{"id":"court_ctb_2295_0","court":"CTB","case_no":"22-50073","doc_number":2295,"sub_number":0,"doc_type":"UNKNOWN","filed_date":null,"title":"UNITED STATES BANKRUPTCY COURT DISTRICT OF CONNECTICUT BRIDGEPORT DIVISION | -------------------------------------------","summary_zh":null,"summary_en":null,"body_en":"## **UNITED STATES BANKRUPTCY COURT DISTRICT OF CONNECTICUT BRIDGEPORT DIVISION**\n\n| ------------------------------------------------------                                                                                                                                                        |                           | x                                                                       |                              |\n|---------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|---------------------------|-------------------------------------------------------------------------|------------------------------|\n| In re:                                                                                                                                                                                                        |                           | :<br>:                                                                  | Chapter 11                   |\n| HO WAN KWOK, et al.,1                                                                                                                                                                                         |                           | :<br>:                                                                  | Case No. 22-50073 (JAM)      |\n|                                                                                                                                                                                                               | Debtors.                  | :<br>:                                                                  | (Jointly Administered)       |\n| ------------------------------------------------------<br>LUC A. DESPINS, CHAPTER 11<br>TRUSTEE,<br>v.<br>GREENWICH LAND, LLC and<br>HING CHI NGOK,<br>------------------------------------------------------ | Plaintiff,<br>Defendants. | :<br>x<br>:<br>:<br>:<br>:<br>:<br>:<br>:<br>:<br>:<br>:<br>:<br>:<br>x | Adv. Proceeding No. 23-05005 |\n|                                                                                                                                                                                                               |                           |                                                                         |                              |\n\n## **JOINT REPORT OF CHAPTER 11 TRUSTEE AND DEFENDANTS GREENWICH LAND, LLC AND HING CHI NGOK REGARDING PERSONALTY AND FIXTURES LOCATED ON OR IN TACONIC PROPERTY**\n\nLuc A. Despins, in his capacity as the chapter 11 trustee (the \"Trustee\") appointed in the\n\nchapter 11 case (the \"Chapter 11 Case\") of Ho Wan Kwok (the \"Debtor\"), and as plaintiff in the\n\nabove-captioned adversary proceeding (the \"Adversary Proceeding\"), by and through his\n\nundersigned counsel, and defendants Greenwich Land, LLC and Hing Chi Ngok (the\n\n<sup>1</sup> The Debtors in these chapter 11 cases are Ho Wan Kwok (also known as Guo Wengui, Miles Guo, and Miles Kwok, as well as numerous other aliases) (last four digits of tax identification number: 9595), 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\"Defendants,\" and, together with the Trustee, collectively, the \"Parties\") hereby submit this joint report (the \"Joint Report\") in response to the Court's order at the status conference on October 24, 2023 directing the Parties to meet and confer regarding the personalty and fixtures located in or on the premises at 373 Taconic Road, Greenwich, Connecticut (the \"Taconic Property\"). The Parties respectfully state the following:\n\n1. On August 24, 2023, the Court entered its *Memorandum of Decision and Order Granting in Part Motion for Preliminary Injunction* in the adversary proceeding against Taurus Fund LLC, Scott Barnett, and Taurus Management LLC [Adv. Proc. 23-05017, Doc. No. 47] (the \"Mahwah PI Order\").\n\n2. Pursuant to the Mahwah PI Order, on September 1, 2023, the Trustee and his counsel conducted a tour of the Mahwah Mansion with professionals from Kroll, LLC to inspect and document the conditions of the premises and the personal property and fixtures located in or on the Mahwah Mansion.\n\n3. On October 23, 2023, the Trustee filed an *Emergency Motion for Status Conference to Discuss Preservation of Property of Estate* [Adv. Proc. Doc. No. 89] (the \"Emergency Motion\") describing his preliminary findings regarding the conditions of the premises and personal property and fixtures located in or on the Mahwah Mansion.\n\n4. In light of these findings, the Trustee sought a status conference to discuss the preservation and protection of estate assets by among other things, authorizing the Trustee to conduct an immediate video tour of the Taconic Property to document items that are on the premises and to document the condition of the premises (the \"Video Tour\").\n\n5. On October 23, 2023, the Court entered its *Order Granting the Trustee's Emergency Motion* [Adv. Proc. Doc. No. 71], ordering counsel for Taurus Fund LLC and counsel for Greenwich Land, LLC to appear at the status conference.\n\n6. On October 24, 2023, the Court held the emergency status conference, which was attended by the Trustee and counsel for the Defendants. The Court directed the Parties to meet and confer, specifically regarding immediately conducting the Video Tour.\n\n7. On October 26, 2023, the Parties met and conferred, but disagreed as to whether or how to proceed with the Video Tour.\n\n#### **Trustee's Position**\n\n8. The Trustee believes the Video Tour is necessary to obtain an inventory of all the items, personalty, and fixtures presently located in or on the Taconic Property so the Trustee can identify any items that are presently missing and/or that may go missing in the future. During the Parties' meet and confer, the Trustee emphasized that the Video Tour is not intended to be and would not be an intrusive process. Specifically, to ensure a speedy, non-intrusive video tour, the Trustee represented that:\n\n- a. the Trustee will not personally attend the Video Tour at the Taconic Property;\n- b. only a limited number of professionals from Kroll, LLC will be present to conduct the Video Tour;\n- c. the Video Tour will not take more than two hours, and will take place at a mutually-agreeable time during the day; and\n- d. counsel for Greenwich Land, LLC may attend the Video Tour.\n\n9. The Court has the power under section 105 of the Bankruptcy Code to enter an order authorizing the Trustee to conduct the Video Tour in accordance with the above parameters to preserve and protect potential estate property located on or in the Taconic Property.\n\n10. The Trustee is fearful that, absent this relief, the Defendants may dissipate potential estate property, as they have in the past, in violation of the Bankruptcy Code and/or a court order. For example, in the memorandum of law in support of his motion for summary judgment [Adv. Proc. Doc. No. 78] (the \"Memorandum of Law\"), the Trustee described how the Defendants (i) sold their property located at 33 Ferncliff Road, Cos Cob, Connecticut after the commencement of this chapter 11 case despite having received a restraining notice from PAX preventing them from selling the property, and (ii) systematically dissipated the sale proceeds thereafter. The Memorandum of Law further describes how Defendants have, through the spending of funds, continued to dissipate Greenwich Land's assets in violation of this Court's temporary restraining order entered on March 28, 2023 [Adv. Proc. Doc. No. 14] and the preliminary injunction entered on May 26, 2023 [Adv. Proc. Doc. No. 53].\n\n11. The Trustee's photographic evidence further suggests that the Defendants have been moving personalty and fixtures out of the Taconic Property following the Debtor's petition date. For example, the images attached hereto as **Exhibit A** show that the wall fixture identified in Tab 29 of the exhibit to the Emergency Motion and seen in the Taconic Property on May 16, 2020, was still located in the Taconic Property as of January 16, 2022, merely one month prior to the Debtor's petition date. The wooden table and blue desk identified in Tab 28, which were seen in the Taconic Property on March 27, 2020, was still located in the Taconic Property as of January 18, 2022. These pieces of furniture were subsequently identified in the Mahwah Mansion on September 1, 2023, at Tabs 26, 38, and 39 of the exhibit to the Emergency Motion.\n\nThere are reasonable grounds to believe that the above-mentioned pieces of furniture were still located in the Taconic Property on the Debtor's petition date.\n\n12. The issue at hand is binary and straightforward: either the Court permits the Trustee to obtain and preserve evidence of assets which the Trustee believes are the property of the estate through the Video Tour, or it does not. The Trustee is confused by the Defendants' position as to what, if anything, could be achieved by further meeting and conferring. Any delay could only potentially lead to further dissipation of property of the estate. To the extent the Court requires the Trustee to file a separate motion for the Video Tour, which the Trustee believes is unnecessary, such motion should be heard on an expedited timetable in light of the history of dissipation of estate assets by the Defendants and others associated with the Debtor.\n\n13. For all of these reasons, the Trustee respectfully requests that the Court to enter an order authorizing the Trustee to conduct an immediate video tour at the Taconic Property to document the items, personalty, and fixtures in or on the premises and to document conditions of the premises.\n\n### **Defendants' Position**\n\n14. Defendants Greenwich Land, LLC and Hing Chi Ngok, by their counsel, respectfully submit this status update at the direction of the Bankruptcy Court. On October 26, 2023, Defendants, through counsel, met and conferred with the Trustee. The parties were unable to reach a consensual resolution regarding the Trustee's Emergency Motion. Defendants remain willing to continue meeting and conferring with the Trustee, but the Trustee has advised Defendants that he does not believe further meeting and conferring would be productive. Therefore, to the extent the Trustee wishes to seek relief, he should file a motion seeking relief and Defendants will respond to any such motion. Defendants respectfully request that the Court\n\nnot require Defendants to respond on an emergency basis while Defendants' counsel is busy preparing Defendants' opposition to the Trustee's summary judgment motion. As it relates to Greenwich Land, the Trustee's Motion for Status Conference was based on purported photographs from videos that have been on the Internet for approximately three years. Defendants respectfully request that the Court not acquiesce to the Trustee's contrived \"emergency\" and that any motion filed by the Trustee be addressed deliberatively after Defendants have a reasonable opportunity to respond.\n\n15. Defendants submit this status report without prejudice to their pending motion to withdraw the reference and all of their rights, remedies, and arguments relating and attendant thereto.\n\n## [*Remainder of Page Intentionally Left Blank*]\n\nNew York, New York\n\n### Dated: October 27, 2023 LUC A. DESPINS, CHAPTER 11 TRUSTEE\n\n By: */s/ Nicholas A. Bassett1* Nicholas A. Bassett (admitted *pro hac vice*) PAUL HASTINGS LLP 2050 M Street NW Washington, D.C., 20036 (202) 551-1902 nicholasbassett@paulhastings.com\n\n*and*\n\nAvram E. Luft (admitted *pro hac vice*) G. Alexander Bongartz (admitted *pro hac vice*) PAUL HASTINGS LLP 200 Park Avenue New York, New York 10166 (212) 318-6079 aviluft@paulhastings.com alexbongartz@paulhastings.com\n\n *and*\n\nDouglas 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<sup>1</sup> As to everything except Defendants' Position.\n\nNew York, New York\n\nDated: October 27, 2023 GREENWICH LAND, LLC and HING CHI NGOK\n\n By: */s/ Christopher J. Major*<sup>3</sup>  Christopher J. Major, Esq. Austin D. Kim, Esq. Michael B. Sloan, Esq. MEISTER SEELING & FEIN PLLC 125 Park Avenue, 7th Floor New York, NY 10017 Tel: (212) 655-3500 Email: cjm@msf-law.com adk@msf-law.com msloan@msf-law.com\n\n*Counsel for the Defendants*\n\n<sup>3</sup> As to Defendants' Statement only.\n\n# **EXHIBIT A**\n\n<span id=\"page-9-0\"></span>**TAB 1**\n\n![](_page_9_Picture_2.jpeg)\n\n**373 Taconic Road, Greenwich, CT – January 16, 2022[1](#page-9-0)**\n\n<sup>1</sup> *See* Kwok January 16, 2022 livestream at [http](http) posted by account Guo Wengui. Tab 29 of the exhibit to the Trustee's Emergency Motion shows the wall fixture in the Taconic Property on May 16, 2020, and Tab 39 show the wall fixture in the Mahwah Mansion on September 1, 2023.\n\n<span id=\"page-10-0\"></span>**TAB 2**\n\n![](_page_10_Picture_2.jpeg)\n\n# **373 Taconic Road, Greenwich, CT – January 18, 2022[2](#page-10-0)**\n\n <sup>2</sup> *See* Kwok January 18, 2022 livestream at [http](http) posted by account Guo Wengui on January 19, 2022. Tab <sup>28</sup> of the exhibit to the Trustee's Emergency Motion shows the wooden table and blue desk in the Taconic Property on March 27, 2020. Tab 31 shows the blue desk in the Taconic Property on February 26, 2021. Tab 26 shows the blue desk in the Mahwah Mansion on September 1, 2023, and Tab 38 shows the wooden table in the Mahwah Mansion on September 1, 2023.","body_zh":null,"key_entities":["Kwok","Guo","Ho Wan Kwok","Despins","Paul Hastings","Miles Guo"],"ecf_references":[],"word_count":1896,"status":"published","published_at":null,"created_at":null,"updated_at":"2026-07-07 08:02:35"}