郭文贵破产案 · ORDER · ECF #3144

元数据

当事人: 郭文贵 (Guo Wengui / Miles Guo / Ho Wan Kwok)
法院: CTB
案号: 22-50073
ECF #: 3144
类型: ORDER

原始法庭文件为英文，下方为英文全文。

全文

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

#### **MOTION FOR ADMISSION** *PRO HAC VICE* **OF RICHARD J. REDING**

Pursuant to Local Rules of Civil Procedure 83.1 (c) and (d) of the United States District Court for the District of Connecticut, incorporated herein by Local Rule of Bankruptcy Procedure 1001-1 and 9083-3, Elizabeth N. Krasnow, a member of the Bar of this Court and special counsel with the firm of Kelley Drye & Warren LLP ("Kelley Drye"), respectfully moves (the "Motion") this Court to enter an Order admitting Richard J. Reding ("Mr. Reding") *pro hac vice* on behalf of Indium Software Inc. in the above-captioned chapter 11 case (the "Case"). In support of this Motion, the undersigned represents the following:

1. Mr. Reding is a partner with ASK LLP. He is a member in good standing of the bar of State of Minnesota (MN SBN 0389945) and the Federal District Courts for the District of Minnesota and the Southern District of Indiana. Mr. Reding has not been denied admission or disciplined by any Court.

<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.

2. Mr. Reding has executed an affidavit in connection with this Motion which has been attached hereto as Exhibit A.

3. The undersigned counsel is a member in good standing of the Bar of the State of Connecticut and State of New York. The undersigned is also admitted before the United States Supreme Court, the United States Second Circuit Court of Appeals, and the United States District Court for the District of Connecticut and the Southern and Eastern Districts of New York.

4. The undersigned respectfully requests that, pursuant to D. Conn. L. Civ. R. 83.1(d), in the event that this motion is granted, she be excused from attendance at proceedings. In accordance with D. Conn. L. Civ. R. 83.1(c), the undersigned agrees to accept service on behalf of Mr. Reding.

WHEREFORE, Elizabeth N. Krasnow respectfully requests that this Court enter an Order in the form of Exhibit B hereto granting Richard J. Reding admission *pro hac vice*.

Dated: April 26, 2024 Stamford, Connecticut

#### **KELLEY DRYE & WARREN LLP**

*/s/ Elizabeth N. Krasnow* Elizabeth N. Krasnow (ct430625) Eric R. Wilson (ct443553) Benjamin D. Feder (ct443211) Canterbury Green 201 Broad Street Stamford, CT 06901 Tel: (203) 324-1400 Email: [ekrasnow@kelleydrye.com](mailto:ekrasnow@kelleydrye.com) [ewilson@kelleydrye.com](mailto:ewilson@kelleydrye.com) [bfeder@kelleydrye.com](mailto:bfeder@kelleydrye.com)

*Counsel to Indium Software Inc.*

# **EXHIBIT A**

#### **AFFIDAVIT IN SUPPORT OF MOTION FOR ADMISSION** *PRO HAC VICE* **OF RICHARD J. REDING**

Richard J. Reding, of full age, deposes and states the following:

1. I am an attorney and partner at the firm ASK LLP ("Ask), with an office address of 2600 Eagan Woods Drive, Suite 400, St. Paul, MN 55121. The firm's telephone number is (651) 406-9665, the facsimile is (651)406-9676 and my email address is rreding@askllp.com.

2. Pursuant to D. Conn. L. Civ. R. 83.1(c), the law firm of Kelley Drye & Warren

LLP ("Kelley Drye"), will serve as my local bankruptcy counsel. Kelley Drye's address is

Canterbury Green, 201 Broad Street, Stamford, CT 06901.

3. Pursuant to D. Conn. L. Civ. R. 83.1(d), I designate the District of Connecticut as

the forum for any resolution of any dispute arising out of my admission.

4. I am a member in good standing of the Bar of the State of Minnesota (MN SBN 0389945) and the Federal District Courts for the District of Minnesota and the Southern District of Indiana. I have no pending disciplinary complaints as to which a finding has been made that

such complaint should proceed to a hearing. Further, 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, while facing a disciplinary complaint.

5. I have read and am familiar with the Federal Rules of Civil and Criminal 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, and will abide by and comply with the substantive and procedural requirements of the local rules and the administrative orders of this Court.

6. I understand that upon admission under this rule I must promptly file with the Clerk of Court a certificate of good standing from the State of Minnesota Supreme Court. 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.

I declare under penalty of perjury that the foregoing is true and accurate.

Dated: April 26, 2024 /s/ Richard J. Reding Richard J. Reding

# **EXHIBIT B**

## **[PROPOSED] ORDER GRANTING MOTION FOR ADMISSION** *PRO HAC VICE* **OF RICHARD J. REDING**

On this \_\_ day of \_\_\_\_\_\_\_\_\_\_, 2024, upon consideration the Motion for Admission *Pro Hac Vice* of Richard J. Reding (the "Motion"), filed by a member of the bar of this Court on behalf of Richard J. Reding ("Mr. Reding"), as attorney for Indium Software Inc. in the above-captioned chapter 11 case (the "Case"), and any responses thereto, it is hereby

ORDERED, that the Motion is granted, and that Mr. Reding is admitted *pro hac vice* to practice in the U.S. District Court for the District of Connecticut in connection with the Case, and with respect to this Case, he shall have all the rights, privileges, and responsibilities of a member of the bar of this Court; and it is further

ORDERED that, pursuant to D. Conn. L. Civ. R. 83.1(d), Mr. Reding's sponsoring attorney shall be excused from attendance at proceedings; and it is further

ORDERED that Elizabeth N. Krasnow will receive service on behalf of Mr. Reding in accordance with D. Conn. Local Civ. R. 83.1(c), as incorporated by D. Conn. L.B.R. 1001-1 and 9083-3.

| ---------------------------------------------------------- | x | | |------------------------------------------------------------|---|-------------------------| | | : | Chapter 11 | | In re: | : | | | | : | Case No. 22-50073 (JAM) | | HO WAN KWOK, et al., | : | | | | : | (Jointly Administered) | | Debtors.2 | : | | | | : | | | ---------------------------------------------------------- | x | |

#### **CERTIFICATE OF SERVICE**

The undersigned hereby certifies that on April 26, 2024, the foregoing Motion for Admission Pro hac Vice of Richard J. Reding was electronically filed. The foregoing notice was served via CM/ECF on all parties registered to receive such notice in the above-captioned cases.

Dated: April 26, 2024 Stamford, Connecticut

#### **KELLEY DRYE & WARREN LLP**

*Counsel to Indium Software Inc.*

<sup>2</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.