郭文贵破产案 · ORDER · ECF #1910

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

In re:

Chapter 11

HO WAN KWOK, *et al.*

Debtors.

Case No: 22-50073 (JAM)

## **CONSENT MOTION TO CONTINUE HEARING ON MOTION TO WITHDRAW AND FOR AARON ROMNEY AND LEE VARTAN TO APPEAR AND SHOW CAUSE WHY THE MOTION TO WITHDRAW AS COUNSEL SHOULD BE GRANTED AND FOR EXTENSION OF TIME TO SERVE ORDER**

Aaron A. Romney (the "Movant") respectfully moves (the "Motion"), with the consent of the Office of the United States Trustee (the "U.S. Trustee"), Luc A. Despins, in his capacity as Chapter 11 trustee (the "Trustee") for the bankruptcy estate of Ho Wan Kwok, and Attorney Lee Vartan ("Attorney Vartan") (collectively with the Movant, the "Participants"), for (i) a continuance of the hearing (the "Hearing") on the motion to withdraw filed by the Movant on June 13, 2023 (ECF Doc. No. 1903, the "Motion to Withdraw") and for the Movant and Lee Vartan to appear and show cause why the Motion to Withdraw as counsel should be granted, which is currently scheduled for June 29, 2023 and (ii) an extension of time to serve the Court's June 15, 2023 order (ECF Doc. No. 1909, the "Order") on Attorney Vartan, the Trustee, the U.S. Trustee, Hudson Dimond NY LLC ("Hudson Diamond NY"), and Hudson Diamond Holdings LLC ("Hudson Diamon Holdings," and together with Hudson Diamond NY, the "Hudson Diamond Entities")—until 48 hours after the Court rules on the instant Motion. The Movant states that the Participants consent to the relief requested, and that good cause exists to grant the relief requested.

1. On June 15, 2023, the Court ordered the Movant and Attorney Vartan "to personally appear on June 29, 2023 at the hearing on the Motion to Withdraw and show cause as to why the Motion to Withdraw should be granted…." Order, at 2. The Court further ordered the Movant to "serve [the] Order on Attorney Vartan, the Trustee, the U.S. Trustee, and the Hudson Diamond Entities at or before 2:00 p.m. on June 16, 2023 and file a certificate of service evidencing compliance with [the] order on or before June 19, 2023." *Id.*, at 3.

2. The Movant will be out-of-state on June 29, 2023 for a pre-planned trip to Pennsylvania to celebrate his mother's 73rd birthday. The Movant's brother and his children, with whom the Movant rarely has the opportunity to visit, will be present. This trip is of great personal importance to the Movant and his family.

3. The Movant contacted the other Participants and they all have indicated that they consent to the requested continuance of the Hearing and the extension of time to serve the Order.

4. All Participants are available on June 27, 2023 and July 6, 2023, with a collective preference, subject to the Court's availability, that the hearing be held on June 27, 2023. Should the Court be unavailable on either of those dates, the Movant requests that the Court continue the Hearing to the earliest date after July 6 that is convenient for the Court. 1

5. Therefore, the Movant respectfully request that the Court (1) continue the Hearing to June 27, 2023, July 6, 2023, or such later date that is convenient for the Court; (2) extend the time for the Movant to serve the Order until 48 hours after the Court rules on the instant Motion; and (3) grant such further relief as the Court deems just and proper.

**WHEREFORE**, for the reasons set forth herein, the Movant respectfully requests that the Court enter an order continuing the Hearing and extending the time for the Movant to serve the Order.

¹ Counsel for the Trustee is not available on July 7, 2023, and, therefore, the Movant respectfully requests that the Court continue the hearing to a date other than July 7, 2023.

Dated this 16 th day of June, 2023.

## THE MOVANT,

*/s/ Aaron A. Romney* Aaron A. Romney (ct28144) Zeisler & Zeisler, P.C. 10 Middle Street, 15th Floor Bridgeport, CT 06604 (203) 368-4234 (203) 549-0872 (fax) Email: aromney@zeislaw.com

## **CERTIFICATE OF SERVICE**

I hereby certify that on this 16 th day of June, 2023, a copy of foregoing 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.

> By: */s/ Aaron A. Romney* Aaron A. Romney (ct28144)