---
type: court_doc
id: "court_ctb_4352_0"
court: "CTB"
case_no: "22-50073"
doc_number: 4352
doc_type: "ORDER"
filed_date: "2025-04-25"
lang: "zh"
url: "https://mubeitech.com/court/court_ctb_4352_0"
json_url: "https://mubeitech.com/api/court/court_ctb_4352_0"
---
# UNITED STATES BANKRUPTCY COURT DISTRICT OF CONNECTICUT BRIDGEPORT DIVISION | -------------------------------------------
> 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**
| ------------------------------------------------------ | 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 HADEF & PARTNERS AS LOCAL 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 Hadef & Partners ("Hadef"), as local counsel in the United Arab Emirates (the
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).
"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 Karim Mahmoud 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 Hadef & Partners as Local Counsel in United Arab Emirates* (the "Mahmoud 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 Hadef as the Chapter 11 Trustee's local counsel in the UAE, effective as of April 11, 2025, to assist the Trustee in his efforts to recover assets of the Debtor's estate potentially located in the UAE.
2. While the Chapter 11 Trustee has already retained Kobre & Kim LLP ("Kobre & Kim") as his special counsel in the UAE, Kobre & Kim's attorneys are only admitted to practice in the courts within certain zones in the UAE, including the Abu Dhabi Global Market ("ADGM") zone (located in Abu Dhabi, UAE's capital), but are not admitted to practice in the federal courts of general jurisdiction of the UAE or the local courts of general jurisdiction in Abu Dhabi. However, in order for the Trustee to continue his investigation and recover assets in the UAE, he requires counsel who is admitted to practice in both the ADGM and the federal in UAE and the local courts in Abu Dhabi. Therefore, the Trustee request this Court's approval to retain
Hadef to act as the Trustee's local counsel in the UAE to represent the Trustee's interest in local and federal UAE courts.
## **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].
## **HADEF'S QUALIFICATIONS**
10. Hadef is a leading full-service law firm in the UAE that is highly regarded for litigation and enforcement matters in the UAE. It has multiple offices in the UAE, including in Dubai, at Level 5, Building 3, Emaar Square, Downtown Dubai, Dubai, UAE. Hadef's partners come from various jurisdictions and backgrounds, including attorneys with expertise in crossborder transactions and disputes as well as corporate and commercial law.
## **ANTICIPATED SERVICES**
11. The Chapter 11 Trustee anticipates that Hadef will assist the Chapter 11 Trustee and Kobre and Kim in the investigation of assets and transfers connected to the Debtor that may be located in the UAE, and litigation in connection with such assets.2 Due to the specialized nature of Hadef's role as local counsel in the UAE federal and local courts, there will be no duplication of services arising from Hadef's retention, including as it relates to Kobre & Kim's retention as special counsel in the UAE's ADGM zone.
## **COMPENSATION OF HADEF**
12. Hadef 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. Hadef will charge the Debtor's estate for its legal services on an hourly basis at its regularly applicable hourly rates in connection with the services required in the UAE.
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.
13. At present, the 2025 hourly rate of Hadef are between \$463 to \$1,021 for lawyers (plus 5% VAT), and \$272 to \$408 for paraprofessionals (plus 5% VAT). Hadef will also bill for out-of-pocket expenses made on behalf of the Trustee, including photocopying, postage and package deliveries, court fees, transcripts, witness fees, service fees, travel expenses, computeraided research and translations.
14. The Trustee submits that Hadef's hourly rates are reasonable, comparable to Hadef's hourly rates for other engagements, and within the range of rates charged by comparably skilled professionals who offer the same services.
## **HADEF IS DISINTERESTED**
15. To the best of the Chapter 11 Trustee's knowledge in reliance upon the Mahmoud Declaration, and except as disclosed therein, Hadef 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 Mahmoud Declaration, and except as disclosed therein, the Chapter 11 Trustee believes that: (a) Hadef 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) Hadef 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
Hadef 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 Mahmoud Declaration, the Chapter 11 Trustee believes that Hadef 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 Hadef as his local 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 local counsel in the UAE to exercise his responsibilities. Hadef will endeavor to avoid the duplication of efforts and provide services as efficiently as possible.
21. Accordingly, the employment of Hadef as the Chapter 11 Trustee's local 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 Hadef'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 Hadef effective April 11, 2025, which was the date that Hadef began providing services to the Chapter 11 Trustee.
## **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 Hadef as local counsel in the UAE, and order such other and further relief as the Court deems just and proper.
Dated: April 25, 2025 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: April 25, 2025 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*
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).
Case 22-50073 Doc 4352 Filed 04/25/25 Entered 04/25/25 13:15:59 Page 10 of 50
# **EXHIBIT A**
**Proposed Order**
# **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 | |
# **[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 HADEF & PARTNERS AS LOCAL 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 Hadef & Partners ("Hadef"), as local counsel in the United Arab Emirates (the "UAE"), effective as of April 11, 2025, 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
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 Mahmoud Declaration
upon consideration of the Application and the Mahmoud 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 Mahmoud Declaration, and the record of any hearing on the Application before this Court establish just cause for the relief granted herein, (iii) Hadef is a "disinterested person," as defined in section 101(14) of the Bankruptcy Code, and (iv) Hadef 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 including a hearing held on
\_\_\_\_\_\_\_\_ 2025; 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 Hadef as his local counsel in the UAE pursuant to sections 327(e) and 330 of the Bankruptcy Code, effective as of April 11, 2025 on the terms set forth in the Application and the Mahmoud Declaration.
3. Hadef is authorized to act as the Chapter 11 Trustee's local counsel in the UAE, and to perform those services described in the Application.
4. The Estate shall be responsible for Hadef's compensation and reimbursement of expenses with respect to the engagement.
5. The allowance of any compensation to be paid to Hadef 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. Any disputes regarding compensation shall be determined solely by this Court.
6. Allowance of any compensation for Hadef shall be limited to the extent of services actually performed, and expenses actually incurred, as local 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 counsel.
7. For the avoidance of doubt, all matters related to the payment and allowance of Hadef's fees and expenses shall be decided by the Bankruptcy Court in accordance with the Bankruptcy Code. All other disputes that may arise out of the Chapter 11 Trustee's engagement are to be governed by the federal law of the UAE, as applied in the Emirate of Dubai or Abu Dhabi, as applicable, under the jurisdiction of the courts of Dubai or Abu Dhabi, as applicable, in accordance with the *Governing Law and Jurisdiction* section of Schedule 1 to Hadef's Engagement Letter.
8. Hadef 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.
9. The Chapter 11 Trustee is authorized and empowered to take all actions necessary to effectuate the relief granted in this Order.
10. The requirements of the Local Bankruptcy Rules are satisfied by the contents of the Application.
11. To the extent the Application, the Mahmoud Declaration, and the Engagement Letter are inconsistent with this Order, the terms of this Order shall govern.
12. The terms and conditions of this Order shall be immediately effective and enforceable upon its entry.
13. 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 4352 Filed 04/25/25 Entered 04/25/25 13:15:59 Page 15 of 50
## **EXHIBIT B**
**Engagement Letter**
# ماحف ويوس ويقاله Hadef & Partners
## By Email Only
24 April 2025
## Attn: Luc A. Despins, in His Capacity as Chapter 11 Trustee for the Estate of Ho Wan Kwok
Email: lucdespins@paulhastings.com
c/o Paul Hastings LLP 200 Park Avenue New York, New York United States
Dear Mr. Despins,
#### Re: Letter of Engagement between Hadef & Partners LLC and Luc A. Despins
#### Introduction A.
- 1. The purpose of this Letter of Engagement ("LOE") is to set out the terms of legal services between Hadef & Partners LLC (the "Firm") and Luc A. Despins, solely in his capacity as the chapter 11 trustee for the estate of Ho Wan Kwok (the "Client").
- 2. The following documents shall form the entire understanding and agreement between the subject of the engagement of the Firm by the Client:
- this LOE; and a)
- b) the Firm's Terms of Business ("TOB"), the current form of which appear in Schedule 1 to this letter.
#### в. Background to the Firm
3. Hadef & Partners is among the largest firms in the UAE, and one of the few with offices in both Dubai and Abu Dhabi. We are an independent, full service business law firm that specialises in commercial dispute resolution, as well as, banking and finance, projects, general corporate and commercial matters. Our team in Dubai is comprised of more than sixty lawyers who have predominantly practised in the UK, the US, Canada, Australia, South Africa and New Zealand, and a range of Middle Eastern jurisdictions. A number of our lawyers have practised at some of the largest and most prominent international law firms. Our team is fully bilingual in English and Arabic. We have a team of UAE qualified lawyers with rights of audience before the UAE Courts and lawyers who have rights of audience before the Dubai International Financial Centre Courts and Abu Dhabi Global Market Courts.
### Dubai
Hadef & Partners LLC Level 6, Building 3 Emaar Square, Downtown Dubai PO Box 37172, Dubal, UAE Tel +971 4 429 2999
### دبی
هادف وشركاوه ذ. م.م المستوى 0، المينى ٣. اعمار سكوير وسط مدينة دبي ص.ب. PVIVP, دبى, آ. ع.م +9V1 € EP9 ٢٩٩٩ : 410
ھاڪف ويتر ڪاھو Hadef & Partners
### C. Scope of Work
4. The Firm agrees to provide professional services to the Client, acting as trustee, in connection with the recovery of assets owned or beneficially owned by the chapter 11 debtor, Mr. Ho Wan Kwok, whose case is styled as In re Ho Wan Kwok, Case No. 22-50073 (JAM) (Bankr. D. Conn.) (the "Bankruptcy Case"), by the Honorable Judge Julie A. Manning of the United States Bankruptcy Court for the District of Connecticut (the "Bankruptcy Court").
The scope of services shall include, but is not limited to, the following:
- · Preparing a draft power of attorney ("POA") in English and/or in Arabic authorising us to act on behalf of the Client in relation to the matter and linking the POA with the court system;
- · Advising the Client on matters of UAE law as they relate to the bankruptcy proceedings;
- · Preparing reports, pleadings and other necessary filings before the UAE courts;
- · Communicating with creditors, debtors and other interested parties as necessary, and in particular communicating with financial institutions, third-party holders or other entities that have received or are holding funds on behalf of the debtor to recover estate assets; and
- · Preparing objections to disputed claims and assisting in related litigation before UAE Courts.
### Team and Structure of Fees D.
- 5. As per our TOB, our fees are charged per hour on a time spent basis. Any estimates provided herein are only indicative of our expected fees and disbursements and the actual fees charged could be less or more than the estimates.
- 6. Karim Mahmoud and Omar Al Heloo, Partners of the Firm, will have overall supervision and primary responsibility of the day-to-day conduct of these matters with the assistance of Farah Bou Nassar, Associate of the Firm, and the assistance of other members of the Firm if required.
- 7. The table below identifies the lawyers who are currently and who, it is envisaged, will remain involved handling these matters with their respective charge out rates:
| Name | Position | Rate per hour in USD
(excl. VAT) |
|------------------|-----------|-------------------------------------|
| Karim Mahmoud | Partner | USD 844 |
| Omar Al Heloo | Partner | USD 858 |
| Farah Bou Nassar | Associate | USD 463 |
8. Other members of the Firm may occasionally need to be involved depending on the progress of matters and/or if further assistance is required. Please note that the Firm will endeavour to keep the costs as low as possible. The range of hourly rates charged by fee earners of the Firm are as follows:
| Position | Hourly Rate in USD
(excl. VAT) |
|----------|-----------------------------------|
| Partner | USD 776-USD 1,021 |
www.hadefpartners.com
هادف وستر داؤن Hadef & Partners
| Senior Counsel / Head of
Department/ Senior Legal
Consultant | USD 694 - USD 749 |
|--------------------------------------------------------------------|-------------------|
| Senior Associate / Advocate | USD 599 - USD 681 |
| Associate / Advocate | USD 463 - USD 572 |
| Trainee | USD 327 - USD 368 |
| Paralegal | USD 272 - USD 408 |
9. The hourly rates of Partners, Associates or non-legal staff will be reflected on your monthly billing statement. The Firm's billing rates may be modified periodically - usually at the start of the calendar year.
### E. Disbursements
Please note that our hourly rates and any fee estimates given herein are exclusive of disbursements, such as, 9. for example, court fees, administration fees, courier charges, translation costs and expert witness' costs, unless stated otherwise.
### F. VAT
10. Please note further that on 1 January 2018, the UAE introduced VAT at 5%. All hourly rates, fee estimates given and disbursements are exclusive of VAT, which will be applicable in respect of these matters.
### G. Termination
11. The Client may terminate the Firm's engagement at any time with or without cause. If there is good reason which prevents the Firm from continuing to act for the Firm may terminate the engagement by giving the Client reasonable notice. In either case of termination of engagement, the Client shall be responsible for any expenses and legal fees incurred up to the date of termination, and for any further work required to facilitate an orderly transfer of matters in process. Failure to pay our fees or to provide monies on account is a good reason for us to terminate our engagement.
### Terms of Business H-
12. Our TOB together with this LOE represent the entire agreement between us. In the event of any conflict between the contents of this LOE and the TOB, the contents of this LOE shall prevail.
### Bankruptcy Matters 11-
- 13. The Firm's engagement is subject to the approval thereof by the Bankruptcy Court.
- 14. Notwithstanding anything herein (including Schedule 1 hereto) to the contrary, (a) payment of any fees and expenses in connection with this engagement shall be made as may be allowed by the Bankruptcy Court on proper applications in accordance with the procedures set forth in section 330 and 331 of Title United States Code (the "Bankruptcy Code") and the procedures established by the Bankruptcy Court, (b) time spent travelling shall be charged at 50% of the prevailing hourly rates, and (c) all matters related to the payment and allowance of fees and expenses in connection with this engagement, including any disputes regarding compensation, shall be decided by the Bankruptcy Court.
- 15. For the avoidance of doubt, neither Mr. Despins, in his personal capacity, nor Paul Hastings LLP shall be liable for compensation for services rendered or reimbursement of expenses.
هادف و سّتركاؤت Hadef & Partners
16. Notwithstanding anything herein (including Schedule 1 hereto) to the contrary, the Firm agrees not to take on engagements that would render it no longer disinterested under section 327(e) of the Bankruptcy Code
## J. Governing Law and Jurisdiction
17. Please refer to the Governing Law and Jurisdiction clause in our TOB, which is applicable to this LOE.
Please sign and date a copy of this letter to confirm our engagement and return one copy for our files.
Signed for and on behalf of Hadef & Partners LLC Abdulrahman Juma, Deputy Managing Partner / Advocate
Signed by Luc A. Despins, in His Capacity as Chapter 11 Trustee for the Estate of Ho Wan Kwok
هادف ويتركاؤه Hadef & Partners
# Schedule 1
www.hadefpartners.com
Abu Dhabi | Dubai
# هادف وسم واقع والف والام Hadet & Partners
## Terms of Business
The following terms apply to the provision of our professional services in respect of any existing and future instructions from you or any affiliate.
SERVICE: You will be allocated a partner or other senior lawyer who will be responsible for your matters and will coordinate with other lawyers in the firm to work on those matters as deemed appropriate. All new matters, queries and concerns should be directed to such partner or senior lawyer in the first instance.
AUTHORITY: Where instructions are received from any person purporting to act on your behalf, including any of your directors, employees, agents or other representatives, you will be deemed to have given such person the authority to issue such instructions to us on your behalf, and you acknowledge and agree that, in the course of our work, we may receive instructions from any and all such persons on your behalf. Instructions may be conveyed in writing, verbally or by conduct, and may be communicated in person, by way of email, telephone or by any other means.
ENGAGEMENT: Any instructions to engage us or commence work, whether from your directors, employees, agents or any other person contacting us on your behalf, will be acceptance by you of these terms.
KNOW YOUR CLIENT (KYC): We can, generally, only accept instructions and commence work for you after we have received the required, up to date 'Know Your Client' information. For these purposes, 'up to date' means confirmed by you, or your directors, employees, agents or any other person contacting us on your behalf, within the previous 12 months.
ANTI-MONEY LAUNDERING (AML): We are required, under applicable law, to undertake an AML risk analysis before accepting instructions. We reserve the right to process your personal and company data using international third-party verification services.
FEES: Our professional fees are generally calculated on a time-spent basis at hourly rates which vary according to experience, practice area and other relevant factors. Hourly rates are generally reviewed as of 1 January each calendar vear. The standard hourly rate bands which are current at the date of issue of these terms are set out in the Annex attached. Hourly rates for paralegals and other professional support depend on the type of work involved, and are also generally revised each 1 January. In respect of dispute work, our fees may be either assessed on a time-spent basis or occasionally on a fixed fee basis (to be determined in advance and calculated as an agreed amount, such as a percentage of the relevant claim). In certain circumstances, depending on the type, nature and scope of work, it may be possible for us to agree to charge a fixed or capped fee, subject to appropriate assumptions and qualifications (including provision for any fixed or capped fee to be revised to the extent that our scope of services changes or any assumption is not met), where the relevant deliverables are readily identifiable.
ADJUSTMENTS: We may, on exceptional occasions and on notice to you, apply adjustments where we believe that time spent is either not an appropriate measure of the value of our services in relation to the particular assignment, or the particular circumstances warrant an adjustment. This may depend, for example, on the nature of work, the complexity, importance, size or urgency of the intrinsic value of the service or knowhow provided.
دبدا
## Dubai
Hadef & Partners LLC Level 5, Building 3 Emaar Square, Downtown Dubal PO Box 37172, Dubai, UAE Tel +971 4 429 2999
هادف وشركاؤه ذ. م.م المستوى 0، الميتى ٣٠٦. اعمار سكوين وسط مدينة دب ص.ب. WVIVP, دبی, اُ.ع.م +9VIE EY9 1999: Lailo
هادف وسط ڪاوم Hadef & Partners
ESTIMATES: Where the scope of work and the elements comprising the work are clearly identifiable, we can, fi requested, provide an estimate of the likely fees in relation to a particular assignment based on relevant assumptions. We can also, if requested, and where approved upper limits to specific scopes of work or phases of work. However, it should be noted that it is not generally possible to estimate accurately, since various factors can have a significant effect on the time spent to conclude an assignment and may vary any estimate provided either marginally or significantly depending on the mature of such factors. Where we cannot or do not provide an estimate, for example because of the degree of uncertainty, we may (if requested) provide the hourly rate(s) (excluding taxes and expenses) of the person(s) likely to have conduct of your matter and, if appropriate, of others who may work on it. Alternatively, we may provide a range of fees representing the estimated minimum and maximum values, or estimated fees for the first or subsequent stages of the instruction.
DISBURSEMENTS: Disbursements, which are charged in addition to our professional fees, include items such as Ministry search fees, international telephone and fax charges, translation fees, notarisation and legalisation fees, government and court fees, travel and other business expenses, including in house bulk photocopying or printing.
PAYMENTS ON ACCOUNT: We generally require advance payment of part (or in some cases all) of the anticipated fees and disbursements prior to comment of work on a particular matter. We may also require additional advance payments as the matter progresses. Any such money paid to us on account will be held by us until an appropriate invoice is delivered to you in the case of fees (which may involve deduction only at the end of the matter) or until (by way of example) it is necessary to pay an expense or disbursement. We will be entitled to transfer monies held on your behalf from our Client Account in order to discharge outstanding fees arising as a result of invoices delivered to you or for expenses or disbursements incurred. Any balance of funds held by us, after settlement of all our invoices and any expenses or disbursements incurred, will be returned to you on completion of our engagement, unless otherwise agreed. We reserve the right to cease or suspend our services if such advance or interim invoice payments are not made in a timely manner. Please note that the total of our fees and disbursements in any matter is likely to exceed the aggregate of any such advances and interim invoice payments.
INVOICES: Our invoices, which include disbursements, are generally submitted monthly, in expectation of prompt payment, and in any case by no later than 30 days from the date of invoice. You are responsible for payment of our fees and disbursements in full regardless of whether or not there is an agreement or order which requires that a third party should pay them. Where a third party assumes responsibility for paying some or all of your costs, we will issue a tax invoice to you in the normal way as the recipient of our legal services. Any query must be raised within thirty days of receiving the invoice. Our firm is under no obligation to accept or act upon any such query received after 30 days from the date of receipt of the relevant invoice usually includes expenses and any other charges incurred for the relevant period. Expenses and charges that are not billed in the month in which they are incurred will be included in a subsequent invoice. We reserve the right to charge interest on overdue amounts without notice to you at a rate of 1% per calendar month or part thereof. In the event of non-payment, we may suspend our further services, while charging in full for all services and expenses incurred prior to or in connection with such suspension.
BANKING: We reserve the right to charge for amounts levied by banks in respect of your matters. We take no responsibility for any credit risk in relation to any bank.
TAXES, LEVIES AND DUTIES: Any estimate, fee, invoice, disbursement or other cost is exclusive of any tax, levy or duty. Value Added Tax (VAT) will be charged on all fees and disbursements as appropriate rate prevailing at the tax point on which an invoice is delivered. If you are registered for VAT in the UAE, we will supply to you, on request, copies of any disbursement invoices against which you may be able to reclaim the input VAT. Any request for zero VAT rating will be considered on a case by case basis. We will make the final determination with respect to VAT on our invoices, including the applicable VAT rate, based on the information provided by you, on which we are entitled to rely.
We are registered in the UAE for VAT and our registration number is 10035013820003.
FOREIGN EXCHANGE AND PAYMENTS: All payments to us must be made in UAE Dirhams (AED) unless we have agreed to render our invoices in USD in which case payment to us must be made in US Dollars (USD). We shall not
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Abu Dhabi | Dubai Page 2 of 7 هادف وسط ساداوه Hadef & Partners
be responsible for any exchange risk or differential, or any tax, levy or duty on any fee, invoice, disbursement or other cost, and you will reimburse us for the same.
CONFIDENTIALITY: In accordance with ethical standards applicable to our profession, we are committed to maintaining confidentiality, and do not disclose material details regarding our clients to third prior permission of the client (unless required by applicable law). However, in response to requests from professional publications, other clients and potential clients, we may provide names of clients and general descriptions of past transactions. We may also include such general information within proposals to prospective clients. We assume that we may disclose such general information, using our professional judgement at all times, unless we are notified by you, in writing, to the contrary.
RESPONSES TO AUDITORS: Where we are required by you to issue a letter in response to your auditor's request for information you consent to the disclosure of material details in respect of our engagement to your nominated auditors. We charge a fixed fee of AED 950 plus VAT, if applicable, for each letter that we issue in response to your auditors.
CONFLICTS: In the event that there is a transaction, matter or dispute which presents a conflict, or involving one or more parties who is/are our client(s), we may elect not to act, or may act only with the consent of appropriate parties.
INTELLECTUAL PROPERTY: We retain and own the intellectual property rights in all material provided to you or generated in connection with our services.
ELECTRONIC COMMUNICATIONS: In an effort to provide you with efficient service, we may communicate with you electronically. As you are aware, electronission is not always entirely secure. Accordingly, you will not hold us, or our fee earners, employees or representatives, responsible for any loss, liability or damage arising in connection with such communications.
ADVICE: We are qualified to advise on the laws of the United Arab Emirates and, in limited situations, other laws, for example the laws of England and Wales. We do not assume responsibility in respect of the laws or practices of other jurisdictions, and any advice provided relating to the same is based on relevant general knowledge, but should not be relied upon.
RESPONSIBILITY: Rights and obligations in respect of our engagement will be between Hadef & Partners LLC and you. We carry professional indemnity insurance with applicable regulations, details of which are provided to our regulator. Our partners, lawyers and our respective employees will not be personally liable in relation to any aspect of our engagement.
TERMINATION AND SUSPENSION OF WORK: You may terminate our engagement, or otherwise request that we suspend the provision of services to you on any matter(s), at any time by written notice to such effect. Likewise, we are entitled to terminate our engagement at any time upon written notice to you where we deem such termination reasonably necessary or appropriate (without prejudice to any right you may have in law to claim compensation as a result of such termination).
We reserve the right to immediately, and at any time, cease work for you on any matter to the extent hat we determine (in our reasonable discretion) that we are unable to continue working on such matter, including in circumstances where (a) you or any person connected with you in a relevant capacity is subject to sanctions imposed by any international, governmental or regulatory authority issues regulations which may expose us or any member of our team to sanctions or disciplinary action. In such event, we will notify you of our ceasing to work on the matter as soon as reasonably practicable, and issue our final invoice for fees and disbursements payable, calculated up to the date of cessation of work. Such final invediately payable by you. In case of any excess fees received as of such date, we shall endeavour to reimburse the excess to you within 30 days from the date of cessation of work.
For the avoidance of doubt, any termination, suspension, discontinuance or cessation of work (whether initiated by you or us in accordance with any provision of these terms) shall not affect your responsibility to pay for legal services and expenses rendered or incurred prior to the date and time of such termination, suspension, discontinuance or cessation, and for any further work necessarily undertaken by us connected to the orderly transfer of documents or work in progress.
هادفاروسوسور Hadef & Partners
We will not be liable to you or any of your affiliates in respect of any loss, liability, or other damage which may be incurred by you or any of your affiliates as a result of the suspension, discontinuance or cessation of work by us on any matter, in accordance with these terms.
PRIVACY: In the course of providing services to you, we may process your personal information and/or that of your employees or agents. Further details on our handling of personal information is set out in the attached Privacy Notice.
THIRD PARTIES: We shall only have responsibility towards you as our client. We shall have no liability in relation to services provided by third parties instructed by us. Our advice should not be disclosed to third parties without our prior written consent.
VARIATION: We reserve the right to revise our fee rates, modify our billing policies and/or vary these terms at any time, and we generally revise our rates as of 1 January each calendar year, as stated under "FEES" above. Notice of any revision, modification or variation may be provided in the normal course and/or shall be utilised to calculate invoices. Moreover, you also are entitled to request an update from us at any time. In any event, to the extent we provide services to you after any revision or variation has been made, the same shall be deemed to apply and to be mutually agreed. Please note that any revision to our fee rates will not affect any fixed or capped fee arrangements for any matter previously agreed in writing between you and us.
STATUS: We use the terms Hadef & Partners, "We" and "our" to refer to Hadef & Partners LLC, which is incorporated separately in each of Abu Dhabi and Dubai. Any reference to a partner means a director or shareholder, or manager, legal consultant or advocate of similar qualification, of Hadef & Partners LLC in Abu Dhabi or Dubai.
GOVERNING LAW AND JURISDICTION: The relationship between your affiliates, your personnel and representatives on one hand and Hadef & Partners LLC and its personnel and representatives on the other hand shall be governed by and construed in accordance with the federal laws of the United Arab Emirates ("UAE"), as applied in the Emirate of Dubai or Abu Dhabi, as applicable. Unless expressly agreed otherwise, the courts of Dubai (established pursuant to Dubai Law No. (3) of 1992 which was replaced and repealed by Dubai Law No. (13) of 2016) or the courts of Abu Dhabi (established pursuant to Abu Dhabi Law No. (2) of 2006, as amended) as applicable, shall have exclusive jurisdiction over any dispute, save in respect of unpaid fees and disbursements owed to Hadef & Partners LLC, arising out of or in connection with our services or these terms. In respect of any claim for unpaid fees and disbursements owed to Hadef & Partners LLC then we shall have the option, exercisable at our sole discretion, to commence legal proceedings in whatsoever jurisdiction we may deem appropriate, whether in UAE or elsewhere, including before the Dubai International Financial Centre Courts or the Abu Dhabi Global Market Courts. Save where prohibited by law, service of a Claim Form or other originating process issued by Hadef & Partners LLC in respect of any claim for unpaid fees and disbursements can be validly effected by sending the same by email address used by you in communicating to us.
## SIGNED ON BEHALF OF HADEF & PARTNERS LLC
Name: Abdulrahman Juma
Position: Deputy Managing Partner / Advocate
Signature:
Date: 02 January 2025
هادفوروسوریورون Hadef& Partners
### HADEF & PARTNERS' PRIVACY NOTICE
Hadef & Partners takes privacy and we respect the privacy of every client we provide services to (the "Services"). In order to effectively provide Services to you, Hadef & Partners needs to process some of your personal information.
Please note that the lists below are non-exhaustive and there may be other examples where we hold, collect, use or share your personal information in order to provide the Services.
### The personal information we may hold
As a client (or potential client) of Hadef & Partners we may hold the following categories of personal information about you (some of this information may be considered sensitive due to its nature):
information you provide when you become a client of the firm as required under Know Your Client and/or Anti Money Laundering regulations or practices, or otherwise, e.g. name, title, address, telephone number, email address, date of birth, passport information, Emirates ID number, nationality and financial information; and/or
information provided in the course of us providing the Services. This will depend on the nature of your instruction to Hadef & Partners, e.g. if you are a client of the employment department, this could include salary information.
### How we may collect your personal information
We may collect personal information about you:
directly;
from or as an adverse party;
from other professional advisers such as lawyers and accountants and/or governmental or regulatory authorities;
through our marketing communications, which may allow us to track your preferences and activity;
public sources; and/or
third parties.
### How we may use your personal information
It is in our legitimate interest to use your personal information to ensure we provide the Services. As a law firm we are also subject to legal, regulatory and professional indemnity obligations which require us to process your personal information, e.g. retain files after a matter has completed.
We may use the personal information we collect about you to:
set you up as a new client on our systems;
enable us to perform the Services effectively;
comply with legal or regulatory requirements;
market our Services and invite you to events; and/or
compile statistics.
### Sharing your personal information
We may need to share your personal information with third parties. Such third parties could include:
professional advisers such as lawyers and accountants and/or governmental or regulatory authorities;
third party professionals such as arbitrators, accountants, tax professionals, auditors, counsel, court workers, mediators, experts and translators; and/or
other third parties, e.g. in the course of organising an event.
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هادف سور سداراه Hadef & Partners
## Marketing communications
We may send you marketing communications in the form of emails in order to provide you with relevant legal insights or invite you to appropriate events. We do not sell or pass on your details to third party marketing companies. Our marketing communications may include tracker technology which allows us to understand the effectiveness of our communications.
We endeavour to ensure that any marketing communications sent to you are appropriate. When you are sent a marketing communication, you will be given the opportunity to unsubscribe from our mailing lists or change your preferences. In order to do this, you should follow the 'unsubscribe' link on the email. Alternatively you can change your preferences or unsubscribe by contacting us at dataprotection@hadefpartners.com.
## Transferring your personal information
The majority of our information is stored in the United Arab Emirates. In certain circumstances, we may transfer the personal information we collect about you to other jurisdictions. However, any such transfer shall not prejudice the data.
## Security of your personal information
We have security measures to protect your personal information. In addition, we limit access to your personal information to those employees, agents, contractors and other third parties on a business need-to-know basis. We have procedures to deal with any suspected data security breach.
## Retention of your personal information
We will retain relevant personal information for at least six years from the date of our last interaction with a client or for longer where we are required to do so according to our legal, regulatory or professional obligations
## Your rights in relation to your personal information
Under certain circumstances, you may have rights in relation to your personal information, e.g. access, correction and erasure. In this respect, please email us at dataprotection@hadefpartners.com with any queries about your rights.
## Data privacy team
We have a data privacy team to oversee compliance with this Privacy Notice. If you have any questions about this Privacy Notice or how we handle your personal information, please email us at dataprotection@hadefpartners.com.
هادف وتتركاؤە Hadef & Partners
## ANNEX
## HADEF & PARTNERS LLC CHARGE OUT RATE BANDS
## CURRENT AS AT 1 JANUARY 2025
| Fee Earner Level | Hourly Rate Range (USD) * | |
|------------------|---------------------------|--|
| Partner | USD 776-USD 1,021 | |
| Senior Counsel | USD 694 - USD 749 | |
| Senior Associate | USD 599 - USD 681 | |
| Associate | USD 463 - USD 572 | |
| Trainee | USD 327 - USD 368 | |
| Paralegal | USD 272 - USD 408 | |
\*Please note that higher individual hourly rates, beyond the standard rate band, may apply in certain circumstances, subject to prior written agreement.
Case 22-50073 Doc 4352 Filed 04/25/25 Entered 04/25/25 13:15:59 Page 28 of 50
# **EXHIBIT C**
**Mahmoud 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 KARIM H. MAHMOUD 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 HADEF & PARTNERS AS LOCAL COUNSEL IN UNITED ARAB EMIRATES**
I, Karim H. Mahmoud, being duly sworn, do depose and say:
1. I am US qualified lawyer and have been practicing law in the United Arab
Emirate (the "UAE") for over 10 years. I am a Partner at Hadef & Partners ("Hadef"), which is a leading full service UAE law firm founded by Dr. Hadef Al Dhaheri, the former Minister of Justice for the UAE, nearly 45 years ago - shortly after the UAE was initially formed. Hadef maintains an office at Level 5, Building 3, Emaar Square, Downtown Dubai, P.O. Box 37172, Dubai, UAE, and 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*
[1](#page-28-1) 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).
*and Approving Retention and Employment of Hadef & Partners as Local Counsel in United Arab Emirates* (the "Application")2 in connection with Hadef's retention as local 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, Hadef'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, Hadef will seek to recover its fees from the Estate, and I will file fee applications in the Chapter 11 Case on Hadef's behalf.
3. I graduated from Rutgers University (2009) and Brooklyn Law School (2013). In addition to my admissions to the New York Bar and the Dubai International Financial Center Court, I am registered with the Dubai Legal Affairs Department (2014) to practice in the UAE. I have extensive experience in litigation and enforcement matters in the UAE. I have also served as Special Master for the US District Court for the Northern District of Illinois.
4. Hadef 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.
5. Hadef will charge our hourly billing rates in connection with the Engagement. At present, the the 2025 hourly rate of Hadef is \$463 to \$1,021 for lawyers (plus 5% VAT), and \$272 to \$408 for paraprofessionals (plus 5% VAT). Hadef may also bill the Estate for any outof-pocket expenses made on behalf of the Chapter 11 Trustee, including photocopying, postage
[2](#page-29-1) Capitalized terms used but not otherwise defined have the meanings set forth in the Application.
and package deliveries, court fees, transcripts, witness fees, service fees, travel expenses, and computer-aided research, and translations.
6. To the best of my knowledge and belief after due inquiry, Hadef is a "disinterested person" within the meaning of section 101(14) of title 11 of the United States Code (the "Bankruptcy Code") in that Hadef 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 Hadef before my signing this Declaration that I am informed includes:
- a. parties listed as creditors, executory contract counterparties, and codebtors 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.
8. Hadef 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, Hadef does not have any relationship or connection with the Interested Parties, subject to the exceptions mentioned in **Schedule 2**, all of which relationships and connections are in connection with work unrelated to the Debtor.
9. While Hadef have made a diligent effort to ascertain the identity of any connections or potential conflicts with the Interested Parties, to the extent that any additional information comes to light, Hadef will review, disclose, and resolve any conflict or adverse interests that may appear.
10. Based on the foregoing, insofar as I have been able to ascertain based on the information currently available to me: (a) Hadef 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 Hadef nor its employees are creditors, equity security holders, or insiders of the Debtor or his affiliates, (ii) neither Hadef 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 Hadef 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 Hadef is a "disinterested person" within the meaning of section 101(14) of the Bankruptcy Code, as modified by section 1107(b).
11. 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.
12. 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 Hadef 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. Hadef 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.
13. Hadef 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.
14. 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 Hadef shall be limited to the extent of services actually performed, and expenses actually incurred, as local 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: April 23, 2025, at Abu Dhabi, United Arab Emirates
Karim H. Mahmoud
## **Schedule 1**
## **SCHEDULE OF PARTIES IN INTEREST – IN RE KWOK**
### **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 AKA JONATHAN HO YUE HUA ZHU SHI XIONG XIAN WEI YE HUIZEN WANG
### **DEBTOR, FAMILY MEMBERS, AND CERTAIN RELATED ENTITIES**
HO WAN KWOK (A.K.A MILES GWOK, MILES GUO AND WENGUI GUO) HING CH NGOK/YUE QINGZHI QIANG GUO (A.K.A. MILESON GUO) MEI GUO/MEI GUI HK INTERNATIONAL FUNDS INVESTMENTS (USA) LIMITED, LLC BRAVO LUCK LIMITED GENEVER HOLDINGS CORPORATION GENEVER HOLDINGS LLC
## **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
### **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 SA 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
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UK HIMALAYA LTD. UK IMPORT SERVICES LIMITED UNA MANYEE WILKINSON UNITED BANK UNITED STATES OF AMERICA UNITEDLEX UPDIKE, KELLY & SPELLACY P.C. URBAN LEGEND MEDIA, INC US HIMALAYA CAPITAL INC. US HIMALAYA LTD. V.X. CERDA & ASSOCIATES P.A. VALLEY NATIONAL BANK VANDENLOOM INC. VANTAGE WEST CREDIT UNION VERDOLINO & LOWEY VERITEXT VERSACE USA, INC. VFT SOLUTIONS INC. VICTOR CERDA VICTOR-OASIS CONSULTANCY LIMITED VISION KNIGHT CAPITAL (CHINA) FUND VOICE OF GUO MEDIA, INC. VX CERDA & ASSOCIATES WA & HF LLC WALLEX DIGITAL LLC WALLEX PAY LLC WALLEX TECHNOLOGIES PTE LTD. WANCI JIAO WANG'S REALTY MANAGEMEMT SERVICE INC. WARD & BERRY, PLLC WARREN LAW GROUP WARROOM BROADCASTING & MEDIA COMMUNICATIONS LLC WAYCAP S.P.A. WEATHERTEST COMPANY INC. WEBSTER FINANCIAL CORPORATION WEDDLE LAW PPLC WEDLAKE BELL LLP WEI HONG XIE WEI SHE WEI ZHANG WEICAN ("WATSON") MENG WEIGUO SUN WEIHUA LI WEIWEI QIAN WEIXIANG GE WEIYI WANG WELL ORIGIN LTD. WELLS FARGO BANK, N.A. WEN LIN WENCONG WANG WENFENG HU WENG WENHUA GONG WESTY'S STORAGE
WHITECROFT SHORE LIMITED WHITMAN BREED ABBOTT & MORGAN LLC WHOLE ALPHA TRADING LLC WILDES & WEINBERG, P.C. WILLIAM BRADLEY WENDEL WILLIAM GERTZ WILLIAM JE (JE KIN MING) WILLIAMS & CONNOLLY WILSON ELSER MOSKOWITZ EDELMAN & DICKER LLP WINGS INSURANCE AGENCY, INC. WISE CREATION INTERNATIONAL LIMITED WISE US, INC. WOLF HALDENSTEIN ADLER FREEMAN & HERZ LLP WOMBLE BOND DICKINSON (US) LLP WORLD CENTURY LIMITED, WORLDWIDE OPPORTUNITY HOLDINGS LIMITED WU ZHENG XIA CHUNFENG XIANHONG ZHANG XIAO HUANG XIAO RUI WANG XIAO YAN ZHU XIAOBO. HE XIAODAN WANG XIAOLAN ZHAO XIAOLI MA XIAOLI XU XIAOMEI ZHAO XIAOMING LIU XIAOXIAO LIN XIAOYAN BA XILI ZHAI XIN LI XINGYU YAN XINHUI LIAO XINRONG LI XIQUI ("BOB") FU XIULING TANG XUE WANG XUEBING WANG XUEHAI LIU XUN DENG YA LI YACHTZOO SARL YAFAN CHANG YAN CHUN LIU YAN GAO YAN HUANG YAN LIU YANCHENG CHEN YANG HAI YANG JUN ZHENG
YANG LAN
YANG YANG YANGPING WANG YANKWITT LLP YANMING WANG YANPING WANG YANPING YVETTE WANG YANYUN REN YAPING ZHANG YAZ QINGUA YELIANG XIA YI LI YI LIN YI WEN YI ZHAO YI ZHOU YIELDESTA L.P. YIMING ZHANG YING LIU YINYING WANG (A/K/A XIAO FEI XIANG) YONG CHUN LI YONG ZHANG YONGBING ZHANG YONGPING YAN (A/K/A SHAN MU) YOSSI ALMANI YOUTUBE, LLC YU XIA LI YUAN ZHOU YUANLIN LIU YUE HUA ZHU SHI YUE ZHOU YUECHEN LAN YUHONG PEI YUJIA WANG YUK MOEY MARY YAP YUKY YUN LIU YULIN YAQ YUMEI HU YUNFA WANG YUNFU JIANG YUNTENG LU YUNXIA WU YUQIANG QIN YUXIANG CHEN & JIA YOU JT TEN YVETTE WANG ZEICHNER ELLMAN & KRAUSE LLP ZEISLER & ZEISLER, P.C. ZENDESK INC ZETA GLOBAL CORP. ZHANG LIN ZHANG WEI ZHENG RUI HE ZHENG WU (A/K/A BRUNO WA) ZHENGHUA SHEN ZHENGJUN DONG ZHENPENG LI ZHIXUAM LI
ZHIXUAN LI ZHIZHE "FRANK" DONG ZHONGYI MA ZHOU BAOJIN ZHOU HAI YANG ZHUOER "JOE" WANG
ZI YE ZIBA LIMITED ZIHAN LIU ZIKUN WANG ZYB & ASSOCIATES, LLC Case 22-50073 Doc 4352 Filed 04/25/25 Entered 04/25/25 13:15:59 Page 49 of 50
**PH DRAFT PRIVILEGED AND CONFIDENTIAL**
**Schedule 2**
# **Parties-in-Interest Related or Connected to Hadef & Partners in Connection with Matters Unrelated to the Debtor**
AMAZON.COM INC. AMERICAN EXPRESS COMPANY APPLE INC. BANK OF CHINA – NEW YORK BRANCH AND/OR BANK OF CHINA LIMITED BANK OF MONTREAL BARCLAYS BANK PLC BOIES SCHILLER FLEXNER LLP BROWN RUDNICK, LLP CITIBANK CROWELL & MORING LLP DBS BANK LTD. DLA PIPER LLP (US) DWF LLP ERNST & YOUNG LLP FIRST ABU DHABI BANK FIRST REPUBLIC BANK GREENBERG TRAURIG, LLP HOGAN LOVELLS INTERNATIONAL LLP K&L GATES LLP KIRKLAND & ELLIS LLP KROLL, LLC LORO PIANA S.P.A. MISHCON DE REYA LLP MORGAN STANLEY O'MELVENY & MYERS LLP OGIER PILLSBURY WINTHROP SHAW PITTMAN LLP PRAGER DREIFUSS AG SIDLEY AUSTIN LLP STANDARD CHARTERED BANK STEPTOE LLP UBS AG UBS AG (LONDON BRANCH) WELLS FARGO BANK, N.A. WILSON ELSER MOSKOWITZ EDELMAN & DICKER LLP WOMBLE BOND DICKINSON (US) LLP