{"id":"court_ctb_2320_0","court":"CTB","case_no":"22-50073","doc_number":2320,"sub_number":0,"doc_type":"ORDER","filed_date":"2023-11-09","title":"IN THE UNITED STATES BANKRUPTCY COURT FOR THE DISTRICT OF CONNECTICUT In re:","summary_zh":null,"summary_en":null,"body_en":"# **IN THE UNITED STATES BANKRUPTCY COURT FOR THE DISTRICT OF CONNECTICUT**\n\nIn re:\n\nHO WAN KWOK, *et al.*,\n\nDebtors.\n\nChapter 11\n\nCase No. 22-50073 (JAM)\n\n(Jointly Administered)\n\n# **G CLUB OPERATIONS LLC'S LIMITED OBJECTION TO EIGHTH 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 RELEVANT BANKS**\n\nG Club Operations LLC (\"G Club\") objects to the *Eighth 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 Relevant Banks* [Dkt. No. 2304] (the \"Motion\") to the extent it proposes to issue subpoenas (the \"Subpoenas\") for the personal financial information of one individual – Andrew Childe – a Director of G Club's independent Manager who only became the Manager after June 1, 2023. Put simply, the wholesale request for this individual's personal financial information is irrelevant; extends beyond the boundaries of Rule 2004 examinations; and is unnecessary and harassing. This individual, therefore, should be stricken from the Subpoenas.<sup>1</sup>\n\n# **Summary of Position**\n\nUnder the guise of seeking Rule 2004 Discovery regarding \"Additional Relevant Banks,\" the Trustee – as is typical – seeks much more. As it relates to this Limited Objection, he seeks, among other broad requests, \"[a]ll Documents related to *any account held by, controlled by, on*\n\n<sup>1</sup> Counsel to G Club represents Mr. Childe in the context of his role as Manager of G Club, and not in his individual capacity. Counsel to G Club makes this Limited Objection because G Club cannot be isolated from discovery addressed to Mr. Childe and does so without in any way waiving or affecting any of his individual rights, including with respect to service.\n\n*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.\" (*See* Ex. A, Subpoenas, Request No. 1) (emphasis added). The Trustee then ties all demands to a list of more than 120 \"Discovery Targets\" which not only include entities but also numerous individuals without any explanation for the basis of their inclusion as \"Discovery Targets.\" Egregiously, the Trustee, for the first time, includes Andrew Childe, a Director of G Club's independent manager, FFP (BVI) Limited among the Discovery Targets, even though Mr. Childe only became affiliated with G Club after June 1, 2023, and through his and his team's work with counsel, G Club has produced more than 140,000 documents in response to the Trustee's never-ending Rule 2004 and other discovery requests directed to G Club. Notably, the list of more than 120 \"Discovery Targets\" includes many other individuals, some which appear to be attorneys, and, thus, seeks their personal financial information as well.\n\nThe Motion and Subpoenas lack any explanation as to why unfettered information about *personal bank accounts* associated with this individual – or any other individual – is needed or appropriate. To include Mr. Childe as one of hundreds of \"Discovery Targets,\" relying on the undifferentiated broad-brush strokes being used by the Trustee to paint multiple entities as the Debtor's \"alter ego,\" exceeds the broad scope of Rule 2004 and is harassment. Accordingly, G Club moves to strike Mr. Childe from the list of \"Discovery Targets.\"\n\n# **RELEVANT FACTIONAL BACKGROUND**\n\n1. On November 2, 2023, the Trustee filed the Motion, seeking eight more Subpoenas because he has \"identified more entities with possible knowledge of the Debtor's assets and financial activities.\" Mot. ¶ 2. The Motion follows seven other omnibus motions seeking the\n\nissuance of more than 100 Rule 2004 Subpoenas to \"targets\" all because of their \"possible knowledge.\"\n\n2. The Subpoenas attached to the Motion contain a definition called \"2004 Discovery Targets,\" listing over 120 entities and persons. Mr. Childe, a Director of FFP, is included in the definition. No explanation for the inclusion of any of these entities – and individuals in particular – was included in the Motion.\n\n3. FFP (BVI) Limited, together with its affiliated entities (\"FFP\") is an independent fiduciary and corporate services business in the Cayman Islands and British Virgin Islands. (*See* Ex. B, FFP Company Information). FFP is regulated and supervised by the Cayman Island Monetary Authority and the BVI Financial Services Commission. *Id.* The FFP team is comprised of accountants, insolvency practitioners, lawyers, trustees, and directors who have experience in managing companies, often stepping in to replace a general partner, managing member, director, liquidator, trustee, or receiver. *Id.* As a Director of FFP, Mr. Childe has held numerous professional roles, including roles analogous to a chief restructuring officer. In addition, Mr. Childe regularly acts as a Court Supervised Liquidator in the Cayman Islands, the British Virgin Islands and Bermuda, and as a Foreign Representative in chapter 15 and similar cross-border cases around the world and as a Director in various structures around the world. Most recently, Mr. Childe was appointed as the Court appointed liquidator of Silicon Valley Bank Cayman Branch involving over \\$800 million of assets.\n\n4. On June 1, 2023, FFP was appointed to serve as the independent manager of G Club after the former Chief Executive Officer, General Counsel, and Assistant General Counsel\n\nresigned. Mr. Childe, as a Director of FFP and an independent fiduciary, together with his team, are handling the day-to-day operations of G Club. *Id.* <sup>2</sup>\n\n# **ARGUMENT**\n\n5. The Trustee is entitled to seek discovery about the Debtor, but there is no basis for the Trustee to seek discovery unrelated to the Debtor just because it relates to someone the Debtor may or may not know. The Motion seeks discovery from eight financial institutions, claiming that \"at least one Debtor-related entity…maintained one or more account(s) at each of these banks.\" Mot. ¶ 9. However, the Trustee's suggested threshold for \"Debtor-related entity\" is so low so as to be effectively limitless.\n\n6. It is black letter law that \"Rule 2004 examinations . . . may not be used for the purposes of abuse or harassment, and cannot stray into matters not relevant to the basic inquiry.\" *In re Orion Healthcorp, Inc.*, 596 B.R. 228, 235 (Bankr. E.D.N.Y. 2019)) (quotations omitted). Moreover, courts consistently acknowledge that \"[i]t is clear that Rule 2004 may not be used as a device to launch into a wholesale investigation of a non-debtor's private business affairs.\" *In re Kearney*, 590 B.R. 913, 921 (Bankr. D. N.M. 2018) (*quoting Matter of Wilcher*, 56 B.R. 428, 434 (Bankr. N.D. Ill. 1985) (collecting cases).\n\n7. That is precisely the situation here. The Trustee has not set forth any factual or legal basis to pry into the personal affairs of Mr. Childe. Indeed, the Trustee strays \"into matters\n\n<sup>2</sup> The Trustee has recently filed a *Ninth 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 and Entities Doing Business With Debtor* [Dkt. No. 2308] (the \"Ninth Motion\"). In the Ninth Motion, the Trustee has exaggerated Mr. Childe's role by alleging that: \"Andrew Childe serves as director of certain G-Club Related Entities, certain of which entities 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.\" The Ninth Motion, ¶ 9(b)(ii) (internal quotations omitted). Counsel to G Club will also be filing an objection to the Ninth Motion by the stated deadline of November 13, 2023, but for now, suffice it to say, Mr. Childe's role is limited to managing G Club post June 1, 2023. Any information that Mr. Childe has is either not contemporaneous to any events related to the Trustee's \"investigation\" and/or is protected by attorney-client privilege or attorney work product privilege.\n\nnot relevant to the basic inquiry,\" seeking documents related to Mr. Childe's personal bank accounts (Subpoenas Request Nos. 1 and 6), his personal property and assets (Subpoenas Request No. 2), his personal loans and other financial transactions (Subpoenas Request No. 3), their personal wire transfer activities (Subpoenas Request No. 4), his personal correspondence with any financial institution (Subpoenas Request No. 5), and regulatory activity relating to him individually (Subpoenas Request Nos. 7 and 8). None of this personal information is relevant to the Debtor's assets.\n\n8. The inclusion of Mr. Childe is exceptionally offensive and nonsensical because, among other reasons:\n\n- FFP was appointed independent manager of G Club on June 1, 2023, well after the Debtor filed for bankruptcy and the appointment of the Trustee, after the formation of G Club, and significantly after any Debtors' transactions that the Trustee seeks to analyze.\n- Mr. Childe is a highly respected, internationally known, restructuring professional, who, among other things, has been appointed by courts around the world to fiduciary roles.\n- And, the Motion effectively seeks to punish Mr. Childe for doing his job, which has involved, in large part, working with counsel to ensure that the Trustee has received, and will continue to receive, relevant and not-privileged G Club documents responsive to the Trustee's pre-existing discovery responses.\n\n9. Moreover, any information Mr. Childe possesses relevant to the Trustee's purported reasons for these examinations as set forth in the Motion belongs to G Club, and G Club has complied with the Trustee's Rule 2004 demands and already produced in excess of 140,000\n\ndocuments to the Trustee. To be clear, G Club does not object to *G Club*'s inclusion among the Rule 2004 Discovery Targets, but firmly objects to irrelevant and harassing discovery of Mr. Childe.\n\n10. Where a Rule 2004 examination goes beyond its purpose as an investigatory device arising out of the needs of the trustee, \"it should be carefully scrutinized.\" *In re J&R Trucking, Inc.*, 431 B.R. 818, 822 (Bankr. N.D. Ind. 2010). The Motion requires this scrutiny, and it fails under it. The Motion seeks discovery into the personal affairs of an individual who at most has a business relationship with G Club as of June 1, 2023, and where G Club already is responding to discovery.\n\n11. Under these circumstances, there is no justified basis to permit expansive discovery from Mr. Childe of his personal financial data. This kind of discovery, in the absence of compelling reasons which are absent here, is harassing, by definition. Accordingly, G Club seeks the exclusion of Mr. Childe from the Motion and the Subpoenas.\n\n# **RELIEF REQUESTED**\n\n12. G Club respectfully requests that the name of Andrew Childe be stricken from each of the Subpoenas attached to the Motion.\n\nDated: November 9, 2023 New York, New York\n\n> By: */s/Kellianne Baranowsky* GREEN & SKLARZ LLC Jeffrey M. Sklarz Kellianne Baranowsky One Audobon St, 3rd Floor New Haven, CT 06511 Tel: 203-285-8545 jsklarz@gs-lawfirm.com kbaranowsky@gs-lawfirm.com\n\n> > PILLSBURY WINTHROP SHAW PITTMAN LLP Carolina A. Fornos (*pro hac vice*) 31 West 52nd Street New York, NY 10019 Tel: 212-858-1558 carolina.fornos@pillsburylaw.com\n\n*Attorneys for G Club Operations LLC*\n\n# **CERTIFICATE OF SERVICE**\n\nI hereby certify that on the date set forth below, a copy of the foregoing was served via CM/ECF. Parties may access this filing through the Court's CM/ECF system.\n\nDate: November 9, 2023.\n\n*/s/ Kellianne Baranowsky* Kellianne Baranowsky\n\nCase 22-50073 Doc 2320 Filed 11/09/23 Entered 11/09/23 16:05:58 Page 9 of 148\n\n# EXHIBIT A\n\n# Exhibit C-1\n\n#### B2540 (Form 2540 – Subpoena for Rule 2004 Examination) (12/15) UNITED STATES BANKRUPTCY COURT Case 22-50073 Doc 2304 Filed 11/02/23 Entered 11/02/23 15:07:07 Page 18 of 152 2320 11/09/23 11/09/23 16:05:58 11 148\n\n\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_ District of \\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\n\nIn re \\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\n\nDebtor\n\nCase No. \\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\n\nChapter \\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\n\n# **SUBPOENA FOR RULE 2004 EXAMINATION**\n\nTo: **\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_**\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|       |               |\n|       |               |\n|       |               |\n\nThe examination will be recorded by this method: \\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\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\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: \\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\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 *(name of party)* \\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_ , who issues or requests this subpoena, are:\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\n|  | Case 22-50073 | Doc 2304<br>2320                                                | Filed 11/02/23<br>11/09/23 | Entered 11/02/23 15:07:07<br>11/09/23 16:05:58 | Page 19 of<br>12 |\n|--|---------------|-----------------------------------------------------------------|----------------------------|------------------------------------------------|------------------|\n|  |               | B2540 (Form 2540 – Subpoena for Rule 2004 Examination) (Page 2) | 152<br>148                 |                                                |                  |\n|  |               |                                                                 |                            |                                                |                  |\n\n| on (date)<br>__________            |                                                                | I received this subpoena for (name of individual and title, if any): ______________________________________________                                                                                                                                                                                  |\n|------------------------------------|----------------------------------------------------------------|------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|\n|                                    | I served the subpoena by delivering a copy to the named person | as follows: ____________________________________                                                                                                                                                                                                                                                     |\n| __________________________________ | on (date) ___________________ ; or                             | ___________________________________________________________________________________________________                                                                                                                                                                                                  |\n|                                    |                                                                | I returned the subpoena unexecuted because: ____________________________________________________________                                                                                                                                                                                             |\n|                                    |                                                                | ___________________________________________________________________________________________________                                                                                                                                                                                                  |\n|                                    |                                                                |                                                                                                                                                                                                                                                                                                      |\n| My fees are \\$ _________           | for travel and \\$_________                                     | Unless the subpoena was issued on behalf of the United States, or one of its officers or agents, I have also tendered to the<br>witness the fees for one day's attendance, and the mileage allowed by law, in the amount of \\$ _______________________ .<br>for services, for a total of \\$_________ |\n| I declare under penalty of perjury | that this information is true and correct.                     |                                                                                                                                                                                                                                                                                                      |\n|                                    |                                                                |                                                                                                                                                                                                                                                                                                      |\n| Date: _______________              |                                                                | ________________________________________________<br>Server's signature<br>________________________________________________                                                                                                                                                                           |\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; (ii) requires a person to comply beyond the geographical limits\n\nspecified in Rule 45(c); (iii) requires disclosure of privileged or other protected matter, if no\n\nexception 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:\n\n(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 trialpreparation 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\n## Case 22-50073 Doc 2304 Filed 11/02/23 Entered 11/02/23 15:07:07 Page 22 of 152 2320 11/09/23 11/09/23 16:05:58 15 148\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 2304 Filed 11/02/23 Entered 11/02/23 15:07:07 Page 23 of 152 2320 11/09/23 11/09/23 16:05:58 16 148\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 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 2304 Filed 11/02/23 Entered 11/02/23 15:07:07 Page 24 of 152 2320 11/09/23 11/09/23 16:05:58 17 148\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 2304 Filed 11/02/23 Entered 11/02/23 15:07:07 Page 25 of 152 2320 11/09/23 11/09/23 16:05:58 18 148\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 2304 Filed 11/02/23 Entered 11/02/23 15:07:07 Page 26 of 152 2320 11/09/23 11/09/23 16:05:58 19 148\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 2304 Filed 11/02/23 Entered 11/02/23 15:07:07 Page 27 of 152 2320 11/09/23 11/09/23 16:05:58 20 148\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 Banco Popular de Puerto Rico. 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 2304 Filed 11/02/23 Entered 11/02/23 15:07:07 Page 28 of 152 2320 11/09/23 11/09/23 16:05:58 21 148\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, 17 Miles, LLC, 5780 Saguaro LLC, ACA Capital Group Limited, Ace Decade Holdings Limited, AI Group Holdings Inc., Ana C. Izquiedo-Henn, Andrew Childe, Booming Sail New York LLC, Bingshang Jiao, Bravo Luck Limited, Brent Petro Inc., Chris Lee (a/k/a Nan Li, Mei Guo Xiao Li), Crane Advisory Group, Daniel Thomas Podhaskie, Defeng Cao (a/k/a Wayne Cao, Max Cao), Ding \"Ivan\" Lin, Doaa Dashoush, Eastern Profit Corporation Limited, Genever Holdings Corporation, Genever Holdings LLC, Gettr USA, Inc., Gnews Media Group Inc., G Fashion Hold Co. B. Limited, G Fashion International Limited, G Fashion LLC, Gmusic LLC, Gnews LLC, Geducation, GFNY, Inc., G Club Finance, G Club HoldCo I LLC, G Club International Limited, G Club Investments Limited, G Club Operations LLC, G Club US\n\n#### Case 22-50073 Doc 2304 Filed 11/02/23 Entered 11/02/23 15:07:07 Page 29 of 152 2320 11/09/23 11/09/23 16:05:58 22 148\n\nOperations Inc., G Club US Operations LLC, G Club One, G Club Two, G Club Three, G Live, LLC, Gbroadcast, LLC, GM 27 LLC, Gladys Chow, Golden Spring (New York) Ltd., Gposts LLC, GTV Media Group, Inc., Gypsy Mei Food Service LLC, Gypsy Mei Productions LLC, Gypsy Mei 27 Vestry, Inc., Dawn State Limited, Greenwich Land LLC, Hao (Gavin) Li (a/k/a Huo Lai), Hamilton Capital Holdings Inc., GS Security Solutions Inc., Han Chunguang, Haoran He, HCHK Property Management, Inc., HCHK Technologies, Inc., HK International Funds Investments (USA) Limited LLC, Freedom Media Ventures Ltd., FungWan Trading Inc., Himalaya New World Inc., Himalaya International Financial Group Ltd., Himalaya International Clearing Ltd., Himalaya International Payments Ltd., Himalaya International Reserves Ltd., Himalaya Ventures LLC, Himalaya Investment LLC, Hudson Diamond Holding, Inc., Hudson Diamond Holding LLC, Hudson Diamond NY LLC, Huk Trading Inc., Infinity Treasury Management Inc., Jesse Brown, Jiaming Liu, Jie Zhang, Jovial Century International Limited, Joyord Sportswear Limited, Kamel Debeche, Karin Maistrello, Lamp Capital LLC, Leading Shine NY Ltd., Lexington Property and Staffing, Inc., Linwan \"Irene\" Feng, Limarie Reyes, Lihong \"Sara\" Wei Lafrenz, The Lost Draft LLC, Macaron Limited, Mary Jiang, MOS Himalaya LLC, Maywind Trading LLC, New York MOS Himalaya LLC, Nicholas Savio, Nodal Partners, LLC, Oasis Tech Limited, Pixshow Film Inc., Qu Guo Jiao, Roscalitar 2, Ridwan Mamode Saib, Ross Heinemeyer, Rule of Law Society IV Inc., Rule of Law Foundation III, Inc., Rule of Law Fund, Saraca Media Group Inc., Savio Law LLC, Scott Barnett, Shih Hsin Yu, Sirius Networking Inc., US Himalaya Capital Inc., V.X. Cerda & Associates P.A., Victor Cerda, Voice of Guo Media, Inc., Wen Xiao, Wencong Wang, William Je, Yinying (Aila) Wang (a/k/a Xiao Fei Xiang), Yongbing Zhang, Yongping Yan (Shan Mu) Yue Zhou, Yumei Hao (a/k/a Ru Shui), Yvette Wang (a/k/a Yanping Wang, a/k/a Yan Ping Wang), Zhixuan Li, and Zhouer \"Joe\" Wang.\n\n#### Case 22-50073 Doc 2304 Filed 11/02/23 Entered 11/02/23 15:07:07 Page 30 of 152 2320 11/09/23 11/09/23 16:05:58 23 148\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 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\n\n#### Case 22-50073 Doc 2304 Filed 11/02/23 Entered 11/02/23 15:07:07 Page 31 of 152 2320 11/09/23 11/09/23 16:05:58 24 148\n\nto, 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, 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\n\n#### Case 22-50073 Doc 2304 Filed 11/02/23 Entered 11/02/23 15:07:07 Page 32 of 152 2320 11/09/23 11/09/23 16:05:58 25 148\n\nis 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, 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\n\n#### Case 22-50073 Doc 2304 Filed 11/02/23 Entered 11/02/23 15:07:07 Page 33 of 152 2320 11/09/23 11/09/23 16:05:58 26 148\n\nstatements, 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, Hong Kong Securities and Futures Commission, and the Hong Kong Monetary Authority relating to any of the 2004 Discovery Targets.\n\n# Exhibit C-2\n\n#### B2540 (Form 2540 – Subpoena for Rule 2004 Examination) (12/15) UNITED STATES BANKRUPTCY COURT Case 22-50073 Doc 2304 Filed 11/02/23 Entered 11/02/23 15:07:07 Page 35 of 152 2320 11/09/23 11/09/23 16:05:58 28 148\n\n\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_ District of \\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\n\nIn re \\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\n\nDebtor\n\nCase No. \\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\n\nChapter \\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\n\n# **SUBPOENA FOR RULE 2004 EXAMINATION**\n\nTo: **\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_**\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|       |               |\n|       |               |\n\nThe examination will be recorded by this method: \\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\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\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: \\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\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 *(name of party)* \\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_ , who issues or requests this subpoena, are:\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\n|  | Case 22-50073 | Doc 2304<br>2320                                                | Filed 11/02/23<br>11/09/23 | Entered 11/02/23 15:07:07<br>11/09/23 16:05:58 | Page 36 of<br>29 |\n|--|---------------|-----------------------------------------------------------------|----------------------------|------------------------------------------------|------------------|\n|  |               | B2540 (Form 2540 – Subpoena for Rule 2004 Examination) (Page 2) | 152<br>148                 |                                                |                  |\n|  |               |                                                                 |                            |                                                |                  |\n\n| on (date)<br>__________                                        |                                            | I received this subpoena for (name of individual and title, if any): ______________________________________________                                                                                                                                                                                  |\n|----------------------------------------------------------------|--------------------------------------------|------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|\n| I served the subpoena by delivering a copy to the named person |                                            | as follows: ____________________________________<br>___________________________________________________________________________________________________                                                                                                                                              |\n| __________________________________                             | on (date) ___________________ ; or         |                                                                                                                                                                                                                                                                                                      |\n|                                                                |                                            | I returned the subpoena unexecuted because: ____________________________________________________________                                                                                                                                                                                             |\n|                                                                |                                            | ___________________________________________________________________________________________________                                                                                                                                                                                                  |\n| My fees are \\$ _________                                       | for travel and \\$_________                 | Unless the subpoena was issued on behalf of the United States, or one of its officers or agents, I have also tendered to the<br>witness the fees for one day's attendance, and the mileage allowed by law, in the amount of \\$ _______________________ .<br>for services, for a total of \\$_________ |\n| I declare under penalty of perjury                             | that this information is true and correct. |                                                                                                                                                                                                                                                                                                      |\n|                                                                |                                            |                                                                                                                                                                                                                                                                                                      |\n| Date: _______________                                          |                                            | ________________________________________________<br>Server's signature<br>________________________________________________                                                                                                                                                                           |\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; (ii) requires a person to comply beyond the geographical limits\n\nspecified in Rule 45(c); (iii) requires disclosure of privileged or other protected matter, if no\n\nexception 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:\n\n(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 trialpreparation 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\n## Case 22-50073 Doc 2304 Filed 11/02/23 Entered 11/02/23 15:07:07 Page 39 of 152 2320 11/09/23 11/09/23 16:05:58 32 148\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 2304 Filed 11/02/23 Entered 11/02/23 15:07:07 Page 40 of 152 2320 11/09/23 11/09/23 16:05:58 33 148\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<br>Smith, John |                          | Email: Mailbox where the email resided           |  |  |\n|                          |                          | Native: Name of the individual or department     |  |  |\n|                          |                          | from whose files the document 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 2304 Filed 11/02/23 Entered 11/02/23 15:07:07 Page 41 of 152 2320 11/09/23 11/09/23 16:05:58 34 148\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 2304 Filed 11/02/23 Entered 11/02/23 15:07:07 Page 42 of 152 2320 11/09/23 11/09/23 16:05:58 35 148\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 2304 Filed 11/02/23 Entered 11/02/23 15:07:07 Page 43 of 152 2320 11/09/23 11/09/23 16:05:58 36 148\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 2304 Filed 11/02/23 Entered 11/02/23 15:07:07 Page 44 of 152 2320 11/09/23 11/09/23 16:05:58 37 148\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 City National 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 2304 Filed 11/02/23 Entered 11/02/23 15:07:07 Page 45 of 152 2320 11/09/23 11/09/23 16:05:58 38 148\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, 17 Miles, LLC, 5780 Saguaro LLC, ACA Capital Group Limited, Ace Decade Holdings Limited, AI Group Holdings Inc., Ana C. Izquiedo-Henn, Andrew Childe, Booming Sail New York LLC, Bingshang Jiao, Bravo Luck Limited, Brent Petro Inc., Chris Lee (a/k/a Nan Li, Mei Guo Xiao Li), Crane Advisory Group, Daniel Thomas Podhaskie, Defeng Cao (a/k/a Wayne Cao, Max Cao), Ding \"Ivan\" Lin, Doaa Dashoush, Eastern Profit Corporation Limited, Genever Holdings Corporation, Genever Holdings LLC, Gettr USA, Inc., Gnews Media Group Inc., G Fashion Hold Co. B. Limited, G Fashion International Limited, G Fashion LLC, Gmusic LLC, Gnews LLC, Geducation, GFNY, Inc., G Club Finance, G Club HoldCo I LLC, G Club International Limited, G Club Investments Limited, G Club Operations LLC, G Club US\n\n#### Case 22-50073 Doc 2304 Filed 11/02/23 Entered 11/02/23 15:07:07 Page 46 of 152 2320 11/09/23 11/09/23 16:05:58 39 148\n\nOperations Inc., G Club US Operations LLC, G Club One, G Club Two, G Club Three, G Live, LLC, Gbroadcast, LLC, GM 27 LLC, Gladys Chow, Golden Spring (New York) Ltd., Gposts LLC, GTV Media Group, Inc., Gypsy Mei Food Service LLC, Gypsy Mei Productions LLC, Gypsy Mei 27 Vestry, Inc., Dawn State Limited, Greenwich Land LLC, Hao (Gavin) Li (a/k/a Huo Lai), Hamilton Capital Holdings Inc., GS Security Solutions Inc., Han Chunguang, Haoran He, HCHK Property Management, Inc., HCHK Technologies, Inc., HK International Funds Investments (USA) Limited LLC, Freedom Media Ventures Ltd., FungWan Trading Inc., Himalaya New World Inc., Himalaya International Financial Group Ltd., Himalaya International Clearing Ltd., Himalaya International Payments Ltd., Himalaya International Reserves Ltd., Himalaya Ventures LLC, Himalaya Investment LLC, Hudson Diamond Holding, Inc., Hudson Diamond Holding LLC, Hudson Diamond NY LLC, Huk Trading Inc., Infinity Treasury Management Inc., Jesse Brown, Jiaming Liu, Jie Zhang, Jovial Century International Limited, Joyord Sportswear Limited, Kamel Debeche, Karin Maistrello, Lamp Capital LLC, Leading Shine NY Ltd., Lexington Property and Staffing, Inc., Linwan \"Irene\" Feng, Limarie Reyes, Lihong \"Sara\" Wei Lafrenz, The Lost Draft LLC, Macaron Limited, Mary Jiang, MOS Himalaya LLC, Maywind Trading LLC, New York MOS Himalaya LLC, Nicholas Savio, Nodal Partners, LLC, Oasis Tech Limited, Pixshow Film Inc., Qu Guo Jiao, Roscalitar 2, Ridwan Mamode Saib, Ross Heinemeyer, Rule of Law Society IV Inc., Rule of Law Foundation III, Inc., Rule of Law Fund, Saraca Media Group Inc., Savio Law LLC, Scott Barnett, Shih Hsin Yu, Sirius Networking Inc., US Himalaya Capital Inc., V.X. Cerda & Associates P.A., Victor Cerda, Voice of Guo Media, Inc., Wen Xiao, Wencong Wang, William Je, Yinying (Aila) Wang (a/k/a Xiao Fei Xiang), Yongbing Zhang, Yongping Yan (Shan Mu) Yue Zhou, Yumei Hao (a/k/a Ru Shui), Yvette Wang (a/k/a Yanping Wang, a/k/a Yan Ping Wang), Zhixuan Li, and Zhouer \"Joe\" Wang.\n\n#### Case 22-50073 Doc 2304 Filed 11/02/23 Entered 11/02/23 15:07:07 Page 47 of 152 2320 11/09/23 11/09/23 16:05:58 40 148\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 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\n\n#### Case 22-50073 Doc 2304 Filed 11/02/23 Entered 11/02/23 15:07:07 Page 48 of 152 2320 11/09/23 11/09/23 16:05:58 41 148\n\nto, 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, 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\n\n#### Case 22-50073 Doc 2304 Filed 11/02/23 Entered 11/02/23 15:07:07 Page 49 of 152 2320 11/09/23 11/09/23 16:05:58 42 148\n\nis 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, 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\n\n#### Case 22-50073 Doc 2304 Filed 11/02/23 Entered 11/02/23 15:07:07 Page 50 of 152 2320 11/09/23 11/09/23 16:05:58 43 148\n\nstatements, 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, Hong Kong Securities and Futures Commission, and the Hong Kong Monetary Authority relating to any of the 2004 Discovery Targets.\n\n# Exhibit C-3\n\n#### B2540 (Form 2540 – Subpoena for Rule 2004 Examination) (12/15) UNITED STATES BANKRUPTCY COURT Case 22-50073 Doc 2304 Filed 11/02/23 Entered 11/02/23 15:07:07 Page 52 of 152 2320 11/09/23 11/09/23 16:05:58 45 148\n\n\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_ District of \\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\n\nIn re \\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\n\nDebtor\n\nCase No. \\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\n\nChapter \\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\n\n# **SUBPOENA FOR RULE 2004 EXAMINATION**\n\nTo: **\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_**\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|       |               |\n|       |               |\n|       |               |\n\nThe examination will be recorded by this method: \\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\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\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: \\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\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 *(name of party)* \\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_ , who issues or requests this subpoena, are:\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\n| Case 22-50073                                                   | Doc 2304<br>2320 | Filed 11/02/23<br>11/09/23 | Entered 11/02/23 15:07:07<br>11/09/23 16:05:58 | Page 53 of<br>46 |\n|-----------------------------------------------------------------|------------------|----------------------------|------------------------------------------------|------------------|\n| B2540 (Form 2540 – Subpoena for Rule 2004 Examination) (Page 2) |                  | 152<br>148                 |                                                |                  |\n|                                                                 |                  |                            |                                                |                  |\n\n| on (date)<br>__________            |                                                                | I received this subpoena for (name of individual and title, if any): ______________________________________________                                                                                                                                                                                  |\n|------------------------------------|----------------------------------------------------------------|------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|\n|                                    | I served the subpoena by delivering a copy to the named person | as follows: ____________________________________                                                                                                                                                                                                                                                     |\n| __________________________________ | on (date) ___________________ ; or                             | ___________________________________________________________________________________________________                                                                                                                                                                                                  |\n|                                    |                                                                | I returned the subpoena unexecuted because: ____________________________________________________________                                                                                                                                                                                             |\n|                                    |                                                                | ___________________________________________________________________________________________________                                                                                                                                                                                                  |\n|                                    |                                                                |                                                                                                                                                                                                                                                                                                      |\n| My fees are \\$ _________           | for travel and \\$_________                                     | Unless the subpoena was issued on behalf of the United States, or one of its officers or agents, I have also tendered to the<br>witness the fees for one day's attendance, and the mileage allowed by law, in the amount of \\$ _______________________ .<br>for services, for a total of \\$_________ |\n| I declare under penalty of perjury | that this information is true and correct.                     |                                                                                                                                                                                                                                                                                                      |\n|                                    |                                                                |                                                                                                                                                                                                                                                                                                      |\n| Date: _______________              |                                                                | ________________________________________________<br>Server's signature<br>________________________________________________                                                                                                                                                                           |\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; (ii) requires a person to comply beyond the geographical limits\n\nspecified 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:\n\n(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 trialpreparation 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\n## Case 22-50073 Doc 2304 Filed 11/02/23 Entered 11/02/23 15:07:07 Page 56 of 152 2320 11/09/23 11/09/23 16:05:58 49 148\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 2304 Filed 11/02/23 Entered 11/02/23 15:07:07 Page 57 of 152 2320 11/09/23 11/09/23 16:05:58 50 148\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 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 2304 Filed 11/02/23 Entered 11/02/23 15:07:07 Page 58 of 152 2320 11/09/23 11/09/23 16:05:58 51 148\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|              |                           |                                                 |\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 2304 Filed 11/02/23 Entered 11/02/23 15:07:07 Page 59 of 152 2320 11/09/23 11/09/23 16:05:58 52 148\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 2304 Filed 11/02/23 Entered 11/02/23 15:07:07 Page 60 of 152 2320 11/09/23 11/09/23 16:05:58 53 148\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 2304 Filed 11/02/23 Entered 11/02/23 15:07:07 Page 61 of 152 2320 11/09/23 11/09/23 16:05:58 54 148\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 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\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 2304 Filed 11/02/23 Entered 11/02/23 15:07:07 Page 62 of 152 2320 11/09/23 11/09/23 16:05:58 55 148\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, 17 Miles, LLC, 5780 Saguaro LLC, ACA Capital Group Limited, Ace Decade Holdings Limited, AI Group Holdings Inc., Ana C. Izquiedo-Henn, Andrew Childe, Booming Sail New York LLC, Bingshang Jiao, Bravo Luck Limited, Brent Petro Inc., Chris Lee (a/k/a Nan Li, Mei Guo Xiao Li), Crane Advisory Group, Daniel Thomas Podhaskie, Defeng Cao (a/k/a Wayne Cao, Max Cao), Ding \"Ivan\" Lin, Doaa Dashoush, Eastern Profit Corporation Limited, Genever Holdings Corporation, Genever Holdings LLC, Gettr USA, Inc., Gnews Media Group Inc., G Fashion Hold Co. B. Limited, G Fashion International Limited, G Fashion LLC, Gmusic LLC, Gnews LLC, Geducation, GFNY, Inc., G Club Finance, G Club HoldCo I LLC, G Club International Limited, G Club Investments Limited, G Club Operations LLC, G Club US Operations Inc., G Club US Operations LLC, G Club One, G Club Two, G Club Three, G Live, LLC, Gbroadcast, LLC, GM 27 LLC, Gladys Chow, Golden Spring (New York) Ltd., Gposts LLC, GTV Media Group, Inc., Gypsy Mei Food Service LLC, Gypsy Mei Productions LLC, Gypsy Mei\n\n#### Case 22-50073 Doc 2304 Filed 11/02/23 Entered 11/02/23 15:07:07 Page 63 of 152 2320 11/09/23 11/09/23 16:05:58 56 148\n\n27 Vestry, Inc., Dawn State Limited, Greenwich Land LLC, Hao (Gavin) Li (a/k/a Huo Lai), Hamilton Capital Holdings Inc., GS Security Solutions Inc., Han Chunguang, Haoran He, HCHK Property Management, Inc., HCHK Technologies, Inc., HK International Funds Investments (USA) Limited LLC, Freedom Media Ventures Ltd., FungWan Trading Inc., Himalaya New World Inc., Himalaya International Financial Group Ltd., Himalaya International Clearing Ltd., Himalaya International Payments Ltd., Himalaya International Reserves Ltd., Himalaya Ventures LLC, Himalaya Investment LLC, Hudson Diamond Holding, Inc., Hudson Diamond Holding LLC, Hudson Diamond NY LLC, Huk Trading Inc., Infinity Treasury Management Inc., Jesse Brown, Jiaming Liu, Jie Zhang, Jovial Century International Limited, Joyord Sportswear Limited, Kamel Debeche, Karin Maistrello, Lamp Capital LLC, Leading Shine NY Ltd., Lexington Property and Staffing, Inc., Linwan \"Irene\" Feng, Limarie Reyes, Lihong \"Sara\" Wei Lafrenz, The Lost Draft LLC, Macaron Limited, Mary Jiang, MOS Himalaya LLC, Maywind Trading LLC, New York MOS Himalaya LLC, Nicholas Savio, Nodal Partners, LLC, Oasis Tech Limited, Pixshow Film Inc., Qu Guo Jiao, Roscalitar 2, Ridwan Mamode Saib, Ross Heinemeyer, Rule of Law Society IV Inc., Rule of Law Foundation III, Inc., Rule of Law Fund, Saraca Media Group Inc., Savio Law LLC, Scott Barnett, Shih Hsin Yu, Sirius Networking Inc., US Himalaya Capital Inc., V.X. Cerda & Associates P.A., Victor Cerda, Voice of Guo Media, Inc., Wen Xiao, Wencong Wang, William Je, Yinying (Aila) Wang (a/k/a Xiao Fei Xiang), Yongbing Zhang, Yongping Yan (Shan Mu) Yue Zhou, Yumei Hao (a/k/a Ru Shui), Yvette Wang (a/k/a Yanping Wang, a/k/a Yan Ping Wang), Zhixuan Li, and Zhouer \"Joe\" 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\n#### Case 22-50073 Doc 2304 Filed 11/02/23 Entered 11/02/23 15:07:07 Page 64 of 152 2320 11/09/23 11/09/23 16:05:58 57 148\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 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 2304 Filed 11/02/23 Entered 11/02/23 15:07:07 Page 65 of 152 2320 11/09/23 11/09/23 16:05:58 58 148\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, 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\n\n#### Case 22-50073 Doc 2304 Filed 11/02/23 Entered 11/02/23 15:07:07 Page 66 of 152 2320 11/09/23 11/09/23 16:05:58 59 148\n\nuploaded 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, 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\n#### Case 22-50073 Doc 2304 Filed 11/02/23 Entered 11/02/23 15:07:07 Page 67 of 152 2320 11/09/23 11/09/23 16:05:58 60 148\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, Hong Kong Securities and Futures Commission, and the Hong Kong Monetary Authority relating to any of the 2004 Discovery Targets.\n\n# Exhibit C-4\n\n#### B2540 (Form 2540 – Subpoena for Rule 2004 Examination) (12/15) UNITED STATES BANKRUPTCY COURT Case 22-50073 Doc 2304 Filed 11/02/23 Entered 11/02/23 15:07:07 Page 69 of 152 2320 11/09/23 11/09/23 16:05:58 62 148\n\n\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_ District of \\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\n\nIn re \\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\n\nDebtor\n\nCase No. \\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\n\nChapter \\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\n\n# **SUBPOENA FOR RULE 2004 EXAMINATION**\n\nTo: **\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_**\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|       |               |\n|       |               |\n|       |               |\n\nThe examination will be recorded by this method: \\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\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\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: \\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\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 *(name of party)* \\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_ , who issues or requests this subpoena, are:\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\n|  | Case 22-50073 | Doc 2304<br>2320                                                | Filed 11/02/23<br>11/09/23 | Entered 11/02/23 15:07:07<br>11/09/23 16:05:58 | Page 70 of<br>63 |\n|--|---------------|-----------------------------------------------------------------|----------------------------|------------------------------------------------|------------------|\n|  |               | B2540 (Form 2540 – Subpoena for Rule 2004 Examination) (Page 2) | 152<br>148                 |                                                |                  |\n|  |               |                                                                 |                            |                                                |                  |\n\n| on (date)<br>__________            |                                                                | I received this subpoena for (name of individual and title, if any): ______________________________________________                                                                                                                                                                                  |\n|------------------------------------|----------------------------------------------------------------|------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|\n|                                    | I served the subpoena by delivering a copy to the named person | as follows: ____________________________________                                                                                                                                                                                                                                                     |\n| __________________________________ | on (date) ___________________ ; or                             | ___________________________________________________________________________________________________                                                                                                                                                                                                  |\n|                                    |                                                                | I returned the subpoena unexecuted because: ____________________________________________________________                                                                                                                                                                                             |\n|                                    |                                                                | ___________________________________________________________________________________________________                                                                                                                                                                                                  |\n|                                    |                                                                |                                                                                                                                                                                                                                                                                                      |\n| My fees are \\$ _________           | for travel and \\$_________                                     | Unless the subpoena was issued on behalf of the United States, or one of its officers or agents, I have also tendered to the<br>witness the fees for one day's attendance, and the mileage allowed by law, in the amount of \\$ _______________________ .<br>for services, for a total of \\$_________ |\n| I declare under penalty of perjury | that this information is true and correct.                     |                                                                                                                                                                                                                                                                                                      |\n|                                    |                                                                |                                                                                                                                                                                                                                                                                                      |\n| Date: _______________              |                                                                | ________________________________________________<br>Server's signature<br>________________________________________________                                                                                                                                                                           |\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; (ii) requires a person to comply beyond the geographical limits\n\nspecified in Rule 45(c); (iii) requires disclosure of privileged or other protected matter, if no\n\nexception 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:\n\n(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 trialpreparation 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\n## Case 22-50073 Doc 2304 Filed 11/02/23 Entered 11/02/23 15:07:07 Page 73 of 152 2320 11/09/23 11/09/23 16:05:58 66 148\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 2304 Filed 11/02/23 Entered 11/02/23 15:07:07 Page 74 of 152 2320 11/09/23 11/09/23 16:05:58 67 148\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 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 2304 Filed 11/02/23 Entered 11/02/23 15:07:07 Page 75 of 152 2320 11/09/23 11/09/23 16:05:58 68 148\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 2304 Filed 11/02/23 Entered 11/02/23 15:07:07 Page 76 of 152 2320 11/09/23 11/09/23 16:05:58 69 148\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 2304 Filed 11/02/23 Entered 11/02/23 15:07:07 Page 77 of 152 2320 11/09/23 11/09/23 16:05:58 70 148\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 2304 Filed 11/02/23 Entered 11/02/23 15:07:07 Page 78 of 152 2320 11/09/23 11/09/23 16:05:58 71 148\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 Kyrgyz-Swiss Bank CJSC 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 2304 Filed 11/02/23 Entered 11/02/23 15:07:07 Page 79 of 152 2320 11/09/23 11/09/23 16:05:58 72 148\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, 17 Miles, LLC, 5780 Saguaro LLC, ACA Capital Group Limited, Ace Decade Holdings Limited, AI Group Holdings Inc., Ana C. Izquiedo-Henn, Andrew Childe, Booming Sail New York LLC, Bingshang Jiao, Bravo Luck Limited, Brent Petro Inc., Chris Lee (a/k/a Nan Li, Mei Guo Xiao Li), Crane Advisory Group, Daniel Thomas Podhaskie, Defeng Cao (a/k/a Wayne Cao, Max Cao), Ding \"Ivan\" Lin, Doaa Dashoush, Eastern Profit Corporation Limited, Genever Holdings Corporation, Genever Holdings LLC, Gettr USA, Inc., Gnews Media Group Inc., G Fashion Hold Co. B. Limited, G Fashion International Limited, G Fashion LLC, Gmusic LLC, Gnews LLC, Geducation, GFNY, Inc., G Club Finance, G Club HoldCo I LLC, G Club International Limited, G Club Investments Limited, G Club Operations LLC, G Club US\n\n#### Case 22-50073 Doc 2304 Filed 11/02/23 Entered 11/02/23 15:07:07 Page 80 of 152 2320 11/09/23 11/09/23 16:05:58 73 148\n\nOperations Inc., G Club US Operations LLC, G Club One, G Club Two, G Club Three, G Live, LLC, Gbroadcast, LLC, GM 27 LLC, Gladys Chow, Golden Spring (New York) Ltd., Gposts LLC, GTV Media Group, Inc., Gypsy Mei Food Service LLC, Gypsy Mei Productions LLC, Gypsy Mei 27 Vestry, Inc., Dawn State Limited, Greenwich Land LLC, Hao (Gavin) Li (a/k/a Huo Lai), Hamilton Capital Holdings Inc., GS Security Solutions Inc., Han Chunguang, Haoran He, HCHK Property Management, Inc., HCHK Technologies, Inc., HK International Funds Investments (USA) Limited LLC, Freedom Media Ventures Ltd., FungWan Trading Inc., Himalaya New World Inc., Himalaya International Financial Group Ltd., Himalaya International Clearing Ltd., Himalaya International Payments Ltd., Himalaya International Reserves Ltd., Himalaya Ventures LLC, Himalaya Investment LLC, Hudson Diamond Holding, Inc., Hudson Diamond Holding LLC, Hudson Diamond NY LLC, Huk Trading Inc., Infinity Treasury Management Inc., Jesse Brown, Jiaming Liu, Jie Zhang, Jovial Century International Limited, Joyord Sportswear Limited, Kamel Debeche, Karin Maistrello, Lamp Capital LLC, Leading Shine NY Ltd., Lexington Property and Staffing, Inc., Linwan \"Irene\" Feng, Limarie Reyes, Lihong \"Sara\" Wei Lafrenz, The Lost Draft LLC, Macaron Limited, Mary Jiang, MOS Himalaya LLC, Maywind Trading LLC, New York MOS Himalaya LLC, Nicholas Savio, Nodal Partners, LLC, Oasis Tech Limited, Pixshow Film Inc., Qu Guo Jiao, Roscalitar 2, Ridwan Mamode Saib, Ross Heinemeyer, Rule of Law Society IV Inc., Rule of Law Foundation III, Inc., Rule of Law Fund, Saraca Media Group Inc., Savio Law LLC, Scott Barnett, Shih Hsin Yu, Sirius Networking Inc., US Himalaya Capital Inc., V.X. Cerda & Associates P.A., Victor Cerda, Voice of Guo Media, Inc., Wen Xiao, Wencong Wang, William Je, Yinying (Aila) Wang (a/k/a Xiao Fei Xiang), Yongbing Zhang, Yongping Yan (Shan Mu) Yue Zhou, Yumei Hao (a/k/a Ru Shui), Yvette Wang (a/k/a Yanping Wang, a/k/a Yan Ping Wang), Zhixuan Li, and Zhouer \"Joe\" Wang.\n\n#### Case 22-50073 Doc 2304 Filed 11/02/23 Entered 11/02/23 15:07:07 Page 81 of 152 2320 11/09/23 11/09/23 16:05:58 74 148\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 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\n\n#### Case 22-50073 Doc 2304 Filed 11/02/23 Entered 11/02/23 15:07:07 Page 82 of 152 2320 11/09/23 11/09/23 16:05:58 75 148\n\nto, 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, 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\n\n#### Case 22-50073 Doc 2304 Filed 11/02/23 Entered 11/02/23 15:07:07 Page 83 of 152 2320 11/09/23 11/09/23 16:05:58 76 148\n\nis 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, 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\n\n#### Case 22-50073 Doc 2304 Filed 11/02/23 Entered 11/02/23 15:07:07 Page 84 of 152 2320 11/09/23 11/09/23 16:05:58 77 148\n\nstatements, 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, Hong Kong Securities and Futures Commission, and the Hong Kong Monetary Authority relating to any of the 2004 Discovery Targets.\n\n# Exhibit C-5\n\n#### B2540 (Form 2540 – Subpoena for Rule 2004 Examination) (12/15) UNITED STATES BANKRUPTCY COURT Case 22-50073 Doc 2304 Filed 11/02/23 Entered 11/02/23 15:07:07 Page 86 of 152 2320 11/09/23 11/09/23 16:05:58 79 148\n\n\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_ District of \\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\n\nIn re \\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\n\nDebtor\n\nCase No. \\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\n\nChapter \\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\n\n# **SUBPOENA FOR RULE 2004 EXAMINATION**\n\nTo: **\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_** 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|       |               |\n|       |               |\n\nThe examination will be recorded by this method: \\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\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\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: \\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\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 *(name of party)* \\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_ , who issues or requests this subpoena, are:\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\n| Case 22-50073                                                   | Doc 2304<br>2320 | Filed 11/02/23<br>11/09/23 | Entered 11/02/23 15:07:07<br>11/09/23 16:05:58 | Page 87 of<br>80 |\n|-----------------------------------------------------------------|------------------|----------------------------|------------------------------------------------|------------------|\n| B2540 (Form 2540 – Subpoena for Rule 2004 Examination) (Page 2) |                  | 152<br>148                 |                                                |                  |\n|                                                                 |                  |                            |                                                |                  |\n\n| (This section should not be filed with the court unless required by Fed. R. Civ. P. 45.) |                                                                |                                                                                                                                                                                                                                                                                                      |\n|------------------------------------------------------------------------------------------|----------------------------------------------------------------|------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|\n| on (date)<br>__________                                                                  |                                                                | I received this subpoena for (name of individual and title, if any): ______________________________________________                                                                                                                                                                                  |\n|                                                                                          | I served the subpoena by delivering a copy to the named person | as follows: ____________________________________<br>___________________________________________________________________________________________________                                                                                                                                              |\n| __________________________________                                                       |                                                                | on (date) ___________________ ; or                                                                                                                                                                                                                                                                   |\n|                                                                                          |                                                                |                                                                                                                                                                                                                                                                                                      |\n|                                                                                          |                                                                | I returned the subpoena unexecuted because: ____________________________________________________________<br>___________________________________________________________________________________________________                                                                                      |\n|                                                                                          | for travel and \\$_________                                     | Unless the subpoena was issued on behalf of the United States, or one of its officers or agents, I have also tendered to the<br>witness the fees for one day's attendance, and the mileage allowed by law, in the amount of \\$ _______________________ .<br>for services, for a total of \\$_________ |\n| I declare under penalty of perjury                                                       |                                                                | that this information is true and correct.                                                                                                                                                                                                                                                           |\n|                                                                                          |                                                                |                                                                                                                                                                                                                                                                                                      |\n| My fees are \\$ _________<br>Date: _______________                                        |                                                                | ________________________________________________<br>Server's signature<br>________________________________________________                                                                                                                                                                           |\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; (ii) requires a person to comply beyond the geographical limits\n\nspecified 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:\n\n(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 trialpreparation 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\n## Case 22-50073 Doc 2304 Filed 11/02/23 Entered 11/02/23 15:07:07 Page 90 of 152 2320 11/09/23 11/09/23 16:05:58 83 148\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 2304 Filed 11/02/23 Entered 11/02/23 15:07:07 Page 91 of 152 2320 11/09/23 11/09/23 16:05:58 84 148\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 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 2304 Filed 11/02/23 Entered 11/02/23 15:07:07 Page 92 of 152 2320 11/09/23 11/09/23 16:05:58 85 148\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|              |                           |                                                 |\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 2304 Filed 11/02/23 Entered 11/02/23 15:07:07 Page 93 of 152 2320 11/09/23 11/09/23 16:05:58 86 148\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 2304 Filed 11/02/23 Entered 11/02/23 15:07:07 Page 94 of 152 2320 11/09/23 11/09/23 16:05:58 87 148\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 2304 Filed 11/02/23 Entered 11/02/23 15:07:07 Page 95 of 152 2320 11/09/23 11/09/23 16:05:58 88 148\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 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 2304 Filed 11/02/23 Entered 11/02/23 15:07:07 Page 96 of 152 2320 11/09/23 11/09/23 16:05:58 89 148\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, 17 Miles, LLC, 5780 Saguaro LLC, ACA Capital Group Limited, Ace Decade Holdings Limited, AI Group Holdings Inc., Ana C. Izquiedo-Henn, Andrew Childe, Booming Sail New York LLC, Bingshang Jiao, Bravo Luck Limited, Brent Petro Inc., Chris Lee (a/k/a Nan Li, Mei Guo Xiao Li), Crane Advisory Group, Daniel Thomas Podhaskie, Defeng Cao (a/k/a Wayne Cao, Max Cao), Ding \"Ivan\" Lin, Doaa Dashoush, Eastern Profit Corporation Limited, Genever Holdings Corporation, Genever Holdings LLC, Gettr USA, Inc., Gnews Media Group Inc., G Fashion Hold Co. B. Limited, G Fashion International Limited, G Fashion LLC, Gmusic LLC, Gnews LLC, Geducation, GFNY, Inc., G Club Finance, G Club HoldCo I LLC, G Club International Limited, G Club Investments Limited, G Club Operations LLC, G Club US\n\n#### Case 22-50073 Doc 2304 Filed 11/02/23 Entered 11/02/23 15:07:07 Page 97 of 152 2320 11/09/23 11/09/23 16:05:58 90 148\n\nOperations Inc., G Club US Operations LLC, G Club One, G Club Two, G Club Three, G Live, LLC, Gbroadcast, LLC, GM 27 LLC, Gladys Chow, Golden Spring (New York) Ltd., Gposts LLC, GTV Media Group, Inc., Gypsy Mei Food Service LLC, Gypsy Mei Productions LLC, Gypsy Mei 27 Vestry, Inc., Dawn State Limited, Greenwich Land LLC, Hao (Gavin) Li (a/k/a Huo Lai), Hamilton Capital Holdings Inc., GS Security Solutions Inc., Han Chunguang, Haoran He, HCHK Property Management, Inc., HCHK Technologies, Inc., HK International Funds Investments (USA) Limited LLC, Freedom Media Ventures Ltd., FungWan Trading Inc., Himalaya New World Inc., Himalaya International Financial Group Ltd., Himalaya International Clearing Ltd., Himalaya International Payments Ltd., Himalaya International Reserves Ltd., Himalaya Ventures LLC, Himalaya Investment LLC, Hudson Diamond Holding, Inc., Hudson Diamond Holding LLC, Hudson Diamond NY LLC, Huk Trading Inc., Infinity Treasury Management Inc., Jesse Brown, Jiaming Liu, Jie Zhang, Jovial Century International Limited, Joyord Sportswear Limited, Kamel Debeche, Karin Maistrello, Lamp Capital LLC, Leading Shine NY Ltd., Lexington Property and Staffing, Inc., Linwan \"Irene\" Feng, Limarie Reyes, Lihong \"Sara\" Wei Lafrenz, The Lost Draft LLC, Macaron Limited, Mary Jiang, MOS Himalaya LLC, Maywind Trading LLC, New York MOS Himalaya LLC, Nicholas Savio, Nodal Partners, LLC, Oasis Tech Limited, Pixshow Film Inc., Qu Guo Jiao, Roscalitar 2, Ridwan Mamode Saib, Ross Heinemeyer, Rule of Law Society IV Inc., Rule of Law Foundation III, Inc., Rule of Law Fund, Saraca Media Group Inc., Savio Law LLC, Scott Barnett, Shih Hsin Yu, Sirius Networking Inc., US Himalaya Capital Inc., V.X. Cerda & Associates P.A., Victor Cerda, Voice of Guo Media, Inc., Wen Xiao, Wencong Wang, William Je, Yinying (Aila) Wang (a/k/a Xiao Fei Xiang), Yongbing Zhang, Yongping Yan (Shan Mu) Yue Zhou, Yumei Hao (a/k/a Ru Shui), Yvette Wang (a/k/a Yanping Wang, a/k/a Yan Ping Wang), Zhixuan Li, and Zhouer \"Joe\" Wang.\n\n#### Case 22-50073 Doc 2304 Filed 11/02/23 Entered 11/02/23 15:07:07 Page 98 of 152 2320 11/09/23 11/09/23 16:05:58 91 148\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 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\n\n#### Case 22-50073 Doc 2304 Filed 11/02/23 Entered 11/02/23 15:07:07 Page 99 of 152 2320 11/09/23 11/09/23 16:05:58 92 148\n\nto, 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, 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\n\n#### Case 22-50073 Doc 2304 Filed 11/02/23 Entered 11/02/23 15:07:07 Page 100 of 152 Case 22-50073 Doc 2320 Filed 11/09/23 Entered 11/09/23 16:05:58 Page 93 of 148\n\nis 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, 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\n\n#### Case 22-50073 Doc 2304 Filed 11/02/23 Entered 11/02/23 15:07:07 Page 101 of 152 Case 22-50073 Doc 2320 Filed 11/09/23 Entered 11/09/23 16:05:58 Page 94 of 148\n\nstatements, 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, Hong Kong Securities and Futures Commission, and the Hong Kong Monetary Authority relating to any of the 2004 Discovery Targets.\n\n# Exhibit C-6\n\n| Case 22-50073<br>Case 22-50073<br>Doc 2304<br>Doc 2320<br>Filed 11/02/23<br>Filed 11/09/23<br>Entered 11/02/23 15:07:07<br>Entered 11/09/23 16:05:58 | Page 103 of<br>Page 96 of |  |  |  |\n|------------------------------------------------------------------------------------------------------------------------------------------------------|---------------------------|--|--|--|\n| B2540 (Form 2540 – Subpoena for Rule 2004 Examination) (12/15)<br>152<br>148                                                                         |                           |  |  |  |\n| UNITED STATES BANKRUPTCY COURT                                                                                                                       |                           |  |  |  |\n| _______________________________________ District of<br>___________________________________________                                                   |                           |  |  |  |\n\nCase No. \\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\n\nDebtor\n\nIn re \\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\n\nChapter \\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\n\n# **SUBPOENA FOR RULE 2004 EXAMINATION**\n\nTo: **\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_**\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|       |               |\n|       |               |\n|       |               |\n\nThe examination will be recorded by this method: \\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\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\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: \\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\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 *(name of party)* \\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_ , who issues or requests this subpoena, are:\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\n| Case 22-50073<br>Case 22-50073<br>Doc 2304<br>Doc 2320<br>Filed 11/02/23<br>Filed 11/09/23<br>B2540 (Form 2540 – Subpoena for Rule 2004 Examination) (Page 2)<br>152<br>148                                                                              | Entered 11/02/23 15:07:07<br>Entered 11/09/23 16:05:58<br>Page 104 of<br>Page 97 of |  |  |  |\n|----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|-------------------------------------------------------------------------------------|--|--|--|\n| PROOF OF SERVICE<br>(This section should not be filed with the court unless required by Fed. R. Civ. P. 45.)                                                                                                                                             |                                                                                     |  |  |  |\n| I received this subpoena for (name of individual and title, if any): ______________________________________________<br>on (date)<br>__________                                                                                                           |                                                                                     |  |  |  |\n| I served the subpoena by delivering a copy to the named person<br>as follows: ____________________________________<br>___________________________________________________________________________________________________                                |                                                                                     |  |  |  |\n| __________________________________<br>on (date) ___________________ ; or                                                                                                                                                                                 |                                                                                     |  |  |  |\n| I returned the subpoena unexecuted because: ____________________________________________________________<br>___________________________________________________________________________________________________                                          |                                                                                     |  |  |  |\n| Unless the subpoena was issued on behalf of the United States, or one of its officers or agents, I have also tendered to the<br>witness the fees for one day's attendance, and the mileage allowed by law, in the amount of \\$ _______________________ . |                                                                                     |  |  |  |\n| My fees are \\$ _________<br>for travel and \\$_________<br>for services, for a total of \\$_________                                                                                                                                                       |                                                                                     |  |  |  |\n| I declare under penalty of perjury<br>that this information is true and correct.                                                                                                                                                                         |                                                                                     |  |  |  |\n| Date: _______________                                                                                                                                                                                                                                    |                                                                                     |  |  |  |\n|                                                                                                                                                                                                                                                          | ________________________________________________<br>Server's signature              |  |  |  |\n|                                                                                                                                                                                                                                                          | ________________________________________________<br>Printed name and title          |  |  |  |\n|                                                                                                                                                                                                                                                          | ________________________________________________<br>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; (ii) requires a person to comply beyond the geographical limits\n\nspecified in Rule 45(c); (iii) requires disclosure of privileged or other protected matter, if no\n\nexception 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:\n\n(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 trialpreparation 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#### Case 22-50073 Doc 2304 Filed 11/02/23 Entered 11/02/23 15:07:07 Page 106 of 152 Case 22-50073 Doc 2320 Filed 11/09/23 Entered 11/09/23 16:05:58 Page 99 of 148\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\n## Case 22-50073 Doc 2304 Filed 11/02/23 Entered 11/02/23 15:07:07 Page 107 of 152 2320 11/09/23 11/09/23 16:05:58 100 148\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 2304 Filed 11/02/23 Entered 11/02/23 15:07:07 Page 108 of 152 2320 11/09/23 11/09/23 16:05:58 101 148\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 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 2304 Filed 11/02/23 Entered 11/02/23 15:07:07 Page 109 of 152 2320 11/09/23 11/09/23 16:05:58 102 148\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 2304 Filed 11/02/23 Entered 11/02/23 15:07:07 Page 110 of 152 2320 11/09/23 11/09/23 16:05:58 103 148\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 2304 Filed 11/02/23 Entered 11/02/23 15:07:07 Page 111 of 152 2320 11/09/23 11/09/23 16:05:58 104 148\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 2304 Filed 11/02/23 Entered 11/02/23 15:07:07 Page 112 of 152 2320 11/09/23 11/09/23 16:05:58 105 148\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 NexBank 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\n#### Case 22-50073 Doc 2304 Filed 11/02/23 Entered 11/02/23 15:07:07 Page 113 of 152 2320 11/09/23 11/09/23 16:05:58 106 148\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, 17 Miles, LLC, 5780 Saguaro LLC, ACA Capital Group Limited, Ace Decade Holdings Limited, AI Group Holdings Inc., Ana C. Izquiedo-Henn, Andrew Childe, Booming Sail New York LLC, Bingshang Jiao, Bravo Luck Limited, Brent Petro Inc., Chris Lee (a/k/a Nan Li, Mei Guo Xiao Li), Crane Advisory Group, Daniel Thomas Podhaskie, Defeng Cao (a/k/a Wayne Cao, Max Cao), Ding \"Ivan\" Lin, Doaa Dashoush, Eastern Profit Corporation Limited, Genever Holdings Corporation, Genever Holdings LLC, Gettr USA, Inc., Gnews Media Group Inc., G Fashion Hold Co. B. Limited, G Fashion International Limited, G Fashion LLC, Gmusic LLC, Gnews LLC, Geducation, GFNY, Inc., G Club Finance, G Club HoldCo I LLC, G Club International Limited, G Club Investments Limited, G Club Operations LLC, G Club US Operations Inc., G Club US Operations LLC, G Club One, G Club Two, G Club Three, G Live, LLC, Gbroadcast, LLC, GM 27 LLC, Gladys Chow, Golden Spring (New York) Ltd., Gposts LLC, GTV Media Group, Inc., Gypsy Mei Food Service LLC, Gypsy Mei Productions LLC, Gypsy Mei\n\n#### Case 22-50073 Doc 2304 Filed 11/02/23 Entered 11/02/23 15:07:07 Page 114 of 152 2320 11/09/23 11/09/23 16:05:58 107 148\n\n27 Vestry, Inc., Dawn State Limited, Greenwich Land LLC, Hao (Gavin) Li (a/k/a Huo Lai), Hamilton Capital Holdings Inc., GS Security Solutions Inc., Han Chunguang, Haoran He, HCHK Property Management, Inc., HCHK Technologies, Inc., HK International Funds Investments (USA) Limited LLC, Freedom Media Ventures Ltd., FungWan Trading Inc., Himalaya New World Inc., Himalaya International Financial Group Ltd., Himalaya International Clearing Ltd., Himalaya International Payments Ltd., Himalaya International Reserves Ltd., Himalaya Ventures LLC, Himalaya Investment LLC, Hudson Diamond Holding, Inc., Hudson Diamond Holding LLC, Hudson Diamond NY LLC, Huk Trading Inc., Infinity Treasury Management Inc., Jesse Brown, Jiaming Liu, Jie Zhang, Jovial Century International Limited, Joyord Sportswear Limited, Kamel Debeche, Karin Maistrello, Lamp Capital LLC, Leading Shine NY Ltd., Lexington Property and Staffing, Inc., Linwan \"Irene\" Feng, Limarie Reyes, Lihong \"Sara\" Wei Lafrenz, The Lost Draft LLC, Macaron Limited, Mary Jiang, MOS Himalaya LLC, Maywind Trading LLC, New York MOS Himalaya LLC, Nicholas Savio, Nodal Partners, LLC, Oasis Tech Limited, Pixshow Film Inc., Qu Guo Jiao, Roscalitar 2, Ridwan Mamode Saib, Ross Heinemeyer, Rule of Law Society IV Inc., Rule of Law Foundation III, Inc., Rule of Law Fund, Saraca Media Group Inc., Savio Law LLC, Scott Barnett, Shih Hsin Yu, Sirius Networking Inc., US Himalaya Capital Inc., V.X. Cerda & Associates P.A., Victor Cerda, Voice of Guo Media, Inc., Wen Xiao, Wencong Wang, William Je, Yinying (Aila) Wang (a/k/a Xiao Fei Xiang), Yongbing Zhang, Yongping Yan (Shan Mu) Yue Zhou, Yumei Hao (a/k/a Ru Shui), Yvette Wang (a/k/a Yanping Wang, a/k/a Yan Ping Wang), Zhixuan Li, and Zhouer \"Joe\" 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\n#### Case 22-50073 Doc 2304 Filed 11/02/23 Entered 11/02/23 15:07:07 Page 115 of 152 2320 11/09/23 11/09/23 16:05:58 108 148\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 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 2304 Filed 11/02/23 Entered 11/02/23 15:07:07 Page 116 of 152 2320 11/09/23 11/09/23 16:05:58 109 148\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, 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\n\n#### Case 22-50073 Doc 2304 Filed 11/02/23 Entered 11/02/23 15:07:07 Page 117 of 152 2320 11/09/23 11/09/23 16:05:58 110 148\n\nuploaded 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, 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\n#### Case 22-50073 Doc 2304 Filed 11/02/23 Entered 11/02/23 15:07:07 Page 118 of 152 2320 11/09/23 11/09/23 16:05:58 111 148\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, Hong Kong Securities and Futures Commission, and the Hong Kong Monetary Authority relating to any of the 2004 Discovery Targets.\n\n# Exhibit C-7\n\n#### B2540 (Form 2540 – Subpoena for Rule 2004 Examination) (12/15) UNITED STATES BANKRUPTCY COURT Case 22-50073 Doc 2304 Filed 11/02/23 Entered 11/02/23 15:07:07 Page 120 of 152 2320 11/09/23 11/09/23 16:05:58 113 148\n\n\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_ District of \\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\n\nIn re \\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\n\nDebtor\n\nCase No. \\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\n\nChapter \\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\n\n# **SUBPOENA FOR RULE 2004 EXAMINATION**\n\nTo: **\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_**\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|       |               |\n|       |               |\n|       |               |\n\nThe examination will be recorded by this method: \\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\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\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: \\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\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 *(name of party)* \\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_ , who issues or requests this subpoena, are:\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\n| Case 22-50073                                                   | Doc 2304<br>2320 | Filed 11/02/23<br>11/09/23 |            | Entered 11/02/23 15:07:07<br>11/09/23 16:05:58 | Page 121 of<br>114 |\n|-----------------------------------------------------------------|------------------|----------------------------|------------|------------------------------------------------|--------------------|\n| B2540 (Form 2540 – Subpoena for Rule 2004 Examination) (Page 2) |                  |                            | 152<br>148 |                                                |                    |\n|                                                                 |                  |                            |            |                                                |                    |\n\n|                                    | PROOF OF SERVICE<br>(This section should not be filed with the court unless required by Fed. R. Civ. P. 45.)                                                                                                                                                                                                                                                                                                           |  |\n|------------------------------------|------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|--|\n| on (date)<br>__________            | I received this subpoena for (name of individual and title, if any): ______________________________________________                                                                                                                                                                                                                                                                                                    |  |\n|                                    | I served the subpoena by delivering a copy to the named person<br>as follows: ____________________________________<br>___________________________________________________________________________________________________                                                                                                                                                                                              |  |\n| __________________________________ | on (date) ___________________ ; or                                                                                                                                                                                                                                                                                                                                                                                     |  |\n|                                    | I returned the subpoena unexecuted because: ____________________________________________________________<br>___________________________________________________________________________________________________                                                                                                                                                                                                        |  |\n|                                    |                                                                                                                                                                                                                                                                                                                                                                                                                        |  |\n| My fees are \\$ _________           | Unless the subpoena was issued on behalf of the United States, or one of its officers or agents, I have also tendered to the<br>witness the fees for one day's attendance, and the mileage allowed by law, in the amount of \\$ _______________________ .<br>for travel and \\$_________<br>for services, for a total of \\$_________<br>I declare under penalty of perjury<br>that this information is true and correct. |  |\n| Date: _______________              |                                                                                                                                                                                                                                                                                                                                                                                                                        |  |\n|                                    | ________________________________________________<br>Server's signature<br>________________________________________________                                                                                                                                                                                                                                                                                             |  |\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; (ii) requires a person to comply beyond the geographical limits\n\nspecified in Rule 45(c); (iii) requires disclosure of privileged or other protected matter, if no\n\nexception 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:\n\n(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 trialpreparation 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\n## Case 22-50073 Doc 2304 Filed 11/02/23 Entered 11/02/23 15:07:07 Page 124 of 152 2320 11/09/23 11/09/23 16:05:58 117 148\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 2304 Filed 11/02/23 Entered 11/02/23 15:07:07 Page 125 of 152 2320 11/09/23 11/09/23 16:05:58 118 148\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 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 2304 Filed 11/02/23 Entered 11/02/23 15:07:07 Page 126 of 152 2320 11/09/23 11/09/23 16:05:58 119 148\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 2304 Filed 11/02/23 Entered 11/02/23 15:07:07 Page 127 of 152 2320 11/09/23 11/09/23 16:05:58 120 148\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 2304 Filed 11/02/23 Entered 11/02/23 15:07:07 Page 128 of 152 2320 11/09/23 11/09/23 16:05:58 121 148\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 2304 Filed 11/02/23 Entered 11/02/23 15:07:07 Page 129 of 152 2320 11/09/23 11/09/23 16:05:58 122 148\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 Oriental 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\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 2304 Filed 11/02/23 Entered 11/02/23 15:07:07 Page 130 of 152 2320 11/09/23 11/09/23 16:05:58 123 148\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, 17 Miles, LLC, 5780 Saguaro LLC, ACA Capital Group Limited, Ace Decade Holdings Limited, AI Group Holdings Inc., Ana C. Izquiedo-Henn, Andrew Childe, Booming Sail New York LLC, Bingshang Jiao, Bravo Luck Limited, Brent Petro Inc., Chris Lee (a/k/a Nan Li, Mei Guo Xiao Li), Crane Advisory Group, Daniel Thomas Podhaskie, Defeng Cao (a/k/a Wayne Cao, Max Cao), Ding \"Ivan\" Lin, Doaa Dashoush, Eastern Profit Corporation Limited, Genever Holdings Corporation, Genever Holdings LLC, Gettr USA, Inc., Gnews Media Group Inc., G Fashion Hold Co. B. Limited, G Fashion International Limited, G Fashion LLC, Gmusic LLC, Gnews LLC, Geducation, GFNY, Inc., G Club Finance, G Club HoldCo I LLC, G Club International Limited, G Club Investments Limited, G Club Operations LLC, G Club US Operations Inc., G Club US Operations LLC, G Club One, G Club Two, G Club Three, G Live, LLC, Gbroadcast, LLC, GM 27 LLC, Gladys Chow, Golden Spring (New York) Ltd., Gposts LLC, GTV Media Group, Inc., Gypsy Mei Food Service LLC, Gypsy Mei Productions LLC, Gypsy Mei\n\n#### Case 22-50073 Doc 2304 Filed 11/02/23 Entered 11/02/23 15:07:07 Page 131 of 152 2320 11/09/23 11/09/23 16:05:58 124 148\n\n27 Vestry, Inc., Dawn State Limited, Greenwich Land LLC, Hao (Gavin) Li (a/k/a Huo Lai), Hamilton Capital Holdings Inc., GS Security Solutions Inc., Han Chunguang, Haoran He, HCHK Property Management, Inc., HCHK Technologies, Inc., HK International Funds Investments (USA) Limited LLC, Freedom Media Ventures Ltd., FungWan Trading Inc., Himalaya New World Inc., Himalaya International Financial Group Ltd., Himalaya International Clearing Ltd., Himalaya International Payments Ltd., Himalaya International Reserves Ltd., Himalaya Ventures LLC, Himalaya Investment LLC, Hudson Diamond Holding, Inc., Hudson Diamond Holding LLC, Hudson Diamond NY LLC, Huk Trading Inc., Infinity Treasury Management Inc., Jesse Brown, Jiaming Liu, Jie Zhang, Jovial Century International Limited, Joyord Sportswear Limited, Kamel Debeche, Karin Maistrello, Lamp Capital LLC, Leading Shine NY Ltd., Lexington Property and Staffing, Inc., Linwan \"Irene\" Feng, Limarie Reyes, Lihong \"Sara\" Wei Lafrenz, The Lost Draft LLC, Macaron Limited, Mary Jiang, MOS Himalaya LLC, Maywind Trading LLC, New York MOS Himalaya LLC, Nicholas Savio, Nodal Partners, LLC, Oasis Tech Limited, Pixshow Film Inc., Qu Guo Jiao, Roscalitar 2, Ridwan Mamode Saib, Ross Heinemeyer, Rule of Law Society IV Inc., Rule of Law Foundation III, Inc., Rule of Law Fund, Saraca Media Group Inc., Savio Law LLC, Scott Barnett, Shih Hsin Yu, Sirius Networking Inc., US Himalaya Capital Inc., V.X. Cerda & Associates P.A., Victor Cerda, Voice of Guo Media, Inc., Wen Xiao, Wencong Wang, William Je, Yinying (Aila) Wang (a/k/a Xiao Fei Xiang), Yongbing Zhang, Yongping Yan (Shan Mu) Yue Zhou, Yumei Hao (a/k/a Ru Shui), Yvette Wang (a/k/a Yanping Wang, a/k/a Yan Ping Wang), Zhixuan Li, and Zhouer \"Joe\" 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\n#### Case 22-50073 Doc 2304 Filed 11/02/23 Entered 11/02/23 15:07:07 Page 132 of 152 2320 11/09/23 11/09/23 16:05:58 125 148\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 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 2304 Filed 11/02/23 Entered 11/02/23 15:07:07 Page 133 of 152 2320 11/09/23 11/09/23 16:05:58 126 148\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, 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\n\n#### Case 22-50073 Doc 2304 Filed 11/02/23 Entered 11/02/23 15:07:07 Page 134 of 152 2320 11/09/23 11/09/23 16:05:58 127 148\n\nuploaded 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, 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\n#### Case 22-50073 Doc 2304 Filed 11/02/23 Entered 11/02/23 15:07:07 Page 135 of 152 2320 11/09/23 11/09/23 16:05:58 128 148\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, Hong Kong Securities and Futures Commission, and the Hong Kong Monetary Authority relating to any of the 2004 Discovery Targets.\n\n# Exhibit C-8\n\n#### B2540 (Form 2540 – Subpoena for Rule 2004 Examination) (12/15) UNITED STATES BANKRUPTCY COURT Case 22-50073 Doc 2304 Filed 11/02/23 Entered 11/02/23 15:07:07 Page 137 of 152 2320 11/09/23 11/09/23 16:05:58 130 148\n\n\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_ District of \\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\n\nIn re \\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\n\nDebtor\n\nCase No. \\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\n\nChapter \\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\n\n# **SUBPOENA FOR RULE 2004 EXAMINATION**\n\nTo: **\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_**\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|       |               |\n|       |               |\n|       |               |\n\nThe examination will be recorded by this method: \\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\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\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: \\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\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 *(name of party)* \\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_ , who issues or requests this subpoena, are:\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\n| Case 22-50073                                                   | Doc 2304<br>2320 | Filed 11/02/23<br>11/09/23 |            | Entered 11/02/23 15:07:07<br>11/09/23 16:05:58 | Page 138 of<br>131 |\n|-----------------------------------------------------------------|------------------|----------------------------|------------|------------------------------------------------|--------------------|\n| B2540 (Form 2540 – Subpoena for Rule 2004 Examination) (Page 2) |                  |                            | 152<br>148 |                                                |                    |\n|                                                                 |                  |                            |            |                                                |                    |\n\n| PROOF OF SERVICE<br>(This section should not be filed with the court unless required by Fed. R. Civ. P. 45.) |                                                                                                                                                                                                                                                                                                                                                    |  |  |  |\n|--------------------------------------------------------------------------------------------------------------|----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|--|--|--|\n| on (date)<br>__________                                                                                      | I received this subpoena for (name of individual and title, if any): ______________________________________________                                                                                                                                                                                                                                |  |  |  |\n| I served the subpoena by delivering a copy to the named person                                               | as follows: ____________________________________<br>___________________________________________________________________________________________________                                                                                                                                                                                            |  |  |  |\n| __________________________________                                                                           | on (date) ___________________ ; or                                                                                                                                                                                                                                                                                                                 |  |  |  |\n|                                                                                                              | I returned the subpoena unexecuted because: ____________________________________________________________<br>___________________________________________________________________________________________________                                                                                                                                    |  |  |  |\n|                                                                                                              |                                                                                                                                                                                                                                                                                                                                                    |  |  |  |\n| My fees are \\$ _________<br>for travel and \\$_________<br>I declare under penalty of perjury                 | Unless the subpoena was issued on behalf of the United States, or one of its officers or agents, I have also tendered to the<br>witness the fees for one day's attendance, and the mileage allowed by law, in the amount of \\$ _______________________ .<br>for services, for a total of \\$_________<br>that this information is true and correct. |  |  |  |\n| Date: _______________                                                                                        |                                                                                                                                                                                                                                                                                                                                                    |  |  |  |\n|                                                                                                              | ________________________________________________<br>Server's signature<br>________________________________________________                                                                                                                                                                                                                         |  |  |  |\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; (ii) requires a person to comply beyond the geographical limits\n\nspecified 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:\n\n(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 trialpreparation 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\n### Case 22-50073 Doc 2304 Filed 11/02/23 Entered 11/02/23 15:07:07 Page 141 of 152 2320 11/09/23 11/09/23 16:05:58 134 148\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 2304 Filed 11/02/23 Entered 11/02/23 15:07:07 Page 142 of 152 2320 11/09/23 11/09/23 16:05:58 135 148\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 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 2304 Filed 11/02/23 Entered 11/02/23 15:07:07 Page 143 of 152 2320 11/09/23 11/09/23 16:05:58 136 148\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 2304 Filed 11/02/23 Entered 11/02/23 15:07:07 Page 144 of 152 2320 11/09/23 11/09/23 16:05:58 137 148\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 2304 Filed 11/02/23 Entered 11/02/23 15:07:07 Page 145 of 152 2320 11/09/23 11/09/23 16:05:58 138 148\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 2304 Filed 11/02/23 Entered 11/02/23 15:07:07 Page 146 of 152 2320 11/09/23 11/09/23 16:05:58 139 148\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 Wells Fargo Bank, National Association 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 2304 Filed 11/02/23 Entered 11/02/23 15:07:07 Page 147 of 152 2320 11/09/23 11/09/23 16:05:58 140 148\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, 17 Miles, LLC, 5780 Saguaro LLC, ACA Capital Group Limited, Ace Decade Holdings Limited, AI Group Holdings Inc., Ana C. Izquiedo-Henn, Andrew Childe, Booming Sail New York LLC, Bingshang Jiao, Bravo Luck Limited, Brent Petro Inc., Chris Lee (a/k/a Nan Li, Mei Guo Xiao Li), Crane Advisory Group, Daniel Thomas Podhaskie, Defeng Cao (a/k/a Wayne Cao, Max Cao), Ding \"Ivan\" Lin, Doaa Dashoush, Eastern Profit Corporation Limited, Genever Holdings Corporation, Genever Holdings LLC, Gettr USA, Inc., Gnews Media Group Inc., G Fashion Hold Co. B. Limited, G Fashion International Limited, G Fashion LLC, Gmusic LLC, Gnews LLC, Geducation, GFNY, Inc., G Club Finance, G Club HoldCo I LLC, G Club International Limited, G Club Investments Limited, G Club Operations LLC, G Club US\n\n#### Case 22-50073 Doc 2304 Filed 11/02/23 Entered 11/02/23 15:07:07 Page 148 of 152 2320 11/09/23 11/09/23 16:05:58 141 148\n\nOperations Inc., G Club US Operations LLC, G Club One, G Club Two, G Club Three, G Live, LLC, Gbroadcast, LLC, GM 27 LLC, Gladys Chow, Golden Spring (New York) Ltd., Gposts LLC, GTV Media Group, Inc., Gypsy Mei Food Service LLC, Gypsy Mei Productions LLC, Gypsy Mei 27 Vestry, Inc., Dawn State Limited, Greenwich Land LLC, Hao (Gavin) Li (a/k/a Huo Lai), Hamilton Capital Holdings Inc., GS Security Solutions Inc., Han Chunguang, Haoran He, HCHK Property Management, Inc., HCHK Technologies, Inc., HK International Funds Investments (USA) Limited LLC, Freedom Media Ventures Ltd., FungWan Trading Inc., Himalaya New World Inc., Himalaya International Financial Group Ltd., Himalaya International Clearing Ltd., Himalaya International Payments Ltd., Himalaya International Reserves Ltd., Himalaya Ventures LLC, Himalaya Investment LLC, Hudson Diamond Holding, Inc., Hudson Diamond Holding LLC, Hudson Diamond NY LLC, Huk Trading Inc., Infinity Treasury Management Inc., Jesse Brown, Jiaming Liu, Jie Zhang, Jovial Century International Limited, Joyord Sportswear Limited, Kamel Debeche, Karin Maistrello, Lamp Capital LLC, Leading Shine NY Ltd., Lexington Property and Staffing, Inc., Linwan \"Irene\" Feng, Limarie Reyes, Lihong \"Sara\" Wei Lafrenz, The Lost Draft LLC, Macaron Limited, Mary Jiang, MOS Himalaya LLC, Maywind Trading LLC, New York MOS Himalaya LLC, Nicholas Savio, Nodal Partners, LLC, Oasis Tech Limited, Pixshow Film Inc., Qu Guo Jiao, Roscalitar 2, Ridwan Mamode Saib, Ross Heinemeyer, Rule of Law Society IV Inc., Rule of Law Foundation III, Inc., Rule of Law Fund, Saraca Media Group Inc., Savio Law LLC, Scott Barnett, Shih Hsin Yu, Sirius Networking Inc., US Himalaya Capital Inc., V.X. Cerda & Associates P.A., Victor Cerda, Voice of Guo Media, Inc., Wen Xiao, Wencong Wang, William Je, Yinying (Aila) Wang (a/k/a Xiao Fei Xiang), Yongbing Zhang, Yongping Yan (Shan Mu) Yue Zhou, Yumei Hao (a/k/a Ru Shui), Yvette Wang (a/k/a Yanping Wang, a/k/a Yan Ping Wang), Zhixuan Li, and Zhouer \"Joe\" Wang.\n\n#### Case 22-50073 Doc 2304 Filed 11/02/23 Entered 11/02/23 15:07:07 Page 149 of 152 2320 11/09/23 11/09/23 16:05:58 142 148\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 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\n\n#### Case 22-50073 Doc 2304 Filed 11/02/23 Entered 11/02/23 15:07:07 Page 150 of 152 2320 11/09/23 11/09/23 16:05:58 143 148\n\nto, 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, 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\n\n#### Case 22-50073 Doc 2304 Filed 11/02/23 Entered 11/02/23 15:07:07 Page 151 of 152 2320 11/09/23 11/09/23 16:05:58 144 148\n\nis 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, 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\n\n#### Case 22-50073 Doc 2304 Filed 11/02/23 Entered 11/02/23 15:07:07 Page 152 of 152 2320 11/09/23 11/09/23 16:05:58 145 148\n\nstatements, 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, 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 2320 Filed 11/09/23 Entered 11/09/23 16:05:58 Page 146 of 148\n\n# EXHIBIT B\n\nCase 22-50073 Doc 2320 Filed 11/09/23 Entered 11/09/23 16:05:58 Page 147 of\n\n148\n\nFFP is a leading offshore independent fiduciary and corporate services business in the Cayman Islands and British Virgin Islands (BVI). FFP group companies and employees are regulated and supervised by the Cayman Island Monetary Authority and The BVI Financial Services Commission.\n\nThe FFP team comprises approximately 55 people made up of qualified accountants, insolvency practitioners, lawyers and trustees. FFP has expertise in financial and corporate investigations, and litigation, including collating offshore corporate intelligence and eDiscovery. Our engagements are usually in the form of replacement general partner, managing member, director, liquidator or receiver.\n\nAlmost all of our engagements involve litigation, insolvency or regulatory issues. We are experienced in managing companies and assets, working on complex or contentious engagements, our work frequently bringing us into contact with government agencies such as the SEC and DoJ in the United States.\n\nOur senior team members are regularly appointed by Courts in the Cayman Islands and BVI, and have been appointed as foreign representatives of numerous companies that have filed for Chapter 15 bankruptcy recognition in the US, or equivalent processes elsewhere. We are accustomed to deposition and live Court testimony given the nature of our work and to instigating or responding to 2004 and 1782 type discovery.\n\nSome of FFP's notable recent appointments with significant United States litigation connections include:\n\n- Court appointed Liquidators of Silicon Valley Bank NA Cayman Branch with over \\$800m of claims and creditors against the US Federal Deposit Insurance Company.\n- Court appointed Liquidators and Chapter 15 foreign representatives of a group of offshore companies embroiled in a \\$250m ponzi scheme with hundreds of victims. We recently successfully sued Deutsche Bank AG in the Southern District of Florida for \\$95m following issuing over 100 subpoenas and reviewing several million documents.\n- Court appointed liquidators in Bermuda and recognised in Delaware relating to tax avoidance allegations by the IRS of over \\$2bn. Ongoing litigation and discovery.\n- Court appointed Receivers of a \\$2bn private equity fund embroiled in an alleged corporate hijacking and fraud against a Chinese investor. FFP took control of underlying entities and shepherded the sale of the key asset, US company J.D. Power in a competitive private equity tender for nearly \\$2bn.\n- Appointed as replacement directors of a \\$1bn healthcare fund by investors including the Gates Foundation and the World Bank to recover and defend against preference and fraud actions emanating from the collapse of Middle East based Abraaj Holdings, the biggest PE firm in the region at the time of its collapse. This required a significant forensic and discovery exercise. We continue to operate the fund for its intended purpose - hospital projects in developing countries.\n- Appointed as Trustee of over 50 trusts by orders of courts in the Cayman Islands and New Zealand relating to the alleged misappropriation of several billion dollars of assets. FFP took control of real estate and private equity assets to ensure proper management, value preservation and advanced defences to in forfeiture proceedings brought by the US Department of Justice in California.\n- Court appointed Liquidators of a \\$1.6bn Madoff feeder fund. Oversaw the distribution plan of recoveries to hundreds of investors.\n- Appointed as liquidators and recognised as foreign representatives by the US Bankruptcy Court, SDNY, in a heavily contested hearing to take control of investment funds and subsidiaries. Current litigation on foot to recover records and reconstruct financial history.\n- Appointed as directors for restructuring purposes to two US listed oil and gas groups to effect \\$5bn debt for equity swaps, including heavily contested proceedings in SDNY, Brazil, BVI and Cayman.\n- Successfully wound down a fund where the principals of the investment manager were accused of insider trading by the SEC resulting in a total asset freeze. Worked with the SEC to repatriate funds to innocent investors.\n\nCase 22-50073 Doc 2320 Filed 11/09/23 Entered 11/09/23 16:05:58 Page 148 of 148\n\n![](_page_147_Picture_1.jpeg)\n\n![](_page_147_Picture_2.jpeg)\n\n# Andrew Childe\n\nCayman Islands E: andrew.childe@ffp.ky\n\nAndrew Childe is an independent director specialising in providing independent board level governance and dispute resolution advice to companies, partnerships, trusts and other financial structures.\n\nHe takes liquidation appointments over both solvent and insolvent entities, and is qualified to act as a Court appointed liquidator in the Cayman Islands.\n\nFormerly a senior manager at a 'Big Four' advisory and accounting firms, where he managed the restructuring department. Andrew moved to the Cayman Islands in 2009, prior to which he worked with PricewaterhouseCoopers, on a number of large retail and banking restructuring engagements.\n\nAndrew has substantial experience in dealing with a wide range of assets and managing complex cross border litigation. He has in depth knowledge of litigation claims, secondary markets, performing and non-performing loans, as well as traded and non-traded equities. He is also well versed in asset backed lending, real estate sales and management, derivatives and debt instruments, in addition private equity investments, structured finance products and other esoteric assets.\n\nHe is therefore extremely well placed to advise on a wide range of investment strategies, operating an extensive network of trusted advisors and legal counsel in multiple jurisdictions.\n\nAndrew currently sits as a board member on a variety of investment companies in Cayman, the US, British Virgin Islands, the Channel Islands and West Africa.\n\nHe is a member of the Institute of Chartered Accountants in England & Wales, CISPA, the American Bankruptcy Institute, INSOL International, and is the former Secretary of the Restructuring and Insolvency Specialists Association in the Cayman Islands.\n\nAndrew is a qualified Court appointed liquidator in the Cayman Islands and a Certified Director, accredited by ICSA Canada. He is a member of the Cayman Islands Directors Association, the Cayman Islands Compliance Association and is a registered with the Cayman Islands Monetary Authority as an Approved Director.\n\n![](_page_147_Picture_13.jpeg)","body_zh":null,"key_entities":["Je","Himalaya","Guo","Kwok","HCHK","Ho Wan Kwok","Miles Guo","Yanping Wang","William Je","GTV","Saraca","GETTR","RICO","CIPA","forfeiture"],"ecf_references":[{"doc_number":2304,"court":"CTB"},{"doc_number":2308,"court":"CTB"}],"word_count":51136,"status":"published","published_at":"2023-11-09 00:00:00","created_at":"2023-11-09","updated_at":"2026-07-07 08:02:51"}