郭文贵破产案 · ORDER · ECF #4148

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

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

# **COVERSHEET FOR FOURTH INTERIM FEE APPLICATION OF O'SULLIVAN MCCORMACK JENSEN & BLISS PC**

| Interim Application of: | | O'Sullivan McCormack Jensen & Bliss PC | | | | | |-------------------------------------------------------------|---------------|----------------------------------------|-----------------------------------------------------------------------|--|----------------|--| | Time Period:<br>September 1, 2024 through December 31, 2024 | | | | | | | | Bankruptcy Petition Filed: | | | February 15, 2022 | | | | | Date of Entry of Retention Order: | | | August 22, 2023 [Docket No. 2241] (effective as of July<br>27, 2023). | | | | | Amount Requested | | | Reductions | | | | | Fees: | \$35,485.00 | | Voluntary Fee Reductions:<br>none | | | | | Expenses: | \$2,421.66 | | Voluntary Expenses Reductions:<br>none | | | | | Total: | \$37,906.66 | | | | | | | Fees Previously Requested: | | | Retainer Request: | | | | | Requested Fees: | \$227,919.90 | | None | | | | | Awarded Fees: | \$227,919.90 | | | | | | | Paid Fees: | \$227,919.902 | | | | | | | Expenses Previously Requested: | | | Expense Detail: | | | | | Requested Expenses: | \$7,870.69 | | Retainer Received: | | Not applicable | | | Awarded Expenses: | \$7,870.69 | | Copies per page cost & total: Not applicable | | | | | Paid Expenses: | \$7,870.69 | | | | | |

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 As detailed below, with respect to the Application Period, an additional \$28,388.00 in fees and \$2,421.66 in expenses were paid in accordance with the Interim Compensation Order (as defined below) and OMJB's monthly fee statements.

| Monthly | Total Fees | Requested | Requested | Fees Paid | Expenses | 20% Fee | |-----------|-------------|-------------|------------|-------------|------------|------------| | Period | (100%) | Fees (80%) | Expenses | | Paid | Holdback | | Covered | | | (100%) | | | | | 9/1/24 - | \$11,130.00 | \$8,904.00 | \$435.94 | \$8,904.00 | \$435.94 | \$2,226.00 | | 9/30/24 | | | | | | | | 10/1/24 - | \$4,145.00 | \$3,316.00 | \$179.22 | \$3,316.00 | \$179.22 | \$829.00 | | 10/31/24 | | | | | | | | 11/1/24 - | \$9,292.50 | \$7,434.00 | \$207.48 | \$7,434.00 | \$207.48 | \$1,858.50 | | 11/30/24 | | | | | | | | 12/1/24 - | \$10,917.50 | \$8,734.00 | \$1,599.02 | \$8,734.00 | \$1,599.02 | \$2,183.50 | | 12/31/24 | | | | | | | | TOTAL | \$35,485.00 | \$28,388.00 | \$2,421.66 | \$28,388.00 | \$2,421.66 | \$7,097.00 | | | | | | | | |

# **MONTHLY FEE REQUESTS FOR APPLICATION PERIOD**

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

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

# **FOURTH INTERIM FEE APPLICATION OF O'SULLIVAN MCCORMACK JENSEN & BLISS PC, AS SPECIAL INSURANCE COVERAGE COUNSEL, FOR COMPENSATION AND REIMBURSEMENT OF EXPENSES FOR PERIOD FROM SEPTEMBER 1, 2024 THROUGH DECEMBER 31, 2024**

Pursuant to sections 105(a), 330, and 331 of title 11 of the United States Code (such title, hereinafter, the "Bankruptcy Code"), Rule 2016 of the Federal Rules of Bankruptcy Procedure (the "Bankruptcy Rules"), Rule 2016-1 of the Local Rules of Bankruptcy Practice and Procedure of the United States Bankruptcy Court for the District of Connecticut (the "Local Rules"), and the *Order Establishing Procedures for Interim Compensation and Reimbursement of Expenses for Retained Professionals, dated August 18, 2023* [Docket No. 2094] (the "Interim Compensation Order"), O'Sullivan McCormack Jensen & Bliss PC ("OMJB"), as special insurance coverage counsel for Genever Holdings LLC ("Genever (US)"), hereby files this *Fourth Interim Application of O'Sullivan McCormack Jensen & Bliss PC, as Special Insurance Coverage Counsel, for Compensation and Reimbursement of Expenses for the Period from*

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).

*September 1, 2024 through December 31, 2024* (the "Application"). By this Application, OMJB requests interim allowance of professional fees incurred during the period from September 1, 2024 through and including December 31, 2024 (the "Application Period") in Genever (US)'s chapter 11 case. In support of this Application, OMJB respectfully states as follows:

# **JURISDICTION, VENUE, BASES FOR RELIEF, AND COMPLIANCE**

1. 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 matter is a core proceeding within the meaning of 28 U.S.C. § 157(b)(2). Venue is proper pursuant to 28 U.S.C. §§ 1408 and 1409.

2. The legal predicates for the relief requested herein are sections 330 and 331 of the Bankruptcy Code, Bankruptcy Rule 2016, and Local Rule 2016-1.

3. OMJB believes that this Application, together with the attachments hereto, substantially complies with the Bankruptcy Rules, Local Rule 2016-1, and the *United States Trustee's Guidelines for Reviewing Applications for Compensation and Reimbursement of Expenses Filed Under 11 U.S.C. § 330 by Attorneys in Larger Chapter 11 Cases* (the "U.S. Trustee Guidelines").2 OMJB respectfully requests a waiver of any of the foregoing requirements not met by this Application.

- 4. Attached and incorporated herein by reference are the following Exhibits: - **Exhibit A** contains the Proposed Order granting this Application. - **Exhibit B** is a timekeeper summary that includes the name, title, bar admission, hourly billing rate, aggregate hours, and amount of fees earned for each OMJB individual who provided services during the Application Period;

² OMJB reserves all rights as to the relevance and substantive legal effect of the U.S. Trustee Guidelines with respect to any application for compensation in these chapter 11 cases.

- **Exhibit C** is a summary of expenses incurred and reimbursement sought, by expense type, during the Application Period; and - **Exhibit D** contains the detail of the fees and expenses incurred during the Application Period.

# **BACKGROUND**

# **I. Chapter 11 Cases**

5. On October 12, 2020, Genever (US) filed a voluntary petition for relief under chapter 11 of title 11 of the United States Bankruptcy Code before the United States Bankruptcy Court for the Southern District of New York (the "SDNY Bankruptcy Court"), thereby commencing case number 20-12411 (JLG). See Chapter 11 Petition [Docket No. 1 in Case No. 22-50592 (JAM)].

6. No trustee or examiner has been appointed in Genever (US)'s case.

7. On February 15, 2022 (the "Petition Date"), Ho Wan Kwok (the "Individual

Debtor") filed a voluntary petition for relief under the Bankruptcy Code in the United States Bankruptcy Court for the District of Connecticut (Bridgeport Division) (the "Court").

8. On March 21, 2022, the United States Trustee appointed an Official Committee of Unsecured Creditors (the "Committee") in the Individual Debtor's chapter 11 case. No examiner has been appointed in the Individual Debtor's chapter 11 case.

9. 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 Individual Debtor's chapter 11 case.

10. Pursuant to the Trustee Order, the United States Trustee selected Luc A. Despins as the Trustee. On July 8, 2022, the Court entered an order granting the appointment of Luc A. Despins as trustee (the "Trustee") in the Individual Debtor's chapter 11 case

11. On November 3, 2022, the SDNY Bankruptcy Court entered an order transferring the venue of Genever (US)'s chapter 11 case to this Court. *See Memorandum Decision and Order Granting the Joint Motion of (A) Genever Holdings LLC and (B) Luc A. Despins as Chapter 11 Trustee for Estate of Ho Wan Kwok to Transfer, Pursuant to 28 U.S.C. §§ 1408, and 1412 and Bankruptcy Rule 1014(a), Venue of Chapter 11 Case of Genever Holdings LLC to Bankruptcy Court for District of Connecticut* [Docket No. 225 in Case No. 22-50592 (JAM)].

12. The chapter 11 cases of the Individual Debtor, Genever (US), and Genever Holdings Corporation ("Genever (BVI)") are being jointly administered before this Court for procedural purposes only. *See* Docket No. 1141 in Case No. 22-50073 (JAM).

13. By order entered August 22, 2023, the Court authorized OMJB's retention as special insurance coverage counsel to Genever (US) [Docket No. 2105] (the "Retention Order") effective as of July 27, 2023 in Genever (US)'s chapter 11 case. The Retention Order authorizes OMJB to be compensated on an hourly basis and reimbursed for actual and necessary out-ofpocket expenses pursuant to sections 328 and 330 of the Bankruptcy Code, the Bankruptcy Rules, the Local Rules, and such orders as the Court may direct.

### **II. Prior Interim Fee Applications**

14. On February 16, 2024, OMJB filed its *First Interim Fee Application of O'Sullivan McCormack Jensen & Bliss PC, as Special Insurance Coverage Counsel for Compensation and Reimbursement of Expenses for Period From July 27, 2023 Through December 31, 2023* [Docket No. 2928] (the "First Interim Fee Application"), requesting interim allowance of professional fees incurred during the period from July 27, 2023 through and including December 31, 2023 in these chapter 11 cases. On March 20, 2024, the Court granted the First Interim Fee Application.

15. On June 24, 2024, OMJB filed its *Second Interim Fee Application of O'Sullivan McCormack Jensen & Bliss PC, as Special Insurance Coverage Counsel for Compensation and Reimbursement of Expenses for Period From January 1, 2024 Through April 30, 2024* [Docket No. 3279] (the "Second Interim Fee Application"), requesting interim allowance of professional fees incurred during the period from January 1, 2024 through and including April 30, 2024 in these chapter 11 cases. On July 23, 2024, the Court granted the Second Interim Fee Application.

16. On October 15, 2024, OMJB filed its *Third Interim Fee Application of O'Sullivan McCormack Jensen & Bliss PC, as Special Insurance Coverage Counsel for Compensation and Reimbursement of Expenses for Period From May 1, 2024 Through August 31, 2024* [Docket No. 3697] (the "Third Interim Fee Application"), requesting interim allowance of professional fees incurred during the period from May 1, 2024 through and including August 31, 2024 in these chapter 11 cases. On November 13, 2024, the Court granted the Third Interim Fee Application.

#### **III. Monthly Fee Statements**

17. On August 18, 2023, the Court entered the *Order Establishing Procedures for Interim Compensation and Reimbursement of Expenses for Retained Professionals* [Docket No. 2094 (the *"*Interim Compensation Procedures Order"), which, among other things, approves procedures for the payment of 80% of fees and 100% of expenses on a monthly basis.

18. In accordance with the Interim Compensation Procedures Order, on October 21, 2024, OMJB filed and served its monthly fee statement [Docket No. 3732] (the "September Fee Statement") requesting payment of 80% of all fees and 100% of all expenses actually and necessarily incurred for services rendered during the period from September 1, 2024 through September 30, 2024, in the amounts of \$8,904.00 (80% of \$11,130.00) and \$435.94,

respectively. No objections were filed in response to the September Fee Statement. Accordingly, the estate has paid OMJB \$9,339.94 for fees and expenses with respect to the September Fee Statement.

19. On November 20, 2024, OMJB filed and served its monthly fee statement [Docket No. 3841] (the "October Fee Statement") requesting payment of 80% of all fees and 100% of all expenses actually and necessarily incurred for services rendered during the period from October 1, 2024 through October 31, 2024, in the amounts of \$3,316.00 (80% of \$4,145.00) and \$179.22, respectively. No objections were filed in response to the October Fee Statement. Accordingly, the estate has paid OMJB \$3,495.22 for fees and expenses with respect to the October Fee Statement.

20. On December 20, 2024, OMJB filed and served its monthly fee statement [Docket No. 3922] (the "November Fee Statement") requesting payment of 80% of all fees and 100% of all expenses actually and necessarily incurred for services rendered during the period from November 1, 2024 through November 30, 2024, in the amounts of \$7,434.00 (80% of \$9,292.50) and \$207.48, respectively. No objections were filed in response to the November Fee Statement. Accordingly, the estate has paid OMJB \$7,641.48 for fees and expenses with respect to the November Fee Statement.

21. On January 21, 2025, OMJB filed and served its monthly fee statement [Docket No. 3983] (the "December Fee Statement") requesting payment of 80% of all fees and 100% of all expenses actually and necessarily incurred for services rendered during the period from December 1, 2024 through December 31, 2024, in the amounts of \$8,734.00 (80% of \$10,917.50) and \$1,599.02, respectively. No objections were filed in response to the December

Fee Statement. Accordingly, the estate has paid OMJB \$10,333.02 for fees and expenses with respect to the December Fee Statement.

### **ALLOWANCE REQUEST**

22. The Applicant is applying for compensation pursuant to Sections 330 and 331 of the Bankruptcy Code for legal services performed for Genever (US) during the Application Period.

23. For the Application Period, the Applicant seeks allowance of \$35,485.00 as compensation for services rendered and allowance and reimbursement of \$2,421.66 in expenses incurred in connection with such services. The Applicant devoted 95.1 hours to this case during the Application Period, equating to an overall blended rate of \$373.13.

24. As noted, OMJB has already received payment of \$28,388.00 of the fees incurred during the Application Period and \$2,421.66 of the expenses incurred during the Application Period, such that OMJB is only seeking payment of the remaining 20% of its fees incurred during the Application Period, namely \$7,097.00.

25. Throughout the Application Period, the Applicant maintained records to indicate the name of each professional working on this matter, the time spent on a particular issue, and the nature of the work performed. These records, which describe in detail the services rendered by the Applicant, were created at the approximate time the services were performed.

26. Annexed hereto and made a part hereof as **Exhibit D** is a detailed billing report, upon which this application is based that contains each individual professional's time for Genever (US)'s bankruptcy proceedings, itemizing the dates upon which services were rendered, including a summary of the services on each of such dates by each person rendering the service, the time spent in rendering such service, and the dollar value of such services. The time detail

attached hereto as **Exhibit D** include certain redactions to protect against the disclosure of privileged or confidential information.

#### **SUMMARY OF SERVICES RENDERED**

27. OMJB is special insurance coverage counsel for Genever (US) in its pending litigation against American International Group, Inc. ("AIG") under Adv. Proc. No. 23-5007 (the "AIG Action"). Generally, OMJB represents Genever (US) with respect to insurance coverage advice and litigation services to recover insurance benefits claimed to be due to Genever (US) for losses it sustained as well as to any matters related to the AIG Action.

28. During the Application Period, OMJB continued to work closely with Genever (US) regarding its prosecution of the AIG Action, reviewing documents and pursuing discovery from AIG and nonparties, taking the deposition of Wolfson Insurance, and preparing briefing in connection with a stay of discovery. In addition, OMJB prepared for and attended the status conference with respect to the AIG Action on October 8, 2024, as well as worked with counsel for AIG regarding a scheduling order, including as it relates to expert discovery. Finally, OMJB prepared a substantive response to AIG's submission of supplemental materials in opposition to Genever (US)'s motion for partial summary judgment in the AIG Action.

29. The work undertaken by OMJB to date has been significant and remains ongoing, with additional work expected in due course.

#### **LEGAL AUTHORITY FOR COMPENSATION**

30. All of the professional services for which this award is being sought hereby were rendered solely on behalf of Genever (US) in connection with the chapter 11 cases herein.

31. Applicant respectfully submits that its services have benefited Genever (US) with the expertise and skill required in insurance litigation. The services for which such

compensation is requested were performed for and on behalf of Genever (US). Such services have been necessary to protect and enforce the rights and interests of Genever (US) in connection with these chapter 11 cases. The reasonable value of services rendered by OMJB in these cases is based upon OMJB' usual hourly rates for matters of this nature.

32. Section 330 of the Bankruptcy Code prescribes the general standards for determining the amount of compensation to be paid to professionals. The Applicant submits that the amount sought for the Application Period represents reasonable compensation for professional services rendered based upon the time spent, the nature, the extent, and the value of such services, taking into account the cost of comparable services in a non-bankruptcy case.

33. Section 331 of the Bankruptcy Code provides for interim compensation of professionals and incorporates the substantive standards of section 330 of the Bankruptcy Code to govern the Court's award of such compensation. Section 330(a) of the Bankruptcy Code provides that, after notice and a hearing, the Court may award a professional employed under 11 U.S.C. § 327 "reasonable compensation for actual, necessary services rendered" and "reimbursement for actual, necessary expenses." 11 U.S.C. § 330(a)(1).3

34. In determining the amount of "reasonable compensation," the Court must consider the nature, extent, and value of the services, taking into account all the relevant factors, including the time spent on such services, the rates charged for such services, whether the services were necessary and beneficial, whether the services were performed in a reasonable amount of time commensurate with the complexity, importance, and nature of the problem, issue, or task addressed, and whether the compensation is reasonable based on the customary

³ Under section 328(a) of the Bankruptcy Code, with bankruptcy court approval, a trustee may employ professional persons under section 327(a) of the Bankruptcy Code "on any reasonable terms and conditions of employment, including on a retainer, on an hourly basis, on a fixed or percentage fee basis, or on a contingent fee basis." 11 U.S.C. § 328(a).

compensation charged by comparably skilled practitioners in cases other than cases under the Bankruptcy Code. See 11 U.S.C. § 330(a)(3). The Court enjoys "considerable discretion in determining reasonable fee awards." *In re Ahead Communication Systems, Inc.*, 395 B.R. 512 (D. Conn. 2008).

35. In assessing the "reasonableness" of the fees requested, the Second Circuit has stated that courts should consider the factors enumerated in *Johnson v. Ga. Highway Express, Inc.*, 4 while also incorporating the "lodestar method." *See Arbor Hill Concerned Citizens Neighborhood Ass'n v. County of Albany and Albany County Bd. of Elections*, 522 F.3d 182, 190 (2d Cir. 2007) (*citing Johnson v. Ga. Highway Express, Inc.*, 488 F.2d 714 (5th Cir.1974), *abrogated on other grounds* by *Blanchard v. Bergeron*, 489 U.S. 87, 92–93, 96 (1989)). The "lodestar method" of calculating the reasonable fee contemplates "the number of hours reasonably expended . . . multiplied by a reasonable hourly rate." *See Hensley v. Eckerhart*, 461 U.S. 424, 433 (1983); *Gisbrecht v. Barnhart*, 535 U.S. 789, 801 (2002); *Perdue v. Kenny A.*, 130 S.Ct. 1662, 1672 (2010); *In re Drexel Burnham Lambert Grp., Inc.*, 133 B.R. 13 (Bankr. S.D.N.Y. 1991). The factors set forth in *Johnson* and *In re First Colonial Corp. of Am.*, 544 F.2d 1291, 1298–99 (5th Cir. 1977) have been adopted by most courts.⁵ *See In re Nine Assocs., Inc.*, 76 B.R. 943, 945 (S.D.N.Y. 1987) (adopting *First Colonial/Johnson* analysis); *In re Cuisine*

⁴ The twelve *Johnson* factors are (1) the time and labor required, (2) the novelty and difficulty of the questions, (3) the skill requisite to perform the legal service properly, (4) the preclusion of other employment by the attorney due to acceptance of the case, (5) the customary fee, (6) whether the fee is fixed or contingent, (7) the time limitations imposed by the client or the circumstances, (8) the amount involved and the results obtained, (9) the experience, reputation, and ability of the attorneys, (10) the "undesirability" of the case, (11) the nature and length of the professional relationship with the client, and (12) awards in similar cases. *Johnson*, 488 F.2d at 717-19.

⁵ The factors articulated in *First Colonial* were first articulated by the Fifth Circuit in *Johnson*, with the *First Colonial* court adding the factor of the "spirit of economy," which was later rejected by Congress. *See Stroock & Stroock & Lavan v. Hillsborough Holdings Corp. (In re Hillsborough Holdings Corp.)*, 127 F.3d 1398, 1403 (11th Cir. 1997).

*Magazine, Inc.*, 61 B.R. 210, 212–13 (Bankr. S.D.N.Y 1986) (same); *Green v. City of New York*, 403 F. Appx. 626, 629 (2d Cir. 2010) (summary order); *see generally* 3 COLLIER ON BANKRUPTCY ¶ 330.03[9] (Lawrence P. King ed., 16th ed. 2016) (describing *First Colonial* and *Johnson* as the "leading cases with regard to the factors to be considered in determining a reasonable allowance of compensation").

36. In accordance with the factors enumerated in section 330 of the Bankruptcy Code and applicable case law, the amount requested herein by OMJB is fair and reasonable.

#### **STATUTORY COMPLIANCE**

38. No agreement or understanding exists between OMJB and any other person for the sharing of compensation received or to be received for services rendered in or in connection with this matter. OMJB will not, in any form or guise, share or agree to share compensation for services with any person, nor will OMJB share in the compensation for any other person rendering service in these cases, except as so provided by Section 504(b) of the Bankruptcy Code and Rule 2016 of the Bankruptcy Rules.

#### **RESERVATION OF RIGHTS**

39. To the extent that time or disbursement charges for services rendered or expenses incurred during the Application Period are not included in this Application, or OMJB has for any reason not sought compensation or reimbursement with respect to such services, OMJB reserves the right to request compensation and reimbursement for such services in a supplemental or future application in these chapter 11 cases. Also, OMJB does not waive, and expressly reserves, its right to respond to any objections regarding this Application and the amounts sought for services rendered and expenses incurred.

# **NO PRIOR REQUEST**

40. No previous request for the relief sought herein has been made to this Court or any other court.

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

**WHEREFORE**, OMJB respectfully requests entry of an order, substantially in the form attached hereto, (i) allowing interim compensation for professional services rendered during the Application Period in the amount of \$35,485.00 and reimbursement of \$2,421.66 in expenses, (ii) authorizing and directing prompt payment of fees and expenses from the estate, to the extent not already paid, (iii) allowing such compensation and payment for professional services rendered without prejudice to OMJB's right to seek further compensation and/or payment from the estates for the full value of services performed and expenses incurred, and (iv) granting OMJB such other and further relief as is just.

Dated: February 24, 2025 Glastonbury, Connecticut

By: */s/ Michael T. McCormack*

Michael T. McCormack (ct13799) O'Sullivan McCormack Jensen & Bliss PC 180 Glastonbury Boulevard, Suite 210 Glastonbury, CT 06033 Tel: 860-258-1993 Fax: 860-258-1991 mmccormack@omjblaw.com

*Special Insurance Coverage Counsel for Debtor-In-Possession Genever Holdings LLC*

# **IN THE UNITED STATES BANKRUPTCY COURT FOR THE DISTRICT OF CONNECTICUT BRIDGEPORT DIVISION**

In re:

HO WAN KWOK, et al.,

Debtors.1

Chapter 11

) ) ) ) ) ) ) )

Case No. 22-50073 (JAM)

(Jointly Administered)

# **CERTIFICATE OF SERVICE**

The undersigned hereby certifies that on the date hereof, the *Fourth Interim Application of O'Sullivan McCormack Jensen & Bliss PC, as Special Insurance Coverage Counsel, for Compensation and Reimbursement of Expenses for the Period from September 1, 2024 through December 31, 2024* (the "Application")² was electronically filed. Notice of this filing was sent by e-mail to all parties to the above-captioned chapter 11 cases 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.3 In addition, to the extent not covered by the foregoing, copies of the Application were served on the twenty (20) largest creditors in Genever (US)'s chapter 11 case. Parties may access this filing through the Court's CM/ECF system.

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 defined in this Certification shall have the meanings ascribed to them in the Application.

³ To the extent that the foregoing was filed outside regular business hours, service by mail on recipients unable or not qualified to accept electronic notice was made on the next business day.

Dated: February 24, 2025

New York, New York By: */s/ G. Alexander Bongartz*

G. Alexander Bongartz (*pro hac vice*) Douglass Barron (*pro hac vice*) PAUL HASTINGS LLP 200 Park Avenue New York, New York 10166 (212) 318-6000 alexbongartz@paulhastings.com douglassbarron@paulhastings.com

*Counsel for Genever Holdings LLC*

Case 22-50073 Doc 4148 Filed 02/24/25 Entered 02/24/25 16:57:57 Page 18 of 37

# **EXHIBIT A**

**Proposed Order**

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

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

------------------------------------------------------------- x

# **[PROPOSED] ORDER GRANTING FOURTH INTERIM FEE APPLICATION OF O'SULLIVAN MCCORMACK JENSEN & BLISS PC, AS SPECIAL INSURANCE COVERAGE COUNSEL, FOR COMPENSATION AND REIMBURSEMENT OF EXPENSES FOR PERIOD FROM SEPTEMBER 1, 2024 THROUGH DECEMBER 31, 2024**

Upon consideration of the Application (the "Application") of O'Sullivan McCormack

Jensen & Bliss PC ("OMJB"), as special insurance coverage counsel for Genever Holdings LLC

("Genever (US)"),2 for interim allowance of compensation and reimbursement of expenses from

September 1, 2024 through December 31, 2024; and sufficient notice having been given; and a

hearing having been held on \_\_\_\_\_\_\_\_, 2025 and due consideration having been given to any

responses thereto; and sufficient cause having been shown therefor, it is hereby:

1. ORDERED that the Application is granted, pursuant to 11 U.S.C. §§ 330 and 331,

and compensation in the amount of \$35,485.00 and reimbursement of expenses in the amount 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).

² Capitalized terms not otherwise defined herein adopt the definitions set forth in the Application.

\$2,421.66 are awarded to OMJB, subject to final adjustment and disgorgement in the event all administrative expenses are not paid in full; it is further

2. ORDERED that nothing herein modified the Retention Order; it is further

3. ORDERED that the estates are authorized and directed to pay OMJB's fees in the amount of \$7,097.00, *i.e.*, 20% of the fees allowed in paragraph 1 above, within fourteen days of the date of this Order; it is further

4. ORDERED that this Court shall retain jurisdiction to hear and determine all matters arising from the implementation of this Order; it is further

5. ORDERED that Genever (US)'s estate and OMJB are authorized and empowered to take all necessary actions to implement the relief granted in this Order; it is further

6. ORDERED that notwithstanding the possible applicability of Bankruptcy Rules 6006(d), 7062, 9014, or otherwise, the terms and conditions of this Order shall be immediately effective and enforceable upon its entry; and it is further

7. ORDERED that all time periods set forth in this Order shall be calculated in accordance with Bankruptcy Rule 9006(a).

Case 22-50073 Doc 4148 Filed 02/24/25 Entered 02/24/25 16:57:57 Page 21 of 37

### **EXHIBIT B**

#### **Timekeeper Summary**

| TIMEKEEPER | DATE OF | TITLE | HOURS | HOURLY | TOTAL | |----------------------|-----------|-------------|-------|----------|-------------| | | FIRST BAR | | | RATE | | | | ADMISSION | | | | | | Timothy P. Jensen | 1997 | Shareholder | 28.2 | \$450.00 | \$12,690.00 | | Michael T. McCormack | 1993 | Shareholder | 27.2 | \$400.00 | \$10,880.00 | | Amy E. Markim | 2008 | Shareholder | 30.9 | \$350.00 | \$10,815.00 | | Melissa Gambardella | | Paralegal | 8.8 | \$125.00 | \$1,100.00 | | | | | | | | | | | Total | 95.1 | | \$35,485.00 |

**Blended Hourly Rate: \$373.13**

# **EXHIBIT C**

### **Summary of Actual and Necessary Expenses**

| Expense Category | Amount<br>(US\$) | |----------------------------------------|------------------| | PACER | \$9.10 | | Copying | \$57.20 | | Westlaw | \$453.33 | | Fees Advanced to Logikcull | \$709.78 | | Fees Advanced to Veritext (transcript) | \$1,192.25 | | TOTAL | \$2,421.66 |

Case 22-50073 Doc 4148 Filed 02/24/25 Entered 02/24/25 16:57:57 Page 23 of 37

# **EXHIBIT D**

**Fee and Expense Detail**

Case 22-50073 Doc 4148 Filed 02/24/25 Entered 02/24/25 16:57:57 Page 24 of 37 Case 22-50073 Doc 3732 Filed 10/21/24 Entered 10/21/24 15:05:06 Page 9 of 11


180 Glastonbury Boulevard, Suite 210 Glastonbury, CT 06033 Phone: 860-258-1993 [www.omjblaw.com](htt)

**INVOICE**

Invoice No. 28156 Date: 10/15/2024

Genever Holdings LLC c/o Luc Despins, Esq. Paul Hastings LLP 200 Park Avenue New York, NY 10166

# **3726-001-Genever Holdings/AIG Property Casualty**

# **Services**

| Date | Attorney | Activity | Time | Rate | Total | |------------|----------|-------------------------------------------------------------------------------------------------------------------------------------------------------|------|----------|----------| | 09/02/2024 | TPJ | Review background scheduling filings and orders; outline for modifying<br>discovery schedule and specifically damages experts | 1.00 | \$450.00 | \$450.00 | | 09/03/2024 | MTM | Revise and supplement draft motion re stay of expert discovery | 0.40 | \$400.00 | \$160.00 | | 09/03/2024 | TPJ | Drafting motion to modifyfirst level of expert discovery | 1.00 | \$450.00 | \$450.00 | | 09/04/2024 | TPJ | Revise motion to modify discovery schedule | 0.30 | \$450.00 | \$135.00 | | 09/05/2024 | TPJ | Communications re motion to modifydiscovery schedule; Revise motion<br>and finalize | 1.00 | \$450.00 | \$450.00 | | 09/10/2024 | MTM | Telephone conference and email communications with L. Despins re<br>REDACTED | 0.20 | \$400.00 | \$80.00 | | 09/11/2024 | MTM | Review order re status conference re discovery | 0.10 | \$400.00 | \$40.00 | | 09/11/2024 | MTM | Email communications with AIG counsel re status conference issues | 0.10 | \$400.00 | \$40.00 | | 09/12/2024 | MTM | Review of AIG Opposition to Motion to Stay; email correspondence with<br>L. Despins re<br>REDACTED | 0.30 | \$400.00 | \$120.00 | | 09/13/2024 | TPJ | Review and analysis of AIG objection to motion to extend | 0.30 | \$450.00 | \$135.00 | | 09/16/2024 | MBG | Draft August OMJB Fee Statement and begin redactions of invoice exhibit<br>to same. | 0.40 | \$125.00 | \$50.00 | | 09/16/2024 | TPJ | Review fee application; communications re reply brief | 0.30 | \$450.00 | \$135.00 | | 09/17/2024 | MTM | Review and analysis of AIG motions to continue status conference and<br>motion to depose Kwok; email correspondence with Attny Despins re<br>REDACTED | 0.30 | \$400.00 | \$120.00 |

#### Invoice No. 28156 - 10/15/2024 Case 22-50073 Doc 3732 Filed 10/21/24 Entered 10/21/24 15:05:06 Page 10 of 11 4148 02/24/25 02/24/25 16:57:57 25 37

| | | Services Subtotal | | \$11,130.00 | |-------------------|-------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|-------------------|----------|-------------| | 09/26/2024<br>TPJ | Communications re reply brief; revisions to reply brief | 1.00 | \$450.00 | \$450.00 | | 09/26/2024<br>MBG | Review and finalize Reply to AIG's Opposition to Motion to Stay. | 0.60 | \$125.00 | \$75.00 | | 09/26/2024<br>MTM | Attention to revision to reply brief re stay of discovery and summary<br>judgment issues | 0.20 | \$400.00 | \$80.00 | | 09/25/2024<br>TPJ | Revise reply brief | 0.50 | \$450.00 | \$225.00 | | 09/25/2024<br>MTM | Revise and supplement draft reply to AIG opposition to motion to stay<br>(1.2); review and analysis of case re<br>REDACTED<br>(.5); email communications with L. Despins re<br>REDACTED<br>REDACTED<br>(.2)<br>REDACTED | 1.90 | \$400.00 | \$760.00 | | 09/24/2024<br>TPJ | Continue drafting reply brief to opposition to motion, for motion to compel<br>and in support of motion to extend expert deadlines(2.1); review<br>REDACTED<br>REDACTED<br>(2.8)<br>REDACTED | 4.90 | \$450.00 | \$2,205.00 | | 09/24/2024<br>MTM | Review draft reply to AIG memorandumin opposition to motion to stay<br>expert discovery. | 0.20 | \$400.00 | \$80.00 | | 09/23/2024<br>TPJ | Draft reply brief to opposition to motion, for motion to compel and in<br>support of motion to extend expert deadlines | 5.00 | \$450.00 | \$2,250.00 | | 09/20/2024<br>MBG | Attention to E-file and service of OMJB August 2024 Fee Application on<br>Notice Parties. | 0.20 | \$125.00 | \$25.00 | | 09/20/2024<br>MBG | Attention to further redactions to OMJB August 2024 invoice and finalize<br>Fee Application. | 0.20 | \$125.00 | \$25.00 | | 09/20/2024<br>MTM | Revise and supplement fee application and redacted invoice in support | 0.20 | \$400.00 | \$80.00 | | 09/19/2024<br>TPJ | Review cases cited by AIG in objection; additionalresearch re<br>REDACTED<br>REDACTED | 3.90 | \$450.00 | \$1,755.00 | | 09/18/2024<br>MTM | Review of AIG motion to depose Kwok; email correspondence to L.<br>Despins re<br>REDACT | 0.20 | \$400.00 | \$80.00 | | 09/18/2024<br>TPJ | Review motion to depose Kwok. Outlining response to objection to<br>extendingexpert discovery. | 1.50 | \$450.00 | \$675.00 | | | | | | |

#### **Expenses**

| Type | Date | Activity | Total | |---------|------------|----------------------------------------------------------|----------| | Expense | 09/04/2024 | Fees advancedto Logikcull INV270179 8/1/2024 - 8/31/2024 | \$191.66 | | Expense | 09/30/2024 | Westlaw: Month of September | \$235.68 | | Expense | 09/30/2024 | PACER: Month of September | \$8.60 | | | | | |

**Expenses Subtotal \$435.94**

| Time Keeper | Time | Rate | Total | |-------------------|------|----------|------------| | Timothy Jensen | 20.7 | \$450.00 | \$9,315.00 | | Michael McCormack | 4.1 | \$400.00 | \$1,640.00 |

| Melissa Gambardella | 1.4 | \$125.00<br>\$175.00 | |---------------------|------------------|----------------------| | | Invoice Subtotal | \$11,565.94 | | | Invoice Total | \$11,565.94 |

*REDACTED*

Please make all amounts payable to: O'Sullivan McCormack Jensen & Bliss PC

*REDACTED*

Payment is due upon receipt.

Case 22-50073 Doc 4148 Filed 02/24/25 Entered 02/24/25 16:57:57 Page 27 of 37 Case 22-50073 Doc 3841 Filed 11/20/24 Entered 11/20/24 13:43:20 Page 9 of 13


180 Glastonbury Boulevard, Suite 210 Glastonbury, CT 06033 Phone: 860-258-1993 [www.omjblaw.com](htt)

**INVOICE**

Invoice No. 28257 Date: 11/12/2024

Genever Holdings LLC c/o Luc Despins, Esq. Paul Hastings LLP 200 Park Avenue New York, NY 10166

# **3726-001-Genever Holdings/AIG Property Casualty**

# **Services**

| Date | Attorney | Activity | Time | Rate | Total | |------------|----------|---------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|------|----------|------------| | 10/02/2024 | MTM | Review of materials from Attny Linsey re<br>REDACTED<br>telephone conference with. P. Linsey re same | 0.70 | \$400.00 | \$280.00 | | 10/02/2024 | MTM | Review and analysis of policy cancellation letter and policy terms re<br>email correspondence to Attny Linsey re<br>REDACTED<br>REDACTED<br>REDACTED | 0.40 | \$400.00 | \$160.00 | | 10/04/2024 | MBG | Review, revise and finalize Motion to Hold Remote Hearing. | 0.50 | \$125.00 | \$62.50 | | 10/07/2024 | MBG | Attention to Order converting 10/08/2024 hearing to remote and contact<br>clerk for zoom link. | 0.10 | \$125.00 | \$12.50 | | 10/07/2024 | TPJ | Communications with counsel re hearing date | 0.20 | \$450.00 | \$90.00 | | 10/08/2024 | MTM | Review of motion to stay, opposition and reply brief in preparation for<br>status conference; review motion for summary judgment affidavit of<br>O'Connor re<br>(.9); attend status hearing and<br>REDACTED<br>argument re motion to stay expert discovery and motions re Kwok<br>deposition(1.8) | 2.70 | \$400.00 | \$1,080.00 | | 10/08/2024 | MBG | Review recent fee applications and update spreadsheet of fees and<br>expenses to date. | 0.30 | \$125.00 | \$37.50 | | 10/08/2024 | TPJ | Communications with MTM re hearing and status | 0.20 | \$450.00 | \$90.00 | | 10/09/2024 | MTM | Telephone conference with L. Despins re<br>REDACTED<br>REDACTED | 0.30 | \$400.00 | \$120.00 | | 10/09/2024 | MTM | Attention to status conference hearing transcript issues | 0.10 | \$400.00 | \$40.00 | | 10/09/2024 | MBG | Draft, revise and finalize Transcript Request for 10/08 hearing in<br>bankruptcy court. | 0.30 | \$125.00 | \$37.50 |

#### Invoice No. 28257 - 11/12/2024 Case 22-50073 Doc 3841 Filed 11/20/24 Entered 11/20/24 13:43:20 Page 10 of 13 4148 02/24/25 02/24/25 16:57:57 28 37

| 10/10/2024 | MTM | Attention to issues re modifiedpretrial scheduling order and draft<br>proposed order re granting of motion to stay expert discovery and<br>proposed order re msj and pretrial order, email communications to L.<br>Despins and AIG counsel re same | 1.50 | \$400.00 | \$600.00 | |------------|-----|----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|-------------------|----------|------------| | 10/10/2024 | MBG | Telcon with court clerk and email to court reporter to request copy of 10/<br>08/2024 transcript ordered by other counsel. | 0.10 | \$125.00 | \$12.50 | | 10/11/2024 | MTM | Telephone conference with J. O'Connor re status conference follow up<br>and depositions;email correspondence to court clerk re proposed order<br>re motion stay | 0.30 | \$400.00 | \$120.00 | | 10/11/2024 | MTM | REDACTED<br>Review of AIG/Wolfson documentsre issues<br>REDACTED | 0.30 | \$400.00 | \$120.00 | | 10/13/2024 | MTM | Review, revise and supplement interim fee application, email<br>correspondence with Attny Bongartz re same | 0.50 | \$400.00 | \$200.00 | | 10/14/2024 | MTM | Review and comment re revised interim fee application; email<br>correspondence with Attny Bongartz re same | 0.10 | \$400.00 | \$40.00 | | 10/16/2024 | MBG | Draft September Fee Application and begin redactions of OMJB invoices<br>for same. | 0.40 | \$125.00 | \$50.00 | | 10/17/2024 | MTM | Review court orders re modified scheduling order and AIG motion to<br>deposeKwok | 0.10 | \$400.00 | \$40.00 | | 10/17/2024 | MBG | Additionalredactions to OMJB invoice. | 0.10 | \$125.00 | \$12.50 | | 10/17/2024 | TPJ | Review fee application | 0.20 | \$450.00 | \$90.00 | | 10/18/2024 | MBG | Finalize OMJB September fee application. | 0.20 | \$125.00 | \$25.00 | | 10/25/2024 | TPJ | Communications re Wolfson deposition | 0.50 | \$450.00 | \$225.00 | | 10/29/2024 | MTM | Telephone conference with Luc Despins re<br>REDACTED | 0.20 | \$400.00 | \$80.00 | | 10/29/2024 | MTM | Review of Wolfson production in preparation of for AIG depositionof<br>Wolfson; review<br>REDACTED | 0.80 | \$400.00 | \$320.00 | | 10/31/2024 | MTM | Telephone conference with<br>REDACTED<br>re deposition | 0.50 | \$400.00 | \$200.00 | | | | | Services Subtotal | | \$4,145.00 |

#### **Expenses**

| Date | Activity | Total | |------------|-----------------------------------------------------------|----------| | 10/01/2024 | Fees advancedto Logikcull INV2722378 9/1/2024 - 9/30/2024 | \$176.92 | | 10/31/2024 | Copying: Month of October | \$1.80 | | 10/31/2024 | PACER: Month of October | \$0.50 | | | | |

**Expenses Subtotal \$179.22**

| Time Keeper | Time | Rate | Total | |-------------------|------|----------|------------| | Timothy Jensen | 1.1 | \$450.00 | \$495.00 | | Michael McCormack | 8.5 | \$400.00 | \$3,400.00 |

Invoice No. 28257 - 11/12/2024 Case 22-50073 Doc 3841 Filed 11/20/24 Entered 11/20/24 13:43:20 Page 11 of 13 4148 02/24/25 02/24/25 16:57:57 29 37

| Melissa Gambardella | 2.0 | \$125.00 | \$250.00 | |---------------------|-----|------------------|------------| | | | Invoice Subtotal | \$4,324.22 | | | | Invoice Total | \$4,324.22 |

| REDACTED | | |----------|--| | | | | | |

Please make all amounts payable to: O'Sullivan McCormack Jensen & Bliss PC Tax ID#

*REDACTED*

Payment is due upon receipt.

Invoice No. 28257 - 11/12/2024 Case 22-50073 Doc 3841 Filed 11/20/24 Entered 11/20/24 13:43:20 Page 12 of 13 4148 02/24/25 02/24/25 16:57:57 30 37

*REDACTED*

180 Glastonbury Boulevard, Suite 210 Glastonbury, CT 06033 Phone: 860-258-1993 [www.omjblaw.com](htt)


Invoice No. 28257 Date: 11/12/2024

*REDACTED*

Case 22-50073 Doc 4148 Filed 02/24/25 Entered 02/24/25 16:57:57 Page 32 of 37 Case 22-50073 Doc 3922 Filed 12/20/24 Entered 12/20/24 13:48:51 Page 9 of 11


180 Glastonbury Boulevard, Suite 210 Glastonbury, CT 06033 Phone: 860-258-1993 [www.omjblaw.com](htt)

**INVOICE**

Invoice No. 28372 Date: 12/11/2024

Genever Holdings LLC c/o Luc Despins, Esq. Paul Hastings LLP 200 Park Avenue New York, NY 10166

# **3726-001-Genever Holdings/AIG Property Casualty**

# **Services**

| Date | Attorney | Activity | Time | Rate | Total | |------------|----------|------------------------------------------------------------------------------------------------------------------------------------|------|----------|------------| | 11/01/2024 | MTM | Revise depositionnotice re AIG deposition,draft list of topics re AIG<br>deposition,email correspondence to Attny O'Connor re same | 0.90 | \$400.00 | \$360.00 | | 11/01/2024 | MBG | Draft 30b(6) depositionnotice on AIG. | 0.40 | \$125.00 | \$50.00 | | 11/01/2024 | TPJ | Attend to depositiontopics | 0.90 | \$450.00 | \$405.00 | | 11/02/2024 | TPJ | Review corporate witness depositiontopics; communications re same | 0.50 | \$450.00 | \$225.00 | | 11/03/2024 | TPJ | Communications re Wolfson deposition | 0.20 | \$450.00 | \$90.00 | | 11/04/2024 | MBG | Communications with court reporter re AIG 30b(6) deposition. | 0.10 | \$125.00 | \$12.50 | | 11/04/2024 | AM | Email correspondence with J. O'Connor, A. Wolfson, et al. re: Wolfson<br>30b6 deposition. | 0.30 | \$350.00 | \$105.00 | | 11/06/2024 | MTM | Email communications with AIG counsel re motion to modify<br>scheduling order | 0.10 | \$400.00 | \$40.00 | | 11/06/2024 | MTM | Review of draft motion to modifyfact discovery deadline;email<br>correspondence with counsel re same | 0.10 | \$400.00 | \$40.00 | | 11/09/2024 | MTM | Email communications with T. Garg re status conference transcript | 0.10 | \$400.00 | \$40.00 | | 11/13/2024 | MBG | Draft of OMJB Fee Application for October Fees and initial redaction of<br>invoice re same. | 0.40 | \$125.00 | \$50.00 | | 11/14/2024 | AM | Review Wolfson documentproduction in preparation for Wolfson<br>deposition. | 3.30 | \$350.00 | \$1,155.00 | | 11/16/2024 | MTM | Email communications re AIG deposition | 0.20 | \$400.00 | \$80.00 |

#### Invoice No. 28372 - 12/11/2024 Case 22-50073 Doc 3922 Filed 12/20/24 Entered 12/20/24 13:48:51 Page 10 of 11 4148 02/24/25 02/24/25 16:57:57 33 37

| 11/16/2024 | TPJ | Communications re Wolfson deposition; review documentsfor<br>information to use for deposition | 0.80 | \$450.00 | \$360.00 | |------------|-----|-----------------------------------------------------------------------------------------------------------------------------------------------------------------------|------|----------|------------| | 11/17/2024 | TPJ | Review and analysis of information for Wolfson depo | 0.70 | \$450.00 | \$315.00 | | 11/18/2024 | AM | Prepare for depositionof Wolfson by reviewing documents/potential<br>exhibits and outlining examination. | 3.50 | \$350.00 | \$1,225.00 | | 11/18/2024 | MBG | Attention to court order converting hearing to remote proceeding. | 0.10 | \$125.00 | \$12.50 | | 11/18/2024 | TPJ | Communications re Wolfson deposition | 0.50 | \$450.00 | \$225.00 | | 11/18/2024 | MTM | Telephone conference with<br>REDACTED<br>(2.) review of documentsre preparation for deposition,email<br>communications re Wolfson deposition(.6) | 0.80 | \$400.00 | \$320.00 | | 11/18/2024 | MTM | Email correspondence to L. Despins re<br>REDACTED<br>REDACTED | 0.20 | \$400.00 | \$80.00 | | 11/19/2024 | AM | Attend depositionof Wolfson Insurance. | 4.20 | \$350.00 | \$1,470.00 | | 11/19/2024 | MTM | Attend status conference with J. Manning re discovery deadlines;<br>telephone conference with J. O'Connor re depositionsand status re<br>potential mediation | 0.50 | \$400.00 | \$200.00 | | 11/19/2024 | AM | Continue preparing for depositionof Wolfson Insurance. | 2.90 | \$350.00 | \$1,015.00 | | 11/19/2024 | AM | Prepare and send exhibits to court reporter and AIG counsel. | 0.20 | \$350.00 | \$70.00 | | 11/19/2024 | TPJ | Review and pull additionaldocumentsfor use at Wolfson deposition<br>(.8) Review fee application (.3) | 1.10 | \$450.00 | \$495.00 | | 11/19/2024 | MBG | Further revisions to October OMJB fee application and redactions to<br>invoice. | 0.20 | \$125.00 | \$25.00 | | 11/19/2024 | MTM | Attention to issues re<br>REDACTED<br>REDACTED | 0.50 | \$400.00 | \$200.00 | | 11/19/2024 | MTM | Email correspondence to Attny O'Connor re AIG deposition(.1), email<br>communications with L. Despins re<br>REDACTED<br>(.2) | 0.30 | \$400.00 | \$120.00 | | 11/20/2024 | MTM | Review proposed order re modification of scheduling order; email<br>correspondence to L. Despins re<br>; review<br>REDACTED<br>summary re Wolfson depositiontestimony | 0.30 | \$400.00 | \$120.00 | | 11/20/2024 | MBG | Finalize and e-file OMJB October Fees Application and transmit to<br>notice parties. | 0.30 | \$125.00 | \$37.50 | | 11/20/2024 | AM | REDACTED<br>Email to L. Despins re: | 1.00 | \$350.00 | \$350.00 | | | | | | | |

*REDACTED*

**Services Subtotal \$9,292.50**

**Expenses**

| Type | Date | Activity | Total | |---------|------------|------------------------------------------------------------|----------| | Expense | 11/04/2024 | Fees advancedto Logikcull INV273921 10/1/2024 - 10/31/2024 | \$164.28 | | Expense | 11/30/2024 | Copying: Month of November | \$43.20 |

| | | Expenses Subtotal | \$207.48 | |---------------------|------|----------------------|------------| | Time Keeper | Time | Rate | Total | | Timothy Jensen | 4.7 | \$450.00 | \$2,115.00 | | Amy Markim | 15.4 | \$350.00 | \$5,390.00 | | Michael McCormack | 4.0 | \$400.00 | \$1,600.00 | | Melissa Gambardella | 1.5 | \$125.00 | \$187.50 | | Administrator OMJB | 1.0 | \$0.00 | \$0.00 | | | | Invoice Subtotal | \$9,499.98 | | | | Invoice Total | \$9,499.98 | | | | Payment (12/11/2024) | -\$4.32 | | | | Balance Owing | \$9,495.66 | | | | | |

*REDACTED*

Please make all amounts payable to: O'Sullivan McCormack Jensen & Bliss PC

*REDACTED*

Payment is due upon receipt.

Case 22-50073 Doc 4148 Filed 02/24/25 Entered 02/24/25 16:57:57 Page 35 of 37 Case 22-50073 Doc 3983 Filed 01/21/25 Entered 01/21/25 10:46:13 Page 9 of 11


180 Glastonbury Boulevard, Suite 210 Glastonbury, CT 06033 Phone: 860-258-1993 [www.omjblaw.com](htt)

**INVOICE**

Invoice No. 28454 Date: 01/13/2025

Genever Holdings LLC c/o Luc Despins, Esq. Paul Hastings LLP 200 Park Avenue New York, NY 10166

# **3726-001-Genever Holdings/AIG Property Casualty**

# **Services**

| Date | Attorney | Activity | Time | Rate | Total | |------------|----------|--------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|------|----------|------------| | 12/04/2024 | MTM | Email correspondence from Attny O'Connor re AIG depositionissues | 0.10 | \$400.00 | \$40.00 | | 12/04/2024 | AM | Review supplemental submission by AIG and email from opposing<br>counsel re: extending depositions/mediation. | 0.30 | \$350.00 | \$105.00 | | 12/04/2024 | MBG | Draft Re-NOD of AIG 30(b)(6) depositionand finalize same with<br>Schedule A. | 0.20 | \$125.00 | \$25.00 | | 12/05/2024 | AM | Confer with M. McCormack and T. Jensen re: strategy re: deposition,<br>summary judgment, and mediation. | 0.50 | \$350.00 | \$175.00 | | 12/05/2024 | MTM | Review and analysis of AIG supplemental memorandumin opposition<br>to motion for summary judgment (.4), analysis re<br>REDACTED<br>(.5),<br>REDACTED<br>review of Wolfson depositiontranscript re AIG MSJ opposition issues<br>(1.4) | 2.30 | \$400.00 | \$920.00 | | 12/05/2024 | MTM | Draft email to L. Despins re<br>REDACTED<br>REDACTED | 0.30 | \$400.00 | \$120.00 | | 12/05/2024 | TPJ | Communications re MSJ strategy and discovery | 0.50 | \$450.00 | \$225.00 | | 12/06/2024 | MTM | Email communications with Attny O'Connor re AIG depositionissues | 0.10 | \$400.00 | \$40.00 | | 12/12/2024 | AM | Legal research to respond to supplemental materials/brief of AIG. | 5.00 | \$350.00 | \$1,750.00 | | 12/12/2024 | MTM | Review of MSJ cases re<br>from Attny Barron;<br>REDACTED<br>attention to reply brief issues re AIG supplemental opposition | 0.20 | \$400.00 | \$80.00 | | 12/12/2024 | MBG | Begin draft of November OMJB Fee Application and redaction of<br>invoice. | 0.50 | \$125.00 | \$62.50 |

#### Invoice No. 28454 - 01/13/2025 Case 22-50073 Doc 3983 Filed 01/21/25 Entered 01/21/25 10:46:13 Page 10 of 11 4148 02/24/25 02/24/25 16:57:57 36 37

| | | | Services Subtotal | | \$10,917.50 | |------------|-----|------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|-------------------|----------|-------------| | 12/20/2024 | TPJ | Review fee application | 0.20 | \$450.00 | \$90.00 | | 12/20/2024 | MBG | Revise and finalize OMJB November Fees Application and further<br>redaction of invoice attachment. | 0.40 | \$125.00 | \$50.00 | | 12/20/2024 | MTM | Review, revise and supplement interim fee application and supporting<br>documents | 0.30 | \$400.00 | \$120.00 | | 12/17/2024 | MBG | Review and revise Response to AIG Supplemental Materials<br>memorandumand draft MTM Declaration including preparation of<br>attached exhibits. | 2.80 | \$125.00 | \$350.00 | | 12/17/2024 | MTM | Review and analysis of cases re summary judgment and declarations<br>re<br>(.8);<br>REDACTED<br>review of<br>(.5)<br>REDACTED | 1.30 | \$400.00 | \$520.00 | | 12/17/2024 | MTM | Revise and supplement declaration and supporting documentsre reply<br>to AIG opposition (.8); email communications and telephone<br>conference with Attny Despins re<br>(.4)<br>REDACTED | 1.20 | \$400.00 | \$480.00 | | 12/17/2024 | MTM | Revise and supplement reply brief to AIG supplemental submission<br>and review and analysis of cases re<br>REDACTED<br>; review AIG brief in opposition to motion for summary judgment | 3.30 | \$400.00 | \$1,320.00 | | 12/17/2024 | AM | Revise/supplement response to AIG's supplemental MSJ submission. | 3.00 | \$350.00 | \$1,050.00 | | 12/16/2024 | TPJ | Review draft reply and comments re same | 1.00 | \$450.00 | \$450.00 | | 12/16/2024 | AM | Revise/supplement response to AIG summary judgment supplement. | 1.60 | \$350.00 | \$560.00 | | 12/16/2024 | MTM | Telephone conference with Attny O'Connor re possible mediation<br>issues | 0.20 | \$400.00 | \$80.00 | | 12/16/2024 | MTM | Review and revise draft of reply re AIG supplemental summary<br>judgment submission; email communications with L. Despins re<br>REDA | 1.00 | \$400.00 | \$400.00 | | 12/13/2024 | MTM | Analysis and strategy re reply to AIG supplement opposition | 0.30 | \$400.00 | \$120.00 | | 12/13/2024 | AM | Continue drafting response to supplemental submission of AIG re:<br>summary judgment. | 5.10 | \$350.00 | \$1,785.00 | | | | | | | |

#### **Expenses**

| Type | Date | Activity | Total | |---------|------------|-----------------------------------------------------------------------------------|------------| | Expense | 12/03/2024 | Fees advancedto Logikcull INV275607 11/1-2024-11/30/2024 | \$176.92 | | Expense | 12/23/2024 | Fees advancedto Veritext LLC invoice 7893246 11-22-2024 re AdamWolfson transcript | \$1,192.25 | | Expense | 12/31/2024 | Copying: Month of December | \$12.20 | | Expense | 12/31/2024 | Westlaw: Month of December | \$217.65 | | | | | |

**Expenses Subtotal \$1,599.02**

| Time Keeper | Time | Rate | Total | |----------------|------|----------|----------| | Timothy Jensen | 1.7 | \$450.00 | \$765.00 |

Invoice No. 28454 - 01/13/2025 Case 22-50073 Doc 3983 Filed 01/21/25 Entered 01/21/25 10:46:13 Page 11 of 11 4148 02/24/25 02/24/25 16:57:57 37 37

| Amy Markim | 15.5 | \$350.00 | \$5,425.00 | |---------------------|------|------------------|-------------| | Michael McCormack | 10.6 | \$400.00 | \$4,240.00 | | Melissa Gambardella | 3.9 | \$125.00 | \$487.50 | | | | Invoice Subtotal | \$12,516.52 | | | | Invoice Total | \$12,516.52 | | | | | |

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Please make all amounts payable to: O'Sullivan McCormack Jensen & Bliss PC Tax ID#

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Payment is due upon receipt.