郭文贵破产案 · EXHIBIT · ECF #3449

# UNITED STATES BANKRUPTCY COURT DISTRICT OF CONNECTICUT BRIDGEPORT DIVISION

In re:

HO WAN KWOK, et al.,

Debtors.

Chapter 11 Case No. 22-50073 (JAM)

(Jointly Administered)

August 22, 2024

### MOTION FOR ADMISSION PRO HAC VICE OF DARRYL S. LADDIN

Pursuant to Local Rule of Civil Procedures 83.1(d) and Local Rule of Bankr. P. 9083-1 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 this Court and principal of the law firm of Law Offices of Ronald I. Chorches, LLC, respectfully moves that the Court admit attorney Darryl S. Laddin, a member of the Bar of the State of Georgia pro hac vice to represent American Express Company, in the above captioned Chapter 11 bankruptcy case and in the related adversary proceeding, Despins v. American Express Company, Adv. Pro. No. 24-05077, and in support represents the following:

1, The primary office of Attorney Laddin is Arnall Golden Gregory LLP, 1711 Street NW, Ste. 2100, Atlanta, GA 30363. His telephone number is 404-873-8120; and his email address is darryl.laddin(a)agg.com.

2, in his Affidavit, attached as Exhibit A.

3. standing of the courts listed in his Affidavit, has no pending disciplinary complaints as to which a

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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and has not been denied admission to, been disciplined by, resigned from, surrendered a license to practice before, or withdrawn an application for admission to practice while facing a disciplinary complaint before, this Court or any other court.

To the best of my knowledge and belief, Attorney Laddin has reviewed and is 4. 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. hac vice admission.

6. Service of all papers directed to American Express 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.

#### CERTIFICATION

This is to certify that on the 22nd 7004(a), and 9014 F.R.Bankr.P., the undersigned serve a true and correct copy of the foregoing Motion for Admission Pro Hac Vice of Darryl S. Laddin, via Electronic Filing or First Class Mail postage pre-paid upon the following:

### U.S. Trustee

Holley Claiborn, Esq. Office of the U.S. Trustee Giaimo Federal Building 150 Court Street, Rm. 302 New Haven, CT 06510

#### Counsel for Plaintiff

Patrick R. Linsey, Esq. Douglas S. Skalka, Esq. Neubert Pepe & Monteith, P.C. 195 Church Street, 13th Fl. New Haven, CT 06510 plinsey(@npmlaw.com dskalka@npmlaw.com

> /s/ Ronald I. Chorches Ronald I. Chorches

## UNITED STATES BANKRUPTCY COURT DISTRICT OF CONNECTICUT BRIDGEPORT DIVISION

IN RE:

HO WAN KWOK, et al., 4

Debtors.

Chapter 11

Case No: 22-50073 (JAM)

(Jointly Administered)

August 12, 2024

# AFFIDAVIT OF DARRYL S. LADDIN IN SUPPORT OF MOTION FOR ADMISSION PRO HAC VICE

I, Darryl S. Laddin, being of the full age, having been duly sworn according to law, state the following:

1. Atlanta, GA 30363. My telephone number is 404-873-8120; and my email address is darryl.laddin(a)agg.com.

2. counsel for American Express in the above-captioned chapter 11 case and in the related adversary proceeding, Despins v. American Express Company, Adv. Pro. No. 24-05077.

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.

I am a member in good standing of the Bar of the State of Georgia (Bar No. 460793 4. Ai admitted 1990). In addition, I am a member in good standing of (i) the U.S. District Court

¹ The Debtors in these chapter 11 cases are Ho Wan Kwok (also Wengui, Miles Guo, and Miles) September 11 cases and condinatel Cast four digits of tax identification number: I The Debtors in these chapter 1 less are Ho Wall Kirks of tax identification whear. Society Blogings Kwok, as well as numerous other aliases) (last four digits of the mailin Kwok, as well as numerous of tax identification number: 3002) and Genever Holding addess, and est and the mating addess, addess, addess, addess, addess, addess, LLC (last four digits of tax identities) on the Genever Holdings Capacities e Dania Braines LLP, 200 Park for the Trustee, Genever Holdings LLC and the Genever Holdings Capab for the Trustee, Genever Holdings LLC and the Gellevel Librand State of Holland. Avenue, New York, NY 10166 Olo Luc A. Despins, as Trustee for the Estate of Ho Wan Kwok (sole of notices and communications).

N.D.G.A., admitted October 15, 1991; (ii) U.S. District Court, M.D.G.A., admitted July 18, 1994; (iii) U.S. District Court, E.D.M.I., admitted February 17, 2000; (iv) U.S. District Court, E.D.N.Y., admitted September 3, 2004; (v) U.S. District Court, N.D.N.Y, admitted January 24, 2007; (vi) U.S. District Court, S.D.N.Y., admitted August 3, 1999; (vii) U.S. District Court, D.C., admitted May 3, 2010; (viii) U.S. Court of Appeals 11th Circuit, admitted October 17, 1001; U.S. Court of Appeals 8th Circuit, admitted August 19, 2019; U.S. Court of Appeals 5th Circuit, admitted January 11, 2018; U.S. Court of Appeals 3rd Circuit, admitted December 3, 2004; U.S. Court of Appeals 2nd Circuit, admitted July 27, 2006.

5. 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. 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, Ronald I. Chorches, (Fed. Bar No. ct08720) of Law Offices of Ronald I. Chorches, LLC, 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 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.

Darryl S. Laddin

Subscribed and sworn to before me this 12 day of Hugus , 2024. Notary Rotary FOURN Commssioner of the Specifor Court EXPIRES GEORGIA ebruary 23, 2025