郭文贵破产案 · DECLARATION · ECF #1813-1

Case 22-50073 Doc 1813-1 Filed 05/22/23 Entered 05/22/23 18:39:15 Page 1 of 3

## Exhibit 1

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

x : : : : : : :

In re:

HO WAN KWOK, *et al*.,

Chapter 11

Case No. 22-50073 (JAM)

Debtors.

## **DECLARATION OF CHRISTOPHER J. MAJOR**

I, CHRISTOPHER J. MAJOR, hereby declare:

1. I am a partner with the law firm Meister, Seelig & Fein PLLC, counsel for Greenwich Land, LLC ("Greenwich Land") and Hing Chi Ngok ("Ms. Ngok" and together with Greenwich Land the "Greenwich Land Defendants"). I submit this Declaration pursuant to D.Conn.L.Civ.R. 37(a) and Local Bankr.R. 2004-1 in connection with the Greenwich Land Defendants' Objection to the Chapter 11 Trustee's Fifth Supplemental Omnibus Motion of Chapter 11 Trustee for Rule 2004 Discovery (the "Rule 2004 Motion") (ECF 1789).

2. The Greenwich Land Defendants are defendants in an adversary proceeding commenced by the Trustee on March 27, 2023, *Luc A. Despins, Chapter 11 Trustee v. Greenwich Land, LLC and Hing Chi Ngok*, Adversary Proceeding No. 23-05005 (the "Adversary Proceeding")

3. The Greenwich Land Defendants object to the Trustee's use of Rule 2004 discovery to obtain discovery for use in the Adversary Proceeding. The Greenwich Land Defendants are a party to the Adversary Proceeding, and the Trustee is required to conduct discovery in the normal course in accordance with the Federal Rules of Civil Procedure. The Trustee cannot evade its discovery obligations under the Federal Rules of Civil Procedure through closed Rule 2004 discovery.

4. On May 22, 2023, counsel for the Greenwich Land Defendants and the Trustee engaged in a meet and confer to discuss the Rule 2004 Motion and the Greenwich Land Defendants' objection to the Trustee's use of Rule 2004 to obtain discovery that the Trustee acknowledges may be used in the Adversary Proceeding. During this call I notified the Trustee's counsel, Avi Luft, of the Greenwich Land Defendants' planned objection to the Rule 2004 Motion.

5. Despite good faith efforts to resolve the parties' dispute without the intervention of the Court, the parties were unable to resolve, in whole or in part, the Greenwich Land Defendants' objection to the Rule 2004 Motion.

Pursuant to 28 U.S.C. §1746, I declare under penalty of perjury that the foregoing is true and correct.

Executed at Stamford, Connecticut on this 22nd day of May, 2023

Dated: May 22, 2023 Stamford, Connecticut

*/s/ Christopher J. Major*

Christopher J. Major, Esq. 125 Park Avenue, 7th Floor New York, NY 10017 Tel: (212) 655-3500 Email: cjm@msf-law.com