郭文贵破产案 · ORDER · ECF #3646

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

| ------------------------------------------------------ | x | | |--------------------------------------------------------|-------------|-------------------------| | In re: | :<br>: | Chapter 11 | | HO WAN KWOK, et al., | :<br>: | Case No. 22-50073 (JAM) | | Debtors.1 | :<br>:<br>: | Jointly Administered | | ------------------------------------------------------ | x | |

# **APPLICATION OF CHAPTER 11 TRUSTEE FOR ENTRY OF ORDER, PURSUANT TO BANKRUPTCY CODE SECTIONS 327, 328, AND 330, BANKRUPTCY RULES 2014 AND 2016, AND LOCAL BANKRUPTCY RULES 2014-1 AND 2016-1, AUTHORIZING AND APPROVING RETENTION AND EMPLOYMENT OF PATRICE DOGER DE SPEVILLE, SENIOR COUNSEL, AND WILLIAM DE ROBILLARD, OF COUNSEL, AS BARRISTERS IN REPUBLIC OF MAURITIUS**

Mr. Luc A. Despins, in his capacity as the Chapter 11 Trustee (the "Chapter 11 Trustee") appointed in the above-captioned chapter 11 case (the "Chapter 11 Case") of Ho Wan Kwok (the "Debtor"), pursuant to sections 327, 328, and 330 of Title 11 of the United States Code (the "Bankruptcy Code"), Rules 2014 and 2016 of the Federal Rules of Bankruptcy Procedure (the "Bankruptcy Rules"), and Rules 2014-1 and 2016-1 of the Local Rules of Bankruptcy Procedure (the "Local Bankruptcy Rules") for the United States Bankruptcy Court for the District of Connecticut (the "Court"), files this application (the "Application") requesting entry of an order, substantially in the form attached hereto as **Exhibit A** (the "Proposed Order") authorizing his employment of Patrice Doger de Spéville, Senior Counsel, and William de Robillard, of Counsel

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 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).

(together, the "Barristers"), as barristers in the Republic of Mauritius ("Mauritius") under the instruction of ENSafrica (Mauritius) ("ENS"), on the terms set forth in the engagement letter attached hereto as **Exhibit B** (the "Engagement Letter"). In support of this Application, the Chapter 11 Trustee submits the *Declaration of Patrice Doger de Spéville in Support of Application of Chapter 11 Trustee for Entry of Order, Pursuant to Bankruptcy Code Sections 327, 328, and 330, Bankruptcy Rules 2014 and 2016, and Local Bankruptcy Rules 2014-1 and 2016-1, Authorizing and Approving Retention and Employment of Patrice Doger de Spéville, Senior Counsel, and William de Robillard, of Counsel, as Barrister in Republic of Mauritius* (the "Doger de Spéville Declaration"), attached as **Exhibit C**, which is incorporated herein by reference. In further support of this Application, the Chapter 11 Trustee states the following:

### **RELIEF REQUESTED**

1. By this Application, the Chapter 11 Trustee seeks entry of an order, substantially in the form of the proposed order filed herewith (the "Proposed Order"), authorizing and approving the retention and employment of the Barristers as the Chapter 11 Trustee's barrister in Mauritius, effective as of September 11, 2024, to act as barristers under the instruction of ENS in connection with the conservatorship of Silver Bank Limited (the "Silver Bank") and to oppose the request of Himalaya International Clearing Limited ("HICL") to release funds nominally under HICL's name held in Silver Bank, pending in the Chambers Commercial Division of the Supreme Court of Mauritius (the "Mauritius Action") and related matters. As the Court is well aware, the Chapter 11 Trustee has filed an adversary proceeding, Adv. Proc. No. 24-5249, seeking a ruling from this Court that HICL is the *alter ego* of and equitably owned by Ho Wan Kwok, and that, therefore, the funds in HICL's account at Silver Bank are owned by the Trustee.

2. The Chapter 11 Trustee selected the Barristers as his barrister based on their

expertise in corporate and commercial litigation in Mauritius, as well as its extensive experience with in complex commercial matters, including banking and financial matters, under Mauritius law.

# **JURISDICTION, VENUE, AND STATUTORY BASES**

3. The Court has jurisdiction over this matter pursuant to 28 U.S.C. §§ 157 and 1334 and the *Standing Order of Reference* from the United States District Court for the District of Connecticut. This is a core proceeding within the meaning of 28 U.S.C. § 157(b).

4. Venue in this District is proper pursuant to 28 U.S.C. §§ 1408 and 1409.

5. The statutory bases for the relief requested herein are sections 327(a), 328(a), and 330 of the Bankruptcy Code, and, to the extent applicable, Bankruptcy Rules 2014 and 2016, and Local Bankruptcy Rules 2014-1 and 2016-1.

## **BACKGROUND**

6. On February 15, 2022 (the "Petition Date"), the Debtor filed with the Court a voluntary petition for relief under chapter 11 of the Bankruptcy Code.

7. On March 21, 2022, the United States Trustee appointed an Official Committee of Unsecured Creditors (the "Committee") in the Debtor's Chapter 11 Case.

8. On June 15, 2022, the Court entered a memorandum of decision and order [Docket No. 465] (the "Trustee Order") directing the United States Trustee to appoint a chapter 11 trustee in the Chapter 11 Case. Pursuant to the Trustee Order, the United States Trustee selected Luc A. Despins as the Chapter 11 Trustee [Docket No. 514].

9. On July 8, 2022, the Court entered an order granting the appointment of Luc A. Despins as the Chapter 11 Trustee in the Chapter 11 Case [Docket No. 523].

### **BARRISTERS QUALIFICATIONS**

10. The Barristers have extensive experience with, and offers a broad spectrum of legal services in, both litigation and transactional matters within Mauritian law, as well as internationally. The Barristers have expertise in civil and commercial matters, in a broad range of corporate and financial matters. Over the years, Mr. Doger de Spéville has appeared in numerous complex and high profile cases at all levels, including before the Supreme Court of Mauritius and the Judicial Committee of the Privy Council.

# **ANTICIPATED SERVICES**

11. The Chapter 11 Trustee anticipates that the Barristers will serve as his barrister in Mauritius with respect to all matters related to the Mauritius Action. Due to the specialized nature of the role of a barrister, there will be no duplication of services arising from the Barrister's retention, including in connection with ENS, whom the Trustee will retain as his Mauritius attorneys, from whom the Barristers will receive instruction.

### **COMPENSATION OF BARRISTERS**

12. The Barristers intend to apply to the Court for compensation for professional services rendered and for reimbursement of expenses incurred in connection with this Chapter 11 Case pursuant to sections 330 and 331 of the Bankruptcy Code, Bankruptcy Rule 2016, Local Bankruptcy Rule 2016-1, and any other applicable rules and orders with respect to this Chapter 11 Case. The Barristers will charge the Debtor for its legal services on an hourly basis at its regularly applicable hourly rates in connection with barrister's services required in the Mauritius Action.

13. At present, the 2024 hourly rate of \$700 for Mr. Doger de Spéville and \$400 for Mr. de Robillard (plus 15% VAT). The Barristers will also bill for out-of-pocket expenses made

on behalf of the Debtor, including photocopying, postage and package deliveries, court fees, transcripts, witness fees, service fees, travel expenses, and computer-aided research.

14. The Debtor submits that the Barristers' hourly rates are reasonable, comparable to the Barristers' hourly rates for other engagements, and within the range of rates charged by comparably skilled professionals who offer the same services.

# **BARRISTERS ARE DISINTERESTED**

15. To the best of the Chapter 11 Trustee's knowledge in reliance upon the Doger de Spéville Declaration, and except as disclosed therein, the Barristers do not have any relationships with the Debtor, its creditors, or any other party-in-interest, their respective attorneys and accountants, the United States Trustee, or any person employed in the Office of the United States Trustee.

16. More specifically, upon the basis of the Doger de Spéville Declaration, and except as disclosed therein, the Chapter 11 Trustee believes that: (a) the Barristers have no connection with the Debtor, his creditors, the U.S. Trustee, any person employed in the office of the U.S. Trustee, or any other party with an actual or potential interest in the Debtor or his respective attorneys or accountants; and (b) the Barristers (i) are not a creditors, equity security holders, or insiders of the Debtor or his affiliates, (ii) have not been, within two years before the Petition Date, a director, officer, or employee of the Debtor or his affiliates, and (iii) have not had any interest materially adverse to the interests of the Debtor's estate or any class of creditors or equity security holders by reason of any direct or indirect relationship to, connection with, or interest in the Debtor, or for any other reason. Therefore, the Chapter 11 Trustee believes that the Barristers are "disinterested persons" within the meaning of section 101(14) of the Bankruptcy Code, as modified by section 1107(b).

17. Based on the Doger de Spéville Declaration, the Chapter 11 Trustee believes that the Barristers do not represent any adverse interest to unsecured creditors in connection with the Chapter 11 Case.

## **BASIS FOR RELIEF REQUESTED**

18. The Chapter 11 Trustee requests to retain and employ the Barristers as his barristers in Mauritius with respect to the Mauritius Action pursuant to section 327(a) of the Bankruptcy Code, which provides that a trustee, subject to the approval of the Court, may employ professional persons "that do not hold or represent an interest adverse to the estate, and that are disinterested persons, to represent or assist the trustee in carrying out the trustee's duties under this title."

19. Under section 328(a) of the Bankruptcy Code, with bankruptcy court approval, a trustee may employ professional persons under section 327(a) of the Bankruptcy Code "on any reasonable terms and conditions of employment, including on a retainer, on an hourly basis, on a fixed or percentage fee basis, or on a contingent fee basis." 11 U.S.C. § 328(a).

20. Bankruptcy Rule 2014(a) provides that an application for retention include:

specific facts showing the necessity for the employment, the name of the [firm] to be employed, the reasons for the selection, the professional services to be rendered, any proposed arrangement for compensation, and, to the best of the applicant's knowledge, all of the [firm's] connections with the debtor, creditors, any other party in interest, their respective attorneys and accountants, the United States trustee.

21. The Chapter 11 Trustee requires the services of barristers in Mauritius to exercise his responsibilities. The Barristers will endeavor to avoid the duplication of efforts and provide services as efficiently as possible.

22. Accordingly, the employment of the Barristers, as the Chapter 11 Trustee's barrister, upon the terms set forth herein and in the Proposed Order, is reasonable and in the best interest of the Debtor's estate.

23. The Chapter 11 Trustee submits that the Barristers' rates are reasonable, comparable to rates for other engagements, and within the range of rates charged by comparably skilled professionals who offer the same services.

24. Local Bankruptcy Rule 2014-1 provides that if "an application to employ a professional is filed within thirty (30) days after the commencement of services provided by that professional, the application shall be deemed contemporaneously filed unless the Court orders otherwise." Accordingly, the Chapter 11 Trustee requests authority to retain and employ the Barristers effective September 11, 2024, which was the date that the Barristers began providing services to the Chapter 11 Trustee.

## **NOTICE**

25. Notice of this Application has been given to the United States Trustee, the Debtor, the Committee, and, by electronic filing utilizing the Court's electronic filing ("CM/ECF") system, to all appearing parties who utilize the CM/ECF system.

### **NO PRIOR REQUEST**

26. No previous application for the relief requested herein has been made to this or any other Court.

[*Remainder of page intentionally left blank.*]

# **CONCLUSION**

WHEREFORE, for the foregoing reasons, Luc A. Despins, the Chapter 11 Trustee, requests that the Court enter an Order, substantially in the form of the Proposed Order filed herewith, granting the Application, and authorizing the Chapter 11 Trustee's employment of the Barristers, as his barristers, and order such other and further relief as the Court deems just and proper.

Dated: October 7, 2024 Chapter 11 Trustee in Chapter 11 Case of Ho Wan Kwok

> */s/ Luc A. Despins* Luc A. Despins

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

| ------------------------------------------------------ | x | | |---------------------------------------------------------|---------------------------------------|--| | In re: | :<br>:<br>Chapter 11 | | | HO WAN KWOK, et al.,2 | :<br>:<br>Case No. 22-50073 (JAM) | | | Debtors. | :<br>:<br>(Jointly Administered)<br>: | | | ------------------------------------------------------x | | |

# **CERTIFICATE OF SERVICE**

The undersigned hereby certifies that on October 7, 2024, the foregoing Application was electronically filed. Notice of this filing was sent by e-mail to all parties to the above-captioned chapter 11 case by operation of the Court's electronic filing ("CM/ECF") system or by 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.

Dated: October 7, 2024 New York, New York

By: */s/ G. Alexander Bongartz* G. Alexander Bongartz (admitted *pro hac vice*) PAUL HASTINGS LLP 200 Park Avenue New York, New York 10166 (212) 318-6079 alexbongartz@paulhastings.com

*Counsel for Chapter 11 Trustee*

² 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 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).

Case 22-50073 Doc 3646 Filed 10/07/24 Entered 10/07/24 16:32:23 Page 10 of 37

# **EXHIBIT A**

**Proposed Order**

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

| ------------------------------------------------------ | x | | |--------------------------------------------------------|-------------|-------------------------| | In re: | :<br>: | Chapter 11 | | HO WAN KWOK, et al., | :<br>: | Case No. 22-50073 (JAM) | | Debtors.1 | :<br>:<br>: | Jointly Administered | | ------------------------------------------------------ | x | |

# **[PROPOSED] ORDER (A) GRANTING APPLICATION OF CHAPTER 11 TRUSTEE FOR ENTRY OF ORDER, PURSUANT TO BANKRUPTCY CODE SECTIONS 327, 328, AND 330, BANKRUPTCY RULES 2014 AND 2016, AND LOCAL BANKRUPTCY RULES 2014-1 AND 2016-1, AUTHORIZING AND APPROVING RETENTION AND EMPLOYMENT OF PATRICE DOGER DE SPEVILLE, SENIOR COUNSEL, AND WILLIAM DE ROBILLARD, OF COUNSEL, AS BARRISTERS IN REPUBLIC OF MAURITIUS**

Upon the application (the "Application")2 of Chapter 11 Trustee Luc A. Despins (the

"Chapter 11 Trustee") in the above-captioned chapter 11 case (the "Chapter 11 Case"), for authority to retain and employ Mr. Patrice Doger de Spéville, Senior Counsel, and William de Robillard, of Counsel (together, the "Barristers"), as barristers in the Republic of Mauritius ("Mauritius"), effective as of September 11, 2024, pursuant to sections 327, 328, and 330 of title 11 of the United States Code (the "Bankruptcy Code"), Rules 2014 and 2016 of the Federal Rules of Bankruptcy Procedure (the "Bankruptcy Rules"), and Rules 2014-1 and 2016-1 of the Local Rules of Bankruptcy Procedure for the United States Bankruptcy Court for the District of

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 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).

² Capitalized terms used but not otherwise defined have the meanings set forth in the Application or the Doger de Spéville Declaration.

Connecticut (the "Local Bankruptcy Rules"), all as more fully set forth in the Application; and upon consideration of the Application and the Doger de Spéville Declaration; and this Court having jurisdiction to consider the Application and the relief requested therein in accordance with 28 U.S.C. §§ 157 and 1334 and the Standing Order of Reference from the United States District Court for the District of Connecticut; and consideration of the Application and the relief requested therein being a core proceeding pursuant to 28 U.S.C. § 157(b); and venue being proper in this Court pursuant to 28 U.S.C. §§ 1408 and 1409; and the Court having found that (i) the relief requested in the Application is in the best interest of the Debtor's estate, its creditors, and all parties-in-interest, (ii) the legal and factual bases set forth in the Application and the Doger de Spéville Declaration, and the record of any hearing on the Application before this Court establish just cause for the relief granted herein, (iii) the Barristers are "disinterested persons," as defined in section 101(14) of the Bankruptcy Code and as required by section 327(a) of the Bankruptcy Code, and (iv) the Barristers do not hold or represent an interest adverse to the Debtor's estate; and due and sufficient notice of the Application having been given under the particular circumstances; and it appearing that no other or further notice need be given; and upon all of the proceedings had before this Court; and after due deliberation and sufficient cause appearing therefor, it is hereby ORDERED THAT:

1. The Application is granted as set forth herein.

2. The Chapter 11 Trustee is authorized to retain and employ the Barristers as his barristers in Mauritius effective as of September 11, 2024 on the terms set forth in the Application and the Doger de Spéville Declaration.

3. The Barristers are authorized to act as the Chapter 11 Trustee's barrister, and to perform those services described in the Application.

4. The Estate shall be responsible for the Barristers' compensation and reimbursement of expenses with respect to the engagement.

5. The allowance of any compensation to be paid to the Barristers shall be determined in accordance with the procedures set forth in sections 330 and 331 of the Bankruptcy Code, Bankruptcy Rule 2016, and Local Bankruptcy Rule 2016-1.

6. Allowance of any compensation for the Barristers shall be limited to the extent of services actually performed, and expenses actually incurred, as barrister for the Chapter 11 Trustee Luc A. Despins, and shall not include compensation for the performance of any of the trustee duties that are generally performed by a Chapter 11 trustee without the assistance of a barrister.

7. The Barristers shall provide no less than ten business days' notice to the Chapter 11 Trustee, the United States Trustee, and counsel to any official committee before any increases in the rates they charges are implemented and shall file such notice with the Court.

8. The Chapter 11 Trustee is authorized and empowered to take all actions necessary to effectuate the relief granted in this Order.

9. The requirements of the Local Bankruptcy Rules are satisfied by the contents of the Application.

10. To the extent the Application and Doger de Spéville Declaration are inconsistent with this Order, the terms of this Order shall govern.

11. The terms and conditions of this Order shall be immediately effective and enforceable upon its entry.

12. This Court shall retain jurisdiction with respect to all matters arising from or related to the implementation, interpretation, and enforcement of this Order.

Case 22-50073 Doc 3646 Filed 10/07/24 Entered 10/07/24 16:32:23 Page 14 of 37

# **EXHIBIT B**

**Engagement Letter**

PATRICE DOGER DE SPEVILLE SC

Barrister-at-Law

Mr. Luc A. Despins, as Trustee for the Chapter 11 Estate of Ho Wan Kwok c/o Paul Hastings LLP 200 Park Avenue. New York, NY 10166 Email: lucdespins@paulhastings.com

This 27th September 2024

Dear Mr. Despins,

#### RE : Himalaya International Clearing Limited

Reference is made to your request to act for you, Mr Luc Despins ("the Client"), in your capacity as court-appointed Trustee for the chapter 11 estate of Ho Wan Kwok (the "US Debtor"), whose chapter 11 case is pending in the United States Bankruptcy Court for the District of Connecticut (the "Bankruptcy Court").

We would be pleased to assist the Client and to appear as barristers before the Supreme Court of Mauritius to intervene in the case before the Commercial Division Himalaya International Clearing Limited v. Silver Bank Limited and to take the necessary steps to (i) oppose the release of Himalaya International Clearing Limited ("HICL") deposits in Sliver Bank Limited ("Silver Bank") to HICL, (ii) apply for and obtain recognition in Mauritius, as foreign representative of the US Debtor's estate (Mr. Ho Wan Kwok), and (iii) lodge any such action in your aforesaid capacity to vindicate the US Debtor's estate's rights to such funds should you prevail before the US Bankruptcy Court on the ownership issue.

The barristers' team will be led by Patrice Doger de Spéville (Senior Counsel) with the assistance of William de Robillard (Counsel). Should there be any need for additional resources to ensure that this particular assignment is managed in the appropriate manner, we shall call upon other members of De Spéville Desvaux Chambers with the required expertise to assist.

#### DE SPEVILLE - DESVALX

. BUS & F

5th Floor, Chancery House, Listet Geoffroy Street, Port-Louis, Mouritins T: (+230) 208 8618 F: (+230) 210 3440 E: pdespeville@despeville-desvaas.com W: despeville-desvaux.com

We shall act under the instructions of ENS Africa (Mauritius), more precisely Thierry Koenig (Senior Attorney) and his team of attorneys and understand that we will be required to liaise principally with Douglass Barron and Alex Bongartz of Paul Hastings LLP in New York.

#### Fee Proposal

At this stage it is difficult to provide a ball park figure and set a fixed fee in respect of this assignment. Having regard to the complexity and urgency of the task, and the importance of the matter, we propose to act on a standard hourly rates (excluding VAT) as follows:

| Position | Rate (USD) | |----------------|------------| | Senior Counsel | 700 | | Counsel | 400 |

# Assumptions and Conditions:

This proposal is subject to the following assumptions and conditions:

- 1) Any tax, financial, accounting, operational, technical, IT, insurance, employment, data and competition matters are excluded from the scope of works. - 2) We shall not accrue fees and expenses outside the scope of work without your prior authorisation. - 3) VAT will be charged at the rate prevailing at the time of invoice (currently15%). - 4) The Client shall furnish all the KYC required for our internal compliance with the Financial Intelligence and Anti Money Laundering Act and other applicable laws. - 5) Notwithstanding anything herein to the contrary, payment in respect of the invoices shall be made in such amounts as may be allowed by the Bankruptcy Court on proper applications in accordance with the compensation procedures established and required by the Bankruptcy Court. The required procedures shall be made promptly by the Client and in any event not later than 30 days from receipt of the invoice. Should for any reason the Bankruptcy Court take more than 120 days from the date of application to grant its authorisation we shall be entitled to stop the mandate.


- 6) Our aggregate liability of whatever nature whether in contract, tort or otherwise, for any loss whatsoever and howsoever caused by or arising from this Agreement, shall not exceed four times the amount of fees received under this Agreement subject to such liability subsisting for a maximum of three years following the end of our engagement. - 7) Notwithstanding anything herein to the contrary, all matters related to the payment and allowance of our fees and expenses, including with respect to payment from funds held in trust and/or any claimed right of set off, shall be decided by the Bankruptcy Court in accordance with the compensation procedures established and required by the Bankruptcy Court. Except to the limited extent provided in the foregoing sentence, we shall not submit to the jurisdiction of the United States of America or cause us in any manner whatsoever to be subject to or have admitted to the jurisdiction of the jurisdiction of the United States of America.

We trust you will find the above satisfactory. We look forward to working with you on this matter and thank you again for the opportunity to assist you to protect the interest of the estate of the bankruptcy of Ho Wan Kwok.

Please do contact us should you have any questions or require additional information.

Yours faithfully,

Patrice Doger de Spéville, SC.

Acknowledged & accepted:

Name: Mr. Luc Despins Date: . Sept. 9 202


Case 22-50073 Doc 3646 Filed 10/07/24 Entered 10/07/24 16:32:23 Page 18 of 37

# **EXHIBIT C**

**Declaration**

# UNITED STATES BANKRUPTCY COURT DISTRICT OF CONNECTICUT BRIDGEPORT DIVISION

In re: HO WAN KWOK, et al.,

Chapter 11

Case No. 22-50073 (JAM)

Debtors.1

Jointly Administered

# DECLARATION OF PATRICE DOGER DE SPEVILLE IN SUPPORT OF APPLICATION OF CHAPTER 11 TRUSTEE FOR ENTRY OF ORDER, PURSUANT TO BANKRUPTCY CODE SECTIONS 327, 328, AND 330, BANKRUPTCY RULES 2014 AND 2016, AND LOCAL BANKRUPTCY RULES 2014-1 AND 2016-1, AUTHORIZING AND APPROVING RETENTION AND EMPLOYMENT OF PATRICE DOGER DE SPEVILLE, SENIOR COUNSEL, AND WILLIAM DE ROBILLARD, OF COUNSEL, AS BARRISTER IN REPUBLIC OF MAURITIUS

I, Patrice Doger de Spéville, being duly sworn, do depose and say:

1. I am a qualified Law Practitioner under the Law Practitioners Act and enrolled

before the Mauritius Supreme Court as a barrister. I am Senior Counsel at De Spéville -

Desvaux Chambers, which maintains its principal office at Fifth Floor, Chancery House. Lislet

Geoffroy Street, Port Louis, Mauritius, and I make this declaration (the "Declaration") in support

of the Application of Chapter 11 Trustee for Entry of Order, Pursuant to Bankruptcy Code

Sections 327, 328, and 330, Bankruptcy Rules 2014 and 2016, and Local Bankruptcy Rules

2014-1 and 2016-1, Authorizing and Approving Retention and Employment of Patrice Doger de

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 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).

Spéville, Senior Counsel, and William de Robillard, of Counsel as Barrister in Republic of Mauritius (the "Application")2 in connection with the Mauritius Action, and related matters (the "Engagement").

2. In relation to the Engagement, the professional client of Patrice Doger de Spéville, Senior Counsel, and William de Robillard, of Counsel (the "Barristers"), is the estate (the "Estate") of Ho Wan Kwok (the "Debtor") in his above-captioned chapter 11 case (the "Chapter 11 Case"). In relation to the Engagement, the Barristers will seek to recover their fees from the Estate, and I will file fee applications in the Chapter 11 Case on their behalf.

3. I graduated in Law at the Council of Legal Education School of Law, London, England and was called to the Mauritian Bar in 1978. I am a member of the Middle Temple, holder of French 'Licence & Maitrise en Droit,'. I was elected President of the Mauritius Bar Association in 2008 and elevated to the rank of Senior Counsel in June 2010. I deal with both international and domestic clients, primarily in banking, financial, insurance, and commercial matters. My experience encompasses, among other things, corporate matters, insolvency, banking and financing matters, and as well as complex commercial litigation and arbitration.

4. Jo The Barristers will file applications for compensation of professional services rendered and for reimbursement of expenses incurred in connection with the Engagement pursuant to sections 330 and 331 of the Bankruptcy Code, Bankruptcy Rule 2016, Local Bankruptcy Rule 2016-1, and any other applicable rules and orders with respect to this Chapter 11 Case.

5. Engagement. At present, the the 2024 hourly rate are \$700 for Mr. Doger de Spéville and \$400

² Capitalized terms used but not otherwise defined have the meanings set forth in the Application.

for Mr. de Robillard (plus 15% VAT). The Barristers may also bill the Estate for any out-ofpocket expenses made on behalf of the Chapter 11 Trustee, including photocopying, postage and package deliveries, court fees, transcripts, witness fees, service fees, travel expenses, and computer-aided research.

6. To the best of my knowledge and belief after due inquiry, the Barristers are "disinterested persons" within the meaning of section 101(14) of title 11 of the United States Code (the "Bankruptcy Code") in that the Barristers:

- are not creditors, equity security holders, or insiders of the Debtor; a. - b. are not, and were not within two years before the date of filing of the Debtor's petition, directors, officers, or employees of the Debtor; and - C. do not have an interest materially adverse to the interest of the Debtor's estate or of any class of creditors or equity security holders, by reason of any direct or indirect relationship to, connection with, or interest in, the Debtor, or for any other reason.

7. I attach to this Declaration, as Schedule 1, a consolidated list of parties in interest in connection with the Chapter 11 Case (the "Interested Parties") that has been produced by Paul Hastings and provided to the Barristers before my signing this Declaration that I am informed includes:

- a. parties listed as creditors, executory contract counterparties, and codebtors on the Debtor's Schedules D, F, G, and H [Docket No. 78]; - b. parties listed on the Debtor's Statement of Financial Affairs ("SOFA") [Docket No. 77], including (i) as recipients of payments within 90 days prior to the filing of the Chapter 11 Case (SOFA Part 3, Question 6); (ii)

parties involved in litigation in which the Debtor is a party (SOFA Part 4, Question 9); and businesses owned by the Debtor (SOFA Part 11, Question 27).

- c. parties and counsel filing notice of appearances in the Chapter 11 Case; - d. the Court and personnel of the office of the United States Trustee; and - e. other parties in interest that I have become aware of as a result of the Chapter 11 Trustee's ongoing investigation of the Debtor's assets.

The Barristers have conducted reasonable checks of the Interested Parties against our records and data, and have determined that to the best of our knowledge and belief, the Barristers do not have any relationship or connection with the Largest Unsecured Creditors, the Debtor, Family Members and Related Entities, the Bankruptcy Judge and U.S. Trustee Personnel. To the best of my knowledge, the Barristers do not have any relationship or connection with the Other Interested Parties, or, to the best of my knowledge, with any other creditor of the Debtor, subject to the following exceptions:

The Barristers have or have had working relationships with the following firms:

- a. DLA Piper LLP - b. Ernst and Young LLP - C Herbert Smith LLP - d. Hogan Lovells International LLP

The following entity is a client of the Barristers:

e. Sotheby's International Realty

The Barrister's relationship with the entities identified in clauses a. through e. are unrelated to the Debtor and the Chapter 11 Case.


8. While the Barristers have made a diligent effort to ascertain the identity of any connections or potential conflicts with the Interested Parties, to the extent that any additional information comes to light, the Barristers will review, disclose, and resolve any conflict or adverse interests that may appear.

9. Based on the foregoing, insofar as I have been able to ascertain based on the information currently available to me: (a) the Barristers have no connection with the Debtor, his creditors, the U.S. Trustee, any person employed in the office of the U.S. Trustee, or any other party with an actual or potential interest in the Debtor or his respective attorneys or accountants; and (b) (i) the Barristers are not creditors, equity security holders, or insiders of the Debtor or his affiliates, (ii) the Barristers have not been, within two years before the Petition Date, a director, officer, or employee of the Debtor or his affiliates, and (iii) the Barristers do not have any interest materially adverse to the interests of the Debtor's estate or any class of creditors or equity security holders by reason of any direct relationship to, connection with, or interest in the Debtor, or for any other reason. Therefore, I understand from my discussions with Paul Hastings that this means the Barristers are "disinterested persons" within the meaning of section 101(14) of the Bankruptcy Code, as modified by section 1107(b).

10. I further understand from such discussions that Appendix B of the U.S. Trustee Guidelines (the "Larger Case Guidelines") does not apply in this Chapter 11 Case, because the Debtor's petition does not list \$50 million or more in assets and \$50 million or more in liabilities. In particular, I am informed that the Debtor estimated the value of his assets between \$50,001 and \$100,000.

11. In the interest of providing maximum disclosure, and notwithstanding my position concerning the inapplicability of the Larger Case Guidelines, I provide the following response on

behalf of the Barristers to the request for information set forth in Paragraph D. 1. of the Larger

Case Guidelines:

Question: Did you agree to any variations from, or alternatives to, your standard or customary billing arrangements for this engagement?

Answer: No.

- Question: Do any of the professionals included in this engagement vary their rate based on the geographic location of the bankruptcy case? - Answer: No. - Question: If you represented the client in the 12 months prepetition, disclose your billing rates and material financial terms for the prepetition engagement, including any adjustments during the 12 months prepetition. If your billing rates and material financial terms have changed postpetition, explain the difference and the reasons for the difference. - Answer: Not applicable. The Barristers have not previously represented the Chapter 11 Trustee. - Question: Has your client approved your prospective budget and staffing plan, and, if so, for what budget period?

Answer: Not applicable.

12. The Barristers have neither shared nor agreed to share with any other person

compensation received in connection with the Engagement, except as is permitted by §504(b)(1)

of the Bankruptcy Code.

13. I consent that the following language may be included in any order by the Court

approving the Chapter 11 Trustee's application in connection with my instruction in connection

with the Engagement.

Allowance of any compensation for the Barristers shall be limited to the extent of services actually performed, and expenses actually incurred, as barrister instructed to act on behalf of the Chapter 11 Trustee Luc A.

Despins, and shall not include compensation for the performance of any of the trustee duties that are generally performed by a Chapter 11 trustee without the assistance of an barrister.

Pursuant to 28 U.S.C. § 1746, I declare under penalty of perjury under the laws of the

United States that the above statements are true and correct.

Dated: October 1, 2024, at Port Louis, Republic of Mauritius

101 Patrice Doger de Spéville

#### Schedule 1

#### SCHEDULE OF PARTIES IN INTEREST - IN RE KWOK

#### 20 LARGEST UNSECURED CREDITORS

PACIFIC ALLIANCE ASIA OPPORTUNITY GOLDEN SPRING NEW YORK RUI MA CHENG JIAN WU JIAN SHE NING YE GUO BAOSHENG YAN LAN & WU ZHENG HONG QI QU NAN TONG SI JIAN JIAN GONG YAN ZHAO YUA HUA ZHUANG SHI LIEHONG ZHUANG/XIAO YAN ZHU WEICAN MENG/BOXUN INC. SAMUEL NUNBERG LAMP CAPITAL LLC JUN CHEN AKA JONATHAN HO YUE HUA ZHU SHI XIONG XIAN WEI YE HUIZEN WANG

#### DEBTOR, FAMILY MEMBERS, AND CERTAIN RELATED ENTITIES

HO WAN KWOK (A.K.A MILES GWOK, MILES GUO AND WENGUI GUO) HING CH NGOK/YUE QINGZHI QIANG GUO (A.K.A. MILESON GUO) MEI GUO/MEI GUI HK INTERNATIONAL FUNDS INVESTMENTS (USA) LIMITED, LLC BRAVO LUCK LIMITED GENEVER HOLDINGS CORPORATION GENEVER HOLDINGS LLC

#### BANKRUPTCY JUDGE AND U.S. TRUSTEE PERSONNEL

HONORABLE JULIE A. MANNING WILLIAM HARRINGTON KIM L. MCCABE HOLLEY CLAIBORN JOSEPH H. FLAMINI ERIN HOGAN STEVEN MACKEY FRANK MARINO JENNIFER J. MOREY NICOLE NEELY SHARON WARNER JOHN GERVAIS

OTHER INTERESTED PARTIES

1245 FACTORY PLACE, LLC 12476517 CANADA SOCIETY 1322089 B.C. LTD. 1332156 B.C. LTD 17 MILES, LLC 2 B PACKING LLC 270 W. 39TH ST. CO., LLC 2LAWRENCE RIVER 3 COLUMBUS CIRCLE LLC 5780 SAGUARO LLC 7 NOD HILL LLC, 7 STAR EAST NY LLC 9 EAST 40TH STREET LLC A.Z. BIGIOTTERIE S.A.S. DI ZANUTTO GABRIELE & C. AAGV LIMITED AARON A. MITCHELL AARON A. ROMNEY ABRAMS FENSTERMAN, LLP ACA CAPITAL GROUP LIMITED ACA CAPITAL LIMITED ACA INVESTMENT FUND ACA INVESTMENT MANAGEMENT LTD. ACASS CANADA LTD. ACE DECADE HOLDINGS LIMITED ADAM CHEN NI AFFILIATED ADJUSTMENT GROUP, LTD. AGORA LAB. INC. AI GROUP HOLDINGS INC., AIG PROPERTY CASUALTY COMPANY AKERMAN LLP ALEX HADJICHARALAMBOUS ALFA GLOBAL VENTURES LIMITED ALFONSO GLOBAL LIMITED ALFONSO GLOBAL VENTURES LIMITED ALLIED CAPITAL GLOBAL LIMITED ALPINE FIDUCIARIES SA AMAZING SKY AVIATION LIMITED AMAZON WEB SERVICES LLC AMAZON WEB SERVICES, INC. AMAZON.COM INC. AMERICAN ARBITRATION ASSOCIATION, INC. AMERICAN EXPRESS COMPANY AMY BUCK AN HONG ANA C. IZQUIERDO-HENN ANDREW CHILDE ANDREW SULNER/FORENSIC DOCUMENT EXAMINATIONS, LLC ANN MARIE LEE ANTHEM HEALTH PLANS, INC. ANTHONY DIBATTISTA ANTON DEVELOPMENT LIMITED APPLE INC. APPSFLYER INC

APSLEY YACHTS LIMITED ARETHUSA FORSYTH ARI CASPER ARNALL GOLDEN GREGORY LLP ARNOLD & PORTER KAYE SCHOLER LLP ARRI AMERICAS INC. ART WOLFE. INC. ASAP SRL ASSETS SINO LIMITED AUSPICIOUS COAST LIMITED AVIATION E LLP AVIATION TRUST COMPANY LLC AXOS BANK AXOS FINANCIAL, INC. B&H FOTO & ELECTRONICS CORP. BAC CAPITAL LLC BAIQIAO TANG A/K/A TANG BAIQIAO BAKER HOSTETLER LLP BANCO POPULAR DE PUERTORICO BANK OF AMERICA BANK OF CHINA - NEW YORK BRANCH AND/OR BANK OF CHINA LIMITED BANK OF MONTREAL BANK OF THE WEST BANNON STRATEGIC ADVISORS, INC. BARCLAY DAMON LLP BARCLAYS BANK PLC BEIJING BI HAI GE LIN YUAN LIN LU HUA, LTD. BEIJING CHENG JIAN WU JIAN SHE GROUP, LTD. BEIJING FU LE HONG MA JIAN ZHU ZHUANG SHI GONG CHENG, LTD. BEIJING PANGU INVESTMENT CO. BEIJING ZENITH HOLDINGS CO. BEIJING ZHONG XIAN WEI YE STAINLESS DECORATION CENTER BEILE LI BELLERIVE ATTORNEYS AT LAW BENHAR OFFICE INTERIORS LLC BENTO TECHNOLOGIES, INC. BERING YACHTS, LLC BERKELEY ROWE LIMITED BERNARDO ENRIQUEZ BESTVIEW 1 PTY LTD BINGNAN CUI BINGSHANG JIAO BLACKTHORN FINANCEN INC. BLUE CAPITAL BLUEBERRY BUILDERS, LLC BNY MELLON, N.A. BOARDWALK MOTOR IMPORTS, LLC BOHONNON LAW FIRM BOIES SCHILLER BONNIE C. MANGAN


BOXUNINC. BRANCH BRAVO LUCK LIMITED BRENT PETRO INC. BRIAN HOFMEISTER BROWN HARRIS STEVENS BROWN RUDNICK, LLP BRUNE LAW PC BSA STRATEGIC FUND BSA STRATEGIC FUND I BSI GROUP LLC BUCK, ESQ. LLC BURNETTE SHUTT AND MCDANIEL PA CAHILL GORDON & REINDEL LLP CAIYAN LING CAMERON SMEE CANADIAN IMPERIAL BANK OF COMMERCE CAPITAL ONE BANK CAPITAL ONE, NA CARIBE CONDADO, LLC CARMODY TORRANCE SANDAK & HENNESSEY LLP CAYUSE GOVERNMENT SERVICES, LLC CEDRIC DUPONT ANTIQUES CELESTIAL TIDE LIMITED CESARE ATTOLINI NY LLC CFG GLOBAL LIMITED CHAO KANG SUN CHAO-CHIH CHIU CHARLES SCHWAB CHARMOY & CHARMOY LLC CHASE BANK CHEN XIN XIN CHENGLONG WANG CHENXI WANG CHI WAIKWOK CHIESA SHAHINIAN & GIANTOMASI PC CHINA CITIC BANK INT'L CHINA GOLDEN SPRING GROUP (HONG KONG) LIMITED CHOICE FINANCIAL BANK CHONG SHEN RAPHANELLA CHRIS LEE (A/K/A NAN LI, CHRIS LI, MEI GUO XIAO LI) CHRISTIE'S INTERNATIONAL REAL ESTATE NEW CHRISTINE CHEN CHRISTINE FROSINI CHRISTODOULOS G. VASSILIADES & CO. LLC CHUAN LING Y ANG CHUANG XIN LTD. CHUI KUK WU CHUNFENG XIA CHUNGUANG HAN CHUNHUI SONG

BOOMING SAIL NEW YORK LLC

CI CHEN CIBC INC. (D/B/A CIBC) CINDY ZHANG CIRRUS DESIGN CORPORATION (D/B/A CIRRUS AIRCRAFT) CIRRUS INDUSTRIES, INC. CITIBANK CITIZENS FINANCIAL GROUP, INC. CITY NATIONAL BANK CLARK HILL PLC CLAYMAN & ROSENBERG LLP CLAYMAN ROSENBERG KIRSHNER & LINDER LLP CLOUDFLARE, INC. COHN BIRNBAUM & SHEA P.C. COLDWELL BANKER COLE SCHOTZ P. C. COMERICA INCORPORATED (D/B/A COMERICA BANK) COMMUNITY FEDERAL SAVINGS BANK COMPASS. INC. CONSERVATIVE CAMPAIGN TECHNOLOGY, LLC COTTON CRAFT TEXTILES INTL TRADING COUNSEL PRESS INC. COWDERY, MURPHY & HEALY, LLC CRANE ADVISORY GROUP LLC CREATIVE APEX INVESTMENTS LIMITED CROCKER MANSION ESTATE LLC CROWELL & MORING LLP CRYSTAL BREEZE INVESTMENTS LIMITED CUI ZHULI CUMMINGS & LOCKWOOD, LLC CURIOSITY CORP. LLC D&D SOLUTIONS LLC D.P. TEXTILE & APPAREL, INC. D4ZERO S.R.L. DAIHO ZHOU DANIEL PODHASKIE DANIEL S. ALTER DANYULIN DARK SHADOWS LLC DAVID FALLON DAWN STATE LIMITED DBS BANK LTD DEFENG CAO DELTEC BANK & TRUST LIMITED DENG LI DENG QIAN DEUTSCHE BANK TRUST COMPANY AMERICA DEUTSCHE HANDELSBANKEN AG DIME COMMUNITY BANK DING "IVAN" LIN DING G. WANG A/K/A DINGGANG WANG DING QIANG SHEN DIRECT PERSUASION LLC

DLA PIPER LLP (US) DNM BEAUTY DISTRIBUTION DOAA DASHOUSH DONGNA FANG DREAM PROJECTS LLC DU JIAN YI DWF LLP E.L.J.M. CONSULTING LLC EAST WEST BANCORP, INC. EAST WEST BANK EASTERN PROFIT CORPORATION LIMITED EDMISTON AND COMPANY LIMITED EDUARDO EURNEKIAN EFICENS SYSTEMS LLC EHSAN MASUD EISNER ADVISORY GROUP LLC ELITE WELL GLOBAL LIMITED ELIXIR TECHNICAL CONSULTING LLC ELLIOTT KWOK LEVINE & JAROSLAW LLP EMILE P DE NEREE EMPIRE BLUE CROSS BLUE SHIELD EMPIRE GROWTH HOLDINGS ENGINEERING OPERATIONS AND CERTIFICATION SERVICES, LLC EPIQ CORPORATE RESTRUCTURING, LLC ERIC GOLDSMITH MD, LLC ERNST & YOUNG LLP EVOLVE BANK AND TRUST FAEGRE DRINKER BIDDLE & REATH LLP FAM UNITED LLC FAN BINGBING FAN JING FANGGUI ZHU FANIA ROOFING COMPANY FARHAD ZARETI FARRANT GROUP LIMITED FAY YE FEDERAL CORPORATION FEDERAL EXPRESS CORPORATION FEIFEI MA FENG PENG RELLOS FENG YI FENG ZHU FENGGUO LI FENGJIE MA FFP (BVI) LIMITED FIESTA INVESTMENT LTD. F/K/A FIESTA PROPERTY DEVEL FINN DIXON & HERLING LLP FIONA YU FIRST ABU DHABI BANK FIRST COUNTY BANK FIRST REPUBLIC BANK FIRSTBANK PUERTO RICO FLAGSTAR BANK, N.A.

DJD CREATIVE LLC

FLAT RATE MOVERS, LTD. FLYING COLOURS CORP FORBES HARE FORBES HARE LLP FORTNUM INFORMATION SECURITY LIMITED FOX NEWS NETWORK, LLC FREEDOM MEDIA VENTURES LIMITED FUNGWAN TRADING INC. FUNING ZHANG FUNKY FOUNDATIONS, INC. FV BANK INTERNATIONAL INC. G CLUB HOLDCO I LLC G CLUB INTERNATIONAL LIMITED G CLUB ONE G CLUB OPERATIONS LLC G CLUB THREE G CLUB TWO G CLUB US OPERATIONS INC. G CLUB US OPERATIONS LLC G CLUBTHREE G FASHION G FASHION (CA) G FASHION HOLD CO A LIMITED G FASHION HOLD CO B LIMITED G FASHION INTERNATIONAL LIMITED G FASHION LLC G FASHION MEDIA GROUP INC. G FASHION US OPERATIONS INC. G LIVE. LLC G MUSIC LLC G NEWS LLC. G TRANSLATORS PTY LTD G4S SECURITY SYSTEMS (HONG KONG) LTD. GALAXY LTD GANFER SHORE LEEDS & ZAUDERER, LLP GAO BINGCHEN GBROADCAST, LLC G-CLUB G-CLUB INVESTMENTS LIMITED GCP INVESTMENT ADVISORS SL G-EDU INC. GEORGE L. SU GEORGIOU PAYNE STEWIEN LLP GETTR USA, INC. GF IP, LLC GF ITALY LLC GFASHION MEDIA GROUP INC. GFNY INC. GINNEL ASSOCIATES, INC. (D/B/A GINNEL REAL ESTATE) GLADYS CHOW GLENN MELLOR GLOBAL GROUP LIMITED GLOBALIST INTERNATIONAL LIMITED GM 27 LLC GMUSIC,


HOLY CITY HONG KONG VENTURES, LTD. HONG KONG INTERNATIONAL FUNDS INVESTMENTS LIMITED HONG QI QU JIAN SHE GROUP, LTD. HONG QIU HONG ZENG HONGWEI FU HONGXIA XU HONGXIN ASH HOU YUAN CHAN HOUSER & ALLISON, APC HOUSTON LITSTAR LLC HSBC BANK USA, HSIN SHIH YU HUA AN XIE HUANG YAO HUDSON DIAMOND HOLDING INC. HUDSON DIAMOND HOLDING LLC HUDSON DIAMOND LLC HUDSON DIAMOND NY LLC HUGGA LLC HUI JIN HUK TRADING INC. ICE24 SRO IHOTRY LTD IMMOBILIARA BARBARA 2000 SRL IMPERIUS INTL. TRADE CO. LTD. INDIUM SOFTWARE INC. INFINITE INCREASE LIMITED INFINITUM DEVELOPMENTS LIMITED INFINITY TREASURY MANAGEMENT INC. INSIGHT CAPITAL INSIGHT PHOENIX FUND INSIGHT TITLE SERVICES LLC INTERNATIONAL TREASURE GROUP LLC INTESA SANPAOLO SPA INVESTORS BANK ISRAEL DISCOUNT BANK OF NEW YORK IVEY, BARNUM & O'MARA LLC IVY CAPITAL ADVISOR LIMITED J TAN JEWELRY DESIGN, INC. JACK S. LIPSON JAMES PIZZARUSO JAMESTOWN ASSOCIATES, LLC JANCO SRL JANOVER LLC JAPAN HIMALAYA LEAGUE, INC. JASON MILLER JDM STAFFING CORP. JENNER & BLOCK LLP JENNIFER FANGFANG DING JENNIFER MERCURIO JENNY LI JERSEY, INC. JESSE BROWN JESSICA MASTROGIOVANNI

JETLAW LLC JIA LI WANG JIA YANG JIA YANG LI JIAHUI LIU JIALIN QIN JIAMEI LU JIAMING LIU JIAN FAN JIAN HUA ZHANG JIAN ZHONG HU JIANG SU PROVINCE JIAN GONG GROUP LTD BELING BRANCH JIANG YUNFU BE JIANHAI JIAO JIANHU YI JIANHUA ZHENG JIANMIN HE JIANSHENGXIE AND JIEFU ZHENG JIANXIAO CHEN JIAYAO G JIE ZHANG JINFENG WU JING GENG JING WU JINLAN YAN JIRONG ZHANG JK CHEF COLLECTIONS LLC JM BULLION INC. JNFX LTD. JOHN B. BERRYHILL JOHN P. MORGAN JOHN SLAU JONATHAN YOUNG JOSEPH CHEN JOSHUA 1. SHERMAN JOVIAL CENTURY INTERNATIONAL LIMITED JOYORD SPORTSWEAR LIMITED JPMORGAN CHASE BANK, N.A. JUMBO CENTURY LIMITED JUN CHEN JUN LIU JUN QIAO JUN YUN ZHANG JUNE SHI JUNIIE JIANG K LEGACY LTD. K&L GATES LLP KAEN LIU KAIXIN HONG KALIXUN TRADING LIMITED KAMEL DEBECHE KAN CHAN KARIN MAISTRELLO KATHLEEN SLOANE KEARNY BANK

KERCSMAR FELTUS & COLLINS PLLC KEYI ZIKLIE KHALED ASHAFY KIM THONG LEE KIN MING JE KIN MING JE/WILLIAM JE KIRKLAND & ELLIS LLP KOPPLE, KLINGER & ELBAZ, LLP KROLL, LLC KUI CHENG KYLE BASS KYRGYZ-SWISS BANK CJSC LA INTERNATIONAL FOUNDATION LABARBIERA CUSTOM HOMES LAILAU LALIVE SA LAMP CAPITAL LLC LAN GU LAN LIN LAO JIANG LAW FIRM OF CALLARI PARTNERS, LLC LAW OFFICE OF RICHARD E. SIGNORELLI LAW OFFICES OF RONALD I. CHORCHES, LLC LAWALL & MITCHELL, LLC LAX & NEVILLE LLP LAZARE POTTER GIACOVAS & MOYLE LEADING SHINE LIMITED LEADING SHINE NY LTD LEE CHU LEE VARTAN LEEWAYHERTZ TECHNOLOGIES LEGENDS OWO. LLC LEICESTER HILL INFROMATICES LLC LEONARD SCUDDER LEXINGTON PROPERTY AND STAFFING INC. LI LIU LILONG LI SHO YO LI TANG LI ZHANG LIANG LIU LIANYING SU LIAPULL S.R.L. LIBERTY JET MANAGEMENT CORP. LIEHONG ZHUANG LIHONG "SARA" WEI LAFRENZ LIHONG WEI LAFRENZ (AKA SARA WEI) LIMARIE REYES LIMARIE REYES MOLINARIS LIN DANG LIN XIN LINDA HE CHEUNG LINWAN "IRENE" FENG LIU DONGFANG LLC STZ FUND NO. 1 LOBEL MODERN NYC

LOGAN CHENG (F/K/A SHUIYAN CHENG) LONG GATE LIMITED LORO PIANA S.P.A. LUMINESCENCE CO. LTD LUXURY CLEANING. INC. LYZON ENTERPRISES CORPORATION M&T BANK MA XINGCHAO MACARON LIMITED MACDONALD MAJOR LEAD INTERNATIONAL LIMITED MANDELLI USA, INC. MANHATTAN MOTORCARS, INC. MANUEL MARTINEZ ANZALDUA MANUFACTURERS AND TRADERS TRUST COMPANY MAR-A-LAGO MAR-A-LAGO CLUB LLC MARCELLA MONICA FALCIANI MARCUM LLP MARINI PIETRANTONI MUNIZ LLC MARINO, ZABEL & SCHELLENBERG, PLLC MARK GUNDERSON MARTHA JEFFERY MARY DOWDLE (A/K/A MUFFIN DOWDLE) MARY FASHION S.P.A. MARY JIANG MAUNAKAI CAPITAL MAX FEI MAX KRASNER MAYWIND TRADING LLC MCDONNELL & WHITAKER LLC MCELROY, DEUTSCH, MULVANEY 8 CARPENTER, LLP MCMANIMON, SCOTLAND & BAUMANN, LLC MEDICAL SUPPLY SYSTEM INTERNATIONAL LLC MEDICI BANK INTERNATIONAL LLC MEI KUEN KWOK MEIEN KIKUCHI MEISTER SEELIG & FEIN PLLC MELISSA FRANCIS MELISSA MENDEZ MENGYAO HE MERCANTILE BANK INTERNATIONAL CORP. MERCANTILE GLOBAL HOLDINGS, INC. MERCEDES-BENZ MANHATTAN, INC. META PLATFORMS INC. METROPOLITAN COMMERCIAL BANK AND/OR METROPOLITAN BANK HOLDING CORP. MF19 INC. MI KYUNG YANG MICHAEL LI & CO. MICHAEL S. WEINSTEIN MIHO NISHIMURA

MILES GWOK MILLER MOTORCARS INC. MIMAII NZ LIMITED MIN YANG MINDY WECHSLER MING NI MING WU MINGHUA ZHANG MINGRUI ZHAO MINTZ & GOLD LLP MISHCON DE REYA LLP MOA-FU MODSQUAD INC. MORAN YACHT MANAGEMENT, INC. MORGAN STANLEY MORITT HOCK & HAMROFF MORRISON COHEN LLP MORVILLO ABRAMOWITZ GRAND IASON & ANELLO P.C. MORVILLO ABRAMOWITZ GRAND IASON & ANELLO PC MOS HIMALAYA FOUNDATION INC. MOSAICON SHOES SRL MOUNTAINS OF SPICES INC. MURTHA CULLINA LLP MZC FINANCIAL INC. N.A.R. ENTERPRISES INC. N87 INC. NADEEM AKBAR NAME CORP LLC NARDELLO & CO., LLC NATIONAL AUSTRALIA BANK LIMITED NATIONAL SWEEPSTAKES COMPANY, LLC NAV CONSULTING INC. NAV FUND SERVICES (CAYMAN) LTD. NEALON LAW LLC NEW DYNAMIC DEVELOPMENT LIMITED NEW FEDERAL STATE OF CHINA NEW MULBERRY PTE LTD. NEW TREASURE LLC NEW YORK MOS HIMALAYA LLC NEXBANK NEXT TYCOON INVESTMENTS LIMITED NICHOLAS F. SAVIO NING LI NING ZHAO NIUM, INC. NOBLE FAME GLOBAL LIMITED NODAL PARTNERS, LLC NOVELTY HILL LTD. NRT NEW ENGLAND LLC (D/B/A COLDWELL BANKER RESIDENTIAL BROKERAGE) NUOXI LIU NYC DEPT OF FINANCE O.S.C. ORBIT II SERVICE COMPANY LLC

MILES GUO

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