郭文贵破产案 · ORDER · ECF #3911

元数据

当事人: 郭文贵 (Guo Wengui / Miles Guo / Ho Wan Kwok)
法院: CTB
案号: 22-50073
ECF #: 3911
类型: ORDER
立案日: 2024-12-17

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(e) AND 330, BANKRUPTCY RULES 2014 AND 2016, AND LOCAL BANKRUPTCY RULES 2014-1 AND 2016-1, AUTHORIZING AND APPROVING RETENTION AND EMPLOYMENT OF KOBRE & KIM (GCC) LLP AS SPECIAL COUNSEL IN UNITED ARAB EMIRATES**

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(e) 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 Kobre & Kim (GCC) LLP ("Kobre & Kim"), as special counsel in the United

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).

Arab Emirates (the "UAE"), 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 Paul Hughes in Support of Application of Chapter 11 Trustee for Entry of Order, Pursuant to Bankruptcy Code Sections 327(e) and 330, Bankruptcy Rules 2014 and 2016, and Local Bankruptcy Rules 2014-1 and 2016-1, Authorizing and Approving Retention and Employment of Kobre & Kim (GCC) LLP as Special Counsel in United Arab Emirates* (the "Hughes 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 Kobre & Kim as the Chapter 11 Trustee's special counsel in the UAE, effective as of November 13, 2024, to assist the Trustee in his efforts to recover assets of the Debtor's estate potentially located in the UAE.

2. The Chapter 11 Trustee selected Kobre & Kim as his special counsel based on Kobre & Kim's familiarity with financial investigations, insolvency law, commercial litigation and financial disputes under UAE 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(e) 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].

# **KOBRE & KIM'S QUALIFICATIONS**

10. Kobre & Kim is a law firm that focuses on financial investigations and international disputes. It has offices across the globe, including in Dubai at Office 27-01, Level 27, ICD Brookfield DIFC, Dubai, UAE. Kobre & Kim's areas of expertise include private investigations and suits aimed at combatting fraud, as well as restoring lost revenue and secreted assets, as well as complex restructuring and insolvency litigation and investigations for trustees, creditors, debtors, liquidators, and other investors.

# **ANTICIPATED SERVICES**

11. The Chapter 11 Trustee anticipates that Kobre & Kim will assist him in the investigation of assets and transfers connected to the Debtor that may be located in the UAE.2 Due to the specialized nature of Kobre & Kim's role as special counsel in the UAE, there will be no duplication of services arising from Kobre & Kim's retention.

# **COMPENSATION OF KOBRE & KIM**

12. Kobre & Kim 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. Kobre & Kim will charge the Debtor for its legal services on an hourly basis at its regularly applicable hourly rates in connection with the services required in the UAE.

13. At present, the 2024 hourly rate of Kobre & Kim are \$950 to \$1,875 for lawyers,3 and \$450 to \$875 for paraprofessionals. Kobre & Kim 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 Kobre & Kim's hourly rates are reasonable, comparable to Kobre & Kim's hourly rates for other engagements, and within the range of rates charged by comparably skilled professionals who offer the same services.

2 In the interest of maintain confidentiality regarding the ongoing investigation, the Trustee will not disclose the exact funds and assets believed to be located in the UAE.

3 Certain of Kobre & Kim's lawyers charge up to \$2,750 per hour for highly specialized work. However, based on the scope of services currently envisaged, the Trustee does not presently expect such specialized work to be necessary. The Trustee reserves the right to engage Kobre & Kim lawyers with hourly rates of up to \$2,750 as may be necessary in connection with specialized legal or investigatory work in the UAE, but will seek separate court approval if that may become necessary.

# **KOBRE & KIM IS DISINTERESTED**

15. To the best of the Chapter 11 Trustee's knowledge in reliance upon the Hughes Declaration, and except as disclosed therein, Kobre & Kim 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 Hughes Declaration, and except as disclosed therein, the Chapter 11 Trustee believes that: (a) Kobre & Kim 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) Kobre & Kim and its employees (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 Kobre & Kim 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 Hughes Declaration, the Chapter 11 Trustee believes that Kobre & Kim 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 Kobre & Kim as his special counsel in the UAE pursuant to section 327(e) of the Bankruptcy Code, which provides that the

debtor in possession "may employ, for a specified special purpose, other than to represent the [debtor] in conducting the case, an attorney that has represented the debtor, if in the best interest of the estate, and if such attorney does not represent or hold any interest adverse to the debtor or to the estate with respect to the matter on which such attorney is to be employed." 11 U.S.C.

§ 327(e)

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 special counsel in the UAE to exercise his responsibilities. Kobre & Kim will endeavor to avoid the duplication of efforts and provide services as efficiently as possible.

21. Accordingly, the employment of Kobre & Kim as the Chapter 11 Trustee's special counsel, 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 Kobre & Kim'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." As noted, the Chapter 11 Trustee requests authority to retain and employ Kobre & Kim effective November 13, 2024, which was the date that Kobre & Kim began

providing services to the Chapter 11 Trustee. While that date is 34 days from the date of filing of this Application, the Chapter 11 Trustee nevertheless requests that the retention be effective as of November 13, 2024.

# **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 Kobre & Kim as special counsel in the UAE, and order such other and further relief as the Court deems just and proper.

Dated: December 17, 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: December 17, 2024 New York, New York

By: */s/ G. Alexander Bongartz* G. Alexander Bongartz (*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 3911 Filed 12/17/24 Entered 12/17/24 17:48:49 Page 10 of 53

# **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(e) AND 330, BANKRUPTCY RULES 2014 AND 2016, AND LOCAL BANKRUPTCY RULES 2014-1 AND 2016-1, AUTHORIZING AND APPROVING RETENTION AND EMPLOYMENT OF KOBRE & KIM (GCC) LLP AS SPECIAL COUNSEL IN UNITED ARAB EMIRATES**

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 Kobre & Kim (GCC) LLP ("Kobre & Kim"), as special counsel in the United Arab Emirates (the "UAE"), effective as of November 13, 2024, pursuant to sections 327(e) 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 Hughes

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 Hughes Declaration.

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 Hughes Declaration, and the record of any hearing on the Application before this Court establish just cause for the relief granted herein, (iii) Kobre & Kim is a "disinterested person," as defined in section 101(14) of the Bankruptcy Code, and (iv) Kobre & Kim 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 Kobre & Kim as his special counsel in the UAE pursuant to sections 327(e) and 330 of the Bankruptcy Code, effective as of November 13, 2024 on the terms set forth in the Application and the Hughes Declaration.

3. Kobre & Kim is authorized to act as the Chapter 11 Trustee's special counsel in the UAE, and to perform those services described in the Application.

4. The Estate shall be responsible for Kobre & Kim's compensation and reimbursement of expenses with respect to the engagement.

5. The allowance of any compensation to be paid to Kobre & Kim 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. To the extent it may become necessary to engage Kobre & Kim lawyers with hourly rates of up to \$2,750 in connection with specialized legal or investigatory work in the UAE, the Trustee shall seek separate court approval upon notice and a hearing.

7. Allowance of any compensation for Kobre & Kim shall be limited to the extent of services actually performed, and expenses actually incurred, as special counsel 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 an counsel.

8. Kobre & Kim shall be entitled to indemnification to the extent required under the terms of the Engagement Letter, as modified pursuant to this Order; *provided*, *however*, that any request for indemnification by Kobre & Kim shall be subject to review by the Court as set forth herein to ensure that payment of such indemnity conforms to the terms of the Engagement Letter, as modified pursuant to this Order, and is reasonable under the circumstances of the litigation or settlement in respect of which indemnity is sought; *provided*, further, that in no event shall Kobre & Kim be indemnified in the case of its own bad-faith, self-dealing, breach of fiduciary duty (if any), gross negligence, willful misconduct, or violation of the non-disclosure agreement.

9. If, before the earlier of (i) the entry of an order confirming a chapter 11 plan in these chapter 11 cases (that order having become a final order no longer subject to appeal), or

(ii) the entry of an order closing these chapter 11 cases, Kobre & Kim believes that it is entitled to the payment of any amounts by the Trustee on account of the his indemnification obligations under the Engagement Letter, as modified pursuant to this Order, Kobre & Kim must file an application therefor in the Court, and the Trustee may not pay any such amounts to Kobre & Kim before the entry of an order by this Court approving the payment. With respect to any amounts sought by Kobre & Kim as reimbursement for attorneys' fees and expenses in connection with the payment of an indemnity claim pursuant to the Engagement Letter, as modified by this Order, the invoices and supporting time records for the attorneys' fees and expenses shall be included in Kobre & Kim's application to the Court and these invoices and time records shall be subject to the Amended Guidelines and the approval of the Bankruptcy Court pursuant to sections 330 and 331 of the Bankruptcy Code without regard to whether such attorneys have been retained under section 327 of the Bankruptcy Code, and without regard to whether such attorneys' services satisfy section 330(a)(3)(C) of the Bankruptcy Code. This paragraph is intended only to specify the period of time under which the Court shall have jurisdiction over any request for fees and expenses by Kobre & Kim for indemnification, contribution, or reimbursement, and not a provision limiting the duration of the obligation to indemnify Kobre & Kim. All parties in interest shall retain the right to object to any demand by Kobre & Kim for indemnification, contribution, or reimbursement.

10. Kobre & Kim shall not be entitled to reimbursement by the Trustee for any fees, disbursements and other charges of Kobre & Kim's counsel other than those incurred in connection with a request of Kobre & Kim for payment of indemnity approved by the Court.

11. Kobre & Kim 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 it charges are implemented and shall file such notice with the Court.

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

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

14. To the extent the Application and Hughes Declaration are inconsistent with this Order, the terms of this Order shall govern.

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

16. 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 3911 Filed 12/17/24 Entered 12/17/24 17:48:49 Page 16 of 53

# **EXHIBIT B**

**Engagement Letter**

# KOBRE & KIM

وبري وكيم

office 27-01, Level 27 IGD BROOKFIELD DIFC P.O. Box 506778, Dubai, UAE www.kobrekim.com | Tel +971 4 454 3900

### STRICTLY CONFIDENTIAL

13 November 2024

### BY EMAIL ONLY

Luc Despins lucdespins@paulhastings.com

### Re: Ho Wan Kwok Asset Recovery

Dear Mr. Despins:

Thank you for choosing Kobre & Kim (GCC) LLP ("Kobre & Kim", "we", "us" or "our") to represent and advise you in your capacity as a Chapter 11 Trustee in In re Ho Wan Kwok, 22-50073 (D. Conn.) ("Client", "you" or "your") in connection with the matter described below. This letter, together with the attached Standard Terms of Engagement, sets out the terms and conditions upon which it is agreed we will undertake this engagement (the "Agreement").

#### 1. Engagement

Client engages Kobre & Kim (the "Engagement") to undertake the following projects ':

- · Assess information and documents provided to us by you in relation to the Bankruptcy and related legal proceedings and devise a UAE-focused strategy for monetizing assets for the benefit of the Bankruptcy Estate, involving enforcement actions and civil litigation (including Bankruptcy actions) against companies and/or individuals related to Ho Wan Kwok to be pursued in the UAE onshore courts and/or the DIFC/ADGM Courts. - · Present the above to you via a videoconference on a mutually convenient date near the end of the 30-day period following the commencement of our Engagement. This will include a PowerPoint presentation on deliverables. timetables and budget for the possible options, as well as the probability of achieving the objectives.

1 As we are not qualified to practise mainland UAE law, certain tasks stated in this letter may need to be performed, and certain advice provided, by lawvers who are qualified in UAE law.

AMERICAS (NEW YORK, DELAWARE, MIAMI, SAN FRANCISCO, SÃO PAULO, WASHINGTON DC) APAC (HONG KONG, SEOUL, SHANGHAI), CARIBREAN (BVI, CAYMN ISLANDS), EMEA (CYPRUS, DUBAI, LONDON, TEL AVIV

Kobre & Kim referred to herein is a reference to Korre & Kim (GCC) LLP, a limited liability partnership licensed in the Dubal INTERNATIONAL FINANCIAL CENTRE (COMMERCAL LICENSE NUMBER 5106) AND REGISTERED WITH THE DUBAL FINANCIAL SERVICES AUTHORITY (Reference Number Foo6880).

شركة كوري والد كبر الشار البياني بالرغان مي شركة مي تركة كوري والا كم ردم ولكا ذات سوزياة مدينة لن دركز دبي المالي العالمي (بورجي الترجم التجاري ركم 106) و

Page 2 Luc Despins 13 November 2024

> · Execute on an agreed-upon UAE-focused strategy (with the exact scope and fee estimate to be determined once we have assessed the information and documents provided).

(the "Covered Services")

Kobre & Kim is not being retained for any other purpose.

Paul Hughes will be the partner primarily responsible for the representation of Client, assisted by other lawyers, analysts and/or litigation assistants in the DIFC or in other offices of affiliates of Kobre & Kim as may be necessary or advisable under the circumstances.

Client has agreed that we may act and rely upon instructions from any of the following persons and/or entities as if such instructions had been given by Client: Nicholas Bassett.

Our Engagement will begin from our receipt of your countersignature on this letter; provided, however, that our Engagement is subject to approval thereof by the United States Bankruptcy Court for the District of Connecticut (the "Bankruptcy Court").

The Engagement will automatically terminate and will be closed if a period of six months elapses without any invoicing, with the date of termination falling on the last day of the month containing a time entry invoiced for payment. No final invoice will be issued as the last invoice received by you will serve as the final invoice.

Notwithstanding anything herein or the Standard Terms and Conditions (including Section 4 thereof) to the contrary, we agree not to take on engagements that would render Kobre & Kim no longer disinterested under section 327(e) of Title United States Code (the "Bankruptcy Code").

### 2. Fees

We strive to be transparent in our billing and we will generally seek to agree budgets for our work. These budgets may be amended during the course of the Engagement to reflect changes in scope and assumptions, and we may include for your consideration proposals for fixed-fee or alternative-fee options as alternatives to hourly billing.

You agree that fees charged within budgeted amounts are deemed reasonable and approved.

Our fees for this Engagement will be based upon the hourly billing rates assigned to the individuals performing the services. Our lawyers currently charge US \$950 to US \$1,8752 per hour. Our non-lawyer professionals (e.g., Analysts and Litigation Assistants) charge US \$450 to US \$875 per hour. Up to eight hours per day of travel time may be charged per timekeeper.

2 Certain of our lawyers charge up to US \$2,750 per hour for highly specialized work. However, based on the scope of services currently envisaged, we do not presently expect such work to be necessary. We note that future services requested by the Client might require the same and will endeavor to communicate about budgets and rates throughout our engagement.

Page 3 Luc Despins 13 November 2024

For additional clarity, our hourly rates are as follows:

| Hourly rates in USD | Kobre & Kim 2024 Standard Hourly Rates | |---------------------------|----------------------------------------------| | Founding Partner | 2,750 | | Partner | 1 875 | | Special Counsel | 1.450 | | Principal / Of Counsel | 1.300 | | Associate | 1.050 | | Attorney | 9511 | | Specialist | 875 | | Analyst | 285 | | Litigation Assistant | 450 |

The billing rates of our lawyers are adjusted periodically, and we will inform you of any changes in our periodic invoices.

You agree that all fees and expenses invoiced within pre-submitted budgets are reasonable. All legal fees are earned and due when the work is undertaken, and expenses are to be reimbursed as incurred by us.

Notwithstanding anything herein or the Standard Terms and Conditions (including Sections 7 and 12 thereof) to the contrary, (a) payment of any fees and expenses in connection with this Engagement shall be made in such amounts as may be allowed by the Bankruptcy Court on proper applications in accordance with the procedures set forth in section 330 and 331 of the Bankruptcy Code and the procedures established and required by the Bankruptcy Court and (b) all matters related to the payment and allowance of fees and expenses in connection with this Engagement shall be decided by the Bankruptcy Court. For the avoidance of doubt, neither Mr. Despins, in his personal capacity, nor Paul Hasting LLP shall be liable for compensation for services rendered or reimbursement of expenses.

Page 4 Luc Despins 13 November 2024

### 3. Disbursements

### (a) Ordinary Disbursements

Each invoice will include an itemized schedule of routine disbursements (such as fees for legal research services, telecommunications, non-bulk photocopying, and out-of-hours work expenses). Please note that all extraordinary disbursements (such as outside counsel's fees, expert witness fees, court filing fees, large printing or photocopying jobs, court reporter fees, special database usage, and travel expenses) will be invoiced separately.

### (b) Extraordinary Disbursements

If the need for trial arises then the cost of trial logistics coordination services, including any provided by Kobre & Kim personnel, will be added to our invoices. For the avoidance of doubt, the fees of any outside experts are separate and apart from the fee arrangements contained herein. In addition, Client is responsible for costs associated with foreign exchange, as well as fees incurred in connection with arbitrations.

### Litigation - Recovery of Costs

Certain Courts (such as the DIFC or ADGM Courts) may make orders regarding the payment of the legal fees and expenses in connection with litigation. Usually, the losing party will be required to pay a proportion of the successful party's legal fees, in addition to its own costs, Costs orders do not usually allow a party to recover all its costs but as a matter of prudence, you may wish to make a reserve to provide for a potential scenario in which the court rules against you and you must pay the other side's legal costs. In any event, Client shall be personally responsible for payment of our legal fees and expenses in full regardless of any order for costs made against the opponent. Further, the Dubai Court does not ordinarily permit the recovery of legal fees other than a very limited amount.

### 4. Tax

All amounts in this Agreement are stated to be exclusive of VAT. sales and use tax, gross receipts tax, withholding tax, and any similar tax, imposed on or in connection with the services provided and the payor is responsible for the payment of such taxes.

### 5. Standard Terms and Conditions

The Standard Terms of Engagement set forth in the attached Appendix are incorporated herein and form an integral part of this Agreement. To the extent that there is any inconsistency between the terms of this letter and the Standard Terms, this letter shall prevail. In addition, this Agreement, including the Standard Terms, will prevail over any Client outside counsel or billing guidelines unless otherwise agreed to in writing by Kobre & Kim.

Page 5 Luc Despins 13 November 2024

### 6. Governing Law

This Agreement and all matters arising out of or in connection with it are governed by, and shall be construed in accordance with, the laws of the Dubai International Financial Centre.

Please sign below to acknowledge your acceptance of this letter and return the same to us. We look forward to working with you.

Very truly yours,

KOBRE & KIM (GCC) LLP

We hereby agree to and accept the terms and conditions set out in this letter and enclosed Standard Terms of Business.

Signature:

ામ

Name: Luc Despins, as Chapter 11 Trustee

ત્ત્વ

Title: Chapter 11 Trustee for the Estate of Ho Wan Kwok

Date: November 13, 2024

Page 6 Luc Despins 13 November 2024

### KOBRE & KIM (GCC) LLP

### APPENDIX - STANDARD TERMS OF ENGAGEMENT

The following terms apply to the Engagement. To the extent that the Engagement in this Agreement is for multiple "Clients", then all references to "Client" below shall be replaced with "Clients."

#### 1. Client and Engagement Scope

The Client is contracting with Kobre & Kim (GCC) LLP ("Kobre & Kim"), a Limited Liability Patnership licensed in the Dubai International Financial Centre (Commercial License Number 5106) and registered with the Dubai Financial Services Authority (Reference Number F006880).

Our client in this matter is solely the Client identified in the first paragraph of the Agreement. We do not represent, and do not have a lawyer-client relationship with, any of Client's current or future parents, subsidiaries, shareholders, members, partners, employees, directors, venturers, or other affiliates or constituents, solely on account of our representation of Client in this Engagement.

The Engagement scope is limited to the role described in section 1(a) of the Agreement, and Kobre & Kim is not acting in any other capacity or role for the Client or for any other party. In addition, Kobre & Kim being listed as counsel of record on a particular court case does not mean we generally represent the Client on matters relating to the subject matter of the case.

Unless specifically requested, Kobre & Kim is not advising on the running of limitations periods.

Client acknowledges that this Engagement will not commence until we have obtained all relevant legal permissions, if any, to represent the Client, except to the extent we have been engaged to prepare and file such application(s).

#### 2. Nature of Onr Advice

During this engagement, we may express opinions or beliefs to you about the effectiveness of various courses of action or about the results that might be anticipated. Such statements are expressions of opinion only and should not be considered as promises or guaranties. In addition, Kobre & Kim will only be addressing specific legal questions based on facts presented, which should not be understood as recommending whether an act should or should not be undertaken. Any opinions expressed by Kobre & Kim concerning out-of-scope matters that may arise during this Engagement do not constitute independent legal advice regarding those out-of-scope matters. You should not rely on our advice and should consult other counsel concerning these matters. By signing this Agreement, you acknowledge that you have had an opportunity to consult with other counsel,

#### 3. Know-Your-Client Diligence

Kobre & Kim may request evident's identity or beneficial ownership in accordance our legal obligations and internal policies. In addition, we may request documentation to enable us to establish the source of funds to be remitted to us. This is especially important for us to determine that funds are not subject to confiscation/forfeiture in any creditor-debtor dispute, or asset confiscation/forfeiture-type proceedings.

Client agrees to respond to such requests in good faith and promptly provide all requested documents. Client will also provide information we may request to assist us in applying for special licenses or filing reports with relevant regulatory authority, if necessary.

Client acknowledges that, in some situations, we may be required by law to disclose to the relevant authorities any suspicion of money laundering or terrorist financing.

#### 4. Conflicts of Interest

To allow us to conduct conflicts checks, you represent to us that you have identified to us all persons and entities that are or may become involved in the matter, including all such persons or entities that are affiliated with you.

Page 7 Luc Despins 13 November 2024

You will promptly notify us of any conflict or potential conflict of interest between Jointly Represented Clients or a change of circumstances effecting such a conflict.

Without your consent, we will not represent any other party in a manner that would create an ethical conflict of interest under applicable professional rules. You will have our loyalty with respect to this Engagement.

Kobre & Kim represents many other clients, and some of these other clients may be your direct competitors or otherwise may have interests that are contrary to your commercial interests. By signing this Agreement, you agree that we may act for such other clients, and we may act on may have a commercial interest. This of course does not enable us to actin a situation with an actual ethical conflict of interest under applicable professional rules.

It is possible that during the time we represent you, some of our current or future clients may ask us to represent them in matters in which you are involved as another party. Both our own prudent business conduct, and the interests of our other clients, call for us to seek to retain the ability to take on such matters for all of our clients. Accordingly, by entering into this Agreement you consent in advance, on your behalf of your affiliates, to our current representation or acceptance of future matters (including litigation matters) adverse to Client or any of its affiliates, and not to assert a conflict of interest, or to seek preclude, challenge or otherwise disqualify Kobre & Kim from such matters, provided that those matters are not substantially related to the work we are doing for you.

Thus, for example, you agree that we would be able to take a new lawsuit or transactional matter for one of our current or future clients that is adverse to Client so long as the adverse matter is not substantially related to the work we are doing for you. This consent also includes being adverse to your interests in any bankruptcy, regulatory, administrative, legislative, or rulemaking proceeding.

In addition, by entering into this Agreement you agree that if we represent you in a matter across from another person or entity, we may represent such other person or entity on matters not substantially related to our work for vou.

You should feel completely free to consult other counsel concerning these matters. By signing the Agreement, you acknowledge that you have had an opportunity to consult with other counsel.

#### ડ. Hourly Rates

Our fees for this Engagement will be based upon the hourly billing rates assigned to the individuals performing the services. Our lawyers who we currently expect may work on this matter charge US \$ 950 to US \$1,875 per hour. Our non-lawyer professionals charge US \$450 to US \$875 per hour. Up to eight hours per day of travel time may be charged.

#### 6. Disbursements and Subject Matter Experts

Although we may at times coordinate payments from funds held for Client to third parties who provide services in relation to this Engagement, Client acknowledges that it is within Kobre & Kim's discretion to make such payments and agrees to reimburse and indemnify us relating to any such payments made. Unless otherwise agreed in writing, Client is ultimately responsible for any and all payments to third parties, including vendors or legal services providers.

In addition to any pre-approved timekeepers, Client agrees that Kobre & Kim may assign work to and bill Client for ex. E-Discovery experts, IT experts, Executive Assistants, Legal Analysts, Office Managers, court procedures and filing assistants, which are often most cost-effective and efficient for providing unique value and expertise related to case needs.

#### 7. Terms of Payment

The Client is obligated to pay our fees and other charges, even where we have agreed to accept payment through a third party.

Page 8 Luc Despins 13 November 2024

Our invoices specify the date that payment is due. We reserve the right to charge interest on overdue amounts at a rate of up to 10% per annum until the overdue amount is paid.

All questions regarding our invoices will be raised at the time of receipt, when we are best placed to clarify the nature of work being done. We will continue to consider the invoice unimpaired in all other respects, including applicable payment terms.

In any case where we are required actively to pursue collection of amounts outstanding beyond agreed payment terms, Client agrees to indemnify us against all costs and expenses that we incur in pursuing such collection, including fees or costs of outside counsel, and of any court or arbitrator.

All amounts in this Agreement are stated to be exclusive of VAT, sales and use tax, gross receipts tax, withholding tax, and any similar tax, imposed on or in connection with the services provided and the Client is responsible for the payment of such taxes.

Payment must be made by wire transfer or EFT to the coordinates on our invoices. All amounts due to us will be paid in United States dollars or Emirati Dirham (as indicted in the Agreement), unless otherwise directed by us.

#### 8. Termination and Automatic Termination

Client or Kobre & Kim may terminate this Engagement at any reason by written notice, subject on our part to applicable rules of professional responsibility.

By signing the Agreement Client agrees that we may withdraw from representing Client in this matter, at our sole discretion. Without limitation, the reasons for withdrawal include any required on account payment not being funded in accordance with the terns of the Agreement, Client breaches any of its obligations under the Agreement, or if Client fails to coperate in our efforts to represent Client's interests. Client further agrees to indemnify Kobre & Kim against all fees and expenses in withdrawing from the representation, including in preparing and appearing on any application to withdraw as Client's counsel of record in any proceeding before a court or other tribunal.

Unless previously terminated, this Engagement will terminate upon the earlier of our sending Client our final statement for services rendered, or the conclusion the agreed services under the Agreement, as applicable.

Upon termination, Kobre & Kim has no continuing obligation to advise the Client on the Engagement or on future factual or legal developments regarding the Engagement, unless required by applicable law, rules or court order.

#### の Survivability

Subject to the limitations and other provisions of the Agreement and these Standard Terms of Engagement, or unless otherwise agreed, the sections of the Agreement pertaining to Fees, Disbursements, Governing Law, and the representations and warranties of the Client and Kobre & Kim contained in these Standard Terms of Engagement will survive the Termination or Automatic Termination of the Agreement.

### 10. Client File and Record Retention Policy

In the course of the Engagement, we will maintain a client file in which we may place materials relevant to the matter. Items in this file may be your property and, upon completion of the Engagement, these items will be available to be taken by you. We will be entitled to make copies if we choose. After conclusion of the Engagement, we will store the client file for seven years. If you do not take possession of the items in the client file during this seven-year storage period, we may dispose of the file. Documents containing our attorney work product, internal communications, mental impressions or notes and draft documents will remain our property and are not part of the client file. In addition, electronic documents such as email and documents prepared on our word-processing system (excluding printed copies), and databases remain our property and are not part of the client file. We may

Page 9 Luc Despins 13 November 2024

implement and enact reasonable retention policies for these electronic documents, and we have discretion to delete them.

#### 11. Indemnity

Client will indemnify and hold harmless Kobre & Kim and its partners, affiliates, principals, associates and employees (collectively, the "Indemnified Persons") from and against any claims, damages, liabilities, losses or costs, from third parties, arising from, or relating to this Engagement, and will advance and reimburse each Indemnified Person for all expenses (including fees and expenses of counsel) as they are incurred in connection with investigating, preparing, or defending any action, claim, suit, investigation or proceeding arising from or related to the Engagement, whether pending or threatened and whether or not any Indemnified Person is a party.

#### Arbitration 12.

Any dispute arising out of or in connect including any question regarding its existence, validity or termination, shall be referred to and finally resolved by arbitration under the LCIA Rules, which Rules are deemed to be incorporated by reference into this clause. The number of arbitrators shall be one. The seat of arbitration shall be the Dubai International Financial Centre, and the venue shall be the Dubai International Financial Centre. The language to be used in the arbitration shall be English.

#### 13. Limitations on Claims

You agree that any and all claims by you arising with respect to or relating to this Engagement must be commenced within one year following the date on which the Engagement is terminated.

Kobre & Kim will not be liable for consequential, special, indirect, incidental, punitive or exemplary damages, costs, expenses, or losses (including lost profits or opportunity costs).

Our liability for loss or damage attributable to our negligence, breach of contract, misrepresentation or otherwise (but not in respect of fraud, fraudulent misrepresentation, death or personal injury) shall not exceed US\$5,000,000 per single originating cause.

A limitation of liability provision in these terms shall apply to each and every subsequent transaction or work we carry out for Client unless we agree otherwise. Where the Agreement is addressed to more than one client, the above limit of liability applies to the aggregate of all such clients and not separately to each client.

#### 14. Internal Attorney-Client Privilege

Please be aware that Kobre & Kim has internal counsel that may advise our lawyers regarding their ethical, professional and legal duties. You acknowledge that any such consultation is protected by our own lawyer-client privilege, and you waive any right to discovery of those communications. Should circumstances arise in which Kobre & Kim faces a conflict of interest with respect to or by virtue of these communications, you agree to waive that conflict. You also agree that such communications are property of the firm and are not part of the client file.

#### 15. Confidentiality

We will not disclose any confidential information of yours to any other client (not jointly represented with you), even where that information might have some bearing on their interests. Likewise, we will not disclose to you the confidences of any other cliently represented with you), even where that information might have some bearing on your interests, and you agree that we are under no obligation to do so.

The terms of this Agreement are confidential and will not, except as required by iaw, be disclosed by Client or us to any third party without the consent of the other. Where the fact of our representation of Client is a matter of public record, we agree that Client or Kobre & Kim shall be permitted to inform third parties of the representation.

Page 10 Luc Despins 13 November 2024

We reserve the right to disclose your files to: (a) regulatory bodies in the exercise of their powers to meet legal and regulatory compliance requirements; (b) our auditors; (c) our professional indemnity insurers/underwriters and to provide information to our insurance brokers in relation to these communications with insurers/underwriters; (d) law firms and other third party professionals as required to enable us to enforce our rights, or to advise us on our commercial, regulatory or legal position, in connection with the Engagement.

Client acknowledges that, under certain limited circumstances, we may be obliged to disclose information that the Client provides to us, including in connection with banks' due diligence on payments to or from us.

#### 16. Data Privacy

Kobre & Kim will take steps to ensure that any personal data transferred in accordance with our privacy policy. This privacy policy was last reviewed and updated January 15, 2024 and can be accessed at this URL: http

#### 17. Severability

If any term or provision of the Agreement is determined to be invalid, illegal, or unenforceable in any jurisdiction, such determination shall not affect any other term or provision of the Agreement or invalidate or render unenforceable such term or provision in any other jurisdiction.

Case 22-50073 Doc 3911 Filed 12/17/24 Entered 12/17/24 17:48:49 Page 27 of 53

# **EXHIBIT C**

**Hughes 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 PAUL HUGHES IN SUPPORT OF APPLICATION OF CHAPTER 11 TRUSTEE FOR ENTRY OF ORDER, PURSUANT TO BANKRUPTCY CODE SECTIONS 327(e) AND 330, BANKRUPTCY RULES 2014 AND 2016, AND LOCAL BANKRUPTCY RULES 2014-1 AND 2016-1, AUTHORIZING AND APPROVING RETENTION AND EMPLOYMENT OF KOBRE & KIM (GCC) LLP AS SPECIAL COUNSEL IN UNITED ARAB EMIRATES**

I, Paul Hughes, being duly sworn, do depose and say:

1. I am lawyer and have been practicing law in the United Arab Emirate (the "UAE") for over twelve years. I am a partner at Kobre & Kim (GCC) LLP ("Kobre & Kim"), which focuses on financial investigations and international disputes, and maintains an office at at Office 27-01, Level 27, ICD Brookfield DIFC, Dubai, UAE, Kobre & Kim's majority owner is global law firm, Kobre & Kim LLP (registered in New York, U.S.A)., 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(e) and 330, Bankruptcy Rules 2014 and 2016, and Local Bankruptcy Rules 2014-1 and 2016-1, Authorizing and Approving Retention and Employment 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).

*Kobre & Kim (GCC) LLP as Special Counsel in United Arab Emirates* (the "Application")[2](#page-28-0) in connection with Kobre & Kim's retention as special counsel in the UAE , to assist the Trustee in his efforts to recover assets of Ho Wan Kwok's (the "Debtor") estate potentially located in the UAE (the "Engagement").

2. In relation to the Engagement, Kobre & Kim's professional client is the estate (the "Estate") of the Debtor in his above-captioned chapter 11 case (the "Chapter 11 Case"). In relation to the Engagement, Kobre & Kim will seek to recover its fees from the Estate, and I will file fee applications in the Chapter 11 Case on Kobre & Kim's behalf.

3. I studied at the University of Leeds where I received a Bachelor of Arts degree in 2001 , and I studied law at the College of Law (Chester), where I received a Graduate Diploma in Law in 2002. I qualified as a Solicitor in England & Wales in 2009. I am a leading practitioner in the Dubai International Financial Centre (DIFC), Abu Dhabi Global Market (ADGM) and English Courts, and have further extensive experience in fraud investigations, contentious shareholder disputes, and banking litigation. I also regularly engage in private client disputes for UHNWIs and has served as litigation counsel in high-value multi-jurisdictional bankruptcy matters.

4. Kobre & Kim 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.

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

5. Kobre & Kim will charge our hourly billing rates in connection with the Engagement. At present, the the 2024 hourly rate of Kobre & Kim are \$950 to \$1,875[3](#page-29-0) for lawyers, and \$450 to \$875 for paraprofessionals. Kobre & Kim 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, Kobre & Kim is a "disinterested person" within the meaning of section 101(14) of title 11 of the United States Code (the "Bankruptcy Code") in that Kobre & Kim and its employees:

- a. are not creditors, equity security holders, or insiders of the Debtor; - 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 Kobre & Kim before my signing this Declaration that I am informed includes:

3 Certain of Kobre & Kim's lawyers charge up to \$2,750 per hour for highly specialized work. However, based on the scope of services currently envisaged, the Trustee does not presently expect such specialized work to be necessary. The Trustee reserves the right to engage Kobre & Kim lawyers with hourly rates of up to \$2,750 as may be necessary in connection with specialized legal or investigatory work in the UAE, but will seek separate court approval if that may become necessary.

- a. parties listed as creditors, executory contract counterparties, and co-debtors 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.

Kobre & Kim has conducted reasonable checks of the Interested Parties against our records and data, and has determined that to the best of our knowledge and belief, Kobre & Kim does not have any relationship or connection with the Interested Parties, subject to the following exceptions described in Schedule 2 attached hereto (the "Disclosure Schedule").

8. The Disclosure Schedule has been compiled with the assistance of attorneys and legal professionals at Kobre & Kim who have reviewed conflict records and/or provided additional information regarding relevant matters. The Disclosure Schedule identifies certain Interested Parties (or affiliates thereof) for which Kobre & Kim currently acts as counsel or has acted as counsel during the last three (3) years. It reflects that, to the extent Kobre & Kim currently represents or has previously represented any Interested parties or affiliate thereof, such matters are not related to these Chapter 11 Cases. Further, Kobre & Kim will not represent any Interested Parties in any matter relating to the Chapter 11 Cases or in connection with the Debtors.

9. Pursuant to section 327(c) of the Bankruptcy Code, Kobre & Kim is not disqualified from acting as special counsel merely because it has represented, represents, or may in the future represent certain Interested Parties in matters that are unrelated to the Debtors or these Chapter 11 Cases. As such, I do not believe that Kobre & Kim's representations disclosed on Schedule 2 preclude Kobre & Kim from being a disinterested party under the Bankruptcy Code.

10. While Kobre & Kim have made a diligent effort to ascertain the identity of any connections or potential conflicts with the Interested Parties, Kobre & Kim will undertake to use reasonable efforts to identify such further developments, and if any new relevant facts or relationships are discovered or arise with respect to parties related to this Engagement for which Kobre & Kim has been retained or the Debtors or the Estate, to the extent that any additional information comes to light, Kobre & Kim will review, disclose pursuant to Bankruptcy Rule 2014(a), and resolve any conflict or adverse interests that may appear.

11. Based on the foregoing, insofar as I have been able to ascertain based on the information currently available to me: (a) Kobre & Kim 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) (i) neither Kobre & Kim nor its employees are creditors, equity security holders, or insiders of the Debtor or his affiliates, (ii) neither Kobre & Kim nor its employees have been, within two years before the Petition Date, a director, officer, or employee of the Debtor or his affiliates, and (iii) neither Kobre & Kim nor its employees 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 Kobre & Kim is

a "disinterested person" within the meaning of section 101(14) of the Bankruptcy Code, as modified by section 1107(b).

12. 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.

13. 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 Kobre & Kim 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. Kobre & Kim has 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.

14. Kobre & Kim has 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.

15. 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 Kobre & Kim shall be limited to the extent of services actually performed, and expenses actually incurred, as special counsel 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 attorney.

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 13, 2024, at Dubai, United Arab Emirates

Paul Hughes Partner Kobre & Kim (GCC) LLP

The following schedules contain the names of individuals and entities reviewed for conflicts purposes. Where the names of the entities reviewed were incomplete or ambiguous, the scope of the search was intentionally broad and inclusive in order to match the incomplete or ambiguous name.

# **SCHEDULE 1**

# **Potential Parties-in-Interest List**

*List of Schedules*

# **Schedule Category**

- 1(a) Debtor, Family Members, and Certain Related Entities - 1(b) Bankruptcy Judge and U.S. Trustee Personnel - 1(c) 20 Largest Unsecured Creditors - 1(d) Other Interested Parties

# **SCHEDULE 1(a)**

# **Debtor, Family Members, and Certain Related Entities**

Ho Wan Kwok (a.k.a. Miles Gwok, Miles Guo, and Wengui Guo) Hing Ch Ngok (a.k.a. Yue Qingzhi) Qiang Guo (a.k.a Mileson Guo) Mei Guo (a.k.a Mei Gui) HK International Funds Investments (USA) Limited, LLC Bravo Luck Limited Genever Holdings Corporation Genever Holdings LLC

# **SCHEDULE 1(b)**

### **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

# **SCHEDULE 1(c)**

# **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 (a.k.a. Jonathan Ho Yue Hua Zhu Shi Xiong Xian Wei Ye Huizen Wang

# **SCHEDULE 1(d)**

### **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 S.A. 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 Puerto Rico Bank of America Bank of China – New York Branch 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 Bingshang Jiao Birchstone Capital AG Blackthorn Financen Inc. Blue Capital Blueberry Builders, LLC BNY Mellon, N.A. Boardwalk Motor Imports, LLC Bofang Investment LLC Bohonnon Law Firm Boies Schiller Flexner LLP Bonnie C. Mangan Booming Sail New York LLC Bouillor Holdings Limited Boxun Inc. 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 Callsign Ltd 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 Wai Kwok 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 Yang Chuang Xin Ltd. Chui Kuk Wu Chunfeng Xia Chunguang Han Chunhui Song Ci Chen Cibc Inc. (d.b.a. Cibc) Cimb Bank Berhad (a.k.a. Cimb Islamic Bank Berhad) 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 Clear Treasury (UK Trading) Limited Clear Treasury Limited 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 Credit Agricole CIB Corp. Crocker Mansion Estate LLC Crowell & Moring LLP Crystal Breeze Investments Limited Cui Zhu Li Cummings & Lockwood, LLC

Curiosity Corp. LLC Cyberapt Recruitment Ltd D&D Solutions LLC D.P. Textile & Apparel, Inc. D4zero S.R.L. Daiho Zhou Daniel Podhaskie Daniel S. Alter Danyu Lin Dark Shadows LLC David Fallon Dawn State Limited DBS Bank Ltd. Dean M. Rabideau Dedham Savings 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 DJD Creative 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 Eddy Aquino (a.k.a. Eddy I Sanchez Aquino) 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 Epic It Ltd Epiq Corporate Restructuring, LLC Eric Goldsmith MD, LLC Ernst & Young LLP Evan Cramer Evolve Bank and Trust Faegre Drinker Biddle & Reath LLP Fam United LLC Fan Bingbing Fan Jing Fanggui Zhu Fania Roofing Company Farhad Zabeti Farrant Group Limited Fay Ye Federal Corporation Federal Express Corporation Feibo Jiang 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) Fifth Third Bank, N.A. Finn Dixon & Herling LLP Fiona Yu First Abu Dhabi Bank First Bank (f.k.a. Malvern Bank) First County Bank First Fidelity Bank First Republic Bank

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# **SCHEDULE 2**

# **Disclosure Schedule**

| Matched Entity | Relationship to Debtor | Relationship to K&K | |-----------------------------------------|--------------------------|--------------------------------------------------------------------------------------------------------------------| | UBS AG (London Branch) | Other Interested Parties | Affiliate of current client in unrelated matters | | JPMorgan Chase Bank | Other Interested Parties | Current client (in its capacity of Trustee for certain pension trust funds) in unrelated matters | | East West Bank | Other Interested Parties | Former client in an unrelated matter | | FFP (BVI) Limited | Other Interested Parties | Current client (in its capacity as Court-appointed Liquidator) in an unrelated matter | | JNFX LTD. | Other Interested Parties | Current client in an unrelated matter | | M&T Bank/People's United Bank | Other Interested Parties | Former client in an unrelated matter | | Andrew Childe | Other Interested Parties | Current client (in his capacity as Court-appointed Liquidator) in an unrelated matter | | Deutsche Bank Trust Company America | Other Interested Parties | Affiliate of current client in unrelated matters | | U.S. Bank National Association | Other Interested Parties | Former client in unrelated matters |