郭文贵破产案 · ORDER · ECF #4384

# **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 | |

# **APPLICATION OF CHAPTER 11 TRUSTEE FOR ENTRY OF ORDER, PURSUANT TO BANKRUPTCY CODE SECTIONS 327 AND 330, BANKRUPTCY RULES 2014 AND 2016, AND LOCAL BANKRUPTCY RULES 2014-1 AND 2016-1, AUTHORIZING AND APPROVING RETENTION AND EMPLOYMENT OF MARXER & PARTNER RECHTSANWÄLTE AS LIECHTENSTEIN LAW COUNSEL**

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 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") approving the

Chapter 11 Trustee's employment of Marxer & Partner Rechtsanwälte ("Marxer") as

Liechtenstein law counsel, effective as of March 26, 2025, on the terms set forth in 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 the Genever Holdings Corporation is Paul Hastings LLP, 200 Park Avenue, New York, NY 10166 c/o Luc A. Despins, as Trustee for the Estate of Ho Wan Kwok (solely for purposes of notices and communications).

engagement letter attached hereto as **Exhibit B** (the "Engagement Letter"). In support of this Application, the Chapter 11 Trustee submits the *Declaration of Jochen Schreiber in Support of Application of Chapter 11 Trustee for Entry of Order, Pursuant to Bankruptcy Code Sections 327 and 330, Bankruptcy Rules 2014 and 2016, and Local Bankruptcy Rules 2014-1 and 2016-1, Authorizing and Approving Retention and Employment of Marxer & Partner Rechtsanwälte as Liechtenstein Law Counsel* (the "Schreiber Declaration"), attached as **Exhibit C**, which is incorporated herein by reference. In further support of this Application, the Chapter 11 Trustee respectfully states as follows:

#### **RELIEF REQUESTED**

1. In the course of the Trustee's investigation in Switzerland (including as to assets nominally owned by his son), the Trustee has learned that certain assets may also be located in Liechtenstein.2 The Trustee seeks to retain a Liechtenstein law firm to further investigate these matters and to potentially seek relief in Liechtenstein court in this regard. The Chapter 11 Trustee selected Marxer as his counsel based on Marxer's familiarity with financial investigations and litigation in Lichtenstein.

2. By this Application, the Chapter 11 Trustee seeks entry of the Proposed Order, authorizing and approving the retention and employment of Marxer as the Chapter 11 Trustee's Liechtenstein law counsel, effective as of March 26, 2025, on the terms set forth in the Engagement Letter.

² In the interest of maintain confidentiality regarding the ongoing investigation and litigation efforts, the Trustee will not disclose further details regarding the assets at issue.

#### **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(a) 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].

#### **MARXER'S QUALIFICATIONS**

10. Marxer is a law firm located Heiligkreuz 6, 9490 Vaduz, Liechtenstein. Marxer is a well-regarded Liechtenstein law firm which practices in a range of commercial and business

law areas. The firm currently employs approximately 30 lawyers, who are assisted by paralegals and support staff.

11. Marxer has expertise in practice areas including corporate law, insolvency, as well as complex commercial litigation and arbitration. Marxer's broad law practices span a range of legal services in Liechtenstein.

## **ANTICIPATED SERVICES**

12. The Chapter 11 Trustee anticipates that Marxer will assist him with his efforts to investigate and potentially seize assets in Liechtenstein. Due to the specialized nature of Marxer role as Liechtenstein law counsel, there will be no duplication of services arising from Marxer's retention.

#### **COMPENSATION OF MARXER**

13. Marxer 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, including the *Order Establishing Procedures for Interim Compensation and Reimbursement of Expenses for Retained Professionals* (as such order may be amended, the "Interim Compensation Order").

14. Marxer will charge the Debtor for its legal services on an hourly basis at its regularly applicable hourly rates in connection with the services required in connection with the Trustee's investigations.

15. At present, the 2025 hourly rates of Marxer are between CHF 450 and CHF 625 for associates (which, at current exchange rates, converts into approximately \$525 to \$730) and

CHF 700 for partners (which, at current exchange rates, converts into approximately \$815). Marxer will also charge a flat fee for internal administrative expense equal to 2% of the total hourly fees charged.3 Notwithstanding the foregoing, Marxer will bill separately for expenses with respect to services provided by third party vendors, including local process servers, court and other registration fees, local investigators, travel expenses, and courier fees, will be charged separately.

16. Marxer has requested, and the Chapter 11 Trustee hereby seeks authorization, that Marxer be allowed to invoice its fees and expenses in Swiss Francs (CHF) and to have such fees and expenses paid in Swiss Francs (CHF), subject to the terms of the Interim Compensation Order.

17. The Debtor submits that Marxer's hourly rates are reasonable, comparable to Marxer's hourly rates for other engagements, and within the range of rates charged by comparably skilled professionals who offer the same services.

18. While all matters related to the payment and allowance of Marxer's fees and expenses will be determined by the Bankruptcy Court, as detailed in the Engagement Letter, disputes arising from or in connection with, the Engagement Letter will be resolved by the courts of Liechtenstein pursuant to Liechtenstein substantive law under exclusion of provisions of International Private Law.

#### **MARXER IS DISINTERESTED**

19. To the best of the Chapter 11 Trustee's knowledge in reliance upon the Schreiber Declaration, and except as disclosed therein, Marxer does not have any relationships with the

³ Marxer does not maintain internal processes that would allow it to track its administrative expenses, such as photocopying, printing, etc.

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.

20. More specifically, upon the basis of the Schreiber Declaration, and except as disclosed therein, the Chapter 11 Trustee believes that: (a) Marxer 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) Marxer 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) has 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 Marxer is a "disinterested person" within the meaning of section 101(14) of the Bankruptcy Code, as modified by section 1107(b).

21. Based on the Schreiber Declaration, the Chapter 11 Trustee believes that Marxer does not represent any adverse interest to unsecured creditors in connection with the Chapter 11 Case.

#### **BASIS FOR RELIEF REQUESTED**

22. The Chapter 11 Trustee requests to retain and employ Marxer as his Liechtenstein counsel pursuant to section 327(a) of the Bankruptcy Code, which provides that a trustee, subject to the approval of the Court, may employ professional persons "that do not hold or represent an interest adverse to the estate, and that are disinterested persons, to represent or assist the trustee in carrying out the trustee's duties under this title."

23. 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.

24. The Chapter 11 Trustee requires the services of counsel in Liechtenstein to exercise his responsibilities. Marxer will endeavor to avoid the duplication of efforts and provide services as efficiently as possible.

25. Accordingly, the employment of Marxer as the Chapter 11 Trustee's

Liechtenstein counsel, upon the terms set forth herein and in the Proposed Order, is reasonable and in the best interest of the Debtor's estate.

26. The Chapter 11 Trustee submits that Marxer'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.

27. 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." Accordingly, the Chapter 11 Trustee requests authority to retain and employ Marxer effective as of March 26, 2025, which was the date that Marxer began providing services to the Chapter 11 Trustee.4

⁴ While March 26, 2025 is 41 days prior to the filing of this Application, the Trustee requests that the Court approve the retention as of such date.

#### **NOTICE**

28. 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**

29. 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 Marxer as Liechtenstein law counsel, and order such other and further relief as the Court deems just and proper.

Dated: May 6, 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: | :<br>:<br>Chapter 11 | | HO WAN KWOK, et al., | :<br>:<br>Case No. 22-50073 (JAM) | | Debtors.5 | :<br>:<br>Jointly Administered<br>: | | ------------------------------------------------------ | x |

## **CERTIFICATE OF SERVICE**

The undersigned hereby certifies that on the date hereof, the foregoing Motion 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. Parties may

access this filing through the Court's CM/ECF system.

Dated: May 6, 2025 New York, New York

> By: */s/ G. Alexander Bongartz* G. Alexander Bongartz (admitted *pro hac vice*) PAUL HASTINGS LLP 200 Park Avenue New York, New York 10166 (212) 318-6000 alexbongartz@paulhastings.com

*Counsel for the Chapter 11 Trustee*

⁵ The Debtors in these chapter 11 cases are Ho Wan Kwok (also known as Guo Wengui, Miles Guo, and Miles Kwok, as well as numerous other aliases) (last four digits of tax identification number: 9595), Genever Holdings LLC (last four digits of tax identification number: 8202) and Genever Holdings Corporation. The mailing address for the Trustee, Genever Holdings LLC, and the Genever Holdings Corporation is Paul Hastings LLP, 200 Park Avenue, New York, NY 10166 c/o Luc A. Despins, as Trustee for the Estate of Ho Wan Kwok (solely for purposes of notices and communications).

# **Exhibit A**

**Proposed Order**

# **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 | |

# **[PROPOSED] ORDER (A) GRANTING APPLICATION OF CHAPTER 11 TRUSTEE FOR ENTRY OF ORDER, PURSUANT TO BANKRUPTCY CODE SECTIONS 327 AND 330, BANKRUPTCY RULES 2014 AND 2016, AND LOCAL BANKRUPTCY RULES 2014-1 AND 2016-1, AUTHORIZING AND APPROVING RETENTION AND EMPLOYMENT OF MARXER & PARTNER RECHTSANWÄLTE AS LIECHTENSTEIN LAW COUNSEL**

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 Marxer & Partner Rechtsanwälte ("Marxer"), as Liechtenstein law counsel, effective as of March 26, 2025, pursuant to sections 327 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 Schreiber Declaration

upon consideration of the Application and the Schreiber 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 Schreiber Declaration, and the record of any hearing on the Application before this Court establish just cause for the relief granted herein, (iii) Marxer is a "disinterested person," as defined in section 101(14) of the Bankruptcy Code, and (iv) Marxer 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 Marxer as his Liechtenstein law counsel pursuant to sections 327(a) and 330 of the Bankruptcy Code, effective as of March 26, 2025 on the terms set forth in the Application and the Schreiber Declaration.

3. Marxer is authorized to act as the Chapter 11 Trustee's Liechtenstein law counsel, and to perform those services described in the Application.

4. The Estate shall be responsible for Marxer's compensation and reimbursement of expenses with respect to the engagement.

5. The allowance of any compensation to be paid to Marxer 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 Marxer shall be limited to the extent of services actually performed as 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. Marxer shall also be entitled to (a) a flat fee for disbursements in an amount equal to 2% of total fees charged and (b) reimbursement of reasonable and documented expenses with respect to services provided by third party vendors, including local process servers, court and other registration fees, local investigators, travel expenses, and courier fees (if any).

7. Marxer is authorized to invoice its fees and expenses in Swiss Francs (CHF) and to have such fees and expenses paid in Swiss Francs (CHF), subject to the terms of the Interim Compensation Order. The payment in Swiss Francs (CHF) shall be converted from US Dollars into Swiss Francs (CHF) at the exchange rate prevailing on the date of payment.

8. For the avoidance of doubt, all matters related to the payment and allowance of Marxer'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 Liechtenstein substantive law, under exclusion of provisions of

International Private Law, and to be determined in accordance with section 11 of the General Terms and Conditions to Marxer's Engagement Letter.

9. Marxer 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.

10. The Chapter 11 Trustee is authorized and empowered to take all actions necessary to effectuate the relief granted in this Order.

11. The requirements of the Local Bankruptcy Rules are satisfied by the contents of the Application.

12. To the extent the Application, the Schreiber Declaration, and the Engagement Letter are inconsistent with this Order, the terms of this Order shall govern.

13. The terms and conditions of this Order shall be immediately effective and enforceable upon its entry.

14. This Court shall retain jurisdiction with respect to all matters arising from or related to the implementation, interpretation, and enforcement of this Order.

# **Exhibit B**

**Engagement Letter**

#### VIA E-MAIL

Luc A. Despins, solely in his capacity as the chapter 11 trustee for the estate of Ho Wan Kwok c/o Paul Hastings LLP 200 Park Avenue New York, NY 10166

Vaduz, 17 April 2025

#### Engagement Letter

Dear Client,

We thank you, Luc A. Despins in your capacity as the chapter 11 trustee for the estate of Ho Wan Kwok (the "Client"), for engaging our firm. As agreed, we provide you below with our terms of engagement.

This letter and our General Terms of Business, which are attached hereto, are intended to set out the basis on which we will act on your behalf and will govern the arrangements between us.

In the event of any inconsistency between our General Terms of Business and this letter, the terms of this letter shall prevail.

Partner: Dr. Johannes Michael Burger Dr. Robert Schneider (t) Dr. Michael Grabher, LLM. Dr. Michael Oberhuber, LL.M. Dr. Stefan Wenaweser, LL.M. Dr. Markus Summer, LL.M., MBA Dr. Armin Dobler, LL.M. Dr. Mario A. König, LL.M. Mag. Jochen Schreiber Dr. Florian Marxer, LL M. Dr. Daniel Damjanovic, LL.M. Dr. Hasan Inetas, LL.M. Mag. Sonja Schwaighofer, LL.M. Mag. Franziska Goop-Monauni, LL.M. Dr. Christian Ritzberger, M.A. HSG

Konsulent lic. iur. Jesús Cortés, M.B.L. .- HSG

Juristische Mitarbeiter: Laura Negele-Vogt, MLaw Mag. Martin Pardeller Dr. Thomas Feurstein lic. iur. Dieter Roth, CAS Dr. Edgar Seipelt, M.Sc. Dr. Maximilian Dejaco Mag. Rudolf Kitz, LLM. Dr. Sascha Brunner Mag. Robert Ofensberger Mag. Florian Zerz Katharina Hasler, MLaw Mag. Antonia Wittwer-Tschohl Dr. Dominique Seger, LLM. Dr. Julia Köpf Dr. Michael Pierzl. BSc LLB Mag. Felix Vogt Dr. Lukas Burger Mag. Fabio Chesani

Of Counsel: Dr. Peter Goop Dr. Peter Marxer, LL.M. Dr. Herbert Oberhuber

## 1. Purpose of this Letter

This letter sets out the terms of our engagement for this matter and incorporates our General Terms of Business.

# 2. Scope of Engagement

You have been appointed as the Chapter 11 trustee (the "Chapter 11 Trustee") for the estate of the principal debtor, Ho Wan Kwok (alias "Wengui Guo" alias "Miles Guo") (the "Debtor"). In your capacity as the Chapter 11 Trustee,



To secure possible assets located in Liechtenstein

. In addition, the

Trustee may discover other assets located in Liechtenstein which the Trustee may seek to recover for the benefit of the Debtor's creditors. For these reasons and purpose, you wish us to render legal advice and court representation as far as Liechtenstein law and Liechtenstein courts are concerned.

We will assist you, as set out below:

# 2.1 Preparation and filing of a seizure application


#### 2.3 Other proceedings

We will prepare and file other actions related to potential other assets located in Liechtenstein owned by the Debtor

#### 2.4 Related advice

We will render advice according to your instructions related to the above.

#### 3. Conflict Clearance

On the basis of the facts known to us we have run a conflict-of-interest check and confirm that there is at present, to our knowledge, no conflict of interest. Should such conflict of interest arise at a later stage, or should such conflict become apparent in the course of our-relationship because of facts not properly foreseeable at this point in time, we shall consult with you in order to find a mutually and ethically acceptable solution.

# 4. Responsibility for our Engagement

Your primary contact for this matter will be Mag. Jochen Schreiber, partner of our firm and head of the litigation team. He will be supported by Dr. Edgar Seipelt, as well as other lawyers of appropriate seniority.

## 5. Fees, Disbursements

Based on the scope of engagement and the assumptions listed above, any work will be charged at the following hourly rates:

| Partner | CHF 700 | |----------------------|---------| | Senior Associates | CHF 625 | | Mid-Level Associates | CHF 550 | | Junior Associates | CHF 450 | | Trainees, Paralegals | CHF 250 |

The hourly rates include secretaries' work.

Ordinary minor and ongoing internal administrative expenses, e.g. for communication, our files, insurance etc., will be covered by a flat 2 % surcharge. Other reasonable and documented expenses with respect to services provided by third party vendors, including local process servers, court and other registration fees, local investigators, travel expenses, and courier fees, will be charged separately.

Our fees are generally subject to Liechtenstein value-added tax at a rate of currently 8.1%. Value-added tax does, however, not apply when invoicing to a jurisdiction outside of Liechtenstein or Switzerland.

Once we know the details of the submissions, particularly the value in dispute, we will advise on the possibility to agree on alternative fees based on the Liechtenstein legal tariff. Any costs awards issued by the courts in your favour will be calculated pursuant to this tariff.

# 6. Bankruptcy Matters

Our firm's engagement is subject to the approval thereof by the Bankruptcy Court.

Notwithstanding anything herein or the Terms of Business to the contrary, (a) payment of any fees and expenses in connection with this engagement shall be made in such

amounts 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 11 of the 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. There shall be no retainer or advancement of fees or expenses in connection with this engagement.

Notwithstanding anything in Section 7 of the Terms of Business to the contrary, our liability for any damages caused in connection with our services provided is limited to the amount of CHF 5,000,000 (in words: five million Swiss francs).

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.

Notwithstanding anything herein (including the Terms of Business) 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.

# 7. Terms of Business and Power of Attorney

The attached Terms of Business form an integral part of this engagement letter.

Furthermore, please find enclosed hereto our standard power of attorney which shall be signed by the Client which will authorize us to act on behalf of the Client before court.

We hope to have comprehensively set out the terms of engagement. Your continued instructions constitute acceptance of these terms, but it would help our records if you would kindly date, initial (each page), sign and return the attached copy of this letter.

Should you have any further questions, please do not hesitate to contact us.

We thank you for your trust in us and are looking forward to a successful cooperation.

Yours sincerely Marxer & Partner Attorneys-at-Law

Mag. Jochen Schreiber

We hereby agree to the terms of the letter set out above:

1 1 Date: Place: \_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_

Luc A. Despins, solely in his capacity as the chapter 11 trustee for the estate of Ho Wan Kwok

signature

# **Exhibit C**

## **Schreiber Declaration**

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

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

# **DECLARATION OF JOCHEN SCHREIBER IN SUPPORT OF APPLICATION OF CHAPTER 11 TRUSTEE FOR ENTRY OF ORDER, PURSUANT TO BANKRUPTCY CODE SECTIONS 327 AND 330, BANKRUPTCY RULES 2014 AND 2016, AND LOCAL BANKRUPTCY RULES 2014-1 AND 2016-1, AUTHORIZING AND APPROVING RETENTION AND EMPLOYMENT OF MARXER & PARTNER RECHTSANWÄLTE AS LIECHTENSTEIN LAW COUNSEL**

I, Jochen Schreiber, being duly sworn, do depose and say:

1. I am a qualified lawyer under Liechtenstein law and enrolled before the

Liechtenstein bar as a licensed attorney. I am a Partner at Marxer & Partner Rechtsanwälte

("Marxer"), which is a law firm that maintains its office at Heiligkreuz 6, 9490 Vaduz,

Liechtenstein, 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 and 330,*

*Bankruptcy Rules 2014 and 2016, and Local Bankruptcy Rules 2014-1 and 2016-1, Authorizing*

*and Approving Retention and Employment of Marxer & Partner Rechtsanwälte as Liechtenstein*

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).

*Law Counsel* (the "Application")² in connection with Marxer's retention as Liechtenstein law counsel, and related matters (the "Engagement").

2. In relation to the Engagement, Marxer's professional client is the estate (the "Estate") of Ho Wan Kwok (the "Debtor") in his above-captioned chapter 11 case (the "Chapter 11 Case"). In relation to the Engagement, Marxer will seek to recover Marxer's fees from the Estate, and I will file fee applications in the Chapter 11 Case on Marxer's behalf.

3. I attended the University of Salzburg where I received my degree in law in 1997. I passed the bar exam in Austria in 2003 and in Liechtenstein in 2006. I was made a Partner at Marxer in 2009. Additionally, since August 2024 I am heading the litigation team. My experience encompasses, among other things, corporate matters, insolvency, as well as complex commercial litigation and arbitration, including a wide experience in enforcement of securities.

4. Marxer 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. Marxer will charge our hourly billing rates in connection with the Engagement. At present, the the 2025 hourly rate of Marxer are between CHF 450 and CHF 625 for associates (which, at current exchange rates, converts into approximately \$525 to \$730) and CHF 700 for partners (which, at current exchange rates, converts into approximately \$815). Marxer will also charge a flat fee for disbursements made on behalf of the Trustee, which flat fee amounts will be equal to 3% of the total fees charged. As is the practice for most Liechtenstein law firms, Marxer does not have internal processes in place for tracking administrative expenses made on

² Capitalized terms used but not otherwise defined have the meanings set forth in the Application.

behalf of the Trustee, such as photocopying, postage, and package deliveries. Therefore, Marxer will instead charge a flat fee for disbursements, which flat fee will be equal to 3% of the total fees charged in connection with its legal services. Marxer will also bill separately certain other expenses made on behalf of the Trustee, including courier fees.

6. To the best of my knowledge and belief after due inquiry, Marxer is a "disinterested person" within the meaning of section 101(14) of title 11 of the United States Code (the "Bankruptcy Code") in that Marxer 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 Marxer 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. Marxer 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, Marxer does not have any relationship or connection with the Interested Parties, subject to the exceptions mentioned in **Schedule 2**. Marxer confirms that the connections mentioned in Schedule 2 were and are unrelated to the Debtor, Qiang Guo (a.k.a Mileson Guo) or the Chapter 11 Case.

9. While Marxer has 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, Marxer 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) Marxer 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 Marxer nor its employees are creditors, equity security holders, or insiders of the Debtor or his affiliates, (ii) neither Marxer 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 Marxer 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 Marxer 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 Marxer 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. Marxer 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. Marxer 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 Marxer shall be limited to the extent of services actually performed, and expenses actually incurred, as 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.

15. As is standard for engagement of Liechtenstein law firms, any disputes and claims arising from or in connection with the engagement letter between the Trustee and Marxer in connection with Marxer's retention, including the validity, invalidity, breach or termination thereof, will be subject to Liechtenstein substantive law under exclusion of provisions of International Private Law; provided, however, that all matters related to the payment and allowance of Marxer's fees and expenses shall be determined by the bankruptcy court.

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: May 2, 2025, at Vaduz, Liechtenstein

Jochen Schreiber

# **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 EXAMINATIONS, LLC ANN MARIE LEE ANTHEM HEALTH PLANS, INC. ANTHONY DIBATTISTA ANTON DEVELOPMENT LIMITED APPLE INC. APPSFLYER INC APSLEY YACHTS LIMITED ARETHUSA FORSYTH ARI CASPER ARNALL GOLDEN GREGORY LLP ARNOLD & PORTER KAYE SCHOLER LLP ARRI AMERICAS INC. ART WOLFE, INC. ASAP SRL ASCENTIQ SOLUTIONS LIMITED ASSETS SINO LIMITED AUSPICIOUS COAST LIMITED AVIATION E LLP AVIATION TRUST COMPANY LLC AVIVA PLC AXOS BANK AXOS FINANCIAL, INC. B&H FOTO & ELECTRONICS CORP. BAC CAPITAL LLC BAIQIAO TANG A/K/A TANG BAIQIAO BAKER HOSTETLER LLP BANCO POPULAR DE PUERTORICO BANK OF AMERICA BANK OF CHINA – NEW YORK BRANCH AND/OR BANK OF CHINA LIMITED BANK OF MONTREAL BANK OF THE WEST BANNON STRATEGIC ADVISORS, INC. BARCLAY DAMON LLP BARCLAYS BANK PLC BEIJING BI HAI GE LIN YUAN LIN LU HUA, LTD. BEIJING CHENG JIAN WU JIAN SHE GROUP, LTD. BEIJING FU LE HONG MA JIAN ZHU ZHUANG SHI GONG CHENG, LTD. BEIJING PANGU INVESTMENT CO. BEIJING ZENITH HOLDINGS CO. BEIJING ZHONG XIAN WEI YE STAINLESS DECORATION CENTER BEILE LI BELLERIVE ATTORNEYS AT LAW

BENHAR OFFICE INTERIORS LLC BENTO TECHNOLOGIES, INC. BERING YACHTS, LLC BERKELEY ROWE LIMITED BERNARDO ENRIQUEZ BESTVIEW1 PTY LTD BINGNAN CUI BINGSHANG JIAO BIRCHSTONE CAPITAL AG BLACKTHORN FINANCEN INC. BLUE CAPITAL BLUEBERRY BUILDERS, LLC BNY MELLON, N.A. BOARDWALK MOTOR IMPORTS, LLC BOFANG INVESTMENT LLC BOHONNON LAW FIRM BOIES SCHILLER FLEXNER LLP BONNIE C. MANGAN BOOMING SAIL NEW YORK LLC BOUILLOR HOLDINGS LIMITED BOXUN INC. BRANCH BRAVO LUCK LIMITED BRENT PETRO INC. BRIAN HOFMEISTER BROWN HARRIS STEVENS BROWN RUDNICK, LLP BRUNE LAW PC BSA STRATEGIC FUND BSA STRATEGIC FUND I BSI GROUP LLC BUCK, ESQ. LLC BURNETTE SHUTT AND MCDANIEL PA CAHILL GORDON & REINDEL LLP CAIYAN LING CALLSIGN LTD CAMERON SMEE CANADIAN IMPERIAL BANK OF COMMERCE CAPITAL ONE BANK CAPITAL ONE, NA CARIBE CONDADO, LLC CARMODY TORRANCE SANDAK & HENNESSEY LLP CAYUSE GOVERNMENT SERVICES, LLC CEDRIC DUPONT ANTIQUES CELESTIAL TIDE LIMITED CESARE ATTOLINI NY LLC CFG GLOBAL LIMITED CHAO KANG SUN CHAO-CHIH CHIU CHARLES SCHWAB CHARMOY & CHARMOY LLC

CHASE BANK CHEN XIN XIN CHENGLONG WANG CHENXI WANG CHI WAI KWOK CHIESA SHAHINIAN & GIANTOMASI PC CHINA CITIC BANK INT'L CHINA GOLDEN SPRING GROUP (HONG KONG) LIMITED CHOICE FINANCIAL BANK CHONG SHEN RAPHANELLA CHRIS LEE (A/K/A NAN LI, CHRIS LI, MEI GUO XIAO LI) CHRISTIE'S INTERNATIONAL REAL ESTATE NEW CHRISTINE CHEN CHRISTINE FROSINI CHRISTODOULOS G. VASSILIADES & CO. LLC CHUAN LING YANG CHUANG XIN LTD. CHUI KUK WU CHUNFENG XIA CHUNGUANG HAN CHUNHUI SONG CI CHEN CIBC INC. (D/B/A CIBC) CIMB BANK BERHAD A/K/A CIMB ISLAMIC BANK BERHAD CINDY ZHANG CIRRUS DESIGN CORPORATION (D/B/A CIRRUS AIRCRAFT) CIRRUS INDUSTRIES, INC. CITIBANK CITIZENS FINANCIAL GROUP, INC. CITY NATIONAL BANK CLARK HILL PLC CLAYMAN & ROSENBERG LLP CLAYMAN ROSENBERG KIRSHNER & LINDER LLP CLEAR TREASURY (UK TRADING) LIMITED CLEAR TREASURY LIMITED CLOUDFLARE, INC. COHN BIRNBAUM & SHEA P.C. COLDWELL BANKER COLE SCHOTZ P. C. COMERICA INCORPORATED (D/B/A COMERICA BANK) COMMUNITY FEDERAL SAVINGS BANK COMPASS, INC. CONSERVATIVE CAMPAIGN TECHNOLOGY, LLC COTTON CRAFT TEXTILES INTL TRADING

COUNSEL PRESS INC. COWDERY, MURPHY & HEALY, LLC CRANE ADVISORY GROUP LLC CREATIVE APEX INVESTMENTS LIMITED CREDIT AGRICOLE CIB CORP. CROCKER MANSION ESTATE LLC CROWELL & MORING LLP CRYSTAL BREEZE INVESTMENTS LIMITED CUI ZHU LI CUMMINGS & LOCKWOOD, LLC CURIOSITY CORP. LLC CYBERAPT RECRUITMENT LTD D&D SOLUTIONS LLC D.P. TEXTILE & APPAREL, INC. D4ZERO S.R.L. DAIHO ZHOU DANIEL PODHASKIE DANIEL S. ALTER DANYU LIN DARK SHADOWS LLC DAVID FALLON DAWN STATE LIMITED DBS BANK LTD. DEAN M. RABIDEAU DEDHAM SAVINGS DEFENG CAO DELTEC BANK & TRUST LIMITED DENG LI DENG QIAN DEUTSCHE BANK TRUST COMPANY AMERICA DEUTSCHE HANDELSBANKEN AG DIME COMMUNITY BANK DING "IVAN" LIN DING G. WANG A/K/A DINGGANG WANG DING QIANG SHEN DIRECT PERSUASION LLC DJD CREATIVE LLC DLA PIPER LLP (US) DNM BEAUTY DISTRIBUTION DOAA DASHOUSH DONGNA FANG DREAM PROJECTS LLC DU JIAN YI DWF LLP E.L.J.M. CONSULTING LLC EAST WEST BANCORP, INC. EAST WEST BANK EASTERN PROFIT CORPORATION LIMITED EDDY AQUINO (AKA EDDY I SANCHEZ AQUINO) EDMISTON AND COMPANY LIMITED

EDUARDO EURNEKIAN EFICENS SYSTEMS LLC EHSAN MASUD EISNER ADVISORY GROUP LLC ELITE WELL GLOBAL LIMITED ELIXIR TECHNICAL CONSULTING LLC ELLIOTT KWOK LEVINE & JAROSLAW LLP EMILE P DE NEREE EMPIRE BLUE CROSS BLUE SHIELD EMPIRE GROWTH HOLDINGS ENGINEERING OPERATIONS AND CERTIFICATION SERVICES, LLC EPIC IT LTD EPIQ CORPORATE RESTRUCTURING, LLC ERIC GOLDSMITH MD, LLC ERNST & YOUNG LLP EVAN CRAMER EVOLVE BANK AND TRUST FAEGRE DRINKER BIDDLE & REATH LLP FAM UNITED LLC FAN BINGBING FAN JING FANGGUI ZHU FANIA ROOFING COMPANY FARHAD ZABETI FARRANT GROUP LIMITED FAY YE FEDERAL CORPORATION FEDERAL EXPRESS CORPORATION FEIBO JIANG FEIFEI MA FENG PENG RELLOS FENG YI FENG ZHU FENGGUO LI FENGJIE MA FFP (BVI) LIMITED FIESTA INVESTMENT LTD. F/K/A FIESTA PROPERTY DEVEL FIFTH THIRD BANK, N.A. FINN DIXON & HERLING LLP FIONA YU FIRST ABU DHABI BANK FIRST BANK (F/K/A MALVERN BANK) FIRST COUNTY BANK FIRST FIDELITY BANK FIRST REPUBLIC BANK FIRSTBANK PUERTO RICO FLAGSTAR BANK, N.A. FLAT RATE MOVERS, LTD. FLYING COLOURS CORP FOLEY HOAG LLP

FORBES HARE FORBES HARE LLP FORTNUM INFORMATION SECURITY LIMITED FOX NEWS NETWORK, LLC FREEDOM MEDIA VENTURES LIMITED FUNGWAN TRADING INC. FUNING ZHANG FUNKY FOUNDATIONS, INC. FV BANK INTERNATIONAL INC. G CLUB HOLDCO I LLC G CLUB INTERNATIONAL LIMITED G CLUB ONE G CLUB OPERATIONS LLC G CLUB THREE G CLUB TWO G CLUB US OPERATIONS INC. G CLUB US OPERATIONS LLC G CLUBTHREE G FASHION G FASHION (CA) G FASHION HOLD CO A LIMITED G FASHION HOLD CO B LIMITED G FASHION INTERNATIONAL LIMITED G FASHION LLC G FASHION MEDIA GROUP INC. G FASHION US OPERATIONS INC. G LIVE, LLC G MUSIC LLC G NEWS LLC, G TRANSLATORS PTY LTD G4S SECURITY SYSTEMS (HONG KONG) LTD. GALAXY LTD GANFER SHORE LEEDS & ZAUDERER, LLP GAO BINGCHEN GBROADCAST, LLC G-CLUB G-CLUB INVESTMENTS LIMITED GCP INVESTMENT ADVISORS SL G-EDU INC. GEORGE L. SU GEORGIOU PAYNE STEWIEN LLP GETTR USA, INC. GF IP, LLC GF ITALY LLC GFASHION MEDIA GROUP INC. GFNY INC. GINNEL ASSOCIATES, INC. (D/B/A GINNEL REAL ESTATE) GLADYS CHOW GLENN MELLOR GLOBAL GROUP LIMITED

GLOBALIST INTERNATIONAL LIMITED GM 27 LLC GMUSIC GNEWS LLC GNEWS MEDIA GROUP INC. G-NEWS OPERATIONS, LLC GOLD LEAF CONSULTING LIMITED GOLDBERG WEPRIN FINKEL GOLDSTEIN LLP GOLDEN GATE HIMALAYA FARM LLC GOLDEN SPRING (NEW YORK) LIMITED GOLDFARB & HUCK ROTH RIOJAS, PLLC GOLDFIELDS MONEY (A DIVISION OF BNK CORPORATION LIMITED) GOLENBOCK EISEMAN ASSOR BELL & PESKOE LLP GONET & CIE SA GONG JIANFEN GOODMAN MASSON LTD GORDON & REES SCULLY MANSUKHANI LLP GPOSTS LLC GPP SRL GREAT BOWERY INC. D/B/A CAMILLA LOWTHER MANAGEMENT GREAT LAKES DRONE COMPANY, LLC GREEN & SKLARZ LLC GREENBERG TRAURIG, LLP GREENWICH LAND LLC GROCYBER, LLC GS SECURITY SOLUTIONS INC. G-SERVICE LLC G-TRANSLATORS PTY LTD GTV MEDIA GROUP, INC. GUI LIN GAO GUO LIJIE GUO MEDIA GUO WENOUN GUO WENPING GUOFENG WAN GUY PETRILLO GWGOPNZ LIMITED GYPSY MEI FOOD SERVICES LLC GYPSY MEI PRODUCTIONS LLC H SHAW ENTERPRISES LLC H.R. OWEN DEALERSHIPS LIMITED H.R. OWEN PLC HAA GROUP PTY LTD. HAI YAO HAIDONG HAIHONG WANG HAILING SHENG HAISONG PENG HAITHAM KHALED

HAITONG INTERNATIONAL SECURITIES HALLEY CHEN CPA PROFESSIONAL CORPORATION HAMILTON CAPITAL HOLDING LIMITED HAMILTON CAPITAL HOLDINGS INC HAMILTON DIGITAL ASSETS FUND SP HAMILTON INVESTMENT MANAGEMENT LIMITED HAMILTON M&A FUND SP HAMILTON OPPORTUNITY FUND SPC HAMILTON PE FUND SP HAN CHUNGUANG HANCOCK WHITNEY BANK HANQIANG LIN HAO HAIDONG HAO LI HAO ZHANG HAORAN HE HAOYU WANG HARCUS PARKER LIMITED HARNEY WESTWOOD AND RIEGELS LP HAYASHI MEIOU HAYMAN HONG KONG OPPORTUNITIES ONSHORE FUND LP HAYS SPECIALIST RECRUITMENT LIMITED HCHK PROPERTY MANAGEMENT INC. HCHK TECHNOLOGIES INC. HCHK TECHNOLOGIES, LLC HE BEI YUE HUA ZHUANG SHI GONG CHENG LTD. HEAD WIN GROUP LIMITED HEADWATER SERVICE, LLC HELEN MANIS HENAN YUDA HERBERT SMITH FREEHILLS NEW YORK LLP HERO GRAND LIMITED HGA PROPERTY MANAGEMENT HHS CAPITAL INC. HIBERNIA NATIONAL BANK HIDETOSHI FUJIWARA HILTON MANAGEMENT, LLC HIMALAYA AUSTRALIA ATHENA FARM INC. HIMALAYA AUSTRALIA PTY LTD. HIMALAYA BOSTON MAYFLOWER LLC HIMALAYA CURRENCY CLEARING PTY LTD. HIMALAYA EMBASSY HIMALAYA EXCHANGE HIMALAYA FEDERAL RESERVE HIMALAYA INTERNATIONAL CLEARING LIMITED HIMALAYA INTERNATIONAL FINANCIAL GROUP LIMITED

HIMALAYA INTERNATIONAL PAYMENTS LIMITED HIMALAYA INTERNATIONAL RESERVES LIMITED HIMALAYA INVESTMENT LLC HIMALAYA NEW WORLD INC. HIMALAYA NEW YORK ROCK HIMALAYA SHANGHAI FARM LLC HIMALAYA SUPERVISORY ORGANIZATION HIMALAYA UK CLUB HIMALAYA VENTURES LLC HIMALAYA WORLDWIDE LS HINCKLEY, ALLEN HING CHI NGOK HIU LAAM HAAM HIU SING CHAN HML VANCOUVER SAILING FARM LTD. HODGSON RUSS HOGAN LOVELLS INTERNATIONAL LLP HOLY CITY HONG KONG VENTURES, LTD. HONG KONG INTERNATIONAL FUNDS INVESTMENTS LIMITED HONG QI QU JIAN SHE GROUP, LTD. HONG QIU HONG ZENG HONGWEI FU HONGXIA XU HONGXIN ASH HOU YUAN CHAN HOUSER & ALLISON, APC HOUSTON LITSTAR LLC HP INC UK LIMITED HSBC BANK USA, HSIN SHIH YU HUA AN XIE HUANG YAO HUDSON DIAMOND HOLDING INC. HUDSON DIAMOND HOLDING LLC HUDSON DIAMOND LLC HUDSON DIAMOND NY LLC HUGGA LLC HUGHES FEDERAL CREDIT UNION HUI JIN HUK TRADING INC. I.COM SOLUTIONS LIMITED ICE24 SRO IHOTRY LTD IMMOBILIARA BARBARA 2000 SRL IMPERIUS INTL. TRADE CO. LTD. INDIUM SOFTWARE INC. INFINITE INCREASE LIMITED INFINITUM DEVELOPMENTS LIMITED

INFINITY TREASURY MANAGEMENT INC. INSIGHT CAPITAL INSIGHT PHOENIX FUND INSIGHT TITLE SERVICES LLC INTERNATIONAL TREASURE GROUP LLC INTESA SANPAOLO SPA INVESTORS BANK ISRAEL DISCOUNT BANK OF NEW YORK IVEY, BARNUM & O'MARA LLC IVY CAPITAL ADVISOR LIMITED IW GROUP SERVICES UK LTD J TAN JEWELRY DESIGN, INC. JACK S. LIPSON JAMES PIZZARUSO JAMESTOWN ASSOCIATES, LLC JANCO SRL JANOVER LLC JAPAN HIMALAYA LEAGUE, INC. JASON MILLER JDM STAFFING CORP. JENNER & BLOCK LLP JENNIFER FANGFANG DING JENNIFER MERCURIO JENNY LI JERSEY, INC. JESSE BROWN JESSICA MASTROGIOVANNI JETLAW LLC JIA LI WANG JIA YANG JIA YANG LI JIAHUI LIU JIALIN QIN JIAMEI LU JIAMING LIU JIAN FAN JIAN HUA ZHANG JIAN ZHONG HU JIANG SU PROVINCE JIAN GONG GROUP LTD BEIJING BRANCH JIANG YUNFU BE JIANHAI JIAO JIANHU YI JIANHUA ZHENG JIANMIN HE JIANSHENGXIE AND JIEFU ZHENG JIANXIAO CHEN JIAYAO G JIE ZHANG JINFENG WU JING GENG JING WU

JINLAN YAN JIRONG ZHANG JK CHEF COLLECTIONS LLC JM BULLION INC. JNFX LTD. JOHN B. BERRYHILL JOHN P. MORGAN JOHN S LAU JONATHAN YOUNG JOSEPH CHEN JOSHUA I. SHERMAN JOVIAL CENTURY INTERNATIONAL LIMITED JOYORD SPORTSWEAR LIMITED JPMORGAN CHASE BANK, N.A. JUMBO CENTURY LIMITED JUN CHEN JUN LIU JUN QIAO JUN YUN ZHANG JUNE SHI JUNJIE JIANG K LEGACY LTD. K&L GATES LLP KAEN LIU KAIXIN HONG KALIXUN TRADING LIMITED KAMEL DEBECHE KAN CHAN KARIN MAISTRELLO KATHLEEN SLOANE KEARNY BANK KERCSMAR FELTUS & COLLINS PLLC KEYI ZIKLIE KHALED ASHAFY KIM THONG LEE KIN MING JE KIN MING JE/WILLIAM JE KIONASOFT LLC KIRKLAND & ELLIS LLP KOPPLE, KLINGER & ELBAZ, LLP KROLL, LLC KUI CHENG KYLE BASS KYRGYZ-SWISS BANK CJSC LA INTERNATIONAL FOUNDATION LABARBIERA CUSTOM HOMES LAI LAU LAKE CITY BANK LALIVE SA LAMP CAPITAL LLC LAN GU LAN LIN

LAO JIANG LAW FIRM OF CALLARI PARTNERS, LLC LAW OFFICE OF RICHARD E. SIGNORELLI LAW OFFICES OF RONALD I. CHORCHES, LLC LAWALL & MITCHELL, LLC LAX & NEVILLE LLP LAZARE POTTER GIACOVAS & MOYLE LEADING SHINE LIMITED LEADING SHINE NY LTD LEE CHU LEE VARTAN LEEWAYHERTZ TECHNOLOGIES LEGENDS OWO, LLC LEICESTER HILL INFROMATICES LLC LEONARD SCUDDER LEXINGTON PROPERTY AND STAFFING INC. LI LIU LI LONG LI SHO YO LI TANG LI ZHANG LIANG LIU LIANYING SU LIAPULL S.R.L. LIBERTY JET MANAGEMENT CORP. LIEHONG ZHUANG LIHONG "SARA" WEI LAFRENZ LIHONG WEI LAFRENZ (AKA SARA WEI) LIMARIE REYES LIMARIE REYES MOLINARIS LIN DANG LIN XIN LINDA HE CHEUNG LINWAN "IRENE" FENG LIU DONGFANG LLC STZ FUND NO. 1 LLOYDS BANK PLC LOBEL MODERN NYC LOGAN CHENG (F/K/A SHUIYAN CHENG) LONG GATE LIMITED LORO PIANA S.P.A. LUKASZ LASOTA LUMINESCENCE CO. LTD LUXURY CLEANING, INC. LYZON ENTERPRISES CORPORATION M&T BANK MA XINGCHAO MACARON LIMITED MACDONALD MAJOR LEAD INTERNATIONAL LIMITED MAKAYLA RANDALL MANDELLI USA, INC.

8

MANHATTAN MOTORCARS, INC. MANUEL MARTINEZ ANZALDUA MANUFACTURERS AND TRADERS TRUST COMPANY MAR-A-LAGO MAR-A-LAGO CLUB LLC MARCELLA MONICA FALCIANI MARCUM LLP MARINI PIETRANTONI MUNIZ LLC MARINO, ZABEL & SCHELLENBERG, PLLC MARK GUNDERSON MARTHA JEFFERY MARY DOWDLE (A/K/A MUFFIN DOWDLE) MARY FASHION S.P.A. MARY JIANG MAUNAKAI CAPITAL MAX FEI MAX KRASNER MAYA FAWAZ MAYWIND TRADING LLC MCDONNELL & WHITAKER LLC MCELROY, DEUTSCH, MULVANEY & CARPENTER, LLP MCLAREN RACING LIMITED MCMANIMON, SCOTLAND & BAUMANN, LLC MEDICAL SUPPLY SYSTEM INTERNATIONAL LLC MEDICI BANK INTERNATIONAL LLC MEI KUEN KWOK MEIEN KIKUCHI MEISTER SEELIG & FEIN PLLC MELISSA FRANCIS MELISSA MENDEZ MENGYAO HE MERCANTILE BANK INTERNATIONAL CORP. MERCANTILE GLOBAL HOLDINGS, INC. MERCEDES-BENZ MANHATTAN, INC. META PLATFORMS INC. METRO BANK PLC METRO CREDIT UNION METROPOLITAN COMMERCIAL BANK AND/OR METROPOLITAN BANK HOLDING CORP. MF19 INC. MI KYUNG YANG MICHAEL BARANOWITZ MICHAEL LI & CO. MICHAEL S. WEINSTEIN MICROSOFT CORPORATION MIDFIRST BANK MIHO NISHIMURA MILES GUO

MILES GWOK MILLER MOTORCARS INC. MIMAII NZ LIMITED MIN YANG MINDY WECHSLER MING NI MING WU MINGHUA ZHANG MINGRUI ZHAO MINTZ & GOLD LLP MISHCON DE REYA LLP MOA-FU MODSQUAD INC. MORAN YACHT MANAGEMENT, INC. MORGAN STANLEY MORITT HOCK & HAMROFF MORRISON COHEN LLP MORVILLO ABRAMOWITZ GRAND IASON & ANELLO P.C. MORVILLO ABRAMOWITZ GRAND IASON & ANELLO PC MOS HIMALAYA FOUNDATION INC. MOSAICON SHOES SRL MOUNTAINS OF SPICES INC. MURTHA CULLINA LLP MZC FINANCIAL INC. N.A.R. ENTERPRISES INC. N87 INC. NADEEM AKBAR NAME CORP LLC NARDELLO & CO., LLC NATIONAL AUSTRALIA BANK LIMITED NATIONAL BANK OF ARIZONA (A DIVISION OF ZIONS BANCORPORATION NA) NATIONAL SWEEPSTAKES COMPANY, LLC NAV CONSULTING INC. NAV FUND SERVICES (CAYMAN) LTD. NEALON LAW LLC NEW DYNAMIC DEVELOPMENT LIMITED NEW FEDERAL STATE OF CHINA NEW MULBERRY PTE LTD. NEW TREASURE LLC NEW YORK MOS HIMALAYA LLC NEXBANK NEXT TYCOON INVESTMENTS LIMITED NICHOLAS F. SAVIO NING LI NING ZHAO NIUM, INC. NOBLE FAME GLOBAL LIMITED NODAL PARTNERS, LLC NORRIS MCLAUGHLIN, P.A.

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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

XIAOLAN ZHAO

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# **Schedule 2**

DBS BANK LTD. (connection) FOLEY HOAG LLP (connection) GREENBERG TRAURIG, LLP (connection) HOGAN LOVELLS INTERNATIONAL LLP (connection) K&L GATES LLP (connection) LALIVE SA (connection) MICROSOFT CORPORATION (connection) PRAGER DREIFUSS AG (connection) SIDLEY AUSTIN LLP (connection) UBS AG (LONDON BRANCH) (connection)