--- type: court_doc id: "court_ctb_2568_7" court: "CTB" case_no: "22-50073" doc_number: 2568 doc_type: "SUBPOENA" filed_date: null lang: "zh" url: "https://mubeitech.com/court/court_ctb_2568_7" json_url: "https://mubeitech.com/api/court/court_ctb_2568_7" --- # From: **Sutton, Ezra** [](mailto:ezrasutton@paulhastings.com) Date: Wed, Dec 20, 2023 at 11 > 原始法庭文件为英文；下方为英文全文，顶部为中文摘要。 From: **Sutton, Ezra** [](mailto:ezrasutton@paulhastings.com) Date: Wed, Dec 20, 2023 at 11:16 AM Subject: In re Kwok, U.S. Bankr. Ct., D. Conn., Case No. 22-50073 (JAM) - Subpoenas of Rule of Law Entities To: Bryan Ha [](mailto:bhanyc@gmail.com) Cc: Richard Signorelli [](mailto:richardsignorelli@gmail.com), Luft, Avi E. [](mailto:aviluft@paulhastings.com), Barron, Douglass E. [](mailto:douglassbarron@paulhastings.com), Farmer, Will C. [](mailto:willfarmer@paulhastings.com), Kosciewicz, Jonathon P. [](mailto:jonathonkosciewicz@paulhastings.com) Bryan, In connection with the Trustee's 2004 investigation of Rule of Law Foundation III, Inc. and Rule of Law Society IV, Inc. (together, the "Rule of Law Entities"), in the course of the Trustee's investigations, the Trustee continues to see documents demonstrating or suggesting that funds were transferred between the Rule of Law Entities and various other Debtor-affiliated entities which are believed to be beneficially owned by and/or controlled by the Debtor, and/or are the Debtor's alter ego. A 2004 investigation is meant to be a broad investigation, which courts have likened to a fishing expedition. *See In re Rafsky*, No. 02-50924, at \*3 n.2 (Bankr. D. Conn. Sep. 30, 2003) ("The scope of a Rule 2004 examination is exceptionally broad. . . and have been compared to a fishing expedition."); *In re Parikh*, 397 B.R. 518, 525 (Bankr. E.D.N.Y. 2008) ("A Rule 2004 examination has been likened to a fishing expedition, the scope of which is broad."); *In re Washington Mut., Inc.*, 408 B.R. 45, 50 (Bankr. D. Del. 2009) ("A Rule 2004 examination is commonly recognized as more in the nature of a fishing expedition."). To that end, and pursuant to, without limitation, requests 17 and 18 of the subpoenas of each of the Rule of Law Entities, we ask the Rule of Law Entities to fully comply with the subpoenas by no later than December 27, 2023, producing the balance of their production of responsive documents, including without limitation documents sufficient to show all bank accounts and investment accounts within the Rule of Law Entities' possession or control, including the balances of and transfers to and from any such accounts. The Trustee reserves all rights to seek relief from the court. Thank you, Ezra