郭文贵破产案 · ORDER · ECF #905

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

Chapter 11

In re:

HO WAN KWOK,

Case No: 22-50073 (JAM)

Debtor.

## **THE DEBTOR'S LIMITED OBJECTION TO MOTION OF CHAPTER 11 TRUSTEE FOR ENTRY OF PROTECTIVE ORDER**

Ho Wan Kwok, the debtor (the "Debtor") in the above-captioned bankruptcy case (the "Bankruptcy Case"), by and through his undersigned attorneys, Zeisler & Zeisler, P.C., respectfully submits his limited objection to the Motion of Chapter 11 Trustee for Entry of a Protective Order. The Debtor fully supports the entry of a protective order that will govern the use and dissemination of documents and information produced in the Bankruptcy Case and related proceedings, *e.g.*, adversary proceedings, that are designated as confidential or highly confidential. The Debtor opposes the entry of a protective order in the form submitted by the Trustee because, *inter alia*, i) it does not provide sufficient protections for certain categories of information that the Debtor submits should be treated as confidential; and ii) it appears intrinsically inconsistent, and, therefore, is ambiguous, in certain respects concerning the identity of the parties who would have standing to object to the Trustee's dissemination of information designated as Confidential or Highly Confidential as well as the impact of the protective order on pre-existing protective orders that pertain to some of the same subject matter.

The Debtor, through counsel who was not provided with a copy of the proposed protective order for review before it was filed, has provided the Trustee's counsel with minimal changes to the Trustee's proposed protective order which, if accepted, would make the protective

order acceptable to the Debtor. The Trustee's counsel has responded to the Debtor's comments and the Debtor's counsel will work with the Trustee's counsel to arrive at a mutually agreeable protective order for submission to the Court. The Debtor thus submits this Limited Objection to avoid a waiver of his right to object and so the Court may determine any issues related to the proposed protective order that the Debtor and the Trustee are unable to resolve by agreement.

A copy of the protective order proposed by the Debtor is attached hereto as Exhibit A. A redlined document highlighting the Debtor's proposed changes to the Trustee's proposed protective order is attached hereto as Exhibit B.

Dated at Bridgeport, Connecticut this 3rd day of October, 2022.

## **THE DEBTOR, HO WAN KWOK**

*/s/ James M. Moriarty* Aaron A. Romney (ct28144) James M. Moriarty (ct21876) 10 Middle Street, 15th Floor Bridgeport, Connecticut 06604 Telephone: (203) 368-4234 Facsimile: (203) 368-5487 Email: [aromney@zeislaw.com](mailto:aromney@zeislaw.com) [jmoriarty@zeislaw.com](mailto:jmoriarty@zeislaw.com)

## **CERTIFICATE OF SERVICE**

I hereby certify that on this 3rd day of October, 2022, a copy of foregoing was filed electronically. Notice of this filing will be sent by e-mail to all parties by operation of the Court's electronic filing system or by mail to anyone unable to accept electronic filing as indicated on the Notice ofElectronic Filing. Parties may access this filing through the Court's CM/ECF System.

*/s/ James M. Moriarty* James M. Moriarty