郭文贵破产案 · MOTION · ECF #3752

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

IN RE:

HO WAN KWOK, et al.,

Chapter 11

*Debtors*. [1](#page-0-0) Case No. 22-50073 (JAM) (Jointly Administered) October 28, 2024

## **G CLUB OPERATIONS LLC'S MOTION TO QUASH AND OBJECTIONS TO THE TRUSTEE'S RULE 2004 EXAMINATION SUBPOENA**

Pursuant to Fed. R. Civ. P. 45, as made applicable pursuant to Fed. R. Bankr. P. 7045 and 9016, G Club Operations LLC ("G Club") hereby moves to quash the subpoena dated October 9, 2024 (the "Subpoena") that was served by Luc A. Despins, in his capacity as the chapter 11 trustee (the "Trustee") of the above-captioned debtors (collectively, the "Debtors") and issued pursuant to 11 U.S.C. § 1109(b), Rule 9016 of the Federal Rules of Bankruptcy Procedure (the "Bankruptcy Rules"), Bankruptcy Rule 2004, and Local Bankruptcy Rule 2004-1. A copy of the Subpoena is attached to the memorandum of law as Exhibit A. This Motion is fully supported by the memorandum of law filed concurrently herewith. G Club further sets forth objections to the Subpoena in the memorandum of law.

# **REQUEST FOR EXPEDITED HEARING**

# **Contemporaneous herewith, G Club has filed a request for the Court to hold a hearing**

<span id="page-0-0"></span>¹ The Debtors in the main Chapter 11 case are Ho Wan Kwok (also known as Guo Wengui, Miles Guo, and Miles Kwok) (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.

**to occur on this matter on November 6, 2024, or as soon thereafter as the Court may have availability for a hearing.[2](#page-1-0) The Trustee will file opposition to this Motion on or before November 1, 2024. Should the Court deny this Motion the parties have agreed to hold a deposition of G Club's representative(s) on November 20, 2024. The parties are continuing to work together to resolve this discovery dispute.**

For the foregoing reasons, G Club respectfully requests that the court GRANT this Motion, quash the Subpoena, and grant such other relief as the Court deems appropriate.

\* \* \*

#### **G CLUB OPERATIONS, LLC**

By: /s/ Jeffrey M. Sklarz Jeffrey M. Sklarz Kellianne Baranowsky GREEN & SKLARZ LLC One Audubon St, 3rd Floor New Haven, CT 06511 Tel: 203-285-8545 jsklarz@gs-lawfirm.com kbaranowsky@gs-lawfirm.com

<span id="page-1-0"></span>² The undersigned is unavailable for a hearing on November 5, 2024, as he will be in a mediation with the Honorable James Siciilan in the matter of *Fiano v. 425 Hartford Turnpike Associates, LLP, Case No. TTD-CV24- 6029505-S* (J.D. of Tolland at Rockville).

#### **CERTIFICATE OF SERVICE**

I hereby certify that a copy of the foregoing has been served by CMECF on the partiesin-interest set forth on the service list. Parties-in-interest may access this document by way of CMECF.

Date: October 28, 2024 /s/ Jeffrey M. Sklarz