--- type: court_doc id: "court_ctb_1875_0" court: "CTB" case_no: "22-50073" doc_number: 1875 doc_type: "ORDER" filed_date: null lang: "zh" url: "https://mubeitech.com/court/court_ctb_1875_0" json_url: "https://mubeitech.com/api/court/court_ctb_1875_0" --- # UNITED STATES BANKRUPTCY COURT DISTRICT OF CONNECTICUT 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 In re: HO WAN KWOK, *et al.*, [1](#page-0-0) Chapter 11 Case No. 22-50073 (JAM) Debtors. ## **REPLY IN FURTHER SUPPORT OF MOTION OF HUDSON DIAMOND NY LLC AND HUDSON DIAMOND HOLDING LLC TO ADJOURN HEARING ON MOTION OF CHAPTER 11 TRUSTEE FOR ENTRY OF AN ORDER HOLDING HUDSON DIAMOND NY LLC AND HUDSON DIAMOND HOLDING LLC IN CIVIL CONTEMPT FOR FAILING TO RESPOND TO RULE 2004 SUBPOENAS** Non-parties Hudson Diamond NY LLC and Hudson Diamond Holding LLC (collectively, the "Hudson Entities"), by and through their undersigned counsel, respectfully file this Reply in Further Support of what they believed was a very simple consent motion to adjourn (the "Motion to Adjourn") the hearing on the *Motion of Chapter 11 Trustee for Entry of Order Compelling GTV Media Group, Inc., Saraca Media Group, Inc., and G-Club Operations LLC to Comply With Rule 2004 Subpoenas and for Entry of an Order Holding G-Club US Operations LLC, G-Club US Operations Inc., Hudson Diamond NY LLC, Hudson Diamond Holding LLC, G-Fashion LLC, GNews LLC, US Himalaya Capital Inc., New York Mos Himalaya LLC, Crane Advisory Group LLC, and Maywind Trading LLC in Civil Contempt for Failing to Respond to Rule 2004 Subpoenas* (the "Motion to Compel and for Contempt") [ECF No. 1805]. The Hudson Entities have not misrepresented the terms of their agreement with the Trustee to adjourn the hearing on the Motion 1 The Debtors in these chapter 11 cases are Ho Wan Kwok (also known as Guo Wengui, Miles Guo, and Miles Kwok, as well as other aliases) (last four digits of tax identification number: 9595), Genever Holdings LLC (last four digits of tax identification number: 8202) and Genever Holdings Corporation. The mailing address for the Trustee, Genever Holdings LLC, and the Genever Holdings Corporation is Paul Hastings LLP, 200 Park Avenue, New York, NY 10166 c/o Luc A. Despins, as Trustee for the Estate of Ho Wan Kwok (solely for purposes of notices and communications). to Compel and for Contempt. The Hudson Entities filed a very brief and simple Motion to Adjourn to permit the Hudson Entities two weeks to comply with the subpoenas at issue. The Hudson Entities did not and have not stated or taken any positions that are inconsistent with the agreement reached with the Trustee and, as set forth in the email correspondence between counsel for the Hudson Entities and the Trustee, they will not take any such inconsistent positions. *See*. *e.g.*, Email correspondence attached as Exhibit D to the Trustee's June 2, 2023, Objection. The Hudson Entities have agreed to produce responsive documents to the subpoena that they possesses or control and will do so on or before June 15, 2023. Thus, the Trustee is receiving the full benefit of his bargain, there is no issue in dispute, and the Motion to Adjourn should be granted. The only substantive language set forth in the Hudson Entities' proposed order that does not appear to have been expressly discussed with the Trustee's counsel on June 1, 2023, was the proposed date of any continued hearing on the Trustee's Motion to Compel and for Contempt, which will only be necessary in the event that the Trustee takes issue with the Hudson Entities' compliance with the Trustee's subpoenas on or before June 15, 2023. The Hudson Entities recycled the language concerning that proposed date from a Consented to Motion, filed by UBS on June 1, 2023, to Adjourn the hearing on the Motion to Compel and for Contempt with respect to UBS. (Doc. No. 1843). In light of the fact that the Trustee has consented to a June 15, 2023, compliance date, it would not seem prudent to schedule a hearing on the Motion to Compel and for Contempt with respect to the Hudson Entities on June 16, 2023. It would seem prudent to allow the Trustee a reasonable time to review the Hudson Entities' production and the parties a reasonable time to discuss any remaining concerns, if any, that the Trustee may have. However, to the extent that the Trustee's concern relates to the date of the continued hearing on the Motion to Compel and for Contempt with respect to the Hudson Entities, the Hudson Entities have no objection to any date after June 15, 2023 that allows the Trustee a reasonable time to review the documents that the Hudson Entities produce and the parties an opportunity to discuss any concerns that the Trustee has. It is not clear to the undersigned if the Trustee has any other points of contention with the Hudson Entities' proposed order. The undersigned repeatedly asked the Trustee's counsel to identify what he believed was inaccurate about the Hudson Entities' motion and proposed order and did not receive a response that provided the undersigned with any better clarity. The undersigned also left a voice message for the Trustee's counsel at 4:18 pm on Friday, June 2, 2023, for the purpose of expressing his confusion with the subject of this dispute and hope that the parties could resolve it. The undersigned did not receive a call back. In the event that there are any remaining points of contention, the undersigned is prepared to discuss them before or during the hearing on the Motion to Adjourn, scheduled for 1pm on June 6, 2023. Dated: June 5, 2023 */s/ Aaron A. Romney* Bridgeport, Connecticut Aaron A. Romney (ct28144) [aromney@zeislaw.com](mailto:aromney@zeislaw.com) James M. Moriarty (ct21876) [jmoriarty@zeislaw.com](mailto:jmoriarty@zeislaw.com) **ZEISLER & ZEISLER PC** 10 Middle Street, 15th Floor Bridgeport, CT 06604 Telephone: (203) 368-4234 Facsimile: (203) 368-5485 *Counsel for Non-Parties Hudson Diamond NY LLC and Hudson Diamond Holding LLC* ## **CERTIFICATION OF SERVICE** I hereby certify that on this 5th day of June 2023, a copy of foregoing Motion was filed electronically. 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. > */s/ Aaron A. Romney* Aaron A. Romney (ct28144)