--- type: court_doc id: "court_ctb_1267_0" court: "CTB" case_no: "22-50073" doc_number: 1267 doc_type: "ORDER" filed_date: null lang: "zh" url: "https://mubeitech.com/court/court_ctb_1267_0" json_url: "https://mubeitech.com/api/court/court_ctb_1267_0" --- # UNITED STATES BANKRUPTCY COURT DISTRICT OF CONNECTICUT BRIDGEPORT DIVISION In re: > 原始法庭文件为英文；下方为英文全文，顶部为中文摘要。 ## **UNITED STATES BANKRUPTCY COURT DISTRICT OF CONNECTICUT BRIDGEPORT DIVISION** In re: Chapter 11 HO WAN KWOK, *et al.* Debtors. Case No: 22-50073 (JAM) ### **APPELLANT'S DESIGNATION OF ITEMS TO BE INCLUDED IN THE RECORD ON APPEAL AND STATEMENT OF ISSUES TO BE PRESENTED** Pursuant to Fed. R. Bankr. P. 8009(a), the appellant and debtor Ho Wan Kwok, (the "Debtor"), by his undersigned attorneys, Zeisler & Zeisler, P.C., respectfully submits his designation of items to be included in the record on appeal and his statement of issues to be presented in connection with his appeal of the United States Bankruptcy Court's December 9, 2022, Order Granting in Part Motion for Protective Order [Doc. No. 1217]. # **I. Designation of Items to be Included in the Record on Appeal[1](#page-0-0)** - 1. Transcript of August 30, 2022, hearing before the Hon. Julie A. Manning [Doc. No. 847]. - 2. Transcript of September 6, 2022, before the Hon. Julie A. Manning [Doc. No. 864]. - 3. Transcript of November 30, 2022, hearing before the Hon. Julie A. Manning [Doc. No. 1220]. - 4. Transcript of December 2, 2022, hearing before the Hon. Julie A. Manning [Doc. No. 1221]. 1 The Debtor reserves the right to supplement this designation of items to include "any order granting leave to appeal," Fed. R. Bankr. P. 8009(a)(4), as no such order has been issued to date. - 5. July 28, 2022, Omnibus Motion of Chapter 11 Trustee for Entry of Order Under Bankruptcy Rule 2004 and Local Rule 2004-1 Authorizing Discovery With Respect to Various Legal and Financial Advisors to the Debtor [Doc. No. 637]. - 6. August 5, 2022, Debtor's Limited Objection to Rule 2004 Motions [Doc. No. 703]. - 7. August 10, 2022, Chapter 11 Trustee's Reply in Support of Motions for Entry of Orders Under Bankruptcy Rule 2004 and Local Rule 2004-1 Authorizing Examinations of Debtor, Debtor's Legal and Financial Advisors, and Various Entities and Individuals Affiliated With Debtor, and for Production of Documents [Doc. No. 724]. - 8. August 16, 2022, Order Granting Chapter 11 Trustee's Application For Rule 2004 Discovery With Respect to Various Legal and Financial Advisors to the Debtor [Doc. No. 756]. - 9. August 22, 2022, Motion of Chapter 11 Trustee for Entry of Order (A) Providing That Control of Any Attorney-Client Privilege, Work Product Protection, and Other Privileges Related to Rule 2004 Subpoenaed Documents Passed to Trustee Upon Appointment, (B) Directing That Debtor and Other Examinees Not Withhold Documents on Account of Such Privileges, and (C) Granting Related Relief [Doc. No. 777]. - 10. August 27, 2022, Debtor's Objection to Motion of Chapter 11 Trustee for Entry of Order (A) Providing That Control of Any Attorney-Client Privilege, Work Product Protection, and Other Privileges Related to Rule 2004 Subpoenaed Documents Passed to Trustee Upon Appointment, (B) Directing That Debtor and Other Examinees Not Withhold Documents on Account of Such Privileges, and (C) Granting Related Relief [Doc. No. 799]. - 11. August 29, 2022, Trustee's Reply to Debtor's Objection to Motion of Chapter 11 Trustee for Entry of Order (A) Providing That Control of Any Attorney-Client Privilege, Work Product Protection, and Other Privileges Related to Rule 2004 Subpoenaed Documents Passed to Trustee Upon Appointment, (B) Directing That Debtor and Other Examinees Not Withhold Documents on Account of Such Privileges, and (C) Granting Related Relief [Doc. No. 801]. - 12. September 14, 2022, Consent Order Regarding Control of Attorney-Client Privilege and Work Product Protection Related to Rule 2004 Subpoenaed Documents and Information [Doc. No. 856]. - 13. November 2, 2022, Motion for Protective Order [Doc. No. 1063]. - 14. November 16, 2022, Chapter 11 Trustee's Response in Opposition to the Debtor's Motion for a Protective Order Precluding the Disclosure of the Debtor's Asylum Application [Doc. No. 1105]. - 15. November 29, 2022, Reply in Further Support of Motion for Protective Order [Doc. No. 1174]. - 16. December 9, 2022, Order Granting in Part Motion for Protective Order [Doc. No. 1217]. - 17. December 12, 2022, Notice of Appeal to District Court [Doc. No. 1226]. - 18. December 13, 2022, Individual Debtor's Motion for Leave to File Appeal of Order Granting in Part Motion for Protective Order and, in the Alternative, Petition for Writ of Mandamus [Doc. No. 1228]. - 19. December 13, 2022, Individual Debtor's Motion for Stay Pending Appeal of Order Granting in Part Motion for Protective Order [Doc. No. 1235]. #### **II. Statement of Issues To Be Presented** 1. Whether the Bankruptcy Court erred in ordering the production of Ho Wan Kwok's asylum application to the chapter 11 trustee and his counsel. 2. Whether the Bankruptcy Court erred in ordering the production of Ho Wan Kwok's asylum application to the chapter 11 trustee and his counsel in violation of 8 C.F.R. § 1208.6(a) and/or 8 C.F.R. § 208.6(a). 3. Whether the Bankruptcy Court erred in ordering the production of Ho Wan Kwok's asylum application to the chapter 11 trustee and his counsel in light 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]. Dated at Bridgeport, Connecticut, this 27th day of December, 2022. THE DEBTOR, HO WAN KWOK By: */s/ Aaron A. Romney* Aaron A. Romney (ct28144) ZEISLER & ZEISLER, P.C. 10 Middle Street, 15th floor Bridgeport, CT 06605 Telephone: (203) 368-4234 Facsimile: (203) 368-0903 Email: [aromney@zeislaw.com](mailto:aromney@zeislaw.com) #### **CERTIFICATE OF SERVICE** I hereby certify that on December 27, 2022, a copy of the foregoing was filed electronically through the Court's CM/ECF System. Notice of this filing will be sent by e-mail to all parties by operation of the Court's electronic filing system or by mail to anyone unable to accept electronic filing as indicated on the Notice of Electronic Filing. Parties may access this filing through the Court's CM/ECF System. > By: */s/ Aaron A. Romney* Aaron A. Romney (ct28144)