--- type: court_doc id: "court_ctb_876_2" court: "CTB" case_no: "22-50073" doc_number: 876 doc_type: "JUDGMENT" filed_date: "2022-09-24" lang: "zh" url: "https://mubeitech.com/court/court_ctb_876_2" json_url: "https://mubeitech.com/api/court/court_ctb_876_2" --- # | UNITED STATES BANKRUPTCY COURT | |--------------------------------| > 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 | | :
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Chapter 11
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Case No. 22-50073 (JAM)
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Adv. Proceeding No. 22-05003 | | :
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September 23, 2022 | | :
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-------------------------------------------------------x | | | ## **CHAPTER 11 TRUSTEE'S APPLICATION FOR PREJUDGMENT REMEDY** In support of this application for prejudgment remedy (the "Application") by defendant/counterclaim-plaintiff Luc A. Despins, in his capacity as the chapter 11 trustee in the Debtor's above-captioned chapter 11 case (the "Trustee"), the undersigned respectfully represents as follows: 1. That, on April 11, 2022, plaintiff/counterclaim-defendant HK INTERNATIONAL FUNDS INVESTMENTS (USA) LIMITED, LLC ("HK USA"), of 203 NE Front Street, Suite #### Case 22-50073 Doc 876-2 Filed 09/24/22 Entered 09/24/22 18:59:04 Page 2 of 22 Case 22-05003 Doc 37 Filed 09/23/22 Entered 09/23/22 20:13:07 Page 2 of 22 101, Milford, DE, 19963, commenced the above-captioned adversary proceeding (the "Adversary Proceeding") against the predecessor defendant HO WAN KWOK (the "Debtor"). 2. That THE TRUSTEE was substituted for the Debtor as the defendant in this Adversary Proceeding. 3. That the Trustee has asserted counterclaims against counterclaim-defendants HK USA and MEI GUO, of 373 Taconic Rd, Greenwich, CT 06831 ("Ms. Guo" and, together with HK USA, collectively, the "Counterclaim-Defendants") in this Adversary Proceeding, as set forth in the Trustee's *Answer and Counterclaims* [Adversary Proceeding Docket No. 36]. 4. That there is probable cause that a judgment (the "Judgment") with a value equal to or greater than the prejudgment remedy sought, or in an amount greater than the amount of the prejudgment remedy sought, taking into account any known defenses, counterclaims or set-offs, will be rendered in this Adversary Proceeding in favor of the Trustee's claims asserted in the Answer and Counterclaims as follows: - On Count I, judgment with a value equal to the value of the Lady May; - On Count II, judgment with a value equal to the assets, known and unknown, of HK USA, including, without limitation, the Lady May and the Escrowed Funds; - On Count III, judgment with a value equal to the membership interests in HK USA; - On Count IV, judgment with a value equal to the Lady May or its value at the time of the asserted intentionally fraudulent transfer; and - On Count V, judgment with a value equal to or greater than \$134 million. 5. To secure such Judgment, the Trustee seeks an order from this court, following a hearing pursuant to Conn. Gen. Stat. § 52-278d, directing that a prejudgment remedy be issued to secure such Judgment: To secure such Judgment, the Trustee requests that he be permitted: (a) To attach sufficient property of the Counterclaim-Defendants, as known or as may hereafter be identified, including in the Counterclaim-Defendants' disclosures pursuant to the Trustee's Motion for Disclosure of Assets or as otherwise discovered by the Trustee, to secure such sum; (b) To garnish the Counterclaim-Defendants' accounts at any financial institution, as known or as may hereafter be identified, including in the Counterclaim-Defendants' disclosures pursuant to the Trustee's Motion for Disclosure of Assets or as otherwise discovered by the Trustee; (c) To attach any stock, membership, or other equity interests of the Counterclaim-Defendants in any entity(ies), including, without limitation, Ms. Guo's membership interest in HK USA; (d) To attach any personal property (including but not limited to automobiles, boats, aircraft, art, jewelry, and collectibles) in which the Counterclaim-Defendants have any interest, including, without limitation, any interest in the Lady May; (e) To attach property of the Counterclaim-Defendants in possession of any third persons, as known, including any interest and/or right to payment of the Counterclaim-Defendants with respect to the funds—originally \$37 million—that HK USA placed into an escrow account under the April 29, 2022 stipulation regarding the Lady May's return to the United States, or as may hereafter be identified, including in the Counterclaim-Defendants' disclosures pursuant to the Trustee's Motion for Disclosure of Assets or as otherwise discovered by the Trustee; and/or (f) To garnish third persons in possession of other property of the Counterclaim-Defendants or owing debts to the Counterclaim-Defendants, as known or as 3 may hereafter be identified, including in the Counterclaim-Defendants' disclosures pursuant to the Trustee's Motion for Disclosure of Assets or as otherwise discovered by the Trustee. 6. The Trustee reserves all rights to seek to amend the amount of the prejudgment remedy during this Adversary Proceeding and in any postjudgment proceedings, as well as to seek other and further ultimate relief, including, without limitation, damages and interest that may not be enumerated herein as part of the prejudgment remedy sought. In further support of this Application, the Trustee submits the Trustee's Affidavit and a Memorandum of Law in Support of the Trustee's Application for a Prejudgment Remedy. Dated: September 23, 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 *and* Nicholas A. Bassett *(pro hac vice*) PAUL HASTINGS LLP 2050 M Street NW Washington, D.C., 20036 (202) 551-1902 nicholasbassett@paulhastings.com *and* Avram E. Luft *(pro hac vice*) Douglass Barron (*pro hac vice*) PAUL HASTINGS LLP 200 Park Avenue New York, New York 10166 (212) 318-6079 aviluft@paulhastings.com *Counsel for the Chapter 11 Trustee* | UNITED STATES BANKRUPTCY COURT | |--------------------------------| | DISTRICT OF CONNECTICUT | | BRIDGEPORT DIVISION | | ----------------------------------------------------------- | x | |-------------------------------------------------------------------------------------------------------------------------|-----------------------------------| | In re: | :
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Chapter 11 | | HO WAN KWOK, | :
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Case No. 22-50073 (JAM) | | Debtor. | :
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HK International Funds Investments
(USA) Limited, LLC | :
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Adv. Proceeding No. 22-05003 | | v.
Ho Wan Kwok | :
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September 23, 2022
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Chapter 11 Trustee Luc A. Despins
Counter-Plaintiff | :
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: | | HK International Funds Investments | : | | (USA) Limited, LLC, and Mei Guo | : | | Counter-Defendants.
-------------------------------------------------------x | : | # **[PROPOSED] ORDER GRANTING CHAPTER 11 TRUSTEE'S APPLICATION FOR PREJUDGMENT REMEDY** WHEREAS, Luc A. Despins, in his capacity as the chapter 11 trustee (the "Trustee"), is the counterclaim-plaintiff in the above-captioned adversary proceeding (the "Adversary Proceeding"), has made an application for prejudgment remedy (the "Application") to secure his claims against counterclaim-defendants HK INTERNATIONAL FUNDS INVESTMENTS (USA) Limited LLC ("HK USA") and MEI GUO ("Ms. Guo" and, together with HK USA, collectively, the "Counterclaim-Defendants"); and WHEREAS, on the basis of the papers submitted, including but not limited to the supporting affidavit(s), and of an evidentiary hearing on the Application, in which all parties were heard, there is probable cause that a judgment in the amount of the prejudgment remedy sought, or in an amount greater than the amount of the prejudgment remedy sought, taking into account any known defenses, counterclaims or set-offs, will be rendered in the matter in favor of the Trustee, NOW, THEREFORE, it is hereby ORDERED that the Trustee shall be authorized, to the amount of the Judgment (as defined in the Application); (a) To attach sufficient property of the Counterclaim-Defendants, as known or as may hereafter be identified, including in the Counterclaim-Defendants' disclosures pursuant to the Trustee's Motion for Disclosure of Assets or as otherwise discovered by the Trustee, to secure such sum; (b) To garnish the Counterclaim-Defendants' accounts at any financial institution, as known or as may hereafter be identified, including in the Counterclaim-Defendants' disclosures pursuant to the Trustee's Motion for Disclosure of Assets or as otherwise discovered by the Trustee; (c) To attach any stock, membership, or other equity interests of the Counterclaim-Defendants in any entity(ies), including, without limitation, Ms. Guo's membership interest in HK USA; (d) To attach any personal property (including but not limited to automobiles, boats, aircraft, art, jewelry, and collectibles) in which the Counterclaim-Defendants have any interest, including, without limitation, any interest in the Lady May; (e) To attach property of the Counterclaim-Defendants in possession of any third persons, as known, including any interest and/or right to payment of the Counterclaim-Defendants with respect to the funds—originally \$37 million—that HK USA placed into an escrow account under the April 29, 2022 stipulation regarding the *Lady May*'s return to the United States, or as may hereafter be identified, including in the Counterclaim-Defendants' disclosures pursuant to the Trustee's Motion for Disclosure of Assets or as otherwise discovered by the Trustee; and/or (f) To garnish third persons in possession of other property of the Counterclaim-Defendants or owing debts to the Counterclaim-Defendants, as known or as may hereafter be identified, including in the Counterclaim-Defendants' disclosures pursuant to the Trustee's Motion for Disclosure of Assets or as otherwise discovered by the Trustee. It is further ORDERED that: 1. The *Motion for Disclosure of Assets* accompanying the Trustee's Application is GRANTED in all respects. 2. The Trustee shall NOT be required to give a bond in connection with the prejudgment remedy. 3. The Trustee is authorized to take all actions necessary to implement the terms of this Order. 4. This Court shall retain jurisdiction with respect to all matters arising from or related to the implementation, interpretation, and enforcement of this Order. | -----------------------------------------------------------
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Adv. Proceeding No. 22-05003
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-------------------------------------------------------x | | Counter-Defendants. | # **AFFIDAVIT OF THE CHAPTER 11 TRUSTEE IN SUPPORT OF THE CHAPTER 11 TRUSTEE'S APPLICATION FOR PREJUDGMENT REMEDY** I, Luc A. Despins, in my capacity as chapter 11 trustee in the above-captioned chapter 11 case (the "Chapter 11 Case"), being duly sworn, hereby depose and say: 1. I am over the age of eighteen years and understand and believe in the obligations of an oath. 2. I am the chapter 11 trustee in the above-captioned chapter 11 case (the "Trustee"). I make the statements herein solely in my capacity as Trustee based upon my investigation to date and my knowledge from my review of the sources cited as exhibits to the *Chapter 11* #### Case 22-50073 Doc 876-2 Filed 09/24/22 Entered 09/24/22 18:59:04 Page 10 of Case 22-05003 Doc 37 Filed 09/23/22 Entered 09/23/22 20:13:07 Page 10 of 22 22 *Trustee's Answer and Counterclaims* (the "Counterclaims"). 3. I offer this affidavit in support of the Trustee's *Application for Prejudgment Remedy* (the "Application") filed in the above-captioned adversary proceeding (the "Adversary Proceeding") against Counter-Defendants HK International Funds Investments (USA) Limited, LLC ("HK USA") and Mei Guo to secure a future judgment against Counter-Defendants with respect to the Counterclaims. 4. As stated in the Counterclaims, the Trustee holds a series of affirmative claims against HK USA based on, among other things, HK USA's well-documented role as one of a series of shell companies used by the Debtor to protect his assets from creditors. 5. These Counterclaims are supported by the extensive evidentiary record of documents cited in and attached to the Counterclaims, including without limitation (i) admissions by the Debtor or his representatives; (ii) rulings made by Justice Ostrager of the New York Supreme Court (the "State Court") in the action captioned *PAX v. Kwok*, Index No. 652077/2017 (N.Y. Sup. Ct.); and (iii) the docket and public record in this chapter 11 case. 6. To the best of my knowledge, the documents attached as exhibits to the counterclaims are true and correct copies of such documents, and such documents are incorporated herein as evidence supporting the Application. 7. As set forth in Counterclaims and the exhibits and evidence referred to therein, the Trustee is entitled to prevail on his declaratory judgment claims and claims for damages, including (i) recovery of all property belonging to Counter-Defendant HK USA, including without limitation the *Lady May* (or its value at the time of its transfer by the Debtor, as described in the Application) and HK USA's interest in the \$37 million in escrowed funds; (ii) recovery of Counter-Defendant Mei Guo's membership interest in HK USA; and/or (iii) a 2 ## Case 22-50073 Doc 876-2 Filed 09/24/22 Entered 09/24/22 18:59:04 Page 11 of Case 22-05003 Doc 37 Filed 09/23/22 Entered 09/23/22 20:13:07 Page 11 of 22 22 judgment of an award of damages of at least \$134 million relating to the contempt fines discussed in the Counterclaims. 8. On account of the facts set forth above, and as discussed in the Counterclaims, HK USA's claim in its Adversary Complaint fails, and the Trustee has demonstrated probable cause to succeed on the Counterclaims. I am not aware of any defenses, set offs or counterclaims that HK USA might have with respect to its liability and indebtedness to the Plaintiffs that would affect the Trustee's ability to obtain the relief sought in the Application. I declare under penalty of perjury under the laws of the United States of America that the foregoing is true and correct. > */s/ Luc A. Despins* Luc A. Despins Chapter 11 Trustee | ----------------------------------------------------------- | x | |------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|---------------------------------------------------------------------------------------| | In re: | :
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Chapter 11 | | HO WAN KWOK, | :
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Case No. 22-50073 (JAM) | | Debtor. | :
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HK International Funds Investments
(USA) Limited, LLC
Plaintiff
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Ho Wan Kwok
Defendant | :
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Adv. Proceeding No. 22-05003
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September 23, 2022
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Chapter 11 Trustee Luc A. Despins
Counter-Plaintiff
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HK International Funds Investments
(USA) Limited, LLC, and Mei Guo
Counter-Defendants. | :
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: | | -------------------------------------------------------x | | # **[PROPOSED] ORDER FOR HEARING AND NOTICE REGARDING CHAPTER 11 TRUSTEE'S APPLICATION FOR PREJUDGMENT REMEDY** The *Chapter 11 Trustee's Application for Prejudgment Remedy* (the "Application") having been presented to the Court, it is hereby ordered, that a hearing be held thereon on \_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_ at \_\_\_\_\_ a.m. / p.m., and that counterclaim-plaintiff Luc A. Despins, in his capacity as the chapter 11 trustee (the "Trustee"), give notice to counterclaim-defendants HK International Funds Investments (USA) Limited, LLC ("HK USA") and Mei Guo ("Ms. Guo" and, together with HK USA, collectively, the "Counterclaim-Defendants"), in accordance with section 52-278c of the Connecticut General Statutes, of the pendency of the Application and of the time ## Case 22-50073 Doc 876-2 Filed 09/24/22 Entered 09/24/22 18:59:04 Page 13 of Case 22-05003 Doc 37 Filed 09/23/22 Entered 09/23/22 20:13:07 Page 13 of 22 22 when it will be heard by causing a true and attested copy of the Application, prejudgment remedy summons, affidavit, and of this order, together with such notice as is required under subsection (e) of section 52-278c, to be served upon the Counterclaim-Defendants by some proper officer or indifferent person on or before \_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_ and that due return of service be made to this court. | ----------------------------------------------------------- | x | |------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|---------------------------------------------------------------------------------------| | In re: | :
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Chapter 11 | | HO WAN KWOK, | :
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Case No. 22-50073 (JAM) | | Debtor. | :
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HK International Funds Investments
(USA) Limited, LLC
Plaintiff
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Ho Wan Kwok
Defendant | :
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Adv. Proceeding No. 22-05003
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September 23, 2022
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Chapter 11 Trustee Luc A. Despins
Counter-Plaintiff
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HK International Funds Investments
(USA) Limited, LLC, and Mei Guo
Counter-Defendants. | :
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: | | -------------------------------------------------------x | | #### **[PROPOSED] SUMMONS** To a state marshal of the counties of Hartford and Fairfield, or his/her deputy in said Counties, or any other person duly authorized to serve process: GREETING: By authority of the State of Connecticut and the United States Bankruptcy Court, you are hereby commanded to serve a true and attested copy of the above Application, Affidavit, Order for Prejudgment Remedy, Order for Hearing and Notice, Notice to the Counterclaim-Defendants, and Motion for Disclosure of Assets upon: ## Case 22-50073 Doc 876-2 Filed 09/24/22 Entered 09/24/22 18:59:04 Page 15 of Case 22-05003 Doc 37 Filed 09/23/22 Entered 09/23/22 20:13:07 Page 15 of 22 22 # HK INTERNATIONAL FUNDS INVESTMENTS (USA) LIMITED, LLC, of 203 NE Front Street, Suite 101, Milford, DE, 19963 by leaving two true and attested copies of such process together with the required fee at the office of the Secretary of the State or depositing the same in the United States mail, by registered or certified mail, postage prepaid, addressed to said office, on or before \_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_. By authority of the State of Connecticut and the United States Bankruptcy Court, you are hereby commanded to serve a true and attested copy of the above Application, Affidavit, Order for Prejudgment Remedy, Order for Hearing and Notice, Notice to the Counterclaim-Defendants, and Motion for Disclosure of Assets upon: MEI GUO, of 373 Taconic Rd, Greenwich, CT 06831 by leaving the same in her hands or at her usual place of abode, on or before \_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_. Hereof fail not but due service and return make. Dated at New Haven, Connecticut, this \_\_\_\_\_\_\_\_ day of \_\_\_\_\_\_\_\_\_ 2022. \_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_ Commissioner of the Superior Court | ----------------------------------------------------------- | x | |------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|---------------------------------------------------------------------------------------| | In re: | :
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Chapter 11 | | HO WAN KWOK, | :
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Case No. 22-50073 (JAM) | | Debtor. | :
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HK International Funds Investments
(USA) Limited, LLC
Plaintiff
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Ho Wan Kwok
Defendant | :
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Adv. Proceeding No. 22-05003
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September 23, 2022
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Chapter 11 Trustee Luc A. Despins
Counter-Plaintiff
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HK International Funds Investments
(USA) Limited, LLC, and Mei Guo
Counter-Defendants. | :
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: | | -------------------------------------------------------x | | # **NOTICE TO COUNTERCLAIM-DEFENDANTS** YOU HAVE RIGHTS SPECIFIED IN THE CONNECTICUT GENERAL STATUTES, INCLUDING CHAPTER 903A, WHICH YOU MAY WISH TO EXERCISE CONCERNING THIS APPLICATION FOR PREJUDGMENT REMEDY. THESE RIGHTS INCLUDE THE RIGHT TO A HEARING: (1) TO OBJECT TO THE PROPOSED PREJUDGMENT REMEDY BECAUSE YOU HAVE A DEFENSE TO OR SET-OFF AGAINST THE ACTION OR AN OFFSETTING CLAIM AGAINST THE DEFENDANT/COUNTERCLAIM-PLAINTIFF OR BECAUSE THE AMOUNT SOUGHT IN THE APPLICATION FOR THE PREJUDGMENT REMEDY IS UNREASONABLY HIGH OR BECAUSE PAYMENT OF ANY JUDGMENT THAT MAY BE RENDERED AGAINST YOU IS COVERED BY ANY INSURANCE THAT MAY BE AVAILABLE; (2) TO REQUEST THAT THE COUNTERCLAIM-PLAINTIFF POST A BOND IN ACCORDANCE WITH SECTION 52-278D OF THE GENERAL STATUTES TO SECURE YOU AGAINST ANY DAMAGES THAT MAY RESULT FROM THE PREJUDGMENT REMEDY; (3) TO REQUEST THAT YOU BE ALLOWED TO SUBSTITUTE A BOND FOR THE PREJUDGMENT REMEDY SOUGHT; AND (4) TO SHOW THAT THE PROPERTY SOUGHT TO BE SUBJECTED TO THE PREJUDGMENT REMEDY IS EXEMPT FROM SUCH A PREJUDGMENT REMEDY. | Dated: | September 23, 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 *and* Nicholas A. Bassett *(pro hac vice*) PAUL HASTINGS LLP 2050 M Street NW Washington, D.C., 20036 (202) 551-1902 nicholasbassett@paulhastings.com *and* Avram E. Luft *(pro hac vice*) Douglass Barron (*pro hac vice*) PAUL HASTINGS LLP 200 Park Avenue New York, New York 10166 (212) 318-6079 aviluft@paulhastings.com *Counsel for the Chapter 11 Trustee* | ----------------------------------------------------------- | x | |------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|---------------------------------------------------------------------------------------| | In re: | :
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Chapter 11 | | HO WAN KWOK, | :
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Case No. 22-50073 (JAM) | | Debtor. | :
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HK International Funds Investments
(USA) Limited, LLC
Plaintiff
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Ho Wan Kwok
Defendant | :
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Adv. Proceeding No. 22-05003
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September 23, 2022
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Chapter 11 Trustee Luc A. Despins
Counter-Plaintiff
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HK International Funds Investments
(USA) Limited, LLC, and Mei Guo
Counter-Defendants. | :
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: | | -------------------------------------------------------x | | # **MOTION FOR DISCLOSURE OF ASSETS** Pursuant to Connecticut General Statutes § 52-278n and Rule 7064 of the Federal Rules of Bankruptcy Procedure, counterclaim-plaintiff Luc A. Despins, in his capacity as the chapter 11 trustee (the "Trustee"), and in connection with the *Chapter 11 Trustee's Application for Prejudgment Remedy* (the "Application") files this motion (the "Motion") that the counterclaimdefendants HK International Funds Investments (USA) Limited, LLC ("HK USA") and Mei Guo ("Ms. Guo" and, together with HK USA, collectively, the "Counterclaim-Defendants"), be ordered to disclose the existence, location and extent of its or her interest in any and all sufficient tangible or intangible real or personal property – including, without limitation, general intangibles, #### Case 22-50073 Doc 876-2 Filed 09/24/22 Entered 09/24/22 18:59:04 Page 20 of Case 22-05003 Doc 37 Filed 09/23/22 Entered 09/23/22 20:13:07 Page 20 of 22 22 accounts, shares of stocks, bonds, partnership interests, membership interests, contracts, contract rights, notes, bills, drafts, acceptances, letters of credit, debts, accounts receivable, obligations and liabilities in whatever form owing, tax refunds, and all proceeds of any kind of insurance to which it may be entitled – to secure the Judgment (as defined in the Application) in favor of the Trustee, said disclosure to be made through deposition of the Counterclaim-Defendants by the Trustee, with document production provided by the Counterclaim-Defendants in advance thereof, all within thirty (30) days of the date of the granting of this Motion. Dated: September 23, 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 *and* Nicholas A. Bassett *(pro hac vice*) PAUL HASTINGS LLP 2050 M Street NW Washington, D.C., 20036 (202) 551-1902 nicholasbassett@paulhastings.com *and* Avram E. Luft *(pro hac vice*) Douglass Barron (*pro hac vice*) PAUL HASTINGS LLP 200 Park Avenue New York, New York 10166 (212) 318-6079 aviluft@paulhastings.com *Counsel for the Chapter 11 Trustee* | ----------------------------------------------------------- | x | |------------------------------------------------------------------------------------------------------------------------------------------------------------------------|--------------------------------------------------| | In re: | :
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Chapter 11 | | HO WAN KWOK, | :
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Case No. 22-50073 (JAM) | | Debtor. | :
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HK International Funds Investments
(USA) Limited, LLC
Plaintiff
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Ho Wan Kwok
Defendant | :
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Adv. Proceeding No. 22-05003
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September 23, 2022
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Chapter 11 Trustee Luc A. Despins
Counter-Plaintiff | :
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HK International Funds Investments
(USA) Limited, LLC, and Mei Guo
Counter-Defendants.
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: | # **CERTIFICATE OF SERVICE** The undersigned hereby certifies that on September 23, 2022, the foregoing Application for Prejudgment Remedy (including the affidavit, proposed order, and all other attachments, exhibits, notices, and other documents associated therewith) 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 ## Case 22-50073 Doc 876-2 Filed 09/24/22 Entered 09/24/22 18:59:04 Page 22 of Case 22-05003 Doc 37 Filed 09/23/22 Entered 09/23/22 20:13:07 Page 22 of 22 22 electronic filing as indicated on the Notice of Electronic Filing.1 Parties may access this filing through the Court's CM/ECF system. Dated: September 23, 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 *and* Nicholas A. Bassett *(pro hac vice*) PAUL HASTINGS LLP 2050 M Street NW Washington, D.C., 20036 (202) 551-1902 nicholasbassett@paulhastings.com *and* Avram E. Luft *(pro hac vice*) Douglass Barron (*pro hac vice*) PAUL HASTINGS LLP 200 Park Avenue New York, New York 10166 (212) 318-6079 aviluft@paulhastings.com *Counsel for the Chapter 11 Trustee* 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.