郭文贵破产案 · ORDER · ECF #635

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

--------------------------------------------------------------------X In re: Ho Wan Kwok, Debtor.¹ : : : : : : : : Chapter 11 Case No. 22-50073 (JAM) --------------------------------------------------------------------X

## **CHAPTER 11 TRUSTEE'S NOTICE OF FILING PROPOSED ORDER ESTABLISHING DEADLINES FOR FILING PROOFS OF CLAIM AND APPROVING FORM AND MANNER OF NOTICE THEREOF AND RELATED DOCUMENTS AND REQUEST FOR HEARING**

With respect to the motion, initially filed by the Debtor, for entry of an order (a) setting bar dates for creditors to submit proofs of claim in the above-captioned chapter 11 case (the "Chapter 11 Case"), (b) approving procedures for submitting proofs of claim, (c) approving the form of proof of claim, and (d) approving the form of notice of the bar dates and manner of service thereof [Docket No. 146] (the "Motion"), Luc A. Despins, as the chapter 11 trustee (the "Trustee") appointed in this Chapter 11 Case, hereby files the attached revised proposed order granting the Motion (together with the documents annexed thereto, the "Trustee's Proposed Order"), and requests that the Court schedule a hearing with respect thereto, as follows:

1. Attached hereto as Exhibit A is the Trustee's Proposed Order, together with the Trustee's proposed annexed documents thereto, *i.e.*, Annex I (the "Bar Date Notice"), Annex II (the "Claim Form"), Annex III (the "Publication Notice"), and Annex IV (the "Local Rule 3003- 1 Notice"). Attached hereto as Exhibit B is a blackline of the Trustee's Proposed Order (marked

¹ The above-captioned debtor (the "Debtor") is known by the following names: Guo Wengui; Miles Guo; Miles Kwok; and Ho Wan Kwok.

to show changes against the Debtor's Proposed Order, as submitted to Chambers on May 2, 2022) and a blackline of the Trustee's proposed Bar Date Notice (marked to show changes against the Debtor's proposed version, as submitted to Chambers on May 2, 2022).²

2. The Trustee provides the attached documents following (a) the Trustee's status report to the Court on July 21, 2022, including as it relates to the setting of a bar date, and (b) the Court's request, at the July 21, 2022 status conference, to submit a revised proposed bar date order. On July 28, 2022, the Trustee provided a draft of the Trustee's Proposed Order to counsel for the official committee of unsecured creditors and counsel to PAX. As of the time of this notice, the Trustee has not received any comments from either counsel.

3. Finally, the Trustee requests that matter relating to the setting of a bar date, including with respect to the Trustee's Proposed Order, be heard at the August 1, 2022 hearing, which the Court previously scheduled on certain other pending matters in this Chapter 11 Case.

Dated: July 28, 2022 LUC A. DESPINS,

New Haven, Connecticut CHAPTER 11 TRUSTEE

By: */s/ Patrick R. Linsey* Douglas S. Skalka (ct00616) Patrick R. Linsey (ct29437) NEUBERT, PEPE & MONTEITH, P.C. 195 Church Street, 13th Floor New Haven, Connecticut 06510 (203) 781-2847 dskalka@npmlaw.com plinsey@npmlaw.com

² No blacklines are included with respect to the Claim Form and the Local Rule 3003-1 Notice because they are unchanged from the Debtor's proposed versions. The Publication Notice is a new document (*i.e.*, there was no version of this document annexed to the Debtor's Proposed Order), and, accordingly, no blackline is provided with respect to this document either. The Trustee's Proposed Order does not annex a notice of a section 503(b)(9) bar date because the Trustee does not believe that it is necessary, at this time, to set a bar date for section 503(b)(9) administrative expense claims.

*and*

Nicholas A. Bassett *(*admitted *pro hac vice*) PAUL HASTINGS LLP 2050 M Street NW Washington, D.C., 20036 (202) 551-1902 nicholasbassett@paulhastings.com

*and*

Avram E. Luft *(*admitted *pro hac vice*) Douglass Barron (admitted *pro hac vice*) PAUL HASTINGS LLP 200 Park Avenue New York, New York 10166 (212) 318-6079 aviluft@paulhastings.com

*Proposed counsel for the Chapter 11 Trustee*

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

| -----------------------------------------------------------<br>x | | | |------------------------------------------------------------------|--------|-------------------------| | In re: | :<br>: | Chapter 11 | | HO WAN KWOK, | :<br>: | Case No. 22-50073 (JAM) | | Debtor. | :<br>: | | | ----------------------------------------------------------- | :<br>x | |

## **CERTIFICATE OF SERVICE**

The undersigned hereby certifies that on July 28, 2022, the foregoing Notice, and all exhibits and attachments thereto, 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.¹ Parties may access this filing through the Court's CM/ECF system.

Dated: July 28, 2022 New Haven, Connecticut

> By: */s/ Patrick R. Linsey* Douglas S. Skalka (ct00616) Patrick R. Linsey (ct29437) NEUBERT, PEPE & MONTEITH, P.C. 195 Church Street, 13th Floor New Haven, Connecticut 06510 (203) 781-2847 dskalka@npmlaw.com plinsey@npmlaw.com

¹ To the extent that the foregoing was filed outside regular business hours, service by mail on recipients unable or not qualified to accept electronic notice was made on the next business day.

*and*

Nicholas A. Bassett *(*admitted *pro hac vice*) PAUL HASTINGS LLP 2050 M Street NW Washington, D.C., 20036 (202) 551-1902 nicholasbassett@paulhastings.com

*and*

Avram E. Luft *(*admitted *pro hac vice*) Douglass Barron (admitted *pro hac vice*) PAUL HASTINGS LLP 200 Park Avenue New York, New York 10166 (212) 318-6079 aviluft@paulhastings.com

*Proposed Counsel for the Chapter 11 Trustee*