郭文贵破产案 · SUBPOENA · ECF #1805-32

元数据

当事人: 郭文贵 (Guo Wengui / Miles Guo / Ho Wan Kwok)
法院: CTB
案号: 22-50073
ECF #: 1805
类型: SUBPOENA

原始法庭文件为英文，下方为英文全文。

全文

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| From: | Luft. Avi E. | |--------------|--------------------------------------------------------------------------------------------------------------------| | To: | Aaron Mitchell | | Cc: | Kosciewicz, Jonathon P.; Sutton, Ezra | | Subject: | Re: [EXT] Re: Rule 2004 Subpoenas to GTV Media and Saraca Media -- In re Kwok (Bankr. D. Conn. Case. No. 22-50073) | | Date: | Wednesday, December 21, 2022 12:49:12 PM | | Attachments: | image001.png | | | image002.png | | | image003.png[61].png | | | image004.png |

Aaron,

Has GTV retained new counsel? If so, please let us know who that is. As to Saraca, am I correct that as of now it is neither represented by you or Morvillo? If so, do you know if it is represented by anyone? If not, who is person at Saraca that we should be speaking to, as Morvillo directed us to speak to you re: our requests to Saraca. Thanks.

Avi

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Avi E. Luft | Of Counsel | Financial Restructuring Group

On Dec 16, 2022, at 10:18 AM, Aaron Mitchell <aaron@lmesq.com> wrote:

# --- External Email ---

I will speak to Mr. Temkin and revert regarding GTV. I will also put you in contact with GTV's new counsel once retained.

As to Saraca, I have no authority. I am not a board member of Saraca. Nor have I ever been. I am confident that Mr. Temkin is well aware of that and would not have misinformed you of same.

## Aaron A. Mitchell, Esq.

Partner

Lawall & Mitchell, LLC p: 973-285-3280

c: 914-760-8963

w:lmesa.com

e: aaron@lmesq.com

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From: Luft, Avi E. <aviluft@paulhastings.com>

Date: Friday, December 16, 2022 at 10:01 AM

To: Aaron Mitchell <aaron@lmesq.com>

Cc: Kosciewicz, Jonathon P. <jonathonkosciewicz@paulhastings.com>, Sutton, Ezra

<ezrasutton@paulhastings.com>

Subject: Re: Rule 2004 Subpoenas to GTV Media and Saraca Media -- In re Kwok (Bankr. D. Conn. Case. No. 22-50073)

### Aaron,

We have not received any documents from either entity. Morvillo has referenced a database that was shared with the SEC, about which we have asked a series of questions that have not been answered, not have any documents been produced from it, but more importantly, we have told them from the outset that the database is not a sufficient set of data to search as based on their description it clearly was not put together to address the relevant information we seek as opposed to what was the SEC's concerns (by way of example, we have been told you were not a custodian whose documents would be captured despite them informing us you are the sole board member of the entities.) You are obviously welcome to call whomever you wish, but that cannot delay the entities productions any further. I have no idea on what basis Morvillo withdrew on the eve of our production demand, but we are at almost four months of delay. Please let us know a time you wish to speak today. Thanks.

ব

Avi

### [image001.png]<htt>

On Dec 16, 2022, at 9:43 AM. Aaron Mitchell <aaron@lmesq.com> wrote:

#### Jonathon,

I am receipt of your email below. I want to speak to Jeremy Temkin first and understand where he was in the production process in order to have a productive conversation with you.

Aaron A. Mitchell, Esq. Partner Lawall & Mitchell, LLC p: 973-285-3280 c: 914-760-8963 w:lmesq.com<htt> e: aaron@lmesq.com<mailto:aaron@lmesq.com>

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From: Kosciewicz, Jonathon P. <jonathonkosciewicz@paulhastings.com> Date: Thursday, December 15, 2022 at 1:01 PM To: Aaron Mitchell <aaron@lmesq.com> Cc: Luft, Avi E. <aviluft@paulhastings.com>, Sutton, Ezra <ezrasutton@paulhastings.com> Subject: Rule 2004 Subpoenas to GTV Media and Saraca Media -- In re Kwok (Bankr. D. Conn. Case. No. 22-50073) Aaron,

I write regarding the Rule 2004 Subpoenas served on both GTV Media Group, Inc. ("GTV Media") and Saraca Media Group, Inc. ("Saraca") in connection to the Trusted s Rule 2004 investigation in In re Kwok (Bankr. D. Conn. Case. No. 22-50073).

As you may recall, you accepted email service on behalf of GTV Media on August 19, 2022 (service was deemed effective August 22, 2022). Separately, Saraca was served via process server on August 22, 2022. On or around September 13, 2022, Jeremy Temkin of Morvillo Abramowitz Grand lason & Anello PC ("Morvillo") informed counsel for the Trustee that his firm had been hired to represent GTV Media in response to its Rule 2004 Subpoena. On September 16, 2022, Mr. Temkin informed counsel for the Trustee that Morvillo had also been retained to represent Saraca in response to its Rule 2004 Subpoena. Counsel for the Trustee subsequently extended the for both entities to respond and object to their subpoenas until October 3, 2022. Since that time, we have been meeting and conferring with Morvillo, attempting to get greater clarity on what documents were available, only to be of clarity or responsiveness. To date, not a single document has been produced by either entity, despite both entities responding that they did not obiect and would produce responsive documents.

On November 28, 2022, more than fifty days after GTV Media's and Saraca's document productions were due, counsel for the Trustee requested that both entities complete their production of documents (including privilege log(s)) on or before December 2, 2022. On November 29, 2022, Morvillo responded that it had withdrew from its representation of both GTV Media and Saraca. We have been provided no further details as to why Morvillo has withdrawn on the eve of their clients production deadline. Morvillo has indicated that all future inquiries regarding the Rule 2004 Subpoenas served on GTV Media and Saraca should not be addressed to them, but rather that all such inquiries should be directed to you.

As the person we have now been told is designated to respond for both GTV Media and Saraca, we request that we speak today or tomorrow to address these outstanding requests. Both entities are woefully late in responding to the their Rule 2004 Subpoenas and need to do so immediately.

Thank you,

Jon Kosciewicz

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