--- type: court_doc id: "court_ctb_3563_0" court: "CTB" case_no: "22-50073" doc_number: 3563 doc_type: "MOTION" filed_date: null lang: "zh" url: "https://mubeitech.com/court/court_ctb_3563_0" json_url: "https://mubeitech.com/api/court/court_ctb_3563_0" --- # UNITED STATES BANKRUPTCY COURT DISTRICT OF CONNECTICUT In re: Chapter 11 > 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** In re: Chapter 11 HO WAN KWOK, *et al.*, Case No. 22-50073 (JAM) Debtors. (Jointly Administered) ## **MOTION TO PERMIT COUNSEL FOR AMAZON WEB SERVICES, INC. AND AMAZON.COM, INC. TO APPEAR REMOTELY AT THE SEPTEMBER 24, 2024 STATUS CONFERENCE** Amazon Web Services, Inc. ("AWS") and Amazon.com, Inc. ("Amazon") move to allow their counsel, Brian T. Peterson and Ruby A. Nagamine, 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 adversary defendants exempted from mediation [ECF No. 3511] ("Request for Status Conference"). 1. AWS and Amazon are defendants in two separate adversary proceedings brought by chapter 11 trustee Luc A. Despins (the "Trustee"). *See* Adv. Proc. Nos. 24-05006, 24-05057. 2. Amazon and AWS have a significant amount at stake in this bankruptcy proceeding, as the Trustee has sought the recovery of more than \$19 million in allegedly avoidable transfers against AWS, and more than \$400,000 in allegedly avoidable transfers against Amazon. The Trustee asserts that he is entitled to recover the allegedly avoidable transfers made by purported alter ego entities that are not debtors in this bankruptcy case. 3. The issues raised in the Request for Status Conference are equally applicable to AWS and Amazon, as well as numerous other defendants in the avoidance action adversary proceedings filed by the Trustee. Amazon and AWS agree that consolidated briefing of common legal issues would be beneficial to all parties and the Court. AWS and Amazon are concerned that, absent implementation of a consolidated or omnibus briefing protocol, the Court (i) will face voluminous and potentially duplicative briefing across numerous adversary proceedings, and (ii) may adjudicate certain common legal issues without allowing the numerous other defendants (including those subject to mediation procedures) an opportunity to be heard on these important legal issues that concern the scope of the Trustee's avoidance action powers. 4. On September 16, 2024, the Court granted the Request for Status Conference 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. 5. The Status Conference could potentially address, among other things, scheduling and/or coordination among the various avoidance action defendants with respect to briefing threshold legal issues and other common adjudicatory matters, as well as the Court's view on the utility of establishing common briefing procedures. 6. Mr. Peterson and Ms. Nagamine work out of Seattle, Washington, and one or both of them intend to 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, AWS and Amazon respectfully request that the Court allow Mr. Peterson and Ms. Nagamine to participate remotely via the Court's Zoom platform for the September 24, 2024 Status Conference. 2 September 19, 2024 Boston, Massachusetts By: */s/ Lindsay S. Bishop \_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_* Lindsay S. Bishop, Esq. (ct29990) K&L Gates LLP 1 Congress St, Suite 2900 Boston, MA 02114 Telephone: 617-951-9198 Email: lindsay.bishop@klgates.com Brian T. Peterson, *admitted pro hac vice* Ruby A. Nagamine, *admitted pro hac vice* K&L Gates LLP 925 Fourth Avenue, Suite 2900 Seattle, WA 98104 Phone: (206) 623-7580 Fax: (206) 623-7022 E-mail: brian.peterson@klgates.com ruby.nagamine@klgates.com ## **CERTIFICATE OF SERVICE** I certify that on September 19, 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. Dated: Boston, Massachusetts /s/ *Lindsay S. Bishop* September 19, 2024 Lindsay S. Bishop