郭文贵破产案 · ECF #3339

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

| _________________________________________ | | |-------------------------------------------|----------------------------------------| | In Re: | :<br>CHAPTER 11 | | HO WAN KWOK, et al.1 | :<br>:<br>CASE NO. 22-50073 (JAM) | | Debtors. | :<br>:<br>(Jointly Administered)<br>: | | LUC A<br>DESPINS, CHAPTER 11 TRUSTEE | :<br>: | | Plaintiff, | :<br>:<br>Adv. Proceeding No. 24-05158 | | v. | :<br>: | | RV RETAILER EAST, LLC | :<br>: | | Defendant. | :<br>:<br>:<br>: |

### **MOTION FOR ADMISSION** *PRO HAC VICE* **OF LONDON ENGLAND**

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 London England, a member of the Bar of the State of Texas *pro hac vice* to represent RV Retailer East, LLC in the above-captioned Chapter 11 bankruptcy case and in the related adversary proceeding*,*

<span id="page-0-0"></span>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).

*Luc Despins, Chapter 11 Trustee v. RV Retailer East, LLC.* Adv. Pro. No. 24-05158, and in support represents the following:

1. The primary office of AttorneyLondon England is Gray Reed, 1601 Elm Street, Suite 4600, Dallas, Texas 75201. Her telephone number is (469) 320-6188 and her email address is lengland@grayreed.com.

2. Attorney London England is a member in good standing in the state and jurisdictions set forth in her declaration, attached as **Exhibit A**.

3. To the best of my knowledge and belief, Attorney London England is a member in good standing of the courts listed in her 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 London England 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 London England has submitted the filing fee of \$200.00 with this motion for *pro hac vice* admission.

6. Service of all papers directed to RV Retailer East, 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.

-2-

July 23, 2024 Hartford, Connecticut

> By: */s/ Eric S. Goldstein* Eric S. Goldstein, Esq. (ct27195) Shipman & Goodwin LLP One Constitution Plaza Hartford, CT 06103 Telephone: 860-251-5000 Facsimile: 860-251-5218 Email:egoldstein@goodwin.com

*Local Counsel for RV Retailer East, LLC*

#### **CERTIFICATION**

I hereby certify that the foregoing *Motion for Admission Pro Hac Vice of London England* as visiting attorney was filed electronically on July 23, 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 S. Goldstein

## **Exhibit A**

Declaration of London England, Esq.

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

| _________________________________________ | | |-------------------------------------------|---------------------------------------------| | In Re: | :<br>CHAPTER 11 | | HO WAN KWOK, et al.1 | :<br>:<br>CASE NO. 22-50073 (JAM) | | Debtors. | :<br>:<br>(Jointly Administered)<br>: | | :<br>LUC A DESPINS, CHAPTER 11 TRUSTEE | : | | Plaintiff, | :<br>:<br>Adv. Proceeding No. 24-05158<br>: | | v. | : | | RV RETAILER EAST, LLC, | :<br>:<br>: | | Defendant. | :<br>:<br>: |

# **DECLARATION OF LONDON ENGLAND IN SUPPORT OF MOTION FOR ADMISSION** *PRO HAC VICE*

I, London England being of full age, having been dully sworn according to law, state the following:

1. I am an attorney at Gray Reed. My telephone number is (469) 320-6188; and

my email address is lengland@grayreed.com.

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

as counsel for RV Retailer East, LLC in the above-captioned Chapter 11 case and in the related

<span id="page-5-0"></span>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).

adversary proceeding, *Luc Despins, Chapter 11 Trustee v. RV Retailer East, LLC,* Adv. Pro. No. 24-05158.

3. In accordance with D. Conn. L. Civ. R. 83.1(d), I am an active member in good standing of the Bar of the State of Texas (Bar No. 24110313). In addition, I am a member in good standing of (i) the United States Courts of Appeals for the Second Circuit, and (ii) the United States District Courts for the Eastern District of Texas, the United States District Courts for the Southern District of Texas (Bar No. 3575076), and the United States District Courts for the Northern District of Texas.

4. I have no pending disciplinary complaints as to which a finding has been made that such complaint should proceed to a hearing. 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 while facing a disciplinary complaint before this Court or any other court.

5. I have fully reviewed 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 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 administrative orders of this Court.

6. I hereby designate my sponsoring attorney, Eric S. Goldstein (Federal Bar No. ct27195) of Shipman & Goodwin LLP, as my agent for service of process. Pursuant to D. Conn. L. Civ. 83.1 (d), I designate the District of Connecticut as the forum for any resolution of any dispute arising out of my admission *pro hac vice* in the above-captioned Chapter 11 case and related cases.

-2-

7. I understand that upon admission under D. Conn. L. Civ. 83.1 (d) I must promptly file 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.

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

Pursuant to 28 U.S.C. § 1746,¹ declare under penalty ofperjury that the foregoing is true and accurate.

This 23rd day ofJuly, 2024.

London England