郭文贵破产案 · ORDER · ECF #3940

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

In re:

HO WAN KWOK, *et al*.,

Debtors.1

Chapter 11

Case No. 22-50073 (JAM)

Jointly Administered

## **B&H FOTO & ELECTRONICS CORP.'S MOTION TO EXCUSE LOCAL COUNSEL FROM ATTENDANCE AT HEARING ON MOTIONS TO DISMISS AND MOTIONS FOR JUDGMENT ON THE PLEADINGS**

B&H Foto & Electronics Corp. hereinafter ("B&H Foto) respectfully moves for an order excusing B&H Foto's undersigned local counsel from attendance at the hearing on the Motions to Dismiss and Motions for Judgment on the Pleadings (the "Motions") scheduled for Wednesday, January 15, 2025, at 10:00 a.m. before Judge Julie A. Manning (the "Hearing"). In support of its request, B&H submits as follows:

1. B&H is a defendant in an avoidance claim adversary proceeding brought by the chapter 11 trustee Luc A. Despins (the "Trustee"). See *Luc A. Despins, Chapter 11 Trustee v. B&H Foto & Electronics Corp. et al.*, Case No. 24-05069 (the "Adversary Proceeding" or "Adv. Proc.").

2. B&H Foto is among the Joint Defendants who filed a Motion (Adv. Proc. ECF No. 035) and joined in the joint memorandum of law in support of, *inter alia*, the Motions filed October 18, 2024 (the "Joint Brief", ECF No. 3713), and the joint reply in further support of, *inter alia*, the Motions (the "Joint Reply", ECF No. 3848). *See also* Trustee's objection to the Motion(s) (ECF

¹ The Debtors 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 the Genever Holdings Corporation is Paul Hastings LLP, 200 Park Avenue, New York, NY 10166 c/o Luc A. Despins, as Trustee for the Estate of Ho Wan Kwok (solely for purposes of notices and communications).

No. 3803; Adv. Proc. ECF No. 37).

3. By *Order Scheduling Hearing on Motions to Dismiss and Motions for Judgment on the Pleadings* entered by the Court (Manning, J.) dated November 27, 2024 (ECF Doc. No. 3857), the Court (Manning, J.) scheduled the Hearing.

4. Attorney Scott M. Kessler represents B&H Foto as lead counsel and this Court admitted him *pro hac vice* as co-counsel for B&H Foto in the Adversary Proceeding on April 25, 2024 (Adv. Proc. ECF No. 17) and in this Main Case on September 30, 2024 (ECF No. 3597). Mr. Kessler will be present in person at the Hearing and will be prepared to represent B&H Foto's interest(s) thereat.

5. B&H Foto makes this request pursuant to Local Bankr. R. 9083-1 and Local R. 83- 1(e)(2) and respectfully requests that this motion be granted.

Dated: January 7, 2025 B&H FOTO & ELECTRONICS CORP.

By: */s/ Tracy Ellis Williams* Tracy Ellis Williams, Esq. (ct25137) Shipman & Goodwin LLP 300 Atlantic Street, 3rd Floor Stamford, CT 06901 Telephone: 203-324-8136 Facsimile: 203-324-8199 tewilliams@goodwin.com

Scott M. Kessler (NY SK5510) (admitted *pro hac vice*) Akerman LLP 1251 Avenue of the Americas, 37th Floor New York, NY 10020 Telephone: 212-880-3800 Facsimile: 212-880-8965 scott.kessler@akerman.com

## **CERTIFICATION**

I hereby certify that on January 7, 2025 a copy of the foregoing was filed electronically and served by mail on anyone unable to accept electronic filing. Notice of this filing will be sent by e-mail to all parties by operation of the Court's electronic filing system or by mail to anyone unable to accept electronic filing. Parties may access this filing through the Court's system.

> By: */s/ Tracy Ellis Williams* Tracy Ellis Williams, Esq.