上形式提交相同的电子存储信息。\n\n(D) 无法访问的电子存储信息。对于回应人认定因不当负担或费用而无法合理访问的来源中的电子存储信息，回应人无须提供证据开示。在提出强制证据开示动议或保护令动议时，回应人必须证明该信息因不当负担或费用而无法合理访问。如作出该证明，若请求方在考虑规则26(b)(2)(C)的限制后证明具有正当理由，法院仍可命令对该等来源进行证据开示。法院可以规定该证据开示的条件。\n\n(2) 主张特权或保护。\n\n(A) 扣留的信息。因主张传票要求的信息享有特权或作为审判准备材料受到保护而扣留该信息的人，必须：(i) 明确提出该主张；并且\n\n(ii) 以一种在不披露本身享有特权或受保护的信息的情况下，使当事人能够评估该主张的方式，描述被扣留文件、通信或有形物品的性质。\n\n(B) 已提交的信息。如为回应传票而提交的信息被主张享有特权或作为审判准备材料受到保护，提出该主张的人可以将该主张及其依据通知任何收到该信息的当事人。收到通知后，当事人必须立即返还、隔离或销毁所指定的信息及其持有的任何副本；在该主张得到解决之前，不得使用或披露该信息；如当事人在收到通知前已披露该信息，必须采取合理措施予以追回；并可立即向要求履行的地区法院密封提交该信息，以裁定该主张。提交该信息的人必须在该主张得到解决前保存该信息。\n\n(g) 藐视法庭。要求履行的地区法院，以及在动议被移送后签发传票的法院，可以对已被送达却无充分理由不遵守传票或相关命令的人以藐视法庭论处。\n\n有关传票材料，请参见 Fed.R.Civ.P.45(a) Committee Note (2013)\n\n……\n\n文件提交请求\nI. 指示\n\n1. 除非另有说明，下列文件请求（以下简称“请求”，每一项以下简称“一项请求”）必须分别且具体地作出答复。除非善意提出异议，否则必须完整答复每项请求；如提出异议，则必须按照下文规定详细说明阁下异议的理由。如异议仅涉及一项请求的一部分，或其中包含的某一词语、短语或条款，阁下仅须对该部分提出异议，并对其余请求作出答复。\n\n2. 电子存储信息必须按照以下指示提交：\n\na. 图像。黑白图像必须为300 DPI Group IV 单页 TIFF 文件。彩色图像必须以 JPEG 格式提交。文件名不得包含嵌入式空格或特殊字符（包括逗号）。文件夹名称不得包含嵌入式空格或特殊字符（包括逗号）。所有 TIFF 图像文件必须具有唯一的文件名，即 Bates 编号。每幅图像的右下角必须标注连续的 Bates 编号。每个文件夹内的 TIFF 文件数量不应超过1000个文件。Excel 电子表格应具有以该文件的 Bates 编号命名的占位图像。\n\nb. 图像加载文件\n\na. Concordance® 数据文件。数据文件（.DAT）包含将被加载至 Concordance® 数据库的所有字段化信息。.DAT 文件的第一行必须为标识字段名称的标题行。.DAT 文件必须使用以下 Concordance® 默认分隔符：逗号 ASCII 字符（020）引号 þ ASCII 字符（254）。日期字段应按以下格式提供：mm/dd/yyyy。日期和时间字段必须为两个独立字段。如文件包括已成像的电子邮件及附件，则必须包括附件字段，以保留电子邮件及其附件之间的父项/子项关系。必须包括 OCRPATH 字段，以提供所提交存储介质上提取文本文件的文件路径和名称。文本文件必须以 FIRSTBATES 命名。请勿在 .DAT 文件中包含文本。对于含有原生文件的文件，必须包括 LINK 字段，以提供原生文件的文件路径和名称。原生文件必须以 FIRSTBATES 命名。\n\nb. Concordance Image® 或 Opticon 交叉引用文件。图像交叉引用文件（.LOG 或 .OPT）将图像链接至数据库记录。该文件应为以逗号分隔的文件，每行由七个字段组成，数据库中的每一图像均应在交叉引用文件中对应一行，格式如下：ImageID,VolumeLabel,ImageFilePath,DocumentBreak,FolderBreak,Box Break,PageCount。\n\nc. 文档文本。文本必须作为单独的文本文件提供，而非作为 .DAT 文件内的字段。文本文件的完整路径（OCRPATH）应包含在 .DAT 文件中。建议提供以 FIRSTBATES/Image Key 命名的文档级 ANSI 文本文件。提取的文本文件必须置于单独的文件夹中，且每个文件夹中的文本文件数量不得超过 1,000 个。文件夹名称中不得包含特殊字符（包括逗号）。文本文件必须按文档级别提供。\n\nd. 特定文件类型的原生格式提供。为充分理解其内容和含义而合理需要以原生格式查看的文件类型，必须以原生格式提供。该等文件包括但不限于：电子表格、类电子表格文件（Microsoft Excel、逗号分隔值、制表符分隔值等）、Microsoft PowerPoint 或其他特殊演示文件、数据库文件以及音频/视频文件。应提供一张带有 Bates 编号的分隔页图像，表明存在原生文件，并将原生文件的路径作为 .dat 文件中的一个字段列入。所提供的原生文件应以与该文件分隔页相对应的 Bates 编号命名。原生文件应归入按递增方式命名的“NATIVE”目录中，并与图像目录分开。\n\ne. 去重。对于存在完全重复件的每一电子文档，仅提供一个副本。对于电子邮件，应根据由 BCC、Body、CC、From、IntMsgID、To 和 Attach 属性生成的 MD5 哈希值合并重复件。对于电子邮件附件及独立电子文件，应根据整个文件的 MD5 哈希值合并重复件。\n\nf. 元数据。应以符合 Concordance 标准的加载文件（.dat）形式，为每份文档提供提取的元数据。.DAT 文件的第一行必须为标明字段名称的标题行。.DAT 文件必须使用以下 Concordance 默认分隔符：逗号 , ASCII 字符（020）引号 þ ASCII 字符（254）\n\n日期字段应按如下格式提供：mm/dd/yyyy。日期和时间字段必须为两个独立字段。所需元数据如下：\n\n案号 22-50073 文件 1592 提交于 03/24/23 录入于 03/24/23 10:57:37 第 840 页，共 1063 页\n\n字段名称　示例数据　说明\n\nFIRSTBATES　EDC0000001　原生文件文档/电子邮件的第一个 Bates 编号\n\nLASTBATES　EDC0000001　原生文件文档/电子邮件的最后一个 Bates 编号\n\nLASTBATES 字段应针对单页文档填写。\n\nATTACHRANGE　EDC0000001\n-　父文档第一页的 Bates 编号至最后一个附件“子”文档最后一页的 Bates 编号。\nEDC0000015\n\nBEGATTACH　EDC0000001　附件范围的第一个 Bates 编号\n\nENDATTACH　EDC0000015　附件范围的最后一个 Bates 编号\n\nCUSTODIAN　Smith, John　电子邮件：该电子邮件所在的邮箱。\n原生文件：文档来源文件所属个人或部门的名称。\n\nFROM　John Smith　电子邮件：发件人。\n原生文件：文档作者。\n多个条目应使用分号分隔。\n\nTO　Coffman, Janice; LeeW　收件人。\n[mailto:LeeW@MSN.com]　多个条目应使用分号分隔。\n\nCC　Frank Thompson [mailto:　抄送收件人。\nfrank_Thompson@cdt.com]　多个条目应使用分号分隔。\n\nBCC　John Cain　密送收件人。\n多个条目应使用分号分隔。\n\nSUBJECT　Board Meeting Minutes　电子邮件：电子邮件主题行。原生文件：文档标题（如有）。\n\nFILE_NAME　BoardMeetingMinutes.docx　原生文件：原始原生文件的名称，包括扩展名。\n\nDATE_SENT　10/12/2010　电子邮件：电子邮件发送日期。\n原生文件：（空）\n\nTIME_SENT/　07:05 PM GMT　电子邮件：电子邮件发送时间/电子邮件标准化所采用的时区。\nTIME_ZONE\n\nTIME_ZONE　GMT　在转换过程中电子邮件被标准化所采用的时区。\n\nLINK　EDC0000001.msg　电子邮件或原生文件文档的超链接。\n所链接文件必须按 FIRSTBATES 编号命名。\n\nFILE_EXTEN　MSG　表示电子邮件或原生文件的文件类型扩展名。\n\nAUTHOR　John Smith　电子邮件：（空）\n原生文件：文档作者。\n\nDATE_CREATED　10/10/2010　电子邮件：（空）\n原生文件：文档创建日期。\n\n案号 22-50073 文件 1592 提交于 03/24/23 录入于 03/24/23 10:57:37 第 841 页，共 1063 页\n\nTIME_CREATED　10:25 AM　电子邮件：（空）\n原生文件：文档创建时间。\n该数据必须为独立字段，不得与 DATE_CREATED 字段合并。\n\nDATE_MOD　10/12/2010　电子邮件：（空）\n原生文件：文档最后修改日期。\n\nTIME_MOD　07:00 PM　电子邮件：（空）\n原生文件：文档最后修改时间。\n该数据必须为独立字段，不得与 DATE_MOD 字段合并。\n\nDATE_ACCESSD　10/12/2010　电子邮件：（空）\n原生文件：文档最后访问日期。\n\nTIME_ACCESSD　07:00 PM　电子邮件：（空）\n原生文件：文档最后访问时间。\n该数据必须为独立字段，不得与 DATE_ACCESSD 字段合并。\n\nFILE_SIZE　5,952　原生文件文档/电子邮件的大小，以 KB 计。\n\nPGCOUNT　1　原生文件文档/电子邮件的页数。\n\nPATH　电子邮件：（空）\nAgenda.doc　原生文件：存储原生文件文档的路径，包括原始文件名称。\n\nINTFILEPATH　Personal Folders\\Deleted　电子邮件：电子邮件的原始位置，包括原始文件名称。\nItems\\Board Meeting\nMinutes.msg　原生文件：（空）\n\nINTMSGID　<000805c2c71b\\$75977050\\$　电子邮件：唯一消息 ID。原生文件：（空）\ncb8306d1@MSN>\n\nMD5HASH　d131dd02c5e6eec4693d9a0　文档的 MD5 哈希值。\n698aff95c\n2fcab58712467eab4004583e\nb8fb7f89\n\nOCRPATH　TEXT/001/EDC0000001.txt　原生文件提取文本的路径。\n\n3. 每项请求均独立适用并应独立解释；除非另有说明，任何一项请求均不限制任何其他请求的范围。\n\n4. 所有文档均应按照其在通常业务过程中保存的方式提供，或者应予以组织和标注，以对应本请求中的类别。\n\n5. 本文件所载每项请求均延及下列所有文档：(a) 由您占有、保管或控制的文档；或 (b) 由代表您行事的任何人占有、保管或控制的文档，\n\n案号 22-50073 文件 1592 提交于 03/24/23 录入于 03/24/23 10:57:37 第 842 页，共 1063 页\n\n包括您的律师或其他代表和顾问。每份文档均应完整提供。\n\n6. 如要求您提供的某份文档已不再由您占有、保管或控制，则您的答复必须：(a) 详细说明该文档的性质及其内容；(b) 指明编制或撰写该文档的人员（以及，如适用，该文档被发送给的人员）；(c) 指明该文档编制或创建的日期；(d) 说明该文档是否：(i) 遗失或丢失，(ii) 已被销毁，(iii) 已自愿或非自愿地转移给他人，或 (iv) 以其他方式被处置；(e) 说明该等处置的原因及其相关事实和情形；(f) 指明授权该等处置的人员；(g) 指明该等处置的日期或大致日期；(h) 说明该文档最近一次由您占有、保管或控制的时间；以及 (i) 指明目前占有、保管或控制该文档的人员（如有）。\n\n7. 如要求您提供的某份文档已被销毁，则除前述指示要求的信息外，您的答复还必须说明：(a) 销毁该文档的原因；(b) 销毁该文档的人员身份；以及 (c) 指示销毁该文档的人员身份。\n\n8. 如您主张所请求的文档享有特权或属于律师工作成果，则您的答复必须：(a) 说明：(i) 足以支持您关于该文档享有特权之主张的文档说明，(ii) 文档标题，(iii) 文档日期，(iv) 文档作者，(v) 文档收件人，(vi) 收到或看到该文档原件或任何草稿、副本或复制件的每一人员身份，(vii) 该文档本身或文档所载或所提及的任何信息是否由任何其他人员占有、保管或控制，以及如是，该等人员的身份；\n\n案号 22-50073 文件 1592 提交于 03/24/23 录入于 03/24/23 10:57:37 第 843 页，共 1063 页\n\n并说明该信息如何进入其占有范围，(viii) 据以扣留该文档的特权主张，以及 (ix) 您将依赖以支持该等特权主张的所有情形；以及 (b) 根据 D. Conn. L. Civ. R. 26(e)，就每一份基于特权主张而被扣留的文档，提供一份特权日志，其中载明本指示第 (a) 部分所要求的全部信息。对于文档请求中未主张特权或工作成果的任何部分，应完整提供响应性文档。\n\n9. 如本应响应的文档中有一部分包含受特权主张约束的信息，则仅应按照上述指示从该文档中删除或遮盖受特权主张约束的部分，其余部分应予提供。\n\n10. 各项请求具有持续性。特此指示您：(a) 一旦得知先前答复不完整或不正确，应立即补充或更正任何后来发现不完整或不正确的答复；以及 (b) 提供根据下述规定所要求的任何补充文档。\n\n11. 如某份文档使用英语以外的语言，您应提供该文档。如某份文档使用英语以外的语言，且存在英文译本，您应同时提供两份文档。\n\n12. 对实体的所有提及均包括其全部关联方。\n\n13. 对个人姓名的所有提及均包括所有别名、化名或昵称。\n\n案号 22-50073 文件 1592 提交于 03/24/23 录入于 03/24/23 10:57:37 第 844 页，共 1063 页\n\n14. 除非另有明确说明，文档请求所涵盖的期间为自 February 5, 2012 起至应提交文档请求答复之日止。\n\nII. 解释规则\n\n15. (a) 任何单数名词的使用均应解释为包括复数，反之亦然；以及 (b) 任何时态动词的使用均应解释为使用该动词的所有其他时态。\n\n16. (a) “和”及“或”应按必要情形解释为连词性或选择性用法，以使任何请求的范围涵盖原本可能被解释为不在其范围内的所有答复；以及 (b) “每一”和“任何”应视为包括并涵盖“每个”和“所有”二词。\n\nIII. 定义\n\nD. Conn. L. Civ. R. 26(c) 所提供的定义以及 D. Conn. L. Civ. R. 26(d) 所提供的解释规则，经由 D. Conn. Bankr. L.R. 2004-1(a) 纳入，均适用于文档请求。此外，本文件中的文档请求所使用的下列术语具有如下含义：\n\n1. “您”或“您的”或“您本人”是指并包括 Marcum LLP（玛泽会计师事务所）及其任何雇员、代理人、律师、顾问或代表其行事的任何人。\n\n2. “债务人”是指 Ho Wan Kwok（郭文贵）（又名 Miles Kwok、Miles Guo、Guo Wengui、Guo Haoyun、郭文贵或任何其他别名）及其雇员、代理人、律师、顾问或代表其行事的任何人。\n\n案号 22-50073 文件 1592 提交于 03/24/23 录入于 03/24/23 10:57:37 第 845 页，共 1063 页\n\n3. “债务人之子”系指 Qiang Guo（郭强）（又名 Mileson Kwok、郭强，或任何其他别名），连同其雇员、代理人、律师、顾问或任何代表其行事之人。\n\n4. “债务人之女”系指 Mei Guo（郭美）（又名 Mei Gui、郭美，或任何其他别名），连同其雇员、代理人、律师、顾问或任何代表其行事之人。\n\n5. “债务人自称的妻子”系指 Hing Chi Ngok（岳庆芝）（又名 Hing Chi Ng、Yue Qingzhi、岳庆芝，或任何其他别名），连同其雇员、代理人、律师、顾问或任何代表其行事之人。\n\n6. “债务人家庭”统称债务人、债务人之子、债务人之女及债务人自称的妻子，以及与债务人具有任何其他家庭关系之人。\n\n7. “关联个人”单独及合称指下列所有个人：(1) 持有、控制、保管或有权酌情处置由债务人或债务人家庭拥有、控制或享有的资产；或 (2) 曾为一个或多个关联实体的雇员、董事，或以其他方式与其有关联；连同上述任何人的各自雇员、代理人、律师、顾问或任何代表其行事之人。该等关联个人包括但不限于：Daniel Podhaskie、Jason Miller、Steve Bannon、Karin Maistrello、Melissa Francis、Anthony DiBattista、William Gertz、Arethusa Forsyth、Glenn Mellor、Jennifer Mercurio、Eduardo Eurnekian、Wencong Wang、Han Chunguang（又名 韩春光）、Qu Guojiao（又名 Qu Guo Jiao、屈国姣）、Guo Lijie（又名 郭丽杰）、Zhang Wei（又名 张伟*）、Lihong Wei Lafrenz（又名 Sara Wei、魏丽红）、Hao Haidong（又名 郝海东）、Ross Heinemeyer、Max Krasner、Kyle Bass、Melissa Mendez、Ya Li（又名 李娅）、Dinggang Wang（又名 王定刚）、An Hong（又名 安红）、Yvette Wang（又名 Yanping Wang、Yan Ping Wang、王雁平）、Fiona Yu、Je Kin Ming\n\nCase 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 846 of 1063\n\n（又名 William Je、Yu Jianming、余建明）、Yaz Qingua 及 Lao Jiang（又名 Jiang Yunfu、Jiang Yunfu Be、姜云浮）。\n\n8. “关联实体”单独及合称指下列所有任何类型的组织或实体：(1) 曾由债务人或债务人家庭拥有、控制或投资；或 (2) 对债务人或债务人家庭拥有、控制或享有的任何资产直接或间接享有权益；连同上述任何实体的各自雇员、代理人、律师、顾问或任何代表其行事之人。该等关联实体包括但不限于：7 Nod Hill LLC、AAGV Limited、ACA Investment Management Limited、ACA Capital Group Limited、Ace Decade Holdings Limited、AI Group Holdings Inc.、Alfa Global Ventures Limited、Alfonso Global Limited、Allied Capital Global Limited、Alpine Fiduciaries SA、Anton Development Limited、Assets Sino Limited、Auspicious Coast Limited、Beijing Pangu Investment Co.、Beijing Pangu Investment Co. Ltd.、Beijing Pangu Investment Inc.、Beijing Zenith Holdings Company Limited、Booming Sail New York LLC、Bravo Luck Limited、BSA Strategic Fund I、China Golden Spring (Hong Kong) Limited、Chuang Xin Limited、Crane Advisory Group LLC、Creative Apex Investments Limited、Crystal Breeze Investments Limited、Dawn State Limited、Eastern Profit Corporation Limited、Elite Well Global Limited、Empire Growth Holdings、Freedom Media Ventures Ltd.、G Club Operations LLC、G Fashion LLC、G News LLC、GETTR USA、Genever Holdings Corporation、Genever Holdings LLC、Gfashion Media Group Inc.、GFNY, Inc.、Globalist International Limited、GNews Media Group Inc.、Golden Spring (New York) Ltd.、Greenwich Land LLC、Guo Media、GTV Media Group, Inc.、Hamilton Capital Holdings Inc.、HCHK Property Management, Inc.、HCHK Technologies, Inc.、Head Win Group Limited、Henan Yuda、Himalaya Embassy、Himalaya Exchange、Himalaya Federal Reserve、Himalaya Investment LLC、Himalaya International、\n\nCase 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 847 of 1063\n\nHimalaya New World Inc.、Himalaya Supervisory Organization、Himalaya Ventures LLC、HK International Funds Investments (USA) Limited LLC、Hong Kong International Funds Investments Limited、Hudson Diamond Holding、Infinite Increase Limited、Infinitum Developments Limited、Infinity Treasury Management Inc.、Insight Phoenix Fund、Lamp Capital LLC、Leading Shine Limited、Leading Shine NY Limited、Lexington Property and Staffing、Long Gate Limited、Maywind Trading LLC、MOS Himalaya LLC、Next Tycoon Investments Limited、New Federal State of China（又名 NFSC）、Noble Fame Global Limited、Rosy Acme Ventures Limited、Rule of Law Foundation III, Inc.、Rule of Law Foundation IV, Inc.、Rule of Law Fund、Rule of Law Society、Rule of Law Society IV, Inc.、G-Translators PTY LTD、Saraca Media Group, Inc.、Shiny Ace Ltd.、Shiny Times Holdings Ltd.、Spirit Charter Investment Limited、Stevenson, Wong & Co.、Voice of Guo Media, Inc.、Well Origin Ltd.、World Century Limited、Worldwide Opportunity Holdings Limited、Whitecroft Shore Limited 及 ZIBA Limited。\n\n9. “包括”或其任何变体，系指“包括但不限于”。\n\n10. “和”及“或”系指“和/或”，并应作连词性及析取性解释，以最大限度扩大其范围。\n\n11. “任何”及“所有”和“每一”系指“每一个及所有”。\n\n12. “每一”及“每个”系指“每一个及所有”。\n\n13. “第三方”系指您以外的个人或实体。\n\n14. “转让”具有《破产法》第 101(54) 条赋予该词的含义。\n\n15. “文件”系指属于 Fed. R. Civ. P. 34 范围内的任何信息或物品，并包括但不限于任何种类、类型、性质或描述的每一份书面、记录或图形材料，\n\nCase 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 848 of 1063\n\n该等材料现由或曾由您占有、保管或控制，包括所有电子邮件的印刷副本及电子副本、以电子形式保存的计算机文件、通信函件、备忘录、磁带、速记或手写笔记、任何种类的书面表格、图表、蓝图、绘图、草图、曲线图、计划、文章、规格、日记、信函、电报、照片、会议记录、合同、协议、调查资料、计算机打印件、任何种类的数据汇编、电传、传真、电子邮件、短信、即时消息、语音留言、发票、订购单、支票、汇票、对账单、贷项通知单、报告、头寸报告、摘要、索引、账簿、分类账、笔记本、清单、透明胶片、录音、目录、广告、宣传材料、胶片、录像带、录音带、CD、计算机磁盘、小册子、宣传册、穿孔卡、工时单、推文、社交媒体帖子或任何其他种类的书面或记录材料，以及其全部元数据，无论以何种方式存储（无论为有形或电子形式）、记录、制作或复制，亦包括但不限于前述任何文件的草稿或副本，如其包含原始文件中未有的任何种类笔记、评论或标记，或以其他方式与原始文件不相同。\n\n16. “个人”系指个人、公司、独资企业、合伙企业、协会或任何其他实体。“个人”亦包括任何代理人、代表或专家，包括但不限于律师或财务顾问。\n\n17. “实体”系指任何自然人、公司、合伙企业、子公司、独资企业、商号、董事会、合资企业、协会、机构、机关、委员会或其他商业实体或法人，以及任何关联方、代理人、母公司，包括但不限于律师、财务顾问或任何其他代表。\n\nCase 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 849 of 1063\n\n18. “关于”系指涉及、描述、构成、提及、与之相关、支持、赞成、反对、强化、减损、位于其中、就其加以考虑、对其有影响、证明、表明、报告、记录、暗指、回应、与之相连、评论、就其而言、有关、与之相关、讨论、显示、描述、反映、分析、构成及属于。\n\n19. 当“与……相关”、“涉及”或“相关”指称任何特定事项时，系指但不限于构成、组成、涉及、包含、体现、反映、识别、陈述、直接或间接提及，或以任何方式与所识别的特定事项有关的任何文件。\n\n20. “通信”系指在最广泛可能意义上且不限于任何信息或知识的传递（以事实、想法、询问或其他形式）。通信还指所有谈话、协议、询问或答复，无论是当面、通过电话、书面方式，还是通过电子传输设备，并包括但不限于所有通信函件、电子邮件、录音、传送单、备忘录、电话通信、语音留言、电报、电话传真、传真副本、电传、即时消息、聊天、短信、发布至留言板或群聊的帖子、社交媒体帖子、推文、上传至任何视频平台的视频、电话笔记，或在内部或与第三方之间传送的笔记。\n\n21. “资产”系指受占有、保管或控制的任何具有经济价值的项目。资产包括所有不动产和动产，包括但不限于房地产、土地、房屋、公寓、共管公寓、汽车、游艇、船只、飞机、喷气机、直升机、现金、银行账户、加密货币、证券、应收账款、存货及其他有形和无形财产。\n\nCase 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 850 of 1063\n\nIV. 应提交的文件\n\n1. 与债务人、债务人财产、债务人家庭或关联实体的任何收入或资产相关的所有文件。\n\n2. 与债务人、债务人家庭任何成员和/或任何关联实体签订的任何委托函相关的所有文件，包括该等委托函的副本。\n\n3. 与基于您对债务人、债务人家庭或关联实体的代理而向您支付任何预付律师费相关的所有文件，包括足以识别该预付律师费金额及其来源的文件。\n\n4. 与您从债务人、债务人家庭、家庭关联实体或关联实体处或代表其收取，并存放于托管账户或客户信托账户中的任何费用、付款或款项相关的所有文件。\n\n5. 足以显示债务人、债务人家庭或关联实体向您支付或为其利益向您支付的任何款项的金额、日期及来源的文件。\n\n6. 与债务人的财务状况及其对债权人的义务相关的所有文件，包括但不限于与避免支付该等义务的任何努力相关的所有文件，以及与本次或任何其他实际或潜在破产或类似资不抵债程序相关的所有文件。\n\n7. 与关联实体相关的所有文件，包括但不限于与其公司结构、资产、设立信息、高级职员及董事、经营目的，以及其与债务人、债务人家庭任何成员或任何关联个人之间关系相关的文件。\n\nCase 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 851 of 1063\n\n8. 与债务人或债务人家庭一方同关联实体另一方之间，由、与或代表债务人或债务人家庭进行的任何投资或商业交易有关的所有文件。\n\n9. 与债务人、债务人财产、债务人家庭成员或关联实体持有任何权益或投资的任何实体有关的所有文件，包括但不限于该等权益或投资的性质和价值；债务人、债务人财产、债务人家庭成员或关联实体因该等权益或投资而从该实体获得的任何收益或利益；以及与该实体有关的任何财务报告或数据的所有文件，包括但不限于所有账簿和记录、财务报表或税务文件。\n\n10. 关于 Lady May（“Lady May”号）、Sherry Netherland Hotel / Condominium（雪梨荷兰人酒店／共管公寓）；位于 Connecticut（康涅狄格州）Greenwich（格林尼治）373 Taconic Rd. 的住宅物业；位于 Connecticut（康涅狄格州）Greenwich（格林尼治）33 Ferncliff Rd. 的住宅物业；位于 Connecticut（康涅狄格州）Wilton（威尔顿）354 Nod Hill Rd. 的住宅物业；以及债务人或债务人财产在任何关联实体中拥有的任何财务权益的所有文件。\n\n11. 与债务人以受托人身份、Genever Holdings Corporation（Genever Holdings 公司）及 Genever Holdings LLC（Genever Holdings 有限责任公司）为 Bravo Luck Limited（Bravo Luck 有限公司）作为受益人而订立的、日期为 February 17, 2015 的所称《信托声明及协议》有关的所有文件。\n\n12. 与债务人拥有、控制或使用的任何航空器有关的所有文件，包括但不限于尾号为 T7-GQM 的航空器，以及在 San Marino（圣马力诺）登记的任何其他航空器，包括但不限于所有登记文件副本及显示该等航空器所执行航班和该等航班机上人员的飞行舱单。\n案号 22-50073 文件 1592 提交于 03/24/23 录入于 03/24/23 10:57:37 第 852 页，共 1063 页\n\n13. 与债务人、债务人家庭成员或关联实体于 July 2020 前后或任何其他时间对原油期货或任何类似商品进行的任何投资或交易有关的所有文件，包括但不限于与 Jiang Yunfu Be（姜云福贝）就任何该等投资或交易进行的通信。\n\n14. 贵方与债务人、债务人家庭成员或任何关联个人、代理人、雇员或代表债务人行事的其他个人之间，就与债务人、债务人财产、债务人家庭成员或关联实体有关的任何转移、投资或其他交易或商业往来所进行的所有通信。\n\n15. 与由债务人、债务人财产、债务人家庭成员或关联实体设立、代表其设立或为其利益设立的任何信托或类似文书有关的所有文件，包括但不限于显示该等信托何时设立、由何人设立、为谁的利益设立以及该文书信托财产的文件。\n\n16. 与涉及债务人、债务人家庭成员或任何关联实体的任何出售、取得、处置、购买、投资、出资、赠与、信贷展期、贷款或转移有关的所有文件。\n\n17. 与涉及债务人的任何法律争议相关的任何义务、请求权、责任或债务有关的所有文件，包括但不限于与在任何地方、州、联邦或国际机构（无论为行政机构、法院、合议机构或替代性争议解决实体）前进行的任何诉讼有关的文件。\n\n18. 与向债务人、债务人财产、债务人家庭成员或任何关联实体提供或由其提供的任何贷款或信贷展期，或对该等贷款或信贷展期的申请有关的所有文件，包括但不限于：(i) 任何该等贷款或信贷展期的条款，包括其\n案号 22-50073 文件 1592 提交于 03/24/23 录入于 03/24/23 10:57:37 第 853 页，共 1063 页\n\n还款条款、陈述与保证及利率；以及 (ii) 证明贷款付款情况的所有证据。\n\n19. 与债务人使用属于、由债务人家庭成员、关联实体或关联个人控制，或其全部或部分所有权由债务人家庭成员、关联实体或关联个人持有的任何资产有关的所有文件。\n\n20. 关于与债务人、债务人财产、债务人家庭成员、关联实体或关联个人有关的任何资产负债表、银行对账单、账户对账单、财务报表、账目报表、电汇指示及／或确认书、资金证明、存款证、持有证明、投资组合摘要或类似文件的所有文件，包括但不限于足以显示向前述任何一方作出的所有转移的所有文件。\n\n21. 与将任何关联实体（包括 Bravo Luck Limited（Bravo Luck 有限公司））的资产质押给任何其他实体有关的所有文件。\n\n案号 22-50073 文件 1592 提交于 03/24/23 录入于 03/24/23 10:57:37 第 854 页，共 1063 页\n附件 C-47\nB2540（表格 2540－Rule 2004（规则 2004）审查传票）（12/15）案号 22-50073 文件 1592 提交于 03/24/23 录入于 03/24/23 10:57:37 第 855 页，共\n\nUNITED STATES BANKRUPTCY COURT（美国破产法院）\n\nDistrict of Connecticut（康涅狄格区）\n\n关于 HO WAN KWOK（郭文贵）等人，\n\n1 案号 22-50073 (JAM) 债务人 第 11 章\n\n（合并管理）\nRULE 2004 审查传票\n\n致：Brent Petro Inc.（Brent Petro 公司）\n\n（传票所指向人员的姓名）\n\n证言：兹命令贵方于下列载明的时间、日期和地点出席，以根据《联邦破产程序规则》Rule 2004（规则 2004）接受审查并作证。随附授权该审查的法院命令副本。\n\n地点　日期和时间\n\nPaul Hastings LLP（Paul Hastings 律师事务所）\n200 Park Avenue　[TBD]\nNew York, New York 10166（纽约州纽约市 10166）\n\n审查将通过以下方式记录：法庭记录员／速记员\n\n提交：贵方或贵方代表还必须携带下列文件、以电子方式存储的信息或物品参加审查，并必须允许对该等材料进行查验、复制、测试或抽样：\n见随附的文件提交请求。\n\n《联邦民事诉讼规则》Fed. R. Civ. P. 45 的下列规定（根据《联邦破产程序规则》Fed. R. Bankr. P. 9016 适用于破产案件）随附于后——有关履行地点的 Rule 45(c)；有关对作为传票对象之人员的保护的 Rule 45(d)；以及有关贵方对本传票作出回应的义务及未如此行事的潜在后果的 Rule 45(e) 和 45(g)。\n\n日期：March , 2023\n\n法院书记员\n\n或\n\n书记员或副书记员签名　律师签名\n\n代表发出或请求本传票的第 11 章受托人 Luc A. Despins（Luc A. Despins）的律师姓名、地址、电子邮件地址和电话号码如下：\n\nDouglas S. Skalka, Esq.（Douglas S. Skalka 律师）；Neubert, Pepe & Monteith, P.C.（Neubert, Pepe & Monteith 专业公司）；195 Church Street, New Haven, Connecticut 06510；dskalka@npmlaw.com；(203) 821-2000\n\n致发出或请求本传票之人员的通知\n\n如本传票命令在审判前提交文件、以电子方式存储的信息或有形物品，或查验场所，则必须在向本传票所指向人员送达之前，向每一方送达通知和本传票副本。Fed. R. Civ. P. 45(a)(4)。\n\n软件版权 (c) 1996-2022 Best Case, LLC（Best Case 有限责任公司）－www.bestcase.com Best Case Bankruptcy 1 本第 11 章案件中的债务人为 Ho Wan Kwok（郭文贵）（亦称 Guo Wengui（郭文贵）、Miles Guo（郭文贵）及 Miles Kwok（郭文贵），以及众多其他别名）（税务识别号码末四位：9595）、Genever Holdings LLC（Genever Holdings 有限责任公司）（税务识别号码末四位：8202）及 Genever Holdings Corporation（Genever Holdings 公司）。受托人、Genever Holdings LLC 及 Genever Holdings Corporation 的邮寄地址为 Paul Hastings LLP（Paul Hastings 律师事务所），200 Park Avenue, New York, NY 10166，转交 Luc A. Despins（Luc A. Despins），作为 Ho Wan Kwok（郭文贵）财产的受托人（仅为通知和通信之目的）。\n送达证明\n\n（除非 Fed. R. Civ. P. 45 要求，否则本节不应向法院提交。）\n\n本人于（日期）收到向（个人姓名及职务，如有）发出的本传票。\n\n本人通过如下方式向被指定人员交付副本，以送达该传票：\n\n于（日期）；或\n\n本人未执行而退回本传票，原因如下：\n\n除非本传票代表 United States（美国）或其官员或代理人之一发出，本人亦已向证人支付一天出席费用及法律允许的里程费，金额为 \\$ 。\n\n本人的差旅费用为 \\$ ，服务费用为 \\$ ，合计为 \\$ 。\n\n本人在伪证处罚下声明，该等信息真实且正确。\n\n日期：\n\n送达人签名\n\n印刷姓名及职务\n\n送达人地址\n\n关于尝试送达等的补充信息：\n《联邦民事诉讼规则》Rule 45(c)、(d)、(e) 和 (g)（Effective 12/1/13（自 12/1/13 生效））（根据《联邦破产程序规则》Rule 9016 适用于破产案件）\n(c) 履行地点。\n\n(1) 审判、听证或证言记录。传票仅可按下列方式命令人员出席审判、听证或证言记录：\n\n(A) 在该人员居住、受雇或经常亲自从事商业活动地点的 100 英里范围内；或\n\n(B) 在该人员居住、受雇或经常亲自从事商业活动所在的州内，如该人员\n\n(i) 为当事人或当事人的高级职员；或\n\n(ii) 被命令出席审判且不会产生重大费用。\n\n(2) 其他证据开示。传票可以命令：\n\n(A) 在该人员居住、受雇或经常亲自从事商业活动地点的 100 英里范围内的地点提交文件、以电子方式存储的信息或物品；以及\n\n(B) 在应受查验的场所查验场所。\n(d) 对作为传票对象之人员的保护；执行。\n\n(1) 避免不当负担或费用；制裁。负责发出和送达传票的当事人或律师必须采取合理措施，避免对作为传票对象的人员施加不当负担或费用。要求履行的地区法院必须执行此项义务，并对未遵守者——当事人或律师——施加适当制裁，该制裁可包括损失的收入和合理的律师费。\n(2) 命令提交材料或允许查验。\n\n(A) 无需出席。被命令提交文件、以电子方式存储的信息或有形物品，或允许查验场所的人员，无需亲自到提交或查验地点出席，除非其还被命令出席证言记录、听证或审判。\n\n(B) 异议。被命令提交文件或有形物品，或允许查验的人员，可以向传票中指定的当事人或律师送达书面异议，反对查验、复制、测试或抽样任何或全部材料，或反对查验场所——或反对以所请求的一种或多种形式提交以电子方式存储的信息。异议必须在规定履行时间或传票送达后 14 天中较早者之前送达。如提出异议，则适用下列规则：\n\n(i) 经通知被命令人员后，送达方可在任何时候向要求履行的地区法院提出动议，请求作出强制提交或查验的命令。\n\n(ii) 仅可依照命令的指示要求实施该等行为，且该命令必须保护并非当事人或当事人高级职员的人员免于承担因履行而产生的重大费用。\n(3) 撤销或修改传票。\n\n(A) 必须撤销或修改的情形。经及时动议，要求履行的地区法院必须撤销或修改具有下列情形的传票：\n\n(i) 未给予合理的履行时间；\n\n(ii) 要求人员在 Rule 45(c) 规定的地理范围以外履行；\n\n(iii) 在不存在任何适用例外或豁免的情况下，要求披露享有特权或受其他保护的事项；或\n\n(iv) 对人员施加不当负担。\n\n(B) 可以撤销或修改的情形。为保护作为传票对象或受传票影响的人员，要求履行的地区法院可以经动议撤销或修改要求下列事项的传票：\n\n(i) 披露商业秘密或其他保密的研究、开发或商业信息；或\n\n(ii) 披露未受聘专家的意见或信息，该等意见或信息并非描述争议中的具体事件，且源于该专家并非应一方当事人请求而进行的研究。\n\n(C) 作为替代方案规定条件。在第45(d)(3)(B)条所述情形下，法院可以不撤销或修改传票，而是在规定条件下命令出庭或提交材料，前提是送达传票的一方：\n\n(i) 证明其对该证言或材料具有重大需求，且若不承受不当困难则无法以其他方式满足该需求；以及\n\n(ii) 确保被传唤人将获得合理报酬。\n(e) 回应传票的义务。\n\n(1) 提交文件或电子存储信息。以下程序适用于提交文件或电子存储信息：\n\n(A) 文件。回应要求提交文件的传票的人，必须按照其在通常业务过程中保存的方式提交文件，或者必须将文件整理并标注，以对应请求中的类别。\n\n(B) 未指定电子存储信息提交形式。如传票未指定电子存储信息的提交形式，回应人必须按其通常保存的一种或多种形式，或以合理可用的一种或多种形式提交。\n\n(C) 电子存储信息仅以一种形式提交。回应人无需以一种以上形式提交同一电子存储信息。\n\n(D) 不可访问的电子存储信息。回应人无需从其认定因不当负担或费用而无法合理访问的来源提供电子存储信息的证据开示。在强制证据开示动议或保护令动议中，回应人必须证明该信息因不当负担或费用而无法合理访问。如作出该证明，若请求方在考虑第26(b)(2)(C)条的限制后证明存在正当理由，法院仍可命令从该等来源进行证据开示。法院可以规定证据开示的条件。\n(2) 主张特权或保护。\n\n(A) 扣留的信息。以信息享有特权或作为审判准备材料受到保护为由扣留被传唤信息的人，必须：(i) 明确提出该主张；以及\n\n(ii) 在不披露本身享有特权或受保护的信息的情况下，以足以使各方当事人评估该主张的方式说明被扣留文件、通信或有形物品的性质。\n\n(B) 已提交的信息。如为回应传票而提交的信息被主张享有特权或作为审判准备材料受到保护，提出该主张的人可以将该主张及其依据通知任何收到该信息的当事人。收到通知后，当事人必须立即返还、隔离或销毁所指定的信息及其持有的任何副本；在该主张得到解决前不得使用或披露该信息；如该当事人在收到通知前已披露该信息，必须采取合理措施追回该信息；并可以立即将该信息密封提交给须履行传票的地区的法院，以裁定该主张。提交该信息的人必须在该主张得到解决前保存该信息。\n\n(g) 藐视法庭。在须履行传票的地区的法院——以及在动议移送后，签发传票的法院——可以认定已被送达但无充分理由不遵守传票或与之相关命令的人构成藐视法庭。\n\n有关查阅传票材料，请参见 Fed.R.Civ.P.45(a) 委员会说明（2013）\n\n…\n\n文件提交请求\nI. 指示\n\n1. 除非另有说明，下述文件请求（统称“请求”，单称“一项请求”）必须分别且具体地作出答复。每项请求均应得到完整答复，除非出于善意提出异议；如提出异议，应按如下规定详细说明阁下提出异议的理由。如异议仅涉及某项请求的一部分，或其中包含的某个词语、短语或条款，阁下仅须说明对该部分的异议，并对请求的其余部分作出答复。\n\n2. 电子存储信息必须按照以下指示提交：\n\na. 图像。黑白图像必须为300 DPI Group IV 单页 TIFF 文件。彩色图像必须以 JPEG 格式提交。文件名不得包含嵌入空格或特殊字符（包括逗号）。文件夹名称不得包含嵌入空格或特殊字符（包括逗号）。所有 TIFF 图像文件必须具有唯一文件名，即 Bates 编号。每张图像右下角必须加注连续的 Bates 编号。每个文件夹中的 TIFF 文件数量不得超过1000个文件。Excel 电子表格应具有以该文件的 Bates 编号命名的占位图像。\n\nb. 图像加载文件\n\na. Concordance® 数据文件。数据文件（.DAT）包含将加载至 Concordance® 数据库的所有字段信息。.DAT 文件的第一行必须为标识字段名称的标题行。.DAT 文件必须使用以下 Concordance® 默认分隔符：逗号 ASCII 字符（020）；引号 þ ASCII 字符（254）。日期字段应采用以下格式提供：mm/dd/yyyy。日期和时间字段必须为两个单独字段。如文件包括已成像的电子邮件及附件，必须包括附件字段，以保留电子邮件与其附件之间的父/子关系。必须包括 OCRPATH 字段，以提供所提交存储介质上提取文本文件的文件路径和名称。文本文件必须以 FIRSTBATES 命名。不得在 .DAT 文件中包含文本。对于含有原生文件的文件，必须包括 LINK 字段，以提供原生文件的文件路径和名称。原生文件必须以 FIRSTBATES 命名。\n\nb. Concordance Image® 或 Opticon 交叉引用文件。图像交叉引用文件（.LOG 或 .OPT）将图像链接至数据库记录。其应为逗号分隔文件，每行包含七个字段，数据库中的每个图像均应在交叉引用文件中有一行，格式如下：ImageID,VolumeLabel,ImageFilePath,DocumentBreak,FolderBreak,Box Break,PageCoun。\n\nc. 文件文本。文本必须作为单独的文本文件提交，而非作为 .DAT 文件中的字段。文本文件的完整路径（OCRPATH）应包括在 .DAT 文件中。建议提供按文件级别制作、以 FIRSTBATES/Image Key 命名的 ANSI 文本文件。提取的文本文件必须置于单独文件夹中，每个文件夹中的文本文件数量不得超过1,000个文件。文件夹名称中不得含有特殊字符（包括逗号）。文本文件必须按文件级别提供。\n\nd. 特定文件类型的原生提交。为充分理解其内容和含义而合理需要以原生格式查看的文件类型，必须以原生格式提交。该等文件包括但不限于电子表格、类似电子表格的文件（Microsoft Excel、逗号分隔值、制表符分隔值等）、Microsoft PowerPoint 或其他特殊演示文件、数据库文件以及音频/视频文件。应提供一张带有 Bates 编号的分隔页图像，以表明原生文件的存在，并将原生文件的路径作为字段列入 .dat 文件。提交的原生文件应以与该文件分隔页相对应的 Bates 编号命名。将原生文件归入按递增方式命名的“NATIVE”目录中，并与图像目录分开。\n\ne. 去重。对于存在完全重复件的每份电子文件，提交一份副本。对于电子邮件，应根据由 BCC、Body、CC、From、IntMsgID、To 和 Attach 属性生成的 MD5 哈希值合并重复件。对于电子邮件附件和独立电子文件，应根据整个文件的 MD5 哈希值合并重复件。\n\nf. 元数据。以符合 Concordance 标准的加载文件（.dat）形式提交每份文件提取的元数据。.DAT 文件的第一行必须为标识字段名称的标题行。.DAT 文件必须使用以下 Concordance 默认分隔符：逗号 , ASCII 字符（020）；引号 þ ASCII 字符（254）\n\n日期字段应采用以下格式提供：mm/dd/yyyy。日期和时间字段必须为两个单独字段。以下为所需元数据：\nCase 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 860 of 1063\n\n字段名称　示例数据　说明\n\nFIRSTBATES　EDC0000001　原生文件文件/电子邮件的第一个 Bates 编号\nLASTBATES　EDC0000001　原生文件文件/电子邮件的最后一个 Bates 编号\nLASTBATES 字段应针对单页予以填写\nATTACHRANGE　EDC0000001\n-　父文件第一页的 Bates 编号至最后一个附件“子”文件最后一页的 Bates 编号\nEDC0000015\nBEGATTACH　EDC0000001　附件范围的第一个 Bates 编号\nENDATTACH　EDC0000015　附件范围的最后一个 Bates 编号\nCUSTODIAN　Smith, John　电子邮件：电子邮件所在的邮箱\n原生文件：文件来源的个人或部门名称\nFROM　John Smith　电子邮件：发件人\n原生文件：文件作者\n多个条目应以分号分隔\nTO　Coffman, Janice; LeeW　收件人\n[mailto:LeeW@MSN.com]　多个条目应以分号分隔\nCC　Frank Thompson [mailto:　抄送收件人\nfrank_Thompson@cdt.com]　多个条目应以分号分隔\nBCC　John Cain　密送收件人\n多个条目应以分号分隔\nSUBJECT　Board Meeting Minutes　电子邮件：电子邮件主题行；原生文件：文件标题（如有）\nFILE_NAME　BoardMeetingMinutes.docx　原生文件：原始原生文件的名称，包括扩展名\nDATE_SENT　10/12/2010　电子邮件：电子邮件发送日期\n原生文件：（空）\nTIME_SENT/\nTIME_ZONE　07:05 PM GMT　电子邮件：电子邮件发送时间/电子邮件在其中被标准化的时区\nTIME_ZONE　GMT　在转换期间电子邮件被标准化所使用的时区。\nLINK　EDC0000001.msg　电子邮件或原生文件文件的超链接\n链接文件必须以 FIRSTBATES 编号命名\nFILE_EXTEN　MSG　代表电子邮件或文件的文件类型扩展名\nAUTHOR　John Smith　电子邮件：（空）\n原生文件：文件作者\nDATE_CREATED　10/10/2010　电子邮件：（空）\n原生文件：文件创建日期\nCase 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 861 of 1063\n\nTIME_CREATED　10:25 AM　电子邮件：（空）\n\n原生：文件创建时间\n该数据必须为独立字段，且不得与 DATE_CREATED 字段合并\nDATE_MOD　10/12/2010　电子邮件：（空）\n原生：文件最后修改日期\nTIME_MOD　07:00 PM　电子邮件：（空）\n原生：文件最后修改时间\n该数据必须为独立字段，且不得与 DATE_MOD 字段合并\nDATE_ACCESSD　10/12/2010　电子邮件：（空）\n原生：文件最后访问日期\nTIME_ACCESSD　07:00 PM　电子邮件：（空）\n原生：文件最后访问时间\n该数据必须为独立字段，且不得与 DATE_ACCESSD 字段合并\nFILE_SIZE　5,952　原生文件文件/电子邮件的大小（KB）\nPGCOUNT　1　原生文件文件/电子邮件的页数\nPATH　电子邮件：（空）\nAgenda.doc　原生：存储原生文件文件的路径，包括原始文件名。\nINTFILEPATH　Personal Folders\\Deleted Items\\Board Meeting Minutes.msg　电子邮件：电子邮件的原始位置，包括原始文件名。原生：（空）\nINTMSGID　<000805c2c71b\\$75977050\\$cb8306d1@MSN>　电子邮件：唯一消息 ID。原生：（空）\nMD5HASH　d131dd02c5e6eec4693d9a0698aff95c2fcab58712467eab4004583eb8fb7f89　文件的 MD5 哈希值。\nOCRPATH　TEXT/001/EDC0000001.txt　原生文件提取文本的路径\n\n3. 每项请求均独立适用并应独立解释；除非另有说明，任何请求均不限制其他任何请求的范围。\n\n4. 所有文件应按其在正常业务过程中保存的方式提供，或者应组织和标注，以对应本请求中的类别。\n\n5. 本文件所载的每项请求均延及所有文件：(a) 由您占有、保管或控制的文件；或 (b) 由代表您行事的任何人占有、保管或控制的文件，包括您的律师或其他代表及顾问。每份文件均应完整提供。\n\n案件 22-50073　文件 1592　提交于 03/24/23　录入于 03/24/23 10:57:37　第 862 页，共 1063 页\n\n6. 如要求您提供一份已不再由您占有、保管或控制的文件，则您的答复必须：(a) 详细说明该文件的性质及其内容；(b) 确认编制或撰写该文件的人员（及，如适用，该文件被发送至的人员）；(c) 确认该文件编制或创建的日期；(d) 说明该文件是否：(i) 遗失或丢失，(ii) 已被销毁，(iii) 已自愿或非自愿地转移给他人，或 (iv) 以其他方式处置；(e) 说明该等处置的原因，以及相关事实和情形；(f) 确认授权该等处置的人员；(g) 确认该等处置的日期或大致日期；(h) 说明该文件最近一次由您占有、保管或控制的时间；以及 (i) 确认目前占有、保管或控制该文件的人员（如有）。\n\n7. 如要求您提供一份已被销毁的文件，则除前述指示所要求的信息外，您的答复还必须说明：(a) 销毁该文件的原因；(b) 销毁该文件的人员身份；以及 (c) 指示销毁该文件的人员身份。\n\n8. 如您主张被请求的文件享有特权或属于律师工作成果，则您的答复必须：(a) 说明：(i) 足以支持您关于该文件享有特权之主张的文件描述，(ii) 文件标题，(iii) 文件日期，(iv) 文件作者，(v) 文件收件人，(vi) 收到或阅览过该文件原件或任何草稿、副本或复制件的每一人员身份，(vii) 该文件本身或文件中载明或提及的任何信息是否由其他任何人员占有、保管或控制；如是，确认该等人员身份，并说明该等信息如何进入其占有范围，(viii) 据以拒绝提供该文件的特权主张，以及 (ix) 您将赖以支持该等特权主张的所有情形；以及 (b) 就根据 D. Conn. L. Civ. R. 26(e) 基于特权主张而拒绝提供的每份文件，制作一份特权日志，其中载明本指示第 (a) 部分要求的全部信息。\n\n案件 22-50073　文件 1592　提交于 03/24/23　录入于 03/24/23 10:57:37　第 863 页，共 1063 页\n\n9. 如一份原本应当提供的文件的一部分含有受特权主张约束的信息，则仅应按照上述指示从该文件中删除或涂黑受特权主张约束的该部分，其余部分应予提供。\n\n10. 本请求具有持续性。现指示您：(a) 一旦知悉先前答复不完整或不正确，立即补充或更正任何后来发现不完整或不正确的答复；以及 (b) 提供根据以下规定所要求的任何补充文件。\n\n11. 如文件使用英语以外的语言，您应提供该文件。如文件使用英语以外的语言且存在英文译本，您应同时提供该两份文件。\n\n12. 对实体的所有提及均包括其所有关联方。\n\n13. 对个人姓名的所有提及均包括所有其他名称、别名或绰号。\n\n14. 除非另有明确说明，文件请求所涵盖的期间为自 February 5, 2012 起至文件请求答复到期之日止。\n\n案件 22-50073　文件 1592　提交于 03/24/23　录入于 03/24/23 10:57:37　第 864 页，共 1063 页\n\nII. 解释规则\n\n15. (a) 对任何单数名词的使用应解释为包括复数，反之亦然；及 (b) 对任何时态动词的使用应解释为使用该动词的所有其他时态。\n\n16. (a) “and”和“or”应在必要时解释为连词或析取词，以使本请求范围涵盖原本可能被解释为超出其范围的所有答复；及 (b) “each”和“any”应视为包括并涵盖“every”和“all”二词。\n\nIII. 定义\n\n经 D. Conn. Bankr. L.R. 2004-1(a) 纳入的 D. Conn. L. Civ. R. 26(c) 所提供的定义，以及 D. Conn. L. Civ. R. 26(d) 所提供的解释规则，适用于文件请求。此外，本文件请求中使用的下列术语具有下列含义：\n\n1. “您”或“您的”或“您本人”系指 Brent Petro Inc.（布伦特石油公司），连同其所有关联方、部门、机构、工具机构、处室、办事处、合伙人、高级职员、董事、代理人、律师、代表、雇员和／或代表其行事的任何人。\n\n2. “债务人”系指 Ho Wan Kwok（郭文贵）（又名 Miles Kwok、Miles Guo、Guo Wengui、Guo Haoyun、郭文贵，或任何其他别名），连同其雇员、代理人、律师、顾问或代表其行事的任何人。\n\n3. “债务人之子”系指 Qiang Guo（郭强）（又名 Mileson Kwok、郭强，或任何其他别名），连同其雇员、代理人、律师、顾问或代表其行事的任何人。\n\n案件 22-50073　文件 1592　提交于 03/24/23　录入于 03/24/23 10:57:37　第 865 页，共 1063 页\n\n4. “债务人之女”系指 Mei Guo（郭美）（又名 Mei Gui、郭美，或任何其他别名），连同其雇员、代理人、律师、顾问或代表其行事的任何人。\n\n5. “债务人所谓妻子”系指 Hing Chi Ngok（岳庆芝）（又名 Hing Chi Ng、Yue Qingzhi、岳庆芝，或任何其他别名），连同其雇员、代理人、律师、顾问或代表其行事的任何人。\n\n6. “债务人家属”统称债务人、债务人之子、债务人之女及债务人所谓妻子，以及与债务人具有任何其他亲属关系的人。\n\n7. “关联个人”单独及统称所有符合下列条件的个人：(1) 持有、控制、保管或对债务人或债务人家属拥有、控制或享有的资产拥有处置权；或 (2) 曾为一家或多家关联实体的雇员、董事或以其他方式与其关联者，连同前述任何人士各自的雇员、代理人、律师、顾问或代表其行事的任何人。该等关联个人包括但不限于：Daniel Podhaskie（丹尼尔·波达斯基）、Jason Miller（杰森·米勒）、Steve Bannon（史蒂夫·班农）、Karin Maistrello（卡琳·迈斯特雷洛）、Melissa Francis（梅丽莎·弗朗西斯）、Anthony DiBattista（安东尼·迪巴蒂斯塔）、William Gertz（威廉·格茨）、Arethusa Forsyth（阿瑞苏莎·福赛思）、Glenn Mellor（格伦·梅勒）、Jennifer Mercurio（珍妮弗·梅尔库里奥）、Eduardo Eurnekian（爱德华多·欧内基安）、Wencong Wang（王文聪）、Han Chunguang（韩春光）（又名 韩春光）、Qu Guojiao（屈国姣）（又名 Qu Guo Jiao、屈国姣）、Guo Lijie（郭丽杰）（又名 郭丽杰）、Zhang Wei（张伟）（又名 张伟\\*）、Lihong Wei Lafrenz（魏丽红·拉弗伦茨）（又名 Sara Wei、魏丽红）、Hao Haidong（郝海东）（又名 郝海东）、Ross Heinemeyer（罗斯·海内迈耶）、Max Krasner（马克斯·克拉斯纳）、Kyle Bass（凯尔·巴斯）、Melissa Mendez（梅丽莎·门德斯）、Ya Li（李娅）（又名 李娅）、Dinggang Wang（王定刚）（又名 王定刚）、An Hong（安红）（又名 安红）、Yvette Wang（王雁平）（又名 Yanping Wang、Yan Ping Wang、王雁平）、Fiona Yu（菲奥娜·余）、Je Kin Ming（余建明）（又名 William Je、Yu Jianming、余建明）、Yaz Qingua（亚兹·青瓜）及 Lao Jiang（姜云浮）（又名 Jiang Yunfu、Jiang Yunfu Be、姜云浮）。\n\n案件 22-50073　文件 1592　提交于 03/24/23　录入于 03/24/23 10:57:37　第 866 页，共 1063 页\n\n8. “关联实体”单独及统称所有符合下列条件的任何类型组织或实体：(1) 曾由债务人或债务人家属拥有、控制或投资；或 (2) 对债务人或债务人家属拥有、控制或享有的任何资产直接或间接享有权益，连同前述任何人士各自的雇员、代理人、律师、顾问或代表其行事的任何人。该等关联实体包括但不限于：7 Nod Hill LLC（7 Nod Hill 有限责任公司）、AAGV Limited（AAGV有限公司）、ACA Investment Management Limited（ACA投资管理有限公司）、ACA Capital Group Limited（ACA资本集团有限公司）、Ace Decade Holdings Limited（Ace Decade控股有限公司）、AI Group Holdings Inc.（AI集团控股公司）、Alfa Global Ventures Limited（Alfa全球风险投资有限公司）、Alfonso Global Limited（Alfonso全球有限公司）、Allied Capital Global Limited（Allied Capital全球有限公司）、Alpine Fiduciaries SA（Alpine受托公司）、Anton Development Limited（Anton开发有限公司）、Assets Sino Limited（Assets Sino有限公司）、Auspicious Coast Limited（Auspicious Coast有限公司）、Beijing Pangu Investment Co.（北京盘古投资公司）、Beijing Pangu Investment Co. Ltd.（北京盘古投资有限公司）、Beijing Pangu Investment Inc.（北京盘古投资股份有限公司）、Beijing Zenith Holdings Company Limited（北京Zenith控股有限公司）、Booming Sail New York LLC（Booming Sail纽约有限责任公司）、Bravo Luck Limited（Bravo Luck有限公司）、BSA Strategic Fund I（BSA战略基金I）、China Golden Spring (Hong Kong) Limited（中国金泉〈香港〉有限公司）、Chuang Xin Limited（创新有限公司）、Crane Advisory Group LLC（Crane咨询集团有限责任公司）、Creative Apex Investments Limited（Creative Apex投资有限公司）、Crystal Breeze Investments Limited（Crystal Breeze投资有限公司）、Dawn State Limited（Dawn State有限公司）、Eastern Profit Corporation Limited（Eastern Profit Corporation有限公司）、Elite Well Global Limited（Elite Well Global有限公司）、Empire Growth Holdings（Empire Growth控股）、Freedom Media Ventures Ltd.（Freedom Media Ventures有限公司）、G Club Operations LLC（G Club运营有限责任公司）、G Fashion LLC（G Fashion有限责任公司）、G News LLC（G News有限责任公司）、GETTR USA（GETTR美国）、Genever Holdings Corporation（Genever控股公司）、Genever Holdings LLC（Genever控股有限责任公司）、Gfashion Media Group Inc.（Gfashion媒体集团公司）、GFNY, Inc.（GFNY公司）、Globalist International Limited（Globalist International有限公司）、GNews Media Group Inc.（GNews媒体集团公司）、Golden Spring (New York) Ltd.（Golden Spring〈纽约〉有限公司）、Greenwich Land LLC（Greenwich Land有限责任公司）、Guo Media（Guo Media）、GTV Media Group, Inc.（GTV媒体集团公司）、Hamilton Capital Holdings Inc.（Hamilton Capital控股公司）、HCHK Property Management, Inc.（HCHK物业管理公司）、HCHK Technologies, Inc.（HCHK技术公司）、Head Win Group Limited（Head Win集团有限公司）、Henan Yuda（河南豫达）、Himalaya Embassy（喜马拉雅大使馆）、Himalaya Exchange（喜马拉雅交易所）、Himalaya Federal Reserve（喜马拉雅联邦储备）、Himalaya Investment LLC（喜马拉雅投资有限责任公司）、Himalaya International（喜马拉雅国际）、Himalaya New World Inc.（喜马拉雅新世界公司）、Himalaya Supervisory Organization（喜马拉雅监督组织）、Himalaya Ventures LLC（喜马拉雅风险投资有限责任公司）、HK International Funds Investments (USA) Limited LLC（HK International Funds Investments〈USA〉有限责任公司）、Hong Kong International Funds\n\n投资有限公司、Hudson Diamond Holding（哈德逊钻石控股）、Infinite Increase Limited（无限增长有限公司）、Infinitum Developments Limited（无限发展有限公司）、Infinity Treasury Management Inc.（无限财务管理公司）、Insight Phoenix Fund（洞察凤凰基金）、Lamp Capital LLC（兰普资本有限责任公司）、Leading Shine Limited（领耀有限公司）、Leading Shine NY Limited（领耀纽约有限公司）、Lexington Property and Staffing（列克星敦物业与人力服务）、Long Gate Limited（长龙门有限公司）、Maywind Trading LLC（五月风贸易有限责任公司）、MOS Himalaya LLC（MOS喜马拉雅有限责任公司）、Next Tycoon Investments Limited（下一大亨投资有限公司）、New Federal State of China（中国新联邦国家，亦称NFSC）、Noble Fame Global Limited（高贵名声环球有限公司）、Rosy Acme Ventures Limited（玫瑰顶点创投有限公司）、Rule of Law Foundation III, Inc.（法治基金会III公司）、Rule of Law Foundation IV, Inc.（法治基金会IV公司）、Rule of Law Fund（法治基金）、Rule of Law Society（法治协会）、Rule of Law Society IV, Inc.（法治协会IV公司）、G-Translators PTY LTD（G-翻译员有限公司）、Saraca Media Group, Inc.（娑罗媒体集团公司）、Shiny Ace Ltd.（闪耀王牌有限公司）、Shiny Times Holdings Ltd.（闪耀时代控股有限公司）、Spirit Charter Investment Limited（精神宪章投资有限公司）、Stevenson, Wong & Co.（史蒂文森、黄氏律师事务所）、Voice of Guo Media, Inc.（郭媒体之声公司）、Well Origin Ltd.（良好起源有限公司）、World Century Limited（世界世纪有限公司）、Worldwide Opportunity Holdings Limited（全球机遇控股有限公司）、Whitecroft Shore Limited（怀特克罗夫特海岸有限公司）以及ZIBA Limited（ZIBA有限公司）。\n\n9. “Including（包括）”或其任何变体，均指“包括但不限于”。\n\n10. “And（和）”及“or（或）”均指“和/或”，并应同时按合取及析取方式解释，以最大限度扩大其范围。\n\n11. “Any（任何）”、“all（全部）”及“each（每一）”均指“每一个及全部”。\n\n12. “Each（每一）”及“every（每一）”均指“每一个及全部”。\n\n13. “Third Party（第三方）”指除贵方以外的个人或实体。\n\n14. “Transfer（转让）”具有《破产法典》第101(54)条赋予该术语的含义。\n\n15. “Document（文件）”指属于Fed. R. Civ. P. 34范围内的任何信息或物品，包括但不限于贵方占有、保管或控制之中或曾在贵方占有、保管或控制之中的任何种类、类型、性质或描述的每一项书面、记录或图形材料，包括所有以电子形式保存的电子邮件、计算机文件的印刷件和电子副本。\n\n案件22-50073，文件1592，提交日期03/24/23，录入日期03/24/23 10:57:37，第868页，共1063页\n\n电子形式、电子通信、短信、社交媒体帖子、推文、元数据、通信函件、备忘录、磁带、速记或手写笔记、任何种类的书面表格、图表、蓝图、图纸、草图、曲线图、计划、文章、规格说明、日记、信函、电报、照片、会议记录、合同、协议、调查报告、计算机打印件、任何种类的数据汇编、电传、传真、语音留言、发票、订购单、支票、汇票、对账单、贷项通知单、报告、持仓报告、摘要、索引、书籍、账簿、笔记本、清单、透明胶片、录音、目录、广告、宣传材料、电影、录像带、录音带、CD、计算机磁盘、宣传册、小册子、穿孔卡、工时单、推文、社交媒体帖子或任何其他种类的书面或记录材料，以及其全部元数据，无论以何种方式存储（无论为有形或电子形式）、记录、制作或复制；还包括但不限于上述任何材料的草稿或副本，如其含有原始文件中未出现的任何种类的笔记、评论或标记，或在其他方面与原始文件不完全相同。\n\n16. “Person(s)（个人）”指个人、公司、独资企业、合伙企业、协会或任何其他实体。“Person（个人）”还包括任何代理人、代表或专家，包括但不限于律师或财务顾问。\n\n17. “Entity（实体）”指任何自然人、公司、合伙企业、子公司、独资企业、商号、董事会、合资企业、协会、机构、主管机关、委员会或其他商业实体或法人，以及任何关联方、代理人、母公司，包括但不限于法律顾问、财务顾问或任何其他代表。\n\n18. “Regarding（关于）”指涉及、描述、构成、提及、与之相关、支持、有利于、反对、强化、削弱、载于、在关联中予以考虑、与之有关、证明、表明、报告、记录、暗示、回应、\n\n案件22-50073，文件1592，提交日期03/24/23，录入日期03/24/23 10:57:37，第869页，共1063页\n\n与之相连、评论、就其而言、关于、与之有关、讨论、显示、描述、反映、分析、构成及属于。\n\n19. 在提及任何特定主题事项时，“Relating to（与……有关）”、“relate(s) to（与……有关）”或“related to（与……相关）”指包括但不限于构成、包含、涉及、含有、体现、反映、识别、陈述、直接或间接提及该特定主题事项，或以任何方式与所确定的特定主题事项相关的任何文件。\n\n20. “Communication(s)（通信）”在最广泛可能的意义上且不受限制地指任何信息或知识的传递（以事实、思想、询问或其他形式）。通信还指所有谈话、协议、询问或答复，无论是当面、通过电话、书面方式，还是通过电子传输设备进行，并包括但不限于所有通信函件、电子邮件、录音、传送单、备忘录、电话通信、语音留言、电报、传真、电传副本、电传、即时消息、聊天、短信、电话笔记，或在内部或与第三方之间传送的笔记。\n\n21. “Asset(s)（资产）”指任何可用于产生正面经济价值的项目，包括但不限于由某一实体拥有、控制或为该实体利益而持有的任何具有经济价值、预期能够提供未来利益的资源，包括但不限于所有不动产和动产、无形财产、投资、投资权或未来收入权、现金、银行账户、商品、证券、债权、对实体的全部或部分控制权，以及预期经济机会。\n\n22. “Transfer（转让）”具有《破产法典》第101(54)条赋予该术语的含义。\n\nIV. 应提交的文件\n\n1. 关于债务人、债务人财产或关联实体的任何收入或资产的全部文件。\n\n2. 与债务人的财务状况及其对债权人所负义务有关的全部文件，包括但不限于与为避免支付该等义务所作任何努力有关的全部文件，以及与本次或任何其他实际或可能的破产或类似无力偿债程序有关的全部文件。\n\n3. 关于与债务人、债务人财产、债务人家庭成员、关联实体或关联个人有关的任何资产负债表、银行对账单、账户对账单、财务报表、账户结单、电汇指示和/或确认、资金证明、存款证、持仓证明、投资组合摘要或类似文件的全部文件，包括但不限于足以显示向上述任何一方进行的全部转让的文件。\n\n4. 关于债务人作出、与债务人进行或代表债务人作出的任何投资、商业往来或交易的全部文件。\n\n5. 与债务人的全部通信，以及与债务人的通信有关、涉及任何实体运营、管理或决策的文件，包括但不限于关联实体。\n\n6. 关于向债务人、由债务人、与债务人、债务人家庭成员或关联实体进行的任何转让、投资或其他交易或商业往来的全部文件。\n\n7. 关于债务人曾经占用或使用的任何财产的全部文件，包括但不限于Lady May（梅夫人号）；Sherry Netherland Hotel / Condominium（谢里荷兰酒店/公寓）；位于康涅狄格州格林尼治373 Taconic Rd.的住宅物业；位于康涅狄格州格林尼治33 Ferncliff Rd.的住宅物业；以及位于康涅狄格州威尔顿354 Nod Hill Rd.的住宅物业。\n\n案件22-50073，文件1592，提交日期03/24/23，录入日期03/24/23 10:57:37，第871页，共1063页\n\n8. 与债务人拥有、控制或使用的任何飞机有关的全部文件，包括但不限于尾号为T7-GQM的飞机，以及在圣马力诺登记的任何其他飞机，包括但不限于所有登记文件副本以及显示该等飞机所执飞航班和该等航班机上人员的飞行清单。\n\n9. 关于向债务人、债务人财产、债务人家庭成员或关联实体提供、由其提供或代表其提供的任何赠与、利益或贷款的全部文件，包括但不限于足以显示该等赠与、利益或贷款金额；该等赠与、利益或贷款的用途；提供该等赠与、利益或贷款的时间；以及任何贷款的条款、就任何贷款作出的全部陈述与保证、任何贷款的利率及任何贷款付款的全部证据的文件。\n\n10. 关于由债务人、债务人财产、债务人家庭成员或关联实体设立、代表其设立或为其利益设立的任何信托或类似文书的全部文件，包括但不限于足以显示该等信托设立时间、设立人、为谁的利益而设立及信托财产的文件。\n\n11. 与涉及债务人的任何法律争议相关的任何义务、债权、责任或债务有关的全部文件，包括但不限于与在任何地方、州、联邦或国际机构前进行的任何诉讼有关的文件，无论该机构为行政机构、法院、合议庭或替代性争议解决实体。\n\n案件22-50073，文件1592，提交日期03/24/23，录入日期03/24/23 10:57:37，第872页，共1063页\n\n12. 贵方任何外部法律顾问或其他顾问与债务人之间的全部文件和通信。\n\n13. 足以显示贵方全部资产以及收入或资金来源的文件。\n\n14. 对于针对请求14所识别的、价值超过$50,000的全部资产，提供：(i) 与贵方取得该等资产有关的全部文件；以及(ii) 贵方与债务人或债务人家庭成员就该等资产进行的通信。\n\n15. 贵方纳税申报表的副本。\n\n16. 足以显示贵方占有或控制之内的全部银行账户及投资账户的文件，包括每一该等账户的余额以及向其和从其进行的转让。\n\n17. 关于贵方使用的任何信用卡的全部文件，包括但不限于月度对账单或足以显示为债务人或关联实体利益而进行的全部相关购买的其他文件。\n\n18. 全部公司治理及组织文件，包括但不限于公司章程细则、公司注册证书及足以显示贵方公司结构、高级职员及董事姓名、经营目的以及与债务人或债务人任何家庭成员关系的其他文件。\n\n19. 与贵方向任何其他实体质押任何资产有关的全部文件。\n\n附件C-48\n\nB2540（表格2540——规则2004审查传票）（12/15）案件22-50073，文件1592，提交日期03/24/23，录入日期03/24/23 10:57:37，第874页，共\n\nUNITED STATES BANKRUPTCY COURT（美国破产法院）\n\nDistrict of Connecticut（康涅狄格地区）\n\n关于HO WAN KWOK（郭文贵）等人案，\n\n1 案件编号22-50073 (JAM) 债务人 第11章\n\n（合并管理）\n\n规则2004审查传票\n\n致：Brent Petro Inc.（布伦特石油公司）\n\n（传票所指向人员的姓名）\n\n作证：特此命令贵方于下列规定的时间、日期和地点出席，并根据《联邦破产程序规则》第2004条接受审查并作证。随附一份授权进行该审查的法院命令副本。\n\n地点　日期和时间\n\nPaul Hastings LLP（普衡律师事务所）\n200 Park Avenue　[TBD]\nNew York, New York 10166（纽约州纽约市10166）\n\n审查将采用以下方式记录：法庭记录员/速记员\n\n提交：贵方或贵方代表还必须将下列文件、电子存储信息或物品携带至审查现场，并必须允许对该等材料进行检查、复制、测试或抽样：\n\n见随附的文件提交请求。\n\n以下 Fed. R. Civ. P. 45 的规定，依 Fed. R. Bankr. P. 9016 适用于破产案件，现随附如下：与履行地点有关的 Rule 45(c)；与您作为传票对象所受保护有关的 Rule 45(d)；以及与您答复本传票的义务及未履行该义务的潜在后果有关的 Rule 45(e) 和 45(g)。\n\n日期：March , 2023\n\n法院书记员\n\n或\n\n书记员或副书记员签名　律师签名\n\n签发或请求本传票的代表第11章受托人 Luc A. Despins 的律师的姓名、地址、电子邮箱地址和电话号码如下：\n\nDouglas S. Skalka, Esq.; Neubert, Pepe & Monteith, P.C.; 195 Church Street, New Haven, Connecticut 06510 dskalka@npmlaw.com; (203) 821-2000\n\n致签发或请求本传票之人的通知\n\n如本传票命令在审判前提交文件、电子存储信息或有形物品，或检查场所，则在向传票指向之人送达之前，必须向每一方当事人送达通知及本传票副本。Fed. R. Civ. P. 45(a)(4)。\n\n软件版权 (c) 1996-2022 Best Case, LLC - www.bestcase.com Best Case Bankruptcy 1 本第11章案件中的债务人为 Ho Wan Kwok（郭文贵）（又名 Guo Wengui、Miles Guo 和 Miles Kwok，以及众多其他别名）（税务识别号码后四位：9595）、Genever Holdings LLC（Genever Holdings有限责任公司）（税务识别号码后四位：8202）以及 Genever Holdings Corporation（Genever Holdings公司）。受托人、Genever Holdings LLC 和 Genever Holdings Corporation 的邮寄地址为 Paul Hastings LLP，200 Park Avenue, New York, NY 10166，转交 Luc A. Despins，作为 Ho Wan Kwok 破产财产的受托人（仅为通知和通信之目的）。\n\n送达证明\n\n（除非 Fed. R. Civ. P. 45 要求，否则本节不应向法院提交。）\n\n本人于（日期）收到为以下人员（个人姓名及职务，如有）发出的本传票： 。\n\n本人通过如下方式将副本交付给具名人员，以送达本传票：\n\n于（日期） ；或\n\n本人未执行即退还本传票，原因如下：\n\n除非本传票系代表美国或其官员或代理人签发，本人亦已向证人支付一日出席费用及法律允许的里程费用，金额为 $ 。\n\n本人差旅费用为 $ ，服务费用为 $ ，合计为 $ 。\n\n本人在伪证处罚的约束下声明，上述信息真实且正确。\n\n日期：\n\n送达人员签名\n\n正楷姓名及职务\n\n送达人员地址\n\n有关尝试送达等的补充信息：\n联邦民事诉讼规则 45(c)、(d)、(e) 和 (g)（Effective 12/1/13）（依《联邦破产程序规则》Rule 9016 适用于破产案件）\n\n(c) 履行地点。\n\n(1) 审判、听证或证言录取。传票仅可在下列地点命令某人出席审判、听证或证言录取：\n\n(A) 距该人居住地、工作地或经常亲自从事商业活动地点 100 英里以内；或\n\n(B) 在该人居住、工作或经常亲自从事商业活动所在州内，如该人\n\n(i) 为当事人或当事人的高级职员；或\n\n(ii) 被命令出席审判且不会产生重大费用。\n\n(2) 其他证据开示。传票可命令：\n\n(A) 在距该人居住地、工作地或经常亲自从事商业活动地点 100 英里以内的地点提交文件、电子存储信息或物品；以及\n\n(B) 在待检查的场所检查场所。\n\n(d) 对传票对象的保护；执行。\n\n(1) 避免不当负担或费用；制裁。负责签发和送达传票的当事人或律师必须采取合理措施，避免对传票对象施加不当负担或费用。要求履行的地区法院必须执行该义务，并对未遵守者的当事人或律师施加适当制裁，其中可包括损失的收入和合理的律师费。\n\n(2) 命令提交材料或准许检查。\n\n(A) 无须出庭。被命令提交文件、电子存储信息或有形物品，或准许检查场所的人，无须亲自到提交或检查地点出席，除非同时被命令出席证言录取、听证或审判。\n\n(B) 异议。被命令提交文件或有形物品，或准许检查的人，可以就检查、复制、测试或抽样全部或部分材料，或检查场所，或以所请求的一种或多种形式提交电子存储信息，向传票中指定的当事人或律师送达书面异议。异议必须在规定履行时间或传票送达后 14 日届满两者中较早者之前送达。如提出异议，适用以下规则：\n\n(i) 在任何时候，送达方通知被命令之人后，可向要求履行的地区法院申请强制提交或检查的命令。\n\n(ii) 仅可依命令指示要求实施上述行为，且该命令必须保护既非当事人亦非当事人高级职员之人，免受因履行而产生的重大费用。\n\n(3) 撤销或修改传票。\n\n(A) 必须撤销或修改的情形。经及时动议，要求履行的地区法院必须撤销或修改具有下列情形的传票：\n\n(i) 未给予合理的履行时间；\n\n(ii) 要求某人在 Rule 45(c) 规定的地理范围之外履行；\n\n(iii) 如不存在适用的例外或豁免，要求披露享有特权或以其他方式受保护的事项；或\n\n(iv) 对某人造成不当负担。\n\n(B) 可撤销或修改的情形。为保护传票对象或受传票影响之人，要求履行的地区法院可经动议撤销或修改要求下列事项的传票：\n\n(i) 披露商业秘密或其他保密的研究、开发或商业信息；或\n\n(ii) 披露未受聘专家的意见或信息，该等意见或信息并非描述争议中的具体事件，且系该专家未应任何一方当事人请求所进行研究的结果。\n\n(C) 作为替代方案规定条件。在 Rule 45(d)(3)(B) 所述情形下，如送达方：\n\n(i) 证明对该证言或材料存在重大需要，且如不承受不当困难则无法以其他方式满足该需要；并且\n\n(ii) 确保被传唤之人将获得合理补偿，\n\n法院可不撤销或修改传票，而命令在规定条件下出席或提交。\n\n(e) 答复传票的义务。\n\n(1) 提交文件或电子存储信息。下列程序适用于提交文件或电子存储信息：\n\n(A) 文件。答复提交文件传票之人，必须按文件在正常业务过程中保存的方式提交，或者必须依照要求中的类别对文件进行整理和标记。\n\n(B) 未规定电子存储信息的提交形式。如传票未规定提交电子存储信息的形式，答复之人必须以其通常保存的一种或多种形式，或以一种或多种合理可用的形式提交。\n\n(C) 电子存储信息仅以一种形式提交。答复之人无须以一种以上形式提交相同的电子存储信息。\n\n(D) 无法合理访问的电子存储信息。答复之人无须就其认定因不当负担或费用而无法合理访问的来源中的电子存储信息提供证据开示。就强制证据开示或保护令提出动议时，答复之人必须证明该信息因不当负担或费用而无法合理访问。如作出该证明，若请求方在考虑 Rule 26(b)(2)(C) 的限制后证明存在正当理由，法院仍可命令对该等来源进行证据开示。法院可对该证据开示规定条件。\n\n(2) 主张特权或保护。\n\n(A) 被扣留的信息。以信息享有特权或作为审判准备材料受到保护为由扣留被传唤信息之人，必须：(i) 明确提出该主张；以及\n\n(ii) 以一种在不披露本身享有特权或受保护信息的情况下，使各方当事人能够评估该主张的方式，说明被扣留文件、通信或有形物品的性质。\n\n(B) 已提交的信息。如为答复传票而提交的信息受特权主张或作为审判准备材料受保护的主张约束，提出该主张之人可将该主张及其依据通知收到该信息的任何当事人。收到通知后，当事人必须迅速返还、隔离或销毁所指明的信息及其持有的任何副本；在该主张得到解决前不得使用或披露该信息；如该当事人在收到通知前已披露该信息，必须采取合理措施予以追回；并可迅速将该信息密封提交至要求履行的地区法院，以裁定该主张。提交该信息之人必须保存该信息，直至该主张得到解决。\n\n(g) 藐视法庭。要求履行的地区法院——以及在动议被移送后，签发传票的法院——可认定已被送达但无充分理由不遵守传票或相关命令之人构成藐视法庭。\n\n有关获取传票材料，请参见 Fed.R.Civ.P.45(a) Committee Note (2013)\n\n……\n\n文件提交请求\n\nI. 指示\n\n1. 除非另有说明，下列文件请求（以下简称“请求”，各项称为“一项请求”）必须分别且具体地予以答复。除非基于善意提出异议，否则必须完整答复每项请求；如提出异议，则必须按照下文规定详细说明贵方异议的理由。如异议仅涉及一项请求的一部分，或其中所含的某一词语、短语或条款，贵方仅须说明对该部分的异议，并答复请求的其余部分。\n\n2. 电子存储信息必须依照以下指示提交：\n\na. 图像。黑白图像必须为 300 DPI Group IV 单页 TIFF 文件。彩色图像必须以 JPEG 格式制作。文件名不得包含嵌入空格或特殊字符（包括逗号）。文件夹名称不得包含嵌入空格或特殊字符（包括逗号）。所有 TIFF 图像文件必须具有唯一文件名，即 Bates 编号。图像必须在每张图像右下角标注连续的 Bates 编号。每个文件夹中的 TIFF 文件数量不得超过 1000 个文件。Excel 电子表格应具有以该文件的 Bates 编号命名的占位图像。\n\nb. 图像加载文件\n\na. Concordance® 数据文件。数据文件（.DAT）包含将被加载至 Concordance® 数据库的所有字段信息。.DAT 文件的第一行必须为标识字段名称的标题行。.DAT 文件必须使用以下 Concordance® 默认分隔符：逗号 ASCII 字符（020）引号 þ ASCII 字符（254）。日期字段应以 mm/dd/yyyy 格式提供。日期和时间字段必须为两个独立字段。如文件包括已成像的电子邮件及附件，则必须包括附件字段，以保留电子邮件与其附件之间的父项/子项关系。必须包括 OCRPATH 字段，以提供所提取文本文件在所交付存储介质上的文件路径和名称。文本文件必须以 FIRSTBATES 命名。不得在 .DAT 文件中包含文本。对于含有原生文件的文件，必须包括 LINK 字段，以提供原生文件的文件路径和名称。原生文件必须以 FIRSTBATES 命名。\n\nb. Concordance Image® 或 Opticon 交叉引用文件。图像交叉引用文件（.LOG 或 .OPT）将图像与数据库记录相链接。其应为以逗号分隔的文件，每行由七个字段组成；数据库中的每张图像均应在交叉引用文件中具有一行，格式如下：ImageID,VolumeLabel,ImageFilePath,DocumentBreak,FolderBreak,Box Break,PageCoun。\n\nc. 文件文本。文本必须作为独立的文本文件交付，而非作为 .DAT 文件内的字段。文本文件的完整路径（OCRPATH）应包含在 .DAT 文件中。建议使用按 FIRSTBATES/Image Key 命名的文件级 ANSI 文本文件。提取的文本文件必须置于单独文件夹中，每个文件夹中的文本文件数量不得超过 1,000 个文件。文件夹名称中不得含有特殊字符（包括逗号）。文本文件必须按文件级别提供。\n\nd. 特定文件类型的原生格式交付。为充分理解其内容和含义而合理需要以原生格式查看的文件类型，必须以原生格式交付。该等文件包括但不限于电子表格、类电子表格文件（Microsoft Excel、逗号分隔值、制表符分隔值等）、Microsoft PowerPoint 或其他特殊演示文件、数据库文件以及音频/视频文件。提供一张带有 Bates 编号的提示页图像，以指明原生文件的存在，并在 .dat 文件中将原生文件的路径作为字段列入。所交付的原生文件应以与该文件提示页相对应的 Bates 编号命名。将原生文件归入按递增方式命名的“NATIVE”目录中，并与图像目录分开。\n\ne. 去重。对于存在完全重复件的每一电子文件，仅交付一份。对于电子邮件，根据由 BCC、Body、CC、From、IntMsgID、To 和 Attach 属性生成的 MD5 哈希值合并重复件。对于电子邮件附件和独立电子文件，根据整个文件的 MD5 哈希值合并重复件。\n\nf. 元数据。以符合 Concordance 要求的加载文件（.dat）形式，为每份文件交付提取的元数据。.DAT 文件的第一行必须为标识字段名称的标题行。.DAT 文件必须使用以下 Concordance 默认分隔符：逗号 , ASCII 字符（020）引号 þ ASCII 字符（254）\n\n日期字段应以 mm/dd/yyyy 格式提供。日期和时间字段必须为两个独立字段。以下所列为必需元数据：\n\nCase 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 879 of 1063\n\n字段名称　示例数据　说明\n\nFIRSTBATES　EDC0000001　原生文件文件/电子邮件的首个 Bates 编号\n\nLASTBATES　EDC0000001　原生文件文件/电子邮件的最后一个 Bates 编号\n\n对于单页文件，应填写 LASTBATES 字段\n\nATTACHRANGE　EDC0000001\n-　父项文件第一页的 Bates 编号至最后一个附件“子项”文件最后一页的 Bates 编号\nEDC0000015\n\nBEGATTACH　EDC0000001　附件范围的首个 Bates 编号\n\nENDATTACH　EDC0000015　附件范围的最后一个 Bates 编号\n\nCUSTODIAN　Smith, John（约翰·史密斯）　电子邮件：电子邮件所在的邮箱\n原生文件：文件来源的个人或部门名称\n\nFROM　John Smith（约翰·史密斯）　电子邮件：发件人\n原生文件：文件作者\n多个条目之间应使用分号分隔\n\nTO　Coffman, Janice（贾尼斯·科夫曼）; LeeW\n[mailto:LeeW@MSN.com]　收件人\n多个条目之间应使用分号分隔\n\nCC　Frank Thompson（弗兰克·汤普森） [mailto:\nfrank_Thompson@cdt.com]　抄送收件人\n多个条目之间应使用分号分隔\n\nBCC　John Cain（约翰·凯恩）　密送收件人\n多个条目之间应使用分号分隔\n\nSUBJECT　Board Meeting Minutes　电子邮件：电子邮件主题行 原生文件：文件标题（如有）\n\nFILE_NAME　BoardMeetingMinutes.docx　原生文件：原始原生文件的名称，包括扩展名\n\nDATE_SENT　10/12/2010　电子邮件：电子邮件发送日期\n原生文件：（空）\n\nTIME_SENT/\nTIME_ZONE　07:05 PM GMT　电子邮件：电子邮件发送时间/电子邮件在其中被标准化的时区\n\nTIME_ZONE　GMT　电子邮件在转换过程中被标准化所采用的时区。\n\nLINK　EDC0000001.msg　电子邮件或原生文件文件的超链接\n所链接的文件必须按 FIRSTBATES 编号命名\n\nFILE_EXTEN　MSG　代表电子邮件或原生文件的文件类型扩展名\n\nAUTHOR　John Smith（约翰·史密斯）　电子邮件：（空）\n原生文件：文件作者\n\nDATE_CREATED　10/10/2010　电子邮件：（空）\n原生文件：文件创建日期\n\nCase 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 880 of 1063\n\nTIME_CREATED　10:25 AM　电子邮件：（空）\n原生文件：文件创建时间\n该数据必须为独立字段，不得与 DATE_CREATED 字段合并\n\nDATE_MOD　10/12/2010　电子邮件：（空）\n原生文件：文件最后修改日期\n\nTIME_MOD　07:00 PM　电子邮件：（空）\n原生文件：文件最后修改时间\n该数据必须为独立字段，不得与 DATE_MOD 字段合并\n\nDATE_ACCESSD　10/12/2010　电子邮件：（空）\n原生文件：最后访问该文件的日期\n\nTIME_ACCESSD　07:00 PM　电子邮件：（空）\n原生文件：最后访问该文件的时间\n该数据必须为独立字段，不得与 DATE_ACCESSD 字段合并\n\nFILE_SIZE　5,952　原生文件文件/电子邮件的大小，单位为 KB\n\nPGCOUNT　1　原生文件文件/电子邮件中的页数\n\nPATH　电子邮件：（空）\nAgenda.doc　原生文件：存储原生文件文件的路径，包括原始文件名称。\n\nINTFILEPATH　Personal Folders\\Deleted\nItems\\Board Meeting\nMinutes.msg　电子邮件：电子邮件的原始位置，包括原始文件名称。\n原生文件：（空）\n\nINTMSGID　<000805c2c71b\\$75977050\\$\ncb8306d1@MSN>　电子邮件：唯一消息 ID 原生文件：（空）\n\nMD5HASH　d131dd02c5e6eec4693d9a0\n698aff95c\n2fcab58712467eab4004583e\nb8fb7f89　文件的 MD5 哈希值。\n\nOCRPATH　TEXT/001/EDC0000001.txt　原生文件提取文本的路径\n\n3. 每项请求独立运作并应独立解释，除非另有说明，任何请求均不限制任何其他请求的范围。\n\n4. 所有文件均应按其在通常业务过程中保存的方式交付，或应进行组织和标注，以对应本请求中的类别。\n\n5. 本文所载每项请求均延及所有文件：（a）在贵方拥有、保管或控制之下的文件；或（b）在任何代表贵方行事之人拥有、保管或控制之下的文件，\n\nCase 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 881 of 1063\n\n包括贵方的律师或其他代表和顾问。每份文件均应完整交付。\n\n6. 如要求贵方交付一份已不再由贵方拥有、保管或控制的文件，则贵方的答复必须：（a）详细说明该文件的性质及其内容；（b）确定编制或撰写该文件的人员（以及，如适用，确定该文件被发送给的人员）；（c）确定该文件编制或创建的日期；（d）说明该文件是否（i）遗失或丢失，（ii）已被毁灭，（iii）已自愿或非自愿地转移给他人，或（iv）已以其他方式处置；（e）说明该等处置的理由，以及围绕该等处置的事实和情形；（f）确定授权该等处置的人员；（g）确定该等处置的日期或大致日期；（h）说明该文件最近一次处于贵方拥有、保管或控制之下的时间；以及（i）确定目前拥有、保管或控制该文件的人员（如有）。\n\n7. 如要求贵方交付一份已被毁灭的文件，则除前述指示所要求的信息外，贵方的答复还必须说明：（a）该文件被毁灭的理由；（b）毁灭该文件的人员身份；以及（c）指示毁灭该文件的人员身份。\n\n8. 如贵方主张所请求的文件享有特权或属于律师工作成果，则贵方的答复必须：（a）说明（i）足以支持贵方关于该文件享有特权之主张的文件描述，（ii）文件标题，（iii）文件日期，（iv）文件作者，（v）文件收件人，（vi）收到或阅览该文件原件或任何草稿、副本或复制件的每一人员身份，（vii）该文件本身或该文件所载或提及的任何信息是否由任何其他人员拥有、保管或控制；如是，则确定该等人员身份，并说明该等信息如何进入其拥有、保管或控制之下，（viii）据以扣留该文件的特权主张，以及（ix）贵方将赖以支持该等特权主张的所有情形；以及（b）根据 D. Conn. L. Civ. R. 26(e)，就基于特权主张而被扣留的每份文件，制作一份包含本指示第（a）部分所要求全部信息的特权日志。\n\nCase 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 882 of 1063\n\n9. 如一份在其他方面应予提供的文件的一部分包含受特权主张约束的信息，则仅应按照上述指示从该文件中删除或遮蔽受该特权主张约束的部分，其余部分应予交付。\n\n10. 各项请求具有持续性。特此指示贵方：（a）一旦得知先前答复不完整或不正确，立即补充或更正任何后来发现不完整或不正确的答复；以及（b）交付根据该等项下所要求的任何额外文件。\n\n11. 如文件使用英语以外的语言，贵方应提供该文件。如文件使用英语以外的语言且存在英文译本，贵方应同时提供两份文件。\n\n12. 对实体的所有提及均包括其所有关联方。\n\n13. 对个人姓名的所有提及均包括所有替代姓名、别名或昵称。\n\n14. 除非另有明确说明，文件请求所涵盖的期间为自 February 5, 2012 起至对文件请求作出答复的到期日止。\n\nCase 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 883 of 1063\n\n二、解释规则\n\n15. (a) 任何单数名词的使用应解释为包括复数，反之亦然；以及 (b) 任何时态动词的使用应解释为使用该动词的所有其他时态。\n\n16. (a) “和”及“或”应视为必要时以连词或选择连词方式解释，以便将原本可能被解释为不在任何请求范围内的所有答复纳入该请求范围；以及 (b) “每一”及“任何”应视为包括并涵盖“每个”及“所有”一词。\n\n三、定义\n\n经 D. Conn. Bankr. L.R. 2004-1(a) 纳入的 D. Conn. L. Civ. R. 26(c) 所规定的定义，以及 D. Conn. L. Civ. R. 26(d) 所规定的解释规则，适用于文件请求。此外，本文件请求中使用的下列术语具有如下含义：\n\n1. “您”或“您的”或“您本人”系指 Sirius Networking Inc.（天狼星网络公司），连同其所有关联方、部门、机构、办事机构、职能部门、办公室、合伙人、高级管理人员、董事、代理人、律师、代表、雇员及／或任何代表其行事的人。\n\n2. “债务人”系指 Ho Wan Kwok（郭文贵；又名 Miles Kwok、Miles Guo、Guo Wengui、Guo Haoyun、郭文贵或任何其他别名），连同其雇员、代理人、律师、顾问或任何代表其行事的人。\n\n3. “债务人之子”系指 Qiang Guo（郭强；又名 Mileson Kwok、郭强或任何其他别名），连同其雇员、代理人、律师、顾问或任何代表其行事的人。\n\nCase 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 884 of 1063\n\n4. “债务人之女”系指 Mei Guo（郭美；又名 Mei Gui、郭美或任何其他别名），连同其雇员、代理人、律师、顾问或任何代表其行事的人。\n\n5. “债务人之据称妻子”系指 Hing Chi Ngok（岳庆芝；又名 Hing Chi Ng、Yue Qingzhi、岳庆芝或任何其他别名），连同其雇员、代理人、律师、顾问或任何代表其行事的人。\n\n6. “债务人家属”统称债务人、债务人之子、债务人之女及债务人之据称妻子，以及与债务人存在任何其他家庭关系的人。\n\n7. “关联个人”单独及共同系指以下所有个人：(1) 持有、控制、保管或对债务人或债务人家属拥有、控制或享有的资产具有处置权；或 (2) 曾为一个或多个关联实体的雇员、董事，或以其他方式与之关联；连同前述各方各自的雇员、代理人、律师、顾问或任何代表前述任何一方行事的人。该等关联个人包括但不限于：Daniel Podhaskie（丹尼尔·波达斯基）、Jason Miller（杰森·米勒）、Steve Bannon（史蒂夫·班农）、Karin Maistrello（卡琳·迈斯特雷洛）、Melissa Francis（梅利莎·弗朗西斯）、Anthony DiBattista（安东尼·迪巴蒂斯塔）、William Gertz（威廉·格茨）、Arethusa Forsyth（阿瑞苏萨·福赛斯）、Glenn Mellor（格伦·梅勒）、Jennifer Mercurio（詹妮弗·梅尔库里奥）、Eduardo Eurnekian（爱德华多·厄尔内基安）、Wencong Wang（王文聪）、Han Chunguang（韩春光；又名 韩春光）、Qu Guojiao（屈国姣；又名 Qu Guo Jiao、屈国姣）、Guo Lijie（郭丽杰；又名 郭丽杰）、Zhang Wei（张伟；又名 张伟\\*）、Lihong Wei Lafrenz（魏丽红；又名 Sara Wei、魏丽红）、Hao Haidong（郝海东；又名 郝海东）、Ross Heinemeyer（罗斯·海内迈耶）、Max Krasner（马克斯·克拉斯纳）、Kyle Bass（凯尔·巴斯）、Melissa Mendez（梅利莎·门德斯）、Ya Li（李娅；又名 李娅）、Dinggang Wang（王定刚；又名 王定刚）、An Hong（安红；又名 安红）、Yvette Wang（王雁平；又名 Yanping Wang、Yan Ping Wang、王雁平）、Fiona Yu（菲奥娜·于）、Je Kin Ming（余建明；又名 William Je、Yu Jianming、余建明）、Yaz Qingua（亚兹·钦瓜）及 Lao Jiang（姜云浮；又名 Jiang Yunfu、Jiang Yunfu Be、姜云浮）。\n\nCase 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 885 of 1063\n\n8. “关联实体”单独及共同系指以下所有任何类型的组织或实体：(1) 曾由债务人或债务人家属拥有、控制或投资；或 (2) 对债务人或债务人家属拥有、控制或享有的任何资产直接或间接享有权益；连同前述各方各自的雇员、代理人、律师、顾问或任何代表前述任何一方行事的人。该等关联实体包括但不限于：7 Nod Hill LLC、AAGV Limited、ACA Investment Management Limited、ACA Capital Group Limited、Ace Decade Holdings Limited、AI Group Holdings Inc.、Alfa Global Ventures Limited、Alfonso Global Limited、Allied Capital Global Limited、Alpine Fiduciaries SA、Anton Development Limited、Assets Sino Limited、Auspicious Coast Limited、Beijing Pangu Investment Co.、Beijing Pangu Investment Co. Ltd.、Beijing Pangu Investment Inc.、Beijing Zenith Holdings Company Limited、Booming Sail New York LLC、Bravo Luck Limited、BSA Strategic Fund I、China Golden Spring (Hong Kong) Limited、Chuang Xin Limited、Crane Advisory Group LLC、Creative Apex Investments Limited、Crystal Breeze Investments Limited、Dawn State Limited、Eastern Profit Corporation Limited、Elite Well Global Limited、Empire Growth Holdings、Freedom Media Ventures Ltd.、G Club Operations LLC、G Fashion LLC、G News LLC、GETTR USA、Genever Holdings Corporation、Genever Holdings LLC、Gfashion Media Group Inc.、GFNY, Inc.、Globalist International Limited、GNews Media Group Inc.、Golden Spring (New York) Ltd.、Greenwich Land LLC、Guo Media、GTV Media Group, Inc.、Hamilton Capital Holdings Inc.、HCHK Property Management, Inc.、HCHK Technologies, Inc.、Head Win Group Limited、Henan Yuda、Himalaya Embassy、Himalaya Exchange、Himalaya Federal Reserve、Himalaya Investment LLC、Himalaya International、Himalaya New World Inc.、Himalaya Supervisory Organization、Himalaya Ventures LLC、HK International Funds Investments (USA) Limited LLC、Hong Kong International Funds\n\nCase 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 886 of 1063\n\nInvestments Limited、Hudson Diamond Holding、Infinite Increase Limited、Infinitum Developments Limited、Infinity Treasury Management Inc.、Insight Phoenix Fund、Lamp Capital LLC、Leading Shine Limited、Leading Shine NY Limited、Lexington Property and Staffing、Long Gate Limited、Maywind Trading LLC、MOS Himalaya LLC、Next Tycoon Investments Limited、New Federal State of China（新中国联邦；又名 NFSC）、Noble Fame Global Limited、Rosy Acme Ventures Limited、Rule of Law Foundation III, Inc.、Rule of Law Foundation IV, Inc.、Rule of Law Fund、Rule of Law Society、Rule of Law Society IV, Inc.、G-Translators PTY LTD、Saraca Media Group, Inc.、Shiny Ace Ltd.、Shiny Times Holdings Ltd.、Spirit Charter Investment Limited、Stevenson, Wong & Co.、Voice of Guo Media, Inc.、Well Origin Ltd.、World Century Limited、Worldwide Opportunity Holdings Limited、Whitecroft Shore Limited及 ZIBA Limited。\n\n9. “包括”或其任何变体，系指“包括但不限于”。\n\n10. “和”及“或”系指“和／或”，并应为最大限度扩大其范围而同时作连词及选择连词解释。\n\n11. “任何”、“所有”及“每一”系指“每一个”。\n\n12. “每一”及“每个”系指“每一个”。\n\n13. “第三方”系指您本人以外的个人或实体。\n\n14. “转让”具有《破产法典》第 101(54) 条赋予该词的含义。\n\n15. “文件”系指 Fed. R. Civ. P. 34 范围内的任何信息或物品，并包括但不限于任何种类、类型、性质或描述的每一项书面、记录或图形资料，只要该等资料现由或曾由您占有、保管或控制，包括电子邮件的所有打印及电子副本、以电子形式保存的计算机文件、\n\nCase 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 887 of 1063\n\n电子通信、短信、社交媒体帖子、推文、元数据、通信函件、备忘录、磁带、速记或手写笔记、任何种类的书面表格、图表、蓝图、图纸、草图、图形、计划、文章、规格、日记、信函、电报、照片、会议记录、合同、协议、调查资料、计算机打印件、任何种类的数据汇编、电传、电传传真、语音留言、发票、订单、支票、汇票、对账单、贷项通知单、报告、持仓报告、摘要、索引、书籍、总账、笔记本、明细表、透明胶片、录音、目录、广告、宣传材料、影片、录像带、录音带、CD、计算机磁盘、宣传册、传单、穿孔卡、工时单、推文、社交媒体帖子或任何其他种类的书面或记录材料，以及其所有元数据；无论以何种方式存储（无论为有形形式或电子形式）、记录、制作或复制；并且还包括但不限于前述任何文件的草稿或副本，如其包含原始文件中未有的任何种类笔记、评论或标记，或在其他方面与原始文件不相同。\n\n16. “个人”系指个人、公司、独资企业、合伙企业、协会或任何其他实体。“个人”还包括任何代理人、代表或专家，包括但不限于律师或财务顾问。\n\n17. “实体”系指任何自然人、公司、合伙企业、子公司、独资企业、商号、董事会、合资企业、协会、机构、主管机关、委员会或其他商业实体或法人，以及任何关联方、代理人、母公司，包括但不限于法律顾问、财务顾问或任何其他代表。\n\n18. “关于”系指涉及、描述、构成、提及、与之相关、支持、有利于、反对、加强、削弱、位于其中、结合其加以考虑、对其有影响、证明、表明、报告、记录、暗示、答复、\n\nCase 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 888 of 1063\n\n与之连接、评论、就其而言、关于、与之有关、讨论、显示、描述、反映、分析、构成及属于。\n\n19. 在提及任何特定事项时，“与……有关”、“涉及”或“相关”系指但不限于任何构成、包含、涉及、含有、体现、反映、识别、陈述、直接或间接提及，或以任何方式与所识别的特定事项相关的文件。\n\n20. “通信”在最广泛可能的意义上且不限于此，系指任何信息或知识的传递（以事实、观点、询问或其他形式）。通信还系指所有谈话、协议、询问或答复，无论系当面、通过电话、书面方式，或通过电子传输设备进行，并包括但不限于所有函件、电子邮件、录音、传送单、备忘录、电话通信、语音留言、电报、传真、电传副本、电传、即时消息、聊天、短信、电话笔记，或在内部或与第三方传递的笔记。\n\n21. “资产”系指可用于产生正向经济价值的任何项目，包括但不限于由实体拥有、控制或为实体利益而持有的任何具有经济价值并预期提供未来利益的资源，包括但不限于所有不动产和动产、无形财产、投资、投资权利或未来收入权利、现金、银行账户、商品、证券、债权、对实体的全部或部分控制权及预期经济机会。\n\n22. “转让”具有《破产法典》第 101(54) 条赋予该词的含义。\n\n四、应提交的文件\n\n1. 关于债务人、债务人财产或关联实体的任何收入或资产的所有文件。\n\n2. 与债务人的财务状况及其对债权人的义务有关的所有文件，包括但不限于与任何试图避免支付该等义务的行为有关的所有文件，以及与本破产程序或任何其他实际或潜在破产或类似无力偿债程序有关的所有文件。\n\n3. 关于与债务人、债务人破产财产、债务人家属、关联实体或关联个人有关的任何资产负债表、银行对账单、账户对账单、财务报表、账户报表、电汇指示和/或确认、资金证明、存款证明、持仓证明、投资组合摘要或类似文件的所有文件，包括但不限于足以显示向前述任何一方进行的所有转移的所有文件。\n\n4. 关于债务人作出、与债务人进行或代表债务人作出的任何投资、业务往来或交易的所有文件。\n\n5. 与债务人之间的所有通信，以及与债务人之间通信有关的文件，涉及任何实体的运营、管理或决策，包括但不限于关联实体。\n\n6. 关于向债务人、债务人家属或关联实体进行、由其进行或与其进行的任何转移、投资或其他交易或业务往来的所有文件。\n\n7. 关于债务人曾占用或使用的任何财产的所有文件，包括但不限于Lady May（“梅夫人”号）；Sherry Netherland Hotel / Condominium（谢里-尼德兰酒店/公寓）；位于康涅狄格州格林尼治373 Taconic Rd.的住宅物业；位于康涅狄格州格林尼治33 Ferncliff Rd.的住宅物业；以及位于康涅狄格州威尔顿354 Nod Hill Rd.的住宅物业。\n\n案件22-50073 文件1592 提交日期03/24/23 登记日期03/24/23 10:57:37 第890页，共1063页\n\n8. 关于债务人拥有、控制或使用的任何航空器的所有文件，包括但不限于尾号为T7-GQM的航空器以及在圣马力诺登记的任何其他航空器，包括但不限于所有登记文件的副本，以及显示该等航空器所进行航班及该等航班机上人员的飞行清单。\n\n9. 关于向债务人、债务人破产财产、债务人家属或关联实体提供、由其提供或代表其提供的任何赠与、利益或贷款的所有文件，包括但不限于足以显示该等赠与、利益或贷款金额的文件；该等赠与、利益或贷款的使用目的；提供该等赠与、利益或贷款的时间；以及任何贷款的条款、就任何贷款作出的所有陈述与保证、任何贷款的利率以及任何贷款付款的所有证据。\n\n10. 关于由债务人、债务人破产财产、债务人家属或关联实体设立、代表其设立或为其利益设立的任何信托或类似文书的所有文件，包括但不限于足以显示该等信托何时设立、由谁设立、为谁的利益设立以及信托本金的文件。\n\n11. 与涉及债务人的任何法律争议有关的任何义务、请求权、责任或债务的所有文件，包括但不限于与在任何地方、州、联邦或国际机构（无论是行政机构、法院、合议庭或替代性争议解决实体）进行的任何诉讼有关的文件。\n\n案件22-50073 文件1592 提交日期03/24/23 登记日期03/24/23 10:57:37 第891页，共1063页\n\n12. 贵方的任何外聘律师或其他顾问与债务人之间的所有文件和通信。\n\n13. 足以显示贵方全部资产以及收入或资金来源的文件。\n\n14. 对于为回应第14项请求而确定的、价值超过$50,000的所有资产，提供：(i) 与贵方取得该资产有关的所有文件；以及(ii) 与债务人或债务人家属就该资产进行的通信。\n\n15. 贵方纳税申报表的副本。\n\n16. 足以显示贵方占有或控制的所有银行账户和投资账户的文件，包括每一该等账户的余额以及向该等账户和自该等账户进行的转移。\n\n17. 关于贵方使用的任何信用卡的所有文件，包括但不限于月度对账单或足以显示为债务人或关联实体利益而进行的所有相关购买的其他文件。\n\n18. 所有公司治理及组织文件，包括但不限于公司章程和公司注册证书，以及足以显示贵方公司结构、高级管理人员和董事姓名、经营目的以及与债务人或债务人家属任何成员关系的其他文件。\n\n19. 与将贵方资产质押给任何其他实体有关的所有文件。\n\n附件C-49\n\nB2540（表格2540——Rule 2004审查传票）（12/15）案件22-50073 文件1592 提交日期03/24/23 登记日期03/24/23 10:57:37 第893页，共\n\n美国破产法院\n\n康涅狄格地区\n\n关于HO WAN KWOK（郭文贵）等人，\n\n1 案件编号22-50073 (JAM) 债务人 第11章\n\n（合并管理）\n\nRule 2004审查传票\n\n致：Pixshow Film Inc.（Pixshow Film公司）\n\n（传票所指向人员的姓名）\n\n证言：现命令贵方于下列载明的时间、日期和地点出席，以便根据《联邦破产程序规则》Rule 2004进行审查并作证。随附授权该审查的法院命令副本。\n\n地点　日期和时间\n\nPaul Hastings LLP（保罗·黑斯廷斯律师事务所）\n200 Park Avenue　[TBD]\nNew York, New York 10166（纽约州纽约市10166）\n\n审查将通过以下方式记录：法庭记录员/速记员\n\n文件提交：贵方或贵方代表还必须在审查时携带下列文件、电子存储信息或物品，并必须允许对该等材料进行检查、复制、测试或取样：\n\n见随附的文件提交请求。\n\n《联邦民事诉讼规则》Fed. R. Civ. P. 45的下列条款，根据《联邦破产程序规则》Fed. R. Bankr. P. 9016适用于破产案件，现随附如下——关于履行地点的Rule 45(c)；关于作为传票对象之人的保护的Rule 45(d)；以及关于贵方回应本传票的义务及未作回应可能后果的Rule 45(e)和45(g)。\n\n日期：March , 2023\n\n法院书记员\n\n或\n\n书记员或副书记员签名　律师签名\n\n签发或请求本传票的代表第11章受托人Luc A. Despins（卢克·A·德斯平斯）的律师姓名、地址、电子邮件地址和电话号码如下：\n\nDouglas S. Skalka, Esq.（道格拉斯·S·斯卡尔卡律师）；Neubert, Pepe & Monteith, P.C.（纽伯特、佩佩和蒙蒂思专业公司）；195 Church Street, New Haven, Connecticut 06510；dskalka@npmlaw.com；(203) 821-2000\n\n致签发或请求本传票之人的通知\n\n如本传票命令在审判前提交文件、电子存储信息或有形物品，或检查场所，则必须在向传票所指向人员送达之前，向各方送达通知及本传票副本。Fed. R. Civ. P. 45(a)(4)。\n\n软件版权(c) 1996-2022 Best Case, LLC（Best Case有限责任公司）- www.bestcase.com Best Case Bankruptcy 1 本第11章案件中的债务人为Ho Wan Kwok（郭文贵，亦称Guo Wengui、Miles Guo及Miles Kwok，以及众多其他别名）（税务识别号码末四位：9595）、Genever Holdings LLC（Genever Holdings有限责任公司）（税务识别号码末四位：8202）及Genever Holdings Corporation（Genever Holdings公司）。受托人、Genever Holdings LLC及Genever Holdings Corporation的邮寄地址为Paul Hastings LLP（保罗·黑斯廷斯律师事务所），200 Park Avenue, New York, NY 10166，转交Luc A. Despins，作为Ho Wan Kwok破产财产的受托人（仅为通知及通信之目的）。\n\n送达证明\n\n（除非Fed. R. Civ. P. 45要求，否则本节不应向法院提交。）\n\n本人于（日期）收到向（个人姓名及职务，如有）发出的本传票。\n\n本人通过如下方式向被指定人员交付副本而送达本传票：\n\n于（日期）；或\n\n本人未执行即退回本传票，原因为：\n\n除非本传票代表美国或其官员或代理人签发，本人还已向证人支付一天出席费用及法律允许的里程费，金额为$ 。\n\n本人的差旅费用为$ ，服务费用为$ ，合计$ 。\n\n本人依伪证罪处罚之规定声明，该等信息真实且正确。\n\n日期：\n\n送达人签名\n\n正楷姓名及职务\n\n送达人地址\n\n有关尝试送达等的补充信息：\n\n《联邦民事诉讼规则》Rule 45(c)、(d)、(e)和(g)（Effective 12/1/13）（根据《联邦破产程序规则》Rule 9016适用于破产案件）\n\n(c) 履行地点。\n\n(1) 审判、听证或证言录取。传票仅可按以下规定命令人员出席审判、听证或证言录取：\n\n(A) 在该人员居住、受雇或经常亲自从事业务之地100英里范围内；或\n\n(B) 在该人员居住、受雇或经常亲自从事业务所在州内，如该人员：\n\n(i) 为当事人或当事人的高级管理人员；或\n\n(ii) 被命令出席审判且不会产生重大费用。\n\n(2) 其他证据开示。传票可命令：\n\n(A) 在该人员居住、受雇或经常亲自从事业务之地100英里范围内的地点提交文件、电子存储信息或物品；以及\n\n(B) 在拟检查的场所检查场所。\n\n(d) 对作为传票对象之人的保护；执行。\n\n(1) 避免不当负担或费用；制裁。负责签发和送达传票的当事人或律师必须采取合理措施，避免对作为传票对象之人施加不当负担或费用。要求履行的地区法院必须执行该义务，并对未遵守者的当事人或律师施加适当制裁，该制裁可包括损失的收入和合理的律师费。\n\n(2) 命令提交材料或允许检查。\n\n(A) 无须出席。被命令提交文件、电子存储信息或有形物品，或允许检查场所的人员，无须亲自出席提交或检查地点，除非同时被命令出席证言录取、听证或审判。\n\n(B) 异议。被命令提交文件或有形物品，或允许检查的人员，可以向传票中指定的当事人或律师送达书面异议，反对检查、复制、测试或取样任何或全部材料，或反对检查场所——或反对以请求的一种或多种形式提交电子存储信息。异议必须在指定履行时间或传票送达后14日（以较早者为准）之前送达。如提出异议，适用以下规则：\n\n(i) 送达方可在任何时候，在通知被命令人员后，向要求履行的地区法院提出动议，请求作出强制提交或检查的命令。\n\n(ii) 仅可按该命令所指示要求实施该等行为，且该命令必须保护并非当事人或当事人高级管理人员之人免于承担因履行而产生的重大费用。\n\n(3) 撤销或修改传票。\n\n(A) 必须撤销或修改的情形。经及时动议，要求履行的地区法院必须撤销或修改以下传票：\n\n(i) 未给予合理履行时间；\n\n(ii) 要求人员在Rule 45(c)规定的地域限制以外履行；\n\n(iii) 要求披露享有特权或受其他保护的事项，且不存在适用的例外或豁免；或\n\n(iv) 对人员造成不当负担。\n\n(B) 可以撤销或修改的情形。为保护作为传票对象或受传票影响之人，要求履行的地区法院可依动议撤销或修改要求以下事项的传票：\n\n(i) 披露商业秘密或其他保密性研究、开发或商业信息；或\n\n(ii) 披露未受聘专家的意见或信息，该等意见或信息未描述争议中的具体事件，且源于并非由任何一方请求的该专家研究。\n\n(C) 将条件具体化作为替代措施。在 Rule 45(d)(3)(B) 所述情形下，法院可不撤销或修改传票，而是在送达方符合下列条件时，命令在具体规定的条件下出庭或提交材料：\n\n(i) 证明其对该证言或材料具有重大需要，且如不承受不当困难，无法以其他方式满足该需要；以及\n\n(ii) 确保被传唤人将获得合理报酬。\n(e) 回应传票时的义务。\n\n(1) 提交文件或电子存储信息。下列程序适用于提交文件或电子存储信息：\n\n(A) 文件。回应要求提交文件的传票的人，必须按照文件在正常业务过程中保存的方式提交，或者将文件整理并标注，使其与要求中的类别相对应。\n\n(B) 未指定电子存储信息提交形式。如果传票未指定提交电子存储信息的形式，回应人必须以其通常保存的形式，或以合理可用的形式提交。\n\n(C) 电子存储信息仅以一种形式提交。回应人无需以一种以上的形式提交同一电子存储信息。\n\n(D) 不可合理获取的电子存储信息。回应人无需就其认定因不当负担或费用而无法合理获取的来源中的电子存储信息提供证据开示。在强制证据开示动议或保护令动议中，回应人必须证明该信息因不当负担或费用而无法合理获取。即使作出该证明，如请求方在考虑 Rule 26(b)(2)(C) 的限制后证明存在正当理由，法院仍可命令对该等来源进行证据开示。法院可规定该证据开示的条件。\n(2) 主张特权或保护。\n\n(A) 扣留的信息。基于该信息享有特权或作为审判准备材料受保护而扣留被传唤信息的人，必须：(i) 明确提出该主张；以及\n\n(ii) 以一种在不披露本身享有特权或受保护的信息的情况下，能够使当事人评估该主张的方式，说明被扣留文件、通信或有形物品的性质。\n\n(B) 已提交的信息。如果为回应传票而提交的信息受到特权主张或作为审判准备材料受保护的主张，提出该主张的人可将该主张及其依据通知任何收到该信息的当事人。收到通知后，当事人必须立即返还、隔离或销毁所指定的信息及其持有的任何副本；在该主张得到解决前不得使用或披露该信息；如该当事人在收到通知前已披露该信息，必须采取合理措施追回该信息；并且可立即将该信息密封提交至履行义务所在地区的法院，以裁定该主张。提交该信息的人必须在该主张得到解决前保存该信息。\n\n(g) 藐视法庭。履行义务所在地区的法院——以及在动议移送后，签发传票的法院——可认定已经送达但无正当理由不遵守传票或相关命令的人构成藐视法庭。\n\n如需查阅传票材料，参见 Fed.R.Civ.P.45(a) Committee Note (2013)\n\n……\n\n文件提交请求\nI. 指示\n\n1. 除非另有说明，下列文件请求（“请求”，每一项为“一项请求”）必须分别且具体地作出回应。除非基于善意提出异议，否则必须完整回答每项请求；如提出异议，必须按下文规定详细说明贵方异议的理由。如异议仅涉及某项请求的一部分，或其中的某一词语、短语或条款，贵方须仅说明对该部分的异议，并对请求的其余部分作出回应。\n\n2. 电子存储信息必须依照下列指示提交：\n\na．图像。黑白图像必须为 300 DPI Group IV 单页 TIFF 文件。彩色图像必须以 JPEG 格式提交。文件名不得包含内嵌空格或特殊字符（包括逗号）。文件夹名称不得包含内嵌空格或特殊字符（包括逗号）。所有 TIFF 图像文件必须具有唯一文件名，即 Bates 编号。每张图像右下角必须标注连续的 Bates 编号。每个文件夹中的 TIFF 文件数量不应超过 1000 个。Excel 电子表格应有一张以该文件 Bates 编号命名的占位图像。\n\nb．图像加载文件\n\na．Concordance® 数据文件。数据文件（.DAT）包含将载入 Concordance® 数据库的全部字段信息。.DAT 文件的第一行必须为标识字段名称的标题行。.DAT 文件必须使用以下 Concordance® 默认分隔符：逗号 ASCII 字符（020）引号 þ ASCII 字符（254）。日期字段应采用以下格式提供：mm/dd/yyyy。日期和时间字段必须为两个独立字段。如文件包括图像化的电子邮件及附件，必须包括附件字段，以保留电子邮件与其附件之间的父项/子项关系。必须包括 OCRPATH 字段，以提供所提交存储介质上提取文本文件的文件路径和名称。文本文件必须以 FIRSTBATES 命名。不得在 .DAT 文件中包含文本。对于具有原生文件的文件，必须包括 LINK 字段，以提供原生文件的文件路径和名称。原生文件必须以 FIRSTBATES 命名。\n\nb．Concordance Image® 或 Opticon 交叉引用文件。图像交叉引用文件（.LOG 或 .OPT）将图像链接至数据库记录。该文件应为逗号分隔文件，每行由七个字段组成；数据库中的每张图像均应在交叉引用文件中有一行，格式如下：ImageID,VolumeLabel,ImageFilePath,DocumentBreak,FolderBreak,Box Break,PageCoun。\n\nc．文件文本。文本必须作为独立文本文件提交，而非作为 .DAT 文件内的字段。通往文本文件的完整路径（OCRPATH）应包括在 .DAT 文件中。建议使用以 FIRSTBATES/Image Key 命名的文件级 ANSI 文本文件。提取的文本文件必须置于单独的文件夹中，每个文件夹中的文本文件数量不应超过 1,000 个。文件夹名称中不得有特殊字符（包括逗号）。文本文件必须按文件级别提供。\n\nd．特定文件类型的原生格式提交。为充分理解其内容和含义而合理需要以原生格式查看的文件类型，必须以原生格式提交。这些包括但不限于电子表格、类似电子表格的文件（Microsoft Excel、逗号分隔值、制表符分隔值等）、Microsoft PowerPoint 或其他特殊演示文件、数据库文件以及音频/视频文件。应提供一张标有 Bates 编号的分隔页图像，表明存在原生文件，并在 .dat 文件中以字段形式包括原生文件路径。所提交原生文件应以与该文件分隔页相对应的 Bates 编号命名。将原生文件归入按递增方式命名的“NATIVE”目录中，并与图像目录分开。\n\ne．去重。对于存在完全重复副本的每一电子文件，仅提交一份副本。对于电子邮件，应根据由 BCC、Body、CC、From、IntMsgID、To 和 Attach 属性生成的 MD5 哈希值合并重复项。对于电子邮件附件和独立电子文件，应根据整个文件的 MD5 哈希值合并重复项。\n\nf．元数据。以符合 Concordance 要求的加载文件（.dat）形式，为每份文件提交提取的元数据。.DAT 文件的第一行必须为标识字段名称的标题行。.DAT 文件必须使用以下 Concordance 默认分隔符：逗号 , ASCII 字符（020）引号 þ ASCII 字符（254）。\n\n日期字段应采用以下格式提供：mm/dd/yyyy。日期和时间字段必须为两个独立字段。下列为必需元数据：\nCase 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 898 of 1063\n\n字段名称　示例数据　说明\n\nFIRSTBATES　EDC0000001　原生文件文件/电子邮件的第一个 Bates 编号\nLASTBATES　EDC0000001　原生文件文件/电子邮件的最后一个 Bates 编号\nLASTBATES 字段应针对单页文件填写\nATTACHRANGE　EDC0000001 - EDC0000015　父文件第一页的 Bates 编号至最后一个附件“子”文件最后一页的 Bates 编号\nBEGATTACH　EDC0000001　附件范围的第一个 Bates 编号\nENDATTACH　EDC0000015　附件范围的最后一个 Bates 编号\nCUSTODIAN　Smith, John　电子邮件：该电子邮件所在的邮箱\n原生文件：该文件来源的个人或部门名称\nFROM　John Smith　电子邮件：发件人\n原生文件：文件作者\n多个条目应使用分号分隔\nTO　Coffman, Janice; LeeW [mailto:LeeW@MSN.com]　收件人\n多个条目应使用分号分隔\nCC　Frank Thompson [mailto:frank_Thompson@cdt.com]　抄送收件人\n多个条目应使用分号分隔\nBCC　John Cain　密送收件人\n多个条目应使用分号分隔\nSUBJECT　Board Meeting Minutes　电子邮件：电子邮件主题行 原生文件：文件标题（如有）\nFILE_NAME　BoardMeetingMinutes.docx　原生文件：原始原生文件名称，包括扩展名\nDATE_SENT　10/12/2010　电子邮件：电子邮件发送日期\n原生文件：（空）\nTIME_SENT/TIME_ZONE　07:05 PM GMT　电子邮件：电子邮件发送时间/电子邮件标准化时所采用的时区\nTIME_ZONE　GMT　在转换期间电子邮件被标准化时所采用的时区。\nLINK　EDC0000001.msg　指向电子邮件或原生文件文件的超链接\n所链接文件必须按 FIRSTBATES 编号命名\nFILE_EXTEN　MSG　代表电子邮件或文件的文件类型扩展名\nAUTHOR　John Smith　电子邮件：（空）\n原生文件：文件作者\nDATE_CREATED　10/10/2010　电子邮件：（空）\n原生文件：文件创建日期\nCase 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 899 of 1063\n\nTIME_CREATED　10:25 AM　电子邮件：（空）\n原生文件：文件创建时间\n该数据必须为独立字段，不得与 DATE_CREATED 字段合并\nDATE_MOD　10/12/2010　电子邮件：（空）\n原生文件：文件最后修改日期\nTIME_MOD　07:00 PM　电子邮件：（空）\n原生文件：文件最后修改时间\n该数据必须为独立字段，不得与 DATE_MOD 字段合并\nDATE_ACCESSD　10/12/2010　电子邮件：（空）\n原生文件：文件最后访问日期\nTIME_ACCESSD　07:00 PM　电子邮件：（空）\n原生文件：文件最后访问时间\n该数据必须为独立字段，不得与 DATE_ACCESSD 字段合并\nFILE_SIZE　5,952　原生文件文件/电子邮件的大小，单位为 KB\nPGCOUNT　1　原生文件文件/电子邮件的页数\nPATH　Email: (empty) Agenda.doc　原生文件文件的存储路径，包括原始文件名称。\nINTFILEPATH　Personal Folders\\Deleted Items\\Board Meeting Minutes.msg　电子邮件：电子邮件的原始位置，包括原始文件名称。\n原生文件：（空）\nINTMSGID　<000805c2c71b\\$75977050\\$cb8306d1@MSN>　电子邮件：唯一消息 ID 原生文件：（空）\nMD5HASH　d131dd02c5e6eec4693d9a0698aff95c2fcab58712467eab4004583eb8fb7f89　文件的 MD5 哈希值。\nOCRPATH　TEXT/001/EDC0000001.txt　原生文件提取文本的路径\n\n3. 每一项请求均独立适用并应独立解释；除非另有说明，任何一项请求均不限制任何其他请求的范围。\n\n4. 所有文件均应按照其在通常业务过程中保存的方式提供，或者应予以整理并标注，以对应本请求中的类别。\n\n5. 本文所载的每项请求均延及所有文件：(a) 由您占有、保管或控制的文件；或 (b) 由任何代表您行事之人占有、保管或控制的文件，\n案件 22-50073 文件 1592 提交 03/24/23 登记 03/24/23 10:57:37 第 900 页，共 1063 页\n包括您的律师或其他代表及顾问。每份文件均应完整提供。\n\n6. 如要求您提供一份已不再由您占有、保管或控制的文件，则您的答复必须：(a) 详细说明该文件的性质及其内容；(b) 识别编制或撰写该文件之人的身份（以及，如适用，该文件被送达之人的身份）；(c) 识别该文件编制或创建的日期；(d) 说明该文件是否：(i) 下落不明或遗失，(ii) 已被销毁，(iii) 已自愿或非自愿地转移给他人，或 (iv) 已以其他方式处置；(e) 说明该等处置的原因，以及围绕该等处置的事实和情形；(f) 识别授权该等处置之人的身份；(g) 识别该等处置的日期或约略日期；(h) 说明该文件最近一次由您占有、保管或控制的时间；以及 (i) 识别目前占有、保管或控制该文件之人的身份（如有）。\n\n7. 如要求您提供一份已被销毁的文件，则除前述指示所要求的信息外，您的答复还必须说明：(a) 销毁该文件的原因；(b) 销毁该文件之人的身份；以及 (c) 指示销毁该文件之人的身份。\n\n8. 如您主张某一被请求的文件享有特权或属于律师工作成果，则您的答复必须：(a) 说明：(i) 对该文件作出足以支持您关于该文件享有特权之主张的描述，(ii) 该文件的标题，(iii) 该文件的日期，(iv) 该文件的作者，(v) 该文件的收件人，(vi) 收到或阅览该文件原件或任何草稿、副本或复制件的每一人的身份，(vii) 该文件本身或该文件中载明或提及的任何信息是否由任何其他人占有、保管或控制；如是，则说明该等人员的身份，\n案件 22-50073 文件 1592 提交 03/24/23 登记 03/24/23 10:57:37 第 901 页，共 1063 页\n以及说明该等信息如何进入其占有范围，(viii) 据以扣留该文件的特权主张，以及 (ix) 您将据以支持该等特权主张的全部情形；以及 (b) 对于依据特权主张而扣留的每份文件，按照 D. Conn. L. Civ. R. 26(e)，提供一份特权清单，其中载有本指示第 (a) 部分所要求的全部信息。\n\n9. 如一份本应提交的文件中有一部分包含受特权主张约束的信息，则仅应按照上述指示从该文件中删除或遮蔽受该特权主张约束的部分，其余部分应予提供。\n\n10. 本请求具有持续性。现指示您：(a) 在得知先前答复不完整或不正确后，立即补充或更正任何后来发现不完整或不正确的答复；以及 (b) 提供依照下文所要求的任何额外文件。\n\n11. 如某一文件使用英语以外的语言，您应提供该文件。如某一文件使用英语以外的语言，且存在英文译本，您应同时提供两份文件。\n\n12. 对实体的所有提及均包括其所有关联方。\n\n13. 对个人姓名的所有提及均包括所有替代姓名、别名或昵称。\n\n14. 除非另有明确说明，文件请求所涵盖的期间为自 February 5, 2012 起至文件请求答复到期之日止。\n案件 22-50073 文件 1592 提交 03/24/23 登记 03/24/23 10:57:37 第 902 页，共 1063 页\n\nII. 解释规则\n\n15. (a) 对任何单数名词的使用应解释为包括复数，反之亦然；以及 (b) 对任何时态动词的使用应解释为包括该动词所有其他时态的使用。\n\n16. (a) “和”及“或”应视必要作连言或选言解释，以使任何请求的范围包括原本可能被解释为不在其范围内的所有答复；以及 (b) “每一”及“任何”应视为包括并涵盖“每个”及“所有”二词。\n\nIII. 定义\n\n经 D. Conn. Bankr. L.R. 2004-1(a) 纳入的 D. Conn. L. Civ. R. 26(c) 所规定的定义，以及 D. Conn. L. Civ. R. 26(d) 所规定的解释规则，适用于文件请求。此外，本文件请求中使用的下列术语具有如下含义：\n\n1. “您”或“您的”或“您本人”是指 Pixshow Film Inc.（Pixshow Film股份有限公司），连同其所有关联方、部门、机构、职能单位、科室、办事处、合伙人、高级管理人员、董事、代理人、律师、代表、雇员和/或任何代表其行事之人。\n\n2. “债务人”是指 Ho Wan Kwok（郭文贵，亦称 Miles Kwok、Miles Guo、Guo Wengui、Guo Haoyun 或任何其他别名），连同其雇员、代理人、律师、顾问或任何代表其行事之人。\n\n3. “债务人之子”是指 Qiang Guo（郭强，亦称 Mileson Kwok 或任何其他别名），连同其雇员、代理人、律师、顾问或任何代表其行事之人。\n案件 22-50073 文件 1592 提交 03/24/23 登记 03/24/23 10:57:37 第 903 页，共 1063 页\n\n4. “债务人之女”是指 Mei Guo（郭美，亦称 Mei Gui 或任何其他别名），连同其雇员、代理人、律师、顾问或任何代表其行事之人。\n\n5. “债务人所称之妻”是指 Hing Chi Ngok（岳庆芝，亦称 Hing Chi Ng、Yue Qingzhi 或任何其他别名），连同其雇员、代理人、律师、顾问或任何代表其行事之人。\n\n6. “债务人家庭成员”统称债务人、债务人之子、债务人之女及债务人所称之妻，以及与债务人具有任何其他家庭关系之人。\n\n7. “关联个人”单独及统称所有下列个人：(1) 持有、控制、保管或对债务人或债务人家庭成员拥有、控制或享有的资产具有酌处权的个人；或 (2) 曾为一个或多个关联实体的雇员、董事，或以其他方式与一个或多个关联实体有关联的个人，连同前述各方各自的雇员、代理人、律师、顾问或任何代表前述任何一方行事之人。该等关联个人包括但不限于：Daniel Podhaskie（丹尼尔·波德哈斯基）、Jason Miller（杰森·米勒）、Steve Bannon（史蒂夫·班农）、Karin Maistrello（卡琳·迈斯特雷洛）、Melissa Francis（梅丽莎·弗朗西斯）、Anthony DiBattista（安东尼·迪巴蒂斯塔）、William Gertz（威廉·格茨）、Arethusa Forsyth（阿雷图萨·福赛思）、Glenn Mellor（格伦·梅勒）、Jennifer Mercurio（詹妮弗·默丘里奥）、Eduardo Eurnekian（爱德华多·欧尔内基安）、Wencong Wang（王文聪）、Han Chunguang（韩春光）、Qu Guojiao（屈国姣，亦称 Qu Guo Jiao）、Guo Lijie（郭丽杰）、Zhang Wei（张伟*）、Lihong Wei Lafrenz（魏丽红，亦称 Sara Wei）、Hao Haidong（郝海东）、Ross Heinemeyer（罗斯·海内迈耶）、Max Krasner（马克斯·克拉斯纳）、Kyle Bass（凯尔·巴斯）、Melissa Mendez（梅丽莎·门德斯）、Ya Li（李娅）、Dinggang Wang（王定刚）、An Hong（安红）、Yvette Wang（王雁平，亦称 Yanping Wang、Yan Ping Wang）、Fiona Yu（菲奥娜·余）、Je Kin Ming（余建明，亦称 William Je、Yu Jianming）、Yaz Qingua（亚兹·钦瓜）及 Lao Jiang（姜云浮，亦称 Jiang Yunfu、Jiang Yunfu Be）。\n案件 22-50073 文件 1592 提交 03/24/23 登记 03/24/23 10:57:37 第 904 页，共 1063 页\n\n8. “关联实体”单独及统称所有下列任何类型的组织或实体：(1) 曾由债务人或债务人家庭成员拥有、控制或投资的组织或实体；或 (2) 对债务人或债务人家庭成员拥有、控制或享有的任何资产直接或间接享有权益的组织或实体，连同前述各方各自的雇员、代理人、律师、顾问或任何代表前述任何一方行事之人。该等关联实体包括但不限于：7 Nod Hill LLC（7 Nod Hill有限责任公司）、AAGV Limited（AAGV有限公司）、ACA Investment Management Limited（ACA投资管理有限公司）、ACA Capital Group Limited（ACA资本集团有限公司）、Ace Decade Holdings Limited（Ace Decade控股有限公司）、AI Group Holdings Inc.（AI Group控股股份有限公司）、Alfa Global Ventures Limited（Alfa全球创投有限公司）、Alfonso Global Limited（Alfonso全球有限公司）、Allied Capital Global Limited（Allied Capital全球有限公司）、Alpine Fiduciaries SA（Alpine受托人股份公司）、Anton Development Limited（Anton开发有限公司）、Assets Sino Limited（Assets Sino有限公司）、Auspicious Coast Limited（Auspicious Coast有限公司）、Beijing Pangu Investment Co.（北京盘古投资公司）、Beijing Pangu Investment Co. Ltd.（北京盘古投资有限公司）、Beijing Pangu Investment Inc.（北京盘古投资股份有限公司）、Beijing Zenith Holdings Company Limited（北京Zenith控股有限公司）、Booming Sail New York LLC（Booming Sail New York有限责任公司）、Bravo Luck Limited（Bravo Luck有限公司）、BSA Strategic Fund I（BSA战略基金I）、China Golden Spring (Hong Kong) Limited（中国金泉〈香港〉有限公司）、Chuang Xin Limited（创新有限公司）、Crane Advisory Group LLC（Crane咨询集团有限责任公司）、Creative Apex Investments Limited（Creative Apex投资有限公司）、Crystal Breeze Investments Limited（Crystal Breeze投资有限公司）、Dawn State Limited（Dawn State有限公司）、Eastern Profit Corporation Limited（Eastern Profit有限公司）、Elite Well Global Limited（Elite Well全球有限公司）、Empire Growth Holdings（Empire Growth控股公司）、Freedom Media Ventures Ltd.（Freedom Media Ventures有限公司）、G Club Operations LLC（G Club运营有限责任公司）、G Fashion LLC（G Fashion有限责任公司）、G News LLC（G News有限责任公司）、GETTR USA（GETTR美国）、Genever Holdings Corporation（Genever控股公司）、Genever Holdings LLC（Genever控股有限责任公司）、Gfashion Media Group Inc.（Gfashion媒体集团股份有限公司）、GFNY, Inc.（GFNY股份有限公司）、Globalist International Limited（Globalist International有限公司）、GNews Media Group Inc.（GNews媒体集团股份有限公司）、Golden Spring (New York) Ltd.（Golden Spring〈纽约〉有限公司）、Greenwich Land LLC（Greenwich Land有限责任公司）、Guo Media（郭媒体）、GTV Media Group, Inc.（GTV媒体集团股份有限公司）、Hamilton Capital Holdings Inc.（Hamilton Capital控股股份有限公司）、HCHK Property Management, Inc.（HCHK物业管理股份有限公司）、HCHK Technologies, Inc.（HCHK科技股份有限公司）、Head Win Group Limited（Head Win集团有限公司）、Henan Yuda（河南裕达）、Himalaya Embassy（喜马拉雅使馆）、Himalaya Exchange（喜马拉雅交易所）、Himalaya Federal Reserve（喜马拉雅联邦储备）、Himalaya Investment LLC（喜马拉雅投资有限责任公司）、Himalaya International（喜马拉雅国际）、Himalaya New World Inc.（喜马拉雅新世界股份有限公司）、Himalaya Supervisory Organization（喜马拉雅监督组织）、Himalaya Ventures LLC（喜马拉雅创投有限责任公司）、HK International Funds Investments (USA) Limited LLC（香港国际基金投资〈美国〉有限责任公司）、Hong Kong International Funds\n案件 22-50073 文件 1592 提交 03/24/23 登记 03/24/23 10:57:37 第 905 页，共 1063 页\nInvestments Limited（香港国际基金投资有限公司）、Hudson Diamond Holding（Hudson Diamond控股公司）、Infinite Increase Limited（Infinite Increase有限公司）、Infinitum Developments Limited（Infinitum开发有限公司）、Infinity Treasury Management Inc.（Infinity财资管理股份有限公司）、Insight Phoenix Fund（Insight Phoenix基金）、Lamp Capital LLC（Lamp Capital有限责任公司）、Leading Shine Limited（Leading Shine有限公司）、Leading Shine NY Limited（Leading Shine NY有限公司）、Lexington Property and Staffing（Lexington物业与人力资源公司）、Long Gate Limited（Long Gate有限公司）、Maywind Trading LLC（Maywind Trading有限责任公司）、MOS Himalaya LLC（MOS Himalaya有限责任公司）、Next Tycoon Investments Limited（Next Tycoon投资有限公司）、New Federal State of China（中国新联邦国，亦称 NFSC）、Noble Fame Global Limited（Noble Fame Global有限公司）、Rosy Acme Ventures Limited（Rosy Acme Ventures有限公司）、Rule of Law Foundation III, Inc.（法治基金会III股份有限公司）、Rule of Law Foundation IV, Inc.（法治基金会IV股份有限公司）、Rule of Law Fund（法治基金）、Rule of Law Society（法治协会）、Rule of Law Society IV, Inc.（法治协会IV股份有限公司）、G-Translators PTY LTD（G-Translators有限公司）、Saraca Media Group, Inc.（Saraca媒体集团股份有限公司）、Shiny Ace Ltd.（Shiny Ace有限公司）、Shiny Times Holdings Ltd.（Shiny Times控股有限公司）、Spirit Charter Investment Limited（Spirit Charter投资有限公司）、Stevenson, Wong & Co.（Stevenson, Wong & Co.）、Voice of Guo Media, Inc.（郭媒体之声股份有限公司）、Well Origin Ltd.（Well Origin有限公司）、World Century Limited（World Century有限公司）、Worldwide Opportunity Holdings Limited（Worldwide Opportunity控股有限公司）、Whitecroft Shore Limited（Whitecroft Shore有限公司）及 ZIBA Limited（ZIBA有限公司）。\n\n9. “包括”或其任何变体是指“包括但不限于”。\n\n10. “和”及“或”是指“和/或”，并应同时作连言及选言解释，以最大限度扩大其范围。\n\n11. “任何”、“所有”及“每一”是指“每一个及全部”。\n\n12. “每一”及“每个”是指“每一个及全部”。\n\n13. “第三方”是指您本人以外的个人或实体。\n\n14. “转让”具有《破产法典》第 101(54) 条赋予其的含义。\n\n15. “文件”是指属于 Fed. R. Civ. P. 34 范围内的任何信息或物品，并且包括但不限于您占有、保管或控制的，或曾由您占有、保管或控制的任何种类、类型、性质或描述的每一项书面、记录或图形材料，包括所有电子邮件的打印件及电子副本、存储于计算机中的文件\n案件 22-50073 文件 1592 提交 03/24/23 登记 03/24/23 10:57:37 第 906 页，共 1063 页\n\n电子形式、电子通信、短信、社交媒体帖子、推文、元数据、通信函件、备忘录、录音带、速记或手写笔记、任何种类的书面表格、图表、蓝图、图纸、草图、图形、计划、文章、说明书、日记、信件、电报、照片、会议记录、合同、协议、调查资料、计算机打印件、任何种类的数据汇编、电传、传真、语音留言、发票、订购单、支票、汇票、报表、贷项通知单、报告、立场报告、摘要、索引、书籍、账簿、笔记本、日程表、透明胶片、录音、目录、广告、宣传材料、影片、录像带、录音带、CD、计算机磁盘、宣传册、小册子、穿孔卡、工时单、推文、社交媒体帖子，或任何其他种类的书面或录制材料，以及其全部元数据，无论以何种方式存储（无论为有形形式或电子形式）、记录、制作或复制；亦包括但不限于前述任何材料的草稿或副本，如其中载有原始文件中不存在的任何种类的笔记、评论或标记，或在其他方面与原始文件不相同。\n\n16. “人员”系指个人、公司、独资企业、合伙企业、协会或任何其他实体。“人员”还包括任何代理人、代表或专家，包括但不限于律师或财务顾问。\n\n17. “实体”系指任何自然人、公司、合伙企业、子公司、独资企业、商号、董事会、合资企业、协会、机构、主管机关、委员会或其他商业实体或法人，以及任何关联方、代理人、母公司，包括但不限于法律顾问、财务顾问或任何其他代表。\n\n18. “关于”系指涉及、描述、构成、提及、与之相关、支持、赞成、反对、强化、减损、位于、结合考虑、影响、证明、表明、报告、记录、暗指、回应，\n案件 22-50073 文件 1592 提交于 03/24/23 录入于 03/24/23 10:57:37 第 907 页，共 1063 页\n\n与之相连、评论、就其而言、有关、与之相关、讨论、显示、描述、反映、分析、构成及属于。\n\n19. 在提及任何特定事项时，“与……有关”、“涉及”或“相关”系指但不限于构成、包含、涉及、含有、体现、反映、识别、陈述、直接或间接提及该特定事项，或以任何方式与所识别的特定事项相关的任何文件。\n\n20. “通信”在最广泛可能的意义上且不限于此，系指任何信息或知识的传递（以事实、观点、询问或其他形式）。通信还指所有谈话、协议、询问或答复，无论是当面、通过电话、书面方式，还是通过电子传输设备，并包括但不限于所有通信函件、电子邮件、录音、传送单、备忘录、电话通信、语音留言、电报、电传、传真复制件、电传、即时消息、聊天记录、短信、电话笔记，或在内部或与第三方传送的笔记。\n\n21. “资产”系指任何可用于产生正面经济价值的项目，包括但不限于由某一实体拥有、控制或为其利益而持有，并预期提供未来利益的任何具有经济价值的资源，包括但不限于所有不动产和动产、无形财产、投资、投资权或未来收入权、现金、银行账户、商品、证券、债权、对某一实体的全部或部分控制权，以及预期经济机会。\n\n22. “转让”应具有《破产法》第 101(54) 条赋予其的含义。\n\nIV. 应提交的文件\n\n1. 关于债务人、债务人财产或关联实体的任何收入或资产的所有文件。\n\n2. 与债务人的财务状况及其对债权人的义务有关的所有文件，包括但不限于与任何避免支付该等义务的努力有关的所有文件，以及与本次或任何其他实际或潜在破产或类似资不抵债程序有关的所有文件。\n\n3. 关于与债务人、债务人财产、债务人家庭成员、关联实体或关联个人有关的任何资产负债表、银行对账单、账户对账单、财务报表、账户结单、电汇指示和/或确认、资金证明、存款证、持有证明、投资组合摘要或类似文件的所有文件，包括但不限于足以显示向前述任何一方作出的所有转让的全部文件。\n\n4. 关于债务人作出、与债务人进行或代表债务人作出的任何投资、商业交易或其他交易的所有文件。\n\n5. 与债务人的所有通信，以及与债务人的通信有关、且涉及任何实体（包括但不限于关联实体）的运营、管理或决策的文件。\n\n6. 关于向债务人、由债务人、向债务人家庭成员、由债务人家庭成员、向关联实体、由关联实体或与其进行的任何转让、投资或其他交易或商业往来的所有文件。\n\n7. 关于债务人曾经占用或使用的任何财产的所有文件，包括但不限于 Lady May（梅夫人号）；Sherry Netherland Hotel / Condominium（谢里荷兰酒店／共管公寓）；位于 Connecticut（康涅狄格州）Greenwich（格林尼治）373 Taconic Rd. 的住宅物业；位于 Connecticut（康涅狄格州）Greenwich（格林尼治）33 Ferncliff Rd. 的住宅物业；以及位于 Connecticut（康涅狄格州）Wilton（威尔顿）354 Nod Hill Rd. 的住宅物业。\n案件 22-50073 文件 1592 提交于 03/24/23 录入于 03/24/23 10:57:37 第 909 页，共 1063 页\n\n8. 与债务人拥有、控制或使用的任何航空器有关的所有文件，包括但不限于尾号为 T7-GQM 的航空器以及在 San Marino（圣马力诺）登记的任何其他航空器，包括但不限于所有登记文件的副本，以及显示该等航空器所执行航班及该等航班乘员的所有飞行清单。\n\n9. 关于向债务人、债务人财产、债务人家庭成员或关联实体提供、由其提供或代表其提供的任何赠与、利益或贷款的所有文件，包括但不限于足以显示该等赠与、利益或贷款的金额；该等赠与、利益或贷款的使用目的；提供该等赠与、利益或贷款的时间；以及任何贷款的条款、就任何贷款作出的所有陈述和保证、任何贷款的利率及任何贷款付款的所有证明的文件。\n\n10. 关于由债务人、债务人财产、债务人家庭成员或关联实体设立、代表其设立或为其利益而设立的任何信托或类似文书的所有文件，包括但不限于足以显示信托设立时间、设立人、为谁的利益而设立以及信托财产的文件。\n\n11. 与涉及债务人的任何法律争议有关的任何义务、请求权、责任或债务有关的所有文件，包括但不限于与在任何地方、州、联邦或国际机构（无论是行政机构、法院、合议庭或替代性争议解决实体）进行的任何诉讼有关的文件。\n案件 22-50073 文件 1592 提交于 03/24/23 录入于 03/24/23 10:57:37 第 910 页，共 1063 页\n\n12. 你方外部法律顾问或其他顾问与债务人之间的所有文件和通信。\n\n13. 足以显示你方全部资产及收入或资金来源的文件。\n\n14. 对于就第 14 项请求所确认的、价值超过 \\$50,000 的所有资产，(i) 与你方取得该等资产有关的所有文件，以及 (ii) 与债务人或债务人家庭成员就该等资产进行的通信。\n\n15. 你方纳税申报表的副本。\n\n16. 足以显示你方占有或控制的所有银行账户和投资账户的文件，包括每一该等账户的余额以及向该等账户和从该等账户进行的转让。\n\n17. 关于你方使用的任何信用卡的所有文件，包括但不限于月度账单或足以显示为债务人或关联实体利益而进行的所有相关购买的其他文件。\n\n18. 所有公司治理及组织文件，包括但不限于章程细则和公司注册证书，以及足以显示你方公司结构、高级管理人员和董事姓名、经营目的及与债务人或债务人任何家庭成员关系的其他文件。\n\n19. 与将你方资产质押给任何其他实体有关的所有文件。\n\n附件 C-50\nB2540（表格 2540－依据规则 2004 审查的传票）（12/15）案件 22-50073 文件 1592 提交于 03/24/23 录入于 03/24/23 10:57:37 第 912 页，共\n\n美国破产法院 1063\n\n康涅狄格州地区\n\n关于 HO WAN KWOK（郭文贵）等人，\n\n1 案号 22-50073 (JAM)\n\n债务人 第 11 章\n\n（合并管理）\n依据规则 2004 审查的传票\n\n致：Fung Wan Trading Inc.（丰万贸易公司）\n\n（传票所指向人员的姓名）\n\n证言：兹命令你于下列规定的时间、日期和地点出席，并根据《联邦破产程序规则》第 2004 条接受审查并作证。授权该审查的法院命令副本附后。\n\n地点　日期和时间\n\nPaul Hastings LLP（普衡律师事务所）\n200 Park Avenue　[TBD]\nNew York, New York 10166\n\n审查将通过以下方式记录：法庭记录员／速记员\n\n提交材料：你或你的代表还必须在审查时携带下列文件、电子存储信息或物品，并必须允许对该等材料进行查验、复制、测试或抽样：\n见随附的文件提交请求。\n\n以下《联邦民事诉讼规则》第 45 条的规定，依《联邦破产程序规则》第 9016 条适用于破产案件，现附于本传票之后——有关履行地点的第 45(c) 条；有关你作为传票对象所受保护的第 45(d) 条；以及有关你对本传票作出回应的义务及未作出回应的潜在后果的第 45(e) 和 45(g) 条。\n\n日期：March , 2023\n\n法院书记员\n\n或\n\n书记员或副书记员签名　律师签名\n\n签发或请求本传票、代表第 11 章受托人 Luc A. Despins（吕克·A·德斯平）的律师姓名、地址、电子邮件地址和电话号码如下：\n\nDouglas S. Skalka, Esq.（道格拉斯·S·斯卡尔卡律师）；Neubert, Pepe & Monteith, P.C.；195 Church Street, New Haven, Connecticut 06510；dskalka@npmlaw.com；(203) 821-2000\n\n致签发或请求本传票之人员的通知\n\n如本传票命令在审判前提交文件、电子存储信息或有形物品，或命令查验场所，则必须在向传票所指向人员送达前，向各方送达通知及本传票副本。Fed. R. Civ. P. 45(a)(4)。\n\n软件版权 (c) 1996-2022 Best Case, LLC（最佳案件有限责任公司）－www.bestcase.com Best Case Bankruptcy（最佳案件破产）1 本第 11 章案件中的债务人为 Ho Wan Kwok（亦称 Guo Wengui、Miles Guo 和 Miles Kwok，以及众多其他化名）（税务识别号码后四位：9595）、Genever Holdings LLC（税务识别号码后四位：8202）和 Genever Holdings Corporation。受托人、Genever Holdings LLC 和 Genever Holdings Corporation 的邮寄地址为 Paul Hastings LLP（普衡律师事务所），200 Park Avenue, New York, NY 10166，转交 Luc A. Despins，作为 Ho Wan Kwok 财产的受托人（仅用于通知和通信目的）。\n\n送达证明\n\n（除非 Fed. R. Civ. P. 45 要求，否则本节不应向法院提交。）\n\n我于（日期）收到向（个人姓名及职务，如有）发出的本传票。\n\n本人通过向所列明人员送达副本，以如下方式送达传票：\n\n于（日期）；或\n\n本人因下列原因退回未执行的传票：\n\n除非该传票是代表美国或其官员或代理人签发，本人亦已向证人支付一天出庭费用及法律允许的里程费用，金额为 \\$ 。\n\n本人的差旅费用为 \\$ ，服务费用为 \\$ ，合计 \\$ 。\n\n本人在伪证罪处罚的约束下声明，本信息真实、正确。\n\n日期：\n\n送达人签名\n\n正楷姓名及职务\n\n送达人地址\n\n关于尝试送达等事项的附加信息：\n《联邦民事诉讼规则》第45(c)、(d)、(e)及(g)条（2013年12月1日生效）（依据《联邦破产程序规则》第9016条适用于破产案件）\n(c) 履行地点。\n\n(1) 审判、听证或证言录取。传票仅可按如下方式命令某人出席审判、听证或证言录取：\n\n(A) 在该人居住、受雇或经常亲自办理业务地点100英里以内；或\n\n(B) 在该人居住、受雇或经常亲自办理业务所在州内，若该人\n\n(i) 是当事人或当事人的高级职员；或\n\n(ii) 被命令出席审判，且不会产生重大费用。\n\n(2) 其他证据开示。传票可命令：\n\n(A) 在该人居住、受雇或经常亲自办理业务地点100英里以内的地点提交文件、电子存储信息或物品；以及\n\n(B) 在待检查场所对该场所进行检查。\n(d) 保护受传票约束之人；执行。\n\n(1) 避免不当负担或费用；制裁。负责签发及送达传票的当事人或律师必须采取合理措施，避免对受传票约束之人施加不当负担或费用。要求履行的地区法院必须执行该义务，并对未遵守者，即当事人或律师，施加适当制裁，其中可包括损失的收入及合理的律师费。\n(2) 命令提交材料或允许检查。\n\n(A) 无须出庭。被命令提交文件、电子存储信息或有形物品，或允许检查场所之人，无须亲自到提交或检查地点出庭，除非同时被命令为证言录取、听证或审判而出庭。\n\n(B) 异议。被命令提交文件或有形物品或允许检查的人，可以向传票中指定的当事人或律师送达书面异议，反对检查、复制、测试或抽样任何或全部材料，或反对检查场所，或反对以所要求的一种或多种形式提交电子存储信息。异议必须在规定的履行时间或传票送达后14日届满之前（以较早者为准）送达。如提出异议，适用下列规则：\n\n(i) 送达方可随时在通知被命令之人后，向要求履行的地区法院提出动议，请求作出强制提交或检查的命令。\n\n(ii) 仅可依命令所指示的方式要求实施该等行为，且该命令必须保护既非当事人亦非当事人高级职员之人，使其免受因履行而产生的重大费用。\n(3) 撤销或修改传票。\n\n(A) 必须撤销或修改的情形。经及时提出动议，要求履行的地区法院必须撤销或修改符合下列情形的传票：\n\n(i) 未给予合理的履行时间；\n\n(ii) 要求某人在第45(c)条规定的地理范围之外履行；\n\n(iii) 如无适用例外或豁免，要求披露享有特权或受其他保护的事项；或\n\n(iv) 对某人施加不当负担。\n\n(B) 可以撤销或修改的情形。为保护受传票约束或受其影响之人，要求履行的地区法院可经动议，在传票要求下列事项时撤销或修改传票：\n\n(i) 披露商业秘密或其他保密的研究、开发或商业信息；或\n\n(ii) 披露未受聘专家的意见或信息，该等意见或信息并非描述争议中的特定事件，且源于未经任何当事人请求的该专家研究。\n\n(C) 以规定条件作为替代。在第45(d)(3)(B)条所述情形下，如送达方：\n\n(i) 证明对证言或材料具有实质需要，且如不造成不当困难则无法以其他方式满足该需要；并且\n\n(ii) 确保受传票人将获得合理补偿，\n\n法院可不撤销或修改传票，而命令在规定条件下出庭或提交。\n(e) 回应传票时的义务。\n\n(1) 提交文件或电子存储信息。下列程序适用于提交文件或电子存储信息：\n\n(A) 文件。回应提交文件传票之人必须按照该等文件在正常业务过程中保存的方式提交，或者必须将其整理并标记为与请求中的类别相对应。\n\n(B) 未规定电子存储信息提交形式。如传票未规定电子存储信息的提交形式，回应人必须以其通常保存的一种或多种形式，或以合理可使用的一种或多种形式提交。\n\n(C) 电子存储信息仅以一种形式提交。回应人无须以一种以上形式提交相同的电子存储信息。\n\n(D) 无法访问的电子存储信息。回应人无须就其认定因不当负担或费用而无法合理访问的信息来源中的电子存储信息提供证据开示。对于强制证据开示动议或保护令动议，回应人必须证明该信息因不当负担或费用而无法合理访问。如作出该证明，法院在考虑第26(b)(2)(C)条限制后，如请求方证明有正当理由，仍可命令从该等来源进行证据开示。法院可规定该证据开示的条件。\n(2) 主张特权或保护。\n\n(A) 扣留的信息。基于该信息享有特权或作为审判准备材料而受保护的主张，扣留被传唤信息之人必须：(i) 明确提出该主张；并且\n\n(ii) 以一种方式描述被扣留文件、通信或有形物品的性质，使当事人能够评估该主张，且不披露本身享有特权或受保护的信息。\n\n(B) 已提交的信息。如为回应传票而提交的信息受特权主张或作为审判准备材料受保护的主张约束，提出该主张之人可将该主张及其依据通知收到该信息的任何当事人。收到通知后，当事人必须立即返还、隔离或销毁所指明的信息及其持有的任何副本；在该主张得到解决前，不得使用或披露该信息；如该当事人在收到通知前已披露该信息，必须采取合理措施予以追回；并可立即将该信息密封提交给要求履行的地区法院，以裁定该主张。提交该信息之人必须在该主张得到解决前保存该信息。\n\n(g) 藐视法庭。要求履行的地区法院——以及在动议移送后，签发传票的法院——可认定已被送达但无充分理由未遵从传票或相关命令之人构成藐视法庭。\n\n如需查阅传票材料，参见《联邦民事诉讼规则》第45(a)条委员会说明（2013年）\n\n……\n\n文件提交请求\nI. 指示\n\n1. 除非另有说明，下列文件请求（以下简称“请求”，每一项称为“一项请求”）必须分别且具体地作出回应。除非善意提出异议，否则每项请求均应得到完整答复；如提出异议，应按如下规定详细说明贵方异议的理由。如异议仅涉及某项请求的一部分，或其中所含的一个词语、短语或条款，贵方仅须说明对该部分的异议，并对其余请求作出回应。\n\n2. 电子存储信息必须按照以下指示提交：\n\n- a. 图像。黑白图像必须为300 DPI Group IV单页TIFF文件。彩色图像必须以JPEG格式提交。文件名不得包含嵌入空格或特殊字符（包括逗号）。文件夹名称不得包含嵌入空格或特殊字符（包括逗号）。所有TIFF图像文件必须具有唯一文件名，即Bates编号。每张图像右下角必须标注连续的Bates编号。每个文件夹中的TIFF文件不得超过1000个。Excel电子表格应具有以该文件Bates编号命名的占位图像。\n- b. 图像加载文件\n\t- a. Concordance® 数据文件。数据文件（.DAT）包含将加载至Concordance®数据库的全部字段信息。.DAT文件的第一行必须为标明字段名称的标题行。.DAT文件必须使用下列Concordance®默认分隔符：逗号 ASCII 字符（020）引号 þ ASCII 字符（254）。日期字段应以如下格式提供：mm/dd/yyyy。日期与时间字段必须为两个独立字段。如文件包括已成像的电子邮件及附件，则必须包括附件字段，以保留电子邮件与其附件之间的父/子关系。必须包括OCRPATH字段，以提供已提交存储介质上提取文本文件的文件路径及名称。文本文件必须以FIRSTBATES命名。不得在.DAT文件中包含文本。对于含有原生文件的文件，必须包括LINK字段，以提供原生文件的文件路径及\n\n名称。原生文件必须以FIRSTBATES命名。\n\n- b. Concordance Image® 或 Opticon 交叉引用文件。图像交叉引用文件（.LOG 或 .OPT）将图像与数据库记录关联。该文件应为逗号分隔文件，每行由七个字段组成，且数据库中的每一图像均应在交叉引用文件中对应一行，格式如下：ImageID,VolumeLabel,ImageFilePath,DocumentBreak,FolderBreak,Box Break,PageCoun。\n\n- c. 文档文本。文本必须以单独的文本文件形式提供，而非作为 .DAT 文件内的字段。文本文件的完整路径（OCRPATH）应包含在 .DAT 文件中。建议提供文档级 ANSI 文本文件，并按 FIRSTBATES/Image Key 命名。提取的文本文件必须置于单独文件夹中，每个文件夹内的文本文件数量不得超过 1,000 个。文件夹名称中不得含有特殊字符（包括逗号）。文本文件必须按文档级别提供。\n\n- d. 特定文件类型的原生格式提供。为全面理解其内容和含义而合理需要以原生格式查看的文件类型，必须以原生格式提供。其中包括但不限于：电子表格、类似电子表格的文件（Microsoft Excel（微软 Excel）、逗号分隔值、制表符分隔值等）、Microsoft PowerPoint（微软 PowerPoint）或其他特殊演示文件、数据库文件及音频/视频文件。应提供一张带有 Bates 编号的分隔页图像，以表明存在原生文件，并将原生文件的路径作为 .dat 文件中的字段列入。所提供的原生文件应以与该文件分隔页对应的 Bates 编号命名。原生文件应归入依次命名的“NATIVE”目录中，并与图像目录分开。\n\n- e. 去重。对于存在完全重复件的每一电子文档，仅提供一份副本。对于电子邮件，应根据由 BCC、Body、CC、From、IntMsgID、To 和 Attach 属性生成的 MD5 哈希值合并重复件。对于电子邮件附件和独立电子文件，应根据整个文件的 MD5 哈希值合并重复件。\n\n- f. 元数据。以符合 Concordance 规范的加载文件（.dat）形式提供每一文档的提取元数据。.DAT 文件的第一行必须为标识字段名称的标题行。.DAT 文件必须使用以下 Concordance 默认分隔符：逗号 , ASCII 字符（020）引号 þ ASCII 字符（254）\n\n日期字段应按以下格式提供：mm/dd/yyyy。日期字段和时间字段必须为两个单独字段。所需元数据如下：\n案号 22-50073 文档 1592 提交日期 03/24/23 登记日期 03/24/23 10:57:37 第 917 页，共 1063 页\n\n字段名称　示例数据　说明\n\nFIRSTBATES　EDC0000001　原生文件文档/电子邮件的第一个 Bates 编号\nLASTBATES　EDC0000001　原生文件文档/电子邮件的最后一个 Bates 编号\n**对于单页文件，应填写 LASTBATES 字段\nATTACHRANGE　EDC0000001\n-　父文档第一页的 Bates 编号至最后一个\nEDC0000015　附件“子”文档最后一页的 Bates 编号\nBEGATTACH　EDC0000001　附件范围的第一个 Bates 编号\nENDATTACH　EDC0000015　附件范围的最后一个 Bates 编号\nCUSTODIAN　Smith, John（约翰·史密斯）　电子邮件：该电子邮件所在的邮箱\n原生文件：文档来源文件所属的个人或部门名称\nFROM　John Smith　电子邮件：发件人\n原生文件：文档作者\n**多个条目之间应使用分号分隔\nTO　Coffman, Janice（贾尼斯·科夫曼）; LeeW　收件人\n[mailto:LeeW@MSN.com]　**多个条目之间应使用分号分隔\nCC　Frank Thompson（弗兰克·汤普森） [mailto:　抄送收件人\nfrank_Thompson@cdt.com]　**多个条目之间应使用分号分隔\nBCC　John Cain（约翰·凯恩）　密送收件人\n**多个条目之间应使用分号分隔\nSUBJECT　Board Meeting Minutes　电子邮件：电子邮件主题行 原生文件：文档标题（如有）\nFILE_NAME　BoardMeetingMinutes.docx　原生文件：原始原生文件名称，包括扩展名\nDATE_SENT　10/12/2010　电子邮件：电子邮件发送日期\n原生文件：（空）\nTIME_SENT/\nTIME_ZONE　07:05 PM GMT　电子邮件：电子邮件发送时间/电子邮件标准化所在的时区\nTIME_ZONE　GMT　在转换过程中电子邮件被标准化的时区。\nLINK　EDC0000001.msg　指向电子邮件或原生文件文档的超链接\n**链接文件必须按 FIRSTBATES 编号命名\nFILE_EXTEN　MSG　表示电子邮件或原生文件的文件类型扩展名\nAUTHOR　John Smith　电子邮件：（空）\n原生文件：文档作者\nDATE_CREATED　10/10/2010　电子邮件：（空）\n原生文件：文档创建日期\n案号 22-50073 文档 1592 提交日期 03/24/23 登记日期 03/24/23 10:57:37 第 918 页，共 1063 页\n\nTIME_CREATED　10:25 AM　电子邮件：（空）\n\n原生文件：文档创建时间\n**该数据必须为单独字段，不得与 DATE_CREATED 字段合并\nDATE_MOD　10/12/2010　电子邮件：（空）\n原生文件：文档最后修改日期\nTIME_MOD　07:00 PM　电子邮件：（空）\n原生文件：文档最后修改时间\n**该数据必须为单独字段，不得与 DATE_MOD 字段合并\nDATE_ACCESSD　10/12/2010　电子邮件：（空）\n原生文件：文档最后访问日期\nTIME_ACCESSD　07:00 PM　电子邮件：（空）\n原生文件：文档最后访问时间\n**该数据必须为单独字段，不得与 DATE_ACCESSD 字段合并\nFILE_SIZE　5,952　原生文件文档/电子邮件的大小，以 KB 计\nPGCOUNT　1　原生文件文档/电子邮件的页数\nPATH　电子邮件：（空）\nAgenda.doc　原生文件：存储原生文件文档的路径，包括原始文件名。\nINTFILEPATH　Personal Folders\\Deleted　电子邮件：电子邮件的原始位置，包括原始文件名。\nItems\\Board Meeting\nMinutes.msg　原生文件：（空）\nINTMSGID　<000805c2c71b\\$75977050\\$　电子邮件：唯一消息 ID 原生文件：（空）\ncb8306d1@MSN>\nMD5HASH　d131dd02c5e6eec4693d9a0　文档的 MD5 哈希值。\n698aff95c\n2fcab58712467eab4004583e\nb8fb7f89\nOCRPATH　TEXT/001/EDC0000001.txt　原生文件提取文本的路径\n\n3. 每一项请求均独立运作并应独立解释；除非另有说明，任何一项请求均不限制任何其他请求的范围。\n\n4. 所有文档应按通常业务过程中保存的方式提供，或者应进行整理和标注，以对应本请求中的类别。\n\n5. 本文所载每一项请求均延及所有文档：(a) 在您占有、保管或控制之下的文档；或 (b) 在任何代表您行事之人占有、保管或控制之下的文档，\n案号 22-50073 文档 1592 提交日期 03/24/23 登记日期 03/24/23 10:57:37 第 919 页，共 1063 页\n\n包括您的律师或其他代表及顾问。每一文档均应完整提供。\n\n6. 如要求您提供的某一文档已不再处于您的占有、保管或控制之下，则您的答复必须：(a) 详细说明该文档的性质及其内容；(b) 识别编制或撰写该文档的人员（以及，如适用，该文档被发送给的人员）；(c) 识别该文档编制或创建的日期；(d) 说明该文档是否：(i) 缺失或遗失，(ii) 已被销毁，(iii) 已自愿或非自愿地转移给他人，或 (iv) 以其他方式被处置；(e) 说明该等处置的原因以及相关事实和情况；(f) 识别授权该等处置的人员；(g) 识别该等处置的日期或大致日期；(h) 说明该文档最近一次处于您的占有、保管或控制之下的时间；以及 (i) 识别目前占有、保管或控制该文档的人员（如有）。\n\n7. 如要求您提供的某一文档已被销毁，则除前述指示所要求的信息外，您的答复还必须说明：(a) 销毁该文档的原因；(b) 销毁该文档的人员身份；以及 (c) 指示销毁该文档的人员身份。\n\n8. 如您主张某一被请求的文档享有特权或属于律师工作成果，则您的答复必须：(a) 说明：(i) 足以支持您关于该文档享有特权之主张的文档描述，(ii) 文档标题，(iii) 文档日期，(iv) 文档作者，(v) 文档收件人，(vi) 收到或阅览该文档原件、任何草稿、副本或复制件的每一人员的身份，(vii) 该文档本身，或该文档中包含或提及的任何信息，是否处于任何其他人员的占有、保管或控制之下；如是，则应识别该等人员的身份，以及说明该信息如何进入其占有，\n案号 22-50073 文档 1592 提交日期 03/24/23 登记日期 03/24/23 10:57:37 第 920 页，共 1063 页\n\n(viii) 据以扣留该文档的特权主张，以及 (ix) 您将依赖以支持该特权主张的所有情况；以及 (b) 就根据特权主张而被扣留的每一文档，依照 D. Conn. L. Civ. R. 26(e)，制作一份特权日志，其中包含本指示第 (a) 部分所要求的全部信息。\n\n9. 如一份原本应提供的文档的一部分包含受特权主张约束的信息，则仅应依照上述指示从该文档中删除或遮盖受该特权主张约束的部分，其余部分应予提供。\n\n10. 本请求具有持续性。特此指示您：(a) 一旦获悉先前答复不完整或不正确，应立即补充或更正任何后来发现不完整或不正确的答复；以及 (b) 提供根据下列规定所要求的任何额外文档\n\n11. 如某一文档使用英语以外的语言，您应提供该文档。如某一文档使用英语以外的语言，且存在英文译本，您应同时提供两份文档。\n\n12. 对实体的一切提及均包括其所有关联方。\n\n13. 对个人姓名的一切提及均包括所有替代姓名、化名或昵称。\n\n14. 除非另有明确说明，文档请求所涵盖的期间为自 February 5, 2012 起至文档请求答复到期之日止。\n案号 22-50073 文档 1592 提交日期 03/24/23 登记日期 03/24/23 10:57:37 第 921 页，共 1063 页\n\nII. 解释规则\n\n15. (a) 任何单数名词的使用应解释为包括复数，反之亦然；以及 (b) 任何时态动词的使用应解释为包括该动词所有其他时态的使用。\n\n16. (a) “and”和“or”应在必要时解释为连词或析取词，以使原本可能被解释为不属于任何请求范围的所有答复均纳入该请求范围；以及 (b) “each”和“any”应视为包括并涵盖“every”和“all”之词。\nIII. 定义\n\nD. Conn. L. Civ. R. 26(c) 所规定的定义以及 D. Conn. L. Civ. R. 26(d) 所规定的解释规则，经 D. Conn. Bankr. L.R. 2004-1(a) 纳入后，适用于文档请求。此外，本文件请求中使用的下列术语具有以下含义：\n\n1. “您”或“您的”或“您本人”系指 FungWan Trading Inc.（FungWan 贸易公司），连同其所有关联方、部门、机构、工具机构、处室、办公室、合伙人、高级职员、董事、代理人、律师、代表、雇员和/或任何代表其行事之人。\n\n2. “债务人”系指 Ho Wan Kwok（郭文贵）（又名 Miles Kwok、Miles Guo、Guo Wengui、Guo Haoyun、郭文贵，或任何其他化名），连同其雇员、代理人、律师、顾问或任何代表其行事之人。\n\n3. “债务人之子”系指 Qiang Guo（郭强，亦称 Mileson Kwok 或任何其他别名），以及其雇员、代理人、律师、顾问或任何代表其行事之人。\n案件 22-50073 文件 1592 提交日期 03/24/23 录入日期 03/24/23 10:57:37 第 922 页，共 1063 页\n\n4. “债务人之女”系指 Mei Guo（郭美，亦称 Mei Gui 或任何其他别名），以及其雇员、代理人、律师、顾问或任何代表其行事之人。\n\n5. “债务人所谓之妻”系指 Hing Chi Ngok（岳庆芝，亦称 Hing Chi Ng、Yue Qingzhi 或任何其他别名），以及其雇员、代理人、律师、顾问或任何代表其行事之人。\n\n6. “债务人家属”统称债务人、债务人之子、债务人之女、债务人所谓之妻，以及与债务人具有任何其他亲属关系之人。\n\n7. “关联个人”单独及共同地系指：(1) 持有、控制、保管债务人或债务人家属所有、控制或享有之资产，或对该等资产拥有酌处权的所有个人；或 (2) 曾任一个或多个关联实体的雇员、董事，或以其他方式与一个或多个关联实体有关联的所有个人，以及前述任何个人各自的雇员、代理人、律师、顾问或任何代表其行事之人。该等关联个人应包括但不限于：Daniel Podhaskie、Jason Miller、Steve Bannon、Karin Maistrello、Melissa Francis、Anthony DiBattista、William Gertz、Arethusa Forsyth、Glenn Mellor、Jennifer Mercurio、Eduardo Eurnekian、Wencong Wang、Han Chunguang（韩春光）、Qu Guojiao（屈国姣，亦称 Qu Guo Jiao）、Guo Lijie（郭丽杰）、Zhang Wei（张伟*）、Lihong Wei Lafrenz（魏丽红，亦称 Sara Wei）、Hao Haidong（郝海东）、Ross Heinemeyer、Max Krasner、Kyle Bass、Melissa Mendez、Ya Li（李娅）、Dinggang Wang（王定刚）、An Hong（安红）、Yvette Wang（王雁平，亦称 Yanping Wang、Yan Ping Wang）、Fiona Yu、Je Kin Ming（余建明，亦称 William Je、Yu Jianming）、Yaz Qingua 及 Lao Jiang（姜云浮，亦称 Jiang Yunfu、Jiang Yunfu Be）。\n案件 22-50073 文件 1592 提交日期 03/24/23 录入日期 03/24/23 10:57:37 第 923 页，共 1063 页\n\n8. “关联实体”单独及共同地系指：(1) 已由债务人或债务人家属拥有、控制或投资的任何类型的所有组织或实体；或 (2) 对债务人或债务人家属所有、控制或享有的任何资产直接或间接拥有权益的任何类型的所有组织或实体，以及前述任何实体各自的雇员、代理人、律师、顾问或任何代表其行事之人。该等关联实体应包括但不限于：7 Nod Hill LLC、AAGV Limited、ACA Investment Management Limited、ACA Capital Group Limited、Ace Decade Holdings Limited、AI Group Holdings Inc.、Alfa Global Ventures Limited、Alfonso Global Limited、Allied Capital Global Limited、Alpine Fiduciaries SA、Anton Development Limited、Assets Sino Limited、Auspicious Coast Limited、Beijing Pangu Investment Co.、Beijing Pangu Investment Co. Ltd.、Beijing Pangu Investment Inc.、Beijing Zenith Holdings Company Limited、Booming Sail New York LLC、Bravo Luck Limited、BSA Strategic Fund I、China Golden Spring (Hong Kong) Limited、Chuang Xin Limited、Crane Advisory Group LLC、Creative Apex Investments Limited、Crystal Breeze Investments Limited、Dawn State Limited、Eastern Profit Corporation Limited、Elite Well Global Limited、Empire Growth Holdings、Freedom Media Ventures Ltd.、G Club Operations LLC、G Fashion LLC、G News LLC、GETTR USA、Genever Holdings Corporation、Genever Holdings LLC、Gfashion Media Group Inc.、GFNY, Inc.、Globalist International Limited、GNews Media Group Inc.、Golden Spring (New York) Ltd.、Greenwich Land LLC、Guo Media、GTV Media Group, Inc.、Hamilton Capital Holdings Inc.、HCHK Property Management, Inc.、HCHK Technologies, Inc.、Head Win Group Limited、Henan Yuda、Himalaya Embassy、Himalaya Exchange、Himalaya Federal Reserve、Himalaya Investment LLC、Himalaya International、Himalaya New World Inc.、Himalaya Supervisory Organization、Himalaya Ventures LLC、HK International Funds Investments (USA) Limited LLC、Hong Kong International Funds\n案件 22-50073 文件 1592 提交日期 03/24/23 录入日期 03/24/23 10:57:37 第 924 页，共 1063 页\n\nInvestments Limited、Hudson Diamond Holding、Infinite Increase Limited、Infinitum Developments Limited、Infinity Treasury Management Inc.、Insight Phoenix Fund、Lamp Capital LLC、Leading Shine Limited、Leading Shine NY Limited、Lexington Property and Staffing、Long Gate Limited、Maywind Trading LLC、MOS Himalaya LLC、Next Tycoon Investments Limited、New Federal State of China（中国新联邦，亦称 NFSC）、Noble Fame Global Limited、Rosy Acme Ventures Limited、Rule of Law Foundation III, Inc.、Rule of Law Foundation IV, Inc.、Rule of Law Fund、Rule of Law Society、Rule of Law Society IV, Inc.、G-Translators PTY LTD、Saraca Media Group, Inc.、Shiny Ace Ltd.、Shiny Times Holdings Ltd.、Spirit Charter Investment Limited、Stevenson, Wong & Co.、Voice of Guo Media, Inc.、Well Origin Ltd.、World Century Limited、Worldwide Opportunity Holdings Limited、Whitecroft Shore Limited 及 ZIBA Limited。\n\n9. “包括”或其任何变体，系指“包括但不限于”。\n\n10. “和”及“或”系指“和/或”，并应作连词性及析取性解释，以最大限度扩大其范围。\n\n11. “任何”、“所有”及“每一”均系指“每一个及全部”。\n\n12. “每一”及“每个”均系指“每一个及全部”。\n\n13. “第三方”系指除您本人以外的个人或实体。\n\n14. “转让”应具有《破产法典》第 101(54) 条赋予该词的含义。\n\n15. “文件”系指属于《联邦民事诉讼规则》第 34 条范围内的任何信息或物品，并包括但不限于任何种类、类型、性质或描述的每一项书面、记录或图形材料，该等材料现由或曾由您占有、保管或控制，包括电子邮件的所有印刷及电子副本、以\n案件 22-50073 文件 1592 提交日期 03/24/23 录入日期 03/24/23 10:57:37 第 925 页，共 1063 页\n\n电子形式保存的计算机文件、电子通信、短信、社交媒体帖子、推文、元数据、通信函件、备忘录、磁带、速记或手写笔记、任何种类的书面表格、图表、蓝图、图纸、草图、图形、计划、文章、规格说明、日记、信函、电报、照片、会议记录、合同、协议、调查资料、计算机打印件、任何种类的数据汇编、电传、传真、语音留言、发票、订购单、支票、汇票、对账单、贷项通知单、报告、持仓报告、摘要、索引、书籍、账簿、笔记本、清单、透明胶片、录音、目录、广告、宣传材料、影片、录像带、录音带、CD、计算机磁盘、小册子、宣传单、穿孔卡、工时单、推文、社交媒体帖子或任何其他种类的书面或记录材料，以及其所有元数据；无论其以何种方式存储（无论为有形或电子形式）、记录、制作或复制；还包括但不限于前述任何文件的草稿或副本，如其包含原始文件中不存在的任何种类笔记、评论或标记，或在其他方面与原始文件不完全相同。\n\n16. “个人”系指个人、公司、独资企业、合伙企业、协会或任何其他实体。“个人”还包括任何代理人、代表或专家，包括但不限于律师或财务顾问。\n\n17. “实体”系指任何自然人、公司、合伙企业、子公司、独资企业、商号、董事会、合资企业、协会、机构、主管机关、委员会或其他商业实体或法人，以及任何关联方、代理人、母公司，包括但不限于法律顾问、财务顾问或任何其他代表。\n\n18. “关于”系指涉及、描述、包含、提及、与之相关、支持、赞成、反对、加强、减损、载于、结合考虑、影响、证明、表明、报告、记录、暗指、答复、\n案件 22-50073 文件 1592 提交日期 03/24/23 录入日期 03/24/23 10:57:37 第 926 页，共 1063 页\n\n与之相连、评论、就其而言、有关、与之相关、讨论、显示、描述、反映、分析、构成及属于。\n\n19. 在提及任何特定事项时，“与……有关”、“涉及”或“相关”，系指但不限于构成、包含、涉及、载有、体现、反映、识别、陈述、直接或间接提及该特定事项，或以任何方式与已确定的该特定事项相关的任何文件。\n\n20. “通信”应作最广义且不受限制的理解，系指任何信息或知识的传递（以事实、观点、询问或其他形式）。通信还系指所有谈话、协议、询问或答复，无论系当面、通过电话、书面方式，或借助电子传输设备进行，并包括但不限于所有函件、电子邮件、录音、传送单、备忘录、电话通信、语音留言、电报、电传传真、影印传真、电传、即时消息、聊天、短信、电话记录，或在内部或与第三方之间传递的笔记。\n\n21. “资产”系指可用于产生正面经济价值的任何项目，包括但不限于由某一实体拥有、控制或为该实体利益而持有，且预期可提供未来利益的任何具有经济价值的资源，包括但不限于所有不动产和动产、无形财产、投资、投资权或未来收益权、现金、银行账户、商品、证券、债权、对某一实体的全部或部分控制权以及预期经济机会。\n\n22. “转让”应具有《破产法典》第 101(54) 条赋予该词的含义。\n\nIV. 应提交的文件\n\n1. 关于债务人、债务人破产财产或关联实体的任何收入或资产的所有文件。\n\n2. 与债务人的财务状况及其对债权人的义务有关的所有文件，包括但不限于与任何规避支付该等义务的努力有关的所有文件，以及与本案或任何其他实际或潜在破产或类似无力偿债程序有关的所有文件。\n\n3. 关于与债务人、债务人破产财产、债务人家属、关联实体或关联个人有关的任何资产负债表、银行对账单、账户对账单、财务报表、账户结单、电汇指令和/或确认、资金证明、存款证、持仓证明、投资组合摘要或类似文件的所有文件，包括但不限于足以显示向前述任何主体作出的所有转让的所有文件。\n\n4. 关于债务人作出、与债务人进行或代表债务人作出的任何投资、商业交易或交易的所有文件。\n\n5. 与债务人的所有通信，以及与债务人之间通信有关、涉及任何实体（包括但不限于关联实体）的运营、管理或决策的文件。\n\n6. 关于向债务人、债务人家属或关联实体作出，或由债务人、债务人家属或关联实体作出，或与其进行的任何转让、投资或其他交易或商业往来的所有文件。\n\n7. 关于债务人曾经占用或使用的任何财产的所有文件，包括但不限于 Lady May；Sherry Netherland Hotel / Condominium；位于 Connecticut（康涅狄格州）Greenwich（格林尼治）373 Taconic Rd. 的住宅物业；位于 Connecticut（康涅狄格州）Greenwich（格林尼治）33 Ferncliff Rd. 的住宅物业；以及位于 Connecticut（康涅狄格州）Wilton（威尔顿）354 Nod Hill Rd. 的住宅物业。\n\n8. 与债务人拥有、控制或使用的任何航空器有关的所有文件，包括但不限于尾号为 T7-GQM 的航空器以及在圣马力诺登记的任何其他航空器，包括但不限于所有登记文件副本，以及显示该等航空器所执行航班及该等航班机上人员的飞行清单。\n\n9. 关于向债务人、债务人破产财产、债务人家庭成员或关联实体提供、从其取得或代表其提供的任何馈赠、利益或贷款的所有文件，包括但不限于足以显示该等馈赠、利益或贷款金额；该等馈赠、利益或贷款的使用目的；提供该等馈赠、利益或贷款的时间；以及任何贷款的条款、与任何贷款有关的所有陈述与保证、任何贷款的利率以及任何贷款付款的所有证据的文件。\n\n10. 关于由债务人、代表债务人或为债务人、债务人破产财产、债务人家庭成员或关联实体之利益而设立的任何信托或类似文书的所有文件，包括但不限于足以显示信托的设立时间、设立人、受益人及信托财产的文件。\n\n11. 与涉及债务人的任何法律争议有关的任何义务、请求权、责任或债务相关的所有文件，包括但不限于与在任何地方、州、联邦或国际机构（无论是行政机构、法院、合议庭或替代性争议解决实体）进行的任何诉讼有关的文件。\n案件 22-50073 文书 1592 已提交 03/24/23 已录入 03/24/23 10:57:37 第 929 页，共 1063 页\n\n12. 你方任何外聘律师或其他顾问与债务人之间的所有文件及通信。\n\n13. 足以显示你方全部资产以及收入或资金来源的文件。\n\n14. 对第14项请求的答复中所识别的、价值超过 $50,000 的所有资产，提供：(i) 与你方取得该等资产有关的所有文件；以及 (ii) 你方与债务人或债务人家庭成员就该等资产进行的通信。\n\n15. 你方纳税申报表副本。\n\n16. 足以显示处于你方占有或控制之下的所有银行账户和投资账户的文件，包括每一该等账户的余额及向该等账户转入和从该等账户转出的款项。\n\n17. 关于你方使用的任何信用卡的所有文件，包括但不限于月度对账单或足以显示为债务人或关联实体之利益而进行的与该等信用卡有关的所有购买的其他文件。\n\n18. 所有公司治理及组织文件，包括但不限于章程细则、公司注册证书及足以显示你方公司结构、高级职员和董事姓名、经营目的以及与债务人或债务人任何家庭成员关系的其他文件。\n\n19. 与将你方任何资产质押给任何其他实体有关的所有文件。\n附件 C-51\nB2540（表格 2540——依第2004条规则审查的传票）（12/15）案件 22-50073 文书 1592 已提交 03/24/23 已录入 03/24/23 10:57:37 第 931 页，共\n\n美国破产法院\n\n康涅狄格区\n\n关于 HO WAN KWOK（郭文贵）等人的事项，\n\n1 案件编号 22-50073 (JAM)\n\n债务人 第11章\n\n（合并管理）\n依第2004条规则审查的传票\n\n致：Huk Trading Inc.（Huk贸易公司）\n\n（传票所指向之人的姓名）\n\n证言：现命令你方于下列规定的时间、日期和地点出席，并根据《联邦破产程序规则》第2004条接受审查并作证。随附准许该审查的法院命令副本。\n\n地点　日期及时间\n\nPaul Hastings LLP（普衡律师事务所）\n200 Park Avenue　[TBD]\nNew York, New York 10166\n\n审查将通过以下方式记录：法庭书记员/速记员\n\n提交：你方或你方代表还必须在审查时携带下列文件、电子存储信息或物品，并必须允许对该等材料进行查验、复制、测试或抽样：\n见随附的文件提交请求。\n\n《联邦民事诉讼规则》第45条的下列规定，依《联邦破产程序规则》第9016条适用于破产案件，现随附于后——关于履行地点的第45(c)条；关于保护作为传票对象之人的第45(d)条；以及关于你方回应本传票的义务和未作回应之潜在后果的第45(e)条和第45(g)条。\n\n日期：March , 2023\n\n法院书记员\n\n或\n\n书记员或副书记员签名　律师签名\n\n签发或请求签发本传票的、代表第11章破产管理人 Luc A. Despins（吕克·A·德斯平斯）的律师姓名、地址、电子邮件地址和电话号码如下：\n\nDouglas S. Skalka, Esq.（道格拉斯·S·斯卡尔卡律师）；Neubert, Pepe & Monteith, P.C.（纽伯特、佩佩及蒙蒂思专业公司）；195 Church Street, New Haven, Connecticut 06510；dskalka@npmlaw.com；(203) 821-2000\n\n致签发或请求签发本传票之人的通知\n\n如本传票命令在审判前提交文件、电子存储信息或有形物品，或检查场所，则必须在向传票所指向之人送达之前，向每一当事人送达通知及本传票副本。《联邦民事诉讼规则》第45(a)(4)条。\n\n软件版权 (c) 1996-2022 Best Case, LLC（贝斯特凯斯有限责任公司）- www.bestcase.com Best Case Bankruptcy 1 本第11章案件的债务人为 Ho Wan Kwok（郭文贵，亦称 Guo Wengui（郭文贵）、Miles Guo（郭文贵）和 Miles Kwok（郭文贵），以及众多其他别名）（税务识别号码后四位：9595）、Genever Holdings LLC（杰纳弗控股有限责任公司）（税务识别号码后四位：8202）及 Genever Holdings Corporation（杰纳弗控股公司）。破产管理人、Genever Holdings LLC 和 Genever Holdings Corporation 的邮寄地址为 Paul Hastings LLP（普衡律师事务所）, 200 Park Avenue, New York, NY 10166，转交 Luc A. Despins，作为 Ho Wan Kwok 破产财产的破产管理人（仅为通知及通信之目的）。\n\n送达证明\n\n（除非《联邦民事诉讼规则》第45条要求，否则本节不应向法院提交。）\n\n我于（日期）收到向（个人姓名及职务，如有）发出的本传票。\n\n我以下述方式向被指定之人交付副本，送达本传票：\n\n于（日期）送达；或\n\n我未予执行而退回本传票，原因如下：\n\n除非本传票代表美国或其官员或代理人签发，我还已向证人支付法律允许的一日出席费用及里程费，金额为 $ 。\n\n我的差旅费为 $，服务费为 $，合计为 $ 。\n\n我在伪证处罚的约束下声明，本信息真实且准确。\n\n日期：\n\n送达人员签名\n\n正楷姓名及职务\n\n送达人员地址\n\n关于尝试送达等的补充信息：\n《联邦民事诉讼规则》第45(c)、(d)、(e)及(g)条（自 12/1/13 生效）（依《联邦破产程序规则》第9016条适用于破产案件）\n(c) 履行地点。\n\n(1) 审判、听证或证言录取。传票仅可按下列方式命令某人出席审判、听证或证言录取：\n\n(A) 在该人居住、受雇或经常亲自办理业务之地点的100英里范围内；或\n\n(B) 在该人居住、受雇或经常亲自办理业务所在的州内，如该人：\n\n(i) 为当事人或当事人的高级职员；或\n\n(ii) 被命令出席审判且不会产生重大费用。\n\n(2) 其他证据开示。传票可以命令：\n\n(A) 在该人居住、受雇或经常亲自办理业务之地点的100英里范围内的地点提交文件、电子存储信息或物品；以及\n\n(B) 在应检查的场所检查场所。\n(d) 保护作为传票对象之人；执行。\n\n(1) 避免不当负担或费用；制裁。负责签发和送达传票的当事人或律师必须采取合理步骤，避免对作为传票对象之人施加不当负担或费用。要求履行的地区法院必须执行该义务，并对未遵守该义务的当事人或律师施加适当制裁，其中可包括损失的收入和合理的律师费。\n\n(2) 命令提交材料或允许检查。\n\n(A) 无须出席。被命令提交文件、电子存储信息或有形物品，或允许检查场所之人，无须亲自到提交或检查地点出席，除非同时被命令出席证言录取、听证或审判。\n\n(B) 异议。被命令提交文件或有形物品，或允许检查之人，可以向传票中指定的当事人或律师送达书面异议，反对检查、复制、测试或抽样任何或全部材料，或反对检查场所，或反对以所请求的一种或多种形式提交电子存储信息。异议必须在规定的履行时间之前，或在传票送达后14日内，以较早者为准送达。如提出异议，适用下列规则：\n\n(i) 送达方可随时在通知被命令之人后，向要求履行的地区法院提出动议，请求作出强制提交或检查的命令。\n\n(ii) 仅可依命令所指示的方式要求实施该等行为，且该命令必须保护既非当事人亦非当事人高级职员之人免于承担因履行而产生的重大费用。\n(3) 撤销或修改传票。\n\n(A) 必须撤销或修改的情形。经及时动议，要求履行的地区法院必须撤销或修改存在下列情形的传票：\n\n(i) 未留出合理的履行时间；\n\n(ii) 要求某人在第45(c)条规定的地域限制以外履行；\n\n(iii) 要求披露享有特权或受其他保护的事项，且不适用任何例外或豁免；或\n\n(iv) 对某人施加不当负担。\n\n(B) 可以撤销或修改的情形。为保护作为传票对象或受传票影响之人，要求履行的地区法院可依动议撤销或修改要求下列事项的传票：\n\n(i) 披露商业秘密或其他保密的研究、开发或商业信息；或\n\n(ii) 披露未经聘用专家的意见或信息，该等意见或信息并未描述存在争议的具体事件，且系该专家并非应当事人请求所进行研究的结果。\n\n(C) 作为替代方案规定条件。在第45(d)(3)(B)条所述情形下，如送达方：\n\n(i) 证明对证言或材料具有重大需求，且不遭受不当困难即无法以其他方式满足该需求；以及\n\n(ii) 确保被传唤之人将获得合理补偿，\n\n法院可不撤销或修改传票，而是命令在指定条件下出席或提交。\n(e) 回应传票的义务。\n\n(1) 提交文件或电子存储信息。下列程序适用于提交文件或电子存储信息：\n\n(A) 文件。回应要求提交文件的传票之人，必须按照文件在正常业务过程中保存的方式提交，或必须将文件整理并标注，使其与请求中的类别相对应。\n\n(B) 未指定提交电子存储信息的形式。如传票未指定提交电子存储信息的形式，回应之人必须以其通常保存的一种或多种形式，或以合理可用的一种或多种形式提交。\n\n(C) 电子存储信息仅以一种形式提交。回应之人无须以一种以上形式提交相同的电子存储信息。\n\n(D) 无法合理电子访问的存储信息。作出回应的人无需就其认定因不当负担或费用而无法合理访问的来源中的电子存储信息提供证据开示。在提出强制证据开示动议或保护令动议时，作出回应的人必须证明该信息因不当负担或费用而无法合理访问。若作出该证明，如请求方在考虑第 26(b)(2)(C) 条的限制后证明存在正当理由，法院仍可命令就该等来源进行证据开示。法院可以规定该证据开示的条件。\n\n(2) 主张特权或保护。\n\n(A) 扣留的信息。依据该信息享有特权或作为审判准备材料受到保护的主张而扣留被传唤信息的人必须：(i) 明确提出该主张；并且\n\n(ii) 以一种方式说明被扣留文件、通信或有形物品的性质，使各方能够评估该主张，同时不披露本身享有特权或受保护的信息。\n\n(B) 已提供的信息。如为回应传票而提供的信息受到特权主张或作为审判准备材料受到保护的主张约束，提出该主张的人可以将该主张及其依据通知任何收到该信息的一方。收到通知后，一方必须立即返还、隔离或销毁指明的信息及其持有的任何副本；在该主张得到解决前不得使用或披露该信息；如该方在收到通知前已披露该信息，必须采取合理措施取回该信息；并可立即将该信息密封提交给要求履行义务所在地区的法院，以裁定该主张。提供该信息的人必须在该主张得到解决前保全该信息。\n\n(g) 藐视法庭。要求履行义务所在地区的法院——以及在动议被移送后，签发传票的法院——可以认定已被送达但无充分理由未遵从传票或与其有关命令的人构成藐视法庭。\n\n有关获取传票材料，请参见 Fed.R.Civ.P.45(a) 委员会说明（2013）\n\n……\n\n文件提交请求\nI. 指示\n\n1. 除非另有说明，下列文件请求（以下简称“请求”，每一项称为“一项请求”）必须分别且具体地作出回应。除非基于善意提出异议，否则必须完整答复每一项请求；如提出异议，应按下文规定详细说明贵方异议的理由。如异议仅涉及某项请求的一部分，或其中包含的一个词语、短语或条款，贵方仅须说明对该部分的异议，并对其余请求作出回应。\n\n2. 电子存储信息必须依照下列指示提供：\n\n- a. 图像。黑白图像必须为 300 DPI Group IV 单页 TIFF 文件。彩色图像必须以 JPEG 格式提供。文件名不得包含嵌入空格或特殊字符（包括逗号）。文件夹名称不得包含嵌入空格或特殊字符（包括逗号）。所有 TIFF 图像文件必须具有唯一的文件名，即 Bates 编号。每张图像右下角必须标注连续的 Bates 编号。每个文件夹内的 TIFF 文件不得超过 1000 个。Excel 电子表格应具有以该文件 Bates 编号命名的占位图像。\n- b. 图像加载文件\n\t- a. Concordance® 数据文件。数据文件（.DAT）包含将加载到 Concordance® 数据库中的所有字段信息。.DAT 文件的第一行必须为标明字段名称的标题行。.DAT 文件必须使用下列 Concordance® 默认分隔符：逗号 ASCII 字符（020）引号 þ ASCII 字符（254）。日期字段应以如下格式提供：mm/dd/yyyy。日期和时间字段必须为两个单独字段。如文件包括已成像的电子邮件及附件，必须包括附件字段，以保留电子邮件与其附件之间的父/子关系。必须包括 OCRPATH 字段，以提供所提交存储介质上提取文本文件的文件路径和名称。文本文件必须以 FIRSTBATES 命名。不得在 .DAT 文件中包含文本。对于包含原生文件的文件，必须包括 LINK 字段，以提供原生文件的文件路径和名称。原生文件必须以 FIRSTBATES 命名。\n\n- b. Concordance Image® 或 Opticon 交叉引用文件。图像交叉引用文件（.LOG 或 .OPT）将图像链接至数据库记录。其应为逗号分隔文件，每行由七个字段组成；数据库中每张图像均应在交叉引用文件中对应一行，格式如下：ImageID,VolumeLabel,ImageFilePath,DocumentBreak,FolderBreak,Box Break,PageCoun。\n- c. 文件文本。文本必须作为单独的文本文件提供，而不得作为 .DAT 文件内的字段提供。文本文件的完整路径（OCRPATH）应包含在 .DAT 文件中。建议使用文件级 ANSI 文本文件，并按 FIRSTBATES/Image Key 命名。提取的文本文件必须置于单独文件夹内，每个文件夹内的文本文件不得超过 1,000 个。文件夹名称不得含有特殊字符（包括逗号）。文本文件必须按文件级提供。\n- d. 某些文件类型的原生格式提供。为充分理解其内容和含义而合理需要以原生格式查看的文件类型，必须以原生格式提供。这些包括但不限于电子表格、类似电子表格的文件（Microsoft Excel、逗号分隔值、制表符分隔值等）、Microsoft PowerPoint 或其他特殊演示文稿文件、数据库文件以及音频/视频文件。应提供一张标有 Bates 编号的分隔页图像，注明存在原生文件，并在 .dat 文件中以字段形式列入原生文件的路径。所提供的原生文件应以与该文件分隔页相对应的 Bates 编号命名。原生文件应归入按递增方式命名的“NATIVE”目录中，并与图像目录分开。\n- e. 去重。对于存在完全重复件的每份电子文件，提供单一副本。对于电子邮件信息，应根据由 BCC、Body、CC、From、IntMsgID、To 和 Attach 属性生成的 MD5 哈希值合并重复件。对于电子邮件附件和独立电子文件，应根据整个文件的 MD5 哈希值合并重复件。\n- f. 元数据。以符合 Concordance 要求的加载文件（.dat）形式提供每份文件的提取元数据。.DAT 文件的第一行必须为标明字段名称的标题行。.DAT 文件必须使用下列 Concordance 默认分隔符：逗号 , ASCII 字符（020）引号 þ ASCII 字符（254）\n\n日期字段应以如下格式提供：mm/dd/yyyy。日期和时间字段必须为两个单独字段。下列为必需元数据：\nCase 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 936 of 1063\n\n字段名称　示例数据　说明\n\nFIRSTBATES　EDC0000001　原生文件文件/电子邮件的第一个 Bates 编号\nLASTBATES　EDC0000001　原生文件文件/电子邮件的最后一个 Bates 编号\n**对于单页文件，应填写 LASTBATES 字段\nATTACHRANGE　EDC0000001\n-　父文件第一页的 Bates 编号至最后一份附件“子”文件最后一页的 Bates 编号\nEDC0000015\nBEGATTACH　EDC0000001　附件范围的第一个 Bates 编号\nENDATTACH　EDC0000015　附件范围的最后一个 Bates 编号\nCUSTODIAN　Smith, John　电子邮件：该电子邮件所在的邮箱\n原生文件：文件来源的个人或部门名称\nFROM　John Smith　电子邮件：发件人\n原生文件：文件作者\n**多个条目应以分号分隔\nTO　Coffman, Janice; LeeW　收件人\n[mailto:LeeW@MSN.com]　**多个条目应以分号分隔\nCC　Frank Thompson [mailto:　抄送收件人\nfrank_Thompson@cdt.com]　**多个条目应以分号分隔\nBCC　John Cain　密送收件人\n**多个条目应以分号分隔\nSUBJECT　Board Meeting Minutes　电子邮件：电子邮件主题行 原生文件：文件标题（如有）\nFILE_NAME　BoardMeetingMinutes.docx　原生文件：原始原生文件的名称，包括扩展名\nDATE_SENT　10/12/2010　电子邮件：电子邮件发送日期\n原生文件：（空）\nTIME_SENT/　07:05 PM GMT　电子邮件：电子邮件发送时间/电子邮件标准化所采用的时区\nTIME_ZONE\nTIME_ZONE　GMT　在转换过程中电子邮件被标准化所采用的时区。\nLINK　EDC0000001.msg　电子邮件或原生文件文件的超链接\n**链接文件必须按 FIRSTBATES 编号命名\nFILE_EXTEN　MSG　代表电子邮件或原生文件的文件类型扩展名\nAUTHOR　John Smith　电子邮件：（空）\n原生文件：文件作者\nDATE_CREATED　10/10/2010　电子邮件：（空）\n原生文件：文件创建日期\nCase 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 937 of 1063\n\nTIME_CREATED　10:25 AM　电子邮件：（空）\n\n原生文件：文件创建时间\n**该数据必须为单独字段，不得与 DATE_CREATED 字段合并\nDATE_MOD　10/12/2010　电子邮件：（空）\n原生文件：文件最后修改日期\nTIME_MOD　07:00 PM　电子邮件：（空）\n原生文件：文件最后修改时间\n**该数据必须为单独字段，不得与 DATE_MOD 字段合并\nDATE_ACCESSD　10/12/2010　电子邮件：（空）\n原生文件：文件最后访问日期\nTIME_ACCESSD　07:00 PM　电子邮件：（空）\n原生文件：文件最后访问时间\n**该数据必须为单独字段，不得与 DATE_ACCESSD 字段合并\nFILE_SIZE　5,952　原生文件文件/电子邮件的大小，单位为 KB\nPGCOUNT　1　原生文件文件/电子邮件的页数\nPATH　电子邮件：（空）\nAgenda.doc　原生文件：存储原生文件文件的路径，包括原始文件名。\nINTFILEPATH　Personal Folders\\Deleted　电子邮件：电子邮件的原始位置，包括原始文件名。\nItems\\Board Meeting\nMinutes.msg　原生文件：（空）\nINTMSGID　<000805c2c71b\\$75977050\\$　电子邮件：唯一信息 ID 原生文件：（空）\ncb8306d1@MSN>\nMD5HASH　d131dd02c5e6eec4693d9a0　文件的 MD5 哈希值。\n698aff95c\n2fcab58712467eab4004583e\nb8fb7f89\nOCRPATH　TEXT/001/EDC0000001.txt　原生文件提取文本的路径\n\n3. 每项请求均独立适用且应独立解释；除非另有说明，任何请求均不限制任何其他请求的范围。\n\n4. 所有文件均应按通常业务过程中保存的方式提供，或者应予以组织和标注，以对应这些请求中的类别。\n\n5. 本文所载每项请求均延及所有文件：(a) 由贵方占有、保管或控制；或 (b) 由代表贵方行事的任何人占有、保管或控制，\nCase 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 938 of 1063\n\n包括贵方的律师或其他代表和顾问。每份文件均应完整提供。\n\n6. 如要求您提供已不再由您占有、保管或控制的文件，则您的答复必须：（a）详细描述该文件的性质及其内容；（b）确定编制或撰写该文件的人员（以及，如适用，文件发送给的人员）；（c）确定该文件编制或创建的日期；（d）说明该文件是否：（i）遗失或丢失；（ii）已被销毁；（iii）已自愿或非自愿地转移给他人；或（iv）以其他方式处置；（e）说明该等处置的原因，以及围绕该等处置的事实和情形；（f）确定授权该等处置的人员；（g）确定该等处置的日期或大致日期；（h）说明该文件最近一次由您占有、保管或控制的时间；以及（i）确定目前占有、保管或控制该文件的人员（如有）。\n\n7. 如要求您提供已被销毁的文件，则除前述指示所要求的信息外，您的答复还必须说明：（a）该文件被销毁的原因；（b）销毁该文件的人员身份；以及（c）指示销毁该文件的人员身份。\n\n8. 如您主张所要求的文件受特权或律师工作成果保护，则您的答复必须：（a）说明：（i）足以支持您关于该文件受特权保护之主张的文件描述；（ii）文件标题；（iii）文件日期；（iv）文件作者；（v）文件收件人；（vi）收到或阅览该文件原件或任何草稿、副本或复制件的每一人员身份；（vii）该文件本身或该文件中包含或提及的任何信息，是否由任何其他人员占有、保管或控制；如是，则确定该等人员的身份，并说明该等信息如何进入其占有；\n\n案号 22-50073 文书 1592 于 03/24/23 提交 于 03/24/23 10:57:37 录入 第 939 页，共 1063 页\n\n该等人员，以及说明该等信息如何进入其占有；（viii）据以扣留该文件的特权主张；以及（ix）您将据以支持该等特权主张的所有情形；并且（b）就每一份因根据 D. Conn. L. Civ. R. 26(e) 提出的特权主张而被扣留的文件，提供一份特权清单，载明本指示第（a）部分所要求的全部信息。\n\n9. 如一份原本应予提供的文件中有部分包含受特权主张约束的信息，则仅应按照上述指示从该文件中删除或遮盖受该特权主张约束的部分，其余部分应予提供。\n\n10. 该等请求具有持续性。特此指示您：（a）一经得知先前答复不完整或不正确，应立即补充或更正其后得知不完整或不正确的任何答复；以及（b）提供根据下列规定所要求的任何额外文件。\n\n11. 如文件使用英语以外的语言，您应提供该文件。如文件使用英语以外的语言，且存在英文译本，您应同时提供两份文件。\n\n12. 所有对实体的提述均包括其所有关联方。\n\n13. 所有对个人姓名的提述均包括所有其他姓名、别名或昵称。\n\n14. 除非另有明确说明，文件请求所涵盖的期间为自 February 5, 2012 起至文件请求答复到期之日止。\n\n案号 22-50073 文书 1592 于 03/24/23 提交 于 03/24/23 10:57:37 录入 第 940 页，共 1063 页\n\nII. 解释规则\n\n15. （a）任何单数名词的使用，应解释为包括复数，反之亦然；以及（b）任何时态动词的使用，应解释为包括该动词所有其他时态的使用。\n\n16. （a）“和”及“或”应视需要解释为连词或选择词，以使任何请求的范围包括原本可能被解释为在其范围之外的所有答复；以及（b）“每一”及“任何”应视为包括并涵盖“每一个”和“全部”二词。\n\nIII. 定义\n\n经 D. Conn. Bankr. L.R. 2004-1(a) 纳入的 D. Conn. L. Civ. R. 26(c) 所规定的定义，以及 D. Conn. L. Civ. R. 26(d) 所规定的解释规则，均适用于文件请求。此外，本文件请求中使用的下列术语具有下列含义：\n\n1. “您”或“您的”或“您本人”系指 Huk Trading Inc.（Huk贸易公司），连同其所有关联方、部门、机构、工具部门、处室、办事处、合伙人、高级职员、董事、代理人、律师、代表、雇员和/或任何代表其行事的人。\n\n2. “债务人”系指 Ho Wan Kwok（郭文贵）（又名 Miles Kwok、Miles Guo、Guo Wengui、Guo Haoyun、郭文贵，或任何其他别名），连同其雇员、代理人、律师、顾问或任何代表其行事的人。\n\n3. “债务人之子”系指 Qiang Guo（郭强）（又名 Mileson Kwok、郭强，或任何其他别名），连同其雇员、代理人、律师、顾问或任何代表其行事的人。\n\n案号 22-50073 文书 1592 于 03/24/23 提交 于 03/24/23 10:57:37 录入 第 941 页，共 1063 页\n\n4. “债务人之女”系指 Mei Guo（郭美）（又名 Mei Gui、郭美，或任何其他别名），连同其雇员、代理人、律师、顾问或任何代表其行事的人。\n\n5. “债务人声称的妻子”系指 Hing Chi Ngok（岳庆芝）（又名 Hing Chi Ng、Yue Qingzhi、岳庆芝，或任何其他别名），连同其雇员、代理人、律师、顾问或任何代表其行事的人。\n\n6. “债务人家属”统称债务人、债务人之子、债务人之女及债务人声称的妻子，以及与债务人存在其他家庭关系的任何人。\n\n7. “关联个人”单独及统称：（1）持有、控制、保管或对债务人或债务人家属拥有、控制或享有的资产具有酌处权的所有个人；或（2）曾为一个或多个关联实体的雇员、董事或以其他方式与其有关联的所有个人，连同前述任何人的各自雇员、代理人、律师、顾问或任何代表其行事的人。该等关联个人包括但不限于：Daniel Podhaskie、Jason Miller、Steve Bannon、Karin Maistrello、Melissa Francis、Anthony DiBattista、William Gertz、Arethusa Forsyth、Glenn Mellor、Jennifer Mercurio、Eduardo Eurnekian、Wencong Wang、Han Chunguang（韩春光）（又名 韩春光）、Qu Guojiao（屈国姣）（又名 Qu Guo Jiao、屈国姣）、Guo Lijie（郭丽杰）（又名 郭丽杰）、Zhang Wei（张伟）（又名 张伟*）、Lihong Wei Lafrenz（魏丽红）（又名 Sara Wei、魏丽红）、Hao Haidong（郝海东）（又名 郝海东）、Ross Heinemeyer、Max Krasner、Kyle Bass、Melissa Mendez、Ya Li（李娅）（又名 李娅）、Dinggang Wang（王定刚）（又名 王定刚）、An Hong（安红）（又名 安红）、Yvette Wang（王雁平）（又名 Yanping Wang、Yan Ping Wang、王雁平）、Fiona Yu、Je Kin Ming（余建明）（又名 William Je、Yu Jianming、余建明）、Yaz Qingua，以及 Lao Jiang（姜云浮）（又名 Jiang Yunfu、Jiang Yunfu Be、姜云浮）。\n\n案号 22-50073 文书 1592 于 03/24/23 提交 于 03/24/23 10:57:37 录入 第 942 页，共 1063 页\n\n8. “关联实体”单独及统称：（1）曾由债务人或债务人家属拥有、控制或投资的任何类型的所有组织或实体；或（2）直接或间接对债务人或债务人家属拥有、控制或享有的任何资产享有权益的所有组织或实体，连同前述任何人的各自雇员、代理人、律师、顾问或任何代表其行事的人。该等关联实体包括但不限于：7 Nod Hill LLC、AAGV Limited、ACA Investment Management Limited、ACA Capital Group Limited、Ace Decade Holdings Limited、AI Group Holdings Inc.、Alfa Global Ventures Limited、Alfonso Global Limited、Allied Capital Global Limited、Alpine Fiduciaries SA、Anton Development Limited、Assets Sino Limited、Auspicious Coast Limited、Beijing Pangu Investment Co.、Beijing Pangu Investment Co. Ltd.、Beijing Pangu Investment Inc.、Beijing Zenith Holdings Company Limited、Booming Sail New York LLC、Bravo Luck Limited、BSA Strategic Fund I、China Golden Spring (Hong Kong) Limited、Chuang Xin Limited、Crane Advisory Group LLC、Creative Apex Investments Limited、Crystal Breeze Investments Limited、Dawn State Limited、Eastern Profit Corporation Limited、Elite Well Global Limited、Empire Growth Holdings、Freedom Media Ventures Ltd.、G Club Operations LLC、G Fashion LLC、G News LLC、GETTR USA、Genever Holdings Corporation、Genever Holdings LLC、Gfashion Media Group Inc.、GFNY, Inc.、Globalist International Limited、GNews Media Group Inc.、Golden Spring (New York) Ltd.、Greenwich Land LLC、Guo Media、GTV Media Group, Inc.、Hamilton Capital Holdings Inc.、HCHK Property Management, Inc.、HCHK Technologies, Inc.、Head Win Group Limited、Henan Yuda、Himalaya Embassy、Himalaya Exchange、Himalaya Federal Reserve、Himalaya Investment LLC、Himalaya International、Himalaya New World Inc.、Himalaya Supervisory Organization、Himalaya Ventures LLC、HK International Funds Investments (USA) Limited LLC、Hong Kong International Funds\n\n案号 22-50073 文书 1592 于 03/24/23 提交 于 03/24/23 10:57:37 录入 第 943 页，共 1063 页\n\nInvestments Limited、Hudson Diamond Holding、Infinite Increase Limited、Infinitum Developments Limited、Infinity Treasury Management Inc.、Insight Phoenix Fund、Lamp Capital LLC、Leading Shine Limited、Leading Shine NY Limited、Lexington Property and Staffing、Long Gate Limited、Maywind Trading LLC、MOS Himalaya LLC、Next Tycoon Investments Limited、New Federal State of China（中国新联邦国）（又名 NFSC）、Noble Fame Global Limited、Rosy Acme Ventures Limited、Rule of Law Foundation III, Inc.、Rule of Law Foundation IV, Inc.、Rule of Law Fund、Rule of Law Society、Rule of Law Society IV, Inc.、G-Translators PTY LTD、Saraca Media Group, Inc.、Shiny Ace Ltd.、Shiny Times Holdings Ltd.、Spirit Charter Investment Limited、Stevenson, Wong & Co.、Voice of Guo Media, Inc.、Well Origin Ltd.、World Century Limited、Worldwide Opportunity Holdings Limited、Whitecroft Shore Limited，以及 ZIBA Limited。\n\n9. “包括”或其任何变体，意为“包括但不限于”。\n\n10. “和”及“或”意为“和/或”，并应同时解释为连词及选择词，以最大限度地扩大其范围。\n\n11. “任何”、“全部”及“每一”意为“每一个及全部”。\n\n12. “每一”及“每一个”意为“每一个及全部”。\n\n13. “第三方”系指您本人以外的人员或实体。\n\n14. “转让”具有《破产法典》第 101(54) 条赋予该词的含义。\n\n15. “文件”系指属于 Fed. R. Civ. P. 34 范围内的任何信息或物品，并包括但不限于由您占有、保管或控制、或曾由您占有、保管或控制的各种、各类、各种性质或描述的每一书面、记录或图形材料，包括所有电子邮件的印刷件和电子副本、保存在计算机文件中的\n\n案号 22-50073 文书 1592 于 03/24/23 提交 于 03/24/23 10:57:37 录入 第 944 页，共 1063 页\n\n电子形式、电子通信、短信、社交媒体帖子、推文、元数据、函件、备忘录、磁带、速记或手写笔记、任何种类的书面表格、图表、蓝图、图纸、草图、图形、计划、文章、规格说明、日记、信函、电报、照片、会议记录、合同、协议、调查资料、计算机打印件、任何种类的数据汇编、电传、传真、语音留言、发票、订货单、支票、汇票、对账单、贷项通知单、报告、情况报告、摘要、索引、书籍、分类账、笔记本、明细表、透明胶片、录音资料、目录、广告、宣传材料、影片、录像带、录音带、CD、计算机磁盘、小册子、传单、穿孔卡、工时单、推文、社交媒体帖子，或任何其他种类的书面或录制材料，以及其全部元数据，无论以何种方式存储（无论以有形或电子形式）、记录、制作或复制；亦包括但不限于前述任何文件的草稿或副本，如其中含有原始文件中未载有的任何种类的笔记、评论或标记，或在其他方面与原始文件不一致。\n\n16. “个人”是指个人、公司、独资企业、合伙企业、协会或任何其他实体。“个人”还包括任何代理人、代表或专家，包括但不限于律师或财务顾问。\n\n17. “实体”是指任何自然人、公司、合伙企业、子公司、独资企业、商号、董事会、合资企业、协会、机构、主管机关、委员会或其他商业实体或法人，以及任何关联方、代理人、母公司，包括但不限于法律顾问、财务顾问或任何其他代表。\n\n18. “关于”是指涉及、描述、包含、提及、与之有关、支持、赞成、反对、加强、削弱、位于其中、结合考虑、影响、证明、表明、报告、记录、暗指、回应、\nCase 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 945 of 1063\n\n与之相连、对其评论、就其而言、关于、与之相关、讨论、展示、描述、反映、分析、构成及属于。\n\n19. “与……有关”、“涉及”或“相关”，在指称任何特定事项时，是指但不限于构成、包含、涉及、含有、体现、反映、识别、陈述、直接或间接提及，或以任何方式与所识别的特定事项相关的任何文件。\n\n20. “通信”是指在最广泛可能的意义上且不受限制地传递任何信息或知识（以事实、想法、询问或其他形式）。通信还指所有谈话、协议、询问或答复，无论是当面、通过电话、以书面形式，或借助电子传输设备，并包括但不限于所有函件、电子邮件、录音、传输单、备忘录、电话通信、语音留言、电报、传真、电传、即时消息、聊天记录、短信、电话笔记，或在内部或与第三方传递的笔记。\n\n21. “资产”是指可用于产生正面经济价值的任何项目，包括但不限于由实体拥有、控制或为其利益而持有并预期将提供未来利益的任何具有经济价值的资源，包括但不限于所有不动产和动产、无形财产、投资、投资权或未来收入权、现金、银行账户、商品、证券、债权、对实体的全部或部分控制权，以及预期的经济机会。\n\n22. “转让”具有《破产法》第101(54)条赋予该词的含义。\n\nIV. 应提交的文件\n\n1. 与债务人、债务人财产或关联实体的任何收入或资产有关的全部文件。\n\n2. 与债务人的财务状况及其对债权人的义务有关的全部文件，包括但不限于与任何试图避免支付该等义务的行为有关的全部文件，以及与本次或任何其他实际或可能的破产或类似无力偿债程序有关的全部文件。\n\n3. 与债务人、债务人财产、债务人家属、关联实体或关联个人有关的任何资产负债表、银行对账单、账户对账单、财务报表、账户结单、电汇指示和/或确认、资金证明、存款证明、持仓证明、投资组合摘要或类似文件有关的全部文件，包括但不限于足以显示向前述任何一方进行的全部转让的所有文件。\n\n4. 与债务人作出、与债务人进行或代表债务人作出的任何投资、业务往来或交易有关的全部文件。\n\n5. 与债务人的全部通信，以及与债务人的通信有关、并与任何实体的运营、管理或决策有关的文件，包括但不限于关联实体。\n\n6. 与向债务人、由债务人或与债务人、债务人家属或关联实体进行的任何转让、投资或其他交易或业务往来有关的全部文件。\n\n7. 与债务人曾经占用或使用的任何财产有关的全部文件，包括但不限于 Lady May；Sherry Netherland Hotel / Condominium；位于 Connecticut（康涅狄格州）Greenwich（格林尼治）373 Taconic Rd. 的住宅房产；位于 Connecticut（康涅狄格州）Greenwich（格林尼治）33 Ferncliff Rd. 的住宅房产；以及位于 Connecticut（康涅狄格州）Wilton（威尔顿）354 Nod Hill Rd. 的住宅房产。\nCase 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 947 of 1063\n\n8. 与债务人拥有、控制或使用的任何航空器有关的全部文件，包括但不限于尾号为 T7-GQM 的航空器以及任何其他在 San Marino（圣马力诺）登记的航空器，包括但不限于所有登记文件的副本，以及显示该等航空器所执行航班及该等航班机上人员的飞行清单。\n\n9. 与向债务人、债务人财产、债务人家属或关联实体提供、由其提供或代表其提供的任何赠与、利益或贷款有关的全部文件，包括但不限于足以显示该等赠与、利益或贷款金额；该等赠与、利益或贷款的用途；提供该等赠与、利益或贷款的时间；以及任何贷款的条款、就任何贷款作出的全部陈述与保证、任何贷款的利率，以及任何贷款的全部付款证据的文件。\n\n10. 与由债务人、代表债务人或为债务人、债务人财产、债务人家属或关联实体的利益设立的任何信托或类似工具有关的全部文件，包括但不限于足以显示信托设立时间、设立人、受益人以及信托本金的文件。\n\n11. 与涉及债务人的任何法律争议有关的任何义务、债权、责任或债务有关的全部文件，包括但不限于与在任何地方、州、联邦或国际机构（无论为行政机构、法院、合议庭或替代性争议解决实体）前进行的任何诉讼有关的文件。\nCase 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 948 of 1063\n\n12. 贵方的任何外部法律顾问或其他顾问与债务人之间的全部文件和通信。\n\n13. 足以显示贵方全部资产以及收入或资金来源的文件。\n\n14. 对于就请求14所识别的、价值超过 $50,000 的全部资产，(i) 与贵方取得该等资产有关的全部文件，以及 (ii) 贵方与债务人或债务人家属就该等资产进行的通信。\n\n15. 贵方纳税申报表的副本。\n\n16. 足以显示贵方拥有或控制的全部银行账户和投资账户的文件，包括每个该等账户的余额以及向该等账户和自该等账户进行的转让。\n\n17. 与贵方使用的任何信用卡有关的全部文件，包括但不限于月度账单或足以显示为债务人或关联实体利益而进行的与此有关全部购买行为的其他文件。\n\n18. 全部公司治理及组织文件，包括但不限于公司章程细则、公司设立证明以及足以显示贵方公司结构、高级管理人员和董事姓名、经营目的以及与债务人或债务人家属任何成员关系的其他文件。\n\n19. 与贵方向任何其他实体质押贵方资产有关的全部文件。\n\nCase 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 949 of 1063\n附件 C-52\nB2540（表格 2540 – Rule 2004 审查传票）（12/15）Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 950 of\n\nUNITED STATES BANKRUPTCY COURT（美国破产法院）\n\nDistrict of Connecticut（康涅狄格州地区）\n\n关于 HO WAN KWOK（郭文贵）等人，\n\n1 案号 22-50073 (JAM) 债务人 第11章\n\n（联合管理）\nRULE 2004 审查传票\n\n致：HHS Capital Inc.（HHS资本公司）\n\n（传票所指向之人的姓名）\n\n证言：兹命令贵方于下列载明的时间、日期和地点出席，根据《联邦破产程序规则》第2004条进行审查并作证。随附准许该审查的法院命令副本。\n\n地点　日期和时间\n\nPaul Hastings LLP（保罗·黑斯廷斯律师事务所）\n200 Park Avenue　[TBD]\nNew York, New York 10166（纽约州纽约市 10166）\n\n审查将通过以下方式记录：法庭记录员/速记员\n\n提交：贵方或贵方代表还必须将下列文件、电子存储信息或物品带至审查现场，并必须允许对该等材料进行查验、复制、测试或抽样：\n见随附的文件提交请求。\n\n《联邦民事诉讼规则》第45条的下列规定（根据《联邦破产程序规则》第9016条适用于破产案件）随附于后——与履行地点有关的第45(c)条；与贵方作为受传票约束之人的保护有关的第45(d)条；以及与贵方对该传票作出回应的义务及未作回应的潜在后果有关的第45(e)条和第45(g)条。\n\n日期：March , 2023\n\n法院书记官\n\n或\n\n书记官或副书记官签名　律师签名\n\n签发或申请本传票、代表第11章受托人 Luc A. Despins（卢克·A·德斯平斯）的律师的姓名、地址、电子邮件地址和电话号码如下：\n\nDouglas S. Skalka, Esq.（道格拉斯·S·斯卡尔卡律师）；Neubert, Pepe & Monteith, P.C.（诺伊伯特、佩佩及蒙蒂思律师事务所）；195 Church Street, New Haven, Connecticut 06510 dskalka@npmlaw.com；(203) 821-2000\n\n致签发或申请本传票之人的通知\n\n如本传票命令在审判前提交文件、电子存储信息或有形物品，或检查场所，则必须在向传票所指向之人送达前，向每一方当事人送达通知及本传票副本。Fed. R. Civ. P. 45(a)(4)。\n\n软件版权 (c) 1996-2022 Best Case, LLC（最佳案件有限责任公司）- www.bestcase.com Best Case Bankruptcy（最佳案件破产软件） 1 本第11章案件中的债务人为 Ho Wan Kwok（郭文贵）（亦称 Guo Wengui（郭文贵）、Miles Guo（郭文贵）和 Miles Kwok（郭文贵），以及众多其他别名）（税务识别号码后四位：9595）、Genever Holdings LLC（Genever控股有限责任公司）（税务识别号码后四位：8202）及 Genever Holdings Corporation（Genever控股公司）。受托人、Genever Holdings LLC（Genever控股有限责任公司）及 Genever Holdings Corporation（Genever控股公司）的邮寄地址为 Paul Hastings LLP（保罗·黑斯廷斯律师事务所），200 Park Avenue, New York, NY 10166，转交 Luc A. Despins（卢克·A·德斯平斯），作为 Ho Wan Kwok（郭文贵）财产的受托人（仅为通知和通信之目的）。\n\n送达证明\n\n（除非 Fed. R. Civ. P. 45 要求，否则本节不应向法院提交。）\n\n本人于（日期）收到向（个人姓名及职务，如有）送达的本传票。\n\n本人通过如下方式向被指定人交付副本，以送达本传票：\n\n于（日期）；或者\n\n本人未予执行而退回本传票，原因如下：\n\n除非本传票系代表美国或其官员或代理人签发，本人还已向证人支付一天出席费用及法律允许的里程费，金额为 $ 。\n\n本人的差旅费为 $ ，服务费为 $ ，合计 $ 。\n\n本人在伪证处罚的约束下声明，本信息真实且正确。\n\n日期：\n\n送达人签名\n\n正楷姓名及职务\n\n送达人地址\n\n关于尝试送达等的补充信息：\n《联邦民事诉讼规则》第45(c)、(d)、(e)及(g)条（2013年12月1日生效）（根据《联邦破产诉讼规则》第9016条，适用于破产案件）\n(c) 履行地点。\n\n(1) 审判、听证或证言录取。传票仅可按如下方式命令某人出席审判、听证或证言录取：\n\n(A) 在该人居住、受雇或经常亲自从事商业活动地点100英里以内；或者\n\n(B) 在该人居住、受雇或经常亲自从事商业活动所在州内，如该人：\n\n(i) 为当事人或当事人的高级人员；或者\n\n(ii) 被命令出席审判且不会产生重大费用。\n\n(2) 其他证据开示。传票可命令：\n\n(A) 在该人居住、受雇或经常亲自从事商业活动地点100英里以内的地点提交文件、电子存储信息或物品；以及\n\n(B) 在待检查处所进行处所检查。\n(d) 对受传票约束者的保护；执行。\n\n(1) 避免不当负担或费用；制裁。负责签发和送达传票的当事人或律师必须采取合理措施，避免对受传票约束者施加不当负担或费用。要求履行之地区的法院必须执行该义务，并对未遵守该义务的当事人或律师施加适当制裁，该制裁可包括损失的收入和合理的律师费。\n\n(2) 命令提交材料或允许检查。\n\n(A) 无须出庭。被命令提交文件、电子存储信息或有形物品，或允许检查处所者，无须亲自到提交或检查地点出庭，除非其同时被命令出席证言录取、听证或审判。\n\n(B) 异议。被命令提交文件或有形物品，或允许检查者，可向传票中指定的当事人或律师送达书面异议，反对检查、复制、测试或抽样任何或全部材料，或反对检查处所，或反对以所要求的一种或多种形式提交电子存储信息。异议必须在指定履行时间或传票送达后14日届满两者中较早者之前送达。如提出异议，适用下列规则：\n\n(i) 送达方可随时在通知被命令者后，向要求履行之地区的法院提出动议，请求作出强制提交或检查的命令。\n\n(ii) 仅可按照该命令所指示的方式要求实施该等行为，且该命令必须保护并非当事人或当事人高级人员者免于承担因履行而产生的重大费用。\n\n(3) 撤销或修改传票。\n\n(A) 必须撤销或修改的情形。经及时动议，要求履行之地区的法院必须撤销或修改有下列情形的传票：\n\n(i) 未给予合理的履行时间；\n\n(ii) 要求某人在第45(c)条规定的地域限制之外履行；\n\n(iii) 要求披露享有特权或受其他保护的事项，且不适用任何例外或放弃；或者\n\n(iv) 对某人施加不当负担。\n\n(B) 可以撤销或修改的情形。为保护受传票约束或受其影响者，要求履行之地区的法院可经动议撤销或修改要求下列事项的传票：\n\n(i) 披露商业秘密或其他保密的研究、开发或商业信息；或者\n\n(ii) 披露未受聘专家的意见或信息，该意见或信息不描述争议中的特定事件，并且源自非由当事人请求进行的该专家研究。\n\n(C) 作为替代方案规定条件。在第45(d)(3)(B)条所述情形下，如送达方：\n\n(i) 证明其对证言或材料具有重大需要，且如不遭受不当困难则无法以其他方式满足该需要；并且\n\n(ii) 确保被传唤者将获得合理补偿，\n\n法院可不撤销或修改传票，而命令在特定条件下出庭或提交材料。\n(e) 对传票作出回应的义务。\n\n(1) 提交文件或电子存储信息。下列程序适用于提交文件或电子存储信息：\n\n(A) 文件。对要求提交文件的传票作出回应者，必须按照文件在正常经营过程中保存的方式提交，或者必须将其整理并标注，以对应请求中的类别。\n\n(B) 未指定电子存储信息的提交形式。如传票未指定提交电子存储信息的形式，回应者必须按照其通常保存的一种或多种形式，或以合理可使用的一种或多种形式提交。\n\n(C) 电子存储信息仅以一种形式提交。回应者无须以一种以上形式提交相同的电子存储信息。\n\n(D) 不可合理访问的电子存储信息。回应者无须从其认定因不当负担或成本而不可合理访问的来源提供电子存储信息的证据开示。对于强制证据开示的动议或保护令动议，回应者必须证明该信息因不当负担或成本而不可合理访问。如作出该证明，法院在考虑第26(b)(2)(C)条的限制后，如请求方证明具有正当理由，仍可命令从该等来源进行证据开示。法院可为该证据开示规定条件。\n\n(2) 主张特权或保护。\n\n(A) 被扣留的信息。以信息享有特权或作为审判准备材料受到保护为由扣留被传唤信息者，必须：(i) 明确提出该主张；以及\n\n(ii) 以一种不披露本身享有特权或受保护信息的方式，描述被扣留文件、通信或有形物品的性质，使当事人能够评估该主张。\n\n(B) 已提交的信息。如为回应传票而提交的信息受到特权主张或作为审判准备材料受保护的主张约束，提出该主张者可将该主张及其依据通知任何已收到该信息的当事人。收到通知后，当事人必须立即返还、隔离或销毁所指定的信息及其持有的任何副本；在该主张得到解决前不得使用或披露该信息；如该当事人在收到通知前已披露该信息，必须采取合理措施追回该信息；并可立即向要求履行之地区的法院密封提交该信息，以裁定该主张。提交该信息者必须保存该信息，直至该主张得到解决。\n\n(g) 藐视法庭。要求履行之地区的法院，以及在动议被移送后签发传票的法院，可认定已被送达但无充分理由不遵守传票或与之相关命令者构成藐视法庭。\n\n如需查阅传票材料，请参见 Fed.R.Civ.P.45(a) Committee Note (2013)\n\n……\n\n文件提交请求\nI. 指示\n\n1. 除非另有说明，下述文件请求（以下简称“请求”，每一项称为“一项请求”）必须分别且具体地作出回应。每项请求均应得到完整答复，除非对此善意提出异议；在此情况下，应按如下所述详细说明贵方异议的理由。如异议仅涉及某项请求的一部分，或其中包含的一个词、短语或条款，贵方须仅对该部分提出异议，并对请求的其余部分作出回应。\n\n2. 电子存储信息必须按照下列指示提交：\n\n- a. 图像。黑白图像必须为300 DPI Group IV单页TIFF文件。彩色图像必须以JPEG格式提交。文件名不得包含嵌入空格或特殊字符（包括逗号）。文件夹名称不得包含嵌入空格或特殊字符（包括逗号）。所有TIFF图像文件必须具有唯一文件名，即Bates编号。每张图像的右下角必须标注连续的Bates编号。每个文件夹中的TIFF文件数量不应超过1000个文件。Excel电子表格应具有以该文件Bates编号命名的占位图像。\n\n- b. 图像加载文件\n\n\t- a. Concordance®数据文件。数据文件（.DAT）包含将被加载到Concordance®数据库中的所有字段信息。.DAT文件的第一行必须为标识字段名称的标题行。.DAT文件必须使用以下Concordance®默认分隔符：逗号ASCII字符（020）引号 þ ASCII字符（254）。日期字段应采用以下格式提供：mm/dd/yyyy。日期字段和时间字段必须为两个独立字段。如文件包括图像化的电子邮件及附件，必须包括附件字段，以保留电子邮件与其附件之间的父子关系。必须包括OCRPATH字段，以提供所提交存储介质上提取文本文件的文件路径和名称。文本文件必须以FIRSTBATES命名。请勿在.DAT文件中包含文本。对于具有原生文件的文件，必须包括LINK字段，以提供原生文件的文件路径和\n\n名称。原生文件必须以FIRSTBATES命名。\n\n- b. Concordance Image® 或 Opticon 交叉引用文件。图像交叉引用文件（.LOG 或 .OPT）将图像与数据库记录关联。该文件应为逗号分隔文件，每行由七个字段组成，并且数据库中的每张图像均应在交叉引用文件中对应一行，格式如下：ImageID,VolumeLabel,ImageFilePath,DocumentBreak,FolderBreak,BoxBreak,PageCount。\n\n- c. 文档文本。文本必须作为单独的文本文件提供，而非作为 .DAT 文件中的字段。文本文件的完整路径（OCRPATH）应包含在 .DAT 文件中。建议提供以 FIRSTBATES/Image Key 命名的文档级 ANSI 文本文件。提取的文本文件必须存放于单独文件夹中，每个文件夹中的文本文件数量不得超过 1,000 个。文件夹名称中不得包含特殊字符（包括逗号）。文本文件必须按文档级别提供。\n\n- d. 特定文件类型的原生格式提供。为完整理解其内容和含义而合理需要以原生格式查看的文件类型，必须以原生格式提供。此类文件包括但不限于电子表格、类电子表格文件（Microsoft Excel、逗号分隔值、制表符分隔值等）、Microsoft PowerPoint 或其他特殊演示文件、数据库文件以及音频/视频文件。应提供一张带有 Bates 编号的隔页纸图像，表明存在原生文件，并在 .dat 文件中将原生文件路径作为一个字段列入。提供的原生文件应以该文件隔页纸对应的 Bates 编号命名。原生文件应归入按递增方式命名的 “NATIVE” 目录中，并与图像目录分开。\n\n- e. 去重。对于存在完全相同副本的每一电子文档，仅提供一份副本。对于电子邮件，应根据由 BCC、Body、CC、From、IntMsgID、To 和 Attach 属性生成的 MD5 哈希值合并重复件。对于电子邮件附件和独立电子文件，应根据整个文件的 MD5 哈希值合并重复件。\n\n- f. 元数据。应以符合 Concordance 要求的加载文件（.dat）形式，为每份文档提供提取的元数据。.DAT 文件的第一行必须为标明字段名称的标题行。.DAT 文件必须使用以下 Concordance 默认分隔符：逗号 , ASCII 字符（020）引号 þ ASCII 字符（254）\n\n日期字段应采用以下格式提供：mm/dd/yyyy。日期和时间字段必须为两个单独字段。下列为必需元数据：\n案号 22-50073 文件 1592 提交日期 03/24/23 录入日期 03/24/23 10:57:37 第 955 页，共 1063 页\n\n字段名称　示例数据　说明\n\nFIRSTBATES　EDC0000001　原生文件文档/电子邮件的第一个 Bates 编号\nLASTBATES　EDC0000001　原生文件文档/电子邮件的最后一个 Bates 编号\nLASTBATES 字段应针对单页予以填充\nATTACHRANGE　EDC0000001 - EDC0000015　父文档第一页的 Bates 编号至最后一个附件“子”文档最后一页的 Bates 编号\nBEGATTACH　EDC0000001　附件范围的第一个 Bates 编号\nENDATTACH　EDC0000015　附件范围的最后一个 Bates 编号\nCUSTODIAN　Smith, John　电子邮件：电子邮件所在的邮箱。原生文件：该文档来源的个人或部门名称\nFROM　John Smith　电子邮件：发件人。原生文件：文档作者。多个条目应以分号分隔\nTO　Coffman, Janice; LeeW [mailto:LeeW@MSN.com]　收件人。多个条目应以分号分隔\nCC　Frank Thompson [mailto:frank_Thompson@cdt.com]　抄送收件人。多个条目应以分号分隔\nBCC　John Cain　密送收件人。多个条目应以分号分隔\nSUBJECT　Board Meeting Minutes　电子邮件：电子邮件主题行。原生文件：文档标题（如有）\nFILE_NAME　BoardMeetingMinutes.docx　原生文件：原始原生文件名称，包括扩展名\nDATE_SENT　10/12/2010　电子邮件：电子邮件发送日期。原生文件：（空）\nTIME_SENT/TIME_ZONE　07:05 PM GMT　电子邮件：电子邮件发送时间/电子邮件标准化时所采用的时区\nTIME_ZONE　GMT　在转换过程中电子邮件被标准化所采用的时区。\nLINK　EDC0000001.msg　电子邮件或原生文件文档的超链接。链接文件必须按 FIRSTBATES 编号命名\nFILE_EXTEN　MSG　表示电子邮件或原生文件的文件类型扩展名\nAUTHOR　John Smith　电子邮件：（空）。原生文件：文档作者\nDATE_CREATED　10/10/2010　电子邮件：（空）。原生文件：文档创建日期\n案号 22-50073 文件 1592 提交日期 03/24/23 录入日期 03/24/23 10:57:37 第 956 页，共 1063 页\n\nTIME_CREATED　10:25 AM　电子邮件：（空）。原生文件：文档创建时间。该数据必须为单独字段，不得与 DATE_CREATED 字段合并\nDATE_MOD　10/12/2010　电子邮件：（空）。原生文件：文档最后修改日期\nTIME_MOD　07:00 PM　电子邮件：（空）。原生文件：文档最后修改时间。该数据必须为单独字段，不得与 DATE_MOD 字段合并\nDATE_ACCESSD　10/12/2010　电子邮件：（空）。原生文件：文档最后访问日期\nTIME_ACCESSD　07:00 PM　电子邮件：（空）。原生文件：文档最后访问时间。该数据必须为单独字段，不得与 DATE_ACCESSD 字段合并\nFILE_SIZE　5,952　原生文件文档/电子邮件的大小，以 KB 计\nPGCOUNT　1　原生文件文档/电子邮件的页数\nPATH　Email: (empty) Agenda.doc　电子邮件：（空）。原生文件：存储原生文件文档的路径，包括原始文件名称。\nINTFILEPATH　Personal Folders\\Deleted Items\\Board Meeting Minutes.msg　电子邮件：电子邮件的原始位置，包括原始文件名称。原生文件：（空）\nINTMSGID　<000805c2c71b\\$75977050\\$cb8306d1@MSN>　电子邮件：唯一信息 ID。原生文件：（空）\nMD5HASH　d131dd02c5e6eec4693d9a0698aff95c2fcab58712467eab4004583eb8fb7f89　文档的 MD5 哈希值。\nOCRPATH　TEXT/001/EDC0000001.txt　原生文件提取文本的路径\n\n3. 各项请求独立运作并应独立解释，除非另有说明，任何请求均不限制任何其他请求的范围。\n\n4. 所有文件均应按通常业务过程中的保存方式提供，或应加以整理和标注，以对应本请求中的类别。\n\n5. 本文件所载各项请求均延及所有文件：(a) 由您占有、保管或控制的文件；或 (b) 由代表您行事的任何人占有、保管或控制的文件，\n案号 22-50073 文件 1592 提交日期 03/24/23 录入日期 03/24/23 10:57:37 第 957 页，共 1063 页\n\n包括您的律师或其他代表及顾问。每份文件均应完整提供。\n\n6. 如要求您提供一份已不再由您占有、保管或控制的文件，则您的答复必须：(a) 详细说明该文件的性质及其内容；(b) 确认制作或撰写该文件的人员（以及，如适用，该文件被发送给的人员）；(c) 确认该文件制作或创建的日期；(d) 说明该文件是否 (i) 缺失或遗失，(ii) 已被销毁，(iii) 已自愿或非自愿地转移给他人，或 (iv) 以其他方式被处置；(e) 说明该处置的理由，以及围绕该处置的事实和情形；(f) 确认授权该处置的人员；(g) 确认该处置的日期或大致日期；(h) 说明该文件最近一次由您占有、保管或控制的时间；以及 (i) 确认目前占有、保管或控制该文件的人员（如有）。\n\n7. 如要求您提供一份已被销毁的文件，则除前述指示所要求的信息外，您的答复还必须说明：(a) 销毁该文件的理由；(b) 销毁该文件的人员身份；以及 (c) 指示销毁该文件的人员身份。\n\n8. 如您主张所请求的文件享有特权或属于律师工作成果，则您的答复必须：(a) 说明 (i) 足以支持您关于该文件享有特权之主张的文件描述，(ii) 文件标题，(iii) 文件日期，(iv) 文件作者，(v) 文件收件人，(vi) 收到或见到该文件原件或任何草稿、副本或复制件的每一人员身份，(vii) 该文件本身或文件所载或所提及的任何信息是否由其他任何人员占有、保管或控制，如是，则确认该等人员身份，并说明该等信息如何由其取得，(viii) 据以扣留该文件的特权主张，以及 (ix) 您将据以支持该特权主张的所有情形；以及 (b) 根据 D. Conn. L. Civ. R. 26(e)，针对每份基于特权主张而被扣留的文件，制作一份包含本指示第 (a) 部分所要求全部信息的特权日志。\n\n9. 如一份本应予以提供的文件的一部分包含受特权主张约束的信息，则仅应按照上述指示从该文件中删除或遮蔽受特权主张约束的该部分，其余部分应予提供。\n\n10. 各项请求具有持续性。特此指示您：(a) 在知悉先前答复不完整或不正确时，立即补充或更正任何后来发现不完整或不正确的答复；以及 (b) 提供根据各项请求所要求的任何其他文件。\n\n11. 如文件使用英语以外的语言，您应提供该文件。如文件使用英语以外的语言且存在英文译本，您应同时提供两份文件。\n\n12. 对实体的所有提及均包括其所有关联方。\n\n13. 对个人姓名的所有提及均包括所有别名、化名或昵称。\n\n14. 除非另有明确说明，文件请求所涵盖的期间为自 February 5, 2012 起至应提交文件请求答复之日止。\n案号 22-50073 文件 1592 提交日期 03/24/23 录入日期 03/24/23 10:57:37 第 959 页，共 1063 页\n\nII. 解释规则\n\n15. (a) 任何单数名词的使用应解释为包括复数，反之亦然；以及 (b) 任何时态动词的使用应解释为在所有其他时态中使用该动词。\n\n16. (a) “and”和“or”应视必要情况作连言或选言解释，以使本可被解释为不属于任何请求范围的所有答复均纳入该请求范围；以及 (b) “each”和“any”应视为包括并涵盖“every”和“all”二词。\n\nIII. 定义\n\nD. Conn. L. Civ. R. 26(c) 所规定的定义，以及经 D. Conn. Bankr. L.R. 2004-1(a) 纳入的 D. Conn. L. Civ. R. 26(d) 所规定的解释规则，适用于文件请求。此外，本文件请求中所用术语具有以下含义：\n\n1. “您”或“您的”或“您本人”系指 HHS Capital Inc.（HHS 资本公司）及其所有关联方、部门、机构、职能机构、处室、办公室、合伙人、高级职员、董事、代理人、律师、代表、雇员和/或代表其行事的任何人。\n\n2. “债务人”系指 Ho Wan Kwok（郭文贵）（又名 Miles Kwok、Miles Guo、Guo Wengui、Guo Haoyun、郭文贵，或任何其他别名），以及其雇员、代理人、律师、顾问或代表其行事的任何人。\n\n3. “债务人的儿子”系指 Qiang Guo（郭强，又名 Mileson Kwok，或任何其他别名），连同其雇员、代理人、律师、顾问或任何代表其行事之人。\nCase 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 960 of 1063\n\n4. “债务人的女儿”系指 Mei Guo（郭美，又名 Mei Gui，或任何其他别名），连同其雇员、代理人、律师、顾问或任何代表其行事之人。\n\n5. “债务人的自称妻子”系指 Hing Chi Ngok（岳庆芝，又名 Hing Chi Ng、Yue Qingzhi，或任何其他别名），连同其雇员、代理人、律师、顾问或任何代表其行事之人。\n\n6. “债务人家属”系指，合称债务人、债务人的儿子、债务人的女儿及债务人的自称妻子，以及与债务人有任何其他亲属关系的人。\n\n7. “关联个人”系指，单独及共同地，所有以下个人：(1) 持有、控制、保管或有酌处权处理债务人或债务人家属拥有、控制或享有的资产；或 (2) 曾为一个或多个关联实体的雇员、董事，或以其他方式与其有关联者，连同前述任何一方各自的雇员、代理人、律师、顾问或任何代表其行事之人。该等关联个人包括但不限于：Daniel Podhaskie、Jason Miller、Steve Bannon、Karin Maistrello、Melissa Francis、Anthony DiBattista、William Gertz、Arethusa Forsyth、Glenn Mellor、Jennifer Mercurio、Eduardo Eurnekian、Wencong Wang、Han Chunguang（又名 韩春光）、Qu Guojiao（又名 Qu Guo Jiao、屈国姣）、Guo Lijie（又名 郭丽杰）、Zhang Wei（又名 张伟*）、Lihong Wei Lafrenz（又名 Sara Wei、魏丽红）、Hao Haidong（又名 郝海东）、Ross Heinemeyer、Max Krasner、Kyle Bass、Melissa Mendez、Ya Li（又名 李娅）、Dinggang Wang（又名 王定刚）、An Hong（又名 安红）、Yvette Wang（又名 Yanping Wang、Yan Ping Wang、王雁平）、Fiona Yu、Je Kin Ming（又名 William Je、Yu Jianming、余建明）、Yaz Qingua，以及 Lao Jiang（又名 Jiang Yunfu、Jiang Yunfu Be、姜云浮）。\nCase 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 961 of 1063\n\n8. “关联实体”系指，单独及共同地，所有以下任何类型的组织或实体：(1) 曾由债务人或债务人家属拥有、控制或投资；或 (2) 对债务人或债务人家属拥有、控制或享有的任何资产直接或间接享有权益，连同前述任何一方各自的雇员、代理人、律师、顾问或任何代表其行事之人。该等关联实体包括但不限于：7 Nod Hill LLC、AAGV Limited、ACA Investment Management Limited、ACA Capital Group Limited、Ace Decade Holdings Limited、AI Group Holdings Inc.、Alfa Global Ventures Limited、Alfonso Global Limited、Allied Capital Global Limited、Alpine Fiduciaries SA、Anton Development Limited、Assets Sino Limited、Auspicious Coast Limited、Beijing Pangu Investment Co.、Beijing Pangu Investment Co. Ltd.、Beijing Pangu Investment Inc.、Beijing Zenith Holdings Company Limited、Booming Sail New York LLC、Bravo Luck Limited、BSA Strategic Fund I、China Golden Spring (Hong Kong) Limited、Chuang Xin Limited、Crane Advisory Group LLC、Creative Apex Investments Limited、Crystal Breeze Investments Limited、Dawn State Limited、Eastern Profit Corporation Limited、Elite Well Global Limited、Empire Growth Holdings、Freedom Media Ventures Ltd.、G Club Operations LLC、G Fashion LLC、G News LLC、GETTR USA、Genever Holdings Corporation、Genever Holdings LLC、Gfashion Media Group Inc.、GFNY, Inc.、Globalist International Limited、GNews Media Group Inc.、Golden Spring (New York) Ltd.、Greenwich Land LLC、Guo Media、GTV Media Group, Inc.、Hamilton Capital Holdings Inc.、HCHK Property Management, Inc.、HCHK Technologies, Inc.、Head Win Group Limited、Henan Yuda、Himalaya Embassy、Himalaya Exchange、Himalaya Federal Reserve、Himalaya Investment LLC、Himalaya International、Himalaya New World Inc.、Himalaya Supervisory Organization、Himalaya Ventures LLC、HK International Funds Investments (USA) Limited LLC、Hong Kong International Funds\nCase 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 962 of 1063\n\nInvestments Limited、Hudson Diamond Holding、Infinite Increase Limited、Infinitum Developments Limited、Infinity Treasury Management Inc.、Insight Phoenix Fund、Lamp Capital LLC、Leading Shine Limited、Leading Shine NY Limited、Lexington Property and Staffing、Long Gate Limited、Maywind Trading LLC、MOS Himalaya LLC、Next Tycoon Investments Limited、New Federal State of China（又名 NFSC）、Noble Fame Global Limited、Rosy Acme Ventures Limited、Rule of Law Foundation III, Inc.、Rule of Law Foundation IV, Inc.、Rule of Law Fund、Rule of Law Society、Rule of Law Society IV, Inc.、G-Translators PTY LTD、Saraca Media Group, Inc.、Shiny Ace Ltd.、Shiny Times Holdings Ltd.、Spirit Charter Investment Limited、Stevenson, Wong & Co.、Voice of Guo Media, Inc.、Well Origin Ltd.、World Century Limited、Worldwide Opportunity Holdings Limited、Whitecroft Shore Limited，以及 ZIBA Limited。\n\n9. “包括”或其任何变体，系指“包括但不限于”。\n\n10. “和”及“或”系指“和/或”，并应同时按连词及选择连词解释，以最大限度扩大其范围。\n\n11. “任何”及“所有”及“每一”系指“每一个及全部”。\n\n12. “每一”及“每个”系指“每一个及全部”。\n\n13. “第三方”系指除你本人以外的个人或实体。\n\n14. “转让”应具有《破产法》section 101(54)赋予该词的含义。\n\n15. “文件”系指属于 Fed. R. Civ. P. 34 范围内的任何信息或物品，并包括但不限于任何种类、类型、性质或描述的、现处于或曾处于你的占有、保管或控制之下的每一份书面、记录或图形材料，包括电子邮件的所有印刷及电子副本、以电子形式保存的计算机文件、\nCase 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 963 of 1063\n\n电子通信、短信、社交媒体帖子、推文、元数据、函件、备忘录、磁带、速记或手写笔记、任何种类的书面表格、图表、蓝图、图纸、草图、曲线图、计划、文章、规格说明、日记、信函、电报、照片、会议记录、合同、协议、调查资料、计算机打印件、任何种类的数据汇编、电传、传真、语音留言、发票、订购单、支票、汇票、对账单、信用备忘录、报告、持仓报告、摘要、索引、书籍、账簿、笔记本、时间表、透明胶片、录音、目录、广告、宣传材料、影片、录像带、录音带、CD、计算机磁盘、小册子、宣传册、穿孔卡、工时单、推文、社交媒体帖子或任何其他种类的书面或记录材料，以及其全部元数据，无论以何种方式储存（无论为有形形式或电子形式）、记录、制作或复制；亦包括但不限于前述任何文件的草稿或副本，如其中含有原始文件中未有的任何种类笔记、评论或标记，或在其他方面与原始文件不完全相同。\n\n16. “个人”系指个人、公司、独资企业、合伙企业、协会或任何其他实体。“个人”亦包括任何代理人、代表或专家，包括但不限于律师或财务顾问。\n\n17. “实体”系指任何自然人、公司、合伙企业、子公司、独资企业、商号、董事会、合资企业、协会、机构、主管机关、委员会或其他商业实体或法人，以及任何关联方、代理人、母公司，包括但不限于法律顾问、财务顾问或任何其他代表。\n\n18. “关于”系指涉及、描述、构成、提及、与之相关、支持、有利于、反对、加强、削弱、载于、与之关联地考虑、影响、证明、表明、报告、记录、暗示、回应、\nCase 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 964 of 1063\n\n与之联系、评论、就其而言、关于、与之有关、讨论、显示、描述、反映、分析、构成及属于。\n\n19. “与……有关”、“涉及”或“相关”，在提及任何特定主题事项时，系指但不限于构成、包含、涉及、载有、体现、反映、识别、陈述、直接或间接提及该特定主题事项，或以任何方式与所识别特定主题事项相关的任何文件。\n\n20. “通信”系指，在最广泛可能的意义上且不限于此，任何信息或知识的传递（以事实、想法、询问或其他形式）。通信还指所有面谈、协议、询问或答复，无论是当面、通过电话、书面形式，还是通过电子传输设备进行，并包括但不限于所有函件、电子邮件、录音、传送单、备忘录、电话通信、语音留言、电报、传真、电传复印件、电传、即时消息、聊天记录、短信、电话笔记或在内部或与第三方之间传送的笔记。\n\n21. “资产”系指可用于产生正向经济价值的任何项目，包括但不限于由某一实体拥有、控制或为其利益而持有，并预期可提供未来利益的任何具有经济价值的资源，包括但不限于所有不动产和动产、无形财产、投资、投资权或未来收入权、现金、银行账户、商品、证券、债权、对某一实体的全部或部分控制权，以及预期经济机会。\n\n22. “转让”应具有《破产法》section 101(54)赋予该词的含义。\n\nIV. 应提交的文件\n\n1. 与债务人、债务人破产财产或关联实体的任何收入或资产有关的所有文件。\n\n2. 与债务人的财务状况及其对债权人的义务有关的所有文件，包括但不限于与任何规避支付该等义务的行为有关的所有文件，以及与本次或任何其他实际或潜在破产或类似无力偿债程序有关的所有文件。\n\n3. 与债务人、债务人破产财产、债务人家属、关联实体或关联个人有关的任何资产负债表、银行对账单、账户对账单、财务报表、账户报表、电汇指示和/或确认、资金证明、存款证、持仓证明、投资组合摘要或类似文件有关的所有文件，包括但不限于足以显示向前述任何一方作出的所有转让的全部文件。\n\n4. 与债务人作出、与债务人进行或代表债务人作出的任何投资、商业往来或交易有关的所有文件。\n\n5. 与债务人的所有通信，以及与债务人通信有关的文件，涉及任何实体的运营、管理或决策，包括但不限于关联实体。\n\n6. 与向债务人、债务人家属或关联实体作出、由其作出或与其进行的任何转让、投资或其他交易或商业往来有关的所有文件。\n\n7. 与债务人曾经占用或使用的任何财产有关的所有文件，包括但不限于 Lady May；Sherry Netherland Hotel / Condominium；位于 Connecticut 州 Greenwich 市 373 Taconic Rd. 的住宅物业；位于 Connecticut 州 Greenwich 市 33 Ferncliff Rd. 的住宅物业；以及位于 Connecticut 州 Wilton 市 354 Nod Hill Rd. 的住宅物业。\n\n8. 与债务人拥有、控制或使用的任何航空器有关的所有文件，包括但不限于尾号为 T7-GQM 的航空器以及在 San Marino（圣马力诺）注册的任何其他航空器，包括但不限于所有登记文件副本及显示该等航空器所执行航班和该等航班机上人员的飞行舱单。\n\n9. 关于向债务人、债务人财产、债务人家庭成员或关联实体提供、由其提供或代表其提供的任何赠与、利益或贷款的所有文件，包括但不限于足以显示该等赠与、利益或贷款金额；该等赠与、利益或贷款的使用目的；赠与、利益或贷款提供的时间；以及任何贷款的条款、与任何贷款有关作出的所有陈述及保证、任何贷款的利率，以及任何贷款付款的所有证据的文件。\n\n10. 与由债务人、代表债务人或为债务人、债务人财产、债务人家庭成员或关联实体之利益设立的任何信托或类似文书有关的所有文件，包括但不限于足以显示该等信托设立的时间、设立人、为谁的利益而设立以及信托本金的文件。\n\n11. 与涉及债务人的任何法律争议有关的任何义务、请求权、责任或债务相关的所有文件，包括但不限于与在任何地方、州、联邦或国际机构（无论是行政机构、法院、合议庭或替代性争议解决实体）前进行的任何诉讼有关的文件。\n\n案件 22-50073 文书 1592 提交于 03/24/23 录入于 03/24/23 10:57:37 第 967 页，共 1063 页\n\n12. 您的任何外聘律师或其他顾问与债务人之间的所有文件和通信。\n\n13. 足以显示您的全部资产以及收入或资金来源的文件。\n\n14. 对于就第 14 项请求作出的答复中识别的、价值超过 $50,000 的所有资产，提供：(i) 与您取得该等资产有关的所有文件；以及 (ii) 与债务人或债务人家庭成员就该等资产进行的通信。\n\n15. 您的纳税申报表副本。\n\n16. 足以显示由您持有或控制的所有银行账户和投资账户的文件，包括每一该等账户的余额以及向该等账户转入和从该等账户转出的款项。\n\n17. 关于您使用的任何信用卡的所有文件，包括但不限于月度账单或足以显示为债务人或关联实体利益而进行的所有相关购买的其他文件。\n\n18. 所有公司治理及组织文件，包括但不限于公司章程细则、公司注册证书，以及足以显示您的公司结构、高级管理人员和董事姓名、经营宗旨以及与债务人或债务人任何家庭成员关系的其他文件。\n\n19. 与将您的任何资产质押给任何其他实体有关的所有文件。\n\n案件 22-50073 文书 1592 提交于 03/24/23 录入于 03/24/23 10:57:37 第 968 页，共 1063 页\n\n证物 C-53\n\nB2540（表格 2540－Rule 2004 审查传票）（12/15）案件 22-50073 文书 1592 提交于 03/24/23 录入于 03/24/23 10:57:37 第 969 页，共 1063 页\n\nUNITED STATES BANKRUPTCY COURT（美国破产法院）\n\nDistrict of Connecticut（康涅狄格联邦地区）\n\n关于 HO WAN KWOK（郭文贵）等人，\n\n1 案件编号 22-50073 (JAM) 债务人 第 11 章\n\n（合并管理）\n\nRULE 2004 审查传票\n\n致：Medical Supply System International LLC（医疗供应系统国际有限责任公司）\n\n（传票所指向人员的姓名）\n\n证言：兹命令您于下列载明的时间、日期和地点出席，并在依据 Federal Rules of Bankruptcy Procedure（联邦破产程序规则）Rule 2004 进行的审查中作证。随附授权该审查的法院命令副本。\n\n地点　日期和时间\n\nPaul Hastings LLP（博衡律师事务所）\n200 Park Avenue　[TBD]\nNew York, New York 10166（纽约州纽约市 10166）\n\n审查将通过以下方式记录：法庭记录员/速记员\n\n提交：您或您的代表还必须在审查时携带下列文件、以电子方式存储的信息或物品，并必须准许对该等材料进行检查、复制、测试或取样：\n\n见随附的文件提交请求。\n\nFed. R. Civ. P. 45 的下列规定（其根据 Fed. R. Bankr. P. 9016 适用于破产案件）随附于后：关于履行地点的 Rule 45(c)；关于作为传票对象之人的保护的 Rule 45(d)；以及关于您回应本传票之义务和未回应的可能后果的 Rule 45(e) 和 45(g)。\n\n日期：March , 2023\n\n法院书记员\n\n或\n\n书记员或副书记员签名　律师签名\n\n签发或请求本传票的第 11 章受托人 Luc A. Despins（卢克·A·德斯平斯）的代理律师姓名、地址、电子邮件地址和电话号码如下：\n\nDouglas S. Skalka, Esq.（道格拉斯·S·斯卡尔卡，律师）；Neubert, Pepe & Monteith, P.C.（诺伊伯特、佩佩及蒙蒂思专业公司）；195 Church Street, New Haven, Connecticut 06510（康涅狄格州纽黑文市教堂街 195 号，邮编 06510）dskalka@npmlaw.com；(203) 821-2000\n\n致签发或请求本传票之人的通知\n\n如本传票命令在审判前提交文件、以电子方式存储的信息或有形物品，或检查场所，则必须在向传票所指向人员送达之前，向每一当事人送达通知及本传票副本。Fed. R. Civ. P. 45(a)(4)。\n\n软件版权 (c) 1996-2022 Best Case, LLC（Best Case 有限责任公司）－www.bestcase.com Best Case Bankruptcy（Best Case 破产软件）1 本第 11 章案件中的债务人为 Ho Wan Kwok（郭文贵）（又名 Guo Wengui（郭文贵）、Miles Guo（郭文贵）和 Miles Kwok（郭文贵），以及众多其他别名）（税务识别号码后四位：9595）、Genever Holdings LLC（Genever Holdings 有限责任公司）（税务识别号码后四位：8202）和 Genever Holdings Corporation（Genever Holdings 公司）。受托人、Genever Holdings LLC 和 Genever Holdings Corporation 的邮寄地址为 Paul Hastings LLP，200 Park Avenue，New York, NY 10166，由 Luc A. Despins 代收，作为 Ho Wan Kwok 财产的受托人（仅为通知和通信之目的）。\n\n送达证明\n\n（除非 Fed. R. Civ. P. 45 要求，否则本节不得向法院提交。）\n\n我于（日期）收到向（个人姓名及职务，如有）发出的本传票。\n\n我通过按如下方式向被指定人员交付副本而送达本传票：\n\n于（日期）；或\n\n我未执行本传票即予退回，原因是：\n\n除非本传票代表 United States（美国）或其官员或代理人签发，我还已向证人预付一天出席费用及法律允许的里程费，金额为 $ 。\n\n我的差旅费用为 $，服务费用为 $，合计为 $。\n\n我在伪证罪处罚的约束下声明，该等信息真实且正确。\n\n日期：\n\n送达人签名\n\n正楷姓名及职务\n\n送达人地址\n\n关于尝试送达等的补充信息：\n\nFederal Rule of Civil Procedure 45(c)、(d)、(e) 和 (g)（生效日期 12/1/13）（根据 Federal Rules of Bankruptcy Procedure Rule 9016 适用于破产案件）\n\n(c) 履行地点。\n\n(1) 审判、听证或证言录取。传票仅可按下列方式命令某人出席审判、听证或证言录取：\n\n(A) 在该人居住、受雇或经常亲自从事营业之地 100 英里以内；或\n\n(B) 在该人居住、受雇或经常亲自从事营业所在的州内，如该人：\n\n(i) 为当事人或当事人的高级管理人员；或\n\n(ii) 被命令出席审判且不会产生重大费用。\n\n(2) 其他证据开示。传票可以命令：\n\n(A) 在该人居住、受雇或经常亲自从事营业之地 100 英里以内的地点提交文件、以电子方式存储的信息或物品；以及\n\n(B) 在待检查场所对该场所进行检查。\n\n(d) 对作为传票对象之人的保护；执行。\n\n(1) 避免不当负担或费用；制裁。负责签发和送达传票的当事人或律师必须采取合理措施，避免对作为传票对象之人施加不当负担或费用。要求履行的地区法院必须执行该义务，并对未遵守者的当事人或律师施加适当制裁，该制裁可包括损失的收入和合理的律师费。\n\n(2) 命令提交材料或准许检查。\n\n(A) 无须出席。被命令提交文件、以电子方式存储的信息或有形物品，或准许检查场所之人，无须亲自出席提交或检查地点，除非同时被命令出席证言录取、听证或审判。\n\n(B) 异议。被命令提交文件或有形物品，或准许检查之人，可以向传票中指定的当事人或律师送达书面异议，反对检查、复制、测试或取样任何或全部材料，或反对检查场所，或反对以所要求的一种或多种形式提交以电子方式存储的信息。异议必须在指定履行时间或传票送达后 14 天两者中较早者之前送达。如提出异议，适用下列规则：\n\n(i) 送达方可随时在通知被命令人员后，向要求履行的地区法院申请强制提交或检查的命令。\n\n(ii) 仅可依照该命令所指示的方式要求实施该等行为，且该命令必须保护并非当事人或当事人高级管理人员之人免于承担因履行而产生的重大费用。\n\n(3) 撤销或修改传票。\n\n(A) 必须撤销或修改的情形。经及时动议，要求履行的地区法院必须撤销或修改具有下列情形的传票：\n\n(i) 未给予合理履行时间；\n\n(ii) 要求某人在 Rule 45(c) 规定的地域限制之外履行；\n\n(iii) 要求披露享有特权或以其他方式受保护的事项，且不存在任何例外或豁免；或\n\n(iv) 对某人施加不当负担。\n\n(B) 可以撤销或修改的情形。为保护作为传票对象或受传票影响之人，经动议，要求履行的地区法院可以撤销或修改要求下列事项的传票：\n\n(i) 披露商业秘密或其他保密研究、开发或商业信息；或\n\n(ii) 披露未经聘用的专家的意见或信息，该等意见或信息并未描述争议中的具体事件，且源于当事人未请求的专家研究。\n\n(C) 以规定条件作为替代办法。在 Rule 45(d)(3)(B) 所述情形下，如送达方：\n\n(i) 证明对证言或材料存在实质性需要，且如不承受不当困难便无法以其他方式满足该需要；以及\n\n(ii) 确保被传唤之人将获得合理补偿，\n\n法院可以不撤销或修改传票，而是命令在规定条件下出席或提交。\n\n(e) 回应传票的义务。\n\n(1) 提交文件或以电子方式存储的信息。下列程序适用于提交文件或以电子方式存储的信息：\n\n(A) 文件。回应要求提交文件之传票的人，必须按文件在正常业务过程中保存的方式提交，或者必须按照请求中的类别对文件进行整理和标注。\n\n(B) 未指定以电子方式存储的信息的提交形式。如传票未指定提交以电子方式存储的信息的形式，回应之人必须以其通常保存的一种或多种形式，或以合理可用的一种或多种形式提交。\n\n(C) 以电子方式存储的信息仅须以一种形式提交。回应之人无须以一种以上形式提交同一以电子方式存储的信息。\n\n(D) 无法合理访问的电子存储信息。答复人无需就其认定为因不当负担或费用而无法合理访问的来源中的电子存储信息提供证据开示。在提出强制证据开示动议或保护令动议时，答复人必须证明该信息因不当负担或费用而无法合理访问。如作出该证明，法院仍可在请求方考虑到 Rule 26(b)(2)(C) 的限制后证明存在正当理由时，命令对该等来源进行证据开示。法院可规定证据开示的条件。\n\n(2) 主张特权或保护。\n\n(A) 被扣留的信息。根据该信息享有特权或作为审判准备材料受保护的主张而扣留被传唤信息的人，必须：(i) 明确提出该主张；以及\n\n(ii) 以不披露本身享有特权或受保护的信息、但足以使各方评估该主张的方式，说明被扣留文件、通信或有形物品的性质。\n\n(B) 已提供的信息。如为回应传票而提供的信息受特权主张或作为审判准备材料受保护的主张约束，提出该主张的人可以将该主张及其依据通知收到该信息的任何一方。收到通知后，一方必须立即返还、隔离或销毁指定信息及其持有的任何副本；在该主张得到解决之前，不得使用或披露该信息；如该方在收到通知前已披露该信息，必须采取合理措施收回该信息；并可立即向履行义务所在地辖区的法院密封提交该信息，以裁定该主张。提供该信息的人必须在该主张得到解决前保存该信息。\n\n(g) 藐视法庭。在要求履行义务的辖区的法院——以及在动议被移送后，发出传票的法院——可对已被送达但无充分理由未遵守传票或与之有关命令的人作出藐视法庭裁定。\n\n如需查阅传票材料，请参见 Fed.R.Civ.P.45(a) Committee Note (2013)\n\n……\n\n文件出示请求\n\nI. 指示\n\n1. 除非另有说明，下列文件请求（统称“请求”，单称“一项请求”）必须分别并具体作出答复。每项请求均应得到完整答复，除非您方出于善意提出异议；在此情况下，您方应按下文规定详细说明异议理由。如异议仅涉及一项请求的一部分，或其中包含的某个词语、短语或条款，您方仅须就该部分说明异议，并对其余请求作出答复。\n\n2. 电子存储信息必须按照下列指示提供：\n\n- a. 图像。黑白图像必须为 300 DPI Group IV 单页 TIFF 文件。彩色图像必须以 JPEG 格式提供。文件名不得包含嵌入空格或特殊字符（包括逗号）。文件夹名称不得包含嵌入空格或特殊字符（包括逗号）。所有 TIFF 图像文件必须具有唯一文件名，即 Bates 编号。每幅图像右下角必须标注连续的 Bates 编号。每个文件夹中的 TIFF 文件不得超过 1000 个。Excel 电子表格应有一个以该文件的 Bates 编号命名的占位图像。\n- b. 图像加载文件\n\t- a. Concordance®（康科丹斯®）数据文件。数据文件（.DAT）包含将加载至 Concordance® 数据库的全部字段信息。.DAT 文件的第一行必须为标明字段名称的标题行。.DAT 文件必须使用下列 Concordance® 默认分隔符：逗号 ASCII 字符（020）；引号 þ ASCII 字符（254）。日期字段应按下列格式提供：mm/dd/yyyy。日期和时间字段必须为两个独立字段。如文件包括图像化电子邮件及附件，必须包含附件字段，以保留电子邮件与其附件之间的父/子关系。必须包括 OCRPATH 字段，以提供已提供存储介质上提取文本文件的文件路径及名称。文本文件必须以 FIRSTBATES 命名。不得在 .DAT 文件中包含文本。对于含有原生文件的文件，必须包括 LINK 字段，以提供原生文件的文件路径及名称。原生文件必须以 FIRSTBATES 命名。\n\n- b. Concordance Image®（康科丹斯图像®）或 Opticon（奥普蒂康）交叉引用文件。图像交叉引用文件（.LOG 或 .OPT）将图像链接至数据库记录。该文件应为逗号分隔文件，每行由七个字段组成，并应就数据库中的每幅图像在交叉引用文件中包含一行，格式如下：ImageID,VolumeLabel,ImageFilePath,DocumentBreak,FolderBreak,BoxBreak,PageCount。\n- c. 文件文本。文本必须作为单独的文本文件提供，不得作为 .DAT 文件中的字段提供。文本文件的完整路径（OCRPATH）应包含于 .DAT 文件中。建议使用文件级 ANSI 文本文件，并按 FIRSTBATES/Image Key 命名。提取的文本文件必须置于单独的文件夹中，每个文件夹中的文本文件不得超过 1,000 个。文件夹名称中不得有特殊字符（包括逗号）。文本文件必须按文件级别提供。\n- d. 特定文件类型的原生格式提供。为全面理解其内容和含义而合理需要以原生格式查看的文件类型，必须以原生格式提供。此类文件包括但不限于电子表格、类似电子表格的文件（Microsoft Excel（微软 Excel）、逗号分隔值、制表符分隔值等）、Microsoft PowerPoint（微软 PowerPoint）或其他特殊演示文件、数据库文件以及音频/视频文件。应提供一张带有 Bates 编号的提示页图像，以表明存在原生文件，并在 .dat 文件中将原生文件路径作为字段列入。提供的原生文件应以与该文件提示页相对应的 Bates 编号命名。原生文件应归入按递增方式命名的“NATIVE”目录中，并与图像目录分开。\n- e. 去重。对于存在完全重复件的每份电子文件，仅提供一份副本。对于电子邮件，应根据由 BCC、Body、CC、From、IntMsgID、To 和 Attach 属性生成的 MD5 哈希值合并重复件。对于电子邮件附件和独立电子文件，应根据整个文件的 MD5 哈希值合并重复件。\n- f. 元数据。应以符合 Concordance 标准的加载文件（.dat）形式提供每份文件的提取元数据。.DAT 文件的第一行必须为标明字段名称的标题行。.DAT 文件必须使用下列 Concordance 默认分隔符：逗号 , ASCII 字符（020）；引号 þ ASCII 字符（254）。\n\n日期字段应按下列格式提供：mm/dd/yyyy。日期和时间字段必须为两个独立字段。以下列出所需元数据：\nCase 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 974 of 1063\n\n字段名称　示例数据　说明\n\nFIRSTBATES　EDC0000001　原生文件文件/电子邮件的第一个 Bates 编号\nLASTBATES　EDC0000001　原生文件文件/电子邮件的最后一个 Bates 编号\nLASTBATES 字段应针对单页文件填写\nATTACHRANGE　EDC0000001\n-　父文件第一页的 Bates 编号至最后一个附件“子”文件最后一页的 Bates 编号\nEDC0000015\nBEGATTACH　EDC0000001　附件范围的第一个 Bates 编号\nENDATTACH　EDC0000015　附件范围的最后一个 Bates 编号\nCUSTODIAN　Smith, John　电子邮件：电子邮件所在的邮箱\n原生文件：文件来源的个人或部门名称\nFROM　John Smith　电子邮件：发件人\n原生文件：文件作者\n多个条目应以分号分隔\nTO　Coffman, Janice; LeeW　收件人\n[mailto:LeeW@MSN.com]　多个条目应以分号分隔\nCC　Frank Thompson [mailto:　抄送收件人\nfrank_Thompson@cdt.com]　多个条目应以分号分隔\nBCC　John Cain　密送收件人\n多个条目应以分号分隔\nSUBJECT　Board Meeting Minutes　电子邮件：电子邮件主题行；原生文件：文件标题（如有）\nFILE_NAME　BoardMeetingMinutes.docx　原生文件：原始原生文件名称，包括扩展名\nDATE_SENT　10/12/2010　电子邮件：电子邮件发出日期\n原生文件：（空）\nTIME_SENT/\nTIME_ZONE　07:05 PM GMT　电子邮件：电子邮件发出时间/电子邮件标准化所使用的时区\nTIME_ZONE　GMT　在转换期间电子邮件被标准化所使用的时区。\nLINK　EDC0000001.msg　指向电子邮件或原生文件文件的超链接\n链接文件必须按 FIRSTBATES 编号命名\nFILE_EXTEN　MSG　代表电子邮件或原生文件的文件类型扩展名\nAUTHOR　John Smith　电子邮件：（空）\n原生文件：文件作者\nDATE_CREATED　10/10/2010　电子邮件：（空）\n原生文件：文件创建日期\nCase 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 975 of 1063\n\nTIME_CREATED　10:25 AM　电子邮件：（空）\n原生文件：文件创建时间\n该数据必须为单独字段，且不得与 DATE_CREATED 字段合并\nDATE_MOD　10/12/2010　电子邮件：（空）\n原生文件：文件最后修改日期\nTIME_MOD　07:00 PM　电子邮件：（空）\n原生文件：文件最后修改时间\n该数据必须为单独字段，且不得与 DATE_MOD 字段合并\nDATE_ACCESSD　10/12/2010　电子邮件：（空）\n原生文件：文件最后访问日期\nTIME_ACCESSD　07:00 PM　电子邮件：（空）\n原生文件：文件最后访问时间\n该数据必须为单独字段，且不得与 DATE_ACCESSD 字段合并\nFILE_SIZE　5,952　原生文件文件/电子邮件的大小，以 KB 计\nPGCOUNT　1　原生文件文件/电子邮件的页数\nPATH　电子邮件：（空）\nAgenda.doc　原生文件：储存原生文件文件的路径，包括原始文件名称。\nINTFILEPATH　Personal Folders\\Deleted　电子邮件：电子邮件的原始位置，包括原始文件名称。\nItems\\Board Meeting\nMinutes.msg　原生文件：（空）\nINTMSGID　<000805c2c71b\\$75977050\\$　电子邮件：唯一消息 ID；原生文件：（空）\ncb8306d1@MSN>\nMD5HASH　d131dd02c5e6eec4693d9a0　文件的 MD5 哈希值。\n698aff95c\n2fcab58712467eab4004583e\nb8fb7f89\nOCRPATH　TEXT/001/EDC0000001.txt　原生文件提取文本的路径\n\n3. 每项请求均独立适用并应独立解释，除非另有说明，任何一项请求均不限制任何其他请求的范围。\n\n4. 所有文件应按其在通常业务过程中保存的方式提供，或应加以组织和标注以对应本请求中的类别。\n\n5. 本文件所载每项请求均延及以下所有文件：(a) 由您方占有、保管或控制的文件；或 (b) 由代表您方行事的任何人占有、保管或控制的文件，\nCase 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 976 of 1063\n\n包括您方的律师或其他代表及顾问。每份文件均应完整提供。\n\n6. 如要求您提交一份已不再由您占有、保管或控制的文件，则您的答复必须：(a) 详细说明该文件的性质及其内容；(b) 指明编制或撰写该文件的人员（以及，如适用，该文件被发送给的人员）；(c) 指明该文件编制或创建的日期；(d) 说明该文件是否：(i) 遗失或丢失，(ii) 已被销毁，(iii) 已自愿或非自愿地转移给他人，或 (iv) 以其他方式处置；(e) 说明该等处置的理由以及相关事实和情形；(f) 指明授权该等处置的人员；(g) 指明该等处置的日期或大致日期；(h) 说明该文件最后一次由您占有、保管或控制的时间；以及 (i) 指明目前占有、保管或控制该文件的人员（如有）。\n\n7. 如要求您提交一份已被销毁的文件，则除前一项指示所要求的信息外，您的答复还必须说明：(a) 销毁该文件的理由；(b) 销毁该文件的人员身份；以及 (c) 指示销毁该文件的人员身份。\n\n8. 如您主张某一被要求提交的文件享有特权或属于律师工作成果，则您的答复必须：(a) 说明：(i) 对该文件作出足以支持您关于该文件享有特权之主张的描述，(ii) 该文件的标题，(iii) 该文件的日期，(iv) 该文件的作者，(v) 该文件的收件人，(vi) 收到或阅览该文件原件或任何草稿、副本或复制件的每一人员的身份，(vii) 该文件本身或该文件所含或所提及的任何信息，是否由任何其他人员占有、保管或控制；如是，该等人员的身份，以及说明该信息如何由其取得的陈述，(viii) 据以不提交该文件的特权主张，以及 (ix) 您将据以支持该等特权主张的所有情形；以及 (b) 就依据特权主张而不提交的每一文件，依照 D. Conn. L. Civ. R. 26(e)，提交一份特权清单，其中载明本指示第 (a) 部分所要求的全部信息。\n\n案件 22-50073 文书 1592 提交于 03/24/23 登记于 03/24/23 10:57:37 第 977 页，共 1063 页\n\n该等人员，以及说明该信息如何由其取得的陈述，(viii) 据以不提交该文件的特权主张，以及 (ix) 您将据以支持该等特权主张的所有情形；以及 (b) 就依据特权主张而不提交的每一文件，依照 D. Conn. L. Civ. R. 26(e)，提交一份特权清单，其中载明本指示第 (a) 部分所要求的全部信息。\n\n9. 如一份原本应予提交的文件的一部分含有受特权主张约束的信息，则仅应依照上述指示从该文件中删除或遮蔽受特权主张约束的该部分，其余部分应予提交。\n\n10. 该等请求具有持续性。特此指示您：(a) 一旦得知先前答复不完整或不正确，立即补充或更正任何后来得知不完整或不正确的答复；以及 (b) 提交依照文件请求所要求的任何补充文件。\n\n11. 如一份文件使用英语以外的语言，您应提供该文件。如一份文件使用英语以外的语言，且存在英文译本，您应同时提供两份文件。\n\n12. 对实体的所有提及均包括其所有关联方。\n\n13. 对个人姓名的所有提及均包括所有别名、化名或昵称。\n\n14. 除非另有明确说明，文件请求所涵盖的期间为自 February 5, 2012 起至文件请求答复到期之日止。\n\n案件 22-50073 文书 1592 提交于 03/24/23 登记于 03/24/23 10:57:37 第 978 页，共 1063 页\n\nII. 解释规则\n\n15. (a) 任何单数名词的使用应解释为包括复数，反之亦然；以及 (b) 任何时态动词应解释为使用该动词的所有其他时态。\n\n16. (a) “and”和“or”应在必要时解释为连词或选择词，以将原本可能被解释为不在任何请求范围内的所有答复纳入该请求的范围；以及 (b) “each”和“any”应视为包括并涵盖“every”和“all”二词。\n\nIII. 定义\n\n经 D. Conn. Bankr. L.R. 2004-1(a) 纳入的 D. Conn. L. Civ. R. 26(c) 所规定的定义，以及 D. Conn. L. Civ. R. 26(d) 所规定的解释规则，适用于文件请求。此外，本文件请求中使用的下列术语具有下列含义：\n\n1. “You”或“Your”或“Yourself”是指并包括 Medical Supply System International LLC（国际医疗供应系统有限责任公司）及其所有关联方、部门、机构、办事机构、职能机构、处室、办公室、合伙人、高级管理人员、董事、代理人、律师、代表、雇员，和/或任何代表其行事的人员。\n\n2. “Debtor”是指 Ho Wan Kwok（郭文贵）（亦称 Miles Kwok（郭文贵）、Miles Guo（郭文贵）、Guo Wengui（郭文贵）、Guo Haoyun（郭浩云）、郭文贵，或任何其他别名），以及其雇员、代理人、律师、顾问或任何代表其行事的人员。\n\n3. “Debtor's Son”是指 Qiang Guo（郭强）（亦称 Mileson Kwok（郭强）、郭强，或任何其他别名），以及其雇员、代理人、律师、顾问或任何代表其行事的人员。\n\n案件 22-50073 文书 1592 提交于 03/24/23 登记于 03/24/23 10:57:37 第 979 页，共 1063 页\n\n4. “Debtor's Daughter”是指 Mei Guo（郭美）（亦称 Mei Gui（郭美）、郭美，或任何其他别名），以及其雇员、代理人、律师、顾问或任何代表其行事的人员。\n\n5. “Debtor's Purported Wife”是指 Hing Chi Ngok（岳庆芝）（亦称 Hing Chi Ng（岳庆芝）、Yue Qingzhi（岳庆芝）、岳庆芝，或任何其他别名），以及其雇员、代理人、律师、顾问或任何代表其行事的人员。\n\n6. “Debtor's Family”统称债务人、债务人的儿子、债务人的女儿及债务人的据称妻子，以及与债务人有任何其他亲属关系的人员。\n\n7. “Associated Individuals”单独及合称：(1) 持有、控制、保管或有权酌情处置债务人或债务人家庭所拥有、控制或享有的资产的所有个人；或 (2) 曾为一间或多间关联实体的雇员、董事，或以其他方式与其有关联的所有个人，以及上述各方各自的雇员、代理人、律师、顾问或任何代表其行事的人员。该等关联个人包括但不限于：Daniel Podhaskie（丹尼尔·波达斯基）、Jason Miller（杰森·米勒）、Steve Bannon（史蒂夫·班农）、Karin Maistrello（卡琳·迈斯特雷洛）、Melissa Francis（梅丽莎·弗朗西斯）、Anthony DiBattista（安东尼·迪巴蒂斯塔）、William Gertz（威廉·格茨）、Arethusa Forsyth（阿雷图萨·福赛思）、Glenn Mellor（格伦·梅勒）、Jennifer Mercurio（詹妮弗·默丘里奥）、Eduardo Eurnekian（爱德华多·厄尔内基安）、Wencong Wang（王文聪）、Han Chunguang（韩春光）（亦称 韩春光）、Qu Guojiao（屈国姣）（亦称 Qu Guo Jiao（屈国姣）、屈国姣）、Guo Lijie（郭丽杰）（亦称 郭丽杰）、Zhang Wei（张伟）（亦称 张伟*）、Lihong Wei Lafrenz（魏丽红·拉弗伦茨）（亦称 Sara Wei（魏丽红）、魏丽红）、Hao Haidong（郝海东）（亦称 郝海东）、Ross Heinemeyer（罗斯·海内迈耶）、Max Krasner（马克斯·克拉斯纳）、Kyle Bass（凯尔·巴斯）、Melissa Mendez（梅丽莎·门德斯）、Ya Li（李娅）（亦称 李娅）、Dinggang Wang（王定刚）（亦称 王定刚）、An Hong（安红）（亦称 安红）、Yvette Wang（王雁平）（亦称 Yanping Wang（王雁平）、Yan Ping Wang（王雁平）、王雁平）、Fiona Yu（菲奥娜·余）、Je Kin Ming（余建明）（亦称 William Je（余建明）、Yu Jianming（余建明）、余建明）、Yaz Qingua（雅兹·钦瓜）以及 Lao Jiang（姜云浮）（亦称 Jiang Yunfu（姜云浮）、Jiang Yunfu Be（姜云浮）、姜云浮）。\n\n案件 22-50073 文书 1592 提交于 03/24/23 登记于 03/24/23 10:57:37 第 980 页，共 1063 页\n\n8. “Associated Entities”单独及合称：(1) 曾由债务人或债务人家庭拥有、控制或投资的任何类型的所有组织或实体；或 (2) 对债务人或债务人家庭所拥有、控制或享有的任何资产直接或间接享有权益的所有组织或实体，以及上述各方各自的雇员、代理人、律师、顾问或任何代表其行事的人员。该等关联实体包括但不限于：7 Nod Hill LLC（七诺德山有限责任公司）、AAGV Limited（AAGV有限公司）、ACA Investment Management Limited（ACA投资管理有限公司）、ACA Capital Group Limited（ACA资本集团有限公司）、Ace Decade Holdings Limited（艾斯十年控股有限公司）、AI Group Holdings Inc.（AI集团控股公司）、Alfa Global Ventures Limited（阿尔法全球创投有限公司）、Alfonso Global Limited（阿方索全球有限公司）、Allied Capital Global Limited（联合资本全球有限公司）、Alpine Fiduciaries SA（阿尔卑斯受托人股份公司）、Anton Development Limited（安东开发有限公司）、Assets Sino Limited（中资资产有限公司）、Auspicious Coast Limited（吉祥海岸有限公司）、Beijing Pangu Investment Co.（北京盘古投资公司）、Beijing Pangu Investment Co. Ltd.（北京盘古投资有限公司）、Beijing Pangu Investment Inc.（北京盘古投资股份有限公司）、Beijing Zenith Holdings Company Limited（北京鼎峰控股有限公司）、Booming Sail New York LLC（纽约兴帆有限责任公司）、Bravo Luck Limited（鸿运有限公司）、BSA Strategic Fund I（BSA战略基金一号）、China Golden Spring (Hong Kong) Limited（中国金泉〈香港〉有限公司）、Chuang Xin Limited（创新有限公司）、Crane Advisory Group LLC（鹤咨询集团有限责任公司）、Creative Apex Investments Limited（创意顶峰投资有限公司）、Crystal Breeze Investments Limited（水晶微风投资有限公司）、Dawn State Limited（黎明州有限公司）、Eastern Profit Corporation Limited（东方利润有限公司）、Elite Well Global Limited（精英环球有限公司）、Empire Growth Holdings（帝国成长控股）、Freedom Media Ventures Ltd.（自由媒体创投有限公司）、G Club Operations LLC（G俱乐部运营有限责任公司）、G Fashion LLC（G时尚有限责任公司）、G News LLC（G新闻有限责任公司）、GETTR USA（GETTR美国）、Genever Holdings Corporation（吉尼弗控股公司）、Genever Holdings LLC（吉尼弗控股有限责任公司）、Gfashion Media Group Inc.（G时尚媒体集团公司）、GFNY, Inc.（GFNY公司）、Globalist International Limited（全球主义者国际有限公司）、GNews Media Group Inc.（G新闻媒体集团公司）、Golden Spring (New York) Ltd.（金泉〈纽约〉有限公司）、Greenwich Land LLC（格林尼治土地有限责任公司）、Guo Media（郭媒体）、GTV Media Group, Inc.（GTV媒体集团公司）、Hamilton Capital Holdings Inc.（汉密尔顿资本控股公司）、HCHK Property Management, Inc.（HCHK物业管理公司）、HCHK Technologies, Inc.（HCHK科技公司）、Head Win Group Limited（领胜集团有限公司）、Henan Yuda（河南裕达）、Himalaya Embassy（喜马拉雅大使馆）、Himalaya Exchange（喜马拉雅交易所）、Himalaya Federal Reserve（喜马拉雅联邦储备）、Himalaya Investment LLC（喜马拉雅投资有限责任公司）、Himalaya International（喜马拉雅国际）、Himalaya New World Inc.（喜马拉雅新世界公司）、Himalaya Supervisory Organization（喜马拉雅监督组织）、Himalaya Ventures LLC（喜马拉雅创投有限责任公司）、HK International Funds Investments (USA) Limited LLC（香港国际基金投资〈美国〉有限责任公司）、Hong Kong International Funds\n\n案件 22-50073 文书 1592 提交于 03/24/23 登记于 03/24/23 10:57:37 第 981 页，共 1063 页\n\nInvestments Limited（香港国际基金投资有限公司）、Hudson Diamond Holding（哈德逊钻石控股）、Infinite Increase Limited（无限增长有限公司）、Infinitum Developments Limited（无限开发有限公司）、Infinity Treasury Management Inc.（无限财务管理公司）、Insight Phoenix Fund（洞见凤凰基金）、Lamp Capital LLC（灯资本有限责任公司）、Leading Shine Limited（领耀有限公司）、Leading Shine NY Limited（领耀纽约有限公司）、Lexington Property and Staffing（列克星敦物业及人力服务）、Long Gate Limited（长龙门有限公司）、Maywind Trading LLC（五月风贸易有限责任公司）、MOS Himalaya LLC（MOS喜马拉雅有限责任公司）、Next Tycoon Investments Limited（下一大亨投资有限公司）、New Federal State of China（中国新联邦国）（亦称 NFSC）、Noble Fame Global Limited（名誉全球有限公司）、Rosy Acme Ventures Limited（玫瑰顶点创投有限公司）、Rule of Law Foundation III, Inc.（法治基金会III公司）、Rule of Law Foundation IV, Inc.（法治基金会IV公司）、Rule of Law Fund（法治基金）、Rule of Law Society（法治协会）、Rule of Law Society IV, Inc.（法治协会IV公司）、G-Translators PTY LTD（G译者有限公司）、Saraca Media Group, Inc.（萨拉卡媒体集团公司）、Shiny Ace Ltd.（闪耀王牌有限公司）、Shiny Times Holdings Ltd.（闪耀时代控股有限公司）、Spirit Charter Investment Limited（精神宪章投资有限公司）、Stevenson, Wong & Co.（史蒂文森、黄氏及公司）、Voice of Guo Media, Inc.（郭媒体之声公司）、Well Origin Ltd.（良好起源有限公司）、World Century Limited（世界世纪有限公司）、Worldwide Opportunity Holdings Limited（全球机遇控股有限公司）、Whitecroft Shore Limited（怀特克罗夫特海岸有限公司）以及 ZIBA Limited（ZIBA有限公司）。\n\n9. “Including”或其任何变体意为“包括但不限于”。\n\n10. “And”和“or”意为“和/或”，并应同时解释为连词和选择词，以最大限度地扩大其范围。\n\n11. “Any”、“all”和“each”意为“每一及全部”。\n\n12. “Each”和“every”意为“每一及全部”。\n\n13. “Third Party”是指您本人以外的个人或实体。\n\n14. “Transfer”具有《破产法》第 101(54) 条赋予该词的含义。\n\n15. “Document”是指属于 Fed. R. Civ. P. 34 范围内的任何信息或物品，并包括但不限于由您占有、保管或控制的，或曾由您占有、保管或控制的各种、各类、任何性质或描述的每一书面、记录或图形资料，包括电子邮件的所有印刷及电子副本、保存于的计算机文件\n\n案件 22-50073 文书 1592 提交于 03/24/23 登记于 03/24/23 10:57:37 第 982 页，共 1063 页\n\n电子形式、电子通信、短信、社交媒体帖子、推文、元数据、通信函件、备忘录、录音带、速记或手写笔记、任何形式的书面表格、图表、蓝图、图纸、草图、图形、计划、文章、规格说明、日记、信函、电报、照片、会议记录、合同、协议、调查资料、计算机打印件、任何种类的数据汇编、电传、传真、语音留言、发票、订购单、支票、汇票、对账单、贷项通知单、报告、职位报告、摘要、索引、书籍、账簿、笔记本、清单、透明胶片、录音、目录、广告、宣传材料、影片、录像带、录音带、CD、计算机磁盘、宣传册、手册、穿孔卡、工时单、推文、社交媒体帖子，或任何其他种类的书面或录制材料，以及其全部元数据，无论以何种方式存储（无论为有形或电子形式）、记录、制作或复制，并且还包括但不限于上述任何文件的草稿或副本，只要其包含原始文件中未见的任何种类的笔记、评论或标记，或者在其他方面与原始文件不完全相同。\n\n16. “人员”是指个人、公司、独资企业、合伙企业、协会或任何其他实体。“人员”还包括任何代理人、代表或专家，包括但不限于律师或财务顾问。\n\n17. “实体”是指任何自然人、公司、合伙企业、子公司、独资企业、商号、董事会、合资企业、协会、机构、主管部门、委员会或其他商业实体或法人，以及任何关联方、代理人、母公司，包括但不限于法律顾问、财务顾问或任何其他代表。\n\n18. “关于”是指涉及、描述、包括、提及、与之有关、支持、有利于、反对、加强、减损、载于、结合考虑、影响、证明、表明、报告、记录、暗指、回应、\n案件 22-50073 文件 1592 提交于 03/24/23 录入于 03/24/23 10:57:37 第 983 页，共 1063 页\n\n与之相连、评论、就其而言、关于、与之相关、讨论、显示、描述、反映、分析、构成及属于。\n\n19. 在提及任何特定事项时，“与……有关”、“涉及”或“相关”是指，包括但不限于，构成、包括、涉及、载有、体现、反映、识别、陈述、直接或间接提及该特定事项，或以任何方式与所识别的特定事项相关的任何文件。\n\n20. “通信”在最广义且不限于此的意义上，是指任何信息或知识的传递（以事实、观点、询问或其他形式）。通信还指所有谈话、协议、询问或答复，无论是当面、通过电话、书面方式，还是通过电子传输设备进行，并包括但不限于所有函件、电子邮件、录音、传送单、备忘录、电话通信、语音留言、电报、传真、电传、即时消息、聊天记录、短信、电话笔记，或在内部或与第三方之间传送的笔记。\n\n21. “资产”是指任何可用于产生正面经济价值的项目，包括但不限于由某一实体拥有、控制或使其受益，并预期将提供未来利益的任何具有经济价值的资源，包括但不限于所有不动产和动产、无形财产、投资、投资权或未来收入权、现金、银行账户、商品、证券、债权、对某一实体的全部或部分控制权，以及潜在的经济机会。\n\n22. “转让”应具有《破产法》第 101(54) 条赋予该词的含义。\n\n四、应提交的文件\n\n1. 关于债务人、债务人破产财产或关联实体的任何收入或资产的所有文件。\n\n2. 与债务人的财务状况及其对债权人的义务有关的所有文件，包括但不限于与任何规避支付该等义务的努力有关的所有文件，以及与本次或任何其他实际或潜在的破产或类似无力偿债程序有关的所有文件。\n\n3. 关于与债务人、债务人破产财产、债务人家庭成员、关联实体或关联个人有关的任何资产负债表、银行对账单、账户对账单、财务报表、账户报表、电汇指示及/或确认、资金证明、存款证明、持有证明、投资组合摘要或类似文件的所有文件，包括但不限于足以显示向上述任何主体进行的所有转让的所有文件。\n\n4. 关于债务人作出、与债务人进行或代表债务人作出的任何投资、商业交易或其他交易的所有文件。\n\n5. 与债务人的所有通信，以及与债务人的通信有关、涉及任何实体（包括但不限于关联实体）的运营、管理或决策的文件。\n\n6. 关于向债务人、由债务人或与债务人、债务人家庭成员或关联实体进行的任何转让、投资或其他交易或商业往来的所有文件。\n\n7. 关于债务人曾占用或使用的任何财产的所有文件，包括但不限于 Lady May；Sherry Netherland Hotel / Condominium；位于 Connecticut（康涅狄格州）Greenwich（格林尼治）373 Taconic Rd. 的住宅物业；位于 Connecticut（康涅狄格州）Greenwich（格林尼治）33 Ferncliff Rd. 的住宅物业；以及位于 Connecticut（康涅狄格州）Wilton（威尔顿）354 Nod Hill Rd. 的住宅物业。\n案件 22-50073 文件 1592 提交于 03/24/23 录入于 03/24/23 10:57:37 第 985 页，共 1063 页\n\n8. 与债务人拥有、控制或使用的任何飞机有关的所有文件，包括但不限于尾号为 T7-GQM 的飞机及在 San Marino（圣马力诺）登记的任何其他飞机，包括但不限于所有登记文件的副本，以及显示该等飞机所执飞航班和该等航班上所载人员的航班清单。\n\n9. 关于向债务人、债务人破产财产、债务人家庭成员或关联实体提供、从其取得或代表其提供的任何赠与、利益或贷款的所有文件，包括但不限于足以显示该等赠与、利益或贷款金额；该等赠与、利益或贷款的用途；提供该等赠与、利益或贷款的时间；以及任何贷款的条款、与任何贷款有关的所有陈述和保证、任何贷款的利率及任何贷款付款的所有证据的文件。\n\n10. 关于由债务人、债务人破产财产、债务人家庭成员或关联实体设立、代表其设立或为其利益设立的任何信托或类似文书的所有文件，包括但不限于足以显示信托设立时间、设立人、为谁的利益设立以及信托财产的文件。\n\n11. 与涉及债务人的任何法律争议有关的任何义务、债权、责任或债务的所有文件，包括但不限于与在任何地方、州、联邦或国际机构（无论为行政机构、法院、合议庭或替代性争议解决实体）进行的任何诉讼有关的文件。\n案件 22-50073 文件 1592 提交于 03/24/23 录入于 03/24/23 10:57:37 第 986 页，共 1063 页\n\n12. 贵方的任何外聘律师或其他顾问与债务人之间的所有文件和通信。\n\n13. 足以显示贵方全部资产及收入或资金来源的文件。\n\n14. 对于就请求第14项所识别的、价值超过 $50,000 的所有资产，(i) 与贵方取得该等资产有关的所有文件，以及 (ii) 与债务人或债务人家庭成员就该等资产进行的通信。\n\n15. 贵方纳税申报表的副本。\n\n16. 足以显示贵方占有或控制的所有银行账户和投资账户的文件，包括每一该等账户的余额以及转入和转出该等账户的款项。\n\n17. 关于贵方使用的任何信用卡的所有文件，包括但不限于月度对账单或足以显示为债务人或关联实体利益而进行的所有相关购买的其他文件。\n\n18. 所有公司治理及组织文件，包括但不限于章程细则和公司注册证书，以及足以显示贵方公司结构、高级管理人员及董事姓名、经营目的以及与债务人或债务人任何家庭成员关系的其他文件。\n\n19. 与贵方向任何其他实体质押贵方资产有关的所有文件。\n\n案件 22-50073 文件 1592 提交于 03/24/23 录入于 03/24/23 10:57:37 第 987 页，共 1063 页\n附件 C-54\nB2540（表格 2540——Rule 2004 审查传票）（12/15）案件 22-50073 文件 1592 提交于 03/24/23 录入于 03/24/23 10:57:37 第 988 页，共\n\n美国破产法院 1063\n\n康涅狄格州地区\n\n关于 HO WAN KWOK（郭文贵）等人，\n\n1 案号 22-50073 (JAM)\n\n债务人 第 11 章\n\n（合并管理）\nRule 2004 审查传票\n\n致：Leading Shine NY Ltd.（纽约领耀有限公司）\n\n（传票所指向人员的姓名）\n\n证言：现命令贵方于下列载明的时间、日期和地点出席，并根据《联邦破产程序规则》第 2004 条接受审查并作证。随附一份授权该项审查的法院命令副本。\n\n地点　日期和时间\n\nPaul Hastings LLP（保罗·黑斯廷斯律师事务所）\n200 Park Avenue　[TBD]\nNew York, New York 10166（纽约州纽约市 10166）\n\n审查将通过以下方式记录：法庭记录员/速记员\n\n提交：贵方或贵方代表还必须在审查时携带以下文件、电子存储信息或物品，并必须允许对该等材料进行查验、复制、测试或抽样：\n见随附的文件提交请求。\n\n下列《联邦民事诉讼规则》第 45 条规定已随附，该条通过《联邦破产程序规则》第 9016 条适用于破产案件——有关履行地点的第 45(c) 条；有关贵方作为传票对象所受保护的第 45(d) 条；以及有关贵方回应本传票的义务及未回应的潜在后果的第 45(e) 条和第 45(g) 条。\n\n日期：March , 2023\n\n法院书记员\n\n或\n\n书记员或副书记员签名　律师签名\n\n签发或请求本传票、代表第 11 章受托人 Luc A. Despins（吕克·A·德斯平斯）的律师姓名、地址、电子邮件地址及电话号码如下：\n\nDouglas S. Skalka, Esq.（道格拉斯·S·斯卡尔卡律师）；Neubert, Pepe & Monteith, P.C.（纽伯特、佩佩与蒙泰思专业公司）；195 Church Street, New Haven, Connecticut 06510（康涅狄格州纽黑文市丘奇街195号）dskalka@npmlaw.com；(203) 821-2000\n\n致签发或请求本传票的人员的通知\n\n如本传票要求在审判前提交文件、电子存储信息或有形物品，或者查验场所，则必须在向传票所指向的人员送达之前，向每一当事人送达本传票的通知和副本。Fed. R. Civ. P. 45(a)(4)。\n\n软件版权 (c) 1996-2022 Best Case, LLC（最佳案件有限责任公司）- www.bestcase.com Best Case Bankruptcy（最佳案件破产软件） 1 本第 11 章案件中的债务人为 Ho Wan Kwok（郭文贵，亦称 Guo Wengui、Miles Guo 和 Miles Kwok，以及众多其他别名）（税务识别号后四位：9595）、Genever Holdings LLC（税务识别号后四位：8202）及 Genever Holdings Corporation。受托人、Genever Holdings LLC 和 Genever Holdings Corporation 的邮寄地址为 Paul Hastings LLP（保罗·黑斯廷斯律师事务所），200 Park Avenue, New York, NY 10166，转交 Luc A. Despins（吕克·A·德斯平斯），其作为 Ho Wan Kwok 破产财产受托人（仅为通知和通信之目的）。\n\n送达证明\n\n（除非 Fed. R. Civ. P. 45 要求，否则本节不应向法院提交。）\n\n本人于（日期）收到本传票，送达对象为（个人姓名及职务，如有）：\n\n本人按如下方式，通过向所列明人员交付副本，送达了本传票：\n\n于（日期）；或\n\n本人未执行本传票即予退回，原因如下：\n\n除非本传票系代表美国或其官员或代理人签发，本人亦已向证人预付一天出庭费用及法律允许的里程费，金额为 $ 。\n\n本人的差旅费用为 $ ，服务费用为 $ ，合计 $ 。\n\n本人在伪证罪处罚的约束下声明，该等信息真实无误。\n\n日期：\n\n送达人员签名\n\n打印姓名及职务\n\n送达人员地址\n\n关于尝试送达等事项的补充信息：\n《联邦民事诉讼规则》第45(c)、(d)、(e)及(g)条（自12/1/13起生效）（根据《联邦破产程序规则》第9016条适用于破产案件）\n(c) 履行地点。\n\n(1) 审判、听证或证言录取。传票仅可按下列方式命令某人出席审判、听证或证言录取：\n\n(A) 在该人居住、受雇或经常亲自从事营业之地100英里范围内；或\n\n(B) 在该人居住、受雇或经常亲自从事营业所在州内，如该人\n\n(i) 是当事人或当事人的高级职员；或\n\n(ii) 被命令出席审判且不会产生重大费用。\n\n(2) 其他证据开示。传票可以命令：\n\n(A) 在该人居住、受雇或经常亲自从事营业之地100英里范围内的地点提供文件、电子存储信息或物品；以及\n\n(B) 在待检查场所对该场所进行检查。\n(d) 保护受传票约束的人；执行。\n\n(1) 避免不当负担或费用；制裁。负责签发和送达传票的当事人或律师，必须采取合理措施，避免对受传票约束的人施加不当负担或费用。要求履行的地区法院必须执行该项义务，并对未遵守者的当事人或律师施加适当制裁，制裁可包括损失的收入和合理的律师费。\n\n(2) 命令提供材料或允许检查。\n\n(A) 无需出席。被命令提供文件、电子存储信息或有形物品，或允许检查场所的人，无需亲自到提供或检查地点出席，除非其亦被命令出席证言录取、听证或审判。\n\n(B) 异议。被命令提供文件或有形物品，或允许检查的人，可以就检查、复制、测试或抽样任何或全部材料，或检查场所，或以要求的形式提供电子存储信息，向传票中指定的当事人或律师送达书面异议。异议必须在规定的履行时间或传票送达后14日中较早的时间之前送达。如提出异议，适用以下规则：\n\n(i) 在任何时候，经通知被命令之人，送达传票的一方可以向要求履行的地区法院提出动议，请求作出强制提供或检查的命令。\n\n(ii) 仅可按照命令所指示的方式要求实施该等行为，且该命令必须保护既非当事人亦非当事人高级职员的人，使其免受因履行而产生的重大费用。\n(3) 撤销或修改传票。\n\n(A) 必须撤销或修改的情形。经及时动议，要求履行的地区法院必须撤销或修改符合下列情形的传票：\n\n(i) 未给予合理的履行时间；\n\n(ii) 要求某人在第45(c)条规定的地理范围以外履行；\n\n(iii) 要求披露享有特权或受其他保护的事项，且不存在适用的例外或豁免；或\n\n(iv) 对某人施加不当负担。\n\n(B) 可以撤销或修改的情形。为保护受传票约束或受其影响的人，如传票要求下列事项，要求履行的地区法院可依动议撤销或修改传票：\n\n(i) 披露商业秘密或其他保密的研究、开发或商业信息；或\n\n(ii) 披露未经聘用的专家的意见或信息，该等意见或信息并非描述争议中的具体事件，且源于该专家未经任何一方请求而进行的研究。\n\n(C) 规定条件作为替代办法。在第45(d)(3)(B)条所述情形下，如送达传票的一方：\n\n(i) 证明其对该证言或材料具有重大需要，且如无不当困难无法以其他方式满足该需要；并且\n\n(ii) 确保被传唤之人将获得合理报酬，\n\n法院可以不撤销或修改传票，而命令在规定条件下出席或提供材料。\n(e) 回应传票的义务。\n\n(1) 提供文件或电子存储信息。下列程序适用于提供文件或电子存储信息：\n\n(A) 文件。回应要求提供文件之传票的人，必须按照文件在日常业务过程中保存的方式提供文件，或者必须整理并标记文件，使其对应于请求中所列类别。\n\n(B) 未规定电子存储信息的提供形式。如传票未规定电子存储信息的提供形式，回应之人必须以其通常保存的形式，或以一种或多种合理可用的形式提供该等信息。\n\n(C) 电子存储信息仅须以一种形式提供。回应之人无需以一种以上形式提供同一电子存储信息。\n\n(D) 无法合理获取的电子存储信息。回应之人无需就其认定因不当负担或费用而无法合理获取的来源中的电子存储信息提供证据开示。在强制证据开示动议或保护令动议中，回应之人必须证明该信息因不当负担或费用而无法合理获取。如作出该等证明，法院在考虑第26(b)(2)(C)条的限制后，如请求方证明存在正当理由，仍可命令从该等来源进行证据开示。法院可以规定证据开示的条件。\n(2) 主张特权或保护。\n\n(A) 扣留的信息。以信息享有特权或作为审判准备材料受到保护为由而扣留被传唤信息的人，必须：(i) 明确提出该主张；以及\n\n(ii) 以一种在不披露本身享有特权或受保护的信息的情况下，足以使当事人评估该主张的方式，描述被扣留文件、通信或有形物品的性质。\n\n(B) 已提供的信息。如为回应传票而提供的信息受特权主张或作为审判准备材料受保护的主张约束，提出该主张之人可以将该主张及其依据通知收到该信息的任何当事人。收到通知后，当事人必须立即返还、隔离或销毁所指定的信息及其持有的任何副本；在该主张得到解决前不得使用或披露该信息；如该当事人在收到通知前已披露该信息，必须采取合理措施追回该信息；并可立即将该信息密封提交给要求履行的地区法院，以裁定该主张。提供该信息之人必须在该主张得到解决前保存该信息。\n\n(g) 藐视法庭。要求履行的地区法院，以及在动议移送后签发传票的法院，可以认定已被送达但无充分理由不遵守传票或相关命令的人构成藐视法庭。\n\n有关传票材料，请参见 Fed.R.Civ.P.45(a) Committee Note (2013)\n\n……\n\n文件提供请求\nI. 指示\n\n1. 除非另有说明，下列文件请求（以下简称“请求”，单称“一项请求”）必须分别且具体地作出答复。每项请求均应完整答复，除非基于善意提出异议；在该情形下，应按如下所述详细说明贵方异议的理由。如异议仅涉及某项请求的一部分，或其中包含的某个词语、短语或条款，贵方仅须说明对该部分的异议，并答复其余请求。\n\n2. 电子存储信息必须依照下列指示提供：\n\na. 图像。黑白图像必须为300 DPI Group IV单页TIFF文件。彩色图像必须以JPEG格式提供。文件名不得含有嵌入空格或特殊字符（包括逗号）。文件夹名不得含有嵌入空格或特殊字符（包括逗号）。所有TIFF图像文件必须具有唯一文件名，即Bates编号。每张图像的右下角必须标注连续的Bates编号。每个文件夹中的TIFF文件数量不应超过1000个文件。Excel电子表格应具有以该文件的Bates编号命名的占位图像。\n\nb. 图像加载文件\n\na. Concordance®数据文件。数据文件（.DAT）包含将加载到Concordance®数据库中的全部字段信息。.DAT文件的第一行必须为标明字段名称的标题行。.DAT文件必须使用以下Concordance®默认分隔符：逗号ASCII字符（020）引号þ ASCII字符（254）。日期字段应采用以下格式：mm/dd/yyyy。日期和时间字段必须为两个独立字段。如文件包括图像化的电子邮件及附件，必须包括附件字段，以保留电子邮件与其附件之间的父子关系。必须包括OCRPATH字段，以提供在所提供存储介质上提取文本文件的文件路径及名称。文本文件必须以FIRSTBATES命名。请勿在.DAT文件中包括文本。对于具有原生文件的文件，必须包括LINK字段，以提供原生文件的文件路径和名称。原生文件必须以FIRSTBATES命名。\n\nb. Concordance Image® 或 Opticon 交叉引用文件。图像交叉引用文件（.LOG 或 .OPT）将图像链接至数据库记录。该文件应为逗号分隔文件，每行由七个字段组成；数据库中的每个图像均应在交叉引用文件中对应一行，格式如下：ImageID,VolumeLabel,ImageFilePath,DocumentBreak,FolderBreak,Box Break,PageCount。\n\nc. 文档文本。文本必须作为单独的文本文件提供，而非作为 .DAT 文件中的字段提供。应在 .DAT 文件中包含文本文件的完整路径（OCRPATH）。建议提供以 FIRSTBATES/Image Key 命名的文档级 ANSI 文本文件。提取的文本文件必须存放在单独的文件夹中，每个文件夹中的文本文件数量不得超过 1,000 个。文件夹名称中不得含有特殊字符（包括逗号）。文本文件必须按文档级别提供。\n\nd. 特定文件类型的原生格式交付。为充分理解其内容和含义而合理需要以原生格式查看的文件类型，必须以原生格式提供。此类文件包括但不限于电子表格、类似电子表格的文件（Microsoft Excel、逗号分隔值、制表符分隔值等）、Microsoft PowerPoint 或其他特殊演示文件、数据库文件以及音频/视频文件。应提供一张带有 Bates 编号的提示页图像，标明存在原生文件，并在 .dat 文件中将原生文件的路径作为一个字段列入。所提供的原生文件应以与该文件提示页对应的 Bates 编号命名。原生文件应归入按递增方式命名的“NATIVE”目录中，并与图像目录分开。\n\ne. 去重。对于存在完全重复件的每一电子文档，应仅提供一份。对于电子邮件，应根据由 BCC、Body、CC、From、IntMsgID、To 和 Attach 属性生成的 MD5 哈希值合并重复件。对于电子邮件附件和独立电子文件，应根据整个文件的 MD5 哈希值合并重复件。\n\nf. 元数据。应以符合 Concordance 要求的加载文件（.dat）形式提供每份文档的提取元数据。.DAT 文件的第一行必须为标明字段名称的标题行。.DAT 文件必须使用下列 Concordance 默认分隔符：逗号 , ASCII 字符（020）引号 þ ASCII 字符（254）\n\n日期字段应采用如下格式提供：mm/dd/yyyy。日期字段和时间字段必须为两个独立字段。以下为必需元数据：\nCase 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 993 of 1063\n\n字段名称　示例数据　说明\n\nFIRSTBATES　EDC0000001　原生文件文档/电子邮件的第一个 Bates 编号\nLASTBATES　EDC0000001　原生文件文档/电子邮件的最后一个 Bates 编号\n注：对于单页文档，应填写 LASTBATES 字段。\nATTACHRANGE　EDC0000001 - EDC0000015　从父文档第一页的 Bates 编号至最后一个附件“子”文档最后一页的 Bates 编号\nBEGATTACH　EDC0000001　附件范围的第一个 Bates 编号\nENDATTACH　EDC0000015　附件范围的最后一个 Bates 编号\nCUSTODIAN　Smith, John　电子邮件：电子邮件所在的邮箱\n原生文件：文档源自其文件的个人或部门名称\nFROM　John Smith　电子邮件：发件人\n原生文件：文档作者\n注：应使用分号分隔多个条目。\nTO　Coffman, Janice; LeeW [mailto:LeeW@MSN.com]　收件人\n注：应使用分号分隔多个条目。\nCC　Frank Thompson [mailto:frank_Thompson@cdt.com]　抄送收件人\n注：应使用分号分隔多个条目。\nBCC　John Cain　密送收件人\n注：应使用分号分隔多个条目。\nSUBJECT　Board Meeting Minutes　电子邮件：电子邮件主题行；原生文件：文档标题（如有）\nFILE_NAME　BoardMeetingMinutes.docx　原生文件：原始原生文件的名称，包括扩展名\nDATE_SENT　10/12/2010　电子邮件：电子邮件发送日期\n原生文件：（空）\nTIME_SENT/TIME_ZONE　07:05 PM GMT　电子邮件：电子邮件发送时间/电子邮件标准化所采用的时区\nTIME_ZONE　GMT　在转换过程中对电子邮件进行标准化所采用的时区。\nLINK　EDC0000001.msg　指向电子邮件或原生文件文档的超链接\n注：链接文件必须按 FIRSTBATES 编号命名。\nFILE_EXTEN　MSG　表示电子邮件或的文件类型扩展名\nAUTHOR　John Smith　电子邮件：（空）\n原生文件：文档作者\nDATE_CREATED　10/10/2010　电子邮件：（空）\n原生文件：文档创建日期\nCase 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 994 of 1063\n\nTIME_CREATED　10:25 AM　电子邮件：（空）\n原生文件：文档创建时间\n注：该数据必须为单独字段，不得与 DATE_CREATED 字段合并。\nDATE_MOD　10/12/2010　电子邮件：（空）\n原生文件：文档最后修改日期\nTIME_MOD　07:00 PM　电子邮件：（空）\n原生文件：文档最后修改时间\n注：该数据必须为单独字段，不得与 DATE_MOD 字段合并。\nDATE_ACCESSD　10/12/2010　电子邮件：（空）\n原生文件：文档最后访问日期\nTIME_ACCESSD　07:00 PM　电子邮件：（空）\n原生文件：文档最后访问时间\n注：该数据必须为单独字段，不得与 DATE_ACCESSD 字段合并。\nFILE_SIZE　5,952　原生文件文档/电子邮件的大小，以 KB 计\nPGCOUNT　1　原生文件文档/电子邮件的页数\nPATH　Email: (empty) Agenda.doc　电子邮件：（空）\n原生文件：存储原生文件文档的路径，包括原始文件名称。\nINTFILEPATH　Personal Folders\\Deleted Items\\Board Meeting Minutes.msg　电子邮件：电子邮件的原始位置，包括原始文件名称。\n原生文件：（空）\nINTMSGID　<000805c2c71b\\$75977050\\$cb8306d1@MSN>　电子邮件：唯一消息 ID；原生文件：（空）\nMD5HASH　d131dd02c5e6eec4693d9a0698aff95c2fcab58712467eab4004583eb8fb7f89　文档的 MD5 哈希值。\nOCRPATH　TEXT/001/EDC0000001.txt　原生文件提取文本的路径\n\n3. 每项请求均独立运作且应独立解释；除非另有说明，任何请求均不限制任何其他请求的范围。\n\n4. 所有文件均应按其在通常业务过程中保存的方式提供，或者应予组织和标注，以与本请求中的类别相对应。\n\n5. 本文所载每项请求均延伸至所有文件：（a）由您占有、保管或控制的文件；或（b）由任何代表您行事之人占有、保管或控制的文件，\nCase 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 995 of 1063\n\n包括您的律师或其他代表和顾问。每份文件均应完整提供。\n\n6. 如要求您提供一份已不再由您占有、保管或控制的文件，则您的答复必须：（a）详细描述该文件的性质及其内容；（b）确定编制或撰写该文件的人员（以及，如适用，该文件被发送给的人员）；（c）确定该文件编制或创建的日期；（d）说明该文件是否：（i）遗失或丢失；（ii）已被毁损；（iii）已自愿或非自愿地转移给他人；或（iv）以其他方式被处置；（e）说明该处置的原因，以及围绕该处置的事实和情形；（f）确定授权该处置的人员；（g）确定该处置的日期或大致日期；（h）说明该文件最近一次由您占有、保管或控制的时间；以及（i）确定目前占有、保管或控制该文件的人员（如有）。\n\n7. 如要求您提供一份已被毁损的文件，则除前述指示所要求的信息外，您的答复还必须说明：（a）毁损该文件的原因；（b）毁损该文件的人员身份；以及（c）指示毁损该文件的人员身份。\n\n8. 如您主张所请求的文件享有特权或属于律师工作成果，则您的答复必须：（a）说明：（i）足以支持您关于该文件享有特权之主张的文件描述；（ii）该文件的标题；（iii）该文件的日期；（iv）该文件的作者；（v）该文件的收件人；（vi）收到或阅览该文件原件或任何草稿、副本或复制件的每一人员身份；（vii）该文件本身或该文件所含或所提及的任何信息是否由任何其他人员占有、保管或控制，如是，则须确定该等人员的身份，\nCase 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 996 of 1063\n\n并说明该信息如何进入其占有；（viii）据以扣留该文件的特权主张；以及（ix）您将据以支持该特权主张的所有情形；以及（b）就基于特权主张而扣留的每份文件，依照 D. Conn. L. Civ. R. 26(e)，提供一份特权日志，其中载明本指示第（a）部分所要求的全部信息。\n\n9. 如本应作出回应的文件的一部分含有受特权主张约束的信息，则仅应依照上述指示从该文件中删除或遮蔽受特权主张约束的部分，其余部分应予提供。\n\n10. 本请求具有持续性。特此指示您：（a）一旦得知先前答复不完整或不正确，立即补充或更正任何后来发现不完整或不正确的答复；以及（b）提供根据该等要求所要求的任何附加文件。\n\n11. 如一份文件使用英语以外的语言，您应提供该文件。如一份文件使用英语以外的语言且存在英文译本，您应同时提供两份文件。\n\n12. 对实体的所有提及均包括其所有关联方。\n\n13. 对个人姓名的所有提及均包括所有其他名称、别名或昵称。\n\n14. 除非另有明确说明，文件请求所涵盖的期间为自 February 5, 2012 起至应提交文件请求答复之日止。\nCase 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 997 of 1063\n\nII. 解释规则\n\n15. （a）任何单数名词的使用均应解释为包括复数，反之亦然；（b）任何时态的动词均应解释为使用该动词的所有其他时态。\n\n16. （a）“and”和“or”两个术语应按必要情况解释为连词或析取词，以使原本可能被解释为不在任何请求范围内的所有答复均纳入该请求范围；以及（b）“each”和“any”应视为包括并涵盖“every”和“all”二词。\n\nIII. 定义\n\n经 D. Conn. Bankr. L.R. 2004-1(a) 纳入的 D. Conn. L. Civ. R. 26(c) 所规定的定义，以及 D. Conn. L. Civ. R. 26(d) 所规定的解释规则，适用于文件请求。此外，本文件请求中使用的下列术语具有以下含义：\n\n1. “您”或“您的”或“您本人”是指 Leading Shine NY Ltd.（纽约领先辉煌有限公司），以及其所有关联方、部门、机构、工具部门、处室、办公室、合伙人、高级职员、董事、代理人、律师、代表、雇员和/或任何代表其行事之人。\n\n2. “债务人”是指 Ho Wan Kwok（郭文贵）（又名 Miles Kwok、Miles Guo、Guo Wengui、Guo Haoyun、郭文贵或任何其他别名），以及其雇员、代理人、律师、顾问或任何代表其行事之人。\n\n3. “债务人之子”系指 Qiang Guo（郭强，又名 Mileson Kwok 或任何其他别名），以及其雇员、代理人、律师、顾问或任何代表其行事之人。\n案件 22-50073 文件 1592 提交日期 03/24/23 录入日期 03/24/23 10:57:37 第 998 页，共 1063 页\n\n4. “债务人之女”系指 Mei Guo（郭美，又名 Mei Gui 或任何其他别名），以及其雇员、代理人、律师、顾问或任何代表其行事之人。\n\n5. “债务人声称的妻子”系指 Hing Chi Ngok（岳庆芝，又名 Hing Chi Ng、Yue Qingzhi 或任何其他别名），以及其雇员、代理人、律师、顾问或任何代表其行事之人。\n\n6. “债务人家属”统称债务人、债务人之子、债务人之女及债务人声称的妻子，以及与债务人具有任何其他亲属关系之人。\n\n7. “关联个人”单独及共同系指所有符合下列情形的个人：(1) 持有、控制、保管或对债务人或债务人家属拥有、控制或享有的资产具有处置权；或 (2) 曾为一个或多个关联实体的雇员、董事，或以其他方式与其关联者，以及前述各方各自的雇员、代理人、律师、顾问或任何代表前述任何一方行事之人。该等关联个人应包括但不限于：Daniel Podhaskie、Jason Miller、Steve Bannon、Karin Maistrello、Melissa Francis、Anthony DiBattista、William Gertz、Arethusa Forsyth、Glenn Mellor、Jennifer Mercurio、Eduardo Eurnekian、Wencong Wang、Han Chunguang（韩春光）、Qu Guojiao（屈国姣，又名 Qu Guo Jiao）、Guo Lijie（郭丽杰）、Zhang Wei（张伟*）、Lihong Wei Lafrenz（魏丽红，又名 Sara Wei）、Hao Haidong（郝海东）、Ross Heinemeyer、Max Krasner、Kyle Bass、Melissa Mendez、Ya Li（李娅）、Dinggang Wang（王定刚）、An Hong（安红）、Yvette Wang（王雁平，又名 Yanping Wang、Yan Ping Wang）、Fiona Yu、Je Kin Ming（余建明，又名 William Je、Yu Jianming）、Yaz Qingua，以及 Lao Jiang（姜云浮，又名 Jiang Yunfu、Jiang Yunfu Be）。\n案件 22-50073 文件 1592 提交日期 03/24/23 录入日期 03/24/23 10:57:37 第 999 页，共 1063 页\n\n8. “关联实体”单独及共同系指所有符合下列情形的任何类型组织或实体：(1) 曾由债务人或债务人家属拥有、控制或投资；或 (2) 对债务人或债务人家属拥有、控制或享有的任何资产直接或间接享有权益，以及前述各方各自的雇员、代理人、律师、顾问或任何代表前述任何一方行事之人。该等关联实体应包括但不限于：7 Nod Hill LLC、AAGV Limited、ACA Investment Management Limited、ACA Capital Group Limited、Ace Decade Holdings Limited、AI Group Holdings Inc.、Alfa Global Ventures Limited、Alfonso Global Limited、Allied Capital Global Limited、Alpine Fiduciaries SA、Anton Development Limited、Assets Sino Limited、Auspicious Coast Limited、Beijing Pangu Investment Co.、Beijing Pangu Investment Co. Ltd.、Beijing Pangu Investment Inc.、Beijing Zenith Holdings Company Limited、Booming Sail New York LLC、Bravo Luck Limited、BSA Strategic Fund I、China Golden Spring (Hong Kong) Limited、Chuang Xin Limited、Crane Advisory Group LLC、Creative Apex Investments Limited、Crystal Breeze Investments Limited、Dawn State Limited、Eastern Profit Corporation Limited、Elite Well Global Limited、Empire Growth Holdings、Freedom Media Ventures Ltd.、G Club Operations LLC、G Fashion LLC、G News LLC、GETTR USA、Genever Holdings Corporation、Genever Holdings LLC、Gfashion Media Group Inc.、GFNY, Inc.、Globalist International Limited、GNews Media Group Inc.、Golden Spring (New York) Ltd.、Greenwich Land LLC、Guo Media、GTV Media Group, Inc.、Hamilton Capital Holdings Inc.、HCHK Property Management, Inc.、HCHK Technologies, Inc.、Head Win Group Limited、Henan Yuda、Himalaya Embassy、Himalaya Exchange、Himalaya Federal Reserve、Himalaya Investment LLC、Himalaya International、Himalaya New World Inc.、Himalaya Supervisory Organization、Himalaya Ventures LLC、HK International Funds Investments (USA) Limited LLC、Hong Kong International Funds\n案件 22-50073 文件 1592 提交日期 03/24/23 录入日期 03/24/23 10:57:37 第 1000 页，共 1063 页\n\nInvestments Limited、Hudson Diamond Holding、Infinite Increase Limited、Infinitum Developments Limited、Infinity Treasury Management Inc.、Insight Phoenix Fund、Lamp Capital LLC、Leading Shine Limited、Leading Shine NY Limited、Lexington Property and Staffing、Long Gate Limited、Maywind Trading LLC、MOS Himalaya LLC、Next Tycoon Investments Limited、New Federal State of China（又名 NFSC）、Noble Fame Global Limited、Rosy Acme Ventures Limited、Rule of Law Foundation III, Inc.、Rule of Law Foundation IV, Inc.、Rule of Law Fund、Rule of Law Society、Rule of Law Society IV, Inc.、G-Translators PTY LTD、Saraca Media Group, Inc.、Shiny Ace Ltd.、Shiny Times Holdings Ltd.、Spirit Charter Investment Limited、Stevenson, Wong & Co.、Voice of Guo Media, Inc.、Well Origin Ltd.、World Century Limited、Worldwide Opportunity Holdings Limited、Whitecroft Shore Limited，以及 ZIBA Limited。\n\n9. “包括”或其任何变体，系指“包括但不限于”。\n\n10. “和”及“或”系指“和/或”，并应为最大限度扩大其范围而同时作连词性及析取性解释。\n\n11. “任何”及“所有”及“每一”系指“每一个和所有”。\n\n12. “每一”及“每个”系指“每一个和所有”。\n\n13. “第三方”系指除您本人以外的个人或实体。\n\n14. “转让”应具有《破产法》第 101(54) 条赋予其的含义。\n\n15. “文件”系指属于 Fed. R. Civ. P. 34 范围内的任何信息或物品，并包括但不限于在您的占有、保管或控制之下或曾在您的占有、保管或控制之下的每一项任何种类、类型、性质或描述的书面、记录或图形材料，包括电子邮件的所有打印及电子副本、以电子形式保存的计算机文件、电子通信、短信、社交媒体帖子、推文、元数据、函件、备忘录、磁带、速记或手写笔记、任何种类的书面表格、图表、蓝图、图纸、草图、曲线图、计划、文章、规格说明、日记、信函、电报、照片、会议记录、合同、协议、调查、计算机打印输出、任何种类的数据汇编、电传、传真、语音信息、发票、订购单、支票、汇票、对账单、贷项通知单、报告、仓位报告、摘要、索引、账簿、分类账、笔记本、明细表、透明胶片、录音、目录、广告、宣传材料、影片、录像带、录音带、CD、计算机磁盘、小册子、传单、穿孔卡、工时单、Tweets、社交媒体帖子，或任何其他种类的书面或记录材料，以及其全部元数据，无论其以何种方式存储（无论为有形或电子形式）、记录、制作或复制；还包括但不限于前述任何文件的草稿或副本，如其中载有原始文件中未载有的任何种类的笔记、评论或标记，或在其他方面与原始文件不完全相同。\n案件 22-50073 文件 1592 提交日期 03/24/23 录入日期 03/24/23 10:57:37 第 1001 页，共 1063 页\n\n16. “个人”系指个人、公司、独资企业、合伙企业、协会或任何其他实体。“个人”还包括任何代理人、代表或专家，包括但不限于律师或财务顾问。\n\n17. “实体”系指任何自然人、公司、合伙企业、子公司、独资企业、商号、董事会、合资企业、协会、机构、主管机关、委员会或其他商业实体或法人，以及任何关联方、代理人、母公司，包括但不限于法律顾问、财务顾问或任何其他代表。\n\n18. “关于”系指涉及、描述、构成、提及、与之相关、支持、有利于、反对、加强、削弱、载于其中、在关联中考虑、影响、证明、表明、报告、记录、暗示、回应、\n案件 22-50073 文件 1592 提交日期 03/24/23 录入日期 03/24/23 10:57:37 第 1002 页，共 1063 页\n\n与之相连、评论、就其而言、有关、与之相关、讨论、显示、描述、反映、分析、构成及为之。\n\n19. “与……有关”、“与……相关”或“有关联”，在指称任何特定事项时，系指但不限于构成、包含、涉及、含有、体现、反映、识别、陈述、直接或间接提及，或以任何方式与所指明特定事项相关的任何文件。\n\n20. “通信”系指在最广泛的可能意义上且不限于任何信息或知识的传递（以事实、思想、询问或其他形式）。通信还指所有谈话、协议、询问或答复，无论是当面、电话、书面，还是通过电子传输设备，并包括但不限于所有函件、电子邮件、录音、传送单、备忘录、电话通信、语音信息、电报、电传传真、复印传真、电传、即时消息、聊天、短信、电话笔记，或在内部或与第三方传送的笔记。\n\n21. “资产”系指任何可用于产生正面经济价值的项目，包括但不限于由某一实体拥有、控制或为其利益而持有的、预期将提供未来利益的任何具有经济价值的资源，包括但不限于所有不动产和动产、无形财产、投资、投资权或取得未来收入的权利、现金、银行账户、商品、证券、债权、对某一实体的全部或部分控制权，以及预期经济机会。\n\n22. “转让”应具有《破产法》第 101(54) 条赋予其的含义。\n案件 22-50073 文件 1592 提交日期 03/24/23 录入日期 03/24/23 10:57:37 第 1003 页，共 1063 页\n\nIV. 应提交的文件\n\n1. 与债务人、债务人破产财产或关联实体的任何收入或资产有关的所有文件。\n\n2. 与债务人的财务状况及其对债权人所负义务有关的所有文件，包括但不限于与任何规避支付该等义务之努力有关的所有文件，以及与本次或任何其他实际或潜在破产或类似无力偿债程序有关的所有文件。\n\n3. 与债务人、债务人破产财产、债务人家属、关联实体或关联个人有关的任何资产负债表、银行对账单、账户对账单、财务报表、账户报表、电汇指示和/或确认、资金证明、存款证明、持仓证明、投资组合摘要或类似文件有关的所有文件，包括但不限于足以显示向前述任何一方进行的所有转让的所有文件。\n\n4. 与债务人作出、与债务人进行或代表债务人作出的任何投资、商业交易或交易有关的所有文件。\n\n5. 与债务人的所有通信，以及与债务人就任何实体（包括但不限于关联实体）的运营、管理或决策有关的通信相关的文件。\n\n6. 与向债务人、债务人家属或关联实体作出、由其作出或与其进行的任何转让、投资或其他交易或商业往来有关的所有文件。\n\n7. 与债务人曾经占用或使用的任何财产有关的所有文件，包括但不限于 Lady May；Sherry Netherland Hotel / Condominium；位于 Connecticut 州 Greenwich 市 373 Taconic Rd. 的住宅物业；位于 Connecticut 州 Greenwich 市 33 Ferncliff Rd. 的住宅物业；以及位于 Connecticut 州 Wilton 市 354 Nod Hill Rd. 的住宅物业。\n\n8. 与债务人拥有、控制或使用的任何航空器有关的所有文件，包括但不限于尾号为 T7-GQM 的航空器以及在圣马力诺注册的任何其他航空器，包括但不限于所有登记文件副本，以及显示该等航空器所进行航班和该等航班机上人员的飞行清单。\n\n9. 关于向债务人、债务人破产财产、债务人家庭成员或关联实体提供、由其提供或代表其提供的任何赠与、利益或贷款的所有文件，包括但不限于足以显示该等赠与、利益或贷款金额的文件；该等赠与、利益或贷款的使用目的；提供该等赠与、利益或贷款的时间；以及任何贷款的条款、就任何贷款作出的所有陈述和保证、任何贷款的利率，以及任何贷款付款的全部证据。\n\n10. 关于由债务人、代表债务人或为债务人利益，或由债务人破产财产、债务人家庭成员或关联实体设立、代表其设立或为其利益设立的任何信托或类似工具的所有文件，包括但不限于足以显示该等信托的设立时间、设立人、为谁的利益而设立以及信托财产的文件。\n\n11. 与涉及债务人的任何法律争议有关的任何义务、请求权、责任或债务的所有文件，包括但不限于与在任何地方、州、联邦或国际机构——无论是行政机构、法院、合议庭或替代性争议解决实体——前进行的任何诉讼有关的文件。\n\nCase 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 1005 of 1063\n\n12. 您的任何外聘律师或其他顾问与债务人之间的所有文件和通信。\n\n13. 足以显示您的全部资产以及收入或资金来源的文件。\n\n14. 对于就请求第 14 项所识别、价值超过 \\$50,000 的全部资产，提供：(i) 与您取得该等资产有关的所有文件，以及 (ii) 与债务人或债务人家庭成员就该等资产进行的通信。\n\n15. 您的纳税申报表副本。\n\n16. 足以显示由您占有或控制的全部银行账户和投资账户的文件，包括每一该等账户的余额以及向该等账户和自该等账户进行的转账。\n\n17. 关于您使用的任何信用卡的所有文件，包括但不限于月度对账单或足以显示为债务人或关联实体利益而作出的全部相关购买的其他文件。\n\n18. 所有公司治理及组织文件，包括但不限于章程细则、公司注册证书，以及足以显示您的公司结构、高级管理人员和董事姓名、经营目的以及与债务人或债务人任何家庭成员关系的其他文件。\n\n19. 与将您的任何资产质押给任何其他实体有关的所有文件。\n\nCase 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 1006 of 1063\n\n附件 C-55\n\nB2540（表格 2540——依据规则 2004 进行审查的传票）（12/15）Case 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 1007 of\n\n美国破产法院 1063\n\n康涅狄格区\n\n关于 HO WAN KWOK（郭文贵）等人，\n\n1 案号 22-50073 (JAM) 债务人 第 11 章\n\n（合并管理）\n依据规则 2004 进行审查的传票\n\n致：Oasis Tech Limited（绿洲科技有限公司）\n\n（传票所指向之人的姓名）\n\n证言：兹命令您于下列规定的时间、日期和地点出席，依据《联邦破产程序规则》规则 2004 接受审查并作证。随附授权该审查的法院命令副本。\n\n地点　日期和时间\n\nPaul Hastings LLP（普衡律师事务所）\n200 Park Avenue　[待定]\nNew York, New York 10166\n\n审查将采用以下方式记录：法庭书记员／速记员\n\n提交：您或您的代表还必须携带下列文件、电子存储信息或物品参加审查，并必须准许对该等材料进行查验、复制、测试或抽样：\n\n见随附的文件提交请求。\n\n以下《联邦民事诉讼规则》规则 45 的规定，根据《联邦破产程序规则》规则 9016 适用于破产案件，现随附于后——有关履行地点的规则 45(c)；有关对作为传票对象之人的保护的规则 45(d)；以及有关您回应本传票的义务和未回应的可能后果的规则 45(e) 和 45(g)。\n\n日期：March , 2023\n\n法院书记员\n\n或\n\n书记员或副书记员签名　律师签名\n\n签发或请求本传票、代表第 11 章受托人 Luc A. Despins（卢克·A.·德斯平斯）的律师姓名、地址、电子邮件地址和电话号码如下：\n\nDouglas S. Skalka, Esq.（道格拉斯·S.·斯卡尔卡，律师）；Neubert, Pepe & Monteith, P.C.；195 Church Street, New Haven, Connecticut 06510；dskalka@npmlaw.com；(203) 821-2000\n\n致签发或请求本传票之人的通知\n\n如本传票命令在审判前提交文件、电子存储信息或有形物品，或查验场所，则必须在向传票指向之人送达之前，向每一当事人送达通知及本传票副本。《联邦民事诉讼规则》规则 45(a)(4)。\n\n软件版权 (c) 1996-2022 Best Case, LLC（百斯特凯斯有限责任公司）- www.bestcase.com Best Case Bankruptcy 1 本第 11 章案件中的债务人为 Ho Wan Kwok（郭文贵，亦称 Guo Wengui、Miles Guo、Miles Kwok 以及众多其他别名）（税务识别号后四位：9595）、Genever Holdings LLC（税务识别号后四位：8202）及 Genever Holdings Corporation。受托人、Genever Holdings LLC 和 Genever Holdings Corporation 的邮寄地址为：Paul Hastings LLP，200 Park Avenue, New York, NY 10166，转交 Luc A. Despins，作为 Ho Wan Kwok 破产财产的受托人（仅用于通知和通信目的）。\n\n送达证明\n\n（除非《联邦民事诉讼规则》规则 45 要求，否则本节不应向法院提交。）\n\n我于（日期）收到向（个人姓名及职务，如有）送达的本传票。\n\n我按如下方式向被指名之人交付副本，以送达本传票：\n\n于（日期）；或\n\n我未执行即退回本传票，原因如下：\n\n除非本传票系代表美国或其官员或代理人签发，我还已向证人支付一天出席费用及法律允许的里程费，金额为 \\$ 。\n\n我的差旅费用为 \\$，服务费用为 \\$，合计为 \\$。\n\n我在伪证处罚的约束下声明，该等信息真实且正确。\n\n日期：\n\n送达人员签名\n\n正楷姓名及职务\n\n送达人员地址\n\n关于尝试送达等事项的补充信息：\n\n《联邦民事诉讼规则》规则 45(c)、(d)、(e) 和 (g)（Effective 12/1/13）（根据《联邦破产程序规则》规则 9016 适用于破产案件）\n\n(c) 履行地点。\n\n(1) 审判、听证或证言录取。传票仅可按下列方式命令某人出席审判、听证或证言录取：\n\n(A) 在该人居住、受雇或通常亲自从事商业活动地点的 100 英里范围内；或\n\n(B) 在该人居住、受雇或通常亲自从事商业活动所在州内，如该人：\n\n(i) 是当事人或当事人的高级管理人员；或\n\n(ii) 被命令出席审判且不会产生重大费用。\n\n(2) 其他证据开示。传票可命令：\n\n(A) 在该人居住、受雇或通常亲自从事商业活动地点的 100 英里范围内某地提交文件、电子存储信息或物品；以及\n\n(B) 在待查验场所对该场所进行查验。\n\n(d) 对作为传票对象之人的保护；执行。\n\n(1) 避免不当负担或费用；制裁。负责签发及送达传票的当事人或律师必须采取合理措施，避免对作为传票对象之人施加不当负担或费用。要求履行的地区法院必须执行该义务，并对未遵守者——当事人或律师——施加适当制裁，该制裁可包括损失的收入和合理律师费。\n\n(2) 命令提交材料或准许查验。\n\n(A) 无须出席。被命令提交文件、电子存储信息或有形物品，或准许查验场所之人，无须亲自到提交或查验地点出席，除非同时被命令出席证言录取、听证或审判。\n\n(B) 异议。被命令提交文件或有形物品，或准许查验之人，可向传票中指定的当事人或律师送达书面异议，反对对任何或全部材料进行查验、复制、测试或抽样，或反对查验场所，或反对按所要求的一种或多种形式提交电子存储信息。异议必须在规定履行时间届满前或传票送达后 14 天内（以较早者为准）送达。如提出异议，适用下列规则：\n\n(i) 送达方可随时，在通知被命令之人后，向要求履行的地区法院提出动议，请求作出强制提交或查验的命令。\n\n(ii) 仅可依照命令的指示要求实施该等行为，且该命令必须保护非当事人且非当事人高级管理人员之人免受因履行而产生的重大费用。\n\n(3) 撤销或修改传票。\n\n(A) 必须撤销或修改的情形。经及时动议，要求履行的地区法院必须撤销或修改符合下列情形的传票：\n\n(i) 未给予合理履行时间；\n\n(ii) 要求某人在规则 45(c) 所规定地域限制之外履行；\n\n(iii) 在不适用任何例外或豁免的情况下，要求披露享有特权或受其他保护的事项；或\n\n(iv) 对某人施加不当负担。\n\n(B) 可以撤销或修改的情形。为保护作为传票对象或受传票影响之人，要求履行的地区法院可以依动议撤销或修改要求下列事项的传票：\n\n(i) 披露商业秘密或其他保密的研究、开发或商业信息；或\n\n(ii) 披露未受聘专家的意见或信息，而该等意见或信息并非描述争议中的特定事件，且源自该专家并非应当事人请求所进行的研究。\n\n(C) 以规定条件作为替代措施。在规则 45(d)(3)(B) 所述情形下，如送达方：\n\n(i) 证明对该证言或材料具有实质需要，且如不遭受不当困难则无法以其他方式满足该需要；以及\n\n(ii) 确保被传唤之人将获得合理补偿，\n\n法院可以不撤销或修改传票，而命令在规定条件下出席或提交。\n\n(e) 回应传票的义务。\n\n(1) 提交文件或电子存储信息。下列程序适用于提交文件或电子存储信息：\n\n(A) 文件。回应要求提交文件的传票之人，必须按照文件在通常业务过程中保存的方式提交，或者必须将文件整理并标记，使之与请求中的类别相对应。\n\n(B) 未规定电子存储信息的提交形式。如传票未规定提交电子存储信息的形式，回应之人必须按其通常保存的一种或多种形式，或按一种或多种合理可用的形式提交。\n\n(C) 电子存储信息仅以一种形式提交。回应之人无须以一种以上形式提交相同的电子存储信息。\n\n(D) 无法以电子方式访问的存储信息。作出答复的人无需就其认定因不当负担或成本而无法合理访问的来源中的电子存储信息提供证据开示。在提出强制证据开示动议或保护令动议时，作出答复的人必须证明该信息因不当负担或成本而无法合理访问。若作出该证明，法院仍可在请求方根据 Rule 26(b)(2)(C) 的限制条件证明存在正当理由时，命令从该等来源进行证据开示。法院可以规定证据开示的条件。\n\n(2) 主张特权或保护。\n\n(A) 被扣留的信息。依照信息享有特权或属于审判准备材料保护范围的主张而扣留经传票要求提供的信息的人必须：(i) 明确提出该主张；以及\n\n(ii) 以一种在不披露本身享有特权或受保护的信息的前提下，足以使各方评估该主张的方式，说明被扣留文件、通信或有形物品的性质。\n\n(B) 已提供的信息。如为回应传票而提供的信息受特权主张或审判准备材料保护主张的约束，提出该主张的人可以将该主张及其依据通知任何收到该信息的当事人。收到通知后，当事人必须立即返还、隔离或销毁所指定的信息及其持有的任何副本；在该主张得到解决之前，不得使用或披露该信息；如该当事人在收到通知前已披露该信息，必须采取合理措施追回该信息；并且可以立即将该信息密封提交至要求履行义务所在地区的法院，以裁定该主张。提供该信息的人必须保存该信息，直至该主张得到解决。\n\n(g) 藐视法庭。要求履行义务所在地区的法院——以及在动议被移送后，签发传票的法院——可以认定已被送达但无充分理由未遵守传票或与其相关命令的人构成藐视法庭。\n\n关于查阅传票材料，参见 Fed.R.Civ.P.45(a) 委员会说明（2013）\n\n……\n\n文件出示请求\nI. 指示\n\n1. 除非另有说明，下列文件请求（以下简称“请求”，每一项称为“一项请求”）必须分别且具体地作出答复。每一项请求均应得到完整答复，除非基于善意提出异议；在该情况下，必须如下文所述详细说明贵方异议的理由。若异议仅涉及某项请求的一部分，或该请求中包含的某个词语、短语或条款，贵方仅须说明对该部分的异议，并对其余请求作出答复。\n\n2. 电子存储信息必须依照下列指示提供：\n\na. 图像。黑白图像必须为 300 DPI Group IV 单页 TIFF 文件。彩色图像必须以 JPEG 格式提供。文件名不得含有嵌入式空格或特殊字符（包括逗号）。文件夹名称不得含有嵌入式空格或特殊字符（包括逗号）。所有 TIFF 图像文件必须具有唯一文件名，即 Bates 编号。每幅图像右下角必须标注连续的 Bates 编号。每个文件夹中的 TIFF 文件数量不应超过 1000 个。Excel 电子表格应具有以该文件的 Bates 编号命名的占位图像。\n\nb. 图像加载文件\n\na. Concordance® 数据文件。数据文件（.DAT）包含将被加载至 Concordance® 数据库的所有字段信息。.DAT 文件的第一行必须是标识字段名称的标题行。.DAT 文件必须使用下列 Concordance® 默认分隔符：逗号 ASCII 字符（020）；引号 þ ASCII 字符（254）。日期字段应按以下格式提供：mm/dd/yyyy。日期和时间字段必须为两个独立字段。如果文件包括已成像的电子邮件及附件，则必须包含附件字段，以保留电子邮件与其附件之间的父项/子项关系。必须包含 OCRPATH 字段，以提供所提供存储介质上提取文本文件的文件路径和名称。文本文件必须以 FIRSTBATES 命名。不得在 .DAT 文件中包括文本。对于含有原生文件的文件，必须包含 LINK 字段，以提供原生文件的文件路径和名称。原生文件必须以 FIRSTBATES 命名。\n\nb. Concordance Image® 或 Opticon 交叉引用文件。图像交叉引用文件（.LOG 或 .OPT）将图像链接至数据库记录。其应为逗号分隔文件，每行由七个字段构成，数据库中的每一幅图像均应在交叉引用文件中有一行，并采用以下格式：ImageID,VolumeLabel,ImageFilePath,DocumentBreak,FolderBreak,BoxBreak,PageCount。\n\nc. 文件文本。文本必须作为单独的文本文件提供，而非作为 .DAT 文件内的字段提供。文本文件的完整路径（OCRPATH）应包含在 .DAT 文件中。建议提供以 FIRSTBATES/Image Key 命名的文件级 ANSI 文本文件。提取的文本文件必须位于单独文件夹中，每个文件夹中的文本文件数量不应超过 1,000 个。文件夹名称中不得含有特殊字符（包括逗号）。文本文件必须按文件级别提供。\n\nd. 特定文件类型的原生格式提供。为充分理解其内容和含义而合理需要以原生格式查看的文件类型，必须以原生格式提供。这些文件包括但不限于电子表格、类似电子表格的文件（Microsoft Excel（微软 Excel）、逗号分隔值、制表符分隔值等）、Microsoft PowerPoint（微软 PowerPoint）或其他特殊演示文件、数据库文件以及音频/视频文件。应提供一份带有 Bates 编号的隔页图像，以表明原生文件的存在，并将原生文件的路径作为字段列入 .dat 文件。所提供的原生文件应以与该文件隔页对应的 Bates 编号命名。原生文件应归入按递增方式命名的“NATIVE”目录中，并与图像目录分开。\n\ne. 去重。对于存在完全重复件的每份电子文件，仅提供一份副本。对于电子邮件，应根据由 BCC、Body、CC、From、IntMsgID、To 和 Attach 属性生成的 MD5 哈希值合并重复件。对于电子邮件附件和独立电子文件，应根据整个文件的 MD5 哈希值合并重复件。\n\nf. 元数据。应以符合 Concordance 要求的加载文件（.dat）形式，为每份文件提供提取的元数据。.DAT 文件的第一行必须是标识字段名称的标题行。.DAT 文件必须使用下列 Concordance 默认分隔符：逗号 , ASCII 字符（020）；引号 þ ASCII 字符（254）。\n\n日期字段应按以下格式提供：mm/dd/yyyy。日期和时间字段必须为两个独立字段。以下为所需元数据：\n案件 22-50073 文档 1592 提交于 03/24/23 登记于 03/24/23 10:57:37 第 1012 页，共 1063 页\n\n字段名称　示例数据　说明\n\nFIRSTBATES　EDC0000001　原生文件/电子邮件文件的首个 Bates 编号\nLASTBATES　EDC0000001　原生文件/电子邮件文件的最后一个 Bates 编号\nLASTBATES 字段应针对单页文件填写。\nATTACHRANGE　EDC0000001 - EDC0000015　父文件首页的 Bates 编号至最后一个附件“子”文件最后一页的 Bates 编号\nBEGATTACH　EDC0000001　附件范围的首个 Bates 编号\nENDATTACH　EDC0000015　附件范围的最后一个 Bates 编号\nCUSTODIAN　Smith, John（史密斯，约翰）　电子邮件：电子邮件所在的邮箱。原生文件：该文件源自其文件的个人或部门名称\nFROM　John Smith（约翰·史密斯）　电子邮件：发件人。原生文件：文件作者。多个条目应以分号分隔\nTO　Coffman, Janice（科夫曼，贾尼斯）；LeeW（李W）[mailto:LeeW@MSN.com]　收件人。多个条目应以分号分隔\nCC　Frank Thompson（弗兰克·汤普森）[mailto:frank_Thompson@cdt.com]　抄送收件人。多个条目应以分号分隔\nBCC　John Cain（约翰·凯恩）　密送收件人。多个条目应以分号分隔\nSUBJECT　Board Meeting Minutes　电子邮件：电子邮件主题行。原生文件：文件标题（如有）\nFILE_NAME　BoardMeetingMinutes.docx　原生文件：原始原生文件的名称，包括扩展名\nDATE_SENT　10/12/2010　电子邮件：电子邮件发送日期。原生文件：（空）\nTIME_SENT/TIME_ZONE　07:05 PM GMT　电子邮件：电子邮件发送时间/电子邮件被标准化时所使用的时区\nTIME_ZONE　GMT　在转换期间电子邮件被标准化时所使用的时区。\nLINK　EDC0000001.msg　指向电子邮件或原生文件的超链接。所链接的文件必须按 FIRSTBATES 编号命名\nFILE_EXTEN　MSG　表示电子邮件或原生文件的文件类型扩展名\nAUTHOR　John Smith（约翰·史密斯）　电子邮件：（空）。原生文件：文件作者\nDATE_CREATED　10/10/2010　电子邮件：（空）。原生文件：文件创建日期\n案件 22-50073 文档 1592 提交于 03/24/23 登记于 03/24/23 10:57:37 第 1013 页，共 1063 页\n\nTIME_CREATED　10:25 AM　电子邮件：（空）。原生文件：文件创建时间。该数据必须为独立字段，不得与 DATE_CREATED 字段合并\nDATE_MOD　10/12/2010　电子邮件：（空）。原生文件：文件最后修改日期\nTIME_MOD　07:00 PM　电子邮件：（空）。原生文件：文件最后修改时间。该数据必须为独立字段，不得与 DATE_MOD 字段合并\nDATE_ACCESSD　10/12/2010　电子邮件：（空）。原生文件：文件最后访问日期\nTIME_ACCESSD　07:00 PM　电子邮件：（空）。原生文件：文件最后访问时间。该数据必须为独立字段，不得与 DATE_ACCESSD 字段合并\nFILE_SIZE　5,952　原生文件/电子邮件文件的大小，以 KB 计\nPGCOUNT　1　原生文件/电子邮件文件的页数\nPATH　Email: （空） Agenda.doc　原生文件：储存原生文件的路径，包括原始文件名。\nINTFILEPATH　Personal Folders\\Deleted Items\\Board Meeting Minutes.msg　电子邮件：电子邮件的原始位置，包括原始文件名。原生文件：（空）\nINTMSGID　<000805c2c71b\\$75977050\\$cb8306d1@MSN>　电子邮件：唯一消息 ID。原生文件：（空）\nMD5HASH　d131dd02c5e6eec4693d9a0698aff95c2fcab58712467eab4004583eb8fb7f89　文件的 MD5 哈希值。\nOCRPATH　TEXT/001/EDC0000001.txt　原生文件提取文本的路径\n\n3. 每项请求均独立适用并应独立解释，且除非另有说明，任何一项请求均不限制任何其他请求的范围。\n\n4. 所有文件应按其在通常业务过程中保存的方式提供，或者应予以组织和标记，以对应本请求中的类别。\n\n5. 本文所载每项请求延伸至所有文件：(a) 由贵方占有、保管或控制的文件；或 (b) 由代表贵方行事的任何人占有、保管或控制的文件，\n案件 22-50073 文档 1592 提交于 03/24/23 登记于 03/24/23 10:57:37 第 1014 页，共 1063 页\n\n包括贵方律师或其他代表和顾问。每份文件均应完整提供。\n\n6. 如要求您提交已不再由您占有、保管或控制的文件，则您的答复必须：(a) 详细说明该文件的性质及其内容；(b) 指明准备或撰写该文件的人员（以及，如适用，该文件发送给的人员）；(c) 指明该文件准备或创建的日期；(d) 说明该文件是否：(i) 遗失或丢失，(ii) 已被销毁，(iii) 已自愿或非自愿地转交给他人，或 (iv) 以其他方式处置；(e) 说明该等处置的理由及其相关事实和情形；(f) 指明授权该等处置的人员；(g) 指明该等处置的日期或大致日期；(h) 说明该文件最近一次由您占有、保管或控制的时间；以及 (i) 指明目前占有、保管或控制该文件的人员（如有）。\n\n7. 如要求您提交已被销毁的文件，则除前述指示所要求的信息外，您的答复还必须说明：(a) 销毁该文件的理由；(b) 销毁该文件的人员身份；以及 (c) 指示销毁该文件的人员身份。\n\n8. 如您主张被要求提交的文件享有特权或属于律师工作成果，则您的答复必须：(a) 说明：(i) 足以支持您关于该文件享有特权之主张的文件描述，(ii) 文件标题，(iii) 文件日期，(iv) 文件作者，(v) 文件收件人，(vi) 收到或阅览该文件原件或任何草稿、副本或复制件的每一人员身份，(vii) 该文件本身或文件中包含或提及的任何信息是否由任何其他人员占有、保管或控制；如是，则指明该等人员身份，并说明该信息如何进入其占有范围，(viii) 据以扣留该文件的特权主张，以及 (ix) 您将据以支持该等特权主张的全部情形；以及 (b) 对于依据特权主张而扣留的每一文件，依照 D. Conn. L. Civ. R. 26(e)，提交一份特权清单，其中载明本指示第 (a) 部分所要求的全部信息。\n\n案件 22-50073 文件 1592 提交于 03/24/23 录入于 03/24/23 10:57:37 第 1015 页，共 1063 页\n\n9. 如一份原本应予提交的文件的一部分包含受特权主张约束的信息，则仅应依照上述指示从该文件中删除或涂黑受特权主张约束的部分，其余部分应予提交。\n\n10. 该等请求具有持续性。现指示您：(a) 在得知先前答复不完整或不正确后，立即补充或更正任何后来得知不完整或不正确的答复；以及 (b) 提交根据下列规定所要求的任何其他文件。\n\n11. 如文件使用英语以外的语言，您应提供该文件。如文件使用英语以外的语言，且存在英文译本，您应同时提供两份文件。\n\n12. 对实体的所有提及均包括其所有关联方。\n\n13. 对个人姓名的所有提及均包括所有其他名称、别名或昵称。\n\n14. 除非另有明确说明，文件请求所涵盖的期间为自 February 5, 2012 起至文件请求答复到期之日止。\n\n案件 22-50073 文件 1592 提交于 03/24/23 录入于 03/24/23 10:57:37 第 1016 页，共 1063 页\n\n二、解释规则\n\n15. (a) 对任何单数名词的使用，应解释为包括复数，反之亦然；及 (b) 对任何时态动词的使用，应解释为在所有其他时态下对该动词的使用。\n\n16. (a) “and”和“or”应视需要解释为连词或析取词，以使任何请求的范围包括原本可能被解释为不在其范围内的所有答复；及 (b) “each”和“any”应视为包括并涵盖“every”和“all”两个词。\n\n三、定义\n\n经 D. Conn. Bankr. L.R. 2004-1(a) 纳入的 D. Conn. L. Civ. R. 26(c) 所规定的定义，以及 D. Conn. L. Civ. R. 26(d) 所规定的解释规则，适用于文件请求。此外，本文件请求中使用的下列术语具有下列含义：\n\n1. “You”或“Your”或“Yourself”系指 Oasis Tech Limited（绿洲科技有限公司），连同其所有关联方、部门、机构、职能机构、处室、办公室、合伙人、高级职员、董事、代理人、律师、代表、雇员，和/或代表其行事的任何人。\n\n2. “Debtor”系指 Ho Wan Kwok（郭文贵）（又名 Miles Kwok、Miles Guo、Guo Wengui、Guo Haoyun、郭文贵，或任何其他别名），连同其雇员、代理人、律师、顾问，或代表其行事的任何人。\n\n3. “Debtor's Son”系指 Qiang Guo（郭强）（又名 Mileson Kwok、郭强，或任何其他别名），连同其雇员、代理人、律师、顾问，或代表其行事的任何人。\n\n案件 22-50073 文件 1592 提交于 03/24/23 录入于 03/24/23 10:57:37 第 1017 页，共 1063 页\n\n4. “Debtor's Daughter”系指 Mei Guo（郭美）（又名 Mei Gui、郭美，或任何其他别名），连同其雇员、代理人、律师、顾问，或代表其行事的任何人。\n\n5. “Debtor's Purported Wife”系指 Hing Chi Ngok（岳庆芝）（又名 Hing Chi Ng、Yue Qingzhi、岳庆芝，或任何其他别名），连同其雇员、代理人、律师、顾问，或代表其行事的任何人。\n\n6. “Debtor's Family”统称债务人、债务人之子、债务人之女和债务人所谓的妻子，以及与债务人具有任何其他家庭关系的人。\n\n7. “Associated Individuals”单独及共同系指以下所有个人：(1) 持有、控制、保管或对债务人或债务人家属所拥有、控制或享有的资产具有酌处权；或 (2) 曾为一个或多个关联实体的雇员、董事，或以其他方式与其关联，连同前述各方各自的雇员、代理人、律师、顾问，或代表前述任何一方行事的任何人。该等关联个人包括但不限于：Daniel Podhaskie（丹尼尔·波达斯基）、Jason Miller（杰森·米勒）、Steve Bannon（史蒂夫·班农）、Karin Maistrello（卡琳·迈斯特雷洛）、Melissa Francis（梅利莎·弗朗西斯）、Anthony DiBattista（安东尼·迪巴蒂斯塔）、William Gertz（威廉·格茨）、Arethusa Forsyth（阿雷图萨·福赛思）、Glenn Mellor（格伦·梅勒）、Jennifer Mercurio（詹妮弗·默丘里奥）、Eduardo Eurnekian（爱德华多·尤尔内基安）、Wencong Wang（王文聪）、Han Chunguang（韩春光）（又名 韩春光）、Qu Guojiao（屈国姣）（又名 Qu Guo Jiao、屈国姣）、Guo Lijie（郭丽杰）（又名 郭丽杰）、Zhang Wei（张伟）（又名 张伟*）、Lihong Wei Lafrenz（魏丽红）（又名 Sara Wei、魏丽红）、Hao Haidong（郝海东）（又名 郝海东）、Ross Heinemeyer（罗斯·海内迈耶）、Max Krasner（马克斯·克拉斯纳）、Kyle Bass（凯尔·巴斯）、Melissa Mendez（梅利莎·门德斯）、Ya Li（李娅）（又名 李娅）、Dinggang Wang（王定刚）（又名 王定刚）、An Hong（安红）（又名 安红）、Yvette Wang（王雁平）（又名 Yanping Wang、Yan Ping Wang、王雁平）、Fiona Yu（菲奥娜·于）、Je Kin Ming（余建明）（又名 William Je、Yu Jianming、余建明）、Yaz Qingua（亚兹·钦瓜）以及 Lao Jiang（姜云浮）（又名 Jiang Yunfu、Jiang Yunfu Be、姜云浮）。\n\n案件 22-50073 文件 1592 提交于 03/24/23 录入于 03/24/23 10:57:37 第 1018 页，共 1063 页\n\n8. “Associated Entities”单独及共同系指以下所有各种类型的组织或实体：(1) 曾由债务人或债务人家属拥有、控制或投资；或 (2) 直接或间接地在债务人或债务人家属所拥有、控制或享有的任何资产中享有权益，连同前述各方各自的雇员、代理人、律师、顾问，或代表前述任何一方行事的任何人。该等关联实体包括但不限于：7 Nod Hill LLC、AAGV Limited、ACA Investment Management Limited、ACA Capital Group Limited、Ace Decade Holdings Limited、AI Group Holdings Inc.、Alfa Global Ventures Limited、Alfonso Global Limited、Allied Capital Global Limited、Alpine Fiduciaries SA、Anton Development Limited、Assets Sino Limited、Auspicious Coast Limited、Beijing Pangu Investment Co.、Beijing Pangu Investment Co. Ltd.、Beijing Pangu Investment Inc.、Beijing Zenith Holdings Company Limited、Booming Sail New York LLC、Bravo Luck Limited、BSA Strategic Fund I、China Golden Spring (Hong Kong) Limited、Chuang Xin Limited、Crane Advisory Group LLC、Creative Apex Investments Limited、Crystal Breeze Investments Limited、Dawn State Limited、Eastern Profit Corporation Limited、Elite Well Global Limited、Empire Growth Holdings、Freedom Media Ventures Ltd.、G Club Operations LLC、G Fashion LLC、G News LLC、GETTR USA、Genever Holdings Corporation、Genever Holdings LLC、Gfashion Media Group Inc.、GFNY, Inc.、Globalist International Limited、GNews Media Group Inc.、Golden Spring (New York) Ltd.、Greenwich Land LLC、Guo Media、GTV Media Group, Inc.、Hamilton Capital Holdings Inc.、HCHK Property Management, Inc.、HCHK Technologies, Inc.、Head Win Group Limited、Henan Yuda、Himalaya Embassy、Himalaya Exchange、Himalaya Federal Reserve、Himalaya Investment LLC、Himalaya International、Himalaya New World Inc.、Himalaya Supervisory Organization、Himalaya Ventures LLC、HK International Funds Investments (USA) Limited LLC、Hong Kong International Funds\n\n案件 22-50073 文件 1592 提交于 03/24/23 录入于 03/24/23 10:57:37 第 1019 页，共 1063 页\n\nInvestments Limited、Hudson Diamond Holding、Infinite Increase Limited、Infinitum Developments Limited、Infinity Treasury Management Inc.、Insight Phoenix Fund、Lamp Capital LLC、Leading Shine Limited、Leading Shine NY Limited、Lexington Property and Staffing、Long Gate Limited、Maywind Trading LLC、MOS Himalaya LLC、Next Tycoon Investments Limited、New Federal State of China（中国新联邦）（又名 NFSC）、Noble Fame Global Limited、Rosy Acme Ventures Limited、Rule of Law Foundation III, Inc.、Rule of Law Foundation IV, Inc.、Rule of Law Fund、Rule of Law Society、Rule of Law Society IV, Inc.、G-Translators PTY LTD、Saraca Media Group, Inc.、Shiny Ace Ltd.、Shiny Times Holdings Ltd.、Spirit Charter Investment Limited、Stevenson, Wong & Co.、Voice of Guo Media, Inc.、Well Origin Ltd.、World Century Limited、Worldwide Opportunity Holdings Limited、Whitecroft Shore Limited 以及 ZIBA Limited。\n\n9. “Including”或其任何变体，意为“包括但不限于”。\n\n10. “And”和“or”意为“and/or”，并应为最大限度扩大其范围而同时解释为连词和析取词。\n\n11. “Any”“all”和“each”意为“每一及所有”。\n\n12. “Each”和“every”意为“每一及所有”。\n\n13. “Third Party”系指您本人以外的个人或实体。\n\n14. “Transfer”具有《破产法》第 101(54) 条赋予该词的含义。\n\n15. “Document”系指属于 Fed. R. Civ. P. 34 范围内的任何信息或物品，包括但不限于由您占有、保管或控制的，或曾由您占有、保管或控制的各种、任何类型、性质或描述的每一书面、记录或图形材料，包括电子邮件的所有打印件和电子副本、存储于计算机中的计算机文件。\n\n电子形式、电子通信、短信、社交媒体帖子、推文、元数据、函件、备忘录、录音带、速记或手写笔记、任何种类的书面表格、图表、蓝图、绘图、草图、曲线图、计划、文章、规格说明、日记、信函、电报、照片、会议记录、合同、协议、调查、计算机打印件、任何种类的数据汇编、电传、电传传真、语音留言、发票、订购单、支票、汇票、对账单、贷项通知单、报告、立场报告、摘要、索引、书籍、账簿、笔记本、日程表、透明胶片、录音、目录、广告、宣传材料、电影、录像带、录音带、CD、计算机磁盘、宣传册、小册子、穿孔卡、工时单、Tweets、社交媒体帖子，或任何其他种类的书面或录制材料，以及其所有元数据，无论以何种方式存储（无论为有形形式或电子形式）、记录、制作或复制；还包括但不限于前述任何材料的草稿或副本，如其中含有原始文件中未载的任何种类的笔记、评论或标记，或在其他方面与原始文件不相同。\n\n16. “Person(s)”（“个人”）是指个人、公司、独资企业、合伙企业、协会或任何其他实体。“Person”（“个人”）还包括任何代理人、代表或专家，包括但不限于律师或财务顾问。\n\n17. “Entity”（“实体”）是指任何自然人、公司、合伙企业、子公司、独资企业、商号、董事会、合资企业、协会、机构、主管机关、委员会或其他商业实体或法人，以及任何关联方、代理人、母公司，包括但不限于法律顾问、财务顾问或任何其他代表。\n\n18. “Regarding”（“关于”）是指涉及、描述、构成、提及、与之相关、支持、赞成、反对、加强、削弱、位于、在关联中考虑、对其有影响、证明、表明、报告、记录、暗指、回应、\n\n案件 22-50073 文件 1592 于 03/24/23 提交 于 03/24/23 10:57:37 登记 第 1021 页，共 1063 页\n\n与之关联、对其评论、就其而言、关于、与之有关、讨论、显示、描述、反映、分析、构成及属于。\n\n19. 当提及任何特定事项时，“Relating to”（“与……有关”）、“relate(s) to”（“与……有关”）或“related to”（“与……相关”）是指，包括但不限于，构成、包含、涉及、载有、体现、反映、识别、陈述、直接或间接提及，或以任何方式与所识别的特定事项相关的任何文件。\n\n20. “Communication(s)”（“通信”）在最广泛可能的意义上且不受限制地，是指任何信息或知识的传递（以事实、观点、询问或其他形式）。Communication(s)还指所有谈话、协议、询问或答复，无论是当面、通过电话、书面方式或通过电子传输设备进行，并包括但不限于所有函件、电子邮件、录音、传送单、备忘录、电话通信、语音留言、电报、电传传真、复印传真、电传、即时消息、聊天、短信、电话笔记，或与内部人员或第三方传送的笔记。\n\n21. “Asset(s)”（“资产”）是指任何可用于产生正向经济价值的项目，包括但不限于由实体拥有、控制或为实体利益而持有，并预期提供未来利益的任何具有经济价值的资源，包括但不限于所有不动产和动产、无形财产、投资、投资权或未来收入权、现金、银行账户、商品、证券、债权、对实体的全部或部分控制权，以及预期经济机会。\n\n22. “Transfer”（“转让”）应具有《破产法典》第 101(54) 条赋予该词的含义。\n\n案件 22-50073 文件 1592 于 03/24/23 提交 于 03/24/23 10:57:37 登记 第 1022 页，共 1063 页\n\nIV. 应提交的文件\n\n1. 关于债务人、债务人财产或关联实体任何收入或资产的所有文件。\n\n2. 与债务人的财务状况及其对债权人所负义务有关的所有文件，包括但不限于与任何试图避免支付该等义务有关的所有文件，以及与本次或任何其他实际或潜在破产或类似资不抵债程序有关的所有文件。\n\n3. 关于与债务人、债务人财产、债务人家庭成员、关联实体或关联个人有关的任何资产负债表、银行对账单、账户对账单、财务报表、账目报表、电汇指示和/或确认、资金证明、存款证、持仓证明、投资组合摘要或类似文件的所有文件，包括但不限于足以显示向前述任何一方作出的所有转让的所有文件。\n\n4. 关于债务人作出、与债务人进行或代表债务人作出的任何投资、商业交易或交易的所有文件。\n\n5. 与债务人的所有通信，以及与债务人的通信有关、涉及任何实体（包括但不限于关联实体）运营、管理或决策的文件。\n\n6. 关于向债务人、由债务人或与债务人、债务人家庭成员或关联实体进行的任何转让、投资、其他交易或商业交易的所有文件。\n\n7. 关于债务人曾占用或使用的任何财产的所有文件，包括但不限于 Lady May；Sherry Netherland Hotel / Condominium；位于康涅狄格州格林威治 373 Taconic Rd. 的住宅物业；位于康涅狄格州格林威治 33 Ferncliff Rd. 的住宅物业；以及位于康涅狄格州威尔顿 354 Nod Hill Rd. 的住宅物业。\n\n案件 22-50073 文件 1592 于 03/24/23 提交 于 03/24/23 10:57:37 登记 第 1023 页，共 1063 页\n\n8. 与债务人拥有、控制或使用的任何飞机有关的所有文件，包括但不限于尾号为 T7-GQM 的飞机及在圣马力诺注册的任何其他飞机，包括但不限于所有登记文件副本以及显示该等飞机所执行航班和该等航班机上人员的飞行清单。\n\n9. 关于向债务人、债务人财产、债务人家庭成员或关联实体提供、由其提供或代表其提供的任何赠与、利益或贷款的所有文件，包括但不限于足以显示该等赠与、利益或贷款金额；该等赠与、利益或贷款的用途；提供该等赠与、利益或贷款的时间；以及任何贷款的条款、就任何贷款作出的所有陈述与保证、任何贷款的利率及任何贷款付款的所有证据的文件。\n\n10. 关于由债务人、债务人财产、债务人家庭成员或关联实体设立、代表其设立或为其利益设立的任何信托或类似文书的所有文件，包括但不限于足以显示该等信托何时设立、由谁设立、为谁的利益设立及信托本金的文件。\n\n11. 与涉及债务人的任何法律争议有关的任何义务、债权、责任或债务有关的所有文件，包括但不限于与在任何地方、州、联邦或国际机构前进行的任何诉讼有关的文件，无论该机构为行政机关、法院、合议庭或替代性争议解决实体。\n\n案件 22-50073 文件 1592 于 03/24/23 提交 于 03/24/23 10:57:37 登记 第 1024 页，共 1063 页\n\n12. 您的任何外部法律顾问或其他顾问与债务人之间的所有文件和通信。\n\n13. 足以显示您的全部资产以及收入或资金来源的文件。\n\n14. 对于就第 14 项请求所识别的、价值超过 $50,000 的全部资产，提供：(i) 与您取得该等资产有关的所有文件；及 (ii) 与债务人或债务人家庭成员就该等资产进行的通信。\n\n15. 您的纳税申报表副本。\n\n16. 足以显示由您占有或控制的所有银行账户和投资账户的文件，包括每一该等账户的余额及向其转入和自其转出的款项。\n\n17. 关于您使用的任何信用卡的所有文件，包括但不限于月度对账单或足以显示为债务人或关联实体利益而进行的与之相关的所有购买的其他文件。\n\n18. 所有公司治理及组织文件，包括但不限于章程细则、公司注册证书以及足以显示您的公司结构、高级管理人员和董事姓名、经营目的，以及与债务人或债务人任何家庭成员关系的其他文件。\n\n19. 与向任何其他实体质押您的资产有关的所有文件。\n\n案件 22-50073 文件 1592 于 03/24/23 提交 于 03/24/23 10:57:37 登记 第 1025 页，共 1063 页\n\n附件 C-56\n\nB2540（表格 2540——《规则 2004 审查传票》）（12/15）案件 22-50073 文件 1592 于 03/24/23 提交 于 03/24/23 10:57:37 登记 第 1026 页，共\n\n美国破产法院 1063\n\n康涅狄格地区\n\n关于 HO WAN KWOK（郭文贵）等人，\n\n1 案件编号 22-50073 (JAM)\n\n债务人 第 11 章\n\n（合并管理）\n规则 2004 审查传票\n\n致：Joyord Sportswear Limited\n\n（传票所指向人员的姓名）\n\n证言：兹命令您于下列载明的时间、日期和地点出席，并根据《联邦破产程序规则》第 2004 条接受审查并作证。随附准许该审查的法院命令副本。\n\n地点　日期和时间\n\nPaul Hastings LLP\n200 Park Avenue　[TBD]\nNew York, New York 10166\n\n审查将以下列方式记录：法庭记录员/速记员\n\n提交：您或您的代表还必须将下列文件、电子存储信息或物品带至审查现场，并必须准许对该等材料进行检查、复制、测试或取样：\n见随附的文件提交请求。\n\n下列《联邦民事诉讼规则》第 45 条规定，依据《联邦破产程序规则》第 9016 条适用于破产案件，随附于后——第 45(c) 条，关于履行地点；第 45(d) 条，关于您作为受传票约束人员所受的保护；以及第 45(e) 条和第 45(g) 条，关于您对本传票的答复义务及不答复可能产生的后果。\n\n日期：March , 2023\n\n法院书记员\n\n或\n\n书记员或副书记员签名　律师签名\n\n签发或请求本传票、代表第 11 章受托人 Luc A. Despins（卢克·A·德斯平斯）的律师姓名、地址、电子邮件地址和电话号码如下：\n\nDouglas S. Skalka, Esq.（道格拉斯·S·斯卡尔卡，律师）；Neubert, Pepe & Monteith, P.C.；195 Church Street, New Haven, Connecticut 06510；dskalka@npmlaw.com；(203) 821-2000\n\n致签发或请求本传票者的通知\n\n如本传票要求在审判前提交文件、电子存储信息或有形物品，或检查场所，则必须在向传票所指向人员送达之前，向每一当事人送达通知及本传票副本。Fed. R. Civ. P. 45(a)(4)。\n\n软件版权 (c) 1996-2022 Best Case, LLC - www.bestcase.com Best Case Bankruptcy 1 本第 11 章案件的债务人为 Ho Wan Kwok（郭文贵）（又名 Guo Wengui、Miles Guo 和 Miles Kwok，以及其他众多别名）（纳税人识别号码后四位：9595）、Genever Holdings LLC（纳税人识别号码后四位：8202）及 Genever Holdings Corporation。受托人、Genever Holdings LLC 和 Genever Holdings Corporation 的邮寄地址为 Paul Hastings LLP, 200 Park Avenue, New York, NY 10166，转交 Ho Wan Kwok 财产受托人 Luc A. Despins（仅为通知和通信之目的）。\n\n送达证明\n\n（除非 Fed. R. Civ. P. 45 要求，否则本节不应向法院提交。）\n\n本人于（日期）收到针对（个人姓名及职务，如有）的本传票：\n\n本人通过按下列方式向具名人员交付副本而送达本传票：\n\n于（日期）；或\n\n本人因下列原因未执行送达而退回本传票：\n\n除非本传票代表 United States（美国）或其官员或代理人签发，本人亦已向证人支付一日出庭费用及法律允许的里程费，金额为 $ 。\n\n本人的差旅费用为 $ ，服务费用为 $ ，合计为 $ 。\n\n本人在伪证处罚的惩罚下声明，本信息真实且准确无误。\n\n日期：\n\n送达人签名\n\n正楷姓名及职务\n\n送达人地址\n\n关于尝试送达等事项的补充信息：\n《联邦民事诉讼规则》45(c)、(d)、(e) 及 (g)（自 12/1/13 起生效）（经《联邦破产程序规则》Rule 9016 适用于破产案件）\n(c) 履行地点。\n\n(1) 审判、听证或宣誓证言。传票仅可按下列方式命令某人出席审判、听证或宣誓证言：\n\n(A) 在该人居住、受雇或经常亲自进行营业活动地点的 100 英里范围内；或\n\n(B) 在该人居住、受雇或经常亲自进行营业活动所在州内，条件是该人\n\n(i) 是当事人或当事人的高级职员；或\n\n(ii) 被命令出席审判且不会产生重大费用。\n\n(2) 其他证据开示。传票可命令：\n\n(A) 在该人居住、受雇或经常亲自进行营业活动地点的 100 英里范围内某一地点提交文件、电子存储信息或物品；以及\n\n(B) 在待检查的场所检查场所。\n(d) 保护受传票约束的人；执行。\n\n(1) 避免不当负担或费用；制裁。负责签发和送达传票的当事人或律师必须采取合理措施，避免对受传票约束的人施加不当负担或费用。要求履行义务所在地区的法院必须执行该义务，并对未遵守该义务的当事人或律师施加适当制裁，其中可包括损失的收入及合理的律师费。\n\n(2) 命令提交材料或准许检查。\n\n(A) 无须出席。被命令提交文件、电子存储信息或有形物品，或准许检查场所的人，无须亲自到提交或检查地点出席，除非亦被命令出席宣誓证言、听证或审判。\n\n(B) 异议。被命令提交文件或有形物品，或准许检查的人，可以向传票中指定的当事人或律师送达书面异议，反对检查、复制、测试或抽样任何或全部材料，或反对检查场所，或反对以所要求的一种或多种形式提交电子存储信息。异议必须在规定履行时间届满前或传票送达后 14 日内（以较早者为准）送达。如提出异议，适用下列规则：\n\n(i) 在任何时候，送达方可通知被命令者后，向要求履行义务所在地区的法院提出动议，请求作出强制提交或检查的命令。\n\n(ii) 仅可依命令的指示要求实施该等行为，且该命令必须保护并非当事人或当事人高级职员的人免受因履行义务而产生的重大费用。\n\n(3) 撤销或修改传票。\n\n(A) 必须撤销或修改的情形。经及时动议，要求履行义务所在地区的法院必须撤销或修改具有下列情形的传票：\n\n(i) 未给予合理的履行时间；\n\n(ii) 要求某人在 Rule 45(c) 规定的地理范围之外履行义务；\n\n(iii) 要求披露享有特权或受其他保护的事项，且不适用任何例外或豁免；或\n\n(iv) 对某人造成不当负担。\n\n(B) 可以撤销或修改的情形。为保护受传票约束或受其影响的人，要求履行义务所在地区的法院可以经动议撤销或修改要求下列事项的传票：\n\n(i) 披露商业秘密或其他保密的研究、开发或商业信息；或\n\n(ii) 披露未受聘专家的意见或信息，该等意见或信息并非描述争议中的具体事件，且系该专家未经任何当事人请求所作研究的结果。\n\n(C) 以规定条件作为替代。在 Rule 45(d)(3)(B) 所述情形下，如送达方：\n\n(i) 证明其对该证言或材料具有重大需要，且若无不当困难即无法以其他方式满足该需要；并且\n\n(ii) 确保被传唤之人将获得合理补偿，\n\n法院可以不撤销或修改传票，而命令在规定条件下出席或提交。\n(e) 回应传票的义务。\n\n(1) 提交文件或电子存储信息。下列程序适用于提交文件或电子存储信息：\n\n(A) 文件。回应提交文件传票的人必须按照文件在正常营业过程中保存的方式提交，或者必须将文件整理并标注，使其与请求中的类别相对应。\n\n(B) 未规定电子存储信息的提交形式。如传票未规定电子存储信息的提交形式，回应者必须以其通常保存的一种或多种形式，或以合理可用的一种或多种形式提交。\n\n(C) 电子存储信息仅以一种形式提交。回应者无须以一种以上形式提交相同的电子存储信息。\n\n(D) 无法合理访问的电子存储信息。回应者无须就其认定因不当负担或成本而无法合理访问的来源中的电子存储信息提供证据开示。对于强制证据开示动议或保护令动议，回应者必须证明该信息因不当负担或成本而无法合理访问。如作出该证明，法院仍可在请求方证明具有正当理由时，考虑 Rule 26(b)(2)(C) 的限制，命令从该等来源进行证据开示。法院可以对该证据开示规定条件。\n\n(2) 主张特权或保护。\n\n(A) 被保留的信息。以该等信息享有特权或作为审判准备材料受到保护为由保留被传唤信息的人必须：(i) 明确提出该主张；以及\n\n(ii) 以一种不披露本身享有特权或受保护信息的方式，说明被保留文件、通信或有形物品的性质，从而使当事人能够评估该主张。\n\n(B) 已提交的信息。如为回应传票而提交的信息受到特权主张或作为审判准备材料的保护主张约束，提出该主张的人可以将该主张及其依据通知任何收到该信息的当事人。收到通知后，当事人必须立即返还、隔离或销毁所指定的信息及其持有的任何副本；在该主张得到解决前不得使用或披露该信息；如该当事人在收到通知前已披露该信息，必须采取合理措施追回该信息；并可以立即将该信息密封提交至要求履行义务所在地区的法院，以裁定该主张。提交该信息的人必须在该主张得到解决前保存该信息。\n\n(g) 藐视法庭。要求履行义务所在地区的法院，以及在动议被移送后签发传票的法院，可以认定已被送达但无充分理由不遵守传票或相关命令的人构成藐视法庭。\n\n有关获取传票材料的信息，见 Fed.R.Civ.P.45(a) Committee Note (2013)\n\n……\n\n文件提交请求\n一、指示\n\n1. 除非另有说明，下列文件请求（“请求”，每一项称为“一项请求”）必须分别且具体地作出回应。除非基于善意提出异议，否则必须完整回答每一项请求；如提出异议，则必须按照下文规定详细说明阁下异议的理由。如异议仅涉及一项请求的一部分，或其中所载的一个词语、短语或条款，阁下仅须说明对该部分的异议，并对请求的其余部分作出回应。\n\n2. 电子存储信息必须依照下列指示提交：\n\na. 图像。黑白图像必须为 300 DPI Group IV 单页 TIFF 文件。彩色图像必须以 JPEG 格式提交。文件名不得包含嵌入空格或特殊字符（包括逗号）。文件夹名称不得包含嵌入空格或特殊字符（包括逗号）。所有 TIFF 图像文件必须具有唯一文件名，即 Bates 编号。图像必须在每幅图像的右下角标注连续的 Bates 编号。每个文件夹中的 TIFF 文件数量不得超过 1000 个文件。Excel 电子表格应具有一个以该文件 Bates 编号命名的占位图像。\n\nb. 图像加载文件\n\na. Concordance® 数据文件。数据文件（.DAT）包含将加载至 Concordance® 数据库的所有字段信息。.DAT 文件的第一行必须为标明字段名称的标题行。.DAT 文件必须使用以下 Concordance® 默认分隔符：逗号 ASCII 字符（020）引号 þ ASCII 字符（254）。日期字段应采用以下格式提供：mm/dd/yyyy。日期和时间字段必须为两个独立字段。如文件包括已成像的电子邮件及附件，则必须包括附件字段，以保留电子邮件与其附件之间的父项/子项关系。必须包括 OCRPATH 字段，以提供所提交存储介质上提取文本文件的文件路径及名称。文本文件必须以 FIRSTBATES 命名。不得在 .DAT 文件中包含文本。对于具有原生文件的文件，必须包括 LINK 字段，以提供原生文件的文件路径及名称。原生文件必须以 FIRSTBATES 命名。\n\n- b. Concordance Image® 或 Opticon 交叉引用文件。图像交叉引用文件（.LOG 或 .OPT）将图像与数据库记录关联。该文件应为逗号分隔文件，每行包含七个字段，并且数据库中的每一幅图像均应在交叉引用文件中对应一行，格式如下：ImageID,VolumeLabel,ImageFilePath,DocumentBreak,FolderBreak,BoxBreak,PageCount。\n\n- c. 文件文本。文本必须作为单独的文本文件提供，不得作为 .DAT 文件内的字段提供。文本文件的完整路径（OCRPATH）应载入 .DAT 文件。建议提供以 FIRSTBATES/Image Key 命名的文件级 ANSI 文本文件。提取的文本文件必须置于单独文件夹中，且每个文件夹中的文本文件数量不得超过 1,000 个。文件夹名称中不得包含特殊字符（包括逗号）。文本文件必须按文件级别提供。\n\n- d. 特定文件类型的原生格式提供。为充分理解其内容和含义而合理需要以原生格式查看的文件类型，必须以原生格式提供。该等文件包括但不限于：电子表格、类似电子表格的文件（Microsoft Excel、逗号分隔值、制表符分隔值等）、Microsoft PowerPoint 或其他特殊演示文件、数据库文件以及音频/视频文件。应提供一份带有 Bates 编号的提示页图像，以表明存在原生文件，并将原生文件的路径作为 .dat 文件中的一个字段载入。所提供的原生文件应以与该文件提示页相对应的 Bates 编号命名。原生文件应归入按递增方式命名的 “NATIVE” 目录中，并与图像目录分开。\n\n- e. 去重。对于存在完全重复件的每份电子文件，仅提供一份副本。对于电子邮件，应依据从 BCC、Body、CC、From、IntMsgID、To 和 Attach 属性生成的 MD5 哈希值合并重复件。对于电子邮件附件和独立电子文件，应依据整个文件的 MD5 哈希值合并重复件。\n\n- f. 元数据。应以符合 Concordance 格式的载入文件（.dat）形式，为每份文件提供提取的元数据。.DAT 文件的第一行必须为标明字段名称的标题行。.DAT 文件必须使用以下 Concordance 默认分隔符：逗号 , ASCII 字符（020）引号 þ ASCII 字符（254）\n\n日期字段应按以下格式提供：mm/dd/yyyy。日期和时间字段必须为两个独立字段。以下为必需元数据：\nCase 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 1031 of 1063\n\n字段名称　示例数据　说明\n\nFIRSTBATES　EDC0000001　原生文件文件/电子邮件的第一个 Bates 编号\nLASTBATES　EDC0000001　原生文件文件/电子邮件的最后一个 Bates 编号\n**对于单页文件，亦应填写 LASTBATES 字段\n\nATTACHRANGE　EDC0000001\n-　母文件第一页的 Bates 编号至\nEDC0000015　最后一个附件“子”文件最后一页的 Bates 编号\nBEGATTACH　EDC0000001　附件范围的第一个 Bates 编号\nENDATTACH　EDC0000015　附件范围的最后一个 Bates 编号\nCUSTODIAN　Smith, John　电子邮件：电子邮件所在的邮箱\n原生文件：文件来源的个人或部门名称\nFROM　John Smith　电子邮件：发件人\n原生文件：文件作者\n**多项条目之间应使用分号分隔\nTO　Coffman, Janice; LeeW　收件人\n[mailto:LeeW@MSN.com]　**多项条目之间应使用分号分隔\nCC　Frank Thompson [mailto:　抄送收件人\nfrank_Thompson@cdt.com]　**多项条目之间应使用分号分隔\nBCC　John Cain　密送收件人\n**多项条目之间应使用分号分隔\nSUBJECT　Board Meeting Minutes　电子邮件：电子邮件主题行 原生文件：文件标题（如有）\nFILE_NAME　BoardMeetingMinutes.docx　原生文件：原始原生文件名称，包括扩展名\nDATE_SENT　10/12/2010　电子邮件：电子邮件发送日期\n原生文件：（空）\nTIME_SENT/\nTIME_ZONE　07:05 PM GMT　电子邮件：电子邮件发送时间/电子邮件标准化所在时区\nTIME_ZONE　GMT　在转换过程中对电子邮件进行标准化所使用的时区。\nLINK　>EDC0000001.msg　电子邮件或原生文件文件的超链接\n**链接文件必须以 FIRSTBATES 编号命名\nFILE_EXTEN　MSG　表示电子邮件或原生文件的文件类型扩展名\nAUTHOR　John Smith　电子邮件：（空）\n原生文件：文件作者\nDATE_CREATED　10/10/2010　电子邮件：（空）\n原生文件：文件创建日期\n\nCase 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 1032 of 1063\n\nTIME_CREATED　10:25 AM　电子邮件：（空）\n原生文件：文件创建时间\n**该数据必须为独立字段，不得与 DATE_CREATED 字段合并\nDATE_MOD　10/12/2010　电子邮件：（空）\n原生文件：文件最后修改日期\nTIME_MOD　07:00 PM　电子邮件：（空）\n原生文件：文件最后修改时间\n**该数据必须为独立字段，不得与 DATE_MOD 字段合并\nDATE_ACCESSD　10/12/2010　电子邮件：（空）\n原生文件：文件最后访问日期\nTIME_ACCESSD　07:00 PM　电子邮件：（空）\n原生文件：文件最后访问时间\n**该数据必须为独立字段，不得与 DATE_ACCESSD 字段合并\nFILE_SIZE　5,952　原生文件文件/电子邮件的大小，以 KB 计\nPGCOUNT　1　原生文件文件/电子邮件的页数\nPATH　电子邮件：（空）\nAgenda.doc　原生文件：原生文件文件的存储路径，包括原始文件名。\nINTFILEPATH　Personal Folders\\Deleted　电子邮件：电子邮件的原始位置，包括原始文件名。\nItems\\Board Meeting\nMinutes.msg　原生文件：（空）\nINTMSGID　<000805c2c71b\\$75977050\\$　电子邮件：唯一消息 ID 原生文件：（空）\ncb8306d1@MSN>\nMD5HASH　d131dd02c5e6eec4693d9a0　文件的 MD5 哈希值。\n698aff95c\n2fcab58712467eab4004583e\nb8fb7f89\nOCRPATH　TEXT/001/EDC0000001.txt　原生文件提取文本的路径\n\n3. 每项请求均独立运作并应独立解释，且除非另有说明，任何请求均不限制任何其他请求的范围。\n\n4. 所有文件均应按照通常业务过程中保存的方式提供，或应进行组织和标记，以对应于本请求中的类别。\n\n5. 本文件所载每项请求均延及下列所有文件：(a) 由贵方占有、保管或控制的文件；或 (b) 由任何代表贵方行事之人占有、保管或控制的文件，\nCase 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 1033 of 1063\n\n包括贵方律师或其他代表及顾问。每份文件均应完整提供。\n\n6. 如要求贵方提供已不再由贵方占有、保管或控制的文件，则贵方的答复必须：(a) 详细描述该文件的性质及其内容；(b) 确认编制或撰写该文件的人员（及，如适用，文件发送对象）；(c) 确认该文件编制或创建的日期；(d) 说明该文件是否：(i) 遗失或丢失，(ii) 已被销毁，(iii) 自愿或非自愿转移给他人，或 (iv) 以其他方式处置；(e) 说明该等处置的原因，以及围绕该等处置的事实和情形；(f) 确认授权该等处置的人员；(g) 确认该等处置的日期或大致日期；(h) 说明该文件最近一次由贵方占有、保管或控制的时间；以及 (i) 确认目前占有、保管或控制该文件的人员（如有）。\n\n7. 如要求贵方提供已被销毁的文件，则除前项指示要求的信息外，贵方的答复还必须说明：(a) 该文件被销毁的原因；(b) 销毁该文件的人员身份；以及 (c) 指示销毁该文件的人员身份。\n\n8. 如贵方主张所请求文件享有特权或属于律师工作成果，则贵方的答复必须：(a) 说明：(i) 足以支持贵方关于该文件享有特权之主张的文件描述，(ii) 文件标题，(iii) 文件日期，(iv) 文件作者，(v) 文件收件人，(vi) 收到或阅览该文件原件或任何草稿、副本或复制件的每一人员身份，(vii) 该文件本身或其中包含或提及的任何信息是否由任何其他人员占有、保管或控制；如是，该等人员身份，以及说明该等人员如何取得该信息的陈述，(viii) 据以拒绝提供该文件的特权主张，以及 (ix) 贵方将据以支持该特权主张的所有情形；并且 (b) 就每份基于特权主张而拒绝提供的文件，依照 D. Conn. L. Civ. R. 26(e) 提供一份特权日志，其中包含本指示第 (a) 部分所要求的全部信息。\n\n9. 如一份原本应答的文件中有部分内容包含受特权主张约束的信息，则仅应按照上述指示从该文件中删除或遮盖受特权主张约束的部分，其余部分应予提供。\n\n10. 本请求具有持续性。现指示贵方：(a) 一旦得知先前答复不完整或不正确，应立即补充或更正任何后来发现不完整或不正确的答复；以及 (b) 提供根据下列规定所要求的任何补充文件\n\n11. 如文件使用英语以外的语言，贵方应提供该文件。如文件使用英语以外的语言且存在英文译本，贵方应同时提供两份文件。\n\n12. 对实体的一切提及均包括其所有关联方。\n\n13. 对个人姓名的一切提及均包括所有其他名称、别名或昵称。\n\n14. 除非另有明确说明，文件请求所涵盖的期间为自 February 5, 2012 起至文件请求答复到期之日止。\nCase 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 1035 of 1063\n\nII. 解释规则\n\n15. (a) 任何单数名词的使用均应解释为包括复数，反之亦然；以及 (b) 任何时态动词的使用均应解释为在所有其他时态中使用该动词。\n\n16. (a) “and” 和 “or” 应在必要时解释为连词或选择连词，以使本可被解释为超出任何请求范围的所有答复均纳入该请求范围；以及 (b) “each” 和 “any” 应视为包括并涵盖 “every” 和 “all” 一词。\nIII. 定义\n\n根据 D. Conn. Bankr. L.R. 2004-1(a) 纳入的 D. Conn. L. Civ. R. 26(c) 所规定的定义，以及 D. Conn. L. Civ. R. 26(d) 所规定的解释规则，适用于文件请求。此外，本文件请求中使用的下列术语具有以下含义：\n\n1. “You” 或 “Your” 或 “Yourself” 是指 Joyord Sportswear Limited，以及其所有关联方、部门、机构、工具机构、职能部门、办事处、合伙人、高级职员、董事、代理人、律师、代表、雇员和/或任何代表其行事之人。\n\n2. “Debtor” 是指 Ho Wan Kwok（又名 Miles Kwok、Miles Guo、Guo Wengui、Guo Haoyun、郭文贵或任何其他别名），以及其雇员、代理人、律师、顾问或任何代表其行事之人。\n\n3. “债务人之子”是指 Qiang Guo（郭强，亦称 Mileson Kwok，或任何其他别名），以及其雇员、代理人、律师、顾问或任何代表其行事之人。\n案件 22-50073 文件 1592 提交日期 03/24/23 录入日期 03/24/23 10:57:37 第 1036 页，共 1063 页\n\n4. “债务人之女”是指 Mei Guo（郭美，亦称 Mei Gui，或任何其他别名），以及其雇员、代理人、律师、顾问或任何代表其行事之人。\n\n5. “债务人声称的妻子”是指 Hing Chi Ngok（岳庆芝，亦称 Hing Chi Ng、Yue Qingzhi，或任何其他别名），以及其雇员、代理人、律师、顾问或任何代表其行事之人。\n\n6. “债务人家庭成员”统称债务人、债务人之子、债务人之女及债务人声称的妻子，以及与债务人有任何其他亲属关系之人。\n\n7. “关联个人”单独或合称指下列所有个人：(1) 持有、控制、保管或对债务人或债务人家庭成员所拥有、控制或享有的资产具有处置权；或 (2) 曾为一个或多个关联实体的雇员、董事，或以其他方式与之有关联；以及前述任何一方各自的雇员、代理人、律师、顾问或任何代表其行事之人。该等关联个人包括但不限于：Daniel Podhaskie、Jason Miller、Steve Bannon、Karin Maistrello、Melissa Francis、Anthony DiBattista、William Gertz、Arethusa Forsyth、Glenn Mellor、Jennifer Mercurio、Eduardo Eurnekian、Wencong Wang、Han Chunguang（韩春光）、Qu Guojiao（屈国姣，亦称 Qu Guo Jiao）、Guo Lijie（郭丽杰）、Zhang Wei（张伟*）、Lihong Wei Lafrenz（魏丽红，亦称 Sara Wei）、Hao Haidong（郝海东）、Ross Heinemeyer、Max Krasner、Kyle Bass、Melissa Mendez、Ya Li（李娅）、Dinggang Wang（王定刚）、An Hong（安红）、Yvette Wang（王雁平，亦称 Yanping Wang、Yan Ping Wang）、Fiona Yu、Je Kin Ming（余建明，亦称 William Je、Yu Jianming）、Yaz Qingua，以及 Lao Jiang（姜云浮，亦称 Jiang Yunfu、Jiang Yunfu Be）。\n案件 22-50073 文件 1592 提交日期 03/24/23 录入日期 03/24/23 10:57:37 第 1037 页，共 1063 页\n\n8. “关联实体”单独或合称指下列所有类型的组织或实体：(1) 曾由债务人或债务人家庭成员拥有、控制或投资；或 (2) 对债务人或债务人家庭成员所拥有、控制或享有的任何资产直接或间接享有权益；以及前述任何一方各自的雇员、代理人、律师、顾问或任何代表其行事之人。该等关联实体包括但不限于：7 Nod Hill LLC、AAGV Limited、ACA Investment Management Limited、ACA Capital Group Limited、Ace Decade Holdings Limited、AI Group Holdings Inc.、Alfa Global Ventures Limited、Alfonso Global Limited、Allied Capital Global Limited、Alpine Fiduciaries SA、Anton Development Limited、Assets Sino Limited、Auspicious Coast Limited、Beijing Pangu Investment Co.、Beijing Pangu Investment Co. Ltd.、Beijing Pangu Investment Inc.、Beijing Zenith Holdings Company Limited、Booming Sail New York LLC、Bravo Luck Limited、BSA Strategic Fund I、China Golden Spring (Hong Kong) Limited、Chuang Xin Limited、Crane Advisory Group LLC、Creative Apex Investments Limited、Crystal Breeze Investments Limited、Dawn State Limited、Eastern Profit Corporation Limited、Elite Well Global Limited、Empire Growth Holdings、Freedom Media Ventures Ltd.、G Club Operations LLC、G Fashion LLC、G News LLC、GETTR USA、Genever Holdings Corporation、Genever Holdings LLC、Gfashion Media Group Inc.、GFNY, Inc.、Globalist International Limited、GNews Media Group Inc.、Golden Spring (New York) Ltd.、Greenwich Land LLC、Guo Media、GTV Media Group, Inc.、Hamilton Capital Holdings Inc.、HCHK Property Management, Inc.、HCHK Technologies, Inc.、Head Win Group Limited、Henan Yuda、Himalaya Embassy、Himalaya Exchange、Himalaya Federal Reserve、Himalaya Investment LLC、Himalaya International、Himalaya New World Inc.、Himalaya Supervisory Organization、Himalaya Ventures LLC、HK International Funds Investments (USA) Limited LLC、Hong Kong International Funds\n案件 22-50073 文件 1592 提交日期 03/24/23 录入日期 03/24/23 10:57:37 第 1038 页，共 1063 页\n\nInvestments Limited、Hudson Diamond Holding、Infinite Increase Limited、Infinitum Developments Limited、Infinity Treasury Management Inc.、Insight Phoenix Fund、Lamp Capital LLC、Leading Shine Limited、Leading Shine NY Limited、Lexington Property and Staffing、Long Gate Limited、Maywind Trading LLC、MOS Himalaya LLC、Next Tycoon Investments Limited、New Federal State of China（亦称 NFSC）、Noble Fame Global Limited、Rosy Acme Ventures Limited、Rule of Law Foundation III, Inc.、Rule of Law Foundation IV, Inc.、Rule of Law Fund、Rule of Law Society、Rule of Law Society IV, Inc.、G-Translators PTY LTD、Saraca Media Group, Inc.、Shiny Ace Ltd.、Shiny Times Holdings Ltd.、Spirit Charter Investment Limited、Stevenson, Wong & Co.、Voice of Guo Media, Inc.、Well Origin Ltd.、World Century Limited、Worldwide Opportunity Holdings Limited、Whitecroft Shore Limited，以及 ZIBA Limited。\n\n9. “包括”或其任何变体，是指“包括但不限于”。\n\n10. “和”及“或”是指“和/或”，并应同时作连词及析取词解释，以最大限度扩大其范围。\n\n11. “任何”及“所有”以及“每一”是指“每一个和全部”。\n\n12. “每一”及“每个”是指“每一个和全部”。\n\n13. “第三方”是指除您本人以外的个人或实体。\n\n14. “转让”具有《破产法》第 101(54) 条赋予其的含义。\n\n15. “文件”是指属于 Fed. R. Civ. P. 34 范围内的任何信息或物品，并包括但不限于任何种类、类型、性质或描述的每一项书面、记录或图形材料，该等材料现由或曾由您占有、保管或控制，包括电子邮件的全部打印及电子副本、以电子形式保存的计算机文件、电子通信、短信、社交媒体帖子、推文、元数据、信函、备忘录、磁带、速记或手写笔记、任何种类的书面表格、图表、蓝图、图纸、草图、曲线图、计划、文章、规格说明、日记、信件、电报、照片、会议记录、合同、协议、调查、计算机打印件、任何种类的数据汇编、电传、传真、语音留言、发票、订单表格、支票、汇票、对账单、贷项通知单、报告、持仓报告、摘要、索引、书籍、账簿、笔记本、附表、透明胶片、录音、目录、广告、宣传材料、胶片、录像带、录音带、CD、计算机磁盘、宣传册、小册子、穿孔卡、工时单、推文、社交媒体帖子或任何其他种类的书面或记录材料，以及其全部元数据，无论以何种方式存储（无论为有形或电子形式）、记录、制作或复制；并且还包括但不限于前述任何材料的草稿或副本，如该等草稿或副本载有原始文件中未出现的任何种类的笔记、评论或标记，或在其他方面与原始文件不相同。\n案件 22-50073 文件 1592 提交日期 03/24/23 录入日期 03/24/23 10:57:37 第 1039 页，共 1063 页\n\n16. “个人”是指个人、公司、独资企业、合伙企业、协会或任何其他实体。“个人”还包括任何代理人、代表或专家，包括但不限于律师或财务顾问。\n\n17. “实体”是指任何自然人、公司、合伙企业、子公司、独资企业、商号、董事会、合资企业、协会、机构、机关、委员会或其他商业实体或法人，以及任何关联方、代理人、母公司，包括但不限于法律顾问、财务顾问或任何其他代表。\n\n18. “关于”是指涉及、描述、构成、提及、与之相关、支持、赞成、反对、加强、削弱、位于其中、结合其予以考虑、对其具有影响、证明、表明、就其报告、记录、暗指、回应、与之关联、就其评论、就其而言、有关、与之相关、讨论、显示、描述、反映、分析、构成及属于。\n案件 22-50073 文件 1592 提交日期 03/24/23 录入日期 03/24/23 10:57:37 第 1040 页，共 1063 页\n\n19. 在提及任何特定事项时，“与之有关”“涉及”或“相关”是指，包括但不限于，构成、包括、涉及、包含、体现、反映、识别、陈述、直接或间接提及，或以任何方式与所确定的特定事项有关的任何文件。\n\n20. “通信”在最广泛可能的意义上且不受限制地指任何信息或知识的传递（以事实、观点、询问或其他形式）。通信还指所有谈话、协议、询问或答复，无论是当面、通过电话、书面方式，还是通过电子传输设备，并包括但不限于所有信函、电子邮件、录音、传送单、备忘录、电话通信、语音留言、电报、电话传真、传真副本、电传、即时消息、聊天、短信、电话笔记，或在内部或与第三方之间传送的笔记。\n\n21. “资产”是指可用于产生正面经济价值的任何项目，包括但不限于由实体拥有、控制或为实体利益而存在，并预期能够提供未来利益的任何具有经济价值的资源，包括但不限于所有不动产和动产、无形财产、投资、投资权或未来收益权、现金、银行账户、商品、证券、债权、对实体的全部或部分控制权，以及预期的经济机会。\n\n22. “转让”具有《破产法》第 101(54) 条赋予其的含义。\n案件 22-50073 文件 1592 提交日期 03/24/23 录入日期 03/24/23 10:57:37 第 1041 页，共 1063 页\n\n四、应提交的文件\n\n1. 与债务人、债务人财产或关联实体的任何收入或资产有关的所有文件。\n\n2. 与债务人的财务状况及其对债权人的义务有关的所有文件，包括但不限于与任何试图避免支付该等义务的行为有关的所有文件，以及与本案或任何其他实际或可能发生的破产或类似无力偿债程序有关的所有文件。\n\n3. 与债务人、债务人财产、债务人家庭成员、关联实体或关联个人有关的任何资产负债表、银行对账单、账户对账单、财务报表、账户报表、电汇指示及/或确认、资金证明、存款证、持仓证明、投资组合摘要或类似文件有关的所有文件，包括但不限于足以显示向前述任何一方作出的全部转让的所有文件。\n\n4. 与债务人作出、与债务人进行或代表债务人作出的任何投资、商业交易或其他交易有关的所有文件。\n\n5. 与债务人的所有通信，以及与债务人的通信有关、涉及任何实体（包括但不限于关联实体）的运营、管理或决策的文件。\n\n6. 与向债务人、债务人家庭成员或关联实体作出、由其作出或与其进行的任何转让、投资或其他交易或商业往来有关的所有文件。\n\n7. 与债务人曾经占用或使用的任何财产有关的所有文件，包括但不限于 Lady May；Sherry Netherland Hotel / Condominium；位于 Connecticut（康涅狄格州）Greenwich（格林尼治）373 Taconic Rd. 的住宅物业；位于 Connecticut（康涅狄格州）Greenwich（格林尼治）33 Ferncliff Rd. 的住宅物业；以及位于 Connecticut（康涅狄格州）Wilton（威尔顿）354 Nod Hill Rd. 的住宅物业。\n案件 22-50073 文件 1592 提交日期 03/24/23 录入日期 03/24/23 10:57:37 第 1042 页，共 1063 页\n\n8. 与债务人拥有、控制或使用的任何航空器有关的所有文件，包括但不限于尾号为 T7-GQM 的航空器以及在圣马力诺登记的任何其他航空器，包括但不限于所有登记文件副本，以及显示该等航空器所进行航班及该等航班机上人员的飞行清单。\n\n9. 有关向债务人、债务人财产、债务人家属或关联实体提供、从其取得或代表其提供的任何赠与、利益或贷款的所有文件，包括但不限于足以显示该等赠与、利益或贷款金额的文件；该等赠与、利益或贷款的用途；提供该等赠与、利益或贷款的时间；以及任何贷款的条款、与任何贷款有关作出的所有陈述和保证、任何贷款的利率，以及任何贷款付款的全部证据。\n\n10. 有关由债务人、代表债务人或为债务人利益，或由、代表或为债务人财产、债务人家属或关联实体的利益而设立的任何信托或类似文书的所有文件，包括但不限于足以显示设立该等信托的时间、设立人、设立受益人以及信托财产的文件。\n\n11. 与涉及债务人的任何法律争议相关的任何义务、请求权、责任或债务有关的所有文件，包括但不限于与任何地方、州、联邦或国际机构前的任何诉讼有关的文件，无论该机构为行政机构、法院、合议机构或替代性争议解决实体。\n案件 22-50073 文书 1592 提交于 03/24/23 录入于 03/24/23 10:57:37 第 1043 页，共 1063 页\n\n12. 您的任何外聘律师或其他顾问与债务人之间的所有文件和通信。\n\n13. 足以显示您的全部资产以及收入或资金来源的文件。\n\n14. 对于就请求第 14 项所识别的、价值超过 $50,000 的所有资产，提供：(i) 与您取得该等资产有关的所有文件；以及 (ii) 与债务人或债务人家属就该等资产进行的通信。\n\n15. 您的纳税申报表副本。\n\n16. 足以显示由您占有或控制的所有银行账户和投资账户的文件，包括每一该等账户的余额以及向其转入和从其转出的款项。\n\n17. 有关您使用的任何信用卡的所有文件，包括但不限于月度对账单或足以显示为债务人或关联实体利益而进行的与此有关的所有购买的其他文件。\n\n18. 所有公司治理和组织文件，包括但不限于公司章程细则、公司注册证书，以及足以显示您的公司结构、高级管理人员和董事姓名、经营目的及与债务人或债务人任何家属成员关系的其他文件。\n\n19. 与向任何其他实体质押您的任何资产有关的所有文件。\n\n案件 22-50073 文书 1592 提交于 03/24/23 录入于 03/24/23 10:57:37 第 1044 页，共 1063 页\n\n附件 C-57\n\nB2540（表格 2540——依据规则 2004 进行审查的传票）（12/15）案件 22-50073 文书 1592 提交于 03/24/23 录入于 03/24/23 10:57:37 第 1045 页，共 1063 页\n\n美国破产法院（UNITED STATES BANKRUPTCY COURT）\n\n康涅狄格地区\n\n关于 HO WAN KWOK（郭文贵）等人，\n\n案件编号 22-50073 (JAM)\n\n债务人　第 11 章\n\n（联合管理）\n\n依据规则 2004 进行审查的传票\n\n致：Brown Harris Stevens（布朗·哈里斯·史蒂文斯）\n\n（传票受送达人的姓名）\n\n证言：兹命令您于下列规定的时间、日期和地点到场，就《联邦破产程序规则》第 2004 条规定的审查作证。随附准许该审查的法院命令副本。\n\n地点　日期和时间\n\nPaul Hastings LLP（普衡律师事务所）\n200 Park Avenue　[TBD]\nNew York, New York 10166\n\n审查将以如下方式记录：法庭记录员/速记员\n\n提交：您或您的代表还必须在审查时携带下列文件、以电子方式存储的信息或物件，并且必须允许对该等材料进行查验、复制、测试或抽样：\n\n见随附于此的文件提交请求。\n\nFed. R. Civ. P. 45 的下列规定通过 Fed. R. Bankr. P. 9016 适用于破产案件，现随附于后——有关履行地点的规则 45(c)；有关作为传票对象的您所受保护的规则 45(d)；以及有关您对本传票的答复义务和不答复的潜在后果的规则 45(e) 和 45(g)。\n\n日期：2023 年 3 月\n\n法院书记官\n\n或\n\n书记官或副书记官签名　律师签名\n\n签发或请求本传票的、代表第 11 章受托人 Luc A. Despins（Luc A. Despins）的律师姓名、地址、电子邮件地址及电话号码如下：\n\nDouglas S. Skalka, Esq.（Douglas S. Skalka）；Neubert, Pepe & Monteith, P.C.（Neubert, Pepe & Monteith, P.C.）；195 Church Street, New Haven, Connecticut 06510；dskalka@npmlaw.com；(203) 821-2000\n\n致签发或请求本传票之人的通知\n\n如本传票要求在审判前提交文件、以电子方式存储的信息或有形物品，或者查验场所，则必须在向传票所指向之人送达前，向各方当事人送达通知及本传票副本。Fed. R. Civ. P. 45(a)(4)。\n\n软件版权 (c) 1996-2022 Best Case, LLC（最佳案件有限责任公司）- www.bestcase.com Best Case Bankruptcy（最佳案件破产系统）1 本第 11 章案件中的债务人为 Ho Wan Kwok（郭文贵）（又称 Guo Wengui、Miles Guo 和 Miles Kwok，以及众多其他别名）（税务识别号码后四位：9595）、Genever Holdings LLC（税务识别号码后四位：8202）及 Genever Holdings Corporation。受托人、Genever Holdings LLC 和 Genever Holdings Corporation 的邮寄地址为 Paul Hastings LLP, 200 Park Avenue, New York, NY 10166，收件人为 Luc A. Despins，作为 Ho Wan Kwok 财产的受托人（仅为通知和通信之目的）。\n\n送达证明\n\n（除非 Fed. R. Civ. P. 45 要求，否则本节不应向法院提交。）\n\n本人于（日期）收到向（个人姓名及职务，如有）发出的本传票。\n\n本人通过如下方式向被指定人交付副本，以送达本传票：\n\n于（日期）；或\n\n本人未执行即退回本传票，原因如下：\n\n除非本传票系代表美国或其官员或代理人签发，本人还已向证人支付一天出席费用及法律允许的里程费，金额为 $ 。\n\n本人的费用为差旅费 $ 及服务费 $，合计 $ 。\n\n本人在伪证处罚的约束下声明，该等信息真实且正确。\n\n日期：\n\n送达人员签名\n\n正楷姓名及职务\n\n送达人员地址\n\n关于尝试送达等事项的补充信息：\n\n《联邦民事诉讼规则》45(c)、(d)、(e) 和 (g)（自 12/1/13 起生效）（通过《联邦破产程序规则》第 9016 条适用于破产案件）\n\n(c) 履行地点。\n\n(1) 审判、听证或证言录取。传票仅可按如下方式命令某人出席审判、听证或证言录取：\n\n(A) 在该人居住、受雇或经常亲自办理业务地点 100 英里以内；或者\n\n(B) 在该人居住、受雇或经常亲自办理业务所在州内，前提是该人：\n\n(i) 为当事人或当事人的高级管理人员；或者\n\n(ii) 被命令出席审判且不会产生重大费用。\n\n(2) 其他证据开示。传票可以命令：\n\n(A) 在该人居住、受雇或经常亲自办理业务地点 100 英里以内的地点提交文件、以电子方式存储的信息或物品；以及\n\n(B) 在待查验场所进行场所查验。\n\n(d) 对作为传票对象之人的保护；执行。\n\n(1) 避免不当负担或费用；制裁。负责签发和送达传票的当事人或律师必须采取合理措施，避免对作为传票对象之人施加不当负担或费用。要求履行的地区法院必须执行该义务，并对未遵守者的当事人或律师施加适当制裁，该制裁可包括损失的收入和合理的律师费。\n\n(2) 命令提交材料或允许查验。\n\n(A) 无须到场。被命令提交文件、以电子方式存储的信息或有形物品，或允许查验场所之人，无须亲自到提交或查验地点到场，除非还被命令出席证言录取、听证或审判。\n\n(B) 异议。被命令提交文件或有形物品，或允许查验之人，可以向传票中指定的当事人或律师送达书面异议，反对查验、复制、测试或抽样任何或全部材料，或反对查验场所——或者反对以所请求的一种或多种形式提交以电子方式存储的信息。异议必须在指定履行时间或传票送达后 14 天届满之日中较早者之前送达。如提出异议，则适用下列规则：\n\n(i) 送达方可在任何时候，经通知被命令之人后，向要求履行的地区法院提出动议，请求作出强制提交或查验的命令。\n\n(ii) 仅可按命令指示要求进行该等行为，且该命令必须保护既非当事人亦非当事人高级管理人员之人，免受因履行而产生的重大费用。\n\n(3) 撤销或修改传票。\n\n(A) 必须撤销或修改的情形。经及时动议，要求履行的地区法院必须撤销或修改具有下列情形的传票：\n\n(i) 未给予合理履行时间；\n\n(ii) 要求某人在规则 45(c) 规定的地理限制范围以外履行；\n\n(iii) 要求披露享有特权或以其他方式受保护的事项，且不适用任何例外或弃权；或者\n\n(iv) 对某人施加不当负担。\n\n(B) 允许撤销或修改的情形。为保护作为传票对象或受传票影响之人，要求履行的地区法院可依动议撤销或修改要求下列事项的传票：\n\n(i) 披露商业秘密或其他保密的研究、开发或商业信息；或者\n\n(ii) 披露未经聘任的专家的意见或信息，该等意见或信息并非描述争议中的具体事件，且系该专家未受当事人请求所进行研究的结果。\n\n(C) 以规定条件作为替代。在规则 45(d)(3)(B) 所述情形下，如送达方：\n\n(i) 证明对该证言或材料具有重大需要，且如无不当困难即无法通过其他方式满足；以及\n\n(ii) 确保被传唤之人将获得合理报酬，\n\n法院可不撤销或修改传票，而是命令在规定条件下到场或提交。\n\n(e) 答复传票的义务。\n\n(1) 提交文件或以电子方式存储的信息。下列程序适用于提交文件或以电子方式存储的信息：\n\n(A) 文件。答复要求提交文件的传票之人，必须按照文件在正常业务过程中保存的方式提交，或者必须将其整理并标注，以对应请求中的类别。\n\n(B) 未指定以电子方式存储的信息的提交形式。如传票未指定提交以电子方式存储的信息的形式，答复之人必须以该等信息通常保存的一种或多种形式，或以一种或多种合理可用的形式提交。\n\n(C) 以电子方式存储的信息仅须以一种形式提交。答复之人无须以一种以上形式提交同一以电子方式存储的信息。\n\n(D) 无法合理访问的电子存储信息。答复人无需就其认定因不当负担或费用而无法合理访问的来源中的电子存储信息提供证据开示。在提出强制证据开示动议或保护令动议时，答复人必须证明该信息因不当负担或费用而无法合理访问。如作出该证明，法院仍可在请求方证明存在正当理由时，命令对该等来源进行证据开示，并应考虑 Rule 26(b)(2)(C) 的限制。法院可以规定证据开示的条件。\n\n(2) 主张特权或保护。\n\n(A) 被扣留的信息。依据该等信息享有特权或作为审判准备材料受到保护的主张而扣留被传唤信息的人，必须：(i) 明确提出该主张；以及\n\n(ii) 以一种在不披露本身享有特权或受保护的信息的情况下，能够使各方评估该主张的方式，说明被扣留文件、通信或有形物品的性质。\n\n(B) 已提供的信息。如为响应传票而提供的信息受特权主张或作为审判准备材料受到保护的主张所规限，提出该主张的人可以将该主张及其依据通知任何收到该信息的当事方。收到通知后，当事方必须立即返还、隔离或销毁所指明的信息及其持有的任何副本；在该主张得到解决前，不得使用或披露该信息；如该当事方在收到通知前已披露该信息，必须采取合理措施取回该信息；并且可以立即将该信息密封提交给要求履行义务所在地区的法院，以裁定该主张。提供该信息的人必须在该主张得到解决前保存该信息。\n\n(g) 藐视法庭。要求履行义务所在地区的法院——以及在动议被移送后，发出传票的法院——可以认定已被送达但无充分理由不遵守传票或与其有关命令的人构成藐视法庭。\n\n有关获取传票材料，请参见 Fed.R.Civ.P.45(a) Committee Note (2013)\n\n……\n\n文件提供请求\nI. 指示\n\n1. 除非另有说明，下列文件请求（以下简称“请求”，每一项以下简称“一项请求”）必须分别且具体地作出答复。除非善意提出异议，否则必须对每项请求作出完整答复；如提出异议，则必须按如下所述详细说明您提出异议的理由。如异议仅涉及某项请求的一部分，或其中包含的某个词语、短语或条款，您仅须说明对该部分的异议，并对其余请求作出答复。\n\n2. 电子存储信息必须依照下列指示提供：\n\na. 图像。黑白图像必须为 300 DPI Group IV 单页 TIFF 文件。彩色图像必须以 JPEG 格式提供。文件名不得包含嵌入空格或特殊字符（包括逗号）。文件夹名称不得包含嵌入空格或特殊字符（包括逗号）。所有 TIFF 图像文件必须具有唯一文件名，即 Bates 编号。每一图像右下角必须加注连续的 Bates 编号。每个文件夹内的 TIFF 文件数量不得超过 1000 个文件。Excel 电子表格应具有以该文件的 Bates 编号命名的占位图像。\n\nb. 图像加载文件\n\na. Concordance® 数据文件。数据文件（.DAT）包含将被加载至 Concordance® 数据库的全部字段信息。.DAT 文件的第一行必须为标识字段名称的标题行。.DAT 文件必须使用以下 Concordance® 默认分隔符：逗号 ASCII 字符（020）；引号 þ ASCII 字符（254）。日期字段应以 mm/dd/yyyy 格式提供。日期和时间字段必须为两个单独字段。如文件包括已成像的电子邮件及附件，则必须包括附件字段，以保留电子邮件与其附件之间的父/子关系。必须包括 OCRPATH 字段，以提供所提供存储介质中提取文本文件的文件路径和名称。文本文件必须以 FIRSTBATES 命名。不得在 .DAT 文件中包含文本。对于含有原生文件的文件，必须包括 LINK 字段，以提供原生文件的文件路径和名称。原生文件必须以 FIRSTBATES 命名。\n\nb. Concordance Image® 或 Opticon 交叉引用文件。图像交叉引用文件（.LOG 或 .OPT）将图像链接至数据库记录。其应为逗号分隔的文件，每行由七个字段组成；数据库中每一图像均应在交叉引用文件中有一行，格式如下：ImageID,VolumeLabel,ImageFilePath,DocumentBreak,FolderBreak,Box Break,PageCoun。\n\nc. 文件文本。文本必须作为单独的文本文件提供，而不得作为 .DAT 文件内的字段提供。文本文件的完整路径（OCRPATH）应包括在 .DAT 文件中。建议提供以 FIRSTBATES/Image Key 命名的文件级 ANSI 文本文件。提取的文本文件必须置于单独的文件夹中，每个文件夹内的文本文件数量不得超过 1,000 个文件。文件夹名称中不得有特殊字符（包括逗号）。文本文件必须按文件级提供。\n\nd. 特定文件类型的原生文件提供。为完整理解其内容和含义而合理需要以原生格式查看的文件类型，必须以原生格式提供。这些文件包括但不限于电子表格、类电子表格文件（Microsoft Excel、逗号分隔值、制表符分隔值等）、Microsoft PowerPoint 或其他特殊演示文件、数据库文件以及音频/视频文件。提供一张带有 Bates 编号的提示页图像，以表明存在原生文件，并在 .dat 文件中将原生文件的路径作为字段列入。所提供的原生文件应以与该文件提示页相对应的 Bates 编号命名。将原生文件按递增命名的“NATIVE”目录分组，并与图像目录分开。\n\ne. 去重。对于存在完全重复件的每份电子文件，仅提供一份副本。对于电子邮件，基于由 BCC、Body、CC、From、IntMsgID、To 和 Attach 属性生成的 MD5 哈希值合并重复件。对于电子邮件附件和独立电子文件，基于整个文件的 MD5 哈希值合并重复件。\n\nf. 元数据。以符合 Concordance 要求的加载文件（.dat）形式，提供每份文件的提取元数据。.DAT 文件的第一行必须为标识字段名称的标题行。.DAT 文件必须使用以下 Concordance 默认分隔符：逗号 , ASCII 字符（020）；引号 þ ASCII 字符（254）\n\n日期字段应以 mm/dd/yyyy 格式提供。日期和时间字段必须为两个单独字段。下列为必需的元数据：\nCase 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 1050 of 1063\n\n字段名称　样本数据　说明\n\nFIRSTBATES　EDC0000001　原生文件文件/电子邮件的第一个 Bates 编号\nLASTBATES　EDC0000001　原生文件文件/电子邮件的最后一个 Bates 编号\nLASTBATES 字段应针对单页文件填入\nATTACHRANGE　EDC0000001\n-　父文件首页的 Bates 编号至最后一个附件“子”文件最后一页的 Bates 编号\nEDC0000015\nBEGATTACH　EDC0000001　附件范围的第一个 Bates 编号\n\nENDATTACH　EDC0000015　附件范围的最后一个 Bates 编号\nCUSTODIAN　Smith, John（约翰·史密斯）　电子邮件：该电子邮件所在的邮箱\n原生文件：该文件源自其文件的个人或部门名称\nFROM　John Smith（约翰·史密斯）　电子邮件：发件人\n原生文件：文件作者\n多个条目应以分号分隔\nTO　Coffman, Janice（珍妮丝·科夫曼）; LeeW（李W）\n[mailto:LeeW@MSN.com]　收件人\n多个条目应以分号分隔\nCC　Frank Thompson（弗兰克·汤普森） [mailto:\nfrank_Thompson@cdt.com]　抄送收件人\n多个条目应以分号分隔\nBCC　John Cain（约翰·凯恩）　密送收件人\n多个条目应以分号分隔\nSUBJECT　Board Meeting Minutes　电子邮件：电子邮件主题行；原生文件：文件标题（如有）\nFILE_NAME　BoardMeetingMinutes.docx　原生文件：原始原生文件的名称，包括扩展名\nDATE_SENT　10/12/2010　电子邮件：电子邮件发送日期\n原生文件：（空）\nTIME_SENT/\nTIME_ZONE　07:05 PM GMT　电子邮件：电子邮件发送时间/电子邮件被标准化时所在的时区\nTIME_ZONE　GMT　在转换期间电子邮件被标准化时所在的时区。\nLINK　>EDC0000001.msg　电子邮件或原生文件文件的超链接\n所链接文件必须按 FIRSTBATES 编号命名\nFILE_EXTEN　MSG　表示电子邮件或原生文件的文件类型扩展名\nAUTHOR　John Smith　电子邮件：（空）\n原生文件：文件作者\nDATE_CREATED　10/10/2010　电子邮件：（空）\n原生文件：文件创建日期\n\nCase 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 1051 of 1063\n\nTIME_CREATED　10:25 AM　电子邮件：（空）\n原生文件：文件创建时间\n该数据必须为单独字段，不得与 DATE_CREATED 字段合并\nDATE_MOD　10/12/2010　电子邮件：（空）\n原生文件：文件最后修改日期\nTIME_MOD　07:00 PM　电子邮件：（空）\n原生文件：文件最后修改时间\n该数据必须为单独字段，不得与 DATE_MOD 字段合并\nDATE_ACCESSD　10/12/2010　电子邮件：（空）\n原生文件：文件最后访问日期\nTIME_ACCESSD　07:00 PM　电子邮件：（空）\n原生文件：文件最后访问时间\n该数据必须为单独字段，不得与 DATE_ACCESSD 字段合并\nFILE_SIZE　5,952　原生文件文件/电子邮件的大小，以 KB 计\nPGCOUNT　1　原生文件文件/电子邮件中的页数\nPATH　电子邮件：（空）\nAgenda.doc　原生文件：存储原生文件文件的路径，包括原始文件名。\nINTFILEPATH　Personal Folders\\Deleted\nItems\\Board Meeting\nMinutes.msg　电子邮件：电子邮件的原始位置，包括原始文件名。\n原生文件：（空）\nINTMSGID　<000805c2c71b\\$75977050\\$\ncb8306d1@MSN>　电子邮件：唯一消息 ID；原生文件：（空）\nMD5HASH　d131dd02c5e6eec4693d9a0\n698aff95c\n2fcab58712467eab4004583e\nb8fb7f89　文件的 MD5 哈希值。\nOCRPATH　TEXT/001/EDC0000001.txt　原生文件提取文本的路径\n\n3. 每项请求均独立适用并应独立解释，除非另有说明，任何请求均不限制任何其他请求的范围。\n\n4. 所有文件均应按其在正常业务过程中保存的方式提供，或者应予组织和标注，以对应本请求中的类别。\n\n5. 本文所载每项请求均延及所有文件：(a) 由您占有、保管或控制的文件；或 (b) 由代表您行事的任何人占有、保管或控制的文件，\nCase 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 1052 of 1063\n\n包括您的律师或其他代表和顾问。每份文件均应完整提供。\n\n6. 如要求贵方提供一份已不再由贵方占有、保管或控制的文书，则贵方的答复必须：(a) 详细说明该文书的性质及其内容；(b) 指明编制或撰写该文书的人员（以及，如适用，该文书的收件人员）；(c) 指明该文书编制或形成的日期；(d) 说明该文书是否：(i) 遗失或丢失，(ii) 已被销毁，(iii) 已自愿或非自愿地转移给他人，或 (iv) 以其他方式被处置；(e) 说明该等处置的理由，以及有关该等处置的事实和情形；(f) 指明授权该等处置的人员；(g) 指明该等处置的日期或大致日期；(h) 说明该文书最近一次由贵方占有、保管或控制的时间；及 (i) 指明目前占有、保管或控制该文书的人员（如有）。\n\n7. 如要求贵方提供一份已被销毁的文书，则除前述指示所要求的信息外，贵方的答复还必须说明：(a) 销毁该文书的理由；(b) 销毁该文书的人员身份；及 (c) 指示销毁该文书的人员身份。\n\n8. 如贵方主张某一被要求提供的文书享有特权或属于律师工作成果，则贵方的答复必须：(a) 说明：(i) 足以支持贵方关于该文书享有特权之主张的该文书描述，(ii) 该文书的标题，(iii) 该文书的日期，(iv) 该文书的作者，(v) 该文书的收件人，(vi) 收到或阅览该文书原件或任何草稿、副本或复制件的每一人员的身份，(vii) 该文书本身，或该文书中载有或提及的任何信息，是否由任何其他人员占有、保管或控制；如是，则该等人员的身份，以及说明该等信息如何进入其占有范围的陈述，(viii) 据以不提供该文书的特权主张，及 (ix) 贵方将据以支持该等特权主张的全部情形；及 (b) 就根据 D. Conn. L. Civ. R. 26(e) 基于特权主张而未予提供的每一文书，制作一份特权清单，其中载明本指示第 (a) 部分所要求的全部信息。对于文书请求中未提出特权或工作成果主张的任何部分，应完整提供相应文书。\n\n案件 22-50073，文件 1592，于 03/24/23 提交，于 03/24/23 10:57:37 登记，第 1053 页，共 1063 页\n\n9. 如一份原本应予提供的文书的一部分含有受特权主张约束的信息，则仅应依照上述指示从该文书中删除或遮盖受特权主张约束的该部分，其余部分应予提供。\n\n10. 该等请求具有持续性。现指示贵方：(a) 在获悉先前答复不完整或不正确后，立即补充或更正任何后来获悉不完整或不正确的答复；及 (b) 提供根据下列规定所要求的任何额外文书\n\n11. 如文书使用英语以外的语言，贵方应提供该文书。如文书使用英语以外的语言，且存在英文译本，贵方应同时提供两份文书。\n\n12. 对实体的所有提及均包括其全部关联方。\n\n13. 对个人姓名的所有提及均包括所有别名、化名或昵称。\n\n案件 22-50073，文件 1592，于 03/24/23 提交，于 03/24/23 10:57:37 登记，第 1054 页，共 1063 页\n\n14. 除非另有明确说明，文书请求所涵盖的期间为自 February 5, 2012 起至文书请求答复到期之日止。\n\nII. 解释规则\n\n15. (a) 任何单数名词的使用，应解释为包括复数，反之亦然；以及 (b) 任何时态动词的使用，应解释为该动词在所有其他时态中的使用。\n\n16. (a) “和”及“或”应根据需要解释为合取或析取，以使原本可能被解释为不在任何请求范围内的所有答复均纳入该请求范围；以及 (b) “每一”及“任何”应视为包括并涵盖“每个”及“全部”一词。\n\nIII. 定义\n\n经 D. Conn. Bankr. L.R. 2004-1(a) 纳入的 D. Conn. L. Civ. R. 26(c) 所规定的定义，以及 D. Conn. L. Civ. R. 26(d) 所规定的解释规则，适用于文书请求。此外，本文件书请求中使用的下列术语具有下列含义：\n\n1. “贵方”或“贵方的”或“贵方自身”是指 Brown Harris Stevens（布朗·哈里斯·史蒂文斯），连同其任何关联方、子公司、雇员、代理人、律师、顾问或代表其行事的任何人。\n\n2. “债务人”是指 Ho Wan Kwok（郭文贵）（亦称 Miles Kwok、Miles Guo、Guo Wengui、Guo Haoyun、郭文贵，或任何其他别名），连同其雇员、代理人、律师、顾问或代表其行事的任何人。\n\n案件 22-50073，文件 1592，于 03/24/23 提交，于 03/24/23 10:57:37 登记，第 1055 页，共 1063 页\n\n3. “债务人的儿子”是指 Qiang Guo（郭强）（亦称 Mileson Kwok、郭强，或任何其他别名），连同其雇员、代理人、律师、顾问或代表其行事的任何人。\n\n4. “债务人的女儿”是指 Mei Guo（郭美）（亦称 Mei Gui、郭美，或任何其他别名），连同其雇员、代理人、律师、顾问或代表其行事的任何人。\n\n5. “债务人据称的妻子”是指 Hing Chi Ngok（岳庆芝）（亦称 Hing Chi Ng、Yue Qingzhi、岳庆芝，或任何其他别名），连同其雇员、代理人、律师、顾问或代表其行事的任何人。\n\n6. “债务人的家庭成员”统称债务人、债务人的儿子、债务人的女儿及债务人据称的妻子，以及与债务人有任何其他家庭关系的人。\n\n7. “关联个人”单独及合并是指所有符合下列条件的个人：(1) 持有、控制、保管或对债务人或债务人的家庭成员拥有、控制或享有的资产拥有处置权；或 (2) 曾为一个或多个关联实体的雇员、董事，或以其他方式与其关联，连同前述各方各自的雇员、代理人、律师、顾问或代表其行事的任何人。该等关联个人包括但不限于：Daniel Podhaskie（丹尼尔·波德哈斯基）、Jason Miller（贾森·米勒）、Steve Bannon（史蒂夫·班农）、Karin Maistrello（卡琳·迈斯特雷洛）、Melissa Francis（梅丽莎·弗朗西斯）、William Gertz（威廉·格茨）、Arethusa Forsyth（阿瑞图莎·福赛思）、Glenn Mellor（格伦·梅勒）、Jennifer Mercurio（詹妮弗·默库里奥）、Eduardo Eurnekian（爱德华多·尤尔内基安）、Han Chunguang（韩春光）（亦称 韩春光）、Qu Guojiao（屈国姣）（亦称 Qu Guo Jiao、屈国姣）、Guo Lijie（郭丽杰）（亦称 郭丽杰）、Zhang Wei（张伟）（亦称 张伟*）、Lihong Wei Lafrenz（魏丽红）（亦称 Sara Wei、魏丽红）、Hao Haidong（郝海东）（亦称 郝海东）、Ross Heinemeyer（罗斯·海内迈耶）、Max Krasner（马克斯·克拉斯纳）、Kyle Bass（凯尔·巴斯）、Melissa Mendez（梅丽莎·门德斯）、Ya Li（李娅）（亦称 李娅）、Dinggang Wang（王定刚）（亦称 王定刚）、An Hong（安红）（亦称 安红）、Yvette Wang（王雁平）（亦称 Yanping Wang、Yan Ping Wang、王雁平）、Fiona Yu（菲奥娜·余）、Je Kin Ming（余建明）（亦称 William Je、Yu Jianming、余建明）、Yaz Qingua（亚兹·钦瓜）及 Lao Jiang（姜云浮）（亦称 Jiang Yunfu、Jiang Yunfu Be、姜云浮）。\n\n案件 22-50073，文件 1592，于 03/24/23 提交，于 03/24/23 10:57:37 登记，第 1056 页，共 1063 页\n\n8. “关联实体”单独及合并是指所有符合下列条件的任何类型组织或实体：(1) 曾由债务人或债务人的家庭成员拥有、控制或投资；或 (2) 对债务人或债务人的家庭成员拥有、控制或享有的任何资产，直接或间接拥有权益，连同前述各方各自的雇员、代理人、律师、顾问或代表其行事的任何人。该等关联实体包括但不限于：7 Nod Hill LLC（7诺德山有限责任公司）、AAGV Limited（AAGV有限公司）、ACA Investment Management Limited（ACA投资管理有限公司）、ACA Capital Group Limited（ACA资本集团有限公司）、Ace Decade Holdings Limited（艾斯十年控股有限公司）、AI Group Holdings Inc.（AI集团控股公司）、Alfa Global Ventures Limited（阿尔法全球创投有限公司）、Alfonso Global Limited（阿方索全球有限公司）、Allied Capital Global Limited（联合资本全球有限公司）、Alpine Fiduciaries SA（阿尔卑斯受托人股份公司）、Anton Development Limited（安东开发有限公司）、Assets Sino Limited（中资产有限公司）、Auspicious Coast Limited（吉祥海岸有限公司）、Beijing Pangu Investment Co.（北京盘古投资公司）、Beijing Pangu Investment Co. Ltd.（北京盘古投资有限公司）、Beijing Pangu Investment Inc.（北京盘古投资股份公司）、Beijing Zenith Holdings Company Limited（北京鼎峰控股有限公司）、Bravo Luck Limited（鸿运有限公司）、BSA Strategic Fund I（BSA战略基金I）、China Golden Spring (Hong Kong) Limited（中国金泉〔香港〕有限公司）、Chuang Xin Limited（创新有限公司）、Crane Advisory Group LLC（克兰咨询集团有限责任公司）、Creative Apex Investments Limited（创意顶峰投资有限公司）、Crystal Breeze Investments Limited（水晶微风投资有限公司）、Dawn State Limited（黎明州有限公司）、Eastern Profit Corporation Limited（东方利润有限公司）、Elite Well Global Limited（精英环球有限公司）、Empire Growth Holdings（帝国增长控股公司）、G Club Operations LLC（G俱乐部运营有限责任公司）、G Fashion LLC（G时尚有限责任公司）、G News LLC（G新闻有限责任公司）、GETTR USA（GETTR美国）、Genever Holdings Corporation（吉尼弗控股公司）、Genever Holdings LLC（吉尼弗控股有限责任公司）、GFASHION MEDIA GROUP INC.（GFASHION媒体集团公司）、GFNY, Inc.（GFNY公司）、Globalist International Limited（环球主义者国际有限公司）、GNews Media Group Inc.（GNews媒体集团公司）、Golden Spring (New York) Ltd.（金泉〔纽约〕有限公司）、Greenwich Land LLC（格林尼治地产有限责任公司）、Guo Media（郭媒体）、GTV Media Group, Inc.（GTV媒体集团公司）、Hamilton Capital Holdings Inc.（汉密尔顿资本控股公司）、Head Win Group Limited（领赢集团有限公司）、Henan Yuda（河南裕达）、Himalaya Embassy（喜马拉雅大使馆）、Himalaya Exchange（喜马拉雅交易所）、Himalaya Federal Reserve（喜马拉雅联邦储备）、Himalaya Supervisory Organization（喜马拉雅监督组织）、HK International Funds Investments (USA) Limited LLC（香港国际基金投资〔美国〕有限责任公司）、Hong Kong International Funds Investments Limited（香港国际基金投资有限公司）、Infinite Increase Limited（无限增长有限公司）、Infinitum Developments Limited（无限开发有限公司）、Insight Phoenix Fund（洞察凤凰基金）、Lamp Capital LLC（兰普资本有限责任公司）、Leading Shine Limited（领耀有限公司）、Leading Shine NY Limited（领耀纽约有限公司）、Long Gate Limited（长龙门有限公司）、Next Tycoon Investments Limited（下一大亨投资有限公司）、New\n\n案件 22-50073，文件 1592，于 03/24/23 提交，于 03/24/23 10:57:37 登记，第 1057 页，共 1063 页\n\nFederal State of China（中国新联邦国）（亦称 NFSC）、Noble Fame Global Limited（卓名环球有限公司）、Rosy Acme Ventures Limited（蔷薇顶点创投有限公司）、Rule of Law Foundation III, Inc.（法治基金会III公司）、Rule of Law Foundation IV, Inc.（法治基金会IV公司）、Rule of Law Fund（法治基金）、Rule of Law Society（法治协会）、Rule of Law Society IV, Inc.（法治协会IV公司）、G-Translators PTY LTD（G-翻译者私人有限公司）、Saraca Media Group, Inc.（萨拉卡媒体集团公司）、Shiny Ace Ltd.（闪耀王牌有限公司）、Shiny Times Holdings Ltd.（闪耀时代控股有限公司）、Spirit Charter Investment Limited（精神宪章投资有限公司）、Stevenson, Wong & Co.（史蒂文森、黄氏公司）、Voice of Guo Media, Inc.（郭媒体之声公司）、Well Origin Ltd.（良好起源有限公司）、World Century Limited（世界世纪有限公司）、Worldwide Opportunity Holdings Limited（全球机遇控股有限公司）、Whitecroft Shore Limited（怀特克罗夫特海岸有限公司）及 ZIBA Limited（ZIBA有限公司）。\n\n9. “包括”或其任何变体是指“包括但不限于”。\n\n10. “和”及“或”是指“和/或”，并应为最大限度扩大其范围而解释为既具有合取含义亦具有析取含义。\n\n11. “任何”、“全部”及“每一”是指“每一个和每一个”。\n\n12. “每一”及“每个”是指“每一个和每一个”。\n\n13. “第三方”是指贵方自身以外的人员或实体。\n\n14. “转让”具有《破产法》section 101(54) 所赋予的含义。\n\n15. “文书”是指属于 Fed. R. Civ. P. 34 范围内的任何信息或物品，并包括但不限于贵方占有、保管或控制之中或曾经由贵方占有、保管或控制的每一项任何种类、类型、性质或描述的书面、记录或图形材料，包括电子邮件的所有纸质及电子副本、以电子形式保存的计算机文件、函件、备忘录、磁带、速记或手写笔记、任何种类的书面表格、图表、蓝图、绘图、草图、图形、计划、文章、规格说明书、日记、信件、电报、照片、会议记录、合同、协议、调查、计算机打印件、任何种类的数据汇编、电传、传真、电子邮件、短信、即时消息、语音\n\n案件 22-50073，文件 1592，于 03/24/23 提交，于 03/24/23 10:57:37 登记，第 1058 页，共 1063 页\n\n消息、发票、订购单、支票、汇票、对账单、贷项通知单、报告、持仓报告、摘要、索引、账簿、分类账、笔记本、附表、透明片、录音、目录、广告、宣传材料、影片、录像带、录音带、CD、计算机磁盘、宣传册、小册子、穿孔卡、工时单、推文、社交媒体帖子，或任何其他种类的书面或记录材料，以及其全部元数据，无论以何种方式存储（无论为有形或电子形式）、记录、制作或复制；并且还包括但不限于前述任何文书的草稿或副本，如其中含有原始文书中不存在的任何种类的笔记、评论或标记，或以其他方式与原始文书不相同。\n\n16. “人员”是指个人、公司、独资企业、合伙企业、协会或任何其他实体。“人员”还包括任何代理人、代表或专家，包括但不限于律师或财务顾问。\n\n17. “实体”是指任何自然人、公司、合伙企业、子公司、独资企业、商号、董事会、合资企业、协会、机构、主管机关、委员会或其他商业实体或法人，以及任何关联方、代理人、母公司，包括但不限于法律顾问、财务顾问或任何其他代表。\n\n18. “关于”是指涉及、描述、构成、提及、与之相关、支持、赞成、反对、强化、削弱、位于、结合考虑、对其有影响、证明、表明、报告、记录、暗指、回应、与之连接、评论、就其而言、有关、与之相关、讨论、显示、描述、反映、分析、构成及属于。\n\n19. 当提及任何特定主题时，“与……相关”“涉及”或“有关”是指但不限于任何构成、包含、涉及、载有、\nCase 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 1059 of 1063\n\n体现、反映、识别、陈述、直接或间接提及，或以任何方式与所识别的特定主题相关的文件。\n\n20. “通信”在最广泛可能的意义上且不受限制地，是指任何信息或知识的传递（以事实、观点、询问或其他形式）。通信还指所有谈话、协议、询问或答复，无论是当面、通过电话、书面形式，还是借助电子传输设备，并包括但不限于所有信函、电子邮件、录音、传送单、备忘录、电话通信、语音留言、电报、传真、电传副本、电传、即时消息、聊天、短信、留言板或群聊中的帖子、社交媒体帖子、推文、上传至任何视频平台的视频、电话记录，或在内部或与第三方之间传递的记录。\n\n21. “资产”是指受占有、保管或控制的任何具有经济价值的项目。资产包括所有不动产和动产，包括但不限于房地产、土地、房屋、公寓、产权公寓、汽车、游艇、船舶、飞机、喷气式飞机、直升机、现金、银行账户、加密货币、证券、应收账款、存货及其他有形和无形财产。\n\nIV. 应提交的文件\n\n1. 与债务人、债务人财产、债务人家属或关联实体的任何收入或资产有关的所有文件。\n\n2. 与债务人、债务人家属的任何成员和／或任何关联实体签订的任何委托书有关的所有文件，包括该等委托书的副本。\nCase 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 1060 of 1063\n\n3. 与基于阁下对债务人、债务人家属或关联实体的代理而向阁下支付任何预付费用有关的所有文件，包括足以识别该预付费用金额及其来源的文件。\n\n4. 与阁下从债务人、债务人家属、家属关联实体或关联实体处或代表其收到并存放于托管账户或客户信托账户中的任何费用、付款或款项有关的所有文件。\n\n5. 足以显示债务人、债务人家属或关联实体向阁下支付或为其利益向阁下支付的任何款项的金额、日期及来源的文件。\n\n6. 与债务人的财务状况及其对债权人的义务有关的所有文件，包括但不限于与任何试图逃避偿付该等义务的行为有关的所有文件，以及与本次或任何其他实际或潜在破产或类似无力偿债程序有关的所有文件。\n\n7. 与关联实体有关的所有文件，包括但不限于与其公司结构、资产、注册成立信息、高级职员及董事、经营目的，以及其与债务人、债务人家属的任何成员或任何关联个人之间关系有关的文件。\n\n8. 与债务人或债务人家属一方及关联实体另一方之间由其作出、与其进行或代表其进行的任何投资或商业交易有关的所有文件。\n\n9. 与债务人、债务人财产、债务人家属或关联实体在其中持有任何权益或投资的任何实体有关的所有文件，包括但不限于该等权益或投资的性质和价值；债务人、债务人财产、债务人家属或关联实体因该等权益或投资而从该等\nCase 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 1061 of 1063\n\n实体获得的任何收益或利益；以及与该等实体有关的任何财务报告或数据有关的所有文件，包括但不限于所有账簿和记录、财务报表或税务文件。\n\n10. 与Lady May；Sherry Netherland Hotel / Condominium；位于康涅狄格州格林尼治Taconic Rd. 373号的住宅物业；位于康涅狄格州格林尼治Ferncliff Rd. 33号的住宅物业；位于康涅狄格州威尔顿Nod Hill Rd. 354号的住宅物业；以及债务人或债务人财产在任何关联实体中拥有的任何财务权益有关的所有文件。\n\n11. 与债务人作为受托人、Genever Holdings Corporation及Genever Holdings LLC于February 17, 2015订立、以Bravo Luck Limited为受益人的所谓《信托声明及协议》有关的所有文件。\n\n12. 与债务人拥有、控制或使用的任何航空器有关的所有文件，包括但不限于尾号为T7-GQM的航空器及在San Marino登记的任何其他航空器，包括但不限于所有登记文件副本，以及显示该等航空器所执行航班及该等航班机上人员的飞行清单。\n\n13. 与债务人、债务人家属或关联实体于July 2020前后或任何其他时间进行的任何原油期货或任何类似商品的投资或交易有关的所有文件，包括但不限于与Jiang Yunfu Be就任何该等投资或交易进行的通信。\n\n14. 阁下与债务人、债务人家属，或代表债务人行事的任何关联个人、代理人、雇员或其他个人之间，就与债务人、债务人财产、债务人家属或关联实体有关的任何转移、投资或其他交易或商业往来所进行的所有通信。\nCase 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 1062 of 1063\n\n15. 与由债务人、债务人财产、债务人家属或关联实体设立、代表其设立或为其利益设立的任何信托或类似文书有关的所有文件，包括但不限于显示该等信托于何时设立、由何人设立、为谁的利益设立，以及该文书信托财产的文件。\n\n16. 与涉及债务人、债务人家属或任何关联实体的任何出售、取得、处置、购买、投资、出资、赠与、信贷展期、贷款或转移有关的所有文件。\n\n17. 与涉及债务人的任何法律争议相关的任何义务、请求权、责任或债务有关的所有文件，包括但不限于与在任何地方、州、联邦或国际机构前进行的任何诉讼有关的文件，无论该机构为行政机关、法院、合议庭或替代性争议解决实体。\n\n18. 与向债务人、债务人财产、债务人家属或任何关联实体提供或由其提供的任何贷款或信贷展期，或相关申请有关的所有文件，包括但不限于：(i) 任何该等贷款或信贷展期的条款，包括其还款条款、陈述与保证及利率；以及(ii) 贷款付款的所有证据。\n\n19. 与债务人使用属于、由债务人家属、关联实体或关联个人控制，或其全部或部分所有权由其持有的任何资产有关的所有文件。\nCase 22-50073 Doc 1592 Filed 03/24/23 Entered 03/24/23 10:57:37 Page 1063 of 1063\n\n20. 与债务人、债务人财产、债务人家属、关联实体或关联个人有关的任何资产负债表、银行对账单、账户对账单、财务报表、账目报表、电汇指示和／或确认书、资金证明、存款证明、持仓证明、投资组合摘要或类似文件有关的所有文件，包括但不限于足以显示向前述任何一方进行的所有转移的所有文件。\n\n21. 与将任何关联实体（包括Bravo Luck Limited）的资产质押给任何其他实体有关的所有文件。","key_entities":["Je","Guo","Himalaya","Kwok","Ho Wan Kwok","Despins","Miles Guo","HCHK","Paul Hastings","William Je","GTV","Saraca","Yanping Wang","GETTR","Himalaya Exchange","Himalaya Alliance","Luc Despins","RICO","CIPA"],"ecf_references":[{"doc_number":637,"court":"CTB"},{"doc_number":1339,"court":"CTB"}],"word_count":359446,"status":"published","published_at":"2023-03-24 00:00:00","created_at":"2023-03-24","updated_at":"2026-08-24 03:36:19"}