郭文贵破产案 · MOTION · ECF #4007

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

| --------------------------------------------------------------- | x | | |-----------------------------------------------------------------|--------|-------------------------| | In re: | :<br>: | Chapter 11 | | HO WAN KWOK, | :<br>: | Case No. 22-50073 (JAM) | | Debtor. | :<br>: | | | --------------------------------------------------------------- | :<br>x | |

### **CHAPTER 11 TRUSTEE'S MOTION TO APPEAR REMOTELY FOR JANUARY 28, 2025 HEARINGS**

Pursuant to section 105(a) of the Bankruptcy Code and Rule 1001 of the Federal Rules of Bankruptcy Procedure, Luc A. Despins, in his capacity as Chapter 11 Trustee (the "Trustee") appointed in the above-captioned chapter 11 case (the "Chapter 11 Case") of Ho Wan Kwok, respectfully moves (this "Motion") the Court for permission to appear remotely at the January 28, 2025 hearings scheduled in the Chapter 11 Case and the related adversary proceeding: *Luc A. Despins, Chapter 11 Trustee v. ACA Capital Group Ltd.*, et al. (Adv. Proc. No. 24-05249) (the "Adversary Proceeding"). In support of the Motion, the Trustee respectfully states as follows:

- 1. The following matters are scheduled to be heard at 1 p.m. on January 28, 2025, in the Chapter 11 Case and the related Adversary Proceeding: - a. In the Chapter 11 Case, the *First Interim Fee Application of Chryssafinis & Polyviou LLC, as Cypriot Law Counsel* [ECF No. 3930]; and

b. In the Adversary Proceeding, the *Motion to Dismiss Adversary Proceeding* filed by ACA Capital Group Ltd., Celestial Tide Limited, G Fashion (CA), G Fashion Hold Co A Limited, G Fashion Hold Co B Limited, G Fashion International Limited, GF IP, LLC, GF Italy, LLC, GFNY, Inc., GFashion Media Group Inc., Hamilton Capital Holding

Limited, Hamilton Investment Management Limited, Hamilton Opportunity Fund SPC, Himalaya Currency Clearing Pty Ltd., Himalaya International Clearing Limited, Himalaya International Financial Group Limited, Himalaya International Payments Limited, Himalaya International Reserves Limited, William Je, and Major Lead International Limited [Adv. ECF No. 114] and the *Motion to Dismiss Adversary Proceeding* filed by G Club International Limited and G Club Operations LLC [Adv. ECF No. 116] (collectively, the "Motions to Dismiss").

2. The Trustee respectfully requests permission to attend these hearings via Zoom, because he will be out of the country on January 28, 2025.

3. Undersigned counsel as well as Nicholas A. Bassett, counsel to the Trustee, will attend these hearings in person and Attorney Bassett will present argument in opposition to the Motions to Dismiss.

# *[THE REMAINDER OF THIS PAGE IS INTENTIONALLY BLANK.]*

WHEREFORE, the Trustee respectfully requests permission to appear remotely before this

Court on January 28, 2025.

Dated: January 27, 2025 LUC A. DESPINS,

New Haven, Connecticut CHAPTER 11 TRUSTEE

By: */s/ Patrick R. Linsey* Patrick R. Linsey (ct29437) NEUBERT, PEPE & MONTEITH, P.C. 195 Church Street, 13th Floor New Haven, Connecticut 06510 (203) 781-2847 plinsey@npmlaw.com

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

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

# **[PROPOSED] ORDER GRANTING CHAPTER 11 TRUSTEE'S MOTION TO APPEAR REMOTELY FOR JANUARY 28, 2025 HEARINGS**

Upon the motion (the "Motion") of Luc A. Despins, as Chapter 11 Trustee (the "Trustee") appointed in the Chapter 11 Case² of Ho Wan Kwok, for permission to participate remotely at the hearings scheduled for January 28, 2025, at 1 p.m., in the Chapter 11 Case and the related Adversary Proceeding, sufficient notice having been provided, and good cause appearing therefore, it is hereby

- 1. ORDERED that the Motion is granted as set forth herein; and it is further - 2. ORDERED that the Trustee may participate in the hearings scheduled for January

28, 2025, at 1 p.m., via the Court's Zoom.gov platform, by contacting the Clerk's Office for instructions to connect to the ZoomGov remote conference by sending an email to the following court email address: CalendarConnect\_BPT@ctb.uscourts.gov.

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 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 Capitalized terms not defined in this Order adopt the definitions as set forth in the Motion.

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

| ______________________________________x | | | |-----------------------------------------|---|-------------------------| | | : | | | In re: | : | CHAPTER 11 | | | : | | | HO WAN KWOK, | : | CASE NO. 22-50073 (JAM) | | | : | | | Debtor. | : | | | ______________________________________x | | |

#### **CERTIFICATE OF SERVICE**

The undersigned hereby certifies that on the date hereof, the foregoing was filed electronically in the Chapter 11 Case and the Adversary Proceeding, and that notice of this filing will be sent by e-mail to all parties appearing in the Chapter 11 Case and Adversary Proceeding that are eligible to receive electronic notice by operation of the Court's electronic filing system.

Dated: January 27, 2025 LUC A. DESPINS,

New Haven, Connecticut CHAPTER 11 TRUSTEE

By: */s/ Patrick R. Linsey* Patrick R. Linsey (ct29437) NEUBERT, PEPE & MONTEITH, P.C. 195 Church Street, 13th Floor New Haven, Connecticut 06510 (203) 781-2847 plinsey@npmlaw.com