{"id":"court_ctb_1647_0","court":"CTB","case_no":"22-50073","doc_number":1647,"sub_number":0,"doc_type":"ORDER","filed_date":null,"title":"UNITED STATES BANKRUPTCY COURT DISTRICT OF CONNECTICUT BRIDGEPORT DIVISION In re:","summary_zh":null,"summary_en":null,"body_en":"# UNITED STATES BANKRUPTCY COURT DISTRICT OF CONNECTICUT BRIDGEPORT DIVISION\n\nIn re:\n\nChapter 11\n\nHO WAN KWOK, *et al.*, [1](#page-0-0)\n\nDocket No. 22-50073 (JAM)\n\nDebtors.\n\n(Jointly Administered)\n\n# **APPELLANTS' DESIGNATION OF ITEMS TO BE INCLUDED IN THE RECORD ON APPEAL AND STATEMENT OF ISSUES TO BE PRESENTED**\n\nPursuant to Rule 8009(a) of the Federal Rules of Bankruptcy Procedure, the appellants, Mei Guo; HK International Funds Investments (USA) Limited, LLC (sometimes, \"HKI\"); Lee Vartan, Esq.; and Chiesa Shahinian & Giantomasi PC (sometimes, \"CSG Law\"); by their undersigned attorneys, CSG Law and Zeisler & Zeisler, P.C., respectfully submit their designation of items to be included in the record on appeal and their statement of issues to be presented in connection with their appeal of the United States Bankruptcy Court's March 10, 2023 *Order Holding HK Parties in Contempt of Court and Sanctioning HK Parties, Attorney Vartan and Chiesa Shahinian & Giantomasi PC* (ECF No. 1537).\n\n## **I. Designation of Items to be Included in the Record on Appeal**\n\n1. March 10, 2023 Order Holding HK Parties in Contempt of Court and Sanctioning HK Parties, Attorney Vartan and Chiesa Shahinian & Giantomasi PC (ECF No. 1537).\n\n<span id=\"page-0-0\"></span><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- 2. July 28, 2022 Omnibus Motion of Chapter 11 Trustee for Entry of Order Under Bankruptcy Rule 2004 and Local Rule 2004-1 Authorizing Discovery With Respect to Various Entities and Individuals Affiliated With Debtor (ECF No. 638).\n- 3. August 16, 2022 Order Granting Chapter 11 Trustee's Application for Rule 2004 Discovery With Respect to Various Entities and Individuals Affiliated With Debtor (ECF No. 758).\n- 4. October 28, 2022 Motion of Chapter 11 Trustee for Entry of Order Compelling Individual Debtor, Mei Guo, HK International Funds Investments (USA) Limited, LLC, Hing Chi Ngok, Greenwich Land LLC, Lamp Capital LLC, and Golden Spring (New York) Ltd. to Comply With Rule 2004 Subpoenas (ECF No. 1046).\n- 5. October 28, 2022 Declaration of Avram E. Luft in Support of Motion of Chapter 11 Trustee for Entry of Order Compelling Debtor, Mei Guo, HK International Funds Investments (USA) Limited, LLC, Hing Chi Ngok, Greenwich Land LLC, Lamp Capital LLC, and Golden Spring (New York) Ltd. to Comply With Rule 2004 Subpoenas (ECF No. 1047).\n- 6. November 14, 2022 Joint Objection of the Debtor, Mei Guo, and HK International Funds Investments (USA) Limited, LLC to Chapter 11 Trustee's Motion to Compel Compliance With Rule 2004 Subpoenas (ECF No. 1090).\n- 7. January 20, 2023 Order Granting in Part Motion to Compel Compliance With Rule 2004 Subpoenas (ECF No. 1353).\n- 8. January 24, 2023 Order Directing the Parties to Mediation (ECF No. 1373).\n- 9. February 1, 2023 Notice of Appearance and Request for Service of Papers filed by Lee Vartan, Esq. (ECF No. 1426).\n- 10. February 10, 2023 Motion of Chapter 11 Trustee for Order to Show Cause Why Debtor, Mei Guo, and HK (USA) Should Not be Held in Contempt of Court for Failure to Comply With Order Compelling Compliance With Rule 2004 Subpoenas and Sanctioned for Such Contempt (ECF No. 1453).\n- 11. February 10, 2023 Motion of Mei Guo and HK International Funds Investments (USA) Limited, LLC for an Extension of Time to Comply With the Court's Order Dated January 20, 2023 (ECF No. 1454).\n- 12. February 13, 2023 Order Granting in Part Motion for Order to Appear and Show Cause Why the Court Should Not Hold the HK Parties in Contempt of Court (ECF No. 1455).\n- 13. March 6, 2023 Opposition of Chapter 11 Trustee to Mei Guo and HK International Funds Investments (USA) Limited, LLC's Motion for an Extension of Time to Comply With the Court's Order Dated January 20, 2023 (ECF No. 1510).\n- 14. March 6, 2023 Declaration of Lee Vartan, Esq. in Opposition to Trustee's Order to Show Cause Regarding Compliance With Rule 2004 Subpoenas and January 20, 2023 Order (ECF No. 1512).\n- 15. March 7, 2023 Reply of Mei Guo and HK International Funds Investments (USA) Limited, LLC in Further Support of Motion for Extension of Time to Comply With the Court's Order Dated January 20, 2023 (ECF No. 1516).\n- 16. March 7, 2023 Response of Chapter 11 Trustee to Declaration of Lee Vartan, Esq. in Opposition to Trustee's Order to Show Cause Regarding Compliance With Rule 2004 Subpoenas and January 20, 2023 Order (ECF No. 1517).\n- 17. March 9, 2023 Order Requiring Filing of Transcript (ECF No. 1527).\n- 18. March 9, 2023 Transcript of Videotaped Deposition of Mei Guo taken on January 20, 2023 (ECF No. 1529).\n- 19. March 13, 2023 Declaration of Mei Guo (ECF No. 1543).\n- 20. March 13, 2023 Declaration of Mei Guo, in Her Capacity as the Sole Member of HK International Funds Investments (USA) Limited, LLC (ECF No. 1544).\n- 21. Transcript of Proceedings dated November 30, 2022, before the Honorable Julie A. Manning in connection with Motion of Chapter 11 Trustee for Entry of Order Compelling Mei Guo and HK International to Comply with Rule 2004 Subpoenas.\n- 22. Transcript of Proceedings dated March 7, 2023, before the Honorable Julie A. Manning in connection with Order to Appear and Show Cause Why the Court Should Not Hold the HK Parties in Contempt of Court; Motion to Extend Time to Comply with the Court's Order Dated 1/20/23.\n- 23. Transcript of Proceedings dated March 8, 2023, before the Honorable Julie A. Manning.\n\n#### II. **Statement of Issues to Be Presented**\n\n- 1. Whether the Bankruptcy Court erred in finding that the order that Mei Guo and HKI purportedly failed to comply with, defined in the *Order Holding HK Parties in Contempt of Court and Sanctioning HK Parties, Attorney Vartan and Chiesa Shahinian & Giantomasi PC* (ECF No. 1537) as the Order Compelling Production, as interpreted by the Chapter 11 Trustee and enforced by the Court, was clear and unambiguous.\n- 2. Whether the Bankruptcy Court erred in finding that Mei Guo and HKI did not comply with the Order Compelling Production.\n- 3. Whether the Bankruptcy Court erred in finding that Mei Guo and HKI did not diligently attempt to reasonably comply with the Order Compelling Production.\n- 4. Whether the Bankruptcy Court erred in finding that the Trustee had proven Mei Guo's and HKI's noncompliance by clear and convincing evidence.\n- 5. Whether the Bankruptcy Court erred in holding Mei Guo and HKI in contempt of court under the Court's inherent contempt power and pursuant to Rule 37(b)(1) and Rule 37(b)(2)(A)(vii) of the Federal Rules of Civil Procedure (the \"Federal Rules\").\n- 6. Whether the Bankruptcy Court erred in finding that Federal Rule 37(b)(2) sanctions were appropriate to enter against Mei Guo; HKI Lee Vartan, Esq.; and CSG Law.\n- 7. Whether the Bankruptcy Court erred in holding that Lee Vartan, Esq. and CSG Law materially misrepresented to the Court that it would proceed with production in its Cross-Motion for an Extension of Time to Comply with Order Compelling Production.\n- 8. Whether the Bankruptcy Court erred in holding that Lee Vartan, Esq. and CSG Law knowingly made false statements to the Court.\n- 9. Each and every issue raised by the Bankruptcy Court's March 10, 2023 Order Holding HK Parties in Contempt of Court and Sanctioning HK Parties, Attorney Vartan and Chiesa Shahinian & Giantomasi PC (ECF No. 1537).\n\nDated: April 10, 2023 */s/ Lee Vartan*\n\nRoseland, New Jersey Lee Vartan (admitted pro hac vice) [lvartan@csglaw.com](mailto:lvartan@csglaw.com) Sam Della Fera, Jr. (admitted pro hac vice) [sdellafera@csglaw.com](mailto:sdellafera@csglaw.com)  Melissa F. Wernick (admitted pro hac vice) [mwernick@csglaw.com](mailto:mwernick@csglaw.com) **CHIESA SHAHINIAN & GIANTOMASI PC** 105 Eisenhower Parkway Roseland, NJ 07068\n\nTelephone: (973) 325-1500 Facsimile: (973) 325-1501 *Attorneys for Mei Guo, HK International Funds Investments (USA) Limited, LLC, Lee Vartan, Esq., and Chiesa Shahinian & Giantomasi PC*\n\nAaron A. Romney (ct28144) [aromney@zeislaw.com](mailto:aromney@zeislaw.com)  James M. Moriarty (ct21876) [jmoriarty@zeislaw.com](mailto:jmoriarty@zeislaw.com)  **ZEISLER & ZEISLER PC** 10 Middle Street, 15th Floor Bridgeport, CT 06604 Telephone: (203) 368-4234 Facsimile: (203) 368-5485 *Local Counsel for Mei Guo, HK International Funds Investments (USA) Limited, LLC, Lee Vartan, Esq., and Chiesa Shahinian & Giantomasi PC*\n\n### **CERTIFICATION OF SERVICE**\n\nI hereby certify that on this 10th day of April 2023, a copy of foregoing Appellants' Designation of Items to be Included in the Record on Appeal and Statement of Issues to be Presented was filed electronically. Notice of this filing will be sent by e-mail to all parties by operation of the Court's electronic filing system or by mail to anyone unable to accept electronic filing as indicated on the Notice of Electronic Filing. Parties may access this filing through the Court's CM/ECF System.\n\nDated: April 10, 2023 */s/ Lee Vartan*\n\nRoseland, New Jersey Lee Vartan (admitted pro hac vice) [lvartan@csglaw.com](mailto:lvartan@csglaw.com) Sam Della Fera, Jr. (admitted pro hac vice) [sdellafera@csglaw.com](mailto:sdellafera@csglaw.com)  Melissa F. Wernick (admitted pro hac vice) [mwernick@csglaw.com](mailto:mwernick@csglaw.com) **CHIESA SHAHINIAN & GIANTOMASI PC** 105 Eisenhower Parkway Roseland, NJ 07068 Telephone: (973) 325-1500 Facsimile: (973) 325-1501 *Attorneys for Mei Guo, HK International Funds Investments (USA) Limited, LLC, Lee Vartan, Esq., and Chiesa Shahinian & Giantomasi PC*\n\nAaron A. Romney (ct28144) [aromney@zeislaw.com](mailto:aromney@zeislaw.com)  James M. Moriarty (ct21876) [jmoriarty@zeislaw.com](mailto:jmoriarty@zeislaw.com)  **ZEISLER & ZEISLER PC** 10 Middle Street, 15th Floor Bridgeport, CT 06604 Telephone: (203) 368-4234 Facsimile: (203) 368-5485 *Local Counsel for Mei Guo, HK International Funds Investments (USA) Limited, LLC, Lee Vartan, Esq., and Chiesa Shahinian & Giantomasi PC*","body_zh":null,"key_entities":["Guo","Kwok","Ho Wan Kwok","Je","Miles Guo","Despins","Paul Hastings"],"ecf_references":[{"doc_number":638,"court":"CTB"},{"doc_number":758,"court":"CTB"},{"doc_number":1046,"court":"CTB"},{"doc_number":1047,"court":"CTB"},{"doc_number":1090,"court":"CTB"},{"doc_number":1353,"court":"CTB"},{"doc_number":1373,"court":"CTB"},{"doc_number":1426,"court":"CTB"},{"doc_number":1453,"court":"CTB"},{"doc_number":1454,"court":"CTB"},{"doc_number":1455,"court":"CTB"},{"doc_number":1510,"court":"CTB"},{"doc_number":1512,"court":"CTB"},{"doc_number":1516,"court":"CTB"},{"doc_number":1517,"court":"CTB"},{"doc_number":1527,"court":"CTB"},{"doc_number":1529,"court":"CTB"},{"doc_number":1537,"court":"CTB"},{"doc_number":1543,"court":"CTB"},{"doc_number":1544,"court":"CTB"}],"word_count":1644,"status":"published","published_at":null,"created_at":null,"updated_at":"2026-07-07 07:53:58"}