{"id":"court_ctb_2710_0","court":"CTB","case_no":"22-50073","doc_number":2710,"sub_number":0,"doc_type":"PETITION","filed_date":"2024-02-11","title":"UNITED STATES BANKRUPTCY COURT DISTRICT OF CONNECTICUT BRIDGEPORT DIVISION | -------------------------------------------","summary_zh":null,"summary_en":null,"body_en":"# **UNITED STATES BANKRUPTCY COURT DISTRICT OF CONNECTICUT BRIDGEPORT DIVISION**\n\n| ----------------------------------------------------------- | x |\n|---------------------------------------------------------------------------|-------------------------------------------------------|\n| In re: | :
:
Chapter 11 |\n| 1
HO WAN KWOK,
et al., | :
:
Case No. 22-50073 (JAM) |\n| Debtors.
----------------------------------------------------------- | :
:
(Jointly Administered)
:
x |\n| LUC A. DESPINS, CHAPTER 11
TRUSTEE,
Plaintiff,
v. | :
:
:
:
Adv. Proceeding No. [ ]
:
: |\n| | :
:
February 11, 2024 |\n| CLOUDFLARE, INC, | :
: |\n| Defendant.
----------------------------------------------------------- | :
:
x |\n\n# **COMPLAINT OF CHAPTER 11 TRUSTEE SEEKING AVOIDANCE AND RECOVERY OF FRAUDULENT TRANSFERS AND POSTPETITION TRANSFERS AND RELATED RELIEF PURSUANT TO BANKRUPTCY CODE SECTIONS 544, 548, 549, AND 550 AND NEW YORK DEBTOR & CREDITOR LAW SECTIONS 273, 274, AND 276**\n\nLuc A. Despins, in his capacity as the chapter 11 trustee (the \"Trustee\") appointed in the\n\nchapter 11 case (the \"Chapter 11 Case\") of Ho Wan Kwok (the \"Debtor\" or \"Kwok\"), files this\n\n1 The Debtors in these chapter 11 cases are Ho Wan Kwok (also known as Guo Wengui, Miles Guo, and Miles Kwok, as well as numerous other aliases) (last four digits of tax identification number: 9595), Genever Holdings LLC (last four digits of tax identification number: 8202) and Genever Holdings Corporation. The mailing address for the Trustee, Genever Holdings LLC, and the Genever Holdings Corporation is Paul Hastings LLP, 200 Park Avenue, New York, NY 10166 c/o Luc A. Despins, as Trustee for the Estate of Ho Wan Kwok (solely for purposes of notices and communications).\n\nadversary proceeding complaint (the \"Complaint\") against defendant Cloudflare, Inc. (the \"Defendant\"), stating as follows:\n\n### **NATURE OF ACTION**\n\n1. The Trustee commences this adversary proceeding to avoid and recover: (a) transfers of the Debtor's property prior to the commencement of this Chapter 11 Case; and (b) transfers of property of the Debtor's chapter 11 estate effectuated after the commencement of this Chapter 11 Case without authority of the Bankruptcy Court or otherwise under Title 11 of the United States Code (the \"Bankruptcy Code\").\n\n2. The Debtor, through his alter-ego shell companies, Golden Spring (New York) Ltd. (\"Golden Spring\"), Lexington Property and Staffing Inc. (\"Lexington\"), G Club Operations, LLC (\"G Club Operations\"), G Fashion and HCHK Technologies, Inc. (\"HCHK Technologies\"), transferred funds in the amount of \\$594,800.04 prior to the Petition Date (as defined herein) to the Defendant as the initial transferee.\n\n3. These transfers were actually fraudulent, because the Debtor effectuated them as part of his \"shell game,\" and they were made with the intent to hinder, delay, and/or defraud the Debtor's creditors. 1\n\n4. The Debtor, through his alter-ego shell companies, Lexington and G Club Operations transferred funds in the amount of \\$145,926.96 after the Petition Date (as defined herein) to the Defendant as initial transferee.\n\n2\n\n5. Because these postpetition transfers of estate property were not authorized by the Court or under the Bankruptcy Code, they are subject to avoidance and recovery under sections 549 and 550 of the Bankruptcy Code.\n\n## **JURISDICTION AND VENUE**\n\n6. This Court has subject matter jurisdiction over this adversary proceeding pursuant to 28 U.S.C. § 1334(b).\n\n7. This adversary proceeding has been referred to this Court pursuant to 28 U.S.C. § 157(a).\n\n8. The statutory predicates for the relief sought herein include sections 544, 548, 549, and 550 of the Bankruptcy Code and New York Debtor & Creditor Law sections 273, 274, and 276 2 or any other applicable state law equivalents.\n\n## **THE PARTIES**\n\n9. The Trustee is the chapter 11 trustee in the Chapter 11 Case pursuant to the\n\nBankruptcy Court's order entered on July 8, 2022 [Case No. 22-50073 (the \"Main Case\") Docket No. 523].\n\n10. The Defendant is a Delaware corporation with a place of business located at 101 Townsend Street, San Francisco, California 94107.\n\n2 All statutory references to New York Debtor and Creditor Law will hereinafter be referred to as \"N.Y. Debt. & Cred. Law\". The New York Uniform Voidable Transactions Act (\"NYUVT\") replaced the New York Uniform Fraudulent Conveyance Act (\"NYUFC\") and became effective on April 4, 2020 and applies to transfers made or obligations incurred on or after April 4, 2020. With respect to transfers prior to April 4, 2020, the Trustee seeks relief in this action under the NYUFC and N.Y. Debt. & Cred. Law sections 273,273a,275, 276 and 278.\n\n## **FACTS**\n\n## **A. Chapter 11 Case**\n\n11. The Debtor filed a voluntary petition for relief under Chapter 11 of Title 11 of the Bankruptcy Code on February 15, 2022 (the \"Petition Date\") in the United States Bankruptcy Court for the District of Connecticut (the \"Court\" or \"Bankruptcy Court\"), thus commencing the above-captioned chapter 11 case (the \"Chapter 11 Case\").\n\n12. On March 21, 2022, the Office of the United States Trustee appointed an Official Committee of Unsecured Creditors in this Chapter 11 Case. No examiner has been appointed.\n\n13. The Debtor's bankruptcy schedules, filed in March 2022 with the Bankruptcy Court, claimed that he owned \\$3,850 in assets and had incurred hundreds of millions of dollars of liabilities.3 While the Debtor was, indeed, deeply indebted, his schedules failed to disclose the Debtor's property as held and transferred through his many alter-ego shell companies, including Golden Spring, Lexington, G Club Operations, G Fashion, and HCHK Technologies.\n\n14. On June 15, 2022, the Court entered a memorandum of decision and order [Main Case Docket No. 465] directing the United States Trustee to appoint a chapter 11 trustee in the Chapter 11 Case. Pursuant to this order, the United States Trustee selected Luc A. Despins as the Trustee. On July 8, 2022, the Court entered an order granting the appointment of Luc A. Despins as the Trustee in the Chapter 11 Case [Main Case Docket No. 523].\n\n## **B. Debtor's Use of Shell Companies and Trustee's Adversary Proceedings**\n\n15. Golden Spring, Lexington, G Club Operations, G Fashion, and HCHK Technologies, are among the numerous alter-ego shell companies used by the Debtor to hinder,\n\n3 Schedule of Assets and Liabilities, at 1 (Main Case, Docket No. 78).\n\ndelay, and/or defraud his creditors.4 For years, the Debtor has orchestrated a \"shell game,\" employing a convoluted web of shell companies, nominally owned by family members, lieutenants, and/or subordinates, but in reality, controlled by the Debtor. This shell game enabled the Debtor to use and spend and/or transfer millions of dollars of cash and other assets—much of which the Debtor obtained through his fraudulent investment and cryptocurrency schemes—while concealing this property of this creditors.\n\n16. Since his appointment, the Trustee has commenced a number of adversary proceedings in the Chapter 11 Case to, among other things, establish that the Debtor's shell companies were his alter-egos and/or that such companies and their assets were equitably owned by the Debtor and in several adversary proceedings the Bankruptcy Court has already granted such relief.5\n\nThe Trustee has or will imminently commence an adversary proceeding against G Club Operations and G Fashion, which adversary proceeding seeks, among other things, a declaratory judgment that G Club Operations and G Fashion were the alter egos of the Debtor. The Trustee incorporates by reference herein, the Trustee's Complaint filed in such adversary proceeding.\n\n4 The Court has entered judgment to the effect that Golden Spring was the Debtor's alter ego. *See Despins v. Golden Spring (New York) Limited* (Adv. Proc. No. 23-5018 (the \"Golden Spring A.P.\"), Docket No. 35). The Trustee incorporates by reference herein, the Trustee's Complaint filed in the Golden Spring A.P. (Adv. Proc. No. 23-5018, Docket No. 1).\n\nDefault has entered against Lexington and HCHK Technologies in the adversary proceeding *Despins v. HCHK Technologies, Inc., et. al.* (Adv. Proc. No. 23-5013 (the \"HCHK Entities A.P.\"), Docket No. 139), which adversary proceeding seeks, among other things, a declaratory judgment that Lexington and HCHK Technologies were the alter egos of the Debtor. The Trustee incorporates by reference herein, the Trustee's Complaint filed in the HCHK Entities A.P. (Adv. Proc. No. 23-5013, Docket No. 1).\n\n5 These include the following adversary proceedings: (i) *Luc A. Despins, Chapter 11 Trustee v. HK International Funds Investments (USA) Limited, LLC, et al.* [Adv. Proc. No. 22-05003]; (ii) *Luc A. Despins, Chapter 11 Trustee v. Greenwich Land LLC, et al.* [Adv. Proc. No. 23-05005]; (iii) *Luc A. Despins, Chapter 11 Trustee v. Mei Guo* [Adv. Proc. No. 23-05008]; (iv) *Luc A. Despins, Chapter 11 Trustee v. HCHK Technologies, Inc., et al.* [Adv. Proc. No. 23-05013]; (v) *Luc A. Despins, Chapter 11 Trustee v. Taurus Fund LLC, et al.* [Adv. Proc. No. 23-05017]; (vi) *Luc A. Despins, Chapter 11 Trustee v. Golden Spring (New York) Limited* [Adv. Proc. 23- 05018]; and (vii) *Luc A. Despins, Chapter 11 Trustee v. Lamp Capital LLC, et al.* [Adv. Proc. 23-05023].\n\n17. The fact patterns in these litigations consistently involve: (i) Debtor-controlled shell companies held by close family members and/or subordinates, (ii) assets purchased with cash from other Debtor-controlled entities and/or transferred to and among shell entities for no consideration, and (iii) the Debtor benefiting from and having control and dominion over such assets.\n\n### **C. Debtor's Conduct to Hinder, Delay, and/or Defraud Creditors**\n\n18. In addition to the matters addressed in the Trustee's adversary proceedings, the Bankruptcy Court has found that the Debtor was the beneficial owner of Ace Decade Limited (and through it, Dawn State Limited) and that the Debtor controlled and employed Ace Decade Limited's nominee shareholder, Yvette Wang.6\n\n19. The Bankruptcy Court has also found that the \"G Entities\" (Gettr, G Fashion, G Music, GClubs, GNews and GEdu), the New Federal State of China and the Rule of Law Foundation, as well as other purportedly independent entities and organizations, were controlled by the Debtor7 , led by the Debtor8 and/or served \"the purposes of… and as business vehicles of\" the Debtor.9\n\n20. Prior to the Petition Date, Judge Liman of the United States District Court for the Southern District of New York found that Eastern Profit Corporation Limited, an entity originally\n\n6 *Order Granting Motion to Hold Debtor in Contempt of Corporate Governance Order,* ¶¶ 1, 4 (Jan. 24, 2023, Docket No. 1372 (\"Corp. Governance Contempt Order\").\n\n7 *Corrected Memorandum of Decision Granting in Part Motion for Preliminary Injunction*, ¶ 3 (Adv. Proc. No. 22-05032, January 13, 2023 (\"The Debtor also controls Saraca Media Group and a related entity 'GTV'\").\n\n8 *Id*. at ¶ 7 (\"The Debtor is the leader of The Whistleblower Movement, NFSC, ROLF and Himalaya.\").\n\n9 *Id*. (\"The Whistleblower Movement, NFSC, ROLF, GSeries, and Himalaya serve the purposes of the Debtor, serve as business vehicles for the Debtor, and their members are personally loyal to the Debtor.\").\n\nowned by one of Debtor's chefs before its transfer to Debtor's daughter, was \"in essence, a shell corporation\" for the Debtor.10\n\n21. The Debtor has gone to great lengths to hinder and delay the collection efforts of one of his largest creditors, *i.e.*, Pacific Alliance Asia Opportunity Fund, L.P. (\"PAX\"). In 2017, PAX sued the Debtor in the Supreme Court of the State of New York (the \"New York Court\"), Index No. 652077/2017 (the \"PAX Case\"), seeking judgment for monies owed. On February 3, 2021, PAX obtained a judgment from the New York Court against the Debtor in the sum of \\$116,402,019.57 (the \"PAX Judgment\"). PAX sought to enforce the PAX Judgment by levying the Debtor's assets—including the Lady May, which the Debtor falsely claimed was owned by his daughter, and the Debtor's luxury apartment in Manhattan, which the Debtor falsely claimed was held in trust for the Debtor's son. The Debtor's defiance of New York Court orders in postjudgment proceedings eventually resulted in the Debtor incurring contempt penalties of \\$134 million.\n\n22. The Debtor also used his alter egos, including Golden Spring, Lexington, G Club Operations, G Fashion, and HCHK Technologies, as personal piggy-banks, funding the lavish lifestyle to which he and his family had become accustomed, while concealing assets in these alter egos from his creditors and hindering and delaying creditors from recoveries on their claims. The transfers that the Debtor effectuated through these alter egos effectuated the Debtor's fraudulent scheme.\n\n10 *Eastern Profit Corp. Ltd. v. Strategic Vision US LLC*, No. 18-CV-2185 (LJL) 2021 WL 2554631, at \\*1 (S.D.N.Y. June 22, 2021).\n\n23. The Debtor has testified before the Bankruptcy Court that he has insufficient assets to pay his liabilities and that his luxurious lifestyle is funded by his family through businesses nominally held by family members. 11 The Debtor scheduled only \\$3,850 in assets.12\n\n24. In March 2023, the Debtor was arrested and remains confined pending his trial on federal criminal charges of, among other things, wire fraud, securities fraud, and money laundering.\n\n25. In its criminal indictment of the Debtor, the United States Government asserts that the Debtor and his co-defendants \"utilized more than approximately 500 accounts held in the names of *at least 80 different entities or individuals* to launder more than \\$1 billion in fraud proceeds.\"13\n\n26. The property of the Debtor's alter egos, including Golden Spring, Lexington, G Club Operations, G Fashion, and HCHK Technologies, was at all times prior to the Petition Date property of the Debtor.\n\n27. At all times relevant herein, the Debtor conducted business in New York, New York, including direction of the prepetition transfers at issue in this Complaint.\n\n11 Hearing on Debtor's Motion for Entry of Interim and Final DIP Orders (I) Authorizing the Debtor to Obtain Unsecured, Subordinated Postpetition Financing and (II) Scheduling Interim and Final Hearings, and (III) Granting Related Relief (Main Case, April 27, 2022).\n\n12 *See* n.3\n\n13 *See* Memorandum of Law of the United States of America in Opposition to Defendant Yanping Wang's Motion for Pretrial Release at 29, attached as Exhibit B in the Reply of Chapter 11 Trustee to G Club Operations LLC's Supplemental Objection to Trustee's Motion to Compel and Request for Related Relief (June 23, 2023, Main Case Docket No. 1934).\n\n## **D. Debtor's Shell Game and Fraud Continues Postpetition**\n\n28. As of the Petition Date, all of the Debtor's property held through his alter egos, including Golden Spring, Lexington, G Fashion, G Club Operations and HCHK Technologies, became property of the Debtor's chapter 11 estate. *See* 11 U.S.C. § 541(a)(1).\n\n29. Following the Petition Date, the Debtor, with blatant disregard for the Bankruptcy Court and his obligations under the Bankruptcy Code, continued to effectuate transfers through numerous alter-ego shell companies, including, without limitation, Lexington and G Club Operations.\n\n30. None of these postpetition transfers were authorized by the Bankruptcy Court nor were such transfers authorized under the Bankruptcy Code.\n\n### **E. Transfers Made with Intent to Hinder, Delay, or Defraud Creditors**\n\n31. The Transfers (as defined herein) at issue in this Complaint were made with the intent to hinder, delay, and/or defraud the Debtor's creditors inasmuch as they were all made through the Debtor's alter-ego shell companies operated as a part of the Debtor's shell game.\n\n32. The Debtor intentionally orchestrated his financial affairs in this manner in order to conceal and dissipate millions of dollars in assets while falsely pleading poverty to his many creditors. The Debtor claimed to be destitute while simultaneously spending heavily to maintain a billionaire lifestyle for himself and for his family members and close associates.\n\n33. The assets concealed and dissipated by the Debtor included funds that he obtained from the victims of his cryptocurrency, securities, and other fraud schemes. As a result of this conduct, the Debtor faces multiple felony fraud, money laundering, and racketeering charges in a criminal case pending in the U.S. District Court for the Southern District of New York. *See United States v. Ho Wan Kwok*, case no. 1:23-cr-00118-AT [ECF No. 215] (Jan. 3, 2024 S.D.N.Y.).\n\n34. The Debtor knew and intended that by concealing and dissipating his assets in this manner there would not be sufficient assets remaining to repay his creditors—including the many victims of his frauds. These transfers were thus necessarily made with the intent to hinder, delay, and/or defraud the Debtor's creditors.\n\n## **F. Transfers to the Defendant**\n\n35. Prior to the Petition Date, the Debtor, through shell companies including Golden Spring, Lexington, G Club Operations, G Fashion, and HCHK Technologies, or otherwise, transferred property of the Debtor's chapter 11 estate to the Defendant (collectively, the \"Transfers\"), including, without limitation, as follows:\n\nSee **SCHEDULE A** attached hereto and made a part hereof.\n\n36. Subsequent to the Petition Date, the Debtor, through shell companies including Lexington and G Club Operations, or otherwise, transferred property of the estate to the Defendant (collectively, the \"Postpetition Transfers\"), including, without limitation, as follows:\n\nSee **SCHEDULE B** attached hereto and made a part hereof.\n\n37. At the time of the Prepetition Transfers and the Postpetition Transfers (collectively, the \"Transfers\"), the Debtor had outstanding obligations to creditors of the Debtor's estate.\n\n38. The Defendant was the initial transferee of the Transfers.\n\n## **FIRST CLAIM**\n\n# **(Claim to Avoid and Recover Actual Fraudulent Transfers Pursuant to Bankruptcy Code sections 548(a)(1)(A) and 550(a))**\n\n39. The Trustee repeats and realleges the allegations contained in paragraphs 1-38 as if fully set forth herein.\n\n40. The Prepetition Transfers were made by the Debtor through his alter egos, Golden Spring, Lexington, G Club Operations, G Fashion, and HCHK Technologies, with the actual intent to hinder, delay and/or defraud his creditors.\n\n41. The Debtor's intent to hinder, delay, and/or defraud his creditors in effectuating the Prepetition Transfers is shown by, among other things:\n\na. The Prepetition Transfers were effectuated using an alter-ego shell company;\n\nb. The Prepetition Transfers were concealed from the Debtor's creditors;\n\nc. The Prepetition Transfers were effectuated as part of the Debtor's \"shell game\" with the aid of the Debtor's family members and other lieutenants and subordinates that he controlled in an effort to conceal and shield assets;\n\nd. The Prepetition Transfers furthered the Debtor's fraudulent conduct by enabling the Debtor to benefit from his fraud without subjecting his property to the reach of his creditors;\n\ne. The Prepetition Transfers furthered the Debtor's fraudulent conduct by enabling the Debtor to profit from his fraud without subjecting his property to the reach of his creditors;\n\nf. At the time of the Prepetition Transfers, the Debtor was being sued, including by PAX in the PAX Case; and\n\ng. At the time of the Prepetition Transfers, the Debtor was insolvent or undercapitalized.\n\n11\n\n42. The Prepetition Transfers are avoidable by the Trustee pursuant to section 548(a)(i)(A) of the Bankruptcy Code and are recoverable pursuant to section 550(a) of the Bankruptcy Code.\n\n## **SECOND CLAIM**\n\n## **(Claim to Avoid and Recover Actual Fraudulent Transfers pursuant to N.Y. Debt. & Cred. Law sections 273, 274, and 276, and Bankruptcy Code sections 544(b) and 550(a))**\n\n43. The Trustee repeats and realleges the allegations contained in paragraphs 1-38 as if fully set forth herein.\n\n44. The Prepetition Transfers were made by the Debtor, through his alter egos, Golden Spring, Lexington, G Club Operations, G Fashion, and HCHK Technologies, with the actual intent to hinder, delay and/or defraud his creditors.\n\n45. The Debtor's intent to hinder, delay, and/or defraud his creditors in effectuating the Prepetition Transfers is shown by, among other things:\n\na. The Prepetition Transfers were effectuated using an alter-ego shell company;\n\nb. The Prepetition Transfers were concealed from the Debtor's creditors;\n\nc. The Prepetition Transfers were effectuated as part of the Debtor's \"shell game\" with the aid of the Debtor's family members and other lieutenants and subordinates that he controlled in an effort to conceal and shield assets;\n\nd. The Prepetition Transfers furthered the Debtor's fraudulent conduct by enabling the Debtor to benefit from his fraud without subjecting his property to the reach of his creditors;\n\ne. The Prepetition Transfers furthered the Debtor's fraudulent conduct by enabling the Debtor to profit from his fraud without subjecting his property to the reach of his creditors;\n\nf. At the time of the Prepetition Transfers, the Debtor was being sued, including by PAX in the PAX Case; and\n\ng. At the time of the Prepetition Transfers, the Debtor was insolvent or undercapitalized.\n\n46. The Prepetition Transfers are avoidable by the Trustee pursuant to N.Y. Debt. & Cred. Law sections 273(a)(1), 274, and 276, and section 544(b) of the Bankruptcy Code and recoverable pursuant to section 550(a) of the Bankruptcy Code.\n\n### **THIRD CLAIM**\n\n# **(Claim to Avoid and Recover Unauthorized Postpetition Transfers pursuant to Bankruptcy Code sections 549 and 550(a))**\n\n47. The Trustee repeats and realleges the allegations contained in paragraphs 1-38 as if fully set forth herein.\n\n48. The Postpetition Transfers were made to the Defendant by the Debtor, including through his alter-ego shell companies, Lexington and G Club Operations.\n\n49. The Postpetition Transfers occurred after the Petition Date.\n\n50. The Postpetition Transfers were not authorized by the Bankruptcy Court or by the Bankruptcy Code.\n\n51. The Postpetition Transfers constitute the unauthorized transfers of property of the Debtor's chapter 11 estate.\n\n52. The Postpetition Transfers are avoidable pursuant to section 549(a) of the Bankruptcy Code.\n\n53. Pursuant to section 550(a) of the Bankruptcy Code, the Trustee is entitled to recover the Postpetition Transfers, or the value thereof, from the Defendant plus interest thereon to the date of payment and the costs of this action.\n\n*[THE REMAINDER OF THIS PAGE IS INTENTIONALLY BLANK.]*\n\n### **PRAYER FOR RELIEF**\n\nWHEREFORE, for the foregoing reasons, the Trustee respectfully requests that judgment be entered as follows:\n\n1. On the First Claim, (a) an order declaring that the Prepetition Transfers in an amount not less than \\$594,800.04 are avoided pursuant to section 548(a)(1)(A) of the Bankruptcy Code; (b) an order directing that the Prepetition Transfers be set aside; and (c) recovery of the Prepetition Transfers, or the value thereof at the Trustee's option, from the Defendant for the benefit of the Debtor's estate pursuant to section 550(a)(1) of the Bankruptcy Code;\n\n2. On the Second Claim, (a) an order declaring that the Prepetition Transfers in an amount not less than \\$594,800.04 are avoided pursuant to section 544(b) of the Bankruptcy Code and N.Y. Debt. & Cred. Law sections 273(a)(2), 274 and 276; (b) an order directing that the Prepetition Transfers be set aside; and (c) recovery of the Prepetition Transfers, or the value thereof at the Trustee's option, from the Defendant for the benefit of the Debtor's estate pursuant to N.Y. Debt & Cred. Law section 276 and section 550(a)(1) of the Bankruptcy Code;\n\n3. On the Third Claim, (a) an order declaring that the Postpetition Transfers in an amount not less than \\$145,926.26 are avoided pursuant to section 549 of the Bankruptcy Code; and (b) an order directing that the Postpetition Transfers be set aside; and (c) recovery of the Postpetition Transfers, or the value thereof at the Trustee's option, from the Defendant for the benefit of the Debtor's estate pursuant to section 550(a)(1) of the Bankruptcy Code;\n\n4. Awarding the Trustee pre-judgment interest at the maximum legal rate from the date of the filing of this Complaint to the date of judgment herein; and\n\n5. Such other and further relief as the Court may deem just, proper, or equitable under the circumstances.\n\n15\n\nDated: February 11, 2024 New Haven, CT\n\nLUC A. DESPINS CHAPTER 11 TRUSTEE\n\nBy: /s/ Douglas Skalka \\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_*\\_\\_\\_* Douglas S. Skalka (ct00616) Patrick R. Linsey (ct29437) NEUBERT, PEPE & MONTEITH, P.C. 195 Church Street, 13th Floor New Haven, Connecticut 06510 (203) 781-2847 dskalka@npmlaw.com plinsey@npmlaw.com *Counsel for the Chapter 11 Trustee*\n\nCase 22-50073 Doc 2710 Filed 02/11/24 Entered 02/11/24 14:23:53 Page 17 of 18\n\n## **SCHEDULE A**\n\n**FILED UNDER SEAL**\n\nCase 22-50073 Doc 2710 Filed 02/11/24 Entered 02/11/24 14:23:53 Page 18 of 18\n\n# **EXHIBIT B**\n\n## **FILED UNDER SEAL**","body_zh":null,"key_entities":["HCHK","Despins","Kwok","Je","Ho Wan Kwok","Guo","Himalaya","Miles Guo","Yanping Wang","GTV","Saraca","GETTR","Paul Hastings"],"ecf_references":[{"doc_number":215,"court":"CTB"}],"word_count":3907,"status":"published","published_at":"2024-02-11 00:00:00","created_at":"2024-02-11","updated_at":"2026-07-07 08:07:19"}