--- type: court_doc id: "court_ctb_3946_0" court: "CTB" case_no: "22-50073" doc_number: 3946 doc_type: "ORDER" filed_date: "2024-10-18" lang: "zh" url: "https://mubeitech.com/court/court_ctb_3946_0" json_url: "https://mubeitech.com/api/court/court_ctb_3946_0" --- # UNITED STATES BANKRUPTCY COURT DISTRICT OF CONNECTICUT BRIDGEPORT DIVISION In re: > 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: Chapter 11 HO WAN KWOK, *et al*., Debtors.1 Jointly Administered Case No. 22-50073 (JAM) ## **AMAZON WEB SERVICES, INC. AND AMAZON.COM, INC.'S MOTION TO EXCUSE LOCAL COUNSEL FROM ATTENDANCE AT HEARING ON MOTIONS TO DISMISS AND MOTIONS FOR JUDGMENT ON THE PLEADINGS** Amazon Web Services, Inc. ("AWS") and Amazon.com, Inc. ("Amazon") respectfully move for an order excusing AWS and Amazon'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, AWS and Amazon submit as follows: 1. AWS and Amazon are defendants in avoidance claim adversary proceedings brought by the chapter 11 trustee Luc A. Despins (the "Trustee"). See *Luc A. Despins, Chapter 11 Trustee v. Amazon Web Services, Inc.*, Adv. Proceeding No. 24-05006 (JAM) (the "AWS Adversary Proceeding" or "AWS Adv. Proc."); *Luc A. Despins, Chapter 11 Trustee v. Amazon.com, Inc., et al.,* Adv. Proceeding No. 24-05057 (JAM) (the "Amazon Adversary Proceeding" or "Amazon Adv. Proc."). 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). 2. AWS and Amazon are among the Joint Defendants who filed a Motion (AWS Adv. Proc. ECF No. 021; Amazon Adv. Proc. ECF No. 042) 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 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 Brian T. Peterson represents AWS and Amazon as lead counsel and this Court admitted him *pro hac vice* as counsel in this Main Case on September 18, 2024 (ECF No. 3550). Mr. Peterson will be present in person at the Hearing. AWS and Amazon have been in discussions with other Joint Defendants and pursuant to those discussions, Mr. Peterson tentatively plans on sharing a speaking role at the Hearing and requests that he be permitted to do so without the appearance of local counsel at the Hearing. 5. AWS and Amazon make 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 8, 2025 K&L GATES LLP By: */s/ Lindsay Sampson Bishop* Lindsay Sampson Bishop (ct29990) K&L GATES LLP 1 Congress Street Boston, MA 02114 Tel: (617) 261-3100 Email: lindsay.bishop@klgates.com -and- By: */s/ Brian T. Peterson* Brian T. Peterson (phv208265) Ruby A. Nagamine (phv208290) K&L GATES LLP 925 Fourth Avenue, Suite 2900 Seattle, WA 98104 Tel: (206) 623-7580 Email: brian.peterson@klgates.com ruby.nagamine@klgates.com *Counsel for Amazon Web Services, Inc. and Amazon.com, Inc.* ## **CERTIFICATION** I hereby certify that on this day, 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/Brian T. Peterson* Brian T. Peterson (phv208265) K&L Gates LLP 925 Fourth Avenue, Suite 2900 Seattle, WA 98104 Phone: (206) 623-7580 Fax: (206) 623-7022 E-mail: brian.peterson@klgates.com > > *Counsel for Amazon Web Services, Inc. and Amazon.com, Inc.*