{"id":"court_ctb_899_0","court":"CTB","case_no":"22-50073","doc_number":899,"sub_number":0,"doc_type":"ORDER","filed_date":null,"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| -----------------------------------------------------------<br>x |                                        |  |\n|------------------------------------------------------------------|----------------------------------------|--|\n| In re:                                                           | :<br>:<br>Chapter 11                   |  |\n| HO WAN KWOK,                                                     | :<br>:<br>Case No. 22-50073 (JAM)<br>: |  |\n| Debtor.1                                                         | :<br>:                                 |  |\n| -----------------------------------------------------------      | x                                      |  |\n\n## **AFFIDAVIT OF AVRAM E. LUFT PURSUANT TO LOCAL BANKRUPTCY RULE 7037-1**\n\nI, Avram E. Luft, hereby declare:\n\n1. I am counsel at the law firm Paul Hastings LLP, 200 Park Avenue, New York, New York 10166, counsel to Luc A. Despins, chapter 11 trustee (the \"Trustee\") in the above-captioned chapter 11 case. I respectfully submit this declaration pursuant to Local Bankruptcy Rule 7037-1 and in support of the *Motion of Chapter 11 Trustee for Entry of Order Authorizing Compliance with Rule 2004 Subpoenas and Enforcing Consent Order Regarding Control of Attorney-Client Privilege and Work Product Protection Related to Rule 2004 Subpoenaed Documents and Information*.\n\n- 2. I am an adult and understand the obligations of an oath.\n- 3. I have personal knowledge of the facts stated herein.\n\n4. Following service of Rule 2004 subpoenas on Brown Rudnick LLP and Verdolino & Lowey, P.C. on August 17, 2022, I have participated in multiple meet and confers with Brown Rudnick LLP and Zeisler & Zeisler, P.C., including multiple telephone conferences with each firm\n\n<sup>1</sup> 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\nseparately, and one meet and confer as a group, in an effort to resolve the issues of: (i) compliance by Brown Rudnick LLP and Verdolino & Lowey, P.C. with Rule 2004 subpoenas issued by counsel to the Trustee in a timely manner, and (ii) the Debtor's position that a review of every privileged document in the possession of Brown Rudnick LLP and Verdolino & Lowey, P.C., for potential personal harm to the Debtor, be conducted by either Brown Rudnick LLP or, as of now, counsel to the Debtor.\n\n5. On, September 29, 2022, I attended a meet and confer between myself, on behalf of the Trustee, Brown Rudnick LLP, on behalf of itself and Verdonlino & Lowey, P.C., and counsel to the Debtor concerning the foregoing, which did not result in resolution of the foregoing issues.\n\n6. As a result of the ongoing discovery dispute, court intervention is necessary.\n\nPursuant to 28 U.S.C. § 1746, to the best of my knowledge, information and belief, and after reasonable inquiry, I declare under penalty of perjury that the foregoing is true and correct.\n\nDated: September 30, 2022 New York, New York\n\nBy: */s/ Avram E. Luft*\n\nAvram E. Luft PAUL HASTINGS LLP","body_zh":null,"key_entities":["Kwok","Guo","Ho Wan Kwok","Paul Hastings","Miles Guo","Despins","CIPA"],"ecf_references":[],"word_count":460,"status":"published","published_at":null,"created_at":null,"updated_at":"2026-07-07 08:30:42"}