---
type: court_doc
id: "court_ctb_3098_0"
court: "CTB"
case_no: "22-50073"
doc_number: 3098
doc_type: "ORDER"
filed_date: "2024-04-12"
lang: "zh"
url: "https://mubeitech.com/court/court_ctb_3098_0"
json_url: "https://mubeitech.com/api/court/court_ctb_3098_0"
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# IN THE UNITED STATES BANKRUPTCY COURT FOR THE DISTRICT OF CONNECTICUT In re:



> 原始法庭文件为英文；下方为英文全文，顶部为中文摘要。

### **IN THE UNITED STATES BANKRUPTCY COURT FOR THE DISTRICT OF CONNECTICUT**

In re:

HO WAN KWOK, *et al.*,

Debtors.

Chapter 11

Case No. 22-50073 (JAM)

(Jointly Administered)

## **G CLUB OPERATIONS LLC'S OBJECTION TO TRUSTEE'S MOTION TO MODIFY PROCEDURES APPLICABLE TO AVOIDANCE CLAIM ADVERSARY PROCEEDINGS TO INCLUDE PROCEDURES FOR MEDIATION OF AVOIDANCE ACTIONS**

G Club Operations LLC ("G Club Operations") herein files its objection, in part, to the *Chapter 11 Trustee's Motion, Pursuant to 11 U.S.C. §§ 105(a) and 363, Federal Rules of Bankruptcy Procedure 7016, 7026, And 9006, and District of Connecticut Local Bankruptcy Rule 7016-1, to Modify Procedures Applicable to Avoidance Claim Adversary Proceedings to Include Procedures for Mediation of Avoidance Actions* (ECF No. 3003)(the "Motion"), and in support thereof, states as follows:

### **RELEVANT FACTUAL BACKGROUND**

1. On January 29, 2024, the Trustee filed his *Motion, Pursuant to 11 U.S.C. §105(a), Federal Rules of Bankruptcy Procedure 7016, 7026 and 9006, and District Court Local Bankruptcy Rule 7016-1, To Approve Procedures Applicable to Avoidance Claim Adversary Proceedings (ECN No. 253 for Order Approving Procedures Applicable to Avoidance Claim Adversary Proceedings* (ECF No. 2532) (the "Procedures Motion"). Through the Procedures Motion, the Trustee requested that the Court approve certain procedures to govern the avoidance actions filed and to be filed by the Trustee.

2. On February 7, 2024, the Court entered an order approving the Procedures Motion (ECF No. 2578).

3. On March 15, 2024, the Trustee filed his *Motion, Pursuant to 11 U.S.C. §105(a), Federal Rules of Bankruptcy Procedure 7016, 7026 and 9006, and District Court Local Bankruptcy Rule 7016-1, To Modify Procedures Applicable to Avoidance Claim Adversary Proceedings To Include Procedures for Mediation of Avoidance Actions* (ECF No. 3003) (the "Amended Procedures Motion") seeking an order requiring revising the procedures approved by the Court to include procedures for mandatory mediation of certain Avoidance Actions.

4. On March 22, 2024, the Trustee filed his *Notice of Filing [Revised Proposed] Amended Order Approving Procedures Applicable to Avoidance Claim Adversary Proceedings* (ECF No. 3035) (the "Proposed Amended Procedures Order"). The Proposed Amended Procedures Order set for the proposed procedures to govern mediation of certain avoidance actions, among other requested changes.

5. On March 22, 2024, the Court also entered a Scheduling Order concerning the Amended Procedures Motion (ECF No. 3037), (the "Scheduling Order") requiring any response to the Amended Procedures Motion to be filed by April 12, 2024 and scheduling a hearing on the Amended Procedures Motion for April 23, 2024.

6. Since the filing of the Proposed Amended Procedures Motion the undersigned has discussed the same with the Trustee's counsel and the parties have attempted to resolve disputes concerning the language of the order and certain provisions contained therein. Counsel for G Club Operations provided counsel for the Trustee with a redline version of the Proposed Amended Procedures Order which identified the problematic provisions of the order as drafted and proposed revisions to the same in order to address G Club Operations' concerns. A copy of G Club Operations' proposed revisions to the Proposed Amended Procedures Order is attached hereto as Exhibit A.

{00360355.1 } 2

7. In further discussions, the parties made some progress and were able to narrow the issues in dispute. To that end, on April 10, 2024, the Trustee provided the undersigned with a proposed further revised version of the Proposed Amended Procedures Order. A copy of the April 10th version of the Proposed Amended Procedures Order drafted by the Trustee is attached hereto as Exhibit B. As set forth in Exhibit B, the Trustee rejected many of the changes sought by G Club Operations and made further modifications to the order which were not discussed by the parties.

8. Although the Trustee has not yet docketed the April 10th version of the Proposed Amended Procedures Order, the Trustee's counsel has represented that the Trustee agrees to implement the redline changes made by the Trustee in Exhibit B. However, the Trustee's counsel indicated that the Trustee expects to make further changes to the Proposed Amended Procedures Order and does not plan on docketing a revised version until shortly before the scheduled hearing.

9. Although the Trustee agreed to make the (redlined) changes contained in Exhibit B, the April 10th version of the Proposed Amended Procedures Order does not address many of the concerns of G Club Operations with respect to proposed procedures.

10. Although G Club Operations is not automatically subject to the mediation procedures because as per the Proposed Amended Procedure Order (Exhibit A at Exhibit 4), these procedures provide that regardless of whether a matter is stayed or an avoidance action defendant is listed on Exhibit 4, the parties may agree to mediate pursuant to the procedures set forth in the Proposed Amended Procedures Order. Thus, to the extent that G Club Operations wishes to mediate with the Trustee, it would be governed by the Proposed Amended Procedures Order and its rights affected by implementation of the same. Further, the Trustee's counsel has represented that Trustee anticipates filing a further revised proposed amended procedures order prior to the

hearing scheduled on April 23, 2024. G Club Operations reserves its right to further object depending on the revisions to yet another Proposed Amended Procedures.[1](#page-3-0)

#### **OBJECTION TO PROPOSED AMENDED ORDER, IN PART**

11. G Club Operations objects to the both the original Proposed Amended Procedures Order (ECF No. 3035) as well as the April 10th version of the Proposed Amended Procedures Order shared by the Trustee (attached hereto as Exhibit B), in part, as the proposed procedures are burdensome, inequitable and prejudicial to the avoidance action defendants, including G Club Operations. Such objectionable provisions, include, but are not limited to the following provisions discussed below:

(i) The procedures seek to suspend any obligation by the Trustee to timely respond to a motion to dismiss until 60 days after any stay or partial stay is lifted, which unjustly traps parties in litigation where dismissal may be warranted;

(ii) The order needs to make clear that the parties to a stayed action, including the Trustee, cannot propound discovery during the stay;

(iii) The procedures makes no distinction between domestic and foreign entities that are avoidance defendants. Avoidance defendants outside of the United States should not be subject to the same mandatory mediation provisions. The mediation provisions as drafted provide for the imposition of sanctions, include default judgments, against parties that do not comply with mediation. Thus, various persons and entities that reside or exist outside of the United States risk significant sanctions if they do not participate in mandatory mediation. Such provisions are unduly

<span id="page-3-0"></span><sup>{00360355.1 }</sup> 4 1 It may also be possible that after entry of an order by the Court, the Trustee later seeks to amends the list of exempt defendants. Therefore, regardless of a defendant's potential designation under the Proposed Amended Procedures Order, the Order may impact the rights of all defendants and, therefore, objections to the Proposed Amended Procedures Order should be considered regardless of a parties' potential designation.

burdensome for foreign defendants and prejudicial as there could be instances where foreign defendants are required to engaged in mediation prior to adjudication of any challenges to jurisdiction and service of process. Further, compliance may be impracticable for various foreign defendants;

(iv) The procedures provide that only the Trustee will be able to select mediators to serve on a mediation panel and provides no opportunity for input by any of the avoidance action defendants. Not only will avoidance action defendants be compelled to mediate, but they may also be required to mediate with a mediator handpicked by the Trustee. Giving the Trustee such control over the process, avoidance action defendants will have no confidence in the mediation process itself, which will only serve as an impediment to settlement. Accordingly, the composition of the panel should be left to the sole discretion of Judge Tancredi;

(v) The procedures provide that if avoidance action defendants do not believe that the claims against them should be mediated, they must establish "good cause" to exempt such claims from the mediation procedures. "Good cause" is not defined in the order. As settlement of a claim is a voluntary act, so should participation in mediation. If a defendant wants its day in court to test the merits of the Trustee's claims, it should be able to "opt out" of the mediation procedures without having to file a motion and meet some undefined standard in order to do so. Such a procedure only serves to run up costs for avoidance action defendants and undermines the purpose of mediation – to procure a voluntary compromise. Accordingly, avoidance action defendants should be able to opt-out of mediation without a showing of good cause or unnecessary motion practice; and

(vi) The procedures unjustly impact a party's right to withdraw the reference of an avoidance action or any proceeding. The order needs to make clear that notwithstanding any

provision to the contrary, a party's right to withdraw the reference is preserved and not stayed by the order.

12. The foregoing is intended to highlight issues of concern for the Court and is not intended to be a complete list of all of the changes that are necessary and appropriate to preserve and protect the rights of avoidance action defendants, including G Club Operations.

13. The redline changes reflected in **Exhibit A** attached hereto set forth all of the objections to the Proposed Amended Procedures Order, which are incorporate herein by reference, and include modifying language necessary to correct those objections.

14. G Club Operationsreserves it right to further object to any revisions to the Proposed Amended Procedures Order that may be filed by the Trustee prior to or after the hearing scheduled by the Court.

### **CONCLUSION**

15. For the foregoing reasons, G Club Operations respectfully requests that the Court modify the Proposed Amended Procedures Order and adopt the changes contained in **Exhibit A** hereto.

Dated: April 12, 2024

By: */s/ Kellianne Baranowsky* GREEN & SKLARZ LLC Jeffrey M. Sklarz Kellianne Baranowsky One Audubon St, 3rd Floor New Haven, CT 06511 Tel: 203-285-8545 jsklarz@gs-lawfirm.com kbaranowsky@gs-lawfirm.com

> PILLSBURY WINTHROP SHAW PITTMAN LLP Carolina A. Fornos (*pro hac vice*) 31 West 52nd Street New York, NY 10019 Tel: 212-858-1558 carolina.fornos@pillsburylaw.com

*Attorneys for G Club Operations LLC*

#### **CERTIFICATE OF SERVICE**

I hereby certify that on the date set forth below, a copy of the foregoing was served via CM/ECF. Parties may access this filing through the Court's CM/ECF system.

Date: April 12, 2024

*/s/Kellianne Baranowsky* Kellianne Baranowsky

# **EXHIBIT A**

**G Club Operations' Objections and Proposed Revisions**

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

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

## **[REVISED PROPOSED] AMENDED ORDER APPROVING PROCEDURES APPLICABLE TO AVOIDANCE CLAIM ADVERSARY PROCEEDINGS**

Upon the motion (the "Motion")2 of Luc A. Despins, in his capacity as the chapter 11 trustee (the "Trustee") appointed in the chapter 11 case of Ho Wan Kwok (the "Debtor"), for the entry of an order (this "Order"), pursuant to sections 105(a) and 363 of Title 11 of the United States Code (the "Bankruptcy Code"), Rules 7016, 7026, and 9006 of the Federal Rules of Bankruptcy Procedure (the "Bankruptcy Rules"), and Rule 7016-1 of the District of Connecticut Local Rules of Bankruptcy Procedure (the "Local Bankruptcy Rules"), to modify the Court's *Order Approving Procedures Applicable to Avoidance Claim Adversary Proceedings* [ECF No. 2578] (the "Avoidance Procedures Order") and thereby modifying the Avoidance Action Procedures to provide for the inclusion of certain procedures governing mediation of Avoidance Actions; and this Court having jurisdiction to consider the Motion and the relief requested therein in accordance with 28 U.S.C. §§ 157 and 1334 and the *Standing Order of Reference* from

<sup>1</sup> 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).

<sup>2</sup> Capitalized terms used but not otherwise defined in this Order have the meanings ascribed to them in the Motion.

the United States District Court for the District of Connecticut; and consideration of the Motion and the relief requested therein being a core proceeding pursuant to 28 U.S.C. § 157(b); and venue being proper in this Court pursuant to 28 U.S.C. §§ 1408 and 1409; and the Court having found that the relief requested in the Motion is in the best interest of the Debtor's chapter 11 estate, its creditors, and all parties in interest; and due and sufficient notice of the Motion having been given under the particular circumstances; and it appearing that no other or further notice need be given; and upon all of the proceedings had before this Court, including a hearing held April 23, 2024; and any objections to the relief requested herein having been withdrawn or overruled on the merits; and after due deliberation and sufficient cause appearing therefor, it is hereby ORDERED THAT:

1. The Motion is granted as set forth herein.

2. The Court hereby orders that the following amended Avoidance Action Procedures shall govern the Avoidance Actions:

a. The Avoidance Action Procedures shall apply to any adversary proceedings commenced by the Trustee on or after February 1, 2024, in which the Trustee asserts claims solely under sections 544, 547, 548, 549, and 550 of the Bankruptcy Code (the "Avoidance Actions").

b. Upon filing a complaint commencing any Avoidance Action (an "Avoidance Complaint"), the Trustee shall file a Notice of Applicability of Avoidance Action Procedures in a form substantially similar to that attached hereto as **Exhibit 1** (the "Avoidance Action Procedures Notice"). The Trustee shall serve a copy of the Avoidance Action Procedures Notice on each defendant in an Avoidance Action (an "Avoidance Defendant") together with the Summons and Avoidance Complaint pursuant to Bankruptcy Rule 7004.

c. Motions affecting multiple Avoidance Actions shall be filed in each applicable Avoidance Action and shall use a caption substantially in the form attached hereto as **Exhibit 2**.

d. To the extent that an Avoidance Complaint (including exhibits) contains information that is designated confidential or highly confidential pursuant to the Protective Order [Main Case ECF No. 923] (the "Protective Order") and the Stipulated Addendum to Protective Order [Main Case ECF No. 2460] (the "P.O. Addendum"), the Trustee may file the Avoidance Complaint under seal (a "Sealed Avoidance Complaint"), provided, however, the Trustee shall file unsealed a copy of the Avoidance Complaint that redacts any information that is designated confidential or highly confidential (a "Redacted Avoidance Complaint"). Service of a Redacted Avoidance Complaint shall constitute sufficient service of a complaint as required by Bankruptcy Rule 7004. Notwithstanding anything to the contrary in the Protective Order and the P.O. Addendum, upon any Avoidance Defendant and its counsel each executing copies of Exhibit A to the Protective Order and, if applicable, Exhibit A to the P.O. Addendum, the Trustee may provide a copy of the unredacted Avoidance Complaint to such Avoidance Defendant.

e. An Avoidance Defendant's time to respond to any Avoidance Complaint (the "Response Date") shall be sixty (60) days from the date that service is effected on such Avoidance Defendant, *provided, however*, that, without further order of the Court, the Trustee and any Avoidance Defendant may stipulate to further extend the defendant's Response Date up to ninety (90) additional days. Any such stipulation shall be made in writing and filed on the docket in the applicable adversary proceeding. Notwithstanding anything herein to the contrary:

i. the Avoidance Actions set forth on **Exhibit 3-A** attached hereto (the "Stayed Avoidance Actions") shall be stayed pending further order of the Court; *provided, however*, that an Avoidance Defendant in an Avoidance Action set forth on **Exhibit 3-B** may timely file a motion to dismiss pursuant to Federal Rule of Civil Procedure 12(b), made applicable here by Federal Rule of Bankruptcy Procedure 7012, and if a motion to dismiss is or has been timely filed, the Trustee shall respond timely to that motion. At such time that the stay of the Stayed Avoidance Actions is lifted, the Court shall determine whether the Stayed Avoidance Actions shall be subject to the Mediation Procedures and set deadlines for Avoidance Defendants in such actions to respond to the Avoidance Complaints.

ii. the Avoidance Actions set forth on **Exhibit 3-B** attached hereto (the "Partially Stayed Avoidance Actions") shall be stayed pending further order of the Court solely as to any legal or factual issues concerning whether ACA Capital Group Ltd, Anton Development Limited, G Club International Limited, G Club Operations LLC, G Fashion, G Fashion Media Group Inc., GFNY Inc., Hamilton Capital Holding Ltd, Himalaya International Clearing Ltd, Leading Shine NY Ltd, Rule of Law Foundation III Inc., Rule of Law Society IV Inc., and Saraca Media Group Inc. were alter-egos of the Debtor and/or whether the property of such entities was property of the Debtor and/or of the Debtor's chapter 11 estate (collectively, the "Stayed Issues"). For the avoidance of doubt, Partially Stayed Avoidance Actions shall proceed to mediation to the extent provided by the Mediation Procedures (as defined herein) as to all issues that are

not Stayed Issues, *provided, however*, Stayed Issues may also be mediated on a voluntary basis.

iii. Upon the filing of any new Avoidance Action, the Trustee may designate such action a Stayed Avoidance Action or a Partially Stayed Avoidance Action by filing a notice of such designation (a "Stay Designation Notice") in the relevant Avoidance Action. Any Avoidance Defendant wishing to challenge a Stay Designation Notice shall file a response to such notice in the relevant Avoidance Action within seven (7) days of appearing in same, to which the Trustee may reply within fourteen (14) days of the filing of such response. Any disputes over a Stay Designation Notice shall be determined by the Court.

f. In the event that any Avoidance Defendant responds to an Avoidance Complaint by filing a motion pursuant to Civil Rule 12(b), the Trustee shall have sixty (60) days to respond to such motion.

g. Unless otherwise ordered by the Court, no initial pretrial conference pursuant to Bankruptcy Rule 7016 will be held prior to discovery in any Avoidance Action and, accordingly, the Summons issued by the Clerk of the Court and served by the Trustee will not include a date for a pretrial conference. To the extent that a party to an Avoidance Action believes that a pretrial conference is necessary to address scheduling or other issues, any party may request such a conference at any time by filing a request on the docket in the Avoidance Action.

h. As soon as practicable following the Response Date, the parties shall confer pursuant to Civil Rule 26(f) (the "Initial Case Conference") and, thereafter, the parties shall either file a joint proposed scheduling order governing discovery, summary judgment, and other pretrial proceedings, subject to Court approval. If the Court does not approve the joint proposed scheduling order, the Court shall schedule a pretrial conference to determine a scheduling order. If the parties do not agree on a joint proposed scheduling order, the parties shall request a pretrial conference to determine a scheduling order. No party shall propound discovery in an Avoidance Action before a scheduling order is entered.

i. Any party to an Avoidance Action may request that the Avoidance Action Procedures be modified as applied in such Avoidance Action for good cause shown. Such modification shall be requested by motion filed in the applicable Avoidance Action.

j. Notwithstanding anything herein to the contrary, the Avoidance Action Procedures shall be subject to the following procedures governing mediation proceedings (the "Mediation Procedures"), *provided however*, that the Mediation Procedures shall only apply as to defendants domiciled in the United States, and any non-United States domiciled defendants shall not be subject to the Mediation Procedures unless they agree voluntarily; *provided further*, that voluntary participation in mediation in accordance with the Mediation Procedures shall not constitute submission to jurisdiction or a waiver of any claim or defense, including based on sufficiency of process: Upon the appearance of any Avoidance Defendant in an Avoidance Action prior to the expiration of such

Avoidance Defendant's deadline to respond to the Trustee's Avoidance Complaint, the Trustee's claims against such Avoidance Defendant in such Avoidance Action shall automatically (and without further order) be referred (the "Mediation Referral") to non-binding mediation proceedings (as set forth herein, the "Mediation Proceedings"), *provided, however*, no Mediation Referral shall be deemed to have occurred prior to May 15, 2024. Upon a Mediation Referral, the Avoidance Action shall be stayed, as to such Avoidance Defendant only (including, without limitation, as to such Avoidance Defendant's obligation to respond to the Avoidance Complaint), pending the conclusion of Mediation Proceedings. If the Avoidance Defendant appears in the Avoidance Action after the Avoidance Defendant's time to respond to the Avoidance Complaint has expired, no Mediation Referral shall occur except upon a written stipulation by the Trustee and such Avoidance Defendant filed in the Avoidance Action or by order of the Court. For the avoidance of doubt, the staying of any Avoidance Action as to a particular Avoidance Defendant shall not stay the Avoidance Action as to any other Avoidance Defendant, nor shall the staying of a particular Avoidance Action as against an Avoidance Defendant stay any other claims by the Trustee against such Avoidance Defendant outside of such Avoidance Action (whether in other Avoidance Actions or otherwise). Notwithstanding anything herein to the contrary, no claims by the Trustee against the Avoidance Defendants set forth on the attached **Exhibit 4** shall be subject to a Mediation Referral except upon a stipulation between the Trustee and such Avoidance Defendant or by Order of the Court.

k. United States Bankruptcy Judge James J. Tancredi ("Judge Tancredi") shall oversee all Mediation Proceedings, *provided, however*, mediations shall be conducted by Judge Tancredi or by a mediator from an approved panel of disinterested mediators of Avoidance Actions (the "Mediation Panel") if the TrusteeJudge Tancredi determines, in consultation with Judge Tancredithe Trustee, that it would be beneficial to create such a panel. The members of any Mediation Panel shall be selected by the Trustee in consultation with Judge Tancredi, who may take recommendations from the Trustee, subject to the Court's approval of the appointment of each such mediator and rates of compensation applicable to same. Such approval shall be requested by the Trustee in the Main Case only by way of motion, and after notice and hearing, consistent with Bankruptcy Rules 2002 and 9013 and applicable Local Bankruptcy Rules and served on all Avoidance Defendants, and the appointment of a mediator to the Mediation Panel shall become effective upon approval by the Court. Any request for the appointment of a mediator to the Mediation Panel will be accompanied by a sworn declaration from the mediator that the mediator that the mediator does not hold or represent any party with an interest adverse to the estate or any Avoidance Defendant and is otherwise a "disinterested person" within the meaning of 11 U.S.C. § 101(14). The proposed mediator's declaration shall also disclose all connections with the Trustee and his counsel.

l. Within fourteen (14) days of any Mediation Referral, the Trustee and the relevant Avoidance Defendant shall jointly contact Judge Tancredi by letter submitted via Judge Tancredi's courtroom deputy briefly (and in a non-argumentative manner) describing the claims at issue and advising regarding their availability to participate in mediation in the following sixty (60) days as well as to whether the mediation session(s) should take place in person or via videoconference. Following receipt of such letter, Judge Tancredi shall assign the Avoidance Action to be mediated by himself or by a member of the Mediation Panel (the "Assigned Mediator") and shall direct that the mediation be conducted in person or via videoconference. Judge Tancredi may order that related Mediation Proceedings (including, where appropriate, where claims are asserted against multiple defendants in a single Avoidance Action) be consolidated.

m. Alternatively, any Avoidance Defendant that believes that the claims against it should not be subject to mediation may, within fourteen (14) days of the Mediation Referral, file a motionopt-out of the Mediation by filing a notice with the Court setting forth good cause to exempt the claims against it from the Mediation Procedures, with notice to the Trustee, the Trustee, and Judge Tancredi. No Mediation Proceedings as to such an Avoidance Defendant shall occur pending the Court's determination of such a motion. If the Court grants the motion, the Mediation Proceedings shall be deemed immediately terminated and the Avoidance Defendant shall respond to the Trustee's Avoidance Complaint within thirty (30) days of such termination. If the Court denies the motion, the Trustee and the Avoidance Defendant shall contact Judge Tancredi by letter within fourteen (14) days of such denial pursuant to the procedure set forth in the foregoing paragraph l to obtain an Assigned Mediator. that it does not wish to participate in the Mediation. If a defendant wishes to participate in mediation at a later time, the parties may notify Judge Tancredi and the Court that they wish to proceed to mediation.

n. Upon notification of their assignment, the Assigned Mediator shall have an opportunity to determine whether they have any conflicts with the Avoidance Defendant and, in the event of a conflict, mayshall abstain from acting in the particular mediation, unless the Avoidance Defendant consents. If the Assigned Mediator abstains, Judge Tancredi shall assign an alternative mediator from the Mediation Panel or shall assign himself to the mediation. If a party to Mediation Proceedings believes that a conflict of interest precludes the service of the Assigned Mediator, such party may seek the assignment of a different Assigned Mediator by letter submitted to Judge Tancredi via his courtroom deputy (with copies to the opposing party and the Assigned Mediator) or by motion filed with the Court, *provided, however*, such relief may only be sought within seven (7) days of a party's discovery of the basis for seeking such relief.

o. Upon the assignment of the Assigned Mediator, the Trustee and the Avoidance Defendant shall confer with the Assigned Mediator regarding a date for the initial mediation session. The Assigned Mediator shall schedule the mediation to occur within sixty (60) days of assignment*, provided, however*, upon the consent of the parties and the Assigned Mediator, the mediation session may be scheduled on a later date that is within the deadline to complete Mediation Proceedings set forth in ¶ (t) herein. If the mediation is to occur in person, the Assigned Mediator shall also select the location of the mediation, *provided, however*, that, unless otherwise agreed by the parties and the Assigned Mediator, any in-person mediation shall occur only within the District of Connecticut or the New York City metropolitan area at (i) the offices of Trustee's counsel, (ii) a facility of the United States Bankruptcy Court for the District of Connecticut, or (iii) the offices of the Assigned Mediator. The Assigned Mediator shall provide at least twenty-one (21) days' written notice of the first date, time, and place of the mediation (the "Mediation Notice"), which Mediation Notice the Assigned Mediator shall cause to be filed in the relevant Avoidance Action.

p. Upon consent of the parties at least seven (7) days prior to any scheduled mediation session, the Assigned Mediator may (at their discretion) reschedule such mediation session. If the Trustee or the relevant Avoidance Defendant seeks to reschedule a mediation session absent the counter-party's or the Assigned Mediator's consent or within seven (7) days of the mediation session, such request shall be made by letter to Judge Tancredi via his courtroom deputy and the counter-party and/or Assigned Mediator shall submit any response to Judge Tancredi likewise by letter to his courtroom deputy. Judge Tancredi will then determine whether the mediation session shall be rescheduled and, if the mediation session was scheduled to occur in less than seven (7) days from the date of the request, whether the Assigned Mediator is entitled to compensation and which party(ies) shall be responsible for same.

q. All proceedings and writings incident to Mediation Proceedings shall be considered privileged and confidential and subject to all protections of Federal Rule of Evidence 408 and shall not be reported or admitted as evidence for any reason except to prove that a party failed to comply with the Mediation Procedures. No Assigned Mediator nor Judge Tancredi shall be called as a witness by any party except as set forth in this paragraph. No party shall attempt to compel the testimony of, or compel the production of documents from, the Assigned Mediator (including their agents, partners, or employees of their respective law firms or organizations) or Judge Tancredi, *provided, however*, subject to Court order, an Assigned Mediator may be called as a witness by any party and may be compelled to testify on a limited basis in proceedings where it is alleged that a party failed to comply with the Mediation Procedures. Any documents provided to the Assigned Mediator by the parties shall be destroyed within thirty (30) days after the filing of the Mediator's Report unless the Assigned Mediator is otherwise ordered by the Court.

r. The Assigned Mediator shall preside over any mediation sessions with full authority to determine the nature and order of the parties' presentations, and the rules of evidence shall not apply. The Assigned Mediator may implement additional procedures which are reasonable and practical under the circumstances. The Trustee and any Avoidance Defendant that is party to Mediation Proceedings may communicate *ex-parte* with their Assigned Mediator(s) to the extent that their Assigned Mediator(s) deem(s) appropriate. The Trustee and his counsel may communicate *ex-parte* with Judge Tancredi concerning the implementation of these Mediation Procedures, the selection of mediators to the Mediation Panel, the categorization of Avoidance Actions, and/or any recommendations issued by Judge Tancredi to the Court.

s. The parties to any Mediation Proceedings shall participate in such proceedings as scheduled and presided over by the Assigned Mediator in good faith and with a view toward reaching a consensual resolution. Mediation sessions shall be attended (either in person or, where permitted, by videoconference) by a representative of the Defendant will full settlement authority (and if a Defendant is represented by counsel, their counsel) as well as by the Trustee and/or counsel for the Trustee (who must have settlement authority from the Trustee). Assigned Mediators may, in their discretion, request the parties to prepare mediation statements in advance of mediation; unless otherwise instructed by the Assigned Mediator, such mediation statements shall not be shared with the other party to the mediation. The Assigned Mediator may issue further instructions regarding the mediation statements to the parties.

t. The Assigned Mediator, in the Mediation Notice or in a separate notice that need not be filed, may require the parties to provide to the Assigned Mediator any relevant papers and exhibits, statements of position, and/or settlement proposals. In the Assigned Mediator's discretion, upon notice (which need not be filed), the Assigned Mediator may adjourn a mediation or move a mediation to a different location within those locations authorized by the Mediation Procedures. The Assigned Mediator may also continue a mediation that has been commenced for additional sessions upon the request of the parties to the mediation or if the Assigned Mediator determines that a continuation is in the best interest of the parties, *provided, however*, no Mediation Proceedings shall continue for a period beyond one-hundred-eighty (180) days following the Mediation Referral unless the period to mediate is extended by order of this Court on the request of Judge Tancredi, which request and order shall be filed on the docket in the relevant Avoidance Action. In the event that additional mediation sessions are held beyond the initial mediation session, the Assigned Mediator may, in their discretion, permit that such sessions be held by videoconference.

u. Unless otherwise agreed or ordered by Judge Tancredi or the Court, the fees and costs of the Assigned Mediator, if any (the "Mediation Fee"), shall be paid equally by the parties to any Mediation Proceedings with the Mediation Fee for the initial mediation session due at least seven (7) days prior to the date such session is scheduled. Upon a showing that the payment of such amounts constitutes a hardship (submitted in writing with notice to all counter-parties to any Mediation Proceedings), Judge Tancredi or the Court may modify the parties' responsibilities for the Mediation Fee, *provided, however*, such relief shall be sought at least fourteen (14) days before any such Mediation Fee is due to be paid. The Mediation Fee shall be determined using the rates approved by the Court in connection with the appointment of the members of the Mediation Panel.

v. Within seven (7) days after the conclusion of the mediation, the Assigned Mediator shall file a report (the "Mediator's Report") in the relevant Avoidance Action indicating whether the parties to the Mediation Proceedings complied with the Mediation Procedures and whether the Mediation Proceedings resulted in a settlement. The Mediator's Report shall not address the substance of mediation discussions or provide details of any settlement that might be reached. In addition, in the case of material noncompliance with the Mediation Procedures, an Assigned Mediator may file an interim report (an "Interim Report") in the relevant Avoidance Action advising the Court of such noncompliance. Where a Mediator's Report or an Interim Report indicates noncompliance with the Mediation Procedures, the Court may (without the filing of a motion by any party) schedule a hearing to consider the appropriateness of sanctions against the noncompliant party. Such sanctions may include, without limitation, assessing costs of the Mediation Proceedings and/or the opposing party's attorneys' fees against the noncompliant party. Additionally, in cases of willful, persistent, or egregious noncompliance, the Court may enter a default judgment or dismissal against the party that failed to comply with the Mediation Procedures. Additionally, if any party to Mediation Proceedings is not attempting to schedule or resolve the mediation in good faith, an opposing party may file a motion for sanctions with the Court. Litigation with respect to the issuance of sanctions shall not delay the commencement of mediation. Failure to achieve settlement alone cannot constitute grounds for a finding of "bad faith" or other sanctions.

w. If the Mediator's Report indicates that the Mediation Proceedings resulted in a settlement and the settlement requires approval of the Court, the Trustee shall file a motion requesting such approval within thirty (30) days of the issuance of the Mediator's Report. The Trustee may submit a motion seeking such approval under seal (with access limited to the Trustee, the relevant Avoidance Defendant, the Official Committee of Unsecured Creditors, and the United States Trustee) to the extent the Trustee believes that public disclosure of the settlement terms would harm the estate and/or would implicate commercially sensitive or otherwise confidential information public disclosure of which would prejudice parties to the settlement. Where a motion is filed under seal, the Trustee shall file on the public docket a copy of the motion that redacts any commercially sensitive or otherwise confidential information.

x. If a Mediator's Report does not indicate a full settlement of the claims between the Trustee and the Avoidance Defendant, the deadline to respond to the Trustee's Avoidance Complaint shall be thirtysixty (3060) days from the filing of the Mediator's Report.

y. Members of the Mediation Panel (if any) shall regularly consult with Judge Tancredi concerning the status of Mediation Proceedings to which they are assigned. In addition, to facilitate the mediation process and to minimize any burden on Judge Tancredi, the Trustee shall endeavor, in consultation with Judge Tancredi, to devise categories of Avoidance Action claims (whether by amounts of transfers, timing of transfers, alter egos at issue, or otherwise). Such categorization shall not have any binding effect on any Avoidance Defendants as relates to the merits of claims or defenses in an Avoidance Action. Judge Tancredi may submit reports to the Court regarding the progress of Mediation Proceedings and any recommendations of Judge Tancredi to promote the efficient administration of the Avoidance Actions. Such reports shall be issued in writing and filed on the docket in the Main Case. Without limitation, these recommendations may include that certain Avoidance Actions and/or certain categories of Avoidance Actions be stayed for a fixed period prior to commencing one-on-one Mediation Proceedings. During the period of such a stay or otherwise, in order to facilitate the exchange of information and to encourage productive negotiations between the Trustee and Avoidance Defendants, Judge Tancredi may schedule informational sessions and/or mediation sessions that include multiple Avoidance Defendants and/or certain categories of Avoidance Defendants. To the extent that Judge Tancredi recommends staying any Avoidance Actions and/or categories of Avoidance Actions, the Trustee (within seven (7) days of the issuance of such recommendations) shall cause notice of same to be filed in such actions. Upon a hearing but without need for the filing of a motion, the Court may enter further orders addressing any recommendations issued by Judge Tancredi, including, without limitation, the stay of any Avoidance Actions or categories of Avoidance Actions prior to one-on-one mediation.

z. Notwithstanding anything in the Avoidance Action Procedures to the contrary, these Mediation Procedures may be modified by the Court upon the request of the Trustee or any other party in interest, or as otherwise ordered by the Court (including, without limitation, upon recommendations issued by Judge Tancredi), upon notice issued in the Main Case only and an opportunity for a hearing, *provided, however*, the revised Mediation Procedures, upon approval, shall be filed in all Avoidance Actions.

3. Within seven (7) days of the entry of this Order, the Trustee shall file the Avoidance Action Procedures Notice (in the revised form attached hereto as Exhibit 1) in all Avoidance Actions pending as of the entry of this Order.

4. The time periods set forth in this Order and the Avoidance Action Procedures shall be calculated in accordance with Bankruptcy Rule 9006(a).

5. To the extent that information in an Avoidance Complaint (or its exhibits) may be subject to the Privacy Act of 1974, 5 U.S.C. § 552a, et al., this Order constitutes an order of a court of competent jurisdiction authorizing the disclosure of such information to any Avoidance Defendant and its counsel, pursuant to 5 U.S.C. § 552a(b)(11) and 12 C.F.R § 310.10(b). This Order also amends the Protective Order and the P.O. Addendum to permit the Trustee, to the extent provided in the Avoidance Action Procedures, to disclose to any Avoidance Defendant information in an Avoidance Complaint (filed against such defendant) that is designated as highly confidential under the Protective Order or the P.O. Addendum.; *provided that*, (i) the Trustee shall provide the party that designated the information as highly confidential at least 5 business days' notice of the intent to share this information with an Avoidance Defendant and the identity of that Avoidance Defendant, (ii) the Trustee shall not provide this information to an Avoidance Defendant if an objection is raised absent further order the Court, and (iii) the proposed recipient of the highly confidential information has agreed to be bound by the Protective Order and P.O. Addendum in writing provided to the party that provided the information to the Trustee.

6. Pursuant to District of Connecticut Local Rule of Civil Procedure 5(e), District of Connecticut Local Rule of Bankruptcy Procedure 9077-1, Bankruptcy Rule 9018, and section 107(b) of the Bankruptcy Code, this constitutes an Order of the Court authorizing the sealed filing of Avoidance Complaints and of motions seeking approval of settlements to the extent permitted by the Mediation Procedures.

7. Any Avoidance Defendant may request that the District Court withdraw the reference to this case or any proceeding at any time pursuant to 28 U.S.C. §158(d) and that request, including briefing and resolution, shall not be stayed by any provision of this Order.

8. 7. The Court retains jurisdiction with respect to all matters arising from or related to the implementation of this Order.

8. This Order shall be effective immediately upon entry.

## **EXHIBIT 1**

**(Form Notice of Applicability of Avoidance Action Procedures)**

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

----------------------------------------------------- x

In re:

HO WAN KWOK, *et al*.,1

Chapter 11

Case No. 22-50073 (JAM)

Debtors.

(Jointly Administered)

----------------------------------------------------- x

LUC A. DESPINS, CHAPTER 11 TRUSTEE,

Plaintiff,

Adv. Proceeding No. [ ]

v.

[NAME OF DEFENDANT]

Defendant.

----------------------------------------------------- x

### **NOTICE OF APPLICABILITY OF AVOIDANCE ACTION PROCEDURES**

PLEASE TAKE NOTICE, that the Amended Order Approving Procedures Applicable to Avoidance Claim Adversary Proceedings entered by the Bankruptcy Court in the above-captioned chapter 11 case [ECF No. \_\_\_] appended hereto as **Exhibit A**, is hereby made applicable to and governs this adversary proceeding.

Dated: \_\_\_\_\_\_\_\_\_ \_\_, 2024

<sup>1</sup> 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).

New Haven, Connecticut

By: *\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_*

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

*and*

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

*Counsel for the Chapter 11 Trustee*

## **EXHIBIT 2**

**(Caption Applicable to Omnibus Filings)**

| UNITED STATES BANKRUPTCY COURT<br>DISTRICT OF CONNECTICUT<br>BRIDGEPORT DIVISION |                                                                      |  |
|----------------------------------------------------------------------------------|----------------------------------------------------------------------|--|
| ------------------------------------------------------<br>:                      | x<br>Chapter 11                                                      |  |
| In re:<br>:<br>:                                                                 | Case No. 22-50073 (JAM)                                              |  |
| HO WAN KWOK, et al.,1<br>:                                                       |                                                                      |  |
| :<br>Debtors.<br>:                                                               | (Jointly Administered)                                               |  |
| :                                                                                |                                                                      |  |
| ------------------------------------------------------<br>:                      | x<br>Adv. Proc. Nos. 24-XXXX, 24-XXXX,<br>24-XXXX, 24-XXXX, 24-XXXX, |  |
| LUC A. DESPINS, CHAPTER 11<br>:                                                  | 24-XXXX, 24-XXXX, 24-XXXX, 24-                                       |  |
| TRUSTEE,<br>:                                                                    | XXXX, 24-XXXX, 24-XXXX, 24-XXXX,                                     |  |
| :                                                                                | 24-XXXX, 24-XXXX, 24-XXXX, 24-                                       |  |
| Plaintiff,<br>:                                                                  | XXXX, 24-XXXX, 24-XXXX, 24-XXXX,                                     |  |
| v.<br>:<br>:                                                                     | 24-XXXX, 24-XXXX, 24-XXXX, 24-<br>XXXX, 24-XXXX, 24-XXXX, 24-XXXX,   |  |
| :                                                                                | 24-XXXX, 24-XXXX, 24-XXXX, 24-                                       |  |
| :                                                                                | XXXX, 24-XXXX, 24-XXXX, 24-XXXX,                                     |  |
| AVOIDANCE DEFENDANTS<br>:                                                        | 24-XXXX, 24-XXXX, 24-XXXX, 24-                                       |  |
| :                                                                                | XXXX, 24-XXXX, 24-XXXX, 24-XXXX,                                     |  |
| Defendants.<br>:                                                                 | 24-XXXX, 24-XXXX, 24-XXXX, 24-                                       |  |
|                                                                                  | x<br>XXXX, 24-XXXX, 24-XXXX, 24-XXXX,                                |  |
|                                                                                  | 24-XXXX, 24-XXXX, 24-XXXX, 24-                                       |  |
|                                                                                  | XXXX, 24-XXXX, 24-XXXX, 24-XXXX,                                     |  |
|                                                                                  | 24-XXXX, 24-XXXX, 24-XXXX, 24-                                       |  |
|                                                                                  | XXXX, 24-XXXX, 24-XXXX, 24-XXXX,                                     |  |
|                                                                                  | 24-XXXX, 24-XXXX, 24-XXXX, 24-<br>XXXX, 24-XXXX, 24-XXXX, 24-XXXX,   |  |
|                                                                                  | 24-XXXX, 24-XXXX, 24-XXXX, 24-                                       |  |
|                                                                                  | XXXX, 24-XXXX, 24-XXXX, 24-XXXX,                                     |  |
|                                                                                  | 24-XXXX, 24-XXXX, 24-XXXX, 24-                                       |  |
|                                                                                  | XXXX, 24-XXXX, 24-XXXX, 24-XXXX,                                     |  |
|                                                                                  | 24-XXXX, 24-XXXX, 24-XXXX, 24-                                       |  |
|                                                                                  | XXXX, 24-XXXX, 24-XXXX, 24-XXXX,                                     |  |
|                                                                                  | 24-XXXX, 24-XXXX, 24-XXXX, 24-                                       |  |
| ------------------------------------------------------                           | XXXX, 24-XXXX, and 24-XXXX                                           |  |

<sup>1</sup> 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).

## **EXHIBIT 3-A**

**(Avoidance Actions Subject to Stay)**

| ADV. PROC. NO.          | FIRST NAMED DEFENDANT                           |
|-------------------------|-------------------------------------------------|
| Adv. Proc. No. 24-05008 | Boardwalk Motor Imports LLC                     |
| Adv. Proc. No. 24-05009 | Mercantile Bank International                   |
| Adv. Proc. No. 24-05012 | Ogier                                           |
| Adv. Proc. No. 24-05014 | Pillsbury Winthrop Shaw Pittman LLP             |
| Adv. Proc. No. 24-05017 | Post Oak Motor Cars LLC                         |
| Adv. Proc. No. 24-05020 | Slaughter Law Group PC                          |
| Adv. Proc. No. 24-05022 | FAM United LLC                                  |
| Adv. Proc. No. 24-05026 | Yieldesta LP                                    |
| Adv. Proc. No. 24-05029 | Great Bowery Inc dba Camilla Lowther Management |
| Adv. Proc. No. 24-05030 | Vision Knight Capital (China) Fund              |
| Adv. Proc. No. 24-05032 | Hugga LLC                                       |
| Adv. Proc. No. 24-05037 | Triple2 Digital                                 |
| Adv. Proc. No. 24-05038 | D4.Zero                                         |
| Adv. Proc. No. 24-05041 | CFG Global Limited                              |
| Adv. Proc. No. 24-05043 | Loro Piana                                      |
| Adv. Proc. No. 24-05045 | The Quinlan Law Firm LLC                        |
| Adv. Proc. No. 24-05046 | Janco SRL                                       |
| Adv. Proc. No. 24-05050 | Oro Mont Alpi SRL                               |
| Adv. Proc. No. 24-05051 | Mindy Wechsler                                  |
| Adv. Proc. No. 24-05052 | MF19 Inc                                        |
| Adv. Proc. No. 24-05056 | FFP (BVI) Limited                               |
| Adv. Proc. No. 24-05068 | Caribe Condado LLC                              |
| Adv. Proc. No. 24-05080 | Reinhard Plank SRL                              |
| Adv. Proc. No. 24-05083 | UK Import Services Limited                      |
| Adv. Proc. No. 24-05084 | Tavares Cutting Inc                             |
| Adv. Proc. No. 24-05087 | Mosaicon Shoes SRL                              |
| Adv. Proc. No. 24-05088 | Tokyoseiki Co LTD                               |
| Adv. Proc. No. 24-05089 | Pellettieri Di Parma SRL                        |
| Adv. Proc. No. 24-05091 | Shalom B LLC dba Asher Fabric Concepts          |
| Adv. Proc. No. 24-05094 | Solazzo Calzature SRL                           |
| Adv. Proc. No. 24-05095 | SOD Stone Offroad Design GmbH                   |
| Adv. Proc. No. 24-05096 | 1245 Factory Place LLC                          |
| Adv. Proc. No. 24-05097 | Liapull S.R.L.                                  |
| Adv. Proc. No. 24-05098 | Shing Seung Ankerite Engineering Ltd            |
| Adv. Proc. No. 24-05099 | American Arbitration Association                |
| Adv. Proc. No. 24-05104 | Ice24 SRO                                       |
| Adv. Proc. No. 24-05106 | REACH MFG                                       |
| Adv. Proc. No. 24-05111 | DNM Beauty Distribution                         |
| Adv. Proc. No. 24-05113 | 1322089 BC Ltd                                  |
| Adv. Proc. No. 24-05116 | Hilton Management LLC                           |

| Adv. Proc. No. 24-05118 | J Tan Jewelry Design Inc                           |
|-------------------------|----------------------------------------------------|
| Adv. Proc. No. 24-05121 | Shaylen Music LLC                                  |
| Adv. Proc. No. 24-05123 | Bestview1 Pty Ltd                                  |
| Adv. Proc. No. 24-05124 | Legends OWO LLC                                    |
| Adv. Proc. No. 24-05127 | Waycap SPA                                         |
| Adv. Proc. No. 24-05129 | Fay Ye                                             |
| Adv. Proc. No. 24-05131 | Lawrence River                                     |
| Adv. Proc. No. 24-05136 | ASAP SRL                                           |
| Adv. Proc. No. 24-05137 | Bellerive Attorneys at Law                         |
| Adv. Proc. No. 24-05139 | Houston Litstar LLC                                |
| Adv. Proc. No. 24-05140 | Quinones Law PLLC                                  |
| Adv. Proc. No. 24-05142 | Immobiliara Barbara 2000 SRL                       |
| Adv. Proc. No. 24-05143 | Dream Projects LLC                                 |
| Adv. Proc. No. 24-05146 | Fortnum Information Security Limited               |
| Adv. Proc. No. 24-05148 | Galaxy Ltd                                         |
| Adv. Proc. No. 24-05150 | Jialin Qin                                         |
| Adv. Proc. No. 24-05151 | Li Sho Yo                                          |
| Adv. Proc. No. 24-05153 | Ming Ni                                            |
| Adv. Proc. No. 24-05155 | Hayashi Meiou                                      |
| Adv. Proc. No. 24-05156 | 12476517 Canada Society                            |
| Adv. Proc. No. 24-05157 | DP Textile & Apparel Inc                           |
| Adv. Proc. No. 24-05160 | LA International Foundation                        |
| Adv. Proc. No. 24-05164 | National Sweepstakes Company LLC                   |
| Adv. Proc. No. 24-05165 | Oxford Visionary Ltd                               |
| Adv. Proc. No. 24-05166 | Chris Lee                                          |
| Adv. Proc. No. 24-05169 | D&D Solutions LLC                                  |
| Adv. Proc. No. 24-05170 | The Gertz File Investigative Reporting Project Inc |
| Adv. Proc. No. 24-05173 | Wenhua Gong                                        |
| Adv. Proc. No. 24-05174 | SGB Packaging                                      |
| Adv. Proc. No. 24-05176 | Luminescence Co Ltd                                |
| Adv. Proc. No. 24-05177 | Xiaobo He                                          |
| Adv. Proc. No. 24-05180 | Richmond Strategic Advisor                         |
| Adv. Proc. No. 24-05183 | Reverence Capital Partners Opportunities Fund I    |
| Adv. Proc. No. 24-05191 | (Cayman) LP<br>Deng Qian                           |
| Adv. Proc. No. 24-05193 | Fiesta Investments Ltd                             |
| Adv. Proc. No. 24-05195 | Shujuan Milne                                      |
| Adv. Proc. No. 24-05197 | Great Lakes Drone Company                          |
| Adv. Proc. No. 24-05198 | G-Service LLC                                      |
| Adv. Proc. No. 24-05205 | Marini Pietrantoni Muniz LLC                       |
| Adv. Proc. No. 24-05210 | Jiayao Gan                                         |
| Adv. Proc. No. 24-05212 | Michael Li and Co                                  |
| Adv. Proc. No. 24-05213 | GPS McQuhae LLP                                    |
|                         |                                                    |

| Adv. Proc. No. 24-05215 | Bradley Staple, dba Staples Building Solutions |
|-------------------------|------------------------------------------------|
| Adv. Proc. No. 24-05217 | Haisong Peng                                   |
| Adv. Proc. No. 24-05218 | Hou Yuan Chan                                  |
| Adv. Proc. No. 24-05224 | OSC Orbit Services Company LLC                 |
| Adv. Proc. No. 24-05227 | Tao Zheng                                      |
| Adv. Proc. No. 24-05230 | Cayuse Government Services                     |
| Adv. Proc. No. 24-05231 | 9 East 40th Street                             |
| Adv. Proc. No. 24-05232 | Daihao Zhou                                    |
| Adv. Proc. No. 24-05233 | Brune Law PC                                   |
| Adv. Proc. No. 24-05234 | Lyzon Enterprises Corporation                  |
| Adv. Proc. No. 24-05235 | Halley Chen CPA Professional Corporation       |
| Adv. Proc. No. 24-05236 | Feng Yi                                        |
| Adv. Proc. No. 24-05237 | Qiang Hu                                       |
| Adv. Proc. No. 24-05239 | Jianhai Jiao                                   |
| Adv. Proc. No. 24-05240 | Fengjie Ma                                     |
| Adv. Proc. No. 24-05241 | MZC Financial Inc                              |
| Adv. Proc. No. 24-05242 | Cotton Craft Textiles Intl Trading             |
| Adv. Proc. No. 24-05243 | Ihotry Ltd                                     |
| Adv. Proc. No. 24-05244 | Quick-Equip LLC                                |
| Adv. Proc. No. 24-05245 | RM Auctions Deutschland GmbH, et al.           |
| Adv. Proc. No. 24-05246 | WA & HF LLC                                    |
| Adv. Proc. No. 24-05248 | Curiosity Corp, et al.                         |
| Adv. Proc. No. 24-05250 | Scarabaeus Wealth Management AG                |
| Adv. Proc. No. 24-05251 | LLC Stz Fund No. 1                             |
| Adv. Proc. No. 24-05252 | Gettr USA Inc                                  |
| Adv. Proc. No. 24-05253 | Ivy Capital Advisor Limited                    |
| Adv. Proc. No. 24-05254 | NAV Consulting Inc                             |
| Adv. Proc. No. 24-05255 | Ziba Limited                                   |
| Adv. Proc. No. 24-05256 | New Mulberry PTE Ltd                           |
| Adv. Proc. No. 24-05257 | Mishcon de Reya LLP                            |
| Adv. Proc. No. 24-05258 | Hogan Lovells International LLP                |
| Adv. Proc. No. 24-05259 | Top Target General Trading LLC                 |
| Adv. Proc. No. 24-05260 | GCP Investment Advisors SL                     |
| Adv. Proc. No. 24-05261 | Starling                                       |
| Adv. Proc. No. 24-05262 | Red Team Partners                              |
| Adv. Proc. No. 24-05264 | Smaragdos Mamzeris                             |
| Adv. Proc. No. 24-05265 | Siu Ming Je                                    |
| Adv. Proc. No. 24-05266 | Gong Jianfen                                   |
| Adv. Proc. No. 24-05267 | Khaled Ashafy                                  |
| Adv. Proc. No. 24-05268 | Pure Global Group Limited                      |
| Adv. Proc. No. 24-05269 | Himalaya Australia Athena Farm Inc, et al.     |
| Adv. Proc. No. 24-05272 | Hayman Hong Kong Opportunities                 |
| Adv. Proc. No. 24-05274 | Kin Ming Je                                    |

Adv. Proc. No. 24-05275 Lamp Capital LLC, et al.

## **EXHIBIT 3-B**

**(Avoidance Actions Subject to Partial Stay)**

| ADV. PROC. NO.          | FIRST NAMED DEFENDANT                            |
|-------------------------|--------------------------------------------------|
| Adv. Proc. No. 24-05006 | AWS (Amazon Web Services)                        |
| Adv. Proc. No. 24-05007 | Blueberry Builders                               |
| Adv. Proc. No. 24-05011 | E.L.J.M. Consulting LLC                          |
| Adv. Proc. No. 24-05016 | Imperius International Trad Co Ltd               |
| Adv. Proc. No. 24-05019 | Mary Fashion SPA                                 |
| Adv. Proc. No. 24-05021 | Bannon Strategic Advisors Inc                    |
| Adv. Proc. No. 24-05023 | Studio Cataldi Group SRL                         |
| Adv. Proc. No. 24-05024 | TT Resources 1 Pty Ltd                           |
| Adv. Proc. No. 24-05028 | Yuqiang Qin & Yunfu Jiang                        |
| Adv. Proc. No. 24-05044 | Teris                                            |
| Adv. Proc. No. 24-05054 | Style Eyes Inc. d/b/a Ginger Finds               |
| Adv. Proc. No. 24-05057 | Amazon Inc                                       |
| Adv. Proc. No. 24-05058 | Anthem Blue Cross Blue Shield                    |
| Adv. Proc. No. 24-05059 | Federal Express                                  |
| Adv. Proc. No. 24-05060 | Apple Inc                                        |
| Adv. Proc. No. 24-05065 | A.Z. Bigiotterie S.A.S. DI Zanutto Gabriele & C. |
| Adv. Proc. No. 24-05069 | B&H Photo                                        |
| Adv. Proc. No. 24-05075 | Marcella Monica Falciani                         |
| Adv. Proc. No. 24-05077 | American Express                                 |
| Adv. Proc. No. 24-05081 | Victor-Oasis Consultancy Limited                 |
| Adv. Proc. No. 24-05090 | Swans Team Design Inc                            |
| Adv. Proc. No. 24-05093 | 2 B Packing LLC                                  |
| Adv. Proc. No. 24-05102 | Ocorian Consulting Ltd                           |
| Adv. Proc. No. 24-05105 | N87 Inc                                          |
| Adv. Proc. No. 24-05109 | Moran Yacht Management Inc                       |
| Adv. Proc. No. 24-05115 | Cloudflare                                       |
| Adv. Proc. No. 24-05122 | Indium Software Inc                              |
| Adv. Proc. No. 24-05125 | Rilievi Group SRL                                |
| Adv. Proc. No. 24-05133 | Beile Li                                         |
| Adv. Proc. No. 24-05134 | V.X. Cerda & Associates PA                       |
| Adv. Proc. No. 24-05135 | Liberty Jet Management                           |
| Adv. Proc. No. 24-05145 | Manhattan Motorcars Inc                          |
| Adv. Proc. No. 24-05152 | Troutman Pepper Hamilton Sanders LLP             |
| Adv. Proc. No. 24-05154 | Kamel Debeche                                    |
| Adv. Proc. No. 24-05159 | Gold Leaf Consulting Limited                     |
| Adv. Proc. No. 24-05161 | Mandelli USA Inc                                 |
| Adv. Proc. No. 24-05163 | Harcus Parker Limited                            |
| Adv. Proc. No. 24-05172 | Federal Corporation (Japan)                      |
| Adv. Proc. No. 24-05175 | Lau Lai Chun Annie                               |
| Adv. Proc. No. 24-05178 | Super Star Project Limited                       |

| Adv. Proc. No. 24-05179 | Rising Sun Capital Ltd               |
|-------------------------|--------------------------------------|
| Adv. Proc. No. 24-05188 | Berkeley Rowe Ltd                    |
| Adv. Proc. No. 24-05188 | Weddle Law PLLC                      |
| Adv. Proc. No. 24-05189 | TD Avenue (The Diamond Avenue)       |
| Adv. Proc. No. 24-05199 | Lawall & Mitchell LLC                |
| Adv. Proc. No. 24-05203 | Oasis Tech Limited                   |
| Adv. Proc. No. 24-05204 | G4S Security Systems (Hong Kong) Ltd |
| Adv. Proc. No. 24-05206 | Hao Haidong                          |
| Adv. Proc. No. 24-05221 | Gypsy Mei Food Services LLC          |
| Adv. Proc. No. 24-05223 | G-Translators Pty Ltd                |
| Adv. Proc. No. 24-05225 | Cirrus Design Corporation            |
| Adv. Proc. No. 24-05226 | ACASS Canada Ltd                     |
| Adv. Proc. No. 24-05238 | Qiang Guo                            |
| Adv. Proc. No. 24-05248 | Tut Co Limited                       |
| Adv. Proc. No. 24-05263 | BSA Strategic Fund I, et al.         |
| Adv. Proc. No. 24-05271 | Weihua Li, et al.                    |

Case 22-50073 Doc 3098 Filed 04/12/24 Entered 04/12/24 19:40:09 Page 34 of 69

### **EXHIBIT 4**

**(List of Avoidance Defendants Not Automatically Subject to Mediation Referral)**

- 1. ACA Capital Limited
- 2. Anton Development Limited
- 3. Bannon Strategic Advisors, Inc.
- 4. Barnett, Scott
- 5. Berkeley Rowe Limited
- 6. BSA Strategic Fund
- 7. BSA Strategic Fund I
- 8. Chiesa Shahinian & Giantomasi PC
- 9. China Golden Spring Group (Hong Kong) Ltd.
- 10. Debeche, Kamel
- 11. DiBattista, Anthony
- 12. Enriquez, Bernardo
- 13. Federal Corporation
- 14. Fiesta Investment Ltd. f/k/a Fiesta Property Developments Ltd.
- 15. G Club Holdco I LLC
- 16. G Club International Limited
- 17. G Club Operations LLC
- 18. G Club Three
- 19. G Fashion
- 20. G Fashion International Limited
- 21. G Fashion Media Group Inc.
- 22. Gettr USA, Inc.
- 23. GF Italy, LLC
- 24. GFNY Inc.
- 25. Gold Leaf Consulting Limited
- 26. Golden Gate Himalaya Farm LLC
- 27. Golden Spring (New York) Limited
- 28. Greenwich Land LLC
- 29. GS Security Solutions Inc.
- 30. G-Service LLC
- 31. G-Translators Pty Ltd
- 32. Guo, Mei
- 33. Guo, Qiang
- 34. Gypsy Mei Food Services LLC
- 35. HAA Group Pty Ltd
- 36. Hadjicharalambous, Alex
- 37. Hamilton Capital Holding Ltd
- 38. Hamilton Investment Management Ltd
- 39. Hamilton Opportunity Fund SPC
- 40. Han, Chunguang
- 41. Harcus Parker Limited
- 42. HCHK Property Management Inc.
- 43. HCHK Technologies Inc.
- 44. Himalaya Australia Athena Farm Inc.
- 45. Himalaya Australia PTY Ltd.
- 46. Himalaya Boston Mayflower LLC
- 47. Himalaya Currency Clearing Pty Ltd.
- 48. Himalaya International Clearing Ltd.
- 49. Himalaya International Financial Group Ltd
- 50. Himalaya International Reserves Ltd
- 51. Himalaya New World Inc.
- 52. Himalaya New York Rock
- 53. Himalaya Shanghai Farm LLC
- 54. Himalaya UK Club
- 55. Himalaya Worldwide LS
- 56. HML Vancouver Sailing Farm Ltd.
- 57. Hong Kong International Funds Investments Limited
- 58. Hudson Diamond NY LLC
- 59. Je, Kin Ming
- 60. Krasner, Max
- 61. Lamp Capital LLC
- 62. Lawall & Mitchell, LLC
- 63. Leading Shine NY Limited
- 64. Lee, Chris
- 65. Lexington Property and Staffing Inc.
- 66. Miller, Jason
- 67. Mitchell, Aaron
- 68. MOS Himalaya Foundation Inc.
- 69. Mountains of Spices Inc.
- 70. Ngok, Hing Chi
- 71. O.S.C. Orbit II Service Company LLC
- 72. Omicron Nutraceutical LLC
- 73. OSC Orbit Service Company LLC
- 74. Oxford Visionary Ltd.
- 75. Pillsbury Winthrop Shaw Pittman LLP
- 76. Rising Sun Capital Ltd.
- 77. Rong, Sin Ting
- 78. Rosy Acme Ventures Limited
- 79. Rule of Law III Foundation Inc.
- 80. Rule of Law Society IV Inc.
- 81. Saraca Media Group, Inc.
- 82. Taurus Fund LLC
- 83. The Francis Firm PLLC
- 84. Troutman Pepper Hamilton Sanders LLP
- 85. UK Himalaya Ltd.
- 86. V.X. Cerda & Associates P.A.
- 87. Wang, Yanping
- 88. Warroom Broadcasting & Media Communications LLC
- 89. Zeisler & Zeisler, P.C.
- 90. Zhang, Yongbing
- 91. Any potential Avoidance Defendant that is subject to a stipulated tolling order entered by the Court.

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# **EXHIBIT B**

**Trustee's April 10th Version of the Proposed Amended Procedures Order**

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

| -----------------------------------------------------------<br>In re:<br>1<br>HO WAN KWOK, et al.,<br>Debtors.<br>-----------------------------------------------------x----- | x<br>:<br>Chapter 11<br>:<br>:<br>Case No. 22-50073 (JAM)<br>:<br>:<br>(Jointly Administered)<br>:<br>:<br>x                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                  |
|-------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|-------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| LUC A. DESPINS, CHAPTER 11<br>TRUSTEE,<br>Plaintiff,<br>v.                                                                                                                    | :<br>Adv. Proc. Nos. 24-05005, 24-05006, 24-05007,<br>:<br>24-05008, 24-05009, 24-05010, 24-05011, 24-<br>:<br>:<br>05012, 24-05013, 24-05014, 24-05015, 24-05016,<br>:<br>24-05017, 24-05018, 24-05019, 24-05020, 24-<br>:<br>05021, 24-05022, 24-05023, 24-05024, 24-05025,<br>:<br>24-05026, 24-05027, 24-05028, 24-05029, 24-<br>:                                                                                                                                                                                                                                                                                                                                                                                                                                                                                        |
| AVOIDANCE DEFENDANTS<br>Defendants.                                                                                                                                           | 05030, 24-05031, 24-05032, 24-05033, 24-05034,<br>:<br>24-05035, 24-05036, 24-05037, 24-05038, 24-<br>:<br>:<br>05039, 24-05040, 24-05041, 24-05042, 24-05043,<br>:<br>24-05044, 24-05045, 24-05046, 24-05047, 24-<br>x<br>05048, 24-05049, 24-05050, 24-05051, 24-05052,<br>24-05053, 24-05054, 24-05055, 24-05056, 24-<br>05057, 24-05058, 24-05059, 24-05060, 24-05061,<br>24-05062, 24-05063, 24-05064, 24-05065, 24-<br>05066, 24-05067, 24-05068, 24-05069, 24-05070,<br>24-05071, 24-05072, 24-05073, 24-05074, 24-<br>05075, 24-05076, 24-05077, 24-05078, 24-05079,<br>24-05080, 24-05081, 24-05082, 24-05083, 24-<br>05084, 24-05085, 24-05086, 24-05087, 24-05088,<br>24-05089, 24-05090, 24-05091, 24-05092, 24-<br>05093, 24-05094, 24-05095, 24-05096, 24-05097,<br>24-05098, 24-05099, 24-05100, 24-05101, 24- |
| (caption continues on next page)                                                                                                                                              | 05102, 24-05102, 24-05103, 24-05104, 24-05105,<br>24-05106, 24-05107, 24-05108, 24-05109, 24-                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                 |

<sup>1</sup> 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).

05110, 24-05111, 24-05112, 24-05113, 24-05114, 24-05115, 24-05116, 24-05117, 24-05118, 24- 05119, 24-05120, 24-05121, 24-05122, 24-05123, 24-05124, 24-05125, 24-05126, 24-05127, 24- 05128, 24-05129, 24-05130, 24-05131, 24-05132, 24-05133, 24-05134, 24-05135, 24-05136, 24- 05137, 24-05138, 24-05139, 24-05140, 24-05141, 24-05142, 24-05143, 24-05144, 24-05145, 24- 05146, 24-05147, 24-05148, 24-05149, 24-05150, 24-05151, 24-05152, 24-05153, 24-05154, 24- 05155, 24-05156, 24-05157, 24-05158, 24-05159, 24-05160, 24-05161, 24-05162, 24-05163, 24- 05164, 24-05165, 24-05166, 24-05167, 24-05168, 24-05169, 24-05170, 24-05171, 24-05172, 24- 05173, 24-05174, 24-05175, 24-05176, 24-05177, 24-05178, 24-05179, 24-05180, 24-05181, 24- 05182, 24-05183, 24-05184, 24-05185, 24-05186, 24-05187, 24-05188, 24-05189, 24-05190, 24- 05191, 24-05192, 24-05193, 24-05194, 24-05195, 24-05196, 24-05197, 24-05198, 24-05199, 24- 05200, 24-05201, 24-05202, 24-05203, 24-05204, 24-05205, 24-05206, 24-05207, 24-05208, 24- 05209, 24-05210, 24-05211, 24-05212, 24-05213, 24-05214, 24-05215, 24-05216, 24-05217, 24- 05218, 24-05219, 24-05220, 24-05221, 24-05222, 24-05223, 24-05224, 24-05225, 24-05226, 24- 05227, 24-05228, 24-05229, 24-05230, 24-05231, 24-05232, 24-05233, 24-05234, 24-05235, 24- 05236, 24-05237, 24-05238, 24-05239, 24-05240, 24-05241, 24-05242, 24-05243, 24-05244, 24- 05245, 24-05246, 24-05247, 24-05248, 24-05250, 24-05251, 24-05252, 24-05253, 24-05254, 24- 05255, 24-05256, 24-05257, 24-05258, 24-05259, 24-05260, 24-05261, 24-05262, 24-05263, 24- 05264, 24-05265, 24-05266, 24-05267, 24-05268, 24-05269, 24-05270, 24-05271, 24-05272, 24- 05274, 24-05275

----------------------------------------------------x

2

#### **[REVISED PROPOSED] AMENDED ORDER APPROVING PROCEDURES APPLICABLE TO AVOIDANCE CLAIM ADVERSARY PROCEEDINGS**

Upon the motion (the "Motion")<sup>2</sup> of Luc A. Despins, in his capacity as the chapter 11 trustee (the "Trustee") appointed in the chapter 11 case of Ho Wan Kwok (the "Debtor"), for the entry of an order (this "Order"), pursuant to sections 105(a) and 363 of Title 11 of the United States Code (the "Bankruptcy Code"), Rules 7016, 7026, and 9006 of the Federal Rules of Bankruptcy Procedure (the "Bankruptcy Rules"), and Rule 7016-1 of the District of Connecticut Local Rules of Bankruptcy Procedure (the "Local Bankruptcy Rules"), to modify the Court's *Order Approving Procedures Applicable to Avoidance Claim Adversary Proceedings* [ECF No. 2578] (the "Avoidance Procedures Order") and thereby modifying the Avoidance Action Procedures to provide for the inclusion of certain procedures governing mediation of Avoidance Actions; and this Court having jurisdiction to consider the Motion and the relief requested therein in accordance with 28 U.S.C. §§ 157 and 1334 and the *Standing Order of Reference* from the United States District Court for the District of Connecticut; and consideration of the Motion and the relief requested therein being a core proceeding pursuant to 28 U.S.C. § 157(b); and venue being proper in this Court pursuant to 28 U.S.C. §§ 1408 and 1409; and the Court having found that the relief requested in the Motion is in the best interest of the Debtor's chapter 11 estate, its creditors, and all parties in interest; and due and sufficient notice of the Motion having been given under the particular circumstances; and it appearing that no other or further notice need be given; and upon all of the proceedings had before this Court, including a hearing held April 23, 2024; and any objections to the relief requested herein having been withdrawn or overruled on the merits; and after due deliberation and sufficient cause appearing therefor, it is hereby ORDERED THAT:

1. The Motion is granted as set forth herein.

<sup>2</sup> Capitalized terms used but not otherwise defined in this Order have the meanings ascribed to them in the Motion.

2. The Court hereby orders that the following amended Avoidance Action Procedures

shall govern the Avoidance Actions:

a. The Avoidance Action Procedures shall apply to any adversary proceedings commenced by the Trustee on or after February 1, 2024, in which the Trustee asserts claims solely under sections 544, 547, 548, 549, and 550 of the Bankruptcy Code and analogous claims under applicable state law (the "Avoidance Actions").

b. Upon filing a complaint commencing any Avoidance Action (an "Avoidance Complaint"), the Trustee shall file a Notice of Applicability of Avoidance Action Procedures in a form substantially similar to that attached hereto as **Exhibit 1** (the "Avoidance Action Procedures Notice"). The Trustee shall serve a copy of the Avoidance Action Procedures Notice on each defendant in an Avoidance Action (an "Avoidance Defendant") together with the Summons and Avoidance Complaint pursuant to Bankruptcy Rule 7004.

c. Motions affecting multiple Avoidance Actions shall be filed in each applicable Avoidance Action and shall use a caption substantially in the form attached hereto as **Exhibit 2**.

d. To the extent that an Avoidance Complaint (including exhibits) contains information that is designated confidential or highly confidential pursuant to the Protective Order [Main Case ECF No. 923] (the "Protective Order") and the Stipulated Addendum to Protective Order [Main Case ECF No. 2460] (the "P.O. Addendum"), the Trustee may file the Avoidance Complaint under seal (a "Sealed Avoidance Complaint"), provided, however, the Trustee shall file unsealed a copy of the Avoidance Complaint that redacts any information that is designated confidential or highly confidential (a "Redacted Avoidance Complaint"). Service of a Redacted Avoidance Complaint shall constitute sufficient service of a complaint as required by Bankruptcy Rule 7004. Notwithstanding anything to the contrary in the Protective Order and the P.O. Addendum, upon any Avoidance Defendant and its counsel each executing copies of Exhibit A to the Protective Order and, if applicable, Exhibit A to the P.O. Addendum, the Trustee may provide a copy of the unredacted Avoidance Complaint to such Avoidance Defendant.

e. An Avoidance Defendant's time to respond to any Avoidance Complaint (the "Response Date") shall be sixty (60) days from the date that service is effected on such Avoidance Defendant, *provided, however*, that, without further order of the Court, the Trustee and any Avoidance Defendant may stipulate to further extend the defendant's Response Date up to ninety (90) additional days. Any such stipulation shall be made in writing and filed on the docket in the applicable adversary proceeding.Avoidance Action. Notwithstanding anything herein to the contrary:

i. the Avoidance Actions set forth on **Exhibit 3-A** attached hereto (the "Stayed Avoidance Actions") shall be stayed pending further order of the Court. At such time that the stay of the Stayed Avoidance Actions is lifted, the Court shall determine whether the Stayed Avoidance Actions shall be subject to the Mediation Procedures and set deadlines for Avoidance Defendants in such actions to respond to the Avoidance Complaints.

ii. the Avoidance Actions set forth on **Exhibit 3-B** attached hereto (the "Partially Stayed Avoidance Actions") shall be stayed pending further order of the Court solely as to any legal or factual issues concerning whether ACA Capital Group Ltd, Anton Development Limited, G Club International Limited, G Club Operations LLC, G Fashion, G Fashion Media Group Inc., GFNY Inc., Hamilton Capital Holding Ltd, Himalaya International Clearing Ltd, Leading Shine NY Ltd, Rule of Law Foundation III Inc., Rule of Law Society IV Inc., and Saraca Media Group Inc. were alter-egos of the Debtor and/or whether the property of such entities was property of the Debtor and/or of the Debtor's chapter 11 estate (collectively, the "Stayed Issues"). For the avoidance of doubt, Partially Stayed Avoidance Actions shall proceed to mediation to the extent provided by the Mediation Procedures (as defined herein) as to all issues that are not Stayed Issues, *provided, however*, Stayed Issues may also be mediated on a voluntary basis.

iii. Upon the filing of any new Avoidance Action, the Trustee may designate such action a Stayed Avoidance Action or a Partially Stayed Avoidance Action by filing a notice of such designation (a "Stay Designation Notice") in the relevant Avoidance Action. Any Avoidance Defendant wishing to challenge a Stay Designation Notice shall file a response to such notice in the relevant Avoidance Action within seven (7) days of appearing in same, to which the Trustee may reply within fourteen (14) days of the filing of such response. Any disputes over a Stay Designation Notice shall be determined by the Court.

f. In the event that any Avoidance Defendant responds to an Avoidance Complaint by filing a motion pursuant to Civil Rule 12(b),, the Trustee shall have sixty (60) days to respond to such motion. , *provided, however*, if such a motion is filed while an Avoidance Action is subject to a stay or if an Avoidance Action is stayed while such a motion is pending, the Trustee shall have sixty (60) days to respond to such motion following the termination of the stay. An Avoidance Defendant shall have thirty (30) days to reply to any response by the Trustee to a motion filed pursuant to Civil Rule 12.

g. Unless otherwise ordered by the Court, no initial pretrial conference pursuant to Bankruptcy Rule 7016 will be held prior to discovery in any Avoidance Action and, accordingly, the Summons issued by the Clerk of the Court and served by the Trustee will not include a date for a pretrial conference. To the extent that a party to an Avoidance Action believes that a pretrial conference is necessary to address scheduling or other issues, any party may request such a conference at any time by filing a request on the docket in the Avoidance Action.

h. As soon as practicable following the Response Date, to the extent that an Avoidance Action is not stayed, the parties shall confer pursuant to Civil Rule 26(f) (the "Initial Case Conference") and, thereafter, the parties shall either file a joint proposed scheduling order governing discovery, summary judgment, and other pretrial proceedings, subject to Court approval. If the Court does not approve the joint proposed scheduling order, the Court shall schedule a pretrial conference to determine a scheduling order. If the parties do not agree on a joint proposed scheduling order, the parties shall request a pretrial conference to determine a scheduling order. If an Avoidance Action is stayed, the parties shall hold the Initial Case Conference as soon as practicable following the termination of the stay and thereafter shall otherwise comply with the foregoing procedure. Civil Rule 26 (to the extent incorporated by Bankruptcy Rule 7026), District of Connecticut Local Civil Rule 26, and District of Connecticut Local Bankruptcy Rule 7026-1 shall apply to the Avoidance Actions except to the extent that they are expressly modified by this Order or otherwise by order of the Court.

i. Any party to an Avoidance Action may request that the Avoidance Action Procedures be modified as applied in such Avoidance Action for good cause shown. Such modification shall be requested by motion filed in the applicable Avoidance Action.

j. Notwithstanding anything herein to the contrary, the Avoidance Action Procedures shall be subject to the following procedures governing mediation proceedings (the "Mediation Procedures"):") as to any Avoidance Defendant that was served with process prior to April 4, 2024: Upon the appearance of any Avoidance Defendant in an Avoidance Action prior to the expiration of such Avoidance Defendant's deadline to respond to the Trustee's Avoidance Complaint, the Trustee's claims against such Avoidance Defendant in such Avoidance Action shall automatically (and without further order) be referred (the "Mediation Referral") to non-binding mediation proceedings (as set forth herein, the "Mediation Proceedings"), *provided, however*, no Mediation Referral shall be deemed to have occurred prior to May 15, 2024. Upon a Mediation Referral, the Avoidance Action shall be stayed, as to such Avoidance Defendant only (including, without limitation, as to such Avoidance Defendant's obligation to respond to the Avoidance Complaint), pending the conclusion of Mediation Proceedings. If the Avoidance Defendant appears in the Avoidance Action after the Avoidance Defendant's time to respond to the Avoidance Complaint has expired, no Mediation Referral shall occur except upon a written stipulation by the Trustee and such Avoidance Defendant filed in the Avoidance Action or by order of the Court. For the avoidance of doubt, the staying of any Avoidance Action as to a particular Avoidance Defendant shall not stay the Avoidance Action as to any other Avoidance Defendant, nor shall the staying of a particular Avoidance Action as against an Avoidance Defendant stay any other claims by the Trustee against such Avoidance Defendant outside of such Avoidance Action (whether in other Avoidance Actions or otherwise). Notwithstanding anything herein to the contrary, no claims by the Trustee against the Avoidance Defendants set forth on the attached **Exhibit 4** shall be subject to a Mediation Referral except upon a stipulation between the Trustee and such Avoidance Defendant or by Order of the Court. To the extent that an Avoidance Defendant was not served with process prior to April 4, 2024, the Trustee may stipulate with such Avoidance Defendant to the application of the Mediation Procedures (with such stipulation to be made in writing and filed in the relevant Avoidance Action), or, following the service of such

Avoidance Defendant, the Trustee may file a motion (with notice to the Avoidance Defendant) requesting that the Mediation Procedures apply to such Avoidance Defendant.

k. United States Bankruptcy Judge James J. Tancredi ("Judge Tancredi") shall oversee all Mediation Proceedings, *provided, however*, mediations shall be conducted by Judge Tancredi or by a mediator from an approved panel of mediators of Avoidance Actions (the "Mediation Panel") if the Trustee determines, in consultation with Judge Tancredi, that it would be beneficial to create such a panel. The members of any Mediation Panel shall be selected by the Trustee in consultation with Judge Tancredi, subject to the Court's approval of the appointment of each such mediator and rates of compensation applicable to same. Such approval shall be requested by the Trustee in the Main Case only by motion filed in accordance with all applicable rules and served on all Avoidance Defendants subject to the Mediation Procedures, and the appointment of a mediator to the Mediation Panel shall become effective upon approval by the Court.

l. Within fourteen (14) days of any Mediation Referral, the Trustee and the relevant Avoidance Defendant shall jointly contact Judge Tancredi by letter submitted via Judge Tancredi's courtroom deputy briefly (and in a non-argumentative manner) describing the claims at issue and advising regarding their availability to participate in mediation in the following sixty (60) days as well as to whether the mediation session(s) should take place in person or via videoconference. Following receipt of such letter, Judge Tancredi shall assign the Avoidance Action to be mediated by himself or by a member of the Mediation Panel (the "Assigned Mediator") and shall direct that the mediation be conducted in person or via videoconference. Judge Tancredi may order that related Mediation Proceedings (including, where appropriate, where claims are asserted against multiple defendants in a single Avoidance Action) be consolidated.

m. Alternatively, any Avoidance Defendant that believes that the claims against it should not be subject to mediation may, within fourteen (14) days of the Mediation Referral, file a motion with the Court setting forth good cause to exempt the claims against it from the Mediation Procedures, with notice to the Trustee and Judge Tancredi. No Mediation Proceedings as to such an Avoidance Defendant shall occur pending the Court's determination of such a motion. If the Court grants the motion, the Mediation Proceedings shall be deemed immediately terminated and the Avoidance Defendant shall respond to the Trustee's Avoidance Complaint within thirty (30) days of such termination. If the Court denies the motion, the Trustee and the Avoidance Defendant shall contact Judge Tancredi by letter within fourteen (14) days of such denial pursuant to the procedure set forth in the foregoing paragraph l to obtain an Assigned Mediator.

n. Upon notification of their assignment, the Assigned Mediator shall have an opportunity to determine whether they have any conflicts with respect to the Avoidance DefendantAction subject to mediation and, in the event of a conflict, mayshall abstain from acting in the particular mediation unless such conflict is disclosed to and expressly waived by the Trustee and the Avoidance Defendant. If the Assigned Mediator abstains, Judge Tancredi shall assign an alternative mediator from the Mediation Panel or shall assign himself to the mediation. If a party to Mediation Proceedings believes that a conflict of interest precludes the service of the Assigned Mediator, such party may seek the assignment of a different Assigned Mediator by letter submitted to Judge Tancredi via his courtroom deputy (with copies to the opposing party and the Assigned Mediator) or by motion filed with the Court, *provided, however*, such relief may only be sought within seven (7fourteen

(14) days of a party's discovery of the basis for seeking such relief. To the extent that a conflict is disclosed by the Assigned Mediator or timely challenged by a party to a Mediation Proceeding, such Mediation Proceeding shall be suspended pending (a) selection by Judge Tancredi of an alternative mediator to serve as the Assigned Mediator, (b) waiver of the conflict, or (c) the denial of any request for reassignment.

o. Upon the assignment of the Assigned Mediator, the Trustee and the Avoidance Defendant shall confer with the Assigned Mediator regarding a date for the initial mediation session. The Assigned Mediator shall schedule the mediation to occur within sixty (60) days of assignment*, provided, however*, upon the consent of the parties and the Assigned Mediator, the mediation session may be scheduled on a later date that is within the deadline to complete Mediation Proceedings set forth in ¶ (t) herein. If the mediation is to occur in person, the Assigned Mediator shall also select the location of the mediation, *provided, however*, that, unless otherwise agreed by the parties and the Assigned Mediator, any in-person mediation shall occur only within the District of Connecticut or the New York City metropolitan area at (i) the offices of Trustee's counsel, (ii) a facility of the United States Bankruptcy Court for the District of Connecticut, or (iii) the offices of the Assigned Mediator. The Assigned Mediator shall provide at least twenty-one (21) days' written notice of the first date, time, and place of the mediation (the "Mediation Notice"), which Mediation Notice the Assigned Mediator shall cause to be filed in the relevant Avoidance Action.

p. Upon consent of the parties at least seven (7) days prior to any scheduled mediation session, the Assigned Mediator may (at their discretion) reschedule such mediation session. If the Trustee or the relevant Avoidance Defendant seeks to reschedule a mediation session absent the counter-party's or the Assigned Mediator's consent or within seven (7) days ofprior to the mediation session, such request shall be made by letter to Judge Tancredi via his courtroom deputy and the counter-party and/or Assigned Mediator shall submit any response to Judge Tancredi likewise by letter to his courtroom deputy. Judge Tancredi will then determine whether the mediation session shall be rescheduled and, if the mediation session was scheduled to occur in less than seven (7) days from the date of the request, whether the Assigned Mediator is entitled to compensation and which party(ies) shall be responsible for same.

q. All proceedings and writings incident to Mediation Proceedings shall be considered privileged and confidential and subject to all protections of Federal Rule of Evidence 408 and shall not be reported or admitted as evidence for any reason except to prove that a party failed to comply with the Mediation Procedures. No Assigned Mediator nor Judge Tancredi shall be called as a witness by any party except as set forth in this paragraph. No party shall attempt to compel the testimony of, or compel the production of documents from, the Assigned Mediator (including their agents, partners, or employees of their respective law firms or organizations) or Judge Tancredi, *provided, however*, subject to Court order, an Assigned Mediator may be called as a witness by any party and may be compelled to testify on a limited basis in proceedings where it is alleged that a party failed to comply with the Mediation Procedures. Any documents provided to the Assigned Mediator by the parties shall be destroyed within thirty (30) days after the filing of the Mediator's Report unless the Assigned Mediator is otherwise ordered by the Court.

r. The Assigned Mediator shall preside over any mediation sessions with full authority to determine the nature and order of the parties' presentations, and the rules of evidence shall not apply. The Assigned Mediator may implement additional procedures which are reasonable and practical under the circumstances. The Trustee and any Avoidance Defendant that is party to Mediation Proceedings may communicate *ex-parte*  with their Assigned Mediator(s) to the extent that their Assigned Mediator(s) deem appropriate. The Trustee and his counsel may communicate *ex-parte* with Judge Tancredi concerning the implementation of these Mediation Procedures, the selection of mediators to the Mediation Panel, the categorization of Avoidance Actions, and/or any recommendations issued by Judge Tancredi to the Court.

s. The parties to any Mediation Proceedings shall participate in such proceedings as scheduled and presided over by the Assigned Mediator in good faith and with a view toward reaching a consensual resolution. Mediation sessions shall be attended (either in person or, where permitted, by videoconference) by a representative of the Defendant willwith full settlement authority (and if a Defendant is represented by counsel, their counsel) as well as by the Trustee and/or counsel for the Trustee (who must have settlement authority from the Trustee). Assigned Mediators may, in their discretion, request the parties to prepare mediation statements in advance of mediation; unless otherwise instructed by the Assigned Mediator, such mediation statements shall not be shared with the other party to the mediation. The Assigned Mediator may issue further instructions regarding the mediation statements to the parties.

t. The Assigned Mediator, in the Mediation Notice or in a separate notice that need not be filed, may require the parties to provide to the Assigned Mediator any relevant papers and exhibits, statements of position, and/or settlement proposals. In the Assigned Mediator's discretion, upon notice (which need not be filed), the Assigned Mediator may adjourn a mediation or move a mediation to a different location within those locations authorized by the Mediation Procedures. The Assigned Mediator may also continue a mediation that has been commenced for additional sessions upon the request of the parties to the mediation or if the Assigned Mediator determines that a continuation is in the best interest of the parties, *provided, however*, no Mediation Proceedings shall continue for a period beyond one-hundred-eighty (180) days following the Mediation Referral unless the period to mediate is extended by order of this Court on the request of Judge Tancredi, which request and order shall be filed on the docket in the relevant Avoidance Action. In the event that additional mediation sessions are held beyond the initial mediation session, the Assigned Mediator may, in their discretion, permit that such sessions be held by videoconference.

u. Unless otherwise agreed or ordered by Judge Tancredi or the Court, the fees and costs of the Assigned Mediator, if any (the "Mediation Fee"), shall be paid equally by the parties to any Mediation Proceedings with the Mediation Fee for the initial mediation session due at least seven (7) days prior to the date such session is scheduled. Upon a showing that the payment of such amounts constitutes a hardship (submitted in writing with notice to all counter-parties to any Mediation Proceedings), Judge Tancredi or the Court may modify the parties' responsibilities for the Mediation Fee, *provided, however*, such relief shall be sought at least fourteen (14) days before any such Mediation Fee is due to be paid. If such relief is requested from the Court, it shall be requested in writing filed in the relevant Avoidance Action(s), which may be filed under seal, *provided, however*, the Avoidance Defendant shall provide a copy of any such sealed filing to the Trustee. Any response by the Trustee to such a sealed filing may likewise be filed under seal with reciprocal notice to the relevant Avoidance Defendant. The Mediation Fee shall be determined using the rates approved by the Court in connection with the appointment of the members of the Mediation Panel.

v. Within seven (7) days after the conclusion of the mediation, the Assigned Mediator shall file a report (the "Mediator's Report") in the relevant Avoidance Action indicating whether the parties to the Mediation Proceedings complied with the Mediation Procedures and whether the Mediation Proceedings resulted in a settlement. The Mediator's Report shall not address the substance of mediation discussions. or provide details of any settlement that might be reached. In addition, in the case of material noncompliance with the Mediation Procedures, an Assigned Mediator may file an interim report (an "Interim Report") in the relevant Avoidance Action advising the Court of such noncompliance. Where a Mediator's Report or an Interim Report indicates noncompliance with the Mediation Procedures, the Court may (without the filing of a motion by any party) schedule a hearing to consider the appropriateness of sanctions against the noncompliant party. Such sanctions may include, without limitation, assessing costs of the Mediation Proceedings and/or the opposing party's attorneys' fees against the noncompliant party. Additionally, in cases of willful, persistent, or egregious noncompliance, the Court may enter a default judgment or dismissal against the party that failed to comply with the Mediation Procedures. Additionally, if any party to Mediation Proceedings is not attempting to schedule or resolve the mediation in good faith, an opposing party may file a motion for sanctions with the Court. Litigation with respect to the issuance of sanctions shall not delay the commencement of mediation. Failure to achieve settlement alone cannot constitute grounds for a finding of "bad faith" or the imposition of sanctions.

w. If the Mediator's Report indicates that the Mediation Proceedings resulted in a settlement and the settlement requires approval of the Court, the Trustee shall file a motion requesting such approval within thirty (30) days of the issuance of the Mediator's Report. The Trustee may submit a motion seeking such approval under seal (with access limited to the Trustee, the relevant Avoidance Defendant, the Official Committee of Unsecured Creditors, and the United States Trustee) to the extent the Trustee believes that public disclosure of the settlement terms would harm the estate and/or would implicate commercially sensitive or otherwise confidential information public disclosure of which would prejudice parties to the settlement. Where a motion is filed under seal, the Trustee shall file on the public docket a copy of the motion that redacts any commercially sensitive or otherwise confidential information.

x. If a Mediator's Report does not indicate a full settlement of the claims between the Trustee and the Avoidance Defendant, the deadline to respond to the Trustee's Avoidance Complaint shall be thirty (30) days from the filing of the Mediator's Report.

y. Members of the Mediation Panel (if any) shall regularly consult with Judge Tancredi concerning the status of Mediation Proceedings to which they are assigned. In addition, to facilitate the mediation process and to minimize any burden on Judge Tancredi, the Trustee shall endeavor, in consultation with Judge Tancredi, to devise categories of Avoidance Action claims (whether by amounts of transfers, timing of transfers, alter egos at issue, or otherwise). Such categorization shall not have any binding effect on any Avoidance Defendants as relates to the merits of claims or defenses in an Avoidance Action. Judge Tancredi may submit reports to the Court regarding the progress of Mediation Proceedings and any recommendations of Judge Tancredi to promote the efficient administration of the Avoidance Actions. Such reports shall be issued in writing and filed on the docket in the Main Case. Without limitation, these recommendations may include that certain Avoidance Actions and/or certain categories of Avoidance Actions be stayed for a fixed period prior to commencing one-on-oneparticular Mediation Proceedings. During the period of such a stay or otherwise, in order to facilitate the exchange of information and to encourage productive negotiations between the Trustee and Avoidance Defendants, Judge Tancredi may schedule informational sessions and/or mediation sessions that include multiple Avoidance Defendants and/or certain categories of Avoidance Defendants. To the extent that Judge Tancredi recommends staying any Avoidance Actions and/or categories of Avoidance Actions, the Trustee (within seven (7) days of the issuance of such recommendations) shall cause notice of same to be filed in such actions. Upon a hearing, and any Avoidance Defendant impacted by such recommended stay may file a written response in its Avoidance Action(s) within seven (7) days of the filing of notice. Upon a hearing considering Judge Tancredi's recommendations and any timely written response but without need for the filing of a motion, the Court may enter further orders addressing any recommendations issued by Judge Tancredi, including, without limitation, the stay of any Avoidance Actions or categories of Avoidance Actions prior to one-on-one mediation.

z. Notwithstanding anything in the Avoidance Action Procedures to the contrary, these Mediation Procedures may be modified by the Court upon the request of the Trustee or any other party in interest, or as otherwise ordered by the Court (including, without limitation, upon recommendations issued by Judge Tancredi), upon notice issueda motion filed in the Main Case only in accordance with any applicable rules, *provided, however*, the revised Mediation Procedures, upon approval, shall be filed in all Avoidance Actions.

3. Within seven (7) days of the entry of this Order, the Trustee shall file the Avoidance

Action Procedures Notice (in the revised form attached hereto as Exhibit 1) in all Avoidance

Actions pending as of the entry of this Order.

4. The time periods set forth in this Order and the Avoidance Action Procedures shall

be calculated in accordance with Bankruptcy Rule 9006(a).

5. To the extent that information in an Avoidance Complaint (or its exhibits) may be subject to the Privacy Act of 1974, 5 U.S.C. § 552a, et al., this Order constitutes an order of a court of competent jurisdiction authorizing the disclosure of such information to any Avoidance Defendant and its counsel, pursuant to 5 U.S.C. § 552a(b)(11) and 12 C.F.R § 310.10(b). This Order also amends the Protective Order and the P.O. Addendum to permit the Trustee, to the extent provided in the Avoidance Action Procedures, to disclose to any Avoidance Defendant information in an Avoidance Complaint (filed against such defendant) that is designated as highly confidential under the Protective Order or the P.O. Addendum.

6. Pursuant to District of Connecticut Local Rule of Civil Procedure 5(e), District of Connecticut Local Rule of Bankruptcy Procedure 9077-1, Bankruptcy Rule 9018, and section 107(b) of the Bankruptcy Code, this constitutes an Order of the Court authorizing the sealed filing of Avoidance Complaints and of motions seeking approval of settlements to the extent permitted by the Mediation Procedures.

7. The Court retains jurisdiction with respect to all matters arising from or related to the implementation of this Order.

8. This Order shall be effective immediately upon entry.

#### **EXHIBIT 1**

**(Form Notice of Applicability of Avoidance Action Procedures)**

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

| -----------------------------------------------------------                                                               | x                                                                       |
|---------------------------------------------------------------------------------------------------------------------------|-------------------------------------------------------------------------|
| In re:                                                                                                                    | :<br>:<br>Chapter 11                                                    |
| 1<br>HO WAN KWOK, et al.,                                                                                                 | :<br>:<br>Case No. 22-50073 (JAM)                                       |
| Debtors.                                                                                                                  | :<br>:<br>(Jointly Administered)<br>:                                   |
| -----------------------------------------------------------<br>LUC A. DESPINS, CHAPTER 11<br>TRUSTEE,<br>Plaintiff,<br>v. | x<br>:<br>:<br>:<br>:<br>Adv. Proceeding No. [<br>]<br>:<br>:<br>:<br>: |
| [NAME OF DEFENDANT]                                                                                                       | :                                                                       |
| Defendant.<br>-----------------------------------------------------------                                                 | :<br>:<br>:<br>x                                                        |

#### **NOTICE OF APPLICABILITY OF AVOIDANCE ACTION PROCEDURES**

PLEASE TAKE NOTICE, that the Amended Order Approving Procedures Applicable to Avoidance Claim Adversary Proceedings entered by the Bankruptcy Court in the above-captioned chapter 11 case [ECF No. \_\_\_] appended hereto as **Exhibit A**, is hereby made applicable to and governs this adversary proceeding.

<sup>1</sup> 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).

Dated: \_\_\_\_\_\_\_\_\_ \_\_, 2024 New Haven, Connecticut

By: *\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_*

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

*and*

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

*Counsel for the Chapter 11 Trustee*

#### **EXHIBIT 2**

**(Caption Applicable to Omnibus Filings)**

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

| -----------------------------------------------------------<br>In re:<br>1<br>HO WAN KWOK, et al.,<br>Debtors.      | x<br>:<br>Chapter 11<br>:<br>:<br>Case No. 22-50073 (JAM)<br>:<br>:<br>(Jointly Administered)<br>:<br>:                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                   |
|---------------------------------------------------------------------------------------------------------------------|---------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| -----------------------------------------------------------<br>LUC A. DESPINS, CHAPTER 11<br>TRUSTEE,<br>Plaintiff, | x<br>Adv. Proc. Nos. 24-XXXX, 24-XXXX,<br>:<br>24-XXXX, 24-XXXX, 24-XXXX,<br>:<br>24-XXXX, 24-XXXX, 24-XXXX, 24-<br>:<br>XXXX, 24-XXXX, 24-XXXX, 24-XXXX,<br>:<br>24-XXXX, 24-XXXX, 24-XXXX, 24-<br>:<br>XXXX, 24-XXXX, 24-XXXX, 24-XXXX,                                                                                                                                                                                                                                                                                                                                                                                 |
| v.<br>AVOIDANCE DEFENDANTS                                                                                          | :<br>24-XXXX, 24-XXXX, 24-XXXX, 24-<br>:<br>XXXX, 24-XXXX, 24-XXXX, 24-XXXX,<br>:<br>24-XXXX, 24-XXXX, 24-XXXX, 24-<br>:<br>XXXX, 24-XXXX, 24-XXXX, 24-XXXX,<br>:<br>24-XXXX, 24-XXXX, 24-XXXX, 24-                                                                                                                                                                                                                                                                                                                                                                                                                       |
| Defendants.<br>-----------------------------------------------------------                                          | :<br>XXXX, 24-XXXX, 24-XXXX, 24-XXXX,<br>:<br>24-XXXX, 24-XXXX, 24-XXXX, 24-<br>x<br>XXXX, 24-XXXX, 24-XXXX, 24-XXXX,<br>24-XXXX, 24-XXXX, 24-XXXX, 24-<br>XXXX, 24-XXXX, 24-XXXX, 24-XXXX,<br>24-XXXX, 24-XXXX, 24-XXXX, 24-<br>XXXX, 24-XXXX, 24-XXXX, 24-XXXX,<br>24-XXXX, 24-XXXX, 24-XXXX, 24-<br>XXXX, 24-XXXX, 24-XXXX, 24-XXXX,<br>24-XXXX, 24-XXXX, 24-XXXX, 24-<br>XXXX, 24-XXXX, 24-XXXX, 24-XXXX,<br>24-XXXX, 24-XXXX, 24-XXXX, 24-<br>XXXX, 24-XXXX, 24-XXXX, 24-XXXX,<br>24-XXXX, 24-XXXX, 24-XXXX, 24-<br>XXXX, 24-XXXX, 24-XXXX, 24-XXXX,<br>24-XXXX, 24-XXXX, 24-XXXX, 24-<br>XXXX, 24-XXXX, and 24-XXXX |

<sup>1</sup> 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).

#### **EXHIBIT 3-A**

**(Avoidance Actions Subject to Stay)**

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|                         |                                        |  | Formatted       |  |
| ADV. PROC. NO.          | FIRST NAMED DEFENDANT                  |  |                 |  |
| Adv. Proc. No. 24-05008 | Boardwalk Motor Imports LLC            |  | Formatted       |  |
| Adv. Proc. No. 24-05009 | Mercantile Bank International          |  | Formatted       |  |
| Adv. Proc. No. 24-05012 | Ogier                                  |  | Formatted       |  |
| Adv. Proc. No. 24-05014 | Pillsbury Winthrop Shaw Pittman LLP    |  | Formatted       |  |
| Adv. Proc. No. 24-05017 | Post Oak Motor Cars LLC                |  | Formatted       |  |
| Adv. Proc. No. 24-05020 | Slaughter Law Group PC                 |  | Formatted       |  |
| Adv. Proc. No. 24-05022 | FAM United LLC                         |  | Formatted       |  |
| Adv. Proc. No. 24-05026 | Yieldesta LP                           |  |                 |  |
|                         | Great Bowery Inc dba Camilla Lowther   |  | Formatted       |  |
| Adv. Proc. No. 24-05029 | Management                             |  | Formatted       |  |
| Adv. Proc. No. 24-05030 | Vision Knight Capital (China) Fund     |  | Formatted       |  |
| Adv. Proc. No. 24-05032 | Hugga LLC                              |  | Formatted       |  |
| Adv. Proc. No. 24-05037 | Triple2 Digital                        |  | Formatted Table |  |
| Adv. Proc. No. 24-05038 | D4.Zero                                |  | Formatted       |  |
| Adv. Proc. No. 24-05041 | CFG Global Limited                     |  | Formatted       |  |
| Adv. Proc. No. 24-05043 | Loro Piana                             |  |                 |  |
| Adv. Proc. No. 24-05045 | The Quinlan Law Firm LLC               |  | Formatted       |  |
| Adv. Proc. No. 24-05046 | Janco SRL                              |  | Formatted       |  |
| Adv. Proc. No. 24-05050 | Oro Mont Alpi SRL                      |  | Formatted       |  |
| Adv. Proc. No. 24-05051 | Mindy Wechsler                         |  | Formatted       |  |
| Adv. Proc. No. 24-05052 | MF19 Inc                               |  | Formatted Table |  |
| Adv. Proc. No. 24-05056 | FFP (BVI) Limited                      |  | Formatted       |  |
| Adv. Proc. No. 24-05068 | Caribe Condado LLC                     |  | Formatted       |  |
| Adv. Proc. No. 24-05080 | Reinhard Plank SRL                     |  | Formatted       |  |
| Adv. Proc. No. 24-05083 | UK Import Services Limited             |  | Formatted       |  |
| Adv. Proc. No. 24-05084 | Tavares Cutting Inc                    |  |                 |  |
| Adv. Proc. No. 24-05087 | Mosaicon Shoes SRL                     |  | Formatted       |  |
| Adv. Proc. No. 24-05088 | Tokyoseiki Co LTD                      |  | Formatted       |  |
| Adv. Proc. No. 24-05089 | Pellettieri Di Parma SRL               |  | Formatted       |  |
| Adv. Proc. No. 24-05091 | Shalom B LLC dba Asher Fabric Concepts |  | Formatted       |  |
| Adv. Proc. No. 24-05094 | Solazzo Calzature SRL                  |  | Formatted       |  |
| Adv. Proc. No. 24-05095 | SOD Stone Offroad Design GmbH          |  | Formatted       |  |
| Adv. Proc. No. 24-05096 | 1245 Factory Place LLC                 |  | Formatted       |  |
| Adv. Proc. No. 24-05097 | Liapull S.R.L.                         |  | Formatted       |  |
| Adv. Proc. No. 24-05098 | Shing Seung Ankerite Engineering Ltd   |  |                 |  |
| Adv. Proc. No. 24-05099 | American Arbitration Association       |  | Formatted       |  |
| Adv. Proc. No. 24-05104 | Ice24 SRO                              |  | Formatted       |  |
| Adv. Proc. No. 24-05106 | REACH MFG                              |  | Formatted       |  |
| Adv. Proc. No. 24-05111 | DNM Beauty Distribution                |  | Formatted       |  |
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|                         |                                        |  |                 |  |

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| Adv. Proc. No. 24-05113 | 1322089 BC Ltd                                     |  |
|-------------------------|----------------------------------------------------|--|
|                         |                                                    |  |
| Adv. Proc. No. 24-05116 | Hilton Management LLC                              |  |
| Adv. Proc. No. 24-05118 | J Tan Jewelry Design Inc                           |  |
| Adv. Proc. No. 24-05121 | Shaylen Music LLC                                  |  |
| Adv. Proc. No. 24-05123 | Bestview1 Pty Ltd                                  |  |
| Adv. Proc. No. 24-05124 | Legends OWO LLC                                    |  |
| Adv. Proc. No. 24-05127 | Waycap SPA                                         |  |
| Adv. Proc. No. 24-05129 | Fay Ye                                             |  |
| Adv. Proc. No. 24-05131 | Lawrence River                                     |  |
| Adv. Proc. No. 24-05136 | ASAP SRL                                           |  |
| Adv. Proc. No. 24-05137 | Bellerive Attorneys at Law                         |  |
| Adv. Proc. No. 24-05139 | Houston Litstar LLC                                |  |
| Adv. Proc. No. 24-05140 | Quinones Law PLLC                                  |  |
| Adv. Proc. No. 24-05142 | Immobiliara Barbara 2000 SRL                       |  |
| Adv. Proc. No. 24-05143 | Dream Projects LLC                                 |  |
| Adv. Proc. No. 24-05146 | Fortnum Information Security Limited               |  |
| Adv. Proc. No. 24-05148 | Galaxy Ltd                                         |  |
| Adv. Proc. No. 24-05150 | Jialin Qin                                         |  |
| Adv. Proc. No. 24-05151 | Li Sho Yo                                          |  |
| Adv. Proc. No. 24-05153 | Ming Ni                                            |  |
| Adv. Proc. No. 24-05155 | Hayashi Meiou                                      |  |
| Adv. Proc. No. 24-05156 | 12476517 Canada Society                            |  |
| Adv. Proc. No. 24-05157 | DP Textile & Apparel Inc                           |  |
| Adv. Proc. No. 24-05160 | LA International Foundation                        |  |
| Adv. Proc. No. 24-05164 | National Sweepstakes Company LLC                   |  |
| Adv. Proc. No. 24-05165 | Oxford Visionary Ltd                               |  |
| Adv. Proc. No. 24-05166 | Chris Lee                                          |  |
| Adv. Proc. No. 24-05169 | D&D Solutions LLC                                  |  |
| Adv. Proc. No. 24-05170 | The Gertz File Investigative Reporting Project Inc |  |
| Adv. Proc. No. 24-05173 | Wenhua Gong                                        |  |
| Adv. Proc. No. 24-05174 | SGB Packaging                                      |  |
| Adv. Proc. No. 24-05176 | Luminescence Co Ltd                                |  |
| Adv. Proc. No. 24-05177 | Xiaobo He                                          |  |
| Adv. Proc. No. 24-05180 | Richmond Strategic Advisor                         |  |
| Adv. Proc. No. 24-05183 | Reverence Capital Partners Opportunities Fund I    |  |
|                         | (Cayman) LP                                        |  |
| Adv. Proc. No. 24-05191 | Deng Qian                                          |  |
| Adv. Proc. No. 24-05193 | Fiesta Investments Ltd                             |  |
| Adv. Proc. No. 24-05195 | Shujuan Milne                                      |  |
| Adv. Proc. No. 24-05197 | Great Lakes Drone Company                          |  |
|                         |                                                    |  |

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| Adv. Proc. No. 24-05205 | Marini Pietrantoni Muniz LLC                   |  |
|-------------------------|------------------------------------------------|--|
| Adv. Proc. No. 24-05210 | Jiayao Gan                                     |  |
| Adv. Proc. No. 24-05212 | Michael Li and Co                              |  |
| Adv. Proc. No. 24-05213 | GPS McQuhae LLP                                |  |
| Adv. Proc. No. 24-05215 | Bradley Staple, dba Staples Building Solutions |  |
| Adv. Proc. No. 24-05217 | Haisong Peng                                   |  |
| Adv. Proc. No. 24-05218 | Hou Yuan Chan                                  |  |
| Adv. Proc. No. 24-05224 | OSC Orbit Services Company LLC                 |  |
| Adv. Proc. No. 24-05227 | Tao Zheng                                      |  |
| Adv. Proc. No. 24-05230 | Cayuse Government Services                     |  |
| Adv. Proc. No. 24-05231 | 9 East 40th Street                             |  |
| Adv. Proc. No. 24-05232 | Daihao Zhou                                    |  |
| Adv. Proc. No. 24-05233 | Brune Law PC                                   |  |
| Adv. Proc. No. 24-05234 | Lyzon Enterprises Corporation                  |  |
| Adv. Proc. No. 24-05235 | Halley Chen CPA Professional Corporation       |  |
| Adv. Proc. No. 24-05236 | Feng Yi                                        |  |
| Adv. Proc. No. 24-05237 | Qiang Hu                                       |  |
| Adv. Proc. No. 24-05239 | Jianhai Jiao                                   |  |
| Adv. Proc. No. 24-05240 | Fengjie Ma                                     |  |
| Adv. Proc. No. 24-05241 | MZC Financial Inc                              |  |
| Adv. Proc. No. 24-05242 | Cotton Craft Textiles Intl Trading             |  |
| Adv. Proc. No. 24-05243 | Ihotry Ltd                                     |  |
| Adv. Proc. No. 24-05244 | Quick-Equip LLC                                |  |
| Adv. Proc. No. 24-05245 | RM Auctions Deutschland GmbH, et al.           |  |
| Adv. Proc. No. 24-05246 | WA & HF LLC                                    |  |
| Adv. Proc. No. 24-05248 | Curiosity Corp, et al.                         |  |
| Adv. Proc. No. 24-05250 | Scarabaeus Wealth Management AG                |  |
| Adv. Proc. No. 24-05251 | LLC Stz Fund No. 1                             |  |
| Adv. Proc. No. 24-05252 | Gettr USA Inc                                  |  |
| Adv. Proc. No. 24-05253 | Ivy Capital Advisor Limited                    |  |
| Adv. Proc. No. 24-05254 | NAV Consulting Inc                             |  |
| Adv. Proc. No. 24-05255 | Ziba Limited                                   |  |
| Adv. Proc. No. 24-05256 | New Mulberry PTE Ltd                           |  |
| Adv. Proc. No. 24-05257 | Mishcon de Reya LLP                            |  |
| Adv. Proc. No. 24-05258 | Hogan Lovells International LLP                |  |
| Adv. Proc. No. 24-05259 | Top Target General Trading LLC                 |  |
| Adv. Proc. No. 24-05260 | GCP Investment Advisors SL                     |  |
| Adv. Proc. No. 24-05261 | Starling                                       |  |
| Adv. Proc. No. 24-05262 | Red Team Partners                              |  |
| Adv. Proc. No. 24-05264 | Smaragdos Mamzeris                             |  |
| Adv. Proc. No. 24-05265 | Siu Ming Je                                    |  |

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3

| Adv. Proc. No. 24-05266 | Gong Jianfen                               |  |
|-------------------------|--------------------------------------------|--|
| Adv. Proc. No. 24-05267 | Khaled Ashafy                              |  |
| Adv. Proc. No. 24-05268 | Pure Global Group Limited                  |  |
| Adv. Proc. No. 24-05269 | Himalaya Australia Athena Farm Inc, et al. |  |
| Adv. Proc. No. 24-05272 | Hayman Hong Kong Opportunities             |  |
| Adv. Proc. No. 24-05274 | Kin Ming Je                                |  |
| Adv. Proc. No. 24-05275 | Lamp Capital LLC, et al.                   |  |

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#### **EXHIBIT 3-B**

**(Avoidance Actions Subject to Partial Stay)**

| ADV. PROC. NO.<br>FIRST NAMED DEFENDANT<br>AWS (Amazon Web Services)<br>Adv. Proc. No. 24-05006<br>Blueberry Builders<br>Adv. Proc. No. 24-05007<br>E.L.J.M. Consulting LLC<br>Adv. Proc. No. 24-05011<br>Imperius International Trad Co Ltd<br>Adv. Proc. No. 24-05016<br>Mary Fashion SPA<br>Adv. Proc. No. 24-05019<br>Bannon Strategic Advisors Inc<br>Adv. Proc. No. 24-05021<br>Studio Cataldi Group SRL<br>Adv. Proc. No. 24-05023<br>TT Resources 1 Pty Ltd<br>Adv. Proc. No. 24-05024<br>Yuqiang Qin & Yunfu Jiang<br>Adv. Proc. No. 24-05028<br>Teris<br>Adv. Proc. No. 24-05044<br>Style Eyes Inc. d/b/a Ginger Finds<br>Adv. Proc. No. 24-05054<br>Adv. Proc. No. 24-05056<br>FFP (BVI) Limited<br>Amazon Inc<br>Adv. Proc. No. 24-05057<br>Anthem Blue Cross Blue Shield<br>Adv. Proc. No. 24-05058<br>Federal Express<br>Adv. Proc. No. 24-05059<br>Apple Inc<br>Adv. Proc. No. 24-05060<br>A.Z. Bigiotterie S.A.S. DI Zanutto Gabriele & C.<br>Adv. Proc. No. 24-05065<br>B&H Photo<br>Adv. Proc. No. 24-05069<br>Marcella Monica Falciani<br>Adv. Proc. No. 24-05075<br>American Express<br>Adv. Proc. No. 24-05077<br>Adv. Proc. No. 24-05081<br>Victor-Oasis Consultancy Limited<br>Swans Team Design Inc<br>Adv. Proc. No. 24-05090<br>2 B Packing LLC<br>Adv. Proc. No. 24-05093<br>Ocorian Consulting Ltd<br>Adv. Proc. No. 24-05102<br>N87 Inc<br>Adv. Proc. No. 24-05105<br>Moran Yacht Management Inc<br>Adv. Proc. No. 24-05109<br>Cloudflare<br>Adv. Proc. No. 24-05115<br>Indium Software Inc<br>Adv. Proc. No. 24-05122<br>Rilievi Group SRL<br>Adv. Proc. No. 24-05125<br>Beile Li<br>Adv. Proc. No. 24-05133<br>V.X. Cerda & Associates PA<br>Adv. Proc. No. 24-05134<br>Liberty Jet Management<br>Adv. Proc. No. 24-05135 |  |  |                         |  |
|----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|--|--|-------------------------|--|
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|                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                          |  |  |                         |  |
|                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                          |  |  |                         |  |
|                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                          |  |  |                         |  |
|                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                          |  |  |                         |  |
|                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                          |  |  |                         |  |
| Adv. Proc. No. 24-05145                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                  |  |  | Manhattan Motorcars Inc |  |
| Adv. Proc. No. 24-05152<br>Troutman Pepper Hamilton Sanders LLP                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                          |  |  |                         |  |
| Kamel Debeche<br>Adv. Proc. No. 24-05154                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                 |  |  |                         |  |
| Gold Leaf Consulting Limited<br>Adv. Proc. No. 24-05159                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                  |  |  |                         |  |
| Mandelli USA Inc<br>Adv. Proc. No. 24-05161                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                              |  |  |                         |  |
| Adv. Proc. No. 24-05163<br>Harcus Parker Limited                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                         |  |  |                         |  |

| Formatted<br><br>Formatted<br><br>Formatted<br><br>Formatted Table<br><br>Formatted<br><br>Formatted<br><br>Formatted<br><br>Formatted<br><br>Formatted<br><br>Formatted<br><br>Formatted<br><br>Formatted<br><br>Formatted<br><br>Formatted<br><br>Formatted<br><br>Formatted<br><br>Formatted<br><br>Formatted<br><br>Formatted<br><br>Formatted<br><br>Formatted<br><br>Formatted<br><br>Formatted<br><br>Formatted<br><br>Formatted<br><br>Formatted<br><br>Formatted<br><br>Formatted<br><br>Formatted Table<br><br>Formatted<br><br>Formatted<br><br>Formatted<br><br>Formatted<br><br>Formatted<br><br>Formatted<br><br>Formatted<br><br>Formatted<br><br>Formatted<br><br>Formatted<br><br>Formatted<br><br>Formatted<br><br>Formatted<br><br>Formatted<br><br>Formatted<br><br>Formatted<br><br>Formatted Table<br><br>Formatted<br><br>Formatted<br><br>Formatted<br> |           |  |
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|                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                 | Formatted |  |
| Formatted                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                       |           |  |
| <br>Formatted                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                   |           |  |
| <br>Formatted<br>                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                               |           |  |

**Formatted** ... **Formatted** ... **Formatted** ... **Formatted** ... **Formatted** ... **Formatted** ... **Formatted** ... **Formatted** ... **Formatted** ... **Formatted** ... **Formatted** ... **Formatted** ... **Formatted** ... **Formatted** ... **Formatted** ... **Formatted** ... **Formatted** ... **Formatted Table** ... **Formatted** ... **Formatted** ... **Formatted** ... **Formatted** ...

| Adv. Proc. No. 24-05172 | Federal Corporation (Japan)          |  |  |
|-------------------------|--------------------------------------|--|--|
| Adv. Proc. No. 24-05175 | Lau Lai Chun Annie                   |  |  |
| Adv. Proc. No. 24-05178 | Super Star Project Limited           |  |  |
| Adv. Proc. No. 24-05179 | Rising Sun Capital Ltd               |  |  |
| Adv. Proc. No. 24-05188 | Berkeley Rowe Ltd                    |  |  |
| Adv. Proc. No. 24-05188 | Weddle Law PLLC                      |  |  |
| Adv. Proc. No. 24-05189 | TD Avenue (The Diamond Avenue)       |  |  |
| Adv. Proc. No. 24-05199 | Lawall & Mitchell LLC                |  |  |
| Adv. Proc. No. 24-05203 | Oasis Tech Limited                   |  |  |
| Adv. Proc. No. 24-05204 | G4S Security Systems (Hong Kong) Ltd |  |  |
| Adv. Proc. No. 24-05206 | Hao Haidong                          |  |  |
| Adv. Proc. No. 24-05221 | Gypsy Mei Food Services LLC          |  |  |
| Adv. Proc. No. 24-05223 | G-Translators Pty Ltd                |  |  |
| Adv. Proc. No. 24-05225 | Cirrus Design Corporation            |  |  |
| Adv. Proc. No. 24-05226 | ACASS Canada Ltd                     |  |  |
| Adv. Proc. No. 24-05238 | Qiang Guo                            |  |  |
| Adv. Proc. No. 24-05248 | Tut Co Limited                       |  |  |
| Adv. Proc. No. 24-05263 | BSA Strategic Fund I, et al.         |  |  |
| Adv. Proc. No. 24-05271 | Weihua Li, et al.                    |  |  |
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#### **EXHIBIT 4**

**(List of Avoidance Defendants Not Automatically Subject to Mediation Referral)**

- 1. ACA Capital Limited
- 2. Anton Development Limited
- 3. Bannon Strategic Advisors, Inc.
- 4. Barnett, Scott
- 5. Berkeley Rowe Limited
- 6. BSA Strategic Fund
- 7. BSA Strategic Fund I
- 8. Chiesa Shahinian & Giantomasi PC
- 9. China Golden Spring Group (Hong Kong) Ltd.
- 10. Debeche, Kamel
- 11. DiBattista, Anthony
- 12. Enriquez, Bernardo
- 13. Federal Corporation
- 14. Fiesta Investment Ltd. f/k/a Fiesta Property Developments Ltd.
- 15. G Club Holdco I LLC
- 16. G Club International Limited
- 17. G Club Operations LLC
- 18. G Club Three
- 19. G Fashion
- 20. G Fashion International Limited
- 21. G Fashion Media Group Inc.
- 22. Gettr USA, Inc.
- 23. GF Italy, LLC
- 24. GFNY Inc.
- 25. Gold Leaf Consulting Limited
- 26. Golden Gate Himalaya Farm LLC
- 27. Golden Spring (New York) Limited
- 28. Greenwich Land LLC
- 29. GS Security Solutions Inc.
- 30. G-Service LLC
- 31. G-Translators Pty Ltd
- 32. Guo, Mei
- 33. Guo, Qiang
- 34. Gypsy Mei Food Services LLC
- 35. HAA Group Pty Ltd
- 36. Hadjicharalambous, Alex
- 37. Hamilton Capital Holding Ltd
- 38. Hamilton Investment Management Ltd
- 39. Hamilton Opportunity Fund SPC
- 40. Han, Chunguang
- 41. Harcus Parker Limited
- 42. HCHK Property Management Inc.
- 43. HCHK Technologies Inc.

45. Himalaya Australia PTY Ltd. 46. Himalaya Boston Mayflower LLC 47. Himalaya Currency Clearing Pty Ltd. 48. Himalaya International Clearing Ltd. 49. Himalaya International Financial Group Ltd 50. Himalaya International Reserves Ltd 51. Himalaya New World Inc. 52. Himalaya New York Rock 53. Himalaya Shanghai Farm LLC 54. Himalaya UK Club 55. Himalaya Worldwide LS 56. HML Vancouver Sailing Farm Ltd. 57. Hong Kong International Funds Investments Limited 58. Hudson Diamond NY LLC 59. Je, Kin Ming 60. Krasner, Max 61. Lamp Capital LLC 62. Lawall & Mitchell, LLC 63. Leading Shine NY Limited 64. Lee, Chris 65. Lexington Property and Staffing Inc. 66. Miller, Jason 67. Mitchell, Aaron 68. MOS Himalaya Foundation Inc. 69. Mountains of Spices Inc. 70. Ngok, Hing Chi 71. O.S.C. Orbit II Service Company LLC 72. Omicron Nutraceutical LLC 73. OSC Orbit Service Company LLC 74. Oxford Visionary Ltd. 75. Pillsbury Winthrop Shaw Pittman LLP 76. Rising Sun Capital Ltd. 77. Rong, Sin Ting 78. Rosy Acme Ventures Limited 79. Rule of Law III Foundation Inc. 80. Rule of Law Society IV Inc. 81. Saraca Media Group, Inc. 82. Taurus Fund LLC 83. The Francis Firm PLLC 84. Troutman Pepper Hamilton Sanders LLP 85. UK Himalaya Ltd. 86. V.X. Cerda & Associates P.A.

44. Himalaya Australia Athena Farm Inc.

87. Wang, Yanping

- 88. Warroom Broadcasting & Media Communications LLC
- 89. Zeisler & Zeisler, P.C.

90. Zhang, Yongbing

- 91. ZYB & Associates, LLC, d/b/a Law Offices of Yongbing Zhang
- 91.92. Any potential Avoidance Defendant that is subject to a stipulated tolling order entered by the Court.