郭文贵破产案 · ECF #2046

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

In re:

Chapter 11

Case No. 22-50073 (JAM)

HO WAN KWOK *et al.*, 1

Debtors.

(Jointly Administered)

## **BRAVO LUCK LIMITED'S SIXTH 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 an 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*

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") until the Court considers the filed or forthcoming settlement motion related to the adversary proceedings at Adv. Proceeding No. 22-05027.

The Debtors and Bravo Luck expect to file or already have filed a settlement motion related to the adversary proceedings. This being the sixth request for an extension of time to respond to the Claims Objections, and due to the expectation of filing a motion regarding settlement shortly, it is now most efficient for the Court to enter a general extension until such settlement motion may be considered by the Court. If no settlement is approved, then the Debtors and Bravo Luck will request the Court to establish new deadlines.

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 sixth 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 until the Court considers the settlement motion related to the adversary proceeding.

*[Remainder of Page Intentionally Left Blank]*

Dated: August 4, 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*

## **CERTIFICATE OF SERVICE**

The undersigned certifies that on August 4, 2023, *Bravo Luck Limited's Sixth 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)* 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 United States first class mail, postage prepaid, 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.

| Douglass E. Barron | douglassbarron@paulhastings.com; ezrasutton@paulhastings.com; | |---------------------|-----------------------------------------------------------------| | | alexbongartz@paulhastings.com; kristincatalano@paulhastings.com | | Nicholas A. Bassett | nicholasbassett@paulhastings.com; | | | jonathonkosciewicz@paulhastings.com; | | | lucdespins@paulhastings.com; alexbongartz@paulhastings.com; | | | ezrasutton@paulhastings.com; douglassbarron@paulhastings.com; | | | ecf.frg@paulhastings.com; aviluft@paulhastings.com | | Patrick R. Linsey | plinsey@npmlaw.com; sdobson@npmlaw.com; | | | NeubertPepeMonteithPC@jubileebk.net | | Avram Emmanuel Luft | aviluft@paulhastings.com | | Douglas S. Skalka | dskalka@npmlaw.com; smowery@npmlaw.com; | | | NeubertPepeMonteithPC@jubileebk.net |

A. Electronic Notice Via CM/ECF Service List

## B. United States First Class Mail, Postage Prepaid, Service List

Genever Holdings LLC c/o J. Ted Donovan Goldberg Weprin Finkel Goldstein LLP 1501 Broadway 22nd Floor New York, NY 10036

Qiang Guo 5 Princess Gate, G3 London, SW7 1QJ United Kingdom

Douglass Barron, Esq. Paul Hastings LLP 200 Park Ave. New York, NY 10166

> */s/ Francis J. Lawall* Francis J. Lawall (admitted *pro hac vice*)