Guo Wengui / Miles Guo — bankruptcy case · MOTION · ECF #1385-1

## **EXHIBIT A**

## **LAWALL DECLARATION**

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

In re:

Chapter 11

HO WAN KWOK *et al.*,

Case No. 22-50073 (JAM)

<span id="page-1-1"></span>Debtors. [1](#page-1-0) Jointly Administered

## **DECLARATION OF FRANCIS J. LAWALL**

I, Francis J. Lawall, make this declaration pursuant to 28 U.S.C. § 1746.

1. My name is Francis J. Lawall.

2. I am over the age of eighteen years and am competent to testify as a witness.

3. The facts stated in tis declaration are based on matters of which I have personal knowledge

4. I am a partner of Troutman Pepper Hamilton Sanders. LLP, counsel to Bravo Luck Limited in the chapter 11 case *In re: Ho Wan Kwok*, Case No. 22-50073 (JAM).

<span id="page-1-3"></span>5. I offer this declaration in support of the *Bravo Luck Limited's Motion to Quash Subpoena* (the "Motion").[2](#page-1-2)

6. On January 23, 2023, I had a meet and confer with Patrick Linsey of Neubert, Pepe & Monteithm P.C., counsel to the Trustee, via the telephone, in an effort in good faith to resolve by agreement the issues raised by the Motion. During the meet and confer, Mr. Linsey and I

<span id="page-1-0"></span>¹ The Debtors in these chapter 11 cases are Ho Wan Kwok (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).

<span id="page-1-2"></span>² Capitalized terms used but not defined herein shall have the meaning ascribed to them in the Motion.

discussed the discovery issues between the parties regarding the Rule 2004 Subpoena and requested that the Rule 2004 Subpoena be withdrawn in light of the three pending adversary proceedings filed by the Trustee and Debtors against Bravo. On January 25, 2023, Mr. Linsey notified me via email that the Trustee will not withdraw the Rule 2004 Subpoena and thus the issues raised during the meet and confer remain unresolved.

Pursuant to 28 U.S.C. § 1746, I declare under penalty of perjury under the laws of the United States that the foregoing is true and correct.

Executed within the United States on January 25, 2023.

*/s/ Francis J. Lawall* Francis J. Lawall, Esq. TROUTMAN PEPPER HAMILTON SANDERS LLP 3000 Two Logan Square Eighteenth and Arch Streets Philadelphia, PA 19103 Telephone: (215) 981-4481 francis.lawall@troutman.com