郭文贵破产案 · MOTION · ECF #3546

## UNITED STATES BANKRUPTCY COURT DISTRICT OF CONNECTICUT

In re:

HO WAN KWOK, et al.,

Chapter 11

Case No. 22-50073 (JAM)

Debtors.

(Jointly Administered)

## MOTION TO PERMIT COUNSEL FOR AMERICAN EXPRESS COMPANY TO APPEAR REMOTELY AT THE SEPTEMBER 24, 2024 STATUS CONFERENCE

American Express Company ("American Express") moves to allow its counsel, Darryl S. Laddin and Frank N. White, to appear remotely via the Court's Zoom platform at the status conference set for September 24, 2024 at 1:00 p.m. E.T. on certain adversary defendants' request for a status conference to discuss, among other things, the mediation stay and motions to dismiss filed by other adversary defendants exempted from mediation [ECF No. 3511].

1. American Express is the defendant in a separate adversary proceeding brought by chapter 11 trustee Luc A. Despins (the "Trustee"). See Adv. Proc. No. 24-05077. American Express is not among the adversary defendants who requested the status conference, but it is similarly situated with those parties and wishes to monitor and potentially participate in the scheduled discussion with the Court.

2. On September 16, 2024, the Court granted the request and scheduled a status conference to be held on September 24, 2024 at 1:00 p.m. in the United States Bankruptcy Court, 915 Lafayette Boulevard, Bridgeport, CT ("Status Conference"). ECF Docket No. 3532.

3. The Status Conference could potentially address, among other things, scheduling and/or coordination among various adversary defendants with respect to briefing threshold legal issues and other common adjudicatory matters. To the extent the Court and parties participating in

the Status Conference identify procedural efficiencies, those may present benefits for other adversary proceedings beyond the ones the Trustee filed against that requested the conference. Consequently, it may be beneficial for American Express to understand and potentially join in any procedural course of action resulting from the Status Conference.

4. appear at the September 24, 2024 Status Conference, but given the time and expense needed to travel to Bridgeport, CT, they respectfully request that the Court permit them to participate via the Court's Zoom platform.

WHEREFORE, American Express respectfully requests that the Court allow Mr. Laddin

and Mr. White to participate remotely via the Court's Zoom platform for the September 24, 2024

Status Conference.

Dated: September 18, 2024

DEFENDANT, AMERICAN EXPRESS COMPANY

By /s/ Ronald I. Chorches Ronald I. Chorches, Esquire Fed Bar #ct08720 Law Offices of Ronald I. Chorches, LLC 82 Wolcott Hill Road, Ste. 203 Wethersfield, CT 06109 Ph: (860) 563-3955/Fax: (8600 513-1577 Email: ronchorcheslaw(@sbcglobal.net

ARNALL GOLDEN GREGORY LLP Darryl S. Laddin Frank N. White 171 17th Street, N.W., Suite 2100 Atlanta, GA 30363-1031 Telephone: (404) 873-8500 Fax: (404) 873-8121 darryl.laddin@agg.com frank.white@agg.com

Attorneys for Defendant American Express Company

## CERTIFICATE OF SERVICE

I certify that on September 18, 2024, I caused a true and correct copy of the foregoing document to be filed with the Clerk of the Court using the CM/ECF filing system, which will send notification of such filing to all attorneys of record.

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