郭文贵破产案 · ORDER · ECF #625

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

\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_ In re : Chapter 11 : Ho Wan Kwok, : Case No. 22-50073 : Debtor.¹ : : \_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_:

## **RESPONSE OF THE OFFICIAL COMMITTEE OF UNSECURED CREDITORS TO APPLICATION OF CHAPTER 11 TRUSTEE FOR ENTRY OF ORDER PURSUANT TO BANKRUPTCY CODE SECTIONS 327, 328, AND 330 AND BANKRUTPCY RULES 2014 AND 2016, AUTHORIZING AND APPROVING RETENTION AND EMPLOYMENT OF PAUL HASTINGS LLP AS COUNSEL, TO CHAPTER 11 TRUSTEE**

The Official Committee of Unsecured Creditors (the "Committee") of the estate of the Debtor, Ho Wan Kwok (the "Debtor"), hereby submits this response to the Application of Chapter 11 Trustee for Entry of Order Pursuant to Bankruptcy Code Sections 327, 328, and 330 and Bankruptcy Rules 2014 and 2016, Authorizing and Approving Retention and Employment of Paul Hastings LLP as Counsel, to Chapter 11 Trustee (the "Paul Hastings Retention Application"), and respectfully represents as follows:

The Committee has no objection to the Paul Hastings Retention Application based on the Committee's understanding that Paul Hastings LLP ("Paul Hastings") will undertake commencement and prosecution of any estate claims without seeking litigation funding and will economize, whenever reasonably feasible, by using local counsel and working cooperatively with the Committee and PAX's counsel in utilizing information and case history each may have that could aid in litigation or other recoveries for creditors.

¹ The Debtor is known by the following names: Guo Wengui; Miles Guo; Miles Kwok; and Ho Wan Kwok.

The Committee reserves its rights to review and object to, if considered appropriate, the

interim and final fee applications filed by Paul Hastings for its services to the Trustee in this case.

**WHEREFORE**, the Committee respectfully requests that the Court grant the Paul Hastings Retention Application with the caveats expressed above and that the Court grant such other or further relief as it may deem just, equitable and proper.

Dated: Bridgeport, Connecticut July 27, 2022

## **OFFICIAL COMMITTEE OF UNSECURED CREDITORS OF HO WAN KWOK**

By: */s/Irve J. Goldman* Irve J. Goldman Jonathan A. Kaplan Pullman & Comley, LLC 850 Main Street, 8th Floor PO Box 7006 Bridgeport, CT 06601-7006 (203) 330-2213 igoldman@pullcom.com

Its Attorneys

## **CERTIFICATION OF SERVICE**

I, Irve J. Goldman, herby certify that on the 27th day of July, 2022, a true and correct copy of the foregoing response to the Response to the Application of Chapter 11 Trustee for Entry of Order Pursuant to Bankruptcy Code Sections 327, 328, and 330 and Bankruptcy Rules 2014 and 2016, Authorizing and Approving Retention and Employment of Paul Hastings LLP as Counsel, to Chapter 11 Trustee was filed with the Court and served all parties that have filed a notice of appearance and request for notice electronically via the Court's CM/ECF electronic filing system.

By: */s/Irve J. Goldman*