---
type: court_doc
id: "court_ctb_3861_0"
court: "CTB"
case_no: "22-50073"
doc_number: 3861
doc_type: "ORDER"
filed_date: "2024-12-03"
lang: "zh"
url: "https://mubeitech.com/court/court_ctb_3861_0"
json_url: "https://mubeitech.com/api/court/court_ctb_3861_0"
---
# UNITED STATES BANKRUPTCY COURT DISTRICT OF CONNECTICUT BRIDGEPORT DIVISION | In re:<br>HO WAN KWOK, et al.,      | Chapt



> 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 BRIDGEPORT DIVISION**

| In re:<br>HO WAN KWOK, et al.,      | Chapter 11              |
|-------------------------------------|-------------------------|
|                                     | Case No. 22-50073 (JAM) |
| Debtor.                             | (Jointly Administered)  |
|                                     |                         |
| LUC A. DESPINS, Chapter 11 Trustee, | Adv. Proceeding         |
| Plaintiff,                          |                         |
| v.                                  |                         |
| DJD CREATIVE, LLC                   |                         |
| Defendant.                          |                         |

## **DEFENDANT DJD CREATIVE, LLC'S MOTION TO DISMISS COMPLAINT**

As directed by the Order Further Amending Avoidance Action Procedures Order and Scheduling Joint Briefing of Motions to Dismiss and Motions for Judgment on the Pleadings (Case No. 22-50073 (JAM), ECF No. 3577) (the "Kwok Proceeding"), DJD Creative, LLC ("DJD"), by and through its undersigned attorneys, hereby files this Motion to Dismiss Complaint (the "Motion") for the reasons set forth more fully in the Memorandum of Law filed in the Kwok Proceeding substantially contemporaneously herewith. (See ECF No. 3713.)

DJD respectfully requests that the Motion be granted and that all causes of action asserted against it be dismissed with prejudice pursuant to Fed. R. Civ. P. 12(b)(1) and 12(b)(6), made applicable to this adversary proceeding by Fed. R. Bankr. P. 7012, due to Plaintiff's failure to plead facts sufficient to state plausible claims for which relief can be granted and for lack of standing, and for such additional relief as the Court deems appropriate.

Dated: December 3, 2024

Respectfully submitted,

**THE STRONG FIRM P.C.**

/*s/ Zachary W. Doninger\_\_\_\_\_\_\_\_\_\_\_\_\_*

**BRET STRONG** Texas Bar No. 00795671 [bstrong@thestrongfirm.com](mailto:bstrong@thestrongfirm.com) **ZACHARY W. DONINGER** Texas Bar No. 24129542 SDTX Bar No. 3804761 zdoninger@thestrongfirm.com Two Hughes Landing 1790 Hughes Landing, Suite 200 The Woodlands, Texas 77380 Phone: 281.367.1222 Fax: 281.210.1361

**ATTORNEYS FOR DEFENDANT DJD CREATIVE, LLC**

## **CERTIFICATION**

I hereby certify that on December 3, 2024, a copy of the foregoing was electronically filed with the Clerk of Court using the CM/ECF system. Notice of this filing will be sent by e-mail to all parties by operation of the Court's electronic filing system. Parties may access this filing through the Court's system.

> */s/Zachary W. Doninger*\_\_\_\_\_\_\_\_\_\_\_\_\_\_ Zachary W. Doninger