郭文贵破产案 · ORDER · ECF #3704

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

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HO WAN KWOK, GENEVER ) CASE NO.: 22-50073 (JAM) HOLDINGS CORPORATION and ) GENEVER HOLDINGS LLC ) OCTOBER 16, 2023 \_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_)

In Re: ) CHAPTER 11

## **LIMITED OBJECTION TO MOTION**

Ohtzar Shlomo Solomon Treasure LLC ("Ohtzar") hereby objects to the Trustee's Motion to Sell the contents of the Mahwah New Jersey mansion (the "Mahwah Property") and in support represents the following:

1. Ohtzar is a defendant in adversary proceeding # 24-05082 in which the Trustee has sued Ohtzar to recovery funds allegedly paid to it by HCHK Property Management, Inc. ("HCHK") an alleged alter-ego of the Debtor.

2. Ohtzar's only dealings with HCHK were to sell the furniture shown on Exhibit A (the "Furniture").

3. While the Trustee has sued Ohtzar for the price paid by HCHK for the Furniture, the Trustee has not offered to return the Furniture to Ohtzar.

4. The Trustee new seeks to sell the Furniture, presumably through an agent or auctioneer at substantial expense to the Estate, keep the proceeds of the sale, while continuing to sue Ohtzar for the sales price of the Furniture. This is inequitable, unfair, and inefficient.

5. Ohtzar's business is to sell objects such as the Furniture and it is in the best position to obtain the best possible price for the Furniture.

6. In order to maximize the proceeds available to the Estate, Ohtzar has offered to sell the Furniture on consignment without fee or commission for the benefit of the Estate, with all proceeds to be applied to reduce Ohtzar's potential liability to the Estate. To date, the Trustee has not been willing to agree. While Ohtzar has no objection to the sale of the Property and its contents, other than the Furniture, Defendant objects to the sale of the Furniture, except as Ohtzar has proposed in paragraphs 5 and 6 above.

7. Accordingly, Ohtzar files this limited objection to the sale of the Furniture. Ohtzar does not object to the sale of the Mahwah Property.

## **DEFENDANT IN ADV. PRO. NO.: 24-05082 OHTZAR SHLOMO SOLOMON TREASURE LLC**

By: /s/ *Jeffrey Hellman* Jeffrey Hellman, Esq. Law Offices of Jeffrey Hellman, LLC 195 Church Street, 10th Floor Tel.: 203-691-8762 Fax: 203-832-4401 New Haven, CT 06510 [jeff@jeffhellmanlaw.com](mailto:jeff@jeffhellmanlaw.com) Federal Bar No.: ct04102