郭文贵破产案 · ECF #3126

元数据

当事人: 郭文贵 (Guo Wengui / Miles Guo / Ho Wan Kwok)
法院: CTB
案号: 22-50073
ECF #: 3126
类型: UNKNOWN

原始法庭文件为英文，下方为英文全文。

全文

## UNITED STATES BANKRUPTCY COURT DISTRICT OF CONNECTICUT BRIDGEPORT DIVISION

| In Re: | : : CHAPTER 11 | |-----------------------------------|---------------------------------------| | HO WAN KWOK, et al.1 | : : CASE NO. 22-50073 (JAM) | | Debtors. | : : (Jointly Administered) : | | LUC A DESPINS, CHAPTER 11 TRUSTEE | : : : | | Plaintiff, | : Adv. Proceeding No. 24-05010 | | v. | : : | | DIRECT PERSUASION LLC | : : | | Defendant. | : : : |

### MOTION FOR ADMISSION PRO HAC VICE OF RYAN M. TROMBLEY

Pursuant to Local Rule of Civil Procedures 83.1(d) of the United States District Court for the District of Connecticut, incorporated herein by Local Rule of Bankruptcy Procedure 1001-1, the undersigned, a member of the Bar of this Court and partner of the law firm Shipman & Goodwin LLP, respectfully moves that the Court admit attorney Ryan M. Trombley, a member of the Bar of the State of Illinois pro hac vice to represent Direct Persuasion LLC, in the above captioned Chapter 11 bankruptcy case and in the related adversary proceeding, Despins v. Direct Persuasion LLC, Adv. Pro. No. 24-05010, and in support represents the following:

1 The Debtors in these chapter 11 cases are Ho Wan Kwok (also known as Guo Wengui, Miles Guo, and Miles Kwok, as well as numerous other aliases) (last four digits of tax identification number: 9595), Genever Holdings LLC (last four digits of tax identification number: 8202) and Genever Holdings Corporation. The mailing address for the Trustee, Genever Holdings LLC, and 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).

1. The primary office of Attorney Trombley is Arnold & Porter Kaye Scholer LLP, 70 West Madison Street, Suite 4200, Chicago, IL 60602. His telephone number is 312- 583-2472; and his email address is ryan.trombley@arnoldporter.com.

2. Attorney Trombley is a member in good standing in the state and jurisdictions set forth in his declaration, attached as Exhibit A.

3. To the best of my knowledge and belief, Attorney Trombley is a member in good standing of the courts listed in his declaration, has no pending disciplinary complaints as to which a finding has been made that such complaint should proceed to a hearing and has 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.

4. To the best of my knowledge and belief, Attorney Trombley has reviewed and is familiar with the Federal Rules of Civil Procedure, the Local Rules of the United States District Court for the District of Connecticut, the Local Rules of the Bankruptcy Court for the District of Connecticut, and the Connecticut Rules of Professional Conduct.

5. Attorney Trombley has submitted the filing fee of \$200.00 with this motion for pro hac vice admission.

6. Service of all papers directed to Direct Persuasion LLC may be made upon the undersigned, pursuant to Rule 83.1(e) of the Local Rules of Civil Procedure for the United States District Court for the District of Connecticut.

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April 24, 2024 Hartford, Connecticut

> By: /s/ Eric S. Goldstein Eric S. Goldstein, Esq. (ct27195) Shipman & Goodwin LLP One Constitution Plaza Hartford, CT 06103 Telephone: 860-251-5059 Facsimile: 860-251-5218 Email: egoldstein@goodwin.com

Local Counsel for Direct Persuasion LLC

#### CERTIFICATION

I hereby certify that the foregoing Motion for Admission Pro Hac Vice of Ryan M. Trombley as visiting attorney was filed electronically on April 24, 2024. Notice of this filing will be sent by email to all parties registered for electronic service in this proceeding through the Court's CM/ECF system.

> /s/ Eric S. Goldstein Eric Goldstein, Esq.

## Exhibit A

Declaration of Ryan M. Trombley, Esq.

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

| _________________________________________ | | |-------------------------------------------|---------------------------------------------| | In Re: | : CHAPTER 11 | | HO WAN KWOK, et al.2 | : : CASE NO. 22-50073 (JAM) | | Debtors. | : : (Jointly Administered) : | | LUC A DESPINS, CHAPTER 11 TRUSTEE | : : | | Plaintiff, | : : Adv. Proceeding No. 24-05010 : | | v. | : | | DIRECT PERSUASION LLC | : : | | Defendant. | : : : |

# DECLARATION OF RYAN M. TROMBLEY IN SUPPORT OF MOTION FOR ADMISSION PRO HAC VICE

I, Ryan M. Trombley, being of the full age, having been dully sworn according to law,

state the following:

1. I am an attorney and associate at Arnold & Porter Kaye Scholer LLP, 70 West

Madison Street, Suite 4200, Chicago, IL 60602. My telephone number is 312-583-2472; and

my email address is ryan.trombley@arnoldporter.com.

2. I submit this declaration in support of the motion for my admission pro hac vice

as counsel for Direct Persuasion LLC in the above-captioned chapter 11 cases and in the related

adversary proceeding, Despins v. Direct Persuasion LLC, Adv. Pro. No. 24-05010.

3. Pursuant to D. Conn. L. Civ. 83(d) ("Rule 83(d)"), I designate the District of Connecticut as the forum for any resolution of any dispute arising out of my admission.

4. I am member in good standing of the Bar of the State of Illinois (Bar No. 6330560). In addition, I am a member in good standing of (i) the United States District Courts for the Northern District of Illinois (Bar No. 6330560), Central District of Illinois, the Southern District of Illinois, the District of Colorado, and the District of Columbia (Bar No. IL0106); and (ii) the United States Bankruptcy Courts for the Northern District of Illinois, Central District of Illinois, the Southern District of Illinois (N/A), the District of Colorado, and the District of Columbia (Bar No. IL0106).

5. I have no disciplinary complaints, and I have not been denied admission to, been disciplined by, resigned from, surrendered my license to practice before, or withdrawn an application for admission to practice before this Court or any other court.

6. I have read and am familiar with the Federal Rules of Civil Procedure, the Local Rules of the United States District Court for the District of Connecticut, the Local Rule of the Bankruptcy Court for the District of Connecticut, and the Connecticut Rules of Professional Conduct, and will abide by and comply with the substantive and procedural requirements of the local rules and administrative orders of this Court.

7. I hereby designate my sponsoring attorney, Eric S. Goldstein (Federal Bar No. ct27195) of Shipman & Goodwin LLP, as my agent for service of process and the District of Connecticut as the forum for the resolution of any dispute arising out of my admission pro hac vice in the above-captioned chapter 11 case and related cases.

8. I understand that upon admission under Rule 83(d) I must promptly file with the Clerk of Court a certificate of good standing from the court of the state in which I have

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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.

Pursuant to 28 U.S.C. § 1746, I declare under penalty of perjury that the foregoing is true and accurate.

> /s/Ryan M. Trobmley Ryan M. Trombley