郭文贵刑事案 · ECF #4301

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

| x | | | |------------------------------|--------|-------------------------| | | : | | | In re: | : | Chapter 11 | | | : | | | 1<br>HO WAN KWOK,<br>et al., | : | Case No. 22-50073 (JAM) | | Debtors. | :<br>: | (Jointly Administered) | | | : | | | | | | | | x | |

## **APPLICATION OF CHAPTER 11 TRUSTEE AND GENEVER HOLDINGS, LLC FOR ENTRY OF ORDER TO SELL CERTAIN PERSONAL PROPERTY BY PUBLIC AUCTION FREE AND CLEAR OF ALL LIENS CLAIMS AND INTERESTS AND APPROVE FORM OF NOTICE OF SALE**

Luc A. Despins, in his capacity as chapter 11 trustee (the "Trustee") of Ho Wan Kwok (the "Individual Debtor"), and Genever Holdings LLC ("Genever US" and, together with the Trustee, the "Applicants") hereby file this application (the "Application") requesting entry of an order, substantially in the form attached as **Exhibit A** hereto (the "Proposed Order"), approving the sale by public auction to be conducted by The Hamilton Group, LLC, as auctioneer ("Hamilton") of certain personal property and motor vehicles as more particularly identified on **Exhibit B** attached hereto, free and clear of all liens, claims and interests; and approving the form of the Notice of Sale of Estate Property substantially in the form attached as **Exhibit C** hereto (the "Notice"). In support of this Application, the Applicants respectfully state as follows:

¹ The Debtors in these chapter 11 cases are Ho Wan Kwok (also known as Guo Wengui, Miles Guo, and Miles Kwok, as well as numerous other aliases) (last four digits of tax identification number: 9595), Genever Holdings LLC (last four digits of tax identification number: 8202) and Genever Holdings Corporation. The mailing address for the Trustee, Genever Holdings LLC, and the Genever Holdings Corporation is Paul Hastings LLP, 200 Park Avenue, New York, NY 10166 c/o Luc A. Despins, as Trustee for the Estate of Ho Wan Kwok (solely for purposes of notices and communications).

## **PRELIMINARY STATEMENT²**

1. The Trustee has identified certain personal property that belongs to the Individual

Debtor's Estate and Genever US's Estate, and which should be sold by public auction for the

benefit of the respective Estate's creditors. As it relates to the Individual Debtor's Estate, this

property includes:

- a. a 2022 BMW motorcycle with a VIN number of WB10L4303N6F02046 (the "BMW"); - b. a 2021 Harley Davidson motorcycle with a VIN number of 1HD1TEH1XMB956441 (the "Harley"); - c. a 2021 Ducati Diavel motorcycle bearing VIN number ZDMGAHRW5MB005016 (the "Ducati"); and - d. a 2017 Lexus NX 200T bearing VIN number JTJBARBZOH2127320 (the "Lexus," and together with the Ducati and the BMW, the "First Vehicle Group").

The First Vehicle Group is currently stored at Hamilton's Clinton, Connecticut facility.

2. Genever US's principal assets consist of the Sherry Netherland Apartment and certain furniture previously located at that apartment. As the Court may recall, in order to conduct remediation work at the Sherry Netherland Apartment, all furniture and personal property previously located at the Sherry Netherland Apartment (the "Genever US Property")³ was moved to a secure location. The Genever US Property is currently stored in warehouse facilities in New Jersey (the "New Jersey Storage Facility"), separate from other personal property recovered by the Trustee in these bankruptcy proceedings.⁴

² Capitalized terms not defined in the Preliminary Statement shall have the meaning ascribed to them later in the Application.

³ The Genever US Property consists of furniture that was originally acquired by Genever US in connection with the purchase of the Sherry Netherland Apartment and additional furniture acquired by the Individual Debtor thereafter. The Trustee and Genever US reserve all rights as to the allocation, as between their respective estates, of the proceeds of the Genever US Property.

⁴ Given that the property of two separate estates are at issue here, the proceeds from the Genever US Property will be kept separate from the proceeds of the other property to be sold.

3. By this Application, in accordance with the Applicants' statutory duty to maximize value for the Estates' creditors, Genever US and the Trustee seek entry of the Proposed Order, pursuant to Section 363(b) of the Bankruptcy Code, Rules 2002, 6004 and 9014 of the Federal Rules of Bankruptcy Procedure (the "Bankruptcy Rules") and Rules 6004- 1 and 6005-1 of the District of Connecticut Local Rules of Bankruptcy Procedure (the "Local Bankruptcy Rules "), approving the sale of the First Vehicle Group and the Genever US Property by public online auction conducted by Hamilton, upon the terms set forth herein (the "Auction"), free and clear of liens, claims and interests and approving the form of Notice of Sale of Estate Property.

### **JURISDICTION, VENUE, AND STATUTORY BASES**

4. The United States Bankruptcy Court for the District of Connecticut (the "Court") has jurisdiction over this matter pursuant to 28 U.S.C. §§ 157 and 1334 and the *Standing Order of Reference* from the United States District Court for the District of Connecticut (as amended). This is a core proceeding within the meaning of 28 U.S.C. § 157(b).

5. Venue in this District is proper pursuant to 28 U.S.C. §§ 1408 and 1409.

6. The bases for the relief requested herein is section 363 of title 11 of the United States Code (the "Bankruptcy Code").

## **BACKGROUND**

## **I. Chapter 11 Cases**

7. On October 12, 2020, Genever US filed a voluntary petition for relief under chapter 11 of title 11 of the United States Code in the United States Bankruptcy Court for the Southern District of New York (the "SDNY Bankruptcy Court"), thereby commencing case number 20-12411 (JLG) (the "SDNY Bankruptcy Case").

8. On February 15, 2022 (the "Petition Date"), the Individual Debtor filed with the Court a voluntary petition for relief under chapter 11 of the Bankruptcy Code.

9. On March 21, 2022, the United States Trustee appointed an Official Committee of Unsecured Creditors (the "Committee") in the Individual Debtor's chapter 11 case.

10. On June 15, 2022, the Court entered a memorandum of decision and order [Main case Docket No. 465] (the "Trustee Order") directing the United States Trustee to appoint a chapter 11 trustee in the Individual Debtor's chapter 11 case. Pursuant to the Trustee Order, the United States Trustee selected Luc A. Despins as the Chapter 11 Trustee [Main Case Docket No. 514].

11. On July 8, 2022, the Court entered an order granting the appointment of Luc A. Despins as the Chapter 11 Trustee in the Individual Debtor's chapter 11 case [Main Case Docket No. 523].

12. On August 10, 2022, the Court entered an order [Main Case Docket No. 717] finding that the Trustee holds all of the Individual Debtor's economic and governance rights with respect to Genever BVI, which, in turn wholly owns Genever US.

13. On September 30, 2022, the Trustee and Genever US filed a joint motion [Docket No. 211 in Case No. 22-50592] seeking an order from the SDNY Bankruptcy Court transferring the SDNY Bankruptcy Case to the Court. On November 3, 2022, the SDNY Bankruptcy Court entered an order [Docket No. 225 in Case No. 22-50592] granting the motion and the SDNY Bankruptcy Case was transferred to this Court.

14. On October 11, 2022, Genever Holdings Corporation ("Genever BVI," and together with Genever US, the "Genever Debtors") filed its voluntary chapter 11 petition in this Court.

15. On November 3, 2022, the SDNY Bankruptcy Court entered an order [Docket No. 225 in Case No. 22-50592] transferring the venue of the SDNY Bankruptcy Case to this Court, which assigned it Case Number 22-50592.

16. By order dated November 21, 2022 [Main Case Docket No. 1141], the Court approved the joint administration of the chapter 11 cases of Genever US, Genever BVI, and the Individual Debtor.

### **II. Sherry Netherland Apartment and Genever US Property**

17. Genever US's principal assets consist of the 18th floor apartment and auxiliary units in the Sherry Netherland Hotel located at 781 Fifth Avenue, New York, New York 10022 (collectively, the "Sherry Netherland Apartment"), as well as the Genever US Property. The Sherry Netherland Apartment was purchased by Genever US in 2015 as a fully furnished residence. Since the purchase of the Sherry Netherland Apartment, Genever US added additional furniture and other personal property.

18. During the SDNY Bankruptcy Case, Bravo Luck Limited ("Bravo Luck"), an entity purportedly owned by the Individual Debtor's son, claimed beneficial ownership of the Sherry Netherland Apartment pursuant to a purported trust agreement signed by the Individual Debtor and his son. Shortly after the transfer of the SDNY Bankruptcy Case to this Court, the Trustee commenced an adversary proceeding against Bravo Luck [Adv. Proc. No. 22-05027], alleging, among other things, that the purported trust agreement was a forgery and the Individual Debtor (and now the estate) is the true beneficial owner of the Sherry Netherland Apartment.

19. On August 30, 2023, the Bankruptcy Court entered an order [Adv. Proc. No. 22- 05027, Docket No. 118] approving a settlement agreement by and between the Trustee, Genever US, Genever BVI, Bravo Luck, and the Individual Debtor's son, pursuant to which agreement

Bravo Luck and the Individual Debtor's son agreed, among other things, that (a) Genever US is the full and exclusive owner of the Sherry Netherland Apartment, free and clear of all liens and encumbrances, with the Sherry Netherland Apartment constituting property of the Genever US estate under section 541 of the Bankruptcy Code and (b) Bravo Luck and the Individual Debtor's son will never assert any rights or claims for or related to the Sherry Netherland Apartment or the Genever Debtors, or any other assets related to the foregoing the Trustee asserts are part of the Individual Debtor's or the Genever Debtors' estates.

20. On March 15, 2023, a fire broke out in the Sherry Netherland Apartment and caused significant damage to certain portions of the apartment. Following the fire, Genever US undertook to remediate the fire damage and clean the Sherry Netherland Apartment in order to prepare the apartment for sale. On or about May 1 and May 2, 2024, Genever US caused the Genever US Property to be cleaned, packaged, and moved to the New Jersey Storage Facility where it has remained to date.

## **III. Cao Adversary Proceeding, the Harley Motorcycle and the BMW Motorcycle**

21. On February 6, 2024, the Trustee commenced an adversary proceeding against Defeng Cao—long-time boyfriend of the Debtor's daughter, Mei Guo —by filing a Complaint [Adv Proc. No. 24-05001, Docket No.1] (the "Cao Adversary Proceeding") seeking, among other things, an order declaring that the Debtor is the equitable owner of the Harley, the BMW and two other motorcycles⁵ (the "Four Motorcycles") nominally held in Mr. Cao's name, (ii) declaring that the Four Motorcycles are property of the Debtor's chapter 11 estate, to be administered by the Trustee, and (iii) ordering Mr. Cao to turn over the Four Motorcycles to the Trustee.

⁵ The two motorcycles were turned over to the Trustee without their electronic keys. The Trustee is in the process of obtaining new sets of keys and intends to seek authority to sell these motor vehicles shortly thereafter.

22. On April 12, 2024, the Trustee filed a motion for judgment on the pleadings [Adv. Proc. No, 24-05001, Docket No. 19] in connection with his claims regarding the Four Motorcycles in the Cao Adversary Proceeding, which motion was briefed and argued before the Court on May 24, 2024.

23. On September 9, 2024, the Court granted the Trustee's motion [Adv. Proc. No. 24-05001, Docket No. 33], finding that the Debtor was the beneficial owner of the Four Motorcycles, and ordering the turnover of the Four Motorcycles and transfer of their titles to the Trustee (the "Motorcycle Order"). Soon after the entry of the Motorcycle Order, the Trustee obtained possession of the Four Motorcycles. In January 2025 the Trustee obtained title to the Harley and the BMW.

## **IV. The Ducati Motorcycle**

24. By motion dated May 10, 2024, filed with the consent of the then-registered owner of the Ducati, Scott Barnett [Main Case Docket No. 3177], the Trustee sought entry of a consent order declaring the Ducati to be the property of the Estate and transferring ownership of the Ducati from Scott Barnett to the Individual Debtor's Chapter 11 estate.

25. On May 28, 2024, the Court entered the *Consent Order Regarding Transfer of Ownership of Ducati Motorcycle to Estate* [Main Docket No. 3220] (the "Ducati Order"), finding that the Ducati is exclusively property of the Debtor's estate to be administered by the Trustee and ordering the turnover of the Ducati to the Trustee, free and clear of all liens, claims, interests and encumbrances. Shortly after entry of the Ducati Order, the Trustee obtained possession of the Ducati and began the process of transferring the title of the Ducati.

26. In October 2024, the Trustee obtained title to the Ducati.

### **V. Greenwich Land and Turnover of the Lexus**

27. On March 27, 2023, the Trustee initiated an adversary proceeding by filing a Complaint [Docket No. 1, in Adv. Proc. No. 23-5005 (the "Greenwich Land A.P.")] against Greenwich Land, LLC ("Greenwich Land" and Hing Chi Ngok "Ms. Ngok" and, together with Greenwich Land, collectively, the "Defendants"), seeking, among other things, (i) a ruling declaring that Greenwich Land is an alter ego of the Debtor and ordering turnover of its assets, including the real and personal property located at 373 Taconic Road, Greenwich, Connecticut (the "Greenwich Property"), to the Trustee, and (ii) a ruling declaring that the membership interest in Greenwich Land is property of the Estate and ordering the surrender of such membership interest to the Trustee.

28. On July 2, 2024, for the reasons stated on the record and further set forth in the Court's Memorandum of Decision and Order Granting Motion for Summary Judgment [Docket No. 133 in Adv. Proc. No. 23-5005], the Court granted summary judgment in favor of the Trustee in the Greenwich Land A.P. [Docket No. 134 in Adv. Proc. No. 23-5005] (the "SJ Order"), finding, among other things, that the Greenwich Property is property of the Estate to be administered by the Trustee, and ordering the turnover of the Greenwich Property to the Trustee.

29. On July 10, 2024, the Defendants filed a notice of their appeal (the "Appeal") with respect to the SJ Order [Docket No. 138 in Adv. Proc. No. 23-5005]. On July 12, 2024, the Defendants filed a motion for stay pending the Appeal [Docket No. 139 in Adv. Proc. No. 23- 5005] (the "Stay Motion") in the Greenwich Land A.P.

30. On August 16, 2024, the Court entered its Consent Order Resolving Motion for Stay Pending Appeal and Enforcing Summary Judgment [Docket No. 166 in Adv. Proc. No. 235005] ("Consent Order"), pursuant to which, on August 20, 2024, (a) the Trustee assumed

possession of the Greenwich Property and its contents for the benefit of the Estate; and (b) the Defendants withdrew the Stay Motion with prejudice. The Lexus is one of the items of personal property at the Greenwich Property turned over to the Trustee pursuant to the Consent Order.

31. In January 2025, the Trustee obtained title to the Lexus.

## **VI. The Auctioneer**

32. On January 31, 2025, the Applicants filed a Motion to Employ and Appoint Hamilton as auctioneer to market and sell the First Vehicle Group, the Genever US Property and other personal property [the "Retention Application" ECF No. 4021]. Hamilton has significant experience conducting auctions and has been retained to provide auction services to chapter 7 trustees in several bankruptcy cases in this district. By Order dated February 27, 2025, [ECF 4180] Hamilton has been retained to provide auction services regarding the sale of motor vehicles, including the First Vehicle Group. The balance of the Retention Application, regarding the sale of other personal property, has been adjourned until the hearing on this Application.

### **RELIEF REQUESTED**

# **a. Approval of the Sale of the First Vehicle Group and Genever US Property and Conduct of Auction**

33. Based upon their investigation and consultations with auction professionals, Genever US and the Trustee have determined that a public auction of the First Vehicle Group and Genever US Property with extensive advertising to expose the assets to the public market is the most likely method to maximize the value of the personal property for the benefit of the Estates.

34. Hamilton estimates the value of the Genever US Property (consisting of more than 150 pieces of personal property) at \$25,000.00 and the value of the First Vehicle Group at \$65,000. Hamilton has obtained surety bonds in the aggregate amount of \$150,000.00 and provided the original bonds to the Office of the United States Trustee (the "Bonds"). A copy of the Bonds are attached hereto as **Exhibit D**.

35. The online only Auction will be conducted for fourteen days through Auction Ninja via the URL http Based on information obtained from Hamilton, the Applicants believe that the use of Auction Ninja is the appropriate platform for the sale of the First Vehicle Group and Genever US Property. Auction Ninja is a leader in event-based online auctions and notices potential buyers from its own list of auctions, thus increasing the targeted market for the First Vehicle Group and Genever US Property.

36. Neither the Applicants nor Hamilton has any known connection with the proposed internet auction mechanism or any expected bidder. Each participating bidder at the auction will be required to certify through acceptance of the auction terms on Auction Ninja that it has not engaged and will not engage in any collusion with respect to the bidding or the Auction. Auction Ninja's services shall be limited to access to its automated online service and related customer support. The Applicants believe that there are no rules, policies, procedures, terms or conditions set by Auction Ninja likely to restrict bidding for the First Vehicle Group and Genever US Property. Auction Ninja is seeking a final value fee of 2.35% of the Auction proceeds for its services. In order to prevent "snipping bids" Auction Ninja employs a dynamic closing, allowing additional bidding by extending the auction time for an additional five minutes in the event a bid is placed on a lot or item within the final five minutes of the auction. The Auction ends at its closing time if no bids are placed within the final five minutes.

37. Consistent with Local Bankruptcy Rule 6004-1, advertising for the Auction will occur for at least fourteen (14) days. Advertising shall be geared to interior decorators, antique

collectors, homeowners, and dealers plus other potential end users and will be marketed on several online sites such as Facebook, Auctionzip.com, and Craigslist as well as other online auction calendars. Direct mailings will be sent to a select list of buyers. In addition, email blasts will be sent to a list of approximately 15,000 potential buyers.

38. In accordance with Local Bankruptcy Rules 6004-1 and 6004-2, the proposed terms of the Auction are as follows:

(a) The Auction will commence fourteen (14) days after the entry of the order approving the Application. A full catalogue and photographs of the items that constitute the First Vehicle Group and the Genever US Property, as noted on **Exhibit B**, will be posted on the Auction website by Hamilton.

(b) Removal of purchased items will be conducted and coordinated by Genever US, the Trustee and Hamilton and will occur within three days of the close of the Auction. A Hamilton representative will be onsite at the New Jersey Storage Facility to assist in the removal of the Genever US Property purchased items. A Hamilton representative will also be available at its Connecticut location to coordinate the removal of the First Vehicle Group purchased items.

(c) The First Vehicle Group and Genever US Property will be sold "as is, where is, with all faults" with no representations or warranties. Genever US or the Trustee may set a reserve price as deemed appropriate for specific items. The reserve price may be disclosed to bidders or set as the starting bid for those items.

(d) Genever US and the Trustee reserve the right to continue the Auction from time to time as necessary.

39. The Trustee requests that his attendance at the closing on any sales from the Auction, to the extent required by the Local Bankruptcy Rules, be excused.

40. Hamilton will file a report subsequent to the Auction, setting forth the results of the Auction and such additional information as may be required by Local Bankruptcy Rule 6005- 1. Funds collected from the Auction will be deposited into Hamilton's escrow account at Wells Fargo Bank or Citizens Bank. These funds will be turned over to the Trustee and Genever US within five business days of the close of the Auction.

### **B. Approval of the Form of Notice of Sale of Estate Property**

41. The Trustee seeks to have Hamilton conduct the Auction as soon as practicable after obtaining an order approving the Application and the balance of the Retention Application. Genever US and the Trustee have attached a form Notice of Sale of Estate Property (Appendix O of the Local Bankruptcy Rules) as **Exhibit C** (the "Notice") with details of the proposed Auction and seek approval the form of the Notice.

### **BASIS FOR RELIEF**

### **C. Sale Free and Clear of Liens, Claims and Interests**

42. Section 363(b) of the Bankruptcy Code authorizes the sale of assets other than in the ordinary course of its business after notice and hearing. Additionally, Bankruptcy Rule 6004(f) authorizes the sale of estate property outside the ordinary course of business by private sale or public auction.

43. The sale of assets outside the ordinary course of business is based upon the sound business judgment of the trustee. See e.g. *In re Chateaugay Corp*., 973 F.2d 141 (2d Cir. 1992); *Comm. of Equity Security Holders v. Lionel Corp. (In re Lionel Corp.),* 772 F.2d 1063, 1071 (2d Cir. 1983). The Auction of the First Vehicle Group and Genever US Property is a sound business judgment that will limit storage costs and monetize assets for the benefit of the Estates'

creditors.

44. Pursuant to section 363(f) of the Bankruptcy Code, a sale may be approved free and clear of liens if (1) applicable non-bankruptcy law permits sale of such property free and clear of such interest; (2) such entity consents (3) such interest is a lien and the price at which the property is sold exceeds the aggregate value of the liens on such property; (4) a bona fide dispute exits or (5) the entity could be compelled to accept monetary satisfaction of such interest.

45. A lien search and search of title records has indicated that there are no liens or encumbrances affecting the First Vehicle Group and Genever US Property.

46. For the foregoing reasons, Genever US and the Trustee request the approval of the sale of the First Vehicle Group and Genever US Property by public auction free and clear of liens, claims and encumbrances.

### **NOTICE**

47. Notice of this Motion has been given to the United States Trustee, the Individual Debtor, the Committee, and, by electronic filing utilizing the Court's electronic filing ("CM/ECF") system, to all appearing parties who utilize the CM/ECF system.

WHEREFORE, the Applicants request that the Court enter an Order, substantially in the form of the Proposed Order filed herewith, granting the Application, and such other relief as the Court deems just and proper.

Dated: April 8, 2025 GENEVER HOLDINGS, LLC AND LUC A. DESPINS, New Haven, Connecticut CHAPTER 11 TRUSTEE

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

*Counsel for Genever Holdings, LLC and the Chapter 11 Trustee*

Case 22-50073 Doc 4301 Filed 04/08/25 Entered 04/08/25 17:07:48 Page 15 of 43

## **EXHIBIT A**

**Proposed Order**

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

| x | | | | | |------------------------------|-------------|-------------------------|--|--| | | : | | | | | In re: | : | Chapter 11 | | | | 1<br>HO WAN KWOK,<br>et al., | :<br>:<br>: | Case No. 22-50073 (JAM) | | | | Debtors. | :<br>: | (Jointly Administered) | | | | | | | | | | | x | | | |

## **ORDER APPROVING SALE OF CERTAIN PERSONAL PROPERTY BY PUBLIC AUCTION FREE AND CLEAR OF ALL LIENS, CLAIMS AND INTERESTS AND FORM OF NOTICE OF SALE**

Upon the application (the "Application") of Luc A. Despins, in his capacity as the chapter 11 trustee (the "Trustee") of Ho Wan Kwok (the "Debtor"), debtor in these above-captioned jointly administered cases (the "Chapter 11 Cases" and/or "Estates"), and Genever Holdings, LLC ( "Genever US," together with the Trustee, the "Applicants") requesting entry of an order, (this "Order") approving (i) the sale by public auction of certain personal property as more particularly identified on **Exhibit B** attached hereto (the "Genever US Property" and "First Vehicle Group") free and clear of all liens and encumbrances; and (ii) the form of the Notice of Sale of Estate Property substantially in form attached as **Exhibit C** hereto (the "Notice of Sale"); and the Court having reviewed the Application and having considered the statements of counsel before the Court at a hearing held on \_\_\_\_\_\_\_\_\_\_\_\_\_\_\_ (the "Hearing"); and the Court having found that (a) the Court has jurisdiction over this matter pursuant to 28 U.S.C. §§ 157 and 1334;

¹ The Debtors in these chapter 11 cases are Ho Wan Kwok (also known as Guo Wengui, Miles Guo, and Miles Kwok, as well as numerous other aliases) (last four digits of tax identification number: 9595), Genever Holdings LLC (last four digits of tax identification number: 8202) and Genever Holdings Corporation. The mailing address for the Trustee, Genever Holdings LLC, and the Genever Holdings Corporation is Paul Hastings LLP, 200 Park Avenue, New York, NY 10166 c/o Luc A. Despins, as Trustee for the Estate of Ho Wan Kwok (solely for purposes of notices and communications).

(b) this is a core proceeding pursuant to 28 U.S.C. § 157(b); (c) venue is proper pursuant to 28 U.S.C. §§ 1408 and 1409; and (d) good and sufficient notice of the Application having been given; and no other or further notice being required; and the Court having determined that the relief sought in the Application is in the best interest of the Applicants, their estates, creditors, and all parties in interest, therefor;

## IT IS HEREBY ORDERED THAT:

1. The Application is approved in all respects;

2. Genever US and the Trustee are authorized to consummate the sale of the Genever US Property and First Vehicle Group free and clear of all liens, claims and interests pursuant to 11 U.S.C. Sections 363(b) by public auction to be conducted by The Hamilton Group LLC on the terms and conditions set forth in the Application; and

3. The Notice of Sale is approved.

## **EXHIBIT B (see catalog of Genever US Property attached hereto)**

**The Hamilton Group, LLC Auctioneers & Appraisers 36 Killingworth Turnpike Clinton, CT 06413 Phone: 203-433-8052 Fax: 203-643-2285** Case 22-50073 Doc 4301 Filed 04/08/25 Entered 04/08/25 17:07:48 Page 19 of 43

### **Ho Wan Kwook Sherry Netherland 3/31/2025**

### **LOT #**


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## **EXHIBIT C**

## **NOTICE OF SALE OF ESTATE PROPERTY (draft Appendix O attached hereto)**

###

|   | | | | | |-----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|-------------------------------------------------------------------------------|----------------------------------------------------|--|--| |      | |  <br> | | | |  | |  | | | | |  | | | | |         | | | | | |        | | | | | |    | | <br><br><br><br><br> | | | |     <br>     | |      | | | |     | | | | | | | |       | | | | Attorney for:<br> |      <br>Genever Holdings, LLC | | | | | Individual appearing without attorney | | | | | |              <br>                    <br>                     <br>           | | | | | |       | | | | | | <br><br><br><br><br><br><br><br><br><br><br><br><br><br><br><br><br><br><br><br>                    <br>     <br>The catalog can be obtained by contacting the Auctioneer.<br>    <br> <br>  <br>    | | | | | | <br><br> | | | | | |     |  |     | | | |  <br>   <br> <br> | | | | | |                    | | | | | | |  | <br><br><br> | | | | |        <br>    | | | | | |     <br>  |  | | | | |    | | | |

include name, address, telephone, fax and/or email address

##

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|  |   |  | | | |---------------------------------------------------------------------------------------------------------|--------------|-----------|--|--| |                    | | | | |

Case 22-50073 Doc 4301 Filed 04/08/25 Entered 04/08/25 17:07:48 Page 35 of 43

## **EXHIBIT D**

**Copy of Bond COPIES OF BONDS** Bond Number: 0862842

### AUCTIONEER BOND

KNOW ALL MEN BY THESE PRESENTS that we, THE HAMILTON GROUP, LLC (hereinafter called Principal), as Principal, and the HARCO NATIONAL INSURANCE COMPANY, its home office in Raleigh, Nc 27605 (hereinafter called Surety), as Surety, are held and firmly bound unto the UNITED STATES OF AMERICA (hereinafter called Obligee), in the full and just sum of SEVENTY FIVE THOUSAND AND NO/100 (\$75,000.00) Dollars, for the payment of which, well and truly to be made, the Principal and Surety hereby bind themselves, their heirs, executors, administrators, successors and assigns, jointly and severally, firmly by these presents.

NOW THEREFORE, the condition of this obligation is such that if the said Principal shall faithfully account for all money, assets and effects of bankruptcy case, HO WAN KWOK, ET AL; CASE #22-50073JAM , in which the Principal is serving as auctioneer, then this obligation to be void; otherwise to remain in full force in effect.

The liability of the Surety hereunder shall not exceed the aggregate sum of SEVENTY FIVE THOUSAND AND NO/100 (\$75,000.00) Dollars, for all claims asserted against this bond.

This bond shall remain in full force and effect from JANUARY 16, 2025 to APRIL 16, 2025. This bond may not be cancelled or terminated without sixty (60) days notice being given to the clerk and the United States Trustee.

SIGNED AND SEALED THIS 16TH day of JANUARY, 2025.

THE HAMILTON GROUP, LLC

HARCO NATIONAL INSURANCE COMPANY

By:

CATHERINE C. KEHOE, ATTORNEY-IN-FACT

## POWER OF ATTORNEY

### HARCO NATIONAL INSURANCE COMPANY

INTERNATIONAL FIDELITY INSURANCE COMPANY

Member companies of IAT Insurance Group, Headquartered: 4200 Six Forks Rd, Suite 1400, Raleigh, NC 27609

KNOW ALL MEN BY THESE PRESENTS: That HARCO NATIONAL INSURANCE COMPANY, a corporation organized and existing under the laws of the State of Illinois, and INTERNATIONAL FIDELITY INSURANCE COMPANY, a corporation organized and existing under the State of New Jersey, and having their principal offices localed respectively in the cities of Rolling Meadows, New Jersey, do hereby constitute and appoint

SARA S. DEJARNETTE, CONVAY C. MARSHALL, STEPHEN BEAHM, ELIZABETH SCHOTT, DAVID C. JOSEPH, JESSICA PALMER, KELLI R. CROSS, AMANDA RIEDL, ANDRE AUTIN, VICTORIA SCRUGGS, CLARK P. FITZ-HUGH, CATHERINE C. KEHOE, KRISTINE DONOVAN

### New Orleans, LA.

their true and lawful attorney(s)-in-fact to execute, seal and deliver for and on its behalf as surely, any and all bonds and undertakings, contracts of indemnity and other writings obligatory in the ne or may be allowed, required or permitted by law, statute, rule, regulation, contract or otherwise, and the execution of such in these presents, shall be as binding upon the said HARCO NATIONAL INSURANCE COMPANY and INTERNATIONAL FIDELITY INSURANCE COMPANY, as fully and and puroses, as if the same had been duly executed and acknowledged by their regularly elected officers at their principal offices.

This Power of Attorney is execuled, and may be revoled, pursuant to and by authority of the By-Laws of HARCO NATIONAL INSURANY and INTERNATIONAL FIDELITY INSURANCE COMPANY and is granted under and by authority of the following resolution adopted by the Board of Directors of INTERNATIONAL FIDELITY INSURANCE COMPANY at a meeting duly held on the 13th day of December, 2018 and by the Board of Directors of HARCO NATIONAL INSURANCE COMPANY at a meeting held on the 13th day of December, 2018.

"RESOLVED, that (1) the Chief Executive Vice President, Senior Vice President, Vice President, Vice President, or Secretary of the Corporation shall have the power to appointments of, Attorneys-in-Fact or agents with power and authority as defined or limiled in their respective powers of attorney, and to execute on behalf of the Corporation's seal there's, bonds, undertakings, recognizances, contracts of indemnity and other written obligations in the nature thereo; and (2) any such Officers of the Corporation may appoint and revole the appointments of interest caceptance of process, and Attorneys-in-fact with authority to execute waivers and consents on behalf of the Corporation of any such Officer of the Corporation and the Corporation's seal may be affixed by facsimile to any power of attorney or the execution of any bond, undertaking, recognizance, contract of indemnity or other written obligation in the nature thereof or related there and seals when so used whether heretofore or hereafter, being hereby adopted by the Corporation as the original signature of such of the Corporation, to be valid and binding upon the Corporation with the same force and effect as though manually affixed."

> IN WITNESS WHEREOF, HARCO NATIONAL INSURANCE COMPANY and INTERNATIONAL FIDELITY INSURANCE COMPANY have each executed and attested these presents on this 31st day of December, 2024


STATE OF NEW JERSEY County of Essex

STATE OF ILLINOIS County of Cook


Michael F. Zurcher Executive Vice President, Harco National Insurance Company and International Fidelity Insurance Company

, before me came the individual who executed the preceding instrument, to me personally known, and, On this 31st day of December. 2024 being by me duly sworn, said he is the therein described and authorized officer of HARCO NATIONAL INSURANCE COMPANY and INTERNATIONAL FIDELITY INSURANCE COMPANY; that the seals affixed to said instrument are the Corporates; that the said Corporate Seals and his signature were duly affixed by order of Directors of said Companies.


IN TESTIMONY WHEREOF, I have hereunto set my hand affixed my Official Seal, at the City of Newark, New Jersey the day and year first above written.

Cathy Cruz a Notary Public of New Jersey My Commission Expires April 16, 2029

### CERTIFICATION

I, the undersigned officer of HARCO NATIONAL NSURANCE COMPANY and INTERNATIONAL FIDELITY INSURANCE COMPANY do hereby certify that I have compared the foregoing copy of the Power of Attorney and affidavit, and the By-Laws of said Companies as set forth in said Power of Attorney, with the home office of said companies, and that the same are correct transcripts thereof, and of he whole of the said originals, and that the said Power of Attorney has not been revoked and is now in full force and effect.

IN TESTIMONY WHEREOF, I have hereunto set my hand on this day, January 16, 2025

Irene Martins, Assistant Secretary

Bond Number: 0866857

### AUCTIONEER BOND

KNOW ALL MEN BY THESE PRESENTS that we, THE HAMILTON GROUP, LLC (hereinafter called Principal), as Principal, and the HARCO NATIONAL INSURANCE COMPANY, its home office in Raleigh, Nc 27605 (hereinafter called Surety), as Surety, are held and firmly bound unto the UNITED STATES OF AMERICA (hereinafter called Obligee), in the full and just sum of TWENTY THOUSAND AND NO/100 (\$20,000.00) Dollars, for the payment of which, well and truly to be made, the Principal and Surety hereby bind themselves, their heirs, executors, administrators, successors and assigns, jointly and severally, firmly by these presents.

NOW THEREFORE, the condition of this obligation is such that if the said Principal shall faithfully account for all money, assets and effects of bankruptcy case, HO WAN KWOK, ET AL; CASE 22-50073JAM TO AUCTION 2017 LEXUS NX 200T, in which the Principal is serving as auctioneer, then this obligation to be void; otherwise to remain in full force in effect.

The liability of the Surety hereunder shall not exceed the aggregate sum of TWENTY THOUSAND AND NO/100 (\$20,000.00) Dollars, for all claims asserted against this bond.

This bond shall remain in full force and effect from JANUARY 24, 2025 to APRIL 24, 2025. This bond may not be cancelled or terminated without sixty (60) days notice being given to the clerk and the United States Trustee.

SIGNED AND SEALED THIS 24TH day of JANUARY, 2025.

THE HAMILTON GROUP, LLC

HARCO NATIONAL INSURANCE COMPANY

By:

CATHERINE C. KEHCE, ATTORNEY-IN-FACT

## POWER OF ATTORNEY

### HARCO NATIONAL INSURANCE COMPANY

INTERNATIONAL FIDELITY INSURANCE COMPANY

Member companies of IAT Insurance Group, Headquartered: 4200 Six Forks Rd, Suite 1400, Raleigh, NC 27609

KNOW ALL MEN BY THESE PRESENTS: That HARCO NATIONAL INSURANCE COMPANY, a corporation organized and existing under the laws of the State of Illinois, and INTERNATIONAL FIDELITY INSURANCE COMPANY, a corporation organized and existing under the State of New Jersey, and having their principal offices located respectively in the cities of Rolling Meadows, Illinois and Newark, New Jersey, do hereby constitute and appoint

SARA S. DEJARNETTE, CONVAY C. MARSHALL, STEPHEN BEAHM, ELIZABETH SCHOTT, DAVID C. JOSEPH, JESSICA PALMER, KELLI R. CROSS, AMANDA RIEDL, ANDRE AUTIN, VICTORIA SCRUGGS, CLARK P. FITZ-HUGH, CATHERINE C. KEHOE, KRISTINE DONOVAN

### New Orleans, LA.

their true and lawful attorney(s)-in-fact to execute, seal and deliver for and all bonds and undertakings, ontracts of indemity and other writings obligatory in the nature there or may be allowed, required or permitted by law, statute, regulation, contract or otherwise, and the execution of such in pursuance of these presents, shall be as binding upon the said HARCO NATIONAL INSURANCE COMPANY and INTERNATIONAL FIDELITY INSURANCE COMPANY, as fully and amply, to all intents and purposes, as if the same had been duly executed and acknowledged by their regularly elected officers at their principal offices.

This Power of Attorney is executed, and may be revoled, pursuant to and by authority of the By-Laws of HARCO NATIONAL INSURANY and INTERNATIONAL FIDELITY INSURANCE COMPANY and is granted under and by authority of the following resolution adopted by the Board of Directors of NTERNATIONAL FIDELITY INSURANCE COMPANY at a meeting duly held on the 13th day of December, 2018 and by the Board of Directors of HARCO NATIONAL INSURANCE COMPANY at a meeting held on the 13th day of December, 2018.

"RESOLVED, that (1) the Chief Executive Vice President, Senior Vice President, Vice President, Vice President, or Seretary of the Corporation shall have the power to appointments of, Attorneys-in-Fact or agents with power and authority as defined or imiled in their respective powers of attorney, and to execute of the Corporation's seal therei, bonds, undertakings, recognizances, contracts of indemnity and other written obligations in the nature thereof or related therelo; and (2) any such Officers of the Corporation may appoint and revole the appointments of joints for acceptance of process, and Attorneys-in-fact with authority to execute waivers and consents on behalf of the Corporation of any such Officer of the Corporation and the Corporation's seal may be affixed by facsimile to any power of attorney or che execution of any bond, undertaking, recognizance, contract of indemnity or other written obligation in the nature thereof or related there and seals when so used whether heretofore or hereafler, being hereby adopted by the Corporation as the original signature of such of the Corporation, to be valid and binding upon the Corporation with the same force and effect as though manually affixed."

> IN WITNESS WHEREOF, HARCO NATIONAL INSURANCE COMPANY and INTERNATIONAL FIDELITY INSURANCE COMPANY have each executed and attested these presents on this 31st day of December, 2024


STATE OF NEW JERSEY County of Essex

STATE OF ILLINOIS County of Cook


Michael F. Zurcher Executive Vice President, Harco National Insurance Company and International Fidelity Insurance Company

On this 31st day of December, 2024 , before me came the individual who executed the preceding instrument, to me personally known, and, being by me duly sworn, said he is the therein described and authorized officer of HARCO NATIONAL INSURANCE COMPANY and INTERNATIONAL FIDELITY INSURANCE COMPANY; that the seals affixed to said instrument are the Corporates; that the said Corporate Seals and his signature were duly affixed by order of Directors of said Companies.


IN TESTIMONY WHEREOF, I have hereunto set my hand affixed my Official Seal, at the City of Newark, New Jersey the day and year first above written.

a Notary Public of New Jersey Cathy Cruz My Commission Expires April 16, 2029

### CERTIFICATION

I, the undersigned officer of HARCO NATIONAL INSURANCE COMPANY and INTERNATIONAL FIDELITY INSURANCE COMPANY do hereby certify that I have compared the foregoing copy of the Power of Attorney and affidavit, and the By-Laws of said Companies as set forth in said Power of Attorney, with the home office of said companies, and that the same are correct transcripts thereof, and of the whole of the said originals, and that the said Power of Attorney has not been revoked and is now in full force and effect.

IN TESTIMONY WHEREOF, I have hereunto set my hand on this day, January 24, 2025

Irene Martins, Assistant Secretary

Bond Number: 0866884

### AUCTIONEER BOND

KNOW ALL MEN BY THESE PRESENTS that we, THE HAMILTON GROUP, LLC (hereinafter called Principal), as Principal, and the HARCO NATIONAL INSURANCE COMPANY, its home office in Raleigh, Nc 27605 (hereinafter called Surety), as Surety, are held and firmly bound unto the UNITED STATES OF AMERICA (hereinafter called Obligee), in the full and just sum of TWENTY THOUSAND AND NO/100 (\$20,000.00) Dollars, for the payment of which, well and truly to be made, the Principal and Surety hereby bind themselves, their heirs, executors, administrators, successors and assigns, jointly and severally, firmly by these presents.

NOW THEREFORE, the condition of this obligation is such that if the said Principal shall faithfully account for all money, assets and effects of bankruptcy case, HO WAN KWOK, ET AL; CASE #22-50073JAM TO AUCTION 2021 DUCATI DIAVEL, in which the Principal is serving as auctioneer, then this obligation to be void; otherwise to remain in full force in effect.

The liability of the Surety hereunder shall not exceed the aggregate sum of TWENTY THOUSAND AND NO/100 (\$20,000.00) Dollars, for all claims asserted against this bond.

This bond shall remain in full force and effect from JANUARY 30, 2025 to APRIL 30, 2025.This bond may not be cancelled or terminated without sixty(60) days notice being given to the clerk and the United States Trustee.

SIGNED AND SEALED THIS 30TH day of JANUARY, 2025.

THE HAMILTON GROUP, LLC

HARCO NATIONAL INSURANCE COMPANY

By:

CATHERINE C. KEHOE, ATTORNEY-IN-FACT

## POWER OF ATTORNEY

### HARCO NATIONAL INSURANCE COMPANY

INTERNATIONAL FIDELITY INSURANCE COMPANY

Member companies of IAT Insurance Group, Headquartered: 4200 Six Forks Rd, Suite 1400, Raleigh, NC 27609

KNOW ALL MEN BY THESE PRESENTS: That HARCO NATIONAL INSURANCE COMPANY, a corporation organized and existing under the laws of the State of Illinois, and INTERNATIONAL FIDELITY INSURANCE COMPANY, a corporation organized and existing under the State of New Jersey, and having their principal offices located respectively in the cities of Rolling Meadows, Illinois and appoint

SARA S. DEJARNETTE, CONVAY C. MARSHALL, STEPHEN BEAHM, ELIZABETH SCHOTT, DAVID C. JOSEPH, JESSICA PALMERI, KELLI R. CROSS, AMANDA RIEDL, ANDRE AUTIN, VICTORIA SCRUGGS, CLARK P. FITZ-HUGH, CATHERINE C. KEHOE, KRISTINE DONOVAN

### New Orleans, LA.

their true and lawful attorney(s)-in-fact to execute, seal and deliver for and all bonds and undertakings, contracts of indemnity and other writings obligatory in the natured, which are or may be allowed, required by law, statute, rule, requlation, contract or otherwise, and the execution of such in pursuance of these presents, shall be as binding upon the said HARCO NATIONAL INSURANCE COMPANY and INTERNATIONAL FIDELITY INSURANCE COMPANY, as fully and amply, to all intents and purposes, as if the same had been duly executed and acknowledged by their regularly elected officers at their principal offices.

This Power of Attorney is executed, and may be revoled, pursuant to and by authority of the By-Laws of HARCO NATIONAL INSURANY and INTERNATIONAL FIDELITY INSURANCE COMPANY and is granted under and by authority of the following resolution adopted by the Board of Directors of NTERNATIONAL FIDELITY INSURANCE COMPANY at a meeting duly held on the 13th day of December, 2018 and by the Board of Directors of HARCO NATIONAL INSURANCE COMPANY at a meeting held on the 13th day of December, 2018.

"RESOLVED, that (1) the Chief, President, Executive Vice President, Senior Vice President, Vice President, or Seretary of the Corporation shall have the power to appointments of, Attorneys-in-Fact or agents with power and authority as defined or limited in their respective powers of attorney, and to execute of the Corporation and affix the Corporation's seal thereig, bonds, undertakings, recognizances, contracts of indemnity and other obligations in the nature thereo; and (2) any such Officers of the Copporation may appoint and revole the appointments of initial casedance of process and Attorneys-in-fact with authority to execute waivers and consents on behalf of the Corporation of any such Officer of the Corporation and the Corporation's seal may be affixed by facsimile to any power of attorney or the execution of any bond, undertaking, recognizance, contract of indemnity or other written obligation in the nature thereof or related there and seals when so used whether hereafter, being hereby adopted by the Corporation as the original signature of such al seal of the Corporation, to be valid and binding upon the Corporation with the same force and effect as though manually affixed."

> IN WITNESS WHEREOE, HARCO NATIONAL INSURANCE COMPANY and INTERNATIONAL FIDELITY INSURANCE COMPANY have each executed and attested these presents on this 31st day of December, 2024


STATE OF NEW JERSEY County of Essex

STATE OF ILLINOIS County of Cook


Michael F. Zurcher Executive Vice President, Harco National Insurance Company and International Fidelity Insurance Company

On this 31st day of December, 2024 , before me came the individual who executed the preceding instrument, to me personally known, and, being by me duly sworn, said he is the therein described and authorized officer of HARCO NATIONAL INSURANCE COMPANY and INTERNATIONAL FIDELITY INSURANCE COMPANY; that the seals affired to said instrument are the Corporates that the said Corporate Seals and his signature were duly affixed by order of Directors of said Companies.


IN TESTIMONY WHEREOF, I have hereunto set my hand affixed my Official Seal, at the City of Newark, New Jersey the day and year first above written.

Cathy Cruz a Notary Public of New Jersey My Commission Expires April 16, 2029

### CERTIFICATION

I, the undersigned officer of HARCO NATIONAL COMPANY and INTERNATIONAL FIDELITY INSURANCE COMPANY do hereby certify that I have compared the foregoing copy of the Power of Attorney and affidavit, and the By-Laws of said Companies as set forth in said Power of Attorney, with the home office of said companies, and that the same are correct transcripts thereof, and of the whole of the said originals, and that the said Power of Attorney has not been revoked and is now in full force and effect.

IN TESTIMONY WHEREOF, I have hereunto set my hand on this day, January 30, 2025

Irene Martins, Assistant Secretary

Bond Number: 0867090

### AUCTIONEER BOND

KNOW ALL MEN BY THESE PRESENTS that we, THE HAMILTON GROUP, LLC (hereinafter called Principal) as Principal, and the HARCO NATIONAL INSURANCE COMPANY, its home office in Raleigh, and the HA (hereinafter called Surety), as Surety, are held and firmly bound unto the UNITED STATES OF AMERICA (hereinafter called Oblige), in the full and just sum of THIRTY FIVE THOUSAND AND NO/100 (\$35,000.00) Dollars, for the payment of which, well and truly to be made, the Principal and Surety hereby bind themselves, their heirs, executors, administrators, successors and assigns, jointly and severally, firmly by these presents.

NOW THEREFORE, the condition of this obligation is such that if the said Principal shall faithfully account for all money, assets and NETHERIAND SUCTION . In WAN KWOX; CASE #22-50073 (JAM) (SHERRY NETHERLAND AUCTION) , in which the Principal is serving as auctioneer, then this obligation to be void; otherwise to remain in full force in effect.

The liability of the Surety hereunder shall not exceed the aggregate sum of THIRTY FIVE THOUSAND AND NO/100 (\$35,000 .00) Dollars, for all claims asserted against this bond.

This bond shall remain in full force and effect from MARCH 24, 2025 to JUNE 24, 2025. This bond may not be cancelled or terminated without sixty(60) days notice being given to the clerk and the United States Trustee.

SIGNED AND SEALED THIS 24TH day of MARCH, 2025.

THE HAMILTON GROUP, LLC

HARCO NATIONAL INSURANCE COMPANY

CATHERINE C. KEHOE, ATTORNEY-IN-FACT

## POWER OF ATTORNEY HARCO NATIONAL INSURANCE COMPANY INTERNATIONAL FIDELITY INSURANCE COMPANY STATE COMPLENTERNATIONAL FIDELTTY INSURANCE COMPANY Member companies of IAT Insurance Group, Headquartered: 4200 Six Forks Rd, Suite 1400, Raleigh, NC 27609

KNOW ALL MEN BY THESE PRESENTS. That HARCO NATIONAL INSURANCE COMPANY (namized and existing under the laws of the State of INTERNATIONAL FIDELITY INSURANCE COMPANY, a comprai the even and in of The Series in This And Andres Compation organized and existing under the laws of the Six and INTERNATIONAL FIDELITY WSURANCE COMPANY, a concertion organize le call claimstill in LINA NORAL FICELLY INSURAID, a corporation organized and existing under the tales of the time of be the blev on bellev the ele

SARA S. DEJARNETTE, CONWAY C. MARSHALL, STEPHEN BEAHM, ELIZABETH SCHOTT, DAVID C. JOSEPH, JESSICA PALMER, LED R. CHART COMMENTE, GENVAT C. MARSHALL, STEPHEN BEARM, ELIZABETH SCHOTT, DAVID C. JOSEPH, JESSOR PALMER, KE CROSS, AMANDA RIEDL, ANDRE AUTIN, VICTORIA SCRUGGS, CLARK P. FITZ-HUGH

### New Orleans, LA.

their frue and lawful attorney(s)-in-fact to execute, seal and on its behalf as sure). any and all bonds and undertakings, contracts of indennity and other writing of the nature for and on its behalf as and an and undershings, controls of or otherwise, and the executived, which an or may be allowed negard of somes of the execution of such interials in the sering be alowed or permiled by law, statue, roy, statue, roy, statue, roy, statue, roy, statue, roy, repeal on on the said HA mather on the "xeculon" of sectiments" in posuance of here present, shall be brond on the said. Notes MSURANCE COMPANY and NYERNATIONAL FIDELLY (NSURAN') as ful been duly executed and acknowledged by their regularly elected officers at their principal offices at their principal offices.

This Power of Altoney is execuled, and may be revoled, pursuant to and by authority of the By-Laws of HARCO NATIONAL INSURANCE COMPANY and INTERNATIONAL METHAY BEWRE, pursent to and by authority of the By-Laws of HARCO NATIONAL MSURANCE CoMPAN Directors of INTERNATIONAL FIDELITY INSURANCE CoMPANY all the fil Drecors of INTERNET HOSKNEE COMPANY and Is and by authority of be followig resolution adoped of the Board of Directors of HARCO NATIONAL FOELITY NSURANC COMPANY at and and on Directors of HARCO NATIONAL INSURANCE COMPANY at a meeting duly held on the 13th day of December, 2018

"RESOLVED, that (1) the Chief Executive Officer President, Senio December Coronalion (r) the Une Leacher Onlier, President, Senior Vice President, Vice President, of bereday of the President, of bereday of he in hell be no your to appint, and it it the Circles of Altoneys-in-Fact or agens with be oeffied or imited on bindied on binder on befied or innele, recognizates by be be in ticency, and of the Corporation and affix the Corporations seal thereo, bonds, undertakings, undertakings, undertakings, may appoint and revoke in active within in the neue thereof or related thereo; wavers and consents on behalf in the stigative of a coseption of process, and Atheney-in-tact will autority to eacult by facsinile to any power of attores or control of the e by facsimile to any power of the synature of any such of the Corporation and the Corporation and the Corporation's sed may be all nay be all nay be anned of indemity on the w obligation in the nature here, such signature and seal when so weet when er encordence, contract of inemity or oher writer Corporation as the cities of class when so used when so used whether hereatler being here been by be force and effect as though manually affixed."

FIDELITY INSURANCE COMPANY have each executed and attested these presents on this 31st day of December 2024


STATE OF NEW JERSEY County of Essex

on this 31st day of December, 2024

IN WITNESS WHEREOF, HARCO NATIONAL INSURANCE COMPANY and INTERNATIONAL

STATE OF ILLINOIS County of Cook


Michael F. Zurche Executive Vice President, Harco National Insurance Company and International Fidelity Insurance Company

On this 31st day of December, 2024 . before me came the individual who execuled the preceding instrument, to me personally known, and, being by sworn, said he is the the cane the cane the institution of Harmer, to me personal MTERNATIONAL FIDELITY INSURANCE Cribed and authorized of HARCO NATIONAL INSURANCE INTERNATIONAL FIDELITY INSURANCE and atthorized of HARCO MATIONAL INSURANCE COMPANY and INTERNA TIONAL FIDELITY INSURANCE Of Hat the sais finstrument are the Corporate Seals said Corporate Seals and his signature were duly affixed to said instrument are the Corporation


IN TESTIMONY WHEREOF, I have hereunto set my hand affixed my Official Seal, at the City of Newark, New Jersey the day and year first above written.

Cathy Cruz a Notary Public of New Jersey My Commission Expires April 16, 2029

### CERTIFICATION

I. Ihe undersigned officer of HARCO NATIONAL NEURANCE COMPANY and INTERNATIONAL FIDELITY INSURANCE COMPANY do hereby certify that have compared the foregories of Altoney and INTERNATIONAL FIDELITY HISURANCE COMPANY on bereby cell forth in said Pover of Attorney and the botto been affay and the S fort in said Power of Atloney, with the home of and andard, and the Secions of the Berline of the By-Laws of the Breaties as sel whole of he sald originals on file hithe home whole of the said originals of this the sitten of hic in the none of said companies, and the same are con-

IN TESTIMONY WHEREOF, I have hereunto set my hand on this day. March 24, 2025

A00586

Irene Martins, Assistant Secretary