郭文贵破产案 · ORDER · ECF #1088

## **UNITED STATES BANRUPTCY COURT DISTRICT OF CONNECTICUT BRIDGEPORT DIVISION**

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In re: ) CHAPTER 11

HO WAN KWOK, ) CASE NO. 22-50073 (JAM)

Debtor. ) NOVEMBER 14, 2022

## **HING CHI NGOK AND GREENWICH LAND, LLC'S OBJECTION AND RESPONSE TO MOTION OF CHAPTER 11 TRUSTEE FOR ENTRY OF ORDER COMPELLING [] HING CHI NGOK [AND] GREENWICH LAND LLC [] TO COMPLY WITH RULE 2004 SUBPOENAS**

Hing Chi Ngok ("Mrs. Ngok") and Greenwich Land, LLC ("Greenwich Land") (collectively, the "Respondents"), by and through their undersigned counsel, hereby object to the *Motion of Chapter 11 Trustee for Entry of Order Compelling Individual Debtor, Mei Guo, HK International Funds Investments (USA) Limited, LLC, Hing Chi Ngok, Greenwich Land LLC, Lamp Capital LLC, and Golden Spring (New York) Ltd. to Comply with Rule 2004 Subpoenas* ("Motion") (Doc. No. 1046), filed by Luc A. Despins, the Chapter 11 Trustee (the "Trustee"), on October 28, 2022. In support of their Objection, the Respondents respectfully represent as follows:

1. The Trustee served Rule 2004 Subpoenas on Greenwich Land and Mrs. Ngok on August 22, 2022 and August 23, 2022, respectively (each a "Subpoena" individually, and the "Subpoenas" collectively).

2. The Trustee asserts in his Motion that Respondents refused to search "for documents related to Individual Debtor's Family, Associated Individuals, or Associated Entities (other than Greenwich Land)." *See* Motion at ¶ 27.

3. Prior to their production of documents on November 8, 2022, Respondents initially objected to various requests concerning documents related to the Individual Debtor's Family, Associated Individuals, or Associated Entities on the basis that such requests are overbroad and "without sufficient limitation to information concerning the Debtor" (the "Objections").

4. After continued meet-and-confer discussions with the Trustee, the Respondents have withdrawn their Objections concerning documents related to the Individual Debtor's Family, Associated Individuals, or Associated Entities (the Respondents' "Withdrawal").

5. The Respondents have represented to the Trustee that they do not have responsive documents in their possession, custody, or control concerning the Individual Debtor's Family (other than Hing Chi Ngok), Associated Individuals or Associated Entities (other than Greenwich Land, LLC). Notwithstanding, Respondents will continue to search for all responsive documents and will supplement as needed on or before November 18, 2022.

6. The Trustee has represented that he will withdraw the Motion based on Respondents' Withdrawal of its Objections as stated herein.

WHEREFORE, for the foregoing reasons, Hing Chi Ngok and Greenwich Land, LLC request that the Court deny the Motion as moot.

Dated at Hartford, Connecticut this 14th day of November, 2022.

## HING CHI NGOK and GREENWICH LAND, LLC

By: */s/ Evan S. Goldstein*

Evan S. Goldstein, Esq. Federal Bar No. ct22994 UPDIKE, KELLY & SPELLACY, P.C. Goodwin Square 225 Asylum Street, 20th Floor Hartford, Connecticut 06103 Tel. (860) 548-2600 Fax. (860) 548-2680 egoldstein@uks.com *Counsel to Hing Chi Ngok and Greenwich Land, LLC*