---
type: court_doc
id: "court_ctb_3117_0"
court: "CTB"
case_no: "22-50073"
doc_number: 3117
doc_type: "MOTION"
filed_date: "2024-04-23"
lang: "zh"
url: "https://mubeitech.com/court/court_ctb_3117_0"
json_url: "https://mubeitech.com/api/court/court_ctb_3117_0"
---
# UNITED STATES BANKRUPTCY COURT DISTRICT OF CONNECTICUT BRIDGEPORT DIVISION 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。

# UNITED STATES BANKRUPTCY COURT DISTRICT OF CONNECTICUT BRIDGEPORT DIVISION

In re:

V.

Chapter 11

HO WAN KWOK, et al.,

Case No. 22-50073 (JAM)

Debtors.1

(Jointly Administered)

LUC A. DESPINS, CHAPTER 11 TRUSTEE.

Plaintiff,

Adv. Proceeding No. 24-05007

BLUEBERRY BUILDERS, LLC, Defendant

April 23, 2024

# MOTION TO APPEAR PRO HAC VICE - ATTORNEY ODEN

In accordance with the D. Conn. L. Civ. R. 83.1(d), I , David B. Zabel, an active member of the Bar of the U.S. District Court for the District of Connecticut, respectfully request that the Court admit Attorney Amy M. Oden pro hac vice to the Bar of this Court for the purpose of appearing on behalf of defendant Blueberry Builders, LLC, in the above-captioned Chapter 11 case and Adversary Proceeding. The Affidavit of Visiting Attorney Oden in support of her admission pro hac vice is attached hereto.

<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).

As the sponsoring attorney, I am a member of this Court and have an appearance in the Chapter 11 case and Adversary Proceeding. The filing fee has been paid and I maintain the address listed below.

If this motion is granted, I request to be excused from attendance in Court and participation in other proceedings before the Court. It is likewise requested that Attorney Heather R. Spaide, another attorney with our firm who has entered an appearance in the Adversary Proceeding, also be excused from attendance in Court and participation in other proceedings before the Court.

By Sponsoring Attorney:

David B. Zabel Marino, Zabel & Schellenberg, PLLC 657 Orange Center Road Orange, CT 06477 Tele: (203) 864-4511 Fax: (203) 456-8249 E-mail: dzabel@mzslaw.com Federal Bar No. ct01382

Dated: April 23, 2024

By:

David B. Zabel, Esq. Federal Bar No. ct01382 Marino, Zabel & Schellenberg, PLLC 657 Orange Center Road Orange, CT 06477 Tele: (203) 864-4511 Fax: (203) 456-8249 E-mail: dzabel@mzslaw.com

Local Counsel to Blueberry Builders, LLC

#### CERTIFICATION OF SERVICE

I hereby certify that on April 23, 2024, a copy of the foregoing Motion to Appear Pro Hac Vice - Attorney Oden was filed electronically. Notice of filing will be sent by e-mail to all parties by operation of the Court's electronic filing system and by mail to any parties who are unable to accept electronic filing as indicated on the Notice of Electronic Filing.

Parties may access this filing through the Court's CM/ECF system.

/s/ David B. Zabel David B. Zabel

### AFFIDAVIT OF VISTING ATTORNEY

Amy Oden

a motion to appear pro hac vice pursuant to Local Rule 83.1(d):

### a) My office information is:

| Firm            | Pashman Stein Walder Hayden P.C.              |
|-----------------|-----------------------------------------------|
| Address         | 233 Broadway, Suite 820<br>New York, NY 10279 |
| Phone<br>Number | 646-828-8081                                  |
| Fax             | 201-488-5556                                  |
| Email           | aoden@pashmanstein.com                        |

b) I am a member of the bar of the following court(s), and I include the corresponding bar identification number(s):

| Court                                                     | Bar Number<br>(or indicate if no bar # issued) |
|-----------------------------------------------------------|------------------------------------------------|
| State of New York                                         | N/A                                            |
| U.S. District Court for the Southern District of New York | IN/A                                           |
|                                                           |                                                |
| 【                                                         |                                                |
|                                                           |                                                |
|                                                           |                                                |
|                                                           |                                                |
|                                                           |                                                |

- c) I have no pending disciplinary complaints as to which a finding has been made that such complaint should proceed to a hearing;
- d) I have not been denied admission to, been disciplined by, resigned from, surrendered a license to practice before, or withdrawn an application for admission to practice while facing a disciplinary complaint before, this Court or any other court;

or, if I cannot so state as to subsections (c) and (d), then I attach a description in full of the circumstances of any such complaint, denial, discipline, resignation, surrender, or

withdrawal, including the reasons therefor, any penalty, sanction or other discipline imposed, whether such discipline was satisfied, and whether I am currently in good standing in such jurisdiction(s);

- e) I have fully reviewed and am familiar with the Federal Rules of Civil Procedure (for an attorney seeking admission in a civil case) or Criminal Procedure (for an attorney seeking admission in a criminal case), the applicable Local Rules of the United States District Court for the District of Connecticut, and the Connecticut Rules of Professional Conduct;
- f) I designate the sponsoring attorney as my agent for service of process and the District of Comecticut as the forun for the resolution of any dispute arising out of my admission under this Local Rule 83.1(d), including matters involving grievances filed against the visiting attorney and matters of attorney discipline that relate thereto;
- g) I understand that upon admission under this rule I must promptly file with the Clerk of Court a certificate of good standing from the court of the state in which I have my primary office. I acknowledge that the certificate shall be filed no later than 60 days after the date of admission and shall be dated no more than 60 days before the date of admission. I understand that failure to file such certificate will result in the automatic revocation of my visiting attorney status, absent an order of the Court. Furthermore, I understand that upon revocation of my visiting attorney status in one case, the Clerk of the Court shall examine the Court's Docket and revoke my visiting attorney status in all cases in which I have filed an appearance.

Certificate of good standing:

![](_page_4_Picture_6.jpeg)

has been included with this filing. will be filed within 60 days after admission.

h) I will file my appearance with the Court after my admission has been approved.

I hereby certify that the information provided on this form is true, correct, and complete as of this 23rd day of April 2024.

Signed

Print Name Amy Oden