{"id":"court_ctb_839_0","court":"CTB","case_no":"22-50073","doc_number":839,"sub_number":0,"doc_type":"ORDER","filed_date":"2022-09-07","title":"UNITED STATES BANKRUPTCY COURT DISTRICT OF CONNECTICUT BRIDGEPORT DIVISION | -------------------------------------------","summary_zh":null,"summary_en":null,"body_en":"## **UNITED STATES BANKRUPTCY COURT DISTRICT OF CONNECTICUT BRIDGEPORT DIVISION**\n\n| ----------------------------------------------------------- | x | |\n|-------------------------------------------------------------|----------------------------------------|--|\n| In re: | :
:
Chapter 11 | |\n| HO WAN KWOK, | :
:
Case No. 22-50073 (JAM)
: | |\n| Debtor.1 | :
: | |\n| ----------------------------------------------------------- | x | |\n\n## **FIRST 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 LEGAL AND FINANCIAL ADVISORS TO THE DEBTOR, ENTITIES AND INDIVIDUALS AFFILIATED WITH DEBTOR, AND RELEVANT BANKS**\n\nLuc Despins, as the appointed Chapter 11 Trustee to the Debtor's estate (the \"Trustee\"), 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 of the legal, advisory, or accounting firms (the \"Advisors\"), the family members, business associates, and corporate entities (the \"Related Persons\"), and certain banks at which the Trustee believes the Debtor and Related Persons conducted business relevant to the estate (the \"Banks\" and, together with the Advisors and the Related Persons, the \"Examinees\") of the above-captioned debtor (the \"Debtor\"), as such Examinees are identified in **Exhibit B**, attached hereto, in the above-captioned chapter 11 case (the \"Case\"). **Please take notice that the deadline to object to this Application is September 15, 2022, and in the absence of a timely filed objection, the proposed order filed herewith as**\n\n1 Although the Debtor's legal name is Ho Wan Kwok, he is also known as Guo Wengui, Miles Guo, and Miles Kwok, as well as numerous other aliases. The last four digits of the Debtor's taxpayer identification number are 9595.\n\n**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. In authorizing the appointment of a chapter 11 trustee, the Court recognized that one of the trustee's key objectives would be to conduct an \"effective investigation of the Debtor's assets, liabilities, and financial affairs.\" (*See* ECF. No. 465, at 14, hereinafter referred to as the \"Trustee Order\"). Such an investigation is imperative in this case to explore, among other things, the glaring inconsistency between the Debtor's assertion in his schedules that he owns assets valued at only \\$3,850 and the fact that he nevertheless has access to significant funds and resources, including for the purpose of paying his counsel in this case, and continues to live a lavish and luxurious lifestyle as a self-proclaimed billionaire. The Trustee has thus begun an extensive investigation into the Debtor's financial affairs to determine whether, despite the contents of his schedules, there may be significant assets—in the form of real and personal property, equity ownership in other legal entities, litigation claims, and other property interests that constitute property of the estate.\n\n2. To aid this investigation, on July 28, 2022, the Trustee filed three motions to authorize discovery under Bankruptcy Rule 2004, *i.e.*, motions with respect to the Debtor, the Debtor's legal and financial advisors, and entities and individuals believed to be affiliated with or otherwise related to the Debtor. The Court granted these motions, and the Trustee is presently undertaking this Bankruptcy Rule 2004 discovery. As the Trustee's investigation develops, and the Trustee learns the identities of, or relevant facts regarding, additional Advisors and Related Persons, the Trustee seeks to further his investigation by moving to take additional Bankruptcy Rule 2004 discovery with respect to 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. Indeed, the Trustee expects that, to the extent the Debtor has engaged in efforts to hide his wealth through a network of shell companies and otherwise (as the New York Supreme Court has found), the Debtor would likely have needed extensive assistance and counsel from the Advisors and aid and participation by the Related Persons.\n\n4. This Motion is consistent with, and complementary to, the Trustee's prior Bankruptcy Rule 2004 motions and the Court's orders granting same. These additional sources of information will supplement and augment inquiries the Trustee has already begun, as well as open additional avenues of investigation and potential discovery of assets.\n\n## **PROCEDURAL POSTURE**\n\n5. On March 19, 2022, the United States Trustee filed a Motion for an Order Directing the Appointment of an Examiner or, in the alternative, a Motion for Order Directing the Appointment of a Chapter 11 Trustee. (*See* ECF No. 102).\n\n6. On April 6, 2022, Pacific Alliance Asia Opportunity Fund L.P. (\"PAX\") filed a Motion to Dismiss Chapter 11 Case, or in the alternative, Joinder to the United States Trustee's Motion for an Order Directing the Appointment of a Chapter 11 Trustee. (*See* ECF No. 183).\n\n7. On June 15, 2022, this Court issued the Trustee Order.\n\n8. The Trustee Order held, in relevant part that, \"[w]hen balanced against dismissal or conversion, the complexity of the Debtor's financial affairs and lack of independent managerial oversight in this case warrants the appointment of a Chapter 11 trustee who can investigate, identify, and locate the Debtor's assets for the benefit of creditors and the estate\" and further held\n\nthat \"[t]he Chapter 11 trustee shall perform all of the duties set forth in 11 U.S.C. § 1106.\" (*See id.* at 15-16, 18).\n\n9. The Trustee Order further held that \"[t]he appointment of a Chapter 11 trustee will also allow for the effective investigation of the Debtor's assets, liabilities, and financial affairs\" and \"allow[] the Chapter 11 trustee to investigate the Debtor's assets, liabilities, and financial affairs and to ensure compliance with the provisions of the Stipulated Order.\" (*See id.* at 14, 18).\n\n10. On July 7, 2022, a Notice of Appointment of Chapter 11 Trustee was filed by the Office of the United States Trustee appointing Luc Despins as Chapter 11 Trustee of the Debtor's estate. (*See* ECF No. 514).\n\n11. Following his appointment, the Trustee filed three Rule 2004 motions: one with respect to the Debtor (ECF No. 636, the \"Debtor 2004 Motion\"), and two omnibus motions—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\") and one directed at entities and individuals believed to be affiliated with, controlled by, or otherwise connected to the Debtor (the \"Related Persons 2004 Motion,\" and, together with the Debtor 2004 Motion and the Advisors 2004 Motion, collectively, the \"2004 Motions\"). The court entered orders granting the respective 2004 Motions on August 16, 2022 (ECF No. 756, the \"Advisors 2004 Order;\" ECF No. 757, the \"Debtor 2004 Order,\" ECF No. 758, the \"Related Persons 2004 Order,\" and, together with the Advisors 2004 Order and the Debtor 2004 Order, collectively, the \"2004 Orders.\")\n\n## **FACTUAL BACKGROUND**\n\n## **I. Petition and Debtor's Schedules**\n\n12. On February 15, 2022 (the \"Petition Date\"), the Debtor filed a voluntary petition for relief under Chapter 11, Title 11 of the United States Code (the \"Bankruptcy Code\").\n\n13. The Debtor's schedules list aggregate unsecured claims in the amount of approximately \\$374 million (*See* ECF No. 78, at 1, hereinafter referred to as the \"Debtor's Schedules\"). The asserted \\$254 million claim of PAX is the largest single claim identified among the Debtor's scheduled unsecured claims. (*See id.*, Attached Schedule F). The Debtor's Schedules also list a secured claim in an unknown amount purportedly belonging to Golden Spring (New York) Ltd. (\"Golden Spring\"), an entity purportedly owned by the Debtor's son, Qiang Guo (the \"Son\" or \"Qiang\"), allegedly secured by \"[c]ertain claims and recoveries thereto,\" and asserted to have arisen in connection with a \"Litigation Funding Agreement.\" (*See id.*, Attached Schedule D).\n\n14. Despite evidence from prior proceedings demonstrating the Debtor's lavish lifestyle and luxurious accommodations, the Debtor's Schedules list assets of only \\$3,850.2 (*See id.* at 3-7). The Debtor contends that he earns no income, and that his expenses are paid for by Golden Spring (*See id.* at 1; *see also* ECF No. 107 at ¶17, hereinafter referred to as \"Debtor's Declaration\").\n\n## **II. Potential Assets Owned or Controlled by Debtor Not Identified in Schedules**\n\n15. Despite the Debtor's contentions in his Schedules, reports suggest he may own and control significant real and personal property assets in New York and Connecticut, among other locations, the title of which is held by business entities affiliated with the Debtor. Reports further suggest that the Debtor also has a financial interest in myriad for-profit and purported not-for profit entities. The Debtor has been found to display a pattern of manipulating ownership among those various business entities to hide assets, especially through entities owned by family members. (*See* Decision + Order on Motion, *Pacific Alliance Asia Opportunity Fund L.P. v. Ho Wan Kwok*, Index\n\n2 The Debtor has scheduled certain assets with unknown values, including disputed unregistered copyrights and litigation claims. (*See id.*, at 6).\n\nNo. 652077/2017 (N.Y. Sup. Feb. 9, 2022), at 1, hereinafter referred to as the \"Final Contempt Order\" (finding that Debtor engaged \"in efforts to avoid and deceive his creditors by parking his substantial personal assets with a series of corporations, trusted confidants, and family members\" and had \"secreted his assets in a maze of corporate entities and with family members.\")).3\n\n## *a. Controlled Related Entities*\n\n16. Although a thorough investigation is necessary to identify all the various entities over which the Debtor may have ownership or control, the Trustee has reason to believe, based on publicly available information, including findings by other courts, that the Debtor has an extensive network of shell companies he uses to pursue business interests and mask his assets.\n\n17. For example, in June 2021, a \\$1 million dollar judgment was awarded to Eastern Profit Corporation Limited (\"Eastern Profit\"), an entity allegedly controlled by the Debtor's daughter, Mei Guo (\"Daughter\" or \"Mei\"), in a breach of contract action against Strategic Vision US LLC in the United States District Court for the Southern District of New York. (*See* ECF No. 77 at 12-13; *see also Eastern Profit Corp. v. Strategic Vision US LLC*, 2021 U.S. Dist. LEXIS 116334, at \\*98 (S.D.N.Y. June 22, 2021), hereinafter referred to as the \"Eastern Profit Lawsuit\"). In its Findings of Fact and Conclusion of Law issued in connection with the Eastern Profit Lawsuit, the District Court found that Eastern Profit was \"in essence, a shell corporation for\" the Debtor. (*See* the Eastern Profit Lawsuit at \\*4).\n\n18. Other identified entities that the Debtor potentially controls include: (i) Bravo Luck Limited (\"Bravo Luck\"), an entity purportedly owned by the Debtor's Son (*see* Debtor's Declaration, ¶33); (ii) Genever Holdings LLC (\"Genever NY\"), a wholly-owned subsidiary of Genever Holdings Corporation (\"Genever BVI\"), whose equity is held by the Debtor in his\n\n3 The Final Contempt Order is attached as Exhibit A to the *Objection Of Chapter 11 Trustee to Debtor's Motion For Relief From Order Appointing Luc A. Despins as Chapter 11 Trustee* [Docket No. 575].\n\nindividual capacity (*see id.*); (iii) Golden Spring, an entity purportedly controlled by the Debtor's Son (*see id.* at ¶17); (iv) Greenwich Land LLC (\"Greenwich Land\"), an entity purportedly owned by the Debtor's purported wife, Hing Chi Ngok (\"Wife\" or \"Hing\") (*see id.*); (v) Lamp Capital LLC (\"Lamp\"), an entity purportedly owned by the Debtor's Son (*see id.*, ¶51); and (vi) HK International Funds Investment (USA) Limited, LLC (\"HK USA\"), an entity purportedly owned by the Debtor's Daughter (*see id.* at ¶33).\n\n19. The Debtor has stated that these above-listed entities, perhaps along with others, fund the lavish lifestyle the Debtor flaunts to the media and on social media. (*See, e.g.*, *id.,* ¶17 (stating that his Son, through Golden Spring, \"provides for [Debtor's] needs\"); *id.*, ¶ 23 (contending that his Daughter owns the *Lady May*, a luxury yacht allegedly purchased in 2015 for £41 million, and that his Son provides for *Lady May's* maintenance); and *id.*, ¶51 (noting that his Son, through Lamp, funded a \\$1 million retainer for Debtor's initial chapter 11 bankruptcy counsel). The Debtor does not explain, however, how these entities derive their income or what consideration, if any, he provides to these entities in exchange for the funding they provide him.\n\n### *b. Real and Personal Assets Potentially Owned or Controlled by Debtor*\n\n20. In addition to this opaque network of controlled related entities, there are extensive real and personal assets—which the Debtor himself has bragged about owning to the media—that may also be property of the estate.\n\n21. For example, when asked in a 2017 interview whether he had any regrets over how he has fought his campaign against the Chinese Communist Party, Debtor said:\n\n> I have absolutely no regrets for what I have done over the past nine months. I have the *wealthy life that everyone in the world dreams about*. I have the *biggest house in Hong Kong*, thousands of square meters. I have the *most luxurious apartment in London*. I have the *biggest place in Beijing*. I *have more than 10 properties in Pangu*. I have *two private jets*. I have the *most advanced yachts*. I have\n\n*hundreds of race cars*. I have *an apartment like this in New York*. I don't have any material needs anymore.\").\n\n(*See, e.g.,* Vice News, Exiled Chinese Billionaire Uses YouTube to Wage A War On Corruption, YOUTUBE, at 6:38-7:07 (Nov. 15 2017) (emphasis added) (available at http), hereinafter referred to as the \"Vice News Interview\")).4 Notably, the Debtor has never offered a credible explanation of what has become of these assets, or any proceeds from them – a central question the Trustee believes will be answered through the Trustee's investigation, including his examination of the Debtor and the Examinees.\n\n22. Consistent with the Debtor's own admissions, other courts have already found that certain assets are effectively owned by the Debtor, despite his newfound contentions to the contrary in this Case.\n\n23. **The** *Lady May.* Following an evidentiary hearing to determine who held beneficial ownership of the *Lady May*, the New York Supreme Court found the Debtor beneficially owns and controls the *Lady May*. (Final Contempt Order at 9 (\"The evidence clearly and convincingly demonstrates that [Debtor] holds a beneficial interest in and controls the Lady May.\")). Specifically, the court, after considering all of the evidence, including lengthy testimony from the Debtor's daughter and three other witnesses presented by counsel for HK International on behalf of the Debtor, found that \"[t]he testimony adduced at the hearing out of the mouths of defendants' witnesses clearly and convincingly demonstrates that Kwok beneficially owns and controls the Lady May and has utter contempt for this Court and the judicial process.\" (Final Contempt Order at 4). The court went on to state that \"[i]n short, Ms. Guo's testimony that she owns and controls\n\n4 This quote was spoken by Debtor in Chinese and translated into English by Vice News.\n\nthe Lady May cannot be credited in any respect\" and that, \"[n]ot only does Kwok control the yacht, it appears he provided the funds to purchase it and he is the person who principally enjoys the use of the yacht.\" (*Id.* at 6-8).5\n\n24. **The Sherry Netherland Hotel Property**. The Debtor may similarly own and control a condominium in the Sherry Netherland Hotel in Manhattan, allegedly purchased in 2015 for approximately \\$70 million (the \"Condominium\"). The Debtor maintains that the Condominium is owned by Genever NY, and that Genever NY holds the Condominium in trust for his Son through Bravo Luck. (*See* Debtor's Declaration, ¶ 33). As noted, *supra*, Genever NY is itself owned by Genever BVI, an entity owned by the Debtor. (*See id.*).\n\n25. Similar to the *Lady May*, the Condominium became subject to prepetition litigation in the separate chapter 11 bankruptcy that Genever NY filed in October 2020 in the Southern District of New York before the Honorable Judge James L. Garrity Jr. (*See* Case No. 20-12411 (Bankr. S.D.N.Y.)).\n\n26. The Trustee also has reason to believe that a security deposit in an amount of approximately \\$2 million may also remain in connection with the Condominium's acquisition. (*See* ECF No. 77 at 7).\n\n27. **Other Real and Personal Property**. In addition to the foregoing, the Debtor has frequently referenced other significant real and personal property assets that he or his immediate family members own and control. For example:\n\n> The Debtor maintains that his Wife, through Greenwich Land, owns the Debtor's residential property located at 373 Taconic Road, Greenwich, Connecticut 06831.\n\n5 On March 1, 2022, PAX filed a Motion for Entry of an Order Confirming the Inapplicability of the Automatic Stay or, in the Alternative, Relief from the Automatic Stay Pursuant to Section 362(d)(2) of the Bankruptcy Code (ECF No. 57) (the \"PAX Stay Motion\"). The PAX Stay Motion was resolved pursuant to a stipulated order pursuant to which, among other conditions, HK USA agreed to return the *Lady May* to the United States, securing this obligation through the placement \\$37 million in an escrow account. (*See* ECF No. 299). The *Lady May* was returned to the navigable waters of Connecticut in early July 2022.\n\n(*See* Debtor's Declaration, ¶¶ 6, 17). Greenwich Land may also hold ownership rights to another residential property located in Greenwich, Connecticut at 33 Ferncliff Rd.6\n\n- The Debtor has declared that he owns \"billions\" of \"funds and property, including real estate in Hong Kong\" which were frozen in 2019 by the High Court of the Hong Kong Special Administrative Region, Court of First Instance. (Debtor's Declaration, ¶ 17).\n- The Debtor is also a co-plaintiff in litigation in the United Kingdom that involves claims of approximately \\$500 million.7\n- As noted above, in a 2017 interview, the Debtor bragged of owning, among other things, (i) the \"biggest house in Hong Kong,\" (ii) the \"most luxurious apartment in London,\" (iii) the \"biggest place in Beijing,\" (iv) \"more than 10 properties in Pangu,\" (v) two private jets,8 and (vi) \"hundreds of race cars.\"9\n- In particular, the Trustee has ascertained \"tail numbers\" and a serial number potentially associated with private jets used and/or controlled by the Debtor, and, by analyzing public records, has determined the identity of a management company that it is believed has operated and may continue to operate on or more of these aircraft. Further, the Trustee is aware that this management company at one point marketed for sale one of the aircraft that the Debtor has used and may own or control. Sources of funds to operate these aircraft, and any value generated by the aircraft (whether by sale, lease, charter, or otherwise) may shed further light on the Debtor's financial condition.\n- 28. The proposed examinations will help determine whether—and likely confirm—that\n\nthese various property interests are property of the estate. The Trustee further believes that the\n\nDebtor's transactions with respect to these property interests—in particular, the sources of funding\n\n6 *See Supplemental Memorandum of Law of the Official Committee of Unsecured Creditors Addressing the Alternatives of Dismissal, Conversion or the Appointment of a Chapter 11 Trustee*, at 3 [ECF No. 408] (noting \"other potential assets of the estate are two properties in Greenwich, Connecticut (373 Taconic Rd. and 33 Ferncliff Rd.) which [Debtor] claims are owned by [Greenwich Land].\").\n\n7 *See* Approved Judgment dated February 9, 2022, *Kwok Ho Wan & Ors v UBS*, Cl-2020-000345, High Court of Justice of England and Wales Queen's Bench Division Commercial Court, ¶30(i) (\"The principal claim is for some US\\$495 million.\").\n\n8 According to a press report, one of these private jets bears tail number T7-GQM. *See* \"Steve Bannon's Use of Private Jet Linked to Chinese Businessman Could Violate Campaign Finance Law,\" ProPublica, dated Feb. 26, 2020, (available at http) (last visited July 25, 2022).\n\n9 Vice News Interview, at 6:38-7:07 (Nov. 15 2017).\n\nto purchase and maintain them, and any value generated by their use or disposition—may uncover additional assets that may provide value to the estate and are not yet known to the Trustee.\n\n## *c. Debtor's Potential Financial Interests in For-Profit and Purported Not-For Profit Business Entities*\n\n29. In addition to the real and personal property assets that the Debtor may own or control through business entities owned by his family members, the Debtor may also have significant financial or ownership interests (or liabilities) in both for-profit and alleged not-for profit business entities that may provide substantial value to the estate and creditors.\n\n30. For instance, it is reported that the Debtor has a financial interest in Gettr USA, Inc. (\"Gettr\"), a conservative social media platform. (*See* Will Sommer, Adam Rawnsley, A. Suebsaeng, *Trumpworld App Is Bankrolled by Fugitive Chinese Billionaire,* THE DAILY BEAST, http\n\nbillionaire?ref=home (July 5, 2021, 12:19 PM) (last visited July 20, 2022) (reporting that \"sites associated with the billionaire have suggested that Gettr is [Debtor's] brainchild,\" and attributing to a host on GTV, \"a media outlet that serves as a mouthpiece for [Debtor],\" the observation that Gettr was \"'the concentration of [Debtor]'s whole lifework',\" and adding that \"[Debtor] had come up with the idea for Gettr's logo, a torch.\"); *see also* The New York Times: Sway, *Best Of: Jason Miller*, at 30:15-30:35 (July 18, 2022) (downloaded using Apple Podcasts) (When asked who is funding Gettr, Gettr CEO Jason Miller responded, \"We have multiple international investment funds that are putting into this . . . . The family foundation of Miles Kwok is one of the initial funders, one of the initial sponsors of this. There's been over \\$50 million that's [been] put in the\n\nplatform so far. [We] have somewhere [near] \\$25-\\$30 million range that we currently have in the bank.\")).10\n\n31. It has also been reported that Gettr's pay stubs list the same address as the \"Himalaya Embassy,\" a property leased in Manhattan's Upper East Side, that is also associated with the New Federal State of China (the \"NFSC\"), a proclaimed \"government in exile dedicated to overthrow the [Chinese Communist Party]\" created by the Debtor and Steve Bannon, former chief strategist to former President Donald J. Trump. (*See* Dan Friedman, *A Fugitive Chinese Tycoon Met Steve Bannon. Misinformation Mayhem Ensued. The weird, wild, and scary tale of Miles Guo*, Mother Jones (March-April 2022 Issue) (last visited July 21, 2022), http).\n\n32. The Debtor also reportedly owns or controls a \"web of more than 60 commercial, nonprofit, and online groups\" collectively referred to as the \"whistleblower movement.\" (S*ee id.*). At least two of these nonprofits—the Rule of Law Society and the Rule of Law Foundation—are said to fund the NFSC. (S*ee id.*). It has been reported that as of summer 2021 the Rule of Law Society and Rule of Law Foundation had \"combined receipts of about \\$15 million.\" (*Id.*).\n\n33. The Debtor's alleged \"web\" of for-profit and not-for profit commercial interests may also include entities or brands such as (i) \"GCoin,\" a cryptocurrency allegedly created by Debtor to serve as a monetary currency for NFSC; (ii) \"GFashion,\" a clothing line designed by Debtor; (iii) \"GMusic,\" a music platform that promotes Debtor's videos; (iv) \"GClubs,\" a membership service which provides \"'concierge customer service' and special access to [Debtor's] fashion collections, music releases, and an annual GSummit\"; (v) \"GTV,\" a Chinese-language\n\n10 Shortly after this exchange, Miller was careful to distinguish the \"family foundation of Miles Kwok\" with Miles Kwok, himself, saying, \"Mr. Kwok doesn't have any direct financial investment in Gettr,\" instead calling the Debtor an \"ally\" to Gettr. (*See id.* at 30:51-31:11).\n\nvideo platform; (vi) \"GNews,\" a news website that \"runs articles summarizing [Debtor's] pronouncements.\";11 (vii) Saraca Media, the parent company of GNews that also reportedly paid Mr. Bannon at least \\$1 million in consulting fees in May 2018; and (viii) the Himalaya Supervisory Organization, which oversees a number of online chat groups that promote and idolize Debtor, and which offered members of those chat groups \"various mechanisms\" to send Debtor money, including through a loan program which allegedly \"promised eventual repayment with interest and a chance to invest at a discount in other [Debtor] ventures\" and through stock purchases of GTV. (*See id.*). It is alleged that the GTV stock opportunity raised \\$114 million and that the loan program raised \"at least \\$90 million.\" (*See id.*).\n\n34. These are just certain of the business interests and entities that either the Debtor has boasted about, or that have been reported in the media to date. It stands to reason that the Debtor may be affiliated with numerous other entities whose assets, liabilities and financial interests may be critical to the Trustee's administration of the Debtor's estate.\n\n35. Because the Debtor may be the true owner of the aforementioned assets and interests, among other potentially unknown assets and interests, it is critical that the Chapter 11 trustee examine and investigate fully the Debtor's estate assets, including the role that his family members, their business entities, and other third parties, including the law firms representing the Debtor and his affiliated family entities, have with regards to the Debtor's financial positioning.\n\n## **III. Information in Possession of Advisors Regarding Estate Assets**\n\n36. Numerous third parties, including the Debtor's law firms, accountants and financial firms, and brokerage firms have advised or provided services to the Debtor or related entities and\n\n11 *See id*.\n\nindividuals on a number of business deals and other matters concerning assets, liabilities or financial interests potentially relevant to the administration of the Debtor's estate. These Advisors likely have information, based on their communications with the Debtor and work they performed at his or others' requests, that could be of vital importance to the Trustee's investigation.\n\n37. By this Application, the Trustee seeks to discover documents and information from\n\nthe following Advisors:\n\n- **ACASS CANADA LTD.** appears to have provided services to the Debtor and/or Related Persons, including, without limitation, the Debtor's private aircraft. ACASS Canada Ltd. has published on its website a brochure that appears to market for sale, lease, or charter, a private jet that has been described in media reports as being owned by the Debtor. The Trustee is also aware that ACASS Canada Ltd. may have operated or otherwise provided services with respect to this aircraft when it was owned or maintained by the Debtor.\n- **BERKELEY ROWE** represents, according to documents reviewed by the Trustee, Himalaya International Financial Group Ltd., an entity that lent \\$37 million to HK USA, which funds were placed into escrow pursuant to a stipulated order approved by the Court on April 29, 2022 [ECF No. 299]. These documents also show that Berkeley Rowe represented ACA Capital Group Limited, which was intended at one point to be the lender of the \\$37 million to HK USA prior to the execution of HK USA's loan agreement with Himalaya International Financial Group Ltd. In addition, Berkeley Rowe's address was used as the address of the Debtor's son, Qiang Guo, in the proof of claim he filed in the Genever US Chapter 11 Case. Berkeley Rowe is therefore likely to have documents relevant to entities and assets that may constitute property of the estate.\n- **CAHILL GORDON & REINDEL LLP** represented the Debtor and/or certain related entities to the Debtor in connection with an investigation conducted by the Securities and Exchange Commission. Cahill Gordon & Reindel LLP is therefore likely to have documents relevant to the Debtor's financial condition and potential claims against the estate.\n- **ELLIOTT KWOK LEVINE & JAROSLAW LLP** represents Lamp Capital in its capacity as a non-party involved in *Pacific Alliance Asia Opportunity Fund L.P. v. Ho Wan Kwok*, Index No. 652077/2017 (N.Y. Sup. Ct.). This firm was substituted in place of Phillips Nizer LLP – an examinee under the Advisors 2004 Motion – as attorneys of record for Lamp Capital as of May 10, 2022. In that capacity, it may be in possession of documents relevant to the Trustee's investigation.\n- **FORBES HARE** serves as counsel to the Debtor in the British Virgin Islands, where several entities owned by or closely connected to the Debtor, including Genever Holdings Corporation, Ace Decade Holdings Limited, Dawn State Limited, and Bravo Luck\n\nLimited are incorporated. Forbes Hare is therefore likely in possession of documents relevant to the Trustee's investigation.\n\n- **OGIER** serves as British Virgin Islands counsel to the Debtor's son and Bravo Luck Limited, an entity allegedly controlled by the Debtor's son which purports to hold beneficial interests in a condominium in the Sherry Netherland Hotel in Manhattan. Ogier is therefore likely in possession of documents relevant to the Trustee's investigation.\n- **O'NEAL WEBSTER** is former British Virgin Islands counsel to the Debtor's son and Bravo Luck Limited, an entity allegedly controlled by the Debtor's son which purports to hold beneficial interests in a condominium in the Sherry Netherland Hotel in Manhattan. Ogier is therefore likely in possession of documents relevant to the Trustee's investigation.\n- **WILLIAMS & CONNOLLY LLP** assisted the Debtor in connection with the incorporation of Genever BVI and Genever NY in 2015, in connection with the purchase of the Condominium. Williams & Connolly therefore is likely to have documents relevant to corporate entities that may be, or be in possession of, estate property.\n- **TROUTMAN PEPPER HAMILTON SANDERS LLP** serves as counsel to Bravo Luck Limited, an entity allegedly controlled by the Debtor's son which purports to hold beneficial interests in a condominium in the Sherry Netherland Hotel in Manhattan, and served as counsel to Eastern Profit Corporation Limited, which is likely a shell entity of the Debtor. Troutman Pepper Hamilton Sanders LLP is therefore likely in possession of documents relevant to the Trustee's investigation.\n- **YACHTZOO SARL** serves as the yacht management company for the Lady May, a yacht which the New York Supreme Court found the Debtor to beneficially own and controls. *See* Decision + Order on Motion*, Pacific Alliance Asia Opportunity Fund L.P. v. Ho Wan Kwok*, Index No. 652077/2017 (N.Y. Sup. Feb. 9, 2022). Additionally Yachtzoo SARL and HK International Funds Investments (USA) Limited, LLC, an entity purportedly owned by the Debtor's Daughter, have been parties to a management contract with respect to the Lady May since 2021, and Yachtzoo SARL provide financial administration, technical support and management, safety management, and human resources services for the Lady May and its crew members.\n\n38. Most of the Advisors are legal or financial advisors to the Debtor or a closely related\n\nentity, and, thus, are likely to be in possession or control of evidence that may lead to the identification and/or recovery of known and to-be-identified assets of the estate. The other Advisors have provided management and other services, and potentially brokerage services, to the Debtor or closely related entities or family members with respect to major assets, *i.e.*, the *Lady May* and private aircraft that he Debtor has used and as to which the estate may have interests.\n\n## **IV. Information in Possession of Related Persons Regarding Estate Assets**\n\n39. The public record, including court decisions and media reporting, is replete with information regarding members of the Debtor's family, close advisors to the Debtor, and the entities that such individuals purport to control, who have a critical role in the Debtor's commercial activities and other conduct concerning assets, liabilities or financial interests potentially relevant to the administration of the Debtor's estate.\n\n40. By this Application, the Trustee seeks to discover documents and information from\n\nthe following Related Persons:\n\n- **ACA CAPITAL GROUP LIMITED** is an entity represented by Berkeley Rowe that, according to documents in the possession of the Trustee, was originally intended to be the lender of \\$37 million to HK USA but was replaced as lender by Himalaya International Financial Group Ltd. In addition, ACA Capital Group Limited has been linked to the Debtor in other ways, including through the payment of the fees of the Debtor's counsel, Hodgson Russ LLP, in the prepetition litigation between the Debtor and PAX before the New York Supreme Court.\n- **HIMALAYA INTERNATIONAL FINANCIAL GROUP LTD.** is an entity that is publicly linked to the Debtor that lent \\$37 million to HK USA, which funds were placed into escrow pursuant to a stipulated order approved by the Court on April 29, 2022 [Docket 299]. In addition, Himalaya International Financial Group Ltd. has been identified as the issuer of a cryptocurrency called \"Himalaya Coin\" or \"H-Coin\" that has been heavily promoted by the Debtor on the internet. Himalaya International Financial Group Ltd.'s issuance of Himalaya Coin has been carried out through a business relationship with **Himalaya International Clearing Ltd.,** the entity that issues the related \"Himalaya Dollar\" cryptocurrency and whose chief executive has been identified as **Jesse Brown.** In addition, the Trustee believes that the **Himalaya International Payments Ltd.** and **Himalaya International Reserves Ltd**. entities are also involved in this cryptocurrency business.\n- **WILLIAM JE** is an individual who is reported to be a current or former business partner of the Debtor, including in connection with the Debtor's Himalaya Coin cryptocurrency enterprise.\n\n **MAX KRASNER** is an individual associated with several entities linked to the Debtor. Among other things, Mr. Krasner incorporated GTV Media Group Inc. in Delaware in April 2020 and is a current or former officer and director of Rule of Law Foundation III, Inc. a purported non-profit entity linked to the Debtor.\n\n## **V. Information in Possession of Relevant Banks**\n\n41. It has been reported to the Trustee that the Debtor, along with entities and individuals linked to the Debtor, have done business at multiple banking institutions, which may include the Related Persons and transactions described in this Application. The Trustee thus believes that these banking institutions 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. These Banks are:\n\n- **BARCLAYS BANK PLC**\n- **BNY MELLON, N.A.**\n- **CITIBANK, N.A.**\n- **HSBC HOLDINGS PLC**\n- **JPMORGAN CHASE BANK, N.A.**\n- **STANDARD CHARTERED PLC**\n- **UBS AG**\n\n## **JURISDICTION AND VENUE**\n\n42. The Court has jurisdiction to entertain this application under 28 U.S.C. §§ 157 and\n\n1334. Venue to hear this Application is proper in accordance with 28 U.S.C. §§ 1408 and 1409.\n\n43. This Application is a core proceeding pursuant to, *inter alia*, 28 U.S.C. § 157(b)(2)\n\n(A), (E), and (F).\n\n### **RELIEF REQUESTED**\n\n44. 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\n45. 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\n46. \"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\n47. 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\n48. The areas for initial inquiry pursuant to the requested examinations of the Examinees are readily apparent. Based on all the facts and evidence discussed above—including the Debtor's own numerous public statements and past findings by other courts—the Trustee has already identified various corporate entities and real and personal property assets of the Debtor that may provide significant value to the estate. The Trustee needs, however, the investigative tools afforded by Rule 2004 to further establish the true ownership of these assets and to explore other potential assets about which the Trustee does not yet have knowledge.\n\n49. 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 hereto12 and made a part hereof (the \"Proposed Subpoenas\"), within thirty (30) 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.13\n\n12 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-25** the individualized Proposed Subpoenas, including the topics for discovery directed to each Examinee, which are substantially similar in form and substance.\n\n13 The *Lady May* is among the topics and potential estate assets with respect to which the Trustee seeks discovery. The Trustee submits that such discovery is appropriate pursuant to Rule 2004 even though an adversary proceeding with respect to the ownership of the *Lady May* is presently pending. The Trustee's proposed discovery related to the\n\n50. 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\n51. The Trustee submits that the facts set forth above constitute sufficient cause for the Court to order the production of documents pursuant to Rule 2004 from the Examinees. Although the Debtor is a necessary source of information and documents to help the Trustee uncover estate assets, seeking discovery from other parties, including the Examinees, is likely to significantly reduce the costs the estate would otherwise incur in identifying and recovering estate property. Indeed, lawyers and other professionals are uniquely positioned to have information concerning asset transfers, legal entity formation and other corporate governance issues, and the Debtor's financial condition. Accordingly, documents in the possession of the Examinees could be among the most valuable to the Trustee's investigation.\n\n52. 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\n\n*Lady May* relates to the overall pattern of conduct by the Debtor to evade his creditors and is therefore broader than discovery that will likely be sought in the adversary proceeding. It is also more efficient for all parties for the Trustee to take this discovery now given that the Trustee is otherwise seeking Rule 2004 discovery from the same parties on other topics—it would be inefficient for the Trustee to have to take discovery from these same parties twice. Moreover, this is not the classic situation where an adversary plaintiff, through Rule 2004, seeks to undermine the protections provided by the Bankruptcy Rules governing discovery in adversary proceedings. In fact, the pending proceeding doctrine, if it would apply at all (it does not) would not prevent the Trustee from seeking Rule 2004 discovery from individuals or entities who are not parties to the adversary proceeding concerning the *Lady May*. Finally, given the procedural posture of the adversary proceeding, the Trustee may not be able to obtain discovery in that proceeding at present. The Trustee needs its Rule 2004 discovery now, however, to adequately protect and preserve potential assets of the estate.\n\nDebtor'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\n53. No party in interest, including the Debtor, shall suffer undue prejudice upon the granting of the relief sought in this Application.\n\n## **NO PRIOR REQUEST**\n\n54. No prior application for the relief requested herein has been made. The Debtor filed the prior 2004 Motions, which the Court granted, however, those prior motions did not request to take discovery from the Examinees at issue here.\n\n### **OBJECTION DEADLINE**\n\n55. The deadline to object to this Application is **September 15, 2022**, and in the absence of a timely filed objection, the Proposed Order may enter without further notice and hearing.\n\n*[The rest of this page is intentionally blank.]*\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\nDated: September 7, 2022 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## **Exhibit A – Proposed Order**\n\n## **UNITED STATES BANKRUPTCY COURT DISTRICT OF CONNECTICUT BRIDGEPORT DIVISION**\n\n| ----------------------------------------------------------- | x |\n|-------------------------------------------------------------|-----------------------------------|\n| In re: | :
:
Chapter 11 |\n| HO WAN KWOK, | :
:
Case No. 22-50073 (JAM) |\n| Debtor.1 | :
:
: |\n\n#### ---------------------------------------------------------- x **[PROPOSED] ORDER**\n\n## **GRANTING FIRST 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 LEGAL AND FINANCIAL ADVISORS TO THE DEBTOR, ENTITIES AND INDIVIDUALS AFFILIATED WITH DEBTOR, AND RELEVANT BANKS**\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. 637), 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-25 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 30 days of the service of the Subpoena, or such other time as agreed upon by the Trustee. To the extent an Examinee does 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.\n\n1 Although the Debtor's legal name is Ho Wan Kwok, he is also known as Guo Wengui, Miles Guo, and Miles Kwok, as well as numerous other aliases. The last four digits of the Debtor's taxpayer identification number are 9595.\n\n45(e)(2), made applicable by Fed. R. Bankr. P. 9016, and D. Conn. L. Civ. R. 26(e), within 30 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 & Montheith, 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: \\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_, 2022\n\nJulie A. Manning,\n\n\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\n\nUnited States Bankruptcy Judge\n\n**Exhibit B – List of Examinees**\n\n| Discovery Party | Address | Subpoena Index |\n|------------------------------------------------------|------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|----------------|\n| HIMALAYA
INTERNATIONAL
FINANCIAL GROUP
LTD. | Himalaya International Financial Group Ltd
c/o Arias, Fabrega & Fabrega
Trust Co. BVI
Limited
P.O. Box 985
Road Town, Tortola, BVI | Exhibit C-1 |\n| HIMALAYA
INTERNATIONAL
CLEARING LTD. | Himalaya International Clearing Ltd.
c/o Commerce House
Wickhams Cay 1
P.O. Box 3140
Road Town
Tortola VG1110 British Virgin Islands | Exhibit C-2 |\n| HIMALAYA
INTERNATIONAL
PAYMENTS LTD | Himalaya International Payments Ltd.
c/o Commerce House
Wickhams Cay 1
P.O. Box 3140
Road Town
Tortola VG1110 British Virgin Islands | Exhibit C-3 |\n| HIMALAYA
INTERNATIONAL
RESERVES LTD. | Himalaya International Reserves Ltd.
c/o Commerce House
Wickhams Cay 1
P.O. Box 3140
Road Town
Tortola VG1110 British Virgin Islands | Exhibit C-4 |\n| JESSE BROWN | Jesse Brown
c/o Arias, Fabrega & Fabrega Trust Co. BVI
Limited
P.O. Box 985
Road Town, Tortola, BVI
Jesse Brown
c/o Commerce House,
Wickhams Cay 1
P.O. Box 3140
Road Town
Tortola VG1110 British Virgin Islands | Exhibit C-5 |\n| ACA CAPITAL GROUP
LIMITED | ACA Capital Group Limited
Rm 1605, 16/F
Hua Qin International Bldg,
340 Queen's Rd C,
Sheung Wan,
Hong Kong SAR
ACA Capital Group Limited
3a Montagu Row
Marylebone | Exhibit C-6 |\n\n| Discovery Party | Address | Subpoena Index |\n|-------------------|------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|----------------|\n| | London
W1U 6DZ United Kingdom | |\n| WILLIAM JE | William Je
162 East 64th Street
New York, NY 10065
William Je
c/o Corporate Creations Network Inc.
3411 Silverside Road
Tatnall
Building, Ste 104
Wilmington, Delaware 19810 | Exhibit C-7 |\n| MAX KRASNER | Max Krasner
162 E. 64th Street
New York, NY 10605 | Exhibit C-8 |\n| ACASS CANADA LTD. | ACASS Canada Ltd.
6700 Côte de Liesse
Suite 206
Montréal H4T 2B5 Canada | Exhibit C-9 |\n| YACHTZOO SARL | Yachtzoo SARL
Le Beau Rivage
9 Avenue d'Ostende
MC 98000 Monaco | Exhibit C-10 |\n| BERKELEY ROWE | Berkeley Rowe Limited
20 North Audley Street
Mayfair, London W1k 6WE United Kingdom
Geoffrey Yussouf
Berkeley Rowe Limited
5 Merchant Square
London, W2 1AY United Kingdom | Exhibit C-11 |\n\n| Discovery Party | Address | Subpoena Index |\n|------------------------------------------|----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|----------------|\n| CAHILL GORDON &
REINDEL LLP | Cahill Gordon & Reindel LLP
32 Old Slip
New York, NY 10005 | Exhibit C-12 |\n| ELLIOTT KWOK
LEVINE & JAROSLAW
LLP | Matthew Levine, Esq.
Elliott Kwok Levine & Jaroslaw LLP
565 Fifth Avenue
New York, NY 10017 | Exhibit C-13 |\n| WILLIAMS & CONNOLLY
LLP | Jerry Shulman, Esq.
Williams & Connolly LLP
680 Maine Avenue SW
Washington, DC 20024 | Exhibit C-14 |\n| TROUTMAN PEPPER
HAMILTON SANDERS LLP | Francis J. Lawall, Esq.
Troutman Pepper Hamilton Sanders LLP
3000 Two Logan Square
Philadelphia, PA 19103
Joanna J. Cline, Esq.
Troutman Pepper Hamilton Sanders LLP
3000 Two Logan Square
Philadelphia, PA 19103 | Exhibit C-15 |\n| FORBES HARE | Robert Nader
Forbes Hare
Qwomar Building
4th Floor
Blackburn Highway
Road Town,
Tortola
British Virgin Islands
VG1110 | Exhibit C-16 |\n| OGIER | Ogier
Ritter House
Wickhams Cay II
PO Box 3170
Road Town, Tortola
British Virgin Islands VG1110 | Exhibit C-17 |\n\n| Discovery Party | Address | Subpoena Index |\n|-------------------|--------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|----------------|\n| O'NEAL WEBSTER | O'Neal Webster
Commerce House
181 Main Street
P.O. Box 961
Road Town, Tortola
British Virgin Islands
VG1110 | Exhibit C-18 |\n| BARCLAYS BANK PLC | Barclays Bank PLC
c/o Corporation Service Company
251 Little Falls Drive
Wilmington, DE 19808
Paul H. Compton
Barclays Bank PLC
1 Churchill Place
London, Greater London E14 5HP
United Kingdom | Exhibit C-19 |\n| BNY MELLON, N.A. | Jane Kevin McCarthy
BNY Mellon, N.A.
BNY Mellon Center
500 Grant Street
Pittsburgh, PA 15219 | Exhibit C-20 |\n| CITIBANK, N.A. | Citibank, N.A.
c/o The Corporation Trust Company
Corporation Trust Center
1209 Orange Street
Wilmington, DE 19801
Citibank, N.A.
c/o CT Corporation System
28 Liberty Street
New York, NY 10005
Brent J. McIntosh
Citibank, N.A.
388 Greenwich Street
New York, NY 10013 | Exhibit C-21 |\n| HSBC HOLDINGS PLC | HSBC Holdings PLC
c/o The Corporation Trust, Incorporated
2405 York Road, Suite 201
Lutherville Timonium, MD 21093
HSBC Holdings PLC
c/o Office of the General Counsel
95 Washington Street
Buffalo, NY 14203 | Exhibit C-22 |\n\n| Discovery Party | Address | Subpoena Index |\n|------------------------------|-------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|----------------|\n| | Mark A. Steffensen
HSBC Holdings PLC
452 Fifth Avenue
New York, NY 10018 | |\n| JPMORGAN CHASE
BANK, N.A. | JPMorgan Chase Bank, N.A.
c/o CT Corporation System
4400 Easton Commons Way
Suite 125
Columbus, OH 43219
Stacey Friedman
JPMorgan Chase Bank, N.A.
1111 Polaris Parkway, Suite 0460
Columbus, OH 43240
JPMorgan Chase Bank, N.A. | Exhibit C-23 |\n| STANDARD
CHARTERED PLC | Standard Chartered PLC
1095 Avenue of the Americas
New York, NY 10036 | Exhibit C-24 |\n| UBS AG | UBS AG
Hong Kong Branch
52/F., Two International Finance Centre
8 Finance Street
Central, Hong Kong | Exhibit C-25 |\n\n## **Exhibits C-1 to C-25 – Subpoenas and Document Requests to Examinees**\n\n## **Exhibit C-1**\n\nB2540 (Form 2540 – Subpoena for Rule 2004 Examination) (12/15) Case 22-50073 Doc 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 34 of 491\n\n# UNITED STATES BANKRUPTCY COURT\n\n\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_ District of \\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_ Connecticut\n\nIn re \\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\n\nCase No. \\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_ Ho Wan Kwok 22-50073\n\nDebtor\n\nChapter \\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_ 11\n\n## **SUBPOENA FOR RULE 2004 EXAMINATION**\n\nTo: **\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_** Himalaya International Financial Group 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| Paul Hastings LLP
200 Park Avenue
New York, New York 10166 | |\n\nThe examination will be recorded by this method: \\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_ court reporter/stenographer\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: September \\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_ \\_\\_, 2022\n\nCLERK OF COURT\n\nOR\n\n\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_ *Signature of Clerk or Deputy Clerk* \\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_ *Attorney's signature* Patrick R. Linsey (ct29437)\n\nThe name, address, email address, and telephone number of the attorney representing *(name of party)* \\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_ , who issues or requests this subpoena, are: Luc Despins, Ch. 11 Trustee\n\nPatrick R. Linsey, Esq.; Neubert, Pepe & Monteith, P.C.; 195 Church Street, New Haven, Connecticut 06510 plinsey@npmlaw.com; 203-821-2000\n\n## **Notice to the person who issues or requests this subpoena**\n\nIf this subpoena commands the production of documents, electronically stored information, or tangible things, or the inspection of premises before trial, a notice and a copy of this subpoena must be served on each party before it is served on the person to whom it is directed. Fed. R. Civ. P. 45(a)(4).\n\n## **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 following 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
- | 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
time
zone
in
which
the
emails
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 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, including 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\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 Himalaya International Financial Group 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\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. \"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: Daniel Podhaskie, Jason Miller, Steve Bannon, Karin Maistrello, Melissa Francis, William Gertz, Arethusa Forsyth, Glenn Mellor, Jennifer Mercurio, Eduardo Eurnekian, Han Chunguang (a/k/a 韩春光), Qu Guojiao (a/k/a Qu Guo Jiao, 屈国姣), Guo Lijie (a/k/a 郭丽杰), Zhang Wei (a/k/a 张伟\\*), Lihong Wei Lafrenz (a/k/a Sara Wei, 魏丽红), Hao Haidong (a/k/a 郝海东), Ross Heinemeyer, Max Krasner, Kyle Bass, Melissa Mendez, Ya Li (a/k/a 李娅), Dinggang Wang (a/k/a 王定刚), An Hong (a/k/a 安红), Yvette Wang (a/k/a Yanping Wang, Yan Ping Wang, 王雁平), Fiona Yu, Je Kin Ming (a/k/a William Je, Yu Jianming, 余建明 ), Yaz Qingua, and Lao Jiang (a/k/a Jiang Yunfu, Jiang Yunfu Be, 姜云浮).\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: 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, Assets Sino Limited, Auspicious Coast Limited, Beijing Pangu Investment Co., Beijing Pangu Investment Co. Ltd., Beijing Pangu Investment Inc., Beijing Zenith Holdings Company Limited, Bravo Luck Limited, 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, Elite Well Global Limited, Empire Growth Holdings, G Club Operations LLC, G Fashion LLC, G News LLC, GETTR USA, Genever Holdings Corporation, Genever Holdings LLC, GFASHION MEDIA GROUP INC., GFNY, Inc., Globalist International Limited, GNews Media Group Inc., Golden Spring (New York) Ltd., Greenwich Land LLC, Guo Media, GTV Media Group, Inc., Hamilton Capital Holdings Inc., Head Win Group Limited, Henan Yuda, Himalaya Embassy, Himalaya Exchange, Himalaya Federal Reserve, Himalaya Supervisory Organization, HK International Funds Investments (USA) Limited LLC, Hong Kong International Funds Investments Limited, Infinite Increase Limited, Infinitum Developments Limited, Insight Phoenix Fund, Lamp Capital LLC, Leading Shine Limited, Leading Shine NY Limited, Long Gate Limited, Next Tycoon Investments Limited, New Federal State of China (a/k/a NFSC), Noble Fame Global Limited, Rosy Acme Ventures Limited, Rule of Law Foundation III, Inc., Rule of Law Foundation IV, Inc., Rule of Law Fund, Rule of Law Society, Rule of Law Society IV, Inc., G-Translators PTY LTD, Saraca Media Group, Inc., Shiny Ace Ltd., Shiny Times Holdings Ltd., Spirit Charter Investment Limited, Stevenson, Wong & Co., Voice of Guo Media, Inc., Well Origin Ltd., World Century Limited, Worldwide Opportunity Holdings Limited, Whitecroft Shore 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\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\n\ncompilations 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\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,\n\nembodies, 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, 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 estate, 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\n\nobligations 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\n4. All Documents regarding any investment, business dealing or transactions made by, with, or on behalf of the Debtor.\n\n5. All Communications with the Debtor, and Documents related to Communications with the Debtor, 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, or an Associated Entity.\n\n7. All Documents regarding any property ever occupied or used by the Debtor, including without limitation the *Lady May*; the Sherry Netherland Hotel / Condominium; the residential property located in Greenwich, Connecticut at 373 Taconic Rd.; the residential property located in Greenwich, Connecticut at 33 Ferncliff Rd.; and the residential property located in Wilton, Connecticut at 354 Nod Hill Rd.\n\n8. All Documents related to any investments or trading by the Debtor, the Debtor's Family, or an Associated Entity, in or around July 2020, or at any other time, in crude oil futures\n\nor any similar commodity, including without limitation Communications with Jiang Yunfu Be regarding any such investments or trading.\n\n9. All Documents related to any aircraft owned, controlled, or used by the Debtor, including without limitation 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.\n\n10. 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\n11. 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\n12. 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\n13. All Documents and communications between any of your outside counsel or other advisors and the Debtor.\n\n14. Documents sufficient to show all of Your Assets and sources of income or funding.\n\n15. For all Assets identified in response to Request 14 having a value of more than \\$50,000, all (i) Documents related to Your acquisition of such Asset and (ii) Communications with the Debtor or the Debtor's Family regarding such Asset.\n\n16. Copies of Your tax returns.\n\n17. Documents sufficient to show all bank accounts and investment accounts within Your possession or control, including the balances of and transfers to and from each such account.\n\n18. All Documents regarding any credit cards used by You, including without limitation monthly statements or other Documents sufficient to show all purchases related thereto for the benefit of the Debtor or an Associated Entity.\n\n19. All corporate governance and organizational Documents, including without limitation by-laws and certificates of incorporation and other Documents sufficient to show Your corporate structure, names of officers and directors, business purpose, and relationship to the Debtor or to any member of the Debtor's Family.\n\n20. All Documents related to any pledge(s) of Your Assets to any other Entity.\n\n| | | PROOF OF SERVICE
(This section should not be filed with the court unless required by Fed. R. Civ. P. 45.) |\n|------------------------|------------------------------------------------------------------------------------------------|----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|\n| on (date) __________ . | | I received this subpoena for (name of individual and title, if any): ______________________________________________ |\n| | | I served the subpoena by delivering a copy to the named person as follows: ____________________________________ |\n| | __________________________________ on (date) ___________________ ; or | ___________________________________________________________________________________________________ |\n| | | I returned the subpoena unexecuted because: ____________________________________________________________
___________________________________________________________________________________________________ |\n| | My fees are \\$ _________ for travel and \\$_________ for services, for a total of \\$_________ . | Unless 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| | I declare under penalty of perjury | that this information is true and correct. |\n| Date: _______________ | | |\n| | | ________________________________________________
Server's signature |\n| | | ________________________________________________
Printed name and title |\n| | | ________________________________________________
Server's address |\n\nAdditional information concerning attempted service, etc.:\n\n### **Federal Rule of Civil Procedure 45(c), (d), (e), and (g) (Effective 12/1/13) (made applicable in bankruptcy cases by Rule 9016, Federal Rules of Bankruptcy Procedure)**\n\n#### **(c) Place of compliance.**\n\n*(1) For a Trial, Hearing, or Deposition.* A subpoena may command a person to attend a trial, hearing, or deposition only as follows:\n\n(A) within 100 miles of where the person resides, is employed, or regularly transacts business in person; or\n\n(B) within the state where the person resides, is employed, or regularly transacts business in person, if the person\n\n(i) is a party or a party's officer; or\n\n(ii) is commanded to attend a trial and would not incur substantial expense.\n\n#### *(2) For Other Discovery.* A subpoena may command:\n\n(A) production of documents, or electronically stored information, or things at a place within 100 miles of where the person resides, is employed, or regularly transacts business in person; and\n\n(B) inspection of premises, at the premises to be inspected.\n\n#### **(d) Protecting a Person Subject to a Subpoena; Enforcement.**\n\n*(1) Avoiding Undue Burden or Expense; Sanctions.* A party or attorney responsible for issuing and serving a subpoena must take reasonable steps to avoid imposing undue burden or expense on a person subject to the subpoena. The court for the district where compliance is required must enforce this duty and impose an appropriate sanction which may include lost earnings and reasonable attorney's fees — on a party or attorney who fails to comply.\n\n#### *(2) Command to Produce Materials or Permit Inspection.*\n\n*(A) Appearance Not Required.* A person commanded to produce documents, electronically stored information, or tangible things, or to permit the inspection of premises, need not appear in person at the place of production or inspection unless also commanded to appear for a deposition, hearing, or trial.\n\n*(B) Objections*. A person commanded to produce documents or tangible things or to permit inspection may serve on the party or attorney designated in the subpoena a written objection to inspecting, copying, testing or sampling any or all of the materials or to inspecting the premises — or to producing electronically stored information in the form or forms requested. The objection must be served before the earlier of the time specified for compliance or 14 days after the subpoena is served. If an objection is made, the following rules apply:\n\n(i) At any time, on notice to the commanded person, the serving party may move the court for the district where compliance is required for an order compelling production or inspection.\n\n(ii) These acts may be required only as directed in the order, and the order must protect a person who is neither a party nor a party's officer from significant expense resulting from compliance.\n\n#### *(3) Quashing or Modifying a Subpoena.*\n\n*(A) When Required.* On timely motion, the court for the district where compliance is required must quash or modify a subpoena that:\n\n(i) fails to allow a reasonable time to comply; (ii) requires a person to comply beyond the geographical limits\n\nspecified in Rule 45(c); (iii) requires disclosure of privileged or other protected matter, if no\n\nexception or waiver applies; or\n\n(iv) subjects a person to undue burden.\n\n*(B) When Permitted.* To protect a person subject to or affected by a subpoena, the court for the district where compliance is required may, on motion, quash or modify the subpoena if it requires:\n\n(i) disclosing a trade secret or other confidential research, development, or commercial information; or\n\n(ii) disclosing an unretained expert's opinion or information that does not describe specific occurrences in dispute and results from the expert's study that was not requested by a party.\n\n*(C) Specifying Conditions as an Alternative.* In the circumstances described in Rule 45(d)(3)(B), the court may, instead of quashing or modifying a subpoena, order appearance or production under specified conditions if the serving party:\n\n(i) shows a substantial need for the testimony or material that cannot be otherwise met without undue hardship; and\n\n(ii) ensures that the subpoenaed person will be reasonably compensated.\n\n#### **(e) Duties in Responding to a Subpoena.**\n\n*(1) Producing Documents or Electronically Stored Information.* These procedures apply to producing documents or electronically stored information:\n\n*(A) Documents.* A person responding to a subpoena to produce documents must produce them as they are kept in the ordinary course of business or must organize and label them to correspond to the categories in the demand.\n\n*(B) Form for Producing Electronically Stored Information Not Specified.* If a subpoena does not specify a form for producing electronically stored information, the person responding must produce it in a form or forms in which it is ordinarily maintained or in a reasonably usable form or forms.\n\n*(C) Electronically Stored Information Produced in Only One Form.* The person responding need not produce the same electronically stored information in more than one form.\n\n*(D) Inaccessible Electronically Stored Information.* The person responding need not provide discovery of electronically stored information from sources that the person identifies as not reasonably accessible because of undue burden or cost. On motion to compel discovery or for a protective order, the person responding must show that the information is not reasonably accessible because of undue burden or cost. If that showing is made, the court may nonetheless order discovery from such sources if the requesting party shows good cause, considering the limitations of Rule 26(b)(2)(C). The court may specify conditions for the discovery.\n\n### *(2) Claiming Privilege or Protection.*\n\n*(A) Information Withheld.* A person withholding subpoenaed information under a claim that it is privileged or subject to protection as trial-preparation material must:\n\n(i) expressly make the claim; and\n\n(ii) describe the nature of the withheld documents, communications, or tangible things in a manner that, without revealing information itself privileged or protected, will enable the parties to assess the claim.\n\n*(B) Information Produced.* If information produced in response to a subpoena is subject to a claim of privilege or of protection as trialpreparation material, the person making the claim may notify any party that received the information of the claim and the basis for it. After being notified, a party must promptly return, sequester, or destroy the specified information and any copies it has; must not use or disclose the information until the claim is resolved; must take reasonable steps to retrieve the information if the party disclosed it before being notified; and may promptly present the information under seal to the court for the district where compliance is required for a determination of the claim. The person who produced the information must preserve the information until the claim is resolved.\n\n**(g) Contempt.** The court for the district where compliance is required – and also, after a motion is transferred, the issuing court – may hold in contempt a person who, having been served, fails without adequate excuse to obey the subpoena or an order related to it.\n\nFor access to subpoena materials, see Fed. R. Civ. P. 45(a) Committee Note (2013)\n\n…\n\n## **Exhibit C-2**\n\nB2540 (Form 2540 – Subpoena for Rule 2004 Examination) (12/15) Case 22-50073 Doc 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 53 of 491\n\n# UNITED STATES BANKRUPTCY COURT\n\n\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_ District of \\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_ Connecticut\n\nIn re \\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\n\nCase No. \\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_ Ho Wan Kwok 22-50073\n\nDebtor\n\nChapter \\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_ 11\n\n## **SUBPOENA FOR RULE 2004 EXAMINATION**\n\nTo: **\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_** Himalaya International Clearing 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| Paul Hastings LLP
200 Park Avenue
New York, New York 10166 | |\n\nThe examination will be recorded by this method: \\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_ court reporter/stenographer\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: September \\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_ \\_\\_, 2022\n\nCLERK OF COURT\n\nOR\n\n\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_ *Signature of Clerk or Deputy Clerk* \\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_ *Attorney's signature* Patrick R. Linsey (ct29437)\n\nThe name, address, email address, and telephone number of the attorney representing *(name of party)* \\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_ , who issues or requests this subpoena, are: Luc Despins, Ch. 11 Trustee\n\nPatrick R. Linsey, Esq.; Neubert, Pepe & Monteith, P.C.; 195 Church Street, New Haven, Connecticut 06510 plinsey@npmlaw.com; 203-821-2000\n\n## **Notice to the person who issues or requests this subpoena**\n\nIf this subpoena commands the production of documents, electronically stored information, or tangible things, or the inspection of premises before trial, a notice and a copy of this subpoena must be served on each party before it is served on the person to whom it is directed. Fed. R. Civ. P. 45(a)(4).\n\n## **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 following 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
- | 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
time
zone
in
which
the
emails
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 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, including 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\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 othertenses.\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 Himalaya International Clearing 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\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. \"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: Daniel Podhaskie, Jason Miller, Steve Bannon, Karin Maistrello, Melissa Francis, William Gertz, Arethusa Forsyth, Glenn Mellor, Jennifer Mercurio, Eduardo Eurnekian, Han Chunguang (a/k/a 韩春光), Qu Guojiao (a/k/a Qu Guo Jiao, 屈国姣), Guo Lijie (a/k/a 郭丽杰), Zhang Wei (a/k/a 张伟\\*), Lihong Wei Lafrenz (a/k/a Sara Wei, 魏丽红), Hao Haidong (a/k/a 郝海东), Ross Heinemeyer, Max Krasner, Kyle Bass, Melissa Mendez, Ya Li (a/k/a 李娅), Dinggang Wang (a/k/a 王定刚), An Hong (a/k/a 安红), Yvette Wang (a/k/a Yanping Wang, Yan Ping Wang, 王雁平), Fiona Yu, Je Kin Ming (a/k/a William Je, Yu Jianming, 余建明 ), Yaz Qingua, and Lao Jiang (a/k/a Jiang Yunfu, Jiang Yunfu Be, 姜云浮).\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: 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, Assets Sino Limited, Auspicious Coast Limited, Beijing Pangu Investment Co., Beijing Pangu Investment Co. Ltd., Beijing Pangu Investment Inc., Beijing Zenith Holdings Company Limited, Bravo Luck Limited, 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, Elite Well Global Limited, Empire Growth Holdings, G Club Operations LLC, G Fashion LLC, G News LLC, GETTR USA, Genever Holdings Corporation, Genever Holdings LLC, GFASHION MEDIA GROUP INC., GFNY, Inc., Globalist International Limited, GNews Media Group Inc., Golden Spring (New York) Ltd., Greenwich Land LLC, Guo Media, GTV Media Group, Inc., Hamilton Capital Holdings Inc., Head Win Group Limited, Henan Yuda, Himalaya Embassy, Himalaya Exchange, Himalaya Federal Reserve, Himalaya Supervisory Organization, HK International Funds Investments (USA) Limited LLC, Hong Kong International Funds Investments Limited, Infinite Increase Limited, Infinitum Developments Limited, Insight Phoenix Fund, Lamp Capital LLC, Leading Shine Limited, Leading Shine NY Limited, Long Gate Limited, Next Tycoon Investments Limited, New Federal State of China (a/k/a NFSC), Noble Fame Global Limited, Rosy Acme Ventures Limited, Rule of Law Foundation III, Inc., Rule of Law Foundation IV, Inc., Rule of Law Fund, Rule of Law Society, Rule of Law Society IV, Inc., G-Translators PTY LTD, Saraca Media Group, Inc., Shiny Ace Ltd., Shiny Times Holdings Ltd., Spirit Charter Investment Limited, Stevenson, Wong & Co., Voice of Guo Media, Inc., Well Origin Ltd., World Century Limited, Worldwide Opportunity Holdings Limited, Whitecroft Shore 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\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\n\ncompilations 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\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,\n\nembodies, 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, 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 estate, 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\n\nobligations 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\n4. All Documents regarding any investment, business dealing or transactions made by, with, or on behalf of the Debtor.\n\n5. All Communications with the Debtor, and Documents related to Communications with the Debtor, 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, or an Associated Entity.\n\n7. All Documents regarding any property ever occupied or used by the Debtor, including without limitation the *Lady May*; the Sherry Netherland Hotel / Condominium; the residential property located in Greenwich, Connecticut at 373 Taconic Rd.; the residential property located in Greenwich, Connecticut at 33 Ferncliff Rd.; and the residential property located in Wilton, Connecticut at 354 Nod Hill Rd.\n\n8. All Documents related to any investments or trading by the Debtor, the Debtor's Family, or an Associated Entity, in or around July 2020, or at any other time, in crude oil futures\n\nor any similar commodity, including without limitation Communications with Jiang Yunfu Be regarding any such investments or trading.\n\n9. All Documents related to any aircraft owned, controlled, or used by the Debtor, including without limitation 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.\n\n10. 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\n11. 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\n12. 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\n13. All Documents and communications between any of your outside counsel or other advisors and the Debtor.\n\n14. Documents sufficient to show all of Your Assets and sources of income or funding.\n\n15. For all Assets identified in response to Request 14 having a value of more than \\$50,000, all (i) Documents related to Your acquisition of such Asset and (ii) Communications with the Debtor or the Debtor's Family regarding such Asset.\n\n16. Copies of Your tax returns.\n\n17. Documents sufficient to show all bank accounts and investment accounts within Your possession or control, including the balances of and transfers to and from each such account.\n\n18. All Documents regarding any credit cards used by You, including without limitation monthly statements or other Documents sufficient to show all purchases related thereto for the benefit of the Debtor or an Associated Entity.\n\n19. All corporate governance and organizational Documents, including without limitation by-laws and certificates of incorporation and other Documents sufficient to show Your corporate structure, names of officers and directors, business purpose, and relationship to the Debtor or to any member of the Debtor's Family.\n\n20. All Documents related to any pledge(s) of Your Assets to any other Entity.\n\n| | | PROOF OF SERVICE
(This section should not be filed with the court unless required by Fed. R. Civ. P. 45.) |\n|--------------------------|----------------------------------------------------------------|------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|\n| on (date)
__________ | | I received this subpoena for (name of individual and title, if any): ______________________________________________ |\n| | I served the subpoena by delivering a copy to the named person | as follows: ____________________________________ |\n| | __________________________________ | ___________________________________________________________________________________________________
on (date) ___________________ ; or |\n| | | I returned the subpoena unexecuted because: ____________________________________________________________
___________________________________________________________________________________________________ |\n| My fees are \\$ _________ | for travel and \\$_________ | Unless the subpoena was issued on behalf of the United States, or one of its officers or agents, I have also tendered to the
witness the fees for one day's attendance, and the mileage allowed by law, in the amount of \\$ _______________________ .
for services, for a total of \\$_________ |\n| | I declare under penalty of perjury | that this information is true and correct. |\n| Date: _______________ | | |\n| | | ________________________________________________
Server's signature |\n| | | ________________________________________________
Printed name and title |\n| | | ________________________________________________
Server's address |\n\nAdditional information concerning attempted service, etc.:\n\n### **Federal Rule of Civil Procedure 45(c), (d), (e), and (g) (Effective 12/1/13) (made applicable in bankruptcy cases by Rule 9016, Federal Rules of Bankruptcy Procedure)**\n\n#### **(c) Place of compliance.**\n\n *(1) For a Trial, Hearing, or Deposition.* A subpoena may command a person to attend a trial, hearing, or deposition only as follows:\n\n (A) within 100 miles of where the person resides, is employed, or regularly transacts business in person; or\n\n (B) within the state where the person resides, is employed, or regularly transacts business in person, if the person\n\n(i) is a party or a party's officer; or\n\n (ii) is commanded to attend a trial and would not incur substantial expense.\n\n#### *(2) For Other Discovery.* A subpoena may command:\n\n (A) production of documents, or electronically stored information, or things at a place within 100 miles of where the person resides, is employed, or regularly transacts business in person; and\n\n(B) inspection of premises, at the premises to be inspected.\n\n#### **(d) Protecting a Person Subject to a Subpoena; Enforcement.**\n\n*(1) Avoiding Undue Burden or Expense; Sanctions.* A party or attorney responsible for issuing and serving a subpoena must take reasonable steps to avoid imposing undue burden or expense on a person subject to the subpoena. The court for the district where compliance is required must enforce this duty and impose an appropriate sanction which may include lost earnings and reasonable attorney's fees — on a party or attorney who fails to comply.\n\n#### *(2) Command to Produce Materials or Permit Inspection.*\n\n *(A) Appearance Not Required.* A person commanded to produce documents, electronically stored information, or tangible things, or to permit the inspection of premises, need not appear in person at the place of production or inspection unless also commanded to appear for a deposition, hearing, or trial.\n\n *(B) Objections*. A person commanded to produce documents or tangible things or to permit inspection may serve on the party or attorney designated in the subpoena a written objection to inspecting, copying, testing or sampling any or all of the materials or to inspecting the premises — or to producing electronically stored information in the form or forms requested. The objection must be served before the earlier of the time specified for compliance or 14 days after the subpoena is served. If an objection is made, the following rules apply:\n\n (i) At any time, on notice to the commanded person, the serving party may move the court for the district where compliance is required for an order compelling production or inspection.\n\n (ii) These acts may be required only as directed in the order, and the order must protect a person who is neither a party nor a party's officer from significant expense resulting from compliance.\n\n#### *(3) Quashing or Modifying a Subpoena.*\n\n *(A) When Required.* On timely motion, the court for the district where compliance is required must quash or modify a subpoena that:\n\n (i) fails to allow a reasonable time to comply; (ii) requires a person to comply beyond the geographical limits\n\nspecified in Rule 45(c); (iii) requires disclosure of privileged or other protected matter, if no\n\nexception or waiver applies; or\n\n(iv) subjects a person to undue burden.\n\n *(B) When Permitted.* To protect a person subject to or affected by a subpoena, the court for the district where compliance is required may, on motion, quash or modify the subpoena if it requires:\n\n (i) disclosing a trade secret or other confidential research, development, or commercial information; or\n\n (ii) disclosing an unretained expert's opinion or information that does not describe specific occurrences in dispute and results from the expert's study that was not requested by a party.\n\n *(C) Specifying Conditions as an Alternative.* In the circumstances described in Rule 45(d)(3)(B), the court may, instead of quashing or modifying a subpoena, order appearance or production under specified conditions if the serving party:\n\n (i) shows a substantial need for the testimony or material that cannot be otherwise met without undue hardship; and\n\n (ii) ensures that the subpoenaed person will be reasonably compensated.\n\n#### **(e) Duties in Responding to a Subpoena.**\n\n *(1) Producing Documents or Electronically Stored Information.* These procedures apply to producing documents or electronically stored information:\n\n *(A) Documents.* A person responding to a subpoena to produce documents must produce them as they are kept in the ordinary course of business or must organize and label them to correspond to the categories in the demand.\n\n *(B) Form for Producing Electronically Stored Information Not Specified.* If a subpoena does not specify a form for producing electronically stored information, the person responding must produce it in a form or forms in which it is ordinarily maintained or in a reasonably usable form or forms.\n\n *(C) Electronically Stored Information Produced in Only One Form.* The person responding need not produce the same electronically stored information in more than one form.\n\n *(D) Inaccessible Electronically Stored Information.* The person responding need not provide discovery of electronically stored information from sources that the person identifies as not reasonably accessible because of undue burden or cost. On motion to compel discovery or for a protective order, the person responding must show that the information is not reasonably accessible because of undue burden or cost. If that showing is made, the court may nonetheless order discovery from such sources if the requesting party shows good cause, considering the limitations of Rule 26(b)(2)(C). The court may specify conditions for the discovery.\n\n#### *(2) Claiming Privilege or Protection.*\n\n *(A) Information Withheld.* A person withholding subpoenaed information under a claim that it is privileged or subject to protection as trial-preparation material must:\n\n(i) expressly make the claim; and\n\n (ii) describe the nature of the withheld documents, communications, or tangible things in a manner that, without revealing information itself privileged or protected, will enable the parties to assess the claim.\n\n *(B) Information Produced.* If information produced in response to a subpoena is subject to a claim of privilege or of protection as trialpreparation material, the person making the claim may notify any party that received the information of the claim and the basis for it. After being notified, a party must promptly return, sequester, or destroy the specified information and any copies it has; must not use or disclose the information until the claim is resolved; must take reasonable steps to retrieve the information if the party disclosed it before being notified; and may promptly present the information under seal to the court for the district where compliance is required for a determination of the claim. The person who produced the information must preserve the information until the claim is resolved.\n\n**(g) Contempt.** The court for the district where compliance is required – and also, after a motion is transferred, the issuing court – may hold in contempt a person who, having been served, fails without adequate excuse to obey the subpoena or an order related to it.\n\nFor access to subpoena materials, see Fed. R. Civ. P. 45(a) Committee Note (2013)\n\n…\n\n## **Exhibit C-3**\n\nB2540 (Form 2540 – Subpoena for Rule 2004 Examination) (12/15) Case 22-50073 Doc 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 72 of 491\n\n# UNITED STATES BANKRUPTCY COURT\n\n\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_ District of \\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_ Connecticut\n\nIn re \\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\n\nCase No. \\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_ Ho Wan Kwok 22-50073\n\nDebtor\n\nChapter \\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_ 11\n\n## **SUBPOENA FOR RULE 2004 EXAMINATION**\n\nTo: **\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_** Himalaya International Payments 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| Paul Hastings LLP
200 Park Avenue
New York, New York 10166 | |\n\nThe examination will be recorded by this method: \\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_ court reporter/stenographer\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: September \\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_ \\_\\_, 2022\n\nCLERK OF COURT\n\nOR\n\n\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_ *Signature of Clerk or Deputy Clerk* \\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_ *Attorney's signature* Patrick R. Linsey (ct29437)\n\nThe name, address, email address, and telephone number of the attorney representing *(name of party)* \\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_ , who issues or requests this subpoena, are: Luc Despins, Ch. 11 Trustee\n\nPatrick R. Linsey, Esq.; Neubert, Pepe & Monteith, P.C.; 195 Church Street, New Haven, Connecticut 06510 plinsey@npmlaw.com; 203-821-2000\n\n## **Notice to the person who issues or requests this subpoena**\n\nIf this subpoena commands the production of documents, electronically stored information, or tangible things, or the inspection of premises before trial, a notice and a copy of this subpoena must be served on each party before it is served on the person to whom it is directed. Fed. R. Civ. P. 45(a)(4).\n\n## **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 following 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
- | 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
time
zone
in
which
the
emails
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 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, including 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\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 othertenses.\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 Himalaya International Payments 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\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. \"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: Daniel Podhaskie, Jason Miller, Steve Bannon, Karin Maistrello, Melissa Francis, William Gertz, Arethusa Forsyth, Glenn Mellor, Jennifer Mercurio, Eduardo Eurnekian, Han Chunguang (a/k/a 韩春光), Qu Guojiao (a/k/a Qu Guo Jiao, 屈国姣), Guo Lijie (a/k/a 郭丽杰), Zhang Wei (a/k/a 张伟\\*), Lihong Wei Lafrenz (a/k/a Sara Wei, 魏丽红), Hao Haidong (a/k/a 郝海东), Ross Heinemeyer, Max Krasner, Kyle Bass, Melissa Mendez, Ya Li (a/k/a 李娅), Dinggang Wang (a/k/a 王定刚), An Hong (a/k/a 安红), Yvette Wang (a/k/a Yanping Wang, Yan Ping Wang, 王雁平), Fiona Yu, Je Kin Ming (a/k/a William Je, Yu Jianming, 余建明 ), Yaz Qingua, and Lao Jiang (a/k/a Jiang Yunfu, Jiang Yunfu Be, 姜云浮).\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: 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, Assets Sino Limited, Auspicious Coast Limited, Beijing Pangu Investment Co., Beijing Pangu Investment Co. Ltd., Beijing Pangu Investment Inc., Beijing Zenith Holdings Company Limited, Bravo Luck Limited, 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, Elite Well Global Limited, Empire Growth Holdings, G Club Operations LLC, G Fashion LLC, G News LLC, GETTR USA, Genever Holdings Corporation, Genever Holdings LLC, GFASHION MEDIA GROUP INC., GFNY, Inc., Globalist International Limited, GNews Media Group Inc., Golden Spring (New York) Ltd., Greenwich Land LLC, Guo Media, GTV Media Group, Inc., Hamilton Capital Holdings Inc., Head Win Group Limited, Henan Yuda, Himalaya Embassy, Himalaya Exchange, Himalaya Federal Reserve, Himalaya Supervisory Organization, HK International Funds Investments (USA) Limited LLC, Hong Kong International Funds Investments Limited, Infinite Increase Limited, Infinitum Developments Limited, Insight Phoenix Fund, Lamp Capital LLC, Leading Shine Limited, Leading Shine NY Limited, Long Gate Limited, Next Tycoon Investments Limited, New Federal State of China (a/k/a NFSC), Noble Fame Global Limited, Rosy Acme Ventures Limited, Rule of Law Foundation III, Inc., Rule of Law Foundation IV, Inc., Rule of Law Fund, Rule of Law Society, Rule of Law Society IV, Inc., G-Translators PTY LTD, Saraca Media Group, Inc., Shiny Ace Ltd., Shiny Times Holdings Ltd., Spirit Charter Investment Limited, Stevenson, Wong & Co., Voice of Guo Media, Inc., Well Origin Ltd., World Century Limited, Worldwide Opportunity Holdings Limited, Whitecroft Shore 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\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\n\ncompilations 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\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,\n\nembodies, 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, 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 estate, 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\n\nobligations 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\n4. All Documents regarding any investment, business dealing or transactions made by, with, or on behalf of the Debtor.\n\n5. All Communications with the Debtor, and Documents related to Communications with the Debtor, 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, or an Associated Entity.\n\n7. All Documents regarding any property ever occupied or used by the Debtor, including without limitation the *Lady May*; the Sherry Netherland Hotel / Condominium; the residential property located in Greenwich, Connecticut at 373 Taconic Rd.; the residential property located in Greenwich, Connecticut at 33 Ferncliff Rd.; and the residential property located in Wilton, Connecticut at 354 Nod Hill Rd.\n\n8. All Documents related to any investments or trading by the Debtor, the Debtor's Family, or an Associated Entity, in or around July 2020, or at any other time, in crude oil futures\n\nor any similar commodity, including without limitation Communications with Jiang Yunfu Be regarding any such investments or trading.\n\n9. All Documents related to any aircraft owned, controlled, or used by the Debtor, including without limitation 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.\n\n10. 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\n11. 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\n12. 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\n13. All Documents and communications between any of your outside counsel or other advisors and the Debtor.\n\n14. Documents sufficient to show all of Your Assets and sources of income or funding.\n\n15. For all Assets identified in response to Request 14 having a value of more than \\$50,000, all (i) Documents related to Your acquisition of such Asset and (ii) Communications with the Debtor or the Debtor's Family regarding such Asset.\n\n16. Copies of Your tax returns.\n\n17. Documents sufficient to show all bank accounts and investment accounts within Your possession or control, including the balances of and transfers to and from each such account.\n\n18. All Documents regarding any credit cards used by You, including without limitation monthly statements or other Documents sufficient to show all purchases related thereto for the benefit of the Debtor or an Associated Entity.\n\n19. All corporate governance and organizational Documents, including without limitation by-laws and certificates of incorporation and other Documents sufficient to show Your corporate structure, names of officers and directors, business purpose, and relationship to the Debtor or to any member of the Debtor's Family.\n\n20. All Documents related to any pledge(s) of Your Assets to any other Entity.\n\n| | | PROOF OF SERVICE
(This section should not be filed with the court unless required by Fed. R. Civ. P. 45.) |\n|------------------------|------------------------------------------------------------------------------------------------|----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|\n| on (date) __________ . | | I received this subpoena for (name of individual and title, if any): ______________________________________________ |\n| | | I served the subpoena by delivering a copy to the named person as follows: ____________________________________ |\n| | __________________________________ on (date) ___________________ ; or | ___________________________________________________________________________________________________ |\n| | | I returned the subpoena unexecuted because: ____________________________________________________________
___________________________________________________________________________________________________ |\n| | My fees are \\$ _________ for travel and \\$_________ for services, for a total of \\$_________ . | Unless 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| | I declare under penalty of perjury | that this information is true and correct. |\n| Date: _______________ | | |\n| | | ________________________________________________
Server's signature |\n| | | ________________________________________________
Printed name and title |\n| | | ________________________________________________
Server's address |\n\nAdditional information concerning attempted service, etc.:\n\n### **Federal Rule of Civil Procedure 45(c), (d), (e), and (g) (Effective 12/1/13) (made applicable in bankruptcy cases by Rule 9016, Federal Rules of Bankruptcy Procedure)**\n\n#### **(c) Place of compliance.**\n\n*(1) For a Trial, Hearing, or Deposition.* A subpoena may command a person to attend a trial, hearing, or deposition only as follows:\n\n(A) within 100 miles of where the person resides, is employed, or regularly transacts business in person; or\n\n(B) within the state where the person resides, is employed, or regularly transacts business in person, if the person\n\n(i) is a party or a party's officer; or\n\n(ii) is commanded to attend a trial and would not incur substantial expense.\n\n#### *(2) For Other Discovery.* A subpoena may command:\n\n(A) production of documents, or electronically stored information, or things at a place within 100 miles of where the person resides, is employed, or regularly transacts business in person; and\n\n(B) inspection of premises, at the premises to be inspected.\n\n#### **(d) Protecting a Person Subject to a Subpoena; Enforcement.**\n\n*(1) Avoiding Undue Burden or Expense; Sanctions.* A party or attorney responsible for issuing and serving a subpoena must take reasonable steps to avoid imposing undue burden or expense on a person subject to the subpoena. The court for the district where compliance is required must enforce this duty and impose an appropriate sanction which may include lost earnings and reasonable attorney's fees — on a party or attorney who fails to comply.\n\n#### *(2) Command to Produce Materials or Permit Inspection.*\n\n*(A) Appearance Not Required.* A person commanded to produce documents, electronically stored information, or tangible things, or to permit the inspection of premises, need not appear in person at the place of production or inspection unless also commanded to appear for a deposition, hearing, or trial.\n\n*(B) Objections*. A person commanded to produce documents or tangible things or to permit inspection may serve on the party or attorney designated in the subpoena a written objection to inspecting, copying, testing or sampling any or all of the materials or to inspecting the premises — or to producing electronically stored information in the form or forms requested. The objection must be served before the earlier of the time specified for compliance or 14 days after the subpoena is served. If an objection is made, the following rules apply:\n\n(i) At any time, on notice to the commanded person, the serving party may move the court for the district where compliance is required for an order compelling production or inspection.\n\n(ii) These acts may be required only as directed in the order, and the order must protect a person who is neither a party nor a party's officer from significant expense resulting from compliance.\n\n#### *(3) Quashing or Modifying a Subpoena.*\n\n*(A) When Required.* On timely motion, the court for the district where compliance is required must quash or modify a subpoena that:\n\n(i) fails to allow a reasonable time to comply; (ii) requires a person to comply beyond the geographical limits\n\nspecified in Rule 45(c);\n\n(iii) requires disclosure of privileged or other protected matter, if no exception or waiver applies; or\n\n(iv) subjects a person to undue burden.\n\n*(B) When Permitted.* To protect a person subject to or affected by a subpoena, the court for the district where compliance is required may, on motion, quash or modify the subpoena if it requires:\n\n(i) disclosing a trade secret or other confidential research, development, or commercial information; or\n\n(ii) disclosing an unretained expert's opinion or information that does not describe specific occurrences in dispute and results from the expert's study that was not requested by a party.\n\n*(C) Specifying Conditions as an Alternative.* In the circumstances described in Rule 45(d)(3)(B), the court may, instead of quashing or modifying a subpoena, order appearance or production under specified conditions if the serving party:\n\n(i) shows a substantial need for the testimony or material that cannot be otherwise met without undue hardship; and\n\n(ii) ensures that the subpoenaed person will be reasonably compensated.\n\n#### **(e) Duties in Responding to a Subpoena.**\n\n*(1) Producing Documents or Electronically Stored Information.* These procedures apply to producing documents or electronically stored information:\n\n*(A) Documents.* A person responding to a subpoena to produce documents must produce them as they are kept in the ordinary course of business or must organize and label them to correspond to the categories in the demand.\n\n*(B) Form for Producing Electronically Stored Information Not Specified.* If a subpoena does not specify a form for producing electronically stored information, the person responding must produce it in a form or forms in which it is ordinarily maintained or in a reasonably usable form or forms.\n\n*(C) Electronically Stored Information Produced in Only One Form.* The person responding need not produce the same electronically stored information in more than one form.\n\n*(D) Inaccessible Electronically Stored Information.* The person responding need not provide discovery of electronically stored information from sources that the person identifies as not reasonably accessible because of undue burden or cost. On motion to compel discovery or for a protective order, the person responding must show that the information is not reasonably accessible because of undue burden or cost. If that showing is made, the court may nonetheless order discovery from such sources if the requesting party shows good cause, considering the limitations of Rule 26(b)(2)(C). The court may specify conditions for the discovery.\n\n#### *(2) Claiming Privilege or Protection.*\n\n*(A) Information Withheld.* A person withholding subpoenaed information under a claim that it is privileged or subject to protection as trial-preparation material must:\n\n(i) expressly make the claim; and\n\n(ii) describe the nature of the withheld documents, communications, or tangible things in a manner that, without revealing information itself privileged or protected, will enable the parties to assess the claim.\n\n*(B) Information Produced.* If information produced in response to a subpoena is subject to a claim of privilege or of protection as trialpreparation material, the person making the claim may notify any party that received the information of the claim and the basis for it. After being notified, a party must promptly return, sequester, or destroy the specified information and any copies it has; must not use or disclose the information until the claim is resolved; must take reasonable steps to retrieve the information if the party disclosed it before being notified; and may promptly present the information under seal to the court for the district where compliance is required for a determination of the claim. The person who produced the information must preserve the information until the claim is resolved.\n\n**(g) Contempt.** The court for the district where compliance is required – and also, after a motion is transferred, the issuing court – may hold in contempt a person who, having been served, fails without adequate excuse to obey the subpoena or an order related to it.\n\nFor access to subpoena materials, see Fed. R. Civ. P. 45(a) Committee Note (2013)\n\n…\n\n## **Exhibit C-4**\n\nB2540 (Form 2540 – Subpoena for Rule 2004 Examination) (12/15) Case 22-50073 Doc 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 91 of 491\n\n# UNITED STATES BANKRUPTCY COURT\n\n\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_ District of \\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_ Connecticut\n\nIn re \\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\n\nCase No. \\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_ Ho Wan Kwok 22-50073\n\nDebtor\n\nChapter \\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_ 11\n\n## **SUBPOENA FOR RULE 2004 EXAMINATION**\n\nTo: **\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_** Himalaya International Reserves 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| Paul Hastings LLP
200 Park Avenue
New York, New York 10166 | |\n\nThe examination will be recorded by this method: \\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_ court reporter/stenographer\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: September \\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_ \\_\\_, 2022\n\nCLERK OF COURT\n\nOR\n\n\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_ *Signature of Clerk or Deputy Clerk* \\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_ *Attorney's signature* Patrick R. Linsey (ct29437)\n\nThe name, address, email address, and telephone number of the attorney representing *(name of party)* \\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_ , who issues or requests this subpoena, are: Luc Despins, Ch. 11 Trustee\n\nPatrick R. Linsey, Esq.; Neubert, Pepe & Monteith, P.C.; 195 Church Street, New Haven, Connecticut 06510 plinsey@npmlaw.com; 203-821-2000\n\n## **Notice to the person who issues or requests this subpoena**\n\nIf this subpoena commands the production of documents, electronically stored information, or tangible things, or the inspection of premises before trial, a notice and a copy of this subpoena must be served on each party before it is served on the person to whom it is directed. Fed. R. Civ. P. 45(a)(4).\n\n## **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 following 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
- | 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
time
zone
in
which
the
emails
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 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, including 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\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 othertenses.\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 Himalaya International Reserves 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\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. \"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: Daniel Podhaskie, Jason Miller, Steve Bannon, Karin Maistrello, Melissa Francis, William Gertz, Arethusa Forsyth, Glenn Mellor, Jennifer Mercurio, Eduardo Eurnekian, Han Chunguang (a/k/a 韩春光), Qu Guojiao (a/k/a Qu Guo Jiao, 屈国姣), Guo Lijie (a/k/a 郭丽杰), Zhang Wei (a/k/a 张伟\\*), Lihong Wei Lafrenz (a/k/a Sara Wei, 魏丽红), Hao Haidong (a/k/a 郝海东), Ross Heinemeyer, Max Krasner, Kyle Bass, Melissa Mendez, Ya Li (a/k/a 李娅), Dinggang Wang (a/k/a 王定刚), An Hong (a/k/a 安红), Yvette Wang (a/k/a Yanping Wang, Yan Ping Wang, 王雁平), Fiona Yu, Je Kin Ming (a/k/a William Je, Yu Jianming, 余建明 ), Yaz Qingua, and Lao Jiang (a/k/a Jiang Yunfu, Jiang Yunfu Be, 姜云浮).\n\n## Case 22-50073 Doc 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 100 of 491\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: 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, Assets Sino Limited, Auspicious Coast Limited, Beijing Pangu Investment Co., Beijing Pangu Investment Co. Ltd., Beijing Pangu Investment Inc., Beijing Zenith Holdings Company Limited, Bravo Luck Limited, 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, Elite Well Global Limited, Empire Growth Holdings, G Club Operations LLC, G Fashion LLC, G News LLC, GETTR USA, Genever Holdings Corporation, Genever Holdings LLC, GFASHION MEDIA GROUP INC., GFNY, Inc., Globalist International Limited, GNews Media Group Inc., Golden Spring (New York) Ltd., Greenwich Land LLC, Guo Media, GTV Media Group, Inc., Hamilton Capital Holdings Inc., Head Win Group Limited, Henan Yuda, Himalaya Embassy, Himalaya Exchange, Himalaya Federal Reserve, Himalaya Supervisory Organization, HK International Funds Investments (USA) Limited LLC, Hong Kong International Funds Investments Limited, Infinite Increase Limited, Infinitum Developments Limited, Insight Phoenix Fund, Lamp Capital LLC, Leading Shine Limited, Leading Shine NY Limited, Long Gate Limited, Next Tycoon Investments Limited, New\n\n## Case 22-50073 Doc 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 101 of 491\n\nFederal State of China (a/k/a NFSC), Noble Fame Global Limited, Rosy Acme Ventures Limited, Rule of Law Foundation III, Inc., Rule of Law Foundation IV, Inc., Rule of Law Fund, Rule of Law Society, Rule of Law Society IV, Inc., G-Translators PTY LTD, Saraca Media Group, Inc., Shiny Ace Ltd., Shiny Times Holdings Ltd., Spirit Charter Investment Limited, Stevenson, Wong & Co., Voice of Guo Media, Inc., Well Origin Ltd., World Century Limited, Worldwide Opportunity Holdings Limited, Whitecroft Shore 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\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\n\n## Case 22-50073 Doc 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 102 of 491\n\ncompilations 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\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,\n\n## Case 22-50073 Doc 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 103 of 491\n\nembodies, 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, 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 estate, 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\n\n## Case 22-50073 Doc 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 104 of 491\n\nobligations 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\n4. All Documents regarding any investment, business dealing or transactions made by, with, or on behalf of the Debtor.\n\n5. All Communications with the Debtor, and Documents related to Communications with the Debtor, 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, or an Associated Entity.\n\n7. All Documents regarding any property ever occupied or used by the Debtor, including without limitation the *Lady May*; the Sherry Netherland Hotel / Condominium; the residential property located in Greenwich, Connecticut at 373 Taconic Rd.; the residential property located in Greenwich, Connecticut at 33 Ferncliff Rd.; and the residential property located in Wilton, Connecticut at 354 Nod Hill Rd.\n\n8. All Documents related to any investments or trading by the Debtor, the Debtor's Family, or an Associated Entity, in or around July 2020, or at any other time, in crude oil futures\n\n## Case 22-50073 Doc 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 105 of 491\n\nor any similar commodity, including without limitation Communications with Jiang Yunfu Be regarding any such investments or trading.\n\n9. All Documents related to any aircraft owned, controlled, or used by the Debtor, including without limitation 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.\n\n10. 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\n11. 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\n12. 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\n13. All Documents and communications between any of your outside counsel or other advisors and the Debtor.\n\n## Case 22-50073 Doc 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 106 of 491\n\n14. Documents sufficient to show all of Your Assets and sources of income or funding.\n\n15. For all Assets identified in response to Request 14 having a value of more than \\$50,000, all (i) Documents related to Your acquisition of such Asset and (ii) Communications with the Debtor or the Debtor's Family regarding such Asset.\n\n16. Copies of Your tax returns.\n\n17. Documents sufficient to show all bank accounts and investment accounts within Your possession or control, including the balances of and transfers to and from each such account.\n\n18. All Documents regarding any credit cards used by You, including without limitation monthly statements or other Documents sufficient to show all purchases related thereto for the benefit of the Debtor or an Associated Entity.\n\n19. All corporate governance and organizational Documents, including without limitation by-laws and certificates of incorporation and other Documents sufficient to show Your corporate structure, names of officers and directors, business purpose, and relationship to the Debtor or to any member of the Debtor's Family.\n\n20. All Documents related to any pledge(s) of Your Assets to any other Entity.\n\n| Case 22-50073 | Doc 839 | Filed 09/07/22 | | Entered 09/07/22 20:02:47 | Page 107 of |\n|-----------------------------------------------------------------|---------|----------------|-----|---------------------------|-------------|\n| B2540 (Form 2540 – Subpoena for Rule 2004 Examination) (Page 2) | | | 491 | | |\n| | | | | | |\n\n| | | (This section should not be filed with the court unless required by Fed. R. Civ. P. 45.) |\n|------------------------------------|----------------------------------------------------------------|------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|\n| on (date)
__________ | | I received this subpoena for (name of individual and title, if any): ______________________________________________ |\n| | I served the subpoena by delivering a copy to the named person | as follows: ____________________________________
___________________________________________________________________________________________________ |\n| __________________________________ | on (date) ___________________ ; or | |\n| | | I returned the subpoena unexecuted because: ____________________________________________________________
___________________________________________________________________________________________________ |\n| | | |\n| My fees are \\$ _________ | for travel and \\$_________ | Unless the subpoena was issued on behalf of the United States, or one of its officers or agents, I have also tendered to the
witness the fees for one day's attendance, and the mileage allowed by law, in the amount of \\$ _______________________ .
for services, for a total of \\$_________ |\n| I declare under penalty of perjury | that this information is true and correct. | |\n| | | |\n| Date: _______________ | | ________________________________________________
Server's signature |\n\n*Server's address*\n\nAdditional information concerning attempted service, etc.:\n\n### **Federal Rule of Civil Procedure 45(c), (d), (e), and (g) (Effective 12/1/13) (made applicable in bankruptcy cases by Rule 9016, Federal Rules of Bankruptcy Procedure)**\n\n#### **(c) Place of compliance.**\n\n *(1) For a Trial, Hearing, or Deposition.* A subpoena may command a person to attend a trial, hearing, or deposition only as follows:\n\n (A) within 100 miles of where the person resides, is employed, or regularly transacts business in person; or\n\n (B) within the state where the person resides, is employed, or regularly transacts business in person, if the person\n\n(i) is a party or a party's officer; or\n\n (ii) is commanded to attend a trial and would not incur substantial expense.\n\n#### *(2) For Other Discovery.* A subpoena may command:\n\n (A) production of documents, or electronically stored information, or things at a place within 100 miles of where the person resides, is employed, or regularly transacts business in person; and\n\n(B) inspection of premises, at the premises to be inspected.\n\n#### **(d) Protecting a Person Subject to a Subpoena; Enforcement.**\n\n*(1) Avoiding Undue Burden or Expense; Sanctions.* A party or attorney responsible for issuing and serving a subpoena must take reasonable steps to avoid imposing undue burden or expense on a person subject to the subpoena. The court for the district where compliance is required must enforce this duty and impose an appropriate sanction which may include lost earnings and reasonable attorney's fees — on a party or attorney who fails to comply.\n\n#### *(2) Command to Produce Materials or Permit Inspection.*\n\n *(A) Appearance Not Required.* A person commanded to produce documents, electronically stored information, or tangible things, or to permit the inspection of premises, need not appear in person at the place of production or inspection unless also commanded to appear for a deposition, hearing, or trial.\n\n *(B) Objections*. A person commanded to produce documents or tangible things or to permit inspection may serve on the party or attorney designated in the subpoena a written objection to inspecting, copying, testing or sampling any or all of the materials or to inspecting the premises — or to producing electronically stored information in the form or forms requested. The objection must be served before the earlier of the time specified for compliance or 14 days after the subpoena is served. If an objection is made, the following rules apply:\n\n (i) At any time, on notice to the commanded person, the serving party may move the court for the district where compliance is required for an order compelling production or inspection.\n\n (ii) These acts may be required only as directed in the order, and the order must protect a person who is neither a party nor a party's officer from significant expense resulting from compliance.\n\n#### *(3) Quashing or Modifying a Subpoena.*\n\n *(A) When Required.* On timely motion, the court for the district where compliance is required must quash or modify a subpoena that:\n\n (i) fails to allow a reasonable time to comply; (ii) requires a person to comply beyond the geographical limits\n\nspecified in Rule 45(c); (iii) requires disclosure of privileged or other protected matter, if no\n\nexception or waiver applies; or\n\n(iv) subjects a person to undue burden.\n\n *(B) When Permitted.* To protect a person subject to or affected by a subpoena, the court for the district where compliance is required may, on motion, quash or modify the subpoena if it requires:\n\n (i) disclosing a trade secret or other confidential research, development, or commercial information; or\n\n (ii) disclosing an unretained expert's opinion or information that does not describe specific occurrences in dispute and results from the expert's study that was not requested by a party.\n\n *(C) Specifying Conditions as an Alternative.* In the circumstances described in Rule 45(d)(3)(B), the court may, instead of quashing or modifying a subpoena, order appearance or production under specified conditions if the serving party:\n\n (i) shows a substantial need for the testimony or material that cannot be otherwise met without undue hardship; and\n\n (ii) ensures that the subpoenaed person will be reasonably compensated.\n\n#### **(e) Duties in Responding to a Subpoena.**\n\n *(1) Producing Documents or Electronically Stored Information.* These procedures apply to producing documents or electronically stored information:\n\n *(A) Documents.* A person responding to a subpoena to produce documents must produce them as they are kept in the ordinary course of business or must organize and label them to correspond to the categories in the demand.\n\n *(B) Form for Producing Electronically Stored Information Not Specified.* If a subpoena does not specify a form for producing electronically stored information, the person responding must produce it in a form or forms in which it is ordinarily maintained or in a reasonably usable form or forms.\n\n *(C) Electronically Stored Information Produced in Only One Form.* The person responding need not produce the same electronically stored information in more than one form.\n\n *(D) Inaccessible Electronically Stored Information.* The person responding need not provide discovery of electronically stored information from sources that the person identifies as not reasonably accessible because of undue burden or cost. On motion to compel discovery or for a protective order, the person responding must show that the information is not reasonably accessible because of undue burden or cost. If that showing is made, the court may nonetheless order discovery from such sources if the requesting party shows good cause, considering the limitations of Rule 26(b)(2)(C). The court may specify conditions for the discovery.\n\n#### *(2) Claiming Privilege or Protection.*\n\n *(A) Information Withheld.* A person withholding subpoenaed information under a claim that it is privileged or subject to protection as trial-preparation material must:\n\n(i) expressly make the claim; and\n\n (ii) describe the nature of the withheld documents, communications, or tangible things in a manner that, without revealing information itself privileged or protected, will enable the parties to assess the claim.\n\n *(B) Information Produced.* If information produced in response to a subpoena is subject to a claim of privilege or of protection as trialpreparation material, the person making the claim may notify any party that received the information of the claim and the basis for it. After being notified, a party must promptly return, sequester, or destroy the specified information and any copies it has; must not use or disclose the information until the claim is resolved; must take reasonable steps to retrieve the information if the party disclosed it before being notified; and may promptly present the information under seal to the court for the district where compliance is required for a determination of the claim. The person who produced the information must preserve the information until the claim is resolved.\n\n**(g) Contempt.** The court for the district where compliance is required – and also, after a motion is transferred, the issuing court – may hold in contempt a person who, having been served, fails without adequate excuse to obey the subpoena or an order related to it.\n\nFor access to subpoena materials, see Fed. R. Civ. P. 45(a) Committee Note (2013)\n\n…\n\n## **Exhibit C-5**\n\n### B2540 (Form 2540 – Subpoena for Rule 2004 Examination) (12/15) UNITED STATES BANKRUPTCY COURT Case 22-50073 Doc 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 110 of 491\n\n\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_ District of \\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_ Connecticut\n\nIn re \\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\n\nCase No. \\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_ Ho Wan Kwok 22-50073\n\nDebtor\n\nChapter \\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_ 11\n\n## **SUBPOENA FOR RULE 2004 EXAMINATION**\n\nTo: **\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_** Jesse Brown\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| Paul Hastings LLP
200 Park Avenue
New York, New York 10166 | |\n\nThe examination will be recorded by this method: \\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_ court reporter/stenographer\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: September \\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_ \\_\\_, 2022\n\nCLERK OF COURT\n\nOR\n\n\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_ *Signature of Clerk or Deputy Clerk* \\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_ *Attorney's signature* Patrick R. Linsey (ct29437)\n\nThe name, address, email address, and telephone number of the attorney representing *(name of party)* \\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_ , who issues or requests this subpoena, are: Luc Despins, Ch. 11 Trustee\n\nPatrick R. Linsey, Esq.; Neubert, Pepe & Monteith, P.C.; 195 Church Street, New Haven, Connecticut 06510 plinsey@npmlaw.com; 203-821-2000\n\n## **Notice to the person who issues or requests this subpoena**\n\nIf this subpoena commands the production of documents, electronically stored information, or tangible things, or the inspection of premises before trial, a notice and a copy of this subpoena must be served on each party before it is served on the person to whom it is directed. Fed. R. Civ. P. 45(a)(4).\n\n## **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 following 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 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 113 of 491\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
- | 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| | | |\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| | | |\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
time
zone
in
which
the
emails
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| | | |\n| DATE_CREATED | 10/10/2010 | Email: (empty) |\n| | | Native: Date the document was created |\n\n## Case 22-50073 Doc 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 114 of 491\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 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 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 115 of 491\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 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 116 of 491\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 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 117 of 491\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 othertenses.\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 Jesse Brown, 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\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 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 118 of 491\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: Daniel Podhaskie, Jason Miller, Steve Bannon, Karin Maistrello, Melissa Francis, William Gertz, Arethusa Forsyth, Glenn Mellor, Jennifer Mercurio, Eduardo Eurnekian, Han Chunguang (a/k/a 韩春光), Qu Guojiao (a/k/a Qu Guo Jiao, 屈国姣), Guo Lijie (a/k/a 郭丽杰), Zhang Wei (a/k/a 张伟\\*), Lihong Wei Lafrenz (a/k/a Sara Wei, 魏丽红), Hao Haidong (a/k/a 郝海东), Ross Heinemeyer, Max Krasner, Kyle Bass, Melissa Mendez, Ya Li (a/k/a 李娅), Dinggang Wang (a/k/a 王定刚), An Hong (a/k/a 安红), Yvette Wang (a/k/a Yanping Wang, Yan Ping Wang, 王雁平), Fiona Yu, Je Kin Ming (a/k/a William Je, Yu Jianming, 余建明 ), Yaz Qingua, and Lao Jiang (a/k/a Jiang Yunfu, Jiang Yunfu Be, 姜云浮).\n\n## Case 22-50073 Doc 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 119 of 491\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: 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, Assets Sino Limited, Auspicious Coast Limited, Beijing Pangu Investment Co., Beijing Pangu Investment Co. Ltd., Beijing Pangu Investment Inc., Beijing Zenith Holdings Company Limited, Bravo Luck Limited, 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, Elite Well Global Limited, Empire Growth Holdings, G Club Operations LLC, G Fashion LLC, G News LLC, GETTR USA, Genever Holdings Corporation, Genever Holdings LLC, GFASHION MEDIA GROUP INC., GFNY, Inc., Globalist International Limited, GNews Media Group Inc., Golden Spring (New York) Ltd., Greenwich Land LLC, Guo Media, GTV Media Group, Inc., Hamilton Capital Holdings Inc., Head Win Group Limited, Henan Yuda, Himalaya Embassy, Himalaya Exchange, Himalaya Federal Reserve, Himalaya Supervisory Organization, HK International Funds Investments (USA) Limited LLC, Hong Kong International Funds Investments Limited, Infinite Increase Limited, Infinitum Developments Limited, Insight Phoenix Fund, Lamp Capital LLC, Leading Shine Limited, Leading Shine NY Limited, Long Gate Limited, Next Tycoon Investments Limited, New\n\n## Case 22-50073 Doc 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 120 of 491\n\nFederal State of China (a/k/a NFSC), Noble Fame Global Limited, Rosy Acme Ventures Limited, Rule of Law Foundation III, Inc., Rule of Law Foundation IV, Inc., Rule of Law Fund, Rule of Law Society, Rule of Law Society IV, Inc., G-Translators PTY LTD, Saraca Media Group, Inc., Shiny Ace Ltd., Shiny Times Holdings Ltd., Spirit Charter Investment Limited, Stevenson, Wong & Co., Voice of Guo Media, Inc., Well Origin Ltd., World Century Limited, Worldwide Opportunity Holdings Limited, Whitecroft Shore 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\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\n\n## Case 22-50073 Doc 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 121 of 491\n\ncompilations 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\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,\n\n## Case 22-50073 Doc 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 122 of 491\n\nembodies, 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, 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 estate, 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\n\n## Case 22-50073 Doc 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 123 of 491\n\nobligations 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\n4. All Documents regarding any investment, business dealing or transactions made by, with, or on behalf of the Debtor.\n\n5. All Communications with the Debtor, and Documents related to Communications with the Debtor, 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, or an Associated Entity.\n\n7. All Documents regarding any property ever occupied or used by the Debtor, including without limitation the *Lady May*; the Sherry Netherland Hotel / Condominium; the residential property located in Greenwich, Connecticut at 373 Taconic Rd.; the residential property located in Greenwich, Connecticut at 33 Ferncliff Rd.; and the residential property located in Wilton, Connecticut at 354 Nod Hill Rd.\n\n8. All Documents related to any investments or trading by the Debtor, the Debtor's Family, or an Associated Entity, in or around July 2020, or at any other time, in crude oil futures\n\n## Case 22-50073 Doc 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 124 of 491\n\nor any similar commodity, including without limitation Communications with Jiang Yunfu Be regarding any such investments or trading.\n\n9. All Documents related to any aircraft owned, controlled, or used by the Debtor, including without limitation 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.\n\n10. 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\n11. 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\n12. 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\n13. All Documents and communications between any of your outside counsel or other advisors and the Debtor.\n\n## Case 22-50073 Doc 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 125 of 491\n\n14. Documents sufficient to show all of Your Assets and sources of income or funding.\n\n15. For all Assets identified in response to Request 14 having a value of more than \\$50,000, all (i) Documents related to Your acquisition of such Asset and (ii) Communications with the Debtor or the Debtor's Family regarding such Asset.\n\n16. Copies of Your tax returns.\n\n17. Documents sufficient to show all bank accounts and investment accounts within Your possession or control, including the balances of and transfers to and from each such account.\n\n18. All Documents regarding any credit cards used by You, including without limitation monthly statements or other Documents sufficient to show all purchases related thereto for the benefit of the Debtor or an Associated Entity.\n\n19. All Documents related to any pledge(s) of Your Assets to any other Entity.\n\n| Case 22-50073 | Doc 839 | Filed 09/07/22 | Entered 09/07/22 20:02:47 | Page 126 of |\n|-----------------------------------------------------------------|---------|----------------|---------------------------|-------------|\n| B2540 (Form 2540 – Subpoena for Rule 2004 Examination) (Page 2) | | 491 | | |\n| | | | | |\n\n| I received this subpoena for (name of individual and title, if any): ______________________________________________
on (date)
__________
I served the subpoena by delivering a copy to the named person
___________________________________________________________________________________________________
__________________________________
on (date) ___________________ ; or | as follows: ____________________________________ |\n|-----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|----------------------------------------------------------------------------|\n| | |\n| | |\n| | |\n| I returned the subpoena unexecuted because: ____________________________________________________________
___________________________________________________________________________________________________ | |\n| Unless the subpoena was issued on behalf of the United States, or one of its officers or agents, I have also tendered to the
witness the fees for one day's attendance, and the mileage allowed by law, in the amount of \\$ _______________________ . | |\n| My fees are \\$ _________
for travel and \\$_________ | for services, for a total of \\$_________ |\n| I declare under penalty of perjury
that this information is true and correct. | |\n| Date: _______________ | |\n| | ________________________________________________
Server's signature |\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; (ii) requires a person to comply beyond the geographical limits\n\nspecified in Rule 45(c);\n\n (iii) requires disclosure of privileged or other protected matter, if no exception or waiver applies; or\n\n(iv) subjects a person to undue burden.\n\n *(B) When Permitted.* To protect a person subject to or affected by a subpoena, the court for the district where compliance is required may, on motion, quash or modify the subpoena if it requires:\n\n (i) disclosing a trade secret or other confidential research, development, or commercial information; or\n\n (ii) disclosing an unretained expert's opinion or information that does not describe specific occurrences in dispute and results from the expert's study that was not requested by a party.\n\n *(C) Specifying Conditions as an Alternative.* In the circumstances described in Rule 45(d)(3)(B), the court may, instead of quashing or modifying a subpoena, order appearance or production under specified conditions if the serving party:\n\n (i) shows a substantial need for the testimony or material that cannot be otherwise met without undue hardship; and\n\n (ii) ensures that the subpoenaed person will be reasonably compensated.\n\n#### **(e) Duties in Responding to a Subpoena.**\n\n *(1) Producing Documents or Electronically Stored Information.* These procedures apply to producing documents or electronically stored information:\n\n *(A) Documents.* A person responding to a subpoena to produce documents must produce them as they are kept in the ordinary course of business or must organize and label them to correspond to the categories in the demand.\n\n *(B) Form for Producing Electronically Stored Information Not Specified.* If a subpoena does not specify a form for producing electronically stored information, the person responding must produce it in a form or forms in which it is ordinarily maintained or in a reasonably usable form or forms.\n\n *(C) Electronically Stored Information Produced in Only One Form.* The person responding need not produce the same electronically stored information in more than one form.\n\n *(D) Inaccessible Electronically Stored Information.* The person responding need not provide discovery of electronically stored information from sources that the person identifies as not reasonably accessible because of undue burden or cost. On motion to compel discovery or for a protective order, the person responding must show that the information is not reasonably accessible because of undue burden or cost. If that showing is made, the court may nonetheless order discovery from such sources if the requesting party shows good cause, considering the limitations of Rule 26(b)(2)(C). The court may specify conditions for the discovery.\n\n### *(2) Claiming Privilege or Protection.*\n\n *(A) Information Withheld.* A person withholding subpoenaed information under a claim that it is privileged or subject to protection as trial-preparation material must:\n\n(i) expressly make the claim; and\n\n (ii) describe the nature of the withheld documents, communications, or tangible things in a manner that, without revealing information itself privileged or protected, will enable the parties to assess the claim.\n\n *(B) Information Produced.* If information produced in response to a subpoena is subject to a claim of privilege or of protection as trialpreparation material, the person making the claim may notify any party that received the information of the claim and the basis for it. After being notified, a party must promptly return, sequester, or destroy the specified information and any copies it has; must not use or disclose the information until the claim is resolved; must take reasonable steps to retrieve the information if the party disclosed it before being notified; and may promptly present the information under seal to the court for the district where compliance is required for a determination of the claim. The person who produced the information must preserve the information until the claim is resolved.\n\n**(g) Contempt.** The court for the district where compliance is required – and also, after a motion is transferred, the issuing court – may hold in contempt a person who, having been served, fails without adequate excuse to obey the subpoena or an order related to it.\n\nFor access to subpoena materials, see Fed. R. Civ. P. 45(a) Committee Note (2013)\n\n…\n\n## **Exhibit C-6**\n\n### B2540 (Form 2540 – Subpoena for Rule 2004 Examination) (12/15) UNITED STATES BANKRUPTCY COURT Case 22-50073 Doc 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 129 of 491\n\n\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_ District of \\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_ Connecticut\n\nIn re \\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\n\nCase No. \\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_ Ho Wan Kwok 22-50073\n\nDebtor\n\nChapter \\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_ 11\n\n## **SUBPOENA FOR RULE 2004 EXAMINATION**\n\nTo: **\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_** ACA Capital Group 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| Paul Hastings LLP
200 Park Avenue
New York, New York 10166 | |\n\nThe examination will be recorded by this method: \\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_ court reporter/stenographer\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: September \\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_ \\_\\_, 2022\n\nCLERK OF COURT\n\nOR\n\n\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_ *Signature of Clerk or Deputy Clerk* \\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_ *Attorney's signature* Patrick R. Linsey (ct29437)\n\nThe name, address, email address, and telephone number of the attorney representing *(name of party)* \\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_ , who issues or requests this subpoena, are: Luc Despins, Ch. 11 Trustee\n\nPatrick R. Linsey, Esq.; Neubert, Pepe & Monteith, P.C.; 195 Church Street, New Haven, Connecticut 06510 plinsey@npmlaw.com; 203-821-2000\n\n## **Notice to the person who issues or requests this subpoena**\n\nIf this subpoena commands the production of documents, electronically stored information, or tangible things, or the inspection of premises before trial, a notice and a copy of this subpoena must be served on each party before it is served on the person to whom it is directed. Fed. R. Civ. P. 45(a)(4).\n\n## **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 following 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 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 132 of 491\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
- | 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| | | |\n| FROM | John Smith | Email: Sender
Native: Author(s) of document |\n| | | |\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
time
zone
in
which
the
emails
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 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 133 of 491\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 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 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 134 of 491\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 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 135 of 491\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 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 136 of 491\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 othertenses.\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 ACA Capital Group 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\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 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 137 of 491\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: Daniel Podhaskie, Jason Miller, Steve Bannon, Karin Maistrello, Melissa Francis, William Gertz, Arethusa Forsyth, Glenn Mellor, Jennifer Mercurio, Eduardo Eurnekian, Han Chunguang (a/k/a 韩春光), Qu Guojiao (a/k/a Qu Guo Jiao, 屈国姣), Guo Lijie (a/k/a 郭丽杰), Zhang Wei (a/k/a 张伟\\*), Lihong Wei Lafrenz (a/k/a Sara Wei, 魏丽红), Hao Haidong (a/k/a 郝海东), Ross Heinemeyer, Max Krasner, Kyle Bass, Melissa Mendez, Ya Li (a/k/a 李娅), Dinggang Wang (a/k/a 王定刚), An Hong (a/k/a 安红), Yvette Wang (a/k/a Yanping Wang, Yan Ping Wang, 王雁平), Fiona Yu, Je Kin Ming (a/k/a William Je, Yu Jianming, 余建明 ), Yaz Qingua, and Lao Jiang (a/k/a Jiang Yunfu, Jiang Yunfu Be, 姜云浮).\n\n## Case 22-50073 Doc 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 138 of 491\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: 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, Assets Sino Limited, Auspicious Coast Limited, Beijing Pangu Investment Co., Beijing Pangu Investment Co. Ltd., Beijing Pangu Investment Inc., Beijing Zenith Holdings Company Limited, Bravo Luck Limited, 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, Elite Well Global Limited, Empire Growth Holdings, G Club Operations LLC, G Fashion LLC, G News LLC, GETTR USA, Genever Holdings Corporation, Genever Holdings LLC, GFASHION MEDIA GROUP INC., GFNY, Inc., Globalist International Limited, GNews Media Group Inc., Golden Spring (New York) Ltd., Greenwich Land LLC, Guo Media, GTV Media Group, Inc., Hamilton Capital Holdings Inc., Head Win Group Limited, Henan Yuda, Himalaya Embassy, Himalaya Exchange, Himalaya Federal Reserve, Himalaya Supervisory Organization, HK International Funds Investments (USA) Limited LLC, Hong Kong International Funds Investments Limited, Infinite Increase Limited, Infinitum Developments Limited, Insight Phoenix Fund, Lamp Capital LLC, Leading Shine Limited, Leading Shine NY Limited, Long Gate Limited, Next Tycoon Investments Limited, New\n\n## Case 22-50073 Doc 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 139 of 491\n\nFederal State of China (a/k/a NFSC), Noble Fame Global Limited, Rosy Acme Ventures Limited, Rule of Law Foundation III, Inc., Rule of Law Foundation IV, Inc., Rule of Law Fund, Rule of Law Society, Rule of Law Society IV, Inc., G-Translators PTY LTD, Saraca Media Group, Inc., Shiny Ace Ltd., Shiny Times Holdings Ltd., Spirit Charter Investment Limited, Stevenson, Wong & Co., Voice of Guo Media, Inc., Well Origin Ltd., World Century Limited, Worldwide Opportunity Holdings Limited, Whitecroft Shore 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\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\n\n## Case 22-50073 Doc 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 140 of 491\n\ncompilations 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\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,\n\n## Case 22-50073 Doc 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 141 of 491\n\nembodies, 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, 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 estate, 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\n\n## Case 22-50073 Doc 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 142 of 491\n\nobligations 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\n4. All Documents regarding any investment, business dealing or transactions made by, with, or on behalf of the Debtor.\n\n5. All Communications with the Debtor, and Documents related to Communications with the Debtor, 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, or an Associated Entity.\n\n7. All Documents regarding any property ever occupied or used by the Debtor, including without limitation the *Lady May*; the Sherry Netherland Hotel / Condominium; the residential property located in Greenwich, Connecticut at 373 Taconic Rd.; the residential property located in Greenwich, Connecticut at 33 Ferncliff Rd.; and the residential property located in Wilton, Connecticut at 354 Nod Hill Rd.\n\n8. All Documents related to any investments or trading by the Debtor, the Debtor's Family, or an Associated Entity, in or around July 2020, or at any other time, in crude oil futures\n\n## Case 22-50073 Doc 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 143 of 491\n\nor any similar commodity, including without limitation Communications with Jiang Yunfu Be regarding any such investments or trading.\n\n9. All Documents related to any aircraft owned, controlled, or used by the Debtor, including without limitation 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.\n\n10. 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\n11. 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\n12. 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\n13. All Documents and communications between any of your outside counsel or other advisors and the Debtor.\n\n## Case 22-50073 Doc 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 144 of 491\n\n14. Documents sufficient to show all of Your Assets and sources of income or funding.\n\n15. For all Assets identified in response to Request 14 having a value of more than \\$50,000, all (i) Documents related to Your acquisition of such Asset and (ii) Communications with the Debtor or the Debtor's Family regarding such Asset.\n\n16. Copies of Your tax returns.\n\n17. Documents sufficient to show all bank accounts and investment accounts within Your possession or control, including the balances of and transfers to and from each such account.\n\n18. All Documents regarding any credit cards used by You, including without limitation monthly statements or other Documents sufficient to show all purchases related thereto for the benefit of the Debtor or an Associated Entity.\n\n19. All corporate governance and organizational Documents, including without limitation by-laws and certificates of incorporation and other Documents sufficient to show Your corporate structure, names of officers and directors, business purpose, and relationship to the Debtor or to any member of the Debtor's Family.\n\n20. All Documents related to any pledge(s) of Your Assets to any other Entity.\n\n| Case 22-50073 | Doc 839 | Filed 09/07/22 | Entered 09/07/22 20:02:47 | Page 145 of |\n|-----------------------------------------------------------------|---------|----------------|---------------------------|-------------|\n| B2540 (Form 2540 – Subpoena for Rule 2004 Examination) (Page 2) | | 491 | | |\n| | | | | |\n\n| I received this subpoena for (name of individual and title, if any): ______________________________________________
on (date)
__________
I served the subpoena by delivering a copy to the named person
___________________________________________________________________________________________________
__________________________________
on (date) ___________________ ; or | as follows: ____________________________________ |\n|-----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|----------------------------------------------------------------------------|\n| | |\n| | |\n| | |\n| I returned the subpoena unexecuted because: ____________________________________________________________
___________________________________________________________________________________________________ | |\n| Unless the subpoena was issued on behalf of the United States, or one of its officers or agents, I have also tendered to the
witness the fees for one day's attendance, and the mileage allowed by law, in the amount of \\$ _______________________ . | |\n| My fees are \\$ _________
for travel and \\$_________ | for services, for a total of \\$_________ |\n| I declare under penalty of perjury
that this information is true and correct. | |\n| Date: _______________ | |\n| | ________________________________________________
Server's signature |\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; (ii) requires a person to comply beyond the geographical limits\n\nspecified in Rule 45(c); (iii) requires disclosure of privileged or other protected matter, if no\n\nexception or waiver applies; or\n\n(iv) subjects a person to undue burden.\n\n *(B) When Permitted.* To protect a person subject to or affected by a subpoena, the court for the district where compliance is required may, on motion, quash or modify the subpoena if it requires:\n\n (i) disclosing a trade secret or other confidential research, development, or commercial information; or\n\n (ii) disclosing an unretained expert's opinion or information that does not describe specific occurrences in dispute and results from the expert's study that was not requested by a party.\n\n *(C) Specifying Conditions as an Alternative.* In the circumstances described in Rule 45(d)(3)(B), the court may, instead of quashing or modifying a subpoena, order appearance or production under specified conditions if the serving party:\n\n (i) shows a substantial need for the testimony or material that cannot be otherwise met without undue hardship; and\n\n (ii) ensures that the subpoenaed person will be reasonably compensated.\n\n#### **(e) Duties in Responding to a Subpoena.**\n\n *(1) Producing Documents or Electronically Stored Information.* These procedures apply to producing documents or electronically stored information:\n\n *(A) Documents.* A person responding to a subpoena to produce documents must produce them as they are kept in the ordinary course of business or must organize and label them to correspond to the categories in the demand.\n\n *(B) Form for Producing Electronically Stored Information Not Specified.* If a subpoena does not specify a form for producing electronically stored information, the person responding must produce it in a form or forms in which it is ordinarily maintained or in a reasonably usable form or forms.\n\n *(C) Electronically Stored Information Produced in Only One Form.* The person responding need not produce the same electronically stored information in more than one form.\n\n *(D) Inaccessible Electronically Stored Information.* The person responding need not provide discovery of electronically stored information from sources that the person identifies as not reasonably accessible because of undue burden or cost. On motion to compel discovery or for a protective order, the person responding must show that the information is not reasonably accessible because of undue burden or cost. If that showing is made, the court may nonetheless order discovery from such sources if the requesting party shows good cause, considering the limitations of Rule 26(b)(2)(C). The court may specify conditions for the discovery.\n\n#### *(2) Claiming Privilege or Protection.*\n\n *(A) Information Withheld.* A person withholding subpoenaed information under a claim that it is privileged or subject to protection as trial-preparation material must:\n\n(i) expressly make the claim; and\n\n (ii) describe the nature of the withheld documents, communications, or tangible things in a manner that, without revealing information itself privileged or protected, will enable the parties to assess the claim.\n\n *(B) Information Produced.* If information produced in response to a subpoena is subject to a claim of privilege or of protection as trialpreparation material, the person making the claim may notify any party that received the information of the claim and the basis for it. After being notified, a party must promptly return, sequester, or destroy the specified information and any copies it has; must not use or disclose the information until the claim is resolved; must take reasonable steps to retrieve the information if the party disclosed it before being notified; and may promptly present the information under seal to the court for the district where compliance is required for a determination of the claim. The person who produced the information must preserve the information until the claim is resolved.\n\n**(g) Contempt.** The court for the district where compliance is required – and also, after a motion is transferred, the issuing court – may hold in contempt a person who, having been served, fails without adequate excuse to obey the subpoena or an order related to it.\n\nFor access to subpoena materials, see Fed. R. Civ. P. 45(a) Committee Note (2013)\n\n…\n\n## **Exhibit C-7**\n\n#### B2540 (Form 2540 – Subpoena for Rule 2004 Examination) (12/15) Case 22-50073 Doc 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 148 of 491\n\nUNITED STATES BANKRUPTCY COURT\n\n\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_ District of \\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_ Connecticut\n\nIn re \\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\n\nCase No. \\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_ Ho Wan Kwok 22-50073\n\nDebtor\n\nChapter \\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_ 11\n\n## **SUBPOENA FOR RULE 2004 EXAMINATION**\n\nTo: **\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_** William Je\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| Paul Hastings LLP
200 Park Avenue
New York, New York 10166 | |\n\nThe examination will be recorded by this method: \\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_ court reporter/stenographer\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: September \\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_ \\_\\_, 2022\n\nCLERK OF COURT\n\nOR\n\n\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_ *Signature of Clerk or Deputy Clerk* \\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_ *Attorney's signature* Patrick R. Linsey (ct29437)\n\nThe name, address, email address, and telephone number of the attorney representing *(name of party)* \\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_ , who issues or requests this subpoena, are: Luc Despins, Ch. 11 Trustee\n\nPatrick R. Linsey, Esq.; Neubert, Pepe & Monteith, P.C.; 195 Church Street, New Haven, Connecticut 06510 plinsey@npmlaw.com; 203-821-2000\n\n## **Notice to the person who issues or requests this subpoena**\n\nIf this subpoena commands the production of documents, electronically stored information, or tangible things, or the inspection of premises before trial, a notice and a copy of this subpoena must be served on each party before it is served on the person to whom it is directed. Fed. R. Civ. P. 45(a)(4).\n\n## **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 following 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 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 151 of 491\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
- | 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| | | |\n| FROM | John Smith | Email: Sender
Native: Author(s) of document |\n| | | |\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
time
zone
in
which
the
emails
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 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 152 of 491\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 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 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 153 of 491\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 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 154 of 491\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 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 155 of 491\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 othertenses.\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 William Je, 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\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 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 156 of 491\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: Daniel Podhaskie, Jason Miller, Steve Bannon, Karin Maistrello, Melissa Francis, William Gertz, Arethusa Forsyth, Glenn Mellor, Jennifer Mercurio, Eduardo Eurnekian, Han Chunguang (a/k/a 韩春光), Qu Guojiao (a/k/a Qu Guo Jiao, 屈国姣), Guo Lijie (a/k/a 郭丽杰), Zhang Wei (a/k/a 张伟\\*), Lihong Wei Lafrenz (a/k/a Sara Wei, 魏丽红), Hao Haidong (a/k/a 郝海东), Ross Heinemeyer, Max Krasner, Kyle Bass, Melissa Mendez, Ya Li (a/k/a 李娅), Dinggang Wang (a/k/a 王定刚), An Hong (a/k/a 安红), Yvette Wang (a/k/a Yanping Wang, Yan Ping Wang, 王雁平), Fiona Yu, Je Kin Ming (a/k/a William Je, Yu Jianming, 余建明 ), Yaz Qingua, and Lao Jiang (a/k/a Jiang Yunfu, Jiang Yunfu Be, 姜云浮).\n\n## Case 22-50073 Doc 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 157 of 491\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: 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, Assets Sino Limited, Auspicious Coast Limited, Beijing Pangu Investment Co., Beijing Pangu Investment Co. Ltd., Beijing Pangu Investment Inc., Beijing Zenith Holdings Company Limited, Bravo Luck Limited, 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, Elite Well Global Limited, Empire Growth Holdings, G Club Operations LLC, G Fashion LLC, G News LLC, GETTR USA, Genever Holdings Corporation, Genever Holdings LLC, GFASHION MEDIA GROUP INC., GFNY, Inc., Globalist International Limited, GNews Media Group Inc., Golden Spring (New York) Ltd., Greenwich Land LLC, Guo Media, GTV Media Group, Inc., Hamilton Capital Holdings Inc., Head Win Group Limited, Henan Yuda, Himalaya Embassy, Himalaya Exchange, Himalaya Federal Reserve, Himalaya Supervisory Organization, HK International Funds Investments (USA) Limited LLC, Hong Kong International Funds Investments Limited, Infinite Increase Limited, Infinitum Developments Limited, Insight Phoenix Fund, Lamp Capital LLC, Leading Shine Limited, Leading Shine NY Limited, Long Gate Limited, Next Tycoon Investments Limited, New\n\n## Case 22-50073 Doc 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 158 of 491\n\nFederal State of China (a/k/a NFSC), Noble Fame Global Limited, Rosy Acme Ventures Limited, Rule of Law Foundation III, Inc., Rule of Law Foundation IV, Inc., Rule of Law Fund, Rule of Law Society, Rule of Law Society IV, Inc., G-Translators PTY LTD, Saraca Media Group, Inc., Shiny Ace Ltd., Shiny Times Holdings Ltd., Spirit Charter Investment Limited, Stevenson, Wong & Co., Voice of Guo Media, Inc., Well Origin Ltd., World Century Limited, Worldwide Opportunity Holdings Limited, Whitecroft Shore 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\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\n\n## Case 22-50073 Doc 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 159 of 491\n\ncompilations 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\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,\n\n## Case 22-50073 Doc 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 160 of 491\n\nembodies, 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, 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 estate, 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\n\n## Case 22-50073 Doc 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 161 of 491\n\nobligations 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\n4. All Documents regarding any investment, business dealing or transactions made by, with, or on behalf of the Debtor.\n\n5. All Communications with the Debtor, and Documents related to Communications with the Debtor, 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, or an Associated Entity.\n\n7. All Documents regarding any property ever occupied or used by the Debtor, including without limitation the *Lady May*; the Sherry Netherland Hotel / Condominium; the residential property located in Greenwich, Connecticut at 373 Taconic Rd.; the residential property located in Greenwich, Connecticut at 33 Ferncliff Rd.; and the residential property located in Wilton, Connecticut at 354 Nod Hill Rd.\n\n8. All Documents related to any investments or trading by the Debtor, the Debtor's Family, or an Associated Entity, in or around July 2020, or at any other time, in crude oil futures\n\n## Case 22-50073 Doc 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 162 of 491\n\nor any similar commodity, including without limitation Communications with Jiang Yunfu Be regarding any such investments or trading.\n\n9. All Documents related to any aircraft owned, controlled, or used by the Debtor, including without limitation 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.\n\n10. 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\n11. 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\n12. 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\n13. All Documents and communications between any of your outside counsel or other advisors and the Debtor.\n\n## Case 22-50073 Doc 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 163 of 491\n\n14. Documents sufficient to show all of Your Assets and sources of income or funding.\n\n15. For all Assets identified in response to Request 14 having a value of more than \\$50,000, all (i) Documents related to Your acquisition of such Asset and (ii) Communications with the Debtor or the Debtor's Family regarding such Asset.\n\n16. Copies of Your tax returns.\n\n17. Documents sufficient to show all bank accounts and investment accounts within Your possession or control, including the balances of and transfers to and from each such account.\n\n18. All Documents regarding any credit cards used by You, including without limitation monthly statements or other Documents sufficient to show all purchases related thereto for the benefit of the Debtor or an Associated Entity.\n\n19. All Documents related to any pledge(s) of Your Assets to any other Entity.\n\n| Case 22-50073 | Doc 839 | Filed 09/07/22 | Entered 09/07/22 20:02:47 | Page 164 of |\n|-----------------------------------------------------------------|---------|----------------|---------------------------|-------------|\n| B2540 (Form 2540 – Subpoena for Rule 2004 Examination) (Page 2) | | 491 | | |\n| | | | | |\n\n| I received this subpoena for (name of individual and title, if any): ______________________________________________
on (date)
__________
I served the subpoena by delivering a copy to the named person
___________________________________________________________________________________________________
__________________________________
on (date) ___________________ ; or | as follows: ____________________________________ |\n|-----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|----------------------------------------------------------------------------|\n| | |\n| | |\n| | |\n| I returned the subpoena unexecuted because: ____________________________________________________________
___________________________________________________________________________________________________ | |\n| Unless the subpoena was issued on behalf of the United States, or one of its officers or agents, I have also tendered to the
witness the fees for one day's attendance, and the mileage allowed by law, in the amount of \\$ _______________________ . | |\n| My fees are \\$ _________
for travel and \\$_________ | for services, for a total of \\$_________ |\n| I declare under penalty of perjury
that this information is true and correct. | |\n| Date: _______________ | |\n| | ________________________________________________
Server's signature |\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; (ii) requires a person to comply beyond the geographical limits\n\nspecified in Rule 45(c);\n\n (iii) requires disclosure of privileged or other protected matter, if no exception or waiver applies; or\n\n(iv) subjects a person to undue burden.\n\n *(B) When Permitted.* To protect a person subject to or affected by a subpoena, the court for the district where compliance is required may, on motion, quash or modify the subpoena if it requires:\n\n (i) disclosing a trade secret or other confidential research, development, or commercial information; or\n\n (ii) disclosing an unretained expert's opinion or information that does not describe specific occurrences in dispute and results from the expert's study that was not requested by a party.\n\n *(C) Specifying Conditions as an Alternative.* In the circumstances described in Rule 45(d)(3)(B), the court may, instead of quashing or modifying a subpoena, order appearance or production under specified conditions if the serving party:\n\n (i) shows a substantial need for the testimony or material that cannot be otherwise met without undue hardship; and\n\n (ii) ensures that the subpoenaed person will be reasonably compensated.\n\n### **(e) Duties in Responding to a Subpoena.**\n\n *(1) Producing Documents or Electronically Stored Information.* These procedures apply to producing documents or electronically stored information:\n\n *(A) Documents.* A person responding to a subpoena to produce documents must produce them as they are kept in the ordinary course of business or must organize and label them to correspond to the categories in the demand.\n\n *(B) Form for Producing Electronically Stored Information Not Specified.* If a subpoena does not specify a form for producing electronically stored information, the person responding must produce it in a form or forms in which it is ordinarily maintained or in a reasonably usable form or forms.\n\n *(C) Electronically Stored Information Produced in Only One Form.* The person responding need not produce the same electronically stored information in more than one form.\n\n *(D) Inaccessible Electronically Stored Information.* The person responding need not provide discovery of electronically stored information from sources that the person identifies as not reasonably accessible because of undue burden or cost. On motion to compel discovery or for a protective order, the person responding must show that the information is not reasonably accessible because of undue burden or cost. If that showing is made, the court may nonetheless order discovery from such sources if the requesting party shows good cause, considering the limitations of Rule 26(b)(2)(C). The court may specify conditions for the discovery.\n\n### *(2) Claiming Privilege or Protection.*\n\n *(A) Information Withheld.* A person withholding subpoenaed information under a claim that it is privileged or subject to protection as trial-preparation material must:\n\n(i) expressly make the claim; and\n\n (ii) describe the nature of the withheld documents, communications, or tangible things in a manner that, without revealing information itself privileged or protected, will enable the parties to assess the claim.\n\n *(B) Information Produced.* If information produced in response to a subpoena is subject to a claim of privilege or of protection as trialpreparation material, the person making the claim may notify any party that received the information of the claim and the basis for it. After being notified, a party must promptly return, sequester, or destroy the specified information and any copies it has; must not use or disclose the information until the claim is resolved; must take reasonable steps to retrieve the information if the party disclosed it before being notified; and may promptly present the information under seal to the court for the district where compliance is required for a determination of the claim. The person who produced the information must preserve the information until the claim is resolved.\n\n**(g) Contempt.** The court for the district where compliance is required – and also, after a motion is transferred, the issuing court – may hold in contempt a person who, having been served, fails without adequate excuse to obey the subpoena or an order related to it.\n\nFor access to subpoena materials, see Fed. R. Civ. P. 45(a) Committee Note (2013)\n\n…\n\n## **Exhibit C-8**\n\n### B2540 (Form 2540 – Subpoena for Rule 2004 Examination) (12/15) UNITED STATES BANKRUPTCY COURT Case 22-50073 Doc 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 167 of 491\n\n\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_ District of \\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_ Connecticut\n\nIn re \\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\n\nCase No. \\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_ Ho Wan Kwok 22-50073\n\nDebtor\n\nChapter \\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_ 11\n\n## **SUBPOENA FOR RULE 2004 EXAMINATION**\n\nTo: **\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_** Max Krasner\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| Paul Hastings LLP
200 Park Avenue
New York, New York 10166 | |\n\nThe examination will be recorded by this method: \\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_ court reporter/stenographer\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: September \\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_ \\_\\_, 2022\n\nCLERK OF COURT\n\nOR\n\n\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_ *Signature of Clerk or Deputy Clerk* \\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_ *Attorney's signature* Patrick R. Linsey (ct29437)\n\nThe name, address, email address, and telephone number of the attorney representing *(name of party)* \\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_ , who issues or requests this subpoena, are: Luc Despins, Ch. 11 Trustee\n\nPatrick R. Linsey, Esq.; Neubert, Pepe & Monteith, P.C.; 195 Church Street, New Haven, Connecticut 06510 plinsey@npmlaw.com; 203-821-2000\n\n## **Notice to the person who issues or requests this subpoena**\n\nIf this subpoena commands the production of documents, electronically stored information, or tangible things, or the inspection of premises before trial, a notice and a copy of this subpoena must be served on each party before it is served on the person to whom it is directed. Fed. R. Civ. P. 45(a)(4).\n\n## **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 following 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 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 170 of 491\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
- | 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
time
zone
in
which
the
emails
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 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 171 of 491\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 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 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 172 of 491\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 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 173 of 491\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 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 174 of 491\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 othertenses.\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 Max Krasner, 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\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 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 175 of 491\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: Daniel Podhaskie, Jason Miller, Steve Bannon, Karin Maistrello, Melissa Francis, William Gertz, Arethusa Forsyth, Glenn Mellor, Jennifer Mercurio, Eduardo Eurnekian, Han Chunguang (a/k/a 韩春光), Qu Guojiao (a/k/a Qu Guo Jiao, 屈国姣), Guo Lijie (a/k/a 郭丽杰), Zhang Wei (a/k/a 张伟\\*), Lihong Wei Lafrenz (a/k/a Sara Wei, 魏丽红), Hao Haidong (a/k/a 郝海东), Ross Heinemeyer, Max Krasner, Kyle Bass, Melissa Mendez, Ya Li (a/k/a 李娅), Dinggang Wang (a/k/a 王定刚), An Hong (a/k/a 安红), Yvette Wang (a/k/a Yanping Wang, Yan Ping Wang, 王雁平), Fiona Yu, Je Kin Ming (a/k/a William Je, Yu Jianming, 余建明 ), Yaz Qingua, and Lao Jiang (a/k/a Jiang Yunfu, Jiang Yunfu Be, 姜云浮).\n\n## Case 22-50073 Doc 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 176 of 491\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: 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, Assets Sino Limited, Auspicious Coast Limited, Beijing Pangu Investment Co., Beijing Pangu Investment Co. Ltd., Beijing Pangu Investment Inc., Beijing Zenith Holdings Company Limited, Bravo Luck Limited, 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, Elite Well Global Limited, Empire Growth Holdings, G Club Operations LLC, G Fashion LLC, G News LLC, GETTR USA, Genever Holdings Corporation, Genever Holdings LLC, GFASHION MEDIA GROUP INC., GFNY, Inc., Globalist International Limited, GNews Media Group Inc., Golden Spring (New York) Ltd., Greenwich Land LLC, Guo Media, GTV Media Group, Inc., Hamilton Capital Holdings Inc., Head Win Group Limited, Henan Yuda, Himalaya Embassy, Himalaya Exchange, Himalaya Federal Reserve, Himalaya Supervisory Organization, HK International Funds Investments (USA) Limited LLC, Hong Kong International Funds Investments Limited, Infinite Increase Limited, Infinitum Developments Limited, Insight Phoenix Fund, Lamp Capital LLC, Leading Shine Limited, Leading Shine NY Limited, Long Gate Limited, Next Tycoon Investments Limited, New\n\n## Case 22-50073 Doc 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 177 of 491\n\nFederal State of China (a/k/a NFSC), Noble Fame Global Limited, Rosy Acme Ventures Limited, Rule of Law Foundation III, Inc., Rule of Law Foundation IV, Inc., Rule of Law Fund, Rule of Law Society, Rule of Law Society IV, Inc., G-Translators PTY LTD, Saraca Media Group, Inc., Shiny Ace Ltd., Shiny Times Holdings Ltd., Spirit Charter Investment Limited, Stevenson, Wong & Co., Voice of Guo Media, Inc., Well Origin Ltd., World Century Limited, Worldwide Opportunity Holdings Limited, Whitecroft Shore 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\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\n\n## Case 22-50073 Doc 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 178 of 491\n\ncompilations 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\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,\n\n## Case 22-50073 Doc 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 179 of 491\n\nembodies, 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, 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 estate, 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\n\n## Case 22-50073 Doc 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 180 of 491\n\nobligations 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\n4. All Documents regarding any investment, business dealing or transactions made by, with, or on behalf of the Debtor.\n\n5. All Communications with the Debtor, and Documents related to Communications with the Debtor, 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, or an Associated Entity.\n\n7. All Documents regarding any property ever occupied or used by the Debtor, including without limitation the *Lady May*; the Sherry Netherland Hotel / Condominium; the residential property located in Greenwich, Connecticut at 373 Taconic Rd.; the residential property located in Greenwich, Connecticut at 33 Ferncliff Rd.; and the residential property located in Wilton, Connecticut at 354 Nod Hill Rd.\n\n8. All Documents related to any investments or trading by the Debtor, the Debtor's Family, or an Associated Entity, in or around July 2020, or at any other time, in crude oil futures\n\n## Case 22-50073 Doc 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 181 of 491\n\nor any similar commodity, including without limitation Communications with Jiang Yunfu Be regarding any such investments or trading.\n\n9. All Documents related to any aircraft owned, controlled, or used by the Debtor, including without limitation 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.\n\n10. 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\n11. 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\n12. 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\n13. All Documents and communications between any of your outside counsel or other advisors and the Debtor.\n\n## Case 22-50073 Doc 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 182 of 491\n\n14. Documents sufficient to show all of Your Assets and sources of income or funding.\n\n15. For all Assets identified in response to Request 14 having a value of more than \\$50,000, all (i) Documents related to Your acquisition of such Asset and (ii) Communications with the Debtor or the Debtor's Family regarding such Asset.\n\n16. Copies of Your tax returns.\n\n17. Documents sufficient to show all bank accounts and investment accounts within Your possession or control, including the balances of and transfers to and from each such account.\n\n18. All Documents regarding any credit cards used by You, including without limitation monthly statements or other Documents sufficient to show all purchases related thereto for the benefit of the Debtor or an Associated Entity.\n\n19. All Documents related to any pledge(s) of Your Assets to any other Entity.\n\n| Case 22-50073 | Doc 839 | Filed 09/07/22 | Entered 09/07/22 20:02:47 | Page 183 of |\n|-----------------------------------------------------------------|---------|----------------|---------------------------|-------------|\n| B2540 (Form 2540 – Subpoena for Rule 2004 Examination) (Page 2) | | 491 | | |\n| | | | | |\n\n| | | (This section should not be filed with the court unless required by Fed. R. Civ. P. 45.) |\n|------------------------------------|----------------------------------------------------------------|------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|\n| on (date)
__________ | | I received this subpoena for (name of individual and title, if any): ______________________________________________ |\n| | I served the subpoena by delivering a copy to the named person | as follows: ____________________________________ |\n| __________________________________ | on (date) ___________________ ; or | ___________________________________________________________________________________________________ |\n| | | I returned the subpoena unexecuted because: ____________________________________________________________
___________________________________________________________________________________________________ |\n| My fees are \\$ _________ | for travel and \\$_________ | Unless the subpoena was issued on behalf of the United States, or one of its officers or agents, I have also tendered to the
witness the fees for one day's attendance, and the mileage allowed by law, in the amount of \\$ _______________________ .
for services, for a total of \\$_________ |\n| I declare under penalty of perjury | that this information is true and correct. | |\n| Date: _______________ | | |\n| | | ________________________________________________
Server's signature |\n| | | |\n\n*Server's address*\n\nAdditional information concerning attempted service, etc.:\n\n### **Federal Rule of Civil Procedure 45(c), (d), (e), and (g) (Effective 12/1/13) (made applicable in bankruptcy cases by Rule 9016, Federal Rules of Bankruptcy Procedure)**\n\n#### **(c) Place of compliance.**\n\n *(1) For a Trial, Hearing, or Deposition.* A subpoena may command a person to attend a trial, hearing, or deposition only as follows:\n\n (A) within 100 miles of where the person resides, is employed, or regularly transacts business in person; or\n\n (B) within the state where the person resides, is employed, or regularly transacts business in person, if the person\n\n(i) is a party or a party's officer; or\n\n (ii) is commanded to attend a trial and would not incur substantial expense.\n\n#### *(2) For Other Discovery.* A subpoena may command:\n\n (A) production of documents, or electronically stored information, or things at a place within 100 miles of where the person resides, is employed, or regularly transacts business in person; and\n\n(B) inspection of premises, at the premises to be inspected.\n\n#### **(d) Protecting a Person Subject to a Subpoena; Enforcement.**\n\n*(1) Avoiding Undue Burden or Expense; Sanctions.* A party or attorney responsible for issuing and serving a subpoena must take reasonable steps to avoid imposing undue burden or expense on a person subject to the subpoena. The court for the district where compliance is required must enforce this duty and impose an appropriate sanction which may include lost earnings and reasonable attorney's fees — on a party or attorney who fails to comply.\n\n#### *(2) Command to Produce Materials or Permit Inspection.*\n\n *(A) Appearance Not Required.* A person commanded to produce documents, electronically stored information, or tangible things, or to permit the inspection of premises, need not appear in person at the place of production or inspection unless also commanded to appear for a deposition, hearing, or trial.\n\n *(B) Objections*. A person commanded to produce documents or tangible things or to permit inspection may serve on the party or attorney designated in the subpoena a written objection to inspecting, copying, testing or sampling any or all of the materials or to inspecting the premises — or to producing electronically stored information in the form or forms requested. The objection must be served before the earlier of the time specified for compliance or 14 days after the subpoena is served. If an objection is made, the following rules apply:\n\n (i) At any time, on notice to the commanded person, the serving party may move the court for the district where compliance is required for an order compelling production or inspection.\n\n (ii) These acts may be required only as directed in the order, and the order must protect a person who is neither a party nor a party's officer from significant expense resulting from compliance.\n\n#### *(3) Quashing or Modifying a Subpoena.*\n\n *(A) When Required.* On timely motion, the court for the district where compliance is required must quash or modify a subpoena that:\n\n (i) fails to allow a reasonable time to comply; (ii) requires a person to comply beyond the geographical limits\n\nspecified in Rule 45(c); (iii) requires disclosure of privileged or other protected matter, if no\n\nexception or waiver applies; or\n\n(iv) subjects a person to undue burden.\n\n *(B) When Permitted.* To protect a person subject to or affected by a subpoena, the court for the district where compliance is required may, on motion, quash or modify the subpoena if it requires:\n\n (i) disclosing a trade secret or other confidential research, development, or commercial information; or\n\n (ii) disclosing an unretained expert's opinion or information that does not describe specific occurrences in dispute and results from the expert's study that was not requested by a party.\n\n *(C) Specifying Conditions as an Alternative.* In the circumstances described in Rule 45(d)(3)(B), the court may, instead of quashing or modifying a subpoena, order appearance or production under specified conditions if the serving party:\n\n (i) shows a substantial need for the testimony or material that cannot be otherwise met without undue hardship; and\n\n (ii) ensures that the subpoenaed person will be reasonably compensated.\n\n#### **(e) Duties in Responding to a Subpoena.**\n\n *(1) Producing Documents or Electronically Stored Information.* These procedures apply to producing documents or electronically stored information:\n\n *(A) Documents.* A person responding to a subpoena to produce documents must produce them as they are kept in the ordinary course of business or must organize and label them to correspond to the categories in the demand.\n\n *(B) Form for Producing Electronically Stored Information Not Specified.* If a subpoena does not specify a form for producing electronically stored information, the person responding must produce it in a form or forms in which it is ordinarily maintained or in a reasonably usable form or forms.\n\n *(C) Electronically Stored Information Produced in Only One Form.* The person responding need not produce the same electronically stored information in more than one form.\n\n *(D) Inaccessible Electronically Stored Information.* The person responding need not provide discovery of electronically stored information from sources that the person identifies as not reasonably accessible because of undue burden or cost. On motion to compel discovery or for a protective order, the person responding must show that the information is not reasonably accessible because of undue burden or cost. If that showing is made, the court may nonetheless order discovery from such sources if the requesting party shows good cause, considering the limitations of Rule 26(b)(2)(C). The court may specify conditions for the discovery.\n\n### *(2) Claiming Privilege or Protection.*\n\n *(A) Information Withheld.* A person withholding subpoenaed information under a claim that it is privileged or subject to protection as trial-preparation material must:\n\n(i) expressly make the claim; and\n\n (ii) describe the nature of the withheld documents, communications, or tangible things in a manner that, without revealing information itself privileged or protected, will enable the parties to assess the claim.\n\n *(B) Information Produced.* If information produced in response to a subpoena is subject to a claim of privilege or of protection as trialpreparation material, the person making the claim may notify any party that received the information of the claim and the basis for it. After being notified, a party must promptly return, sequester, or destroy the specified information and any copies it has; must not use or disclose the information until the claim is resolved; must take reasonable steps to retrieve the information if the party disclosed it before being notified; and may promptly present the information under seal to the court for the district where compliance is required for a determination of the claim. The person who produced the information must preserve the information until the claim is resolved.\n\n**(g) Contempt.** The court for the district where compliance is required – and also, after a motion is transferred, the issuing court – may hold in contempt a person who, having been served, fails without adequate excuse to obey the subpoena or an order related to it.\n\nFor access to subpoena materials, see Fed. R. Civ. P. 45(a) Committee Note (2013)\n\n…\n\n## **EXHIBIT C-9**\n\n#### B2540 (Form 2540 – Subpoena for Rule 2004 Examination) (12/15) Case 22-50073 Doc 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 186 of 491\n\nUNITED STATES BANKRUPTCY COURT\n\n\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_ District of \\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_ Connecticut\n\nIn re \\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\n\nCase No. \\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_ Ho Wan Kwok 22-50073\n\nDebtor\n\nChapter \\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_ 11\n\n## **SUBPOENA FOR RULE 2004 EXAMINATION**\n\nTo: **\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_** Acass Canada 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| Paul Hastings LLP
200 Park Avenue
New York, New York 10166 | |\n\nThe examination will be recorded by this method: \\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_ court reporter/stenographer\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: September \\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_ \\_\\_, 2022\n\nCLERK OF COURT\n\nOR\n\n\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_ *Signature of Clerk or Deputy Clerk* \\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_ *Attorney's signature* Patrick R. Linsey (ct29437)\n\nThe name, address, email address, and telephone number of the attorney representing *(name of party)* \\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_ , who issues or requests this subpoena, are: Luc Despins, Ch. 11 Trustee\n\nPatrick R. Linsey, Esq.; Neubert, Pepe & Monteith, P.C.; 195 Church Street, New Haven, Connecticut 06510 plinsey@npmlaw.com; 203-821-2000\n\n## **Notice to the person who issues or requests this subpoena**\n\nIf this subpoena commands the production of documents, electronically stored information, or tangible things, or the inspection of premises before trial, a notice and a copy of this subpoena must be served on each party before it is served on the person to whom it is directed. Fed. R. Civ. P. 45(a)(4).\n\n## **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 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 189 of 491\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
- | 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| | | |\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
time
zone
in
which
the
emails
were |\n| | | standardized during conversion. |\n| LINK | >EDC0000001.msg | Hyperlink to the email or native file document |\n| | | **The linked file must be named per the |\n| | | FIRSTBATES number |\n| FILE_EXTEN | MSG | The file type extension |\n| | | representing |\n| | | the Email or |\n| AUTHOR | John Smith | Email: (empty) |\n| | | Native: Author of the document |\n| DATE_CREATED | 10/10/2010 | Email: (empty) |\n| | | Native: Date the document was created |\n| | | |\n\n## Case 22-50073 Doc 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 190 of 491\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| | | |\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 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 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 191 of 491\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 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 192 of 491\n\nsuch Persons, as well as a statement addressing how the information came into their possession, (viii) the claim of privilege under which the Document is withheld, and (ix) all of the circumstances upon which You will rely to support such claim of privilege; and (b) produce a privilege log containing all of the information requested in Part (a) of this Instruction for each Document withheld on the basis of a claim of privilege in accordance with D. Conn. L. Civ. R. 26(e). For any part of a Document Request as to which a claim of privilege or work product is not made, responsive documents should be provided in full.\n\n9. If a portion of an otherwise responsive Document contains information subject to a claim of privilege, only that portion of the Document subject to the claim of privilege shall be deleted or redacted from the Document following the instructions above, and the rest shall be produced.\n\n10. The Requests are continuing in nature. You are hereby instructed to (a) supplement or correct any responses later learned to be incomplete or incorrect immediately upon learning that a prior response was incomplete or incorrect; and (b) produce any additional Documents that are called for under the\n\n11. If a Document is in a language other than English, You should provide that Document. If a Document is in a language other than English, and an English translation exists, You should provide both Documents.\n\n12. All references to Entities includes all affiliates thereof.\n\n13. All references to individual names include all alternative names, aliased, or nicknames.\n\n## Case 22-50073 Doc 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 193 of 491\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 othertenses.\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 ACASS Canada Limited, including its affiliated entities, including, without limitation, ACASS San Marino S.R.L and ACASS U.S.A. Inc., together with any of their employees, agents, counsel, advisors, or anyone acting on its behalf.\n\n## Case 22-50073 Doc 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 194 of 491\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. \"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: Daniel Podhaskie, Jason Miller, Steve Bannon, Karin Maistrello, Melissa Francis, William Gertz, Arethusa Forsyth, Glenn Mellor, Jennifer Mercurio, Eduardo Eurnekian, Han Chunguang (a/k/a 韩春光), Qu Guojiao (a/k/a Qu Guo Jiao, 屈国姣), Guo Lijie (a/k/a 郭丽杰), Zhang Wei (a/k/a 张伟\\*), Lihong Wei Lafrenz (a/k/a Sara Wei, 魏丽红), Hao Haidong (a/k/a 郝海东), Ross Heinemeyer, Max Krasner, Kyle Bass, Melissa Mendez, Ya Li\n\n## Case 22-50073 Doc 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 195 of 491\n\n(a/k/a 李娅), Dinggang Wang (a/k/a 王定刚), An Hong (a/k/a 安红), Yvette Wang (a/k/a Yanping Wang, Yan Ping Wang, 王雁平), Fiona Yu, Je Kin Ming (a/k/a William Je, Yu Jianming, 余建明 ), Yaz Qingua, and Lao Jiang (a/k/a Jiang Yunfu, Jiang Yunfu Be, 姜云浮).\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: 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, Assets Sino Limited, Auspicious Coast Limited, Beijing Pangu Investment Co., Beijing Pangu Investment Co. Ltd., Beijing Pangu Investment Inc., Beijing Zenith Holdings Company Limited, Bravo Luck Limited, 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, Elite Well Global Limited, Empire Growth Holdings, G Club Operations LLC, G Fashion LLC, G News LLC, GETTR USA, Genever Holdings Corporation, Genever Holdings LLC, GFASHION MEDIA GROUP INC., GFNY, Inc., Globalist International Limited, GNews Media Group Inc., Golden Spring (New York) Ltd., Greenwich Land LLC, Guo Media, GTV Media Group, Inc., Hamilton Capital Holdings Inc., Head Win Group Limited, Henan Yuda, Himalaya Embassy, Himalaya Exchange, Himalaya Federal Reserve, Himalaya Supervisory Organization, HK International Funds Investments (USA)\n\n## Case 22-50073 Doc 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 196 of 491\n\nLimited LLC, Hong Kong International Funds Investments Limited, Infinite Increase Limited, Infinitum Developments Limited, Insight Phoenix Fund, Lamp Capital LLC, Leading Shine Limited, Leading Shine NY Limited, Long Gate Limited, Next Tycoon Investments Limited, New Federal State of China (a/k/a NFSC), Noble Fame Global Limited, Rosy Acme Ventures Limited, Rule of Law Foundation III, Inc., Rule of Law Foundation IV, Inc., Rule of Law Fund, Rule of Law Society, Rule of Law Society IV, Inc., G-Translators PTY LTD, Saraca Media Group, Inc., Shiny Ace Ltd., Shiny Times Holdings Ltd., Spirit Charter Investment Limited, Stevenson, Wong & Co., Voice of Guo Media, Inc., Well Origin Ltd., World Century Limited, Worldwide Opportunity Holdings Limited, Whitecroft Shore 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\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, correspondence, memoranda, tapes, stenographic or handwritten notes, written forms of any kind,\n\n## Case 22-50073 Doc 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 197 of 491\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\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,\n\n## Case 22-50073 Doc 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 198 of 491\n\nconnected 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, 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\n21. \"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\n22. \"Aircraft\" means any vehicle for traveling through the air, including, without limitation, airplanes and helicopters, that are or were at any time owned, used, controlled, purchased, sold, leased, rented, licensed, serviced, maintained, repaired, overhauled, stored,\n\n## Case 22-50073 Doc 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 199 of 491\n\noperated, marketed, or inspected by, to, or for the benefit of the Debtor, the Debtor's Family, or any Associated Entity, including, without limitation, any aircraft that are or were ever identified by or associated with the following alphanumeric sequences: T7-GQM, T7-17777, M-GYQM, SN9189, or 9189.\n\n23. \"Aircraft Staff\" means any employee, independent contractor, pilot, co-pilot, mechanic, flight attendant, or individual associated with the maintenance, operation, service, upkeep, or storage of an Aircraft.\n\n### **IV. DOCUMENTS TO BE PRODUCED**\n\n1. All Documents related to any income or Asset of the Debtor, the Debtor's estate, the Debtor's Family, an Associated Entity, or an Associated Individual.\n\n2. All Documents related to the Debtor, the Debtor's estate, the Debtor's Family, an Associated Entity, or an Associated Individual and any Aircraft, including without limitation (i) ownership or control of any Aircraft; (ii) use of any Aircraft; (iii) lease or rental of any Aircraft; (iv) the purchase, sale, or marketing of any Aircraft; (v) any money or value paid or given related to any Aircraft and the source thereof; (vi) any money or value generated or obtained related to any Aircraft and the disposition thereof; or (vii) operation, maintenance, service, or overhaul, related to any Aircraft\n\n3. All Documents related to any account associated with the Debtor, the Debtor's estate, the Debtor's Family, an Associated Entity, or an Associated Individual.\n\n4. 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, or an Associated Individual.\n\n## Case 22-50073 Doc 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 200 of 491\n\n5. All Documents related to any flight logs, flight plans, or any other recording of any flight information related to travels undertaken, or planned by the Debtor, the Debtor's estate, the Debtor's Family, an Associated Entity, or an Associated Individual.\n\n6. All Documents related to any activates by Aircraft Staff related the Debtor, the Debtor's estate, the Debtor's Family, an Associated Entity, or an Associated Individual.\n\n7. All Documents related to any payments, expenses, transfers or monies related to Aircraft Staff and the Debtor, the Debtor's estate, the Debtor's Family, an Associated Entity, or an Associated Individual.\n\n8. All Documents related to who may have been onboard any Aircraft in use by the Debtor, the Debtor's estate, the Debtor's Family, an Associated Entity, or an Associated Individual, including any flight manifests.\n\n9. All Documents related to any cargo, storage, items for delivery, assets or property on an Aircraft related to the Debtor, the Debtor's estate, the Debtor's Family, an Associated Entity, or an Associated Individual.\n\n10. All Documents related to the location of the Aircraft.\n\n## **EXHIBIT C-10**\n\n### B2540 (Form 2540 – Subpoena for Rule 2004 Examination) (12/15) UNITED STATES BANKRUPTCY COURT Case 22-50073 Doc 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 202 of 491\n\n\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_ District of \\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_ Connecticut\n\nIn re \\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\n\nCase No. \\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_ Ho Wan Kwok 22-50073\n\nDebtor\n\nChapter \\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_ 11\n\n## **SUBPOENA FOR RULE 2004 EXAMINATION**\n\nTo: **\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_** Yachtzoo SARL\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| Paul Hastings LLP
200 Park Avenue
New York, New York 10166 | |\n\nThe examination will be recorded by this method: \\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_ court reporter/stenographer\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: September \\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_ \\_\\_, 2022\n\nCLERK OF COURT\n\nOR\n\n\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_ *Signature of Clerk or Deputy Clerk* \\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_ *Attorney's signature* Patrick R. Linsey (ct29437)\n\nThe name, address, email address, and telephone number of the attorney representing *(name of party)* \\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_ , who issues or requests this subpoena, are: Luc Despins, Ch. 11 Trustee\n\nPatrick R. Linsey, Esq.; Neubert, Pepe & Monteith, P.C.; 195 Church Street, New Haven, Connecticut 06510 plinsey@npmlaw.com; 203-821-2000\n\n## **Notice to the person who issues or requests this subpoena**\n\nIf this subpoena commands the production of documents, electronically stored information, or tangible things, or the inspection of premises before trial, a notice and a copy of this subpoena must be served on each party before it is served on the person to whom it is directed. Fed. R. Civ. P. 45(a)(4).\n\n## **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 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 205 of 491\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| | | | | |\n| ATTACHRANGE | EDC0000001
- | 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
time
zone
in
which
the
emails
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| | | | | |\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 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 206 of 491\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| | | | | |\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 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 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 207 of 491\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 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 208 of 491\n\nsuch Persons, as well as a statement addressing how the information came into their possession, (viii) the claim of privilege under which the Document is withheld, and (ix) all of the circumstances upon which You will rely to support such claim of privilege; and (b) produce a privilege log containing all of the information requested in Part (a) of this Instruction for each Document withheld on the basis of a claim of privilege in accordance with D. Conn. L. Civ. R. 26(e). For any part of a Document Request as to which a claim of privilege or work product is not made, responsive documents should be provided in full.\n\n9. If a portion of an otherwise responsive Document contains information subject to a claim of privilege, only that portion of the Document subject to the claim of privilege shall be deleted or redacted from the Document following the instructions above, and the rest shall be produced.\n\n10. The Requests are continuing in nature. You are hereby instructed to (a) supplement or correct any responses later learned to be incomplete or incorrect immediately upon learning that a prior response was incomplete or incorrect; and (b) produce any additional Documents that are called for under the\n\n11. If a Document is in a language other than English, You should provide that Document. If a Document is in a language other than English, and an English translation exists, You should provide both Documents.\n\n12. All references to Entities includes all affiliates thereof.\n\n13. All references to individual names include all alternative names, aliased, or nicknames.\n\n## Case 22-50073 Doc 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 209 of 491\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 othertenses.\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 Yachtzoo SARL, including its parents, subsidiaries, and affiliates, together with any of their employees, agents, counsel, advisors, 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\n## Case 22-50073 Doc 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 210 of 491\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. \"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: Daniel Podhaskie, Jason Miller, Steve Bannon, Karin Maistrello, Melissa Francis, William Gertz, Arethusa Forsyth, Glenn Mellor, Jennifer Mercurio, Eduardo Eurnekian, Han Chunguang (a/k/a 韩春光), Qu Guojiao (a/k/a Qu Guo Jiao, 屈国姣), Guo Lijie (a/k/a 郭丽杰), Zhang Wei (a/k/a 张伟\\*), Lihong Wei Lafrenz (a/k/a Sara Wei, 魏丽红), Hao Haidong (a/k/a 郝海东), Ross Heinemeyer, Max Krasner, Kyle Bass, Melissa Mendez, Ya Li\n\n(a/k/a 李娅), Dinggang Wang (a/k/a 王定刚), An Hong (a/k/a 安红), Yvette Wang (a/k/a Yanping\n\n## Case 22-50073 Doc 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 211 of 491\n\nWang, Yan Ping Wang, 王雁平), Fiona Yu, Je Kin Ming (a/k/a William Je, Yu Jianming, 余建明 ), Yaz Qingua, and Lao Jiang (a/k/a Jiang Yunfu, Jiang Yunfu Be, 姜云浮).\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: 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, Assets Sino Limited, Auspicious Coast Limited, Beijing Pangu Investment Co., Beijing Pangu Investment Co. Ltd., Beijing Pangu Investment Inc., Beijing Zenith Holdings Company Limited, Bravo Luck Limited, 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, Elite Well Global Limited, Empire Growth Holdings, G Club Operations LLC, G Fashion LLC, G News LLC, GETTR USA, Genever Holdings Corporation, Genever Holdings LLC, GFASHION MEDIA GROUP INC., GFNY, Inc., Globalist International Limited, GNews Media Group Inc., Golden Spring (New York) Ltd., Greenwich Land LLC, Guo Media, GTV Media Group, Inc., Hamilton Capital Holdings Inc., Head Win Group Limited, Henan Yuda, Himalaya Embassy, Himalaya Exchange, Himalaya Federal Reserve, Himalaya Supervisory Organization, HK International Funds Investments (USA) Limited LLC, Hong Kong International Funds Investments Limited, Infinite Increase Limited,\n\n## Case 22-50073 Doc 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 212 of 491\n\nInfinitum Developments Limited, Insight Phoenix Fund, Lamp Capital LLC, Leading Shine Limited, Leading Shine NY Limited, Long Gate Limited, Next Tycoon Investments Limited, New Federal State of China (a/k/a NFSC), Noble Fame Global Limited, Rosy Acme Ventures Limited, Rule of Law Foundation III, Inc., Rule of Law Foundation IV, Inc., Rule of Law Fund, Rule of Law Society, Rule of Law Society IV, Inc., G-Translators PTY LTD, Saraca Media Group, Inc., Shiny Ace Ltd., Shiny Times Holdings Ltd., Spirit Charter Investment Limited, Stevenson, Wong & Co., Voice of Guo Media, Inc., Well Origin Ltd., World Century Limited, Worldwide Opportunity Holdings Limited, Whitecroft Shore 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\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, correspondence, memoranda, tapes, stenographic or handwritten notes, written forms of any kind, charts, blueprints, drawings, sketches, graphs, plans, articles, specifications, diaries, letters,\n\n## Case 22-50073 Doc 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 213 of 491\n\ntelegrams, 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\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\n## Case 22-50073 Doc 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 214 of 491\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, 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\n21. \"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\n22. \"*Lady May* Stipulated Order\" means that *Stipulated Order Compelling HK International Funds Investments (USA) Limited, LLC to Transport and Deliver that Certain Yacht, the \"Lady May\"* entered April 29, 2022 in the chapter 11 case pending in the U.S. Bankruptcy Court for the District of Connecticut and styled *In re Ho Wan Kwok*, case no. 22-50073-JAM [Docket No. 299].\n\n## Case 22-50073 Doc 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 215 of 491\n\n23. \"*Lady May*\" means that pleasure yacht discussed in the *Lady May* Stipulated Order.\n\n24. \"Vessel\" means any vehicle for traveling through or over water, including, without limitation, boats, ships, personal watercraft, submersible craft, or amphibious craft, 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, or any Associated Entity, including, without limitation, the *Lady May*.\n\n25. \"Vessel Staff\" means any employee, independent contractor, captain, mate, deckhand, crew, steward, mechanic, or individual associated with the maintenance, operation, service, upkeep, or storage of a Vessel.\n\n## **IV. DOCUMENTS TO BE PRODUCED**\n\n1. All Documents related to any income or Asset of the Debtor, the Debtor's estate, the Debtor's Family, or Associated Entity.1\n\n2. All Documents related to the Debtor, the Debtor's estate, the Debtor's Family, or Associated Entity and any Vessel. 2\n\n3. All Documents related to the Debtor, the Debtor's estate, the Debtor's Family, or Associated Entity and ownership or control of any Vessel.\n\n4. All Documents related to the Debtor, the Debtor's estate, the Debtor's Family, or Associated Entity and any money or value paid or given related to any Vessel and the source thereof.\n\n1 Without limitation, note that the term Associated Entity is inclusive of HK International Funds Investments (USA) Limited LLC.\n\n2 Without limitation, note that the term Vessel is inclusive of the *Lady May.*\n\n## Case 22-50073 Doc 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 216 of 491\n\n5. All Documents related to the Debtor, the Debtor's estate, the Debtor's Family, or Associated Entity and any money or value generated or obtained related to any Vessel and the disposition thereof.\n\n6. All Documents related to the Debtor, the Debtor's estate, the Debtor's Family, or Associated Entity and use of any Vessel.\n\n7. All Documents related to the Debtor, the Debtor's estate, the Debtor's Family, or Associated Entity and operation, maintenance, service, or overhaul, related to any Vessel.\n\n8. All Documents related to the Debtor, the Debtor's estate, the Debtor's Family, or Associated Entity and lease or rental of any Vessel.\n\n9. All Documents related to the Debtor, the Debtor's estate, the Debtor's Family, or Associated Entity and the purchase, sale, or marketing of any Vessel.\n\n10. All Documents related to any account associated with the Debtor, the Debtor's estate, the Debtor's Family, or Associated Entity.\n\n11. All Documents related to any invoices or payments of expenses related to the Debtor, the Debtor's estate, the Debtor's Family, or Associated Entity.\n\n12. All Documents related to any logs, plans, docking records, or any other recording of information related to travels undertaken, or planned by the Debtor, the Debtor's estate, the Debtor's Family, or Associated Entity on any Vessel.\n\n13. All Documents related to any Vessel Staff related to any activates by them related the Debtor, the Debtor's estate, the Debtor's Family, or Associated Entity.\n\n14. All Documents related to any payments, expenses, transfers or monies related to Vessel Staff and the Debtor, the Debtor's estate, the Debtor's Family, or Associated Entity.\n\n## Case 22-50073 Doc 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 217 of 491\n\n15. All Documents related to who may have been onboard any Vessel in use by the Debtor, the Debtor's estate, the Debtor's Family, or Associated Entity.\n\n16. All Documents related to any cargo, storage, items for delivery, assets or property on a Vessel related to the Debtor, the Debtor's estate, the Debtor's Family, or Associated Entity.\n\n## **Exhibit C-11**\n\n### B2540 (Form 2540 – Subpoena for Rule 2004 Examination) (12/15) UNITED STATES BANKRUPTCY COURT Case 22-50073 Doc 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 219 of 491\n\n\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_ District of \\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_ Connecticut\n\nIn re \\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\n\nCase No. \\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_ Ho Wan Kwok 22-50073\n\nDebtor\n\nChapter \\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_ 11\n\n## **SUBPOENA FOR RULE 2004 EXAMINATION**\n\nTo: **\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_ Berkeley Rowe**\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| Paul Hastings LLP
200 Park Avenue
New York, New York 10166 | |\n\nThe examination will be recorded by this method: \\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_ court reporter/stenographer\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: Sept\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_ ember \\_\\_, 2022\n\nCLERK OF COURT\n\nOR\n\n\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_ *Signature of Clerk or Deputy Clerk* \\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_ *Attorney's signature* Patrick R. Linsey (ct29437)\n\nThe name, address, email address, and telephone number of the attorney representing *(name of party)* \\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_ , who issues or requests this subpoena, are: Luc Despins, Ch. 11 Trustee\n\nPatrick R. Linsey, Esq.; Neubert, Pepe & Monteith, P.C.; 195 Church Street, New Haven, Connecticut 06510 plinsey@npmlaw.com; 203-821-2000\n\n## **Notice to the person who issues or requests this subpoena**\n\nIf this subpoena commands the production of documents, electronically stored information, or tangible things, or the inspection of premises before trial, a notice and a copy of this subpoena must be served on each party before it is served on the person to whom it is directed. Fed. R. Civ. P. 45(a)(4).\n\n## **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 following 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 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 222 of 491\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
- | 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| | | | | |\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
time
zone
in
which
the
emails
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 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 223 of 491\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 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 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 224 of 491\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 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 225 of 491\n\nsuch Persons, as well as a statement addressing how the information came into their possession, (viii) the claim of privilege under which the Document is withheld, and (ix) all of the circumstances upon which You will rely to support such claim of privilege; and (b) produce a privilege log containing all of the information requested in Part (a) of this Instruction for each Document withheld on the basis of a claim of privilege in accordance with D. Conn. L. Civ. R. 26(e). For any part of a Document Request as to which a claim of privilege or work product is not made, responsive documents should be provided in full.\n\n9. If a portion of an otherwise responsive Document contains information subject to a claim of privilege, only that portion of the Document subject to the claim of privilege shall be deleted or redacted from the Document following the instructions above, and the rest shall be produced.\n\n10. The Requests are continuing in nature. You are hereby instructed to (a) supplement or correct any responses later learned to be incomplete or incorrect immediately upon learning that a prior response was incomplete or incorrect; and (b) produce any additional Documents that are called for under the\n\n11. If a Document is in a language other than English, You should provide that Document. If a Document is in a language other than English, and an English translation exists, You should provide both Documents.\n\n12. All references to Entities includes all affiliates thereof.\n\n13. All references to individual names include all alternative names, aliased, or nicknames.\n\n## Case 22-50073 Doc 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 226 of 491\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 othertenses.\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 Berkeley Rowe, together with any of its employees, agents, counsel, advisors, 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 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 227 of 491\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. \"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: Daniel Podhaskie, Jason Miller, Steve Bannon, Karin Maistrello, Melissa Francis, William Gertz, Arethusa Forsyth, Glenn Mellor, Jennifer Mercurio, Eduardo Eurnekian, Han Chunguang (a/k/a 韩春光), Qu Guojiao (a/k/a Qu Guo Jiao, 屈国姣), Guo Lijie (a/k/a 郭丽杰), Zhang Wei (a/k/a 张伟\\*), Lihong Wei Lafrenz (a/k/a Sara Wei, 魏丽红), Hao Haidong (a/k/a 郝海东), Ross Heinemeyer, Max Krasner, Kyle Bass, Melissa Mendez, Ya Li (a/k/a 李娅), Dinggang Wang (a/k/a 王定刚), An Hong (a/k/a 安红), Yvette Wang (a/k/a Yanping\n\n## Case 22-50073 Doc 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 228 of 491\n\nWang, Yan Ping Wang, 王雁平), Fiona Yu, Je Kin Ming (a/k/a William Je, Yu Jianming, 余建明\n\n), Yaz Qingua, and Lao Jiang (a/k/a Jiang Yunfu, Jiang Yunfu Be, 姜云浮).\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: 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, Assets Sino Limited, Auspicious Coast Limited, Beijing Pangu Investment Co., Beijing Pangu Investment Co. Ltd., Beijing Pangu Investment Inc., Beijing Zenith Holdings Company Limited, Bravo Luck Limited, 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, Elite Well Global Limited, Empire Growth Holdings, G Club Operations LLC, G Fashion LLC, G News LLC, GETTR USA, Genever Holdings Corporation, Genever Holdings LLC, GFASHION MEDIA GROUP INC., GFNY, Inc., Globalist International Limited, GNews Media Group Inc., Golden Spring (New York) Ltd., Greenwich Land LLC, Guo Media, GTV Media Group, Inc., Hamilton Capital Holdings Inc., Head Win Group Limited, Henan Yuda, Himalaya Embassy, Himalaya Exchange, Himalaya Federal Reserve, Himalaya Supervisory Organization, HK International Funds Investments (USA)\n\n## Case 22-50073 Doc 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 229 of 491\n\nLimited LLC, Hong Kong International Funds Investments Limited, Infinite Increase Limited, Infinitum Developments Limited, Insight Phoenix Fund, Lamp Capital LLC, Leading Shine Limited, Leading Shine NY Limited, Long Gate Limited, Next Tycoon Investments Limited, New Federal State of China (a/k/a NFSC), Noble Fame Global Limited, Rosy Acme Ventures Limited, Rule of Law Foundation III, Inc., Rule of Law Foundation IV, Inc., Rule of Law Fund, Rule of Law Society, Rule of Law Society IV, Inc., G-Translators PTY LTD, Saraca Media Group, Inc., Shiny Ace Ltd., Shiny Times Holdings Ltd., Spirit Charter Investment Limited, Stevenson, Wong & Co., Voice of Guo Media, Inc., Well Origin Ltd., World Century Limited, Worldwide Opportunity Holdings Limited, Whitecroft Shore 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\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, correspondence, memoranda, tapes, stenographic or handwritten notes, written forms of any kind,\n\n## Case 22-50073 Doc 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 230 of 491\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\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,\n\n## Case 22-50073 Doc 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 231 of 491\n\nconnected 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, 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\n21. \"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 income or Asset of the Debtor, the Debtor's estate, the Debtor's Family, or Associated Entity.\n\n## Case 22-50073 Doc 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 232 of 491\n\n2. All Documents related to any engagement letter with the Debtor, any member of the Debtor's Family, and/or any Associated Entity, including copy(ies) of such engagement letter(s).\n\n3. All Documents related to the payment of any retainer to You based upon your representation of the Debtor, the Debtor's Family, or an Associated Entity, including documents sufficient to identify the amount of the retainer and its source.\n\n4. All Documents related to any fees, payments, or monies received by You from or on behalf of the Debtor, the Debtor's Family, a Family Related Entity, or an Associated Entity held in escrow or in a client trust account.\n\n5. Documents sufficient to show the amount, date, and source of any payments made to You by or for the benefit of the Debtor, the Debtor's Family, or an Associated Entity.\n\n6. 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\n7. All Documents related to the Associated Entities, including but not limited to Documents related to their corporate structure, Assets, incorporation information, officers and directors, business purpose, and relationship to the Debtor, to any member of the Debtor's Family, or to any Associated Individual.\n\n8. All Documents regarding any investment or business dealing made by, with, or on behalf of Debtor or the Debtor's Family, on the one hand, and an Associated Entity, on the other hand.\n\n## Case 22-50073 Doc 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 233 of 491\n\n9. All Documents related to any Entity that the Debtor, the Debtor's Estate, the Debtor's Family, or the Associated Entities hold any interest or investment in, including but not limited to the nature and value of that interest or investment; any proceeds or benefits from such Entity that the Debtor, the Debtor's Estate, the Debtor's Family, or the Associated Entities receive on account of such interest or investment; and all Documents relating to any financial reporting or data relating to such Entity, including but not limited to all books and records, financial statements or tax Documents.\n\n10. All Documents regarding the *Lady May*; the Sherry Netherland Hotel / Condominium; 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.; and any financial interest that the Debtor or the Debtor's estate possesses in any Associated Entity.\n\n11. All Documents related to the purported Declaration of Trust and Agreement, dated February 17, 2015, entered into by the Debtor, as Trustee, Genever Holdings Corporation, and Genever Holdings LLC, in favor of Bravo Luck Limited, as beneficiary.\n\n12. All Documents related to any aircraft owned, controlled, or used by the Debtor, including without limitation the aircraft bearing tail number T7-GQM 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.\n\n13. All Documents related to any investments or trading by the Debtor, the Debtor's Family, or an Associated Entity, in or around July 2020, or at any other time, in crude oil futures or any similar commodity, including without limitation Communications with Jiang Yunfu Be regarding any such investments or trading.\n\n## Case 22-50073 Doc 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 234 of 491\n\n14. All Communications between You and, either, the Debtor, the Debtor's Family, or any Associated Individual, agent, employee, or other individual acting on behalf of the Debtor, related to any Transfer, investment, or other transaction or business dealing relating to the Debtor, the Debtor's Estate, the Debtor's Family, or the Associated Entities.\n\n15. All Documents concerning any trust or similar instrument set up by, on behalf of, or for the benefit of Debtor, Debtor's Estate, Debtor's Family, or Associated Entities, including but not limited to Documents showing when the trust(s) was created, by whom it was created, to whose benefit it was created, and the corpus of the instrument.\n\n16. All Documents related to any sale, acquisition, disposition, purchase, investment, contribution, gift, extension of credit, loan, or Transfer involving the Debtor, the Debtor's Family, or any Associated Entity.\n\n17. 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\n18. All Documents related to any loans or extensions of credit, or applications for the same, to or from the Debtor, the Debtor's Estate, the Debtor's Family or any Associated Entity, including but not limited to (i) the terms of any such loans or extensions of credit, including their terms of repayment, representations and warranties, and interest rate, and (ii) all evidence of payments of the loans.\n\n## Case 22-50073 Doc 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 235 of 491\n\n19. All Documents related to the Debtor's use of any Assets belonging to, controlled by, or whose complete or partial ownership is held by the Debtor's Family, an Associated Entity, or an Associated Individual.\n\n20. 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\n21. All Documents related to any pledges of Assets of any Associated Entity, including Bravo Luck Limited, to any other Entity.\n\n| Case 22-50073 | Doc 839 | Filed 09/07/22 | | Entered 09/07/22 20:02:47 | Page 236 of |\n|-----------------------------------------------------------------|---------|----------------|-----|---------------------------|-------------|\n| B2540 (Form 2540 – Subpoena for Rule 2004 Examination) (Page 2) | | | 491 | | |\n| | | | | | |\n\n| | | (This section should not be filed with the court unless required by Fed. R. Civ. P. 45.) |\n|------------------------------------|----------------------------------------------------------------|------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|\n| on (date)
__________ | | I received this subpoena for (name of individual and title, if any): ______________________________________________ |\n| | I served the subpoena by delivering a copy to the named person | as follows: ____________________________________
___________________________________________________________________________________________________ |\n| __________________________________ | on (date) ___________________ ; or | |\n| | | I returned the subpoena unexecuted because: ____________________________________________________________
___________________________________________________________________________________________________ |\n| | | |\n| My fees are \\$ _________ | for travel and \\$_________ | Unless the subpoena was issued on behalf of the United States, or one of its officers or agents, I have also tendered to the
witness the fees for one day's attendance, and the mileage allowed by law, in the amount of \\$ _______________________ .
for services, for a total of \\$_________ |\n| I declare under penalty of perjury | that this information is true and correct. | |\n| | | |\n| Date: _______________ | | ________________________________________________
Server's signature |\n\n*Server's address*\n\nAdditional information concerning attempted service, etc.:\n\n### **Federal Rule of Civil Procedure 45(c), (d), (e), and (g) (Effective 12/1/13) (made applicable in bankruptcy cases by Rule 9016, Federal Rules of Bankruptcy Procedure)**\n\n#### **(c) Place of compliance.**\n\n *(1) For a Trial, Hearing, or Deposition.* A subpoena may command a person to attend a trial, hearing, or deposition only as follows:\n\n (A) within 100 miles of where the person resides, is employed, or regularly transacts business in person; or\n\n (B) within the state where the person resides, is employed, or regularly transacts business in person, if the person\n\n(i) is a party or a party's officer; or\n\n (ii) is commanded to attend a trial and would not incur substantial expense.\n\n#### *(2) For Other Discovery.* A subpoena may command:\n\n (A) production of documents, or electronically stored information, or things at a place within 100 miles of where the person resides, is employed, or regularly transacts business in person; and\n\n(B) inspection of premises, at the premises to be inspected.\n\n#### **(d) Protecting a Person Subject to a Subpoena; Enforcement.**\n\n*(1) Avoiding Undue Burden or Expense; Sanctions.* A party or attorney responsible for issuing and serving a subpoena must take reasonable steps to avoid imposing undue burden or expense on a person subject to the subpoena. The court for the district where compliance is required must enforce this duty and impose an appropriate sanction which may include lost earnings and reasonable attorney's fees — on a party or attorney who fails to comply.\n\n#### *(2) Command to Produce Materials or Permit Inspection.*\n\n *(A) Appearance Not Required.* A person commanded to produce documents, electronically stored information, or tangible things, or to permit the inspection of premises, need not appear in person at the place of production or inspection unless also commanded to appear for a deposition, hearing, or trial.\n\n *(B) Objections*. A person commanded to produce documents or tangible things or to permit inspection may serve on the party or attorney designated in the subpoena a written objection to inspecting, copying, testing or sampling any or all of the materials or to inspecting the premises — or to producing electronically stored information in the form or forms requested. The objection must be served before the earlier of the time specified for compliance or 14 days after the subpoena is served. If an objection is made, the following rules apply:\n\n (i) At any time, on notice to the commanded person, the serving party may move the court for the district where compliance is required for an order compelling production or inspection.\n\n (ii) These acts may be required only as directed in the order, and the order must protect a person who is neither a party nor a party's officer from significant expense resulting from compliance.\n\n#### *(3) Quashing or Modifying a Subpoena.*\n\n *(A) When Required.* On timely motion, the court for the district where compliance is required must quash or modify a subpoena that:\n\n (i) fails to allow a reasonable time to comply; (ii) requires a person to comply beyond the geographical limits\n\nspecified in Rule 45(c);\n\n (iii) requires disclosure of privileged or other protected matter, if no exception or waiver applies; or\n\n(iv) subjects a person to undue burden.\n\n *(B) When Permitted.* To protect a person subject to or affected by a subpoena, the court for the district where compliance is required may, on motion, quash or modify the subpoena if it requires:\n\n (i) disclosing a trade secret or other confidential research, development, or commercial information; or\n\n (ii) disclosing an unretained expert's opinion or information that does not describe specific occurrences in dispute and results from the expert's study that was not requested by a party.\n\n *(C) Specifying Conditions as an Alternative.* In the circumstances described in Rule 45(d)(3)(B), the court may, instead of quashing or modifying a subpoena, order appearance or production under specified conditions if the serving party:\n\n (i) shows a substantial need for the testimony or material that cannot be otherwise met without undue hardship; and\n\n (ii) ensures that the subpoenaed person will be reasonably compensated.\n\n#### **(e) Duties in Responding to a Subpoena.**\n\n *(1) Producing Documents or Electronically Stored Information.* These procedures apply to producing documents or electronically stored information:\n\n *(A) Documents.* A person responding to a subpoena to produce documents must produce them as they are kept in the ordinary course of business or must organize and label them to correspond to the categories in the demand.\n\n *(B) Form for Producing Electronically Stored Information Not Specified.* If a subpoena does not specify a form for producing electronically stored information, the person responding must produce it in a form or forms in which it is ordinarily maintained or in a reasonably usable form or forms.\n\n *(C) Electronically Stored Information Produced in Only One Form.* The person responding need not produce the same electronically stored information in more than one form.\n\n *(D) Inaccessible Electronically Stored Information.* The person responding need not provide discovery of electronically stored information from sources that the person identifies as not reasonably accessible because of undue burden or cost. On motion to compel discovery or for a protective order, the person responding must show that the information is not reasonably accessible because of undue burden or cost. If that showing is made, the court may nonetheless order discovery from such sources if the requesting party shows good cause, considering the limitations of Rule 26(b)(2)(C). The court may specify conditions for the discovery.\n\n### *(2) Claiming Privilege or Protection.*\n\n *(A) Information Withheld.* A person withholding subpoenaed information under a claim that it is privileged or subject to protection as trial-preparation material must:\n\n(i) expressly make the claim; and\n\n (ii) describe the nature of the withheld documents, communications, or tangible things in a manner that, without revealing information itself privileged or protected, will enable the parties to assess the claim.\n\n *(B) Information Produced.* If information produced in response to a subpoena is subject to a claim of privilege or of protection as trialpreparation material, the person making the claim may notify any party that received the information of the claim and the basis for it. After being notified, a party must promptly return, sequester, or destroy the specified information and any copies it has; must not use or disclose the information until the claim is resolved; must take reasonable steps to retrieve the information if the party disclosed it before being notified; and may promptly present the information under seal to the court for the district where compliance is required for a determination of the claim. The person who produced the information must preserve the information until the claim is resolved.\n\n**(g) Contempt.** The court for the district where compliance is required – and also, after a motion is transferred, the issuing court – may hold in contempt a person who, having been served, fails without adequate excuse to obey the subpoena or an order related to it.\n\nFor access to subpoena materials, see Fed. R. Civ. P. 45(a) Committee Note (2013)\n\n…\n\n## **Exhibit C-12**\n\n### B2540 (Form 2540 – Subpoena for Rule 2004 Examination) (12/15) UNITED STATES BANKRUPTCY COURT Case 22-50073 Doc 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 239 of 491\n\n\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_ District of \\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_ Connecticut\n\nIn re \\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\n\nCase No. \\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_ Ho Wan Kwok 22-50073\n\nDebtor\n\nChapter \\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_ 11\n\n## **SUBPOENA FOR RULE 2004 EXAMINATION**\n\nTo: **\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_** Cahill Gordon & Reindel LLP\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| Paul Hastings LLP
200 Park Avenue
New York, New York 10166 | |\n\nThe examination will be recorded by this method: \\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_ court reporter/stenographer\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: September \\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_ \\_\\_, 2022\n\nCLERK OF COURT\n\nOR\n\n\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_ *Signature of Clerk or Deputy Clerk* \\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_ *Attorney's signature* Patrick R. Linsey (ct29437)\n\nThe name, address, email address, and telephone number of the attorney representing *(name of party)* \\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_ , who issues or requests this subpoena, are: Luc Despins, Ch. 11 Trustee\n\nPatrick R. Linsey, Esq.; Neubert, Pepe & Monteith, P.C.; 195 Church Street, New Haven, Connecticut 06510 plinsey@npmlaw.com; 203-821-2000\n\n## **Notice to the person who issues or requests this subpoena**\n\nIf this subpoena commands the production of documents, electronically stored information, or tangible things, or the inspection of premises before trial, a notice and a copy of this subpoena must be served on each party before it is served on the person to whom it is directed. Fed. R. Civ. P. 45(a)(4).\n\n## **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 following 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 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 242 of 491\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
- | 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| | | |\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
time
zone
in
which
the
emails
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 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 243 of 491\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 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 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 244 of 491\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 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 245 of 491\n\nsuch Persons, as well as a statement addressing how the information came into their possession, (viii) the claim of privilege under which the Document is withheld, and (ix) all of the circumstances upon which You will rely to support such claim of privilege; and (b) produce a privilege log containing all of the information requested in Part (a) of this Instruction for each Document withheld on the basis of a claim of privilege in accordance with D. Conn. L. Civ. R. 26(e). For any part of a Document Request as to which a claim of privilege or work product is not made, responsive documents should be provided in full.\n\n9. If a portion of an otherwise responsive Document contains information subject to a claim of privilege, only that portion of the Document subject to the claim of privilege shall be deleted or redacted from the Document following the instructions above, and the rest shall be produced.\n\n10. The Requests are continuing in nature. You are hereby instructed to (a) supplement or correct any responses later learned to be incomplete or incorrect immediately upon learning that a prior response was incomplete or incorrect; and (b) produce any additional Documents that are called for under the\n\n11. If a Document is in a language other than English, You should provide that Document. If a Document is in a language other than English, and an English translation exists, You should provide both Documents.\n\n12. All references to Entities includes all affiliates thereof.\n\n13. All references to individual names include all alternative names, aliased, or nicknames.\n\n## Case 22-50073 Doc 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 246 of 491\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 othertenses.\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 Cahill Gordon & Reindel LLP, together with any of its employees, agents, counsel, advisors, 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 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 247 of 491\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. \"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: Daniel Podhaskie, Jason Miller, Steve Bannon, Karin Maistrello, Melissa Francis, William Gertz, Arethusa Forsyth, Glenn Mellor, Jennifer Mercurio, Eduardo Eurnekian, Han Chunguang (a/k/a 韩春光), Qu Guojiao (a/k/a Qu Guo Jiao, 屈国姣), Guo Lijie (a/k/a 郭丽杰), Zhang Wei (a/k/a 张伟\\*), Lihong Wei Lafrenz (a/k/a Sara Wei, 魏丽红), Hao Haidong (a/k/a 郝海东), Ross Heinemeyer, Max Krasner, Kyle Bass, Melissa Mendez, Ya Li (a/k/a 李娅), Dinggang Wang (a/k/a 王定刚), An Hong (a/k/a 安红), Yvette Wang (a/k/a Yanping\n\n## Case 22-50073 Doc 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 248 of 491\n\nWang, Yan Ping Wang, 王雁平), Fiona Yu, Je Kin Ming (a/k/a William Je, Yu Jianming, 余建明\n\n), Yaz Qingua, and Lao Jiang (a/k/a Jiang Yunfu, Jiang Yunfu Be, 姜云浮).\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: 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, Assets Sino Limited, Auspicious Coast Limited, Beijing Pangu Investment Co., Beijing Pangu Investment Co. Ltd., Beijing Pangu Investment Inc., Beijing Zenith Holdings Company Limited, Bravo Luck Limited, 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, Elite Well Global Limited, Empire Growth Holdings, G Club Operations LLC, G Fashion LLC, G News LLC, GETTR USA, Genever Holdings Corporation, Genever Holdings LLC, GFASHION MEDIA GROUP INC., GFNY, Inc., Globalist International Limited, GNews Media Group Inc., Golden Spring (New York) Ltd., Greenwich Land LLC, Guo Media, GTV Media Group, Inc., Hamilton Capital Holdings Inc., Head Win Group Limited, Henan Yuda, Himalaya Embassy, Himalaya Exchange, Himalaya Federal Reserve, Himalaya Supervisory Organization, HK International Funds Investments (USA)\n\n## Case 22-50073 Doc 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 249 of 491\n\nLimited LLC, Hong Kong International Funds Investments Limited, Infinite Increase Limited, Infinitum Developments Limited, Insight Phoenix Fund, Lamp Capital LLC, Leading Shine Limited, Leading Shine NY Limited, Long Gate Limited, Next Tycoon Investments Limited, New Federal State of China (a/k/a NFSC), Noble Fame Global Limited, Rosy Acme Ventures Limited, Rule of Law Foundation III, Inc., Rule of Law Foundation IV, Inc., Rule of Law Fund, Rule of Law Society, Rule of Law Society IV, Inc., G-Translators PTY LTD, Saraca Media Group, Inc., Shiny Ace Ltd., Shiny Times Holdings Ltd., Spirit Charter Investment Limited, Stevenson, Wong & Co., Voice of Guo Media, Inc., Well Origin Ltd., World Century Limited, Worldwide Opportunity Holdings Limited, Whitecroft Shore 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\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, correspondence, memoranda, tapes, stenographic or handwritten notes, written forms of any kind,\n\n## Case 22-50073 Doc 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 250 of 491\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\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,\n\n## Case 22-50073 Doc 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 251 of 491\n\nconnected 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, 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\n21. \"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 income or Asset of the Debtor, the Debtor's estate, the Debtor's Family, or Associated Entity.\n\n## Case 22-50073 Doc 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 252 of 491\n\n2. All Documents related to any engagement letter with the Debtor, any member of the Debtor's Family, and/or any Associated Entity, including copy(ies) of such engagement letter(s).\n\n3. All Documents related to the payment of any retainer to You based upon your representation of the Debtor, the Debtor's Family, or an Associated Entity, including documents sufficient to identify the amount of the retainer and its source.\n\n4. All Documents related to any fees, payments, or monies received by You from or on behalf of the Debtor, the Debtor's Family, a Family Related Entity, or an Associated Entity held in escrow or in a client trust account.\n\n5. Documents sufficient to show the amount, date, and source of any payments made to You by or for the benefit of the Debtor, the Debtor's Family, or an Associated Entity.\n\n6. 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\n7. All Documents related to the Associated Entities, including but not limited to Documents related to their corporate structure, Assets, incorporation information, officers and directors, business purpose, and relationship to the Debtor, to any member of the Debtor's Family, or to any Associated Individual.\n\n8. All Documents regarding any investment or business dealing made by, with, or on behalf of Debtor or the Debtor's Family, on the one hand, and an Associated Entity, on the other hand.\n\n## Case 22-50073 Doc 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 253 of 491\n\n9. All Documents related to any Entity that the Debtor, the Debtor's Estate, the Debtor's Family, or the Associated Entities hold any interest or investment in, including but not limited to the nature and value of that interest or investment; any proceeds or benefits from such Entity that the Debtor, the Debtor's Estate, the Debtor's Family, or the Associated Entities receive on account of such interest or investment; and all Documents relating to any financial reporting or data relating to such Entity, including but not limited to all books and records, financial statements or tax Documents.\n\n10. All Documents regarding the *Lady May*; the Sherry Netherland Hotel / Condominium; 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.; and any financial interest that the Debtor or the Debtor's estate possesses in any Associated Entity.\n\n11. All Documents related to the purported Declaration of Trust and Agreement, dated February 17, 2015, entered into by the Debtor, as Trustee, Genever Holdings Corporation, and Genever Holdings LLC, in favor of Bravo Luck Limited, as beneficiary.\n\n12. All Documents related to any aircraft owned, controlled, or used by the Debtor, including without limitation the aircraft bearing tail number T7-GQM 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.\n\n13. All Documents related to any investments or trading by the Debtor, the Debtor's Family, or an Associated Entity, in or around July 2020, or at any other time, in crude oil futures or any similar commodity, including without limitation Communications with Jiang Yunfu Be regarding any such investments or trading.\n\n## Case 22-50073 Doc 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 254 of 491\n\n14. All Communications between You and, either, the Debtor, the Debtor's Family, or any Associated Individual, agent, employee, or other individual acting on behalf of the Debtor, related to any Transfer, investment, or other transaction or business dealing relating to the Debtor, the Debtor's Estate, the Debtor's Family, or the Associated Entities.\n\n15. All Documents concerning any trust or similar instrument set up by, on behalf of, or for the benefit of Debtor, Debtor's Estate, Debtor's Family, or Associated Entities, including but not limited to Documents showing when the trust(s) was created, by whom it was created, to whose benefit it was created, and the corpus of the instrument.\n\n16. All Documents related to any sale, acquisition, disposition, purchase, investment, contribution, gift, extension of credit, loan, or Transfer involving the Debtor, the Debtor's Family, or any Associated Entity.\n\n17. 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\n18. All Documents related to any loans or extensions of credit, or applications for the same, to or from the Debtor, the Debtor's Estate, the Debtor's Family or any Associated Entity, including but not limited to (i) the terms of any such loans or extensions of credit, including their terms of repayment, representations and warranties, and interest rate, and (ii) all evidence of payments of the loans.\n\n## Case 22-50073 Doc 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 255 of 491\n\n19. All Documents related to the Debtor's use of any Assets belonging to, controlled by, or whose complete or partial ownership is held by the Debtor's Family, an Associated Entity, or an Associated Individual.\n\n20. 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\n21. All Documents related to any pledges of Assets of any Associated Entity, including Bravo Luck Limited, to any other Entity.\n\n| Case 22-50073 | Doc 839 | Filed 09/07/22 | | Entered 09/07/22 20:02:47 | Page 256 of |\n|-----------------------------------------------------------------|---------|----------------|-----|---------------------------|-------------|\n| B2540 (Form 2540 – Subpoena for Rule 2004 Examination) (Page 2) | | | 491 | | |\n| | | | | | |\n\n| I received this subpoena for (name of individual and title, if any): ______________________________________________
on (date)
__________
I served the subpoena by delivering a copy to the named person
___________________________________________________________________________________________________
__________________________________
on (date) ___________________ ; or | as follows: ____________________________________ |\n|-----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|----------------------------------------------------------------------------|\n| | |\n| | |\n| | |\n| I returned the subpoena unexecuted because: ____________________________________________________________
___________________________________________________________________________________________________ | |\n| Unless the subpoena was issued on behalf of the United States, or one of its officers or agents, I have also tendered to the
witness the fees for one day's attendance, and the mileage allowed by law, in the amount of \\$ _______________________ . | |\n| My fees are \\$ _________
for travel and \\$_________ | for services, for a total of \\$_________ |\n| I declare under penalty of perjury
that this information is true and correct. | |\n| Date: _______________ | |\n| | ________________________________________________
Server's signature |\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; (ii) requires a person to comply beyond the geographical limits\n\nspecified in Rule 45(c);\n\n (iii) requires disclosure of privileged or other protected matter, if no exception or waiver applies; or\n\n(iv) subjects a person to undue burden.\n\n *(B) When Permitted.* To protect a person subject to or affected by a subpoena, the court for the district where compliance is required may, on motion, quash or modify the subpoena if it requires:\n\n (i) disclosing a trade secret or other confidential research, development, or commercial information; or\n\n (ii) disclosing an unretained expert's opinion or information that does not describe specific occurrences in dispute and results from the expert's study that was not requested by a party.\n\n *(C) Specifying Conditions as an Alternative.* In the circumstances described in Rule 45(d)(3)(B), the court may, instead of quashing or modifying a subpoena, order appearance or production under specified conditions if the serving party:\n\n (i) shows a substantial need for the testimony or material that cannot be otherwise met without undue hardship; and\n\n (ii) ensures that the subpoenaed person will be reasonably compensated.\n\n#### **(e) Duties in Responding to a Subpoena.**\n\n *(1) Producing Documents or Electronically Stored Information.* These procedures apply to producing documents or electronically stored information:\n\n *(A) Documents.* A person responding to a subpoena to produce documents must produce them as they are kept in the ordinary course of business or must organize and label them to correspond to the categories in the demand.\n\n *(B) Form for Producing Electronically Stored Information Not Specified.* If a subpoena does not specify a form for producing electronically stored information, the person responding must produce it in a form or forms in which it is ordinarily maintained or in a reasonably usable form or forms.\n\n *(C) Electronically Stored Information Produced in Only One Form.* The person responding need not produce the same electronically stored information in more than one form.\n\n *(D) Inaccessible Electronically Stored Information.* The person responding need not provide discovery of electronically stored information from sources that the person identifies as not reasonably accessible because of undue burden or cost. On motion to compel discovery or for a protective order, the person responding must show that the information is not reasonably accessible because of undue burden or cost. If that showing is made, the court may nonetheless order discovery from such sources if the requesting party shows good cause, considering the limitations of Rule 26(b)(2)(C). The court may specify conditions for the discovery.\n\n### *(2) Claiming Privilege or Protection.*\n\n *(A) Information Withheld.* A person withholding subpoenaed information under a claim that it is privileged or subject to protection as trial-preparation material must:\n\n(i) expressly make the claim; and\n\n (ii) describe the nature of the withheld documents, communications, or tangible things in a manner that, without revealing information itself privileged or protected, will enable the parties to assess the claim.\n\n *(B) Information Produced.* If information produced in response to a subpoena is subject to a claim of privilege or of protection as trialpreparation material, the person making the claim may notify any party that received the information of the claim and the basis for it. After being notified, a party must promptly return, sequester, or destroy the specified information and any copies it has; must not use or disclose the information until the claim is resolved; must take reasonable steps to retrieve the information if the party disclosed it before being notified; and may promptly present the information under seal to the court for the district where compliance is required for a determination of the claim. The person who produced the information must preserve the information until the claim is resolved.\n\n**(g) Contempt.** The court for the district where compliance is required – and also, after a motion is transferred, the issuing court – may hold in contempt a person who, having been served, fails without adequate excuse to obey the subpoena or an order related to it.\n\nFor access to subpoena materials, see Fed. R. Civ. P. 45(a) Committee Note (2013)\n\n…\n\n## **Exhibit C-13**\n\n### B2540 (Form 2540 – Subpoena for Rule 2004 Examination) (12/15) UNITED STATES BANKRUPTCY COURT Case 22-50073 Doc 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 259 of 491\n\n\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_ District of \\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_ Connecticut\n\nIn re \\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\n\nCase No. \\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_ Ho Wan Kwok 22-50073\n\nDebtor\n\nChapter \\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_ 11\n\n## **SUBPOENA FOR RULE 2004 EXAMINATION**\n\n#### To: **\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_ Elliott Kwok Levine & Jaroslaw LLP**\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| Paul Hastings LLP
200 Park Avenue
New York, New York 10166 | |\n\nThe examination will be recorded by this method: \\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_ court reporter/stenographer\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: Sept\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_ ember \\_\\_, 2022\n\nCLERK OF COURT\n\nOR\n\n\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_ *Signature of Clerk or Deputy Clerk* \\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_ *Attorney's signature* Patrick R. Linsey (ct29437)\n\nThe name, address, email address, and telephone number of the attorney representing *(name of party)* \\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_ , who issues or requests this subpoena, are: Luc Despins, Ch. 11 Trustee\n\nPatrick R. Linsey, Esq.; Neubert, Pepe & Monteith, P.C.; 195 Church Street, New Haven, Connecticut 06510 plinsey@npmlaw.com; 203-821-2000\n\n## **Notice to the person who issues or requests this subpoena**\n\nIf this subpoena commands the production of documents, electronically stored information, or tangible things, or the inspection of premises before trial, a notice and a copy of this subpoena must be served on each party before it is served on the person to whom it is directed. Fed. R. Civ. P. 45(a)(4).\n\n## **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 following 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 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 262 of 491\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
- | 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| | | | |\n| FROM | John Smith | Email: Sender
Native: Author(s) of document | |\n| | | | |\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
time
zone
in
which
the
emails
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 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 263 of 491\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 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 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 264 of 491\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 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 265 of 491\n\nsuch Persons, as well as a statement addressing how the information came into their possession, (viii) the claim of privilege under which the Document is withheld, and (ix) all of the circumstances upon which You will rely to support such claim of privilege; and (b) produce a privilege log containing all of the information requested in Part (a) of this Instruction for each Document withheld on the basis of a claim of privilege in accordance with D. Conn. L. Civ. R. 26(e). For any part of a Document Request as to which a claim of privilege or work product is not made, responsive documents should be provided in full.\n\n9. If a portion of an otherwise responsive Document contains information subject to a claim of privilege, only that portion of the Document subject to the claim of privilege shall be deleted or redacted from the Document following the instructions above, and the rest shall be produced.\n\n10. The Requests are continuing in nature. You are hereby instructed to (a) supplement or correct any responses later learned to be incomplete or incorrect immediately upon learning that a prior response was incomplete or incorrect; and (b) produce any additional Documents that are called for under the\n\n11. If a Document is in a language other than English, You should provide that Document. If a Document is in a language other than English, and an English translation exists, You should provide both Documents.\n\n12. All references to Entities includes all affiliates thereof.\n\n13. All references to individual names include all alternative names, aliased, or nicknames.\n\n## Case 22-50073 Doc 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 266 of 491\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 Elliott Kwok Levine & Jaroslaw LLP, together with any of its employees, agents, counsel, advisors, 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 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 267 of 491\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. \"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: Daniel Podhaskie, Jason Miller, Steve Bannon, Karin Maistrello, Melissa Francis, William Gertz, Arethusa Forsyth, Glenn Mellor, Jennifer Mercurio, Eduardo Eurnekian, Han Chunguang (a/k/a 韩春光), Qu Guojiao (a/k/a Qu Guo Jiao, 屈国姣), Guo Lijie (a/k/a 郭丽杰), Zhang Wei (a/k/a 张伟\\*), Lihong Wei Lafrenz (a/k/a Sara Wei, 魏丽红), Hao Haidong (a/k/a 郝海东), Ross Heinemeyer, Max Krasner, Kyle Bass, Melissa Mendez, Ya Li (a/k/a 李娅), Dinggang Wang (a/k/a 王定刚), An Hong (a/k/a 安红), Yvette Wang (a/k/a Yanping\n\n## Case 22-50073 Doc 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 268 of 491\n\nWang, Yan Ping Wang, 王雁平), Fiona Yu, Je Kin Ming (a/k/a William Je, Yu Jianming, 余建明\n\n), Yaz Qingua, and Lao Jiang (a/k/a Jiang Yunfu, Jiang Yunfu Be, 姜云浮).\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: 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, Assets Sino Limited, Auspicious Coast Limited, Beijing Pangu Investment Co., Beijing Pangu Investment Co. Ltd., Beijing Pangu Investment Inc., Beijing Zenith Holdings Company Limited, Bravo Luck Limited, 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, Elite Well Global Limited, Empire Growth Holdings, G Club Operations LLC, G Fashion LLC, G News LLC, GETTR USA, Genever Holdings Corporation, Genever Holdings LLC, GFASHION MEDIA GROUP INC., GFNY, Inc., Globalist International Limited, GNews Media Group Inc., Golden Spring (New York) Ltd., Greenwich Land LLC, Guo Media, GTV Media Group, Inc., Hamilton Capital Holdings Inc., Head Win Group Limited, Henan Yuda, Himalaya Embassy, Himalaya Exchange, Himalaya Federal Reserve, Himalaya Supervisory Organization, HK International Funds Investments (USA)\n\n## Case 22-50073 Doc 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 269 of 491\n\nLimited LLC, Hong Kong International Funds Investments Limited, Infinite Increase Limited, Infinitum Developments Limited, Insight Phoenix Fund, Lamp Capital LLC, Leading Shine Limited, Leading Shine NY Limited, Long Gate Limited, Next Tycoon Investments Limited, New Federal State of China (a/k/a NFSC), Noble Fame Global Limited, Rosy Acme Ventures Limited, Rule of Law Foundation III, Inc., Rule of Law Foundation IV, Inc., Rule of Law Fund, Rule of Law Society, Rule of Law Society IV, Inc., G-Translators PTY LTD, Saraca Media Group, Inc., Shiny Ace Ltd., Shiny Times Holdings Ltd., Spirit Charter Investment Limited, Stevenson, Wong & Co., Voice of Guo Media, Inc., Well Origin Ltd., World Century Limited, Worldwide Opportunity Holdings Limited, Whitecroft Shore 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\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, correspondence, memoranda, tapes, stenographic or handwritten notes, written forms of any kind,\n\n## Case 22-50073 Doc 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 270 of 491\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\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,\n\n## Case 22-50073 Doc 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 271 of 491\n\nconnected 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, 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\n21. \"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 income or Asset of the Debtor, the Debtor's estate, the Debtor's Family, or Associated Entity.\n\n## Case 22-50073 Doc 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 272 of 491\n\n2. All Documents related to any engagement letter with the Debtor, any member of the Debtor's Family, and/or any Associated Entity, including copy(ies) of such engagement letter(s).\n\n3. All Documents related to the payment of any retainer to You based upon your representation of the Debtor, the Debtor's Family, or an Associated Entity, including documents sufficient to identify the amount of the retainer and its source.\n\n4. All Documents related to any fees, payments, or monies received by You from or on behalf of the Debtor, the Debtor's Family, a Family Related Entity, or an Associated Entity held in escrow or in a client trust account.\n\n5. Documents sufficient to show the amount, date, and source of any payments made to You by or for the benefit of the Debtor, the Debtor's Family, or an Associated Entity.\n\n6. 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\n7. All Documents related to the Associated Entities, including but not limited to Documents related to their corporate structure, Assets, incorporation information, officers and directors, business purpose, and relationship to the Debtor, to any member of the Debtor's Family, or to any Associated Individual.\n\n8. All Documents regarding any investment or business dealing made by, with, or on behalf of Debtor or the Debtor's Family, on the one hand, and an Associated Entity, on the other hand.\n\n## Case 22-50073 Doc 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 273 of 491\n\n9. All Documents related to any Entity that the Debtor, the Debtor's Estate, the Debtor's Family, or the Associated Entities hold any interest or investment in, including but not limited to the nature and value of that interest or investment; any proceeds or benefits from such Entity that the Debtor, the Debtor's Estate, the Debtor's Family, or the Associated Entities receive on account of such interest or investment; and all Documents relating to any financial reporting or data relating to such Entity, including but not limited to all books and records, financial statements or tax Documents.\n\n10. All Documents regarding the *Lady May*; the Sherry Netherland Hotel / Condominium; 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.; and any financial interest that the Debtor or the Debtor's estate possesses in any Associated Entity.\n\n11. All Documents related to the purported Declaration of Trust and Agreement, dated February 17, 2015, entered into by the Debtor, as Trustee, Genever Holdings Corporation, and Genever Holdings LLC, in favor of Bravo Luck Limited, as beneficiary.\n\n12. All Documents related to any aircraft owned, controlled, or used by the Debtor, including without limitation the aircraft bearing tail number T7-GQM 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.\n\n13. All Documents related to any investments or trading by the Debtor, the Debtor's Family, or an Associated Entity, in or around July 2020, or at any other time, in crude oil futures or any similar commodity, including without limitation Communications with Jiang Yunfu Be regarding any such investments or trading.\n\n## Case 22-50073 Doc 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 274 of 491\n\n14. All Communications between You and, either, the Debtor, the Debtor's Family, or any Associated Individual, agent, employee, or other individual acting on behalf of the Debtor, related to any Transfer, investment, or other transaction or business dealing relating to the Debtor, the Debtor's Estate, the Debtor's Family, or the Associated Entities.\n\n15. All Documents concerning any trust or similar instrument set up by, on behalf of, or for the benefit of Debtor, Debtor's Estate, Debtor's Family, or Associated Entities, including but not limited to Documents showing when the trust(s) was created, by whom it was created, to whose benefit it was created, and the corpus of the instrument.\n\n16. All Documents related to any sale, acquisition, disposition, purchase, investment, contribution, gift, extension of credit, loan, or Transfer involving the Debtor, the Debtor's Family, or any Associated Entity.\n\n17. 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\n18. All Documents related to any loans or extensions of credit, or applications for the same, to or from the Debtor, the Debtor's Estate, the Debtor's Family or any Associated Entity, including but not limited to (i) the terms of any such loans or extensions of credit, including their terms of repayment, representations and warranties, and interest rate, and (ii) all evidence of payments of the loans.\n\n## Case 22-50073 Doc 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 275 of 491\n\n19. All Documents related to the Debtor's use of any Assets belonging to, controlled by, or whose complete or partial ownership is held by the Debtor's Family, an Associated Entity, or an Associated Individual.\n\n20. 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\n21. All Documents related to any pledges of Assets of any Associated Entity, including Bravo Luck Limited, to any other Entity.\n\n| Case 22-50073 | Doc 839 | Filed 09/07/22 | | Entered 09/07/22 20:02:47 | Page 276 of |\n|-----------------------------------------------------------------|---------|----------------|-----|---------------------------|-------------|\n| B2540 (Form 2540 – Subpoena for Rule 2004 Examination) (Page 2) | | | 491 | | |\n| | | | | | |\n\n| I received this subpoena for (name of individual and title, if any): ______________________________________________
on (date) __________ .
I served the subpoena by delivering a copy to the named person as follows: ____________________________________
___________________________________________________________________________________________________
__________________________________ on (date) ___________________ ; or | |\n|--------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|----------------------------------------------------------------------------|\n| | |\n| | |\n| | |\n| I returned the subpoena unexecuted because: ____________________________________________________________
___________________________________________________________________________________________________ | |\n| Unless the subpoena was issued on behalf of the United States, or one of its officers or agents, I have also tendered to the
witness the fees for one day's attendance, and the mileage allowed by law, in the amount of \\$ _______________________ . | |\n| My fees are \\$ _________ for travel and \\$_________ for services, for a total of \\$_________ . | |\n| I declare under penalty of perjury
that this information is true and correct. | |\n| Date: _______________ | |\n| | ________________________________________________
Server's signature |\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; (ii) requires a person to comply beyond the geographical limits\n\nspecified in Rule 45(c);\n\n(iii) requires disclosure of privileged or other protected matter, if no exception or waiver applies; or\n\n(iv) subjects a person to undue burden.\n\n*(B) When Permitted.* To protect a person subject to or affected by a subpoena, the court for the district where compliance is required may, on motion, quash or modify the subpoena if it requires:\n\n(i) disclosing a trade secret or other confidential research, development, or commercial information; or\n\n(ii) disclosing an unretained expert's opinion or information that does not describe specific occurrences in dispute and results from the expert's study that was not requested by a party.\n\n*(C) Specifying Conditions as an Alternative.* In the circumstances described in Rule 45(d)(3)(B), the court may, instead of quashing or modifying a subpoena, order appearance or production under specified conditions if the serving party:\n\n(i) shows a substantial need for the testimony or material that cannot be otherwise met without undue hardship; and\n\n(ii) ensures that the subpoenaed person will be reasonably compensated.\n\n### **(e) Duties in Responding to a Subpoena.**\n\n*(1) Producing Documents or Electronically Stored Information.* These procedures apply to producing documents or electronically stored information:\n\n*(A) Documents.* A person responding to a subpoena to produce documents must produce them as they are kept in the ordinary course of business or must organize and label them to correspond to the categories in the demand.\n\n*(B) Form for Producing Electronically Stored Information Not Specified.* If a subpoena does not specify a form for producing electronically stored information, the person responding must produce it in a form or forms in which it is ordinarily maintained or in a reasonably usable form or forms.\n\n*(C) Electronically Stored Information Produced in Only One Form.* The person responding need not produce the same electronically stored information in more than one form.\n\n*(D) Inaccessible Electronically Stored Information.* The person responding need not provide discovery of electronically stored information from sources that the person identifies as not reasonably accessible because of undue burden or cost. On motion to compel discovery or for a protective order, the person responding must show that the information is not reasonably accessible because of undue burden or cost. If that showing is made, the court may nonetheless order discovery from such sources if the requesting party shows good cause, considering the limitations of Rule 26(b)(2)(C). The court may specify conditions for the discovery.\n\n### *(2) Claiming Privilege or Protection.*\n\n*(A) Information Withheld.* A person withholding subpoenaed information under a claim that it is privileged or subject to protection as trial-preparation material must:\n\n(i) expressly make the claim; and\n\n(ii) describe the nature of the withheld documents, communications, or tangible things in a manner that, without revealing information itself privileged or protected, will enable the parties to assess the claim.\n\n*(B) Information Produced.* If information produced in response to a subpoena is subject to a claim of privilege or of protection as trialpreparation material, the person making the claim may notify any party that received the information of the claim and the basis for it. After being notified, a party must promptly return, sequester, or destroy the specified information and any copies it has; must not use or disclose the information until the claim is resolved; must take reasonable steps to retrieve the information if the party disclosed it before being notified; and may promptly present the information under seal to the court for the district where compliance is required for a determination of the claim. The person who produced the information must preserve the information until the claim is resolved.\n\n**(g) Contempt.** The court for the district where compliance is required – and also, after a motion is transferred, the issuing court – may hold in contempt a person who, having been served, fails without adequate excuse to obey the subpoena or an order related to it.\n\nFor access to subpoena materials, see Fed. R. Civ. P. 45(a) Committee Note (2013)\n\n…\n\n## **Exhibit C-14**\n\n### B2540 (Form 2540 – Subpoena for Rule 2004 Examination) (12/15) UNITED STATES BANKRUPTCY COURT Case 22-50073 Doc 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 279 of 491\n\n\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_ District of \\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_ Connecticut\n\nIn re \\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\n\nCase No. \\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_ Ho Wan Kwok 22-50073\n\nDebtor\n\nChapter \\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_ 11\n\n## **SUBPOENA FOR RULE 2004 EXAMINATION**\n\nTo: **\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_ Williams & Connolly LLP**\n\nPLACE Paul Has\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| DATE AND TIME |\n|---------------|\n| |\n| |\n| |\n| |\n\nThe examination will be recorded by this method: \\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_ court reporter/stenographer\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: Sept\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_ ember \\_\\_, 2022\n\nCLERK OF COURT\n\nOR\n\n\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_ *Signature of Clerk or Deputy Clerk* \\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_ *Attorney's signature* Patrick R. Linsey (ct29437)\n\nThe name, address, email address, and telephone number of the attorney representing *(name of party)* \\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_ , who issues or requests this subpoena, are: Luc Despins, Ch. 11 Trustee\n\nPatrick R. Linsey, Esq.; Neubert, Pepe & Monteith, P.C.; 195 Church Street, New Haven, Connecticut 06510 plinsey@npmlaw.com; 203-821-2000\n\n## **Notice to the person who issues or requests this subpoena**\n\nIf this subpoena commands the production of documents, electronically stored information, or tangible things, or the inspection of premises before trial, a notice and a copy of this subpoena must be served on each party before it is served on the person to whom it is directed. Fed. R. Civ. P. 45(a)(4).\n\n## **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 following 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 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 282 of 491\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
- | 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| | | |\n| FROM | John Smith | Email: Sender
Native: Author(s) of document |\n| | | |\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
time
zone
in
which
the
emails
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 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 283 of 491\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 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 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 284 of 491\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 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 285 of 491\n\nsuch Persons, as well as a statement addressing how the information came into their possession, (viii) the claim of privilege under which the Document is withheld, and (ix) all of the circumstances upon which You will rely to support such claim of privilege; and (b) produce a privilege log containing all of the information requested in Part (a) of this Instruction for each Document withheld on the basis of a claim of privilege in accordance with D. Conn. L. Civ. R. 26(e). For any part of a Document Request as to which a claim of privilege or work product is not made, responsive documents should be provided in full.\n\n9. If a portion of an otherwise responsive Document contains information subject to a claim of privilege, only that portion of the Document subject to the claim of privilege shall be deleted or redacted from the Document following the instructions above, and the rest shall be produced.\n\n10. The Requests are continuing in nature. You are hereby instructed to (a) supplement or correct any responses later learned to be incomplete or incorrect immediately upon learning that a prior response was incomplete or incorrect; and (b) produce any additional Documents that are called for under the\n\n11. If a Document is in a language other than English, You should provide that Document. If a Document is in a language other than English, and an English translation exists, You should provide both Documents.\n\n12. All references to Entities includes all affiliates thereof.\n\n13. All references to individual names include all alternative names, aliased, or nicknames.\n\n## Case 22-50073 Doc 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 286 of 491\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 Williams & Connolly LLP, together with any of its employees, agents, counsel, advisors, 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 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 287 of 491\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. \"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: Daniel Podhaskie, Jason Miller, Steve Bannon, Karin Maistrello, Melissa Francis, William Gertz, Arethusa Forsyth, Glenn Mellor, Jennifer Mercurio, Eduardo Eurnekian, Han Chunguang (a/k/a 韩春光), Qu Guojiao (a/k/a Qu Guo Jiao, 屈国姣), Guo Lijie (a/k/a 郭丽杰), Zhang Wei (a/k/a 张伟\\*), Lihong Wei Lafrenz (a/k/a Sara Wei, 魏丽红), Hao Haidong (a/k/a 郝海东), Ross Heinemeyer, Max Krasner, Kyle Bass, Melissa Mendez, Ya Li (a/k/a 李娅), Dinggang Wang (a/k/a 王定刚), An Hong (a/k/a 安红), Yvette Wang (a/k/a Yanping\n\n## Case 22-50073 Doc 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 288 of 491\n\nWang, Yan Ping Wang, 王雁平), Fiona Yu, Je Kin Ming (a/k/a William Je, Yu Jianming, 余建明\n\n), Yaz Qingua, and Lao Jiang (a/k/a Jiang Yunfu, Jiang Yunfu Be, 姜云浮).\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: 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, Assets Sino Limited, Auspicious Coast Limited, Beijing Pangu Investment Co., Beijing Pangu Investment Co. Ltd., Beijing Pangu Investment Inc., Beijing Zenith Holdings Company Limited, Bravo Luck Limited, 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, Elite Well Global Limited, Empire Growth Holdings, G Club Operations LLC, G Fashion LLC, G News LLC, GETTR USA, Genever Holdings Corporation, Genever Holdings LLC, GFASHION MEDIA GROUP INC., GFNY, Inc., Globalist International Limited, GNews Media Group Inc., Golden Spring (New York) Ltd., Greenwich Land LLC, Guo Media, GTV Media Group, Inc., Hamilton Capital Holdings Inc., Head Win Group Limited, Henan Yuda, Himalaya Embassy, Himalaya Exchange, Himalaya Federal Reserve, Himalaya Supervisory Organization, HK International Funds Investments (USA)\n\n## Case 22-50073 Doc 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 289 of 491\n\nLimited LLC, Hong Kong International Funds Investments Limited, Infinite Increase Limited, Infinitum Developments Limited, Insight Phoenix Fund, Lamp Capital LLC, Leading Shine Limited, Leading Shine NY Limited, Long Gate Limited, Next Tycoon Investments Limited, New Federal State of China (a/k/a NFSC), Noble Fame Global Limited, Rosy Acme Ventures Limited, Rule of Law Foundation III, Inc., Rule of Law Foundation IV, Inc., Rule of Law Fund, Rule of Law Society, Rule of Law Society IV, Inc., G-Translators PTY LTD, Saraca Media Group, Inc., Shiny Ace Ltd., Shiny Times Holdings Ltd., Spirit Charter Investment Limited, Stevenson, Wong & Co., Voice of Guo Media, Inc., Well Origin Ltd., World Century Limited, Worldwide Opportunity Holdings Limited, Whitecroft Shore 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\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, correspondence, memoranda, tapes, stenographic or handwritten notes, written forms of any kind,\n\n## Case 22-50073 Doc 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 290 of 491\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\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,\n\n## Case 22-50073 Doc 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 291 of 491\n\nconnected 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, 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\n21. \"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 income or Asset of the Debtor, the Debtor's estate, the Debtor's Family, or Associated Entity.\n\n## Case 22-50073 Doc 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 292 of 491\n\n2. All Documents related to any engagement letter with the Debtor, any member of the Debtor's Family, and/or any Associated Entity, including copy(ies) of such engagement letter(s).\n\n3. All Documents related to the payment of any retainer to You based upon your representation of the Debtor, the Debtor's Family, or an Associated Entity, including documents sufficient to identify the amount of the retainer and its source.\n\n4. All Documents related to any fees, payments, or monies received by You from or on behalf of the Debtor, the Debtor's Family, a Family Related Entity, or an Associated Entity held in escrow or in a client trust account.\n\n5. Documents sufficient to show the amount, date, and source of any payments made to You by or for the benefit of the Debtor, the Debtor's Family, or an Associated Entity.\n\n6. 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\n7. All Documents related to the Associated Entities, including but not limited to Documents related to their corporate structure, Assets, incorporation information, officers and directors, business purpose, and relationship to the Debtor, to any member of the Debtor's Family, or to any Associated Individual.\n\n8. All Documents regarding any investment or business dealing made by, with, or on behalf of Debtor or the Debtor's Family, on the one hand, and an Associated Entity, on the other hand.\n\n## Case 22-50073 Doc 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 293 of 491\n\n9. All Documents related to any Entity that the Debtor, the Debtor's Estate, the Debtor's Family, or the Associated Entities hold any interest or investment in, including but not limited to the nature and value of that interest or investment; any proceeds or benefits from such Entity that the Debtor, the Debtor's Estate, the Debtor's Family, or the Associated Entities receive on account of such interest or investment; and all Documents relating to any financial reporting or data relating to such Entity, including but not limited to all books and records, financial statements or tax Documents.\n\n10. All Documents regarding the *Lady May*; the Sherry Netherland Hotel / Condominium; 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.; and any financial interest that the Debtor or the Debtor's estate possesses in any Associated Entity.\n\n11. All Documents related to the purported Declaration of Trust and Agreement, dated February 17, 2015, entered into by the Debtor, as Trustee, Genever Holdings Corporation, and Genever Holdings LLC, in favor of Bravo Luck Limited, as beneficiary.\n\n12. All Documents related to any aircraft owned, controlled, or used by the Debtor, including without limitation the aircraft bearing tail number T7-GQM 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.\n\n13. All Documents related to any investments or trading by the Debtor, the Debtor's Family, or an Associated Entity, in or around July 2020, or at any other time, in crude oil futures or any similar commodity, including without limitation Communications with Jiang Yunfu Be regarding any such investments or trading.\n\n## Case 22-50073 Doc 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 294 of 491\n\n14. All Communications between You and, either, the Debtor, the Debtor's Family, or any Associated Individual, agent, employee, or other individual acting on behalf of the Debtor, related to any Transfer, investment, or other transaction or business dealing relating to the Debtor, the Debtor's Estate, the Debtor's Family, or the Associated Entities.\n\n15. All Documents concerning any trust or similar instrument set up by, on behalf of, or for the benefit of Debtor, Debtor's Estate, Debtor's Family, or Associated Entities, including but not limited to Documents showing when the trust(s) was created, by whom it was created, to whose benefit it was created, and the corpus of the instrument.\n\n16. All Documents related to any sale, acquisition, disposition, purchase, investment, contribution, gift, extension of credit, loan, or Transfer involving the Debtor, the Debtor's Family, or any Associated Entity.\n\n17. 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\n18. All Documents related to any loans or extensions of credit, or applications for the same, to or from the Debtor, the Debtor's Estate, the Debtor's Family or any Associated Entity, including but not limited to (i) the terms of any such loans or extensions of credit, including their terms of repayment, representations and warranties, and interest rate, and (ii) all evidence of payments of the loans.\n\n## Case 22-50073 Doc 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 295 of 491\n\n19. All Documents related to the Debtor's use of any Assets belonging to, controlled by, or whose complete or partial ownership is held by the Debtor's Family, an Associated Entity, or an Associated Individual.\n\n20. 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\n21. All Documents related to any pledges of Assets of any Associated Entity, including Bravo Luck Limited, to any other Entity.\n\n| Case 22-50073 | Doc 839 | Filed 09/07/22 | | Entered 09/07/22 20:02:47 | Page 296 of |\n|-----------------------------------------------------------------|---------|----------------|-----|---------------------------|-------------|\n| B2540 (Form 2540 – Subpoena for Rule 2004 Examination) (Page 2) | | | 491 | | |\n| | | | | | |\n\n| I received this subpoena for (name of individual and title, if any): ______________________________________________
on (date) __________ .
I served the subpoena by delivering a copy to the named person as follows: ____________________________________
___________________________________________________________________________________________________
__________________________________ on (date) ___________________ ; or | |\n|--------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|----------------------------------------------------------------------------|\n| | |\n| | |\n| | |\n| I returned the subpoena unexecuted because: ____________________________________________________________
___________________________________________________________________________________________________ | |\n| Unless the subpoena was issued on behalf of the United States, or one of its officers or agents, I have also tendered to the
witness the fees for one day's attendance, and the mileage allowed by law, in the amount of \\$ _______________________ . | |\n| My fees are \\$ _________ for travel and \\$_________ for services, for a total of \\$_________ . | |\n| I declare under penalty of perjury
that this information is true and correct. | |\n| Date: _______________ | |\n| | ________________________________________________
Server's signature |\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; (ii) requires a person to comply beyond the geographical limits\n\nspecified in Rule 45(c); (iii) requires disclosure of privileged or other protected matter, if no\n\nexception or waiver applies; or\n\n(iv) subjects a person to undue burden.\n\n*(B) When Permitted.* To protect a person subject to or affected by a subpoena, the court for the district where compliance is required may, on motion, quash or modify the subpoena if it requires:\n\n(i) disclosing a trade secret or other confidential research, development, or commercial information; or\n\n(ii) disclosing an unretained expert's opinion or information that does not describe specific occurrences in dispute and results from the expert's study that was not requested by a party.\n\n*(C) Specifying Conditions as an Alternative.* In the circumstances described in Rule 45(d)(3)(B), the court may, instead of quashing or modifying a subpoena, order appearance or production under specified conditions if the serving party:\n\n(i) shows a substantial need for the testimony or material that cannot be otherwise met without undue hardship; and\n\n(ii) ensures that the subpoenaed person will be reasonably compensated.\n\n#### **(e) Duties in Responding to a Subpoena.**\n\n*(1) Producing Documents or Electronically Stored Information.* These procedures apply to producing documents or electronically stored information:\n\n*(A) Documents.* A person responding to a subpoena to produce documents must produce them as they are kept in the ordinary course of business or must organize and label them to correspond to the categories in the demand.\n\n*(B) Form for Producing Electronically Stored Information Not Specified.* If a subpoena does not specify a form for producing electronically stored information, the person responding must produce it in a form or forms in which it is ordinarily maintained or in a reasonably usable form or forms.\n\n*(C) Electronically Stored Information Produced in Only One Form.* The person responding need not produce the same electronically stored information in more than one form.\n\n*(D) Inaccessible Electronically Stored Information.* The person responding need not provide discovery of electronically stored information from sources that the person identifies as not reasonably accessible because of undue burden or cost. On motion to compel discovery or for a protective order, the person responding must show that the information is not reasonably accessible because of undue burden or cost. If that showing is made, the court may nonetheless order discovery from such sources if the requesting party shows good cause, considering the limitations of Rule 26(b)(2)(C). The court may specify conditions for the discovery.\n\n### *(2) Claiming Privilege or Protection.*\n\n*(A) Information Withheld.* A person withholding subpoenaed information under a claim that it is privileged or subject to protection as trial-preparation material must:\n\n(i) expressly make the claim; and\n\n(ii) describe the nature of the withheld documents, communications, or tangible things in a manner that, without revealing information itself privileged or protected, will enable the parties to assess the claim.\n\n*(B) Information Produced.* If information produced in response to a subpoena is subject to a claim of privilege or of protection as trialpreparation material, the person making the claim may notify any party that received the information of the claim and the basis for it. After being notified, a party must promptly return, sequester, or destroy the specified information and any copies it has; must not use or disclose the information until the claim is resolved; must take reasonable steps to retrieve the information if the party disclosed it before being notified; and may promptly present the information under seal to the court for the district where compliance is required for a determination of the claim. The person who produced the information must preserve the information until the claim is resolved.\n\n**(g) Contempt.** The court for the district where compliance is required – and also, after a motion is transferred, the issuing court – may hold in contempt a person who, having been served, fails without adequate excuse to obey the subpoena or an order related to it.\n\nFor access to subpoena materials, see Fed. R. Civ. P. 45(a) Committee Note (2013)\n\n…\n\n## **Exhibit C-15**\n\n### B2540 (Form 2540 – Subpoena for Rule 2004 Examination) (12/15) UNITED STATES BANKRUPTCY COURT Case 22-50073 Doc 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 299 of 491\n\n\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_ District of \\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_ Connecticut\n\nIn re \\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\n\nCase No. \\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_ Ho Wan Kwok 22-50073\n\nDebtor\n\nChapter \\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_ 11\n\n## **SUBPOENA FOR RULE 2004 EXAMINATION**\n\n#### To: **\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_ Troutman Pepper Hamilton Sanders LLP**\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| Paul Hastings LLP
200 Park Avenue
New York, New York 10166 | |\n\nThe examination will be recorded by this method: \\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_ court reporter/stenographer\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: Sept\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_ ember \\_\\_, 2022\n\nCLERK OF COURT\n\nOR\n\n\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_ *Signature of Clerk or Deputy Clerk* \\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_ *Attorney's signature* Patrick R. Linsey (ct29437)\n\nThe name, address, email address, and telephone number of the attorney representing *(name of party)* \\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_ , who issues or requests this subpoena, are: Luc Despins, Ch. 11 Trustee\n\nPatrick R. Linsey, Esq.; Neubert, Pepe & Monteith, P.C.; 195 Church Street, New Haven, Connecticut 06510 plinsey@npmlaw.com; 203-821-2000\n\n## **Notice to the person who issues or requests this subpoena**\n\nIf this subpoena commands the production of documents, electronically stored information, or tangible things, or the inspection of premises before trial, a notice and a copy of this subpoena must be served on each party before it is served on the person to whom it is directed. Fed. R. Civ. P. 45(a)(4).\n\n## **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 following 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 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 302 of 491\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
- | 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| | | |\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
time
zone
in
which
the
emails
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 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 303 of 491\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 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 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 304 of 491\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 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 305 of 491\n\nsuch Persons, as well as a statement addressing how the information came into their possession, (viii) the claim of privilege under which the Document is withheld, and (ix) all of the circumstances upon which You will rely to support such claim of privilege; and (b) produce a privilege log containing all of the information requested in Part (a) of this Instruction for each Document withheld on the basis of a claim of privilege in accordance with D. Conn. L. Civ. R. 26(e). For any part of a Document Request as to which a claim of privilege or work product is not made, responsive documents should be provided in full.\n\n9. If a portion of an otherwise responsive Document contains information subject to a claim of privilege, only that portion of the Document subject to the claim of privilege shall be deleted or redacted from the Document following the instructions above, and the rest shall be produced.\n\n10. The Requests are continuing in nature. You are hereby instructed to (a) supplement or correct any responses later learned to be incomplete or incorrect immediately upon learning that a prior response was incomplete or incorrect; and (b) produce any additional Documents that are called for under the\n\n11. If a Document is in a language other than English, You should provide that Document. If a Document is in a language other than English, and an English translation exists, You should provide both Documents.\n\n12. All references to Entities includes all affiliates thereof.\n\n13. All references to individual names include all alternative names, aliased, or nicknames.\n\n## Case 22-50073 Doc 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 306 of 491\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 Troutman Pepper Hamilton Sanders LLP, together with any of its employees, agents, counsel, advisors, 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 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 307 of 491\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. \"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: Daniel Podhaskie, Jason Miller, Steve Bannon, Karin Maistrello, Melissa Francis, William Gertz, Arethusa Forsyth, Glenn Mellor, Jennifer Mercurio, Eduardo Eurnekian, Han Chunguang (a/k/a 韩春光), Qu Guojiao (a/k/a Qu Guo Jiao, 屈国姣), Guo Lijie (a/k/a 郭丽杰), Zhang Wei (a/k/a 张伟\\*), Lihong Wei Lafrenz (a/k/a Sara Wei, 魏丽红), Hao Haidong (a/k/a 郝海东), Ross Heinemeyer, Max Krasner, Kyle Bass, Melissa Mendez, Ya Li (a/k/a 李娅), Dinggang Wang (a/k/a 王定刚), An Hong (a/k/a 安红), Yvette Wang (a/k/a Yanping\n\n## Case 22-50073 Doc 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 308 of 491\n\nWang, Yan Ping Wang, 王雁平), Fiona Yu, Je Kin Ming (a/k/a William Je, Yu Jianming, 余建明\n\n), Yaz Qingua, and Lao Jiang (a/k/a Jiang Yunfu, Jiang Yunfu Be, 姜云浮).\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: 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, Assets Sino Limited, Auspicious Coast Limited, Beijing Pangu Investment Co., Beijing Pangu Investment Co. Ltd., Beijing Pangu Investment Inc., Beijing Zenith Holdings Company Limited, Bravo Luck Limited, 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, Elite Well Global Limited, Empire Growth Holdings, G Club Operations LLC, G Fashion LLC, G News LLC, GETTR USA, Genever Holdings Corporation, Genever Holdings LLC, GFASHION MEDIA GROUP INC., GFNY, Inc., Globalist International Limited, GNews Media Group Inc., Golden Spring (New York) Ltd., Greenwich Land LLC, Guo Media, GTV Media Group, Inc., Hamilton Capital Holdings Inc., Head Win Group Limited, Henan Yuda, Himalaya Embassy, Himalaya Exchange, Himalaya Federal Reserve, Himalaya Supervisory Organization, HK International Funds Investments (USA)\n\n## Case 22-50073 Doc 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 309 of 491\n\nLimited LLC, Hong Kong International Funds Investments Limited, Infinite Increase Limited, Infinitum Developments Limited, Insight Phoenix Fund, Lamp Capital LLC, Leading Shine Limited, Leading Shine NY Limited, Long Gate Limited, Next Tycoon Investments Limited, New Federal State of China (a/k/a NFSC), Noble Fame Global Limited, Rosy Acme Ventures Limited, Rule of Law Foundation III, Inc., Rule of Law Foundation IV, Inc., Rule of Law Fund, Rule of Law Society, Rule of Law Society IV, Inc., G-Translators PTY LTD, Saraca Media Group, Inc., Shiny Ace Ltd., Shiny Times Holdings Ltd., Spirit Charter Investment Limited, Stevenson, Wong & Co., Voice of Guo Media, Inc., Well Origin Ltd., World Century Limited, Worldwide Opportunity Holdings Limited, Whitecroft Shore 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\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, correspondence, memoranda, tapes, stenographic or handwritten notes, written forms of any kind,\n\n## Case 22-50073 Doc 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 310 of 491\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\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,\n\n## Case 22-50073 Doc 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 311 of 491\n\nconnected 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, 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\n21. \"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 income or Asset of the Debtor, the Debtor's estate, the Debtor's Family, or Associated Entity.\n\n## Case 22-50073 Doc 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 312 of 491\n\n2. All Documents related to any engagement letter with the Debtor, any member of the Debtor's Family, and/or any Associated Entity, including copy(ies) of such engagement letter(s).\n\n3. All Documents related to the payment of any retainer to You based upon your representation of the Debtor, the Debtor's Family, or an Associated Entity, including documents sufficient to identify the amount of the retainer and its source.\n\n4. All Documents related to any fees, payments, or monies received by You from or on behalf of the Debtor, the Debtor's Family, a Family Related Entity, or an Associated Entity held in escrow or in a client trust account.\n\n5. Documents sufficient to show the amount, date, and source of any payments made to You by or for the benefit of the Debtor, the Debtor's Family, or an Associated Entity.\n\n6. 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\n7. All Documents related to the Associated Entities, including but not limited to Documents related to their corporate structure, Assets, incorporation information, officers and directors, business purpose, and relationship to the Debtor, to any member of the Debtor's Family, or to any Associated Individual.\n\n8. All Documents regarding any investment or business dealing made by, with, or on behalf of Debtor or the Debtor's Family, on the one hand, and an Associated Entity, on the other hand.\n\n## Case 22-50073 Doc 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 313 of 491\n\n9. All Documents related to any Entity that the Debtor, the Debtor's Estate, the Debtor's Family, or the Associated Entities hold any interest or investment in, including but not limited to the nature and value of that interest or investment; any proceeds or benefits from such Entity that the Debtor, the Debtor's Estate, the Debtor's Family, or the Associated Entities receive on account of such interest or investment; and all Documents relating to any financial reporting or data relating to such Entity, including but not limited to all books and records, financial statements or tax Documents.\n\n10. All Documents regarding the *Lady May*; the Sherry Netherland Hotel / Condominium; 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.; and any financial interest that the Debtor or the Debtor's estate possesses in any Associated Entity.\n\n11. All Documents related to the purported Declaration of Trust and Agreement, dated February 17, 2015, entered into by the Debtor, as Trustee, Genever Holdings Corporation, and Genever Holdings LLC, in favor of Bravo Luck Limited, as beneficiary.\n\n12. All Documents related to any aircraft owned, controlled, or used by the Debtor, including without limitation the aircraft bearing tail number T7-GQM 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.\n\n13. All Documents related to any investments or trading by the Debtor, the Debtor's Family, or an Associated Entity, in or around July 2020, or at any other time, in crude oil futures or any similar commodity, including without limitation Communications with Jiang Yunfu Be regarding any such investments or trading.\n\n## Case 22-50073 Doc 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 314 of 491\n\n14. All Communications between You and, either, the Debtor, the Debtor's Family, or any Associated Individual, agent, employee, or other individual acting on behalf of the Debtor, related to any Transfer, investment, or other transaction or business dealing relating to the Debtor, the Debtor's Estate, the Debtor's Family, or the Associated Entities.\n\n15. All Documents concerning any trust or similar instrument set up by, on behalf of, or for the benefit of Debtor, Debtor's Estate, Debtor's Family, or Associated Entities, including but not limited to Documents showing when the trust(s) was created, by whom it was created, to whose benefit it was created, and the corpus of the instrument.\n\n16. All Documents related to any sale, acquisition, disposition, purchase, investment, contribution, gift, extension of credit, loan, or Transfer involving the Debtor, the Debtor's Family, or any Associated Entity.\n\n17. 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\n18. All Documents related to any loans or extensions of credit, or applications for the same, to or from the Debtor, the Debtor's Estate, the Debtor's Family or any Associated Entity, including but not limited to (i) the terms of any such loans or extensions of credit, including their terms of repayment, representations and warranties, and interest rate, and (ii) all evidence of payments of the loans.\n\n## Case 22-50073 Doc 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 315 of 491\n\n19. All Documents related to the Debtor's use of any Assets belonging to, controlled by, or whose complete or partial ownership is held by the Debtor's Family, an Associated Entity, or an Associated Individual.\n\n20. 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\n21. All Documents related to any pledges of Assets of any Associated Entity, including Bravo Luck Limited, to any other Entity.\n\n| Case 22-50073 | Doc 839 | Filed 09/07/22 | | Entered 09/07/22 20:02:47 | Page 316 of |\n|-----------------------------------------------------------------|---------|----------------|-----|---------------------------|-------------|\n| B2540 (Form 2540 – Subpoena for Rule 2004 Examination) (Page 2) | | | 491 | | |\n| | | | | | |\n\n| I received this subpoena for (name of individual and title, if any): ______________________________________________
on (date)
__________
I served the subpoena by delivering a copy to the named person
___________________________________________________________________________________________________
__________________________________
on (date) ___________________ ; or | as follows: ____________________________________ |\n|-----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|----------------------------------------------------------------------------|\n| | |\n| | |\n| | |\n| I returned the subpoena unexecuted because: ____________________________________________________________
___________________________________________________________________________________________________ | |\n| Unless the subpoena was issued on behalf of the United States, or one of its officers or agents, I have also tendered to the
witness the fees for one day's attendance, and the mileage allowed by law, in the amount of \\$ _______________________ . | |\n| My fees are \\$ _________
for travel and \\$_________ | for services, for a total of \\$_________ |\n| I declare under penalty of perjury
that this information is true and correct. | |\n| Date: _______________ | |\n| | ________________________________________________
Server's signature |\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; (ii) requires a person to comply beyond the geographical limits\n\nspecified in Rule 45(c); (iii) requires disclosure of privileged or other protected matter, if no\n\nexception or waiver applies; or\n\n(iv) subjects a person to undue burden.\n\n*(B) When Permitted.* To protect a person subject to or affected by a subpoena, the court for the district where compliance is required may, on motion, quash or modify the subpoena if it requires:\n\n(i) disclosing a trade secret or other confidential research, development, or commercial information; or\n\n(ii) disclosing an unretained expert's opinion or information that does not describe specific occurrences in dispute and results from the expert's study that was not requested by a party.\n\n*(C) Specifying Conditions as an Alternative.* In the circumstances described in Rule 45(d)(3)(B), the court may, instead of quashing or modifying a subpoena, order appearance or production under specified conditions if the serving party:\n\n(i) shows a substantial need for the testimony or material that cannot be otherwise met without undue hardship; and\n\n(ii) ensures that the subpoenaed person will be reasonably compensated.\n\n#### **(e) Duties in Responding to a Subpoena.**\n\n*(1) Producing Documents or Electronically Stored Information.* These procedures apply to producing documents or electronically stored information:\n\n*(A) Documents.* A person responding to a subpoena to produce documents must produce them as they are kept in the ordinary course of business or must organize and label them to correspond to the categories in the demand.\n\n*(B) Form for Producing Electronically Stored Information Not Specified.* If a subpoena does not specify a form for producing electronically stored information, the person responding must produce it in a form or forms in which it is ordinarily maintained or in a reasonably usable form or forms.\n\n*(C) Electronically Stored Information Produced in Only One Form.* The person responding need not produce the same electronically stored information in more than one form.\n\n*(D) Inaccessible Electronically Stored Information.* The person responding need not provide discovery of electronically stored information from sources that the person identifies as not reasonably accessible because of undue burden or cost. On motion to compel discovery or for a protective order, the person responding must show that the information is not reasonably accessible because of undue burden or cost. If that showing is made, the court may nonetheless order discovery from such sources if the requesting party shows good cause, considering the limitations of Rule 26(b)(2)(C). The court may specify conditions for the discovery.\n\n### *(2) Claiming Privilege or Protection.*\n\n*(A) Information Withheld.* A person withholding subpoenaed information under a claim that it is privileged or subject to protection as trial-preparation material must:\n\n(i) expressly make the claim; and\n\n(ii) describe the nature of the withheld documents, communications, or tangible things in a manner that, without revealing information itself privileged or protected, will enable the parties to assess the claim.\n\n*(B) Information Produced.* If information produced in response to a subpoena is subject to a claim of privilege or of protection as trialpreparation material, the person making the claim may notify any party that received the information of the claim and the basis for it. After being notified, a party must promptly return, sequester, or destroy the specified information and any copies it has; must not use or disclose the information until the claim is resolved; must take reasonable steps to retrieve the information if the party disclosed it before being notified; and may promptly present the information under seal to the court for the district where compliance is required for a determination of the claim. The person who produced the information must preserve the information until the claim is resolved.\n\n**(g) Contempt.** The court for the district where compliance is required – and also, after a motion is transferred, the issuing court – may hold in contempt a person who, having been served, fails without adequate excuse to obey the subpoena or an order related to it.\n\nFor access to subpoena materials, see Fed. R. Civ. P. 45(a) Committee Note (2013)\n\n…\n\n## **Exhibit C-16**\n\n### B2540 (Form 2540 – Subpoena for Rule 2004 Examination) (12/15) UNITED STATES BANKRUPTCY COURT Case 22-50073 Doc 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 319 of 491\n\n\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_ District of \\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_ Connecticut\n\nIn re \\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\n\nCase No. \\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_ Ho Wan Kwok 22-50073\n\nDebtor\n\nChapter \\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_ 11\n\n## **SUBPOENA FOR RULE 2004 EXAMINATION**\n\nTo: **\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_ Forbes Hare**\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| Paul Hastings LLP
200 Park Avenue
New York, New York 10166 | |\n\nThe examination will be recorded by this method: \\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_ court reporter/stenographer\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: Sept\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_ ember \\_\\_, 2022\n\nCLERK OF COURT\n\nOR\n\n\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_ *Signature of Clerk or Deputy Clerk* \\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_ *Attorney's signature* Patrick R. Linsey (ct29437)\n\nThe name, address, email address, and telephone number of the attorney representing *(name of party)* \\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_ , who issues or requests this subpoena, are: Luc Despins, Ch. 11 Trustee\n\nPatrick R. Linsey, Esq.; Neubert, Pepe & Monteith, P.C.; 195 Church Street, New Haven, Connecticut 06510 plinsey@npmlaw.com; 203-821-2000\n\n## **Notice to the person who issues or requests this subpoena**\n\nIf this subpoena commands the production of documents, electronically stored information, or tangible things, or the inspection of premises before trial, a notice and a copy of this subpoena must be served on each party before it is served on the person to whom it is directed. Fed. R. Civ. P. 45(a)(4).\n\n## **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 following 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 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 322 of 491\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
- | 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| | | |\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
time
zone
in
which
the
emails
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 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 323 of 491\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 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 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 324 of 491\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 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 325 of 491\n\nsuch Persons, as well as a statement addressing how the information came into their possession, (viii) the claim of privilege under which the Document is withheld, and (ix) all of the circumstances upon which You will rely to support such claim of privilege; and (b) produce a privilege log containing all of the information requested in Part (a) of this Instruction for each Document withheld on the basis of a claim of privilege in accordance with D. Conn. L. Civ. R. 26(e). For any part of a Document Request as to which a claim of privilege or work product is not made, responsive documents should be provided in full.\n\n9. If a portion of an otherwise responsive Document contains information subject to a claim of privilege, only that portion of the Document subject to the claim of privilege shall be deleted or redacted from the Document following the instructions above, and the rest shall be produced.\n\n10. The Requests are continuing in nature. You are hereby instructed to (a) supplement or correct any responses later learned to be incomplete or incorrect immediately upon learning that a prior response was incomplete or incorrect; and (b) produce any additional Documents that are called for under the\n\n11. If a Document is in a language other than English, You should provide that Document. If a Document is in a language other than English, and an English translation exists, You should provide both Documents.\n\n12. All references to Entities includes all affiliates thereof.\n\n13. All references to individual names include all alternative names, aliased, or nicknames.\n\n## Case 22-50073 Doc 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 326 of 491\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 Forbes Hare, together with any of its employees, agents, counsel, advisors, 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 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 327 of 491\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. \"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: Daniel Podhaskie, Jason Miller, Steve Bannon, Karin Maistrello, Melissa Francis, William Gertz, Arethusa Forsyth, Glenn Mellor, Jennifer Mercurio, Eduardo Eurnekian, Han Chunguang (a/k/a 韩春光), Qu Guojiao (a/k/a Qu Guo Jiao, 屈国姣), Guo Lijie (a/k/a 郭丽杰), Zhang Wei (a/k/a 张伟\\*), Lihong Wei Lafrenz (a/k/a Sara Wei, 魏丽红), Hao Haidong (a/k/a 郝海东), Ross Heinemeyer, Max Krasner, Kyle Bass, Melissa Mendez, Ya Li (a/k/a 李娅), Dinggang Wang (a/k/a 王定刚), An Hong (a/k/a 安红), Yvette Wang (a/k/a Yanping\n\n## Case 22-50073 Doc 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 328 of 491\n\nWang, Yan Ping Wang, 王雁平), Fiona Yu, Je Kin Ming (a/k/a William Je, Yu Jianming, 余建明\n\n), Yaz Qingua, and Lao Jiang (a/k/a Jiang Yunfu, Jiang Yunfu Be, 姜云浮).\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: 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, Assets Sino Limited, Auspicious Coast Limited, Beijing Pangu Investment Co., Beijing Pangu Investment Co. Ltd., Beijing Pangu Investment Inc., Beijing Zenith Holdings Company Limited, Bravo Luck Limited, 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, Elite Well Global Limited, Empire Growth Holdings, G Club Operations LLC, G Fashion LLC, G News LLC, GETTR USA, Genever Holdings Corporation, Genever Holdings LLC, GFASHION MEDIA GROUP INC., GFNY, Inc., Globalist International Limited, GNews Media Group Inc., Golden Spring (New York) Ltd., Greenwich Land LLC, Guo Media, GTV Media Group, Inc., Hamilton Capital Holdings Inc., Head Win Group Limited, Henan Yuda, Himalaya Embassy, Himalaya Exchange, Himalaya Federal Reserve, Himalaya Supervisory Organization, HK International Funds Investments (USA)\n\n## Case 22-50073 Doc 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 329 of 491\n\nLimited LLC, Hong Kong International Funds Investments Limited, Infinite Increase Limited, Infinitum Developments Limited, Insight Phoenix Fund, Lamp Capital LLC, Leading Shine Limited, Leading Shine NY Limited, Long Gate Limited, Next Tycoon Investments Limited, New Federal State of China (a/k/a NFSC), Noble Fame Global Limited, Rosy Acme Ventures Limited, Rule of Law Foundation III, Inc., Rule of Law Foundation IV, Inc., Rule of Law Fund, Rule of Law Society, Rule of Law Society IV, Inc., G-Translators PTY LTD, Saraca Media Group, Inc., Shiny Ace Ltd., Shiny Times Holdings Ltd., Spirit Charter Investment Limited, Stevenson, Wong & Co., Voice of Guo Media, Inc., Well Origin Ltd., World Century Limited, Worldwide Opportunity Holdings Limited, Whitecroft Shore 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\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, correspondence, memoranda, tapes, stenographic or handwritten notes, written forms of any kind,\n\n## Case 22-50073 Doc 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 330 of 491\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\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,\n\n## Case 22-50073 Doc 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 331 of 491\n\nconnected 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, 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\n21. \"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 income or Asset of the Debtor, the Debtor's estate, the Debtor's Family, or Associated Entity.\n\n## Case 22-50073 Doc 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 332 of 491\n\n2. All Documents related to any engagement letter with the Debtor, any member of the Debtor's Family, and/or any Associated Entity, including copy(ies) of such engagement letter(s).\n\n3. All Documents related to the payment of any retainer to You based upon your representation of the Debtor, the Debtor's Family, or an Associated Entity, including documents sufficient to identify the amount of the retainer and its source.\n\n4. All Documents related to any fees, payments, or monies received by You from or on behalf of the Debtor, the Debtor's Family, a Family Related Entity, or an Associated Entity held in escrow or in a client trust account.\n\n5. Documents sufficient to show the amount, date, and source of any payments made to You by or for the benefit of the Debtor, the Debtor's Family, or an Associated Entity.\n\n6. 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\n7. All Documents related to the Associated Entities, including but not limited to Documents related to their corporate structure, Assets, incorporation information, officers and directors, business purpose, and relationship to the Debtor, to any member of the Debtor's Family, or to any Associated Individual.\n\n8. All Documents regarding any investment or business dealing made by, with, or on behalf of Debtor or the Debtor's Family, on the one hand, and an Associated Entity, on the other hand.\n\n## Case 22-50073 Doc 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 333 of 491\n\n9. All Documents related to any Entity that the Debtor, the Debtor's Estate, the Debtor's Family, or the Associated Entities hold any interest or investment in, including but not limited to the nature and value of that interest or investment; any proceeds or benefits from such Entity that the Debtor, the Debtor's Estate, the Debtor's Family, or the Associated Entities receive on account of such interest or investment; and all Documents relating to any financial reporting or data relating to such Entity, including but not limited to all books and records, financial statements or tax Documents.\n\n10. All Documents regarding the *Lady May*; the Sherry Netherland Hotel / Condominium; 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.; and any financial interest that the Debtor or the Debtor's estate possesses in any Associated Entity.\n\n11. All Documents related to the purported Declaration of Trust and Agreement, dated February 17, 2015, entered into by the Debtor, as Trustee, Genever Holdings Corporation, and Genever Holdings LLC, in favor of Bravo Luck Limited, as beneficiary.\n\n12. All Documents related to any aircraft owned, controlled, or used by the Debtor, including without limitation the aircraft bearing tail number T7-GQM 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.\n\n13. All Documents related to any investments or trading by the Debtor, the Debtor's Family, or an Associated Entity, in or around July 2020, or at any other time, in crude oil futures or any similar commodity, including without limitation Communications with Jiang Yunfu Be regarding any such investments or trading.\n\n## Case 22-50073 Doc 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 334 of 491\n\n14. All Communications between You and, either, the Debtor, the Debtor's Family, or any Associated Individual, agent, employee, or other individual acting on behalf of the Debtor, related to any Transfer, investment, or other transaction or business dealing relating to the Debtor, the Debtor's Estate, the Debtor's Family, or the Associated Entities.\n\n15. All Documents concerning any trust or similar instrument set up by, on behalf of, or for the benefit of Debtor, Debtor's Estate, Debtor's Family, or Associated Entities, including but not limited to Documents showing when the trust(s) was created, by whom it was created, to whose benefit it was created, and the corpus of the instrument.\n\n16. All Documents related to any sale, acquisition, disposition, purchase, investment, contribution, gift, extension of credit, loan, or Transfer involving the Debtor, the Debtor's Family, or any Associated Entity.\n\n17. 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\n18. All Documents related to any loans or extensions of credit, or applications for the same, to or from the Debtor, the Debtor's Estate, the Debtor's Family or any Associated Entity, including but not limited to (i) the terms of any such loans or extensions of credit, including their terms of repayment, representations and warranties, and interest rate, and (ii) all evidence of payments of the loans.\n\n## Case 22-50073 Doc 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 335 of 491\n\n19. All Documents related to the Debtor's use of any Assets belonging to, controlled by, or whose complete or partial ownership is held by the Debtor's Family, an Associated Entity, or an Associated Individual.\n\n20. 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\n21. All Documents related to any pledges of Assets of any Associated Entity, including Bravo Luck Limited, to any other Entity.\n\n| Case 22-50073 | Doc 839 | Filed 09/07/22 | Entered 09/07/22 20:02:47 | Page 336 of |\n|-----------------------------------------------------------------|---------|----------------|---------------------------|-------------|\n| B2540 (Form 2540 – Subpoena for Rule 2004 Examination) (Page 2) | | 491 | | |\n| | | | | |\n\n| | | (This section should not be filed with the court unless required by Fed. R. Civ. P. 45.) |\n|------------------------------------|----------------------------------------------------------------|------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|\n| on (date)
__________ | | I received this subpoena for (name of individual and title, if any): ______________________________________________ |\n| | I served the subpoena by delivering a copy to the named person | as follows: ____________________________________
___________________________________________________________________________________________________ |\n| __________________________________ | on (date) ___________________ ; or | |\n| | | I returned the subpoena unexecuted because: ____________________________________________________________
___________________________________________________________________________________________________ |\n| | | |\n| My fees are \\$ _________ | for travel and \\$_________ | Unless the subpoena was issued on behalf of the United States, or one of its officers or agents, I have also tendered to the
witness the fees for one day's attendance, and the mileage allowed by law, in the amount of \\$ _______________________ .
for services, for a total of \\$_________ |\n| I declare under penalty of perjury | that this information is true and correct. | |\n| | | |\n| Date: _______________ | | ________________________________________________
Server's signature |\n\n*Server's address*\n\nAdditional information concerning attempted service, etc.:\n\n### **Federal Rule of Civil Procedure 45(c), (d), (e), and (g) (Effective 12/1/13) (made applicable in bankruptcy cases by Rule 9016, Federal Rules of Bankruptcy Procedure)**\n\n#### **(c) Place of compliance.**\n\n*(1) For a Trial, Hearing, or Deposition.* A subpoena may command a person to attend a trial, hearing, or deposition only as follows:\n\n(A) within 100 miles of where the person resides, is employed, or regularly transacts business in person; or\n\n(B) within the state where the person resides, is employed, or regularly transacts business in person, if the person\n\n(i) is a party or a party's officer; or\n\n(ii) is commanded to attend a trial and would not incur substantial expense.\n\n#### *(2) For Other Discovery.* A subpoena may command:\n\n(A) production of documents, or electronically stored information, or things at a place within 100 miles of where the person resides, is employed, or regularly transacts business in person; and\n\n(B) inspection of premises, at the premises to be inspected.\n\n#### **(d) Protecting a Person Subject to a Subpoena; Enforcement.**\n\n*(1) Avoiding Undue Burden or Expense; Sanctions.* A party or attorney responsible for issuing and serving a subpoena must take reasonable steps to avoid imposing undue burden or expense on a person subject to the subpoena. The court for the district where compliance is required must enforce this duty and impose an appropriate sanction which may include lost earnings and reasonable attorney's fees — on a party or attorney who fails to comply.\n\n#### *(2) Command to Produce Materials or Permit Inspection.*\n\n*(A) Appearance Not Required.* A person commanded to produce documents, electronically stored information, or tangible things, or to permit the inspection of premises, need not appear in person at the place of production or inspection unless also commanded to appear for a deposition, hearing, or trial.\n\n*(B) Objections*. A person commanded to produce documents or tangible things or to permit inspection may serve on the party or attorney designated in the subpoena a written objection to inspecting, copying, testing or sampling any or all of the materials or to inspecting the premises — or to producing electronically stored information in the form or forms requested. The objection must be served before the earlier of the time specified for compliance or 14 days after the subpoena is served. If an objection is made, the following rules apply:\n\n(i) At any time, on notice to the commanded person, the serving party may move the court for the district where compliance is required for an order compelling production or inspection.\n\n(ii) These acts may be required only as directed in the order, and the order must protect a person who is neither a party nor a party's officer from significant expense resulting from compliance.\n\n#### *(3) Quashing or Modifying a Subpoena.*\n\n*(A) When Required.* On timely motion, the court for the district where compliance is required must quash or modify a subpoena that:\n\n(i) fails to allow a reasonable time to comply; (ii) requires a person to comply beyond the geographical limits\n\nspecified in Rule 45(c); (iii) requires disclosure of privileged or other protected matter, if no\n\nexception or waiver applies; or\n\n(iv) subjects a person to undue burden.\n\n*(B) When Permitted.* To protect a person subject to or affected by a subpoena, the court for the district where compliance is required may, on motion, quash or modify the subpoena if it requires:\n\n(i) disclosing a trade secret or other confidential research, development, or commercial information; or\n\n(ii) disclosing an unretained expert's opinion or information that does not describe specific occurrences in dispute and results from the expert's study that was not requested by a party.\n\n*(C) Specifying Conditions as an Alternative.* In the circumstances described in Rule 45(d)(3)(B), the court may, instead of quashing or modifying a subpoena, order appearance or production under specified conditions if the serving party:\n\n(i) shows a substantial need for the testimony or material that cannot be otherwise met without undue hardship; and\n\n(ii) ensures that the subpoenaed person will be reasonably compensated.\n\n#### **(e) Duties in Responding to a Subpoena.**\n\n*(1) Producing Documents or Electronically Stored Information.* These procedures apply to producing documents or electronically stored information:\n\n*(A) Documents.* A person responding to a subpoena to produce documents must produce them as they are kept in the ordinary course of business or must organize and label them to correspond to the categories in the demand.\n\n*(B) Form for Producing Electronically Stored Information Not Specified.* If a subpoena does not specify a form for producing electronically stored information, the person responding must produce it in a form or forms in which it is ordinarily maintained or in a reasonably usable form or forms.\n\n*(C) Electronically Stored Information Produced in Only One Form.* The person responding need not produce the same electronically stored information in more than one form.\n\n*(D) Inaccessible Electronically Stored Information.* The person responding need not provide discovery of electronically stored information from sources that the person identifies as not reasonably accessible because of undue burden or cost. On motion to compel discovery or for a protective order, the person responding must show that the information is not reasonably accessible because of undue burden or cost. If that showing is made, the court may nonetheless order discovery from such sources if the requesting party shows good cause, considering the limitations of Rule 26(b)(2)(C). The court may specify conditions for the discovery.\n\n### *(2) Claiming Privilege or Protection.*\n\n*(A) Information Withheld.* A person withholding subpoenaed information under a claim that it is privileged or subject to protection as trial-preparation material must:\n\n(i) expressly make the claim; and\n\n(ii) describe the nature of the withheld documents, communications, or tangible things in a manner that, without revealing information itself privileged or protected, will enable the parties to assess the claim.\n\n*(B) Information Produced.* If information produced in response to a subpoena is subject to a claim of privilege or of protection as trialpreparation material, the person making the claim may notify any party that received the information of the claim and the basis for it. After being notified, a party must promptly return, sequester, or destroy the specified information and any copies it has; must not use or disclose the information until the claim is resolved; must take reasonable steps to retrieve the information if the party disclosed it before being notified; and may promptly present the information under seal to the court for the district where compliance is required for a determination of the claim. The person who produced the information must preserve the information until the claim is resolved.\n\n**(g) Contempt.** The court for the district where compliance is required – and also, after a motion is transferred, the issuing court – may hold in contempt a person who, having been served, fails without adequate excuse to obey the subpoena or an order related to it.\n\nFor access to subpoena materials, see Fed. R. Civ. P. 45(a) Committee Note (2013)\n\n…\n\n## **Exhibit C-17**\n\n#### B2540 (Form 2540 – Subpoena for Rule 2004 Examination) (12/15) Case 22-50073 Doc 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 339 of 491\n\nUNITED STATES BANKRUPTCY COURT\n\n\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_ District of \\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_ Connecticut\n\nIn re \\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\n\nCase No. \\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_ Ho Wan Kwok 22-50073\n\nDebtor\n\nChapter \\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_ 11\n\n## **SUBPOENA FOR RULE 2004 EXAMINATION**\n\nTo: **\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_** Ogier\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| Paul Hastings LLP
200 Park Avenue
New York, New York 10166 | |\n\nThe examination will be recorded by this method: \\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_ court reporter/stenographer\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: Sept\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_ ember \\_\\_, 2022\n\nCLERK OF COURT\n\nOR\n\n\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_ *Signature of Clerk or Deputy Clerk* \\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_ *Attorney's signature* Patrick R. Linsey (ct29437)\n\nThe name, address, email address, and telephone number of the attorney representing *(name of party)* \\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_ , who issues or requests this subpoena, are: Luc Despins, Ch. 11 Trustee\n\nPatrick R. Linsey, Esq.; Neubert, Pepe & Monteith, P.C.; 195 Church Street, New Haven, Connecticut 06510 plinsey@npmlaw.com; 203-821-2000\n\n## **Notice to the person who issues or requests this subpoena**\n\nIf this subpoena commands the production of documents, electronically stored information, or tangible things, or the inspection of premises before trial, a notice and a copy of this subpoena must be served on each party before it is served on the person to whom it is directed. Fed. R. Civ. P. 45(a)(4).\n\n## **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 following 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 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 342 of 491\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
- | 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| | | | | | |\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
time
zone
in
which
the
emails
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 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 343 of 491\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 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 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 344 of 491\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 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 345 of 491\n\nsuch Persons, as well as a statement addressing how the information came into their possession, (viii) the claim of privilege under which the Document is withheld, and (ix) all of the circumstances upon which You will rely to support such claim of privilege; and (b) produce a privilege log containing all of the information requested in Part (a) of this Instruction for each Document withheld on the basis of a claim of privilege in accordance with D. Conn. L. Civ. R. 26(e). For any part of a Document Request as to which a claim of privilege or work product is not made, responsive documents should be provided in full.\n\n9. If a portion of an otherwise responsive Document contains information subject to a claim of privilege, only that portion of the Document subject to the claim of privilege shall be deleted or redacted from the Document following the instructions above, and the rest shall be produced.\n\n10. The Requests are continuing in nature. You are hereby instructed to (a) supplement or correct any responses later learned to be incomplete or incorrect immediately upon learning that a prior response was incomplete or incorrect; and (b) produce any additional Documents that are called for under the\n\n11. If a Document is in a language other than English, You should provide that Document. If a Document is in a language other than English, and an English translation exists, You should provide both Documents.\n\n12. All references to Entities includes all affiliates thereof.\n\n13. All references to individual names include all alternative names, aliased, or nicknames.\n\n## Case 22-50073 Doc 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 346 of 491\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 Ogier, together with any of its employees, agents, counsel, advisors, 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 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 347 of 491\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. \"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: Daniel Podhaskie, Jason Miller, Steve Bannon, Karin Maistrello, Melissa Francis, William Gertz, Arethusa Forsyth, Glenn Mellor, Jennifer Mercurio, Eduardo Eurnekian, Han Chunguang (a/k/a 韩春光), Qu Guojiao (a/k/a Qu Guo Jiao, 屈国姣), Guo Lijie (a/k/a 郭丽杰), Zhang Wei (a/k/a 张伟\\*), Lihong Wei Lafrenz (a/k/a Sara Wei, 魏丽红), Hao Haidong (a/k/a 郝海东), Ross Heinemeyer, Max Krasner, Kyle Bass, Melissa Mendez, Ya Li (a/k/a 李娅), Dinggang Wang (a/k/a 王定刚), An Hong (a/k/a 安红), Yvette Wang (a/k/a Yanping\n\n## Case 22-50073 Doc 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 348 of 491\n\nWang, Yan Ping Wang, 王雁平), Fiona Yu, Je Kin Ming (a/k/a William Je, Yu Jianming, 余建明\n\n), Yaz Qingua, and Lao Jiang (a/k/a Jiang Yunfu, Jiang Yunfu Be, 姜云浮).\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: 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, Assets Sino Limited, Auspicious Coast Limited, Beijing Pangu Investment Co., Beijing Pangu Investment Co. Ltd., Beijing Pangu Investment Inc., Beijing Zenith Holdings Company Limited, Bravo Luck Limited, 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, Elite Well Global Limited, Empire Growth Holdings, G Club Operations LLC, G Fashion LLC, G News LLC, GETTR USA, Genever Holdings Corporation, Genever Holdings LLC, GFASHION MEDIA GROUP INC., GFNY, Inc., Globalist International Limited, GNews Media Group Inc., Golden Spring (New York) Ltd., Greenwich Land LLC, Guo Media, GTV Media Group, Inc., Hamilton Capital Holdings Inc., Head Win Group Limited, Henan Yuda, Himalaya Embassy, Himalaya Exchange, Himalaya Federal Reserve, Himalaya Supervisory Organization, HK International Funds Investments (USA)\n\n## Case 22-50073 Doc 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 349 of 491\n\nLimited LLC, Hong Kong International Funds Investments Limited, Infinite Increase Limited, Infinitum Developments Limited, Insight Phoenix Fund, Lamp Capital LLC, Leading Shine Limited, Leading Shine NY Limited, Long Gate Limited, Next Tycoon Investments Limited, New Federal State of China (a/k/a NFSC), Noble Fame Global Limited, Rosy Acme Ventures Limited, Rule of Law Foundation III, Inc., Rule of Law Foundation IV, Inc., Rule of Law Fund, Rule of Law Society, Rule of Law Society IV, Inc., G-Translators PTY LTD, Saraca Media Group, Inc., Shiny Ace Ltd., Shiny Times Holdings Ltd., Spirit Charter Investment Limited, Stevenson, Wong & Co., Voice of Guo Media, Inc., Well Origin Ltd., World Century Limited, Worldwide Opportunity Holdings Limited, Whitecroft Shore 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\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, correspondence, memoranda, tapes, stenographic or handwritten notes, written forms of any kind,\n\n## Case 22-50073 Doc 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 350 of 491\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\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,\n\n## Case 22-50073 Doc 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 351 of 491\n\nconnected 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, 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\n21. \"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 income or Asset of the Debtor, the Debtor's estate, the Debtor's Family, or Associated Entity.\n\n## Case 22-50073 Doc 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 352 of 491\n\n2. All Documents related to any engagement letter with the Debtor, any member of the Debtor's Family, and/or any Associated Entity, including copy(ies) of such engagement letter(s).\n\n3. All Documents related to the payment of any retainer to You based upon your representation of the Debtor, the Debtor's Family, or an Associated Entity, including documents sufficient to identify the amount of the retainer and its source.\n\n4. All Documents related to any fees, payments, or monies received by You from or on behalf of the Debtor, the Debtor's Family, a Family Related Entity, or an Associated Entity held in escrow or in a client trust account.\n\n5. Documents sufficient to show the amount, date, and source of any payments made to You by or for the benefit of the Debtor, the Debtor's Family, or an Associated Entity.\n\n6. 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\n7. All Documents related to the Associated Entities, including but not limited to Documents related to their corporate structure, Assets, incorporation information, officers and directors, business purpose, and relationship to the Debtor, to any member of the Debtor's Family, or to any Associated Individual.\n\n8. All Documents regarding any investment or business dealing made by, with, or on behalf of Debtor or the Debtor's Family, on the one hand, and an Associated Entity, on the other hand.\n\n## Case 22-50073 Doc 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 353 of 491\n\n9. All Documents related to any Entity that the Debtor, the Debtor's Estate, the Debtor's Family, or the Associated Entities hold any interest or investment in, including but not limited to the nature and value of that interest or investment; any proceeds or benefits from such Entity that the Debtor, the Debtor's Estate, the Debtor's Family, or the Associated Entities receive on account of such interest or investment; and all Documents relating to any financial reporting or data relating to such Entity, including but not limited to all books and records, financial statements or tax Documents.\n\n10. All Documents regarding the *Lady May*; the Sherry Netherland Hotel / Condominium; 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.; and any financial interest that the Debtor or the Debtor's estate possesses in any Associated Entity.\n\n11. All Documents related to the purported Declaration of Trust and Agreement, dated February 17, 2015, entered into by the Debtor, as Trustee, Genever Holdings Corporation, and Genever Holdings LLC, in favor of Bravo Luck Limited, as beneficiary.\n\n12. All Documents related to any aircraft owned, controlled, or used by the Debtor, including without limitation the aircraft bearing tail number T7-GQM 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.\n\n13. All Documents related to any investments or trading by the Debtor, the Debtor's Family, or an Associated Entity, in or around July 2020, or at any other time, in crude oil futures or any similar commodity, including without limitation Communications with Jiang Yunfu Be regarding any such investments or trading.\n\n## Case 22-50073 Doc 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 354 of 491\n\n14. All Communications between You and, either, the Debtor, the Debtor's Family, or any Associated Individual, agent, employee, or other individual acting on behalf of the Debtor, related to any Transfer, investment, or other transaction or business dealing relating to the Debtor, the Debtor's Estate, the Debtor's Family, or the Associated Entities.\n\n15. All Documents concerning any trust or similar instrument set up by, on behalf of, or for the benefit of Debtor, Debtor's Estate, Debtor's Family, or Associated Entities, including but not limited to Documents showing when the trust(s) was created, by whom it was created, to whose benefit it was created, and the corpus of the instrument.\n\n16. All Documents related to any sale, acquisition, disposition, purchase, investment, contribution, gift, extension of credit, loan, or Transfer involving the Debtor, the Debtor's Family, or any Associated Entity.\n\n17. 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\n18. All Documents related to any loans or extensions of credit, or applications for the same, to or from the Debtor, the Debtor's Estate, the Debtor's Family or any Associated Entity, including but not limited to (i) the terms of any such loans or extensions of credit, including their terms of repayment, representations and warranties, and interest rate, and (ii) all evidence of payments of the loans.\n\n## Case 22-50073 Doc 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 355 of 491\n\n19. All Documents related to the Debtor's use of any Assets belonging to, controlled by, or whose complete or partial ownership is held by the Debtor's Family, an Associated Entity, or an Associated Individual.\n\n20. 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\n21. All Documents related to any pledges of Assets of any Associated Entity, including Bravo Luck Limited, to any other Entity.\n\n| Case 22-50073 | Doc 839 | Filed 09/07/22 | | Entered 09/07/22 20:02:47 | Page 356 of |\n|-----------------------------------------------------------------|---------|----------------|-----|---------------------------|-------------|\n| B2540 (Form 2540 – Subpoena for Rule 2004 Examination) (Page 2) | | | 491 | | |\n| | | | | | |\n\n| | | (This section should not be filed with the court unless required by Fed. R. Civ. P. 45.) |\n|------------------------------------|----------------------------------------------------------------|------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|\n| on (date)
__________ | | I received this subpoena for (name of individual and title, if any): ______________________________________________ |\n| | I served the subpoena by delivering a copy to the named person | as follows: ____________________________________
___________________________________________________________________________________________________ |\n| __________________________________ | on (date) ___________________ ; or | |\n| | | I returned the subpoena unexecuted because: ____________________________________________________________
___________________________________________________________________________________________________ |\n| | | |\n| My fees are \\$ _________ | for travel and \\$_________ | Unless the subpoena was issued on behalf of the United States, or one of its officers or agents, I have also tendered to the
witness the fees for one day's attendance, and the mileage allowed by law, in the amount of \\$ _______________________ .
for services, for a total of \\$_________ |\n| I declare under penalty of perjury | that this information is true and correct. | |\n| | | |\n| Date: _______________ | | ________________________________________________
Server's signature |\n\n*Server's address*\n\nAdditional information concerning attempted service, etc.:\n\n### **Federal Rule of Civil Procedure 45(c), (d), (e), and (g) (Effective 12/1/13) (made applicable in bankruptcy cases by Rule 9016, Federal Rules of Bankruptcy Procedure)**\n\n#### **(c) Place of compliance.**\n\n*(1) For a Trial, Hearing, or Deposition.* A subpoena may command a person to attend a trial, hearing, or deposition only as follows:\n\n(A) within 100 miles of where the person resides, is employed, or regularly transacts business in person; or\n\n(B) within the state where the person resides, is employed, or regularly transacts business in person, if the person\n\n(i) is a party or a party's officer; or\n\n(ii) is commanded to attend a trial and would not incur substantial expense.\n\n#### *(2) For Other Discovery.* A subpoena may command:\n\n(A) production of documents, or electronically stored information, or things at a place within 100 miles of where the person resides, is employed, or regularly transacts business in person; and\n\n(B) inspection of premises, at the premises to be inspected.\n\n#### **(d) Protecting a Person Subject to a Subpoena; Enforcement.**\n\n*(1) Avoiding Undue Burden or Expense; Sanctions.* A party or attorney responsible for issuing and serving a subpoena must take reasonable steps to avoid imposing undue burden or expense on a person subject to the subpoena. The court for the district where compliance is required must enforce this duty and impose an appropriate sanction which may include lost earnings and reasonable attorney's fees — on a party or attorney who fails to comply.\n\n#### *(2) Command to Produce Materials or Permit Inspection.*\n\n*(A) Appearance Not Required.* A person commanded to produce documents, electronically stored information, or tangible things, or to permit the inspection of premises, need not appear in person at the place of production or inspection unless also commanded to appear for a deposition, hearing, or trial.\n\n*(B) Objections*. A person commanded to produce documents or tangible things or to permit inspection may serve on the party or attorney designated in the subpoena a written objection to inspecting, copying, testing or sampling any or all of the materials or to inspecting the premises — or to producing electronically stored information in the form or forms requested. The objection must be served before the earlier of the time specified for compliance or 14 days after the subpoena is served. If an objection is made, the following rules apply:\n\n(i) At any time, on notice to the commanded person, the serving party may move the court for the district where compliance is required for an order compelling production or inspection.\n\n(ii) These acts may be required only as directed in the order, and the order must protect a person who is neither a party nor a party's officer from significant expense resulting from compliance.\n\n#### *(3) Quashing or Modifying a Subpoena.*\n\n*(A) When Required.* On timely motion, the court for the district where compliance is required must quash or modify a subpoena that:\n\n(i) fails to allow a reasonable time to comply; (ii) requires a person to comply beyond the geographical limits\n\nspecified in Rule 45(c); (iii) requires disclosure of privileged or other protected matter, if no\n\nexception or waiver applies; or\n\n(iv) subjects a person to undue burden.\n\n*(B) When Permitted.* To protect a person subject to or affected by a subpoena, the court for the district where compliance is required may, on motion, quash or modify the subpoena if it requires:\n\n(i) disclosing a trade secret or other confidential research, development, or commercial information; or\n\n(ii) disclosing an unretained expert's opinion or information that does not describe specific occurrences in dispute and results from the expert's study that was not requested by a party.\n\n*(C) Specifying Conditions as an Alternative.* In the circumstances described in Rule 45(d)(3)(B), the court may, instead of quashing or modifying a subpoena, order appearance or production under specified conditions if the serving party:\n\n(i) shows a substantial need for the testimony or material that cannot be otherwise met without undue hardship; and\n\n(ii) ensures that the subpoenaed person will be reasonably compensated.\n\n#### **(e) Duties in Responding to a Subpoena.**\n\n*(1) Producing Documents or Electronically Stored Information.* These procedures apply to producing documents or electronically stored information:\n\n*(A) Documents.* A person responding to a subpoena to produce documents must produce them as they are kept in the ordinary course of business or must organize and label them to correspond to the categories in the demand.\n\n*(B) Form for Producing Electronically Stored Information Not Specified.* If a subpoena does not specify a form for producing electronically stored information, the person responding must produce it in a form or forms in which it is ordinarily maintained or in a reasonably usable form or forms.\n\n*(C) Electronically Stored Information Produced in Only One Form.* The person responding need not produce the same electronically stored information in more than one form.\n\n*(D) Inaccessible Electronically Stored Information.* The person responding need not provide discovery of electronically stored information from sources that the person identifies as not reasonably accessible because of undue burden or cost. On motion to compel discovery or for a protective order, the person responding must show that the information is not reasonably accessible because of undue burden or cost. If that showing is made, the court may nonetheless order discovery from such sources if the requesting party shows good cause, considering the limitations of Rule 26(b)(2)(C). The court may specify conditions for the discovery.\n\n#### *(2) Claiming Privilege or Protection.*\n\n*(A) Information Withheld.* A person withholding subpoenaed information under a claim that it is privileged or subject to protection as trial-preparation material must:\n\n(i) expressly make the claim; and\n\n(ii) describe the nature of the withheld documents, communications, or tangible things in a manner that, without revealing information itself privileged or protected, will enable the parties to assess the claim.\n\n*(B) Information Produced.* If information produced in response to a subpoena is subject to a claim of privilege or of protection as trialpreparation material, the person making the claim may notify any party that received the information of the claim and the basis for it. After being notified, a party must promptly return, sequester, or destroy the specified information and any copies it has; must not use or disclose the information until the claim is resolved; must take reasonable steps to retrieve the information if the party disclosed it before being notified; and may promptly present the information under seal to the court for the district where compliance is required for a determination of the claim. The person who produced the information must preserve the information until the claim is resolved.\n\n**(g) Contempt.** The court for the district where compliance is required – and also, after a motion is transferred, the issuing court – may hold in contempt a person who, having been served, fails without adequate excuse to obey the subpoena or an order related to it.\n\nFor access to subpoena materials, see Fed. R. Civ. P. 45(a) Committee Note (2013)\n\n…\n\n## **Exhibit C-18**\n\n#### B2540 (Form 2540 – Subpoena for Rule 2004 Examination) (12/15) Case 22-50073 Doc 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 359 of 491\n\nUNITED STATES BANKRUPTCY COURT\n\n\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_ District of \\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_ Connecticut\n\nIn re \\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\n\nCase No. \\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_ Ho Wan Kwok 22-50073\n\nDebtor\n\nChapter \\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_ 11\n\n## **SUBPOENA FOR RULE 2004 EXAMINATION**\n\nTo: **\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_** O'Neal Webster\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| Paul Hastings LLP
200 Park Avenue
New York, New York 10166 | |\n\nThe examination will be recorded by this method: \\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_ court reporter/stenographer\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: Sept\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_ ember \\_\\_, 2022\n\nCLERK OF COURT\n\nOR\n\n\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_ *Signature of Clerk or Deputy Clerk* \\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_ *Attorney's signature* Patrick R. Linsey (ct29437)\n\nThe name, address, email address, and telephone number of the attorney representing *(name of party)* \\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_ , who issues or requests this subpoena, are: Luc Despins, Ch. 11 Trustee\n\nPatrick R. Linsey, Esq.; Neubert, Pepe & Monteith, P.C.; 195 Church Street, New Haven, Connecticut 06510 plinsey@npmlaw.com; 203-821-2000\n\n## **Notice to the person who issues or requests this subpoena**\n\nIf this subpoena commands the production of documents, electronically stored information, or tangible things, or the inspection of premises before trial, a notice and a copy of this subpoena must be served on each party before it is served on the person to whom it is directed. Fed. R. Civ. P. 45(a)(4).\n\n## **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 following 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 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 362 of 491\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
- | 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| | | | |\n| FROM | John Smith | Email: Sender
Native: Author(s) of document | |\n| | | | |\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
time
zone
in
which
the
emails
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 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 363 of 491\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 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 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 364 of 491\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 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 365 of 491\n\nsuch Persons, as well as a statement addressing how the information came into their possession, (viii) the claim of privilege under which the Document is withheld, and (ix) all of the circumstances upon which You will rely to support such claim of privilege; and (b) produce a privilege log containing all of the information requested in Part (a) of this Instruction for each Document withheld on the basis of a claim of privilege in accordance with D. Conn. L. Civ. R. 26(e). For any part of a Document Request as to which a claim of privilege or work product is not made, responsive documents should be provided in full.\n\n9. If a portion of an otherwise responsive Document contains information subject to a claim of privilege, only that portion of the Document subject to the claim of privilege shall be deleted or redacted from the Document following the instructions above, and the rest shall be produced.\n\n10. The Requests are continuing in nature. You are hereby instructed to (a) supplement or correct any responses later learned to be incomplete or incorrect immediately upon learning that a prior response was incomplete or incorrect; and (b) produce any additional Documents that are called for under the\n\n11. If a Document is in a language other than English, You should provide that Document. If a Document is in a language other than English, and an English translation exists, You should provide both Documents.\n\n12. All references to Entities includes all affiliates thereof.\n\n13. All references to individual names include all alternative names, aliased, or nicknames.\n\n## Case 22-50073 Doc 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 366 of 491\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 O'Neal Webster, together with any of its employees, agents, counsel, advisors, 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 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 367 of 491\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. \"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: Daniel Podhaskie, Jason Miller, Steve Bannon, Karin Maistrello, Melissa Francis, William Gertz, Arethusa Forsyth, Glenn Mellor, Jennifer Mercurio, Eduardo Eurnekian, Han Chunguang (a/k/a 韩春光), Qu Guojiao (a/k/a Qu Guo Jiao, 屈国姣), Guo Lijie (a/k/a 郭丽杰), Zhang Wei (a/k/a 张伟\\*), Lihong Wei Lafrenz (a/k/a Sara Wei, 魏丽红), Hao Haidong (a/k/a 郝海东), Ross Heinemeyer, Max Krasner, Kyle Bass, Melissa Mendez, Ya Li (a/k/a 李娅), Dinggang Wang (a/k/a 王定刚), An Hong (a/k/a 安红), Yvette Wang (a/k/a Yanping\n\n## Case 22-50073 Doc 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 368 of 491\n\nWang, Yan Ping Wang, 王雁平), Fiona Yu, Je Kin Ming (a/k/a William Je, Yu Jianming, 余建明\n\n), Yaz Qingua, and Lao Jiang (a/k/a Jiang Yunfu, Jiang Yunfu Be, 姜云浮).\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: 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, Assets Sino Limited, Auspicious Coast Limited, Beijing Pangu Investment Co., Beijing Pangu Investment Co. Ltd., Beijing Pangu Investment Inc., Beijing Zenith Holdings Company Limited, Bravo Luck Limited, 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, Elite Well Global Limited, Empire Growth Holdings, G Club Operations LLC, G Fashion LLC, G News LLC, GETTR USA, Genever Holdings Corporation, Genever Holdings LLC, GFASHION MEDIA GROUP INC., GFNY, Inc., Globalist International Limited, GNews Media Group Inc., Golden Spring (New York) Ltd., Greenwich Land LLC, Guo Media, GTV Media Group, Inc., Hamilton Capital Holdings Inc., Head Win Group Limited, Henan Yuda, Himalaya Embassy, Himalaya Exchange, Himalaya Federal Reserve, Himalaya Supervisory Organization, HK International Funds Investments (USA)\n\n## Case 22-50073 Doc 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 369 of 491\n\nLimited LLC, Hong Kong International Funds Investments Limited, Infinite Increase Limited, Infinitum Developments Limited, Insight Phoenix Fund, Lamp Capital LLC, Leading Shine Limited, Leading Shine NY Limited, Long Gate Limited, Next Tycoon Investments Limited, New Federal State of China (a/k/a NFSC), Noble Fame Global Limited, Rosy Acme Ventures Limited, Rule of Law Foundation III, Inc., Rule of Law Foundation IV, Inc., Rule of Law Fund, Rule of Law Society, Rule of Law Society IV, Inc., G-Translators PTY LTD, Saraca Media Group, Inc., Shiny Ace Ltd., Shiny Times Holdings Ltd., Spirit Charter Investment Limited, Stevenson, Wong & Co., Voice of Guo Media, Inc., Well Origin Ltd., World Century Limited, Worldwide Opportunity Holdings Limited, Whitecroft Shore 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\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, correspondence, memoranda, tapes, stenographic or handwritten notes, written forms of any kind,\n\n## Case 22-50073 Doc 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 370 of 491\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\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,\n\n## Case 22-50073 Doc 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 371 of 491\n\nconnected 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, 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\n21. \"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 income or Asset of the Debtor, the Debtor's estate, the Debtor's Family, or Associated Entity.\n\n## Case 22-50073 Doc 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 372 of 491\n\n2. All Documents related to any engagement letter with the Debtor, any member of the Debtor's Family, and/or any Associated Entity, including copy(ies) of such engagement letter(s).\n\n3. All Documents related to the payment of any retainer to You based upon your representation of the Debtor, the Debtor's Family, or an Associated Entity, including documents sufficient to identify the amount of the retainer and its source.\n\n4. All Documents related to any fees, payments, or monies received by You from or on behalf of the Debtor, the Debtor's Family, a Family Related Entity, or an Associated Entity held in escrow or in a client trust account.\n\n5. Documents sufficient to show the amount, date, and source of any payments made to You by or for the benefit of the Debtor, the Debtor's Family, or an Associated Entity.\n\n6. 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\n7. All Documents related to the Associated Entities, including but not limited to Documents related to their corporate structure, Assets, incorporation information, officers and directors, business purpose, and relationship to the Debtor, to any member of the Debtor's Family, or to any Associated Individual.\n\n8. All Documents regarding any investment or business dealing made by, with, or on behalf of Debtor or the Debtor's Family, on the one hand, and an Associated Entity, on the other hand.\n\n## Case 22-50073 Doc 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 373 of 491\n\n9. All Documents related to any Entity that the Debtor, the Debtor's Estate, the Debtor's Family, or the Associated Entities hold any interest or investment in, including but not limited to the nature and value of that interest or investment; any proceeds or benefits from such Entity that the Debtor, the Debtor's Estate, the Debtor's Family, or the Associated Entities receive on account of such interest or investment; and all Documents relating to any financial reporting or data relating to such Entity, including but not limited to all books and records, financial statements or tax Documents.\n\n10. All Documents regarding the *Lady May*; the Sherry Netherland Hotel / Condominium; 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.; and any financial interest that the Debtor or the Debtor's estate possesses in any Associated Entity.\n\n11. All Documents related to the purported Declaration of Trust and Agreement, dated February 17, 2015, entered into by the Debtor, as Trustee, Genever Holdings Corporation, and Genever Holdings LLC, in favor of Bravo Luck Limited, as beneficiary.\n\n12. All Documents related to any aircraft owned, controlled, or used by the Debtor, including without limitation the aircraft bearing tail number T7-GQM 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.\n\n13. All Documents related to any investments or trading by the Debtor, the Debtor's Family, or an Associated Entity, in or around July 2020, or at any other time, in crude oil futures or any similar commodity, including without limitation Communications with Jiang Yunfu Be regarding any such investments or trading.\n\n## Case 22-50073 Doc 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 374 of 491\n\n14. All Communications between You and, either, the Debtor, the Debtor's Family, or any Associated Individual, agent, employee, or other individual acting on behalf of the Debtor, related to any Transfer, investment, or other transaction or business dealing relating to the Debtor, the Debtor's Estate, the Debtor's Family, or the Associated Entities.\n\n15. All Documents concerning any trust or similar instrument set up by, on behalf of, or for the benefit of Debtor, Debtor's Estate, Debtor's Family, or Associated Entities, including but not limited to Documents showing when the trust(s) was created, by whom it was created, to whose benefit it was created, and the corpus of the instrument.\n\n16. All Documents related to any sale, acquisition, disposition, purchase, investment, contribution, gift, extension of credit, loan, or Transfer involving the Debtor, the Debtor's Family, or any Associated Entity.\n\n17. 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\n18. All Documents related to any loans or extensions of credit, or applications for the same, to or from the Debtor, the Debtor's Estate, the Debtor's Family or any Associated Entity, including but not limited to (i) the terms of any such loans or extensions of credit, including their terms of repayment, representations and warranties, and interest rate, and (ii) all evidence of payments of the loans.\n\n## Case 22-50073 Doc 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 375 of 491\n\n19. All Documents related to the Debtor's use of any Assets belonging to, controlled by, or whose complete or partial ownership is held by the Debtor's Family, an Associated Entity, or an Associated Individual.\n\n20. 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\n21. All Documents related to any pledges of Assets of any Associated Entity, including Bravo Luck Limited, to any other Entity.\n\n| Case 22-50073 | Doc 839 | Filed 09/07/22 | Entered 09/07/22 20:02:47 | Page 376 of |\n|-----------------------------------------------------------------|---------|----------------|---------------------------|-------------|\n| B2540 (Form 2540 – Subpoena for Rule 2004 Examination) (Page 2) | | | 491 | |\n| | | | | |\n\n| I received this subpoena for (name of individual and title, if any): ______________________________________________
on (date)
__________
I served the subpoena by delivering a copy to the named person
___________________________________________________________________________________________________
__________________________________
on (date) ___________________ ; or | as follows: ____________________________________ |\n|-----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|----------------------------------------------------------------------------|\n| | |\n| | |\n| | |\n| I returned the subpoena unexecuted because: ____________________________________________________________
___________________________________________________________________________________________________ | |\n| Unless the subpoena was issued on behalf of the United States, or one of its officers or agents, I have also tendered to the
witness the fees for one day's attendance, and the mileage allowed by law, in the amount of \\$ _______________________ . | |\n| My fees are \\$ _________
for travel and \\$_________ | for services, for a total of \\$_________ |\n| I declare under penalty of perjury
that this information is true and correct. | |\n| Date: _______________ | |\n| | ________________________________________________
Server's signature |\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; (ii) requires a person to comply beyond the geographical limits\n\nspecified in Rule 45(c); (iii) requires disclosure of privileged or other protected matter, if no\n\nexception or waiver applies; or\n\n(iv) subjects a person to undue burden.\n\n *(B) When Permitted.* To protect a person subject to or affected by a subpoena, the court for the district where compliance is required may, on motion, quash or modify the subpoena if it requires:\n\n (i) disclosing a trade secret or other confidential research, development, or commercial information; or\n\n (ii) disclosing an unretained expert's opinion or information that does not describe specific occurrences in dispute and results from the expert's study that was not requested by a party.\n\n *(C) Specifying Conditions as an Alternative.* In the circumstances described in Rule 45(d)(3)(B), the court may, instead of quashing or modifying a subpoena, order appearance or production under specified conditions if the serving party:\n\n (i) shows a substantial need for the testimony or material that cannot be otherwise met without undue hardship; and\n\n (ii) ensures that the subpoenaed person will be reasonably compensated.\n\n#### **(e) Duties in Responding to a Subpoena.**\n\n *(1) Producing Documents or Electronically Stored Information.* These procedures apply to producing documents or electronically stored information:\n\n *(A) Documents.* A person responding to a subpoena to produce documents must produce them as they are kept in the ordinary course of business or must organize and label them to correspond to the categories in the demand.\n\n *(B) Form for Producing Electronically Stored Information Not Specified.* If a subpoena does not specify a form for producing electronically stored information, the person responding must produce it in a form or forms in which it is ordinarily maintained or in a reasonably usable form or forms.\n\n *(C) Electronically Stored Information Produced in Only One Form.* The person responding need not produce the same electronically stored information in more than one form.\n\n *(D) Inaccessible Electronically Stored Information.* The person responding need not provide discovery of electronically stored information from sources that the person identifies as not reasonably accessible because of undue burden or cost. On motion to compel discovery or for a protective order, the person responding must show that the information is not reasonably accessible because of undue burden or cost. If that showing is made, the court may nonetheless order discovery from such sources if the requesting party shows good cause, considering the limitations of Rule 26(b)(2)(C). The court may specify conditions for the discovery.\n\n#### *(2) Claiming Privilege or Protection.*\n\n *(A) Information Withheld.* A person withholding subpoenaed information under a claim that it is privileged or subject to protection as trial-preparation material must:\n\n(i) expressly make the claim; and\n\n (ii) describe the nature of the withheld documents, communications, or tangible things in a manner that, without revealing information itself privileged or protected, will enable the parties to assess the claim.\n\n *(B) Information Produced.* If information produced in response to a subpoena is subject to a claim of privilege or of protection as trialpreparation material, the person making the claim may notify any party that received the information of the claim and the basis for it. After being notified, a party must promptly return, sequester, or destroy the specified information and any copies it has; must not use or disclose the information until the claim is resolved; must take reasonable steps to retrieve the information if the party disclosed it before being notified; and may promptly present the information under seal to the court for the district where compliance is required for a determination of the claim. The person who produced the information must preserve the information until the claim is resolved.\n\n**(g) Contempt.** The court for the district where compliance is required – and also, after a motion is transferred, the issuing court – may hold in contempt a person who, having been served, fails without adequate excuse to obey the subpoena or an order related to it.\n\nFor access to subpoena materials, see Fed. R. Civ. P. 45(a) Committee Note (2013)\n\n…\n\n## **Exhibit C-19**\n\n### B2540 (Form 2540 – Subpoena for Rule 2004 Examination) (12/15) UNITED STATES BANKRUPTCY COURT Case 22-50073 Doc 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 379 of 491\n\n\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_ District of \\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_ Connecticut\n\nIn re \\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\n\nCase No. \\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_ Ho Wan Kwok 22-50073\n\nDebtor\n\nChapter \\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_ 11\n\n## **SUBPOENA FOR RULE 2004 EXAMINATION**\n\nTo: **\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_** Barclays 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. X\n\n| PLACE
NEUBERT, PEPE & MONTEITH, P.C. | DATE AND TIME |\n|-----------------------------------------|---------------|\n| 195 Church Street, 13th Floor | |\n| New Haven, Connecticut 06510 | |\n\nThe examination will be recorded by this method: \\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_ court reporter/stenographer\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: X\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: \\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_ September \\_\\_, 2022\n\nCLERK OF COURT\n\nOR\n\n\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_ *Signature of Clerk or Deputy Clerk* \\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_ *Attorney's signature* Patrick R. Linsey (ct29437)\n\nThe name, address, email address, and telephone number of the attorney representing *(name of party)* \\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_ , who issues or requests this subpoena, are: Luc Despins, Ch. 11 Trustee\n\nPatrick R. Linsey, Esq.; Neubert, Pepe & Monteith, P.C.; 195 Church Street, 13th Floor, New Haven, Connecticut 06510 plinsey@npmlaw.com; (203) 821-2000\n\n## **Notice to the person who issues or requests this subpoena**\n\nIf this subpoena commands the production of documents, electronically stored information, or tangible things, or the inspection of premises before trial, a notice and a copy of this subpoena must be served on each party before it is served on the person to whom it is directed. Fed. R. Civ. P. 45(a)(4).\n\n## **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 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 382 of 491\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
- | 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
time zone in which
the emails
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 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 383 of 491\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| | | |\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
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 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 384 of 491\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 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 385 of 491\n\nsuch Persons, as well as a statement addressing how the information came into their possession, (viii) the claim of privilege under which the Document is withheld, and (ix) all of the circumstances upon which You will rely to support such claim of privilege; and (b) produce a privilege log containing all of the information requested in Part (a) of this Instruction for each Document withheld on the basis of a claim of privilege in accordance with D. Conn. L. Civ. R. 26(e). For any part of a Document Request as to which a claim of privilege or work product is not made, responsive documents should be provided in full.\n\n9. If a portion of an otherwise responsive Document contains information subject to a claim of privilege, only that portion of the Document subject to the claim of privilege shall be deleted or redacted from the Document following the instructions above, and the rest shall be produced.\n\n10. The Requests are continuing in nature. You are hereby instructed to (a) supplement or correct any responses later learned to be incomplete or incorrect immediately upon learning that a prior response was incomplete or incorrect; and (b) produce any additional Documents that are called for under the\n\n11. If a Document is in a language other than English, You should provide that Document. If a Document is in a language other than English, and an English translation exists, You should provide both Documents.\n\n12. All references to Entities includes all affiliates thereof.\n\n13. All references to individual names include all alternative names, aliased, or nicknames.\n\n## Case 22-50073 Doc 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 386 of 491\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 Barclays Bank PLC, together with any of its affiliates, parents, and subsidiaries, and any of their employees, agents, counsel, advisors, 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\n## Case 22-50073 Doc 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 387 of 491\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, ACA Capital Group Limited, Himalaya International Financial Group Ltd., Himalaya International Clearing Ltd., Himalaya International Payments Ltd., Himalaya International Reserves Ltd., Jesse Brown, William Je, William Je, Eastern Profit Corporation Limited, HK International Funds Investments (USA) Limited LLC, Bravo Luck Limited, Golden Spring (New York) Ltd., Lamp Capital LLC, Greenwich Land LLC, Qu Guo Jiao, Daniel Thomas Podhaskie, Yvette Wang, Ace Decade Holdings Limited, Dawn State Limited, Rule of Law Society IV Inc., Rule of Law Foundation III, GTV Media Group, Inc., Voice of Guo Media, Inc., and Saraca Media Group Inc.\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,\n\n## Case 22-50073 Doc 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 388 of 491\n\nadvisors, or anyone acting on behalf of any of the foregoing. Such Associated Individuals shall include, but are not limited to: Daniel Podhaskie, Jason Miller, Jesse Brown, William Je, Steve Bannon, Karin Maistrello, Melissa Francis, William Gertz, Arethusa Forsyth, Glenn Mellor, Jennifer Mercurio, Eduardo Eurnekian, Han Chunguang (a/k/a 韩春光), Qu Guojiao (a/k/a Qu Guo Jiao, 屈国姣), Guo Lijie (a/k/a 郭丽杰), Zhang Wei (a/k/a 张伟\\*), Lihong Wei Lafrenz (a/k/a Sara Wei, 魏丽红), Hao Haidong (a/k/a 郝海东), Ross Heinemeyer, Max Krasner, Kyle Bass, Melissa Mendez, Ya Li (a/k/a 李娅), Dinggang Wang (a/k/a 王定刚), An Hong (a/k/a 安红), Yvette Wang (a/k/a Yanping Wang, Yan Ping Wang, 王雁平), Fiona Yu, Je Kin Ming (a/k/a William Je, Yu Jianming, 余建明), Yaz Qingua, and Lao Jiang (a/k/a Jiang Yunfu, Jiang Yunfu Be, 姜云浮).\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: 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, Assets Sino Limited, Auspicious Coast Limited, Beijing Pangu Investment Co., Beijing Pangu Investment Co. Ltd., Beijing Pangu Investment Inc., Beijing Zenith Holdings Company Limited, Bravo Luck Limited, 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,\n\n## Case 22-50073 Doc 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 389 of 491\n\nDawn State Limited, Eastern Profit Corporation Limited, Elite Well Global Limited, Empire Growth Holdings, G Club Operations LLC, G Fashion LLC, G News LLC, GETTR USA, Genever Holdings Corporation, Genever Holdings LLC, GFASHION MEDIA GROUP INC., GFNY, Inc., Globalist International Limited, GNews Media Group Inc., Golden Spring (New York) Ltd., Greenwich Land LLC, Guo Media, GTV Media Group, Inc., Hamilton Capital Holdings Inc., Head Win Group Limited, Henan Yuda, Himalaya Embassy, Himalaya Exchange, Himalaya Federal Reserve, Himalaya International Financial Group Ltd., Himalaya International Clearing Ltd. , Himalaya International Payments Ltd., Himalaya International Reserves Ltd., Himalaya Supervisory Organization, HK International Funds Investments (USA) Limited LLC, Hong Kong International Funds Investments Limited, Hudson Diamond NY LLC, Infinite Increase Limited, Infinitum Developments Limited, Insight Phoenix Fund, Lamp Capital LLC, Leading Shine Limited, Leading Shine NY Limited, Long Gate Limited, Next Tycoon Investments Limited, New Federal State of China (a/k/a NFSC), Noble Fame Global Limited, Rosy Acme Ventures Limited, Rule of Law Foundation III, Inc., Rule of Law Foundation IV, Inc., Rule of Law Fund, Rule of Law Society, Rule of Law Society IV, Inc., G-Translators PTY LTD, Saraca Media Group, Inc., Shiny Ace Ltd., Shiny Times Holdings Ltd., Spirit Charter Investment Limited, Stevenson, Wong & Co., TM Primrose Limited, Voice of Guo Media, Inc., Well Origin Ltd., World Century Limited, Worldwide Opportunity Holdings Limited, Whitecroft Shore Limited, and ZIBA Limited.\n\n10. \"Including\" or any variant thereof means \"including without limitation.\"\n\n11. \"And\" and \"or\" mean \"and/or,\" and shall be construed both conjunctively as well as disjunctively in order to maximize their scope.\n\n12. \"Any\" and \"all\" and \"each\" mean \"each and every.\"\n\n13. \"Each\" and \"every\" mean \"each and every.\"\n\n## Case 22-50073 Doc 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 390 of 491\n\n14. \"Third Party\" means a Person or Entity other than Yourself.\n\n15. \"Transfer\" shall have the meaning given to it by section 101(54) of the Bankruptcy Code.\n\n16. \"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\n17. \"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\n## Case 22-50073 Doc 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 391 of 491\n\n18. \"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\n19. \"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\n20. \"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\n21. \"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\n## Case 22-50073 Doc 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 392 of 491\n\n22. \"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 dated between January 1, 2014 and the present 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 dated between January 1, 2014 and the present 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 dated between January 1, 2014 and the present related to any business, commerce or financial transactions, including but not limited to any loan, line of credit, bailment, deposit, swap, securities transactions, mortgage, or ISDA, with any of the 2004 Discovery Targets, including any and all account statements, authorizations, powers of attorney, trusts, instructions or forms, copies of cancelled checks, correspondence, and wire transfers and related correspondence and instructions.\n\n## Case 22-50073 Doc 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 393 of 491\n\n4. All Documents dated between January 1, 2014 and the present 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 dated between January 1, 2014 and the present related to any correspondence and communications between you and the 2004 Discovery Targets.\n\n6. All Documents dated between January 1, 2014 and the present 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 dated between January 1, 2014 and the present related to any antimoney 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 dated between January 1, 2014 and the present 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-20**\n\n### B2540 (Form 2540 – Subpoena for Rule 2004 Examination) (12/15) UNITED STATES BANKRUPTCY COURT Case 22-50073 Doc 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 395 of 491\n\n\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_ District of \\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_ Connecticut\n\nIn re \\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\n\nCase No. \\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_ Ho Wan Kwok 22-50073\n\nDebtor\n\nChapter \\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_ 11\n\n## **SUBPOENA FOR RULE 2004 EXAMINATION**\n\nTo: **\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_** BNY Mellon, N.A.\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. X\n\n| PLACE
NEUBERT, PEPE & MONTEITH, P.C. | DATE AND TIME |\n|-----------------------------------------|---------------|\n| 195 Church Street, 13th Floor | |\n| New Haven, Connecticut 06510 | |\n| | |\n\nThe examination will be recorded by this method: \\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_ court reporter/stenographer\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: X\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: \\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_ September \\_\\_, 2022\n\nCLERK OF COURT\n\nOR\n\n\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_ *Signature of Clerk or Deputy Clerk* \\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_ *Attorney's signature* Patrick R. Linsey (ct29437)\n\nThe name, address, email address, and telephone number of the attorney representing *(name of party)* \\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_ , who issues or requests this subpoena, are: Luc Despins, Ch. 11 Trustee\n\nPatrick R. Linsey, Esq.; Neubert, Pepe & Monteith, P.C.; 195 Church Street, 13th Floor, New Haven, Connecticut 06510 plinsey@npmlaw.com; (203) 821-2000\n\n## **Notice to the person who issues or requests this subpoena**\n\nIf this subpoena commands the production of documents, electronically stored information, or tangible things, or the inspection of premises before trial, a notice and a copy of this subpoena must be served on each party before it is served on the person to whom it is directed. Fed. R. Civ. P. 45(a)(4).\n\n## **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 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 398 of 491\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
**The LASTBATES field should be populated |\n| | | for single page |\n| ATTACHRANGE | EDC0000001
- | 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
time zone in which
the emails
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 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 399 of 491\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
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 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 400 of 491\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 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 401 of 491\n\nsuch Persons, as well as a statement addressing how the information came into their possession, (viii) the claim of privilege under which the Document is withheld, and (ix) all of the circumstances upon which You will rely to support such claim of privilege; and (b) produce a privilege log containing all of the information requested in Part (a) of this Instruction for each Document withheld on the basis of a claim of privilege in accordance with D. Conn. L. Civ. R. 26(e). For any part of a Document Request as to which a claim of privilege or work product is not made, responsive documents should be provided in full.\n\n9. If a portion of an otherwise responsive Document contains information subject to a claim of privilege, only that portion of the Document subject to the claim of privilege shall be deleted or redacted from the Document following the instructions above, and the rest shall be produced.\n\n10. The Requests are continuing in nature. You are hereby instructed to (a) supplement or correct any responses later learned to be incomplete or incorrect immediately upon learning that a prior response was incomplete or incorrect; and (b) produce any additional Documents that are called for under the\n\n11. If a Document is in a language other than English, You should provide that Document. If a Document is in a language other than English, and an English translation exists, You should provide both Documents.\n\n12. All references to Entities includes all affiliates thereof.\n\n13. All references to individual names include all alternative names, aliased, or nicknames.\n\n## Case 22-50073 Doc 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 402 of 491\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 BNY Mellon, N.A., together with any of its affiliates, parents, and subsidiaries, and any of their employees, agents, counsel, advisors, 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\n## Case 22-50073 Doc 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 403 of 491\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, ACA Capital Group Limited, Himalaya International Financial Group Ltd., Himalaya International Clearing Ltd., Himalaya International Payments Ltd., Himalaya International Reserves Ltd., Jesse Brown, William Je, William Je, Eastern Profit Corporation Limited, HK International Funds Investments (USA) Limited LLC, Bravo Luck Limited, Golden Spring (New York) Ltd., Lamp Capital LLC, Greenwich Land LLC, Qu Guo Jiao, Daniel Thomas Podhaskie, Yvette Wang, Ace Decade Holdings Limited, Dawn State Limited, Rule of Law Society IV Inc., Rule of Law Foundation III, GTV Media Group, Inc., Voice of Guo Media, Inc., and Saraca Media Group Inc.\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,\n\n## Case 22-50073 Doc 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 404 of 491\n\nadvisors, or anyone acting on behalf of any of the foregoing. Such Associated Individuals shall include, but are not limited to: Daniel Podhaskie, Jason Miller, Jesse Brown, William Je, Steve Bannon, Karin Maistrello, Melissa Francis, William Gertz, Arethusa Forsyth, Glenn Mellor, Jennifer Mercurio, Eduardo Eurnekian, Han Chunguang (a/k/a 韩春光), Qu Guojiao (a/k/a Qu Guo Jiao, 屈国姣), Guo Lijie (a/k/a 郭丽杰), Zhang Wei (a/k/a 张伟\\*), Lihong Wei Lafrenz (a/k/a Sara Wei, 魏丽红), Hao Haidong (a/k/a 郝海东), Ross Heinemeyer, Max Krasner, Kyle Bass, Melissa Mendez, Ya Li (a/k/a 李娅), Dinggang Wang (a/k/a 王定刚), An Hong (a/k/a 安红), Yvette Wang (a/k/a Yanping Wang, Yan Ping Wang, 王雁平), Fiona Yu, Je Kin Ming (a/k/a William Je, Yu Jianming, 余建明), Yaz Qingua, and Lao Jiang (a/k/a Jiang Yunfu, Jiang Yunfu Be, 姜云浮).\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: 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, Assets Sino Limited, Auspicious Coast Limited, Beijing Pangu Investment Co., Beijing Pangu Investment Co. Ltd., Beijing Pangu Investment Inc., Beijing Zenith Holdings Company Limited, Bravo Luck Limited, 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,\n\n## Case 22-50073 Doc 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 405 of 491\n\nDawn State Limited, Eastern Profit Corporation Limited, Elite Well Global Limited, Empire Growth Holdings, G Club Operations LLC, G Fashion LLC, G News LLC, GETTR USA, Genever Holdings Corporation, Genever Holdings LLC, GFASHION MEDIA GROUP INC., GFNY, Inc., Globalist International Limited, GNews Media Group Inc., Golden Spring (New York) Ltd., Greenwich Land LLC, Guo Media, GTV Media Group, Inc., Hamilton Capital Holdings Inc., Head Win Group Limited, Henan Yuda, Himalaya Embassy, Himalaya Exchange, Himalaya Federal Reserve, Himalaya International Financial Group Ltd., Himalaya International Clearing Ltd. , Himalaya International Payments Ltd., Himalaya International Reserves Ltd., Himalaya Supervisory Organization, HK International Funds Investments (USA) Limited LLC, Hong Kong International Funds Investments Limited, Hudson Diamond NY LLC, Infinite Increase Limited, Infinitum Developments Limited, Insight Phoenix Fund, Lamp Capital LLC, Leading Shine Limited, Leading Shine NY Limited, Long Gate Limited, Next Tycoon Investments Limited, New Federal State of China (a/k/a NFSC), Noble Fame Global Limited, Rosy Acme Ventures Limited, Rule of Law Foundation III, Inc., Rule of Law Foundation IV, Inc., Rule of Law Fund, Rule of Law Society, Rule of Law Society IV, Inc., G-Translators PTY LTD, Saraca Media Group, Inc., Shiny Ace Ltd., Shiny Times Holdings Ltd., Spirit Charter Investment Limited, Stevenson, Wong & Co., TM Primrose Limited, Voice of Guo Media, Inc., Well Origin Ltd., World Century Limited, Worldwide Opportunity Holdings Limited, Whitecroft Shore Limited, and ZIBA Limited.\n\n10. \"Including\" or any variant thereof means \"including without limitation.\"\n\n11. \"And\" and \"or\" mean \"and/or,\" and shall be construed both conjunctively as well as disjunctively in order to maximize their scope.\n\n12. \"Any\" and \"all\" and \"each\" mean \"each and every.\"\n\n13. \"Each\" and \"every\" mean \"each and every.\"\n\n## Case 22-50073 Doc 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 406 of 491\n\n14. \"Third Party\" means a Person or Entity other than Yourself.\n\n15. \"Transfer\" shall have the meaning given to it by section 101(54) of the Bankruptcy Code.\n\n16. \"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\n17. \"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\n## Case 22-50073 Doc 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 407 of 491\n\n18. \"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\n19. \"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\n20. \"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\n21. \"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\n## Case 22-50073 Doc 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 408 of 491\n\n22. \"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 dated between January 1, 2014 and the present 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 dated between January 1, 2014 and the present 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 dated between January 1, 2014 and the present related to any business, commerce or financial transactions, including but not limited to any loan, line of credit, bailment, deposit, swap, securities transactions, mortgage, or ISDA, with any of the 2004 Discovery Targets, including any and all account statements, authorizations, powers of attorney, trusts, instructions or forms, copies of cancelled checks, correspondence, and wire transfers and related correspondence and instructions.\n\n## Case 22-50073 Doc 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 409 of 491\n\n4. All Documents dated between January 1, 2014 and the present 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 dated between January 1, 2014 and the present related to any correspondence and communications between you and the 2004 Discovery Targets.\n\n6. All Documents dated between January 1, 2014 and the present 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 dated between January 1, 2014 and the present related to any antimoney 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 dated between January 1, 2014 and the present 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-21**\n\n### B2540 (Form 2540 – Subpoena for Rule 2004 Examination) (12/15) UNITED STATES BANKRUPTCY COURT Case 22-50073 Doc 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 411 of 491\n\n\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_ District of \\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_ Connecticut\n\nIn re \\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\n\nCase No. \\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_ Ho Wan Kwok 22-50073\n\nDebtor\n\nChapter \\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_ 11\n\n## **SUBPOENA FOR RULE 2004 EXAMINATION**\n\nTo: **\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_** Citibank, N.A.\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. X\n\n| PLACE | DATE AND TIME |\n|-----------------------------------------------------------------|---------------|\n| NEUBERT, PEPE & MONTEITH, P.C.
195 Church Street, 13th Floor | |\n| New Haven, Connecticut 06510 | |\n\nThe examination will be recorded by this method: \\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_ court reporter/stenographer\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: X\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: \\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_ September \\_\\_, 2022\n\nCLERK OF COURT\n\nOR\n\n\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_ *Signature of Clerk or Deputy Clerk* \\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_ *Attorney's signature* Patrick R. Linsey (ct29437)\n\nThe name, address, email address, and telephone number of the attorney representing *(name of party)* \\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_ , who issues or requests this subpoena, are: Luc Despins, Ch. 11 Trustee\n\nPatrick R. Linsey, Esq.; Neubert, Pepe & Monteith, P.C.; 195 Church Street, 13th Floor, New Haven, Connecticut 06510 plinsey@npmlaw.com; (203) 821-2000\n\n## **Notice to the person who issues or requests this subpoena**\n\nIf this subpoena commands the production of documents, electronically stored information, or tangible things, or the inspection of premises before trial, a notice and a copy of this subpoena must be served on each party before it is served on the person to whom it is directed. Fed. R. Civ. P. 45(a)(4).\n\n## **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 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 414 of 491\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
- | 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
time zone in which
the emails
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 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 415 of 491\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| | | |\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
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 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 416 of 491\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 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 417 of 491\n\nsuch Persons, as well as a statement addressing how the information came into their possession, (viii) the claim of privilege under which the Document is withheld, and (ix) all of the circumstances upon which You will rely to support such claim of privilege; and (b) produce a privilege log containing all of the information requested in Part (a) of this Instruction for each Document withheld on the basis of a claim of privilege in accordance with D. Conn. L. Civ. R. 26(e). For any part of a Document Request as to which a claim of privilege or work product is not made, responsive documents should be provided in full.\n\n9. If a portion of an otherwise responsive Document contains information subject to a claim of privilege, only that portion of the Document subject to the claim of privilege shall be deleted or redacted from the Document following the instructions above, and the rest shall be produced.\n\n10. The Requests are continuing in nature. You are hereby instructed to (a) supplement or correct any responses later learned to be incomplete or incorrect immediately upon learning that a prior response was incomplete or incorrect; and (b) produce any additional Documents that are called for under the\n\n11. If a Document is in a language other than English, You should provide that Document. If a Document is in a language other than English, and an English translation exists, You should provide both Documents.\n\n12. All references to Entities includes all affiliates thereof.\n\n13. All references to individual names include all alternative names, aliased, or nicknames.\n\n## Case 22-50073 Doc 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 418 of 491\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 Citibank, N.A., together with any of its affiliates, parents, and subsidiaries, and any of their employees, agents, counsel, advisors, 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\n## Case 22-50073 Doc 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 419 of 491\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, ACA Capital Group Limited, Himalaya International Financial Group Ltd., Himalaya International Clearing Ltd., Himalaya International Payments Ltd., Himalaya International Reserves Ltd., Jesse Brown, William Je, William Je, Eastern Profit Corporation Limited, HK International Funds Investments (USA) Limited LLC, Bravo Luck Limited, Golden Spring (New York) Ltd., Lamp Capital LLC, Greenwich Land LLC, Qu Guo Jiao, Daniel Thomas Podhaskie, Yvette Wang, Ace Decade Holdings Limited, Dawn State Limited, Rule of Law Society IV Inc., Rule of Law Foundation III, GTV Media Group, Inc., Voice of Guo Media, Inc., and Saraca Media Group Inc.\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,\n\n## Case 22-50073 Doc 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 420 of 491\n\nadvisors, or anyone acting on behalf of any of the foregoing. Such Associated Individuals shall include, but are not limited to: Daniel Podhaskie, Jason Miller, Jesse Brown, William Je, Steve Bannon, Karin Maistrello, Melissa Francis, William Gertz, Arethusa Forsyth, Glenn Mellor, Jennifer Mercurio, Eduardo Eurnekian, Han Chunguang (a/k/a 韩春光), Qu Guojiao (a/k/a Qu Guo Jiao, 屈国姣), Guo Lijie (a/k/a 郭丽杰), Zhang Wei (a/k/a 张伟\\*), Lihong Wei Lafrenz (a/k/a Sara Wei, 魏丽红), Hao Haidong (a/k/a 郝海东), Ross Heinemeyer, Max Krasner, Kyle Bass, Melissa Mendez, Ya Li (a/k/a 李娅), Dinggang Wang (a/k/a 王定刚), An Hong (a/k/a 安红), Yvette Wang (a/k/a Yanping Wang, Yan Ping Wang, 王雁平), Fiona Yu, Je Kin Ming (a/k/a William Je, Yu Jianming, 余建明), Yaz Qingua, and Lao Jiang (a/k/a Jiang Yunfu, Jiang Yunfu Be, 姜云浮).\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: 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, Assets Sino Limited, Auspicious Coast Limited, Beijing Pangu Investment Co., Beijing Pangu Investment Co. Ltd., Beijing Pangu Investment Inc., Beijing Zenith Holdings Company Limited, Bravo Luck Limited, 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,\n\n## Case 22-50073 Doc 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 421 of 491\n\nDawn State Limited, Eastern Profit Corporation Limited, Elite Well Global Limited, Empire Growth Holdings, G Club Operations LLC, G Fashion LLC, G News LLC, GETTR USA, Genever Holdings Corporation, Genever Holdings LLC, GFASHION MEDIA GROUP INC., GFNY, Inc., Globalist International Limited, GNews Media Group Inc., Golden Spring (New York) Ltd., Greenwich Land LLC, Guo Media, GTV Media Group, Inc., Hamilton Capital Holdings Inc., Head Win Group Limited, Henan Yuda, Himalaya Embassy, Himalaya Exchange, Himalaya Federal Reserve, Himalaya International Financial Group Ltd., Himalaya International Clearing Ltd. , Himalaya International Payments Ltd., Himalaya International Reserves Ltd., Himalaya Supervisory Organization, HK International Funds Investments (USA) Limited LLC, Hong Kong International Funds Investments Limited, Hudson Diamond NY LLC, Infinite Increase Limited, Infinitum Developments Limited, Insight Phoenix Fund, Lamp Capital LLC, Leading Shine Limited, Leading Shine NY Limited, Long Gate Limited, Next Tycoon Investments Limited, New Federal State of China (a/k/a NFSC), Noble Fame Global Limited, Rosy Acme Ventures Limited, Rule of Law Foundation III, Inc., Rule of Law Foundation IV, Inc., Rule of Law Fund, Rule of Law Society, Rule of Law Society IV, Inc., G-Translators PTY LTD, Saraca Media Group, Inc., Shiny Ace Ltd., Shiny Times Holdings Ltd., Spirit Charter Investment Limited, Stevenson, Wong & Co., TM Primrose Limited, Voice of Guo Media, Inc., Well Origin Ltd., World Century Limited, Worldwide Opportunity Holdings Limited, Whitecroft Shore Limited, and ZIBA Limited.\n\n10. \"Including\" or any variant thereof means \"including without limitation.\"\n\n11. \"And\" and \"or\" mean \"and/or,\" and shall be construed both conjunctively as well as disjunctively in order to maximize their scope.\n\n12. \"Any\" and \"all\" and \"each\" mean \"each and every.\"\n\n13. \"Each\" and \"every\" mean \"each and every.\"\n\n## Case 22-50073 Doc 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 422 of 491\n\n14. \"Third Party\" means a Person or Entity other than Yourself.\n\n15. \"Transfer\" shall have the meaning given to it by section 101(54) of the Bankruptcy Code.\n\n16. \"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\n17. \"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\n## Case 22-50073 Doc 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 423 of 491\n\n18. \"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\n19. \"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\n20. \"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\n21. \"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\n## Case 22-50073 Doc 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 424 of 491\n\n22. \"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 dated between January 1, 2014 and the present 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 dated between January 1, 2014 and the present 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 dated between January 1, 2014 and the present related to any business, commerce or financial transactions, including but not limited to any loan, line of credit, bailment, deposit, swap, securities transactions, mortgage, or ISDA, with any of the 2004 Discovery Targets, including any and all account statements, authorizations, powers of attorney, trusts, instructions or forms, copies of cancelled checks, correspondence, and wire transfers and related correspondence and instructions.\n\n## Case 22-50073 Doc 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 425 of 491\n\n4. All Documents dated between January 1, 2014 and the present 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 dated between January 1, 2014 and the present related to any correspondence and communications between you and the 2004 Discovery Targets.\n\n6. All Documents dated between January 1, 2014 and the present 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 dated between January 1, 2014 and the present related to any antimoney 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 dated between January 1, 2014 and the present 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-22**\n\n### B2540 (Form 2540 – Subpoena for Rule 2004 Examination) (12/15) UNITED STATES BANKRUPTCY COURT Case 22-50073 Doc 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 427 of 491\n\n\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_ District of \\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_ Connecticut\n\nIn re \\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\n\nCase No. \\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_ Ho Wan Kwok 22-50073\n\nDebtor\n\nChapter \\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_ 11\n\n## **SUBPOENA FOR RULE 2004 EXAMINATION**\n\nTo: **\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_** HSBC Holdings, 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. X\n\n| PLACE
NEUBERT, PEPE & MONTEITH, P.C. | DATE AND TIME |\n|-----------------------------------------|---------------|\n| 195 Church Street, 13th Floor | |\n| New Haven, Connecticut 06510 | |\n\nThe examination will be recorded by this method: \\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_ court reporter/stenographer\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: X\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: \\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_ September \\_\\_, 2022\n\nCLERK OF COURT\n\nOR\n\n\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_ *Signature of Clerk or Deputy Clerk* \\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_ *Attorney's signature* Patrick R. Linsey (ct29437)\n\nThe name, address, email address, and telephone number of the attorney representing *(name of party)* \\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_ , who issues or requests this subpoena, are: Luc Despins, Ch. 11 Trustee\n\nPatrick R. Linsey, Esq.; Neubert, Pepe & Monteith, P.C.; 195 Church Street, 13th Floor, New Haven, Connecticut 06510 plinsey@npmlaw.com; (203) 821-2000\n\n## **Notice to the person who issues or requests this subpoena**\n\nIf this subpoena commands the production of documents, electronically stored information, or tangible things, or the inspection of premises before trial, a notice and a copy of this subpoena must be served on each party before it is served on the person to whom it is directed. Fed. R. Civ. P. 45(a)(4).\n\n## **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 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 430 of 491\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
- | 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
time zone in which
the emails
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 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 431 of 491\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
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 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 432 of 491\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 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 433 of 491\n\nsuch Persons, as well as a statement addressing how the information came into their possession, (viii) the claim of privilege under which the Document is withheld, and (ix) all of the circumstances upon which You will rely to support such claim of privilege; and (b) produce a privilege log containing all of the information requested in Part (a) of this Instruction for each Document withheld on the basis of a claim of privilege in accordance with D. Conn. L. Civ. R. 26(e). For any part of a Document Request as to which a claim of privilege or work product is not made, responsive documents should be provided in full.\n\n9. If a portion of an otherwise responsive Document contains information subject to a claim of privilege, only that portion of the Document subject to the claim of privilege shall be deleted or redacted from the Document following the instructions above, and the rest shall be produced.\n\n10. The Requests are continuing in nature. You are hereby instructed to (a) supplement or correct any responses later learned to be incomplete or incorrect immediately upon learning that a prior response was incomplete or incorrect; and (b) produce any additional Documents that are called for under the\n\n11. If a Document is in a language other than English, You should provide that Document. If a Document is in a language other than English, and an English translation exists, You should provide both Documents.\n\n12. All references to Entities includes all affiliates thereof.\n\n13. All references to individual names include all alternative names, aliased, or nicknames.\n\n## Case 22-50073 Doc 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 434 of 491\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 HSBC Holdings PLC, together with any of its affiliates, parents, and subsidiaries, and any of their employees, agents, counsel, advisors, 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\n## Case 22-50073 Doc 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 435 of 491\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, ACA Capital Group Limited, Himalaya International Financial Group Ltd., Himalaya International Clearing Ltd., Himalaya International Payments Ltd., Himalaya International Reserves Ltd., Jesse Brown, William Je, William Je, Eastern Profit Corporation Limited, HK International Funds Investments (USA) Limited LLC, Bravo Luck Limited, Golden Spring (New York) Ltd., Lamp Capital LLC, Greenwich Land LLC, Qu Guo Jiao, Daniel Thomas Podhaskie, Yvette Wang, Ace Decade Holdings Limited, Dawn State Limited, Rule of Law Society IV Inc., Rule of Law Foundation III, GTV Media Group, Inc., Voice of Guo Media, Inc., and Saraca Media Group Inc.\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,\n\n## Case 22-50073 Doc 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 436 of 491\n\nadvisors, or anyone acting on behalf of any of the foregoing. Such Associated Individuals shall include, but are not limited to: Daniel Podhaskie, Jason Miller, Jesse Brown, William Je, Steve Bannon, Karin Maistrello, Melissa Francis, William Gertz, Arethusa Forsyth, Glenn Mellor, Jennifer Mercurio, Eduardo Eurnekian, Han Chunguang (a/k/a 韩春光), Qu Guojiao (a/k/a Qu Guo Jiao, 屈国姣), Guo Lijie (a/k/a 郭丽杰), Zhang Wei (a/k/a 张伟\\*), Lihong Wei Lafrenz (a/k/a Sara Wei, 魏丽红), Hao Haidong (a/k/a 郝海东), Ross Heinemeyer, Max Krasner, Kyle Bass, Melissa Mendez, Ya Li (a/k/a 李娅), Dinggang Wang (a/k/a 王定刚), An Hong (a/k/a 安红), Yvette Wang (a/k/a Yanping Wang, Yan Ping Wang, 王雁平), Fiona Yu, Je Kin Ming (a/k/a William Je, Yu Jianming, 余建明), Yaz Qingua, and Lao Jiang (a/k/a Jiang Yunfu, Jiang Yunfu Be, 姜云浮).\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: 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, Assets Sino Limited, Auspicious Coast Limited, Beijing Pangu Investment Co., Beijing Pangu Investment Co. Ltd., Beijing Pangu Investment Inc., Beijing Zenith Holdings Company Limited, Bravo Luck Limited, 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,\n\n## Case 22-50073 Doc 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 437 of 491\n\nDawn State Limited, Eastern Profit Corporation Limited, Elite Well Global Limited, Empire Growth Holdings, G Club Operations LLC, G Fashion LLC, G News LLC, GETTR USA, Genever Holdings Corporation, Genever Holdings LLC, GFASHION MEDIA GROUP INC., GFNY, Inc., Globalist International Limited, GNews Media Group Inc., Golden Spring (New York) Ltd., Greenwich Land LLC, Guo Media, GTV Media Group, Inc., Hamilton Capital Holdings Inc., Head Win Group Limited, Henan Yuda, Himalaya Embassy, Himalaya Exchange, Himalaya Federal Reserve, Himalaya International Financial Group Ltd., Himalaya International Clearing Ltd. , Himalaya International Payments Ltd., Himalaya International Reserves Ltd., Himalaya Supervisory Organization, HK International Funds Investments (USA) Limited LLC, Hong Kong International Funds Investments Limited, Hudson Diamond NY LLC, Infinite Increase Limited, Infinitum Developments Limited, Insight Phoenix Fund, Lamp Capital LLC, Leading Shine Limited, Leading Shine NY Limited, Long Gate Limited, Next Tycoon Investments Limited, New Federal State of China (a/k/a NFSC), Noble Fame Global Limited, Rosy Acme Ventures Limited, Rule of Law Foundation III, Inc., Rule of Law Foundation IV, Inc., Rule of Law Fund, Rule of Law Society, Rule of Law Society IV, Inc., G-Translators PTY LTD, Saraca Media Group, Inc., Shiny Ace Ltd., Shiny Times Holdings Ltd., Spirit Charter Investment Limited, Stevenson, Wong & Co., TM Primrose Limited, Voice of Guo Media, Inc., Well Origin Ltd., World Century Limited, Worldwide Opportunity Holdings Limited, Whitecroft Shore Limited, and ZIBA Limited.\n\n10. \"Including\" or any variant thereof means \"including without limitation.\"\n\n11. \"And\" and \"or\" mean \"and/or,\" and shall be construed both conjunctively as well as disjunctively in order to maximize their scope.\n\n12. \"Any\" and \"all\" and \"each\" mean \"each and every.\"\n\n13. \"Each\" and \"every\" mean \"each and every.\"\n\n## Case 22-50073 Doc 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 438 of 491\n\n14. \"Third Party\" means a Person or Entity other than Yourself.\n\n15. \"Transfer\" shall have the meaning given to it by section 101(54) of the Bankruptcy Code.\n\n16. \"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\n17. \"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\n## Case 22-50073 Doc 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 439 of 491\n\n18. \"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\n19. \"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\n20. \"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\n21. \"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\n## Case 22-50073 Doc 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 440 of 491\n\n22. \"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 dated between January 1, 2014 and the present 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 dated between January 1, 2014 and the present 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 dated between January 1, 2014 and the present related to any business, commerce or financial transactions, including but not limited to any loan, line of credit, bailment, deposit, swap, securities transactions, mortgage, or ISDA, with any of the 2004 Discovery Targets, including any and all account statements, authorizations, powers of attorney, trusts, instructions or forms, copies of cancelled checks, correspondence, and wire transfers and related correspondence and instructions.\n\n## Case 22-50073 Doc 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 441 of 491\n\n4. All Documents dated between January 1, 2014 and the present 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 dated between January 1, 2014 and the present related to any correspondence and communications between you and the 2004 Discovery Targets.\n\n6. All Documents dated between January 1, 2014 and the present 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 dated between January 1, 2014 and the present related to any antimoney 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 dated between January 1, 2014 and the present 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-23**\n\n### B2540 (Form 2540 – Subpoena for Rule 2004 Examination) (12/15) UNITED STATES BANKRUPTCY COURT Case 22-50073 Doc 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 443 of 491\n\n\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_ District of \\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_ Connecticut\n\nIn re \\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\n\nCase No. \\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_ Ho Wan Kwok 22-50073\n\nDebtor\n\nChapter \\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_ 11\n\n## **SUBPOENA FOR RULE 2004 EXAMINATION**\n\nTo: **\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_** JPMorgan Chase Bank, N.A.\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. X\n\n| PLACE
NEUBERT, PEPE & MONTEITH, P.C. | DATE AND TIME |\n|---------------------------------------------------------------|---------------|\n| 195 Church Street, 13th Floor
New Haven, Connecticut 06510 | |\n| | |\n\nThe examination will be recorded by this method: \\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_ court reporter/stenographer\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: X\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: \\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_ September \\_\\_, 2022\n\nCLERK OF COURT\n\nOR\n\n\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_ *Signature of Clerk or Deputy Clerk* \\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_ *Attorney's signature* Patrick R. Linsey (ct29437)\n\nThe name, address, email address, and telephone number of the attorney representing *(name of party)* \\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_ , who issues or requests this subpoena, are: Luc Despins, Ch. 11 Trustee\n\nPatrick R. Linsey, Esq.; Neubert, Pepe & Monteith, P.C.; 195 Church Street, 13th Floor, New Haven, Connecticut 06510 plinsey@npmlaw.com; (203) 821-2000\n\n## **Notice to the person who issues or requests this subpoena**\n\nIf this subpoena commands the production of documents, electronically stored information, or tangible things, or the inspection of premises before trial, a notice and a copy of this subpoena must be served on each party before it is served on the person to whom it is directed. Fed. R. Civ. P. 45(a)(4).\n\n## **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 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 446 of 491\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
- | 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
time zone in which
the emails
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 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 447 of 491\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| | | |\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
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 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 448 of 491\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 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 449 of 491\n\nsuch Persons, as well as a statement addressing how the information came into their possession, (viii) the claim of privilege under which the Document is withheld, and (ix) all of the circumstances upon which You will rely to support such claim of privilege; and (b) produce a privilege log containing all of the information requested in Part (a) of this Instruction for each Document withheld on the basis of a claim of privilege in accordance with D. Conn. L. Civ. R. 26(e). For any part of a Document Request as to which a claim of privilege or work product is not made, responsive documents should be provided in full.\n\n9. If a portion of an otherwise responsive Document contains information subject to a claim of privilege, only that portion of the Document subject to the claim of privilege shall be deleted or redacted from the Document following the instructions above, and the rest shall be produced.\n\n10. The Requests are continuing in nature. You are hereby instructed to (a) supplement or correct any responses later learned to be incomplete or incorrect immediately upon learning that a prior response was incomplete or incorrect; and (b) produce any additional Documents that are called for under the\n\n11. If a Document is in a language other than English, You should provide that Document. If a Document is in a language other than English, and an English translation exists, You should provide both Documents.\n\n12. All references to Entities includes all affiliates thereof.\n\n13. All references to individual names include all alternative names, aliased, or nicknames.\n\n## Case 22-50073 Doc 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 450 of 491\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 JPMorgan Chase Bank, N.A., together with any of its affiliates, parents, and subsidiaries, and any of their employees, agents, counsel, advisors, 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\n## Case 22-50073 Doc 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 451 of 491\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, ACA Capital Group Limited, Himalaya International Financial Group Ltd., Himalaya International Clearing Ltd., Himalaya International Payments Ltd., Himalaya International Reserves Ltd., Jesse Brown, William Je, William Je, Eastern Profit Corporation Limited, HK International Funds Investments (USA) Limited LLC, Bravo Luck Limited, Golden Spring (New York) Ltd., Lamp Capital LLC, Greenwich Land LLC, Qu Guo Jiao, Daniel Thomas Podhaskie, Yvette Wang, Ace Decade Holdings Limited, Dawn State Limited, Rule of Law Society IV Inc., Rule of Law Foundation III, GTV Media Group, Inc., Voice of Guo Media, Inc., and Saraca Media Group Inc.\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,\n\n## Case 22-50073 Doc 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 452 of 491\n\nadvisors, or anyone acting on behalf of any of the foregoing. Such Associated Individuals shall include, but are not limited to: Daniel Podhaskie, Jason Miller, Jesse Brown, William Je, Steve Bannon, Karin Maistrello, Melissa Francis, William Gertz, Arethusa Forsyth, Glenn Mellor, Jennifer Mercurio, Eduardo Eurnekian, Han Chunguang (a/k/a 韩春光), Qu Guojiao (a/k/a Qu Guo Jiao, 屈国姣), Guo Lijie (a/k/a 郭丽杰), Zhang Wei (a/k/a 张伟\\*), Lihong Wei Lafrenz (a/k/a Sara Wei, 魏丽红), Hao Haidong (a/k/a 郝海东), Ross Heinemeyer, Max Krasner, Kyle Bass, Melissa Mendez, Ya Li (a/k/a 李娅), Dinggang Wang (a/k/a 王定刚), An Hong (a/k/a 安红), Yvette Wang (a/k/a Yanping Wang, Yan Ping Wang, 王雁平), Fiona Yu, Je Kin Ming (a/k/a William Je, Yu Jianming, 余建明), Yaz Qingua, and Lao Jiang (a/k/a Jiang Yunfu, Jiang Yunfu Be, 姜云浮).\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: 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, Assets Sino Limited, Auspicious Coast Limited, Beijing Pangu Investment Co., Beijing Pangu Investment Co. Ltd., Beijing Pangu Investment Inc., Beijing Zenith Holdings Company Limited, Bravo Luck Limited, 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,\n\n## Case 22-50073 Doc 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 453 of 491\n\nDawn State Limited, Eastern Profit Corporation Limited, Elite Well Global Limited, Empire Growth Holdings, G Club Operations LLC, G Fashion LLC, G News LLC, GETTR USA, Genever Holdings Corporation, Genever Holdings LLC, GFASHION MEDIA GROUP INC., GFNY, Inc., Globalist International Limited, GNews Media Group Inc., Golden Spring (New York) Ltd., Greenwich Land LLC, Guo Media, GTV Media Group, Inc., Hamilton Capital Holdings Inc., Head Win Group Limited, Henan Yuda, Himalaya Embassy, Himalaya Exchange, Himalaya Federal Reserve, Himalaya International Financial Group Ltd., Himalaya International Clearing Ltd. , Himalaya International Payments Ltd., Himalaya International Reserves Ltd., Himalaya Supervisory Organization, HK International Funds Investments (USA) Limited LLC, Hong Kong International Funds Investments Limited, Hudson Diamond NY LLC, Infinite Increase Limited, Infinitum Developments Limited, Insight Phoenix Fund, Lamp Capital LLC, Leading Shine Limited, Leading Shine NY Limited, Long Gate Limited, Next Tycoon Investments Limited, New Federal State of China (a/k/a NFSC), Noble Fame Global Limited, Rosy Acme Ventures Limited, Rule of Law Foundation III, Inc., Rule of Law Foundation IV, Inc., Rule of Law Fund, Rule of Law Society, Rule of Law Society IV, Inc., G-Translators PTY LTD, Saraca Media Group, Inc., Shiny Ace Ltd., Shiny Times Holdings Ltd., Spirit Charter Investment Limited, Stevenson, Wong & Co., TM Primrose Limited, Voice of Guo Media, Inc., Well Origin Ltd., World Century Limited, Worldwide Opportunity Holdings Limited, Whitecroft Shore Limited, and ZIBA Limited.\n\n10. \"Including\" or any variant thereof means \"including without limitation.\"\n\n11. \"And\" and \"or\" mean \"and/or,\" and shall be construed both conjunctively as well as disjunctively in order to maximize their scope.\n\n12. \"Any\" and \"all\" and \"each\" mean \"each and every.\"\n\n13. \"Each\" and \"every\" mean \"each and every.\"\n\n## Case 22-50073 Doc 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 454 of 491\n\n14. \"Third Party\" means a Person or Entity other than Yourself.\n\n15. \"Transfer\" shall have the meaning given to it by section 101(54) of the Bankruptcy Code.\n\n16. \"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\n17. \"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\n## Case 22-50073 Doc 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 455 of 491\n\n18. \"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\n19. \"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\n20. \"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\n21. \"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\n## Case 22-50073 Doc 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 456 of 491\n\n22. \"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 dated between January 1, 2014 and the present 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 dated between January 1, 2014 and the present 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 dated between January 1, 2014 and the present related to any business, commerce or financial transactions, including but not limited to any loan, line of credit, bailment, deposit, swap, securities transactions, mortgage, or ISDA, with any of the 2004 Discovery Targets, including any and all account statements, authorizations, powers of attorney, trusts, instructions or forms, copies of cancelled checks, correspondence, and wire transfers and related correspondence and instructions.\n\n## Case 22-50073 Doc 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 457 of 491\n\n4. All Documents dated between January 1, 2014 and the present 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 dated between January 1, 2014 and the present related to any correspondence and communications between you and the 2004 Discovery Targets.\n\n6. All Documents dated between January 1, 2014 and the present 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 dated between January 1, 2014 and the present related to any antimoney 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 dated between January 1, 2014 and the present 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-24**\n\n### B2540 (Form 2540 – Subpoena for Rule 2004 Examination) (12/15) UNITED STATES BANKRUPTCY COURT Case 22-50073 Doc 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 459 of 491\n\n\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_ District of \\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_ Connecticut\n\nIn re \\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\n\nCase No. \\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_ Ho Wan Kwok 22-50073\n\nDebtor\n\nChapter \\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_ 11\n\n## **SUBPOENA FOR RULE 2004 EXAMINATION**\n\nTo: **\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_** Standard Chartered 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. X\n\n| PLACE | DATE AND TIME |\n|-----------------------------------------------------------------|---------------|\n| NEUBERT, PEPE & MONTEITH, P.C.
195 Church Street, 13th Floor | |\n| New Haven, Connecticut 06510 | |\n\nThe examination will be recorded by this method: \\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_ court reporter/stenographer\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: X\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: \\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_ September \\_\\_, 2022\n\nCLERK OF COURT\n\nOR\n\n\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_ *Signature of Clerk or Deputy Clerk* \\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_ *Attorney's signature* Patrick R. Linsey (ct29437)\n\nThe name, address, email address, and telephone number of the attorney representing *(name of party)* \\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_ , who issues or requests this subpoena, are: Luc Despins, Ch. 11 Trustee\n\nPatrick R. Linsey, Esq.; Neubert, Pepe & Monteith, P.C.; 195 Church Street, 13th Floor, New Haven, Connecticut 06510 plinsey@npmlaw.com; (203) 821-2000\n\n## **Notice to the person who issues or requests this subpoena**\n\nIf this subpoena commands the production of documents, electronically stored information, or tangible things, or the inspection of premises before trial, a notice and a copy of this subpoena must be served on each party before it is served on the person to whom it is directed. Fed. R. Civ. P. 45(a)(4).\n\n## **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 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 462 of 491\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
- | 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
time zone in which
the emails
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 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 463 of 491\n\n| TIME_CREATED | 10:25 AM | Email: (empty) |\n|--------------|---------------------------|-------------------------------------------------|\n| | | Native: Time the document was created |\n| | | **This data must be a separate field and cannot |\n| | | be combined with the DATE_CREATED field |\n| DATE_MOD | 10/12/2010 | Email: (empty) |\n| | | Native: Date the document was last modified |\n| TIME_MOD | 07:00 PM | Email: (empty) |\n| | | Native: Time the document was last modified |\n| | | **This data must be a separate field and cannot |\n| | | be combined with the DATE_MOD field |\n| | | |\n| DATE_ACCESSD | 10/12/2010 | Email: (empty) |\n| | | Native: Date the document was last accessed |\n| TIME_ACCESSD | 07:00 PM | Email: (empty) |\n| | | Native: Time the document was last accessed |\n| | | **This data must be a separate field and cannot |\n| | | be combined with the DATE_ACCESSD field |\n| FILE_SIZE | 5,952 | Size of native file
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 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 464 of 491\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 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 465 of 491\n\nsuch Persons, as well as a statement addressing how the information came into their possession, (viii) the claim of privilege under which the Document is withheld, and (ix) all of the circumstances upon which You will rely to support such claim of privilege; and (b) produce a privilege log containing all of the information requested in Part (a) of this Instruction for each Document withheld on the basis of a claim of privilege in accordance with D. Conn. L. Civ. R. 26(e). For any part of a Document Request as to which a claim of privilege or work product is not made, responsive documents should be provided in full.\n\n9. If a portion of an otherwise responsive Document contains information subject to a claim of privilege, only that portion of the Document subject to the claim of privilege shall be deleted or redacted from the Document following the instructions above, and the rest shall be produced.\n\n10. The Requests are continuing in nature. You are hereby instructed to (a) supplement or correct any responses later learned to be incomplete or incorrect immediately upon learning that a prior response was incomplete or incorrect; and (b) produce any additional Documents that are called for under the\n\n11. If a Document is in a language other than English, You should provide that Document. If a Document is in a language other than English, and an English translation exists, You should provide both Documents.\n\n12. All references to Entities includes all affiliates thereof.\n\n13. All references to individual names include all alternative names, aliased, or nicknames.\n\n## Case 22-50073 Doc 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 466 of 491\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 Standard Chartered PLC, together with any of its affiliates, parents, and subsidiaries, and any of their employees, agents, counsel, advisors, 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\n## Case 22-50073 Doc 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 467 of 491\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, ACA Capital Group Limited, Himalaya International Financial Group Ltd., Himalaya International Clearing Ltd., Himalaya International Payments Ltd., Himalaya International Reserves Ltd., Jesse Brown, William Je, William Je, Eastern Profit Corporation Limited, HK International Funds Investments (USA) Limited LLC, Bravo Luck Limited, Golden Spring (New York) Ltd., Lamp Capital LLC, Greenwich Land LLC, Qu Guo Jiao, Daniel Thomas Podhaskie, Yvette Wang, Ace Decade Holdings Limited, Dawn State Limited, Rule of Law Society IV Inc., Rule of Law Foundation III, GTV Media Group, Inc., Voice of Guo Media, Inc., and Saraca Media Group Inc.\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,\n\n## Case 22-50073 Doc 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 468 of 491\n\nadvisors, or anyone acting on behalf of any of the foregoing. Such Associated Individuals shall include, but are not limited to: Daniel Podhaskie, Jason Miller, Jesse Brown, William Je, Steve Bannon, Karin Maistrello, Melissa Francis, William Gertz, Arethusa Forsyth, Glenn Mellor, Jennifer Mercurio, Eduardo Eurnekian, Han Chunguang (a/k/a 韩春光), Qu Guojiao (a/k/a Qu Guo Jiao, 屈国姣), Guo Lijie (a/k/a 郭丽杰), Zhang Wei (a/k/a 张伟\\*), Lihong Wei Lafrenz (a/k/a Sara Wei, 魏丽红), Hao Haidong (a/k/a 郝海东), Ross Heinemeyer, Max Krasner, Kyle Bass, Melissa Mendez, Ya Li (a/k/a 李娅), Dinggang Wang (a/k/a 王定刚), An Hong (a/k/a 安红), Yvette Wang (a/k/a Yanping Wang, Yan Ping Wang, 王雁平), Fiona Yu, Je Kin Ming (a/k/a William Je, Yu Jianming, 余建明), Yaz Qingua, and Lao Jiang (a/k/a Jiang Yunfu, Jiang Yunfu Be, 姜云浮).\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: 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, Assets Sino Limited, Auspicious Coast Limited, Beijing Pangu Investment Co., Beijing Pangu Investment Co. Ltd., Beijing Pangu Investment Inc., Beijing Zenith Holdings Company Limited, Bravo Luck Limited, 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,\n\n## Case 22-50073 Doc 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 469 of 491\n\nDawn State Limited, Eastern Profit Corporation Limited, Elite Well Global Limited, Empire Growth Holdings, G Club Operations LLC, G Fashion LLC, G News LLC, GETTR USA, Genever Holdings Corporation, Genever Holdings LLC, GFASHION MEDIA GROUP INC., GFNY, Inc., Globalist International Limited, GNews Media Group Inc., Golden Spring (New York) Ltd., Greenwich Land LLC, Guo Media, GTV Media Group, Inc., Hamilton Capital Holdings Inc., Head Win Group Limited, Henan Yuda, Himalaya Embassy, Himalaya Exchange, Himalaya Federal Reserve, Himalaya International Financial Group Ltd., Himalaya International Clearing Ltd. , Himalaya International Payments Ltd., Himalaya International Reserves Ltd., Himalaya Supervisory Organization, HK International Funds Investments (USA) Limited LLC, Hong Kong International Funds Investments Limited, Hudson Diamond NY LLC, Infinite Increase Limited, Infinitum Developments Limited, Insight Phoenix Fund, Lamp Capital LLC, Leading Shine Limited, Leading Shine NY Limited, Long Gate Limited, Next Tycoon Investments Limited, New Federal State of China (a/k/a NFSC), Noble Fame Global Limited, Rosy Acme Ventures Limited, Rule of Law Foundation III, Inc., Rule of Law Foundation IV, Inc., Rule of Law Fund, Rule of Law Society, Rule of Law Society IV, Inc., G-Translators PTY LTD, Saraca Media Group, Inc., Shiny Ace Ltd., Shiny Times Holdings Ltd., Spirit Charter Investment Limited, Stevenson, Wong & Co., TM Primrose Limited, Voice of Guo Media, Inc., Well Origin Ltd., World Century Limited, Worldwide Opportunity Holdings Limited, Whitecroft Shore Limited, and ZIBA Limited.\n\n10. \"Including\" or any variant thereof means \"including without limitation.\"\n\n11. \"And\" and \"or\" mean \"and/or,\" and shall be construed both conjunctively as well as disjunctively in order to maximize their scope.\n\n12. \"Any\" and \"all\" and \"each\" mean \"each and every.\"\n\n13. \"Each\" and \"every\" mean \"each and every.\"\n\n## Case 22-50073 Doc 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 470 of 491\n\n14. \"Third Party\" means a Person or Entity other than Yourself.\n\n15. \"Transfer\" shall have the meaning given to it by section 101(54) of the Bankruptcy Code.\n\n16. \"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\n17. \"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\n## Case 22-50073 Doc 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 471 of 491\n\n18. \"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\n19. \"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\n20. \"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\n21. \"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\n## Case 22-50073 Doc 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 472 of 491\n\n22. \"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 dated between January 1, 2014 and the present 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 dated between January 1, 2014 and the present 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 dated between January 1, 2014 and the present related to any business, commerce or financial transactions, including but not limited to any loan, line of credit, bailment, deposit, swap, securities transactions, mortgage, or ISDA, with any of the 2004 Discovery Targets, including any and all account statements, authorizations, powers of attorney, trusts, instructions or forms, copies of cancelled checks, correspondence, and wire transfers and related correspondence and instructions.\n\n## Case 22-50073 Doc 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 473 of 491\n\n4. All Documents dated between January 1, 2014 and the present 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 dated between January 1, 2014 and the present related to any correspondence and communications between you and the 2004 Discovery Targets.\n\n6. All Documents dated between January 1, 2014 and the present 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 dated between January 1, 2014 and the present related to any antimoney 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 dated between January 1, 2014 and the present 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-25**\n\n### B2540 (Form 2540 – Subpoena for Rule 2004 Examination) (12/15) UNITED STATES BANKRUPTCY COURT Case 22-50073 Doc 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 475 of 491\n\n\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_ District of \\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_ Connecticut\n\nIn re \\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\n\nCase No. \\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_ Ho Wan Kwok 22-50073\n\nDebtor\n\nChapter \\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_ 11\n\n## **SUBPOENA FOR RULE 2004 EXAMINATION**\n\nTo: **\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_** UBS AG\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. X\n\n| PLACE
NEUBERT, PEPE & MONTEITH, P.C. | DATE AND TIME |\n|---------------------------------------------------------------|---------------|\n| 195 Church Street, 13th Floor
New Haven, Connecticut 06510 | |\n| | |\n\nThe examination will be recorded by this method: \\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_ court reporter/stenographer\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: X\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: \\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_ September \\_\\_, 2022\n\nCLERK OF COURT\n\nOR\n\n\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_ *Signature of Clerk or Deputy Clerk* \\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_ *Attorney's signature* Patrick R. Linsey (ct29437)\n\nThe name, address, email address, and telephone number of the attorney representing *(name of party)* \\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_ , who issues or requests this subpoena, are: Luc Despins, Ch. 11 Trustee\n\nPatrick R. Linsey, Esq.; Neubert, Pepe & Monteith, P.C.; 195 Church Street, 13th Floor, New Haven, Connecticut 06510 plinsey@npmlaw.com; (203) 821-2000\n\n## **Notice to the person who issues or requests this subpoena**\n\nIf this subpoena commands the production of documents, electronically stored information, or tangible things, or the inspection of premises before trial, a notice and a copy of this subpoena must be served on each party before it is served on the person to whom it is directed. Fed. R. Civ. P. 45(a)(4).\n\n## **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 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 478 of 491\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
- | 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
time zone in which
the emails
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 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 479 of 491\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
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 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 480 of 491\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 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 481 of 491\n\nsuch Persons, as well as a statement addressing how the information came into their possession, (viii) the claim of privilege under which the Document is withheld, and (ix) all of the circumstances upon which You will rely to support such claim of privilege; and (b) produce a privilege log containing all of the information requested in Part (a) of this Instruction for each Document withheld on the basis of a claim of privilege in accordance with D. Conn. L. Civ. R. 26(e). For any part of a Document Request as to which a claim of privilege or work product is not made, responsive documents should be provided in full.\n\n9. If a portion of an otherwise responsive Document contains information subject to a claim of privilege, only that portion of the Document subject to the claim of privilege shall be deleted or redacted from the Document following the instructions above, and the rest shall be produced.\n\n10. The Requests are continuing in nature. You are hereby instructed to (a) supplement or correct any responses later learned to be incomplete or incorrect immediately upon learning that a prior response was incomplete or incorrect; and (b) produce any additional Documents that are called for under the\n\n11. If a Document is in a language other than English, You should provide that Document. If a Document is in a language other than English, and an English translation exists, You should provide both Documents.\n\n12. All references to Entities includes all affiliates thereof.\n\n13. All references to individual names include all alternative names, aliased, or nicknames.\n\n## Case 22-50073 Doc 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 482 of 491\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 UBS AG, together with any of its affiliates, parents, and subsidiaries, and any of their employees, agents, counsel, advisors, 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\n## Case 22-50073 Doc 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 483 of 491\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, ACA Capital Group Limited, Himalaya International Financial Group Ltd., Himalaya International Clearing Ltd., Himalaya International Payments Ltd., Himalaya International Reserves Ltd., Jesse Brown, William Je, William Je, Eastern Profit Corporation Limited, HK International Funds Investments (USA) Limited LLC, Bravo Luck Limited, Golden Spring (New York) Ltd., Lamp Capital LLC, Greenwich Land LLC, Qu Guo Jiao, Daniel Thomas Podhaskie, Yvette Wang, Ace Decade Holdings Limited, Dawn State Limited, Rule of Law Society IV Inc., Rule of Law Foundation III, GTV Media Group, Inc., Voice of Guo Media, Inc., and Saraca Media Group Inc.\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,\n\n## Case 22-50073 Doc 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 484 of 491\n\nadvisors, or anyone acting on behalf of any of the foregoing. Such Associated Individuals shall include, but are not limited to: Daniel Podhaskie, Jason Miller, Jesse Brown, William Je, Steve Bannon, Karin Maistrello, Melissa Francis, William Gertz, Arethusa Forsyth, Glenn Mellor, Jennifer Mercurio, Eduardo Eurnekian, Han Chunguang (a/k/a 韩春光), Qu Guojiao (a/k/a Qu Guo Jiao, 屈国姣), Guo Lijie (a/k/a 郭丽杰), Zhang Wei (a/k/a 张伟\\*), Lihong Wei Lafrenz (a/k/a Sara Wei, 魏丽红), Hao Haidong (a/k/a 郝海东), Ross Heinemeyer, Max Krasner, Kyle Bass, Melissa Mendez, Ya Li (a/k/a 李娅), Dinggang Wang (a/k/a 王定刚), An Hong (a/k/a 安红), Yvette Wang (a/k/a Yanping Wang, Yan Ping Wang, 王雁平), Fiona Yu, Je Kin Ming (a/k/a William Je, Yu Jianming, 余建明), Yaz Qingua, and Lao Jiang (a/k/a Jiang Yunfu, Jiang Yunfu Be, 姜云浮).\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: 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, Assets Sino Limited, Auspicious Coast Limited, Beijing Pangu Investment Co., Beijing Pangu Investment Co. Ltd., Beijing Pangu Investment Inc., Beijing Zenith Holdings Company Limited, Bravo Luck Limited, 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,\n\n## Case 22-50073 Doc 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 485 of 491\n\nDawn State Limited, Eastern Profit Corporation Limited, Elite Well Global Limited, Empire Growth Holdings, G Club Operations LLC, G Fashion LLC, G News LLC, GETTR USA, Genever Holdings Corporation, Genever Holdings LLC, GFASHION MEDIA GROUP INC., GFNY, Inc., Globalist International Limited, GNews Media Group Inc., Golden Spring (New York) Ltd., Greenwich Land LLC, Guo Media, GTV Media Group, Inc., Hamilton Capital Holdings Inc., Head Win Group Limited, Henan Yuda, Himalaya Embassy, Himalaya Exchange, Himalaya Federal Reserve, Himalaya International Financial Group Ltd., Himalaya International Clearing Ltd. , Himalaya International Payments Ltd., Himalaya International Reserves Ltd., Himalaya Supervisory Organization, HK International Funds Investments (USA) Limited LLC, Hong Kong International Funds Investments Limited, Hudson Diamond NY LLC, Infinite Increase Limited, Infinitum Developments Limited, Insight Phoenix Fund, Lamp Capital LLC, Leading Shine Limited, Leading Shine NY Limited, Long Gate Limited, Next Tycoon Investments Limited, New Federal State of China (a/k/a NFSC), Noble Fame Global Limited, Rosy Acme Ventures Limited, Rule of Law Foundation III, Inc., Rule of Law Foundation IV, Inc., Rule of Law Fund, Rule of Law Society, Rule of Law Society IV, Inc., G-Translators PTY LTD, Saraca Media Group, Inc., Shiny Ace Ltd., Shiny Times Holdings Ltd., Spirit Charter Investment Limited, Stevenson, Wong & Co., TM Primrose Limited, Voice of Guo Media, Inc., Well Origin Ltd., World Century Limited, Worldwide Opportunity Holdings Limited, Whitecroft Shore Limited, and ZIBA Limited.\n\n10. \"Including\" or any variant thereof means \"including without limitation.\"\n\n11. \"And\" and \"or\" mean \"and/or,\" and shall be construed both conjunctively as well as disjunctively in order to maximize their scope.\n\n12. \"Any\" and \"all\" and \"each\" mean \"each and every.\"\n\n13. \"Each\" and \"every\" mean \"each and every.\"\n\n## Case 22-50073 Doc 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 486 of 491\n\n14. \"Third Party\" means a Person or Entity other than Yourself.\n\n15. \"Transfer\" shall have the meaning given to it by section 101(54) of the Bankruptcy Code.\n\n16. \"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\n17. \"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\n## Case 22-50073 Doc 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 487 of 491\n\n18. \"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\n19. \"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\n20. \"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\n21. \"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\n## Case 22-50073 Doc 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 488 of 491\n\n22. \"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 dated between January 1, 2012 and the present 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 dated between January 1, 2012 and the present 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 dated between January 1, 2012 and the present related to any business, commerce or financial transactions, including but not limited to any loan, line of credit, bailment, deposit, swap, securities transactions, mortgage, or ISDA, with any of the 2004 Discovery Targets, including any and all account statements, authorizations, powers of attorney, trusts, instructions or forms, copies of cancelled checks, correspondence, and wire transfers and related correspondence and instructions.\n\n## Case 22-50073 Doc 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 489 of 491\n\n4. All Documents dated between January 1, 2012 and the present 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 dated between January 1, 2012 and the present related to any correspondence and communications between you and the 2004 Discovery Targets.\n\n6. All Documents dated between January 1, 2012 and the present 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 dated between January 1, 2012 and the present related to any antimoney 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 dated between January 1, 2012 and the present 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## **UNITED STATES BANKRUPTCY COURT DISTRICT OF CONNECTICUT BRIDGEPORT DIVISION**\n\n| ----------------------------------------------------------- | x | |\n|-------------------------------------------------------------|---|-------------------------|\n| | : | |\n| In re: | : | Chapter 11 |\n| | : | |\n| HO WAN KWOK, | : | Case No. 22-50073 (JAM) |\n| | : | |\n| Debtor. | : | |\n| | : | |\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 advisors and professionals, family members, business associates, corporate entities, and banking 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 September 15, 2022,1 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 Page Intentionally Left Blank*]\n\n1 Although objections to a Rule 2004 application are due seven days after filing under the Local Rules, the Trustee submits that a one-day extension of the objection deadline is appropriate given that some notice parties will not be served with the Application until Thursday, September 8, 2022.\n\n## Case 22-50073 Doc 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 491 of 491\n\nDated: September 7, 2022 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*","body_zh":"美国康涅狄格州联邦破产法院\n布里奇波特分部\n\n----------------------------------------------------------- x\n\n关于： :\n:\n第11章\nHO WAN KWOK（郭文贵）， :\n:\n案号 22-50073 (JAM)\n\n债务人。1 :\n\n----------------------------------------------------------- x\n第11章受托人关于根据《破产程序规则》第2004条及地方法院规则第2004-1条请求作出命令，以授权就债务人的其他法律及财务顾问、与债务人有关联的实体及个人以及相关银行进行取证的第一次补充综合动议\n\nLuc Despins，作为获任命管理债务人财产的第11章受托人（“受托人”），通过其下列签署的律师，依据《联邦破产程序规则》第2004(a)条（“《破产规则》”）及《地方破产规则》第2004-1条（“《地方法院规则》”），特此申请（“本申请”或“本动议”）对上述标题所列债务人（“债务人”）在上述第11章案件（“本案”）中的法律、咨询或会计师事务所（“顾问”）、家庭成员、商业伙伴及公司实体（“关联人士”），以及受托人认为债务人及关联人士曾在其处从事与财产相关业务的若干银行（“银行”，并与顾问及关联人士合称“受查对象”）进行审查；该等受查对象载于本文件所附附件B。请注意，对本申请提出异议的截止日期为 September 15, 2022；如未及时提出异议，则本文件随附作为附件A的拟议命令（“拟议命令”）可在无需进一步通知和听证的情况下作出。为支持其申请，受托人谨陈述如下：\n\n1 尽管债务人的法定姓名为 Ho Wan Kwok（郭文贵），其亦被称为 Guo Wengui、Miles Guo 和 Miles Kwok，以及许多其他别名。债务人纳税人识别号码的最后四位为 9595。\n\n初步陈述\n\n1. 在授权任命第11章受托人时，本院确认，受托人的一项关键目标将是对“债务人的资产、负债及财务状况进行有效调查”。（见 ECF. No. 465，第14页，以下简称“受托人命令”）。在本案中，此类调查至关重要，目的包括探究债务人在其附表中声称其仅拥有价值 \\$3,850 的资产，与其仍可获得大量资金及资源（包括用于支付其在本案中的律师费用）且继续以自称亿万富翁的身份过着奢华生活这一事实之间的明显不一致。因此，受托人已开始对债务人的财务状况进行广泛调查，以确定尽管其附表载明的内容，是否仍存在重大资产——包括构成财产的动产及不动产、在其他法人实体中的股权所有权、诉讼请求及其他财产权益。\n\n2. 为协助该调查，受托人于 July 28, 2022 提交了三项动议，请求根据《破产规则》第2004条授权进行取证，即分别针对债务人、债务人的法律及财务顾问，以及被认为与债务人有关联或以其他方式与债务人相关的实体及个人的动议。本院批准了该等动议，受托人目前正在进行该等《破产规则》第2004条取证。随着受托人调查的进展，以及受托人获知其他顾问及关联人士的身份或与其有关的相关事实，受托人请求通过申请就该等受查对象进行额外的《破产规则》第2004条取证，以进一步推进其调查。\n\n3. 受托人认为，受查对象可获得并了解与债务人的资产、财务状况及其在与债务人、其家属或其关联人士相关的各种公司实体中可能具有的财务权益有关的信息。事实上，若债务人曾通过空壳公司网络及其他方式隐匿其财富（正如纽约州最高法院已认定），受托人预计债务人很可能需要顾问提供广泛协助和意见，以及关联人士提供帮助并参与其中。\n\n4. 本动议与受托人先前根据《破产规则》第2004条提出的动议及本院批准该等动议的命令相一致并相互补充。该等额外信息来源将补充和扩展受托人已开始进行的调查，并开辟额外的调查途径及潜在资产发现途径。\n\n程序经过\n\n5. 于 March 19, 2022，美国受托人提交了请求作出命令以指示任命审查员的动议，或作为替代请求，提交了请求作出命令以指示任命第11章受托人的动议。（见 ECF No. 102）。\n\n6. 于 April 6, 2022，Pacific Alliance Asia Opportunity Fund L.P.（“PAX”）提交了请求驳回第11章案件的动议，或作为替代请求，加入美国受托人请求作出命令以指示任命第11章受托人的动议。（见 ECF No. 183）。\n\n7. 于 June 15, 2022，本院作出受托人命令。\n\n8. 受托人命令认定，就相关部分而言，“在驳回或转换程序之间进行权衡后，债务人财务状况的复杂性以及本案中缺乏独立管理监督，足以支持任命一名第11章受托人，以为债权人和财产的利益调查、识别并查找债务人的资产”；并进一步认定，“第11章受托人应履行 11 U.S.C. § 1106 规定的全部职责。”（见同上，第15-16、18页）。\n\n9. 受托人命令进一步认定，“任命第11章受托人还将有助于对债务人的资产、负债及财务状况进行有效调查”，并“使第11章受托人能够调查债务人的资产、负债及财务状况，并确保遵守约定命令的规定。”（见同上，第14、18页）。\n\n10. 于 July 7, 2022，美国受托人办公室提交了第11章受托人任命通知，任命 Luc Despins 为债务人财产的第11章受托人。（见 ECF No. 514）。\n\n11. 在获任命后，受托人提交了三项第2004条规则动议：一项针对债务人（ECF No. 636，“债务人第2004条动议”），以及两项综合动议——一项针对被认为曾向债务人及相关实体和个人提供意见的法律及财务事务所（ECF No. 637，“顾问第2004条动议”），另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及个人（“关联人士第2004条动议”，并与债务人第2004条动议及顾问第2004条动议合称“第2004条动议”）。本院于 August 16, 2022 作出命令，分别批准该等第2004条动议（ECF No. 756，“顾问第2004条命令”；ECF No. 757，“债务人第2004条命令”；ECF No. 758，“关联人士第2004条命令”；并与顾问第2004条命令及债务人第2004条命令合称“第2004条命令”）。\n\n事实背景\nI. 申请及债务人的附表\n\n12. 于 February 15, 2022（“申请日”），债务人根据《美国法典》第11编第11章（“《破产法典》”）提交了自愿破产救济申请。\n\n13. 债务人的附表列明无担保债权总额约为 \\$374 million（见 ECF No. 78，第1页，以下简称“债务人的附表”）。PAX 主张的 \\$254 million 债权，是债务人附表所列无担保债权中确认的最大单项债权。（见同上，所附附表F）。债务人的附表还列明一项金额不明的有担保债权，据称属于 Golden Spring (New York) Ltd.（“Golden Spring”），该实体据称由债务人的儿子 Qiang Guo（“儿子”或“Qiang”）拥有；该债权据称以“[c]ertain claims and recoveries thereto”为担保，并主张其因“Litigation Funding Agreement”而产生。（见同上，所附附表D）。\n\n14. 尽管先前程序中的证据表明债务人过着奢华的生活并享有豪华住所，债务人的附表仅列明 \\$3,850 的资产。2（见同上，第3-7页）。债务人主张其没有任何收入，其费用由 Golden Spring 支付（见同上，第1页；另见 ECF No. 107，第¶17段，以下简称“债务人声明”）。\n\nII. 债务人拥有或控制但未在附表中列明的潜在资产\n\n15. 尽管债务人在其附表中作出该等主张，报告显示其可能在纽约州和康涅狄格州等地拥有并控制大量动产及不动产资产，而该等资产的所有权登记在与债务人有关联的商业实体名下。报告还显示，债务人在大量营利性及声称为非营利性实体中亦拥有财务权益。债务人已被认定具有在该等不同商业实体之间操纵所有权以隐匿资产的模式，尤其是通过由家庭成员拥有的实体。（见《关于动议的裁决及命令》，Pacific Alliance Asia Opportunity Fund L.P. v. Ho Wan Kwok，Index No. 652077/2017 (N.Y. Sup. Feb. 9, 2022)，第1页，以下简称“最终藐视法庭命令”（认定债务人“为逃避和欺骗其债权人，曾试图将其大量个人资产置于一系列公司、受信赖的知己及家庭成员名下”，并且“将其资产隐藏在错综复杂的公司实体及家庭成员之中。”）。3\n\n2 债务人在附表中列明了若干价值不明的资产，包括存在争议的未登记著作权及诉讼请求。（见同上，第6页）。\n\na. 受控制的关联实体\n\n16. 尽管有必要进行彻底调查以识别债务人可能拥有所有权或控制权的所有不同实体，但受托人基于公开可获得的信息，包括其他法院的认定，有理由相信债务人拥有广泛的空壳公司网络，其利用该网络追求商业利益并掩盖其资产。\n\n17. 例如，于 June 2021，在美国纽约南区联邦地区法院，Eastern Profit Corporation Limited（“Eastern Profit”）——据称由债务人的女儿 Mei Guo（“女儿”或“Mei”）控制的实体——在针对 Strategic Vision US LLC 的违约诉讼中获判 \\$1 million。（见 ECF No. 77，第12-13页；另见 Eastern Profit Corp. v. Strategic Vision US LLC, 2021 U.S. Dist. LEXIS 116334, at \\*98 (S.D.N.Y. June 22, 2021)，以下简称“Eastern Profit 诉讼”）。地区法院在就 Eastern Profit 诉讼作出的事实认定和法律结论中认定，Eastern Profit“实质上是”债务人的空壳公司。（见 Eastern Profit 诉讼，第 \\*4 页）。\n\n18. 已确认的债务人可能控制的其他实体包括：(i) Bravo Luck Limited（“Bravo Luck”），据称由债务人的儿子拥有的实体（见债务人声明，第¶33段）；(ii) Genever Holdings LLC（“Genever NY”），其为 Genever Holdings Corporation（“Genever BVI”）的全资子公司，而该公司的股权由债务人以其\n\n3 最终藐视法庭命令作为附件A附于《第11章受托人对债务人请求免除任命 Luc A. Despins 为第11章受托人的命令之动议的异议》[Docket No. 575]。\n\n以个人身份（见同上）；(iii) Golden Spring（黄金泉），据称由债务人的儿子控制的实体（见同上，第 ¶17 段）；(iv) Greenwich Land LLC（格林尼治土地有限责任公司）（“Greenwich Land”），据称由债务人据称的妻子 Hing Chi Ngok（吴兴芝）（“妻子”或“Hing”）拥有的实体（见同上）；(v) Lamp Capital LLC（蓝普资本有限责任公司）（“Lamp”），据称由债务人的儿子拥有的实体（见同上，第 ¶51 段）；以及 (vi) HK International Funds Investment (USA) Limited, LLC（香港国际基金投资〈美国〉有限责任公司）（“HK USA”），据称由债务人的女儿拥有的实体（见同上，第 ¶33 段）。\n\n19. 债务人曾表示，上述实体，或许连同其他实体，为债务人在媒体和社交媒体上炫耀的奢华生活方式提供资金。（例如，见同上，第 ¶17 段〔称其儿子通过 Golden Spring“满足[债务人]的需要”〕；同上，第 ¶23 段〔主张其女儿拥有 Lady May，一艘据称于 2015 年以 £41 million 购置的豪华游艇，且其儿子承担 Lady May 的维护费用〕；以及同上，第 ¶51 段〔指出其儿子通过 Lamp 为债务人最初的 chapter 11 破产案律师支付了 \\$1 million 预付律师费〕。）然而，债务人并未说明这些实体如何取得收入，亦未说明其为换取这些实体向其提供的资金而向其提供何种对价（如有）。\n\nb. 债务人可能拥有或控制的不动产及动产资产\n\n20. 除该等不透明的受控关联实体网络外，还存在大量不动产及动产资产——债务人本人曾向媒体夸耀其拥有这些资产——其亦可能构成破产财产。\n\n21. 例如，在 2017 年的一次采访中，当被问及其以何种方式开展反对中国共产党的运动是否令其后悔时，债务人表示：\n\n“我对过去九个月所做的一切绝无任何后悔。我拥有全世界每个人都梦想拥有的富裕生活。我拥有香港最大的房子，数千平方米。我拥有伦敦最豪华的公寓。我拥有北京最大的住所。我在盘古拥有十多处房产。我有两架私人飞机。我有最先进的游艇。我有数百辆赛车。我在纽约也有像这样的公寓。我已不再有任何物质需求。”\n\n（例如，见 Vice News（Vice 新闻），Exiled Chinese Billionaire Uses YouTube to Wage A War On Corruption，YOUTUBE，6:38-7:07（Nov. 15 2017）（着重号为后加）（可见于 http），下文称“Vice News Interview”）。4 值得注意的是，债务人从未就这些资产或其任何收益的去向作出可信解释——受托人认为，这一核心问题将通过受托人的调查获得答案，包括其对债务人及被审查人的审查。\n\n22. 与债务人本人的承认一致，其他法院已认定，尽管债务人在本案中提出相反的新近主张，某些资产实际上由债务人拥有。\n\n23. Lady May。经举行证据听证以确定谁拥有 Lady May 的受益所有权后，New York Supreme Court（纽约州最高法院）认定债务人受益拥有并控制 Lady May。（Final Contempt Order 第 9 页〔“证据以清楚且令人信服的程度表明，[债务人]持有 Lady May 的受益权益并控制 Lady May。”〕。）具体而言，法院在审查全部证据后，包括债务人的女儿及代表债务人的 HK International 律师提出的另外三名证人的长篇证词，认定“听证中由被告方证人亲口提供的证词，以清楚且令人信服的程度表明，Kwok 受益拥有并控制 Lady May，且对本院及司法程序抱有彻底蔑视。”（Final Contempt Order 第 4 页。）法院进一步表示，“简言之，Guo 女士关于其拥有并控制 Lady May 的证词在任何方面均不可信”，并且“Kwok 不仅控制该游艇，看来还是其提供了购买该游艇的资金，且其是主要享用该游艇的人。”（同上，第 6-8 页。）5\n\n24. Sherry Netherland Hotel Property。债务人可能同样拥有并控制位于 Manhattan（曼哈顿）Sherry Netherland Hotel（雪莉-荷兰酒店）的一套共管公寓，据称于 2015 年以约 \\$70 million 购置（下称“该共管公寓”）。债务人坚持称，该共管公寓由 Genever NY（Genever NY）拥有，且 Genever NY 通过 Bravo Luck（Bravo Luck）为其儿子以信托方式持有该共管公寓。（见 Debtor's Declaration，第 ¶33 段。）如上所述，Genever NY 本身由 Genever BVI（Genever BVI）拥有，而该实体由债务人拥有。（见同上。）\n\n25. 与 Lady May 类似，该共管公寓成为 Genever NY 于 October 2020 在 Southern District of New York（纽约南区）向 Honorable Judge James L. Garrity Jr.（尊敬的 James L. Garrity Jr. 法官）提起的独立 chapter 11 破产案中申请前诉讼的标的。（见 Case No. 20-12411 (Bankr. S.D.N.Y.)。）\n\n26. 受托人亦有理由相信，与购置该共管公寓相关的约 \\$2 million 保证金可能仍然存在。（见 ECF No. 77 第 7 页。）\n\n27. 其他不动产及动产。除上述事项外，债务人经常提及由其本人或其直系亲属拥有及控制的其他重大不动产和动产资产。例如：\n\n债务人坚持称，其妻子通过 Greenwich Land 拥有债务人位于 373 Taconic Road, Greenwich, Connecticut 06831 的住宅物业。\n\n（见 Debtor's Declaration，第 ¶¶ 6、17 段。）Greenwich Land 亦可能拥有位于 Greenwich, Connecticut 的另一处住宅物业，即 33 Ferncliff Rd。6\n\n- 债务人已声明，其拥有于 2019 年被 High Court of the Hong Kong Special Administrative Region, Court of First Instance（香港特别行政区高等法院原讼法庭）冻结的“数十亿” “资金和财产，包括香港的不动产”。（Debtor's Declaration，第 ¶17 段。）\n\n- 债务人还是 United Kingdom（英国）一宗诉讼中的共同原告，该诉讼涉及约 \\$500 million 的请求。7\n\n- 如上所述，在 2017 年的一次采访中，债务人夸耀其拥有的资产包括：(i)“香港最大的房子”；(ii)“伦敦最豪华的公寓”；(iii)“北京最大的住所”；(iv)“盘古十多处房产”；(v)两架私人飞机，8 以及 (vi)“数百辆赛车”。9\n\n- 特别是，受托人已查明可能与债务人使用和/或控制的私人飞机相关的“机尾编号”及一个序列号，并通过分析公开记录，确定了一家管理公司的身份；据认为，该管理公司曾运营且可能仍在运营其中一架或多架飞机。此外，受托人知悉，该管理公司曾一度出售债务人使用且可能拥有或控制的一架飞机。运营这些飞机的资金来源，以及该等飞机产生的任何价值（无论通过出售、租赁、包机或其他方式），可能进一步揭示债务人的财务状况。\n\n28. 拟议审查将有助于确定——并很可能确认——这些各项财产权益属于破产财产。受托人还认为，债务人就这些财产权益进行的交易——尤其是购置和维护该等权益的资金来源，以及其使用或处分所产生的任何价值——可能发现尚不为受托人所知、但可为破产财产提供价值的额外资产。\n\nc. 债务人在营利性及据称非营利性商业实体中的潜在财务权益\n\n29. 除债务人可能通过其家庭成员拥有的商业实体而拥有或控制的不动产及动产资产外，债务人还可能在营利性及据称非营利性商业实体中拥有重大财务或所有权权益（或负债），该等权益可能为破产财产及债权人提供重大价值。\n\n30. 例如，据报道，债务人在 Gettr USA, Inc.（Gettr USA, Inc.）（“Gettr”）中拥有财务权益，该公司是一个保守派社交媒体平台。（见 Will Sommer、Adam Rawnsley、A. Suebsaeng，Trumpworld App Is Bankrolled by Fugitive Chinese Billionaire，THE DAILY BEAST，http billionaire?ref=home（July 5, 2021, 12:19 PM）（last visited July 20, 2022）（报道“与该亿万富翁相关的网站曾暗示 Gettr 是[债务人]的构想”，并将 GTV 一名主持人的观点归于其言，该 GTV 是“作为[债务人]喉舌的媒体机构”，即 Gettr 是“‘[债务人]毕生全部事业的集中体现’”，并补充称“[债务人]构思了 Gettr 的标志，即一支火炬。”）；另见 The New York Times: Sway，Best Of: Jason Miller，第 30:15-30:35 分钟（July 18, 2022）（使用 Apple Podcasts 下载）（在被问及谁为 Gettr 提供资金时，Gettr CEO Jason Miller（Gettr 首席执行官 Jason Miller）答称：“我们有多个国际投资基金正在向其投入资金……Miles Kwok（郭文贵）的家族基金会是其最初资助者、最初赞助者之一。迄今已有超过 \\$50 million 投入该平台。[我们]目前银行中约有 \\$25-\\$30 million。”）。10\n\n31. 另有报道，Gettr 的工资单列有与“Himalaya Embassy（喜马拉雅大使馆）”相同的地址；该物业位于 Manhattan Upper East Side（曼哈顿上东区），以租赁方式取得，且亦与 New Federal State of China（新中国联邦）（“NFSC”）相关。NFSC 是债务人与 Steve Bannon（史蒂夫·班农）、前 President Donald J. Trump（唐纳德·J·特朗普前总统）的前首席战略师共同建立的、声称“致力于推翻[中国共产党]的流亡政府”。（见 Dan Friedman，A Fugitive Chinese Tycoon Met Steve Bannon. Misinformation Mayhem Ensued. The weird, wild, and scary tale of Miles Guo，Mother Jones（March-April 2022 Issue）（last visited July 21, 2022），http。）\n\n32. 据报道，债务人还拥有或控制由“60 多个商业、非营利及在线团体”构成的“网络”，统称为“爆料革命”。（见同上。）据称，其中至少两个非营利组织——Rule of Law Society（法治协会）和 Rule of Law Foundation（法治基金会）——为 NFSC 提供资金。（见同上。）据报道，截至 summer 2021，Rule of Law Society 和 Rule of Law Foundation 的“合计收入约为 \\$15 million。”（同上。）\n\n33. 债务人被指称的营利性和非营利性商业利益“网络”还可能包括以下实体或品牌：(i) “GCoin（G币）”，一种据称由债务人创建、用作 NFSC 货币的加密货币；(ii) “GFashion（G时尚）”，由债务人设计的服装系列；(iii) “GMusic（G音乐）”，一个推广债务人视频的音乐平台；(iv) “GClubs（G俱乐部）”，一项会员服务，提供“‘礼宾客户服务’以及对[债务人]时尚系列、音乐发行和年度 GSummit（G峰会）的特别访问”；(v) “GTV”，一个中文视频平台；(vi) “GNews（G新闻）”，一个“刊载总结[债务人]声明之文章”的新闻网站；11 (vii) Saraca Media（萨拉卡媒体），GNews 的母公司，据报道该公司还于 2018年5月向 Mr. Bannon（班农先生）支付了至少 \\$1 million 的咨询费；以及 (viii) Himalaya Supervisory Organization（喜马拉雅监督组织），其监管多个推广并崇拜债务人的在线聊天群，并向这些聊天群的成员提供“各种机制”向债务人汇款，包括通过一项贷款计划——该计划据称“承诺最终连本带息偿还，并有机会以折扣价投资于其他[债务人]事业”——以及购买 GTV 股票的方式。（见同上。）据称，GTV 股票机会筹集了 \\$114 million，而贷款计划筹集了“至少 \\$90 million”。（见同上。）\n\n10 在此次交流后不久，Miller（米勒）谨慎地区分了“Miles Kwok（郭文贵）的家族基金会”与 Miles Kwok 本人，称“Mr. Kwok 并未对 Gettr 进行任何直接金融投资”，而是称债务人为 Gettr 的“盟友”。（见同上，第 30:51-31:11 页。）\n\n34. 上述仅是债务人曾夸耀过或迄今由媒体报道过的部分商业利益和实体。可以合理推断，债务人可能与众多其他实体有关联，而这些实体的资产、负债和财务利益可能对受托人管理债务人的破产财产至关重要。\n\n35. 由于债务人可能是前述资产和利益以及其他可能尚不知悉的资产和利益的实际所有人，至关重要的是，第11章受托人应全面审查和调查债务人的破产财产资产，包括其家庭成员、其家庭成员的商业实体及其他第三方——包括代表债务人及其关联家族实体的律师事务所——在债务人财务状况方面所发挥的作用。\n\nIII. 顾问所持有的有关破产财产资产的信息\n\n36. 众多第三方，包括债务人的律师事务所、会计师事务所、金融公司及经纪公司，曾就多项商业交易及其他涉及可能与债务人破产财产管理相关的资产、负债或财务利益的事项，向债务人或关联实体及个人提供建议或服务。这些顾问很可能基于其与债务人的沟通以及其应债务人或他人要求所完成的工作，掌握可能对受托人调查具有重大重要性的信息。\n\n11 见同上。\n\n37. 受托人通过本申请，寻求从下列顾问处获取文件和信息：\n\nACASS CANADA LTD.（加拿大 ACASS 有限公司）似乎曾向债务人和/或关联人士提供服务，包括但不限于债务人的私人飞机。ACASS Canada Ltd. 曾在其网站上发布一份宣传册，似乎推销出售、租赁或包租一架据媒体报道由债务人拥有的私人喷气机。受托人还知悉，在该飞机由债务人拥有或维护期间，ACASS Canada Ltd. 可能曾运营该飞机或以其他方式就该飞机提供服务。\n\nBERKELEY ROWE（伯克利·罗）根据受托人审阅的文件，代表 Himalaya International Financial Group Ltd.（喜马拉雅国际金融集团有限公司），该实体向 HK USA 提供了 \\$37 million 贷款；该等资金依照法院于 April 29, 2022 批准的约定命令被存入托管账户 [ECF No. 299]。该等文件还显示，Berkeley Rowe 曾代表 ACA Capital Group Limited（ACA 资本集团有限公司）；在 HK USA 与 Himalaya International Financial Group Ltd. 签署贷款协议之前，该公司一度拟作为向 HK USA 提供 \\$37 million 贷款的贷款人。此外，在债务人之子 Qiang Guo（郭强）在 Genever US Chapter 11 Case（Genever 美国第11章案件）中提交的债权证明中，Berkeley Rowe 的地址被用作其地址。因此，Berkeley Rowe 很可能持有与可能构成破产财产的实体和资产相关的文件。\n\nCAHILL GORDON & REINDEL LLP（卡希尔·戈登与林德尔律师事务所）曾在 Securities and Exchange Commission（证券交易委员会）进行的一项调查中代表债务人和/或债务人的某些关联实体。因此，Cahill Gordon & Reindel LLP 很可能持有与债务人的财务状况及针对破产财产的潜在债权相关的文件。\n\nELLIOTT KWOK LEVINE & JAROSLAW LLP（艾略特·郭·莱文与雅罗斯拉夫律师事务所）在 Pacific Alliance Asia Opportunity Fund L.P.（太平洋联盟亚洲机会基金有限合伙企业）诉 Ho Wan Kwok（郭文贵）一案中代表 Lamp Capital（兰普资本），该案案号为 Index No. 652077/2017 (N.Y. Sup. Ct.)。自 May 10, 2022 起，该律师事务所取代 Phillips Nizer LLP——顾问2004动议项下的受审查人——担任 Lamp Capital 的备案代理律师。以此身份，其可能持有与受托人调查相关的文件。\n\nFORBES HARE（福布斯·黑尔）担任债务人在 British Virgin Islands（英属维尔京群岛）的律师；由债务人拥有或与债务人密切关联的若干实体，包括 Genever Holdings Corporation（Genever 控股公司）、Ace Decade Holdings Limited（艾斯十年控股有限公司）、Dawn State Limited（曙光州有限公司）及 Bravo Luck Limited（布拉沃幸运有限公司），均在该地注册成立。因此，Forbes Hare 很可能持有与受托人调查相关的文件。\n\nOGIER（奥吉尔）担任债务人之子及 Bravo Luck Limited 的英属维尔京群岛律师；Bravo Luck Limited 是一家据称由债务人之子控制的实体，声称持有位于曼哈顿 Sherry Netherland Hotel（谢里内德兰酒店）一套公寓的受益权益。因此，Ogier 很可能持有与受托人调查相关的文件。\n\nO'NEAL WEBSTER（奥尼尔·韦伯斯特）曾担任债务人之子及 Bravo Luck Limited 的英属维尔京群岛律师；Bravo Luck Limited 是一家据称由债务人之子控制的实体，声称持有位于曼哈顿 Sherry Netherland Hotel 的一套公寓的受益权益。因此，Ogier 很可能持有与受托人调查相关的文件。\n\nWILLIAMS & CONNOLLY LLP（威廉姆斯与康诺利律师事务所）曾于 2015 年协助债务人注册成立 Genever BVI 和 Genever NY，涉及购买该公寓。因此，Williams & Connolly 很可能持有与可能属于破产财产或持有破产财产的公司实体相关的文件。\n\nTROUTMAN PEPPER HAMILTON SANDERS LLP（特劳特曼·佩珀·汉密尔顿·桑德斯律师事务所）担任 Bravo Luck Limited 的律师；Bravo Luck Limited 是一家据称由债务人之子控制的实体，声称持有位于曼哈顿 Sherry Netherland Hotel 的一套公寓的受益权益；该所还曾担任 Eastern Profit Corporation Limited（东方利润有限公司）的律师，该公司很可能是债务人的空壳实体。因此，Troutman Pepper Hamilton Sanders LLP 很可能持有与受托人调查相关的文件。\n\nYACHTZOO SARL（游艇动物园有限责任公司）担任 Lady May（“梅夫人”号）游艇的游艇管理公司；New York Supreme Court（纽约州最高法院）认定债务人享有该游艇的受益所有权并对其实施控制。见 Decision + Order on Motion*, Pacific Alliance Asia Opportunity Fund L.P. v. Ho Wan Kwok*, Index No. 652077/2017 (N.Y. Sup. Feb. 9, 2022)。此外，自 2021 年起，Yachtzoo SARL 与 HK International Funds Investments (USA) Limited, LLC（一家据称由债务人女儿拥有的实体）一直是就 Lady May 签订的管理合同的当事方，且 Yachtzoo SARL 为 Lady May 及其船员提供财务管理、技术支持和管理、安全管理以及人力资源服务。\n\n38. 大多数顾问均为债务人或与其密切关联的实体提供法律或财务咨询，因此很可能持有或控制可能促成识别和/或追回已知及尚待识别的破产财产资产的证据。其他顾问曾就重大资产，即 Lady May 以及债务人曾使用且破产财产可能享有权益的私人飞机，向债务人或密切关联的实体或家庭成员提供管理及其他服务，并可能提供经纪服务。\n\nIV. 关联人士所持有的有关破产财产资产的信息\n\n39. 包括法院裁判和媒体报道在内的公开记录，充斥着有关债务人家庭成员、债务人的密切顾问以及该等个人声称控制的实体的信息；该等人员在债务人的商业活动及其他涉及可能与债务人破产财产管理相关的资产、负债或财务利益的行为中，发挥着关键作用。\n\n40. 受托人通过本申请，寻求从下列关联人士处获取文件和信息：\n\nACA CAPITAL GROUP LIMITED 是一家由 Berkeley Rowe 代表的实体。根据受托人持有的文件，该实体原拟作为向 HK USA 提供 \\$37 million 贷款的贷款人，但其后由 Himalaya International Financial Group Ltd. 取代成为贷款人。此外，ACA Capital Group Limited 还以其他方式与债务人有关联，包括在债务人与 PAX 于纽约州最高法院进行的破产申请前诉讼中，支付债务人律师 Hodgson Russ LLP（霍奇森·拉斯律师事务所）的费用。\n\nHIMALAYA INTERNATIONAL FINANCIAL GROUP LTD. 是一家与债务人存在公开关联的实体，曾向 HK USA 提供 \\$37 million 贷款；该等资金依照法院于 April 29, 2022 批准的约定命令被存入托管账户 [Docket 299]。此外，Himalaya International Financial Group Ltd. 被认定为一种名为 “Himalaya Coin（喜马拉雅币）”或 “H-Coin（H币）”的加密货币的发行人，该加密货币曾由债务人在互联网上大力推广。Himalaya International Financial Group Ltd. 对 Himalaya Coin 的发行，是通过与 Himalaya International Clearing Ltd.（喜马拉雅国际清算有限公司）的业务关系进行的；后者发行相关的 “Himalaya Dollar（喜马拉雅元）”加密货币，其首席执行官被认定为 Jesse Brown（杰西·布朗）。此外，受托人认为，Himalaya International Payments Ltd.（喜马拉雅国际支付有限公司）和 Himalaya International Reserves Ltd.（喜马拉雅国际储备有限公司）实体也参与该加密货币业务。\n\nWILLIAM JE（威廉·杰）是一名据报道现任或曾任债务人商业伙伴的个人，包括与债务人的 Himalaya Coin 加密货币业务有关的商业伙伴。\n\nMAX KRASNER（马克斯·克拉斯纳）是一名与数个与债务人有关联的实体相关的个人。除其他事项外，Mr. Krasner 于 April 2020 在 Delaware（特拉华州）注册成立了 GTV Media Group Inc.（GTV 媒体集团公司），并且现任或曾任 Rule of Law Foundation III, Inc.（法治基金会 III 公司）的高级管理人员及董事；该实体声称为与债务人有关联的非营利实体。\n\nV. 相关银行所持有的信息\n\n41. 据向受托人报告，债务人连同与债务人有关联的实体和个人，曾在多家银行机构开展业务，其中可能包括本申请中所述的关联人士和交易。因此，受托人认为，这些银行机构可能持有与债务人的商业活动及其他涉及可能与债务人破产财产管理相关的资产、负债或财务利益的行为有关的信息和文件，并可能持有债务人的资产。这些银行如下：\n\nBARCLAYS BANK PLC（巴克莱银行公众有限公司）\n\nBNY MELLON, N.A.（纽约梅隆银行，全国协会）\n\nCITIBANK, N.A.（花旗银行，全国协会）\n\nHSBC HOLDINGS PLC（汇丰控股公众有限公司）\n\nJPMORGAN CHASE BANK, N.A.（摩根大通银行，全国协会）\n\nSTANDARD CHARTERED PLC（渣打银行公众有限公司）\n\nUBS AG（瑞银集团股份公司）\n\n管辖权和审判地\n\n42. 本院根据 28 U.S.C. §§ 157 和 1334 对审理本申请具有管辖权。根据 28 U.S.C. §§ 1408 和 1409，本申请的审理地点适格。\n\n43. 本申请为一项核心程序，依据包括但不限于 28 U.S.C. § 157(b)(2) (A)、(E) 和 (F)。\n\n请求的救济\n\n44. 受托人请求本院根据 Bankruptcy Rule 2004(a) 和 Local Rule 2004-1，以与拟议命令实质上相同的形式作出命令，授权受托人对附件 B 所列受审查人进行审查。\n\n请求救济的依据\n\n45. 根据 Rule 2004(a)，经利害关系方申请，本院可命令对任何个人或实体进行审查。根据 Rule 2004 获准的审查范围极其广泛，并可涉及“债务人的作为、行为或财产，或债务人的负债及财务状况，或可能影响债务人破产财产管理的任何事项。”Fed. R. Bankr. P. 2004(b)。\n\n46. “Rule 2004 审查的目的在于协助利害关系方确定破产财产的性质和范围、揭示资产、审查交易，以及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)（省略内部引文及援引）。这包括揭示破产财产的性质和范围，以及发现可能被故意或非故意隐瞒的债务人资产。参见 In re Bennett Funding Group, Inc., 203 B.R. 24, 27-28 (Bankr. N.D.N.Y. 1996)。另参见 In re Millennium Lab Holdings II, LLC, 562 B.R. 614, 626 (Bankr. D. Del. 2016)（“Rule 2004 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。”（省略内部引文及援引））。\n\n47. 债务人在其于 March 20, 2022 提交、支持本案立案的声明中表示，其提起第 11 章案件的目的包括“……（b）鉴于其认为在该等方面存在误解，为利害关系方提供一个有效机会，以调查[其]资产、负债和财务事务；[以及]（c）确定哪些资产属于破产财产，并进而可供向获准债权持有人分配……。”（债务人声明，第 3 段）。受托人拟进行的调查与这些既定目的直接相关，因为其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\n48. 根据所请求对受审查人进行的审查，初步调查领域显而易见。基于上述讨论的全部事实和证据——包括债务人本人多次公开声明及其他法院过去作出的认定——受托人已识别出债务人的多个公司实体及不动产和动产资产，这些资产可能为破产财产提供重大价值。然而，受托人需要 Rule 2004 所提供的调查工具，以进一步确定这些资产的真实所有权，并探查受托人尚未知悉的其他潜在资产。\n\n49. 为推进其审查，受托人请求本院命令受审查人于传票送达后 thirty (30) 日内，或于受托人同意的其他期限内，按照附于本申请并构成本申请一部分的表格12所请求的内容，向受托人律师提供与拟议传票实质上在形式和内容上相同的文件（“拟议传票”）。这些请求寻求的文件包括但不限于受审查人与债务人就其财务状况、资产转让及公司治理问题进行的通信。该等请求还寻求受审查人就同一等事项的内部文件和通信。13\n\n12 附件 B 包括一份拟议传票索引，如本动议获准，该等传票将向受审查人送达。受托人还将针对各受审查人的个别拟议传票作为附件 C-1 至 C-25 附于本申请，其中包括针对各受审查人的取证事项，且该等传票在形式和内容上实质相同。\n\n13 Lady May 是受托人寻求取证的事项及潜在破产财产资产之一。受托人主张，尽管目前就 Lady May 的所有权尚有一项对抗程序待决，但根据 Rule 2004 进行该等取证仍属适当。受托人拟议的与 Lady May 相关的取证，涉及债务人为逃避其债权人所采取的整体行为模式，因此其范围广于在该对抗程序中可能寻求的取证。鉴于受托人另正在向同一方就其他事项寻求 Rule 2004 取证，由受托人现在进行该等取证对所有当事方亦更有效率——若要求受托人向该等相同当事方进行两次取证，将缺乏效率。此外，这并非对抗程序原告通过 Rule 2004 寻求削弱《破产规则》就对抗程序中的取证所提供保护的典型情形。事实上，即使待决程序原则适用（其并不适用），该原则也不会阻止受托人向并非有关 Lady May 的对抗程序当事方的个人或实体寻求 Rule 2004 取证。最后，鉴于该对抗程序的程序进展情况，受托人目前可能无法在该程序中取得取证。然而，受托人现在需要其 Rule 2004 取证，以充分保护和保存潜在的破产财产资产。\n\n50. 受托人将从受审查人取得的取证类型完全属于 Bankruptcy Rule 2004 的范围。破产法院通常准许针对专业机构的 Rule 2004 取证，前提是该取证可能识别资产并有助于为破产财产和债权人的利益追回资产。参见，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)（批准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增加债务人破产财产的价值）。\n\n51. 受托人主张，上述事实构成充分理由，使本院命令受审查人根据 Rule 2004 提供文件。尽管债务人是帮助受托人发现破产财产资产所需信息和文件的必要来源，但向包括受审查人在内的其他方寻求取证，很可能会显著减少破产财产为识别和追回破产财产所原本需承担的费用。事实上，律师及其他专业人士在资产转让、法人实体设立及其他公司治理问题，以及债务人的财务状况方面，具有独特的信息获取地位。因此，受审查人持有的文件可能是对受托人调查最有价值的文件之一。\n\n52. 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的资产”以及“调查债务人的资产、负债和财务事务”的职责。（见《受托人命令》第 15-16、18 页）。\n\n53. 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\n无先前请求\n\n54. 此前未曾就本申请所请求的救济提出申请。债务人曾提交先前的 2004 动议，本院已予准许；然而，该等先前动议并未请求向本案所涉受审查人进行取证。\n\n异议期限\n\n55. 对本申请提出异议的期限为 September 15, 2022；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[本页其余部分特意留白。]\n\n因此，受托人谨此请求本院根据 Fed. R. Bankr. P. 2004(a) 批准本申请并作出拟议命令，命令对受审查人进行审查，并命令提供拟议传票所附《文件提供请求》中所列的特定文件，以及本院认为公正和适当的其他及进一步救济。\n\n日期：September 7, 2022 LUC A. DESPINS（吕克·A·德斯平斯），\n\nNew Haven, Connecticut 第 11 章受托人\n\n代理人：/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\n附件 A——拟议命令\nUNITED STATES BANKRUPTCY COURT（美国破产法院）DISTRICT OF CONNECTICUT（康涅狄格地区）BRIDGEPORT DIVISION（布里奇波特分部）\n\n----------------------------------------------------------- x\n\n关于： ：\n：\n第 11 章\nHO WAN KWOK（郭文贵）， ：\n：\n案号 22-50073 (JAM)\n债务人。1 ：\n\n---------------------------------------------------------- x [拟议]命令\n准许第 11 章受托人提出的第一份补充综合动议，即请求根据《破产规则》2004 和地方法规 2004-1 作出命令，授权就债务人的其他法律和财务顾问、与债务人关联的实体和个人，以及相关银行进行取证\n\n经审议 Luc Despins（吕克·德斯平斯）作为获任命的债务人破产财产第 11 章受托人（“申请人”）所提交的申请，该申请请求作出命令，授权根据 Federal Rule of Bankruptcy Procedure 2004 对其附件 B 所列受审查人进行审查（“本申请”，ECF No. 637）；在通知和听证后，参见 11 U.S.C. § 102(1)；本院认定存在按下文条件准许所请求救济的理由；现据此命令：\n\n命令：如下文所述，准许该 Rule 2004 动议。\n\n命令：NEUBERT, PEPE & MONTEITH, P.C. 作为受托人律师，现获授权签署在形式上与作为该 Rule 2004 动议附件 C-1 至 C-25 所附传票实质相同的传票，并依照 Bankruptcy Rule 2004 向本申请附件 B 所列受审查人送达该等传票及本命令，要求其接受审查并提供文件。\n\n命令：在不影响根据 Federal Rules of Bankruptcy Procedure、Federal Rules of Civil Procedure 及适用地方法规享有的任何权利，并除非本院另有命令外，现命令受审查人于传票送达后 30 日内，或于受托人同意的其他期限内，提供全部文件。如受审查人基于某项特权而未提供传票所请求的任何文件，现命令该受审查人于传票送达后 30 日内，或于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 适用以及 D. Conn. L. Civ. R. 26(e) 的特权日志。\n\n1 尽管债务人的法定姓名为 Ho Wan Kwok（郭文贵），其亦被称为 Guo Wengui、Miles Guo 和 Miles Kwok，以及诸多其他别名。债务人纳税人识别号码的后四位为 9595。\n\n命令：现命令受审查人确保所有在传票中请求的或以其他方式与债务人、其业务、资产、负债、财务状况或本第 11 章案件相关的文件及其他信息，包括但不限于任何电子格式的信息，均得到妥善保存，可供提供、查阅和复制，且不被毁坏。\n\n命令：现授权Neubert, Pepe & Monteith, P.C.（纽伯特、佩佩及蒙泰思律师事务所）作为受托人的律师，无须本院进一步命令，即可依《破产程序规则》2004，在Neubert, Pepe & Montheith位于195 Church Street, 13th Floor, New Haven, CT 06510的办公室、Paul Hastings LLP（保尔·黑斯廷斯律师事务所）位于200 Park Avenue, New York, NY 10166的办公室，或在当事人双方均可接受的其他地点，于受托人可接受的日期，对申请书附件B所列任何被审查人的一名或多名代表进行《破产程序规则》2004项下的审查并取得其证言；由受托人选择，该日期应不早于拟议被审查人依传票及本命令并根据《破产程序规则》2004完成文件提交后14个日历日；该审查应逐日持续至完成为止。\n\n日期：____________, 2022\n\nJulie A. Manning（朱莉·A·曼宁），\n\n____________________________________________\n\n美国破产法院法官\n\n附件B——被审查人名单\n\n取证当事人 地址 传票索引\n\nHIMALAYA\nINTERNATIONAL\nFINANCIAL GROUP\nLTD.（喜马拉雅国际金融集团有限公司） Himalaya International Financial Group Ltd.\n转交 Arias, Fabrega & Fabrega\nTrust Co. BVI\nLimited\nP.O. Box 985\nRoad Town, Tortola, BVI 附件C-1\nHIMALAYA\nINTERNATIONAL\nCLEARING LTD.（喜马拉雅国际清算有限公司） Himalaya International Clearing Ltd.\n转交 Commerce House\nWickhams Cay 1\nP.O. Box 3140\nRoad Town\nTortola VG1110 British Virgin Islands 附件C-2\nHIMALAYA\nINTERNATIONAL\nPAYMENTS LTD（喜马拉雅国际支付有限公司） Himalaya International Payments Ltd.\n转交 Commerce House\nWickhams Cay 1\nP.O. Box 3140\nRoad Town\nTortola VG1110 British Virgin Islands 附件C-3\nHIMALAYA\nINTERNATIONAL\nRESERVES LTD.（喜马拉雅国际储备有限公司） Himalaya International Reserves Ltd.\n转交 Commerce House\nWickhams Cay 1\nP.O. Box 3140\nRoad Town\nTortola VG1110 British Virgin Islands 附件C-4\nJESSE BROWN（杰西·布朗） Jesse Brown\n转交 Arias, Fabrega & Fabrega Trust Co. BVI\nLimited\nP.O. Box 985\nRoad Town, Tortola, BVI\nJesse Brown\n转交 Commerce House,\nWickhams Cay 1\nP.O. Box 3140\nRoad Town\nTortola VG1110 British Virgin Islands 附件C-5\nACA CAPITAL GROUP\nLIMITED（ACA资本集团有限公司） ACA Capital Group Limited\nRm 1605, 16/F\nHua Qin International Bldg,\n340 Queen's Rd C,\nSheung Wan,\nHong Kong SAR\nACA Capital Group Limited\n3a Montagu Row\nMarylebone 附件C-6\n\n取证当事人 地址 传票索引\n\nLondon\nW1U 6DZ United Kingdom\nWILLIAM JE（威廉·杰） William Je\n162 East 64th Street\nNew York, NY 10065\nWilliam Je\n转交 Corporate Creations Network Inc.\n3411 Silverside Road\nTatnall\nBuilding, Ste 104\nWilmington, Delaware 19810 附件C-7\nMAX KRASNER（马克斯·克拉斯纳） Max Krasner\n162 E. 64th Street\nNew York, NY 10605 附件C-8\nACASS CANADA LTD.（ACASS加拿大有限公司） ACASS Canada Ltd.\n6700 Côte de Liesse\nSuite 206\nMontréal H4T 2B5 Canada 附件C-9\nYACHTZOO SARL（游艇动物园有限公司） Yachtzoo SARL\nLe Beau Rivage\n9 Avenue d'Ostende\nMC 98000 Monaco 附件C-10\nBERKELEY ROWE（伯克利·罗有限公司） Berkeley Rowe Limited\n20 North Audley Street\nMayfair, London W1k 6WE United Kingdom\nGeoffrey Yussouf（杰弗里·尤苏夫）\nBerkeley Rowe Limited\n5 Merchant Square\nLondon, W2 1AY United Kingdom 附件C-11\n\n取证当事人 地址 传票索引\n\nCAHILL GORDON &\nREINDEL LLP（卡希尔·戈登与林德尔律师事务所） Cahill Gordon & Reindel LLP\n32 Old Slip\nNew York, NY 10005 附件C-12\nELLIOTT KWOK\nLEVINE & JAROSLAW\nLLP（艾略特·郭、莱文与雅罗斯拉夫律师事务所） Matthew Levine, Esq.（马修·莱文律师）\nElliott Kwok Levine & Jaroslaw LLP\n565 Fifth Avenue\nNew York, NY 10017 附件C-13\nWILLIAMS & CONNOLLY\nLLP（威廉斯与康诺利律师事务所） Jerry Shulman, Esq.（杰里·舒尔曼律师）\nWilliams & Connolly LLP\n680 Maine Avenue SW\nWashington, DC 20024 附件C-14\nTROUTMAN PEPPER\nHAMILTON SANDERS LLP（特劳特曼·佩珀·汉密尔顿·桑德斯律师事务所） Francis J. Lawall, Esq.（弗朗西斯·J·拉沃尔律师）\nTroutman Pepper Hamilton Sanders LLP\n3000 Two Logan Square\nPhiladelphia, PA 19103\nJoanna J. Cline, Esq.（乔安娜·J·克莱因律师）\nTroutman Pepper Hamilton Sanders LLP\n3000 Two Logan Square\nPhiladelphia, PA 19103 附件C-15\nFORBES HARE（福布斯·黑尔） Robert Nader（罗伯特·纳德）\nForbes Hare\nQwomar Building\n4th Floor\nBlackburn Highway\nRoad Town,\nTortola\nBritish Virgin Islands\nVG1110 附件C-16\nOGIER（奥杰尔） Ogier\nRitter House\nWickhams Cay II\nPO Box 3170\nRoad Town, Tortola\nBritish Virgin Islands VG1110 附件C-17\n\n取证当事人 地址 传票索引\n\nO'NEAL WEBSTER（奥尼尔·韦伯斯特） O'Neal Webster\nCommerce House\n181 Main Street\nP.O. Box 961\nRoad Town, Tortola\nBritish Virgin Islands\nVG1110 附件C-18\nBARCLAYS BANK PLC（巴克莱银行公众有限公司） Barclays Bank PLC\n转交 Corporation Service Company\n251 Little Falls Drive\nWilmington, DE 19808\nPaul H. Compton（保罗·H·康普顿）\nBarclays Bank PLC\n1 Churchill Place\nLondon, Greater London E14 5HP\nUnited Kingdom 附件C-19\nBNY MELLON, N.A.（纽约梅隆银行，全国协会） Jane Kevin McCarthy（简·凯文·麦卡锡）\nBNY Mellon, N.A.\nBNY Mellon Center\n500 Grant Street\nPittsburgh, PA 15219 附件C-20\nCITIBANK, N.A.（花旗银行，全国协会） Citibank, N.A.\n转交 The Corporation Trust Company\nCorporation Trust Center\n1209 Orange Street\nWilmington, DE 19801\nCitibank, N.A.\n转交 CT Corporation System\n28 Liberty Street\nNew York, NY 10005\nBrent J. McIntosh（布伦特·J·麦金托什）\nCitibank, N.A.\n388 Greenwich Street\nNew York, NY 10013 附件C-21\nHSBC HOLDINGS PLC（汇丰控股公众有限公司） HSBC Holdings PLC\n转交 The Corporation Trust, Incorporated\n2405 York Road, Suite 201\nLutherville Timonium, MD 21093\nHSBC Holdings PLC\n转交 Office of the General Counsel\n95 Washington Street\nBuffalo, NY 14203 附件C-22\n\n取证当事人 地址 传票索引\n\nMark A. Steffensen（马克·A·斯特芬森）\nHSBC Holdings PLC\n452 Fifth Avenue\nNew York, NY 10018\nJPMORGAN CHASE\nBANK, N.A.（摩根大通银行，全国协会） JPMorgan Chase Bank, N.A.\n转交 CT Corporation System\n4400 Easton Commons Way\nSuite 125\nColumbus, OH 43219\nStacey Friedman（斯泰西·弗里德曼）\nJPMorgan Chase Bank, N.A.\n1111 Polaris Parkway, Suite 0460\nColumbus, OH 43240\nJPMorgan Chase Bank, N.A. 附件C-23\nSTANDARD\nCHARTERED PLC（渣打银行公众有限公司） Standard Chartered PLC\n1095 Avenue of the Americas\nNew York, NY 10036 附件C-24\nUBS AG（瑞银集团股份公司） UBS AG\nHong Kong Branch\n52/F., Two International Finance Centre\n8 Finance Street\nCentral, Hong Kong 附件C-25\n附件C-1至C-25——向被审查人发出的传票及文件请求\n附件C-1\n\nB2540（表格2540——规则2004审查传票）（12/15）Case 22-50073 Doc 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 34 of 491\nUNITED STATES BANKRUPTCY COURT（美国破产法院）\n\n________________________________________________ District of ________________________________________________ Connecticut\n\n关于 ________________________________________________________________\n\nCase No. ______________________________ Ho Wan Kwok（郭文贵）22-50073\n\n债务人\n\nChapter __________________ 11\n规则2004审查传票\n\n致：________________________________________________________________________________________________ Himalaya International Financial Group Ltd.\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、日期及地点出席，并在《联邦破产程序规则》规则2004项下的审查中作证。随附授权该审查的法院命令副本。\n\n地点 日期和时间\n\nPaul Hastings LLP\n200 Park Avenue\nNew York, New York 10166\n\n审查将以以下方式记录：____________________________________________________________ 法庭记录员/速记员\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，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《文件出示请求》。\n\n《联邦民事诉讼规则》规则45的下列规定，依据《联邦破产程序规则》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)；有关你作为受传票约束之人所受保护的规则45(d)；以及有关你回应本传票的义务及未如此做的潜在后果的规则45(e)和45(g)。\n\n日期：September __________ __, 2022\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 Patrick R. Linsey（帕特里克·R·林齐，ct29437）\n\n代表（当事人姓名）______________________________，签发或请求本传票的律师之姓名、地址、电子邮件地址及电话号码如下：Luc Despins（卢克·德斯平斯），第11章受托人\n\nPatrick R. Linsey, Esq.; Neubert, Pepe & Monteith, P.C.; 195 Church Street, New Haven, Connecticut 06510 plinsey@npmlaw.com; 203-821-2000\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之人送达前，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文件出示请求\nI. 指示\n\n1. 除非另有说明，下列文件请求（以下简称“请求”，每项单称“一项请求”）必须分别且具体地予以答复。每项请求均应得到完整答复，除非对此提出善意异议；如提出异议，应如下文所述详细说明你提出异议的理由。如异议仅涉及一项请求的一部分，或其中所载的一个词、短语或条款，你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。\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，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。不得将文本纳入.DAT文件。对于含有原生文件的文件，必须包括LINK字段，以提供文件路径及\n\n原生文件的名称。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相链接。该文件应为逗号分隔的文件，每行包含七个字段，并且数据库中的每一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. 文档文本。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。建议按 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的文件夹中，且每个文件夹中的文本文件数量不得超过 1,000 个。文件夹名称中不得包含特殊字符（包括逗号）。文本文件必须按文档级别提供。\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 编号的隔页图像，表明存在原生文件，并将该原生文件的路径作为字段包含在 .dat 文件中。所提供的原生文件应以与该文件隔页对应的 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。对于存在完全重复件的每一电子文档，仅提供一份副本。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。应以符合 Concordance 要求的加载文件（.dat）形式，为每一文档提供提取的元数据。.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独立字段。以下所列为必需元数据：\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\n对于单页文件，应填写 LASTBATES 字段\n\nATTACHRANGE EDC0000001 - EDC0000015 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\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：该电子邮件所在的邮箱。原生文件：该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。原生文件：文档作者。多个条目应使用分号分隔\n\nTO Coffman, Janice; LeeW [mailto:LeeW@MSN.com] 收件人。多个条目应使用分号分隔\n\nCC Frank Thompson [mailto:frank_Thompson@cdt.com] 抄送收件人。多个条目应使用分号分隔\n\nBCC John Cain 密送收件人。多个条目应使用分号分隔\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：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/电子邮件标准化所采用时区中的时间\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 指向电子邮件或原生文件文档的超链接。链接文件必须按 FIRSTBATES 编号命名\n\nFILE_EXTEN MSG 表示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\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，单位为 KB\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：原生文件文档的存储路径，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。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. 所有文件均应按通常业务过程中保存的方式提供，或者应进行组织和标注，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，包括您的律师或其他代表及顾问。每一文件均应完整提供。\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（以及，如适用，识别该文件发送给的人员）；(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交他人，或 (iv) 以其他方式处置；(e) 说明该等处置的原因以及相关事实和情形；(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，则说明该等人员身份，并说明该等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)，就每一基于特权主张而被扣留的文件，提供一份载有本指示第 (a) 部分所要求全部信息的特权清单。\n\n9. 如原本应予提交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) 在知悉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) 提交根据以下规定所要求的任何其他文件。\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. 对实体的一切提述均包括其所有关联方。\n\n13. 对个人姓名的一切提述均包括所有其他名称、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性或选择性用法，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下列含义：\n\n1. “您”或“您的”或“您本人”是指 Himalaya International Financial Group Ltd.，连同其所有关联方、部门、机构、工具、处室、办事处、合伙人、高级职员、董事、代理人、律师、代表、雇员，及/或代表其行事的任何人。\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，或任何其他化名），连同其雇员、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）（又名 Mileson Kwok、郭强，或任何其他化名），连同其雇员、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）（又名 Mei Gui、郭美，或任何其他化名），连同其雇员、代理人、律师、顾问或代表其行事的任何人。\n\n5. “债务人所谓之妻”是指 Hing Chi Ngok（岳庆芝）（又名 Hing Chi Ng、Yue Qingzhi、岳庆芝，或任何其他化名），连同其雇员、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，统称债务人、债务人之子、债务人之女、债务人据称的妻子，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，单独及合称所有：(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的个人；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其关联的个人，以及前述任何人员各自的雇员、代理人、法律顾问、顾问或代表其行事的任何人。此类关联个人包括但不限于：Daniel Podhaskie（丹尼尔·波德哈斯基）、Jason Miller（杰森·米勒）、Steve Bannon（史蒂夫·班农）、Karin Maistrello（卡琳·迈斯特雷洛）、Melissa Francis（梅丽莎·弗朗西斯）、William Gertz（威廉·格茨）、Arethusa Forsyth（阿雷图萨·福赛思）、Glenn Mellor（格伦·梅勒）、Jennifer Mercurio（詹妮弗·梅尔库里奥）、Eduardo Eurnekian（爱德华多·埃尔内基安）、Han Chunguang（韩春光，亦称韩春光）、Qu Guojiao（屈国姣，亦称Qu Guo Jiao、屈国姣）、Guo Lijie（郭丽杰，亦称郭丽杰）、Zhang Wei（张伟，亦称张伟*）、Lihong Wei Lafrenz（魏丽红·拉弗伦茨，亦称Sara Wei、魏丽红）、Hao Haidong（郝海东，亦称郝海东）、Ross Heinemeyer（罗斯·海内迈耶）、Max Krasner（马克斯·克拉斯纳）、Kyle Bass（凯尔·巴斯）、Melissa Mendez（梅丽莎·门德斯）、Ya Li（李娅，亦称李娅）、Dinggang Wang（王定刚，亦称王定刚）、An Hong（安红，亦称安红）、Yvette Wang（王雁平，亦称Yanping Wang、Yan Ping Wang、王雁平）、Fiona Yu（菲奥娜·余）、Je Kin Ming（余建明，亦称William Je、Yu Jianming、余建明）、Yaz Qingua（亚兹·青瓜）及Lao Jiang（老姜，亦称Jiang Yunfu、Jiang Yunfu Be、姜云浮）。\n\n8. “关联实体”系指，单独及合称所有：(1) 曾由债务人或债务人家属拥有、控制或投资的任何类型组织或实体；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的任何类型组织或实体，以及前述任何实体各自的雇员、代理人、法律顾问、顾问或代表其行事的任何人。此类关联实体包括但不限于：7 Nod Hill LLC（7诺德希尔有限责任公司）、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（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）、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（阿尔卑斯受托人股份公司）、Anton Development Limited（安东开发有限公司）、Assets Sino Limited（中资资产有限公司）、Auspicious Coast Limited（吉祥海岸有限公司）、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）、Bravo Luck Limited（幸运布拉沃有限公司）、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（克兰咨询集团有限责任公司）、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（黎明国度有限公司）、Eastern Profit Corporation Limited（东方利润有限公司）、Elite Well Global Limited（精英全球有限公司）、Empire Growth Holdings（帝国增长控股）、G Club Operations LLC（G俱乐部运营有限责任公司）、G Fashion LLC（G时尚有限责任公司）、G News LLC（G新闻有限责任公司）、GETTR USA（GETTR美国）、Genever Holdings Corporation（杰内弗控股公司）、Genever Holdings LLC（杰内弗控股有限责任公司）、GFASHION MEDIA GROUP INC.（GFASHION媒体集团公司）、GFNY, Inc.（GFNY公司）、Globalist International Limited（全球主义者国际有限公司）、GNews Media Group Inc.（GNews媒体集团公司）、Golden Spring (New York) Ltd.（金泉〈纽约〉有限公司）、Greenwich Land LLC（格林尼治土地有限责任公司）、Guo Media（郭媒体）、GTV Media Group, Inc.（GTV媒体集团公司）、Hamilton Capital Holdings Inc.（汉密尔顿资本控股公司）、Head Win Group Limited（领赢集团有限公司）、Henan Yuda（河南豫达）、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 Supervisory Organization（喜马拉雅监督组织）、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）、Infinite Increase Limited（无限增长有限公司）、Infinitum Developments Limited（无限发展有限公司）、Insight Phoenix Fund（洞见凤凰基金）、Lamp Capital LLC（蓝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）、Long Gate Limited（长龙门有限公司）、Next Tycoon Investments Limited（下一大亨投资有限公司）、New Federal State of China（中国新联邦国，亦称NFSC）、Noble Fame Global Limited（高贵名望全球有限公司）、Rosy Acme Ventures Limited（玫瑰顶峰创投有限公司）、Rule of Law Foundation III, Inc.（法治基金会III公司）、Rule of Law Foundation IV, Inc.（法治基金会IV公司）、Rule of Law Fund（法治基金）、Rule of Law Society（法治协会）、Rule of Law Society IV, Inc.（法治协会IV公司）、G-Translators PTY LTD（G翻译服务有限公司）、Saraca Media Group, Inc.（萨拉卡媒体集团公司）、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）、Spirit Charter Investment Limited（精神宪章投资有限公司）、Stevenson, Wong & Co.（史蒂文森、黄氏律师事务所）、Voice of Guo Media, Inc.（郭媒体之声公司）、Well Origin Ltd.（优良起源有限公司）、World Century Limited（世界世纪有限公司）、Worldwide Opportunity Holdings Limited（全球机遇控股有限公司）、Whitecroft Shore Limited（怀特克罗夫特海岸有限公司）及ZIBA Limited（ZIBA有限公司）。\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”，并应为最大限度扩大其范围而按合取及析取两种含义解释。\n\n11. “任何”及“全部”和“每一”系指“每一及全部”。\n\n12. “每一”及“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”应具有《破产法》第101(54)条赋予该词的含义。\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、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、头寸报告、摘要、索引、账簿、分类账、笔记本、清单、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文件的草稿或副本，如其载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相同。\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、减损、位于其中、结合其考虑、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、构成及为之。\n\n19. 当“与……有关”、“涉及”或“相关”用于指称任何特定事项时，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\n20. “通信”系指以最广泛的可能含义且不限于任何信息或知识的传递（以事实、构想、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，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、电话传真、传真副本、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，并预计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、投资权利或未来收益权、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经济机会。\n\n22. “转让”应具有《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、债务人财产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发生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、账户报表、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\n4. 关于债务人作出、与债务人进行或代表债务人作出的任何投资、商业交易或其他交易的所有文件。\n\n5. 与债务人的所有通信，以及与债务人的通信有关、涉及任何实体（包括但不限于关联实体）运营、管理或决策的文件。\n\n6. 关于向债务人、债务人家属或关联实体作出、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Lady May（梅夫人号）；Sherry Netherland Hotel / Condominium（雪莉荷兰酒店／公寓）；位于Connecticut（康涅狄格州）Greenwich（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；以及位于康涅狄格州Wilton（威尔顿）354 Nod Hill Rd.的住宅物业。\n\n8. 与债务人、债务人家属或关联实体于2020年7月前后或任何其他时间进行的任何原油期货或任何类似商品投资或交易有关的所有文件，包括但不限于与Jiang Yunfu Be（姜云浮·贝）就任何此类投资或交易进行的通信。\n\n9. 与债务人拥有、控制或使用的任何航空器有关的所有文件，包括但不限于机尾编号为T7-GQM的航空器及任何其他在San Marino（圣马力诺）登记的航空器，包括但不限于所有登记文件副本及显示该等航空器所进行航班和该等航班机上人员的飞行清单。\n\n10. 关于向债务人、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、就任何贷款作出的所有陈述和保证、任何贷款的利率及任何贷款付款的所有证据的文件。\n\n11. 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的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时间、设立人、受益人及信托本金的文件。\n\n12. 与涉及债务人的任何法律争议有关的任何义务、权利主张、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\n13. 您的任何外聘律师或其他顾问与债务人之间的所有文件及通信。\n\n14. 足以显示您的全部资产以及收入或资金来源的文件。\n\n15. 就针对第14项请求所确定的、价值超过 \\$50,000 的所有资产，提供：(i) 与您取得该等资产有关的所有文件；及 (ii) 与债务人或债务人家庭成员就该等资产进行的通信。\n\n16. 您的纳税申报表副本。\n\n17. 足以显示由您占有或控制的所有银行账户和投资账户的文件，包括每一该等账户的余额以及向该等账户的转账和自该等账户的转账。\n\n18. 与您使用的任何信用卡有关的所有文件，包括但不限于月度账单或足以显示为债务人或关联实体的利益而进行的所有相关购买的其他文件。\n\n19. 所有公司治理及组织文件，包括但不限于章程细则、公司注册证书，以及足以显示您的公司结构、高级职员及董事姓名、经营宗旨以及与债务人或债务人任何家庭成员关系的其他文件。\n\n20. 与将您的任何资产质押给任何其他实体有关的所有文件。\n\n送达证明\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于（日期）__________。本人收到为（个人姓名及职务，如有）：______________________________________________而发出的本传票。\n\n本人通过如下方式将传票副本交付给被指定人员，从而完成送达：____________________________________ 于（日期）___________________；或 ___________________________________________________________________________________________________\n\n本人未执行传票即予退回，原因是：____________________________________________________________\n\n本人收取的差旅费为 \\$ _________，服务费为 \\$_________，合计为 \\$_________。除非该传票代表美国或其官员或代理人发出，本人还已向证人预付一天出席费用及法律允许的里程费，金额为 \\$ _______________________ 。\n\n本人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（2013年12月1日生效）（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商业交易之地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交易所在州内，但该人员：\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交易之地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) 在待检查场所对场所进行检查。\n\n(d) 保护受传票约束的人员；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，制裁可包括损失的收入和合理的律师费。\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) 送达方可在任何时候通知被命令人员后，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) 仅可按照该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；(ii) 要求人员在超出第45(c)条规定的地理限制范围外履行；(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) 对人员施加不当负担。\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的人员，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，该等意见或信息并非描述争议中的具体事件，且源于该专家未受任何当事人请求进行的研究。\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) 证明其对证言或材料有实质性需要，且若不承受不当困难则无法以其他方式满足该需要；且\n\n(ii) 确保受传唤人员将获得合理补偿，\n\n法院可以不撤销或修改传票，而命令其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的人员，必须按照文件在正常业务过程中保存的方式提交，或将其整理并标注为与要求中的类别相对应。\n\n(B) 未规定电子存储信息的提交形式。如传票未规定电子存储信息的提交形式，回应人员必须以该信息通常保存的一种或多种形式，或以合理可使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) 无法合理访问的电子存储信息。回应人员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。对于强制证据开示动议或保护令动议，回应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，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扣留被传唤信息的人员必须：\n\n(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，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的主张，提出该主张的人员可以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披露了该信息，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。提交该信息的人员必须保存该信息，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——可以认定已被送达但无充分理由不遵守传票或相关命令的人员构成藐视法庭。\n\n如需获取传票材料，请参见《联邦民事诉讼规则》第45(a)条委员会说明（2013年）\n\n……\n\n附件 C-2\n\nB2540（表格2540——《规则2004审查传票》）（12/15）Case 22-50073 Doc 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 53 of 491\n\nUNITED STATES BANKRUPTCY COURT（美国联邦破产法院）\n\n________________________________________________________ District of（地区）________________________________________________________ Connecticut（康涅狄格州）\n\n关于 ______________________________________________________\n\n案号：________________________________ Ho Wan Kwok（郭文贵）22-50073\n\n债务人\n\n章节：__________________ 11\n\n规则2004审查传票\n\n致：________________________________________________________________________________________________ Himalaya International Clearing Ltd.（喜马拉雅国际清算有限公司）\n\n（传票所指向人员的姓名）\n\n证言：兹命令您于下列规定的时间、日期和地点出席，以便根据《Federal Rules of Bankruptcy Procedure（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\nPaul Hastings LLP（普衡律师事务所）\n200 Park Avenue\nNew York, New York 10166\n\n审查将以如下方式记录：________________________________________________________________________________ 法庭记录员/速记员\n\n出示：您或您的代表还必须在接受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》（Fed. R. Civ. P.）第45条的规定，依据《联邦破产程序规则》（Fed. R. Bankr. P.）第9016条适用于破产案件，随附于后——第45(c)条，关于履行地点；第45(d)条，关于作为受传票约束之人的保护；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以及未作出回应的潜在后果。\n\n日期：September ______________ __, 2022\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 Patrick R. Linsey（ct29437）\n\n代表（当事人名称）______________________________，签发或请求本传票的律师的姓名、地址、电子邮件地址和电话号码如下：Luc Despins, Ch. 11 Trustee（Luc Despins，第11章受托人）\n\nPatrick R. Linsey, Esq.; Neubert, Pepe & Monteith, P.C.; 195 Church Street, New Haven, Connecticut 06510 plinsey@npmlaw.com; 203-821-2000\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出示文件、电子存储信息或有形物品，或检查场所，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。Fed. R. Civ. P. 45(a)(4)。\n文件出示请求\nI. 指示\n\n1. 除非另有说明，下列文件请求（以下简称“请求”，每一项以下简称“一项请求”）必须分别且具体地作出回应。除非您善意提出异议，否则必须对每一项请求作出完整答复；如提出异议，则必须按照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，或其中包含的某个词语、短语或条款，您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。每一图像的右下角必须标注连续的 Bates 编号。每个文件夹中的 TIFF 文件不得超过1000个。Excel 电子表格应有一张以该文件 Bates 编号命名的占位图像。\n\nb. 图像加载文件\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 文件的第一行必须是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。如文件包括已生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项/子项关系。必须包含 OCRPATH 字段，以提供出示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，必须包含 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。该文件应为以逗号分隔的文件，每行由七个字段组成，数据库中的每一图像均应在交叉引用文件中占一行，格式如下：ImageID,VolumeLabel,ImageFilePath,DocumentBreak,FolderBreak,BoxBreak,PageCount。\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内，每个文件夹中的文本文件不得超过1,000个。文件夹名称中不得有特殊字符（包括逗号）。文本文件必须按文件级提供。\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。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。提供一张标有 Bates 编号的隔页图像，指明原生文件的存在，并将原生文件路径作为字段纳入 .dat 文件。出示的原生文件应以与该文件隔页相对应的 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。\n\ne. 去重。对于存在完全重复件的每一电子文件，出示一份副本。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 的加载文件（.dat）形式，出示每一文件的提取元数据。.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。所需元数据如下：\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\n单页文件应填写 LASTBATES 字段\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：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 [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/电子邮件被标准化时所采用的时区\nTIME_ZONE GMT 在转换期间电子邮件被标准化时所采用的时区。\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\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，且不得与 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，且不得与 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，且不得与 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：唯一信息 ID\n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. 每项请求均独立运作并应被独立解释，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. 所有文件应按其在日常业务过程中保存的方式出示，或应予整理和标记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) 在您占有、保管或控制之下的；或 (b) 在任何代表您行事之人占有、保管或控制之下的，包括您的律师或其他代表及顾问。每一文件均应完整出示。\n\n6. 如要求您出示一份已不再由您占有、保管或控制的文件，则您的回应必须：(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之人的身份（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) 缺失或遗失，(ii) 已被销毁，(iii) 已自愿或非自愿地转交他人，或 (iv) 以其他方式被处置；(e) 说明该等处置的理由及相关事实和情形；(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处于您占有、保管或控制之下的时间；以及 (i) 确认目前占有、保管或控制该文件的人员（如有）。\n\n7. 如要求您出示一份已被销毁的文件，则除前述指示所要求的信息外，您的回应还必须说明：(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. 如您主张所请求的某一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) 收到或阅览该文件原件、任何草稿、副本或复制件的每一人士的身份，(vii) 该文件本身，或该文件中载有或提及的任何信息，是否由任何其他人士持有、保管或控制；如是，则说明该等人士的身份，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) 您将据以支持该等特权主张的所有情形；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，提供一份载有本指示第 (a) 部分所要求全部信息的特权清单。\n\n9. 如一份原本应予提供的文件的一部分载有受特权主张保护的信息，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保护的部分，其余部分应予提供。\n\n10. 该等请求具有持续性。兹指示您：(a) 在获悉先前答复不完整或不正确后，立即补充或更正任何后来发现不完整或不正确的答复；以及 (b) 提供根据该等文件请求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；以及 (b) 任何时态动词的使用应解释为使用该动词的所有其他时态。\n\n16. (a) “and”和“or”应视必要情况解释为连词性或选择性用法，以使本应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”两词。\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，以及 D. Conn. L. Civ. R. 26(d) 所提供的解释规则，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”、“Your”或“Yourself”系指 Himalaya International Clearing Ltd.（喜马拉雅国际清算有限公司），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，及/或任何代表其行事的人。\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），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）（亦称 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）（亦称 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）（亦称 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自称妻子，以及与债务人有任何其他家庭关系的人。\n\n7. “Associated Individuals”系指个别及共同而言，所有：(1) 持有、控制、保管债务人或债务人家庭所拥有、控制或享有的资产，或对该等资产具有酌处权的个人；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的个人，连同上述任何人士各自的雇员、代理人、律师、顾问或任何代表其行事的人。该等关联个人包括但不限于：Daniel Podhaskie（丹尼尔·波达斯基）、Jason Miller（杰森·米勒）、Steve Bannon（史蒂夫·班农）、Karin Maistrello（卡琳·迈斯特雷洛）、Melissa Francis（梅丽莎·弗朗西斯）、William Gertz（威廉·格茨）、Arethusa Forsyth（阿雷图萨·福赛思）、Glenn Mellor（格伦·梅勒）、Jennifer Mercurio（詹妮弗·默丘里奥）、Eduardo Eurnekian（爱德华多·尤尔内基安）、Han Chunguang（韩春光）（亦称 韩春光）、Qu Guojiao（屈国姣）（亦称 Qu Guo Jiao、屈国姣）、Guo Lijie（郭丽杰）（亦称 郭丽杰）、Zhang Wei（张伟）（亦称 张伟*）、Lihong Wei Lafrenz（魏丽红）（亦称 Sara Wei、魏丽红）、Hao Haidong（郝海东）（亦称 郝海东）、Ross Heinemeyer（罗斯·海内迈耶）、Max Krasner（马克斯·克拉斯纳）、Kyle Bass（凯尔·巴斯）、Melissa Mendez（梅丽莎·门德斯）、Ya Li（李娅）（亦称 李娅）、Dinggang Wang（王定刚）（亦称 王定刚）、An Hong（安红）（亦称 安红）、Yvette Wang（王雁平）（亦称 Yanping Wang、Yan Ping Wang、王雁平）、Fiona Yu（菲奥娜·于）、Je Kin Ming（余建明）（亦称 William Je、Yu Jianming、余建明）、Yaz Qingua（亚兹·青瓜）及 Lao Jiang（姜云浮）（亦称 Jiang Yunfu、Jiang Yunfu Be、姜云浮）。\n\n8. “Associated Entities”系指个别及共同而言，所有：(1) 曾由债务人或债务人家庭拥有、控制或投资的任何类型组织或实体；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任何类型组织或实体，连同上述任何实体各自的雇员、代理人、律师、顾问或任何代表其行事的人。该等关联实体包括但不限于：7 Nod Hill LLC（7诺德山有限责任公司）、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（阿尔卑斯受托人股份公司）、Anton Development Limited（安东开发有限公司）、Assets Sino Limited（中资资产有限公司）、Auspicious Coast Limited（吉祥海岸有限公司）、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（北京鼎峰控股有限公司）、Bravo Luck Limited（鸿运有限公司）、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（克兰咨询集团有限责任公司）、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（曙光国度有限公司）、Eastern Profit Corporation Limited（东方利润有限公司）、Elite Well Global Limited（精英环球有限公司）、Empire Growth Holdings（帝国增长控股）、G Club Operations LLC（G俱乐部运营有限责任公司）、G Fashion LLC（G时尚有限责任公司）、G News LLC（G新闻有限责任公司）、GETTR USA（GETTR美国）、Genever Holdings Corporation（吉内弗控股公司）、Genever Holdings LLC（吉内弗控股有限责任公司）、GFASHION MEDIA GROUP INC.（GFASHION媒体集团公司）、GFNY, Inc.（GFNY公司）、Globalist International Limited（全球主义者国际有限公司）、GNews Media Group Inc.（GNews媒体集团公司）、Golden Spring (New York) Ltd.（金泉〈纽约〉有限公司）、Greenwich Land LLC（格林尼治地产有限责任公司）、Guo Media（郭媒体）、GTV Media Group, Inc.（GTV媒体集团公司）、Hamilton Capital Holdings Inc.（汉密尔顿资本控股公司）、Head Win Group Limited（领赢集团有限公司）、Henan Yuda（河南裕达）、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 Supervisory Organization（喜马拉雅监督组织）、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）、Infinite Increase Limited（无限增长有限公司）、Infinitum Developments Limited（无限发展有限公司）、Insight Phoenix Fund（洞察凤凰基金）、Lamp Capital LLC（蓝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）、Long Gate Limited（长龙门有限公司）、Next Tycoon Investments Limited（下一大亨投资有限公司）、New Federal State of China（中国新联邦国）（亦称 NFSC）、Noble Fame Global Limited（卓名环球有限公司）、Rosy Acme Ventures Limited（玫瑰顶峰创投有限公司）、Rule of Law Foundation III, Inc.（法治基金会III公司）、Rule of Law Foundation IV, Inc.（法治基金会IV公司）、Rule of Law Fund（法治基金）、Rule of Law Society（法治协会）、Rule of Law Society IV, Inc.（法治协会IV公司）、G-Translators PTY LTD（G-翻译服务有限公司）、Saraca Media Group, Inc.（萨拉卡媒体集团公司）、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）、Spirit Charter Investment Limited（精神特许投资有限公司）、Stevenson, Wong & Co.（史蒂文森、黄及公司）、Voice of Guo Media, Inc.（郭媒体之声公司）、Well Origin Ltd.（良好起源有限公司）、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）、Whitecroft Shore Limited（白克罗夫特海岸有限公司）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”，并应同时按连词性及选择性用法解释，以最大限度扩大其范围。\n\n11. “Any”、“all”和“each”意为“每一个及所有”。\n\n12. “Each”和“every”意为“每一个及所有”。\n\n13. “Third Party”系指您本人以外的人士或实体。\n\n14. “Transfer”具有《破产法典》第 101(54) 条赋予该词的含义。\n\n15. “Document”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，该等材料目前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、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、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、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；还包括但不限于上述任何文件的草稿或副本，如该等草稿或副本载有原始文件中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。\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”意为涉及、描述、包含、提及、与之有关、支持、赞成、反对、加强、削弱、位于其中、结合其加以考虑、对其产生影响、证明、表明、报告、记录、暗指、回应、与之关联、评论、就其而言、关于、与之相关、讨论、显示、描述、反映、分析、构成及为。\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，或以任何方式与所确定的特定主题相关的任何文件。\n\n20. “通信”系指在最广义且不受任何限制的意义上，任何信息或知识的传送（以事实、观点、询问或其他形式）。通信还指所有当面、电话、书面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”应具有《破产法典》（Bankruptcy Code）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、债务人财产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避免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. 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、账户结单、电汇指示及/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\n4. 关于由债务人作出、与债务人进行或代表债务人作出的任何投资、商业交易或交易的所有文件。\n\n5. 与债务人的所有通信，以及与债务人的通信有关、并涉及任何实体的运营、管理或决策的文件，包括但不限于关联实体。\n\n6. 关于向债务人、由债务人作出或与债务人、债务人家庭成员或关联实体进行的任何转让、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Lady May；Sherry Netherland Hotel / Condominium（谢里·尼德兰酒店／公寓）；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；以及位于康涅狄格州威尔顿354 Nod Hill Rd.的住宅物业。\n\n8. 与债务人、债务人家庭成员或关联实体于2020年7月前后或任何其他时间进行的任何原油期货或任何类似商品投资或交易有关的所有文件，包括但不限于与Jiang Yunfu Be（Jiang Yunfu Be）就任何该等投资或交易进行的通信。\n\n9. 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清单。\n\n10. 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、利益或贷款的金额；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、任何贷款的利率以及任何贷款付款的所有证据的文件。\n\n11. 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、受益人及信托财产的文件。\n\n12. 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（无论为行政机构、法院、合议庭或替代性争议解决实体）前的任何诉讼有关的文件。\n\n13. 您的任何外部律师或其他顾问与债务人之间的所有文件和通信。\n\n14. 足以显示您的所有资产以及收入或资金来源的文件。\n\n15. 对于就第14项请求所识别的价值超过$50,000的所有资产，所有(i)与您取得该等资产有关的文件，以及(ii)您与债务人或债务人家庭成员就该等资产进行的通信。\n\n16. 您的纳税申报表副本。\n\n17. 足以显示由您持有或控制的所有银行账户和投资账户的文件，包括每一该等账户的余额以及向该等账户作出和从该等账户作出的转让。\n\n18. 关于您使用的任何信用卡的所有文件，包括但不限于月度对账单或足以显示为债务人或关联实体利益而作出的所有相关购买的其他文件。\n\n19. 所有公司治理及组织文件，包括但不限于公司章程细则、公司注册证书以及足以显示您的公司结构、高级管理人员和董事姓名、经营目的，以及与债务人或债务人任何家庭成员之关系的其他文件。\n\n20. 与将您的任何资产质押给任何其他实体有关的所有文件。\n\n送达证明\n（除非《联邦民事诉讼规则》（Federal Rules of Civil Procedure）第45条要求，否则本节不应向法院提交。）\n\n于（日期）\n__________ 本人收到送达给（个人姓名及职务，如有）：______________________________________________\n本人通过向被指定人交付副本送达传票，具体如下：____________________________________\n__________________________________ ___________________________________________________________________________________________________\n于（日期）___________________；或\n本人因以下原因退回未执行的传票：____________________________________________________________\n\n本人旅费为$_________，服务费为$_________。除非该传票代表美国或其官员或代理人发出，本人还已向证人支付一天出席费用及法律允许的里程费，金额为$_______________________。\n服务费用合计为$_________\n本人在伪证处罚的约束下声明，该等信息真实且正确。\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《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》（Federal Rules of Bankruptcy Procedure）第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、受雇或经常亲自办理业务地点的100英里范围内；或\n\n(B) 在该人居住、受雇或经常亲自办理业务所在州内，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(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的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) 在拟检查的不动产所在地检查该不动产。\n(d) 对受传票约束者的保护；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，避免对受传票约束者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，并对未予遵守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，或允许检查不动产的人，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，或反对检查不动产，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，适用以下规则：\n\n(i) 送达方可在任何时候，在通知被命令者后，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者免于承担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有下列情形的传票：\n\n(i) 未给予合理的履行时间；(ii) 要求某人在第45(c)条规定的地域范围之外履行；(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。为保护受传票约束或受其影响者，要求履行义务所在地区的法院可经动议撤销或修改有下列要求的传票：\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) 披露未经聘用的专家的意见或信息，该等意见或信息未描述争议中的具体事件，并源于任何一方未要求该专家进行的研究。\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) 证明对证词或材料具有实质性需要，且若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) 确保受传票人将获得合理补偿，\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(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。对要求提供文件的传票作出回应的人，必须按其在正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注，以对应请求中的类别。\n\n(B) 未指定的电子存储信息提供形式。如果传票未规定提供电子存储信息的形式，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同一电子存储信息。\n\n(D) 无法合理取得的电子存储信息。对于该人认定因不当负担或费用而无法合理取得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。在要求强制证据开示或申请保护令的动议中，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取得。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，并应考虑第26(b)(2)(C)条的限制。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) 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：\n\n(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的信息的情况下，能够使各方评估该主张的方式，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，提出该主张的人可将该主张及其依据通知任何收到该信息的一方。收到通知后，一方必须立即返还、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，必须采取合理步骤追回该信息；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与之相关命令的人处以藐视法庭。\n\n有关获取传票材料的信息，见 Fed. R. Civ. P. 45(a) 委员会说明（2013）\n\n……\n\n附件 C-3\n\nB2540（表格2540——第2004条审查传票）（12/15）Case 22-50073 Doc 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 72 of 491\n\n美国破产法院\n\n________________________________________________ 地区 ________________________________ Connecticut（康涅狄格州）\n\n关于 ________________________________________________________________\n\n案号：____________________________ Ho Wan Kwok（郭文贵）22-50073\n\n债务人\n\n章节：________________ 11\n\n第2004条审查传票\n\n致：________________________________________________________________________________ Himalaya International Payments Ltd.\n\n（传票所指向人员的姓名）\n\n证言：兹命令您于下列规定的时间、日期和地点出席，根据《联邦破产程序规则》第2004条接受审查并作证。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\nPaul Hastings LLP\n200 Park Avenue\nNew York, New York 10166\n\n该审查将以如下方式记录：____________________________________________________________ 法院记录员/速记员\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参加审查，并必须准许对该材料进行检查、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》第45条的下列规定，经《联邦破产程序规则》第9016条适用于破产案件，现随附于后——有关履行地点的第45(c)条；有关您作为受传票约束之人的保护的第45(d)条；以及有关您回应本传票的义务和未履行该义务可能后果的第45(e)条和第45(g)条。\n\n日期：September __________________ __, 2022\n\n法院书记员\n\n或\n\n____________________________ 法院书记员或副书记员签名 ____________________________ 律师签名 Patrick R. Linsey (ct29437)\n\n代表（当事人姓名）____________________________并签发或请求本传票的律师的姓名、地址、电子邮件地址和电话号码如下：Luc Despins，Chapter 11 Trustee（第11章受托人）\n\nPatrick R. Linsey, Esq.; Neubert, Pepe & Monteith, P.C.; 195 Church Street, New Haven, Connecticut 06510 plinsey@npmlaw.com; 203-821-2000\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供文件、电子存储信息或有形物，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。Fed. R. Civ. P. 45(a)(4)。\n\n文件提交请求\n\nI. 指示\n\n1. 除非另有说明，下述文件请求（统称“请求”，各称“一项请求”）必须分别且具体地予以回应。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，则必须按照下述规定详细说明您提出异议的理由。如异议仅涉及一项请求的一部分，或者其中包含的一个词、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. 电子存储信息必须按照下列指示提供：\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。每张图像必须在右下角加注连续 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\n- b. 图像加载文件\n\n - 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）。日期字段应按如下格式提供：mm/dd/yyyy。日期和时间字段必须为两个单独字段。如文件包括图像化的电子邮件及附件，则必须包括附件字段，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，每行由七个字段组成，并且数据库中每幅图像均须在交叉引用文件中具有一行，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）应包括在 .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\n- d. 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。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。请提供一张带有 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字段纳入 .dat 文件。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\n- e. 去重。对存在完全重复件的每一电子文件，提供一份副本。对于电子邮件，以根据 BCC、Body、CC、From、IntMsgID、To 和 Attach 属性生成的 MD5 哈希值为基础合并重复件。对于电子邮件附件和独立电子文件，以整个文件的 MD5 哈希值为基础合并重复件。\n\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日期字段应按如下格式提供：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字段名称 示例数据 说明\n\nFIRSTBATES EDC0000001 本机文件文档/电子邮件的首个 Bates 编号\nLASTBATES EDC0000001 本机文件文档/电子邮件的最后一个 Bates 编号\nLASTBATES 字段应针对单页\n予以填写\nATTACHRANGE EDC0000001\n- 母文档首页的 Bates 编号\nEDC0000015 文档至最后一个附件“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\n本机文件：该文档源自其文件的个人或部门名称\nFROM John Smith 电子邮件：发件人\n本机文件：文档作者\n应使用分号分隔\n多个条目\nTO Coffman, Janice（贾妮斯·科夫曼）；LeeW 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 电子邮件：电子邮件主题行 本机文件：文档标题\n（如有）\nFILE_NAME BoardMeetingMinutes.docx 本机文件：原始本机文件的名称，\n包括扩展名\nDATE_SENT 10/12/2010 电子邮件：电子邮件发送日期\n本机文件：（空）\nTIME_SENT/ 07:05 PM GMT 电子邮件：电子邮件发送时间/电子邮件经\nTIME_ZONE 标准化时所采用时区内的时间\nTIME_ZONE GMT 电子邮件在转换过程中\n被\n标准化时所采用的\n时区。\nLINK >EDC0000001.msg 电子邮件或本机文件文档的超链接\n链接文件必须按照\nFIRSTBATES 编号命名\nFILE_EXTEN MSG 代表\n电子邮件或本机文件文档的文件类型\n扩展名\nAUTHOR John Smith 电子邮件：（空）\n本机文件：文档作者\nDATE_CREATED 10/10/2010 电子邮件：（空）\n本机文件：文档创建日期\n\nTIME_CREATED 10:25 AM 电子邮件：（空）\n\n本机文件：文档创建时间\n该数据必须为单独字段\n且不得\n与 DATE_CREATED 字段合并\nDATE_MOD 10/12/2010 电子邮件：（空）\n本机文件：文档最后修改日期\nTIME_MOD 07:00 PM 电子邮件：（空）\n本机文件：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本机文件：文档最后访问日期\nTIME_ACCESSD 07:00 PM 电子邮件：（空）\n本机文件：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 本机文件文档/电子邮件的大小，单位为 KB\nPGCOUNT 1 本机文件文档/电子邮件中的页数\nPATH 电子邮件：（空）\nAgenda.doc 本机文件：存储本机文件文档的路径，\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 本机文件：（空）\nINTMSGID <000805c2c71b\\$75977050\\$ 电子邮件：唯一邮件\nID 本机文件：（空）\ncb8306d1@MSN>\nMD5HASH d131dd02c5e6eec4693d9a0 文档的 MD5 哈希值。\n698aff95c\n2fcab58712467eab4004583e\nb8fb7f89\nOCRPATH TEXT/001/EDC0000001.txt 本机文件提取文本的路径\n\n3. 各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. 所有文件均应按其在通常业务过程中保存的方式提交，或应予以组织和标注，以对应于本请求中的类别。\n\n5. 本文所载的各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的人占有、保管或控制的文件，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）详细描述该文档的性质及其内容；（b）指明编制或撰写该文件的人士（以及，如适用，文件发送给的人士）；（c）指明该文档编制或创建的日期；（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）指明授权该等处置的人士；（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士（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）该文件被销毁的原因；（b）销毁该文件的人士的身份；以及（c）指示销毁该文件的人士的身份。\n\n8. 如贵方主张所要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）收到或查看该文件原件或任何草稿、副本或复制件的每一人士的身份；（vii）该文件本身，或文件中包含或提及的任何信息，是否由任何其他人士占有、保管或控制；如是，则说明该等人士的身份，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）贵方将据以支持该等特权主张的所有情形；并且（b）根据 D. Conn. L. Civ. R. 26(e)，就基于特权主张而被扣留的每份文件，提交一份特权清单，其中载明本指示第（a）部分所要求的全部信息。\n\n9. 如一份原本应予提交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该部分，其余部分应予提交。\n\n10. 各项请求具有持续性。现指示贵方：（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发现不完整或不正确的答复；以及（b）提交根据该等请求所要求的任何补充文件。\n\n11. 如一份文件以英语以外的语言写成，贵方应提供该文件。如一份文件以英语以外的语言写成，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或选择连词，以便将任何请求范围内所有可能被解释为不在其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”。\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如下含义：\n\n1. “贵方”或“贵方自身”系指 Himalaya International Payments Ltd.（喜马拉雅国际支付有限公司），连同其所有关联方、部门、机构、工具、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、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。\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的人。\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所谓的妻子，以及与债务人有其他亲属关系的任何人。\n\n7. “关联个人”系指单独及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、控制或享有的资产拥有酌处权；或（2）曾为一项或多项关联实体的雇员、董事，或以其他方式与其存在关联，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：Daniel Podhaskie（丹尼尔·波德哈斯基）、Jason Miller（杰森·米勒）、Steve Bannon（史蒂夫·班农）、Karin Maistrello（卡琳·迈斯特雷洛）、Melissa Francis（梅丽莎·弗朗西斯）、William Gertz（威廉·格茨）、Arethusa Forsyth（阿雷图莎·福赛思）、Glenn Mellor（格伦·梅勒）、Jennifer Mercurio（詹妮弗·梅尔库里奥）、Eduardo Eurnekian（爱德华多·尤尔内基安）、Han Chunguang（韩春光）（又名 韩春光）、Qu Guojiao（屈国姣）（又名 Qu Guo Jiao、屈国姣）、Guo Lijie（郭丽杰）（又名 郭丽杰）、Zhang Wei（张伟）（又名 张伟*）、Lihong Wei Lafrenz（魏丽红）（又名 Sara Wei、魏丽红）、Hao Haidong（郝海东）（又名 郝海东）、Ross Heinemeyer（罗斯·海尼迈耶）、Max Krasner（马克斯·克拉斯纳）、Kyle Bass（凯尔·巴斯）、Melissa Mendez（梅丽莎·门德斯）、Ya Li（李娅）（又名 李娅）、Dinggang Wang（王定刚）（又名 王定刚）、An Hong（安红）（又名 安红）、Yvette Wang（王雁平）（又名 Yanping Wang、Yan Ping Wang、王雁平）、Fiona Yu（菲奥娜·余）、Je Kin Ming（余建明）（又名 William Je、Yu Jianming、余建明）、Yaz Qingua（亚兹·钦瓜）以及 Lao Jiang（姜云浮）（又名 Jiang Yunfu、Jiang Yunfu Be、姜云浮）。\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各类组织或实体：(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：7 Nod Hill LLC（诺德山7号有限责任公司）、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（阿尔卑斯受托人股份公司）、Anton Development Limited（安东开发有限公司）、Assets Sino Limited（华资有限公司）、Auspicious Coast Limited（吉祥海岸有限公司）、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（北京鼎峰控股有限公司）、Bravo Luck Limited（鸿运有限公司）、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（东方盈利有限公司）、Elite Well Global Limited（精英环球有限公司）、Empire Growth Holdings（帝国增长控股）、G Club Operations LLC（G俱乐部运营有限责任公司）、G Fashion LLC（G时尚有限责任公司）、G News LLC（G新闻有限责任公司）、GETTR USA（GETTR美国）、Genever Holdings Corporation（吉尼弗控股公司）、Genever Holdings LLC（吉尼弗控股有限责任公司）、GFASHION MEDIA GROUP INC.（GFASHION媒体集团公司）、GFNY, Inc.（GFNY公司）、Globalist International Limited（全球主义者国际有限公司）、GNews Media Group Inc.（GNews媒体集团公司）、Golden Spring (New York) Ltd.（金泉〔纽约〕有限公司）、Greenwich Land LLC（格林尼治土地有限责任公司）、Guo Media（郭媒体）、GTV Media Group, Inc.（GTV媒体集团公司）、Hamilton Capital Holdings Inc.（汉密尔顿资本控股公司）、Head Win Group Limited（领先集团有限公司）、Henan Yuda（河南裕达）、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 Supervisory Organization（喜马拉雅监督组织）、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）、Infinite Increase Limited（无限增长有限公司）、Infinitum Developments Limited（无限发展有限公司）、Insight Phoenix Fund（洞察凤凰基金）、Lamp Capital LLC（灯资本有限责任公司）、Leading Shine Limited（领耀有限公司）、Leading Shine NY Limited（领耀纽约有限公司）、Long Gate Limited（长龙门有限公司）、Next Tycoon Investments Limited（下一大亨投资有限公司）、New Federal State of China (a/k/a NFSC)（中国新联邦国，亦称NFSC）、Noble Fame Global Limited（全球盛名有限公司）、Rosy Acme Ventures Limited（蔷薇顶峰创投有限公司）、Rule of Law Foundation III, Inc.（法治基金会III公司）、Rule of Law Foundation IV, Inc.（法治基金会IV公司）、Rule of Law Fund（法治基金）、Rule of Law Society（法治协会）、Rule of Law Society IV, Inc.（法治协会IV公司）、G-Translators PTY LTD（G-翻译员私人有限公司）、Saraca Media Group, Inc.（萨拉卡媒体集团公司）、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）、Spirit Charter Investment Limited（精神宪章投资有限公司）、Stevenson, Wong & Co.（史蒂文森、黄律师事务所）、Voice of Guo Media, Inc.（郭媒体之声公司）、Well Origin Ltd.（良好源头有限公司）、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）、Whitecroft Shore Limited（怀特克罗夫特海岸有限公司）以及ZIBA Limited（ZIBA有限公司）。\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”，并应同时按连词和选择连词解释，以最大限度扩大其范围。\n\n11. “任何”及“全部”以及“每一”系指“每一个及全部”。\n\n12. “每一”及“每个”系指“每一个及全部”。\n\n13. “第三方”系指除您本人以外的个人或实体。\n\n14. “转让”应具有《破产法》第101(54)条赋予该词的含义。\n\n15. “文件”系指属于Fed. R. Civ. P. 34范围内的任何信息或物品，并包括但不限于在您的占有、保管或控制之中或曾处于其中的各种、各种类型、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印刷版和电子版副本、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、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、图形、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、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，不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；亦包括但不限于前述任何材料的草稿或副本，如其中载有原始文件所无的任何种类笔记、评论或标记，或在其他方面与原始文件并不相同。\n\n16. “人”系指自然人、公司、独资企业、合伙企业、协会或任何其他实体。“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、有关、支持、有利于、反对、强化、减损、位于、结合考虑、影响、证明、表明、报告、记录、暗指、答复、关联、评论、就……而言、有关、与……相关、讨论、显示、描述、反映、分析、构成及为。\n\n19. “与……有关”、“与……相关”或“相关”，在提及任何特定事项时，系指包括但不限于构成、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事项相关的任何文件。\n\n20. “通信”在最广泛可能的意义上且不受限制地，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、以书面方式，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预期经济机会。\n\n22. “转让”应具有《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、债务人破产财产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、债务人破产财产、债务人家庭、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、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主体作出的所有转让的全部文件。\n\n4. 关于债务人作出、与债务人进行或代表债务人作出的任何投资、商业交易或其他交易的所有文件。\n\n5. 与债务人的所有通信，以及与债务人的通信有关、并与任何实体的运营、管理或决策有关的文件，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交易的所有文件。\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Lady May（“Lady May”号游艇）；Sherry Netherland Hotel / Condominium（谢里内德兰酒店／公寓）；位于Connecticut（康涅狄格州）Greenwich（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；以及位于康涅狄格州Wilton（威尔顿）354 Nod Hill Rd.的住宅物业。\n\n8. 与债务人、债务人家庭或关联实体于2020年7月前后或任何其他时间进行的任何原油期货或任何类似商品投资或交易有关的所有文件，包括但不限于与Jiang Yunfu（姜云福）就任何该等投资或交易进行的通信。\n\n9. 与债务人拥有、控制或使用的任何航空器有关的所有文件，包括但不限于尾号为T7-GQM的航空器以及在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清单。\n\n10. 关于向债务人、债务人破产财产、债务人家庭或关联实体提供、由其提供或代表其提供的任何礼品、利益或贷款的所有文件，包括但不限于足以显示该等礼品、利益或贷款的金额、该等礼品、利益或贷款的用途、提供该等礼品、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\n11. 关于由债务人、债务人破产财产、债务人家庭或关联实体设立、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何时设立、由谁设立、为谁的利益设立及信托财产的文件。\n\n12. 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\n13. 您的任何外聘律师或其他顾问与债务人之间的所有文件和通信。\n\n14. 足以显示您的全部资产及收入或资金来源的文件。\n\n15. 对于为答复请求14而确定的、价值超过$50,000的所有资产，(i) 与您取得该等资产有关的所有文件，以及 (ii) 与债务人或债务人家庭就该等资产进行的通信。\n\n16. 您的纳税申报表副本。\n\n17. 足以显示由您占有或控制的所有银行账户和投资账户的文件，包括每一该等账户的余额以及向该等账户和从该等账户进行的转账。\n\n18. 关于您使用的任何信用卡的所有文件，包括但不限于月度对账单或足以显示为债务人或关联实体的利益而作出的与之有关的全部购买的其他文件。\n\n19. 所有公司治理及组织文件，包括但不限于章程细则、公司设立证明书，以及足以显示贵方公司结构、高级管理人员和董事姓名、经营目的及与债务人或债务人任何家庭成员关系的其他文件。\n\n20. 与贵方向任何其他实体质押贵方资产有关的所有文件。\n\n送达证明\n（除非《联邦民事诉讼规则》第45条要求，否则本节不应向法院提交。）\n\n于（日期）__________。本人收到向以下人员（姓名及职务，如有）发出的本传票：______________________________________________\n本人通过按如下方式向被指定人员交付副本送达本传票：____________________________________\n__________________________________，于（日期）___________________；或 ___________________________________________________________________________________________________\n本人未执行即退回本传票，原因如下：____________________________________________________________\n\n本人差旅费为 \\$ _________，服务费为 \\$_________，合计 \\$_________。除非本传票系代表美国或其官员或代理人签发，本人还已向证人预付一天出席费用及法律允许的里程费，金额为 \\$ _______________________。\n本人在伪证罪处罚的约束下声明，本信息真实且正确。\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《联邦民事诉讼规则》第45(c)、(d)、(e)及(g)条（2013年12月1日生效）（依据《联邦破产程序规则》第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) 在该人居住地、受雇地或经常亲自从事营业地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的州内，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(2) 其他证据开示。传票可命令：\n\n(A) 在该人居住地、受雇地或经常亲自从事营业地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) 在被检查的场所对该场所进行检查。\n(d) 保护受传票约束的人；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，避免对受传票约束的人施加不当负担或费用。要求履行传票义务所在地区的法院必须执行该义务，并对未遵守者施加适当制裁，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，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，或准许检查的人，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) 送达方可随时在通知被命令人的情况下，向要求履行传票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免于承担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，要求履行传票义务所在地区的法院必须撤销或修改符合下列情形的传票：\n\n(i) 未给予合理履行时间；(ii) 要求人在超出第45(c)条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。为保护受传票约束或受其影响的人，经动议，要求履行传票义务所在地区的法院如传票要求：\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未说明争议中的具体事件，且系该专家未经任何当事人请求所进行研究的结果，\n\n则可以撤销或修改该传票。\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) 确保受传票人将获得合理补偿，\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，必须按文件在正常营业过程中保存的方式提交，或者必须将其整理和标记，以对应请求中的类别。\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。就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。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。基于信息享有特权或作为审判准备材料受到保护而扣留被传唤信息的人，必须：\n\n(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，必须采取合理措施予以取回；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，以裁定该主张。提交该信息的人必须保全该信息，直至该主张得到解决。\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签发传票的法院，均可认定已被送达但无充分理由不遵从传票或相关命令的人构成藐视法庭。\n\n如需查阅传票材料，见《联邦民事诉讼规则》第45(a)条委员会说明（2013年）\n\n……\n\n附件C-4\n\nB2540（表格2540－《规则2004审查传票》）（12/15）案号 22-50073，文件839，提交于09/07/22，录入于09/07/22 20:02:47，第91页，共491页\n美国破产法院\n\n__________________________________________________________________ Connecticut（康涅狄格州）地区\n\n关于 _________________________________________________________________\n\n案号。________________________________ Ho Wan Kwok（郭文贵）22-50073\n\n债务人\n\n章节 ____________________ 11\n规则2004审查传票\n\n致：________________________________________________________________________________________________________________ Himalaya International Reserves Ltd.\n\n（传票所指向人员的姓名）\n\n证言：兹命令你于下列载明的时间、日期和地点出席，依照《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\nPaul Hastings LLP\n200 Park Avenue\nNew York（纽约州纽约市）10166\n\n审查将以以下方式记录：________________________________________________________________________________ 法庭记录员/速记员\n\n提交：你或你的代表还必须将以下文件、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检查、复制、测试或抽样：\n见随附的文件提交请求。\n\n随附《联邦民事诉讼规则》第45条以下规定，该规则依据《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；有关你作为受传票约束之人所受保护的第45(d)条；以及有关你回应本传票的义务及不履行可能后果的第45(e)条和第45(g)条。\n\n日期：2022年9月 _________ __日\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 Patrick R. Linsey（ct29437）\n\n代表（当事人姓名）________________________________签发或请求本传票的律师姓名、地址、电子邮件地址及电话号码如下：Luc Despins，第11章受托人\n\nPatrick R. Linsey, Esq.; Neubert, Pepe & Monteith, P.C.; 195 Church Street, New Haven（康涅狄格州纽黑文）06510；plinsey@npmlaw.com；203-821-2000\n向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，或对场所进行检查，则必须在向被指向之人送达本传票之前，向各方送达通知及本传票副本。Fed. R. Civ. P. 45(a)(4)。\n\n文件提供请求\n\n一、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答复。除非基于善意提出异议，否则必须完整答复每一项请求；如提出异议，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，并答复其余请求。\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文件名，即 Bates 编号。每幅图像右下角必须加盖连续的 Bates 编号。每个文件夹中的 TIFF 文件数量不应超过 1000 个。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® 数据库中的全部字段信息。.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具有一行，格式如下：ImageID,VolumeLabel,ImageFilePath,DocumentBreak,FolderBreak,BoxBreak,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。建议提供文件级 ANSI 文本文件，并依 FIRSTBATES/Image Key 命名。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（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。提供一幅带 Bates 编号的插页图像，说明原生文件的存在，并在 .dat 文件中以字段形式包括该原生文件的路径。所提供的原生文件应以与该文件插页对应的 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，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。以下为所需元数据：\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 - 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 电子邮件：电子邮件所在的邮箱；原生文件：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。多个条目之间应使用分号分隔。\n\nTO Coffman, Janice; 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 [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 密送收件人。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/电子邮件统一标准化时所采用的时区\n\nTIME_ZONE GMT 在转换期间电子邮件被统一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。链接文件必须依 FIRSTBATES 编号命名。\n\nFILE_EXTEN MSG 表示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，以 KB 计\n\nPGCOUNT 1 原生文件文件/电子邮件的页数\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；原生文件：（空）\n\nINTMSGID <000805c2c71b$75977050$cb8306d1@MSN> 电子邮件：唯一消息 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. 每一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其他任何请求的范围。\n\n4. 所有文件应按其在通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. 本文所载每一项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，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其内容；(b) 识别编制或撰写该文件的人员（以及，如适用，文件被发送给的人员）；(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) 已自愿或非自愿转移给他人，或 (iv) 已以其他方式处置；(e) 说明该处置的理由以及相关事实和情形；(f) 识别授权该处置的人员；(g) 识别该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) 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. 如贵方主张被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) 对该文件作出足以支持贵方关于该文件享有特权之主张的描述，(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) 该文件本身或文件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，则说明该等人员的身份，以及说明该信息如何进入其占有范围，(viii) 据以拒绝提供该文件的特权主张，以及 (ix) 贵方将据以支持该特权主张的全部情形；以及 (b) 按照 D. Conn. L. Civ. R. 26(e)，就每份基于特权主张而未提供的文件，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) 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) 提供根据下文所要求的任何额外文件\n\n11. 如某一文件为英语以外的语言，您应提供该文件。如某一文件为英语以外的语言，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) 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) “和”及“或”应视为必要时以连词或选择词方式解释，以使任何请求的范围包括原本可能被解释为在其范围之外的所有答复；以及 (b) “每一”和“任何”应视为包括并涵盖“每一个”和“所有”二词。\nIII. 定义\n\n根据 D. Conn. L. Civ. R. 26(c) 提供的定义及根据 D. Conn. L. Civ. R. 26(d) 提供的解释规则，并经 D. Conn. Bankr. L.R. 2004-1(a) 纳入者，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如下含义：\n\n1. “您”或“您的”或“您本人”是指 Himalaya International Reserves Ltd.（喜马拉雅国际储备有限公司），连同其所有关联方、部门、机构、执行机构、职能部门、办事处、合伙人、高级管理人员、董事、代理人、律师、代表、雇员和/或任何代表其行事之人。\n\n2. “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、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）（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. “债务人声称的妻子”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、律师、顾问或任何代表其行事之人。\n\n6. “债务人家庭成员”统称债务人、债务人之子、债务人之女及债务人声称的妻子，以及债务人的任何其他亲属关系人。\n\n7. “关联个人”单独及统称指下列所有个人：(1) 持有、控制、保管债务人或债务人家庭成员拥有、控制或享有的资产，或对该等资产拥有酌处权；或 (2) 曾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，连同前述任何人士各自的雇员、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：Daniel Podhaskie（丹尼尔·波德哈斯基）、Jason Miller（杰森·米勒）、Steve Bannon（史蒂夫·班农）、Karin Maistrello（卡琳·迈斯特雷洛）、Melissa Francis（梅利莎·弗朗西斯）、William Gertz（威廉·格茨）、Arethusa Forsyth（阿瑞图莎·福赛思）、Glenn Mellor（格伦·梅勒）、Jennifer Mercurio（珍妮弗·默丘里奥）、Eduardo Eurnekian（爱德华多·厄内基安）、Han Chunguang（韩春光）（又名 韩春光）、Qu Guojiao（屈国姣）（又名 Qu Guo Jiao、屈国姣）、Guo Lijie（郭丽杰）（又名 郭丽杰）、Zhang Wei（张伟）（又名 张伟*）、Lihong Wei Lafrenz（魏丽红）（又名 Sara Wei、魏丽红）、Hao Haidong（郝海东）（又名 郝海东）、Ross Heinemeyer（罗斯·海内迈耶）、Max Krasner（马克斯·克拉斯纳）、Kyle Bass（凯尔·巴斯）、Melissa Mendez（梅利莎·门德斯）、Ya Li（李娅）（又名 李娅）、Dinggang Wang（王定刚）（又名 王定刚）、An Hong（安红）（又名 安红）、Yvette Wang（王雁平）（又名 Yanping Wang、Yan Ping Wang、王雁平）、Fiona Yu（菲奥娜·余）、Je Kin Ming（余建明）（又名 William Je、Yu Jianming、余建明）、Yaz Qingua（亚兹·钦瓜）及 Lao Jiang（姜云浮）（又名 Jiang Yunfu、Jiang Yunfu Be、姜云浮）。\nCase 22-50073 Doc 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 100 of 491\n\n8. “关联实体”单独及统称指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拥有权益，连同前述任何人士各自的雇员、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：7 Nod Hill LLC（七诺德山有限责任公司）、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（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）、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（阿尔卑斯受托人股份公司）、Anton Development Limited（安东发展有限公司）、Assets Sino Limited（华夏资产有限公司）、Auspicious Coast Limited（吉祥海岸有限公司）、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（北京鼎峰控股有限公司）、Bravo Luck Limited（百利有限公司）、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（克兰咨询集团有限责任公司）、Creative Apex Investments Limited（创意巅峰投资有限公司）、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）、Elite Well Global Limited（精英环球有限公司）、Empire Growth Holdings（帝国增长控股）、G Club Operations LLC（G Club 运营有限责任公司）、G Fashion LLC（G Fashion 有限责任公司）、G News LLC（G News 有限责任公司）、GETTR USA（GETTR 美国）、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（环球主义者国际有限公司）、GNews Media Group Inc.（GNews 媒体集团公司）、Golden Spring (New York) Ltd.（金泉〈纽约〉有限公司）、Greenwich Land LLC（格林尼治土地有限责任公司）、Guo Media（郭媒体）、GTV Media Group, Inc.（GTV 媒体集团公司）、Hamilton Capital Holdings Inc.（汉密尔顿资本控股公司）、Head Win Group Limited（领赢集团有限公司）、Henan Yuda（河南裕达）、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 Supervisory Organization（喜马拉雅监督组织）、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）、Infinite Increase Limited（无限增长有限公司）、Infinitum Developments Limited（无限发展有限公司）、Insight Phoenix Fund（洞见凤凰基金）、Lamp Capital LLC（灯资本有限责任公司）、Leading Shine Limited（领耀有限公司）、Leading Shine NY Limited（领耀纽约有限公司）、Long Gate Limited（长龙门有限公司）、Next Tycoon Investments Limited（下一大亨投资有限公司）、New\nCase 22-50073 Doc 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 101 of 491\n\nFederal State of China（中国新联邦国）（又名 NFSC）、Noble Fame Global Limited（高贵名望全球有限公司）、Rosy Acme Ventures Limited（玫瑰顶峰创投有限公司）、Rule of Law Foundation III, Inc.（法治基金会 III 公司）、Rule of Law Foundation IV, Inc.（法治基金会 IV 公司）、Rule of Law Fund（法治基金）、Rule of Law Society（法治协会）、Rule of Law Society IV, Inc.（法治协会 IV 公司）、G-Translators PTY LTD（G-翻译者有限公司）、Saraca Media Group, Inc.（萨拉卡媒体集团公司）、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）、Spirit Charter Investment Limited（精神宪章投资有限公司）、Stevenson, Wong & Co.（史蒂文森、黄氏律师事务所）、Voice of Guo Media, Inc.（郭媒体之声公司）、Well Origin Ltd.（良好起源有限公司）、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）、Whitecroft Shore Limited（怀特克罗夫特海岸有限公司）及 ZIBA Limited（ZIBA 有限公司）。\n\n9. “包括”或其任何变体意指“包括但不限于”。\n\n10. “和”及“或”意指“和/或”，并应以连词及选择词两种方式解释，以最大限度扩大其范围。\n\n11. “任何”、“所有”及“每一”意指“每一及全部”。\n\n12. “每一”及“每个”意指“每一及全部”。\n\n13. “第三方”指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 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现处于您的占有、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、记录或图示材料，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、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、数据\nCase 22-50073 Doc 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 102 of 491\n\n汇编资料、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、明细表、投影片、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；亦包括但不限于前述任何文件的草稿或副本，如其中载有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\n16. “个人”指自然人、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”意指涉及、描述、构成、提及、有关、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、暗示、回应、连接、评论、就……而言、关于、与……有关、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”指向任何特定主题事项时，意指包括但不限于构成、包含、涉及、载有、\nCase 22-50073 Doc 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 103 of 491\n\n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主题事项相关的任何文件。\n\n20. “通信”应按最广义且不受限制地理解，指任何信息或知识的传递（以事实、想法、询问或其他形式）。通信进一步指所有当面、通过电话、书面或借助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、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”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，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、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) 条赋予该词的含义。\nIV. 应提供的文件\n\n1. 关于债务人、债务人财产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，以及与本案或任何其他实际或潜在破产程序或类似资不抵债程序有关的所有文件。\n\n案件 22-50073 文件 839 提交日期 09/07/22 录入日期 09/07/22 20:02:47 第 104 页，共 491 页\n\n3. 有关债务人、债务人财产、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/或确认书、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前述任何一方进行的所有转让的所有文件。\n\n4. 有关债务人作出、与债务人进行或代表债务人作出的任何投资、业务往来或交易的所有文件。\n\n5. 与债务人的所有通信，以及与债务人的通信有关、且与任何实体的运营、管理或决策有关的文件，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、其他交易或业务往来的所有文件。\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 Lady May；Sherry Netherland Hotel / Condominium（雪莉荷兰酒店／公寓）；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；以及位于 Connecticut（康涅狄格州）Wilton（威尔顿）354 Nod Hill Rd. 的住宅物业。\n\n8. 有关债务人、债务人家庭成员或关联实体于 2020 年 7 月前后或任何其他时间进行的任何原油期货或任何类似商品投资或交易的所有文件，包括但不限于与 Jiang Yunfu Be（江云甫·贝）就任何该等投资或交易进行的通信。\n\n案件 22-50073 文件 839 提交日期 09/07/22 录入日期 09/07/22 20:02:47 第 105 页，共 491 页\n\n9. 有关债务人拥有、控制或使用的任何航空器的所有文件，包括但不限于尾号为 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。\n\n10. 有关向债务人、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；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与保证、任何贷款的利率，以及任何贷款付款的所有证明的文件。\n\n11. 有关由债务人、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何时设立、由谁设立、为谁的利益设立以及信托本金的文件。\n\n12. 有关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、审裁小组或替代性争议解决实体）前进行的任何诉讼有关的文件。\n\n13. 贵方任何外聘律师或其他顾问与债务人之间的所有文件和通信。\n\n案件 22-50073 文件 839 提交日期 09/07/22 录入日期 09/07/22 20:02:47 第 106 页，共 491 页\n\n14. 足以显示贵方所有资产及收入或资金来源的文件。\n\n15. 对于在答复请求第 14 项时确认的、价值超过 \\$50,000 的所有资产，提供：(i) 与贵方取得该等资产有关的所有文件，以及 (ii) 与债务人或债务人家庭成员就该等资产进行的通信。\n\n16. 贵方纳税申报表副本。\n\n17. 足以显示贵方占有或控制的所有银行账户和投资账户的文件，包括每一该等账户的余额及向该等账户转入和自该等账户转出的款项。\n\n18. 有关贵方使用的任何信用卡的所有文件，包括但不限于月度账单或足以显示为债务人或关联实体利益而作出的与此有关的所有购买的其他文件。\n\n19. 所有公司治理和组织文件，包括但不限于章程细则、公司注册证书，以及足以显示贵方公司结构、高级职员和董事姓名、业务目的，以及与债务人或债务人任何家庭成员关系的其他文件。\n\n20. 与贵方向任何其他实体质押贵方资产有关的所有文件。\n\n案件 22-50073 文件 839 提交日期 09/07/22 录入日期 09/07/22 20:02:47 第 107 页，共 491 页\n\nB2540（表格 2540——依规则 2004 审查发出的传票）（第 2 页）\n\n（除非 Fed. R. Civ. P. 45 要求，否则本节不应向法院提交。）\n\n于（日期）\n__________ 本人收到为以下人员发出的本传票（个人姓名及职务，如有）：______________________________________________\n本人通过向所列人员交付副本的方式送达本传票，具体如下：____________________________________\n\n__________________________________ 于（日期）___________________；或\n本人因以下原因未执行而退回本传票：____________________________________________________________\n\n本人收取的费用为差旅 \\$_________，以及服务费用 \\$_________，合计 \\$_________。除非本传票代表 United States（美国）或其官员或代理人发出，本人还已向证人预付一天出席费用及法律允许的里程费，金额为 \\$_______________________。\n\n本人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送达人员签名\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（联邦民事诉讼规则）45(c)、(d)、(e) 及 (g)（生效日期 12/1/13）（依 Federal Rules of Bankruptcy Procedure（联邦破产程序规则）规则 9016 适用于破产案件）\n(c) 遵从地点。\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、受雇或经常亲自进行营业活动地点 100 英里以内；或\n\n(B) 在该人居住、受雇或经常亲自进行营业活动所在州内，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(2) 其他取证。传票可以命令：\n\n(A) 在该人居住、受雇或经常亲自进行营业活动地点 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) 在待检查场所对该场所进行检查。\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。要求遵从的地区法院必须执行该义务，并对未遵守者施加适当制裁，该制裁可包括收入损失及合理的律师费。\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，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、测试或抽样全部或部分材料，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。异议必须在规定的遵从时间或传票送达后 14 日两者中较早者之前送达。如提出异议，适用以下规则：\n\n(i) 送达方可随时在通知被命令人的情况下，向要求遵从的地区法院申请强制提交或检查的命令。\n\n(ii) 仅可依命令所指示的方式要求实施该等行为，且该命令必须保护非当事人亦非当事人高级职员之人免于承担因遵从而产生的重大费用。\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，要求遵从的地区法院必须撤销或修改符合下列情形的传票：\n\n(i) 未给予合理的遵从时间；(ii) 要求某人在规则 45(c) 规定的地域限制以外遵从；(iii) 要求披露享有特权或受其他保护的事项，且无例外或放弃情形适用；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，经动议，要求遵从的地区法院可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性研究、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，且源自该专家未经任何当事人请求而进行的研究。\n\n(C) 以规定条件作为替代。在规则 45(d)(3)(B) 所述情形下，如送达方：\n\n(i) 表明其对该证言或材料具有重大需要，且不遭受不当困难即无法通过其他方式满足该需要；并且\n\n(ii) 确保被传唤之人将获得合理补偿，\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材料。\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。答复提交文件传票之人必须按文件在通常业务过程中保存的方式提交，或必须整理并标记文件，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，答复之人必须以通常保存该信息的一种或多种形式，或以合理可使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。答复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）无法以电子方式访问的存储信息。答复人无需提供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的证据开示。在提出强制证据开示动议或保护令动议时，答复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具有正当理由的情况下，命令从该等来源进行证据开示，并应考虑 Rule 26(b)(2)(C) 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受审判准备材料保护的主张而扣留被传唤信息的人，必须：\n\n（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，描述被扣留文件、通信或有形物品的性质，使各方能够评估该主张。\n\n（B）已提供的信息。如为答复传票而提供的信息受到特权主张或审判准备材料保护主张的约束，提出该主张的人可以通知收到该信息的任何一方该主张及其依据。收到通知后，一方必须立即返还、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传票的地区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——可以认定已被送达但无充分理由不遵守传票或与其相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附件 C-5\n\nB2540（表格 2540——Rule 2004 审查传票）（12/15）UNITED STATES BANKRUPTCY COURT（美国破产法院）Case 22-50073 Doc 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 110 of 491\n\n____________________________________________________________ 地区法院，Connecticut（康涅狄格州）\n\n关于 _________________________________________________\n\n案号：________________________________ Ho Wan Kwok（郭文贵）22-50073\n\n债务人\n\n章：________________ 11\n\nRULE 2004 审查传票\n\n致：________________________________________________________________________________ Jesse Brown（杰西·布朗）\n\n（传票所指向人员的姓名）\n\n证言：兹命令你于下列载明的时间、日期和地点出席，依《联邦破产程序规则》Rule 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\nPaul Hastings LLP（普衡律师事务所）\n\n200 Park Avenue\n\nNew York, New York 10166\n\n审查将通过以下方式记录：____________________________________________________________ 法院记录员/速记员\n\n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 Fed. R. Civ. P. 45 条款依 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)；有关作为受传唤人员对你的保护的 Rule 45(d)；以及有关你答复本传票的义务和不履行义务的潜在后果的 Rule 45(e) 和 45(g)。\n\n日期：September __________ __, 2022\n\n法院书记员\n\n或\n\n________________________ 法院书记员或副书记员签名 ________________________ 律师签名 Patrick R. Linsey（帕特里克·R·林赛）(ct29437)\n\n签发或请求本传票、代表（当事人姓名）____________________________ 的律师的姓名、地址、电子邮件地址和电话号码如下：Luc Despins（吕克·德斯潘），Chapter 11 受托人\n\nPatrick R. Linsey, Esq.; Neubert, Pepe & Monteith, P.C.（纽伯特、佩佩和蒙蒂斯律师事务所）；195 Church Street, New Haven, Connecticut 06510；plinsey@npmlaw.com；203-821-2000\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文件提交请求\n\n一、指示\n\n1. 除非另有说明，下列文件请求（统称“请求”，单称“一项请求”）必须分别且具体地作出答复。除非善意提出异议，否则必须完整答复每项请求；如提出异议，必须按如下规定详细说明你提出异议的理由。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，你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\n－b. 图像加载文件\n\n－a. Concordance®（康科丹斯）数据文件。数据文件（.DAT）包含将载入 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：mm/dd/yyyy。日期和时间字段必须为两个单独字段。如文件包含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\n－b. Concordance Image®（康科丹斯图像）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，每行包含七个字段，数据库中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。文本必须作为单独的文本文件提交，而不得作为 .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\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。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\n－f. 元数据。应以符合 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。下列为必需的元数据：\n\nCase 22-50073 Doc 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 113 of 491\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 字段应针对单页文件填写\n\nATTACHRANGE EDC0000001\n\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\n\nEDC0000015\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\n原生文件：文件来源个人或部门的名称\n\nFROM John Smith 电子邮件：发件人\n\n原生文件：文件作者\n\n多个条目应使用分号分隔\n\nTO Coffman, Janice; LeeW 收件人\n\n[mailto:LeeW@MSN.com] 多个条目应使用分号分隔\n\nCC Frank Thompson [mailto: 抄送收件人\n\nfrank_Thompson@cdt.com] 多个条目应使用分号分隔\n\nBCC John Cain 密送收件人\n\n多个条目应使用分号分隔\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\n文件名 BoardMeetingMinutes.docx 原生文件的原始文件名，包括扩展名\n\n发送日期 10/12/2010 电子邮件：发送电子邮件的日期\n原生文件：（空）\n\n发送时间/时区 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的时区\n\n时区 GMT 电子邮件在转换期间进行标准化所采用的时区。\n\n链接 >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 FIRSTBATES 编号命名\n\n文件扩展名 MSG 代表电子邮件的文件类型扩展名\n\n作者 John Smith（约翰·史密斯） 电子邮件：（空）\n原生文件：文档作者\n\n创建日期 10/10/2010 电子邮件：（空）\n原生文件：文档创建日期\n案件 22-50073 文档 839 于 09/07/22 提交 于 09/07/22 20:02:47 登记 第 114 页，共 491 页\n\n创建时间 10:25 AM 电子邮件：（空）\n原生文件：文档创建时间\n该数据必须为单独字段，不得与 DATE_CREATED 字段合并\n\n修改日期 10/12/2010 电子邮件：（空）\n原生文件：文档最后修改日期\n\n修改时间 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\n\n访问日期 10/12/2010 电子邮件：（空）\n原生文件：文档最后访问日期\n\n访问时间 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\n\n文件大小 5,952 原生文件文档/电子邮件的大小，以 KB 计\n\n页数 1 原生文件文档/电子邮件中的页数\n\n路径 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。\n\n内部文件路径 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）\n\n内部邮件标识 <000805c2c71b\\$75977050\\$cb8306d1@MSN> 电子邮件：唯一邮件标识\n原生文件：（空）\n\nMD5 哈希值 d131dd02c5e6eec4693d9a0698aff95c2fcab58712467eab4004583eb8fb7f89 文档的 MD5 哈希值。\n\nOCR 路径 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. 所有文件应按其在正常业务过程中保存的方式提供，或者应予以组织和标注，使其与本请求中的类别相对应。\n\n5. 本文所载的每项请求均延伸至所有文件：(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，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案件 22-50073 文档 839 于 09/07/22 提交 于 09/07/22 20:02:47 登记 第 115 页，共 491 页\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) 识别编制或撰写该文件的人员（以及，如适用，识别该文件被发送给的人员）；(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) 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) 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) 陈述：(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说明；(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，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) 您将据以支持该等特权主张的所有情况；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，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。\n案件 22-50073 文档 839 于 09/07/22 提交 于 09/07/22 20:02:47 登记 第 116 页，共 491 页\n\n9. 如一份本应响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。特此指示您：(a) 一旦得知先前答复不完整或不正确，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) 提供根据下列要求的任何其他文件。\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 起至应提交文件请求答复之日止。\n案件 22-50073 文档 839 于 09/07/22 提交 于 09/07/22 20:02:47 登记 第 117 页，共 491 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；(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) “和”及“或”应视必要解释为连词或析取词，以将否则可能被解释为处于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“每一个”及“全部”。\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，应适用于文件请求。此外，本文件请求中所使用的下列术语应具有下列含义：\n\n1. “您”或“您的”或“您本人”系指 Jesse Brown（杰西·布朗），连同其所有关联方、部门、机构、工具、处室、合伙人、高级职员、董事、代理人、律师、代表、雇员，及/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. “债务人的儿子”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案件 22-50073 文档 839 于 09/07/22 提交 于 09/07/22 20:02:47 登记 第 118 页，共 491 页\n\n4. “债务人的女儿”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. “债务人的所谓妻子”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之人。\n\n6. “债务人的家庭成员”系指债务人、债务人的儿子、债务人的女儿及债务人的所谓妻子，合称为一体，以及与债务人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下列情形的所有个人：(1) 持有、控制、保管债务人或债务人的家庭成员所拥有、控制或享有的资产，或对该等资产拥有处置权；或 (2) 曾为一项或多项关联实体的雇员、董事，或以其他方式与其有关联；连同前述任何人员各自的雇员、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：Daniel Podhaskie（丹尼尔·波达斯基）、Jason Miller（杰森·米勒）、Steve Bannon（史蒂夫·班农）、Karin Maistrello（卡琳·迈斯特雷洛）、Melissa Francis（梅丽莎·弗朗西斯）、William Gertz（威廉·格茨）、Arethusa Forsyth（阿瑞苏莎·福赛斯）、Glenn Mellor（格伦·梅勒）、Jennifer Mercurio（詹妮弗·梅库里奥）、Eduardo Eurnekian（爱德华多·尤尔内基安）、Han Chunguang（韩春光）（又名 韩春光）、Qu Guojiao（屈国姣）（又名 Qu Guo Jiao、屈国姣）、Guo Lijie（郭丽杰）（又名 郭丽杰）、Zhang Wei（张伟）（又名 张伟*）、Lihong Wei Lafrenz（魏丽红）（又名 Sara Wei、魏丽红）、Hao Haidong（郝海东）（又名 郝海东）、Ross Heinemeyer（罗斯·海内迈耶）、Max Krasner（马克斯·克拉斯纳）、Kyle Bass（凯尔·巴斯）、Melissa Mendez（梅丽莎·门德斯）、Ya Li（李娅）（又名 李娅）、Dinggang Wang（王定刚）（又名 王定刚）、An Hong（安红）（又名 安红）、Yvette Wang（王雁平）（又名 Yanping Wang、Yan Ping Wang、王雁平）、Fiona Yu（菲奥娜·余）、Je Kin Ming（余建明）（又名 William Je、Yu Jianming、余建明）、Yaz Qingua（亚兹·钦瓜）及 Lao Jiang（姜云浮）（又名 Jiang Yunfu、Jiang Yunfu Be、姜云浮）。\n案件 22-50073 文档 839 于 09/07/22 提交 于 09/07/22 20:02:47 登记 第 119 页，共 491 页\n\n8. “关联实体”系指，单独或共同地，所有符合下列情形的任何类型组织或实体：(1) 已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士。该等关联实体包括但不限于：7 Nod Hill LLC（7诺德山有限责任公司）、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（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）、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（阿尔卑斯受托人股份公司）、Anton Development Limited（安东开发有限公司）、Assets Sino Limited（中资资产有限公司）、Auspicious Coast Limited（吉祥海岸有限公司）、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（北京鼎峰控股有限公司）、Bravo Luck Limited（好运有限公司）、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（黎明国度有限公司）、Eastern Profit Corporation Limited（东方利润有限公司）、Elite Well Global Limited（精英富源全球有限公司）、Empire Growth Holdings（帝国增长控股）、G Club Operations LLC（G俱乐部运营有限责任公司）、G Fashion LLC（G时尚有限责任公司）、G News LLC（G新闻有限责任公司）、GETTR USA（GETTR美国）、Genever Holdings Corporation（吉尼弗控股公司）、Genever Holdings LLC（吉尼弗控股有限责任公司）、GFASHION MEDIA GROUP INC.（GFASHION媒体集团公司）、GFNY, Inc.（GFNY公司）、Globalist International Limited（全球主义者国际有限公司）、GNews Media Group Inc.（GNews媒体集团公司）、Golden Spring (New York) Ltd.（金泉〈纽约〉有限公司）、Greenwich Land LLC（格林尼治土地有限责任公司）、Guo Media（郭媒体）、GTV Media Group, Inc.（GTV媒体集团公司）、Hamilton Capital Holdings Inc.（汉密尔顿资本控股公司）、Head Win Group Limited（领赢集团有限公司）、Henan Yuda（河南裕达）、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 Supervisory Organization（喜马拉雅监督组织）、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）、Infinite Increase Limited（无限增长有限公司）、Infinitum Developments Limited（无限发展有限公司）、Insight Phoenix Fund（洞察凤凰基金）、Lamp Capital LLC（蓝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）、Long Gate Limited（长龙门有限公司）、Next Tycoon Investments Limited（下一大亨投资有限公司）、New Federal State of China（中国新联邦国，亦称 NFSC）、Noble Fame Global Limited（高贵名望全球有限公司）、Rosy Acme Ventures Limited（玫瑰顶点创投有限公司）、Rule of Law Foundation III, Inc.（法治基金会III公司）、Rule of Law Foundation IV, Inc.（法治基金会IV公司）、Rule of Law Fund（法治基金）、Rule of Law Society（法治协会）、Rule of Law Society IV, Inc.（法治协会IV公司）、G-Translators PTY LTD（G-翻译员私人有限公司）、Saraca Media Group, Inc.（娑罗双媒体集团公司）、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）、Spirit Charter Investment Limited（精神宪章投资有限公司）、Stevenson, Wong & Co.（史蒂文森、黄律师事务所）、Voice of Guo Media, Inc.（郭媒体之声公司）、Well Origin Ltd.（良源有限公司）、World Century Limited（世界世纪有限公司）、Worldwide Opportunity Holdings Limited（全球机遇控股有限公司）、Whitecroft Shore Limited（怀特克罗夫特海岸有限公司）及 ZIBA Limited（ZIBA有限公司）。\n\n9. “包括”或其任何变体，系指“包括但不限于”。\n\n10. “和”及“或”均系指“和/或”，并应同时作连词及析取词解释，以最大限度扩大其范围。\n\n11. “任何”及“全部”与“每一”均系指“每一及全部”。\n\n12. “每一”及“每个”均系指“每一及全部”。\n\n13. “第三方”系指除贵方以外的人士或实体。\n\n14. “转让”应具有《破产法》section 101(54) 赋予该词的含义。\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贵方占有、保管或控制，包括电子邮件的所有印刷副本及电子副本、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、图形、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、账簿、分类账、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、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，无论以何种方式储存（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，如其中包含原始文件中未载有的任何类型笔记、评论或标记，或其在其他方面与原始文件不相同。\n\n16. “人士”系指个人、公司、独资企业、合伙企业、协会或任何其他实体。“人士”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”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、相关、支持、赞成、反对、强化、减损、载于、结合考虑、影响、证明、表明、报告、记录、暗示、回应、连接、评论、就……而言、有关、与……相关、讨论、展示、描述、反映、分析、构成及为。\n\n19. “与……有关”、“与……相关”或“有关”，在提及任何特定事项时，系指但不限于构成、包含、涉及、载有、体现、反映、识别、陈述、直接或间接提及该特定事项，或以任何方式与所识别的特定事项有关的任何文件。\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）。通信进一步指所有谈话、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，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、传真、电传副本、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”系指能够用于产生积极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，以及预期经济机会\n\n22. “转让”应具有《破产法》section 101(54) 赋予该词的含义。\n\nIV. 应提交的文件\n\n1. 与债务人、债务人财产或关联实体的任何收入或资产有关的全部文件。\n\n2. 与债务人的财务状况及其对债权人承担的义务有关的全部文件，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. 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有关的全部文件，包括但不限于足以显示向前述任何一方作出的全部转让的全部文件。\n\n4. 与债务人作出、与债务人进行或代表债务人作出的任何投资、商业往来或交易有关的全部文件。\n\n5. 与债务人的全部通信，以及与债务人的通信有关并涉及任何实体（包括但不限于关联实体）运营、管理或决策的文件。\n\n6. 与向债务人、债务人家庭成员或关联实体作出、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全部文件。\n\n7. 与债务人曾经占用或使用的任何财产有关的全部文件，包括但不限于 Lady May（梅夫人号）；Sherry Netherland Hotel / Condominium（雪莉荷兰酒店/公寓）；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；以及位于 Connecticut（康涅狄格州）Wilton（威尔顿）354 Nod Hill Rd. 的住宅房产。\n\n8. 与债务人、债务人家庭成员或关联实体于 2020年7月前后或任何其他时间进行的任何原油期货或任何类似商品投资或交易有关的全部文件，包括但不限于与 Jiang Yunfu Be（贝江云富）就任何该等投资或交易进行的通信。\n\n9. 与债务人拥有、控制或使用的任何飞机有关的全部文件，包括但不限于尾号为 T7-GQM 的飞机及任何其他在 San Marino（圣马力诺）登记的飞机，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机上人员的飞行清单。\n\n10. 与向债务人、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、利益或贷款有关的全部文件，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；与任何贷款有关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的文件。\n\n11. 与由债务人、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有关的全部文件，包括但不限于足以显示该等信托设立时间、设立人、受益人及信托本金的文件。\n\n12. 与涉及债务人的任何法律争议相关的任何义务、债权、责任或债务有关的全部文件，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\n13. 贵方任何外部法律顾问或其他顾问与债务人之间的全部文件及通信。\n\n14. 足以显示贵方全部资产及收入或资金来源的文件。\n\n15. 对于就请求第14项所识别的价值超过 $50,000 的全部资产，(i) 与贵方取得该等资产有关的全部文件，以及 (ii) 与债务人或债务人家庭成员就该等资产进行的通信。\n\n16. 您的纳税申报表副本。\n\n17. 足以显示由您持有或控制的所有银行账户和投资账户的文件，包括每一该等账户的余额以及向其转入和从其转出的款项。\n\n18. 与您使用的任何信用卡有关的所有文件，包括但不限于月度对账单或其他足以显示为债务人或关联实体利益而进行的所有相关购买的文件。\n\n19. 与将您的任何资产质押给任何其他实体有关的所有文件。\n\n案件 22-50073 文件 839 提交于 09/07/22 录入于 09/07/22 20:02:47 第 126 页，共 491 页\n\nB2540（表格2540——规则2004审查传票）（第2页）\n\n我于（日期）收到送达给（个人姓名及职务，如有）：____________________________________________________________的本传票。\n\n我于（日期）___________________通过向被指名人交付副本送达本传票；或者按如下方式送达：____________________________________。\n\n我未执行而退回本传票，原因是：__________________________________________________________________。\n\n除非本传票是代表美利坚合众国或其官员或代理人签发，我亦已向证人预付其一天出席的费用及法律允许的里程费，金额为 \\$ _______________________ 。\n\n我的费用为旅行 \\$ _________，服务 \\$_________，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关于尝试送达等事项的补充信息：\n\n《联邦民事诉讼规则》第45条(c)、(d)、(e)和(g)（2013年12月1日生效）（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，若该人\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) 在待检查场所进行场所检查。\n\n(d) 对受传票约束者的保护；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，以避免对受传票约束者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，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，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) 送达方可随时通知被命令人后，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) 仅可依命令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的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。经及时提出动议，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；(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，且不适用任何例外或豁免；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。为保护受传票约束或受其影响的人，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的意见或信息；该意见或信息并未描述争议中的具体事件，且源于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。在第45(d)(3)(B)条所述情形中，如送达方：\n\n(i) 证明对该证言或材料存在重大需要，且无法在不造成不当困难的情况下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，而命令在指定条件下出席或提交。\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。答复要求提交文件的传票的人，必须按照文件在通常业务过程中保存的方式提交，或者将文件整理并标注，以对应请求中的类别。\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，答复者必须以其通常保存的一种或多种形式，或者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。答复者无须以一种以上形式提交相同的电子存储信息。\n\n(D) 无法合理访问的电子存储信息。答复者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。对于强制证据开示的动议或保护令动议，答复者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，下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) 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，必须：\n\n(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) 已提交的信息。如为答复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。要求履行的地区法院，以及在动议被移送后签发传票的法院，可以藐视法庭罪处罚已被送达但无充分理由不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附件 C-6\n\nB2540（表格2540——规则2004审查传票）（12/15）美国破产法院 案件 22-50073 文件 839 提交于 09/07/22 录入于 09/07/22 20:02:47 第 129 页，共 491 页\n\n____________________________________________________________ 地区：____________________________________________________________ Connecticut（康涅狄格州）\n\n关于____________________________________________________________事项\n\n案号：____________________________ Ho Wan Kwok（郭文贵）22-50073\n\n债务人\n\n第________________章 11\n\n规则2004审查传票\n\n致：________________________________________________________________________________________________ ACA Capital Group Limited（ACA资本集团有限公司）\n\n（传票所指向之人的姓名）\n\n证言：兹命令您于下列载明的时间、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 日期和时间\n\nPaul Hastings LLP\n200 Park Avenue\nNew York, New York 10166\n\n审查将通过下列方式记录：____________________________________________________________________________ 法庭记录员/速记员\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，并必须允许检查、复制、测试或抽样该等材料：\n\n见随附的文件提交请求。\n\n根据 Fed. R. Bankr. P. 9016 适用于破产案件的 Fed. R. Civ. P. 45 的下列规定随附于此——有关履行地点的第45(c)条；有关您作为受传票约束者所获保护的第45(d)条；以及有关您答复本传票的义务和未予答复的潜在后果的第45(e)条和第45(g)条。\n\n日期：September ____________________ __, 2022\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 Patrick R. Linsey（ct29437）\n\n代表（当事人姓名）________________________________________、签发或请求本传票的律师的姓名、地址、电子邮件地址和电话号码如下：Luc Despins, Ch. 11 Trustee（Luc Despins，第11章受托人）\n\nPatrick R. Linsey, Esq.; Neubert, Pepe & Monteith, P.C.; 195 Church Street, New Haven, Connecticut 06510 plinsey@npmlaw.com; 203-821-2000\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供文件、以电子方式存储的信息或有形物品，或检查场所，则必须在向本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文件提供请求\n\n一、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。除非贵方出于善意提出异议，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，或其中所含的某个词语、短语或条款，贵方仅须就该部分说明异议，并答复其余请求。\n\n2. 以电子方式存储的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。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\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。通往文本文件的完整路径（OCRPATH）应列入 .DAT 文件。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位于单独的文件夹中，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）。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。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。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 文件中以字段形式列入通往原生文件的路径。所提供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。对于存在完全重复件的每份电子文件，提供一份副本。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 标准的加载文件（.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。下列为必需元数据：\n案号 22-50073 文件 839 提交于 09/07/22 录入于 09/07/22 20:02:47 第 132 页，共 491 页\n\n字段名称 示例数据 说明\n\nFIRSTBATES EDC0000001 原生文件/电子邮件文件的第一个 Bates 编号\nLASTBATES EDC0000001 原生文件/电子邮件文件的最后一个 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\nEDC0000015 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\n\nFROM John Smith 电子邮件：发件人\n原生文件：文件作者\n\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\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\n时区。\nLINK >EDC0000001.msg 通向电子邮件或原生文件的超链接\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\n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案号 22-50073 文件 839 提交于 09/07/22 录入于 09/07/22 20:02:47 第 133 页，共 491 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，\n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\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该数据必须为独立字段，不得\n与 DATE_ACCESSD 字段合并\nFILE_SIZE 5,952 原生文件/电子邮件文件的大小，以 KB 计\nPGCOUNT 1 原生文件/电子邮件文件的页数\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，\nItems\\Board Meeting 包括原始文件名。\nMinutes.msg 原生文件：（空）\nINTMSGID <000805c2c71b\\$75977050\\$ 电子邮件：唯一消息\nID 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. 所有文件应按通常业务过程中保存的方式提供，或者应予以整理和标识，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) 在贵方占有、保管或控制之下的文件；或 (b) 在代表贵方行事的任何人占有、保管或控制之下的文件，\n案号 22-50073 文件 839 提交于 09/07/22 录入于 09/07/22 20:02:47 第 134 页，共 491 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，该文件被发送给的人员）；(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) 说明该文件最后一次由贵方占有、保管或控制的时间；以及 (i) 指明现时占有、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，则指明该等人员的身份，\n案号 22-50073 文件 839 提交于 09/07/22 录入于 09/07/22 20:02:47 第 135 页，共 491 页\n\n并说明该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全部情形；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。\n\n9. 如一份本应提交的文件中有一部分信息属于特权主张的对象，则仅应按照上述指示从该文件中删除或遮蔽属于该特权主张对象的部分，其余部分应予提交。\n\n10. 该等请求具有持续性。现指示你方：(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发现不完整或不正确的答复；以及 (b) 提交根据下述规定所要求的任何补充文件。\n\n11. 如一份文件使用英语以外的语言，你方应提供该文件。如一份文件使用英语以外的语言，且存在英文译本，你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、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 文书 839 提交于 09/07/22 登记于 09/07/22 20:02:47 第 136 页，共 491 页\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在所有其他时态中使用该动词。\n\n16. (a) “和”与“或”应视为必要时采用连言或选言解释，以将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) “每一”与“任何”应视为包括并涵盖“每一个”和“所有”二词。\n\nIII. 定义\n\n经由 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. “你”或“你的”或“你自己”系指 ACA Capital Group Limited（ACA资本集团有限公司），连同其所有关联方、部门、机构、工具机构、分支、办事处、合伙人、高级职员、董事、代理人、律师、代表、雇员，及/或任何代表其行事之人。\n\n2. “债务人”系指 Ho Wan Kwok（郭文贵）（又称 Miles Kwok、Miles Guo、Guo Wengui、Guo Haoyun、郭文贵或任何其他化名），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）（又称 Mileson Kwok、郭强或任何其他化名），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 839 提交于 09/07/22 登记于 09/07/22 20:02:47 第 137 页，共 491 页\n\n4. “债务人之女”系指 Mei Guo（郭美）（又称 Mei Gui、郭美或任何其他化名），连同其雇员、代理人、律师、顾问或任何代表其行事之人。\n\n5. “债务人所谓之妻”系指 Hing Chi Ngok（岳庆芝）（又称 Hing Chi Ng、Yue Qingzhi、岳庆芝或任何其他化名），连同其雇员、代理人、律师、顾问或任何代表其行事之人。\n\n6. “债务人家属”统称债务人、债务人之子、债务人之女及债务人所谓之妻，以及与债务人有任何其他家庭关系之人。\n\n7. “关联个人”系指单独及共同而言，所有：(1) 持有、控制、保管债务人或债务人家属拥有、控制或享有的资产，或对该等资产拥有酌处权的个人；或 (2) 曾担任一个或多个关联实体的雇员、董事，或以其他方式与其关联的个人，连同前述任何一方各自的雇员、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：Daniel Podhaskie（丹尼尔·波德哈斯基）、Jason Miller（杰森·米勒）、Steve Bannon（史蒂夫·班农）、Karin Maistrello（卡琳·迈斯特雷洛）、Melissa Francis（梅丽莎·弗朗西斯）、William Gertz（威廉·格茨）、Arethusa Forsyth（阿雷图莎·福赛思）、Glenn Mellor（格伦·梅勒）、Jennifer Mercurio（詹妮弗·默丘里奥）、Eduardo Eurnekian（爱德华多·埃尔内基安）、Han Chunguang（韩春光）（又称 韩春光）、Qu Guojiao（屈国姣）（又称 Qu Guo Jiao、屈国姣）、Guo Lijie（郭丽杰）（又称 郭丽杰）、Zhang Wei（张伟）（又称 张伟*）、Lihong Wei Lafrenz（魏丽红）（又称 Sara Wei、魏丽红）、Hao Haidong（郝海东）（又称 郝海东）、Ross Heinemeyer（罗斯·海内迈耶）、Max Krasner（马克斯·克拉斯纳）、Kyle Bass（凯尔·巴斯）、Melissa Mendez（梅丽莎·门德斯）、Ya Li（李娅）（又称 李娅）、Dinggang Wang（王定刚）（又称 王定刚）、An Hong（安红）（又称 安红）、Yvette Wang（王雁平）（又称 Yanping Wang、Yan Ping Wang、王雁平）、Fiona Yu（菲奥娜·余）、Je Kin Ming（余建明）（又称 William Je、Yu Jianming、余建明）、Yaz Qingua（亚兹·钦瓜）及 Lao Jiang（姜云浮）（又称 Jiang Yunfu、Jiang Yunfu Be、姜云浮）。\n案件 22-50073 文书 839 提交于 09/07/22 登记于 09/07/22 20:02:47 第 138 页，共 491 页\n\n8. “关联实体”系指单独及共同而言，所有类型的组织或实体：(1) 曾由债务人或债务人家属拥有、控制或投资；或 (2) 直接或间接对债务人或债务人家属拥有、控制或享有的任何资产拥有权益，连同前述任何一方各自的雇员、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：7 Nod Hill LLC（7诺德山有限责任公司）、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（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）、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（阿尔卑斯受托人股份公司）、Anton Development Limited（安东开发有限公司）、Assets Sino Limited（中资资产有限公司）、Auspicious Coast Limited（吉祥海岸有限公司）、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（北京泽尼思控股有限公司）、Bravo Luck Limited（布拉沃幸运有限公司）、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（克兰咨询集团有限责任公司）、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（黎明国度有限公司）、Eastern Profit Corporation Limited（东方利润有限公司）、Elite Well Global Limited（精英环球有限公司）、Empire Growth Holdings（帝国增长控股）、G Club Operations LLC（G俱乐部运营有限责任公司）、G Fashion LLC（G时尚有限责任公司）、G News LLC（G新闻有限责任公司）、GETTR USA（GETTR美国）、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（环球主义者国际有限公司）、GNews Media Group Inc.（GNews媒体集团公司）、Golden Spring (New York) Ltd.（金泉〈纽约〉有限公司）、Greenwich Land LLC（格林尼治土地有限责任公司）、Guo Media（郭媒体）、GTV Media Group, Inc.（GTV媒体集团公司）、Hamilton Capital Holdings Inc.（汉密尔顿资本控股公司）、Head Win Group Limited（领先胜利集团有限公司）、Henan Yuda（河南裕达）、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 Supervisory Organization（喜马拉雅监督组织）、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）、Infinite Increase Limited（无限增长有限公司）、Infinitum Developments Limited（无限开发有限公司）、Insight Phoenix Fund（洞察凤凰基金）、Lamp Capital LLC（兰普资本有限责任公司）、Leading Shine Limited（领先光辉有限公司）、Leading Shine NY Limited（领先光辉纽约有限公司）、Long Gate Limited（长龙门有限公司）、Next Tycoon Investments Limited（下一大亨投资有限公司）、New Federal State of China（新中国联邦）（又称 NFSC）、Noble Fame Global Limited（高贵名声全球有限公司）、Rosy Acme Ventures Limited（玫瑰顶点创投有限公司）、Rule of Law Foundation III, Inc.（法治基金会III公司）、Rule of Law Foundation IV, Inc.（法治基金会IV公司）、Rule of Law Fund（法治基金）、Rule of Law Society（法治协会）、Rule of Law Society IV, Inc.（法治协会IV公司）、G-Translators PTY LTD（G-翻译者有限公司）、Saraca Media Group, Inc.（萨拉卡媒体集团公司）、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）、Spirit Charter Investment Limited（精神宪章投资有限公司）、Stevenson, Wong & Co.（史蒂文森、黄氏律师事务所）、Voice of Guo Media, Inc.（郭媒体之声公司）、Well Origin Ltd.（良好起源有限公司）、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）、Whitecroft Shore Limited（怀特克罗夫特海岸有限公司）及 ZIBA Limited（ZIBA有限公司）。\n\n9. “包括”或其任何变体，意指“包括但不限于”。\n\n10. “和”与“或”意指“和/或”，并应同时作连言及选言解释，以最大限度扩大其范围。\n\n11. “任何”、“所有”及“每一”意指“每一个及所有”。\n\n12. “每一”及“每个”意指“每一个及所有”。\n\n13. “第三方”系指你方以外的个人或实体。\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 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打印及电子副本、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、信件、电报、照片、会议记录、合同、协议、调查资料、计算机打印件、数据\n案件 22-50073 文书 839 提交于 09/07/22 登记于 09/07/22 20:02:47 第 140 页，共 491 页\n\n汇编资料、电传、传真、语音信息、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、账簿、分类账、笔记本、清单、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，无论以何种方式存储（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\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”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”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”意指涉及、描述、包含、提及、与之有关、支持、赞成、反对、加强、减损、位于其中、与之相关地加以考虑、对其有影响、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、构成及为其。\n\n19. “涉及”、“涉及到”或“相关”，在指称任何特定事项时，意指但不限于构成、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有关的任何文件。\n案件 22-50073 文书 839 提交于 09/07/22 登记于 09/07/22 20:02:47 第 141 页，共 491 页\n\n20. “通信”系指在最广泛的可能意义上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）。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、语音信息、电报、电话传真、传真副本、电传、即时信息、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”系指可用于产生正向经济价值的任何项目，包括但不限于由某实体拥有、控制或为其利益而持有的、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、投资权利或取得未来收入的权利、现金、银行账户、商品、证券、请求权、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”具有《破产法典》第101(54)条赋予其的含义。\n\nIV. 应提交的文件\n\n1. 与债务人、债务人破产财团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，包括但不限于与避免支付该等义务的任何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无力偿债程序有关的所有文件。\n\n案件号 22-50073 文件 839 提交日期 09/07/22 录入日期 09/07/22 20:02:47 第 142 页，共 491 页\n\n3. 与债务人、债务人破产财团、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/或确认书、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文件。\n\n4. 与债务人作出、与债务人进行或代表债务人作出的任何投资、商业往来或交易有关的所有文件。\n\n5. 与债务人的所有通信，以及与债务人的通信有关、涉及任何实体（包括但不限于关联实体）的运营、管理或决策的文件。\n\n6. 与向债务人、债务人家庭成员或关联实体作出、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 Lady May；Sherry Netherland Hotel / Condominium；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；以及位于 Connecticut（康涅狄格州）Wilton（威尔顿）354 Nod Hill Rd. 的住宅物业。\n\n8. 与债务人、债务人家庭成员或关联实体于 2020年7月前后或任何其他时间在原油期货或任何类似商品中的任何投资或交易有关的所有文件，包括但不限于与 Jiang Yunfu Be 就任何该等投资或交易进行的通信。\n\n案件号 22-50073 文件 839 提交日期 09/07/22 录入日期 09/07/22 20:02:47 第 143 页，共 491 页\n\n9. 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以及显示该等航空器所执行航班及该等航班上人员的飞行清单。\n\n10. 与向债务人、债务人破产财团、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\n11. 与由债务人、债务人破产财团、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安排有关的所有文件，包括但不限于足以显示该等信托设立时间、设立人、受益人及信托财产的文件。\n\n12. 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）进行的任何诉讼有关的文件。\n\n13. 您的任何外聘法律顾问或其他顾问与债务人之间的所有文件和通信。\n\n案件号 22-50073 文件 839 提交日期 09/07/22 录入日期 09/07/22 20:02:47 第 144 页，共 491 页\n\n14. 足以显示您的所有资产及收入或资金来源的文件。\n\n15. 对于就请求第14项所确认的、价值超过 \\$50,000 的所有资产，(i) 与您取得该等资产有关的所有文件，以及 (ii) 与债务人或债务人家庭成员就该等资产进行的通信。\n\n16. 您的纳税申报表副本。\n\n17. 足以显示由您占有或控制的所有银行账户和投资账户的文件，包括每一该等账户的余额以及向该等账户的转入和从该等账户的转出。\n\n18. 与您使用的任何信用卡有关的所有文件，包括但不限于月度对账单或其他足以显示为债务人或关联实体利益而作出的所有相关购买的文件。\n\n19. 所有公司治理及组织文件，包括但不限于章程细则、公司注册证书，以及足以显示您的公司架构、高级职员和董事姓名、经营目的以及与债务人或债务人任何家庭成员关系的其他文件。\n\n20. 与您向任何其他实体质押任何资产有关的所有文件。\n\n案件号 22-50073 文件 839 提交日期 09/07/22 录入日期 09/07/22 20:02:47 第 145 页，共\n\nB2540（表格 2540——依据第2004条规则审查的传票）（第 2 页） 491\n\n本人已于（个人姓名及职务，如有）：______________________________________________\n\n（日期）收到本传票\n\n本人已通过向被指定人员交付副本的方式送达本传票\n\n于（日期）___________________；或按如下方式送达：____________________________________\n\n本人退回未执行的传票，原因是：____________________________________________________________\n\n除非本传票系代表 United States（美国）或其官员或代理人签发，本人还已向证人支付一日出席费用及法律允许的里程费，金额为 \\$ _______________________ 。\n\n本人的费用为 \\$ _________\n\n交通费，以及 \\$_________ 服务费，合计 \\$_________\n\n本人在伪证处罚的约束下声明\n\n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)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、受雇或经常亲自进行商业活动地点 100 英里范围内；或\n\n(B) 在该人居住、受雇或经常亲自进行商业活动所在州内，且该人\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、受雇或经常亲自进行商业活动地点 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) 在待检查场所进行场所检查。\n\n(d) 对受传票约束者的保护；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，避免对受传票约束者施加不当负担或费用。要求履行传票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，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。异议必须于规定的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，送达方可在通知被命令人的情况下，向要求履行传票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) 仅可按该命令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，要求履行传票的地区法院必须撤销或修改符合下列情形的传票：\n\n(i) 未留出合理履行时间；(ii) 要求某人在超出第45(c)条规定的地理范围外履行；(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。为保护受传票约束或受其影响的人，要求履行传票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，且系该专家进行的、非由当事人请求的研究所得。\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，且若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) 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。响应要求提交文件的传票的人，必须按其在日常经营过程中保存的方式提交文件，或必须按要求中的类别对文件进行整理和标记。\n\n(B) 未规定电子存储信息的提交形式。如传票未规定电子存储信息的提交形式，响应者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该等信息。\n\n(C) 仅以一种形式提供的电子存储信息。答复人无需以多种形式提供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。答复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。在提出强制证据开示动议或申请保护令时，答复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，法院在考虑规则 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) 被扣留的信息。以该信息享有特权或受审判准备材料保护为由扣留被传唤信息的人必须：\n\n(i) 明确提出该主张；以及\n\n(ii) 以一种方式说明被扣留文件、通信或有形物的性质，使各方能够评估该主张，同时不披露本身享有特权或受保护的信息。\n\n(B) 已提供的信息。如为响应传票而提供的信息涉及特权主张或审判准备材料保护主张，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一方。收到通知后，一方必须立即返还、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；如该方在收到通知前已披露该信息，必须采取合理措施予以追回；并可立即将该信息密封提交至要求遵从的地区法院，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全该信息。\n\n(g) 藐视法庭。在要求遵从的地区的法院，以及在动议移送后签发传票的法院，均可对已被送达但无充分理由不遵从传票或相关命令的人作出藐视法庭认定。\n\n如需查阅传票材料，见 Fed. R. Civ. P. 45(a) Committee Note (2013)\n\n……\n\n附件 C-7\n\nB2540（表格 2540－规则第 2004 条审查传票）（12/15）Case 22-50073 Doc 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 148 of 491\n\nUNITED STATES BANKRUPTCY COURT（美国破产法院）\n\n_________________________________________________________________ District of（地区）_____________________________________________________________ Connecticut（康涅狄格）\n\nIn re（关于）_________________________________________________________________\n\nCase No.（案号）_______________________ Ho Wan Kwok（郭文贵）22-50073\n\nDebtor（债务人）\n\nChapter（章）____________ 11\n\n规则第 2004 条审查传票\n\n致：________________________________________________________________________________________________ William Je（杰威廉）\n\n（传票所指向人员的姓名）\n\n证言：兹命令你于下列规定的时间、日期和地点出席，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\nPaul Hastings LLP（普衡律师事务所）\n200 Park Avenue\nNew York, New York 10166\n\n该审查将采用以下方法记录：_____________________________________________________________________________ 法庭记录员／速记员\n\n提交材料：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以下 Fed. R. Civ. P. 45 的规定，依 Fed. R. Bankr. P. 9016 适用于破产案件，随附于此——有关遵从地点的规则 45(c)；有关你作为受传票约束之人的保护的规则 45(d)；以及有关你对本传票的答复义务及未答复的潜在后果的规则 45(e) 和 45(g)。\n\n日期：September __________________ __, 2022\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 Patrick R. Linsey（帕特里克·R·林赛）(ct29437)\n\n代表（当事人姓名）____________________________、签发或申请本传票的律师的姓名、地址、电子邮箱地址和电话号码如下：Luc Despins（吕克·德斯潘），第 11 章受托人\n\nPatrick R. Linsey, Esq.; Neubert, Pepe & Monteith, P.C.（诺伊伯特、佩佩和蒙泰思律师事务所）；195 Church Street, New Haven, Connecticut 06510；plinsey@npmlaw.com；203-821-2000\n\n致签发或申请本传票之人的通知\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，或检查场所，则必须在向传票所指向的人送达之前，向每一方送达本传票的通知和副本。Fed. R. Civ. P. 45(a)(4)。\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（简称“请求”，每项单称“一项请求”）必须分别且具体作出答复。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你提出异议的理由。如异议仅涉及某项请求的一部分，或其中包含的某个词语、短语或条款，你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。每幅图像的右下角必须加注连续的 Bates 编号。每个文件夹中的 TIFF 文件数量不应超过 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\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。文本必须作为独立文本文件提供，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. 某些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，必须以原生格式提供。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，表明原生文件的存在，并将原生文件路径作为字段包含在 .dat 文件中。以与该文件分隔页相对应的 Bates 编号命名所提供的原生文件。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，仅提供一份副本。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。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。以下为要求提供的元数据：\n\nCase 22-50073 Doc 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 151 of 491\n\n字段名称 示例数据 说明\n\nFIRSTBATES EDC0000001 原生文件／电子邮件文件的第一个 Bates 编号\n\nLASTBATES EDC0000001 原生文件／电子邮件文件的最后一个 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 电子邮件：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\n\nFROM John Smith 电子邮件：发件人\n原生文件：文件作者\n\n分号应用于分隔多个条目\n\nTO Coffman, Janice；LeeW 收件人\n[mailto:LeeW@MSN.com] 分号应用于分隔多个条目\n\nCC Frank Thompson [mailto: 抄送收件人\nfrank_Thompson@cdt.com] 分号应用于分隔多个条目\n\nBCC John Cain 密件抄送收件人\n分号应用于分隔多个条目\n\nSUBJECT 董事会会议纪要 电子邮件：电子邮件的主题行 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/ 07:05 PM GMT 电子邮件：发送电子邮件的时间／所采用的时区\nTIME_ZONE 电子邮件在该时区内被标准化\n\nTIME_ZONE GMT 在转换期间电子邮件被标准化所采用的\n时\n区。\n\nLINK >EDC0000001.msg 指向电子邮件或原生文件文档的超链接\n链接文件必须以 FIRSTBATES 编号命名\n\nFILE_EXTEN MSG 代表电子邮件或\n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\n\n案件 22-50073 文书 839 提交于 09/07/22 录入于 09/07/22 20:02:47 第 152 页，共 491 页\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，且不得\n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该数据必须为单独字段，且不得\n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该数据必须为单独字段，且不得\n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（KB）\n\nPGCOUNT 1 原生文件文档／电子邮件的页数\n\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。\n\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）\n\nINTMSGID <000805c2c71b\\$75977050\\$ 电子邮件：唯一消息\nID 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. 每一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. 所有文件均应按照通常业务过程中保存的方式提供，或者应当予以组织和标记，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，\n\n案件 22-50073 文书 839 提交于 09/07/22 录入于 09/07/22 20:02:47 第 153 页，共 491 页\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) 确定编制或撰写该文件的人士（以及，如适用，该文件被发送给的人士）；(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) 以其他方式被处置；(e) 说明该等处置的理由及相关事实和情形；(f) 确定授权该等处置的人士；(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士身份，(vii) 该文件本身或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，则确定该等人士的身份，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所有情形；以及 (b) 根据 D. Conn. L. Civ. R. 26(e)，就每份基于特权主张而被扣留的文件，提供一份特权清单，其中载明本指示第 (a) 部分所要求的全部信息。\n\n案件 22-50073 文书 839 提交于 09/07/22 录入于 09/07/22 20:02:47 第 154 页，共 491 页\n\n该等人士，以及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) 您将据以支持该等特权主张的所有情形；以及 (b) 根据 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。兹指示您：(a) 一旦得知先前答复不完整或不正确，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) 提供根据以下规定所要求的任何额外文件\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，且存在英语译本，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的期间。\n\n案件 22-50073 文书 839 提交于 09/07/22 录入于 09/07/22 20:02:47 第 155 页，共 491 页\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包括该动词在所有其他时态中的使用。\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\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，本文件请求中所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 William Je，以及其所有关联方、部门、机构、办事机构、工具机构、科室、办公室、合伙人、高级职员、董事、代理人、律师、代表、雇员及／或任何代表其行事的人。\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、顾问或任何代表其行事的人。\n\n3. “债务人的儿子”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、顾问或任何代表其行事的人。\n\n案件 22-50073 文书 839 提交于 09/07/22 录入于 09/07/22 20:02:47 第 156 页，共 491 页\n\n4. “债务人的女儿”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、顾问或任何代表其行事的人。\n\n5. “债务人的声称妻子”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、顾问或任何代表其行事的人。\n\n6. “债务人家庭成员”统称债务人、债务人的儿子、债务人的女儿和债务人的声称妻子，以及与债务人具有任何其他家庭关系的人。\n\n7. “关联个人”单独及共同指：(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：Daniel Podhaskie、Jason Miller、Steve Bannon、Karin Maistrello、Melissa Francis、William Gertz、Arethusa Forsyth、Glenn Mellor、Jennifer Mercurio、Eduardo Eurnekian、Han Chunguang（韩春光，亦称 韩春光）、Qu Guojiao（屈国姣，亦称 Qu Guo Jiao、屈国姣）、Guo Lijie（郭丽杰，亦称 郭丽杰）、Zhang Wei（张伟，亦称 张伟*）、Lihong Wei Lafrenz（魏丽红，亦称 Sara Wei、魏丽红）、Hao Haidong（郝海东，亦称 郝海东）、Ross Heinemeyer、Max Krasner、Kyle Bass、Melissa Mendez、Ya Li（李娅，亦称 李娅）、Dinggang Wang（王定刚，亦称 王定刚）、An Hong（安红，亦称 安红）、Yvette Wang（王雁平，亦称 Yanping Wang、Yan Ping Wang、王雁平）、Fiona Yu、Je Kin Ming（余建明，亦称 William Je、Yu Jianming、余建明）、Yaz Qingua，以及 Lao Jiang（姜云浮，亦称 Jiang Yunfu、Jiang Yunfu Be、姜云浮）。\n\n案件 22-50073 文书 839 提交于 09/07/22 录入于 09/07/22 20:02:47 第 157 页，共 491 页\n\n8. “关联实体（Associated Entities）”系指单独或共同符合下列情形的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；或（2）直接或间接对债务人或债务人家庭拥有、控制或享有的任何资产享有权益，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。该等关联实体应包括但不限于：7 Nod Hill LLC（诺德山7号有限责任公司）、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（阿尔卑斯受托人股份公司）、Anton Development Limited（安东发展有限公司）、Assets Sino Limited（中资产有限公司）、Auspicious Coast Limited（吉祥海岸有限公司）、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（北京鼎盛控股有限公司）、Bravo Luck Limited（好运有限公司）、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（创新顶峰投资有限公司）、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）、Elite Well Global Limited（精英环球有限公司）、Empire Growth Holdings（帝国增长控股）、G Club Operations LLC（G俱乐部运营有限责任公司）、G Fashion LLC（G时尚有限责任公司）、G News LLC（G新闻有限责任公司）、GETTR USA（GETTR美国）、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（全球主义者国际有限公司）、GNews Media Group Inc.（GNews媒体集团公司）、Golden Spring (New York) Ltd.（金泉〈纽约〉有限公司）、Greenwich Land LLC（格林尼治土地有限责任公司）、Guo Media（郭媒体）、GTV Media Group, Inc.（GTV媒体集团公司）、Hamilton Capital Holdings Inc.（汉密尔顿资本控股公司）、Head Win Group Limited（领赢集团有限公司）、Henan Yuda（河南裕达）、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 Supervisory Organization（喜马拉雅监督组织）、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）、Infinite Increase Limited（无限增长有限公司）、Infinitum Developments Limited（无限发展有限公司）、Insight Phoenix Fund（洞见凤凰基金）、Lamp Capital LLC（灯资本有限责任公司）、Leading Shine Limited（领耀有限公司）、Leading Shine NY Limited（领耀纽约有限公司）、Long Gate Limited（长门有限公司）、Next Tycoon Investments Limited（下一个大亨投资有限公司）、New Federal State of China（中国新联邦国，亦称NFSC）、Noble Fame Global Limited（显赫名望全球有限公司）、Rosy Acme Ventures Limited（玫瑰顶峰创投有限公司）、Rule of Law Foundation III, Inc.（法治基金会III公司）、Rule of Law Foundation IV, Inc.（法治基金会IV公司）、Rule of Law Fund（法治基金）、Rule of Law Society（法治协会）、Rule of Law Society IV, Inc.（法治协会IV公司）、G-Translators PTY LTD（G-翻译者私人有限公司）、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）、Spirit Charter Investment Limited（精神宪章投资有限公司）、Stevenson, Wong & Co.（Stevenson, Wong & Co.）、Voice of Guo Media, Inc.（郭媒体之声公司）、Well Origin Ltd.（良好起源有限公司）、World Century Limited（世界世纪有限公司）、Worldwide Opportunity Holdings Limited（全球机遇控股有限公司）、Whitecroft Shore Limited（白克罗夫特海岸有限公司）及ZIBA Limited（ZIBA有限公司）。\n\n案号 22-50073，文件 839，提交于 09/07/22，录入于 09/07/22 20:02:47，第 158 页，共 491 页\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”，并应为最大限度扩大其适用范围而同时作连词性及选择性解释。\n\n11. “任何（Any）”“所有（all）”及“每一（each）”均系指“每一项及所有”。\n\n12. “每一（Each）”及“每一（every）”均系指“每一项及所有”。\n\n13. “第三方（Third Party）”系指除您本人以外的个人或实体。\n\n14. “转让（Transfer）”应具有《破产法典（Bankruptcy Code）》第101(54)条赋予该词的含义。\n\n15. “文件（Document）”系指属于《联邦民事诉讼规则（Fed. R. Civ. P.）》第34条范围内的任何信息或物件，包括但不限于处于您占有、保管或控制之下，或曾处于您占有、保管或控制之下的任何种类、类型、性质或描述的每一份书面、记录或图示材料，包括电子邮件的所有印刷版及电子版副本、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、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、投影片、录音、目录、广告、促销材料、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；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完全相同。\n\n案号 22-50073，文件 839，提交于 09/07/22，录入于 09/07/22 20:02:47，第 159 页，共 491 页\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（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. “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、构成、提及、与之相关、支持、赞成、反对、强化、削弱、位于其中、与之关联考虑、对之有影响、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、构成及为。\n\n19. 在提及任何特定事项时，“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、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事项相关的任何文件。\n\n案号 22-50073，文件 839，提交于 09/07/22，录入于 09/07/22 20:02:47，第 160 页，共 491 页\n\n20. “通信（Communication(s)）”系指在最广泛可能的意义上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）。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、电话笔记或与内部人员或第三方传送的笔记。\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、控制或为该实体利益而持有，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、投资权利或未来收入权利、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及预期经济机会。\n\n22. “转让（Transfer）”应具有《破产法典（Bankruptcy Code）》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、债务人财产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可能的破产或类似资不抵债程序有关的所有文件。\n\n案号 22-50073，文件 839，提交于 09/07/22，录入于 09/07/22 20:02:47，第 161 页，共 491 页\n\n3. 关于与债务人、债务人财产、债务人家庭、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一方作出的所有转让的所有文件。\n\n4. 关于由债务人作出、与债务人进行或代表债务人作出的任何投资、商业交易或交易活动的所有文件。\n\n5. 与债务人的所有通信，以及与债务人的通信有关的文件，该等通信涉及任何实体的运营、管理或决策，包括但不限于关联实体。\n\n6. 关于向债务人、债务人家庭或关联实体作出、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Lady May（梅夫人号）；Sherry Netherland Hotel / Condominium（雪莉荷兰酒店/公寓）；位于康涅狄格州格林尼治373 Taconic Rd.的不动产住宅；位于康涅狄格州格林尼治33 Ferncliff Rd.的不动产住宅；以及位于康涅狄格州威尔顿354 Nod Hill Rd.的不动产住宅。\n\n8. 与债务人、债务人家庭或关联实体于2020年7月前后或任何其他时间进行的任何原油期货或任何类似商品投资或交易有关的所有文件，包括但不限于与Jiang Yunfu Be（Jiang Yunfu Be）就任何该等投资或交易进行的通信。\n\n案号 22-50073，文件 839，提交于 09/07/22，录入于 09/07/22 20:02:47，第 162 页，共 491 页\n\n9. 与债务人拥有、控制或使用的任何航空器有关的所有文件，包括但不限于机尾编号为T7-GQM的航空器及在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。\n\n10. 关于向债务人、债务人财产、债务人家庭或关联实体提供、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全部证据的文件。\n\n11. 关于由债务人、债务人财产、债务人家庭或关联实体设立、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、设立所为受益人及信托财产的文件。\n\n12. 与涉及债务人的任何法律争议有关的任何义务、债权、责任或债务有关的所有文件，包括但不限于与任何地方、州、联邦或国际机构，无论为行政机关、法院、审裁小组或替代性争议解决实体，审理的任何诉讼有关的文件。\n\n13. 您的任何外部法律顾问或其他顾问与债务人之间的所有文件和通信。\n\n案号 22-50073，文件 839，提交于 09/07/22，录入于 09/07/22 20:02:47，第 163 页，共 491 页\n\n14. 足以显示您所有资产及收入或资金来源的文件。\n\n15. 对于在答复第14项请求时识别出的价值超过\\$50,000的所有资产，（i）与您取得该等资产有关的所有文件，以及（ii）与债务人或债务人家庭就该等资产进行的通信。\n\n16. 您的纳税申报表副本。\n\n17. 足以显示由您占有或控制的所有银行账户和投资账户的文件，包括每一该等账户的余额以及向该等账户和自该等账户进行的转账。\n\n18. 有关您使用的任何信用卡的所有文件，包括但不限于月度对账单或足以显示为债务人或关联实体利益而进行的所有相关购买的其他文件。\n\n19. 与向任何其他实体质押您的资产有关的所有文件。\n\n案号 22-50073 文件 839 提交日期 09/07/22 登记日期 09/07/22 20:02:47 第 164 页，共\n\nB2540（表格 2540——规则 2004 审查传票）（第 2 页） 491\n\n本人于（日期）收到向下列人士发出的本传票（个人姓名及职务，如有）：______________________________________________\n\n本人通过向被指名人士送达副本的方式送达传票\n\n于（日期）___________________；或按如下方式送达：____________________________________\n\n本人退回未执行的传票，原因如下：____________________________________________________________\n\n除非本传票代表美国或其官员或代理人发出，本人亦已向证人预付一天出庭费用及法律允许的里程费，金额为 \\$ _______________________。\n本人的费用为 \\$ _________\n交通费，以及 \\$_________ 服务费，合计 \\$_________\n本人在伪证罪处罚的约束下声明，\n该等信息真实且正确。\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有关尝试送达等事项的补充信息：\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(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一人出席审判、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) 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(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、以电子方式存储的信息或物品；以及\n\n(B) 在待检查处所对该处所进行检查。\n(d) 对受传票约束者的保护；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，避免对受传票约束者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(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、以电子方式存储的信息或有形物品，或允许检查处所的人，无须亲自到提交或检查地点出庭，除非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，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，或反对检查处所——或反对以所要求的一种或多种形式提交以电子方式存储的信息。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者后，向要求履行义务所在地区的法院提出动议，申请强制提交或检查的命令。\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者免于承担因履行义务而产生的重大费用。\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；(ii) 要求一人在超出\n\n第 45(c) 条规定的地理范围之外履行义务的；\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放弃的；或\n\n(iv) 对一人施加不当负担的。\n\n(B) 可以撤销或修改的情形。为保护受传票约束或受其影响者，要求履行义务所在地区的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未说明争议中的特定事件，并系该专家未应任何当事人请求而进行研究所得的结果。\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) 证明其对证言或材料具有重大需要，且如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) 确保受传票者将获得合理补偿，\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(e) 回应传票的义务。\n\n(1) 提交文件或以电子方式存储的信息。下列程序适用于提交文件或以电子方式存储的信息：\n\n(A) 文件。回应提交文件传票的人必须按文件在通常业务过程中保存的方式提交，或必须对其进行整理和标注，以对应请求中的类别。\n\n(B) 未指定提交以电子方式存储的信息的形式。如传票未指定提交以电子方式存储的信息的形式，回应者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) 以电子方式存储的信息仅以一种形式提交。回应者无须以一种以上形式提交相同的以电子方式存储的信息。\n\n(D) 无法获取的以电子方式存储的信息。回应者无须对其确定因不当负担或费用而无法合理获取的来源中的以电子方式存储的信息提供证据开示。在提出强制证据开示动议或保护令动议时，回应者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，仍可命令对该等来源进行证据开示。法院可就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保护为由而扣留被传唤信息的人，必须：\n\n(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受保护的主张，提出该主张者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。提交该信息者必须保存该信息，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，签发传票的法院——可对已经送达但无正当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欲查阅传票材料，请参见 Fed. R. Civ. P. 45(a) 委员会注释（2013）\n\n……\n\n附件 C-8\nB2540（表格 2540——规则 2004 审查传票）（12/15）UNITED STATES BANKRUPTCY COURT（美国破产法院）案号 22-50073 文件 839 提交日期 09/07/22 登记日期 09/07/22 20:02:47 第 167 页，共 491\n\n____________________________________________________________ 地区：____________________________________________________________ Connecticut（康涅狄格州）\n\n关于 ____________________________________________________________\n\n案号：________________________________ Ho Wan Kwok（郭文贵）22-50073\n\n债务人\n\n章节：__________________ 11\n规则 2004 审查传票\n\n致：________________________________________________________________________________________________________________________ Max Krasner（马克斯·克拉斯纳）\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，以根据《联邦破产程序规则》第 2004 条进行审查并作证。随附授权该审查的法院命令副本。\n\n地点 日期和时间\n\nPaul Hastings LLP（普衡律师事务所）\n200 Park Avenue\nNew York, New York（纽约州纽约市）10166\n\n审查将采用下列方式记录：____________________________________________________________ 法庭记录员/速记员\n\n提交：您或您的代表还必须携带下列文件、以电子方式存储的信息或物品出席审查，并且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下列《联邦民事诉讼规则》第 45 条规定经 Fed. R. Bankr. P. 9016 适用于破产案件，现随附于后——有关履行地点的第 45(c) 条；有关您作为受传票约束者所受保护的第 45(d) 条；以及有关您回应本传票的义务及不予回应可能后果的第 45(e) 条和第 45(g) 条。\n\n日期：September（九月）____，2022\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 Patrick R. Linsey（帕特里克·R·林赛）(ct29437)\n\n代表（当事人姓名）____________________________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：Luc Despins（吕克·德斯平斯），第 11 章受托人\n\nPatrick R. Linsey, Esq.（帕特里克·R·林赛律师）；Neubert, Pepe & Monteith, P.C.（纽伯特、佩佩及蒙泰思专业公司）；195 Church Street, New Haven, Connecticut（康涅狄格州纽黑文）06510；plinsey@npmlaw.com；203-821-2000\n致签发或请求本传票者的通知\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，则必须在向受送达人送达本传票之前，向各方送达本传票的通知及副本。Fed. R. Civ. P. 45(a)(4)。\n\n文件提交请求\n\n一、说明\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“请求”）必须分别并具体作出答复。除非基于善意提出异议，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，或其中所含的某个词语、短语或条款，您仅须说明对该部分的异议，并答复请求的其余部分。\n\n2. 电子存储信息必须依照下列说明提交：\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。每张图像右下角必须加盖连续的Bates编号。每个文件夹中的TIFF文件不得超过1000个。Excel电子表格应有一张以该文件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。不得在.DAT文件中包括文本。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及名称。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连接起来。该文件应为以逗号分隔的文件，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有一行，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，而非作为.DAT文件中的字段。文本文件的完整路径（OCRPATH）应列入.DAT文件。建议提交文件级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，每个文件夹内的文本文件不得超过1,000个。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- d. 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，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”目录中，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- f. 元数据。应以符合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：\n\nCase 22-50073 Doc 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 170 of 491\n\n字段名称 示例数据 说明\n\nFIRSTBATES EDC0000001 原生文件/电子邮件文件的第一个Bates编号\n\nLASTBATES EDC0000001 原生文件/电子邮件文件的最后一个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 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 电子邮件：发件人\n原生文件：文件作者\n**多个条目应以分号分隔\n\nTO Coffman, Janice; LeeW 收件人\n[mailto:LeeW@MSN.com] **多个条目应以分号分隔\n\nCC Frank Thompson [mailto: 抄送收件人\nfrank_Thompson@cdt.com] **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 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\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的超链接\n**链接文件必须按照FIRSTBATES编号命名\n\nFILE_EXTEN MSG 表示电子邮件或原生文件类型的文件扩展名\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\n\nCase 22-50073 Doc 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 171 of 491\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\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**该数据必须为单独字段，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**该数据必须为单独字段，不得与DATE_ACCESSD字段合并\n\nFILE_SIZE 5,952 原生文件/电子邮件文件的大小，以KB计\n\nPGCOUNT 1 原生文件/电子邮件文件的页数\n\nPATH 电子邮件：（空）\nAgenda.doc 原生文件：存储原生文件的位置路径，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：唯一消息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. 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. 所有文件均应按通常业务过程中保存的方式提交，或者应进行整理和标记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，\n\nCase 22-50073 Doc 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 172 of 491\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交。\n\n6. 如要求您提交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) 确定制作或起草该文件的人员（以及如适用，确定该文件的收件人）；(c) 确定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相关事实和情形；(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. 如要求您提交的某份文件已被销毁，则除前述说明所要求的信息外，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全部情形；以及(b) 对于依据特权主张而扣留的每份文件，应依照D. Conn. L. Civ. R. 26(e)制作一份特权清单，其中包含本说明第(a)部分所要求的全部信息。\n\n9. 如一份本应提交的文书中有部分信息属于特权主张的范围，则仅应依照上述指示从该文书中删除或遮蔽属于该特权主张范围的部分，其余部分应予提交。\n\n10. 本请求具有持续性。现指示您：(a) 一旦知悉先前答复不完整或不正确，应立即补充或更正任何后来发现不完整或不正确的答复；以及 (b) 提交根据以下规定所要求的任何额外文书。\n\n11. 如一份文书为英文以外的语言，您应提供该文书。如一份文书为英文以外的语言，且存在英文译本，您应同时提供两份文书。\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，文书请求所涵盖的期间为自 February 5, 2012 起至文书请求答复到期之日止。\n案件 22-50073 文书 839 提交于 09/07/22 登记于 09/07/22 20:02:47 第 174 页，共 491 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”应在必要时作合取或析取解释，以使任何请求的范围包括原本可能被解释为不在其范围内的所有答复；以及 (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，适用于文书请求。此外，本文件请求中使用的下列术语具有以下含义：\n\n1. “You”、“Your”或“Yourself”系指 Max Krasner，以及其所有关联方、部门、机构、工具部门、科室、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. “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的人。\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的人。\n案件 22-50073 文书 839 提交于 09/07/22 登记于 09/07/22 20:02:47 第 175 页，共 491 页\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的人。\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的人。\n\n6. “Debtor's Family”统称债务人、债务人之子、债务人之女、债务人所谓的妻子，以及与债务人具有其他家庭关系的任何人。\n\n7. “Associated Individuals”单独及合称：(1) 持有、控制、保管或对债务人或债务人家庭拥有、控制或享有的资产享有裁量权的所有个人；或 (2) 曾为一个或多个关联实体的雇员、董事，或以其他方式与一个或多个关联实体有关联的所有个人，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。此类关联个人包括但不限于：Daniel Podhaskie、Jason Miller、Steve Bannon、Karin Maistrello、Melissa Francis、William Gertz、Arethusa Forsyth、Glenn Mellor、Jennifer Mercurio、Eduardo Eurnekian、Han Chunguang（韩春光）（亦称 韩春光）、Qu Guojiao（屈国姣）（亦称 Qu Guo Jiao、屈国姣）、Guo Lijie（郭丽杰）（亦称 郭丽杰）、Zhang Wei（张伟）（亦称 张伟*）、Lihong Wei Lafrenz（魏丽红）（亦称 Sara Wei、魏丽红）、Hao Haidong（郝海东）（亦称 郝海东）、Ross Heinemeyer、Max Krasner、Kyle Bass、Melissa Mendez、Ya Li（李娅）（亦称 李娅）、Dinggang Wang（王定刚）（亦称 王定刚）、An Hong（安红）（亦称 安红）、Yvette Wang（王雁平）（亦称 Yanping Wang、Yan Ping Wang、王雁平）、Fiona Yu、Je Kin Ming（余建明）（亦称 William Je、Yu Jianming、余建明）、Yaz Qingua，以及 Lao Jiang（姜云浮）（亦称 Jiang Yunfu、Jiang Yunfu Be、姜云浮）。\n案件 22-50073 文书 839 提交于 09/07/22 登记于 09/07/22 20:02:47 第 176 页，共 491 页\n\n8. “Associated Entities”单独及合称：(1) 曾由债务人或债务人家庭拥有、控制或投资的所有类型的组织或实体；或 (2) 直接或间接在债务人或债务人家庭拥有、控制或享有的任何资产中享有权益的所有类型的组织或实体，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。此类关联实体包括但不限于：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、Assets Sino Limited、Auspicious Coast Limited、Beijing Pangu Investment Co.、Beijing Pangu Investment Co. Ltd.、Beijing Pangu Investment Inc.、Beijing Zenith Holdings Company Limited、Bravo Luck Limited、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、Elite Well Global Limited、Empire Growth Holdings、G Club Operations LLC、G Fashion LLC、G News LLC、GETTR USA、Genever Holdings Corporation、Genever Holdings LLC、GFASHION MEDIA GROUP INC.、GFNY, Inc.、Globalist International Limited、GNews Media Group Inc.、Golden Spring (New York) Ltd.、Greenwich Land LLC、Guo Media、GTV Media Group, Inc.、Hamilton Capital Holdings Inc.、Head Win Group Limited、Henan Yuda、Himalaya Embassy、Himalaya Exchange、Himalaya Federal Reserve、Himalaya Supervisory Organization、HK International Funds Investments (USA) Limited LLC、Hong Kong International Funds Investments Limited、Infinite Increase Limited、Infinitum Developments Limited、Insight Phoenix Fund、Lamp Capital LLC、Leading Shine Limited、Leading Shine NY Limited、Long Gate Limited、Next Tycoon Investments Limited、New\n案件 22-50073 文书 839 提交于 09/07/22 登记于 09/07/22 20:02:47 第 177 页，共 491 页\n\nFederal State of China（亦称 NFSC）、Noble Fame Global Limited、Rosy Acme Ventures Limited、Rule of Law Foundation III, Inc.、Rule of Law Foundation IV, Inc.、Rule of Law Fund、Rule of Law Society、Rule of Law Society IV, Inc.、G-Translators PTY LTD、Saraca Media Group, Inc.、Shiny Ace Ltd.、Shiny Times Holdings Ltd.、Spirit Charter Investment Limited、Stevenson, Wong & Co.、Voice of Guo Media, Inc.、Well Origin Ltd.、World Century Limited、Worldwide Opportunity Holdings Limited、Whitecroft Shore Limited，以及 ZIBA Limited。\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”，并应同时作合取和析取解释，以最大限度扩大其范围。\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”系指您本人以外的个人或实体。\n\n14. “Transfer”具有《Bankruptcy Code》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，并包括但不限于处于或曾经处于您占有、保管或控制之下的任何种类、类型、性质或描述的每一份书面、记录或图示材料，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、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、日记、信件、电报、照片、会议记录、合同、协议、调查、计算机打印件、数据\n案件 22-50073 文书 839 提交于 09/07/22 登记于 09/07/22 20:02:47 第 178 页，共 491 页\n\n汇编资料、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、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，以及上述全部材料的所有元数据，无论其以何种方式储存（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，如其包含原始文书中未见的任何种类的笔记、评论或标记，或以其他方式与原始文书不相同。\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”意为关于、描述、构成、提及、与之相关、支持、赞成、反对、强化、削弱、位于其中、结合考虑、与之有关、证明、表明、就其报告、记录、暗指、回应、与之连接、就其评论、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. 当提及任何特定事项时，“Relating to”、“relate(s) to”或“related to”意为但不限于，构成、组成、涉及、包含、\n案件 22-50073 文书 839 提交于 09/07/22 登记于 09/07/22 20:02:47 第 179 页，共 491 页\n\n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书。\n\n20. “Communication(s)”在最广泛可能的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，还是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、电传传真、影印传真、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送的笔记。\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，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，以及预期的经济机会。\n\n22. “转让”应具有《破产法》第101(54)条赋予该词的含义。\n\nIV. 应提交的文件\n\n1. 与债务人、债务人财产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试图规避偿付该等义务有关的所有文件，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\nCase 22-50073 Doc 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 180 of 491\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、账户报表、电汇指令和/或确认书、资金证明、存款证明、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前述任何主体作出的所有转让的文件。\n\n4. 与债务人作出、与债务人进行或代表债务人作出的任何投资、业务往来或交易有关的所有文件。\n\n5. 与债务人的所有通信，以及与债务人的通信有关、涉及任何实体（包括但不限于关联实体）的运营、管理或决策的文件。\n\n6. 与向债务人、债务人的家庭成员或关联实体作出、由其作出或与其进行的任何转让、投资、其他交易或业务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 Lady May（“梅夫人”号）；Sherry Netherland Hotel / Condominium（雪莉·荷兰酒店/公寓）；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；以及位于 Connecticut（康涅狄格州）Wilton（威尔顿）354 Nod Hill Rd. 的住宅物业。\n\n8. 与债务人、债务人的家庭成员或关联实体于 July 2020 前后或任何其他时间进行的原油期货或任何类似商品投资或交易有关的所有文件，包括但不限于与 Jiang Yunfu Be（贝江云福）就任何该等投资或交易进行的通信。\n\nCase 22-50073 Doc 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 181 of 491\n\n9. 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及显示该等航空器所执飞航班和该等航班上人员的飞行清单。\n\n10. 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、利益或贷款的金额；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、与任何贷款有关作出的所有陈述和保证、任何贷款的利率及任何贷款还款的所有证据的文件。\n\n11. 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该等信托何时设立、由谁设立、为谁的利益设立及信托本金的文件。\n\n12. 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\n13. 您的任何外部法律顾问或其他顾问与债务人之间的所有文件及通信。\n\nCase 22-50073 Doc 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 182 of 491\n\n14. 足以显示您的所有资产及收入或资金来源的文件。\n\n15. 对于就请求14所识别的、价值超过 $50,000 的所有资产，提供：(i) 与您取得该等资产有关的所有文件；以及 (ii) 与债务人或债务人的家庭成员就该等资产进行的通信。\n\n16. 您的纳税申报表副本。\n\n17. 足以显示由您持有或控制的所有银行账户和投资账户的文件，包括每一该等账户的余额及向该等账户转入和从该等账户转出的款项。\n\n18. 与您使用的任何信用卡有关的所有文件，包括但不限于月度对账单或足以显示为债务人或关联实体利益而作出的所有相关购买的其他文件。\n\n19. 与您将资产质押给任何其他实体有关的所有文件。\n\nCase 22-50073 Doc 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 183 of\n\nB2540（表格2540－规则2004审查传票）（第2页） 491\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于（日期）\n__________ 本人收到为（个人姓名及职务，如有）：______________________________________________发出的本传票。\n本人通过向被指定人员交付副本送达传票，具体如下：____________________________________\n__________________________________ 于（日期）___________________；或 ___________________________________________________________________________________________________\n本人未执行传票即予退回，原因如下：____________________________________________________________\n\n本人收取的费用为：差旅费 $_________，服务费 $_________，合计 $_________。除非传票系代表 United States（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本人在伪证处罚的前提下声明，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》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) 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) 在待检查的场所检查该场所。\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，避免对受传票约束的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，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，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，适用下列规则：\n\n(i) 送达方可在任何时候通知被命令人员后，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) 仅可依照命令的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；(ii) 要求某人在超出第45(c)条规定的地理范围外履行；(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；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的人，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，该等意见或信息既不描述争议中的具体事件，亦源于未经当事人请求的该专家研究。\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) 证明对证言或材料具有实质性需要，且若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) 确保受传票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，或必须将其整理并标注，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) 无法合理访问的电子存储信息。答复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。对于强制证据开示动议或保护令动议，答复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，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保护为由扣留被传唤信息的人，必须：\n\n(i) 明确提出该主张；以及\n\n(ii) 以一种方式描述被扣留文件、通信或有形物的性质，使各方能够评估该主张，同时不披露本身享有特权或受保护的信息。\n\n(B) 已提供的信息。如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，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其有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) Committee Note (2013)\n\n……\n\n附件 C-9\n\nB2540（表格 2540——Rule 2004 审查传票）（12/15）Case 22-50073 Doc 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 186 of 491\n\n美国破产法院\n\n__________________________________________________ Connecticut（康涅狄格州）地区\n\n关于 __________________________________________________\n\n案号：____________________________ Ho Wan Kwok（郭文贵）22-50073\n\n债务人\n\n章节：________________ 11\n\nRULE 2004 审查传票\n\n致：________________________________________________________________________________ Acass Canada Ltd（加拿大 Acass 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，以便根据《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\nPaul Hastings LLP（保尔·黑斯廷斯律师事务所）\n200 Park Avenue\nNew York, New York 10166\n\n审查将采用以下方法记录：____________________________________________________________ 法庭记录员/速记员\n\n提交：您或您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检查、复制、测试或抽样：\n\n见随附的文件提交请求。\n\n以下 Fed. R. Civ. P. 45 的规定，根据 Fed. R. Bankr. P. 9016 适用于破产案件，现随附——有关履行地点的 Rule 45(c)；有关您作为传票对象所受保护的 Rule 45(d)；以及有关您答复本传票的义务及不答复的潜在后果的 Rule 45(e) 和 45(g)。\n\n日期：September __________ __, 2022\n\n法院书记员\n\n或\n\n________________________ 法院书记员或副法院书记员签名 ________________________ 律师签名 Patrick R. Linsey（ct29437）\n\n签发或请求本传票的、代表（当事人名称）____________________________的律师姓名、地址、电子邮件地址和电话号码如下：Luc Despins（第 11 章受托人）\n\nPatrick R. Linsey, Esq.; Neubert, Pepe & Monteith, P.C.; 195 Church Street, New Haven, Connecticut 06510 plinsey@npmlaw.com; 203-821-2000\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，或检查场所，则必须在向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答复。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，必须按下文所述详细说明您提出异议的理由。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，您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。每张图像右下角必须标注连续的 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项/子项关系。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\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 文件内的字段。至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内，每个文件夹内的文本文件不得超过 1,000 个。文件夹名称不得包含特殊字符（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字段列入。所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一电子文件，仅提交一份副本。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\nf. 元数据。以符合 Concordance 要求的加载文件（.dat）形式，为每一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。下列为要求提供的元数据：\n\nCase 22-50073 Doc 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 189 of 491\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单页文件应填写 LASTBATES 字段\n\nATTACHRANGE EDC0000001\n— 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 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\n\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\n\nTO Coffman, Janice; LeeW\n[mailto:LeeW@MSN.com] 收件人\n多个条目之间应使用分号分隔\n\nCC Frank Thompson [mailto:\nfrank_Thompson@cdt.com] 抄送收件人\n多个条目之间应使用分号分隔\n\nBCC（密送） 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（主题） Board Meeting Minutes（董事会会议纪要） 电子邮件：电子邮件的主题行 原生文件：文件标题（如有）\nFILE_NAME（文件名） BoardMeetingMinutes.docx 原生文件：原始原生文件的名称，包括扩展名\nDATE_SENT（发送日期） 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（发送时间/时区） 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（时区） GMT 转换期间电子邮件标准化所采用的时区。\nLINK（链接） >EDC0000001.msg 指向电子邮件或原生文件的超链接\n链接文件必须以FIRSTBATES编号命名\nFILE_EXTEN（文件扩展名） MSG 代表电子邮件或原生文件的文件类型扩展名\nAUTHOR（作者） John Smith（约翰·史密斯） 电子邮件：（空）\n原生文件：文件作者\nDATE_CREATED（创建日期） 10/10/2010 电子邮件：（空）\n原生文件：文件创建日期\n\nCase 22-50073 Doc 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 190 of 491\n\nTIME_CREATED（创建时间） 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（修改日期） 10/12/2010 电子邮件：（空）\n原生文件：文件最后修改日期\nTIME_MOD（修改时间） 07:00 PM 电子邮件：（空）\n\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（访问日期） 10/12/2010 电子邮件：（空）\n原生文件：文件最后访问日期\nTIME_ACCESSD（访问时间） 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（文件大小） 5,952 原生文件/电子邮件的大小，以KB计\nPGCOUNT（页数） 1 原生文件/电子邮件的页数\nPATH（路径） 电子邮件：（空）\nAgenda.doc 原生文件：存储原生文件的路径，包括原始文件名。\nINTFILEPATH（内部文件路径） Personal Folders\\Deleted\nItems\\Board Meeting\nMinutes.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（内部消息ID） <000805c2c71b\\$75977050\\$\ncb8306d1@MSN> 电子邮件：唯一消息ID 原生文件：（空）\nMD5HASH（MD5哈希值） d131dd02c5e6eec4693d9a0\n698aff95c\n2fcab58712467eab4004583e\nb8fb7f89 文件的MD5哈希值。\nOCRPATH（OCR路径） 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. 所有文件应按其在日常业务过程中保存的方式提供，或应加以组织并标注，以对应本请求中的类别。\n\n5. 本文所载每项请求均延及以下所有文件：(a) 由您占有、保管或控制的文件；或(b) 由任何代表您行事的人占有、保管或控制的文件，\n\nCase 22-50073 Doc 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 191 of 491\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，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) 您将依赖以支持该等特权主张的所有情形；以及(b) 就依据特权主张而扣留的每份文件，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，应完整提供回应性文件。\n\n9. 如一份原本具有回应性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。特此指示您：(a) 在知悉先前答复不完整或不正确后，立即补充或更正随后知悉为不完整或不正确的任何答复；以及(b) 提供根据以下规定所要求的任何补充文件\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其他姓名、别名或昵称。\n\nCase 22-50073 Doc 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 193 of 491\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或选择连词，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；以及(b) “each”和“any”应视为包括并涵盖“every”和“all”二词。\nIII. 定义\n\nD. 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，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如下含义：\n\n1. “您”或“您的”或“您本人”系指ACASS Canada Limited（ACASS加拿大有限公司），包括其关联实体，包括但不限于ACASS San Marino S.R.L（ACASS圣马力诺有限责任公司）和ACASS U.S.A. Inc.（ACASS美国公司），以及其任何雇员、代理人、律师、顾问或代表其行事的任何人。\n\nCase 22-50073 Doc 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 194 of 491\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、顾问或代表其行事的任何人。\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、顾问或代表其行事的任何人。\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，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. “债务人家庭成员”统称债务人、债务人之子、债务人之女和债务人声称的妻子，以及与债务人有任何其他家庭关系的人。\n\n7. “关联个人”单独及统称指：(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裁量权的所有个人；或(2) 曾为一名或多名关联实体的雇员、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。该等关联个人包括但不限于：Daniel Podhaskie（丹尼尔·波德哈斯基）、Jason Miller（杰森·米勒）、Steve Bannon（史蒂夫·班农）、Karin Maistrello（卡琳·迈斯特雷洛）、Melissa Francis（梅丽莎·弗朗西斯）、William Gertz（威廉·格茨）、Arethusa Forsyth（阿雷图萨·福赛思）、Glenn Mellor（格伦·梅勒）、Jennifer Mercurio（詹妮弗·梅尔库里奥）、Eduardo Eurnekian（爱德华多·埃乌尔内基安）、Han Chunguang（韩春光，亦称韩春光）、Qu Guojiao（屈国姣，亦称Qu Guo Jiao、屈国姣）、Guo Lijie（郭丽杰，亦称郭丽杰）、Zhang Wei（张伟，亦称张伟*）、Lihong Wei Lafrenz（魏丽红，亦称Sara Wei、魏丽红）、Hao Haidong（郝海东，亦称郝海东）、Ross Heinemeyer（罗斯·海内迈耶）、Max Krasner（马克斯·克拉斯纳）、Kyle Bass（凯尔·巴斯）、Melissa Mendez（梅丽莎·门德斯）、Ya Li\n\nCase 22-50073 Doc 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 195 of 491\n\n（李娅，亦称李娅）、Dinggang Wang（王定刚，亦称王定刚）、An Hong（安红，亦称安红）、Yvette Wang（王雁平，亦称Yanping Wang、Yan Ping Wang、王雁平）、Fiona Yu（菲奥娜·余）、Je Kin Ming（余建明，亦称William Je、Yu Jianming、余建明）、Yaz Qingua（亚兹·钦瓜）以及Lao Jiang（姜云浮，亦称Jiang Yunfu、Jiang Yunfu Be、姜云浮）。\n\n8. “关联实体”系指单独及合称下列所有组织或任何类型的实体：(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、顾问或代表前述任何一方行事的任何人。该等关联实体应包括但不限于：7 Nod Hill LLC（7诺德山有限责任公司）、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（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）、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（阿尔卑斯受托人股份公司）、Anton Development Limited（安东开发有限公司）、Assets Sino Limited（中资资产有限公司）、Auspicious Coast Limited（吉祥海岸有限公司）、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（北京鼎峰控股有限公司）、Bravo Luck Limited（好运有限公司）、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（克兰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）、Elite Well Global Limited（精英环球有限公司）、Empire Growth Holdings（帝国成长控股）、G Club Operations LLC（G俱乐部运营有限责任公司）、G Fashion LLC（G时尚有限责任公司）、G News LLC（G新闻有限责任公司）、GETTR USA（GETTR美国）、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（环球主义者国际有限公司）、GNews Media Group Inc.（GNews媒体集团公司）、Golden Spring (New York) Ltd.（金泉〔纽约〕有限公司）、Greenwich Land LLC（格林尼治土地有限责任公司）、Guo Media（郭媒体）、GTV Media Group, Inc.（GTV媒体集团公司）、Hamilton Capital Holdings Inc.（汉密尔顿资本控股公司）、Head Win Group Limited（领先集团有限公司）、Henan Yuda（河南裕达）、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 Supervisory Organization（喜马拉雅监管组织）、HK International Funds Investments (USA) Limited LLC（香港国际基金投资〔美国〕有限公司）、Hong Kong International Funds Investments Limited（香港国际基金投资有限公司）、Infinite Increase Limited（无限增长有限公司）、Infinitum Developments Limited（无限发展有限公司）、Insight Phoenix Fund（洞见凤凰基金）、Lamp Capital LLC（灯资本有限责任公司）、Leading Shine Limited（领耀有限公司）、Leading Shine NY Limited（领耀纽约有限公司）、Long Gate Limited（长龙门有限公司）、Next Tycoon Investments Limited（下一个大亨投资有限公司）、New Federal State of China (a/k/a NFSC)（中国新联邦国〔又称NFSC〕）、Noble Fame Global Limited（高贵声望全球有限公司）、Rosy Acme Ventures Limited（玫瑰顶峰创投有限公司）、Rule of Law Foundation III, Inc.（法治基金会III公司）、Rule of Law Foundation IV, Inc.（法治基金会IV公司）、Rule of Law Fund（法治基金）、Rule of Law Society（法治协会）、Rule of Law Society IV, Inc.（法治协会IV公司）、G-Translators PTY LTD（G-翻译员有限公司）、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）、Spirit Charter Investment Limited（精神宪章投资有限公司）、Stevenson, Wong & Co.（Stevenson, Wong & Co.）、Voice of Guo Media, Inc.（郭媒体之声公司）、Well Origin Ltd.（良好起源有限公司）、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）、Whitecroft Shore Limited（白克罗夫特海岸有限公司）及 ZIBA Limited（ZIBA有限公司）。\n\n案号 22-50073；文件 839；提交日期 09/07/22；录入日期 09/07/22 20:02:47；第 196 页，共 491 页\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”，并应同时按连词及析取词解释，以最大限度扩大其范围。\n\n11. “任何”及“所有”以及“每一”系指“每一个及所有”。\n\n12. “每一”及“每个”系指“每一个及所有”。\n\n13. “第三方”系指除您以外的个人或实体。\n\n14. “转让”应具有《破产法典》第 101(54) 条赋予该词的含义。\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、保管或控制之下的任何种类、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印刷版和电子版、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案号 22-50073；文件 839；提交日期 09/07/22；录入日期 09/07/22 20:02:47；第 197 页，共 491 页\n\n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、清单、透明片、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、宣传单、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，无论以何种方式储存（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，如其载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\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，包括但不限于律师、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、强化、削弱、载于、结合考虑、对其有影响、证明、表明、报告、记录、暗示、回应、\n\n案号 22-50073；文件 839；提交日期 09/07/22；录入日期 09/07/22 20:02:47；第 198 页，共 491 页\n\n与之联系、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. 就任何特定主题事项而言，“与……相关”、“与……有关”或“相关的”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主题事项相关的任何文件。\n\n20. “通信”系指，在最广义且不限于此的意义上，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，无论系当面、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、电话笔记，或在内部或与第三方传递的笔记。\n\n21. “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\n22. “航空器”系指任何用于空中旅行的交通工具，包括但不限于飞机和直升机，其现时或曾在任何时候由债务人、债务人的家庭成员或任何关联实体拥有、使用、控制、购买、出售、租赁、出租、许可、维护、保养、修理、大修、储存、\n\n案号 22-50073；文件 839；提交日期 09/07/22；录入日期 09/07/22 20:02:47；第 199 页，共 491 页\n\n运营、营销或检查，或为债务人、债务人的家庭成员或任何关联实体的利益而进行前述行为，包括但不限于曾经以或与以下字母数字序列识别或关联的任何航空器：T7-GQM、T7-17777、M-GYQM、SN9189 或 9189。\n\n23. “航空器工作人员”系指与航空器的维护、运营、服务、保养或储存有关的任何雇员、独立承包人、飞行员、副驾驶员、机械师、空乘人员或个人。\n\nIV. 应提交的文件\n\n1. 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的任何收入或资产相关的所有文件。\n\n2. 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及任何航空器相关的所有文件，包括但不限于：(i) 对任何航空器的所有权或控制权；(ii) 对任何航空器的使用；(iii) 对任何航空器的租赁或出租；(iv) 任何航空器的购买、出售或营销；(v) 与任何航空器有关的任何已支付或给付的款项或价值及其来源；(vi) 与任何航空器有关的任何产生或取得的款项或价值及其处置；或 (vii) 与任何航空器有关的运营、维护、服务或大修。\n\n3. 与任何和债务人、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账户相关的所有文件。\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有关的任何发票或费用支付相关的所有文件。\n\n案号 22-50073；文件 839；提交日期 09/07/22；录入日期 09/07/22 20:02:47；第 200 页，共 491 页\n\n5. 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已经进行或计划进行的旅行有关的任何飞行日志、飞行计划或任何其他飞行信息记录相关的所有文件。\n\n6. 与航空器工作人员就债务人、债务人财产、债务人的家庭成员、关联实体或关联个人开展的任何活动相关的所有文件。\n\n7. 与航空器工作人员以及债务人、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付款、费用、转让或款项相关的所有文件。\n\n8. 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所使用的任何航空器上可能搭载的人员相关的所有文件，包括任何飞行乘客名单。\n\n9. 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航空器上的任何货物、储存物、待交付物品、资产或财产相关的所有文件。\n\n10. 与航空器所在地相关的所有文件。\n\n附件 C-10\n\nB2540（表格 2540——第 2004 条审查传票）（12/15）美国破产法院 案号 22-50073；文件 839；提交日期 09/07/22；录入日期 09/07/22 20:02:47；第 202 页，共 491 页\n\n_____________________________________________________________ 康涅狄格州地区\n\n关于 _____________________________________________________________\n\n案号 ______________________________ Ho Wan Kwok（郭文贵） 22-50073\n\n债务人\n\n第 ____________________ 章 11\n\n第 2004 条审查传票\n\n致：________________________________________________________________________________________________ Yachtzoo SARL（游艇动物园有限责任公司）\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、日期及地点出席，根据《联邦破产程序规则》第 2004 条进行审查并作证。随附准许该审查的法院命令副本。\n\n地点 日期及时间\n\nPaul Hastings LLP（普衡律师事务所）\n200 Park Avenue\nNew York, New York 10166\n\n审查将通过下列方式记录：__________________________________________________________________________________ 法庭记录员/速记员\n\n出示：您或您的代表还必须将下列文件、电子存储信息或物品携带至询问，并必须允许对该材料进行查验、复制、测试或抽样：\n见随附的文件出示请求。\n\n《联邦民事诉讼规则》第45条的下列规定，经《联邦破产程序规则》第9016条规定适用于破产案件，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的您的保护；以及第45(e)条和第45(g)条，关于您回应本传票的义务及未作回应的潜在后果。\n\n日期：September ______________ __, 2022\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 Patrick R. Linsey（帕特里克·R·林赛）(ct29437)\n\n代表（当事人名称）______________________________签发或申请本传票的律师的姓名、地址、电子邮件地址及电话号码如下：Luc Despins（吕克·德斯潘），Ch. 11 Trustee（第11章受托人）\n\nPatrick R. Linsey（帕特里克·R·林赛）, Esq.; Neubert, Pepe & Monteith, P.C.（纽伯特、佩佩和蒙蒂思专业公司）; 195 Church Street, New Haven, Connecticut 06510 plinsey@npmlaw.com; 203-821-2000\n\n致签发或申请本传票者的通知\n\n如本传票要求在审判前出示文件、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文件出示请求\n\n一、指示\n\n1. 除非另有说明，下述文件出示请求（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。除非基于善意提出异议，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，或其中包含的某个词语、短语或条款，您仅须说明对该部分的异议，并对请求的其余部分作出答复。\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格式出示。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。日期与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，以提供所出示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，每行由七个字段构成；数据库中的每幅图像均应在交叉引用文件中有一行，并采用如下格式：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出示，而不得作为.DAT文件中的字段出示。通往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位于单独的文件夹中，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\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。应提供一张标有Bates编号的提示页图像，表明存在原生文件，并将通往原生文件的路径作为字段包含在.dat文件中。所出示的原生文件应以与该文件提示页对应的Bates编号命名。应将原生文件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一电子文件，仅出示一份。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。应以符合Concordance要求的加载文件（.dat）形式，出示每一文件的提取元数据。.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。日期与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 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 205 of 491\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对于单页文件，应填写LASTBATES字段\n\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\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 电子邮件：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\n\nFROM John Smith 电子邮件：发件人\n原生文件：文件作者\n多个条目应以分号分隔\n\nTO Coffman, Janice; LeeW 收件人\n[mailto:LeeW@MSN.com] 多个条目应以分号分隔\n\nCC Frank Thompson [mailto: 抄送收件人\nfrank_Thompson@cdt.com] 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；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 表示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 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 206 of 491\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\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，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：最后访问文件的日期\n\nTIME_ACCESSD 07:00 PM 电子邮件：（空）\n原生文件：最后访问文件的时间\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 原生文件文件/电子邮件的大小，以KB计\n\nPGCOUNT 1 原生文件文件/电子邮件的页数\n\nPATH Email: (empty)\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。\n\nINTFILEPATH Personal Folders\\Deleted 电子邮件：电子邮件的原始位置，包括原始文件名称。\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. 每项请求独立运作并应被独立解释；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. 所有文件均应按照其在通常业务过程中保存的方式出示，或应予以组织和标记，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) 由任何代表您行事者占有、保管或控制的文件，\nCase 22-50073 Doc 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 207 of 491\n\n包括您的律师或其他代表及顾问。每一文件均应完整出示。\n\n6. 如要求您出示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) 识别编制或撰写该文件的人员（以及，如适用，识别该文件被发送给的人员）；(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) 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相关事实和情形；(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) 说明该文件最近一次由您占有、保管或控制的时间；以及(i) 识别现时占有、保管或控制该文件的人员（如有）。\n\n7. 如要求您提交的某一文件已被销毁，则您的答复除须载明前述指示所要求的信息外，还必须说明：(a) 该文件被销毁的原因；(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. 如您主张所要求的某一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 文书 839 提交 09/07/22 登记 09/07/22 20:02:47 第 208 页，共 491 页\n\n以及说明该等信息如何为其占有，(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) 根据 D. Conn. L. Civ. R. 26(e)，就基于特权主张而被扣留的每一文件，制作一份载有本指示第 (a) 部分所要求全部信息的特权日志。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. 如一份原本应予提交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盖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。特此指示您：(a) 一经得知先前答复不完整或不正确，即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) 提交根据下述规定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. 对实体的一切提述均包括其所有关联方。\n\n13. 对个人姓名的一切提述均包括所有其他姓名、别名或昵称。\n案件 22-50073 文书 839 提交 09/07/22 登记 09/07/22 20:02:47 第 209 页，共 491 页\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 起至应就文件请求作出答复之日止。\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”应视需要解释为连词或析取词，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其范围；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”系指并包括 Yachtzoo SARL（Yachtzoo SARL），包括其母公司、子公司及关联方，以及其任何雇员、代理人、律师、顾问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。\n案件 22-50073 文书 839 提交 09/07/22 登记 09/07/22 20:02:47 第 210 页，共 491 页\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. “债务人所谓之妻”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. “债务人家庭成员”统称债务人、债务人之子、债务人之女及债务人所谓之妻，以及与债务人有任何其他亲属关系之人。\n\n7. “关联个人”单独及统称指：(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，以及前述任何人员各自的雇员、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：Daniel Podhaskie、Jason Miller、Steve Bannon、Karin Maistrello、Melissa Francis、William Gertz、Arethusa Forsyth、Glenn Mellor、Jennifer Mercurio、Eduardo Eurnekian、Han Chunguang（韩春光）（又名 韩春光）、Qu Guojiao（屈国姣）（又名 Qu Guo Jiao、屈国姣）、Guo Lijie（郭丽杰）（又名 郭丽杰）、Zhang Wei（张伟）（又名 张伟*）、Lihong Wei Lafrenz（魏丽红）（又名 Sara Wei、魏丽红）、Hao Haidong（郝海东）（又名 郝海东）、Ross Heinemeyer、Max Krasner、Kyle Bass、Melissa Mendez、Ya Li\n（又名 李娅）、Dinggang Wang（王定刚）（又名 王定刚）、An Hong（安红）（又名 安红）、Yvette Wang（王雁平）（又名 Yanping\n案件 22-50073 文书 839 提交 09/07/22 登记 09/07/22 20:02:47 第 211 页，共 491 页\n\nWang、Yan Ping Wang、王雁平）、Fiona Yu、Je Kin Ming（余建明）（又名 William Je、Yu Jianming、余建明）、Yaz Qingua，以及 Lao Jiang（姜云浮）（又名 Jiang Yunfu、Jiang Yunfu Be、姜云浮）。\n\n8. “关联实体”单独及统称指：(1) 曾由债务人或债务人家庭成员拥有、控制或投资的所有任何类型组织或实体；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的所有组织或实体，以及前述任何实体各自的雇员、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：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、Assets Sino Limited、Auspicious Coast Limited、Beijing Pangu Investment Co.、Beijing Pangu Investment Co. Ltd.、Beijing Pangu Investment Inc.、Beijing Zenith Holdings Company Limited、Bravo Luck Limited、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、Elite Well Global Limited、Empire Growth Holdings、G Club Operations LLC、G Fashion LLC、G News LLC、GETTR USA、Genever Holdings Corporation、Genever Holdings LLC、GFASHION MEDIA GROUP INC.、GFNY, Inc.、Globalist International Limited、GNews Media Group Inc.、Golden Spring (New York) Ltd.、Greenwich Land LLC、Guo Media、GTV Media Group, Inc.、Hamilton Capital Holdings Inc.、Head Win Group Limited、Henan Yuda、Himalaya Embassy、Himalaya Exchange、Himalaya Federal Reserve、Himalaya Supervisory Organization、HK International Funds Investments (USA) Limited LLC、Hong Kong International Funds Investments Limited、Infinite Increase Limited、\n案件 22-50073 文书 839 提交 09/07/22 登记 09/07/22 20:02:47 第 212 页，共 491 页\n\nInfinitum Developments Limited、Insight Phoenix Fund、Lamp Capital LLC、Leading Shine Limited、Leading Shine NY Limited、Long Gate Limited、Next Tycoon Investments Limited、New Federal State of China（又名 NFSC）、Noble Fame Global Limited、Rosy Acme Ventures Limited、Rule of Law Foundation III, Inc.、Rule of Law Foundation IV, Inc.、Rule of Law Fund、Rule of Law Society、Rule of Law Society IV, Inc.、G-Translators PTY LTD、Saraca Media Group, Inc.、Shiny Ace Ltd.、Shiny Times Holdings Ltd.、Spirit Charter Investment Limited、Stevenson, Wong & Co.、Voice of Guo Media, Inc.、Well Origin Ltd.、World Century Limited、Worldwide Opportunity Holdings Limited、Whitecroft Shore Limited，以及 ZIBA Limited。\n\n9. “包括”或其任何变体，系指“包括但不限于”。\n\n10. “and”和“or”系指“and/or”，并应解释为兼具连词及析取词含义，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. “第三方”系指您本人以外的人员或实体。\n\n14. “转让”具有《破产法》section 101(54) 赋予该词的含义。\n\n15. “文件”系指属于 Fed. R. Civ. P. 34 范围内的任何信息或物品，包括但不限于处于或曾处于您占有、保管或控制之下的每一份任何种类、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、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、\n案件 22-50073 文书 839 提交 09/07/22 登记 09/07/22 20:02:47 第 213 页，共 491 页\n\n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、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、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；亦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未见的任何种类注释、评论或标记，或在其他方面与原始文件不一致。\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”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”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、与之相关、支持、赞成、反对、加强、削弱、位于、结合考虑、与之有关、证明、表明、报告、记录、暗指、回应、与之相连、评论、就……而言、关于、与……有关、讨论、显示、描述、反映、分析、构成及作为。\n\n案件 22-50073 文件 839 提交于 09/07/22 录入于 09/07/22 20:02:47 第 214 页，共 491 页\n\n19. “与……有关”、“涉及”或“相关”，在指称任何特定事项时，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”是指以最广义且不受限制的方式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、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布、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\n21. “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\n22. “Lady May 约定命令”是指于 2022 年 4 月 29 日在美国康涅狄格州联邦破产法院（U.S. Bankruptcy Court for the District of Connecticut）审理的、案名为 In re Ho Wan Kwok（郭文贵）、案号为 22-50073-JAM [Docket No. 299] 的第 11 章案件中作出的《约定命令，责令 HK International Funds Investments (USA) Limited, LLC 运输并交付该游艇“Lady May”》。\n\n案件 22-50073 文件 839 提交于 09/07/22 录入于 09/07/22 20:02:47 第 215 页，共 491 页\n\n23. “Lady May”是指 Lady May 约定命令中所讨论的该艘休闲游艇。\n\n24. “船舶”是指任何用于在水面上或水中航行的交通工具，包括但不限于由债务人、债务人家属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、修理、大修、存放、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、修理、大修、存放、操作、营销或检查的船艇、轮船、个人水上交通工具、潜水艇或两栖艇，包括但不限于 Lady May。\n\n25. “船舶工作人员”是指与船舶的维护、操作、服务、保养或存放有关的任何雇员、独立承包人、船长、大副、甲板水手、船员、服务员、机械师或个人。\n\nIV. 应提交的文件\n\n1. 与债务人、债务人财产、债务人家属或关联实体的任何收入或资产有关的所有文件。1\n\n2. 与债务人、债务人财产、债务人家属或关联实体及任何船舶有关的所有文件。2\n\n3. 与债务人、债务人财产、债务人家属或关联实体及任何船舶的所有权或控制有关的所有文件。\n\n4. 与债务人、债务人财产、债务人家属或关联实体及就任何船舶支付或给予的任何款项或价值，以及其来源有关的所有文件。\n\n1 不受限制地注意，“关联实体”一词包括 HK International Funds Investments (USA) Limited LLC。\n\n2 不受限制地注意，“船舶”一词包括 Lady May。\n\n案件 22-50073 文件 839 提交于 09/07/22 录入于 09/07/22 20:02:47 第 216 页，共 491 页\n\n5. 与债务人、债务人财产、债务人家属或关联实体及与任何船舶有关而产生或取得的任何款项或价值，以及其处置有关的所有文件。\n\n6. 与债务人、债务人财产、债务人家属或关联实体及任何船舶的使用有关的所有文件。\n\n7. 与债务人、债务人财产、债务人家属或关联实体及与任何船舶有关的操作、维护、服务或大修有关的所有文件。\n\n8. 与债务人、债务人财产、债务人家属或关联实体及任何船舶的租赁或出租有关的所有文件。\n\n9. 与债务人、债务人财产、债务人家属或关联实体及任何船舶的购买、出售或营销有关的所有文件。\n\n10. 与任何与债务人、债务人财产、债务人家属或关联实体有关的账户有关的所有文件。\n\n11. 与债务人、债务人财产、债务人家属或关联实体有关的任何费用发票或付款有关的所有文件。\n\n12. 与债务人、债务人财产、债务人家属或关联实体就任何船舶已进行或计划进行的航行有关的任何日志、计划、靠泊记录或任何其他信息记录有关的所有文件。\n\n13. 与任何船舶工作人员就其与债务人、债务人财产、债务人家属或关联实体有关的任何活动有关的所有文件。\n\n14. 与船舶工作人员及债务人、债务人财产、债务人家属或关联实体有关的任何付款、费用、转账或款项有关的所有文件。\n\n案件 22-50073 文件 839 提交于 09/07/22 录入于 09/07/22 20:02:47 第 217 页，共 491 页\n\n15. 与在债务人、债务人财产、债务人家属或关联实体使用的任何船舶上可能登船的人员有关的所有文件。\n\n16. 与船舶上任何货物、储存物、待交付物品、资产或财产有关，且与债务人、债务人财产、债务人家属或关联实体有关的所有文件。\n\n附件 C-11\n\nB2540（表格 2540－Rule 2004 审查传票）（12/15）美国联邦破产法院（UNITED STATES BANKRUPTCY COURT）案件 22-50073 文件 839 提交于 09/07/22 录入于 09/07/22 20:02:47 第 219 页，共 491 页\n\n_____________________________________________________________ 康涅狄格州地区 _____________________________________________________________\n\n关于 ______________________________________________________________________\n\n案件编号 ______________________________ Ho Wan Kwok（郭文贵）22-50073\n\n债务人\n\n第 __________________ 章 11\n\nRule 2004 审查传票\n\n致：________________________________________________________________________________________________________________ Berkeley Rowe（伯克利·罗）\n\n（传票所指向人员的姓名）\n\n证言：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》（Federal Rules of Bankruptcy Procedure）Rule 2004 在审查中作证。随附准许进行该审查的法院命令副本。\n\n地点 日期和时间\n\nPaul Hastings LLP\n200 Park Avenue\nNew York, New York 10166\n\n审查将以以下方式记录：________________________________________________________________________________ 法庭书记员/速记员\n\n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，并必须允许对该等材料进行检查、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》（Fed. R. Civ. P.）Rule 45 的下列规定，依《联邦破产程序规则》（Fed. R. Bankr. P.）9016 在破产案件中适用，随附于此：关于履行地点的 Rule 45(c)；关于作为传票对象的人员所受保护的 Rule 45(d)；以及关于你回应本传票的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：2022 年 9 月 ___ 日\n\n法院书记员\n\n或\n\n____________________________ 法院书记员或副书记员签名 ____________________________ 律师签名 Patrick R. Linsey（ct29437）\n\n签发或申请本传票的一方当事人（姓名）____________________________的代理律师姓名、地址、电子邮件地址及电话号码如下：Luc Despins，第 11 章受托人\n\nPatrick R. Linsey, Esq.; Neubert, Pepe & Monteith, P.C.; 195 Church Street, New Haven, Connecticut 06510 plinsey@npmlaw.com; 203-821-2000\n\n致签发或申请本传票的人员的通知\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文件提交请求\n\nI. 指示\n\n1. 除非另有说明，下述文件请求（统称“请求”，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，则应如下文所述详细说明你方异议的理由。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，你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。每个文件夹内的 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\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。如文件包括图像化的电子邮件及附件，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\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）将图像与数据库记录关联起来。其应为逗号分隔文件，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\n- c. 文档文本。文本必须作为单独的文本文件提供，而不得作为 .DAT 文件中的字段提供。文本文件的完整路径（OCRPATH）应载入 .DAT 文件。建议提供文档级 ANSI 文本文件，并按 FIRSTBATES/Image Key 命名。提取的文本文件必须存放在单独的文件夹中，且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. 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。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、数据库文件及音频/视频文件。应提供一张带 Bates 编号的提示页图像，指明存在原生文件，并将原生文件路径作为 .dat 文件中的字段载入。提供的原生文件应以与该文件提示页对应的 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\n- e. 去重。对于存在完全重复件的每份电子文档，仅提供一个副本。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\n- f. 元数据。应以符合 Concordance 规范的载入文件（.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。日期字段和时间字段必须为两个单独字段。以下为必需元数据：\n案号 22-50073 文件 839 提交日期 09/07/22 录入日期 09/07/22 20:02:47 第 222 页，共 491 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\nLASTBATES 字段应针对单页予以填写\n\nATTACHRANGE EDC0000001\n- 母文档第一页的 Bates 编号至\nEDC0000015 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：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\n\nFROM John Smith 电子邮件：发件人\n原生文件：文档作者\n应使用分号分隔多个条目\n\nTO Coffman, Janice; LeeW 收件人\n[mailto:LeeW@MSN.com] 应使用分号分隔多个条目\n\nCC Frank Thompson [mailto: 抄送收件人\nfrank_Thompson@cdt.com] 应使用分号分隔多个条目\n\nBCC John Cain 密送收件人\n应使用分号分隔多个条目\n\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）\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\n原生文件：（空）\n\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\n\nTIME_ZONE GMT 在转换过程中电子邮件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 表示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 839 提交日期 09/07/22 录入日期 09/07/22 20:02:47 第 223 页，共 491 页\n\nTIME_CREATED 10:25 AM 电子邮件：（空）\n原生文件：文档创建时间\n该数据必须为单独字段，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该数据必须为单独字段，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该数据必须为单独字段，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 电子邮件：（空）\nAgenda.doc 原生文件：原生文件文档的存储路径，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\nItems\\Board Meeting 原始文件名。\nMinutes.msg 原生文件：（空）\n\nINTMSGID <000805c2c71b\\$75977050\\$ 电子邮件：唯一消息 ID\ncb8306d1@MSN> 原生文件：（空）\n\nMD5HASH d131dd02c5e6eec4693d9a0 文档的 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. 每项请求均独立运作并应被独立解释，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. 所有文档应按通常业务过程中的保存方式提供，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下列所有文档：(a) 在您占有、保管或控制之下的文档；或 (b) 在任何代表您行事之人占有、保管或控制之下的文档，\n案号 22-50073 文件 839 提交日期 09/07/22 录入日期 09/07/22 20:02:47 第 224 页，共 491 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. 如要求您提供已不在您占有、保管或控制之下的文档，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（如适用，识别接收该文档的人员）；(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) 已自愿或非自愿转移给他人，或 (iv) 以其他方式处置；(e) 说明该等处置的理由及其相关事实和情形；(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) 说明该文档最后一次处于您占有、保管或控制之下的时间；以及 (i) 识别目前占有、保管或控制该文档的人员（如有）。\n\n7. 如要求您提供已被销毁的文档，则除前一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. 如您主张所要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) 陈述：(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) 收到或见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处于任何其他人员的占有、保管或控制之下，如是，识别该等人员身份，并说明该等信息如何进入其占有，\n案号 22-50073 文件 839 提交日期 09/07/22 录入日期 09/07/22 20:02:47 第 225 页，共 491 页\n\n(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) 按照 D. Conn. L. Civ. R. 26(e)，就基于特权主张而拒绝提供的每份文档，制作一份特权清单，其中包含本指示第 (a) 部分所要求的全部信息。对于文档请求中未主张特权或工作成果保护的任何部分，应完整提供响应性文档。\n\n9. 如一份原本具有响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. 各项请求具有持续性。特此指示您：(a) 一旦得知先前答复不完整或不正确，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) 提供根据该项所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. 对实体的一切提述均包括其所有关联方。\n\n13. 对个人姓名的一切提述均包括所有其他姓名、别名或昵称。\n案号 22-50073 文件 839 提交日期 09/07/22 录入日期 09/07/22 20:02:47 第 226 页，共 491 页\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。\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) “and”和“or”应视必要按连词或选择连词解释，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”系指并指代 Berkeley Rowe（伯克利·罗），以及其任何雇员、代理人、律师、顾问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），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 839 提交日期 09/07/22 录入日期 09/07/22 20:02:47 第 227 页，共 491 页\n\n3. “债务人的儿子”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、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（又名 Mei Gui、郭美或任何其他别名），以及其雇员、代理人、律师、顾问或任何代表其行事的人。\n\n5. “债务人据称的妻子”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、律师、顾问或任何代表其行事的人。\n\n6. “债务人的家属”统指债务人、债务人的儿子、债务人的女儿及债务人据称的妻子，以及与债务人有任何其他亲属关系的人。\n\n7. “关联个人”单独及合并而言，系指以下所有个人：(1) 持有、控制、保管或对债务人或债务人的家属所拥有、控制或享有的资产具有处置决定权者；或 (2) 曾担任一个或多个关联实体的雇员、董事，或以其他方式与其有关联者，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：Daniel Podhaskie、Jason Miller、Steve Bannon、Karin Maistrello、Melissa Francis、William Gertz、Arethusa Forsyth、Glenn Mellor、Jennifer Mercurio、Eduardo Eurnekian、Han Chunguang（又名 韩春光）、Qu Guojiao（又名 Qu Guo Jiao、屈国姣）、Guo Lijie（又名 郭丽杰）、Zhang Wei（又名 张伟*）、Lihong Wei Lafrenz（又名 Sara Wei、魏丽红）、Hao Haidong（又名 郝海东）、Ross Heinemeyer、Max Krasner、Kyle Bass、Melissa Mendez、Ya Li（又名 李娅）、Dinggang Wang（又名 王定刚）、An Hong（又名 安红）、Yvette Wang（又名 Yanping Wang、Yan Ping Wang、王雁平）、Fiona Yu、Je Kin Ming（又名 William Je、Yu Jianming、余建明）、Yaz Qingua，以及 Lao Jiang（又名 Jiang Yunfu、Jiang Yunfu Be、姜云浮）。\n\n8. “关联实体”单独及合并而言，系指以下所有类型的组织或实体：(1) 曾由债务人或债务人的家属拥有、控制或投资的；或 (2) 对债务人或债务人的家属所拥有、控制或享有的任何资产直接或间接享有权益的，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：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、Assets Sino Limited、Auspicious Coast Limited、Beijing Pangu Investment Co.、Beijing Pangu Investment Co. Ltd.、Beijing Pangu Investment Inc.、Beijing Zenith Holdings Company Limited、Bravo Luck Limited、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、Elite Well Global Limited、Empire Growth Holdings、G Club Operations LLC、G Fashion LLC、G News LLC、GETTR USA、Genever Holdings Corporation、Genever Holdings LLC、GFASHION MEDIA GROUP INC.、GFNY, Inc.、Globalist International Limited、GNews Media Group Inc.、Golden Spring (New York) Ltd.、Greenwich Land LLC、Guo Media、GTV Media Group, Inc.、Hamilton Capital Holdings Inc.、Head Win Group Limited、Henan Yuda、Himalaya Embassy、Himalaya Exchange、Himalaya Federal Reserve、Himalaya Supervisory Organization、HK International Funds Investments (USA) Limited LLC、Hong Kong International Funds Investments Limited、Infinite Increase Limited、Infinitum Developments Limited、Insight Phoenix Fund、Lamp Capital LLC、Leading Shine Limited、Leading Shine NY Limited、Long Gate Limited、Next Tycoon Investments Limited、New Federal State of China（又名 NFSC）、Noble Fame Global Limited、Rosy Acme Ventures Limited、Rule of Law Foundation III, Inc.、Rule of Law Foundation IV, Inc.、Rule of Law Fund、Rule of Law Society、Rule of Law Society IV, Inc.、G-Translators PTY LTD、Saraca Media Group, Inc.、Shiny Ace Ltd.、Shiny Times Holdings Ltd.、Spirit Charter Investment Limited、Stevenson, Wong & Co.、Voice of Guo Media, Inc.、Well Origin Ltd.、World Century Limited、Worldwide Opportunity Holdings Limited、Whitecroft Shore Limited，以及 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”均系指“和/或”，并应作合取及析取两种解释，以最大限度扩大其范围。\n\n11. “任何”及“所有”及“每一”均系指“每一个及所有”。\n\n12. “每一”及“每个”均系指“每一个及所有”。\n\n13. “第三方”系指除你方以外的个人或实体。\n\n14. “转让”应具有 Bankruptcy Code 第101(54)条所赋予的含义。\n\n15. “文件”系指属于 Fed. R. Civ. P. 34 范围内的任何信息或物品，并包括但不限于任何种类、类型、性质或描述的每一项书面、记录或图形材料，只要该等材料现由或曾由你方占有、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、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、账簿、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未载有的任何种类的笔记、评论或标记，或其在其他方面与原始文件不一致。\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、委员会、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”系指涉及、描述、构成、提及、与之相关、支持、赞成、反对、加强、减损、位于其中、结合其予以考虑、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、与其有关、讨论、显示、描述、反映、分析、构成及属于。\n\n19. 当“与……有关”、“与……相关”或“有关”用于指任何特定主题事项时，系指但不限于构成、包含、涉及、含有、体现、反映、识别、陈述、直接或间接提及，或以任何方式与所指明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，系指任何信息或知识的传递（以事实、观念、询问或其他形式）。通信还指所有当面、通过电话、书面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往来函件、电子邮件、录音、传送单、备忘录、电话通信、语音消息、电报、传真、影印传真、电传、即时消息、聊天信息、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笔记。\n\n21. “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. 应提交的文件\n\n1. 与债务人、债务人财产、债务人的家属或关联实体的任何收入或资产有关的所有文件。\n\n2. 与同债务人、债务人的任何家属成员和/或任何关联实体签订的任何聘用函有关的所有文件，包括该等聘用函的副本。\n\n3. 与基于你方代理债务人、债务人的家属或关联实体而向你方支付任何预付律师费有关的所有文件，包括足以识别该预付律师费金额及其来源的文件。\n\n4. 与你方从债务人、债务人的家属、家庭关联实体或关联实体处或代表其收取并存入第三方托管账户或客户信托账户的任何费用、付款或款项有关的所有文件。\n\n5. 足以显示债务人、债务人的家属或关联实体向你方支付或为其利益向你方支付的任何款项的金额、日期及来源的文件。\n\n6. 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偿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\n7. 与关联实体有关的所有文件，包括但不限于与其公司结构、资产、设立信息、高级管理人员及董事、经营目的，以及其与债务人、债务人的任何家属成员或任何关联个人之关系有关的文件。\n\n8. 与一方的债务人或债务人的家属，以及另一方的关联实体所作出、与之进行或代表其进行的任何投资或商业交易有关的所有文件。\n\n9. 与债务人、债务人财产、债务人的家属或关联实体持有任何权益或投资的任何实体有关的所有文件，包括但不限于该等权益或投资的性质和价值；债务人、债务人财产、债务人的家属或关联实体因该等权益或投资而从该实体获得的任何收益或利益；以及与该实体有关的任何财务报告或数据有关的所有文件，包括但不限于所有账簿和记录、财务报表或税务文件。\n\n10. 与 Lady May（“梅夫人”号游艇）、Sherry Netherland Hotel / Condominium（Sherry Netherland 酒店／公寓）、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，以及债务人或债务人财产在任何关联实体中拥有的任何财务权益有关的所有文件。\n\n11. 与所谓日期为 February 17, 2015、由债务人以受托人身份、Genever Holdings Corporation（Genever Holdings 公司）及 Genever Holdings LLC（Genever Holdings 有限责任公司）订立，并以 Bravo Luck Limited（Bravo Luck 有限公司）为受益人的《信托声明及协议》有关的所有文件。\n\n12. 与债务人拥有、控制或使用的任何飞机有关的所有文件，包括但不限于机尾编号为 T7-GQM 的飞机及在 San Marino（圣马力诺）登记的任何其他飞机，包括但不限于所有登记文件副本及显示该等飞机所进行航班和该等航班上人员的飞行清单。\n\n13. 与债务人、债务人家属或关联实体于 July 2020 前后或任何其他时间就原油期货或任何类似商品进行的任何投资或交易有关的所有文件，包括但不限于与 Jiang Yunfu Be（贝江云富）就任何该等投资或交易进行的通信。\n案件 22-50073 文档 839 提交于 09/07/22 录入于 09/07/22 20:02:47 第 234 页，共 491 页\n\n14. 您与债务人、债务人家属或任何关联个人、代理人、雇员或其他代表债务人行事的个人之间，就与债务人、债务人财产、债务人家属或关联实体有关的任何转让、投资或其他交易或商业往来进行的所有通信。\n\n15. 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，包括但不限于显示该等信托何时设立、由谁设立、为谁的利益而设立以及该文书信托财产的文件。\n\n16. 与涉及债务人、债务人家属或任何关联实体的任何出售、取得、处分、购买、投资、出资、赠与、信贷展期、贷款或转让有关的所有文件。\n\n17. 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）进行的任何诉讼有关的文件。\n\n18. 与向债务人、债务人财产、债务人家属或任何关联实体提供或由其提供的任何贷款或信贷展期，或就该等贷款或信贷展期提出的申请有关的所有文件，包括但不限于：(i) 任何该等贷款或信贷展期的条款，包括其偿还条款、陈述与保证以及利率；及 (ii) 所有贷款付款的证据。\n案件 22-50073 文档 839 提交于 09/07/22 录入于 09/07/22 20:02:47 第 235 页，共 491 页\n\n19. 与债务人使用由债务人家属、关联实体或关联个人所有、控制或由其持有全部或部分所有权的任何资产有关的所有文件。\n\n20. 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、账户结单、财务报表、账户报表、电汇指示及／或确认书、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前述任何主体进行的所有转让的所有文件。\n\n21. 与将任何关联实体（包括 Bravo Luck Limited）的资产质押给任何其他实体有关的所有文件。\n\n案件 22-50073 文档 839 提交于 09/07/22 录入于 09/07/22 20:02:47 第 236 页，共\n\nB2540（表格 2540——依破产规则第 2004 条审查的传票）（第 2 页） 491\n\n（除非 Federal Rules of Civil Procedure（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于（日期）\n__________ 本人已为（个人姓名及职务，如有）：______________________________________________ 收到本传票。\n本人通过向被指名人员交付副本送达传票，具体如下：____________________________________\n\n__________________________________ 于（日期）___________________；或\n本人因下列原因将传票未执行退回：____________________________________________________________\n\n本人因出行收取费用 \\$ _________，因服务收取费用 \\$_________，合计 \\$_________。除非传票代表 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允许的里程费，金额为 \\$ _______________________ 。\n\n本人在伪证处罚之下声明，该等信息真实且正确。\n\n日期：_______________ ________________________________________________\n送达人签名\n\n送达人地址\n\n有关尝试送达等的补充信息：\nFederal Rules of Civil Procedure（联邦民事诉讼规则）第 45(c)、(d)、(e) 及 (g) 条（Effective 12/1/13）（依 Federal Rules of Bankruptcy Procedure（联邦破产程序规则）第 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、受雇或经常亲自从事业务地点 100 英里以内；或\n\n(B) 在该人居住、受雇或经常亲自从事业务所在州内，如果该人\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(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该场所。\n(d) 保护受传票约束的人；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，避免向受传票约束的人施加不当负担或费用。要求履行传票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，其中可包括收入损失和合理的律师费。\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，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 天中较早的时间之前送达。如提出异议，适用以下规则：\n\n(i) 在任何时候，送达传票的当事人可以通知被命令的人后，向要求履行传票的地区法院申请强制提交或检查的命令。\n\n(ii) 仅可依命令所指示要求进行该等行为，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，要求履行传票的地区法院必须撤销或修改符合下列情形的传票：\n\n(i) 未给予合理的履行时间；(ii) 要求某人在超出第 45(c) 条规定的地域限制范围内履行；\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的人，要求履行传票的地区法院可以经动议撤销或修改符合下列情形的传票：\n\n(i) 要求披露商业秘密或其他保密研究、开发或商业信息；或\n\n(ii) 要求披露未受聘专家的意见或信息；该等意见或信息不描述争议中的具体事件，并且源于未由当事人请求进行的专家研究。\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，如送达传票的当事人：\n\n(i) 证明对该证言或材料具有实质需要，且不遭受不当困难便无法以其他方式满足该需要；并且\n\n(ii) 确保受传票人将获得合理补偿，\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的人，必须按照文件在日常业务过程中保存的方式提交，或者按照要求中所列类别对文件进行整理和标记。\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。回应人无须从其认定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。在提出强制证据开示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访问。如作出该证明，法院仍可在请求方证明有正当理由并考虑第 26(b)(2)(C) 条限制的情况下，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(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：\n\n(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）已提供的信息。如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约束，提出该主张的人可将该主张及其依据通知任何已收到该信息的当事人。收到通知后，当事人必须立即返还、隔离保管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，必须采取合理措施予以追回；并可立即将该信息密封提交至要求履行的地区法院，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。要求履行的地区法院——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而未遵守传票或与其相关命令的人处以藐视法庭。\n\n如需查阅传票材料，参见 Fed. R. Civ. P. 45(a) Committee Note (2013)\n\n……\n\n附件 C-12\n\nB2540（表格 2540——规则 2004 审查传票）（12/15）UNITED STATES BANKRUPTCY COURT（美国破产法院）案件 22-50073 文件 839 已提交 09/07/22 已录入 09/07/22 20:02:47 第 239 页，共 491 页\n\n_______________________________________________________________ Connecticut（康涅狄格地区）\n\n关于 _______________________________________________________________\n\n案件编号：________________________________ Ho Wan Kwok（郭文贵）22-50073\n\n债务人\n\n第 _________ 章 11\n\n规则 2004 审查传票\n\n致：________________________________________________________________________________________________ Cahill Gordon & Reindel LLP（凯易律师事务所）\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》规则 2004 的审查作证。随附授权该审查的法院命令副本。\n\n地点 日期和时间\n\nPaul Hastings LLP（普衡律师事务所）\n200 Park Avenue\nNew York, New York 10166（纽约州纽约市 10166）\n\n该审查将通过以下方式记录：____________________________________________________________ 法庭记录员／速记员\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出席审查，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以下 Fed. R. Civ. P. 45 的规定，根据 Fed. R. Bankr. P. 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)；与作为传票对象的您所受保护有关的规则 45(d)；以及与您回应本传票的义务及未履行该义务可能产生的后果有关的规则 45(e) 和 45(g)。\n\n日期：September ______________ __, 2022\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 Patrick R. Linsey（ct29437）\n\n代表（当事人姓名）____________________________并签发或请求本传票的律师姓名、地址、电子邮件地址和电话号码如下：Luc Despins（卢克·德斯潘），第 11 章受托人\n\nPatrick R. Linsey, Esq.（帕特里克·R·林赛）；Neubert, Pepe & Monteith, P.C.（诺伊伯特、佩佩与蒙蒂思律师事务所）；195 Church Street, New Haven, Connecticut 06510；plinsey@npmlaw.com；203-821-2000\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文件提交请求\n\n一、指示\n\n1．除非另有说明，下列文件提交请求（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。除非善意地提出异议，否则必须对每一项请求作出完整答复；如提出异议，必须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，或其中包含的某个词语、短语或条款，您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的 Bates 编号命名的占位图像。\n\nb．图像加载文件\n\n（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）。日期字段应按 mm/dd/yyyy 格式提供。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，则必须包含附件字段，以保存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，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,PageCoun。\n\n（c）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）应包含于 .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）。必须按文件级别提供文本文件。\n\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地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，注明存在原生文件，并将原生文件的路径作为字段载入 .dat 文件。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。对于存在完全相同副本的每份电子文件，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 哈希值合并重复项。对于电子邮件附件和独立电子文件，应根据整个文件的 MD5 哈希值合并重复项。\n\n（f）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日期字段应按 mm/dd/yyyy 格式提供。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案件 22-50073 文件 839 已提交 09/07/22 已录入 09/07/22 20:02:47 第 242 页，共 491 页\n\n字段名称 示例数据 说明\n\nFIRSTBATES EDC0000001 原生文件／电子邮件文件的首个 Bates 编号\n\nLASTBATES EDC0000001 原生文件／电子邮件文件的最后一个 Bates 编号\n\nLASTBATES 字段应就单页文件填写\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（约翰·史密斯） 电子邮件：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\n\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\n\nTO Coffman, Janice（贾尼斯·科夫曼）；LeeW［mailto:LeeW@MSN.com］ 收件人\n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\n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\n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/TIME_ZONE 07:05 PM GMT 电子邮件：电子邮件发送时间／电子邮件标准化时所采用的时区\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的超链接\n所链接文件必须按 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 839 已提交 09/07/22 已录入 09/07/22 20:02:47 第 243 页，共 491 页\n\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（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：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：唯一消息 ID 原生：（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. 所有文件应按其在通常业务过程中保存的方式提供，或者应予以组织和标注，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) 在贵方占有、保管或控制之下的文件；或 (b) 在代表贵方行事的任何人占有、保管或控制之下的文件，\nCase 22-50073 Doc 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 244 of 491\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处于贵方的占有、保管或控制之下，则贵方的答复必须：(a) 详细说明该文件的性质及其内容；(b) 确定编制或撰写该文件的人员（以及，如适用，接收该文件的人员）；(c) 确定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与之有关的事实和情形；(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处于贵方占有、保管或控制之下的时间；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) 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. 如贵方主张所要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提及的任何信息是否处于任何其他人员的占有、保管或控制之下，如是，该等人员的身份，\nCase 22-50073 Doc 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 245 of 491\n\n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；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，制作一份特权日志，其中载有本指示第 (a) 部分要求的全部信息。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. 如一份本应回应请求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. 本请求具有持续性。特此指示贵方：(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知为不完整或不正确的任何答复；以及 (b) 提供根据下述规定所要求的任何补充文件。\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文，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。\nCase 22-50073 Doc 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 246 of 491\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) 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在所有其他时态中使用该动词。\n\n16. (a) “and”和“or”应视为根据需要作合取或析取解释，以将原本可能被解释为不在其范围内的所有答复纳入任何请求的范围内；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根据 D. Conn. L. Civ. R. 26(c) 提供、并经 D. Conn. Bankr. L.R. 2004-1(a) 纳入的定义，以及根据 D. Conn. L. Civ. R. 26(d) 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以下含义：\n\n1. “贵方”或“贵方的”或“贵方自身”系指 Cahill Gordon & Reindel LLP（凯易律师事务所），连同其任何雇员、代理人、律师、顾问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（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、顾问或代表其行事的任何人。\nCase 22-50073 Doc 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 247 of 491\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）、郭美，或任何其他别名），连同其雇员、代理人、律师、顾问或代表其行事的任何人。\n\n5. “债务人所谓的妻子”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所谓的妻子，以及与债务人存在任何其他家庭关系的人，合称。\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、控制或享有的资产享有处置权；或 (2) 曾担任一个或多个关联实体的雇员、董事，或以其他方式与其有关联，连同前述任何人员各自的雇员、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：Daniel Podhaskie（丹尼尔·波达斯基）、Jason Miller（杰森·米勒）、Steve Bannon（史蒂夫·班农）、Karin Maistrello（卡琳·迈斯特雷洛）、Melissa Francis（梅丽莎·弗朗西斯）、William Gertz（威廉·格茨）、Arethusa Forsyth（阿瑞苏莎·福赛斯）、Glenn Mellor（格伦·梅勒）、Jennifer Mercurio（詹妮弗·默丘里奥）、Eduardo Eurnekian（爱德华多·欧尔内基安）、Han Chunguang（韩春光）（又名韩春光）、Qu Guojiao（屈国姣）（又名 Qu Guo Jiao（屈国姣）、屈国姣）、Guo Lijie（郭丽杰）（又名郭丽杰）、Zhang Wei（张伟）（又名张伟*）、Lihong Wei Lafrenz（魏丽红）（又名 Sara Wei（魏丽红）、魏丽红）、Hao Haidong（郝海东）（又名郝海东）、Ross Heinemeyer（罗斯·海内迈耶）、Max Krasner（马克斯·克拉斯纳）、Kyle Bass（凯尔·巴斯）、Melissa Mendez（梅丽莎·门德斯）、Ya Li（李娅）（又名李娅）、Dinggang Wang（王定刚）（又名王定刚）、An Hong（安红）（又名安红）、Yvette Wang（王雁平）（又名 Yanping\nCase 22-50073 Doc 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 248 of 491\n\nWang（王雁平）、Yan Ping Wang（王雁平）、王雁平）、Fiona Yu（菲奥娜·余）、Je Kin Ming（余建明）（又名 William Je（余建明）、Yu Jianming（余建明）、余建明）、Yaz Qingua（亚兹·青瓜）及 Lao Jiang（姜云浮）（又名 Jiang Yunfu（姜云浮）、Jiang Yunfu Be（姜云浮）、姜云浮）。\n\n8. “关联实体”系指单独或共同符合下列情形的任何类型的所有组织或实体：(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，连同前述任何实体各自的雇员、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：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、Assets Sino Limited、Auspicious Coast Limited、Beijing Pangu Investment Co.、Beijing Pangu Investment Co. Ltd.、Beijing Pangu Investment Inc.、Beijing Zenith Holdings Company Limited、Bravo Luck Limited、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、Elite Well Global Limited、Empire Growth Holdings、G Club Operations LLC、G Fashion LLC、G News LLC、GETTR USA、Genever Holdings Corporation、Genever Holdings LLC、GFASHION MEDIA GROUP INC.、GFNY, Inc.、Globalist International Limited、GNews Media Group Inc.、Golden Spring (New York) Ltd.、Greenwich Land LLC、Guo Media、GTV Media Group, Inc.、Hamilton Capital Holdings Inc.、Head Win Group Limited、Henan Yuda、Himalaya Embassy、Himalaya Exchange、Himalaya Federal Reserve、Himalaya Supervisory Organization、HK International Funds Investments (USA)\nCase 22-50073 Doc 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 249 of 491\n\nLimited LLC、Hong Kong International Funds Investments Limited、Infinite Increase Limited、Infinitum Developments Limited、Insight Phoenix Fund、Lamp Capital LLC、Leading Shine Limited、Leading Shine NY Limited、Long Gate Limited、Next Tycoon Investments Limited、New Federal State of China（新中国联邦）（又名 NFSC）、Noble Fame Global Limited、Rosy Acme Ventures Limited、Rule of Law Foundation III, Inc.、Rule of Law Foundation IV, Inc.、Rule of Law Fund、Rule of Law Society、Rule of Law Society IV, Inc.、G-Translators PTY LTD、Saraca Media Group, Inc.、Shiny Ace Ltd.、Shiny Times Holdings Ltd.、Spirit Charter Investment Limited、Stevenson, Wong & Co.、Voice of Guo Media, Inc.、Well Origin Ltd.、World Century Limited、Worldwide Opportunity Holdings Limited、Whitecroft Shore 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”均指“和/或”，并应按合取及析取两种含义解释，以最大限度扩大其范围。\n\n11. “任何”及“所有”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”是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”是指属于《联邦民事诉讼规则》第34条范围内的任何信息或物件，包括但不限于您占有、保管或控制之下或曾处于您占有、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，\n案件 22-50073 文件 839 提交于 09/07/22 录入于 09/07/22 20:02:47 第 250 页，共 491 页\n\n图表、蓝图、图纸、草图、图形、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、明细表、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、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，以及上述材料的所有元数据，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；还包括但不限于上述任何材料的草稿或副本，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完全相同。\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、赞成、反对、强化、削弱、位于、结合考虑、对其有影响、证明、表明、报告、记录、暗指、回应，\n案件 22-50073 文件 839 提交于 09/07/22 录入于 09/07/22 20:02:47 第 251 页，共 491 页\n\n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、构成以及属于。\n\n19. 在提及任何特定主题事项时，“与……有关”“涉及”或“相关”是指，包括但不限于，构成、包含、涉及、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相关的任何文件。\n\n20. “通信”是指，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、电话笔记，或在内部或与第三方之间传送的笔记。\n\n21. “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、存货以及其他有形和无形财产。\n\n四、须提交的文件\n\n1. 与债务人、债务人财产、债务人家庭成员或关联实体的任何收入或资产有关的所有文件。\n案件 22-50073 文件 839 提交于 09/07/22 录入于 09/07/22 20:02:47 第 252 页，共 491 页\n\n2. 与您同债务人、债务人家庭成员的任何成员和/或任何关联实体签订的任何聘任函有关的所有文件，包括该等聘任函的副本。\n\n3. 与基于您对债务人、债务人家庭成员或关联实体的代理而向您支付任何预付费用有关的所有文件，包括足以识别该预付费用金额及其来源的文件。\n\n4. 与您从债务人、债务人家庭成员、家庭关联实体或关联实体处或代表其收取，并存放于第三方保管账户或客户信托账户中的任何费用、付款或款项有关的所有文件。\n\n5. 足以显示债务人、债务人家庭成员或关联实体向您支付或为其利益向您支付的任何款项之金额、日期及来源的文件。\n\n6. 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潜在破产或类似无力偿债程序有关的所有文件。\n\n7. 与关联实体有关的所有文件，包括但不限于与其公司结构、资产、设立信息、高级职员及董事、商业目的，以及其与债务人、债务人家庭成员的任何成员或任何关联个人之间关系有关的文件。\n\n8. 与债务人或债务人家庭成员一方同关联实体另一方之间，由其作出、与其进行或代表其进行的任何投资或商业交易有关的所有文件。\n案件 22-50073 文件 839 提交于 09/07/22 录入于 09/07/22 20:02:47 第 253 页，共 491 页\n\n9. 与债务人、债务人财产、债务人家庭成员或关联实体持有任何权益或投资的任何实体有关的所有文件，包括但不限于该权益或投资的性质及价值；债务人、债务人财产、债务人家庭成员或关联实体因该等权益或投资而从该实体获得的任何收益或利益；以及与该实体有关的任何财务报告或数据有关的所有文件，包括但不限于所有账簿和记录、财务报表或税务文件。\n\n10. 关于 Lady May（梅夫人号）、Sherry Netherland Hotel / Condominium（谢里荷兰酒店／共管公寓）、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，以及债务人或债务人财产在任何关联实体中拥有的任何财务权益的所有文件。\n\n11. 与债务人以受托人身份、Genever Holdings Corporation（杰尼弗控股公司）及 Genever Holdings LLC（杰尼弗控股有限责任公司）于 February 17, 2015 为受益人 Bravo Luck Limited（布拉沃幸运有限公司）订立的所谓《信托声明及协议》有关的所有文件。\n\n12. 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的副本，以及显示该等航空器所执行航班和乘坐该等航班人员的飞行清单。\n\n13. 与债务人、债务人家庭成员或关联实体于 July 2020 前后或在任何其他时间进行的任何原油期货或任何类似商品投资或交易有关的所有文件，包括但不限于与 Jiang Yunfu Be（姜云福贝）就任何该等投资或交易进行的通信。\n案件 22-50073 文件 839 提交于 09/07/22 录入于 09/07/22 20:02:47 第 254 页，共 491 页\n\n14. 您与债务人、债务人家庭成员或任何关联个人、代理人、雇员或代表债务人行事的其他个人之间，就与债务人、债务人财产、债务人家庭成员或关联实体有关的任何转让、投资或其他交易或商业交易所进行的所有通信。\n\n15. 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所有文件，包括但不限于显示该等信托何时设立、由谁设立、为谁的利益设立以及该文书信托财产的文件。\n\n16. 与涉及债务人、债务人家庭成员或任何关联实体的任何出售、收购、处分、购买、投资、出资、赠与、授信、贷款或转让有关的所有文件。\n\n17. 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、审裁小组或替代性争议解决实体。\n\n18. 与向债务人、债务人财产、债务人家庭成员或任何关联实体提供或由其提供的任何贷款或授信，或对此提出的申请有关的所有文件，包括但不限于：(i) 任何该等贷款或授信的条款，包括其还款条款、陈述与保证及利率；以及 (ii) 所有贷款付款的证据。\n案件 22-50073 文件 839 提交于 09/07/22 录入于 09/07/22 20:02:47 第 255 页，共 491 页\n\n19. 与债务人使用属于、受控制于或其全部或部分所有权由债务人家庭成员、关联实体或关联个人持有的任何资产有关的所有文件。\n\n20. 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，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所有文件。\n\n21. 与将任何关联实体（包括 Bravo Luck Limited（布拉沃幸运有限公司））的任何资产质押给任何其他实体有关的所有文件。\n\n案件 22-50073 文件 839 提交于 09/07/22 录入于 09/07/22 20:02:47 第 256 页，共\n\nB2540（表格2540——规则2004审查传票）（第2页） 491\n\n本人于（日期）_______________________________收到向以下个人送达的本传票（个人姓名及职务，如有）：______________________________________________\n\n本人通过向所列名人员交付副本的方式送达本传票\n\n于（日期）___________________；或方式如下：____________________________________\n\n本人因下列原因未予执行而退回本传票：____________________________________________________________\n\n除非该传票系代表 United States（美国）或其官员或代理人签发，本人亦已向该证人支付一天出席费用及法律允许的里程费，金额为 \\$ _______________________ 。本人旅费为 \\$ _________，服务费为 \\$_________，合计 \\$_________。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（2013年12月1日生效）（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、受雇或经常亲自从事商业活动地点的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的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。负责签发和送达传票的当事人或律师必须采取合理措施，避免向受传票约束之人施加不当负担或费用。要求履行传票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，或允许检查场所之人，除非同时被命令出席证言录取、听证或审判，否则无需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，或允许检查之人，可就检查、复制、测试或抽样全部或部分材料，或检查场所，或以所要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。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人后，向要求履行传票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\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，要求履行传票的地区法院必须撤销或修改存在下列情形的传票：\n\n(i) 未给予合理的履行时间；(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，要求履行传票的地区法院可经动议，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) 披露未经聘用的专家的意见或信息，而该等意见或信息并非描述争议中的具体事件，且系源于未经当事人请求的该专家研究。\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以其他方式满足该需要；以及\n\n(ii) 确保受传唤之人将获得合理补偿，\n\n法院可不撤销或修改传票，而命令其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。回应提交文件传票之人，必须按照文件在日常业务过程中保存的方式提交，或必须将其整理并标注，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。回应之人无需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。就强制证据开示的动议或保护令动议，回应之人必须证明该信息因不当负担或费用而无法合理获取。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) 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受传票要求的信息之人，必须：\n\n(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的信息的情况下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给要求履行传票的地区法院，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存该信息。\n\n(g) 藐视法庭。要求履行传票的地区法院——以及在动议移送后，签发传票的法院——可对已被送达但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有关获取传票材料，请参见 Fed. R. Civ. P. 45(a) Committee Note (2013)\n\n……\n\n证物 C-13\n\nB2540（表格2540——根据 Rule 2004 进行审查的传票）(12/15) UNITED STATES BANKRUPTCY COURT（美国破产法院） Case 22-50073 Doc 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 259 of 491\n\n________________________________________________________________________ 地区法院，康涅狄格州 ________________________________________________________________________\n\n关于 ________________________________________________________________________\n\n案号：________________________________ Ho Wan Kwok（郭文贵）22-50073\n\n债务人\n\n第 ________ 章 11\n\n根据 Rule 2004 进行审查的传票\n\n致：________________________________________________________________________________________________ Elliott Kwok Levine & Jaroslaw LLP（艾略特·郭·莱文与贾罗斯瓦夫律师事务所）\n\n（传票所指向之人的姓名）\n\n证言：兹命令你于下列规定的时间、日期和地点出席，根据《联邦破产程序规则》Rule 2004 进行审查并作证。随附准许该审查的法院命令副本。\n\n地点 日期和时间\n\nPaul Hastings LLP（普衡律师事务所）\n200 Park Avenue\nNew York, New York 10166\n\n审查将以以下方式记录：______________________________________________________________ 法院书记员／速记员\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，并必须允许对该材料进行检查、复制、测试或抽样：\n\n参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，现随附于此——关于履行地点的 Rule 45(c)；关于你作为受传票约束之人所受保护的 Rule 45(d)；以及关于你回应本传票的义务及不回应的潜在后果的 Rule 45(e) 和 45(g)。\n\n日期：September __, 2022\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 Patrick R. Linsey（帕特里克·R·林赛）(ct29437)\n\n代表（当事人姓名）_________________________ 的律师，其签发或请求本传票的姓名、地址、电子邮件地址和电话号码如下：Luc Despins（吕克·德斯平），第11章受托人\n\nPatrick R. Linsey, Esq.; Neubert, Pepe & Monteith, P.C.（纽伯特、佩佩与蒙蒂斯律师事务所）；195 Church Street, New Haven, Connecticut 06510；plinsey@npmlaw.com；203-821-2000\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，向每一当事人送达通知及本传票副本。Fed. R. Civ. P. 45(a)(4)。\n\n文件提交请求\n\n一、指示\n\n1. 除非另有说明，下列文件请求（以下简称“请求”，各项称为“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，除非基于善意提出异议；如提出异议，应按下文所述详细说明你提出异议的理由。如异议仅涉及某项请求的一部分，或该请求中包含的某个词语、短语或条款，你须仅就该部分说明异议，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\n英文>>>\n\na．图像。黑白图像必须为 300 DPI Group IV 单页 TIFF 文件。彩色图像必须采用 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。每份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。如文件包括图像化的电子邮件及附件，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均应在交叉引用文件中具有一行，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 文件中的字段提供。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。文件夹名称中不得包含特殊字符（包括逗号）。文本文件必须按文件级提供。\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。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。应提供一份带有 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包括在内。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。对于存在完全重复件的每一电子文件，仅提供一份副本。对于电子邮件信息，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。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。下列为必需元数据：\n\n案件 22-50073 文件 839 提交于 09/07/22 录入于 09/07/22 20:02:47 第 262 页，共 491 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 - EDC0000015 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。\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 电子邮件：该电子邮件所在的邮箱。原生文件：该文件源自其文件的个人或部门名称。\n\nFROM John Smith 电子邮件：发件人。原生文件：文件作者。\n\n多个条目之间应使用分号分隔。\n\nTO Coffman, Janice; LeeW [mailto:LeeW@MSN.com] 收件人。\n\n多个条目之间应使用分号分隔。\n\nCC Frank Thompson [mailto:frank_Thompson@cdt.com] 抄送收件人。\n\n多个条目之间应使用分号分隔。\n\nBCC John Cain 密送收件人。\n\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：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/电子邮件标准化所采用的时区。\n\nTIME_ZONE GMT 在转换期间对电子邮件进行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\n所链接文件必须以 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 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\n案件 22-50073 文件 839 提交于 09/07/22 录入于 09/07/22 20:02:47 第 263 页，共 491 页\n\nTIME_CREATED 10:25 AM 电子邮件：（空）。原生文件：文件创建时间。\n\n该数据必须为单独字段，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。\n\n该数据必须为单独字段，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。\n\n该数据必须为单独字段，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，以 KB 计。\n\nPGCOUNT 1 原生文件文件/电子邮件的页数。\n\nPATH Email: （空）Agenda.doc 原生文件：存储原生文件文件的路径，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：唯一信息 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．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其他任何请求的范围。\n\n4．所有文件均应按其在正常业务过程中保存的方式提供，或者应进行组织和标记，以对应本请求中的类别。\n\n5．本文件所载每项请求均延伸至所有文件：（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\n案件 22-50073 文件 839 提交于 09/07/22 录入于 09/07/22 20:02:47 第 264 页，共 491 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）确认编制或撰写该文件的人员（以及，如适用，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）已自愿或非自愿转移给他人；或（iv）以其他方式处置；（e）说明该等处置的原因以及相关事实和情形；（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）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，则确认该等人员身份，并说明该等信息如何进入其占有范围；（viii）据以拒绝提供该文件的特权主张；以及（ix）贵方将据以支持该等特权主张的所有情形；以及（b）根据 D. Conn. L. Civ. R. 26(e)，针对每份基于特权主张而拒绝提供的文件，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。对于文件请求中未就其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 839 提交于 09/07/22 录入于 09/07/22 20:02:47 第 265 页，共 491 页\n\n9．如一份原本具有响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盖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。现指示贵方：（a）一旦得知先前答复不完整或不正确，即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案号 22-50073 文书 839 提交于 09/07/22 录入于 09/07/22 20:02:47 第 266 页，共 491 页\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 起至对文件请求作出答复的截止日期止。\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”应视必要情况作连言或选言解释，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 Elliott Kwok Levine & Jaroslaw LLP（艾略特·郭·莱文与雅罗斯拉夫律师事务所），连同其任何雇员、代理人、律师、顾问或代表其行事的任何人。\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、顾问或代表其行事的任何人。\n案号 22-50073 文书 839 提交于 09/07/22 录入于 09/07/22 20:02:47 第 267 页，共 491 页\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、顾问或代表其行事的任何人。\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、顾问或代表其行事的任何人。\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、顾问或代表其行事的任何人。\n\n6．“Debtor's Family”统称债务人、债务人之子、债务人之女、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，（1）持有、控制、保管债务人或债务人家庭成员拥有、控制或享有的资产，或对该等资产拥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，连同前述任何人员各自的雇员、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：Daniel Podhaskie（丹尼尔·波达斯基）、Jason Miller（杰森·米勒）、Steve Bannon（史蒂夫·班农）、Karin Maistrello（卡琳·迈斯特雷洛）、Melissa Francis（梅利莎·弗朗西斯）、William Gertz（威廉·格茨）、Arethusa Forsyth（阿瑞修莎·福赛思）、Glenn Mellor（格伦·梅勒）、Jennifer Mercurio（詹妮弗·默丘里奥）、Eduardo Eurnekian（爱德华多·尤尔内基安）、Han Chunguang（韩春光）（又名 韩春光）、Qu Guojiao（屈国姣）（又名 Qu Guo Jiao、屈国姣）、Guo Lijie（郭丽杰）（又名 郭丽杰）、Zhang Wei（张伟）（又名 张伟*）、Lihong Wei Lafrenz（魏丽红）（又名 Sara Wei、魏丽红）、Hao Haidong（郝海东）（又名 郝海东）、Ross Heinemeyer（罗斯·海内迈耶）、Max Krasner（马克斯·克拉斯纳）、Kyle Bass（凯尔·巴斯）、Melissa Mendez（梅利莎·门德斯）、Ya Li（李娅）（又名 李娅）、Dinggang Wang（王定刚）（又名 王定刚）、An Hong（安红）（又名 安红）、Yvette Wang（王雁平）（又名 Yanping Wang、\n案号 22-50073 文书 839 提交于 09/07/22 录入于 09/07/22 20:02:47 第 268 页，共 491 页\n\nWang, Yan Ping Wang, 王雁平), Fiona Yu, Je Kin Ming (a/k/a William Je, Yu Jianming, 余建明\n\n), Yaz Qingua, and Lao Jiang (a/k/a Jiang Yunfu, Jiang Yunfu Be, 姜云浮).\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: 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, Assets Sino Limited, Auspicious Coast Limited, Beijing Pangu Investment Co., Beijing Pangu Investment Co. Ltd., Beijing Pangu Investment Inc., Beijing Zenith Holdings Company Limited, Bravo Luck Limited, 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, Elite Well Global Limited, Empire Growth Holdings, G Club Operations LLC, G Fashion LLC, G News LLC, GETTR USA, Genever Holdings Corporation, Genever Holdings LLC, GFASHION MEDIA GROUP INC., GFNY, Inc., Globalist International Limited, GNews Media Group Inc., Golden Spring (New York) Ltd., Greenwich Land LLC, Guo Media, GTV Media Group, Inc., Hamilton Capital Holdings Inc., Head Win Group Limited, Henan Yuda, Himalaya Embassy, Himalaya Exchange, Himalaya Federal Reserve, Himalaya Supervisory Organization, HK International Funds Investments (USA)\nCase 22-50073 Doc 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 269 of 491\n\nLimited LLC, Hong Kong International Funds Investments Limited, Infinite Increase Limited, Infinitum Developments Limited, Insight Phoenix Fund, Lamp Capital LLC, Leading Shine Limited, Leading Shine NY Limited, Long Gate Limited, Next Tycoon Investments Limited, New Federal State of China (a/k/a NFSC), Noble Fame Global Limited, Rosy Acme Ventures Limited, Rule of Law Foundation III, Inc., Rule of Law Foundation IV, Inc., Rule of Law Fund, Rule of Law Society, Rule of Law Society IV, Inc., G-Translators PTY LTD, Saraca Media Group, Inc., Shiny Ace Ltd., Shiny Times Holdings Ltd., Spirit Charter Investment Limited, Stevenson, Wong & Co., Voice of Guo Media, Inc., Well Origin Ltd., World Century Limited, Worldwide Opportunity Holdings Limited, Whitecroft Shore 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\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, correspondence, memoranda, tapes, stenographic or handwritten notes, written forms of any kind,\nCase 22-50073 Doc 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 270 of 491\n\n5. 足以显示债务人、债务人家庭成员或关联实体向您作出或为其利益作出的任何付款的金额、日期及来源的文件。\n\n6. 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，包括但不限于与避免支付该等义务的任何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无力偿债程序有关的所有文件。\n\n7. 与关联实体有关的所有文件，包括但不限于与其公司结构、资产、设立登记信息、高级管理人员及董事、经营目的，以及其与债务人、债务人任何家庭成员或任何关联个人的关系有关的文件。\n\n8. 关于债务人或债务人家庭成员一方与关联实体另一方所进行、与之进行或代表其进行的任何投资或商业交易的所有文件。\n案号 22-50073 文件 839 提交日期 09/07/22 录入日期 09/07/22 20:02:47 第 273 页，共 491 页\n\n9. 与债务人、债务人财产、债务人家庭成员或关联实体持有任何权益或投资的任何实体有关的所有文件，包括但不限于该权益或投资的性质和价值；债务人、债务人财产、债务人家庭成员或关联实体因该等权益或投资而从该实体获得的任何收益或利益；以及与该实体有关的任何财务报告或数据的所有文件，包括但不限于所有账簿和记录、财务报表或税务文件。\n\n10. 关于 Lady May；Sherry Netherland Hotel / Condominium；位于康涅狄格州格林威治市 373 Taconic Rd. 的住宅房产；位于康涅狄格州格林威治市 33 Ferncliff Rd. 的住宅房产；位于康涅狄格州威尔顿市 354 Nod Hill Rd. 的住宅房产；以及债务人或债务人财产在任何关联实体中拥有的任何财务权益的所有文件。\n\n11. 与据称由债务人作为受托人、Genever Holdings Corporation 和 Genever Holdings LLC 于 February 17, 2015 签订，并以 Bravo Luck Limited 为受益人的《信托声明及协议》有关的所有文件。\n\n12. 与债务人拥有、控制或使用的任何飞机有关的所有文件，包括但不限于尾号为 T7-GQM 的飞机，以及在圣马力诺登记的任何其他飞机；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机上人员的飞行舱单。\n\n13. 与债务人、债务人家庭成员或关联实体于 July 2020 前后或任何其他时间进行的任何原油期货或任何类似商品的投资或交易有关的所有文件，包括但不限于与 Jiang Yunfu Be 就任何该等投资或交易进行的通信。\n案号 22-50073 文件 839 提交日期 09/07/22 录入日期 09/07/22 20:02:47 第 274 页，共 491 页\n\n14. 您与债务人、债务人家庭成员，或代表债务人行事的任何关联个人、代理人、雇员或其他个人之间，就与债务人、债务人财产、债务人家庭成员或关联实体有关的任何转让、投资或其他交易或商业往来进行的所有通信。\n\n15. 与由债务人、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有关的所有文件，包括但不限于显示该等信托何时设立、由谁设立、为谁的利益设立以及该文书信托财产的文件。\n\n16. 与涉及债务人、债务人家庭成员或任何关联实体的任何出售、取得、处分、购买、投资、出资、赠与、授信、贷款或转让有关的所有文件。\n\n17. 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、联邦或国际机构审理的任何诉讼有关的文件，无论该机构为行政机构、法院、合议庭还是替代性争议解决实体。\n\n18. 与向债务人、债务人财产、债务人家庭成员或任何关联实体提供或由其提供的任何贷款或授信，或就此提出的申请有关的所有文件，包括但不限于：(i) 任何该等贷款或授信的条款，包括其还款条款、陈述与保证及利率；以及 (ii) 贷款付款的所有证明。\n案号 22-50073 文件 839 提交日期 09/07/22 录入日期 09/07/22 20:02:47 第 275 页，共 491 页\n\n19. 与债务人使用属于、由债务人家庭成员、关联实体或关联个人控制，或其全部或部分所有权由债务人家庭成员、关联实体或关联个人持有的任何资产有关的所有文件。\n\n20. 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、电汇指示和/或确认函、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一方进行的所有转让的所有文件。\n\n21. 与任何关联实体（包括 Bravo Luck Limited）向任何其他实体质押资产有关的所有文件。\n\n案号 22-50073 文件 839 提交日期 09/07/22 录入日期 09/07/22 20:02:47 第 276 页，共\n\nB2540（表格 2540——依据规则 2004 审查的传票）（第 2 页） 491\n\n我于（日期）__________ 收到向以下人员送达的本传票（个人姓名及职务，如有）：______________________________________________。\n\n我通过如下方式向被指名人员交付副本，送达本传票：____________________________________\n\n__________________________________，送达日期为 ___________________；或者\n\n我因下列原因未执行传票即予退回：____________________________________________________________\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席费用及法律允许的里程费，金额为 \\$ _______________________。\n\n我的费用为差旅 \\$ _________ 及服务 \\$_________，合计 \\$_________。\n\n我在伪证处罚下声明\n\n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）（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；或者\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) 为当事人或当事人的高级管理人员；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) 在拟检查的场所进行场所检查。\n\n(d) 保护受传票约束的人员；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，避免对受传票约束的人员造成不当负担或费用。要求履行的地区所属法院必须执行该项义务，并对未遵守者，即当事人或律师，施加适当制裁，其中可能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、测试或抽样全部或部分材料，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 日之前（以较早者为准）送达。如提出异议，适用以下规则：\n\n(i) 送达方可随时向被命令人员发出通知后，向要求履行的地区所属法院提出动议，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管理人员的人员，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，要求履行的地区所属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；(ii) 要求人员在超出第 45(c) 条规定的地理范围外履行；\n\n(iii) 在不适用任何例外或豁免的情况下，要求披露享有特权或受其他保护的事项；或者\n\n(iv) 使人员承受不当负担。\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的人员，要求履行的地区所属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；或者\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，且源自该专家未受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：\n\n(i) 证明对该证言或材料具有重大需要，且如不承受不当困难即无法通过其他方式满足该需要；以及\n\n(ii) 确保受传票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的人员，必须按该等文件在通常业务过程中保存的方式提交，或者必须将其整理和标记，以对应请求中所列类别。\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，回应人员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。回应人员无须以一种以上形式提交同一电子存储信息。\n\n（D）无法合理访问的电子存储信息。答复人无需提供其认定为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的证据开示。在提出强制证据开示动议或保护令动议时，答复人必须证明该信息因不当负担或费用而无法合理访问。如果作出该证明，法院仍可在请求方证明存在正当理由的情况下，命令对该等来源进行证据开示，同时考虑第26(b)(2)(C)条的限制。法院可对证据开示规定条件。\n(2) 主张特权或保护。\n\n(A) 被扣留的信息。根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被传唤信息的人，必须：\n\n(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) 已提供的信息。如为答复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，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。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义务地区的法院，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附件 C-14\nB2540（表格2540——第2004条审查传票）(12/15) 美国破产法院 Case 22-50073 Doc 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 279 of 491\n\n__________________________________________________________________________ Connecticut（康涅狄格州）地区\n\n关于 ______________________________________________________________________\n\n案号：________________________________ Ho Wan Kwok（郭文贵）22-50073\n\n债务人\n\n章：__________________ 11\n第2004条审查传票\n\n致：________________________________________________________________________________________________________________ Williams & Connolly LLP（威廉斯与康诺利律师事务所）\n\n地点 Paul Has（保罗·哈斯）\n\n（传票所指向人员的姓名）\n\n证言：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条接受审查并作证。随附授权该审查的法院命令副本。\n\n日期和时间\n\n审查将通过以下方式记录：________________________________________________________________________________ 法庭记录员/速记员\n\n文件提供：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、测试或抽样：\n见随附于此的文件提供请求。\n\n下列 Fed. R. Civ. P. 45 规定已附上；该规则经 Fed. R. Bankr. P. 9016 规定适用于破产案件——第45(c)条，关于履行地点；第45(d)条，关于你作为传票对象所受的保护；以及第45(e)条和第45(g)条，关于你答复本传票的义务以及不答复的潜在后果。\n\n日期：Sept____________ ember __, 2022\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 Patrick R. Linsey（帕特里克·R·林赛）(ct29437)\n\n代表（当事人姓名）____________________________并签发或请求本传票的律师的姓名、地址、电子邮件地址和电话号码如下：Luc Despins（吕克·德斯潘），第11章受托人\n\nPatrick R. Linsey, Esq.; Neubert, Pepe & Monteith, P.C.; 195 Church Street, New Haven, Connecticut 06510 plinsey@npmlaw.com; 203-821-2000\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供文件、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，向每一当事人送达通知及本传票副本。Fed. R. Civ. P. 45(a)(4)。\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”，每一项称为“一项请求”）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，必须按如下规定详细说明你提出异议的理由。如异议仅涉及某项请求的一部分，或其中所含的某个词、短语或条款，你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/子关系。必须包括 OCRPATH 字段，以提供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。其应为以逗号分隔的文件，每行由七个字段组成，并且数据库中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\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）应列入 .DAT 文件。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，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。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。将原生文件归入名称递增的“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一电子文件，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 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。所需元数据如下：\nCase 22-50073 Doc 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 282 of 491\n\n字段名称 示例数据 说明\n\nFIRSTBATES EDC0000001 原生文件/电子邮件文件的第一个 Bates 编号\nLASTBATES EDC0000001 原生文件/电子邮件文件的最后一个 Bates 编号\nLASTBATES 字段应予填充\n用于单页\nATTACHRANGE EDC0000001\n- 父文件第一页的 Bates 编号至\nEDC0000015 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：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\n\nFROM John Smith 电子邮件：发件人\n原生文件：文件作者（们）\n\n分号应用于分隔\n多个条目\n收件人 Coffman, Janice；LeeW 收件人\n[mailto:LeeW@MSN.com] 分号应用于分隔多个\n条目\n抄送 Frank Thompson [mailto: 抄送收件人\nfrank_Thompson@cdt.com] 分号应用于分隔\n多个条目\n密送 John Cain 密送收件人\n分号应用于分隔\n多个条目\n主题 董事会会议纪要 电子邮件：电子邮件的主题行 原生文件：文档标题\n（如有）\n文件名 BoardMeetingMinutes.docx 原生文件：原始原生文件的名称，\n包括扩展名\n发送日期 10/12/2010 电子邮件：发送电子邮件的日期\n原生文件：（空）\n发送时间/ 07:05 PM GMT 电子邮件：发送电子邮件的时间/电子邮件被\n时区 标准化所在的时区\n时区 GMT 电子邮件在转换期间\n被\n标准化所在的\n时区。\n链接 >EDC0000001.msg 电子邮件或原生文件文档的超链接\n所链接的文件必须以\nFIRSTBATES 编号命名\n文件扩展名 MSG 代表电子邮件或\n原生文件的\n文件类型扩展名\n作者 John Smith 电子邮件：（空）\n原生文件：文档作者\n创建日期 10/10/2010 电子邮件：（空）\n原生文件：文档创建日期\n案件 22-50073 文书 839 提交日期 09/07/22 登记日期 09/07/22 20:02:47 第 283 页，共 491 页\n\n创建时间 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，\n不得\n与 DATE_CREATED 字段合并\n修改日期 10/12/2010 电子邮件：（空）\n原生文件：文档最后修改日期\n修改时间 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\n与 DATE_MOD 字段合并\n访问日期 10/12/2010 电子邮件：（空）\n原生文件：文档最后访问日期\n访问时间 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\n与 DATE_ACCESSD 字段合并\n文件大小 5,952 原生文件文档/电子邮件的大小，单位为 KB\n页数 1 原生文件文档/电子邮件的页数\n路径 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。\n内部文件路径 Personal Folders\\Deleted 电子邮件：包括\nItems\\Board Meeting 原始文件名的电子邮件原始位置。\nMinutes.msg 原生文件：（空）\n内部邮件 ID <000805c2c71b\\$75977050\\$ 电子邮件：唯一邮件\nID 原生文件：（空）\ncb8306d1@MSN>\nMD5 哈希值 d131dd02c5e6eec4693d9a0 文档的 MD5 哈希值。\n698aff95c\n2fcab58712467eab4004583e\nb8fb7f89\nOCR 路径 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，或应予以整理和标注，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；或 (b) 由代表您行事的任何人占有、保管或控制的，\n案件 22-50073 文书 839 提交日期 09/07/22 登记日期 09/07/22 20:02:47 第 284 页，共 491 页\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，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) 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，则应确定\n案件 22-50073 文书 839 提交日期 09/07/22 登记日期 09/07/22 20:02:47 第 285 页，共 491 页\n\n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) 您将据以支持该等特权主张的所有情形；以及 (b) 根据 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，应完整提供响应性文件。\n\n9. 如一份原本具有响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盖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) 在获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) 提供根据下列规定所要求提供的任何额外文件\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. 对实体的一切提及包括其所有关联方。\n\n13. 对个人姓名的一切提及包括所有别名、化名或昵称。\n案件 22-50073 文书 839 提交日期 09/07/22 登记日期 09/07/22 20:02:47 第 286 页，共 491 页\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下的使用。\n\n16. (a) “and”和“or”应视需要解释为连词或析取词，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”。\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，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如下含义：\n\n1. “您”或“您的”或“您本人”系指并指称 Williams & Connolly LLP（威廉斯与康诺利律师事务所），以及其任何雇员、代理人、律师、顾问或代表其行事的任何人。\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、顾问或代表其行事的任何人。\n案件 22-50073 文书 839 提交日期 09/07/22 登记日期 09/07/22 20:02:47 第 287 页，共 491 页\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、顾问或代表其行事的任何人。\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、顾问或代表其行事的任何人。\n\n5. “债务人所谓的妻子”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、顾问或代表其行事的任何人。\n\n6. “债务人的家庭成员”统称债务人、债务人之子、债务人之女及债务人所谓的妻子，以及与债务人具有任何其他亲属关系的人。\n\n7. “关联个人”单独及共同系指以下所有个人：(1) 持有、控制、保管或对债务人或债务人家庭成员所有、控制或享有的资产具有酌处权者；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者，以及上述各方各自的雇员、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：Daniel Podhaskie（丹尼尔·波德哈斯基）、Jason Miller（杰森·米勒）、Steve Bannon（史蒂夫·班农）、Karin Maistrello（卡琳·迈斯特雷洛）、Melissa Francis（梅利莎·弗朗西斯）、William Gertz（威廉·格茨）、Arethusa Forsyth（阿瑞苏莎·福赛思）、Glenn Mellor（格伦·梅勒）、Jennifer Mercurio（詹妮弗·梅尔库里奥）、Eduardo Eurnekian（爱德华多·欧内基安）、Han Chunguang（韩春光，亦称 韩春光）、Qu Guojiao（屈国姣，亦称 Qu Guo Jiao、屈国姣）、Guo Lijie（郭丽杰，亦称 郭丽杰）、Zhang Wei（张伟，亦称 张伟*）、Lihong Wei Lafrenz（魏丽红，亦称 Sara Wei、魏丽红）、Hao Haidong（郝海东，亦称 郝海东）、Ross Heinemeyer（罗斯·海内迈耶）、Max Krasner（马克斯·克拉斯纳）、Kyle Bass（凯尔·巴斯）、Melissa Mendez（梅利莎·门德斯）、Ya Li（李娅，亦称 李娅）、Dinggang Wang（王定刚，亦称 王定刚）、An Hong（安红，亦称 安红）、Yvette Wang（王雁平，亦称 Yanping\n案件 22-50073 文书 839 提交日期 09/07/22 登记日期 09/07/22 20:02:47 第 288 页，共 491 页\n\nWang、Yan Ping Wang、王雁平）、Fiona Yu（菲奥娜·余）、Je Kin Ming（余建明，亦称 William Je、Yu Jianming、余建明\n\n）、Yaz Qingua（亚兹·青瓜）以及 Lao Jiang（姜云浮，亦称 Jiang Yunfu、Jiang Yunfu Be、姜云浮）。\n\n8. “关联实体”系指，单独或共同地，任何类型的所有组织或实体，该等组织或实体：(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，以及前述任何组织或实体各自的雇员、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：7 Nod Hill LLC（诺德山7号有限责任公司）、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（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（阿尔法环球风险投资有限公司）、Alfonso Global Limited（阿方索环球有限公司）、Allied Capital Global Limited（联合资本环球有限公司）、Alpine Fiduciaries SA（阿尔卑斯受托人股份公司）、Anton Development Limited（安东发展有限公司）、Assets Sino Limited（中资资产有限公司）、Auspicious Coast Limited（吉祥海岸有限公司）、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（北京鼎峰控股有限公司）、Bravo Luck Limited（鸿运有限公司）、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（克兰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（曙光州有限公司）、Eastern Profit Corporation Limited（东方利润有限公司）、Elite Well Global Limited（精英环球有限公司）、Empire Growth Holdings（帝国成长控股）、G Club Operations LLC（G俱乐部运营有限责任公司）、G Fashion LLC（G时尚有限责任公司）、G News LLC（G新闻有限责任公司）、GETTR USA（GETTR美国）、Genever Holdings Corporation（吉尼弗控股公司）、Genever Holdings LLC（吉尼弗控股有限责任公司）、GFASHION MEDIA GROUP INC.（GFASHION媒体集团公司）、GFNY, Inc.（GFNY公司）、Globalist International Limited（环球主义者国际有限公司）、GNews Media Group Inc.（GNews媒体集团公司）、Golden Spring (New York) Ltd.（金泉（纽约）有限公司）、Greenwich Land LLC（格林尼治土地有限责任公司）、Guo Media（郭媒体）、GTV Media Group, Inc.（GTV媒体集团公司）、Hamilton Capital Holdings Inc.（汉密尔顿资本控股公司）、Head Win Group Limited（领先集团有限公司）、Henan Yuda（河南裕达）、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 Supervisory Organization（喜马拉雅监督组织）、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）、Infinite Increase Limited（无限增长有限公司）、Infinitum Developments Limited（无限发展有限公司）、Insight Phoenix Fund（洞察凤凰基金）、Lamp Capital LLC（兰普资本有限责任公司）、Leading Shine Limited（领先光辉有限公司）、Leading Shine NY Limited（领先光辉纽约有限公司）、Long Gate Limited（长门有限公司）、Next Tycoon Investments Limited（下一大亨投资有限公司）、New Federal State of China（中国新联邦国，亦称NFSC）、Noble Fame Global Limited（高尚名声环球有限公司）、Rosy Acme Ventures Limited（玫瑰顶点风险投资有限公司）、Rule of Law Foundation III, Inc.（法治基金会III公司）、Rule of Law Foundation IV, Inc.（法治基金会IV公司）、Rule of Law Fund（法治基金）、Rule of Law Society（法治协会）、Rule of Law Society IV, Inc.（法治协会IV公司）、G-Translators PTY LTD（G-翻译员有限公司）、Saraca Media Group, Inc.（萨拉卡媒体集团公司）、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）、Spirit Charter Investment Limited（精神宪章投资有限公司）、Stevenson, Wong & Co.（史蒂文森、黄氏律师事务所）、Voice of Guo Media, Inc.（郭媒体之声公司）、Well Origin Ltd.（良好起源有限公司）、World Century Limited（世界世纪有限公司）、Worldwide Opportunity Holdings Limited（环球机会控股有限公司）、Whitecroft Shore Limited（怀特克罗夫特海岸有限公司）及ZIBA Limited（ZIBA有限公司）。\n\nCase 22-50073 Doc 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 289 of 491\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”系指“每一个及全部”。\n\n12. “每一”及“每个”系指“每一个及全部”。\n\n13. “第三方”系指除您以外的个人或实体。\n\n14. “转让”应具有《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，并包括但不限于任何种类、类型、性质或描述的每一份书面、记录或图形材料，无论该等材料目前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、\n\nCase 22-50073 Doc 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 290 of 491\n\n图表、蓝图、图纸、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、语音信息、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、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、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文件的草稿或副本，如其中含有原始文件中未见的任何种类笔记、评论或标记，或以其他方式与原始文件不完全相同。\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”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”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，包括但不限于律师、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、结合考虑、与之有关、证明、表明、报告、记录、暗示、回应、\n\nCase 22-50073 Doc 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 291 of 491\n\n连接、评论、就其而言、关于、与之有关、讨论、显示、描述、反映、分析、构成及为。\n\n19. 就任何特定主题事项而言，“与之相关”“相关”或“有关”系指但不限于任何构成、包含、涉及、载有、体现、反映、识别、陈述、直接或间接提及，或以任何方式与所确定的特定主题事项相关的文件。\n\n20. “通信”系指在最广泛可能意义上且不限于此，任何信息或知识的传递（以事实、想法、询问或其他形式）。通信进一步系指所有谈话、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信函、电子邮件、录音、传送单、备忘录、电话通信、语音信息、电报、电话传真、传真副本、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、电话笔记，或在内部或与第三方之间传送的笔记。\n\n21. “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、共有公寓、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. 与债务人、债务人财产、债务人家庭或关联实体的任何收入或资产有关的所有文件。\n\nCase 22-50073 Doc 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 292 of 491\n\n2. 与您同债务人、债务人家庭的任何成员和/或任何关联实体签订的任何委托函有关的所有文件，包括该等委托函的副本。\n\n3. 与基于您对债务人、债务人家庭或关联实体的代理而向您支付任何预付费用有关的所有文件，包括足以识别该预付费用的金额及其来源的文件。\n\n4. 与由债务人、债务人家庭、家庭关联实体或关联实体向您或代表其向您支付的、存放于托管账户或客户信托账户中的任何费用、付款或款项有关的所有文件。\n\n5. 足以显示债务人、债务人家庭或关联实体向您支付或为其利益向您支付的任何款项的金额、日期及来源的文件。\n\n6. 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旨在避免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可能的破产或类似无力偿债程序有关的所有文件。\n\n7. 与关联实体有关的所有文件，包括但不限于与其公司结构、资产、设立信息、高级职员及董事、经营目的，以及其与债务人、债务人家庭任何成员或任何关联个人之间关系有关的文件。\n\n8. 关于债务人或债务人家庭一方与关联实体另一方所作出的、与其进行的或代表其进行的任何投资或商业交易的所有文件。\n\nCase 22-50073 Doc 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 293 of 491\n\n9. 与债务人、债务人财产、债务人家庭或关联实体持有任何权益或投资的任何实体有关的所有文件，包括但不限于该权益或投资的性质及价值；债务人、债务人财产、债务人家庭或关联实体因该等权益或投资从该实体获得的任何收益或利益；以及与该实体有关的任何财务报告或数据的所有文件，包括但不限于所有账簿和记录、财务报表或税务文件。\n\n10. 关于Lady May（梅夫人号）；Sherry Netherland Hotel / Condominium（雪莉荷兰酒店／共管公寓）；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；以及债务人或债务人财产在任何关联实体中拥有的任何财务权益的所有文件。\n\n11. 与据称由债务人作为受托人、Genever Holdings Corporation（吉尼弗控股公司）及Genever Holdings LLC（吉尼弗控股有限责任公司）于February 17, 2015订立、以Bravo Luck Limited（鸿运有限公司）为受益人的《信托声明及协议》有关的所有文件。\n\n12. 与债务人拥有、控制或使用的任何飞机有关的所有文件，包括但不限于尾号为T7-GQM的飞机及在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机上人员的飞行清单。\n\n13. 与债务人、债务人家庭或关联实体于July 2020前后或任何其他时间就原油期货或任何类似商品进行的任何投资或交易有关的所有文件，包括但不限于与Jiang Yunfu Be（姜云福）就该等任何投资或交易进行的通信。\n\nCase 22-50073 Doc 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 294 of 491\n\n14. 您与债务人、债务人家庭或任何关联个人、代理人、雇员或代表债务人行事的其他个人之间，就与债务人、债务人财产、债务人家庭或关联实体有关的任何转让、投资或其他交易或商业往来所进行的所有通信。\n\n15. 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，包括但不限于显示该等信托设立时间、设立人、为谁的利益而设立以及该文书信托财产的文件。\n\n16. 与涉及债务人、债务人家庭成员或任何关联实体的任何出售、收购、处置、购买、投资、出资、赠与、信贷展期、贷款或转让有关的所有文件。\n\n17. 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关、法院、合议庭或替代性争议解决实体。\n\n18. 与向债务人、债务人财产、债务人家庭成员或任何关联实体提供或由其提供的任何贷款或信贷展期，或就此提出的申请有关的所有文件，包括但不限于：(i) 任何该等贷款或信贷展期的条款，包括其偿还条款、陈述与保证以及利率；及(ii) 贷款付款的所有证据。\n\n案件 22-50073 文件 839 提交日期 09/07/22 录入日期 09/07/22 20:02:47 第 295 页，共 491 页\n\n19. 与债务人使用属于、由债务人家庭成员、关联实体或关联个人控制，或其全部或部分所有权由债务人家庭成员、关联实体或关联个人持有的任何资产有关的所有文件。\n\n20. 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、账户结单、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一方进行的所有转让的所有文件。\n\n21. 与将任何关联实体（包括 Bravo Luck Limited（布拉沃·拉克有限公司））的资产质押给任何其他实体有关的所有文件。\n\n案件 22-50073 文件 839 提交日期 09/07/22 录入日期 09/07/22 20:02:47 第 296 页，共\n\nB2540（表格 2540——Rule 2004 审查传票）（第 2 页） 491\n\n本人于（日期）__________收到向以下人员（个人姓名及职务，如有）送达的本传票：____________________________________________________________\n\n本人通过向被指名人员交付副本的方式送达本传票，具体如下：____________________________________\n\n__________________________________，于（日期）___________________；或\n\n本人未执行传票即予退回，原因为：____________________________________________________________\n\n除非该传票是代表美国或其官员或代理人签发，本人亦已向证人支付其一天出席的费用及法律允许的里程费，金额为 \\$ _______________________。\n\n本人的费用为差旅 \\$_________，服务 \\$_________，合计 \\$_________。\n\n本人在伪证处罚下声明\n\n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》45(c)、(d)、(e)和(g)（2013年12月1日生效）（依《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) 在该人居住、受雇或经常亲自从事营业之地点 100 英里范围内；或\n\n(B) 在该人居住、受雇或经常亲自从事营业所在州内，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、受雇或经常亲自从事营业之地点 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，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) 无须出庭。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，或准许检查之人，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。异议必须在指定履行时间或传票送达后 14 天中较早者之前送达。如提出异议，则适用下列规则：\n\n(i) 送达方可以随时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) 仅可依照命令的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；(ii) 要求某人在超出 Rule 45(c) 规定的地域限制范围外履行；(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，而该等意见或信息未描述争议中的具体事件，且源于该专家未经任何当事人请求所进行的研究。\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，如送达方：\n\n(i) 证明其对该证言或材料具有实质性需要，且不造成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。回应要求提交文件之传票的人，必须按其在正常营业过程中保存的方式提交文件，或必须将文件整理并标注，使其与请求中的类别相对应。\n\n(B) 未指定电子存储信息的提交形式。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。回应人无须从其认定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。对于强制证据开示的动议或保护令动议，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。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之人，必须：\n\n(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，描述被扣留文件、通信或有形物品的性质，以使各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在该主张解决前保全该信息。\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相关命令之人藐视法庭。\n\n如需查阅传票材料，请参见 Fed. R. Civ. P. 45(a) Committee Note (2013)\n\n……\n\n附件 C-15\n\nB2540（表格 2540——Rule 2004 审查传票）（12/15） 美国破产法院 案件 22-50073 文件 839 提交日期 09/07/22 录入日期 09/07/22 20:02:47 第 299 页，共 491 页\n\n＿＿＿＿＿＿＿＿＿＿＿＿＿＿＿＿＿＿＿＿＿＿＿＿＿＿＿＿＿＿＿＿＿＿＿＿＿＿＿＿＿地区，Connecticut（康涅狄格州）\n\n关于＿＿＿＿＿＿＿＿＿＿＿＿＿＿＿＿＿＿＿＿＿＿＿＿＿＿＿＿＿＿＿＿＿＿＿＿＿＿＿＿＿\n\n案件编号 ＿＿＿＿＿＿＿＿＿＿＿＿＿＿ Ho Wan Kwok（郭文贵）22-50073\n\n债务人\n\nChapter ＿＿＿＿＿＿＿＿＿＿ 11\n\nRule 2004 审查传票\n\n致：Troutman Pepper Hamilton Sanders LLP（特劳特曼·佩珀·汉密尔顿·桑德斯律师事务所）\n\n（传票所指向人员的姓名）\n\n证言：兹命令你于下列载明的时间、日期和地点出席，依《联邦破产程序规则》Rule 2004 接受审查并作证。随附授权该项审查的法院命令副本。\n\n地点 日期和时间\n\nPaul Hastings LLP（保罗·黑斯廷斯律师事务所）\n200 Park Avenue\nNew York, New York 10166\n\n本次询问将采用以下方式记录：________________________________________________________________________________ 法院书记员/速记员\n\n提交材料：您或您的代表还必须在接受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，现随附如下——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，关于您回应本传票的义务以及未回应可能产生的后果。\n\n日期：September __, 2022\n\n法院书记员\n\n或\n\n_________________________ 法院书记员或副书记员签名 _________________________ 律师签名 Patrick R. Linsey（帕特里克·R·林赛）(ct29437)\n\n代表（当事人姓名）_________________________并签发或请求本传票的律师的姓名、地址、电子邮件地址和电话号码如下：Luc Despins（吕克·德斯潘），第11章受托人\n\nPatrick R. Linsey（帕特里克·R·林赛）, Esq.; Neubert, Pepe & Monteith, P.C.（纽伯特、佩佩与蒙泰思专业公司）; 195 Church Street, New Haven, Connecticut 06510 plinsey@npmlaw.com; 203-821-2000\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，则必须在向本传票所指向之人送达前，向每一当事人送达通知及本传票副本。Fed. R. Civ. P. 45(a)(4)。\n文件提交请求\n一、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。除非您基于诚信提出异议，否则必须对每项请求作出完整答复；如提出异议，必须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，或其中包含的某个词、短语或条款，您仅须说明对该部分的异议，并对请求的其余部分作出答复。\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电子表格应有一张以该文件Bates编号命名的占位图像。\n\nb. 图像加载文件\na. Concordance®（康科丹斯）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®（康科丹斯图像）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,PageCount。\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，每个文件夹内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\nd. 某些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，以表明原生文件的存在，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。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一电子文件，仅提交一份。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\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日期字段应以如下格式提供：mm/dd/yyyy。日期和时间字段必须为两个单独字段。所需元数据如下：\nCase 22-50073 Doc 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 302 of 491\n\n字段名称 示例数据 说明\n\nFIRSTBATES EDC0000001 原生文件/电子邮件文件的第一个Bates编号\nLASTBATES EDC0000001 原生文件/电子邮件文件的最后一个Bates编号\nLASTBATES字段应就单页文件填写\nATTACHRANGE EDC0000001\n- 父文件第一页的Bates编号至最后一份附件“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：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\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/电子邮件被标准化的时区\nTIME_ZONE GMT 在转换期间电子邮件被标准化的时区。\nLINK >EDC0000001.msg 电子邮件或原生文件的超链接\n所链接的文件必须按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 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 303 of 491\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，且不得与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，且不得与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，且不得与DATE_ACCESSD字段合并\nFILE_SIZE 5,952 原生文件/电子邮件文件的大小，单位为KB\nPGCOUNT 1 原生文件/电子邮件文件的页数\nPATH 电子邮件：（空）\nAgenda.doc 原生文件：原生文件存储的路径，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：唯一消息\nID 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. 所有文件均应按日常业务过程中保存的方式提交，或者应进行组织和标注，以对应本请求中的类别。\n\n5. 本文所载每项请求均延及以下所有文件：(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 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 304 of 491\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交。\n\n6. 如要求您提交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) 详细描述该文件的性质及其内容；(b) 确认编制或撰写该文件之人（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) 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与之有关的事实和情况；(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) 确认当前占有、保管或控制该文件的人员（如有）。\n\n7. 如要求您提交一份已被销毁的文件，则除前一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，则说明该等人员身份，以及说明该等信息如何为其所占有，(viii) 据以拒绝提交该文件的特权主张，以及 (ix) 您将据以支持该特权主张的全部情形；以及 (b) 就依据符合 D. Conn. L. Civ. R. 26(e) 的特权主张而拒绝提交的每一文件，制作一份包含本项指示第 (a) 部分所要求全部信息的特权日志。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 839 提交日期 09/07/22 录入日期 09/07/22 20:02:47 第 305 页，共 491 页\n\n该等人员，以及说明该等信息如何为其所占有，(viii) 据以拒绝提交该文件的特权主张，以及 (ix) 您将据以支持该特权主张的全部情形；以及 (b) 就依据符合 D. Conn. L. Civ. R. 26(e) 的特权主张而拒绝提交的每一文件，制作一份包含本项指示第 (a) 部分所要求全部信息的特权日志。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. 如一份本应提交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特权主张约束的该部分，其余部分应予提交。\n\n10. 该等请求具有持续性。特此指示您：(a) 在得知先前答复不完整或不正确后，立即补充或更正任何其后得知不完整或不正确的答复；以及 (b) 提交根据下述所要求的任何补充文件\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. 对实体的一切提述均包括其所有关联方。\n\n13. 对个人姓名的一切提述均包括所有别名、化名或昵称。\n\n案件 22-50073 文件 839 提交日期 09/07/22 录入日期 09/07/22 20:02:47 第 306 页，共 491 页\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；且 (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) “和”及“或”应根据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该请求范围；且 (b) “每一”及“任何”应视为包括并涵盖“每个”及“所有”一词。\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. “您”或“您的”或“您本人”是指 Troutman Pepper Hamilton Sanders LLP（特劳特曼·佩珀·汉密尔顿·桑德斯律师事务所），连同其任何雇员、代理人、律师、顾问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），连同其雇员、代理人、律师、顾问或代表其行事的任何人。\n\n案件 22-50073 文件 839 提交日期 09/07/22 录入日期 09/07/22 20:02:47 第 307 页，共 491 页\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），连同其雇员、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），连同其雇员、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”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），连同其雇员、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、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. “关联个人”单独及共同指：(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，或以其他方式与其关联的所有个人，连同前述任何人员各自的雇员、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：Daniel Podhaskie（丹尼尔·波达斯基）、Jason Miller（杰森·米勒）、Steve Bannon（史蒂夫·班农）、Karin Maistrello（卡琳·迈斯特雷洛）、Melissa Francis（梅利莎·弗朗西斯）、William Gertz（威廉·格茨）、Arethusa Forsyth（阿瑞苏萨·福赛思）、Glenn Mellor（格伦·梅勒）、Jennifer Mercurio（詹妮弗·默库里奥）、Eduardo Eurnekian（爱德华多·厄内基安）、Han Chunguang（韩春光）（亦称 韩春光）、Qu Guojiao（屈国姣）（亦称 Qu Guo Jiao、屈国姣）、Guo Lijie（郭丽杰）（亦称 郭丽杰）、Zhang Wei（张伟）（亦称 张伟*）、Lihong Wei Lafrenz（魏丽红）（亦称 Sara Wei、魏丽红）、Hao Haidong（郝海东）（亦称 郝海东）、Ross Heinemeyer（罗斯·海内迈耶）、Max Krasner（马克斯·克拉斯纳）、Kyle Bass（凯尔·巴斯）、Melissa Mendez（梅利莎·门德斯）、Ya Li（李娅）（亦称 李娅）、Dinggang Wang（王定刚）（亦称 王定刚）、An Hong（安红）（亦称 安红）、Yvette Wang（王雁平）（亦称 Yanping\n\n案件 22-50073 文件 839 提交日期 09/07/22 录入日期 09/07/22 20:02:47 第 308 页，共 491 页\n\nWang、Yan Ping Wang、王雁平）、Fiona Yu（菲奥娜·余）、Je Kin Ming（余建明）（亦称 William Je、Yu Jianming、余建明）、Yaz Qingua（亚兹·青瓜）及 Lao Jiang（姜云浮）（亦称 Jiang Yunfu、Jiang Yunfu Be、姜云浮）。\n\n8. “关联实体”单独及共同指：(1) 曾由债务人或债务人家属拥有、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属拥有、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，连同前述任何实体各自的雇员、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：7 Nod Hill LLC（七诺德山有限责任公司）、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（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（阿尔法全球风险投资有限公司）、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（阿尔卑斯受托人股份公司）、Anton Development Limited（安东开发有限公司）、Assets Sino Limited（中资资产有限公司）、Auspicious Coast Limited（吉祥海岸有限公司）、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）、Bravo Luck Limited（布拉沃幸运有限公司）、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（克兰咨询集团有限责任公司）、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）、Elite Well Global Limited（精英环球有限公司）、Empire Growth Holdings（帝国增长控股）、G Club Operations LLC（G俱乐部运营有限责任公司）、G Fashion LLC（G时尚有限责任公司）、G News LLC（G新闻有限责任公司）、GETTR USA（GETTR美国）、Genever Holdings Corporation（吉尼弗控股公司）、Genever Holdings LLC（吉尼弗控股有限责任公司）、GFASHION MEDIA GROUP INC.（GFASHION媒体集团公司）、GFNY, Inc.（GFNY公司）、Globalist International Limited（环球主义者国际有限公司）、GNews Media Group Inc.（GNews媒体集团公司）、Golden Spring (New York) Ltd.（金泉〈纽约〉有限公司）、Greenwich Land LLC（格林尼治土地有限责任公司）、Guo Media（郭媒体）、GTV Media Group, Inc.（GTV媒体集团公司）、Hamilton Capital Holdings Inc.（汉密尔顿资本控股公司）、Head Win Group Limited（首胜集团有限公司）、Henan Yuda（河南裕达）、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 Supervisory Organization（喜马拉雅监督组织）、HK International Funds Investments (USA)\n\n案件 22-50073 文件 839 提交日期 09/07/22 录入日期 09/07/22 20:02:47 第 309 页，共 491 页\n\nLimited 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）、Infinite Increase Limited（无限增长有限公司）、Infinitum Developments Limited（无尽发展有限公司）、Insight Phoenix Fund（洞察凤凰基金）、Lamp Capital LLC（蓝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）、Long Gate Limited（长门有限公司）、Next Tycoon Investments Limited（下一大亨投资有限公司）、New Federal State of China（中国新联邦国）（亦称 NFSC）、Noble Fame Global Limited（环球名望有限公司）、Rosy Acme Ventures Limited（玫瑰顶点创投有限公司）、Rule of Law Foundation III, Inc.（法治基金会III公司）、Rule of Law Foundation IV, Inc.（法治基金会IV公司）、Rule of Law Fund（法治基金）、Rule of Law Society（法治协会）、Rule of Law Society IV, Inc.（法治协会IV公司）、G-Translators PTY LTD（G-翻译员私人有限公司）、Saraca Media Group, Inc.（萨拉卡媒体集团公司）、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）、Spirit Charter Investment Limited（精神宪章投资有限公司）、Stevenson, Wong & Co.（史蒂文森、黄律师事务所）、Voice of Guo Media, Inc.（郭媒体之声公司）、Well Origin Ltd.（良好起源有限公司）、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）、Whitecroft Shore Limited（怀特克罗夫特海岸有限公司）及 ZIBA Limited（ZIBA有限公司）。\n\n9. “包括”或其任何变体意为“包括但不限于”。\n\n10. “和”及“或”意为“和/或”，并应为最大限度扩大其范围而解释为连词及析取词。\n\n11. “任何”、“所有”及“每一”均意为“每一个及所有”。\n\n12. “每一”及“每个”均意为“每一个及所有”。\n\n13. “第三方”是指您本人以外的人员或实体。\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”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您占有、保管或控制的任何种类、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 839 提交日期 09/07/22 录入日期 09/07/22 20:02:47 第 310 页，共 491 页\n\n图表、蓝图、图纸、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、小册子、传单、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文件的草稿或副本，其中载有原始文件中不存在的任何种类笔记、评论或标记，或以其他方式与原始文件不相同。\n\n16. “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\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，包括但不限于律师、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、相关、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、答复、\n\n案件 22-50073 文件 839 提交日期 09/07/22 录入日期 09/07/22 20:02:47 第 311 页，共 491 页\n\n与……相联系、就……发表评论、涉及……、关于……、与……相关、讨论……、展示……、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”是指，包括但不限于，构成、包括、涉及、含有、体现、反映、识别、陈述、直接或间接提及该特定主题，或以任何方式与所识别的特定主题相关的任何文件。\n\n20. “Communication(s)”在最广泛的含义上且不限于此，是指任何信息或知识的传递（以事实、想法、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、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、发布至留言板或群聊的信息、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\n21. “Asset(s)”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. 与债务人、债务人财产、债务人家庭成员或关联实体的任何收入或资产有关的所有文件。\n\n案件 22-50073 文书 839 提交 09/07/22 录入 09/07/22 20:02:47 第 312 页，共 491 页\n\n2. 与您同债务人、债务人家庭成员的任何成员和/或任何关联实体签订的任何委托函有关的所有文件，包括该等委托函的副本。\n\n3. 与基于您对债务人、债务人家庭成员或关联实体的代理而向您支付任何预付聘用费有关的所有文件，包括足以识别该预付聘用费金额及其来源的文件。\n\n4. 与您从债务人、债务人家庭成员、家庭关联实体或关联实体处或代表其收取，并存放于托管账户或客户信托账户中的任何费用、付款或款项有关的所有文件。\n\n5. 足以显示由债务人、为债务人利益、由债务人家庭成员、为债务人家庭成员利益，或由关联实体、为关联实体利益向您支付的任何款项的金额、日期和来源的文件。\n\n6. 与债务人的财务状况及其对债权人的债务有关的所有文件，包括但不限于与任何逃避支付该等债务的行为有关的所有文件，以及与本案或任何其他实际或可能发生的破产或类似无力清偿程序有关的所有文件。\n\n7. 与关联实体有关的所有文件，包括但不限于与其公司结构、资产、设立信息、高级职员和董事、经营目的，以及其与债务人、债务人家庭成员的任何成员或任何关联个人之间关系有关的文件。\n\n8. 关于任何投资或商业交易的所有文件，该等投资或商业交易由、与或代表债务人或债务人家庭成员一方，以及关联实体另一方进行。\n\n案件 22-50073 文书 839 提交 09/07/22 录入 09/07/22 20:02:47 第 313 页，共 491 页\n\n9. 与债务人、债务人财产、债务人家庭成员或关联实体持有任何权益或投资的任何实体有关的所有文件，包括但不限于该等权益或投资的性质和价值；债务人、债务人财产、债务人家庭成员或关联实体因该等权益或投资而从该实体获得的任何收益或利益；以及与该实体有关的任何财务报告或数据有关的所有文件，包括但不限于所有账簿和记录、财务报表或税务文件。\n\n10. 关于Lady May（“梅女士”号）；Sherry Netherland Hotel / Condominium（谢里·内瑟兰酒店/公寓）；位于康涅狄格州格林尼治市 373 Taconic Rd.的住宅房产；位于康涅狄格州格林尼治市 33 Ferncliff Rd.的住宅房产；位于康涅狄格州威尔顿市 354 Nod Hill Rd.的住宅房产；以及债务人或债务人财产在任何关联实体中拥有的任何财务权益的所有文件。\n\n11. 与债务人作为受托人、Genever Holdings Corporation（Genever Holdings公司）及Genever Holdings LLC（Genever Holdings有限责任公司）于 February 17, 2015 签订、以Bravo Luck Limited（好运有限公司）为受益人的所谓《信托声明及协议》有关的所有文件。\n\n12. 与债务人拥有、控制或使用的任何航空器有关的所有文件，包括但不限于尾号为 T7-GQM 的航空器，以及在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乘机人员的飞行清单。\n\n13. 与债务人、债务人家庭成员或关联实体于 July 2020 前后或任何其他时间进行的原油期货或任何类似商品的任何投资或交易有关的所有文件，包括但不限于与Jiang Yunfu Be（蒋云富·贝）就任何该等投资或交易进行的通信。\n\n案件 22-50073 文书 839 提交 09/07/22 录入 09/07/22 20:02:47 第 314 页，共 491 页\n\n14. 您与下列任一方之间就与债务人、债务人财产、债务人家庭成员或关联实体有关的任何转让、投资或其他交易或商业往来所进行的所有通信：债务人、债务人家庭成员，或代表债务人行事的任何关联个人、代理人、雇员或其他个人。\n\n15. 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所有文件，包括但不限于显示该等信托何时设立、由谁设立、为谁的利益设立以及该文书的信托财产的文件。\n\n16. 与涉及债务人、债务人家庭成员或任何关联实体的任何出售、取得、处分、购买、投资、出资、赠与、授信、贷款或转让有关的所有文件。\n\n17. 与涉及债务人的任何法律争议有关的任何义务、索赔、责任或债务有关的所有文件，包括但不限于与任何地方、州、联邦或国际机构之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\n18. 与向债务人、债务人财产、债务人家庭成员或任何关联实体提供或由其提供的任何贷款或授信，或就该等贷款或授信提出的申请有关的所有文件，包括但不限于：(i) 任何该等贷款或授信的条款，包括其还款条款、陈述与保证以及利率；及(ii) 贷款付款的所有证据。\n\n案件 22-50073 文书 839 提交 09/07/22 录入 09/07/22 20:02:47 第 315 页，共 491 页\n\n19. 与债务人使用任何属于、由其控制，或其全部或部分所有权由债务人家庭成员、关联实体或关联个人持有的资产有关的所有文件。\n\n20. 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、账目明细、电汇指示和/或确认书、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进行的所有转让的所有文件。\n\n21. 与将任何关联实体的资产（包括Bravo Luck Limited（好运有限公司）的资产）质押给任何其他实体有关的所有文件。\n\n案件 22-50073 文书 839 提交 09/07/22 录入 09/07/22 20:02:47 第 316 页，共 491 页\n\nB2540（表格 2540——Rule 2004 审查传票）（第 2 页）\n\n本人于（日期）收到本传票，收件人（个人姓名及职务，如有）：______________________________________________\n\n本人于（日期）___________________通过向被指定人员交付副本的方式送达本传票；或按如下方式送达：____________________________________\n\n本人未执行而退回本传票，原因如下：____________________________________________________________\n\n除非本传票是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本人的费用为 \\$ _________ 用于差旅，及 \\$_________ 用于服务，合计 \\$_________。\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送达人的签名\n\n正楷姓名及职务\n\n送达人的地址\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), and (g)（Effective 12/1/13）（根据Federal Rules of Bankruptcy Procedure Rule 9016适用于破产案件）\n\n(c) 履行地点。\n\n(1) 对审判、听证或证言录取。传票只能在下列情况下命令某人出席审判、听证或证言录取：\n\n(A) 在该人居住、受雇或亲自经常从事商业活动地点的 100 英里范围内；或\n\n(B) 在该人居住、受雇或亲自经常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) 对其他证据开示。传票可以命令：\n\n(A) 在该人居住、受雇或亲自经常从事商业活动地点的 100 英里范围内的某一地点提供文件、电子存储信息或物品；及\n\n(B) 在待检查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。履行义务所要求地区的法院必须执行该项义务，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) 要求提供材料或允许检查之命令。\n\n(A) 无须出席。被命令提供文件、电子存储信息或有形物品，或允许检查场所的人，无须亲自出席提供或检查地点，除非其同时被命令出席证言录取、听证或审判。\n\n(B) 异议。被命令提供文件或有形物品，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供电子存储信息。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，则适用下列规则：\n\n(i) 送达方可随时在通知被命令人的情况下，向履行义务所要求地区的法院提出动议，请求作出强制提供或检查的命令。\n\n(ii) 此等行为仅可依命令所指示的方式要求实施，且该命令必须保护既非当事人亦非当事人高级职员之人，使其免于因遵从而产生重大费用。\n\n(3) 撤销或修改传票。\n\n(A) 必须撤销或修改的情形。经及时提出动议，要求遵从的地区法院必须撤销或修改具有下列情形的传票：\n\n(i) 未给予合理的遵从时间；(ii) 要求某人在超出规则45(c)规定的地理范围之外遵从；\n\n(iii) 在不存在任何适用的例外或放弃情形时，要求披露享有特权或受其他保护的事项；或\n\n(iv) 使某人承受不当负担。\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，要求遵从的地区法院可经动议，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) 披露未经聘用的专家之意见或信息，而该等意见或信息并非描述争议中的具体事件，且系该专家未应任何当事人请求所进行研究的结果。\n\n(C) 以规定条件作为替代方案。在规则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实质性需要，且如无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，而命令其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。对要求提交文件的传票作出回应之人，必须按照其在日常业务过程中保存的方式提交文件，或必须对文件进行整理和标注，使其与请求中所列类别相对应。\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。作出回应之人无需以一种以上的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。作出回应之人无需就其认定因不当负担或费用而无法合理获取之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，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。如作出该等证明，法院在考虑规则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扣留被传唤信息之人，必须：\n\n(i) 明确提出该主张；并且\n\n(ii) 以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到保护的主张，提出该主张之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；在该主张获得解决之前，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，必须采取合理步骤取回该信息；并可立即将该信息密封提交给要求遵从的地区法院，以裁定该主张。提交该信息之人必须保存该信息，直至该主张获得解决。\n\n(g) 藐视法庭。要求遵从的地区法院——以及在动议被移送后，签发传票的法院——可对已被送达但无正当理由不遵从传票或与之相关命令之人，以藐视法庭论处。\n\n如需查阅传票材料，见《联邦民事诉讼规则》45(a)委员会说明（2013年）\n\n……\n\n附件C-16\nB2540（表格2540——规则2004审查传票）（12/15）美国破产法院 案号22-50073 文件839 提交于09/07/22 录入于09/07/22 20:02:47 第319页，共491页\n\n____________________________________________________________ 地区：____________________________________________________________ Connecticut（康涅狄格州）\n\n关于 ____________________________________________________________\n\n案号：____________________________ Ho Wan Kwok（郭文贵）22-50073\n\n债务人\n\n章程：________________ 11\n规则2004审查传票\n\n致：________________________________________________________________________________________________ Forbes Hare\n\n（传票所指向之人的姓名）\n\n证言：特此命令你于下文列明的时间、日期和地点出席，依《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\nPaul Hastings LLP\n200 Park Avenue\nNew York, New York 10166\n\n审查将通过以下方式记录：____________________________________________________________ 法庭记录员/速记员\n\n提交材料：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检查、复制、测试或抽样：\n见随附于本传票的《文件提交请求》。\n\n下列《联邦民事诉讼规则》45条规定，经《联邦破产程序规则》9016条适用于破产案件，现随附于后——有关遵从地点的规则45(c)；有关作为受传票约束之人的保护的规则45(d)；以及有关你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：2022年9月___日\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 Patrick R. Linsey (ct29437)\n\n签发或请求本传票、代表（当事人姓名）____________________________的律师之姓名、地址、电子邮件地址和电话号码如下：Luc Despins，第11章受托人\n\nPatrick R. Linsey, Esq.; Neubert, Pepe & Monteith, P.C.; 195 Church Street, New Haven, Connecticut 06510；plinsey@npmlaw.com；203-821-2000\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之人送达之前，向每一当事人送达通知及本传票副本。《联邦民事诉讼规则》45(a)(4)。\n\n文件提交请求\n\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”，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，否则必须完整回答每项请求；如提出异议，则必须按下文规定详细说明你提出异议的理由。如异议仅涉及一项请求的一部分，或其中所含的一个词语、短语或条款，你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。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电子表格应有一张以该文件Bates编号命名的占位图像。\n\n- b. 图像加载文件\n\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）。日期字段应按以下格式提供：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。请勿在.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；数据库中的每一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。文本必须以单独的文本文件形式提供，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。建议提供文档级 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，且每个文件夹中的文本文件数量不得超过 1,000 个。文件夹名称中不得包含特殊字符（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。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。应提供一张带有 Bates 编号的提示页图像，表明原生文件的存在，并将原生文件的路径作为 .dat 文件中的一个字段列入。所提供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 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日期字段应按以下格式提供：mm/dd/yyyy。日期和时间字段必须为两个独立字段。以下为必需元数据：\n案号 22-50073 文档 839 提交于 09/07/22 录入于 09/07/22 20:02:47 第 322 页，共 491 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\n**对于单页文件，应填写 LASTBATES 字段\n\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\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：文档来源个人或部门的名称\n\nFROM John Smith 电子邮件：发件人\n原生文件：文档作者\n\n**多个条目之间应使用分号分隔\n\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\n\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\n\nBCC John Cain 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：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 文档 839 提交于 09/07/22 录入于 09/07/22 20:02:47 第 323 页，共 491 页\n\nTIME_CREATED 10:25 AM 电子邮件：（空）\n原生文件：文档创建时间\n**该数据必须为单独字段，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**该数据必须为单独字段，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**该数据必须为单独字段，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，单位为 KB\n\nPGCOUNT 1 原生文件文档/电子邮件的页数\n\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。\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 原生文件：（空）\nMinutes.msg\n\nINTMSGID <000805c2c71b\\$75977050\\$ 电子邮件：唯一消息\nID 原生文件：（空）\ncb8306d1@MSN>\n\nMD5HASH d131dd02c5e6eec4693d9a0 文档的 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. 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，或者应组织并标记为与本请求中的类别相对应。\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）由代表您行事的任何人占有、保管或控制的文件，\n案号 22-50073 文档 839 提交于 09/07/22 录入于 09/07/22 20:02:47 第 324 页，共 491 页\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，确定该文件被发送给的人员）；（c）确定该文件编制或创建的日期；（d）说明该文件是否（i）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）以其他方式处置；（e）说明该等处置的原因及相关事实和情形；（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）足以支持您关于该文件享有特权这一主张的文件描述，（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的身份，（vii）该文件本身或文件中所含或所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，则应确定该等人员的身份，\n案号 22-50073 文档 839 提交于 09/07/22 录入于 09/07/22 20:02:47 第 325 页，共 491 页\n\n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. 该等请求具有持续性。现指示您：（a）一旦知悉先前答复不完整或不正确，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额外文件。\n\n11. 如文件为英文以外的语言，您应提供该文件。如文件为英文以外的语言，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替代姓名、别名或昵称。\n案号 22-50073 文档 839 提交于 09/07/22 录入于 09/07/22 20:02:47 第 326 页，共 491 页\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；（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”应视需要解释为连词或析取词，以使任何请求的范围涵盖原本可能被解释为处于其范围之外的所有答复；以及（b）“each”和“any”应被视为包括并涵盖“every”和“all”一词。\nIII. 定义\n\n经 D. Conn. Bankr. L.R. 2004-1(a) 纳入的 D. Conn. L. Civ. R. 26(c) 所规定的定义和 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如下含义：\n\n1. “You”或“Your”或“Yourself”系指 Forbes Hare（福布斯·黑尔），以及其任何雇员、代理人、律师、顾问或代表其行事的任何人。\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），以及其雇员、代理人、律师、顾问或代表其行事的任何人。\n案号 22-50073 文档 839 提交于 09/07/22 录入于 09/07/22 20:02:47 第 327 页，共 491 页\n\n3. “债务人之子”系指 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. “债务人之女”系指 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. “债务人所谓之妻”系指 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. “债务人家属”统指债务人、债务人之子、债务人之女、债务人所谓之妻，以及与债务人具有任何其他亲属关系的人。\n\n7. “关联个人”单独及合并地系指所有以下个人：（1）持有、控制、保管或对债务人或债务人家属所拥有、控制或享有的资产具有处置权；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，并包括前述任何人员各自的雇员、代理人、律师、顾问或任何代表其行事的人。该等关联个人包括但不限于：Daniel Podhaskie、Jason Miller、Steve Bannon、Karin Maistrello、Melissa Francis、William Gertz、Arethusa Forsyth、Glenn Mellor、Jennifer Mercurio、Eduardo Eurnekian、Han Chunguang（韩春光）、Qu Guojiao（屈国姣，亦称 Qu Guo Jiao）、Guo Lijie（郭丽杰）、Zhang Wei（张伟）、Lihong Wei Lafrenz（魏丽红，亦称 Sara Wei）、Hao Haidong（郝海东）、Ross Heinemeyer、Max Krasner、Kyle Bass、Melissa Mendez、Ya Li（李娅）、Dinggang Wang（王定刚）、An Hong（安红）、Yvette Wang（王雁平，亦称 Yanping Wang、Yan Ping Wang）、Fiona Yu、Je Kin Ming（余建明，亦称 William Je、Yu Jianming）、Yaz Qingua，以及 Lao Jiang（姜云浮，亦称 Jiang Yunfu、Jiang Yunfu Be）。\n\n8. “关联实体”单独及合并地系指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）直接或间接地对债务人或债务人家属所拥有、控制或享有的任何资产具有权益，并包括前述任何实体各自的雇员、代理人、律师、顾问或任何代表其行事的人。该等关联实体包括但不限于：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、Assets Sino Limited、Auspicious Coast Limited、Beijing Pangu Investment Co.、Beijing Pangu Investment Co. Ltd.、Beijing Pangu Investment Inc.、Beijing Zenith Holdings Company Limited、Bravo Luck Limited、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、Elite Well Global Limited、Empire Growth Holdings、G Club Operations LLC、G Fashion LLC、G News LLC、GETTR USA、Genever Holdings Corporation、Genever Holdings LLC、GFASHION MEDIA GROUP INC.、GFNY, Inc.、Globalist International Limited、GNews Media Group Inc.、Golden Spring (New York) Ltd.、Greenwich Land LLC、Guo Media、GTV Media Group, Inc.、Hamilton Capital Holdings Inc.、Head Win Group Limited、Henan Yuda、Himalaya Embassy、Himalaya Exchange、Himalaya Federal Reserve、Himalaya Supervisory Organization、HK International Funds Investments (USA) Limited LLC、Hong Kong International Funds Investments Limited、Infinite Increase Limited、Infinitum Developments Limited、Insight Phoenix Fund、Lamp Capital LLC、Leading Shine Limited、Leading Shine NY Limited、Long Gate Limited、Next Tycoon Investments Limited、New Federal State of China（亦称 NFSC）、Noble Fame Global Limited、Rosy Acme Ventures Limited、Rule of Law Foundation III, Inc.、Rule of Law Foundation IV, Inc.、Rule of Law Fund、Rule of Law Society、Rule of Law Society IV, Inc.、G-Translators PTY LTD、Saraca Media Group, Inc.、Shiny Ace Ltd.、Shiny Times Holdings Ltd.、Spirit Charter Investment Limited、Stevenson, Wong & Co.、Voice of Guo Media, Inc.、Well Origin Ltd.、World Century Limited、Worldwide Opportunity Holdings Limited、Whitecroft Shore Limited，以及 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”，并应作连词及析取词两种解释，以最大限度扩大其范围。\n\n11. “任何”“所有”及“每一”均系指“每一个及所有”。\n\n12. “每一”及“每个”均系指“每一个及所有”。\n\n13. “第三方”系指除您以外的个人或实体。\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”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、性质或描述的每一份书面、记录或图形材料，只要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、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、调查材料、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、持仓报告、摘要、索引、账簿、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、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文件的草稿或副本，如该等草稿或副本包含原始文件中没有的任何种类笔记、评论或标记，或以其他方式与原始文件不完全相同。\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、代理机构、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、赞成、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. 就任何特定事项而言，“与……有关”“有关”或“相关”，包括但不限于任何构成、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相关的文件。\n\n20. “通信”在最广泛的可能意义上且不限于此，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，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、录音记录、传送单、备忘录、电话通信、语音留言、电报、电传传真件、影印传真件、电传、即时消息、聊天记录、短信、在留言板或群聊中的发布内容、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递的笔记。\n\n21. “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、存货以及其他有形和无形财产。\n\nIV. 应提交的文件\n\n1. 与债务人、债务人财产、债务人家属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、债务人家属的任何成员和/或任何关联实体的任何委托函有关的所有文件，包括该等委托函的副本。\n\n3. 与基于您对债务人、债务人家属或关联实体的代理而向您支付任何预付律师费有关的所有文件，包括足以识别该预付律师费金额及其来源的文件。\n\n4. 与您从债务人、债务人家属、家庭关联实体或关联实体处或代表其收取，并存放于托管账户或客户信托账户中的任何费用、付款或款项有关的所有文件。\n\n5. 足以显示债务人、债务人家属或关联实体向您作出或为其利益而向您作出的任何付款的金额、日期和来源的文件。\n\n6. 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偿付该等义务的行为有关的所有文件，以及与本破产程序或任何其他实际或可能发生的破产或类似无力偿债程序有关的所有文件。\n\n7. 与关联实体有关的所有文件，包括但不限于与其公司结构、资产、注册信息、高级职员及董事、业务目的，以及其与债务人、债务人家属的任何成员或任何关联个人之间关系有关的文件。\n\n8. 与一方的债务人或债务人家属，以及另一方的关联实体之间由、与或代表债务人或债务人家属进行的任何投资或商业交易有关的所有文件。\n\n9. 与债务人、债务人财产、债务人家属或关联实体持有任何权益或投资的任何实体有关的所有文件，包括但不限于该等权益或投资的性质及价值；债务人、债务人财产、债务人家属或关联实体因该等权益或投资而从该实体取得的任何收益或利益；以及与该实体有关的任何财务报告或数据有关的所有文件，包括但不限于所有账簿和记录、财务报表或税务文件。\n\n10. 关于 Lady May（“五月花女士”号）；Sherry Netherland Hotel / Condominium（Sherry Netherland 酒店／公寓）；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；以及债务人或债务人遗产在任何关联实体中拥有的任何财务权益的所有文件。\n\n11. 与日期为 February 17, 2015、由债务人作为受托人、Genever Holdings Corporation（Genever 控股公司）及 Genever Holdings LLC（Genever 控股有限责任公司）订立、以 Bravo Luck Limited（Bravo Luck 有限公司）为受益人的所谓信托声明及协议有关的所有文件。\n\n12. 与债务人拥有、控制或使用的任何航空器有关的所有文件，包括但不限于尾号为 T7-GQM 的航空器，以及任何其他在 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以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。\n\n13. 与债务人、债务人的家属或关联实体于 July 2020 前后或任何其他时间就原油期货或任何类似商品进行的任何投资或交易有关的所有文件，包括但不限于与 Jiang Yunfu Be（江云富贝）就任何该等投资或交易进行的通信记录。\nCase 22-50073 Doc 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 334 of 491\n\n14. 你与债务人、债务人的家属，或任何关联个人、代理人、雇员或代表债务人行事的其他个人之间，与任何涉及债务人、债务人遗产、债务人的家属或关联实体的转让、投资或其他交易或商业往来有关的所有通信记录。\n\n15. 与由债务人、债务人遗产、债务人的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，包括但不限于显示该等信托于何时设立、由谁设立、为谁的利益设立以及该文书的信托财产的文件。\n\n16. 与涉及债务人、债务人的家属或任何关联实体的任何出售、取得、处分、购买、投资、出资、赠与、信用展期、贷款或转让有关的所有文件。\n\n17. 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\n18. 与向债务人、债务人遗产、债务人的家属或任何关联实体提供或由其提供的任何贷款或信用展期，或就此提出的申请有关的所有文件，包括但不限于：(i) 任何该等贷款或信用展期的条款，包括其偿还条款、陈述与保证及利率；以及 (ii) 所有贷款付款的证据。\nCase 22-50073 Doc 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 335 of 491\n\n19. 与债务人使用任何属于、受控制于或其全部或部分所有权由债务人的家属、关联实体或关联个人持有的资产有关的所有文件。\n\n20. 关于与债务人、债务人遗产、债务人的家属、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\n21. 与任何关联实体（包括 Bravo Luck Limited）的资产向任何其他实体作出的任何质押有关的所有文件。\n\nCase 22-50073 Doc 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 336 of 491\n\nB2540（表格 2540—规则 2004 审查传票）（第 2 页）491\n\n（除非 Fed. R. Civ. P. 45 要求，否则本节不应向法院提交。）\n\n于（日期）\n__________ 本人收到了向（个人姓名及职务，如有）发出的本传票：______________________________________________\n本人通过向被点名人员交付副本的方式送达本传票，具体如下：____________________________________\n\n__________________________________ 于（日期）___________________；或\n本人未执行本传票即予退回，原因如下：____________________________________________________________\n\n本人的费用为差旅 \\$ _________ 及服务 \\$_________，合计 \\$_________。除非本传票代表 United States（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本人在伪证罪处罚的约束下声明，该等信息真实且准确。\n\n日期：_______________ ________________________________________________\n送达人员签名\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）（根据 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、受雇或经常亲自办理业务地点的 100 英里范围内；或\n\n(B) 在该人居住、受雇或经常亲自办理业务所在州内，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。传票可以命令：\n\n(A) 在该人居住、受雇或经常亲自办理业务地点的 100 英里范围内某一地点提交文件、以电子方式存储的信息或物品；以及\n\n(B) 在应检查的不动产处检查该不动产。\n\n(d) 保护受传票约束的人；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，避免对受传票约束的人施加不当负担或费用。要求履行传票义务所在地区的法院必须执行该项义务，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) 命令提交材料或允许检查。\n\n(A) 无需出席。被命令提交文件、以电子方式存储的信息或有形物品，或允许检查不动产的人，无需亲自到提交或检查地点出席，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，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，或反对检查不动产，或反对以所要求的一种或多种形式提交以电子方式存储的信息。异议必须在规定的履行时间或传票送达后 14 天两者中较早者之前送达。提出异议的，适用下列规则：\n\n(i) 经通知被命令之人后，送达传票的当事人可随时向要求履行传票义务所在地区的法院提出动议，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，要求履行传票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) 未给予合理履行时间；(ii) 要求某人在超出 Rule 45(c) 规定的地域限制之外履行；(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) 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的人，要求履行传票义务所在地区的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，且源于该专家未经当事人请求所进行的研究。\n\n(C) 作为替代措施规定条件。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报酬，\n\n法院可以不撤销或修改传票，而命令其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) 提交文件或以电子方式存储的信息。下列程序适用于提交文件或以电子方式存储的信息：\n\n(A) 文件。回应要求提交文件的传票的人，必须按照文件在日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文件进行整理和标注。\n\n(B) 未规定提交以电子方式存储的信息的形式。如传票未规定提交以电子方式存储的信息的形式，回应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该等信息。\n\n(C) 以电子方式存储的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以电子方式存储的信息。\n\n(D) 无法获取的以电子方式存储的信息。回应人无需从其认定因不当负担或费用而无法合理获取的来源，提供以电子方式存储的信息的证据开示。在申请强制证据开示或保护令的动议中，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。如作出该等证明，法院在考虑 Rule 26(b)(2)(C) 的限制后，如提出请求的当事人证明有正当理由，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。基于所要求的信息享有特权或作为审判准备材料受到保护而扣留传票所要求信息的人，必须：\n\n(i) 明确提出该项主张；并且\n\n(ii) 以一种不披露本身享有特权或受保护的信息、但足以使各方评估该项主张的方式，说明被扣留文件、通信记录或有形物品的性质。\n\n（B）已提供的信息。如果为回应传票而提供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、隔离或销毁所指明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；如果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履行义务所在地辖区的法院，由其裁定该主张。提供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。履行义务所在地辖区的法院——以及在动议被移送后签发传票的法院——可以对已被送达但无充分理由不遵守传票或相关命令的人认定为藐视法庭。\n\n如需查阅传票材料，见 Fed. R. Civ. P. 45(a) Committee Note (2013)\n\n……\n\n附件 C-17\nB2540（表格 2540——依据规则 2004 进行审查的传票）（12/15）Case 22-50073 Doc 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 339 of 491\n\nUNITED STATES BANKRUPTCY COURT（美国联邦破产法院）\n\n＿＿＿＿＿＿＿＿＿＿＿＿＿＿＿＿＿＿＿＿＿＿＿＿＿＿＿＿＿＿＿＿＿＿＿＿＿＿ District of ＿＿＿＿＿＿＿＿＿＿＿＿＿＿＿＿＿＿＿＿＿＿＿＿＿＿＿＿＿＿＿＿＿＿＿＿＿＿ Connecticut（康涅狄格州）\n\n关于 ＿＿＿＿＿＿＿＿＿＿＿＿＿＿＿＿＿＿＿＿＿＿＿＿＿＿＿＿＿＿＿＿＿＿＿＿＿＿\n\n案号：＿＿＿＿＿＿＿＿＿＿＿＿＿＿＿＿＿＿ Ho Wan Kwok（郭文贵）22-50073\n\n债务人\n\n第 ＿＿＿＿＿＿＿＿＿＿＿＿＿＿ 章 11\n依据规则 2004 进行审查的传票\n\n致：＿＿＿＿＿＿＿＿＿＿＿＿＿＿＿＿＿＿＿＿＿＿＿＿＿＿＿＿＿＿＿＿＿＿＿＿＿＿＿＿＿＿＿＿＿＿＿＿ Ogier（欧杰）\n\n（传票所指向之人的姓名）\n\n证言：兹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》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\nPaul Hastings LLP（普衡律师事务所）\n200 Park Avenue\nNew York, New York 10166\n\n审查将通过以下方式记录：＿＿＿＿＿＿＿＿＿＿＿＿＿＿＿＿＿＿＿＿＿＿＿＿＿＿＿＿＿＿＿＿＿＿＿＿＿＿＿＿法院记录员／速记员\n\n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，并且必须允许对该材料进行查验、复制、测试或取样：\n见随附的文件提交请求。\n\n以下 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——Rule 45(c)，关于履行义务的地点；Rule 45(d)，关于作为传票对象之人的保护；以及 Rule 45(e) 和 45(g)，关于你对本传票作出回应的义务以及未履行该义务的潜在后果。\n\n日期：Sept＿＿＿＿＿＿＿＿＿＿＿＿＿＿ ember ＿＿, 2022\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 Patrick R. Linsey（帕特里克·R·林赛）(ct29437)\n\n代表（当事人姓名）＿＿＿＿＿＿＿＿＿＿＿＿＿＿＿＿＿＿＿＿＿＿的律师，即签发或请求本传票的律师，其姓名、地址、电子邮件地址和电话号码如下：Luc Despins（卢克·德斯潘），Ch. 11 Trustee（第 11 章受托人）\n\nPatrick R. Linsey, Esq.; Neubert, Pepe & Monteith, P.C.（诺伊伯特、佩佩与蒙蒂斯职业公司）；195 Church Street, New Haven, Connecticut 06510；plinsey@npmlaw.com；203-821-2000\n\n致签发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文件提交请求\n\n一、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。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，则必须如下文所述详细说明你提出异议的理由。如果异议仅涉及某项请求的一部分，或其中包含的某个词、短语或条款，你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。文件名称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。Excel 电子表格应有以该文件 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。如果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，以提供在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\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存放于单独的文件夹中，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。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 文件中以字段形式包括原生文件路径。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。\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，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：\nCase 22-50073 Doc 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 342 of 491\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 字段应就单页文件填写\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\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 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 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 343 of 491\n\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，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，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，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（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：存储原生文件的路径，包括原始文件名。\nINTFILEPATH Personal Folders\\Deleted 电子邮件：包括原始文件名的电子邮件原始位置。\nItems\\Board Meeting 原始文件名。\nMinutes.msg 原生：（空）\nINTMSGID <000805c2c71b\\$75977050\\$ 电子邮件：唯一邮件\nID 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. 各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. 所有文件应按通常业务过程中的保存方式提供，或者应按照本请求中的类别进行整理和标记。\n\n5. 本文所载的各项请求延伸至所有文件：(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，\nCase 22-50073 Doc 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 344 of 491\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，该文件的收件人员）；(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) 说明该等处置的原因及相关事实和情形；(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) 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) 对该文件作出足以支持贵方关于该文件享有特权之主张的描述，(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) 该文件本身或其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，该等人员的身份，\nCase 22-50073 Doc 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 345 of 491\n\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) 就根据 D. Conn. L. Civ. R. 26(e) 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的任何部分，应完整提供响应性文件。\n\n9. 如本应响应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。现指示贵方：(a) 在获知先前答复不完整或不正确后，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) 提供根据下列规定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替代姓名、别名或昵称。\nCase 22-50073 Doc 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 346 of 491\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在所有其他时态中使用该动词。\n\n16. (a) “and”和“or”应视需要解释为连词关系或选择关系，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；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. “贵方”或“贵方的”或“贵方自身”系指 Ogier（奥杰），连同其任何雇员、代理人、律师、顾问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），连同其雇员、代理人、律师、顾问或代表其行事的任何人。\nCase 22-50073 Doc 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 347 of 491\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），连同其雇员、代理人、律师、顾问或代表其行事的任何人。\n\n5. “债务人所谓之妻”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、顾问或代表其行事的任何人。\n\n6. “债务人家庭成员”统指债务人、债务人之子、债务人之女及债务人所谓之妻，以及与债务人有任何其他家庭关系的人员。\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庭成员拥有、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，连同上述任何人员各自的雇员、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：Daniel Podhaskie（丹尼尔·波德哈斯基）、Jason Miller（杰森·米勒）、Steve Bannon（史蒂夫·班农）、Karin Maistrello（卡琳·迈斯特雷洛）、Melissa Francis（梅丽莎·弗朗西斯）、William Gertz（威廉·格茨）、Arethusa Forsyth（阿雷图萨·福赛思）、Glenn Mellor（格伦·梅勒）、Jennifer Mercurio（詹妮弗·默丘里奥）、Eduardo Eurnekian（爱德华多·厄尔内基安）、Han Chunguang（韩春光）（又名 韩春光）、Qu Guojiao（屈国姣）（又名 Qu Guo Jiao、屈国姣）、Guo Lijie（郭丽杰）（又名 郭丽杰）、Zhang Wei（张伟）（又名 张伟\\*）、Lihong Wei Lafrenz（魏丽红）（又名 Sara Wei、魏丽红）、Hao Haidong（郝海东）（又名 郝海东）、Ross Heinemeyer（罗斯·海内迈耶）、Max Krasner（马克斯·克拉斯纳）、Kyle Bass（凯尔·巴斯）、Melissa Mendez（梅丽莎·门德斯）、Ya Li（李娅）（又名 李娅）、Dinggang Wang（王定刚）（又名 王定刚）、An Hong（安红）（又名 安红）、Yvette Wang（王雁平）（又名 Yanping\nCase 22-50073 Doc 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 348 of 491\n\nWang、Yan Ping Wang、王雁平）、Fiona Yu（菲奥娜·余）、Je Kin Ming（余建明）（又名 William Je、Yu Jianming、余建明\n\n）、Yaz Qingua（亚兹·钦瓜）以及 Lao Jiang（姜云浮）（又名 Jiang Yunfu、Jiang Yunfu Be、姜云浮）。\n\n8. “关联实体”系指单独或共同符合下列情形的各种类型的所有组织或实体：(1) 已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，连同上述任何实体各自的雇员、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：7 Nod Hill LLC（7号诺德山有限责任公司）、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（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）、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（阿尔卑斯受托人股份公司）、Anton Development Limited（安东开发有限公司）、Assets Sino Limited（中资资产有限公司）、Auspicious Coast Limited（吉祥海岸有限公司）、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（北京鼎峰控股有限公司）、Bravo Luck Limited（鸿运有限公司）、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（克兰咨询集团有限责任公司）、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）、Elite Well Global Limited（精英环球有限公司）、Empire Growth Holdings（帝国成长控股）、G Club Operations LLC（G俱乐部运营有限责任公司）、G Fashion LLC（G时尚有限责任公司）、G News LLC（G新闻有限责任公司）、GETTR USA（GETTR美国）、Genever Holdings Corporation（吉尼弗控股公司）、Genever Holdings LLC（吉尼弗控股有限责任公司）、GFASHION MEDIA GROUP INC.（GFASHION媒体集团公司）、GFNY, Inc.（GFNY公司）、Globalist International Limited（环球主义者国际有限公司）、GNews Media Group Inc.（GNews媒体集团公司）、Golden Spring (New York) Ltd.（金泉〔纽约〕有限公司）、Greenwich Land LLC（格林尼治土地有限责任公司）、Guo Media（郭媒体）、GTV Media Group, Inc.（GTV媒体集团公司）、Hamilton Capital Holdings Inc.（汉密尔顿资本控股公司）、Head Win Group Limited（领赢集团有限公司）、Henan Yuda（河南裕达）、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 Supervisory Organization（喜马拉雅监督组织）、HK International Funds Investments (USA)\nCase 22-50073 Doc 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 349 of 491\n\nLimited 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）、Infinite Increase Limited（无限增长有限公司）、Infinitum Developments Limited（无尽开发有限公司）、Insight Phoenix Fund（洞察凤凰基金）、Lamp Capital LLC（蓝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）、Long Gate Limited（长龙门有限公司）、Next Tycoon Investments Limited（下一个大亨投资有限公司）、New Federal State of China（中国新联邦国）（又名 NFSC）、Noble Fame Global Limited（全球名望有限公司）、Rosy Acme Ventures Limited（玫瑰顶峰创投有限公司）、Rule of Law Foundation III, Inc.（法治基金会III公司）、Rule of Law Foundation IV, Inc.（法治基金会IV公司）、Rule of Law Fund（法治基金）、Rule of Law Society（法治协会）、Rule of Law Society IV, Inc.（法治协会IV公司）、G-Translators PTY LTD（G-译者私人有限公司）、Saraca Media Group, Inc.（萨拉卡媒体集团公司）、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）、Spirit Charter Investment Limited（精神宪章投资有限公司）、Stevenson, Wong & Co.（史蒂文森、黄氏及公司）、Voice of Guo Media, Inc.（郭媒体之声公司）、Well Origin Ltd.（良源有限公司）、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）、Whitecroft Shore Limited（怀特克罗夫特海岸有限公司）以及 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”，并应作连词及析取词两种解释，以最大限度扩大其适用范围。\n\n11. “任何”及“所有”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《破产法典》第101(54)条所赋予的含义。\n\n15. “文件”系指属于 Fed. R. Civ. P. 34 范围内的任何信息或物品，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、记录或图形资料，其现由或曾由您占有、保管或控制，包括电子邮件、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、各种书面表格的所有打印及电子副本，\n\nCase 22-50073 Doc 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 350 of 491\n\n图表、蓝图、图纸、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、清单、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，无论以何种方式存储（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上述任何资料的草稿或副本，如其中包含原始文件中未载有的任何种类的注释、评论或标记，或在其他方面与原始文件不相同。\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、对其有影响、证明、表明、报告、记录、暗示、回应、\n\nCase 22-50073 Doc 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 351 of 491\n\n与之有关、评论、就其而言、有关、与之相关、讨论、显示、描述、反映、分析、构成及为其组成部分。\n\n19. “与……相关”、“与……有关”或“与……有关联”，在指称任何特定主题事项时，系指包括但不限于构成、包含、涉及、含有、体现、反映、识别、陈述、直接或间接提及该特定主题事项，或以任何方式与该特定主题事项相关的任何文件。\n\n20. “通信”系指以最广义且不限于任何形式传递信息或知识（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、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、电话笔记，或在内部或与第三方之间传送的笔记。\n\n21. “资产”系指受占有、保管或控制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、存货及其他有形和无形财产。\n\nIV. 应提交的文件\n\n1. 与债务人、债务人破产财产、债务人家庭或关联实体的任何收入或资产有关的所有文件。\n\nCase 22-50073 Doc 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 352 of 491\n\n2. 与债务人、债务人家庭任何成员和/或任何关联实体订立的任何委托函有关的所有文件，包括该等委托函的副本。\n\n3. 与基于您对债务人、债务人家庭或关联实体的代理而向您支付任何预付聘金有关的所有文件，包括足以识别该预付聘金金额及其来源的文件。\n\n4. 与您从债务人、债务人家庭、家庭关联实体或关联实体处或代表其收取，并存放于托管账户或客户信托账户中的任何费用、付款或款项有关的所有文件。\n\n5. 足以显示债务人、债务人家庭或关联实体向您支付或为其利益向您支付的任何款项之金额、日期及来源的文件。\n\n6. 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破产程序或类似无力偿债程序有关的所有文件。\n\n7. 与关联实体有关的所有文件，包括但不限于与其公司结构、资产、设立信息、高级职员及董事、商业目的，以及其与债务人、债务人家庭任何成员或任何关联个人之间关系有关的文件。\n\n8. 与债务人或债务人家庭（一方）和关联实体（另一方）所作、与之进行或代表其进行的任何投资或商业交易有关的所有文件。\n\nCase 22-50073 Doc 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 353 of 491\n\n9. 与债务人、债务人破产财产、债务人家庭或关联实体在其中持有任何权益或投资的任何实体有关的所有文件，包括但不限于该等权益或投资的性质及价值；债务人、债务人破产财产、债务人家庭或关联实体因该等权益或投资而从该实体获得的任何收益或利益；以及与该实体有关的任何财务报告或数据有关的所有文件，包括但不限于所有账簿和记录、财务报表或税务文件。\n\n10. 关于 Lady May（“梅夫人号”）；Sherry Netherland Hotel / Condominium（谢里-荷兰酒店／共管公寓）；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；以及债务人或债务人破产财产在任何关联实体中拥有的任何财务权益的所有文件。\n\n11. 与债务人以受托人身份、Genever Holdings Corporation（吉尼维尔控股公司）及 Genever Holdings LLC（吉尼维尔控股有限责任公司）于 February 17, 2015 为 Bravo Luck Limited（鸿运有限公司）作为受益人而订立的所谓《信托声明及协议》有关的所有文件。\n\n12. 与债务人拥有、控制或使用的任何航空器有关的所有文件，包括但不限于机尾编号为 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飞行清单，该等飞行清单显示该等航空器所执行的飞行及搭乘该等航班的人员。\n\n13. 与债务人、债务人家庭或关联实体于 July 2020 前后或任何其他时间进行的原油期货或任何类似商品的任何投资或交易有关的所有文件，包括但不限于与 Jiang Yunfu Be（江云福贝）就该等投资或交易进行的通信。\n\nCase 22-50073 Doc 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 354 of 491\n\n14. 您与债务人、债务人家庭或任何关联个人、代理人、雇员或其他代表债务人行事的个人之间，就与债务人、债务人破产财产、债务人家庭或关联实体有关的任何转让、投资或其他交易或商业往来所进行的所有通信。\n\n15. 关于由债务人、债务人破产财产、债务人家庭或关联实体设立、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，包括但不限于显示该等信托于何时设立、由何人设立、为谁的利益设立以及该文书信托财产的文件。\n\n16. 与涉及债务人、债务人家庭或任何关联实体的任何出售、取得、处置、购买、投资、出资、赠与、授信、贷款或转让有关的所有文件。\n\n17. 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（无论为行政机构、法院、合议庭或替代性争议解决实体）审理的任何诉讼有关的文件。\n\n18. 与向债务人、债务人破产财产、债务人家庭或任何关联实体提供或从其取得的任何贷款或授信，或就此提出的申请有关的所有文件，包括但不限于：(i) 任何该等贷款或授信的条款，包括其偿还条款、陈述与保证及利率；及 (ii) 该等贷款付款的所有证明。\n\nCase 22-50073 Doc 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 355 of 491\n\n19. 与债务人使用任何属于、由其控制或其全部或部分所有权由债务人家庭、关联实体或关联个人持有的资产有关的所有文件。\n\n20. 关于与债务人、债务人破产财产、债务人家庭、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、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主体进行的所有转让的所有文件。\n\n21. 与任何关联实体（包括 Bravo Luck Limited）的资产向任何其他实体提供的任何质押有关的所有文件。\n\nCase 22-50073 Doc 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 356 of\n\nB2540（表格 2540－Rule 2004 审查传票）（第 2 页） 491\n\n（除非 Fed. R. Civ. P. 45 要求，否则本节不应向法院提交。）\n\n于（日期）\n__________ 本人收到为以下人员（姓名及职务，如有）发出的本传票：______________________________________________\n\n本人通过向被指定人员交付副本的方式送达本传票，具体如下：____________________________________\n\n__________________________________ 于（日期）___________________；或\n\n本人因以下原因未执行传票并将其退回：____________________________________________________________\n\n我的差旅费用为 $ _________，服务费用为 $_________，合计 $_________。除非传票系代表 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及法律允许的里程费，金额为 $ _______________________。\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送达人签名\n\n送达人地址\n\n关于尝试送达等事项的补充信息：\n\nFederal Rule of Civil Procedure（《联邦民事诉讼规则》）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》）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、受雇或经常亲自开展业务的地点 100 英里以内；或\n\n(B) 在该人居住、受雇或经常亲自开展业务的州内，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、受雇或经常亲自开展业务的地点 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，避免对受传票约束的人员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。异议必须在指定履行时间或传票送达后 14 天届满之日中较早者之前送达。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命令人员后，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员，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。经及时动议，要求履行义务所在地区的法院必须撤销或修改符合下列情形的传票：\n\n(i) 未给予合理的履行时间；(ii) 要求某人在超出 Rule 45(c) 规定的地域限制范围外履行；(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。为保护受传票约束或受其影响的人员，要求履行义务所在地区的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说明争议中的具体事件，且系该专家未受当事人请求而进行的研究所得结果。\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，且如不遭受不当困难则无法以其他方式满足该需要；以及\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席或提交材料。\n\n(e) 回应传票的义务。\n\n(1) 提交文件或电子存储信息。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员，必须按其在正常业务过程中保存的方式提交文件，或者必须将其整理并标注，以对应请求中所列类别。\n\n(B) 未指定提交电子存储信息的形式。如传票未指定提交电子存储信息的形式，回应人员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该等信息。\n\n(C) 电子存储信息仅以一种形式提交。回应人员无须以多于一种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。回应人员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。就强制证据开示动议或保护令动议，回应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) 扣留信息。依据该信息享有特权或作为审判准备材料受保护而扣留被传唤信息的人员，必须：\n\n(i) 明确提出该主张；以及\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，能够使当事人评估该主张。\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，提出该主张的人员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义务所在地区的法院，以裁定该主张。提交该信息的人员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，均可认定已被送达却无充分理由不遵守传票或相关命令的人员构成藐视法庭。\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附件 C-18\n\nB2540（Form 2540 – Subpoena for Rule 2004 Examination）（12/15）Case 22-50073 Doc 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 359 of 491\n\nUNITED STATES BANKRUPTCY COURT（美国破产法院）\n\n________________________________________________ 康涅狄格地区\n\n关于 _______________________________________________________\n\n案号 ___________________ Ho Wan Kwok（郭文贵） 22-50073\n\n债务人\n\n第 ____________ 11 章\n\n依据 Rule 2004 进行审查的传票\n\n致：________________________________________________________________________________ O'Neal Webster（奥尼尔·韦伯斯特）\n\n（传票所指向人员的姓名）\n\n证言：兹命令你于下列载明的时间、日期和地点出席，依据 Federal Rules of Bankruptcy Procedure（《联邦破产程序规则》）Rule 2004 进行审查并作证。随附授权该审查的法院命令副本。\n\n地点 日期和时间\n\nPaul Hastings LLP（普衡律师事务所）\n\n200 Park Avenue\n\nNew York, New York 10166\n\n审查将通过下列方式记录：___________________________________________________________ 法院记录员/速记员\n\n提交材料：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 Fed. R. Civ. P. 45 条款依据 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)；有关你作为受传票约束人员所获保护的 Rule 45(d)；以及有关你回应本传票的义务和不这样做的潜在后果的 Rule 45(e) 和 45(g)。\n\n日期：September __, 2022\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 Patrick R. Linsey（帕特里克·R·林赛）(ct29437)\n\n代表（当事人姓名）_____________________________、签发或请求本传票的律师的姓名、地址、电子邮箱地址和电话号码如下：Luc Despins（吕克·德斯潘），第 11 章受托人\n\nPatrick R. Linsey, Esq.; Neubert, Pepe & Monteith, P.C.（纽伯特、佩佩与蒙蒂斯专业公司）；195 Church Street, New Haven, Connecticut 06510；plinsey@npmlaw.com；203-821-2000\n\n向签发或请求本传票人员的通知\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，则必须在向其所指向人员送达之前，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”）必须分别且具体地予以回应。每项请求均应得到完整答复，除非对此善意提出异议；如提出异议，应按下文所述详细说明你提出异议的理由。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，你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）。日期字段应以如下格式提供：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，并且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内，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\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。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。应提供一张标有 Bates 编号的分隔页图像，表明原生文件的存在，并在 .dat 文件中将原生文件路径作为字段列入。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，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，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。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日期字段应以如下格式提供：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案件 22-50073 文件 839 提交 09/07/22 录入 09/07/22 20:02:47 第 362 页，共 491 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 字段应针对单页予以填写。\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 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\n\n应使用分号分隔多个条目。\n\nTO Coffman, Janice; LeeW [mailto:LeeW@MSN.com] 收件人\n\n应使用分号分隔多个条目。\n\nCC Frank Thompson [mailto:frank_Thompson@cdt.com] 抄送收件人\n\n应使用分号分隔多个条目。\n\nBCC John Cain 密送收件人\n\n应使用分号分隔多个条目。\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件的超链接\n\n链接文件必须按照 FIRSTBATES 编号命名。\n\nFILE_EXTEN MSG 表示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\n案件 22-50073 文件 839 提交 09/07/22 录入 09/07/22 20:02:47 第 363 页，共 491 页\n\nTIME_CREATED 10:25 AM 电子邮件：（空）；原生文件：文件创建时间\n\n该数据必须为单独字段，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\n\n该数据必须为单独字段，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\n\n该数据必须为单独字段，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，以 KB 为单位\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：存储原生文件文件的位置，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. 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，或者应予以组织和标注，以对应本等请求中的类别。\n\n5. 本文所载每项请求均延伸至所有文件：(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，\n\n案件 22-50073 文件 839 提交 09/07/22 录入 09/07/22 20:02:47 第 364 页，共 491 页\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) 指明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) 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) 自愿或非自愿地转让给他人，或 (iv) 以其他方式处置；(e) 说明该等处置的理由，以及与该等处置有关的事实和情况；(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) 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. 如您主张某一被要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、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，则指明该等人员身份，并说明该信息如何进入其占有状态，(viii) 据以拒绝提供该文件的特权主张，以及 (ix) 您将赖以支持该特权主张的所有情况；以及 (b) 根据 D. Conn. L. Civ. R. 26(e)，针对基于特权主张而拒绝提供的每份文件，提供一份特权日志，其中载明本指示第 (a) 部分要求的全部信息。对于未就其提出特权或工作成果主张的文件请求部分，应完整提供响应性文件。\n\n案件 22-50073 文件 839 提交 09/07/22 录入 09/07/22 20:02:47 第 365 页，共 491 页\n\n9. 如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，则仅应按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，且其余部分应予提供。\n\n10. 本等请求具有持续性。特此指示您：(a) 一旦获悉先前答复不完整或不正确，立即补充或更正其后获知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，且存在英文译文，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及均包括所有其他姓名、别名或昵称。\n\n案件 22-50073 文书 839 提交于 09/07/22 登记于 09/07/22 20:02:47 第 366 页，共 491 页\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\n二、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”应根据需要解释为连词或析取词，以使任何请求的范围涵盖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”应视为包括并涵盖“every”和“all”二词。\n\n三、定义\n\n根据 D. Conn. L. Civ. R. 26(c) 提供并经 D. Conn. Bankr. L.R. 2004-1(a) 纳入的定义，以及根据 D. Conn. L. Civ. R. 26(d) 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. “You”或“Your”或“Yourself”系指 O'Neal Webster（奥尼尔·韦伯斯特），连同其任何雇员、代理人、律师、顾问或代表其行事的任何人。\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），连同其雇员、代理人、律师、顾问或代表其行事的任何人。\n\n案件 22-50073 文书 839 提交于 09/07/22 登记于 09/07/22 20:02:47 第 367 页，共 491 页\n\n3. “Debtor's Son”系指 Qiang Guo（郭强）（亦称 Mileson Kwok、郭强或任何其他别名），连同其雇员、代理人、律师、顾问或代表其行事的任何人。\n\n4. “Debtor's Daughter”系指 Mei Guo（郭美）（亦称 Mei Gui、郭美或任何其他别名），连同其雇员、代理人、律师、顾问或代表其行事的任何人。\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），连同其雇员、代理人、律师、顾问或代表其行事的任何人。\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家庭关系的人。\n\n7. “Associated Individuals”单独及合称指所有下列个人：(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权者；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者，连同上述任何人的各自雇员、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：Daniel Podhaskie（丹尼尔·波德哈斯基）、Jason Miller（杰森·米勒）、Steve Bannon（史蒂夫·班农）、Karin Maistrello（卡琳·迈斯特雷洛）、Melissa Francis（梅利莎·弗朗西斯）、William Gertz（威廉·格茨）、Arethusa Forsyth（阿瑞图莎·福赛思）、Glenn Mellor（格伦·梅勒）、Jennifer Mercurio（詹妮弗·梅库里奥）、Eduardo Eurnekian（爱德华多·厄尔内基安）、Han Chunguang（韩春光）（亦称 韩春光）、Qu Guojiao（屈国姣）（亦称 Qu Guo Jiao、屈国姣）、Guo Lijie（郭丽杰）（亦称 郭丽杰）、Zhang Wei（张伟）（亦称 张伟*）、Lihong Wei Lafrenz（魏丽红）（亦称 Sara Wei、魏丽红）、Hao Haidong（郝海东）（亦称 郝海东）、Ross Heinemeyer（罗斯·海内迈耶）、Max Krasner（马克斯·克拉斯纳）、Kyle Bass（凯尔·巴斯）、Melissa Mendez（梅利莎·门德斯）、Ya Li（李娅）（亦称 李娅）、Dinggang Wang（王定刚）（亦称 王定刚）、An Hong（安红）（亦称 安红）、Yvette Wang（王雁平）（亦称 Yanping Wang、Yan Ping Wang、王雁平）、Fiona Yu（菲奥娜·余）、Je Kin Ming（余建明）（亦称 William Je、Yu Jianming、余建明）、Yaz Qingua（亚兹·青瓦）及 Lao Jiang（姜云浮）（亦称 Jiang Yunfu、Jiang Yunfu Be、姜云浮）。\n\n案件 22-50073 文书 839 提交于 09/07/22 登记于 09/07/22 20:02:47 第 368 页，共 491 页\n\n8. “Associated Entities”单独及合称指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拥有权益的组织或实体，连同上述任何实体的各自雇员、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：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、Assets Sino Limited、Auspicious Coast Limited、Beijing Pangu Investment Co.、Beijing Pangu Investment Co. Ltd.、Beijing Pangu Investment Inc.、Beijing Zenith Holdings Company Limited、Bravo Luck Limited、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、Elite Well Global Limited、Empire Growth Holdings、G Club Operations LLC、G Fashion LLC、G News LLC、GETTR USA、Genever Holdings Corporation、Genever Holdings LLC、GFASHION MEDIA GROUP INC.、GFNY, Inc.、Globalist International Limited、GNews Media Group Inc.、Golden Spring (New York) Ltd.、Greenwich Land LLC、Guo Media、GTV Media Group, Inc.、Hamilton Capital Holdings Inc.、Head Win Group Limited、Henan Yuda、Himalaya Embassy、Himalaya Exchange、Himalaya Federal Reserve、Himalaya Supervisory Organization、HK International Funds Investments (USA) Limited LLC、Hong Kong International Funds Investments Limited、Infinite Increase Limited、Infinitum Developments Limited、Insight Phoenix Fund、Lamp Capital LLC、Leading Shine Limited、Leading Shine NY Limited、Long Gate Limited、Next Tycoon Investments Limited、New Federal State of China（新中国联邦）（亦称 NFSC）、Noble Fame Global Limited、Rosy Acme Ventures Limited、Rule of Law Foundation III, Inc.、Rule of Law Foundation IV, Inc.、Rule of Law Fund、Rule of Law Society、Rule of Law Society IV, Inc.、G-Translators PTY LTD、Saraca Media Group, Inc.、Shiny Ace Ltd.、Shiny Times Holdings Ltd.、Spirit Charter Investment Limited、Stevenson, Wong & Co.、Voice of Guo Media, Inc.、Well Origin Ltd.、World Century Limited、Worldwide Opportunity Holdings Limited、Whitecroft Shore Limited 及 ZIBA Limited。\n\n案件 22-50073 文书 839 提交于 09/07/22 登记于 09/07/22 20:02:47 第 369 页，共 491 页\n\n9. “Including”或其任何变体，系指“包括但不限于”。\n\n10. “And”和“or”系指“and/or”，并应同时解释为连词及析取词，以最大限度扩大其范围。\n\n11. “Any”、“all”和“each”系指“每一个及所有”。\n\n12. “Each”和“every”系指“每一个及所有”。\n\n13. “Third Party”系指除您本人以外的自然人或实体。\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，并包括但不限于处于或曾处于您占有、保管或控制之下的每一项任何种类、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纸质及电子副本、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、\n\n案件 22-50073 文书 839 提交于 09/07/22 登记于 09/07/22 20:02:47 第 370 页，共 491 页\n\n图表、蓝图、绘图、草图、图形、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、语音信息、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、账簿、总账、笔记本、日程表、透明胶片、录音记录、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；还包括但不限于上述任何文件的草稿或副本，如其中载有原始文件中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一致。\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，包括但不限于律师、财务顾问或任何其他代表。\n\n18. “Regarding”系指有关、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、对其具有影响、证明、表明、报告、记录、暗示、答复、\n\n案件 22-50073 文书 839 提交于 09/07/22 登记于 09/07/22 20:02:47 第 371 页，共 491 页\n\n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、构成及为。\n\n19. 当“Relating to”、“relate(s) to”或“related to”指任何特定事项时，系指但不限于构成、包含、涉及、载有、体现、反映、识别、陈述、直接或间接提及该特定事项，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)”在最广泛可能的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、书面方式，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、录音记录、传送单、备忘录、电话通信、语音信息、电报、电话传真、传真副本、电传、即时消息、聊天、短信、在留言板或群聊中的发布内容、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\n21. “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、产权公寓、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\n四、应提交的文件\n\n1. 与债务人、债务人财产、债务人家庭或关联实体的任何收入或资产有关的所有文件。\n\n案件 22-50073 文书 839 提交于 09/07/22 登记于 09/07/22 20:02:47 第 372 页，共 491 页\n\n2. 与债务人、债务人家庭的任何成员和/或任何关联实体订立的任何委聘函有关的所有文件，包括该等委聘函的副本。\n\n3. 与基于您对债务人、债务人家庭或关联实体的代理而向您支付的任何预付律师费有关的所有文件，包括足以识别该预付律师费金额及其来源的文件。\n\n4. 与您从债务人、债务人家庭、家庭关联实体或关联实体处或代表其收取，并存放于托管账户或客户信托账户中的任何费用、付款或款项有关的所有文件。\n\n5. 足以显示债务人、债务人的家庭成员或关联实体向您支付或为使您受益而支付的任何款项之金额、日期及来源的文件。\n\n6. 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，包括但不限于与避免支付该等义务的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\n7. 与关联实体有关的所有文件，包括但不限于与其公司结构、资产、注册成立信息、高级职员及董事、经营目的，以及其与债务人、债务人家庭任何成员或任何关联个人之间关系有关的文件。\n\n8. 关于债务人或债务人的家庭一方与关联实体另一方之间由其作出、与其进行或代表其进行的任何投资或商业交易的所有文件。\n案号 22-50073 文件 839 提交日期 09/07/22 录入日期 09/07/22 20:02:47 第 373 页，共 491 页\n\n9. 与债务人、债务人财产、债务人的家庭或关联实体持有任何权益或投资的任何实体有关的所有文件，包括但不限于该权益或投资的性质和价值；债务人、债务人财产、债务人的家庭或关联实体因该等权益或投资而从该实体获得的任何收益或利益；以及与该实体有关的任何财务报告或数据有关的所有文件，包括但不限于所有账簿和记录、财务报表或税务文件。\n\n10. 关于 Lady May（“五月女士”号）；Sherry Netherland Hotel / Condominium（谢里荷兰酒店／公寓）；位于康涅狄格州格林尼治市 373 Taconic Rd. 的住宅物业；位于康涅狄格州格林尼治市 33 Ferncliff Rd. 的住宅物业；位于康涅狄格州威尔顿市 354 Nod Hill Rd. 的住宅物业；以及债务人或债务人财产在任何关联实体中拥有的任何财务权益的所有文件。\n\n11. 与债务人作为受托人、Genever Holdings Corporation（Genever 控股公司）及 Genever Holdings LLC（Genever 控股有限责任公司）于 February 17, 2015 订立、以 Bravo Luck Limited（百利福有限公司）为受益人的所谓《信托声明及协议》有关的所有文件。\n\n12. 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。\n\n13. 与债务人、债务人的家庭或关联实体于 July 2020 前后或任何其他时间在原油期货或任何类似商品中的任何投资或交易有关的所有文件，包括但不限于与 Jiang Yunfu Be（姜云福贝）就任何该等投资或交易进行的通信。\n案号 22-50073 文件 839 提交日期 09/07/22 录入日期 09/07/22 20:02:47 第 374 页，共 491 页\n\n14. 您与债务人、债务人的家庭，或任何关联个人、代理人、雇员或其他代表债务人行事的个人之间，就与债务人、债务人财产、债务人的家庭或关联实体有关的任何转移、投资或其他交易或商业往来所进行的所有通信。\n\n15. 关于由债务人、债务人财产、债务人的家庭或关联实体设立、代表其设立或为使其受益而设立的任何信托或类似文书的所有文件，包括但不限于显示该等信托何时设立、由谁设立、为使谁受益而设立以及该文书信托财产的文件。\n\n16. 与涉及债务人、债务人的家庭或任何关联实体的任何出售、取得、处置、购买、投资、出资、赠与、信贷展期、贷款或转移有关的所有文件。\n\n17. 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）进行的任何诉讼有关的文件。\n\n18. 与向债务人、债务人财产、债务人的家庭或任何关联实体提供或由其提供的任何贷款或信贷展期，或该等贷款或信贷展期的申请有关的所有文件，包括但不限于：(i) 任何该等贷款或信贷展期的条款，包括其偿还条款、陈述与保证及利率；以及 (ii) 该等贷款还款的所有证据。\n案号 22-50073 文件 839 提交日期 09/07/22 录入日期 09/07/22 20:02:47 第 375 页，共 491 页\n\n19. 与债务人使用任何属于、由其控制或其全部或部分所有权由债务人的家庭、关联实体或关联个人持有的资产有关的所有文件。\n\n20. 关于与债务人、债务人财产、债务人的家庭、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、电汇指令及／或确认书、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一方进行的所有转移的所有文件。\n\n21. 与将任何关联实体（包括 Bravo Luck Limited）的资产质押给任何其他实体有关的所有文件。\n\n案号 22-50073 文件 839 提交日期 09/07/22 录入日期 09/07/22 20:02:47 第 376 页，共\n\nB2540（表格 2540——依规则 2004 审查的传票）（第 2 页） 491\n\n我于（日期）收到送达给（个人姓名及职务，如有）：______________________________________________ 的本传票。\n\n我于（日期）___________________ 通过向被指定人交付副本的方式送达本传票；或按如下方式送达：____________________________________。\n\n我未执行本传票即予退回，原因是：____________________________________________________________\n\n除非本传票系代表美国或其官员或代理人签发，我还已向证人交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我在伪证罪处罚的约束下声明，\n\n该等信息真实且正确。\n\n日期：_______________\n\n送达人的签名\n\n正楷姓名及职务\n\n送达人的地址\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 条 (c)、(d)、(e) 及 (g) 款（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交易地点 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交易所在州内，条件是该人\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。传票可以命令：\n\n(A) 在该人居住、受雇或经常亲自从事商业交易地点 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该场所。\n\n(d) 保护受传票约束的人；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，避免对受传票约束的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，无须亲自到提交或检查地点出席，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被命令人的情况下，向要求履行的地区法院申请作出强制提交或检查的命令。\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具有下列情形的传票：\n\n(i) 未给予合理履行时间；(ii) 要求某人在超出第 45 条 (c) 款规定的地域限制之外履行；(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) 披露未经聘用专家的意见或信息，该意见或信息并非描述争议中的具体事件，且源于未经当事人要求进行的该专家研究。\n\n(C) 以规定条件作为替代办法。在第 45 条 (d)(3)(B) 款所述情形下，如送达方：\n\n(i) 证明其对该证言或材料有重大需要，且不遭受不当困难即无法通过其他方式满足该需要；以及\n\n(ii) 确保受传票人将获得合理补偿，\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) 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。回应要求提交文件之传票的人，必须按照文件在日常业务中保存的方式提交，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，回应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) 无法合理电子访问的存储信息。作出回应的人无需提供其认定因不当负担或费用而无法合理访问之来源中的电子存储信息的证据开示。在请求强制证据开示的动议或申请保护令的动议中，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。若作出该证明，法院仍可在提出请求的一方考虑到第 26(b)(2)(C) 条的限制并证明具有正当理由时，命令从该等来源进行证据开示。法院可以就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。依据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：\n\n(i) 明确提出该主张；以及\n\n(ii) 以一种不会披露本身享有特权或受保护信息的方式，描述被扣留文件、通信或有形物的性质，以使各方能够评估该主张。\n\n(B) 已提供的信息。如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任何收到该信息的一方。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；如该方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——可以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，裁定其藐视法庭。\n\n有关传票材料的获取，请参见 Fed. R. Civ. P. 45(a) Committee Note (2013)\n\n……\n\n附件 C-19\n\nB2540（表格 2540——Rule 2004 审查传票）（12/15）UNITED STATES BANKRUPTCY COURT（美国破产法院） Case 22-50073 Doc 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 379 of 491\n\n____________________________________________________________ District of ____________________________________________________________ Connecticut（康涅狄格地区）\n\n关于 ____________________________________________________________\n\n案件编号 ______________________________ Ho Wan Kwok（郭文贵）22-50073\n\n债务人\n\n章程 __________________ 11\n\nRULE 2004 审查传票\n\n致：________________________________________________________________________________________________ Barclays Bank PLC（巴克莱银行公众有限公司）\n\n（传票所指向之人的姓名）\n\n证言：特此命令你于下列规定的时间、日期及地点出席，就《联邦破产程序规则》Rule 2004 下的审查作证。随附授权该审查的法院命令副本。X\n\n地点\n\nNEUBERT, PEPE & MONTEITH, P.C.（纽伯特、佩佩与蒙泰思专业公司） 日期和时间\n\n195 Church Street, 13th Floor\n\nNew Haven, Connecticut 06510\n\n审查将采用以下方式记录：________________________________________________________________________________ 法庭记录员／速记员\n\n提交材料：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，并必须允许对该等材料进行检查、复制、测试或抽样：X\n\n见随附的文件提交请求。\n\n以下 Fed. R. Civ. P. 45 的规定，依 Fed. R. Bankr. P. 9016 适用于破产案件，现随附——有关履行地点的 Rule 45(c)；有关作为传票对象之人的保护的 Rule 45(d)；以及有关你回应本传票的义务和不回应的潜在后果的 Rule 45(e) 和 45(g)。\n\n日期：____________________ September __, 2022\n\n法院书记员\n\n或\n\n____________________________ 法院书记员或副书记员签名 ____________________________ 律师签名 Patrick R. Linsey（帕特里克·R·林赛）(ct29437)\n\n代表（当事人姓名）________________________________________、发出或请求本传票的律师姓名、地址、电子邮件地址和电话号码如下：Luc Despins（吕克·德斯潘），第 11 章受托人\n\nPatrick R. Linsey, Esq.; Neubert, Pepe & Monteith, P.C.; 195 Church Street, 13th Floor, New Haven, Connecticut 06510 plinsey@npmlaw.com; (203) 821-2000\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，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及本传票副本。Fed. R. Civ. P. 45(a)(4)。\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。每项请求均应得到完整答复，除非出于善意提出异议；在此情况下，应按照下文规定详细说明你提出异议的理由。如异议仅涉及某项请求的一部分，或其中包含的某个词、短语或条款，你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。每个文件夹内的 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。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。如文件包括图像化电子邮件及附件，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，必须包含 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；数据库中的每一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。文本必须作为独立文本文件提交，而不得作为 .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，每个文件夹内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。应提供一张带有 Bates 编号的分隔页图像，表明原生文件的存在，并将原生文件的路径作为字段包含在 .dat 文件中。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。对于存在完全重复副本的每份电子文件，提交一份副本。对于电子邮件，应根据从 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，应根据整个文件的 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。下列为所要求的元数据：\n\nCase 22-50073 Doc 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 382 of 491\n\n字段名称 示例数据 说明\n\n首贝茨编号 EDC0000001 原生文件文档/电子邮件的首个贝茨编号\n末贝茨编号 EDC0000001 原生文件文档/电子邮件的最后一个贝茨编号\n末贝茨编号字段应予填写\n适用于单页文件\n附件范围 EDC0000001\n- 母文档首页的贝茨编号\nEDC0000015 至最后一个附件“子”文档最后一页的贝茨编号\n附件起始 EDC0000001 附件范围的首个贝茨编号\n附件结束 EDC0000015 附件范围的最后一个贝茨编号\n保管人 Smith, John 电子邮件：电子邮件所在的邮箱\n原生文件：文档来源的个人或部门名称\n发件人 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收件人 Coffman, Janice; LeeW 收件人\n[mailto:LeeW@MSN.com] 多个条目应以分号分隔\n抄送 Frank Thompson [mailto: 抄送收件人\nfrank_Thompson@cdt.com] 多个条目应以分号分隔\n密送 John Cain 密送收件人\n多个条目应以分号分隔\n主题 Board Meeting Minutes 电子邮件：电子邮件主题行；原生文件：文档标题（如有）\n文件名 BoardMeetingMinutes.docx 原生文件：原始原生文件名称，包括扩展名\n发送日期 10/12/2010 电子邮件：电子邮件发送日期\n原生文件：（空）\n发送时间/\n时区 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\n时区 GMT 转换过程中电子邮件被标准化所使用的时区。\n链接 EDC0000001.msg 指向电子邮件或原生文件文档的超链接\n链接文件必须按首贝茨编号命名\n文件扩展名 MSG 表示电子邮件或原生文件的文件类型扩展名\n作者 John Smith 电子邮件：（空）\n原生文件：文档作者\n创建日期 10/10/2010 电子邮件：（空）\n原生文件：文档创建日期\n案件 22-50073 文书 839 于 09/07/22 提交 于 09/07/22 20:02:47 登记 第 383 页，共 491 页\n\n创建时间 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，不得与创建日期字段合并\n修改日期 10/12/2010 电子邮件：（空）\n原生文件：文档最后修改日期\n修改时间 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，不得与修改日期字段合并\n访问日期 10/12/2010 电子邮件：（空）\n\n原生文件：文档最后访问日期\n访问时间 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，不得与访问日期字段合并\n文件大小 5,952 原生文件文档/电子邮件的大小，以 KB 计\n页数 1 原生文件文档/电子邮件中的页数\n路径 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。\n内部文件路径 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）\n内部消息 ID <000805c2c71b\\$75977050\\$ 电子邮件：唯一消息 ID；原生文件：（空）\ncb8306d1@MSN>\nMD5 哈希值 d131dd02c5e6eec4693d9a0 文档的 MD5 哈希值。\n698aff95c\n2fcab58712467eab4004583e\nb8fb7f89\nOCR 路径 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. 所有文件应按其在通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. 本文所载各项请求延及以下所有文件：(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案件 22-50073 文书 839 于 09/07/22 提交 于 09/07/22 20:02:47 登记 第 384 页，共 491 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的人员（及如适用，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) 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相关事实和情形；(f) 确认授权该等处置的人员；(g) 确认该等处置的日期或约略日期；(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) 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，则确认该等人员的身份，\n案件 22-50073 文书 839 于 09/07/22 提交 于 09/07/22 20:02:47 登记 第 385 页，共 491 页\n\n并说明该等信息如何由其取得，(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)，就基于特权主张而被扣留的每份文件，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，应完整提供相关文件。\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。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新增文件。\n\n11. 如文件以英语以外的语言写成，贵方应提供该文件。如文件以英语以外的语言写成，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全部关联方。\n\n13. 对个人姓名的所有提及均包括所有替代名称、别名或昵称。\n案件 22-50073 文书 839 于 09/07/22 提交 于 09/07/22 20:02:47 登记 第 386 页，共 491 页\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) 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在所有其他时态中使用该动词。\n\n16. (a) “和”与“或”应按必要情况解释为连词或选择连词，以使本应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) “每一”与“任何”应被视为包括并涵盖“每个”和“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. “贵方”或“贵方的”或“贵方本人”系指 Barclays Bank PLC（巴克莱银行公共有限公司），连同其任何关联方、母公司及子公司，以及其任何雇员、代理人、律师、顾问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），连同其雇员、代理人、律师、顾问或代表其行事的任何人。\n案件 22-50073 文书 839 于 09/07/22 提交 于 09/07/22 20:02:47 登记 第 387 页，共 491 页\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），连同其雇员、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、顾问或代表其行事的任何人。\n\n6. “债务人家属”系指单独及共同的债务人、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的人。\n\n7. “2004 取证对象”系指单独及共同的债务人、债务人家属、ACA Capital Group Limited、Himalaya International Financial Group Ltd.、Himalaya International Clearing Ltd.、Himalaya International Payments Ltd.、Himalaya International Reserves Ltd.、Jesse Brown、William Je、William Je、Eastern Profit Corporation Limited、HK International Funds Investments (USA) Limited LLC、Bravo Luck Limited、Golden Spring (New York) Ltd.、Lamp Capital LLC、Greenwich Land LLC、Qu Guo Jiao、Daniel Thomas Podhaskie、Yvette Wang、Ace Decade Holdings Limited、Dawn State Limited、Rule of Law Society IV Inc.、Rule of Law Foundation III、GTV Media Group, Inc.、Voice of Guo Media, Inc. 及 Saraca Media Group Inc.\n\n8. “关联个人”系指单独及共同的所有下列个人：(1) 持有、控制、保管债务人或债务人家属所拥有、控制或享有的资产，或对该等资产拥有酌处权；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、\n案件 22-50073 文书 839 于 09/07/22 提交 于 09/07/22 20:02:47 登记 第 388 页，共 491 页\n\n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：Daniel Podhaskie、Jason Miller、Jesse Brown、William Je、Steve Bannon、Karin Maistrello、Melissa Francis、William Gertz、Arethusa Forsyth、Glenn Mellor、Jennifer Mercurio、Eduardo Eurnekian、Han Chunguang（韩春光）（又名 韩春光）、Qu Guojiao（屈国姣）（又名 Qu Guo Jiao、屈国姣）、Guo Lijie（郭丽杰）（又名 郭丽杰）、Zhang Wei（张伟）（又名 张伟\\*）、Lihong Wei Lafrenz（魏丽红）（又名 Sara Wei、魏丽红）、Hao Haidong（郝海东）（又名 郝海东）、Ross Heinemeyer、Max Krasner、Kyle Bass、Melissa Mendez、Ya Li（李娅）（又名 李娅）、Dinggang Wang（王定刚）（又名 王定刚）、An Hong（安红）（又名 安红）、Yvette Wang（王雁平）（又名 Yanping Wang、Yan Ping Wang、王雁平）、Fiona Yu、Je Kin Ming（余建明）（又名 William Je、Yu Jianming、余建明）、Yaz Qingua 及 Lao Jiang（姜云浮）（又名 Jiang Yunfu、Jiang Yunfu Be、姜云浮）。\n\n9. “关联实体”系指单独及共同符合下列任一情形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士。该等关联实体包括但不限于：7 Nod Hill LLC（7诺德山有限责任公司）、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（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）、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（阿尔卑斯受托人股份公司）、Anton Development Limited（安东发展有限公司）、Assets Sino Limited（华资有限公司）、Auspicious Coast Limited（吉祥海岸有限公司）、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（北京鼎盛控股有限公司）、Bravo Luck Limited（好运有限公司）、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）、\n\n案号 22-50073 文书 839 提交日期 09/07/22 登记日期 09/07/22 20:02:47 第 389 页，共 491 页\n\nDawn State Limited（黎明州有限公司）、Eastern Profit Corporation Limited（东方利润有限公司）、Elite Well Global Limited（精英环球有限公司）、Empire Growth Holdings（帝国增长控股）、G Club Operations LLC（G俱乐部运营有限责任公司）、G Fashion LLC（G时尚有限责任公司）、G News LLC（G新闻有限责任公司）、GETTR USA（GETTR美国）、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（全球主义者国际有限公司）、GNews Media Group Inc.（GNews媒体集团公司）、Golden Spring (New York) Ltd.（金泉〔纽约〕有限公司）、Greenwich Land LLC（格林尼治土地有限责任公司）、Guo Media（郭媒体）、GTV Media Group, Inc.（GTV媒体集团公司）、Hamilton Capital Holdings Inc.（汉密尔顿资本控股公司）、Head Win Group Limited（领先胜利集团有限公司）、Henan Yuda（河南裕达）、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 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 Supervisory Organization（喜马拉雅监管组织）、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）、Hudson Diamond NY LLC（哈德逊钻石纽约有限责任公司）、Infinite Increase Limited（无限增长有限公司）、Infinitum Developments Limited（无限发展有限公司）、Insight Phoenix Fund（洞察凤凰基金）、Lamp Capital LLC（灯塔资本有限责任公司）、Leading Shine Limited（领先光辉有限公司）、Leading Shine NY Limited（领先光辉纽约有限公司）、Long Gate Limited（长龙门有限公司）、Next Tycoon Investments Limited（下一大亨投资有限公司）、New Federal State of China (a/k/a NFSC)（中国新联邦国，亦称NFSC）、Noble Fame Global Limited（高贵声誉全球有限公司）、Rosy Acme Ventures Limited（玫瑰顶峰创投有限公司）、Rule of Law Foundation III, Inc.（法治基金会III公司）、Rule of Law Foundation IV, Inc.（法治基金会IV公司）、Rule of Law Fund（法治基金）、Rule of Law Society（法治协会）、Rule of Law Society IV, Inc.（法治协会IV公司）、G-Translators PTY LTD（G-译者私人有限公司）、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）、Spirit Charter Investment Limited（精神宪章投资有限公司）、Stevenson, Wong & Co.（史蒂文森、黄氏事务所）、TM Primrose Limited（TM报春花有限公司）、Voice of Guo Media, Inc.（郭媒体之声公司）、Well Origin Ltd.（良好起源有限公司）、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）、Whitecroft Shore Limited（怀特克罗夫特海岸有限公司）及 ZIBA Limited（ZIBA有限公司）。\n\n10. “包括”或其任何变体，系指“包括但不限于”。\n\n11. “和”及“或”系指“和/或”，并应同时按照连词及选择连词解释，以最大限度扩大其范围。\n\n12. “任何”及“所有”以及“每一”系指“每一个和全部”。\n\n13. “每一”及“每个”系指“每一个和全部”。\n\n案号 22-50073 文书 839 提交日期 09/07/22 登记日期 09/07/22 20:02:47 第 390 页，共 491 页\n\n14. “第三方”系指除您本人以外的个人或实体。\n\n15. “转让”应具有《破产法典》第 101(54) 条赋予其的含义。\n\n16. “文件”系指属于 Fed. R. Civ. P. 34 规定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、保管或控制之下的任何种类、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、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、持仓报告、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、胶片、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，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，如其包含原始文件中不存在的任何种类笔记、评论或标记，或者其在其他方面与原始文件不相同。\n\n17. “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”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\n案号 22-50073 文书 839 提交日期 09/07/22 登记日期 09/07/22 20:02:47 第 391 页，共 491 页\n\n18. “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\n19. “关于”系指涉及、描述、构成、提及、与之相关、支持、赞成、反对、强化、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、构成及属于。\n\n20. “与……有关”、“涉及”或“相关”，在提及任何特定事项时，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事项相关的任何文件。\n\n21. “通信”系指以最广泛的可能意义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）。通信还指所有当面、电话、书面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、即时消息、聊天信息、短信、发布至留言板或群聊的信息、社交媒体帖子、推文、上传至任何视频平台的视频、电话笔记或内部传送或与第三方传送的笔记。\n\n案号 22-50073 文书 839 提交日期 09/07/22 登记日期 09/07/22 20:02:47 第 392 页，共 491 页\n\n22. “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. 所有日期在 January 1, 2014 至今期间、与由任何 2004 Discovery Targets（2004取证对象）持有、控制、代为持有或以其他方式与其相关的任何账户有关的文件，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、通信函件以及电汇和相关通信函件及指示。\n\n2. 所有日期在 January 1, 2014 至今期间、与属于任何 2004 Discovery Targets、由其持有、控制、代为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、通信函件以及电汇和相关通信函件及指示。\n\n3. 所有日期在 January 1, 2014 至今期间、与同任何 2004 Discovery Targets 进行的任何商业、贸易或金融交易有关的文件，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，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、通信函件以及电汇和相关通信函件及指示。\n\n案号 22-50073 文书 839 提交日期 09/07/22 登记日期 09/07/22 20:02:47 第 393 页，共 491 页\n\n4. 所有日期在 January 1, 2014 至今期间、与涉及 2004 Discovery Targets 的任何电汇活动有关的文件，无论是否存在任何账户，包括但不限于所有电汇收据、账户号码、余额、授权书、与转账各方有关的身份识别信息、通信函件、指示或其他记录。\n\n5. 所有日期在 January 1, 2014 至今期间、与您和 2004 Discovery Targets 之间的任何函件和通信有关的文件。\n\n6. 所有日期在 January 1, 2014 至今期间、与在任何 2004 Discovery Target 开立的任何账户有关，且涉及该账户开立、该账户授权用户及该账户维护的文件。\n\n7. 所有日期在 January 1, 2014 至今期间、与涉及任何 2004 Discovery Targets 的任何反洗钱、了解你的客户或其他合规活动有关的文件，包括但不限于任何 2004 Discovery Targets 提供的或您获知的任何信息。\n\n8. 所有日期在 January 1, 2014 至今期间、与就任何 2004 Discovery Targets 同任何国家的任何监管机构进行的任何通信有关的文件，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证物 C-20\n\nB2540（表格2540－Rule 2004 审查传票）（12/15）美国破产法院 案号 22-50073 文书 839 提交日期 09/07/22 登记日期 09/07/22 20:02:47 第 395 页，共 491 页\n\n____________________________________________________________ 区，Connecticut（康涅狄格州）\n\n关于 ____________________________________________________________\n\n案号 ______________________________ Ho Wan Kwok（郭文贵）22-50073\n\n债务人\n\n章节 ____________________ 11\n\nRule 2004 审查传票\n\n致：________________________________________________________________________________________________ BNY Mellon, N.A.（纽约梅隆银行，全国协会）\n\n（传票所指向人员的姓名）\n\n证言：兹命令您于下文载明的时间、日期和地点到场，在依据《联邦破产程序规则》Rule 2004 进行的审查中作证。随附授权该审查的法院命令副本。X\n\n地点 日期和时间\n\nNEUBERT, PEPE & MONTEITH, P.C.（纽伯特、佩佩及蒙蒂思律师事务所）\n\n195 Church Street, 13th Floor\n\nNew Haven, Connecticut 06510\n\n审查将采用以下方式记录：____________________________________________________________ 法庭记录员/速记员\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：X\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，依据《联邦破产程序规则》第 9016 条适用于破产案件，现随附——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，关于您对本传票的回应义务及不履行该义务的潜在后果。\n\n日期：__________________ September __, 2022\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 Patrick R. Linsey（帕特里克·R·林西）(ct29437)\n\n签发或请求本传票的代理（当事人名称）_________________________的律师的姓名、地址、电子邮件地址和电话号码如下：Luc Despins（吕克·德斯潘），第 11 章受托人\n\nPatrick R. Linsey（帕特里克·R·林西）, Esq.; Neubert, Pepe & Monteith, P.C.（纽伯特、佩佩与蒙蒂思律师事务所，P.C.）；195 Church Street, 13th Floor, New Haven, Connecticut 06510 plinsey@npmlaw.com; (203) 821-2000\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。《联邦民事诉讼规则》第 45(a)(4) 条。\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”，每项单称“一项请求”）必须分别且具体地予以答复。除非善意提出异议，否则每项请求均应完整答复；如提出异议，则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，或其中包含的一个词、短语或条款，您仅须说明对该部分的异议，并答复请求的其余部分。\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。文件名不得含有嵌入式空格或特殊字符（包括逗号）。文件夹名称不得含有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\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）。日期字段应以如下格式提供：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，数据库中的每幅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,PageCount。\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。至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，且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）。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。请提供一张带有 Bates 编号的分隔页图像，注明原生文件的存在，并在 .dat 文件中将原生文件路径作为字段列明。所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。将原生文件归类至依次命名的“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，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 标准的加载文件（.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。日期和时间字段必须为两个单独字段。下列为必需元数据：\nCase 22-50073 Doc 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 398 of 491\n\n字段名称 样本数据 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\nLASTBATES 字段应针对单页文件填写\n\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\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：文件来源个人或部门的名称\n\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\n\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\n\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\n\nBCC John Cain 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：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/电子邮件标准化所用时区\n\nTIME_ZONE GMT 在转换过程中电子邮件被标准化所用的时区。\n\nLINK EDC0000001.msg 至电子邮件或原生文件文件的超链接\n所链接文件必须以 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 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 399 of 491\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\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该数据必须为单独字段，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：最后访问该文件的日期\n\nTIME_ACCESSD 07:00 PM 电子邮件：（空）\n原生文件：最后访问该文件的时间\n该数据必须为单独字段，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，以 KB 计\n\nPGCOUNT 1 原生文件文件/电子邮件的页数\n\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。\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：唯一消息 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. 每项请求独立适用且应独立解释；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日常业务过程中保存的方式提交，或者应予整理和标注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 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 400 of 491\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交。\n\n6. 如要求您提交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) 识别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) 识别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交他人，或 (iv) 以其他方式被处置；(e) 说明该等处置的理由及相关事实和情况；(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. 如果要求您提交已被销毁的文书，则您的答复除须载明前述指示所要求的信息外，还必须说明：(a) 该文书被销毁的原因；(b) 销毁该文书之人的身份；以及 (c) 指示销毁该文书之人的身份。\n\n8. 如果您主张被请求的文书受特权保护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书受特权保护之主张的文书描述，(ii) 该文书的标题，(iii) 该文书的日期，(iv) 该文书的作者，(v) 该文书的收件人，(vi) 收到或见过该文书原件或任何草稿、副本或复制件的每一人的身份，(vii) 该文书本身，或该文书中包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，以及说明该信息如何进入其占有范围，(viii) 据以扣留该文书的特权主张，以及 (ix) 您将据以支持该特权主张的所有情形；以及 (b) 就根据 D. Conn. L. Civ. R. 26(e) 基于特权主张而扣留的每一份文书，制作一份特权清单，载明本指示第 (a) 部分所要求的全部信息。对于文书请求中未提出特权或工作成果主张的任何部分，应完整提供相关文书。\n\n9. 如果一份本应提交的文书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书中删除或遮蔽受特权主张约束的该部分，其余部分应予提交。\n\n10. 该等请求具有持续性。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) 提交根据下述规定所要求的任何补充文书。\n\n11. 如果文书使用英语以外的语言，您应提供该文书。如果文书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书。\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所有其他姓名、别名或昵称。\n\n14. 除非另有明确说明，文书请求所涵盖的期间为自 February 5, 2012 起至文书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) “and”和“or”应视为必要时作合取或析取解释，以便将原本可能被解释为不属于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) 所规定的定义及 D. Conn. L. Civ. R. 26(d) 所规定的解释规则，适用于该等文书请求。此外，本等文书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 BNY Mellon, N.A.（纽约梅隆银行），连同其任何关联方、母公司和子公司，以及上述各方的任何雇员、代理人、律师、顾问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（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之人。\n\n3. “Debtor's Son”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之人。\n\n4. “Debtor's Daughter”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之人。\n\n5. “Debtor's Purported Wife”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之人。\n\n6. “Debtor's Family”单独及合并系指债务人、债务人之子、债务人之女和债务人所谓的妻子，以及与债务人有任何其他亲属关系之人。\n\n7. “2004 Discovery Targets”单独及合并系指债务人、债务人家庭、ACA Capital Group Limited（ACA资本集团有限公司）、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）、Jesse Brown（杰西·布朗）、William Je（余建明）、William Je（余建明）、Eastern Profit Corporation Limited（东方利润有限公司）、HK International Funds Investments (USA) Limited LLC（香港国际基金投资〈美国〉有限责任公司）、Bravo Luck Limited（鸿运有限公司）、Golden Spring (New York) Ltd.（金泉〈纽约〉有限公司）、Lamp Capital LLC（灯资本有限责任公司）、Greenwich Land LLC（格林尼治土地有限责任公司）、Qu Guo Jiao（屈国姣）、Daniel Thomas Podhaskie（丹尼尔·托马斯·波达斯基）、Yvette Wang（王雁平）、Ace Decade Holdings Limited（王牌十年控股有限公司）、Dawn State Limited（黎明州有限公司）、Rule of Law Society IV Inc.（法治协会IV公司）、Rule of Law Foundation III（法治基金会III）、GTV Media Group, Inc.（GTV媒体集团公司）、Voice of Guo Media, Inc.（郭媒体之声公司）以及 Saraca Media Group Inc.（萨拉卡媒体集团公司）。\n\n8. “Associated Individuals”单独及合并系指以下所有个人：(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酌处权之人；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之人，连同上述各方各自的雇员、代理人、律师、顾问或任何代表上述任何一方行事之人。该等关联个人包括但不限于：Daniel Podhaskie（丹尼尔·波达斯基）、Jason Miller（贾森·米勒）、Jesse Brown（杰西·布朗）、William Je（余建明）、Steve Bannon（史蒂夫·班农）、Karin Maistrello（卡琳·迈斯特雷洛）、Melissa Francis（梅利莎·弗朗西斯）、William Gertz（威廉·格茨）、Arethusa Forsyth（阿瑞苏莎·福赛思）、Glenn Mellor（格伦·梅勒）、Jennifer Mercurio（珍妮弗·默库里奥）、Eduardo Eurnekian（爱德华多·埃尔内基安）、Han Chunguang（韩春光）（又名 韩春光）、Qu Guojiao（屈国姣）（又名 Qu Guo Jiao（屈国姣）、屈国姣）、Guo Lijie（郭丽杰）（又名 郭丽杰）、Zhang Wei（张伟）（又名 张伟）、Lihong Wei Lafrenz（魏丽红）（又名 Sara Wei（魏丽红）、魏丽红）、Hao Haidong（郝海东）（又名 郝海东）、Ross Heinemeyer（罗斯·海内迈耶）、Max Krasner（马克斯·克拉斯纳）、Kyle Bass（凯尔·巴斯）、Melissa Mendez（梅利莎·门德斯）、Ya Li（李娅）（又名 李娅）、Dinggang Wang（王定刚）（又名 王定刚）、An Hong（安红）（又名 安红）、Yvette Wang（王雁平）（又名 Yanping Wang（王雁平）、Yan Ping Wang（王雁平）、王雁平）、Fiona Yu（菲奥娜·余）、Je Kin Ming（余建明）（又名 William Je（余建明）、Yu Jianming（余建明）、余建明）、Yaz Qingua（亚兹·青瓜）以及 Lao Jiang（姜云浮）（又名 Jiang Yunfu（姜云浮）、Jiang Yunfu Be（姜云浮）、姜云浮）。\n\n9. “Associated Entities”单独及合并系指以下任何类型的所有组织或实体：(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，连同上述各方各自的雇员、代理人、律师、顾问或任何代表上述任何一方行事之人。该等关联实体包括但不限于：7 Nod Hill LLC（七诺德山有限责任公司）、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（阿尔卑斯受托人股份公司）、Anton Development Limited（安东开发有限公司）、Assets Sino Limited（中资资产有限公司）、Auspicious Coast Limited（吉祥海岸有限公司）、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（北京鼎峰控股有限公司）、Bravo Luck Limited（鸿运有限公司）、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）、Elite Well Global Limited（精英环球有限公司）、Empire Growth Holdings（帝国增长控股）、G Club Operations LLC（G俱乐部运营有限责任公司）、G Fashion LLC（G时尚有限责任公司）、G News LLC（G新闻有限责任公司）、GETTR USA（GETTR美国）、Genever Holdings Corporation（吉尼弗控股公司）、Genever Holdings LLC（吉尼弗控股有限责任公司）、GFASHION MEDIA GROUP INC.（GFASHION媒体集团公司）、GFNY, Inc.（GFNY公司）、Globalist International Limited（全球主义者国际有限公司）、GNews Media Group Inc.（GNews媒体集团公司）、Golden Spring (New York) Ltd.（金泉〈纽约〉有限公司）、Greenwich Land LLC（格林尼治土地有限责任公司）、Guo Media（郭媒体）、GTV Media Group, Inc.（GTV媒体集团公司）、Hamilton Capital Holdings Inc.（汉密尔顿资本控股公司）、Head Win Group Limited（领赢集团有限公司）、Henan Yuda（河南裕达）、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 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 Supervisory Organization（喜马拉雅监督组织）、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）、Hudson Diamond NY LLC（哈德逊钻石纽约有限责任公司）、Infinite Increase Limited（无限增长有限公司）、Infinitum Developments Limited（无限开发有限公司）、Insight Phoenix Fund（洞察凤凰基金）、Lamp Capital LLC（灯资本有限责任公司）、Leading Shine Limited（领耀有限公司）、Leading Shine NY Limited（领耀纽约有限公司）、Long Gate Limited（长龙门有限公司）、Next Tycoon Investments Limited（下一巨富投资有限公司）、New Federal State of China（中国新联邦国）（又名 NFSC）、Noble Fame Global Limited（尊誉环球有限公司）、Rosy Acme Ventures Limited（蔷薇顶峰创投有限公司）、Rule of Law Foundation III, Inc.（法治基金会III公司）、Rule of Law Foundation IV, Inc.（法治基金会IV公司）、Rule of Law Fund（法治基金）、Rule of Law Society（法治协会）、Rule of Law Society IV, Inc.（法治协会IV公司）、G-Translators PTY LTD（G-翻译员有限公司）、Saraca Media Group, Inc.（萨拉卡媒体集团公司）、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）、Spirit Charter Investment Limited（精神宪章投资有限公司）、Stevenson, Wong & Co.（史蒂文森、黄合伙公司）、TM Primrose Limited（TM报春花有限公司）、Voice of Guo Media, Inc.（郭媒体之声公司）、Well Origin Ltd.（良好起源有限公司）、World Century Limited（世界世纪有限公司）、Worldwide Opportunity Holdings Limited（全球机遇控股有限公司）、Whitecroft Shore Limited（白克罗夫特海岸有限公司）以及 ZIBA Limited（ZIBA有限公司）。\n\n10. “Including”或其任何变体，系指“包括但不限于”。\n\n11. “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\n12. “Any”、“all”和“each”系指“每一及全部”。\n\n13. “Each”和“every”系指“每一及全部”。\n\n14. “Third Party”系指您本人以外的个人或实体。\n\n15. “Transfer”具有《破产法典》第 101(54) 条赋予该术语的含义。\n\n16. “文件”系指属于 Fed. R. Civ. P. 34 范围内的任何信息或物品，并且包括但不限于每一项及全部任何种类、类型、性质或描述的书面、记录或图示资料，该等资料现由或曾由贵方占有、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、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、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、日程表、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文件的草稿或副本，如其中包含原始文件中未有的任何种类笔记、评论或标记，或在其他方面与原始文件不相同。\n\n17. “人士”系指个人、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。\nCase 22-50073 Doc 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 407 of 491\n\n18. “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\n19. “关于”系指涉及、描述、包含、提及、与之有关、支持、有利于、反对、加强、减损、载于、结合考虑、对其有影响、证明、表明、报告、记录、暗指、回应、与之联系、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\n20. 就任何特定事项而言，“与……有关”“有关”或“相关”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\n21. “通信”系指以最广泛可能的含义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）。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、电话笔记，或在内部或与第三方传送的笔记。\nCase 22-50073 Doc 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 408 of 491\n\n22. “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、产权公寓、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. 所有日期在 January 1, 2014 至今之间、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有关的账户相关的文件，包括任何及所有账户对账单、授权书、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. 所有日期在 January 1, 2014 至今之间、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有关的任何资金、证券、财产或资产相关的文件，包括任何及所有账户对账单、授权书、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. 所有日期在 January 1, 2014 至今之间、与和任何 2004 调查对象进行的任何商业、贸易或金融交易有关的文件，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，包括任何及所有账户对账单、授权书、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。\nCase 22-50073 Doc 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 409 of 491\n\n4. 所有日期在 January 1, 2014 至今之间、与任何涉及 2004 调查对象的电汇活动有关的文件，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、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. 所有日期在 January 1, 2014 至今之间、与贵方和 2004 调查对象之间的任何函件及通信有关的文件。\n\n6. 所有日期在 January 1, 2014 至今之间、与任何 2004 调查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文件。\n\n7. 所有日期在 January 1, 2014 至今之间、与任何涉及 2004 调查对象的反洗钱、了解你的客户或其他合规活动有关的文件，包括但不限于任何 2004 调查对象提供的信息，或贵方获知的信息。\n\n8. 所有日期在 January 1, 2014 至今之间、与任何国家的任何监管机构进行的、涉及任何 2004 调查对象的通信有关的文件，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-21\nB2540（表格 2540－Rule 2004 审查传票）（12/15）UNITED STATES BANKRUPTCY COURT（美国破产法院）Case 22-50073 Doc 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 411 of 491\n\n_______________________________________________________ Connecticut（康涅狄格州）地区\n\n关于 _______________________________________________________\n\n案号 __________________________________________________ Ho Wan Kwok（郭文贵）22-50073\n\n债务人\n\n第 ______________ 11 章\nRule 2004 审查传票\n\n致：________________________________________________________________________________________________ Citibank, N.A.（花旗银行，全国协会）\n\n（传票所指向人士的姓名）\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，并在依照《联邦破产程序规则》Rule 2004 进行的审查中作证。随附授权该审查的法院命令副本。X\n\n地点 日期和时间\n\nNEUBERT, PEPE & MONTEITH, P.C.\n195 Church Street, 13th Floor\nNew Haven, Connecticut 06510\n\n审查将以以下方式记录：________________________________________________________________________________ 法院记录员／速记员\n\n提交：贵方或贵方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，并且必须允许对该等材料进行检查、复制、测试或取样：X\n见随附的文件提交请求。\n\n下列 Fed. R. Civ. P. 45 条款依据 Fed. R. Bankr. P. 9016 适用于破产案件，并随附于此——Rule 45(c)，关于履行地点；Rule 45(d)，关于作为受传票约束人士的贵方保护；以及 Rule 45(e) 和 45(g)，关于贵方对本传票作出回应的义务及未作出回应的潜在后果。\n\n日期：__________________ September __, 2022\n\n法院书记官\n\n或\n\n____________________________ 法院书记官或副书记官签名 ____________________________ 律师签名 Patrick R. Linsey（ct29437）\n\n签发或请求本传票的（当事人姓名）____________________________ 的代理律师的姓名、地址、电子邮件地址和电话号码为：Luc Despins（第 11 章受托人）\n\nPatrick R. Linsey, Esq.; Neubert, Pepe & Monteith, P.C.; 195 Church Street, 13th Floor, New Haven, Connecticut 06510 plinsey@npmlaw.com; (203) 821-2000\n\n致签发或请求本传票人士的通知\n\n如本传票命令在审判前提交文件、以电子方式存储的信息或有形物品，或检查场所，则必须在向本传票所指向人士送达之前，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文件提交请求\n\nI. 指示\n\n1. 除非另有说明，下列文件请求（“请求”，每一项均为“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，否则每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，或其中所含的一个词语、短语或条款，贵方仅须说明对该部分的异议，并对其余请求作出答复。\n\n2. 以电子方式存储的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。日期字段与时间字段必须为两个单独的字段。如文件包括已制作为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。其应为以逗号分隔的文件，每行由七个字段组成；数据库中的每一图像均应在交叉引用文件中具有一行，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包括在内。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。原生文件应归入名称依次递增的“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一电子文件，仅提供一份副本。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 的加载文件（.dat）形式，为每一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日期字段应采用以下格式提供：mm/dd/yyyy。日期字段与时间字段必须为两个单独的字段。以下列出所需元数据：\n\n案件 22-50073 文件 839 提交于 09/07/22 录入于 09/07/22 20:02:47 第 414 页，共 491 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 字段应针对单页予以填充\n\nATTACHRANGE EDC0000001\n- 父文件第一页的 Bates 编号至最后一份附件“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：文件来源个人或部门的名称\n\nFROM John Smith（约翰·史密斯） 电子邮件：发件人\n原生：文件作者\n多个条目之间应使用分号分隔\n\nTO Coffman, Janice（贾尼斯·科夫曼）; LeeW（李W）\n[mailto:LeeW@MSN.com] 收件人\n多个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：文件标题（如有）\n\nFILE_NAME BoardMeetingMinutes.docx 原生：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\n原生：（空）\n\nTIME_SENT/\nTIME_ZONE 07:05 PM GMT 电子邮件：电子邮件发送时间/电子邮件经标准化处理所在的时区\n\nTIME_ZONE GMT 在转换过程中电子邮件经标准化处理所在的时区。\n\nLINK EDC0000001.msg 电子邮件或原生文件文件的超链接\n所链接文件必须按 FIRSTBATES 编号命名\n\nFILE_EXTEN MSG 表示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：文件作者\n\nDATE_CREATED 10/10/2010 电子邮件：（空）\n原生：文件创建日期\n\n案件 22-50073 文件 839 提交于 09/07/22 录入于 09/07/22 20:02:47 第 415 页，共 491 页\n\nTIME_CREATED 10:25 AM 电子邮件：（空）\n原生：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\n\nDATE_MOD 10/12/2010 电子邮件：（空）\n原生：文件最后修改日期\n\nTIME_MOD 07:00 PM 电子邮件：（空）\n原生：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\n\nDATE_ACCESSD 10/12/2010 电子邮件：（空）\n原生：文件最后访问日期\n\nTIME_ACCESSD 07:00 PM 电子邮件：（空）\n原生：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\n\nFILE_SIZE 5,952 原生文件文件/电子邮件的大小，以 KB 计\n\nPGCOUNT 1 原生文件文件/电子邮件的页数\n\nPATH 电子邮件：（空）\nAgenda.doc 原生：原生文件文件的存储路径，包括原始文件名称。\n\nINTFILEPATH Personal Folders\\Deleted\nItems\\Board Meeting\nMinutes.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：（空）\n\nINTMSGID <000805c2c71b\\$75977050\\$\ncb8306d1@MSN> 电子邮件：唯一邮件 ID 原生：（空）\n\nMD5HASH d131dd02c5e6eec4693d9a0\n698aff95c\n2fcab58712467eab4004583e\nb8fb7f89 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. 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. 所有文件均应按通常业务过程中保存的方式提供，或应予以组织和标记，以对应本请求中的类别。\n\n5. 本文所载每一项请求均延伸至所有文件：(a) 在您占有、保管或控制之下的文件；或 (b) 在任何代表您行事之人占有、保管或控制之下的文件，\n\n案件 22-50073 文件 839 提交于 09/07/22 录入于 09/07/22 20:02:47 第 416 页，共 491 页\n\n包括您的律师或其他代表及顾问。每一文件均应完整提供。\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，获发送该文件的人员）；(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) 已以其他方式处置；(e) 说明该处置的理由及与其有关的事实和情形；(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身份，(vii) 该文件本身或该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，则确认该等人员身份，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拒绝提供的文件，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。对于文件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件。\n\n案件 22-50073 文件 839 提交于 09/07/22 录入于 09/07/22 20:02:47 第 417 页，共 491 页\n\n9. 如原本具有回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) 提供本请求项下要求提供的任何补充文件。\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. 对实体的一切提述均包括其所有关联方。\n\n13. 对所有个人姓名的提及均包括所有其他名称、别名或昵称。\n\n案件 22-50073 文件 839 提交日期 09/07/22 录入日期 09/07/22 20:02:47 第 418 页，共 491 页\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。\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”应在必要时解释为连词关系或选择关系，以使任何请求的范围涵盖所有本可能被解释为不在其范围内的答复；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. 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，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 Citibank, N.A.（花旗银行，全国协会），连同其任何关联方、母公司和子公司，以及其任何雇员、代理人、律师、顾问，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\n案件 22-50073 文件 839 提交日期 09/07/22 录入日期 09/07/22 20:02:47 第 419 页，共 491 页\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”单独及合称系指债务人、债务人之子、债务人之女和债务人据称的妻子，以及与债务人有任何其他家庭关系的人。\n\n7. “2004 Discovery Targets”单独及合称系指债务人、债务人家属、ACA Capital Group Limited（ACA资本集团有限公司）、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）、Jesse Brown（杰西·布朗）、William Je（余建明）、William Je、Eastern Profit Corporation Limited（东方利润有限公司）、HK International Funds Investments (USA) Limited LLC（香港国际基金投资〈美国〉有限责任公司）、Bravo Luck Limited（鸿运有限公司）、Golden Spring (New York) Ltd.（金泉〈纽约〉有限公司）、Lamp Capital LLC（蓝普资本有限责任公司）、Greenwich Land LLC（格林威治地产有限责任公司）、Qu Guo Jiao（屈国姣）、Daniel Thomas Podhaskie（丹尼尔·托马斯·波德哈斯基）、Yvette Wang（王雁平）、Ace Decade Holdings Limited（王牌十年控股有限公司）、Dawn State Limited（黎明国度有限公司）、Rule of Law Society IV Inc.（法治协会 IV 公司）、Rule of Law Foundation III（法治基金会 III）、GTV Media Group, Inc.（GTV媒体集团公司）、Voice of Guo Media, Inc.（郭之声媒体公司）以及 Saraca Media Group Inc.（萨拉卡媒体集团公司）。\n\n8. “Associated Individuals”单独及合称系指所有以下个人：(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；连同前述各方各自的雇员、代理人、律师、\n\n案件 22-50073 文件 839 提交日期 09/07/22 录入日期 09/07/22 20:02:47 第 420 页，共 491 页\n\n顾问，或任何代表前述任一方行事的人。此类关联个人包括但不限于：Daniel Podhaskie（丹尼尔·波德哈斯基）、Jason Miller（杰森·米勒）、Jesse Brown、William Je、Steve Bannon（史蒂夫·班农）、Karin Maistrello（卡琳·迈斯特雷洛）、Melissa Francis（梅利莎·弗朗西斯）、William Gertz（威廉·格茨）、Arethusa Forsyth（阿瑞图萨·福赛思）、Glenn Mellor（格伦·梅勒）、Jennifer Mercurio（詹妮弗·梅尔库里奥）、Eduardo Eurnekian（爱德华多·厄尔内基安）、Han Chunguang（韩春光）（又名 韩春光）、Qu Guojiao（屈国姣）（又名 Qu Guo Jiao、屈国姣）、Guo Lijie（郭丽杰）（又名 郭丽杰）、Zhang Wei（张伟）（又名 张伟*）、Lihong Wei Lafrenz（魏丽红）（又名 Sara Wei、魏丽红）、Hao Haidong（郝海东）（又名 郝海东）、Ross Heinemeyer（罗斯·海内迈耶）、Max Krasner（马克斯·克拉斯纳）、Kyle Bass（凯尔·巴斯）、Melissa Mendez（梅利莎·门德斯）、Ya Li（李娅）（又名 李娅）、Dinggang Wang（王定刚）（又名 王定刚）、An Hong（安红）（又名 安红）、Yvette Wang（王雁平）（又名 Yanping Wang、Yan Ping Wang、王雁平）、Fiona Yu（菲奥娜·余）、Je Kin Ming（余建明）（又名 William Je、Yu Jianming、余建明）、Yaz Qingua（亚兹·钦瓜）以及 Lao Jiang（姜云浮）（又名 Jiang Yunfu、Jiang Yunfu Be、姜云浮）。\n\n9. “Associated Entities”单独及合称系指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、律师、顾问，或任何代表前述任一方行事的人。此类关联实体包括但不限于：7 Nod Hill LLC（7诺德山有限责任公司）、AAGV Limited（AAGV有限公司）、ACA Investment Management Limited（ACA投资管理有限公司）、ACA Capital Group Limited、Ace Decade Holdings Limited、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（阿尔卑斯信托责任公司）、Anton Development Limited（安东开发有限公司）、Assets Sino Limited（中资资产有限公司）、Auspicious Coast Limited（吉祥海岸有限公司）、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（北京鼎峰控股有限公司）、Bravo Luck Limited、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（克兰咨询集团有限责任公司）、Creative Apex Investments Limited（创意顶峰投资有限公司）、Crystal Breeze Investments Limited（水晶清风投资有限公司）、\n\n案件 22-50073 文件 839 提交日期 09/07/22 录入日期 09/07/22 20:02:47 第 421 页，共 491 页\n\nDawn State Limited、Eastern Profit Corporation Limited、Elite Well Global Limited（精英环球有限公司）、Empire Growth Holdings（帝国增长控股）、G Club Operations LLC（G俱乐部运营有限责任公司）、G Fashion LLC（G时尚有限责任公司）、G News LLC（G新闻有限责任公司）、GETTR USA（GETTR美国）、Genever Holdings Corporation（吉尼弗控股公司）、Genever Holdings LLC（吉尼弗控股有限责任公司）、GFASHION MEDIA GROUP INC.（GFASHION媒体集团公司）、GFNY, Inc.（GFNY公司）、Globalist International Limited（环球主义者国际有限公司）、GNews Media Group Inc.（GNews媒体集团公司）、Golden Spring (New York) Ltd.、Greenwich Land LLC、Guo Media（郭媒体）、GTV Media Group, Inc.、Hamilton Capital Holdings Inc.（汉密尔顿资本控股公司）、Head Win Group Limited（领赢集团有限公司）、Henan Yuda（河南裕达）、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.、Himalaya International Clearing Ltd.、Himalaya International Payments Ltd.、Himalaya International Reserves Ltd.、Himalaya Supervisory Organization（喜马拉雅监督组织）、HK International Funds Investments (USA) Limited LLC、Hong Kong International Funds Investments Limited（香港国际基金投资有限公司）、Hudson Diamond NY LLC（哈德逊钻石纽约有限责任公司）、Infinite Increase Limited（无限增长有限公司）、Infinitum Developments Limited（无限发展有限公司）、Insight Phoenix Fund（洞察凤凰基金）、Lamp Capital LLC、Leading Shine Limited（领耀有限公司）、Leading Shine NY Limited（领耀纽约有限公司）、Long Gate Limited（龙门有限公司）、Next Tycoon Investments Limited（新大亨投资有限公司）、New Federal State of China（中国新联邦国）（又名 NFSC）、Noble Fame Global Limited（名望环球有限公司）、Rosy Acme Ventures Limited（玫瑰顶峰创投有限公司）、Rule of Law Foundation III, Inc.（法治基金会 III 公司）、Rule of Law Foundation IV, Inc.（法治基金会 IV 公司）、Rule of Law Fund（法治基金）、Rule of Law Society（法治协会）、Rule of Law Society IV, Inc.（法治协会 IV 公司）、G-Translators PTY LTD（G-翻译者有限公司）、Saraca Media Group, Inc.（萨拉卡媒体集团公司）、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）、Spirit Charter Investment Limited（精神宪章投资有限公司）、Stevenson, Wong & Co.（史蒂文森、黄氏公司）、TM Primrose Limited（TM报春花有限公司）、Voice of Guo Media, Inc.、Well Origin Ltd.（优源有限公司）、World Century Limited（世界世纪有限公司）、Worldwide Opportunity Holdings Limited（全球机遇控股有限公司）、Whitecroft Shore Limited（怀特克罗夫特海岸有限公司）以及 ZIBA Limited（ZIBA有限公司）。\n\n10. “Including”或其任何变体意为“包括但不限于”。\n\n11. “And”和“or”意为“and/or”，并应同时解释为连词关系及选择关系，以最大限度地扩大其范围。\n\n12. “Any”、“all”和“each”意为“每一及全部”。\n\n13. “Each”和“every”意为“每一及全部”。\n\n案件 22-50073 文件 839 提交日期 09/07/22 录入日期 09/07/22 20:02:47 第 422 页，共 491 页\n\n14. “Third Party”系指除您本人以外的个人或实体。\n\n15. “Transfer”具有《破产法》第 101(54) 条赋予该术语的含义。\n\n16. “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，该等材料现为或曾为您占有、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、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、图形、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、语音消息、发票、订单表格、支票、汇票、对账单、贷项通知单、报告、头寸报告、摘要、索引、账簿、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、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；亦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未载有的任何种类的注释、评论或标记，或在其他方面与原始文件不完全相同。\n\n17. “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\n案件 22-50073 文件 839 提交日期 09/07/22 录入日期 09/07/22 20:02:47 第 423 页，共 491 页\n\n18. “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，包括但不限于律师、财务顾问或任何其他代表。\n\n19. “Regarding”意为有关、描述、构成、提及、与之相关、支持、有利于、反对、加强、减损、位于其中、与之相关地考虑、对其具有影响、证明、表明、报告、记录、暗指、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、构成及为。\n\n20. 当提及任何特定主题事项时，“Relating to”、“relate(s) to”或“related to”意为，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相关的任何文件。\n\n21. “Communication(s)”在最广泛可能的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，还是借助电子传输设备进行，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、语音消息、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\n案件 22-50073 文件 839 提交日期 09/07/22 录入日期 09/07/22 20:02:47 第 424 页，共 491 页\n\n22. “资产”系指任何受占有、保管或控制的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. 所有日期为2014年1月1日至今、与任何2004调查对象所持有、控制、代表其持有或以其他方式与其相关的任何账户有关的文件，包括任何及所有账户结单、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，以及电汇及相关通信函件和指示。\n\n2. 所有日期为2014年1月1日至今、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、财产或资产有关的文件，包括任何及所有账户结单、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，以及电汇及相关通信函件和指示。\n\n3. 所有日期为2014年1月1日至今、与同任何2004调查对象进行的任何业务、商业或金融交易有关的文件，包括但不限于任何贷款、信贷额度、寄托、存款、互换、证券交易、抵押或ISDA，包括任何及所有账户结单、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，以及电汇及相关通信函件和指示。\n\n案件 22-50073 文件 839 于 09/07/22 提交 于 09/07/22 20:02:47 登记 第 425 页，共 491 页\n\n4. 所有日期为2014年1月1日至今、与涉及2004调查对象的任何电汇活动有关的文件，无论是否存在任何账户，包括但不限于所有电汇收据、账户号码、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. 所有日期为2014年1月1日至今、与贵方和2004调查对象之间任何通信函件及通讯有关的文件。\n\n6. 所有日期为2014年1月1日至今、与任何2004调查对象开立账户、账户获授权使用人及账户维护有关的任何账户的文件。\n\n7. 所有日期为2014年1月1日至今、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文件，包括但不限于任何2004调查对象提供的或贵方获悉的任何信息。\n\n8. 所有日期为2014年1月1日至今、与就任何2004调查对象同任何国家的任何监管机构进行的任何通讯有关的文件，包括但不限于英格兰银行、美国联邦储备系统、S.E.C.、CFTC、FINRA、中国证券监督管理委员会、中国人民银行、香港证券及期货事务监察委员会及香港金融管理局。\n\n附件 C-22\n\nB2540（表格2540——Rule 2004审查传票）（12/15）美国破产法院 案件 22-50073 文件 839 于 09/07/22 提交 于 09/07/22 20:02:47 登记 第 427 页，共 491 页\n\n_________________________________________________________ 康涅狄格区 _________________________________________________________\n\n关于 _________________________________________________________\n\n案件编号 ____________________ Ho Wan Kwok（郭文贵）22-50073\n\n债务人\n\n第 ____________________ 章 11\n\nRule 2004审查传票\n\n致：________________________________________________________________________________________________ HSBC Holdings, PLC（汇丰控股有限公司）\n\n（传票所指向之人的姓名）\n\n证言：特此命令贵方在下文所列的时间、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。X\n\n地点\n\nNEUBERT, PEPE & MONTEITH, P.C.（纽伯特、佩佩和蒙泰思专业公司） 日期和时间\n\n195 Church Street, 13th Floor\n\nNew Haven, Connecticut 06510\n\n审查将通过以下方式记录：_________________________________________________________ 法庭记录员/速记员\n\n提交：贵方或贵方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、测试或抽样：X\n\n见随附的《文件提交请求》。\n\n下列《联邦民事诉讼规则》Rule 45条款根据《联邦破产程序规则》Rule 9016适用于破产案件，现随附：有关履行地点的Rule 45(c)；有关作为受传票约束之人的保护的Rule 45(d)；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Rule 45(e)和45(g)。\n\n日期：____________________ September __, 2022\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 Patrick R. Linsey（ct29437）\n\n代表（当事人姓名）_________________________并签发或请求本传票的律师的姓名、地址、电子邮件地址和电话号码如下：Luc Despins（卢克·德斯平斯），第11章受托人\n\nPatrick R. Linsey, Esq.; Neubert, Pepe & Monteith, P.C.（纽伯特、佩佩和蒙泰思专业公司）；195 Church Street, 13th Floor, New Haven, Connecticut 06510；plinsey@npmlaw.com；(203) 821-2000\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文件提交请求\n\nI. 指示\n\n1. 除非另有说明，下列文件请求（统称“请求”，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，否则必须完整答复每项请求；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，贵方仅须说明对该部分的异议，并答复请求的其余部分。\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\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和附件，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。\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，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，而不得作为.DAT文件内的字段。通往文本文件的完整路径（OCRPATH）应包含于.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，表明存在原生文件，并在.dat文件中将原生文件的路径作为一个字段包含在内。所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一电子文件，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提供：mm/dd/yyyy。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案件 22-50073 文件 839 于 09/07/22 提交 于 09/07/22 20:02:47 登记 第 430 页，共 491 页\n\n字段名称 示例数据 说明\n\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 字段应当填写\n适用于单页文件\nATTACHRANGE EDC0000001\n- 父文档首页的 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：电子邮件的主题行 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/ 07:05 PM GMT 电子邮件：电子邮件发送时间/电子邮件标准化时所采用的时区\nTIME_ZONE GMT 转换过程中电子邮件标准化时所采用的时区。\nLINK EDC0000001.msg 电子邮件或原生文件文档的超链接\n链接文件必须以 FIRSTBATES 编号命名\nFILE_EXTEN MSG 代表电子邮件或\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案件 22-50073 文书 839 提交日期 09/07/22 录入日期 09/07/22 20:02:47 第 431 页，共 491 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，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. 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. 所有文档均应按照通常业务过程中的保存方式提供，或者应进行整理和标记，以与本等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) 由贵方占有、保管或控制的文档；或 (b) 由任何代表贵方行事之人占有、保管或控制的文档，\n案件 22-50073 文书 839 提交日期 09/07/22 录入日期 09/07/22 20:02:47 第 432 页，共 491 页\n\n包括贵方的律师或其他代表和顾问。每份文档均应完整提供。\n\n6. 如要求贵方提供的文档已不再由贵方占有、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，识别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) 已自愿或非自愿地转移给他人，或 (iv) 以其他方式处置；(e) 说明该处置的原因，以及与该处置有关的事实和情况；(f) 识别授权该处置的人员；(g) 识别该处置的日期或大致日期；(h) 说明该文档最后一次由贵方占有、保管或控制的时间；以及 (i) 识别目前占有、保管或控制该文档的人员（如有）。\n\n7. 如要求贵方提供的文档已被销毁，则除前述指示所要求的信息外，贵方的答复还必须说明：(a) 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. 如贵方主张所请求的文档受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) 收到或阅览该文档原件或任何草稿、副本或复制件的每一人员的身份，(vii) 该文档本身或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，则识别该等人员的身份，\n案件 22-50073 文书 839 提交日期 09/07/22 录入日期 09/07/22 20:02:47 第 433 页，共 491 页\n\n并说明该等信息如何由其占有，(viii) 据以拒绝提供该文档的特权主张，以及 (ix) 贵方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)，就每份基于特权主张而拒绝提供的文档，制作一份特权清单，其中包含本指示第 (a) 部分所要求的全部信息。对于未就其提出特权或工作成果主张的任何文档请求部分，应完整提供相应文档。\n\n9. 如本应答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盖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。现指示贵方：(a) 一旦得知先前答复不完整或不正确，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) 提供根据以下规定所要求的任何额外文档\n\n11. 如文档为英文以外的语言，贵方应提供该文档。如文档为英文以外的语言，且存在英文译本，贵方应同时提供两份文档。\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案件 22-50073 文书 839 提交日期 09/07/22 录入日期 09/07/22 20:02:47 第 434 页，共 491 页\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 起至文档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该动词在所有其他时态下的使用。\n\n16. (a) “and”和“or”应根据需要解释为连词或选择词，以使本应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，均适用于文档请求。此外，本等文档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 HSBC Holdings PLC，连同其任何关联方、母公司和子公司，以及其任何雇员、代理人、律师、顾问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案件 22-50073 文书 839 提交日期 09/07/22 录入日期 09/07/22 20:02:47 第 435 页，共 491 页\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。\n\n5. “债务人自称的妻子”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），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”单独及合称债务人、债务人之子、债务人之女及债务人自称的妻子，以及与债务人存在任何其他家庭关系的人。\n\n7. “2004 年调查目标”单独及合称债务人、债务人家庭成员、ACA Capital Group Limited、Himalaya International Financial Group Ltd.、Himalaya International Clearing Ltd.、Himalaya International Payments Ltd.、Himalaya International Reserves Ltd.、Jesse Brown、William Je、William Je、Eastern Profit Corporation Limited、HK International Funds Investments (USA) Limited LLC、Bravo Luck Limited、Golden Spring (New York) Ltd.、Lamp Capital LLC、Greenwich Land LLC、Qu Guo Jiao、Daniel Thomas Podhaskie、Yvette Wang、Ace Decade Holdings Limited、Dawn State Limited、Rule of Law Society IV Inc.、Rule of Law Foundation III、GTV Media Group, Inc.、Voice of Guo Media, Inc. 和 Saraca Media Group Inc.。\n\n8. “关联个人”单独及合称以下所有个人：(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处置权者；或 (2) 曾为或现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者，连同前述任何人的各自雇员、代理人、律师、\n案件 22-50073 文书 839 提交日期 09/07/22 录入日期 09/07/22 20:02:47 第 436 页，共 491 页\n\n顾问或任何代表前述任何人行事之人。该等关联个人包括但不限于：Daniel Podhaskie、Jason Miller、Jesse Brown、William Je、Steve Bannon、Karin Maistrello、Melissa Francis、William Gertz、Arethusa Forsyth、Glenn Mellor、Jennifer Mercurio、Eduardo Eurnekian、Han Chunguang（又名 韩春光）、Qu Guojiao（又名 Qu Guo Jiao、屈国姣）、Guo Lijie（又名 郭丽杰）、Zhang Wei（又名 张伟\\*）、Lihong Wei Lafrenz（又名 Sara Wei、魏丽红）、Hao Haidong（又名 郝海东）、Ross Heinemeyer、Max Krasner、Kyle Bass、Melissa Mendez、Ya Li（又名 李娅）、Dinggang Wang（又名 王定刚）、An Hong（又名 安红）、Yvette Wang（又名 Yanping Wang、Yan Ping Wang、王雁平）、Fiona Yu、Je Kin Ming（又名 William Je、Yu Jianming、余建明）、Yaz Qingua 和 Lao Jiang（又名 Jiang Yunfu、Jiang Yunfu Be、姜云浮）。\n\n9. “关联实体”系指单独及共同而言，所有符合下列条件的任何类型组织或实体：(1) 由债务人或债务人家庭成员拥有、控制或投资的；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拥有权益的，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：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、Assets Sino Limited、Auspicious Coast Limited、Beijing Pangu Investment Co.、Beijing Pangu Investment Co. Ltd.、Beijing Pangu Investment Inc.、Beijing Zenith Holdings Company Limited、Bravo Luck Limited、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、\n\n案件 22-50073 文件 839 提交日期 09/07/22 登记日期 09/07/22 20:02:47 第 437 页，共 491 页\n\nDawn State Limited、Eastern Profit Corporation Limited、Elite Well Global Limited、Empire Growth Holdings、G Club Operations LLC、G Fashion LLC、G News LLC、GETTR USA、Genever Holdings Corporation、Genever Holdings LLC、GFASHION MEDIA GROUP INC.、GFNY, Inc.、Globalist International Limited、GNews Media Group Inc.、Golden Spring (New York) Ltd.、Greenwich Land LLC、Guo Media、GTV Media Group, Inc.、Hamilton Capital Holdings Inc.、Head Win Group Limited、Henan Yuda、Himalaya Embassy、Himalaya Exchange、Himalaya Federal Reserve、Himalaya International Financial Group Ltd.、Himalaya International Clearing Ltd.、Himalaya International Payments Ltd.、Himalaya International Reserves Ltd.、Himalaya Supervisory Organization、HK International Funds Investments (USA) Limited LLC、Hong Kong International Funds Investments Limited、Hudson Diamond NY LLC、Infinite Increase Limited、Infinitum Developments Limited、Insight Phoenix Fund、Lamp Capital LLC、Leading Shine Limited、Leading Shine NY Limited、Long Gate Limited、Next Tycoon Investments Limited、New Federal State of China (a/k/a NFSC)、Noble Fame Global Limited、Rosy Acme Ventures Limited、Rule of Law Foundation III, Inc.、Rule of Law Foundation IV, Inc.、Rule of Law Fund、Rule of Law Society、Rule of Law Society IV, Inc.、G-Translators PTY LTD、Saraca Media Group, Inc.、Shiny Ace Ltd.、Shiny Times Holdings Ltd.、Spirit Charter Investment Limited、Stevenson, Wong & Co.、TM Primrose Limited、Voice of Guo Media, Inc.、Well Origin Ltd.、World Century Limited、Worldwide Opportunity Holdings Limited、Whitecroft Shore Limited，以及 ZIBA Limited。\n\n10. “包括”或其任何变体，系指“包括但不限于”。\n\n11. “和”与“或”系指“和/或”，并应同时作合取及析取解释，以最大限度扩大其范围。\n\n12. “任何”及“所有”及“每一”系指“每一个及所有”。\n\n13. “每一”及“每个”系指“每一个及所有”。\n\n案件 22-50073 文件 839 提交日期 09/07/22 登记日期 09/07/22 20:02:47 第 438 页，共 491 页\n\n14. “第三方”系指除您以外的个人或实体。\n\n15. “转让”具有《破产法典》第 101(54) 条赋予该词的含义。\n\n16. “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品，包括但不限于任何种类、类型、性质或描述的每一份书面、录制或图形材料，只要其现由或曾由您占有、保管或控制，包括电子邮件的所有打印及电子副本、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、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、促销材料、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（无论为有形形式还是电子形式）、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，如其中含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相同。\n\n17. “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”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\n案件 22-50073 文件 839 提交日期 09/07/22 登记日期 09/07/22 20:02:47 第 439 页，共 491 页\n\n18. “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，包括但不限于律师、财务顾问或任何其他代表。\n\n19. “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、结合考虑、与之有关、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、构成及成为。\n\n20. 当“与……有关”“涉及”或“相关”指向任何特定主题时，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，或以任何方式与所指明特定主题相关的任何文件。\n\n21. “通信”在最广泛可能的意义上且不限于此，系指任何信息或知识的传递（以事实、理念、询问或其他形式）。通信还指所有交谈、协议、询问或答复，无论是当面、通过电话、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、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、电话笔记，或在内部或与第三方之间传送的笔记。\n\n案件 22-50073 文件 839 提交日期 09/07/22 登记日期 09/07/22 20:02:47 第 440 页，共 491 页\n\n22. “资产”系指受占有、保管或控制的任何具有经济价值的物项。资产包括所有不动产及动产，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、存货以及其他有形及无形财产。\n\nIV. 应提交的文件\n\n1. 所有日期在 January 1, 2014 至今之间、与由任何 2004 取证对象持有、控制、代表其持有或以其他方式与其有关的任何账户相关的文件，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、通信记录，以及电汇及相关通信和指示。\n\n2. 所有日期在 January 1, 2014 至今之间、与属于任何 2004 取证对象、由其持有、控制、代表其持有或以其他方式与其有关的任何资金、证券、财产或资产相关的文件，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、通信记录，以及电汇及相关通信和指示。\n\n3. 所有日期在 January 1, 2014 至今之间、与同任何 2004 取证对象进行的任何商业、贸易或金融交易相关的文件，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、通信记录，以及电汇及相关通信和指示。\n\n案件 22-50073 文件 839 提交日期 09/07/22 登记日期 09/07/22 20:02:47 第 441 页，共 491 页\n\n4. 所有日期在 January 1, 2014 至今之间、与任何涉及 2004 取证对象的电汇活动有关的文件，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、与转账当事人有关的身份识别信息、通信记录、指示或其他记录。\n\n5. 所有日期在 January 1, 2014 至今之间、与您和 2004 取证对象之间任何信函及通信相关的文件。\n\n6. 所有日期在 January 1, 2014 至今之间、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文件。\n\n7. 所有日期在 January 1, 2014 至今之间、与涉及任何 2004 取证对象的任何反洗钱、了解你的客户或其他合规活动有关的文件，包括但不限于由任何 2004 取证对象提供或由您获悉的任何信息。\n\n8. 所有日期在 January 1, 2014 至今之间、与就任何 2004 取证对象而与任何国家的任何监管机构进行的任何通信有关的文件，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附件 C-23\n\nB2540（表格 2540——规则 2004 审查传票）（12/15）美国破产法院 案件 22-50073 文件 839 提交日期 09/07/22 登记日期 09/07/22 20:02:47 第 443 页，共 491 页\n\n_____________________________________________________________ Connecticut 区\n\n关于 _____________________________________________________________\n\n案件编号 ______________________________ Ho Wan Kwok（郭文贵）22-50073\n\n债务人\n\n第 ____________________ 章 11\n\n规则 2004 审查传票\n\n致：________________________________________________________________________________________________________________________ JPMorgan Chase Bank, N.A.\n\n（传票所指向之人的姓名）\n\n证言：兹命令您于下列载明的时间、日期及地点出席，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。X\n\n地点\nNEUBERT, PEPE & MONTEITH, P.C. 日期和时间\n\n195 Church Street, 13th Floor\nNew Haven, Connecticut 06510\n\n本次询问将通过以下方式记录：________________________________________________________________________________ 法庭记录员/速记员\n\n提交：贵方或贵方代表还必须将下列文件、电子存储信息或物品带至询问现场，并必须允许对该材料进行检查、复制、测试或抽样：X\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，根据《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，涉及履行地点；第45(d)条，涉及对作为传票对象之人的保护；以及第45(e)条和第45(g)条，涉及贵方对本传票作出回应的义务及不作出回应的潜在后果。\n\n日期：__________________ September __, 2022\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 Patrick R. Linsey（帕特里克·R·林赛）(ct29437)\n\n代表（当事人姓名）____________________________并签发或请求本传票的律师姓名、地址、电子邮件地址和电话号码如下：Luc Despins（吕克·德斯平），第11章受托人\n\nPatrick R. Linsey（帕特里克·R·林赛）, Esq.; 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) 821-2000\n向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，则必须在向本传票所指向之人送达前，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”，每一项以下简称“一项请求”）必须分别且具体地予以答复。除非贵方基于善意提出异议，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\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。其应为以逗号分隔的文件，每行由七个字段组成，并应对数据库中的每张图像在交叉引用文件中设置一行，格式如下：ImageID,VolumeLabel,ImageFilePath,DocumentBreak,FolderBreak,Box Break,PageCount。\n- c. 文件文本。文本必须作为独立文本文件提交，而非作为 .DAT 文件内的字段提交。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。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- 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，表明存在原生文件，并在 .dat 文件中将原生文件的路径列为一个字段。所提交的原生文件应以对应于该文件分隔页的 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。\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，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- f. 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 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 446 of 491\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 字段应针对单页予以填写\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 附件范围的首个 Bates 编号\nENDATTACH EDC0000015 附件范围的最后一个 Bates 编号\nCUSTODIAN Smith, John（史密斯，约翰） 电子邮件：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（约翰·史密斯） 电子邮件：发件人\n原生文件：文件作者\n多个条目应以分号分隔\nTO Coffman, Janice（科夫曼，贾妮丝）; LeeW\n[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:\nfrank_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 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，\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/\nTIME_ZONE 07:05 PM GMT 电子邮件：电子邮件发送时间/电子邮件标准化时所采用的时区\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\nCase 22-50073 Doc 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 447 of 491\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\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，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，包括原始文件名称。\nINTFILEPATH Personal Folders\\Deleted\nItems\\Board Meeting\nMinutes.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）\nINTMSGID <000805c2c71b\\$75977050\\$\ncb8306d1@MSN> 电子邮件：唯一邮件 ID 原生文件：（空）\nMD5HASH d131dd02c5e6eec4693d9a0\n698aff95c\n2fcab58712467eab4004583e\nb8fb7f89 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，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. 所有文件应按其在通常业务过程中保存的方式提交，或者应进行组织并加注标签，以对应本请求中的类别。\n\n5. 本文件所含每项请求均延及所有文件：(a) 在贵方占有、保管或控制之下的文件；或(b) 在代表贵方行事的任何人占有、保管或控制之下的文件，\nCase 22-50073 Doc 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 448 of 491\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交。\n\n6. 如要求贵方提交的某份文件已不再处于贵方占有、保管或控制之下，则贵方答复必须：(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之人的身份（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) 缺失或遗失，(ii) 已被销毁，(iii) 已自愿或非自愿地转交给他人，或(iv) 已以其他方式处置；(e) 说明该等处置的理由，以及该等处置的相关事实和情形；(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处于贵方占有、保管或控制之下的时间；以及(i) 确认目前占有、保管或控制该文件的人员（如有）。\n\n7. 如要求您提交的某一文件已被销毁，则您的答复除须载明前述指示所要求的信息外，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. 如您主张所要求的某一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、保管或控制范围；(viii) 据以不提交该文件的特权主张；以及 (ix) 您将据以支持该等特权主张的全部情形；以及 (b) 就每一份基于特权主张而未提交的文件，依照 D. Conn. L. Civ. R. 26(e)，提交一份特权清单，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，应完整提交响应性文件。\n\n案件 22-50073 文件 839 提交于 09/07/22 录入于 09/07/22 20:02:47 第 449 页，共 491 页\n\n9. 如原本具有响应性的文件的一部分含有受特权主张保护的信息，则仅应依照上述指示从该文件中删除或遮盖受特权主张保护的该部分，其余部分应予提交。\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) 提交根据文件请求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，您应提交该文件。如某一文件使用英语以外的语言，且存在英文译本，您应同时提交两份文件。\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所有其他姓名、别名或昵称。\n\n案件 22-50073 文件 839 提交于 09/07/22 录入于 09/07/22 20:02:47 第 450 页，共 491 页\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) 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”应视需要解释为连词关系或选择关系，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其范围；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以下含义：\n\n1. “You”、“Your”或“Yourself”系指 JPMorgan Chase Bank, N.A.（摩根大通银行，全国协会），连同其任何关联方、母公司和子公司，以及其任何雇员、代理人、律师、顾问或任何代表其行事的人员。\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员。\n\n案件 22-50073 文件 839 提交于 09/07/22 录入于 09/07/22 20:02:47 第 451 页，共 491 页\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员。\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员。\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员。\n\n6. “Debtor’s Family”单独及统称指债务人、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家庭关系的人员。\n\n7. “2004 Discovery Targets”单独及统称指债务人、债务人家属、ACA Capital Group Limited、Himalaya International Financial Group Ltd.、Himalaya International Clearing Ltd.、Himalaya International Payments Ltd.、Himalaya International Reserves Ltd.、Jesse Brown、William Je、William Je、Eastern Profit Corporation Limited、HK International Funds Investments (USA) Limited LLC、Bravo Luck Limited、Golden Spring (New York) Ltd.、Lamp Capital LLC、Greenwich Land LLC、Qu Guo Jiao（屈国姣）、Daniel Thomas Podhaskie、Yvette Wang（王雁平）、Ace Decade Holdings Limited、Dawn State Limited、Rule of Law Society IV Inc.、Rule of Law Foundation III、GTV Media Group, Inc.、Voice of Guo Media, Inc. 及 Saraca Media Group Inc.\n\n8. “Associated Individuals”单独及统称指以下所有个人：(1) 持有、控制、保管或对债务人或债务人家属所拥有、控制或享有的资产具有处置决定权者；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之关联者，连同前述任一人员各自的雇员、代理人、律师、顾问或任何代表其行事的人员。该等关联个人包括但不限于：Daniel Podhaskie、Jason Miller、Jesse Brown、William Je、Steve Bannon、Karin Maistrello、Melissa Francis、William Gertz、Arethusa Forsyth、Glenn Mellor、Jennifer Mercurio、Eduardo Eurnekian、Han Chunguang（韩春光）（又名 韩春光）、Qu Guojiao（屈国姣）（又名 Qu Guo Jiao、屈国姣）、Guo Lijie（郭丽杰）（又名 郭丽杰）、Zhang Wei（张伟）（又名 张伟\\*）、Lihong Wei Lafrenz（魏丽红）（又名 Sara Wei、魏丽红）、Hao Haidong（郝海东）（又名 郝海东）、Ross Heinemeyer、Max Krasner、Kyle Bass、Melissa Mendez、Ya Li（李娅）（又名 李娅）、Dinggang Wang（王定刚）（又名 王定刚）、An Hong（安红）（又名 安红）、Yvette Wang（王雁平）（又名 Yanping Wang、Yan Ping Wang、王雁平）、Fiona Yu、Je Kin Ming（余建明）（又名 William Je、Yu Jianming、余建明）、Yaz Qingua 及 Lao Jiang（姜云浮）（又名 Jiang Yunfu、Jiang Yunfu Be、姜云浮）。\n\n案件 22-50073 文件 839 提交于 09/07/22 录入于 09/07/22 20:02:47 第 452 页，共 491 页\n\n9. “Associated Entities”单独及统称指以下所有类型的组织或实体：(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，连同前述任一组织或实体各自的雇员、代理人、律师、顾问或任何代表其行事的人员。该等关联实体包括但不限于：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、Assets Sino Limited、Auspicious Coast Limited、Beijing Pangu Investment Co.、Beijing Pangu Investment Co. Ltd.、Beijing Pangu Investment Inc.、Beijing Zenith Holdings Company Limited、Bravo Luck Limited、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、\n\n案件 22-50073 文件 839 提交于 09/07/22 录入于 09/07/22 20:02:47 第 453 页，共 491 页\n\nDawn State Limited、Eastern Profit Corporation Limited、Elite Well Global Limited、Empire Growth Holdings、G Club Operations LLC、G Fashion LLC、G News LLC、GETTR USA、Genever Holdings Corporation、Genever Holdings LLC、GFASHION MEDIA GROUP INC.、GFNY, Inc.、Globalist International Limited、GNews Media Group Inc.、Golden Spring (New York) Ltd.、Greenwich Land LLC、Guo Media、GTV Media Group, Inc.、Hamilton Capital Holdings Inc.、Head Win Group Limited、Henan Yuda、Himalaya Embassy、Himalaya Exchange、Himalaya Federal Reserve、Himalaya International Financial Group Ltd.、Himalaya International Clearing Ltd.、Himalaya International Payments Ltd.、Himalaya International Reserves Ltd.、Himalaya Supervisory Organization、HK International Funds Investments (USA) Limited LLC、Hong Kong International Funds Investments Limited、Hudson Diamond NY LLC、Infinite Increase Limited、Infinitum Developments Limited、Insight Phoenix Fund、Lamp Capital LLC、Leading Shine Limited、Leading Shine NY Limited、Long Gate Limited、Next Tycoon Investments Limited、New Federal State of China（又名 NFSC）、Noble Fame Global Limited、Rosy Acme Ventures Limited、Rule of Law Foundation III, Inc.、Rule of Law Foundation IV, Inc.、Rule of Law Fund、Rule of Law Society、Rule of Law Society IV, Inc.、G-Translators PTY LTD、Saraca Media Group, Inc.、Shiny Ace Ltd.、Shiny Times Holdings Ltd.、Spirit Charter Investment Limited、Stevenson, Wong & Co.、TM Primrose Limited、Voice of Guo Media, Inc.、Well Origin Ltd.、World Century Limited、Worldwide Opportunity Holdings Limited、Whitecroft Shore Limited 及 ZIBA Limited。\n\n10. “Including”或其任何变体，意为“包括但不限于”。\n\n11. “And”和“or”意为“和/或”，并应同时解释为连词关系及选择关系，以最大限度扩大其范围。\n\n12. “Any”、“all”和“each”意为“每一个及所有”。\n\n13. “Each”和“every”意为“每一个及所有”。\n\n案件 22-50073 文件 839 提交于 09/07/22 录入于 09/07/22 20:02:47 第 454 页，共 491 页\n\n14. “Third Party”系指除您本人以外的人员或实体。\n\n15. “Transfer”应具有《破产法》section 101(54) 赋予该术语的含义。\n\n16. “文件”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、现由或曾由贵方持有、保管或控制的每一份书面、记录或图形材料，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、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、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、进度表、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（无论为有形形式还是电子形式）、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，如其中载有原始文件中未载明的任何种类的笔记、评论或标记，或在其他方面与原始文件不相同。\n\n17. “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案号 22-50073，文件 839，提交日期 09/07/22，录入日期 09/07/22 20:02:47，第 455 页，共 491 页\n\n18. “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\n19. “关于”系指涉及、描述、构成、提及、相关、支持、有利于、反对、加强、削弱、载于、结合考虑、对……有影响、证明、表明、报告、记录、暗指、回应、与……相联系、评论、就……而言、有关、与……相关、讨论、显示、描述、反映、分析、构成及属于。\n\n20. 就任何特定主题而言，“与……有关”、“涉及”或“相关”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，或以任何方式与所识别的特定主题相关的任何文件。\n\n21. “通信”系指在最广泛可能的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）。通信还指所有交谈、协议、询问或答复，无论是当面、通过电话、以书面方式，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、电传、影印件、电传、电讯即时消息、聊天、短信、公告板或群聊帖子、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送的笔记。\n案号 22-50073，文件 839，提交日期 09/07/22，录入日期 09/07/22 20:02:47，第 456 页，共 491 页\n\n22. “资产”系指受持有、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、共有产权公寓、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、存货以及其他有形和无形财产。\n四、应提交的文件\n\n1. 自 January 1, 2014 起至今与由任何 2004 调查对象持有、控制、代为持有、代表其持有或以其他方式与其有关的任何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、已付款支票副本、函件，以及电汇及相关函件和指示。\n\n2. 自 January 1, 2014 起至今与属于任何 2004 调查对象、由其持有、控制、代为持有、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、已付款支票副本、函件，以及电汇及相关函件和指示。\n\n3. 自 January 1, 2014 起至今与和任何 2004 调查对象之间的任何商业、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，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、已付款支票副本、函件，以及电汇及相关函件和指示。\n案号 22-50073，文件 839，提交日期 09/07/22，录入日期 09/07/22 20:02:47，第 457 页，共 491 页\n\n4. 自 January 1, 2014 起至今与任何涉及 2004 调查对象的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、账户号码、余额、授权文件、与转账当事方有关的身份识别信息、函件、指示或其他记录。\n\n5. 自 January 1, 2014 起至今与贵方和 2004 调查对象之间的任何函件和通信有关的所有文件。\n\n6. 自 January 1, 2014 起至今与任何 2004 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. 自 January 1, 2014 起至今与涉及任何 2004 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 调查对象提供的信息，或贵方获知的信息。\n\n8. 自 January 1, 2014 起至今与就任何 2004 调查对象而与任何国家的任何监管机构进行的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附件 C-24\nB2540（表格 2540——Rule 2004 审查传票）（12/15）UNITED STATES BANKRUPTCY COURT（美国破产法院）案号 22-50073，文件 839，提交日期 09/07/22，录入日期 09/07/22 20:02:47，第 459 页，共 491 页\n\n_________________________________________________________ 地区：_________________________________________________________ Connecticut（康涅狄格州）\n\n关于：_________________________________________________________\n\n案号：____________________________ Ho Wan Kwok（郭文贵）22-50073\n\n债务人\n\n章节：________________ 11\nRULE 2004 审查传票\n\n致：_________________________________________________________________________________________________________________________ Standard Chartered PLC（渣打集团有限公司）\n\n（传票送达对象姓名）\n\n 证言：兹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》Rule 2004 在审查中作证。随附授权该审查的法院命令副本。X\n\n地点 日期和时间\n\nNEUBERT, PEPE & MONTEITH, P.C.（纽伯特、佩佩及蒙泰斯专业公司）\n195 Church Street, 13th Floor\nNew Haven, Connecticut 06510\n\n该审查将以下列方式记录：________________________________________________________________________________ 法庭记录员/速记员\n\n 提交：贵方或贵方代表还必须携带下列文件、电子存储信息或物品参加审查，并必须准许对该材料进行检查、复制、测试或抽样：X\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 的下列规定已附上；该规则经 Fed. R. Bankr. P. 9016 适用于破产案件——关于履行地点的 Rule 45(c)；关于作为受传票约束之人的保护的 Rule 45(d)；以及关于贵方回应本传票的义务及未予回应的潜在后果的 Rule 45(e) 和 45(g)。\n\n日期：________________ September __, 2022\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 Patrick R. Linsey（ct29437）\n\n代表（当事人姓名）____________________________ 并签发或申请本传票的律师的姓名、地址、电子邮件地址和电话号码如下：Luc Despins（卢克·德斯平斯），Ch. 11 Trustee（第 11 章受托人）\n\nPatrick R. Linsey, Esq.; Neubert, Pepe & Monteith, P.C.; 195 Church Street, 13th Floor, New Haven, Connecticut 06510 plinsey@npmlaw.com; (203) 821-2000\n向签发或申请本传票之人的通知\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，则必须在向传票指定对象送达前，向每一当事人送达通知及本传票副本。Fed. R. Civ. P. 45(a)(4)。\n文件提交请求\n一、说明\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。每项请求均应得到完整答复，除非贵方基于善意提出异议；在此情形下，贵方应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，并对请求的其余部分作出答复。\n\n2. 电子存储信息必须按照以下说明提交：\n\na. 图像。黑白图像必须为 300 DPI Group IV 单页 TIFF 文件。彩色图像必须采用 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，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；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交付，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。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交付。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，必须以原生格式交付。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。应提供一张带有 Bates 编号的分隔页图像，注明存在原生文件，并将原生文件路径作为字段包含在 .dat 文件中。交付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一电子文件，仅交付一份。对于电子邮件信息，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\nf. 元数据。以符合 Concordance 要求的加载文件（.dat）形式交付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。以下列出必需的元数据：\nCase 22-50073 Doc 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 462 of 491\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 在转换过程中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 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 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 463 of 491\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\n\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. 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. 所有文件应按照通常业务过程中的保存方式交付，或应进行组织和标注，以对应于本请求中的类别。\n\n5. 本文所载各项请求延伸至所有文件：（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，\nCase 22-50073 Doc 839 Filed 09/07/22 Entered 09/07/22 20:02:47 Page 464 of 491\n\n包括贵方的律师或其他代表及顾问。每份文件均应完整交付。\n\n6. 如要求贵方交付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，该文件被发送给的人员）；（c）确定该文件编制或创建的日期；（d）说明该文件是否（i）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）说明该等处置的原因以及相关事实和情形；（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贵方占有、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. 如要求贵方交付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）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. 如贵方主张所要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）收到或阅览过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）贵方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一文件，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。对于文件请求中未主张特权或工作成果的任何部分，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，其余部分应予交付。\n\n10. 各项请求具有持续性。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）交付根据下文所要求的任何其他文件。\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. 对实体的所有提述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\n案件 22-50073 文件 839 提交于 09/07/22 录入于 09/07/22 20:02:47 第 466 页，共 491 页\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；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”应在必要时解释为连词或析取连词，以使本可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；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如下含义：\n\n1. “You”、“Your”或“Yourself”系指 Standard Chartered PLC（渣打集团有限公司），连同其任何关联方、母公司及子公司，以及其任何雇员、代理人、律师、顾问或代表其行事的任何人。\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、顾问或代表其行事的任何人。\n\n案件 22-50073 文件 839 提交于 09/07/22 录入于 09/07/22 20:02:47 第 467 页，共 491 页\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、顾问或代表其行事的任何人。\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、顾问或代表其行事的任何人。\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、顾问或代表其行事的任何人。\n\n6. “Debtor's Family”系指单独及合称的债务人、债务人之子、债务人之女及债务人所称之妻，以及债务人的任何其他家庭关系人。\n\n7. “2004 Discovery Targets”系指单独及合称的债务人、债务人家庭成员、ACA Capital Group Limited、Himalaya International Financial Group Ltd.、Himalaya International Clearing Ltd.、Himalaya International Payments Ltd.、Himalaya International Reserves Ltd.、Jesse Brown、William Je、William Je、Eastern Profit Corporation Limited、HK International Funds Investments (USA) Limited LLC、Bravo Luck Limited、Golden Spring (New York) Ltd.、Lamp Capital LLC、Greenwich Land LLC、Qu Guo Jiao、Daniel Thomas Podhaskie、Yvette Wang、Ace Decade Holdings Limited、Dawn State Limited、Rule of Law Society IV Inc.、Rule of Law Foundation III、GTV Media Group, Inc.、Voice of Guo Media, Inc.及 Saraca Media Group Inc.。\n\n8. “Associated Individuals”系指单独及合称的所有下列个人：(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处置权者；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者，连同前述各方各自的雇员、代理人、律师、\n\n案件 22-50073 文件 839 提交于 09/07/22 录入于 09/07/22 20:02:47 第 468 页，共 491 页\n\n顾问或代表前述任何一方行事的任何人。此类关联个人包括但不限于：Daniel Podhaskie、Jason Miller、Jesse Brown、William Je、Steve Bannon、Karin Maistrello、Melissa Francis、William Gertz、Arethusa Forsyth、Glenn Mellor、Jennifer Mercurio、Eduardo Eurnekian、Han Chunguang（韩春光）（又名 韩春光）、Qu Guojiao（屈国姣）（又名 Qu Guo Jiao、屈国姣）、Guo Lijie（郭丽杰）（又名 郭丽杰）、Zhang Wei（张伟）（又名 张伟*）、Lihong Wei Lafrenz（魏丽红）（又名 Sara Wei、魏丽红）、Hao Haidong（郝海东）（又名 郝海东）、Ross Heinemeyer、Max Krasner、Kyle Bass、Melissa Mendez、Ya Li（李娅）（又名 李娅）、Dinggang Wang（王定刚）（又名 王定刚）、An Hong（安红）（又名 安红）、Yvette Wang（王雁平）（又名 Yanping Wang、Yan Ping Wang、王雁平）、Fiona Yu、Je Kin Ming（余建明）（又名 William Je、Yu Jianming、余建明）、Yaz Qingua 及 Lao Jiang（姜云浮）（又名 Jiang Yunfu、Jiang Yunfu Be、姜云浮）。\n\n9. “Associated Entities”系指单独及合称的所有下列组织或任何类型的实体：(1) 曾由债务人或债务人家庭成员拥有、控制或投资的组织或实体；或 (2) 对债务人或债务人家庭成员拥有、控制或享有的任何资产直接或间接具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、顾问或代表前述任何一方行事的任何人。此类关联实体包括但不限于：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、Assets Sino Limited、Auspicious Coast Limited、Beijing Pangu Investment Co.、Beijing Pangu Investment Co. Ltd.、Beijing Pangu Investment Inc.、Beijing Zenith Holdings Company Limited、Bravo Luck Limited、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、\n\n案件 22-50073 文件 839 提交于 09/07/22 录入于 09/07/22 20:02:47 第 469 页，共 491 页\n\nDawn State Limited、Eastern Profit Corporation Limited、Elite Well Global Limited、Empire Growth Holdings、G Club Operations LLC、G Fashion LLC、G News LLC、GETTR USA、Genever Holdings Corporation、Genever Holdings LLC、GFASHION MEDIA GROUP INC.、GFNY, Inc.、Globalist International Limited、GNews Media Group Inc.、Golden Spring (New York) Ltd.、Greenwich Land LLC、Guo Media、GTV Media Group, Inc.、Hamilton Capital Holdings Inc.、Head Win Group Limited、Henan Yuda、Himalaya Embassy、Himalaya Exchange、Himalaya Federal Reserve、Himalaya International Financial Group Ltd.、Himalaya International Clearing Ltd.、Himalaya International Payments Ltd.、Himalaya International Reserves Ltd.、Himalaya Supervisory Organization、HK International Funds Investments (USA) Limited LLC、Hong Kong International Funds Investments Limited、Hudson Diamond NY LLC、Infinite Increase Limited、Infinitum Developments Limited、Insight Phoenix Fund、Lamp Capital LLC、Leading Shine Limited、Leading Shine NY Limited、Long Gate Limited、Next Tycoon Investments Limited、New Federal State of China（新中国联邦）（又名 NFSC）、Noble Fame Global Limited、Rosy Acme Ventures Limited、Rule of Law Foundation III, Inc.、Rule of Law Foundation IV, Inc.、Rule of Law Fund、Rule of Law Society、Rule of Law Society IV, Inc.、G-Translators PTY LTD、Saraca Media Group, Inc.、Shiny Ace Ltd.、Shiny Times Holdings Ltd.、Spirit Charter Investment Limited、Stevenson, Wong & Co.、TM Primrose Limited、Voice of Guo Media, Inc.、Well Origin Ltd.、World Century Limited、Worldwide Opportunity Holdings Limited、Whitecroft Shore Limited 及 ZIBA Limited。\n\n10. “Including”或其任何变体，意为“包括但不限于”。\n\n11. “And”和“or”意为“and/or”，并应同时按连词及析取连词解释，以最大限度扩大其范围。\n\n12. “Any”、“all”和“each”意为“每一及全部”。\n\n13. “Each”和“every”意为“每一及全部”。\n\n案件 22-50073 文件 839 提交于 09/07/22 录入于 09/07/22 20:02:47 第 470 页，共 491 页\n\n14. “Third Party”系指除您本人以外的个人或实体。\n\n15. “Transfer”具有《破产法典》第 101(54) 条赋予该词的含义。\n\n16. “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、记录或图示材料，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、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、电传传真、电子邮件、短信、即时消息、语音消息、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、账簿、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，以及其全部元数据，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，如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完全相同。\n\n17. “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”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\n案件 22-50073 文件 839 提交于 09/07/22 录入于 09/07/22 20:02:47 第 471 页，共 491 页\n\n18. “Entity”系指任何自然人、公司、合伙企业、子公司、独资企业、商号、委员会、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\n19. “Regarding”系指有关、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、与之相联系地考虑、对之有影响、证明、表明、报告、记录、暗示、答复、与之连接、评论、关于、就其而言、与之有关、讨论、显示、描述、反映、分析、构成及成为。\n\n20. 当“Relating to”、“relate(s) to”或“related to”提及任何既定事项时，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\n21. “Communication(s)”系指以最广泛可能的含义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、以书面形式，还是通过电子传输设备，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、语音消息、电报、电传传真、传真副本、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、电话笔记，或在内部或与第三方之间传递的笔记。\n\n案件 22-50073 文件 839 提交于 09/07/22 录入于 09/07/22 20:02:47 第 472 页，共 491 页\n\n22. “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\nIV. 应提交的文件\n\n1. 所有日期介于 January 1, 2014 至今、与任何2004调查对象以其名义持有、控制、代表其持有或以其他方式与其有关的任何账户相关的文件，包括任何及所有账户对账单、授权书、委托书、信托、指示或表格、已注销支票副本、通信往来，以及电汇及相关通信往来和指示。\n\n2. 所有日期介于 January 1, 2014 至今、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有关的任何资金、证券、财产或资产相关的文件，包括任何及所有账户对账单、授权书、委托书、信托、指示或表格、已注销支票副本、通信往来，以及电汇及相关通信往来和指示。\n\n3. 所有日期介于 January 1, 2014 至今、与同任何2004调查对象进行的任何商业、贸易或金融交易相关的文件，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，以及任何及所有账户对账单、授权书、委托书、信托、指示或表格、已注销支票副本、通信往来，以及电汇及相关通信往来和指示。\n\n案号 22-50073 文件 839 提交日期 09/07/22 录入日期 09/07/22 20:02:47 第 473 页，共 491 页\n\n4. 所有日期介于 January 1, 2014 至今、与任何涉及2004调查对象的电汇活动相关的文件，无论是否存在任何账户，包括但不限于所有电汇收据、账户号码、余额、授权、与转账当事人有关的身份识别信息、通信往来、指示或其他记录。\n\n5. 所有日期介于 January 1, 2014 至今、与贵方和2004调查对象之间的任何通信往来及通讯相关的文件。\n\n6. 所有日期介于 January 1, 2014 至今、与任何2004调查对象的任何账户相关的文件，涉及账户开立、账户获授权使用人及账户维护。\n\n7. 所有日期介于 January 1, 2014 至今、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相关的文件，包括但不限于任何2004调查对象提供的信息，或贵方获悉的信息。\n\n8. 所有日期介于 January 1, 2014 至今、与同任何国家的任何监管机构进行的任何通讯相关的文件，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）、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）和香港金融管理局（Hong Kong Monetary Authority），涉及任何2004调查对象。\n\n附件 C-25\n\nB2540（表格2540——2004规则审查传票）(12/15) 美国破产法院（UNITED STATES BANKRUPTCY COURT） 案号 22-50073 文件 839 提交日期 09/07/22 录入日期 09/07/22 20:02:47 第 475 页，共 491 页\n\n________________________________________________________________________ 地区：________________________________________________________________________ Connecticut（康涅狄格州）\n\n关于________________________________________________________________________一案\n\n案号：____________________________ Ho Wan Kwok（郭文贵） 22-50073\n\n债务人\n\n章：________________ 11\n\n2004规则审查传票\n\n致：________________________________________________________________________________________________ UBS AG（瑞银集团）\n\n（传票所指向人员的姓名）\n\n证言：兹命令贵方于下文载明的时间、日期和地点出席，并根据《联邦破产程序规则》第2004条接受审查作证。随附准许该审查的法院命令副本。X\n\n地点 日期和时间\n\nNEUBERT, PEPE & MONTEITH, P.C.（纽伯特、佩佩和蒙蒂斯律师事务所）\n\n195 Church Street, 13th Floor\n\nNew Haven, Connecticut 06510\n\n审查将以以下方式记录：________________________________________________________________________ 法庭记录员/速记员\n\n提交：贵方或贵方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检查、复制、测试或取样：X\n\n见随附的《文件提交请求》。\n\n《联邦民事诉讼规则》第45条的下列规定，根据《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；以及关于贵方对该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：________________ September __, 2022\n\n法院书记官\n\n或\n\n____________________________ 法院书记官或副书记官签名 ____________________________ 律师签名 Patrick R. Linsey（ct29437）\n\n代表（当事人名称）____________________________并签发或请求本传票的律师的姓名、地址、电子邮件地址和电话号码为：Luc Despins（卢克·德斯平斯），第11章受托人\n\nPatrick R. Linsey, Esq.; Neubert, Pepe & Monteith, P.C.; 195 Church Street, 13th Floor, New Haven, Connecticut 06510 plinsey@npmlaw.com; (203) 821-2000\n\n致签发或请求本传票者的通知\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，则必须在向传票所指向人员送达之前，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文件提交请求\n\nI. 指示\n\n1. 除非另有说明，下列文件请求（“请求”，每项称为“一项请求”）必须分别且具体地作出答复。除非善意提出异议，否则每项请求均应得到完整答复；如提出异议，应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，或其中所含的某个词语、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，即贝茨编号。每张图像的右下角必须标注连续的贝茨编号。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贝茨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。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。应在.DAT文件中包括文本文件的完整路径（OCRPATH）。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提供。\n\nd. 特定文件类型的原生格式提交。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。提供一张标有贝茨编号的分隔页图像，以指示原生文件的存在，并在.dat文件中将原生文件路径作为字段列入。以对应于该文件分隔页的贝茨编号命名所提交的原生文件。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，仅提交一份副本。对于电子邮件，根据由BCC、Body、CC、From、IntMsgID、To及Attach属性生成的MD5哈希值合并重复项。对于电子邮件附件及独立电子文件，根据整个文件的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）\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案号 22-50073 文件 839 提交日期 09/07/22 录入日期 09/07/22 20:02:47 第 478 页，共 491 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\nLASTBATES 字段应针对单页文件予以填写\n\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\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：该电子邮件所在的邮箱\n原生文件：文档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：文档作者\n多个条目应以分号分隔\n\nTO Coffman, Janice（珍妮丝·科夫曼）；LeeW 收件人\n[mailto:LeeW@MSN.com] 多个条目应以分号分隔\n\nCC Frank Thompson（弗兰克·汤普森）[mailto: 抄送收件人\nfrank_Thompson@cdt.com] 多个条目应以分号分隔\n\nBCC John Cain（约翰·凯恩） 密送收件人\n多个条目应以分号分隔\n\nSUBJECT Board Meeting Minutes（董事会会议纪要） 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：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时区内的时间\n\nTIME_ZONE GMT 转换期间电子邮件被标准化所采用的时区。\n\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\n案件 22-50073 文件 839 于 09/07/22 提交 于 09/07/22 20:02:47 登记 第 479 页，共 491 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，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该数据必须为单独字段，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该数据必须为单独字段，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，单位为 KB\n\nPGCOUNT 1 原生文件文档/电子邮件的页数\n\nPATH 电子邮件：（空）\nAgenda.doc 原生文件：原生文件文档的存储路径，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：唯一消息 ID 原生文件：（空）\ncb8306d1@MSN>\n\nMD5HASH d131dd02c5e6eec4693d9a0 文档的 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. 每一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. 所有文件均应按其在正常业务过程中保存的方式提供，或应按本等请求中的类别整理并标记。\n\n5. 本文所载的每一项请求均延及所有文件：(a) 由贵方占有、保管或控制的；或 (b) 由任何代表贵方行事之人占有、保管或控制的，\n\n案件 22-50073 文件 839 于 09/07/22 提交 于 09/07/22 20:02:47 登记 第 480 页，共 491 页\n\n包括贵方的律师或其他代表和顾问。每份文件均应完整提供。\n\n6. 如要求贵方提供已不再由贵方占有、保管或控制的文件，则贵方的答复必须：(a) 详细描述该文件的性质及其内容；(b) 确认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) 确认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) 以其他方式处置；(e) 说明该等处置的原因及其相关事实和情况；(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. 如要求贵方提供已被销毁的文件，则除前述指示所要求的信息外，贵方的答复还必须说明：(a) 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. 如贵方主张某一被请求提供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案件 22-50073 文件 839 于 09/07/22 提交 于 09/07/22 20:02:47 登记 第 481 页，共 491 页\n\n以及说明该等人员如何取得该信息，(viii) 据以不提供该文件的特权主张，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)，就基于特权主张而不提供的每一份文件，制作一份载有本指示第 (a) 部分所要求全部信息的特权日志。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. 如本应响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涂黑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。兹指示贵方：(a) 在获悉先前答复不完整或不正确后，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. 如某份文件使用英语以外的语言，贵方应提供该文件。如某份文件使用英语以外的语言，且存在英文译本，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替代姓名、别名或昵称。\n\n案件 22-50073 文件 839 于 09/07/22 提交 于 09/07/22 20:02:47 登记 第 482 页，共 491 页\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”应视需要解释为连词或析取词，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。\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，本等文件请求中使用的下列术语具有如下含义：\n\n1. “贵方”或“贵方的”或“贵方自身”系指 UBS AG（瑞银集团），连同其任何关联公司、母公司和子公司，以及其任何雇员、代理人、律师、顾问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（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之人。\n\n案件 22-50073 文件 839 于 09/07/22 提交 于 09/07/22 20:02:47 登记 第 483 页，共 491 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之人。\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之人。\n\n5. “债务人所谓的妻子”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之人。\n\n6. “债务人家庭成员”系指单独及合称的债务人、债务人之子、债务人之女和债务人所谓的妻子，以及与债务人有任何其他亲属关系之人。\n\n7. “2004 年证据开示对象”系指单独及合称的债务人、债务人家庭成员、ACA Capital Group Limited（ACA 资本集团有限公司）、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）、Jesse Brown（杰西·布朗）、William Je（余建明）、William Je（余建明）、Eastern Profit Corporation Limited（东方利润有限公司）、HK International Funds Investments (USA) Limited LLC（香港国际基金投资〈美国〉有限责任公司）、Bravo Luck Limited（鸿运有限公司）、Golden Spring (New York) Ltd.（金泉〈纽约〉有限公司）、Lamp Capital LLC（蓝普资本有限责任公司）、Greenwich Land LLC（格林威治土地有限责任公司）、Qu Guo Jiao（屈国姣）、Daniel Thomas Podhaskie（丹尼尔·托马斯·波德哈斯基）、Yvette Wang（王雁平）、Ace Decade Holdings Limited（十年卓越控股有限公司）、Dawn State Limited（黎明州有限公司）、Rule of Law Society IV Inc.（法治协会 IV 公司）、Rule of Law Foundation III（法治基金会 III）、GTV Media Group, Inc.（GTV 媒体集团公司）、Voice of Guo Media, Inc.（郭媒体之声公司）及 Saraca Media Group Inc.（萨拉卡媒体集团公司）。\n\n8. “关联个人”系指单独及合称的所有下列个人：(1) 持有、控制、保管债务人或债务人家庭成员拥有、控制或享有的资产，或对该等资产拥有处置权；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之关联者，以及前述任何人士各自的雇员、代理人、律师、\n\n案件 22-50073 文件 839 于 09/07/22 提交 于 09/07/22 20:02:47 登记 第 484 页，共 491 页\n\n顾问或任何代表前述任何人士行事之人。该等关联个人包括但不限于：Daniel Podhaskie（丹尼尔·波德哈斯基）、Jason Miller（杰森·米勒）、Jesse Brown（杰西·布朗）、William Je（余建明）、Steve Bannon（史蒂夫·班农）、Karin Maistrello（卡琳·迈斯特雷洛）、Melissa Francis（梅利莎·弗朗西斯）、William Gertz（威廉·格茨）、Arethusa Forsyth（阿瑞苏莎·福赛思）、Glenn Mellor（格伦·梅勒）、Jennifer Mercurio（詹妮弗·默库里奥）、Eduardo Eurnekian（爱德华多·埃尔内基安）、Han Chunguang（韩春光）（又名 韩春光）、Qu Guojiao（屈国姣）（又名 Qu Guo Jiao（屈国姣）、屈国姣）、Guo Lijie（郭丽杰）（又名 郭丽杰）、Zhang Wei（张伟）（又名 张伟\\*）、Lihong Wei Lafrenz（魏丽红·拉弗伦茨）（又名 Sara Wei（魏丽红）、魏丽红）、Hao Haidong（郝海东）（又名 郝海东）、Ross Heinemeyer（罗斯·海内迈耶）、Max Krasner（马克斯·克拉斯纳）、Kyle Bass（凯尔·巴斯）、Melissa Mendez（梅利莎·门德斯）、Ya Li（李娅）（又名 李娅）、Dinggang Wang（王定刚）（又名 王定刚）、An Hong（安红）（又名 安红）、Yvette Wang（王雁平）（又名 Yanping Wang（王雁平）、Yan Ping Wang（王雁平）、王雁平）、Fiona Yu（余菲奥娜）、Je Kin Ming（余建明）（又名 William Je（余建明）、Yu Jianming（余建明）、余建明）、Yaz Qingua（亚兹·青瓜）及 Lao Jiang（老姜）（又名 Jiang Yunfu（姜云浮）、Jiang Yunfu Be（姜云浮·贝）、姜云浮）。\n\n9. “关联实体”系指，单独或合并而言，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) 直接或间接在债务人或债务人的家庭成员拥有、控制或享有的任何资产中拥有权益，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：7 Nod Hill LLC（七诺德山有限责任公司）、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（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）、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（阿尔卑斯受托人股份公司）、Anton Development Limited（安东开发有限公司）、Assets Sino Limited（华夏资产有限公司）、Auspicious Coast Limited（吉祥海岸有限公司）、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（北京鼎峰控股有限公司）、Bravo Luck Limited（鸿运有限公司）、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（克兰咨询集团有限责任公司）、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）、\n\n案号 22-50073，文件 839，提交日期 09/07/22，录入日期 09/07/22 20:02:47，第 485 页，共 491 页\n\nDawn State Limited（曙光州有限公司）、Eastern Profit Corporation Limited（东方利润有限公司）、Elite Well Global Limited（精英环球有限公司）、Empire Growth Holdings（帝国增长控股）、G Club Operations LLC（G俱乐部运营有限责任公司）、G Fashion LLC（G时尚有限责任公司）、G News LLC（G新闻有限责任公司）、GETTR USA（GETTR美国）、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（全球主义者国际有限公司）、GNews Media Group Inc.（GNews媒体集团公司）、Golden Spring (New York) Ltd.（金泉〔纽约〕有限公司）、Greenwich Land LLC（格林尼治土地有限责任公司）、Guo Media（郭媒体）、GTV Media Group, Inc.（GTV媒体集团公司）、Hamilton Capital Holdings Inc.（汉密尔顿资本控股公司）、Head Win Group Limited（领赢集团有限公司）、Henan Yuda（河南裕达）、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 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 Supervisory Organization（喜马拉雅监督组织）、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）、Hudson Diamond NY LLC（哈德逊钻石纽约有限责任公司）、Infinite Increase Limited（无限增长有限公司）、Infinitum Developments Limited（无限发展有限公司）、Insight Phoenix Fund（洞察凤凰基金）、Lamp Capital LLC（蓝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）、Long Gate Limited（长门有限公司）、Next Tycoon Investments Limited（下一大亨投资有限公司）、New Federal State of China (a/k/a NFSC)（中国新联邦国〔亦称NFSC〕）、Noble Fame Global Limited（卓名环球有限公司）、Rosy Acme Ventures Limited（玫瑰顶点创投有限公司）、Rule of Law Foundation III, Inc.（法治基金会III公司）、Rule of Law Foundation IV, Inc.（法治基金会IV公司）、Rule of Law Fund（法治基金）、Rule of Law Society（法治协会）、Rule of Law Society IV, Inc.（法治协会IV公司）、G-Translators PTY LTD（G翻译服务有限公司）、Saraca Media Group, Inc.（娑罗媒体集团公司）、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）、Spirit Charter Investment Limited（精神宪章投资有限公司）、Stevenson, Wong & Co.（史蒂文森、黄氏律师事务所）、TM Primrose Limited（TM报春花有限公司）、Voice of Guo Media, Inc.（郭媒体之声公司）、Well Origin Ltd.（良好起源有限公司）、World Century Limited（世界世纪有限公司）、Worldwide Opportunity Holdings Limited（全球机遇控股有限公司）、Whitecroft Shore Limited（怀特克罗夫特海岸有限公司）及 ZIBA Limited（ZIBA有限公司）。\n\n10. “包括”或其任何变体，系指“包括但不限于”。\n\n11. “和”及“或”系指“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\n12. “任何”及“全部”以及“每一”系指“每一项及全部”。\n\n13. “每一”及“每个”系指“每一项及全部”。\n\n案号 22-50073，文件 839，提交日期 09/07/22，录入日期 09/07/22 20:02:47，第 486 页，共 491 页\n\n14. “第三方”系指除您本人以外的个人或实体。\n\n15. “转让”具有《破产法》第 101(54) 条赋予该词的含义。\n\n16. “文件”系指属于 Fed. R. Civ. P. 34 范围内的任何信息或物品，包括但不限于每一项现由或曾由您占有、保管或控制的任何种类、类型、性质或描述的书面、记录或图形材料，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、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、总账、笔记本、明细表、透明胶片、录音、目录、广告、促销材料、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文件的草稿或副本，如该等草稿或副本含有原始文件中不存在的任何种类的注释、评论或标记，或者在其他方面与原始文件不相同。\n\n17. “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\n案号 22-50073，文件 839，提交日期 09/07/22，录入日期 09/07/22 20:02:47，第 487 页，共 491 页\n\n18. “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，包括但不限于律师、财务顾问或任何其他代表。\n\n19. “关于”系指有关、描述、构成、提及、与之相关、支持、赞成、反对、加强、减损、位于、与之相关地予以考虑、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、涉及、与之有关、讨论、展示、描述、反映、分析、构成及为。\n\n20. 在提及任何特定事项时，“与之相关”、“与之有关”或“相关”，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\n21. “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，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、聊天信息、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、电话笔记，或在内部或与第三方传送的笔记。\n\n案号 22-50073，文件 839，提交日期 09/07/22，录入日期 09/07/22 20:02:47，第 488 页，共 491 页\n\n22. “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\nIV. 应提交的文件\n\n1. 日期在 January 1, 2012 至今期间内，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所有文件，包括任何及全部账户对账单、授权书、委托书、信托文件、指示或表格、已注销支票副本、通信，以及电汇及相关通信和指示。\n\n2. 日期在 January 1, 2012 至今期间内，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、财产或资产相关的所有文件，包括任何及全部账户对账单、授权书、委托书、信托文件、指示或表格、已注销支票副本、通信，以及电汇及相关通信和指示。\n\n3. 日期在 January 1, 2012 至今期间内，与同任何 2004 证据开示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，包括任何及全部账户对账单、授权书、委托书、信托文件、指示或表格、已注销支票副本、通信，以及电汇及相关通信和指示。\n\n案号 22-50073，文件 839，提交日期 09/07/22，录入日期 09/07/22 20:02:47，第 489 页，共 491 页\n\n4. 日期在 January 1, 2012 至今期间内，与涉及 2004 证据开示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、与转账当事方有关的身份识别信息、通信、指示或其他记录。\n\n5. 日期在 January 1, 2012 至今期间内，与您和 2004 证据开示对象之间的任何信函和通信有关的所有文件。\n\n6. 日期在 January 1, 2012 至今期间内，与任何 2004 证据开示对象的任何账户有关，并涉及该账户的开立、账户获授权使用人及账户维护的所有文件。\n\n7. 日期在 January 1, 2012 至今期间内，与涉及任何 2004 证据开示对象的任何反洗钱、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 证据开示对象提供给您的任何信息，或您获知的任何信息。\n\n8. 日期在 January 1, 2012 至今期间内，与就任何 2004 证据开示对象同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 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\nUNITED STATES BANKRUPTCY COURT DISTRICT OF CONNECTICUT BRIDGEPORT DIVISION（美国康涅狄格州联邦破产法院布里奇波特分院）\n\n----------------------------------------------------------- x\n\n关于： ： 第 11 章\n\nHO WAN KWOK（郭文贵）， ： 案号 22-50073 (JAM)\n\n债务人。 ：\n\n----------------------------------------------------------- x\n\n异议截止日期通知\n\nLuc Despins（吕克·德斯潘）作为获任命的债务人财产第 11 章受托人（“申请人”），已向 U.S. Bankruptcy Court for the District of Connecticut（美国康涅狄格州联邦破产法院）提交申请，请求对附件 B 中确定的某些顾问和专业人士、家庭成员、商业伙伴、公司实体及银行机构进行 Rule 2004 Examination（第 2004 条审查）（“第 2004 条审查”）。特此通知，对第 2004 条审查提出的任何异议或答复，必须根据 Fed. R. Bankr. P. 2002(a) 和 9014 以及 Local Bankr. R. 2004-1(c)，不迟于 September 15, 2022,1 向法院提交。如未及时提交异议，则有关第 2004 条审查的拟议命令可在无需进一步通知和听证的情况下签发，见 11 U.S.C. section 102(1)。\n\n[本页其余部分故意留白]\n\n1 尽管根据地方法院规则，对 Rule 2004 申请提出异议的期限为提交后七天，但受托人认为，鉴于部分应受通知方直至 Thursday, September 8, 2022 才会收到本申请的送达，将异议期限延长一天是适当的。\n\n案号 22-50073 文书 839 提交于 09/07/22 登记于 09/07/22 20:02:47 第 491 页，共 491 页\n\n日期：September 7, 2022 LUC A. DESPINS（吕克·A·德斯平斯），\n\n康涅狄格州纽黑文 第11章受托人\n\n签署人：/s/ Patrick R. Linsey（帕特里克·R·林赛） Douglas S. Skalka（道格拉斯·S·斯卡尔卡）（ct00616） Patrick R. Linsey（帕特里克·R·林赛）（ct29437） NEUBERT, PEPE & MONTEITH, P.C.（纽伯特、佩佩及蒙蒂斯律师事务所） 195 Church Street, 13th Floor New Haven, Connecticut 06510 (203) 781-2847 dskalka@npmlaw.com plinsey@npmlaw.com\n\n第11章受托人的律师","key_entities":["Je","Guo","Himalaya","Kwok","Ho Wan Kwok","William Je","GTV","GETTR","Saraca","Despins","Luc Despins","Miles Guo","Himalaya Exchange","Paul Hastings","Yanping Wang","CIPA","Chinese Communist Party"],"ecf_references":[{"doc_number":57,"court":"CTB"},{"doc_number":77,"court":"CTB"},{"doc_number":78,"court":"CTB"},{"doc_number":102,"court":"CTB"},{"doc_number":107,"court":"CTB"},{"doc_number":183,"court":"CTB"},{"doc_number":299,"court":"CTB"},{"doc_number":408,"court":"CTB"},{"doc_number":514,"court":"CTB"},{"doc_number":636,"court":"CTB"},{"doc_number":637,"court":"CTB"},{"doc_number":756,"court":"CTB"},{"doc_number":757,"court":"CTB"},{"doc_number":758,"court":"CTB"}],"word_count":158276,"status":"published","published_at":"2022-09-07 00:00:00","created_at":"2022-09-07","updated_at":"2026-08-24 01:24:00"}