郭文贵破产案 · MOTION · ECF #2341

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

| -----------------------------------------------------------<br>x | | | | | |------------------------------------------------------------------|-------------|-------------------------|--|--| | In re: | :<br>: | Chapter 11 | | | | HO WAN KWOK, et al., | :<br>: | Case No. 22-50073 (JAM) | | | | Debtors.1 | :<br>:<br>: | Jointly Administered | | | | ----------------------------------------------------------- | x | | | |

## **CHAPTER 11 TRUSTEE'S RESPONSE TO G CLUB OPERATIONS LLC'S** *EX-PARTE* **MOTION TO EXPEDITE HEARING AND LIMIT NOTICE RE: MOTION TO STAY PENDING APPEAL**

Luc A. Despins, in his capacity as the chapter 11 trustee (the "Trustee") appointed in the chapter 11 case (the "Chapter 11 Case") of Ho Wan Kwok (the "Debtor" or "Kwok"), hereby responds to G Club Operations, LLC's ("G-Club") Ex-Parte *Motion to Expedite Hearing and Limit Notice re: Motion to Stay Pending Appeal* (the "Motion to Expedite"), seeking expedited consideration of its *Emergency Motion to Stay Pending Appeal* (the "Motion to Stay Pending Appeal") as follows:

The Trustee intends to oppose the Motion to Stay Pending Appeal and respectfully requests the opportunity to be heard on such motion prior to the Court's ruling. In the Motion to Expedite, G-Club asks for the Court to issue a ruling by no later than tomorrow, November 16, 2023, with G-Club asserting it will seek relief in the District Court on November 17, 2023, in the absence of such a ruling. Consistent with this proposed schedule, the Trustee will, if necessary, make himself

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 numerous 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).

available tomorrow, November 16, for a hearing, at which time the Trustee would be prepared to respond orally to the Motion to Stay Pending appeal, rather than expend resources on a written response.

*[THE REMAINDER OF THIS PAGE IS INTENTIONALLY BLANK.]*

Dated: November 15, 2023 LUC A. DESPINS,

New Haven, Connecticut CHAPTER 11 TRUSTEE

By: */s/ Patrick R. Linsey* Patrick R. Linsey (ct29437) NEUBERT, PEPE & MONTEITH, P.C. 195 Church Street, 13th Floor New Haven, Connecticut 06510 (203) 781-2847 plinsey@npmlaw.com

*and*

Nicholas A. Bassett *(pro hac vice* pending) PAUL HASTINGS LLP 2050 M Street NW Washington, D.C., 20036 (202) 551-1902 nicholasbassett@paulhastings.com

*and*

Avram E. Luft *(pro hac vice* pending) Douglass Barron (*pro hac vice* pending) PAUL HASTINGS LLP 200 Park Avenue New York, New York 10166 (212) 318-6079 aviluft@paulhastings.com

*Counsel for the Chapter 11 Trustee*

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

| -----------------------------------------------------------<br>x | | | | | |------------------------------------------------------------------|--------|-------------------------|--|--| | In re: | :<br>: | Chapter 11 | | | | | : | | | | | HO WAN KWOK, et al., | :<br>: | Case No. 22-50073 (JAM) | | | | Debtors.2 | : | Jointly Administered | | | | | : | | | | | -----------------------------------------------------------<br>x | | | | |

## **CERTIFICATE OF SERVICE**

The undersigned hereby certifies that on November 15, 2023, the foregoing was filed electronically. Notice of this filing will be sent by e-mail to all appearing parties able to receive electronic notice by operation of the Court's case management/electronic case files system ("CM/ECF"). Parties may access this filing through CM/ECF.

Dated: November 15, 2023 New Haven, Connecticut

> By: */s/ Patrick R. Linsey* Patrick R. Linsey (ct29437) NEUBERT, PEPE & MONTEITH, P.C. 195 Church Street, 13th Floor New Haven, Connecticut 06510 (203) 781-2847 plinsey@npmlaw.com

² The Debtors in these chapter 11 cases are Ho Wan Kwok (also known as Guo Wengui, Miles Guo, and Miles Kwok, as well as numerous 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).