{"id":"court_ctb_2931_0","court":"CTB","case_no":"22-50073","doc_number":2931,"sub_number":0,"doc_type":"ORDER","filed_date":"2024-02-16","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| HO WAN KWOK, et al., | :
: | Case No. 22-50073 (JAM) |\n| Debtors.1 | :
:
: | Jointly Administered |\n| ------------------------------------------------------ | x | |\n\n# **APPLICATION OF CHAPTER 11 TRUSTEE FOR ENTRY OF ORDER, PURSUANT TO BANKRUPTCY CODE SECTIONS 327, 328, AND 330, BANKRUPTCY RULES 2014 AND 2016, AND LOCAL BANKRUPTCY RULES 2014-1 AND 2016-1, AUTHORIZING AND APPROVING RETENTION AND EMPLOYMENT OF PRAGER DREIFUSS AG AS SWISS LAW COUNSEL**\n\nMr. Luc A. Despins, in his capacity as the Chapter 11 Trustee (the \"Chapter 11 Trustee\") appointed in the above-captioned chapter 11 case (the \"Chapter 11 Case\") of Ho Wan Kwok (the \"Debtor\"), pursuant to sections 327, 328, and 330 of Title 11 of the United States Code (the \"Bankruptcy Code\"), Rules 2014 and 2016 of the Federal Rules of Bankruptcy Procedure (the \"Bankruptcy Rules\"), and Rules 2014-1 and 2016-1 of the Local Rules of Bankruptcy Procedure (the \"Local Bankruptcy Rules\") for the United States Bankruptcy Court for the District of Connecticut (the \"Court\"), files this application (the \"Application\") requesting entry of an order, substantially in the form attached hereto as **Exhibit A** (the \"Proposed Order\") approving the Chapter 11 Trustee's employment of Prager Dreifuss AG (\"Prager Dreifuss\") as Swiss law counsel, effective as of January 16, 2024, on the terms set forth in the engagement letter attached\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\nhereto as **Exhibit B** (the \"Engagement Letter\"). In support of this Application, the Chapter 11 Trustee submits the *Declaration of Daniel Hayek in Support of Application of Chapter 11 Trustee for Entry of Order, Pursuant to Bankruptcy Code Sections 327, 328, and 330, Bankruptcy Rules 2014 and 2016, and Local Bankruptcy Rules 2014-1 and 2016-1, Authorizing and Approving Retention and Employment of Prager Dreifuss AG as Swiss Law Counsel* (the \"Hayek Declaration\"), attached as **Exhibit C**, which is incorporated herein by reference. In further support of this Application, the Chapter 11 Trustee respectfully states as follows:\n\n# **RELIEF REQUESTED**\n\n1. In the course of his investigation into the Debtor's financial firms, the Trustee recently discovered assets located, and transfers that took place, in Switzerland. The Trustee thus requires a Swiss law firm to further investigate these matters, particularly as the Trustee may need to file pleadings in Swiss court to seek discovery in connection with these matters. As part of these efforts, the Chapter 11 Trustee will also seek to have this chapter 11 case recognized in Switzerland. The Chapter 11 Trustee selected Prager Dreifuss as his counsel based on Prager Dreifuss' familiarity with financial investigations, insolvency, and tracing of funds.\n\n2. By this Application, the Chapter 11 Trustee seeks entry of the Proposed Order, authorizing and approving the retention and employment of Prager Dreifuss as the Chapter 11 Trustee's Swiss law counsel, effective as of January 16, 2024, on the terms set forth in the Engagement Letter, to assist the Trustee in his efforts to recover assets of the Debtor's estate potentially located in Switzerland.\n\n## **JURISDICTION, VENUE, AND STATUTORY BASES**\n\n3. The Court has jurisdiction over this matter pursuant to 28 U.S.C. §§ 157 and 1334 and the *Standing Order of Reference* from the United States District Court for the District of Connecticut. This is a core proceeding within the meaning of 28 U.S.C. § 157(b).\n\n4. Venue in this District is proper pursuant to 28 U.S.C. §§ 1408 and 1409.\n\n5. The statutory bases for the relief requested herein are sections 327(a), 328(a), and 330 of the Bankruptcy Code, and, to the extent applicable, Bankruptcy Rules 2014 and 2016, and Local Bankruptcy Rules 2014-1 and 2016-1.\n\n## **BACKGROUND**\n\n6. On February 15, 2022 (the \"Petition Date\"), the Debtor filed with the Court a voluntary petition for relief under chapter 11 of the Bankruptcy Code.\n\n7. On March 21, 2022, the United States Trustee appointed an Official Committee of Unsecured Creditors (the \"Committee\") in the Debtor's Chapter 11 Case.\n\n8. On June 15, 2022, the Court entered a memorandum of decision and order [Docket No. 465] (the \"Trustee Order\") directing the United States Trustee to appoint a chapter 11 trustee in the Chapter 11 Case. Pursuant to the Trustee Order, the United States Trustee selected Luc A. Despins as the Chapter 11 Trustee [Docket No. 514].\n\n9. On July 8, 2022, the Court entered an order granting the appointment of Luc A. Despins as the Chapter 11 Trustee in the Chapter 11 Case [Docket No. 523].\n\n## **PRAGER DREIFUSS' QUALIFICATIONS**\n\n10. Prager Dreifuss is a law firm located at 6 Mühlebachstrasse, Zurich 8008, Switzerland. Prager Dreifuss maintains offices in Zurich (Switzerland), Bern (Switzerland), and Brussels (Belgium). Prager Dreifuss is a renowned Swiss law firm which practices in a range of\n\nbusiness law areas. The firm currently employs 45 lawyers, who are assisted by paralegals and support staff.\n\n11. For example, Daniel Hayek and his team at Prager Dreifuss have represented the trustee and the security agent of the bondholders regarding their claims against one of Europe's largest independent oil refiners, the Swiss-based Petroplus group; they secured the enforcement of a large claim based on derivatives in litigation against the bankrupt estate of the Swiss Lehman entity; and advised the trustee of the Kodak pension plan on the acquisition of assets and restructuring.\n\n12. Prager Dreifuss has expertise in practice areas including white collar crimes and investigations, as well as finance and insolvency. Prager Dreifuss' broad business law practices spans a range of legal services in Switzerland.\n\n# **ANTICIPATED SERVICES**\n\n13. The Chapter 11 Trustee anticipates that Prager Dreifuss will assist him in the investigation of assets and transfers connected to the Debtor that took place in Switzerland.2 As part of these efforts, Prager Dreifuss will also assist the Chapter 11 Trustee in seeking to have this chapter 11 case recognized in Switzerland. Due to the specialized nature of Prager Dreifuss role as Swiss law counsel, there will be no duplication of services arising from Prager Dreifuss' retention.\n\n## **COMPENSATION OF PRAGER DREIFUSS**\n\n14. Prager Dreifuss intends to apply to the Court for compensation for professional services rendered and for reimbursement of expenses incurred in connection with this Chapter 11\n\n2 In the interest of maintain confidentiality regarding the ongoing investigation, the Trustee will not disclose the exact funds and assets believed to be located in Switzerland.\n\nCase pursuant to sections 330 and 331 of the Bankruptcy Code, Bankruptcy Rule 2016, Local Bankruptcy Rule 2016-1, and any other applicable rules and orders with respect to this Chapter 11 Case, including the *Order Establishing Procedures for Interim Compensation and Reimbursement of Expenses for Retained Professionals* (as such order may be amended, the \"Interim Compensation Order\").\n\n15. Prager Dreifuss will charge the Debtor for its legal services on an hourly basis at its regularly applicable hourly rates in connection with the services required in connection with the Trustee's investigations.\n\n16. At present, the 2024 hourly rates of Prager Dreifuss are between CHF 275 and CHF 450 for associates (which, at current exchange rates, converts into approximately \\$315 to \\$516) and between CHF 500 to CHF 900 for partners (which, at current exchange rates, converts into approximately \\$574 and \\$1,033). Prager Dreifuss will also charge a flat fee for disbursements made on behalf of the Debtor, which flat fee amounts will be equal to 3% of the total fees charged.3\n\n17. Prager Dreifuss has requested, and the Chapter 11 Trustee hereby seeks authorization, that Prager Dreifuss be allowed to invoice its fees and expenses in Swiss Francs (CHF) and to have such fees and expenses paid in Swiss Francs (CHF), subject to the terms of the Interim Compensation Order.\n\n18. The Debtor submits that Prager Dreifuss' hourly rates are reasonable, comparable to Prager Dreifuss' hourly rates for other engagements, and within the range of rates charged by comparably skilled professionals who offer the same services.\n\n3 Prager Dreifuss does not maintain internal processes that would allow it track its administrative expenses, such as photocopying, printing, etc.\n\n19. While all matters related to the payment and allowance of Prager Dreifuss' fees and expenses will be determined by the Bankruptcy Court, as detailed in the Engagement Letter, disputes and claims arising from or in connection with the Engagement Letter, including the validity, invalidity, breach or termination thereof, will be resolved by arbitration in accordance with the Swiss Rules of International Arbitration of the Swiss Chambers' Arbitration Institution. Prager Dreifuss has advised the Trustee that it cannot remove the arbitration provision, because it is required to maintain liability insurance coverage.\n\n## **PRAGER DREIFUSS IS DISINTERESTED**\n\n20. To the best of the Chapter 11 Trustee's knowledge in reliance upon the Hayek Declaration, and except as disclosed therein, Prager Dreifuss does not have any relationships with the Debtor, its creditors, or any other party-in-interest, their respective attorneys and accountants, the United States Trustee, or any person employed in the Office of the United States Trustee.\n\n21. More specifically, upon the basis of the Hayek Declaration, and except as disclosed therein, the Chapter 11 Trustee believes that: (a) Prager Dreifuss has no connection with the Debtor, his creditors, the U.S. Trustee, any person employed in the office of the U.S. Trustee, or any other party with an actual or potential interest in the Debtor or his respective attorneys or accountants; and (b) Prager Dreifuss and its employees (i) are not a creditors, equity security holders, or insiders of the Debtor or his affiliates, (ii) have not been, within two years before the Petition Date, a director, officer, or employee of the Debtor or his affiliates, and (iii) has not had any interest materially adverse to the interests of the Debtor's estate or any class of creditors or equity security holders by reason of any direct or indirect relationship to, connection with, or interest in the Debtor, or for any other reason. Therefore, the Chapter 11 Trustee\n\nbelieves that Prager Dreifuss is a \"disinterested person\" within the meaning of section 101(14) of the Bankruptcy Code, as modified by section 1107(b).\n\n22. Based on the Hayek Declaration, the Chapter 11 Trustee believes that Prager Dreifuss does not represent any adverse interest to unsecured creditors in connection with the Chapter 11 Case.\n\n# **BASIS FOR RELIEF REQUESTED**\n\n23. The Chapter 11 Trustee requests to retain and employ Prager Dreifuss as his Swiss counsel pursuant to section 327(a) of the Bankruptcy Code, which provides that a trustee, subject to the approval of the Court, may employ professional persons \"that do not hold or represent an interest adverse to the estate, and that are disinterested persons, to represent or assist the trustee in carrying out the trustee's duties under this title.\"\n\n24. Under section 328(a) of the Bankruptcy Code, with bankruptcy court approval, a trustee may employ professional persons under section 327(a) of the Bankruptcy Code \"on any reasonable terms and conditions of employment, including on a retainer, on an hourly basis, on a fixed or percentage fee basis, or on a contingent fee basis.\" 11 U.S.C. § 328(a).\n\n25. Bankruptcy Rule 2014(a) provides that an application for retention include:\n\nspecific facts showing the necessity for the employment, the name of the [firm] to be employed, the reasons for the selection, the professional services to be rendered, any proposed arrangement for compensation, and, to the best of the applicant's knowledge, all of the [firm's] connections with the debtor, creditors, any other party in interest, their respective attorneys and accountants, the United States trustee.\n\n26. The Chapter 11 Trustee requires the services of counsel in Switzerland to exercise his responsibilities. Prager Dreifuss will endeavor to avoid the duplication of efforts and provide services as efficiently as possible.\n\n27. Accordingly, the employment of Prager Dreifuss as the Chapter 11 Trustee's Swiss counsel, upon the terms set forth herein and in the Proposed Order, is reasonable and in the best interest of the Debtor's estate.\n\n28. The Chapter 11 Trustee submits that Prager Dreifuss' rates are reasonable, comparable to rates for other engagements, and within the range of rates charged by comparably skilled professionals who offer the same services.\n\n29. Local Bankruptcy Rule 2014-1 provides that if \"an application to employ a professional is filed within thirty (30) days after the commencement of services provided by that professional, the application shall be deemed contemporaneously filed unless the Court orders otherwise.\" Accordingly, the Chapter 11 Trustee requests authority to retain and employ Prager Dreifuss effective January 16, 2024, which was the date that Prager Dreifuss began providing services to the Chapter 11 Trustee.\n\n# **NOTICE**\n\n30. Notice of this Application has been given to the United States Trustee, the Debtor, the Committee, and, by electronic filing utilizing the Court's electronic filing (\"CM/ECF\") system, to all appearing parties who utilize the CM/ECF system.\n\n## **NO PRIOR REQUEST**\n\n31. No previous application for the relief requested herein has been made to this or any other Court.\n\n## **CONCLUSION**\n\nWHEREFORE, for the foregoing reasons, Luc A. Despins, the Chapter 11 Trustee, requests that the Court enter an Order, substantially in the form of the Proposed Order filed herewith, granting the Application, and authorizing the Chapter 11 Trustee's employment of Prager Dreifuss as Swiss law counsel, and order such other and further relief as the Court deems just and proper.\n\nDated: February 16, 2024 Chapter 11 Trustee in Chapter 11 Case of Ho Wan Kwok\n\n> */s/ Luc A. Despins* Luc A. Despins\n\n# **UNITED STATES BANKRUPTCY COURT DISTRICT OF CONNECTICUT BRIDGEPORT DIVISION**\n\n| | ---------------------------------------------------------------- | x | |\n|-----------------------|------------------------------------------------------------------|---|-------------------------|\n| | | : | |\n| In re: | | : | Chapter 11 |\n| | | : | |\n| HO WAN KWOK, et al.,1 | | : | Case No. 22-50073 (JAM) |\n| | | : | |\n| | Debtors. | : | (Jointly Administered) |\n\n# **CERTIFICATE OF SERVICE**\n\n:\n\nThe undersigned hereby certifies that on February 16, 2024, the foregoing Application was electronically filed. Notice of this filing was sent by e-mail to all parties to the above-captioned chapter 11 case by operation of the Court's electronic filing (\"CM/ECF\") system or by mail to anyone unable to accept electronic filing as indicated on the Notice of Electronic Filing. Parties may access this filing through the Court's CM/ECF system.\n\nDated: February 16, 2024\n\nBy: */s/ G. Alexander Bongartz*\n\nG. Alexander Bongartz (admitted *pro hac vice*) PAUL HASTINGS LLP 200 Park Avenue New York, New York 10166 (212) 318-6000 alexbongartz@paulhastings.com\n\n *Counsel for the Chapter 11 Trustee*\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\n# **Exhibit A**\n\n**Proposed Order**\n\n# **UNITED STATES BANKRUPTCY COURT DISTRICT OF CONNECTICUT BRIDGEPORT DIVISION**\n\n| ------------------------------------------------------ | x | |\n|--------------------------------------------------------|-------------|-------------------------|\n| In re: | :
: | Chapter 11 |\n| HO WAN KWOK, et al., | :
: | Case No. 22-50073 (JAM) |\n| Debtors.1 | :
:
: | Jointly Administered |\n| ------------------------------------------------------ | x | |\n\n# **[PROPOSED] ORDER (A) GRANTING APPLICATION OF CHAPTER 11 TRUSTEE FOR ENTRY OF ORDER, PURSUANT TO BANKRUPTCY CODE SECTIONS 327, 328, AND 330, BANKRUPTCY RULES 2014 AND 2016, AND LOCAL BANKRUPTCY RULES 2014-1 AND 2016-1, AUTHORIZING AND APPROVING RETENTION AND EMPLOYMENT OF PRAGER DREIFUSS AG AS SWISS LAW COUNSEL**\n\nUpon the application (the \"Application\")2 of Chapter 11 Trustee Luc A. Despins (the\n\n\"Chapter 11 Trustee\") in the above-captioned chapter 11 case (the \"Chapter 11 Case\"), (a) for authority to retain and employ Prager Dreifuss AG (\"Prager Dreifuss\") as counsel in Switzerland to the Chapter 11 Trustee, effective as of January 16, 2024, pursuant to sections 327, 328, and 330 of title 11 of the United States Code (the \"Bankruptcy Code\"), Rules 2014 and 2016 of the Federal Rules of Bankruptcy Procedure (the \"Bankruptcy Rules\"), and Rules 2014-1 and 2016-1 of the Local Rules of Bankruptcy Procedure for the United States Bankruptcy Court for the District of Connecticut (the \"Local Bankruptcy Rules\"), all as more fully set forth in the Application and the Engagement Letter; and upon consideration of the Application and the\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 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\n2 Capitalized terms used but not otherwise defined have the meanings set forth in the Application or the Hayek Declaration.\n\nHayek Declaration; and this Court having jurisdiction to consider the Application and the relief requested therein in accordance with 28 U.S.C. §§ 157 and 1334 and the Standing Order of Reference from the United States District Court for the District of Connecticut; and consideration of the Application and the relief requested therein being a core proceeding pursuant to 28 U.S.C. § 157(b); and venue being proper in this Court pursuant to 28 U.S.C. §§ 1408 and 1409; and the Court having found that (i) the relief requested in the Application is in the best interest of the Debtor's estate, its creditors, and all parties-in-interest, (ii) the legal and factual bases set forth in the Application and the Hayek Declaration, and the record of any hearing on the Application before this Court establish just cause for the relief granted herein, (iii) Prager Dreifuss is a \"disinterested person,\" as defined in section 101(14) of the Bankruptcy Code and as required by section 327(a) of the Bankruptcy Code, and (iv) Prager Dreifuss and its employees do not hold or represent an interest adverse to the Debtor's estate; and due and sufficient notice of the Application having been given under the particular circumstances; and it appearing that no other or further notice need be given; and upon all of the proceedings had before this Court; and after due deliberation and sufficient cause appearing therefor, it is hereby ORDERED THAT:\n\n1. The Application is granted as set forth herein.\n\n2. The Chapter 11 Trustee is authorized to retain and employ Prager Dreifuss as his Swiss law counsel effective as of January 16, 2024 on the terms set forth in the Application, the Engagement Letter, and the Hayek Declaration.\n\n3. Prager Dreifuss is authorized to act as the Chapter 11 Trustee's lawyers and to perform those services described in the Application.\n\n4. The Estate shall be responsible for Prager Dreifuss' compensation and reimbursement of expenses with respect to the engagement.\n\n5. The allowance of any compensation to be paid to Prager Dreifuss shall be determined in accordance with the procedures set forth in sections 330 and 331 of the Bankruptcy Code, Bankruptcy Rule 2016, Local Bankruptcy Rule 2016-1, and the Interim Compensation Order.\n\n6. Allowance of any compensation for Prager Dreifuss shall be limited to the extent of services actually performed (plus a flat fee for disbursements in an amount equal to 3% of total fees charged) as Swiss law counsel for the Chapter 11 Trustee Luc A. Despins, and shall not include compensation for the performance of any of the trustee duties that are generally performed by a Chapter 11 trustee without the assistance of an attorney.\n\n7. Prager Dreifuss is authorized to invoice its fees and expenses in Swiss Francs (CHF) and to have such fees and expenses paid in Swiss Francs (CHF), subject to the terms of the Interim Compensation Order.\n\n8. Prager Dreifuss shall provide no less than ten business days' notice to the Chapter 11 Trustee, the United States Trustee, and counsel to any official committee before any increases in the rates it charges are implemented and shall file such notice with the Court.\n\n9. The Chapter 11 Trustee is authorized and empowered to take all actions necessary to effectuate the relief granted in this Order.\n\n10. The requirements of the Local Bankruptcy Rules are satisfied by the contents of the Application.\n\n11. To the extent the Application, the Engagement Letter, and the Hayek Declaration are inconsistent with this Order, the terms of this Order shall govern.\n\n12. The terms and conditions of this Order shall be immediately effective and enforceable upon its entry.\n\n13. This Court shall retain jurisdiction with respect to all matters arising from or related to the implementation, interpretation, and enforcement of this Order.\n\n# **Exhibit B**\n\n**Engagement Letter**\n\n### ATTORNEYS AT LAW\n\nDr. Andreas Moll M C.J.\n\nDr. Christoph K. Graber Daniel Hayek LL.M. Dr. Hans-Ulrich Brunner LL.M.\n\nVerena Morscher-Guggenbühl LL.M\n\nProf. Dr. Philipp E. Zurkinden LL.M. Prof Dr. Urs Bertschinger Dr. Urs FeIler\n\nDr. Dion Christian Casanova LL M. Dr. Reto M. Jenny LL.M. Dr. Gion Jegher LL.M. Frddüric Gante Mark Meill LL.M. Dr. Andrea Stäubli Dr Andrea Schütz LL.M. Guy Deillon, LL M. Corinne Nobs LL M. Marcel Frey LL.M. Bernhard C. Lauterburg LL.M. Dr Christian Schönfeld LL.M MarkusSeglias\n\nMichaels Ksppeler LL.M. Raphael Keller LL.M. Dr. Rahel A. Nedi LL.M. Laura Richenberger Dr. MikeAbegg LL.M. Dr. Raphael Märki Anik S. Zehnder Mohsmed Hasnaoui Edith Schmidt LL.M.\n\nDr. Tis Prager Dr. Urs Brunner Gaudenz F. Domenig LL.M.\n\nRalph Butz LL M Dr.Marino Bsldi\n\nBy E-Mail Paul Hastings LLP Attn: Luc Despins 200 Park Avenue New York, NY 10166 USA\n\nZurich, 16 January 2024 VS PD 16.01 .24\n\n### Mandate Agreement regarding Ho Wan Kwok\n\nDear Luc\n\nAs Prager Dreifuss AG (\"Prager Dreifuss\") we would like to express our gratitude for the trust you have put in us. Please find below the terms of our mandate agreement with you. lt is our business mission to provide our clients with value-adding services. To ensure that this can be achieved in an efficient and effective manner, we have set out the terms of our business relationship in this mandate agreement. These terms shall henceforth form the basis of our cooperation.\n\n### 1. Matters of fact 1 Point of departure and assumptions\n\nlt is our understanding that Prager Dreifuss shall advise and represent Luc Despins (the \"Trustee\"), solely in his capacity as the chapter 11 trustee of the estate of Ho Wan Kwok, a/k/a Miles Guo (the \"Estat&'). The chapter 11 case of Ho Wan Kwok is pending in the United States Bankruptcy Court for the District of Connecticut (the \"Bankruptcy Court\").\n\n### 2. Scope of work\n\nThe scope of work performed by Prager Dreifuss shall encompass the re covery of assets in Switzerland of the Estate, in particular from Ho Wan Kwok and his son, Qiang Guo, and any related companies. This may in clude, if expressly approved in writing by the Trustee, the filing of criminal complaints, the initiation of ancillary insolvency proceedings and the en gagement of forensic firms. Swiss Banks which were potentially involved in\n\nMuhlebachstrasse 6, CH-8008 Zurich T+41 442545555, F +41 442545599 Schweizerhof-Passage 7, CH-3001 Berne T+41 31 3275454, F +41313275499\n\nAvenue Louise 235, 6-1 050 Brussels T+3225370949, F+32253721 16\n\n\n\nATTORNEYS AT LAW\n\nasset transfers of Ha Wan Kwok and Qiang Guo include Banque Gonet and MBAER Bank.\n\n### 3. Attorneys working on the matter\n\nThe matter described above shall primarily be attended to by Daniel Hayek (Partner, attorney at law), Gion Jegher (Partner, attorney at law), Mark Meili (Partner, attorney at law) and Edith Schmidt (associate, attorney at law).\n\nPrager Dreifuss shall be entitled, if the need therefore arises or the case in question requires so, to call upon further partners, caunsels or attorneys.\n\n### 4. Fees\n\n### 4.1 Hourlyrates\n\nAs a rule, the fees of Prager Dreifuss are charged based an the time spend an the mandate. The hourly rate of partners in our law firm ranges between CHF 500 and CHF 900. The work performed by associates is charged at between CHF 275 and CHF 450 per hour. In general, we da not charge any supplements (i.e. for Sunday or night work, particularly complex legal issues, foreign language work, etc.) and we propose not to da so in this matter. We will, however, charge a flatfee tor disbursements, which amounts to 3% of the total fees. Since the Client is domiciled outside of Switzerland, the fees of Prager Dreifuss are not subject ta Swiss VAT.\n\nA detailed schedule of fees reflecting the work performed shall be provided to you every 30 days.\n\nIn the case at hand the following hourly rates shall be applicable: Daniel Hayek: CHF 750, Gion Jegher: CHF 650, Mark Meili: CHF 550 and Edith Schmidt: CHF 400 (which are the rates that such attorneys regularly charge to firm clients).\n\nThe invoice shall be based an the time spent an the matter pursuant to this mandate agreement, including legal research, documentation, analysis, meetings and travel time (to the extent such travel time is approved by the Trustee prior ta travel).\n\nATTORNEYS AT LAW\n\n### 4.2 Invoicing\n\nlnvoices are issued on a monthly basis, atthe latest, however, afterthe con clusion of the services rendered. lnvoices shall be paid in accordance with the United States Bankruptcy Code, the Federal Rules of Bankruptcy Pro cedure, and the compensation procedures established and required by the Bankruptcy Court. In case of arrears in payments, Prager Dreifuss reserves its right to terminate this mandate agreement with an adequate period of notice. Work done in connection with the enforcement of the payment shall be invoiced at the normal hourly rates.\n\n### 5. Instruction and communication\n\nCurrently, we shall accept instructions solely from Luc Despins of Paul Has tings LLP. Please let us know in writing, should the right of instruction be extended to other persons.\n\nCommunication and correspondence with you, counterparties or third par ties may take electronic form (e.g. internet, e-mail etc.).\n\nE-mail communication and communication by other electronic means bear a higher risk with regard to data protection and potential unauthorized access. In this regard Prager Dreifuss shall not be liable for any damages resulting from the non-receipt, late receipt or falsification of information or the breach of confidentiality of such information.\n\nDespite performing regular virus checks on our computer and data systems we advise you to also perform such checks on your behalf. Prager Dreifuss shall not be liable for any damages caused to your systems or data owing to virus activity.\n\n### 6. Conflicts of interest\n\nWe confirm that we have performed an internal conflict of interest check and that currently, to the best of our knowledge, no such conflict of interest exists which might influence our work for you in this matter.\n\nWe are bound by the applicable rules governing conflicts of interest. lt might therefore become necessary for us to suspend our work for you owing to a conflict of interest arising in the future.\n\nATTORNEYS AT LAW\n\nEven in the absence of a conflict of interest, it is conceivable that we could act for other clients or that we could be in possession of information by other clients, which are engaged in a similar line of business as yourself and which might be viewed by you as your competitors. We are not obliged to disclose to you such information where this could constitute a breach of trust visvis another client or a third party.\n\n### 7. Termination\n\nYou are entitled to terminate this mandate agreement at any time. Prager Dreifuss shall be entitled to terminate this mandate agreement if (a) a conflict of interests arises, (b) a due payment to Prager Dreifuss is not effected, (c) Prager Dreifuss does not receive complete or adequate instructions or where such instruction are contradictory, or (d) if further work by Prager Dreifuss should become impossible in view of the applicable rules of the profession. In case of termination, all due fees and disbursements until the termination, including those fees and disbursements arising for reason of the termination of the mandate agreement or because of the handing over of the matter to a different advisor of your choice, shall be borne by you.\n\n### 8. Storage offiles\n\nSwiss law requires us to store all correspondence and other documentation pertaining to the mandate for a period of ten years since the termination of the mandate agreement. After this period, Prager Dreifuss shall be entitled to destroy the documents of the client file without further notice.\n\n### 9. Liability and limitation of liability\n\nSave for gross negligence and willful intent, Prager Dreifuss does not accept any liability for damages. Any claims shall be addressed solely at Prager Dreifuss and cannot be made against employees, councils, associates or partners of Prager Dreifuss.\n\nThe services rendered by Prager Dreifuss are exclusively for your own purpose and may not be used for other purposes without our prior written approval nor given to third parties (save to your professional advisors, who may not rely on our services).\n\nATTORNEYS AT LAW\n\nPrager Dreifuss does not assume responsibility for advisory services which you have received from third parties, irrespective of the type, scope or appropriateness of such advice or performance of the advisor. lt shall remain the responsibility of the client to ensure that these advisory services are ren dered and that they are appropriate for your requirements.\n\n### 10. Professional Confidentiality\n\nWe are bound by professional confidentially obligations pursuant to art. 13 of the Federal Act on the Freedom of Movement tor Lawyers and art. 321 of the Swiss Penal Code (breach of professional confidentiality). Hence we are not allowed to disclose contidential information that has been confided to us in our professional capacity, unless this duty is waived by the Client, the relevant supervisory body or if itforms a part of the mandate to communicate certain information to third-parties. Further, the communication with officers of Client who deal with the project do not fall under these professional confidentiality obligations.\n\n### 11. Applicable Iaw and place ofjurisdiction\n\nThis mandate agreement shall be governed in its entirety by Swiss law (to the exclusion of the rules on the conflict of Iaws). Disputes, differences of opinion and claims arising from or in connection with this mandate agree ment, including the validity, invalidity, breach or termination thereof shall be resolved by arbitration in accordance with the Swiss Rules of International Arbitration of the Swiss Chambers' Arbitration Institution; provided, however, that all matters related to the payment and allowance of our fees and ex penses shall be determined by the Bankruptcy Court. The version of the arbitration rules in force on the date of the filing of the notice of arbitration shall be applicable. The number of arbitrators shall be one. The arbitral proceedings shall be conducted in English and the seat of the arbitration shall be in Zurich.\n\nThe provisions above shall formally constitute our business terms. Please contact us should you wish to discuss these. To confirm your agreement with these business terms, please sign the enclosed copy of this mandate agree ment and return it to us by fax (+41 44 254 55 99) or by PDF e-mail attach ment (to: daniel.hayek@prager-dreifuss.com).\n\nCase 22-50073 Doc 2931 Filed 02/16/24 Entered 02/16/24 18:40:15 Page 22 of 39\n\n### PRAGER DREIFUSS\n\nATTORNEYS AT LAW\n\nlt is a privilege for us to act as attorneys tor you an this project. Rest assured that our law firm and every attorney engaged in this matter will play his part with the utmost commitment, enthusiasm and show of team spirit.\n\nYours sincerely\n\nPreifuss\n\nDaniel Hayek\n\n(\\\n\nGb Jegher\n\n# Case 22-50073 Doc 2931 Filed 02/16/24 Entered 02/16/24 18:40:15 Page 23 of 39\n\n\n\n# **Exhibit C**\n\n# **Hayek Declaration**\n\n### UNITED STATES BANKRUPTCY COURT DISTRICT OF CONNECTICUT BRIDGEPORT DIVISION\n\nx\n\n:\n\n:\n\nx\n\nIn rc:\n\nChapter 11\n\nCase No.\n\nHO WAN KWOK, et al.,\n\nJointlyAdministered\n\n22-50073 (JAM)\n\nDcbtors.'\n\n### DECLARATION OF DANIEL HAYEK IN SUPPORT OF APPLICATION OF CHAPTER 11 TRUSTEE FOR ENTRY OF ORDER, PURSUANT TO BANKRUPTCY CODE SECTIONS 327, 328, AND 330, BANKRUPTCY RULES 2014 AND 2016, AND LOCAL BANKRUPTCY RULES 2014-1 AND 2016-1, AUTHORIZING AND APPROVING RETENTION AND EMPLOYMENT OF PRAGER DREIFUSS AG AS SWISS LAW COUNSEL\n\n1, Daniel Hayek, being duly sworn, do depose and say:\n\n1. 1 am a lawyer admitted to practice in Switzerland since 1993, and the chairman of the board ofthe law firm Prager Dreifuss AG (\"Prager Dreifuss\"), which maintains its principal office at 6 Mühlebachstrasse, Zurich 8008, Switzerland, and 1 make this deciaration (the \"Declaration\") in support of the Application ofChapter 11 Trusteefor Entiy ofOrder, Fursuant to Sections 327, 328, and 330 oftlie Bankruptcy Code, Bankruptcy Rules 2014 and 2016, und Local Bankruptcy Rules 2014-1 und 2016-1, Authorizing andApproving Retention und Enip!oymentofFragerDreifussAGasSwissLawCounsel,withrespecttotheTrustee's\n\nThe Debtors n these chapter 11 cases are Ho Wan Kwok (also known as Guo Wengui, Miles Guo, and Miles Kwok, as weil as nurnerous other aliases) (last four digits oftax identification number: 9595) Genever Holdings LLC (last four digits oftax identification number: 8202) and Genever Holdings Corporation. The mailing address for the Trustee, Genever Holdings LLC, and Genever Holdings Corporation is Paul Hastings LLP, 200 Park Avenue, New York, NY 10166 c/o Luc A. Despins, as Trustee for the Estate ofHo Wan Kwok (soleiy for purposes ofnotices and communications).\n\ninvestigation of the Debtor's estate and assets in Switzerland and related matters (the \"Engagement\").\n\n2. In relation to the Engagement, (a) Prager Dreifuss' professional client is the estate (the \"Estate\") ofHo Wan Kwok (the \"Debtor\") in his above-captioned chapter 11 case (the \"Chapter 11 Case\") and (b) Prager Dreifuss will seek to recover its fees from the Estate and will file fee statcrncnts and fee applications in the Chapter 11 Case in accordance with the Interim Compensation Order.\n\n3. 1 received a legal degree from the University ofZurich, and am a graduate ofthe New York University where 1 received an LLM. My experience encompasses acquisitions of Swiss companies by large stratcgic buycrs as weil as on debt restructuring and bankruptcy law, including the representation ofchapter 11 trustees. 1 also specializes in corporate finance, acquisitions, banking and finance as weil as corporate iaw issues, and advise clients on all types of domestic and cross-border transactions.\n\n4. Prager Dreifuss will file applications for compensation ofprofessional services rendercd and for reimbursement of expenses incurred in connection with the Engagement pursuantto sections 330 and 331 ofthe Bankruptcy Code, Bankruptcy Rule 2016, Local Bankruptcy Rule 2016- 1, and any other applicable rules and orders with respect to this Chapter 11 Case, including thc Interim Compensation Order.\n\n5. Prager Dreifuss will charge its normal billing rates in connection with the Engagement. At present, the 2024 hourly rates of Prager Dreifuss are between CHF 275 and CHF 450 for associates (which, at culTent exchange rates, converts into approximately \\$3 15 to \\$516) and between CHF 500 to CHF 900 for partners (which, at current cxchange rates, converts into approximately \\$574 and \\$ 1,033). Prager Dreifuss will also charge a fiat fee for\n\ndisbursements made on behalf ofthe Debtor, which fiat fee amounts will be equal to 3% ofthe total fees charged. For work conducted by me on this Engagement, Prager Dreifuss will charge an hourly rate of CHF 750 (which, at current exchange rates, converts into approximately \\$863). As is the practice for most Swiss law firrns, Prager Dreifuss does not have internal processes in place for tracking administrative expenses made on behalf ofthe Debtor, such as photocopying, postage, and package deliveries. Therefore, Prager Dreifuss will instead charge a fiat fee for disbursements, which fiat fee will be equal to 3% ofthe total fees charged in connection with its legal services.\n\n6. To the best of my knowledge and belief after due inquily, Prager Dreifuss is a \"disinterested person\" within the meaning ofsection 101(14) oftitle 11 ofthe United States Code (the \"Bankruptcy Code\") in that Prager Dreifuss and each of Prager Dreifuss' lawyers:\n\n- a. arc not creditors, equity security holders, or insiders of the Debtor;\n- b. are not, and were not within two years before the date of fihing ofthe Debtor's petition, directors, officers, or employees ofthe Debtor; and\n- c. do not have an interest rnaterially adverse to the interest ofthe Debtor's estate or of any dass of creditors or equity security holders, by reason of any direct or indirect relationship to, connection with, or interest in, the Debtor, or for any other reason.\n\n7. 1 attach to this Declaration, as Schedule 1, a consolidated list ofparties in interest in connection with the Chapter 11 Case (the \"Interested Pailies\") that has been produced by Paul Hastings and provided to Prager Dreifuss before my signing this Declaration that 1 am informed includes:\n\n- a. parties listcd as creditors, executory contract counterpartics, and co dcbtors on the Debtor's Schedules D, F, G, and H [Docket No. 78];\n- b. parties listed on the Debtor's Statement of Financial Affairs (\"SOFA\") [Docket No. 77], including (i) as recipients ofpayments within 90 days prior to the fihing ofthe Chapter 11 Case (SOFA Part 3, Question 6); (ii) parties involved in litigation in which the Debtor is a party (SOFA Part 4, Qucstion 9); and businesses owned by the Dcbtor (SOFA Part 11, Question 27).\n- c. parties and counsel fihing notice of appearances in the Chapter 11 Case;\n- d. the Court and personnel ofthe office of the United States Trustee; and\n- e. other parties in interest that 1 have become aware of as a result of the Chapter 11 Trustee's ongoing investigation of the Debtor's assets.\n\nPrager Dreifuss has conducted reasonable checks of the Interested Parties against our records and data, and has determined that to the best of our knowledge and belief, neither Prager Dreifuss nor any ofthe firm's lawyers, has any relationship or connection with the Interested Parties, or, to the best of my knowledge, with any other creditor of the Debtor.\n\n8. While Prager Dreifuss has made a diligent effort to ascertain the identity of any connections or potential conflicts with the Interested Parties, to the extent that any additional information comes to light, 1 will review, diselose, and resolve any conflict or adverse interests that may appear.\n\n9. Based on the foregoing, insofar as 1 have been able to ascertain based on the information currently available to me: (a) Prager Dreifuss and each its lawyers have no connection with the Debtor, his creditors, the U.S. Trustee, any person employed in the office of the U.S. Trustee, or any other party with an actual or potential interest in the Debtor or his respective attorneys or accountants; and (b) (i) Prager Dreifuss and each its lawyers are not creditors, equity security holders, or insiders of the Debtor or his affihiates, (ii) Prager Dreifuss and each its lawyers have not been, within two years before the Petition Date, a director, officer, oi employee of the Debtor or his affihiates, and (iii) Prager Dreifuss and each its lawyers do not have any interest materially adverse to the interests of the Debtor's estate or any dass of creditors or equity security holders by reason of any direct or indirect relationship to, connection with, or interest in the Debtor, or for any other reason. Therefore, 1 understand from my discussions with Paul Hastings that this means Prager Dreifuss is a \"disinterested person\" within the meaning ofsection 101(14) of the Bankruptcy Code, as modified by section 1107(b).\n\n10. 1 further understand from such discussions that Appendix B ofthe U.S. Trustee Guidelines (the \"Larger Case Guidelines\") does not apply in this Chapter 11 Case, because the Debtor's petition does not list \\$50 million or more in assets and \\$50 million or more in liabilities. In particular, 1 am informed that the Debtor estimated the value ofhis assets between \\$50,00 1 and \\$ 100,000.\n\n11. In the interest ofproviding maximum disclosure, and notwithstanding my position concerning the inapplicability ofthe Larger Case Guidelines, 1 provide the following response on behalf of Prager Dreifuss to the request for information set forth in Paragraph D. 1. of the Larger Case Guidelines:\n\n> Question: Did you agree to any variations from, or alternatives to, your standard or customary billing arrangements for this engagement?\n\nAnswer: No.\n\n- Ouestion: Do any of the professionals included in this engagement vary their rate based on the geographic location ofthe bankruptcy case?\n- Answer: No.\n- Ouestion: If you represented the client in the 12 months prepetition, disclose your billing rates and material financial terms for the prepetition engagement, including any adjustments during the 12 months prepetition. Ifyour billing rates and material financial terms have changed postpetition, explain the difference and the reasons for the difference.\n- Answer: Not applicable. Prager Dreifuss has not previously represented the Chapter 11 Trustee.\n- Question: Has your client approved your prospective budget and staffing plan, and, if so, for what budget period?\n\nAnswer: Not applicable.\n\n12. 1 have neither shared nor agreed to share with any other person compensation\n\nreceived in connection with the Engagement, except as is perrnitted by section 504(b)(1) ofthe\n\nBankntptcy Code.\n\n13. 1 consent that the following language may be included in any order by the Court approving the Chapter 11 Trustee's application in connection with my instruction in connection with theEngagement.\n\n> Allowance of any compensation for Prager Dreifuss shall be limited to the extent of services actually performed (plus a fiat fee for disbursements in an amount equal to 3% of total fees charged) as Swiss law counsel for the Chapter 11 Trustee Luc A. Despins, and shall not include compensation for the performance of any of the trustee duties that arc generally performed by a Chapter 11 trustee without the assistance of an attorney.\n\n14. As is standard for engagement of Swiss law firms, any disputes and claims arising\n\nfrom or in connection with the engagement letter between the Trustee and Prager Dreifuss in\n\nconnection with Prager Dreifuss' retention, including the validity, invalidity, breach or termination thereof, will be resolved by arbitration in accordance with the Swiss Rules of International Arbitration of the Swiss Chambers' Arbitration Institution; provided, however, that all matters related to the payment and allowance of Prager Dreifuss' fees and expenses shall be determined by the Bankruptcy Court. This arbitration clause is a requirement for Prager Dreifuss' to be able to maintain liability insurance coverage.\n\nPursuantto 28 U.S.C. § 1746,1 declare underpenalty of perjury that the above statements are true and correct.\n\nDated: February 16, 2024, at Zürich, Switzerland\n\nCase 22-50073 Doc 2931 Filed 02/16/24 Entered 02/16/24 18:40:15 Page 32 of 39\n\n### Schedule 1\n\n### SCHEDULE OF PARTIES IN INTEREST - IN RE KWOK\n\n20 LARGEST UNSECURED CREDITORS PACIFIC ALLIANCE ASTA OPPORRJNITYGOLDEN SPRING NEW YORK RUI MA CHENG JIAN WU JIAN SHE NING YE GUO BAOSHENG YAN LAN & WU ZHENG HONG QI QU NAN TONG S1 JIAN JIAN GONG YAN ZHAO YUA HUA ZH1JANG SHI LIEHONG ZHUANG/XIAO YAN ZHU WEICAN MENG/BOXUN INC. SAMUEL NUNBERG LAMP CAPITAL LLC JUN CHEN AKA JONATHAN HO YUE HUA ZF{U SHI XIONG XIAN WEI YE HUIZENWANG\n\n### DEBTOR, FAMILY MEMBERS, AND\n\nCERTAIN RELATED ENTITIES HO WAN KWOK (A.K.A MILES GWOK. MILES GUO AND WENGUT GUO) HING CH NGOK/YUE QINGZHI QIANG GUO (A.K.A. MILESON GUO) MET GUO/MEI GUI HK INTERNATIONAL FUNDS INVESTMENTS (USA) LIMITED, LLC BRAVO LUCK LIMITED GENEVER HOLDINGS CORPORATION GENEVER HOLDINGS LLC\n\n### BANKRIJPTCY JUDGE AND U.S. TRUSTEE\n\nPERSONNEL HONORABLE JULIE A. MANNING WILLIAM HARRINGTON KlM L. MCCABE HOLLEY CLAIBORN JOSEPH H. FLAMINT ERIN HOGAN STEVEN MACKEY FRAM( MARJNO JENNIFER J. MOREY N1COLE NEELY SHARON WARNER JOHN GERVAIS\n\n### OTHER INTERESTED PARTIES\n\n1332156 B.C. LTD 17 MILES, LLC 7 NOD HILL LLC, 7 STAREASTNYLLC AAGV LIMITED AARON A. MITCHELL ABRAMS FENSTERMAN, LLP ACA CAPITAL GROUP LIMITED ACA INVESTMENT FUND ACA TNVESTMENT MANAGEMENT LTD. ACASS CANADA LTD. ACE DECADE HOLDINGS LIMITED ADAM CHEN NT AFFILIATED ADJUSTMENT GROUP, LTD. Al GROUP HOLDINGS INC., AIG PROPERTY CASUALTY COMPANY AKERMAN LLP ALEX HADJICHARALAMBOUS ALFA GLOBAL VENTURES LIMITED ALFONSO GLOBAL LIMITED ALLIED CAPITAL GLOBAL LIMITED ALPINE FIDUCIARIES SA AMAZON WEB SERVICES LLC AMAZON.COM INC. AN HONG ANA C. 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