Guo Wengui / Miles Guo — bankruptcy case · SUBPOENA · ECF #1465-1

| Case 22-50073 Doc 1465-1 Filed 02/20/23 Entered 02/20/23 19:04:59 Page 1 of<br>1 /<br>B2540 (Form 2540 - Subpoena for Rule 2004 Examination) (12/15) | | | | | |----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|---------------------------------------------------------|--|--|--| | UNITED STATES BANKRUPTCY COURT<br>District of Connecticut | | | | | | HO WAN KWOK, et al., 1<br>In re<br>Debtor<br>Chapter | Case No. 22-50073 (JAM)<br>11<br>(Jointly Administered) | | | | | SUBPOENA FOR RULE 2004 EXAMINATION<br>Jiaming Liu<br>10:1 | | | | | | | (Name of person to whom the subpoena is directed) | | | | | Testimony: YOU ARE COMMANDED to appear at the time, date, and place set forth below to testify at an examination under Rule 2004,<br>Federal Rules of Bankruptcy Procedure. A copy of the court order authorizing the examination is attached.<br>PLACE | | | | | | Paul Hastings LLP | DATE AND TIME | | | | | 200 Park Avenue | February 27, 2023 at | | | | | New York, New York 10166 | 10:00a.m. | | | | | | | | | | | The examination will be recorded by this method: Court reporter/stenographer | | | | | | Production: You, or your representatives, must also bring with you to the examination the following documents, electronically stored<br>information, or objects, and must permit inspection, copying, testing, or sampling of the material: | | | | | | See Requests for Production of Documents, attached hereto. | | | | | | The following provisions of Fed. R. Civ. P. 45, made applicable in bankruptcy cases by Fed. R. Bankr. P. 9016, are attached – Rule<br>45(c), relating to the place of compliance; Rule 45(d), relating to your protection as a person subject to a subpoena; and Rule 45(e),<br>elating to your duty to respond to this subpoena and the potential consequences of not doing so. | | | | | | Date: January 24, 2023 | | | | | | CLERK OF COURT<br>OR | | | | | | Signature of Clerk or Deputy Clerk | A ++ - - - - - - - - - - - - - - - | | | |

The name, address, email address, and telephone number of the attorney representing Luc A. Despins, Chapter 11 Trustee, who issues or requests this subpoena, are: requests this subpoena, are:

Patrick R. Linsey, Esq.; Neubert, Pepe & Monteith, P.C.; 195 Church Street, 13th Floor, New Haven, CT 06510; plinsey@npmlaw.com:; (203) 781-2847

Attorney's signature

# Notice to the person who issues or requests this subpoena

If this subpoena commands the productions will sistem wio issues or requests this subpoena before trial, a noice and a copy of this subpoens must be served on each be hings, before trial, a notice and a copy of this subpents, sicclinically stored integrity of the insection of premiss Civ. P. 45(a)(4).

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# Requests for Production of Documents

## INSTRUCTIONS I.

- T. Unless otherwise indicated, the requests for documents set forth below, (the "Requests," and each, a "Request"), must be responded to separately and specifically. Each Request shall be answered fully unless it is in good faith objected to, in which event the reason for Your objection shall be stated in detail, as set forth below. If an objection pertains only to a portion of a Request, or a word, phrase or clause contained within it, You are required to state Your objection to that portion only and to respond to the remainder of the Requests. - 2. Electronically stored information must be produced in accordance with the following instructions: - · a. Images. Black and white images must be 300 DPI Group IV single-page TIFF files. Color images must be produced in JPEG format. File names cannot contain embedded spaces or special characters (including the comma). Folder names cannot contain embedded spaces or special characters (including the comma). All TIFF image files must have a unique file name, i.e. Bates number. Images must be endorsed with sequential Bates numbers in the lower right corner of each image. The number of TIFF files per folder should not exceed 1000 files. Excel spreadsheets should have a placeholder image named by the Bates number of the file. - b. Image Load File - a. Concordance® Data File. The data file (.DAT) contains all of the fielded information that will be loaded into the Concordance® database. The first line of the .DAT file must be a header row identifying the field names. The .DAT file must use the following Concordance® default delimiters: Comma ASCII character (020) Quote b ASCII character (254). Date fields should be provided in the format: mm/dd/yyyy. Date and time fields must be two separate fields. If documents includes imaged emails and attachments, the attachment fields must be included to preserve the parent/child relationship between an email and its attachments. An OCRPATH field must be included to provide the file path and name of the extracted text file on the produced storage media. The text file must be named after the FIRSTBATES. Do not include the text in the .DAT file. For Documents with native files, a LINK field must be included to provide the file path and

name of the native file. The native file must be named after the FIRSTBATES.

b. Concordance Image® OR Opticon Cross-Reference File. The image crossreference file (.LOG;or .OPT) links the images to the database records. It should be a comma-delimited file consisting of seven fields per line with a line in the cross-reference file for every image in the database with the format: following ImageID, VolumeLabel,ImageFilePath,DocumentBreak,FolderBreak,Box Break,PageCoun.

- c. Document Text. Text must be produced as separate text files, not as fields within the .DAT file. The full path to the text file (OCRPATH) should be included in the .DAT file. It is recommended document level ANSI text files, named per the FIRSTBATES/Image Key. Extracted text files must be in a separate folder, and the number of text files per folder should not exceed 1,000 files. There should be no special characters (including commas in the folder names). Text files must be provided on a document level. - d. Native Production for Certain File Types. File types that reasonably require viewing in their native format for a full understanding of their content and meaning must be produced in native format. These include, but are not limited to, spreadsheets, spreadsheet-like files (Microsoft Excel, comma separated values, tab separated values, etc.), Microsoft PowerPoint or other special presentation files, database files, and audio/visual files. Provide an image of a Bates numbered slip sheet indicating the presence of a native file, and include the path to the native as a field in the .dat file. Name the produced native file with the Bates number corresponding to the slip sheet for the file. Group native files within incrementally named "NATIVE" directories, separate from images directories. - e. De-duplication. Produce a single copy of each electronic document for which exact duplicates exist. For email messages, consolidate duplicates based on MD5 hash generated from the BCC, Body, CC, From, IntMsgID, To, and Attach properties. For email attachments and standalone electronic files, consolidate duplicates based on MD5 hash of the entire file. - f. Metadata. Produce extracted metadata for each document in the form of a Concordance compliant load file (.dat). The first line of the .DAT file must be a header row identifying the field names. The .DAT file must use the following Concordance default delimiters: Comma , ASCII character (020) Quote p ASCII character (254)

Date fields should be provided in the format: mm/dd/yyyy. Date and time fields must be two separate fields. Required metadata listed below:

| | for single page | |-----------------------|-----------------------------------------| | DC0000001 | Bates number of the first page of the p | | DC0000015 | document to the Bates number of the | | | the last attachment "child" document | | DC0000001 | First Bates number of attachment rang | | DC0000015 | Last Bates number of attachment rang | | mith, John | Email: Mailbox where the email resid | | | Native: Name of the individual or dep | | | from whose files the document origin | | ohn Smith | Email: Sender | | | Native: Author(s) of document | | | ** semi-colon should be used to separ | | | multiple entries | | offman, Janice; Lee W | Recipient(s) | | nailto:LeeW(@MSN.com] | ** semi-colon should be used to separ | | | entries | | rank Thompson mailto: | Carbon copy recipient(s) | | ank Thompson@cdt.com] | ** semi-colon should be used to separ | | | multiple entries | | ohn Cain | Blind carbon copy recipient(s) | | | ** semi-colon should be used to separ | | | multiple entries | | oard Meeting Minutes | Email: Subject line of the email Nativ |

| 10 | Coffman, Janice; Lee W | Recipient(s) | |--------------|--------------------------|-------------------------------------------------| | | [mailto:LeeW@MSN.com] | ** semi-colon should be used to separate multip | | | | entries | | ·CC | Frank Thompson mailto: | Carbon copy recipient(s) | | | frank Thompson@cdt.com] | ** semi-colon should be used to separate | | | | multiple entries | | BCC | John Cain | Blind carbon copy recipient(s) | | | | ** semi-colon should be used to separate | | | | multiple entries | | SUBJECT | Board Meeting Minutes | Email: Subject line of the email Native: Title | | | | of document (if available) | | FILE NAME | BoardMeetingMinutes.docx | Native: Name of the original native file, | | | | including extension | | DATE SENT | 10/12/2010 | Email: Date the email was sent | | | | Native: (empty) | | TIME SENT/ | 07-05 PM GMT | Email: Time the email was sent/ Time zone in | | TIME ZONE | | which the emails were standardized | | TIME ZONE | GMT | The time zone in which the emails we | | | | standardized during conversion. | | I INK | EDC000001.msg | Hyperlink to the email or native file document | | | | ** The linked file must be named per the | | | | FIRSTBATES number | | FILE EXTEN | MSG | The file type extension | | | | representing | | | | the Email or | | AUTHOR | John Smith | Email: (empty) | | | | Native: Author of the document | | DATE CREATED | 10/10/2010 | Email · (emntv) |

| TIME CREATED | 10:25 AM | Email: (empty) | |--------------|---------------------------|--------------------------------------------------| | | | Native: Time the document was created | | | | ** This data must be a separate field and cannot | | | | be combined with the DATE CREATED field | | DATE MOD | 10/12/2010<br> | Email: (empty) | | | | Native: Date the document was last modified | | TIME MOD | 07:00 PM | Email: (empty) | | | | Native: Time the document was last modified | | | | ** This data must be a separate field and cannot | | | | be combined with the DATE MOD field | | DATE ACCESSD | 10/12/2010 | Email: (empty) | | | | Native: Date the document was last accessed | | TIME ACCESSD | 07:00 PM | Email: (empty) | | | | Native: Time the document was last accessed | | | | ** This data must be a separate field and cannot | | | | be combined with the DATE ACCESSD field | | FILE SIZE | 5.952 | Size of native file document/email in KB | | PGCOUNT | | Number of pages in native file document/email | | PATH | | Email: (empty) | | | Agenda.doc | Native: Path where native file document was | | | | stored including original file name. | | INTFILEPATH | Personal Folders Deleted | Email: original location of email including | | | Items Board Meeting | original file name. | | | Minutes.msg | Native: (empty) | | INTMSGID | <000805c2c71b\$75977050\$ | Email: Unique Message ID Native: (empty) | | | cb8306d1@MSN> | | | MDSHASH | d131dd02c5e6eec4693d9a0 | MD5 Hash value of the document. | | | 698aff95c | | | | 2fcab58712467eab4004583e | | | | b8fb7f89 | | | OCRPATH | TEXT/001/EDC000001.txt | Path to extracted text of the native file |

including Your counsel or other representatives and advisors. Each Document shall be produced in its entirety.

6 .- If You are requested to produce a Document that is no longer in Your possession, custody, or control, then Your response must (a) describe in detail the nature of the document and its contents; (b) identify the person(s) who prepared or authored the Document (and, if applicable, the Person(s) to whom the Document was sent); (c) identify the date on which the document was prepared or created; (d) state whether such Document (i) is missing or lost, (ii) has been destroyed, (iii) has been transferred, voluntarily or involuntarily, to others, or (iv) was otherwise disposed of; (e) state the reason for, and the facts and circumstances surrounding, such disposition; (f) identify the Persons who authorized such disposition; (g) identify the date or approximate date of such . disposition; (h) state when the Document was most recently in Your possession, custody or control; and (i) identify the Person, if any, presently in possession, custody, or control of such Document.

7. If You are requested to produce a Document that has been destroyed, then Your response must state, in addition to the information required by the preceding Instruction: (a) the reason for the Document's destruction; (b) the identity of the Person who destroyed the Document; and (c) the identity of the Person who directed that the Document be destroyed.

8. If You claim that a requested Document is privileged or attorney work-product, then Your response must: (a) state (i) a description of the Document adequate to support Your contention that the Document is privileged, (ii) the title of the Document, (iii) the date of the Document, (iv) the author of the Document, (v) the addressee of the Document, (vi) the identity of each Person who received or saw the original or any draft, copy, or reproduction of the Document, (vii) whether the Document itself, or any information contained or referred to in the Document is in the possession, custody, or control of any other Persons, and if so, the identity of such Persons, as well as a statement addressing how the information came into their possession, (viii) the claim of privilege under which the Document is withheld, and (ix) all of the circumstances upon whieh You will rely to support such claim of privilege; and (b) produce a privilege log containing all of the information requested in Part (a) of this Instruction for each Document withheld on the basis of a claim of privilege in accordance with D. Conn. L. Civ. R. 26(e).

9. If a portion of an otherwise responsive Document contains information subject to a claim of privilege, only that portion of the Document subject to the claim of privilege shall be deléted or redacted from the Document following the instructions above, and the rest shall be produced.

10. The Requests are continuing in nature. You are hereby instructed to (a) supplement · or correct any responses later learned to be incomplete or incorrect immediately upon learning that a prior response was incomplete or incorrect; and (b) produce any additional Documents that are called for under the

11. If a Document is in a language other than English, You should provide that Document. If a Document is in a language other than English, and an English translation exists, You should provide both Documents.

12. All references to Entities includes all affiliates thereof.

13. All references to individual names include all alternative names, aliased, or nicknames.

14. Unless otherwise expressly indicated, the period of time covered by the Document Requests is the period from February 5, 2012 to the date responses to the Document Requests are due.

#### II. RULES OF CONSTRUCTION

15. The use of (a) any singular noun shall be construed to include the plural, and vice versa, and (b) a verb in any tense shall be construed as the use of the verb in all other tenses.

16. The terms (a) "and" and "or" shall be construed either conjunctively or disjunctively as necessary to bring within the scope of any request all responses that might otherwise be construed to be outside of its scope, and (b) "each" and "any" shall be deemed to include and encompass the words "every" and "all."

### DEFINITIONS III.

The definitions supplied by D. Conn. L. Civ. R. 26(c) and the rules of construction

supplied by D. Conn. L. Civ. R. 26(d), as incorporated by D. Conn. Bankr. L.R. 2004-1(a), shall apply to the Document Requests. In addition, the following terms used in these Document Requests shall have the following meanings:

1. "You" or "Your" or "Yourself" means and refers to Jiaming Liu, together with all of their agents, attorneys, representatives, employees, and/or anyone acting on their behalf.

2. "Debtor" means Ho Wan Kwok (a/k/a Miles Kwok, Miles Guo, Guo Wengui, Guo Haoyun, 郭文贵, or any other alias), together with his employees, agents, counsel, advisors, or anyone acting on his behalf.

3. " "Debtor's Son" means Qiang Guo (a/k/a Mileson Kwok, 郭强, or any other alias), together with his employees, agents, counsel, advisors, or anyone acting on his behalf.

4. " "Debtor's Daughter" means Mei Guo (a/k/a Mei Gui, 郭美, or any other alias), together with her employees, agents, counsel, advisors, or anyone acting on her behalf.

5. " "Debtor's Purported Wife" means Hing Chi Ngok (a/k/a Hing Chi Ng, Yue Qingzhi, 岳庆芝, or any other alias), together with her employees, agents, counsel, advisors, or anyone acting on her behalf.

6. "Debtor's Family" means, collectively, the Debtor, the Debtor's Son, the Debtor's Daughter, and the Debtor's Purported Wife, and any other familial relation to the Debtor.

"Associated Individuals" means, individually and collectively, all individuals that 7. (1) hold, control, have custody over, or discretion over assets owned, controlled, or enjoyed by the Debtor or the Debtor's Family; or (2) have been employees, directors, or otherwise are affiliated with one or more Associated Entities, together with the respective employees, agents, counsel, · advisors, or anyone acting on behalf of any of the foregoing. Such Associated Individuals shall include, but are not limited to: Daniel Podhaskie, Jason Miller, Steve Bannon, Karin Maistrello, Melissa Francis, William Gertz, Arethusa Forsyth, Glenn Mellor, Jennifer Mercurio, Eduardo Eurnekian, Han Chunguang (a/k/a 韩春光), Qu Guojiao (a/k/a Qu Guo Jiao, 屈国姣), Guo Lijie (a/k/a 郭丽杰), Zhang Wei (a/k/a 张伟\*), Lihong Wei Lafrenz (a/k/a Sara Wei, 魏刚红), Hao Haidong (a/k/a 郝海东), Ross Heinemeyer, Max Krasner, Kyle Bass, Melissa Mendez, Ya Li (a/k/a 李娅), Dinggang Wang (a/k/a 王定刚), An Hong (a/k/a 安红), Yvette Wang (a/k/a Yanping Wang, Yan Ping Wang, 王雁平), Fiona Yu, Je Kin Ming (a/k/a William Je, Yu Jianming, 余建明 ), Yaz Qingua, and Lao Jiang (a/k/a Jiang Yunfu, Jiang Yunfu Be, 美云浮).

8. "Associated Entities" means, individually and collectively, all organizations or Entities of any type that (1) have been owned, controlled, or invested in by the Debtor or the Debtor's Family; or (2) have an interest, whether directly or indirectly, in any assets owned,

# Case 22-50073 Doc 1465-1 Filed 02/20/23 Entered 02/20/23 19:04:59 Page 12 of 17

Shiny Ace Ltd., Shiny Times Holdings Ltd., Spirit Charter Investment Limited, Stevenson, Wong & Co., Voice of Guo Media, Inc., Well Origin Ltd., World Century Limited, Worldwide Opportunity Holdings Limited, Whitecroft Shore Limited, and ZIBA Limited.

9. "Including" or any variant thereof means "including without limitation."

10. "And" and "or" mean "and/or," and shall be construed both conjunctively as well as disjunctively in order to maximize their scope.

"Any" and "all" and "each" mean "each and every." 11.

"Each" and "every" mean "each and every." 12.

13. "Third Party" means a Person or Entity other than Yourself.

14. "Transfer" shall have the meaning given to it by section 101(54) of the Bankruptcy Code.

15. "Document" means any information or thing within the scope of Fed. R. Civ. P. 34, and includes, without limitation, each and every written, recorded, or graphic matter of any kind, type, nature, or description that is or has been in Your Possession, Custody or Control, including all printed and electronic copies of electronic mail, computer files maintained in electronic form, electronic communication, text message, social media post, tweet, meta-data, correspondence, memoranda, tapes, stenographic or handwritten notes, written forms of any kind, charts, blueprints, drawings, sketches, graphs, plans, articles, specifications, diaries, letters, telegrams, photographs, minutes, contracts, agreements, surveys, computer printouts, data compilations of any kind, telexes, facsimiles, voice messages, invoices, order forms, checks, drafts, statements, credit memos, reports, position reports, summaries, indices, books, ledgers, notebooks, schedules, transparencies, recordings, catalogs, advertisements, promotional

materials, films, video tapes, audio tapes, CDs, computer disks, brochures, pamphlets, punchcards, time-slips, Tweets, social media posts, or any written or recorded materials of any other kind, and all meta-data thereof, however stored (whether in tangible or electronic form), recorded, produced, or reproduced, and also including but not limited to, drafts or copies of any of the foregoing that contain any notes, comments, or markings of any kind not found on the original documents or that are otherwise not identical to the original documents.

16. "Person(s)" means an individual, corporation, proprietorship, partnership, association, or any other Entity. "Person" also includes any agent, representatives, or expert, including but not limiting to, attorneys or financial advisors.

17. "Entity" means any natural Person, corporation, partnership, subsidiary, sole proprietorship, firm, board, joint venture, association, agency, authority, commission or other business entity or juristic Person, as well as any affiliate, agent, parent including but not limited to legal counsel, financial advisors, or any other representative.

18. "Regarding" means concerning, describing, comprising, referring to, related to, supporting, favoring, opposing, bolstering, detracting from, located in, considered in connection with, bearing on, evidencing, indicating, reporting on, recording, alluding to, responding to, connected with, commenting on, in respect of, about, in relation to, discussing, showing, describing, reflecting, analyzing constituting, and being.

19. "Relating to," "relate(s) to" or "related to," when referring to any given subject matter, means, without limitation, any document that constitutes, comprises, involves, contains, embodies, reflects, identifies, states, refers directly to, or is in any way relevant to the particular subject matter identified.

20. "Communication(s)" means, in the broadest possible sense, and without limitation, any transmittal of information or knowledge (in the form of facts, ideas, inquiries, or otherwise). Communication(s) further refers to all conversations, agreements, inquiries, or replies, whether in person, by telephone, in writing, or by means of electronic transmittal devices, and includes, but is not limited to, all correspondence, emails, recordings, transmittal slips, memoranda, telephone communications, voice messages, telegrams, telefaxes, telecopies, telexes, instant messages, chats, text messages, telephonic notes, or notes transmitted internally or with third parties.

21. "Asset(s)" means any item that can be used to produce positive economic value, including but not limited to any resource with economic value that is owned, controlled or is for · the benefit of an entity, that is expected to provide a future benefit, including but not limited to, all real and personal property, intangible property, investments, rights to invest or to future revenue, cash, bank accounts, commodities, securities, claims, total or partial control of an entity, and prospective economic opportunities

"Transfer" shall have the meaning given to it by section 101(54) of the 22. Bankruptcy Code.

### DOCUMENTS TO BE PRODUCED IV.

1. All Documents regarding any income or Asset of the Debtor's estate, or an Associated Entity.

2. All Documents related to the Debtor's financial condition and obligations to his creditors, including without limitation all Documents related to any effort to avoid paying such obligations and All Documents related to this or any other actual or potential bankruptcy or similar insolvency proceeding.

3. All Documents regarding any balance sheet, bank statement, account statement, financial statement, statement of account, wire transfer instructions and/or confirmation, proof of funds, certificate of deposit, certificate of holdings, investment portfolio summary, or similar document relating to the Debtor's Estate, the Debtor's Family, an Associated Entity, or an Associated Individual, including without limitation all Documents sufficient to show all Transfers to any of the foregoing.

4. 9 All Documents regarding any investment, business dealing or transactions made by, with, or on behalf of the Debtor.

5. All Communications with the Debtor, and Documents related to Communications with the Debtor, related to the operation, management, or decision-making of any Entity, including without limitation the Associated Entities.

All Documents regarding any Transfer, investment, or other transaction or 6. business dealing made to, by, or with the Debtor's Family, or an Associated Entity.

7. All Documents regarding any property ever occupied or used by the Debtor, including without limitation the Lady May; the Sherry Netherland Hotel / Condominium; the residential property located in Greenwich, Connecticut at 373 Taconic Rd.; the residential property located in Greenwich, Connecticut at 33 Ferncliff Rd.; and the residential property located in Wilton, Connecticut at 354 Nod Hill Rd.

All Documents related to any investments or trading by the Debtor, the Debtor's 8. Family, or an Associated Entity, in or around July 2020, or at any other time, in crude oil futures or any similar commodity, including without limitation Communications with Jiang Yunfu Be regarding any such investments or trading.

9. All Documents related to any aircraft owned, controlled, or used by the Debtor, including without limitation the aircraft bearing tail number T7-GQM and any other aircraft registered in San Marino, including without limitation copies of all registration documents and flight manifests showing flights taken by such aircraft and the individuals onboard such flights.

10. All Documents regarding any gifts, benefits or loans, to, from or on behalf of the Debtor, the Debtor's Estate, the Debtor's Family, or the Associated Entities, including without limitation Documents sufficient to show the amounts of such gifts, benefits, or loans; the purposes for which such gifts, benefits, or loans were used; when the gifts, benefits, or loans were provided; and the terms of any loans, all representations and warranties made in connection with any loans, the interest rate on any loans, and all evidence of payments of any loans.

11. All Documents concerning any trust or similar instrument set up by, on behalf of, or for the benefit of the Debtor's Estate, the Debtor's Family, or an Associated Entity, including without limitation Documents sufficient to show when the trust(s) was created, by whom it was created, for whose benefit it was created, and the corpus of the trust.

12. All Documents related to any obligation, claim, liability, or debt associated with any legal dispute involving the Debtor, including but not limited to those relating to any litigation before any local, state, federal, or international body, whether an administrative body, court, panel, or alternative dispute resolution entity.

13. All Documents and communications between any of your outside counsel or other advisors and the Debtor.

14. All Documents related to any Associated Entity that You hold or have held an interest in.