---
type: court_doc
id: "court_ctb_1083_0"
court: "CTB"
case_no: "22-50073"
doc_number: 1083
doc_type: "ORDER"
filed_date: "2022-11-11"
lang: "en"
machine_translated: false
url: "https://mubeitech.com/en/court/court_ctb_1083_0"
json_url: "https://mubeitech.com/api/court/court_ctb_1083_0"
---
# Guo Wengui / Miles Guo — bankruptcy case · ORDER · ECF #1083

**Trustee's Witness and Exhibit List for Contempt Hearing —— In re Ho Wan Kwok (Miles Guo / Guo Wengui), CTB 22-50073 ECF #1083 (filed 2022-11-11). Chapter 11 Trustee Luc Despins submitted a witness list (including Ho Wan Kwok and Una Wilkinson) and a 28-item exhibit list in connection with the November 15, 2022 hearing on the motion to hold the individual debtor in civil contempt for failure to comply with the corporate governance rights order.**


UNITED STATES BANKRUPTCY COURT DISTRICT OF CONNECTICUT BRIDGEPORT DIVISION

x

In re:　:
:　Chapter 11
HO WAN KWOK, et al.,　:
:
:　Case No. 22-50073 (JAM)
Debtors.1　:
:　Jointly Administered
-----------------------------------------------------------　x
**WITNESS LIST AND EXHIBITS LIST OF CHAPTER 11 TRUSTEE IN CONNECTION WITH HEARING ON NOVEMBER 15, 2022 RELATED TO CHAPTER 11 TRUSTEE'S MOTION TO HOLD INDIVIDUAL DEBTOR IN CIVIL CONTEMPT FOR FAILURE TO COMPLY WITH CORPORATE GOVERNANCE RIGHTS ORDER**

Luc Despins, as the appointed Chapter 11 Trustee to the Individual Debtor's estate (the "Trustee"), by and through his undersigned counsel, and pursuant to the Court's Order Granting Motion To Expedite Hearing on Motion for Contempt [ECF No. 1044], submits this witness list and exhibits list for the November 15, 2022 hearing (the "Hearing") on the *Motion of Chapter 11 Trustee for Entry of Order Holding Debtor in Civil Contempt for Failure to Comply with Corporate Governance Rights Order* [ECF No. 913] (the "Motion") before the Hon. Julia A. Manning, United States Bankruptcy Court for the District of Connecticut (Bridgeport), Courtroom 123, 915 Lafayette Blvd., Bridgeport, CT.

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) (the "Individual Debtor") and Genever Holdings Corporation (the "Genever BVI Debtor"). The mailing address for the Trustee and the Genever BVI Debtor 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).

Case 22-50073 Doc 1083 Filed 11/11/22 Entered 11/11/22 14:29:50 Page 2 of 5
WITNESS LIST

The Trustee designates the following individuals whom he presently anticipates may be called as witnesses at the Hearing:

- 1. Ho Wan Kwok;
- 2. Una Wilkinson;
- 3. Any and all witnesses called by an adverse party;
- 4. Other witnesses to the extent necessary for the authentication of documents;
- 5. Other witnesses for rebuttal purposes.

The Trustee reserves the right to supplement or amend this list, including based on the results of ongoing discovery.

[Remainder of Page Intentionally Left Blank
EXHIBITS LIST

Exhibit　Description of Exhibit　Docket No(s).2 or
Bates Numbers3

1.　Vice News, Exiled Chinese Billionaire Uses YouTube to Wage A War On
Corruption, YOUTUBE, (Nov. 15, 2017) (available at
http)
2.　Vice News, Take Down the CCP & World's Coolest Dictator, SHOWTIME,
(original air date: Dec. 19, 2021) (available at
http>worlds-coolest-dictator)
3.　Steve Bannon's War Room: Pandemic, Ep 241 –
Pandemic: The CCP's
Information War Against America (w/ Miles Guo and Jack Posobiec),
(June 18, 2020)
http>QW2Nzr8/view?usp=sharing
4.　Decision and Order on Motion, dated February 9, 2022, PAX v. Kwok,
Index No. 652077/2017 (N.Y. Sup. Ct.)　ECF No. 913, Exhibit
B
5.　Decision and Order on Motion, dated July 7, 2020, PAX v. Kwok, Index
No. 652077/2017 (N.Y. Sup. Ct.)　ECF No. 913, Exhibit
C
6.　Particular of Claims, Kwok Ho Wan & Ors. v. UBS, Cl-2020-000345,
High Court of Justice of England and Wales Queen's Bench Division
Commercial Court, dated September 23, 2020　ECF No. 913, Exhibit
D
7.　Transcript of Section 341 Meeting, dated April 6, 2022　ECF No. 913, Exhibit
E
8.　August 31, 2022 letter from Trustee to Debtor's counsel requesting that
the Debtor cause his shares on Ace Decade to be transferred to the Trustee
no later than September
6, 2022　ECF No. 913, Exhibit
F
9.　The transcript of the September 6, 2022 status conference　ECF No. 913, Exhibit
G
10.　Transcript of Section 341 Meeting, dated March 21, 2022
11.　Complaint, Guo Wengui v. Joshua Schiller, et al., Supreme Court of the
State of New York, County of New York, Index No. 150001/2019 (Dec.
31, 2018)　NYSCEF Doc. No. 1
12.　Memorandum of Law in Support of Defendants' Motion to Compel
Arbitration, Guo Wengui v. Joshua Schiller, et al., Supreme Court of the
State of New York, County of New York, Index No. 150001/2019　NYSCEF Doc. No. 3
13.　Final Arbitration Award in Boies Schiller Flexner, LLP v. Miles Kwok　NYSCEF Doc. No. 3,
Exhibit B

2 All docket entries referenced herein include all exhibits and declarations attached thereto. References to ECF No.'s are to documents filed on the docket of the above caption case. All other references to docket numbers refer to cases described for each exhibit number.

3 All bates numbers were provided by the producing party.

14.　Complaint in Ace Decade Holdings Limited v. UBS AG　NYSCEF Doc. No. 1

15.　Kwok Affidavit in Ace Decade Holdings Limited v. UBS AG　NYSCEF Doc. No. 27
16.　Kwok's Chinese Translation of Kwok Affidavit in Ace Decade Holdings
Limited v. UBS AG　NYSCEF Doc. No. 28
17.　Paul Hasting's Chinese Translation of Kwok Affidavit in Ace Decade
Holdings Limited v. UBS AG
18.　Certificate of Translation for Kwok Affidavit Ace Decade Holdings
Limited v. UBS AG
19.　Affidavit of
Yu Yong in Ace Decade Holdings Limited v. UBS AG　NYSCEF Doc. No. 29
20.　Email chain beginning on January 30, 2015 at 6:36 PM, in which R.
Barnett of Williams & Connolly emailed multiple individuals concerning　PWRWG00002204—
Mr. Kwok's desire to retain real estate counsel　PWRWG00002205
21.　Engagement letter between Boies Schiller and Miles Kwok　KWOK_M_00000008
22.　Email chain beginning on May 18, 2015 in which Kristin Beirne emailed
a Kwok Office email address concerning 2015 annual shareholder　PWRWG00002433—
meeting proxy information for the Sherry Netherland　PWRWG00002434
23.　Email chain beginning on Feb. 27, 2015 in which Kathy Sloane emailed a　PWRWG00002413—
Kwok Office email address concerning the Carlyle apartment　PWRWG00002416
24.　Email chain beginning on Feb. 24, 2015 in which a Kwok Office email
address emailed Adam Wolfson of Wolfsom Insurance Brokerage, Inc.　PWRWG00002298—
concerning insurance coverage for the Sherry Netherland　PWRWG00002299
25.　Audio File, Section 341 Meeting, dated March 21, 2022
26.　Audio File, Section 341 Meeting, dated April 6, 2022
27.　Deposition Transcript of Ho Wan Kwok, dated November 11, 2021
28.　Deposition Transcript of Una Wilkinson, dated November 11, 2021

The Trustee reserves the right to supplement or amend this list, including based on the

results of ongoing discovery. The Trustee further reserves the right to introduce or otherwise

rely upon any exhibit offered by any other party. The Trustee further reserves the right to

introduce additional exhibits for rebuttal or impeachment purposes.

[Remainder of Page Intentionally Left Blank]

Dated: November 11, 2022 LUC A. DESPINS, New Haven, Connecticut CHAPTER 11 TRUSTEE

By: /s/ Patrick R. Linsey

Patrick R. Linsey (ct29437) NEUBERT, PEPE & MONTEITH, P.C. 195 Church Street, 13th Floor New Haven, Connecticut 06510 (203) 781-2847 plinsey@npmlaw.com

and

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

and

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

Counsel for the Chapter 11 Trustee