{"id":"court_ctb_3193_0","court":"CTB","case_no":"22-50073","doc_number":3193,"sub_number":0,"doc_type":"ORDER","filed_date":"2024-05-16","title":"UNITED STATES BANKRUPTCY COURT DISTRICT OF CONNECTICUT BRIDGEPORT DIVISION | -------------------------------------------","summary_zh":"受托人第十五次第 2004 条调查综合补充动议 —— Ho Wan Kwok 破产案（郭文贵 / Guo Wengui / Miles Guo），CTB 22-50073 ECF #3193（2024-05-16立案）。第 11 章受托人 Luc A. Despins 根据《联邦破产诉讼程序规则》第 2004 条提出动议，申请授权向更多关联个人、相关银行及汽车经销商发出传票调取文件与证言，以深入调查债务人财产线索。","summary_en":"Trustee's fifteenth supplemental omnibus Rule 2004 discovery motion —— In re Ho Wan Kwok (Miles Guo / Guo Wengui), CTB 22-50073 ECF #3193 (filed 2024-05-16). Chapter 11 Trustee Luc A. Despins moved under Bankruptcy Rule 2004 for authorization to issue subpoenas for documents and testimony to additional affiliated individuals, relevant banks, and automobile dealerships to investigate estate assets.","body_en":"# **UNITED STATES BANKRUPTCY COURT DISTRICT OF CONNECTICUT BRIDGEPORT DIVISION**\n\n| ----------------------------------------------------------- | x      |                         |\n|-------------------------------------------------------------|--------|-------------------------|\n| In re:                                                      | :<br>: | Chapter 11              |\n|                                                             | :      |                         |\n| 1<br>HO WAN KWOK,<br>et al.,                                | :<br>: | Case No. 22-50073 (JAM) |\n| Debtors.                                                    | :      | (Jointly Administered)  |\n| ----------------------------------------------------------- | :<br>x |                         |\n\n# **FIFTEENTH 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 INDIVIDUALS AFFILIATED WITH THE DEBTOR, RELEVANT BANKS AND ENTITIES THAT DEAL IN AUTOMOBILES**\n\nLuc A. Despins, in his capacity as the Chapter 11 Trustee (the \"Trustee\") appointed in the above-captioned chapter 11 case (the \"Case\") of Ho Wan Kwok (the \"Debtor\"), by and through his undersigned counsel, pursuant to Federal Rule of Bankruptcy Procedure 2004(a) (the \"Bankruptcy Rules\") and Local Bankruptcy Rule 2004-1 (the \"Local Rules\"), hereby applies (the \"Application\" or \"Motion\") to conduct the examination<sup>2</sup> of certain banks and financial institutions, entities that deal in automobiles, and individuals associated with the Debtor and his alter ego shell companies (the \"Examinees\") which the Trustee believes the Debtor and Related Persons\n\n<sup>1</sup> The Debtors in these chapter 11 cases are Ho Wan Kwok (also known as Guo Wengui, Miles Guo, and Miles Kwok, as well as numerous other aliases) (last four digits of tax identification number: 9595), Genever Holdings LLC (last four digits of tax identification number: 8202) and Genever Holdings Corporation. The mailing address for the Trustee, Genever Holdings LLC, and the Genever Holdings Corporation is Paul Hastings LLP, 200 Park Avenue, New York, NY 10166 c/o Luc A. Despins, as Trustee for the Estate of Ho Wan Kwok (solely for purposes of notices and communications).\n\n<sup>2</sup> By this Motion, the Trustee seeks the authority to conduct his examination of the Examinees by serving subpoenas which call for both document production and deposition testimony. For the avoidance of doubt, the Trustee will not conduct depositions of the Examinees within the stay period pursuant to the *Order Staying Adversary Proceedings and Granting Other Related Relief Pending Disposition of Criminal Proceeding* [ECF No. 3038] without advance permission from the Court.\n\nconducted business relevant to the estate of the Debtor, as such Examinees are identified in **Exhibit B**, attached hereto. **Please take notice that the deadline to object to this Application is May 23, 2024, and in the absence of a timely filed objection, the proposed order filed herewith as Exhibit A (the \"Proposed Order\") may enter without further notice and hearing**. In support of his Application, the Trustee respectfully states as follows:\n\n## **PRELIMINARY STATEMENT**\n\n1. The Trustee, in furtherance of his duties and responsibilities under the order authorizing the appointment of a chapter 11 trustee dated July 6, 2022, (*See* ECF. No. 465, at 14, hereinafter referred to as the \"Trustee Order\"), continues his investigation into the Debtor's financial and business affairs to determine whether additional estate assets exist and to recover upon those assets for the benefit of the Debtor's estate.\n\n2. The Trustee's investigation has identified more entities with possible knowledge of the Debtor's assets and financial activities, and the Trustee seeks to further his investigation through additional Bankruptcy Rule 2004 discovery of these Examinees.\n\n3. The Trustee believes that the Examinees have access to and understandings of information relating to the Debtor's assets, financial affairs, and potential financial interests in various corporate entities related to the Debtor, his family, or his associates, including, without limitation, entities that are the Debtor's alter egos.\n\n4. The Trustee has submitted multiple Bankruptcy Rule 2004 motions granted by the Court, including one directed at legal and financial firms believed to have advised the Debtor and related entities and individuals (ECF No. 637, the \"Advisors 2004 Motion\"), one directed at entities and individuals believed to be affiliated with, controlled by, or otherwise connected to the Debtor (the \"Affiliates 2004 Motion\"), the Trustee's First Supplemental Omnibus Motion dated\n\nSeptember 7, 2022 (the \"First Omnibus Motion\"), the Trustee's Second Supplemental Omnibus Motion dated November 18, 2022 (the \"Second Omnibus Motion\"), the Trustee's Third Supplemental Omnibus Motion dated December 21, 2022 (the \"Third Omnibus Motion,\"), the Trustee's Fourth Supplemental Omnibus Motion dated March 24, 2023 (the \"Fourth Omnibus Motion\"), the Trustee's Fifth Supplemental Omnibus Motion dated May 15, 2023 (the \"Fifth Omnibus Motion\"), the Trustee's Sixth Supplemental Omnibus Motion dated August 11, 2023 (the \"Sixth Omnibus Motion,\"), the Trustee's Seventh Supplemental Omnibus Motion dated October 10, 2023 (the \"Seventh Omnibus Motion\"), the Trustee's Eighth Supplemental Omnibus Motion dated November 2, 2023 (the \"Eighth Omnibus Motion\"), the Trustee's Ninth Supplemental Omnibus Motion dated November 6, 2023 (the \"Ninth Omnibus Motion\"), the Trustee's Tenth Supplemental Omnibus Motion dated December 14, 2023 (the \"Tenth Omnibus Motion\"), the Trustee's Eleventh Supplemental Omnibus Motion dated January 16, 2024 (the \"Eleventh Omnibus Motion\"), the Trustee's Twelfth Supplemental Omnibus Motion dated January 30, 2024 (the \"Twelfth Omnibus Motion\"), the Trustee's Thirteenth Supplemental Omnibus Motion dated March 21, 2024 (the \"Thirteenth Omnibus Motion\") and the Trustee's Fourteenth Supplemental Omnibus Motion dated March 25, 2024 (the \"Fourteenth Omnibus Motion,\" together with the Advisors 2004 Motion, the Affiliates 2004 Motion, the First Omnibus Motion, the Second Omnibus Motion, the Third Omnibus Motion, the Fourth Omnibus Motion, the Fifth Omnibus Motion, and the Sixth Omnibus Motion, the Seventh Omnibus Motion, the Eighth Omnibus Motion, the Ninth Omnibus Motion, the Tenth Omnibus Motion, the Eleventh Omnibus Motion, the Twelfth Omnibus Motion, and the Thirteenth Omnibus Motion, collectively, the \"2004 Motions\"). The discovery requested herein will supplement and augment inquiries the Trustee has already begun, as well as open additional avenues of investigation and potential discovery of assets.\n\n5. In the interest of brevity, the Trustee incorporates the 2004 Motions herein by reference and makes them a part hereof. All capitalized terms not defined herein shall have the meanings ascribed to them in the 2004 Motions.\n\n## **JURISDICTION AND VENUE**\n\n6. The Court has jurisdiction to entertain this application under 28 U.S.C. §§ 157 and 1334. Venue to hear this Application is proper in accordance with 28 U.S.C. §§ 1408 and 1409.\n\n7. This Application is a core proceeding pursuant to, *inter alia*, 28 U.S.C. § 157(b)(2) (A), (E), and (F).\n\n## **THE EXAMINEES**\n\n8. The Examinees are banks and financial institutions, entities that deal in automobiles, and certain individuals associated with the Debtor and his alter ego shell companies, not included in the prior 2004 Motions, which Examinees may have material information concerning the Debtor's assets and financial condition.\n\n9. The Trustee has ascertained that the Debtor, along with entities and individuals linked to the Debtor, may have conducted banking or other business at or with the bank/financial institution Examinees. More specifically, these are: **China CITIC Bank International; Intesa Sanpaolo SpA; Lloyds Bank PLC; PayrNet Limited; Revolut Ltd.; and CIMB Bank Berhad a/k/a CIMB Islamic Bank Berhad**. The Trustee understands that at least one Debtor-associated individual or entity has maintained one or more account(s) at each of these Examinees and/or that such Examinees have assisted with or facilitated transfers between other Debtor-related accounts held at previously identified financial institutions.\n\n10. The Trustee has identified certain entities that are in the business of selling automobiles with which at least one Debtor-associated individual or entity has transacted business. It has been the Debtor's practice to purchase motor vehicles through shell companies and individuals associated with the Debtor. Thus, the Trustee reasonably believes these entities may have documents or information relating to the Debtor and his financial affairs which will aid the Trustee in his investigations. Specifically, these entities are as follows: **H.R. Owen PLC; Headwater Service, LLC; and RM Sotheby's and/or RM Auctions 2022**.\n\n11. The Trustee also seeks to undertake Rule 2004 discovery from certain individuals who the Trustee understands were directly involved in the Debtor's financial affairs. The Trustee believes these Examinees may possess information and documents related to the Debtor's commercial activities and other conduct concerning assets, liabilities, or financial interests potentially relevant to the administration of the Debtor's estate and may hold assets of the Debtor:\n\n(a) **Evan Cramer** is an individual believed to be associated with the Debtor and Yvette Wang, who operated as the Debtor's \"chief of staff\" (\"Ms. Wang\"), and the Trustee understands that Mr. Cramer received at least one (1) significant transfer from Ms. Wang in the years leading to the Debtor's bankruptcy filing. Ms. Wang recently pleaded guilty to criminal charges arising from her involvement in the Debtor's fraud schemes. Therefore, Mr. Cramer may have information, documents, and records relating to the Debtor and his business and financial affairs and transactions, which will aid the Trustee in his investigations.\n\n(b) The Trustee has identified additional individuals who were involved with the Debtor's alter egos and who received transfers of funds from the Debtor via his alter egos. The Trustee believes these individuals may have knowledge about the Debtor's\n\nassets and financial affairs. These individuals, and the alter egos with which they were associated, are as follows:\n\n- i. **Makaya Randall**: HCHK Property Management, Inc., HCHK Technologies, Lexington Property & Staffing Inc., and GTV Media Group, Inc.;\n- ii. **Richard Leahy**: HCHK Property Management, Inc.;\n- iii. **Thomas Guarino (aka Thomas Guarino II)**: HCHK Property Management, Inc., Golden Spring NY, GS Security Solutions Inc., and Lamp Capital LLC;\n- iv. **Lukasz Lasota**: HCHK Property Management, Inc.;\n- v. **Thomas McHale**: HCHK Property Management, Inc., Golden Spring NY, GS Security Solutions Inc., and Lamp Capital LLC;\n- vi. **Sean Lynch**: HCHK Property Management, Inc. and Lamp Capital LLC;\n- vii. **Eddy Aquino (aka Eddy I Sanchez Aquino)**: G Club Operations, LLC;\n- viii. **Summer L. Bridges**: G Fashion;\n- ix. **Michael Baranowitz**: Rule of Law Foundation III, Inc. and Rule of Law Society IV, Inc.;\n- x. **Maya Fawaz**: Lexington Property & Staffing Inc. and GTV Media Group Inc.;\n- xi. **Andrea Volpe**: GFNY, Inc. and HCHK Technologies; and\n- xii. **Dean M**. **Rabideau**: Golden Spring NY.\n\n## **RELIEF REQUESTED**\n\n12. The Trustee seeks entry of an order, in substantially the form of the Proposed Order, pursuant to Bankruptcy Rule 2004(a) and Local Rule 2004-1, authorizing the Trustee to conduct the examination of the Examinees included on **Exhibit B**.\n\n## **BASIS FOR RELIEF REQUESTED**\n\n13. Pursuant to Rule 2004(a), on application of a party in interest, the Court may order the examination of any person or entity. The scope of an examination authorized under Rule 2004 is exceedingly broad and may relate to the \"acts, conduct, or property or to the liabilities and financial condition of the debtor, or to any matter which may affect the administration of the debtor's estate.\" Fed. R. Bankr. P. 2004(b).\n\n14. \"The purpose of a Rule 2004 examination is to assist a party in interest in determining the nature and extent of the bankruptcy estate, revealing assets, examining transactions and assessing whether wrongdoing has occurred.\" *In re Transmar Commodity Group Ltd.*, 2018 WL 4006324, at \\*4 (Bankr. S.D.N.Y. Aug. 17, 2018) (internal quotation and citation omitted). This includes revealing the nature and extent of the estate and in discovering assets of the debtor that may have been intentionally or unintentionally concealed. *See In re Bennett Funding Group, Inc.*, 203 B.R. 24, 27-28 (Bankr. N.D.N.Y. 1996). *See also In re Millennium Lab Holdings II, LLC*, 562 B.R. 614, 626 (Bankr. D. Del. 2016) (\"Legitimate goals of Rule 2004 examinations include discovering assets, examining transactions, and determining whether wrongdoing has occurred.\" (internal quotation and citation omitted)).\n\n15. In the declaration he submitted on March 20, 2022 in support of the filing of this case, the Debtor represented that among the purposes for filing his chapter 11 case were \"to … (b) afford stakeholders an efficient opportunity to investigate [his] assets, liabilities, and financial\n\naffairs, given what [he] perceive[d] to be misunderstandings in that regard; [and] (c) establish what assets are estate property and, in turn, available for distribution to holders of allowed claims . . . .\" (Debtor's Declaration, ¶3). The investigation the Trustee seeks to perform is directly relevant to these stated purposes in that it will help the Trustee identify the Debtor's assets and liabilities in order to make distributions to creditors.\n\n16. The areas for inquiry herein are part of the Trustee's ongoing investigative efforts. As the investigation evolves, new avenues of inquiry become apparent and the need for additional discovery of persons, entities and areas of inquiry arises. Based on all the facts and evidence discussed above and as contained in the 2004 Motions, the Trustee seeks the investigative tools afforded by Rule 2004 to further establish the true ownership of assets and to explore other potential assets about which the Trustee does not yet have knowledge.\n\n17. The Trustee requests that, in furtherance of his examinations, the Court direct the Examinees to provide documentation to the Trustee's counsel, as requested in the forms annexed hereto<sup>3</sup> and made a part hereof (the \"Proposed Subpoenas\"), within fourteen (14) days of the service of a subpoena, substantially similar in form and substance to the Proposed Subpoenas, or such other time as agreed upon by the Trustee. These requests seek documents consisting of, among other things, the Examinees' communications with the Debtor regarding his financial condition, asset transfers, and corporate governance issues. The requests also seek the Examinees' internal files and correspondence on these same topics.\n\n<sup>3</sup> Included in Exhibit B is an index of Proposed Subpoenas that would be served on the Examinees if this Motion is granted. The Trustee also attaches hereto as **Exhibits C-1 to C-22** the individualized Proposed Subpoenas, including the topics for discovery directed to each Examinee, which are substantially similar in form and substance.\n\n18. The type of discovery that the Trustee will obtain from Examinees is well within the scope of Bankruptcy Rule 2004. Bankruptcy courts routinely provide for Rule 2004 discovery against professional firms when the discovery may identify and aid the recovery of assets for the benefit of the estate and creditors. *See, e.g., In re Bame,* 251 B.R. 367 (Bankr. D. Minn. 2000); *In re Horvath*, No. 13-34137, 2015 WL 2195060 (Bankr. N.D. Ohio May 7, 2015) (approving discovery related to claims on schedule of assets permissible from individual debtor where obtaining such discovery might increase the value of the debtor's estate).\n\n19. The Trustee submits that the facts set forth above constitute sufficient cause for the Court to order the production of documents pursuant to Bankruptcy Rule 2004 from the Examinees. Particularly considering the pattern of obstruction by the Debtor and certain of his family members and associates, seeking discovery from other parties, including the Examinees, is an essential investigative tool in identifying and recovering estate property. Indeed, documents in the possession of third parties like the Examinees have been among the most useful of those obtained in the Trustee's investigation to date.<sup>4</sup>\n\n20. Authorization of this Application is critical for the Trustee to fulfill the duties contemplated in the Trustee Order effectively, including specifically his mandate to \"locate the Debtor's assets for the benefit of creditors and the estate\" and \"investigate the Debtor's assets, liabilities, and financial affairs.\" (*See* Trustee Order at 15-16, 18).\n\n21. No party in interest, including the Debtor, shall suffer undue prejudice upon the granting of the relief sought in this Application.\n\n<sup>4</sup> The Trustee also requests authority to serve the Proposed Subpoenas on affiliates or subsidiaries of the Examinees if in the course of the Trustee's investigation it is determined that such affiliates and subsidiaries of the Examinees are the parties in control of documents relating to the Examinees that are relevant to the Trustee's investigation.\n\n## **NO PRIOR REQUEST**\n\n22. No prior application for the relief requested herein has been made. The Trustee filed the prior 2004 Motions however, those prior motions did not request to take discovery from the Examinees at issue here.\n\n## **OBJECTION DEADLINE**\n\n23. The deadline to object to this Application is May 23, 2024, and in the absence of a timely filed objection, the Proposed Order may enter without further notice and hearing.\n\nWHEREFORE, the Trustee respectfully requests that the Court grant this Application and enter the Proposed Order, pursuant to Fed. R. Bankr. P. 2004(a), directing the examination of the Examinees, and directing the production of certain documents as set forth in the Requests for Production of Documents attached to the Proposed Subpoenas, and for such other and further relief as the Court may deem just and proper.\n\nWHEREFORE, the Court should grant this Motion and grant such other relief as is just and proper.\n\nDated: May 16, 2024 LUC A. DESPINS,\n\nNew Haven, Connecticut CHAPTER 11 TRUSTEE\n\nBy: */s/ Patrick R. Linsey* 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\n\n*Counsel for the Chapter 11 Trustee*\n\n# **UNITED STATES BANKRUPTCY COURT DISTRICT OF CONNECTICUT BRIDGEPORT DIVISION**\n\n| ----------------------------------------------------------- | x           |                         |\n|-------------------------------------------------------------|-------------|-------------------------|\n| In re:                                                      | :<br>:      | Chapter 11              |\n| 1<br>HO WAN KWOK,<br>et al.,                                | :<br>:      | Case No. 22-50073 (JAM) |\n| Debtors.                                                    | :<br>:<br>: | (Jointly Administered)  |\n| ----------------------------------------------------------- | x           |                         |\n\n## **NOTICE OF OBJECTION DEADLINE**\n\nLuc Despins, as the appointed Chapter 11 Trustee to the Debtor's Estate (the \"Applicant\"), has filed an Application for Rule 2004 Examination of certain corporate entities, individuals, and banking and financial institutions identified in **Exhibit B** (the \"Rule 2004 Examination\") with the U.S. Bankruptcy Court for the District of Connecticut. Notice is hereby given that any objection or response to the Rule 2004 Examination must be filed with the Court no later than May 23, 2024, in accordance with Fed. R. Bankr. P. 2002(a) and 9014 and Local Bankr. R. 2004-1(c). In the absence of a timely filed objection, the proposed order regarding the Rule 2004 Examination may enter without further notice and hearing, see 11 U.S.C. section 102(1).\n\n## [*REMAINDER OF THIS PAGE IS INTENTIONALLY LEFT BLANK*.]\n\n<sup>1</sup> The Debtors in these chapter 11 cases are Ho Wan Kwok (also known as Guo Wengui, Miles Guo, and Miles Kwok, as well as numerous other aliases) (last four digits of tax identification number: 9595), Genever Holdings LLC (last four digits of tax identification number: 8202) and Genever Holdings Corporation. The mailing address for the Trustee, Genever Holdings LLC, and the Genever Holdings Corporation is Paul Hastings LLP, 200 Park Avenue, New York, NY 10166 c/o Luc A. Despins, as Trustee for the Estate of Ho Wan Kwok (solely for purposes of notices and communications).\n\nDated: May 16, 2024 LUC A. DESPINS, New Haven, Connecticut CHAPTER 11 TRUSTEE\n\nBy: */s/ Patrick R. Linsey*\n\nDouglas S. Skalka (ct00616) Patrick R. Linsey (ct29437) NEUBERT, PEPE & MONTEITH, P.C. 195 Church Street, 13th Floor New Haven, Connecticut 06510 (203) 781-2847 dskalka@npmlaw.com plinsey@npmlaw.com\n\n*Counsel for the Chapter 11 Trustee*\n\n# **Exhibit A**\n\n**Proposed Order**\n\n| Case 22-50073 | Doc 3193 | Filed 05/16/24 | Entered 05/16/24 10:28:21 | Page 14 of |\n|---------------|----------|----------------|---------------------------|------------|\n|               |          | 439            |                           |            |\n\n# **UNITED STATES BANKRUPTCY COURT DISTRICT OF CONNECTICUT BRIDGEPORT DIVISION**\n\n| ----------------------------------------------------------- | x           |                         |\n|-------------------------------------------------------------|-------------|-------------------------|\n| In re:                                                      | :<br>:      | Chapter 11              |\n| 1<br>HO WAN KWOK,<br>et al.,                                | :<br>:<br>: | Case No. 22-50073 (JAM) |\n| Debtors.                                                    | :<br>:      | (Jointly Administered)  |\n| ----------------------------------------------------------- | x           |                         |\n\n# **[PROPOSED] ORDER GRANTING FIFTEENTH 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 INDIVIDUALS, RELEVANT BANKS, AND ENTITIES THAT DEAL IN AUTOMOBILES**\n\nUpon consideration of the Application seeking an order authorizing a Federal Rule of Bankruptcy Procedure 2004 examination of the Examinees listed on Exhibit B thereto (the \"Application\", ECF No. \\_\\_\\_\\_), filed by Luc Despins, as the appointed Chapter 11 Trustee to the Debtor's estate (the \"Applicant\"), after notice and a hearing, see 11 U.S.C. § 102(1), it appearing that cause exists to grant the requested relief as conditioned hereafter; it is hereby\n\n**ORDERED**: The Rule 2004 Motion is granted as set forth below.\n\n**ORDERED**: Neubert, Pepe & Monteith, P.C., as counsel for the Trustee, is hereby authorized to sign Subpoenas in a form substantially similar to the Subpoenas attached to the Rule 2004 Motion as Exhibits C-1 to C-22 and to serve the Subpoenas, along with a copy of this Order, in accordance with Bankruptcy Rule 2004 requiring examination and the production of documents by the Examinees listed on Exhibit B to the Application.\n\n**ORDERED**: Subject to any rights under the Federal Rules of Bankruptcy Procedure, the Federal Rules of Civil Procedure, and applicable Local Rules, and unless otherwise ordered by the Court, the Examinees are hereby directed to produce all documents within 14 days of the service of the Subpoena, or such other time as agreed upon by the Trustee. To the extent an Examinee\n\n<sup>1</sup> The Debtors in these chapter 11 cases are Ho Wan Kwok (also known as Guo Wengui, Miles Guo, and Miles Kwok, as well as numerous other aliases) (last four digits of tax identification number: 9595), Genever Holdings LLC (last four digits of tax identification number: 8202) and Genever Holdings Corporation. The mailing address for the Trustee, Genever Holdings LLC, and the Genever Holdings Corporation is Paul Hastings LLP, 200 Park Avenue, New York, NY 10166 c/o Luc A. Despins, as Trustee for the Estate of Ho Wan Kwok (solely for purposes of notices and communications).\n\nCase 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 15 of 439\n\ndoes not produce any documents requested in the Subpoena on the basis of some privilege, the Examinee is hereby directed to produce to the Trustee a privilege log that comports with Fed. R. Civ. P. 45(e)(2), made applicable by Fed. R. Bankr. P. 9016, and D. Conn. L. Civ. R. 26(e), within 14 days of service of the Subpoena, or such other time as agreed upon by the Trustee.\n\n**ORDERED**: The Examinees are hereby directed to ensure that all documents and other information, including without limitation in any electronic format, requested in the Subpoenas or otherwise relevant to the Debtor, his business, assets, liabilities, financial condition, or this Chapter 11 case, are properly maintained, are available for production, inspection and copying, and are not destroyed.\n\n**ORDERED**: Neubert, Pepe & Monteith, P.C., as counsel for the Trustee, is hereby authorized, without further order of this Court, to take the testimony of one or more representatives of any Examinee listed on Exhibit B to the Application by examination under Bankruptcy Rule 2004 either at the offices of Neubert, Pepe & Monteith, 195 Church Street, 13th Floor, New Haven, CT 06510, at the offices of Paul Hastings LLP, 200 Park Avenue, New York, NY 10166, or at such other place that is mutually acceptable to the parties, on a date acceptable to the Trustee, which, at the election of the Trustee, shall be not less than 14 calendar days after the production of documents by the proposed examinee in compliance with the Subpoena and this Order pursuant to Bankruptcy Rule 2004, and such examination shall continue from day to day until completed.\n\nDated: \\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_, 2024\n\nJulie A. Manning, United States Bankruptcy Judge\n\n\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\n\n# **Exhibit B**\n\nCase 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 17 of 439\n\n| Discovery Party                                       | Address                                                                                                                                                                                         | Subpoena Index |\n|-------------------------------------------------------|-------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|----------------|\n| China CITIC Bank<br>International                     | New York Branch<br>China CITIC Bank International<br>410 Park Avenue, 11F<br>New York, NY 10022                                                                                                 | Exhibit C-1    |\n| Intesa Sanpaolo SpA                                   | New York Branch<br>1 William Street<br>New York, NY 10004                                                                                                                                       | Exhibit C-2    |\n| Lloyds Bank PLC                                       | New York Office<br>1095 Avenue of the Americas, 34th Floor<br>New York, NY 10036<br>Registered Office Address<br>25 Gresham Street<br>London, England EC2V 7HN                                  | Exhibit C-3    |\n| PayrNet Limited                                       | Registered Office Address<br>Montacute Yards, Shoreditch High Street<br>London, England E1 6HU                                                                                                  | Exhibit C-4    |\n| Revolut Ltd.                                          | Registered Agent<br>Cogency Global Inc.<br>122 East 42nd Street, 18th Floor<br>New York, NY 10168<br>107 Greenwich Street, 20th Floor<br>New York, NY 10006                                     | Exhibit C-5    |\n| CIMN Bank Berhad<br>a/k/a CIMB Islamic<br>Bank Berhad | UK Establishment Office<br>27 Knightsbridge<br>London, England SW1X 7LY<br>Correspondence Address<br>Menara Cimb Jalan Stesen Sentral 2<br>Juala Lumpur Sentral<br>Kuala Lumpur, Malaysia 50470 | Exhibit C-6    |\n\nCase 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 18 of 439\n\n| Discovery Party                             | Address                                             | Subpoena Index |\n|---------------------------------------------|-----------------------------------------------------|----------------|\n| Evan Cramer                                 | 1250 100th St.<br>Bay Harbor Islands, FL 33154-1106 | Exhibit C-7    |\n| Makaya Randall                              | 24 Hinckley Place<br>Poughkeepsie, NY 12601         | Exhibit C-8    |\n| Richard Leahy                               | 661 Locust Point Road<br>Rumson, NJ 07760           | Exhibit C-9    |\n| Thomas Guarino (a/k/a<br>Thomas Guarino II) | 112 Lakewood Drive<br>Congers, NY 10920             | Exhibit C-10   |\n| Lukasz Lasota                               | 35 Landmark Lane<br>Fairlawn, NJ 07410              | Exhibit C-11   |\n| Thomas McHale                               | 11 Eden Road<br>Harriman, NY 10926                  | Exhibit C-12   |\n| Sean Lynch                                  | 800 Wildwood Court<br>Yorktown Heights, NY 10598    | Exhibit C-13   |\n\nCase 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 19 of 439\n\n| Discovery Party                                  | Address                                                                                                                             | Subpoena Index |  |\n|--------------------------------------------------|-------------------------------------------------------------------------------------------------------------------------------------|----------------|--|\n| Eddy Aquino (a/k/a<br>Eddy I. Sanchez<br>Aquino) | Cond Palmares De Monteverde<br>94 Ramal 842<br>San Juan, PR 00926-3903                                                              | Exhibit C-14   |  |\n| Summer L. Bridges                                | 6102 Premiere Ave.<br>Lakewood, CA 90712                                                                                            | Exhibit C-15   |  |\n| Michael Baranowitz                               | 10 Huntsman Lane<br>Commack, NY 11725                                                                                               | Exhibit C-16   |  |\n| Maya Fawaz                                       | 130 Ocean Parkway, 3D<br>Brooklyn, NY 11218                                                                                         | Exhibit C-17   |  |\n| Andrea Volpe                                     | 15 Broad Street, Apt. 3110<br>New York, NY 10005                                                                                    | Exhibit C-18   |  |\n| H.R. Owen PLC                                    | Registered Office Address<br>Melton Court, Old Brompton Road<br>London, England SW7 3TD                                             | Exhibit C-19   |  |\n| Headwater Service,<br>LLC                        | Registered Agent<br>c/o Northwest Registered Agent LLC<br>Five Greentree Centre,<br>55 Route 73 North Ste. 104<br>Marlton, NJ 08053 | Exhibit C-20   |  |\n\nCase 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 20 of 439\n\n| Discovery Party     | Address                                                | Subpoena Index |\n|---------------------|--------------------------------------------------------|----------------|\n| RM Sotheby's and/or | 1334 York Ave.                                         | Exhibit C-21   |\n| RM Auctions 2022    | New York, NY 10021                                     |                |\n|                     |                                                        |                |\n|                     | Registered Office Address                              |                |\n|                     | Heron House, 5 Heron Square                            |                |\n|                     | Richmond, United Kingdom TW9 1EL                       |                |\n| Dean M. Rabideau    | 1898 Hanover Street                                    | Exhibit C-22   |\n|                     | Yorktown Heights, NY 10598                             |                |\n|                     | 15 Bayberry Street<br>Hopewell Junction, NY 12533-4333 |                |\n\n# Exhibit C-1\n\n#### B2540 (Form 2540 – Subpoena for Rule 2004 Examination) (12/15) Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 22 of\n\n439\n\nUNITED STATES BANKRUPTCY COURT\n\n**District of Connecticut**\n\nIn re HO WAN KWOK, *et al*.,\n\n<sup>1</sup> Case No. 22-50073 (JAM) Debtor Chapter 11\n\n(Jointly Administered)\n\n# **SUBPOENA FOR RULE 2004 EXAMINATION**\n\nTo: **China CITIC Bank International**\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/A   | N/A           |\n|       |               |\n\nThe examination will be recorded by this method: N/A\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\n## **See Requests for Production of Documents, attached hereto.**\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: **May , 2024**\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 Luc A. Despins, Chapter 11 Trustee, who issues or requests this subpoena, are:\n\n**Patrick R. Linsey, Esq.; Neubert, Pepe & Monteith, P.C.; 195 Church Street, 13th Floor, New Haven, Connecticut 06510 plinsey@npmlaw.com; (203) 781-2847**\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\nSoftware Copyright (c) 1996-2022 Best Case, LLC - www.bestcase.com Best Case Bankruptcy 1 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## **PROOF OF SERVICE**\n\n**(This section should not be filed with the court unless required by Fed. R. Civ. P. 45.)**\n\nI received this subpoena for (*name of individual and title, if any*): on (*date*) .\n\nI served the subpoena by delivering a copy to the named person as follows:\n\non *(date)* ; or\n\nI returned the subpoena unexecuted because:\n\nUnless the subpoena was issued on behalf of the United States, or one of its officers or agents, I have also tendered to the witness the fees for one day's attendance, and the mileage allowed by law, in the amount of \\$ .\n\nMy fees are \\$ for travel and \\$ for services, for a total of \\$ .\n\nI declare under penalty of perjury that this information is true and correct.\n\nDate:\n\n*Server's signature*\n\n*Printed name and title*\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;\n\n(ii) requires a person to comply beyond the geographical limits specified 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: (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 trial-preparation 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\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| 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| TIME_CREATED | 10:25 AM                  |                                                 |  |\n|--------------|---------------------------|-------------------------------------------------|--|\n|              |                           | Email: (empty)                                  |  |\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 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 29 of 439\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 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 30 of 439\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 subpoena.\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\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 China CITIC 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 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 32 of 439\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, Aaron Mitchell, ACA Capital Group Limited, Ace Decade Holdings Limited, AI Group Holdings Inc., Alfa Global Ventures Limited, Alphonso Global Ventures Limited, Ana C. Izquiedo-Henn, Andrew Childe, Anthony DiBattista, Anton Development Limited, Booming Sail New York LLC, Beile Li, Bingshang Jiao, Bravo Luck Limited, Brent Petro Inc., Celestial Tide Limited, Chris Lee (a/k/a Nan Li, Mei Guo Xiao Li), China Golden Spring Group (Hong Kong) Ltd., 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 (CA), G Fashion, G Fashion Hold Co. A. Limited, G\n\n## Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 33 of 439\n\nFashion Hold Co. B. Limited, G Fashion Media Group Inc., 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, 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), Haitham Khaled, Hamilton Capital Holdings Inc., Hamilton Digital Assets Funds SP, Hamilton Investment Management Limited, Hamilton Opportunity Fund SPC, Hamilton PE Funds SP, Holy City Hong Kong Ventures Ltd., GS Security Solutions Inc., Alex Hadjcharalambous, 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 Currency Clearing Pty. Ltd., 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, Jessica Mastrogiovanni, Jiaming Liu, Jie Zhang, Jovial Century International Limited, Joyord Sportswear Limited, K Legacy Ltd., Kamel Debeche, Karin Maistrello, Kin Ming Je, Lamp Capital LLC, Lawall & Mitchell, LLC, Leading Shine NY Ltd., Lexington Property and Staffing, Inc., Lexington Property and Staffing LLC, Linwan \"Irene\" Feng, Limarie Reyes, Lihong \"Sara\" Wei Lafrenz, The Lost Draft LLC, Macaron Limited, Major Lead International Limited, Mary Jiang, MOS Himalaya LLC, Maywind Trading LLC, New York MOS Himalaya LLC, Next\n\n## Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 34 of 439\n\nTycoon Investments Limited, Nicholas Savio, Nodal Partners, LLC, Qidong Xia, Oasis Tech Limited, O.S.C. Orbit Service Company, LLC, 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, Seven Mission Group LLC, Shih Hsin Yu, Sirius Networking Inc., Taurus Fund LLC, Taurus Management LLC, US Himalaya Capital Inc., V.X. Cerda & Associates P.A., Victor Cerda, Voice of Guo Media, Inc., Wen Xiao, Wencong Wang, William Je, Kin Ming Je a/k/a Je Kin Ming, Wise Creation International Limited, Xuebing Wang, Yan Chun Liu, 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, Zhouer \"Joe\" Wang, NewPeople LLC, Ziba Limited, New Mulberry PTE Ltd, TD Primrose Limited, and Shin Hee-Seup a/k/a Hee Seup Shin.\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,\n\n## Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 35 of 439\n\ntype, 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\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\n## Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 36 of 439\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 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 statements, 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\n## Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 38 of 439\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) Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 40 of\n\n439\n\nUNITED STATES BANKRUPTCY COURT\n\n**District of Connecticut**\n\nIn re HO WAN KWOK, *et al*.,\n\n<sup>1</sup> Case No. 22-50073 (JAM) Debtor Chapter 11\n\n(Jointly Administered)\n\n# **SUBPOENA FOR RULE 2004 EXAMINATION**\n\nTo: **Intesa Sanpaolo SpA**\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/A   | N/A           |\n|       |               |\n\nThe examination will be recorded by this method: N/A\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\n## **See Requests for Production of Documents, attached hereto.**\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: **May , 2024**\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 Luc A. Despins, Chapter 11 Trustee, who issues or requests this subpoena, are:\n\n**Patrick R. Linsey, Esq.; Neubert, Pepe & Monteith, P.C.; 195 Church Street, 13th Floor, New Haven, Connecticut 06510 plinsey@npmlaw.com; (203) 781-2847**\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\nSoftware Copyright (c) 1996-2022 Best Case, LLC - www.bestcase.com Best Case Bankruptcy 1 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## **PROOF OF SERVICE**\n\n**(This section should not be filed with the court unless required by Fed. R. Civ. P. 45.)**\n\nI received this subpoena for (*name of individual and title, if any*): on (*date*) .\n\nI served the subpoena by delivering a copy to the named person as follows:\n\non *(date)* ; or\n\nI returned the subpoena unexecuted because:\n\nUnless the subpoena was issued on behalf of the United States, or one of its officers or agents, I have also tendered to the witness the fees for one day's attendance, and the mileage allowed by law, in the amount of \\$ .\n\nMy fees are \\$ for travel and \\$ for services, for a total of \\$ .\n\nI declare under penalty of perjury that this information is true and correct.\n\nDate:\n\n*Server's signature*\n\n*Printed name and title*\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;\n\n(ii) requires a person to comply beyond the geographical limits specified 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: (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 trial-preparation 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\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| 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| 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 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 47 of 439\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 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 48 of 439\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 subpoena.\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\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 Intesa Sanpaolo SpA, 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 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 50 of 439\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, Aaron Mitchell, ACA Capital Group Limited, Ace Decade Holdings Limited, AI Group Holdings Inc., Alfa Global Ventures Limited, Alphonso Global Ventures Limited, Ana C. Izquiedo-Henn, Andrew Childe, Anthony DiBattista, Anton Development Limited, Booming Sail New York LLC, Beile Li, Bingshang Jiao, Bravo Luck Limited, Brent Petro Inc., Celestial Tide Limited, Chris Lee (a/k/a Nan Li, Mei Guo Xiao Li), China Golden Spring Group (Hong Kong) Ltd., 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 (CA), G Fashion, G Fashion Hold Co. A. Limited, G\n\n## Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 51 of 439\n\nFashion Hold Co. B. Limited, G Fashion Media Group Inc., 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, 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), Haitham Khaled, Hamilton Capital Holdings Inc., Hamilton Digital Assets Funds SP, Hamilton Investment Management Limited, Hamilton Opportunity Fund SPC, Hamilton PE Funds SP, Holy City Hong Kong Ventures Ltd., GS Security Solutions Inc., Alex Hadjcharalambous, 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 Currency Clearing Pty. Ltd., 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, Jessica Mastrogiovanni, Jiaming Liu, Jie Zhang, Jovial Century International Limited, Joyord Sportswear Limited, K Legacy Ltd., Kamel Debeche, Karin Maistrello, Kin Ming Je, Lamp Capital LLC, Lawall & Mitchell, LLC, Leading Shine NY Ltd., Lexington Property and Staffing, Inc., Lexington Property and Staffing LLC, Linwan \"Irene\" Feng, Limarie Reyes, Lihong \"Sara\" Wei Lafrenz, The Lost Draft LLC, Macaron Limited, Major Lead International Limited, Mary Jiang, MOS Himalaya LLC, Maywind Trading LLC, New York MOS Himalaya LLC, Next\n\n## Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 52 of 439\n\nTycoon Investments Limited, Nicholas Savio, Nodal Partners, LLC, Qidong Xia, Oasis Tech Limited, O.S.C. Orbit Service Company, LLC, 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, Seven Mission Group LLC, Shih Hsin Yu, Sirius Networking Inc., Taurus Fund LLC, Taurus Management LLC, US Himalaya Capital Inc., V.X. Cerda & Associates P.A., Victor Cerda, Voice of Guo Media, Inc., Wen Xiao, Wencong Wang, William Je, Kin Ming Je a/k/a Je Kin Ming, Wise Creation International Limited, Xuebing Wang, Yan Chun Liu, 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, Zhouer \"Joe\" Wang, NewPeople LLC, Ziba Limited, New Mulberry PTE Ltd, TD Primrose Limited, and Shin Hee-Seup a/k/a Hee Seup Shin.\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,\n\n## Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 53 of 439\n\ntype, 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\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\n## Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 54 of 439\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 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 statements, 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\n## Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 56 of 439\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) Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 58 of\n\n439\n\nUNITED STATES BANKRUPTCY COURT\n\n**District of Connecticut**\n\nIn re HO WAN KWOK, *et al*.,\n\n<sup>1</sup> Case No. 22-50073 (JAM) Debtor Chapter 11\n\n(Jointly Administered)\n\n# **SUBPOENA FOR RULE 2004 EXAMINATION**\n\nTo: **Lloyds Bank PLC**\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/A   | N/A           |\n|       |               |\n\nThe examination will be recorded by this method: N/A\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\n## **See Requests for Production of Documents, attached hereto.**\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: **May , 2024**\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 Luc A. Despins, Chapter 11 Trustee, who issues or requests this subpoena, are:\n\n**Patrick R. Linsey, Esq.; Neubert, Pepe & Monteith, P.C.; 195 Church Street, 13th Floor, New Haven, Connecticut 06510 plinsey@npmlaw.com; (203) 781-2847**\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\nSoftware Copyright (c) 1996-2022 Best Case, LLC - www.bestcase.com Best Case Bankruptcy 1 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## **PROOF OF SERVICE**\n\n**(This section should not be filed with the court unless required by Fed. R. Civ. P. 45.)**\n\nI received this subpoena for (*name of individual and title, if any*): on (*date*) .\n\nI served the subpoena by delivering a copy to the named person as follows:\n\non *(date)* ; or\n\nI returned the subpoena unexecuted because:\n\nUnless the subpoena was issued on behalf of the United States, or one of its officers or agents, I have also tendered to the witness the fees for one day's attendance, and the mileage allowed by law, in the amount of \\$ .\n\nMy fees are \\$ for travel and \\$ for services, for a total of \\$ .\n\nI declare under penalty of perjury that this information is true and correct.\n\nDate:\n\n*Server's signature*\n\n*Printed name and title*\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;\n\n(ii) requires a person to comply beyond the geographical limits specified 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: (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 trial-preparation 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\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| 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| TIME_CREATED | 10:25 AM                  | Email: (empty)                                  |  |\n|--------------|---------------------------|-------------------------------------------------|--|\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 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 65 of 439\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 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 66 of 439\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 subpoena.\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 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 67 of 439\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 Lloyds Bank PLC, 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 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 68 of 439\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, Aaron Mitchell, ACA Capital Group Limited, Ace Decade Holdings Limited, AI Group Holdings Inc., Alfa Global Ventures Limited, Alphonso Global Ventures Limited, Ana C. Izquiedo-Henn, Andrew Childe, Anthony DiBattista, Anton Development Limited, Booming Sail New York LLC, Beile Li, Bingshang Jiao, Bravo Luck Limited, Brent Petro Inc., Celestial Tide Limited, Chris Lee (a/k/a Nan Li, Mei Guo Xiao Li), China Golden Spring Group (Hong Kong) Ltd., 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 (CA), G Fashion, G Fashion Hold Co. A. Limited, G\n\n## Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 69 of 439\n\nFashion Hold Co. B. Limited, G Fashion Media Group Inc., 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, 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), Haitham Khaled, Hamilton Capital Holdings Inc., Hamilton Digital Assets Funds SP, Hamilton Investment Management Limited, Hamilton Opportunity Fund SPC, Hamilton PE Funds SP, Holy City Hong Kong Ventures Ltd., GS Security Solutions Inc., Alex Hadjcharalambous, 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 Currency Clearing Pty. Ltd., 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, Jessica Mastrogiovanni, Jiaming Liu, Jie Zhang, Jovial Century International Limited, Joyord Sportswear Limited, K Legacy Ltd., Kamel Debeche, Karin Maistrello, Kin Ming Je, Lamp Capital LLC, Lawall & Mitchell, LLC, Leading Shine NY Ltd., Lexington Property and Staffing, Inc., Lexington Property and Staffing LLC, Linwan \"Irene\" Feng, Limarie Reyes, Lihong \"Sara\" Wei Lafrenz, The Lost Draft LLC, Macaron Limited, Major Lead International Limited, Mary Jiang, MOS Himalaya LLC, Maywind Trading LLC, New York MOS Himalaya LLC, Next\n\n## Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 70 of 439\n\nTycoon Investments Limited, Nicholas Savio, Nodal Partners, LLC, Qidong Xia, Oasis Tech Limited, O.S.C. Orbit Service Company, LLC, 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, Seven Mission Group LLC, Shih Hsin Yu, Sirius Networking Inc., Taurus Fund LLC, Taurus Management LLC, US Himalaya Capital Inc., V.X. Cerda & Associates P.A., Victor Cerda, Voice of Guo Media, Inc., Wen Xiao, Wencong Wang, William Je, Kin Ming Je a/k/a Je Kin Ming, Wise Creation International Limited, Xuebing Wang, Yan Chun Liu, 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, Zhouer \"Joe\" Wang, NewPeople LLC, Ziba Limited, New Mulberry PTE Ltd, TD Primrose Limited, and Shin Hee-Seup a/k/a Hee Seup Shin.\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,\n\n## Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 71 of 439\n\ntype, 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\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\n## Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 72 of 439\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 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 statements, 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\n## Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 74 of 439\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) Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 76 of\n\n439\n\nUNITED STATES BANKRUPTCY COURT\n\n**District of Connecticut**\n\nIn re HO WAN KWOK, *et al*.,\n\n<sup>1</sup> Case No. 22-50073 (JAM) Debtor Chapter 11\n\n(Jointly Administered)\n\n# **SUBPOENA FOR RULE 2004 EXAMINATION**\n\nTo: **PayrNet Limited**\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/A   | N/A           |\n|       |               |\n\nThe examination will be recorded by this method: N/A\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\n## **See Requests for Production of Documents, attached hereto.**\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: **May , 2024**\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 Luc A. Despins, Chapter 11 Trustee, who issues or requests this subpoena, are:\n\n**Patrick R. Linsey, Esq.; Neubert, Pepe & Monteith, P.C.; 195 Church Street, 13th Floor, New Haven, Connecticut 06510 plinsey@npmlaw.com; (203) 781-2847**\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\nSoftware Copyright (c) 1996-2022 Best Case, LLC - www.bestcase.com Best Case Bankruptcy 1 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## **PROOF OF SERVICE**\n\n**(This section should not be filed with the court unless required by Fed. R. Civ. P. 45.)**\n\nI received this subpoena for (*name of individual and title, if any*): on (*date*) .\n\nI served the subpoena by delivering a copy to the named person as follows:\n\non *(date)* ; or\n\nI returned the subpoena unexecuted because:\n\nUnless the subpoena was issued on behalf of the United States, or one of its officers or agents, I have also tendered to the witness the fees for one day's attendance, and the mileage allowed by law, in the amount of \\$ .\n\nMy fees are \\$ for travel and \\$ for services, for a total of \\$ .\n\nI declare under penalty of perjury that this information is true and correct.\n\nDate:\n\n*Server's signature*\n\n*Printed name and title*\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;\n\n(ii) requires a person to comply beyond the geographical limits specified 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: (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 trial-preparation 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\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| 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| TIME_CREATED | 10:25 AM                  | Email: (empty)                                  |\n|--------------|---------------------------|-------------------------------------------------|\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 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 83 of 439\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 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 84 of 439\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 subpoena.\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\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 PayrNet Limited, 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 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 86 of 439\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, Aaron Mitchell, ACA Capital Group Limited, Ace Decade Holdings Limited, AI Group Holdings Inc., Alfa Global Ventures Limited, Alphonso Global Ventures Limited, Ana C. Izquiedo-Henn, Andrew Childe, Anthony DiBattista, Anton Development Limited, Booming Sail New York LLC, Beile Li, Bingshang Jiao, Bravo Luck Limited, Brent Petro Inc., Celestial Tide Limited, Chris Lee (a/k/a Nan Li, Mei Guo Xiao Li), China Golden Spring Group (Hong Kong) Ltd., 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 (CA), G Fashion, G Fashion Hold Co. A. Limited, G Fashion Hold Co. B. Limited, G Fashion Media Group Inc., 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\n\n## Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 87 of 439\n\nLLC, G Club US Operations Inc., G Club US Operations LLC, G Club, 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), Haitham Khaled, Hamilton Capital Holdings Inc., Hamilton Digital Assets Funds SP, Hamilton Investment Management Limited, Hamilton Opportunity Fund SPC, Hamilton PE Funds SP, Holy City Hong Kong Ventures Ltd., GS Security Solutions Inc., Alex Hadjcharalambous, 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 Currency Clearing Pty. Ltd., 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, Jessica Mastrogiovanni, Jiaming Liu, Jie Zhang, Jovial Century International Limited, Joyord Sportswear Limited, K Legacy Ltd., Kamel Debeche, Karin Maistrello, Kin Ming Je, Lamp Capital LLC, Lawall & Mitchell, LLC, Leading Shine NY Ltd., Lexington Property and Staffing, Inc., Lexington Property and Staffing LLC, Linwan \"Irene\" Feng, Limarie Reyes, Lihong \"Sara\" Wei Lafrenz, The Lost Draft LLC, Macaron Limited, Major Lead International Limited, Mary Jiang, MOS Himalaya LLC, Maywind Trading LLC, New York MOS Himalaya LLC, Next Tycoon Investments Limited, Nicholas Savio, Nodal Partners, LLC, Qidong Xia, Oasis Tech Limited, O.S.C. Orbit Service Company, LLC, Pixshow Film Inc., Qu Guo Jiao, Roscalitar 2, Ridwan Mamode Saib, Ross Heinemeyer, Rule of Law Society IV Inc., Rule of Law Foundation\n\n## Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 88 of 439\n\nIII, Inc., Rule of Law Fund, Saraca Media Group Inc., Savio Law LLC, Scott Barnett, Seven Mission Group LLC, Shih Hsin Yu, Sirius Networking Inc., Taurus Fund LLC, Taurus Management LLC, US Himalaya Capital Inc., V.X. Cerda & Associates P.A., Victor Cerda, Voice of Guo Media, Inc., Wen Xiao, Wencong Wang, William Je, Kin Ming Je a/k/a Je Kin Ming, Wise Creation International Limited, Xuebing Wang, Yan Chun Liu, 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, Zhouer \"Joe\" Wang, NewPeople LLC, Ziba Limited, New Mulberry PTE Ltd, TD Primrose Limited, and Shin Hee-Seup a/k/a Hee Seup Shin.\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,\n\n## Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 89 of 439\n\ncharts, 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\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,\n\n## Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 90 of 439\n\nconnected 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 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,\n\n## Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 91 of 439\n\nauthorizations, 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\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\n## Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 92 of 439\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) Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 94 of\n\n439\n\nUNITED STATES BANKRUPTCY COURT\n\n**District of Connecticut**\n\nIn re HO WAN KWOK, *et al*.,\n\n<sup>1</sup> Case No. 22-50073 (JAM) Debtor Chapter 11\n\n(Jointly Administered)\n\n# **SUBPOENA FOR RULE 2004 EXAMINATION**\n\nTo: **Revolut Ltd.**\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/A   | N/A           |\n|       |               |\n\nThe examination will be recorded by this method: N/A\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\n## **See Requests for Production of Documents, attached hereto.**\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: **May , 2024**\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 Luc A. Despins, Chapter 11 Trustee, who issues or requests this subpoena, are:\n\n**Patrick R. Linsey, Esq.; Neubert, Pepe & Monteith, P.C.; 195 Church Street, 13th Floor, New Haven, Connecticut 06510 plinsey@npmlaw.com; (203) 781-2847**\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\nSoftware Copyright (c) 1996-2022 Best Case, LLC - www.bestcase.com Best Case Bankruptcy 1 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## **PROOF OF SERVICE**\n\n**(This section should not be filed with the court unless required by Fed. R. Civ. P. 45.)**\n\nI received this subpoena for (*name of individual and title, if any*): on (*date*) .\n\nI served the subpoena by delivering a copy to the named person as follows:\n\non *(date)* ; or\n\nI returned the subpoena unexecuted because:\n\nUnless the subpoena was issued on behalf of the United States, or one of its officers or agents, I have also tendered to the witness the fees for one day's attendance, and the mileage allowed by law, in the amount of \\$ .\n\nMy fees are \\$ for travel and \\$ for services, for a total of \\$ .\n\nI declare under penalty of perjury that this information is true and correct.\n\nDate:\n\n*Server's signature*\n\n*Printed name and title*\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;\n\n(ii) requires a person to comply beyond the geographical limits specified 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: (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 trial-preparation 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\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| 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 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 100 of 439\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|              |                           |                                                 |\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 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 101 of 439\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 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 102 of 439\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 subpoena.\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\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 Revolut Ltd., 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 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 104 of 439\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, Aaron Mitchell, ACA Capital Group Limited, Ace Decade Holdings Limited, AI Group Holdings Inc., Alfa Global Ventures Limited, Alphonso Global Ventures Limited, Ana C. Izquiedo-Henn, Andrew Childe, Anthony DiBattista, Anton Development Limited, Booming Sail New York LLC, Beile Li, Bingshang Jiao, Bravo Luck Limited, Brent Petro Inc., Celestial Tide Limited, Chris Lee (a/k/a Nan Li, Mei Guo Xiao Li), China Golden Spring Group (Hong Kong) Ltd., 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 (CA), G Fashion, G Fashion Hold Co. A. Limited, G Fashion Hold Co. B. Limited, G Fashion Media Group Inc., 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\n\n## Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 105 of 439\n\nLLC, G Club US Operations Inc., G Club US Operations LLC, G Club, 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), Haitham Khaled, Hamilton Capital Holdings Inc., Hamilton Digital Assets Funds SP, Hamilton Investment Management Limited, Hamilton Opportunity Fund SPC, Hamilton PE Funds SP, Holy City Hong Kong Ventures Ltd., GS Security Solutions Inc., Alex Hadjcharalambous, 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 Currency Clearing Pty. Ltd., 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, Jessica Mastrogiovanni, Jiaming Liu, Jie Zhang, Jovial Century International Limited, Joyord Sportswear Limited, K Legacy Ltd., Kamel Debeche, Karin Maistrello, Kin Ming Je, Lamp Capital LLC, Lawall & Mitchell, LLC, Leading Shine NY Ltd., Lexington Property and Staffing, Inc., Lexington Property and Staffing LLC, Linwan \"Irene\" Feng, Limarie Reyes, Lihong \"Sara\" Wei Lafrenz, The Lost Draft LLC, Macaron Limited, Major Lead International Limited, Mary Jiang, MOS Himalaya LLC, Maywind Trading LLC, New York MOS Himalaya LLC, Next Tycoon Investments Limited, Nicholas Savio, Nodal Partners, LLC, Qidong Xia, Oasis Tech Limited, O.S.C. Orbit Service Company, LLC, Pixshow Film Inc., Qu Guo Jiao, Roscalitar 2, Ridwan Mamode Saib, Ross Heinemeyer, Rule of Law Society IV Inc., Rule of Law Foundation\n\n## Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 106 of 439\n\nIII, Inc., Rule of Law Fund, Saraca Media Group Inc., Savio Law LLC, Scott Barnett, Seven Mission Group LLC, Shih Hsin Yu, Sirius Networking Inc., Taurus Fund LLC, Taurus Management LLC, US Himalaya Capital Inc., V.X. Cerda & Associates P.A., Victor Cerda, Voice of Guo Media, Inc., Wen Xiao, Wencong Wang, William Je, Kin Ming Je a/k/a Je Kin Ming, Wise Creation International Limited, Xuebing Wang, Yan Chun Liu, 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, Zhouer \"Joe\" Wang, NewPeople LLC, Ziba Limited, New Mulberry PTE Ltd, TD Primrose Limited, and Shin Hee-Seup a/k/a Hee Seup Shin.\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,\n\n## Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 107 of 439\n\ncharts, 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\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,\n\n## Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 108 of 439\n\nconnected 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 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,\n\n## Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 109 of 439\n\nauthorizations, 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\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\n## Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 110 of 439\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 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 111 of 439\n\n# Exhibit C-6\n\n#### B2540 (Form 2540 – Subpoena for Rule 2004 Examination) (12/15) Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 112 of\n\n439\n\nUNITED STATES BANKRUPTCY COURT\n\n**District of Connecticut**\n\nIn re HO WAN KWOK, *et al*.,\n\n<sup>1</sup> Case No. 22-50073 (JAM) Debtor Chapter 11\n\n(Jointly Administered)\n\n# **SUBPOENA FOR RULE 2004 EXAMINATION**\n\n## To: **CIMN Bank Berhad a/k/a CIMB Islamic Bank Berhad**\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/A   | N/A           |\n|       |               |\n\nThe examination will be recorded by this method: N/A\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\n## **See Requests for Production of Documents, attached hereto.**\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: **May , 2024**\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 Luc A. Despins, Chapter 11 Trustee, who issues or requests this subpoena, are:\n\n**Patrick R. Linsey, Esq.; Neubert, Pepe & Monteith, P.C.; 195 Church Street, 13th Floor, New Haven, Connecticut 06510 plinsey@npmlaw.com; (203) 781-2847**\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\nSoftware Copyright (c) 1996-2022 Best Case, LLC - www.bestcase.com Best Case Bankruptcy 1 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## **PROOF OF SERVICE**\n\n**(This section should not be filed with the court unless required by Fed. R. Civ. P. 45.)**\n\nI received this subpoena for (*name of individual and title, if any*): on (*date*) .\n\nI served the subpoena by delivering a copy to the named person as follows:\n\non *(date)* ; or\n\nI returned the subpoena unexecuted because:\n\nUnless the subpoena was issued on behalf of the United States, or one of its officers or agents, I have also tendered to the witness the fees for one day's attendance, and the mileage allowed by law, in the amount of \\$ .\n\nMy fees are \\$ for travel and \\$ for services, for a total of \\$ .\n\nI declare under penalty of perjury that this information is true and correct.\n\nDate:\n\n*Server's signature*\n\n*Printed name and title*\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;\n\n(ii) requires a person to comply beyond the geographical limits specified 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: (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 trial-preparation 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\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 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 117 of 439\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 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 118 of 439\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 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 119 of 439\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 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 120 of 439\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 subpoena.\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\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 CIMN Bank Berhad (a/k/a CIMB Islamic Bank Berhad), 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 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 122 of 439\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, Aaron Mitchell, ACA Capital Group Limited, Ace Decade Holdings Limited, AI Group Holdings Inc., Alfa Global Ventures Limited, Alphonso Global Ventures Limited, Ana C. Izquiedo-Henn, Andrew Childe, Anthony DiBattista, Anton Development Limited, Booming Sail New York LLC, Beile Li, Bingshang Jiao, Bravo Luck Limited, Brent Petro Inc., Celestial Tide Limited, Chris Lee (a/k/a Nan Li, Mei Guo Xiao Li), China Golden Spring Group (Hong Kong) Ltd., 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 (CA), G Fashion, G Fashion Hold Co. A. Limited, G\n\n## Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 123 of 439\n\nFashion Hold Co. B. Limited, G Fashion Media Group Inc., 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, 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), Haitham Khaled, Hamilton Capital Holdings Inc., Hamilton Digital Assets Funds SP, Hamilton Investment Management Limited, Hamilton Opportunity Fund SPC, Hamilton PE Funds SP, Holy City Hong Kong Ventures Ltd., GS Security Solutions Inc., Alex Hadjcharalambous, 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 Currency Clearing Pty. Ltd., 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, Jessica Mastrogiovanni, Jiaming Liu, Jie Zhang, Jovial Century International Limited, Joyord Sportswear Limited, K Legacy Ltd., Kamel Debeche, Karin Maistrello, Kin Ming Je, Lamp Capital LLC, Lawall & Mitchell, LLC, Leading Shine NY Ltd., Lexington Property and Staffing, Inc., Lexington Property and Staffing LLC, Linwan \"Irene\" Feng, Limarie Reyes, Lihong \"Sara\" Wei Lafrenz, The Lost Draft LLC, Macaron Limited, Major Lead International Limited, Mary Jiang, MOS Himalaya LLC, Maywind Trading LLC, New York MOS Himalaya LLC, Next\n\n## Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 124 of 439\n\nTycoon Investments Limited, Nicholas Savio, Nodal Partners, LLC, Qidong Xia, Oasis Tech Limited, O.S.C. Orbit Service Company, LLC, 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, Seven Mission Group LLC, Shih Hsin Yu, Sirius Networking Inc., Taurus Fund LLC, Taurus Management LLC, US Himalaya Capital Inc., V.X. Cerda & Associates P.A., Victor Cerda, Voice of Guo Media, Inc., Wen Xiao, Wencong Wang, William Je, Kin Ming Je a/k/a Je Kin Ming, Wise Creation International Limited, Xuebing Wang, Yan Chun Liu, 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, Zhouer \"Joe\" Wang, NewPeople LLC, Ziba Limited, New Mulberry PTE Ltd, TD Primrose Limited, and Shin Hee-Seup a/k/a Hee Seup Shin.\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,\n\n## Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 125 of 439\n\ntype, 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\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\n## Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 126 of 439\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 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 statements, 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\n## Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 128 of 439\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 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 129 of 439\n\n# Exhibit C-7\n\n#### B2540 (Form 2540 – Subpoena for Rule 2004 Examination) (12/15) Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 130 of\n\n439\n\nUNITED STATES BANKRUPTCY COURT\n\n**District of Connecticut**\n\nIn re HO WAN KWOK, *et al*.,\n\n<sup>1</sup> Case No. 22-50073 (JAM) Debtor Chapter 11\n\n(Jointly Administered)\n\n# **SUBPOENA FOR RULE 2004 EXAMINATION**\n\nTo: **Evan Cramer**\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/A   | N/A           |\n|       |               |\n\nThe examination will be recorded by this method: N/A\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\n## **See Requests for Production of Documents, attached hereto.**\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: **May , 2024**\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 Luc A. Despins, Chapter 11 Trustee, who issues or requests this subpoena, are:\n\n**Patrick R. Linsey, Esq.; Neubert, Pepe & Monteith, P.C.; 195 Church Street, 13th Floor, New Haven, Connecticut 06510 plinsey@npmlaw.com; (203) 781-2847**\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\nSoftware Copyright (c) 1996-2022 Best Case, LLC - www.bestcase.com Best Case Bankruptcy 1 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## **PROOF OF SERVICE**\n\n**(This section should not be filed with the court unless required by Fed. R. Civ. P. 45.)**\n\nI received this subpoena for (*name of individual and title, if any*): on (*date*) .\n\nI served the subpoena by delivering a copy to the named person as follows:\n\non *(date)* ; or\n\nI returned the subpoena unexecuted because:\n\nUnless the subpoena was issued on behalf of the United States, or one of its officers or agents, I have also tendered to the witness the fees for one day's attendance, and the mileage allowed by law, in the amount of \\$ .\n\nMy fees are \\$ for travel and \\$ for services, for a total of \\$ .\n\nI declare under penalty of perjury that this information is true and correct.\n\nDate:\n\n*Server's signature*\n\n*Printed name and title*\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;\n\n(ii) requires a person to comply beyond the geographical limits specified 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: (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 trial-preparation 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## **Requests 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\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 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 135 of 439\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 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 136 of 439\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 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 137 of 439\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 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 138 of 439\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).\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\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 Evan Cramer, together with all of their agents, attorneys, representatives, employees, and/or anyone acting on their 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\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\n## Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 140 of 439\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, 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. \"Associated Individuals\" means individually and collectively, all individuals that (1) hold, control, have custody over, or discretion over assets owned, controlled, or enjoyed by the Debtor or the Debtor's Family; or (2) have been employees, directors, or otherwise are affiliated with one or more Associated Entities, together with the respective employees, agents, counsel, advisors, or anyone acting on behalf of any of the foregoing. Such Associated Individuals shall include, but are not limited to: Anthony DiBattista, Alex Hadjicharalambous, Bernardo Enriquez, Bingshang Jiao, Beile Li, Brian W. Hofmeister, Charles Gruder, Daniel Podhaskie, David Fallon, Defeng Cao (a/k/a Wayne Cao, Max Cao), Ding Lin, Dinggang Wang (a/k/a 王定刚), Eduardo Eurnekian, Ehsan Masud, Fiona Yu, Gladys Chow, Hao (Gavin) Li (a/k/a Huo Lai), Hao Haidong (a/k/a 郝海东), Han Chunguang (a/k/a 韩春光), Haoran He, Ivan Lin, Haitham Khaled, Jason Miller, Jennifer Mercurio, Jesse Brown, Jessica Mastrogiovanni, Jie Zhang, Jintao Li, Karin Maistrello, Kyle Bass, Lihong Wei Lafrenz (a/k/a Sara Wei, 魏丽红), Linwan \"Irene\" Feng, Max Krasner, Melissa Francis, Michael Baranowitz, Min Yang, Melissa Mendez, Nadeem Akbar, Nan Li (a/k/a Chris Lee, Mei Guo Xiao Li), Qidong Xia, Qu Guojiao (a/k/a Qu Guo Jiao, 屈国姣), Ridwan Mamode Saib, Ross Heinemeyer, Rui \"Ray\" Hao, Scott Barnett, Shih Hsin Yu, Shin Hee-Seup (a/k/a Hee Seup Shin), Steve Bannon, Talha Zobair, Victor Cerda, Wen Xiao, Wencong Wang, William Gertz, William Je (a/k/a Je Kin Ming, Yu Jianming, 余建明), and Xuebing Wang,\n\n## Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 141 of 439\n\nYa Li (a/k/a 李娅), Yinying (Aila) Wang (a/k/a Xiao Fei Xiang), Yongping Yan (Shan Mu), Yong Yu, Yue Zhou, Yumei Hao (a/k/a Ru Shui), Yvette Wang (a/k/a Yanping Wang, Yan Ping Wang, 王雁平), Zhang Wei (a/k/a 张魏), Zhouer Wang (a/k/a Joe Wang), Zhixuan Li, and Ziyang Liu.\n\n8. \"Associated Entities\" means, individually and collectively, all organizations or Entities of any type that (1) have been owned, controlled, or invested in by the Debtor or the Debtor's Family; or (2) have an interest, whether directly or indirectly, in any assets owned, controlled, or enjoyed by the Debtor or the Debtor's Family, together with the respective employees, agents, counsel, advisors, or anyone acting on behalf of any of the foregoing. Such Associated Entities shall include, but are not limited to: 1332156 B.C. Ltd., 7 Nod Hill LLC, AAGV Limited, ACA Investment Management Limited, ACA Capital Group Limited, Ace Decade Holdings Limited, AI Group Holdings Inc., Alfa Global Ventures Limited, Alfonso Global Limited, Allied Capital Global Limited, Alpine Fiduciaries SA, Beijing Pangu Investment Co., Beijing Pangu Investment Co. Ltd., Beijing Pangu Investment Inc., Beijing Zenith Holdings Company Limited, Blue Capital Limited, Booming Sail New York LLC, Bravo Luck Limited, Brent Petro, BSA Strategic Fund I, China Golden Spring (Hong Kong) Limited, Chuang Xin Limited, Crane Advisory Group LLC, Creative Apex Investments Limited, Crystal Breeze Investments Limited, Dawn State Limited, Eastern Profit Corporation Limited, Empire Growth Holdings, Elite Well Global Limited, Freedom Media Ventures Ltd., Fung Wan Trading Inc., G Club, G Club Operations LLC, G Club International Limited, G Club Investments Limited, G Fashion LLC, G-News Operations LLC, G News LLC, GMusic Inc., G-Services LLC, G-Translators PTY LTD, GETTR USA, Inc., Genever Holdings Corporation, Genever Holdings LLC, GFashion Media Group Inc., GFNY, Inc., Globalist International Limited, GNews Media Group Inc., Golden Spring (New York) Ltd., Guo Media, GTV Media Group, Inc., GWGOPNZ\n\n## Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 142 of 439\n\nLimited, GWGNZ Limited, Gypsy Mei Food Services, LLC, HCHK Property Management Inc., HCHK Technologies Inc., Hamilton Digital Assets FD SP, Hamilton Capital Holdings Inc., Hamilton Opportunity Fund SPC, Head Win Group Limited, Himalaya Embassy, Himalaya Exchange, Himalaya Federal Reserve, Himalaya International Financial Group Ltd., Himalaya Investment LLC, Himalaya (USA) Investment Management LLC, Himalaya New World Inc., Himalaya Supervisory Organization, Himalaya Ventures, Holy City Hong Kong Ventures, Ltd., Hudson Diamond Holding LLC, Hudson Diamond Holding Inc., Hudson Diamond NY LLC, HK International Funds Investments (USA) Limited LLC, Hong Kong International Funds Investments Limited, Huk Trading Inc, Infinite Increase Limited, Infinitum Developments Limited, Japan Himalaya League, Inc., Kalixun Trading Limited, Lamp Capital LLC, Leading Shine Limited, Leading Shine NY Limited, Lexington Property and Staffing Inc., Long Gate Limited, MOS Himalaya Foundation Inc., Maywind Trading LLC, New Federal State of China (a/k/a NFSC), New York MOS Himalaya LLC, New Mulberry PTE Ltd., Newpeople LLC, Noble Fame Global Limited, Pixshow Film Inc., Roscalitar 2, Rosy Acme Ventures Limited, Rule of Law Foundation III, Inc., Rule of Law Society, Rule of Law Society IV, Inc., Santel LLC, Saraca Media Group, Inc., Shiny Ace Ltd., Shiny Times Holdings Ltd., Stevenson, Wong & Co., Taurus Fund LLC, Taurus Fund SP, Taurus Management LLC, The Lost Draft LLC, TM Primrose Limited, UA Himalaya Inc., Voice of Guo Media, Inc., Well Origin Ltd., Wise Creation, Whitecroft Shore Limited, World Century Limited, Worldwide Opportunity Holdings Limited, and ZIBA Limited.\n\n9. \"Including\" or any variant thereof means \"including without limitation.\"\n\n10. \"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 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 143 of 439\n\n11. \"Any\" and \"all\" and \"each\" mean \"each and every.\"\n\n12. \"Each\" and \"every\" mean \"each and every.\"\n\n13. \"Third Party\" means a Person or Entity other than Yourself.\n\n14. \"Transfer\" shall have the meaning given to it by section 101(54) of the Bankruptcy Code.\n\n15. \"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, electronic communication, text message, social media post, tweet, meta-data, 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, 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, punchcards, 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 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 144 of 439\n\n16. \"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\n17. \"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 legal counsel, financial advisors, or any other representative.\n\n18. \"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\n19. \"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\n20. \"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,\n\n## Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 145 of 439\n\ntelexes, instant messages, chats, text messages, telephonic notes, or notes transmitted internally or with third parties.\n\n21. \"Asset(s)\" means any item that can be used to produce positive economic value, including but not limited to any resource with economic value that is owned, controlled or is for the benefit of an entity, that is expected to provide a future benefit, including but not limited to, all real and personal property, intangible property, investments, rights to invest or to future revenue, cash, bank accounts, commodities, securities, claims, total or partial control of an entity, and prospective economic opportunities\n\n22. \"Transfer\" shall have the meaning given to it by section 101(54) of the Bankruptcy Code.\n\n## **IV. DOCUMENTS TO BE PRODUCED**\n\n1. All Documents regarding any income or Asset of the Debtor, the Debtor's Family, the Debtor's estate, an Associated Individuals, or an Associated Entity.\n\n2. All Documents related to the Debtor's financial condition and obligations to his creditors, including without limitation all Documents related to any effort to avoid paying such obligations and All Documents related to this or any other actual or potential bankruptcy or similar insolvency proceeding.\n\n3. All Documents regarding any balance sheet, bank statement, account statement, financial statement, statement of account, wire transfer instructions and/or confirmation, proof of funds, certificate of deposit, certificate of holdings, investment portfolio summary, or similar document relating to the Debtor, the Debtor's Estate, the Debtor's Family, an Associated Entity, or an Associated Individual, including without limitation all Documents sufficient to show all Transfers to any of the foregoing.\n\n## Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 146 of 439\n\n4. All Documents regarding any investment, business dealings or transactions made by, with, or on behalf of the Debtor, the Debtor's Family, an Associated Individual, or an Associated Entity.\n\n5. All Communications with the Debtor, the Debtor's Family, an Associated Individual, or an Associated Entity, and Documents related to Communications with the Debtor, the Debtor's Family, an Associated Individual, or an Associated Entity, including related to the operation, management, or decision-making of any Entity, including without limitation the Associated Entities.\n\n6. All Documents regarding any Transfer, investment, or other transaction or business dealing made to, by, or with the Debtor, the Debtor's Family, an Associated Individual, or an Associated Entity.\n\n7. All Documents regarding any property ever occupied or used by the Debtor, including without limitation the residential property located in Greenwich, Connecticut at 373 Taconic Rd.; the residential property located in Greenwich, Connecticut at 33 Ferncliff Rd.; the residential property located in Wilton, Connecticut at 354 Nod Hill Rd; the apartments or condominiums located in 5 Princes Gate London, United Kingdom SW7 1QJ; and the residential property located in Mahwah, New Jersey at 675 Ramapo Valley Road, Mahwah, New Jersey 07430.\n\n8. All Documents related to any aircraft owned, controlled, or used by the Debtor, including without limitation (i) the aircraft bearing tail number T7-GQM and any other aircraft registered in San Marino, including without limitation copies of all registration documents and flight manifests showing flights taken by such aircraft and the individuals onboard such flights, and (ii) any Cirrus SF50 aircraft.\n\n## Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 147 of 439\n\n9. All Documents regarding any gifts, benefits or loans, to, from or on behalf of the Debtor, the Debtor's Estate, the Debtor's Family, or the Associated Entities, including without limitation Documents sufficient to show the amounts of such gifts, benefits, or loans; the purposes for which such gifts, benefits, or loans were used; when the gifts, benefits, or loans were provided; and the terms of any loans, all representations and warranties made in connection with any loans, the interest rate on any loans, and all evidence of payments of any loans.\n\n10. All Documents concerning any trust or similar instrument set up by, on behalf of, or for the benefit of the Debtor, the Debtor's Estate, the Debtor's Family, or an Associated Entity, including without limitation Documents sufficient to show when the trust(s) was created, by whom it was created, for whose benefit it was created, and the corpus of the trust.\n\n11. All Documents related to any obligation, claim, liability, or debt associated with any legal dispute involving the Debtor, including but not limited to those relating to any litigation before any local, state, federal, or international body, whether an administrative body, court, panel, or alternative dispute resolution entity.\n\n12. All Documents and communications with the Debtor, the Debtor's Family, or an Associated Individual.\n\n13. All Documents and communications between any of your counsel or other advisors and the Debtor, the Debtor's Family, or an Associated Individual.\n\n14. All Documents related to any Associated Entity that You hold or have held an interest in.\n\nCase 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 148 of 439\n\n# Exhibit C-8\n\n#### B2540 (Form 2540 – Subpoena for Rule 2004 Examination) (12/15) Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 149 of\n\n439\n\nUNITED STATES BANKRUPTCY COURT\n\n**District of Connecticut**\n\nIn re HO WAN KWOK, *et al*.,\n\n<sup>1</sup> Case No. 22-50073 (JAM) Debtor Chapter 11\n\n(Jointly Administered)\n\n# **SUBPOENA FOR RULE 2004 EXAMINATION**\n\nTo: **Makayla Randall**\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/A   | N/A           |\n|       |               |\n\nThe examination will be recorded by this method: N/A\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\n## **See Requests for Production of Documents, attached hereto.**\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: **May , 2024**\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 Luc A. Despins, Chapter 11 Trustee, who issues or requests this subpoena, are:\n\n**Patrick R. Linsey, Esq.; Neubert, Pepe & Monteith, P.C.; 195 Church Street, 13th Floor, New Haven, Connecticut 06510 plinsey@npmlaw.com; (203) 781-2847**\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\nSoftware Copyright (c) 1996-2022 Best Case, LLC - www.bestcase.com Best Case Bankruptcy 1 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## **PROOF OF SERVICE**\n\n**(This section should not be filed with the court unless required by Fed. R. Civ. P. 45.)**\n\nI received this subpoena for (*name of individual and title, if any*): on (*date*) .\n\nI served the subpoena by delivering a copy to the named person as follows:\n\non *(date)* ; or\n\nI returned the subpoena unexecuted because:\n\nUnless the subpoena was issued on behalf of the United States, or one of its officers or agents, I have also tendered to the witness the fees for one day's attendance, and the mileage allowed by law, in the amount of \\$ .\n\nMy fees are \\$ for travel and \\$ for services, for a total of \\$ .\n\nI declare under penalty of perjury that this information is true and correct.\n\nDate:\n\n*Server's signature*\n\n*Printed name and title*\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;\n\n(ii) requires a person to comply beyond the geographical limits specified 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: (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 trial-preparation 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## **Requests 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\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 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 154 of 439\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 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 155 of 439\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 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 156 of 439\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 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 157 of 439\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).\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\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## Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 158 of 439\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 Makaya Randall, together with all of their agents, attorneys, representatives, employees, and/or anyone acting on their 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\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\n## Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 159 of 439\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, 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. \"Associated Individuals\" means individually and collectively, all individuals that (1) hold, control, have custody over, or discretion over assets owned, controlled, or enjoyed by the Debtor or the Debtor's Family; or (2) have been employees, directors, or otherwise are affiliated with one or more Associated Entities, together with the respective employees, agents, counsel, advisors, or anyone acting on behalf of any of the foregoing. Such Associated Individuals shall include, but are not limited to: Anthony DiBattista, Alex Hadjicharalambous, Bernardo Enriquez, Bingshang Jiao, Beile Li, Brian W. Hofmeister, Charles Gruder, Daniel Podhaskie, David Fallon, Defeng Cao (a/k/a Wayne Cao, Max Cao), Ding Lin, Dinggang Wang (a/k/a 王定刚), Eduardo Eurnekian, Ehsan Masud, Fiona Yu, Gladys Chow, Hao (Gavin) Li (a/k/a Huo Lai), Hao Haidong (a/k/a 郝海东), Han Chunguang (a/k/a 韩春光), Haoran He, Ivan Lin, Haitham Khaled, Jason Miller, Jennifer Mercurio, Jesse Brown, Jessica Mastrogiovanni, Jie Zhang, Jintao Li, Karin Maistrello, Kyle Bass, Lihong Wei Lafrenz (a/k/a Sara Wei, 魏丽红), Linwan \"Irene\" Feng, Max Krasner, Melissa Francis, Michael Baranowitz, Min Yang, Melissa Mendez, Nadeem Akbar, Nan Li (a/k/a Chris Lee, Mei Guo Xiao Li), Qidong Xia, Qu Guojiao (a/k/a Qu Guo Jiao, 屈国姣), Ridwan Mamode Saib, Ross Heinemeyer, Rui \"Ray\" Hao, Scott Barnett, Shih Hsin Yu, Shin Hee-\n\n## Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 160 of 439\n\nSeup (a/k/a Hee Seup Shin), Steve Bannon, Talha Zobair, Victor Cerda, Wen Xiao, Wencong Wang, William Gertz, William Je (a/k/a Je Kin Ming, Yu Jianming, 余建明), and Xuebing Wang, Ya Li (a/k/a 李娅), Yinying (Aila) Wang (a/k/a Xiao Fei Xiang), Yongping Yan (Shan Mu), Yong Yu, Yue Zhou, Yumei Hao (a/k/a Ru Shui), Yvette Wang (a/k/a Yanping Wang, Yan Ping Wang, 王雁平), Zhang Wei (a/k/a 张魏), Zhouer Wang (a/k/a Joe Wang), Zhixuan Li, and Ziyang Liu.\n\n8. \"Associated Entities\" means, individually and collectively, all organizations or Entities of any type that (1) have been owned, controlled, or invested in by the Debtor or the Debtor's Family; or (2) have an interest, whether directly or indirectly, in any assets owned, controlled, or enjoyed by the Debtor or the Debtor's Family, together with the respective employees, agents, counsel, advisors, or anyone acting on behalf of any of the foregoing. Such Associated Entities shall include, but are not limited to: 1332156 B.C. Ltd., 7 Nod Hill LLC, AAGV Limited, ACA Investment Management Limited, ACA Capital Group Limited, Ace Decade Holdings Limited, AI Group Holdings Inc., Alfa Global Ventures Limited, Alfonso Global Limited, Allied Capital Global Limited, Alpine Fiduciaries SA, Beijing Pangu Investment Co., Beijing Pangu Investment Co. Ltd., Beijing Pangu Investment Inc., Beijing Zenith Holdings Company Limited, Blue Capital Limited, Booming Sail New York LLC, Bravo Luck Limited, Brent Petro, BSA Strategic Fund I, China Golden Spring (Hong Kong) Limited, Chuang Xin Limited, Crane Advisory Group LLC, Creative Apex Investments Limited, Crystal Breeze Investments Limited, Dawn State Limited, Eastern Profit Corporation Limited, Empire Growth Holdings, Elite Well Global Limited, Freedom Media Ventures Ltd., Fung Wan Trading Inc., G Club, G Club Operations LLC, G Club International Limited, G Club Investments Limited, G Fashion LLC, G-News Operations LLC, G News LLC, GMusic Inc., G-Services LLC, G-Translators PTY LTD, GETTR USA, Inc., Genever Holdings Corporation, Genever Holdings\n\n## Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 161 of 439\n\nLLC, GFashion Media Group Inc., GFNY, Inc., Globalist International Limited, GNews Media Group Inc., Golden Spring (New York) Ltd., Guo Media, GTV Media Group, Inc., GWGOPNZ Limited, GWGNZ Limited, Gypsy Mei Food Services, LLC, HCHK Property Management Inc., HCHK Technologies Inc., Hamilton Digital Assets FD SP, Hamilton Capital Holdings Inc., Hamilton Opportunity Fund SPC, Head Win Group Limited, Himalaya Embassy, Himalaya Exchange, Himalaya Federal Reserve, Himalaya International Financial Group Ltd., Himalaya Investment LLC, Himalaya (USA) Investment Management LLC, Himalaya New World Inc., Himalaya Supervisory Organization, Himalaya Ventures, Holy City Hong Kong Ventures, Ltd., Hudson Diamond Holding LLC, Hudson Diamond Holding Inc., Hudson Diamond NY LLC, HK International Funds Investments (USA) Limited LLC, Hong Kong International Funds Investments Limited, Huk Trading Inc, Infinite Increase Limited, Infinitum Developments Limited, Japan Himalaya League, Inc., Kalixun Trading Limited, Lamp Capital LLC, Leading Shine Limited, Leading Shine NY Limited, Lexington Property and Staffing Inc., Long Gate Limited, MOS Himalaya Foundation Inc., Maywind Trading LLC, New Federal State of China (a/k/a NFSC), New York MOS Himalaya LLC, New Mulberry PTE Ltd., Newpeople LLC, Noble Fame Global Limited, Pixshow Film Inc., Roscalitar 2, Rosy Acme Ventures Limited, Rule of Law Foundation III, Inc., Rule of Law Society, Rule of Law Society IV, Inc., Santel LLC, Saraca Media Group, Inc., Shiny Ace Ltd., Shiny Times Holdings Ltd., Stevenson, Wong & Co., Taurus Fund LLC, Taurus Fund SP, Taurus Management LLC, The Lost Draft LLC, TM Primrose Limited, UA Himalaya Inc., Voice of Guo Media, Inc., Well Origin Ltd., Wise Creation, Whitecroft Shore Limited, World Century Limited, Worldwide Opportunity Holdings Limited, and ZIBA Limited.\n\n9. \"Including\" or any variant thereof means \"including without limitation.\"\n\n## Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 162 of 439\n\n10. \"And\" and \"or\" mean \"and/or,\" and shall be construed both conjunctively as well as disjunctively in order to maximize their scope.\n\n11. \"Any\" and \"all\" and \"each\" mean \"each and every.\"\n\n12. \"Each\" and \"every\" mean \"each and every.\"\n\n13. \"Third Party\" means a Person or Entity other than Yourself.\n\n14. \"Transfer\" shall have the meaning given to it by section 101(54) of the Bankruptcy Code.\n\n15. \"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, electronic communication, text message, social media post, tweet, meta-data, 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, 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, punchcards, 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\n\n## Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 163 of 439\n\nof 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\n16. \"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\n17. \"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 legal counsel, financial advisors, or any other representative.\n\n18. \"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\n19. \"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\n20. \"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\n\n## Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 164 of 439\n\nslips, memoranda, telephone communications, voice messages, telegrams, telefaxes, telecopies, telexes, instant messages, chats, text messages, telephonic notes, or notes transmitted internally or with third parties.\n\n21. \"Asset(s)\" means any item that can be used to produce positive economic value, including but not limited to any resource with economic value that is owned, controlled or is for the benefit of an entity, that is expected to provide a future benefit, including but not limited to, all real and personal property, intangible property, investments, rights to invest or to future revenue, cash, bank accounts, commodities, securities, claims, total or partial control of an entity, and prospective economic opportunities\n\n22. \"Transfer\" shall have the meaning given to it by section 101(54) of the Bankruptcy Code.\n\n## **IV. DOCUMENTS TO BE PRODUCED**\n\n1. All Documents regarding any income or Asset of the Debtor, the Debtor's Family, the Debtor's estate, an Associated Individuals, or an Associated Entity.\n\n2. All Documents related to the Debtor's financial condition and obligations to his creditors, including without limitation all Documents related to any effort to avoid paying such obligations and All Documents related to this or any other actual or potential bankruptcy or similar insolvency proceeding.\n\n3. All Documents regarding any balance sheet, bank statement, account statement, financial statement, statement of account, wire transfer instructions and/or confirmation, proof of funds, certificate of deposit, certificate of holdings, investment portfolio summary, or similar document relating to the Debtor, the Debtor's Estate, the Debtor's Family, an Associated Entity,\n\n## Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 165 of 439\n\nor an Associated Individual, including without limitation all Documents sufficient to show all Transfers to any of the foregoing.\n\n4. All Documents regarding any investment, business dealings or transactions made by, with, or on behalf of the Debtor, the Debtor's Family, an Associated Individual, or an Associated Entity.\n\n5. All Communications with the Debtor, the Debtor's Family, an Associated Individual, or an Associated Entity, and Documents related to Communications with the Debtor, the Debtor's Family, an Associated Individual, or an Associated Entity, including related to the operation, management, or decision-making of any Entity, including without limitation the Associated Entities.\n\n6. All Documents regarding any Transfer, investment, or other transaction or business dealing made to, by, or with the Debtor, the Debtor's Family, an Associated Individual, or an Associated Entity.\n\n7. All Documents regarding any property ever occupied or used by the Debtor, including without limitation the residential property located in Greenwich, Connecticut at 373 Taconic Rd.; the residential property located in Greenwich, Connecticut at 33 Ferncliff Rd.; the residential property located in Wilton, Connecticut at 354 Nod Hill Rd; the apartments or condominiums located in 5 Princes Gate London, United Kingdom SW7 1QJ; and the residential property located in Mahwah, New Jersey at 675 Ramapo Valley Road, Mahwah, New Jersey 07430.\n\n8. All Documents related to any aircraft owned, controlled, or used by the Debtor, including without limitation (i) the aircraft bearing tail number T7-GQM and any other aircraft\n\n## Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 166 of 439\n\nregistered in San Marino, including without limitation copies of all registration documents and flight manifests showing flights taken by such aircraft and the individuals onboard such flights, and (ii) any Cirrus SF50 aircraft.\n\n9. All Documents regarding any gifts, benefits or loans, to, from or on behalf of the Debtor, the Debtor's Estate, the Debtor's Family, or the Associated Entities, including without limitation Documents sufficient to show the amounts of such gifts, benefits, or loans; the purposes for which such gifts, benefits, or loans were used; when the gifts, benefits, or loans were provided; and the terms of any loans, all representations and warranties made in connection with any loans, the interest rate on any loans, and all evidence of payments of any loans.\n\n10. All Documents concerning any trust or similar instrument set up by, on behalf of, or for the benefit of the Debtor, the Debtor's Estate, the Debtor's Family, or an Associated Entity, including without limitation Documents sufficient to show when the trust(s) was created, by whom it was created, for whose benefit it was created, and the corpus of the trust.\n\n11. All Documents related to any obligation, claim, liability, or debt associated with any legal dispute involving the Debtor, including but not limited to those relating to any litigation before any local, state, federal, or international body, whether an administrative body, court, panel, or alternative dispute resolution entity.\n\n12. All Documents and communications with the Debtor, the Debtor's Family, or an Associated Individual.\n\n13. All Documents and communications between any of your counsel or other advisors and the Debtor, the Debtor's Family, or an Associated Individual.\n\n## Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 167 of 439\n\n14. All Documents related to any Associated Entity that You hold or have held an interest in.\n\nCase 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 168 of 439\n\n# Exhibit C-9\n\n#### B2540 (Form 2540 – Subpoena for Rule 2004 Examination) (12/15) Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 169 of\n\n439\n\nUNITED STATES BANKRUPTCY COURT\n\n**District of Connecticut**\n\nIn re HO WAN KWOK, *et al*.,\n\n<sup>1</sup> Case No. 22-50073 (JAM) Debtor Chapter 11\n\n(Jointly Administered)\n\n# **SUBPOENA FOR RULE 2004 EXAMINATION**\n\nTo: **Richard Leahy**\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/A   | N/A           |\n|       |               |\n\nThe examination will be recorded by this method: N/A\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\n## **See Requests for Production of Documents, attached hereto.**\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: **May , 2024**\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 Luc A. Despins, Chapter 11 Trustee, who issues or requests this subpoena, are:\n\n**Patrick R. Linsey, Esq.; Neubert, Pepe & Monteith, P.C.; 195 Church Street, 13th Floor, New Haven, Connecticut 06510 plinsey@npmlaw.com; (203) 781-2847**\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\nSoftware Copyright (c) 1996-2022 Best Case, LLC - www.bestcase.com Best Case Bankruptcy 1 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## **PROOF OF SERVICE**\n\n**(This section should not be filed with the court unless required by Fed. R. Civ. P. 45.)**\n\nI received this subpoena for (*name of individual and title, if any*): on (*date*) .\n\nI served the subpoena by delivering a copy to the named person as follows:\n\non *(date)* ; or\n\nI returned the subpoena unexecuted because:\n\nUnless the subpoena was issued on behalf of the United States, or one of its officers or agents, I have also tendered to the witness the fees for one day's attendance, and the mileage allowed by law, in the amount of \\$ .\n\nMy fees are \\$ for travel and \\$ for services, for a total of \\$ .\n\nI declare under penalty of perjury that this information is true and correct.\n\nDate:\n\n*Server's signature*\n\n*Printed name and title*\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;\n\n(ii) requires a person to comply beyond the geographical limits specified 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: (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 trial-preparation 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## **Requests 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\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| 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 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 175 of 439\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 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 176 of 439\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 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 177 of 439\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).\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\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 Richard Leahy, together with all of their agents, attorneys, representatives, employees, and/or anyone acting on their 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\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\n## Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 179 of 439\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, 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. \"Associated Individuals\" means individually and collectively, all individuals that (1) hold, control, have custody over, or discretion over assets owned, controlled, or enjoyed by the Debtor or the Debtor's Family; or (2) have been employees, directors, or otherwise are affiliated with one or more Associated Entities, together with the respective employees, agents, counsel, advisors, or anyone acting on behalf of any of the foregoing. Such Associated Individuals shall include, but are not limited to: Anthony DiBattista, Alex Hadjicharalambous, Bernardo Enriquez, Bingshang Jiao, Beile Li, Brian W. Hofmeister, Charles Gruder, Daniel Podhaskie, David Fallon, Defeng Cao (a/k/a Wayne Cao, Max Cao), Ding Lin, Dinggang Wang (a/k/a 王定刚), Eduardo Eurnekian, Ehsan Masud, Fiona Yu, Gladys Chow, Hao (Gavin) Li (a/k/a Huo Lai), Hao Haidong (a/k/a 郝海东), Han Chunguang (a/k/a 韩春光), Haoran He, Ivan Lin, Haitham Khaled, Jason Miller, Jennifer Mercurio, Jesse Brown, Jessica Mastrogiovanni, Jie Zhang, Jintao Li, Karin Maistrello, Kyle Bass, Lihong Wei Lafrenz (a/k/a Sara Wei, 魏丽红), Linwan \"Irene\" Feng, Max Krasner, Melissa Francis, Michael Baranowitz, Min Yang, Melissa Mendez, Nadeem Akbar, Nan Li (a/k/a Chris Lee, Mei Guo Xiao Li), Qidong Xia, Qu Guojiao (a/k/a Qu Guo Jiao, 屈国姣), Ridwan Mamode Saib, Ross Heinemeyer, Rui \"Ray\" Hao, Scott Barnett, Shih Hsin Yu, Shin Hee-Seup (a/k/a Hee Seup Shin), Steve Bannon, Talha Zobair, Victor Cerda, Wen Xiao, Wencong Wang, William Gertz, William Je (a/k/a Je Kin Ming, Yu Jianming, 余建明), and Xuebing Wang,\n\n## Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 180 of 439\n\nYa Li (a/k/a 李娅), Yinying (Aila) Wang (a/k/a Xiao Fei Xiang), Yongping Yan (Shan Mu), Yong Yu, Yue Zhou, Yumei Hao (a/k/a Ru Shui), Yvette Wang (a/k/a Yanping Wang, Yan Ping Wang, 王雁平), Zhang Wei (a/k/a 张魏), Zhouer Wang (a/k/a Joe Wang), Zhixuan Li, and Ziyang Liu.\n\n8. \"Associated Entities\" means, individually and collectively, all organizations or Entities of any type that (1) have been owned, controlled, or invested in by the Debtor or the Debtor's Family; or (2) have an interest, whether directly or indirectly, in any assets owned, controlled, or enjoyed by the Debtor or the Debtor's Family, together with the respective employees, agents, counsel, advisors, or anyone acting on behalf of any of the foregoing. Such Associated Entities shall include, but are not limited to: 1332156 B.C. Ltd., 7 Nod Hill LLC, AAGV Limited, ACA Investment Management Limited, ACA Capital Group Limited, Ace Decade Holdings Limited, AI Group Holdings Inc., Alfa Global Ventures Limited, Alfonso Global Limited, Allied Capital Global Limited, Alpine Fiduciaries SA, Beijing Pangu Investment Co., Beijing Pangu Investment Co. Ltd., Beijing Pangu Investment Inc., Beijing Zenith Holdings Company Limited, Blue Capital Limited, Booming Sail New York LLC, Bravo Luck Limited, Brent Petro, BSA Strategic Fund I, China Golden Spring (Hong Kong) Limited, Chuang Xin Limited, Crane Advisory Group LLC, Creative Apex Investments Limited, Crystal Breeze Investments Limited, Dawn State Limited, Eastern Profit Corporation Limited, Empire Growth Holdings, Elite Well Global Limited, Freedom Media Ventures Ltd., Fung Wan Trading Inc., G Club, G Club Operations LLC, G Club International Limited, G Club Investments Limited, G Fashion LLC, G-News Operations LLC, G News LLC, GMusic Inc., G-Services LLC, G-Translators PTY LTD, GETTR USA, Inc., Genever Holdings Corporation, Genever Holdings LLC, GFashion Media Group Inc., GFNY, Inc., Globalist International Limited, GNews Media Group Inc., Golden Spring (New York) Ltd., Guo Media, GTV Media Group, Inc., GWGOPNZ\n\n## Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 181 of 439\n\nLimited, GWGNZ Limited, Gypsy Mei Food Services, LLC, HCHK Property Management Inc., HCHK Technologies Inc., Hamilton Digital Assets FD SP, Hamilton Capital Holdings Inc., Hamilton Opportunity Fund SPC, Head Win Group Limited, Himalaya Embassy, Himalaya Exchange, Himalaya Federal Reserve, Himalaya International Financial Group Ltd., Himalaya Investment LLC, Himalaya (USA) Investment Management LLC, Himalaya New World Inc., Himalaya Supervisory Organization, Himalaya Ventures, Holy City Hong Kong Ventures, Ltd., Hudson Diamond Holding LLC, Hudson Diamond Holding Inc., Hudson Diamond NY LLC, HK International Funds Investments (USA) Limited LLC, Hong Kong International Funds Investments Limited, Huk Trading Inc, Infinite Increase Limited, Infinitum Developments Limited, Japan Himalaya League, Inc., Kalixun Trading Limited, Lamp Capital LLC, Leading Shine Limited, Leading Shine NY Limited, Lexington Property and Staffing Inc., Long Gate Limited, MOS Himalaya Foundation Inc., Maywind Trading LLC, New Federal State of China (a/k/a NFSC), New York MOS Himalaya LLC, New Mulberry PTE Ltd., Newpeople LLC, Noble Fame Global Limited, Pixshow Film Inc., Roscalitar 2, Rosy Acme Ventures Limited, Rule of Law Foundation III, Inc., Rule of Law Society, Rule of Law Society IV, Inc., Santel LLC, Saraca Media Group, Inc., Shiny Ace Ltd., Shiny Times Holdings Ltd., Stevenson, Wong & Co., Taurus Fund LLC, Taurus Fund SP, Taurus Management LLC, The Lost Draft LLC, TM Primrose Limited, UA Himalaya Inc., Voice of Guo Media, Inc., Well Origin Ltd., Wise Creation, Whitecroft Shore Limited, World Century Limited, Worldwide Opportunity Holdings Limited, and ZIBA Limited.\n\n9. \"Including\" or any variant thereof means \"including without limitation.\"\n\n10. \"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 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 182 of 439\n\n11. \"Any\" and \"all\" and \"each\" mean \"each and every.\"\n\n12. \"Each\" and \"every\" mean \"each and every.\"\n\n13. \"Third Party\" means a Person or Entity other than Yourself.\n\n14. \"Transfer\" shall have the meaning given to it by section 101(54) of the Bankruptcy Code.\n\n15. \"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, electronic communication, text message, social media post, tweet, meta-data, 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, 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, punchcards, 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 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 183 of 439\n\n16. \"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\n17. \"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 legal counsel, financial advisors, or any other representative.\n\n18. \"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\n19. \"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\n20. \"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,\n\n## Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 184 of 439\n\ntelexes, instant messages, chats, text messages, telephonic notes, or notes transmitted internally or with third parties.\n\n21. \"Asset(s)\" means any item that can be used to produce positive economic value, including but not limited to any resource with economic value that is owned, controlled or is for the benefit of an entity, that is expected to provide a future benefit, including but not limited to, all real and personal property, intangible property, investments, rights to invest or to future revenue, cash, bank accounts, commodities, securities, claims, total or partial control of an entity, and prospective economic opportunities\n\n22. \"Transfer\" shall have the meaning given to it by section 101(54) of the Bankruptcy Code.\n\n## **IV. DOCUMENTS TO BE PRODUCED**\n\n1. All Documents regarding any income or Asset of the Debtor, the Debtor's Family, the Debtor's estate, an Associated Individuals, or an Associated Entity.\n\n2. All Documents related to the Debtor's financial condition and obligations to his creditors, including without limitation all Documents related to any effort to avoid paying such obligations and All Documents related to this or any other actual or potential bankruptcy or similar insolvency proceeding.\n\n3. All Documents regarding any balance sheet, bank statement, account statement, financial statement, statement of account, wire transfer instructions and/or confirmation, proof of funds, certificate of deposit, certificate of holdings, investment portfolio summary, or similar document relating to the Debtor, the Debtor's Estate, the Debtor's Family, an Associated Entity, or an Associated Individual, including without limitation all Documents sufficient to show all Transfers to any of the foregoing.\n\n## Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 185 of 439\n\n4. All Documents regarding any investment, business dealings or transactions made by, with, or on behalf of the Debtor, the Debtor's Family, an Associated Individual, or an Associated Entity.\n\n5. All Communications with the Debtor, the Debtor's Family, an Associated Individual, or an Associated Entity, and Documents related to Communications with the Debtor, the Debtor's Family, an Associated Individual, or an Associated Entity, including related to the operation, management, or decision-making of any Entity, including without limitation the Associated Entities.\n\n6. All Documents regarding any Transfer, investment, or other transaction or business dealing made to, by, or with the Debtor, the Debtor's Family, an Associated Individual, or an Associated Entity.\n\n7. All Documents regarding any property ever occupied or used by the Debtor, including without limitation the residential property located in Greenwich, Connecticut at 373 Taconic Rd.; the residential property located in Greenwich, Connecticut at 33 Ferncliff Rd.; the residential property located in Wilton, Connecticut at 354 Nod Hill Rd; the apartments or condominiums located in 5 Princes Gate London, United Kingdom SW7 1QJ; and the residential property located in Mahwah, New Jersey at 675 Ramapo Valley Road, Mahwah, New Jersey 07430.\n\n8. All Documents related to any aircraft owned, controlled, or used by the Debtor, including without limitation (i) the aircraft bearing tail number T7-GQM and any other aircraft registered in San Marino, including without limitation copies of all registration documents and flight manifests showing flights taken by such aircraft and the individuals onboard such flights, and (ii) any Cirrus SF50 aircraft.\n\n## Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 186 of 439\n\n9. All Documents regarding any gifts, benefits or loans, to, from or on behalf of the Debtor, the Debtor's Estate, the Debtor's Family, or the Associated Entities, including without limitation Documents sufficient to show the amounts of such gifts, benefits, or loans; the purposes for which such gifts, benefits, or loans were used; when the gifts, benefits, or loans were provided; and the terms of any loans, all representations and warranties made in connection with any loans, the interest rate on any loans, and all evidence of payments of any loans.\n\n10. All Documents concerning any trust or similar instrument set up by, on behalf of, or for the benefit of the Debtor, the Debtor's Estate, the Debtor's Family, or an Associated Entity, including without limitation Documents sufficient to show when the trust(s) was created, by whom it was created, for whose benefit it was created, and the corpus of the trust.\n\n11. All Documents related to any obligation, claim, liability, or debt associated with any legal dispute involving the Debtor, including but not limited to those relating to any litigation before any local, state, federal, or international body, whether an administrative body, court, panel, or alternative dispute resolution entity.\n\n12. All Documents and communications with the Debtor, the Debtor's Family, or an Associated Individual.\n\n13. All Documents and communications between any of your counsel or other advisors and the Debtor, the Debtor's Family, or an Associated Individual.\n\n14. All Documents related to any Associated Entity that You hold or have held an interest in.\n\n# Exhibit C-10\n\nB2540 (Form 2540 – Subpoena for Rule 2004 Examination) (12/15) Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 188 of\n\nUNITED STATES BANKRUPTCY COURT 439\n\n**District of Connecticut**\n\nIn re HO WAN KWOK, *et al*.,\n\n<sup>1</sup> Case No. 22-50073 (JAM)\n\nDebtor Chapter 11\n\n(Jointly Administered)\n\n**SUBPOENA FOR RULE 2004 EXAMINATION**\n\nTo: **Thomas Guarino (a/k/a Thomas Guarino II)**\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/A   | N/A           |\n|       |               |\n\nThe examination will be recorded by this method: N/A\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\n## **See Requests for Production of Documents, attached hereto.**\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: **May , 2024**\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 Luc A. Despins, Chapter 11 Trustee, who issues or requests this subpoena, are:\n\n**Patrick R. Linsey, Esq.; Neubert, Pepe & Monteith, P.C.; 195 Church Street, 13th Floor, New Haven, Connecticut 06510 plinsey@npmlaw.com; (203) 781-2847**\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\nSoftware Copyright (c) 1996-2022 Best Case, LLC - www.bestcase.com Best Case Bankruptcy 1 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## **PROOF OF SERVICE**\n\n**(This section should not be filed with the court unless required by Fed. R. Civ. P. 45.)**\n\nI received this subpoena for (*name of individual and title, if any*): on (*date*) .\n\nI served the subpoena by delivering a copy to the named person as follows:\n\non *(date)* ; or\n\nI returned the subpoena unexecuted because:\n\nUnless the subpoena was issued on behalf of the United States, or one of its officers or agents, I have also tendered to the witness the fees for one day's attendance, and the mileage allowed by law, in the amount of \\$ .\n\nMy fees are \\$ for travel and \\$ for services, for a total of \\$ .\n\nI declare under penalty of perjury that this information is true and correct.\n\nDate:\n\n*Server's signature*\n\n*Printed name and title*\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;\n\n(ii) requires a person to comply beyond the geographical limits specified 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: (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 trial-preparation 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## **Requests 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\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 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 193 of 439\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 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 194 of 439\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 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 195 of 439\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 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 196 of 439\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).\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\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 Thomas Guarino (a/k/a Thomas Guarino II), together with all of their agents, attorneys, representatives, employees, and/or anyone acting on their 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\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\n## Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 198 of 439\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, 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. \"Associated Individuals\" means individually and collectively, all individuals that (1) hold, control, have custody over, or discretion over assets owned, controlled, or enjoyed by the Debtor or the Debtor's Family; or (2) have been employees, directors, or otherwise are affiliated with one or more Associated Entities, together with the respective employees, agents, counsel, advisors, or anyone acting on behalf of any of the foregoing. Such Associated Individuals shall include, but are not limited to: Anthony DiBattista, Alex Hadjicharalambous, Bernardo Enriquez, Bingshang Jiao, Beile Li, Brian W. Hofmeister, Charles Gruder, Daniel Podhaskie, David Fallon, Defeng Cao (a/k/a Wayne Cao, Max Cao), Ding Lin, Dinggang Wang (a/k/a 王定刚), Eduardo Eurnekian, Ehsan Masud, Fiona Yu, Gladys Chow, Hao (Gavin) Li (a/k/a Huo Lai), Hao Haidong (a/k/a 郝海东), Han Chunguang (a/k/a 韩春光), Haoran He, Ivan Lin, Haitham Khaled, Jason Miller, Jennifer Mercurio, Jesse Brown, Jessica Mastrogiovanni, Jie Zhang, Jintao Li, Karin Maistrello, Kyle Bass, Lihong Wei Lafrenz (a/k/a Sara Wei, 魏丽红), Linwan \"Irene\" Feng, Max Krasner, Melissa Francis, Michael Baranowitz, Min Yang, Melissa Mendez, Nadeem Akbar, Nan Li (a/k/a Chris Lee, Mei Guo Xiao Li), Qidong Xia, Qu Guojiao (a/k/a Qu Guo Jiao, 屈国姣), Ridwan Mamode Saib, Ross Heinemeyer, Rui \"Ray\" Hao, Scott Barnett, Shih Hsin Yu, Shin Hee-\n\n## Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 199 of 439\n\nSeup (a/k/a Hee Seup Shin), Steve Bannon, Talha Zobair, Victor Cerda, Wen Xiao, Wencong Wang, William Gertz, William Je (a/k/a Je Kin Ming, Yu Jianming, 余建明), and Xuebing Wang, Ya Li (a/k/a 李娅), Yinying (Aila) Wang (a/k/a Xiao Fei Xiang), Yongping Yan (Shan Mu), Yong Yu, Yue Zhou, Yumei Hao (a/k/a Ru Shui), Yvette Wang (a/k/a Yanping Wang, Yan Ping Wang, 王雁平), Zhang Wei (a/k/a 张魏), Zhouer Wang (a/k/a Joe Wang), Zhixuan Li, and Ziyang Liu.\n\n8. \"Associated Entities\" means, individually and collectively, all organizations or Entities of any type that (1) have been owned, controlled, or invested in by the Debtor or the Debtor's Family; or (2) have an interest, whether directly or indirectly, in any assets owned, controlled, or enjoyed by the Debtor or the Debtor's Family, together with the respective employees, agents, counsel, advisors, or anyone acting on behalf of any of the foregoing. Such Associated Entities shall include, but are not limited to: 1332156 B.C. Ltd., 7 Nod Hill LLC, AAGV Limited, ACA Investment Management Limited, ACA Capital Group Limited, Ace Decade Holdings Limited, AI Group Holdings Inc., Alfa Global Ventures Limited, Alfonso Global Limited, Allied Capital Global Limited, Alpine Fiduciaries SA, Beijing Pangu Investment Co., Beijing Pangu Investment Co. Ltd., Beijing Pangu Investment Inc., Beijing Zenith Holdings Company Limited, Blue Capital Limited, Booming Sail New York LLC, Bravo Luck Limited, Brent Petro, BSA Strategic Fund I, China Golden Spring (Hong Kong) Limited, Chuang Xin Limited, Crane Advisory Group LLC, Creative Apex Investments Limited, Crystal Breeze Investments Limited, Dawn State Limited, Eastern Profit Corporation Limited, Empire Growth Holdings, Elite Well Global Limited, Freedom Media Ventures Ltd., Fung Wan Trading Inc., G Club, G Club Operations LLC, G Club International Limited, G Club Investments Limited, G Fashion LLC, G-News Operations LLC, G News LLC, GMusic Inc., G-Services LLC, G-Translators PTY LTD, GETTR USA, Inc., Genever Holdings Corporation, Genever Holdings\n\n## Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 200 of 439\n\nLLC, GFashion Media Group Inc., GFNY, Inc., Globalist International Limited, GNews Media Group Inc., Golden Spring (New York) Ltd., Guo Media, GTV Media Group, Inc., GWGOPNZ Limited, GWGNZ Limited, Gypsy Mei Food Services, LLC, HCHK Property Management Inc., HCHK Technologies Inc., Hamilton Digital Assets FD SP, Hamilton Capital Holdings Inc., Hamilton Opportunity Fund SPC, Head Win Group Limited, Himalaya Embassy, Himalaya Exchange, Himalaya Federal Reserve, Himalaya International Financial Group Ltd., Himalaya Investment LLC, Himalaya (USA) Investment Management LLC, Himalaya New World Inc., Himalaya Supervisory Organization, Himalaya Ventures, Holy City Hong Kong Ventures, Ltd., Hudson Diamond Holding LLC, Hudson Diamond Holding Inc., Hudson Diamond NY LLC, HK International Funds Investments (USA) Limited LLC, Hong Kong International Funds Investments Limited, Huk Trading Inc, Infinite Increase Limited, Infinitum Developments Limited, Japan Himalaya League, Inc., Kalixun Trading Limited, Lamp Capital LLC, Leading Shine Limited, Leading Shine NY Limited, Lexington Property and Staffing Inc., Long Gate Limited, MOS Himalaya Foundation Inc., Maywind Trading LLC, New Federal State of China (a/k/a NFSC), New York MOS Himalaya LLC, New Mulberry PTE Ltd., Newpeople LLC, Noble Fame Global Limited, Pixshow Film Inc., Roscalitar 2, Rosy Acme Ventures Limited, Rule of Law Foundation III, Inc., Rule of Law Society, Rule of Law Society IV, Inc., Santel LLC, Saraca Media Group, Inc., Shiny Ace Ltd., Shiny Times Holdings Ltd., Stevenson, Wong & Co., Taurus Fund LLC, Taurus Fund SP, Taurus Management LLC, The Lost Draft LLC, TM Primrose Limited, UA Himalaya Inc., Voice of Guo Media, Inc., Well Origin Ltd., Wise Creation, Whitecroft Shore Limited, World Century Limited, Worldwide Opportunity Holdings Limited, and ZIBA Limited.\n\n9. \"Including\" or any variant thereof means \"including without limitation.\"\n\n## Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 201 of 439\n\n10. \"And\" and \"or\" mean \"and/or,\" and shall be construed both conjunctively as well as disjunctively in order to maximize their scope.\n\n11. \"Any\" and \"all\" and \"each\" mean \"each and every.\"\n\n12. \"Each\" and \"every\" mean \"each and every.\"\n\n13. \"Third Party\" means a Person or Entity other than Yourself.\n\n14. \"Transfer\" shall have the meaning given to it by section 101(54) of the Bankruptcy Code.\n\n15. \"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, electronic communication, text message, social media post, tweet, meta-data, 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, 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, punchcards, 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\n\n## Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 202 of 439\n\nof 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\n16. \"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\n17. \"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 legal counsel, financial advisors, or any other representative.\n\n18. \"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\n19. \"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\n20. \"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\n\n## Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 203 of 439\n\nslips, memoranda, telephone communications, voice messages, telegrams, telefaxes, telecopies, telexes, instant messages, chats, text messages, telephonic notes, or notes transmitted internally or with third parties.\n\n21. \"Asset(s)\" means any item that can be used to produce positive economic value, including but not limited to any resource with economic value that is owned, controlled or is for the benefit of an entity, that is expected to provide a future benefit, including but not limited to, all real and personal property, intangible property, investments, rights to invest or to future revenue, cash, bank accounts, commodities, securities, claims, total or partial control of an entity, and prospective economic opportunities\n\n22. \"Transfer\" shall have the meaning given to it by section 101(54) of the Bankruptcy Code.\n\n## **IV. DOCUMENTS TO BE PRODUCED**\n\n1. All Documents regarding any income or Asset of the Debtor, the Debtor's Family, the Debtor's estate, an Associated Individuals, or an Associated Entity.\n\n2. All Documents related to the Debtor's financial condition and obligations to his creditors, including without limitation all Documents related to any effort to avoid paying such obligations and All Documents related to this or any other actual or potential bankruptcy or similar insolvency proceeding.\n\n3. All Documents regarding any balance sheet, bank statement, account statement, financial statement, statement of account, wire transfer instructions and/or confirmation, proof of funds, certificate of deposit, certificate of holdings, investment portfolio summary, or similar document relating to the Debtor, the Debtor's Estate, the Debtor's Family, an Associated Entity,\n\n## Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 204 of 439\n\nor an Associated Individual, including without limitation all Documents sufficient to show all Transfers to any of the foregoing.\n\n4. All Documents regarding any investment, business dealings or transactions made by, with, or on behalf of the Debtor, the Debtor's Family, an Associated Individual, or an Associated Entity.\n\n5. All Communications with the Debtor, the Debtor's Family, an Associated Individual, or an Associated Entity, and Documents related to Communications with the Debtor, the Debtor's Family, an Associated Individual, or an Associated Entity, including related to the operation, management, or decision-making of any Entity, including without limitation the Associated Entities.\n\n6. All Documents regarding any Transfer, investment, or other transaction or business dealing made to, by, or with the Debtor, the Debtor's Family, an Associated Individual, or an Associated Entity.\n\n7. All Documents regarding any property ever occupied or used by the Debtor, including without limitation the residential property located in Greenwich, Connecticut at 373 Taconic Rd.; the residential property located in Greenwich, Connecticut at 33 Ferncliff Rd.; the residential property located in Wilton, Connecticut at 354 Nod Hill Rd; the apartments or condominiums located in 5 Princes Gate London, United Kingdom SW7 1QJ; and the residential property located in Mahwah, New Jersey at 675 Ramapo Valley Road, Mahwah, New Jersey 07430.\n\n8. All Documents related to any aircraft owned, controlled, or used by the Debtor, including without limitation (i) the aircraft bearing tail number T7-GQM and any other aircraft\n\n## Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 205 of 439\n\nregistered in San Marino, including without limitation copies of all registration documents and flight manifests showing flights taken by such aircraft and the individuals onboard such flights, and (ii) any Cirrus SF50 aircraft.\n\n9. All Documents regarding any gifts, benefits or loans, to, from or on behalf of the Debtor, the Debtor's Estate, the Debtor's Family, or the Associated Entities, including without limitation Documents sufficient to show the amounts of such gifts, benefits, or loans; the purposes for which such gifts, benefits, or loans were used; when the gifts, benefits, or loans were provided; and the terms of any loans, all representations and warranties made in connection with any loans, the interest rate on any loans, and all evidence of payments of any loans.\n\n10. All Documents concerning any trust or similar instrument set up by, on behalf of, or for the benefit of the Debtor, the Debtor's Estate, the Debtor's Family, or an Associated Entity, including without limitation Documents sufficient to show when the trust(s) was created, by whom it was created, for whose benefit it was created, and the corpus of the trust.\n\n11. All Documents related to any obligation, claim, liability, or debt associated with any legal dispute involving the Debtor, including but not limited to those relating to any litigation before any local, state, federal, or international body, whether an administrative body, court, panel, or alternative dispute resolution entity.\n\n12. All Documents and communications with the Debtor, the Debtor's Family, or an Associated Individual.\n\n13. All Documents and communications between any of your counsel or other advisors and the Debtor, the Debtor's Family, or an Associated Individual.\n\n## Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 206 of 439\n\n14. All Documents related to any Associated Entity that You hold or have held an interest in.\n\nCase 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 207 of 439\n\n# Exhibit C-11\n\n#### B2540 (Form 2540 – Subpoena for Rule 2004 Examination) (12/15) Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 208 of\n\n439\n\nUNITED STATES BANKRUPTCY COURT\n\n**District of Connecticut**\n\nIn re HO WAN KWOK, *et al*.,\n\n<sup>1</sup> Case No. 22-50073 (JAM) Debtor Chapter 11\n\n(Jointly Administered)\n\n# **SUBPOENA FOR RULE 2004 EXAMINATION**\n\nTo: **Lukasz Lasota**\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/A   | N/A           |\n|       |               |\n\nThe examination will be recorded by this method: N/A\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\n## **See Requests for Production of Documents, attached hereto.**\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: **May , 2024**\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 Luc A. Despins, Chapter 11 Trustee, who issues or requests this subpoena, are:\n\n**Patrick R. Linsey, Esq.; Neubert, Pepe & Monteith, P.C.; 195 Church Street, 13th Floor, New Haven, Connecticut 06510 plinsey@npmlaw.com; (203) 781-2847**\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\nSoftware Copyright (c) 1996-2022 Best Case, LLC - www.bestcase.com Best Case Bankruptcy 1 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## **PROOF OF SERVICE**\n\n**(This section should not be filed with the court unless required by Fed. R. Civ. P. 45.)**\n\nI received this subpoena for (*name of individual and title, if any*): on (*date*) .\n\nI served the subpoena by delivering a copy to the named person as follows:\n\non *(date)* ; or\n\nI returned the subpoena unexecuted because:\n\nUnless the subpoena was issued on behalf of the United States, or one of its officers or agents, I have also tendered to the witness the fees for one day's attendance, and the mileage allowed by law, in the amount of \\$ .\n\nMy fees are \\$ for travel and \\$ for services, for a total of \\$ .\n\nI declare under penalty of perjury that this information is true and correct.\n\nDate:\n\n*Server's signature*\n\n*Printed name and title*\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;\n\n(ii) requires a person to comply beyond the geographical limits specified 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: (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 trial-preparation 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## **Requests 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\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 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 213 of 439\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 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 214 of 439\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 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 215 of 439\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 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 216 of 439\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).\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\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 Lukasz Lasota, together with all of their agents, attorneys, representatives, employees, and/or anyone acting on their 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\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\n## Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 218 of 439\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, 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. \"Associated Individuals\" means individually and collectively, all individuals that (1) hold, control, have custody over, or discretion over assets owned, controlled, or enjoyed by the Debtor or the Debtor's Family; or (2) have been employees, directors, or otherwise are affiliated with one or more Associated Entities, together with the respective employees, agents, counsel, advisors, or anyone acting on behalf of any of the foregoing. Such Associated Individuals shall include, but are not limited to: Anthony DiBattista, Alex Hadjicharalambous, Bernardo Enriquez, Bingshang Jiao, Beile Li, Brian W. Hofmeister, Charles Gruder, Daniel Podhaskie, David Fallon, Defeng Cao (a/k/a Wayne Cao, Max Cao), Ding Lin, Dinggang Wang (a/k/a 王定刚), Eduardo Eurnekian, Ehsan Masud, Fiona Yu, Gladys Chow, Hao (Gavin) Li (a/k/a Huo Lai), Hao Haidong (a/k/a 郝海东), Han Chunguang (a/k/a 韩春光), Haoran He, Ivan Lin, Haitham Khaled, Jason Miller, Jennifer Mercurio, Jesse Brown, Jessica Mastrogiovanni, Jie Zhang, Jintao Li, Karin Maistrello, Kyle Bass, Lihong Wei Lafrenz (a/k/a Sara Wei, 魏丽红), Linwan \"Irene\" Feng, Max Krasner, Melissa Francis, Michael Baranowitz, Min Yang, Melissa Mendez, Nadeem Akbar, Nan Li (a/k/a Chris Lee, Mei Guo Xiao Li), Qidong Xia, Qu Guojiao (a/k/a Qu Guo Jiao, 屈国姣), Ridwan Mamode Saib, Ross Heinemeyer, Rui \"Ray\" Hao, Scott Barnett, Shih Hsin Yu, Shin Hee-Seup (a/k/a Hee Seup Shin), Steve Bannon, Talha Zobair, Victor Cerda, Wen Xiao, Wencong Wang, William Gertz, William Je (a/k/a Je Kin Ming, Yu Jianming, 余建明), and Xuebing Wang,\n\n## Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 219 of 439\n\nYa Li (a/k/a 李娅), Yinying (Aila) Wang (a/k/a Xiao Fei Xiang), Yongping Yan (Shan Mu), Yong Yu, Yue Zhou, Yumei Hao (a/k/a Ru Shui), Yvette Wang (a/k/a Yanping Wang, Yan Ping Wang, 王雁平), Zhang Wei (a/k/a 张魏), Zhouer Wang (a/k/a Joe Wang), Zhixuan Li, and Ziyang Liu.\n\n8. \"Associated Entities\" means, individually and collectively, all organizations or Entities of any type that (1) have been owned, controlled, or invested in by the Debtor or the Debtor's Family; or (2) have an interest, whether directly or indirectly, in any assets owned, controlled, or enjoyed by the Debtor or the Debtor's Family, together with the respective employees, agents, counsel, advisors, or anyone acting on behalf of any of the foregoing. Such Associated Entities shall include, but are not limited to: 1332156 B.C. Ltd., 7 Nod Hill LLC, AAGV Limited, ACA Investment Management Limited, ACA Capital Group Limited, Ace Decade Holdings Limited, AI Group Holdings Inc., Alfa Global Ventures Limited, Alfonso Global Limited, Allied Capital Global Limited, Alpine Fiduciaries SA, Beijing Pangu Investment Co., Beijing Pangu Investment Co. Ltd., Beijing Pangu Investment Inc., Beijing Zenith Holdings Company Limited, Blue Capital Limited, Booming Sail New York LLC, Bravo Luck Limited, Brent Petro, BSA Strategic Fund I, China Golden Spring (Hong Kong) Limited, Chuang Xin Limited, Crane Advisory Group LLC, Creative Apex Investments Limited, Crystal Breeze Investments Limited, Dawn State Limited, Eastern Profit Corporation Limited, Empire Growth Holdings, Elite Well Global Limited, Freedom Media Ventures Ltd., Fung Wan Trading Inc., G Club, G Club Operations LLC, G Club International Limited, G Club Investments Limited, G Fashion LLC, G-News Operations LLC, G News LLC, GMusic Inc., G-Services LLC, G-Translators PTY LTD, GETTR USA, Inc., Genever Holdings Corporation, Genever Holdings LLC, GFashion Media Group Inc., GFNY, Inc., Globalist International Limited, GNews Media Group Inc., Golden Spring (New York) Ltd., Guo Media, GTV Media Group, Inc., GWGOPNZ\n\n## Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 220 of 439\n\nLimited, GWGNZ Limited, Gypsy Mei Food Services, LLC, HCHK Property Management Inc., HCHK Technologies Inc., Hamilton Digital Assets FD SP, Hamilton Capital Holdings Inc., Hamilton Opportunity Fund SPC, Head Win Group Limited, Himalaya Embassy, Himalaya Exchange, Himalaya Federal Reserve, Himalaya International Financial Group Ltd., Himalaya Investment LLC, Himalaya (USA) Investment Management LLC, Himalaya New World Inc., Himalaya Supervisory Organization, Himalaya Ventures, Holy City Hong Kong Ventures, Ltd., Hudson Diamond Holding LLC, Hudson Diamond Holding Inc., Hudson Diamond NY LLC, HK International Funds Investments (USA) Limited LLC, Hong Kong International Funds Investments Limited, Huk Trading Inc, Infinite Increase Limited, Infinitum Developments Limited, Japan Himalaya League, Inc., Kalixun Trading Limited, Lamp Capital LLC, Leading Shine Limited, Leading Shine NY Limited, Lexington Property and Staffing Inc., Long Gate Limited, MOS Himalaya Foundation Inc., Maywind Trading LLC, New Federal State of China (a/k/a NFSC), New York MOS Himalaya LLC, New Mulberry PTE Ltd., Newpeople LLC, Noble Fame Global Limited, Pixshow Film Inc., Roscalitar 2, Rosy Acme Ventures Limited, Rule of Law Foundation III, Inc., Rule of Law Society, Rule of Law Society IV, Inc., Santel LLC, Saraca Media Group, Inc., Shiny Ace Ltd., Shiny Times Holdings Ltd., Stevenson, Wong & Co., Taurus Fund LLC, Taurus Fund SP, Taurus Management LLC, The Lost Draft LLC, TM Primrose Limited, UA Himalaya Inc., Voice of Guo Media, Inc., Well Origin Ltd., Wise Creation, Whitecroft Shore Limited, World Century Limited, Worldwide Opportunity Holdings Limited, and ZIBA Limited.\n\n9. \"Including\" or any variant thereof means \"including without limitation.\"\n\n10. \"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 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 221 of 439\n\n11. \"Any\" and \"all\" and \"each\" mean \"each and every.\"\n\n12. \"Each\" and \"every\" mean \"each and every.\"\n\n13. \"Third Party\" means a Person or Entity other than Yourself.\n\n14. \"Transfer\" shall have the meaning given to it by section 101(54) of the Bankruptcy Code.\n\n15. \"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, electronic communication, text message, social media post, tweet, meta-data, 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, 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, punchcards, 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 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 222 of 439\n\n16. \"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\n17. \"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 legal counsel, financial advisors, or any other representative.\n\n18. \"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\n19. \"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\n20. \"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,\n\n## Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 223 of 439\n\ntelexes, instant messages, chats, text messages, telephonic notes, or notes transmitted internally or with third parties.\n\n21. \"Asset(s)\" means any item that can be used to produce positive economic value, including but not limited to any resource with economic value that is owned, controlled or is for the benefit of an entity, that is expected to provide a future benefit, including but not limited to, all real and personal property, intangible property, investments, rights to invest or to future revenue, cash, bank accounts, commodities, securities, claims, total or partial control of an entity, and prospective economic opportunities\n\n22. \"Transfer\" shall have the meaning given to it by section 101(54) of the Bankruptcy Code.\n\n## **IV. DOCUMENTS TO BE PRODUCED**\n\n1. All Documents regarding any income or Asset of the Debtor, the Debtor's Family, the Debtor's estate, an Associated Individuals, or an Associated Entity.\n\n2. All Documents related to the Debtor's financial condition and obligations to his creditors, including without limitation all Documents related to any effort to avoid paying such obligations and All Documents related to this or any other actual or potential bankruptcy or similar insolvency proceeding.\n\n3. All Documents regarding any balance sheet, bank statement, account statement, financial statement, statement of account, wire transfer instructions and/or confirmation, proof of funds, certificate of deposit, certificate of holdings, investment portfolio summary, or similar document relating to the Debtor, the Debtor's Estate, the Debtor's Family, an Associated Entity, or an Associated Individual, including without limitation all Documents sufficient to show all Transfers to any of the foregoing.\n\n## Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 224 of 439\n\n4. All Documents regarding any investment, business dealings or transactions made by, with, or on behalf of the Debtor, the Debtor's Family, an Associated Individual, or an Associated Entity.\n\n5. All Communications with the Debtor, the Debtor's Family, an Associated Individual, or an Associated Entity, and Documents related to Communications with the Debtor, the Debtor's Family, an Associated Individual, or an Associated Entity, including related to the operation, management, or decision-making of any Entity, including without limitation the Associated Entities.\n\n6. All Documents regarding any Transfer, investment, or other transaction or business dealing made to, by, or with the Debtor, the Debtor's Family, an Associated Individual, or an Associated Entity.\n\n7. All Documents regarding any property ever occupied or used by the Debtor, including without limitation the residential property located in Greenwich, Connecticut at 373 Taconic Rd.; the residential property located in Greenwich, Connecticut at 33 Ferncliff Rd.; the residential property located in Wilton, Connecticut at 354 Nod Hill Rd; the apartments or condominiums located in 5 Princes Gate London, United Kingdom SW7 1QJ; and the residential property located in Mahwah, New Jersey at 675 Ramapo Valley Road, Mahwah, New Jersey 07430.\n\n8. All Documents related to any aircraft owned, controlled, or used by the Debtor, including without limitation (i) the aircraft bearing tail number T7-GQM and any other aircraft registered in San Marino, including without limitation copies of all registration documents and flight manifests showing flights taken by such aircraft and the individuals onboard such flights, and (ii) any Cirrus SF50 aircraft.\n\n## Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 225 of 439\n\n9. All Documents regarding any gifts, benefits or loans, to, from or on behalf of the Debtor, the Debtor's Estate, the Debtor's Family, or the Associated Entities, including without limitation Documents sufficient to show the amounts of such gifts, benefits, or loans; the purposes for which such gifts, benefits, or loans were used; when the gifts, benefits, or loans were provided; and the terms of any loans, all representations and warranties made in connection with any loans, the interest rate on any loans, and all evidence of payments of any loans.\n\n10. All Documents concerning any trust or similar instrument set up by, on behalf of, or for the benefit of the Debtor, the Debtor's Estate, the Debtor's Family, or an Associated Entity, including without limitation Documents sufficient to show when the trust(s) was created, by whom it was created, for whose benefit it was created, and the corpus of the trust.\n\n11. All Documents related to any obligation, claim, liability, or debt associated with any legal dispute involving the Debtor, including but not limited to those relating to any litigation before any local, state, federal, or international body, whether an administrative body, court, panel, or alternative dispute resolution entity.\n\n12. All Documents and communications with the Debtor, the Debtor's Family, or an Associated Individual.\n\n13. All Documents and communications between any of your counsel or other advisors and the Debtor, the Debtor's Family, or an Associated Individual.\n\n14. All Documents related to any Associated Entity that You hold or have held an interest in.\n\n# Exhibit C-12\n\n#### B2540 (Form 2540 – Subpoena for Rule 2004 Examination) (12/15) Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 227 of\n\n439\n\nUNITED STATES BANKRUPTCY COURT\n\n**District of Connecticut**\n\nIn re HO WAN KWOK, *et al*.,\n\n<sup>1</sup> Case No. 22-50073 (JAM) Debtor Chapter 11\n\n(Jointly Administered)\n\n# **SUBPOENA FOR RULE 2004 EXAMINATION**\n\nTo: **Thomas McHale**\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/A   | N/A           |\n|       |               |\n\nThe examination will be recorded by this method: N/A\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\n## **See Requests for Production of Documents, attached hereto.**\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: **May , 2024**\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 Luc A. Despins, Chapter 11 Trustee, who issues or requests this subpoena, are:\n\n**Patrick R. Linsey, Esq.; Neubert, Pepe & Monteith, P.C.; 195 Church Street, 13th Floor, New Haven, Connecticut 06510 plinsey@npmlaw.com; (203) 781-2847**\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\nSoftware Copyright (c) 1996-2022 Best Case, LLC - www.bestcase.com Best Case Bankruptcy 1 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## **PROOF OF SERVICE**\n\n**(This section should not be filed with the court unless required by Fed. R. Civ. P. 45.)**\n\nI received this subpoena for (*name of individual and title, if any*): on (*date*) .\n\nI served the subpoena by delivering a copy to the named person as follows:\n\non *(date)* ; or\n\nI returned the subpoena unexecuted because:\n\nUnless the subpoena was issued on behalf of the United States, or one of its officers or agents, I have also tendered to the witness the fees for one day's attendance, and the mileage allowed by law, in the amount of \\$ .\n\nMy fees are \\$ for travel and \\$ for services, for a total of \\$ .\n\nI declare under penalty of perjury that this information is true and correct.\n\nDate:\n\n*Server's signature*\n\n*Printed name and title*\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;\n\n(ii) requires a person to comply beyond the geographical limits specified 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: (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 trial-preparation 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## **Requests 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\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| 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 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 233 of 439\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 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 234 of 439\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 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 235 of 439\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).\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\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 Thomas McHale, together with all of their agents, attorneys, representatives, employees, and/or anyone acting on their 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\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\n## Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 237 of 439\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, 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. \"Associated Individuals\" means individually and collectively, all individuals that (1) hold, control, have custody over, or discretion over assets owned, controlled, or enjoyed by the Debtor or the Debtor's Family; or (2) have been employees, directors, or otherwise are affiliated with one or more Associated Entities, together with the respective employees, agents, counsel, advisors, or anyone acting on behalf of any of the foregoing. Such Associated Individuals shall include, but are not limited to: Anthony DiBattista, Alex Hadjicharalambous, Bernardo Enriquez, Bingshang Jiao, Beile Li, Brian W. Hofmeister, Charles Gruder, Daniel Podhaskie, David Fallon, Defeng Cao (a/k/a Wayne Cao, Max Cao), Ding Lin, Dinggang Wang (a/k/a 王定刚), Eduardo Eurnekian, Ehsan Masud, Fiona Yu, Gladys Chow, Hao (Gavin) Li (a/k/a Huo Lai), Hao Haidong (a/k/a 郝海东), Han Chunguang (a/k/a 韩春光), Haoran He, Ivan Lin, Haitham Khaled, Jason Miller, Jennifer Mercurio, Jesse Brown, Jessica Mastrogiovanni, Jie Zhang, Jintao Li, Karin Maistrello, Kyle Bass, Lihong Wei Lafrenz (a/k/a Sara Wei, 魏丽红), Linwan \"Irene\" Feng, Max Krasner, Melissa Francis, Michael Baranowitz, Min Yang, Melissa Mendez, Nadeem Akbar, Nan Li (a/k/a Chris Lee, Mei Guo Xiao Li), Qidong Xia, Qu Guojiao (a/k/a Qu Guo Jiao, 屈国姣), Ridwan Mamode Saib, Ross Heinemeyer, Rui \"Ray\" Hao, Scott Barnett, Shih Hsin Yu, Shin Hee-\n\n## Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 238 of 439\n\nSeup (a/k/a Hee Seup Shin), Steve Bannon, Talha Zobair, Victor Cerda, Wen Xiao, Wencong Wang, William Gertz, William Je (a/k/a Je Kin Ming, Yu Jianming, 余建明), and Xuebing Wang, Ya Li (a/k/a 李娅), Yinying (Aila) Wang (a/k/a Xiao Fei Xiang), Yongping Yan (Shan Mu), Yong Yu, Yue Zhou, Yumei Hao (a/k/a Ru Shui), Yvette Wang (a/k/a Yanping Wang, Yan Ping Wang, 王雁平), Zhang Wei (a/k/a 张魏), Zhouer Wang (a/k/a Joe Wang), Zhixuan Li, and Ziyang Liu.\n\n8. \"Associated Entities\" means, individually and collectively, all organizations or Entities of any type that (1) have been owned, controlled, or invested in by the Debtor or the Debtor's Family; or (2) have an interest, whether directly or indirectly, in any assets owned, controlled, or enjoyed by the Debtor or the Debtor's Family, together with the respective employees, agents, counsel, advisors, or anyone acting on behalf of any of the foregoing. Such Associated Entities shall include, but are not limited to: 1332156 B.C. Ltd., 7 Nod Hill LLC, AAGV Limited, ACA Investment Management Limited, ACA Capital Group Limited, Ace Decade Holdings Limited, AI Group Holdings Inc., Alfa Global Ventures Limited, Alfonso Global Limited, Allied Capital Global Limited, Alpine Fiduciaries SA, Beijing Pangu Investment Co., Beijing Pangu Investment Co. Ltd., Beijing Pangu Investment Inc., Beijing Zenith Holdings Company Limited, Blue Capital Limited, Booming Sail New York LLC, Bravo Luck Limited, Brent Petro, BSA Strategic Fund I, China Golden Spring (Hong Kong) Limited, Chuang Xin Limited, Crane Advisory Group LLC, Creative Apex Investments Limited, Crystal Breeze Investments Limited, Dawn State Limited, Eastern Profit Corporation Limited, Empire Growth Holdings, Elite Well Global Limited, Freedom Media Ventures Ltd., Fung Wan Trading Inc., G Club, G Club Operations LLC, G Club International Limited, G Club Investments Limited, G Fashion LLC, G-News Operations LLC, G News LLC, GMusic Inc., G-Services LLC, G-Translators PTY LTD, GETTR USA, Inc., Genever Holdings Corporation, Genever Holdings\n\n## Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 239 of 439\n\nLLC, GFashion Media Group Inc., GFNY, Inc., Globalist International Limited, GNews Media Group Inc., Golden Spring (New York) Ltd., Guo Media, GTV Media Group, Inc., GWGOPNZ Limited, GWGNZ Limited, Gypsy Mei Food Services, LLC, HCHK Property Management Inc., HCHK Technologies Inc., Hamilton Digital Assets FD SP, Hamilton Capital Holdings Inc., Hamilton Opportunity Fund SPC, Head Win Group Limited, Himalaya Embassy, Himalaya Exchange, Himalaya Federal Reserve, Himalaya International Financial Group Ltd., Himalaya Investment LLC, Himalaya (USA) Investment Management LLC, Himalaya New World Inc., Himalaya Supervisory Organization, Himalaya Ventures, Holy City Hong Kong Ventures, Ltd., Hudson Diamond Holding LLC, Hudson Diamond Holding Inc., Hudson Diamond NY LLC, HK International Funds Investments (USA) Limited LLC, Hong Kong International Funds Investments Limited, Huk Trading Inc, Infinite Increase Limited, Infinitum Developments Limited, Japan Himalaya League, Inc., Kalixun Trading Limited, Lamp Capital LLC, Leading Shine Limited, Leading Shine NY Limited, Lexington Property and Staffing Inc., Long Gate Limited, MOS Himalaya Foundation Inc., Maywind Trading LLC, New Federal State of China (a/k/a NFSC), New York MOS Himalaya LLC, New Mulberry PTE Ltd., Newpeople LLC, Noble Fame Global Limited, Pixshow Film Inc., Roscalitar 2, Rosy Acme Ventures Limited, Rule of Law Foundation III, Inc., Rule of Law Society, Rule of Law Society IV, Inc., Santel LLC, Saraca Media Group, Inc., Shiny Ace Ltd., Shiny Times Holdings Ltd., Stevenson, Wong & Co., Taurus Fund LLC, Taurus Fund SP, Taurus Management LLC, The Lost Draft LLC, TM Primrose Limited, UA Himalaya Inc., Voice of Guo Media, Inc., Well Origin Ltd., Wise Creation, Whitecroft Shore Limited, World Century Limited, Worldwide Opportunity Holdings Limited, and ZIBA Limited.\n\n9. \"Including\" or any variant thereof means \"including without limitation.\"\n\n## Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 240 of 439\n\n10. \"And\" and \"or\" mean \"and/or,\" and shall be construed both conjunctively as well as disjunctively in order to maximize their scope.\n\n11. \"Any\" and \"all\" and \"each\" mean \"each and every.\"\n\n12. \"Each\" and \"every\" mean \"each and every.\"\n\n13. \"Third Party\" means a Person or Entity other than Yourself.\n\n14. \"Transfer\" shall have the meaning given to it by section 101(54) of the Bankruptcy Code.\n\n15. \"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, electronic communication, text message, social media post, tweet, meta-data, 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, 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, punchcards, 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\n\n## Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 241 of 439\n\nof 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\n16. \"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\n17. \"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 legal counsel, financial advisors, or any other representative.\n\n18. \"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\n19. \"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\n20. \"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\n\n## Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 242 of 439\n\nslips, memoranda, telephone communications, voice messages, telegrams, telefaxes, telecopies, telexes, instant messages, chats, text messages, telephonic notes, or notes transmitted internally or with third parties.\n\n21. \"Asset(s)\" means any item that can be used to produce positive economic value, including but not limited to any resource with economic value that is owned, controlled or is for the benefit of an entity, that is expected to provide a future benefit, including but not limited to, all real and personal property, intangible property, investments, rights to invest or to future revenue, cash, bank accounts, commodities, securities, claims, total or partial control of an entity, and prospective economic opportunities\n\n22. \"Transfer\" shall have the meaning given to it by section 101(54) of the Bankruptcy Code.\n\n## **IV. DOCUMENTS TO BE PRODUCED**\n\n1. All Documents regarding any income or Asset of the Debtor, the Debtor's Family, the Debtor's estate, an Associated Individuals, or an Associated Entity.\n\n2. All Documents related to the Debtor's financial condition and obligations to his creditors, including without limitation all Documents related to any effort to avoid paying such obligations and All Documents related to this or any other actual or potential bankruptcy or similar insolvency proceeding.\n\n3. All Documents regarding any balance sheet, bank statement, account statement, financial statement, statement of account, wire transfer instructions and/or confirmation, proof of funds, certificate of deposit, certificate of holdings, investment portfolio summary, or similar document relating to the Debtor, the Debtor's Estate, the Debtor's Family, an Associated Entity,\n\n## Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 243 of 439\n\nor an Associated Individual, including without limitation all Documents sufficient to show all Transfers to any of the foregoing.\n\n4. All Documents regarding any investment, business dealings or transactions made by, with, or on behalf of the Debtor, the Debtor's Family, an Associated Individual, or an Associated Entity.\n\n5. All Communications with the Debtor, the Debtor's Family, an Associated Individual, or an Associated Entity, and Documents related to Communications with the Debtor, the Debtor's Family, an Associated Individual, or an Associated Entity, including related to the operation, management, or decision-making of any Entity, including without limitation the Associated Entities.\n\n6. All Documents regarding any Transfer, investment, or other transaction or business dealing made to, by, or with the Debtor, the Debtor's Family, an Associated Individual, or an Associated Entity.\n\n7. All Documents regarding any property ever occupied or used by the Debtor, including without limitation the residential property located in Greenwich, Connecticut at 373 Taconic Rd.; the residential property located in Greenwich, Connecticut at 33 Ferncliff Rd.; the residential property located in Wilton, Connecticut at 354 Nod Hill Rd; the apartments or condominiums located in 5 Princes Gate London, United Kingdom SW7 1QJ; and the residential property located in Mahwah, New Jersey at 675 Ramapo Valley Road, Mahwah, New Jersey 07430.\n\n8. All Documents related to any aircraft owned, controlled, or used by the Debtor, including without limitation (i) the aircraft bearing tail number T7-GQM and any other aircraft\n\n## Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 244 of 439\n\nregistered in San Marino, including without limitation copies of all registration documents and flight manifests showing flights taken by such aircraft and the individuals onboard such flights, and (ii) any Cirrus SF50 aircraft.\n\n9. All Documents regarding any gifts, benefits or loans, to, from or on behalf of the Debtor, the Debtor's Estate, the Debtor's Family, or the Associated Entities, including without limitation Documents sufficient to show the amounts of such gifts, benefits, or loans; the purposes for which such gifts, benefits, or loans were used; when the gifts, benefits, or loans were provided; and the terms of any loans, all representations and warranties made in connection with any loans, the interest rate on any loans, and all evidence of payments of any loans.\n\n10. All Documents concerning any trust or similar instrument set up by, on behalf of, or for the benefit of the Debtor, the Debtor's Estate, the Debtor's Family, or an Associated Entity, including without limitation Documents sufficient to show when the trust(s) was created, by whom it was created, for whose benefit it was created, and the corpus of the trust.\n\n11. All Documents related to any obligation, claim, liability, or debt associated with any legal dispute involving the Debtor, including but not limited to those relating to any litigation before any local, state, federal, or international body, whether an administrative body, court, panel, or alternative dispute resolution entity.\n\n12. All Documents and communications with the Debtor, the Debtor's Family, or an Associated Individual.\n\n13. All Documents and communications between any of your counsel or other advisors and the Debtor, the Debtor's Family, or an Associated Individual.\n\n## Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 245 of 439\n\n14. All Documents related to any Associated Entity that You hold or have held an interest in.\n\n# Exhibit C-13\n\n#### B2540 (Form 2540 – Subpoena for Rule 2004 Examination) (12/15) Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 247 of\n\n439\n\nUNITED STATES BANKRUPTCY COURT\n\n**District of Connecticut**\n\nIn re HO WAN KWOK, *et al*.,\n\n<sup>1</sup> Case No. 22-50073 (JAM) Debtor Chapter 11\n\n(Jointly Administered)\n\n# **SUBPOENA FOR RULE 2004 EXAMINATION**\n\nTo: **Sean Lynch**\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/A   | N/A           |\n|       |               |\n\nThe examination will be recorded by this method: N/A\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\n## **See Requests for Production of Documents, attached hereto.**\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: **May , 2024**\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 Luc A. Despins, Chapter 11 Trustee, who issues or requests this subpoena, are:\n\n**Patrick R. Linsey, Esq.; Neubert, Pepe & Monteith, P.C.; 195 Church Street, 13th Floor, New Haven, Connecticut 06510 plinsey@npmlaw.com; (203) 781-2847**\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\nSoftware Copyright (c) 1996-2022 Best Case, LLC - www.bestcase.com Best Case Bankruptcy 1 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## **PROOF OF SERVICE**\n\n**(This section should not be filed with the court unless required by Fed. R. Civ. P. 45.)**\n\nI received this subpoena for (*name of individual and title, if any*): on (*date*) .\n\nI served the subpoena by delivering a copy to the named person as follows:\n\non *(date)* ; or\n\nI returned the subpoena unexecuted because:\n\nUnless the subpoena was issued on behalf of the United States, or one of its officers or agents, I have also tendered to the witness the fees for one day's attendance, and the mileage allowed by law, in the amount of \\$ .\n\nMy fees are \\$ for travel and \\$ for services, for a total of \\$ .\n\nI declare under penalty of perjury that this information is true and correct.\n\nDate:\n\n*Server's signature*\n\n*Printed name and title*\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;\n\n(ii) requires a person to comply beyond the geographical limits specified 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: (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 trial-preparation 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## **Requests 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\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 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 252 of 439\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 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 253 of 439\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 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 254 of 439\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 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 255 of 439\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).\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\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 Sean Lynch, together with all of their agents, attorneys, representatives, employees, and/or anyone acting on their 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\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\n## Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 257 of 439\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, 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. \"Associated Individuals\" means individually and collectively, all individuals that (1) hold, control, have custody over, or discretion over assets owned, controlled, or enjoyed by the Debtor or the Debtor's Family; or (2) have been employees, directors, or otherwise are affiliated with one or more Associated Entities, together with the respective employees, agents, counsel, advisors, or anyone acting on behalf of any of the foregoing. Such Associated Individuals shall include, but are not limited to: Anthony DiBattista, Alex Hadjicharalambous, Bernardo Enriquez, Bingshang Jiao, Beile Li, Brian W. Hofmeister, Charles Gruder, Daniel Podhaskie, David Fallon, Defeng Cao (a/k/a Wayne Cao, Max Cao), Ding Lin, Dinggang Wang (a/k/a 王定刚), Eduardo Eurnekian, Ehsan Masud, Fiona Yu, Gladys Chow, Hao (Gavin) Li (a/k/a Huo Lai), Hao Haidong (a/k/a 郝海东), Han Chunguang (a/k/a 韩春光), Haoran He, Ivan Lin, Haitham Khaled, Jason Miller, Jennifer Mercurio, Jesse Brown, Jessica Mastrogiovanni, Jie Zhang, Jintao Li, Karin Maistrello, Kyle Bass, Lihong Wei Lafrenz (a/k/a Sara Wei, 魏丽红), Linwan \"Irene\" Feng, Max Krasner, Melissa Francis, Michael Baranowitz, Min Yang, Melissa Mendez, Nadeem Akbar, Nan Li (a/k/a Chris Lee, Mei Guo Xiao Li), Qidong Xia, Qu Guojiao (a/k/a Qu Guo Jiao, 屈国姣), Ridwan Mamode Saib, Ross Heinemeyer, Rui \"Ray\" Hao, Scott Barnett, Shih Hsin Yu, Shin Hee-Seup (a/k/a Hee Seup Shin), Steve Bannon, Talha Zobair, Victor Cerda, Wen Xiao, Wencong Wang, William Gertz, William Je (a/k/a Je Kin Ming, Yu Jianming, 余建明), and Xuebing Wang,\n\n## Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 258 of 439\n\nYa Li (a/k/a 李娅), Yinying (Aila) Wang (a/k/a Xiao Fei Xiang), Yongping Yan (Shan Mu), Yong Yu, Yue Zhou, Yumei Hao (a/k/a Ru Shui), Yvette Wang (a/k/a Yanping Wang, Yan Ping Wang, 王雁平), Zhang Wei (a/k/a 张魏), Zhouer Wang (a/k/a Joe Wang), Zhixuan Li, and Ziyang Liu.\n\n8. \"Associated Entities\" means, individually and collectively, all organizations or Entities of any type that (1) have been owned, controlled, or invested in by the Debtor or the Debtor's Family; or (2) have an interest, whether directly or indirectly, in any assets owned, controlled, or enjoyed by the Debtor or the Debtor's Family, together with the respective employees, agents, counsel, advisors, or anyone acting on behalf of any of the foregoing. Such Associated Entities shall include, but are not limited to: 1332156 B.C. Ltd., 7 Nod Hill LLC, AAGV Limited, ACA Investment Management Limited, ACA Capital Group Limited, Ace Decade Holdings Limited, AI Group Holdings Inc., Alfa Global Ventures Limited, Alfonso Global Limited, Allied Capital Global Limited, Alpine Fiduciaries SA, Beijing Pangu Investment Co., Beijing Pangu Investment Co. Ltd., Beijing Pangu Investment Inc., Beijing Zenith Holdings Company Limited, Blue Capital Limited, Booming Sail New York LLC, Bravo Luck Limited, Brent Petro, BSA Strategic Fund I, China Golden Spring (Hong Kong) Limited, Chuang Xin Limited, Crane Advisory Group LLC, Creative Apex Investments Limited, Crystal Breeze Investments Limited, Dawn State Limited, Eastern Profit Corporation Limited, Empire Growth Holdings, Elite Well Global Limited, Freedom Media Ventures Ltd., Fung Wan Trading Inc., G Club, G Club Operations LLC, G Club International Limited, G Club Investments Limited, G Fashion LLC, G-News Operations LLC, G News LLC, GMusic Inc., G-Services LLC, G-Translators PTY LTD, GETTR USA, Inc., Genever Holdings Corporation, Genever Holdings LLC, GFashion Media Group Inc., GFNY, Inc., Globalist International Limited, GNews Media Group Inc., Golden Spring (New York) Ltd., Guo Media, GTV Media Group, Inc., GWGOPNZ\n\n## Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 259 of 439\n\nLimited, GWGNZ Limited, Gypsy Mei Food Services, LLC, HCHK Property Management Inc., HCHK Technologies Inc., Hamilton Digital Assets FD SP, Hamilton Capital Holdings Inc., Hamilton Opportunity Fund SPC, Head Win Group Limited, Himalaya Embassy, Himalaya Exchange, Himalaya Federal Reserve, Himalaya International Financial Group Ltd., Himalaya Investment LLC, Himalaya (USA) Investment Management LLC, Himalaya New World Inc., Himalaya Supervisory Organization, Himalaya Ventures, Holy City Hong Kong Ventures, Ltd., Hudson Diamond Holding LLC, Hudson Diamond Holding Inc., Hudson Diamond NY LLC, HK International Funds Investments (USA) Limited LLC, Hong Kong International Funds Investments Limited, Huk Trading Inc, Infinite Increase Limited, Infinitum Developments Limited, Japan Himalaya League, Inc., Kalixun Trading Limited, Lamp Capital LLC, Leading Shine Limited, Leading Shine NY Limited, Lexington Property and Staffing Inc., Long Gate Limited, MOS Himalaya Foundation Inc., Maywind Trading LLC, New Federal State of China (a/k/a NFSC), New York MOS Himalaya LLC, New Mulberry PTE Ltd., Newpeople LLC, Noble Fame Global Limited, Pixshow Film Inc., Roscalitar 2, Rosy Acme Ventures Limited, Rule of Law Foundation III, Inc., Rule of Law Society, Rule of Law Society IV, Inc., Santel LLC, Saraca Media Group, Inc., Shiny Ace Ltd., Shiny Times Holdings Ltd., Stevenson, Wong & Co., Taurus Fund LLC, Taurus Fund SP, Taurus Management LLC, The Lost Draft LLC, TM Primrose Limited, UA Himalaya Inc., Voice of Guo Media, Inc., Well Origin Ltd., Wise Creation, Whitecroft Shore Limited, World Century Limited, Worldwide Opportunity Holdings Limited, and ZIBA Limited.\n\n9. \"Including\" or any variant thereof means \"including without limitation.\"\n\n10. \"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 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 260 of 439\n\n11. \"Any\" and \"all\" and \"each\" mean \"each and every.\"\n\n12. \"Each\" and \"every\" mean \"each and every.\"\n\n13. \"Third Party\" means a Person or Entity other than Yourself.\n\n14. \"Transfer\" shall have the meaning given to it by section 101(54) of the Bankruptcy Code.\n\n15. \"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, electronic communication, text message, social media post, tweet, meta-data, 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, 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, punchcards, 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 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 261 of 439\n\n16. \"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\n17. \"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 legal counsel, financial advisors, or any other representative.\n\n18. \"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\n19. \"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\n20. \"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,\n\n## Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 262 of 439\n\ntelexes, instant messages, chats, text messages, telephonic notes, or notes transmitted internally or with third parties.\n\n21. \"Asset(s)\" means any item that can be used to produce positive economic value, including but not limited to any resource with economic value that is owned, controlled or is for the benefit of an entity, that is expected to provide a future benefit, including but not limited to, all real and personal property, intangible property, investments, rights to invest or to future revenue, cash, bank accounts, commodities, securities, claims, total or partial control of an entity, and prospective economic opportunities\n\n22. \"Transfer\" shall have the meaning given to it by section 101(54) of the Bankruptcy Code.\n\n## **IV. DOCUMENTS TO BE PRODUCED**\n\n1. All Documents regarding any income or Asset of the Debtor, the Debtor's Family, the Debtor's estate, an Associated Individuals, or an Associated Entity.\n\n2. All Documents related to the Debtor's financial condition and obligations to his creditors, including without limitation all Documents related to any effort to avoid paying such obligations and All Documents related to this or any other actual or potential bankruptcy or similar insolvency proceeding.\n\n3. All Documents regarding any balance sheet, bank statement, account statement, financial statement, statement of account, wire transfer instructions and/or confirmation, proof of funds, certificate of deposit, certificate of holdings, investment portfolio summary, or similar document relating to the Debtor, the Debtor's Estate, the Debtor's Family, an Associated Entity, or an Associated Individual, including without limitation all Documents sufficient to show all Transfers to any of the foregoing.\n\n## Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 263 of 439\n\n4. All Documents regarding any investment, business dealings or transactions made by, with, or on behalf of the Debtor, the Debtor's Family, an Associated Individual, or an Associated Entity.\n\n5. All Communications with the Debtor, the Debtor's Family, an Associated Individual, or an Associated Entity, and Documents related to Communications with the Debtor, the Debtor's Family, an Associated Individual, or an Associated Entity, including related to the operation, management, or decision-making of any Entity, including without limitation the Associated Entities.\n\n6. All Documents regarding any Transfer, investment, or other transaction or business dealing made to, by, or with the Debtor, the Debtor's Family, an Associated Individual, or an Associated Entity.\n\n7. All Documents regarding any property ever occupied or used by the Debtor, including without limitation the residential property located in Greenwich, Connecticut at 373 Taconic Rd.; the residential property located in Greenwich, Connecticut at 33 Ferncliff Rd.; the residential property located in Wilton, Connecticut at 354 Nod Hill Rd; the apartments or condominiums located in 5 Princes Gate London, United Kingdom SW7 1QJ; and the residential property located in Mahwah, New Jersey at 675 Ramapo Valley Road, Mahwah, New Jersey 07430.\n\n8. All Documents related to any aircraft owned, controlled, or used by the Debtor, including without limitation (i) the aircraft bearing tail number T7-GQM and any other aircraft registered in San Marino, including without limitation copies of all registration documents and flight manifests showing flights taken by such aircraft and the individuals onboard such flights, and (ii) any Cirrus SF50 aircraft.\n\n## Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 264 of 439\n\n9. All Documents regarding any gifts, benefits or loans, to, from or on behalf of the Debtor, the Debtor's Estate, the Debtor's Family, or the Associated Entities, including without limitation Documents sufficient to show the amounts of such gifts, benefits, or loans; the purposes for which such gifts, benefits, or loans were used; when the gifts, benefits, or loans were provided; and the terms of any loans, all representations and warranties made in connection with any loans, the interest rate on any loans, and all evidence of payments of any loans.\n\n10. All Documents concerning any trust or similar instrument set up by, on behalf of, or for the benefit of the Debtor, the Debtor's Estate, the Debtor's Family, or an Associated Entity, including without limitation Documents sufficient to show when the trust(s) was created, by whom it was created, for whose benefit it was created, and the corpus of the trust.\n\n11. All Documents related to any obligation, claim, liability, or debt associated with any legal dispute involving the Debtor, including but not limited to those relating to any litigation before any local, state, federal, or international body, whether an administrative body, court, panel, or alternative dispute resolution entity.\n\n12. All Documents and communications with the Debtor, the Debtor's Family, or an Associated Individual.\n\n13. All Documents and communications between any of your counsel or other advisors and the Debtor, the Debtor's Family, or an Associated Individual.\n\n14. All Documents related to any Associated Entity that You hold or have held an interest in.\n\nCase 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 265 of 439\n\n# Exhibit C-14\n\nB2540 (Form 2540 – Subpoena for Rule 2004 Examination) (12/15) Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 266 of\n\nUNITED STATES BANKRUPTCY COURT 439\n\n**District of Connecticut**\n\nIn re HO WAN KWOK, *et al*.,\n\n<sup>1</sup> Case No. 22-50073 (JAM)\n\nDebtor Chapter 11\n\n(Jointly Administered)\n\n## **SUBPOENA FOR RULE 2004 EXAMINATION**\n\nTo: **Eddy Aquino (a/k/a Eddy L. Sanchez Aquino)**\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/A   | N/A           |\n|       |               |\n\nThe examination will be recorded by this method: N/A\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\n## **See Requests for Production of Documents, attached hereto.**\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: **May , 2024**\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 Luc A. Despins, Chapter 11 Trustee, who issues or requests this subpoena, are:\n\n**Patrick R. Linsey, Esq.; Neubert, Pepe & Monteith, P.C.; 195 Church Street, 13th Floor, New Haven, Connecticut 06510 plinsey@npmlaw.com; (203) 781-2847**\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\nSoftware Copyright (c) 1996-2022 Best Case, LLC - www.bestcase.com Best Case Bankruptcy 1 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## **PROOF OF SERVICE**\n\n**(This section should not be filed with the court unless required by Fed. R. Civ. P. 45.)**\n\nI received this subpoena for (*name of individual and title, if any*): on (*date*) .\n\nI served the subpoena by delivering a copy to the named person as follows:\n\non *(date)* ; or\n\nI returned the subpoena unexecuted because:\n\nUnless the subpoena was issued on behalf of the United States, or one of its officers or agents, I have also tendered to the witness the fees for one day's attendance, and the mileage allowed by law, in the amount of \\$ .\n\nMy fees are \\$ for travel and \\$ for services, for a total of \\$ .\n\nI declare under penalty of perjury that this information is true and correct.\n\nDate:\n\n*Server's signature*\n\n*Printed name and title*\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;\n\n(ii) requires a person to comply beyond the geographical limits specified 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: (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 trial-preparation 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## **Requests 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\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 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 271 of 439\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 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 272 of 439\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 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 273 of 439\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 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 274 of 439\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).\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\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 Eddy Aquino (a/k/a Eddy I. Sanchez Aquino), together with all of their agents, attorneys, representatives, employees, and/or anyone acting on their 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\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\n## Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 276 of 439\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, 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. \"Associated Individuals\" means individually and collectively, all individuals that (1) hold, control, have custody over, or discretion over assets owned, controlled, or enjoyed by the Debtor or the Debtor's Family; or (2) have been employees, directors, or otherwise are affiliated with one or more Associated Entities, together with the respective employees, agents, counsel, advisors, or anyone acting on behalf of any of the foregoing. Such Associated Individuals shall include, but are not limited to: Anthony DiBattista, Alex Hadjicharalambous, Bernardo Enriquez, Bingshang Jiao, Beile Li, Brian W. Hofmeister, Charles Gruder, Daniel Podhaskie, David Fallon, Defeng Cao (a/k/a Wayne Cao, Max Cao), Ding Lin, Dinggang Wang (a/k/a 王定刚), Eduardo Eurnekian, Ehsan Masud, Fiona Yu, Gladys Chow, Hao (Gavin) Li (a/k/a Huo Lai), Hao Haidong (a/k/a 郝海东), Han Chunguang (a/k/a 韩春光), Haoran He, Ivan Lin, Haitham Khaled, Jason Miller, Jennifer Mercurio, Jesse Brown, Jessica Mastrogiovanni, Jie Zhang, Jintao Li, Karin Maistrello, Kyle Bass, Lihong Wei Lafrenz (a/k/a Sara Wei, 魏丽红), Linwan \"Irene\" Feng, Max Krasner, Melissa Francis, Michael Baranowitz, Min Yang, Melissa Mendez, Nadeem Akbar, Nan Li (a/k/a Chris Lee, Mei Guo Xiao Li), Qidong Xia, Qu Guojiao (a/k/a Qu Guo Jiao, 屈国姣), Ridwan Mamode Saib, Ross Heinemeyer, Rui \"Ray\" Hao, Scott Barnett, Shih Hsin Yu, Shin Hee-\n\n## Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 277 of 439\n\nSeup (a/k/a Hee Seup Shin), Steve Bannon, Talha Zobair, Victor Cerda, Wen Xiao, Wencong Wang, William Gertz, William Je (a/k/a Je Kin Ming, Yu Jianming, 余建明), and Xuebing Wang, Ya Li (a/k/a 李娅), Yinying (Aila) Wang (a/k/a Xiao Fei Xiang), Yongping Yan (Shan Mu), Yong Yu, Yue Zhou, Yumei Hao (a/k/a Ru Shui), Yvette Wang (a/k/a Yanping Wang, Yan Ping Wang, 王雁平), Zhang Wei (a/k/a 张魏), Zhouer Wang (a/k/a Joe Wang), Zhixuan Li, and Ziyang Liu.\n\n8. \"Associated Entities\" means, individually and collectively, all organizations or Entities of any type that (1) have been owned, controlled, or invested in by the Debtor or the Debtor's Family; or (2) have an interest, whether directly or indirectly, in any assets owned, controlled, or enjoyed by the Debtor or the Debtor's Family, together with the respective employees, agents, counsel, advisors, or anyone acting on behalf of any of the foregoing. Such Associated Entities shall include, but are not limited to: 1332156 B.C. Ltd., 7 Nod Hill LLC, AAGV Limited, ACA Investment Management Limited, ACA Capital Group Limited, Ace Decade Holdings Limited, AI Group Holdings Inc., Alfa Global Ventures Limited, Alfonso Global Limited, Allied Capital Global Limited, Alpine Fiduciaries SA, Beijing Pangu Investment Co., Beijing Pangu Investment Co. Ltd., Beijing Pangu Investment Inc., Beijing Zenith Holdings Company Limited, Blue Capital Limited, Booming Sail New York LLC, Bravo Luck Limited, Brent Petro, BSA Strategic Fund I, China Golden Spring (Hong Kong) Limited, Chuang Xin Limited, Crane Advisory Group LLC, Creative Apex Investments Limited, Crystal Breeze Investments Limited, Dawn State Limited, Eastern Profit Corporation Limited, Empire Growth Holdings, Elite Well Global Limited, Freedom Media Ventures Ltd., Fung Wan Trading Inc., G Club, G Club Operations LLC, G Club International Limited, G Club Investments Limited, G Fashion LLC, G-News Operations LLC, G News LLC, GMusic Inc., G-Services LLC, G-Translators PTY LTD, GETTR USA, Inc., Genever Holdings Corporation, Genever Holdings\n\n## Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 278 of 439\n\nLLC, GFashion Media Group Inc., GFNY, Inc., Globalist International Limited, GNews Media Group Inc., Golden Spring (New York) Ltd., Guo Media, GTV Media Group, Inc., GWGOPNZ Limited, GWGNZ Limited, Gypsy Mei Food Services, LLC, HCHK Property Management Inc., HCHK Technologies Inc., Hamilton Digital Assets FD SP, Hamilton Capital Holdings Inc., Hamilton Opportunity Fund SPC, Head Win Group Limited, Himalaya Embassy, Himalaya Exchange, Himalaya Federal Reserve, Himalaya International Financial Group Ltd., Himalaya Investment LLC, Himalaya (USA) Investment Management LLC, Himalaya New World Inc., Himalaya Supervisory Organization, Himalaya Ventures, Holy City Hong Kong Ventures, Ltd., Hudson Diamond Holding LLC, Hudson Diamond Holding Inc., Hudson Diamond NY LLC, HK International Funds Investments (USA) Limited LLC, Hong Kong International Funds Investments Limited, Huk Trading Inc, Infinite Increase Limited, Infinitum Developments Limited, Japan Himalaya League, Inc., Kalixun Trading Limited, Lamp Capital LLC, Leading Shine Limited, Leading Shine NY Limited, Lexington Property and Staffing Inc., Long Gate Limited, MOS Himalaya Foundation Inc., Maywind Trading LLC, New Federal State of China (a/k/a NFSC), New York MOS Himalaya LLC, New Mulberry PTE Ltd., Newpeople LLC, Noble Fame Global Limited, Pixshow Film Inc., Roscalitar 2, Rosy Acme Ventures Limited, Rule of Law Foundation III, Inc., Rule of Law Society, Rule of Law Society IV, Inc., Santel LLC, Saraca Media Group, Inc., Shiny Ace Ltd., Shiny Times Holdings Ltd., Stevenson, Wong & Co., Taurus Fund LLC, Taurus Fund SP, Taurus Management LLC, The Lost Draft LLC, TM Primrose Limited, UA Himalaya Inc., Voice of Guo Media, Inc., Well Origin Ltd., Wise Creation, Whitecroft Shore Limited, World Century Limited, Worldwide Opportunity Holdings Limited, and ZIBA Limited.\n\n9. \"Including\" or any variant thereof means \"including without limitation.\"\n\n## Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 279 of 439\n\n10. \"And\" and \"or\" mean \"and/or,\" and shall be construed both conjunctively as well as disjunctively in order to maximize their scope.\n\n11. \"Any\" and \"all\" and \"each\" mean \"each and every.\"\n\n12. \"Each\" and \"every\" mean \"each and every.\"\n\n13. \"Third Party\" means a Person or Entity other than Yourself.\n\n14. \"Transfer\" shall have the meaning given to it by section 101(54) of the Bankruptcy Code.\n\n15. \"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, electronic communication, text message, social media post, tweet, meta-data, 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, 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, punchcards, 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\n\n## Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 280 of 439\n\nof 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\n16. \"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\n17. \"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 legal counsel, financial advisors, or any other representative.\n\n18. \"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\n19. \"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\n20. \"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\n\n## Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 281 of 439\n\nslips, memoranda, telephone communications, voice messages, telegrams, telefaxes, telecopies, telexes, instant messages, chats, text messages, telephonic notes, or notes transmitted internally or with third parties.\n\n21. \"Asset(s)\" means any item that can be used to produce positive economic value, including but not limited to any resource with economic value that is owned, controlled or is for the benefit of an entity, that is expected to provide a future benefit, including but not limited to, all real and personal property, intangible property, investments, rights to invest or to future revenue, cash, bank accounts, commodities, securities, claims, total or partial control of an entity, and prospective economic opportunities\n\n22. \"Transfer\" shall have the meaning given to it by section 101(54) of the Bankruptcy Code.\n\n## **IV. DOCUMENTS TO BE PRODUCED**\n\n1. All Documents regarding any income or Asset of the Debtor, the Debtor's Family, the Debtor's estate, an Associated Individuals, or an Associated Entity.\n\n2. All Documents related to the Debtor's financial condition and obligations to his creditors, including without limitation all Documents related to any effort to avoid paying such obligations and All Documents related to this or any other actual or potential bankruptcy or similar insolvency proceeding.\n\n3. All Documents regarding any balance sheet, bank statement, account statement, financial statement, statement of account, wire transfer instructions and/or confirmation, proof of funds, certificate of deposit, certificate of holdings, investment portfolio summary, or similar document relating to the Debtor, the Debtor's Estate, the Debtor's Family, an Associated Entity,\n\n## Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 282 of 439\n\nor an Associated Individual, including without limitation all Documents sufficient to show all Transfers to any of the foregoing.\n\n4. All Documents regarding any investment, business dealings or transactions made by, with, or on behalf of the Debtor, the Debtor's Family, an Associated Individual, or an Associated Entity.\n\n5. All Communications with the Debtor, the Debtor's Family, an Associated Individual, or an Associated Entity, and Documents related to Communications with the Debtor, the Debtor's Family, an Associated Individual, or an Associated Entity, including related to the operation, management, or decision-making of any Entity, including without limitation the Associated Entities.\n\n6. All Documents regarding any Transfer, investment, or other transaction or business dealing made to, by, or with the Debtor, the Debtor's Family, an Associated Individual, or an Associated Entity.\n\n7. All Documents regarding any property ever occupied or used by the Debtor, including without limitation the residential property located in Greenwich, Connecticut at 373 Taconic Rd.; the residential property located in Greenwich, Connecticut at 33 Ferncliff Rd.; the residential property located in Wilton, Connecticut at 354 Nod Hill Rd; the apartments or condominiums located in 5 Princes Gate London, United Kingdom SW7 1QJ; and the residential property located in Mahwah, New Jersey at 675 Ramapo Valley Road, Mahwah, New Jersey 07430.\n\n8. All Documents related to any aircraft owned, controlled, or used by the Debtor, including without limitation (i) the aircraft bearing tail number T7-GQM and any other aircraft\n\n## Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 283 of 439\n\nregistered in San Marino, including without limitation copies of all registration documents and flight manifests showing flights taken by such aircraft and the individuals onboard such flights, and (ii) any Cirrus SF50 aircraft.\n\n9. All Documents regarding any gifts, benefits or loans, to, from or on behalf of the Debtor, the Debtor's Estate, the Debtor's Family, or the Associated Entities, including without limitation Documents sufficient to show the amounts of such gifts, benefits, or loans; the purposes for which such gifts, benefits, or loans were used; when the gifts, benefits, or loans were provided; and the terms of any loans, all representations and warranties made in connection with any loans, the interest rate on any loans, and all evidence of payments of any loans.\n\n10. All Documents concerning any trust or similar instrument set up by, on behalf of, or for the benefit of the Debtor, the Debtor's Estate, the Debtor's Family, or an Associated Entity, including without limitation Documents sufficient to show when the trust(s) was created, by whom it was created, for whose benefit it was created, and the corpus of the trust.\n\n11. All Documents related to any obligation, claim, liability, or debt associated with any legal dispute involving the Debtor, including but not limited to those relating to any litigation before any local, state, federal, or international body, whether an administrative body, court, panel, or alternative dispute resolution entity.\n\n12. All Documents and communications with the Debtor, the Debtor's Family, or an Associated Individual.\n\n13. All Documents and communications between any of your counsel or other advisors and the Debtor, the Debtor's Family, or an Associated Individual.\n\n## Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 284 of 439\n\n14. All Documents related to any Associated Entity that You hold or have held an interest in.\n\nCase 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 285 of 439\n\n# Exhibit C-15\n\nB2540 (Form 2540 – Subpoena for Rule 2004 Examination) (12/15) Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 286 of\n\nUNITED STATES BANKRUPTCY COURT 439\n\n**District of Connecticut**\n\nIn re HO WAN KWOK, *et al*.,\n\n<sup>1</sup> Case No. 22-50073 (JAM)\n\nDebtor Chapter 11\n\n(Jointly Administered)\n\n## **SUBPOENA FOR RULE 2004 EXAMINATION**\n\nTo: **Summer L. Bridges**\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/A   | N/A           |\n|       |               |\n\nThe examination will be recorded by this method: N/A\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\n## **See Requests for Production of Documents, attached hereto.**\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: **May , 2024**\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 Luc A. Despins, Chapter 11 Trustee, who issues or requests this subpoena, are:\n\n**Patrick R. Linsey, Esq.; Neubert, Pepe & Monteith, P.C.; 195 Church Street, 13th Floor, New Haven, Connecticut 06510 plinsey@npmlaw.com; (203) 781-2847**\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\nSoftware Copyright (c) 1996-2022 Best Case, LLC - www.bestcase.com Best Case Bankruptcy 1 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## **PROOF OF SERVICE**\n\n**(This section should not be filed with the court unless required by Fed. R. Civ. P. 45.)**\n\nI received this subpoena for (*name of individual and title, if any*): on (*date*) .\n\nI served the subpoena by delivering a copy to the named person as follows:\n\non *(date)* ; or\n\nI returned the subpoena unexecuted because:\n\nUnless the subpoena was issued on behalf of the United States, or one of its officers or agents, I have also tendered to the witness the fees for one day's attendance, and the mileage allowed by law, in the amount of \\$ .\n\nMy fees are \\$ for travel and \\$ for services, for a total of \\$ .\n\nI declare under penalty of perjury that this information is true and correct.\n\nDate:\n\n*Server's signature*\n\n*Printed name and title*\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;\n\n(ii) requires a person to comply beyond the geographical limits specified 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: (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 trial-preparation 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## **Requests 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\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 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 291 of 439\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 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 292 of 439\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 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 293 of 439\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 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 294 of 439\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).\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\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## Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 295 of 439\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 Summer L. Bridges, together with all of their agents, attorneys, representatives, employees, and/or anyone acting on their 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\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\n## Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 296 of 439\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, 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. \"Associated Individuals\" means individually and collectively, all individuals that (1) hold, control, have custody over, or discretion over assets owned, controlled, or enjoyed by the Debtor or the Debtor's Family; or (2) have been employees, directors, or otherwise are affiliated with one or more Associated Entities, together with the respective employees, agents, counsel, advisors, or anyone acting on behalf of any of the foregoing. Such Associated Individuals shall include, but are not limited to: Anthony DiBattista, Alex Hadjicharalambous, Bernardo Enriquez, Bingshang Jiao, Beile Li, Brian W. Hofmeister, Charles Gruder, Daniel Podhaskie, David Fallon, Defeng Cao (a/k/a Wayne Cao, Max Cao), Ding Lin, Dinggang Wang (a/k/a 王定刚), Eduardo Eurnekian, Ehsan Masud, Fiona Yu, Gladys Chow, Hao (Gavin) Li (a/k/a Huo Lai), Hao Haidong (a/k/a 郝海东), Han Chunguang (a/k/a 韩春光), Haoran He, Ivan Lin, Haitham Khaled, Jason Miller, Jennifer Mercurio, Jesse Brown, Jessica Mastrogiovanni, Jie Zhang, Jintao Li, Karin Maistrello, Kyle Bass, Lihong Wei Lafrenz (a/k/a Sara Wei, 魏丽红), Linwan \"Irene\" Feng, Max Krasner, Melissa Francis, Michael Baranowitz, Min Yang, Melissa Mendez, Nadeem Akbar, Nan Li (a/k/a Chris Lee, Mei Guo Xiao Li), Qidong Xia, Qu Guojiao (a/k/a Qu Guo Jiao, 屈国姣), Ridwan Mamode Saib, Ross Heinemeyer, Rui \"Ray\" Hao, Scott Barnett, Shih Hsin Yu, Shin Hee-\n\n## Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 297 of 439\n\nSeup (a/k/a Hee Seup Shin), Steve Bannon, Talha Zobair, Victor Cerda, Wen Xiao, Wencong Wang, William Gertz, William Je (a/k/a Je Kin Ming, Yu Jianming, 余建明), and Xuebing Wang, Ya Li (a/k/a 李娅), Yinying (Aila) Wang (a/k/a Xiao Fei Xiang), Yongping Yan (Shan Mu), Yong Yu, Yue Zhou, Yumei Hao (a/k/a Ru Shui), Yvette Wang (a/k/a Yanping Wang, Yan Ping Wang, 王雁平), Zhang Wei (a/k/a 张魏), Zhouer Wang (a/k/a Joe Wang), Zhixuan Li, and Ziyang Liu.\n\n8. \"Associated Entities\" means, individually and collectively, all organizations or Entities of any type that (1) have been owned, controlled, or invested in by the Debtor or the Debtor's Family; or (2) have an interest, whether directly or indirectly, in any assets owned, controlled, or enjoyed by the Debtor or the Debtor's Family, together with the respective employees, agents, counsel, advisors, or anyone acting on behalf of any of the foregoing. Such Associated Entities shall include, but are not limited to: 1332156 B.C. Ltd., 7 Nod Hill LLC, AAGV Limited, ACA Investment Management Limited, ACA Capital Group Limited, Ace Decade Holdings Limited, AI Group Holdings Inc., Alfa Global Ventures Limited, Alfonso Global Limited, Allied Capital Global Limited, Alpine Fiduciaries SA, Beijing Pangu Investment Co., Beijing Pangu Investment Co. Ltd., Beijing Pangu Investment Inc., Beijing Zenith Holdings Company Limited, Blue Capital Limited, Booming Sail New York LLC, Bravo Luck Limited, Brent Petro, BSA Strategic Fund I, China Golden Spring (Hong Kong) Limited, Chuang Xin Limited, Crane Advisory Group LLC, Creative Apex Investments Limited, Crystal Breeze Investments Limited, Dawn State Limited, Eastern Profit Corporation Limited, Empire Growth Holdings, Elite Well Global Limited, Freedom Media Ventures Ltd., Fung Wan Trading Inc., G Club, G Club Operations LLC, G Club International Limited, G Club Investments Limited, G Fashion LLC, G-News Operations LLC, G News LLC, GMusic Inc., G-Services LLC, G-Translators PTY LTD, GETTR USA, Inc., Genever Holdings Corporation, Genever Holdings\n\n## Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 298 of 439\n\nLLC, GFashion Media Group Inc., GFNY, Inc., Globalist International Limited, GNews Media Group Inc., Golden Spring (New York) Ltd., Guo Media, GTV Media Group, Inc., GWGOPNZ Limited, GWGNZ Limited, Gypsy Mei Food Services, LLC, HCHK Property Management Inc., HCHK Technologies Inc., Hamilton Digital Assets FD SP, Hamilton Capital Holdings Inc., Hamilton Opportunity Fund SPC, Head Win Group Limited, Himalaya Embassy, Himalaya Exchange, Himalaya Federal Reserve, Himalaya International Financial Group Ltd., Himalaya Investment LLC, Himalaya (USA) Investment Management LLC, Himalaya New World Inc., Himalaya Supervisory Organization, Himalaya Ventures, Holy City Hong Kong Ventures, Ltd., Hudson Diamond Holding LLC, Hudson Diamond Holding Inc., Hudson Diamond NY LLC, HK International Funds Investments (USA) Limited LLC, Hong Kong International Funds Investments Limited, Huk Trading Inc, Infinite Increase Limited, Infinitum Developments Limited, Japan Himalaya League, Inc., Kalixun Trading Limited, Lamp Capital LLC, Leading Shine Limited, Leading Shine NY Limited, Lexington Property and Staffing Inc., Long Gate Limited, MOS Himalaya Foundation Inc., Maywind Trading LLC, New Federal State of China (a/k/a NFSC), New York MOS Himalaya LLC, New Mulberry PTE Ltd., Newpeople LLC, Noble Fame Global Limited, Pixshow Film Inc., Roscalitar 2, Rosy Acme Ventures Limited, Rule of Law Foundation III, Inc., Rule of Law Society, Rule of Law Society IV, Inc., Santel LLC, Saraca Media Group, Inc., Shiny Ace Ltd., Shiny Times Holdings Ltd., Stevenson, Wong & Co., Taurus Fund LLC, Taurus Fund SP, Taurus Management LLC, The Lost Draft LLC, TM Primrose Limited, UA Himalaya Inc., Voice of Guo Media, Inc., Well Origin Ltd., Wise Creation, Whitecroft Shore Limited, World Century Limited, Worldwide Opportunity Holdings Limited, and ZIBA Limited.\n\n9. \"Including\" or any variant thereof means \"including without limitation.\"\n\n## Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 299 of 439\n\n10. \"And\" and \"or\" mean \"and/or,\" and shall be construed both conjunctively as well as disjunctively in order to maximize their scope.\n\n11. \"Any\" and \"all\" and \"each\" mean \"each and every.\"\n\n12. \"Each\" and \"every\" mean \"each and every.\"\n\n13. \"Third Party\" means a Person or Entity other than Yourself.\n\n14. \"Transfer\" shall have the meaning given to it by section 101(54) of the Bankruptcy Code.\n\n15. \"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, electronic communication, text message, social media post, tweet, meta-data, 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, 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, punchcards, 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\n\n## Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 300 of 439\n\nof 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\n16. \"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\n17. \"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 legal counsel, financial advisors, or any other representative.\n\n18. \"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\n19. \"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\n20. \"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\n\n## Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 301 of 439\n\nslips, memoranda, telephone communications, voice messages, telegrams, telefaxes, telecopies, telexes, instant messages, chats, text messages, telephonic notes, or notes transmitted internally or with third parties.\n\n21. \"Asset(s)\" means any item that can be used to produce positive economic value, including but not limited to any resource with economic value that is owned, controlled or is for the benefit of an entity, that is expected to provide a future benefit, including but not limited to, all real and personal property, intangible property, investments, rights to invest or to future revenue, cash, bank accounts, commodities, securities, claims, total or partial control of an entity, and prospective economic opportunities\n\n22. \"Transfer\" shall have the meaning given to it by section 101(54) of the Bankruptcy Code.\n\n## **IV. DOCUMENTS TO BE PRODUCED**\n\n1. All Documents regarding any income or Asset of the Debtor, the Debtor's Family, the Debtor's estate, an Associated Individuals, or an Associated Entity.\n\n2. All Documents related to the Debtor's financial condition and obligations to his creditors, including without limitation all Documents related to any effort to avoid paying such obligations and All Documents related to this or any other actual or potential bankruptcy or similar insolvency proceeding.\n\n3. All Documents regarding any balance sheet, bank statement, account statement, financial statement, statement of account, wire transfer instructions and/or confirmation, proof of funds, certificate of deposit, certificate of holdings, investment portfolio summary, or similar document relating to the Debtor, the Debtor's Estate, the Debtor's Family, an Associated Entity,\n\n## Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 302 of 439\n\nor an Associated Individual, including without limitation all Documents sufficient to show all Transfers to any of the foregoing.\n\n4. All Documents regarding any investment, business dealings or transactions made by, with, or on behalf of the Debtor, the Debtor's Family, an Associated Individual, or an Associated Entity.\n\n5. All Communications with the Debtor, the Debtor's Family, an Associated Individual, or an Associated Entity, and Documents related to Communications with the Debtor, the Debtor's Family, an Associated Individual, or an Associated Entity, including related to the operation, management, or decision-making of any Entity, including without limitation the Associated Entities.\n\n6. All Documents regarding any Transfer, investment, or other transaction or business dealing made to, by, or with the Debtor, the Debtor's Family, an Associated Individual, or an Associated Entity.\n\n7. All Documents regarding any property ever occupied or used by the Debtor, including without limitation the residential property located in Greenwich, Connecticut at 373 Taconic Rd.; the residential property located in Greenwich, Connecticut at 33 Ferncliff Rd.; the residential property located in Wilton, Connecticut at 354 Nod Hill Rd; the apartments or condominiums located in 5 Princes Gate London, United Kingdom SW7 1QJ; and the residential property located in Mahwah, New Jersey at 675 Ramapo Valley Road, Mahwah, New Jersey 07430.\n\n8. All Documents related to any aircraft owned, controlled, or used by the Debtor, including without limitation (i) the aircraft bearing tail number T7-GQM and any other aircraft\n\n## Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 303 of 439\n\nregistered in San Marino, including without limitation copies of all registration documents and flight manifests showing flights taken by such aircraft and the individuals onboard such flights, and (ii) any Cirrus SF50 aircraft.\n\n9. All Documents regarding any gifts, benefits or loans, to, from or on behalf of the Debtor, the Debtor's Estate, the Debtor's Family, or the Associated Entities, including without limitation Documents sufficient to show the amounts of such gifts, benefits, or loans; the purposes for which such gifts, benefits, or loans were used; when the gifts, benefits, or loans were provided; and the terms of any loans, all representations and warranties made in connection with any loans, the interest rate on any loans, and all evidence of payments of any loans.\n\n10. All Documents concerning any trust or similar instrument set up by, on behalf of, or for the benefit of the Debtor, the Debtor's Estate, the Debtor's Family, or an Associated Entity, including without limitation Documents sufficient to show when the trust(s) was created, by whom it was created, for whose benefit it was created, and the corpus of the trust.\n\n11. All Documents related to any obligation, claim, liability, or debt associated with any legal dispute involving the Debtor, including but not limited to those relating to any litigation before any local, state, federal, or international body, whether an administrative body, court, panel, or alternative dispute resolution entity.\n\n12. All Documents and communications with the Debtor, the Debtor's Family, or an Associated Individual.\n\n13. All Documents and communications between any of your counsel or other advisors and the Debtor, the Debtor's Family, or an Associated Individual.\n\n## Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 304 of 439\n\n14. All Documents related to any Associated Entity that You hold or have held an interest in.\n\n# Exhibit C-16\n\n#### B2540 (Form 2540 – Subpoena for Rule 2004 Examination) (12/15) Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 306 of\n\n439\n\nUNITED STATES BANKRUPTCY COURT\n\n**District of Connecticut**\n\nIn re HO WAN KWOK, *et al*.,\n\n<sup>1</sup> Case No. 22-50073 (JAM) Debtor Chapter 11\n\n(Jointly Administered)\n\n# **SUBPOENA FOR RULE 2004 EXAMINATION**\n\nTo: **Michael Baranowitz**\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/A   | N/A           |\n|       |               |\n\nThe examination will be recorded by this method: N/A\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\n## **See Requests for Production of Documents, attached hereto.**\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: **May , 2024**\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 Luc A. Despins, Chapter 11 Trustee, who issues or requests this subpoena, are:\n\n**Patrick R. Linsey, Esq.; Neubert, Pepe & Monteith, P.C.; 195 Church Street, 13th Floor, New Haven, Connecticut 06510 plinsey@npmlaw.com; (203) 781-2847**\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\nSoftware Copyright (c) 1996-2022 Best Case, LLC - www.bestcase.com Best Case Bankruptcy 1 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## **PROOF OF SERVICE**\n\n**(This section should not be filed with the court unless required by Fed. R. Civ. P. 45.)**\n\nI received this subpoena for (*name of individual and title, if any*): on (*date*) .\n\nI served the subpoena by delivering a copy to the named person as follows:\n\non *(date)* ; or\n\nI returned the subpoena unexecuted because:\n\nUnless the subpoena was issued on behalf of the United States, or one of its officers or agents, I have also tendered to the witness the fees for one day's attendance, and the mileage allowed by law, in the amount of \\$ .\n\nMy fees are \\$ for travel and \\$ for services, for a total of \\$ .\n\nI declare under penalty of perjury that this information is true and correct.\n\nDate:\n\n*Server's signature*\n\n*Printed name and title*\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;\n\n(ii) requires a person to comply beyond the geographical limits specified 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: (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 trial-preparation 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## **Requests 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\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 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 311 of 439\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 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 312 of 439\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 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 313 of 439\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 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 314 of 439\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).\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\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## Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 315 of 439\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 Michael Baranowitz, together with all of their agents, attorneys, representatives, employees, and/or anyone acting on their 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\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\n## Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 316 of 439\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, 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. \"Associated Individuals\" means individually and collectively, all individuals that (1) hold, control, have custody over, or discretion over assets owned, controlled, or enjoyed by the Debtor or the Debtor's Family; or (2) have been employees, directors, or otherwise are affiliated with one or more Associated Entities, together with the respective employees, agents, counsel, advisors, or anyone acting on behalf of any of the foregoing. Such Associated Individuals shall include, but are not limited to: Anthony DiBattista, Alex Hadjicharalambous, Bernardo Enriquez, Bingshang Jiao, Beile Li, Brian W. Hofmeister, Charles Gruder, Daniel Podhaskie, David Fallon, Defeng Cao (a/k/a Wayne Cao, Max Cao), Ding Lin, Dinggang Wang (a/k/a 王定刚), Eduardo Eurnekian, Ehsan Masud, Fiona Yu, Gladys Chow, Hao (Gavin) Li (a/k/a Huo Lai), Hao Haidong (a/k/a 郝海东), Han Chunguang (a/k/a 韩春光), Haoran He, Ivan Lin, Haitham Khaled, Jason Miller, Jennifer Mercurio, Jesse Brown, Jessica Mastrogiovanni, Jie Zhang, Jintao Li, Karin Maistrello, Kyle Bass, Lihong Wei Lafrenz (a/k/a Sara Wei, 魏丽红), Linwan \"Irene\" Feng, Max Krasner, Melissa Francis, Michael Baranowitz, Min Yang, Melissa Mendez, Nadeem Akbar, Nan Li (a/k/a Chris Lee, Mei Guo Xiao Li), Qidong Xia, Qu Guojiao (a/k/a Qu Guo Jiao, 屈国姣), Ridwan Mamode Saib, Ross Heinemeyer, Rui \"Ray\" Hao, Scott Barnett, Shih Hsin Yu, Shin Hee-\n\n## Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 317 of 439\n\nSeup (a/k/a Hee Seup Shin), Steve Bannon, Talha Zobair, Victor Cerda, Wen Xiao, Wencong Wang, William Gertz, William Je (a/k/a Je Kin Ming, Yu Jianming, 余建明), and Xuebing Wang, Ya Li (a/k/a 李娅), Yinying (Aila) Wang (a/k/a Xiao Fei Xiang), Yongping Yan (Shan Mu), Yong Yu, Yue Zhou, Yumei Hao (a/k/a Ru Shui), Yvette Wang (a/k/a Yanping Wang, Yan Ping Wang, 王雁平), Zhang Wei (a/k/a 张魏), Zhouer Wang (a/k/a Joe Wang), Zhixuan Li, and Ziyang Liu.\n\n8. \"Associated Entities\" means, individually and collectively, all organizations or Entities of any type that (1) have been owned, controlled, or invested in by the Debtor or the Debtor's Family; or (2) have an interest, whether directly or indirectly, in any assets owned, controlled, or enjoyed by the Debtor or the Debtor's Family, together with the respective employees, agents, counsel, advisors, or anyone acting on behalf of any of the foregoing. Such Associated Entities shall include, but are not limited to: 1332156 B.C. Ltd., 7 Nod Hill LLC, AAGV Limited, ACA Investment Management Limited, ACA Capital Group Limited, Ace Decade Holdings Limited, AI Group Holdings Inc., Alfa Global Ventures Limited, Alfonso Global Limited, Allied Capital Global Limited, Alpine Fiduciaries SA, Beijing Pangu Investment Co., Beijing Pangu Investment Co. Ltd., Beijing Pangu Investment Inc., Beijing Zenith Holdings Company Limited, Blue Capital Limited, Booming Sail New York LLC, Bravo Luck Limited, Brent Petro, BSA Strategic Fund I, China Golden Spring (Hong Kong) Limited, Chuang Xin Limited, Crane Advisory Group LLC, Creative Apex Investments Limited, Crystal Breeze Investments Limited, Dawn State Limited, Eastern Profit Corporation Limited, Empire Growth Holdings, Elite Well Global Limited, Freedom Media Ventures Ltd., Fung Wan Trading Inc., G Club, G Club Operations LLC, G Club International Limited, G Club Investments Limited, G Fashion LLC, G-News Operations LLC, G News LLC, GMusic Inc., G-Services LLC, G-Translators PTY LTD, GETTR USA, Inc., Genever Holdings Corporation, Genever Holdings\n\n## Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 318 of 439\n\nLLC, GFashion Media Group Inc., GFNY, Inc., Globalist International Limited, GNews Media Group Inc., Golden Spring (New York) Ltd., Guo Media, GTV Media Group, Inc., GWGOPNZ Limited, GWGNZ Limited, Gypsy Mei Food Services, LLC, HCHK Property Management Inc., HCHK Technologies Inc., Hamilton Digital Assets FD SP, Hamilton Capital Holdings Inc., Hamilton Opportunity Fund SPC, Head Win Group Limited, Himalaya Embassy, Himalaya Exchange, Himalaya Federal Reserve, Himalaya International Financial Group Ltd., Himalaya Investment LLC, Himalaya (USA) Investment Management LLC, Himalaya New World Inc., Himalaya Supervisory Organization, Himalaya Ventures, Holy City Hong Kong Ventures, Ltd., Hudson Diamond Holding LLC, Hudson Diamond Holding Inc., Hudson Diamond NY LLC, HK International Funds Investments (USA) Limited LLC, Hong Kong International Funds Investments Limited, Huk Trading Inc, Infinite Increase Limited, Infinitum Developments Limited, Japan Himalaya League, Inc., Kalixun Trading Limited, Lamp Capital LLC, Leading Shine Limited, Leading Shine NY Limited, Lexington Property and Staffing Inc., Long Gate Limited, MOS Himalaya Foundation Inc., Maywind Trading LLC, New Federal State of China (a/k/a NFSC), New York MOS Himalaya LLC, New Mulberry PTE Ltd., Newpeople LLC, Noble Fame Global Limited, Pixshow Film Inc., Roscalitar 2, Rosy Acme Ventures Limited, Rule of Law Foundation III, Inc., Rule of Law Society, Rule of Law Society IV, Inc., Santel LLC, Saraca Media Group, Inc., Shiny Ace Ltd., Shiny Times Holdings Ltd., Stevenson, Wong & Co., Taurus Fund LLC, Taurus Fund SP, Taurus Management LLC, The Lost Draft LLC, TM Primrose Limited, UA Himalaya Inc., Voice of Guo Media, Inc., Well Origin Ltd., Wise Creation, Whitecroft Shore Limited, World Century Limited, Worldwide Opportunity Holdings Limited, and ZIBA Limited.\n\n9. \"Including\" or any variant thereof means \"including without limitation.\"\n\n## Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 319 of 439\n\n10. \"And\" and \"or\" mean \"and/or,\" and shall be construed both conjunctively as well as disjunctively in order to maximize their scope.\n\n11. \"Any\" and \"all\" and \"each\" mean \"each and every.\"\n\n12. \"Each\" and \"every\" mean \"each and every.\"\n\n13. \"Third Party\" means a Person or Entity other than Yourself.\n\n14. \"Transfer\" shall have the meaning given to it by section 101(54) of the Bankruptcy Code.\n\n15. \"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, electronic communication, text message, social media post, tweet, meta-data, 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, 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, punchcards, 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\n\n## Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 320 of 439\n\nof 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\n16. \"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\n17. \"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 legal counsel, financial advisors, or any other representative.\n\n18. \"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\n19. \"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\n20. \"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\n\n## Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 321 of 439\n\nslips, memoranda, telephone communications, voice messages, telegrams, telefaxes, telecopies, telexes, instant messages, chats, text messages, telephonic notes, or notes transmitted internally or with third parties.\n\n21. \"Asset(s)\" means any item that can be used to produce positive economic value, including but not limited to any resource with economic value that is owned, controlled or is for the benefit of an entity, that is expected to provide a future benefit, including but not limited to, all real and personal property, intangible property, investments, rights to invest or to future revenue, cash, bank accounts, commodities, securities, claims, total or partial control of an entity, and prospective economic opportunities\n\n22. \"Transfer\" shall have the meaning given to it by section 101(54) of the Bankruptcy Code.\n\n## **IV. DOCUMENTS TO BE PRODUCED**\n\n1. All Documents regarding any income or Asset of the Debtor, the Debtor's Family, the Debtor's estate, an Associated Individuals, or an Associated Entity.\n\n2. All Documents related to the Debtor's financial condition and obligations to his creditors, including without limitation all Documents related to any effort to avoid paying such obligations and All Documents related to this or any other actual or potential bankruptcy or similar insolvency proceeding.\n\n3. All Documents regarding any balance sheet, bank statement, account statement, financial statement, statement of account, wire transfer instructions and/or confirmation, proof of funds, certificate of deposit, certificate of holdings, investment portfolio summary, or similar document relating to the Debtor, the Debtor's Estate, the Debtor's Family, an Associated Entity,\n\n## Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 322 of 439\n\nor an Associated Individual, including without limitation all Documents sufficient to show all Transfers to any of the foregoing.\n\n4. All Documents regarding any investment, business dealings or transactions made by, with, or on behalf of the Debtor, the Debtor's Family, an Associated Individual, or an Associated Entity.\n\n5. All Communications with the Debtor, the Debtor's Family, an Associated Individual, or an Associated Entity, and Documents related to Communications with the Debtor, the Debtor's Family, an Associated Individual, or an Associated Entity, including related to the operation, management, or decision-making of any Entity, including without limitation the Associated Entities.\n\n6. All Documents regarding any Transfer, investment, or other transaction or business dealing made to, by, or with the Debtor, the Debtor's Family, an Associated Individual, or an Associated Entity.\n\n7. All Documents regarding any property ever occupied or used by the Debtor, including without limitation the residential property located in Greenwich, Connecticut at 373 Taconic Rd.; the residential property located in Greenwich, Connecticut at 33 Ferncliff Rd.; the residential property located in Wilton, Connecticut at 354 Nod Hill Rd; the apartments or condominiums located in 5 Princes Gate London, United Kingdom SW7 1QJ; and the residential property located in Mahwah, New Jersey at 675 Ramapo Valley Road, Mahwah, New Jersey 07430.\n\n8. All Documents related to any aircraft owned, controlled, or used by the Debtor, including without limitation (i) the aircraft bearing tail number T7-GQM and any other aircraft\n\n## Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 323 of 439\n\nregistered in San Marino, including without limitation copies of all registration documents and flight manifests showing flights taken by such aircraft and the individuals onboard such flights, and (ii) any Cirrus SF50 aircraft.\n\n9. All Documents regarding any gifts, benefits or loans, to, from or on behalf of the Debtor, the Debtor's Estate, the Debtor's Family, or the Associated Entities, including without limitation Documents sufficient to show the amounts of such gifts, benefits, or loans; the purposes for which such gifts, benefits, or loans were used; when the gifts, benefits, or loans were provided; and the terms of any loans, all representations and warranties made in connection with any loans, the interest rate on any loans, and all evidence of payments of any loans.\n\n10. All Documents concerning any trust or similar instrument set up by, on behalf of, or for the benefit of the Debtor, the Debtor's Estate, the Debtor's Family, or an Associated Entity, including without limitation Documents sufficient to show when the trust(s) was created, by whom it was created, for whose benefit it was created, and the corpus of the trust.\n\n11. All Documents related to any obligation, claim, liability, or debt associated with any legal dispute involving the Debtor, including but not limited to those relating to any litigation before any local, state, federal, or international body, whether an administrative body, court, panel, or alternative dispute resolution entity.\n\n12. All Documents and communications with the Debtor, the Debtor's Family, or an Associated Individual.\n\n13. All Documents and communications between any of your counsel or other advisors and the Debtor, the Debtor's Family, or an Associated Individual.\n\n## Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 324 of 439\n\n14. All Documents related to any Associated Entity that You hold or have held an interest in.\n\nCase 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 325 of 439\n\n# Exhibit C-17\n\n#### B2540 (Form 2540 – Subpoena for Rule 2004 Examination) (12/15) Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 326 of\n\n439\n\nUNITED STATES BANKRUPTCY COURT\n\n**District of Connecticut**\n\nIn re HO WAN KWOK, *et al*.,\n\n<sup>1</sup> Case No. 22-50073 (JAM) Debtor Chapter 11\n\n(Jointly Administered)\n\n# **SUBPOENA FOR RULE 2004 EXAMINATION**\n\nTo: **Maya Fawaz**\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/A   | N/A           |\n|       |               |\n\nThe examination will be recorded by this method: N/A\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\n## **See Requests for Production of Documents, attached hereto.**\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: **May , 2024**\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 Luc A. Despins, Chapter 11 Trustee, who issues or requests this subpoena, are:\n\n**Patrick R. Linsey, Esq.; Neubert, Pepe & Monteith, P.C.; 195 Church Street, 13th Floor, New Haven, Connecticut 06510 plinsey@npmlaw.com; (203) 781-2847**\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\nSoftware Copyright (c) 1996-2022 Best Case, LLC - www.bestcase.com Best Case Bankruptcy 1 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## **PROOF OF SERVICE**\n\n**(This section should not be filed with the court unless required by Fed. R. Civ. P. 45.)**\n\nI received this subpoena for (*name of individual and title, if any*): on (*date*) .\n\nI served the subpoena by delivering a copy to the named person as follows:\n\non *(date)* ; or\n\nI returned the subpoena unexecuted because:\n\nUnless the subpoena was issued on behalf of the United States, or one of its officers or agents, I have also tendered to the witness the fees for one day's attendance, and the mileage allowed by law, in the amount of \\$ .\n\nMy fees are \\$ for travel and \\$ for services, for a total of \\$ .\n\nI declare under penalty of perjury that this information is true and correct.\n\nDate:\n\n*Server's signature*\n\n*Printed name and title*\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;\n\n(ii) requires a person to comply beyond the geographical limits specified 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: (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 trial-preparation 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## **Requests 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\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 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 331 of 439\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 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 332 of 439\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 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 333 of 439\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 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 334 of 439\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).\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\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 Maya Fawaz, together with all of their agents, attorneys, representatives, employees, and/or anyone acting on their 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\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\n## Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 336 of 439\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, 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. \"Associated Individuals\" means individually and collectively, all individuals that (1) hold, control, have custody over, or discretion over assets owned, controlled, or enjoyed by the Debtor or the Debtor's Family; or (2) have been employees, directors, or otherwise are affiliated with one or more Associated Entities, together with the respective employees, agents, counsel, advisors, or anyone acting on behalf of any of the foregoing. Such Associated Individuals shall include, but are not limited to: Anthony DiBattista, Alex Hadjicharalambous, Bernardo Enriquez, Bingshang Jiao, Beile Li, Brian W. Hofmeister, Charles Gruder, Daniel Podhaskie, David Fallon, Defeng Cao (a/k/a Wayne Cao, Max Cao), Ding Lin, Dinggang Wang (a/k/a 王定刚), Eduardo Eurnekian, Ehsan Masud, Fiona Yu, Gladys Chow, Hao (Gavin) Li (a/k/a Huo Lai), Hao Haidong (a/k/a 郝海东), Han Chunguang (a/k/a 韩春光), Haoran He, Ivan Lin, Haitham Khaled, Jason Miller, Jennifer Mercurio, Jesse Brown, Jessica Mastrogiovanni, Jie Zhang, Jintao Li, Karin Maistrello, Kyle Bass, Lihong Wei Lafrenz (a/k/a Sara Wei, 魏丽红), Linwan \"Irene\" Feng, Max Krasner, Melissa Francis, Michael Baranowitz, Min Yang, Melissa Mendez, Nadeem Akbar, Nan Li (a/k/a Chris Lee, Mei Guo Xiao Li), Qidong Xia, Qu Guojiao (a/k/a Qu Guo Jiao, 屈国姣), Ridwan Mamode Saib, Ross Heinemeyer, Rui \"Ray\" Hao, Scott Barnett, Shih Hsin Yu, Shin Hee-Seup (a/k/a Hee Seup Shin), Steve Bannon, Talha Zobair, Victor Cerda, Wen Xiao, Wencong Wang, William Gertz, William Je (a/k/a Je Kin Ming, Yu Jianming, 余建明), and Xuebing Wang,\n\n## Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 337 of 439\n\nYa Li (a/k/a 李娅), Yinying (Aila) Wang (a/k/a Xiao Fei Xiang), Yongping Yan (Shan Mu), Yong Yu, Yue Zhou, Yumei Hao (a/k/a Ru Shui), Yvette Wang (a/k/a Yanping Wang, Yan Ping Wang, 王雁平), Zhang Wei (a/k/a 张魏), Zhouer Wang (a/k/a Joe Wang), Zhixuan Li, and Ziyang Liu.\n\n8. \"Associated Entities\" means, individually and collectively, all organizations or Entities of any type that (1) have been owned, controlled, or invested in by the Debtor or the Debtor's Family; or (2) have an interest, whether directly or indirectly, in any assets owned, controlled, or enjoyed by the Debtor or the Debtor's Family, together with the respective employees, agents, counsel, advisors, or anyone acting on behalf of any of the foregoing. Such Associated Entities shall include, but are not limited to: 1332156 B.C. Ltd., 7 Nod Hill LLC, AAGV Limited, ACA Investment Management Limited, ACA Capital Group Limited, Ace Decade Holdings Limited, AI Group Holdings Inc., Alfa Global Ventures Limited, Alfonso Global Limited, Allied Capital Global Limited, Alpine Fiduciaries SA, Beijing Pangu Investment Co., Beijing Pangu Investment Co. Ltd., Beijing Pangu Investment Inc., Beijing Zenith Holdings Company Limited, Blue Capital Limited, Booming Sail New York LLC, Bravo Luck Limited, Brent Petro, BSA Strategic Fund I, China Golden Spring (Hong Kong) Limited, Chuang Xin Limited, Crane Advisory Group LLC, Creative Apex Investments Limited, Crystal Breeze Investments Limited, Dawn State Limited, Eastern Profit Corporation Limited, Empire Growth Holdings, Elite Well Global Limited, Freedom Media Ventures Ltd., Fung Wan Trading Inc., G Club, G Club Operations LLC, G Club International Limited, G Club Investments Limited, G Fashion LLC, G-News Operations LLC, G News LLC, GMusic Inc., G-Services LLC, G-Translators PTY LTD, GETTR USA, Inc., Genever Holdings Corporation, Genever Holdings LLC, GFashion Media Group Inc., GFNY, Inc., Globalist International Limited, GNews Media Group Inc., Golden Spring (New York) Ltd., Guo Media, GTV Media Group, Inc., GWGOPNZ\n\n## Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 338 of 439\n\nLimited, GWGNZ Limited, Gypsy Mei Food Services, LLC, HCHK Property Management Inc., HCHK Technologies Inc., Hamilton Digital Assets FD SP, Hamilton Capital Holdings Inc., Hamilton Opportunity Fund SPC, Head Win Group Limited, Himalaya Embassy, Himalaya Exchange, Himalaya Federal Reserve, Himalaya International Financial Group Ltd., Himalaya Investment LLC, Himalaya (USA) Investment Management LLC, Himalaya New World Inc., Himalaya Supervisory Organization, Himalaya Ventures, Holy City Hong Kong Ventures, Ltd., Hudson Diamond Holding LLC, Hudson Diamond Holding Inc., Hudson Diamond NY LLC, HK International Funds Investments (USA) Limited LLC, Hong Kong International Funds Investments Limited, Huk Trading Inc, Infinite Increase Limited, Infinitum Developments Limited, Japan Himalaya League, Inc., Kalixun Trading Limited, Lamp Capital LLC, Leading Shine Limited, Leading Shine NY Limited, Lexington Property and Staffing Inc., Long Gate Limited, MOS Himalaya Foundation Inc., Maywind Trading LLC, New Federal State of China (a/k/a NFSC), New York MOS Himalaya LLC, New Mulberry PTE Ltd., Newpeople LLC, Noble Fame Global Limited, Pixshow Film Inc., Roscalitar 2, Rosy Acme Ventures Limited, Rule of Law Foundation III, Inc., Rule of Law Society, Rule of Law Society IV, Inc., Santel LLC, Saraca Media Group, Inc., Shiny Ace Ltd., Shiny Times Holdings Ltd., Stevenson, Wong & Co., Taurus Fund LLC, Taurus Fund SP, Taurus Management LLC, The Lost Draft LLC, TM Primrose Limited, UA Himalaya Inc., Voice of Guo Media, Inc., Well Origin Ltd., Wise Creation, Whitecroft Shore Limited, World Century Limited, Worldwide Opportunity Holdings Limited, and ZIBA Limited.\n\n9. \"Including\" or any variant thereof means \"including without limitation.\"\n\n10. \"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 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 339 of 439\n\n11. \"Any\" and \"all\" and \"each\" mean \"each and every.\"\n\n12. \"Each\" and \"every\" mean \"each and every.\"\n\n13. \"Third Party\" means a Person or Entity other than Yourself.\n\n14. \"Transfer\" shall have the meaning given to it by section 101(54) of the Bankruptcy Code.\n\n15. \"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, electronic communication, text message, social media post, tweet, meta-data, 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, 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, punchcards, 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 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 340 of 439\n\n16. \"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\n17. \"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 legal counsel, financial advisors, or any other representative.\n\n18. \"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\n19. \"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\n20. \"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,\n\n## Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 341 of 439\n\ntelexes, instant messages, chats, text messages, telephonic notes, or notes transmitted internally or with third parties.\n\n21. \"Asset(s)\" means any item that can be used to produce positive economic value, including but not limited to any resource with economic value that is owned, controlled or is for the benefit of an entity, that is expected to provide a future benefit, including but not limited to, all real and personal property, intangible property, investments, rights to invest or to future revenue, cash, bank accounts, commodities, securities, claims, total or partial control of an entity, and prospective economic opportunities\n\n22. \"Transfer\" shall have the meaning given to it by section 101(54) of the Bankruptcy Code.\n\n## **IV. DOCUMENTS TO BE PRODUCED**\n\n1. All Documents regarding any income or Asset of the Debtor, the Debtor's Family, the Debtor's estate, an Associated Individuals, or an Associated Entity.\n\n2. All Documents related to the Debtor's financial condition and obligations to his creditors, including without limitation all Documents related to any effort to avoid paying such obligations and All Documents related to this or any other actual or potential bankruptcy or similar insolvency proceeding.\n\n3. All Documents regarding any balance sheet, bank statement, account statement, financial statement, statement of account, wire transfer instructions and/or confirmation, proof of funds, certificate of deposit, certificate of holdings, investment portfolio summary, or similar document relating to the Debtor, the Debtor's Estate, the Debtor's Family, an Associated Entity, or an Associated Individual, including without limitation all Documents sufficient to show all Transfers to any of the foregoing.\n\n## Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 342 of 439\n\n4. All Documents regarding any investment, business dealings or transactions made by, with, or on behalf of the Debtor, the Debtor's Family, an Associated Individual, or an Associated Entity.\n\n5. All Communications with the Debtor, the Debtor's Family, an Associated Individual, or an Associated Entity, and Documents related to Communications with the Debtor, the Debtor's Family, an Associated Individual, or an Associated Entity, including related to the operation, management, or decision-making of any Entity, including without limitation the Associated Entities.\n\n6. All Documents regarding any Transfer, investment, or other transaction or business dealing made to, by, or with the Debtor, the Debtor's Family, an Associated Individual, or an Associated Entity.\n\n7. All Documents regarding any property ever occupied or used by the Debtor, including without limitation the residential property located in Greenwich, Connecticut at 373 Taconic Rd.; the residential property located in Greenwich, Connecticut at 33 Ferncliff Rd.; the residential property located in Wilton, Connecticut at 354 Nod Hill Rd; the apartments or condominiums located in 5 Princes Gate London, United Kingdom SW7 1QJ; and the residential property located in Mahwah, New Jersey at 675 Ramapo Valley Road, Mahwah, New Jersey 07430.\n\n8. All Documents related to any aircraft owned, controlled, or used by the Debtor, including without limitation (i) the aircraft bearing tail number T7-GQM and any other aircraft registered in San Marino, including without limitation copies of all registration documents and flight manifests showing flights taken by such aircraft and the individuals onboard such flights, and (ii) any Cirrus SF50 aircraft.\n\n## Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 343 of 439\n\n9. All Documents regarding any gifts, benefits or loans, to, from or on behalf of the Debtor, the Debtor's Estate, the Debtor's Family, or the Associated Entities, including without limitation Documents sufficient to show the amounts of such gifts, benefits, or loans; the purposes for which such gifts, benefits, or loans were used; when the gifts, benefits, or loans were provided; and the terms of any loans, all representations and warranties made in connection with any loans, the interest rate on any loans, and all evidence of payments of any loans.\n\n10. All Documents concerning any trust or similar instrument set up by, on behalf of, or for the benefit of the Debtor, the Debtor's Estate, the Debtor's Family, or an Associated Entity, including without limitation Documents sufficient to show when the trust(s) was created, by whom it was created, for whose benefit it was created, and the corpus of the trust.\n\n11. All Documents related to any obligation, claim, liability, or debt associated with any legal dispute involving the Debtor, including but not limited to those relating to any litigation before any local, state, federal, or international body, whether an administrative body, court, panel, or alternative dispute resolution entity.\n\n12. All Documents and communications with the Debtor, the Debtor's Family, or an Associated Individual.\n\n13. All Documents and communications between any of your counsel or other advisors and the Debtor, the Debtor's Family, or an Associated Individual.\n\n14. All Documents related to any Associated Entity that You hold or have held an interest in.\n\n# Exhibit C-18\n\n#### B2540 (Form 2540 – Subpoena for Rule 2004 Examination) (12/15) Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 345 of\n\n439\n\nUNITED STATES BANKRUPTCY COURT\n\n**District of Connecticut**\n\nIn re HO WAN KWOK, *et al*.,\n\n<sup>1</sup> Case No. 22-50073 (JAM) Debtor Chapter 11\n\n(Jointly Administered)\n\n# **SUBPOENA FOR RULE 2004 EXAMINATION**\n\nTo: **Andrea Volpe**\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/A   | N/A           |\n|       |               |\n\nThe examination will be recorded by this method: N/A\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\n## **See Requests for Production of Documents, attached hereto.**\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: **May , 2024**\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 Luc A. Despins, Chapter 11 Trustee, who issues or requests this subpoena, are:\n\n**Patrick R. Linsey, Esq.; Neubert, Pepe & Monteith, P.C.; 195 Church Street, 13th Floor, New Haven, Connecticut 06510 plinsey@npmlaw.com; (203) 781-2847**\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\nSoftware Copyright (c) 1996-2022 Best Case, LLC - www.bestcase.com Best Case Bankruptcy 1 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## **PROOF OF SERVICE**\n\n**(This section should not be filed with the court unless required by Fed. R. Civ. P. 45.)**\n\nI received this subpoena for (*name of individual and title, if any*): on (*date*) .\n\nI served the subpoena by delivering a copy to the named person as follows:\n\non *(date)* ; or\n\nI returned the subpoena unexecuted because:\n\nUnless the subpoena was issued on behalf of the United States, or one of its officers or agents, I have also tendered to the witness the fees for one day's attendance, and the mileage allowed by law, in the amount of \\$ .\n\nMy fees are \\$ for travel and \\$ for services, for a total of \\$ .\n\nI declare under penalty of perjury that this information is true and correct.\n\nDate:\n\n*Server's signature*\n\n*Printed name and title*\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;\n\n(ii) requires a person to comply beyond the geographical limits specified 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: (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 trial-preparation 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## **Requests 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\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 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 350 of 439\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 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 351 of 439\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 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 352 of 439\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 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 353 of 439\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).\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\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 Andrea Volpe, together with all of their agents, attorneys, representatives, employees, and/or anyone acting on their 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\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\n## Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 355 of 439\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, 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. \"Associated Individuals\" means individually and collectively, all individuals that (1) hold, control, have custody over, or discretion over assets owned, controlled, or enjoyed by the Debtor or the Debtor's Family; or (2) have been employees, directors, or otherwise are affiliated with one or more Associated Entities, together with the respective employees, agents, counsel, advisors, or anyone acting on behalf of any of the foregoing. Such Associated Individuals shall include, but are not limited to: Anthony DiBattista, Alex Hadjicharalambous, Bernardo Enriquez, Bingshang Jiao, Beile Li, Brian W. Hofmeister, Charles Gruder, Daniel Podhaskie, David Fallon, Defeng Cao (a/k/a Wayne Cao, Max Cao), Ding Lin, Dinggang Wang (a/k/a 王定刚), Eduardo Eurnekian, Ehsan Masud, Fiona Yu, Gladys Chow, Hao (Gavin) Li (a/k/a Huo Lai), Hao Haidong (a/k/a 郝海东), Han Chunguang (a/k/a 韩春光), Haoran He, Ivan Lin, Haitham Khaled, Jason Miller, Jennifer Mercurio, Jesse Brown, Jessica Mastrogiovanni, Jie Zhang, Jintao Li, Karin Maistrello, Kyle Bass, Lihong Wei Lafrenz (a/k/a Sara Wei, 魏丽红), Linwan \"Irene\" Feng, Max Krasner, Melissa Francis, Michael Baranowitz, Min Yang, Melissa Mendez, Nadeem Akbar, Nan Li (a/k/a Chris Lee, Mei Guo Xiao Li), Qidong Xia, Qu Guojiao (a/k/a Qu Guo Jiao, 屈国姣), Ridwan Mamode Saib, Ross Heinemeyer, Rui \"Ray\" Hao, Scott Barnett, Shih Hsin Yu, Shin Hee-Seup (a/k/a Hee Seup Shin), Steve Bannon, Talha Zobair, Victor Cerda, Wen Xiao, Wencong Wang, William Gertz, William Je (a/k/a Je Kin Ming, Yu Jianming, 余建明), and Xuebing Wang,\n\n## Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 356 of 439\n\nYa Li (a/k/a 李娅), Yinying (Aila) Wang (a/k/a Xiao Fei Xiang), Yongping Yan (Shan Mu), Yong Yu, Yue Zhou, Yumei Hao (a/k/a Ru Shui), Yvette Wang (a/k/a Yanping Wang, Yan Ping Wang, 王雁平), Zhang Wei (a/k/a 张魏), Zhouer Wang (a/k/a Joe Wang), Zhixuan Li, and Ziyang Liu.\n\n8. \"Associated Entities\" means, individually and collectively, all organizations or Entities of any type that (1) have been owned, controlled, or invested in by the Debtor or the Debtor's Family; or (2) have an interest, whether directly or indirectly, in any assets owned, controlled, or enjoyed by the Debtor or the Debtor's Family, together with the respective employees, agents, counsel, advisors, or anyone acting on behalf of any of the foregoing. Such Associated Entities shall include, but are not limited to: 1332156 B.C. Ltd., 7 Nod Hill LLC, AAGV Limited, ACA Investment Management Limited, ACA Capital Group Limited, Ace Decade Holdings Limited, AI Group Holdings Inc., Alfa Global Ventures Limited, Alfonso Global Limited, Allied Capital Global Limited, Alpine Fiduciaries SA, Beijing Pangu Investment Co., Beijing Pangu Investment Co. Ltd., Beijing Pangu Investment Inc., Beijing Zenith Holdings Company Limited, Blue Capital Limited, Booming Sail New York LLC, Bravo Luck Limited, Brent Petro, BSA Strategic Fund I, China Golden Spring (Hong Kong) Limited, Chuang Xin Limited, Crane Advisory Group LLC, Creative Apex Investments Limited, Crystal Breeze Investments Limited, Dawn State Limited, Eastern Profit Corporation Limited, Empire Growth Holdings, Elite Well Global Limited, Freedom Media Ventures Ltd., Fung Wan Trading Inc., G Club, G Club Operations LLC, G Club International Limited, G Club Investments Limited, G Fashion LLC, G-News Operations LLC, G News LLC, GMusic Inc., G-Services LLC, G-Translators PTY LTD, GETTR USA, Inc., Genever Holdings Corporation, Genever Holdings LLC, GFashion Media Group Inc., GFNY, Inc., Globalist International Limited, GNews Media Group Inc., Golden Spring (New York) Ltd., Guo Media, GTV Media Group, Inc., GWGOPNZ\n\n## Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 357 of 439\n\nLimited, GWGNZ Limited, Gypsy Mei Food Services, LLC, HCHK Property Management Inc., HCHK Technologies Inc., Hamilton Digital Assets FD SP, Hamilton Capital Holdings Inc., Hamilton Opportunity Fund SPC, Head Win Group Limited, Himalaya Embassy, Himalaya Exchange, Himalaya Federal Reserve, Himalaya International Financial Group Ltd., Himalaya Investment LLC, Himalaya (USA) Investment Management LLC, Himalaya New World Inc., Himalaya Supervisory Organization, Himalaya Ventures, Holy City Hong Kong Ventures, Ltd., Hudson Diamond Holding LLC, Hudson Diamond Holding Inc., Hudson Diamond NY LLC, HK International Funds Investments (USA) Limited LLC, Hong Kong International Funds Investments Limited, Huk Trading Inc, Infinite Increase Limited, Infinitum Developments Limited, Japan Himalaya League, Inc., Kalixun Trading Limited, Lamp Capital LLC, Leading Shine Limited, Leading Shine NY Limited, Lexington Property and Staffing Inc., Long Gate Limited, MOS Himalaya Foundation Inc., Maywind Trading LLC, New Federal State of China (a/k/a NFSC), New York MOS Himalaya LLC, New Mulberry PTE Ltd., Newpeople LLC, Noble Fame Global Limited, Pixshow Film Inc., Roscalitar 2, Rosy Acme Ventures Limited, Rule of Law Foundation III, Inc., Rule of Law Society, Rule of Law Society IV, Inc., Santel LLC, Saraca Media Group, Inc., Shiny Ace Ltd., Shiny Times Holdings Ltd., Stevenson, Wong & Co., Taurus Fund LLC, Taurus Fund SP, Taurus Management LLC, The Lost Draft LLC, TM Primrose Limited, UA Himalaya Inc., Voice of Guo Media, Inc., Well Origin Ltd., Wise Creation, Whitecroft Shore Limited, World Century Limited, Worldwide Opportunity Holdings Limited, and ZIBA Limited.\n\n9. \"Including\" or any variant thereof means \"including without limitation.\"\n\n10. \"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 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 358 of 439\n\n11. \"Any\" and \"all\" and \"each\" mean \"each and every.\"\n\n12. \"Each\" and \"every\" mean \"each and every.\"\n\n13. \"Third Party\" means a Person or Entity other than Yourself.\n\n14. \"Transfer\" shall have the meaning given to it by section 101(54) of the Bankruptcy Code.\n\n15. \"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, electronic communication, text message, social media post, tweet, meta-data, 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, 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, punchcards, 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 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 359 of 439\n\n16. \"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\n17. \"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 legal counsel, financial advisors, or any other representative.\n\n18. \"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\n19. \"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\n20. \"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,\n\n## Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 360 of 439\n\ntelexes, instant messages, chats, text messages, telephonic notes, or notes transmitted internally or with third parties.\n\n21. \"Asset(s)\" means any item that can be used to produce positive economic value, including but not limited to any resource with economic value that is owned, controlled or is for the benefit of an entity, that is expected to provide a future benefit, including but not limited to, all real and personal property, intangible property, investments, rights to invest or to future revenue, cash, bank accounts, commodities, securities, claims, total or partial control of an entity, and prospective economic opportunities\n\n22. \"Transfer\" shall have the meaning given to it by section 101(54) of the Bankruptcy Code.\n\n## **IV. DOCUMENTS TO BE PRODUCED**\n\n1. All Documents regarding any income or Asset of the Debtor, the Debtor's Family, the Debtor's estate, an Associated Individuals, or an Associated Entity.\n\n2. All Documents related to the Debtor's financial condition and obligations to his creditors, including without limitation all Documents related to any effort to avoid paying such obligations and All Documents related to this or any other actual or potential bankruptcy or similar insolvency proceeding.\n\n3. All Documents regarding any balance sheet, bank statement, account statement, financial statement, statement of account, wire transfer instructions and/or confirmation, proof of funds, certificate of deposit, certificate of holdings, investment portfolio summary, or similar document relating to the Debtor, the Debtor's Estate, the Debtor's Family, an Associated Entity, or an Associated Individual, including without limitation all Documents sufficient to show all Transfers to any of the foregoing.\n\n## Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 361 of 439\n\n4. All Documents regarding any investment, business dealings or transactions made by, with, or on behalf of the Debtor, the Debtor's Family, an Associated Individual, or an Associated Entity.\n\n5. All Communications with the Debtor, the Debtor's Family, an Associated Individual, or an Associated Entity, and Documents related to Communications with the Debtor, the Debtor's Family, an Associated Individual, or an Associated Entity, including related to the operation, management, or decision-making of any Entity, including without limitation the Associated Entities.\n\n6. All Documents regarding any Transfer, investment, or other transaction or business dealing made to, by, or with the Debtor, the Debtor's Family, an Associated Individual, or an Associated Entity.\n\n7. All Documents regarding any property ever occupied or used by the Debtor, including without limitation the residential property located in Greenwich, Connecticut at 373 Taconic Rd.; the residential property located in Greenwich, Connecticut at 33 Ferncliff Rd.; the residential property located in Wilton, Connecticut at 354 Nod Hill Rd; the apartments or condominiums located in 5 Princes Gate London, United Kingdom SW7 1QJ; and the residential property located in Mahwah, New Jersey at 675 Ramapo Valley Road, Mahwah, New Jersey 07430.\n\n8. All Documents related to any aircraft owned, controlled, or used by the Debtor, including without limitation (i) the aircraft bearing tail number T7-GQM and any other aircraft registered in San Marino, including without limitation copies of all registration documents and flight manifests showing flights taken by such aircraft and the individuals onboard such flights, and (ii) any Cirrus SF50 aircraft.\n\n## Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 362 of 439\n\n9. All Documents regarding any gifts, benefits or loans, to, from or on behalf of the Debtor, the Debtor's Estate, the Debtor's Family, or the Associated Entities, including without limitation Documents sufficient to show the amounts of such gifts, benefits, or loans; the purposes for which such gifts, benefits, or loans were used; when the gifts, benefits, or loans were provided; and the terms of any loans, all representations and warranties made in connection with any loans, the interest rate on any loans, and all evidence of payments of any loans.\n\n10. All Documents concerning any trust or similar instrument set up by, on behalf of, or for the benefit of the Debtor, the Debtor's Estate, the Debtor's Family, or an Associated Entity, including without limitation Documents sufficient to show when the trust(s) was created, by whom it was created, for whose benefit it was created, and the corpus of the trust.\n\n11. All Documents related to any obligation, claim, liability, or debt associated with any legal dispute involving the Debtor, including but not limited to those relating to any litigation before any local, state, federal, or international body, whether an administrative body, court, panel, or alternative dispute resolution entity.\n\n12. All Documents and communications with the Debtor, the Debtor's Family, or an Associated Individual.\n\n13. All Documents and communications between any of your counsel or other advisors and the Debtor, the Debtor's Family, or an Associated Individual.\n\n14. All Documents related to any Associated Entity that You hold or have held an interest in.\n\n# Exhibit C-19\n\n#### B2540 (Form 2540 – Subpoena for Rule 2004 Examination) (12/15) Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 364 of\n\n439\n\nUNITED STATES BANKRUPTCY COURT\n\n**District of Connecticut**\n\nIn re HO WAN KWOK, *et al*.,\n\n<sup>1</sup> Case No. 22-50073 (JAM) Debtor Chapter 11\n\n(Jointly Administered)\n\n# **SUBPOENA FOR RULE 2004 EXAMINATION**\n\nTo: **H.R. Owen PLC**\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/A   | N/A           |\n|       |               |\n\nThe examination will be recorded by this method: N/A\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\n## **See Requests for Production of Documents, attached hereto.**\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: **May , 2024**\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 Luc A. Despins, Chapter 11 Trustee, who issues or requests this subpoena, are:\n\n**Patrick R. Linsey, Esq.; Neubert, Pepe & Monteith, P.C.; 195 Church Street, 13th Floor, New Haven, Connecticut 06510 plinsey@npmlaw.com; (203) 781-2847**\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\nSoftware Copyright (c) 1996-2022 Best Case, LLC - www.bestcase.com Best Case Bankruptcy 1 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## **PROOF OF SERVICE**\n\n**(This section should not be filed with the court unless required by Fed. R. Civ. P. 45.)**\n\nI received this subpoena for (*name of individual and title, if any*): on (*date*) .\n\nI served the subpoena by delivering a copy to the named person as follows:\n\non *(date)* ; or\n\nI returned the subpoena unexecuted because:\n\nUnless the subpoena was issued on behalf of the United States, or one of its officers or agents, I have also tendered to the witness the fees for one day's attendance, and the mileage allowed by law, in the amount of \\$ .\n\nMy fees are \\$ for travel and \\$ for services, for a total of \\$ .\n\nI declare under penalty of perjury that this information is true and correct.\n\nDate:\n\n*Server's signature*\n\n*Printed name and title*\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;\n\n(ii) requires a person to comply beyond the geographical limits specified 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: (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 trial-preparation 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\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 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 369 of 439\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 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 370 of 439\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 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 371 of 439\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 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 372 of 439\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\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 H.R. Owen PLC, 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 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 374 of 439\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, 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. \"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\n8. \"Associated Individuals\" means individually and collectively, all individuals that (1) hold, control, have custody over, or discretion over assets owned, controlled, or enjoyed by the Debtor or the Debtor's Family; or (2) have been employees, directors, or otherwise are affiliated with one or more Associated Entities, together with the respective employees, agents, counsel, advisors, or anyone acting on behalf of any of the foregoing. Such Associated Individuals shall include, but are not limited to: Aaron Mitchell, Anthony DiBattista, Ana Izquierdo, Alex Hadjicharalambous, Bingshang Jiao, Beile Li, Brian W. Hofmeister, Charles Gruder, Daniel Podhaskie, David Fallon, Defeng Cao (a/k/a Wayne Cao, Max Cao), Ding Lin, Dinggang Wang (a/k/a 王定刚), Eduardo Eurnekian, Ehsan Masud, Fiona Yu, Gladys Chow, Haitham Khaled, Hao\n\n## Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 375 of 439\n\n(Gavin) Li (a/k/a Huo Lai), Hao Haidong (a/k/a 郝海东), Han Chunguang (a/k/a 韩春光), Haoran He, Ivan Lin, Haitham Khaled, Jason Miller, Jennifer Mercurio, Jesse Brown, Jessica Mastrogiovanni, Jie Zhang, Jintao Li, Karin Maistrello, Kyle Bass, Leanne Li, Lihong Wei Lafrenz (a/k/a Sara Wei, 魏丽红), Limarie Reyes Molinaris, Linwan \"Irene\" Feng, Max Krasner, Melissa Francis, Michael Baranowitz, Min Yang, Melissa Mendez, Nadeem Akbar, Nan Li (a/k/a Chris Lee, Mei Guo Xiao Li), Qidong Xia, Qu Guojiao (a/k/a Qu Guo Jiao, 屈国姣), Ridwan Mamode Saib, Ross Heinemeyer, Rui \"Ray\" Hao, Scott Barnett, Shih Hsin Yu, Shin Hee-Seup (a/k/a Hee Seup Shin), Steve Bannon, Talha Zobair, Victor Cerda, Wen Xiao, Wencong Wang, William Gertz, William Je (a/k/a Je Kin Ming, Yu Jianming, 余建明), and Xuebing Wang, Ya Li (a/k/a 李娅), Yinying (Aila) Wang (a/k/a Xiao Fei Xiang), Yongping Yan (Shan Mu), Yong Yu, Yue Zhou, Yumei Hao (a/k/a Ru Shui), Yvette Wang (a/k/a Yanping Wang, Yan Ping Wang, 王雁平 ), Zhang Wei (a/k/a 张魏), Zhouer Wang (a/k/a Joe Wang), Zhixuan Li, and Ziyang Liu.\n\n9. \"Associated Entities\" means, individually and collectively, all organizations or Entities of any type that (1) have been owned, controlled, or invested in by the Debtor or the Debtor's Family; or (2) have an interest, whether directly or indirectly, in any assets owned, controlled, or enjoyed by the Debtor or the Debtor's Family, together with the respective employees, agents, counsel, advisors, or anyone acting on behalf of any of the foregoing. Such Associated Entities shall include, but are not limited to: 1332156 B.C. Ltd., 7 Nod Hill LLC, AAGV Limited, ACA Investment Management Limited, ACA Capital Group Limited, Ace Decade Holdings Limited, AI Group Holdings Inc., Alfa Global Ventures Limited, Alfonso Global Limited, Allied Capital Global Limited, Alpine Fiduciaries SA, Anton Development Limited, Beijing Pangu Investment Co., Beijing Pangu Investment Co. Ltd., Beijing Pangu Investment Inc.,\n\n## Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 376 of 439\n\nBeijing Zenith Holdings Company Limited, Blue Capital Limited, Booming Sail New York LLC, Bravo Luck Limited, Brent Petro, BSA Strategic Fund I, China Golden Spring (Hong Kong) Limited, Chuang Xin Limited, Crane Advisory Group LLC, Creative Apex Investments Limited, Crystal Breeze Investments Limited, Dawn State Limited, Eastern Profit Corporation Limited, Empire Growth Holdings, Elite Well Global Limited, Freedom Media Ventures Ltd., Fung Wan Trading Inc., G Club, G Club Operations LLC, G Club International Limited, G Club Investments Limited, G Fashion LLC, G-News Operations LLC, G News LLC, GMusic Inc., G Music LLC, G-Services LLC, G-Translators PTY LTD, GETTR USA, Inc., Genever Holdings Corporation, Genever Holdings LLC,G Fashion, GFashion Media Group Inc., GF Italy, LLC, GFNY, Inc., Globalist International Limited, GNews Media Group Inc., Golden Spring (New York) Ltd., Greenwich Land, LLC, Guo Media, GTV Media Group, Inc., GWGOPNZ Limited, GWGNZ Limited, Gypsy Mei Food Services, LLC, HCHK Property Management Inc., HCHK Technologies Inc., Hamilton Digital Assets FD SP, Hamilton Capital Holdings Inc., Hamilton Opportunity Fund SPC, Head Win Group Limited, Himalaya Embassy, Himalaya Exchange, Himalaya Federal Reserve, Himalaya International Clearing Limited, Himalaya International Financial Group Ltd., Himalaya Investment LLC, Himalaya (USA) Investment Management LLC, Himalaya New World Inc., Himalaya Supervisory Organization, Himalaya Ventures, Holy City Hong Kong Ventures, Ltd., Hudson Diamond Holding LLC, Hudson Diamond Holding Inc., Hudson Diamond NY LLC, HK International Funds Investments (USA) Limited LLC, Hong Kong International Funds Investments Limited, Huk Trading Inc, Infinite Increase Limited, Infinitum Developments Limited, Japan Himalaya League, Inc., Kalixun Trading Limited, K Legacy Ltd., Lamp Capital LLC, Leading Shine Limited, Leading Shine NY Limited, Lexington Property and Staffing Inc., Long Gate Limited, MOS Himalaya Foundation Inc., Maywind Trading LLC, New\n\n## Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 377 of 439\n\nFederal State of China (a/k/a NFSC), Newpeople LLC, New Mulberry PTE Ltd., New York MOS Himalaya LLC, Next Tycoon Investments Limited, Noble Fame Global Limited, O.S.C. Orbit Service Company LLC, Pixshow Film Inc., Rising Sun Capital Ltd., Roscalitar 2, Rosy Acme Ventures Limited, Rule of Law Foundation III, Inc., Rule of Law Society, Rule of Law Society IV, Inc., Santel LLC, Saraca Media Group, Inc., Shiny Ace Ltd., Shiny Times Holdings Ltd., Stevenson, Wong & Co., Taurus Fund LLC, Taurus Fund SP, Taurus Management LLC, The Lost Draft LLC, TM Primrose Limited, UA Himalaya Inc., Voice of Guo Media, Inc., Well Origin Ltd., Wise Creation International Limited, Whitecroft Shore Limited, World Century Limited, Worldwide Opportunity Holdings Limited, and ZIBA Limited.\n\n10. \"And\" and \"or\" mean \"and/or,\" and shall be construed both conjunctively as well as disjunctively in order to maximize their scope.\n\n11. \"Any\" and \"all\" and \"each\" mean \"each and every.\"\n\n12. \"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 uploaded to any video platform, telephonic notes, or notes transmitted internally or with third parties.\n\n13. \"Each\" and \"every\" mean \"each and every.\"\n\n## Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 378 of 439\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\n14. \"G Club Entities\" means, collectively, G Club Operations LLC, G Club HoldCo I LLC, G Club International Ltd., G-Club Investments Limited, G Club International Ltd (BVI), G Club One, G Club Two, G Club Three, G Club US Operations Inc., and G Club US Operations LLC, together with all of their affiliates, divisions, agencies, instrumentalities, departments, offices, officers, directors, agents, managers, attorneys, representatives, employees, professionals, and/or anyone acting for or on their behalf.\n\n## Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 379 of 439\n\n15. \"Including\" or any variant thereof means \"including without limitation.\"\n\n16. \"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\n17. \"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\n18. \"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\n19. \"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\n20. \"Third Party\" means a Person or Entity other than Yourself.\n\n21. \"Transfer\" shall have the meaning given to it by section 101(54) of the Bankruptcy Code.\n\n22. \"Vehicle\" means any vehicle for traveling, including, without limitation, cars and motor vehicles, that are or were at any time owned, used, controlled, purchased, sold, leased, rented, licensed, serviced, maintained, repaired, overhauled, stored, operated, marketed, or\n\n## Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 380 of 439\n\ninspected by, to, or for the benefit of the Debtor, the Debtor's Family, an Associated Individual, or any Associated Entity.\n\n## **IV. DOCUMENTS TO BE PRODUCED**\n\n1. All Documents and Communications related to any Transfers to You from G Club International Limited or G Club Operations LLC, including without limitation a transfer of \\$832,000.75 on or around September 13, 2021.\n\n2. All Documents related to any income or Asset of the Debtor, the Debtor's estate, the Debtor's Family, an Associated Individual, or an Associated Entity, including without limitation the G Club Entities.\n\n3. All Documents related to any communications between You and the Debtor, the Debtor's estate, the Debtor's Family, an Associated Individual, or an Associated Entity, including without limitation the G Club Entities.\n\n4. All Documents related to the Debtor, the Debtor's estate, the Debtor's Family, an Associated Entity, or an Associated Individual (including without limitation the G Club Entities) related to any Vehicle, including without limitation (i) ownership or control of any Vehicle; (ii) use of any Vehicle; (iii) lease or rental of any Vehicle; (iv) the purchase, sale, or marketing of any Vehicle; (v) any money or value paid or given related to any Vehicle and the source thereof; (vi) any money or value generated or obtained related to any Vehicle and the disposition thereof; or (vii) operation, maintenance, service, or overhaul, related to any Vehicle.\n\n5. All Documents related to any account associated with the Debtor, the Debtor's estate, the Debtor's Family, an Associated Entity (including without limitation the G Club Entities), or an Associated Individual.\n\n## Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 381 of 439\n\n6. All Documents related to any invoices or payments of expenses related to the Debtor, the Debtor's estate, the Debtor's Family, an Associated Entity (including without limitation the G Club Entities), or an Associated Individual.\n\n7. All Documents related to the current location of an Vehicle related to the Debtor, the Debtor's estate, the Debtor's Family, an Associated Entity (including without limitation the G Club Entities), or an Associated Individual.\n\nCase 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 382 of 439\n\n# Exhibit C-20\n\nB2540 (Form 2540 – Subpoena for Rule 2004 Examination) (12/15) Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 383 of\n\nUNITED STATES BANKRUPTCY COURT 439\n\n**District of Connecticut**\n\nIn re HO WAN KWOK, *et al*.,\n\n<sup>1</sup> Case No. 22-50073 (JAM)\n\nDebtor Chapter 11\n\n(Jointly Administered)\n\n# **SUBPOENA FOR RULE 2004 EXAMINATION**\n\nTo: **Headwater Service, 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/A   | N/A           |\n|       |               |\n\nThe examination will be recorded by this method: N/A\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\n## **See Requests for Production of Documents, attached hereto.**\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: **May , 2024**\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 Luc A. Despins, Chapter 11 Trustee, who issues or requests this subpoena, are:\n\n**Patrick R. Linsey, Esq.; Neubert, Pepe & Monteith, P.C.; 195 Church Street, 13th Floor, New Haven, Connecticut 06510 plinsey@npmlaw.com; (203) 781-2847**\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\nSoftware Copyright (c) 1996-2022 Best Case, LLC - www.bestcase.com Best Case Bankruptcy 1 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## **PROOF OF SERVICE**\n\n**(This section should not be filed with the court unless required by Fed. R. Civ. P. 45.)**\n\nI received this subpoena for (*name of individual and title, if any*): on (*date*) .\n\nI served the subpoena by delivering a copy to the named person as follows:\n\non *(date)* ; or\n\nI returned the subpoena unexecuted because:\n\nUnless the subpoena was issued on behalf of the United States, or one of its officers or agents, I have also tendered to the witness the fees for one day's attendance, and the mileage allowed by law, in the amount of \\$ .\n\nMy fees are \\$ for travel and \\$ for services, for a total of \\$ .\n\nI declare under penalty of perjury that this information is true and correct.\n\nDate:\n\n*Server's signature*\n\n*Printed name and title*\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;\n\n(ii) requires a person to comply beyond the geographical limits specified 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: (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 trial-preparation 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\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 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 388 of 439\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 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 389 of 439\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 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 390 of 439\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 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 391 of 439\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\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 Headwater Service, LLC, 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 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 393 of 439\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, 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. \"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\n8. \"Associated Individuals\" means individually and collectively, all individuals that (1) hold, control, have custody over, or discretion over assets owned, controlled, or enjoyed by the Debtor or the Debtor's Family; or (2) have been employees, directors, or otherwise are affiliated with one or more Associated Entities, together with the respective employees, agents, counsel, advisors, or anyone acting on behalf of any of the foregoing. Such Associated Individuals shall include, but are not limited to: Aaron Mitchell, Anthony DiBattista, Ana Izquierdo, Alex\n\n## Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 394 of 439\n\nHadjicharalambous, Bingshang Jiao, Beile Li, Brian W. Hofmeister, Charles Gruder, Daniel Podhaskie, David Fallon, Defeng Cao (a/k/a Wayne Cao, Max Cao), Ding Lin, Dinggang Wang (a/k/a 王定刚), Eduardo Eurnekian, Ehsan Masud, Fiona Yu, Gladys Chow, Haitham Khaled, Hao (Gavin) Li (a/k/a Huo Lai), Hao Haidong (a/k/a 郝海东), Han Chunguang (a/k/a 韩春光), Haoran He, Ivan Lin, Haitham Khaled, Jason Miller, Jennifer Mercurio, Jesse Brown, Jessica Mastrogiovanni, Jie Zhang, Jintao Li, Karin Maistrello, Kyle Bass, Leanne Li, Lihong Wei Lafrenz (a/k/a Sara Wei, 魏丽红), Limarie Reyes Molinaris, Linwan \"Irene\" Feng, Max Krasner, Melissa Francis, Michael Baranowitz, Min Yang, Melissa Mendez, Nadeem Akbar, Nan Li (a/k/a Chris Lee, Mei Guo Xiao Li), Qidong Xia, Qu Guojiao (a/k/a Qu Guo Jiao, 屈国姣), Ridwan Mamode Saib, Ross Heinemeyer, Rui \"Ray\" Hao, Scott Barnett, Shih Hsin Yu, Shin Hee-Seup (a/k/a Hee Seup Shin), Steve Bannon, Talha Zobair, Victor Cerda, Wen Xiao, Wencong Wang, William Gertz, William Je (a/k/a Je Kin Ming, Yu Jianming, 余建明), and Xuebing Wang, Ya Li (a/k/a 李娅), Yinying (Aila) Wang (a/k/a Xiao Fei Xiang), Yongping Yan (Shan Mu), Yong Yu, Yue Zhou, Yumei Hao (a/k/a Ru Shui), Yvette Wang (a/k/a Yanping Wang, Yan Ping Wang, 王雁平 ), Zhang Wei (a/k/a 张魏), Zhouer Wang (a/k/a Joe Wang), Zhixuan Li, and Ziyang Liu.\n\n9. \"Associated Entities\" means, individually and collectively, all organizations or Entities of any type that (1) have been owned, controlled, or invested in by the Debtor or the Debtor's Family; or (2) have an interest, whether directly or indirectly, in any assets owned, controlled, or enjoyed by the Debtor or the Debtor's Family, together with the respective employees, agents, counsel, advisors, or anyone acting on behalf of any of the foregoing. Such Associated Entities shall include, but are not limited to: 1332156 B.C. Ltd., 7 Nod Hill LLC, AAGV Limited, ACA Investment Management Limited, ACA Capital Group Limited, Ace\n\n## Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 395 of 439\n\nDecade Holdings Limited, AI Group Holdings Inc., Alfa Global Ventures Limited, Alfonso Global Limited, Allied Capital Global Limited, Alpine Fiduciaries SA, Anton Development Limited, Beijing Pangu Investment Co., Beijing Pangu Investment Co. Ltd., Beijing Pangu Investment Inc., Beijing Zenith Holdings Company Limited, Blue Capital Limited, Booming Sail New York LLC, Bravo Luck Limited, Brent Petro, BSA Strategic Fund I, China Golden Spring (Hong Kong) Limited, Chuang Xin Limited, Crane Advisory Group LLC, Creative Apex Investments Limited, Crystal Breeze Investments Limited, Dawn State Limited, Eastern Profit Corporation Limited, Empire Growth Holdings, Elite Well Global Limited, Freedom Media Ventures Ltd., Fung Wan Trading Inc., G Club, G Club Operations LLC, G Club International Limited, G Club Investments Limited, G Fashion LLC, G-News Operations LLC, G News LLC, GMusic Inc., G Music LLC, G-Services LLC, G-Translators PTY LTD, GETTR USA, Inc., Genever Holdings Corporation, Genever Holdings LLC,G Fashion, GFashion Media Group Inc., GF Italy, LLC, GFNY, Inc., Globalist International Limited, GNews Media Group Inc., Golden Spring (New York) Ltd., Greenwich Land, LLC, Guo Media, GTV Media Group, Inc., GWGOPNZ Limited, GWGNZ Limited, Gypsy Mei Food Services, LLC, HCHK Property Management Inc., HCHK Technologies Inc., Hamilton Digital Assets FD SP, Hamilton Capital Holdings Inc., Hamilton Opportunity Fund SPC, Head Win Group Limited, Himalaya Embassy, Himalaya Exchange, Himalaya Federal Reserve, Himalaya International Clearing Limited, Himalaya International Financial Group Ltd., Himalaya Investment LLC, Himalaya (USA) Investment Management LLC, Himalaya New World Inc., Himalaya Supervisory Organization, Himalaya Ventures, Holy City Hong Kong Ventures, Ltd., Hudson Diamond Holding LLC, Hudson Diamond Holding Inc., Hudson Diamond NY LLC, HK International Funds Investments (USA) Limited LLC, Hong Kong International Funds Investments Limited, Huk Trading Inc, Infinite Increase Limited, Infinitum\n\n## Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 396 of 439\n\nDevelopments Limited, Japan Himalaya League, Inc., Kalixun Trading Limited, K Legacy Ltd., Lamp Capital LLC, Leading Shine Limited, Leading Shine NY Limited, Lexington Property and Staffing Inc., Long Gate Limited, MOS Himalaya Foundation Inc., Maywind Trading LLC, New Federal State of China (a/k/a NFSC), Newpeople LLC, New Mulberry PTE Ltd., New York MOS Himalaya LLC, Next Tycoon Investments Limited, Noble Fame Global Limited, O.S.C. Orbit Service Company LLC, Pixshow Film Inc., Rising Sun Capital Ltd., Roscalitar 2, Rosy Acme Ventures Limited, Rule of Law Foundation III, Inc., Rule of Law Society, Rule of Law Society IV, Inc., Santel LLC, Saraca Media Group, Inc., Shiny Ace Ltd., Shiny Times Holdings Ltd., Stevenson, Wong & Co., Taurus Fund LLC, Taurus Fund SP, Taurus Management LLC, The Lost Draft LLC, TM Primrose Limited, UA Himalaya Inc., Voice of Guo Media, Inc., Well Origin Ltd., Wise Creation International Limited, Whitecroft Shore Limited, World Century Limited, Worldwide Opportunity Holdings Limited, and ZIBA Limited.\n\n10. \"And\" and \"or\" mean \"and/or,\" and shall be construed both conjunctively as well as disjunctively in order to maximize their scope.\n\n11. \"Any\" and \"all\" and \"each\" mean \"each and every.\"\n\n12. \"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 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 397 of 439\n\nuploaded to any video platform, telephonic notes, or notes transmitted internally or with third parties.\n\n13. \"Each\" and \"every\" mean \"each and every.\"\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\n14. \"G Club Entities\" means, collectively, G Club Operations LLC, G Club HoldCo I LLC, G Club International Ltd., G-Club Investments Limited, G Club International Ltd (BVI), G Club One, G Club Two, G Club Three, G Club US Operations Inc., and G Club US Operations\n\n## Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 398 of 439\n\nLLC, together with all of their affiliates, divisions, agencies, instrumentalities, departments, offices, officers, directors, agents, managers, attorneys, representatives, employees, professionals, and/or anyone acting for or on their behalf.\n\n15. \"Including\" or any variant thereof means \"including without limitation.\"\n\n16. \"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\n17. \"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\n18. \"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\n19. \"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\n20. \"Third Party\" means a Person or Entity other than Yourself.\n\n21. \"Transfer\" shall have the meaning given to it by section 101(54) of the Bankruptcy Code.\n\n## Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 399 of 439\n\n22. \"Vehicle\" means any vehicle for traveling, including, without limitation, cars and motor vehicles, that are or were at any time owned, used, controlled, purchased, sold, leased, rented, licensed, serviced, maintained, repaired, overhauled, stored, operated, marketed, or inspected by, to, or for the benefit of the Debtor, the Debtor's Family, an Associated Individual, or any Associated Entity.\n\n## **IV. DOCUMENTS TO BE PRODUCED**\n\n1. All Documents and Communications related to any Transfers to You from G Club International Limited or G Club Operations LLC, including without limitation a transfer of \\$832,000.75 on or around September 13, 2021.\n\n2. All Documents related to any income or Asset of the Debtor, the Debtor's estate, the Debtor's Family, an Associated Individual, or an Associated Entity, including without limitation the G Club Entities.\n\n3. All Documents related to any communications between You and the Debtor, the Debtor's estate, the Debtor's Family, an Associated Individual, or an Associated Entity, including without limitation the G Club Entities.\n\n4. All Documents related to the Debtor, the Debtor's estate, the Debtor's Family, an Associated Entity, or an Associated Individual (including without limitation the G Club Entities) related to any Vehicle, including without limitation (i) ownership or control of any Vehicle; (ii) use of any Vehicle; (iii) lease or rental of any Vehicle; (iv) the purchase, sale, or marketing of any Vehicle; (v) any money or value paid or given related to any Vehicle and the source thereof; (vi) any money or value generated or obtained related to any Vehicle and the disposition thereof; or (vii) operation, maintenance, service, or overhaul, related to any Vehicle.\n\n## Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 400 of 439\n\n5. All Documents related to any account associated with the Debtor, the Debtor's estate, the Debtor's Family, an Associated Entity (including without limitation the G Club Entities), or an Associated Individual.\n\n6. All Documents related to any invoices or payments of expenses related to the Debtor, the Debtor's estate, the Debtor's Family, an Associated Entity (including without limitation the G Club Entities), or an Associated Individual.\n\n7. All Documents related to the current location of an Vehicle related to the Debtor, the Debtor's estate, the Debtor's Family, an Associated Entity (including without limitation the G Club Entities), or an Associated Individual.\n\n# Exhibit C-21\n\nB2540 (Form 2540 – Subpoena for Rule 2004 Examination) (12/15) Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 402 of\n\nUNITED STATES BANKRUPTCY COURT 439\n\n**District of Connecticut**\n\nIn re HO WAN KWOK, *et al*.,\n\n<sup>1</sup> Case No. 22-50073 (JAM)\n\nDebtor Chapter 11\n\n(Jointly Administered)\n\n## **SUBPOENA FOR RULE 2004 EXAMINATION**\n\nTo: **RM Sotheby's and/or RM Auctions 2022**\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/A   | N/A           |\n|       |               |\n\nThe examination will be recorded by this method: N/A\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\n## **See Requests for Production of Documents, attached hereto.**\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: **May , 2024**\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 Luc A. Despins, Chapter 11 Trustee, who issues or requests this subpoena, are:\n\n**Patrick R. Linsey, Esq.; Neubert, Pepe & Monteith, P.C.; 195 Church Street, 13th Floor, New Haven, Connecticut 06510 plinsey@npmlaw.com; (203) 781-2847**\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\nSoftware Copyright (c) 1996-2022 Best Case, LLC - www.bestcase.com Best Case Bankruptcy 1 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## **PROOF OF SERVICE**\n\n**(This section should not be filed with the court unless required by Fed. R. Civ. P. 45.)**\n\nI received this subpoena for (*name of individual and title, if any*): on (*date*) .\n\nI served the subpoena by delivering a copy to the named person as follows:\n\non *(date)* ; or\n\nI returned the subpoena unexecuted because:\n\nUnless the subpoena was issued on behalf of the United States, or one of its officers or agents, I have also tendered to the witness the fees for one day's attendance, and the mileage allowed by law, in the amount of \\$ .\n\nMy fees are \\$ for travel and \\$ for services, for a total of \\$ .\n\nI declare under penalty of perjury that this information is true and correct.\n\nDate:\n\n*Server's signature*\n\n*Printed name and title*\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;\n\n(ii) requires a person to comply beyond the geographical limits specified 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: (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 trial-preparation 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\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 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 407 of 439\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 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 408 of 439\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 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 409 of 439\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 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 410 of 439\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\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 RM Sotheby's and/or RM Auctions 2022, 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 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 412 of 439\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, 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. \"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\n8. \"Associated Individuals\" means individually and collectively, all individuals that (1) hold, control, have custody over, or discretion over assets owned, controlled, or enjoyed by the Debtor or the Debtor's Family; or (2) have been employees, directors, or otherwise are affiliated with one or more Associated Entities, together with the respective employees, agents, counsel, advisors, or anyone acting on behalf of any of the foregoing. Such Associated Individuals shall include, but are not limited to: Aaron Mitchell, Anthony DiBattista, Ana Izquierdo, Alex\n\n## Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 413 of 439\n\nHadjicharalambous, Bingshang Jiao, Beile Li, Brian W. Hofmeister, Charles Gruder, Daniel Podhaskie, David Fallon, Defeng Cao (a/k/a Wayne Cao, Max Cao), Ding Lin, Dinggang Wang (a/k/a 王定刚), Eduardo Eurnekian, Ehsan Masud, Fiona Yu, Gladys Chow, Haitham Khaled, Hao (Gavin) Li (a/k/a Huo Lai), Hao Haidong (a/k/a 郝海东), Han Chunguang (a/k/a 韩春光), Haoran He, Ivan Lin, Haitham Khaled, Jason Miller, Jennifer Mercurio, Jesse Brown, Jessica Mastrogiovanni, Jie Zhang, Jintao Li, Karin Maistrello, Kyle Bass, Leanne Li, Lihong Wei Lafrenz (a/k/a Sara Wei, 魏丽红), Limarie Reyes Molinaris, Linwan \"Irene\" Feng, Max Krasner, Melissa Francis, Michael Baranowitz, Min Yang, Melissa Mendez, Nadeem Akbar, Nan Li (a/k/a Chris Lee, Mei Guo Xiao Li), Qidong Xia, Qu Guojiao (a/k/a Qu Guo Jiao, 屈国姣), Ridwan Mamode Saib, Ross Heinemeyer, Rui \"Ray\" Hao, Scott Barnett, Shih Hsin Yu, Shin Hee-Seup (a/k/a Hee Seup Shin), Steve Bannon, Talha Zobair, Victor Cerda, Wen Xiao, Wencong Wang, William Gertz, William Je (a/k/a Je Kin Ming, Yu Jianming, 余建明), and Xuebing Wang, Ya Li (a/k/a 李娅), Yinying (Aila) Wang (a/k/a Xiao Fei Xiang), Yongping Yan (Shan Mu), Yong Yu, Yue Zhou, Yumei Hao (a/k/a Ru Shui), Yvette Wang (a/k/a Yanping Wang, Yan Ping Wang, 王雁平 ), Zhang Wei (a/k/a 张魏), Zhouer Wang (a/k/a Joe Wang), Zhixuan Li, and Ziyang Liu.\n\n9. \"Associated Entities\" means, individually and collectively, all organizations or Entities of any type that (1) have been owned, controlled, or invested in by the Debtor or the Debtor's Family; or (2) have an interest, whether directly or indirectly, in any assets owned, controlled, or enjoyed by the Debtor or the Debtor's Family, together with the respective employees, agents, counsel, advisors, or anyone acting on behalf of any of the foregoing. Such Associated Entities shall include, but are not limited to: 1332156 B.C. Ltd., 7 Nod Hill LLC, AAGV Limited, ACA Investment Management Limited, ACA Capital Group Limited, Ace\n\n## Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 414 of 439\n\nDecade Holdings Limited, AI Group Holdings Inc., Alfa Global Ventures Limited, Alfonso Global Limited, Allied Capital Global Limited, Alpine Fiduciaries SA, Anton Development Limited, Beijing Pangu Investment Co., Beijing Pangu Investment Co. Ltd., Beijing Pangu Investment Inc., Beijing Zenith Holdings Company Limited, Blue Capital Limited, Booming Sail New York LLC, Bravo Luck Limited, Brent Petro, BSA Strategic Fund I, China Golden Spring (Hong Kong) Limited, Chuang Xin Limited, Crane Advisory Group LLC, Creative Apex Investments Limited, Crystal Breeze Investments Limited, Dawn State Limited, Eastern Profit Corporation Limited, Empire Growth Holdings, Elite Well Global Limited, Freedom Media Ventures Ltd., Fung Wan Trading Inc., G Club, G Club Operations LLC, G Club International Limited, G Club Investments Limited, G Fashion LLC, G-News Operations LLC, G News LLC, GMusic Inc., G Music LLC, G-Services LLC, G-Translators PTY LTD, GETTR USA, Inc., Genever Holdings Corporation, Genever Holdings LLC,G Fashion, GFashion Media Group Inc., GF Italy, LLC, GFNY, Inc., Globalist International Limited, GNews Media Group Inc., Golden Spring (New York) Ltd., Greenwich Land, LLC, Guo Media, GTV Media Group, Inc., GWGOPNZ Limited, GWGNZ Limited, Gypsy Mei Food Services, LLC, HCHK Property Management Inc., HCHK Technologies Inc., Hamilton Digital Assets FD SP, Hamilton Capital Holdings Inc., Hamilton Opportunity Fund SPC, Head Win Group Limited, Himalaya Embassy, Himalaya Exchange, Himalaya Federal Reserve, Himalaya International Clearing Limited, Himalaya International Financial Group Ltd., Himalaya Investment LLC, Himalaya (USA) Investment Management LLC, Himalaya New World Inc., Himalaya Supervisory Organization, Himalaya Ventures, Holy City Hong Kong Ventures, Ltd., Hudson Diamond Holding LLC, Hudson Diamond Holding Inc., Hudson Diamond NY LLC, HK International Funds Investments (USA) Limited LLC, Hong Kong International Funds Investments Limited, Huk Trading Inc, Infinite Increase Limited, Infinitum\n\n## Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 415 of 439\n\nDevelopments Limited, Japan Himalaya League, Inc., Kalixun Trading Limited, K Legacy Ltd., Lamp Capital LLC, Leading Shine Limited, Leading Shine NY Limited, Lexington Property and Staffing Inc., Long Gate Limited, MOS Himalaya Foundation Inc., Maywind Trading LLC, New Federal State of China (a/k/a NFSC), Newpeople LLC, New Mulberry PTE Ltd., New York MOS Himalaya LLC, Next Tycoon Investments Limited, Noble Fame Global Limited, O.S.C. Orbit Service Company LLC, Pixshow Film Inc., Rising Sun Capital Ltd., Roscalitar 2, Rosy Acme Ventures Limited, Rule of Law Foundation III, Inc., Rule of Law Society, Rule of Law Society IV, Inc., Santel LLC, Saraca Media Group, Inc., Shiny Ace Ltd., Shiny Times Holdings Ltd., Stevenson, Wong & Co., Taurus Fund LLC, Taurus Fund SP, Taurus Management LLC, The Lost Draft LLC, TM Primrose Limited, UA Himalaya Inc., Voice of Guo Media, Inc., Well Origin Ltd., Wise Creation International Limited, Whitecroft Shore Limited, World Century Limited, Worldwide Opportunity Holdings Limited, and ZIBA Limited.\n\n10. \"And\" and \"or\" mean \"and/or,\" and shall be construed both conjunctively as well as disjunctively in order to maximize their scope.\n\n11. \"Any\" and \"all\" and \"each\" mean \"each and every.\"\n\n12. \"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 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 416 of 439\n\nuploaded to any video platform, telephonic notes, or notes transmitted internally or with third parties.\n\n13. \"Each\" and \"every\" mean \"each and every.\"\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\n14. \"G Club Entities\" means, collectively, G Club Operations LLC, G Club HoldCo I LLC, G Club International Ltd., G-Club Investments Limited, G Club International Ltd (BVI), G Club One, G Club Two, G Club Three, G Club US Operations Inc., and G Club US Operations\n\n## Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 417 of 439\n\nLLC, together with all of their affiliates, divisions, agencies, instrumentalities, departments, offices, officers, directors, agents, managers, attorneys, representatives, employees, professionals, and/or anyone acting for or on their behalf.\n\n15. \"Including\" or any variant thereof means \"including without limitation.\"\n\n16. \"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\n17. \"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\n18. \"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\n19. \"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\n20. \"Third Party\" means a Person or Entity other than Yourself.\n\n21. \"Transfer\" shall have the meaning given to it by section 101(54) of the Bankruptcy Code.\n\n## Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 418 of 439\n\n22. \"Vehicle\" means any vehicle for traveling, including, without limitation, cars and motor vehicles, that are or were at any time owned, used, controlled, purchased, sold, leased, rented, licensed, serviced, maintained, repaired, overhauled, stored, operated, marketed, or inspected by, to, or for the benefit of the Debtor, the Debtor's Family, an Associated Individual, or any Associated Entity.\n\n## **IV. DOCUMENTS TO BE PRODUCED**\n\n1. All Documents and Communications related to any Transfers to You from G Club International Limited or G Club Operations LLC, including without limitation a transfer of \\$832,000.75 on or around September 13, 2021.\n\n2. All Documents related to any income or Asset of the Debtor, the Debtor's estate, the Debtor's Family, an Associated Individual, or an Associated Entity, including without limitation the G Club Entities.\n\n3. All Documents related to any communications between You and the Debtor, the Debtor's estate, the Debtor's Family, an Associated Individual, or an Associated Entity, including without limitation the G Club Entities.\n\n4. All Documents related to the Debtor, the Debtor's estate, the Debtor's Family, an Associated Entity, or an Associated Individual (including without limitation the G Club Entities) related to any Vehicle, including without limitation (i) ownership or control of any Vehicle; (ii) use of any Vehicle; (iii) lease or rental of any Vehicle; (iv) the purchase, sale, or marketing of any Vehicle; (v) any money or value paid or given related to any Vehicle and the source thereof; (vi) any money or value generated or obtained related to any Vehicle and the disposition thereof; or (vii) operation, maintenance, service, or overhaul, related to any Vehicle.\n\n## Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 419 of 439\n\n5. All Documents related to any account associated with the Debtor, the Debtor's estate, the Debtor's Family, an Associated Entity (including without limitation the G Club Entities), or an Associated Individual.\n\n6. All Documents related to any invoices or payments of expenses related to the Debtor, the Debtor's estate, the Debtor's Family, an Associated Entity (including without limitation the G Club Entities), or an Associated Individual.\n\n7. All Documents related to the current location of an Vehicle related to the Debtor, the Debtor's estate, the Debtor's Family, an Associated Entity (including without limitation the G Club Entities), or an Associated Individual.\n\nCase 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 420 of 439\n\n# Exhibit C-22\n\n#### B2540 (Form 2540 – Subpoena for Rule 2004 Examination) (12/15) Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 421 of\n\n439\n\nUNITED STATES BANKRUPTCY COURT\n\n**District of Connecticut**\n\nIn re HO WAN KWOK, *et al*.,\n\n<sup>1</sup> Case No. 22-50073 (JAM) Debtor Chapter 11\n\n(Jointly Administered)\n\n# **SUBPOENA FOR RULE 2004 EXAMINATION**\n\nTo: **Dean M. Rabideau**\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/A   | N/A           |\n|       |               |\n\nThe examination will be recorded by this method: N/A\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\n## **See Requests for Production of Documents, attached hereto.**\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: **May , 2024**\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 Luc A. Despins, Chapter 11 Trustee, who issues or requests this subpoena, are:\n\n**Patrick R. Linsey, Esq.; Neubert, Pepe & Monteith, P.C.; 195 Church Street, 13th Floor, New Haven, Connecticut 06510 plinsey@npmlaw.com; (203) 781-2847**\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\nSoftware Copyright (c) 1996-2022 Best Case, LLC - www.bestcase.com Best Case Bankruptcy 1 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## **PROOF OF SERVICE**\n\n**(This section should not be filed with the court unless required by Fed. R. Civ. P. 45.)**\n\nI received this subpoena for (*name of individual and title, if any*): on (*date*) .\n\nI served the subpoena by delivering a copy to the named person as follows:\n\non *(date)* ; or\n\nI returned the subpoena unexecuted because:\n\nUnless the subpoena was issued on behalf of the United States, or one of its officers or agents, I have also tendered to the witness the fees for one day's attendance, and the mileage allowed by law, in the amount of \\$ .\n\nMy fees are \\$ for travel and \\$ for services, for a total of \\$ .\n\nI declare under penalty of perjury that this information is true and correct.\n\nDate:\n\n*Server's signature*\n\n*Printed name and title*\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;\n\n(ii) requires a person to comply beyond the geographical limits specified 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: (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 trial-preparation 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## **Requests 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\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| 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 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 427 of 439\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 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 428 of 439\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 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 429 of 439\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).\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\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 Dean M. Rabideau, together with all of their agents, attorneys, representatives, employees, and/or anyone acting on their 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\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\n## Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 431 of 439\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, 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. \"Associated Individuals\" means individually and collectively, all individuals that (1) hold, control, have custody over, or discretion over assets owned, controlled, or enjoyed by the Debtor or the Debtor's Family; or (2) have been employees, directors, or otherwise are affiliated with one or more Associated Entities, together with the respective employees, agents, counsel, advisors, or anyone acting on behalf of any of the foregoing. Such Associated Individuals shall include, but are not limited to: Anthony DiBattista, Alex Hadjicharalambous, Bernardo Enriquez, Bingshang Jiao, Beile Li, Brian W. Hofmeister, Charles Gruder, Daniel Podhaskie, David Fallon, Defeng Cao (a/k/a Wayne Cao, Max Cao), Ding Lin, Dinggang Wang (a/k/a 王定刚), Eduardo Eurnekian, Ehsan Masud, Fiona Yu, Gladys Chow, Hao (Gavin) Li (a/k/a Huo Lai), Hao Haidong (a/k/a 郝海东), Han Chunguang (a/k/a 韩春光), Haoran He, Ivan Lin, Haitham Khaled, Jason Miller, Jennifer Mercurio, Jesse Brown, Jessica Mastrogiovanni, Jie Zhang, Jintao Li, Karin Maistrello, Kyle Bass, Lihong Wei Lafrenz (a/k/a Sara Wei, 魏丽红), Linwan \"Irene\" Feng, Max Krasner, Melissa Francis, Michael Baranowitz, Min Yang, Melissa Mendez, Nadeem Akbar, Nan Li (a/k/a Chris Lee, Mei Guo Xiao Li), Qidong Xia, Qu Guojiao (a/k/a Qu Guo Jiao, 屈国姣), Ridwan Mamode Saib, Ross Heinemeyer, Rui \"Ray\" Hao, Scott Barnett, Shih Hsin Yu, Shin Hee-\n\n## Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 432 of 439\n\nSeup (a/k/a Hee Seup Shin), Steve Bannon, Talha Zobair, Victor Cerda, Wen Xiao, Wencong Wang, William Gertz, William Je (a/k/a Je Kin Ming, Yu Jianming, 余建明), and Xuebing Wang, Ya Li (a/k/a 李娅), Yinying (Aila) Wang (a/k/a Xiao Fei Xiang), Yongping Yan (Shan Mu), Yong Yu, Yue Zhou, Yumei Hao (a/k/a Ru Shui), Yvette Wang (a/k/a Yanping Wang, Yan Ping Wang, 王雁平), Zhang Wei (a/k/a 张魏), Zhouer Wang (a/k/a Joe Wang), Zhixuan Li, and Ziyang Liu.\n\n8. \"Associated Entities\" means, individually and collectively, all organizations or Entities of any type that (1) have been owned, controlled, or invested in by the Debtor or the Debtor's Family; or (2) have an interest, whether directly or indirectly, in any assets owned, controlled, or enjoyed by the Debtor or the Debtor's Family, together with the respective employees, agents, counsel, advisors, or anyone acting on behalf of any of the foregoing. Such Associated Entities shall include, but are not limited to: 1332156 B.C. Ltd., 7 Nod Hill LLC, AAGV Limited, ACA Investment Management Limited, ACA Capital Group Limited, Ace Decade Holdings Limited, AI Group Holdings Inc., Alfa Global Ventures Limited, Alfonso Global Limited, Allied Capital Global Limited, Alpine Fiduciaries SA, Beijing Pangu Investment Co., Beijing Pangu Investment Co. Ltd., Beijing Pangu Investment Inc., Beijing Zenith Holdings Company Limited, Blue Capital Limited, Booming Sail New York LLC, Bravo Luck Limited, Brent Petro, BSA Strategic Fund I, China Golden Spring (Hong Kong) Limited, Chuang Xin Limited, Crane Advisory Group LLC, Creative Apex Investments Limited, Crystal Breeze Investments Limited, Dawn State Limited, Eastern Profit Corporation Limited, Empire Growth Holdings, Elite Well Global Limited, Freedom Media Ventures Ltd., Fung Wan Trading Inc., G Club, G Club Operations LLC, G Club International Limited, G Club Investments Limited, G Fashion LLC, G-News Operations LLC, G News LLC, GMusic Inc., G-Services LLC, G-Translators PTY LTD, GETTR USA, Inc., Genever Holdings Corporation, Genever Holdings\n\n## Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 433 of 439\n\nLLC, GFashion Media Group Inc., GFNY, Inc., Globalist International Limited, GNews Media Group Inc., Golden Spring (New York) Ltd., Guo Media, GTV Media Group, Inc., GWGOPNZ Limited, GWGNZ Limited, Gypsy Mei Food Services, LLC, HCHK Property Management Inc., HCHK Technologies Inc., Hamilton Digital Assets FD SP, Hamilton Capital Holdings Inc., Hamilton Opportunity Fund SPC, Head Win Group Limited, Himalaya Embassy, Himalaya Exchange, Himalaya Federal Reserve, Himalaya International Financial Group Ltd., Himalaya Investment LLC, Himalaya (USA) Investment Management LLC, Himalaya New World Inc., Himalaya Supervisory Organization, Himalaya Ventures, Holy City Hong Kong Ventures, Ltd., Hudson Diamond Holding LLC, Hudson Diamond Holding Inc., Hudson Diamond NY LLC, HK International Funds Investments (USA) Limited LLC, Hong Kong International Funds Investments Limited, Huk Trading Inc, Infinite Increase Limited, Infinitum Developments Limited, Japan Himalaya League, Inc., Kalixun Trading Limited, Lamp Capital LLC, Leading Shine Limited, Leading Shine NY Limited, Lexington Property and Staffing Inc., Long Gate Limited, MOS Himalaya Foundation Inc., Maywind Trading LLC, New Federal State of China (a/k/a NFSC), New York MOS Himalaya LLC, New Mulberry PTE Ltd., Newpeople LLC, Noble Fame Global Limited, Pixshow Film Inc., Roscalitar 2, Rosy Acme Ventures Limited, Rule of Law Foundation III, Inc., Rule of Law Society, Rule of Law Society IV, Inc., Santel LLC, Saraca Media Group, Inc., Shiny Ace Ltd., Shiny Times Holdings Ltd., Stevenson, Wong & Co., Taurus Fund LLC, Taurus Fund SP, Taurus Management LLC, The Lost Draft LLC, TM Primrose Limited, UA Himalaya Inc., Voice of Guo Media, Inc., Well Origin Ltd., Wise Creation, Whitecroft Shore Limited, World Century Limited, Worldwide Opportunity Holdings Limited, and ZIBA Limited.\n\n9. \"Including\" or any variant thereof means \"including without limitation.\"\n\n## Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 434 of 439\n\n10. \"And\" and \"or\" mean \"and/or,\" and shall be construed both conjunctively as well as disjunctively in order to maximize their scope.\n\n11. \"Any\" and \"all\" and \"each\" mean \"each and every.\"\n\n12. \"Each\" and \"every\" mean \"each and every.\"\n\n13. \"Third Party\" means a Person or Entity other than Yourself.\n\n14. \"Transfer\" shall have the meaning given to it by section 101(54) of the Bankruptcy Code.\n\n15. \"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, electronic communication, text message, social media post, tweet, meta-data, 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, 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, punchcards, 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\n\n## Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 435 of 439\n\nof 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\n16. \"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\n17. \"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 legal counsel, financial advisors, or any other representative.\n\n18. \"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\n19. \"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\n20. \"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\n\n## Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 436 of 439\n\nslips, memoranda, telephone communications, voice messages, telegrams, telefaxes, telecopies, telexes, instant messages, chats, text messages, telephonic notes, or notes transmitted internally or with third parties.\n\n21. \"Asset(s)\" means any item that can be used to produce positive economic value, including but not limited to any resource with economic value that is owned, controlled or is for the benefit of an entity, that is expected to provide a future benefit, including but not limited to, all real and personal property, intangible property, investments, rights to invest or to future revenue, cash, bank accounts, commodities, securities, claims, total or partial control of an entity, and prospective economic opportunities\n\n22. \"Transfer\" shall have the meaning given to it by section 101(54) of the Bankruptcy Code.\n\n## **IV. DOCUMENTS TO BE PRODUCED**\n\n1. All Documents regarding any income or Asset of the Debtor, the Debtor's Family, the Debtor's estate, an Associated Individuals, or an Associated Entity.\n\n2. All Documents related to the Debtor's financial condition and obligations to his creditors, including without limitation all Documents related to any effort to avoid paying such obligations and All Documents related to this or any other actual or potential bankruptcy or similar insolvency proceeding.\n\n3. All Documents regarding any balance sheet, bank statement, account statement, financial statement, statement of account, wire transfer instructions and/or confirmation, proof of funds, certificate of deposit, certificate of holdings, investment portfolio summary, or similar document relating to the Debtor, the Debtor's Estate, the Debtor's Family, an Associated Entity,\n\n## Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 437 of 439\n\nor an Associated Individual, including without limitation all Documents sufficient to show all Transfers to any of the foregoing.\n\n4. All Documents regarding any investment, business dealings or transactions made by, with, or on behalf of the Debtor, the Debtor's Family, an Associated Individual, or an Associated Entity.\n\n5. All Communications with the Debtor, the Debtor's Family, an Associated Individual, or an Associated Entity, and Documents related to Communications with the Debtor, the Debtor's Family, an Associated Individual, or an Associated Entity, including related to the operation, management, or decision-making of any Entity, including without limitation the Associated Entities.\n\n6. All Documents regarding any Transfer, investment, or other transaction or business dealing made to, by, or with the Debtor, the Debtor's Family, an Associated Individual, or an Associated Entity.\n\n7. All Documents regarding any property ever occupied or used by the Debtor, including without limitation the residential property located in Greenwich, Connecticut at 373 Taconic Rd.; the residential property located in Greenwich, Connecticut at 33 Ferncliff Rd.; the residential property located in Wilton, Connecticut at 354 Nod Hill Rd; the apartments or condominiums located in 5 Princes Gate London, United Kingdom SW7 1QJ; and the residential property located in Mahwah, New Jersey at 675 Ramapo Valley Road, Mahwah, New Jersey 07430.\n\n8. All Documents related to any aircraft owned, controlled, or used by the Debtor, including without limitation (i) the aircraft bearing tail number T7-GQM and any other aircraft\n\n## Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 438 of 439\n\nregistered in San Marino, including without limitation copies of all registration documents and flight manifests showing flights taken by such aircraft and the individuals onboard such flights, and (ii) any Cirrus SF50 aircraft.\n\n9. All Documents regarding any gifts, benefits or loans, to, from or on behalf of the Debtor, the Debtor's Estate, the Debtor's Family, or the Associated Entities, including without limitation Documents sufficient to show the amounts of such gifts, benefits, or loans; the purposes for which such gifts, benefits, or loans were used; when the gifts, benefits, or loans were provided; and the terms of any loans, all representations and warranties made in connection with any loans, the interest rate on any loans, and all evidence of payments of any loans.\n\n10. All Documents concerning any trust or similar instrument set up by, on behalf of, or for the benefit of the Debtor, the Debtor's Estate, the Debtor's Family, or an Associated Entity, including without limitation Documents sufficient to show when the trust(s) was created, by whom it was created, for whose benefit it was created, and the corpus of the trust.\n\n11. All Documents related to any obligation, claim, liability, or debt associated with any legal dispute involving the Debtor, including but not limited to those relating to any litigation before any local, state, federal, or international body, whether an administrative body, court, panel, or alternative dispute resolution entity.\n\n12. All Documents and communications with the Debtor, the Debtor's Family, or an Associated Individual.\n\n13. All Documents and communications between any of your counsel or other advisors and the Debtor, the Debtor's Family, or an Associated Individual.\n\n14. All Documents related to any Associated Entity that You hold or have held an interest in.","body_zh":"美国康涅狄格州联邦破产法院布里奇波特分庭\n\n-----------------------------------------------------------　x\n\n关于：　：\n：　第11章\n\nHO WAN KWOK（郭文贵），\n等，　：\n：　案号：22-50073 (JAM)\n债务人。　：　（合并管理）\n\nx\n第11章受托人根据《破产程序规则》第2004条及地方法规第2004-1条申请作出裁定，授权就与债务人有关联的其他个人、相关银行及汽车交易实体进行证据开示的第十五次补充综合动议\n\nLuc A. Despins（卢克·A·德斯平斯）以其作为上述标题所列Ho Wan Kwok（郭文贵）（“债务人”）第11章案件（“本案”）获任命的第11章受托人（“受托人”）的身份，经由其下署律师，依据《联邦破产程序规则》第2004(a)条（“破产规则”）及《地方法院破产规则》第2004-1条（“地方法规”），特此申请（“本申请”或“本动议”）对某些银行和金融机构、汽车交易实体以及与债务人及其另我空壳公司有关联的个人（“受查对象”）进行审查2；受托人认为，债务人及关联人士\n\n1　这些第11章案件中的债务人包括Ho Wan Kwok（郭文贵）（又称Guo Wengui（郭文贵）、Miles Guo（郭文贵）及Miles Kwok（郭文贵），以及众多其他别名）（税务识别号码后四位：9595）、Genever Holdings LLC（吉尼弗控股有限责任公司）（税务识别号码后四位：8202）以及Genever Holdings Corporation（吉尼弗控股公司）。受托人、Genever Holdings LLC（吉尼弗控股有限责任公司）及Genever Holdings Corporation（吉尼弗控股公司）的邮寄地址为：Paul Hastings LLP（宝盛律师事务所），200 Park Avenue, New York, NY 10166，转交Luc A. Despins（卢克·A·德斯平斯），作为Ho Wan Kwok（郭文贵）破产财产的受托人（仅为通知和通信之目的）。\n\n2　受托人通过本动议寻求授权，以送达要求同时提供文件及接受证言的传票方式，对受查对象进行审查。为免疑义，未经法院事先许可，受托人不会在《暂停对抗程序并在刑事程序处理期间给予其他相关救济的命令》[ECF No. 3038]规定的暂停期间内，对受查对象进行证言录取。\n\n与债务人破产财产有关的业务，而该等受查对象载于随附本动议的附件B。请注意，针对本申请提出异议的截止日期为May 23, 2024；如未及时提交异议，作为附件A随附的拟议裁定（“拟议裁定”）可在无需进一步通知和听证的情况下生效。为支持其申请，受托人谨陈述如下：\n\n初步陈述\n\n1.　受托人为履行其在日期为July 6, 2022的授权任命第11章受托人的命令项下的职责和责任（见ECF. No. 465，第14页，下称“受托人命令”），继续调查债务人的财务和商业事务，以确定是否存在额外的破产财产资产，并为债务人破产财产的利益追回该等资产。\n\n2.　受托人的调查已识别出更多可能知悉债务人资产及财务活动的实体，受托人寻求通过对该等受查对象开展额外的《破产规则》第2004条证据开示，进一步推进其调查。\n\n3.　受托人认为，受查对象可取得并了解与债务人的资产、财务事务，以及债务人、其家人或其关联人士所涉各类公司实体中潜在财务权益有关的信息，包括但不限于属于债务人另我的实体。\n\n4.　受托人已提交多项获法院批准的《破产规则》第2004条动议，包括一项针对被认为曾向债务人及相关实体和个人提供法律及财务建议的法律和财务公司的动议（ECF No. 637，“顾问2004动议”）、一项针对被认为与债务人有关联、受债务人控制或以其他方式与债务人存在联系的实体和个人的动议（“关联方2004动议”）、受托人日期为\n\nSeptember 7, 2022的第一次补充综合动议（“第一次综合动议”）、受托人日期为November 18, 2022的第二次补充综合动议（“第二次综合动议”）、受托人日期为December 21, 2022的第三次补充综合动议（“第三次综合动议”）、受托人日期为March 24, 2023的第四次补充综合动议（“第四次综合动议”）、受托人日期为May 15, 2023的第五次补充综合动议（“第五次综合动议”）、受托人日期为August 11, 2023的第六次补充综合动议（“第六次综合动议”）、受托人日期为October 10, 2023的第七次补充综合动议（“第七次综合动议”）、受托人日期为November 2, 2023的第八次补充综合动议（“第八次综合动议”）、受托人日期为November 6, 2023的第九次补充综合动议（“第九次综合动议”）、受托人日期为December 14, 2023的第十次补充综合动议（“第十次综合动议”）、受托人日期为January 16, 2024的第十一次补充综合动议（“第十一次综合动议”）、受托人日期为January 30, 2024的第十二次补充综合动议（“第十二次综合动议”）、受托人日期为March 21, 2024的第十三次补充综合动议（“第十三次综合动议”）以及受托人日期为March 25, 2024的第十四次补充综合动议（“第十四次综合动议”；连同顾问2004动议、关联方2004动议、第一次综合动议、第二次综合动议、第三次综合动议、第四次综合动议、第五次综合动议、第六次综合动议、第七次综合动议、第八次综合动议、第九次综合动议、第十次综合动议、第十一次综合动议、第十二次综合动议及第十三次综合动议，统称“2004动议”）。本动议所请求的证据开示将补充和扩展受托人已开始的调查，并开辟额外的调查途径及发现资产的可能性。\n\n5.　为简明起见，受托人通过援引将2004动议纳入本动议，并使其构成本动议的一部分。本文未定义的所有首字母大写术语，均具有2004动议中赋予其的含义。\n\n管辖权和审判地\n\n6.　法院依据28 U.S.C. §§ 157 and 1334对审理本申请具有管辖权。依据28 U.S.C. §§ 1408 and 1409，本申请的审判地适格。\n\n7.　本申请为根据包括28 U.S.C. § 157(b)(2) (A), (E), and (F)在内的规定所提出的核心程序。\n\n受查对象\n\n8.　受查对象包括未被纳入先前2004动议的银行及金融机构、汽车交易实体，以及与债务人及其另我空壳公司有关联的某些个人；该等受查对象可能掌握有关债务人资产及财务状况的重要信息。\n\n9.　受托人已查明，债务人连同与债务人有关联的实体及个人，可能曾在银行／金融机构受查对象处或与其进行银行业务或其他业务。更具体而言，该等受查对象为：China CITIC Bank International（中信银行国际）；Intesa Sanpaolo SpA（意大利联合圣保罗银行）；Lloyds Bank PLC（劳埃德银行）；PayrNet Limited（佩尔网有限公司）；Revolut Ltd.（睿沃路特有限公司）；及CIMB Bank Berhad（联昌银行）a/k/a CIMB Islamic Bank Berhad（联昌伊斯兰银行）。受托人了解到，至少一名与债务人有关联的个人或实体已在每一该等受查对象处维持一个或多个账户，及／或该等受查对象曾协助或促成在先前已识别金融机构所持有的其他债务人相关账户之间进行转账。\n\n10.　受托人已识别出某些从事汽车销售业务的实体，至少一名与债务人有关联的个人或实体曾与其进行交易。债务人的惯常做法是通过空壳公司及与债务人有关联的个人购买机动车辆。因此，受托人有合理理由相信，该等实体可能持有与债务人及其财务事务有关的文件或信息，从而有助于受托人开展调查。具体而言，该等实体如下：H.R. Owen PLC（H.R.欧文公众有限公司）；Headwater Service, LLC（海德沃特服务有限责任公司）；以及RM Sotheby's（RM苏富比）及／或RM Auctions 2022（RM拍卖2022）。\n\n11.　受托人还寻求依据第2004条对某些个人开展证据开示；受托人了解到，该等个人直接参与了债务人的财务事务。受托人认为，该等受查对象可能持有与债务人的商业活动及其他行为有关的信息和文件，该等活动和行为涉及可能与债务人破产财产管理有关的资产、负债或财务权益，并且该等受查对象可能持有债务人的资产：\n\n(a)　Evan Cramer（埃文·克雷默）被认为是与债务人及Yvette Wang（王雁平）有关联的个人；Yvette Wang曾担任债务人的“幕僚长”（“王女士”）。受托人了解到，在债务人提交破产申请前的数年内，Cramer先生至少从王女士处收到过一（1）笔重大转账。王女士最近已就其参与债务人欺诈计划所引起的刑事指控认罪。因此，Cramer先生可能掌握与债务人及其商业和财务事务及交易有关的信息、文件和记录，这将有助于受托人开展调查。\n\n(b)　受托人已识别出其他参与债务人另我实体并经由该等另我实体从债务人处收取资金转账的个人。受托人认为，该等个人可能知悉债务人的\n\n资产及财务事务。该等个人及其所关联的另我实体如下：\n\ni.　Makaya Randall（玛卡娅·兰德尔）：HCHK Property Management, Inc.（HCHK物业管理公司）、HCHK Technologies（HCHK科技）、Lexington Property & Staffing Inc.（列克星敦物业与人力公司）及GTV Media Group, Inc.（GTV媒体集团公司）；\n\nii.　Richard Leahy（理查德·莱希）：HCHK Property Management, Inc.；\n\niii.　Thomas Guarino（托马斯·瓜里诺）（aka Thomas Guarino II（托马斯·瓜里诺二世））：HCHK Property Management, Inc.、Golden Spring NY（金泉纽约）、GS Security Solutions Inc.（GS安保解决方案公司）及Lamp Capital LLC（蓝普资本有限责任公司）；\n\niv.　Lukasz Lasota（卢卡什·拉索塔）：HCHK Property Management, Inc.；\n\nv.　Thomas McHale（托马斯·麦克黑尔）：HCHK Property Management, Inc.、Golden Spring NY、GS Security Solutions Inc.及Lamp Capital LLC；\n\nvi.　Sean Lynch（肖恩·林奇）：HCHK Property Management, Inc.及Lamp Capital LLC；\n\nvii.　Eddy Aquino（埃迪·阿基诺）（aka Eddy I Sanchez Aquino（埃迪·I·桑切斯·阿基诺））：G Club Operations, LLC（G俱乐部运营有限责任公司）；\n\nviii.　Summer L. Bridges（萨默·L·布里奇斯）：G Fashion（G时尚）；\n\nix.　Michael Baranowitz（迈克尔·巴拉诺维茨）：Rule of Law Foundation III, Inc.（法治基金会第三公司）及Rule of Law Society IV, Inc.（法治协会第四公司）；\n\nx.　Maya Fawaz（玛雅·法瓦兹）：Lexington Property & Staffing Inc.及GTV Media Group Inc.；\n\nxi.　Andrea Volpe（安德烈亚·沃尔佩）：GFNY, Inc.（GFNY公司）及HCHK Technologies；以及\n\nxii.　Dean M. Rabideau（迪恩·M·拉比多）：Golden Spring NY。\n\n请求的救济\n\n12.　受托人寻求依据《破产规则》第2004(a)条及地方法规第2004-1条作出一项实质上采用拟议裁定形式的裁定，授权受托人对附件B所列受查对象进行审查。\n\n请求救济的依据\n\n13.　依据第2004(a)条，经利害关系方申请，法院可命令对任何个人或实体进行审查。根据第2004条获授权审查的范围极其广泛，可涉及“债务人的行为、行为方式或财产，或债务人的负债和财务状况，或任何可能影响债务人破产财产管理的事项。”Fed. R. Bankr. P. 2004(b)。\n\n14. “第2004条规则审查的目的是协助利害关系方确定破产财产的性质和范围，查明资产，审查交易，并评估是否发生不当行为。”In re Transmar Commodity Group Ltd., 2018 WL 4006324, at *4 (Bankr. S.D.N.Y. Aug. 17, 2018)（省略内部引文和引证）。这包括揭示破产财产的性质和范围，以及发现债务人可能故意或无意隐匿的资产。见 In re Bennett Funding Group, Inc., 203 B.R. 24, 27-28 (Bankr. N.D.N.Y. 1996)。另见 In re Millennium Lab Holdings II, LLC, 562 B.R. 614, 626 (Bankr. D. Del. 2016)（“第2004条规则审查的正当目标包括发现资产、审查交易，以及确定是否发生不当行为。”（省略内部引文和引证））。\n\n15. 债务人在其于 March 20, 2022 提交、用于支持本案立案的声明中表示，提起其第11章案件的目的包括“……(b) 鉴于[其]认为在该等事项上存在误解，为利益相关方提供有效机会，以调查[其]资产、负债及财务事务；[以及] (c) 确定哪些资产属于破产财产，进而可供向经认可债权持有人分配……。”（债务人声明，第3段）。受托人拟进行的调查与上述所陈目的直接相关，因为该调查将帮助受托人识别债务人的资产和负债，以便向债权人进行分配。\n\n16. 本文所列调查领域构成受托人持续调查工作的一部分。随着调查进展，新的调查路径逐渐显现，并产生了对人员、实体及调查领域进行额外取证的需要。基于上文讨论的全部事实和证据，以及第2004条规则动议中所载的事实和证据，受托人请求采用第2004条规则赋予的调查工具，以进一步确定资产的真实所有权，并探查受托人目前尚不知悉的其他潜在资产。\n\n17. 受托人请求，为推进其审查，法院命令被审查人按照随附于本文件并构成本文件一部分的表格3所载要求（“拟议传票”），在送达与拟议传票在形式和实质上基本相似的传票后十四（14）日内，或在受托人同意的其他期限内，向受托人律师提供文件。这些请求要求提供的文件包括但不限于被审查人与债务人就其财务状况、资产转移及公司治理问题进行的通信。该等请求还要求提供被审查人就相同主题形成的内部档案和通信。\n\n3 附件B包括一份拟议传票索引，如本动议获准，该等传票将向被审查人送达。受托人还随附附件C-1至C-22，即针对各被审查人的个别拟议传票，其中包括向各被审查人提出的取证主题；该等传票在形式和实质上基本相似。\n\n18. 受托人将从被审查人处取得的取证类型完全属于《联邦破产程序规则》第2004条的范围。破产法院通常准许对专业事务所进行第2004条规则取证，前提是该等取证可能识别并协助为破产财产及债权人的利益追回资产。见，例如，In re Bame, 251 B.R. 367 (Bankr. D. Minn. 2000)；In re Horvath, No. 13-34137, 2015 WL 2195060 (Bankr. N.D. Ohio May 7, 2015)（准许就资产清单所列债权向个人债务人进行取证，因为取得该等取证可能提高债务人破产财产的价值）。\n\n19. 受托人主张，上述事实构成充分理由，使法院命令被审查人依《联邦破产程序规则》第2004条提供文件。特别是考虑到债务人及其某些家庭成员和关联人士的阻挠模式，向其他方（包括被审查人）寻求取证，是识别和追回破产财产的一项必要调查工具。事实上，截至目前，第三方（如被审查人）持有的文件一直是受托人调查中取得的最有用文件之一。4\n\n20. 批准本申请对于受托人有效履行《受托人命令》所设想的职责至关重要，尤其包括其“为债权人和破产财产的利益查找债务人资产”以及“调查债务人的资产、负债及财务事务”的职责。（见《受托人命令》第15-16、18页）。\n\n21. 批准本申请所请求的救济，不会使包括债务人在内的任何利害关系方遭受不当损害。\n\n4 受托人还请求授权，如在受托人的调查过程中确定被审查人的该等关联公司或子公司为控制与被审查人有关且与受托人调查相关文件的一方，则向该等关联公司或子公司送达拟议传票。\n\n未曾提出申请\n\n22. 此前未曾就本文件所请求的救济提出申请。但是，受托人此前提交过第2004条规则动议，而该等先前动议未请求向本案所涉被审查人进行取证。\n\n异议期限\n\n23. 对本申请提出异议的期限为 May 23, 2024；如未及时提交异议，拟议命令可在无需进一步通知和听证的情况下生效。\n\n因此，受托人恭请法院批准本申请，并依 Fed. R. Bankr. P. 2004(a) 作出拟议命令，命令对被审查人进行审查，并命令按照附于拟议传票的文件出示请求所载要求出示特定文件，以及给予法院认为公正和适当的其他及进一步救济。\n\n因此，法院应批准本动议，并给予其他公正和适当的救济。\n\n日期：May 16, 2024　LUC A. DESPINS（卢克·德斯潘），\n\nNew Haven, Connecticut　第11章受托人\n\n签署人：/s/ Patrick R. Linsey\nDouglas S. Skalka（ct00616）\nPatrick R. Linsey（ct29437）\nNEUBERT, PEPE & MONTEITH, P.C.\n195 Church Street, 13th Floor\nNew Haven, Connecticut 06510\n(203) 781-2847\ndskalka@npmlaw.com\nplinsey@npmlaw.com\n\n第11章受托人律师\nUNITED STATES BANKRUPTCY COURT（美国破产法院）\nDISTRICT OF CONNECTICUT（康涅狄格区）\nBRIDGEPORT DIVISION（布里奇波特分院）\n\n-----------------------------------------------------------　x\n\n关于：　：\n：　第11章\n\nHO WAN KWOK（郭文贵），\n等人，　：\n：　案号：22-50073 (JAM)\n债务人。　：\n：\n：　（合并管理）\n-----------------------------------------------------------　x\n异议期限通知\n\nLuc Despins（卢克·德斯潘）作为获指定的债务人破产财产第11章受托人（“申请人”），已向 U.S. Bankruptcy Court for the District of Connecticut（美国康涅狄格区破产法院）提交申请，请求依据第2004条规则对附件B所列的若干公司实体、个人以及银行和金融机构进行审查（“第2004条规则审查”）。兹通知，任何对第2004条规则审查提出的异议或答复，均须依照 Fed. R. Bankr. P. 2002(a) 和 9014 以及 Local Bankr. R. 2004-1(c)，不迟于 May 23, 2024 向法院提交。如未及时提交异议，关于第2004条规则审查的拟议命令可在无需进一步通知和听证的情况下生效，见 11 U.S.C. section 102(1)。\n\n[本页其余部分特意留白。]\n\n1 本第11章案件中的债务人为 Ho Wan Kwok（郭文贵）（亦称 Guo Wengui、Miles Guo 和 Miles Kwok，以及众多其他别名）（税务识别号码后四位：9595）、Genever Holdings LLC（税务识别号码后四位：8202）和 Genever Holdings Corporation。受托人、Genever Holdings LLC 及 Genever Holdings Corporation 的邮寄地址为 Paul Hastings LLP, 200 Park Avenue, New York, NY 10166，收件人为 Luc A. Despins，作为 Ho Wan Kwok 破产财产的受托人（仅限用于通知和通信）。\n\n日期：May 16, 2024　LUC A. DESPINS，\n\nNew Haven, Connecticut　第11章受托人\n\n签署人：/s/ Patrick R. Linsey\n\nDouglas S. Skalka (ct00616)\nPatrick R. Linsey (ct29437)\nNEUBERT, PEPE & MONTEITH, P.C.\n195 Church Street, 13th Floor\nNew Haven, Connecticut 06510\n(203) 781-2847\ndskalka@npmlaw.com\nplinsey@npmlaw.com\n\n第11章受托人律师\n附件A\n\n拟议命令\n\nCase 22-50073　Doc 3193　Filed 05/16/24　Entered 05/16/24 10:28:21　第14页，共\n\nUNITED STATES BANKRUPTCY COURT\nDISTRICT OF CONNECTICUT\nBRIDGEPORT DIVISION\n\n-----------------------------------------------------------　x\n\n关于：　：\n：　第11章\n\nHO WAN KWOK，\n等人，　：\n：\n：　案号：22-50073 (JAM)\n债务人。　：\n：　（合并管理）\n-----------------------------------------------------------　x\n[拟议]命令：批准第11章受托人提出的第十五次补充综合动议，请求依据《联邦破产程序规则》第2004条及地方法则第2004-1条作出命令，授权就新增个人、相关银行及从事汽车交易的实体进行取证\n\n经审议，Luc Despins 作为获指定的债务人破产财产第11章受托人（“申请人”）提交的申请（“申请”，ECF No. ____），该申请请求授权对其附件B所列被审查人进行《联邦破产程序规则》第2004条审查；经通知及听证，见 11 U.S.C. § 102(1)；鉴于存在理由按如下条件批准所请求的救济；现据此\n\n命令：准许第2004条规则动议，具体如下。\n\n命令：Neubert, Pepe & Monteith, P.C. 作为受托人的律师，现获授权签署与作为附件C-1至C-22附于第2004条规则动议的传票在形式上基本相似的传票，并依《联邦破产程序规则》第2004条送达该等传票连同本命令副本，要求对申请附件B所列被审查人进行审查并出示文件。\n\n命令：在不影响《联邦破产程序规则》《联邦民事诉讼规则》及适用地方法则项下任何权利的前提下，且除非法院另有命令，被审查人现被命令于传票送达后14日内，或在受托人同意的其他期限内，出示全部文件。如被审查人以任何特权为由不出示传票所请求的任何文件，则该被审查人现被命令于传票送达后14日内，或在受托人同意的其他期限内，向受托人提供符合 Fed. R. Civ. P. 45(e)(2)（经 Fed. R. Bankr. P. 9016 适用）及 D. Conn. L. Civ. R. 26(e) 的特权日志。\n\n1 本第11章案件中的债务人为 Ho Wan Kwok（亦称 Guo Wengui、Miles Guo 和 Miles Kwok，以及众多其他别名）（税务识别号码后四位：9595）、Genever Holdings LLC（税务识别号码后四位：8202）和 Genever Holdings Corporation。受托人、Genever Holdings LLC 及 Genever Holdings Corporation 的邮寄地址为 Paul Hastings LLP, 200 Park Avenue, New York, NY 10166，收件人为 Luc A. Despins，作为 Ho Wan Kwok 破产财产的受托人（仅限用于通知和通信）。\n\nCase 22-50073　Doc 3193　Filed 05/16/24　Entered 05/16/24 10:28:21　第15页，共439页\n\n兹命令：受审查人应确保所有文件及其他信息，包括但不限于任何电子格式的信息，凡根据传票要求提供的，或与债务人、其业务、资产、负债、财务状况或本 Chapter 11 案件有关的，均得到妥善保存，可供提交、查阅和复制，且不得毁损。\n\n兹命令：Neubert, Pepe & Monteith, P.C.（诺伊伯特、佩佩与蒙蒂思律师事务所）作为受托人律师，特此获授权，无需本院进一步命令，即可依《联邦破产程序规则》第 2004 条，通过审查方式，对申请书附件 B 所列任何受审查人的一名或多名代表在 Neubert, Pepe & Monteith, 195 Church Street, 13th Floor, New Haven, CT 06510 的办公室、Paul Hastings LLP（普衡律师事务所）, 200 Park Avenue, New York, NY 10166 的办公室，或当事人双方共同接受的其他地点，进行取证。取证日期应为受托人可接受的日期；由受托人选择，该日期应不早于拟受审查人依照《联邦破产程序规则》第 2004 条、传票及本命令提交文件后 14 个日历日，且该审查应逐日持续，直至完成。\n\n日期：____________, 2024\n\nJulie A. Manning（朱莉·A·曼宁），美国破产法院法官\n\n____________________________________________________________\n附件 B\n\n案件 22-50073 文书 3193 于 05/16/24 提交 于 05/16/24 10:28:21 录入 第 17 页，共 439 页\n\n取证对象　地址　传票索引\n\nChina CITIC Bank International（中信银行国际）\n纽约分行\nChina CITIC Bank International\n410 Park Avenue, 11F\nNew York, NY 10022　附件 C-1\n\nIntesa Sanpaolo SpA（意大利联合圣保罗银行）\n纽约分行\n1 William Street\nNew York, NY 10004　附件 C-2\n\nLloyds Bank PLC（劳埃德银行有限公司）\n纽约办公室\n1095 Avenue of the Americas, 34th Floor\nNew York, NY 10036\n注册办事处地址\n25 Gresham Street\nLondon, England EC2V 7HN　附件 C-3\n\nPayrNet Limited（PayrNet有限公司）\n注册办事处地址\nMontacute Yards, Shoreditch High Street\nLondon, England E1 6HU　附件 C-4\n\nRevolut Ltd.（Revolut有限公司）\n注册代理人\nCogency Global Inc.（科金西环球公司）\n122 East 42nd Street, 18th Floor\nNew York, NY 10168\n107 Greenwich Street, 20th Floor\nNew York, NY 10006　附件 C-5\n\nCIMN Bank Berhad\n又称 CIMB Islamic\nBank Berhad（联昌伊斯兰银行有限公司）\n英国设立办事处\n27 Knightsbridge\nLondon, England SW1X 7LY\n通信地址\nMenara Cimb Jalan Stesen Sentral 2\nJuala Lumpur Sentral\nKuala Lumpur, Malaysia 50470　附件 C-6\n\n案件 22-50073 文书 3193 于 05/16/24 提交 于 05/16/24 10:28:21 录入 第 18 页，共 439 页\n\n取证对象　地址　传票索引\n\nEvan Cramer（埃文·克雷默）　1250 100th St.\nBay Harbor Islands, FL 33154-1106　附件 C-7\n\nMakaya Randall（马卡娅·兰德尔）　24 Hinckley Place\nPoughkeepsie, NY 12601　附件 C-8\n\nRichard Leahy（理查德·莱希）　661 Locust Point Road\nRumson, NJ 07760　附件 C-9\n\nThomas Guarino（托马斯·瓜里诺）（又称\nThomas Guarino II（托马斯·瓜里诺二世））　112 Lakewood Drive\nCongers, NY 10920　附件 C-10\n\nLukasz Lasota（卢卡什·拉索塔）　35 Landmark Lane\nFairlawn, NJ 07410　附件 C-11\n\nThomas McHale（托马斯·麦克黑尔）　11 Eden Road\nHarriman, NY 10926　附件 C-12\n\nSean Lynch（肖恩·林奇）　800 Wildwood Court\nYorktown Heights, NY 10598　附件 C-13\n\n案件 22-50073 文书 3193 于 05/16/24 提交 于 05/16/24 10:28:21 录入 第 19 页，共 439 页\n\n取证对象　地址　传票索引\n\nEddy Aquino（埃迪·阿基诺）（又称\nEddy I. Sanchez\nAquino（埃迪·I·桑切斯·阿基诺））　Cond Palmares De Monteverde\n94 Ramal 842\nSan Juan, PR 00926-3903　附件 C-14\n\nSummer L. Bridges（萨默·L·布里奇斯）　6102 Premiere Ave.\nLakewood, CA 90712　附件 C-15\n\nMichael Baranowitz（迈克尔·巴拉诺维茨）　10 Huntsman Lane\nCommack, NY 11725　附件 C-16\n\nMaya Fawaz（玛雅·法瓦兹）　130 Ocean Parkway, 3D\nBrooklyn, NY 11218　附件 C-17\n\nAndrea Volpe（安德烈亚·沃尔佩）　15 Broad Street, Apt. 3110\nNew York, NY 10005　附件 C-18\n\nH.R. Owen PLC（H.R. Owen公众有限公司）　注册办事处地址\nMelton Court, Old Brompton Road\nLondon, England SW7 3TD　附件 C-19\n\nHeadwater Service,\nLLC（Headwater服务有限责任公司）　注册代理人\nc/o Northwest Registered Agent LLC（西北注册代理有限责任公司）\nFive Greentree Centre,\n55 Route 73 North Ste. 104\nMarlton, NJ 08053　附件 C-20\n\n案件 22-50073 文书 3193 于 05/16/24 提交 于 05/16/24 10:28:21 录入 第 20 页，共 439 页\n\n取证对象　地址　传票索引\n\nRM Sotheby's and/or（RM苏富比及/或）\nRM Auctions 2022（RM拍卖行2022）　1334 York Ave.　附件 C-21\nNew York, NY 10021\n\n注册办事处地址\nHeron House, 5 Heron Square\nRichmond, United Kingdom TW9 1EL\n\nDean M. Rabideau（迪恩·M·拉比多）　1898 Hanover Street　附件 C-22\nYorktown Heights, NY 10598\n15 Bayberry Street\nHopewell Junction, NY 12533-4333\n\n附件 C-1\n\nB2540（表格 2540 — 第 2004 条审查传票）（12/15）案件 22-50073 文书 3193 于 05/16/24 提交 于 05/16/24 10:28:21 录入 第 22 页，共\n\nUNITED STATES BANKRUPTCY COURT（美国破产法院）\n\nDistrict of Connecticut（康涅狄格州地区）\n\n关于 HO WAN KWOK（郭文贵）等人案，\n\n1 案件编号 22-50073 (JAM) 债务人 Chapter 11\n\n（合并管理）\n第 2004 条审查传票\n\n致：China CITIC Bank International（中信银行国际）\n\n（传票所指向人员的姓名）\n\n证言：特此命令你于下列规定的时间、日期和地点出席，依《联邦破产程序规则》第 2004 条接受审查并作证。随附授权该审查的法院命令副本。\n\n地点　日期及时间\n\n不适用　不适用\n\n审查将以下列方式记录：不适用\n\n提交：你或你的代表还必须将下列文件、电子存储信息或物品带至审查现场，并必须准许对该材料进行查阅、复制、测试或取样：\n见随附的《文件提交请求》。\n\n下列《联邦民事诉讼规则》第 45 条规定已随附，该条经《联邦破产程序规则》第 9016 条适用于破产案件——有关履行地点的第 45(c) 条；有关作为传票对象的你所受保护的第 45(d) 条；以及有关你对本传票的答复义务及未答复的潜在后果的第 45(e) 条和第 45(g) 条。\n\n日期：May , 2024\n\n法院书记员\n\n或\n\n书记员或副书记员签名　律师签名\n\n代表发出或请求本传票的 Chapter 11 受托人 Luc A. Despins（吕克·A·德斯平）的律师姓名、地址、电子邮件地址和电话号码如下：\n\nPatrick R. Linsey, Esq.（帕特里克·R·林赛律师）；Neubert, Pepe & Monteith, P.C.（诺伊伯特、佩佩与蒙蒂思律师事务所）；195 Church Street, 13th Floor, New Haven, Connecticut 06510；plinsey@npmlaw.com；(203) 781-2847\n\n致发出或请求本传票之人的通知\n\n如果本传票命令在审判前提交文件、电子存储信息或有形物品，或检查场所，则必须在向传票指向之人送达前，向每一方当事人送达通知及本传票副本。Fed. R. Civ. P. 45(a)(4).\n\n软件版权所有 (c) 1996-2022 Best Case, LLC（Best Case有限责任公司）- www.bestcase.com Best Case Bankruptcy 1 本 Chapter 11 案件中的债务人为 Ho Wan Kwok（郭文贵）（又名 Guo Wengui（郭文贵）、Miles Guo（郭文贵）及 Miles Kwok（郭文贵），以及众多其他别名）（税务识别号码后四位：9595）、Genever Holdings LLC（Genever控股有限责任公司）（税务识别号码后四位：8202）及 Genever Holdings Corporation（Genever控股公司）。受托人、Genever Holdings LLC 及 Genever Holdings Corporation 的邮寄地址为 Paul Hastings LLP（普衡律师事务所）, 200 Park Avenue, New York, NY 10166，c/o Luc A. Despins（吕克·A·德斯平），作为 Ho Wan Kwok（郭文贵）遗产的受托人（仅为通知和通信之目的）。\n\n送达证明\n\n（除非 Fed. R. Civ. P. 45 要求，否则本节不应向法院提交。）\n\n本人于（日期）收到向（个人姓名及职务，如有）送达的本传票。\n\n本人通过向被指定人员交付副本送达本传票，具体如下：\n\n于（日期）送达；或\n\n本人因下列原因退回未执行的传票：\n\n除非本传票代表美国或其官员或代理人发出，本人还已向证人支付了一日出席费用及法律允许的里程费，金额为 \\$ 。\n\n本人旅费为 \\$ ，服务费为 \\$ ，合计 \\$ 。\n\n本人在伪证罪处罚下声明，上述信息真实且正确。\n\n日期：\n\n送达人员签名\n\n正楷姓名及职务\n\n送达人员地址\n\n有关尝试送达等的补充信息：\n\n《联邦民事诉讼规则》第 45(c)、(d)、(e) 及 (g) 条（Effective 12/1/13）（经《联邦破产程序规则》第 9016 条适用于破产案件）\n\n(c) 履行地点。\n\n(1) 审判、听证或证言录取。传票仅可按下列方式命令人员出席审判、听证或证言录取：\n\n(A) 在该人员居住、受雇或经常亲自从事商业活动地点 100 英里范围内；或\n\n(B) 在该人员居住、受雇或经常亲自从事商业活动所在州内，若该人员\n\n(i) 是当事人或当事人的高级职员；或\n\n(ii) 被命令出席审判且不会产生重大费用。\n\n(2) 其他取证。传票可命令：\n\n(A) 在该人员居住、受雇或经常亲自从事商业活动地点 100 英里范围内的地点提交文件、电子存储信息或物品；以及\n\n(B) 在拟检查的场所检查场所。\n\n(d) 对作为传票对象人员的保护；执行。\n\n(1) 避免不当负担或费用；制裁。负责发出和送达传票的当事人或律师必须采取合理措施，避免对作为传票对象的人员施加不当负担或费用。要求履行的地区法院必须执行该义务，并对未遵守者的当事人或律师施加适当制裁，其中可包括损失的收入和合理的律师费。\n\n(2) 命令提交材料或准许检查。\n\n(A) 无须出席。被命令提交文件、电子存储信息或有形物品，或准许检查场所的人员，无须亲自出席提交或检查地点，除非其同时被命令出席证言录取、听证或审判。\n\n(B) 异议。被命令提交文件或有形物品，或准许检查的人员，可向传票中指定的当事人或律师送达书面异议，反对检查、复制、测试或取样任何或全部材料，或反对检查场所，或反对以所要求的一种或多种形式提交电子存储信息。异议必须在指定履行时间或传票送达后 14 日届满之日中较早者之前送达。如提出异议，下列规则适用：\n\n(i) 送达方在任何时候均可通知被命令人员，并向要求履行的地区法院提出动议，请求作出强制提交或检查的命令。\n\n(ii) 仅可依该命令的指示要求实施这些行为，且该命令必须保护非当事人亦非当事人高级职员的人员，免受因履行而产生的重大费用。\n\n(3) 撤销或修改传票。\n\n(A) 必须撤销或修改的情形。经及时动议，要求履行的地区法院必须撤销或修改具有下列情形的传票：\n\n(i) 未给予合理履行时间；\n\n(ii) 要求人员在第 45(c) 条规定的地域范围以外履行；\n\n(iii) 要求披露享有特权或以其他方式受保护的事项，而不适用任何例外或豁免；或\n\n(iv) 使人员承受不当负担。\n\n(B) 可以撤销或修改的情形。为保护作为传票对象或受传票影响的人员，要求履行的地区法院可经动议撤销或修改要求下列事项的传票：\n\n(i) 披露商业秘密或其他保密研究、开发或商业信息；或\n\n(ii) 披露未受委聘专家的意见或信息，该等意见或信息未描述争议中的具体事件，且源于该专家未经任何一方当事人请求而进行的研究。\n\n(C) 以规定条件作为替代方案。在第 45(d)(3)(B) 条所述情形下，如送达方：法院可不撤销或修改传票，而命令在规定条件下出席或提交。\n\n(i) 表明对该证言或材料存在实质需要，且如不造成不当困难则无法以其他方式获得；并且\n\n(ii) 确保被传唤人将获得合理补偿。\n\n(e) 对传票作出回应时的义务。\n\n(1) 提交文件或电子存储信息。下列程序适用于提交文件或电子存储信息：\n\n(A) 文件。对要求提交文件的传票作出回应的人，必须按照其在正常业务过程中保存的方式提交文件，或者必须对文件进行整理和标注，使其与请求中的类别相对应。\n\n(B) 未指定电子存储信息提交形式。如传票未指定提交电子存储信息的形式，作出回应的人必须以其通常保存的形式，或以一种或多种合理可用的形式提交该信息。\n\n(C) 电子存储信息仅以一种形式提交。作出回应的人无需以一种以上的形式提交同一电子存储信息。\n\n(D) 无法访问的电子存储信息。作出回应的人无需就其认定因不当负担或费用而无法合理访问的来源中的电子存储信息提供证据开示。在提出强制证据开示动议或申请保护令时，作出回应的人必须证明该信息因不当负担或费用而无法合理访问。如作出该证明，法院在考虑第 26(b)(2)(C) 条的限制后，如请求方证明存在正当理由，仍可命令对该等来源进行证据开示。法院可规定该证据开示的条件。\n\n(2) 主张特权或保护。\n\n(A) 被扣留的信息。以该信息享有特权或作为审判准备材料受到保护为由而扣留被传唤信息的人，必须：(i) 明确提出该主张；并且\n\n(ii) 以一种在不披露本身享有特权或受保护信息的情况下，能够使各方评估该主张的方式，描述被扣留文件、通信或有形物品的性质。\n\n(B) 已提交的信息。如为回应传票而提交的信息受到特权主张或作为审判准备材料受到保护，提出该主张的人可将该主张及其依据通知收到该信息的任何一方。收到通知后，一方必须立即返还、隔离或销毁所指明的信息及其拥有的任何副本；在该主张得到解决前，不得使用或披露该信息；如该方在收到通知前披露了该信息，必须采取合理措施取回该信息；并且可立即将该信息密封提交给要求履行传票义务所在地区的法院，以裁定该主张。提交该信息的人必须在该主张得到解决前保存该信息。\n\n(g) 藐视法庭。要求履行传票义务所在地区的法院，以及在动议移交后签发传票的法院，均可对已被送达但无充分理由不遵守传票或与之相关命令的人作出藐视法庭认定。\n\n有关传票材料的获取，请参见 Fed.R.Civ.P.45(a) 委员会说明（2013）\n\n……\n\n文件提交请求\nI. 指示\n\n1. 除非另有说明，下列文件请求（以下简称“请求”，单项称“一项请求”）必须分别且具体地作出回应。除非基于善意提出异议，否则必须完整答复每项请求；如提出异议，贵方必须按如下所述详细说明异议理由。如异议仅涉及某项请求的一部分，或其中所含的某个词语、短语或条款，贵方仅须对该部分提出异议，并对其余请求作出回应。\n\n2. 电子存储信息必须依照下列指示提交：\n\na. 图像。黑白图像必须为 300 DPI Group IV 单页 TIFF 文件。彩色图像必须以 JPEG 格式提交。文件名不得包含嵌入空格或特殊字符（包括逗号）。文件夹名称不得包含嵌入空格或特殊字符（包括逗号）。所有 TIFF 图像文件必须具有唯一文件名，即 Bates 编号。图像必须在每张图像右下角加注连续的 Bates 编号。每个文件夹中的 TIFF 文件数量不应超过 1000 个。Excel 电子表格应具有以该文件 Bates 编号命名的占位图像。\n\nb. 图像加载文件\n\na. Concordance® 数据文件。数据文件（.DAT）包含将加载至 Concordance® 数据库的全部字段信息。.DAT 文件的第一行必须是标识字段名称的标题行。.DAT 文件必须使用以下 Concordance® 默认分隔符：逗号 ASCII 字符（020）引号 þ ASCII 字符（254）。日期字段应以 mm/dd/yyyy 格式提供。日期和时间字段必须为两个单独字段。如文件包括已成像的电子邮件及附件，必须包括附件字段，以保留电子邮件与其附件之间的父项/子项关系。必须包括 OCRPATH 字段，以提供已提交存储介质上提取文本文件的文件路径及名称。文本文件必须以 FIRSTBATES 命名。不得在 .DAT 文件中包含文本。对于含有原生文件的文件，必须包括 LINK 字段，以提供原生文件的文件路径及名称。原生文件必须以 FIRSTBATES 命名。\n\nb. Concordance Image® 或 Opticon 交叉引用文件。图像交叉引用文件（.LOG 或 .OPT）将图像链接至数据库记录。该文件应为逗号分隔文件，每行包含七个字段，并且数据库中每个图像均应在交叉引用文件中有一行，格式如下：ImageID,VolumeLabel,ImageFilePath,DocumentBreak,FolderBreak,Box Break,PageCoun。\n\nc. 文件文本。文本必须作为单独的文本文件提交，不得作为 .DAT 文件内的字段提交。文本文件的完整路径（OCRPATH）应包含在 .DAT 文件中。建议使用以 FIRSTBATES/Image Key 命名的文件级 ANSI 文本文件。提取的文本文件必须置于单独文件夹中，且每个文件夹中的文本文件数量不应超过 1,000 个。文件夹名称中不得包含特殊字符（包括逗号）。文本文件必须按文件级别提供。\n\nd. 特定文件类型的原生格式提交。为充分理解其内容和含义而合理需要以原生格式查看的文件类型，必须以原生格式提交。这些包括但不限于电子表格、类电子表格文件（Microsoft Excel、逗号分隔值、制表符分隔值等）、Microsoft PowerPoint 或其他特殊演示文件、数据库文件以及音频/视频文件。应提供一张带有 Bates 编号的提示页图像，注明存在原生文件，并在 .dat 文件中将原生文件路径作为字段包含。所提交的原生文件应以与该文件提示页相对应的 Bates 编号命名。原生文件应归入按递增方式命名的“NATIVE”目录，并与图像目录分开。\n\ne. 去重。对存在完全重复件的每份电子文件，仅提交一个副本。对于电子邮件，应根据由 BCC、Body、CC、From、IntMsgID、To 和 Attach 属性生成的 MD5 哈希值合并重复件。对于电子邮件附件和独立电子文件，应根据整个文件的 MD5 哈希值合并重复件。\n\nf. 元数据。以符合 Concordance 的加载文件（.dat）形式提交每份文件的提取元数据。.DAT 文件的第一行必须是标识字段名称的标题行。.DAT 文件必须使用以下 Concordance 默认分隔符：逗号 , ASCII 字符（020）引号 þ ASCII 字符（254）\n\n日期字段应以 mm/dd/yyyy 格式提供。日期和时间字段必须为两个单独字段。下列为必需元数据：\n\n字段名称　示例数据　说明\n\nFIRSTBATES　EDC0000001　原生文件文件/电子邮件的第一个 Bates 编号\nLASTBATES　EDC0000001　原生文件文件/电子邮件的最后一个 Bates 编号\nLASTBATES 字段应填写单页文件的值\nATTACHRANGE　EDC0000001 - EDC0000015　父项文件首页的 Bates 编号至最后一个附件“子项”文件最后一页的 Bates 编号\nBEGATTACH　EDC0000001　附件范围的第一个 Bates 编号\nENDATTACH　EDC0000015　附件范围的最后一个 Bates 编号\nCUSTODIAN　Smith, John　电子邮件：电子邮件所在的邮箱\n原生文件：文件源自其文件的个人或部门名称\nFROM　John Smith　电子邮件：发件人\n原生文件：文件作者\n多个条目应使用分号分隔\nTO　Coffman, Janice; LeeW [mailto:LeeW@MSN.com]　收件人\n多个条目应使用分号分隔\nCC　Frank Thompson [mailto:frank_Thompson@cdt.com]　抄送收件人\n多个条目应使用分号分隔\nBCC　John Cain　密送收件人\n多个条目应使用分号分隔\nSUBJECT　Board Meeting Minutes　电子邮件：电子邮件主题行；原生文件：文件标题（如有）\nFILE_NAME　BoardMeetingMinutes.docx　原生文件：原始原生文件的名称，包括扩展名\nDATE_SENT　10/12/2010　电子邮件：电子邮件发送日期\n原生文件：（空）\nTIME_SENT/TIME_ZONE　07:05 PM GMT　电子邮件：电子邮件发送时间/电子邮件标准化所用时区\nTIME_ZONE　GMT　转换过程中电子邮件被标准化所使用的时区。\nLINK　EDC0000001.msg　电子邮件或原生文件文件的超链接\n链接文件必须以 FIRSTBATES 编号命名\nFILE_EXTEN　MSG　表示电子邮件或原生文件的文件类型扩展名\nAUTHOR　John Smith　电子邮件：（空）\n原生文件：文件作者\nDATE_CREATED　10/10/2010　电子邮件：（空）\n原生文件：文件创建日期\n\nTIME_CREATED　10:25 AM　电子邮件：（空）\n原生文件：文件创建时间\n该数据必须为单独字段，不得与 DATE_CREATED 字段合并\nDATE_MOD　10/12/2010　电子邮件：（空）\n原生文件：文件最后修改日期\nTIME_MOD　07:00 PM　电子邮件：（空）\n原生文件：文件最后修改时间\n该数据必须为单独字段，不得与 DATE_MOD 字段合并\nDATE_ACCESSD　10/12/2010　电子邮件：（空）\n原生文件：文件最后访问日期\nTIME_ACCESSD　07:00 PM　电子邮件：（空）\n原生文件：文件最后访问时间\n该数据必须为单独字段，不得与 DATE_ACCESSD 字段合并\nFILE_SIZE　5,952　原生文件文件/电子邮件的大小，以 KB 计\nPGCOUNT　1　原生文件文件/电子邮件的页数\nPATH　Email: (empty) Agenda.doc　电子邮件：（空）\n原生文件：储存原生文件文件的路径，包括原始文件名。\nINTFILEPATH　Personal Folders\\Deleted Items\\Board Meeting Minutes.msg　电子邮件：电子邮件的原始位置，包括原始文件名。\n原生文件：（空）\nINTMSGID　<000805c2c71b\\$75977050\\$cb8306d1@MSN>　电子邮件：唯一消息 ID；原生文件：（空）\nMD5HASH　d131dd02c5e6eec4693d9a0698aff95c2fcab58712467eab4004583eb8fb7f89　文件的 MD5 哈希值。\nOCRPATH　TEXT/001/EDC0000001.txt　原生文件提取文本的路径\n\n3. 每项请求均独立适用并应独立解释，除非另有说明，任何请求均不限制任何其他请求的范围。\n\n4. 所有文件均应按照正常业务过程中保存的方式提交，或者应进行整理和标注，使其与这些请求中的类别相对应。\n\n5. 本文所载的每项请求均延及所有文件：(a) 在贵方占有、保管或控制之下的；或 (b) 在任何代表贵方行事之人占有、保管或控制之下的，\n案件 22-50073 文件 3193 提交日期 05/16/24 录入日期 05/16/24 10:28:21 第 29 页，共 439 页\n包括贵方的律师或其他代表及顾问。每份文件均应完整提交。\n\n6. 如要求贵方提交一份已不再由贵方占有、保管或控制的文件，则贵方的答复必须：(a) 详细说明该文件的性质及其内容；(b) 确认编制或起草该文件之人（如适用，亦确认该文件被发送给的人员）；(c) 确认该文件编制或制作的日期；(d) 说明该文件是否 (i) 遗失或丢失，(ii) 已被销毁，(iii) 已自愿或非自愿地转移给他人，或 (iv) 以其他方式处置；(e) 说明该等处置的理由，以及围绕该等处置的事实和情形；(f) 确认授权该等处置的人员；(g) 确认该等处置的日期或大致日期；(h) 说明该文件最后一次由贵方占有、保管或控制的时间；以及 (i) 确认目前占有、保管或控制该文件的人员（如有）。\n\n7. 如要求贵方提交一份已被销毁的文件，则除前述指示所要求的信息外，贵方的答复还必须说明：(a) 销毁该文件的理由；(b) 销毁该文件之人的身份；以及 (c) 指示销毁该文件之人的身份。\n\n8. 如贵方主张所请求的文件享有特权或属于律师工作成果，则贵方的答复必须：(a) 说明：(i) 足以支持贵方关于该文件享有特权之主张的文件描述，(ii) 文件标题，(iii) 文件日期，(iv) 文件作者，(v) 文件收件人，(vi) 收到或查阅该文件原件或任何草稿、副本或复制件的每一人员的身份，(vii) 该文件本身或该文件中所载或提及的任何信息，是否由任何其他人员占有、保管或控制；如是，则说明该等人员的身份，\n案件 22-50073 文件 3193 提交日期 05/16/24 录入日期 05/16/24 10:28:21 第 30 页，共 439 页\n以及说明该等信息如何进入其占有；(viii) 据以扣留该文件的特权主张；以及 (ix) 贵方将据以支持该等特权主张的所有情形；以及 (b) 就根据 D. Conn. L. Civ. R. 26(e) 基于特权主张而扣留的每份文件，提交一份载有本指示第 (a) 部分所要求全部信息的特权清单。对于文件请求中未提出特权或工作成果主张的任何部分，应完整提供回应性文件。\n\n9. 如一份原本具有回应性的文件的一部分含有受特权主张约束的信息，则仅应依照上述指示从该文件中删除或遮蔽受该特权主张约束的部分，其余部分应予提交。\n\n10. 该等请求具有持续性。现指示贵方：(a) 一旦得知先前答复不完整或不正确，应立即补充或更正其后得知不完整或不正确的任何答复；以及 (b) 提交传票所要求的任何其他文件。\n\n11. 如文件使用非英语语言，贵方应提供该文件。如文件使用非英语语言且存在英文译本，贵方应同时提供两份文件。\n\n12. 对实体的所有提及均包括其所有关联方。\n\n13. 对个人姓名的所有提及均包括所有其他名称、别名或昵称。\n\n14. 除非另有明确说明，文件请求涵盖的期间为自 February 5, 2012 起至文件请求答复到期之日止。\nII. 解释规则\n\n15. (a) 任何单数名词的使用均应解释为包括复数，反之亦然；以及 (b) 任何时态的动词均应解释为使用该动词的所有其他时态。\n\n16. (a) “and”和“or”应在必要时解释为连词或选择词，以使原本可能被解释为不在任何请求范围内的所有答复均纳入该请求范围；以及 (b) “each”和“any”应视为包括并涵盖“every”和“all”。\nIII. 定义\n\n根据 D. Conn. Bankr. L.R. 2004-1(a) 纳入的 D. Conn. L. Civ. R. 26(c) 所规定的定义，以及 D. Conn. L. Civ. R. 26(d) 所规定的解释规则，适用于文件请求。此外，本文件请求中使用的下列术语具有下列含义：\n\n1. “You”或“Your”或“Yourself”系指 China CITIC Bank International（中信银行（国际）），连同其所有关联方、部门、机构、工具性机构、处室、办事处、合伙人、高级职员、董事、代理人、律师、代表、雇员和/或任何代表其行事之人。\n\n案件 22-50073 文件 3193 提交日期 05/16/24 录入日期 05/16/24 10:28:21 第 32 页，共 439 页\n\n2. “Debtor”系指 Ho Wan Kwok（郭文贵）（又名 Miles Kwok、Miles Guo、Guo Wengui、Guo Haoyun、郭文贵或任何其他别名），连同其雇员、代理人、律师、顾问或任何代表其行事之人。\n\n3. “Debtor's Son”系指 Qiang Guo（郭强）（又名 Mileson Kwok、郭强或任何其他别名），连同其雇员、代理人、律师、顾问或任何代表其行事之人。\n\n4. “Debtor's Daughter”系指 Mei Guo（郭美）（又名 Mei Gui、郭美或任何其他别名），连同其雇员、代理人、律师、顾问或任何代表其行事之人。\n\n5. “Debtor's Purported Wife”系指 Hing Chi Ngok（岳庆芝）（又名 Hing Chi Ng、Yue Qingzhi、岳庆芝或任何其他别名），连同其雇员、代理人、律师、顾问或任何代表其行事之人。\n\n6. “Debtor's Family”单独及合称指债务人、债务人的儿子、债务人的女儿和债务人声称的妻子，以及与债务人存在任何其他家庭关系的人。\n\n7. “2004 Discovery Targets”单独及合称指债务人、债务人的家庭成员、17 Miles, LLC、5780 Saguaro LLC、Aaron Mitchell、ACA Capital Group Limited、Ace Decade Holdings Limited、AI Group Holdings Inc.、Alfa Global Ventures Limited、Alphonso Global Ventures Limited、Ana C. Izquiedo-Henn、Andrew Childe、Anthony DiBattista、Anton Development Limited、Booming Sail New York LLC、Beile Li、Bingshang Jiao、Bravo Luck Limited、Brent Petro Inc.、Celestial Tide Limited、Chris Lee（又名 Nan Li、Mei Guo Xiao Li）、China Golden Spring Group (Hong Kong) Ltd.、Crane Advisory Group、Daniel Thomas Podhaskie、Defeng Cao（又名 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 (CA)、G Fashion、G Fashion Hold Co. A. Limited、G\n案件 22-50073 文件 3193 提交日期 05/16/24 录入日期 05/16/24 10:28:21 第 33 页，共 439 页\nFashion Hold Co. B. Limited、G Fashion Media Group Inc.、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、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（又名 Huo Lai）、Haitham Khaled、Hamilton Capital Holdings Inc.、Hamilton Digital Assets Funds SP、Hamilton Investment Management Limited、Hamilton Opportunity Fund SPC、Hamilton PE Funds SP、Holy City Hong Kong Ventures Ltd.、GS Security Solutions Inc.、Alex Hadjcharalambous、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 Currency Clearing Pty. Ltd.、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、Jessica Mastrogiovanni、Jiaming Liu、Jie Zhang、Jovial Century International Limited、Joyord Sportswear Limited、K Legacy Ltd.、Kamel Debeche、Karin Maistrello、Kin Ming Je、Lamp Capital LLC、Lawall & Mitchell, LLC、Leading Shine NY Ltd.、Lexington Property and Staffing, Inc.、Lexington Property and Staffing LLC、Linwan “Irene” Feng、Limarie Reyes、Lihong “Sara” Wei Lafrenz、The Lost Draft LLC、Macaron Limited、Major Lead International Limited、Mary Jiang、MOS Himalaya LLC、Maywind Trading LLC、New York MOS Himalaya LLC、Next\n案件 22-50073 文件 3193 提交日期 05/16/24 录入日期 05/16/24 10:28:21 第 34 页，共 439 页\nTycoon Investments Limited、Nicholas Savio、Nodal Partners, LLC、Qidong Xia、Oasis Tech Limited、O.S.C. Orbit Service Company, LLC、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、Seven Mission Group LLC、Shih Hsin Yu、Sirius Networking Inc.、Taurus Fund LLC、Taurus Management LLC、US Himalaya Capital Inc.、V.X. Cerda & Associates P.A.、Victor Cerda、Voice of Guo Media, Inc.、Wen Xiao、Wencong Wang、William Je、Kin Ming Je 又名 Je Kin Ming、Wise Creation International Limited、Xuebing Wang、Yan Chun Liu、Yinying (Aila) Wang（又名 Xiao Fei Xiang）、Yongbing Zhang、Yongping Yan (Shan Mu) Yue Zhou、Yumei Hao（又名 Ru Shui）、Yvette Wang（又名 Yanping Wang，又名 Yan Ping Wang）、Zhixuan Li、Zhouer “Joe” Wang、NewPeople LLC、Ziba Limited、New Mulberry PTE Ltd、TD Primrose Limited，以及 Shin Hee-Seup 又名 Hee Seup Shin。\n\n8. “Including”或其任何变体意为“包括但不限于”。\n\n9. “And”和“or”意为“and/or”，并应同时解释为连词和选择词，以最大限度扩展其范围。\n\n10. “Any”、“all”和“each”意为“每一及全部”。\n\n11. “Each”和“every”意为“每一及全部”。\n\n12. “Third Party”系指贵方以外的个人或实体。\n\n13. “Transfer”具有《破产法典》第 101(54) 条赋予该词的含义。\n\n14. “Document”系指属于 Fed. R. Civ. P. 34 范围内的任何信息或物品，并包括但不限于任何种类的每一及全部书面、记录或图形材料，\n\n案件 22-50073 文件 3193 提交日期 05/16/24 录入日期 05/16/24 10:28:21 第 35 页，共 439 页\n\n种类、性质或描述，且现由或曾由您占有、保管或控制的文件，包括电子邮件、以电子形式保存的计算机文件、函件、备忘录、磁带、速记或手写笔记、任何种类的书面表格、图表、蓝图、绘图、草图、曲线图、计划、文章、规格、日记、信函、电报、照片、会议记录、合同、协议、调查报告、计算机打印件、任何种类的数据汇编、电传、传真、电子邮件、短信、即时消息、语音留言、发票、订货单、支票、汇票、对账单、贷项通知单、报告、头寸报告、摘要、索引、书籍、分类账、笔记本、附表、透明胶片、录音制品、目录、广告、宣传材料、电影、录像带、录音带、CD、计算机磁盘、宣传册、小册子、穿孔卡、工时单、推文、社交媒体帖子或任何其他种类的书面或录制材料的所有印刷件和电子副本，以及其所有元数据，无论以何种方式存储（无论为有形形式或电子形式）、记录、制作或复制；并且还包括但不限于上述任何文件的草稿或副本，如其包含原始文件中不存在的任何种类的笔记、评论或标记，或以其他方式与原始文件不完全相同。\n\n15. “人员”是指个人、公司、独资企业、合伙企业、协会或任何其他实体。“人员”还包括任何代理人、代表或专家，包括但不限于律师或财务顾问。\n\n16. “实体”是指任何自然人、公司、合伙企业、子公司、独资企业、商号、董事会、合资企业、协会、机构、主管机关、委员会或其他商业实体或法人，以及任何关联方、代理人、母公司，包括但不限于法律顾问、财务顾问或任何其他代表。\n案件 22-50073 文件 3193 提交日期 05/16/24 登记日期 05/16/24 10:28:21 第 36 页，共 439 页\n\n17. “关于”是指涉及、描述、构成、提及、与之相关、支持、赞成、反对、强化、削弱、位于其中、与之结合考虑、与之有关、证明、表明、报告、记录、暗示、回应、与之相连、评论、就其而言、有关、与之相关、讨论、显示、描述、反映、分析、构成及为其一部分。\n\n18. 当提及任何特定事项时，“与……有关”、“涉及”或“相关”是指，包括但不限于，构成、包含、涉及、载有、体现、反映、识别、陈述、直接或间接提及该特定已识别事项，或以任何方式与该特定已识别事项相关的任何文件。\n\n19. “通信”在最广泛的可能意义上且不受限制地，是指任何信息或知识的传递（以事实、观念、询问或其他形式）。通信还指所有谈话、协议、询问或答复，无论是当面、通过电话、书面方式，或通过电子传输设备进行，并且包括但不限于所有函件、电子邮件、录音、传送单、备忘录、电话通信、语音留言、电报、电传传真、复印传真、电传、即时消息、聊天、短信、在留言板或群聊中的发布、社交媒体帖子、推文、上传至任何视频平台的视频、电话笔记，或在内部或与第三方之间传送的笔记。\n\n20. “资产”是指受占有、保管或控制的任何具有经济价值的项目。资产包括所有不动产和动产，包括但不限于房地产、土地、房屋、公寓、共管公寓、汽车、游艇、船只、飞机、喷气式飞机、直升机、现金、银行账户、加密货币、证券、应收账款、存货及其他有形和无形财产。\n\nIV. 应提交的文件\n\n1. 与任何由任何 2004 年调查对象持有、控制、代表其持有或以其他方式与其相关的账户有关的所有文件，包括任何及所有账户对账单、授权书、委托书、信托文件、指示或表格、已注销支票副本、函件，以及电汇及相关函件和指示。\n\n2. 与任何属于、由任何 2004 年调查对象持有、控制、代表其持有或以其他方式与其相关的资金、证券、财产或资产有关的所有文件，包括任何及所有账户对账单、授权书、委托书、信托文件、指示或表格、已注销支票副本、函件，以及电汇及相关函件和指示。\n\n3. 与同任何 2004 年调查对象进行的任何商业、贸易或金融交易有关的所有文件，包括但不限于任何贷款、信用额度、寄托、存款、互换、证券交易、抵押贷款或 ISDA，包括任何及所有账户对账单、授权书、委托书、信托文件、指示或表格、已注销支票副本、函件，以及电汇及相关函件和指示。\n\n4. 与涉及 2004 年调查对象的任何电汇活动有关的所有文件，无论是否存在任何账户，包括但不限于所有电汇收据、账号、余额、授权书、与转账当事人有关的身份识别信息、函件、指示或其他记录。\n\n5. 与您和 2004 年调查对象之间的任何函件和通信有关的所有文件。\n\n6. 与任何 2004 年调查对象的任何账户有关的所有文件，涉及账户开立、账户获授权使用人及账户维护。\n案件 22-50073 文件 3193 提交日期 05/16/24 登记日期 05/16/24 10:28:21 第 38 页，共 439 页\n\n7. 与任何涉及任何 2004 年调查对象的反洗钱、了解你的客户或其他合规活动有关的所有文件，包括但不限于由任何 2004 年调查对象提供或由您获知的任何信息。\n\n8. 与来自任何国家的任何监管机构进行的、涉及任何 2004 年调查对象的任何通信有关的所有文件，包括但不限于 Bank of England（英格兰银行）、United States Federal Reserve（美国联邦储备系统）、S.E.C.（美国证券交易委员会）、CFTC（美国商品期货交易委员会）、FINRA（美国金融业监管局）、China Securities Regulatory Commission（中国证券监督管理委员会）、People's Bank of China（中国人民银行）、Hong Kong Securities and Futures Commission（香港证券及期货事务监察委员会）及 Hong Kong Monetary Authority（香港金融管理局）。\n\n附件 C-2\nB2540（表格 2540——规则 2004 调查传票）（12/15）案件 22-50073 文件 3193 提交日期 05/16/24 登记日期 05/16/24 10:28:21 第 40 页，共\n\n美国破产法院\n\nDistrict of Connecticut（康涅狄格地区）\n\n关于 HO WAN KWOK（郭文贵）等，\n\n1 案件编号 22-50073 (JAM) 债务人 第 11 章\n\n（合并管理）\n规则 2004 调查传票\n\n致：Intesa Sanpaolo SpA（意大利联合圣保罗银行股份公司）\n\n（传票所指向人员的姓名）\n\n作证：现命令您于下文规定的时间、日期和地点出席，并根据《联邦破产程序规则》规则 2004 在调查中作证。随附准许该调查的法院命令副本。\n\n地点　日期和时间\n\n不适用　不适用\n\n调查将通过以下方式记录：不适用\n\n提交：您或您的代表还必须携带下列文件、电子存储信息或物件出席调查，并必须允许对该材料进行检查、复制、测试或抽样：\n见随附的文件提交请求。\n\n《联邦民事诉讼规则》45 的下列规定，根据《联邦破产程序规则》9016 适用于破产案件，现随附于后——关于履行地点的规则 45(c)；关于作为传票对象之人员的保护的规则 45(d)；以及关于您对本传票的答复义务和未作答复之潜在后果的规则 45(e) 和 45(g)。\n\n日期：May , 2024\n\n法院书记员\n\n或\n\n书记员或副书记员签名　律师签名\n\n签发或请求本传票、代表第 11 章受托人 Luc A. Despins（卢克·A·德斯平斯）的律师姓名、地址、电子邮件地址及电话号码如下：\n\nPatrick R. Linsey, Esq.（帕特里克·R·林赛律师）；Neubert, Pepe & Monteith, P.C.（诺伊伯特、佩佩和蒙蒂思专业公司）；195 Church Street, 13th Floor, New Haven, Connecticut 06510；plinsey@npmlaw.com；(203) 781-2847\n\n向签发或请求本传票之人员的通知\n\n如本传票要求在审判前提交文件、电子存储信息或有形物品，或检查场所，则必须在向传票所指向人员送达之前，向各方当事人送达通知及本传票副本。Fed. R. Civ. P. 45(a)(4)。\n\n软件版权 (c) 1996-2022 Best Case, LLC（贝斯特凯斯有限责任公司）- www.bestcase.com Best Case Bankruptcy（贝斯特凯斯破产软件）1 本第 11 章案件中的债务人为 Ho Wan Kwok（郭文贵，亦称 Guo Wengui、Miles Guo 和 Miles Kwok，以及众多其他别名）（税务识别号码后四位：9595）、Genever Holdings LLC（税务识别号码后四位：8202）及 Genever Holdings Corporation。受托人、Genever Holdings LLC 和 Genever Holdings Corporation 的邮寄地址为 Paul Hastings LLP（普衡律师事务所），200 Park Avenue, New York, NY 10166，转交 Luc A. Despins，作为 Ho Wan Kwok 遗产的受托人（仅为通知和通信之目的）。\n\n送达证明\n\n（除非 Fed. R. Civ. P. 45 要求，否则本节不应向法院提交。）\n\n本人于（日期）收到针对（个人姓名及职务，如有）的本传票。\n\n本人按以下方式向所列人员交付副本，以送达本传票：\n\n于（日期）；或\n\n本人未予执行而退回本传票，原因是：\n\n除非本传票代表美国或其官员或代理人签发，本人还已向证人支付一天出席的费用及法律允许的里程费，金额为 \\$ 。\n\n本人的旅费为 \\$，服务费为 \\$，合计为 \\$ 。\n\n本人在伪证处罚的惩罚下声明，该等信息真实且正确。\n\n日期：\n\n送达人签名\n\n印刷体姓名及职务\n\n送达人地址\n\n关于尝试送达等事项的补充信息：\n\n《联邦民事诉讼规则》45(c)、(d)、(e) 和 (g)（于 12/1/13 生效）（根据《联邦破产程序规则》规则 9016 适用于破产案件）\n(c) 履行地点。\n\n(1) 对于审判、听证或证言录取。传票仅可按下列方式命令某人出席审判、听证或证言录取：\n\n(A) 在该人员居住、受雇或经常亲自进行商业交易地点的 100 英里范围内；或\n\n(B) 在该人员居住、受雇或经常亲自进行商业交易所在州内，若该人员\n\n(i) 是当事人或当事人的高级人员；或\n\n(ii) 被命令出席审判且不会产生重大费用。\n\n(2) 对于其他证据开示。传票可以命令：\n\n(A) 在该人员居住、受雇或经常亲自进行商业交易地点的 100 英里范围内某一地点提交文件、电子存储信息或物品；以及\n\n(B) 在应受检查的场所检查该场所。\n\n(d) 对作为传票对象之人员的保护；执行。\n\n(1) 避免不当负担或费用；制裁。负责签发和送达传票的一方当事人或律师必须采取合理措施，避免对作为传票对象的人员施加不当负担或费用。要求履行的地区法院必须执行该义务，并对未遵守者——无论是当事人还是律师——施加适当制裁，该制裁可包括损失的收入和合理的律师费。\n\n(2) 命令提交材料或允许检查。\n\n(A) 无需出庭。被命令出示文件、电子存储信息或有形物品，或允许检查场所的人，无需亲自到出示或检查地点出庭，除非其还被命令为证言录取、听证或审判而出庭。\n\n(B) 异议。被命令出示文件或有形物品，或允许检查的人，可以向传票中指定的当事人或律师送达书面异议，反对检查、复制、测试或抽样任何或全部材料，或反对检查场所——或反对以所要求的一种或多种形式出示电子存储信息。异议必须在规定的遵从时间届满前或传票送达后 14 天内（以较早者为准）送达。提出异议后，适用下列规则：\n\n(i) 送达方可随时在通知被命令者后，向要求遵从所在地辖区的法院提出动议，请求作出强制出示或检查的命令。\n\n(ii) 仅可依照命令的指示要求实施这些行为，且该命令必须保护并非当事人或当事人高级职员的人免于承担因遵从而产生的重大费用。\n\n(3) 撤销或修改传票。\n\n(A) 必须撤销或修改的情形。经及时提出动议，要求遵从所在地辖区的法院必须撤销或修改以下传票：\n\n(i) 未给予合理遵从时间的；\n\n(ii) 要求某人在 Rule 45(c) 规定的地理范围以外遵从的；\n\n(iii) 要求披露享有特权或受其他保护的事项，且不适用任何例外或豁免的；或\n\n(iv) 使某人承受不当负担的。\n\n(B) 可以撤销或修改的情形。为保护受传票约束或影响的人，要求遵从所在地辖区的法院可经动议，在传票要求下列事项时撤销或修改传票：\n\n(i) 披露商业秘密或其他保密的研究、开发或商业信息；或\n\n(ii) 披露未受聘专家的意见或信息，该等意见或信息并未描述争议中的具体事件，且源于该专家未经任何当事人要求进行的研究。\n\n(C) 将规定条件作为替代方案。在 Rule 45(d)(3)(B) 所述情形下，法院可以不撤销或修改传票，而是在送达方符合下列条件时，命令在规定条件下出庭或出示：\n\n(i) 证明对该证言或材料具有实质性需要，且若无不当困难则无法以其他方式满足该需要；并且\n\n(ii) 确保被传唤人将获得合理补偿。\n\n(e) 对传票作出回应的义务。\n\n(1) 出示文件或电子存储信息。下列程序适用于出示文件或电子存储信息：\n\n(A) 文件。对要求出示文件的传票作出回应的人，必须按照文件在正常业务过程中保存的方式出示文件，或者必须将文件整理并标记，使其与请求中的类别相对应。\n\n(B) 未规定电子存储信息出示形式。如果传票未规定电子存储信息的出示形式，作出回应的人必须以其通常保存的一种或多种形式，或者以合理可使用的一种或多种形式出示该信息。\n\n(C) 电子存储信息仅以一种形式出示。作出回应的人无需以一种以上形式出示相同的电子存储信息。\n\n(D) 无法合理获取的电子存储信息。作出回应的人无需就其认定为因不当负担或费用而无法合理获取的来源中的电子存储信息提供证据开示。对于强制证据开示的动议或保护令动议，作出回应的人必须证明该信息因不当负担或费用而无法合理获取。如作出该证明，若提出请求的一方在考虑 Rule 26(b)(2)(C) 的限制后证明具有正当理由，法院仍可命令对该等来源进行证据开示。法院可以规定证据开示的条件。\n\n(2) 主张特权或保护。\n\n(A) 被扣留的信息。以该信息享有特权或作为审判准备材料受到保护为由而扣留被传唤信息的人必须：(i) 明确提出该主张；并且\n\n(ii) 以一种方式说明被扣留文件、通信或有形物品的性质，该方式在不披露本身享有特权或受保护的信息的情况下，使当事人能够评估该主张。\n\n(B) 已出示的信息。如果为回应传票而出示的信息受到特权主张或作为审判准备材料受到保护的主张约束，提出该主张的人可以将该主张及其依据通知收到该信息的任何当事人。收到通知后，当事人必须立即返还、隔离保管或销毁所指定的信息及其所持有的任何副本；在该主张得到解决之前，不得使用或披露该信息；如该当事人在收到通知前已披露该信息，必须采取合理措施追回该信息；并且可以立即向要求遵从所在地辖区的法院密封提交该信息，以裁定该主张。出示该信息的人必须在该主张得到解决前保存该信息。\n\n(g) 藐视法庭。要求遵从所在地辖区的法院——以及在动议被移送后，签发传票的法院——可以以藐视法庭罪惩处已被送达但无充分理由不遵从传票或与其相关命令的人。\n\n如需获取传票材料，请参见 Fed.R.Civ.P.45(a) Committee Note (2013)\n\n……\n\n文件出示请求\n\nI. 指示\n\n1. 除非另有说明，下列文件请求（以下简称“请求”，每一项以下简称“一项请求”）必须分别且具体地作出回应。每项请求均应得到完整答复，除非基于善意提出异议；如提出异议，应按如下规定详细说明贵方异议的理由。如异议仅涉及一项请求的一部分，或其中所含的一个词、短语或条款，贵方仅须说明对该部分的异议，并对请求的其余部分作出回应。\n\n2. 电子存储信息必须依照下列指示出示：\n\na. 图像。黑白图像必须为 300 DPI Group IV 单页 TIFF 文件。彩色图像必须以 JPEG 格式出示。文件名不得包含嵌入空格或特殊字符（包括逗号）。文件夹名称不得包含嵌入空格或特殊字符（包括逗号）。所有 TIFF 图像文件必须具有唯一文件名，即 Bates 编号。每张图像的右下角必须标注连续的 Bates 编号。每个文件夹中的 TIFF 文件数量不得超过 1000 个。Excel 电子表格应有一张以文件 Bates 编号命名的占位图像。\n\nb. 图像加载文件\n\na. Concordance® 数据文件。数据文件（.DAT）包含将被加载至 Concordance® 数据库的全部字段化信息。.DAT 文件的第一行必须是标明字段名称的标题行。.DAT 文件必须使用下列 Concordance® 默认分隔符：逗号 ASCII 字符（020）引号 þ ASCII 字符（254）。日期字段应以 mm/dd/yyyy 格式提供。日期和时间字段必须为两个独立字段。如文件包括已成像的电子邮件及附件，必须包含附件字段，以保留电子邮件与其附件之间的父项/子项关系。必须包含 OCRPATH 字段，以提供已出示存储介质上提取文本文件的文件路径和名称。文本文件必须以 FIRSTBATES 命名。不得在 .DAT 文件中包含文本。对于含有原生文件的文件，必须包含 LINK 字段，以提供原生文件的文件路径和名称。原生文件必须以 FIRSTBATES 命名。\n\nb. Concordance Image® 或 Opticon 交叉引用文件。图像交叉引用文件（.LOG 或 .OPT）将图像链接至数据库记录。该文件应为以逗号分隔的文件，每行由七个字段组成，数据库中每张图像均应在交叉引用文件中有一行，格式如下：ImageID,VolumeLabel,ImageFilePath,DocumentBreak,FolderBreak,Box Break,PageCoun。\n\nc. 文件文本。文本必须作为独立文本文件出示，而非作为 .DAT 文件中的字段。文本文件的完整路径（OCRPATH）应包含在 .DAT 文件中。建议使用文件级 ANSI 文本文件，并按 FIRSTBATES/Image Key 命名。提取的文本文件必须置于单独文件夹中，每个文件夹中的文本文件数量不得超过 1,000 个。文件夹名称中不得有特殊字符（包括逗号）。文本文件必须按文件级别提供。\n\nd. 特定文件类型的原生格式出示。为充分理解其内容和含义而合理需要以原生格式查看的文件类型，必须以原生格式出示。这些包括但不限于电子表格、类似电子表格的文件（Microsoft Excel、逗号分隔值、制表符分隔值等）、Microsoft PowerPoint 或其他特殊演示文件、数据库文件以及音频/视频文件。提供一张带有 Bates 编号的隔页图像，以指明原生文件的存在，并在 .dat 文件中以字段形式包含原生文件的路径。以与该文件隔页相对应的 Bates 编号命名所出示的原生文件。将原生文件归入按递增方式命名的“NATIVE”目录中，并与图像目录分开。\n\ne. 去重。对于存在完全重复副本的每份电子文件，仅出示一个副本。对于电子邮件，将基于由 BCC、Body、CC、From、IntMsgID、To 和 Attach 属性生成的 MD5 哈希值合并重复项。对于电子邮件附件和独立电子文件，将基于整个文件的 MD5 哈希值合并重复项。\n\nf. 元数据。以符合 Concordance 要求的加载文件（.dat）形式，为每份文件出示提取的元数据。.DAT 文件的第一行必须是标明字段名称的标题行。.DAT 文件必须使用下列 Concordance 默认分隔符：逗号 , ASCII 字符（020）引号 þ ASCII 字符（254）\n\n日期字段应以 mm/dd/yyyy 格式提供。日期和时间字段必须为两个独立字段。下列为所需元数据：\n\n字段名称　示例数据　说明\n\nFIRSTBATES　EDC0000001　原生文件文档/电子邮件的首个 Bates 编号\nLASTBATES　EDC0000001　原生文件文档/电子邮件的最后 Bates 编号\nLASTBATES 字段应当填写\n单页文件\nATTACHRANGE　EDC0000001\n-　母文档第一页的 Bates 编号\nEDC0000015　至最后一个附件“子”文档最后一页的 Bates 编号\nBEGATTACH　EDC0000001　附件范围的首个 Bates 编号\nENDATTACH　EDC0000015　附件范围的最后 Bates 编号\nCUSTODIAN　Smith, John（约翰·史密斯）　电子邮件：该电子邮件所在的邮箱\n原生文件：该文档源自其文件的个人或部门名称\nFROM　John Smith（约翰·史密斯）　电子邮件：发件人\n原生文件：文档作者\n应使用分号分隔\n多个条目\nTO　Coffman, Janice（贾尼斯·科夫曼）; LeeW（李W）　收件人\n[mailto:LeeW@MSN.com]　应使用分号分隔多个\n条目\nCC　Frank Thompson（弗兰克·汤普森） [mailto:　抄送收件人\nfrank_Thompson@cdt.com]　应使用分号分隔\n多个条目\nBCC　John Cain（约翰·凯恩）　密送收件人\n应使用分号分隔\n多个条目\nSUBJECT　Board Meeting Minutes（董事会会议纪要）　电子邮件：电子邮件主题行；原生文件：文档标题\n（如有）\nFILE_NAME　BoardMeetingMinutes.docx　原生文件：原始原生文件名称，\n包括扩展名\nDATE_SENT　10/12/2010　电子邮件：电子邮件发送日期\n原生文件：（空）\nTIME_SENT/　07:05 PM GMT　电子邮件：电子邮件发送时间/电子邮件所采用的\nTIME_ZONE　标准化时区\nTIME_ZONE　GMT　在转换过程中，\n电子邮件\n被标准化所采用的\n时区。\nLINK　EDC0000001.msg　电子邮件或原生文件文档的超链接\n链接文件必须按照\nFIRSTBATES 编号命名\nFILE_EXTEN　MSG　表示\n电子邮件或\n原生文件的文件类型扩展名\nAUTHOR　John Smith（约翰·史密斯）　电子邮件：（空）\n原生文件：文档作者\nDATE_CREATED　10/10/2010　电子邮件：（空）\n原生文件：文档创建日期\n\nTIME_CREATED　10:25 AM　电子邮件：（空）\n\n原生文件：文档创建时间\n该数据必须为独立字段，且不得\n与 DATE_CREATED 字段合并\nDATE_MOD　10/12/2010　电子邮件：（空）\n原生文件：文档最后修改日期\nTIME_MOD　07:00 PM　电子邮件：（空）\n原生文件：文档最后修改时间\n该数据必须为独立字段，且不得\n与 DATE_MOD 字段合并\nDATE_ACCESSD　10/12/2010　电子邮件：（空）\n原生文件：文档最后访问日期\nTIME_ACCESSD　07:00 PM　电子邮件：（空）\n原生文件：文档最后访问时间\n该数据必须为独立字段，且不得\n与 DATE_ACCESSD 字段合并\nFILE_SIZE　5,952　原生文件文档/电子邮件的大小，\n单位为 KB\nPGCOUNT　1　原生文件文档/电子邮件中的页数\nPATH　电子邮件：（空）\nAgenda.doc　原生文件：存储原生文件文档的路径，\n包括原始文件名称。\nINTFILEPATH　Personal Folders\\Deleted　电子邮件：电子邮件的原始位置，包括\nItems\\Board Meeting　原始文件名称。\nMinutes.msg　原生文件：（空）\nINTMSGID　<000805c2c71b\\$75977050\\$　电子邮件：唯一消息 ID；原生文件：（空）\ncb8306d1@MSN>\nMD5HASH　d131dd02c5e6eec4693d9a0　文档的 MD5 哈希值。\n698aff95c\n2fcab58712467eab4004583e\nb8fb7f89\nOCRPATH　TEXT/001/EDC0000001.txt　原生文件提取文本的路径\n\n3. 各项请求独立运作并应独立解释，除非另有说明，任何一项请求均不限制任何其他请求的范围。\n\n4. 所有文档应按其在通常业务过程中保存的方式提供，或者应予整理并标注，以对应本请求中的类别。\n\n5. 本文所载各项请求均延及下列所有文档：(a) 由您占有、保管或控制的文档；或 (b) 由任何代表您行事之人占有、保管或控制的文档，\n案件 22-50073 文书 3193 提交于 05/16/24 录入于 05/16/24 10:28:21 第 47 页，共 439 页\n\n包括您的律师或其他代表及顾问。各份文档均应完整提供。\n\n6. 如要求您提供一份已不再由您占有、保管或控制的文档，则您的答复必须：(a) 详细说明该文档的性质及其内容；(b) 识别编制或撰写该文档的人员（以及，如适用，该文档被发送给的人员）；(c) 识别该文档编制或创建的日期；(d) 说明该文档是否：(i) 遗失或丢失，(ii) 已被销毁，(iii) 自愿或非自愿地转让给他人，或 (iv) 以其他方式处置；(e) 说明该等处置的原因，以及围绕该等处置的事实和情形；(f) 识别授权该等处置的人员；(g) 识别该等处置的日期或大致日期；(h) 说明该文档最近一次由您占有、保管或控制的时间；以及 (i) 识别目前占有、保管或控制该文档的人员（如有）。\n\n7. 如要求您提供一份已被销毁的文档，则除前述指示所要求的信息外，您的答复还必须说明：(a) 销毁该文档的原因；(b) 销毁该文档的人员身份；以及 (c) 指示销毁该文档的人员身份。\n\n8. 如您主张所请求的文档享有特权或属于律师工作成果，则您的答复必须：(a) 说明：(i) 足以支持您关于该文档享有特权之主张的文档描述，(ii) 文档标题，(iii) 文档日期，(iv) 文档作者，(v) 文档收件人，(vi) 收到或看过该文档原件或任何草稿、副本或复制件的每一人员身份，(vii) 该文档本身或该文档中包含或提及的任何信息是否由任何其他人员占有、保管或控制；如是，则应说明该等人员的身份，以及说明该等信息如何进入其占有，\n案件 22-50073 文书 3193 提交于 05/16/24 录入于 05/16/24 10:28:21 第 48 页，共 439 页\n\n(viii) 据以扣留该文档的特权主张，以及 (ix) 您将据以支持该等特权主张的全部情形；以及 (b) 根据 D. Conn. L. Civ. R. 26(e)，就每一份基于特权主张而被扣留的文档，提供一份特权清单，其中载明本指示第 (a) 部分所要求的全部信息。对于文档请求中未主张特权或工作成果的任何部分，应完整提供回应性文档。\n\n9. 如一份原本具有回应性的文档的一部分含有受特权主张约束的信息，则仅应依照上述指示从该文档中删除或遮蔽受特权主张约束的部分，其余部分应予提供。\n\n10. 各项请求具有持续性。特此指示您：(a) 一旦获知先前答复不完整或不正确，应立即补充或更正任何后来获知不完整或不正确的答复；以及 (b) 提供传票所要求的任何补充文档。\n\n11. 如一份文档使用英语以外的语言，您应提供该文档。如一份文档使用英语以外的语言且存在英文译本，您应同时提供两份文档。\n\n12. 对实体的所有提述均包括其全部关联方。\n\n13. 对个人姓名的所有提述均包括所有替代姓名、别名或昵称。\n\n14. 除非另有明确说明，文档请求所涵盖的期间为自 February 5, 2012 起至应提交文档请求答复之日止。\nII. 解释规则\n\n15. (a) 任何单数名词的使用均应解释为包括复数，反之亦然；以及 (b) 任何时态动词的使用均应解释为该动词在所有其他时态中的使用。\n\n16. (a) “和”与“或”应视需要解释为连词性或选择性用法，以使原本可能被解释为超出任何请求范围的所有答复均纳入该请求范围；以及 (b) “每一”与“任何”应视为包括并涵盖“每个”与“所有”二词。\nIII. 定义\n\n经 D. Conn. Bankr. L.R. 2004-1(a) 纳入的 D. Conn. L. Civ. R. 26(c) 所提供的定义以及 D. Conn. L. Civ. R. 26(d) 所提供的解释规则，适用于文档请求。此外，本文件请求中使用的下列术语具有以下含义：\n\n1. “您”或“您的”或“您本人”是指并包括 Intesa Sanpaolo SpA（意大利联合圣保罗银行股份公司），以及其所有关联方、部门、机构、工具机构、处室、办公室、合伙人、高级职员、董事、代理人、律师、代表、雇员和/或任何代表其行事之人。\n案件 22-50073 文书 3193 提交于 05/16/24 录入于 05/16/24 10:28:21 第 50 页，共 439 页\n\n2. “债务人”是指 Ho Wan Kwok（郭文贵）（又名 Miles Kwok（郭文贵）、Miles Guo（郭文贵）、Guo Wengui（郭文贵）、Guo Haoyun（郭浩云）、郭文贵或任何其他别名），以及其雇员、代理人、律师、顾问或任何代表其行事之人。\n\n3. “债务人之子”是指 Qiang Guo（郭强）（又名 Mileson Kwok（郭强）、郭强或任何其他别名），以及其雇员、代理人、律师、顾问或任何代表其行事之人。\n\n4. “债务人之女”是指 Mei Guo（郭美）（又名 Mei Gui（郭美）、郭美或任何其他别名），以及其雇员、代理人、律师、顾问或任何代表其行事之人。\n\n5. “债务人之所谓妻子”是指 Hing Chi Ngok（岳庆芝）（又名 Hing Chi Ng（岳庆芝）、Yue Qingzhi（岳庆芝）、岳庆芝或任何其他别名），以及其雇员、代理人、律师、顾问或任何代表其行事之人。\n\n6. “债务人家属”是指，单独及合称，债务人、债务人之子、债务人之女及债务人之所谓妻子，以及与债务人具有任何其他亲属关系之人。\n\n7. “2004 年调查对象”是指，单独及合称，债务人、债务人家属、17 Miles, LLC（17 Miles 有限责任公司）、5780 Saguaro LLC（5780 Saguaro 有限责任公司）、Aaron Mitchell（亚伦·米切尔）、ACA Capital Group Limited（ACA 资本集团有限公司）、Ace Decade Holdings Limited（Ace Decade 控股有限公司）、AI Group Holdings Inc.（AI 集团控股公司）、Alfa Global Ventures Limited（Alfa 全球创投有限公司）、Alphonso Global Ventures Limited（Alphonso 全球创投有限公司）、Ana C. Izquiedo-Henn（安娜·C. 伊斯基耶多-亨）、Andrew Childe（安德鲁·柴尔德）、Anthony DiBattista（安东尼·迪巴蒂斯塔）、Anton Development Limited（Anton 开发有限公司）、Booming Sail New York LLC（Booming Sail 纽约有限责任公司）、Beile Li（李贝乐）、Bingshang Jiao（焦冰尚）、Bravo Luck Limited（Bravo Luck 有限公司）、Brent Petro Inc.（Brent Petro 公司）、Celestial Tide Limited（Celestial Tide 有限公司）、Chris Lee（李克里斯）（又名 Nan Li（李楠）、Mei Guo Xiao Li（郭美小李））、China Golden Spring Group (Hong Kong) Ltd.（中国金泉集团〈香港〉有限公司）、Crane Advisory Group（Crane 顾问集团）、Daniel Thomas Podhaskie（丹尼尔·托马斯·波德哈斯基）、Defeng Cao（曹德峰）（又名 Wayne Cao（曹德峰）、Max Cao（曹德峰））、Ding “Ivan” Lin（林鼎〈伊万〉）、Doaa Dashoush（杜阿·达舒什）、Eastern Profit Corporation Limited（东方利润有限公司）、Genever Holdings Corporation（Genever 控股公司）、Genever Holdings LLC（Genever 控股有限责任公司）、Gettr USA, Inc.（Gettr 美国公司）、Gnews Media Group Inc.（Gnews 媒体集团公司）、G Fashion (CA)（G Fashion〈CA〉）、G Fashion（G Fashion）、G Fashion Hold Co. A. Limited（G Fashion Hold Co. A. 有限公司）、G\n案件 22-50073 文书 3193 提交于 05/16/24 录入于 05/16/24 10:28:21 第 51 页，共 439 页\n\nFashion Hold Co. B. Limited（时尚控股公司B有限公司）、G Fashion Media Group Inc.（G时尚媒体集团公司）、G Fashion International Limited（G时尚国际有限公司）、G Fashion LLC（G时尚有限责任公司）、Gmusic LLC（G音乐有限责任公司）、Gnews LLC（G新闻有限责任公司）、Geducation（G教育）、GFNY, Inc.（GFNY公司）、G Club Finance（G俱乐部金融）、G Club HoldCo I LLC（G俱乐部控股公司I有限责任公司）、G Club International Limited（G俱乐部国际有限公司）、G Club Investments Limited（G俱乐部投资有限公司）、G Club Operations LLC（G俱乐部运营有限责任公司）、G Club US Operations Inc.（G俱乐部美国运营公司）、G Club US Operations LLC（G俱乐部美国运营有限责任公司）、G Club（G俱乐部）、G Club One（G俱乐部一号）、G Club Two（G俱乐部二号）、G Club Three（G俱乐部三号）、G Live, LLC（G直播有限责任公司）、Gbroadcast, LLC（G广播有限责任公司）、GM 27 LLC（GM 27有限责任公司）、Gladys Chow（周格拉迪斯）、Golden Spring (New York) Ltd.（金泉〈纽约〉有限公司）、Gposts LLC（G帖子有限责任公司）、GTV Media Group, Inc.（GTV媒体集团公司）、Gypsy Mei Food Service LLC（吉普赛美食品服务有限责任公司）、Gypsy Mei Productions LLC（吉普赛美制作有限责任公司）、Gypsy Mei 27 Vestry, Inc.（吉普赛美27 Vestry公司）、Dawn State Limited（黎明州有限公司）、Greenwich Land LLC（格林尼治地产有限责任公司）、Hao (Gavin) Li (a/k/a Huo Lai)（李浩〈加文〉，又名霍来）、Haitham Khaled（海赛姆·哈立德）、Hamilton Capital Holdings Inc.（汉密尔顿资本控股公司）、Hamilton Digital Assets Funds SP（汉密尔顿数字资产基金SP）、Hamilton Investment Management Limited（汉密尔顿投资管理有限公司）、Hamilton Opportunity Fund SPC（汉密尔顿机会基金SPC）、Hamilton PE Funds SP（汉密尔顿私募股权基金SP）、Holy City Hong Kong Ventures Ltd.（圣城香港创投有限公司）、GS Security Solutions Inc.（GS安保解决方案公司）、Alex Hadjcharalambous（亚历克斯·哈吉查拉兰布斯）、Han Chunguang（韩春光）、Haoran He（何浩然）、HCHK Property Management, Inc.（HCHK物业管理公司）、HCHK Technologies, Inc.（HCHK科技公司）、HK International Funds Investments (USA) Limited LLC（香港国际基金投资〈美国〉有限责任公司）、Freedom Media Ventures Ltd.（自由媒体创投有限公司）、FungWan Trading Inc.（丰万贸易公司）、Himalaya Currency Clearing Pty. Ltd.（喜马拉雅货币清算有限公司）、Himalaya New World Inc.（喜马拉雅新世界公司）、Himalaya International Financial Group Ltd.（喜马拉雅国际金融集团有限公司）、Himalaya International Clearing Ltd.（喜马拉雅国际清算有限公司）、Himalaya International Payments Ltd.（喜马拉雅国际支付有限公司）、Himalaya International Reserves Ltd.（喜马拉雅国际储备有限公司）、Himalaya Ventures LLC（喜马拉雅创投有限责任公司）、Himalaya Investment LLC（喜马拉雅投资有限责任公司）、Hudson Diamond Holding, Inc.（哈德逊钻石控股公司）、Hudson Diamond Holding LLC（哈德逊钻石控股有限责任公司）、Hudson Diamond NY LLC（哈德逊钻石纽约有限责任公司）、Huk Trading Inc.（胡克贸易公司）、Infinity Treasury Management Inc.（无限资金管理公司）、Jesse Brown（杰西·布朗）、Jessica Mastrogiovanni（杰西卡·马斯特罗焦瓦尼）、Jiaming Liu（刘家明）、Jie Zhang（张杰）、Jovial Century International Limited（乐世纪国际有限公司）、Joyord Sportswear Limited（乔约德运动服饰有限公司）、K Legacy Ltd.（K传承有限公司）、Kamel Debeche（卡迈勒·德贝什）、Karin Maistrello（卡琳·迈斯特雷洛）、Kin Ming Je（谢建明）、Lamp Capital LLC（灯塔资本有限责任公司）、Lawall & Mitchell, LLC（洛沃尔及米切尔有限责任公司）、Leading Shine NY Ltd.（领耀纽约有限公司）、Lexington Property and Staffing, Inc.（列克星敦物业与人力公司）、Lexington Property and Staffing LLC（列克星敦物业与人力有限责任公司）、Linwan \"Irene\" Feng（冯林婉〈艾琳〉）、Limarie Reyes（利马丽·雷耶斯）、Lihong \"Sara\" Wei Lafrenz（魏丽红〈萨拉〉·拉弗伦茨）、The Lost Draft LLC（失落草稿有限责任公司）、Macaron Limited（马卡龙有限公司）、Major Lead International Limited（美卓领航国际有限公司）、Mary Jiang（江玛丽）、MOS Himalaya LLC（MOS喜马拉雅有限责任公司）、Maywind Trading LLC（五月风贸易有限责任公司）、New York MOS Himalaya LLC（纽约MOS喜马拉雅有限责任公司）、Next\n\n案号 22-50073 文书 3193 提交于 05/16/24 录入于 05/16/24 10:28:21 第52页，共439页\n\nTycoon Investments Limited（大亨投资有限公司）、Nicholas Savio（尼古拉斯·萨维奥）、Nodal Partners, LLC（诺达尔合伙人有限责任公司）、Qidong Xia（夏启东）、Oasis Tech Limited（绿洲科技有限公司）、O.S.C. Orbit Service Company, LLC（O.S.C.轨道服务公司有限责任公司）、Pixshow Film Inc.（皮克斯秀电影公司）、Qu Guo Jiao（曲国娇）、Roscalitar 2（罗斯卡利塔尔2）、Ridwan Mamode Saib（里德万·马莫德·赛布）、Ross Heinemeyer（罗斯·海内迈耶）、Rule of Law Society IV Inc.（法治协会IV公司）、Rule of Law Foundation III, Inc.（法治基金会III公司）、Rule of Law Fund（法治基金）、Saraca Media Group Inc.（萨拉卡媒体集团公司）、Savio Law LLC（萨维奥律师事务所有限责任公司）、Scott Barnett（斯科特·巴内特）、Seven Mission Group LLC（七项使命集团有限责任公司）、Shih Hsin Yu（施新宇）、Sirius Networking Inc.（天狼星网络公司）、Taurus Fund LLC（金牛基金有限责任公司）、Taurus Management LLC（金牛管理有限责任公司）、US Himalaya Capital Inc.（美国喜马拉雅资本公司）、V.X. Cerda & Associates P.A.（V.X.塞尔达及合伙人专业协会）、Victor Cerda（维克托·塞尔达）、Voice of Guo Media, Inc.（郭之声媒体公司）、Wen Xiao（肖文）、Wencong Wang（王文聪）、William Je（威廉·谢）、Kin Ming Je a/k/a Je Kin Ming（谢建明，又名谢金明）、Wise Creation International Limited（慧创国际有限公司）、Xuebing Wang（王学兵）、Yan Chun Liu（刘彦春）、Yinying (Aila) Wang (a/k/a Xiao Fei Xiang)（王茵莹〈艾拉〉，又名肖飞翔）、Yongbing Zhang（张永兵）、Yongping Yan (Shan Mu) Yue Zhou（周月舟，又名闫永平〈山木〉）、Yumei Hao (a/k/a Ru Shui)（郝玉梅，又名如水）、Yvette Wang (a/k/a Yanping Wang, a/k/a Yan Ping Wang)（王伊薇特，又名王艳平，又名王燕萍）、Zhixuan Li（李智轩）、Zhouer \"Joe\" Wang（王周二〈乔〉）、NewPeople LLC（新人民有限责任公司）、Ziba Limited（兹巴有限公司）、New Mulberry PTE Ltd（新桑树私人有限公司）、TD Primrose Limited（TD报春花有限公司）以及 Shin Hee-Seup a/k/a Hee Seup Shin（申熙燮，又名熙燮·申）。\n\n8. “包括”或其任何变体，意为“包括但不限于”。\n\n9. “和”及“或”意为“和/或”，并应为最大限度扩大其范围而同时按合取及析取方式解释。\n\n10. “任何”及“所有”以及“每一”均意为“每一及全部”。\n\n11. “每一”及“每个”均意为“每一及全部”。\n\n12. “第三方”是指除您本人以外的个人或实体。\n\n13. “转让”应具有《破产法》section 101(54)赋予其的含义。\n\n14. “文件”是指属于 Fed. R. Civ. P. 34 范围内的任何信息或物品，并包括但不限于，任何种类、类型、性质或描述的每一项书面、记录或图形资料，\n\n案号 22-50073 文书 3193 提交于 05/16/24 录入于 05/16/24 10:28:21 第53页，共439页\n\n该等资料现由或曾由您占有、保管或控制，包括电子邮件的所有纸质及电子副本、以电子形式保存的计算机文件、通信函件、备忘录、磁带、速记或手写笔记、各种书面表格、图表、蓝图、图纸、草图、曲线图、计划、文章、规格说明书、日记、信件、电报、照片、会议记录、合同、协议、调查报告、计算机打印件、任何种类的数据汇编、电传、传真、电子邮件、短信、即时消息、语音留言、发票、订单、支票、汇票、对账单、贷项通知单、报告、头寸报告、摘要、索引、书籍、分类账、笔记本、明细表、透明胶片、录音记录、目录、广告、宣传材料、电影、录像带、录音带、CD、计算机磁盘、宣传册、小册子、穿孔卡、工时单、推文、社交媒体帖子，或任何其他种类的书面或记录材料，以及其所有元数据，无论以何种方式存储（无论为有形或电子形式）、记录、制作或复制；并还包括但不限于上述任何资料的草稿或副本，凡该等草稿或副本含有原始文件中未见的任何种类笔记、评论或标记，或者在其他方面与原始文件不相同者。\n\n15. “个人”是指个人、公司、独资企业、合伙企业、协会或任何其他实体。“个人”还包括任何代理人、代表或专家，包括但不限于律师或财务顾问。\n\n16. “实体”是指任何自然人、公司、合伙企业、子公司、独资企业、商号、董事会、合资企业、协会、机构、主管机关、委员会或其他商业实体或法人，以及任何关联方、代理人、母公司，包括但不限于法律顾问、财务顾问或任何其他代表。\n\n案号 22-50073 文书 3193 提交于 05/16/24 录入于 05/16/24 10:28:21 第54页，共439页\n\n17. “关于”是指涉及、描述、构成、提及、与之相关、支持、有利于、反对、加强、削弱、位于、连同考虑、影响、证明、表明、报告、记录、暗指、回应、与之连接、评论、就其而言、有关、与之相关、讨论、显示、描述、反映、分析、构成及属于。\n\n18. 就任何特定事项而言，“与……有关”、“涉及”或“相关”是指但不限于，构成、包含、涉及、含有、体现、反映、识别、陈述、直接或间接提及，或以任何方式与所识别的特定事项相关的任何文件。\n\n19. “通信”是指以最广泛可能的含义且不限于任何形式，对信息或知识的任何传递（以事实、想法、询问或其他形式）。通信还指所有谈话、协议、询问或答复，无论是当面、通过电话、书面形式或通过电子传输设备进行，并包括但不限于所有函件、电子邮件、录音记录、传送单、备忘录、电话通信、语音留言、电报、电话传真、传真副本、电传、即时消息、聊天、短信、向留言板或群聊发布的帖子、社交媒体帖子、推文、上传至任何视频平台的视频、电话笔记，或在内部或与第三方传送的笔记。\n\n20. “资产”是指受占有、保管或控制的任何具有经济价值的项目。资产包括所有不动产和动产，包括但不限于房地产、土地、房屋、公寓、共有公寓、汽车、游艇、船只、飞机、喷气机、直升机、现金、银行账户、加密货币、证券、应收账款、存货及其他有形和无形财产。\n\nIV. 应提交的文件\n\n1. 与任何由任何2004证据开示对象持有、控制、代表其持有或以其他方式与其有关的账户相关的全部文件，包括任何及所有账户对账单、授权书、授权委托书、信托文件、指示或表格、已注销支票副本、函件，以及电汇及相关函件和指示。\n\n2. 与属于任何2004证据开示对象、由其持有、控制、代表其持有或以其他方式与其有关的任何资金、证券、财产或资产相关的全部文件，包括任何及所有账户对账单、授权书、授权委托书、信托文件、指示或表格、已注销支票副本、函件，以及电汇及相关函件和指示。\n\n3. 与任何2004证据开示对象之间的任何商业、贸易或金融交易相关的全部文件，包括但不限于任何贷款、信贷额度、寄托、存款、掉期、证券交易、抵押贷款或 ISDA，包括任何及所有账户对账单、授权书、授权委托书、信托文件、指示或表格、已注销支票副本、函件，以及电汇及相关函件和指示。\n\n4. 与2004证据开示对象有关的任何电汇活动相关的全部文件，不论是否存在任何账户，包括但不限于所有电汇收据、账号、余额、授权书、与转账当事人有关的身份识别信息、函件、指示或其他记录。\n\n5. 与您和2004证据开示对象之间的任何函件和通信相关的全部文件。\n\n6. 与任何2004证据开示对象的任何账户有关的、涉及开户、该账户获授权使用人及账户维护的全部文件。\n\n案号 22-50073 文书 3193 提交于 05/16/24 录入于 05/16/24 10:28:21 第56页，共439页\n\n7. 与任何2004证据开示对象有关的任何反洗钱、了解你的客户或其他合规活动相关的全部文件，包括但不限于任何2004证据开示对象提供的或您获知的任何信息。\n\n8. 与任何国家的任何监管机构就任何2004证据开示对象进行的任何通信有关的全部文件，包括但不限于 Bank of England（英格兰银行）、the United States Federal Reserve（美国联邦储备系统）、the S.E.C.（美国证券交易委员会）、the CFTC（美国商品期货交易委员会）、FINRA（美国金融业监管局）、China Securities Regulatory Commission（中国证券监督管理委员会）、People's Bank of China（中国人民银行）、Hong Kong Securities and Futures Commission（香港证券及期货事务监察委员会）及 the Hong Kong Monetary Authority（香港金融管理局）。\n\n附件 C-3\n\nB2540（表格2540——Rule 2004 审查传票）（12/15）案号 22-50073 文书 3193 提交于 05/16/24 录入于 05/16/24 10:28:21 第58页，共\n\nUNITED STATES BANKRUPTCY COURT（美国破产法院）\n\nDistrict of Connecticut（康涅狄格区）\n\n关于 HO WAN KWOK（郭文贵）等人，\n\n1 案号 22-50073 (JAM) 债务人 Chapter 11\n\n（合并管理）\n\nRule 2004 审查传票\n\n致：Lloyds Bank PLC（劳埃德银行股份有限公司）\n\n（传票所指向之人的姓名）\n\n作证：兹命令您于下列载明的时间、日期和地点出席，并在依 Federal Rules of Bankruptcy Procedure（联邦破产程序规则）Rule 2004 进行的审查中作证。随附准许该审查的法院命令副本。\n\n地点　日期和时间\n\n不适用　不适用\n\n审查将通过以下方式记录：不适用\n\n提交：您或您的代表还必须在审查时携带下列文件、电子存储信息或物品，并必须准许对该等材料进行检查、复制、测试或抽样：\n\n见随附的文件提交请求。\n\n下列 Fed. R. Civ. P. 45 的规定，依据 Fed. R. Bankr. P. 9016 适用于破产案件，现随附于后——有关履行地点的 Rule 45(c)；有关您作为受传票约束之人的保护的 Rule 45(d)；以及有关您回应本传票的义务及未回应的潜在后果的 Rule 45(e) 和 45(g)。\n\n日期：May , 2024\n\n法院书记官\n\n或\n\n书记官或副书记官签名　律师签名\n\n代表发出或申请本传票的第11章受托人 Luc A. Despins（卢克·A·德斯平斯）的律师姓名、地址、电子邮件地址及电话号码如下：\n\nPatrick R. Linsey, Esq.（帕特里克·R·林西，律师）；Neubert, Pepe & Monteith, P.C.（诺伊伯特、佩佩和蒙蒂思律师事务所）；195 Church Street, 13th Floor, New Haven, Connecticut 06510；plinsey@npmlaw.com；(203) 781-2847\n\n向发出或申请本传票之人的通知\n\n如本传票要求在审判前提交文件、电子存储信息或有形物品，或检查场所，则在向被指名之人送达前，必须向各方送达通知及本传票副本。Fed. R. Civ. P. 45(a)(4)。\n\n软件版权 (c) 1996-2022 Best Case, LLC（贝斯特凯斯有限责任公司）- www.bestcase.com Best Case Bankruptcy 1 本第11章案件中的债务人为 Ho Wan Kwok（郭文贵，亦称 Guo Wengui、Miles Guo 和 Miles Kwok，以及众多其他别名）（税务识别号码后四位：9595）、Genever Holdings LLC（杰纳维尔控股有限责任公司）（税务识别号码后四位：8202）及 Genever Holdings Corporation（杰纳维尔控股公司）。受托人、Genever Holdings LLC 及 Genever Holdings Corporation 的邮寄地址为 Paul Hastings LLP（普衡律师事务所），200 Park Avenue, New York, NY 10166，转交 Luc A. Despins，作为 Ho Wan Kwok 遗产的受托人（仅用于通知及通信目的）。\n\n送达证明\n\n（除非 Fed. R. Civ. P. 45 要求，否则本节不应向法院提交。）\n\n我于（日期）收到本传票，受送达人为（个人姓名及职务，如有）：。\n\n我通过以下方式向被指名之人交付副本，送达本传票：\n\n于（日期）；或\n\n我未予执行而退回本传票，理由如下：\n\n除非本传票代表美国或其官员或代理人发出，我还已向证人支付一天出席费用及法律允许的里程费，金额为 \\$ 。\n\n我的差旅费用为 \\$，服务费用为 \\$，合计 \\$。\n\n我在伪证罪处罚下声明，该等信息真实且正确。\n\n日期：\n\n送达人员签名\n\n正楷姓名及职务\n\n送达人员地址\n\n关于尝试送达等事项的补充信息：\n\nFederal Rule of Civil Procedure 45(c)、(d)、(e) 和 (g)（Effective 12/1/13）（依据 Federal Rules of Bankruptcy Procedure（联邦破产程序规则）Rule 9016 适用于破产案件）\n\n(c) 履行地点。\n\n(1) 审判、听证或证言录取。传票仅可按以下方式命令某人出席审判、听证或证言录取：\n\n(A) 在该人居住、受雇或经常亲自从事经营活动地点的100英里范围内；或\n\n(B) 在该人居住、受雇或经常亲自从事经营活动所在州内，如该人\n\n(i) 为一方当事人或一方当事人的高级职员；或\n\n(ii) 被命令出席审判，且不会产生重大费用。\n\n(2) 其他证据开示。传票可以命令：\n\n(A) 在该人居住、受雇或经常亲自从事经营活动地点的100英里范围内某一地点提交文件、电子存储信息或物品；以及\n\n(B) 在拟检查的场所对该场所进行检查。\n\n(d) 保护受传票约束之人；执行。\n\n(1) 避免不当负担或费用；制裁。负责发出和送达传票的一方当事人或律师必须采取合理措施，避免对受传票约束之人施加不当负担或费用。要求履行的地区法院必须执行该义务，并对未遵守者的一方当事人或律师施加适当制裁，该制裁可包括误工损失和合理律师费。\n\n(2) 要求提交材料或准许检查。\n\n(A) 无须出席。被命令提交文件、电子存储信息或有形物品，或准许检查场所之人，无须亲自出席提交或检查地点，除非同时被命令出席证言录取、听证或审判。\n\n(B) 异议。被命令提交文件或有形物品，或准许检查之人，可向传票中指定的一方当事人或律师送达书面异议，反对检查、复制、测试或抽样全部或部分材料，反对检查场所，或反对以所要求的一种或多种形式提交电子存储信息。异议必须在规定履行时间届满前或传票送达后14日内（以较早者为准）送达。如提出异议，适用以下规则：\n\n(i) 送达方可随时通知被命令之人，并向要求履行的地区法院提出动议，请求作出强制提交或检查的命令。\n\n(ii) 仅可依照命令所指示的方式要求实施该等行为，且该命令必须保护并非当事人或当事人高级职员之人免于承担因履行而产生的重大费用。\n\n(3) 撤销或修改传票。\n\n(A) 必须撤销或修改的情形。经及时动议，要求履行的地区法院必须撤销或修改具有下列情形的传票：\n\n(i) 未给予合理履行时间；\n\n(ii) 要求某人在 Rule 45(c) 规定的地域限制之外履行；\n\n(iii) 要求披露享有特权或受到其他保护的事项，且不存在适用的例外或放弃；或\n\n(iv) 对某人造成不当负担。\n\n(B) 可以撤销或修改的情形。为保护受传票约束或受其影响之人，要求履行的地区法院可经动议撤销或修改要求下列事项的传票：\n\n(i) 披露商业秘密或其他保密研究、开发或商业信息；或\n\n(ii) 披露未受聘专家的意见或信息，该等意见或信息并不描述争议中的具体事件，且源于该专家未经一方当事人请求而进行的研究。\n\n(C) 将规定条件作为替代办法。在 Rule 45(d)(3)(B) 所述情形下，如送达方：\n\n(i) 证明其对无法在不造成不当困难的情况下通过其他方式满足的证言或材料具有重大需要；且\n\n(ii) 确保被传唤之人将获得合理补偿，\n\n法院可不撤销或修改传票，而命令在规定条件下出席或提交。\n\n(e) 回应传票时的义务。\n\n(1) 提交文件或电子存储信息。以下程序适用于提交文件或电子存储信息：\n\n(A) 文件。回应要求提交文件之传票的人，必须按照文件在通常业务过程中保存的方式提交，或必须将其整理并标注，使之与请求中的类别相对应。\n\n(B) 未指定电子存储信息的提交形式。如传票未指定电子存储信息的提交形式，回应之人必须以其通常保存的一种或多种形式，或以合理可用的一种或多种形式提交。\n\n(C) 电子存储信息仅须以一种形式提交。回应之人无须以多于一种形式提交相同的电子存储信息。\n\n(D) 不可合理获取的电子存储信息。回应之人无须对其认定因不当负担或费用而无法合理获取的来源中的电子存储信息提供证据开示。在提出强制证据开示动议或保护令动议时，回应之人必须证明该信息因不当负担或费用而无法合理获取。如作出该证明，法院在考虑 Rule 26(b)(2)(C) 的限制后，如请求方证明存在正当理由，仍可命令从该等来源进行证据开示。法院可为该证据开示规定条件。\n\n(2) 主张特权或保护。\n\n(A) 扣留的信息。基于该信息享有特权或作为审判准备材料而受保护的主张，扣留被传唤信息之人必须：(i) 明确提出该主张；以及\n\n(ii) 以在不披露本身享有特权或受保护信息的前提下，足以使各方评估该主张的方式，描述被扣留文件、通信或有形物品的性质。\n\n(B) 已提交的信息。如为回应传票而提交的信息受特权主张或作为审判准备材料受保护的主张所约束，提出该主张之人可将该主张及其依据通知任何收到该信息的一方当事人。收到通知后，一方当事人必须立即返还、隔离或销毁指定信息及其持有的任何副本；在该主张得到解决前不得使用或披露该信息；如该方在收到通知前已披露该信息，必须采取合理措施追回该信息；并可立即将该信息密封提交给要求履行的地区法院，以裁定该主张。提交该信息之人必须保存该信息，直至该主张得到解决。\n\n(g) 藐视法庭。要求履行的地区法院，以及在动议被移送后发出传票的法院，可对已被送达却无充分理由不遵守传票或相关命令之人，以藐视法庭论处。\n\n欲获取传票材料，请参见 Fed.R.Civ.P.45(a) Committee Note (2013)\n\n…\n\n文件提交请求\n\nI. 指示\n\n1. 除非另有说明，下列文件请求（以下简称“请求”，各称“一项请求”）必须分别且具体地作出回应。每项请求均应得到完整答复，除非基于善意提出异议；如提出异议，应按下文所述详细说明异议理由。如异议仅涉及某项请求的一部分，或其中包含的某一词语、短语或条款，阁下仅须就该部分说明异议，并对其余请求作出回应。\n\n2. 电子存储信息必须按照以下指示提交：\n\na. 图像。黑白图像必须为300 DPI Group IV 单页 TIFF 文件。彩色图像必须以 JPEG 格式提交。文件名不得含有嵌入空格或特殊字符（包括逗号）。文件夹名称不得含有嵌入空格或特殊字符（包括逗号）。所有 TIFF 图像文件必须具有唯一文件名，即 Bates 编号。每个图像右下角必须加注连续的 Bates 编号。每个文件夹内的 TIFF 文件数量不得超过1000个文件。Excel 电子表格应包含一幅占位图像，并以该文件的 Bates 编号命名。\n\nb. 图像加载文件\n\na. Concordance® 数据文件。该数据文件（.DAT）包含将被加载至 Concordance® 数据库的所有字段化信息。.DAT 文件的第一行必须为标明字段名称的标题行。.DAT 文件必须使用以下 Concordance® 默认分隔符：逗号 ASCII 字符 (020) 引号 þ ASCII 字符 (254)。日期字段应以 mm/dd/yyyy 格式提供。日期和时间字段必须为两个独立字段。如文件包括已成像的电子邮件及附件，必须包括附件字段，以保留电子邮件与其附件之间的父子关系。必须包括 OCRPATH 字段，以提供已提取文本文件在所提交存储介质上的文件路径和名称。文本文件必须以 FIRSTBATES 命名。不得在 .DAT 文件中包含文本。对于含有原生文件的文件，必须包括 LINK 字段，以提供原生文件的文件路径和名称。原生文件必须以 FIRSTBATES 命名。\n\n- b. Concordance Image® 或 Opticon 交叉引用文件。图像交叉引用文件（.LOG 或 .OPT）将图像与数据库记录关联。该文件应为逗号分隔文件，每行由七个字段组成，并且数据库中的每个图像均应在交叉引用文件中对应一行，格式如下：ImageID,VolumeLabel,ImageFilePath,DocumentBreak,FolderBreak,Box Break,PageCoun。\n\n- c. 文档文本。文本必须作为单独的文本文件提供，不得作为 .DAT 文件中的字段提供。文本文件的完整路径（OCRPATH）应包含在 .DAT 文件中。建议提供文档级 ANSI 文本文件，并按照 FIRSTBATES/Image Key 命名。提取的文本文件必须置于单独的文件夹中，每个文件夹内的文本文件数量不得超过 1,000 个。文件夹名称中不得含有特殊字符（包括逗号）。文本文件必须按文档级别提供。\n\n- d. 特定文件类型的原生格式提供。为全面理解其内容和含义而合理需要以原生格式查看的文件类型，必须以原生格式提供。这些文件包括但不限于：电子表格、类似电子表格的文件（Microsoft Excel（微软 Excel）、逗号分隔值、制表符分隔值等）、Microsoft PowerPoint（微软 PowerPoint）或其他特殊演示文件、数据库文件以及音频/视频文件。应提供一张带 Bates 编号的分隔页图像，以表明存在原生文件，并将原生文件的路径作为 .dat 文件中的一个字段。提供的原生文件应以与该文件分隔页相对应的 Bates 编号命名。原生文件应归入按递增顺序命名的“NATIVE”目录中，并与图像目录分开。\n\n- e. 去重。对于存在完全重复件的每份电子文档，仅提供一份副本。对于电子邮件，应基于由 BCC、Body、CC、From、IntMsgID、To 和 Attach 属性生成的 MD5 哈希值合并重复件。对于电子邮件附件和独立电子文件，应基于整个文件的 MD5 哈希值合并重复件。\n\n- f. 元数据。应以符合 Concordance 要求的加载文件（.dat）形式提供每份文档的提取元数据。.DAT 文件的第一行必须为标明字段名称的标题行。.DAT 文件必须使用以下 Concordance 默认分隔符：逗号 , ASCII 字符（020）引号 þ ASCII 字符（254）\n\n日期字段应以如下格式提供：mm/dd/yyyy。日期字段和时间字段必须为两个独立字段。以下为必填元数据：\n\n字段名称　示例数据　说明\n\nFIRSTBATES　EDC0000001　原生文件文档/电子邮件的第一个 Bates 编号\nLASTBATES　EDC0000001　原生文件文档/电子邮件的最后一个 Bates 编号\nLASTBATES 字段应针对单页文档填写\nATTACHRANGE　EDC0000001\n-　父文档第一页的 Bates 编号至最后一个附件“子”文档最后一页的 Bates 编号\nEDC0000015\nBEGATTACH　EDC0000001　附件范围的第一个 Bates 编号\nENDATTACH　EDC0000015　附件范围的最后一个 Bates 编号\nCUSTODIAN　Smith, John　电子邮件：该电子邮件所在的邮箱\n原生文件：文档来源文件所属的个人或部门名称\nFROM　John Smith　电子邮件：发件人\n原生文件：文档作者\n多个条目应以分号分隔\nTO　Coffman, Janice; LeeW　收件人\n[mailto:LeeW@MSN.com]　多个条目应以分号分隔\nCC　Frank Thompson [mailto:　抄送收件人\nfrank_Thompson@cdt.com]　多个条目应以分号分隔\nBCC　John Cain　密送收件人\n多个条目应以分号分隔\nSUBJECT　Board Meeting Minutes　电子邮件：电子邮件主题行；原生文件：文档标题（如有）\nFILE_NAME　BoardMeetingMinutes.docx　原生文件：原始原生文件名称，包括扩展名\nDATE_SENT　10/12/2010　电子邮件：电子邮件发送日期\n原生文件：（空）\nTIME_SENT/　07:05 PM GMT　电子邮件：电子邮件发送时间/电子邮件标准化所采用的时区\nTIME_ZONE\nTIME_ZONE　GMT　在转换期间电子邮件被标准化所采用的时区。\nLINK　EDC0000001.msg　指向电子邮件或原生文件文档的超链接\n所链接文件必须按照 FIRSTBATES 编号命名\nFILE_EXTEN　MSG　表示电子邮件或原生文件的文件类型扩展名\nAUTHOR　John Smith　电子邮件：（空）\n原生文件：文档作者\nDATE_CREATED　10/10/2010　电子邮件：（空）\n原生文件：文档创建日期\n\nTIME_CREATED　10:25 AM　电子邮件：（空）\n\n原生文件：文档创建时间\n该数据必须为独立字段，不得与 DATE_CREATED 字段合并\nDATE_MOD　10/12/2010　电子邮件：（空）\n原生文件：文档最后修改日期\nTIME_MOD　07:00 PM　电子邮件：（空）\n原生文件：文档最后修改时间\n该数据必须为独立字段，不得与 DATE_MOD 字段合并\nDATE_ACCESSD　10/12/2010　电子邮件：（空）\n原生文件：文档最后访问日期\nTIME_ACCESSD　07:00 PM　电子邮件：（空）\n原生文件：文档最后访问时间\n该数据必须为独立字段，不得与 DATE_ACCESSD 字段合并\nFILE_SIZE　5,952　原生文件文档/电子邮件的大小，以 KB 计\nPGCOUNT　1　原生文件文档/电子邮件中的页数\nPATH　电子邮件：（空）\nAgenda.doc　原生文件：存储原生文件文档的路径，包括原始文件名。\nINTFILEPATH　Personal Folders\\Deleted　电子邮件：电子邮件的原始位置，包括原始文件名。\nItems\\Board Meeting\nMinutes.msg　原生文件：（空）\nINTMSGID　<000805c2c71b\\$75977050\\$　电子邮件：唯一消息 ID；原生文件：（空）\ncb8306d1@MSN>\nMD5HASH　d131dd02c5e6eec4693d9a0　文档的 MD5 哈希值。\n698aff95c\n2fcab58712467eab4004583e\nb8fb7f89\nOCRPATH　TEXT/001/EDC0000001.txt　原生文件提取文本的路径\n\n3. 每项请求均独立适用并应独立解释；除非另有说明，任何一项请求均不限制任何其他请求的范围。\n\n4. 所有文档均应按其在正常业务过程中保存的方式提供，或者应进行整理和标记，以对应本请求中的类别。\n\n5. 本文所载每项请求均延伸至所有文档：(a) 由您占有、保管或控制的文档；或 (b) 由任何代表您行事之人占有、保管或控制的文档，\nCase 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 65 of 439\n\n包括您的律师或其他代表及顾问。每份文档均应完整提供。\n\n6. 如要求您提供一份已不再由您占有、保管或控制的文档，则您的答复必须：(a) 详细说明该文档的性质及其内容；(b) 指明编制或撰写该文档的人员（以及，如适用，该文档被发送给的人员）；(c) 指明该文档编制或创建的日期；(d) 说明该文档是否：(i) 遗失或丢失，(ii) 已被销毁，(iii) 自愿或非自愿地转交给他人，或 (iv) 以其他方式处置；(e) 说明该等处置的理由以及有关事实和情形；(f) 指明授权该等处置的人员；(g) 指明该等处置的日期或大致日期；(h) 说明该文档最近一次由您占有、保管或控制的时间；以及 (i) 指明目前占有、保管或控制该文档的人员（如有）。\n\n7. 如要求您提供一份已被销毁的文档，则除前述指示所要求的信息外，您的答复还必须说明：(a) 该文档被销毁的原因；(b) 销毁该文档的人员身份；以及 (c) 指示销毁该文档的人员身份。\n\n8. 如您主张所请求的文档受特权或律师工作成果保护，则您的答复必须：(a) 说明：(i) 足以支持您关于该文档受特权保护之主张的文档描述，(ii) 文档标题，(iii) 文档日期，(iv) 文档作者，(v) 文档收件人，(vi) 收到或阅览原件或任何草稿、副本或复制件的每一人员身份，(vii) 该文档本身，或该文档中包含或提及的任何信息，是否由任何其他人员占有、保管或控制；如是，指明该等人员身份，\nCase 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 66 of 439\n\n并说明该信息如何由其占有，(viii) 据以拒绝提供该文档的特权主张，以及 (ix) 您将据以支持该等特权主张的所有情形；以及 (b) 对于基于特权主张而拒绝提供的每份文档，依照 D. Conn. L. Civ. R. 26(e)，提供一份特权日志，其中载明本指示第 (a) 部分所要求的全部信息。对于文档请求中未提出特权或工作成果主张的任何部分，应完整提供回应性文档。\n\n9. 如一份原本具有回应性的文档的一部分包含受特权主张约束的信息，则仅应依照上述指示从该文档中删除或遮蔽受该特权主张约束的部分，其余部分应予提供。\n\n10. 本请求具有持续性。特此指示您：(a) 在获悉先前答复不完整或不正确后，立即补充或更正后来得知不完整或不正确的任何答复；以及 (b) 提供传票要求的任何补充文档。\n\n11. 如文档使用英语以外的语言，您应提供该文档。如文档使用英语以外的语言，且存在英文译本，您应同时提供两份文档。\n\n12. 对实体的所有提述均包括其所有关联方。\n\n13. 对个人姓名的所有提述均包括所有其他姓名、别名或绰号。\nCase 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 67 of 439\n\n14. 除非另有明确说明，文档请求涵盖的期间为自 February 5, 2012 起至文档请求答复到期之日止。\n\nII. 解释规则\n\n15. (a) 对任何单数名词的使用，应解释为包括复数，反之亦然；以及 (b) 对任何时态动词的使用，应解释为包括该动词所有其他时态的使用。\n\n16. (a) “and”和“or”应视为必要时以连词或选择连词方式解释，以使原本可能被解释为不在任何请求范围内的所有答复均纳入该请求范围；以及 (b) “each”和“any”应视为包括并涵盖“every”和“all”二词。\n\nIII. 定义\n\n经 D. Conn. Bankr. L.R. 2004-1(a) 纳入的 D. Conn. L. Civ. R. 26(c) 所规定的定义，以及 D. Conn. L. Civ. R. 26(d) 所规定的解释规则，适用于文档请求。此外，本文件请求中使用的下列术语具有以下含义：\n\n1. “您”或“您的”或“您本人”系指 Lloyds Bank PLC（劳埃德银行有限公司），连同其所有关联方、部门、机构、办事机构、职能部门、办公室、合伙人、高级职员、董事、代理人、律师、代表、雇员和/或任何代表其行事之人。\nCase 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 68 of 439\n\n2. “债务人”系指 Ho Wan Kwok（郭文贵）（又名 Miles Kwok、Miles Guo、Guo Wengui、Guo Haoyun、郭文贵或任何其他别名），连同其雇员、代理人、律师、顾问或任何代表其行事之人。\n\n3. “债务人之子”系指 Qiang Guo（郭强）（又名 Mileson Kwok、郭强或任何其他别名），连同其雇员、代理人、律师、顾问或任何代表其行事之人。\n\n4. “债务人的女儿”是指 Mei Guo（郭美，亦称 Mei Gui，或任何其他别名），连同其雇员、代理人、律师、顾问，或任何代表其行事的人。\n\n5. “债务人的自称妻子”是指 Hing Chi Ngok（岳庆芝，亦称 Hing Chi Ng、Yue Qingzhi，或任何其他别名），连同其雇员、代理人、律师、顾问，或任何代表其行事的人。\n\n6. “债务人的家属”是指单独及共同而言的债务人、债务人的儿子、债务人的女儿及债务人的自称妻子，以及与债务人有任何其他家庭关系的人。\n\n7. “2004取证对象”是指单独及共同而言的债务人、债务人的家属、17 Miles, LLC、5780 Saguaro LLC、Aaron Mitchell、ACA Capital Group Limited、Ace Decade Holdings Limited、AI Group Holdings Inc.、Alfa Global Ventures Limited、Alphonso Global Ventures Limited、Ana C. Izquiedo-Henn、Andrew Childe、Anthony DiBattista、Anton Development Limited、Booming Sail New York LLC、Beile Li、Bingshang Jiao、Bravo Luck Limited、Brent Petro Inc.、Celestial Tide Limited、Chris Lee（亦称 Nan Li、Mei Guo Xiao Li）、China Golden Spring Group (Hong Kong) Ltd.、Crane Advisory Group、Daniel Thomas Podhaskie、Defeng Cao（亦称 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 (CA)、G Fashion、G Fashion Hold Co. A. Limited、G Fashion Hold Co. B. Limited、G Fashion Media Group Inc.、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、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（亦称 Huo Lai）、Haitham Khaled、Hamilton Capital Holdings Inc.、Hamilton Digital Assets Funds SP、Hamilton Investment Management Limited、Hamilton Opportunity Fund SPC、Hamilton PE Funds SP、Holy City Hong Kong Ventures Ltd.、GS Security Solutions Inc.、Alex Hadjcharalambous、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 Currency Clearing Pty. Ltd.、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、Jessica Mastrogiovanni、Jiaming Liu、Jie Zhang、Jovial Century International Limited、Joyord Sportswear Limited、K Legacy Ltd.、Kamel Debeche、Karin Maistrello、Kin Ming Je、Lamp Capital LLC、Lawall & Mitchell, LLC、Leading Shine NY Ltd.、Lexington Property and Staffing, Inc.、Lexington Property and Staffing LLC、Linwan “Irene” Feng、Limarie Reyes、Lihong “Sara” Wei Lafrenz、The Lost Draft LLC、Macaron Limited、Major Lead International Limited、Mary Jiang、MOS Himalaya LLC、Maywind Trading LLC、New York MOS Himalaya LLC、Next Tycoon Investments Limited、Nicholas Savio、Nodal Partners, LLC、Qidong Xia、Oasis Tech Limited、O.S.C. Orbit Service Company, LLC、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、Seven Mission Group LLC、Shih Hsin Yu、Sirius Networking Inc.、Taurus Fund LLC、Taurus Management LLC、US Himalaya Capital Inc.、V.X. Cerda & Associates P.A.、Victor Cerda、Voice of Guo Media, Inc.、Wen Xiao、Wencong Wang、William Je、Kin Ming Je（亦称 Je Kin Ming）、Wise Creation International Limited、Xuebing Wang、Yan Chun Liu、Yinying (Aila) Wang（亦称 Xiao Fei Xiang）、Yongbing Zhang、Yongping Yan (Shan Mu)、Yue Zhou、Yumei Hao（亦称 Ru Shui）、Yvette Wang（亦称 Yanping Wang、Yan Ping Wang）、Zhixuan Li、Zhouer “Joe” Wang、NewPeople LLC、Ziba Limited、New Mulberry PTE Ltd、TD Primrose Limited，以及 Shin Hee-Seup（亦称 Hee Seup Shin）。\n\n案号 22-50073，文书 3193，于 05/16/24 提交，于 05/16/24 10:28:21 登记，第 69 页，共 439 页\n\n8. “包括”或其任何变体，意为“包括但不限于”。\n\n9. “和”及“或”意为“和/或”，并应同时按连词及选择连词解释，以最大限度扩大其范围。\n\n10. “任何”和“所有”以及“每一”意为“每一个和全部”。\n\n11. “每一”和“每个”意为“每一个和全部”。\n\n12. “第三方”是指除您本人以外的个人或实体。\n\n13. “转让”应具有《破产法》第 101(54) 条赋予其的含义。\n\n14. “文件”是指属于 Fed. R. Civ. P. 34 范围内的任何信息或物品，包括但不限于任何种类、类型、性质或描述的每一份书面、记录或图形资料，无论其现由或曾由您占有、保管或控制，包括电子邮件的所有印刷和电子副本、以电子形式保存的计算机文件、信函、备忘录、磁带、速记或手写笔记、任何种类的书面表格、图表、蓝图、图纸、草图、曲线图、计划、文章、规格说明书、日记、信件、电报、照片、会议记录、合同、协议、调查资料、计算机打印件、任何种类的数据汇编、电传、传真、电子邮件、短信、即时消息、语音留言、发票、订购单、支票、汇票、对账单、贷项通知单、报告、头寸报告、摘要、索引、书籍、分类账、笔记本、明细表、透明胶片、录音、目录、广告、宣传材料、影片、录像带、录音带、CD、计算机磁盘、宣传册、小册子、穿孔卡、工时单、推文、社交媒体帖子，或任何其他种类的书面或记录材料，以及其所有元数据，无论以何种方式储存（无论为有形或电子形式）、记录、制作或复制；还包括但不限于前述任何文件的草稿或副本，如其中含有原始文件中不存在的任何种类的笔记、评论或标记，或其在其他方面与原始文件不相同。\n\n案号 22-50073，文书 3193，于 05/16/24 提交，于 05/16/24 10:28:21 登记，第 71 页，共 439 页\n\n15. “个人”是指个人、公司、独资企业、合伙企业、协会或任何其他实体。“个人”还包括任何代理人、代表或专家，包括但不限于律师或财务顾问。\n\n16. “实体”是指任何自然人、公司、合伙企业、子公司、独资企业、商号、董事会、合资企业、协会、机构、主管机关、委员会或其他商业实体或法人，以及任何关联方、代理人、母公司，包括但不限于律师、财务顾问或任何其他代表。\n\n案号 22-50073，文书 3193，于 05/16/24 提交，于 05/16/24 10:28:21 登记，第 72 页，共 439 页\n\n17. “关于”是指涉及、描述、包含、提及、与之相关、支持、有利于、反对、加强、削弱、位于其中、结合考虑、影响、证明、表明、报告、记录、暗指、回应、与之相连、评论、就其而言、关于、与之有关、讨论、展示、描述、反映、分析、构成及属于。\n\n18. 当指称任何特定事项时，“与……有关”、“与……相关”或“有关联”是指，包括但不限于，构成、包含、涉及、含有、体现、反映、识别、陈述、直接或间接提及，或以任何方式与所识别的特定事项有关的任何文件。\n\n19. “通信”是指，以最广泛的可能含义且不受限制地，任何信息或知识的传递（以事实、观点、询问或其他形式）。通信还指所有谈话、协议、询问或答复，无论是当面、通过电话、书面方式，还是通过电子传输设备，并包括但不限于所有信函、电子邮件、录音、传输单、备忘录、电话通信、语音留言、电报、电话传真、传真副本、电传、即时消息、聊天、短信、发布至留言板或群聊的内容、社交媒体帖子、推文、上传至任何视频平台的视频、电话记录，或内部传递或与第三方传递的笔记。\n\n20. “资产”是指受占有、保管或控制的任何具有经济价值的项目。资产包括所有不动产和动产，包括但不限于房地产、土地、房屋、公寓、共管公寓、汽车、游艇、船只、飞机、喷气式飞机、直升机、现金、银行账户、加密货币、证券、应收账款、存货以及其他有形和无形财产。\n\n四、应提交的文件\n\n1. 与任何由任何2004取证对象持有、控制、代表其持有或以其他方式与其相关的账户有关的所有文件，包括任何及所有账户对账单、授权书、委托书、信托文件、指示或表格、已注销支票副本、信函，以及电汇和相关信函及指示。\n\n2. 与任何属于任何2004取证对象、由其持有、控制、代表其持有或以其他方式与其相关的资金、证券、财产或资产有关的所有文件，包括任何及所有账户对账单、授权书、委托书、信托文件、指示或表格、已注销支票副本、信函，以及电汇和相关信函及指示。\n\n3. 与同任何2004取证对象进行的任何商业、贸易或金融交易有关的所有文件，包括但不限于任何贷款、信贷额度、寄托、存款、掉期、证券交易、抵押贷款或 ISDA，包括任何及所有账户对账单、授权书、委托书、信托文件、指示或表格、已注销支票副本、信函，以及电汇和相关信函及指示。\n\n4. 与涉及2004取证对象的任何电汇活动有关的所有文件，无论是否存在任何账户，包括但不限于所有电汇收据、账号、余额、授权、与转账当事人有关的身份识别信息、信函、指示或其他记录。\n\n5. 与您和2004取证对象之间的任何信函及通信有关的所有文件。\n\n6. 与任何2004取证对象的任何账户有关、涉及账户开立、账户获授权使用人及账户维护的所有文件。\n\n案号 22-50073，文书 3193，于 05/16/24 提交，于 05/16/24 10:28:21 登记，第 74 页，共 439 页\n\n7. 与任何涉及任何2004取证对象的反洗钱、了解你的客户或其他合规活动有关的所有文件，包括但不限于任何由任何2004取证对象提供的信息，或您获知的信息。\n\n8. 与来自任何国家的任何监管机构进行的任何通信有关的所有文件，包括但不限于与英格兰银行（Bank of England）、美国联邦储备系统（United States Federal Reserve）、S.E.C.、CFTC、FINRA、中国证券监督管理委员会（China Securities Regulatory Commission）、中国人民银行（People's Bank of China）、香港证券及期货事务监察委员会（Hong Kong Securities and Futures Commission）及香港金融管理局（Hong Kong Monetary Authority）进行的、与任何2004证据开示对象有关的通信。\n附件 C-4\nB2540（表格2540——Rule 2004 审查传票）（12/15）案号 22-50073 文件3193 于05/16/24提交 于05/16/24 10:28:21登记 第76页，共\n\n美国破产法院（UNITED STATES BANKRUPTCY COURT）\n\n康涅狄格地区（District of Connecticut）\n\n关于 HO WAN KWOK（郭文贵）等人，\n\n1 案号 22-50073 (JAM) 债务人 第11章\n\n（合并管理）\nRule 2004 审查传票\n\n致：PayrNet Limited（PayrNet有限公司）\n\n（传票所指向之人的姓名）\n\n证言：兹命令您于下列规定的时间、日期和地点出席，并根据《联邦破产程序规则》Rule 2004接受审查并作证。随附准许该审查的法院命令副本。\n\n地点　日期和时间\n\n不适用　不适用\n\n审查将通过以下方式记录：不适用\n\n提交：您或您的代表还必须携带下列文件、电子存储信息或物品参加审查，并必须允许对该材料进行查验、复制、测试或抽样：\n见随附的文件提交请求。\n\nFed. R. Civ. P. 45的下列规定，经Fed. R. Bankr. P. 9016规定适用于破产案件，现随附于后——有关履行地点的Rule 45(c)；有关作为传票对象之人保护的Rule 45(d)；以及有关您回应本传票之义务及不履行该义务的潜在后果的Rule 45(e)和45(g)。\n\n日期：May , 2024\n\n法院书记官\n\n或\n\n书记官或副书记官签名　律师签名\n\n签发或请求本传票的Luc A. Despins（Luc A. Despins），第11章受托人的代理律师姓名、地址、电子邮件地址及电话号码如下：\n\nPatrick R. Linsey, Esq.；Neubert, Pepe & Monteith, P.C.（Neubert, Pepe & Monteith专业公司）；195 Church Street, 13th Floor, New Haven, Connecticut 06510；plinsey@npmlaw.com；(203) 781-2847\n致签发或请求本传票之人的通知\n\n如本传票要求在审判前提交文件、电子存储信息或有形物品，或查验场所，则必须在向传票所指向之人送达前，向每一方当事人送达通知及本传票副本。Fed. R. Civ. P. 45(a)(4)。\n\n软件版权 (c) 1996-2022 Best Case, LLC（Best Case有限责任公司）- www.bestcase.com Best Case Bankruptcy 1 本第11章案件中的债务人为Ho Wan Kwok（亦称Guo Wengui、Miles Guo及Miles Kwok，以及众多其他别名）（税务识别号码后四位：9595）、Genever Holdings LLC（Genever Holdings有限责任公司）（税务识别号码后四位：8202）及Genever Holdings Corporation（Genever Holdings公司）。受托人、Genever Holdings LLC及Genever Holdings Corporation的邮寄地址为Paul Hastings LLP（Paul Hastings有限责任合伙律师事务所），200 Park Avenue, New York, NY 10166，转Luc A. Despins，作为Ho Wan Kwok财产的受托人（仅为通知及通信之目的）。\n送达证明\n\n（除非Fed. R. Civ. P. 45要求，否则本节不应向法院提交。）\n\n本人于（日期）收到向（个人姓名及职务，如有）发出的本传票。\n\n本人通过以下方式向被指名之人递送副本，以送达该传票：\n\n于（日期）送达；或\n\n本人因下列原因未执行本传票并予以退还：\n\n除非本传票系代表美国或其官员或代理人签发，本人亦已向证人支付一天出席费用及法律允许的里程费用，金额为$。\n\n本人差旅费用为$，服务费用为$，合计为$。\n\n本人在伪证处罚的约束下声明，上述信息真实准确。\n\n日期：\n\n送达人签名\n\n正楷姓名及职务\n\n送达人地址\n\n关于尝试送达等事项的补充信息：\n《联邦民事诉讼规则》45(c)、(d)、(e)及(g)（自12/1/13起生效）（经《联邦破产程序规则》Rule 9016规定适用于破产案件）\n(c) 履行地点。\n\n(1) 审判、听证或证言录取。传票仅可按如下方式命令某人出席审判、听证或证言录取：\n\n(A) 在该人居住、受雇或经常亲自从事商业活动地点100英里以内；或\n\n(B) 在该人居住、受雇或经常亲自从事商业活动所在州内，如该人\n\n(i) 是一方当事人或一方当事人的高级职员；或\n\n(ii) 被命令出席审判且不会产生重大费用。\n\n(2) 其他证据开示。传票可命令：\n\n(A) 在该人居住、受雇或经常亲自从事商业活动地点100英里以内的地点提交文件、电子存储信息或物品；以及\n\n(B) 在待查验场所对该场所进行查验。\n(d) 对作为传票对象之人的保护；执行。\n\n(1) 避免不当负担或费用；制裁。负责签发和送达传票的一方当事人或律师必须采取合理措施，避免对作为传票对象之人施加不当负担或费用。要求履行义务所在地区的法院必须执行该义务，并对未遵守该义务的一方当事人或律师施加适当制裁，其中可包括损失的收入和合理的律师费。\n\n(2) 命令提交材料或准许查验。\n\n(A) 无须出席。被命令提交文件、电子存储信息或有形物品，或准许查验场所之人，无须亲自到提交或查验地点出席，除非同时被命令出席证言录取、听证或审判。\n\n(B) 异议。被命令提交文件或有形物品，或准许查验之人，可以向传票中指定的一方当事人或律师送达书面异议，反对查验、复制、测试或抽样全部或部分材料，或反对查验场所，或反对以所请求的一种或多种形式提交电子存储信息。异议必须在指定履行时间或传票送达后14日中较早的时间之前送达。如提出异议，适用下列规则：\n\n(i) 任何时候，经通知被命令之人，送达方可以向要求履行义务所在地区的法院提出动议，请求作出强制提交或查验的命令。\n\n(ii) 仅可依照命令所指示的方式要求采取该等行为，且该命令必须保护既非一方当事人亦非一方当事人高级职员之人，免受因履行而产生的重大费用。\n(3) 撤销或修改传票。\n\n(A) 必须撤销或修改的情形。经及时动议，要求履行义务所在地区的法院必须撤销或修改下列传票：\n\n(i) 未给予合理履行时间的；\n\n(ii) 要求某人在Rule 45(c)规定的地域限制以外履行的；\n\n(iii) 要求披露享有特权或受其他保护的事项，且不存在适用的例外或豁免的；或\n\n(iv) 使某人承担不当负担的。\n\n(B) 可以撤销或修改的情形。为保护作为传票对象或受传票影响之人，要求履行义务所在地区的法院可以经动议撤销或修改要求下列事项的传票：\n\n(i) 披露商业秘密或其他保密研究、开发或商业信息的；或\n\n(ii) 披露未经聘用的专家的意见或信息，而该意见或信息未描述争议中的具体事件，并源于一方当事人未请求的该专家研究。\n\n(C) 以规定条件作为替代。在Rule 45(d)(3)(B)所述情形下，如送达方：\n\n(i) 证明对该证言或材料具有重大需要，且若不遭受不当困难则无法以其他方式满足该需要；并且\n\n(ii) 确保被传唤之人将获得合理补偿，\n\n法院可不撤销或修改传票，而命令在规定条件下出席或提交。\n(e) 回应传票的义务。\n\n(1) 提交文件或电子存储信息。下列程序适用于提交文件或电子存储信息：\n\n(A) 文件。回应要求提交文件的传票之人，必须按照文件在通常业务过程中保存的方式提交，或者必须将其整理并加注标签，使之对应于请求中的类别。\n\n(B) 未指定电子存储信息提交形式。如传票未指定提交电子存储信息的形式，回应之人必须以其通常保存的一种或多种形式，或以合理可用的一种或多种形式提交。\n\n(C) 电子存储信息仅以一种形式提交。回应之人无须以多于一种形式提交相同的电子存储信息。\n\n(D) 无法访问的电子存储信息。回应之人无须就其认定因不当负担或费用而无法合理访问的来源中的电子存储信息提供证据开示。对于强制证据开示或保护令的动议，回应之人必须证明该信息因不当负担或费用而无法合理访问。如作出该证明，法院在考虑Rule 26(b)(2)(C)的限制后，如请求方证明有正当理由，仍可命令从该等来源进行证据开示。法院可对该证据开示规定条件。\n\n(2) 主张特权或保护。\n\n(A) 被扣留的信息。以该信息享有特权或作为审判准备材料受到保护为由扣留被传唤信息之人，必须：(i) 明确提出该主张；并且\n\n(ii) 在不披露本身享有特权或受保护的信息的情况下，以足以使各方当事人评估该主张的方式，说明被扣留文件、通信或有形物品的性质。\n\n(B) 已提交的信息。如为回应传票而提交的信息受到特权主张或作为审判准备材料的保护主张约束，提出该主张之人可以将该主张及其依据通知收到该信息的任何一方当事人。收到通知后，一方当事人必须立即返还、隔离或销毁所指定的信息及其持有的任何副本；在该主张得到解决前不得使用或披露该信息；如该方当事人在收到通知前已披露该信息，必须采取合理措施追回该信息；并可立即将该信息密封提交给要求履行义务所在地区的法院，以裁定该主张。提交该信息之人必须在该主张得到解决前保全该信息。\n\n(g) 藐视法庭。要求履行义务所在地区的法院——以及在动议移送后，签发法院——可以认定已被送达但无充分理由不遵守传票或与其有关命令之人构成藐视法庭。\n\n如需查阅传票材料，见Fed.R.Civ.P.45(a)委员会说明（2013）\n\n……\n\n文件提交请求\n一、说明\n\n1. 除非另有说明，下文所列文件请求（以下简称“请求”，每项称“一项请求”）必须分别并具体作出回应。每项请求均应得到完整答复，除非基于善意提出异议；在该情况下，应按下文规定详细说明您提出异议的理由。如异议仅涉及某项请求的一部分，或其中所含的一个词、短语或条款，您仅须说明对该部分的异议，并回应请求的其余部分。\n\n2. 电子存储信息必须依照下列指示提供：\n\na. 图像。黑白图像必须为 300 DPI Group IV 单页 TIFF 文件。彩色图像必须以 JPEG 格式提供。文件名不得含有嵌入空格或特殊字符（包括逗号）。文件夹名称不得含有嵌入空格或特殊字符（包括逗号）。所有 TIFF 图像文件必须具有唯一文件名，即 Bates 编号。图像必须在每幅图像右下角加注连续的 Bates 编号。每个文件夹中的 TIFF 文件数量不应超过 1000 个文件。Excel 电子表格应具有以该文件 Bates 编号命名的占位图像。\n\nb. 图像加载文件\n\na. Concordance® 数据文件。数据文件（.DAT）包含将加载至 Concordance® 数据库的所有字段信息。.DAT 文件的第一行必须为标识字段名称的标题行。.DAT 文件必须使用下列 Concordance® 默认分隔符：逗号 ASCII 字符（020）引号 þ ASCII 字符（254）。日期字段应以 mm/dd/yyyy 格式提供。日期字段与时间字段必须为两个独立字段。如文件包括图像化电子邮件及附件，则必须包括附件字段，以保留电子邮件与其附件之间的父项/子项关系。必须包括 OCRPATH 字段，以提供已提取文本文件在所提供存储介质上的文件路径及名称。文本文件必须以 FIRSTBATES 命名。不得将文本包含在 .DAT 文件中。对于具有原生文件的文件，必须包括 LINK 字段，以提供原生文件的文件路径及名称。原生文件必须以 FIRSTBATES 命名。\n\nb. Concordance Image® 或 Opticon 交叉引用文件。图像交叉引用文件（.LOG 或 .OPT）将图像链接至数据库记录。该文件应为以逗号分隔的文件，每行由七个字段构成；数据库中的每幅图像均应在交叉引用文件中有一行，格式如下：ImageID,VolumeLabel,ImageFilePath,DocumentBreak,FolderBreak,Box Break,PageCoun。\n\nc. 文件文本。文本必须作为独立文本文件提供，而非作为 .DAT 文件中的字段。文本文件的完整路径（OCRPATH）应包括在 .DAT 文件中。建议提供以 FIRSTBATES/Image Key 命名的文件级 ANSI 文本文件。提取的文本文件必须置于单独文件夹中，每个文件夹中的文本文件数量不应超过 1,000 个文件。文件夹名称中不得含有特殊字符（包括逗号）。文本文件必须按文件级别提供。\n\nd. 特定文件类型的原生格式提供。为完整理解其内容及含义而合理需要以原生格式查看的文件类型，必须以原生格式提供。该等文件包括但不限于电子表格、类电子表格文件（Microsoft Excel、逗号分隔值、制表符分隔值等）、Microsoft PowerPoint 或其他特殊演示文件、数据库文件及音频/视频文件。提供一张带有 Bates 编号的分隔页图像，注明存在原生文件，并将原生文件的路径作为 .dat 文件中的字段包括在内。所提供原生文件应以与该文件分隔页相对应的 Bates 编号命名。将原生文件归入按递增方式命名的“NATIVE”目录中，并与图像目录分开。\n\ne. 去重。对于存在完全重复件的每一电子文件，提供单一副本。对于电子邮件，依据由 BCC、Body、CC、From、IntMsgID、To 及 Attach 属性生成的 MD5 哈希值合并重复件。对于电子邮件附件及独立电子文件，依据整个文件的 MD5 哈希值合并重复件。\n\nf. 元数据。以符合 Concordance 要求的加载文件（.dat）形式，为每份文件提供提取的元数据。.DAT 文件的第一行必须为标识字段名称的标题行。.DAT 文件必须使用下列 Concordance 默认分隔符：逗号 , ASCII 字符（020）引号 þ ASCII 字符（254）。日期字段应以 mm/dd/yyyy 格式提供。日期字段与时间字段必须为两个独立字段。下列为必需元数据：\n\n字段名称　示例数据　说明\n\nFIRSTBATES　EDC0000001　原生文件文件/电子邮件的首个 Bates 编号\n\nLASTBATES　EDC0000001　原生文件文件/电子邮件的最后一个 Bates 编号\n\nLASTBATES 字段应针对单页填写\n\nATTACHRANGE　EDC0000001 - EDC0000015　父文件第一页的 Bates 编号至最后一个附件“子”文件最后一页的 Bates 编号\n\nBEGATTACH　EDC0000001　附件范围的首个 Bates 编号\n\nENDATTACH　EDC0000015　附件范围的最后一个 Bates 编号\n\nCUSTODIAN　Smith, John　电子邮件：电子邮件所在的邮箱；原生文件：该文件来源的个人或部门名称\n\nFROM　John Smith　电子邮件：发件人；原生文件：文件作者；多个条目应以分号分隔\n\nTO　Coffman, Janice; LeeW [mailto:LeeW@MSN.com]　收件人；多个条目应以分号分隔\n\nCC　Frank Thompson [mailto:frank_Thompson@cdt.com]　抄送收件人；多个条目应以分号分隔\n\nBCC　John Cain　密送收件人；多个条目应以分号分隔\n\nSUBJECT　Board Meeting Minutes　电子邮件：电子邮件主题行；原生文件：文件标题（如有）\n\nFILE_NAME　BoardMeetingMinutes.docx　原生文件：原始原生文件的名称，包括扩展名\n\nDATE_SENT　10/12/2010　电子邮件：电子邮件发送日期；原生文件：（空）\n\nTIME_SENT/TIME_ZONE　07:05 PM GMT　电子邮件：电子邮件发送时间/电子邮件标准化所使用的时区\n\nTIME_ZONE　GMT　在转换期间电子邮件被标准化所使用的时区。\n\nLINK　EDC0000001.msg　电子邮件或原生文件文件的超链接；链接文件必须按 FIRSTBATES 编号命名\n\nFILE_EXTEN　MSG　代表电子邮件或原生文件的文件类型扩展名\n\nAUTHOR　John Smith　电子邮件：（空）；原生文件：文件作者\n\nDATE_CREATED　10/10/2010　电子邮件：（空）；原生文件：文件创建日期\n\nTIME_CREATED　10:25 AM　电子邮件：（空）；原生文件：文件创建时间；该数据必须为独立字段，不得与 DATE_CREATED 字段合并\n\nDATE_MOD　10/12/2010　电子邮件：（空）；原生文件：文件最后修改日期\n\nTIME_MOD　07:00 PM　电子邮件：（空）；原生文件：文件最后修改时间；该数据必须为独立字段，不得与 DATE_MOD 字段合并\n\nDATE_ACCESSD　10/12/2010　电子邮件：（空）；原生文件：文件最后访问日期\n\nTIME_ACCESSD　07:00 PM　电子邮件：（空）；原生文件：文件最后访问时间；该数据必须为独立字段，不得与 DATE_ACCESSD 字段合并\n\nFILE_SIZE　5,952　原生文件文件/电子邮件的大小（KB）\n\nPGCOUNT　1　原生文件文件/电子邮件中的页数\n\nPATH　Email: (empty) Agenda.doc　电子邮件：（空）；原生文件：原生文件文件的存储路径，包括原始文件名。\n\nINTFILEPATH　Personal Folders\\Deleted Items\\Board Meeting Minutes.msg　电子邮件：电子邮件的原始位置，包括原始文件名；原生文件：（空）\n\nINTMSGID　<000805c2c71b\\$75977050\\$cb8306d1@MSN>　电子邮件：唯一邮件 ID；原生文件：（空）\n\nMD5HASH　d131dd02c5e6eec4693d9a0698aff95c2fcab58712467eab4004583eb8fb7f89　文件的 MD5 哈希值。\n\nOCRPATH　TEXT/001/EDC0000001.txt　原生文件提取文本的路径\n\n3. 各项请求独立适用并应独立解释，除非另有说明，任何一项请求均不限制任何其他请求的范围。\n\n4. 所有文件应按通常业务过程中保存的方式提供，或者应予组织和标记，以对应于本请求中的类别。\n\n5. 本文件所载每项请求延及所有文件：(a) 由贵方占有、保管或控制的文件；或 (b) 由任何代表贵方行事之人占有、保管或控制的文件，\n案号 22-50073 文档 3193 提交于 05/16/24 录入于 05/16/24 10:28:21 第 83 页，共 439 页\n\n包括贵方的律师或其他代表及顾问。每份文件均应完整提供。\n\n6. 如要求贵方提供的文件已不再由贵方占有、保管或控制，则贵方的答复必须：(a) 详细说明该文件的性质及内容；(b) 确认编制或起草该文件的人员（以及，如适用，确认该文件的接收人员）；(c) 确认该文件编制或创建的日期；(d) 说明该文件是否：(i) 遗失或丢失，(ii) 已被销毁，(iii) 已自愿或非自愿地转让给他人，或 (iv) 已以其他方式处置；(e) 说明该等处置的理由，以及围绕该等处置的事实及情形；(f) 确认授权该等处置的人员；(g) 确认该等处置的日期或大致日期；(h) 说明该文件最后一次由贵方占有、保管或控制的时间；以及 (i) 确认（如有）目前占有、保管或控制该文件的人员。\n\n7. 如要求贵方提供的文件已被销毁，则除前述指示所要求的信息外，贵方的答复还必须说明：(a) 销毁该文件的理由；(b) 销毁该文件的人员身份；以及 (c) 指示销毁该文件的人员身份。\n\n8. 如贵方主张所要求的文件享有特权或律师工作成果保护，则贵方的答复必须：(a) 说明：(i) 足以支持贵方关于该文件享有特权之主张的文件描述，(ii) 文件标题，(iii) 文件日期，(iv) 文件作者，(v) 文件收件人，(vi) 收到或看过该文件原件或任何草稿、副本或复制件的每一人员的身份，(vii) 该文件本身或该文件中包含或提及的任何信息是否由任何其他人员占有、保管或控制；如是，则说明该等人员的身份，以及说明该等信息如何进入其占有范围，(viii) 据以扣留该文件的特权主张，以及 (ix) 贵方将据以支持该特权主张的全部情形；以及 (b) 根据 D. Conn. L. Civ. R. 26(e)，就基于特权主张而扣留的每份文件，提供一份特权清单，其中载明本指示第 (a) 部分所要求的全部信息。对于文件请求中未主张特权或工作成果保护的任何部分，应完整提供回应性文件。\n\n9. 如本应回应的文件中有一部分包含受特权主张约束的信息，则仅应依照上述指示从该文件中删除或遮盖受特权主张约束的该部分，其余部分应予提供。\n\n10. 本请求具有持续性质。现指示贵方：(a) 在得知先前答复不完整或不正确后，立即补充或更正任何后来得知不完整或不正确的答复；以及 (b) 提供传票所要求的任何补充文件。\n\n11. 如文件使用英语以外的语言，贵方应提供该文件。如文件使用英语以外的语言，且存在英文译本，贵方应同时提供两份文件。\n\n12. 对实体的一切提及均包括其所有关联方。\n\n13. 对个人姓名的一切提及均包括所有别名、化名或昵称。\n\n14. 除非另有明确说明，文件请求所涵盖的期间为自 February 5, 2012 起至文件请求答复到期之日止。\n\nII. 解释规则\n\n15. (a) 任何单数名词的使用均应解释为包括复数，反之亦然；以及 (b) 任何时态的动词均应解释为使用该动词的所有其他时态。\n\n16. (a) “and”和“or”应在必要时解释为连词或析取连词，以使任何请求的范围包括所有原本可能被解释为不在其范围内的答复；以及 (b) “each”和“any”应被视为包括并涵盖“every”和“all”两词。\n\nIII. 定义\n\n根据 D. Conn. Bankr. L.R. 2004-1(a) 纳入的 D. Conn. L. Civ. R. 26(c) 所规定的定义，以及 D. Conn. L. Civ. R. 26(d) 所规定的解释规则，适用于文件请求。此外，本文件请求中使用的下列术语具有下列含义：\n\n1. “You”或“Your”或“Yourself”系指 PayrNet Limited（佩尔内特有限公司），连同其所有关联方、部门、机构、工具机构、处室、办事处、合伙人、高级职员、董事、代理人、律师、代表、雇员和/或任何代表其行事之人。\n\n2. “Debtor（债务人）”系指 Ho Wan Kwok（郭文贵）（又名 Miles Kwok（郭文贵）、Miles Guo（郭文贵）、Guo Wengui（郭文贵）、Guo Haoyun（郭浩云）、郭文贵，或任何其他别名），连同其雇员、代理人、法律顾问、顾问或任何代表其行事之人。\n案件 22-50073 文书 3193 于 05/16/24 提交 于 05/16/24 10:28:21 登记 第 86 页，共 439 页\n\n3. “Debtor's Son（债务人之子）”系指 Qiang Guo（郭强）（又名 Mileson Kwok（郭强）、郭强，或任何其他别名），连同其雇员、代理人、法律顾问、顾问或任何代表其行事之人。\n\n4. “Debtor's Daughter（债务人之女）”系指 Mei Guo（郭美）（又名 Mei Gui（郭美）、郭美，或任何其他别名），连同其雇员、代理人、法律顾问、顾问或任何代表其行事之人。\n\n5. “Debtor's Purported Wife（债务人之据称妻子）”系指 Hing Chi Ngok（岳庆芝）（又名 Hing Chi Ng（岳庆芝）、Yue Qingzhi（岳庆芝）、岳庆芝，或任何其他别名），连同其雇员、代理人、法律顾问、顾问或任何代表其行事之人。\n\n6. “Debtor's Family（债务人家属）”单独或合称债务人、债务人之子、债务人之女及债务人之据称妻子，以及与债务人有任何其他亲属关系者。\n\n7. “2004 Discovery Targets（2004 调查对象）”单独或合称债务人、债务人家属、17 Miles, LLC（17英里有限责任公司）、5780 Saguaro LLC（5780萨瓜罗有限责任公司）、Aaron Mitchell（艾伦·米切尔）、ACA Capital Group Limited（ACA资本集团有限公司）、Ace Decade Holdings Limited（艾斯十年控股有限公司）、AI Group Holdings Inc.（AI集团控股公司）、Alfa Global Ventures Limited（阿尔法全球创投有限公司）、Alphonso Global Ventures Limited（阿方索全球创投有限公司）、Ana C. Izquiedo-Henn（安娜·C·伊斯奎耶多-亨）、Andrew Childe（安德鲁·柴尔德）、Anthony DiBattista（安东尼·迪巴蒂斯塔）、Anton Development Limited（安东开发有限公司）、Booming Sail New York LLC（兴帆纽约有限责任公司）、Beile Li（李贝乐）、Bingshang Jiao（焦冰尚）、Bravo Luck Limited（布拉沃幸运有限公司）、Brent Petro Inc.（布伦特石油公司）、Celestial Tide Limited（天潮有限公司）、Chris Lee（克里斯·李）（又名 Nan Li（李楠）、Mei Guo Xiao Li（郭美小李））、China Golden Spring Group (Hong Kong) Ltd.（中国金泉集团〈香港〉有限公司）、Crane Advisory Group（克兰咨询集团）、Daniel Thomas Podhaskie（丹尼尔·托马斯·波达斯基）、Defeng Cao（曹德峰）（又名 Wayne Cao（曹德峰）、Max Cao（曹德峰））、Ding “Ivan” Lin（丁“伊万”林）、Doaa Dashoush（杜阿·达舒什）、Eastern Profit Corporation Limited（东方利润有限公司）、Genever Holdings Corporation（吉尼弗控股公司）、Genever Holdings LLC（吉尼弗控股有限责任公司）、Gettr USA, Inc.（盖特美国公司）、Gnews Media Group Inc.（G新闻媒体集团公司）、G Fashion (CA)（G时尚〈加州〉）、G Fashion（G时尚）、G Fashion Hold Co. A. Limited（G时尚控股A有限公司）、G Fashion Hold Co. B. Limited（G时尚控股B有限公司）、G Fashion Media Group Inc.（G时尚媒体集团公司）、G Fashion International Limited（G时尚国际有限公司）、G Fashion LLC（G时尚有限责任公司）、Gmusic LLC（G音乐有限责任公司）、Gnews LLC（G新闻有限责任公司）、Geducation（G教育）、GFNY, Inc.（GFNY公司）、G Club Finance（G俱乐部金融）、G Club HoldCo I LLC（G俱乐部控股I有限责任公司）、G Club International Limited（G俱乐部国际有限公司）、G Club Investments Limited（G俱乐部投资有限公司）、G Club Operations\n案件 22-50073 文书 3193 于 05/16/24 提交 于 05/16/24 10:28:21 登记 第 87 页，共 439 页\nLLC（G俱乐部运营有限责任公司）、G Club US Operations Inc.（G俱乐部美国运营公司）、G Club US Operations LLC（G俱乐部美国运营有限责任公司）、G Club（G俱乐部）、G Club One（G俱乐部一号）、G Club Two（G俱乐部二号）、G Club Three（G俱乐部三号）、G Live, LLC（G直播有限责任公司）、Gbroadcast, LLC（G广播有限责任公司）、GM 27 LLC（GM 27有限责任公司）、Gladys Chow（周格拉迪斯）、Golden Spring (New York) Ltd.（金泉〈纽约〉有限公司）、Gposts LLC（G帖子有限责任公司）、GTV Media Group, Inc.（GTV媒体集团公司）、Gypsy Mei Food Service LLC（吉普赛梅餐饮服务有限责任公司）、Gypsy Mei Productions LLC（吉普赛梅制作有限责任公司）、Gypsy Mei 27 Vestry, Inc.（吉普赛梅27维斯特里公司）、Dawn State Limited（黎明州有限公司）、Greenwich Land LLC（格林尼治土地有限责任公司）、Hao (Gavin) Li（李浩）（又名 Huo Lai（霍来））、Haitham Khaled（海赛姆·哈立德）、Hamilton Capital Holdings Inc.（汉密尔顿资本控股公司）、Hamilton Digital Assets Funds SP（汉密尔顿数字资产基金SP）、Hamilton Investment Management Limited（汉密尔顿投资管理有限公司）、Hamilton Opportunity Fund SPC（汉密尔顿机会基金SPC）、Hamilton PE Funds SP（汉密尔顿私募股权基金SP）、Holy City Hong Kong Ventures Ltd.（圣城香港创投有限公司）、GS Security Solutions Inc.（GS安保解决方案公司）、Alex Hadjcharalambous（亚历克斯·哈吉查兰布斯）、Han Chunguang（韩春光）、Haoran He（何浩然）、HCHK Property Management, Inc.（HCHK物业管理公司）、HCHK Technologies, Inc.（HCHK科技公司）、HK International Funds Investments (USA) Limited LLC（香港国际基金投资〈美国〉有限责任公司）、Freedom Media Ventures Ltd.（自由媒体创投有限公司）、FungWan Trading Inc.（丰湾贸易公司）、Himalaya Currency Clearing Pty. Ltd.（喜马拉雅货币清算有限公司）、Himalaya New World Inc.（喜马拉雅新世界公司）、Himalaya International Financial Group Ltd.（喜马拉雅国际金融集团有限公司）、Himalaya International Clearing Ltd.（喜马拉雅国际清算有限公司）、Himalaya International Payments Ltd.（喜马拉雅国际支付有限公司）、Himalaya International Reserves Ltd.（喜马拉雅国际储备有限公司）、Himalaya Ventures LLC（喜马拉雅创投有限责任公司）、Himalaya Investment LLC（喜马拉雅投资有限责任公司）、Hudson Diamond Holding, Inc.（哈德逊钻石控股公司）、Hudson Diamond Holding LLC（哈德逊钻石控股有限责任公司）、Hudson Diamond NY LLC（哈德逊钻石纽约有限责任公司）、Huk Trading Inc.（赫克贸易公司）、Infinity Treasury Management Inc.（无限资金管理公司）、Jesse Brown（杰西·布朗）、Jessica Mastrogiovanni（杰西卡·马斯特罗焦瓦尼）、Jiaming Liu（刘家明）、Jie Zhang（张杰）、Jovial Century International Limited（欢愉世纪国际有限公司）、Joyord Sportswear Limited（乔约德运动服饰有限公司）、K Legacy Ltd.（K传承有限公司）、Kamel Debeche（卡迈勒·德贝什）、Karin Maistrello（卡琳·迈斯特雷洛）、Kin Ming Je（谢建明）、Lamp Capital LLC（兰普资本有限责任公司）、Lawall & Mitchell, LLC（洛沃尔与米切尔有限责任公司）、Leading Shine NY Ltd.（领耀纽约有限公司）、Lexington Property and Staffing, Inc.（列克星敦物业与人力配置公司）、Lexington Property and Staffing LLC（列克星敦物业与人力配置有限责任公司）、Linwan “Irene” Feng（冯林婉“艾琳”）、Limarie Reyes（利马丽·雷耶斯）、Lihong “Sara” Wei Lafrenz（魏丽红“莎拉”·拉弗伦茨）、The Lost Draft LLC（遗失草稿有限责任公司）、Macaron Limited（马卡龙有限公司）、Major Lead International Limited（主要领先国际有限公司）、Mary Jiang（江玛丽）、MOS Himalaya LLC（MOS喜马拉雅有限责任公司）、Maywind Trading LLC（美风贸易有限责任公司）、New York MOS Himalaya LLC（纽约MOS喜马拉雅有限责任公司）、Next Tycoon Investments Limited（新大亨投资有限公司）、Nicholas Savio（尼古拉斯·萨维奥）、Nodal Partners, LLC（节点合伙人有限责任公司）、Qidong Xia（夏启东）、Oasis Tech Limited（绿洲科技有限公司）、O.S.C. Orbit Service Company, LLC（O.S.C.轨道服务公司有限责任公司）、Pixshow Film Inc.（像秀电影公司）、Qu Guo Jiao（焦曲国）、Roscalitar 2（罗斯卡利塔尔2）、Ridwan Mamode Saib（里德万·马莫德·赛义卜）、Ross Heinemeyer（罗斯·海内迈耶）、Rule of Law Society IV Inc.（法治协会IV公司）、Rule of Law Foundation\n案件 22-50073 文书 3193 于 05/16/24 提交 于 05/16/24 10:28:21 登记 第 88 页，共 439 页\nIII, Inc.（法治基金会III公司）、Rule of Law Fund（法治基金）、Saraca Media Group Inc.（萨拉卡媒体集团公司）、Savio Law LLC（萨维奥律师事务所有限责任公司）、Scott Barnett（斯科特·巴内特）、Seven Mission Group LLC（七项使命集团有限责任公司）、Shih Hsin Yu（石欣瑜）、Sirius Networking Inc.（天狼星网络公司）、Taurus Fund LLC（金牛基金有限责任公司）、Taurus Management LLC（金牛管理有限责任公司）、US Himalaya Capital Inc.（美国喜马拉雅资本公司）、V.X. Cerda & Associates P.A.（V.X.塞尔达及合伙人专业协会）、Victor Cerda（维克托·塞尔达）、Voice of Guo Media, Inc.（郭媒体之声公司）、Wen Xiao（肖文）、Wencong Wang（王文聪）、William Je（谢威廉）、Kin Ming Je（谢建明）（又名 Je Kin Ming（谢建明））、Wise Creation International Limited（智创国际有限公司）、Xuebing Wang（王学兵）、Yan Chun Liu（刘艳春）、Yinying (Aila) Wang（王银莹〈艾拉〉）（又名 Xiao Fei Xiang（肖飞翔））、Yongbing Zhang（张永兵）、Yongping Yan (Shan Mu) Yue Zhou（周月舟〈山木〉）、Yumei Hao（郝玉梅）（又名 Ru Shui（如水））、Yvette Wang（王伊维特）（又名 Yanping Wang（王艳萍）、又名 Yan Ping Wang（王艳萍））、Zhixuan Li（李智轩）、Zhouer “Joe” Wang（王周二“乔”）、NewPeople LLC（新人民有限责任公司）、Ziba Limited（齐巴有限公司）、New Mulberry PTE Ltd（新桑树私人有限公司）、TD Primrose Limited（TD报春花有限公司）以及 Shin Hee-Seup（申熙燮）（又名 Hee Seup Shin（申熙燮））。\n\n8. “Including（包括）”或其任何变体，意为“including without limitation（包括但不限于）”。\n\n9. “And”和“or”意为“and/or”，并应同时解释为连词和析取连词，以最大限度扩大其范围。\n\n10. “Any”、“all”和“each”意为“each and every（每一及所有）”。\n\n11. “Each”和“every”意为“each and every（每一及所有）”。\n\n12. “Third Party（第三方）”系指除您本人以外的个人或实体。\n\n13. “Transfer（转让）”应具有《Bankruptcy Code（破产法典）》section 101(54) 赋予该词的含义。\n\n14. “Document（文件）”系指属于 Fed. R. Civ. P. 34 范围内的任何信息或物品，并包括但不限于任何种类、类型、性质或描述的每一项书面、记录或图形资料，只要其现在或曾经处于您的占有、保管或控制之下，包括电子邮件的所有纸质及电子副本、以电子形式保存的计算机文件、函件、备忘录、磁带、速记或手写笔记、任何种类的书面表格、\n案件 22-50073 文书 3193 于 05/16/24 提交 于 05/16/24 10:28:21 登记 第 89 页，共 439 页\n图表、蓝图、图纸、草图、曲线图、计划、文章、规格说明、日记、信件、电报、照片、会议记录、合同、协议、调查资料、计算机打印件、任何种类的数据汇编、电传、传真、电子邮件、短信、即时消息、语音信息、发票、订购单、支票、汇票、对账单、贷项通知单、报告、头寸报告、摘要、索引、书籍、总账、笔记本、附表、透明胶片、录音、目录、广告、宣传材料、电影、录像带、录音带、CD、计算机磁盘、宣传册、小册子、穿孔卡、工时单、推文、社交媒体帖子或任何其他种类的书面或记录材料，以及其所有元数据，无论以何种方式储存（无论为有形形式或电子形式）、记录、制作或复制；还包括但不限于上述任何资料的草稿或副本，凡其中载有原始文件未载有的任何种类笔记、评论或标记，或在其他方面与原始文件不相同者。\n\n15. “Person(s)（个人）”系指个人、公司、独资企业、合伙企业、协会或任何其他实体。“Person”还包括任何代理人、代表或专家，包括但不限于律师或财务顾问。\n\n16. “Entity（实体）”系指任何自然人、公司、合伙企业、子公司、独资企业、商号、董事会、合资企业、协会、机构、主管机关、委员会或其他商业实体或法人，以及任何关联方、代理人、母公司，包括但不限于法律顾问、财务顾问或任何其他代表。\n\n17. “Regarding（关于）”意为涉及、描述、构成、提及、与之有关、支持、赞成、反对、加强、贬损、位于其中、结合予以考虑、对其有影响、证明、表明、报告、记录、暗示、答复、\n案件 22-50073 文书 3193 于 05/16/24 提交 于 05/16/24 10:28:21 登记 第 90 页，共 439 页\n与之相连、评论、就其而言、有关、与之相关、讨论、显示、描述、反映、分析、构成及为。\n\n18. 就任何特定事项而言，“Relating to（与……有关）”、“relate(s) to（与……有关）”或“related to（与……有关）”意为包括但不限于构成、包含、涉及、载有、体现、反映、识别、陈述、直接或间接提及该特定事项，或以任何方式与所确定的特定事项相关的任何文件。\n\n19. “Communication(s)（通信）”在最广义且不受限制的意义上，系指任何信息或知识的传递（以事实、观点、询问或其他形式）。通信还指所有谈话、协议、询问或答复，无论是当面、通过电话、书面方式或通过电子传输设备，并包括但不限于所有函件、电子邮件、录音、传递单、备忘录、电话通信、语音信息、电报、电传传真、复印传真、电传、即时消息、聊天、短信、留言板或群聊中的帖子、社交媒体帖子、推文、上传至任何视频平台的视频、电话笔记，或在内部或与第三方之间传递的笔记。\n\n20. “Asset(s)（资产）”系指受占有、保管或控制的任何具有经济价值的项目。资产包括所有不动产和动产，包括但不限于房地产、土地、房屋、公寓、共管公寓、汽车、游艇、船只、飞机、喷气式飞机、直升机、现金、银行账户、加密货币、证券、应收账款、存货及其他有形和无形财产。\n\nIV. 应提供的文件\n\n1. 与任何由任何 2004 调查对象持有、控制、代其持有或以其他方式与其有关的账户相关的所有文件，包括任何及所有账户对账单、\n案件 22-50073 文书 3193 于 05/16/24 提交 于 05/16/24 10:28:21 登记 第 91 页，共 439 页\n授权书、授权委托书、信托、指示或表格、已注销支票副本、函件，以及电汇及相关函件和指示。\n\n2. 与任何属于任何 2004 调查对象、由其持有、控制、代其持有或以其他方式与其有关的资金、证券、财产或资产相关的所有文件，包括任何及所有账户对账单、授权书、授权委托书、信托、指示或表格、已注销支票副本、函件，以及电汇及相关函件和指示。\n\n3. 与任何 2004 年调查对象有关的任何业务、商业或金融交易的所有文件，包括但不限于任何贷款、信贷额度、寄托、存款、掉期、证券交易、抵押贷款或 ISDA，以及任何和所有账户对账单、授权书、委托书、信托文件、指示或表格、已注销支票副本、通信函件、电汇及相关通信函件和指示。\n\n4. 与涉及 2004 年调查对象的任何电汇活动有关的所有文件，无论是否存在任何账户，包括但不限于所有电汇收据、账号、余额、授权书、与转账当事人有关的身份识别信息、通信函件、指示或其他记录。\n\n5. 与您和 2004 年调查对象之间的任何往来函件和通信有关的所有文件。\n\n6. 与任何 2004 年调查对象的任何账户有关的所有文件，涉及账户开立、账户获授权使用人及账户维护。\n\n7. 与涉及任何 2004 年调查对象的任何反洗钱、了解你的客户或其他合规活动有关的所有文件，包括但不限于任何 2004 年调查对象提供的或您获悉的任何信息。\n案件 22-50073 文件 3193 提交于 05/16/24 登记于 05/16/24 10:28:21 第 92 页，共 439 页\n\n8. 与来自任何国家的任何监管机构的任何通信有关的所有文件，包括但不限于 Bank of England（英格兰银行）、United States Federal Reserve（美国联邦储备系统）、S.E.C.（美国证券交易委员会）、CFTC（美国商品期货交易委员会）、FINRA（美国金融业监管局）、China Securities Regulatory Commission（中国证券监督管理委员会）、People's Bank of China（中国人民银行）、Hong Kong Securities and Futures Commission（香港证券及期货事务监察委员会）及 Hong Kong Monetary Authority（香港金融管理局），涉及任何 2004 年调查对象。\n附件 C-5\nB2540（表格 2540——规则 2004 审查传票）（12/15）案件 22-50073 文件 3193 提交于 05/16/24 登记于 05/16/24 10:28:21 第 94 页，共 439 页\n\n美国破产法院\n\nDistrict of Connecticut（康涅狄格地区）\n\n关于 HO WAN KWOK（郭文贵）等人，\n\n1 案件编号 22-50073 (JAM) 债务人 第 11 章\n\n（合并管理）\n规则 2004 审查传票\n\n致：Revolut Ltd.（Revolut 有限公司）\n\n（传票所指向人员的姓名）\n\n作证：兹命令您于下列规定的时间、日期和地点出席，并根据《联邦破产程序规则》第 2004 条接受审查并作证。随附准许该项审查的法院命令副本。\n\n地点　日期和时间\n\n不适用　不适用\n\n审查将以以下方式记录：不适用\n\n提交：您或您的代表还必须在审查时随身携带下列文件、电子存储信息或物品，并准许对该等材料进行查验、复制、测试或抽样：\n见随附的文件提交请求。\n\n下列《联邦民事诉讼规则》第 45 条规定，依《联邦破产程序规则》第 9016 条适用于破产案件，随附于此——第 45(c) 条，关于履行地点；第 45(d) 条，关于您作为传票对象所受的保护；以及第 45(e) 条和第 45(g) 条，关于您对本传票的回应义务及不履行该义务的潜在后果。\n\n日期：May , 2024\n\n法院书记员\n\n或\n\n书记员或副书记员签名　律师签名\n\n签发或请求本传票并代表第 11 章受托人 Luc A. Despins（Luc A. Despins）的律师姓名、地址、电子邮箱地址和电话号码如下：\n\nPatrick R. Linsey, Esq.; Neubert, Pepe & Monteith, P.C.（Neubert, Pepe & Monteith 专业公司）；195 Church Street, 13th Floor, New Haven, Connecticut 06510；plinsey@npmlaw.com；(203) 781-2847\n向签发或请求本传票之人的通知\n\n如本传票命令在审判前提交文件、电子存储信息或有形物品，或查验场所，则必须在向本传票所指向之人送达之前，向每一方当事人送达通知及本传票副本。《联邦民事诉讼规则》第 45(a)(4) 条。\n\n软件版权 (c) 1996-2022 Best Case, LLC（Best Case 有限责任公司）- www.bestcase.com Best Case Bankruptcy 1 本第 11 章案件中的债务人为 Ho Wan Kwok（亦称 Guo Wengui、Miles Guo 和 Miles Kwok，以及众多其他别名）（税务识别号码后四位：9595）、Genever Holdings LLC（税务识别号码后四位：8202）及 Genever Holdings Corporation（Genever 控股公司）。受托人、Genever Holdings LLC 和 Genever Holdings Corporation 的邮寄地址为 Paul Hastings LLP（普衡律师事务所），200 Park Avenue, New York, NY 10166，转交 Luc A. Despins，作为 Ho Wan Kwok 财产的受托人（仅用于通知和通信）。\n\n送达证明\n\n（除非《联邦民事诉讼规则》第 45 条要求，否则本节不应向法院提交。）\n\n我于（日期）收到向（个人姓名及职务，如有）送达的本传票。\n\n我按如下方式向具名人员交付副本，以送达本传票：\n\n于（日期）；或\n\n我未予执行即退回本传票，原因是：\n\n除非本传票代表美国或其官员或代理人签发，我还已向证人支付一天出席费用及法律允许的里程费，金额为 $ 。\n\n我的旅行费用为 $，服务费用为 $，合计为 $ 。\n\n我在伪证处罚的约束下声明，该等信息真实且正确。\n\n日期：\n\n送达人员签名\n\n正楷姓名及职务\n\n送达人员地址\n\n有关尝试送达等的补充信息：\n《联邦民事诉讼规则》第 45(c)、(d)、(e) 及 (g) 条（于 12/1/13 生效）（依《联邦破产程序规则》第 9016 条适用于破产案件）\n\n(c) 履行地点。\n\n(1) 审判、听证或证言记录。传票仅可按以下规定命令某人出席审判、听证或证言记录：\n\n(A) 在该人居住、受雇或经常亲自从事商业活动所在地 100 英里以内；或\n\n(B) 在该人居住、受雇或经常亲自从事商业活动所在州内，如该人\n\n(i) 为当事人或当事人的高级职员；或\n\n(ii) 被命令出席审判且不会产生重大费用。\n\n(2) 其他发现程序。传票可以命令：\n\n(A) 在该人居住、受雇或经常亲自从事商业活动所在地 100 英里以内的地点提交文件、电子存储信息或物品；以及\n\n(B) 在被查验场所对该场所进行查验。\n(d) 对传票对象的保护；执行。\n\n(1) 避免不当负担或费用；制裁。负责签发和送达传票的当事人或律师必须采取合理措施，以避免对传票对象施加不当负担或费用。要求履行的地区法院必须执行此项义务，并对未遵守该义务的当事人或律师施加适当制裁，其中可包括损失的收入和合理的律师费。\n\n(2) 命令提交材料或准许查验。\n\n(A) 无须出席。被命令提交文件、电子存储信息或有形物品，或准许查验场所的人，无须亲自到提交或查验地点出席，除非同时被命令出席证言记录、听证或审判。\n\n(B) 异议。被命令提交文件或有形物品，或准许查验的人，可以向传票指定的当事人或律师送达书面异议，反对查验、复制、测试或抽样全部或部分材料，或反对查验场所——或者反对以所请求的形式提交电子存储信息。异议必须在规定的履行时间之前或传票送达后 14 天之前（以较早者为准）送达。如提出异议，适用下列规则：\n\n(i) 送达人可在任何时候通知被命令之人后，向要求履行的地区法院提出动议，请求作出强制提交或查验的命令。\n\n(ii) 只有依照命令的指示，方可要求采取这些行为；该命令必须保护并非当事人或当事人高级职员的人免于承担因履行而产生的重大费用。\n\n(3) 撤销或修改传票。\n\n(A) 必须撤销或修改的情形。经及时动议，要求履行的地区法院必须撤销或修改具有下列情形的传票：\n\n(i) 未给予合理的履行时间；\n\n(ii) 要求某人在第 45(c) 条规定的地域限制以外履行；\n\n(iii) 要求披露享有特权或受其他保护的事项，且不存在适用的例外或豁免；或\n\n(iv) 对某人造成不当负担。\n\n(B) 可以撤销或修改的情形。为保护传票对象或受传票影响的人，要求履行的地区法院可经动议撤销或修改具有下列要求的传票：\n\n(i) 披露商业秘密或其他机密研究、开发或商业信息；或\n\n(ii) 披露未经聘用的专家的意见或信息，该等意见或信息并不描述争议中的具体事件，且源于该专家未经当事人请求进行的研究。\n\n(C) 以规定条件作为替代。在第 45(d)(3)(B) 条所述情形下，如送达人：\n\n(i) 证明其对证言或材料具有重大需要，且如不承受不当困难则无法以其他方式满足该需要；并且\n\n(ii) 确保被传唤之人将获得合理补偿，\n\n法院可以不撤销或修改传票，而是命令在规定条件下出席或提交。\n(e) 回应传票时的义务。\n\n(1) 提交文件或电子存储信息。下列程序适用于提交文件或电子存储信息：\n\n(A) 文件。回应提交文件传票的人必须按其在通常业务过程中保存的方式提交文件，或者必须整理并标注文件，使其对应于请求中的类别。\n\n(B) 未规定提交电子存储信息的形式。如传票未规定提交电子存储信息的形式，回应之人必须以其通常保存的一种或多种形式，或以一种或多种合理可用的形式提交。\n\n(C) 电子存储信息仅以一种形式提交。回应之人无须以一种以上形式提交相同的电子存储信息。\n\n(D) 无法访问的电子存储信息。回应之人无须就其认定因不当负担或费用而无法合理访问的来源中的电子存储信息提供发现程序。就强制发现程序或保护令提出动议时，回应之人必须证明该信息因不当负担或费用而无法合理访问。如作出该证明，法院仍可在请求方证明存在正当理由时，考虑第 26(b)(2)(C) 条的限制，命令从该等来源进行发现程序。法院可以为该发现程序规定条件。\n\n(2) 主张特权或保护。\n\n(A) 被扣留的信息。以信息享有特权或作为审判准备材料受保护为由扣留被传唤信息的人必须：(i) 明确提出该主张；以及\n\n(ii) 以不披露本身享有特权或受保护信息的方式，描述被扣留文件、通信函件或有形物品的性质，使当事人能够评估该主张。\n\n（B）已提供的信息。如果为响应传票而提供的信息受到特权主张或作为审判准备材料受保护的主张所规限，提出该主张的人可以将该主张及其依据通知任何已收到该信息的一方。当事人收到通知后，必须立即返还、隔离或销毁所指定的信息及其持有的任何副本；在该主张得到解决之前，不得使用或披露该信息；如该当事人在收到通知前已披露该信息，必须采取合理措施追回该信息；并且可以立即将该信息密封提交给要求履行的地区的法院，以裁定该主张。提供该信息的人必须保存该信息，直至该主张得到解决。\n\n(g) 藐视法庭。要求履行的地区的法院——并且在动议被移送后，签发法院——可以将已被送达但无充分理由不遵守传票或与之相关命令的人以藐视法庭论处。\n\n关于获取传票材料，参见 Fed.R.Civ.P.45(a) Committee Note (2013)\n\n……\n\n文件出示请求\nI. 指示\n\n1. 除非另有说明，下列文件请求（统称“请求”，各称“一项请求”）必须分别且具体地予以答复。除非贵方本着诚信提出异议，否则每项请求均应得到完整答复；如提出异议，则应按如下规定详细说明贵方异议的理由。如异议仅涉及某项请求的一部分，或其中包含的某个词语、短语或条款，贵方仅须说明对该部分的异议，并答复其余请求。\n\n2. 电子存储信息必须依照以下指示提供：\n\n- a. 图像。黑白图像必须为 300 DPI Group IV 单页 TIFF 文件。彩色图像必须以 JPEG 格式提供。文件名不得包含嵌入空格或特殊字符（包括逗号）。文件夹名称不得包含嵌入空格或特殊字符（包括逗号）。所有 TIFF 图像文件必须具有唯一文件名，即 Bates 编号。每张图像的右下角必须加注连续的 Bates 编号。每个文件夹中的 TIFF 文件数量不得超过 1000 个文件。Excel 电子表格应具有以该文件的 Bates 编号命名的占位图像。\n- b. 图像加载文件\n  - a. Concordance® 数据文件。数据文件（.DAT）包含将被加载至 Concordance® 数据库的所有字段化信息。.DAT 文件的第一行必须为识别字段名称的标题行。.DAT 文件必须使用以下 Concordance® 默认分隔符：逗号 ASCII 字符（020）引号 þ ASCII 字符（254）。日期字段应采用以下格式提供：mm/dd/yyyy。日期和时间字段必须为两个独立字段。如文件包括已成像的电子邮件及附件，则必须包括附件字段，以保留电子邮件与其附件之间的父项/子项关系。必须包括 OCRPATH 字段，以提供在所提供存储介质上提取文本文件的文件路径和名称。文本文件必须以 FIRSTBATES 命名。不得将文本包含在 .DAT 文件中。对于具有本地文件的文件，必须包括 LINK 字段，以提供本地文件的文件路径和名称。本地文件必须以 FIRSTBATES 命名。\n  - b. Concordance Image® 或 Opticon 交叉引用文件。图像交叉引用文件（.LOG 或 .OPT）将图像链接至数据库记录。该文件应为逗号分隔文件，每行由七个字段组成，并且数据库中的每张图像均应在交叉引用文件中占一行，格式如下：ImageID,VolumeLabel,ImageFilePath,DocumentBreak,FolderBreak,Box Break,PageCoun。\n  - c. 文件文本。文本必须作为独立文本文件提供，而非作为 .DAT 文件中的字段。文本文件的完整路径（OCRPATH）应包含在 .DAT 文件中。建议提供按 FIRSTBATES/Image Key 命名的文件级 ANSI 文本文件。提取的文本文件必须置于单独文件夹内，且每个文件夹中的文本文件数量不得超过 1,000 个文件。文件夹名称中不得有特殊字符（包括逗号）。文本文件必须按文件级别提供。\n  - d. 某些文件类型的本地格式提供。为充分理解其内容和含义而合理需要以本地格式查看的文件类型，必须以本地格式提供。这些文件包括但不限于电子表格、类似电子表格的文件（Microsoft Excel、逗号分隔值、制表符分隔值等）、Microsoft PowerPoint 或其他特殊演示文件、数据库文件以及音频/视频文件。提供一张带有 Bates 编号的分隔页图像，注明存在本地文件，并在 .dat 文件中将本地文件路径列为一个字段。所提供的本地文件应以与该文件分隔页相对应的 Bates 编号命名。将本地文件归入按递增方式命名的“NATIVE”目录中，并与图像目录分开。\n  - e. 去重。对于存在完全重复件的每份电子文件，仅提供一份副本。对于电子邮件，根据由 BCC、Body、CC、From、IntMsgID、To 和 Attach 属性生成的 MD5 哈希值合并重复件。对于电子邮件附件和独立电子文件，根据整个文件的 MD5 哈希值合并重复件。\n  - f. 元数据。以符合 Concordance 要求的加载文件（.dat）形式提供每份文件的提取元数据。.DAT 文件的第一行必须为识别字段名称的标题行。.DAT 文件必须使用以下 Concordance 默认分隔符：逗号 , ASCII 字符（020）引号 þ ASCII 字符（254）\n\n日期字段应采用以下格式提供：mm/dd/yyyy。日期和时间字段必须为两个独立字段。下列为必需元数据：\n\n字段名称　示例数据　说明\n\nFIRSTBATES　EDC0000001　本地文件文件/电子邮件的第一个 Bates 编号\nLASTBATES　EDC0000001　本地文件文件/电子邮件的最后一个 Bates 编号\n**对于单页文件，应填写 LASTBATES 字段\nATTACHRANGE　EDC0000001\n-　父项文件第一页的 Bates 编号至最后一个附件“子项”文件最后一页的 Bates 编号\nEDC0000015\nBEGATTACH　EDC0000001　附件范围的第一个 Bates 编号\nENDATTACH　EDC0000015　附件范围的最后一个 Bates 编号\nCUSTODIAN　Smith, John　电子邮件：电子邮件所在的邮箱\n本地文件：文件来源的个人或部门名称\nFROM　John Smith　电子邮件：发件人\n本地文件：文件作者\n**应使用分号分隔多个条目\nTO　Coffman, Janice; LeeW　收件人\n[mailto:LeeW@MSN.com]　**应使用分号分隔多个条目\nCC　Frank Thompson [mailto:　抄送收件人\nfrank_Thompson@cdt.com]　**应使用分号分隔多个条目\nBCC　John Cain　密送收件人\n**应使用分号分隔多个条目\nSUBJECT　Board Meeting Minutes　电子邮件：电子邮件的主题行 本地文件：文件标题（如有）\nFILE_NAME　BoardMeetingMinutes.docx　本地文件：原始本地文件的名称，包括扩展名\nDATE_SENT　10/12/2010　电子邮件：电子邮件发送日期\n本地文件：（空）\nTIME_SENT/\nTIME_ZONE　07:05 PM GMT　电子邮件：电子邮件发送时间/电子邮件标准化所采用的时区\nTIME_ZONE　GMT　在转换期间电子邮件被标准化所采用的时区。\nLINK　EDC0000001.msg　电子邮件或本地文件文件的超链接\n**链接文件必须按 FIRSTBATES 编号命名\nFILE_EXTEN　MSG　表示电子邮件或的文件类型扩展名\nAUTHOR　John Smith　电子邮件：（空）\n本地文件：文件作者\nDATE_CREATED　10/10/2010　电子邮件：（空）\n本地文件：文件创建日期\nCase 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 100 of 439\n\nTIME_CREATED　10:25 AM　电子邮件：（空）\n本地文件：文件创建时间\n**该数据必须为单独字段，且不得与 DATE_CREATED 字段合并\nDATE_MOD　10/12/2010　电子邮件：（空）\n本地文件：文件最后修改日期\nTIME_MOD　07:00 PM　电子邮件：（空）\n本地文件：文件最后修改时间\n**该数据必须为单独字段，且不得与 DATE_MOD 字段合并\nDATE_ACCESSD　10/12/2010　电子邮件：（空）\n本地文件：文件最后访问日期\nTIME_ACCESSD　07:00 PM　电子邮件：（空）\n本地文件：文件最后访问时间\n**该数据必须为单独字段，且不得与 DATE_ACCESSD 字段合并\nFILE_SIZE　5,952　本地文件文件/电子邮件的大小，单位为 KB\nPGCOUNT　1　本地文件文件/电子邮件的页数\nPATH　电子邮件：（空）\nAgenda.doc　本地文件：存储本地文件文件的路径，包括原始文件名。\nINTFILEPATH　Personal Folders\\Deleted　电子邮件：电子邮件的原始位置，包括原始文件名。\nItems\\Board Meeting\nMinutes.msg　本地文件：（空）\nINTMSGID　<000805c2c71b\\$75977050\\$　电子邮件：唯一消息 ID 本地文件：（空）\ncb8306d1@MSN>\nMD5HASH　d131dd02c5e6eec4693d9a0　文件的 MD5 哈希值。\n698aff95c\n2fcab58712467eab4004583e\nb8fb7f89\nOCRPATH　TEXT/001/EDC0000001.txt　本地文件提取文本的路径\n\n3. 每项请求独立运行且应独立解释，除非另有说明，任何一项请求均不限制任何其他请求的范围。\n\n4. 所有文件应按通常业务过程中的保存方式提供，或应组织并标注，以对应于这些请求中的类别。\n\n5. 本文件所载的每项请求均延及以下所有文件：(a) 由贵方占有、保管或控制的文件；或 (b) 由任何代表贵方行事的人占有、保管或控制的文件，\nCase 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 101 of 439\n\n包括贵方律师或其他代表及顾问。每份文件均应完整提供。\n\n6. 如要求贵方提供的文件已不再由贵方占有、保管或控制，则贵方的答复必须：(a) 详细描述该文件的性质及其内容；(b) 指明编制或撰写该文件的人，以及（如适用）该文件被发送给的人；(c) 指明该文件编制或创建的日期；(d) 说明该文件是否：(i) 遗失或丢失；(ii) 已被销毁；(iii) 已自愿或非自愿地转让给他人；或 (iv) 已以其他方式处置；(e) 说明该等处置的理由以及相关事实和情形；(f) 指明授权该等处置的人；(g) 指明该等处置的日期或大致日期；(h) 说明该文件最后一次由贵方占有、保管或控制的时间；以及 (i) 指明目前占有、保管或控制该文件的人（如有）。\n\n7. 如要求贵方提供的文件已被销毁，则除前述指示所要求的信息外，贵方的答复还必须说明：(a) 销毁该文件的理由；(b) 销毁该文件的人的身份；以及 (c) 指示销毁该文件的人的身份。\n\n8. 如贵方主张所要求的某一文件享有特权或属于律师工作成果，则贵方的答复必须：(a) 说明：(i) 足以支持贵方主张该文件享有特权的文件描述，(ii) 该文件的标题，(iii) 该文件的日期，(iv) 该文件的作者，(v) 该文件的收件人，(vi) 收到或阅览该文件原件或任何草稿、副本或复制件的每一人员的身份，(vii) 该文件本身，或该文件所载或提及的任何信息，是否由任何其他人员占有、保管或控制；如是，该等人员的身份，以及说明该等信息如何进入其占有范围的陈述，(viii) 据以扣留该文件的特权主张，以及 (ix) 贵方将据以支持该等特权主张的所有情形；及 (b) 就每一份基于特权主张而被扣留的文件，根据 D. Conn. L. Civ. R. 26(e)，制作一份特权清单，其中载明本指示第(a)部分所要求的全部信息。对于文件请求中未提出特权或工作成果主张的任何部分，应完整提供响应性文件。\n\n案件 22-50073 文件 3193 提交于 05/16/24 登记于 05/16/24 10:28:21 第 102 页，共 439 页\n\n9. 如一份原本具有响应性的文件的一部分包含受特权主张约束的信息，则仅应依照上述指示从该文件中删除或遮盖受该特权主张约束的部分，其余部分应予提供。\n\n10. 本请求具有持续性。特此指示贵方：(a) 一旦得知先前答复不完整或不正确，应立即补充或更正任何后来发现不完整或不正确的答复；及 (b) 提供传票所要求的任何额外文件。\n\n11. 如某一文件使用英语以外的语言，贵方应提供该文件。如某一文件使用英语以外的语言，且存在英文译本，贵方应同时提供两份文件。\n\n12. 对实体的所有提述均包括其所有关联方。\n\n13. 对个人姓名的所有提述均包括所有替代姓名、别名或昵称。\n\n14. 除非另有明确说明，文件请求所涵盖的期间为自 February 5, 2012 起至文件请求答复到期之日止。\n\nII. 解释规则\n\n15. (a) 任何单数名词的使用应解释为包括复数，反之亦然；及 (b) 任何时态动词的使用应解释为包括该动词的所有其他时态。\n\n16. (a) “and”和“or”应视需要解释为连词或析取词，以使原本可能被解释为不在任何请求范围内的所有答复均纳入其范围；及 (b) “each”和“any”应被视为包括并涵盖“every”和“all”二词。\n\nIII. 定义\n\n经 D. Conn. Bankr. L.R. 2004-1(a) 纳入的 D. Conn. L. Civ. R. 26(c) 所规定的定义，以及 D. Conn. L. Civ. R. 26(d) 所规定的解释规则，适用于文件请求。此外，本文件请求中使用的下列术语具有下列含义：\n\n1. “贵方”或“贵方的”或“贵方自身”系指 Revolut Ltd.（Revolut有限公司），连同其所有关联方、部门、机构、工具机构、处室、办事处、合伙人、高级职员、董事、代理人、律师、代表、雇员，和/或任何代表其行事的人。\n\n2. “债务人”系指 Ho Wan Kwok（郭文贵）（又名 Miles Kwok（郭文贵）、Miles Guo（郭文贵）、Guo Wengui（郭文贵）、Guo Haoyun（郭浩云）、郭文贵，或任何其他别名），连同其雇员、代理人、律师、顾问或任何代表其行事的人。\n\n案件 22-50073 文件 3193 提交于 05/16/24 登记于 05/16/24 10:28:21 第 104 页，共 439 页\n\n3. “债务人之子”系指 Qiang Guo（郭强）（又名 Mileson Kwok（郭强）、郭强，或任何其他别名），连同其雇员、代理人、律师、顾问或任何代表其行事的人。\n\n4. “债务人之女”系指 Mei Guo（郭美）（又名 Mei Gui（郭美）、郭美，或任何其他别名），连同其雇员、代理人、律师、顾问或任何代表其行事的人。\n\n5. “债务人所谓妻子”系指 Hing Chi Ngok（岳庆芝）（又名 Hing Chi Ng（岳庆芝）、Yue Qingzhi（岳庆芝）、岳庆芝，或任何其他别名），连同其雇员、代理人、律师、顾问或任何代表其行事的人。\n\n6. “债务人家庭成员”单独及合称指债务人、债务人之子、债务人之女和债务人所谓妻子，以及与债务人有任何其他亲属关系的人。\n\n7. “2004 取证对象”单独及合称指债务人、债务人家庭成员、17 Miles, LLC（17英里有限责任公司）、5780 Saguaro LLC（5780仙人掌有限责任公司）、Aaron Mitchell（阿伦·米切尔）、ACA Capital Group Limited（ACA资本集团有限公司）、Ace Decade Holdings Limited（王牌十年控股有限公司）、AI Group Holdings Inc.（AI集团控股公司）、Alfa Global Ventures Limited（阿尔法全球创投有限公司）、Alphonso Global Ventures Limited（阿方索全球创投有限公司）、Ana C. Izquiedo-Henn（安娜·C·伊斯奎耶多-亨）、Andrew Childe（安德鲁·柴尔德）、Anthony DiBattista（安东尼·迪巴蒂斯塔）、Anton Development Limited（安东发展有限公司）、Booming Sail New York LLC（纽约盛帆有限责任公司）、Beile Li（李贝乐）、Bingshang Jiao（焦冰尚）、Bravo Luck Limited（好运有限公司）、Brent Petro Inc.（布伦特石油公司）、Celestial Tide Limited（天潮有限公司）、Chris Lee（克里斯·李）（又名 Nan Li（李楠）、Mei Guo Xiao Li（郭美小李））、China Golden Spring Group (Hong Kong) Ltd.（中国金泉集团〈香港〉有限公司）、Crane Advisory Group（鹤顾问集团）、Daniel Thomas Podhaskie（丹尼尔·托马斯·波德哈斯基）、Defeng Cao（曹德峰）（又名 Wayne Cao（韦恩·曹）、Max Cao（马克斯·曹））、Ding “Ivan” Lin（林丁〈伊万〉）、Doaa Dashoush（杜阿·达舒什）、Eastern Profit Corporation Limited（东方利润有限公司）、Genever Holdings Corporation（热内维尔控股公司）、Genever Holdings LLC（热内维尔控股有限责任公司）、Gettr USA, Inc.（GETTR美国公司）、Gnews Media Group Inc.（Gnews媒体集团公司）、G Fashion (CA)（G时尚〈加州〉）、G Fashion（G时尚）、G Fashion Hold Co. A. Limited（G时尚控股A有限公司）、G Fashion Hold Co. B. Limited（G时尚控股B有限公司）、G Fashion Media Group Inc.（G时尚媒体集团公司）、G Fashion International Limited（G时尚国际有限公司）、G Fashion LLC（G时尚有限责任公司）、Gmusic LLC（G音乐有限责任公司）、Gnews LLC（Gnews有限责任公司）、Geducation（G教育）、GFNY, Inc.（GFNY公司）、G Club Finance（G俱乐部金融）、G Club HoldCo I LLC（G俱乐部控股I有限责任公司）、G Club International Limited（G俱乐部国际有限公司）、G Club Investments Limited（G俱乐部投资有限公司）、G Club Operations\n\n案件 22-50073 文件 3193 提交于 05/16/24 登记于 05/16/24 10:28:21 第 105 页，共 439 页\n\nLLC（G俱乐部运营有限责任公司）、G Club US Operations Inc.（G俱乐部美国运营公司）、G Club US Operations LLC（G俱乐部美国运营有限责任公司）、G Club（G俱乐部）、G Club One（G俱乐部一号）、G Club Two（G俱乐部二号）、G Club Three（G俱乐部三号）、G Live, LLC（G直播有限责任公司）、Gbroadcast, LLC（G广播有限责任公司）、GM 27 LLC（GM 27有限责任公司）、Gladys Chow（周格拉迪斯）、Golden Spring (New York) Ltd.（金泉〈纽约〉有限公司）、Gposts LLC（G帖子有限责任公司）、GTV Media Group, Inc.（GTV媒体集团公司）、Gypsy Mei Food Service LLC（吉普赛美餐饮服务有限责任公司）、Gypsy Mei Productions LLC（吉普赛美制作有限责任公司）、Gypsy Mei 27 Vestry, Inc.（吉普赛美27维斯特里公司）、Dawn State Limited（曙光州有限公司）、Greenwich Land LLC（格林尼治地产有限责任公司）、Hao (Gavin) Li（李浩〈加文〉）（又名 Huo Lai（霍来））、Haitham Khaled（海赛姆·哈立德）、Hamilton Capital Holdings Inc.（汉密尔顿资本控股公司）、Hamilton Digital Assets Funds SP（汉密尔顿数字资产基金SP）、Hamilton Investment Management Limited（汉密尔顿投资管理有限公司）、Hamilton Opportunity Fund SPC（汉密尔顿机会基金SPC）、Hamilton PE Funds SP（汉密尔顿私募股权基金SP）、Holy City Hong Kong Ventures Ltd.（圣城香港创投有限公司）、GS Security Solutions Inc.（GS安保解决方案公司）、Alex Hadjcharalambous（亚历克斯·哈吉查兰博斯）、Han Chunguang（韩春光）、Haoran He（何浩然）、HCHK Property Management, Inc.（HCHK物业管理公司）、HCHK Technologies, Inc.（HCHK技术公司）、HK International Funds Investments (USA) Limited LLC（香港国际基金投资〈美国〉有限责任公司）、Freedom Media Ventures Ltd.（自由媒体创投有限公司）、FungWan Trading Inc.（风云贸易公司）、Himalaya Currency Clearing Pty. Ltd.（喜马拉雅货币清算有限公司）、Himalaya New World Inc.（喜马拉雅新世界公司）、Himalaya International Financial Group Ltd.（喜马拉雅国际金融集团有限公司）、Himalaya International Clearing Ltd.（喜马拉雅国际清算有限公司）、Himalaya International Payments Ltd.（喜马拉雅国际支付有限公司）、Himalaya International Reserves Ltd.（喜马拉雅国际储备有限公司）、Himalaya Ventures LLC（喜马拉雅创投有限责任公司）、Himalaya Investment LLC（喜马拉雅投资有限责任公司）、Hudson Diamond Holding, Inc.（哈德逊钻石控股公司）、Hudson Diamond Holding LLC（哈德逊钻石控股有限责任公司）、Hudson Diamond NY LLC（哈德逊钻石纽约有限责任公司）、Huk Trading Inc.（Huk贸易公司）、Infinity Treasury Management Inc.（无限资金管理公司）、Jesse Brown（杰西·布朗）、Jessica Mastrogiovanni（杰西卡·马斯特罗焦瓦尼）、Jiaming Liu（刘佳明）、Jie Zhang（张杰）、Jovial Century International Limited（欢乐世纪国际有限公司）、Joyord Sportswear Limited（乔约德运动服饰有限公司）、K Legacy Ltd.（K传承有限公司）、Kamel Debeche（卡迈勒·德贝什）、Karin Maistrello（卡琳·迈斯特雷洛）、Kin Ming Je（谢建明）、Lamp Capital LLC（灯资本有限责任公司）、Lawall & Mitchell, LLC（劳沃尔与米切尔有限责任公司）、Leading Shine NY Ltd.（纽约领先光芒有限公司）、Lexington Property and Staffing, Inc.（莱克星顿地产与人力公司）、Lexington Property and Staffing LLC（莱克星顿地产与人力有限责任公司）、Linwan “Irene” Feng（冯琳婉〈艾琳〉）、Limarie Reyes（利马里·雷耶斯）、Lihong “Sara” Wei Lafrenz（魏丽红〈萨拉〉·拉弗伦茨）、The Lost Draft LLC（遗失草稿有限责任公司）、Macaron Limited（马卡龙有限公司）、Major Lead International Limited（美卓领国际有限公司）、Mary Jiang（江玛丽）、MOS Himalaya LLC（MOS喜马拉雅有限责任公司）、Maywind Trading LLC（五月风贸易有限责任公司）、New York MOS Himalaya LLC（纽约MOS喜马拉雅有限责任公司）、Next Tycoon Investments Limited（下一大亨投资有限公司）、Nicholas Savio（尼古拉斯·萨维奥）、Nodal Partners, LLC（节点合伙人有限责任公司）、Qidong Xia（夏启东）、Oasis Tech Limited（绿洲科技有限公司）、O.S.C. Orbit Service Company, LLC（O.S.C.轨道服务公司有限责任公司）、Pixshow Film Inc.（皮克秀电影公司）、Qu Guo Jiao（郭姣）、Roscalitar 2（罗斯卡利塔尔2）、Ridwan Mamode Saib（里德万·马莫德·赛义卜）、Ross Heinemeyer（罗斯·海内迈耶）、Rule of Law Society IV Inc.（法治协会IV公司）、Rule of Law Foundation\n\n案件 22-50073 文件 3193 提交于 05/16/24 登记于 05/16/24 10:28:21 第 106 页，共 439 页\n\nIII, Inc.（法治基金会III公司）、Rule of Law Fund（法治基金）、Saraca Media Group Inc.（萨拉卡媒体集团公司）、Savio Law LLC（萨维奥律师事务所有限责任公司）、Scott Barnett（斯科特·巴尼特）、Seven Mission Group LLC（七项使命集团有限责任公司）、Shih Hsin Yu（余世新）、Sirius Networking Inc.（天狼星网络公司）、Taurus Fund LLC（金牛基金有限责任公司）、Taurus Management LLC（金牛管理有限责任公司）、US Himalaya Capital Inc.（美国喜马拉雅资本公司）、V.X. Cerda & Associates P.A.（V.X.塞尔达及合伙人专业协会）、Victor Cerda（维克托·塞尔达）、Voice of Guo Media, Inc.（郭媒体之声公司）、Wen Xiao（肖文）、Wencong Wang（王文聪）、William Je（谢威廉）、Kin Ming Je a/k/a Je Kin Ming（谢建明，又名谢建明）、Wise Creation International Limited（智创国际有限公司）、Xuebing Wang（王雪冰）、Yan Chun Liu（刘艳春）、Yinying (Aila) Wang（王茵茵〈艾拉〉）（又名 Xiao Fei Xiang（小飞象））、Yongbing Zhang（张永兵）、Yongping Yan (Shan Mu) Yue Zhou（闫永平〈山木〉岳周）、Yumei Hao（郝玉梅）（又名 Ru Shui（如水））、Yvette Wang（王伊薇特）（又名 Yanping Wang（王燕平），又名 Yan Ping Wang（王燕平））、Zhixuan Li（李志轩）、Zhouer “Joe” Wang（王周二〈乔〉）、NewPeople LLC（新人有限责任公司）、Ziba Limited（齐巴有限公司）、New Mulberry PTE Ltd（新桑树私人有限公司）、TD Primrose Limited（TD报春花有限公司），以及 Shin Hee-Seup（申熙燮）（又名 Hee Seup Shin（申熙燮））。\n\n8. “Including”或其任何变体意指“包括但不限于”。\n\n9. “And”和“or”意指“和/或”，并应被解释为既具连词意义亦具析取意义，以最大限度扩大其范围。\n\n10. “Any”、“all”和“each”意指“每一及所有”。\n\n11. “Each”和“every”意指“每一及所有”。\n\n12. “第三方”系指贵方自身以外的人员或实体。\n\n13. “转让”具有《破产法典》第 101(54) 节赋予其的含义。\n\n14. “文件”系指 Fed. R. Civ. P. 34 范围内的任何信息或物品，并包括但不限于贵方占有、保管或控制之中或曾处于其占有、保管或控制之中的任何种类、类型、性质或描述的每一书面、记录或图形材料，包括电子邮件的所有印刷及电子副本、以电子形式保存的计算机文件、通信函件、备忘录、磁带、速记或手写笔记、任何种类的书面表格、\n\n案件 22-50073 文件 3193 提交于 05/16/24 登记于 05/16/24 10:28:21 第 107 页，共 439 页\n\n图表、蓝图、绘图、草图、图形、计划、文章、规格、日记、信函、电报、照片、会议记录、合同、协议、调查、计算机打印输出、任何种类的数据汇编、电传、传真、电子邮件、短信、即时消息、语音消息、发票、订货单、支票、汇票、对账单、贷项通知单、报告、持仓报告、摘要、索引、书籍、账簿、笔记本、附表、透明胶片、录音、目录、广告、宣传材料、电影、录像带、录音带、CD、计算机磁盘、宣传册、小册子、穿孔卡、工时单、推文、社交媒体帖子，或任何其他种类的书面或记录材料，以及其所有元数据，无论其以何种方式存储（无论是有形形式还是电子形式）、记录、制作或复制；还包括但不限于任何前述材料的草稿或副本，如其包含原始文件中未载有的任何种类的笔记、评论或标记，或以其他方式与原始文件不相同。\n\n15. “人员”系指个人、公司、独资企业、合伙企业、协会或任何其他实体。“人员”还包括任何代理人、代表或专家，包括但不限于律师或财务顾问。\n\n16. “实体”系指任何自然人、公司、合伙企业、子公司、独资企业、商号、董事会、合资企业、协会、机构、主管机关、委员会或其他商业实体或法人，以及任何关联方、代理人、母公司，包括但不限于法律顾问、财务顾问或任何其他代表。\n\n17. “Regarding”意指涉及、描述、包含、提及、与之相关、支持、赞成、反对、强化、削弱、位于、结合考虑、对……有影响、证明、表明、报告、记录、暗指、答复、\n\n案件 22-50073 文件 3193 提交于 05/16/24 登记于 05/16/24 10:28:21 第 108 页，共 439 页\n\n与之关联、评论、关于、就……而言、讨论、展示、描述、反映、分析、构成及属于。\n\n18. 就任何特定主题事项而言，“Relating to”、“relate(s) to”或“related to”系指，包括但不限于，构成、包含、涉及、含有、体现、反映、识别、陈述、直接或间接提及该特定主题事项，或以任何方式与该已识别特定主题事项相关的任何文件。\n\n19. “Communication(s)”系指在最广泛可能意义上的且不限于任何信息或知识的传递（以事实、观点、询问或其他形式）。Communication(s)还指所有谈话、协议、询问或答复，无论是当面、通过电话、书面方式，或通过电子传输设备进行，并包括但不限于所有函件、电子邮件、录音、传送单、备忘录、电话通信、语音留言、电报、传真、电传副本、电传、即时消息、聊天记录、短信、发布至留言板或群聊的内容、社交媒体帖子、推文、上传至任何视频平台的视频、电话记录，或在内部或与第三方之间传送的记录。\n\n20. “Asset(s)”系指受占有、保管或控制的任何具有经济价值的项目。资产包括所有不动产和动产，包括但不限于房地产、土地、房屋、公寓、共管公寓、汽车、游艇、船舶、飞机、喷气式飞机、直升机、现金、银行账户、加密货币、证券、应收账款、存货及其他有形和无形财产。\n\nIV. 应提交的文件\n\n1. 与任何由任何2004调查对象持有、控制、代表其持有，或以其他方式与其相关的账户有关的所有文件，包括任何及所有账户对账单、授权书、委托书、信托文件、指示或表格、已注销支票副本、函件，以及电汇及相关函件和指示。\n\n案号 22-50073 文件 3193 提交日期 05/16/24 登记日期 05/16/24 10:28:21 第 109 页，共 439 页\n\n2. 与属于任何2004调查对象、由其持有、控制、代表其持有，或以其他方式与其相关的任何资金、证券、财产或资产有关的所有文件，包括任何及所有账户对账单、授权书、委托书、信托文件、指示或表格、已注销支票副本、函件，以及电汇及相关函件和指示。\n\n3. 与同任何2004调查对象进行的任何商业、贸易或金融交易有关的所有文件，包括但不限于任何贷款、信贷额度、寄托、存款、互换、证券交易、抵押贷款或ISDA，以及任何及所有账户对账单、授权书、委托书、信托文件、指示或表格、已注销支票副本、函件，以及电汇及相关函件和指示。\n\n4. 与涉及2004调查对象的任何电汇活动有关的所有文件，无论是否存在任何账户，包括但不限于所有电汇收据、账号、余额、授权书、与转账各方有关的身份识别信息、函件、指示或其他记录。\n\n5. 与贵方和2004调查对象之间的任何函件和通信有关的所有文件。\n\n6. 与任何2004调查对象的任何账户有关、涉及该账户开立、该账户获授权使用人及该账户维护的所有文件。\n\n7. 与任何2004调查对象有关的任何反洗钱、了解你的客户或其他合规活动有关的所有文件，包括但不限于任何由任何2004调查对象提供的信息，或贵方获知的信息。\n\n案号 22-50073 文件 3193 提交日期 05/16/24 登记日期 05/16/24 10:28:21 第 110 页，共 439 页\n\n8. 与同任何国家的任何监管机构进行的任何通信有关、涉及任何2004调查对象的所有文件，包括但不限于英格兰银行（Bank of England）、美国联邦储备系统（United States Federal Reserve）、美国证券交易委员会（S.E.C.）、美国商品期货交易委员会（CFTC）、美国金融业监管局（FINRA）、中国证券监督管理委员会（China Securities Regulatory Commission）、中国人民银行（People's Bank of China）、香港证券及期货事务监察委员会（Hong Kong Securities and Futures Commission）及香港金融管理局（Hong Kong Monetary Authority）。\n\n案号 22-50073 文件 3193 提交日期 05/16/24 登记日期 05/16/24 10:28:21 第 111 页，共 439 页\n\n附件 C-6\n\nB2540（表格2540——根据规则2004进行审查的传票）（12/15）案号 22-50073 文件 3193 提交日期 05/16/24 登记日期 05/16/24 10:28:21 第 112 页，共\n\n美国破产法院（UNITED STATES BANKRUPTCY COURT）\n\n康涅狄格地区（District of Connecticut）\n\n关于 HO WAN KWOK（郭文贵）等人，\n\n1 案号 22-50073 (JAM) 债务人 第11章\n\n（合并管理）\n\n根据规则2004进行审查的传票\n\n致：CIMN Bank Berhad，又称 CIMB Islamic Bank Berhad\n\n（传票所指向人员的姓名）\n\n证言：特此命令贵方于下列规定的时间、日期和地点出席，并根据《联邦破产程序规则》（Federal Rules of Bankruptcy Procedure）规则2004接受审查并作证。随附授权该审查的法院命令副本。\n\n地点　日期和时间\n\n不适用　不适用\n\n审查将以以下方式记录：不适用\n\n提交：贵方或贵方代表还必须在审查时携带以下文件、电子存储信息或物品，并必须准许对该等材料进行查验、复制、测试或抽样：\n\n见随附的文件提交请求。\n\n《联邦民事诉讼规则》（Fed. R. Civ. P.）第45条的下列规定，根据《联邦破产程序规则》（Fed. R. Bankr. P.）第9016条适用于破产案件，现随附于后——有关履行地点的第45(c)条；有关对作为传票对象之人员的保护的第45(d)条；以及有关贵方对本传票作出回应的义务及不作出回应的潜在后果的第45(e)条和第45(g)条。\n\n日期：May , 2024\n\n法院书记员\n\n或\n\n书记员或副书记员签名　律师签名\n\n签发或请求本传票、代表第11章受托人 Luc A. Despins（卢克·A·德斯平斯）的律师姓名、地址、电子邮件地址及电话号码如下：\n\nPatrick R. Linsey, Esq.（帕特里克·R·林赛律师）；Neubert, Pepe & Monteith, P.C.；195 Church Street, 13th Floor, New Haven, Connecticut 06510；plinsey@npmlaw.com；(203) 781-2847\n\n致签发或请求本传票之人员的通知\n\n如本传票命令在审判前提交文件、电子存储信息或有形物品，或查验场所，则必须在向其所指向人员送达之前，向每一当事人送达本传票的通知及副本。Fed. R. Civ. P. 45(a)(4)。\n\n软件版权 (c) 1996-2022 Best Case, LLC - www.bestcase.com Best Case Bankruptcy 1 本第11章案件中的债务人为 Ho Wan Kwok（郭文贵）（亦称 Guo Wengui、Miles Guo 和 Miles Kwok，以及众多其他别名）（税务识别号码后四位：9595）、Genever Holdings LLC（税务识别号码后四位：8202）及 Genever Holdings Corporation。受托人、Genever Holdings LLC和Genever Holdings Corporation的邮寄地址为 Paul Hastings LLP, 200 Park Avenue, New York, NY 10166，转交 Luc A. Despins，作为 Ho Wan Kwok 财产的受托人（仅为通知和通信之目的）。\n\n送达证明\n\n（除非 Fed. R. Civ. P. 45 要求，否则本节不应向法院提交。）\n\n我于（日期）收到向（个人姓名及职称，如有）发出的本传票。\n\n我已按以下方式将本传票副本交付给所列名人员，完成送达：\n\n于（日期）；或\n\n我退回未执行的传票，原因如下：\n\n除非本传票代表美国或其官员或代理人签发，我还已向证人支付一天出席费及法律允许的里程费，金额为 $ 。\n\n我的差旅费为 $，服务费为 $，合计为 $ 。\n\n我在伪证罪处罚的约束下声明，该等信息真实且正确。\n\n日期：\n\n送达人员签名\n\n正楷姓名及职称\n\n送达人员地址\n\n有关尝试送达等的补充信息：\n\n《联邦民事诉讼规则》第45(c)、(d)、(e)和(g)条（Effective 12/1/13）（根据《联邦破产程序规则》第9016条适用于破产案件）\n\n(c) 履行地点。\n\n(1) 审判、听证或证言录取。传票仅可按如下方式命令某人出席审判、听证或证言录取：\n\n(A) 在该人居住、受雇或经常亲自从事业务之地100英里范围内；或\n\n(B) 在该人居住、受雇或经常亲自从事业务所在州内，如该人\n\n(i) 是当事人或当事人的高级职员；或\n\n(ii) 被命令出席审判且不会产生重大费用。\n\n(2) 其他证据开示。传票可命令：\n\n(A) 在该人居住、受雇或经常亲自从事业务之地100英里范围内的地点提交文件、电子存储信息或物品；以及\n\n(B) 在应受查验的场所查验场所。\n\n(d) 对作为传票对象之人员的保护；执行。\n\n(1) 避免不当负担或费用；制裁。负责签发和送达传票的当事人或律师必须采取合理措施，避免对作为传票对象之人员施加不当负担或费用。要求履行的地区法院必须执行该义务，并对未遵守者——当事人或律师——施加适当制裁，其中可包括误工收入及合理的律师费。\n\n(2) 命令提交材料或准许查验。\n\n(A) 无须出席。被命令提交文件、电子存储信息或有形物品，或准许查验场所的人员，无须亲自到提交或查验地点出席，除非同时被命令出席证言录取、听证或审判。\n\n(B) 异议。被命令提交文件或有形物品，或准许查验的人员，可以向传票中指定的当事人或律师送达书面异议，反对对任何或全部材料进行查验、复制、测试或抽样，或反对查验场所——或反对以所要求的一种或多种形式提交电子存储信息。异议必须在指定履行时间或传票送达后14日中较早者之前送达。如提出异议，适用以下规则：\n\n(i) 在任何时候，经通知被命令人员，送达方可向要求履行的地区法院提出动议，请求作出强制提交或查验的命令。\n\n(ii) 仅可依命令指示要求实施该等行为，且该命令必须保护非当事人亦非当事人高级职员的人员，使其免于因履行而产生的重大费用。\n\n(3) 撤销或修改传票。\n\n(A) 必须撤销或修改的情形。经及时动议，要求履行的地区法院必须撤销或修改具有下列情形的传票：\n\n(i) 未给予合理履行时间；\n\n(ii) 要求某人在第45(c)条规定的地域限制以外履行；\n\n(iii) 要求披露享有特权或受其他保护的事项，且不存在适用的例外或豁免；或\n\n(iv) 使某人承受不当负担。\n\n(B) 可以撤销或修改的情形。为保护作为传票对象或受传票影响的人员，要求履行的地区法院可以依动议撤销或修改要求下列事项的传票：\n\n(i) 披露商业秘密或其他保密的研究、开发或商业信息；或\n\n(ii) 披露未受聘专家的意见或信息，该等意见或信息并非描述争议中的特定事件，且源自该专家未经当事人请求而进行的研究。\n\n(C) 将规定条件作为替代方案。在第45(d)(3)(B)条所述情形下，如送达方：法院可以不撤销或修改传票，而是在规定条件下命令出席或提交：\n\n(i) 表明对该证言或材料具有重大需要，且如不造成不当困难便无法以其他方式满足该需要；并且\n\n(ii) 确保被传唤人将获得合理报酬。\n(e) 对传票作出回应时的义务。\n\n(1) 提供文件或电子存储信息。以下程序适用于提供文件或电子存储信息：\n\n(A) 文件。对要求提供文件的传票作出回应的人，必须按照其在日常业务过程中保存的方式提供文件，或者必须将文件整理并标记，以对应于请求中的类别。\n\n(B) 未指定电子存储信息提供形式。如传票未指定提供电子存储信息的形式，作出回应的人必须以该信息通常保存的一种或多种形式，或以一种或多种合理可用的形式提供该信息。\n\n(C) 电子存储信息仅以一种形式提供。作出回应的人无需以一种以上的形式提供相同的电子存储信息。\n\n(D) 无法访问的电子存储信息。对于作出回应的人认定因不当负担或费用而无法合理访问的来源中的电子存储信息，作出回应的人无需提供证据开示。在提出强制证据开示动议或保护令动议时，作出回应的人必须证明该信息因不当负担或费用而无法合理访问。如作出该证明，法院在考虑第 26(b)(2)(C) 条的限制后，如请求方证明具有正当理由，仍可命令对该等来源进行证据开示。法院可规定该证据开示的条件。\n(2) 主张特权或保护。\n\n(A) 扣留的信息。基于该信息享有特权或作为审判准备材料受到保护的主张而扣留被传唤信息的人，必须：(i) 明确提出该主张；并且\n\n(ii) 以一种在不披露本身享有特权或受保护的信息的情况下，能够使各方当事人评估该主张的方式，说明被扣留文件、通信或有形物的性质。\n\n(B) 已提供的信息。如为回应传票而提供的信息受特权主张或作为审判准备材料受到保护的主张约束，提出该主张的人可将该主张及其依据通知任何收到该信息的当事人。接到通知后，当事人必须立即返还、隔离或销毁指定信息及其持有的任何副本；在该主张得到解决前，不得使用或披露该信息；如该当事人在接到通知前已披露该信息，必须采取合理措施追回该信息；并可立即向要求履行义务所在地区的法院密封提交该信息，以裁定该主张。提供该信息的人必须在该主张得到解决前保存该信息。\n\n(g) 藐视法庭。要求履行义务所在地区的法院——以及在动议被移送后，签发传票的法院——可对已被送达但无充分理由未遵守传票或相关命令的人，作出藐视法庭的认定。\n\n有关获取传票材料，参见 Fed.R.Civ.P.45(a) Committee Note (2013)\n\n……\n\n文件提供请求\nI. 指示\n\n1. 除非另有说明，下列文件请求（以下简称“请求”，每一项单称“一项请求”）必须分别且具体地作出回应。除非善意地提出异议，否则必须完整回答每一项请求；如提出异议，应按如下所述详细说明贵方异议的理由。如异议仅涉及一项请求的一部分，或其中包含的一个词、短语或条款，贵方必须仅说明对该部分的异议，并对其余请求作出回应。\n\n2. 电子存储信息必须依照以下指示提供：\n\na. 图像。黑白图像必须为 300 DPI Group IV 单页 TIFF 文件。彩色图像必须以 JPEG 格式提供。文件名不得包含嵌入空格或特殊字符（包括逗号）。文件夹名称不得包含嵌入空格或特殊字符（包括逗号）。所有 TIFF 图像文件必须具有唯一文件名，即 Bates 编号。每张图像右下角必须加注连续的 Bates 编号。每个文件夹中的 TIFF 文件数量不得超过 1000 个。Excel 电子表格应具有一个以该文件 Bates 编号命名的占位图像。\n\nb. 图像加载文件\n\na. Concordance® 数据文件。数据文件（.DAT）包含将被加载至 Concordance® 数据库的所有字段信息。.DAT 文件的第一行必须为标明字段名称的标题行。.DAT 文件必须使用以下 Concordance® 默认分隔符：逗号 ASCII 字符（020）引号 þ ASCII 字符（254）。日期字段应按以下格式提供：mm/dd/yyyy。日期和时间字段必须分为两个独立字段。如文件包括图像化电子邮件及附件，则必须包括附件字段，以保留电子邮件与其附件之间的父/子关系。必须包括 OCRPATH 字段，以提供已提供存储介质上提取文本文件的文件路径和名称。文本文件必须以 FIRSTBATES 命名。不得在 .DAT 文件中包含文本。对于含有原生文件的文件，必须包括 LINK 字段，以提供原生文件的文件路径和名称。原生文件必须以 FIRSTBATES 命名。\n\nb. Concordance Image® 或 Opticon 交叉引用文件。图像交叉引用文件（.LOG 或 .OPT）将图像链接至数据库记录。该文件应为逗号分隔文件，每行由七个字段组成，且数据库中的每个图像均应在交叉引用文件中有一行，格式如下：ImageID,VolumeLabel,ImageFilePath,DocumentBreak,FolderBreak,Box Break,PageCount。\n\nc. 文件文本。文本必须作为单独的文本文件提供，而非作为 .DAT 文件内的字段。文本文件的完整路径（OCRPATH）应包含在 .DAT 文件中。建议提供文件级 ANSI 文本文件，并按 FIRSTBATES/Image Key 命名。提取的文本文件必须置于单独的文件夹中，每个文件夹中的文本文件数量不得超过 1,000 个。文件夹名称中不得有特殊字符（包括逗号）。必须按文件级别提供文本文件。\n\nd. 特定文件类型的原生文件提供。为完整理解其内容和含义而合理需要以原生格式查看的文件类型，必须以原生格式提供。该等文件包括但不限于电子表格、类似电子表格的文件（Microsoft Excel、逗号分隔值、制表符分隔值等）、Microsoft PowerPoint 或其他特殊演示文件、数据库文件以及音频/视频文件。应提供一张标有 Bates 编号的分隔页图像，说明存在原生文件，并在 .dat 文件中将原生文件的路径作为字段列入。所提供的原生文件应以与该文件分隔页相对应的 Bates 编号命名。将原生文件归入按递增方式命名的“NATIVE”目录中，并与图像目录分开。\n\ne. 去重。对于存在完全重复件的每份电子文件，仅提供一份副本。对于电子邮件，根据由 BCC、Body、CC、From、IntMsgID、To 和 Attach 属性生成的 MD5 哈希值合并重复件。对于电子邮件附件和独立电子文件，根据整个文件的 MD5 哈希值合并重复件。\n\nf. 元数据。以符合 Concordance 要求的加载文件（.dat）形式，提供每份文件的提取元数据。.DAT 文件的第一行必须为标明字段名称的标题行。.DAT 文件必须使用以下 Concordance 默认分隔符：逗号 , ASCII 字符（020）引号 þ ASCII 字符（254）\n\n日期字段应按以下格式提供：mm/dd/yyyy。日期和时间字段必须分为两个独立字段。所需元数据如下：\nCase 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 117 of 439\n\n字段名称　示例数据　说明\n\nFIRSTBATES　EDC0000001　原生文件文件/电子邮件的第一个 Bates 编号\nLASTBATES　EDC0000001　原生文件文件/电子邮件的最后一个 Bates 编号\nLASTBATES 字段应针对单页予以填充\nATTACHRANGE　EDC0000001 - EDC0000015　父文件第一页的 Bates 编号至最后一个附件“子”文件最后一页的 Bates 编号\nBEGATTACH　EDC0000001　附件范围的第一个 Bates 编号\nENDATTACH　EDC0000015　附件范围的最后一个 Bates 编号\nCUSTODIAN　Smith, John　电子邮件：电子邮件所在的邮箱\n原生文件：文件源自其文件的个人或部门名称\nFROM　John Smith　电子邮件：发件人\n原生文件：文件作者\n多个条目之间应使用分号分隔\nTO　Coffman, Janice; LeeW [mailto:LeeW@MSN.com]　收件人\n多个条目之间应使用分号分隔\nCC　Frank Thompson [mailto:frank_Thompson@cdt.com]　抄送收件人\n多个条目之间应使用分号分隔\nBCC　John Cain　密送收件人\n多个条目之间应使用分号分隔\nSUBJECT　Board Meeting Minutes　电子邮件：电子邮件主题行；原生文件：文件标题（如有）\nFILE_NAME　BoardMeetingMinutes.docx　原生文件：原始原生文件名称，包括扩展名\nDATE_SENT　10/12/2010　电子邮件：电子邮件发送日期\n原生文件：（空）\nTIME_SENT/TIME_ZONE　07:05 PM GMT　电子邮件：电子邮件发送时间/电子邮件标准化所采用时区\nTIME_ZONE　GMT　在转换期间电子邮件被标准化所采用的时区。\nLINK　EDC0000001.msg　电子邮件或原生文件文件的超链接\n链接文件必须按 FIRSTBATES 编号命名\nFILE_EXTEN　MSG　表示电子邮件或原生文件文件的文件类型扩展名\nAUTHOR　John Smith　电子邮件：（空）\n原生文件：文件作者\nDATE_CREATED　10/10/2010　电子邮件：（空）\n原生文件：文件创建日期\nCase 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 118 of 439\n\nTIME_CREATED　10:25 AM　电子邮件：（空）\n原生文件：文件创建时间\n该数据必须为单独字段，不得与 DATE_CREATED 字段合并\nDATE_MOD　10/12/2010　电子邮件：（空）\n原生文件：文件最后修改日期\nTIME_MOD　07:00 PM　电子邮件：（空）\n原生文件：文件最后修改时间\n该数据必须为单独字段，不得与 DATE_MOD 字段合并\nDATE_ACCESSD　10/12/2010　电子邮件：（空）\n原生文件：文件最后访问日期\nTIME_ACCESSD　07:00 PM　电子邮件：（空）\n原生文件：文件最后访问时间\n该数据必须为单独字段，不得与 DATE_ACCESSD 字段合并\nFILE_SIZE　5,952　原生文件文件/电子邮件的大小，单位为 KB\nPGCOUNT　1　原生文件文件/电子邮件中的页数\nPATH　Email: (empty) Agenda.doc　原生文件文件的存储路径，包括原始文件名。\nINTFILEPATH　Personal Folders\\Deleted Items\\Board Meeting Minutes.msg　电子邮件：电子邮件的原始位置，包括原始文件名。\n原生文件：（空）\nINTMSGID　<000805c2c71b\\$75977050\\$cb8306d1@MSN>　电子邮件：唯一消息 ID；原生文件：（空）\nMD5HASH　d131dd02c5e6eec4693d9a0698aff95c2fcab58712467eab4004583eb8fb7f89　文件的 MD5 哈希值。\nOCRPATH　TEXT/001/EDC0000001.txt　原生文件提取文本的路径\n\n3. 每一项请求均独立适用并应独立解释；除非另有说明，任何一项请求均不限制任何其他请求的范围。\n\n4. 所有文件均应按照日常业务过程中保存的方式提供，或者应整理并标记，以对应于本请求中的类别。\n\n5. 本文所载的每项请求均延及所有文件：(a) 由您持有、保管或控制的文件；或 (b) 由任何代表您行事的人持有、保管或控制的文件，\n\n案件 22-50073 文件 3193 于 05/16/24 提交 于 05/16/24 10:28:21 录入 第 119 页，共 439 页\n\n包括您的律师或其他代表及顾问。每份文件均应完整提供。\n\n6. 如要求您提供一份已不再由您持有、保管或控制的文件，则您的答复必须：(a) 详细说明该文件的性质及其内容；(b) 识别编制或撰写该文件的人员（及，如适用，向其发送该文件的人员）；(c) 识别该文件编制或制作的日期；(d) 说明该文件是否 (i) 遗失或丢失，(ii) 已被销毁，(iii) 已自愿或非自愿地转移给他人，或 (iv) 已以其他方式处置；(e) 说明该等处置的理由，以及围绕该等处置的事实和情形；(f) 识别授权该等处置的人员；(g) 识别该等处置的日期或大致日期；(h) 说明该文件最近一次由您持有、保管或控制的时间；以及 (i) 识别目前持有、保管或控制该文件的人员（如有）。\n\n7. 如要求您提供一份已被销毁的文件，则除前述指示所要求的信息外，您的答复还必须说明：(a) 该文件被销毁的理由；(b) 销毁该文件的人员身份；以及 (c) 指示销毁该文件的人员身份。\n\n8. 如您主张所请求的文件享有特权或属于律师工作成果，则您的答复必须：(a) 说明 (i) 足以支持您关于该文件享有特权之主张的文件描述，(ii) 该文件的标题，(iii) 该文件的日期，(iv) 该文件的作者，(v) 该文件的收件人，(vi) 收到或阅览该文件原件或任何草稿、副本或复制件的每一人员身份，(vii) 该文件本身或该文件中载明或提及的任何信息是否由任何其他人员持有、保管或控制，如是，则说明该等人员的身份，以及说明该信息如何由其取得，\n\n案件 22-50073 文件 3193 于 05/16/24 提交 于 05/16/24 10:28:21 录入 第 120 页，共 439 页\n\n(viii) 据以拒绝提供该文件的特权主张，以及 (ix) 您将依赖以支持该等特权主张的所有情形；以及 (b) 就每一份基于特权主张而被拒绝提供的文件，依照 D. Conn. L. Civ. R. 26(e)，提供一份特权日志，其中载明本指示第 (a) 部分所要求的全部信息。对于文件请求中未提出特权或工作成果主张的任何部分，应完整提供相应文件。\n\n9. 如一份原本应予提供的文件的一部分包含受特权主张约束的信息，则仅应依照上述指示从该文件中删除或遮蔽受该特权主张约束的部分，其余部分应予提供。\n\n10. 该等请求具有持续性。特此指示您：(a) 一旦得知先前答复不完整或不正确，应立即补充或更正任何其后得知不完整或不正确的答复；以及 (b) 提供传票所要求的任何额外文件。\n\n11. 如文件使用英语以外的语言，您应提供该文件。如文件使用英语以外的语言，且存在英文译本，您应同时提供两份文件。\n\n12. 对实体的所有提述均包括其所有关联方。\n\n13. 对个人姓名的所有提述均包括所有其他姓名、别名或昵称。\n\n14. 除非另有明确说明，文件请求所涵盖的期间为自 February 5, 2012 起至文件请求答复到期之日止。\n\nII. 解释规则\n\n15. (a) 任何单数名词的使用应解释为包括复数，反之亦然；以及 (b) 任何时态动词的使用应解释为包括该动词所有其他时态的使用。\n\n16. (a) “和”与“或”应视必要情况作连词性或选择性解释，以使原本可能被解释为超出任何请求范围的所有答复均纳入该请求范围；以及 (b) “每一”与“任何”应视为包括并涵盖“每一个”与“所有”二词。\n\nIII. 定义\n\n经 D. Conn. Bankr. L.R. 2004-1(a) 纳入的 D. Conn. L. Civ. R. 26(c) 所规定的定义及 D. Conn. L. Civ. R. 26(d) 所规定的解释规则，适用于该等文件请求。此外，本文件请求中使用的下列术语具有如下含义：\n\n1. “您”或“您的”或“您本人”是指并包括 CIMN Bank Berhad（CIMB Islamic Bank Berhad），连同其所有关联方、部门、机构、办事处、职能机构、部门、办公室、合伙人、高级职员、董事、代理人、律师、代表、雇员和／或任何代表其行事之人。\n\n案件 22-50073 文件 3193 于 05/16/24 提交 于 05/16/24 10:28:21 录入 第 122 页，共 439 页\n\n2. “债务人”是指 Ho Wan Kwok（郭文贵，亦称 Miles Kwok、Miles Guo、Guo Wengui、Guo Haoyun 或任何其他别名），连同其雇员、代理人、律师、顾问或任何代表其行事之人。\n\n3. “债务人之子”是指 Qiang Guo（郭强，亦称 Mileson Kwok 或任何其他别名），连同其雇员、代理人、律师、顾问或任何代表其行事之人。\n\n4. “债务人之女”是指 Mei Guo（郭美，亦称 Mei Gui 或任何其他别名），连同其雇员、代理人、律师、顾问或任何代表其行事之人。\n\n5. “债务人声称的妻子”是指 Hing Chi Ngok（岳庆芝，亦称 Hing Chi Ng、Yue Qingzhi 或任何其他别名），连同其雇员、代理人、律师、顾问或任何代表其行事之人。\n\n6. “债务人的家属”单独及合称债务人、债务人之子、债务人之女及债务人声称的妻子，以及与债务人有任何其他亲属关系之人。\n\n7. “2004 取证对象”单独及合称债务人、债务人的家属、17 Miles, LLC、5780 Saguaro LLC、Aaron Mitchell、ACA Capital Group Limited、Ace Decade Holdings Limited、AI Group Holdings Inc.、Alfa Global Ventures Limited、Alphonso Global Ventures Limited、Ana C. Izquiedo-Henn、Andrew Childe、Anthony DiBattista、Anton Development Limited、Booming Sail New York LLC、Beile Li、Bingshang Jiao、Bravo Luck Limited、Brent Petro Inc.、Celestial Tide Limited、Chris Lee（亦称 Nan Li、Mei Guo Xiao Li）、China Golden Spring Group (Hong Kong) Ltd.、Crane Advisory Group、Daniel Thomas Podhaskie、Defeng Cao（亦称 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 (CA)、G Fashion、G Fashion Hold Co. A. Limited、G\n\n案件 22-50073 文件 3193 于 05/16/24 提交 于 05/16/24 10:28:21 录入 第 123 页，共 439 页\n\nFashion Hold Co. B. Limited、G Fashion Media Group Inc.、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、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（亦称 Huo Lai）、Haitham Khaled、Hamilton Capital Holdings Inc.、Hamilton Digital Assets Funds SP、Hamilton Investment Management Limited、Hamilton Opportunity Fund SPC、Hamilton PE Funds SP、Holy City Hong Kong Ventures Ltd.、GS Security Solutions Inc.、Alex Hadjcharalambous、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 Currency Clearing Pty. Ltd.、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、Jessica Mastrogiovanni、Jiaming Liu、Jie Zhang、Jovial Century International Limited、Joyord Sportswear Limited、K Legacy Ltd.、Kamel Debeche、Karin Maistrello、Kin Ming Je、Lamp Capital LLC、Lawall & Mitchell, LLC、Leading Shine NY Ltd.、Lexington Property and Staffing, Inc.、Lexington Property and Staffing LLC、Linwan “Irene” Feng、Limarie Reyes、Lihong “Sara” Wei Lafrenz、The Lost Draft LLC、Macaron Limited、Major Lead International Limited、Mary Jiang、MOS Himalaya LLC、Maywind Trading LLC、New York MOS Himalaya LLC、Next\n\n案件 22-50073 文件 3193 于 05/16/24 提交 于 05/16/24 10:28:21 录入 第 124 页，共 439 页\n\nTycoon Investments Limited、Nicholas Savio、Nodal Partners, LLC、Qidong Xia、Oasis Tech Limited、O.S.C. Orbit Service Company, LLC、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、Seven Mission Group LLC、Shih Hsin Yu、Sirius Networking Inc.、Taurus Fund LLC、Taurus Management LLC、US Himalaya Capital Inc.、V.X. Cerda & Associates P.A.、Victor Cerda、Voice of Guo Media, Inc.、Wen Xiao、Wencong Wang、William Je、Kin Ming Je（亦称 Je Kin Ming）、Wise Creation International Limited、Xuebing Wang、Yan Chun Liu、Yinying (Aila) Wang（亦称 Xiao Fei Xiang）、Yongbing Zhang、Yongping Yan、Shan Mu、Yue Zhou、Yumei Hao（亦称 Ru Shui）、Yvette Wang（亦称 Yanping Wang、Yan Ping Wang）、Zhixuan Li、Zhouer “Joe” Wang、NewPeople LLC、Ziba Limited、New Mulberry PTE Ltd、TD Primrose Limited，以及 Shin Hee-Seup（亦称 Hee Seup Shin）。\n\n8. “包括”或其任何变体，是指“包括但不限于”。\n\n9. “和”与“或”是指“和／或”，并应同时作连词性及选择性解释，以最大限度地扩大其范围。\n\n10. “任何”“所有”及“每一”是指“每一个”。\n\n11. “每一”及“每个”是指“每一个”。\n\n12. “第三方”是指您本人以外的个人或实体。\n\n13. “转让”具有《破产法》第 101(54) 条所赋予的含义。\n\n14. “文件”是指属于 Fed. R. Civ. P. 34 范围内的任何信息或物件，并包括但不限于任何种类的每一份书面、记录或图形材料，\n\n案件 22-50073 文件 3193 于 05/16/24 提交 于 05/16/24 10:28:21 录入 第 125 页，共 439 页\n\n类型、性质或描述的文件，且该等文件现由或曾由您占有、保管或控制，包括所有电子邮件、以电子形式保存的计算机文件、通信函件、备忘录、磁带、速记或手写笔记、任何种类的书面表格、图表、蓝图、绘图、草图、图形、计划、文章、规格说明、日记、信函、电报、照片、会议记录、合同、协议、调查资料、计算机打印件、任何种类的数据汇编、电传、传真、电子邮件、短信、即时消息、语音留言、发票、订单表格、支票、汇票、结单、贷项通知单、报告、持仓报告、摘要、索引、书籍、总账、笔记本、清单、透明胶片、录音、目录、广告、宣传材料、影片、录像带、录音带、CD、计算机磁盘、小册子、宣传册、穿孔卡、工时单、推文、社交媒体帖子或任何其他种类的书面或记录材料的所有印刷及电子副本，以及其所有元数据，无论以何种方式存储（无论为有形形式或电子形式）、记录、制作或复制；还包括但不限于前述任何文件的草稿或副本，如其包含原始文件中未见的任何种类的笔记、评论或标记，或在其他方面与原始文件不相同。\n\n15. “人员”是指个人、公司、独资企业、合伙企业、协会或任何其他实体。“人员”还包括任何代理人、代表或专家，包括但不限于律师或财务顾问。\n\n16. “实体”是指任何自然人、公司、合伙企业、子公司、独资企业、商号、董事会、合资企业、协会、机构、主管机关、委员会或其他商业实体或法人，以及任何关联方、代理人、母公司，包括但不限于法律顾问、财务顾问或任何其他代表。\n案件 22-50073 文件 3193 提交日期 05/16/24 录入日期 05/16/24 10:28:21 第 126 页，共 439 页\n\n17. “关于”是指涉及、描述、包含、提及、与之有关、支持、赞成、反对、强化、削弱、位于、结合考虑、与之相关、证明、表明、报告、记录、暗示、回应、与之相连、评论、就其而言、关于、与之相关、讨论、显示、描述、反映、分析、构成以及属于。\n\n18. 当提及任何特定事项时，“有关”“涉及”或“相关”是指，包括但不限于，构成、包含、涉及、载有、体现、反映、识别、陈述、直接或间接提及，或以任何方式与所识别的特定事项相关的任何文件。\n\n19. “通信”在最广泛的意义上且不受限制地，是指任何信息或知识的传递（以事实、想法、询问或其他形式）。通信还指所有谈话、协议、询问或答复，无论是当面、通过电话、以书面形式，还是通过电子传输设备进行，并包括但不限于所有函件、电子邮件、录音、传送单、备忘录、电话通信、语音留言、电报、电子传真、传真副本、电传、即时消息、聊天、短信、在留言板或群聊中发布的内容、社交媒体帖子、推文、上传至任何视频平台的视频、电话笔记，或在内部或与第三方之间传送的笔记。\n\n20. “资产”是指受占有、保管或控制的任何具有经济价值的项目。资产包括所有不动产和动产，包括但不限于房地产、土地、房屋、公寓、共管公寓、汽车、游艇、船舶、飞机、喷气式飞机、直升机、现金、银行账户、加密货币、证券、应收账款、存货及其他有形和无形财产。\n\n四、应提交的文件\n\n1. 与任何由 2004 取证对象持有、控制、代表其持有，或以其他方式与其相关的账户有关的所有文件，包括任何及所有账户结单、授权书、授权委托书、信托文件、指示或表格、已注销支票副本、通信函件，以及电汇及相关通信函件和指示。\n\n2. 与任何属于 2004 取证对象、由其持有、控制、代表其持有，或以其他方式与其相关的资金、证券、财产或资产有关的所有文件，包括任何及所有账户结单、授权书、授权委托书、信托文件、指示或表格、已注销支票副本、通信函件，以及电汇及相关通信函件和指示。\n\n3. 与同任何 2004 取证对象进行的任何商业、贸易或金融交易有关的所有文件，包括但不限于任何贷款、信贷额度、寄托、存款、掉期、证券交易、抵押贷款或 ISDA，包括任何及所有账户结单、授权书、授权委托书、信托文件、指示或表格、已注销支票副本、通信函件，以及电汇及相关通信函件和指示。\n\n4. 与涉及 2004 取证对象的任何电汇活动有关的所有文件，不论是否存在任何账户，包括但不限于所有电汇收据、账号、余额、授权书、与转账当事人有关的身份识别信息、通信函件、指示或其他记录。\n\n5. 与您和 2004 取证对象之间的任何函件和通信有关的所有文件。\n\n6. 与任何 2004 取证对象的任何账户有关的所有文件，涉及账户开立、账户获授权使用人及账户维护。\n案件 22-50073 文件 3193 提交日期 05/16/24 录入日期 05/16/24 10:28:21 第 128 页，共 439 页\n\n7. 与任何涉及任何 2004 取证对象的反洗钱、了解你的客户或其他合规活动有关的所有文件，包括但不限于由任何 2004 取证对象提供或由您获知的任何信息。\n\n8. 与来自任何国家的任何监管机构进行的任何通信有关的所有文件，包括但不限于英格兰银行（Bank of England）、美国联邦储备系统（United States Federal Reserve）、美国证券交易委员会（S.E.C.）、美国商品期货交易委员会（CFTC）、美国金融业监管局（FINRA）、中国证券监督管理委员会（China Securities Regulatory Commission）、中国人民银行（People's Bank of China）、香港证券及期货事务监察委员会（Hong Kong Securities and Futures Commission）及香港金融管理局（Hong Kong Monetary Authority），涉及任何 2004 取证对象。\n\n案件 22-50073 文件 3193 提交日期 05/16/24 录入日期 05/16/24 10:28:21 第 129 页，共 439 页\n附件 C-7\nB2540（表格 2540——规则 2004 审查传票）（12/15）案件 22-50073 文件 3193 提交日期 05/16/24 录入日期 05/16/24 10:28:21 第 130 页，共\n\n美国破产法院（UNITED STATES BANKRUPTCY COURT）\n\n康涅狄格地区（District of Connecticut）\n\n关于 HO WAN KWOK（郭文贵）等人，\n\n1 案件编号 22-50073 (JAM) 债务人 第 11 章\n\n（合并管理）\n规则 2004 审查传票\n\n致：Evan Cramer（埃文·克莱默）\n\n（传票所指向人员的姓名）\n\n证言：现命令您于下列规定的时间、日期和地点出席，以根据《联邦破产程序规则》第 2004 条接受审查并作证。随附授权该审查的法院命令副本。\n\n地点　日期和时间\n\n不适用　不适用\n\n审查将通过以下方式记录：不适用\n\n提交材料：您或您的代表还必须携带下列文件、电子存储信息或物品前往审查，并必须允许对该等材料进行检查、复制、测试或抽样：\n见随附的文件提交请求。\n\n《联邦民事诉讼规则》第 45 条下列规定，经《联邦破产程序规则》第 9016 条适用于破产案件，随附于此——第 45(c) 条，关于履行地点；第 45(d) 条，关于您作为受传票约束人员所受的保护；以及第 45(e) 条和第 45(g) 条，关于您对本传票作出回应的义务以及未作出回应的潜在后果。\n\n日期：May , 2024\n\n法院书记员\n\n或\n\n书记员或副书记员签名　律师签名\n\n代表发出或请求本传票的第 11 章受托人 Luc A. Despins（卢克·A·德斯平斯）的律师姓名、地址、电子邮件地址和电话号码如下：\n\nPatrick R. Linsey, Esq.（帕特里克·R·林赛，律师）；Neubert, Pepe & Monteith, P.C.；195 Church Street, 13th Floor, New Haven, Connecticut 06510；plinsey@npmlaw.com；(203) 781-2847\n\n向发出或请求本传票的人员发出的通知\n\n如本传票命令在审判前提交文件、电子存储信息或有形物品，或检查场所，则必须在向传票所指向人员送达之前，向各方当事人送达通知及本传票副本。《联邦民事诉讼规则》第 45(a)(4) 条。\n\n软件版权 (c) 1996-2022 Best Case, LLC - www.bestcase.com Best Case Bankruptcy 1 本第 11 章案件中的债务人为 Ho Wan Kwok（郭文贵）（亦称 Guo Wengui、Miles Guo 和 Miles Kwok，以及众多其他别名）（税务识别号码末四位：9595）、Genever Holdings LLC（税务识别号码末四位：8202）及 Genever Holdings Corporation。受托人、Genever Holdings LLC 和 Genever Holdings Corporation 的邮寄地址为 Paul Hastings LLP, 200 Park Avenue, New York, NY 10166，收件人为作为 Ho Wan Kwok 财产受托人的 Luc A. Despins（仅为通知和通信之目的）。\n\n送达证明\n\n（除非《联邦民事诉讼规则》第 45 条要求，否则本节不应向法院提交。）\n\n本人于（日期）收到向（个人姓名及职务，如有）发出的本传票。\n\n本人按以下方式，通过向具名人员交付副本送达本传票：\n\n于（日期）；或\n\n本人退回未执行的传票，原因如下：\n\n除非该传票代表美国或其官员或代理人发出，本人还已向证人支付一天出席费用及法律允许的里程费，金额为 \\$ 。\n\n本人的差旅费为 \\$ ，服务费为 \\$ ，合计 \\$ 。\n\n本人在伪证处罚的约束下声明，该信息真实且正确。\n\n日期：\n\n送达人签名\n\n正楷姓名及职务\n\n送达人地址\n\n关于尝试送达等的补充信息：\n\n《联邦民事诉讼规则》第 45(c)、(d)、(e) 和 (g) 条（自 12/1/13 生效）（经《联邦破产程序规则》第 9016 条适用于破产案件）\n\n(c) 履行地点。\n\n(1) 审判、听证或证言录取。传票仅可按如下方式命令人员出席审判、听证或证言录取：\n\n(A) 在该人员居住、受雇或经常亲自从事营业活动地点 100 英里范围内；或\n\n(B) 在该人员居住、受雇或经常亲自从事营业活动所在州内，如该人员\n\n(i) 是当事人或当事人的高级职员；或\n\n(ii) 被命令出席审判且不会产生重大费用。\n\n(2) 其他取证。传票可命令：\n\n(A) 在该人员居住、受雇或经常亲自从事营业活动地点 100 英里范围内的地点提交文件、电子存储信息或物品；以及\n\n(B) 在被检查的场所检查场所。\n\n(d) 对受传票约束人员的保护；执行。\n\n(1) 避免不当负担或费用；制裁。负责发出和送达传票的当事人或律师必须采取合理措施，避免对受传票约束人员施加不当负担或费用。要求履行的地区法院必须执行该义务，并对未遵守该义务的当事人或律师施加适当制裁，该制裁可包括损失的收入和合理的律师费。\n\n(2) 命令提交材料或允许检查。\n\n(A) 无需出席。被命令提交文件、电子存储信息或有形物品，或者允许检查场所的人，无需亲自到提交或检查地点出席，除非其还被命令为作证、听证或审判而出席。\n\n(B) 异议。被命令提交文件或有形物品，或者允许检查的人，可以向传票中指定的当事人或律师送达书面异议，反对检查、复制、测试或抽样全部或部分材料，或反对检查场所——或者反对以所要求的一种或多种形式提交电子存储信息。异议必须在规定的履行时间之前或传票送达后14天内（以较早者为准）送达。如提出异议，适用下列规则：\n\n(i) 在任何时候，送达方在通知被命令人的情况下，可向要求履行的地区的法院提出动议，请求作出强制提交或检查的命令。\n\n(ii) 此类行为仅可按照命令的指示被要求进行，并且该命令必须保护非当事人且非当事人高级职员的人免于因履行而产生的重大费用。\n\n(3) 撤销或修改传票。\n\n(A) 必须撤销或修改的情形。经及时动议，要求履行的地区的法院必须撤销或修改具有下列情形的传票：\n\n(i) 未给予合理的履行时间；\n\n(ii) 要求人在第45(c)条规定的地理范围之外履行；\n\n(iii) 要求披露享有特权或以其他方式受保护的事项，且不存在任何例外或豁免；或\n\n(iv) 使人承受不当负担。\n\n(B) 可以撤销或修改的情形。为保护受传票约束或受其影响的人，要求履行的地区的法院可经动议撤销或修改要求下列事项的传票：\n\n(i) 披露商业秘密或其他机密研究、开发或商业信息；或\n\n(ii) 披露未受聘专家的意见或信息，该等意见或信息并未描述争议中的具体事件，且源于未经当事人请求的该专家研究。\n\n(C) 作为替代方案规定条件。在第45(d)(3)(B)条所述情形下，如送达方：\n\n(i) 证明其对该证言或材料具有实质性需求，且若无不当困难即无法以其他方式满足该需求；并且\n\n(ii) 确保被传唤人将获得合理补偿，\n\n法院可不撤销或修改传票，而是命令在规定条件下出席或提交。\n\n(e) 对传票作出回应时的义务。\n\n(1) 提交文件或电子存储信息。下列程序适用于提交文件或电子存储信息：\n\n(A) 文件。回应提交文件传票的人必须按该等文件在正常业务过程中保存的方式提交，或者必须将其整理并标记，以对应请求中的类别。\n\n(B) 未指定电子存储信息提交形式。如传票未指定电子存储信息的提交形式，回应人必须以其通常保存的一种或多种形式，或者以一种或多种合理可用的形式提交。\n\n(C) 电子存储信息仅以一种形式提交。回应人无需以一种以上的形式提交相同的电子存储信息。\n\n(D) 不可合理访问的电子存储信息。回应人无需就其认定因不当负担或费用而不可合理访问的来源中的电子存储信息提供证据开示。就强制证据开示或保护令提出动议时，回应人必须证明该信息因不当负担或费用而不可合理访问。如作出该证明，法院仍可在请求方证明具有正当理由时，命令从该等来源进行证据开示，并考虑第26(b)(2)(C)条的限制。法院可为该证据开示规定条件。\n\n(2) 主张特权或保护。\n\n(A) 被扣留的信息。基于该信息享有特权或作为审判准备材料受到保护的主张而扣留被传唤信息的人，必须：(i) 明确提出该主张；并且\n\n(ii) 以一种方式描述被扣留文件、通信或有形物品的性质，使当事人能够评估该主张，同时不披露本身享有特权或受保护的信息。\n\n(B) 已提交的信息。如为回应传票而提交的信息受到特权主张或作为审判准备材料受到保护的主张，提出该主张的人可将该主张及其依据通知收到该信息的任何当事人。收到通知后，当事人必须立即返还、隔离或销毁所指明的信息及其持有的任何副本；在该主张得到解决前不得使用或披露该信息；如该当事人在收到通知前已披露该信息，必须采取合理措施追回该信息；并可立即将该信息密封提交至要求履行的地区的法院，以裁定该主张。提交该信息的人必须保留该信息，直至该主张得到解决。\n\n(g) 藐视法庭。要求履行的地区的法院——以及在动议被移送后，签发法院——可对已被送达但无充分理由未遵守传票或与其相关命令的人认定构成藐视法庭。\n\n有关传票材料的查阅，请参见 Fed.R.Civ.P.45(a) Committee Note (2013)\n\n……\n\n文件提交请求\n\nI. 指示\n\n1. 除非另有说明，下列文件请求（以下简称“请求”，单称为“一项请求”）必须分别且具体地作出回应。除非善意提出异议，否则每项请求均应得到完整答复；如提出异议，应按下文规定详细说明贵方异议的理由。如异议仅涉及一项请求的一部分，或其中包含的一个词语、短语或条款，贵方仅须说明对该部分的异议，并对其余请求作出回应。\n\n2. 电子存储信息必须按照下列指示提交：\n\na. 图像。黑白图像必须为300 DPI Group IV 单页 TIFF 文件。彩色图像必须以 JPEG 格式提交。文件名不得含有嵌入空格或特殊字符（包括逗号）。文件夹名称不得含有嵌入空格或特殊字符（包括逗号）。所有 TIFF 图像文件必须具有唯一的文件名，即 Bates 编号。图像必须在每幅图像的右下角标注连续的 Bates 编号。每个文件夹中的 TIFF 文件数量不应超过1000个文件。Excel 电子表格应具有以该文件的 Bates 编号命名的占位图像。\n\nb. 图像加载文件\n\na. Concordance® 数据文件。数据文件（.DAT）包含将被加载到 Concordance® 数据库的全部字段化信息。.DAT 文件的第一行必须为标识字段名称的标题行。.DAT 文件必须使用下列 Concordance® 默认分隔符：逗号 ASCII 字符（020）引号 þ ASCII 字符（254）。日期字段应采用以下格式提供：mm/dd/yyyy。日期和时间字段必须为两个单独字段。如文件包括已制成图像的电子邮件及附件，则必须包括附件字段，以保留电子邮件与其附件之间的父子关系。必须包括 OCRPATH 字段，以提供已提交存储介质上提取文本文件的文件路径及名称。文本文件必须以 FIRSTBATES 命名。不得在 .DAT 文件中包括文本。对于含有原生文件的文件，必须包括 LINK 字段，以提供原生文件的文件路径及名称。原生文件必须以 FIRSTBATES 命名。\n\nb. Concordance Image® 或 Opticon 交叉引用文件。图像交叉引用文件（.LOG 或 .OPT）将图像与数据库记录关联。其应为以逗号分隔的文件，每行由七个字段组成，且数据库中的每幅图像均应在交叉引用文件中有一行，格式如下：ImageID,VolumeLabel,ImageFilePath,DocumentBreak,FolderBreak,Box Break,PageCoun。\n\nc. 文件文本。文本必须作为单独的文本文件提交，而非作为 .DAT 文件内的字段。文本文件的完整路径（OCRPATH）应包括在 .DAT 文件中。建议使用以 FIRSTBATES/Image Key 命名的文件级 ANSI 文本文件。提取的文本文件必须置于单独的文件夹中，每个文件夹中的文本文件数量不应超过1,000个文件。文件夹名称中不得有特殊字符（包括逗号）。文本文件必须按文件级别提供。\n\nd. 特定文件类型的原生格式提交。为充分理解其内容和含义而合理需要以原生格式查看的文件类型，必须以原生格式提交。该等文件包括但不限于电子表格、类电子表格文件（Microsoft Excel、逗号分隔值、制表符分隔值等）、Microsoft PowerPoint 或其他特殊演示文件、数据库文件以及音频/视频文件。提供一张带有 Bates 编号的分隔页图像，注明存在原生文件，并在 .dat 文件中将原生文件的路径作为一个字段包括在内。以与该文件分隔页相对应的 Bates 编号命名所提交的原生文件。将原生文件按递增命名的“NATIVE”目录分组，并与图像目录分开。\n\ne. 去重。对于存在完全重复件的每份电子文件，提交一份副本。对于电子邮件，应根据由 BCC、Body、CC、From、IntMsgID、To 和 Attach 属性生成的 MD5 哈希值合并重复件。对于电子邮件附件和独立电子文件，应根据整个文件的 MD5 哈希值合并重复件。\n\nf. 元数据。以符合 Concordance 要求的加载文件（.dat）形式提交每份文件的提取元数据。.DAT 文件的第一行必须为标识字段名称的标题行。.DAT 文件必须使用下列 Concordance 默认分隔符：逗号 , ASCII 字符（020）引号 þ ASCII 字符（254）\n\n日期字段应采用以下格式提供：mm/dd/yyyy。日期和时间字段必须为两个单独字段。下列为所需元数据：\n\n案件 22-50073 文书 3193 提交 05/16/24 录入 05/16/24 10:28:21 第 135 页，共 439 页\n\n字段名称　示例数据　说明\n\nFIRSTBATES　EDC0000001　原生文件文件/电子邮件的首个 Bates 编号\nLASTBATES　EDC0000001　原生文件文件/电子邮件的最后一个 Bates 编号\nLASTBATES 字段应予填写\n适用于单页文件\nATTACHRANGE　EDC0000001\n-　母文件首页的 Bates 编号至\nEDC0000015　最后一份附件“子”文件最后一页的 Bates 编号\nBEGATTACH　EDC0000001　附件范围的首个 Bates 编号\nENDATTACH　EDC0000015　附件范围的最后一个 Bates 编号\nCUSTODIAN　Smith, John　电子邮件：该电子邮件所在的邮箱\n原生文件：文件来源个人或部门的名称\nFROM　John Smith　电子邮件：发件人\n原生文件：文件作者\n多个条目应使用分号分隔\nTO　Coffman, Janice; LeeW　收件人\n[mailto:LeeW@MSN.com]　多个条目应使用分号分隔\nCC　Frank Thompson [mailto:　抄送收件人\nfrank_Thompson@cdt.com]　多个条目应使用分号分隔\nBCC　John Cain　密送收件人\n多个条目应使用分号分隔\nSUBJECT　Board Meeting Minutes　电子邮件：电子邮件主题行；原生文件：文件标题\n（如有）\nFILE_NAME　BoardMeetingMinutes.docx　原生文件：原始原生文件的名称，\n包括扩展名\nDATE_SENT　10/12/2010　电子邮件：电子邮件发送日期\n原生文件：（空）\nTIME_SENT/　07:05 PM GMT　电子邮件：电子邮件发送时间/电子邮件\nTIME_ZONE　标准化时所采用的时区\nTIME_ZONE　GMT　电子邮件在转换期间\n进行标准化所采用的\n时区。\nLINK　EDC0000001.msg　电子邮件或原生文件文件的超链接\n链接文件必须按\nFIRSTBATES 编号命名\nFILE_EXTEN　MSG　代表电子邮件或\n原生文件的文件类型\n扩展名\nAUTHOR　John Smith　电子邮件：（空）\n原生文件：文件作者\nDATE_CREATED　10/10/2010　电子邮件：（空）\n原生文件：文件创建日期\nCase 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 136 of 439\n\nTIME_CREATED　10:25 AM　电子邮件：（空）\n\n原生文件：文件创建时间\n该数据必须为单独字段，不得\n与 DATE_CREATED 字段合并\nDATE_MOD　10/12/2010　电子邮件：（空）\n原生文件：文件最后修改日期\nTIME_MOD　07:00 PM　电子邮件：（空）\n原生文件：文件最后修改时间\n该数据必须为单独字段，不得\n与 DATE_MOD 字段合并\nDATE_ACCESSD　10/12/2010　电子邮件：（空）\n原生文件：文件最后访问日期\nTIME_ACCESSD　07:00 PM　电子邮件：（空）\n原生文件：文件最后访问时间\n该数据必须为单独字段，不得\n与 DATE_ACCESSD 字段合并\nFILE_SIZE　5,952　原生文件文件/电子邮件的大小，单位为 KB\nPGCOUNT　1　原生文件文件/电子邮件的页数\nPATH　电子邮件：（空）\nAgenda.doc　原生文件：存储原生文件文件的路径，\n包括原始文件名。\nINTFILEPATH　Personal Folders\\Deleted　电子邮件：电子邮件的原始位置，包括\nItems\\Board Meeting　原始文件名。\nMinutes.msg　原生文件：（空）\nINTMSGID　<000805c2c71b\\$75977050\\$　电子邮件：唯一邮件 ID；原生文件：（空）\ncb8306d1@MSN>\nMD5HASH　d131dd02c5e6eec4693d9a0　文件的 MD5 哈希值。\n698aff95c\n2fcab58712467eab4004583e\nb8fb7f89\nOCRPATH　TEXT/001/EDC0000001.txt　原生文件提取文本的路径\n\n3. 每项请求独立适用并应独立解释，除非另有说明，任何请求均不限制任何其他请求的范围。\n\n4. 所有文件应按其在日常业务过程中保存的方式提供，或者应予组织和标注以对应于本请求中的类别。\n\n5. 本文所载每项请求均延及所有文件：(a) 由您占有、保管或控制的文件；或 (b) 由任何代表您行事之人占有、保管或控制的文件，\nCase 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 137 of 439\n\n包括您的律师或其他代表及顾问。每份文件均应完整提供。\n\n6. 如要求您提供一份已不再由您占有、保管或控制的文件，则您的答复必须：(a) 详细描述该文件的性质及其内容；(b) 指明编制或撰写该文件的人（以及，如适用，向其发送该文件的人）；(c) 指明该文件编制或创建的日期；(d) 说明该文件是否 (i) 缺失或遗失，(ii) 已被销毁，(iii) 已自愿或非自愿地转移给他人，或 (iv) 以其他方式被处置；(e) 说明该等处置的理由以及围绕该等处置的事实和情形；(f) 指明授权该等处置的人；(g) 指明该等处置的日期或大致日期；(h) 说明该文件最近一次由您占有、保管或控制的时间；以及 (i) 指明目前占有、保管或控制该文件的人（如有）。\n\n7. 如要求您提供一份已被销毁的文件，则除前述指示所要求的信息外，您的答复还必须说明：(a) 销毁该文件的理由；(b) 销毁该文件之人的身份；以及 (c) 指示销毁该文件之人的身份。\n\n8. 如您主张所请求的文件享有特权或属于律师工作成果，则您的答复必须：(a) 说明 (i) 足以支持您关于该文件享有特权之主张的文件描述，(ii) 文件标题，(iii) 文件日期，(iv) 文件作者，(v) 文件收件人，(vi) 收到或阅览原件或任何草稿、副本或复制件的每一人的身份，(vii) 该文件本身或其中所含或提及的任何信息是否由任何其他人占有、保管或控制；如是，则说明该等人员的身份，\nCase 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 138 of 439\n\n以及说明该等信息如何进入其占有；(viii) 据以扣留该文件的特权主张；以及 (ix) 您将据以支持该等特权主张的所有情形；并且 (b) 根据 D. Conn. L. Civ. R. 26(e)，就每一份基于特权主张而被扣留的文件，提供一份特权清单，载明本指示第 (a) 部分所要求的全部信息。\n\n9. 如一份本应提供的文件的一部分含有受特权主张约束的信息，则仅应按照上述指示从该文件中删除或遮盖受该特权主张约束的部分，其余部分应予提供。\n\n10. 本请求具有持续性。现指示您：(a) 在得知先前答复不完整或不正确后，立即补充或更正任何后来得知不完整或不正确的答复；以及 (b) 提供本请求所要求的任何补充文件。\n\n11. 如文件使用英语以外的语言，您应提供该文件。如文件使用英语以外的语言，且存在英文译本，您应同时提供两份文件。\n\n12. 对实体的所有提及均包括其所有关联方。\n\n13. 对个人姓名的所有提及均包括所有其他姓名、别名或昵称。\n\n14. 除非另有明确说明，文件请求所涵盖的期间为自 February 5, 2012 起至文件请求答复到期之日止。\nII. 解释规则\n\n15. (a) 任何单数名词的使用应解释为包括复数，反之亦然；以及 (b) 任何时态动词的使用应解释为包括该动词所有其他时态的使用。\n\n16. (a) “和”及“或”应视必要解释为连词或选择连词，以使任何请求的范围包括否则可能被解释为不在其范围内的所有答复；以及 (b) “每一”及“任何”应视为包括并涵盖“每一个”及“所有”。\nIII. 定义\n\n经 D. Conn. Bankr. L.R. 2004-1(a) 纳入的 D. Conn. L. Civ. R. 26(c) 所提供的定义及 D. Conn. L. Civ. R. 26(d) 所提供的解释规则，适用于文件请求。此外，本文件请求中使用的下列术语具有如下含义：\n\n1. “您”或“您的”或“您本人”系指 Evan Cramer（埃文·克雷默），连同其所有代理人、律师、代表、雇员和/或任何代表其行事之人。\n\n2. “债务人”系指 Ho Wan Kwok（郭文贵）（又名 Miles Kwok、Miles Guo、Guo Wengui、Guo Haoyun、郭文贵或任何其他别名），连同其雇员、代理人、律师、顾问或任何代表其行事之人。\n\n3. “债务人之子”系指 Qiang Guo（郭强）（又名 Mileson Kwok、郭强或任何其他别名），连同其雇员、代理人、律师、顾问或任何代表其行事之人。\n\n4. “债务人之女”系指 Mei Guo（郭美）（又名 Mei Gui、郭美或任何其他别名），连同其雇员、代理人、律师、顾问或任何代表其行事之人。\nCase 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 140 of 439\n\n5. “债务人所谓的妻子”系指 Hing Chi Ngok（岳庆芝）（又名 Hing Chi Ng、Yue Qingzhi、岳庆芝或任何其他别名），连同其雇员、代理人、律师、顾问或任何代表其行事之人。\n\n6. “债务人家庭成员”系指债务人、债务人之子、债务人之女及债务人所谓的妻子，以及与债务人有任何其他亲属关系之人，统称。\n\n7. “关联个人”单独及共同系指：(1) 持有、控制、保管或对债务人或债务人家庭成员所拥有、控制或享有的资产拥有处置权的所有个人；或 (2) 曾为一间或多间关联实体的雇员、董事，或以其他方式与其有关联的所有个人，连同前述各人的雇员、代理人、律师、顾问或任何代表前述任何一方行事之人。该等关联个人包括但不限于：Anthony DiBattista（安东尼·迪巴蒂斯塔）、Alex Hadjicharalambous（亚历克斯·哈吉查拉兰布斯）、Bernardo Enriquez（贝尔纳多·恩里克斯）、Bingshang Jiao（焦冰上）、Beile Li（李贝乐）、Brian W. Hofmeister（布莱恩·W·霍夫迈斯特）、Charles Gruder（查尔斯·格鲁德）、Daniel Podhaskie（丹尼尔·波德哈斯基）、David Fallon（大卫·法伦）、Defeng Cao（曹德峰）（又名 Wayne Cao、Max Cao）、Ding Lin（丁林）、Dinggang Wang（王定刚）（又名 王定刚）、Eduardo Eurnekian（爱德华多·厄尔内基安）、Ehsan Masud（埃桑·马苏德）、Fiona Yu（俞菲奥娜）、Gladys Chow（周格拉迪斯）、Hao (Gavin) Li（李昊〔加文〕）（又名 Huo Lai）、Hao Haidong（郝海东）（又名 郝海东）、Han Chunguang（韩春光）（又名 韩春光）、Haoran He（何浩然）、Ivan Lin（林艾文）、Haitham Khaled（海瑟姆·哈立德）、Jason Miller（杰森·米勒）、Jennifer Mercurio（詹妮弗·梅尔库里奥）、Jesse Brown（杰西·布朗）、Jessica Mastrogiovanni（杰西卡·马斯特罗焦瓦尼）、Jie Zhang（张杰）、Jintao Li（李金涛）、Karin Maistrello（卡琳·迈斯特雷洛）、Kyle Bass（凯尔·巴斯）、Lihong Wei Lafrenz（魏丽红·拉弗伦茨）（又名 Sara Wei、魏丽红）、Linwan “Irene” Feng（冯林婉〔艾琳〕）、Max Krasner（马克斯·克拉斯纳）、Melissa Francis（梅利莎·弗朗西斯）、Michael Baranowitz（迈克尔·巴拉诺维茨）、Min Yang（杨敏）、Melissa Mendez（梅利莎·门德斯）、Nadeem Akbar（纳迪姆·阿克巴尔）、Nan Li（李楠）（又名 Chris Lee、Mei Guo Xiao Li）、Qidong Xia（夏启东）、Qu Guojiao（屈国姣）（又名 Qu Guo Jiao、屈国姣）、Ridwan Mamode Saib（里德万·马莫德·赛义卜）、Ross Heinemeyer（罗斯·海内迈耶）、Rui “Ray” Hao（郝睿〔雷〕）、Scott Barnett（斯科特·巴尼特）、Shih Hsin Yu（俞世新）、Shin Hee-Seup（申熙燮）（又名 Hee Seup Shin）、Steve Bannon（史蒂夫·班农）、Talha Zobair（塔尔哈·佐拜尔）、Victor Cerda（维克托·塞尔达）、Wen Xiao（肖文）、Wencong Wang（王文聪）、William Gertz（威廉·格茨）、William Je（余建明）（又名 Je Kin Ming、Yu Jianming、余建明）及 Xuebing Wang（王雪冰），\nCase 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 141 of 439\n\nYa Li（李娅）（又名 李娅）、Yinying (Aila) Wang（王茵莺〔艾拉〕）（又名 Xiao Fei Xiang）、Yongping Yan（Shan Mu）（闫永平〔山木〕）、Yong Yu（俞勇）、Yue Zhou（周跃）、Yumei Hao（郝玉梅）（又名 Ru Shui）、Yvette Wang（王雁平）（又名 Yanping Wang、Yan Ping Wang、王雁平）、Zhang Wei（张魏）（又名 张魏）、Zhouer Wang（王周儿）（又名 Joe Wang）、Zhixuan Li（李致轩）及 Ziyang Liu（刘子阳）。\n\n8. “关联实体”系指，单独及合计而言，所有符合下列条件的任何类型组织或实体：(1) 曾由债务人或债务人家庭成员拥有、控制或投资；或 (2) 对债务人或债务人家庭成员拥有、控制或享有的任何资产直接或间接享有权益，以及前述各方各自的雇员、代理人、法律顾问、顾问或代表前述任何一方行事的任何人。该等关联实体包括但不限于：1332156 B.C. Ltd.、7 Nod Hill LLC、AAGV Limited、ACA Investment Management Limited、ACA Capital Group Limited、Ace Decade Holdings Limited、AI Group Holdings Inc.、Alfa Global Ventures Limited、Alfonso Global Limited、Allied Capital Global Limited、Alpine Fiduciaries SA、Beijing Pangu Investment Co.、Beijing Pangu Investment Co. Ltd.、Beijing Pangu Investment Inc.、Beijing Zenith Holdings Company Limited、Blue Capital Limited、Booming Sail New York LLC、Bravo Luck Limited、Brent Petro、BSA Strategic Fund I、China Golden Spring (Hong Kong) Limited、Chuang Xin Limited、Crane Advisory Group LLC、Creative Apex Investments Limited、Crystal Breeze Investments Limited、Dawn State Limited、Eastern Profit Corporation Limited、Empire Growth Holdings、Elite Well Global Limited、Freedom Media Ventures Ltd.、Fung Wan Trading Inc.、G Club、G Club Operations LLC、G Club International Limited、G Club Investments Limited、G Fashion LLC、G-News Operations LLC、G News LLC、GMusic Inc.、G-Services LLC、G-Translators PTY LTD、GETTR USA, Inc.、Genever Holdings Corporation、Genever Holdings LLC、GFashion Media Group Inc.、GFNY, Inc.、Globalist International Limited、GNews Media Group Inc.、Golden Spring (New York) Ltd.、Guo Media、GTV Media Group, Inc.、GWGOPNZ\n\n案件 22-50073，文书 3193，提交日期 05/16/24，录入日期 05/16/24 10:28:21，第 142 页，共 439 页\n\nLimited、GWGNZ Limited、Gypsy Mei Food Services, LLC、HCHK Property Management Inc.、HCHK Technologies Inc.、Hamilton Digital Assets FD SP、Hamilton Capital Holdings Inc.、Hamilton Opportunity Fund SPC、Head Win Group Limited、Himalaya Embassy、Himalaya Exchange、Himalaya Federal Reserve、Himalaya International Financial Group Ltd.、Himalaya Investment LLC、Himalaya (USA) Investment Management LLC、Himalaya New World Inc.、Himalaya Supervisory Organization、Himalaya Ventures、Holy City Hong Kong Ventures, Ltd.、Hudson Diamond Holding LLC、Hudson Diamond Holding Inc.、Hudson Diamond NY LLC、HK International Funds Investments (USA) Limited LLC、Hong Kong International Funds Investments Limited、Huk Trading Inc、Infinite Increase Limited、Infinitum Developments Limited、Japan Himalaya League, Inc.、Kalixun Trading Limited、Lamp Capital LLC、Leading Shine Limited、Leading Shine NY Limited、Lexington Property and Staffing Inc.、Long Gate Limited、MOS Himalaya Foundation Inc.、Maywind Trading LLC、New Federal State of China (a/k/a NFSC)、New York MOS Himalaya LLC、New Mulberry PTE Ltd.、Newpeople LLC、Noble Fame Global Limited、Pixshow Film Inc.、Roscalitar 2、Rosy Acme Ventures Limited、Rule of Law Foundation III, Inc.、Rule of Law Society、Rule of Law Society IV, Inc.、Santel LLC、Saraca Media Group, Inc.、Shiny Ace Ltd.、Shiny Times Holdings Ltd.、Stevenson, Wong & Co.、Taurus Fund LLC、Taurus Fund SP、Taurus Management LLC、The Lost Draft LLC、TM Primrose Limited、UA Himalaya Inc.、Voice of Guo Media, Inc.、Well Origin Ltd.、Wise Creation、Whitecroft Shore Limited、World Century Limited、Worldwide Opportunity Holdings Limited 及 ZIBA Limited。\n\n9. “包括”或其任何变体，系指“包括但不限于”。\n\n10. “和”及“或”系指“和/或”，并应同时按连词及选择连词解释，以最大限度扩大其范围。\n\n案件 22-50073，文书 3193，提交日期 05/16/24，录入日期 05/16/24 10:28:21，第 143 页，共 439 页\n\n11. “任何”和“所有”及“每一”系指“每一及全部”。\n\n12. “每一”和“每个”系指“每一及全部”。\n\n13. “第三方”系指您本人以外的个人或实体。\n\n14. “转让”具有《破产法》第 101(54) 条赋予该词的含义。\n\n15. “文件”系指属于《联邦民事诉讼规则》第 34 条范围内的任何信息或物件，包括但不限于任何种类、类型、性质或描述的每一项书面、记录或图形材料，该等材料现由或曾由您占有、保管或控制，包括电子邮件的所有印刷及电子副本、以电子形式保存的计算机文件、电子通信、短信、社交媒体帖子、推文、元数据、通信函件、备忘录、磁带、速记或手写笔记、任何种类的书面表格、图表、蓝图、图纸、草图、曲线图、计划、文章、规格、日记、信件、电报、照片、会议记录、合同、协议、调查、计算机打印件、任何种类的数据汇编、电传、传真、语音留言、发票、订单表格、支票、汇票、对账单、贷项通知单、报告、持仓报告、摘要、索引、账册、总账、笔记本、附表、透明胶片、录音、目录、广告、宣传材料、影片、录像带、录音带、CD、计算机磁盘、宣传册、小册子、穿孔卡、工时单、推文、社交媒体帖子或任何其他种类的书面或记录材料，以及其所有元数据，无论以何种方式存储（无论为有形形式或电子形式）、记录、制作或复制；还包括但不限于前述任何材料的草稿或副本，其中载有原始文件中未出现的任何种类笔记、评论或标记，或在其他方面与原始文件不相同。\n\n案件 22-50073，文书 3193，提交日期 05/16/24，录入日期 05/16/24 10:28:21，第 144 页，共 439 页\n\n16. “个人”系指个人、公司、独资企业、合伙企业、协会或任何其他实体。“个人”还包括任何代理人、代表或专家，包括但不限于律师或财务顾问。\n\n17. “实体”系指任何自然人、公司、合伙企业、子公司、独资企业、商号、董事会、合资企业、协会、机构、主管机关、委员会或其他商业实体或法人，以及任何关联方、代理人、母公司，包括但不限于法律顾问、财务顾问或任何其他代表。\n\n18. “关于”系指涉及、描述、构成、提及、与之相关、支持、有利于、反对、加强、削弱、载于、结合考虑、对其具有影响、证明、表明、报告、记录、暗示、回应、与之相连、评论、就其而言、有关、与之相关、讨论、显示、描述、反映、分析、构成及属于。\n\n19. 当“与……有关”“涉及”或“相关”用于指称任何特定事项时，系指包括但不限于构成、包含、涉及、含有、体现、反映、识别、陈述、直接或间接提及或以任何方式与所确定的特定事项有关的任何文件。\n\n20. “通信”系指在最广泛可能的意义上且不限于此，任何信息或知识的传递（以事实、观点、询问或其他形式）。通信还指所有谈话、协议、询问或回复，无论是当面、通过电话、以书面方式或通过电子传输设备进行，并包括但不限于所有通信函件、电子邮件、录音、传送单、备忘录、电话通信、语音留言、电报、电传传真、影印传真、\n\n案件 22-50073，文书 3193，提交日期 05/16/24，录入日期 05/16/24 10:28:21，第 145 页，共 439 页\n\n电传、即时消息、聊天、短信、电话笔记，或在内部或与第三方之间传递的笔记。\n\n21. “资产”系指任何可用于产生正面经济价值的项目，包括但不限于由某一实体拥有、控制或为其利益而持有，并预期可提供未来利益的任何具有经济价值的资源，包括但不限于所有不动产和动产、无形财产、投资、投资权利或未来收入权利、现金、银行账户、商品、证券、债权、对实体的全部或部分控制权，以及潜在经济机会。\n\n22. “转让”具有《破产法》第 101(54) 条赋予该词的含义。\n\nIV. 应提交的文件\n\n1. 关于债务人、债务人家庭成员、债务人破产财产、关联个人或关联实体的任何收入或资产的所有文件。\n\n2. 与债务人的财务状况及其对债权人所负义务有关的所有文件，包括但不限于与任何避免支付该等义务的努力有关的所有文件，以及与本次或任何其他实际或潜在破产或类似无力偿债程序有关的所有文件。\n\n3. 关于与债务人、债务人破产财产、债务人家庭成员、关联实体或关联个人有关的任何资产负债表、银行对账单、账户对账单、财务报表、账户报表、电汇指令和/或确认函、资金证明、存款证明、持仓证明、投资组合摘要或类似文件的所有文件，包括但不限于足以显示向前述任何一方作出的所有转让的所有文件。\n\n案件 22-50073，文书 3193，提交日期 05/16/24，录入日期 05/16/24 10:28:21，第 146 页，共 439 页\n\n4. 关于债务人、债务人家庭成员、关联个人或关联实体作出、与其进行或代表其进行的任何投资、商业交易或交易事项的所有文件。\n\n5. 与债务人、债务人家庭成员、关联个人或关联实体之间的所有通信，以及与同债务人、债务人家庭成员、关联个人或关联实体进行的通信有关的文件，包括与任何实体（包括但不限于关联实体）的运营、管理或决策有关的通信和文件。\n\n6. 关于向债务人、债务人家庭成员、关联个人或关联实体作出、由其作出或与其进行的任何转让、投资或其他交易或商业往来的所有文件。\n\n7. 关于债务人曾占用或使用的任何财产的所有文件，包括但不限于位于 Connecticut（康涅狄格州）Greenwich（格林威治）373 Taconic Rd. 的住宅物业；位于 Connecticut（康涅狄格州）Greenwich（格林威治）33 Ferncliff Rd. 的住宅物业；位于 Connecticut（康涅狄格州）Wilton（威尔顿）354 Nod Hill Rd 的住宅物业；位于 United Kingdom（英国）London（伦敦）SW7 1QJ，5 Princes Gate 的公寓或共管公寓；以及位于 New Jersey（新泽西州）Mahwah（马瓦）675 Ramapo Valley Road, Mahwah, New Jersey 07430 的住宅物业。\n\n8. 与债务人拥有、控制或使用的任何航空器有关的所有文件，包括但不限于：(i) 尾号为 T7-GQM 的航空器及任何其他在 San Marino（圣马力诺）注册的航空器，包括但不限于所有登记文件副本及显示该等航空器所执行航班和该等航班机上人员的飞行清单；以及 (ii) 任何 Cirrus SF50 航空器。\n\n案件 22-50073，文书 3193，提交日期 05/16/24，录入日期 05/16/24 10:28:21，第 147 页，共 439 页\n\n9. 关于向债务人、债务人破产财产、债务人家庭成员或关联实体提供、由其提供或代表其提供的任何赠与、利益或贷款的所有文件，包括但不限于足以显示该等赠与、利益或贷款金额；该等赠与、利益或贷款的用途；提供该等赠与、利益或贷款的时间；以及任何贷款的条款、就任何贷款作出的所有陈述与保证、任何贷款的利率及任何贷款付款的所有证据的文件。\n\n10. 与债务人、债务人的破产财产、债务人的家庭成员或关联实体设立的、代表其设立的或为其利益而设立的任何信托或类似文书有关的所有文件，包括但不限于足以表明该等信托何时设立、由谁设立、为谁的利益而设立以及信托财产的文件。\n\n11. 与涉及债务人的任何法律争议相关的任何义务、请求权、责任或债务有关的所有文件，包括但不限于与在任何地方、州、联邦或国际机构（无论是行政机构、法院、合议机构或替代性争议解决实体）进行的任何诉讼有关的文件。\n\n12. 与债务人、债务人的家庭成员或关联个人之间的所有文件和通信。\n\n13. 你方的任何律师或其他顾问与债务人、债务人的家庭成员或关联个人之间的所有文件和通信。\n\n14. 与你现在或曾经持有权益的任何关联实体有关的所有文件。\n\n案号 22-50073 文书 3193 于 05/16/24 提交 于 05/16/24 10:28:21 登记 第 148 页，共 439 页\n\n附件 C-8\n\nB2540（表格 2540——根据规则 2004 审查的传票）（12/15）案号 22-50073 文书 3193 于 05/16/24 提交 于 05/16/24 10:28:21 登记 第 149 页，共 439 页\n\n美国破产法院（UNITED STATES BANKRUPTCY COURT）\n\n康涅狄格区（District of Connecticut）\n\n关于 HO WAN KWOK（郭文贵）等人，\n\n1 案号 22-50073 (JAM) 债务人 第11章\n\n（联合管理）\n\n根据规则 2004 审查的传票\n\n致：Makayla Randall（麦凯拉·兰德尔）\n\n（传票指向的人员姓名）\n\n证言：特此命令你于下列规定的时间、日期和地点到场，根据《联邦破产程序规则》（Federal Rules of Bankruptcy Procedure）规则 2004 接受审查并作证。随附准许该审查的法院命令副本。\n\n地点　日期和时间\n\n不适用　不适用\n\n审查将通过以下方式记录：不适用\n\n提交：你或你的代表还必须将下列文件、电子存储信息或物品携带至审查现场，并必须允许对该等材料进行查阅、复制、测试或抽样：\n\n见随附的文件提交请求。\n\n《联邦民事诉讼规则》（Fed. R. Civ. P.）45 的下列规定已随附；该规则经《联邦破产程序规则》（Fed. R. Bankr. P.）9016 规定适用于破产案件——与履行地点有关的规则 45(c)；与作为传票对象的人员之保护有关的规则 45(d)；以及与答复本传票的义务及未答复的潜在后果有关的规则 45(e) 和 45(g)。\n\n日期：May , 2024\n\n法院书记员\n\n或\n\n书记员或副书记员签名　律师签名\n\n签发或请求签发本传票的代表第11章受托人 Luc A. Despins（卢克·A·德斯平斯）的律师之姓名、地址、电子邮件地址和电话号码如下：\n\nPatrick R. Linsey, Esq.（帕特里克·R·林赛律师）；Neubert, Pepe & Monteith, P.C.（纽伯特、佩佩及蒙蒂斯专业公司）；195 Church Street, 13th Floor, New Haven, Connecticut 06510；plinsey@npmlaw.com；(203) 781-2847\n\n致签发或请求签发本传票者的通知\n\n如本传票命令在审判前提交文件、电子存储信息或有形物品，或检查场所，则必须在向传票指向的人员送达之前，向每一方当事人送达通知及本传票副本。Fed. R. Civ. P. 45(a)(4)。\n\n软件版权 (c) 1996-2022 Best Case, LLC（百斯特凯斯有限责任公司）- www.bestcase.com Best Case Bankruptcy 1 本第11章案件中的债务人为 Ho Wan Kwok（郭文贵，亦称 Guo Wengui、Miles Guo 和 Miles Kwok，以及众多其他别名）（税务识别号码后四位：9595）、Genever Holdings LLC（吉尼弗控股有限责任公司）（税务识别号码后四位：8202）及 Genever Holdings Corporation（吉尼弗控股公司）。受托人、Genever Holdings LLC 和 Genever Holdings Corporation 的邮寄地址为 Paul Hastings LLP（普衡律师事务所）, 200 Park Avenue, New York, NY 10166，收件人为 Luc A. Despins，作为 Ho Wan Kwok 破产财产的受托人（仅为通知及通信之目的）。\n\n送达证明\n\n（除非 Fed. R. Civ. P. 45 要求，否则本节不应向法院提交。）\n\n本人于（日期）收到向（个人姓名及职务，如有）发出的本传票。\n\n本人通过按下列方式向被指名人员交付副本，送达本传票：\n\n于（日期）；或\n\n本人未执行传票即予退回，原因如下：\n\n除非本传票系代表美国或其官员或代理人签发，本人还已向证人支付其一天出席费用及法律允许的里程费，金额为 \\$ 。\n\n本人的差旅费用为 \\$，服务费用为 \\$，合计为 \\$。\n\n本人在伪证处罚的约束下声明，该等信息真实且正确。\n\n日期：\n\n送达人员签名\n\n印刷体姓名及职务\n\n送达人员地址\n\n有关尝试送达等事项的补充信息：\n\n《联邦民事诉讼规则》45(c)、(d)、(e) 和 (g)（生效日期：12/1/13）（经《联邦破产程序规则》规则 9016 规定适用于破产案件）\n\n(c) 履行地点。\n\n(1) 审判、听证或证言录取。传票仅可按下列方式命令人员出席审判、听证或证言录取：\n\n(A) 在该人员居住、受雇或经常亲自办理业务所在地 100 英里以内；或\n\n(B) 在该人员居住、受雇或经常亲自办理业务所在州内，如该人员：\n\n(i) 是当事人或当事人的高级职员；或\n\n(ii) 被命令出席审判且不会产生重大费用。\n\n(2) 其他证据开示。传票可以命令：\n\n(A) 在该人员居住、受雇或经常亲自办理业务所在地 100 英里以内的地点提交文件、电子存储信息或物品；以及\n\n(B) 在被检查场所进行场所检查。\n\n(d) 对作为传票对象的人员之保护；执行。\n\n(1) 避免不当负担或费用；制裁。负责签发和送达传票的当事人或律师必须采取合理措施，避免对作为传票对象的人员施加不当负担或费用。要求履行的地区法院必须执行该义务，并对未遵守该义务的当事人或律师施加适当制裁，该制裁可包括损失的收入和合理的律师费。\n\n(2) 命令提交材料或准许检查。\n\n(A) 无须出席。被命令提交文件、电子存储信息或有形物品，或准许检查场所的人员，无须亲自到达提交或检查地点，除非同时被命令出席证言录取、听证或审判。\n\n(B) 异议。被命令提交文件或有形物品，或准许检查的人员，可以向传票中指定的当事人或律师送达书面异议，反对对任何或全部材料进行检查、复制、测试或抽样，或反对检查场所，或反对以所要求的一种或多种形式提交电子存储信息。异议必须在指定履行时间或传票送达后 14 日两者中较早者之前送达。提出异议后，适用下列规则：\n\n(i) 送达方可随时在通知受命人员后，向要求履行的地区法院提出动议，请求作出强制提交或检查的命令。\n\n(ii) 仅可依照命令所指示的内容要求实施该等行为，且该命令必须保护并非当事人或当事人高级职员的人员，使其免于因履行而产生的重大费用。\n\n(3) 撤销或修改传票。\n\n(A) 必须撤销或修改的情形。经及时动议，要求履行的地区法院必须撤销或修改具有下列情形的传票：\n\n(i) 未给予合理的履行时间；\n\n(ii) 要求人员在规则 45(c) 规定的地理限制以外履行；\n\n(iii) 要求披露享有特权或受其他保护的事项，而不适用任何例外或豁免；或\n\n(iv) 对人员施加不当负担。\n\n(B) 可以撤销或修改的情形。为保护作为传票对象或受传票影响的人员，要求履行的地区法院可以根据动议撤销或修改要求下列事项的传票：\n\n(i) 披露商业秘密或其他保密研究、开发或商业信息；或\n\n(ii) 披露未受聘专家的意见或信息，该等意见或信息未描述争议中的具体事件，且源于任何当事人未请求的该专家研究。\n\n(C) 作为替代方案规定条件。在规则 45(d)(3)(B) 所述情形下，如送达方：\n\n(i) 证明其对证言或材料具有重大需要，且若无不当困难即无法以其他方式满足该需要；以及\n\n(ii) 确保向被传唤人员给予合理补偿，\n\n法院可以不撤销或修改传票，而是在规定条件下命令出席或提交。\n\n(e) 答复传票的义务。\n\n(1) 提交文件或电子存储信息。下列程序适用于提交文件或电子存储信息：\n\n(A) 文件。对提交文件的传票作出答复的人员，必须按文件在正常业务过程中保管的方式提交文件，或者必须整理并标注文件，使其与请求中的类别相对应。\n\n(B) 未指定电子存储信息的提交形式。如传票未指定提交电子存储信息的形式，答复人员必须以其通常保管的一种或多种形式，或以一种或多种合理可用的形式提交该等信息。\n\n(C) 电子存储信息仅以一种形式提交。答复人员无须以一种以上形式提交相同的电子存储信息。\n\n(D) 无法访问的电子存储信息。对于答复人员认定因不当负担或费用而无法合理访问的来源中的电子存储信息，答复人员无须提供证据开示。在请求强制证据开示或保护令的动议中，答复人员必须证明该信息因不当负担或费用而无法合理访问。如作出该证明，若请求方考虑到规则 26(b)(2)(C) 的限制后显示正当理由，法院仍可命令从该等来源进行证据开示。法院可对该证据开示规定条件。\n\n(2) 主张特权或保护。\n\n(A) 保留的信息。根据该信息享有特权或受审判准备材料保护的主张而保留被传唤信息的人员，必须：(i) 明确提出该主张；并且\n\n(ii) 以一种不披露本身享有特权或受保护信息的方式，描述被保留文件、通信或有形物品的性质，以使各方能够评估该主张。\n\n(B) 已提交的信息。如为答复传票而提交的信息受到特权主张或审判准备材料保护主张的约束，提出该主张的人员可以将该主张及其依据通知收到该信息的任何当事人。收到通知后，当事人必须立即返还、隔离或销毁所指定的信息及其持有的任何副本；在该主张解决前不得使用或披露该信息；如该当事人在收到通知前已披露该信息，必须采取合理措施取回该信息；并且可以立即将该信息密封提交给要求履行的地区法院，以裁定该主张。提交该信息的人员必须保全该信息，直至该主张获得解决。\n\n(g) 藐视法庭。要求履行的地区法院——以及在动议被移送后，签发法院——可以认定已被送达但无充分理由而未遵从传票或与之相关命令的人员构成藐视法庭。\n\n如需查阅传票材料，请参见 Fed.R.Civ.P.45(a) 委员会说明（2013）\n\n……\n\n文件提交请求\n一、指示\n\n1．除非另有说明，下述文件请求（以下简称“请求”，每一项以下简称“一项请求”）必须分别且具体地予以答复。除非出于善意提出异议，否则应对每一项请求作出完整答复；如提出异议，应按下文所述详细说明异议理由。如异议仅涉及某一项请求的一部分，或其中包含的某一文字、短语或条款，您须仅对该部分提出异议，并对其余请求作出答复。\n\n2．电子存储信息必须按照下列指示提供：\n\na．图像。黑白图像必须为 300 DPI Group IV 单页 TIFF 文件。彩色图像必须以 JPEG 格式提供。文件名不得包含嵌入空格或特殊字符（包括逗号）。文件夹名称不得包含嵌入空格或特殊字符（包括逗号）。所有 TIFF 图像文件必须具有唯一的文件名，即 Bates 编号。每张图像右下角必须标注连续的 Bates 编号。每个文件夹中的 TIFF 文件数量不得超过 1000 个文件。Excel 电子表格应具有以该文件 Bates 编号命名的占位图像。\n\nb．图像加载文件\n\na．Concordance® 数据文件。数据文件（.DAT）包含将加载至 Concordance® 数据库的所有字段化信息。.DAT 文件的第一行必须为标识字段名称的标题行。.DAT 文件必须使用以下 Concordance® 默认分隔符：逗号 ASCII 字符（020）引号 þ ASCII 字符（254）。日期字段应采用以下格式提供：mm/dd/yyyy。日期和时间字段必须为两个独立字段。如文件包括已成像的电子邮件及附件，则必须包括附件字段，以保留电子邮件与其附件之间的父/子关系。必须包括 OCRPATH 字段，以提供所交付存储介质上提取文本文件的文件路径和名称。文本文件必须以 FIRSTBATES 命名。不得在 .DAT 文件中包含文本。对于具有原生文件的文件，必须包括 LINK 字段，以提供原生文件的文件路径和名称。原生文件必须以 FIRSTBATES 命名。\n\nb．Concordance Image® 或 Opticon 交叉引用文件。图像交叉引用文件（.LOG 或 .OPT）将图像链接至数据库记录。该文件应为以逗号分隔的文件，每行由七个字段组成；数据库中的每张图像在交叉引用文件中均应有一行，格式如下：ImageID,VolumeLabel,ImageFilePath,DocumentBreak,FolderBreak,Box Break,PageCoun。\n\nc．文件文本。文本必须作为单独的文本文件提供，而非作为 .DAT 文件内的字段提供。文本文件的完整路径（OCRPATH）应包含在 .DAT 文件中。建议提供文件级 ANSI 文本文件，并按照 FIRSTBATES/Image Key 命名。提取的文本文件必须置于单独的文件夹中，每个文件夹中的文本文件数量不得超过 1,000 个文件。文件夹名称中不得含有特殊字符（包括逗号）。必须按文件级别提供文本文件。\n\nd．特定文件类型的原生格式提供。为完整理解其内容和含义而合理需要以原生格式查看的文件类型，必须以原生格式提供。该等文件包括但不限于电子表格、类电子表格文件（Microsoft Excel、逗号分隔值、制表符分隔值等）、Microsoft PowerPoint 或其他特殊演示文件、数据库文件以及音频/视频文件。应提供一张标有 Bates 编号的分隔页图像，表明存在原生文件，并在 .dat 文件中将原生文件路径作为一个字段列出。所提供的原生文件应以与该文件分隔页相对应的 Bates 编号命名。原生文件应归入按递增方式命名的“NATIVE”目录中，并与图像目录分开。\n\ne．去重。对于存在完全重复副本的每一电子文件，仅提供一份副本。对于电子邮件，依据由 BCC、Body、CC、From、IntMsgID、To 和 Attach 属性生成的 MD5 哈希值合并重复项。对于电子邮件附件和独立电子文件，依据整个文件的 MD5 哈希值合并重复项。\n\nf．元数据。应以符合 Concordance 标准的加载文件（.dat）形式提供每一文件的提取元数据。.DAT 文件的第一行必须为标识字段名称的标题行。.DAT 文件必须使用以下 Concordance 默认分隔符：逗号 , ASCII 字符（020）引号 þ ASCII 字符（254）\n\n日期字段应采用以下格式提供：mm/dd/yyyy。日期和时间字段必须为两个独立字段。下列为必需元数据：\n案件 22-50073 文件 3193 提交日期 05/16/24 登记日期 05/16/24 10:28:21 第 154 页，共 439 页\n\n字段名称　示例数据　说明\n\nFIRSTBATES　EDC0000001　原生文件文件/电子邮件的第一个 Bates 编号\nLASTBATES　EDC0000001　原生文件文件/电子邮件的最后一个 Bates 编号\n**对于单页文件，应填写 LASTBATES 字段\nATTACHRANGE　EDC0000001\n-　父文件第一页的 Bates 编号至最后一个附件“子”文件最后一页的 Bates 编号\nEDC0000015\nBEGATTACH　EDC0000001　附件范围的第一个 Bates 编号\nENDATTACH　EDC0000015　附件范围的最后一个 Bates 编号\nCUSTODIAN　Smith, John　电子邮件：电子邮件所在的邮箱\n原生文件：文件来源的个人或部门名称\nFROM　John Smith　电子邮件：发件人\n原生文件：文件作者\n**多个条目应使用分号分隔\nTO　Coffman, Janice; LeeW　收件人\n[mailto:LeeW@MSN.com]　**多个条目应使用分号分隔\nCC　Frank Thompson [mailto:　抄送收件人\nfrank_Thompson@cdt.com]　**多个条目应使用分号分隔\nBCC　John Cain　密送收件人\n**多个条目应使用分号分隔\nSUBJECT　Board Meeting Minutes　电子邮件：电子邮件主题行 原生文件：文件标题（如有）\nFILE_NAME　BoardMeetingMinutes.docx　原生文件：原始原生文件名称，包括扩展名\nDATE_SENT　10/12/2010　电子邮件：电子邮件发送日期\n原生文件：（空）\nTIME_SENT/\nTIME_ZONE　07:05 PM GMT　电子邮件：电子邮件发送时间/电子邮件标准化所采用的时区\nTIME_ZONE　GMT　在转换过程中电子邮件被标准化所采用的时区。\nLINK　EDC0000001.msg　电子邮件或原生文件文件的超链接\n**所链接文件必须按 FIRSTBATES 编号命名\nFILE_EXTEN　MSG　代表电子邮件或原生文件的文件类型扩展名\nAUTHOR　John Smith　电子邮件：（空）\n原生文件：文件作者\nDATE_CREATED　10/10/2010　电子邮件：（空）\n原生文件：文件创建日期\n案件 22-50073 文件 3193 提交日期 05/16/24 登记日期 05/16/24 10:28:21 第 155 页，共 439 页\n\nTIME_CREATED　10:25 AM　电子邮件：（空）\n原生文件：文件创建时间\n**该数据必须为独立字段，不得与 DATE_CREATED 字段合并\nDATE_MOD　10/12/2010　电子邮件：（空）\n原生文件：文件最后修改日期\nTIME_MOD　07:00 PM　电子邮件：（空）\n原生文件：文件最后修改时间\n**该数据必须为独立字段，不得与 DATE_MOD 字段合并\nDATE_ACCESSD　10/12/2010　电子邮件：（空）\n原生文件：文件最后访问日期\nTIME_ACCESSD　07:00 PM　电子邮件：（空）\n原生文件：文件最后访问时间\n**该数据必须为独立字段，不得与 DATE_ACCESSD 字段合并\nFILE_SIZE　5,952　原生文件文件/电子邮件的大小，以 KB 计\nPGCOUNT　1　原生文件文件/电子邮件的页数\nPATH　电子邮件：（空）\nAgenda.doc　原生文件：存储原生文件文件的路径，包括原始文件名称。\nINTFILEPATH　Personal Folders\\Deleted　电子邮件：电子邮件的原始位置，包括原始文件名称。\nItems\\Board Meeting\nMinutes.msg　原生文件：（空）\nINTMSGID　<000805c2c71b\\$75977050\\$　电子邮件：唯一信息 ID 原生文件：（空）\ncb8306d1@MSN>\nMD5HASH　d131dd02c5e6eec4693d9a0　文件的 MD5 哈希值。\n698aff95c\n2fcab58712467eab4004583e\nb8fb7f89\nOCRPATH　TEXT/001/EDC0000001.txt　原生文件提取文本的路径\n\n3．每一项请求均独立适用并应独立解释，除非另有说明，任何一项请求均不限制任何其他请求的范围。\n\n4．所有文件应按照其在通常业务过程中保存的方式提供，或者应予以整理和标记，以与本请求中的类别相对应。\n\n5．本文件中的每一项请求均延及所有文件：（a）由您占有、保管或控制的；或（b）由任何代表您行事之人占有、保管或控制的，\n案件 22-50073 文件 3193 提交日期 05/16/24 登记日期 05/16/24 10:28:21 第 156 页，共 439 页\n\n包括您的律师或其他代表和顾问。每一文件均应完整提供。\n\n6．如要求您提供的文件已不再由您占有、保管或控制，则您的答复必须：（a）详细描述该文件的性质及其内容；（b）确认编制或撰写该文件的人员（以及，如适用，向其发送该文件的人员）；（c）确认该文件编制或创建的日期；（d）说明该文件是否（i）遗失或丢失，（ii）已被销毁，（iii）已自愿或非自愿地转移给他人，或（iv）以其他方式被处置；（e）说明该等处置的理由，以及围绕该等处置的事实和情形；（f）确认授权该等处置的人员；（g）确认该等处置的日期或大致日期；（h）说明该文件最近一次由您占有、保管或控制的时间；以及（i）确认目前占有、保管或控制该文件的人员（如有）。\n\n7．如要求您提供的文件已被销毁，则除前述指示所要求的信息外，您的答复还必须说明：（a）销毁该文件的理由；（b）销毁该文件的人员身份；以及（c）指示销毁该文件的人员身份。\n\n8．如您主张被请求的文件享有特权或属于律师工作成果，则您的答复必须：（a）说明：（i）足以支持您关于该文件享有特权之主张的文件描述；（ii）该文件的标题；（iii）该文件的日期；（iv）该文件的作者；（v）该文件的收件人；（vi）收到或阅览该文件原件、任何草稿、副本或复制件的每一人员身份；（vii）该文件本身或其中包含或提及的任何信息是否由任何其他人员占有、保管或控制，如是，\n案件 22-50073 文件 3193 提交日期 05/16/24 登记日期 05/16/24 10:28:21 第 157 页，共 439 页\n\n则确认该等人员身份，并说明该信息如何进入其占有状态；（viii）据以扣留该文件的特权主张；以及（ix）您将据以支持该特权主张的所有情形；以及（b）根据 D. Conn. L. Civ. R. 26(e)，就基于特权主张而扣留的每一文件，提供一份包含本指示第（a）部分所要求全部信息的特权清单。\n\n9．如原本应答复的文件的一部分含有受特权主张约束的信息，则仅应按照上述指示从该文件中删除或涂黑受特权主张约束的部分，其余部分应予提供。\n\n10. 该等请求具有持续性。特此指示您：(a) 一旦得知先前答复不完整或不正确，应立即补充或更正任何后来发现不完整或不正确的答复；以及 (b) 提供根据下述所要求的任何补充文件\n\n11. 如某一文件使用英语以外的语言，您应提供该文件。如某一文件使用英语以外的语言，且存在英文译本，您应同时提供两份文件。\n\n12. 对实体的所有提及均包括其所有关联方。\n\n13. 对个人姓名的所有提及均包括所有别名、化名或昵称。\n\n14. 除非另有明确说明，文件请求所涵盖的期间为自 February 5, 2012 起至文件请求答复到期之日止。\n案件 22-50073 文件 3193 于 05/16/24 提交 于 05/16/24 10:28:21 登记 第 158 页，共 439 页\nII. 解释规则\n\n15. (a) 任何单数名词的使用应解释为包括复数，反之亦然；以及 (b) 任何时态动词的使用应解释为包括该动词所有其他时态的使用。\n\n16. (a) “and”和“or”应根据需要解释为连词或选择连词，以使本可被解释为超出任何请求范围的所有答复均被纳入该请求范围；以及 (b) “each”和“any”应视为包括并涵盖“every”和“all”二词。\nIII. 定义\n\n根据 D. Conn. Bankr. L.R. 2004-1(a) 纳入的 D. Conn. L. Civ. R. 26(c) 所提供的定义及 D. Conn. L. Civ. R. 26(d) 所提供的解释规则，适用于文件请求。此外，本文件请求中使用的下列术语具有如下含义：\n\n1. “You”或“Your”或“Yourself”系指 Makaya Randall（马卡亚·兰德尔），连同其所有代理人、律师、代表、雇员及/或任何代表其行事的人。\n\n2. “Debtor”系指 Ho Wan Kwok（郭文贵）（又名 Miles Kwok、Miles Guo、Guo Wengui、Guo Haoyun、郭文贵或任何其他别名），连同其雇员、代理人、律师、顾问或任何代表其行事的人。\n\n3. “Debtor's Son”系指 Qiang Guo（郭强）（又名 Mileson Kwok、郭强或任何其他别名），连同其雇员、代理人、律师、顾问或任何代表其行事的人。\n案件 22-50073 文件 3193 于 05/16/24 提交 于 05/16/24 10:28:21 登记 第 159 页，共 439 页\n\n4. “Debtor's Daughter”系指 Mei Guo（郭美）（又名 Mei Gui、郭美或任何其他别名），连同其雇员、代理人、律师、顾问或任何代表其行事的人。\n\n5. “Debtor's Purported Wife”系指 Hing Chi Ngok（岳庆芝）（又名 Hing Chi Ng、Yue Qingzhi、岳庆芝或任何其他别名），连同其雇员、代理人、律师、顾问或任何代表其行事的人。\n\n6. “Debtor's Family”统称债务人、债务人之子、债务人之女及债务人的所谓妻子，以及与债务人有任何其他家庭关系的人。\n\n7. “Associated Individuals”系指单独及统称所有下列个人：(1) 持有、控制、保管或对债务人或债务人家庭所拥有、控制或享有的资产具有处置决定权的人；或 (2) 曾为一个或多个关联实体的雇员、董事，或以其他方式与一个或多个关联实体有关联的人，连同前述各方各自的雇员、代理人、律师、顾问或任何代表前述任何一方行事的人。该等关联个人包括但不限于：Anthony DiBattista（安东尼·迪巴蒂斯塔）、Alex Hadjicharalambous（亚历克斯·哈吉查拉兰布斯）、Bernardo Enriquez（贝尔纳多·恩里克斯）、Bingshang Jiao（焦冰尚）、Beile Li（李贝乐）、Brian W. Hofmeister（布赖恩·W·霍夫迈斯特）、Charles Gruder（查尔斯·格鲁德）、Daniel Podhaskie（丹尼尔·波达斯基）、David Fallon（戴维·法伦）、Defeng Cao（曹德峰）（又名 Wayne Cao、Max Cao）、Ding Lin（林丁）、Dinggang Wang（王定刚）（又名 王定刚）、Eduardo Eurnekian（爱德华多·尤尔内基安）、Ehsan Masud（埃桑·马苏德）、Fiona Yu（余菲奥娜）、Gladys Chow（周格拉迪斯）、Hao (Gavin) Li（李浩）（又名 Huo Lai）、Hao Haidong（郝海东）（又名 郝海东）、Han Chunguang（韩春光）（又名 韩春光）、Haoran He（何浩然）、Ivan Lin（林伊万）、Haitham Khaled（海赛姆·哈立德）、Jason Miller（杰森·米勒）、Jennifer Mercurio（詹妮弗·默库里奥）、Jesse Brown（杰西·布朗）、Jessica Mastrogiovanni（杰西卡·马斯特罗焦瓦尼）、Jie Zhang（张杰）、Jintao Li（李金涛）、Karin Maistrello（卡琳·迈斯特雷洛）、Kyle Bass（凯尔·巴斯）、Lihong Wei Lafrenz（魏丽红·拉弗伦茨）（又名 Sara Wei、魏丽红）、Linwan “Irene” Feng（冯林婉“艾琳”）、Max Krasner（马克斯·克拉斯纳）、Melissa Francis（梅利莎·弗朗西斯）、Michael Baranowitz（迈克尔·巴拉诺维茨）、Min Yang（杨敏）、Melissa Mendez（梅利莎·门德斯）、Nadeem Akbar（纳迪姆·阿克巴尔）、Nan Li（李楠）（又名 Chris Lee、Mei Guo Xiao Li）、Qidong Xia（夏启东）、Qu Guojiao（屈国姣）（又名 Qu Guo Jiao、屈国姣）、Ridwan Mamode Saib（里德万·马莫德·赛布）、Ross Heinemeyer（罗斯·海内迈耶）、Rui “Ray” Hao（郝睿“雷”）、Scott Barnett（斯科特·巴尼特）、Shih Hsin Yu（余世新）、Shin Hee-\n案件 22-50073 文件 3193 于 05/16/24 提交 于 05/16/24 10:28:21 登记 第 160 页，共 439 页\n\nSeup（又名 Hee Seup Shin）、Steve Bannon（史蒂夫·班农）、Talha Zobair（塔尔哈·佐拜尔）、Victor Cerda（维克托·塞尔达）、Wen Xiao（肖文）、Wencong Wang（王文聪）、William Gertz（威廉·格茨）、William Je（余建明）（又名 Je Kin Ming、Yu Jianming、余建明）、Xuebing Wang（王雪冰）、Ya Li（李娅）（又名 李娅）、Yinying (Aila) Wang（王银英）（又名 Xiao Fei Xiang）、Yongping Yan（闫永平）（Shan Mu）、Yong Yu（俞勇）、Yue Zhou（周越）、Yumei Hao（郝玉梅）（又名 Ru Shui）、Yvette Wang（王雁平）（又名 Yanping Wang、Yan Ping Wang、王雁平）、Zhang Wei（张魏）（又名 张魏）、Zhouer Wang（王周二）（又名 Joe Wang）、Zhixuan Li（李智轩）及 Ziyang Liu（刘子扬）。\n\n8. “Associated Entities”系指单独及统称所有下列任何类型的组织或实体：(1) 曾由债务人或债务人家庭拥有、控制或投资的组织或实体；或 (2) 对债务人或债务人家庭所拥有、控制或享有的任何资产直接或间接享有权益的组织或实体，连同前述各方各自的雇员、代理人、律师、顾问或任何代表前述任何一方行事的人。该等关联实体包括但不限于：1332156 B.C. Ltd.、7 Nod Hill LLC、AAGV Limited、ACA Investment Management Limited、ACA Capital Group Limited、Ace Decade Holdings Limited、AI Group Holdings Inc.、Alfa Global Ventures Limited、Alfonso Global Limited、Allied Capital Global Limited、Alpine Fiduciaries SA、Beijing Pangu Investment Co.（北京盘古投资公司）、Beijing Pangu Investment Co. Ltd.（北京盘古投资有限公司）、Beijing Pangu Investment Inc.（北京盘古投资股份有限公司）、Beijing Zenith Holdings Company Limited、Blue Capital Limited、Booming Sail New York LLC、Bravo Luck Limited、Brent Petro、BSA Strategic Fund I、China Golden Spring (Hong Kong) Limited、Chuang Xin Limited、Crane Advisory Group LLC、Creative Apex Investments Limited、Crystal Breeze Investments Limited、Dawn State Limited、Eastern Profit Corporation Limited、Empire Growth Holdings、Elite Well Global Limited、Freedom Media Ventures Ltd.、Fung Wan Trading Inc.、G Club、G Club Operations LLC、G Club International Limited、G Club Investments Limited、G Fashion LLC、G-News Operations LLC、G News LLC、GMusic Inc.、G-Services LLC、G-Translators PTY LTD、GETTR USA, Inc.、Genever Holdings Corporation、Genever Holdings\n案件 22-50073 文件 3193 于 05/16/24 提交 于 05/16/24 10:28:21 登记 第 161 页，共 439 页\n\nLLC、GFashion Media Group Inc.、GFNY, Inc.、Globalist International Limited、GNews Media Group Inc.、Golden Spring (New York) Ltd.、Guo Media、GTV Media Group, Inc.、GWGOPNZ Limited、GWGNZ Limited、Gypsy Mei Food Services, LLC、HCHK Property Management Inc.、HCHK Technologies Inc.、Hamilton Digital Assets FD SP、Hamilton Capital Holdings Inc.、Hamilton Opportunity Fund SPC、Head Win Group Limited、Himalaya Embassy、Himalaya Exchange、Himalaya Federal Reserve、Himalaya International Financial Group Ltd.、Himalaya Investment LLC、Himalaya (USA) Investment Management LLC、Himalaya New World Inc.、Himalaya Supervisory Organization、Himalaya Ventures、Holy City Hong Kong Ventures, Ltd.、Hudson Diamond Holding LLC、Hudson Diamond Holding Inc.、Hudson Diamond NY LLC、HK International Funds Investments (USA) Limited LLC、Hong Kong International Funds Investments Limited、Huk Trading Inc、Infinite Increase Limited、Infinitum Developments Limited、Japan Himalaya League, Inc.、Kalixun Trading Limited、Lamp Capital LLC、Leading Shine Limited、Leading Shine NY Limited、Lexington Property and Staffing Inc.、Long Gate Limited、MOS Himalaya Foundation Inc.、Maywind Trading LLC、New Federal State of China（新中国联邦）（又名 NFSC）、New York MOS Himalaya LLC、New Mulberry PTE Ltd.、Newpeople LLC、Noble Fame Global Limited、Pixshow Film Inc.、Roscalitar 2、Rosy Acme Ventures Limited、Rule of Law Foundation III, Inc.、Rule of Law Society、Rule of Law Society IV, Inc.、Santel LLC、Saraca Media Group, Inc.、Shiny Ace Ltd.、Shiny Times Holdings Ltd.、Stevenson, Wong & Co.、Taurus Fund LLC、Taurus Fund SP、Taurus Management LLC、The Lost Draft LLC、TM Primrose Limited、UA Himalaya Inc.、Voice of Guo Media, Inc.、Well Origin Ltd.、Wise Creation、Whitecroft Shore Limited、World Century Limited、Worldwide Opportunity Holdings Limited 及 ZIBA Limited。\n\n9. “Including”或其任何变体，系指“包括但不限于”。\n案件 22-50073 文件 3193 于 05/16/24 提交 于 05/16/24 10:28:21 登记 第 162 页，共 439 页\n\n10. “And”和“or”系指“and/or”，并应同时解释为连词及选择连词，以最大限度扩大其范围。\n\n11. “Any”、“all”和“each”系指“每一及所有”。\n\n12. “Each”和“every”系指“每一及所有”。\n\n13. “Third Party”系指您本人以外的个人或实体。\n\n14. “Transfer”具有《破产法》第 101(54) 条赋予其的含义。\n\n15. “Document”系指属于 Fed. R. Civ. P. 34 范围内的任何信息或物品，并包括但不限于任何种类、类型、性质或描述的每一项书面、记录或图形材料，该等材料现由或曾由您占有、保管或控制，包括电子邮件的所有印刷及电子副本、以电子形式保存的计算机文件、电子通信、短信、社交媒体帖子、推文、元数据、通信函件、备忘录、磁带、速记或手写笔记、任何种类的书面表格、图表、蓝图、图纸、草图、曲线图、计划、文章、规格、日记、信函、电报、照片、会议记录、合同、协议、调查、计算机打印件、任何种类的数据汇编、电传、电传传真、语音留言、发票、订购单、支票、汇票、对账单、贷项通知单、报告、持仓报告、摘要、索引、书籍、账簿、笔记本、附表、透明胶片、录音、目录、广告、宣传材料、胶片、录像带、录音带、CD、计算机磁盘、宣传册、小册子、穿孔卡、工时单、推文、社交媒体帖子或任何其他种类的书面或记录材料，以及其所有元数据，无论以何种方式储存（无论以有形或电子形式）、记录、制作或复制，亦包括但不限于前述任何材料的草稿或副本，如该等草稿或副本包含原始文件中不存在的任何笔记、评论或标记，或在其他方面与原始文件不相同。\n案件 22-50073 文件 3193 于 05/16/24 提交 于 05/16/24 10:28:21 登记 第 163 页，共 439 页\n\n16. “Person(s)”系指个人、公司、独资企业、合伙企业、协会或任何其他实体。“Person”还包括任何代理人、代表或专家，包括但不限于律师或财务顾问。\n\n17. “Entity”系指任何自然人、公司、合伙企业、子公司、独资企业、商号、董事会、合资企业、协会、机构、机关、委员会或其他商业实体或法人，以及任何关联方、代理人、母公司，包括但不限于法律顾问、财务顾问或任何其他代表。\n\n18. “Regarding”系指关于、描述、构成、提及、与之相关、支持、有利于、反对、加强、贬损、位于其中、在关联中加以考虑、对之有影响、证明、表明、报告、记录、暗示、回应、与之相连、评论、就其而言、关于、与之有关、讨论、展示、描述、反映、分析、构成及为。\n\n19. 在提及任何特定主题时，“Relating to”、“relate(s) to”或“related to”系指但不限于构成、包括、涉及、包含、体现、反映、识别、陈述、直接或间接提及，或以任何方式与所识别的特定主题相关的任何文件。\n\n20. “通讯”系指以最广义且不限于任何方式传递信息或知识（以事实、理念、询问或其他形式）。通讯还指所有谈话、协议、询问或答复，无论是当面、通过电话、以书面形式，还是通过电子传输设备进行，并包括但不限于所有信函、电子邮件、录音、传送\n\n案号 22-50073 文件 3193 提交于 05/16/24 登记于 05/16/24 10:28:21 第 164 页，共 439 页\n\n单、备忘录、电话通讯、语音留言、电报、传真、影印传真、电传、即时消息、聊天、短信、电话记录，或在内部或与第三方之间传送的记录。\n\n21. “资产”系指可用于产生正经济价值的任何项目，包括但不限于由某一实体拥有、控制或为其利益而持有的、预期将提供未来利益的任何具有经济价值的资源，包括但不限于所有不动产和动产、无形财产、投资、投资权或未来收益权、现金、银行账户、商品、证券、债权、对某一实体的全部或部分控制权，以及预期经济机会。\n\n22. “转让”应具有《破产法典》第 101(54) 条赋予该词的含义。\n\nIV. 应提供的文件\n\n1. 有关债务人、债务人的家庭成员、债务人财产、关联个人或关联实体的任何收入或资产的所有文件。\n\n2. 与债务人的财务状况及其对债权人所负义务有关的所有文件，包括但不限于与任何试图规避支付该等义务的行为有关的所有文件，以及与本次或任何其他实际或潜在的破产或类似无力偿债程序有关的所有文件。\n\n3. 有关与债务人、债务人财产、债务人的家庭成员、关联实体、\n\n案号 22-50073 文件 3193 提交于 05/16/24 登记于 05/16/24 10:28:21 第 165 页，共 439 页\n\n或关联个人有关的任何资产负债表、银行对账单、账户对账单、财务报表、账户明细表、电汇指示及／或确认、资金证明、存款证、持有证明、投资组合摘要或类似文件的所有文件，包括但不限于足以显示向上述任何一方作出的所有转让的全部文件。\n\n4. 有关由债务人、债务人的家庭成员、关联个人或关联实体作出、与其进行或代表其作出的任何投资、商业往来或交易的所有文件。\n\n5. 与债务人、债务人的家庭成员、关联个人或关联实体之间的所有通讯，以及与债务人、债务人的家庭成员、关联个人或关联实体之间的通讯有关的文件，包括与任何实体的运营、管理或决策有关的通讯及文件，包括但不限于关联实体。\n\n6. 有关向债务人、债务人的家庭成员、关联个人或关联实体作出、由其作出或与其进行的任何转让、投资、其他交易或商业往来的所有文件。\n\n7. 有关债务人曾占用或使用的任何财产的所有文件，包括但不限于位于 Connecticut（康涅狄格州）Greenwich（格林尼治）373 Taconic Rd. 的住宅物业；位于 Connecticut（康涅狄格州）Greenwich（格林尼治）33 Ferncliff Rd. 的住宅物业；位于 Connecticut（康涅狄格州）Wilton（威尔顿）354 Nod Hill Rd 的住宅物业；位于 United Kingdom（英国）London（伦敦）SW7 1QJ、5 Princes Gate 的公寓或共管公寓；以及位于 New Jersey（新泽西州）Mahwah（马瓦）675 Ramapo Valley Road, Mahwah, New Jersey 07430 的住宅物业。\n\n8. 与债务人拥有、控制或使用的任何航空器有关的所有文件，包括但不限于：(i) 尾号为 T7-GQM 的航空器以及任何其他\n\n案号 22-50073 文件 3193 提交于 05/16/24 登记于 05/16/24 10:28:21 第 166 页，共 439 页\n\n在 San Marino（圣马力诺）登记的航空器，包括但不限于所有登记文件的副本以及显示该等航空器所执行航班及该等航班上乘员的飞行清单；以及 (ii) 任何 Cirrus SF50 航空器。\n\n9. 有关向债务人、债务人财产、债务人的家庭成员或关联实体提供、从其取得或代表其提供的任何赠与、利益或贷款的所有文件，包括但不限于足以显示该等赠与、利益或贷款金额；该等赠与、利益或贷款的用途；提供该等赠与、利益或贷款的时间；以及任何贷款的条款、就任何贷款作出的一切陈述与保证、任何贷款的利率以及任何贷款全部付款证据的文件。\n\n10. 与由债务人、代表债务人、为债务人利益，或由债务人财产、债务人的家庭成员或关联实体设立的任何信托或类似文书有关的所有文件，包括但不限于足以显示该等信托设立时间、设立人、为谁的利益设立以及信托财产的文件。\n\n11. 与涉及债务人的任何法律争议相关的任何义务、请求权、责任或债务有关的所有文件，包括但不限于与在任何地方、州、联邦或国际机构前进行的任何诉讼有关的文件，无论该机构为行政机构、法院、合议庭或替代性争议解决实体。\n\n12. 与债务人、债务人的家庭成员或关联个人之间的所有文件和通讯。\n\n13. 您的任何律师或其他顾问与债务人、债务人的家庭成员或关联个人之间的所有文件和通讯。\n\n案号 22-50073 文件 3193 提交于 05/16/24 登记于 05/16/24 10:28:21 第 167 页，共 439 页\n\n14. 与您持有或曾持有权益的任何关联实体有关的所有文件。\n\n案号 22-50073 文件 3193 提交于 05/16/24 登记于 05/16/24 10:28:21 第 168 页，共 439 页\n\n附件 C-9\n\nB2540（表格 2540——规则 2004 审查传票）(12/15) 案号 22-50073 文件 3193 提交于 05/16/24 登记于 05/16/24 10:28:21 第 169 页，共\n\n美国破产法院\n\n康涅狄格区\n\n关于 HO WAN KWOK（郭文贵）等人，\n\n1 案号 22-50073 (JAM) 债务人 第 11 章\n\n（合并管理）\n\n规则 2004 审查传票\n\n致：Richard Leahy（理查德·莱希）\n\n（传票所指向之人的姓名）\n\n证言：特此命令您于下列规定的时间、日期和地点出席，并根据《联邦破产程序规则》规则 2004 的审查作证。随附准许该审查的法院命令副本。\n\n地点　日期和时间\n\n不适用　不适用\n\n该审查将以下列方式记录：不适用\n\n提交：您或您的代表还必须在审查时携带下列文件、电子存储信息或物品，并必须准许对该等材料进行检查、复制、测试或抽样：\n\n见随附的《文件提交请求》。\n\n《联邦民事诉讼规则》45 条的下列规定，依据《联邦破产程序规则》9016 条适用于破产案件，现随附于后——有关履行地点的规则 45(c)；有关作为传票对象之人的保护的规则 45(d)；以及有关您对本传票作出回应的义务及未作出回应的潜在后果的规则 45(e) 和 45(g)。\n\n日期：May , 2024\n\n法院书记员\n\n或\n\n书记员或副书记员签名　律师签名\n\n代表签发或请求本传票的第 11 章受托人 Luc A. Despins（卢克·A·德斯平斯）的律师姓名、地址、电子邮件地址和电话号码如下：\n\nPatrick R. Linsey, Esq.（帕特里克·R·林赛，律师）；Neubert, Pepe & Monteith, P.C.（Neubert, Pepe & Monteith 专业公司）；195 Church Street, 13th Floor, New Haven, Connecticut 06510；plinsey@npmlaw.com；(203) 781-2847\n\n致签发或请求本传票之人的通知\n\n如本传票命令在审判前提交文件、电子存储信息或有形物品，或检查场所，则必须在向传票所指向之人送达前，向各方送达通知及本传票副本。《联邦民事诉讼规则》45(a)(4)。\n\n软件版权 (c) 1996-2022 Best Case, LLC（Best Case 有限责任公司）- www.bestcase.com Best Case Bankruptcy 1 本第 11 章案件中的债务人为 Ho Wan Kwok（郭文贵）（亦称 Guo Wengui（郭文贵）、Miles Guo（郭文贵）及 Miles Kwok（郭文贵），以及众多其他别名）（税务识别号码后四位：9595）、Genever Holdings LLC（Genever Holdings 有限责任公司）（税务识别号码后四位：8202）及 Genever Holdings Corporation（Genever Holdings 公司）。受托人、Genever Holdings LLC 及 Genever Holdings Corporation 的邮寄地址为 Paul Hastings LLP（Paul Hastings 律师事务所），200 Park Avenue, New York, NY 10166，转交 Luc A. Despins（卢克·A·德斯平斯），作为 Ho Wan Kwok（郭文贵）财产的受托人（仅为通知和通讯之目的）。\n\n送达证明\n\n（除非《联邦民事诉讼规则》45 条要求，本节不应向法院提交。）\n\n本人于（日期）收到向（个人姓名及职务，如有）发出的本传票。\n\n本人以下列方式向具名之人递送副本，完成本传票的送达：\n\n于（日期）；或\n\n本人未予执行而退回本传票，原因如下：\n\n除非本传票代表 United States（美国）或其官员或代理人签发，本人还已向证人预付一天出席费用及法律准许的里程费，金额为 $ 。\n\n本人的差旅费用为 $，服务费用为 $，合计为 $。\n\n本人在伪证罪处罚下声明，该等信息真实且正确。\n\n日期：\n\n送达人签名\n\n正楷姓名及职务\n\n送达人地址\n\n有关尝试送达等的补充信息：\n\n《联邦民事诉讼规则》45(c)、(d)、(e) 和 (g)（自 12/1/13 起生效）（依据《联邦破产程序规则》9016 条适用于破产案件）\n\n(c) 履行地点。\n\n(1) 审判、听证或证言录取。传票仅可按以下方式命令某人出席审判、听证或证言录取：\n\n(A) 在该人居住、受雇或经常亲自从事商业活动地点 100 英里范围内；或\n\n(B) 在该人居住、受雇或经常亲自从事商业活动所在州内，如该人\n\n(i) 为当事人或当事人的高级职员；或\n\n(ii) 被命令出席审判且不会产生重大费用。\n\n(2) 其他证据开示。传票可命令：\n\n(A) 在该人居住、受雇或经常亲自从事商业活动地点 100 英里范围内的地点提交文件、电子存储信息或物品；以及\n\n(B) 在待检查场所对该场所进行检查。\n\n(d) 对作为传票对象之人的保护；执行。\n\n(1) 避免不当负担或费用；制裁。负责签发和送达传票的当事人或律师必须采取合理措施，避免对作为传票对象之人施加不当负担或费用。要求履行的地区法院必须执行该义务，并对未遵守者的当事人或律师施加适当制裁，该制裁可包括损失的收入和合理的律师费。\n\n(2) 命令提交材料或准许检查。\n\n(A) 无须出席。被命令提交文件、电子存储信息或有形物品，或准许检查场所之人，无须亲自到提交或检查地点出席，除非同时被命令出席证言录取、听证或审判。\n\n(B) 异议。被要求提交文件或有形物品或允许检查的人，可以向传票中指定的当事人或律师送达书面异议，反对检查、复制、测试或抽样任何或全部材料，或反对检查场所——或反对以所要求的一种或多种形式提交电子存储信息。异议必须在规定的履行时间之前或传票送达后 14 日内（以较早者为准）送达。如提出异议，适用以下规则：\n\n(i) 在任何时候，送达方均可在通知被要求履行者后，向要求履行地所属地区法院提出动议，请求作出强制提交或检查的命令。\n\n(ii) 仅可按照命令所指示的方式要求实施这些行为，且该命令必须保护既非当事人亦非当事人高级职员的人，使其免于承担因履行而产生的重大费用。\n\n(3) 撤销或修改传票。\n\n(A) 必须撤销或修改的情形。经及时提出动议，要求履行地所属地区法院必须撤销或修改符合以下情形的传票：\n\n(i) 未给予合理的履行时间；\n\n(ii) 要求某人在 Rule 45(c) 规定的地理范围以外履行；\n\n(iii) 要求披露享有特权或受其他保护的事项，且不存在适用的例外或放弃；或\n\n(iv) 使某人承受不当负担。\n\n(B) 可以撤销或修改的情形。为保护受传票约束或受传票影响的人，要求履行地所属地区法院可经动议，在传票要求下列事项时撤销或修改传票：\n\n(i) 披露商业秘密或其他保密的研究、开发或商业信息；或\n\n(ii) 披露未受聘专家的意见或信息，该等意见或信息并未描述争议中的具体事件，且系该专家未经任何当事人请求而进行研究所得。\n\n(C) 作为替代方案规定条件。在 Rule 45(d)(3)(B) 所述情形下，如送达方：\n\n(i) 证明其对证言或材料具有实质性需要，且如不遭受不当困难即无法以其他方式满足该需要；并且\n\n(ii) 确保被传唤人将获得合理补偿，\n\n法院可以不撤销或修改传票，而是在规定条件下命令出庭或提交材料。\n\n(e) 回应传票的义务。\n\n(1) 提交文件或电子存储信息。以下程序适用于提交文件或电子存储信息：\n\n(A) 文件。回应要求提交文件的传票的人，必须按照其在正常业务过程中保存的方式提交文件，或者必须对文件进行整理和标注，使其与要求中所列类别相对应。\n\n(B) 未指定电子存储信息提交形式。如传票未指定提交电子存储信息的形式，回应人必须以该信息通常保存的一种或多种形式，或以一种或多种合理可用的形式提交。\n\n(C) 电子存储信息仅以一种形式提交。回应人无须以一种以上形式提交同一电子存储信息。\n\n(D) 无法合理获取的电子存储信息。回应人无须从其认定因不当负担或费用而无法合理获取的来源，提供电子存储信息的证据开示。就强制证据开示或保护令提出动议时，回应人必须证明该信息因不当负担或费用而无法合理获取。如作出该证明，法院仍可在请求方证明有正当理由时，考虑 Rule 26(b)(2)(C) 的限制，命令从该等来源进行证据开示。法院可以规定证据开示的条件。\n\n(2) 主张特权或保护。\n\n(A) 扣留的信息。以所传唤的信息享有特权或作为诉讼准备材料受到保护为由扣留信息的人，必须：(i) 明确提出该主张；并且\n\n(ii) 以一种方式描述被扣留文件、通信或有形物品的性质，使当事人能够评估该主张，同时不披露本身享有特权或受保护的信息。\n\n(B) 已提交的信息。如为回应传票而提交的信息受特权主张或作为诉讼准备材料受保护主张的约束，提出该主张的人可以通知任何收到该信息的当事人该主张及其依据。收到通知后，当事人必须立即返还、隔离或销毁所指明的信息及其所持有的任何副本；在该主张得到解决前，不得使用或披露该信息；如该当事人在收到通知前已披露该信息，必须采取合理措施追回该信息；并可立即将该信息密封提交至要求履行地所属地区法院，以裁定该主张。提交该信息的人必须在该主张得到解决前保存该信息。\n\n(g) 藐视法庭。要求履行地所属地区法院——以及在动议被移送后，签发法院——可对已被送达而无充分理由不遵守传票或与之相关命令的人处以藐视法庭。\n\n关于获取传票材料，参见 Fed.R.Civ.P.45(a) 委员会说明 (2013)\n\n…\n\n文件提交请求\n\nI. 指示\n\n1. 除非另有说明，下列文件请求（以下简称“请求”，每一项称为“一项请求”）必须分别且具体地作出回应。除非出于善意提出异议，否则必须完整答复每一项请求；如提出异议，则必须按下文规定详细说明贵方异议的理由。如异议仅涉及一项请求的一部分，或其中包含的某一词语、短语或条款，贵方仅须对该部分说明异议，并对其余请求作出回应。\n\n2. 电子存储信息必须按照下列指示提交：\n\n- a. 图像。黑白图像必须为 300 DPI Group IV 单页 TIFF 文件。彩色图像必须以 JPEG 格式提交。文件名不得包含嵌入空格或特殊字符（包括逗号）。文件夹名称不得包含嵌入空格或特殊字符（包括逗号）。所有 TIFF 图像文件必须具有唯一文件名，即 Bates 编号。图像必须在每张图像的右下角标注连续的 Bates 编号。每个文件夹中的 TIFF 文件数量不应超过 1000 个文件。Excel 电子表格应具有以该文件 Bates 编号命名的占位图像。\n- b. 图像加载文件\n\t- a. Concordance® 数据文件。数据文件 (.DAT) 包含将加载至 Concordance® 数据库的所有字段信息。.DAT 文件的第一行必须为标明字段名称的标题行。.DAT 文件必须使用以下 Concordance® 默认分隔符：逗号 ASCII 字符 (020) 引号 þ ASCII 字符 (254)。日期字段应采用以下格式提供：mm/dd/yyyy。日期和时间字段必须为两个独立字段。如文件包括已成像的电子邮件及附件，必须包括附件字段，以保留电子邮件与其附件之间的父子关系。必须包括 OCRPATH 字段，以提供所提交存储介质上提取文本文件的文件路径和名称。文本文件必须以 FIRSTBATES 命名。不得在 .DAT 文件中包含文本。对于含有原生文件的文件，必须包括 LINK 字段，以提供原生文件的文件路径和名称。原生文件必须以 FIRSTBATES 命名。\n\n- b. Concordance Image® 或 Opticon 交叉引用文件。图像交叉引用文件 (.LOG 或 .OPT) 将图像链接至数据库记录。该文件应为逗号分隔文件，每行包括七个字段，且数据库中的每张图像均应在交叉引用文件中对应一行，格式如下：ImageID,VolumeLabel,ImageFilePath,DocumentBreak,FolderBreak,Box Break,PageCoun。\n- c. 文件文本。文本必须作为单独的文本文件提交，而不得作为 .DAT 文件中的字段。文本文件的完整路径 (OCRPATH) 应包括在 .DAT 文件中。建议使用以 FIRSTBATES/Image Key 命名的文件级 ANSI 文本文件。提取的文本文件必须存放在单独文件夹中，每个文件夹中的文本文件数量不应超过 1,000 个文件。文件夹名称中不得含有特殊字符（包括逗号）。文本文件必须按文件级别提供。\n- d. 特定文件类型的原生提交。为充分理解其内容和含义而合理需要以原生格式查看的文件类型，必须以原生格式提交。该等文件包括但不限于电子表格、类似电子表格的文件（Microsoft Excel、逗号分隔值、制表符分隔值等）、Microsoft PowerPoint 或其他特殊演示文件、数据库文件以及音频/视频文件。应提供一张标有 Bates 编号的提示页图像，注明原生文件的存在，并将原生文件路径作为字段包括在 .dat 文件中。所提交的原生文件应以与该文件提示页相对应的 Bates 编号命名。将原生文件归入按递增方式命名的“NATIVE”目录中，并与图像目录分开。\n- e. 去重。对于存在完全重复件的每份电子文件，仅提交一份副本。对于电子邮件，应根据由 BCC、Body、CC、From、IntMsgID、To 和 Attach 属性生成的 MD5 哈希值合并重复件。对于电子邮件附件及独立电子文件，应根据整个文件的 MD5 哈希值合并重复件。\n- f. 元数据。以符合 Concordance 要求的加载文件 (.dat) 形式提交每份文件的提取元数据。.DAT 文件的第一行必须为标明字段名称的标题行。.DAT 文件必须使用以下 Concordance 默认分隔符：逗号 , ASCII 字符 (020) 引号 þ ASCII 字符 (254)\n\n日期字段应采用以下格式提供：mm/dd/yyyy。日期和时间字段必须为两个独立字段。下列为必需的元数据：\n\n字段名称　示例数据　说明\n\nFIRSTBATES　EDC0000001　原生文件文档/电子邮件的首个 Bates 编号\nLASTBATES　EDC0000001　原生文件文档/电子邮件的最后一个 Bates 编号\nLASTBATES 字段应针对单页文件填写\nATTACHRANGE　EDC0000001\n-　母文档第一页的 Bates 编号\nEDC0000015　至最后一份“子”附件文档最后一页的 Bates 编号\nBEGATTACH　EDC0000001　附件范围的首个 Bates 编号\nENDATTACH　EDC0000015　附件范围的最后一个 Bates 编号\nCUSTODIAN　Smith, John　电子邮件：该电子邮件所在的邮箱\n原生文件：该文档来源的个人或部门名称\nFROM　John Smith　电子邮件：发件人\n原生文件：文档作者\n多个条目应以分号分隔\nTO　Coffman, Janice; LeeW　收件人\n[mailto:LeeW@MSN.com]　多个条目应以分号分隔\nCC　Frank Thompson [mailto:　抄送收件人\nfrank_Thompson@cdt.com]　多个条目应以分号分隔\nBCC　John Cain　密送收件人\n多个条目应以分号分隔\nSUBJECT　Board Meeting Minutes　电子邮件：电子邮件主题行；原生文件：文档标题（如有）\nFILE_NAME　BoardMeetingMinutes.docx　原生文件：原始原生文件名称，包括扩展名\nDATE_SENT　10/12/2010　电子邮件：发送电子邮件的日期\n原生文件：（空）\nTIME_SENT/　07:05 PM GMT　电子邮件：发送电子邮件的时间/电子邮件标准化所采用时区的时间\nTIME_ZONE　GMT　转换期间电子邮件被标准化所采用的时区。\nLINK　EDC0000001.msg　电子邮件或原生文件文档的超链接\n链接文件必须按 FIRSTBATES 编号命名\nFILE_EXTEN　MSG　代表电子邮件或原生文件的文件类型扩展名\nAUTHOR　John Smith　电子邮件：（空）\n原生文件：文档作者\nDATE_CREATED　10/10/2010　电子邮件：（空）\n原生文件：文档创建日期\nCase 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 175 of 439\n\nTIME_CREATED　10:25 AM　电子邮件：（空）\n\n原生文件：文档创建时间\n该数据必须为单独字段，不得与 DATE_CREATED 字段合并\nDATE_MOD　10/12/2010　电子邮件：（空）\n原生文件：文档最后修改日期\nTIME_MOD　07:00 PM　电子邮件：（空）\n原生文件：文档最后修改时间\n该数据必须为单独字段，不得与 DATE_MOD 字段合并\nDATE_ACCESSD　10/12/2010　电子邮件：（空）\n原生文件：文档最后访问日期\nTIME_ACCESSD　07:00 PM　电子邮件：（空）\n原生文件：文档最后访问时间\n该数据必须为单独字段，不得与 DATE_ACCESSD 字段合并\nFILE_SIZE　5,952　原生文件文档/电子邮件的大小，以 KB 计\nPGCOUNT　1　原生文件文档/电子邮件的页数\nPATH　电子邮件：（空）\nAgenda.doc　原生文件：存储原生文件文档的路径，包括原始文件名。\nINTFILEPATH　Personal Folders\\Deleted　电子邮件：电子邮件的原始位置，包括原始文件名。\nItems\\Board Meeting　原始文件名。\nMinutes.msg　原生文件：（空）\nINTMSGID　<000805c2c71b\\$75977050\\$　电子邮件：唯一邮件 ID；原生文件：（空）\ncb8306d1@MSN>\nMD5HASH　d131dd02c5e6eec4693d9a0　文档的 MD5 哈希值。\n698aff95c\n2fcab58712467eab4004583e\nb8fb7f89\nOCRPATH　TEXT/001/EDC0000001.txt　原生文件提取文本的路径\n\n3. 各项请求均独立适用并应作独立解释，除非另有说明，任何一项请求均不限制任何其他请求的范围。\n\n4. 所有文件应按通常业务过程中保存的方式提供，或者应按与本请求中各类别相对应的方式组织并标注。\n\n5. 本文件所载的每项请求均延及所有文件：（a）由您占有、保管或控制的文件；或（b）由任何代表您行事之人占有、保管或控制的文件，\nCase 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 176 of 439\n\n包括您的律师或其他代表和顾问。每份文件均应完整提供。\n\n6. 如要求您提供一份已不再由您占有、保管或控制的文件，则您的答复必须：（a）详细说明该文件的性质及其内容；（b）确认编制或撰写该文件的人员（以及，如适用，确认该文件发送给的人员）；（c）确认该文件编制或创建的日期；（d）说明该文件是否（i）遗失或丢失，（ii）已被销毁，（iii）已自愿或非自愿地转移给他人，或（iv）以其他方式被处置；（e）说明该处置的理由及其相关事实和情况；（f）确认授权该处置的人员；（g）确认该处置的日期或大致日期；（h）说明该文件最后一次由您占有、保管或控制的时间；以及（i）确认目前占有、保管或控制该文件的人员（如有）。\n\n7. 如要求您提供一份已被销毁的文件，则除前述指示所要求的信息外，您的答复还必须说明：（a）销毁该文件的理由；（b）销毁该文件的人员身份；以及（c）指示销毁该文件的人员身份。\n\n8. 如您主张所请求的文件享有特权或属于律师工作成果，则您的答复必须：（a）说明（i）足以支持您关于该文件享有特权之主张的文件描述，（ii）文件标题，（iii）文件日期，（iv）文件作者，（v）文件收件人，（vi）收到或阅览该文件原件或任何草稿、复制件或再制件的每一人员身份，（vii）该文件本身或该文件所载或提及的任何信息是否由任何其他人员占有、保管或控制，如是，则确认\nCase 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 177 of 439\n\n该等人员身份，并说明该信息如何进入其占有状态，（viii）据以扣留该文件的特权主张，以及（ix）您将据以支持该特权主张的全部情形；以及（b）根据 D. Conn. L. Civ. R. 26(e)，就每一份基于特权主张而被扣留的文件，制作一份特权日志，其中载明本指示第（a）部分所要求的全部信息。\n\n9. 如一份原本应答的文件的一部分含有受特权主张约束的信息，则仅应依照上述指示从该文件中删除或遮蔽受特权主张约束的部分，其余部分应予提供。\n\n10. 本请求具有持续性。特此指示您：（a）一旦得知先前答复不完整或不正确，应立即补充或更正任何后来发现不完整或不正确的答复；以及（b）提供根据以下内容所要求的任何额外文件\n\n11. 如文件使用英语以外的语言，您应提供该文件。如文件使用英语以外的语言且存在英文译本，您应同时提供两份文件。\n\n12. 对实体的所有提及均包括其全部关联方。\n\n13. 对个人姓名的所有提及均包括全部替代姓名、别名或昵称。\n\n14. 除非另有明确说明，文件请求所涵盖的期间为自 February 5, 2012 起至文件请求答复到期之日止。\nII. 解释规则\n\n15. （a）任何单数名词的使用应解释为包括复数，反之亦然；以及（b）任何时态的动词应解释为使用该动词的所有其他时态。\n\n16. （a）“and”和“or”应在必要时作连词性或选择性解释，以将原本可能被解释为超出任何请求范围的所有答复纳入其范围内；以及（b）“each”和“any”应视为包括并涵盖“every”和“all”二词。\nIII. 定义\n\n经 D. Conn. Bankr. L.R. 2004-1(a) 纳入的 D. Conn. L. Civ. R. 26(c) 所提供的定义以及 D. Conn. L. Civ. R. 26(d) 所提供的解释规则，应适用于文件请求。此外，本文件请求中使用的下列术语具有下列含义：\n\n1. “You”或“Your”或“Yourself”系指 Richard Leahy，以及其全部代理人、律师、代表、雇员和/或任何代表其行事之人。\n\n2. “Debtor”系指 Ho Wan Kwok（郭文贵）（亦称 Miles Kwok、Miles Guo、Guo Wengui、Guo Haoyun、郭文贵，或任何其他别名），以及其雇员、代理人、律师、顾问或任何代表其行事之人。\n\n3. “Debtor's Son”系指 Qiang Guo（郭强）（亦称 Mileson Kwok、郭强，或任何其他别名），以及其雇员、代理人、律师、顾问或任何代表其行事之人。\n\n4. “Debtor's Daughter”系指 Mei Guo（郭美）（亦称 Mei Gui、郭美，或任何其他别名），以及其雇员、代理人、律师、顾问或任何代表其行事之人。\nCase 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 179 of 439\n\n5. “Debtor's Purported Wife”系指 Hing Chi Ngok（岳庆芝）（亦称 Hing Chi Ng、Yue Qingzhi、岳庆芝，或任何其他别名），以及其雇员、代理人、律师、顾问或任何代表其行事之人。\n\n6. “Debtor's Family”统称债务人、债务人之子、债务人之女及债务人所谓的妻子，以及债务人的任何其他家庭关系人。\n\n7. “Associated Individuals”系指单独或共同符合下列情形的全部个人：（1）持有、控制、保管或对债务人或债务人家庭成员拥有、控制或享有的资产具有酌处权；或（2）曾为一个或多个关联实体的雇员、董事，或以其他方式与一个或多个关联实体有关联；以及前述各方各自的雇员、代理人、律师、顾问或任何代表前述任何一方行事之人。该等关联个人包括但不限于：Anthony DiBattista、Alex Hadjicharalambous、Bernardo Enriquez、Bingshang Jiao、Beile Li、Brian W. Hofmeister、Charles Gruder、Daniel Podhaskie、David Fallon、Defeng Cao（亦称 Wayne Cao、Max Cao）、Ding Lin、Dinggang Wang（亦称 王定刚）、Eduardo Eurnekian、Ehsan Masud、Fiona Yu、Gladys Chow、Hao (Gavin) Li（亦称 Huo Lai）、Hao Haidong（亦称 郝海东）、Han Chunguang（亦称 韩春光）、Haoran He、Ivan Lin、Haitham Khaled、Jason Miller、Jennifer Mercurio、Jesse Brown、Jessica Mastrogiovanni、Jie Zhang、Jintao Li、Karin Maistrello、Kyle Bass、Lihong Wei Lafrenz（亦称 Sara Wei、魏丽红）、Linwan “Irene” Feng、Max Krasner、Melissa Francis、Michael Baranowitz、Min Yang、Melissa Mendez、Nadeem Akbar、Nan Li（亦称 Chris Lee、Mei Guo Xiao Li）、Qidong Xia、Qu Guojiao（亦称 Qu Guo Jiao、屈国姣）、Ridwan Mamode Saib、Ross Heinemeyer、Rui “Ray” Hao、Scott Barnett、Shih Hsin Yu、Shin Hee-Seup（亦称 Hee Seup Shin）、Steve Bannon、Talha Zobair、Victor Cerda、Wen Xiao、Wencong Wang、William Gertz、William Je（亦称 Je Kin Ming、Yu Jianming、余建明）以及 Xuebing Wang，\nCase 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 180 of 439\n\nYa Li（亦称 李娅）、Yinying (Aila) Wang（亦称 Xiao Fei Xiang）、Yongping Yan（Shan Mu）、Yong Yu、Yue Zhou、Yumei Hao（亦称 Ru Shui）、Yvette Wang（亦称 Yanping Wang、Yan Ping Wang、王雁平）、Zhang Wei（亦称 张魏）、Zhouer Wang（亦称 Joe Wang）、Zhixuan Li 及 Ziyang Liu。\n\n8. “关联实体（Associated Entities）”系指，单独及共同而言，所有符合以下任一情形的任何类型组织或实体：（1）曾由债务人或债务人家庭成员拥有、控制或投资；或（2）对债务人或债务人家庭成员拥有、控制或享有的任何资产直接或间接享有权益；以及前述各方各自的雇员、代理人、律师、顾问或代表前述任何一方行事的任何人。该等关联实体包括但不限于：1332156 B.C. Ltd.（1332156 B.C.有限公司）、7 Nod Hill LLC（7 Nod Hill有限责任公司）、AAGV Limited（AAGV有限公司）、ACA Investment Management Limited（ACA投资管理有限公司）、ACA Capital Group Limited（ACA资本集团有限公司）、Ace Decade Holdings Limited（Ace Decade控股有限公司）、AI Group Holdings Inc.（AI Group控股公司）、Alfa Global Ventures Limited（Alfa Global Ventures有限公司）、Alfonso Global Limited（Alfonso Global有限公司）、Allied Capital Global Limited（Allied Capital Global有限公司）、Alpine Fiduciaries SA（Alpine Fiduciaries SA）、Beijing Pangu Investment Co.（北京盘古投资公司）、Beijing Pangu Investment Co. Ltd.（北京盘古投资有限公司）、Beijing Pangu Investment Inc.（北京盘古投资股份有限公司）、Beijing Zenith Holdings Company Limited（北京Zenith控股有限公司）、Blue Capital Limited（Blue Capital有限公司）、Booming Sail New York LLC（Booming Sail New York有限责任公司）、Bravo Luck Limited（Bravo Luck有限公司）、Brent Petro（Brent Petro）、BSA Strategic Fund I（BSA战略基金I）、China Golden Spring (Hong Kong) Limited（中国金泉〔香港〕有限公司）、Chuang Xin Limited（创新有限公司）、Crane Advisory Group LLC（Crane Advisory Group有限责任公司）、Creative Apex Investments Limited（Creative Apex Investments有限公司）、Crystal Breeze Investments Limited（Crystal Breeze Investments有限公司）、Dawn State Limited（Dawn State有限公司）、Eastern Profit Corporation Limited（Eastern Profit Corporation有限公司）、Empire Growth Holdings（Empire Growth Holdings）、Elite Well Global Limited（Elite Well Global有限公司）、Freedom Media Ventures Ltd.（Freedom Media Ventures有限公司）、Fung Wan Trading Inc.（Fung Wan Trading股份有限公司）、G Club（G Club）、G Club Operations LLC（G Club Operations有限责任公司）、G Club International Limited（G Club International有限公司）、G Club Investments Limited（G Club Investments有限公司）、G Fashion LLC（G Fashion有限责任公司）、G-News Operations LLC（G-News Operations有限责任公司）、G News LLC（G News有限责任公司）、GMusic Inc.（GMusic股份有限公司）、G-Services LLC（G-Services有限责任公司）、G-Translators PTY LTD（G-Translators PTY LTD）、GETTR USA, Inc.（GETTR USA股份有限公司）、Genever Holdings Corporation（Genever Holdings公司）、Genever Holdings LLC（Genever Holdings有限责任公司）、GFashion Media Group Inc.（GFashion Media Group股份有限公司）、GFNY, Inc.（GFNY股份有限公司）、Globalist International Limited（Globalist International有限公司）、GNews Media Group Inc.（GNews Media Group股份有限公司）、Golden Spring (New York) Ltd.（Golden Spring〔纽约〕有限公司）、Guo Media（郭媒体）、GTV Media Group, Inc.（GTV Media Group股份有限公司）、GWGOPNZ Limited（GWGOPNZ有限公司）、GWGNZ Limited（GWGNZ有限公司）、Gypsy Mei Food Services, LLC（Gypsy Mei Food Services有限责任公司）、HCHK Property Management Inc.（HCHK Property Management股份有限公司）、HCHK Technologies Inc.（HCHK Technologies股份有限公司）、Hamilton Digital Assets FD SP（Hamilton Digital Assets FD SP）、Hamilton Capital Holdings Inc.（Hamilton Capital Holdings股份有限公司）、Hamilton Opportunity Fund SPC（Hamilton Opportunity Fund SPC）、Head Win Group Limited（Head Win Group有限公司）、Himalaya Embassy（喜马拉雅大使馆）、Himalaya Exchange（喜马拉雅交易所）、Himalaya Federal Reserve（喜马拉雅联邦储备）、Himalaya International Financial Group Ltd.（喜马拉雅国际金融集团有限公司）、Himalaya Investment LLC（喜马拉雅投资有限责任公司）、Himalaya (USA) Investment Management LLC（喜马拉雅〔美国〕投资管理有限责任公司）、Himalaya New World Inc.（喜马拉雅新世界股份有限公司）、Himalaya Supervisory Organization（喜马拉雅监督组织）、Himalaya Ventures（喜马拉雅创投）、Holy City Hong Kong Ventures, Ltd.（Holy City Hong Kong Ventures有限公司）、Hudson Diamond Holding LLC（Hudson Diamond Holding有限责任公司）、Hudson Diamond Holding Inc.（Hudson Diamond Holding股份有限公司）、Hudson Diamond NY LLC（Hudson Diamond NY有限责任公司）、HK International Funds Investments (USA) Limited LLC（HK International Funds Investments〔USA〕Limited有限责任公司）、Hong Kong International Funds Investments Limited（香港国际基金投资有限公司）、Huk Trading Inc（Huk Trading股份有限公司）、Infinite Increase Limited（Infinite Increase有限公司）、Infinitum Developments Limited（Infinitum Developments有限公司）、Japan Himalaya League, Inc.（日本喜马拉雅联盟股份有限公司）、Kalixun Trading Limited（Kalixun Trading有限公司）、Lamp Capital LLC（Lamp Capital有限责任公司）、Leading Shine Limited（Leading Shine有限公司）、Leading Shine NY Limited（Leading Shine NY有限公司）、Lexington Property and Staffing Inc.（Lexington Property and Staffing股份有限公司）、Long Gate Limited（Long Gate有限公司）、MOS Himalaya Foundation Inc.（MOS喜马拉雅基金会股份有限公司）、Maywind Trading LLC（Maywind Trading有限责任公司）、New Federal State of China（中国新联邦国，亦称NFSC）、New York MOS Himalaya LLC（纽约MOS喜马拉雅有限责任公司）、New Mulberry PTE Ltd.（New Mulberry PTE有限公司）、Newpeople LLC（Newpeople有限责任公司）、Noble Fame Global Limited（Noble Fame Global有限公司）、Pixshow Film Inc.（Pixshow Film股份有限公司）、Roscalitar 2（Roscalitar 2）、Rosy Acme Ventures Limited（Rosy Acme Ventures有限公司）、Rule of Law Foundation III, Inc.（法治基金会III股份有限公司）、Rule of Law Society（法治协会）、Rule of Law Society IV, Inc.（法治协会IV股份有限公司）、Santel LLC（Santel有限责任公司）、Saraca Media Group, Inc.（Saraca Media Group股份有限公司）、Shiny Ace Ltd.（Shiny Ace有限公司）、Shiny Times Holdings Ltd.（Shiny Times Holdings有限公司）、Stevenson, Wong & Co.（Stevenson, Wong & Co.）、Taurus Fund LLC（Taurus Fund有限责任公司）、Taurus Fund SP（Taurus Fund SP）、Taurus Management LLC（Taurus Management有限责任公司）、The Lost Draft LLC（The Lost Draft有限责任公司）、TM Primrose Limited（TM Primrose有限公司）、UA Himalaya Inc.（UA Himalaya股份有限公司）、Voice of Guo Media, Inc.（郭媒体之声股份有限公司）、Well Origin Ltd.（Well Origin有限公司）、Wise Creation（Wise Creation）、Whitecroft Shore Limited（Whitecroft Shore有限公司）、World Century Limited（World Century有限公司）、Worldwide Opportunity Holdings Limited（Worldwide Opportunity Holdings有限公司）及ZIBA Limited（ZIBA有限公司）。\n\nCase 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 181 of 439\n\n9. “包括（Including）”或其任何变体，系指“包括但不限于”。\n\n10. “和（And）”及“或（or）”系指“和/或”，并应以连词及析取连词两种方式解释，以最大限度扩大其范围。\n\nCase 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 182 of 439\n\n11. “任何（Any）”、“所有（all）”及“每一（each）”系指“每一及全部”。\n\n12. “每一（Each）”及“每个（every）”系指“每一及全部”。\n\n13. “第三方（Third Party）”系指除你方以外的个人或实体。\n\n14. “转让（Transfer）”具有《破产法典》第101(54)条赋予该词的含义。\n\n15. “文件（Document）”系指属于Fed. R. Civ. P. 34范围内的任何信息或物品，并包括但不限于曾处于或目前处于你方占有、保管或控制之下的每一及全部任何种类、类型、性质或描述的书面、记录或图形资料，包括电子邮件的所有印刷及电子副本、以电子形式保存的计算机文件、电子通信、短信、社交媒体帖子、推文、元数据、通信函件、备忘录、磁带、速记或手写笔记、任何种类的书面表格、图表、蓝图、绘图、草图、曲线图、计划、文章、规格说明、日记、信函、电报、照片、会议记录、合同、协议、调查、计算机打印件、任何种类的数据汇编、电传、传真、语音留言、发票、订购单、支票、汇票、对账单、贷项通知单、报告、头寸报告、摘要、索引、书籍、账簿、笔记本、清单、透明胶片、录音、目录、广告、宣传材料、影片、录像带、录音带、CD、计算机磁盘、小册子、传单、穿孔卡、工时单、推文、社交媒体帖子或任何其他种类的书面或记录材料，以及其全部元数据，无论以何种方式存储（无论为有形或电子形式）、记录、制作或复制；亦包括但不限于前述任何材料的草稿或副本，如其载有原始文件中未见的任何种类笔记、评论或标记，或在其他方面与原始文件不完全相同。\n\nCase 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 183 of 439\n\n16. “个人（Person(s)）”系指个人、公司、独资企业、合伙企业、协会或任何其他实体。“个人”亦包括任何代理人、代表或专家，包括但不限于律师或财务顾问。\n\n17. “实体（Entity）”系指任何自然人、公司、合伙企业、子公司、独资企业、商号、董事会、合资企业、协会、机构、主管机关、委员会或其他商业实体或法人，以及任何关联方、代理人、母公司，包括但不限于法律顾问、财务顾问或任何其他代表。\n\n18. “关于（Regarding）”系指涉及、描述、包含、提及、与之有关、支持、赞成、反对、加强、削弱、位于、结合考虑、影响、证明、表明、报告、记录、暗示、回应、与之相连、评论、就其而言、关于、与之相关、讨论、展示、描述、反映、分析、构成及属于。\n\n19. 在提及任何特定主题时，“与……有关（Relating to）”、“与……有关（relate(s) to）”或“相关（related to）”系指，包括但不限于，构成、包含、涉及、含有、体现、反映、识别、陈述、直接或间接提及，或以任何方式与所识别的特定主题相关的任何文件。\n\n20. “通信（Communication(s)）”系指在最广义且不受限制的意义上，任何信息或知识的传递（以事实、想法、询问或其他形式）。通信还指所有谈话、协议、询问或答复，无论是当面、通过电话、书面方式，或通过电子传输设备进行，并包括但不限于所有通信函件、电子邮件、录音、传送单、备忘录、电话通信、语音留言、电报、电传传真、影印传真、\n\nCase 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 184 of 439\n\n电传、即时消息、聊天、短信、电话笔记，或在内部或与第三方之间传送的笔记。\n\n21. “资产（Asset(s)）”系指可用于产生正面经济价值的任何项目，包括但不限于由某一实体拥有、控制或为其利益而持有，并预期提供未来利益的任何具有经济价值的资源，包括但不限于所有不动产和动产、无形财产、投资、投资权或取得未来收入的权利、现金、银行账户、商品、证券、请求权、对某一实体的全部或部分控制权及预期经济机会。\n\n22. “转让（Transfer）”具有《破产法典》第101(54)条赋予该词的含义。\n\n四、应提交的文件\n\n1. 与债务人、债务人家庭成员、债务人的破产财产、关联个人或关联实体的任何收入或资产有关的所有文件。\n\n2. 与债务人的财务状况及其对债权人所负义务有关的所有文件，包括但不限于与任何规避支付该等义务的努力有关的所有文件，以及与本案或任何其他实际或潜在破产程序或类似无力偿债程序有关的所有文件。\n\n3. 与债务人、债务人的破产财产、债务人家庭成员、关联实体或关联个人有关的任何资产负债表、银行对账单、账户对账单、财务报表、账目报表、电汇指示及/或确认、资金证明、存款证明、持仓证明、投资组合摘要或类似文件有关的所有文件，包括但不限于足以显示向前述任何一方作出的所有转让的所有文件。\n\nCase 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 185 of 439\n\n4. 与债务人、债务人家庭成员、关联个人或关联实体作出、与其进行或代表其作出的任何投资、业务往来或交易有关的所有文件。\n\n5. 与债务人、债务人家庭成员、关联个人或关联实体的所有通信，以及与同债务人、债务人家庭成员、关联个人或关联实体的通信有关的文件，包括与任何实体的运营、管理或决策有关的通信或文件，包括但不限于关联实体。\n\n6. 与向债务人、债务人家庭成员、关联个人或关联实体作出、由其作出或与其进行的任何转让、投资或其他交易或业务往来有关的所有文件。\n\n7. 与债务人曾经占用或使用的任何财产有关的所有文件，包括但不限于位于Connecticut（康涅狄格州）Greenwich（格林尼治）373 Taconic Rd.的住宅物业；位于Connecticut（康涅狄格州）Greenwich（格林尼治）33 Ferncliff Rd.的住宅物业；位于Connecticut（康涅狄格州）Wilton（威尔顿）354 Nod Hill Rd的住宅物业；位于United Kingdom（英国）London（伦敦）SW7 1QJ，5 Princes Gate的公寓或共管公寓；以及位于New Jersey（新泽西州）Mahwah（马瓦）675 Ramapo Valley Road, Mahwah, New Jersey 07430的住宅物业。\n\n8. 与债务人拥有、控制或使用的任何航空器有关的所有文件，包括但不限于：（i）尾号为T7-GQM的航空器及在San Marino（圣马力诺）注册的任何其他航空器，包括但不限于所有注册文件副本及显示该等航空器所执行航班和该等航班机上人员的飞行舱单；以及（ii）任何Cirrus SF50航空器。\n\nCase 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 186 of 439\n\n9. 与向债务人、债务人的破产财产、债务人家庭成员或关联实体提供、从其取得或代表其提供的任何赠与、利益或贷款有关的所有文件，包括但不限于足以显示该等赠与、利益或贷款金额；该等赠与、利益或贷款的使用目的；提供该等赠与、利益或贷款的时间；任何贷款的条款；就任何贷款作出的一切陈述与保证；任何贷款的利率；以及任何贷款付款的全部证据的文件。\n\n10. 与由债务人、代表债务人或为债务人、债务人财产、债务人家庭成员或关联实体之利益设立的任何信托或类似文书有关的所有文件，包括但不限于足以显示该等信托设立时间、设立人、为谁的利益设立以及信托财产的文件。\n\n11. 与涉及债务人的任何法律争议相关的任何义务、请求权、责任或债务有关的所有文件，包括但不限于与在任何地方、州、联邦或国际机构（无论是行政机构、法院、审裁小组或替代性争议解决实体）进行的任何诉讼有关的文件。\n\n12. 与债务人、债务人家庭成员或关联个人之间的所有文件和通信。\n\n13. 您的任何律师或其他顾问与债务人、债务人家庭成员或关联个人之间的所有文件和通信。\n\n14. 与您目前或曾经持有权益的任何关联实体有关的所有文件。\n\n附件 C-10\n\nB2540（表格 2540——Rule 2004 审查传票）（12/15）Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 188 of\n\n美国破产法院 439\n\n康涅狄格区\n\n关于 HO WAN KWOK（郭文贵）等人一案，\n\n1 案号 22-50073 (JAM)\n\n债务人 第 11 章\n\n（合并管理）\n\nRule 2004 审查传票\n\n致：Thomas Guarino（托马斯·瓜里诺）（又名 Thomas Guarino II（托马斯·瓜里诺二世））\n\n（传票所指向人员的姓名）\n\n证言：现命令您于下列载明的时间、日期和地点出庭，就根据《联邦破产程序规则》Rule 2004 进行的审查作证。随附授权进行该审查的法院命令副本。\n\n地点　日期和时间\n\n不适用　不适用\n\n审查将通过以下方式记录：不适用\n\n提交：您或您的代表还必须在审查时携带下列文件、电子存储信息或物品，并必须允许对该等材料进行检查、复制、测试或抽样：\n\n见随附的文件提交请求。\n\n《联邦民事诉讼规则》Rule 45 的下列规定（经《联邦破产程序规则》Rule 9016 适用于破产案件）随附于后：有关履行地点的 Rule 45(c)；有关对作为传票对象之人员保护的 Rule 45(d)；以及有关您对本传票作出回应之义务及未作回应可能后果的 Rule 45(e) 和 45(g)。\n\n日期：May , 2024\n\n法院书记员\n\n或\n\n书记员或副书记员签名　律师签名\n\n签发或请求本传票的、代表第 11 章受托人 Luc A. Despins（卢克·A·德斯平斯）的律师姓名、地址、电子邮箱地址和电话号码如下：\n\nPatrick R. Linsey, Esq.（帕特里克·R·林赛，律师）；Neubert, Pepe & Monteith, P.C.（纽伯特、佩佩与蒙蒂思专业公司）；195 Church Street, 13th Floor, New Haven, Connecticut 06510；plinsey@npmlaw.com；(203) 781-2847\n\n致签发或请求本传票之人员的通知\n\n如本传票要求在审判前提交文件、电子存储信息或有形物品，或检查场所，则必须在向传票所指向人员送达之前，向各方送达通知及本传票副本。《联邦民事诉讼规则》Rule 45(a)(4)。\n\n软件版权 (c) 1996-2022 Best Case, LLC（百斯特凯斯有限责任公司）- www.bestcase.com Best Case Bankruptcy 1 本第 11 章案件中的债务人为 Ho Wan Kwok（郭文贵）（亦称 Guo Wengui、Miles Guo 和 Miles Kwok，以及众多其他别名）（税务识别号码后四位：9595）、Genever Holdings LLC（Genever Holdings有限责任公司）（税务识别号码后四位：8202）以及 Genever Holdings Corporation（Genever Holdings公司）。受托人、Genever Holdings LLC 及 Genever Holdings Corporation 的邮寄地址为 Paul Hastings LLP（保罗·黑斯廷斯律师事务所）, 200 Park Avenue, New York, NY 10166，转交 Luc A. Despins（卢克·A·德斯平斯），作为 Ho Wan Kwok 财产的受托人（仅为通知和通信之目的）。\n\n送达证明\n\n（除非《联邦民事诉讼规则》Rule 45 要求，否则本节不应向法院提交。）\n\n本人于（日期）收到向（个人姓名及职务，如有）发出的本传票。\n\n本人已按如下方式，通过向被指定人员交付副本送达本传票：\n\n于（日期）；或\n\n本人未执行而退回本传票，原因如下：\n\n除非本传票代表美国或其官员或代理人签发，本人亦已向证人支付一天出席费用及法律允许的里程费，金额为 \\$ 。\n\n本人的差旅费用为 \\$，服务费用为 \\$，合计为 \\$。\n\n本人在伪证处罚的约束下声明，该等信息真实且正确。\n\n日期：\n\n送达人签名\n\n印刷体姓名及职务\n\n送达人地址\n\n有关尝试送达等的补充信息：\n\n《联邦民事诉讼规则》Rule 45(c)、(d)、(e) 和 (g)（Effective 12/1/13）（经《联邦破产程序规则》Rule 9016 适用于破产案件）\n\n(c) 履行地点。\n\n(1) 审判、听证或证言录取。传票仅可按下列方式命令某人出席审判、听证或证言录取：\n\n(A) 在该人员居住地、受雇地或经常亲自从事商业活动地 100 英里以内；或\n\n(B) 在该人员居住、受雇或经常亲自从事商业活动所在州内，如该人员：\n\n(i) 是当事人或当事人的高级职员；或\n\n(ii) 被命令出席审判且不会产生重大费用。\n\n(2) 其他证据开示。传票可以命令：\n\n(A) 在该人员居住地、受雇地或经常亲自从事商业活动地 100 英里以内的地点提交文件、电子存储信息或物品；以及\n\n(B) 在被检查场所对该场所进行检查。\n\n(d) 对作为传票对象之人员的保护；执行。\n\n(1) 避免不当负担或费用；制裁。负责签发和送达传票的当事人或律师必须采取合理措施，避免对作为传票对象之人员施加不当负担或费用。要求履行的地区法院必须执行该义务，并对未遵守者（当事人或律师）施加适当制裁，该制裁可包括损失的收入和合理的律师费。\n\n(2) 命令提交材料或允许检查。\n\n(A) 无需出庭。被命令提交文件、电子存储信息或有形物品，或允许检查场所的人员，无需亲自到提交或检查地点出庭，除非其亦被命令出席证言录取、听证或审判。\n\n(B) 异议。被命令提交文件或有形物品，或允许检查的人员，可以向传票中指定的当事人或律师送达书面异议，反对检查、复制、测试或抽样任何或全部材料，或反对检查场所，或反对按所要求的一种或多种形式提交电子存储信息。异议必须在规定履行时间或传票送达后 14 日届满两者中较早者之前送达。如提出异议，适用以下规则：\n\n(i) 送达传票的当事人可在任何时候，在通知被命令人员后，向要求履行的地区法院提出动议，请求作出强制提交或检查的命令。\n\n(ii) 仅可依照该命令的指示要求实施上述行为，且该命令必须保护并非当事人或当事人高级职员的人员，使其免于因履行而产生的重大费用。\n\n(3) 撤销或修改传票。\n\n(A) 必须撤销或修改的情形。在及时提出动议后，要求履行的地区法院必须撤销或修改具有下列情形的传票：\n\n(i) 未给予合理履行时间；\n\n(ii) 要求某人在 Rule 45(c) 规定的地理范围之外履行；\n\n(iii) 要求披露享有特权或受其他保护的事项，且不存在适用的例外或放弃；或\n\n(iv) 对某人造成不当负担。\n\n(B) 可以撤销或修改的情形。为保护作为传票对象或受传票影响之人员，要求履行的地区法院可依动议撤销或修改要求下列事项的传票：\n\n(i) 披露商业秘密或其他保密的研究、开发或商业信息；或\n\n(ii) 披露未经聘用的专家之意见或信息，该等意见或信息并未描述争议中的具体事件，且源于未经任何一方请求的该专家研究。\n\n(C) 以规定条件作为替代。在 Rule 45(d)(3)(B) 所述情形下，如送达传票的当事人：\n\n(i) 证明其对证言或材料具有实质性需要，且不遭受不当困难即无法以其他方式满足该需要；并且\n\n(ii) 确保被传唤人员将获得合理补偿，\n\n法院可不撤销或修改传票，而命令在规定条件下出庭或提交材料。\n\n(e) 对传票作出回应的义务。\n\n(1) 提交文件或电子存储信息。下列程序适用于提交文件或电子存储信息：\n\n(A) 文件。对提交文件的传票作出回应的人员，必须按文件在正常业务过程中保存的方式提交，或者必须将文件整理并标注，以对应请求中的类别。\n\n(B) 未规定提交电子存储信息的形式。如传票未规定提交电子存储信息的形式，作出回应的人员必须按其通常保存的一种或多种形式，或按一种或多种合理可用的形式提交。\n\n(C) 电子存储信息仅以一种形式提交。作出回应的人员无需以一种以上形式提交相同的电子存储信息。\n\n(D) 无法合理获取的电子存储信息。作出回应的人员无需就其认定因不当负担或费用而无法合理获取的来源中的电子存储信息提供证据开示。在提出强制证据开示动议或保护令动议时，作出回应的人员必须证明该信息因不当负担或费用而无法合理获取。如作出该等证明，若提出请求的一方在考虑 Rule 26(b)(2)(C) 的限制后证明有正当理由，法院仍可命令对该等来源进行证据开示。法院可规定该证据开示的条件。\n\n(2) 主张特权或保护。\n\n(A) 被扣留的信息。以享有特权或作为审判准备材料而受保护为由扣留被传唤信息的人员必须：(i) 明确提出该主张；并且\n\n(ii) 以一种在不披露本身享有特权或受保护的信息的情况下，足以使各方评估该主张的方式，说明被扣留文件、通信或有形物品的性质。\n\n(B) 已提交的信息。如为回应传票而提交的信息受到特权主张或作为审判准备材料受保护的主张，提出该主张的人员可以通知收到该信息的任何一方该主张及其依据。接到通知后，当事人必须立即返还、隔离或销毁所指定的信息及其持有的任何副本；在该主张获得解决前，不得使用或披露该信息；如该当事人在接到通知前披露了该信息，必须采取合理措施予以追回；并可立即将该信息密封提交给要求履行的地区法院，以裁定该主张。提交该信息的人员必须保存该信息，直至该主张获得解决。\n\n(g) 藐视法庭。要求履行的地区法院——以及在动议被移送后，签发法院——可以认定已经送达但无充分理由不遵守传票或与其有关命令的人员构成藐视法庭。\n\n有关调取传票材料，见 Fed.R.Civ.P.45(a) Committee Note (2013)\n\n……\n\n文件提交请求\nI. 指示\n\n1. 除非另有说明，下列文件请求（以下简称“请求”，各项单称“一项请求”）必须分别且具体地作出答复。除非基于善意提出异议，否则应完整答复每项请求；如提出异议，应按照下文规定详细说明贵方异议的理由。如异议仅涉及某项请求的一部分，或其中包含的某个词语、短语或条款，贵方仅须说明对该部分的异议，并答复其余请求。\n\n2. 电子存储信息必须按照下列指示提供：\n\na. 图像。黑白图像必须为 300 DPI Group IV 单页 TIFF 文件。彩色图像必须以 JPEG 格式提供。文件名不得包含嵌入空格或特殊字符（包括逗号）。文件夹名称不得包含嵌入空格或特殊字符（包括逗号）。所有 TIFF 图像文件必须具有唯一文件名，即 Bates 编号。图像须在每幅图像右下角标注连续的 Bates 编号。每个文件夹内的 TIFF 文件不得超过 1000 个。Excel 电子表格应具有以该文件的 Bates 编号命名的占位图像。\n\nb. 图像加载文件\n\na. Concordance® 数据文件。数据文件（.DAT）包含将加载至 Concordance® 数据库的所有字段信息。.DAT 文件的第一行必须为标识字段名称的标题行。.DAT 文件必须使用以下 Concordance® 默认分隔符：逗号 ASCII 字符（020）引号 þ ASCII 字符（254）。日期字段应采用以下格式提供：mm/dd/yyyy。日期和时间字段必须为两个独立字段。如文件包括已成像的电子邮件及附件，则必须包括附件字段，以保留电子邮件与其附件之间的父/子关系。必须包括 OCRPATH 字段，以提供所提交存储介质上提取文本文件的文件路径及名称。文本文件必须以 FIRSTBATES 命名。不得将文本包含在 .DAT 文件中。对于包含原生文件的文件，必须包括 LINK 字段，以提供原生文件的文件路径及\n\n名称。原生文件必须以 FIRSTBATES 命名。\n\nb. Concordance Image® 或 Opticon 交叉引用文件。图像交叉引用文件（.LOG 或 .OPT）将图像链接至数据库记录。该文件应为以逗号分隔的文件，每行包含七个字段；数据库中的每幅图像均应在交叉引用文件中有一行，格式如下：ImageID,VolumeLabel,ImageFilePath,DocumentBreak,FolderBreak,Box Break,PageCoun。\n\nc. 文件文本。文本必须作为独立文本文件提供，而非作为 .DAT 文件内的字段提供。文本文件的完整路径（OCRPATH）应包含在 .DAT 文件中。建议提供文件级 ANSI 文本文件，并按 FIRSTBATES/Image Key 命名。提取的文本文件必须置于单独的文件夹中，且每个文件夹内的文本文件不得超过 1,000 个。文件夹名称中不得包含特殊字符（包括逗号）。文本文件必须按文件级别提供。\n\nd. 特定文件类型的原生格式提供。为充分理解其内容和含义而合理需要以原生格式查看的文件类型，必须以原生格式提供。该等文件包括但不限于电子表格、类似电子表格的文件（Microsoft Excel、逗号分隔值、制表符分隔值等）、Microsoft PowerPoint 或其他特殊演示文件、数据库文件以及音频/视频文件。应提供一张标注 Bates 编号的分隔页图像，表明存在原生文件，并在 .dat 文件中将原生文件路径作为字段包含。所提交的原生文件应以与该文件分隔页对应的 Bates 编号命名。原生文件应归入按递增方式命名的“NATIVE”目录中，并与图像目录分开。\n\ne. 去重。对于存在完全重复副本的每份电子文件，仅提供一份副本。对于电子邮件，应基于从 BCC、Body、CC、From、IntMsgID、To 和 Attach 属性生成的 MD5 哈希值合并重复文件。对于电子邮件附件和独立电子文件，应基于整个文件的 MD5 哈希值合并重复文件。\n\nf. 元数据。应以符合 Concordance 要求的加载文件（.dat）形式提供每份文件的提取元数据。.DAT 文件的第一行必须为标识字段名称的标题行。.DAT 文件必须使用以下 Concordance 默认分隔符：逗号 , ASCII 字符（020）引号 þ ASCII 字符（254）\n\n日期字段应采用以下格式提供：mm/dd/yyyy。日期和时间字段必须为两个独立字段。所需元数据如下：\n\nCase 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 193 of 439\n\n字段名称　示例数据　说明\n\nFIRSTBATES　EDC0000001　原生文件文件/电子邮件的首个 Bates 编号\nLASTBATES　EDC0000001　原生文件文件/电子邮件的最后 Bates 编号\nLASTBATES 字段应针对单页文件填写\nATTACHRANGE　EDC0000001\n-　父文件第一页的 Bates 编号至最后一个附件“子”文件最后一页的 Bates 编号\nEDC0000015\nBEGATTACH　EDC0000001　附件范围的首个 Bates 编号\nENDATTACH　EDC0000015　附件范围的最后 Bates 编号\nCUSTODIAN　Smith, John　电子邮件：电子邮件所在的邮箱\n原生文件：文件来源的个人或部门名称\nFROM　John Smith　电子邮件：发件人\n原生文件：文件作者\n多个条目之间应使用分号分隔\nTO　Coffman, Janice; LeeW　收件人\n[mailto:LeeW@MSN.com]　多个条目之间应使用分号分隔\nCC　Frank Thompson [mailto:　抄送收件人\nfrank_Thompson@cdt.com]　多个条目之间应使用分号分隔\nBCC　John Cain　密送收件人\n多个条目之间应使用分号分隔\nSUBJECT　Board Meeting Minutes　电子邮件：电子邮件主题行 原生文件：文件标题（如有）\nFILE_NAME　BoardMeetingMinutes.docx　原生文件：原始原生文件名称，包括扩展名\nDATE_SENT　10/12/2010　电子邮件：电子邮件发送日期\n原生文件：（空）\nTIME_SENT/　07:05 PM GMT　电子邮件：电子邮件发送时间/电子邮件标准化所采用的时区\nTIME_ZONE\nTIME_ZONE　GMT　在转换期间电子邮件被标准化所采用的时区。\nLINK　EDC0000001.msg　指向电子邮件或原生文件文件的超链接\n链接文件必须按 FIRSTBATES 编号命名\nFILE_EXTEN　MSG　代表电子邮件或\n文件的文件类型扩展名\nAUTHOR　John Smith　电子邮件：（空）\n原生文件：文件作者\nDATE_CREATED　10/10/2010　电子邮件：（空）\n原生文件：文件创建日期\n\nCase 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 194 of 439\n\nTIME_CREATED　10:25 AM　电子邮件：（空）\n原生文件：文件创建时间\n该数据必须为独立字段，不得与 DATE_CREATED 字段合并\nDATE_MOD　10/12/2010　电子邮件：（空）\n原生文件：文件最后修改日期\nTIME_MOD　07:00 PM　电子邮件：（空）\n原生文件：文件最后修改时间\n该数据必须为独立字段，不得与 DATE_MOD 字段合并\nDATE_ACCESSD　10/12/2010　电子邮件：（空）\n原生文件：文件最后访问日期\nTIME_ACCESSD　07:00 PM　电子邮件：（空）\n原生文件：文件最后访问时间\n该数据必须为独立字段，不得与 DATE_ACCESSD 字段合并\nFILE_SIZE　5,952　原生文件文件/电子邮件的大小，以 KB 计\nPGCOUNT　1　原生文件文件/电子邮件的页数\nPATH　电子邮件：（空）\nAgenda.doc　原生文件：存储原生文件文件的路径，包括原始文件名。\nINTFILEPATH　Personal Folders\\Deleted　电子邮件：电子邮件的原始位置，包括原始文件名。\nItems\\Board Meeting\nMinutes.msg　原生文件：（空）\nINTMSGID　<000805c2c71b\\$75977050\\$　电子邮件：唯一邮件 ID 原生文件：（空）\ncb8306d1@MSN>\nMD5HASH　d131dd02c5e6eec4693d9a0　文件的 MD5 哈希值。\n698aff95c\n2fcab58712467eab4004583e\nb8fb7f89\nOCRPATH　TEXT/001/EDC0000001.txt　原生文件提取文本的路径\n\n3. 每项请求独立运作且应被独立解释；除非另有说明，任何一项请求均不限制任何其他请求的范围。\n\n4. 所有文件应按其在正常业务过程中保存的方式提供，或者应予以整理和标记，以对应本请求中的类别。\n\n5. 每项本文件所载请求均延及所有文件：(a) 由贵方占有、保管或控制的文件；或 (b) 由代表贵方行事的任何人占有、保管或控制的文件，\n\nCase 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 195 of 439\n\n包括贵方律师或其他代表及顾问。每份文件均应完整提供。\n\n6. 如要求贵方提供一份已不再由贵方占有、保管或控制的文件，则贵方答复必须：(a) 详细描述该文件的性质及内容；(b) 识别制作或撰写该文件的人员（以及，如适用，该文件被发送给的人员）；(c) 识别该文件制作或创建的日期；(d) 说明该文件是否：(i) 缺失或遗失，(ii) 已被销毁，(iii) 已自愿或非自愿地转移给他人，或 (iv) 已以其他方式处置；(e) 说明该等处置的理由，以及有关该等处置的事实和情形；(f) 识别授权该等处置的人员；(g) 识别该等处置的日期或大致日期；(h) 说明该文件最近一次由贵方占有、保管或控制的时间；以及 (i) 识别目前占有、保管或控制该文件的人员（如有）。\n\n7. 如要求贵方提供一份已被销毁的文件，则除前述指示所要求的信息外，贵方答复还必须说明：(a) 销毁该文件的理由；(b) 销毁该文件的人员身份；以及 (c) 指示销毁该文件的人员身份。\n\n8. 如贵方主张所请求的文件享有特权或律师工作成果保护，则贵方答复必须：(a) 说明：(i) 足以支持贵方关于该文件享有特权之主张的文件描述，(ii) 文件标题，(iii) 文件日期，(iv) 文件作者，(v) 文件收件人，(vi) 收到或阅览该文件原件或任何草稿、副本或复制件的每一人员身份，(vii) 该文件本身或该文件所含或提及的任何信息是否由任何其他人员占有、保管或控制；如是，则说明该等人员身份，并说明该信息如何进入其占有范围，(viii) 据以扣留该文件的特权主张，以及 (ix) 贵方将据以支持该等特权主张的所有情形；以及 (b) 按照 D. Conn. L. Civ. R. 26(e)，就基于特权主张而扣留的每份文件，制作一份特权日志，其中载明本指示第 (a) 部分所要求的全部信息。\n\nCase 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 196 of 439\n\n9. 如一份原本应答的文件的一部分包含受特权主张约束的信息，则仅应按照上述指示从该文件中删除或涂黑受特权主张约束的部分，其余部分应予提供。\n\n10. 这些请求具有持续性。现指示你方：(a) 一旦得知先前答复不完整或不正确，应立即补充或更正任何后来得知不完整或不正确的答复；以及 (b) 提交根据该等项下所要求的任何补充文件。\n\n11. 如某一文件为英文以外的语言，你方应提供该文件。如某一文件为英文以外的语言，且存在英文译本，你方应同时提供两份文件。\n\n12. 对实体的所有提述均包括其所有关联方。\n\n13. 对个人姓名的所有提述均包括所有其他姓名、别名或昵称。\n\n14. 除非另有明确说明，文件请求所涵盖的期间为自 February 5, 2012 起至文件请求答复到期之日止。\n\nII. 解释规则\n\n15. (a) 使用任何单数名词，应解释为包括复数，反之亦然；以及 (b) 使用任何时态的动词，应解释为在所有其他时态中使用该动词。\n\n16. (a) “and”和“or”应视必要而作连词性或选择性解释，以使原本可能被解释为超出任何请求范围的所有答复均纳入该请求范围；以及 (b) “each”和“any”应视为包括并涵盖“every”和“all”二词。\n\nIII. 定义\n\n经 D. Conn. Bankr. L.R. 2004-1(a) 纳入的 D. Conn. L. Civ. R. 26(c) 所规定的定义以及 D. Conn. L. Civ. R. 26(d) 所规定的解释规则，适用于该等文件请求。此外，本文件请求中使用的下列术语具有下列含义：\n\n1. “You”或“Your”或“Yourself”指并是指 Thomas Guarino（托马斯·瓜里诺，亦称 Thomas Guarino II），以及其所有代理人、律师、代表、雇员和/或任何代表其行事的人员。\n\n2. “Debtor”指 Ho Wan Kwok（郭文贵，亦称 Miles Kwok、Miles Guo、Guo Wengui、Guo Haoyun、郭文贵或任何其他别名），以及其雇员、代理人、法律顾问、顾问或任何代表其行事的人员。\n\n3. “Debtor's Son”指 Qiang Guo（郭强，亦称 Mileson Kwok、郭强或任何其他别名），以及其雇员、代理人、法律顾问、顾问或任何代表其行事的人员。\n\nCase 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 198 of 439\n\n4. “Debtor's Daughter”指 Mei Guo（郭美，亦称 Mei Gui、郭美或任何其他别名），以及其雇员、代理人、法律顾问、顾问或任何代表其行事的人员。\n\n5. “Debtor's Purported Wife”指 Hing Chi Ngok（岳庆芝，亦称 Hing Chi Ng、Yue Qingzhi、岳庆芝或任何其他别名），以及其雇员、代理人、法律顾问、顾问或任何代表其行事的人员。\n\n6. “Debtor's Family”统称债务人、债务人之子、债务人之女及债务人的据称妻子，以及与债务人具有任何其他亲属关系的人员。\n\n7. “Associated Individuals”单独及统称：(1) 持有、控制、保管或对债务人或债务人家族拥有、控制或享有的资产具有酌处权的所有个人；或 (2) 曾为一个或多个关联实体的雇员、董事或以其他方式与其有关联的所有个人，以及上述各方各自的雇员、代理人、法律顾问、顾问或任何代表上述任何一方行事的人员。该等关联个人包括但不限于：Anthony DiBattista（安东尼·迪巴蒂斯塔）、Alex Hadjicharalambous（亚历克斯·哈吉查拉兰布斯）、Bernardo Enriquez（贝尔纳多·恩里克斯）、Bingshang Jiao（焦冰裳）、Beile Li（李蓓乐）、Brian W. Hofmeister（布赖恩·W·霍夫迈斯特）、Charles Gruder（查尔斯·格鲁德）、Daniel Podhaskie（丹尼尔·波德哈斯基）、David Fallon（大卫·法伦）、Defeng Cao（曹德峰，亦称 Wayne Cao、Max Cao）、Ding Lin（林丁）、Dinggang Wang（王定刚，亦称 王定刚）、Eduardo Eurnekian（爱德华多·欧尔内基安）、Ehsan Masud（埃赫桑·马苏德）、Fiona Yu（余菲奥娜）、Gladys Chow（周格拉迪斯）、Hao (Gavin) Li（李浩，亦称 Huo Lai）、Hao Haidong（郝海东，亦称 郝海东）、Han Chunguang（韩春光，亦称 韩春光）、Haoran He（何浩然）、Ivan Lin（林伊万）、Haitham Khaled（海赛姆·哈立德）、Jason Miller（杰森·米勒）、Jennifer Mercurio（詹妮弗·默库里奥）、Jesse Brown（杰西·布朗）、Jessica Mastrogiovanni（杰西卡·马斯特罗焦瓦尼）、Jie Zhang（张杰）、Jintao Li（李金涛）、Karin Maistrello（卡琳·梅斯特雷洛）、Kyle Bass（凯尔·巴斯）、Lihong Wei Lafrenz（魏丽红·拉弗伦茨，亦称 Sara Wei、魏丽红）、Linwan “Irene” Feng（冯林婉“艾琳”）、Max Krasner（马克斯·克拉斯纳）、Melissa Francis（梅丽莎·弗朗西斯）、Michael Baranowitz（迈克尔·巴拉诺维茨）、Min Yang（杨敏）、Melissa Mendez（梅丽莎·门德斯）、Nadeem Akbar（纳迪姆·阿克巴）、Nan Li（李楠，亦称 Chris Lee、Mei Guo Xiao Li）、Qidong Xia（夏启东）、Qu Guojiao（屈国姣，亦称 Qu Guo Jiao、屈国姣）、Ridwan Mamode Saib（里德万·马莫德·赛义卜）、Ross Heinemeyer（罗斯·海内迈耶）、Rui “Ray” Hao（郝锐“雷”）、Scott Barnett（斯科特·巴内特）、Shih Hsin Yu（余世新）、Shin Hee-\n\nCase 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 199 of 439\n\nSeup（申熙燮，亦称 Hee Seup Shin）、Steve Bannon（史蒂夫·班农）、Talha Zobair（塔尔哈·佐拜尔）、Victor Cerda（维克托·塞尔达）、Wen Xiao（肖文）、Wencong Wang（王文聪）、William Gertz（威廉·格茨）、William Je（余建明，亦称 Je Kin Ming、Yu Jianming、余建明）、Xuebing Wang（王学兵）、Ya Li（李娅，亦称 李娅）、Yinying (Aila) Wang（王茵莹，亦称 Xiao Fei Xiang）、Yongping Yan（阎永平，山木）、Yong Yu（余勇）、Yue Zhou（周悦）、Yumei Hao（郝玉梅，亦称 Ru Shui）、Yvette Wang（王雁平，亦称 Yanping Wang、Yan Ping Wang、王雁平）、Zhang Wei（张魏，亦称 张魏）、Zhouer Wang（王周二，亦称 Joe Wang）、Zhixuan Li（李志轩）及 Ziyang Liu（刘子扬）。\n\n8. “Associated Entities”单独及统称：(1) 曾由债务人或债务人家族拥有、控制或投资的所有任何类型的组织或实体；或 (2) 对债务人或债务人家族拥有、控制或享有的任何资产直接或间接拥有权益的所有组织或实体，以及上述各方各自的雇员、代理人、法律顾问、顾问或任何代表上述任何一方行事的人员。该等关联实体包括但不限于：1332156 B.C. Ltd.、7 Nod Hill LLC、AAGV Limited、ACA Investment Management Limited、ACA Capital Group Limited、Ace Decade Holdings Limited、AI Group Holdings Inc.、Alfa Global Ventures Limited、Alfonso Global Limited、Allied Capital Global Limited、Alpine Fiduciaries SA、Beijing Pangu Investment Co.（北京盘古投资有限公司）、Beijing Pangu Investment Co. Ltd.（北京盘古投资有限公司）、Beijing Pangu Investment Inc.（北京盘古投资股份有限公司）、Beijing Zenith Holdings Company Limited（北京泽尼思控股有限公司）、Blue Capital Limited、Booming Sail New York LLC、Bravo Luck Limited、Brent Petro、BSA Strategic Fund I、China Golden Spring (Hong Kong) Limited（中国金泉〈香港〉有限公司）、Chuang Xin Limited、Crane Advisory Group LLC、Creative Apex Investments Limited、Crystal Breeze Investments Limited、Dawn State Limited、Eastern Profit Corporation Limited、Empire Growth Holdings、Elite Well Global Limited、Freedom Media Ventures Ltd.、Fung Wan Trading Inc.、G Club、G Club Operations LLC、G Club International Limited、G Club Investments Limited、G Fashion LLC、G-News Operations LLC、G News LLC、GMusic Inc.、G-Services LLC、G-Translators PTY LTD、GETTR USA, Inc.、Genever Holdings Corporation、Genever Holdings\n\nCase 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 200 of 439\n\nLLC、GFashion Media Group Inc.、GFNY, Inc.、Globalist International Limited、GNews Media Group Inc.、Golden Spring (New York) Ltd.、Guo Media、GTV Media Group, Inc.、GWGOPNZ Limited、GWGNZ Limited、Gypsy Mei Food Services, LLC、HCHK Property Management Inc.、HCHK Technologies Inc.、Hamilton Digital Assets FD SP、Hamilton Capital Holdings Inc.、Hamilton Opportunity Fund SPC、Head Win Group Limited、Himalaya Embassy、Himalaya Exchange、Himalaya Federal Reserve、Himalaya International Financial Group Ltd.、Himalaya Investment LLC、Himalaya (USA) Investment Management LLC、Himalaya New World Inc.、Himalaya Supervisory Organization、Himalaya Ventures、Holy City Hong Kong Ventures, Ltd.、Hudson Diamond Holding LLC、Hudson Diamond Holding Inc.、Hudson Diamond NY LLC、HK International Funds Investments (USA) Limited LLC、Hong Kong International Funds Investments Limited、Huk Trading Inc、Infinite Increase Limited、Infinitum Developments Limited、Japan Himalaya League, Inc.、Kalixun Trading Limited、Lamp Capital LLC、Leading Shine Limited、Leading Shine NY Limited、Lexington Property and Staffing Inc.、Long Gate Limited、MOS Himalaya Foundation Inc.、Maywind Trading LLC、New Federal State of China（新中国联邦，亦称 NFSC）、New York MOS Himalaya LLC、New Mulberry PTE Ltd.、Newpeople LLC、Noble Fame Global Limited、Pixshow Film Inc.、Roscalitar 2、Rosy Acme Ventures Limited、Rule of Law Foundation III, Inc.、Rule of Law Society、Rule of Law Society IV, Inc.、Santel LLC、Saraca Media Group, Inc.、Shiny Ace Ltd.、Shiny Times Holdings Ltd.、Stevenson, Wong & Co.、Taurus Fund LLC、Taurus Fund SP、Taurus Management LLC、The Lost Draft LLC、TM Primrose Limited、UA Himalaya Inc.、Voice of Guo Media, Inc.、Well Origin Ltd.、Wise Creation、Whitecroft Shore Limited、World Century Limited、Worldwide Opportunity Holdings Limited 及 ZIBA Limited。\n\n9. “Including”或其任何变体意为“包括但不限于”。\n\nCase 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 201 of 439\n\n10. “And”和“or”意为“and/or”，并应同时作连词性及选择性解释，以最大限度扩大其范围。\n\n11. “Any”、“all”和“each”意为“每一及全部”。\n\n12. “Each”和“every”意为“每一及全部”。\n\n13. “Third Party”指你方以外的个人或实体。\n\n14. “Transfer”具有《破产法典》第 101(54) 条赋予该词的含义。\n\n15. “Document”指 Fed. R. Civ. P. 34 范围内的任何信息或物品，并包括但不限于你方曾经或现时占有、保管或控制的任何种类、类型、性质或描述的每一份书面、录制或图形材料，包括电子邮件的所有印刷及电子副本、以电子形式保存的计算机文件、电子通信、短信、社交媒体帖子、推文、元数据、通信函件、备忘录、磁带、速记或手写笔记、任何种类的书面表格、图表、蓝图、绘图、草图、图形、计划、文章、规格、日记、信函、电报、照片、会议记录、合同、协议、调查、计算机打印件、任何种类的数据汇编、电传、传真、语音留言、发票、订货单、支票、汇票、对账单、贷项通知单、报告、持仓报告、摘要、索引、书籍、分类账、笔记本、日程表、透明胶片、录音、目录、广告、宣传材料、影片、录像带、录音带、CD、计算机磁盘、宣传册、小册子、穿孔卡、工时单、推文、社交媒体帖子或任何其他种类的书面或录制材料，以及其所有元数据，无论以何种方式存储（无论为有形或电子形式）、记录、制作或复制；还包括但不限于上述任何材料的草稿或副本，如其载有原始文件中未见的任何种类的笔记、评论或标记，或在其他方面与原始文件不相同。\n\nCase 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 202 of 439\n\n16. “Person(s)”指个人、公司、独资企业、合伙企业、协会或任何其他实体。“Person”还包括任何代理人、代表或专家，包括但不限于律师或财务顾问。\n\n17. “Entity”指任何自然人、公司、合伙企业、子公司、独资企业、商号、董事会、合资企业、协会、机构、主管机关、委员会或其他商业实体或法人，以及任何关联方、代理人、母公司，包括但不限于法律顾问、财务顾问或任何其他代表。\n\n18. “Regarding”指涉及、描述、构成、提及、与之相关、支持、有利于、反对、强化、削弱、位于其中、结合考虑、与之有关、证明、表明、报告、记录、暗示、答复、与之相连、评论、就其而言、关于、与之有关、讨论、显示、描述、反映、分析、构成及属于。\n\n19. 当“Relating to”、“relate(s) to”或“related to”指任何特定事项时，系指包括但不限于构成、包含、涉及、含有、体现、反映、识别、陈述、直接或间接提及，或以任何方式与所识别的特定事项相关的任何文件。\n\n20. “通信”系指以最广泛的可能含义且不受限制地，任何信息或知识的传递（以事实、观点、询问或其他形式）。通信还指所有谈话、协议、询问或答复，无论是当面、通过电话、以书面形式，还是通过电子传输设备进行，并包括但不限于所有信函、电子邮件、录音、传递单、备忘录、电话通信、语音留言、电报、传真、电传副本、电传、即时消息、聊天、短信、电话记录或在内部或与第三方之间传递的记录。\n\nCase 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 203 of 439\n\n21. “资产”系指可用于产生正向经济价值的任何项目，包括但不限于由某一实体拥有、控制或为其利益而持有、且预期将提供未来利益的任何具有经济价值的资源，包括但不限于所有不动产和动产、无形财产、投资、投资权或未来收益权、现金、银行账户、商品、证券、请求权、对某一实体的全部或部分控制权，以及预期经济机会。\n\n22. “转让”应具有《破产法》第 101(54) 条赋予其的含义。\n\nIV. 应提供的文件\n\n1. 有关债务人、债务人家庭成员、债务人破产财产、关联个人或关联实体的任何收入或资产的所有文件。\n\n2. 与债务人的财务状况及其对债权人的义务有关的所有文件，包括但不限于与任何试图规避支付该等义务的行为有关的所有文件，以及与本案或任何其他实际或潜在破产或类似无力偿债程序有关的所有文件。\n\n3. 有关债务人、债务人破产财产、债务人家庭成员、关联实体或关联个人的任何资产负债表、银行对账单、账户对账单、财务报表、账户报表、电汇指示及／或确认、资金证明、存款证明、持有证明、投资组合摘要或类似文件的所有文件，包括但不限于足以显示向上述任何一方进行的所有转让的所有文件。\n\nCase 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 204 of 439\n\n4. 有关债务人、债务人家庭成员、关联个人或关联实体作出、与其进行或代表其作出的任何投资、商业往来或交易的所有文件。\n\n5. 与债务人、债务人家庭成员、关联个人或关联实体之间的所有通信，以及与同债务人、债务人家庭成员、关联个人或关联实体的通信有关的文件，包括与任何实体的运营、管理或决策有关的通信和文件，包括但不限于关联实体。\n\n6. 有关向债务人、债务人家庭成员、关联个人或关联实体作出、由其作出或与其进行的任何转让、投资或其他交易或商业往来的所有文件。\n\n7. 有关债务人曾占用或使用的任何财产的所有文件，包括但不限于位于 Connecticut（康涅狄格州）Greenwich（格林尼治）373 Taconic Rd. 的住宅物业；位于 Connecticut（康涅狄格州）Greenwich（格林尼治）33 Ferncliff Rd. 的住宅物业；位于 Connecticut（康涅狄格州）Wilton（威尔顿）354 Nod Hill Rd 的住宅物业；位于 United Kingdom（英国）London（伦敦）SW7 1QJ 5 Princes Gate 的公寓或共管公寓；以及位于 New Jersey（新泽西州）Mahwah（马瓦）675 Ramapo Valley Road, Mahwah, New Jersey 07430 的住宅物业。\n\n8. 与债务人拥有、控制或使用的任何航空器有关的所有文件，包括但不限于：(i) 尾号为 T7-GQM 的航空器及在 San Marino（圣马力诺）注册的任何其他航空器，包括但不限于所有登记文件副本及显示该等航空器所执行航班和该等航班机上人员的飞行清单；以及 (ii) 任何 Cirrus SF50 航空器。\n\nCase 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 205 of 439\n\n9. 有关向债务人、债务人破产财产、债务人家庭成员或关联实体提供、由其提供或代表其提供的任何赠与、利益或贷款的所有文件，包括但不限于足以显示该等赠与、利益或贷款金额；该等赠与、利益或贷款的使用目的；提供该等赠与、利益或贷款的时间；任何贷款的条款；就任何贷款作出的所有陈述和保证；任何贷款的利率；以及任何贷款付款的所有证据的文件。\n\n10. 有关由债务人、债务人破产财产、债务人家庭成员或关联实体设立、代表其设立、或为其利益设立的任何信托或类似文书的所有文件，包括但不限于足以显示信托设立时间、设立人、为谁的利益设立以及信托本金的文件。\n\n11. 与涉及债务人的任何法律争议相关的任何义务、请求权、责任或债务有关的所有文件，包括但不限于与在任何地方、州、联邦或国际机构前进行的任何诉讼有关的文件，无论该机构为行政机构、法院、合议庭或替代性争议解决实体。\n\n12. 与债务人、债务人家庭成员或关联个人之间的所有文件和通信。\n\n13. 你方任何律师或其他顾问与债务人、债务人家庭成员或关联个人之间的所有文件和通信。\n\nCase 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 206 of 439\n\n14. 与你方目前或曾经持有权益的任何关联实体有关的所有文件。\n\nCase 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 207 of 439\n\n证物 C-11\n\nB2540（表格 2540——规则 2004 审查传票）（12/15）Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 208 of\n\nUNITED STATES BANKRUPTCY COURT（美国破产法院）\n\nDistrict of Connecticut（康涅狄格州地区）\n\n关于 HO WAN KWOK（郭文贵）等人，\n\n1　案号 22-50073 (JAM)　债务人　第 11 章\n\n（合并管理）\n\n规则 2004 审查传票\n\n致：Lukasz Lasota（卢卡什·拉索塔）\n\n（传票所指向人员的姓名）\n\n证言：现命令你在下列规定的时间、日期和地点出席，并根据《联邦破产程序规则》第 2004 条接受审查并作证。随附准许该审查的法院命令副本。\n\n地点　日期和时间\n\nN/A　N/A\n\n审查将以以下方式记录：N/A\n\n文件提交：你或你的代表还必须在审查时携带下列文件、电子存储信息或物品，并必须准许对该等材料进行检查、复制、测试或抽样：\n\n见随附的文件提交请求。\n\n现随附 Fed. R. Civ. P. 45 的下列规定；该规则通过 Fed. R. Bankr. P. 9016 适用于破产案件——关于履行地点的第 45(c) 条；关于对作为传票对象的人员进行保护的第 45(d) 条；以及关于你对本传票作出回应的义务及未回应的潜在后果的第 45(e) 条和第 45(g) 条。\n\n日期：May , 2024\n\n法院书记员\n\n或\n\n书记员或副书记员签名　律师签名\n\n签发或请求本传票的 Luc A. Despins（卢克·A.·德斯平斯）第 11 章受托人的代理律师姓名、地址、电子邮件地址和电话号码如下：\n\nPatrick R. Linsey, Esq.（帕特里克·R.·林赛，律师）；Neubert, Pepe & Monteith, P.C.（纽伯特、佩佩及蒙蒂思专业公司）；195 Church Street, 13th Floor, New Haven, Connecticut 06510；plinsey@npmlaw.com；(203) 781-2847\n\n向签发或请求本传票之人的通知\n\n如本传票命令在审判前提交文件、电子存储信息或有形物品，或检查场所，则必须在向传票所指向人员送达之前，向每一方送达通知及本传票副本。Fed. R. Civ. P. 45(a)(4)。\n\n软件版权 (c) 1996-2022 Best Case, LLC - www.bestcase.com Best Case Bankruptcy 1 本第 11 章案件中的债务人为 Ho Wan Kwok（郭文贵）（又名 Guo Wengui（郭文贵）、Miles Guo（郭文贵）和 Miles Kwok（郭文贵），以及众多其他别名）（税务识别号码后四位：9595）、Genever Holdings LLC（杰尼弗控股有限责任公司）（税务识别号码后四位：8202）以及 Genever Holdings Corporation（杰尼弗控股公司）。受托人、Genever Holdings LLC 和 Genever Holdings Corporation 的邮寄地址为 Paul Hastings LLP（普衡律师事务所），200 Park Avenue, New York, NY 10166，c/o Luc A. Despins，作为 Ho Wan Kwok 破产财产的受托人（仅为通知和通信之目的）。\n\n送达证明\n\n（除非 Fed. R. Civ. P. 45 要求，否则本节不应向法院提交。）\n\n本人于（日期）收到向（个人姓名及职务，如有）发出的本传票。\n\n本人通过以下方式向被指定人员递交副本，以送达本传票：\n\n于（日期）；或者\n\n本人未予执行而退回本传票，原因如下：\n\n除非本传票代表 United States（美国）或其官员或代理人签发，本人还已向证人支付一天出席费用及法律允许的里程费，金额为 \\$ 。\n\n本人的差旅费用为 \\$，服务费用为 \\$，合计为 \\$。\n\n本人在伪证处罚下声明，该等信息真实、正确。\n\n日期：\n\n送达人员签名\n\n正楷姓名及职务\n\n送达人员地址\n\n关于尝试送达等的补充信息：\n\n《联邦民事诉讼规则》第 45(c)、(d)、(e) 和 (g) 条（自 12/1/13 起生效）（根据《联邦破产程序规则》第 9016 条适用于破产案件）\n\n(c) 履行地点。\n\n(1) 审判、听证或证言录取。传票仅可按以下规定命令某人出席审判、听证或证言录取：\n\n(A) 在该人居住、受雇或经常亲自从事商业活动地点 100 英里范围内；或者\n\n(B) 在该人居住、受雇或经常亲自从事商业活动所在州内，如该人：\n\n(i) 是一方当事人或一方当事人的高级职员；或者\n\n(ii) 被命令出席审判且不会产生重大费用。\n\n(2) 其他证据开示。传票可以命令：\n\n(A) 在该人居住、受雇或经常亲自从事商业活动地点 100 英里范围内的地点提交文件、电子存储信息或物品；以及\n\n(B) 在应受检查的场所检查该场所。\n\n(d) 对作为传票对象的人员进行保护；执行。\n\n(1) 避免不当负担或费用；制裁。负责签发和送达传票的一方当事人或律师必须采取合理措施，避免对作为传票对象的人员施加不当负担或费用。要求履行的地区法院必须执行该义务，并对未遵守者——当事人或律师——施加适当制裁，该制裁可包括收入损失和合理的律师费。\n\n(2) 命令提交材料或准许检查。\n\n(A) 无需出席。被命令提交文件、电子存储信息或有形物品，或准许检查场所的人员，无需亲自到提交或检查地点出席，除非同时被命令出席证言录取、听证或审判。\n\n(B) 异议。被要求出示文件或有形物品，或准许检查的人，可以向传票中指定的当事人或律师送达书面异议，反对检查、复制、测试或抽样全部或部分材料，或反对检查场所——或者反对以所要求的一种或多种形式出示以电子方式存储的信息。异议必须在指定的履行时间或传票送达后14 days两者中较早者之前送达。如提出异议，适用下列规则：\n\n(i) 送达传票的当事人可随时在通知被要求履行之人后，向要求履行的地区法院提出动议，请求作出强制出示或检查的命令。\n\n(ii) 仅可依照命令的指示要求实施这些行为，并且该命令必须保护既非当事人亦非当事人高级职员的人免于承担因履行而产生的重大费用。\n\n(3) 撤销或修改传票。\n\n(A) 必须撤销或修改的情形。应及时提出的动议，要求履行的地区法院必须撤销或修改具有下列情形的传票：\n\n(i) 未给予合理的履行时间；\n\n(ii) 要求某人在《规则》45(c)规定的地域范围以外履行；\n\n(iii) 要求披露享有特权或受其他保护的事项，而不存在适用的例外或放弃；或\n\n(iv) 使某人承受不当负担。\n\n(B) 准许撤销或修改的情形。为保护受传票约束或受其影响的人，要求履行的地区法院可应动议撤销或修改要求下列事项的传票：\n\n(i) 披露商业秘密或其他保密的研究、开发或商业信息；或\n\n(ii) 披露未受聘专家的意见或信息，该等意见或信息并非描述争议中的具体事件，且系该专家未经任何当事人请求所进行研究的成果。\n\n(C) 作为替代措施指定条件。在《规则》45(d)(3)(B)所述情形下，如送达传票的当事人：\n\n(i) 证明其对该证言或材料具有重大需要，且如不承受不当困难便无法以其他方式满足该需要；并且\n\n(ii) 确保被传唤人将获得合理补偿，\n\n法院可以不撤销或修改传票，而是命令在指定条件下出庭或出示。\n\n(e) 对传票作出回应时的义务。\n\n(1) 出示文件或以电子方式存储的信息。下列程序适用于出示文件或以电子方式存储的信息：\n\n(A) 文件。对要求出示文件的传票作出回应的人，必须按照文件在正常业务过程中保存的方式出示文件，或者必须对文件进行整理和标记，使其与请求中的类别相对应。\n\n(B) 未指定以电子方式存储的信息的出示形式。如传票未指定出示以电子方式存储的信息的形式，作出回应的人必须以该信息通常保存的一种或多种形式，或者以一种或多种合理可用的形式出示该信息。\n\n(C) 以电子方式存储的信息仅以一种形式出示。作出回应的人无需以一种以上形式出示相同的以电子方式存储的信息。\n\n(D) 无法合理访问的以电子方式存储的信息。作出回应的人无需对其认定因不当负担或费用而无法合理访问的来源中的以电子方式存储的信息提供证据开示。就强制证据开示或保护令提出动议时，作出回应的人必须证明该信息因不当负担或费用而无法合理访问。如作出该证明，法院在考虑《规则》26(b)(2)(C)的限制后，如提出请求的当事人证明具有正当理由，仍可命令对该等来源进行证据开示。法院可以就该证据开示指定条件。\n\n(2) 主张特权或保护。\n\n(A) 扣留的信息。以该信息享有特权或作为审判准备材料受保护为由扣留传票所要求信息的人必须：(i) 明确提出该主张；并且\n\n(ii) 以一种在不披露本身享有特权或受保护信息的情况下，能够使当事人评估该主张的方式，说明被扣留文件、通信或有形物品的性质。\n\n(B) 已出示的信息。如为回应传票而出示的信息被主张享有特权或作为审判准备材料受保护，提出该主张的人可以将该主张及其依据通知任何收到该信息的当事人。收到通知后，当事人必须立即返还、隔离或销毁所指定的信息及其持有的任何副本；在该主张得到解决前，不得使用或披露该信息；如该当事人在收到通知前已披露该信息，必须采取合理措施取回该信息；并可立即将该信息密封提交给要求履行的地区法院，以裁定该主张。出示该信息的人必须保存该信息，直至该主张得到解决。\n\n(g) 藐视法庭。要求履行的地区法院——以及在动议移送后，发出传票的法院——可以认定已被送达但无充分理由不遵守传票或与之相关命令的人构成藐视法庭。\n\n关于获取传票材料，见 Fed.R.Civ.P.45(a) 委员会说明（2013）\n\n……\n\n文件出示请求\n\nI. 指示\n\n1. 除非另有说明，下列文件请求（以下简称“请求”，单称“一项请求”）必须分别并具体作出回应。除非善意提出异议，否则必须完整答复每项请求；如提出异议，应依下文规定详细说明贵方异议的理由。如异议仅涉及某项请求的一部分，或其中包含的某个词语、短语或条款，贵方仅须说明对该部分的异议，并对其余请求作出回应。\n\n2. 必须按照下列指示出示以电子方式存储的信息：\n\na. 图像。黑白图像必须为300 DPI Group IV单页TIFF文件。彩色图像必须以JPEG格式出示。文件名不得包含嵌入的空格或特殊字符（包括逗号）。文件夹名称不得包含嵌入的空格或特殊字符（包括逗号）。所有TIFF图像文件必须具有唯一的文件名，即Bates编号。每一图像右下角必须标注连续的Bates编号。每个文件夹中的TIFF文件数量不得超过1000个文件。Excel电子表格应具有以该文件Bates编号命名的占位图像。\n\nb. 图像加载文件\n\na. Concordance® 数据文件。数据文件（.DAT）包含将加载至Concordance®数据库的所有字段信息。.DAT文件的第一行必须为标识字段名称的标题行。.DAT文件必须使用下列Concordance®默认分隔符：逗号 ASCII字符（020） 引号 þ ASCII字符（254）。日期字段应以如下格式提供：mm/dd/yyyy。日期字段和时间字段必须为两个单独的字段。如文件包括已生成图像的电子邮件及附件，则必须包括附件字段，以保留电子邮件与其附件之间的父/子关系。必须包括OCRPATH字段，以提供已出示存储介质上提取文本文件的文件路径和名称。文本文件必须以FIRSTBATES命名。不得在.DAT文件中包含文本。对于附有原生文件的文件，必须包括LINK字段，以提供原生文件的文件路径和名称。原生文件必须以FIRSTBATES命名。\n\nb. Concordance Image® 或 Opticon 交叉引用文件。图像交叉引用文件（.LOG或.OPT）将图像链接至数据库记录。该文件应为逗号分隔文件，每行由七个字段组成；数据库中的每个图像在交叉引用文件中均应有一行，格式如下：ImageID,VolumeLabel,ImageFilePath,DocumentBreak,FolderBreak,Box Break,PageCoun。\n\nc. 文件文本。文本必须作为单独的文本文件出示，而非作为.DAT文件内的字段。文本文件的完整路径（OCRPATH）应包含在.DAT文件中。建议提供文件级ANSI文本文件，并按FIRSTBATES/Image Key命名。提取的文本文件必须置于单独的文件夹中，每个文件夹中的文本文件数量不得超过1,000个文件。文件夹名称中不得有特殊字符（包括逗号）。必须以文件级别提供文本文件。\n\nd. 特定文件类型的原生格式出示。为充分理解其内容和含义而合理需要以原生格式查看的文件类型，必须以原生格式出示。这些文件包括但不限于电子表格、类似电子表格的文件（Microsoft Excel、逗号分隔值、制表符分隔值等）、Microsoft PowerPoint或其他特殊演示文件、数据库文件以及音频/视频文件。提供一张带有Bates编号的插页图像，表明存在原生文件，并在.dat文件中将原生文件路径作为字段包括在内。出示的原生文件应以与该文件插页相对应的Bates编号命名。将原生文件归入按递增方式命名的“NATIVE”目录中，并与图像目录分开。\n\ne. 去重。对于存在完全重复件的每份电子文件，仅出示一份副本。对于电子邮件，基于由BCC、Body、CC、From、IntMsgID、To和Attach属性生成的MD5哈希值合并重复件。对于电子邮件附件和独立电子文件，基于整个文件的MD5哈希值合并重复件。\n\nf. 元数据。以符合Concordance要求的加载文件（.dat）形式，为每份文件出示提取的元数据。.DAT文件的第一行必须为标识字段名称的标题行。.DAT文件必须使用下列Concordance默认分隔符：逗号 , ASCII字符（020） 引号 þ ASCII字符（254）\n\n日期字段应以如下格式提供：mm/dd/yyyy。日期字段和时间字段必须为两个单独的字段。以下列出所需元数据：\n\nCase 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 213 of 439\n\n字段名称　示例数据　说明\n英语>>>\n\nFIRSTBATES　EDC0000001　原生文件文档/电子邮件的首个 Bates 编号\nLASTBATES　EDC0000001　原生文件文档/电子邮件的最后一个 Bates 编号\nLASTBATES 字段应予填写\n适用于单页文件\nATTACHRANGE　EDC0000001\n-　母文件的第一页 Bates 编号\nEDC0000015　至最后一个附件“子”文件的最后一页\n文件的 Bates 编号\nBEGATTACH　EDC0000001　附件范围的首个 Bates 编号\nENDATTACH　EDC0000015　附件范围的最后一个 Bates 编号\nCUSTODIAN　Smith, John（约翰·史密斯）　电子邮件：电子邮件所在的邮箱\n原生文件：文档来源个人或部门的名称\nFROM　John Smith（约翰·史密斯）　电子邮件：发件人\n原生文件：文档作者\n多个条目之间应使用分号分隔\nTO　Coffman, Janice（贾尼斯·科夫曼）; LeeW（李W）　收件人\n[mailto:LeeW@MSN.com]　多个条目之间应使用分号分隔\nCC　Frank Thompson（弗兰克·汤普森）[mailto:　抄送收件人\nfrank_Thompson@cdt.com]　多个条目之间应使用分号分隔\nBCC　John Cain（约翰·凯恩）　密送收件人\n多个条目之间应使用分号分隔\nSUBJECT　Board Meeting Minutes（董事会会议纪要）　电子邮件：电子邮件主题行 原生文件：文档标题（如有）\nFILE_NAME　BoardMeetingMinutes.docx　原生文件：原始原生文件的名称，包括扩展名\nDATE_SENT　10/12/2010　电子邮件：电子邮件发送日期\n原生文件：（空）\nTIME_SENT/\nTIME_ZONE　07:05 PM GMT　电子邮件：电子邮件发送时间/电子邮件统一标准化所采用时区中的时间\nTIME_ZONE　GMT　转换期间电子邮件统一标准化所采用的时区。\nLINK　EDC0000001.msg　电子邮件或原生文件文档的超链接\n链接文件必须按照 FIRSTBATES 编号命名\nFILE_EXTEN　MSG　表示电子邮件或原生文件的文件类型扩展名\nAUTHOR　John Smith（约翰·史密斯）　电子邮件：（空）\n原生文件：文档作者\nDATE_CREATED　10/10/2010　电子邮件：（空）\n原生文件：文档创建日期\nCase 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 214 of 439\n\nTIME_CREATED　10:25 AM　电子邮件：（空）\n\n原生文件：文档创建时间\n该数据必须为单独字段，不得与 DATE_CREATED 字段合并\nDATE_MOD　10/12/2010　电子邮件：（空）\n原生文件：文档最后修改日期\nTIME_MOD　07:00 PM　电子邮件：（空）\n原生文件：文档最后修改时间\n该数据必须为单独字段，不得与 DATE_MOD 字段合并\nDATE_ACCESSD　10/12/2010　电子邮件：（空）\n原生文件：文档最后访问日期\nTIME_ACCESSD　07:00 PM　电子邮件：（空）\n原生文件：文档最后访问时间\n该数据必须为单独字段，不得与 DATE_ACCESSD 字段合并\nFILE_SIZE　5,952　原生文件文档/电子邮件的大小，以 KB 计\nPGCOUNT　1　原生文件文档/电子邮件的页数\nPATH　电子邮件：（空）\nAgenda.doc　原生文件：存储原生文件文档的路径，包括原始文件名。\nINTFILEPATH　Personal Folders\\Deleted　电子邮件：电子邮件的原始位置，包括\nItems\\Board Meeting　原始文件名。\nMinutes.msg　原生文件：（空）\nINTMSGID　<000805c2c71b\\$75977050\\$　电子邮件：唯一邮件 ID 原生文件：（空）\ncb8306d1@MSN>\nMD5HASH　d131dd02c5e6eec4693d9a0　文档的 MD5 哈希值。\n698aff95c\n2fcab58712467eab4004583e\nb8fb7f89\nOCRPATH　TEXT/001/EDC0000001.txt　提取的原生文件文本的路径\n\n3. 每项请求均独立适用并应被独立解释，且除非另有说明，任何一项请求均不限制任何其他请求的范围。\n\n4. 所有文件均应按其在通常业务过程中保存的方式提供，或者应整理并标注，以对应本请求中的类别。\n\n5. 本文所载的每项请求均延及所有文件：(a) 由您占有、保管或控制的文件；或 (b) 由任何代表您行事者占有、保管或控制的文件，\nCase 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 215 of 439\n\n包括您的律师或其他代表及顾问。每份文件均应完整提供。\n\n6. 如要求您提供一份已不再由您占有、保管或控制的文件，则您的答复必须：(a) 详细说明该文件的性质及其内容；(b) 确定编制或撰写该文件的人员（以及，如适用，该文件的收件人）；(c) 确定该文件编制或创建的日期；(d) 说明该文件是否：(i) 缺失或遗失，(ii) 已被销毁，(iii) 已自愿或非自愿地转移给他人，或 (iv) 已以其他方式处置；(e) 说明该等处置的理由，以及与该等处置有关的事实和情形；(f) 确定授权该等处置的人员；(g) 确定该等处置的日期或大致日期；(h) 说明该文件最近一次由您占有、保管或控制的时间；以及 (i) 确定现时占有、保管或控制该文件的人员（如有）。\n\n7. 如要求您提供一份已被销毁的文件，则除前项指示所要求的信息外，您的答复还必须说明：(a) 该文件被销毁的原因；(b) 销毁该文件的人员身份；以及 (c) 指示销毁该文件的人员身份。\n\n8. 如您主张所请求的文件享有特权或属于律师工作成果，则您的答复必须：(a) 说明：(i) 足以支持您关于该文件享有特权之主张的文件描述，(ii) 文件标题，(iii) 文件日期，(iv) 文件作者，(v) 文件收件人，(vi) 收到或阅览该文件原件或任何草稿、副本或复制件的每一人员身份，(vii) 该文件本身或该文件中所载或所提及的任何信息是否由任何其他人员占有、保管或控制，如是，则该等人员的身份，以及说明该等信息如何由其取得，(viii) 据以拒绝提供该文件的特权主张，以及 (ix) 您将据以支持该特权主张的所有情形；以及 (b) 按照 D. Conn. L. Civ. R. 26(e)，就每一份基于特权主张而拒绝提供的文件，提供一份包含本指示第 (a) 部分所要求全部信息的特权日志。\n\n9. 如一份原本应当提供的文件的一部分包含受特权主张保护的信息，则仅应按照上述指示从该文件中删除或遮蔽受特权主张保护的部分，其余部分应予提供。\n\n10. 该等请求具有持续性。特此指示您：(a) 一旦得知先前答复不完整或不正确，应立即补充或更正任何后来发现不完整或不正确的答复；以及 (b) 提供根据下列内容所要求的任何补充文件\n\n11. 如文件使用英语以外的语言，您应提供该文件。如文件使用英语以外的语言，且存在英语译文，您应同时提供两份文件。\n\n12. 对实体的所有提及均包括其所有关联方。\n\n13. 对个人姓名的所有提及均包括所有替代姓名、别名或昵称。\n\n14. 除非另有明确说明，文件请求所涵盖的期间为自 February 5, 2012 起至文件请求答复到期之日止。\nII. 解释规则\n\n15. (a) 任何单数名词的使用应解释为包括复数，反之亦然；以及 (b) 任何时态动词的使用应解释为该动词在所有其他时态中的使用。\n\n16. (a) “and”和“or”应在必要时解释为连词或选择连词，以将否则可能被解释为不在任何请求范围内的所有答复纳入该请求的范围；以及 (b) “each”和“any”应视为包括并涵盖“every”和“all”二词。\nIII. 定义\n\n根据 D. Conn. Bankr. L.R. 2004-1(a) 纳入的 D. Conn. L. Civ. R. 26(c) 所规定的定义以及 D. Conn. L. Civ. R. 26(d) 所规定的解释规则，适用于文件请求。此外，本文件请求中使用的下列术语具有以下含义：\n\n1. “您”或“您的”或“您本人”系指并指代 Lukasz Lasota（卢卡什·拉索塔），连同其所有代理人、律师、代表、雇员和/或任何代表其行事的人。\n\n2. “债务人”系指 Ho Wan Kwok（郭文贵）（又名 Miles Kwok（郭文贵）、Miles Guo（郭文贵）、Guo Wengui（郭文贵）、Guo Haoyun（郭浩云）、郭文贵或任何其他别名），连同其雇员、代理人、律师、顾问或任何代表其行事的人。\n\n3. “债务人的儿子”系指 Qiang Guo（郭强）（又名 Mileson Kwok（郭强）、郭强或任何其他别名），连同其雇员、代理人、律师、顾问或任何代表其行事的人。\n\n4. “债务人的女儿”系指 Mei Guo（郭美）（又名 Mei Gui（郭美）、郭美或任何其他别名），连同其雇员、代理人、律师、顾问或任何代表其行事的人。\nCase 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 218 of 439\n\n5. “债务人声称的妻子”系指 Hing Chi Ngok（岳庆芝）（又名 Hing Chi Ng（岳庆芝）、Yue Qingzhi（岳庆芝）、岳庆芝或任何其他别名），连同其雇员、代理人、律师、顾问或任何代表其行事的人。\n\n6. “债务人家属”统称债务人、债务人的儿子、债务人的女儿和债务人声称的妻子，以及与债务人具有任何其他亲属关系的人。\n\n7. “关联个人”系指单独或共同符合以下情形的所有个人：(1) 持有、控制、保管或对债务人或债务人家属拥有、控制或享有的资产具有酌处权；或 (2) 曾为一个或多个关联实体的雇员、董事，或以其他方式与一个或多个关联实体有关联，连同前述各方各自的雇员、代理人、律师、顾问或任何代表前述任何一方行事的人。该等关联个人包括但不限于：Anthony DiBattista（安东尼·迪巴蒂斯塔）、Alex Hadjicharalambous（亚历克斯·哈吉查拉兰布斯）、Bernardo Enriquez（贝尔纳多·恩里克斯）、Bingshang Jiao（焦冰上）、Beile Li（李蓓蕾）、Brian W. Hofmeister（布莱恩·W·霍夫迈斯特）、Charles Gruder（查尔斯·格鲁德）、Daniel Podhaskie（丹尼尔·波达斯基）、David Fallon（戴维·法伦）、Defeng Cao（曹德峰）（又名 Wayne Cao（韦恩·曹）、Max Cao（马克斯·曹））、Ding Lin（丁林）、Dinggang Wang（王定刚）（又名 王定刚）、Eduardo Eurnekian（爱德华多·尤尔内基安）、Ehsan Masud（艾山·马苏德）、Fiona Yu（菲奥娜·余）、Gladys Chow（格拉迪斯·周）、Hao (Gavin) Li（李昊〔加文〕）（又名 Huo Lai（霍来））、Hao Haidong（郝海东）（又名 郝海东）、Han Chunguang（韩春光）（又名 韩春光）、Haoran He（何浩然）、Ivan Lin（伊万·林）、Haitham Khaled（海瑟姆·哈立德）、Jason Miller（杰森·米勒）、Jennifer Mercurio（詹妮弗·默丘里奥）、Jesse Brown（杰西·布朗）、Jessica Mastrogiovanni（杰西卡·马斯特罗焦瓦尼）、Jie Zhang（张杰）、Jintao Li（李金涛）、Karin Maistrello（卡琳·迈斯特雷洛）、Kyle Bass（凯尔·巴斯）、Lihong Wei Lafrenz（魏丽红·拉弗伦茨）（又名 Sara Wei（萨拉·魏）、魏丽红）、Linwan “Irene” Feng（冯琳婉〔艾琳〕）、Max Krasner（马克斯·克拉斯纳）、Melissa Francis（梅利莎·弗朗西斯）、Michael Baranowitz（迈克尔·巴拉诺维茨）、Min Yang（杨敏）、Melissa Mendez（梅利莎·门德斯）、Nadeem Akbar（纳迪姆·阿克巴尔）、Nan Li（李楠）（又名 Chris Lee（克里斯·李）、Mei Guo Xiao Li（郭美小李））、Qidong Xia（夏启东）、Qu Guojiao（屈国姣）（又名 Qu Guo Jiao（屈国姣）、屈国姣）、Ridwan Mamode Saib（里德万·马莫德·赛义卜）、Ross Heinemeyer（罗斯·海内迈耶）、Rui “Ray” Hao（郝睿〔雷〕）、Scott Barnett（斯科特·巴尼特）、Shih Hsin Yu（史欣宇）、Shin Hee-Seup（申熙燮）（又名 Hee Seup Shin（熙燮·申））、Steve Bannon（史蒂夫·班农）、Talha Zobair（塔尔哈·佐拜尔）、Victor Cerda（维克托·塞尔达）、Wen Xiao（肖文）、Wencong Wang（王文聪）、William Gertz（威廉·格茨）、William Je（余建明）（又名 Je Kin Ming（余建明）、Yu Jianming（余建明）、余建明）以及 Xuebing Wang（王雪兵）、\nCase 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 219 of 439\n\nYa Li（李娅）（又名 李娅）、Yinying (Aila) Wang（王茵茵〔艾拉〕）（又名 Xiao Fei Xiang（小飞翔））、Yongping Yan（Shan Mu）（闫永平〔山木〕）、Yong Yu（余勇）、Yue Zhou（周越）、Yumei Hao（郝玉梅）（又名 Ru Shui（如水））、Yvette Wang（王雁平）（又名 Yanping Wang（王雁平）、Yan Ping Wang（王雁平）、王雁平）、Zhang Wei（张魏）（又名 张魏）、Zhouer Wang（王周儿）（又名 Joe Wang（乔·王））、Zhixuan Li（李志轩）以及 Ziyang Liu（刘子阳）。\n\n8. “关联实体”系指，单独或共同地，所有符合以下任一情形的任何类型组织或实体：(1) 曾由债务人或债务人家庭成员拥有、控制或投资；或 (2) 对债务人或债务人家庭成员拥有、控制或享有的任何资产直接或间接享有权益，以及前述任何主体各自的雇员、代理人、律师、顾问或代表其行事的任何人。该等关联实体包括但不限于：1332156 B.C. Ltd.（1332156 B.C.有限公司）、7 Nod Hill LLC（7 Nod Hill有限责任公司）、AAGV Limited（AAGV有限公司）、ACA Investment Management Limited（ACA投资管理有限公司）、ACA Capital Group Limited（ACA资本集团有限公司）、Ace Decade Holdings Limited（Ace Decade控股有限公司）、AI Group Holdings Inc.（AI集团控股公司）、Alfa Global Ventures Limited（Alfa全球创投有限公司）、Alfonso Global Limited（Alfonso全球有限公司）、Allied Capital Global Limited（Allied Capital全球有限公司）、Alpine Fiduciaries SA（Alpine受托服务股份公司）、Beijing Pangu Investment Co.（北京盘古投资公司）、Beijing Pangu Investment Co. Ltd.（北京盘古投资有限公司）、Beijing Pangu Investment Inc.（北京盘古投资股份公司）、Beijing Zenith Holdings Company Limited（北京Zenith控股有限公司）、Blue Capital Limited（Blue资本有限公司）、Booming Sail New York LLC（Booming Sail纽约有限责任公司）、Bravo Luck Limited（Bravo Luck有限公司）、Brent Petro（布伦特·彼得罗）、BSA Strategic Fund I（BSA战略基金I）、China Golden Spring (Hong Kong) Limited（中国金泉〈香港〉有限公司）、Chuang Xin Limited（创新有限公司）、Crane Advisory Group LLC（Crane顾问集团有限责任公司）、Creative Apex Investments Limited（Creative Apex投资有限公司）、Crystal Breeze Investments Limited（Crystal Breeze投资有限公司）、Dawn State Limited（Dawn State有限公司）、Eastern Profit Corporation Limited（Eastern Profit有限公司）、Empire Growth Holdings（Empire Growth控股）、Elite Well Global Limited（Elite Well全球有限公司）、Freedom Media Ventures Ltd.（Freedom Media Ventures有限公司）、Fung Wan Trading Inc.（Fung Wan贸易公司）、G Club（G俱乐部）、G Club Operations LLC（G俱乐部运营有限责任公司）、G Club International Limited（G俱乐部国际有限公司）、G Club Investments Limited（G俱乐部投资有限公司）、G Fashion LLC（G Fashion有限责任公司）、G-News Operations LLC（G-News运营有限责任公司）、G News LLC（G News有限责任公司）、GMusic Inc.（GMusic公司）、G-Services LLC（G-Services有限责任公司）、G-Translators PTY LTD（G-Translators专有有限公司）、GETTR USA, Inc.（GETTR美国公司）、Genever Holdings Corporation（Genever控股公司）、Genever Holdings LLC（Genever控股有限责任公司）、GFashion Media Group Inc.（GFashion媒体集团公司）、GFNY, Inc.（GFNY公司）、Globalist International Limited（Globalist国际有限公司）、GNews Media Group Inc.（GNews媒体集团公司）、Golden Spring (New York) Ltd.（Golden Spring〈纽约〉有限公司）、Guo Media（郭媒体）、GTV Media Group, Inc.（GTV媒体集团公司）、GWGOPNZ Limited（GWGOPNZ有限公司）、GWGNZ Limited（GWGNZ有限公司）、Gypsy Mei Food Services, LLC（Gypsy Mei食品服务有限责任公司）、HCHK Property Management Inc.（HCHK物业管理公司）、HCHK Technologies Inc.（HCHK科技公司）、Hamilton Digital Assets FD SP（Hamilton数字资产FD SP）、Hamilton Capital Holdings Inc.（Hamilton资本控股公司）、Hamilton Opportunity Fund SPC（Hamilton机会基金SPC）、Head Win Group Limited（Head Win集团有限公司）、Himalaya Embassy（喜马拉雅使馆）、Himalaya Exchange（喜马拉雅交易所）、Himalaya Federal Reserve（喜马拉雅联邦储备）、Himalaya International Financial Group Ltd.（喜马拉雅国际金融集团有限公司）、Himalaya Investment LLC（喜马拉雅投资有限责任公司）、Himalaya (USA) Investment Management LLC（喜马拉雅〈美国〉投资管理有限责任公司）、Himalaya New World Inc.（喜马拉雅新世界公司）、Himalaya Supervisory Organization（喜马拉雅监督组织）、Himalaya Ventures（喜马拉雅创投）、Holy City Hong Kong Ventures, Ltd.（Holy City香港创投有限公司）、Hudson Diamond Holding LLC（Hudson Diamond Holding有限责任公司）、Hudson Diamond Holding Inc.（Hudson Diamond Holding公司）、Hudson Diamond NY LLC（Hudson Diamond纽约有限责任公司）、HK International Funds Investments (USA) Limited LLC（香港国际基金投资〈美国〉有限责任公司）、Hong Kong International Funds Investments Limited（香港国际基金投资有限公司）、Huk Trading Inc（Huk贸易公司）、Infinite Increase Limited（Infinite Increase有限公司）、Infinitum Developments Limited（Infinitum开发有限公司）、Japan Himalaya League, Inc.（日本喜马拉雅联盟公司）、Kalixun Trading Limited（Kalixun贸易有限公司）、Lamp Capital LLC（Lamp资本有限责任公司）、Leading Shine Limited（Leading Shine有限公司）、Leading Shine NY Limited（Leading Shine纽约有限公司）、Lexington Property and Staffing Inc.（Lexington物业及人力配置公司）、Long Gate Limited（Long Gate有限公司）、MOS Himalaya Foundation Inc.（MOS喜马拉雅基金会公司）、Maywind Trading LLC（Maywind贸易有限责任公司）、New Federal State of China（新中国联邦国，亦称NFSC）、New York MOS Himalaya LLC（纽约MOS喜马拉雅有限责任公司）、New Mulberry PTE Ltd.（New Mulberry专有有限公司）、Newpeople LLC（Newpeople有限责任公司）、Noble Fame Global Limited（Noble Fame全球有限公司）、Pixshow Film Inc.（Pixshow电影公司）、Roscalitar 2（Roscalitar 2）、Rosy Acme Ventures Limited（Rosy Acme创投有限公司）、Rule of Law Foundation III, Inc.（法治基金会III公司）、Rule of Law Society（法治协会）、Rule of Law Society IV, Inc.（法治协会IV公司）、Santel LLC（Santel有限责任公司）、Saraca Media Group, Inc.（Saraca媒体集团公司）、Shiny Ace Ltd.（Shiny Ace有限公司）、Shiny Times Holdings Ltd.（Shiny Times控股有限公司）、Stevenson, Wong & Co.（Stevenson、Wong律师事务所）、Taurus Fund LLC（Taurus基金有限责任公司）、Taurus Fund SP（Taurus基金SP）、Taurus Management LLC（Taurus管理有限责任公司）、The Lost Draft LLC（The Lost Draft有限责任公司）、TM Primrose Limited（TM Primrose有限公司）、UA Himalaya Inc.（UA喜马拉雅公司）、Voice of Guo Media, Inc.（郭媒体之声公司）、Well Origin Ltd.（Well Origin有限公司）、Wise Creation（Wise Creation）、Whitecroft Shore Limited（Whitecroft Shore有限公司）、World Century Limited（World Century有限公司）、Worldwide Opportunity Holdings Limited（Worldwide Opportunity控股有限公司）以及ZIBA Limited（ZIBA有限公司）。\n\n案件 22-50073 文书 3193 提交于 05/16/24 登记于 05/16/24 10:28:21 第 220 页，共 439 页\n\n9. “包括”或其任何变体，是指“包括但不限于”。\n\n10. “和”及“或”是指“和/或”，并应为最大限度扩大其范围而同时作连词性及选择性解释。\n\n案件 22-50073 文书 3193 提交于 05/16/24 登记于 05/16/24 10:28:21 第 221 页，共 439 页\n\n11. “任何”及“所有”和“每一”均是指“每一项及全部”。\n\n12. “每一”及“每个”均是指“每一项及全部”。\n\n13. “第三方”是指除你方以外的个人或实体。\n\n14. “转让”具有《破产法》section 101(54)赋予该词的含义。\n\n15. “文件”是指属于Fed. R. Civ. P. 34范围内的任何信息或物品，并包括但不限于现由或曾由你方占有、保管或控制的各种种类、类型、性质或描述的每一份书面、记录或图形材料，包括电子邮件的所有纸质及电子副本、以电子形式保存的计算机文件、电子通信、短信、社交媒体帖子、推文、元数据、函件、备忘录、磁带、速记或手写笔记、任何种类的书面表格、图表、蓝图、绘图、草图、曲线图、计划、文章、规格说明、日记、信函、电报、照片、会议记录、合同、协议、调查资料、计算机打印件、任何种类的数据汇编、电传、传真、语音留言、发票、订货单、支票、汇票、对账单、贷项通知单、报告、持仓报告、摘要、索引、书籍、账簿、笔记本、附表、透明胶片、录音、目录、广告、宣传材料、电影、录像带、录音带、CD、计算机磁盘、宣传册、小册子、穿孔卡、工时单、Tweets、社交媒体帖子或任何其他种类的书面或记录材料，以及其所有元数据，无论以何种方式储存（无论为有形或电子形式）、记录、制作或复制；还包括但不限于前述任何材料的草稿或副本，若该等草稿或副本包含原始文件中未见的任何种类笔记、评论或标记，或在其他方面与原始文件并不相同。\n\n案件 22-50073 文书 3193 提交于 05/16/24 登记于 05/16/24 10:28:21 第 222 页，共 439 页\n\n16. “个人”是指个人、公司、独资企业、合伙企业、协会或任何其他实体。“个人”还包括任何代理人、代表或专家，包括但不限于律师或财务顾问。\n\n17. “实体”是指任何自然人、公司、合伙企业、子公司、独资企业、商号、董事会、合资企业、协会、机构、主管机关、委员会或其他商业实体或法人，以及任何关联方、代理人、母公司，包括但不限于法律顾问、财务顾问或任何其他代表。\n\n18. “关于”是指涉及、描述、构成、提及、与之相关、支持、有利于、反对、增强、削弱、载于、结合考虑、影响、证明、表明、报告、记录、暗指、回应、与之相连、评论、就其而言、有关、与之相关、讨论、显示、描述、反映、分析、构成及为。\n\n19. 就任何特定主题事项而言，“与……有关”、“涉及”或“相关”是指，包括但不限于，构成、包含、涉及、含有、体现、反映、识别、陈述、直接或间接提及，或以任何方式与所识别的特定主题事项有关的任何文件。\n\n20. “通信”在最广泛可能的意义上且不受限制地，是指任何信息或知识的传递（以事实、观点、询问或其他形式）。通信还指所有谈话、协议、询问或答复，无论是当面、通过电话、书面方式或借助电子传输设备进行，并包括但不限于所有函件、电子邮件、录音、传送单、备忘录、电话通信、语音留言、电报、传真、电传副本、\n\n案件 22-50073 文书 3193 提交于 05/16/24 登记于 05/16/24 10:28:21 第 223 页，共 439 页\n\n电传、即时消息、聊天、短信、电话笔记，或内部传送或与第三方传送的笔记。\n\n21. “资产”是指可用于产生正经济价值的任何项目，包括但不限于由某一实体拥有、控制或为其利益而持有并预期提供未来利益的任何具有经济价值的资源，包括但不限于所有不动产和动产、无形财产、投资、投资权或未来收入权、现金、银行账户、商品、证券、债权、对某一实体的全部或部分控制权，以及潜在经济机会\n\n22. “转让”具有《破产法》section 101(54)赋予该词的含义。\n\nIV. 应提交的文件\n\n1. 关于债务人、债务人家庭成员、债务人财产、关联个人或关联实体的任何收入或资产的所有文件。\n\n2. 与债务人的财务状况及其对债权人的义务有关的所有文件，包括但不限于与任何避免支付该等义务的努力有关的所有文件，以及与本次或任何其他实际或可能的破产或类似资不抵债程序有关的所有文件。\n\n3. 关于与债务人、债务人财产、债务人家庭成员、关联实体或关联个人有关的任何资产负债表、银行对账单、账户结单、财务报表、账户报表、电汇指示和/或确认、资金证明、存款证明、持有证明、投资组合摘要或类似文件的所有文件，包括但不限于足以显示向前述任何主体进行的所有转让的所有文件。\n\n案件 22-50073 文书 3193 提交于 05/16/24 登记于 05/16/24 10:28:21 第 224 页，共 439 页\n\n4. 关于债务人、债务人家庭成员、关联个人或关联实体作出、与其进行或代表其作出的任何投资、商业往来或交易的所有文件。\n\n5. 与债务人、债务人家庭成员、关联个人或关联实体的所有通信，以及与同债务人、债务人家庭成员、关联个人或关联实体的通信有关的文件，包括与任何实体的运营、管理或决策有关的通信，包括但不限于关联实体。\n\n6. 关于向债务人、债务人家庭成员、关联个人或关联实体作出、由其作出或与其进行的任何转让、投资或其他交易或商业往来的所有文件。\n\n7. 关于债务人曾占用或使用的任何财产的所有文件，包括但不限于位于康涅狄格州格林尼治373 Taconic Rd.的住宅物业；位于康涅狄格州格林尼治33 Ferncliff Rd.的住宅物业；位于康涅狄格州威尔顿354 Nod Hill Rd的住宅物业；位于英国伦敦SW7 1QJ 5 Princes Gate的公寓或共管公寓；以及位于新泽西州Mahwah, New Jersey 07430，675 Ramapo Valley Road的住宅物业。\n\n8. 与债务人拥有、控制或使用的任何航空器有关的所有文件，包括但不限于：(i) 尾号为T7-GQM的航空器以及在圣马力诺登记的任何其他航空器，包括但不限于所有登记文件及飞行清单的副本，该等飞行清单显示该等航空器所执行的飞行及该等航班上的人员；以及(ii) 任何Cirrus SF50航空器。\n\n案件 22-50073 文书 3193 提交于 05/16/24 登记于 05/16/24 10:28:21 第 225 页，共 439 页\n\n9. 关于向债务人、债务人财产、债务人家庭成员或关联实体提供、由其提供或代表其提供的任何赠与、利益或贷款的所有文件，包括但不限于足以显示该等赠与、利益或贷款金额的文件；该等赠与、利益或贷款的用途；提供该等赠与、利益或贷款的时间；以及任何贷款的条款、就任何贷款作出的所有陈述与保证、任何贷款的利率，以及任何贷款付款的所有证据。\n\n10. 关于由债务人、代表债务人或为债务人、债务人财产、债务人家庭成员或关联实体的利益而设立的任何信托或类似文书的所有文件，包括但不限于足以显示该等信托于何时设立、由何人设立、为谁的利益而设立以及信托财产的文件。\n\n11. 与涉及债务人的任何法律争议有关的任何义务、请求权、责任或债务相关的所有文件，包括但不限于与在任何地方、州、联邦或国际机构（无论为行政机构、法院、合议庭或替代性争议解决实体）进行的任何诉讼有关的文件。\n\n12. 与债务人、债务人家庭成员或关联个人之间的所有文件及通信。\n\n13. 您的任何律师或其他顾问与债务人、债务人家庭成员或关联个人之间的所有文件及通信。\n\n14. 与您持有或曾持有权益的任何关联实体有关的所有文件。\n\n附件 C-12\n\nB2540（表格 2540——根据规则 2004 进行审查的传票）（12/15）案号 22-50073，文件 3193，提交于 05/16/24，录入于 05/16/24 10:28:21，第 227 页，共\n\n美国破产法院\n\n康涅狄格地区\n\n关于 HO WAN KWOK（郭文贵）等人，\n\n1 案号 22-50073 (JAM) 债务人 第 11 章\n\n（合并管理）\n\n根据规则 2004 进行审查的传票\n\n致：Thomas McHale（托马斯·麦克黑尔）\n\n（传票所指向之人的姓名）\n\n证言：兹命令您于下列规定的时间、日期和地点出席，以根据《联邦破产程序规则》第 2004 条接受审查并作证。随附授权该审查的法院命令副本。\n\n地点　日期和时间\n\n不适用　不适用\n\n审查将以以下方式记录：不适用\n\n提交：您或您的代表还必须在审查时携带下列文件、电子存储信息或物品，并应允许对该等材料进行检查、复制、测试或抽样：\n\n见随附的文件提交请求。\n\n根据《联邦破产程序规则》第 9016 条适用于破产案件的《联邦民事诉讼规则》第 45 条下列规定随附于此——关于履行地点的第 45(c) 条；关于作为传票对象之人的保护的第 45(d) 条；以及关于您对本传票作出回应的义务及不履行该义务的潜在后果的第 45(e) 条和第 45(g) 条。\n\n日期：May , 2024\n\n法院书记官\n\n或\n\n书记官或副书记官签名　律师签名\n\n签发或请求本传票的、代表第 11 章受托人 Luc A. Despins（吕克·A·德斯潘斯）的律师姓名、地址、电子邮件地址及电话号码如下：\n\nPatrick R. Linsey, Esq.（帕特里克·R·林赛，律师）；Neubert, Pepe & Monteith, P.C.；195 Church Street, 13th Floor, New Haven, Connecticut 06510；plinsey@npmlaw.com；(203) 781-2847\n\n致签发或请求本传票之人的通知\n\n如本传票要求在审判前提交文件、电子存储信息或有形物品，或检查场所，则必须在向传票所指向之人送达之前，向各方送达通知及本传票副本。Fed. R. Civ. P. 45(a)(4)。\n\n软件版权所有 (c) 1996-2022 Best Case, LLC - www.bestcase.com Best Case Bankruptcy 1 本第 11 章案件中的债务人为 Ho Wan Kwok（郭文贵）（又名 Guo Wengui、Miles Guo 及 Miles Kwok，以及众多其他别名）（税务识别号码后四位：9595）、Genever Holdings LLC（税务识别号码后四位：8202）及 Genever Holdings Corporation。受托人、Genever Holdings LLC 及 Genever Holdings Corporation 的邮寄地址为 Paul Hastings LLP, 200 Park Avenue, New York, NY 10166，转交 Luc A. Despins，作为 Ho Wan Kwok（郭文贵）财产的受托人（仅为通知及通信之目的）。\n\n送达证明\n\n（除非 Fed. R. Civ. P. 45 要求，否则本节不应向法院提交。）\n\n本人于（日期）收到向（个人姓名及职务，如有）发出的本传票。\n\n本人按如下方式向所指定之人交付副本，以送达本传票：\n\n于（日期）；或\n\n本人未予执行而退回本传票，原因如下：\n\n除非本传票代表美国或其官员或代理人签发，本人还已向证人支付一天出席费用及法律允许的里程费，金额为 \\$ 。\n\n本人的旅费为 \\$ ，服务费为 \\$ ，合计为 \\$ 。\n\n本人声明，如有不实，愿受伪证罪处罚；上述信息真实且正确。\n\n日期：\n\n送达人签名\n\n正楷姓名及职务\n\n送达人地址\n\n关于尝试送达等的附加信息：\n\n《联邦民事诉讼规则》第 45(c)、(d)、(e) 及 (g) 条（自 12/1/13 生效）（根据《联邦破产程序规则》第 9016 条适用于破产案件）\n\n(c) 履行地点。\n\n(1) 审判、听证或证言录取。传票仅可按以下方式命令某人出席审判、听证或证言录取：\n\n(A) 在该人居住、受雇或经常亲自从事营业之地 100 英里范围内；或\n\n(B) 在该人居住、受雇或经常亲自从事营业所在州内，如该人\n\n(i) 是一方当事人或当事人的高级职员；或\n\n(ii) 被命令出席审判，且不会产生重大费用。\n\n(2) 其他证据开示。传票可命令：\n\n(A) 在该人居住、受雇或经常亲自从事营业之地 100 英里范围内的地点提交文件、电子存储信息或物品；以及\n\n(B) 在被检查场所对场所进行检查。\n\n(d) 对作为传票对象之人的保护；执行。\n\n(1) 避免不当负担或费用；制裁。负责签发及送达传票的当事人或律师必须采取合理措施，避免给作为传票对象之人施加不当负担或费用。要求履行的地区法院必须执行该义务，并对未遵守者的当事人或律师施加适当制裁，该制裁可包括损失的收入及合理的律师费。\n\n(2) 命令提交材料或允许检查。\n\n(A) 无须出席。被命令提交文件、电子存储信息或有形物品，或允许检查场所之人，无须亲自出席提交或检查地点，除非其亦被命令出席证言录取、听证或审判。\n\n(B) 异议。被命令提交文件或有形物品，或允许检查之人，可以向传票中指定的当事人或律师送达书面异议，反对检查、复制、测试或抽样任何或全部材料，或反对检查场所——或者反对以所要求的形式提交电子存储信息。异议必须在规定履行时间届满前或传票送达后 14 天内（以较早者为准）送达。如提出异议，则适用以下规则：\n\n(i) 在任何时候，送达人可在通知被命令之人后，向要求履行的地区法院提出动议，请求作出强制提交或检查的命令。\n\n(ii) 此类行为仅可按命令指示要求进行，且该命令必须保护既非当事人亦非当事人高级职员之人免于因履行而产生的重大费用。\n\n(3) 撤销或修改传票。\n\n(A) 必须撤销或修改的情形。经及时动议，要求履行的地区法院必须撤销或修改具有下列情形的传票：\n\n(i) 未给予合理的履行时间；\n\n(ii) 要求某人在第 45(c) 条规定的地理范围以外履行；\n\n(iii) 如无适用的例外或放弃，要求披露享有特权或受其他保护的事项；或\n\n(iv) 对某人施加不当负担。\n\n(B) 可以撤销或修改的情形。为保护作为传票对象或受传票影响之人，经动议，要求履行的地区法院可以撤销或修改要求下列事项的传票：\n\n(i) 披露商业秘密或其他保密的研究、开发或商业信息；或\n\n(ii) 披露未受聘专家的意见或信息，而该等意见或信息并不描述争议中的具体事件，且源于非由任何当事人请求进行的该专家研究。\n\n(C) 将规定条件作为替代方案。在第 45(d)(3)(B) 条所述情形下，如送达人：\n\n(i) 证明对该证言或材料具有实质性需要，且如不遭受不当困难则无法通过其他方式满足该需要；并且\n\n(ii) 确保被传唤之人将获得合理补偿，\n\n法院可以不撤销或修改传票，而是命令在规定条件下出席或提交。\n\n(e) 对传票作出回应的义务。\n\n(1) 提交文件或电子存储信息。以下程序适用于提交文件或电子存储信息：\n\n(A) 文件。对要求提交文件的传票作出回应之人，必须按照文件在通常业务过程中保存的方式提交，或者必须按照请求中的类别对其进行整理和标记。\n\n(B) 未规定电子存储信息的提交形式。如传票未规定提交电子存储信息的形式，作出回应之人必须以通常保存的形式或以合理可用的形式提交该信息。\n\n(C) 电子存储信息仅以一种形式提交。作出回应之人无须以一种以上形式提交相同的电子存储信息。\n\n(D) 无法获取的电子存储信息。作出回应之人无须提供来自其确认因不当负担或费用而无法合理获取的来源的电子存储信息的证据开示。在提出强制证据开示动议或保护令动议时，作出回应之人必须证明该信息因不当负担或费用而无法合理获取。如作出该证明，在考虑第 26(b)(2)(C) 条限制的情况下，如请求方证明有正当理由，法院仍可命令从该等来源进行证据开示。法院可以规定证据开示的条件。\n\n(2) 主张特权或保护。\n\n(A) 被扣留的信息。以该信息享有特权或作为审判准备材料受到保护为由扣留被传唤信息之人必须：(i) 明确提出该主张；并且\n\n(ii) 在不披露本身享有特权或受保护的信息的情况下，以足以使各方能够评估该主张的方式，描述被扣留文件、通信或有形物品的性质。\n\n(B) 已提交的信息。如为回应传票而提交的信息受到特权主张或作为审判准备材料受保护的主张，提出该主张之人可通知收到该信息的任何当事人该主张及其依据。收到通知后，当事人必须立即返还、隔离或销毁所指明的信息及其持有的任何副本；在该主张得到解决前不得使用或披露该信息；如当事人在收到通知前已披露该信息，必须采取合理措施取回该信息；并可立即将该信息密封提交给要求履行的地区法院，以裁定该主张。提交该信息之人必须保存该信息，直至该主张得到解决。\n\n(g) 藐视法庭。要求履行的地区法院——以及在动议被移送后，签发法院——可以认定已被送达但无充分理由不遵守传票或与其有关命令之人构成藐视法庭。\n\n如需获取传票材料，见 Fed.R.Civ.P.45(a) 委员会注释（2013）\n\n……\n文件出示请求\nI. 指示\n\n1. 除非另有说明，下列文件请求（统称“请求”，单项称“一项请求”）必须分别且具体地予以答复。除非您基于诚信提出异议，否则应完整答复每项请求；如提出异议，应按如下规定详细说明您提出异议的理由。如异议仅涉及某项请求的一部分，或其中包含的某一词语、短语或条款，您仅须就该部分说明异议，并答复其余请求。\n\n2. 电子存储信息必须按照以下指示出示：\n\n- a. 图像。黑白图像必须为 300 DPI Group IV 单页 TIFF 文件。彩色图像必须以 JPEG 格式出示。文件名不得包含嵌入空格或特殊字符（包括逗号）。文件夹名称不得包含嵌入空格或特殊字符（包括逗号）。所有 TIFF 图像文件必须具有唯一文件名，即 Bates 编号。每张图像右下角必须标注连续的 Bates 编号。每个文件夹中的 TIFF 文件不得超过 1000 个。Excel 电子表格应具有以该文件 Bates 编号命名的占位图像。\n- b. 图像加载文件\n\t- a. Concordance® 数据文件。数据文件（.DAT）包含将加载至 Concordance® 数据库的所有字段信息。.DAT 文件的第一行必须为标明字段名称的标题行。.DAT 文件必须使用以下 Concordance® 默认分隔符：逗号 ASCII 字符（020）引号 þ ASCII 字符（254）。日期字段应按以下格式提供：mm/dd/yyyy。日期和时间字段必须为两个单独字段。如文件包括已成像的电子邮件及附件，则必须包括附件字段，以保留电子邮件与其附件之间的父/子关系。必须包括 OCRPATH 字段，以提供出示的存储介质上提取文本文件的文件路径和名称。文本文件必须以 FIRSTBATES 命名。不得在 .DAT 文件中包含文本。对于含有原生文件的文件，必须包括 LINK 字段，以提供原生文件的文件路径和名称。原生文件必须以 FIRSTBATES 命名。\n\n- b. Concordance Image® 或 Opticon 交叉引用文件。图像交叉引用文件（.LOG 或 .OPT）将图像链接至数据库记录。其应为以逗号分隔的文件，每行由七个字段组成，且数据库中的每张图像在交叉引用文件中均应有一行，格式如下：ImageID,VolumeLabel,ImageFilePath,DocumentBreak,FolderBreak,Box Break,PageCount。\n- c. 文件文本。文本必须作为单独的文本文件出示，而非作为 .DAT 文件内的字段出示。文本文件的完整路径（OCRPATH）应包含在 .DAT 文件中。建议提供以 FIRSTBATES/Image Key 命名的文件级 ANSI 文本文件。提取的文本文件必须置于单独的文件夹中，每个文件夹中的文本文件不得超过 1,000 个。文件夹名称中不得含有特殊字符（包括逗号）。必须按文件级别提供文本文件。\n- d. 特定文件类型的原生格式出示。为充分理解其内容和含义而合理需要以原生格式查看的文件类型，必须以原生格式出示。此类文件包括但不限于电子表格、类似电子表格的文件（Microsoft Excel、逗号分隔值、制表符分隔值等）、Microsoft PowerPoint 或其他特殊演示文件、数据库文件以及音频/视频文件。应提供一张带有 Bates 编号的分隔页图像，注明存在原生文件，并在 .dat 文件中将原生文件路径作为字段列入。出示的原生文件应以与该文件分隔页相对应的 Bates 编号命名。原生文件应归入按递增方式命名的“NATIVE”目录，与图像目录分开。\n- e. 去重。对于存在完全重复副本的每份电子文件，仅出示一份副本。对于电子邮件，根据由 BCC、Body、CC、From、IntMsgID、To 和 Attach 属性生成的 MD5 哈希值合并重复件。对于电子邮件附件和独立电子文件，根据整个文件的 MD5 哈希值合并重复件。\n- f. 元数据。以符合 Concordance 要求的加载文件（.dat）形式，为每份文件出示提取的元数据。.DAT 文件的第一行必须为标明字段名称的标题行。.DAT 文件必须使用以下 Concordance 默认分隔符：逗号 , ASCII 字符（020）引号 þ ASCII 字符（254）\n\n日期字段应按以下格式提供：mm/dd/yyyy。日期和时间字段必须为两个单独字段。以下列出所需元数据：\n\n字段名称　示例数据　说明\n\nFIRSTBATES　EDC0000001　原生文件文件/电子邮件的第一个 Bates 编号\nLASTBATES　EDC0000001　原生文件文件/电子邮件的最后一个 Bates 编号\n**对于单页文件，应填写 LASTBATES 字段\nATTACHRANGE　EDC0000001\n-　父文件首页的 Bates 编号至最后一个附件“子”文件最后一页的 Bates 编号\nEDC0000015\nBEGATTACH　EDC0000001　附件范围的第一个 Bates 编号\nENDATTACH　EDC0000015　附件范围的最后一个 Bates 编号\nCUSTODIAN　Smith, John　电子邮件：该电子邮件所在的邮箱\n原生文件：该文件源自其文件的个人或部门名称\nFROM　John Smith　电子邮件：发件人\n原生文件：文件作者\n**多个条目之间应使用分号分隔\nTO　Coffman, Janice; LeeW　收件人\n[mailto:LeeW@MSN.com]　**多个条目之间应使用分号分隔\nCC　Frank Thompson [mailto:　抄送收件人\nfrank_Thompson@cdt.com]　**多个条目之间应使用分号分隔\nBCC　John Cain　密送收件人\n**多个条目之间应使用分号分隔\nSUBJECT　Board Meeting Minutes　电子邮件：电子邮件主题行 原生文件：文件标题（如有）\nFILE_NAME　BoardMeetingMinutes.docx　原生文件：原始原生文件的名称，包括扩展名\nDATE_SENT　10/12/2010　电子邮件：电子邮件发送日期\n原生文件：（空）\nTIME_SENT/　07:05 PM GMT　电子邮件：电子邮件发送时间/电子邮件标准化所采用的时区\nTIME_ZONE\nTIME_ZONE　GMT　在转换过程中电子邮件被标准化所采用的时区。\nLINK　EDC0000001.msg　电子邮件或原生文件文件的超链接\n**链接文件必须按 FIRSTBATES 编号命名\nFILE_EXTEN　MSG　代表电子邮件或原生文件的文件类型扩展名\nAUTHOR　John Smith　电子邮件：（空）\n原生文件：文件作者\nDATE_CREATED　10/10/2010　电子邮件：（空）\n原生文件：文件创建日期\nCase 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 233 of 439\n\nTIME_CREATED　10:25 AM　电子邮件：（空）\n\n原生文件：文件创建时间\n**该数据必须为单独字段，不得与 DATE_CREATED 字段合并\nDATE_MOD　10/12/2010　电子邮件：（空）\n原生文件：文件最后修改日期\nTIME_MOD　07:00 PM　电子邮件：（空）\n原生文件：文件最后修改时间\n**该数据必须为单独字段，不得与 DATE_MOD 字段合并\nDATE_ACCESSD　10/12/2010　电子邮件：（空）\n原生文件：文件最后访问日期\nTIME_ACCESSD　07:00 PM　电子邮件：（空）\n原生文件：文件最后访问时间\n**该数据必须为单独字段，不得与 DATE_ACCESSD 字段合并\nFILE_SIZE　5,952　原生文件文件/电子邮件的大小，以 KB 计\nPGCOUNT　1　原生文件文件/电子邮件的页数\nPATH　电子邮件：（空）\nAgenda.doc　原生文件：存储原生文件文件的路径，包括原始文件名。\nINTFILEPATH　Personal Folders\\Deleted　电子邮件：电子邮件的原始位置，包括原始文件名。\nItems\\Board Meeting\nMinutes.msg　原生文件：（空）\nINTMSGID　<000805c2c71b\\$75977050\\$　电子邮件：唯一邮件 ID 原生文件：（空）\ncb8306d1@MSN>\nMD5HASH　d131dd02c5e6eec4693d9a0　文件的 MD5 哈希值。\n698aff95c\n2fcab58712467eab4004583e\nb8fb7f89\nOCRPATH　TEXT/001/EDC0000001.txt　原生文件提取文本的路径\n\n3. 每项请求独立适用并应被独立解释；除非另有说明，任何一项请求均不限制任何其他请求的范围。\n\n4. 所有文件应按其在日常业务过程中保存的方式出示，或者应整理并标注以对应这些请求中的类别。\n\n5. 本文所载每项请求均延及所有文件：(a) 在您占有、保管或控制之下的文件；或 (b) 在任何代表您行事者占有、保管或控制之下的文件，\nCase 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 234 of 439\n\n包括您的律师或其他代表及顾问。每份文件均应完整出示。\n\n6. 如要求您出示的某份文件已不再处于您的占有、保管或控制之下，则您的答复必须：(a) 详细描述该文件的性质及其内容；(b) 识别编制或撰写该文件的人士（以及，如适用，识别该文件被发送给的人士）；(c) 识别该文件编制或创建的日期；(d) 说明该文件是否：(i) 遗失或丢失，(ii) 已被销毁，(iii) 已自愿或非自愿地转移给他人，或 (iv) 已以其他方式处置；(e) 说明该等处置的理由以及有关事实和情形；(f) 识别授权该等处置的人士；(g) 识别该等处置的日期或大致日期；(h) 说明该文件最后一次处于您的占有、保管或控制之下的时间；以及 (i) 识别目前占有、保管或控制该文件的人士（如有）。\n\n7. 如要求您出示的某份文件已被销毁，则除前述指示所要求的信息外，您的答复还必须说明：(a) 销毁该文件的理由；(b) 销毁该文件的人士身份；以及 (c) 指示销毁该文件的人士身份。\n\n8. 如您主张被请求的文件享有特权或属于律师工作成果，则您的答复必须：(a) 说明：(i) 足以支持您关于该文件享有特权之主张的文件描述，(ii) 文件标题，(iii) 文件日期，(iv) 文件作者，(v) 文件收件人，(vi) 收到或看过该文件原件或任何草稿、副本或复制件的每一人士身份，(vii) 该文件本身或文件中包含或提及的任何信息是否处于任何其他人士的占有、保管或控制之下；如是，说明该等人士身份，以及说明该信息如何进入其占有，(viii) 据以拒绝提供该文件的特权主张，以及 (ix) 您将据以支持该等特权主张的所有情形；以及 (b) 根据 D. Conn. L. Civ. R. 26(e)，就基于特权主张而扣留的每份文件，出示一份特权日志，其中载明本指示第 (a) 部分所要求的全部信息。\nCase 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 235 of 439\n\n9. 如原本应答复的文件的一部分包含受特权主张约束的信息，则仅应按照上述指示从该文件中删除或遮蔽受特权主张约束的该部分，其余部分应予出示。\n\n10. 该等请求具有持续性。兹指示您：(a) 一旦知悉先前答复不完整或不正确，应立即补充或更正任何后来发现不完整或不正确的答复；以及 (b) 提供根据\n\n11. 如文件使用英语以外的语言，您应提供该文件。如文件使用英语以外的语言，且存在英文译本，您应同时提供两份文件。\n\n12. 对实体的一切提及均包括其所有关联方。\n\n13. 对个人姓名的一切提及均包括所有其他名称、别名或昵称。\n\n14. 除非另有明确说明，文件请求所涵盖的期间为自 February 5, 2012 起至文件请求答复到期之日止。\nII. 解释规则\n\n15. (a) 任何单数名词的使用应解释为包括复数，反之亦然；及 (b) 任何时态动词的使用应解释为包括该动词在所有其他时态中的使用。\n\n16. (a) “and”和“or”应按必要情况解释为连词或析取词，以使任何请求的范围涵盖本可能被解释为不在其范围内的所有答复；及 (b) “each”和“any”应视为包括并涵盖“every”和“all”二词。\nIII. 定义\n\n经 D. Conn. Bankr. L.R. 2004-1(a) 纳入的 D. Conn. L. Civ. R. 26(c) 所规定的定义以及 D. Conn. L. Civ. R. 26(d) 所规定的解释规则，适用于文件请求。此外，本文件请求中使用的下列术语具有如下含义：\n\n1. “You”或“Your”或“Yourself”系指 Thomas McHale（托马斯·麦克黑尔），连同其所有代理人、律师、代表、雇员和/或任何代表其行事之人。\n\n2. “Debtor”系指 Ho Wan Kwok（郭文贵）（又名 Miles Kwok、Miles Guo、Guo Wengui、Guo Haoyun、郭文贵或任何其他别名），连同其雇员、代理人、律师、顾问或任何代表其行事之人。\n\n3. “Debtor's Son”系指 Qiang Guo（郭强）（又名 Mileson Kwok、郭强或任何其他别名），连同其雇员、代理人、律师、顾问或任何代表其行事之人。\n案件 22-50073 文书 3193 于 05/16/24 提交 于 05/16/24 10:28:21 登记 第 237 页，共 439 页\n\n4. “Debtor's Daughter”系指 Mei Guo（郭美）（又名 Mei Gui、郭美或任何其他别名），连同其雇员、代理人、律师、顾问或任何代表其行事之人。\n\n5. “Debtor's Purported Wife”系指 Hing Chi Ngok（岳庆芝）（又名 Hing Chi Ng、Yue Qingzhi、岳庆芝或任何其他别名），连同其雇员、代理人、律师、顾问或任何代表其行事之人。\n\n6. “Debtor's Family”合称债务人、债务人之子、债务人之女及债务人之自称妻子，以及与债务人具有任何其他亲属关系之人。\n\n7. “Associated Individuals”系指个别及合称下列所有个人：(1) 持有、控制、保管或对债务人或债务人家庭拥有、控制或享有的资产具有处置权者；或 (2) 曾任或现任一个或多个关联实体的雇员、董事，或以其他方式与其有关联者，连同前述各方各自的雇员、代理人、律师、顾问或任何代表其行事之人。该等关联个人包括但不限于：Anthony DiBattista（安东尼·迪巴蒂斯塔）、Alex Hadjicharalambous（亚历克斯·哈吉查拉兰布斯）、Bernardo Enriquez（贝尔纳多·恩里克斯）、Bingshang Jiao（焦炳尚）、Beile Li（李贝乐）、Brian W. Hofmeister（布赖恩·W·霍夫迈斯特）、Charles Gruder（查尔斯·格鲁德）、Daniel Podhaskie（丹尼尔·波德哈斯基）、David Fallon（大卫·法伦）、Defeng Cao（曹德峰）（又名 Wayne Cao、Max Cao）、Ding Lin（丁林）、Dinggang Wang（王定刚）（又名 王定刚）、Eduardo Eurnekian（爱德华多·欧尔内基安）、Ehsan Masud（埃赫桑·马苏德）、Fiona Yu（余菲奥娜）、Gladys Chow（周格拉迪斯）、Hao (Gavin) Li（李浩）（又名 Huo Lai）、Hao Haidong（郝海东）（又名 郝海东）、Han Chunguang（韩春光）（又名 韩春光）、Haoran He（何浩然）、Ivan Lin（林艾文）、Haitham Khaled（海瑟姆·哈立德）、Jason Miller（杰森·米勒）、Jennifer Mercurio（詹妮弗·梅尔库里奥）、Jesse Brown（杰西·布朗）、Jessica Mastrogiovanni（杰西卡·马斯特罗焦瓦尼）、Jie Zhang（张杰）、Jintao Li（李金涛）、Karin Maistrello（卡琳·迈斯特雷洛）、Kyle Bass（凯尔·巴斯）、Lihong Wei Lafrenz（魏丽红）（又名 Sara Wei、魏丽红）、Linwan “Irene” Feng（冯林婉）、Max Krasner（马克斯·克拉斯纳）、Melissa Francis（梅利莎·弗朗西斯）、Michael Baranowitz（迈克尔·巴拉诺维茨）、Min Yang（杨敏）、Melissa Mendez（梅利莎·门德斯）、Nadeem Akbar（纳迪姆·阿克巴尔）、Nan Li（李楠）（又名 Chris Lee、Mei Guo Xiao Li）、Qidong Xia（夏启东）、Qu Guojiao（屈国姣）（又名 Qu Guo Jiao、屈国姣）、Ridwan Mamode Saib（里德万·马莫德·赛义卜）、Ross Heinemeyer（罗斯·海内迈耶）、Rui “Ray” Hao（郝睿）、Scott Barnett（斯科特·巴尼特）、Shih Hsin Yu（余世新）、Shin Hee-\n案件 22-50073 文书 3193 于 05/16/24 提交 于 05/16/24 10:28:21 登记 第 238 页，共 439 页\n\nSeup（申熙燮）（又名 Hee Seup Shin）、Steve Bannon（史蒂夫·班农）、Talha Zobair（塔尔哈·佐拜尔）、Victor Cerda（维克托·塞尔达）、Wen Xiao（肖文）、Wencong Wang（王文聪）、William Gertz（威廉·格茨）、William Je（余建明）（又名 Je Kin Ming、Yu Jianming、余建明）、Xuebing Wang（王雪冰）、Ya Li（李娅）（又名 李娅）、Yinying (Aila) Wang（王音莹）（又名 Xiao Fei Xiang）、Yongping Yan（阎永平）（Shan Mu）、Yong Yu（余勇）、Yue Zhou（周玥）、Yumei Hao（郝玉梅）（又名 Ru Shui）、Yvette Wang（王雁平）（又名 Yanping Wang、Yan Ping Wang、王雁平）、Zhang Wei（张魏）（又名 张魏）、Zhouer Wang（王周二）（又名 Joe Wang）、Zhixuan Li（李志轩）及 Ziyang Liu（刘子洋）。\n\n8. “Associated Entities”系指个别及合称下列所有任何类型的组织或实体：(1) 曾由债务人或债务人家庭拥有、控制或投资的组织或实体；或 (2) 对债务人或债务人家庭拥有、控制或享有的任何资产直接或间接拥有权益的组织或实体，连同前述各方各自的雇员、代理人、律师、顾问或任何代表其行事之人。该等关联实体包括但不限于：1332156 B.C. Ltd.、7 Nod Hill LLC、AAGV Limited、ACA Investment Management Limited、ACA Capital Group Limited、Ace Decade Holdings Limited、AI Group Holdings Inc.、Alfa Global Ventures Limited、Alfonso Global Limited、Allied Capital Global Limited、Alpine Fiduciaries SA、Beijing Pangu Investment Co.（北京盘古投资公司）、Beijing Pangu Investment Co. Ltd.（北京盘古投资有限公司）、Beijing Pangu Investment Inc.（北京盘古投资公司）、Beijing Zenith Holdings Company Limited（北京鼎辉控股有限公司）、Blue Capital Limited、Booming Sail New York LLC、Bravo Luck Limited、Brent Petro、BSA Strategic Fund I、China Golden Spring (Hong Kong) Limited（中国金泉〈香港〉有限公司）、Chuang Xin Limited、Crane Advisory Group LLC、Creative Apex Investments Limited、Crystal Breeze Investments Limited、Dawn State Limited、Eastern Profit Corporation Limited、Empire Growth Holdings、Elite Well Global Limited、Freedom Media Ventures Ltd.、Fung Wan Trading Inc.、G Club、G Club Operations LLC、G Club International Limited、G Club Investments Limited、G Fashion LLC、G-News Operations LLC、G News LLC、GMusic Inc.、G-Services LLC、G-Translators PTY LTD、GETTR USA, Inc.、Genever Holdings Corporation、Genever Holdings\n案件 22-50073 文书 3193 于 05/16/24 提交 于 05/16/24 10:28:21 登记 第 239 页，共 439 页\n\nLLC、GFashion Media Group Inc.、GFNY, Inc.、Globalist International Limited、GNews Media Group Inc.、Golden Spring (New York) Ltd.、Guo Media、GTV Media Group, Inc.、GWGOPNZ Limited、GWGNZ Limited、Gypsy Mei Food Services, LLC、HCHK Property Management Inc.、HCHK Technologies Inc.、Hamilton Digital Assets FD SP、Hamilton Capital Holdings Inc.、Hamilton Opportunity Fund SPC、Head Win Group Limited、Himalaya Embassy、Himalaya Exchange、Himalaya Federal Reserve、Himalaya International Financial Group Ltd.、Himalaya Investment LLC、Himalaya (USA) Investment Management LLC、Himalaya New World Inc.、Himalaya Supervisory Organization、Himalaya Ventures、Holy City Hong Kong Ventures, Ltd.、Hudson Diamond Holding LLC、Hudson Diamond Holding Inc.、Hudson Diamond NY LLC、HK International Funds Investments (USA) Limited LLC、Hong Kong International Funds Investments Limited、Huk Trading Inc、Infinite Increase Limited、Infinitum Developments Limited、Japan Himalaya League, Inc.、Kalixun Trading Limited、Lamp Capital LLC、Leading Shine Limited、Leading Shine NY Limited、Lexington Property and Staffing Inc.、Long Gate Limited、MOS Himalaya Foundation Inc.、Maywind Trading LLC、New Federal State of China（新中国联邦）（又名 NFSC）、New York MOS Himalaya LLC、New Mulberry PTE Ltd.、Newpeople LLC、Noble Fame Global Limited、Pixshow Film Inc.、Roscalitar 2、Rosy Acme Ventures Limited、Rule of Law Foundation III, Inc.、Rule of Law Society、Rule of Law Society IV, Inc.、Santel LLC、Saraca Media Group, Inc.、Shiny Ace Ltd.、Shiny Times Holdings Ltd.、Stevenson, Wong & Co.、Taurus Fund LLC、Taurus Fund SP、Taurus Management LLC、The Lost Draft LLC、TM Primrose Limited、UA Himalaya Inc.、Voice of Guo Media, Inc.、Well Origin Ltd.、Wise Creation、Whitecroft Shore Limited、World Century Limited、Worldwide Opportunity Holdings Limited 及 ZIBA Limited。\n\n9. “Including”或其任何变体意为“包括但不限于”。\n案件 22-50073 文书 3193 于 05/16/24 提交 于 05/16/24 10:28:21 登记 第 240 页，共 439 页\n\n10. “And”和“or”意为“and/or”，并应同时按连词及析取词解释，以最大化其范围。\n\n11. “Any”、“all”和“each”意为“每一及所有”。\n\n12. “Each”和“every”意为“每一及所有”。\n\n13. “Third Party”系指除您本人以外的个人或实体。\n\n14. “Transfer”具有《破产法》section 101(54) 所赋予的含义。\n\n15. “Document”系指属于 Fed. R. Civ. P. 34 范围内的任何信息或物品，包括但不限于任何种类、类型、性质或描述的每一项书面、记录或图形材料，该等材料现由或曾由您占有、保管或控制，包括电子邮件的所有印刷及电子副本、以电子形式保存的计算机文件、电子通信、短信、社交媒体帖子、推文、元数据、往来函件、备忘录、磁带、速记或手写笔记、任何种类的书面表格、图表、蓝图、绘图、草图、图形、计划、文章、规格、日记、信函、电报、照片、会议记录、合同、协议、调查、计算机打印输出、任何种类的数据汇编、电传、传真、语音信息、发票、订货单、支票、汇票、账单、贷项通知单、报告、持仓报告、摘要、索引、账簿、分类账、笔记本、时间表、投影片、录音、目录、广告、宣传材料、影片、录像带、录音带、CD、计算机磁盘、宣传册、小册子、穿孔卡、工时单、推文、社交媒体帖子或任何其他种类的书面或记录材料，以及其所有元数据，无论其如何存储（无论以有形或电子形式）、记录、制作或复制，并且还包括但不限于前述任何材料的草稿或副本，而该等草稿或副本包含原始文件中不存在的任何种类笔记、评论或标记，或在其他方面与原始文件不相同。\n案件 22-50073 文书 3193 于 05/16/24 提交 于 05/16/24 10:28:21 登记 第 241 页，共 439 页\n\n16. “Person(s)”系指个人、公司、独资企业、合伙企业、协会或任何其他实体。“Person”还包括任何代理人、代表或专家，包括但不限于律师或财务顾问。\n\n17. “Entity”系指任何自然人、公司、合伙企业、子公司、独资企业、商号、董事会、合资企业、协会、机构、主管机关、委员会或其他商业实体或法人，以及任何关联方、代理人、母公司，包括但不限于法律顾问、财务顾问或任何其他代表。\n\n18. “Regarding”意为有关、描述、包含、提及、与之相关、支持、有利于、反对、加强、减损、位于其中、在关联下予以考虑、与之有关、证明、表明、报告、记录、暗示、回应、与之连接、评论、就其而言、关于、与之有关、讨论、显示、描述、反映、分析、构成及属于。\n\n19. 就任何特定主题而言，“Relating to”、“relate(s) to”或“related to”意为，包括但不限于，构成、包含、涉及、载有、体现、反映、识别、陈述、直接或间接提及，或以任何方式与所识别的特定主题相关的任何文件。\n\n20. “通信”系指在最广泛可能意义上且不受限制地，任何信息或知识的传递（以事实、观点、询问或其他形式）。通信还指所有谈话、协议、询问或答复，无论是当面、通过电话、以书面形式，还是通过电子传输设备进行，并包括但不限于所有信函、电子邮件、录音、传送\n\n案件 22-50073 文件 3193 提交日期 05/16/24 录入日期 05/16/24 10:28:21 第 242 页，共 439 页\n\n单、备忘录、电话通信、语音留言、电报、传真、影印传真、电传、即时消息、聊天、短信、电话记录，或在内部或与第三方之间传递的记录。\n\n21. “资产”系指任何可用于产生正面经济价值的项目，包括但不限于由某实体拥有、控制或为某实体利益而持有、并预期提供未来利益的任何具有经济价值的资源，包括但不限于所有不动产和动产、无形财产、投资、投资权或未来收入权、现金、银行账户、商品、证券、债权、对实体的全部或部分控制权，以及预期的经济机会。\n\n22. “转让”应具有《破产法典》第 101(54) 条赋予该词的含义。\n\nIV. 应提交的文件\n\n1. 与债务人、债务人的家庭成员、债务人的破产财产、关联个人或关联实体的任何收入或资产有关的所有文件。\n\n2. 与债务人的财务状况及其对债权人的义务有关的所有文件，包括但不限于与为避免支付该等义务所作任何努力有关的所有文件，以及与本次或任何其他实际或潜在的破产或类似无力偿债程序有关的所有文件。\n\n3. 与债务人、债务人的破产财产、债务人的家庭成员、关联实体、\n\n案件 22-50073 文件 3193 提交日期 05/16/24 录入日期 05/16/24 10:28:21 第 243 页，共 439 页\n\n或关联个人有关的任何资产负债表、银行对账单、账户对账单、财务报表、账户报表、电汇指示和／或确认、资金证明、存款证、持有证明、投资组合摘要或类似文件有关的所有文件，包括但不限于足以显示向上述任何一方进行的所有转让的所有文件。\n\n4. 与债务人、债务人的家庭成员、关联个人或关联实体作出、与之进行或代表其进行的任何投资、商业往来或交易有关的所有文件。\n\n5. 与债务人、债务人的家庭成员、关联个人或关联实体之间的所有通信，以及与债务人、债务人的家庭成员、关联个人或关联实体之间通信有关的文件，包括与任何实体的运营、管理或决策有关的通信和文件，包括但不限于关联实体。\n\n6. 与向债务人、债务人的家庭成员、关联个人或关联实体作出、由其作出或与其进行的任何转让、投资、其他交易或商业往来有关的所有文件。\n\n7. 与债务人曾经占用或使用的任何财产有关的所有文件，包括但不限于位于 Connecticut（康涅狄格州）Greenwich（格林尼治）373 Taconic Rd. 的住宅房产；位于 Connecticut（康涅狄格州）Greenwich（格林尼治）33 Ferncliff Rd. 的住宅房产；位于 Connecticut（康涅狄格州）Wilton（威尔顿）354 Nod Hill Rd 的住宅房产；位于 United Kingdom（英国）London（伦敦）SW7 1QJ，5 Princes Gate 的公寓或产权公寓；以及位于 New Jersey（新泽西州）Mahwah（马瓦）675 Ramapo Valley Road, Mahwah, New Jersey 07430 的住宅房产。\n\n8. 与债务人拥有、控制或使用的任何飞机有关的所有文件，包括但不限于：(i) 尾号为 T7-GQM 的飞机以及在 San Marino（圣马力诺）注册的任何其他飞机，包括但不限于所有登记文件副本及显示该等飞机所执行航班和该等航班乘机人员的飞行清单；以及 (ii) 任何 Cirrus SF50 飞机。\n\n案件 22-50073 文件 3193 提交日期 05/16/24 录入日期 05/16/24 10:28:21 第 244 页，共 439 页\n\n9. 与向债务人、债务人的破产财产、债务人的家庭成员或关联实体提供、由其提供或代表其提供的任何赠与、利益或贷款有关的所有文件，包括但不限于足以显示该等赠与、利益或贷款金额；该等赠与、利益或贷款的用途；提供该等赠与、利益或贷款的时间；任何贷款的条款；就任何贷款作出的所有陈述和保证；任何贷款的利率；以及任何贷款付款的所有证据的文件。\n\n10. 与由债务人、债务人的破产财产、债务人的家庭成员或关联实体设立、代表其设立或为其利益而设立的任何信托或类似文书有关的所有文件，包括但不限于足以显示该等信托设立的时间、设立人、为谁的利益而设立以及信托本金的文件。\n\n11. 与涉及债务人的任何法律争议相关的任何义务、债权、责任或债务有关的所有文件，包括但不限于与任何地方、州、联邦或国际机构前的任何诉讼有关的文件，无论该机构为行政机关、法院、合议机构或替代性争议解决实体。\n\n12. 与债务人、债务人的家庭成员或关联个人之间的所有文件和通信。\n\n13. 你方任何律师或其他顾问与债务人、债务人的家庭成员或关联个人之间的所有文件和通信。\n\n案件 22-50073 文件 3193 提交日期 05/16/24 录入日期 05/16/24 10:28:21 第 245 页，共 439 页\n\n14. 与你方目前或曾经持有权益的任何关联实体有关的所有文件。\n\n附件 C-13\n\nB2540（表格 2540－《规则 2004 审查传票》）（12/15）案件 22-50073 文件 3193 提交日期 05/16/24 录入日期 05/16/24 10:28:21 第 247 页，共\n\nUNITED STATES BANKRUPTCY COURT（美国破产法院）\n\nDistrict of Connecticut（康涅狄格州地区）\n\n关于 HO WAN KWOK（郭文贵）等人\n\n1 案件编号 22-50073 (JAM) 债务人 第 11 章\n\n（合并管理）\n\n规则 2004 审查传票\n\n致：Sean Lynch（肖恩·林奇）\n\n（传票所指向之人的姓名）\n\n证言：现命令你于下列载明的时间、日期和地点出席，并根据《联邦破产程序规则》规则 2004 在审查中作证。随附准许该审查的法院命令副本。\n\n地点　日期和时间\n\nN/A　N/A\n\n审查将通过以下方式记录：N/A\n\n提交：你或你的代表还必须携带下列文件、电子存储信息或物品参加审查，并必须准许对该等材料进行查阅、复制、测试或取样：\n\n见随附的文件提交请求。\n\n《联邦民事诉讼规则》规则 45 的下列规定根据《联邦破产程序规则》规则 9016 适用于破产案件，现随附于后——与履行地点有关的规则 45(c)；与你作为受传票约束之人的保护有关的规则 45(d)；以及与你对本传票的答复义务和未答复的潜在后果有关的规则 45(e) 和 45(g)。\n\n日期：May , 2024\n\n法院书记员\n\n或\n\n书记员或副书记员签名　律师签名\n\n签发或请求本传票、代表第 11 章受托人 Luc A. Despins（吕克·A·德斯潘）的律师姓名、地址、电子邮件地址和电话号码如下：\n\nPatrick R. Linsey, Esq.（帕特里克·R·林赛律师）；Neubert, Pepe & Monteith, P.C.；195 Church Street, 13th Floor, New Haven, Connecticut 06510；plinsey@npmlaw.com；(203) 781-2847\n\n致签发或请求本传票之人的通知\n\n如本传票命令在审判前提交文件、电子存储信息或有形物品，或检查场所，则在向传票所指向之人送达之前，必须向各方送达通知和本传票副本。Fed. R. Civ. P. 45(a)(4)。\n\n软件版权 (c) 1996-2022 Best Case, LLC（贝斯特凯斯有限责任公司）- www.bestcase.com Best Case Bankruptcy 1 本第 11 章案件中的债务人为 Ho Wan Kwok（郭文贵，亦称 Guo Wengui、Miles Guo 和 Miles Kwok，以及众多其他别名）（税务识别号码后四位：9595）、Genever Holdings LLC（税务识别号码后四位：8202）及 Genever Holdings Corporation。受托人、Genever Holdings LLC 和 Genever Holdings Corporation 的邮寄地址为 Paul Hastings LLP，200 Park Avenue, New York, NY 10166，c/o Luc A. Despins，作为 Ho Wan Kwok 破产财产的受托人（仅为通知和通信之目的）。\n\n送达证明\n\n（除非 Fed. R. Civ. P. 45 要求，否则本节不应向法院提交。）\n\n我于（日期）收到针对（个人姓名及职务，如有）的本传票。\n\n我以如下方式向指定人员递送副本，完成传票送达：\n\n于（日期）；或\n\n我未执行本传票而将其退回，原因如下：\n\n除非本传票系代表 United States（美国）或其官员或代理人签发，我还已向证人支付一天出席费用及法律允许的里程费，金额为 \\$ 。\n\n我的差旅费用为 \\$ ，服务费用为 \\$ ，合计 \\$ 。\n\n我在伪证处罚的约束下声明，本信息真实且正确。\n\n日期：\n\n送达人员签名\n\n正楷姓名及职务\n\n送达人员地址\n\n关于尝试送达等的补充信息：\n\n《联邦民事诉讼规则》规则 45(c)、(d)、(e) 和 (g)（Effective 12/1/13）（根据《联邦破产程序规则》规则 9016 适用于破产案件）\n\n(c) 履行地点。\n\n(1) 审判、听证或证言录取。传票仅可按下列方式命令人员出席审判、听证或证言录取：\n\n(A) 在该人员居住、受雇或经常亲自从事商业活动地点 100 英里范围内；或\n\n(B) 在该人员居住、受雇或经常亲自从事商业活动所在州内，前提是该人员：\n\n(i) 为当事人或当事人的高级职员；或\n\n(ii) 被命令出席审判，且不会产生重大费用。\n\n(2) 其他证据开示。传票可命令：\n\n(A) 在该人员居住、受雇或经常亲自从事商业活动地点 100 英里范围内的某一地点提交文件、电子存储信息或物品；以及\n\n(B) 在待检查场所对该场所进行检查。\n\n(d) 对受传票约束之人的保护；执行。\n\n(1) 避免不当负担或费用；制裁。负责签发和送达传票的当事人或律师必须采取合理措施，避免对受传票约束之人施加不当负担或费用。要求履行义务所在地区的法院必须执行该义务，并对未遵守者的当事人或律师施加适当制裁，该制裁可包括损失的收入和合理的律师费。\n\n(2) 命令提交材料或准许检查。\n\n(A) 无须出席。被命令提交文件、电子存储信息或有形物品，或准许检查场所的人员，除非同时被命令出席证言录取、听证或审判，否则无须亲自到提交或检查地点出席。\n\n(B) 异议。被命令提交文件或有形物品，或准许检查的人员，可向传票中指定的当事人或律师送达书面异议，反对检查、复制、测试或取样任何或全部材料，或反对检查场所，或反对以所要求的一种或多种形式提交电子存储信息。异议必须在规定履行时间之前或传票送达后 14 天之前（以较早者为准）送达。如提出异议，则适用下列规则：\n\n(i) 在任何时候，送达方均可在通知被命令人后，向要求履行的地区的法院提出动议，请求作出强制提交或检查的命令。\n\n(ii) 仅可按照命令所指示的方式要求实施该等行为，且该命令必须保护并非当事人或当事人高级职员的人免于因履行而产生的重大费用。\n\n(3) 撤销或修改传票。\n\n(A) 必须撤销或修改的情形。对于及时提出的动议，要求履行的地区的法院必须撤销或修改具有下列情形的传票：\n\n(i) 未给予合理的履行时间；\n\n(ii) 要求某人在 Rule 45(c) 规定的地域限制之外履行；\n\n(iii) 要求披露享有特权或受其他保护的事项，且不存在任何例外或豁免；或\n\n(iv) 使某人承受不当负担。\n\n(B) 可以撤销或修改的情形。为保护受传票约束或受传票影响的人，要求履行的地区的法院可以根据动议，在传票要求下列事项时撤销或修改传票：\n\n(i) 披露商业秘密或其他保密的研究、开发或商业信息；或\n\n(ii) 披露未受聘专家的意见或信息，该等意见或信息并非描述争议中的具体事件，且系该专家未经任何一方当事人请求而进行研究所得。\n\n(C) 将规定条件作为替代方案。在 Rule 45(d)(3)(B) 所述情形下，如送达方：\n\n(i) 证明其对该证言或材料具有重大需要，且如不遭受不当困难则无法通过其他方式满足该需要；并且\n\n(ii) 确保被传唤人将获得合理补偿，\n\n法院可以不撤销或修改传票，而是在规定条件下命令出庭或提交。\n\n(e) 回应传票的义务。\n\n(1) 提交文件或电子存储信息。下列程序适用于提交文件或电子存储信息：\n\n(A) 文件。回应要求提交文件的传票的人，必须按照其在正常业务过程中保存的方式提交文件，或者必须将文件整理并标记为与请求中的类别相对应。\n\n(B) 未指定电子存储信息提交形式。如传票未指定电子存储信息的提交形式，回应人必须以其通常保存的一种或多种形式，或者以合理可使用的一种或多种形式提交该信息。\n\n(C) 电子存储信息仅以一种形式提交。回应人无需以多于一种形式提交相同的电子存储信息。\n\n(D) 不可合理访问的电子存储信息。回应人无需提供来自其认定为因不当负担或费用而不可合理访问的信息来源的电子存储信息的证据开示。在强制证据开示动议或保护令动议中，回应人必须证明该信息因不当负担或费用而不可合理访问。如作出该证明，法院在考虑 Rule 26(b)(2)(C) 的限制后，如请求方证明有正当理由，仍可命令从该等来源进行证据开示。法院可以规定证据开示的条件。\n\n(2) 主张特权或保护。\n\n(A) 扣留的信息。以信息享有特权或作为审判准备材料受保护为由扣留被传唤信息的人必须：(i) 明确提出该主张；并且\n\n(ii) 以一种在不披露本身享有特权或受保护的信息的情况下，使各方能够评估该主张的方式，描述被扣留文件、通信或有形物品的性质。\n\n(B) 已提交的信息。如为回应传票而提交的信息受到特权主张或作为审判准备材料受保护的主张约束，提出主张的人可以将该主张及其依据通知任何收到该信息的当事人。收到通知后，当事人必须立即返还、隔离或销毁所指定的信息及其持有的任何副本；在该主张得到解决之前不得使用或披露该信息；如该当事人在收到通知前已披露该信息，必须采取合理措施取回该信息；并且可以立即向要求履行的地区的法院密封提交该信息，以裁定该主张。提交该信息的人必须在该主张得到解决之前保存该信息。\n\n(g) 藐视法庭。要求履行的地区的法院——以及在动议被移送后，发出传票的法院——可以认定已被送达但无充分理由未遵从传票或与其有关命令的人构成藐视法庭。\n\n有关传票材料的查阅，见 Fed.R.Civ.P.45(a) Committee Note (2013)\n\n……\n\n文件提交请求\nI. 指示\n\n1. 除非另有说明，下列文件请求（“请求”，每一项称为“一项请求”）必须分别且具体地作出回应。除非善意提出异议，否则必须完整回答每项请求；如提出异议，必须如下文所述详细说明贵方异议的理由。如异议仅涉及某项请求的一部分，或其中包含的某个词语、短语或条款，贵方仅须说明对该部分的异议，并对其余请求作出回应。\n\n2. 电子存储信息必须依照下列指示提交：\n\na. 图像。黑白图像必须为 300 DPI Group IV 单页 TIFF 文件。彩色图像必须以 JPEG 格式提交。文件名不得包含嵌入空格或特殊字符（包括逗号）。文件夹名称不得包含嵌入空格或特殊字符（包括逗号）。所有 TIFF 图像文件必须具有唯一的文件名，即 Bates 编号。图像必须在每张图像的右下角标注连续的 Bates 编号。每个文件夹中的 TIFF 文件数量不应超过 1000 个文件。Excel 电子表格应具有以该文件的 Bates 编号命名的占位图像。\n\nb. 图像加载文件\n\na. Concordance® 数据文件。数据文件（.DAT）包含将加载至 Concordance® 数据库的全部字段信息。.DAT 文件的第一行必须为标识字段名称的标题行。.DAT 文件必须使用以下 Concordance® 默认分隔符：逗号 ASCII 字符（020）引号 þ ASCII 字符（254）。日期字段应以 mm/dd/yyyy 格式提供。日期和时间字段必须为两个单独字段。如文件包括已成像的电子邮件及附件，必须包括附件字段，以保留电子邮件与其附件之间的父/子关系。必须包括 OCRPATH 字段，以提供已提交存储介质上提取文本文件的文件路径和名称。文本文件必须以 FIRSTBATES 命名。不得在 .DAT 文件中包含文本。对于含有原生文件的文件，必须包括 LINK 字段，以提供原生文件的文件路径和名称。原生文件必须以 FIRSTBATES 命名。\n\nb. Concordance Image® 或 Opticon 交叉引用文件。图像交叉引用文件（.LOG 或 .OPT）将图像链接至数据库记录。该文件应为以逗号分隔的文件，每行由七个字段组成；数据库中的每张图像均应在交叉引用文件中有一行，格式如下：ImageID,VolumeLabel,ImageFilePath,DocumentBreak,FolderBreak,Box Break,PageCoun。\n\nc. 文件文本。文本必须作为单独的文本文件提交，而非作为 .DAT 文件中的字段。文本文件的完整路径（OCRPATH）应包括在 .DAT 文件中。建议使用文件级 ANSI 文本文件，并按照 FIRSTBATES/Image Key 命名。提取的文本文件必须置于单独的文件夹中，每个文件夹中的文本文件数量不应超过 1,000 个文件。文件夹名称中不得有特殊字符（包括逗号）。必须按文件级别提供文本文件。\n\nd. 某些文件类型的原生格式提交。为完整理解其内容和含义而合理需要以原生格式查看的文件类型，必须以原生格式提交。该等文件包括但不限于电子表格、类似电子表格的文件（Microsoft Excel、逗号分隔值、制表符分隔值等）、Microsoft PowerPoint 或其他特殊演示文件、数据库文件及音频/视频文件。应提供一张标有 Bates 编号的分隔页图像，注明存在原生文件，并在 .dat 文件中将原生文件路径作为字段列入。提交的原生文件须以与该文件分隔页相对应的 Bates 编号命名。原生文件应归入按递增方式命名的“NATIVE”目录，与图像目录分开。\n\ne. 去重。对于存在完全重复副本的每份电子文件，仅提交一份副本。对于电子邮件，根据由 BCC、Body、CC、From、IntMsgID、To 和 Attach 属性生成的 MD5 哈希值合并重复件。对于电子邮件附件和独立电子文件，根据整个文件的 MD5 哈希值合并重复件。\n\nf. 元数据。以符合 Concordance 要求的加载文件（.dat）形式提交每份文件的提取元数据。.DAT 文件的第一行必须为标识字段名称的标题行。.DAT 文件必须使用以下 Concordance 默认分隔符：逗号 , ASCII 字符（020）引号 þ ASCII 字符（254）\n\n日期字段应以 mm/dd/yyyy 格式提供。日期和时间字段必须为两个单独字段。下列为必需元数据：\n案件 22-50073 文件 3193 提交日期 05/16/24 录入日期 05/16/24 10:28:21 第 252 页，共 439 页\n\n字段名称　示例数据　说明\n\nFIRSTBATES　EDC0000001　原生文件文件/电子邮件的第一个 Bates 编号\nLASTBATES　EDC0000001　原生文件文件/电子邮件的最后一个 Bates 编号\n单页文件应填写 LASTBATES 字段\nATTACHRANGE　EDC0000001\n－　父文件第一页的 Bates 编号至最后一个附件“子”文件最后一页的 Bates 编号\nEDC0000015\nBEGATTACH　EDC0000001　附件范围的第一个 Bates 编号\nENDATTACH　EDC0000015　附件范围的最后一个 Bates 编号\nCUSTODIAN　Smith, John（约翰·史密斯）　电子邮件：该电子邮件所在的邮箱\n原生文件：该文件源自其文件的个人或部门名称\nFROM　John Smith（约翰·史密斯）　电子邮件：发件人\n原生文件：文件作者\n多个条目之间应使用分号分隔\nTO　Coffman, Janice（贾妮斯·科夫曼）; LeeW　收件人\n[mailto:LeeW@MSN.com]　多个条目之间应使用分号分隔\nCC　Frank Thompson（弗兰克·汤普森） [mailto:　抄送收件人\nfrank_Thompson@cdt.com]　多个条目之间应使用分号分隔\nBCC　John Cain（约翰·凯恩）　密送收件人\n多个条目之间应使用分号分隔\nSUBJECT　Board Meeting Minutes　电子邮件：电子邮件主题行；原生文件：文件标题\n（如有）\nFILE_NAME　BoardMeetingMinutes.docx　原生文件：原始原生文件名称，包括扩展名\nDATE_SENT　10/12/2010　电子邮件：电子邮件发送日期\n原生文件：（空）\nTIME_SENT/\nTIME_ZONE　07:05 PM GMT　电子邮件：电子邮件发送时间/电子邮件标准化所采用的时区\nTIME_ZONE　GMT　在转换过程中电子邮件被标准化所采用的时区。\nLINK　EDC0000001.msg　电子邮件或原生文件的超链接\n链接文件必须按照 FIRSTBATES 编号命名\nFILE_EXTEN　MSG　表示电子邮件或原生文件的文件类型扩展名\nAUTHOR　John Smith（约翰·史密斯）　电子邮件：（空）\n原生文件：文件作者\nDATE_CREATED　10/10/2010　电子邮件：（空）\n原生文件：文件创建日期\n案件 22-50073 文件 3193 提交日期 05/16/24 录入日期 05/16/24 10:28:21 第 253 页，共 439 页\n\nTIME_CREATED　10:25 AM　电子邮件：（空）\n\n原生文件：文档创建时间\n**该数据必须为单独字段，且不得\n与 DATE_CREATED 字段合并\nDATE_MOD　10/12/2010　电子邮件：（空）\n原生文件：文档最后修改日期\nTIME_MOD　07:00 PM　电子邮件：（空）\n原生文件：文档最后修改时间\n**该数据必须为单独字段，且不得\n与 DATE_MOD 字段合并\nDATE_ACCESSD　10/12/2010　电子邮件：（空）\n原生文件：文档最后访问日期\nTIME_ACCESSD　07:00 PM　电子邮件：（空）\n原生文件：文档最后访问时间\n**该数据必须为单独字段，且不得\n与 DATE_ACCESSD 字段合并\nFILE_SIZE　5,952　原生文件\n文档/电子邮件的大小（KB）\nPGCOUNT　1　原生文件文档/电子邮件的页数\nPATH　电子邮件：（空）\nAgenda.doc　原生文件：存储原生文件文档的路径，\n包括原始文件名。\nINTFILEPATH　Personal Folders\\Deleted　电子邮件：电子邮件的原始位置，包括\nItems\\Board Meeting　原始文件名。\nMinutes.msg　原生文件：（空）\nINTMSGID　<000805c2c71b\\$75977050\\$　电子邮件：唯一消息 ID　原生文件：（空）\ncb8306d1@MSN>\nMD5HASH　d131dd02c5e6eec4693d9a0698aff95c2fcab58712467eab4004583eb8fb7f89　文档的 MD5 哈希值。\nOCRPATH　TEXT/001/EDC0000001.txt　原生文件提取文本的路径\n\n3. 各项请求均独立运作并应独立解释，除非另有说明，任何请求均不限制任何其他请求的范围。\n\n4. 所有文件均应按照日常业务过程中保存的方式提供，或应予以组织并标记，以对应本请求中的类别。\n\n5. 本文所载每项请求均延及所有文件：(a) 由您占有、保管或控制的文件；或 (b) 由代表您行事的任何人占有、保管或控制的文件，\nCase 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 254 of 439\n包括您的律师或其他代表及顾问。每份文件均应完整提供。\n\n6. 如要求您提供的文件已不再由您占有、保管或控制，则您的答复必须：(a) 详细描述该文件的性质及其内容；(b) 确认编制或撰写该文件的人员（以及，如适用，确认该文件被发送给的人员）；(c) 确认该文件编制或创建的日期；(d) 说明该文件是否 (i) 遗失或丢失，(ii) 已被销毁，(iii) 已自愿或非自愿地转移给他人，或 (iv) 已以其他方式处置；(e) 说明该等处置的原因以及围绕该等处置的事实和情形；(f) 确认授权该等处置的人员；(g) 确认该等处置的日期或大致日期；(h) 说明该文件最近一次由您占有、保管或控制的时间；以及 (i) 确认目前占有、保管或控制该文件的人员（如有）。\n\n7. 如要求您提供的文件已被销毁，则除前述指示所要求的信息外，您的答复还必须说明：(a) 销毁该文件的原因；(b) 销毁该文件的人员身份；以及 (c) 指示销毁该文件的人员身份。\n\n8. 如您主张所要求的文件享有特权或属于律师工作成果，则您的答复必须：(a) 说明：(i) 对该文件作出足以支持您关于该文件享有特权之主张的描述，(ii) 该文件的标题，(iii) 该文件的日期，(iv) 该文件的作者，(v) 该文件的收件人，(vi) 收到或见过该文件原件或任何草稿、复制件或再制件的每一人员的身份，(vii) 该文件本身或该文件所载或提及的任何信息是否由任何其他人员占有、保管或控制；如是，则确认该等人员的身份，并说明该等信息如何进入其占有范围，(viii) 据以扣留该文件的特权主张，以及 (ix) 您将据以支持该等特权主张的全部情形；以及 (b) 依照 D. Conn. L. Civ. R. 26(e)，就每份基于特权主张而被扣留的文件，制作一份特权日志，其中载明本指示第 (a) 部分所要求的全部信息。\nCase 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 255 of 439\n\n9. 如本应答文件的一部分包含受特权主张约束的信息，则仅可按照上述指示从该文件中删除或涂黑受该特权主张约束的部分，其余部分应予提供。\n\n10. 各项请求具有持续性。现指示您：(a) 一旦得知先前答复不完整或不正确，应立即补充或更正任何后来发现不完整或不正确的答复；以及 (b) 提供根据下述内容所要求的任何补充文件\n\n11. 如文件使用英语以外的语言，您应提供该文件。如文件使用英语以外的语言，且存在英文译本，您应同时提供两份文件。\n\n12. 对实体的所有提及均包括其所有关联方。\n\n13. 对个人姓名的所有提及均包括所有替代姓名、别名或昵称。\n\n14. 除非另有明确说明，文件请求所涵盖的期间为自 February 5, 2012 起至文件请求答复到期之日止。\n\nII. 解释规则\n\n15. (a) 任何单数名词的使用均应解释为包括复数，反之亦然；以及 (b) 任何时态动词的使用均应解释为在所有其他时态中使用该动词。\n\n16. (a) “和”及“或”应视必要按连词或选择连词解释，以将否则可能被解释为在任何请求范围之外的所有答复纳入该请求范围；以及 (b) “每一”及“任何”应视为包括并涵盖“每个”及“所有”二词。\n\nIII. 定义\n\n经 D. Conn. Bankr. L.R. 2004-1(a) 纳入的 D. Conn. L. Civ. R. 26(c) 所提供的定义及 D. Conn. L. Civ. R. 26(d) 所提供的解释规则，适用于文件请求。此外，本文件请求中使用的下列术语具有下列含义：\n\n1. “您”或“您的”或“您本人”系指 Sean Lynch（肖恩·林奇），连同其所有代理人、律师、代表、雇员和/或任何代表其行事的人。\n\n2. “债务人”系指 Ho Wan Kwok（郭文贵）（又名 Miles Kwok、Miles Guo、Guo Wengui、Guo Haoyun、郭文贵或任何其他别名），连同其雇员、代理人、律师、顾问或任何代表其行事的人。\n\n3. “债务人之子”系指 Qiang Guo（郭强）（又名 Mileson Kwok、郭强或任何其他别名），连同其雇员、代理人、律师、顾问或任何代表其行事的人。\n\n4. “债务人之女”系指 Mei Guo（郭美）（又名 Mei Gui、郭美或任何其他别名），连同其雇员、代理人、律师、顾问或任何代表其行事的人。\nCase 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 257 of 439\n\n5. “债务人所谓妻子”系指 Hing Chi Ngok（岳庆芝）（又名 Hing Chi Ng、Yue Qingzhi、岳庆芝或任何其他别名），连同其雇员、代理人、律师、顾问或任何代表其行事的人。\n\n6. “债务人家属”系指债务人、债务人之子、债务人之女及债务人所谓妻子，以及与债务人存在任何其他亲属关系的人，合称。\n\n7. “关联个人”系指单独或共同符合以下条件的所有个人：(1) 持有、控制、保管或对债务人或债务人家属所拥有、控制或享有的资产拥有酌处权；或 (2) 曾为一个或多个关联实体的雇员、董事，或以其他方式与一个或多个关联实体有关联，连同前述各方各自的雇员、代理人、律师、顾问或任何代表前述任何一方行事的人。该等关联个人包括但不限于：Anthony DiBattista（安东尼·迪巴蒂斯塔）、Alex Hadjicharalambous（亚历克斯·哈吉查拉兰布斯）、Bernardo Enriquez（贝尔纳多·恩里克斯）、Bingshang Jiao（焦炳尚）、Beile Li（李贝乐）、Brian W. Hofmeister（布赖恩·W·霍夫迈斯特）、Charles Gruder（查尔斯·格鲁德）、Daniel Podhaskie（丹尼尔·波达斯基）、David Fallon（大卫·法伦）、Defeng Cao（曹德峰）（又名 Wayne Cao、Max Cao）、Ding Lin（林丁）、Dinggang Wang（王定刚）（又名 王定刚）、Eduardo Eurnekian（爱德华多·尤尔内基安）、Ehsan Masud（埃桑·马苏德）、Fiona Yu（余菲奥娜）、Gladys Chow（周格拉迪斯）、Hao (Gavin) Li（李浩〔加文〕）（又名 Huo Lai）、Hao Haidong（郝海东）（又名 郝海东）、Han Chunguang（韩春光）（又名 韩春光）、Haoran He（何浩然）、Ivan Lin（林伊凡）、Haitham Khaled（海瑟姆·哈立德）、Jason Miller（杰森·米勒）、Jennifer Mercurio（詹妮弗·梅尔库里奥）、Jesse Brown（杰西·布朗）、Jessica Mastrogiovanni（杰西卡·马斯特罗焦瓦尼）、Jie Zhang（张杰）、Jintao Li（李金涛）、Karin Maistrello（卡琳·迈斯特雷洛）、Kyle Bass（凯尔·巴斯）、Lihong Wei Lafrenz（魏丽红）（又名 Sara Wei、魏丽红）、Linwan “Irene” Feng（冯琳婉“艾琳”）、Max Krasner（马克斯·克拉斯纳）、Melissa Francis（梅利莎·弗朗西斯）、Michael Baranowitz（迈克尔·巴拉诺维茨）、Min Yang（杨敏）、Melissa Mendez（梅利莎·门德斯）、Nadeem Akbar（纳迪姆·阿克巴）、Nan Li（李楠）（又名 Chris Lee、Mei Guo Xiao Li）、Qidong Xia（夏启东）、Qu Guojiao（屈国姣）（又名 Qu Guo Jiao、屈国姣）、Ridwan Mamode Saib（里德万·马莫德·赛布）、Ross Heinemeyer（罗斯·海内迈耶）、Rui “Ray” Hao（郝睿“雷”）、Scott Barnett（斯科特·巴内特）、Shih Hsin Yu（余世新）、Shin Hee-Seup（申熙燮）（又名 Hee Seup Shin）、Steve Bannon（史蒂夫·班农）、Talha Zobair（塔尔哈·佐拜尔）、Victor Cerda（维克托·塞尔达）、Wen Xiao（肖文）、Wencong Wang（王文聪）、William Gertz（威廉·格茨）、William Je（余建明）（又名 Je Kin Ming、Yu Jianming、余建明）以及 Xuebing Wang（王雪冰）、\nCase 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 258 of 439\nYa Li（李娅）（又名 李娅）、Yinying (Aila) Wang（王茵莹〔艾拉〕）（又名 Xiao Fei Xiang）、Yongping Yan（闫永平）（Shan Mu）、Yong Yu（俞勇）、Yue Zhou（周悦）、Yumei Hao（郝玉梅）（又名 Ru Shui）、Yvette Wang（王雁平）（又名 Yanping Wang、Yan Ping Wang、王雁平）、Zhang Wei（张魏）（又名 张魏）、Zhouer Wang（王周儿）（又名 Joe Wang）、Zhixuan Li（李志轩）以及 Ziyang Liu（刘子阳）。\n\n8. “关联实体”系指单独或共同符合以下条件的所有任何类型组织或实体：(1) 曾由债务人或债务人家属拥有、控制或投资；或 (2) 对债务人或债务人家属所拥有、控制或享有的任何资产直接或间接享有权益，连同前述各方各自的雇员、代理人、律师、顾问或任何代表前述任何一方行事的人。该等关联实体包括但不限于：1332156 B.C. Ltd.（1332156 B.C.有限公司）、7 Nod Hill LLC（7 Nod Hill 有限责任公司）、AAGV Limited（AAGV 有限公司）、ACA Investment Management Limited（ACA 投资管理有限公司）、ACA Capital Group Limited（ACA 资本集团有限公司）、Ace Decade Holdings Limited（Ace Decade 控股有限公司）、AI Group Holdings Inc.（AI 集团控股公司）、Alfa Global Ventures Limited（Alfa 全球创投有限公司）、Alfonso Global Limited（Alfonso 全球有限公司）、Allied Capital Global Limited（Allied Capital Global 有限公司）、Alpine Fiduciaries SA（Alpine 受托人股份公司）、Beijing Pangu Investment Co.（北京盘古投资公司）、Beijing Pangu Investment Co. Ltd.（北京盘古投资有限公司）、Beijing Pangu Investment Inc.（北京盘古投资公司）、Beijing Zenith Holdings Company Limited（北京 Zenith 控股有限公司）、Blue Capital Limited（Blue Capital 有限公司）、Booming Sail New York LLC（Booming Sail New York 有限责任公司）、Bravo Luck Limited（Bravo Luck 有限公司）、Brent Petro（Brent Petro）、BSA Strategic Fund I（BSA 战略基金 I）、China Golden Spring (Hong Kong) Limited（中国金泉〔香港〕有限公司）、Chuang Xin Limited（创新有限公司）、Crane Advisory Group LLC（Crane 咨询集团有限责任公司）、Creative Apex Investments Limited（Creative Apex 投资有限公司）、Crystal Breeze Investments Limited（Crystal Breeze 投资有限公司）、Dawn State Limited（Dawn State 有限公司）、Eastern Profit Corporation Limited（Eastern Profit Corporation 有限公司）、Empire Growth Holdings（Empire Growth 控股公司）、Elite Well Global Limited（Elite Well Global 有限公司）、Freedom Media Ventures Ltd.（Freedom Media Ventures 有限公司）、Fung Wan Trading Inc.（Fung Wan Trading 公司）、G Club（G Club）、G Club Operations LLC（G Club 运营有限责任公司）、G Club International Limited（G Club 国际有限公司）、G Club Investments Limited（G Club 投资有限公司）、G Fashion LLC（G Fashion 有限责任公司）、G-News Operations LLC（G-News 运营有限责任公司）、G News LLC（G News 有限责任公司）、GMusic Inc.（GMusic 公司）、G-Services LLC（G-Services 有限责任公司）、G-Translators PTY LTD（G-Translators 私营有限公司）、GETTR USA, Inc.（GETTR USA 公司）、Genever Holdings Corporation（Genever 控股公司）、Genever Holdings LLC（Genever 控股有限责任公司）、GFashion Media Group Inc.（GFashion 媒体集团公司）、GFNY, Inc.（GFNY 公司）、Globalist International Limited（Globalist International 有限公司）、GNews Media Group Inc.（GNews 媒体集团公司）、Golden Spring (New York) Ltd.（Golden Spring〔纽约〕有限公司）、Guo Media（Guo Media）、GTV Media Group, Inc.（GTV 媒体集团公司）、GWGOPNZ\n\nLimited（有限公司）、GWGNZ Limited（GWGNZ有限公司）、Gypsy Mei Food Services, LLC（吉普赛梅食品服务有限责任公司）、HCHK Property Management Inc.（HCHK物业管理公司）、HCHK Technologies Inc.（HCHK技术公司）、Hamilton Digital Assets FD SP（汉密尔顿数字资产FD SP）、Hamilton Capital Holdings Inc.（汉密尔顿资本控股公司）、Hamilton Opportunity Fund SPC（汉密尔顿机会基金SPC）、Head Win Group Limited（海德温集团有限公司）、Himalaya Embassy（喜马拉雅大使馆）、Himalaya Exchange（喜马拉雅交易所）、Himalaya Federal Reserve（喜马拉雅联邦储备）、Himalaya International Financial Group Ltd.（喜马拉雅国际金融集团有限公司）、Himalaya Investment LLC（喜马拉雅投资有限责任公司）、Himalaya (USA) Investment Management LLC（喜马拉雅〔美国〕投资管理有限责任公司）、Himalaya New World Inc.（喜马拉雅新世界公司）、Himalaya Supervisory Organization（喜马拉雅监督组织）、Himalaya Ventures（喜马拉雅创投）、Holy City Hong Kong Ventures, Ltd.（圣城香港创投有限公司）、Hudson Diamond Holding LLC（哈德逊钻石控股有限责任公司）、Hudson Diamond Holding Inc.（哈德逊钻石控股公司）、Hudson Diamond NY LLC（哈德逊钻石纽约有限责任公司）、HK International Funds Investments (USA) Limited LLC（香港国际基金投资〔美国〕有限责任公司）、Hong Kong International Funds Investments Limited（香港国际基金投资有限公司）、Huk Trading Inc（Huk贸易公司）、Infinite Increase Limited（无限增长有限公司）、Infinitum Developments Limited（无限发展有限公司）、Japan Himalaya League, Inc.（日本喜马拉雅联盟公司）、Kalixun Trading Limited（卡利迅贸易有限公司）、Lamp Capital LLC（兰普资本有限责任公司）、Leading Shine Limited（领耀有限公司）、Leading Shine NY Limited（领耀纽约有限公司）、Lexington Property and Staffing Inc.（列克星敦物业与人力公司）、Long Gate Limited（长龙门有限公司）、MOS Himalaya Foundation Inc.（MOS喜马拉雅基金会公司）、Maywind Trading LLC（五月风贸易有限责任公司）、New Federal State of China（中国新联邦国，亦称NFSC）、New York MOS Himalaya LLC（纽约MOS喜马拉雅有限责任公司）、New Mulberry PTE Ltd.（新桑树私人有限公司）、Newpeople LLC（新人民有限责任公司）、Noble Fame Global Limited（诺布尔名誉环球有限公司）、Pixshow Film Inc.（Pixshow电影公司）、Roscalitar 2（Roscalitar 2）、Rosy Acme Ventures Limited（Rosy Acme创投有限公司）、Rule of Law Foundation III, Inc.（法治基金会III公司）、Rule of Law Society（法治协会）、Rule of Law Society IV, Inc.（法治协会IV公司）、Santel LLC（桑特尔有限责任公司）、Saraca Media Group, Inc.（Saraca媒体集团公司）、Shiny Ace Ltd.（闪耀王牌有限公司）、Shiny Times Holdings Ltd.（闪耀时代控股有限公司）、Stevenson, Wong & Co.（Stevenson, Wong & Co.）、Taurus Fund LLC（金牛基金有限责任公司）、Taurus Fund SP（金牛基金SP）、Taurus Management LLC（金牛管理有限责任公司）、The Lost Draft LLC（遗失草稿有限责任公司）、TM Primrose Limited（TM报春花有限公司）、UA Himalaya Inc.（UA喜马拉雅公司）、Voice of Guo Media, Inc.（郭媒体之声公司）、Well Origin Ltd.（良源有限公司）、Wise Creation（智创）、Whitecroft Shore Limited（怀特克罗夫特海岸有限公司）、World Century Limited（世界世纪有限公司）、Worldwide Opportunity Holdings Limited（全球机会控股有限公司）及ZIBA Limited（ZIBA有限公司）。\n\n9. “包括”或其任何变体，均指“包括但不限于”。\n\n10. “和”及“或”均指“和/或”，并应同时按连词及析取词解释，以最大限度扩大其范围。\n案件 22-50073 文书 3193 于 05/16/24 提交，于 05/16/24 10:28:21 录入，第260页，共439页\n\n11. “任何”“全部”及“每一”均指“每一个及所有”。\n\n12. “每一”及“每个”均指“每一个及所有”。\n\n13. “第三方”指除贵方以外的个人或实体。\n\n14. “转让”具有《破产法典》第101(54)条赋予该术语的含义。\n\n15. “文件”指属于《联邦民事诉讼规则》第34条范围内的任何信息或物品，并包括但不限于贵方占有、保管或控制的任何种类、类型、性质或描述的每一份书面、录制或图形资料，包括电子邮件、以电子形式保存的计算机文件、电子通信、短信、社交媒体帖子、推文、元数据、信函、备忘录、磁带、速记或手写笔记、任何种类的书面表格、图表、蓝图、绘图、草图、曲线图、计划、文章、规格说明、日记、信件、电报、照片、会议记录、合同、协议、调查资料、计算机打印件、任何种类的数据汇编、电传、传真、语音留言、发票、订购单、支票、汇票、对账单、贷项通知单、报告、持仓报告、摘要、索引、书籍、分类账、笔记本、附表、透明胶片、录音、目录、广告、宣传材料、影片、录像带、录音带、CD、计算机磁盘、宣传册、小册子、穿孔卡、工时单、推文、社交媒体帖子或任何其他种类的书面或录制材料，以及其全部元数据，无论以何种方式存储（无论为有形或电子形式）、记录、制作或复制；还包括但不限于上述任何资料的草稿或副本，如其包含原始文件中没有的任何种类笔记、评论或标记，或在其他方面与原始文件不完全相同。\n案件 22-50073 文书 3193 于 05/16/24 提交，于 05/16/24 10:28:21 录入，第261页，共439页\n\n16. “个人”指个人、公司、独资企业、合伙企业、协会或任何其他实体。“个人”还包括任何代理人、代表或专家，包括但不限于律师或财务顾问。\n\n17. “实体”指任何自然人、公司、合伙企业、子公司、独资企业、商号、董事会、合资企业、协会、机构、主管机关、委员会或其他商业实体或法人，以及任何关联方、代理人、母公司，包括但不限于法律顾问、财务顾问或任何其他代表。\n\n18. “关于”指涉及、描述、构成、提及、与之相关、支持、赞成、反对、加强、减损、位于、结合考虑、对其有影响、证明、表明、报告、记录、暗指、回应、与之相连、评论、就其而言、关于、与之有关、讨论、显示、描述、反映、分析、构成及成为。\n\n19. 在提及任何既定主题事项时，“与……有关”“与……相关”或“相关于”指，包括但不限于，构成、包含、涉及、含有、体现、反映、识别、陈述、直接或间接提及该特定已识别主题事项，或以任何方式与其相关的任何文件。\n\n20. “通信”在最广泛可能的意义上且不限于此，指任何信息或知识的传递（以事实、观点、询问或其他形式）。通信还指所有谈话、协议、询问或答复，无论是当面、电话、书面或通过电子传输设备进行，并包括但不限于所有信函、电子邮件、录音、传送单、备忘录、电话通信、语音留言、电报、电话传真、传真副本、\n案件 22-50073 文书 3193 于 05/16/24 提交，于 05/16/24 10:28:21 录入，第262页，共439页\n\n电传、即时消息、聊天记录、短信、电话笔记，或在内部或与第三方之间传递的笔记。\n\n21. “资产”指任何可用于产生正向经济价值的项目，包括但不限于任何由实体拥有、控制或为实体利益而持有并预期提供未来利益的具有经济价值的资源，包括但不限于所有不动产和动产、无形财产、投资、投资权或未来收入权、现金、银行账户、商品、证券、债权、对实体的全部或部分控制权，以及预期的经济机会。\n\n22. “转让”具有《破产法典》第101(54)条赋予该术语的含义。\nIV. 应提交的文件\n\n1. 与债务人、债务人的家庭成员、债务人财产、关联个人或关联实体的任何收入或资产有关的所有文件。\n\n2. 与债务人的财务状况及其对债权人的义务有关的所有文件，包括但不限于与任何试图规避支付该等义务的行为有关的所有文件，以及与本次或任何其他实际或潜在破产或类似无力偿债程序有关的所有文件。\n\n3. 与债务人、债务人财产、债务人的家庭成员、关联实体或关联个人有关的任何资产负债表、银行对账单、账户对账单、财务报表、账目报表、电汇指示和/或确认、资金证明、存款证、持有证明、投资组合摘要或类似文件有关的所有文件，包括但不限于足以显示向上述任何一方进行的所有转让的全部文件。\n案件 22-50073 文书 3193 于 05/16/24 提交，于 05/16/24 10:28:21 录入，第263页，共439页\n\n4. 与债务人、债务人的家庭成员、关联个人或关联实体作出、与其进行或代表其进行的任何投资、商业往来或交易有关的所有文件。\n\n5. 与债务人、债务人的家庭成员、关联个人或关联实体进行的所有通信，以及与同债务人、债务人的家庭成员、关联个人或关联实体进行的通信有关的文件，包括与任何实体的运营、管理或决策有关的通信和文件，包括但不限于关联实体。\n\n6. 与向债务人、债务人的家庭成员、关联个人或关联实体进行、由其进行或与其进行的任何转让、投资或其他交易或商业往来有关的所有文件。\n\n7. 与债务人曾占用或使用的任何财产有关的所有文件，包括但不限于位于康涅狄格州格林尼治373 Taconic Rd.的住宅物业；位于康涅狄格州格林尼治33 Ferncliff Rd.的住宅物业；位于康涅狄格州威尔顿354 Nod Hill Rd的住宅物业；位于英国伦敦SW7 1QJ、5 Princes Gate的公寓或共管公寓；以及位于新泽西州马瓦675 Ramapo Valley Road, Mahwah, New Jersey 07430的住宅物业。\n\n8. 与债务人拥有、控制或使用的任何航空器有关的所有文件，包括但不限于：(i) 尾号为T7-GQM的航空器及在圣马力诺登记的任何其他航空器，包括但不限于该等航空器的所有登记文件副本及显示该等航空器所飞航班和该等航班机上人员的飞行舱单；以及(ii) 任何Cirrus SF50航空器。\n案件 22-50073 文书 3193 于 05/16/24 提交，于 05/16/24 10:28:21 录入，第264页，共439页\n\n9. 与向债务人、债务人财产、债务人的家庭成员或关联实体提供、从其获得或代表其提供的任何馈赠、利益或贷款有关的所有文件，包括但不限于足以显示该等馈赠、利益或贷款金额的文件；该等馈赠、利益或贷款的用途；提供该等馈赠、利益或贷款的时间；以及任何贷款的条款、就任何贷款作出的全部陈述和保证、任何贷款的利率，以及任何贷款付款的全部证据。\n\n10. 与由债务人、债务人财产、债务人的家庭成员或关联实体设立、代表其设立或为其利益设立的任何信托或类似文书有关的所有文件，包括但不限于足以显示信托设立时间、设立人、为谁的利益设立及信托本金的文件。\n\n11. 与涉及债务人的任何法律争议相关的任何义务、请求权、责任或债务有关的所有文件，包括但不限于与在任何地方、州、联邦或国际机构前进行的任何诉讼有关的文件，无论该机构为行政机关、法院、合议庭或替代性争议解决实体。\n\n12. 与债务人、债务人的家庭成员或关联个人之间的所有文件及通信。\n\n13. 贵方的任何律师或其他顾问与债务人、债务人的家庭成员或关联个人之间的所有文件及通信。\n\n14. 与贵方持有或曾持有权益的任何关联实体有关的所有文件。\n\n案件 22-50073 文书 3193 于 05/16/24 提交，于 05/16/24 10:28:21 录入，第265页，共439页\n附件C-14\n\nB2540（表格2540——依据规则2004审查的传票）（12/15）案件 22-50073 文书 3193 于 05/16/24 提交，于 05/16/24 10:28:21 录入，第266页，共\n\n美国破产法院 439\n\n康涅狄格区\n\n关于HO WAN KWOK（郭文贵）等人，\n\n1 案件编号 22-50073 (JAM)\n\n债务人 第11章\n\n（合并管理）\n依据规则2004审查的传票\n\n致：Eddy Aquino（亦称Eddy L. Sanchez Aquino）\n\n（传票送达对象姓名）\n\n证言：现命令贵方于下列规定的时间、日期和地点出席，并根据《联邦破产程序规则》规则2004接受审查并作证。随附授权该审查的法院命令副本。\n\n地点　日期和时间\n\n不适用　不适用\n\n审查将采用以下方式记录：不适用\n\n提交材料：您或您的代表还必须在接受询问时随身携带下列文件、电子存储信息或物件，并必须允许对该等材料进行查阅、复制、测试或抽样：\n见随附的《文件提交请求》。\n\n以下《联邦民事诉讼规则》第45条的规定，经《联邦破产程序规则》第9016条适用于破产案件，现随附于后——第45(c)条，关于履行地点；第45(d)条，关于对作为传票对象之人的保护；以及第45(e)条和第45(g)条，关于您对本传票作出回应的义务及未予回应可能产生的后果。\n\n日期：May , 2024\n\n法院书记员\n\n或\n\n书记员或副书记员签名　律师签名\n\n签发或请求本传票的代表第11章受托人 Luc A. Despins 的律师姓名、地址、电子邮件地址和电话号码如下：\n\nPatrick R. Linsey, Esq.; Neubert, Pepe & Monteith, P.C.; 195 Church Street, 13th Floor, New Haven, Connecticut 06510 plinsey@npmlaw.com; (203) 781-2847\n\n致签发或请求本传票之人的通知\n\n如本传票要求在审判前提交文件、电子存储信息或有形物品，或检查场所，则必须在向传票所指向之人送达之前，向各方送达通知及本传票副本。Fed. R. Civ. P. 45(a)(4)。\n\n软件版权 (c) 1996-2022 Best Case, LLC - www.bestcase.com Best Case Bankruptcy 1 本第11章案件中的债务人为 Ho Wan Kwok（郭文贵）（亦称 Guo Wengui、Miles Guo 和 Miles Kwok，以及众多其他别名）（税务识别号码后四位：9595）、Genever Holdings LLC（税务识别号码后四位：8202）和 Genever Holdings Corporation。受托人、Genever Holdings LLC 和 Genever Holdings Corporation 的邮寄地址为 Paul Hastings LLP，200 Park Avenue, New York, NY 10166，转交 Luc A. Despins，作为 Ho Wan Kwok 遗产的受托人（仅为通知和通信之目的）。\n\n送达证明\n\n（除非 Fed. R. Civ. P. 45 要求，否则本节不应向法院提交。）\n\n我于（日期）收到向（个人姓名及职务，如有）发出的本传票。\n\n我通过以下方式向所列明之人交付副本以送达本传票：\n\n于（日期）送达；或\n\n我未予执行而退回本传票，理由如下：\n\n除非本传票系代表美国或其官员或代理人签发，我还已向证人支付一天出庭费用及法律允许的里程费用，金额为 \\$ 。\n\n我的差旅费用为 \\$ ，服务费用为 \\$ ，合计 \\$ 。\n\n我在伪证处罚的约束下声明，该等信息真实且正确。\n\n日期：\n\n送达人员签名\n\n印刷体姓名及职务\n\n送达人员地址\n\n有关尝试送达等事项的补充信息：\n\n《联邦民事诉讼规则》第45(c)、(d)、(e)和(g)条（Effective 12/1/13）（经《联邦破产程序规则》第9016条适用于破产案件）\n\n(c) 履行地点。\n\n(1) 审判、听证或证言录取。传票仅可按如下方式命令某人出席审判、听证或证言录取：\n\n(A) 在该人居住、受雇或经常亲自从事商业交易地点的100英里范围内；或\n\n(B) 在该人居住、受雇或经常亲自从事商业交易所在州内，如该人\n\n(i) 为当事人或当事人的高级职员；或\n\n(ii) 被命令出席审判且不会产生重大费用。\n\n(2) 其他证据开示。传票可命令：\n\n(A) 在该人居住、受雇或经常亲自从事商业交易地点的100英里范围内某地提交文件、电子存储信息或物品；以及\n\n(B) 在待检查场所对该场所进行检查。\n\n(d) 对作为传票对象之人的保护；执行。\n\n(1) 避免不当负担或费用；制裁。负责签发和送达传票的当事人或律师必须采取合理措施，避免对作为传票对象之人施加不当负担或费用。要求履行的地区法院必须执行该义务，并对未遵守者的当事人或律师施加适当制裁，该制裁可包括损失的收入和合理的律师费。\n\n(2) 命令提交材料或允许检查。\n\n(A) 无须出庭。被命令提交文件、电子存储信息或有形物品，或允许检查场所的人，无须亲自到提交或检查地点出庭，除非同时被命令出席证言录取、听证或审判。\n\n(B) 异议。被命令提交文件或有形物品或允许检查的人，可以就检查、复制、测试或抽样全部或部分材料，或检查场所，或以所请求的一种或多种形式提交电子存储信息，向传票中指定的当事人或律师送达书面异议。异议必须在规定履行时间或传票送达后14日两者中较早者之前送达。如提出异议，适用下列规则：\n\n(i) 在任何时候，经通知被命令之人，送达方可以向要求履行的地区法院提出动议，申请作出强制提交或检查的命令。\n\n(ii) 仅可依照该命令的指示要求实施此等行为，且该命令必须保护既非当事人亦非当事人高级职员之人免于承担因履行而产生的重大费用。\n\n(3) 撤销或修改传票。\n\n(A) 必须撤销或修改的情形。经及时提出动议，要求履行的地区法院必须撤销或修改下列传票：\n\n(i) 未留出合理履行时间；\n\n(ii) 要求某人在第45(c)条规定的地理范围以外履行；\n\n(iii) 要求披露享有特权或受其他保护的事项，且不存在适用的例外或豁免；或\n\n(iv) 使某人承担不当负担。\n\n(B) 可以撤销或修改的情形。为保护作为传票对象或受传票影响之人，要求履行的地区法院可以经动议撤销或修改要求下列事项的传票：\n\n(i) 披露商业秘密或其他保密的研究、开发或商业信息；或\n\n(ii) 披露未受聘专家的意见或信息，且该等意见或信息并非描述争议中的特定事件，并且源于该专家未经当事人请求进行的研究。\n\n(C) 以规定条件作为替代。在第45(d)(3)(B)条所述情形下，如送达方：\n\n(i) 证明其对证言或材料具有重大需要，且无法在不造成不当困难的情况下通过其他方式满足该需要；并且\n\n(ii) 确保被传唤之人将获得合理报酬，\n\n法院可以不撤销或修改传票，而命令在规定条件下出庭或提交。\n\n(e) 回应传票时的义务。\n\n(1) 提交文件或电子存储信息。下列程序适用于提交文件或电子存储信息：\n\n(A) 文件。回应提交文件传票的人必须按照文件在正常业务过程中保存的方式提交文件，或者必须将其整理并标注，使之对应于请求中的类别。\n\n(B) 未规定电子存储信息的提交形式。如传票未规定提交电子存储信息的形式，回应之人必须以其通常保存的一种或多种形式，或以合理可用的一种或多种形式提交。\n\n(C) 电子存储信息仅以一种形式提交。回应之人无须以一种以上形式提交同一电子存储信息。\n\n(D) 无法获取的电子存储信息。回应之人无须对其认定因不当负担或费用而无法合理获取来源中的电子存储信息提供证据开示。在申请强制证据开示或保护令的动议中，回应之人必须证明该信息因不当负担或费用而无法合理获取。如作出该证明，法院仍可在请求方考虑第26(b)(2)(C)条限制后证明具有正当理由的情况下，命令从此类来源进行证据开示。法院可以规定证据开示的条件。\n\n(2) 主张特权或保护。\n\n(A) 被扣留的信息。依据该信息享有特权或受审判准备材料保护的主张而扣留被传唤信息的人必须：(i) 明确提出该主张；并且\n\n(ii) 以一种在不披露本身享有特权或受保护信息的情况下，足以使各方评估该主张的方式，说明被扣留文件、通信或有形物品的性质。\n\n(B) 已提交的信息。如为回应传票而提交的信息受特权主张或审判准备材料保护主张约束，提出该主张之人可以将该主张及其依据通知收到该信息的任何当事人。收到通知后，当事人必须立即返还、隔离或销毁所指定的信息及其持有的任何副本；在该主张得到解决前不得使用或披露该信息；如该当事人在收到通知前已披露该信息，必须采取合理措施取回该信息；并可立即将该信息密封提交给要求履行的地区法院，以裁定该主张。提交该信息之人必须保存该信息，直至该主张得到解决。\n\n(g) 藐视法庭。要求履行的地区法院——以及在动议移送后，签发法院——可以以藐视法庭处罚已被送达但无充分理由而未遵守传票或与之相关命令的人。\n\n如需查阅传票材料，见 Fed.R.Civ.P.45(a) Committee Note (2013)\n\n……\n\n文件提交请求\n\nI. 指示\n\n1. 除非另有说明，下列文件请求（以下简称“请求”，每一项称为“一项请求”）必须分别且具体地予以回应。每项请求均应得到完整答复，除非您基于善意提出异议；如有异议，应如下文所述详细说明您提出异议的理由。如异议仅涉及某项请求的一部分，或其中包含的某一词语、短语或条款，您须仅对该部分说明您的异议，并对其余请求作出回应。\n\n2. 电子存储信息必须依照下列指示提交：\n\n- a. 图像。黑白图像必须为 300 DPI Group IV 单页 TIFF 文件。彩色图像必须以 JPEG 格式提供。文件名不得包含嵌入空格或特殊字符（包括逗号）。文件夹名称不得包含嵌入空格或特殊字符（包括逗号）。所有 TIFF 图像文件必须具有唯一的文件名，即 Bates 编号。图像必须在每张图像的右下角加盖连续的 Bates 编号。每个文件夹中的 TIFF 文件数量不应超过 1000 个文件。Excel 电子表格应具有以该文件的 Bates 编号命名的占位图像。\n\n- b. 图像加载文件\n\n\t- a. Concordance® 数据文件。数据文件（.DAT）包含将加载至 Concordance® 数据库的所有字段信息。.DAT 文件的第一行必须为标明字段名称的标题行。.DAT 文件必须使用以下 Concordance® 默认分隔符：逗号 ASCII 字符（020）；引号 þ ASCII 字符（254）。日期字段应按以下格式提供：mm/dd/yyyy。日期字段和时间字段必须为两个独立字段。如文件包括图像化的电子邮件及附件，则必须包含附件字段，以保留电子邮件与其附件之间的父/子关系。必须包含 OCRPATH 字段，以提供所提取文本文件在所提供存储介质上的文件路径和名称。文本文件必须以 FIRSTBATES 命名。不得在 .DAT 文件中包含文本。对于具有原生文件的文件，必须包含 LINK 字段，以提供原生文件的文件路径和名称。原生文件必须以 FIRSTBATES 命名。\n\n- b. Concordance Image® 或 Opticon 交叉引用文件。图像交叉引用文件（.LOG 或 .OPT）将图像与数据库记录关联。该文件应为逗号分隔文件，每行由七个字段组成，数据库中的每幅图像均应在交叉引用文件中有一行，格式如下：ImageID,VolumeLabel,ImageFilePath,DocumentBreak,FolderBreak,Box Break,PageCoun。\n\n- c. 文件文本。文本必须作为独立文本文件提供，不得作为 .DAT 文件中的字段提供。文本文件的完整路径（OCRPATH）应包含在 .DAT 文件中。建议提供文件级 ANSI 文本文件，并按 FIRSTBATES/Image Key 命名。提取的文本文件必须置于单独文件夹中，每个文件夹中的文本文件数量不应超过 1,000 个文件。文件夹名称不得含有特殊字符（包括逗号）。文本文件必须按文件级别提供。\n\n- d. 特定文件类型的原生格式提供。为完整理解其内容和含义而合理需要以原生格式查看的文件类型，必须以原生格式提供。这些文件包括但不限于电子表格、类电子表格文件（Microsoft Excel、逗号分隔值、制表符分隔值等）、Microsoft PowerPoint 或其他特殊演示文件、数据库文件以及音频/视频文件。应提供一张带有 Bates 编号的分隔页图像，表明存在原生文件，并在 .dat 文件中将原生文件路径作为一个字段列入。所提供的原生文件应以与该文件分隔页相对应的 Bates 编号命名。原生文件应归入按递增方式命名的 “NATIVE” 目录中，并与图像目录分开。\n\n- e. 去重。对于存在完全重复件的每一电子文件，仅提供一份。对于电子邮件，应根据由 BCC、Body、CC、From、IntMsgID、To 和 Attach 属性生成的 MD5 哈希值合并重复件。对于电子邮件附件和独立电子文件，应根据整个文件的 MD5 哈希值合并重复件。\n\n- f. 元数据。应以符合 Concordance 要求的加载文件（.dat）形式，为每份文件提供提取的元数据。.DAT 文件的第一行必须为标明字段名称的标题行。.DAT 文件必须使用以下 Concordance 默认分隔符：逗号 , ASCII 字符（020）；引号 þ ASCII 字符（254）。\n\n日期字段应按以下格式提供：mm/dd/yyyy。日期字段和时间字段必须为两个独立字段。下列为必需元数据：\nCase 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 271 of 439\n\n字段名称　示例数据　说明\n\nFIRSTBATES　EDC0000001　原生文件文件/电子邮件的第一个 Bates 编号\n\nLASTBATES　EDC0000001　原生文件文件/电子邮件的最后一个 Bates 编号\n\n**对于单页文件，应填写 LASTBATES 字段\n\nATTACHRANGE　EDC0000001\n-　父文件第一页的 Bates 编号至最后一个附件“子”文件最后一页的 Bates 编号\nEDC0000015\n\nBEGATTACH　EDC0000001　附件范围的第一个 Bates 编号\n\nENDATTACH　EDC0000015　附件范围的最后一个 Bates 编号\n\nCUSTODIAN　Smith, John（约翰·史密斯）　电子邮件：该电子邮件所在的邮箱\n原生文件：文件源自其文件的个人或部门名称\n\nFROM　John Smith（约翰·史密斯）　电子邮件：发件人\n原生文件：文件作者\n**多个条目之间应使用分号分隔\n\nTO　Coffman, Janice（珍妮丝·科夫曼）；LeeW　收件人\n[mailto:LeeW@MSN.com]　**多个条目之间应使用分号分隔\n\nCC　Frank Thompson（弗兰克·汤普森）[mailto:　抄送收件人\nfrank_Thompson@cdt.com]　**多个条目之间应使用分号分隔\n\nBCC　John Cain（约翰·凯恩）　密送收件人\n**多个条目之间应使用分号分隔\n\nSUBJECT　Board Meeting Minutes　电子邮件：电子邮件主题行；原生文件：文件标题（如有）\n\nFILE_NAME　BoardMeetingMinutes.docx　原生文件：原始原生文件的名称，包括扩展名\n\nDATE_SENT　10/12/2010　电子邮件：发送电子邮件的日期\n原生文件：（空）\n\nTIME_SENT/\nTIME_ZONE　07:05 PM GMT　电子邮件：发送电子邮件的时间/电子邮件标准化所用的时区\n\nTIME_ZONE　GMT　在转换过程中电子邮件被标准化所使用的时区。\n\nLINK　EDC0000001.msg　电子邮件或原生文件文件的超链接\n**所链接的文件必须按 FIRSTBATES 编号命名\n\nFILE_EXTEN　MSG　代表电子邮件或原生文件的文件类型扩展名\n\nAUTHOR　John Smith　电子邮件：（空）\n原生文件：文件作者\n\nDATE_CREATED　10/10/2010　电子邮件：（空）\n原生文件：文件创建日期\nCase 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 272 of 439\n\nTIME_CREATED　10:25 AM　电子邮件：（空）\n原生文件：文件创建时间\n**该数据必须为独立字段，且不得与 DATE_CREATED 字段合并\n\nDATE_MOD　10/12/2010　电子邮件：（空）\n原生文件：文件最后修改日期\n\nTIME_MOD　07:00 PM　电子邮件：（空）\n原生文件：文件最后修改时间\n**该数据必须为独立字段，且不得与 DATE_MOD 字段合并\n\nDATE_ACCESSD　10/12/2010　电子邮件：（空）\n原生文件：文件最后访问日期\n\nTIME_ACCESSD　07:00 PM　电子邮件：（空）\n原生文件：文件最后访问时间\n**该数据必须为独立字段，且不得与 DATE_ACCESSD 字段合并\n\nFILE_SIZE　5,952　原生文件文件/电子邮件的大小，单位为 KB\n\nPGCOUNT　1　原生文件文件/电子邮件中的页数\n\nPATH　电子邮件：（空）\nAgenda.doc　原生文件：原生文件文件的存储路径，包括原始文件名。\n\nINTFILEPATH　Personal Folders\\Deleted　电子邮件：电子邮件的原始位置，包括原始文件名。\nItems\\Board Meeting\nMinutes.msg　原生文件：（空）\n\nINTMSGID　<000805c2c71b\\$75977050\\$　电子邮件：唯一邮件 ID；原生文件：（空）\ncb8306d1@MSN>\n\nMD5HASH　d131dd02c5e6eec4693d9a0　文件的 MD5 哈希值。\n698aff95c\n2fcab58712467eab4004583e\nb8fb7f89\n\nOCRPATH　TEXT/001/EDC0000001.txt　原生文件提取文本的路径\n\n3. 各项请求独立适用并应独立解释，除非另有说明，任何一项请求均不限制其他任何请求的范围。\n\n4. 所有文件均应按通常业务过程中保存的方式提供，或者应予组织和标记，以对应于本请求中的类别。\n\n5. 本文所载各项请求均延及所有文件：(a) 由您占有、保管或控制的文件；或 (b) 由代表您行事的任何人占有、保管或控制的文件，\nCase 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 273 of 439\n\n包括您的律师或其他代表及顾问。每份文件均应完整提供。\n\n6. 如要求您提供的文件已不再由您占有、保管或控制，则您的答复必须：(a) 详细说明该文件的性质及其内容；(b) 识别准备或撰写该文件的人员（以及，如适用，该文件发送给的人员）；(c) 识别该文件准备或创建的日期；(d) 说明该文件是否：(i) 遗失或丢失，(ii) 已被销毁，(iii) 已自愿或非自愿转移给他人，或 (iv) 已以其他方式处置；(e) 说明该等处置的原因以及有关事实和情形；(f) 识别授权该等处置的人员；(g) 识别该等处置的日期或大致日期；(h) 说明该文件最后一次由您占有、保管或控制的时间；以及 (i) 识别目前占有、保管或控制该文件的人员（如有）。\n\n7. 如要求您提供的文件已被销毁，则除前述指示所要求的信息外，您的答复还必须说明：(a) 销毁该文件的原因；(b) 销毁该文件的人员身份；以及 (c) 指示销毁该文件的人员身份。\n\n8. 如您主张所请求的文件享有特权或属于律师工作成果，则您的答复必须：(a) 说明：(i) 足以支持您关于该文件享有特权之主张的文件描述，(ii) 文件标题，(iii) 文件日期，(iv) 文件作者，(v) 文件收件人，(vi) 收到或查看过该文件原件或任何草稿、副本或复制件的每一人员身份，(vii) 该文件本身或文件所载或所提及的任何信息，是否由任何其他人员占有、保管或控制；如是，则应说明该等人员身份，以及说明该等信息如何由其占有，(viii) 据以拒绝提供该文件的特权主张，以及 (ix) 您将据以支持该等特权主张的所有情形；以及 (b) 依照 D. Conn. L. Civ. R. 26(e)，就基于特权主张而拒绝提供的每份文件，制作一份特权清单，其中载明本指示第 (a) 部分所要求的全部信息。\nCase 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 274 of 439\n\n9. 如一份本应予提供的文件的一部分含有受特权主张约束的信息，则仅应依照上述指示从该文件中删除或遮蔽受特权主张约束的该部分，其余部分应予提供。\n\n10. 各项请求具有持续性。现指示您：(a) 一旦知悉先前答复不完整或不正确，应立即补充或更正其后获悉为不完整或不正确的任何答复；以及 (b) 提供根据以下内容所要求的任何补充文件：\n\n11. 如文件使用英语以外的语言，您应提供该文件。如文件使用英语以外的语言，且存在英文译本，您应同时提供两份文件。\n\n12. 对实体的所有提及均包括其所有关联方。\n\n13. 对个人姓名的所有提及均包括所有其他名称、别名或昵称。\n\n14. 除非另有明确说明，文件请求所涵盖的期间为自 February 5, 2012 起至应提交文件请求答复之日止。\n\nII. 解释规则\n\n15. (a) 任何单数名词的使用应解释为包括复数，反之亦然；(b) 任何时态的动词应解释为使用该动词的所有其他时态。\n\n16. (a) “and”和“or”应视需要作合取或析取解释，以使原本可能被解释为不在任何请求范围内的所有答复均纳入该请求的范围；(b) “each”和“any”应视为包括并涵盖“every”和“all”两个词。\n\nIII. 定义\n\n依据 D. Conn. Bankr. L.R. 2004-1(a) 纳入的 D. Conn. L. Civ. R. 26(c) 所提供的定义，以及 D. Conn. L. Civ. R. 26(d) 所提供的解释规则，适用于文件请求。此外，本文件请求中使用的下列术语具有如下含义：\n\n1. “You”、“Your”或“Yourself”系指 Eddy Aquino（又名 Eddy I. Sanchez Aquino），以及其所有代理人、律师、代表、雇员和/或任何代表其行事之人。\n\n2. “Debtor”系指 Ho Wan Kwok（又名 Miles Kwok、Miles Guo、Guo Wengui、Guo Haoyun、郭文贵或任何其他别名），以及其雇员、代理人、法律顾问、顾问或任何代表其行事之人。\n\n3. “Debtor's Son”系指 Qiang Guo（又名 Mileson Kwok、郭强或任何其他别名），以及其雇员、代理人、法律顾问、顾问或任何代表其行事之人。\n\n案件 22-50073，文件 3193，于 05/16/24 提交，于 05/16/24 10:28:21 登记，第 276 页，共 439 页\n\n4. “Debtor's Daughter”系指 Mei Guo（又名 Mei Gui、郭美或任何其他别名），以及其雇员、代理人、法律顾问、顾问或任何代表其行事之人。\n\n5. “Debtor's Purported Wife”系指 Hing Chi Ngok（又名 Hing Chi Ng、Yue Qingzhi、岳庆芝或任何其他别名），以及其雇员、代理人、法律顾问、顾问或任何代表其行事之人。\n\n6. “Debtor's Family”统称债务人、债务人之子、债务人之女及债务人的名义妻子，以及与债务人存在其他亲属关系的任何人。\n\n7. “Associated Individuals”单独及统称：(1) 持有、控制、保管或对债务人或债务人家庭所拥有、控制或享有的资产拥有处置权的所有个人；或 (2) 曾为一个或多个关联实体的雇员、董事或以其他方式与其有关联的所有个人，以及前述任何一方各自的雇员、代理人、法律顾问、顾问或任何代表其行事之人。该等关联个人包括但不限于：Anthony DiBattista、Alex Hadjicharalambous、Bernardo Enriquez、Bingshang Jiao、Beile Li、Brian W. Hofmeister、Charles Gruder、Daniel Podhaskie、David Fallon、Defeng Cao（又名 Wayne Cao、Max Cao）、Ding Lin、Dinggang Wang（又名 王定刚）、Eduardo Eurnekian、Ehsan Masud、Fiona Yu、Gladys Chow、Hao (Gavin) Li（又名 Huo Lai）、Hao Haidong（又名 郝海东）、Han Chunguang（又名 韩春光）、Haoran He、Ivan Lin、Haitham Khaled、Jason Miller、Jennifer Mercurio、Jesse Brown、Jessica Mastrogiovanni、Jie Zhang、Jintao Li、Karin Maistrello、Kyle Bass、Lihong Wei Lafrenz（又名 Sara Wei、魏丽红）、Linwan “Irene” Feng、Max Krasner、Melissa Francis、Michael Baranowitz、Min Yang、Melissa Mendez、Nadeem Akbar、Nan Li（又名 Chris Lee、Mei Guo Xiao Li）、Qidong Xia、Qu Guojiao（又名 Qu Guo Jiao、屈国姣）、Ridwan Mamode Saib、Ross Heinemeyer、Rui “Ray” Hao、Scott Barnett、Shih Hsin Yu、Shin Hee-Seup（又名 Hee Seup Shin）、Steve Bannon、Talha Zobair、Victor Cerda、Wen Xiao、Wencong Wang、William Gertz、William Je（又名 Je Kin Ming、Yu Jianming、余建明）、Xuebing Wang、Ya Li（又名 李娅）、Yinying (Aila) Wang（又名 Xiao Fei Xiang）、Yongping Yan（Shan Mu）、Yong Yu、Yue Zhou、Yumei Hao（又名 Ru Shui）、Yvette Wang（又名 Yanping Wang、Yan Ping Wang、王雁平）、Zhang Wei（又名 张魏）、Zhouer Wang（又名 Joe Wang）、Zhixuan Li 和 Ziyang Liu。\n\n案件 22-50073，文件 3193，于 05/16/24 提交，于 05/16/24 10:28:21 登记，第 277 页，共 439 页\n\n8. “Associated Entities”单独及统称：(1) 已由债务人或债务人家庭拥有、控制或投资的任何类型的所有组织或实体；或 (2) 对债务人或债务人家庭所拥有、控制或享有的任何资产直接或间接享有权益的所有组织或实体，以及前述任何一方各自的雇员、代理人、法律顾问、顾问或任何代表其行事之人。该等关联实体包括但不限于：1332156 B.C. Ltd.、7 Nod Hill LLC、AAGV Limited、ACA Investment Management Limited、ACA Capital Group Limited、Ace Decade Holdings Limited、AI Group Holdings Inc.、Alfa Global Ventures Limited、Alfonso Global Limited、Allied Capital Global Limited、Alpine Fiduciaries SA、Beijing Pangu Investment Co.、Beijing Pangu Investment Co. Ltd.、Beijing Pangu Investment Inc.、Beijing Zenith Holdings Company Limited、Blue Capital Limited、Booming Sail New York LLC、Bravo Luck Limited、Brent Petro、BSA Strategic Fund I、China Golden Spring (Hong Kong) Limited、Chuang Xin Limited、Crane Advisory Group LLC、Creative Apex Investments Limited、Crystal Breeze Investments Limited、Dawn State Limited、Eastern Profit Corporation Limited、Empire Growth Holdings、Elite Well Global Limited、Freedom Media Ventures Ltd.、Fung Wan Trading Inc.、G Club、G Club Operations LLC、G Club International Limited、G Club Investments Limited、G Fashion LLC、G-News Operations LLC、G News LLC、GMusic Inc.、G-Services LLC、G-Translators PTY LTD、GETTR USA, Inc.、Genever Holdings Corporation、Genever Holdings LLC、GFashion Media Group Inc.、GFNY, Inc.、Globalist International Limited、GNews Media Group Inc.、Golden Spring (New York) Ltd.、Guo Media、GTV Media Group, Inc.、GWGOPNZ Limited、GWGNZ Limited、Gypsy Mei Food Services, LLC、HCHK Property Management Inc.、HCHK Technologies Inc.、Hamilton Digital Assets FD SP、Hamilton Capital Holdings Inc.、Hamilton Opportunity Fund SPC、Head Win Group Limited、Himalaya Embassy、Himalaya Exchange、Himalaya Federal Reserve、Himalaya International Financial Group Ltd.、Himalaya Investment LLC、Himalaya (USA) Investment Management LLC、Himalaya New World Inc.、Himalaya Supervisory Organization、Himalaya Ventures、Holy City Hong Kong Ventures, Ltd.、Hudson Diamond Holding LLC、Hudson Diamond Holding Inc.、Hudson Diamond NY LLC、HK International Funds Investments (USA) Limited LLC、Hong Kong International Funds Investments Limited、Huk Trading Inc、Infinite Increase Limited、Infinitum Developments Limited、Japan Himalaya League, Inc.、Kalixun Trading Limited、Lamp Capital LLC、Leading Shine Limited、Leading Shine NY Limited、Lexington Property and Staffing Inc.、Long Gate Limited、MOS Himalaya Foundation Inc.、Maywind Trading LLC、New Federal State of China（又名 NFSC）、New York MOS Himalaya LLC、New Mulberry PTE Ltd.、Newpeople LLC、Noble Fame Global Limited、Pixshow Film Inc.、Roscalitar 2、Rosy Acme Ventures Limited、Rule of Law Foundation III, Inc.、Rule of Law Society、Rule of Law Society IV, Inc.、Santel LLC、Saraca Media Group, Inc.、Shiny Ace Ltd.、Shiny Times Holdings Ltd.、Stevenson, Wong & Co.、Taurus Fund LLC、Taurus Fund SP、Taurus Management LLC、The Lost Draft LLC、TM Primrose Limited、UA Himalaya Inc.、Voice of Guo Media, Inc.、Well Origin Ltd.、Wise Creation、Whitecroft Shore Limited、World Century Limited、Worldwide Opportunity Holdings Limited 和 ZIBA Limited。\n\n案件 22-50073，文件 3193，于 05/16/24 提交，于 05/16/24 10:28:21 登记，第 278 页，共 439 页\n\n9. “Including”或其任何变体，系指“包括但不限于”。\n\n案件 22-50073，文件 3193，于 05/16/24 提交，于 05/16/24 10:28:21 登记，第 279 页，共 439 页\n\n10. “And”和“or”系指“and/or”，并应同时作合取及析取解释，以最大限度扩大其范围。\n\n11. “Any”、“all”和“each”系指“每一个及全部”。\n\n12. “Each”和“every”系指“每一个及全部”。\n\n13. “Third Party”系指除您本人以外的个人或实体。\n\n14. “Transfer”具有《破产法》第 101(54) 条赋予该术语的含义。\n\n15. “Document”系指属于 Fed. R. Civ. P. 34 范围内的任何信息或物品，并包括但不限于任何种类、类型、性质或描述的每一项书面、记录或图形材料，该等材料现由或曾由您占有、保管或控制，包括电子邮件的所有纸质及电子副本、以电子形式保存的计算机文件、电子通信、短信、社交媒体帖子、推文、元数据、往来函件、备忘录、磁带、速记或手写笔记、任何种类的书面表格、图表、蓝图、图纸、草图、曲线图、计划、文章、规格、日记、信件、电报、照片、会议记录、合同、协议、调查、计算机打印件、任何种类的数据汇编、电传、电传传真、语音留言、发票、订购单、支票、汇票、对账单、贷项通知单、报告、持仓报告、摘要、索引、簿册、分类账、笔记本、附表、透明胶片、录音、目录、广告、宣传材料、胶片、录像带、录音带、CD、计算机磁盘、宣传册、小册子、穿孔卡、工时单、推文、社交媒体帖子或任何其他种类的书面或记录材料，以及其所有元数据，无论以何种方式储存（无论为有形或电子形式）、记录、制作或复制；并且还包括但不限于前述任何材料的草稿或副本，如其中含有原始文件中未见的任何种类的笔记、评论或标记，或在其他方面与原始文件不一致。\n\n案件 22-50073，文件 3193，于 05/16/24 提交，于 05/16/24 10:28:21 登记，第 280 页，共 439 页\n\n16. “Person(s)”系指个人、公司、独资企业、合伙企业、协会或任何其他实体。“Person”还包括任何代理人、代表或专家，包括但不限于律师或财务顾问。\n\n17. “Entity”系指任何自然人、公司、合伙企业、子公司、独资企业、商号、董事会、合资企业、协会、机构、主管机关、委员会或其他商业实体或法人，以及任何关联方、代理人、母公司，包括但不限于法律顾问、财务顾问或任何其他代表。\n\n18. “Regarding”系指关于、描述、构成、提及、与之有关、支持、赞成、反对、加强、削弱、位于其中、结合其考虑、对其产生影响、证明、表明、报告、记录、暗示、答复、与之相连、评论、就其而言、关于、与其相关、讨论、显示、描述、反映、分析、构成及属于。\n\n19. 就任何特定事项而言，“Relating to”、“relate(s) to”或“related to”系指包括但不限于构成、包含、涉及、载有、体现、反映、识别、陈述、直接或间接提及，或以任何方式与所识别的特定事项有关的任何文件。\n\n20. “Communication(s)”系指在最广泛可能意义上且不限于此的任何信息或知识传递（以事实、观点、询问或其他形式）。Communication(s)还指所有面谈、协议、询问或答复，无论是当面、通过电话、以书面形式，还是通过电子传输设备，并包括但不限于所有往来函件、电子邮件、录音、传送单、备忘录、电话通信、语音留言、电报、电传传真、电传复制件、电传、即时消息、聊天、短信、电话笔记或在内部或与第三方传递的笔记。\n\n案件 22-50073，文件 3193，于 05/16/24 提交，于 05/16/24 10:28:21 登记，第 281 页，共 439 页\n\n21. “资产”是指任何可用于产生正向经济价值的项目，包括但不限于由某一实体拥有、控制或为其利益而持有的任何具有经济价值并预期将提供未来利益的资源，包括但不限于所有不动产和动产、无形财产、投资、投资权或未来收益权、现金、银行账户、商品、证券、请求权、对实体的全部或部分控制权，以及预期的经济机会。\n\n22. “转让”应具有《破产法》第101(54)条赋予其的含义。\n\nIV. 应提交的文件\n\n1. 与债务人、债务人家属、债务人财产、关联个人或关联实体的任何收入或资产有关的所有文件。\n\n2. 与债务人的财务状况及其对债权人的义务有关的所有文件，包括但不限于与任何试图避免支付该等义务的行为有关的所有文件，以及与本次或任何其他实际或可能的破产或类似资不抵债程序有关的所有文件。\n\n3. 与债务人、债务人财产、债务人家属、关联实体或关联个人有关的任何资产负债表、银行对账单、账户对账单、财务报表、账户结单、电汇指示和/或确认、资金证明、存款证、持有证明、投资组合摘要或类似文件有关的所有文件，包括但不限于足以显示向上述任何一方作出的所有转让的全部文件。\n\n案件 22-50073 文件 3193 提交日期 05/16/24 登记日期 05/16/24 10:28:21 第 282 页，共 439 页\n\n4. 与债务人、债务人家属、关联个人或关联实体作出、与其进行或代表其进行的任何投资、业务往来或交易有关的所有文件。\n\n5. 与债务人、债务人家属、关联个人或关联实体之间的所有通信，以及与债务人、债务人家属、关联个人或关联实体之间通信有关的文件，包括与任何实体的运营、管理或决策有关的通信和文件，包括但不限于关联实体。\n\n6. 与向债务人、债务人家属、关联个人或关联实体作出、由其作出或与其进行的任何转让、投资或其他交易或业务往来有关的所有文件。\n\n7. 与债务人曾经占用或使用的任何财产有关的所有文件，包括但不限于位于 Connecticut（康涅狄格州）Greenwich（格林尼治）373 Taconic Rd. 的住宅房产；位于 Connecticut（康涅狄格州）Greenwich（格林尼治）33 Ferncliff Rd. 的住宅房产；位于 Connecticut（康涅狄格州）Wilton（威尔顿）354 Nod Hill Rd 的住宅房产；位于 United Kingdom（英国）London（伦敦）5 Princes Gate London, United Kingdom SW7 1QJ 的公寓或产权公寓；以及位于 New Jersey（新泽西州）Mahwah（马瓦）675 Ramapo Valley Road, Mahwah, New Jersey 07430 的住宅房产。\n\n8. 与债务人拥有、控制或使用的任何航空器有关的所有文件，包括但不限于：(i) 尾号为 T7-GQM 的航空器及在 San Marino（圣马力诺）注册的任何其他航空器，包括但不限于所有登记文件副本及显示该等航空器所执行航班和该等航班上人员的飞行舱单；以及 (ii) 任何 Cirrus SF50 航空器。\n\n案件 22-50073 文件 3193 提交日期 05/16/24 登记日期 05/16/24 10:28:21 第 283 页，共 439 页\n\n9. 与向债务人、债务人财产、债务人家属或关联实体提供、由其提供或代表其提供的任何赠与、利益或贷款有关的所有文件，包括但不限于足以显示该等赠与、利益或贷款的金额；该等赠与、利益或贷款的使用目的；提供该等赠与、利益或贷款的时间；以及任何贷款的条款、就任何贷款作出的所有陈述与保证、任何贷款的利率，以及任何贷款付款的所有证据的文件。\n\n10. 与由债务人、债务人财产、债务人家属或关联实体设立、代表其设立或为其利益设立的任何信托或类似文书有关的所有文件，包括但不限于足以显示信托设立的时间、设立人、为谁的利益设立以及信托本金的文件。\n\n11. 与涉及债务人的任何法律争议相关的任何义务、请求权、责任或债务有关的所有文件，包括但不限于与任何地方、州、联邦或国际机构前的任何诉讼有关的文件，无论该机构为行政机构、法院、合议庭或替代性争议解决实体。\n\n12. 与债务人、债务人家属或关联个人之间的所有文件和通信。\n\n13. 你方任何律师或其他顾问与债务人、债务人家属或关联个人之间的所有文件和通信。\n\n案件 22-50073 文件 3193 提交日期 05/16/24 登记日期 05/16/24 10:28:21 第 284 页，共 439 页\n\n14. 与你方目前或曾经持有权益的任何关联实体有关的所有文件。\n\n案件 22-50073 文件 3193 提交日期 05/16/24 登记日期 05/16/24 10:28:21 第 285 页，共 439 页\n\n附件 C-15\n\nB2540（表格 2540——《规则 2004 审查传票》）(12/15) 案件 22-50073 文件 3193 提交日期 05/16/24 登记日期 05/16/24 10:28:21 第 286 页，共 439 页\n\nUNITED STATES BANKRUPTCY COURT（美国破产法院）\n\nDistrict of Connecticut（康涅狄格州地区）\n\n关于 HO WAN KWOK（郭文贵）等人，\n\n1 案号 22-50073 (JAM)\n\n债务人 第11章\n\n（合并管理）\n\n规则 2004 审查传票\n\n致：Summer L. Bridges（萨默·L·布里奇斯）\n\n（传票所指向之人的姓名）\n\n证言：现命令你于下列规定的时间、日期和地点到场，依《联邦破产程序规则》规则 2004 接受审查并作证。随附准许该审查的法院命令副本。\n\n地点　日期和时间\n\nN/A　N/A\n\n审查将采用以下方式记录：N/A\n\n提交：你或你的代表还必须携带以下文件、电子存储信息或物品参加审查，并必须允许对该材料进行检查、复制、测试或取样：\n\n见随附的文件提交请求。\n\n《联邦民事诉讼规则》45 的下列规定，依《联邦破产程序规则》9016 适用于破产案件，现随附于后——有关履行地点的规则 45(c)；有关你作为传票对象所受保护的规则 45(d)；以及有关你对本传票的回应义务及未作回应可能产生后果的规则 45(e) 和 45(g)。\n\n日期：May , 2024\n\n法院书记员\n\n或\n\n书记员或副书记员签字　律师签字\n\n代表发出或请求本传票的 Luc A. Despins（吕克·A·德斯平斯）第11章受托人的律师的姓名、地址、电子邮箱地址和电话号码如下：\n\nPatrick R. Linsey, Esq.（帕特里克·R·林赛律师）；Neubert, Pepe & Monteith, P.C.（纽伯特、佩佩与蒙泰思专业公司）；195 Church Street, 13th Floor, New Haven, Connecticut 06510；plinsey@npmlaw.com；(203) 781-2847\n\n致发出或请求本传票之人的通知\n\n如本传票命令在审判前提交文件、电子存储信息或有形物品，或检查场所，则必须在向传票所指向之人送达前，向每一方当事人送达通知及本传票副本。Fed. R. Civ. P. 45(a)(4)。\n\n软件版权 (c) 1996-2022 Best Case, LLC（贝斯特凯斯有限责任公司）- www.bestcase.com Best Case Bankruptcy 1 本第11章案件中的债务人为 Ho Wan Kwok（郭文贵）（又名 Guo Wengui（郭文贵）、Miles Guo（郭文贵）和 Miles Kwok（郭文贵），以及众多其他别名）（税务识别号码后四位：9595）、Genever Holdings LLC（税务识别号码后四位：8202）及 Genever Holdings Corporation。受托人、Genever Holdings LLC 和 Genever Holdings Corporation 的邮寄地址为 Paul Hastings LLP（普衡律师事务所），200 Park Avenue, New York, NY 10166，转交 Luc A. Despins，作为 Ho Wan Kwok 财产的受托人（仅限于通知和通信之目的）。\n\n送达证明\n\n（除非 Fed. R. Civ. P. 45 要求，否则本节不应向法院提交。）\n\n我于（日期）收到向（个人姓名及职务，如有）送达的本传票。\n\n我按如下方式向所列明之人交付副本，以送达本传票：\n\n于（日期）送达；或\n\n我未获执行而退回本传票，原因为：\n\n除非本传票代表 United States（美国）或其官员或代理人发出，我还已向证人预付一天出席费用及法律允许的里程费用，金额为 \\$ 。\n\n我的差旅费用为 \\$ ，服务费用为 \\$ ，合计为 \\$ 。\n\n我在伪证处罚的约束下声明，此信息真实且正确。\n\n日期：\n\n送达人员签字\n\n印刷体姓名及职务\n\n送达人员地址\n\n有关尝试送达等事项的补充信息：\n\n《联邦民事诉讼规则》45(c)、(d)、(e) 和 (g)（自 12/1/13 起生效）（依《联邦破产程序规则》9016 适用于破产案件）\n\n(c) 履行地点。\n\n(1) 审判、听证或证言录取。传票仅可按如下规定命令某人出席审判、听证或证言录取：\n\n(A) 在该人居住、受雇或通常亲自从事业务所在地 100 英里范围内；或\n\n(B) 在该人居住、受雇或通常亲自从事业务所在州内，若该人\n\n(i) 是一方当事人或一方当事人的高级职员；或\n\n(ii) 被命令出席审判且不会产生重大费用。\n\n(2) 其他证据开示。传票可以命令：\n\n(A) 在该人居住、受雇或通常亲自从事业务所在地 100 英里范围内的地点提交文件、电子存储信息或物品；以及\n\n(B) 在被检查的场所检查场所。\n\n(d) 对传票对象的保护；执行。\n\n(1) 避免不当负担或费用；制裁。负责发出和送达传票的一方当事人或律师必须采取合理措施，避免对传票对象施加不当负担或费用。要求履行的地区法院必须执行该义务，并对未遵守者——当事人或律师——施加适当制裁，其中可包括损失的收入和合理的律师费。\n\n(2) 命令提交材料或允许检查。\n\n(A) 无须到场。被命令提交文件、电子存储信息或有形物品，或允许检查场所的人，除非同时被命令出席证言录取、听证或审判，否则无须亲自到提交或检查地点到场。\n\n(B) 异议。被命令提交文件或有形物品，或允许检查的人，可以向传票指定的当事人或律师送达书面异议，反对检查、复制、测试或取样任何或全部材料，或反对检查场所——或反对以所请求的一种或多种形式提交电子存储信息。异议必须在指定履行时间或传票送达后 14 天两者中较早者之前送达。如提出异议，适用下列规则：\n\n(i) 在任何时间，经通知被命令之人，送达方可以向要求履行的地区法院提出动议，请求作出强制提交或检查的命令。\n\n(ii) 仅可依命令所指示要求实施该等行为，且该命令必须保护并非当事人或当事人高级职员之人免受因履行而产生的重大费用。\n\n(3) 撤销或修改传票。\n\n(A) 必须撤销或修改的情形。经及时动议，要求履行的地区法院必须撤销或修改有下列情形的传票：\n\n(i) 未给予合理履行时间；\n\n(ii) 要求某人在 Rule 45(c) 规定的地理范围以外履行；\r\n\r\n(iii) 要求披露享有特权或受其他保护的事项，且不存在任何适用的例外或豁免；或\r\n\r\n(iv) 使某人承受不当负担。\r\n\r\n(B) 准许情形。为保护受传票约束或受其影响的人，要求履行传票的地区法院可以依动议撤销或修改传票，如果该传票要求：\r\n\r\n(i) 披露商业秘密或其他保密的研究、开发或商业信息；或\r\n\r\n(ii) 披露未受聘专家的意见或信息，而该意见或信息未描述争议中的具体事件，且系该专家未应任何一方当事人请求进行研究所得的结果。\r\n\r\n(C) 以规定条件作为替代方案。在 Rule 45(d)(3)(B) 所述情形下，如送达方：\r\n\r\n(i) 证明其对证言或材料具有实质性需要，且若不遭受不当困难便无法通过其他方式满足该需要；并且\r\n\r\n(ii) 确保被传唤人将获得合理补偿，\r\n\r\n法院可以不撤销或修改传票，而命令其在规定条件下出庭或提交材料。\r\n\r\n(e) 回应传票的义务。\r\n\r\n(1) 提交文件或电子存储信息。下列程序适用于提交文件或电子存储信息：\r\n\r\n(A) 文件。回应要求提交文件的传票的人，必须按照其在日常业务过程中保存的方式提交文件，或者必须整理并标注文件，使其与请求中的类别相对应。\r\n\r\n(B) 未规定电子存储信息提交形式。如果传票未规定提交电子存储信息的形式，回应人必须以该信息通常保存的一种或多种形式，或以一种或多种合理可用的形式提交。\r\n\r\n(C) 电子存储信息仅以一种形式提交。回应人无需以一种以上的形式提交相同的电子存储信息。\r\n\r\n(D) 无法合理获取的电子存储信息。回应人无需从其认定为因不当负担或费用而无法合理获取的来源提供电子存储信息的发现。在提出强制发现动议或申请保护令时，回应人必须证明该信息因不当负担或费用而无法合理获取。如作出该证明，法院在考虑 Rule 26(b)(2)(C) 的限制后，如请求方证明存在正当理由，仍可命令从该等来源进行发现。法院可以规定发现的条件。\r\n\r\n(2) 主张特权或保护。\r\n\r\n(A) 被扣留的信息。以该信息享有特权或作为审判准备材料受保护为由扣留被传唤信息的人，必须：(i) 明确提出该主张；并且\r\n\r\n(ii) 以一种在不披露本身享有特权或受保护的信息的情况下，能够使各方当事人评估该主张的方式，说明被扣留文件、通信或有形物的性质。\r\n\r\n(B) 已提交的信息。如果为回应传票而提交的信息被主张享有特权或作为审判准备材料受保护，提出该主张的人可以通知任何已收到该信息的当事人该主张及其依据。收到通知后，当事人必须立即返还、隔离或销毁所指明的信息及其持有的任何副本；在该主张得到解决前不得使用或披露该信息；如该当事人在收到通知前已披露该信息，必须采取合理步骤追回该信息；并可立即向要求履行传票的地区法院密封提交该信息，以裁定该主张。提交该信息的人必须在该主张得到解决前保存该信息。\r\n\r\n(g) 藐视法庭。要求履行传票的地区法院——以及在动议被移送后签发传票的法院——可以认定已经受送达人在无充分理由的情况下未遵守传票或与之相关命令的人构成藐视法庭。\r\n\r\n有关获取传票材料，请参见 Fed.R.Civ.P.45(a) Committee Note (2013)\r\n\r\n……\r\n\r\n文件提交请求\r\n\r\nI. 指示\r\n\r\n1. 除非另有说明，下列文件请求（以下简称“请求”，每一项以下简称“一项请求”）必须分别且具体地作出回应。除非基于善意提出异议，否则必须完整回答每一项请求；如提出异议，必须按下文所述详细说明异议理由。如果异议仅涉及某项请求的一部分，或其中包含的一个词、短语或条款，您必须仅对该部分提出异议，并回应请求的其余部分。\r\n\r\n2. 电子存储信息必须依照下列指示提交：\r\n\r\na. 图像。黑白图像必须为 300 DPI Group IV 单页 TIFF 文件。彩色图像必须以 JPEG 格式提交。文件名不得含有嵌入空格或特殊字符（包括逗号）。文件夹名称不得含有嵌入空格或特殊字符（包括逗号）。所有 TIFF 图像文件必须具有唯一的文件名，即 Bates 编号。每幅图像的右下角必须标注连续的 Bates 编号。每个文件夹中的 TIFF 文件数量不得超过 1000 个文件。Excel 电子表格应具有以该文件 Bates 编号命名的占位图像。\r\n\r\nb. 图像加载文件\r\n\r\na. Concordance®（康考丹斯）数据文件。数据文件（.DAT）包含将加载至 Concordance® 数据库的全部字段化信息。.DAT 文件的第一行必须为标识字段名称的标题行。.DAT 文件必须使用以下 Concordance® 默认分隔符：逗号 ASCII 字符（020）；引号 þ ASCII 字符（254）。日期字段应采用以下格式提供：mm/dd/yyyy。日期字段和时间字段必须为两个独立字段。如文件包括已成像的电子邮件及附件，必须包括附件字段，以保持电子邮件与其附件之间的父/子关系。必须包括 OCRPATH 字段，以提供已提交存储介质上提取文本文件的文件路径和名称。文本文件必须以 FIRSTBATES 命名。不得在 .DAT 文件中包含文本。对于含有原生文件的文件，必须包括 LINK 字段，以提供原生文件的文件路径和名称。原生文件必须以 FIRSTBATES 命名。\r\n\r\nb. Concordance Image® 或 Opticon 交叉引用文件。图像交叉引用文件（.LOG 或 .OPT）将图像链接至数据库记录。其应为逗号分隔文件，每行由七个字段构成，并且数据库中的每幅图像均应在交叉引用文件中有一行，格式如下：ImageID,VolumeLabel,ImageFilePath,DocumentBreak,FolderBreak,Box Break,PageCoun。\r\n\r\nc. 文件文本。文本必须作为独立文本文件提交，而非作为 .DAT 文件中的字段。文本文件的完整路径（OCRPATH）应包括在 .DAT 文件中。建议使用按 FIRSTBATES/Image Key 命名的文件级 ANSI 文本文件。提取的文本文件必须置于单独文件夹中，每个文件夹中的文本文件数量不得超过 1,000 个文件。文件夹名称中不得有特殊字符（包括逗号）。文本文件必须按文件级别提供。\r\n\r\nd. 特定文件类型的原生提交。为完整理解其内容和含义而合理需要以原生格式查看的文件类型，必须以原生格式提交。其中包括但不限于电子表格、类似电子表格的文件（Microsoft Excel、逗号分隔值、制表符分隔值等）、Microsoft PowerPoint 或其他特殊演示文件、数据库文件以及音频/视频文件。提供一张标有 Bates 编号的分隔页图像，说明存在原生文件，并将原生文件的路径作为 .dat 文件中的一个字段列入。提交的原生文件应以与该文件分隔页相对应的 Bates 编号命名。将原生文件归入以递增方式命名的“NATIVE”目录中，并与图像目录分开。\r\n\r\ne. 去重。对于存在完全重复件的每份电子文件，仅提交一份副本。对于电子邮件，根据由 BCC、Body、CC、From、IntMsgID、To 和 Attach 属性生成的 MD5 哈希值合并重复件。对于电子邮件附件和独立电子文件，根据整个文件的 MD5 哈希值合并重复件。\r\n\r\nf. 元数据。以符合 Concordance 标准的加载文件（.dat）形式，为每份文件提交提取的元数据。.DAT 文件的第一行必须为标识字段名称的标题行。.DAT 文件必须使用以下 Concordance 默认分隔符：逗号 , ASCII 字符（020）；引号 þ ASCII 字符（254）\r\n\r\n日期字段应采用以下格式提供：mm/dd/yyyy。日期字段和时间字段必须为两个独立字段。下列为所需元数据：\r\n\r\nCase 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 291 of 439\r\n\r\n字段名称　示例数据　说明\r\n\r\nFIRSTBATES　EDC0000001　原生文件文件/电子邮件的首个 Bates 编号\r\n\r\nLASTBATES　EDC0000001　原生文件文件/电子邮件的最后一个 Bates 编号\r\n\r\nLASTBATES 字段应针对单页文件填写\r\n\r\nATTACHRANGE　EDC0000001　父文件首页的 Bates 编号至最后一个附件“子”文件最后一页的 Bates 编号\r\nEDC0000015\r\n\r\nBEGATTACH　EDC0000001　附件范围的首个 Bates 编号\r\n\r\nENDATTACH　EDC0000015　附件范围的最后一个 Bates 编号\r\n\r\nCUSTODIAN　Smith, John（约翰·史密斯）　电子邮件：电子邮件所在的邮箱\r\n原生文件：文件源自其文件的个人或部门名称\r\n\r\nFROM　John Smith（约翰·史密斯）　电子邮件：发件人\r\n原生文件：文件作者\r\n多个条目之间应使用分号分隔\r\n\r\nTO　Coffman, Janice（珍妮丝·科夫曼）；LeeW　收件人\r\n[mailto:LeeW@MSN.com]　多个条目之间应使用分号分隔\r\n\r\nCC　Frank Thompson（弗兰克·汤普森）[mailto:　抄送收件人\r\nfrank_Thompson@cdt.com]　多个条目之间应使用分号分隔\r\n\r\nBCC　John Cain（约翰·凯恩）　密送收件人\r\n多个条目之间应使用分号分隔\r\n\r\nSUBJECT　Board Meeting Minutes　电子邮件：电子邮件主题行；原生文件：文件标题（如有）\r\n\r\nFILE_NAME　BoardMeetingMinutes.docx　原生文件：原始原生文件的名称，包括扩展名\r\n\r\nDATE_SENT　10/12/2010　电子邮件：电子邮件发送日期\r\n原生文件：（空）\r\n\r\nTIME_SENT/　07:05 PM GMT　电子邮件：电子邮件发送时间/电子邮件标准化所在的时区\r\nTIME_ZONE\r\n\r\nTIME_ZONE　GMT　在转换过程中电子邮件被标准化所在的时区。\r\n\r\nLINK　EDC0000001.msg　电子邮件或原生文件文件的超链接\r\n链接文件必须以 FIRSTBATES 编号命名\r\n\r\nFILE_EXTEN　MSG　代表电子邮件或原生文件的文件类型扩展名\r\n\r\nAUTHOR　John Smith（约翰·史密斯）　电子邮件：（空）\r\n原生文件：文件作者\r\n\r\nDATE_CREATED　10/10/2010　电子邮件：（空）\r\n原生文件：文件创建日期\r\n\r\nCase 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 292 of 439\r\n\r\nTIME_CREATED　10:25 AM　电子邮件：（空）\n\n原生：文档创建时间\n此数据必须为单独字段，且不得与 DATE_CREATED 字段合并\nDATE_MOD　10/12/2010　电子邮件：（空）\n原生：文档最后修改日期\nTIME_MOD　07:00 PM　电子邮件：（空）\n原生：文档最后修改时间\n此数据必须为单独字段，且不得与 DATE_MOD 字段合并\nDATE_ACCESSD　10/12/2010　电子邮件：（空）\n原生：文档最后访问日期\nTIME_ACCESSD　07:00 PM　电子邮件：（空）\n原生：文档最后访问时间\n此数据必须为单独字段，且不得与 DATE_ACCESSD 字段合并\nFILE_SIZE　5,952　原生文件文档/电子邮件的大小，以 KB 计\nPGCOUNT　1　原生文件文档/电子邮件的页数\nPATH　电子邮件：（空）\nAgenda.doc　原生：存储原生文件文档的路径，包括原始文件名。\nINTFILEPATH　Personal Folders\\Deleted　电子邮件：电子邮件的原始位置，包括\nItems\\Board Meeting　原始文件名。\nMinutes.msg　原生：（空）\nINTMSGID　<000805c2c71b\\$75977050\\$　电子邮件：唯一邮件 ID 原生：（空）\ncb8306d1@MSN>\nMD5HASH　d131dd02c5e6eec4693d9a0698aff95c2fcab58712467eab4004583eb8fb7f89　文档的 MD5 哈希值。\nOCRPATH　TEXT/001/EDC0000001.txt　原生文件提取文本的路径\n\n3. 各项请求均独立运作并应独立解释；除非另有说明，任何一项请求均不限制任何其他请求的范围。\n\n4. 所有文件均应按照日常业务过程中保存的方式提供，或者应予组织并标注，以对应本请求中的类别。\n\n5. 每项载于本文件中的请求均延及下列所有文件：(a) 由贵方占有、保管或控制的文件；或 (b) 由任何代表贵方行事之人占有、保管或控制的文件，\n案号 22-50073，文件 3193，提交于 05/16/24，登记于 05/16/24 10:28:21，第 293 页，共 439 页\n包括贵方律师或其他代表和顾问。每份文件均应完整提供。\n\n6. 如要求贵方提供一份已不再由贵方占有、保管或控制的文件，则贵方的答复必须：(a) 详细说明该文件的性质及其内容；(b) 指明编制或撰写该文件的人员（以及，如适用，获送该文件的人员）；(c) 指明该文件编制或创建的日期；(d) 说明该文件是否：(i) 遗失或丢失，(ii) 已被销毁，(iii) 已自愿或非自愿地转移给他人，或 (iv) 以其他方式被处置；(e) 说明该等处置的理由以及相关事实和情形；(f) 指明授权该等处置的人员；(g) 指明该等处置的日期或大致日期；(h) 说明该文件最近一次由贵方占有、保管或控制的时间；以及 (i) 指明目前占有、保管或控制该文件的人员（如有）。\n\n7. 如要求贵方提供一份已被销毁的文件，则除前述指示所要求的信息外，贵方的答复还必须说明：(a) 销毁该文件的理由；(b) 销毁该文件的人员身份；以及 (c) 指示销毁该文件的人员身份。\n\n8. 如贵方主张所请求的文件享有特权或属于律师工作成果，则贵方的答复必须：(a) 陈述：(i) 足以支持贵方关于该文件享有特权之主张的文件说明，(ii) 文件标题，(iii) 文件日期，(iv) 文件作者，(v) 文件收件人，(vi) 收到或阅览该文件原件或任何草稿、副本或复制件的每一人员身份，(vii) 该文件本身或该文件所载或所提及的任何信息是否由任何其他人员占有、保管或控制，如是，则该等人员的身份，\n案号 22-50073，文件 3193，提交于 05/16/24，登记于 05/16/24 10:28:21，第 294 页，共 439 页\n以及说明该等信息如何进入其占有范围，(viii) 据以扣留该文件的特权主张，以及 (ix) 贵方将据以支持该特权主张的所有情形；以及 (b) 就每一份基于特权主张而扣留的文件，依照 D. Conn. L. Civ. R. 26(e)，提供一份特权清单，载明本指示第 (a) 部分所要求的全部信息。\n\n9. 如一份原本应予提供的文件的一部分包含受特权主张约束的信息，则仅应按照上述指示从该文件中删除或涂黑受特权主张约束的部分，其余部分应予提供。\n\n10. 本请求具有持续性。特此指示贵方：(a) 一旦得知先前答复不完整或不正确，应立即补充或更正其后得知不完整或不正确的任何答复；以及 (b) 提供依据下述规定所要求的任何附加文件。\n\n11. 如文件使用英语以外的语言，贵方应提供该文件。如文件使用英语以外的语言，且存在英文译本，贵方应同时提供两份文件。\n\n12. 对实体的一切提及均包括其所有关联方。\n\n13. 对个人姓名的一切提及均包括所有其他名称、别名或昵称。\n\n14. 除非另有明确说明，文件请求涵盖的期间为自 February 5, 2012 起至文件请求答复到期之日止。\n案号 22-50073，文件 3193，提交于 05/16/24，登记于 05/16/24 10:28:21，第 295 页，共 439 页\nII. 解释规则\n\n15. (a) 任何单数名词的使用应解释为包括复数，反之亦然；以及 (b) 任何时态动词的使用应解释为该动词所有其他时态的使用。\n\n16. (a) “and”和“or”应视必要分别解释为连词或选择连词，以将原本可能被解释为不在任何请求范围内的所有答复纳入该请求范围；以及 (b) “each”和“any”应视为包括并涵盖“every”和“all”两词。\nIII. 定义\n\n由 D. Conn. L. Civ. R. 26(c) 规定的定义及由 D. Conn. L. Civ. R. 26(d) 规定的解释规则，经 D. Conn. Bankr. L.R. 2004-1(a) 纳入后，适用于文件请求。此外，本文件请求中使用的下列术语具有下列含义：\n\n1. “贵方”或“贵方的”或“贵方本人”系指 Summer L. Bridges（萨默·L·布里奇斯），以及其所有代理人、律师、代表、雇员和/或任何代表其行事之人。\n\n2. “债务人”系指 Ho Wan Kwok（郭文贵）（亦称 Miles Kwok、Miles Guo、Guo Wengui、Guo Haoyun、郭文贵或任何其他别名），以及其雇员、代理人、律师、顾问或任何代表其行事之人。\n\n3. “债务人之子”系指 Qiang Guo（郭强）（亦称 Mileson Kwok、郭强或任何其他别名），以及其雇员、代理人、律师、顾问或任何代表其行事之人。\n案号 22-50073，文件 3193，提交于 05/16/24，登记于 05/16/24 10:28:21，第 296 页，共 439 页\n\n4. “债务人之女”系指 Mei Guo（郭美）（亦称 Mei Gui、郭美或任何其他别名），以及其雇员、代理人、律师、顾问或任何代表其行事之人。\n\n5. “债务人声称的妻子”系指 Hing Chi Ngok（岳庆芝）（亦称 Hing Chi Ng、Yue Qingzhi、岳庆芝或任何其他别名），以及其雇员、代理人、律师、顾问或任何代表其行事之人。\n\n6. “债务人家属”统称债务人、债务人之子、债务人之女、债务人声称的妻子，以及与债务人有任何其他亲属关系之人。\n\n7. “关联个人”系指单独或共同符合下列情形的所有个人：(1) 持有、控制、保管或对债务人或债务人家属拥有、控制或享有的资产具有酌处权；或 (2) 曾为一个或多个关联实体的雇员、董事，或以其他方式与其关联；并包括前述各方各自的雇员、代理人、律师、顾问或任何代表前述任何一方行事之人。该等关联个人包括但不限于：Anthony DiBattista（安东尼·迪巴蒂斯塔）、Alex Hadjicharalambous（亚历克斯·哈吉查拉兰布斯）、Bernardo Enriquez（贝尔纳多·恩里克斯）、Bingshang Jiao（焦炳尚）、Beile Li（李贝乐）、Brian W. Hofmeister（布赖恩·W·霍夫迈斯特）、Charles Gruder（查尔斯·格鲁德）、Daniel Podhaskie（丹尼尔·波达斯基）、David Fallon（大卫·法伦）、Defeng Cao（曹德峰）（亦称 Wayne Cao、Max Cao）、Ding Lin（丁林）、Dinggang Wang（王定刚）（亦称 王定刚）、Eduardo Eurnekian（爱德华多·欧尔内基安）、Ehsan Masud（埃赫桑·马苏德）、Fiona Yu（余菲奥娜）、Gladys Chow（周格拉迪斯）、Hao (Gavin) Li（李昊）（亦称 Huo Lai）、Hao Haidong（郝海东）（亦称 郝海东）、Han Chunguang（韩春光）（亦称 韩春光）、Haoran He（何浩然）、Ivan Lin（林艾文）、Haitham Khaled（海赛姆·哈立德）、Jason Miller（杰森·米勒）、Jennifer Mercurio（詹妮弗·默丘里奥）、Jesse Brown（杰西·布朗）、Jessica Mastrogiovanni（杰西卡·马斯特罗焦瓦尼）、Jie Zhang（张杰）、Jintao Li（李金涛）、Karin Maistrello（卡琳·梅斯特雷洛）、Kyle Bass（凯尔·巴斯）、Lihong Wei Lafrenz（魏丽红）（亦称 Sara Wei、魏丽红）、Linwan “Irene” Feng（冯林婉）、Max Krasner（马克斯·克拉斯纳）、Melissa Francis（梅丽莎·弗朗西斯）、Michael Baranowitz（迈克尔·巴拉诺维茨）、Min Yang（杨敏）、Melissa Mendez（梅丽莎·门德斯）、Nadeem Akbar（纳迪姆·阿克巴尔）、Nan Li（李楠）（亦称 Chris Lee、Mei Guo Xiao Li）、Qidong Xia（夏启东）、Qu Guojiao（屈国姣）（亦称 Qu Guo Jiao、屈国姣）、Ridwan Mamode Saib（里德万·马莫德·赛义卜）、Ross Heinemeyer（罗斯·海内迈耶）、Rui “Ray” Hao（郝睿）、Scott Barnett（斯科特·巴内特）、Shih Hsin Yu（余世新）、Shin Hee-\n案号 22-50073，文件 3193，提交于 05/16/24，登记于 05/16/24 10:28:21，第 297 页，共 439 页\nSeup（申熙燮）（亦称 Hee Seup Shin）、Steve Bannon（史蒂夫·班农）、Talha Zobair（塔尔哈·佐拜尔）、Victor Cerda（维克托·塞尔达）、Wen Xiao（肖文）、Wencong Wang（王文聪）、William Gertz（威廉·格茨）、William Je（余建明）（亦称 Je Kin Ming、Yu Jianming、余建明）、Xuebing Wang（王雪冰）、Ya Li（李娅）（亦称 李娅）、Yinying (Aila) Wang（王茵茵）（亦称 Xiao Fei Xiang）、Yongping Yan（闫永平）（Shan Mu）、Yong Yu（俞勇）、Yue Zhou（周越）、Yumei Hao（郝玉梅）（亦称 Ru Shui）、Yvette Wang（王雁平）（亦称 Yanping Wang、Yan Ping Wang、王雁平）、Zhang Wei（张魏）（亦称 张魏）、Zhouer Wang（王周儿）（亦称 Joe Wang）、Zhixuan Li（李志轩）以及 Ziyang Liu（刘子扬）。\n\n8. “关联实体”系指单独或共同符合下列情形的所有任何类型组织或实体：(1) 曾由债务人或债务人家属拥有、控制或投资；或 (2) 对债务人或债务人家属拥有、控制或享有的任何资产直接或间接享有权益；并包括前述各方各自的雇员、代理人、律师、顾问或任何代表前述任何一方行事之人。该等关联实体包括但不限于：1332156 B.C. Ltd.（1332156 B.C. 有限公司）、7 Nod Hill LLC（7 Nod Hill 有限责任公司）、AAGV Limited（AAGV 有限公司）、ACA Investment Management Limited（ACA 投资管理有限公司）、ACA Capital Group Limited（ACA 资本集团有限公司）、Ace Decade Holdings Limited（王牌十年控股有限公司）、AI Group Holdings Inc.（AI 集团控股公司）、Alfa Global Ventures Limited（阿尔法全球创投有限公司）、Alfonso Global Limited（阿方索全球有限公司）、Allied Capital Global Limited（联合资本全球有限公司）、Alpine Fiduciaries SA（阿尔卑斯受托服务股份公司）、Beijing Pangu Investment Co.（北京盘古投资公司）、Beijing Pangu Investment Co. Ltd.（北京盘古投资有限公司）、Beijing Pangu Investment Inc.（北京盘古投资股份有限公司）、Beijing Zenith Holdings Company Limited（北京泽尼思控股有限公司）、Blue Capital Limited（蓝色资本有限公司）、Booming Sail New York LLC（纽约兴盛帆船有限责任公司）、Bravo Luck Limited（好运有限公司）、Brent Petro（布伦特石油）、BSA Strategic Fund I（BSA 战略基金 I）、China Golden Spring (Hong Kong) Limited（中国金泉〈香港〉有限公司）、Chuang Xin Limited（创新有限公司）、Crane Advisory Group LLC（鹤顾问集团有限责任公司）、Creative Apex Investments Limited（创意顶峰投资有限公司）、Crystal Breeze Investments Limited（水晶微风投资有限公司）、Dawn State Limited（黎明州有限公司）、Eastern Profit Corporation Limited（东方利润有限公司）、Empire Growth Holdings（帝国增长控股）、Elite Well Global Limited（精英环球有限公司）、Freedom Media Ventures Ltd.（自由媒体创投有限公司）、Fung Wan Trading Inc.（风云贸易公司）、G Club（G 俱乐部）、G Club Operations LLC（G 俱乐部运营有限责任公司）、G Club International Limited（G 俱乐部国际有限公司）、G Club Investments Limited（G 俱乐部投资有限公司）、G Fashion LLC（G 时尚有限责任公司）、G-News Operations LLC（G 新闻运营有限责任公司）、G News LLC（G 新闻有限责任公司）、GMusic Inc.（G 音乐公司）、G-Services LLC（G 服务有限责任公司）、G-Translators PTY LTD（G 翻译服务有限公司）、GETTR USA, Inc.（GETTR 美国公司）、Genever Holdings Corporation（Genever 控股公司）、Genever Holdings\n案号 22-50073，文件 3193，提交于 05/16/24，登记于 05/16/24 10:28:21，第 298 页，共 439 页\n\n有限责任公司、GFashion Media Group Inc.（G时尚传媒集团公司）、GFNY, Inc.（GFNY公司）、Globalist International Limited（环球主义者国际有限公司）、GNews Media Group Inc.（G新闻传媒集团公司）、Golden Spring (New York) Ltd.（金泉〈纽约〉有限公司）、Guo Media（郭媒体）、GTV Media Group, Inc.（GTV传媒集团公司）、GWGOPNZ Limited（GWGOPNZ有限公司）、GWGNZ Limited（GWGNZ有限公司）、Gypsy Mei Food Services, LLC（吉普赛梅餐饮服务有限责任公司）、HCHK Property Management Inc.（HCHK物业管理公司）、HCHK Technologies Inc.（HCHK科技公司）、Hamilton Digital Assets FD SP（汉密尔顿数字资产FD SP）、Hamilton Capital Holdings Inc.（汉密尔顿资本控股公司）、Hamilton Opportunity Fund SPC（汉密尔顿机会基金SPC）、Head Win Group Limited（领赢集团有限公司）、Himalaya Embassy（喜马拉雅大使馆）、Himalaya Exchange（喜马拉雅交易所）、Himalaya Federal Reserve（喜马拉雅联邦储备）、Himalaya International Financial Group Ltd.（喜马拉雅国际金融集团有限公司）、Himalaya Investment LLC（喜马拉雅投资有限责任公司）、Himalaya (USA) Investment Management LLC（喜马拉雅〈美国〉投资管理有限责任公司）、Himalaya New World Inc.（喜马拉雅新世界公司）、Himalaya Supervisory Organization（喜马拉雅监督组织）、Himalaya Ventures（喜马拉雅风险投资）、Holy City Hong Kong Ventures, Ltd.（圣城香港风险投资有限公司）、Hudson Diamond Holding LLC（哈德逊钻石控股有限责任公司）、Hudson Diamond Holding Inc.（哈德逊钻石控股公司）、Hudson Diamond NY LLC（哈德逊钻石纽约有限责任公司）、HK International Funds Investments (USA) Limited LLC（香港国际基金投资〈美国〉有限责任公司）、Hong Kong International Funds Investments Limited（香港国际基金投资有限公司）、Huk Trading Inc（Huk贸易公司）、Infinite Increase Limited（无限增长有限公司）、Infinitum Developments Limited（无尽发展有限公司）、Japan Himalaya League, Inc.（日本喜马拉雅联盟公司）、Kalixun Trading Limited（卡利讯贸易有限公司）、Lamp Capital LLC（灯塔资本有限责任公司）、Leading Shine Limited（领耀有限公司）、Leading Shine NY Limited（领耀纽约有限公司）、Lexington Property and Staffing Inc.（列克星敦物业与人力配置公司）、Long Gate Limited（长龙有限公司）、MOS Himalaya Foundation Inc.（MOS喜马拉雅基金会公司）、Maywind Trading LLC（五月风贸易有限责任公司）、New Federal State of China (a/k/a NFSC)（中国新联邦国，亦称NFSC）、New York MOS Himalaya LLC（纽约MOS喜马拉雅有限责任公司）、New Mulberry PTE Ltd.（新桑葚私人有限公司）、Newpeople LLC（新人民有限责任公司）、Noble Fame Global Limited（全球高名有限公司）、Pixshow Film Inc.（Pixshow电影公司）、Roscalitar 2（Roscalitar 2）、Rosy Acme Ventures Limited（罗西顶峰风险投资有限公司）、Rule of Law Foundation III, Inc.（法治基金会III公司）、Rule of Law Society（法治协会）、Rule of Law Society IV, Inc.（法治协会IV公司）、Santel LLC（Santel有限责任公司）、Saraca Media Group, Inc.（Saraca传媒集团公司）、Shiny Ace Ltd.（闪耀王牌有限公司）、Shiny Times Holdings Ltd.（闪耀时代控股有限公司）、Stevenson, Wong & Co.（Stevenson, Wong & Co.）、Taurus Fund LLC（金牛基金有限责任公司）、Taurus Fund SP（金牛基金SP）、Taurus Management LLC（金牛管理有限责任公司）、The Lost Draft LLC（遗失草稿有限责任公司）、TM Primrose Limited（TM报春花有限公司）、UA Himalaya Inc.（UA喜马拉雅公司）、Voice of Guo Media, Inc.（郭媒体之声公司）、Well Origin Ltd.（良好起源有限公司）、Wise Creation（智慧创作）、Whitecroft Shore Limited（白克罗夫特海岸有限公司）、World Century Limited（世界世纪有限公司）、Worldwide Opportunity Holdings Limited（全球机会控股有限公司）及ZIBA Limited（ZIBA有限公司）。\n\n9. “包括”或其任何变体，均指“包括但不限于”。\n案号 22-50073 文件 3193 提交于 05/16/24 录入于 05/16/24 10:28:21 第 299 页，共 439 页\n\n10. “和”及“或”均指“和/或”，并应同时按连接词及选择词解释，以最大限度扩大其范围。\n\n11. “任何”及“全部”以及“每一”均指“每一及全部”。\n\n12. “每一”及“每个”均指“每一及全部”。\n\n13. “第三方”指除您本人以外的个人或实体。\n\n14. “转让”具有《破产法典》第101(54)条赋予该词的含义。\n\n15. “文件”指属于《联邦民事诉讼规则》第34条范围内的任何信息或物品，并包括但不限于您占有、保管或控制之中或曾经处于您占有、保管或控制之中的各种、各类、各性质或各描述的每一份书面、记录或图形材料，包括所有电子邮件、以电子形式保存的计算机文件、电子通信、短信、社交媒体帖文、推文、元数据、函件、备忘录、磁带、速记或手写笔记、任何种类的书面表格、图表、蓝图、绘图、草图、图形、计划、文章、规格说明、日记、信函、电报、照片、会议记录、合同、协议、调查、计算机打印件、任何种类的数据汇编、电传、传真、语音留言、发票、订购单、支票、汇票、对账单、贷项通知单、报告、头寸报告、摘要、索引、账簿、分类账、笔记本、明细表、透明胶片、录音、目录、广告、宣传材料、影片、录像带、录音带、CD、计算机磁盘、小册子、宣传册、穿孔卡、工时单、推文、社交媒体帖文或任何其他种类的书面或记录材料，以及其全部元数据，无论以何种方式存储（无论为有形或电子形式）、记录、制作或复制；还包括但不限于前述任何材料的草稿或副本，如其中含有原始文件中不存在的任何种类的笔记、评论或标记，或在其他方面与原始文件不完全相同。\n案号 22-50073 文件 3193 提交于 05/16/24 录入于 05/16/24 10:28:21 第 300 页，共 439 页\n\n16. “个人”指个人、公司、独资企业、合伙企业、协会或任何其他实体。“个人”还包括任何代理人、代表或专家，包括但不限于律师或财务顾问。\n\n17. “实体”指任何自然人、公司、合伙企业、子公司、独资企业、商号、董事会、合资企业、协会、机构、主管机关、委员会或其他商业实体或法人，以及任何关联方、代理人、母公司，包括但不限于法律顾问、财务顾问或任何其他代表。\n\n18. “关于”指涉及、描述、构成、提及、与之相关、支持、有利于、反对、加强、减损、位于、结合考虑、影响、证明、表明、报告、记录、暗指、答复、与之相连、评论、就其而言、有关、与之相关、讨论、显示、描述、反映、分析、构成及属于。\n\n19. 就任何特定主题而言，“与……有关”“涉及”或“相关”指包括但不限于构成、组成、涉及、包含、体现、反映、识别、陈述、直接或间接提及或以任何方式与所识别的特定主题有关的任何文件。\n\n20. “通信”以最广义且不受限制的含义，指任何信息或知识的传递（以事实、观点、询问或其他形式）。通信还指所有谈话、协议、询问或答复，无论是当面、通过电话、书面方式或借助电子传输设备进行，并包括但不限于所有函件、电子邮件、录音、传送\n案号 22-50073 文件 3193 提交于 05/16/24 录入于 05/16/24 10:28:21 第 301 页，共 439 页\n\n单、备忘录、电话通信、语音留言、电报、电传传真、传真副本、电传、即时消息、聊天、短信、电话笔记或在内部或与第三方传送的笔记。\n\n21. “资产”指可用于产生正经济价值的任何项目，包括但不限于由某一实体拥有、控制或为其利益而持有，且预期将提供未来利益的任何具有经济价值的资源，包括但不限于所有不动产和动产、无形财产、投资、投资权或未来收入权、现金、银行账户、商品、证券、债权、对某一实体的全部或部分控制权及预期经济机会。\n\n22. “转让”具有《破产法典》第101(54)条赋予该词的含义。\n\nIV. 应提交的文件\n\n1. 关于债务人、债务人家庭成员、债务人财产、关联个人或关联实体的任何收入或资产的全部文件。\n\n2. 与债务人的财务状况及其对债权人所负义务有关的全部文件，包括但不限于与任何规避支付该等义务的努力有关的全部文件，以及与本次或任何其他实际或潜在破产或类似无力偿债程序有关的全部文件。\n\n3. 关于与债务人、债务人财产、债务人家庭成员、关联实体或关联个人有关的任何资产负债表、银行对账单、账户对账单、财务报表、账户报表、电汇指示及/或确认、资金证明、存款证明、持有证明、投资组合摘要或类似文件的全部文件，包括但不限于足以显示向前述任何主体作出的全部转让的全部文件。\n案号 22-50073 文件 3193 提交于 05/16/24 录入于 05/16/24 10:28:21 第 302 页，共 439 页\n\n4. 关于由债务人、债务人家庭成员、关联个人或关联实体作出、与其进行或代表其作出的任何投资、商业往来或交易的全部文件。\n\n5. 与债务人、债务人家庭成员、关联个人或关联实体的全部通信，以及与该等通信有关的文件，包括与任何实体的运营、管理或决策有关的通信及文件，包括但不限于关联实体。\n\n6. 关于向债务人、债务人家庭成员、关联个人或关联实体作出、由其作出或与其进行的任何转让、投资或其他交易或商业往来的全部文件。\n\n7. 关于债务人曾占用或使用的任何财产的全部文件，包括但不限于位于康涅狄格州格林威治373 Taconic Rd.的住宅房产；位于康涅狄格州格林威治33 Ferncliff Rd.的住宅房产；位于康涅狄格州威尔顿354 Nod Hill Rd的住宅房产；位于英国伦敦SW7 1QJ，5 Princes Gate的公寓或共管公寓；以及位于新泽西州马瓦675 Ramapo Valley Road, Mahwah, New Jersey 07430的住宅房产。\n\n8. 与债务人拥有、控制或使用的任何航空器有关的全部文件，包括但不限于：(i) 尾号为T7-GQM的航空器及在San Marino（圣马力诺）注册的任何其他航空器，包括但不限于所有登记文件的副本，以及显示该等航空器所执行航班和该等航班乘机人员的飞行清单；及(ii) 任何Cirrus SF50航空器。\n案号 22-50073 文件 3193 提交于 05/16/24 录入于 05/16/24 10:28:21 第 303 页，共 439 页\n\n9. 关于向债务人、债务人财产、债务人家庭成员或关联实体提供、由其提供或代表其提供的任何赠与、利益或贷款的全部文件，包括但不限于足以显示该等赠与、利益或贷款的金额；该等赠与、利益或贷款所使用的目的；提供该等赠与、利益或贷款的时间；任何贷款的条款；就任何贷款作出的全部陈述与保证；任何贷款的利率；以及任何贷款付款的全部证据的文件。\n\n10. 关于由债务人、债务人财产、债务人家庭成员或关联实体设立、代表其设立、或为其利益设立的任何信托或类似文书的全部文件，包括但不限于足以显示该等信托的设立时间、设立人、为谁利益而设立及信托本金的文件。\n\n11. 与涉及债务人的任何法律争议有关的任何义务、债权、责任或债务有关的全部文件，包括但不限于与在任何地方、州、联邦或国际机构面前进行的任何诉讼有关的文件，无论该机构为行政机关、法院、合议庭或替代性争议解决实体。\n\n12. 与债务人、债务人家庭成员或关联个人之间的全部文件和通信。\n\n13. 您的任何律师或其他顾问与债务人、债务人家庭成员或关联个人之间的全部文件和通信。\n案号 22-50073 文件 3193 提交于 05/16/24 录入于 05/16/24 10:28:21 第 304 页，共 439 页\n\n14. 与您目前或曾经持有权益的任何关联实体有关的全部文件。\n\n附件C-16\n\nB2540（表格2540——依据规则2004进行审查的传票）（12/15）案号 22-50073 文件 3193 提交于 05/16/24 录入于 05/16/24 10:28:21 第 306 页，共\n\n美国破产法院\n\nDistrict of Connecticut（康涅狄格区）\n\n关于HO WAN KWOK（郭文贵）等人，\n\n1 案号 22-50073 (JAM) 债务人 第11章\n\n（合并管理）\n依据规则2004进行审查的传票\n\n致：Michael Baranowitz（迈克尔·巴拉诺维茨）\n\n（传票所指向人员的姓名）\n\n证言：兹命令您于下列载明的时间、日期和地点出席，并在依《联邦破产程序规则》第2004条进行的审查中作证。随附授权该审查的法院命令副本。\n\n地点　日期和时间\n\n不适用　不适用\n\n询问将以下列方式记录：不适用\n\n提交：您或您的代表还必须携带以下文件、电子存储信息或物品参加询问，并必须允许对该等材料进行查验、复制、测试或抽样：\n见随附的文件提交请求。\n\n下列 Fed. R. Civ. P. 45 条款，根据 Fed. R. Bankr. P. 9016 适用于破产案件，随附于此——有关履行地点的 Rule 45(c)；有关您作为受传票约束之人的保护的 Rule 45(d)；以及有关您对本传票作出回应的义务及未作出回应的潜在后果的 Rule 45(e) 和 45(g)。\n\n日期：May , 2024\n\n法院书记官\n\n或\n\n书记官或副书记官签名　律师签名\n\n签发或请求本传票的代表第11章受托人 Luc A. Despins（卢克·A·德斯平斯）的律师的姓名、地址、电子邮件地址和电话号码如下：\n\nPatrick R. Linsey, Esq.（帕特里克·R·林赛，律师）；Neubert, Pepe & Monteith, P.C.（纽伯特、佩佩与蒙蒂斯专业公司）；195 Church Street, 13th Floor, New Haven, Connecticut 06510；plinsey@npmlaw.com；(203) 781-2847\n向签发或请求本传票之人的通知\n\n如本传票命令在审判前提交文件、电子存储信息或有形物品，或查验不动产，则必须在向本传票所指向之人送达之前，向每一当事人送达通知及本传票副本。Fed. R. Civ. P. 45(a)(4)。\n\n软件版权 (c) 1996-2022 Best Case, LLC（百思凯斯有限责任公司）- www.bestcase.com Best Case Bankruptcy 1 本第11章案件中的债务人为 Ho Wan Kwok（郭文贵）（亦称 Guo Wengui（郭文贵）、Miles Guo（郭文贵）及 Miles Kwok（郭文贵），以及众多其他别名）（税务识别号码后四位：9595）、Genever Holdings LLC（Genever Holdings有限责任公司）（税务识别号码后四位：8202）及 Genever Holdings Corporation（Genever Holdings公司）。受托人、Genever Holdings LLC 和 Genever Holdings Corporation 的邮寄地址为 Paul Hastings LLP（保罗·黑斯廷斯律师事务所），200 Park Avenue, New York, NY 10166，转交 Luc A. Despins，作为 Ho Wan Kwok 遗产的受托人（仅为通知和通信之目的）。\n\n送达证明\n\n（除非 Fed. R. Civ. P. 45 要求，否则本节不应向法院提交。）\n\n本人于（日期）收到向（个人姓名及职务，如有）送达的本传票。\n\n本人以下列方式向被指名之人交付副本，以送达本传票：\n\n于（日期）送达；或\n\n本人未执行即退回本传票，原因如下：\n\n除非本传票系代表美国或其官员或代理人签发，本人亦已向证人支付一天出席费用及法律允许的里程费，金额为 \\$ 。\n\n本人的差旅费用为 \\$，服务费用为 \\$，合计为 \\$。\n\n本人在伪证处罚的约束下声明，该等信息真实、正确。\n\n日期：\n\n送达人员签名\n\n正楷姓名及职务\n\n送达人员地址\n\n关于尝试送达等事项的补充信息：\nFederal Rule of Civil Procedure 45(c)、(d)、(e) 和 (g)（Effective 12/1/13）（根据 Federal Rules of Bankruptcy Procedure Rule 9016 适用于破产案件）\n(c) 履行地点。\n\n(1) 审判、听证或证言录取。传票仅可按以下方式命令某人出席审判、听证或证言录取：\n\n(A) 在该人居住、受雇或经常亲自从事商业活动地点100英里以内；或\n\n(B) 在该人居住、受雇或经常亲自从事商业活动所在州内，若该人\n\n(i) 为当事人或当事人的高级职员；或\n\n(ii) 被命令出席审判且不会产生重大费用。\n\n(2) 其他证据开示。传票可命令：\n\n(A) 在该人居住、受雇或经常亲自从事商业活动地点100英里以内的地点提交文件、电子存储信息或物品；以及\n\n(B) 在拟查验的不动产处查验不动产。\n(d) 对受传票约束之人的保护；执行。\n\n(1) 避免不当负担或费用；制裁。负责签发及送达传票的当事人或律师必须采取合理措施，避免对受传票约束之人施加不当负担或费用。要求履行的地区法院必须执行该义务，并对未遵守者的当事人或律师施加适当制裁，其中可包括损失的收入和合理的律师费。\n(2) 提交材料或允许查验的命令。\n\n(A) 无须出席。被命令提交文件、电子存储信息或有形物品，或允许查验不动产之人，无须亲自到提交或查验地点出席，除非其亦被命令出席证言录取、听证或审判。\n\n(B) 异议。被命令提交文件或有形物品，或允许查验之人，可向传票指定的当事人或律师送达书面异议，反对查验、复制、测试或抽样任何或全部材料，或反对查验不动产——或反对按所要求的一种或多种形式提交电子存储信息。异议必须在指定履行时间之前或传票送达后14日内（以较早者为准）送达。如提出异议，适用以下规则：\n\n(i) 送达方可在任何时候，通知被命令之人后，向要求履行的地区法院提出动议，请求作出强制提交或查验的命令。\n\n(ii) 仅可按该命令所指示要求实施该等行为，且该命令必须保护既非当事人亦非当事人高级职员之人免受因履行而产生的重大费用。\n(3) 撤销或修改传票。\n\n(A) 必须撤销或修改的情形。经及时动议，要求履行的地区法院必须撤销或修改以下传票：\n\n(i) 未给予合理履行时间；\n\n(ii) 要求某人在 Rule 45(c) 规定的地理范围以外履行；\n\n(iii) 要求披露享有特权或受其他保护的事项，且不存在适用的例外或放弃；或\n\n(iv) 对某人施加不当负担。\n\n(B) 可以撤销或修改的情形。为保护受传票约束或受其影响之人，要求履行的地区法院可依动议撤销或修改要求以下事项的传票：\n\n(i) 披露商业秘密或其他保密的研究、开发或商业信息；或\n\n(ii) 披露未经聘用的专家的意见或信息，该等意见或信息并未描述争议中的具体事件，且系该专家未经当事人请求而进行研究所得。\n\n(C) 规定条件作为替代办法。在 Rule 45(d)(3)(B) 所述情形下，如送达方：\n\n(i) 证明其对证言或材料具有实质性需要，且若不遭受不当困难则无法以其他方式满足该需要；并且\n\n(ii) 确保被传唤之人将获得合理补偿，\n\n法院可不撤销或修改传票，而命令在规定条件下出席或提交。\n(e) 回应传票的义务。\n\n(1) 提交文件或电子存储信息。以下程序适用于提交文件或电子存储信息：\n\n(A) 文件。回应提交文件传票之人，必须按文件在日常业务过程中保存的方式提交，或者必须将文件整理并标注，以对应请求中的类别。\n\n(B) 未规定提交电子存储信息的形式。如传票未规定提交电子存储信息的形式，回应之人必须按其通常保存的一种或多种形式，或按合理可用的一种或多种形式提交。\n\n(C) 电子存储信息仅以一种形式提交。回应之人无须以多于一种形式提交相同的电子存储信息。\n\n(D) 无法合理获取的电子存储信息。回应之人无须提供其认定因不当负担或费用而无法合理获取的来源中的电子存储信息的证据开示。就强制证据开示的动议或保护令动议而言，回应之人必须证明该信息因不当负担或费用而无法合理获取。如作出该证明，法院在考虑 Rule 26(b)(2)(C) 的限制后，如请求方证明有正当理由，仍可命令从该等来源进行证据开示。法院可规定该证据开示的条件。\n(2) 主张特权或保护。\n\n(A) 被扣留的信息。以信息享有特权或作为审判准备材料受保护为由扣留被传唤信息之人，必须：(i) 明确提出该主张；并且\n\n(ii) 以一种方式描述被扣留文件、通信或有形物品的性质，使当事人能够评估该主张，同时不披露本身享有特权或受保护的信息。\n\n(B) 已提交的信息。如为回应传票而提交的信息受到特权主张或作为审判准备材料受保护的主张，提出该主张之人可将该主张及其依据通知任何收到该信息的当事人。收到通知后，当事人必须立即返还、隔离或销毁指定信息及其持有的任何副本；在该主张解决之前，不得使用或披露该信息；如该当事人在收到通知前已披露该信息，必须采取合理措施追回该信息；并可立即将该信息密封提交给要求履行的地区法院，以裁定该主张。提交该信息之人必须保存该信息，直至该主张得到解决。\n\n(g) 藐视法庭。要求履行的地区法院——以及动议移送后，签发法院——可对已被送达但无充分理由未遵从传票或与其相关命令之人，以藐视法庭论处。\n\n如需查阅传票材料，见 Fed.R.Civ.P.45(a) Committee Note (2013)\n\n……\n\n文件提交请求\nI. 指示\n\n1. 除非另有说明，下列文件请求（以下简称“请求”，每一项称“一项请求”）必须分别且具体地作出回应。每项请求均应得到完整答复，除非您基于善意提出异议；在此情形下，您必须按如下规定详细说明异议理由。如异议仅涉及一项请求的一部分，或其中所含的一个词语、短语或条款，您须仅对该部分提出异议，并对请求的其余部分作出回应。\n\n2. 电子存储信息必须依照以下指示提交：\n\n- a. 图像。黑白图像必须为 300 DPI Group IV 单页 TIFF 文件。彩色图像必须以 JPEG 格式制作。文件名不得包含嵌入空格或特殊字符（包括逗号）。文件夹名称不得包含嵌入空格或特殊字符（包括逗号）。所有 TIFF 图像文件必须具有唯一文件名，即 Bates 编号。每张图像的右下角必须加注连续的 Bates 编号。每个文件夹中的 TIFF 文件数量不得超过 1000 个文件。Excel 电子表格应具有一个以该文件的 Bates 编号命名的占位图像。\n\n- b. 图像加载文件\n\t- a. Concordance® 数据文件。数据文件（.DAT）包含将加载至 Concordance® 数据库的所有字段化信息。.DAT 文件的第一行必须为标识字段名称的标题行。.DAT 文件必须使用以下 Concordance® 默认分隔符：逗号 ASCII 字符（020）引号 þ ASCII 字符（254）。日期字段应采用以下格式提供：mm/dd/yyyy。日期字段和时间字段必须为两个单独字段。如文件包括已成像的电子邮件及附件，则必须包括附件字段，以保留电子邮件与其附件之间的父/子关系。必须包括 OCRPATH 字段，以提供所提取文本文件在已提供存储介质上的文件路径和名称。文本文件必须以 FIRSTBATES 命名。不得在 .DAT 文件中包含文本。对于包含原生文件的文件，必须包括 LINK 字段，以提供原生文件的文件路径和名称。原生文件必须以 FIRSTBATES 命名。\n\n- b. Concordance Image® 或 Opticon 交叉引用文件。图像交叉引用文件（.LOG 或 .OPT）将图像链接至数据库记录。该文件应为逗号分隔文件，每行由七个字段组成，并且数据库中每张图像均应在交叉引用文件中占一行，格式如下：ImageID,VolumeLabel,ImageFilePath,DocumentBreak,FolderBreak,Box Break,PageCoun。\n\n- c. 文件文本。文本必须作为单独的文本文件提供，而非作为 .DAT 文件内的字段。文本文件的完整路径（OCRPATH）应包含在 .DAT 文件中。建议使用文件级 ANSI 文本文件，并按 FIRSTBATES/Image Key 命名。提取的文本文件必须置于单独的文件夹中，每个文件夹中的文本文件数量不得超过 1,000 个文件。文件夹名称中不得含有特殊字符（包括逗号）。文本文件必须按文件级提供。\n\n- d. 特定文件类型的原生格式提供。为充分理解其内容及含义而合理需要以原生格式查看的文件类型，必须以原生格式提供。其中包括但不限于电子表格、类电子表格文件（Microsoft Excel、逗号分隔值、制表符分隔值等）、Microsoft PowerPoint 或其他特殊演示文件、数据库文件以及音频/视频文件。应提供一张带有 Bates 编号的分隔页图像，注明存在原生文件，并在 .dat 文件中将该原生文件的路径列为一个字段。所提供的原生文件应以与该文件分隔页相对应的 Bates 编号命名。原生文件应归入按递增方式命名的“NATIVE”目录中，与图像目录分开。\n\n- e. 去重。对于存在完全重复件的每一电子文件，仅提供一份。对于电子邮件，应根据由 BCC、Body、CC、From、IntMsgID、To 和 Attach 属性生成的 MD5 哈希值合并重复件。对于电子邮件附件和独立电子文件，应根据整个文件的 MD5 哈希值合并重复件。\n\n- f. 元数据。应以符合 Concordance 要求的加载文件（.dat）形式提供每份文件的提取元数据。.DAT 文件的第一行必须为标识字段名称的标题行。.DAT 文件必须使用以下 Concordance 默认分隔符：逗号 , ASCII 字符（020）引号 þ ASCII 字符（254）\n\n日期字段应采用以下格式提供：mm/dd/yyyy。日期字段和时间字段必须为两个单独字段。以下列为必需元数据：\nCase 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 311 of 439\n\n字段名称　示例数据　说明\n\nFIRSTBATES　EDC0000001　原生文件文件/电子邮件的第一个 Bates 编号\nLASTBATES　EDC0000001　原生文件文件/电子邮件的最后一个 Bates 编号\n**对于单页文件，应填写 LASTBATES 字段\nATTACHRANGE　EDC0000001\n-　父文件第一页的 Bates 编号至最后一个附件“子”文件最后一页的 Bates 编号\nEDC0000015\nBEGATTACH　EDC0000001　附件范围的第一个 Bates 编号\nENDATTACH　EDC0000015　附件范围的最后一个 Bates 编号\nCUSTODIAN　Smith, John　电子邮件：该电子邮件所在的邮箱\n原生文件：该文件来源的个人或部门名称\nFROM　John Smith　电子邮件：发件人\n原生文件：文件作者\n**多个条目应使用分号分隔\nTO　Coffman, Janice; LeeW　收件人\n[mailto:LeeW@MSN.com]　**多个条目应使用分号分隔\nCC　Frank Thompson [mailto:　抄送收件人\nfrank_Thompson@cdt.com]　**多个条目应使用分号分隔\nBCC　John Cain　密送收件人\n**多个条目应使用分号分隔\nSUBJECT　Board Meeting Minutes　电子邮件：电子邮件主题行 原生文件：文件标题（如有）\nFILE_NAME　BoardMeetingMinutes.docx　原生文件：原始原生文件名称，包括扩展名\nDATE_SENT　10/12/2010　电子邮件：电子邮件发送日期\n原生文件：（空）\nTIME_SENT/\nTIME_ZONE　07:05 PM GMT　电子邮件：电子邮件发送时间/电子邮件被标准化所采用的时区\nTIME_ZONE　GMT　在转换期间电子邮件被标准化所采用的时区。\nLINK　EDC0000001.msg　指向电子邮件或原生文件文件的超链接\n**被链接的文件必须按 FIRSTBATES 编号命名\nFILE_EXTEN　MSG　表示电子邮件或原生文件的文件类型扩展名\nAUTHOR　John Smith　电子邮件：（空）\n原生文件：文件作者\nDATE_CREATED　10/10/2010　电子邮件：（空）\n原生文件：文件创建日期\nCase 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 312 of 439\n\nTIME_CREATED　10:25 AM　电子邮件：（空）\n\n原生文件：文件创建时间\n**该数据必须为单独字段，不得与 DATE_CREATED 字段合并\nDATE_MOD　10/12/2010　电子邮件：（空）\n原生文件：文件最后修改日期\nTIME_MOD　07:00 PM　电子邮件：（空）\n原生文件：文件最后修改时间\n**该数据必须为单独字段，不得与 DATE_MOD 字段合并\nDATE_ACCESSD　10/12/2010　电子邮件：（空）\n原生文件：文件最后访问日期\nTIME_ACCESSD　07:00 PM　电子邮件：（空）\n原生文件：文件最后访问时间\n**该数据必须为单独字段，不得与 DATE_ACCESSD 字段合并\nFILE_SIZE　5,952　原生文件文件/电子邮件的大小，单位为 KB\nPGCOUNT　1　原生文件文件/电子邮件的页数\nPATH　电子邮件：（空）\nAgenda.doc　原生文件：原生文件文件的存储路径，包括原始文件名。\nINTFILEPATH　Personal Folders\\Deleted　电子邮件：电子邮件的原始位置，包括原始文件名。\nItems\\Board Meeting\nMinutes.msg　原生文件：（空）\nINTMSGID　<000805c2c71b\\$75977050\\$　电子邮件：唯一消息 ID 原生文件：（空）\ncb8306d1@MSN>\nMD5HASH　d131dd02c5e6eec4693d9a0　文件的 MD5 哈希值。\n698aff95c\n2fcab58712467eab4004583e\nb8fb7f89\nOCRPATH　TEXT/001/EDC0000001.txt　原生文件提取文本的路径\n\n3. 每项请求均独立适用并应被独立解释，除非另有说明，任何请求均不限制其他任何请求的范围。\n\n4. 所有文件均应按其在通常业务过程中保存的方式提供，或应予整理和标注，以与这些请求中的类别相对应。\n\n5. 本文所载每项请求均延及所有文件：(a) 由您占有、保管或控制的文件；或 (b) 由任何代表您行事之人占有、保管或控制的文件，\nCase 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 313 of 439\n\n包括您的律师或其他代表和顾问。每份文件均应完整提供。\n\n6. 如要求您提供已不再由您占有、保管或控制的文件，则您的答复必须：(a) 详细描述该文件的性质及其内容；(b) 确认编制或撰写该文件的人员（以及，如适用，该文件被发送给的人员）；(c) 确认该文件编制或创建的日期；(d) 说明该文件是否 (i) 遗失或丢失，(ii) 已被销毁，(iii) 已自愿或非自愿地转移给他人，或 (iv) 以其他方式被处置；(e) 说明该处置的原因以及围绕该处置的事实和情形；(f) 确认授权该处置的人员；(g) 确认该处置的日期或大致日期；(h) 说明该文件最近一次由您占有、保管或控制的时间；以及 (i) 确认目前占有、保管或控制该文件的人员（如有）。\n\n7. 如要求您提供已被销毁的文件，则除前述指示所要求的信息外，您的答复还必须说明：(a) 该文件被销毁的原因；(b) 销毁该文件的人员身份；以及 (c) 指示销毁该文件的人员身份。\n\n8. 如您主张所请求的文件享有特权或属于律师工作成果，则您的答复必须：(a) 说明 (i) 对该文件作出足以支持您关于该文件享有特权之主张的描述，(ii) 该文件的标题，(iii) 该文件的日期，(iv) 该文件的作者，(v) 该文件的收件人，(vi) 收到或见过该文件原件或任何草稿、副本或复制件的每一人员身份，(vii) 该文件本身或该文件所载或提及的任何信息是否由任何其他人员占有、保管或控制；如是，则确认该等人员身份，并说明该信息如何进入其占有范围，(viii) 据以扣留该文件的特权主张，以及 (ix) 您将据以支持该特权主张的全部情形；以及 (b) 根据 D. Conn. L. Civ. R. 26(e)，就每一份基于特权主张而被扣留的文件，制作一份特权日志，其中载明本指示第 (a) 部分要求的全部信息。\n\n9. 如一份本应提供的文件的一部分包含受特权主张约束的信息，则仅应依照上述指示从该文件中删除或涂黑受该特权主张约束的部分，其余部分应予提供。\n\n10. 这些请求具有持续性。特此指示您：(a) 一经知悉先前答复不完整或不正确，立即补充或更正其后得知不完整或不正确的任何答复；以及 (b) 提供根据以下内容所要求的任何额外文件\n\n11. 如文件为非英语语言，您应提供该文件。如文件为非英语语言且存在英文译文，您应同时提供两份文件。\n\n12. 对实体的一切提及均包括其所有关联方。\n\n13. 对个人姓名的一切提及均包括所有别名、化名或昵称。\n\n14. 除非另有明确说明，文件请求所涵盖的期间为自 February 5, 2012 起至应提交文件请求答复之日止。\n\n案件 22-50073 文件 3193 提交日期 05/16/24 登记日期 05/16/24 10:28:21 第 315 页，共 439 页\n\nII. 解释规则\n\n15. (a) 任何单数名词的使用应解释为包括复数，反之亦然；以及 (b) 任何时态动词的使用应解释为包括该动词所有其他时态的使用。\n\n16. (a) “和”及“或”应根据需要作连词性或选择性解释，以使本可能被解释为超出任何请求范围的所有答复均纳入该请求范围内；以及 (b) “每一”及“任何”应视为包括并涵盖“每个”及“全部”二词。\n\nIII. 定义\n\n根据 D. Conn. L. Civ. R. 26(c) 提供的定义以及根据 D. Conn. Bankr. L.R. 2004-1(a) 纳入的 D. Conn. L. Civ. R. 26(d) 提供的解释规则，应适用于文件请求。此外，本文件请求中使用的下列术语应具有以下含义：\n\n1. “你”或“你的”或“你本人”是指 Michael Baranowitz（迈克尔·巴拉诺维茨），连同其所有代理人、律师、代表、雇员和/或任何代表其行事的人。\n\n2. “债务人”是指 Ho Wan Kwok（郭文贵）（又名 Miles Kwok、Miles Guo、Guo Wengui、Guo Haoyun、郭文贵，或任何其他别名），连同其雇员、代理人、法律顾问、顾问或任何代表其行事的人。\n\n3. “债务人的儿子”是指 Qiang Guo（郭强）（又名 Mileson Kwok、郭强，或任何其他别名），连同其雇员、代理人、法律顾问、顾问或任何代表其行事的人。\n\n案件 22-50073 文件 3193 提交日期 05/16/24 登记日期 05/16/24 10:28:21 第 316 页，共 439 页\n\n4. “债务人的女儿”是指 Mei Guo（郭美）（又名 Mei Gui、郭美，或任何其他别名），连同其雇员、代理人、法律顾问、顾问或任何代表其行事的人。\n\n5. “债务人的所谓妻子”是指 Hing Chi Ngok（岳庆芝）（又名 Hing Chi Ng、Yue Qingzhi、岳庆芝，或任何其他别名），连同其雇员、代理人、法律顾问、顾问或任何代表其行事的人。\n\n6. “债务人家属”是指统称的债务人、债务人的儿子、债务人的女儿和债务人的所谓妻子，以及与债务人有任何其他亲属关系的人。\n\n7. “关联个人”是指单独及共同而言，所有以下个人：(1) 持有、控制、保管或对债务人或债务人家属拥有、控制或享有的资产具有处置权；或 (2) 曾为一个或多个关联实体的雇员、董事，或以其他方式与一个或多个关联实体有关联，连同前述各方各自的雇员、代理人、法律顾问、顾问或任何代表前述任何一方行事的人。该等关联个人包括但不限于：Anthony DiBattista（安东尼·迪巴蒂斯塔）、Alex Hadjicharalambous（亚历克斯·哈吉查拉兰布斯）、Bernardo Enriquez（贝尔纳多·恩里克斯）、Bingshang Jiao（焦冰上）、Beile Li（李贝乐）、Brian W. Hofmeister（布赖恩·W·霍夫迈斯特）、Charles Gruder（查尔斯·格鲁德）、Daniel Podhaskie（丹尼尔·波达斯基）、David Fallon（大卫·法伦）、Defeng Cao（曹德峰）（又名 Wayne Cao、Max Cao）、Ding Lin（丁林）、Dinggang Wang（王定刚）（又名 王定刚）、Eduardo Eurnekian（爱德华多·厄内基安）、Ehsan Masud（埃赫桑·马苏德）、Fiona Yu（余菲奥娜）、Gladys Chow（周格拉迪斯）、Hao (Gavin) Li（李浩）（又名 Huo Lai）、Hao Haidong（郝海东）（又名 郝海东）、Han Chunguang（韩春光）（又名 韩春光）、Haoran He（何浩然）、Ivan Lin（林艾文）、Haitham Khaled（海瑟姆·哈立德）、Jason Miller（杰森·米勒）、Jennifer Mercurio（詹妮弗·梅尔库里奥）、Jesse Brown（杰西·布朗）、Jessica Mastrogiovanni（杰西卡·马斯特罗焦瓦尼）、Jie Zhang（张杰）、Jintao Li（李金涛）、Karin Maistrello（卡琳·迈斯特雷洛）、Kyle Bass（凯尔·巴斯）、Lihong Wei Lafrenz（魏丽红）（又名 Sara Wei、魏丽红）、Linwan “Irene” Feng（冯林婉）、Max Krasner（马克斯·克拉斯纳）、Melissa Francis（梅丽莎·弗朗西斯）、Michael Baranowitz（迈克尔·巴拉诺维茨）、Min Yang（杨敏）、Melissa Mendez（梅丽莎·门德斯）、Nadeem Akbar（纳迪姆·阿克巴）、Nan Li（李楠）（又名 Chris Lee、Mei Guo Xiao Li）、Qidong Xia（夏启东）、Qu Guojiao（屈国姣）（又名 Qu Guo Jiao、屈国姣）、Ridwan Mamode Saib（里德万·马莫德·赛义卜）、Ross Heinemeyer（罗斯·海内迈耶）、Rui “Ray” Hao（郝睿）、Scott Barnett（斯科特·巴尼特）、Shih Hsin Yu（俞世新）、Shin Hee-Seup（申熙燮）（又名 Hee Seup Shin）、Steve Bannon（史蒂夫·班农）、Talha Zobair（塔尔哈·佐拜尔）、Victor Cerda（维克托·塞尔达）、Wen Xiao（肖文）、Wencong Wang（王文聪）、William Gertz（威廉·格茨）、William Je（余建明）（又名 Je Kin Ming、Yu Jianming、余建明）、Xuebing Wang（王学兵）、Ya Li（李娅）（又名 李娅）、Yinying (Aila) Wang（王音莹）（又名 Xiao Fei Xiang）、Yongping Yan（严永平）（Shan Mu）、Yong Yu（俞勇）、Yue Zhou（周玥）、Yumei Hao（郝玉梅）（又名 Ru Shui）、Yvette Wang（王雁平）（又名 Yanping Wang、Yan Ping Wang、王雁平）、Zhang Wei（张魏）（又名 张魏）、Zhouer Wang（王周儿）（又名 Joe Wang）、Zhixuan Li（李志轩）以及 Ziyang Liu（刘子阳）。\n\n案件 22-50073 文件 3193 提交日期 05/16/24 登记日期 05/16/24 10:28:21 第 317 页，共 439 页\n\n8. “关联实体”是指单独及共同而言，所有以下任何类型的组织或实体：(1) 曾由债务人或债务人家属拥有、控制或投资；或 (2) 对债务人或债务人家属拥有、控制或享有的任何资产直接或间接享有权益，连同前述各方各自的雇员、代理人、法律顾问、顾问或任何代表前述任何一方行事的人。该等关联实体包括但不限于：1332156 B.C. Ltd.、7 Nod Hill LLC、AAGV Limited、ACA Investment Management Limited、ACA Capital Group Limited、Ace Decade Holdings Limited、AI Group Holdings Inc.、Alfa Global Ventures Limited、Alfonso Global Limited、Allied Capital Global Limited、Alpine Fiduciaries SA、Beijing Pangu Investment Co.（北京盘古投资公司）、Beijing Pangu Investment Co. Ltd.（北京盘古投资有限公司）、Beijing Pangu Investment Inc.（北京盘古投资股份有限公司）、Beijing Zenith Holdings Company Limited、Blue Capital Limited、Booming Sail New York LLC、Bravo Luck Limited、Brent Petro、BSA Strategic Fund I、China Golden Spring (Hong Kong) Limited、Chuang Xin Limited、Crane Advisory Group LLC、Creative Apex Investments Limited、Crystal Breeze Investments Limited、Dawn State Limited、Eastern Profit Corporation Limited、Empire Growth Holdings、Elite Well Global Limited、Freedom Media Ventures Ltd.、Fung Wan Trading Inc.、G Club、G Club Operations LLC、G Club International Limited、G Club Investments Limited、G Fashion LLC、G-News Operations LLC、G News LLC、GMusic Inc.、G-Services LLC、G-Translators PTY LTD、GETTR USA, Inc.、Genever Holdings Corporation、Genever Holdings LLC、GFashion Media Group Inc.、GFNY, Inc.、Globalist International Limited、GNews Media Group Inc.、Golden Spring (New York) Ltd.、Guo Media、GTV Media Group, Inc.、GWGOPNZ Limited、GWGNZ Limited、Gypsy Mei Food Services, LLC、HCHK Property Management Inc.、HCHK Technologies Inc.、Hamilton Digital Assets FD SP、Hamilton Capital Holdings Inc.、Hamilton Opportunity Fund SPC、Head Win Group Limited、Himalaya Embassy、Himalaya Exchange、Himalaya Federal Reserve、Himalaya International Financial Group Ltd.、Himalaya Investment LLC、Himalaya (USA) Investment Management LLC、Himalaya New World Inc.、Himalaya Supervisory Organization、Himalaya Ventures、Holy City Hong Kong Ventures, Ltd.、Hudson Diamond Holding LLC、Hudson Diamond Holding Inc.、Hudson Diamond NY LLC、HK International Funds Investments (USA) Limited LLC、Hong Kong International Funds Investments Limited、Huk Trading Inc、Infinite Increase Limited、Infinitum Developments Limited、Japan Himalaya League, Inc.、Kalixun Trading Limited、Lamp Capital LLC、Leading Shine Limited、Leading Shine NY Limited、Lexington Property and Staffing Inc.、Long Gate Limited、MOS Himalaya Foundation Inc.、Maywind Trading LLC、New Federal State of China（中国新联邦国）（又名 NFSC）、New York MOS Himalaya LLC、New Mulberry PTE Ltd.、Newpeople LLC、Noble Fame Global Limited、Pixshow Film Inc.、Roscalitar 2、Rosy Acme Ventures Limited、Rule of Law Foundation III, Inc.、Rule of Law Society、Rule of Law Society IV, Inc.、Santel LLC、Saraca Media Group, Inc.、Shiny Ace Ltd.、Shiny Times Holdings Ltd.、Stevenson, Wong & Co.、Taurus Fund LLC、Taurus Fund SP、Taurus Management LLC、The Lost Draft LLC、TM Primrose Limited、UA Himalaya Inc.、Voice of Guo Media, Inc.、Well Origin Ltd.、Wise Creation、Whitecroft Shore Limited、World Century Limited、Worldwide Opportunity Holdings Limited 以及 ZIBA Limited。\n\n9. “包括”或其任何变体是指“包括但不限于”。\n\n案件 22-50073 文件 3193 提交日期 05/16/24 登记日期 05/16/24 10:28:21 第 319 页，共 439 页\n\n10. “和”及“或”是指“和/或”，并应同时作连词性及选择性解释，以最大限度扩大其范围。\n\n11. “任何”、“全部”及“每一”是指“每一个及每一”。\n\n12. “每一”及“每个”是指“每一个及每一”。\n\n13. “第三方”是指你本人以外的个人或实体。\n\n14. “转让”应具有《破产法》第 101(54) 条赋予其的含义。\n\n15. “文件”是指属于 Fed. R. Civ. P. 34 范围内的任何信息或物品，并包括但不限于任何种类、类型、性质或描述的每一项书面、记录或图形资料，只要该等资料现由或曾由你占有、保管或控制，包括电子邮件的所有纸质及电子副本、以电子形式保存的计算机文件、电子通信、短信、社交媒体帖子、推文、元数据、通信函件、备忘录、磁带、速记或手写笔记、任何种类的书面表格、图表、蓝图、绘图、草图、曲线图、计划、文章、规格、日记、信函、电报、照片、会议记录、合同、协议、调查、计算机打印件、任何种类的数据汇编、电传、传真、语音留言、发票、订购单、支票、汇票、账单、贷项通知单、报告、头寸报告、摘要、索引、书籍、分类账、笔记本、时间表、透明胶片、录音、目录、广告、宣传材料、电影、录像带、录音带、CD、计算机磁盘、宣传册、小册子、穿孔卡、工时单、推文、社交媒体帖子或任何其他种类的书面或记录材料，以及其全部元数据，不论其如何储存（无论以有形或电子形式）、记录、制作或复制；还包括但不限于前述任何材料的草稿或副本，其中载有原始文件中没有的任何种类的笔记、评论或标记，或在其他方面与原始文件不相同。\n\n案件 22-50073 文件 3193 提交日期 05/16/24 登记日期 05/16/24 10:28:21 第 320 页，共 439 页\n\n16. “个人”是指个人、公司、独资企业、合伙企业、协会或任何其他实体。“个人”还包括任何代理人、代表或专家，包括但不限于律师或财务顾问。\n\n17. “实体”是指任何自然人、公司、合伙企业、子公司、独资企业、商号、董事会、合资企业、协会、机构、主管机关、委员会或其他商业实体或法人，以及任何关联方、代理人、母公司，包括但不限于法律顾问、财务顾问或任何其他代表。\n\n18. “关于”是指涉及、描述、包含、提及、与之有关、支持、赞成、反对、强化、减损、位于其中、就其加以考虑、对其有影响、证明、表明、报告、记录、暗示、答复、与之相连、评论、就其而言、有关、与之相关、讨论、显示、描述、反映、分析、构成及属于。\n\n19. “与……有关”、“涉及”或“相关”，在提及任何特定事项时，是指但不限于构成、包含、涉及、含有、体现、反映、识别、陈述、直接或间接提及，或以任何方式与所识别的特定事项相关的任何文件。\n\n20. “通信”是指在最广泛可能意义上且不受限制的任何信息或知识传递（以事实、想法、询问或其他形式）。通信还指所有谈话、协议、询问或答复，无论是当面、电话、书面，还是通过电子传输设备进行，并包括但不限于所有通信函件、电子邮件、录音、传送。\n\n单据、备忘录、电话通讯、语音留言、电报、传真、电传副本、电传电报、即时消息、聊天记录、短信、电话记录，或在内部或与第三方之间传递的记录。\n\n21. “资产”是指任何可用于产生正向经济价值的项目，包括但不限于由某实体拥有、控制或为其利益而持有，并预期将提供未来利益的任何具有经济价值的资源，包括但不限于所有不动产和动产、无形财产、投资、投资权或取得未来收入的权利、现金、银行账户、商品、证券、债权、对某实体的全部或部分控制权，以及预期的经济机会。\n\n22. “转让”应具有《破产法典》第101(54)条赋予该术语的含义。\n\n四、应提供的文件\n\n1. 关于债务人、债务人家庭成员、债务人破产财产、关联个人或关联实体的任何收入或资产的所有文件。\n\n2. 与债务人的财务状况及其对债权人所负义务有关的所有文件，包括但不限于与任何规避支付该等义务的行为有关的所有文件，以及与本案或任何其他实际或潜在的破产或类似无力偿债程序有关的所有文件。\n\n3. 关于与债务人、债务人破产财产、债务人家庭成员、关联实体有关的任何资产负债表、银行对账单、账户对账单、财务报表、账户报表、电汇指示和/或确认、资金证明、存款证明、持仓证明、投资组合摘要或类似文件的所有文件，\n\n案号 22-50073，文书 3193，于 05/16/24 提交，于 05/16/24 10:28:21 录入，第 322 页，共 439 页\n\n或关联个人，包括但不限于足以显示向前述任何一方作出的所有转让的所有文件。\n\n4. 关于由债务人、债务人家庭成员、关联个人或关联实体作出、与其进行或代表其作出的任何投资、商业往来或交易的所有文件。\n\n5. 与债务人、债务人家庭成员、关联个人或关联实体之间的所有通讯，以及与同债务人、债务人家庭成员、关联个人或关联实体的通讯有关的文件，包括与任何实体（包括但不限于关联实体）的运营、管理或决策有关的通讯和文件。\n\n6. 关于向债务人、债务人家庭成员、关联个人或关联实体作出、由其作出或与其进行的任何转让、投资或其他交易或商业往来的所有文件。\n\n7. 关于债务人曾经占用或使用的任何财产的所有文件，包括但不限于位于 Connecticut（康涅狄格州） Greenwich（格林尼治）373 Taconic Rd. 的住宅房产；位于 Connecticut（康涅狄格州） Greenwich（格林尼治）33 Ferncliff Rd. 的住宅房产；位于 Connecticut（康涅狄格州） Wilton（威尔顿）354 Nod Hill Rd 的住宅房产；位于 United Kingdom（英国） London（伦敦）SW7 1QJ，5 Princes Gate 的公寓或共管公寓；以及位于 New Jersey（新泽西州） Mahwah（马瓦）675 Ramapo Valley Road, Mahwah, New Jersey 07430 的住宅房产。\n\n8. 与债务人拥有、控制或使用的任何航空器有关的所有文件，包括但不限于：(i) 尾号为 T7-GQM 的航空器，以及在 San Marino（圣马力诺）登记的任何其他航空器，包括但不限于所有登记文件副本，以及显示该等航空器所执行航班和该等航班机上人员的飞行舱单；及 (ii) 任何 Cirrus SF50 航空器。\n\n案号 22-50073，文书 3193，于 05/16/24 提交，于 05/16/24 10:28:21 录入，第 323 页，共 439 页\n\n9. 关于向债务人、债务人破产财产、债务人家庭成员或关联实体提供、由其提供或代表其提供的任何赠与、利益或贷款的所有文件，包括但不限于足以显示该等赠与、利益或贷款的金额；该等赠与、利益或贷款的使用目的；提供该等赠与、利益或贷款的时间；以及任何贷款的条款、就任何贷款作出的所有陈述和保证、任何贷款的利率，以及任何贷款付款的所有证据的文件。\n\n10. 关于由债务人、债务人破产财产、债务人家庭成员或关联实体设立、代表其设立或为其利益设立的任何信托或类似文书的所有文件，包括但不限于足以显示该等信托设立时间、设立人、为谁的利益设立以及信托财产的文件。\n\n11. 与涉及债务人的任何法律争议相关的任何义务、请求权、责任或债务有关的所有文件，包括但不限于与在任何地方、州、联邦或国际机构（无论是行政机构、法院、合议机构或替代性争议解决实体）前进行的任何诉讼有关的文件。\n\n12. 与债务人、债务人家庭成员或关联个人之间的所有文件和通讯。\n\n13. 你方任何律师或其他顾问与债务人、债务人家庭成员或关联个人之间的所有文件和通讯。\n\n案号 22-50073，文书 3193，于 05/16/24 提交，于 05/16/24 10:28:21 录入，第 324 页，共 439 页\n\n14. 与你方目前或曾经持有权益的任何关联实体有关的所有文件。\n\n案号 22-50073，文书 3193，于 05/16/24 提交，于 05/16/24 10:28:21 录入，第 325 页，共 439 页\n\n附件 C-17\n\nB2540（表格 2540——规则 2004 审查传票）（12/15）案号 22-50073，文书 3193，于 05/16/24 提交，于 05/16/24 10:28:21 录入，第 326 页，共\n\nUNITED STATES BANKRUPTCY COURT（美国破产法院）\n\nDistrict of Connecticut（康涅狄格区）\n\n关于 HO WAN KWOK（郭文贵）等人的事项，\n\n1 案号 22-50073 (JAM) 债务人 第 11 章\n\n（合并管理）\n\n规则 2004 审查传票\n\n致：Maya Fawaz（玛雅·法瓦兹）\n\n（传票所指向人员的姓名）\n\n作证：兹命令你于下列规定的时间、日期和地点出席，并根据《联邦破产程序规则》第2004条接受审查作证。随附准许该审查的法院命令副本。\n\n地点　日期和时间\n\nN/A　N/A\n\n审查将通过以下方式记录：N/A\n\n提交：你或你的代表还必须携带下列文件、电子存储信息或物品参加审查，并必须允许对该等材料进行查验、复制、测试或取样：\n\n见随附的文件提交请求。\n\n下列《联邦民事诉讼规则》第45条的规定，依《联邦破产程序规则》第9016条适用于破产案件，现随附于后——关于履行地点的第45(c)条；关于作为传票对象的人员之保护的第45(d)条；以及关于你对本传票的回应义务及未履行该义务可能后果的第45(e)条和第45(g)条。\n\n日期：May , 2024\n\n法院书记员\n\n或\n\n书记员或副书记员签名　律师签名\n\n签发或请求签发本传票并代表 Chapter 11 Trustee（第11章受托人）Luc A. Despins（卢克·A·德斯平斯）的律师姓名、地址、电子邮件地址和电话号码如下：\n\nPatrick R. Linsey, Esq.（帕特里克·R·林赛，律师）；Neubert, Pepe & Monteith, P.C.（纽伯特、佩佩及蒙蒂思律师事务所）；195 Church Street, 13th Floor, New Haven, Connecticut 06510；plinsey@npmlaw.com；(203) 781-2847\n\n向签发或请求签发本传票之人的通知\n\n如本传票命令在审判前提交文件、电子存储信息或有形物品，或检查场所，则必须在向传票所指向人员送达之前，向每一方送达通知及本传票副本。《联邦民事诉讼规则》第45(a)(4)条。\n\n软件版权 (c) 1996-2022 Best Case, LLC（贝斯特凯斯有限责任公司）- www.bestcase.com Best Case Bankruptcy（贝斯特凯斯破产软件）1 本第11章案件中的债务人为 Ho Wan Kwok（郭文贵）（亦称 Guo Wengui（郭文贵）、Miles Guo（郭文贵）和 Miles Kwok（郭文贵），以及众多其他别名）（税务识别号码后四位：9595）、Genever Holdings LLC（吉尼弗控股有限责任公司）（税务识别号码后四位：8202）及 Genever Holdings Corporation（吉尼弗控股公司）。受托人、Genever Holdings LLC 及 Genever Holdings Corporation 的邮寄地址为 Paul Hastings LLP（博衡律师事务所）, 200 Park Avenue, New York, NY 10166，转交 Luc A. Despins，作为 Ho Wan Kwok 破产财产的受托人（仅为通知和通讯之目的）。\n\n送达证明\n\n（除非《联邦民事诉讼规则》第45条要求，否则本节不应向法院提交。）\n\n我于（日期）收到向以下人士签发的本传票（个人姓名及职务，如有）： 。\n\n我以下列方式向被指定人员交付副本，从而送达本传票：\n\n于（日期） ；或\n\n我未执行本传票即予退回，原因如下：\n\n除非本传票是代表 United States（美国）或其官员或代理人签发，我还已向证人支付一天出席费用及法律允许的里程费，金额为 $ 。\n\n我的差旅费用为 $ ，服务费用为 $ ，合计为 $ 。\n\n我在伪证罪处罚下声明，该等信息真实且正确。\n\n日期：\n\n送达人员签名\n\n正楷姓名及职务\n\n送达人员地址\n\n关于尝试送达等的补充信息：\n\n《联邦民事诉讼规则》第45(c)、(d)、(e)及(g)条（Effective 12/1/13）（依《联邦破产程序规则》第9016条适用于破产案件）\n\n(c) 履行地点。\n\n(1) 审判、听证或证言录取。传票仅可按下列方式命令某人出席审判、听证或证言录取：\n\n(A) 在该人居住、受雇或定期亲自从事商业活动地点的 100 英里范围内；或\n\n(B) 在该人居住、受雇或定期亲自从事商业活动所在州内，如该人\n\n(i) 是当事人或当事人的高级职员；或\n\n(ii) 被命令出席审判且不会产生重大费用。\n\n(2) 其他证据开示。传票可以命令：\n\n(A) 在该人居住、受雇或定期亲自从事商业活动地点的 100 英里范围内，提交文件、电子存储信息或物品；以及\n\n(B) 在待检查场所进行场所检查。\n\n(d) 对作为传票对象的人员的保护；执行。\n\n(1) 避免不当负担或费用；制裁。负责签发和送达传票的当事人或律师必须采取合理步骤，避免对作为传票对象的人员施加不当负担或费用。要求履行的地区法院必须执行此项义务，并对未遵守者的当事人或律师施加适当制裁，其中可包括损失的收入和合理的律师费。\n\n(2) 提交材料或允许检查的命令。\n\n(A) 无须出席。被命令提交文件、电子存储信息或有形物品，或允许检查场所的人员，无须亲自到提交或检查地点出席，除非其同时被命令出席证言录取、听证或审判。\n\n(B) 异议。被命令提交文件或有形物品，或允许检查的人员，可以向传票中指定的当事人或律师送达书面异议，反对对任何或全部材料进行检查、复制、测试或取样，或反对检查场所——或者反对以所要求的一种或多种形式提交电子存储信息。异议必须在规定履行时间届满前或传票送达后 14 日内（以较早者为准）送达。如提出异议，适用下列规则：\n\n(i) 在任何时候，经通知被命令人员，送达方可以向要求履行的地区法院提出动议，请求作出强制提交或检查的命令。\n\n(ii) 仅可依照命令的指示要求实施该等行为，且该命令必须保护既非当事人亦非当事人高级职员的人员，使其免受因履行而产生的重大费用。\n\n(3) 撤销或修改传票。\n\n(A) 必须撤销或修改的情形。经及时提出动议，要求履行地所在地区的法院必须撤销或修改具有下列情形的传票：\n\n(i) 未给予合理的履行期限；\n\n(ii) 要求某人在 Rule 45(c) 规定的地域范围以外履行；\n\n(iii) 要求披露享有特权或受其他保护的事项，且不存在适用的例外或放弃；或\n\n(iv) 使某人承担不当负担。\n\n(B) 可以撤销或修改的情形。为保护受传票约束或受其影响的人，要求履行地所在地区的法院可依动议撤销或修改传票，如该传票要求：\n\n(i) 披露商业秘密或者其他保密的研究、开发或商业信息；或\n\n(ii) 披露未受聘专家的意见或信息，该等意见或信息并非描述争议中的特定事件，且系该专家未应任何一方当事人请求而进行研究所得。\n\n(C) 以规定条件作为替代方案。在 Rule 45(d)(3)(B) 所述情形下，如送达传票的一方：\n\n(i) 证明其对该证言或材料具有重大需要，且若不承受不当困难即无法以其他方式满足该需要；并且\n\n(ii) 确保被传唤人将获得合理补偿，\n\n法院可不撤销或修改传票，而是命令在规定条件下出庭或提交材料。\n\n(e) 对传票作出回应时的义务。\n\n(1) 提交文件或电子存储信息。下列程序适用于提交文件或电子存储信息：\n\n(A) 文件。对要求提交文件的传票作出回应的人，必须按照该等文件在通常业务过程中保存的方式提交，或者必须对其进行整理和标记，使之与请求中的类别相对应。\n\n(B) 未规定电子存储信息提交形式。如传票未规定电子存储信息的提交形式，作出回应的人必须以其通常保存的一种或多种形式，或以一种或多种合理可用的形式提交。\n\n(C) 电子存储信息仅以一种形式提交。作出回应的人无需以一种以上形式提交相同的电子存储信息。\n\n(D) 无法合理获取的电子存储信息。对于作出回应的人认定为因不当负担或费用而无法合理获取的来源中的电子存储信息，作出回应的人无需提供证据开示。对于强制证据开示动议或保护令动议，作出回应的人必须证明该信息因不当负担或费用而无法合理获取。如作出该等证明，法院在考虑 Rule 26(b)(2)(C) 的限制后，如请求方证明存在正当理由，仍可命令从该等来源进行证据开示。法院可规定证据开示的条件。\n\n(2) 主张特权或保护。\n\n(A) 未提交的信息。以该信息享有特权或作为审判准备材料受到保护为由而不提交被传唤信息的人，必须：(i) 明确提出该主张；并且\n\n(ii) 以一种方式描述被扣留文件、通信或有形物的性质，使当事人能够评估该主张，同时不披露本身享有特权或受保护的信息。\n\n(B) 已提交的信息。如为回应传票而提交的信息受到特权主张或作为审判准备材料受保护的主张约束，提出该主张的人可以将该主张及其依据通知收到该信息的任何当事人。收到通知后，当事人必须立即返还、隔离或销毁指定信息及其持有的任何副本；在该主张得到解决前不得使用或披露该信息；如该当事人在收到通知前已披露该信息，必须采取合理措施追回该信息；并且可以立即向要求履行地所在地区的法院密封提交该信息，以裁定该主张。提交该信息的人必须保存该信息，直至该主张得到解决。\n\n(g) 藐视法庭。要求履行地所在地区的法院——以及在动议被移送后，签发传票的法院——可以认定已被送达但无充分理由未遵从传票或与其相关命令的人构成藐视法庭。\n\n有关获取传票材料，请参见 Fed.R.Civ.P.45(a) Committee Note (2013)\n\n……\n\n文件提交请求\nI. 指示\n\n1. 除非另有说明，下列文件请求（以下简称“请求”，每一项单称“一项请求”）必须分别且具体地作出回应。除非基于诚信提出异议，否则每一项请求均应得到完整答复；如提出异议，则应按下文规定详细说明贵方异议的理由。如异议仅涉及某项请求的一部分，或其中包含的某个词语、短语或条款，贵方仅须说明对该部分的异议，并对其余请求作出回应。\n\n2. 电子存储信息必须依照下列指示提交：\n\na. 图像。黑白图像必须为 300 DPI Group IV 单页 TIFF 文件。彩色图像必须以 JPEG 格式提交。文件名不得含有嵌入空格或特殊字符（包括逗号）。文件夹名称不得含有嵌入空格或特殊字符（包括逗号）。所有 TIFF 图像文件必须具有唯一的文件名，即 Bates 编号。每幅图像右下角必须加注连续的 Bates 编号。每个文件夹中的 TIFF 文件数量不得超过 1000 个。Excel 电子表格应具有以该文件的 Bates 编号命名的占位图像。\n\nb. 图像加载文件\n\na. Concordance® 数据文件。数据文件（.DAT）包含将加载至 Concordance® 数据库的全部字段信息。.DAT 文件的第一行必须为标明字段名称的标题行。.DAT 文件必须使用以下 Concordance® 默认分隔符：逗号 ASCII 字符（020）；引号 þ ASCII 字符（254）。日期字段应采用以下格式：mm/dd/yyyy。日期和时间字段必须为两个单独字段。如文件包括已制作成图像的电子邮件及附件，则必须包含附件字段，以保留电子邮件及其附件之间的父/子关系。必须包含 OCRPATH 字段，以提供所提交存储介质上提取文本文件的文件路径和名称。文本文件必须以 FIRSTBATES 命名。不得在 .DAT 文件中包含文本。对于含有原生文件的文件，必须包含 LINK 字段，以提供原生文件的文件路径和名称。原生文件必须以 FIRSTBATES 命名。\n\nb. Concordance Image® 或 Opticon 交叉引用文件。图像交叉引用文件（.LOG 或 .OPT）将图像链接至数据库记录。该文件应为逗号分隔文件，每行由七个字段组成，数据库中的每幅图像均应在交叉引用文件中有一行，格式如下：ImageID,VolumeLabel,ImageFilePath,DocumentBreak,FolderBreak,Box Break,PageCoun。\n\nc. 文件文本。文本必须作为单独的文本文件提交，而非作为 .DAT 文件内的字段。文本文件的完整路径（OCRPATH）应包含在 .DAT 文件中。建议提供以 FIRSTBATES/Image Key 命名的文件级 ANSI 文本文件。提取的文本文件必须置于单独文件夹中，每个文件夹中的文本文件数量不得超过 1,000 个。文件夹名称中不得有特殊字符（包括逗号）。文本文件必须按文件级别提供。\n\nd. 特定文件类型的原生格式提交。为充分理解其内容和含义而合理需要以原生格式查看的文件类型，必须以原生格式提交。此类文件包括但不限于电子表格、类电子表格文件（Microsoft Excel、逗号分隔值、制表符分隔值等）、Microsoft PowerPoint 或其他特殊演示文件、数据库文件以及音频/视频文件。提供一张带有 Bates 编号的分隔页图像，注明存在原生文件，并在 .dat 文件中将原生文件路径作为一个字段列入。提交的原生文件应以与该文件分隔页相对应的 Bates 编号命名。将原生文件归入按递增方式命名的“NATIVE”目录中，并与图像目录分开。\n\ne. 去重。对于存在完全重复件的每份电子文件，仅提交一份副本。对于电子邮件，依据从 BCC、Body、CC、From、IntMsgID、To 和 Attach 属性生成的 MD5 哈希值合并重复件。对于电子邮件附件和独立电子文件，依据整个文件的 MD5 哈希值合并重复件。\n\nf. 元数据。以符合 Concordance 要求的加载文件（.dat）形式提交每份文件的提取元数据。.DAT 文件的第一行必须为标明字段名称的标题行。.DAT 文件必须使用以下 Concordance 默认分隔符：逗号 , ASCII 字符（020）；引号 þ ASCII 字符（254）\n\n日期字段应采用以下格式：mm/dd/yyyy。日期和时间字段必须为两个单独字段。下列为必需元数据：\n\n案件 22-50073 文件 3193 提交于 05/16/24 录入于 05/16/24 10:28:21 第 331 页，共 439 页\n\n字段名称　示例数据　说明\n\nFIRSTBATES　EDC0000001　原生文件文件/电子邮件的第一个 Bates 编号\n\nLASTBATES　EDC0000001　原生文件文件/电子邮件的最后一个 Bates 编号\n\nLASTBATES 字段应针对单页文件填写\n\nATTACHRANGE　EDC0000001\n-　父文件第一页的 Bates 编号至最后一个附件“子”文件最后一页的 Bates 编号\nEDC0000015\n\nBEGATTACH　EDC0000001　附件范围的第一个 Bates 编号\n\nENDATTACH　EDC0000015　附件范围的最后一个 Bates 编号\n\nCUSTODIAN　Smith, John（约翰·史密斯）　电子邮件：电子邮件所在的邮箱\n原生文件：文件来源的个人或部门名称\n\nFROM　John Smith（约翰·史密斯）　电子邮件：发件人\n原生文件：文件作者\n多项条目之间应使用分号分隔\n\nTO　Coffman, Janice（贾妮斯·科夫曼）; LeeW\n[mailto:LeeW@MSN.com]　收件人\n多项条目之间应使用分号分隔\n\nCC　Frank Thompson（弗兰克·汤普森） [mailto:\nfrank_Thompson@cdt.com]　抄送收件人\n多项条目之间应使用分号分隔\n\nBCC　John Cain（约翰·凯恩）　密送收件人\n多项条目之间应使用分号分隔\n\nSUBJECT　Board Meeting Minutes　电子邮件：电子邮件主题行；原生文件：文件标题（如有）\n\nFILE_NAME　BoardMeetingMinutes.docx　原生文件：原始原生文件名称，包括扩展名\n\nDATE_SENT　10/12/2010　电子邮件：电子邮件发送日期\n原生文件：（空）\n\nTIME_SENT/\nTIME_ZONE　07:05 PM GMT　电子邮件：电子邮件发送时间/电子邮件标准化所采用的时区\n\nTIME_ZONE　GMT　在转换过程中电子邮件被标准化所采用的时区。\n\nLINK　EDC0000001.msg　电子邮件或原生文件文件的超链接\n链接文件必须以 FIRSTBATES 编号命名\n\nFILE_EXTEN　MSG　代表电子邮件或原生文件的文件类型扩展名\n\nAUTHOR　John Smith（约翰·史密斯）　电子邮件：（空）\n原生文件：文件作者\n\nDATE_CREATED　10/10/2010　电子邮件：（空）\n原生文件：文件创建日期\n\n案件 22-50073 文件 3193 提交于 05/16/24 录入于 05/16/24 10:28:21 第 332 页，共 439 页\n\nTIME_CREATED　10:25 AM　电子邮件：（空）\n\n原生：文档创建日期\n＊＊该数据必须作为单独字段，不得\n与 DATE_CREATED 字段合并\nDATE_MOD　10/12/2010　电子邮件：（空）\n原生：文档最后修改日期\nTIME_MOD　07:00 PM　电子邮件：（空）\n原生：文档最后修改时间\n＊＊该数据必须作为单独字段，不得\n与 DATE_MOD 字段合并\nDATE_ACCESSD　10/12/2010　电子邮件：（空）\n原生：文档最后访问日期\nTIME_ACCESSD　07:00 PM　电子邮件：（空）\n原生：文档最后访问时间\n＊＊该数据必须作为单独字段，不得\n与 DATE_ACCESSD 字段合并\nFILE_SIZE　5,952　原生文件文档/电子邮件的大小（以 KB 计）\nPGCOUNT　1　原生文件文档/电子邮件的页数\nPATH　电子邮件：（空）\nAgenda.doc　原生：存储原生文件文档的路径，\n包括原始文件名。\nINTFILEPATH　Personal Folders\\Deleted　电子邮件：电子邮件的原始位置，包括\nItems\\Board Meeting　原始文件名。\nMinutes.msg　原生：（空）\nINTMSGID　<000805c2c71b\\$75977050\\$　电子邮件：唯一消息 ID 原生：（空）\ncb8306d1@MSN>\nMD5HASH　d131dd02c5e6eec4693d9a0　文档的 MD5 哈希值。\n698aff95c\n2fcab58712467eab4004583e\nb8fb7f89\nOCRPATH　TEXT/001/EDC0000001.txt　原生文件提取文本的路径\n\n3. 每项请求均独立运作并应独立解释，除非另有说明，任何一项请求均不限制任何其他请求的范围。\n\n4. 所有文件均应按照正常业务过程中保存的方式提供，或应整理并标注以对应本请求中的类别。\n\n5. 本文件所载每项请求均延及所有文件：（a）由您占有、保管或控制的文件；或（b）由代表您行事的任何人占有、保管或控制的文件，\nCase 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 333 of 439\n包括您的律师或其他代表及顾问。每份文件均应完整提供。\n\n6. 如要求您提供一份已不再由您占有、保管或控制的文件，则您的答复必须：（a）详细说明该文件的性质及其内容；（b）确认编制或撰写该文件的人员（以及，如适用，该文件被发送至的人员）；（c）确认该文件编制或创建的日期；（d）说明该文件是否（i）遗失或丢失，（ii）已被销毁，（iii）已自愿或非自愿地转移给他人，或（iv）以其他方式被处置；（e）说明该处置的理由以及围绕该处置的事实和情形；（f）确认授权该处置的人员；（g）确认该处置的日期或大致日期；（h）说明该文件最近一次由您占有、保管或控制的时间；以及（i）确认目前占有、保管或控制该文件的人员（如有）。\n\n7. 如要求您提供一份已被销毁的文件，则除前述指示所要求的信息外，您的答复还必须说明：（a）销毁该文件的理由；（b）销毁该文件的人员身份；以及（c）指示销毁该文件的人员身份。\n\n8. 如您主张所请求的文件受特权或律师工作成果保护，则您的答复必须：（a）说明：（i）足以支持您关于该文件受特权保护之主张的文件描述；（ii）文件标题；（iii）文件日期；（iv）文件作者；（v）文件收件人；（vi）收到或阅览过该文件原件或任何草稿、副本或复制件的每一人员身份；（vii）该文件本身或文件中载有或提及的任何信息，是否由任何其他人员占有、保管或控制，如是，确认该等人员的身份，以及说明该等信息如何进入其占有范围；（viii）据以扣留该文件的特权主张；以及（ix）您将据以支持该特权主张的所有情形；以及（b）依照 D. Conn. L. Civ. R. 26(e)，就基于特权主张而扣留的每份文件，提供一份载有本指示第（a）部分所要求全部信息的特权日志。\nCase 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 334 of 439\n\n9. 如一份本应回应请求的文件的一部分含有受特权主张保护的信息，则仅应按照上述指示自该文件删除或遮盖受特权主张保护的该部分，其余部分应予提供。\n\n10. 本请求具有持续性质。现指示您：（a）一旦得知先前答复不完整或不正确，应立即补充或更正任何后来得知不完整或不正确的答复；以及（b）提供根据下述内容所要求的任何额外文件。\n\n11. 如文件使用英语以外的语言，您应提供该文件。如文件使用英语以外的语言，且存在英文译本，您应同时提供两份文件。\n\n12. 对实体的所有提述均包括其所有关联方。\n\n13. 对个人姓名的所有提述均包括所有替代姓名、别名或昵称。\n\n14. 除非另有明确说明，文件请求所涵盖的期间为自 February 5, 2012 起至文件请求答复到期之日止。\nII. 解释规则\n\n15. （a）任何单数名词的使用均应解释为包括复数，反之亦然；以及（b）任何时态动词的使用均应解释为在所有其他时态中使用该动词。\n\n16. （a）“and”和“or”应根据需要解释为连词性或选择性用法，以将原本可能被解释为超出任何请求范围的所有答复纳入该请求范围；以及（b）“each”和“any”应视为包括并涵盖“every”和“all”两词。\nIII. 定义\n\n经 D. Conn. Bankr. L.R. 2004-1(a) 纳入的 D. Conn. L. Civ. R. 26(c) 所规定的定义及 D. Conn. L. Civ. R. 26(d) 所规定的解释规则，应适用于文件请求。此外，本文件请求中使用的下列术语具有下列含义：\n\n1. “您”或“您的”或“您本人”是指 Maya Fawaz（玛雅·法瓦兹），以及其所有代理人、律师、代表、雇员和/或代表其行事的任何人。\n\n2. “债务人”是指 Ho Wan Kwok（郭文贵，亦称 Miles Kwok、Miles Guo、Guo Wengui、Guo Haoyun、郭文贵或任何其他别名），以及其雇员、代理人、律师、顾问或代表其行事的任何人。\n\n3. “债务人之子”是指 Qiang Guo（郭强，亦称 Mileson Kwok、郭强或任何其他别名），以及其雇员、代理人、律师、顾问或代表其行事的任何人。\n\n4. “债务人之女”是指 Mei Guo（郭美，亦称 Mei Gui、郭美或任何其他别名），以及其雇员、代理人、律师、顾问或代表其行事的任何人。\nCase 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 336 of 439\n\n5. “债务人声称的妻子”是指 Hing Chi Ngok（岳庆芝，亦称 Hing Chi Ng、Yue Qingzhi、岳庆芝或任何其他别名），以及其雇员、代理人、律师、顾问或代表其行事的任何人。\n\n6. “债务人家属”统称债务人、债务人之子、债务人之女及债务人声称的妻子，以及与债务人具有任何其他亲属关系者。\n\n7. “关联个人”单独及统称所有下列个人：（1）持有、控制、保管或对债务人或债务人家属所有、控制或享有的资产具有酌处权者；或（2）曾为一家或多家关联实体的雇员、董事或以其他方式与其有关联者，以及前述任何一方各自的雇员、代理人、律师、顾问或代表前述任何一方行事的任何人。该等关联个人包括但不限于：Anthony DiBattista（安东尼·迪巴蒂斯塔）、Alex Hadjicharalambous（亚历克斯·哈吉查拉兰布斯）、Bernardo Enriquez（贝尔纳多·恩里克斯）、Bingshang Jiao（焦炳尚）、Beile Li（李贝乐）、Brian W. Hofmeister（布赖恩·W·霍夫迈斯特）、Charles Gruder（查尔斯·格鲁德）、Daniel Podhaskie（丹尼尔·波达斯基）、David Fallon（大卫·法伦）、Defeng Cao（曹德峰，亦称 Wayne Cao、Max Cao）、Ding Lin（丁林）、Dinggang Wang（王定刚，亦称 王定刚）、Eduardo Eurnekian（爱德华多·尤尔内基安）、Ehsan Masud（埃桑·马苏德）、Fiona Yu（于菲奥娜）、Gladys Chow（周格拉迪斯）、Hao (Gavin) Li（李浩〔加文〕，亦称 Huo Lai）、Hao Haidong（郝海东，亦称 郝海东）、Han Chunguang（韩春光，亦称 韩春光）、Haoran He（何浩然）、Ivan Lin（林艾文）、Haitham Khaled（海瑟姆·哈立德）、Jason Miller（杰森·米勒）、Jennifer Mercurio（詹妮弗·默丘里奥）、Jesse Brown（杰西·布朗）、Jessica Mastrogiovanni（杰西卡·马斯特罗焦万尼）、Jie Zhang（张杰）、Jintao Li（李金涛）、Karin Maistrello（卡琳·迈斯特雷洛）、Kyle Bass（凯尔·巴斯）、Lihong Wei Lafrenz（魏丽红·拉弗伦茨，亦称 Sara Wei、魏丽红）、Linwan “Irene” Feng（冯琳婉“艾琳”）、Max Krasner（马克斯·克拉斯纳）、Melissa Francis（梅利莎·弗朗西斯）、Michael Baranowitz（迈克尔·巴拉诺维茨）、Min Yang（杨敏）、Melissa Mendez（梅利莎·门德斯）、Nadeem Akbar（纳迪姆·阿克巴尔）、Nan Li（李楠，亦称 Chris Lee、Mei Guo Xiao Li）、Qidong Xia（夏启东）、Qu Guojiao（屈国姣，亦称 Qu Guo Jiao、屈国姣）、Ridwan Mamode Saib（里德万·马莫德·赛义卜）、Ross Heinemeyer（罗斯·海内迈耶）、Rui “Ray” Hao（郝睿“雷”）、Scott Barnett（斯科特·巴尼特）、Shih Hsin Yu（余世新）、Shin Hee-Seup（申熙燮，亦称 Hee Seup Shin）、Steve Bannon（史蒂夫·班农）、Talha Zobair（塔尔哈·佐拜尔）、Victor Cerda（维克托·塞尔达）、Wen Xiao（肖文）、Wencong Wang（王文聪）、William Gertz（威廉·格茨）、William Je（余建明，亦称 Je Kin Ming、Yu Jianming、余建明）以及 Xuebing Wang（王学兵）、\nCase 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 337 of 439\nYa Li（李娅，亦称 李娅）、Yinying (Aila) Wang（王茵颖〔艾拉〕，亦称 Xiao Fei Xiang）、Yongping Yan（严永平，Shan Mu）、Yong Yu（俞勇）、Yue Zhou（周月）、Yumei Hao（郝玉梅，亦称 Ru Shui）、Yvette Wang（王雁平，亦称 Yanping Wang、Yan Ping Wang、王雁平）、Zhang Wei（张魏，亦称 张魏）、Zhouer Wang（王周二，亦称 Joe Wang）、Zhixuan Li（李志轩）及 Ziyang Liu（刘子阳）。\n\n8. “关联实体”单独及统称所有下列任何类型的组织或实体：（1）曾由债务人或债务人家属拥有、控制或投资的组织或实体；或（2）对债务人或债务人家属所有、控制或享有的任何资产直接或间接拥有权益的组织或实体，以及前述任何一方各自的雇员、代理人、律师、顾问或代表前述任何一方行事的任何人。该等关联实体包括但不限于：1332156 B.C. Ltd.（1332156 B.C. 有限公司）、7 Nod Hill LLC（7 Nod Hill 有限责任公司）、AAGV Limited（AAGV 有限公司）、ACA Investment Management Limited（ACA 投资管理有限公司）、ACA Capital Group Limited（ACA 资本集团有限公司）、Ace Decade Holdings Limited（Ace Decade 控股有限公司）、AI Group Holdings Inc.（AI Group Holdings 股份有限公司）、Alfa Global Ventures Limited（Alfa Global Ventures 有限公司）、Alfonso Global Limited（Alfonso Global 有限公司）、Allied Capital Global Limited（Allied Capital Global 有限公司）、Alpine Fiduciaries SA（Alpine Fiduciaries SA）、Beijing Pangu Investment Co.（北京盘古投资公司）、Beijing Pangu Investment Co. Ltd.（北京盘古投资有限公司）、Beijing Pangu Investment Inc.（北京盘古投资股份有限公司）、Beijing Zenith Holdings Company Limited（北京Zenith控股有限公司）、Blue Capital Limited（Blue Capital 有限公司）、Booming Sail New York LLC（Booming Sail New York 有限责任公司）、Bravo Luck Limited（Bravo Luck 有限公司）、Brent Petro（Brent Petro）、BSA Strategic Fund I（BSA 战略基金 I）、China Golden Spring (Hong Kong) Limited（中国金泉〔香港〕有限公司）、Chuang Xin Limited（创新有限公司）、Crane Advisory Group LLC（Crane Advisory Group 有限责任公司）、Creative Apex Investments Limited（Creative Apex Investments 有限公司）、Crystal Breeze Investments Limited（Crystal Breeze Investments 有限公司）、Dawn State Limited（Dawn State 有限公司）、Eastern Profit Corporation Limited（Eastern Profit Corporation 有限公司）、Empire Growth Holdings（Empire Growth Holdings）、Elite Well Global Limited（Elite Well Global 有限公司）、Freedom Media Ventures Ltd.（Freedom Media Ventures 有限公司）、Fung Wan Trading Inc.（Fung Wan Trading 股份有限公司）、G Club（G Club）、G Club Operations LLC（G Club Operations 有限责任公司）、G Club International Limited（G Club International 有限公司）、G Club Investments Limited（G Club Investments 有限公司）、G Fashion LLC（G Fashion 有限责任公司）、G-News Operations LLC（G-News Operations 有限责任公司）、G News LLC（G News 有限责任公司）、GMusic Inc.（GMusic 股份有限公司）、G-Services LLC（G-Services 有限责任公司）、G-Translators PTY LTD（G-Translators PTY LTD）、GETTR USA, Inc.（GETTR USA 股份有限公司）、Genever Holdings Corporation（Genever Holdings 公司）、Genever Holdings LLC（Genever Holdings 有限责任公司）、GFashion Media Group Inc.（GFashion Media Group 股份有限公司）、GFNY, Inc.（GFNY 股份有限公司）、Globalist International Limited（Globalist International 有限公司）、GNews Media Group Inc.（GNews Media Group 股份有限公司）、Golden Spring (New York) Ltd.（Golden Spring〔纽约〕有限公司）、Guo Media（Guo Media）、GTV Media Group, Inc.（GTV Media Group 股份有限公司）、GWGOPNZ\nCase 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 338 of 439\n\nLimited, GWGNZ Limited, Gypsy Mei Food Services, LLC, HCHK Property Management Inc., HCHK Technologies Inc., Hamilton Digital Assets FD SP, Hamilton Capital Holdings Inc., Hamilton Opportunity Fund SPC, Head Win Group Limited, Himalaya Embassy, Himalaya Exchange, Himalaya Federal Reserve, Himalaya International Financial Group Ltd., Himalaya Investment LLC, Himalaya (USA) Investment Management LLC, Himalaya New World Inc., Himalaya Supervisory Organization, Himalaya Ventures, Holy City Hong Kong Ventures, Ltd., Hudson Diamond Holding LLC, Hudson Diamond Holding Inc., Hudson Diamond NY LLC, HK International Funds Investments (USA) Limited LLC, Hong Kong International Funds Investments Limited, Huk Trading Inc, Infinite Increase Limited, Infinitum Developments Limited, Japan Himalaya League, Inc., Kalixun Trading Limited, Lamp Capital LLC, Leading Shine Limited, Leading Shine NY Limited, Lexington Property and Staffing Inc., Long Gate Limited, MOS Himalaya Foundation Inc., Maywind Trading LLC, New Federal State of China（又称 NFSC）, New York MOS Himalaya LLC, New Mulberry PTE Ltd., Newpeople LLC, Noble Fame Global Limited, Pixshow Film Inc., Roscalitar 2, Rosy Acme Ventures Limited, Rule of Law Foundation III, Inc., Rule of Law Society, Rule of Law Society IV, Inc., Santel LLC, Saraca Media Group, Inc., Shiny Ace Ltd., Shiny Times Holdings Ltd., Stevenson, Wong & Co., Taurus Fund LLC, Taurus Fund SP, Taurus Management LLC, The Lost Draft LLC, TM Primrose Limited, UA Himalaya Inc., Voice of Guo Media, Inc., Well Origin Ltd., Wise Creation, Whitecroft Shore Limited, World Century Limited, Worldwide Opportunity Holdings Limited, 以及 ZIBA Limited。\n\n9. “包括”或其任何变体，均意为“包括但不限于”。\n\n10. “和”及“或”均意为“和/或”，并应同时按合取及析取方式解释，以最大化其适用范围。\n\n案号 22-50073 文件 3193 提交日期 05/16/24 录入日期 05/16/24 10:28:21 第 339 页，共 439 页\n\n11. “任何”及“全部”以及“每一”均意为“每一及全部”。\n\n12. “每一”及“每个”均意为“每一及全部”。\n\n13. “第三方”系指除您本人以外的个人或实体。\n\n14. “转让”具有《破产法典》第 101(54) 条赋予该术语的含义。\n\n15. “文件”系指属于 Fed. R. Civ. P. 34 范围内的任何信息或物品，并包括但不限于处于或曾处于您占有、保管或控制之下的各种、各类、各种性质或描述的每一及全部书面、记录或图形资料，包括电子邮件的所有印刷及电子副本、以电子形式保存的计算机文件、电子通信、短信、社交媒体帖子、推文、元数据、函件、备忘录、磁带、速记或手写笔记、任何种类的书面表格、图表、蓝图、图纸、草图、曲线图、计划、文章、规格说明、日记、信函、电报、照片、会议记录、合同、协议、调查、计算机打印件、任何种类的数据汇编、电传、传真、语音留言、发票、订购单、支票、汇票、对账单、贷项通知单、报告、头寸报告、摘要、索引、书籍、分类账、笔记本、明细表、透明胶片、录音、目录、广告、宣传材料、影片、录像带、录音带、CD、计算机磁盘、宣传册、小册子、穿孔卡、工时单、推文、社交媒体帖子或任何其他种类的书面或记录材料，以及其全部元数据，无论以何种方式存储（无论为有形或电子形式）、记录、制作或复制；还包括但不限于前述任何资料的草稿或副本，如其中载有原始文件中未见的任何种类的笔记、评论或标记，或在其他方面与原始文件不完全相同。\n\n案号 22-50073 文件 3193 提交日期 05/16/24 录入日期 05/16/24 10:28:21 第 340 页，共 439 页\n\n16. “个人”系指个人、公司、独资企业、合伙企业、协会或任何其他实体。“个人”还包括任何代理人、代表或专家，包括但不限于律师或财务顾问。\n\n17. “实体”系指任何自然人、公司、合伙企业、子公司、独资企业、商号、董事会、合资企业、协会、机构、主管机关、委员会或其他商业实体或法人，以及任何关联方、代理人、母公司，包括但不限于法律顾问、财务顾问或任何其他代表。\n\n18. “关于”系指涉及、描述、构成、提及、与之相关、支持、有利于、反对、加强、削弱、位于其中、结合考虑、对其有影响、证明、表明、报告、记录、暗示、回应、与之连接、评论、就其而言、有关、与之相关、讨论、显示、描述、反映、分析、构成及属于。\n\n19. 在提及任何特定事项时，“与……有关”、“涉及”或“相关”系指但不限于构成、包括、涉及、包含、体现、反映、识别、陈述、直接或间接提及该特定事项，或以任何方式与所识别的特定事项相关的任何文件。\n\n20. “通信”系指在最广泛可能意义上且不限于此的任何信息或知识传递（以事实、观点、询问或其他形式）。通信还指所有谈话、协议、询问或答复，无论是当面、通过电话、以书面形式，或通过电子传输设备进行，并包括但不限于所有函件、电子邮件、录音、传送单、备忘录、电话通信、语音留言、电报、传真、电传副本、\n\n案号 22-50073 文件 3193 提交日期 05/16/24 录入日期 05/16/24 10:28:21 第 341 页，共 439 页\n\n电传、即时消息、聊天记录、短信、电话笔记，或在内部或与第三方之间传送的笔记。\n\n21. “资产”系指可用于产生正经济价值的任何项目，包括但不限于由某实体拥有、控制或为该实体利益而持有，并预期提供未来利益的任何具有经济价值的资源，包括但不限于所有不动产和动产、无形财产、投资、投资权或未来收入权、现金、银行账户、商品、证券、债权、对实体的全部或部分控制权及潜在经济机会。\n\n22. “转让”具有《破产法典》第 101(54) 条赋予该术语的含义。\n\nIV. 应提交的文件\n\n1. 关于债务人、债务人的家庭成员、债务人的破产财产、关联个人或关联实体的任何收入或资产的所有文件。\n\n2. 与债务人的财务状况及其对债权人的义务有关的所有文件，包括但不限于与任何规避支付该等义务的努力有关的所有文件，以及与本次或任何其他实际或潜在破产或类似无力偿债程序有关的所有文件。\n\n3. 关于与债务人、债务人的破产财产、债务人的家庭成员、关联实体或关联个人有关的任何资产负债表、银行对账单、账户对账单、财务报表、账户报表、电汇指示和/或确认函、资金证明、存款证明、持仓证明、投资组合摘要或类似文件的所有文件，包括但不限于足以显示向前述任何一方作出的所有转让的全部文件。\n\n案号 22-50073 文件 3193 提交日期 05/16/24 录入日期 05/16/24 10:28:21 第 342 页，共 439 页\n\n4. 关于由债务人、债务人的家庭成员、关联个人或关联实体作出、与其进行或代表其作出的任何投资、商业交易或其他交易的所有文件。\n\n5. 与债务人、债务人的家庭成员、关联个人或关联实体进行的所有通信，以及与同债务人、债务人的家庭成员、关联个人或关联实体进行的通信有关的文件，包括与任何实体的运营、管理或决策有关的通信和文件，包括但不限于关联实体。\n\n6. 关于向债务人、债务人的家庭成员、关联个人或关联实体作出、由其作出或与其进行的任何转让、投资、其他交易或商业往来的所有文件。\n\n7. 关于债务人曾占用或使用过的任何财产的所有文件，包括但不限于位于 Connecticut（康涅狄格州）Greenwich（格林尼治）373 Taconic Rd. 的住宅物业；位于 Connecticut（康涅狄格州）Greenwich（格林尼治）33 Ferncliff Rd. 的住宅物业；位于 Connecticut（康涅狄格州）Wilton（威尔顿）354 Nod Hill Rd 的住宅物业；位于 United Kingdom（英国）London（伦敦）SW7 1QJ、5 Princes Gate 的公寓或共管公寓；以及位于 New Jersey（新泽西州）Mahwah（马瓦）675 Ramapo Valley Road, Mahwah, New Jersey 07430 的住宅物业。\n\n8. 与债务人拥有、控制或使用的任何航空器有关的所有文件，包括但不限于：(i) 尾号为 T7-GQM 的航空器及在 San Marino（圣马力诺）注册的任何其他航空器，包括但不限于所有登记文件副本及显示该等航空器所执行航班和该等航班机上人员的飞行清单；以及 (ii) 任何 Cirrus SF50 航空器。\n\n案号 22-50073 文件 3193 提交日期 05/16/24 录入日期 05/16/24 10:28:21 第 343 页，共 439 页\n\n9. 关于向债务人、债务人的破产财产、债务人的家庭成员或关联实体提供、从其取得或代表其提供的任何赠与、利益或贷款的所有文件，包括但不限于足以显示该等赠与、利益或贷款金额；该等赠与、利益或贷款的使用目的；提供该等赠与、利益或贷款的时间；以及任何贷款的条款、就任何贷款作出的全部陈述与保证、任何贷款的利率及任何贷款的所有付款证据的文件。\n\n10. 关于由债务人、代表债务人或为债务人利益，或由债务人的破产财产、债务人的家庭成员或关联实体设立的任何信托或类似文书的所有文件，包括但不限于足以显示该等信托设立时间、设立人、为谁的利益设立及信托财产的文件。\n\n11. 与涉及债务人的任何法律争议相关的任何义务、债权、责任或债务有关的所有文件，包括但不限于与在任何地方、州、联邦或国际机构面前进行的任何诉讼有关的文件，无论该机构为行政机构、法院、合议庭或替代性争议解决实体。\n\n12. 与债务人、债务人的家庭成员或关联个人进行的所有文件及通信。\n\n13. 您的任何律师或其他顾问与债务人、债务人的家庭成员或关联个人之间的所有文件及通信。\n\n14. 与您目前或曾经持有权益的任何关联实体有关的所有文件。\n\n附件 C-18\n\nB2540（表格 2540－Rule 2004 审查传票）（12/15）案号 22-50073 文件 3193 提交日期 05/16/24 录入日期 05/16/24 10:28:21 第 345 页，共\n\nUNITED STATES BANKRUPTCY COURT（美国破产法院）\n\nDistrict of Connecticut（康涅狄格区）\n\n关于 HO WAN KWOK（郭文贵）等人，\n\n1 案号 22-50073 (JAM) 债务人 第 11 章\n\n（合并管理）\n\nRule 2004 审查传票\n\n致：Andrea Volpe（安德烈亚·沃尔佩）\n\n（传票所指向人员的姓名）\n\n证言：现命令您于下列规定的时间、日期和地点出席，并依《联邦破产程序规则》第 2004 条接受审查并作证。随附授权该审查的法院命令副本。\n\n地点　日期和时间\n\n不适用　不适用\n\n审查将以下列方式记录：不适用\n\n提交：您或您的代表还必须在参加询问时携带下列文件、电子存储信息或物品，并必须允许对该等材料进行查阅、复制、测试或抽样：\n见随附的《文件出示请求》。\n\n以下《联邦民事诉讼规则》45条的规定，经《联邦破产程序规则》9016条适用于破产案件，随附于后——涉及履行地点的规则45(c)；涉及对作为传票对象之人的保护的规则45(d)；以及涉及您对本传票的答复义务及未履行该义务可能后果的规则45(e)和45(g)。\n\n日期：May , 2024\n\n法院书记官\n\n或\n\n书记官或副书记官签名 律师签名\n\n代表发出或请求本传票的第11章受托人Luc A. Despins（卢克·A·德斯平斯）的律师姓名、地址、电子邮件地址和电话号码如下：\n\nPatrick R. Linsey, Esq.（帕特里克·R·林赛，律师）；Neubert, Pepe & Monteith, P.C.；195 Church Street, 13th Floor, New Haven, Connecticut 06510；plinsey@npmlaw.com；(203) 781-2847\n致发出或请求本传票之人的通知\n\n如本传票命令在审判前出示文件、电子存储信息或有形物品，或查验场所，则必须在向被指向之人送达前，向各方当事人送达通知及本传票副本。Fed. R. Civ. P. 45(a)(4).\n\n软件版权所有 (c) 1996-2022 Best Case, LLC - www.bestcase.com Best Case Bankruptcy 1 本第11章案件的债务人为Ho Wan Kwok（郭文贵）（亦称Guo Wengui、Miles Guo及Miles Kwok，以及众多其他别名）（税务识别号码后四位：9595）、Genever Holdings LLC（税务识别号码后四位：8202）及Genever Holdings Corporation。受托人、Genever Holdings LLC及Genever Holdings Corporation的邮寄地址为Paul Hastings LLP，200 Park Avenue, New York, NY 10166，转交作为Ho Wan Kwok遗产受托人的Luc A. Despins（仅为通知及通信之目的）。\n送达证明\n\n（除非Fed. R. Civ. P. 45要求，否则本节不应提交法院。）\n\n我于（日期）收到向（个人姓名及职务，如有）发出的本传票。\n\n我通过以下方式向被指定之人交付副本送达本传票：\n\n于（日期）；或\n\n我未执行即退回本传票，原因如下：\n\n除非本传票代表美国或其官员或代理人发出，否则我还已向证人支付一天出席费用及法律允许的里程费，金额为$。\n\n我的差旅费用为$，服务费用为$，合计$。\n\n我在伪证处罚的约束下声明，该等信息真实且正确。\n\n日期：\n\n送达人签名\n\n正楷姓名及职务\n\n送达人地址\n\n关于尝试送达等的补充信息：\n《联邦民事诉讼规则》45(c)、(d)、(e)及(g)（Effective 12/1/13）（经《联邦破产程序规则》9016条适用于破产案件）\n(c) 履行地点。\n\n(1) 审判、听证或证言录取。传票仅可按下列方式命令某人出席审判、听证或证言录取：\n\n(A) 在该人居住、受雇或定期亲自从事商业活动地点100英里以内；或\n\n(B) 在该人居住、受雇或定期亲自从事商业活动所在州内，如该人\n\n(i) 为当事人或当事人的高级职员；或\n\n(ii) 被命令出席审判且不会产生重大费用。\n\n(2) 其他证据开示。传票可命令：\n\n(A) 在该人居住、受雇或定期亲自从事商业活动地点100英里以内的地点出示文件、电子存储信息或物品；以及\n\n(B) 在拟查验的场所查验该场所。\n(d) 保护作为传票对象之人；执行。\n\n(1) 避免不当负担或费用；制裁。负责发出和送达传票的当事人或律师必须采取合理措施，避免对作为传票对象之人施加不当负担或费用。要求履行的地区法院必须执行该义务，并对未遵守者——当事人或律师——施加适当制裁，制裁可包括损失的收入及合理的律师费。\n(2) 命令出示材料或允许查验。\n\n(A) 无须出席。被命令出示文件、电子存储信息或有形物品，或允许查验场所之人，无须亲自到达出示或查验地点，除非其还被命令出席证言录取、听证或审判。\n\n(B) 异议。被命令出示文件或有形物品，或允许查验之人，可向传票中指定的当事人或律师送达书面异议，反对查阅、复制、测试或抽样全部或部分材料，或反对查验场所——或反对以所请求的一种或多种形式出示电子存储信息。异议必须在规定履行时间或传票送达后14日中较早者之前送达。如提出异议，适用以下规则：\n\n(i) 送达方可随时在通知被命令之人后，向要求履行的地区法院提出动议，请求作出强制出示或查验的命令。\n\n(ii) 仅可依命令指示要求实施该等行为，且该命令必须保护既非当事人亦非当事人高级职员之人，使其免于因履行而产生重大费用。\n(3) 撤销或修改传票。\n\n(A) 必须撤销或修改的情形。经及时动议，要求履行的地区法院必须撤销或修改具有下列情形的传票：\n\n(i) 未给予合理履行时间；\n\n(ii) 要求某人在规则45(c)规定的地域限制以外履行；\n\n(iii) 要求披露享有特权或以其他方式受保护的事项，且不适用任何例外或放弃；或\n\n(iv) 对某人施加不当负担。\n\n(B) 可以撤销或修改的情形。为保护作为传票对象或受传票影响之人，经动议，要求履行的地区法院可撤销或修改要求下列事项的传票：\n\n(i) 披露商业秘密或其他保密研究、开发或商业信息；或\n\n(ii) 披露未受聘专家的意见或信息，该等意见或信息并未描述争议中的特定事件，且源于当事人未请求该专家进行的研究。\n\n(C) 规定条件作为替代措施。在规则45(d)(3)(B)所述情形下，如送达方：\n\n(i) 证明对证言或材料具有重大需要，且如不遭受不当困难则无法以其他方式满足该需要；并且\n\n(ii) 确保被传唤之人将获得合理补偿，\n\n法院可不撤销或修改传票，而命令在规定条件下出席或出示。\n(e) 答复传票的义务。\n\n(1) 出示文件或电子存储信息。下列程序适用于出示文件或电子存储信息：\n\n(A) 文件。答复要求出示文件的传票之人，必须按照该等文件在正常营业过程中保存的方式出示，或必须将其整理并标记，使其对应于请求中的类别。\n\n(B) 未指定电子存储信息的出示形式。如传票未指定电子存储信息的出示形式，答复之人必须以其通常保存的一种或多种形式，或以合理可用的一种或多种形式出示。\n\n(C) 电子存储信息仅以一种形式出示。答复之人无须以一种以上形式出示相同的电子存储信息。\n\n(D) 无法合理获取的电子存储信息。答复之人无须就其确认因不当负担或费用而无法合理获取的来源中的电子存储信息提供证据开示。在强制证据开示动议或保护令动议中，答复之人必须证明该等信息因不当负担或费用而无法合理获取。如作出该证明，法院在考虑规则26(b)(2)(C)的限制后，如请求方证明有正当理由，仍可命令从该等来源进行证据开示。法院可为该证据开示规定条件。\n(2) 主张特权或保护。\n\n(A) 扣留的信息。依据信息享有特权或受审判准备材料保护的主张而扣留被传唤信息之人，必须：(i) 明确提出该主张；以及\n\n(ii) 在不披露本身享有特权或受保护的信息的情况下，以足以使当事人评估该主张的方式描述被扣留文件、通信或有形物品的性质。\n\n(B) 已出示的信息。如为答复传票而出示的信息受到特权主张或审判准备材料保护主张的约束，提出该主张之人可将该主张及其依据通知任何收到该信息的当事人。收到通知后，当事人必须立即返还、隔离或销毁指定信息及其所持有的任何副本；在该主张得到解决前不得使用或披露该信息；如该当事人在收到通知前已披露该信息，必须采取合理措施取回该信息；并可立即将该信息密封提交要求履行的地区法院，以裁定该主张。出示该信息之人必须在该主张得到解决前保存该信息。\n\n(g) 藐视法庭。要求履行的地区法院——以及在动议移送后，发出传票的法院——可认定已被送达但无充分理由不遵守传票或相关命令之人构成藐视法庭。\n\n如需查阅传票材料，见Fed.R.Civ.P.45(a) Committee Note (2013)\n\n…\n\n文件出示请求\nI. 指示\n\n1. 除非另有说明，下文所列文件请求（以下简称“请求”，各称“一项请求”）必须分别并具体作出答复。除非您出于善意提出异议，否则必须对每项请求作出完整答复；如有异议，您必须按下文规定详细说明异议理由。如异议仅涉及一项请求的一部分，或其中所载的一个词语、短语或条款，您须仅就该部分说明您的异议，并对其余请求作出答复。\n\n2. 电子存储信息必须按照下列指示出示：\n\na. 图像。黑白图像必须为 300 DPI Group IV 单页 TIFF 文件。彩色图像必须以 JPEG 格式提供。文件名不得包含内嵌空格或特殊字符（包括逗号）。文件夹名称不得包含内嵌空格或特殊字符（包括逗号）。所有 TIFF 图像文件必须具有唯一的文件名，即 Bates 编号。图像必须在每张图像的右下角标注连续的 Bates 编号。每个文件夹中的 TIFF 文件数量不应超过 1000 个文件。Excel 电子表格应具有以该文件 Bates 编号命名的占位图像。\n\nb. 图像加载文件\n\na. Concordance® 数据文件。数据文件（.DAT）包含将加载至 Concordance® 数据库的所有字段化信息。.DAT 文件的第一行必须为标识字段名称的标题行。.DAT 文件必须使用以下 Concordance® 默认分隔符：逗号 ASCII 字符（020）；引号 þ ASCII 字符（254）。日期字段应以如下格式提供：mm/dd/yyyy。日期和时间字段必须为两个独立字段。如果文档包括已成像的电子邮件及附件，则必须包括附件字段，以保留电子邮件与其附件之间的父项/子项关系。必须包括 OCRPATH 字段，以提供所交付存储介质上提取文本文件的文件路径和名称。文本文件必须以 FIRSTBATES 命名。不得在 .DAT 文件中包含文本。对于具有原生文件的文档，必须包括 LINK 字段，以提供原生文件的文件路径和名称。原生文件必须以 FIRSTBATES 命名。\n\nb. Concordance Image® 或 Opticon 交叉引用文件。图像交叉引用文件（.LOG 或 .OPT）将图像与数据库记录关联。其应为以逗号分隔的文件，每行由七个字段组成；数据库中的每张图像均应在交叉引用文件中有一行，格式如下：ImageID,VolumeLabel,ImageFilePath,DocumentBreak,FolderBreak,Box Break,PageCount。\n\nc. 文档文本。文本必须作为独立文本文件提供，而不得作为 .DAT 文件中的字段提供。应在 .DAT 文件中包括文本文件的完整路径（OCRPATH）。建议使用以 FIRSTBATES/Image Key 命名的文档级 ANSI 文本文件。提取的文本文件必须置于单独文件夹中，每个文件夹中的文本文件数量不应超过 1,000 个文件。文件夹名称中不得有特殊字符（包括逗号）。文本文件必须以文档级别提供。\n\nd. 某些文件类型的原生格式提供。为完整理解其内容和含义而合理地需要以原生格式查看的文件类型，必须以原生格式提供。这些文件包括但不限于电子表格、类电子表格文件（Microsoft Excel（微软 Excel）、逗号分隔值、制表符分隔值等）、Microsoft PowerPoint（微软 PowerPoint）或其他特殊演示文件、数据库文件以及音频/视频文件。提供一张带 Bates 编号的分隔页图像，注明存在原生文件，并将原生文件的路径作为字段包括在 .dat 文件中。所提供的原生文件应以与该文件分隔页相对应的 Bates 编号命名。将原生文件归入按递增方式命名的 “NATIVE” 目录中，与图像目录分开。\n\ne. 去重。对于存在完全重复件的每一电子文档，仅提供一份副本。对于电子邮件，根据由 BCC、Body、CC、From、IntMsgID、To 和 Attach 属性生成的 MD5 哈希值合并重复件。对于电子邮件附件和独立电子文件，根据整个文件的 MD5 哈希值合并重复件。\n\nf. 元数据。以符合 Concordance 要求的加载文件（.dat）形式提供每份文档的提取元数据。.DAT 文件的第一行必须为标识字段名称的标题行。.DAT 文件必须使用以下 Concordance 默认分隔符：逗号 , ASCII 字符（020）；引号 þ ASCII 字符（254）。\n\n日期字段应以如下格式提供：mm/dd/yyyy。日期和时间字段必须为两个独立字段。所需元数据如下所列：\n\n案号 22-50073 文档 3193 提交日期 05/16/24 录入日期 05/16/24 10:28:21 第 350 页，共 439 页\n\n字段名称　样例数据　说明\n\nFIRSTBATES　EDC0000001　原生文件文档/电子邮件的首个 Bates 编号\n\nLASTBATES　EDC0000001　原生文件文档/电子邮件的最后一个 Bates 编号\n\nLASTBATES 字段应针对单页填写。\n\nATTACHRANGE　EDC0000001 - EDC0000015　父文档首页的 Bates 编号至最后一个附件“子”文档最后一页的 Bates 编号\n\nBEGATTACH　EDC0000001　附件范围的首个 Bates 编号\n\nENDATTACH　EDC0000015　附件范围的最后一个 Bates 编号\n\nCUSTODIAN　Smith, John（约翰·史密斯）　电子邮件：电子邮件所在的邮箱。原生文件：文档源自其文件的个人或部门名称。\n\nFROM　John Smith（约翰·史密斯）　电子邮件：发件人。原生文件：文档作者。多个条目之间应使用分号分隔。\n\nTO　Coffman, Janice（珍妮丝·科夫曼）；LeeW [mailto:LeeW@MSN.com]　收件人。多个条目之间应使用分号分隔。\n\nCC　Frank Thompson（弗兰克·汤普森） [mailto:frank_Thompson@cdt.com]　抄送收件人。多个条目之间应使用分号分隔。\n\nBCC　John Cain（约翰·凯恩）　密件抄送收件人。多个条目之间应使用分号分隔。\n\nSUBJECT　Board Meeting Minutes　电子邮件：电子邮件的主题行。原生文件：文档标题（如有）。\n\nFILE_NAME　BoardMeetingMinutes.docx　原生文件：原始原生文件的名称，包括扩展名。\n\nDATE_SENT　10/12/2010　电子邮件：发送电子邮件的日期。原生文件：（空）。\n\nTIME_SENT/TIME_ZONE　07:05 PM GMT　电子邮件：发送电子邮件的时间/电子邮件标准化所使用的时区。\n\nTIME_ZONE　GMT　在转换过程中电子邮件被标准化所使用的时区。\n\nLINK　EDC0000001.msg　电子邮件或原生文件文档的超链接。链接文件必须以 FIRSTBATES 编号命名。\n\nFILE_EXTEN　MSG　表示电子邮件或原生文件文档的文件类型扩展名。\n\nAUTHOR　John Smith（约翰·史密斯）　电子邮件：（空）。原生文件：文档作者。\n\nDATE_CREATED　10/10/2010　电子邮件：（空）。原生文件：文档创建日期。\n\n案号 22-50073 文档 3193 提交日期 05/16/24 录入日期 05/16/24 10:28:21 第 351 页，共 439 页\n\nTIME_CREATED　10:25 AM　电子邮件：（空）。原生文件：文档创建时间。该数据必须为独立字段，不得与 DATE_CREATED 字段合并。\n\nDATE_MOD　10/12/2010　电子邮件：（空）。原生文件：文档最后修改日期。\n\nTIME_MOD　07:00 PM　电子邮件：（空）。原生文件：文档最后修改时间。该数据必须为独立字段，不得与 DATE_MOD 字段合并。\n\nDATE_ACCESSD　10/12/2010　电子邮件：（空）。原生文件：文档最后访问日期。\n\nTIME_ACCESSD　07:00 PM　电子邮件：（空）。原生文件：文档最后访问时间。该数据必须为独立字段，不得与 DATE_ACCESSD 字段合并。\n\nFILE_SIZE　5,952　原生文件文档/电子邮件的大小，以 KB 为单位。\n\nPGCOUNT　1　原生文件文档/电子邮件的页数。\n\nPATH　电子邮件：（空）；Agenda.doc　原生文件：存储原生文件文档的路径，包括原始文件名。\n\nINTFILEPATH　Personal Folders\\Deleted Items\\Board Meeting Minutes.msg　电子邮件：电子邮件的原始位置，包括原始文件名。原生文件：（空）。\n\nINTMSGID　<000805c2c71b\\$75977050\\$cb8306d1@MSN>　电子邮件：唯一邮件 ID。原生文件：（空）。\n\nMD5HASH　d131dd02c5e6eec4693d9a0698aff95c2fcab58712467eab4004583eb8fb7f89　文档的 MD5 哈希值。\n\nOCRPATH　TEXT/001/EDC0000001.txt　原生文件提取文本的路径。\n\n3. 每项请求均独立适用并应独立解释，除非另有说明，任何请求均不限制任何其他请求的范围。\n\n4. 所有文档应按其在通常业务过程中保存的方式提供，或者应予以组织和标记，以与本请求中的类别相对应。\n\n5. 本文所载每项请求均延及所有文档：(a) 由您占有、保管或控制的文档；或 (b) 由代表您行事的任何人占有、保管或控制的文档，\n\n案号 22-50073 文档 3193 提交日期 05/16/24 录入日期 05/16/24 10:28:21 第 352 页，共 439 页\n\n包括您的律师或其他代表和顾问。每份文档均应完整提供。\n\n6. 如要求您提供一份已不再由您占有、保管或控制的文档，则您的答复必须：(a) 详细描述该文档的性质及其内容；(b) 指明编制或撰写该文档的人员，以及（如适用）该文档被发送给的人员；(c) 指明该文档编制或创建的日期；(d) 说明该文档是否：(i) 遗失或丢失，(ii) 已被销毁，(iii) 自愿或非自愿地转移给他人，或 (iv) 以其他方式处置；(e) 说明该等处置的理由以及相关事实和情形；(f) 指明授权该等处置的人员；(g) 指明该等处置的日期或大致日期；(h) 说明该文档最近一次由您占有、保管或控制的时间；以及 (i) 指明目前占有、保管或控制该文档的人员（如有）。\n\n7. 如要求您提供一份已被销毁的文档，则除前述指示所要求的信息外，您的答复还必须说明：(a) 销毁该文档的理由；(b) 销毁该文档的人员身份；以及 (c) 指示销毁该文档的人员身份。\n\n8. 如您主张所请求的文档享有特权或属于律师工作成果，则您的答复必须：(a) 说明：(i) 足以支持您关于该文档享有特权这一主张的文档描述，(ii) 文档标题，(iii) 文档日期，(iv) 文档作者，(v) 文档收件人，(vi) 收到或阅览该文档原件或任何草稿、副本或复制件的每位人员身份，(vii) 该文档本身，或文档中所含或提及的任何信息，是否由任何其他人员占有、保管或控制；如是，则该等人员的身份，\n\n案号 22-50073 文档 3193 提交日期 05/16/24 录入日期 05/16/24 10:28:21 第 353 页，共 439 页\n\n以及说明该等人员如何获得该信息的陈述，(viii) 据以扣留该文档的特权主张，以及 (ix) 您将据以支持该特权主张的所有情形；以及 (b) 依照 D. Conn. L. Civ. R. 26(e)，就每份基于特权主张而被扣留的文档，提供一份特权清单，其中包含本指示第 (a) 部分所要求的全部信息。\n\n9. 如原本应提供的文档的一部分含有受特权主张约束的信息，则仅应按照上述指示从该文档中删除或遮盖受该特权主张约束的部分，其余部分应予提供。\n\n10. 该等请求具有持续性。特此指示您：(a) 一旦知悉先前答复不完整或不正确，应立即补充或更正任何后来获知不完整或不正确的答复；以及 (b) 提供根据该等请求所要求的任何附加文档。\n\n11. 如一份文档为英语以外的语言，您应提供该文档。如一份文档为英语以外的语言，且存在英文译文，您应同时提供两份文档。\n\n12. 对实体的所有提述均包括其所有关联方。\n\n13. 对个人姓名的所有提述均包括所有其他姓名、别名或昵称。\n\n14. 除非另有明确说明，文件请求所涵盖的期间为自 February 5, 2012 起至文件请求答复到期之日止。\n\nII. 解释规则\n\n15. (a) 任何单数名词的使用应解释为包括复数，反之亦然；及 (b) 任何时态动词的使用应解释为在所有其他时态中使用该动词。\n\n16. (a) “and”和“or”应视必要情况作连词性或选择性解释，以将否则可能被解释为超出任何请求范围的所有答复纳入该请求范围内；及 (b) “each”和“any”应视为包括并涵盖“every”和“all”二词。\n\nIII. 定义\n\n经 D. Conn. Bankr. L.R. 2004-1(a) 纳入的 D. Conn. L. Civ. R. 26(c) 所规定的定义，以及 D. Conn. L. Civ. R. 26(d) 所规定的解释规则，应适用于文件请求。此外，本文件请求中使用的下列术语具有以下含义：\n\n1. “You”或“Your”或“Yourself”系指 Andrea Volpe（安德烈亚·沃尔佩），连同其所有代理人、律师、代表、雇员及/或任何代表其行事之人。\n\n2. “Debtor”系指 Ho Wan Kwok（郭文贵）（又名 Miles Kwok、Miles Guo、Guo Wengui、Guo Haoyun、郭文贵或任何其他别名），连同其雇员、代理人、律师、顾问或任何代表其行事之人。\n\n3. “Debtor's Son”系指 Qiang Guo（郭强）（又名 Mileson Kwok、郭强或任何其他别名），连同其雇员、代理人、律师、顾问或任何代表其行事之人。\n\n4. “Debtor's Daughter”系指 Mei Guo（郭美）（又名 Mei Gui、郭美或任何其他别名），连同其雇员、代理人、律师、顾问或任何代表其行事之人。\n\nCase 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 355 of 439\n\n5. “Debtor's Purported Wife”系指 Hing Chi Ngok（岳庆芝）（又名 Hing Chi Ng、Yue Qingzhi、岳庆芝或任何其他别名），连同其雇员、代理人、律师、顾问或任何代表其行事之人。\n\n6. “Debtor's Family”合称债务人、债务人之子、债务人之女以及债务人自称的妻子，并包括与债务人有任何其他家庭关系之人。\n\n7. “Associated Individuals”单独及合称指所有符合以下情形的个人：(1) 持有、控制、保管或对债务人或债务人家庭所拥有、控制或享有的资产具有酌处权；或 (2) 曾担任一个或多个关联实体的雇员、董事，或以其他方式与一个或多个关联实体有关联，连同前述各方各自的雇员、代理人、律师、顾问或任何代表其行事之人。该等关联个人包括但不限于：Anthony DiBattista（安东尼·迪巴蒂斯塔）、Alex Hadjicharalambous（亚历克斯·哈吉查拉兰布斯）、Bernardo Enriquez（贝尔纳多·恩里克斯）、Bingshang Jiao（焦炳尚）、Beile Li（李贝乐）、Brian W. Hofmeister（布赖恩·W·霍夫迈斯特）、Charles Gruder（查尔斯·格鲁德）、Daniel Podhaskie（丹尼尔·波德哈斯基）、David Fallon（大卫·法伦）、Defeng Cao（曹德锋）（又名 Wayne Cao、Max Cao）、Ding Lin（林丁）、Dinggang Wang（王定刚）（又名 王定刚）、Eduardo Eurnekian（爱德华多·厄内基安）、Ehsan Masud（埃赫桑·马苏德）、Fiona Yu（余菲奥娜）、Gladys Chow（周格拉迪斯）、Hao (Gavin) Li（李浩）（又名 Huo Lai）、Hao Haidong（郝海东）（又名 郝海东）、Han Chunguang（韩春光）（又名 韩春光）、Haoran He（何浩然）、Ivan Lin（林伊万）、Haitham Khaled（海赛姆·哈立德）、Jason Miller（杰森·米勒）、Jennifer Mercurio（詹妮弗·默丘里奥）、Jesse Brown（杰西·布朗）、Jessica Mastrogiovanni（杰西卡·马斯特罗焦瓦尼）、Jie Zhang（张杰）、Jintao Li（李金涛）、Karin Maistrello（卡琳·迈斯特雷洛）、Kyle Bass（凯尔·巴斯）、Lihong Wei Lafrenz（魏丽红）（又名 Sara Wei、魏丽红）、Linwan “Irene” Feng（冯林婉）、Max Krasner（马克斯·克拉斯纳）、Melissa Francis（梅利莎·弗朗西斯）、Michael Baranowitz（迈克尔·巴拉诺维茨）、Min Yang（杨敏）、Melissa Mendez（梅利莎·门德斯）、Nadeem Akbar（纳迪姆·阿克巴尔）、Nan Li（李楠）（又名 Chris Lee、Mei Guo Xiao Li）、Qidong Xia（夏启东）、Qu Guojiao（屈国姣）（又名 Qu Guo Jiao、屈国姣）、Ridwan Mamode Saib（里德万·马莫德·赛布）、Ross Heinemeyer（罗斯·海内迈耶）、Rui “Ray” Hao（郝睿）、Scott Barnett（斯科特·巴尼特）、Shih Hsin Yu（余世新）、Shin Hee-Seup（申熙燮）（又名 Hee Seup Shin）、Steve Bannon（史蒂夫·班农）、Talha Zobair（塔尔哈·祖拜尔）、Victor Cerda（维克托·塞尔达）、Wen Xiao（肖雯）、Wencong Wang（王文聪）、William Gertz（威廉·格茨）、William Je（余建明）（又名 Je Kin Ming、Yu Jianming、余建明）以及 Xuebing Wang（王雪冰）、\n\nCase 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 356 of 439\n\nYa Li（李娅）（又名 李娅）、Yinying (Aila) Wang（王银英）（又名 Xiao Fei Xiang）、Yongping Yan（严永平）（Shan Mu）、Yong Yu（俞勇）、Yue Zhou（周玥）、Yumei Hao（郝玉梅）（又名 Ru Shui）、Yvette Wang（王雁平）（又名 Yanping Wang、Yan Ping Wang、王雁平）、Zhang Wei（张魏）（又名 张魏）、Zhouer Wang（王周二）（又名 Joe Wang）、Zhixuan Li（李志轩）及 Ziyang Liu（刘子阳）。\n\n8. “Associated Entities”单独及合称指所有符合以下情形的任何类型组织或实体：(1) 曾由债务人或债务人家庭拥有、控制或投资；或 (2) 对债务人或债务人家庭所拥有、控制或享有的任何资产直接或间接拥有权益，连同前述各方各自的雇员、代理人、律师、顾问或任何代表其行事之人。该等关联实体包括但不限于：1332156 B.C. Ltd.（1332156 B.C. 有限公司）、7 Nod Hill LLC（7 Nod Hill 有限责任公司）、AAGV Limited（AAGV 有限公司）、ACA Investment Management Limited（ACA 投资管理有限公司）、ACA Capital Group Limited（ACA 资本集团有限公司）、Ace Decade Holdings Limited（Ace Decade 控股有限公司）、AI Group Holdings Inc.（AI Group 控股公司）、Alfa Global Ventures Limited（Alfa 全球创业有限公司）、Alfonso Global Limited（Alfonso 全球有限公司）、Allied Capital Global Limited（Allied Capital 全球有限公司）、Alpine Fiduciaries SA（Alpine 受托人股份公司）、Beijing Pangu Investment Co.（北京盘古投资公司）、Beijing Pangu Investment Co. Ltd.（北京盘古投资有限公司）、Beijing Pangu Investment Inc.（北京盘古投资股份有限公司）、Beijing Zenith Holdings Company Limited（北京顶峰控股有限公司）、Blue Capital Limited（蓝色资本有限公司）、Booming Sail New York LLC（Booming Sail 纽约有限责任公司）、Bravo Luck Limited（Bravo Luck 有限公司）、Brent Petro（布伦特·彼得罗）、BSA Strategic Fund I（BSA 战略基金 I）、China Golden Spring (Hong Kong) Limited（中国金泉〈香港〉有限公司）、Chuang Xin Limited（创新有限公司）、Crane Advisory Group LLC（Crane 咨询集团有限责任公司）、Creative Apex Investments Limited（Creative Apex 投资有限公司）、Crystal Breeze Investments Limited（Crystal Breeze 投资有限公司）、Dawn State Limited（Dawn State 有限公司）、Eastern Profit Corporation Limited（Eastern Profit 公司有限公司）、Empire Growth Holdings（Empire Growth 控股公司）、Elite Well Global Limited（Elite Well 全球有限公司）、Freedom Media Ventures Ltd.（Freedom Media Ventures 有限公司）、Fung Wan Trading Inc.（Fung Wan 贸易公司）、G Club（G 俱乐部）、G Club Operations LLC（G 俱乐部运营有限责任公司）、G Club International Limited（G 俱乐部国际有限公司）、G Club Investments Limited（G 俱乐部投资有限公司）、G Fashion LLC（G Fashion 有限责任公司）、G-News Operations LLC（G-News 运营有限责任公司）、G News LLC（G News 有限责任公司）、GMusic Inc.（GMusic 公司）、G-Services LLC（G-Services 有限责任公司）、G-Translators PTY LTD（G-Translators 私人有限公司）、GETTR USA, Inc.（GETTR 美国公司）、Genever Holdings Corporation（Genever 控股公司）、Genever Holdings LLC（Genever 控股有限责任公司）、GFashion Media Group Inc.（GFashion 媒体集团公司）、GFNY, Inc.（GFNY 公司）、Globalist International Limited（Globalist 国际有限公司）、GNews Media Group Inc.（GNews 媒体集团公司）、Golden Spring (New York) Ltd.（Golden Spring〈纽约〉有限公司）、Guo Media（郭媒体）、GTV Media Group, Inc.（GTV 媒体集团公司）、GWGOPNZ\n\nCase 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 357 of 439\n\nLimited（GWGOPNZ 有限公司）、GWGNZ Limited（GWGNZ 有限公司）、Gypsy Mei Food Services, LLC（Gypsy Mei 餐饮服务有限责任公司）、HCHK Property Management Inc.（HCHK 物业管理公司）、HCHK Technologies Inc.（HCHK 技术公司）、Hamilton Digital Assets FD SP（Hamilton 数字资产 FD SP）、Hamilton Capital Holdings Inc.（Hamilton 资本控股公司）、Hamilton Opportunity Fund SPC（Hamilton 机会基金 SPC）、Head Win Group Limited（Head Win 集团有限公司）、Himalaya Embassy（喜马拉雅大使馆）、Himalaya Exchange（喜马拉雅交易所）、Himalaya Federal Reserve（喜马拉雅联邦储备）、Himalaya International Financial Group Ltd.（喜马拉雅国际金融集团有限公司）、Himalaya Investment LLC（喜马拉雅投资有限责任公司）、Himalaya (USA) Investment Management LLC（喜马拉雅〈美国〉投资管理有限责任公司）、Himalaya New World Inc.（喜马拉雅新世界公司）、Himalaya Supervisory Organization（喜马拉雅监督组织）、Himalaya Ventures（喜马拉雅创业公司）、Holy City Hong Kong Ventures, Ltd.（Holy City 香港创业有限公司）、Hudson Diamond Holding LLC（Hudson Diamond Holding 有限责任公司）、Hudson Diamond Holding Inc.（Hudson Diamond Holding 公司）、Hudson Diamond NY LLC（Hudson Diamond 纽约有限责任公司）、HK International Funds Investments (USA) Limited LLC（香港国际基金投资〈美国〉有限责任公司）、Hong Kong International Funds Investments Limited（香港国际基金投资有限公司）、Huk Trading Inc（Huk 贸易公司）、Infinite Increase Limited（Infinite Increase 有限公司）、Infinitum Developments Limited（Infinitum 开发有限公司）、Japan Himalaya League, Inc.（日本喜马拉雅联盟公司）、Kalixun Trading Limited（Kalixun 贸易有限公司）、Lamp Capital LLC（Lamp Capital 有限责任公司）、Leading Shine Limited（Leading Shine 有限公司）、Leading Shine NY Limited（Leading Shine NY 有限公司）、Lexington Property and Staffing Inc.（Lexington 物业与人力公司）、Long Gate Limited（Long Gate 有限公司）、MOS Himalaya Foundation Inc.（MOS 喜马拉雅基金会公司）、Maywind Trading LLC（Maywind 贸易有限责任公司）、New Federal State of China（新中国联邦）（又名 NFSC）、New York MOS Himalaya LLC（纽约 MOS 喜马拉雅有限责任公司）、New Mulberry PTE Ltd.（New Mulberry 私人有限公司）、Newpeople LLC（Newpeople 有限责任公司）、Noble Fame Global Limited（Noble Fame 全球有限公司）、Pixshow Film Inc.（Pixshow 电影公司）、Roscalitar 2（Roscalitar 2）、Rosy Acme Ventures Limited（Rosy Acme 创业有限公司）、Rule of Law Foundation III, Inc.（法治基金会 III 公司）、Rule of Law Society（法治协会）、Rule of Law Society IV, Inc.（法治协会 IV 公司）、Santel LLC（Santel 有限责任公司）、Saraca Media Group, Inc.（Saraca 媒体集团公司）、Shiny Ace Ltd.（Shiny Ace 有限公司）、Shiny Times Holdings Ltd.（Shiny Times 控股有限公司）、Stevenson, Wong & Co.（Stevenson、Wong 及公司）、Taurus Fund LLC（Taurus 基金有限责任公司）、Taurus Fund SP（Taurus 基金 SP）、Taurus Management LLC（Taurus 管理有限责任公司）、The Lost Draft LLC（The Lost Draft 有限责任公司）、TM Primrose Limited（TM Primrose 有限公司）、UA Himalaya Inc.（UA 喜马拉雅公司）、Voice of Guo Media, Inc.（郭媒体之声公司）、Well Origin Ltd.（Well Origin 有限公司）、Wise Creation（Wise Creation）、Whitecroft Shore Limited（Whitecroft Shore 有限公司）、World Century Limited（World Century 有限公司）、Worldwide Opportunity Holdings Limited（Worldwide Opportunity 控股有限公司）及 ZIBA Limited（ZIBA 有限公司）。\n\n9. “Including”或其任何变体，意为“包括但不限于”。\n\n10. “And”和“or”意为“and/or”，并应作连词性和选择性解释，以最大限度扩大其范围。\n\nCase 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 358 of 439\n\n11. “Any”、“all”和“each”意为“每一及全部”。\n\n12. “Each”和“every”意为“每一及全部”。\n\n13. “Third Party”系指您本人以外的个人或实体。\n\n14. “Transfer”具有《破产法》第 101(54) 条赋予该词的含义。\n\n15. “Document”系指属于 Fed. R. Civ. P. 34 范围内的任何信息或物件，并包括但不限于现由或曾由您占有、保管或控制的任何种类、类型、性质或描述的每一项书面、记录或图形资料，包括电子邮件的所有印刷和电子副本、以电子形式保存的计算机文件、电子通信、短信、社交媒体帖子、推文、元数据、通信函件、备忘录、磁带、速记或手写笔记、任何种类的书面表格、图表、蓝图、图纸、草图、曲线图、计划、文章、规格说明、日记、信函、电报、照片、会议记录、合同、协议、调查、计算机打印件、任何种类的数据汇编、电传、传真、语音留言、发票、订货单、支票、汇票、对账单、贷项通知单、报告、持仓报告、摘要、索引、账簿、分类账、笔记本、日程表、透明胶片、录音、目录、广告、宣传材料、影片、录像带、录音带、CD、计算机磁盘、宣传册、小册子、穿孔卡、工时单、Tweets、社交媒体帖子或任何其他种类的书面或记录材料，以及其所有元数据，无论以何种方式存储（无论为有形或电子形式）、记录、制作或复制；还包括但不限于前述任何材料的草稿或副本，该等草稿或副本含有原始文件中未见的任何种类的笔记、评论或标记，或在其他方面与原始文件不相同。\n\nCase 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 359 of 439\n\n16. “Person(s)”系指个人、公司、独资企业、合伙企业、协会或任何其他实体。“Person”还包括任何代理人、代表或专家，包括但不限于律师或财务顾问。\n\n17. “Entity”系指任何自然人、公司、合伙企业、子公司、独资企业、商号、董事会、合资企业、协会、机构、主管机关、委员会或其他商业实体或法人，以及任何关联方、代理人、母公司，包括但不限于法律顾问、财务顾问或任何其他代表。\n\n18. “Regarding”意为涉及、描述、构成、提及、与之有关、支持、赞成、反对、强化、削弱、位于其中、结合考虑、对其具有影响、证明、表明、报告、记录、暗指、答复、与之连接、评论、就其而言、关于、与之相关、讨论、显示、描述、反映、分析、构成及属于。\n\n19. 当“Relating to”、“relate(s) to”或“related to”提及任何特定事项时，意为包括但不限于构成、包含、涉及、载有、体现、反映、识别、陈述、直接或间接提及，或以任何方式与所识别的特定事项相关的任何文件。\n\n20. “Communication(s)”在最广泛的可能意义上且不受限制地系指任何信息或知识的传递（以事实、观点、询问或其他形式）。Communication(s)还指所有谈话、协议、询问或答复，无论是当面、通过电话、以书面形式，或通过电子传输设备进行，并包括但不限于所有通信函件、电子邮件、录音、传送单、备忘录、电话通信、语音留言、电报、电话传真、传真副本、\n\nCase 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 360 of 439\n\n电传、即时消息、聊天、短信、电话笔记，或在内部或与第三方之间传送的笔记。\n\n21. “资产”是指能够用于产生正向经济价值的任何项目，包括但不限于由某一实体拥有、控制或为其利益而持有的、预期将提供未来利益的任何具有经济价值的资源，包括但不限于所有不动产和动产、无形财产、投资、投资权或取得未来收入的权利、现金、银行账户、商品、证券、债权、对某一实体的全部或部分控制权，以及预期经济机会。\n\n22. “转让”具有《破产法典》第101(54)条所赋予的含义。\n\n四、应提交的文件\n\n1. 与债务人、债务人家庭成员、债务人的破产财产、关联个人或关联实体的任何收入或资产有关的所有文件。\n\n2. 与债务人的财务状况及其对债权人的义务有关的所有文件，包括但不限于与任何规避支付该等义务的努力有关的所有文件，以及与本案或任何其他实际或潜在的破产或类似无力偿债程序有关的所有文件。\n\n3. 与债务人、债务人的破产财产、债务人家庭成员、关联实体或关联个人有关的任何资产负债表、银行对账单、账户对账单、财务报表、账目报表、电汇指示和／或确认函、资金证明、存款证、持仓证明、投资组合摘要或类似文件有关的所有文件，包括但不限于足以显示向前述任何主体作出的所有转让的所有文件。\n\n案件 22-50073 文件 3193 已提交 05/16/24 已录入 05/16/24 10:28:21 第 361 页，共 439 页\n\n4. 与债务人、债务人家庭成员、关联个人或关联实体作出、与其进行或代表其作出的任何投资、商业往来或交易有关的所有文件。\n\n5. 与债务人、债务人家庭成员、关联个人或关联实体的所有通信，以及与同债务人、债务人家庭成员、关联个人或关联实体的通信有关的文件，包括与任何实体（包括但不限于关联实体）的运营、管理或决策有关的通信及文件。\n\n6. 与向债务人、债务人家庭成员、关联个人或关联实体作出、由其作出或与其进行的任何转让、投资或其他交易或商业往来有关的所有文件。\n\n7. 与债务人曾经占用或使用的任何财产有关的所有文件，包括但不限于位于 Connecticut（康涅狄格州） Greenwich（格林尼治）373 Taconic Rd. 的住宅房产；位于 Connecticut（康涅狄格州） Greenwich（格林尼治）33 Ferncliff Rd. 的住宅房产；位于 Connecticut（康涅狄格州） Wilton（威尔顿）354 Nod Hill Rd 的住宅房产；位于 United Kingdom（英国）London（伦敦）SW7 1QJ，5 Princes Gate 的公寓或共管公寓；以及位于 New Jersey（新泽西州）Mahwah（马瓦）675 Ramapo Valley Road, Mahwah, New Jersey 07430 的住宅房产。\n\n8. 与债务人拥有、控制或使用的任何航空器有关的所有文件，包括但不限于：(i) 尾号为 T7-GQM 的航空器以及在 San Marino（圣马力诺）登记的任何其他航空器，包括但不限于所有登记文件副本，以及显示该等航空器所执行航班和该等航班机上人员的飞行舱单；以及 (ii) 任何 Cirrus SF50 航空器。\n\n案件 22-50073 文件 3193 已提交 05/16/24 已录入 05/16/24 10:28:21 第 362 页，共 439 页\n\n9. 与向债务人、债务人的破产财产、债务人家庭成员或关联实体提供、由其提供或代表其提供的任何赠与、利益或贷款有关的所有文件，包括但不限于足以显示该等赠与、利益或贷款金额；该等赠与、利益或贷款的用途；该等赠与、利益或贷款的提供时间；以及任何贷款的条款、与任何贷款有关的所有陈述与保证、任何贷款的利率及任何贷款的所有付款证据的文件。\n\n10. 与由债务人、债务人的破产财产、债务人家庭成员或关联实体设立、代表其设立或为其利益设立的任何信托或类似文书有关的所有文件，包括但不限于足以显示该等信托的设立时间、设立人、为谁的利益而设立，以及信托本金的文件。\n\n11. 与涉及债务人的任何法律争议相关的任何义务、债权、责任或债务有关的所有文件，包括但不限于与在任何地方、州、联邦或国际机构（无论是行政机构、法院、合议庭或替代性争议解决实体）前进行的任何诉讼有关的文件。\n\n12. 与债务人、债务人家庭成员或关联个人的所有文件和通信。\n\n13. 您的任何律师或其他顾问与债务人、债务人家庭成员或关联个人之间的所有文件和通信。\n\n14. 与您目前或曾经持有权益的任何关联实体有关的所有文件。\n\n附件 C-19\n\nB2540（表格 2540－2004规则审查传票）（12/15）案件 22-50073 文件 3193 已提交 05/16/24 已录入 05/16/24 10:28:21 第 364 页，共\n\nUNITED STATES BANKRUPTCY COURT（美国破产法院）\n\nDistrict of Connecticut（康涅狄格联邦地区）\n\n关于 HO WAN KWOK（郭文贵）等人案，\n\n1 案件编号 22-50073 (JAM) 债务人 第11章\n\n（合并管理）\n\n2004规则审查传票\n\n致：H.R. Owen PLC（H.R. Owen公众有限公司）\n\n（传票所指向人员的姓名）\n\n证言：现命令您于下列载明的时间、日期和地点出席，并根据《联邦破产程序规则》第2004条接受审查并作证。随附授权该审查的法院命令副本。\n\n地点　日期和时间\n\n不适用　不适用\n\n审查将通过以下方式记录：不适用\n\n提交：您或您的代表还必须在审查时携带下列文件、电子存储信息或物品，并应允许对该等材料进行检查、复制、测试或抽样：\n\n见随附的文件提交请求。\n\n下列《联邦民事诉讼规则》第45条规定（根据《联邦破产程序规则》第9016条适用于破产案件）随附于此——关于履行地点的第45(c)条；关于作为传票对象之人员的保护的第45(d)条；以及关于您对本传票作出回应的义务及未作出回应可能产生后果的第45(e)条和第45(g)条。\n\n日期：May , 2024\n\n法院书记官\n\n或\n\n书记官或副书记官签名　律师签名\n\n代表签发或申请本传票的第11章受托人 Luc A. Despins（卢克·A·德斯平斯）的律师姓名、地址、电子邮件地址和电话号码如下：\n\nPatrick R. Linsey, Esq.（帕特里克·R·林赛，律师）；Neubert, Pepe & Monteith, P.C.（纽伯特、佩佩和蒙蒂斯律师事务所）；195 Church Street, 13th Floor, New Haven, Connecticut 06510；plinsey@npmlaw.com；(203) 781-2847\n\n致签发或申请本传票之人员的通知\n\n如本传票命令在审判前提交文件、电子存储信息或有形物品，或者检查场所，则在向传票所指向人员送达之前，必须向各方送达通知及本传票副本。Fed. R. Civ. P. 45(a)(4)。\n\n软件版权 (c) 1996-2022 Best Case, LLC（Best Case有限责任公司）- www.bestcase.com Best Case Bankruptcy 1 本第11章案件中的债务人为 Ho Wan Kwok（亦称 Guo Wengui、Miles Guo 和 Miles Kwok，以及众多其他别名）（税务识别号末四位：9595）、Genever Holdings LLC（Genever Holdings有限责任公司）（税务识别号末四位：8202）及 Genever Holdings Corporation（Genever Holdings股份公司）。受托人、Genever Holdings LLC 及 Genever Holdings Corporation 的邮寄地址为 Paul Hastings LLP（保罗·黑斯廷斯律师事务所），200 Park Avenue, New York, NY 10166，c/o Luc A. Despins，作为 Ho Wan Kwok 破产财产的受托人（仅限于通知和通信之目的）。\n\n送达证明\n\n（除非 Fed. R. Civ. P. 45 要求，否则本节不应向法院提交。）\n\n我于（日期）收到向（个人姓名及职务，如有）发出的本传票。\n\n我以下列方式向具名人员送达了本传票副本：\n\n于（日期）送达；或\n\n我未予执行而退回本传票，原因如下：\n\n除非本传票是代表 United States（美国）或其官员或代理人签发，我还已向证人支付一天出席费用及法律允许的里程费，金额为 $ 。\n\n我的差旅费用为 $ ，服务费用为 $ ，合计为 $ 。\n\n我在伪证罪处罚下声明，该等信息真实且正确。\n\n日期：\n\n送达人签名\n\n正楷姓名及职务\n\n送达人地址\n\n关于尝试送达等事项的补充信息：\n\n《联邦民事诉讼规则》第45(c)、(d)、(e)和(g)条（自 12/1/13 起生效）（根据《联邦破产程序规则》第9016条适用于破产案件）\n\n(c) 履行地点。\n\n(1) 审判、听证或证言录取。传票仅可按如下方式命令某人出席审判、听证或证言录取：\n\n(A) 在该人员居住、受雇或经常亲自从事商业活动地点100英里以内；或\n\n(B) 在该人员居住、受雇或经常亲自从事商业活动所在州内，若该人员\n\n(i) 为当事人或当事人的高级职员；或\n\n(ii) 被命令出席审判且不会产生重大费用。\n\n(2) 其他证据开示。传票可以命令：\n\n(A) 在该人员居住、受雇或经常亲自从事商业活动地点100英里以内的地点提交文件、电子存储信息或物品；以及\n\n(B) 在拟检查的场所对该场所进行检查。\n\n(d) 对作为传票对象之人员的保护；执行。\n\n(1) 避免不当负担或费用；制裁。负责签发和送达传票的当事人或律师必须采取合理措施，避免对作为传票对象之人员施加不当负担或费用。要求履行的地区法院必须执行该义务，并对未遵守该义务的当事人或律师施加适当制裁，其中可包括收入损失和合理的律师费。\n\n(2) 命令提交材料或允许检查。\n\n(A) 无须出席。被命令提交文件、电子存储信息或有形物品，或允许检查场所的人员，无须亲自到达提交或检查地点，除非其还被命令出席证言录取、听证或审判。\n\n(B) 异议。被命令提交文件或有形物品，或允许检查的人员，可以向传票中指定的当事人或律师送达书面异议，反对检查、复制、测试或抽样任何或全部材料，或反对检查场所，或反对以所要求的一种或多种形式提交电子存储信息。异议必须在规定的履行时间之前或传票送达后14日内（以较早者为准）送达。如提出异议，则适用下列规则：\n\n(i) 送达方可在任何时候，在通知被命令人员后，向要求履行的地区法院提出动议，请求作出强制提交或检查的命令。\n\n(ii) 仅可依照该命令所指示的方式要求实施该等行为，并且该命令必须保护既非当事人亦非当事人高级职员的人员，使其免于因履行而产生的重大费用。\n\n(3) 撤销或修改传票。\n\n(A) 必须撤销或修改的情形。经及时动议，要求履行的地区法院必须撤销或修改具有下列情形的传票：\n\n(i) 未给予合理的履行时间；\n\n(ii) 要求某人在第45(c)条规定的地域范围以外履行；\n\n(iii) 要求披露享有特权或受其他保护的事项，且不存在适用的例外或豁免；或\n\n(iv) 对某人造成不当负担。\n\n(B) 何时准许。为保护受传票约束或受传票影响的人，要求履行传票义务所在地区的法院可依动议，在传票要求下列事项时撤销或修改该传票：\n\n(i) 披露商业秘密或其他保密的研究、开发或商业信息；或\n\n(ii) 披露未受聘专家的意见或信息，而该意见或信息并未描述争议中的具体事件，且系该专家未经任何一方当事人请求而进行研究所得的结果。\n\n(C) 规定条件作为替代办法。在第45(d)(3)(B)条所述情形下，法院可不撤销或修改传票，而在送达传票的一方当事人符合下列条件时，命令在规定条件下出庭或提交材料：\n\n(i) 证明对该证言或材料具有实质性需要，且如不造成不当困难则无法以其他方式满足该需要；并且\n\n(ii) 确保受传票人将获得合理补偿。\n(e) 回应传票的义务。\n\n(1) 提交文件或电子存储信息。下列程序适用于提交文件或电子存储信息：\n\n(A) 文件。回应要求提交文件的传票的人，必须按其在日常业务过程中保存的方式提交文件，或必须将文件整理并标注，以对应请求中的类别。\n\n(B) 未规定电子存储信息提交形式。传票未规定电子存储信息的提交形式的，回应人必须按其通常保存的一种或多种形式，或以一种或多种合理可用的形式提交。\n\n(C) 电子存储信息仅以一种形式提交。回应人无需以一种以上形式提交相同的电子存储信息。\n\n(D) 无法合理访问的电子存储信息。回应人无需提供来自其认定因不当负担或费用而无法合理访问的信息源的电子存储信息的证据开示。对于强制证据开示动议或保护令动议，回应人必须证明该信息因不当负担或费用而无法合理访问。作出该证明后，如请求方在考虑第26(b)(2)(C)条限制的情况下证明存在正当理由，法院仍可命令从该等信息源进行证据开示。法院可为该证据开示规定条件。\n(2) 主张特权或保护。\n\n(A) 被扣留的信息。以该信息享有特权或作为审判准备材料受到保护为由扣留被传唤信息的人，必须：(i) 明确提出该主张；并且\n\n(ii) 以一种在不披露本身享有特权或受保护信息的情况下，足以使各方当事人评估该主张的方式，说明被扣留文件、通信或有形物品的性质。\n\n(B) 已提交的信息。如为回应传票而提交的信息被主张享有特权或作为审判准备材料受到保护，提出该主张的人可通知任何收到该信息的当事人该主张及其依据。收到通知后，当事人必须立即返还、隔离或销毁所指定的信息及其持有的任何副本；在该主张得到解决前不得使用或披露该信息；如该当事人在收到通知前已披露该信息，必须采取合理措施取回该信息；并可立即将该信息密封提交给要求履行传票义务所在地区的法院，由其裁定该主张。提交该信息的人必须在该主张得到解决前保存该信息。\n\n(g) 藐视法庭。要求履行传票义务所在地区的法院——以及在动议被移送后，发出传票的法院——可认定已被送达但无充分理由不遵守传票或与之相关命令的人构成藐视法庭。\n\n有关获取传票材料，见 Fed.R.Civ.P.45(a) 委员会说明（2013）\n\n……\n\n文件提交请求\nI. 指示\n\n1. 除非另有说明，下列文件请求（以下简称“请求”，每一项称为“一项请求”）必须分别且具体地作出回应。每项请求均应得到完整答复，除非基于诚信提出异议；在此情况下，应按如下规定详细说明您提出异议的理由。如异议仅涉及某项请求的一部分，或其中的某个词语、短语或条款，您仅须说明对该部分的异议，并回应请求的其余部分。\n\n2. 电子存储信息必须依照下列指示提交：\n\na. 图像。黑白图像必须为300 DPI Group IV 单页 TIFF 文件。彩色图像必须以 JPEG 格式提交。文件名不得包含嵌入空格或特殊字符（包括逗号）。文件夹名称不得包含嵌入空格或特殊字符（包括逗号）。所有 TIFF 图像文件必须具有唯一文件名，即 Bates 编号。每张图像的右下角必须标注连续的 Bates 编号。每个文件夹中的 TIFF 文件数量不得超过1000个。Excel 电子表格应具有以该文件 Bates 编号命名的占位图像。\n\nb. 图像加载文件\n\na. Concordance® 数据文件。数据文件（.DAT）包含将被加载至 Concordance® 数据库的全部字段信息。.DAT 文件的第一行必须为标明字段名称的标题行。.DAT 文件必须使用下列 Concordance® 默认分隔符：逗号 ASCII 字符（020）引号 þ ASCII 字符（254）。日期字段应采用如下格式提供：mm/dd/yyyy。日期和时间字段必须为两个独立字段。如文件包括已成像的电子邮件及附件，则必须包括附件字段，以保留电子邮件与其附件之间的父/子关系。必须包括 OCRPATH 字段，以提供已提交存储介质上提取文本文件的文件路径及名称。文本文件必须以 FIRSTBATES 命名。不得在 .DAT 文件中包括文本。对于含有原生文件的文件，必须包括 LINK 字段，以提供原生文件的文件路径及名称。原生文件必须以 FIRSTBATES 命名。\n\nb. Concordance Image® 或 Opticon 交叉引用文件。图像交叉引用文件（.LOG 或 .OPT）将图像链接至数据库记录。其应为逗号分隔文件，每行由七个字段组成；数据库中每张图像均应在交叉引用文件中有一行，格式如下：ImageID,VolumeLabel,ImageFilePath,DocumentBreak,FolderBreak,Box Break,PageCoun。\n\nc. 文件文本。文本必须作为单独的文本文件提交，而不得作为 .DAT 文件中的字段提交。文本文件的完整路径（OCRPATH）应包括在 .DAT 文件中。建议使用以 FIRSTBATES/Image Key 命名的文件级 ANSI 文本文件。提取的文本文件必须置于单独的文件夹中，每个文件夹中的文本文件数量不得超过1,000个。文件夹名称中不得有特殊字符（包括逗号）。文本文件必须按文件级别提供。\n\nd. 特定文件类型的原生格式提交。为充分理解其内容和含义而合理需要以原生格式查看的文件类型，必须以原生格式提交。这些文件包括但不限于电子表格、类电子表格文件（Microsoft Excel、逗号分隔值、制表符分隔值等）、Microsoft PowerPoint 或其他特殊演示文件、数据库文件以及音频/视频文件。提供一张标有 Bates 编号的分隔页图像，说明存在原生文件，并将原生文件路径作为字段纳入 .dat 文件。提交的原生文件应以与该文件分隔页相对应的 Bates 编号命名。原生文件应归入按递增方式命名的“NATIVE”目录，并与图像目录分开。\n\ne. 去重。对于存在完全重复件的每份电子文件，仅提交一份副本。对于电子邮件，应依据从 BCC、Body、CC、From、IntMsgID、To 和 Attach 属性生成的 MD5 哈希值合并重复件。对于电子邮件附件及独立电子文件，应依据整个文件的 MD5 哈希值合并重复件。\n\nf. 元数据。以符合 Concordance 要求的加载文件（.dat）形式，为每份文件提交提取的元数据。.DAT 文件的第一行必须为标明字段名称的标题行。.DAT 文件必须使用下列 Concordance 默认分隔符：逗号 , ASCII 字符（020）引号 þ ASCII 字符（254）\n\n日期字段应采用如下格式提供：mm/dd/yyyy。日期和时间字段必须为两个独立字段。下列为必需的元数据：\nCase 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 369 of 439\n\n字段名称　示例数据　说明\n\nFIRSTBATES　EDC0000001　原生文件文件/电子邮件的首个 Bates 编号\nLASTBATES　EDC0000001　原生文件文件/电子邮件的最后一个 Bates 编号\nLASTBATES 字段应针对单页文件填写\nATTACHRANGE　EDC0000001　父文件第一页的 Bates 编号\n-　至最后一个附件“子”文件最后一页的 Bates 编号\nEDC0000015　\nBEGATTACH　EDC0000001　附件范围的首个 Bates 编号\nENDATTACH　EDC0000015　附件范围的最后一个 Bates 编号\nCUSTODIAN　Smith, John　电子邮件：该电子邮件所在的邮箱\n原生文件：该文件源自其文件的个人或部门名称\nFROM　John Smith　电子邮件：发件人\n原生文件：文件作者\n多个条目之间应使用分号分隔\nTO　Coffman, Janice; LeeW　收件人\n[mailto:LeeW@MSN.com]　多个条目之间应使用分号分隔\nCC　Frank Thompson [mailto:　抄送收件人\nfrank_Thompson@cdt.com]　多个条目之间应使用分号分隔\nBCC　John Cain　密送收件人\n多个条目之间应使用分号分隔\nSUBJECT　Board Meeting Minutes　电子邮件：电子邮件的主题行 原生文件：文件标题（如有）\nFILE_NAME　BoardMeetingMinutes.docx　原生文件：原始原生文件的名称，包括扩展名\nDATE_SENT　10/12/2010　电子邮件：电子邮件发送日期\n原生文件：（空）\nTIME_SENT/　07:05 PM GMT　电子邮件：电子邮件发送时间/电子邮件标准化所用时区\nTIME_ZONE　\nTIME_ZONE　GMT　在转换期间电子邮件被标准化所用的时区。\nLINK　EDC0000001.msg　指向电子邮件或原生文件文件的超链接\n链接文件必须以 FIRSTBATES 编号命名\nFILE_EXTEN　MSG　代表电子邮件或原生文件的文件类型扩展名\nAUTHOR　John Smith　电子邮件：（空）\n原生文件：文件作者\nDATE_CREATED　10/10/2010　电子邮件：（空）\n原生文件：文件创建日期\nCase 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 370 of 439\n\nTIME_CREATED　10:25 AM　电子邮件：（空）\n\n原始：文件创建时间\n本数据必须为单独字段，且不得与 DATE_CREATED 字段合并\nDATE_MOD　10/12/2010　电子邮件：（空）\n原始：文件最后修改日期\nTIME_MOD　07:00 PM　电子邮件：（空）\n原始：文件最后修改时间\n本数据必须为单独字段，且不得与 DATE_MOD 字段合并\nDATE_ACCESSD　10/12/2010　电子邮件：（空）\n原始：文件最后访问日期\nTIME_ACCESSD　07:00 PM　电子邮件：（空）\n原始：文件最后访问时间\n本数据必须为单独字段，且不得与 DATE_ACCESSD 字段合并\nFILE_SIZE　5,952　原始文件文档/电子邮件的大小（以 KB 计）\nPGCOUNT　1　原始文件文档/电子邮件的页数\nPATH　电子邮件：（空）\nAgenda.doc　原始文件文档的存储路径，包括原始文件名。\nINTFILEPATH　Personal Folders\\Deleted Items\\Board Meeting Minutes.msg　电子邮件的原始位置，包括原始文件名。原始：（空）\nINTMSGID　<000805c2c71b\\$75977050\\$cb8306d1@MSN>　电子邮件：唯一消息 ID 原始：（空）\nMD5HASH　d131dd02c5e6eec4693d9a0698aff95c2fcab58712467eab4004583eb8fb7f89　文档的 MD5 哈希值。\nOCRPATH　TEXT/001/EDC0000001.txt　原始文件提取文本的路径\n\n3. 每项请求均独立运作并应独立解释，除非另有说明，任何请求均不限制任何其他请求的范围。\n\n4. 所有文件均应按其在通常业务过程中保存的方式提供，或应予以整理并标注，以对应本等请求中的类别。\n\n5. 本文所载每项请求均延及所有文件：(a) 由您占有、保管或控制的文件；或 (b) 由代表您行事的任何人占有、保管或控制的文件，\nCase 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 371 of 439\n\n包括您的律师或其他代表及顾问。每份文件均应完整提供。\n\n6. 如要求您提供的某份文件已不再由您占有、保管或控制，则您的答复必须：(a) 详细说明该文件的性质及其内容；(b) 确认编制或起草该文件的人士（以及，如适用，确认该文件被发送给的人士）；(c) 确认该文件编制或创建的日期；(d) 说明该文件是否：(i) 遗失或丢失，(ii) 已被销毁，(iii) 已自愿或非自愿转移给他人，或 (iv) 以其他方式被处置；(e) 说明该等处置的原因，以及围绕该等处置的事实和情形；(f) 确认授权该等处置的人士；(g) 确认该等处置的日期或大致日期；(h) 说明该文件最近一次由您占有、保管或控制的时间；以及 (i) 确认目前占有、保管或控制该文件的人士（如有）。\n\n7. 如要求您提供的某份文件已被销毁，则除前述指示所要求的信息外，您的答复还必须说明：(a) 销毁该文件的原因；(b) 销毁该文件的人士身份；以及 (c) 指示销毁该文件的人士身份。\n\n8. 如您主张所要求的文件享有特权或属于律师工作成果，则您的答复必须：(a) 说明：(i) 足以支持您关于该文件享有特权之主张的文件描述，(ii) 文件标题，(iii) 文件日期，(iv) 文件作者，(v) 文件收件人，(vi) 收到或阅览该文件原件或任何草稿、副本或复制件的每一人士身份，(vii) 该文件本身或该文件所载或提及的任何信息是否由任何其他人士占有、保管或控制，如是，则确认该等人士身份，\nCase 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 372 of 439\n\n以及说明该等信息如何由其占有，(viii) 据以扣留该文件的特权主张，及 (ix) 您将据以支持该等特权主张的所有情形；以及 (b) 按照 D. Conn. L. Civ. R. 26(e)，就每份基于特权主张而被扣留的文件，提供一份特权日志，其中包含本指示第 (a) 部分所要求的全部信息。对于文件请求中未提出特权或工作成果主张的任何部分，应完整提供回应性文件。\n\n9. 如原本具有回应性的文件的一部分含有受特权主张约束的信息，则在遵循上述指示后，仅应从该文件中删除或遮蔽受特权主张约束的部分，其余部分应予提供。\n\n10. 本等请求具有持续性。现指示您：(a) 一旦知悉先前答复不完整或不正确，立即补充或更正其后发现不完整或不正确的任何答复；以及 (b) 提供根据该等请求所要求的任何额外文件\n\n11. 如某份文件使用英语以外的语言，您应提供该文件。如某份文件使用英语以外的语言，且存在英文译本，您应同时提供两份文件。\n\n12. 对实体的所有提及均包括其所有关联方。\n\n13. 对个人姓名的所有提及均包括所有替代姓名、别名或昵称。\n\n14. 除非另有明确说明，文件请求所涵盖的期间为自 February 5, 2012 起至应答复文件请求之日止。\n\nII. 解释规则\n\n15. (a) 任何单数名词的使用均应解释为包括复数，反之亦然；以及 (b) 任何时态动词的使用均应解释为在所有其他时态中使用该动词。\n\n16. (a) 术语“and”和“or”应视需要解释为连词或析取词，以使所有原本可能被解释为不在任何请求范围内的答复纳入该请求的范围；以及 (b) “each”和“any”应视为包括并涵盖“every”和“all”二词。\n\nIII. 定义\n\nD. Conn. L. Civ. R. 26(c) 所提供的定义及 D. Conn. L. Civ. R. 26(d) 所提供的解释规则，经 D. Conn. Bankr. L.R. 2004-1(a) 纳入后，适用于文件请求。此外，本等文件请求中使用的下列术语具有下列含义：\n\n1. “您”或“您的”或“您本人”系指 H.R. Owen PLC，以及其所有关联方、部门、机构、办事机构、职能部门、办公室、合伙人、高级职员、董事、代理人、律师、代表、雇员和/或代表其行事的任何人。\n\n2. “债务人”系指 Ho Wan Kwok（郭文贵）（又名 Miles Kwok、Miles Guo、Guo Wengui、Guo Haoyun、郭文贵，或任何其他别名），以及其雇员、代理人、律师、顾问或代表其行事的任何人。\nCase 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 374 of 439\n\n3. “债务人之子”系指 Qiang Guo（郭强）（又名 Mileson Kwok、郭强，或任何其他别名），以及其雇员、代理人、律师、顾问或代表其行事的任何人。\n\n4. “债务人之女”系指 Mei Guo（郭美）（又名 Mei Gui、郭美，或任何其他别名），以及其雇员、代理人、律师、顾问或代表其行事的任何人。\n\n5. “债务人声称的妻子”系指 Hing Chi Ngok（岳庆芝）（又名 Hing Chi Ng、Yue Qingzhi、岳庆芝，或任何其他别名），以及其雇员、代理人、律师、顾问或代表其行事的任何人。\n\n6. “债务人家属”统称债务人、债务人之子、债务人之女及债务人声称的妻子，以及与债务人有任何其他家庭关系的人。\n\n7. “资产”系指受占有、保管或控制的任何具有经济价值的项目。资产包括所有不动产和动产，包括但不限于房地产、土地、房屋、公寓、共管公寓、汽车、游艇、船只、飞机、喷气式飞机、直升机、现金、银行账户、加密货币、证券、应收账款、存货及其他有形和无形财产。\n\n8. “关联个人”单独及统称所有符合下列条件的个人：(1) 持有、控制、保管或对债务人或债务人家属拥有、控制或享有的资产具有处置权；或 (2) 曾为一个或多个关联实体的雇员、董事，或以其他方式与其有关联，并包括前述各方各自的雇员、代理人、律师、顾问或代表前述任何一方行事的任何人。该等关联个人包括但不限于：Aaron Mitchell、Anthony DiBattista、Ana Izquierdo、Alex Hadjicharalambous、Bingshang Jiao、Beile Li、Brian W. Hofmeister、Charles Gruder、Daniel Podhaskie、David Fallon、Defeng Cao（又名 Wayne Cao、Max Cao）、Ding Lin、Dinggang Wang（又名 王定刚）、Eduardo Eurnekian、Ehsan Masud、Fiona Yu、Gladys Chow、Haitham Khaled、Hao\nCase 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 375 of 439\n\n(Gavin) Li（又名 Huo Lai）、Hao Haidong（又名 郝海东）、Han Chunguang（又名 韩春光）、Haoran He、Ivan Lin、Haitham Khaled、Jason Miller、Jennifer Mercurio、Jesse Brown、Jessica Mastrogiovanni、Jie Zhang、Jintao Li、Karin Maistrello、Kyle Bass、Leanne Li、Lihong Wei Lafrenz（又名 Sara Wei、魏丽红）、Limarie Reyes Molinaris、Linwan “Irene” Feng、Max Krasner、Melissa Francis、Michael Baranowitz、Min Yang、Melissa Mendez、Nadeem Akbar、Nan Li（又名 Chris Lee、Mei Guo Xiao Li）、Qidong Xia、Qu Guojiao（又名 Qu Guo Jiao、屈国姣）、Ridwan Mamode Saib、Ross Heinemeyer、Rui “Ray” Hao、Scott Barnett、Shih Hsin Yu、Shin Hee-Seup（又名 Hee Seup Shin）、Steve Bannon、Talha Zobair、Victor Cerda、Wen Xiao、Wencong Wang、William Gertz、William Je（又名 Je Kin Ming、Yu Jianming、余建明）、Xuebing Wang、Ya Li（又名 李娅）、Yinying (Aila) Wang（又名 Xiao Fei Xiang）、Yongping Yan（Shan Mu）、Yong Yu、Yue Zhou、Yumei Hao（又名 Ru Shui）、Yvette Wang（又名 Yanping Wang、Yan Ping Wang、王雁平）、Zhang Wei（又名 张魏）、Zhouer Wang（又名 Joe Wang）、Zhixuan Li 及 Ziyang Liu。\n\n9. “关联实体”单独及统称所有符合下列条件的各种类型组织或实体：(1) 曾由债务人或债务人家属拥有、控制或投资；或 (2) 对债务人或债务人家属拥有、控制或享有的任何资产直接或间接享有权益，并包括前述各方各自的雇员、代理人、律师、顾问或代表前述任何一方行事的任何人。该等关联实体包括但不限于：1332156 B.C. Ltd.、7 Nod Hill LLC、AAGV Limited、ACA Investment Management Limited、ACA Capital Group Limited、Ace Decade Holdings Limited、AI Group Holdings Inc.、Alfa Global Ventures Limited、Alfonso Global Limited、Allied Capital Global Limited、Alpine Fiduciaries SA、Anton Development Limited、Beijing Pangu Investment Co.、Beijing Pangu Investment Co. Ltd.、Beijing Pangu Investment Inc.、\nCase 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 376 of 439\n\n北京泽尼特控股有限公司（Beijing Zenith Holdings Company Limited）、蓝色资本有限公司（Blue Capital Limited）、繁荣帆船纽约有限责任公司（Booming Sail New York LLC）、好运有限公司（Bravo Luck Limited）、布伦特石油（Brent Petro）、BSA战略基金I（BSA Strategic Fund I）、中国金泉（香港）有限公司（China Golden Spring (Hong Kong) Limited）、创新有限公司（Chuang Xin Limited）、鹤顾问集团有限责任公司（Crane Advisory Group LLC）、创意顶点投资有限公司（Creative Apex Investments Limited）、水晶微风投资有限公司（Crystal Breeze Investments Limited）、黎明州有限公司（Dawn State Limited）、东方利润有限公司（Eastern Profit Corporation Limited）、帝国增长控股公司（Empire Growth Holdings）、精英全球有限公司（Elite Well Global Limited）、自由媒体创投有限公司（Freedom Media Ventures Ltd.）、冯万贸易公司（Fung Wan Trading Inc.）、G俱乐部（G Club）、G俱乐部运营有限责任公司（G Club Operations LLC）、G俱乐部国际有限公司（G Club International Limited）、G俱乐部投资有限公司（G Club Investments Limited）、G时尚有限责任公司（G Fashion LLC）、G新闻运营有限责任公司（G-News Operations LLC）、G新闻有限责任公司（G News LLC）、G音乐公司（GMusic Inc.）、G音乐有限责任公司（G Music LLC）、G服务有限责任公司（G-Services LLC）、G翻译服务有限公司（G-Translators PTY LTD）、GETTR美国公司（GETTR USA, Inc.）、Genever控股公司（Genever Holdings Corporation）、Genever控股有限责任公司（Genever Holdings LLC）、G时尚（G Fashion）、GFashion媒体集团公司（GFashion Media Group Inc.）、GF意大利有限责任公司（GF Italy, LLC）、GFNY公司（GFNY, Inc.）、全球主义者国际有限公司（Globalist International Limited）、GNews媒体集团公司（GNews Media Group Inc.）、金泉（纽约）有限公司（Golden Spring (New York) Ltd.）、格林尼治土地有限责任公司（Greenwich Land, LLC）、郭媒体（Guo Media）、GTV媒体集团公司（GTV Media Group, Inc.）、GWGOPNZ有限公司（GWGOPNZ Limited）、GWGNZ有限公司（GWGNZ Limited）、吉普赛梅食品服务有限责任公司（Gypsy Mei Food Services, LLC）、HCHK物业管理公司（HCHK Property Management Inc.）、HCHK技术公司（HCHK Technologies Inc.）、汉密尔顿数字资产FD SP（Hamilton Digital Assets FD SP）、汉密尔顿资本控股公司（Hamilton Capital Holdings Inc.）、汉密尔顿机会基金SPC（Hamilton Opportunity Fund SPC）、海德温集团有限公司（Head Win Group Limited）、喜马拉雅大使馆（Himalaya Embassy）、喜马拉雅交易所（Himalaya Exchange）、喜马拉雅联邦储备（Himalaya Federal Reserve）、喜马拉雅国际清算有限公司（Himalaya International Clearing Limited）、喜马拉雅国际金融集团有限公司（Himalaya International Financial Group Ltd.）、喜马拉雅投资有限责任公司（Himalaya Investment LLC）、喜马拉雅（美国）投资管理有限责任公司（Himalaya (USA) Investment Management LLC）、喜马拉雅新世界公司（Himalaya New World Inc.）、喜马拉雅监管组织（Himalaya Supervisory Organization）、喜马拉雅创投（Himalaya Ventures）、圣城香港创投有限公司（Holy City Hong Kong Ventures, Ltd.）、哈德逊钻石控股有限责任公司（Hudson Diamond Holding LLC）、哈德逊钻石控股公司（Hudson Diamond Holding Inc.）、哈德逊钻石纽约有限责任公司（Hudson Diamond NY LLC）、香港国际基金投资（美国）有限责任公司（HK International Funds Investments (USA) Limited LLC）、香港国际基金投资有限公司（Hong Kong International Funds Investments Limited）、Huk贸易公司（Huk Trading Inc）、无限增长有限公司（Infinite Increase Limited）、无限发展有限公司（Infinitum Developments Limited）、日本喜马拉雅联盟公司（Japan Himalaya League, Inc.）、卡利森贸易有限公司（Kalixun Trading Limited）、K传承有限公司（K Legacy Ltd.）、灯资本有限责任公司（Lamp Capital LLC）、领先光辉有限公司（Leading Shine Limited）、领先光辉纽约有限公司（Leading Shine NY Limited）、列克星敦物业与人事服务公司（Lexington Property and Staffing Inc.）、长门有限公司（Long Gate Limited）、MOS喜马拉雅基金会公司（MOS Himalaya Foundation Inc.）、五月风贸易有限责任公司（Maywind Trading LLC）、中国新联邦（New Federal State of China，亦称 NFSC）、Newpeople有限责任公司（Newpeople LLC）、新桑树私人有限公司（New Mulberry PTE Ltd.）、纽约MOS喜马拉雅有限责任公司（New York MOS Himalaya LLC）、新大亨投资有限公司（Next Tycoon Investments Limited）、高贵名望全球有限公司（Noble Fame Global Limited）、O.S.C.轨道服务公司有限责任公司（O.S.C. Orbit Service Company LLC）、Pixshow电影公司（Pixshow Film Inc.）、旭日资本有限公司（Rising Sun Capital Ltd.）、Roscalitar 2、玫瑰顶点创投有限公司（Rosy Acme Ventures Limited）、法治基金会III公司（Rule of Law Foundation III, Inc.）、法治协会（Rule of Law Society）、法治协会IV公司（Rule of Law Society IV, Inc.）、Santel有限责任公司（Santel LLC）、Saraca媒体集团公司（Saraca Media Group, Inc.）、闪亮王牌有限公司（Shiny Ace Ltd.）、闪亮时代控股有限公司（Shiny Times Holdings Ltd.）、史蒂文森、黄律师事务所（Stevenson, Wong & Co.）、金牛基金有限责任公司（Taurus Fund LLC）、金牛基金SP（Taurus Fund SP）、金牛管理有限责任公司（Taurus Management LLC）、遗失草稿有限责任公司（The Lost Draft LLC）、TM报春花有限公司（TM Primrose Limited）、UA喜马拉雅公司（UA Himalaya Inc.）、郭媒体之声公司（Voice of Guo Media, Inc.）、良好来源有限公司（Well Origin Ltd.）、明智创作国际有限公司（Wise Creation International Limited）、怀特克罗夫特海岸有限公司（Whitecroft Shore Limited）、世界世纪有限公司（World Century Limited）、全球机会控股有限公司（Worldwide Opportunity Holdings Limited）及ZIBA有限公司（ZIBA Limited）。\n\n案件 22-50073 文书 3193 于 05/16/24 提交 于 05/16/24 10:28:21 登记 第 377 页，共 439 页\n\n10. “和”及“或”系指“和/或”，并应同时作连词性及选择性解释，以最大限度扩大其范围。\n\n11. “任何”及“所有”以及“每一”均系指“每一及全部”。\n\n12. “通信”系指以最广泛的可能含义且不受限制地传递任何信息或知识（以事实、观点、询问或其他形式）。通信还指所有会谈、协议、询问或答复，无论是当面、通过电话、以书面形式，或通过电子传输设备进行，并包括但不限于所有函件、电子邮件、录音、传送单、备忘录、电话通信、语音留言、电报、电传传真、复印传真、电传、即时消息、聊天、短信、在留言板或群聊中的帖子、社交媒体帖子、推文、上传至任何视频平台的视频、电话记录，或在内部或与第三方之间传送的记录。\n\n13. “每一”及“每个”均系指“每一及全部”。\n\n案件 22-50073 文书 3193 于 05/16/24 提交 于 05/16/24 10:28:21 登记 第 378 页，共 439 页\n\n14. “文件”系指属于 Fed. R. Civ. P. 34 范围内的任何信息或物品，并包括但不限于现由或曾由您占有、保管或控制的任何种类、类型、性质或描述的每一及全部书面、录制或图形资料，包括电子邮件的所有印刷及电子副本、以电子形式保存的计算机文件、函件、备忘录、磁带、速记或手写笔记、任何种类的书面表格、图表、蓝图、绘图、草图、图形、计划、文章、规格说明、日记、信函、电报、照片、会议记录、合同、协议、调查、计算机打印件、任何种类的数据汇编、电传、传真、电子邮件、短信、即时消息、语音留言、发票、订购表、支票、汇票、对账单、贷项通知单、报告、持仓报告、摘要、索引、书籍、分类账、笔记本、日程表、透明片、录音、目录、广告、宣传材料、胶片、录像带、录音带、CD、计算机磁盘、宣传册、小册子、穿孔卡、工时单、推文、社交媒体帖子，或任何其他种类的书面或录制材料，以及其全部元数据，无论以何种方式储存、记录、制作或复制（无论为有形形式或电子形式），还包括但不限于前述任何文件的草稿或副本，其中含有原始文件未载有的任何种类的笔记、评论或标记，或在其他方面与原始文件不相同者。\n\n14. “G俱乐部实体”统称G俱乐部运营有限责任公司（G Club Operations LLC）、G Club HoldCo I LLC（G Club HoldCo I LLC）、G Club International Ltd.（G Club International Ltd.）、G-Club Investments Limited（G-Club Investments Limited）、G Club International Ltd (BVI)（G Club International Ltd (BVI)）、G Club One（G Club One）、G Club Two（G Club Two）、G Club Three（G Club Three）、G Club US Operations Inc.（G Club US Operations Inc.）及G Club US Operations LLC（G Club US Operations LLC），连同其所有关联方、部门、机构、工具机构、科室、办事处、高级管理人员、董事、代理人、经理、律师、代表、雇员、专业人士，和/或代表其或为其行事的任何人。\n\n案件 22-50073 文书 3193 于 05/16/24 提交 于 05/16/24 10:28:21 登记 第 379 页，共 439 页\n\n15. “包括”或其任何变体系指“包括但不限于”。\n\n16. “人员”系指个人、公司、独资企业、合伙企业、协会或任何其他实体。“人员”还包括任何代理人、代表或专家，包括但不限于律师或财务顾问。\n\n17. “实体”系指任何自然人、公司、合伙企业、子公司、独资企业、商号、董事会、合资企业、协会、机构、主管机关、委员会或其他商业实体或法人，以及任何关联方、代理人、母公司，包括但不限于法律顾问、财务顾问或任何其他代表。\n\n18. “关于”系指涉及、描述、包含、提及、与之相关、支持、有利于、反对、加强、贬损、位于其中、结合其予以考虑、对其有影响、证明、表明、报告、记录、暗示、答复、与之连接、评论、就其而言、有关、与之相关、讨论、显示、描述、反映、分析、构成及属于。\n\n19. 当“与……有关”、“涉及”或“相关”用于指代任何既定事项时，系指但不限于构成、包含、涉及、载有、体现、反映、识别、陈述、直接或间接提及，或以任何方式与所识别的特定事项相关的任何文件。\n\n20. “第三方”系指除您本人以外的人员或实体。\n\n21. “转让”应具有《破产法》第 101(54) 条赋予该词的含义。\n\n22. “车辆”系指任何用于出行的车辆，包括但不限于在任何时候由债务人、债务人的家庭成员、关联个人或任何关联实体拥有、使用、控制、购买、出售、租赁、出租、许可、维修保养、维护、修理、大修、储存、运营、营销或检查的，向其提供的，或为其利益而提供的汽车及机动车辆。\n\n案件 22-50073 文书 3193 于 05/16/24 提交 于 05/16/24 10:28:21 登记 第 380 页，共 439 页\n\n或由债务人、债务人的家庭成员、关联个人或任何关联实体为其利益而检查的车辆。\n\nIV. 应提交的文件\n\n1. 与G Club International Limited或G Club Operations LLC向您作出的任何转让有关的全部文件及通信，包括但不限于在 2021 年 9 月 13 日前后作出的 $832,000.75 转让。\n\n2. 与债务人、债务人财产、债务人的家庭成员、关联个人或关联实体的任何收入或资产有关的全部文件，包括但不限于G俱乐部实体。\n\n3. 与您和债务人、债务人财产、债务人的家庭成员、关联个人或关联实体之间的任何通信有关的全部文件，包括但不限于G俱乐部实体。\n\n4. 与债务人、债务人财产、债务人的家庭成员、关联实体或关联个人（包括但不限于G俱乐部实体）有关，且涉及任何车辆的全部文件，包括但不限于：(i) 任何车辆的所有权或控制权；(ii) 任何车辆的使用；(iii) 任何车辆的租赁或出租；(iv) 任何车辆的购买、出售或营销；(v) 就任何车辆支付或给予的任何款项或价值及其来源；(vi) 就任何车辆产生或取得的任何款项或价值及其处置；或 (vii) 与任何车辆有关的运营、维护、保养或大修。\n\n5. 与任何账户有关的全部文件，该账户与债务人、债务人财产、债务人的家庭成员、关联实体（包括但不限于G俱乐部实体）或关联个人有关联。\n\n案件 22-50073 文书 3193 于 05/16/24 提交 于 05/16/24 10:28:21 登记 第 381 页，共 439 页\n\n6. 与债务人、债务人财产、债务人的家庭成员、关联实体（包括但不限于G俱乐部实体）或关联个人有关的任何发票或费用支付有关的全部文件。\n\n7. 与债务人、债务人财产、债务人的家庭成员、关联实体（包括但不限于G俱乐部实体）或关联个人有关的任何车辆当前所在地有关的全部文件。\n\n案件 22-50073 文书 3193 于 05/16/24 提交 于 05/16/24 10:28:21 登记 第 382 页，共 439 页\n\n附件 C-20\n\nB2540（表格 2540 – Rule 2004 审查传票）（12/15）案件 22-50073 文书 3193 于 05/16/24 提交 于 05/16/24 10:28:21 登记 第 383 页，共 439 页\n\n美国破产法院（UNITED STATES BANKRUPTCY COURT）\n\n康涅狄格地区（District of Connecticut）\n\n关于 HO WAN KWOK（郭文贵）等人，\n\n1 案件编号 22-50073 (JAM)\n\n债务人 第 11 章\n\n（合并管理）\nRule 2004 审查传票\n\n致：Headwater Service, LLC（Headwater Service, LLC）\n\n（传票所指向人员的姓名）\n\n证言：兹命令您于下列载明的时间、日期和地点出席，并在依据《联邦破产程序规则》Rule 2004 进行的审查中作证。随附准许该审查的法院命令副本。\n\n地点　日期和时间\n\n不适用　不适用\n\n审查将以以下方式记录：不适用\n\n提交：您或您的代表还必须在审查时携带下列文件、以电子方式存储的信息或物品，并必须允许对该等材料进行查验、复制、测试或抽样：\n见随附的文件提交请求。\n\n以下 Fed. R. Civ. P. 45 条款经 Fed. R. Bankr. P. 9016 适用于破产案件，现随附于此——与履行地点有关的 Rule 45(c)；与作为传票对象的您所享有保护有关的 Rule 45(d)；以及与您对本传票作出答复的义务及未作答复的潜在后果有关的 Rule 45(e) 和 45(g)。\n\n日期：May , 2024\n\n法院书记员\n\n或\n\n书记员或副书记员签字 律师签字\n\n代表签发或请求发出本传票的第11章受托人 Luc A. Despins（卢克·A·德斯平斯）的律师姓名、地址、电子邮件地址和电话号码如下：\n\nPatrick R. Linsey, Esq.（帕特里克·R·林赛，律师）；Neubert, Pepe & Monteith, P.C.（纽伯特、佩佩及蒙泰思律师事务所）；195 Church Street, 13th Floor, New Haven, Connecticut 06510；plinsey@npmlaw.com；(203) 781-2847\n\n致签发或请求发出本传票之人的通知\n\n如本传票命令在审判前提交文件、电子存储信息或有形物品，或检查场所，则必须在向受送达人送达本传票之前，向各方当事人送达通知及本传票副本。Fed. R. Civ. P. 45(a)(4)。\n\n软件版权 (c) 1996-2022 Best Case, LLC（百思凯斯有限责任公司）- www.bestcase.com Best Case Bankruptcy 1 本第11章案件中的债务人为 Ho Wan Kwok（郭文贵，亦称 Guo Wengui、Miles Guo 和 Miles Kwok，以及众多其他别名）（税务识别号码后四位：9595）、Genever Holdings LLC（吉尼弗控股有限责任公司）（税务识别号码后四位：8202）及 Genever Holdings Corporation（吉尼弗控股公司）。受托人、Genever Holdings LLC 及 Genever Holdings Corporation 的邮寄地址为 Paul Hastings LLP（保罗·黑斯廷斯律师事务所），200 Park Avenue, New York, NY 10166，转交 Luc A. Despins，作为 Ho Wan Kwok 遗产的受托人（仅为通知和通信之目的）。\n\n送达证明\n\n（除非 Fed. R. Civ. P. 45 要求，否则本节不应向法院提交。）\n\n本人于（日期）收到向（个人姓名及职务，如有）发出的本传票。\n\n本人按如下方式将副本交付给所列人员，从而送达本传票：\n\n于（日期）；或\n\n本人未执行即退回本传票，原因如下：\n\n除非本传票系代表美国或其官员或代理人发出，本人亦已向证人支付一天出席费用及法律允许的里程费，金额为 $。\n\n本人的差旅费用为 $，服务费用为 $，合计为 $。\n\n本人在伪证处罚的约束下声明，该等信息真实且正确。\n\n日期：\n\n送达人签名\n\n打印姓名及职务\n\n送达人地址\n\n关于尝试送达等事项的补充信息：\n\n联邦民事诉讼规则第45(c)、(d)、(e)及(g)条（自12/1/13起生效）（经《联邦破产程序规则》第9016条适用于破产案件）\n\n(c) 履行地点。\n\n(1) 审判、听证或证言录取。传票仅可按下列方式命令某人出席审判、听证或证言录取：\n\n(A) 在该人居住、受雇或经常亲自办理业务地点100英里以内；或\n\n(B) 在该人居住、受雇或经常亲自办理业务所在州内，如该人\n\n(i) 为当事人或当事人的高级职员；或\n\n(ii) 被命令出席审判且不会产生重大费用。\n\n(2) 其他证据开示。传票可命令：\n\n(A) 在该人居住、受雇或经常亲自办理业务地点100英里以内的地点提交文件、电子存储信息或物品；以及\n\n(B) 在待检查的场所检查场所。\n\n(d) 保护受传票约束之人；执行。\n\n(1) 避免不当负担或费用；制裁。负责签发和送达传票的当事人或律师必须采取合理措施，避免对受传票约束之人施加不当负担或费用。要求履行义务所在地区的法院必须执行该义务，并对未遵守者的当事人或律师施加适当制裁，其中可包括损失的收入和合理的律师费。\n\n(2) 命令提交材料或准许检查。\n\n(A) 无需出席。被命令提交文件、电子存储信息或有形物品，或准许检查场所之人，无需亲自出席提交或检查地点，除非同时被命令出席证言录取、听证或审判。\n\n(B) 异议。被命令提交文件或有形物品，或准许检查之人，可向传票中指定的当事人或律师送达书面异议，反对检查、复制、测试或抽样任何或全部材料，或反对检查场所，或反对以所要求的一种或多种形式提交电子存储信息。异议必须在规定履行时间或传票送达后14天这两个时间中较早者之前送达。如提出异议，适用下列规则：\n\n(i) 经通知被命令之人后，送达方可随时向要求履行义务所在地区的法院提出动议，请求作出强制提交或检查的命令。\n\n(ii) 仅可依照该命令的指示要求实施这些行为，且该命令必须保护既非当事人亦非当事人高级职员之人，免于因履行而产生的重大费用。\n\n(3) 撤销或修改传票。\n\n(A) 必须撤销或修改的情形。经及时提出动议，要求履行义务所在地区的法院必须撤销或修改具有下列情形的传票：\n\n(i) 未留出合理履行时间；\n\n(ii) 要求某人在第45(c)条规定的地域限制以外履行；\n\n(iii) 要求披露享有特权或受其他保护的事项，且不适用例外或豁免；或\n\n(iv) 对某人施加不当负担。\n\n(B) 可撤销或修改的情形。为保护受传票约束或受其影响之人，要求履行义务所在地区的法院可经动议撤销或修改要求下列事项的传票：\n\n(i) 披露商业秘密或其他保密的研究、开发或商业信息；或\n\n(ii) 披露未经聘用的专家的意见或信息，该等意见或信息并非描述争议中的特定事件，且源自当事人未请求的该专家研究。\n\n(C) 以规定条件作为替代方案。在第45(d)(3)(B)条所述情形下，如送达方：\n\n(i) 证明其对证言或材料具有重大需求，且若不承受不当困难便无法通过其他方式满足该需求；并且\n\n(ii) 确保被传唤之人将获得合理报酬，\n\n法院可不撤销或修改传票，而命令在规定条件下出席或提交。\n\n(e) 回应传票的义务。\n\n(1) 提交文件或电子存储信息。下列程序适用于提交文件或电子存储信息：\n\n(A) 文件。响应提交文件传票之人必须按该等文件在日常业务过程中保存的方式提交，或必须对其进行整理和标记，使之对应于请求中的类别。\n\n(B) 未规定电子存储信息的提交形式。如传票未规定提交电子存储信息的形式，响应之人必须以其通常保存的一种或多种形式，或以合理可用的一种或多种形式提交。\n\n(C) 电子存储信息仅以一种形式提交。响应之人无需以多于一种的形式提交相同的电子存储信息。\n\n(D) 无法访问的电子存储信息。响应之人无需从其认定为因不当负担或费用而无法合理访问的来源提供电子存储信息的证据开示。对于强制证据开示动议或保护令动议，响应之人必须证明该信息因不当负担或费用而无法合理访问。如作出该证明，法院在考虑第26(b)(2)(C)条的限制后，如请求方证明有正当理由，仍可命令从该等来源进行证据开示。法院可规定该证据开示的条件。\n\n(2) 主张特权或保护。\n\n(A) 扣留的信息。以该信息享有特权或作为审判准备材料受保护为由扣留被传唤信息之人必须：(i) 明确提出该主张；以及\n\n(ii) 以一种在不披露本身享有特权或受保护信息的情况下，能使各方当事人评估该主张的方式，说明所扣留文件、通信或有形物品的性质。\n\n(B) 已提交的信息。如为响应传票而提交的信息属于特权主张或作为审判准备材料受保护的主张范围内，提出该主张之人可通知收到该信息的任何当事人该主张及其依据。收到通知后，当事人必须立即返还、隔离或销毁所指定的信息及其持有的任何副本；在该主张解决前不得使用或披露该信息；如该当事人在收到通知前已披露该信息，必须采取合理措施追回该信息；并可立即将该信息密封提交给要求履行义务所在地区的法院，以裁定该主张。提交该信息之人必须保存该信息，直至该主张得到解决。\n\n(g) 藐视法庭。要求履行义务所在地区的法院——以及在动议移送后，签发法院——可认定已被送达但无充分理由不遵守传票或相关命令之人构成藐视法庭。\n\n关于获取传票材料，见 Fed.R.Civ.P.45(a) Committee Note (2013)\n\n……\n\n文件提交请求\n\nI. 指示\n\n1. 除非另有说明，下列文件请求（以下简称“请求”，每一项称为“一项请求”）必须分别且具体地作出答复。除非善意提出异议，否则应完整答复每项请求；如提出异议，则应按照下文规定详细说明贵方异议的理由。如异议仅涉及某项请求的一部分，或其中包含的一个词语、短语或条款，贵方须仅对该部分说明异议，并答复其余请求。\n\n2. 电子存储信息必须依照下列指示提交：\n\n- a. 图像。黑白图像必须为300 DPI Group IV 单页 TIFF 文件。彩色图像必须以 JPEG 格式提交。文件名不得含有嵌入空格或特殊字符（包括逗号）。文件夹名称不得含有嵌入空格或特殊字符（包括逗号）。所有 TIFF 图像文件必须具有唯一文件名，即 Bates 编号。每幅图像右下角必须标注连续的 Bates 编号。每个文件夹中的 TIFF 文件数量不应超过1000个文件。Excel 电子表格应具有以该文件的 Bates 编号命名的占位图像。\n- b. 图像加载文件\n\t- a. Concordance® 数据文件。数据文件（.DAT）包含将加载至 Concordance® 数据库的全部字段信息。.DAT 文件的第一行必须为标明字段名称的标题行。.DAT 文件必须使用以下 Concordance® 默认分隔符：逗号 ASCII 字符（020）引号 þ ASCII 字符（254）。日期字段应以如下格式提供：mm/dd/yyyy。日期和时间字段必须为两个独立字段。如文件包括已成像的电子邮件及附件，则必须包括附件字段，以保留电子邮件与其附件之间的父/子关系。必须包括 OCRPATH 字段，以提供已提交存储介质上提取文本文件的文件路径和名称。文本文件必须以 FIRSTBATES 命名。不得在 .DAT 文件中包括文本。对于含有原生文件的文件，必须包括 LINK 字段，以提供原生文件的文件路径和\n\n名称。原生文件必须以 FIRSTBATES 命名。\n\n- b. Concordance Image® 或 Opticon 交叉引用文件。图像交叉引用文件（.LOG 或 .OPT）将图像链接至数据库记录。该文件应为逗号分隔文件，每行包含七个字段，且数据库中的每个图像均应在交叉引用文件中对应一行，格式如下：ImageID,VolumeLabel,ImageFilePath,DocumentBreak,FolderBreak,Box Break,PageCoun。\n\n- c. 文档文本。文本必须作为单独的文本文件提供，不得作为 .DAT 文件内的字段提供。文本文件的完整路径（OCRPATH）应包含在 .DAT 文件中。建议提供以 FIRSTBATES/Image Key 命名的文档级 ANSI 文本文件。提取的文本文件必须存放于单独文件夹内，每个文件夹中的文本文件数量不得超过 1,000 个。文件夹名称中不得含有特殊字符（包括逗号）。文本文件必须按文档级别提供。\n\n- d. 某些文件类型的原生格式提供。为充分理解其内容和含义而合理需要以原生格式查看的文件类型，必须以原生格式提供。这些文件包括但不限于：电子表格、类电子表格文件（Microsoft Excel、逗号分隔值、制表符分隔值等）、Microsoft PowerPoint 或其他特殊演示文件、数据库文件，以及音频/视频文件。应提供一张带有 Bates 编号的分隔页图像，标明存在原生文件，并将该原生文件的路径作为 .dat 文件中的一个字段列出。所提供的原生文件应以与该文件分隔页相对应的 Bates 编号命名。原生文件应归入按递增方式命名的“NATIVE”目录，并与图像目录分开。\n\n- e. 去重。对于存在完全重复件的每一电子文档，仅提供一份。对于电子邮件，依据由 BCC、Body、CC、From、IntMsgID、To 和 Attach 属性生成的 MD5 哈希值合并重复件。对于电子邮件附件和独立电子文件，依据整个文件的 MD5 哈希值合并重复件。\n\n- f. 元数据。应以符合 Concordance 标准的加载文件（.dat）形式，为每份文档提供提取的元数据。.DAT 文件的第一行必须为标明字段名称的标题行。.DAT 文件必须使用以下 Concordance 默认分隔符：逗号 , ASCII 字符（020）引号 þ ASCII 字符（254）\n\n日期字段应采用以下格式：mm/dd/yyyy。日期字段和时间字段必须为两个独立字段。下列为必需元数据：\n案号 22-50073 文件 3193 提交 05/16/24 录入 05/16/24 10:28:21 第 388 页，共 439 页\n\n字段名称　示例数据　说明\n\nFIRSTBATES　EDC0000001　原生文件文档/电子邮件的首个 Bates 编号\n\nLASTBATES　EDC0000001　原生文件文档/电子邮件的最后一个 Bates 编号\n**对于单页文件，应填写 LASTBATES 字段\n\nATTACHRANGE　EDC0000001 - EDC0000015　母文档第一页的 Bates 编号至最后一个附件“子”文档最后一页的 Bates 编号\n\nBEGATTACH　EDC0000001　附件范围的首个 Bates 编号\n\nENDATTACH　EDC0000015　附件范围的最后一个 Bates 编号\n\nCUSTODIAN　Smith, John　电子邮件：电子邮件所在的邮箱\n原生文件：文档源自其文件的个人或部门名称\n\nFROM　John Smith　电子邮件：发件人\n原生文件：文档作者\n**多个条目应以分号分隔\n\nTO　Coffman, Janice; LeeW [mailto:LeeW@MSN.com]　收件人\n**多个条目应以分号分隔\n\nCC　Frank Thompson [mailto:frank_Thompson@cdt.com]　抄送收件人\n**多个条目应以分号分隔\n\nBCC　John Cain　密送收件人\n**多个条目应以分号分隔\n\nSUBJECT　Board Meeting Minutes　电子邮件：电子邮件主题行\n原生文件：文档标题（如有）\n\nFILE_NAME　BoardMeetingMinutes.docx　原生文件：原始原生文件名称，包括扩展名\n\nDATE_SENT　10/12/2010　电子邮件：电子邮件发送日期\n原生文件：（空）\n\nTIME_SENT/TIME_ZONE　07:05 PM GMT　电子邮件：电子邮件发送时间/电子邮件标准化所采用的时区\n\nTIME_ZONE　GMT　在转换期间电子邮件被标准化所采用的时区。\n\nLINK　EDC0000001.msg　电子邮件或原生文件文档的超链接\n**链接文件必须按 FIRSTBATES 编号命名\n\nFILE_EXTEN　MSG　代表电子邮件或原生文件的文件类型扩展名\n\nAUTHOR　John Smith　电子邮件：（空）\n原生文件：文档作者\n\nDATE_CREATED　10/10/2010　电子邮件：（空）\n原生文件：文档创建日期\n案号 22-50073 文件 3193 提交 05/16/24 录入 05/16/24 10:28:21 第 389 页，共 439 页\n\nTIME_CREATED　10:25 AM　电子邮件：（空）\n原生文件：文档创建时间\n**该数据必须为独立字段，不得与 DATE_CREATED 字段合并\n\nDATE_MOD　10/12/2010　电子邮件：（空）\n原生文件：文档最后修改日期\n\nTIME_MOD　07:00 PM　电子邮件：（空）\n原生文件：文档最后修改时间\n**该数据必须为独立字段，不得与 DATE_MOD 字段合并\n\nDATE_ACCESSD　10/12/2010　电子邮件：（空）\n原生文件：文档最后访问日期\n\nTIME_ACCESSD　07:00 PM　电子邮件：（空）\n原生文件：文档最后访问时间\n**该数据必须为独立字段，不得与 DATE_ACCESSD 字段合并\n\nFILE_SIZE　5,952　原生文件文档/电子邮件的大小，以 KB 计\n\nPGCOUNT　1　原生文件文档/电子邮件的页数\n\nPATH　Email: (empty) Agenda.doc　原生文件：存储原生文件文档的路径，包括原始文件名称。\n\nINTFILEPATH　Personal Folders\\Deleted Items\\Board Meeting Minutes.msg　电子邮件：电子邮件的原始位置，包括原始文件名称。\n原生文件：（空）\n\nINTMSGID　<000805c2c71b\\$75977050\\$cb8306d1@MSN>　电子邮件：唯一消息 ID\n原生文件：（空）\n\nMD5HASH　d131dd02c5e6eec4693d9a0698aff95c2fcab58712467eab4004583eb8fb7f89　文档的 MD5 哈希值。\n\nOCRPATH　TEXT/001/EDC0000001.txt　原生文件提取文本的路径\n\n3. 各项请求独立运作并应独立解释；除非另有说明，任何一项请求均不限制任何其他请求的范围。\n\n4. 所有文件应按其在正常业务过程中保存的方式提供，或应予以组织和标注，以对应本请求中的类别。\n\n5. 本文所载各项请求延及所有文件：(a) 由您占有、保管或控制的文件；或 (b) 由任何代表您行事之人占有、保管或控制的文件，\n案号 22-50073 文件 3193 提交 05/16/24 录入 05/16/24 10:28:21 第 390 页，共 439 页\n\n包括您的律师或其他代表及顾问。每份文件均应完整提供。\n\n6. 如要求您提供一份已不再由您占有、保管或控制的文件，则您的答复必须：(a) 详细描述该文件的性质及其内容；(b) 确定编制或撰写该文件的人员（以及，如适用，该文件送交的人员）；(c) 确定该文件编制或创建的日期；(d) 说明该文件是否：(i) 遗失或丢失，(ii) 已被销毁，(iii) 已自愿或非自愿地转移给他人，或 (iv) 以其他方式被处置；(e) 说明该等处置的理由，以及围绕该等处置的事实和情况；(f) 确定授权该等处置的人员；(g) 确定该等处置的日期或大致日期；(h) 说明该文件最后一次由您占有、保管或控制的时间；以及 (i) 确定目前占有、保管或控制该文件的人员（如有）。\n\n7. 如要求您提供一份已被销毁的文件，则除前述指示所要求的信息外，您的答复还必须说明：(a) 该文件被销毁的理由；(b) 销毁该文件的人员身份；以及 (c) 指示销毁该文件的人员身份。\n\n8. 如您主张所要求的文件享有特权或属于律师工作成果，则您的答复必须：(a) 说明：(i) 足以支持您关于该文件享有特权之主张的文件描述，(ii) 文件标题，(iii) 文件日期，(iv) 文件作者，(v) 文件收件人，(vi) 收到或看到该文件原件或任何草稿、副本或复制件的每一人员身份，(vii) 该文件本身或该文件所含或提及的任何信息是否由任何其他人员占有、保管或控制；如是，则确定该等人员身份，并说明该等信息如何进入其占有范围，(viii) 据以扣留该文件的特权主张，以及 (ix) 您将据以支持该特权主张的所有情形；以及 (b) 根据 D. Conn. L. Civ. R. 26(e)，就基于特权主张而扣留的每份文件，提供一份特权日志，其中载有本指示第 (a) 部分所要求的全部信息。对于文件请求中未提出特权或工作成果主张的任何部分，应完整提供响应性文件。\n\n9. 如一份原本具有响应性的文件的一部分包含受特权主张约束的信息，则仅应依照上述指示从该文件中删除或遮蔽受该特权主张约束的部分，其余部分应予提供。\n\n10. 各项请求具有持续性。特此指示您：(a) 在得知先前答复不完整或不正确后，立即补充或更正其后得知不完整或不正确的任何答复；以及 (b) 提供根据各项请求所要求的任何额外文件。\n\n11. 如文件为非英语语言，您应提供该文件。如文件为非英语语言，且存在英文译本，您应同时提供两份文件。\n\n12. 对实体的所有提及均包括其所有关联方。\n\n13. 对个人姓名的所有提及均包括所有替代姓名、别名或昵称。\n\n14. 除非另有明确说明，文件请求所涵盖的期间为自 February 5, 2012 起至文件请求答复到期之日止。\nII. 解释规则\n\n15. (a) 对任何单数名词的使用，应解释为包括复数，反之亦然；以及 (b) 对任何时态动词的使用，应解释为包括该动词所有其他时态的使用。\n\n16. (a) “and”和“or”应根据需要解释为连词或选择连词，以将原本可能被解释为不在任何请求范围内的所有答复纳入该请求范围；以及 (b) “each”和“any”应视为包括并涵盖“every”和“all”。\nIII. 定义\n\n经 D. Conn. Bankr. L.R. 2004-1(a) 纳入的 D. Conn. L. Civ. R. 26(c) 所提供的定义及 D. Conn. L. Civ. R. 26(d) 所提供的解释规则，适用于文件请求。此外，本文件请求中使用的下列术语具有如下含义：\n\n1. “您”或“您的”或“您本人”系指 Headwater Service, LLC（Headwater Service 有限责任公司），以及其所有关联方、部门、机构、办事机构、职能部门、办公室、合伙人、高级职员、董事、代理人、律师、代表、雇员和/或任何代表其行事之人。\n案号 22-50073 文件 3193 提交 05/16/24 录入 05/16/24 10:28:21 第 393 页，共 439 页\n\n2. “债务人”系指 Ho Wan Kwok（郭文贵）（又名 Miles Kwok、Miles Guo、Guo Wengui、Guo Haoyun、郭文贵或任何其他别名），以及其雇员、代理人、律师、顾问或任何代表其行事之人。\n\n3. “债务人的儿子”是指 Qiang Guo（郭强，亦称 Mileson Kwok 或任何其他别名），以及其雇员、代理人、律师、顾问或任何代表其行事的人。\n\n4. “债务人的女儿”是指 Mei Guo（郭美，亦称 Mei Gui 或任何其他别名），以及其雇员、代理人、律师、顾问或任何代表其行事的人。\n\n5. “债务人的所谓妻子”是指 Hing Chi Ngok（岳庆芝，亦称 Hing Chi Ng、Yue Qingzhi 或任何其他别名），以及其雇员、代理人、律师、顾问或任何代表其行事的人。\n\n6. “债务人的家属”是指合称的债务人、债务人的儿子、债务人的女儿和债务人的所谓妻子，以及与债务人有任何其他亲属关系的人。\n\n7. “资产”是指处于占有、保管或控制之下的任何具有经济价值的物品。资产包括所有不动产和动产，包括但不限于房地产、土地、房屋、公寓、共管公寓、汽车、游艇、船舶、飞机、喷气式飞机、直升机、现金、银行账户、加密货币、证券、应收账款、存货以及其他有形和无形财产。\n\n8. “关联个人”是指单独或合称的所有下列个人：(1)持有、控制、保管债务人或债务人的家属拥有、控制或享有的资产，或对该等资产拥有自由裁量权；或(2)曾为一个或多个关联实体的雇员、董事，或以其他方式与一个或多个关联实体有关联，以及前述各方各自的雇员、代理人、律师、顾问或任何代表前述任何一方行事的人。该等关联个人包括但不限于：Aaron Mitchell、Anthony DiBattista、Ana Izquierdo、Alex Hadjicharalambous、Bingshang Jiao、Beile Li、Brian W. Hofmeister、Charles Gruder、Daniel Podhaskie、David Fallon、Defeng Cao（亦称 Wayne Cao、Max Cao）、Ding Lin、Dinggang Wang（亦称 王定刚）、Eduardo Eurnekian、Ehsan Masud、Fiona Yu、Gladys Chow、Haitham Khaled、Hao (Gavin) Li（亦称 Huo Lai）、Hao Haidong（亦称 郝海东）、Han Chunguang（亦称 韩春光）、Haoran He、Ivan Lin、Haitham Khaled、Jason Miller、Jennifer Mercurio、Jesse Brown、Jessica Mastrogiovanni、Jie Zhang、Jintao Li、Karin Maistrello、Kyle Bass、Leanne Li、Lihong Wei Lafrenz（亦称 Sara Wei、魏丽红）、Limarie Reyes Molinaris、Linwan “Irene” Feng、Max Krasner、Melissa Francis、Michael Baranowitz、Min Yang、Melissa Mendez、Nadeem Akbar、Nan Li（亦称 Chris Lee、Mei Guo Xiao Li）、Qidong Xia、Qu Guojiao（亦称 Qu Guo Jiao、屈国姣）、Ridwan Mamode Saib、Ross Heinemeyer、Rui “Ray” Hao、Scott Barnett、Shih Hsin Yu、Shin Hee-Seup（亦称 Hee Seup Shin）、Steve Bannon、Talha Zobair、Victor Cerda、Wen Xiao、Wencong Wang、William Gertz、William Je（亦称 Je Kin Ming、Yu Jianming、余建明）、Xuebing Wang、Ya Li（亦称 李娅）、Yinying (Aila) Wang（亦称 Xiao Fei Xiang）、Yongping Yan (Shan Mu)、Yong Yu、Yue Zhou、Yumei Hao（亦称 Ru Shui）、Yvette Wang（亦称 Yanping Wang、Yan Ping Wang、王雁平）、Zhang Wei（亦称 张魏）、Zhouer Wang（亦称 Joe Wang）、Zhixuan Li及Ziyang Liu。\n\n案件 22-50073 文件 3193 于 05/16/24 提交，于 05/16/24 10:28:21 登记，第 394 页，共 439 页\n\n9. “关联实体”是指单独或合称的所有任何类型的组织或实体：(1)曾由债务人或债务人的家属拥有、控制或投资；或(2)直接或间接地在债务人或债务人的家属拥有、控制或享有的任何资产中拥有权益，以及前述各方各自的雇员、代理人、律师、顾问或任何代表前述任何一方行事的人。该等关联实体包括但不限于：1332156 B.C. Ltd.、7 Nod Hill LLC、AAGV Limited、ACA Investment Management Limited、ACA Capital Group Limited、Ace Decade Holdings Limited、AI Group Holdings Inc.、Alfa Global Ventures Limited、Alfonso Global Limited、Allied Capital Global Limited、Alpine Fiduciaries SA、Anton Development Limited、Beijing Pangu Investment Co.、Beijing Pangu Investment Co. Ltd.、Beijing Pangu Investment Inc.、Beijing Zenith Holdings Company Limited、Blue Capital Limited、Booming Sail New York LLC、Bravo Luck Limited、Brent Petro、BSA Strategic Fund I、China Golden Spring (Hong Kong) Limited、Chuang Xin Limited、Crane Advisory Group LLC、Creative Apex Investments Limited、Crystal Breeze Investments Limited、Dawn State Limited、Eastern Profit Corporation Limited、Empire Growth Holdings、Elite Well Global Limited、Freedom Media Ventures Ltd.、Fung Wan Trading Inc.、G Club、G Club Operations LLC、G Club International Limited、G Club Investments Limited、G Fashion LLC、G-News Operations LLC、G News LLC、GMusic Inc.、G Music LLC、G-Services LLC、G-Translators PTY LTD、GETTR USA, Inc.、Genever Holdings Corporation、Genever Holdings LLC、G Fashion、GFashion Media Group Inc.、GF Italy, LLC、GFNY, Inc.、Globalist International Limited、GNews Media Group Inc.、Golden Spring (New York) Ltd.、Greenwich Land, LLC、Guo Media、GTV Media Group, Inc.、GWGOPNZ Limited、GWGNZ Limited、Gypsy Mei Food Services, LLC、HCHK Property Management Inc.、HCHK Technologies Inc.、Hamilton Digital Assets FD SP、Hamilton Capital Holdings Inc.、Hamilton Opportunity Fund SPC、Head Win Group Limited、Himalaya Embassy、Himalaya Exchange、Himalaya Federal Reserve、Himalaya International Clearing Limited、Himalaya International Financial Group Ltd.、Himalaya Investment LLC、Himalaya (USA) Investment Management LLC、Himalaya New World Inc.、Himalaya Supervisory Organization、Himalaya Ventures、Holy City Hong Kong Ventures, Ltd.、Hudson Diamond Holding LLC、Hudson Diamond Holding Inc.、Hudson Diamond NY LLC、HK International Funds Investments (USA) Limited LLC、Hong Kong International Funds Investments Limited、Huk Trading Inc、Infinite Increase Limited、Infinitum Developments Limited、Japan Himalaya League, Inc.、Kalixun Trading Limited、K Legacy Ltd.、Lamp Capital LLC、Leading Shine Limited、Leading Shine NY Limited、Lexington Property and Staffing Inc.、Long Gate Limited、MOS Himalaya Foundation Inc.、Maywind Trading LLC、New Federal State of China（亦称 NFSC）、Newpeople LLC、New Mulberry PTE Ltd.、New York MOS Himalaya LLC、Next Tycoon Investments Limited、Noble Fame Global Limited、O.S.C. Orbit Service Company LLC、Pixshow Film Inc.、Rising Sun Capital Ltd.、Roscalitar 2、Rosy Acme Ventures Limited、Rule of Law Foundation III, Inc.、Rule of Law Society、Rule of Law Society IV, Inc.、Santel LLC、Saraca Media Group, Inc.、Shiny Ace Ltd.、Shiny Times Holdings Ltd.、Stevenson, Wong & Co.、Taurus Fund LLC、Taurus Fund SP、Taurus Management LLC、The Lost Draft LLC、TM Primrose Limited、UA Himalaya Inc.、Voice of Guo Media, Inc.、Well Origin Ltd.、Wise Creation International Limited、Whitecroft Shore Limited、World Century Limited、Worldwide Opportunity Holdings Limited及ZIBA Limited。\n\n案件 22-50073 文件 3193 于 05/16/24 提交，于 05/16/24 10:28:21 登记，第 395 页，共 439 页\n\n10. “和”及“或”均指“和/或”，并应作合取和析取两种解释，以最大限度扩大其范围。\n\n11. “任何”及“全部”和“每一”均指“每一及所有”。\n\n12. “通信”系在可能的最广泛意义上且不受限制地指任何信息或知识的传递（以事实、观念、询问或其他形式）。通信还指所有面对面、通过电话、以书面方式或通过电子传输设备进行的谈话、协议、询问或答复，并包括但不限于所有信函、电子邮件、录音、传送单、备忘录、电话通信、语音留言、电报、传真、电传、即时消息、聊天、短信、留言板或群聊中的帖子、社交媒体帖子、推文、上传至任何视频平台的视频、电话记录或在内部或与第三方之间传送的记录。\n\n案件 22-50073 文件 3193 于 05/16/24 提交，于 05/16/24 10:28:21 登记，第 397 页，共 439 页\n\n13. “每一”及“所有”均指“每一及所有”。\n\n14. “文件”是指属于 Fed. R. Civ. P. 34 范围内的任何信息或物品，并包括但不限于处于或曾处于贵方占有、保管或控制之下的任何种类、类型、性质或描述的每一项书面、记录或图形材料，包括电子邮件的所有印刷和电子副本、以电子形式保存的计算机文件、信函、备忘录、磁带、速记或手写笔记、任何种类的书面表格、图表、蓝图、绘图、草图、曲线图、计划、文章、规格说明、日记、信件、电报、照片、会议记录、合同、协议、调查、计算机打印件、任何种类的数据汇编、电传、传真、电子邮件、短信、即时消息、语音留言、发票、订单、支票、汇票、对账单、贷项通知单、报告、头寸报告、摘要、索引、书籍、账簿、笔记本、日程表、透明胶片、录音、目录、广告、宣传材料、影片、录像带、录音带、CD、计算机磁盘、宣传册、小册子、穿孔卡、工时单、推文、社交媒体帖子或任何其他种类的书面或记录材料，以及无论以何种方式存储（无论以有形或电子形式）、记录、制作或复制的其全部元数据；还包括但不限于前述任何材料的草稿或副本，如其包含原始文件中不存在的任何种类的笔记、评论或标记，或在其他方面与原始文件不相同。\n\n14. “G Club实体”合称 G Club Operations LLC、G Club HoldCo I LLC、G Club International Ltd.、G-Club Investments Limited、G Club International Ltd (BVI)、G Club One、G Club Two、G Club Three、G Club US Operations Inc.及G Club US Operations LLC，以及其所有关联方、部门、机构、工具机构、办事部门、办公室、高级职员、董事、代理人、经理、律师、代表、雇员、专业人员和/或任何为其或代表其行事的人。\n\n案件 22-50073 文件 3193 于 05/16/24 提交，于 05/16/24 10:28:21 登记，第 398 页，共 439 页\n\n15. “包括”或其任何变体均指“包括但不限于”。\n\n16. “人士”是指个人、公司、独资企业、合伙企业、协会或任何其他实体。“人士”还包括任何代理人、代表或专家，包括但不限于律师或财务顾问。\n\n17. “实体”是指任何自然人、公司、合伙企业、子公司、独资企业、商号、董事会、合资企业、协会、机构、机关、委员会或其他商业实体或法人，以及任何关联方、代理人、母公司，包括但不限于律师、财务顾问或任何其他代表。\n\n18. “关于”是指涉及、描述、包含、提及、与之有关、支持、有利于、反对、加强、贬损、位于、与之相关地考虑、影响、证明、表明、报告、记录、暗指、答复、与之相连、评论、就其而言、关于、与之有关、讨论、展示、描述、反映、分析、构成及属于。\n\n19. 在提及任何特定主题时，“与之有关”、“涉及”或“相关”是指包括但不限于构成、包含、涉及、含有、体现、反映、识别、陈述、直接或间接提及该已识别特定主题，或以任何方式与之相关的任何文件。\n\n20. “第三方”是指除贵方以外的人士或实体。\n\n21. “转让”应具有《破产法典》第101(54)条赋予该词的含义。\n\n案件 22-50073 文件 3193 于 05/16/24 提交，于 05/16/24 10:28:21 登记，第 399 页，共 439 页\n\n22. “车辆”系指任何用于出行的车辆，包括但不限于汽车和机动车辆，该等车辆现时或曾在任何时候由债务人、债务人家庭成员、关联个人或关联实体拥有、使用、控制、购买、出售、租赁、出租、许可、维修保养、维护、修理、大修、存放、操作、营销或检查，或为其所拥有、使用、控制、购买、出售、租赁、出租、许可、维修保养、维护、修理、大修、存放、操作、营销或检查，或为其利益而进行前述行为。\n\nIV. 应提交的文件\n\n1. 与 G Club International Limited（G Club 国际有限公司）或 G Club Operations LLC（G Club 运营有限责任公司）向您进行的任何转移有关的所有文件和通信，包括但不限于在 2021年9月13日 或前后进行的 \\$832,000.75 转移。\n\n2. 与债务人、债务人财产、债务人家庭成员、关联个人或关联实体的任何收入或资产有关的所有文件，包括但不限于 G Club Entities（G Club 实体）。\n\n3. 与您和债务人、债务人财产、债务人家庭成员、关联个人或关联实体之间的任何通信有关的所有文件，包括但不限于 G Club 实体。\n\n4. 与债务人、债务人财产、债务人家庭成员、关联实体或关联个人（包括但不限于 G Club 实体）有关并涉及任何车辆的所有文件，包括但不限于：(i) 对任何车辆的所有权或控制权；(ii) 对任何车辆的使用；(iii) 对任何车辆的租赁或出租；(iv) 对任何车辆的购买、出售或营销；(v) 就任何车辆支付或给予的任何金钱或价值及其来源；(vi) 就任何车辆产生或取得的任何金钱或价值及其处置；或 (vii) 与任何车辆有关的操作、维护、维修保养或大修。\n\n案号 22-50073 文件 3193 提交日期 05/16/24 登记日期 05/16/24 10:28:21 第 400 页，共 439 页\n\n5. 与债务人、债务人财产、债务人家庭成员、关联实体（包括但不限于 G Club 实体）或关联个人有关的任何账户有关的所有文件。\n\n6. 与债务人、债务人财产、债务人家庭成员、关联实体（包括但不限于 G Club 实体）或关联个人有关的任何发票或费用支付有关的所有文件。\n\n7. 与债务人、债务人财产、债务人家庭成员、关联实体（包括但不限于 G Club 实体）或关联个人有关的任何车辆的当前位置有关的所有文件。\n\n附件 C-21\n\nB2540（表格 2540——Rule 2004 审查传票）（12/15）案号 22-50073 文件 3193 提交日期 05/16/24 登记日期 05/16/24 10:28:21 第 402 页，共 439 页\n\nUNITED STATES BANKRUPTCY COURT（美国破产法院）\n\nDistrict of Connecticut（康涅狄格联邦地区）\n\n关于 HO WAN KWOK（郭文贵）等人，\n\n¹ 案号：22-50073 (JAM)\n\n债务人 第 11 章\n\n（合并管理）\n\nRULE 2004 审查传票\n\n致：RM Sotheby's and/or RM Auctions 2022（RM 苏富比和/或 RM Auctions 2022）\n\n（传票所指向之人的姓名）\n\n证言：兹命令您于下列规定的时间、日期和地点出席，并根据《联邦破产程序规则》Rule 2004 在审查中作证。随附准许该审查的法院命令副本。\n\n地点　日期和时间\n\nN/A　N/A\n\n本次审查将以以下方式记录：N/A\n\n提交：您或您的代表还必须在审查时携带下列文件、电子存储信息或物品，并必须允许对该等材料进行检查、复制、测试或抽样：\n\n见随附的文件提交请求。\n\nFed. R. Civ. P. 45 的下列规定经 Fed. R. Bankr. P. 9016 适用于破产案件，现随附于后——关于履行地点的 Rule 45(c)；关于您作为传票对象所受保护的 Rule 45(d)；以及关于您回应本传票的义务和未回应之潜在后果的 Rule 45(e) 和 45(g)。\n\n日期：May , 2024\n\n法院书记官\n\n或\n\n书记官或副书记官签名　律师签名\n\n代表第 11 章受托人 Luc A. Despins（卢克·A.·德斯潘斯）并签发或请求本传票的律师之姓名、地址、电子邮件地址和电话号码如下：\n\nPatrick R. Linsey, Esq.（帕特里克·R.·林赛，律师）；Neubert, Pepe & Monteith, P.C.（纽伯特、佩佩和蒙蒂斯专业公司）；195 Church Street, 13th Floor, New Haven, Connecticut 06510；plinsey@npmlaw.com；(203) 781-2847\n\n致签发或请求本传票之人的通知\n\n如本传票要求在审判前提交文件、电子存储信息或有形物品，或检查场所，则必须在向传票所指向之人送达前，向各方送达通知及本传票副本。Fed. R. Civ. P. 45(a)(4)。\n\n软件版权 (c) 1996-2022 Best Case, LLC - www.bestcase.com Best Case Bankruptcy ¹ 本第 11 章案件中的债务人为 Ho Wan Kwok（亦称 Guo Wengui、Miles Guo 和 Miles Kwok，以及众多其他别名）（税务识别号码后四位：9595）、Genever Holdings LLC（税务识别号码后四位：8202）和 Genever Holdings Corporation。受托人、Genever Holdings LLC 及 Genever Holdings Corporation 的邮寄地址为 Paul Hastings LLP（普衡律师事务所），200 Park Avenue, New York, NY 10166，c/o Luc A. Despins，作为 Ho Wan Kwok 财产的受托人（仅为通知和通信之目的）。\n\n送达证明\n\n（除非 Fed. R. Civ. P. 45 要求，否则本节不应向法院提交。）\n\n我于（日期）收到向（个人姓名及职务，如有）送达的本传票。\n\n我以如下方式向被指名人交付副本，送达了该传票：\n\n于（日期）；或\n\n我未执行而退回该传票，原因是：\n\n除非该传票系代表美国或其官员或代理人签发，我还已向证人提供法律允许的一日出席费用和里程费用，金额为 \\$。\n\n我的差旅费用为 \\$，服务费用为 \\$，总计 \\$。\n\n我在伪证罪处罚下声明，本信息真实且正确。\n\n日期：\n\n送达人员签名\n\n正楷姓名及职务\n\n送达人员地址\n\n关于尝试送达等的补充信息：\n\nFederal Rule of Civil Procedure 45(c), (d), (e), and (g)（Effective 12/1/13）（经 Federal Rules of Bankruptcy Procedure Rule 9016 适用于破产案件）\n\n(c) 履行地点。\n\n(1) 审判、听证或证言录取。传票仅可按如下方式命令某人出席审判、听证或证言录取：\n\n(A) 在该人居住、受雇或经常亲自从事营业之地点 100 英里以内；或\n\n(B) 在该人居住、受雇或经常亲自从事营业所在州内，若该人\n\n(i) 为一方当事人或一方当事人的高级人员；或\n\n(ii) 被命令出席审判且不会产生重大费用。\n\n(2) 其他取证。传票可以命令：\n\n(A) 在该人居住、受雇或经常亲自从事营业之地点 100 英里以内的地点提交文件、电子存储信息或物品；以及\n\n(B) 在拟检查的场所检查场所。\n\n(d) 对传票对象的保护；执行。\n\n(1) 避免不当负担或费用；制裁。负责签发和送达传票的一方当事人或律师必须采取合理措施，避免对传票对象施加不当负担或费用。要求履行的地区法院必须执行此项义务，并对未遵守者的一方当事人或律师施加适当制裁，该制裁可包括收入损失和合理的律师费。\n\n(2) 命令提交材料或允许检查。\n\n(A) 无须出席。被命令提交文件、电子存储信息或有形物品，或允许检查场所之人，无须亲自到提交或检查地点出席，除非同时被命令出席证言录取、听证或审判。\n\n(B) 异议。被命令提交文件或有形物品，或允许检查之人，可以向传票中指定的一方当事人或律师送达书面异议，反对检查、复制、测试或抽样任何或全部材料，或反对检查场所，或反对以所请求的一种或多种形式提交电子存储信息。异议必须在规定履行时间届满前或传票送达后 14 日内（以较早者为准）送达。提出异议后，适用下列规则：\n\n(i) 送达方可以随时在通知被命令人后，向要求履行的地区法院申请命令，强制提交或检查。\n\n(ii) 仅可按照该命令的指示要求进行该等行为，且该命令必须保护并非一方当事人或一方当事人高级人员之人，使其免于因履行而产生重大费用。\n\n(3) 撤销或修改传票。\n\n(A) 必须撤销或修改的情形。经及时动议，要求履行的地区法院必须撤销或修改具有下列情形的传票：\n\n(i) 未给予合理的履行时间；\n\n(ii) 要求某人在 Rule 45(c) 规定的地理范围之外履行；\n\n(iii) 要求披露享有特权或受其他保护的事项，且不存在适用的例外或豁免；或\n\n(iv) 对某人施加不当负担。\n\n(B) 可以撤销或修改的情形。为保护传票对象或受传票影响之人，如传票要求下列事项，要求履行的地区法院可以经动议撤销或修改该传票：\n\n(i) 披露商业秘密或其他保密的研究、开发或商业信息；或\n\n(ii) 披露未受聘专家的意见或信息，该等意见或信息并未描述争议中的具体事件，且源于任何一方当事人未请求的该专家研究。\n\n(C) 以规定条件作为替代。在 Rule 45(d)(3)(B) 所述情形下，如送达方：\n\n(i) 证明对证言或材料具有重大需要，且若不造成不当困难则无法以其他方式满足该需要；并且\n\n(ii) 确保被传唤人将获得合理补偿，\n\n法院可以不撤销或修改传票，而命令在规定条件下出席或提交。\n\n(e) 回应传票的义务。\n\n(1) 提交文件或电子存储信息。下列程序适用于提交文件或电子存储信息：\n\n(A) 文件。回应要求提交文件的传票之人，必须按照文件在通常业务过程中保存的方式提交，或必须将其整理并标注，使之与请求中的类别相对应。\n\n(B) 未规定电子存储信息的提交形式。如传票未规定提交电子存储信息的形式，回应之人必须以其通常保存的一种或多种形式，或以一种或多种合理可用的形式提交。\n\n(C) 电子存储信息仅以一种形式提交。回应之人无须以一种以上形式提交相同的电子存储信息。\n\n(D) 无法合理取得的电子存储信息。回应之人无须从其认定因不当负担或费用而无法合理取得的来源提供电子存储信息的取证。对于强制取证或保护令的动议，回应之人必须证明该信息因不当负担或费用而无法合理取得。如作出该证明，在考虑 Rule 26(b)(2)(C) 的限制后，如请求方证明具有正当理由，法院仍可命令从该等来源进行取证。法院可以规定取证条件。\n\n(2) 主张特权或保护。\n\n(A) 扣留的信息。依据该信息享有特权或作为审判准备材料受到保护的主张而扣留经传唤的信息的人，必须：(i) 明确提出该主张；以及\n\n(ii) 以一种不披露本身享有特权或受保护的信息、但能使各方评估该主张的方式，描述被扣留的文件、通信或有形物品的性质。\n\n(B) 已提供的信息。如果为响应传票而提供的信息受到特权主张或作为审判准备材料受保护的主张的约束，提出该主张的人可将该主张及其依据通知任何已接收该信息的当事人。收到通知后，当事人必须立即返还、隔离或销毁所指明的信息及其持有的任何副本；在该主张得到解决前，不得使用或披露该信息；如该当事人在收到通知前已披露该信息，必须采取合理措施追回该信息；并可立即将该信息密封提交至要求履行义务所在地区的法院，以裁定该主张。提供该信息的人必须保存该信息，直至该主张得到解决。\n\n(g) 藐视法庭。要求履行义务所在地区的法院，以及在动议被移送后发出传票的法院，均可认定已被送达但无充分理由不遵从传票或与其有关命令的人构成藐视法庭。\n\n有关查阅传票材料，请参见 Fed.R.Civ.P.45(a) 委员会注释（2013）\n\n……\n\n文件提供请求\nI. 指示\n\n1. 除非另有说明，下列文件请求（以下简称“请求”，单称“请求”）必须分别且具体地予以答复。除非基于善意提出异议，否则必须对每项请求作出完整答复；如提出异议，则应依照下文规定详细说明贵方异议的理由。如异议仅涉及某项请求的一部分，或其中包含的某一词语、短语或条款，贵方仅须说明对该部分的异议，并对其余请求作出答复。\n\n2. 电子存储信息必须依照以下指示提供：\n\na. 图像。黑白图像必须为 300 DPI Group IV 单页 TIFF 文件。彩色图像必须以 JPEG 格式提供。文件名不得含有嵌入空格或特殊字符（包括逗号）。文件夹名称不得含有嵌入空格或特殊字符（包括逗号）。所有 TIFF 图像文件必须具有唯一的文件名，即 Bates 编号。图像必须在每张图像右下角标注连续的 Bates 编号。每个文件夹中的 TIFF 文件数量不得超过 1000 个。Excel 电子表格应具有以该文件的 Bates 编号命名的占位图像。\n\nb. 图像加载文件\n\na. Concordance® 数据文件。数据文件（.DAT）包含将被加载至 Concordance® 数据库的所有字段信息。.DAT 文件的第一行必须为标明字段名称的标题行。.DAT 文件必须使用以下 Concordance® 默认分隔符：逗号 ASCII 字符（020）；引号 þ ASCII 字符（254）。日期字段应采用以下格式提供：mm/dd/yyyy。日期和时间字段必须为两个单独的字段。如文件包括已成像的电子邮件及附件，则必须包括附件字段，以保留电子邮件与其附件之间的父项/子项关系。必须包括 OCRPATH 字段，以提供已提供存储介质上提取文本文件的文件路径及名称。文本文件必须以 FIRSTBATES 命名。不得在 .DAT 文件中包括文本。对于含有原生文件的文件，必须包括 LINK 字段，以提供原生文件的文件路径及名称。原生文件必须以 FIRSTBATES 命名。\n\nb. Concordance Image® 或 Opticon 交叉引用文件。图像交叉引用文件（.LOG 或 .OPT）将图像链接至数据库记录。其应为以逗号分隔的文件，每行由七个字段组成；对于数据库中的每张图像，交叉引用文件中应有一行，格式如下：ImageID,VolumeLabel,ImageFilePath,DocumentBreak,FolderBreak,Box Break,PageCoun。\n\nc. 文件文本。文本必须作为单独的文本文件提供，而非作为 .DAT 文件中的字段。文本文件的完整路径（OCRPATH）应包含在 .DAT 文件中。建议提供以 FIRSTBATES/Image Key 命名的文件级 ANSI 文本文件。提取的文本文件必须置于单独的文件夹中，每个文件夹中的文本文件数量不得超过 1,000 个。文件夹名称中不得含有特殊字符（包括逗号）。文本文件必须按文件级别提供。\n\nd. 特定文件类型的原生格式提供。为充分理解其内容和含义而合理地需要以原生格式查看的文件类型，必须以原生格式提供。这些文件包括但不限于电子表格、类似电子表格的文件（Microsoft（微软） Excel、逗号分隔值、制表符分隔值等）、Microsoft PowerPoint 或其他特殊演示文件、数据库文件以及音频/视频文件。应提供一张标有 Bates 编号的分隔页图像，以表明存在原生文件，并在 .dat 文件中将原生文件的路径作为字段列入。所提供的原生文件应以与该文件分隔页相对应的 Bates 编号命名。原生文件应归入按递增方式命名的“NATIVE”目录中，并与图像目录分开。\n\ne. 去重。对于存在完全重复副本的每份电子文件，仅提供一份副本。对于电子邮件，应基于由 BCC、Body、CC、From、IntMsgID、To 和 Attach 属性生成的 MD5 哈希值合并重复件。对于电子邮件附件及独立电子文件，应基于整个文件的 MD5 哈希值合并重复件。\n\nf. 元数据。以符合 Concordance 要求的加载文件（.dat）形式提供每份文件的提取元数据。.DAT 文件的第一行必须为标明字段名称的标题行。.DAT 文件必须使用以下 Concordance 默认分隔符：逗号 , ASCII 字符（020）；引号 þ ASCII 字符（254）。\n\n日期字段应采用以下格式提供：mm/dd/yyyy。日期和时间字段必须为两个单独的字段。以下为必需的元数据：\n\n案件 22-50073 文书 3193 已提交 05/16/24 已录入 05/16/24 10:28:21 第 407 页，共 439 页\n\n字段名称　示例数据　说明\n\nFIRSTBATES　EDC0000001　原生文件文件/电子邮件的第一个 Bates 编号\nLASTBATES　EDC0000001　原生文件文件/电子邮件的最后一个 Bates 编号\nLASTBATES 字段应针对单页填写\nATTACHRANGE　EDC0000001　父文件第一页的 Bates 编号至最后一个附件“子”文件最后一页的 Bates 编号\n-　EDC0000015\nBEGATTACH　EDC0000001　附件范围的第一个 Bates 编号\nENDATTACH　EDC0000015　附件范围的最后一个 Bates 编号\nCUSTODIAN　Smith, John（约翰·史密斯）　电子邮件：电子邮件所在的邮箱\n原生文件：文件来源的个人或部门名称\nFROM　John Smith（约翰·史密斯）　电子邮件：发件人\n原生文件：文件作者\n多个条目应使用分号分隔\nTO　Coffman, Janice（贾尼斯·科夫曼）; LeeW（李W） [mailto:LeeW@MSN.com]　收件人\n多个条目应使用分号分隔\nCC　Frank Thompson（弗兰克·汤普森） [mailto:frank_Thompson@cdt.com]　抄送收件人\n多个条目应使用分号分隔\nBCC　John Cain（约翰·凯恩）　密送收件人\n多个条目应使用分号分隔\nSUBJECT　Board Meeting Minutes　电子邮件：电子邮件主题行；原生文件：文件标题（如有）\nFILE_NAME　BoardMeetingMinutes.docx　原生文件：原始原生文件的名称，包括扩展名\nDATE_SENT　10/12/2010　电子邮件：电子邮件发送日期\n原生文件：（空）\nTIME_SENT/\nTIME_ZONE　07:05 PM GMT　电子邮件：电子邮件发送时间/电子邮件标准化所采用的时区\nTIME_ZONE　GMT　在转换期间电子邮件被标准化所采用的时区。\nLINK　EDC0000001.msg　电子邮件或原生文件的超链接\n链接文件必须按照 FIRSTBATES 编号命名\nFILE_EXTEN　MSG　代表电子邮件或原生文件的文件类型扩展名\nAUTHOR　John Smith（约翰·史密斯）　电子邮件：（空）\n原生文件：文件作者\nDATE_CREATED　10/10/2010　电子邮件：（空）\n原生文件：文件创建日期\n\n案件 22-50073 文书 3193 已提交 05/16/24 已录入 05/16/24 10:28:21 第 408 页，共 439 页\n\nTIME_CREATED　10:25 AM　电子邮件：（空）\n原生文件：文件创建时间\n该数据必须为单独字段，不得与 DATE_CREATED 字段合并\nDATE_MOD　10/12/2010　电子邮件：（空）\n原生文件：文件最后修改日期\nTIME_MOD　07:00 PM　电子邮件：（空）\n原生文件：文件最后修改时间\n该数据必须为单独字段，不得与 DATE_MOD 字段合并\nDATE_ACCESSD　10/12/2010　电子邮件：（空）\n原生文件：文件最后访问日期\nTIME_ACCESSD　07:00 PM　电子邮件：（空）\n原生文件：文件最后访问时间\n该数据必须为单独字段，不得与 DATE_ACCESSD 字段合并\nFILE_SIZE　5,952　原生文件文件/电子邮件的大小，单位为 KB\nPGCOUNT　1　原生文件文件/电子邮件的页数\nPATH　电子邮件：（空）\nAgenda.doc　原生文件：存储原生文件文件的路径，包括原始文件名。\nINTFILEPATH　Personal Folders\\Deleted Items\\Board Meeting Minutes.msg　电子邮件：电子邮件的原始位置，包括原始文件名。\n原生文件：（空）\nINTMSGID　<000805c2c71b\\$75977050\\$cb8306d1@MSN>　电子邮件：唯一邮件 ID；原生文件：（空）\nMD5HASH　d131dd02c5e6eec4693d9a0698aff95c2fcab58712467eab4004583eb8fb7f89　文件的 MD5 哈希值。\nOCRPATH　TEXT/001/EDC0000001.txt　原生文件提取文本的路径\n\n3. 每项请求独立适用并应作独立解释，且除非另有说明，任何请求均不限制任何其他请求的范围。\n\n4. 所有文件应按其在正常业务过程中保存的方式提供，或者应予以整理和标注，以对应这些请求中的类别。\n\n5. 本文件所载的每项请求均延及以下所有文件：(a) 由贵方占有、保管或控制的文件；或 (b) 由代表贵方行事的任何人占有、保管或控制的文件，\n\n案件 22-50073 文书 3193 已提交 05/16/24 已录入 05/16/24 10:28:21 第 409 页，共 439 页\n\n包括贵方律师或其他代表和顾问。每份文件均应完整提供。\n\n6. 如要求贵方提供的文件已不再由贵方占有、保管或控制，则贵方的答复必须：(a) 详细说明该文件及其内容的性质；(b) 确认制作或撰写该文件的人（以及，如适用，该文件被发送给的人）；(c) 确认该文件制作或创建的日期；(d) 说明该文件是否：(i) 遗失或丢失，(ii) 已被销毁，(iii) 已自愿或非自愿地转移给他人，或 (iv) 以其他方式处置；(e) 说明该等处置的理由及相关事实和情况；(f) 确认授权该等处置的人；(g) 确认该等处置的日期或大致日期；(h) 说明该文件最近一次由贵方占有、保管或控制的时间；以及 (i) 确认目前占有、保管或控制该文件的人（如有）。\n\n7. 如要求贵方提供的文件已被销毁，则除前述指示所要求的信息外，贵方的答复还必须说明：(a) 销毁该文件的理由；(b) 销毁该文件的人的身份；以及 (c) 指示销毁该文件的人的身份。\n\n8. 如您主张所请求的文件享有特权或律师工作成果保护，则您的答复必须：(a) 说明：(i) 对该文件作出足以支持您关于该文件享有特权之主张的描述；(ii) 该文件的标题；(iii) 该文件的日期；(iv) 该文件的作者；(v) 该文件的收件人；(vi) 收到或查阅该文件原件或任何草稿、副本或复制件的每一人的身份；(vii) 该文件本身，或该文件中所载或所提及的任何信息，是否处于任何其他人的占有、保管或控制之下；如是，则说明该等人员的身份，以及说明该等信息如何进入其占有；(viii) 据以扣留该文件的特权主张；以及 (ix) 您将据以支持该等特权主张的所有情形；以及 (b) 就根据特权主张而扣留的每一份文件，依照 D. Conn. L. Civ. R. 26(e)，提供一份特权日志，其中载明本指示第 (a) 部分所要求的全部信息。对于文件请求中未提出特权或工作成果主张的任何部分，应完整提供响应性文件。\n\n9. 如一份原本具有响应性的文件的一部分包含受特权主张约束的信息，则仅应依照上述指示从该文件中删除或遮蔽受特权主张约束的该部分，文件其余部分应予提供。\n\n10. 本请求具有持续性。特此指示您：(a) 一旦得知先前答复不完整或不正确，应立即补充或更正任何后来发现不完整或不正确的答复；以及 (b) 提供根据下述内容所要求的任何额外文件。\n\n11. 如文件为非英文文件，您应提供该文件。如文件为非英文文件，且存在英文译本，您应同时提供两份文件。\n\n12. 对实体的一切提及均包括其全部关联方。\n\n13. 对个人姓名的一切提及均包括所有其他姓名、别名或昵称。\n\n14. 除非另有明确说明，文件请求所涵盖的期间为自 February 5, 2012 起至提交文件请求答复的到期日止。\n\nII. 解释规则\n\n15. (a) 使用任何单数名词，应解释为包括复数，反之亦然；以及 (b) 使用任何时态的动词，应解释为使用该动词的所有其他时态。\n\n16. (a) “and”和“or”应视需要解释为连词性或选择性用法，以将原本可能被解释为超出任何请求范围的所有答复纳入该请求范围；以及 (b) “each”和“any”应视为包括并涵盖“every”和“all”二词。\n\nIII. 定义\n\nD. Conn. L. Civ. R. 26(c) 所提供的定义以及 D. Conn. L. Civ. R. 26(d) 所提供的解释规则，经 D. Conn. Bankr. L.R. 2004-1(a) 纳入后，适用于文件请求。此外，本文件请求中使用的下列术语具有下列含义：\n\n1. “You”或“Your”或“Yourself”系指 RM Sotheby's（RM苏富比）和/或 RM Auctions 2022（RM拍卖2022），连同其全部关联方、部门、机构、工具性实体、司处、办公室、合伙人、高级职员、董事、代理人、律师、代表、雇员和/或任何代表其行事的人。\n\n2. “Debtor”系指 Ho Wan Kwok（郭文贵）（又名 Miles Kwok、Miles Guo、Guo Wengui、Guo Haoyun、郭文贵或任何其他别名），连同其雇员、代理人、律师、顾问或任何代表其行事的人。\n\n3. “Debtor's Son”系指 Qiang Guo（郭强）（又名 Mileson Kwok、郭强或任何其他别名），连同其雇员、代理人、律师、顾问或任何代表其行事的人。\n\n4. “Debtor's Daughter”系指 Mei Guo（郭美）（又名 Mei Gui、郭美或任何其他别名），连同其雇员、代理人、律师、顾问或任何代表其行事的人。\n\n5. “Debtor's Purported Wife”系指 Hing Chi Ngok（岳庆芝）（又名 Hing Chi Ng、Yue Qingzhi、岳庆芝或任何其他别名），连同其雇员、代理人、律师、顾问或任何代表其行事的人。\n\n6. “Debtor's Family”统称债务人、债务人的儿子、债务人的女儿及债务人声称的妻子，以及与债务人有任何其他亲属关系的人。\n\n7. “Asset(s)”系指处于占有、保管或控制之下的任何具有经济价值的项目。资产包括所有不动产和动产，包括但不限于房地产、土地、房屋、公寓、产权公寓、汽车、游艇、船舶、飞机、喷气机、直升机、现金、银行账户、加密货币、证券、应收账款、存货及其他有形和无形财产。\n\n8. “Associated Individuals”系指单独及共同而言，所有：(1) 持有、控制、保管或对债务人或债务人家族所拥有、控制或享用的资产拥有裁量权的个人；或 (2) 曾为一个或多个关联实体的雇员、董事，或以其他方式与一个或多个关联实体有关联的个人，连同前述各方各自的雇员、代理人、律师、顾问或任何代表前述任何一方行事的人。该等关联个人包括但不限于：Aaron Mitchell（阿伦·米切尔）、Anthony DiBattista（安东尼·迪巴蒂斯塔）、Ana Izquierdo（安娜·伊斯基耶多）、Alex Hadjicharalambous（亚历克斯·哈吉查拉兰布斯）、Bingshang Jiao（焦冰尚）、Beile Li（李贝乐）、Brian W. Hofmeister（布赖恩·W·霍夫迈斯特）、Charles Gruder（查尔斯·格鲁德）、Daniel Podhaskie（丹尼尔·波德哈斯基）、David Fallon（大卫·法伦）、Defeng Cao（曹德锋）（又名 Wayne Cao、Max Cao）、Ding Lin（林丁）、Dinggang Wang（王定刚）（又名 王定刚）、Eduardo Eurnekian（爱德华多·厄尔内基安）、Ehsan Masud（埃桑·马苏德）、Fiona Yu（余菲奥娜）、Gladys Chow（周格拉迪斯）、Haitham Khaled（海瑟姆·哈立德）、Hao (Gavin) Li（李浩）（又名 Huo Lai）、Hao Haidong（郝海东）（又名 郝海东）、Han Chunguang（韩春光）（又名 韩春光）、Haoran He（何浩然）、Ivan Lin（林伊万）、Haitham Khaled（海瑟姆·哈立德）、Jason Miller（杰森·米勒）、Jennifer Mercurio（詹妮弗·梅尔库里奥）、Jesse Brown（杰西·布朗）、Jessica Mastrogiovanni（杰西卡·马斯特罗焦万尼）、Jie Zhang（张杰）、Jintao Li（李金涛）、Karin Maistrello（卡琳·迈斯特雷洛）、Kyle Bass（凯尔·巴斯）、Leanne Li（李莉安）、Lihong Wei Lafrenz（魏丽红·拉弗伦茨）（又名 Sara Wei、魏丽红）、Limarie Reyes Molinaris（利马丽·雷耶斯·莫利纳里斯）、Linwan “Irene” Feng（冯林婉“艾琳”）、Max Krasner（马克斯·克拉斯纳）、Melissa Francis（梅丽莎·弗朗西斯）、Michael Baranowitz（迈克尔·巴拉诺维茨）、Min Yang（杨敏）、Melissa Mendez（梅丽莎·门德斯）、Nadeem Akbar（纳迪姆·阿克巴尔）、Nan Li（李楠）（又名 Chris Lee、Mei Guo Xiao Li）、Qidong Xia（夏启东）、Qu Guojiao（屈国姣）（又名 Qu Guo Jiao、屈国姣）、Ridwan Mamode Saib（里德万·马莫德·赛卜）、Ross Heinemeyer（罗斯·海内迈耶）、Rui “Ray” Hao（郝睿“雷”）、Scott Barnett（斯科特·巴尼特）、Shih Hsin Yu（余世新）、Shin Hee-Seup（申熙燮）（又名 Hee Seup Shin）、Steve Bannon（史蒂夫·班农）、Talha Zobair（塔尔哈·佐贝尔）、Victor Cerda（维克托·塞尔达）、Wen Xiao（肖雯）、Wencong Wang（王文聪）、William Gertz（威廉·格茨）、William Je（余建明）（又名 Je Kin Ming、Yu Jianming、余建明）、Xuebing Wang（王学兵）、Ya Li（李娅）（又名 李娅）、Yinying (Aila) Wang（王茵莹）（又名 Xiao Fei Xiang）、Yongping Yan（闫永平）（Shan Mu）、Yong Yu（俞勇）、Yue Zhou（周玥）、Yumei Hao（郝玉梅）（又名 Ru Shui）、Yvette Wang（王雁平）（又名 Yanping Wang、Yan Ping Wang、王雁平）、Zhang Wei（张魏）（又名 张魏）、Zhouer Wang（王周儿）（又名 Joe Wang）、Zhixuan Li（李志轩）及 Ziyang Liu（刘子扬）。\n\n9. “Associated Entities”系指单独及共同而言，所有任何类型的组织或实体：(1) 曾由债务人或债务人家族拥有、控制或投资；或 (2) 直接或间接对债务人或债务人家族所拥有、控制或享用的任何资产享有权益，连同前述各方各自的雇员、代理人、律师、顾问或任何代表前述任何一方行事的人。该等关联实体包括但不限于：1332156 B.C. Ltd.、7 Nod Hill LLC、AAGV Limited、ACA Investment Management Limited、ACA Capital Group Limited、Ace Decade Holdings Limited、AI Group Holdings Inc.、Alfa Global Ventures Limited、Alfonso Global Limited、Allied Capital Global Limited、Alpine Fiduciaries SA、Anton Development Limited、Beijing Pangu Investment Co.（北京盘古投资有限公司）、Beijing Pangu Investment Co. Ltd.（北京盘古投资有限公司）、Beijing Pangu Investment Inc.（北京盘古投资股份有限公司）、Beijing Zenith Holdings Company Limited、Blue Capital Limited、Booming Sail New York LLC、Bravo Luck Limited、Brent Petro、BSA Strategic Fund I、China Golden Spring (Hong Kong) Limited、Chuang Xin Limited、Crane Advisory Group LLC、Creative Apex Investments Limited、Crystal Breeze Investments Limited、Dawn State Limited、Eastern Profit Corporation Limited、Empire Growth Holdings、Elite Well Global Limited、Freedom Media Ventures Ltd.、Fung Wan Trading Inc.、G Club、G Club Operations LLC、G Club International Limited、G Club Investments Limited、G Fashion LLC、G-News Operations LLC、G News LLC、GMusic Inc.、G Music LLC、G-Services LLC、G-Translators PTY LTD、GETTR USA, Inc.、Genever Holdings Corporation、Genever Holdings LLC、G Fashion、GFashion Media Group Inc.、GF Italy, LLC、GFNY, Inc.、Globalist International Limited、GNews Media Group Inc.、Golden Spring (New York) Ltd.、Greenwich Land, LLC、Guo Media、GTV Media Group, Inc.、GWGOPNZ Limited、GWGNZ Limited、Gypsy Mei Food Services, LLC、HCHK Property Management Inc.、HCHK Technologies Inc.、Hamilton Digital Assets FD SP、Hamilton Capital Holdings Inc.、Hamilton Opportunity Fund SPC、Head Win Group Limited、Himalaya Embassy、Himalaya Exchange、Himalaya Federal Reserve、Himalaya International Clearing Limited、Himalaya International Financial Group Ltd.、Himalaya Investment LLC、Himalaya (USA) Investment Management LLC、Himalaya New World Inc.、Himalaya Supervisory Organization、Himalaya Ventures、Holy City Hong Kong Ventures, Ltd.、Hudson Diamond Holding LLC、Hudson Diamond Holding Inc.、Hudson Diamond NY LLC、HK International Funds Investments (USA) Limited LLC、Hong Kong International Funds Investments Limited、Huk Trading Inc、Infinite Increase Limited、Infinitum Developments Limited、Japan Himalaya League, Inc.、Kalixun Trading Limited、K Legacy Ltd.、Lamp Capital LLC、Leading Shine Limited、Leading Shine NY Limited、Lexington Property and Staffing Inc.、Long Gate Limited、MOS Himalaya Foundation Inc.、Maywind Trading LLC、New Federal State of China（新中国联邦）（又名 NFSC）、Newpeople LLC、New Mulberry PTE Ltd.、New York MOS Himalaya LLC、Next Tycoon Investments Limited、Noble Fame Global Limited、O.S.C. Orbit Service Company LLC、Pixshow Film Inc.、Rising Sun Capital Ltd.、Roscalitar 2、Rosy Acme Ventures Limited、Rule of Law Foundation III, Inc.、Rule of Law Society、Rule of Law Society IV, Inc.、Santel LLC、Saraca Media Group, Inc.、Shiny Ace Ltd.、Shiny Times Holdings Ltd.、Stevenson, Wong & Co.、Taurus Fund LLC、Taurus Fund SP、Taurus Management LLC、The Lost Draft LLC、TM Primrose Limited、UA Himalaya Inc.、Voice of Guo Media, Inc.、Well Origin Ltd.、Wise Creation International Limited、Whitecroft Shore Limited、World Century Limited、Worldwide Opportunity Holdings Limited 及 ZIBA Limited。\n\n10. “And”和“or”意指“and/or”，并应同时解释为连词性及选择性用法，以最大限度扩大其范围。\n\n11. “Any”、“all”和“each”意指“each and every”。\n\n12. “Communication(s)”在最广义且不受限制的意义上，系指任何信息或知识的传递（以事实、观点、询问或其他形式）。通信还指所有谈话、协议、询问或答复，无论是当面、通过电话、书面方式，或通过电子传输设备进行，并包括但不限于所有函件、电子邮件、录音、传送单、备忘录、电话通信、语音留言、电报、电传传真、影印传真、电传、即时消息、聊天、短信、在留言板或群聊中的发帖、社交媒体帖子、推文、上传至任何视频平台的视频、电话笔记或在内部或与第三方之间传递的笔记。\n\n13. “每一”及“所有”均指“每一及所有”。\n\n14. “文件”指属于《联邦民事诉讼规则》第34条范围内的任何信息或物品，包括但不限于任何种类、类型、性质或描述的每一及所有书面、记录或图形材料，该等材料现由或曾由您占有、保管或控制，包括所有电子邮件的打印件和电子副本、以电子形式保存的计算机文件、通信函件、备忘录、磁带、速记或手写笔记、任何种类的书面表格、图表、蓝图、图纸、草图、曲线图、计划、文章、规格说明书、日记、信函、电报、照片、会议记录、合同、协议、调查资料、计算机打印输出、任何种类的数据汇编、电传、传真、电子邮件、短信、即时消息、语音消息、发票、订购单、支票、汇票、对账单、贷项通知单、报告、持仓报告、摘要、索引、书籍、账簿、笔记本、时间表、幻灯片、录音、目录、广告、宣传材料、电影、录像带、录音带、CD、计算机磁盘、小册子、传单、穿孔卡、工时单、推文、社交媒体帖子或任何其他种类的书面或记录材料，以及其所有元数据，无论以何种方式存储（无论为有形形式或电子形式）、记录、制作或复制，亦包括但不限于前述任何材料的草稿或副本，其中含有原始文件中未载的任何种类的笔记、评论或标记，或在其他方面与原始文件不完全相同。\n\n14. “G Club实体”统指G Club Operations LLC、G Club HoldCo I LLC、G Club International Ltd.、G-Club Investments Limited、G Club International Ltd (BVI)、G Club One、G Club Two、G Club Three、G Club US Operations Inc.及G Club US Operations LLC，以及其所有关联方、部门、机构、执行机构、科室、办事处、高级职员、董事、代理人、经理、律师、代表、雇员、专业人士和/或任何代表其或为其行事的人员。\n\n案件22-50073 文件3193 于05/16/24提交 于05/16/24 10:28:21录入 第417页，共439页\n\n15. “包括”或其任何变体均指“包括但不限于”。\n\n16. “人员”指个人、公司、独资企业、合伙企业、协会或任何其他实体。“人员”亦包括任何代理人、代表或专家，包括但不限于律师或财务顾问。\n\n17. “实体”指任何自然人、公司、合伙企业、子公司、独资企业、商号、董事会、合资企业、协会、机构、主管机关、委员会或其他商业实体或法人，以及任何关联方、代理人、母公司，包括但不限于法律顾问、财务顾问或任何其他代表。\n\n18. “关于”指涉及、描述、构成、提及、与之相关、支持、赞成、反对、强化、削弱、位于、在与之相关的情况下予以考虑、与之有关、证明、表明、报告、记录、暗示、回应、与之连接、评论、就其而言、有关、与之相关、讨论、显示、描述、反映、分析、构成及作为。\n\n19. 就任何特定事项而言，“与……有关”、“涉及”或“相关”指，包括但不限于，构成、包含、涉及、载有、体现、反映、识别、陈述、直接或间接提及该特定事项，或以任何方式与所识别的特定事项相关的任何文件。\n\n20. “第三方”指除您之外的人员或实体。\n\n21. “转让”具有《破产法典》第101(54)条赋予其的含义。\n\n案件22-50073 文件3193 于05/16/24提交 于05/16/24 10:28:21录入 第418页，共439页\n\n22. “车辆”指任何用于出行的车辆，包括但不限于现由或曾在任何时候由债务人、债务人家属、关联个人或任何关联实体拥有、使用、控制、购买、出售、租赁、出租、许可、维修保养、维护、修理、大修、存储、操作、营销或检查，或为其利益而拥有、使用、控制、购买、出售、租赁、出租、许可、维修保养、维护、修理、大修、存储、操作、营销或检查的汽车及机动车辆。\n\n四、应提交的文件\n\n1. 与G Club International Limited或G Club Operations LLC向您进行的任何转让有关的所有文件及通信，包括但不限于在2021年9月13日前后进行的$832,000.75转让。\n\n2. 与债务人、债务人财产、债务人家属、关联个人或关联实体的任何收入或资产有关的所有文件，包括但不限于G Club实体。\n\n3. 与您和债务人、债务人财产、债务人家属、关联个人或关联实体之间的任何通信有关的所有文件，包括但不限于G Club实体。\n\n4. 与债务人、债务人财产、债务人家属、关联实体或关联个人（包括但不限于G Club实体）有关的、涉及任何车辆的所有文件，包括但不限于：(i) 任何车辆的所有权或控制权；(ii) 任何车辆的使用；(iii) 任何车辆的租赁或出租；(iv) 任何车辆的购买、出售或营销；(v) 与任何车辆有关的任何已支付或给予的金钱或价值及其来源；(vi) 与任何车辆有关的任何产生或取得的金钱或价值及其处置；或(vii) 与任何车辆有关的操作、维护、维修保养或大修。\n\n案件22-50073 文件3193 于05/16/24提交 于05/16/24 10:28:21录入 第419页，共439页\n\n5. 与债务人、债务人财产、债务人家属、关联实体（包括但不限于G Club实体）或关联个人有关的任何账户有关的所有文件。\n\n6. 与债务人、债务人财产、债务人家属、关联实体（包括但不限于G Club实体）或关联个人有关的任何发票或费用支付有关的所有文件。\n\n7. 与债务人、债务人财产、债务人家属、关联实体（包括但不限于G Club实体）或关联个人有关的任何车辆的当前位置有关的所有文件。\n\n案件22-50073 文件3193 于05/16/24提交 于05/16/24 10:28:21录入 第420页，共439页\n\n附件C-22\n\nB2540（表格2540——《规则2004审查传票》）（12/15）案件22-50073 文件3193 于05/16/24提交 于05/16/24 10:28:21录入 第421页，共\n\n美国破产法院\n\n康涅狄格地区\n\n关于HO WAN KWOK（郭文贵）等人，\n\n1 案件编号22-50073 (JAM) 债务人 第11章\n\n（合并管理）\n\n规则2004审查传票\n\n致：Dean M. Rabideau\n\n（传票所指向人员的姓名）\n\n证言：特此命令您于下列规定的时间、日期及地点出席，并依《联邦破产程序规则》第2004条接受审查并作证。随附准许该审查的法院命令副本。\n\n地点　日期及时间\n\n不适用　不适用\n\n审查将通过以下方式记录：不适用\n\n提交：您或您的代表还必须在审查时携带下列文件、电子存储信息或物品，并必须允许对该材料进行检查、复制、测试或取样：\n\n见随附的《文件提交请求》。\n\n下列《联邦民事诉讼规则》第45条规定，依《联邦破产程序规则》第9016条适用于破产案件，现随附于后——第45(c)条，关于履行地点；第45(d)条，关于您作为受传票约束人员所享有的保护；以及第45(e)条和第45(g)条，关于您对本传票的答复义务及未履行该义务的潜在后果。\n\n日期：May , 2024\n\n法院书记官\n\n或\n\n书记官或副书记官签名　律师签名\n\n签发或请求本传票的代表第11章受托人Luc A. Despins的律师，其姓名、地址、电子邮件地址及电话号码如下：\n\nPatrick R. Linsey, Esq.; Neubert, Pepe & Monteith, P.C.; 195 Church Street, 13th Floor, New Haven, Connecticut 06510；plinsey@npmlaw.com；(203) 781-2847\n\n致签发或请求本传票之人员的通知\n\n如本传票命令在审判前提交文件、电子存储信息或有形物品，或检查场所，则必须在向传票所指向人员送达前，向每一当事人送达通知及本传票副本。《联邦民事诉讼规则》第45(a)(4)条。\n\n软件版权 (c) 1996-2022 Best Case, LLC - www.bestcase.com Best Case Bankruptcy 1 本第11章案件中的债务人为Ho Wan Kwok（郭文贵，亦称Guo Wengui、Miles Guo及Miles Kwok，以及众多其他别名）（税务识别号码后四位：9595）、Genever Holdings LLC（税务识别号码后四位：8202）及Genever Holdings Corporation。受托人、Genever Holdings LLC及Genever Holdings Corporation的邮寄地址为Paul Hastings LLP, 200 Park Avenue, New York, NY 10166，转交Luc A. Despins，作为Ho Wan Kwok财产的受托人（仅为通知和通信之目的）。\n\n送达证明\n\n（除非《联邦民事诉讼规则》第45条要求，否则本节不应向法院提交。）\n\n本人于（日期）收到向（个人姓名及职务，如有）发出的本传票。\n\n本人已按如下方式向被指名人员送达本传票副本：\n\n于（日期）送达；或\n\n本人未执行而退回本传票，原因如下：\n\n除非本传票系代表美国或其官员或代理人签发，本人亦已向证人支付一日出席费用及法律允许的里程费，金额为$ 。\n\n本人的差旅费用为$ ，服务费用为$ ，合计$ 。\n\n本人依伪证处罚的规定声明，该等信息真实且正确。\n\n日期：\n\n送达人签名\n\n正楷姓名及职务\n\n送达人地址\n\n关于尝试送达等的补充信息：\n\n《联邦民事诉讼规则》第45(c)、(d)、(e)及(g)条（自12/1/13起生效）（依《联邦破产程序规则》第9016条适用于破产案件）\n\n(c) 履行地点。\n\n(1) 审判、听证或证言录取。传票仅可按以下方式命令人员出席审判、听证或证言录取：\n\n(A) 在该人员居住、受雇或经常亲自从事业务地点100英里范围内；或\n\n(B) 在该人员居住、受雇或经常亲自从事业务所在州内，如该人员\n\n(i) 为当事人或当事人的高级职员；或\n\n(ii) 被命令出席审判且不会产生重大费用。\n\n(2) 其他证据开示。传票可命令：\n\n(A) 在该人员居住、受雇或经常亲自从事业务地点100英里范围内的地点提交文件、电子存储信息或物品；及\n\n(B) 在须检查的场所对该场所进行检查。\n\n(d) 对受传票约束人员的保护；执行。\n\n(1) 避免不当负担或费用；制裁。负责签发及送达传票的当事人或律师必须采取合理措施，避免对受传票约束人员施加不当负担或费用。要求履行的地区法院必须执行该义务，并对未遵守者——当事人或律师——施加适当制裁，制裁可包括损失的收入及合理的律师费。\n\n(2) 命令提交材料或允许检查。\n\n(A) 无须出席。被命令提交文件、电子存储信息或有形物品，或允许检查场所的人员，无须亲自到提交或检查地点出席，除非同时被命令出席证言录取、听证或审判。\n\n(B) 异议。被要求提交文件或有形物品，或允许检查的人，可以向传票中指定的一方当事人或律师送达书面异议，反对检查、复制、测试或抽样任何或全部材料，或反对检查场所——或反对以所要求的一种或多种形式提交电子存储信息。异议必须在规定的履行时间届满前或传票送达后14日内（以较早者为准）送达。如提出异议，适用下列规则：\n\n(i) 在任何时候，送达传票的一方可在通知被要求履行的人后，向要求履行地所在地区的法院提出动议，请求作出强制提交或检查的命令。\n\n(ii) 仅可依照命令的指示要求实施这些行为，该命令必须保护既非当事人亦非当事人高级职员的人免受因履行而产生的重大费用。\n(3) 撤销或修改传票。\n\n(A) 必须撤销或修改的情形。经及时提出动议，要求履行地所在地区的法院必须撤销或修改具有下列情形的传票：\n\n(i) 未给予合理履行时间；\n\n(ii) 要求人在 Rule 45(c) 规定的地域限制之外履行；\n\n(iii) 要求披露享有特权或受其他保护的事项，而不适用任何例外或豁免；或\n\n(iv) 使人承受不当负担。\n\n(B) 可以撤销或修改的情形。为保护受传票约束或受其影响的人，要求履行地所在地区的法院可以根据动议，在传票要求下列事项时撤销或修改该传票：\n\n(i) 披露商业秘密或其他保密的研究、开发或商业信息；或\n\n(ii) 披露未受聘专家的意见或信息，该等意见或信息并非描述争议中的特定事件，且源于未经当事人请求的该专家研究。\n\n(C) 作为替代方案规定条件。在 Rule 45(d)(3)(B) 所述情形下，法院可以不撤销或修改传票，而是在送达传票的一方符合下列条件时，命令在规定条件下出庭或提交：\n\n(i) 证明对证言或材料具有重大需要，且不承受不当困难即无法通过其他方式满足该需要；并且\n\n(ii) 确保被传唤人将获得合理报酬。\n(e) 对传票作出回应时的义务。\n\n(1) 提交文件或电子存储信息。下列程序适用于提交文件或电子存储信息：\n\n(A) 文件。回应要求提交文件的传票的人，必须按其在正常业务过程中保存的方式提交文件，或者必须按照请求中所列类别对文件进行整理和标注。\n\n(B) 未指定电子存储信息提交形式。如传票未指定电子存储信息的提交形式，回应人必须以其通常保存的一种或多种形式，或以一种或多种合理可用的形式提交。\n\n(C) 电子存储信息仅以一种形式提交。回应人无需以一种以上的形式提交相同的电子存储信息。\n\n(D) 无法合理获取的电子存储信息。回应人无需提供其认定为因不当负担或费用而无法合理获取的来源中的电子存储信息以供证据开示。在提出强制证据开示动议或保护令动议时，回应人必须证明该信息因不当负担或费用而无法合理获取。如作出该证明，法院仍可在请求方证明具有正当理由时，命令对该等来源进行证据开示，并考虑 Rule 26(b)(2)(C) 的限制。法院可以规定该证据开示的条件。\n(2) 主张特权或保护。\n\n(A) 未提交的信息。以该信息享有特权或作为审判准备材料受保护为由而不提交被传唤信息的人必须：(i) 明确提出该主张；并且\n\n(ii) 以一种不披露本身享有特权或受保护信息的方式，说明被扣留的文件、通信或有形物品的性质，从而使当事人能够评估该主张。\n\n(B) 已提交的信息。如为回应传票而提交的信息受到特权主张或作为审判准备材料受保护的主张约束，提出主张的人可将该主张及其依据通知任何收到该信息的当事人。收到通知后，当事人必须立即返还、隔离或销毁所指明的信息及其持有的任何副本；在该主张得到解决前不得使用或披露该信息；如该当事人在收到通知前已披露该信息，必须采取合理措施取回该信息；并可立即向要求履行地所在地区的法院密封提交该信息，以裁定该主张。提交该信息的人必须保存该信息，直至该主张得到解决。\n\n(g) 藐视法庭。要求履行地所在地区的法院——以及在动议被移送后，签发传票的法院——可以认定已被送达但无充分理由不遵守传票或与之相关命令的人构成藐视法庭。\n\n关于获取传票材料，见 Fed.R.Civ.P.45(a) 委员会说明（2013年）\n\n……\n\n文件提交请求\nI. 指示\n\n1. 除非另有说明，下列文件请求（统称“请求”，每一项称“一项请求”）必须分别且具体地作出回应。除非出于善意提出异议，否则必须完整答复每项请求；如提出异议，必须如下文所述详细说明贵方异议的理由。如异议仅涉及一项请求的一部分，或其中所含的一个词、短语或条款，贵方仅须对该部分提出异议，并对请求的其余部分作出回应。\n\n2. 电子存储信息必须按照下列指示提交：\n\na. 图像。黑白图像必须为300 DPI Group IV 单页 TIFF 文件。彩色图像必须以 JPEG 格式提交。文件名不得包含嵌入式空格或特殊字符（包括逗号）。文件夹名称不得包含嵌入式空格或特殊字符（包括逗号）。所有 TIFF 图像文件必须具有唯一的文件名，即 Bates 编号。每幅图像的右下角必须标注连续的 Bates 编号。每个文件夹中的 TIFF 文件数量不应超过1000个文件。Excel 电子表格应具有以该文件 Bates 编号命名的占位图像。\n\nb. 图像加载文件\n\na. Concordance® 数据文件。数据文件（.DAT）包含将加载至 Concordance® 数据库的全部字段化信息。.DAT 文件的第一行必须为标识字段名称的标题行。.DAT 文件必须使用下列 Concordance® 默认分隔符：逗号 ASCII 字符（020）引号 þ ASCII 字符（254）。日期字段应以如下格式提供：mm/dd/yyyy。日期字段和时间字段必须为两个单独的字段。如文件包括已成像的电子邮件及附件，必须包括附件字段，以保留电子邮件与其附件之间的父/子关系。必须包括 OCRPATH 字段，以提供已提交存储介质上提取文本文件的文件路径和名称。文本文件必须以 FIRSTBATES 命名。不得将文本包含在 .DAT 文件中。对于包含原生文件的文件，必须包括 LINK 字段，以提供原生文件的文件路径和名称。原生文件必须以 FIRSTBATES 命名。\n\nb. Concordance Image® 或 Opticon 交叉引用文件。图像交叉引用文件（.LOG 或 .OPT）将图像链接至数据库记录。该文件应为以逗号分隔的文件，每行包含七个字段，并且数据库中的每幅图像均应在交叉引用文件中有一行，格式如下：ImageID,VolumeLabel,ImageFilePath,DocumentBreak,FolderBreak,Box Break,PageCoun。\n\nc. 文件文本。文本必须作为独立文本文件提交，而不得作为 .DAT 文件中的字段提交。文本文件的完整路径（OCRPATH）应包含于 .DAT 文件中。建议提供文件级 ANSI 文本文件，并按照 FIRSTBATES/Image Key 命名。提取的文本文件必须位于单独的文件夹中，每个文件夹中的文本文件数量不应超过1,000个文件。文件夹名称中不得有特殊字符（包括逗号）。文本文件必须按文件级别提供。\n\nd. 特定文件类型的原生提交。为充分理解其内容和含义而合理需要以原生格式查看的文件类型，必须以原生格式提交。此类文件包括但不限于电子表格、类似电子表格的文件（Microsoft Excel、逗号分隔值、制表符分隔值等）、Microsoft PowerPoint 或其他特殊演示文件、数据库文件以及音频/视频文件。应提供一幅带有 Bates 编号的分隔页图像，表明存在原生文件，并在 .dat 文件中将原生文件路径作为字段列入。提交的原生文件应以与该文件分隔页相对应的 Bates 编号命名。原生文件应归入以递增方式命名的“NATIVE”目录中，并与图像目录分开。\n\ne. 去重。对于存在完全重复件的每份电子文件，仅提交一份副本。对于电子邮件，应依据由 BCC、Body、CC、From、IntMsgID、To 和 Attach 属性生成的 MD5 哈希值合并重复件。对于电子邮件附件和独立电子文件，应依据整个文件的 MD5 哈希值合并重复件。\n\nf. 元数据。应以符合 Concordance 要求的加载文件（.dat）形式，为每份文件提交提取的元数据。.DAT 文件的第一行必须为标识字段名称的标题行。.DAT 文件必须使用下列 Concordance 默认分隔符：逗号 , ASCII 字符（020）引号 þ ASCII 字符（254）\n\n日期字段应以如下格式提供：mm/dd/yyyy。日期字段和时间字段必须为两个单独的字段。下列为必需元数据：\n\n字段名称　示例数据　说明\n英文>>>\n\nFIRSTBATES　EDC0000001　原生文件文档/电子邮件的首个 Bates 编号\nLASTBATES　EDC0000001　原生文件文档/电子邮件的最后一个 Bates 编号\nLASTBATES 字段应予填写，适用于单页文件\nATTACHRANGE　EDC0000001 至 EDC0000015　母文档首页的 Bates 编号至最后一个附件“子”文档最后一页的 Bates 编号\nBEGATTACH　EDC0000001　附件范围的首个 Bates 编号\nENDATTACH　EDC0000015　附件范围的最后一个 Bates 编号\nCUSTODIAN　Smith, John（约翰·史密斯）　电子邮件：该电子邮件所在的邮箱；原生文件：该文档来源的个人或部门名称\nFROM　John Smith（约翰·史密斯）　电子邮件：发件人；原生文件：文档作者\n多个条目应以分号分隔\nTO　Coffman, Janice（贾尼斯·科夫曼）；LeeW［mailto:LeeW@MSN.com］　收件人\n多个条目应以分号分隔\nCC　Frank Thompson（弗兰克·汤普森）［mailto:frank_Thompson@cdt.com］　抄送收件人\n多个条目应以分号分隔\nBCC　John Cain（约翰·凯恩）　密送收件人\n多个条目应以分号分隔\nSUBJECT　Board Meeting Minutes（董事会会议纪要）　电子邮件：电子邮件主题行；原生文件：文档标题（如有）\nFILE_NAME　BoardMeetingMinutes.docx　原生文件：原始原生文件名称，包括扩展名\nDATE_SENT　10/12/2010　电子邮件：电子邮件发送日期；原生文件：（空）\nTIME_SENT/TIME_ZONE　07:05 PM GMT　电子邮件：电子邮件发送时间/电子邮件标准化所使用时区内的时间\nTIME_ZONE　GMT　在转换过程中电子邮件被标准化所使用的时区。\nLINK　EDC0000001.msg　指向电子邮件或原生文件文档的超链接\n链接文件必须按照 FIRSTBATES 编号命名\nFILE_EXTEN　MSG　表示电子邮件或原生文件的文件类型扩展名\nAUTHOR　John Smith（约翰·史密斯）　电子邮件：（空）；原生文件：文档作者\nDATE_CREATED　10/10/2010　电子邮件：（空）；原生文件：文档创建日期\nCase 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 427 of 439\n\nTIME_CREATED　10:25 AM　电子邮件：（空）；原生文件：文档创建时间\n该数据必须为单独字段，不得与 DATE_CREATED 字段合并\nDATE_MOD　10/12/2010　电子邮件：（空）；原生文件：文档最后修改日期\nTIME_MOD　07:00 PM　电子邮件：（空）；原生文件：文档最后修改时间\n该数据必须为单独字段，不得与 DATE_MOD 字段合并\nDATE_ACCESSD　10/12/2010　电子邮件：（空）；原生文件：文档最后访问日期\nTIME_ACCESSD　07:00 PM　电子邮件：（空）；原生文件：文档最后访问时间\n该数据必须为单独字段，不得与 DATE_ACCESSD 字段合并\nFILE_SIZE　5,952　原生文件文档/电子邮件的大小，单位为 KB\nPGCOUNT　1　原生文件文档/电子邮件中的页数\nPATH　电子邮件：（空）；Agenda.doc　原生文件：储存原生文件文档的路径，包括原始文件名称。\nINTFILEPATH　Personal Folders\\Deleted Items\\Board Meeting Minutes.msg　电子邮件：电子邮件的原始位置，包括原始文件名称；原生文件：（空）\nINTMSGID　<000805c2c71b\\$75977050\\$cb8306d1@MSN>　电子邮件：唯一消息 ID；原生文件：（空）\nMD5HASH　d131dd02c5e6eec4693d9a0698aff95c2fcab58712467eab4004583eb8fb7f89　该文档的 MD5 哈希值。\nOCRPATH　TEXT/001/EDC0000001.txt　原生文件提取文本的路径\n\n3. 每项请求均独立运作且应被独立解释，除非另有说明，任何请求均不限制任何其他请求的范围。\n\n4. 所有文件应按其在日常业务过程中保存的方式提供，或者应予组织和标注，以对应本请求中的类别。\n\n5. 本文件所载的每项请求均延及下列所有文件：(a) 由您占有、保管或控制的文件；或 (b) 由代表您行事的任何人占有、保管或控制的文件，\nCase 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 428 of 439\n\n包括您的律师或其他代表及顾问。每份文件均应完整提供。\n\n6. 如要求您提供一份已不再由您占有、保管或控制的文件，则您的答复必须：(a) 详细描述该文件的性质及其内容；(b) 确定编制或撰写该文件的人员（如适用，亦确定该文件发送给的人员）；(c) 确定该文件编制或创建的日期；(d) 说明该文件是否 (i) 下落不明或遗失，(ii) 已被销毁，(iii) 已自愿或非自愿地转移给他人，或 (iv) 已以其他方式处置；(e) 说明该等处置的原因，以及围绕该等处置的事实和情形；(f) 确定授权该等处置的人员；(g) 确定该等处置的日期或约略日期；(h) 说明该文件最近一次由您占有、保管或控制的时间；以及 (i) 确定目前占有、保管或控制该文件的人员（如有）。\n\n7. 如要求您提供一份已被销毁的文件，则除前述指示所要求的信息外，您的答复还必须说明：(a) 销毁该文件的原因；(b) 销毁该文件的人员身份；以及 (c) 指示销毁该文件的人员身份。\n\n8. 如您主张被请求提供的文件享有特权或属于律师工作成果，则您的答复必须：(a) 说明：(i) 足以支持您主张该文件享有特权的文件描述，(ii) 文件标题，(iii) 文件日期，(iv) 文件作者，(v) 文件收件人，(vi) 收到或阅览该文件原件或任何草稿、副本或复制件的每一人员身份，(vii) 该文件本身或该文件载有或提及的任何信息是否由其他任何人员占有、保管或控制；如是，则确定\nCase 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 429 of 439\n\n该等人员身份，并说明该等信息如何进入其占有范围，(viii) 据以扣留该文件的特权主张，以及 (ix) 您将据以支持该等特权主张的所有情形；以及 (b) 依照 D. Conn. L. Civ. R. 26(e)，就每份基于特权主张而被扣留的文件，制作一份特权清单，其中载明本指示第 (a) 部分所要求的全部信息。\n\n9. 如一份本应提供的文件的一部分含有受特权主张约束的信息，则仅应依照上述指示从该文件中删除或涂黑受特权主张约束的该部分，其余部分应予提供。\n\n10. 本请求具有持续性质。现指示您：(a) 在获知先前答复不完整或不正确时，立即补充或更正任何后来发现不完整或不正确的答复；以及 (b) 提供根据文件请求所要求的任何其他文件。\n\n11. 如一份文件使用英语以外的语言，您应提供该文件。如一份文件使用英语以外的语言，且存在英文译本，您应同时提供两份文件。\n\n12. 对实体的所有提及均包括其所有关联方。\n\n13. 对个人姓名的所有提及均包括所有替代姓名、别名或昵称。\n\n14. 除非另有明确说明，文件请求所涵盖的期间为自 February 5, 2012 起至文件请求答复到期之日止。\nII. 解释规则\n\n15. (a) 任何单数名词的使用应解释为包括复数，反之亦然；以及 (b) 任何时态动词的使用应解释为在所有其他时态中使用该动词。\n\n16. (a) “and”和“or”应在必要时解释为连词或析取连词，以使任何请求涵盖否则可能被解释为不在其范围内的所有答复；以及 (b) “each”和“any”应视为包括并涵盖“every”和“all”二词。\nIII. 定义\n\n经 D. Conn. Bankr. L.R. 2004-1(a) 纳入的 D. Conn. L. Civ. R. 26(c) 所规定的定义，以及 D. Conn. L. Civ. R. 26(d) 所规定的解释规则，适用于文件请求。此外，本文件请求中使用的下列术语具有如下含义：\n\n1. “您”或“您的”或“您本人”系指并包括 Dean M. Rabideau（迪恩·M·拉比多）及其所有代理人、律师、代表、雇员和/或代表其行事的任何人。\n\n2. “债务人”系指 Ho Wan Kwok（郭文贵）（又名 Miles Kwok、Miles Guo、Guo Wengui、Guo Haoyun、郭文贵，或任何其他别名）及其雇员、代理人、律师、顾问或代表其行事的任何人。\n\n3. “债务人之子”系指 Qiang Guo（郭强）（又名 Mileson Kwok、郭强，或任何其他别名）及其雇员、代理人、律师、顾问或代表其行事的任何人。\nCase 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 431 of 439\n\n4. “债务人之女”系指 Mei Guo（郭美）（又名 Mei Gui、郭美，或任何其他别名）及其雇员、代理人、律师、顾问或代表其行事的任何人。\n\n5. “债务人声称的妻子”系指 Hing Chi Ngok（岳庆芝）（又名 Hing Chi Ng、Yue Qingzhi、岳庆芝，或任何其他别名）及其雇员、代理人、律师、顾问或代表其行事的任何人。\n\n6. “债务人家属”系指债务人、债务人之子、债务人之女及债务人声称的妻子，以及与债务人有任何其他亲属关系的任何人，合称为“债务人家属”。\n\n7. “关联个人”系指单独或共同符合下列情形的所有个人：(1) 持有、控制、保管或有权酌情决定债务人或债务人家属拥有、控制或享有的资产；或 (2) 曾为一项或多项关联实体的雇员、董事，或以其他方式与一项或多项关联实体有关联；以及前述各方各自的雇员、代理人、律师、顾问或代表其行事的任何人。该等关联个人包括但不限于：Anthony DiBattista（安东尼·迪巴蒂斯塔）、Alex Hadjicharalambous（亚历克斯·哈吉查拉兰布斯）、Bernardo Enriquez（贝尔纳多·恩里克斯）、Bingshang Jiao（焦冰尚）、Beile Li（李贝乐）、Brian W. Hofmeister（布赖恩·W·霍夫迈斯特）、Charles Gruder（查尔斯·格鲁德）、Daniel Podhaskie（丹尼尔·波德哈斯基）、David Fallon（大卫·法伦）、Defeng Cao（曹德锋）（又名 Wayne Cao、Max Cao）、Ding Lin（丁林）、Dinggang Wang（王定刚）（又名 王定刚）、Eduardo Eurnekian（爱德华多·欧尔内基安）、Ehsan Masud（埃桑·马苏德）、Fiona Yu（俞菲奥娜）、Gladys Chow（周格拉迪斯）、Hao (Gavin) Li（李浩〔加文〕）（又名 Huo Lai）、Hao Haidong（郝海东）（又名 郝海东）、Han Chunguang（韩春光）（又名 韩春光）、Haoran He（何浩然）、Ivan Lin（林艾文）、Haitham Khaled（海赛姆·哈立德）、Jason Miller（杰森·米勒）、Jennifer Mercurio（珍妮弗·默丘里奥）、Jesse Brown（杰西·布朗）、Jessica Mastrogiovanni（杰西卡·马斯特罗焦瓦尼）、Jie Zhang（张杰）、Jintao Li（李金涛）、Karin Maistrello（卡琳·迈斯特雷洛）、Kyle Bass（凯尔·巴斯）、Lihong Wei Lafrenz（魏丽红·拉弗伦茨）（又名 Sara Wei、魏丽红）、Linwan “Irene” Feng（冯林婉“艾琳”）、Max Krasner（马克斯·克拉斯纳）、Melissa Francis（梅丽莎·弗朗西斯）、Michael Baranowitz（迈克尔·巴拉诺维茨）、Min Yang（杨敏）、Melissa Mendez（梅丽莎·门德斯）、Nadeem Akbar（纳迪姆·阿克巴）、Nan Li（李楠）（又名 Chris Lee、Mei Guo Xiao Li）、Qidong Xia（夏启东）、Qu Guojiao（屈国姣）（又名 Qu Guo Jiao、屈国姣）、Ridwan Mamode Saib（里德万·马莫德·赛布）、Ross Heinemeyer（罗斯·海内迈耶）、Rui “Ray” Hao（郝睿“雷”）、Scott Barnett（斯科特·巴内特）、Shih Hsin Yu（俞世新）、Shin Hee-\nCase 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 432 of 439\n\nSeup（申熙燮）（又名 Hee Seup Shin）、Steve Bannon（史蒂夫·班农）、Talha Zobair（塔尔哈·佐拜尔）、Victor Cerda（维克托·塞尔达）、Wen Xiao（肖文）、Wencong Wang（王文聪）、William Gertz（威廉·格茨）、William Je（余建明）（又名 Je Kin Ming、Yu Jianming、余建明）、Xuebing Wang（王学兵）、Ya Li（李娅）（又名 李娅）、Yinying (Aila) Wang（王茵颖〔艾拉〕）（又名 Xiao Fei Xiang）、Yongping Yan（严永平）（Shan Mu）、Yong Yu（俞勇）、Yue Zhou（周跃）、Yumei Hao（郝玉梅）（又名 Ru Shui）、Yvette Wang（王雁平）（又名 Yanping Wang、Yan Ping Wang、王雁平）、Zhang Wei（张魏）（又名 张魏）、Zhouer Wang（王周二）（又名 Joe Wang）、Zhixuan Li（李志轩）及 Ziyang Liu（刘子阳）。\n\n8. “关联实体”系指单独或共同符合下列条件的任何类型的所有组织或实体：(1) 曾由债务人或债务人的家庭成员拥有、控制或投资；或 (2) 对债务人或债务人的家庭成员拥有、控制或享有的任何资产直接或间接享有权益；以及前述任何主体各自的雇员、代理人、律师、顾问或代表其行事的任何人。该等关联实体应包括但不限于：1332156 B.C. Ltd., 7 Nod Hill LLC, AAGV Limited, ACA Investment Management Limited, ACA Capital Group Limited, Ace Decade Holdings Limited, AI Group Holdings Inc., Alfa Global Ventures Limited, Alfonso Global Limited, Allied Capital Global Limited, Alpine Fiduciaries SA, Beijing Pangu Investment Co., Beijing Pangu Investment Co. Ltd., Beijing Pangu Investment Inc., Beijing Zenith Holdings Company Limited, Blue Capital Limited, Booming Sail New York LLC, Bravo Luck Limited, Brent Petro, BSA Strategic Fund I, China Golden Spring (Hong Kong) Limited, Chuang Xin Limited, Crane Advisory Group LLC, Creative Apex Investments Limited, Crystal Breeze Investments Limited, Dawn State Limited, Eastern Profit Corporation Limited, Empire Growth Holdings, Elite Well Global Limited, Freedom Media Ventures Ltd., Fung Wan Trading Inc., G Club, G Club Operations LLC, G Club International Limited, G Club Investments Limited, G Fashion LLC, G-News Operations LLC, G News LLC, GMusic Inc., G-Services LLC, G-Translators PTY LTD, GETTR USA, Inc., Genever Holdings Corporation, Genever Holdings LLC, GFashion Media Group Inc., GFNY, Inc., Globalist International Limited, GNews Media Group Inc., Golden Spring (New York) Ltd., Guo Media, GTV Media Group, Inc., GWGOPNZ Limited, GWGNZ Limited, Gypsy Mei Food Services, LLC, HCHK Property Management Inc., HCHK Technologies Inc., Hamilton Digital Assets FD SP, Hamilton Capital Holdings Inc., Hamilton Opportunity Fund SPC, Head Win Group Limited, Himalaya Embassy, Himalaya Exchange, Himalaya Federal Reserve, Himalaya International Financial Group Ltd., Himalaya Investment LLC, Himalaya (USA) Investment Management LLC, Himalaya New World Inc., Himalaya Supervisory Organization, Himalaya Ventures, Holy City Hong Kong Ventures, Ltd., Hudson Diamond Holding LLC, Hudson Diamond Holding Inc., Hudson Diamond NY LLC, HK International Funds Investments (USA) Limited LLC, Hong Kong International Funds Investments Limited, Huk Trading Inc, Infinite Increase Limited, Infinitum Developments Limited, Japan Himalaya League, Inc., Kalixun Trading Limited, Lamp Capital LLC, Leading Shine Limited, Leading Shine NY Limited, Lexington Property and Staffing Inc., Long Gate Limited, MOS Himalaya Foundation Inc., Maywind Trading LLC, New Federal State of China (a/k/a NFSC), New York MOS Himalaya LLC, New Mulberry PTE Ltd., Newpeople LLC, Noble Fame Global Limited, Pixshow Film Inc., Roscalitar 2, Rosy Acme Ventures Limited, Rule of Law Foundation III, Inc., Rule of Law Society, Rule of Law Society IV, Inc., Santel LLC, Saraca Media Group, Inc., Shiny Ace Ltd., Shiny Times Holdings Ltd., Stevenson, Wong & Co., Taurus Fund LLC, Taurus Fund SP, Taurus Management LLC, The Lost Draft LLC, TM Primrose Limited, UA Himalaya Inc., Voice of Guo Media, Inc., Well Origin Ltd., Wise Creation, Whitecroft Shore Limited, World Century Limited, Worldwide Opportunity Holdings Limited, and ZIBA Limited.\n\n案号 22-50073，文件 3193，提交日期 05/16/24，录入日期 05/16/24 10:28:21，第 433 页，共 439 页\n\n9. “包括”或其任何变体，均指“包括但不限于”。\n\n案号 22-50073，文件 3193，提交日期 05/16/24，录入日期 05/16/24 10:28:21，第 434 页，共 439 页\n\n10. “和”及“或”均指“和/或”，并应为最大限度扩大其范围而按连词和析取词两种方式解释。\n\n11. “任何”及“全部”及“每一”均指“每一及所有”。\n\n12. “每一”及“每个”均指“每一及所有”。\n\n13. “第三方”系指除您本人以外的个人或实体。\n\n14. “转让”应具有《破产法》第 101(54) 条赋予其的含义。\n\n15. “文件”系指属于 Fed. R. Civ. P. 34 范围内的任何信息或物品，并包括但不限于现处于或曾处于您的占有、保管或控制之下的任何种类、类型、性质或描述的每一项书面、记录或图形资料，包括电子邮件的所有打印件和电子副本、以电子形式保存的计算机文件、电子通信、短信、社交媒体帖子、推文、元数据、通信函件、备忘录、磁带、速记或手写笔记、任何种类的书面表格、图表、蓝图、图纸、草图、曲线图、计划、文章、规格说明书、日记、信函、电报、照片、会议记录、合同、协议、调查报告、计算机打印件、任何种类的数据汇编、电传、传真、语音留言、发票、订购单、支票、汇票、对账单、贷项通知单、报告、持仓报告、摘要、索引、账簿、分类账、笔记本、清单、透明胶片、录音录像、目录、广告、宣传材料、影片、录像带、录音带、CD、计算机磁盘、宣传册、小册子、穿孔卡、工时单、推文、社交媒体帖子或任何其他种类的书面或记录材料，以及其全部元数据，无论其以何种方式存储（无论为有形或电子形式）、记录、制作或复制；还包括但不限于前述任何资料的草稿或副本，如其载有原始文件中未有的任何种类的笔记、评论或标记，或在其他方面与原始文件不完全相同。\n\n案号 22-50073，文件 3193，提交日期 05/16/24，录入日期 05/16/24 10:28:21，第 435 页，共 439 页\n\n16. “个人”系指个人、公司、独资企业、合伙企业、协会或任何其他实体。“个人”还包括任何代理人、代表或专家，包括但不限于律师或财务顾问。\n\n17. “实体”系指任何自然人、公司、合伙企业、子公司、独资企业、商号、董事会、合资企业、协会、机构、主管机关、委员会或其他商业实体或法人，以及任何关联方、代理人、母公司，包括但不限于法律顾问、财务顾问或任何其他代表。\n\n18. “关于”系指涉及、描述、构成、提及、与之有关、支持、赞成、反对、强化、削弱、位于其中、结合其加以考虑、对其有影响、证明、表明、报告、记录、暗指、回应、与之相连、评论、就其而言、有关、与之相关、讨论、显示、描述、反映、分析、构成及属于。\n\n19. “与……有关”、“与……相关”或“相关于”任何特定事项时，系指包括但不限于构成、包含、涉及、载有、体现、反映、识别、陈述、直接或间接提及，或以任何方式与所识别的特定事项相关的任何文件。\n\n20. “通信”系指在最广泛可能意义上且不限于此的任何信息或知识传递（以事实、思想、询问或其他形式）。通信还指所有会谈、协议、询问或答复，无论是当面、通过电话、书面方式或通过电子传输装置进行，并包括但不限于所有通信函件、电子邮件、录音录像、传送单、备忘录、电话通信、语音留言、电报、传真、电传、即时消息、聊天、短信、电话笔记，或在内部或与第三方之间传递的笔记。\n\n案号 22-50073，文件 3193，提交日期 05/16/24，录入日期 05/16/24 10:28:21，第 436 页，共 439 页\n\n21. “资产”系指可用于产生正面经济价值的任何项目，包括但不限于由某一实体拥有、控制或为其利益而持有，并预期将提供未来利益的任何具有经济价值的资源，包括但不限于所有不动产和动产、无形财产、投资、投资权或未来收入权、现金、银行账户、商品、证券、请求权、对某一实体的全部或部分控制权以及预期经济机会。\n\n22. “转让”应具有《破产法》第 101(54) 条赋予其的含义。\n\nIV. 应提交的文件\n\n1. 所有涉及债务人、债务人的家庭成员、债务人的破产财团、关联个人或关联实体的任何收入或资产的文件。\n\n2. 所有与债务人的财务状况及其对债权人的义务有关的文件，包括但不限于所有与任何规避支付该等义务的行为有关的文件，以及所有与本次或任何其他实际或潜在的破产或类似无力偿债程序有关的文件。\n\n3. 所有涉及与债务人、债务人的破产财团、债务人的家庭成员、关联实体或关联个人有关的任何资产负债表、银行对账单、账户报表、财务报表、账户结单、电汇指示和/或确认、资金证明、存款证、持仓证明、投资组合摘要或类似文件的文件，包括但不限于足以显示向前述任何主体作出的所有转让的全部文件。\n\n案号 22-50073，文件 3193，提交日期 05/16/24，录入日期 05/16/24 10:28:21，第 437 页，共 439 页\n\n4. 所有涉及由债务人、债务人的家庭成员、关联个人或关联实体作出、与其进行或代表其进行的任何投资、商业交易或交易行为的文件。\n\n5. 与债务人、债务人的家庭成员、关联个人或关联实体进行的所有通信，以及与同债务人、债务人的家庭成员、关联个人或关联实体进行的通信有关的文件，包括与任何实体的运营、管理或决策有关的通信和文件，包括但不限于关联实体。\n\n6. 所有涉及向债务人、债务人的家庭成员、关联个人或关联实体作出、由其作出或与其进行的任何转让、投资或其他交易或商业往来的文件。\n\n7. 所有涉及债务人曾占用或使用过的任何财产的文件，包括但不限于位于 Connecticut（康涅狄格州）Greenwich（格林尼治）373 Taconic Rd. 的住宅物业；位于 Connecticut（康涅狄格州）Greenwich（格林尼治）33 Ferncliff Rd. 的住宅物业；位于 Connecticut（康涅狄格州）Wilton（威尔顿）354 Nod Hill Rd 的住宅物业；位于 United Kingdom（英国）London（伦敦）SW7 1QJ, 5 Princes Gate 的公寓或共管公寓；以及位于 New Jersey（新泽西州）Mahwah（马瓦）675 Ramapo Valley Road, Mahwah, New Jersey 07430 的住宅物业。\n\n8. 所有与债务人拥有、控制或使用的任何航空器有关的文件，包括但不限于：(i) 尾号为 T7-GQM 的航空器及任何其他在 San Marino（圣马力诺）注册的航空器，包括但不限于所有登记文件的副本以及显示该等航空器所执行航班及该等航班机上人员的飞行舱单；及 (ii) 任何 Cirrus SF50 航空器。\n\n案号 22-50073，文件 3193，提交日期 05/16/24，录入日期 05/16/24 10:28:21，第 438 页，共 439 页\n\n9. 所有涉及向债务人、债务人的破产财团、债务人的家庭成员或关联实体提供、由其提供或代表其提供的任何赠与、利益或贷款的文件，包括但不限于足以显示该等赠与、利益或贷款金额；该等赠与、利益或贷款的使用目的；该等赠与、利益或贷款提供的时间；以及任何贷款的条款、就任何贷款作出的全部陈述和保证、任何贷款的利率以及任何贷款的所有付款证据的文件。\n\n10. 与由债务人、代表债务人或为债务人、债务人的遗产、债务人的家庭或关联实体之利益而设立的任何信托或类似文书有关的所有文件，包括但不限于足以显示该等信托何时设立、由谁设立、为谁的利益设立以及信托财产的文件。\n\n11. 与涉及债务人的任何法律争议相关的任何义务、请求权、责任或债务有关的所有文件，包括但不限于与在任何地方、州、联邦或国际机构（无论是行政机构、法院、合议庭或替代性争议解决实体）前进行的任何诉讼有关的文件。\n\n12. 与债务人、债务人的家庭或关联个人之间的所有文件和通信。\n\n13. 您的任何律师或其他顾问与债务人、债务人的家庭或关联个人之间的所有文件和通信。\n\n14. 与您目前或曾经持有权益的任何关联实体有关的所有文件。","key_entities":["Je","Himalaya","Guo","Kwok","Ho Wan Kwok","Despins","HCHK","Miles Guo","Paul Hastings","GTV","Yanping Wang","William Je","Saraca","GETTR","Himalaya Exchange","Kin Ming Je","Luc Despins"],"ecf_references":[{"doc_number":637,"court":"CTB"},{"doc_number":3038,"court":"CTB"}],"word_count":147819,"status":"published","published_at":"2024-05-16 00:00:00","created_at":"2024-05-16","updated_at":"2026-08-24 01:16:23"}