郭文贵破产案 · SUBPOENA · ECF #2568-10

Case 22-50073 Doc 2568-10 Filed 02/05/24 Entered 02/05/24 16:29:39 Page 1 of

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**From:** Bryan Ha <bhanyc@gmail.com>

**Sent:** Friday, February 2, 2024 9:14 PM

**To:** Sutton, Ezra <ezrasutton@paulhastings.com>

**Cc:** Richard Signorelli <richardsignorelli@gmail.com>; Luft, Avi E. <aviluft@paulhastings.com>; Barron, Douglass E. <douglassbarron@paulhastings.com>; Farmer, Will C. <willfarmer@paulhastings.com>; Kosciewicz, Jonathon P. <jonathonkosciewicz@paulhastings.com>; devans sdmlawgroup.com <devans@sdmlawgroup.com>

**Subject:** Re: Re: Re: Re: In re Kwok, U.S. Bankr. Ct., D. Conn., Case No. 22-50073 (JAM) - Subpoenas of Rule of Law Entities

## Ezra,

Consistent with the parties' 2022 agreement to appropriately limit the Trustee's blanket requests for all bank records/statements as discussed in my January 12 email, Rule of Law Foundation III, Inc. ("ROLF") and Rule of Law Society IV, Inc. ("ROLS") can agree to gather and produce all bank records/statements in its possession, to the extent not already produced, pertaining to: (1) incoming donations to either ROLF or ROLS from the Debtor, his family, or any Associated Entities or Associated Individuals (as those terms are defined in the subpoenas); and (2) outgoing transfers from ROLF or ROLS related to the Debtor, his family, or any Associated Entities or Associated Individuals (as those terms are defined in the subpoenas). In addition, we are willing to conduct another comprehensive search for all such incoming donations and outgoing transfers to confirm that each and every one of such donations and transfers has been disclosed to the Trustee.

As I have explained before, the agreement we reached in 2022 to narrow the Trustee's blanket requests for all bank records/statements makes sense for all sides: it provides the Trustee with all the information that is relevant or arguably relevant to the Trustee's investigation; excludes those records that are plainly irrelevant to the Trustee's investigation; and, importantly, protects from disclosure highly sensitive and confidential information that is of no use to the Trustee (e.g., the identities of outside donors with legitimate safety concerns who have no connection to the case whatsoever).

Thanks, Bryan Ha