{"id":"court_ctb_3107_0","court":"CTB","case_no":"22-50073","doc_number":3107,"sub_number":0,"doc_type":"MOTION","filed_date":"2024-04-18","title":"UNITED STATES BANKRUPTCY COURT DISTRICT OF CONNECTICUT BRIDGEPORT DIVISION In re: Chapter 11","summary_zh":null,"summary_en":null,"body_en":"## **UNITED STATES BANKRUPTCY COURT DISTRICT OF CONNECTICUT BRIDGEPORT DIVISION**\n\nIn re: Chapter 11\n\nHO WAN KWOK, *et al.*, Case No. 22-50073 (JAM)\n\nDebtors.[1](#page-0-0)\n\n(Jointly Administered)\n\nLUC A. DESPINS, CHAPTER 11 TRUSTEE,\n\nPlaintiff, Adv. Proceeding No. 24-05007\n\nv.\n\nBLUEBERRY BUILDERS, LLC, Defendant April 22, 2024\n\n# **MOTION TO APPEAR PRO HAC VICE – ATTORNEY ODEN**\n\nIn accordance with the D. Conn. L. Civ. R. 83.1(d), I , David B. Zabel, an active member of the Bar of the U.S. District Court for the District of Connecticut, respectfully request that the Court admit Attorney Amy M. Oden pro hac vice to the Bar of this Court for the purpose of appearing on behalf of defendant Blueberry Builders, LLC, in the above-captioned Chapter 11 case and Adversary Proceeding. The Affidavit of Visiting Attorney by Attorney Oden in support of her admission pro hac vice is attached hereto.\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\nAs the sponsoring attorney, I am a member of the bar of this Court and have an appearance in the Chapter 11 case and Adversary Proceeding. The filing fee has been paid and I maintain the address listed below.\n\nIf this motion is granted, I request to be excused from attendance in Court and participation in other proceedings before the Court. It is likewise requested that Attorney Heather R. Spaide, another attorney with our firm who has entered an appearance in the Adversary Proceeding, also be excused from attendance in Court and participation in other proceedings before the Court.\n\nBy Sponsoring Attorney: David B. Zabel\n\n Marino, Zabel & Schellenberg, PLLC 657 Orange Center Road Orange, CT 06477 Tele: (203) 864-4511 Fax: (203) 456-8249 E-mail: [dzabel@mzslaw.com](mailto:dzabel@mzslaw.com) Federal Bar No. ct01382\n\nDated: April 18, 2024 By: /s/ David B. Zabel\n\n David B. Zabel, Esq. Federal Bar No. ct01382 Marino, Zabel & Schellenberg, PLLC 657 Orange Center Road Orange, CT 06477 Tele: (203) 864-4511 Fax: (203) 456-8249 E-mail: [dzabel@mzslaw.com](mailto:dzabel@mzslaw.com)\n\n*Local Counsel to Blueberry Builders, LLC*\n\n#### **CERTIFICATION OF SERVICE**\n\nI hereby certify that on April 22, 2024, a copy of the foregoing Motion to Appear Pro Hac Vice – Attorney Oden was filed electronically. Notice of filing will be sent by e-mail to all parties by operation of the Court's electronic filing system and by mail to any parties who are unable to accept electronic filing as indicated on the Notice of Electronic Filing.\n\nParties may access this filing through the Court's CM/ECF system.\n\n /s/ David B. Zabel David B. Zabel\n\n## **AFFIDAVIT OF VISTING ATTORNEY**\n\nI, , make this affidavit in support of Amy Oden\n\na motion to appear pro hac vice pursuant to Local Rule 83.1(d):\n\na) My office information is:\n\n| Firm | |\n|---------|--|\n| Address | |\n| Phone | |\n| Number | |\n| Fax | |\n| | |\n| Email | |\n\nb) I am a member of the bar of the following court(s), and I include the corresponding bar identification number(s):\n\n| Court | Bar
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issued) |\n|-------|---------------------------------------------------------------------|\n| | |\n| | |\n| | |\n| | |\n| | |\n| | |\n| | |\n| | |\n\n- c) I have no pending disciplinary complaints as to which a finding has been made that such complaint should proceed to a hearing;\n- d) I have not been denied admission to, been disciplined by, resigned from, surrendered a license to practice before, or withdrawn an application for admission to practice while facing a disciplinary complaint before, this Court or any other court;\n\nor, if I cannot so state as to subsections (c) and (d), then I attach a description in full of the circumstances of any such complaint, denial, discipline, resignation, surrender, or\n\nwithdrawal, including the reasons therefor, any penalty, sanction or other discipline imposed, whether such discipline was satisfied, and whether I am currently in good standing in such jurisdiction(s);\n\n- e) I have fully reviewed and am familiar with the Federal Rules of Civil Procedure (for an attorney seeking admission in a civil case) or Criminal Procedure (for an attorney seeking admission in a criminal case), the applicable Local Rules of the United States District Court for the District of Connecticut, and the Connecticut Rules of Professional Conduct;\n- f) I designate the sponsoring attorney as my agent for service of process and the District of Connecticut as the forum for the resolution of any dispute arising out of my admission under this Local Rule 83.1(d), including matters involving grievances filed against the visiting attorney and matters of attorney discipline that relate thereto;\n- g) I understand that upon admission under this rule I must promptly file with the Clerk of Court a certificate of good standing from the court of the state in which I have my primary office. I acknowledge that the certificate shall be filed no later than 60 days after the date of admission and shall be dated no more than 60 days before the date of admission. I understand that failure to file such certificate will result in the automatic revocation of my visiting attorney status, absent an order of the Court. Furthermore, I understand that upon revocation of my visiting attorney status in one case, the Clerk of the Court shall examine the Court's Docket and revoke my visiting attorney status in all cases in which I have filed an appearance.\n\nCertificate of good standing:\n\n\n\nhas been included with this filing. will be filed within 60 days after admission.\n\nh) I will file my appearance with the Court after my admission has been approved.\n\nI hereby certify that the information provided on this form is true, correct, and complete as of this day of , 20 . 22nd April 24\n\nSigned\n\n#### **UNITED STATES BANKRUPTCY COURT DISTRICT OF CONNECTICUT BRIDGEPORT DIVISION**\n\nIn re:\n\nChapter 11\n\nHO WAN KWOK, *et al.*,\n\n(Jointly Administered)\n\nCase No. 22-50073 (JAM)\n\nDebtors.[1](#page-5-0)\n\n#### **NOTICE OF APPEARANCE**\n\nTo the Clerk of this Court and all parties of record:\n\nPLEASE TAKE NOTICE that the undersigned counsel hereby enters an appearance as counsel for Blueberry Builders, LLC, a party-in-interest in the above-captioned case as a defendant in an adversary proceeding that has been commenced in connection with the abovecaptioned case, and pursuant to, inter alia, Bankruptcy Rules 2002, 2015 and 9007, and Sections 102(1) and 1109 of the Bankruptcy Code, requests that all notices given or required to be given in the above-captioned case and all papers served in the above-captioned case be given to and served upon the undersigned at the address set forth below. I am admitted or otherwise authorized to practice in this court.\n\nPLEASE TAKE FURTHER NOTICE that this Notice of Appearance shall not be deemed or construed to be a waiver of Blueberry Builders' rights, if any: (1) to have final orders in noncore matters entered only after de novo review by a United States District Judge; (2) to a trial by\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\njury in any proceeding so triable in this case, or in any case, controversy or proceeding related to this case; (3) to have the United States District Court withdraw the reference in any matter or proceeding subject to mandatory or discretionary withdrawal of reference; or (4) regarding any claims, defenses, actions, setoffs, recoupments or other rights of any nature whatsoever, all of which are expressly reserved.\n\nDated: April 22, 2024 By: /s/ Heather R. Spaide Heather R. Spaide, Esq. Federal Bar No. ct27705 Marino, Zabel & Schellenberg, PLLC 657 Orange Center Road Orange, CT 06477 Tele: (203) 864-4511 Fax: (203) 456-8249 E-mail: [hspaide@mzslaw.com](mailto:hspaide@mzslaw.com)\n\n*Local Counsel to Blueberry Builders, LLC*\n\n## **CERTIFICATION OF SERVICE**\n\nI hereby certify that on April 22, 2024, a copy of the foregoing Notice of Appearance was filed electronically. Notice of filing will be sent by e-mail to all parties by operation of the Court's electronic filing system and by mail to any parties who are unable to accept electronic filing as indicated on the Notice of Electronic Filing.\n\nParties may access this filing through the Court's CM/ECF system.\n\n /s/ Heather R. Spaide Heather R. Spaide","body_zh":null,"key_entities":["Kwok","Ho Wan Kwok","Guo","Despins","Miles Guo","Paul Hastings","CIPA","Je"],"ecf_references":[],"word_count":1526,"status":"published","published_at":"2024-04-18 00:00:00","created_at":"2024-04-18","updated_at":"2026-07-07 08:11:17"}