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doc_number: 3557
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# UNITED STATES BANKRUPTCY COURT DISTRICT OF CONNECTICUT BRIDGEPORT DIVISION HO WAN KWOK, et al.1



> 原始法庭文件为英文；下方为英文全文，顶部为中文摘要。

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

HO WAN KWOK, et al.1

In Re: : CHAPTER 11

:

:

:

: CASE NO. 22-50073 (JAM)

Debtors. : (Jointly Administered)

# **MOTION FOR ADMISSION** *PRO HAC VICE* **OF SCOTT M. KESSLER**

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 a partner of the law firm Shipman & Goodwin LLP, respectfully moves that the Court admit attorney Scott M. Kessler, Esq., a member of, inter alia, the Bar of the State of New York, *pro hac vice*  to represent B&H Foto & Electronics Corp., a defendant in the related adversary proceeding, *Luc Despins, Chapter 11 Trustee v. B&H Foto & Electronics Corp. et al.*, Adv. Proc. Case No. 24-05069 (the "Adversary Proceeding"), related to the above-captioned Chapter 11 case, and in support represent the following:

1. The primary office of Attorney Kessler is Akerman LLP, 1251 Avenue of the Americas, 37th Floor, New York, New York 10020. His telephone number is 212-880-3874, and his email address is scott.kessler@akerman.com.

2. The Court previously granted Attorney Kessler *pro hac vice* admission in the Adversary Proceeding on April 25, 2024 (Adv. Proc. ECF Doc. No. 17). Moreover, Attorney

<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. 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).

Kessler is also a member in good standing in the other state and jurisdictions set forth in his declaration, attached as **Exhibit A**.

3. To the best of my knowledge and belief, Attorney Kessler 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 Kessler 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 Kessler has submitted the filing fee of \$200.00 with this motion for *pro hac vice* admission.

6. Service of all papers directed to B&H Foto & Electronics Corp. 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.

September 19, 2024 Stamford, Connecticut

> By: */s/ Tracy Ellis Williams*  Tracy Ellis Williams, Esq. (ct25137) Shipman & Goodwin LLP 300 Atlantic Street, 3rd Floor Stamford, CT 06901 Telephone: 203-324-8136 Facsimile: 203-324-8199 tewilliams@goodwin.com

*Local Counsel for B&H Foto & Electronics Corp.*

#### **CERTIFICATION**

I hereby certify that on September 19, 2024, a copy of the foregoing *Motion for Admission Pro Hac Vice of Scott M. Kessler* as visiting attorney was filed electronically and served by first class mail, postage prepaid and/or via email on anyone unable to accept electronic filing. Notice of this filing will be sent by e-mail to all parties by operation of the Court's electronic filing system or by First Class mail to anyone unable to accept electronic filing as indicated on the Notice of Electronic Filing. Parties may access this filing through the Court's CM/ECF System.

> */s/ Tracy Ellis Williams*  Tracy Ellis Williams, Esq.

# **Exhibit A**

Declaration of Scott M. Kessler, Esq.

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

 : HO WAN KWOK, et al.1

 : :

:

In Re: : CHAPTER 11

: CASE NO. 22-50073 (JAM)

Debtors. : (Jointly Administered)

# **DECLARATION OF SCOTT M. KESSLER IN SUPPORT OF MOTION FOR ADMISSION** *PRO HAC VICE*

I, Scott M. Kessler, Esq., being of full age, having been duly sworn according to law, state the following:

1. I am an attorney and partner at Akerman LLP, 1251 Avenue of the Americas,

37th Floor, New York, New York 10020. My telephone number is 212-880-3874, and my email address is scott.kessler@akerman.com.

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

*vice* as counsel for B&H Foto & Electronics Corp., defendant in the related adversary

proceeding, *Luc Despins, Chapter 11 Trustee v. B&H Foto & Electronics Corp. et al.*, Adv.

Proc. Case No. 24-05069 (the "Adversary Proceeding"), related to the above-captioned

Chapter 11 case.

3. This Court granted me *pro hac vice* admission in the Adversary Proceeding on April 25, 2024 (Adv. Proc. ECF Doc. No. 17). Moreover, 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 N e w Y o r k (Bar

<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. 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).

No. 4242905). In addition, I am a member in good standing of (i) the United States Courts of Appeals for the Second Circuit (No Bar No. assigned) and (ii) the United States District Courts for the Southern District of New York (Bar No. SK5510), the Eastern District of New York (Bar No. SK5510), the Northern District of New York (Bar No. 517163) and the Western District of New York (No Bar No. assigned).

4. 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.

5. 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.

6. I hereby designate my sponsoring attorney Tracy Ellis Williams (Federal Bar No. ct25137) 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.

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, I declare under penalty of perjury that the

foregoing is true and accurate.

This 19th day of September, 2024.

\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_

Scott M. Kessler, Esq.

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

HO WAN KWOK, et al.1

 : :

:

In Re: : CHAPTER 11

: CASE NO. 22-50073 (JAM)

Debtors. : (Jointly Administered)

### **ORDER GRANTING MOTION FOR ADMISSION** *PRO HAC VICE*  **OF SCOTT M. KESSLER**

Upon consideration of the Motion of Tracy Ellis Williams for Admission *Pro Hac Vice* of

Scott M. Kessler (the "Motion"), and any and all responses thereto, it is hereby

ORDERED that the Motion is GRANTED and Scott M. Kessler is admitted *pro hac vice*,

and it is further

ORDERED that Tracy Ellis Williams will receive service on behalf of Scott M.

Kessler in accordance with D. Conn. L. Civ. R. 83.1(c), as incorporated by D. Conn. LBR

9083-3.

<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. 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).