郭文贵破产案 · ORDER · ECF #3849

元数据

当事人: 郭文贵 (Guo Wengui / Miles Guo / Ho Wan Kwok)
法院: CTB
案号: 22-50073
ECF #: 3849
类型: ORDER
立案日: 2024-11-25

原始法庭文件为英文，下方为英文全文。

全文

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

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

# **APPLICATION OF CHAPTER 11 TRUSTEE FOR ENTRY OF ORDER, PURSUANT TO BANKRUPTCY CODE SECTIONS 327 AND 330, BANKRUPTCY RULES 2014 AND 2016, AND LOCAL BANKRUPTCY RULES 2014-1 AND 2016-1, AUTHORIZING AND APPROVING RETENTION AND EMPLOYMENT OF PETER SHAW AS BARRISTER IN UNITED KINGDOM**

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 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 Peter Shaw, King's Counsel ("Mr. Shaw"), as barrister in the United Kingdom

("UK"). In support of this Application, the Chapter 11 Trustee submits the *Declaration of Peter*

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).

*Shaw in Support of Application of Chapter 11 Trustee for Entry of Order, Pursuant to Bankruptcy Code Sections 327 and 330, Bankruptcy Rules 2014 and 2016, and Local Bankruptcy Rules 2014-1 and 2016-1, Authorizing and Approving Retention and Employment of Peter Shaw as Barrister in United Kingdom* (the "Shaw Declaration"), attached as **Exhibit B**, 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, authorizing and approving the retention and employment of Peter Shaw, King's Counsel as the Chapter 11 Trustee's barrister in the United Kingdom, effective as of October 18, 2024, to act as barrister under the instruction of Pallas Partners LLP ("Pallas") in connection with the Trustee litigation in the UK courts in connection with the administration proceeding of Hamilton Capital Holdings Limited (the "HCHL Administration") and other litigation matters in the UK.

2. The Chapter 11 Trustee selected Peter Shaw as his barrister based on his expertise in insolvency and commercial litigation in the UK, as well as his extensive experience in complex commercial matters under UK 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) 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].

## **QUALIFICATIONS**

10. Peter Shaw is a highly regarded commercial practitioner in the UK, who was called to the Bar of England and Wales in 1995 and was appointed Queen's Counsel in 2017. He has particular expertise in the fields of corporate and personal insolvency, banking litigation, and company and commercial litigation. He has a wealth of trial experience and considerable expertise in high value insolvency litigation, fraud-related commercial litigation, and shareholder disputes.

### **ANTICIPATED SERVICES**

11. The Chapter 11 Trustee anticipates that Mr. Shaw will serve as his senior barrister in the UK with respect to matters related to, among other things, the HCHL Administration. Due to the specialized nature of the role of a barrister, and the experience of a senior King's Counsel such as Mr. Shaw, there will be no duplication of services arising from his retention, including in connection with Pallas, who serve as the Trustee's solicitors in the UK, and from whom Mr. Shaw will receive instruction, nor with Mr. Paul Wright, who is retained as a more junior barrister, and to whom Mr. Shaw will provide valuable assistance.

## **COMPENSATION OF MR. SHAW**

12. Mr. Shaw intends 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. Mr. Shaw will charge the Debtor for his legal services on an hourly basis at his regularly applicable hourly rates in connection with barrister's services required in the HCHL Administration.

13. At present, Mr. Shaw's 2024 hourly rate for this type of work is GBP 650. Mr. Shaw 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 Mr. Shaw's hourly rates are reasonable, comparable to his hourly rates for other engagements, and within the range of rates charged by comparably skilled professionals who offer the same services.

### **MR. SHAW IS DISINTERESTED**

15. To the best of the Chapter 11 Trustee's knowledge in reliance upon the Shaw Declaration, and except as disclosed therein, Mr. Shaw does 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 Shaw Declaration, and except as disclosed therein, the Chapter 11 Trustee believes that: (a) Mr. Shaw has 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) Mr. Shaw (i) is not a creditor, equity security holder, or insider of the Debtor or his affiliates, (ii) has not been, within two years before the Petition Date, a director, officer, or employee of the Debtor or his affiliates, and (iii) has 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 Mr. Shaw is a "disinterested person" within the meaning of section 101(14) of the Bankruptcy Code, as modified by section 1107(b).

17. Based on the Shaw Declaration, the Chapter 11 Trustee believes that Mr. Shaw does 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 Mr. Shaw as his barrister in the UK with respect to the HCHL Administration 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. 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.

20. The Chapter 11 Trustee requires the services of a senior King's Counsel in connection with, among other things, the HCHL Administration, and the Trustee's efforts to require that the joint administrators of Hamilton Capital Holding Ltd ("HCHL") retain any proceeds of sale in respect of HCHL's property until a final determination of the claim brought by the Trustee before this Court for a declaration that HCHL and its assets are beneficially owned by the Debtor's estate. These efforts require very specialized insolvency and commercial law expertise, and Mr. Shaw is a recognized expert in that field. While Pallas is the law firm acting as the Trustee's solicitors in connection with the HCHL Administration, the Trustee will also require a senior Kings Counsel (in addition to the services of the more junior barrister Mr. Wright) to represent the Trustee before the UK courts in connection with these matters. Mr. Shaw will endeavor to avoid the duplication of efforts and provide services as efficiently as possible.

21. Accordingly, the employment of Mr. Shaw 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.

22. The Chapter 11 Trustee submits that Mr. Shaw's 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.

23. 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." While this Application is filed 38 days after the commencement of services, the Chapter 11 Trustee nevertheless requests authority to retain and employ Mr. Shaw effective October 18, 2024, which was the date that he began providing services to the Chapter 11 Trustee.

### **NOTICE**

24. 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**

25. 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 Mr. Shaw, as his barrister, and order such other and further relief as the Court deems just and proper.

Dated: November 25, 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: | : : | Chapter 11 | | HO WAN KWOK, et al.,1 | : : | Case No. 22-50073 (JAM) | | Debtors. | : : : | (Jointly Administered) | | ------------------------------------------------------x | | |

# **CERTIFICATE OF SERVICE**

The undersigned hereby certifies that on the date hereof, 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: November 25, 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*

Case 22-50073 Doc 3849 Filed 11/25/24 Entered 11/25/24 16:39:24 Page 10 of 33

# **EXHIBIT A**

**Proposed Order**

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

# **[PROPOSED] ORDER (A) GRANTING APPLICATION OF CHAPTER 11 TRUSTEE FOR ENTRY OF ORDER, PURSUANT TO BANKRUPTCY CODE SECTIONS 327 AND 330, BANKRUPTCY RULES 2014 AND 2016, AND LOCAL BANKRUPTCY RULES 2014-1 AND 2016-1, AUTHORIZING AND APPROVING RETENTION AND EMPLOYMENT OF PETER SHAW AS BARRISTER IN UNITED KINGDOM**

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. Peter Shaw, King's Counsel ("Mr. Shaw"), as barrister in the United Kingdom ("UK"), effective as of October 18, 2024, pursuant to sections 327 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 Connecticut (the "Local Bankruptcy Rules"), all as more fully set forth in the Application; and upon consideration of the Application and the Shaw Declaration; and this Court having

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

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 Shaw Declaration, and the record of any hearing on the Application before this Court establish just cause for the relief granted herein, (iii) Mr. Shaw is a "disinterested person," as defined in section 101(14) of the Bankruptcy Code and as required by section 327(a) of the Bankruptcy Code, and (iv) Mr. Shaw does 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 Mr. Shaw as his barrister in the UK effective as of October 18, 2024 on the terms set forth in the Application and the Shaw Declaration.

3. Mr. Shaw is 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 Mr. Shaw's compensation and reimbursement of expenses with respect to the engagement.

5. The allowance of any compensation to be paid to Mr. Shaw 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 Mr. Shaw 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. Mr. Shaw 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 rate he 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 Shaw 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 3849 Filed 11/25/24 Entered 11/25/24 16:39:24 Page 14 of 33

# **EXHIBIT B**

**Shaw Declaration**

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

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

# **DECLARATION OF PETER SHAW IN SUPPORT OF APPLICATION OF CHAPTER 11 TRUSTEE FOR ENTRY OF ORDER, PURSUANT TO BANKRUPTCY CODE SECTIONS 327 AND 330, BANKRUPTCY RULES 2014 AND 2016, AND LOCAL BANKRUPTCY RULES 2014-1 AND 2016-1, AUTHORIZING AND APPROVING RETENTION AND EMPLOYMENT OF PETER SHAW AS BARRISTER IN UNITED KINGDOM**

I, Peter Shaw, being duly sworn, do depose and say:

1. I am a qualified King's Counsel and enrolled before the Bar of England and

Wales as a barrister. I am a barrister at Selborne Chambers, which maintains its principal office

at 10 Essex Street, London, WC2R 3AA, United Kingdom, 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 and 330, Bankruptcy Rules 2014 and 2016, and Local*

*Bankruptcy Rules 2014-1 and 2016-1, Authorizing and Approving Retention and Employment of*

*Peter Shaw as Barrister in United Kingdom* (the "Application")2 in connection with the HCHL

Administration, and related matters (the "Engagement").

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.

2. In relation to the Engagement, my professional client 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, I will seek to recover my fees from the Estate, and I will file fee applications in the Chapter 11 Case.

3. I graduated from Manchester University with a degree in Philosophy and City University, London with a Diploma in Law and was called to the Bar of England and Wales in 1995. I was recommended as a Leading Silk in Insolvency by Chambers and Partners UK Guide to the Bar (2024 Edition). I deal with the fields of corporate and personal insolvency, banking litigation, as well as company and commercial litigation, and have extensive trial experience and considerable expertise in in high value insolvency litigation, fraud-related commercial litigation, and shareholder disputes.

4. I 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. I will charge my hourly billing rates in connection with the Engagement. At present, my 2024 hourly rate is GBP 650. I may also bill the Estate for any out-of-pocket 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, I am a "disinterested person" within the meaning of section 101(14) of title 11 of the United States Code (the "Bankruptcy Code") in that I:

- a. am not a creditor, equity security holder, or insider of the Debtor; - b. am not, and was not within two years before the date of filing of the Debtor's petition, a director, officer, or employee 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 me 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.

I have conducted reasonable checks of the Interested Parties against my records and data, and have determined that to the best of my knowledge and belief, I 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, I 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.

8. While I 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, I 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) I 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) I am not a creditor, equity security holder, or insider of the Debtor or his affiliates, (ii) I have not been, within two years before the Petition Date, a director, officer, or employee of the Debtor or his affiliates, and (iii) I 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 or indirect 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 I am a "disinterested person" 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 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. I 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. I 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 Mr. Shaw 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 a 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: November 25, 2024, at London, United Kingdom

*/s/ Peter Shaw* Peter Shaw

# **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 5IVETECH LIMITED 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. ACASS U.S.A. INC. 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 ALLIANCE BANK OF ARIZONA (A DIVISION OF WESTERN ALLIANCE BANK) 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 ANDREA VOLPE 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 ASCENTIQ SOLUTIONS LIMITED ASSETS SINO LIMITED AUSPICIOUS COAST LIMITED AVIATION E LLP AVIATION TRUST COMPANY LLC AVIVA PLC 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 BESTVIEW1 PTY LTD BINGNAN CUI

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