郭文贵破产案 · ECF #2008

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

In re:

Chapter 11

Case No. 22-50073 (JAM)

HO WAN KWOK *et al.*, [1](#page-0-0)

<span id="page-0-1"></span>Debtors.

(Jointly Administered)

## **BRAVO LUCK LIMITED'S THIRD MOTION** *ON CONSENT* **FOR EXTENSION OF TIME TO RESPOND TO (I) FIRST OMNIBUS OBJECTION OF CHAPTER 11 TRUSTEE, GENEVER HOLDINGS CORPORATION, AND GENEVER HOLDINGS LLC (SEEKING EXPUNGEMENT AND DISALLOWANCE OF PROOFS OF CLAIM FILED BY BRAVO LUCK LIMITED BASED ON LACK OF EVIDENTIARY SUPPORT (DOCKET NO. 1842); (II) FIRST OMNIBUS OBJECTION OF CHAPTER 11 TRUSTEE, GENEVER HOLDINGS CORPORATION, AND GENEVER HOLDINGS LLC (SEEKING EXPUNGEMENT AND DISALLOWANCE OF PROOFS OF CLAIM FILED BY BRAVO LUCK LIMITED BASED ON LACK OF EVIDENTIARY SUPPORT) (DOCKET NO. 252); AND (III) FIRST OMNIBUS OBJECTION OF CHAPTER 11 TRUSTEE, GENEVER HOLDINGS CORPORATION, AND GENEVER HOLDINGS LLC (SEEKING EXPUNGEMENT AND DISALLOWANCE OF PROOFS OF CLAIM FILED BY BRAVO LUCK LIMITED BASED ON LACK OF EVIDENTIARY SUPPORT) (DOCKET NO. 24)**

Bravo Luck Limited ("Bravo Luck"), by and through its undersigned counsel, pursuant to D. Conn. L. Civ. R. 7(b) and L. Bankr. R. 7007-1, hereby moves solely on its own behalf for a further extension of time to respond to the (i) *First Omnibus Objection of Chapter 11 Trustee, Genever Holdings Corporation, and Genever Holdings LLC (Seeking Expungement and Disallowance of Proofs of Claim Filed by Bravo Luck Limited Based on Lack of Evidentiary Support)* (In re Ho Wan Kwok, Case No. 22-50073, Docket No. 1842) (the "Kwok Claims Objection"); (ii) *First Omnibus Objection of Chapter 11 Trustee, Genever Holdings Corporation, and Genever Holdings LLC*

<span id="page-0-0"></span>¹ The Debtors in these chapter 11 cases are Ho Wan Kwok (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).

*(Seeking Expungement and Disallowance of Proofs of Claim Filed by Bravo Luck Limited Based on Lack of Evidentiary Support) (In re Genever Holdings LLC,* Case No. 22-50592, Docket No, 252) (the "Genever US Claims Objection"); and (iii) *First Omnibus Objection of Chapter 11 Trustee, Genever Holdings Corporation, and Genever Holdings LLC (Seeking Expungement and Disallowance of Proofs of Claim Filed by Bravo Luck Limited Based on Lack of Evidentiary Support)* (In re Genever Holdings Corporation, Case No. 22-50542, Docket No. 24) (the "Genever BVI Claims Objection" and collectively with the Kwok Claims Objection and the Genever US Claims Objection, the "Claims Objections") through and including July 21, 2023.

The Debtors have informed Bravo Luck that they consent to the granting of the relief requested herein, but they reserve all rights as to the Claims Objections. This is Bravo Luck's third request for an extension of time to respond to the Claims Objections.

WHEREFORE, Bravo Luck respectfully requests that the Court enter the proposed order attached hereto as **Exhibit A**, extending the time for Bravo Luck to respond to the Claims Objections through and including July 21, 2023.

## *[Remainder of Page Intentionally Left Blank]*

Dated: July 14, 2023 */s/ Francis J. Lawall*

Francis J. Lawall, Esq. TROUTMAN PEPPER HAMILTON SANDERS LLP 3000 Two Logan Square Eighteenth and Arch Streets Philadelphia, PA 19103 Telephone: (215) 981-4481 francis.lawall@troutman.com

*and*

David M. S. Shaiken (ct02297) Shipman, Shaiken & Schwefel, LLC 433 South Main Street, Suite 319 West Hartford, CT 06110 Telephone: (860) 606-1703 Fax: (866) 431-3248 david@shipmanlawct.com

*Counsel for Bravo Luck Limited*