---
type: court_doc
id: "court_ctb_1061_1"
court: "CTB"
case_no: "22-50073"
doc_number: 1061
doc_type: "EXHIBIT"
filed_date: "2022-11-02"
lang: "en"
machine_translated: false
url: "https://mubeitech.com/en/court/court_ctb_1061_1"
json_url: "https://mubeitech.com/api/court/court_ctb_1061_1"
---
# Guo Wengui / Miles Guo — bankruptcy case · EXHIBIT · ECF #1061-1



EXHIBIT

A

Case 22-50073 Doc 1061-1 Filed 11/02/22 Entered 11/02/22 16:17:29 Page 2 of 12
UNITED STATES BANKRUPTCY COURT DISTRICT OF CONNECTICUT BRIDGEPORT DIVISION

In re　:
:
Chapter 11
HO WON KWOK,　:
:
Case No. 22-50073 (JAM)
Debtor.
__________________________________________:　:

REVISED PRIVILEGE LOG DOCUMENTS OF VERDOLINO & LOWEY AND BROWN RUDNICK

Bates　Date　Custodia　Type of　Parties　Subject　Claimed　Personal Harm

n　Document　Privilege
None　10/19/21　Verdolino
& Lowey　Agreement　Golden Spring
(New York)
Ltd., Kwok Ho
Wan, Ace
Decade
Holdings
Limited and
Dawn State　Litigation
Funding　Attorney-Work
Product.1　The withheld document
relates to an action
pending in the United
Kingdom styled Kwok
Ho Wan v. UBS AG,
Claim No. CL-2020-
000345 (High Court of
Justice Business and
Limited　Property Courts of
England and
Wales
Commercial Court)
(the

1 See Cont'l Circuits LLC v. Intel Corp, 435 F. Supp. 3d 1014, 1021 (D. AZ 2020) (concluding that litigation funding agreements were prepared because of litigation and therefore constitute attorney work product). See also Lambeth Magnetic Structures, LLC v. Seagate Tech (US) Holdings, Inc., 2017 U.S. Dist. LEXIS 215773, \*16-\*17 (W.D. Pa, Jan. 18, 2018) (holding that communications with litigation funders and funding agreement are work product and denying motion to compel the production of same).

"UK Action"). The

Bankruptcy Court's
September 14, 2022,
Consent Order
Regarding Control of
Attorney-Client
Privilege and Work
Product Protection
Related to Rule 2004
Subpoenaed
Documents
and Information (the
"Privilege Order")
specifically recognizes
that the Debtor may
have privileges under
the laws of the United
Kingdom that could be
asserted
by the Debtor
in the UK Action. See
Privilege Order, at sec.
9. The Debtor has thus
withheld
this document
from
production for the
express purpose of
ensuring that he is
preserving, and not
waiving, any privilege
that he may have
to
assert against production
or disclosure
of the
same document in the
UK Action.
Case 22-50073 Doc 1061-1 Filed 11/02/22 Entered 11/02/22 16:17:29 Page 4 of 12

BR_　10/19/21　Brown　Agreement　Golden Spring　Litigation　Attorney-Work　The withheld document

KWOK　Rudnick　(New York)　Funding　Product;　relates to the UK
00020991　Ltd., Kwok Ho　Common Interest　Action. The
Privilege
Wan, Ace　Order
specifically
Decade　recognizes that the
Holdings　Debtor may have
Limited and　privileges under the
Dawn State　laws of the United
Limited　Kingdom that could be
asserted
by the Debtor
in the UK Action. See
Privilege Order, at sec.
9. The Debtor has thus
withheld
this document
from
production for the
express purpose of
ensuring that he is
preserving, and not
waiving, any privilege
that he may have
to
assert against production
or disclosure
of the
same document in the
UK Action.
BR_　3/9/22　Brown　Email　Melissa Francis,　Advice　Attorney-Client.　The withheld document
KWOK　Rudnick　Thread　Esq.,
Jennifer　regarding　relates to advice from
00028970　Morrisey,　litigation　counsel representing the
Damon Parker,　fees and　Debtor in UK Action
Edward　the　and the impact
that the
Argles,2　potential　production of a

2 Ms. Morrisey, Mr. Parker and Mr. Argles are, or were at the time of the email, professionals employed by Harcus Parker Limited, the Debtor's UK counsel in the UK Action.

Bennett
Silverberg,
Esq., Aaron
Mitchell,
Esq.,
and Robert
Stark, Esq.　harm to the
Debtor in
the UK
Action of
the
production
of the UBS
litigation
funding
agreement
in response
to
discovery
requests
made to the
Debtor in
his
Bankruptcy
case.　document in the
Debtor's Bankruptcy
case could have on the
Debtor in the UK
Action.
The
Privilege
Order
specifically
recognizes that the
Debtor may have
privileges under the
laws of the United
Kingdom that could be
asserted
by the Debtor
in the UK Action. See
Privilege Order, at sec.
9. The Debtor has thus
withheld
this document
from
production for the
express purpose of
ensuring that he is
preserving, and not
waiving, any privilege
that he may have
to
assert against production
or disclosure of the
same document in the
UK Action.

BR_
KWOK
00028562;
22535　3/3/22　Brown
Rudnick　Invoice　Lalive SA –
Debtor's Swiss
counsel in
connection with
UBS action.　Invoice　Attorney-Client
(privilege may be
governed by
Swiss law)　The withheld document
is an invoice from
counsel representing the
Debtor in an action
pending in Switzerland
which action was filed
solely to preserve the

Debtor's rights to

pursue UBS in
Switzerland in the event
that a motion filed in the
UK
Action to move the
case from the UK to
Switzerland was
granted, it was not. The
case filed in
Switzerland,
and to
which the invoice
relates, is effectively the
same case as the UK
Action. The
Privilege
Order
specifically
recognizes that the
Debtor may have
privileges under the
laws of the United
Kingdom that could be
asserted
by the Debtor
in the UK Action. See
Privilege Order, at sec.
9. The Debtor has thus
withheld
this document
from
production for the
express purpose of
ensuring that he is
preserving, and not
waiving, any privilege
that he may have
to
assert against production
or disclosure
of the
Case 22-50073 Doc 1061-1 Filed 11/02/22 Entered 11/02/22 16:17:29 Page 7 of

same document in the
UK Action, whether
under UK law or Swiss
law.

BR_
KWOK
00027065　3/9/22　Brown
Rudnick　Email
Thread　Melissa Francis,
Esq.,
Jennifer
Morrisey,
Damon Parker,
Edward Argles,
Bennett
Silverberg,
Esq., Aaron
Mitchell, Esq.,
and Robert
Stark, Esq.　Advice
regarding
litigation
fees and
the
potential
harm to the
Debtor in
the UK
Action of
the
production
of the UBS
litigation
funding
agreement
in response
to
discovery
requests
made to the
Debtor in
his
Bankruptcy
case.　Attorney-Client.　The withheld document
relates to advice from
counsel representing the
Debtor in UK Action
and the impact
that the
production of a
document in the
Debtor's Bankruptcy
case could have on the
Debtor in the UK
Action.
The
Privilege
Order
specifically
recognizes that the
Debtor may have
privileges under the
laws of the United
Kingdom that could be
asserted
by the Debtor
in the UK Action. See
Privilege Order, at sec.
9. The Debtor has thus
withheld
this document
from
production for the
express purpose of
ensuring that he is
preserving, and not
waiving, any privilege
that he may have
to
assert against production
Case 22-50073 Doc 1061-1 Filed 11/02/22 Entered 11/02/22 16:17:29 Page 8 of

or disclosure of the

same document in the
UK Action.
BR_　3/17/22　Brown　Email　Melissa Francis,　Comments　Attorney-Client.　The withheld document
KWOK　Rudnick　Thread　Esq.,
Jennifer　from the　relates to advice from
00023917　Morrisey,　Debtor's　counsel representing the
Edward Argles,　UK Action　Debtor in UK Action
Bennett　counsel　regarding disclosures
to
Silverberg,　regarding　be made by the Debtor
Esq.,　the　in his Bankruptcy Court
description　filings related to the
UK
of the UK　Action. The
Privilege
Action to　Order
specifically
be utilized　recognizes that the
in the　Debtor may have
Debtor's　privileges under the
affidavit　laws of the United
and other　Kingdom that could be
Bankruptcy　asserted
by the Debtor
Court　in the UK Action. See
filings.　Privilege Order, at sec.
9. The Debtor has thus
withheld
this document
from
production for the
express purpose of
ensuring that he is
preserving, and not
waiving, any privilege
that he may have
to
assert against production
or disclosure of the
same document in the
UK Action.
Case 22-50073 Doc 1061-1 Filed 11/02/22 Entered 11/02/22 16:17:29 Page 9 of

BR_　3/17/22　Brown　Email　Melissa Francis,　Comments　Attorney-Client.　The withheld document

KWOK　Rudnick　Thread　Esq.,
Jennifer　from the　relates to advice from
00023528　Morrisey,　Debtor's　counsel representing the
Edward Argles,　UK Action　Debtor in UK Action
Bennett　counsel　regarding disclosures
to
Silverberg,　regarding　be made by the Debtor
Esq.,　the　in his Bankruptcy Court
description　filings related to the
UK
of the UK　Action. The
Privilege
Action to　Order
specifically
be utilized　recognizes that the
in the　Debtor may have
Debtor's　privileges under the
affidavit　laws of the United
and other　Kingdom that could be
Bankruptcy　asserted
by the Debtor
Court　in the UK Action. See
filings.　Privilege Order, at sec.
9. The Debtor has thus
withheld
this document
from
production for the
express purpose of
ensuring that he is
preserving, and not
waiving, any privilege
that he may have
to
assert against production
or disclosure of the
same document in the
UK Action.
BR_　3/17/22　Brown　Email　Melissa Francis,　Comments　Attorney-Client.　The withheld document
KWOK　Rudnick　Thread　Esq., Jennifer　from the　relates to advice from
00021709　Morrisey,　Debtor's　counsel representing the

Edward Argles,　UK Action

Bennett　counsel

Debtor in UK Action

regarding disclosures
to
be made by the Debtor
in his Bankruptcy Court
filings related to the
UK
Action. The
Privilege
Order
specifically
recognizes that the
Debtor may have
privileges under the
laws of the United
Kingdom that could be
asserted
by the Debtor
in the UK Action. See
Privilege Order, at sec.
9. The Debtor has thus
withheld
this document
from
production for the
express purpose of
ensuring that he is
preserving, and not
waiving, any privilege
that he may have
to

Silverberg,
Esq.,　regarding
the
description
of the UK
Action to
be utilized
in the
Debtor's
affidavit
and other
Bankruptcy
Court
filings.　be made by the Debtor
in his Bankruptcy Court
filings related to the
UK
Action. The
Privilege
Order
specifically
recognizes that the
Debtor may have
privileges under the
laws of the United
Kingdom that could be
asserted
by the Debtor
in the UK Action. See
Privilege Order, at sec.
9. The Debtor has thus
withheld
this document
from
production for the
express purpose of
ensuring that he is
preserving, and not
waiving, any privilege
that he may have
to
assert against production
or disclosure of the
same document in the
UK Action.

BR_
KWOK
00021713　3/17/22　Brown
Rudnick　Attachment
to email　Jennifer
Morrisey,
Edward Argles,　Comments
from the
Debtor's
UK Action
counsel
regarding　Attorney-Client　The withheld document
relates to advice from
counsel representing the
Debtor in UK Action
regarding disclosures
to
be made by the Debtor

the
description
of the UK
Action to
be utilized
in the
Debtor's
affidavit
and other
Bankruptcy
Court
filings.　in his Bankruptcy Court
filings related to the
UK
Action. The
Privilege
Order
specifically
recognizes that the
Debtor may have
privileges under the
laws of the United
Kingdom that could be
asserted
by the Debtor
in the UK Action. See
Privilege Order, at sec.
9. The Debtor has thus
withheld
this document
from
production for the
express purpose of
ensuring that he is
preserving, and not
waiving, any privilege
that he may have
to
assert against production
or disclosure of the
same document in the
UK Action.

BR_
KWOK
00011133　5/10/22　Brown
Rudnick　Email　William R.
Baldaga, Esq.,
Melissa Francis,
Esq., Bennett
Silverberg,
Esq.,
Jeffrey
Jonas, Esq.,
taxelrod@
brownrudnick.c　Advice
concerning
effect
of
dismissal
of
bankruptcy
case on
future
bankruptcy　Attorney-Client　The privileged advice in
the redacted portion
of
the email does not relate
to Investigation
Topics
as that term is defined in
the Privilege Order and
no showing of personal
harm is required to
withhold the document
Case 22-50073 Doc 1061-1 Filed 11/02/22 Entered 11/02/22 16:17:29 Page 12 of 12

om (BCC),　filings.　on the basis of attorney

kaulet@brownr　(requires　client privilege.
udnick.com　redaction).
(BCC)