{"id":"court_ctb_999_0","court":"CTB","case_no":"22-50073","doc_number":999,"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| ------------------------------------------------------X | |\n|---------------------------------------------------------|-----------------------------------|\n| In re: | :
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Chapter 11 |\n| HO WAN KWOK,1 | :
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Case No. 22-50073 (JAM) |\n| Debtor. | :
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: |\n| ------------------------------------------------------X | |\n\n# **MOTION TO EXPEDITE HEARING ON MOTION BY BAKER & HOSTETLER LLP FOR APPROVAL OF PROCEDURE FOR PRODUCTION IN RESPONSE TO SUBPOENA**\n\nPursuant to Fed. R. Bankr. P. 9006(c)(1), Baker & Hostetler LLP (\"B&H\") hereby moves (the \"Motion to Expedite\") this Court for an order scheduling an expedited hearing on October 21, 2022, at 10:00 a.m., or at time that is more convenient for the Court, to consider the *Motion by Baker & Hostetler LLP for Approval of Procedure for Production in Response to Subpoena* (the \"Production Procedure Motion\"). In support of the Motion to Expedite, B&H respectfully states as follows:\n\n# **JURISDICTION, VENUE AND STATUTORY BASIS**\n\n1. The United States Bankruptcy Court for the District of Connecticut (the \"Court\") has jurisdiction over this matter pursuant to 28 U.S.C. §§ 157 and 1334 and the Standing Order of Reference from the United States District Court for the District of Connecticut (as amended). The\n\n1 The Debtor is known by the following names: Guo Wengui; Miles Guo; Miles Kwok; and Ho Wan Kwok.\n\nProduction Procedure Motion and this Motion to Expedite are core proceedings within the meaning of 28 U.S.C. § 157(b).\n\n2. Venue in this District is proper pursuant to 28 U.S.C. §§ 1408 and 1409.\n\n3. The basis for relief sought by this Motion to Expedite is Fed. R. Bank. P. 9006(c)(1).\n\n# **RELEVANT FACTUAL BACKGROUND**\n\n4. On February 15, 2022, Ho Wan Kwok (the \"Debtor\") filed for relief under Chapter 11 of the Bankruptcy Code\n\n5. Prior to the petition date, B&H represented the Debtor in six lawsuits (the \"Pre-Petition Litigation\").2 The Pre-Petition Litigation was stayed by the Debtor's filing of the abovecaptioned bankruptcy case.\n\n6. On or about August 22, 2022, the Chapter 11 Trustee (\"Trustee\") served B&H with a Rule 2004 Subpoena (Doc. No. 37, Ex. C-1) (the \"Subpoena\").\n\n7. After conferring with the Trustee's counsel and receiving extensions to the initial Subpoena deadline, B&H timely served its response and objections to the Subpoena on October 10, 2022 (the \"Response Deadline\")3 and is working diligently to review and produce documents\n\n2 The Pre-Petition Lawsuits are: (a) *Wu and Lan v. Kwok*, Index No. 152123/2018 in the Supreme Court of the State of New York, County of New York; (b) *Tang and Geng v. Kwok et al.*, Civil Action No. 1:17-cv-09031-JFK in the United States District Court for the Southern District of New York; (c) *Fu v. Kwok et al.*, 7:20-cv-257-DC in the United States District Court for the Western District of Texas (Midland/Odessa Division); (d) *Huang v. Kwok*, Index No. 156552/2017 in the Supreme Court of the State of New York, County of New York; (e) *Meng and Boxun Inc. v. Kwok*, Index No. 159636/2017 in the Supreme Court of the State of New York, County of New York; and (f) *Pacific Alliance Asia Opportunity Fund L.P. v. Kwok et al.*, Index No. 652077/2017 in the Supreme Court of the State of New York, County of New York.\n\n3 For the avoidance of doubt, nothing herein is intended to waive or amend B&H's response to the Subpoena.\n\nby its extended production deadline of October 21, 2022 (the \"Production Deadline\"), to which the Trustee consented.\n\n8. B&H is working diligently to review and produce documents to the Trustee. As of the date of this Motion, B&H has more than fifty (50) professionals reviewing the approximately 60,000 documents that were identified as potentially responsive to the Subpoena using agreedupon search terms negotiated with the Trustee's counsel. B&H anticipates that the vast majority of responsive documents will be produced on the Production Deadline.\n\n9. Counsel for B&H and the Debtor's bankruptcy counsel have engaged in numerous discussions on the Debtor's \"personal harm\" privilege retained by the Debtor under Paragraph 7 of the *Consent Order Regarding Control of Attorney-Client Privilege and Work Product Protection Related to Rule 2004 Subpoenaed Documents and Information* (Doc. No. 856) (the \"Privileges Consent Order\").\n\n10. As a result of those discussions, B&H through the Production Procedure Motion, requests entry of an order permitting B&H to produce documents responsive to the Subpoena to the Trustee and the Debtor in accordance with the Privileges Consent Order under the procedure set forth in the Production Procedure Motion, to which the Debtor does not object:\n\n#### **RELIEF REQUESTED**\n\n11. Bankruptcy Rule 9006(c)(1) provides that the Court may reduce the notice period when requested by motion upon cause shown.\n\n12. B&H seeks to comply with the Subpoena, the Privileges Consent Order and uphold its ethical obligations to its client. As the Production Deadline is October 21st, B&H respectfully asserts that it is imperative that the Court swiftly adjudicate the Production Procedure Motion to\n\nreduce the risk of subsequent disputes regarding compliance with the Subpoena and the Privileges Consent Order.\n\n13. Thus, cause exists for the Court to grant this Motion to Expedite and to schedule an expedited hearing on the Production Procedure Motion.\n\n14. B&H requests that a hearing on the Production Procedure Motion be scheduled on October 21, 2022 at 10:00 a.m., or at time that is more convenient for the Court.\n\n15. B&H further requests that the Court direct that service of the Production Procedure Motion, proposed order, and the Court's order granting this Motion to Expedite, be served on all parties-in-interest appearing in the Chapter 11 Case qualified to receive electronic notice via the Court's CM/ECF service, as well as the Debtor, the Trustee, the Committee, and the United States Trustee, and that the Court set an appropriate deadline for parties to object to the Production Procedure Motion in advance of the hearing.\n\n## **CONCLUSION**\n\nWHEREFORE, B&H respectfully requests that the Court issue an order, substantially in the form attached hereto, setting a hearing on the Production Procedure Motion, ordering notice of such hearing as set forth in the attached order, and ordering such other and further relief as is just and proper.\n\nDated this 19th day of October, 2022 at New Haven Connecticut.\n\n## GREEN & SKLARZ LLC\n\n*/s/ Kellianne T. Baranowsky* Lawrence S. Grossman (ct15790) Kellianne T. Baranowsky (ct26684) Joanna M. Kornafel (ct29199) One Audubon Street, 3rd Floor New Haven, CT 06511 Tel.: 203-285-8545 Fax: 203-823-4546 [lgrossman@gs-lawfirm.com](mailto:lgrossman@gs-lawfirm.com) [kbaranowsky@gs-lawfirm.com](mailto:kbaranowsky@gs-lawfirm.com) [jkornafel@gs-lawfirm.com](mailto:jkornafel@gs-lawfirm.com)\n\n# BAKER & HOSTETLER LLP\n\nAndrew Layden, FL Bar. No.: 86070 *Pro Hac Vice* Danielle Merola, FL Bar. No.: 120120 *Pro Hac Vice* Baker Hostetler LLP 200 South Orange Avenue, Suite 2300 Orlando, Florida 32801-3432 (407) 649-4000 [alayden@bakerlaw.com](mailto:alayden@bakerlaw.com) [dmerola@bakerlaw.com](mailto:dmerola@bakerlaw.com)","body_zh":null,"key_entities":["Kwok","Ho Wan Kwok","Je","Guo","Miles Guo","CIPA"],"ecf_references":[],"word_count":1108,"status":"published","published_at":null,"created_at":null,"updated_at":"2026-07-07 08:31:43"}