郭文贵破产案 · ORDER · ECF #2529

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

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

## **SUPPLEMENTAL DECLARATION OF NATASHA HARRISON IN SUPPORT OF APPLICATION OF CHAPTER 11 TRUSTEE FOR ENTRY OF ORDER, PURSUANT TO BANKRUPTCY CODE SECTIONS 327, 328, AND 330, BANKRUPTCY RULES 2014 AND 2016, AND LOCAL BANKRUPTCY RULES 2014-1 AND 2016-1, AUTHORIZING AND APPROVING RETENTION AND EMPLOYMENT OF PALLAS PARTNERS LLP AS SOLICITORS**

I, Natasha Harrison, being duly sworn, do depose and say:

1. I am a solicitor of the Supreme Court of England and Wales and the founding and managing partner of the law firm of Pallas Partners LLP ("Pallas"), which maintains its principal office at 1 King William Street, London, EC4N 7AF, UK, and I make this supplemental declaration (the "Supplemental Declaration") to supplement the declaration submitted to the Court on March 2, 2023 [Docket No. 1496-1] (the "Prior Declaration") and in further support of the *Application of Chapter 11 Trustee for Entry of Order, Pursuant to Sections 327, 328, and 330 of the Bankruptcy Code, Bankruptcy Rules 2014 and 2016, and Local Bankruptcy Rules 2014-1 and 2016-1, Authorizing and Approving Retention and Employment of Pallas Partners*

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 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).

*LLP as Solicitors in United Kingdom* [Docket No. 1496] (the "Application"). 2 I hereby supplement the Prior Declaration as follows:

2. Subsequent to Pallas' appointment as solicitors in the United Kingdom to the Chapter 11 Trustee, and upon review of the most recently filed schedule of parties in interest, or parties otherwise connected, to the Chapter 11 Cases which was filed in connection with the Trustee's *Seventh Supplemental Declaration of Disinterestedness* submitted to the Court on September 15, 2023 [Docket No. 2204] (the "Interested Parties"), Pallas has conducted reasonable checks on the Interested Parties against our records and data and has determined that, to the best of its and my knowledge and belief, neither Pallas nor Pallas US, nor any of their lawyers , including me, has any additional connections (as that term is used in Bankruptcy Rule 2014), with any of the Interested Parties, except:

- a. In an unrelated matter, Pallas and Pallas US are engaged by (i) JPMorgan Chase Bank N.A. as part of a large group claim (made up of more than 1,000 retail investors and institutional investors) (ii) an investment trust (as part of the same large group claim) for which trust Bank of New York Mellon serves as trustee; and - b. Pallas acts for clients in respect of separate and unrelated matters in relation to which adverse parties have included JPMorgan Chase, Bank of America, UBS and Citi Bank.

² Capitalized terms not defined herein shall have the meanings ascribed to them in the Application or the Prior Declaration.

3. Pallas and Pallas US acts for clients in respect of separate and unrelated matters in relation to which adverse and neutral parties include Morgan Stanley.

4. Pursuant to 28 U.S.C. § 1746, I declare under penalty of perjury that the above statements are true and correct.

Dated: January 22, 2024, at London, United Kingdom

Natasha Harrison