郭文贵破产案 · ORDER · ECF #578

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

In re:

Chapter 11 Case No.

HO WAN KWOK¹

22-50073 (JAM)

Debtor.

July 20, 2022

# **PACIFIC ALLIANCE ASIA OPPORTUNITY FUND L.P.'S RESERVATION OF RIGHTS RELATED TO THE DEBTOR'S MOTION FOR RELIEF FROM ORDER APPOINTING LUC A. DESPINS AS CHAPTER 11 TRUSTEE**

## TO THE HONORABLE JULIE A. MANNING, UNITED STATES BANKRUPTCY JUDGE:

Pacific Alliance Asia Opportunity Fund L.P. ("PAX") submits its reservation of rights

(the "Reservation of Rights") related to the *Debtor's Motion for Relief from Order Appointing*

*Luc A. Despins as Chapter 11 Trustee* [ECF No. 561] (the "Set Aside Motion"). In support of

the Reservation of Rights, PAX states as follows:

1. On July 15, 2022, the debtor Ho Wan Kwok (the "Debtor") filed the Set Aside

Motion.

2. On July 15, 2022, the Court also scheduled a status conference regarding, among other things, the proposed management and administration of this case by Luc A. Despins, in his capacity as Chapter 11 Trustee (the "Chapter 11 Trustee"). The Set Aside Motion had not yet been filed at the time the Court scheduled the status conference.

3. As of the filing of this Reservation of Rights, the Court has not scheduled the hearing date or briefing schedule related to the Set Aside Motion. Nevertheless, on July 20,

¹ The last four digits of the Debtor's taxpayer identification number are 9595.

2022, the Chapter 11 Trustee filed its *Objection of Chapter 11 Trustee to Debtor's Motion for Relief from Order Appointing Luc A. Despins as Chapter 11 Trustee* [ECF No. 575].

4. PAX reserves all rights to file a position statement related to the Set Aside Motion

once the Court schedules the hearing on the Set Aside Motion.

Dated: Hartford, Connecticut July 20, 2022

#### **Pacific Alliance Asia Opportunity Fund L.P.**

*By: /s/ Patrick M. Birney* Patrick M. Birney (CT No. 19875) Annecca H. Smith (CT No. 31148) **ROBINSON & COLE LLP** 280 Trumbull Street Hartford, CT 06103 Telephone: (860) 275-8275 Facsimile: (860) 275-8299 E-mail: pbirney@rc.com asmith@rc.com

-and-

Peter Friedman (admitted *pro hac vice*) Stuart M. Sarnoff (admitted *pro hac vice*) **O'MELVENY & MYERS LLP** Times Square Tower 7 Times Square New York, NY 10036 Telephone: (212) 326-2293 E-mail: pfriedman@omm.com ssarnoff@omm.com

#### **CERTIFICATE OF SERVICE**

I hereby certify that on July 20, 2022, a copy of the foregoing was filed electronically through the Court's CM/ECF System. Notice of this filing will be sent by e-mail to all parties receiving notice by operation of the court's electronic filing system. Parties in interest may access this filing through the Court's CM/ECF System.

/s/ *Patrick M. Birney* Patrick M. Birney