Guo Wengui / Miles Guo — bankruptcy case · SUBPOENA · ECF #1604-47
METADATA
- Defendant
- Guo Wengui / Miles Guo / Ho Wan Kwok
- Court
- CTB
- Case No.
- 22-50073
- ECF #
- 1604
- Type
- SUBPOENA
- Filed
- 2023-03-27
FULL TEXT
EXHIBIT A Case 22-50073 Doc 1604-47 Filed 03/27/23 Entered 03/27/23 14:12:10 Page 2 of 65
Appearance via videoconference (link to follow) DATE AND TIME
Any organization not a party to this suit that is subpoenaed for the taking of a deposition shall designate one or more officers, directors, or managing agents, or other persons who consent to testify on its behalf, and may set forth, for each person designated, the matters on which the person will testify. Delaware Superior Court Civil Rule 30 (b) (6).
REQUESTING PARTYS NAME, ADDRESS AND PHONE NUMBER Pacific Alliance Asia Opportunity Fund L.P. c/o O'Melvery & Joyers 7 Times Square, New York, NY 10036 - (212) 326-2000
Allerian DATE ﻟﻠﻤﻠﺔ ﺍﻟﻤﺴﺎﺣﺔ ﺍﻟﻤﺴﺘﻮﻯ ﺍﻟﻤﺴﺘﻮﻯ ﺍﻟﻤﺴﺘﻮﻯ ﺍﻟﻤﺴﺘﻮﻯ ﺍﻟﻤﺴﺘﻮﻯ ﺍﻟﻤﺴﺘﻮﻯ ﺍﻟﻤﺴﺘﻮﻯ ﺍﻟﻤﺴﺘﻮﻯ ﺍﻟﻤﺴﺘﻮﻯ ﺍﻟﻤﺴﺘﻮﻯ ﺍﻟﻤﺴﺘﻮﻯ ﺍﻟﻤﺴﺘﻮﻯ ﺍﻟﻤﺴﺘﻮﻯ ﺍﻟﻤﺴﺘﻮﻯ ﺍﻟﻤﺴﺘﻮﻯ ﺍﻟﻤﺴﺘﻮﻯ ﺍﻟﻤﺴﺘﻮﻯ ﺍﻟﻤﺴﺘﻮﻯ ﺍﻟﻤﺴﺘﻮﻯ ﺍﻟﻤﺴﺘﻮﻯ
O'Melveny & Myers LLP Times Square Tower 7 Times Square New York, NY 10036-6537 T: +1 212 326 2000 File Number: F: +1 212 326 2061 omm.com
Lisa Fontello, Prothonotary Delaware Superior Court, New Castle County Leonard L. Williams Justice Center 500 North King Street Wilmington, DE 19801
Dear Ms. Fontello:
We represent Pacific Alliance Asia Opportunity Fund L.P. ("Pacific Alliance"), in Pacific Alliance Asia Opportunity Fund L.P. v. Kwok, et al., Index No. 652077/2017, in New York Supreme Court. Pacific Alliance is subpoenaing Greenwich Land, LLC, a Delaware Limited Liability Company whose registered agent, Corporate Creations Network Inc., is located at 3411 Silverside Road, Tatnall Building, Suite 104, Wilmington, Delaware 19810, in New Castle County. As required, we have enclosed (1) the New York subpoenas, (2) the Delaware subpoena, (3) the New York County Case Docket Sheet, and (4) a list of the counsel of record.
Please contact me if there are any questions. Please also contact me when the subpoena is ready at (212) 728-5671 or emoss@omm.com. Thank you in advance.
Edward Moss D: +1 212 728 5671 emoss@omm.com SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF NEW YORK
PACIFIC ALLIANCE ASIA OPPORTUNITY FUND L.P.,
v.
KWOK HO WAN, a/k/a KWOK HO, a/k/a GWO WEN GUI, a/k/a GUO WENGUI, a/k/a GUO WEN GUI, a/k/a WAN GUE HAOYUN, a/k/a MILES KWOK, a/k/a HAOYUN GUO, GENEVER HOLDINGS CORPORATION, and GENEVER HOLDINGS LLC,
Hon. Barry R. Ostrager, J.S.C.
Defendants.
TO: Greenwich Land, LLC C/O Corporate Creations Network, Inc. 3411 Silverside Rd. Tatnall Building Ste. 104 Wilmington, DE 19810
WHEREAS, in an action in the Supreme Court of the State of New York, County of New York, Index No. 652077/2017, between Pacific Alliance Asia Opportunity Fund L.P. ("Judgment Creditor") and Defendants Miles Kwok ("Judgment Debtor"), Genever Holdings Corporation, and Genever Holdings LLC, being all the parties to the action, on February 3, 2021, the Supreme Court of the State of New York, County of New York, entered judgment in favor of Judgment Creditor and against Judgment Debtor in the amount of \$116,402,019.57. This amount, together with statutory interest, remains due and unpaid.
PLEASE TAKE NOTICE that pursuant to CPLR § 5222(b), which is set forth in full herein, you are hereby forbidden to make or suffer any sale, assignment or transfer of, or any interference with, any property in which Judgment Debtor has an interest, except as provided in CPLR § 5222(b). We understand the Judgment Debtor may have direct, indirect, or beneficial ownership in, or the right or ability to direct or control, you and your assets.
5222(b) Effect of restraint; prohibition of transfer; duration. A judgment debtor or obligor served with a restraining notice is forbidden to make or suffer any sale, assignment, transfer or interference with any property in which he or she has an interest, except as set forth in subdivisions (h) and (i) of this section, and except upon direction of the sheriff or pursuant to an order of the court, until the judgment or order is satisfied or vacated. A restraining notice served upon a person other than the judgment debtor or obligor is effective only if, at the time of service, he or she owes a debt to the judgment debtor or obligor or he or she is in the possession or custody of property in which he or she knows or has reason to believe the judgment debtor or obligor has an interest, or if the judgment creditor or support collection unit has stated in the notice that a specified debt is owed by the person served to the judgment debtor or obligor or that the judgment debtor or obligor has an interest in specified property in the possession or custody of the person served. All property in which the judgment debtor or obligor is known or believed to have an interest then in and thereafter coming into the possession or custody of such a person, including any specified in the notice, and all debts of such a person, including any specified in the notice, then due and thereafter coming due to the judgment debtor or obligor, shall be subject to the notice except as set forth in subdivisions (h) and (i) of this section. Such a person is forbidden to make or suffer any sale, assignment or transfer of, or any interference with, any such property, or pay over or otherwise dispose of any such debt, to any person other than the sheriff or the support collection unit, except as set forth in subdivisions (h) and (i) of this section, and except upon direction of the sheriff or pursuant to an order of the court, until the expiration of one year after the notice is served upon him or her, or until the judgment or order is satisfied or vacated, whichever event first occurs. A judgment creditor or support collection unit which has specified personal property or debt in a restraining notice shall be liable to the owner of the property or the person to whom the debt is owed, if other than the judgment debtor or obligor, for any damages sustained by reason of the restraint. If a garnishee served with a restraining notice withholds the payment of money belonging or owed to the judgment debtor or obligor in an amount equal to twice the amount due on the judgment or order, the restraining notice is not effective as to other property or money. PLEASE TAKE FURTHER NOTICE that disobedience of this Restraining Notice is
punishable as a contempt of Court.
Respectfully submitted, O'MELVENY & MYERS LLP
Stuart Sarnoff (ssarnoff@omm.com) Edward Moss (emoss@omm.com) 7 Times Square New York, NY 10036 (212) 326-2000
Attorneys for Plaintiff Pacific Alliance Asia Opportunity Fund L.P. SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF NEW YORK
PACIFIC ALLIANCE ASIA OPPORTUNITY FUND L.P.,
v.
KWOK HO WAN, a/k/a KWOK HO, a/k/a GWO WEN GUI, a/k/a GUO WENGUI, a/k/a GUO WEN GUI, a/k/a WAN GUE HAOYUN, a/k/a MILES KWOK, a/k/a HAOYUN GUO, GENEVER HOLDINGS CORPORATION, and GENEVER HOLDINGS LLC,
Hon. Barry R. Ostrager, J.S.C.
Defendants.
TO: Greenwich Land, LLC C/O Corporate Creations Network, Inc. 3411 Silverside Rd. Tatnall Building Ste. 104 Wilmington, DE 19810
WHEREAS, in an action in the Supreme Court of the State of New York, County of New York, Index No. 652077/2017, between Pacific Alliance Asia Opportunity Fund L.P. ("Judgment Creditor") and Defendants Miles Kwok ("Judgment Debtor"), Genever Holdings Corporation, and Genever Holdings LLC, being all the parties to the action, on February 3, 2021, the Supreme Court of the State of New York, County of New York, entered judgment in favor of Judgment Creditor and against Judgment Debtor in the amount of \$116,402,019.57. This amount, together with statutory interest, remains due and unpaid.
YOU ARE HEREBY COMMANDED, pursuant to New York Civil Practice Law and Rules ("CPLR") §§ 5223 and 5224, all business and excuses being laid aside, to produce for inspection and copying the documents in your possession, custody, or control, identified in Exhibit
A hereto. Such documents shall be produced by 9:00 A.M. on June 15, 2021, at the offices of O'Melveny & Myers LLP, 7 Times Square, New York, New York 10036. These documents are sought because they are material and relevant to the satisfaction of the judgment entered in this action.
FAILURE TO COMPLY with this subpoena is punishable as a contempt of Court and will render you subject to penalties provided by the CPLR.
Respectfully submitted, O'MELVENY & MYERS LLP
Stuart Sarnoff (ssarnoff@omm.com) Edward Moss (emoss@omm.com) 7 Times Square New York, NY 10036 (212) 326-2000
Attorneys for Plaintiff Pacific Alliance Asia Opportunity Fund L.P.
TO:
Greenwich Land, LLC C/O Corporate Creations Network, Inc. 3411 Silverside Rd. Tatnall Building Ste. 104 Wilmington, DE 19810
All requests are deemed to be continuing and the Respondent shall promptly provide supplemental responses and documents upon obtaining information on the basis of which they know either that a response was incorrect or incomplete when made or that the response, although correct and complete when made, is no longer correct or complete.
1. If any documents that would have been responsive to any of the requests have been destroyed, identify each document destroyed and specify the date or approximate date of destruction, the means of destruction, the person or persons causing such destruction, and the cause for destruction.
2. If any documents that would have been responsive to any of the requests are no longer in Respondent's possession, custody, or control, identify each document, the person who currently has possession, custody, or control of the document, and the date possession, custody, or control was transferred to that person.
3. No part of the request shall be left not responded to merely because an objection is interposed to another part of the request. If Respondent objects to a part or parts of a given request, Respondent must state the part objected to and permit inspection of all remaining parts. All grounds for an objection to a document request must be stated with specificity. Any ground not stated in a timely objection is waived unless our failure to object is excused by the court.
4. Any document not produced in response to this request, because of a claimed privilege or for any other reason, should be listed according to the request number; and for each document withheld, its date, number of pages, author, sender, recipient, identification of all persons shown as receiving copies, subject matter, and the grounds for non-production should be set forth. Documents are requested to be produced for inspection as they have been kept in their
original files, folders, notebooks, bindings, boxes, or other organizers or devices used to file or store them.
5. If production of documents is made in a timely manner, witness does not need to appear pursuant to summons.
6. The terms "relate to," "relating to," and "related to" mean concerning, evidencing, supporting, undermining, arising from, commenting on, responding to, showing, describing, analyzing, reflecting or constituting.
7. The terms "and" as well as "or" have both conjunctive and disjunctive meanings.
8. The terms "any" and "all" mean "each" and "every."
9. As employed herein, the singular shall mean the plural and vice versa.
10. If a requested document exists in electronic form, e.g., an e-mail, spreadsheet,
Word document, Power Point Presentation, such electronic document shall be produced in its native format.
11. Document Productions can be made to Edward Moss of O'Melveny & Myers LLP. Any questions regarding document production can be directed to emoss@omm.com.
12. The relevant time period for purposes of these Requests, unless otherwise indicated, is January 1, 2008, to present.
1. "Account" means any bank, brokerage, investment, cryptocurrency, or other accounts (including, but not limited to, the bank or brokerage name and location, name(s) on account, account number, and account balance).
2. "Asset" means any asset or property whatsoever, whether tangible or intangible, including, without limitation, cash, bank accounts, brokerage accounts, real property, land,
corporate shares, membership or interest in a limited liability company or partnership, stocks, shares, bonds, investments, investment vehicles, actual or potential judgments, liens, easements, attachments, leases, intellectual property including, without limitation, patents and trademarks, automobiles, airplanes, helicopters, sea vessels, vehicles, artwork, collectibles, clothing, jewelry, cryptocurrency, crypto-wallets, safe deposit boxes, chattel, precious stones or metals, pledged or hypothecated assets, contingent financial interests, options, warrants, securities, commodities, receivables, convertible loans, and interests derived from financial instruments, whether directly or indirectly held.
3. "Communication" means the transmittal of information (in the form of facts, ideas, inquiries, or otherwise) and/or any other communicative contact between two or more Persons and/or entities, and shall include, without limitation: written contacts by such means as any Document as defined herein, and oral contact by such means as face-to-face or in-person meetings, telephone conversations, e-mail, and any other form of electronic communication such as telecopy transmissions, telexes, telegrams, and video transmissions, and the originals, drafts, copies, and all non-identical copies of all Documents.
4. "Debtor" refers to Miles Kwok a/k/a Kwok Ho Wan, a/k/a Kwok Ho, a/k/a Gwo Wen Gui, a/k/a Guo Wengui, a/k/a Guo Wen-Gui, a/k/a Wan Gue Haoyun, a/k/a Haoyun Guo.
5. "Debtor-Related Person" or "Debtor-Related Persons" is defined in Appendix 1.
6. "Document" is used in the broadest possible sense and means, without limitation, each and every writing of whatever nature, whether an original, draft, copy, or non-identical copy (e.g., because handwritten or "blind notes" or notations appear thereon or are attached thereto), however produced or reproduced, including, but not limited to, typed, printed, photocopied, photographic, machine-readable, magnetically or optically recorded matter of any
kind, and each and every tangible thing from which information can be processed or transcribed, such as tape, disk, or other electronic data compilations. The term includes, but is not limited to, letters; e-mails; text messages; instant messages; envelopes; forms; web pages; websites; analysis; announcements; bills; wires; films; photographs; proofs; prospectuses; reports; receipts; schedules; statements; surveys; statistics; books; checks of any kind; promissory notes; charts; drawings; affidavits; correspondence; social media posts; publications; telegraphs; telecopies; facsimiles; paper communications; electronic communications; signed statements; tabulations; analyses; work papers; charts; graphs; memoranda; licenses; manuals; maps; minutes; plans; permits; appointment books; records; financial statements; proposals; memoranda or other transcriptions by mechanical device, or by longhand or shorthand recording; tape recorded materials; materials recorded by any electronic means; native files; metadata; computer generated information; computer software; computer files; electronically stored information; computer disks; computer tapes; interoffice communications; all summaries of oral communications, telephonic or otherwise; microfiche; microfilm; lists; bulletins; calendars; circulars; desk pads; opinions; ledgers; logs; minutes; agreements; accountings; accounts; journals; diaries; contracts; vouchers; invoices; calendar and diary entries; notebooks; notes; charges; balance sheets; telephone messages or other messages; magazines; pamphlets; articles; notices; newspapers; studies; summaries; worksheets; telexes; cables; records of telephone conversations or face-to-face conversations; marginal comments appearing on any documents; and all other graphic materials, writings, and instruments. The term "Document" includes both the "Document" itself and anything appended thereto.
7. "Interest" means any direct or indirect interest, whether partial, whole, potential, or contingent, including, without limitation, legal ownership, beneficial ownership, right to
control, ownership of any or all of the shares of an incorporated entity, membership or interest in a limited liability company or partnership, or access to funds or assets.
8. "Respondent" refers to whom this subpoena is directed.
Pursuant to CPLR §§ 5223 and 5224, Plaintiff demands that Respondent produce at the date and location listed on the subpoena above, or at a time and location mutually agreeable to the parties, all (whether in hard copy or digital) books, records, communications, (including, but not limited to, e-mail, text message, electronic messaging, mail, fax and the like), and papers as follows:
1. All Documents and Communications relating to the property located at 33 Ferncliff Road, Cos Cob, CT 06807, including but not limited to Documents and Communications relating to:
- a. the identity of the occupant(s) and resident(s); - b. the identity of the owner; - c. the purchase (including but not limited to the purchase price and the source of the funds used for the purchase); - d. the actual or potential sale or efforts to sell or rent or lease; - e. the amount and nature of monthly expenses and the source of the funds used to pay those expenses; and - f. mortgages, trusts, liens, encumbrances, or pledges - 2. All Documents and Communications relating to the property located at 373 Taconic Road, Stamford, CT 06904, including but not limited to Documents and Communications relating to: - a. the identity of the occupant(s) and resident(s); - b. the identity of the owner; - c. the purchase (including but not limited to the purchase price and the source of the funds used for the purchase); - d. the actual or potential sale or efforts to sell or rent or lease; - e. the amount and nature of monthly expenses and the source of the funds used to pay those expenses; and - f. mortgages, trusts, liens, encumbrances, or pledges - 3. All Communications with the Debtor.
4. All Documents and Communications relating to any of Debtor's past or present Interests, Assets, and Accounts.
5. All Documents and Communications relating to businesses or other ventures involving Debtor.
6. All Documents and Communications relating to any Debtor-Related Person(s)'s past or present Interests, Assets, and Accounts.
7. All Documents and Communications relating to businesses or other ventures involving any Debtor-Related Persons(s).
8. All Documents and Communications relating to Debtor's past and present relationship with and Interest in Respondent.
9. All Documents and Communications relating to any Debtor-Related Person(s)'s past and present relationship with and Interest in Respondent.
10. All Documents and Communications relating to Respondent's past and present relationship with and Interest in any Debtor-Related Person(s).
11. Documents sufficient to identify Respondent's Interests, Accounts, and Assets
(including without limitation their amount and location), including without limitation:
- a. Bank account documents, including statements, check images (front and back), deposits, withdrawals, incoming and outgoing wire transfers, signatory cards, and account opening records. - b. Brokerage account documents, including statements, signatory cards, account opening records, detailed wires of each account, and details on linked accounts. - c. Credit card account documents, including statements, check images (front and back), incoming and outgoing wire transfers, signatory cards, and account opening records. - d. Documents relating to debts or liabilities, including without limitation outstanding mortgages, regardless whether the account is in default, arrears, or foreclosure. - e. Financial statements, statements of assets and liabilities, balance sheets, income statements, and expense statements. - f. Solvency opinions, appraisals, valuation opinions, and analysis conducted by Respondent or third-parties in connection with Respondent's business. - g. Documents evidencing ownership, including without limitation deeds and ownership certificates. - h. Other business records of any kind. - 12. All Documents and Communications relating to any actual or contemplated
transactions, transfers, distributions, or conveyances (including without limitation payments,
loans, benefits, gifts, compensation, and income), including without limitation those involving or
made on behalf of Debtor and any Debtor-Related Person(s).
13. Any and all tax returns (whether filed by Respondent, Debtor, or any Debtor-Related Person), including schedules, filed in the United States (both federal and state) and any
other country from 2015 to the present.
14. Documents sufficient to identify all service provides who have been engaged by Respondent (including but not limited to lawyers, accountants, advisers, brokers, and maintenance or other service providers) for the properties located at 33 Ferncliff Road, Cos Cob, CT 06807 and 373 Taconic Road, Stamford, CT 06904.
15. Documents sufficient to show Respondent's ownership structure, reflecting any and all changes since the date of Respondent's formation or incorporation, including without limitation organizational charts, and formation documents.
16. Documents sufficient to identify Respondent's employees, officers, and directors.
17. All Documents and Communications relating to Respondent's internal governance and decision-making, including without limitation bylaws, operating agreements, consents, notices, minutes, resolutions, board meeting packages, and other documents evidencing approval or denial of any corporate, business or legal action.
18. Documents sufficient to show how Respondent has been capitalized since its formation or incorporation, including without limitation documents identifying the source(s) of funds used to capitalize Respondent. Appendix 1 List of Debtor-Related Persons
- AI Group Holdings Inc.
- Beijing Pangu Investment Co. - Beijing Pangu Investment Co. Ltd. - Beijing Pangu Investment Inc. - Beijing Zenith Holdings Company Limited
- China Golden Spring (Hong Kong) Limited
- GFASHION MEDIA GROUP INC.
- GTV Media Group, Inc.
- Hamilton Capital Holdings Inc.
- Hong Kong International Funds Investments Limited - HK International Funds Investments (USA) Limited, LLC
- Rule of Law Foundation III, Inc. - Rule of Law Foundation IV Inc.
- Rule of Law Society IV, Inc. - Saraca Media Group, Inc.
- Voice of Guo Media Inc.
SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF NEW YORK
PACIFIC ALLIANCE ASIA OPPORTUNITY FUND L.P.,
v.
KWOK HO WAN, a/k/a KWOK HO, a/k/a GWO WEN GUI, a/k/a GUO WENGUI, a/k/a GUO WEN-GUI, a/k/a WAN GUE HAOYUN, a/k/a MILES KWOK, a/k/a HAOYUN GUO,
Defendant.
TO: Greenwich Land, LLC C/O Corporate Creations Network, Inc. 3411 Silverside Rd. Tatnall Building Ste. 104 Wilmington, DE 19810
WHEREAS, in an action in the Supreme Court of the State of New York, County of New
York, Index No. 652077/2017, between Pacific Alliance Asia Opportunity Fund L.P.
("Judgment Creditor") and Defendants Miles Kwok ("Judgment Debtor"), Genever Holdings
Corporation, and Genever Holdings LLC, being all the parties to the action, on February 3, 2021,
the Supreme Court of the State of New York, County of New York, entered judgment in favor of
Judgment Creditor and against Judgment Debtor in the amount of \$116,402,019.57. This
amount, together with statutory interest, remains due and unpaid.
YOU ARE HEREBY COMMANDED, pursuant to New York Civil Practice Law and
Rules ("CPLR") §§ 5223 and 5224, all business and excuses being laid aside, to attend a
deposition upon oral or written questions.
PLEASE TAKE NOTICE that, under Articles 23 and 31 of the New York Civil Practice Law and Rules, and Commercial Division Rule 11-f, the Judgment Creditor, by its attorneys at O'Melveny & Myers LLP, will take by stenographic method the deposition upon oral examination of any officer, director, member, or employee of Greenwich Land, LLC who is most knowledgeable to give full and complete testimony on the topics set forth in Exhibit A.
The deposition will be conducted by remote video conference on June 15, 2021, beginning at 10:00 a.m., or at another mutually agreed upon date and time. The deposition will be recorded stenographically and by videotape by a representative of Veritext Legal Solutions, 1250 Broadway, Suite 2400, New York, New York 10001.
Disclosure is being sought from you because, upon information and belief, you possess information relevant and material to the above-captioned action, including without limitation information relating to the Judgment Creditor's efforts to collect on the above-referenced judgment.
PLEASE TAKE FURTHER NOTICE that pursuant to New York Commercial Division Rule 11-f, you must provide counsel for the Judgment Creditor with the name, description, and title of the officer, director, member, employee, or individual who will testify on your behalf no later than ten (10) days prior to the scheduled deposition. Such designation must include the identity, description, or title of such individual. If you designate more than one individual to testify on your behalf, you must also provide counsel for Judgment Creditor with the matters on which each individual will testify. The individual(s) designated must testify about information known or reasonably known to Greenwich Land, LLC, and their testimony can be used against Greenwich Land, LLC to the same extent provided in CPLR § 3117(2) and the applicable rules of evidence. Failure to comply with this subpoena is punishable as a contempt of Court and shall
make you liable to the person on whose behalf this subpoena was issued for a penalty not to exceed fifty dollars (\$50.00) and all damages sustained by reason of your failure to comply.
DATED: May 4, 2021 New York, New York Respectfully submitted, O'MELVENY & MYERS LLP
Stuart Sarnoff (ssarnoff@omm.com) Edward Moss (emoss@omm.com) 7 Times Square New York, NY 10036 (212) 326-2000
Attorneys for Plaintiff Pacific Alliance Asia Opportunity Fund L.P.
1. "And" has both conjunctive and disjunctive meanings.
2. "Any" means each and every.
3. "Asset" means any asset or property whatsoever, whether tangible or intangible, including, without limitation, cash, bank accounts, brokerage accounts, real property, land, corporate shares, membership or interest in a limited liability company or partnership, stocks, shares, bonds, investments, investment vehicles, actual or potential judgments, liens, easements, attachments, leases, intellectual property including, without limitation, patents and trademarks, automobiles, airplanes, helicopters, sea vessels, vehicles, artwork, collectibles, clothing, jewelry, cryptocurrency, crypto-wallets, safe deposit boxes, chattel, precious stones or metals, pledged or hypothecated assets, contingent financial interests, options, warrants, securities, commodities, receivables, convertible loans, and interests derived from financial instruments, whether directly or indirectly held.
4. "Debtor-Related Person" or "Debtor-Related Persons" is defined in Appendix 1.
5. "Interest" means any direct or indirect interest, whether partial, whole, potential, or contingent, including, without limitation, legal ownership, beneficial ownership, right to control, ownership of any or all of the shares of an incorporated entity, membership or interest in a limited liability company or partnership, or access to funds or assets
6. "Miles Kwok" means Kwok Ho Wan, a/k/a Kwok Ho, a/k/a Gwo Wen Gui, a/k/a Guo Wengui, a/k/a Guo Wen-Gui, a/k/a Wan Gue Haoyun, a/k/a Miles Kwok, a/k/a Haoyun Guo, and all of his agents, attorneys, representatives, and all other persons or entities acting or purporting to act on his behalf.
7. "Or" has both conjunctive and disjunctive meanings.
8. "Properties" means the properties located at 33 Ferncliff Road, Cos Cob, CT
06807 and the property located at 373 Taconic Road, Stamford, CT 06904.
9. "You" and "Your" means, without limitation Greenwich Land, LLC, including all entities it controls and also including all of its agents, attorneys, representatives, and all other persons or entities acting or purporting to act on its behalf.
- 1. The Assets and liabilities of Greenwich Land, LLC. - 2. The Properties, including without limitation: - a. the occupants and residents of the Properties; - b. the owner of the Properties and those who have an Interest in the Properties; - c. the purchase of the Properties (including but not limited to the purchase price and the source of the funds used for the purchase); - d. any actual or potential transfers of the Properties or of any Interest in the Properties; - e. the listing or potential sale of the Properties or of any Interest in the Properties; - f. any individuals or companies who use, have used, work, have worked, live, or have lived on the Properties; - g. any monies transferred relating in any way to the Properties; - h. all past and present mortgages, liens, pledges, trusts, and encumbrances on the Properties; - i. Miles Kwok's or any Debtor-Related Person(s)'s Interest in the Properties; and - j. the amount and nature of monthly expenses for the Properties and the source of the funds used to pay those expenses.
3. Greenwich Land, LLC's relationship to Miles Kwok or any Debtor-Related
Person.
4. The Assets and liabilities of Miles Kwok or any Debtor-Related Person.
5. Any actual or potential payments, transfers, loans, or gifts made or given by You to or on behalf of Miles Kwok or any Debtor-Related Person.
6. Any actual or potential payments, transfers, loans, or gifts made or given to You by or on behalf of Miles Kwok or any Debtor-Related Person.
7. The formation and business purpose of Greenwich Land, LLC.
8. The employees, officers, directors, and corporate and organizational structure of Greenwich Land, LLC. Appendix 1 List of Debtor-Related Persons
- AI Group Holdings Inc.
- Beijing Pangu Investment Co. - Beijing Pangu Investment Co. Ltd. - Beijing Pangu Investment Inc. - Beijing Zenith Holdings Company Limited
- China Golden Spring (Hong Kong) Limited
- GFASHION MEDIA GROUP INC.
- GTV Media Group, Inc.
- Hamilton Capital Holdings Inc.
- Hong Kong International Funds Investments Limited - HK International Funds Investments (USA) Limited, LLC
- Rule of Law Foundation III, Inc. - Rule of Law Foundation IV Inc.
- Rule of Law Society IV, Inc. - Saraca Media Group, Inc.
- Voice of Guo Media Inc.
SUPERIOR COURT OF THE STATE OF DELAWARE Case 22-50073 Doc 1604-47 Filed 03/27/23 Entered 03/27/23 14:12:10 Page 25 of 65
Pacific Alliance Asia Opportunity Fund L.P.
Kwok Ho Wan a/k/a Kwok Ho, a/k/a Gwo Wen Gui, a/k/ a Guo Wengui, a/k/a Guo Wen-Gui, a/k/a Wan Gue Haoyun, a/k/a Miles Kwok, a/k/a Haoyun Guo, Genever Holdings, LLC, Genever Holdings Corporation OUT OF STATE SUBPOENA IN A CIVIL CASE v.
Civil Action No.:
TO: Greenwich Land, LLC c/o Corporate Creations Network, Inc. 3411 Silverside Road, Tatnall Building, Ste. 104 Wilmington, DE 19810
YOU ARE COMMANDED to appear in the Delaware Superior Court at the place, date, and time specified below to testify in the above case.
YOU ARE COMMANDED to appear at the place, date, and time specified below to testify at the taking of a deposition in the above case. X
YOU ARE COMMANDED to produce and permit inspection and copying of the following documents or objects at the place, date, and time specified below (list documents or objects): X
YOU ARE COMMANDED to permit inspection of the following premises at the date and time specified below.
Any organization not a party to this suit that is subpoenaed for the taking of a deposition shall
designate one or more officers, directors, or managing agents, or other persons who consent to testify on its behalf, and may set forth, for each person designated, the matters on which the person will testify. Delaware Superior Court Civil Rule 30 (b) (6).
REQUESTING PARTY'S NAME, ADDRESS AND PHONE NUMBER Pacific Alliance Asia Opportunity Fund L.P. c/o O'Melveny & Myers LLP 7 Times Square, New York, NY 10036 - (212) 326-2000
Case 22-50073 Doc 1604-47 Filed 03/27/23 Entered 03/27/23 14:12:10 Page 26
SERVED ON (PRINT NAME) MANNER OF SERVICE
I declare under penalty of perjury under the laws of the State of Delaware that the foregoing information contained in the Proof of Service is true and correct.
Superior Court Civil Rule 45, Parts C, D & E: (c) Protection of Persons Subject to Subpoenas.
(1) A party or an attorney responsible for the issuance and service of a subpoena shall take reasonable steps to avoid imposing undue burden or expense on a person subject to that subpoena. The Court shall enforce this duty and impose upon the party or attorney in breach of this duty an appropriate sanction, which may include, but is not limited to, lost earnings and a reasonable attorney's fee.
(2)(A) A person commanded to produce and permit inspection and copying of designated books, papers, documents or tangible things or inspection of premises need not appear in person at the place of production or inspection unless commanded to appear for deposition, hearing or trial.
(B) Subject to paragraph (d)(2) of this rule, a person commanded to produce and permit inspection and copying may, within 14 days after service of the subpoena or before the time specified for compliance if such time is less than 14 days after service, serve upon the party or attorney designated in the subpoena written objection to inspection or copying of any or all of the designated materials or of the premises. If objection is made, the party serving the subpoena shall not be entitled to inspect and copy the materials or inspect the premises except pursuant to an order of the Court. If objection has been made, the party serving the subpoena may, upon notice to the person commanded to produce, move at any time for an order to compel the production. Such an order to compel production shall protect any person who is not a party or an officer of a party from significant expense resulting from the inspection and copying commanded.
(3)(A) On timely motion, the Court shall quash or modify the subpoena if it
(i) fails to allow reasonable time for compliance,
(ii) requires disclosure of privileged or other
protected matter and no exception or waiver applies, or
(iii) subjects a person to undue burden.
(i) requires disclosure of a trade secret or other confidential research, development, or commercial information, or
(ii) requires disclosure of an unretained expert's opinion or information not describing specific events or occurrences in dispute and resulting from the expert's study made not at the request of any party,
the Court may, to protect a person subject to or affected by the subpoena, quash or modify the subpoena or, if the party in whose behalf the subpoena is issued shows a substantial need for the testimony or material that cannot be otherwise met without undue hardship and assures that the person to whom the subpoena is addressed will be reasonably compensated, the Court may order appearance or production only upon specified conditions. (d) Duties in Responding to Subpoena.
(1) A person responding to a subpoena to produce documents shall produce them as they are kept in the usual course of business or shall organize and label them to correspond with the categories in the demand.
(2) When information subject to a subpoena is withheld on a claim that it is privileged or subject to protection as trial preparation materials, the claim shall be made expressly and shall be supported by a description of the nature of the documents, communications, or things not produced that is sufficient to enable the demanding party to contest the claim. (e) Contempt.
Failure by any person without adequate excuse to obey a subpoena served upon that person may be deemed a contempt of court.
New York County Supreme Court 652077/2017 NYSCEF
Case Caption: Pacific Alliance Asia Opportunity Fund L.P. v. Kwok Ho Wan et al
Doc# Document Type/Information Status Date Received Filed By
Summons Processed 04/18/2017 Seiden, R.
Complaint Processed 04/18/2017 Seiden, R.
2011 Facility Letter Processed 04/18/2017 Seiden, R.
Personal Guarantee Processed 04/18/2017 Seiden, R.
Affidavit of Service Processed 04/21/2017 Seiden, R.
Stipulation to Extend Time to Respond to Complaint Processed 05/26/2017 Lee, F.
Notice of Motion to Dismiss Processed 06/29/2017 Schiller, J.
Memorandum of Law in Support of Defendant's Motion to Dismiss Processed 06/29/2017 Schiller, J. 9 AFFIDAVIT OR AFFIRMATION IN SUPPORT OF Affirmation of Benjamin Margulis in Support of Defendant's Motion to Dismiss Processed 06/29/2017 Schiller, J.
Margulis Aff. Exhibit 1 - Complaint Processed 06/29/2017 Schiller, J. 11 AFFIDAVIT OR AFFIRMATION IN SUPPORT OF Affirmation of Fiona Yu in Support of Defendant's Motion to Dismiss Processed 06/29/2017 Schiller, J.
Yu Aff. Ex. 1 - Loan Facility Letter dated February 4, 2008 Processed 06/29/2017 Schiller, J.
Yu Aff. Ex. 2 - Loan Facility Letter dated March 12, 2008 Processed 06/29/2017 Schiller, J.
Yu Aff. Ex. 3 - Deed of Settlement dated September 17, 2009 Processed 06/29/2017 Schiller, J.
Yu Aff. Ex. 4 - Personal Guarantee dated November 18, 2009 Processed 06/29/2017 Schiller, J.
Yu Aff. Ex. 5 - Loan Facility Letter dated March 16, 2011 Processed 06/29/2017 Schiller, J.
Yu Aff. Ex. 6 - Personal Guarantee dated March 16, Processed 06/29/2017 Schiller, J.
Yu Aff. Ex. 7 - Deed of Settlement dated April 19, 2013 Processed 06/29/2017 Schiller, J.
Yu Aff. Ex. 8 - Supplemental Deed of Settlement dated December 13, 2013 Processed 06/29/2017 Schiller, J.
Yu Aff. Ex. 9 - Supplemental Deed of Settlement dated Processed 06/29/2017 Schiller, J.
Doc# Document Type/Information Status Date Received Filed By
New York County Supreme Court 652077/2017
21 EXHIBIT(S) Yu Aff. Ex. 10 - Supplemental Deed of Settlement dated July 11, 2014 Processed 06/29/2017 Schiller, J. 22 EXHIBIT(S) Yu Aff. Ex. 11 - Supplemental Deed of Settlement dated February 10, 2015 Processed 06/29/2017 Schiller, J. 23 EXHIBIT(S) Yu Aff. Ex. 12 - Option Agreement dated March 31, 2015 Processed 06/29/2017 Schiller, J. 24 AFFIDAVIT OR AFFIRMATION IN SUPPORT OF Affidavit of Kwok Ho Wan in Support of Defendant's Motion to Dismiss Processed 06/29/2017 Schiller, J. 25 RJI -RE: NOTICE OF MOTION Request for Judicial Intervention Processed 06/29/2017 Schiller, J. 26 ADDENDUM - COMMERCIAL DIVISION (840C) Processed 06/29/2017 Schiller, J. 27 NOTICE OF MOTION Notice of Plaintiff's Motion for Pre-Judgment Order of Attachment Processed 07/07/2017 Moss, E. 28 MEMORANDUM OF LAW IN SUPPORT Plaintiff's Memorandum of Law In Support Processed 07/07/2017 Moss, E. 29 AFFIDAVIT OR AFFIRMATION IN SUPPORT Affirmation of Pacific Alliance Asia Opportunity Fund L.P. In Support Processed 07/07/2017 Moss, E. 30 EXHIBIT(S) 2011 Facility Letter Processed 07/07/2017 Moss, E. 31 EXHIBIT(S) Personal Guarantee Processed 07/07/2017 Moss, E. 32 EXHIBIT(S) Original Deed of Settlement Processed 07/07/2017 Moss, E. 33 EXHIBIT(S) Supplemental Deed of Settlement Processed 07/07/2017 Moss, E. 34 EXHIBIT(S) Second Supplemental Deed of Settlement Processed 07/07/2017 Moss, E. 35 EXHIBIT(S) Third Supplemental Deed of Settlement Processed 07/07/2017 Moss, E. 36 EXHIBIT(S) Fourth Supplemental Deed of Settlement Processed 07/07/2017 Moss, E. 37 EXHIBIT(S) Option Agreement Processed 07/07/2017 Moss, E. 38 EXHIBIT(S) Kwok Notice of Demand Processed 07/07/2017 Moss, E. 39 EXHIBIT(S) Shiny Times Demand Letter Processed 07/07/2017 Moss, E. 40 AFFIDAVIT OR AFFIRMATION IN SUPPORT Affirmation of Derek Crane In Support Processed 07/07/2017 Moss, E. 41 AFFIDAVIT OR AFFIRMATION IN SUPPORT Affirmation of Christopher Gradel In Support Processed 07/07/2017 Moss, E.
New York County Supreme Court 652077/2017 Document List Index # of 65
Doc# Document Type/Information Status Date Received Filed By
Affirmation of Ian Zheng In Support Processed 07/07/2017 Moss, E.
Affidavit of Nathaniel Francis In Support Processed 07/07/2017 Moss, E.
Certificate of Incorporation Processed 07/07/2017 Moss, E.
Order Processed 07/07/2017 Moss, E.
Article Processed 07/07/2017 Moss, E.
Complaint Processed 07/07/2017 Moss, E.
Utility Bill Processed 07/07/2017 Moss, E.
Photos Processed 07/07/2017 Moss, E.
Article Processed 07/07/2017 Moss, E.
Business Record Processed 07/07/2017 Moss, E.
Public Land Records Processed 07/07/2017 Moss, E.
Article Processed 07/07/2017 Moss, E.
Article Processed 07/07/2017 Moss, E.
Article Processed 07/07/2017 Moss, E.
Article Processed 07/07/2017 Moss, E.
Article Processed 07/07/2017 Moss, E.
Article Processed 07/07/2017 Moss, E.
Article Processed 07/07/2017 Moss, E.
Summons Processed 07/07/2017 Moss, E.
Certified Translation Processed 07/07/2017 Moss, E.
Affirmation of Edward Moss In Support Processed 07/07/2017 Moss, E.
Complaint Processed 07/07/2017 Moss, E.
Stipulation Processed 07/07/2017 Moss, E.
Motion to Dismiss Papers Processed 07/07/2017 Moss, E.
New York County Supreme Court 652077/2017 Document List Index # of 65
Doc# Document Type/Information Status Date Received Filed By
Defendant's Memorandum of Law in Opposition to Plaintiff's Motion for Pre-Judgment Order of Attachme Processed 08/01/2017 Schiller, J. 67 AFFIDAVIT OR AFFIRMATION IN OPPOSITION TO
Affirmation of Joshua I. Schiller in Opposition to Plaintiff's Motion for Pre-Judgment Order of Atta Processed 08/01/2017 Schiller, J.
Realtor.com Website Processed 08/01/2017 Schiller, J.
XF444641 Delivery Notice Processed 08/01/2017 Schiller, J.
XF444738 Delivery Notice Processed 08/01/2017 Schiller, J.
XF444752 Delivery Notice Processed 08/01/2017 Schiller, J.
XF444641 Purchase Agreement Processed 08/01/2017 Schiller, J.
XF444738 Purchase Agreement Processed 08/01/2017 Schiller, J.
XF444752 Purchase Agreement Processed 08/01/2017 Schiller, J.
Plaintiff's Memorandum of Law in Opposition to Defendants Motion to Dismiss Complaint Processed 08/01/2017 Moss, E. 76 AFFIDAVIT OR AFFIRMATION IN OPPOSITION TO
Affirmation of Edward Moss in Opposition to Defendant's Motion to Dismiss Processed 08/01/2017 Moss, E.
Article Processed 08/01/2017 Moss, E.
Article Processed 08/01/2017 Moss, E.
Article Processed 08/01/2017 Moss, E.
Article Processed 08/01/2017 Moss, E.
Article Processed 08/01/2017 Moss, E.
Article Processed 08/01/2017 Moss, E.
Article Processed 08/01/2017 Moss, E.
Article Processed 08/01/2017 Moss, E.
Certified Translation Processed 08/01/2017 Moss, E.
First Affidavit of Fei-Xue Qian Processed 08/01/2017 Moss, E.
New York County Supreme Court 652077/2017
Doc# Document Type/Information Status Date Received Filed By
Mandarin Transcription Processed 08/01/2017 Moss, E.
English Translation Processed 08/01/2017 Moss, E.
Second Affidavit of Fei-Xue Qian Processed 08/01/2017 Moss, E.
Mandarin Transcription Processed 08/01/2017 Moss, E.
English Translation Processed 08/01/2017 Moss, E.
Defendant's Reply Memorandum of Law in Further Support of Defendant's Motion to Dismiss Processed 08/07/2017 Schiller, J.
Reply Memorandum in Support of Motion for Pre Judgment Order of Attachment Processed 08/07/2017 Moss, E.
Affirmation of Vishal Prakash Melwani in Support of Motion for Pre-Judgment Order of Attachment Processed 08/07/2017 Moss, E.
Affirmation of Catherine Yang in Support of Motion for Pre-Judgment Order of Attachment Processed 08/07/2017 Moss, E.
Affirmation of Edward Moss in Support of Motion for Pre Judgment Order of Attachment Processed 08/07/2017 Moss, E.
(Article) Processed 08/07/2017 Moss, E.
Filing on Behalf of - Hon. Barry R. Ostrager Processed 08/11/2017 Court User
Letter from S. Sarnoff to Justice Ostrager re Proposed Sur-Reply to Defendants' Motion to Dismiss Processed 09/06/2017 Sarnoff, S.
Proposed Sur-Reply Memorandum In Opposition to Defendant's Motion to Dismiss Processed 09/06/2017 Sarnoff, S.
Filing on Behalf of - Rose Ann Magaldi, Law Clerk Processed 09/07/2017 Court User 102 DECISION + ORDER ON MOTION Processed 09/20/2017 Court User 103 DECISION + ORDER ON MOTION Processed 09/20/2017 Court User 104 NOTICE OF ENTRY Processed 09/22/2017 Schiller, J. 105 NOTICE OF ENTRY Processed 09/22/2017 Schiller, J. 106 TRANSCRIPT - SO ORDERED Processed 10/02/2017 Court User
Notice of Appeal Processed 10/18/2017 Sarnoff, S.
New York County Supreme Court 652077/2017
Doc# Document Type/Information Status Date Received Filed By
Decision and Order, Motion Sequence 001 Processed 10/18/2017 Sarnoff, S.
So-Ordered Transcript of Proceedings Processed 10/18/2017 Sarnoff, S.
Pre-Argument Statement Processed 10/18/2017 Sarnoff, S. 111 TRANSCRIPT - SO ORDERED Processed 10/26/2017 Court User
Notice of Entry of Decision and Order Processed 04/05/2018 Sarnoff, S.
Appellate Division, First Department Decision and Order of April 5, 2018 Processed 04/05/2018 Sarnoff, S. 114 NOTICE OF APPEARANCE (POST RJI) Processed 04/09/2018 Searles, J.
Extending Time to Answer Processed 04/09/2018 Searles, J.
Letter from E. Moss to Justice Ostrager re Motion for Pre-Judgment Order of Attachment Processed 04/10/2018 Moss, E.
Proposed Transcriber Affidavit in Support of Motion for Pre-Judgment Order of Attachment Processed 04/10/2018 Moss, E.
Proposed Translator Affidavit in Support of Motion for Pre-Judgment Order of Attachment Processed 04/10/2018 Moss, E.
Proposed Moss Affirmation in Support of Motion for Pre Judgment Order of Attachment Processed 04/10/2018 Moss, E.
Filing on Behalf of - Rose Ann Magaldi, Law Clerk Processed 04/11/2018 Court User 121 REMITTITUR Processed 04/11/2018 Court User
JUDGMENT ORDER OF ATTACHMENT Processed 04/24/2018 Sarnoff, S.
MEMORANDUM OF LAW IN SUPPORT OF PLAINTIFF PACIFIC ALLIANCE ASIA OPPORTUNITY FUND L.P.'S MOTION FOR P Processed 04/24/2018 Sarnoff, S. 124 AFFIDAVIT OR AFFIRMATION IN SUPPORT OF
PLAINTIFF PACIFIC ALLIANCE Processed 04/24/2018 Sarnoff, S.
2011 Facility Letter Processed 04/24/2018 Sarnoff, S.
Personal Guarantee Processed 04/24/2018 Sarnoff, S.
Original Deed of Settlement Processed 04/24/2018 Sarnoff, S.
New York County Supreme Court 652077/2017
Doc# Document Type/Information Status Date Received Filed By
Supplemental Deed of Settlement Processed 04/24/2018 Sarnoff, S.
Second Deed of Settlement Processed 04/24/2018 Sarnoff, S.
Third Deed of Settlement Processed 04/24/2018 Sarnoff, S.
Fourth Deed of Settlement Processed 04/24/2018 Sarnoff, S.
Option Agreement Processed 04/24/2018 Sarnoff, S.
Kwok Notice of Demand Processed 04/24/2018 Sarnoff, S.
Shiny Times Demand Letter Processed 04/24/2018 Sarnoff, S. 135 AFFIDAVIT OR AFFIRMATION IN SUPPORT OF
PLAINTIFF'S MOTION FOR PRE-JUDGMENT ORDER OF ATTACHMENT Processed 04/24/2018 Sarnoff, S. 136 AFFIDAVIT OR AFFIRMATION IN SUPPORT OF
JUDGMENT ORDER OF ATTACHM Processed 04/24/2018 Sarnoff, S. 137 AFFIDAVIT OR AFFIRMATION IN SUPPORT OF
PLAINTIFF'S MOTION FOR PRE-JUDGMENT ORDER OF ATTACHMENT Processed 04/24/2018 Sarnoff, S. 138 AFFIDAVIT OR AFFIRMATION IN SUPPORT OF
OPPORTUNITY FUND L.P.'S Processed 04/24/2018 Sarnoff, S. 139 AFFIDAVIT OR AFFIRMATION IN SUPPORT OF
SUPPORT OF PLAINTIFF PACIFIC ALLIANCE ASIA OPPORTUNITY FUND Processed 04/24/2018 Sarnoff, S. 140 AFFIDAVIT OR AFFIRMATION IN SUPPORT OF AFFIDAVIT OF NATHANIEL FRANCIS IN SUPPORT
OPPORTUNITY FUND L.P.'S Processed 04/24/2018 Sarnoff, S.
Corporate Formation Documents Processed 04/24/2018 Sarnoff, S.
BVI Court Order Processed 04/24/2018 Sarnoff, S.
News Article Processed 04/24/2018 Sarnoff, S.
Complaint Processed 04/24/2018 Sarnoff, S.
Utilities Payment Record Processed 04/24/2018 Sarnoff, S.
Photographs Processed 04/24/2018 Sarnoff, S.
New York County Supreme Court 652077/2017 Document List Index # of 65
New York County Supreme Court 652077/2017 Index #
Doc# Document Type/Information Status Date Received Filed By
Aug. 1, 2017 Schiller Affirmation with Exhibits (Dkt. #'s 67-74) Processed 05/16/2018 Searles, J.
April 26, 2017 NYT Article Processed 05/16/2018 Searles, J.
April 26, 2017 Quartz Media LLC Article Processed 05/16/2018 Searles, J.
June 9, 2017 CNBC Article Processed 05/16/2018 Searles, J.
May 30, 2017 NYT Article Processed 05/16/2018 Searles, J.
April 19, 2017 NYT Article Processed 05/16/2018 Searles, J.
September 29, 2017 Free Beacon Article Processed 05/16/2018 Searles, J.
October 22, 2017 WSJ Article Processed 05/16/2018 Searles, J.
October 23, 2017 CNBC Article Processed 05/16/2018 Searles, J.
July 22, 2017 Reuters Article Processed 05/16/2018 Searles, J.
April 9, 2018 Foley Hoag Letter Processed 05/16/2018 Searles, J.
March 21, 2018 NYT Article Processed 05/16/2018 Searles, J. 182 AFFIDAVIT OR AFFIRMATION IN OPPOSITION TO
Affidavit of Yan Ping Wang Processed 05/16/2018 Searles, J.
Genever Register of Members Processed 05/16/2018 Searles, J.
Genever Certificate of Registration of Charge Processed 05/16/2018 Searles, J.
Property Acceptance Confirmation Notes Processed 05/16/2018 Searles, J.
PLAINTIFF PACIFIC ALLIANCE ASIA OPPORTUNITY FUND L.P.S MOTION Processed 05/23/2018 Sarnoff, S.
PLAINTIFF PACIFIC ALLIANCE ASIA OPPORTUNITY FUND L.P.'S MOTION Processed 05/23/2018 Sarnoff, S.
May 21, 2015 UCC-1 Report Processed 05/23/2018 Sarnoff, S.
March 29, 2017 UCC-1 Report Processed 05/23/2018 Sarnoff, S.
Complaint Wengui v. Wu Processed 05/23/2018 Sarnoff, S.
New York County Supreme Court 652077/2017 Index #
Doc# Document Type/Information Status Date Received Filed By
Filing on Behalf of - Hon. Barry R. Ostrager Processed 05/29/2018 Court User 192 DECISION + ORDER ON MOTION Processed 06/29/2018 Court User 193 NOTICE OF ENTRY Processed 07/09/2018 Searles, J. 194 ORDER - PRELIMINARY CONFERENCE Processed 07/10/2018 Court User
Letter from E. Moss to Justice Ostrager re Stipulation and Proposed Order for Production and Exchang Processed 07/10/2018 Moss, E.
Stipulation and Proposed Order for Production and Exchange of Confidential Information (PROPOSED) Processed 07/10/2018 Moss, E.
Stipulation and Proposed Order for Production and Exchange of Confidential Information (REDLINE) Processed 07/10/2018 Moss, E. 198 STIPULATION - SO ORDERED Processed 07/11/2018 Court User 199 TRANSCRIPT - SO ORDERED Processed 08/29/2018 Court User 200 LETTER / CORRESPONDENCE TO JUDGE Processed 09/11/2018 Moss, E. 201 STIPULATION - SO ORDERED Processed 10/10/2018 Court User 202 STIPULATION - OTHER - ( REQUEST TO SO ORDER ) Stipulation re Request Extension to Commercial Division Rule 17 Word Limits Processed 11/09/2018 Moss, E. 203 STIPULATION - SO ORDERED Processed 11/13/2018 Court User 204 STIPULATION - SO ORDERED Processed 11/14/2018 Court User
Notice of Plaintiff's Renewed Motion for Pre-Judgment Order Of Attachment Processed 11/19/2018 Moss, E.
Plaintiff Pacific Alliance Asia Opportunity Fund L.P.s Memorandum of Law in Support of its Motion fo Processed 11/15/2018 Moss, E.
Affirmation of Edward Moss, Esq. In Support of Plaintiff Pacific Alliance Asia Opportunity Fund L.P. Processed 11/15/2018 Moss, E.
June 28, 2018 Decision and Order Processed 11/15/2018 Moss, E.
April 24, 2018 Memorandum of Law in Support Processed 11/15/2018 Moss, E.
January 30, 2018 Complaint Processed 11/15/2018 Moss, E.
October 3, 2018 Deposition Transcript Excerpts (REDACTED - Partially Under Seal) Processed 11/15/2018 Moss, E.
New York County Supreme Court 652077/2017
Doc# Document Type/Information Status Date Received Filed By
March 4, 2015 Letter (FILED UNDER SEAL) Processed 11/15/2018 Moss, E.
May 15, 2018 Affidavit with Exhibits Processed 11/15/2018 Moss, E.
September 24, 2018 Deposition Transcript Excerpts (REDACTED - Partially Under Seal) Processed 11/15/2018 Moss, E.
March 4, 2015 Letter (FILED UNDER SEAL) Processed 11/15/2018 Moss, E.
February 27, 2015 Letter (FILED UNDER SEAL) Processed 11/15/2018 Moss, E.
April 7, 2017 Answer to Complaint Processed 11/15/2018 Moss, E.
March 3, 2015 email with attachment (FILED UNDER SEAL) Processed 11/15/2018 Moss, E.
August 3, 2018 Responses and Objections to Subpoena Processed 11/15/2018 Moss, E.
March 4, 2015 Debit Advice Statement (FILED UNDER SEAL) Processed 11/15/2018 Moss, E.
May 21, 2015 Certificate of Registration of Charge Processed 11/15/2018 Moss, E.
May 21, 2015 UCC Financing Statement Processed 11/15/2018 Moss, E.
October 7, 2015 realtor.com article Processed 11/15/2018 Moss, E.
May 12, 2017 email (FILED UNDER SEAL) Processed 11/15/2018 Moss, E.
June 16, 2016 TheRealDeal.com article Processed 11/15/2018 Moss, E.
June 29, 2016 email chain (FILED UNDER SEAL) Processed 11/15/2018 Moss, E.
May 21, 2015 Notice of Satisfaction or Release of Registered Charge Processed 11/15/2018 Moss, E.
March 29, 2017 UCC Financing Statement Amendment Processed 11/15/2018 Moss, E.
May 23, 2018 Reply Memorandum of Law Processed 11/15/2018 Moss, E.
June 2017 email chain (FILED UNDER SEAL) Processed 11/15/2018 Moss, E.
June 27, 2018 Hearing Pledge Documents Processed 11/15/2018 Moss, E.
May 18, 2018 TheRealDeal.com article Processed 11/15/2018 Moss, E.
April 10, 2018 Letter Processed 11/15/2018 Moss, E.
New York County Supreme Court 652077/2017
Doc# Document Type/Information Status Date Received Filed By
October 9, 2018 email (FILED UNDER SEAL) Processed 11/15/2018 Moss, E.
October 11, 2018 Deposition Transcript Excerpts (REDACTED - Partially Under Seal) Processed 11/15/2018 Moss, E.
March 6, 2015 Proprietary Lease (FILED UNDER SEAL) Processed 11/15/2018 Moss, E.
August 17, 2018 letter (FILED UNDER SEAL) Processed 11/15/2018 Moss, E.
May 16, 2018 Memorandum of Law in Opposition Processed 11/15/2018 Moss, E.
June 27, 2018 Hearing Transcript Processed 11/15/2018 Moss, E.
February 14, 2018 Notice of Satisfaction or Release of Registered Charge Processed 11/15/2018 Moss, E.
November 10, 2016 email chain (FILED UNDER SEAL) Processed 11/15/2018 Moss, E.
March 12, 2008 Amended Facility Letter Processed 11/15/2018 Moss, E.
August 3, 2018 Responses and Objections to Plaintiffs Second Set of Requests for the Production of D Processed 11/15/2018 Moss, E.
June 18, 2018 email (FILED UNDER SEAL) Processed 11/15/2018 Moss, E.
September 28, 2018 email chain Processed 11/15/2018 Moss, E.
July 30, 2018 Responses and Objections to Plaintiffs Amended First Set of Interrogatories Processed 11/15/2018 Moss, E.
November 14, 2018 TheRealDeal.com article Processed 11/15/2018 Moss, E.
November 9, 2018 Stipulation Processed 11/15/2018 Moss, E.
Letter from Eddie Moss to Justice Ostrager re Filing Under Seal Processed 11/15/2018 Moss, E.
Memorandum of Law in Support of Plaintiff Pacific Alliance Asia Opportunity Fund L.P.'s Motion for P Processed 11/28/2018 Moss, E.
October 3, 2018 Deposition Transcript Excerpts - Dkt. No. 211 Processed 11/28/2018 Moss, E.
March 4, 2015 Letter - Dkt. No. 212 Processed 11/28/2018 Moss, E.
September 24, 2018 Deposition Transcript Excerpts - Dkt. No. 214 Processed 11/28/2018 Moss, E.
March 4, 2015 Letter - Dkt. No. 215 Processed 11/28/2018 Moss, E.
New York County Supreme Court 652077/2017
Doc# Document Type/Information Status Date Received Filed By
February 27, 2015 Letter - Dkt. No. 216 Processed 11/28/2018 Moss, E.
March 3, 2015 email with attachment - Dkt. No. 218 Processed 11/28/2018 Moss, E.
March 4, 2015 Debit Advice Statement - Dkt. No. 220 Processed 11/28/2018 Moss, E.
May 12, 2017 email - Dkt. No. 224 Processed 11/28/2018 Moss, E.
June 29, 2016 email chain - Dkt. No. 226 Processed 11/28/2018 Moss, E.
June 2017 email chain - Dkt. No. 230 Processed 11/28/2018 Moss, E.
October 9, 2018 email - Dkt. No. 234 Processed 11/28/2018 Moss, E.
October 11, 2018 Deposition Transcript Excerpts - Dkt. No. 235 Processed 11/28/2018 Moss, E.
March 6, 2015 Proprietary Lease - Dkt. No. 236 Processed 11/28/2018 Moss, E.
August 17, 2018 letter - Dkt. No. 237 Processed 11/28/2018 Moss, E.
November 10, 2016 email chain - Dkt. No. 241 Processed 11/28/2018 Moss, E.
June 18, 2018 email - Dkt. No. 244 Processed 11/28/2018 Moss, E. 267 STIPULATION - ADJOURNMENT OF MOTION -IN SUBMISSIONS PART -RM 130 Processed 12/07/2018 Searles, J. 268 MEMORANDUM OF LAW IN OPPOSITION Processed 12/14/2018 Searles, J. 269 AFFIDAVIT OR AFFIRMATION IN OPPOSITION TO MOTION Processed 12/14/2018 Searles, J.
09.24.18 - Ullman Deposition Transcript Excerpts Processed 12/14/2018 Searles, J.
07.30.18 Letter from the Sherry-Netherland Processed 12/14/2018 Searles, J.
Reply Memorandum Of Law In Support of Plaintiff's Motion for Pre-Judgment Order Of Attachment Processed 01/18/2019 Moss, E.
Affirmation Of David Lukmire, Esq. In Support Processed 01/18/2019 Moss, E.
Preliminary Conference Order Processed 01/18/2019 Moss, E.
Decision And Order Processed 01/18/2019 Moss, E.
Article Processed 01/18/2019 Moss, E.
New York County Supreme Court 652077/2017
Doc# Document Type/Information Status Date Received Filed By
Filing on Behalf of - Hon. Barry R. Ostrager Processed 01/23/2019 Court User
Filing on Behalf of - Hon. Barry R. Ostrager Processed 02/07/2019 Court User
Filing on Behalf of - Zack Goldberg - Law Clerk for Justice Ostrager Processed 03/08/2019 Court User
Filing on Behalf of - Hon. Barry R. Ostrager Processed 03/14/2019 Court User
Transcript Of Proceedings of March 8, 2019 Processed 03/21/2019 Moss, E.
AMEND THE COMPLAINT Processed 04/02/2019 Moss, E.
OF ITS MOTION FOR LEAVE TO AMEND THE Processed 04/02/2019 Moss, E. 284 AFFIDAVIT OR AFFIRMATION IN SUPPORT OF
SUPPORT OF PLAINTIFF PACIFIC ALLIANCE ASIA OPPORTUNITY FUND L.P. Processed 04/02/2019 Moss, E.
Summonses and Proposed First Amended Complaint Processed 04/02/2019 Moss, E.
Blackline Comparison Processed 04/02/2019 Moss, E.
Summons Processed 04/02/2019 Moss, E.
Decision and Order Processed 04/02/2019 Moss, E.
Corporate Documents Processed 04/02/2019 Moss, E.
Brief Processed 04/02/2019 Moss, E.
Deposition Transcript Processed 04/02/2019 Moss, E.
Financial Documents Processed 04/02/2019 Moss, E.
Deposition Transcript Processed 04/02/2019 Moss, E.
Financial Document Processed 04/02/2019 Moss, E.
Affidavit Processed 04/02/2019 Moss, E.
Certificate of Registration of Charge Processed 04/02/2019 Moss, E.
UCC Financing Statement Processed 04/02/2019 Moss, E.
E-mail Chain Processed 04/02/2019 Moss, E.
New York County Supreme Court 652077/2017
Doc# Document Type/Information Status Date Received Filed By
Financial Documents Processed 04/02/2019 Moss, E.
Pledge Document Processed 04/02/2019 Moss, E.
Deposition Transcript Processed 04/02/2019 Moss, E.
Letter Processed 04/02/2019 Moss, E.
Hearing Transcript Processed 04/02/2019 Moss, E.
Certificate of Registration of Charge Processed 04/02/2019 Moss, E.
UCC Financing Statement Processed 04/02/2019 Moss, E. 306 STIPULATION - SO ORDERED Processed 04/03/2019 Court User
Letter from E. Moss to Justice Ostrager re Extension of Pre-Hearing Submissions Deadline to April 19 Processed 04/05/2019 Moss, E. 308 STIPULATION - OTHER Processed 04/17/2019 Moss, E.
First Amended Complaint Processed 04/18/2019 Moss, E.
Personal Guarantee Processed 04/18/2019 Moss, E.
Loan Facility Processed 04/18/2019 Moss, E.
Amended Loan Facility Processed 04/18/2019 Moss, E.
Settlement Deed Processed 04/18/2019 Moss, E.
Personal Guarantee Processed 04/18/2019 Moss, E.
Loan Facility Letter Processed 04/18/2019 Moss, E.
Deed of Settlement Processed 04/18/2019 Moss, E.
Settlement Extension Processed 04/18/2019 Moss, E.
Settlement Extension Processed 04/18/2019 Moss, E.
Settlement Extension Processed 04/18/2019 Moss, E.
Settlement Extension Processed 04/18/2019 Moss, E.
Option Agreement Processed 04/18/2019 Moss, E.
Genever Holdings Corporation Amended Summons Processed 04/18/2019 Moss, E.
New York County Supreme Court 652077/2017
Doc# Document Type/Information Status Date Received Filed By
Genever Holdings LLC Amended Summons Processed 04/18/2019 Moss, E. 324 NOTICE OF CHANGE OF ATTORNEY (POST RJI) Notice of Withdrawal of Appearance of David Lukmire Processed 04/18/2019 Moss, E.
Letter to J. Ostrager Re Pre-Hearing Materials Processed 04/19/2019 Moss, E.
Exhibit List Processed 04/19/2019 Moss, E.
Depo Designations (Kwok) Processed 04/19/2019 Moss, E.
Depo Designations (Horvitz) Processed 04/19/2019 Moss, E. 329 DECISION + ORDER ON MOTION Processed 04/24/2019 Court User 330 DECISION + ORDER ON MOTION Processed 04/30/2019 Court User 331 TRANSCRIPT - SO ORDERED Processed 05/08/2019 Court User 332 ANSWER Processed 05/24/2019 Searles, J. 333 STIPULATION - SO ORDERED Processed 06/04/2019 Court User 334 NOTICE OF CHANGE OF ATTORNEY (POST RJI) Notice of Withdrawal of Appearance of Garabed Hoplamazian Processed 06/13/2019 Hoplamazian, G. 335 COURT NOTICE Processed 09/10/2019 Court User 336 STIPULATION - SO ORDERED Processed 09/10/2019 Court User 337 STIPULATION - DISCOVERY ( REQUEST TO SO Processed 11/01/2019 Searles, J. 338 CONSENT TO CHANGE ATTORNEY (POST RJI) Consent to Change attorney Processed 11/19/2019 Mitchell, A. 339 STIPULATION - ADJOURNMENT OF CONFERENCE Joint Stipulation to Adjourn Status Conference Processed 12/05/2019 Moss, E.
Filing on Behalf of - Rose Ann Magaldi, Law Clerk Processed 12/06/2019 Court User
Joint Letter to Justice Ostrager re: Court's December 6, 2019 Notice Processed 12/11/2019 Moss, E. 342 ORDER - OTHER Processed 01/22/2020 Court User
Notice of Plaintiff's Motion for Costs and Sanctions Processed 03/03/2020 Moss, E.
Memorandum of Law in Support of Plaintiff Pacific Alliance Asia Opportunity Fund L.P.'s Motion for C Processed 03/03/2020 Moss, E. 345 AFFIDAVIT OR AFFIRMATION IN SUPPORT OF Affirmation of Edward Moss in Support of Plaintiff Pacific Processed 03/03/2020 Moss, E.
New York County Supreme Court 652077/2017
Doc# Document Type/Information Status Date Received Filed By
Alliance Asia Opportunity Fund L.P.'S Mot
Horvitz Deposition Transcript Processed 03/03/2020 Moss, E.
Responses to Requests for Admission Processed 03/03/2020 Moss, E.
Sarnoff Letter Processed 03/03/2020 Moss, E.
Harmon Letter Processed 03/03/2020 Moss, E.
Kwok Day 1 Deposition Transcript Processed 03/03/2020 Moss, E.
Kwok Day 2 Deposition Transcript Processed 03/03/2020 Moss, E.
Stevenson Wong email Processed 03/03/2020 Moss, E.
Stevenson Wong email Processed 03/03/2020 Moss, E.
Stevenson Wong email Processed 03/03/2020 Moss, E.
Stevenson Wong email Processed 03/03/2020 Moss, E.
Stevenson Wong email Processed 03/03/2020 Moss, E.
Stevenson Wong email Processed 03/03/2020 Moss, E.
Stevenson Wong email Processed 03/03/2020 Moss, E.
Stevenson Wong email Processed 03/03/2020 Moss, E.
Stevenson Wong email Processed 03/03/2020 Moss, E.
Letter of Reference Processed 03/03/2020 Moss, E.
Searles Email Processed 03/03/2020 Moss, E.
Kwok Production Processed 03/03/2020 Moss, E.
Attorneys Fees Chart Processed 03/03/2020 Moss, E. 365 STIPULATION - ADJOURNMENT OF MOTION -IN SUBMISSIONS PART -RM 130 Processed 03/12/2020 Searles, J. 366 URGENT - COURT APPEARANCE UPDATE Processed 03/20/2020 Court User
Filing on Behalf of - Rose Ann Magaldi, Law Clerk Processed 05/18/2020 Court User 368 ORDER - STATUS CONFERENCE Processed 05/27/2020 Court User
New York County Supreme Court 652077/2017
Doc# Document Type/Information Status Date Received Filed By
369 STIPULATION - OTHER - ( REQUEST TO SO ORDER ) Stipulation and [Proposed] Order Processed 05/29/2020 Moss, E. 370 AFFIDAVIT OR AFFIRMATION IN OPPOSITION TO MOTION Processed 05/29/2020 Searles, J.
July 2010 PAX Email with Attachment Processed 05/29/2020 Searles, J.
November 2011 PAX Email with Attachment Processed 05/29/2020 Searles, J.
September 2011 Project Pangu Appendix Processed 05/29/2020 Searles, J.
November 25, 2019 Kwok Deposition Excerpts Processed 05/29/2020 Searles, J.
December 11, 2019 Kwok Deposition Excerpts Processed 05/29/2020 Searles, J.
September 2015 PAX Email with Attachment Processed 05/29/2020 Searles, J.
PACL Board of Directors Package Processed 05/29/2020 Searles, J.
June 2011 PAX Email Exchange Processed 05/29/2020 Searles, J.
September 2010 PAX Valuation Committee Minutes Processed 05/29/2020 Searles, J.
August 2010 PAX Email with Attachment Processed 05/29/2020 Searles, J.
October 2012 PAX Email Exchange Processed 05/29/2020 Searles, J.
July 2015 PAX Email Exchange Processed 05/29/2020 Searles, J.
August 2015 PAX Email Processed 05/29/2020 Searles, J.
June - August 2015 PAX Email Exchange Processed 05/29/2020 Searles, J.
January 15, 2020 Crane Deposition Excerpts Processed 05/29/2020 Searles, J.
May 25, 2018 Hodgson Russ Discovery Letter Processed 05/29/2020 Searles, J.
May 30, 2018 O'Melveny Discovery Letter Processed 05/29/2020 Searles, J.
June 7, 2018 Email Exchange Between Counsel Processed 05/29/2020 Searles, J.
July 6, 2018 Email from O'Melveny Processed 05/29/2020 Searles, J. 390 MEMORANDUM OF LAW IN OPPOSITION Processed 05/29/2020 Searles, J. 391 STIPULATION - ADJOURNMENT OF MOTION -IN SUBMISSIONS PART -RM 130 Processed 06/08/2020 Court User
New York County Supreme Court 652077/2017
Doc# Document Type/Information Status Date Received Filed By
Reply Memorandum of Law in Further Support of Plaintiff Pacific Alliance Asia Opportunity Fund L.P.S Processed 06/17/2020 Moss, E.
Affirmation of Edward Moss in Support of Plaintiff Pacific Alliance Asia Opportunity Fund L.P.s Moti Processed 06/17/2020 Moss, E.
Searles_Email Processed 06/17/2020 Moss, E.
KWOK000898 - 935 - March 12, 2008 Investment Agreement Processed 06/17/2020 Moss, E.
2009-09-16 PAX-KWOK-073294_Financial Document Processed 06/17/2020 Moss, E.
2009-09-17 PAX-KWOK-073297_Financial Document Processed 06/17/2020 Moss, E.
2009-11-03 PAX-KWOK-073293_Financial Document Processed 06/17/2020 Moss, E.
2009-11-10 PAX-KWOK-073295_Financial Document Processed 06/17/2020 Moss, E.
Feb 4 2008 Personal Guarantee Processed 06/17/2020 Moss, E. 401 COURT NOTICE Processed 06/23/2020 Court User 402 COURT NOTICE Processed 07/01/2020 Court User
Note of Issue and Certificate of Readiness for Trial Processed 07/03/2020 Moss, E. 404 DECISION + ORDER ON MOTION Processed 07/07/2020 Court User 405 STIPULATION - OTHER - ( REQUEST TO SO ORDER ) Stipulation and (Proposed) Order re: Summary Judgment Scheduling Processed 07/14/2020 Moss, E. 406 TRANSCRIPT - SO ORDERED Processed 07/20/2020 Court User
Filing on Behalf of - Rose Ann Magaldi, Law Clerk Processed 07/22/2020 Court User
Notice of Motion re: Plaintiff Pacific Alliance Asia Opportunity Fund L.P.s Motion for Partial Summa Processed 07/24/2020 Moss, E.
Memorandum of Law in Support of Plaintiff Pacific Alliance Asia Opportunity Fund L.P.s Motion for Pa Processed 07/24/2020 Moss, E.
Statement of Material Fact in Support of Plaintiff Pacific Alliance Asia Opportunity Fund L.P.s Moti Processed 07/24/2020 Moss, E. 411 AFFIDAVIT OR AFFIRMATION IN SUPPORT OF Notice of Intent to Request Judicial Notice of Foreign Law Processed 07/24/2020 Moss, E.
Affirmation of Vishal Melwani Processed 07/24/2020 Moss, E.
New York County Supreme Court 652077/2017
Doc# Document Type/Information Status Date Received Filed By
CV of Vishal Melwani Processed 07/24/2020 Moss, E.
Hong Kong case law Processed 07/24/2020 Moss, E.
Hong Kong case law Processed 07/24/2020 Moss, E.
Hong Kong case law Processed 07/24/2020 Moss, E.
Hong Kong case law Processed 07/24/2020 Moss, E.
Hong Kong case law Processed 07/24/2020 Moss, E.
Hong Kong case law Processed 07/24/2020 Moss, E.
Hong Kong case law Processed 07/24/2020 Moss, E.
Hong Kong case law Processed 07/24/2020 Moss, E.
Hong Kong case law Processed 07/24/2020 Moss, E.
Hong Kong case law Processed 07/24/2020 Moss, E.
Hong Kong case law Processed 07/24/2020 Moss, E.
Hong Kong case law Processed 07/24/2020 Moss, E.
Hong Kong law treatise Processed 07/24/2020 Moss, E.
Hong Kong case law Processed 07/24/2020 Moss, E.
Hong Kong case law Processed 07/24/2020 Moss, E.
Hong Kong case law Processed 07/24/2020 Moss, E.
Hong Kong case law Processed 07/24/2020 Moss, E.
Hong Kong case law Processed 07/24/2020 Moss, E. 432 AFFIDAVIT OR AFFIRMATION IN SUPPORT OF Affirmation of Edward Moss in Support of Plaintiff Pacific Alliance Asia Opportunity Fund L.P.s Moti Processed 07/24/2020 Moss, E.
Feb. 4, 2008 Loan Facility Processed 07/24/2020 Moss, E.
Requests for Admission Processed 07/24/2020 Moss, E.
Deposition Transcript Excerpts Processed 07/24/2020 Moss, E.
Deposition Transcript Excerpts Processed 07/24/2020 Moss, E.
New York County Supreme Court 652077/2017 Index #
Doc# Document Type/Information Status Date Received Filed By
Feb. 4, 2008 Personal Guarantee Processed 07/24/2020 Moss, E.
March 12, 2008 Investment Agreement Processed 07/24/2020 Moss, E.
Sept. 17, 2009 Deed of Settlement Processed 07/24/2020 Moss, E.
Letter Processed 07/24/2020 Moss, E.
Deposition Transcript Excerpts Processed 07/24/2020 Moss, E.
Deposition Transcript Excerpts Processed 07/24/2020 Moss, E.
Deposition Transcript Excerpts Processed 07/24/2020 Moss, E.
Standard Chartered Bank Account Statement Processed 07/24/2020 Moss, E.
Feb. 4, 2008 Notice of Drawing Processed 07/24/2020 Moss, E.
March 12, 2008 Amended Loan Facility Processed 07/24/2020 Moss, E.
Deposition Transcript Processed 07/24/2020 Moss, E.
Standard Chartered Bank Account Record Processed 07/24/2020 Moss, E.
Standard Chartered Bank Account Record Processed 07/24/2020 Moss, E.
Nov. 18, 2009 Personal Guarantee Processed 07/24/2020 Moss, E.
March 12, 2010 Extension Letter Processed 07/24/2020 Moss, E.
Letter Processed 07/24/2020 Moss, E.
March 16, 2011 Loan Facility Processed 07/24/2020 Moss, E.
Financial Document Processed 07/24/2020 Moss, E.
March 16, 2011 Personal Guarantee Processed 07/24/2020 Moss, E.
E-mail correspondence Processed 07/24/2020 Moss, E.
Letter Processed 07/24/2020 Moss, E.
April 25, 2012 Deed of Settlement Processed 07/24/2020 Moss, E.
E-mail correspondence Processed 07/24/2020 Moss, E.
Pleadings Processed 07/24/2020 Moss, E.
Case 22-50073 Doc 1604-47 Filed 03/27/23 Entered 03/27/23 14:12:10 Page 48
New York County Supreme Court 652077/2017
Doc# Document Type/Information Status Date Received Filed By
April 19, 2013 Deed of Settlement Processed 07/24/2020 Moss, E.
Expert Report of Shitong Qiao with Exhibits Processed 07/24/2020 Moss, E.
E-mail correspondence Processed 07/24/2020 Moss, E.
E-mail correspondence Processed 07/24/2020 Moss, E.
E-mail correspondence Processed 07/24/2020 Moss, E.
E-mail correspondence Processed 07/24/2020 Moss, E.
E-mail correspondence Processed 07/24/2020 Moss, E.
E-mail correspondence Processed 07/24/2020 Moss, E.
Dec. 13, 2013 Suppl. Deed of Settlement Processed 07/24/2020 Moss, E.
May 15, 2014 Suppl. Deed of Settlement Processed 07/24/2020 Moss, E.
July 11, 2014 Suppl. Deed of Settlement Processed 07/24/2020 Moss, E.
Feb. 10, 2015 Suppl. Deed of Settlement Processed 07/24/2020 Moss, E.
Purchase Agreement Processed 07/24/2020 Moss, E.
Purchase Agreement Processed 07/24/2020 Moss, E.
Purchase Agreement Processed 07/24/2020 Moss, E.
Delivery Notice Processed 07/24/2020 Moss, E.
Delivery Notice Processed 07/24/2020 Moss, E.
Delivery Notice Processed 07/24/2020 Moss, E.
Property Acceptance Confirmation Notes Processed 07/24/2020 Moss, E.
Affirmation of Catherine Yang in Support of PAX LPs Motion for Pre-Judgment Order of Attachment Processed 07/24/2020 Moss, E.
Translation of Exhibit C to Expert Report of Shitong Qiao Processed 07/24/2020 Moss, E.
Complaint in Wengui v. Wu (S.D.N.Y.) Processed 07/24/2020 Moss, E.
Defendant Kwoks Memorandum of Law in Opposition to PAX LPs Motion for Pre-Judgment Order of Attachme Processed 07/24/2020 Moss, E.
New York County Supreme Court 652077/2017
Doc# Document Type/Information Status Date Received Filed By
Deposition Transcript Excerpts Processed 07/24/2020 Moss, E.
Notice of Demand to Defendant Kwok Processed 07/24/2020 Moss, E.
Demand Letter to Shiny Times Holdings Ltd. Processed 07/24/2020 Moss, E.
Affirmation of PAX LP in Support of PAX LPs Motion for Pre-Judgment Order of Attachment Processed 07/24/2020 Moss, E.
Email correspondence Processed 07/24/2020 Moss, E.
Email correspondence Processed 07/24/2020 Moss, E.
Affirmation of Fiona Yu Processed 07/24/2020 Moss, E.
Decision and Order on Motion Seq. No. 6 Processed 07/24/2020 Moss, E.
Affidavit of Jon Lewis in Support of Plaintiff Pacific Alliance Asia Opportunity Fund L.P.s Motion f Processed 07/24/2020 Moss, E.
Kwoks Brief in Opposition to Sanctions Motion (Mot. Seq. No. 6) Processed 07/24/2020 Moss, E. 494 NOTICE OF CROSS-MOTION Processed 08/17/2020 Searles, J. 495 MEMORANDUM IN OPPOSITION TO MOTION AND IN SUPPORT OF CROSS-MOTION Processed 08/17/2020 Searles, J. 496 STATEMENT OF MATERIAL FACTS Processed 08/17/2020 Searles, J. 497 AFFIDAVIT OR AFFIRMATION IN OPPOSITION TO
Notice of Intent to Request Judicial Notice of Foreign Law Processed 08/17/2020 Searles, J.
Affirmation of Phillip Loukis Georgiou Processed 08/17/2020 Searles, J.
CV of Phillip Loukis Georgiou Processed 08/17/2020 Searles, J.
Hong Kong Legal Treatise Processed 08/17/2020 Searles, J.
Hong Kong Case Law Processed 08/17/2020 Searles, J.
Hong Kong Case Law Processed 08/17/2020 Searles, J.
Hong Kong Case Law Processed 08/17/2020 Searles, J.
Hong Kong Case Law Processed 08/17/2020 Searles, J.
New York County Supreme Court 652077/2017
Doc# Document Type/Information Status Date Received Filed By
Hong Kong Legal Treatise Processed 08/17/2020 Searles, J.
Hong Kong Case Law Processed 08/17/2020 Searles, J.
Hong Kong Case Law Processed 08/17/2020 Searles, J.
Hong Kong Case Law Processed 08/17/2020 Searles, J.
Hong Kong Case Law Processed 08/17/2020 Searles, J. 510 AFFIDAVIT OR AFFIRMATION IN OPPOSITION TO MOTION AND IN SUPPORT OF CROSS-MOTION Processed 08/17/2020 Searles, J.
July 2010 PAX Email with Attachment Processed 08/17/2020 Searles, J.
November 2011 Email with Attachment Processed 08/17/2020 Searles, J.
September 2011 Project Pangu Appendix Processed 08/17/2020 Searles, J.
September 2015 PAX Email with Attachment Processed 08/17/2020 Searles, J.
PACL Board of Directors Package Processed 08/17/2020 Searles, J.
June 2011 PAX Email Exchange Processed 08/17/2020 Searles, J.
September 2010 PAX Valuation Committee Minutes Processed 08/17/2020 Searles, J.
August 2010 PAX Email with Attachment Processed 08/17/2020 Searles, J.
July 2015 PAX Email Exchange Processed 08/17/2020 Searles, J.
August 2015 PAX Email Processed 08/17/2020 Searles, J.
June - August 2015 PAX Email Exchange Processed 08/17/2020 Searles, J.
January 15, 2020 Crane Deposition Excerpts Processed 08/17/2020 Searles, J.
November 21, 2019 Lewis Deposition Excerpts Processed 08/17/2020 Searles, J.
November 6, 2019 Yang Deposition Excerpts Processed 08/17/2020 Searles, J.
June 25, 2020 Qiao Deposition Excerpts Processed 08/17/2020 Searles, J.
November 25, 2019 Kwok Deposition Excerpts Processed 08/17/2020 Searles, J.
May 30, 2018 O'Melveny Discovery Letter Processed 08/17/2020 Searles, J.
July 7, 2020 Decision and Order Processed 08/17/2020 Searles, J.
New York County Supreme Court 652077/2017
Doc# Document Type/Information Status Date Received Filed By
Reply Memorandum of Law in Further Support of Plaintiff Pacific Alliance Asia Opportunity Fund L.P.' Processed 08/28/2020 Moss, E. 530 RESPONSE TO STATEMENT OF MATERIAL FACTS PAX's Reply to Kwok's Counterstatement of Material Facts Processed 08/28/2020 Moss, E.
Affirmation of Edward Moss in Support of Plaintiff Pacific Alliance Asia Opportunity Fund L.P.'s Rep Processed 08/28/2020 Moss, E.
Lewis Deposition Excerpts Processed 08/28/2020 Moss, E.
Crane Deposition Excerpts Processed 08/28/2020 Moss, E.
PAX email Processed 08/28/2020 Moss, E.
Supplemental Affirmation of Vishal Prakash Melwani in Support of Plaintiff Pacific Alliance Asia Opp Processed 08/28/2020 Moss, E.
Hong Kong case law Processed 08/28/2020 Moss, E.
Hong Kong case law Processed 08/28/2020 Moss, E.
Hong Kong case law Processed 08/28/2020 Moss, E.
Hong Kong case law Processed 08/28/2020 Moss, E.
Hong Kong case law Processed 08/28/2020 Moss, E.
Hong Kong case law Processed 08/28/2020 Moss, E.
Hong Kong case law Processed 08/28/2020 Moss, E.
Hong Kong case law Processed 08/28/2020 Moss, E.
Hong Kong case law Processed 08/28/2020 Moss, E.
Hong Kong case law Processed 08/28/2020 Moss, E.
Hong Kong case law Processed 08/28/2020 Moss, E.
Hong Kong case law Processed 08/28/2020 Moss, E. 548 COURT NOTICE Processed 08/31/2020 Court User 549 DECISION + ORDER ON MOTION Processed 09/15/2020 Court User
Notice of Entry of Justice Ostrager's Decision and Order on Motion Sequence 007 Processed 09/16/2020 Moss, E.
New York County Supreme Court 652077/2017
Doc# Document Type/Information Status Date Received Filed By
Order to Show Cause Processed 09/21/2020 Moss, E.
Memorandum of Law in Support of Plaintiff Pacific Alliance Asia Opportunity Fund L.P.'s CPLR 5229 Mo Processed 09/21/2020 Moss, E. 553 AFFIDAVIT OR AFFIRMATION IN SUPPORT OF
Affirmation of Edward Moss in Support of Plaintiff's CPLR 5229 Motion by Order to Show Cause Processed 09/21/2020 Moss, E.
Deposition Transcript Excerpts Processed 09/21/2020 Moss, E.
Deposition Transcript Excerpts Processed 09/21/2020 Moss, E.
Petition Processed 09/21/2020 Moss, E.
Order Processed 09/21/2020 Moss, E.
Listing Processed 09/21/2020 Moss, E.
Complaint Processed 09/21/2020 Moss, E.
Listing Processed 09/21/2020 Moss, E.
Notice of Motion to Establish Damages, Legal Fees, and Expenses Processed 09/21/2020 Moss, E.
Memorandum of Law in Support of Plaintiff Pacific Alliance Asia Opportunity Fund L.P.'s Motion to Es Processed 09/21/2020 Moss, E. 563 AFFIDAVIT OR AFFIRMATION IN SUPPORT OF Affirmation of Jon Lewis Processed 09/21/2020 Moss, E.
Chart Processed 09/21/2020 Moss, E.
Invoices Processed 09/21/2020 Moss, E.
Complaint Processed 09/21/2020 Moss, E. 567 ORDER TO SHOW CAUSE Processed 09/22/2020 Court User
Invoices (corrected) Processed 09/22/2020 Moss, E.
Order to Show Cause Processed 09/23/2020 Moss, E.
Memorandum of Law in Support of Plaintiff Pacific Alliance Asia Opportunity Fund L.P.'s Unopposed Mo Processed 09/23/2020 Moss, E. 571 AFFIDAVIT OR AFFIRMATION IN SUPPORT OF
Affirmation of Edward Moss in Support of Plaintiff's Unopposed Motion to Seal Processed 09/23/2020 Moss, E.
New York County Supreme Court 652077/2017 Document List Index # of 65
Doc# Document Type/Information Status Date Received Filed By
Letter to Justice Ostrager regarding Plaintiff's Order to Show Cause for an Order and Discovery Unde Processed 09/24/2020 Moss, E.
Filing on Behalf of - Rose Ann Magaldi, Law Clerk Processed 09/24/2020 Court User 574 NOTICE OF WITHDRAWAL OF MOTION / ORDER TO
Notice of Withdrawal of Order to Show Cause Processed 09/25/2020 Moss, E.
Order to Show Cause Processed 09/25/2020 Moss, E.
Memorandum of Law in Support of Plaintiff Pacific Alliance Asia Opportunity Fund L.P.'s CPLR 5229 Mo Processed 09/25/2020 Moss, E. 577 AFFIDAVIT OR AFFIRMATION IN SUPPORT OF
Affirmation of Jon Lewis Processed 09/25/2020 Moss, E. 578 AFFIDAVIT OR AFFIRMATION IN SUPPORT OF
Affirmation of Edward Moss in Support of Plaintiff's Order to Show Cause Processed 09/25/2020 Moss, E.
Deposition Transcript Excerpts Processed 09/25/2020 Moss, E.
Deposition Transcript Excerpts Processed 09/25/2020 Moss, E.
Petition Processed 09/25/2020 Moss, E.
Order Processed 09/25/2020 Moss, E.
Listing Processed 09/25/2020 Moss, E.
Complaint Processed 09/25/2020 Moss, E.
Listing Processed 09/25/2020 Moss, E. 586 DECISION + ORDER ON MOTION Processed 09/26/2020 Court User 587 COURT NOTICE Processed 09/28/2020 Court User
Motion Withdrawn Without prejudice Processed 09/28/2020 Court User 589 CONSENT TO CHANGE ATTORNEY (POST RJI) Processed 09/30/2020 Siegal, J. 590 ORDER TO SHOW CAUSE Processed 09/30/2020 Court User 591 ORDER - OTHER Processed 09/30/2020 Court User
Notice of Entry of Justice Ostrager's Decision and Order on Motion Sequence 11 Processed 09/30/2020 Moss, E.
New York County Supreme Court 652077/2017 Document List of 65
Doc# Document Type/Information Status Date Received Filed By
593 ORDER TO SHOW CAUSE - CONFORMED COPY Signed Order to Show Cause with Supporting Papers Processed 09/30/2020 Moss, E. 594 TRANSCRIPT - SO ORDERED Processed 10/07/2020 Court User 595 LETTER / CORRESPONDENCE TO JUDGE Processed 10/07/2020 Nash, K.
Notice of Entry of So-Ordered Transcript re: Motion Sequence 11 Processed 10/08/2020 Moss, E.
Letter from E. Moss to Justice Ostrager re: Genever Holdings LLC's 10/07/20 Letter Processed 10/08/2020 Moss, E.
Joint Letter from Plaintiff and Defendant Miles Kwok to Justice Ostrager re: October 15, 2020 Hearin Processed 10/08/2020 Moss, E.
Defendant Kwok Ho Wan's Memorandum of Law in Opposition to Order to Show Cause Processed 10/13/2020 Carvalho, M. 600 AFFIDAVIT OR AFFIRMATION IN OPPOSITION TO
Affirmation of Melissa M. Carvalho in Opposition to Order to Show Cause Processed 10/13/2020 Carvalho, M.
Exhibit 1 - Plaintiff's Second Set of Request for the Production of Documents Processed 10/13/2020 Carvalho, M.
Defendant Kwok Ho Wan's Notice of Cross-Motion Processed 10/13/2020 Siegal, J. 603 MEMORANDUM IN OPPOSITION TO MOTION AND IN
Defendant Kwok Ho Wan's Memorandum of Law in Opposition and in Support of Cross-Motion Processed 10/13/2020 Siegal, J. 604 AFFIDAVIT OR AFFIRMATION IN OPPOSITION TO
Affirmation of John Siegal in Opposition to Motion and in Support of Cross-Motion Processed 10/13/2020 Siegal, J.
Exhibit 1-Amended Complaint Processed 10/13/2020 Siegal, J.
Exhibit 2-Answer Processed 10/13/2020 Siegal, J.
Exhibit 3-Proposed Amended Answer Processed 10/13/2020 Siegal, J.
Exhibit 4- Highlighted 1.15.20 Derek Crane Full Transcripth Processed 10/13/2020 Siegal, J.
Exhibit 5-Highlighted 11.6.19 Catherine Yang Transcript Processed 10/13/2020 Siegal, J.
Exhibit 6-Highlighted 11.21.19 Jon Lewis Full Transcript Processed 10/13/2020 Siegal, J.
Exhibit 7-8-17-2020-Affirmation of Phillip Loukis Processed 10/13/2020 Siegal, J.
New York County Supreme Court 652077/2017
Doc# Document Type/Information Status Date Received Filed By
Exhibit 8- 8-3-2015 Email from H. Wong to Derek Crane Processed 10/13/2020 Siegal, J.
Exhibit 9-Email 7-24-2015 from D. Crane to Chris Gradel Processed 10/13/2020 Siegal, J.
Exhibit 10-2011 loan facility letter Processed 10/13/2020 Siegal, J.
Exhibit 11-2011 personal guarantee Processed 10/13/2020 Siegal, J.
Exhibit 12-PAX-KWOK-063878 -PAX-KWOK-063879 Processed 10/13/2020 Siegal, J.
Reply Memorandum of Law in Further Support of Plaintiff Pacific Alliance Asia Opportunity Fund L.P.' Processed 10/14/2020 Moss, E.
Affirmation of Edward Moss in Support of Plaintiff's CPLR 5229 Processed 10/14/2020 Moss, E.
Nevada Motion to Order Satisfaction of Judgment Processed 10/14/2020 Moss, E.
Horvitz Deposition Transcript Processed 10/14/2020 Moss, E.
Responses and Objections to Interrogatories Processed 10/14/2020 Moss, E.
Responses and Objections to Requests for Production Processed 10/14/2020 Moss, E.
Kwok Deposition Transcript Processed 10/14/2020 Moss, E.
Searles Email Processed 10/14/2020 Moss, E.
Searles Letter Processed 10/14/2020 Moss, E.
Nevada Opposition Processed 10/14/2020 Moss, E. 627 NOTICE OF BANKRUPTCY (POST RJI) Processed 10/14/2020 Donovan, J.
Proof of filing Processed 10/14/2020 Donovan, J.
Daniel S. Shamah Processed 10/14/2020 Shamah, D. 630 DECISION + ORDER ON MOTION Processed 10/15/2020 Court User
Notice of Entry of Justice Ostrager's Decision and Order on Motion Sequence 011 Processed 10/15/2020 Moss, E.
Notice of Entry of Justice Ostrager's Decision and Order on Motion Sequence 011 Processed 10/15/2020 Moss, E. 633 DECISION + ORDER ON MOTION Processed 10/16/2020 Court User
New York County Supreme Court 652077/2017 Document List Index # of 65
Doc# Document Type/Information Status Date Received Filed By
Notice of Appeal of Order dated 9/15/20 and entered on 9/16/20 Pending 10/16/2020 Siegal, J.
Memorandum of Law in Further Support of Plaintiff Pacific Alliance Asia Opportunity Fund L.P.'s Moti Processed 10/23/2020 Moss, E.
Affirmation of Edward Moss in Further Support of Plaintiff's Motion to Establish Damages, Legal Fees Processed 10/23/2020 Moss, E.
5229 Hearing Transcript Processed 10/23/2020 Moss, E.
Produced Document Metadata Processed 10/23/2020 Moss, E.
Notice of Intent to Request Judicial Notice of Foreign Law Processed 10/23/2020 Moss, E.
Melwani Affirmation Processed 10/23/2020 Moss, E.
Melwani CV Processed 10/23/2020 Moss, E.
Foreign Law Treatise Processed 10/23/2020 Moss, E.
Foreign Case Law Processed 10/23/2020 Moss, E.
Foreign Case Law Processed 10/23/2020 Moss, E.
Foreign Case Law Processed 10/23/2020 Moss, E. 646 COURT NOTICE Processed 10/29/2020 Court User 647 TRANSCRIPT - SO ORDERED Processed 11/10/2020 Court User 648 ORDER - STATUS CONFERENCE Processed 11/13/2020 Court User
Letter to Judge Ostrager re: The Lady May Processed 11/18/2020 Siegal, J.
Letter to the Court re: the Lady May Processed 11/19/2020 Sarnoff, S.
Nov. 18, 2020 Letter Processed 11/19/2020 Sarnoff, S. 652 STIPULATION - OTHER - ( REQUEST TO SO ORDER ) Stipulation Adjourning Pre-Trial Deadlines and Trial Date Processed 11/30/2020 Moss, E.
Affirmation of John Siegal Processed 12/03/2020 Siegal, J.
Exhibit 1 - E-Mail Dated June 1, 2015 Processed 12/03/2020 Siegal, J.
Exhibit 2 - E-Mail Dated January 20, 2012 Processed 12/03/2020 Siegal, J.
New York County Supreme Court 652077/2017
Doc# Document Type/Information Status Date Received Filed By
Exhibit 3 - E-Mail Dated September 12, 2014 Processed 12/03/2020 Siegal, J.
Exhibit 4 - E-Mail Dated August 21, 2015 Processed 12/03/2020 Siegal, J.
Exhibit 5 - Bates numbered PAX-KWOK-066635 Processed 12/03/2020 Siegal, J.
Exhibit 6 - Minutes-PAG Risk Committee Meeting Processed 12/03/2020 Siegal, J.
Exhibit 7 - E-Mail Dated September 12, 2013 Processed 12/03/2020 Siegal, J.
Exhibit 8 - E-Mail Dated October 22, 2012 Processed 12/03/2020 Siegal, J.
Exhibit 9 - Colliers Valuation Dated January 2015 Processed 12/03/2020 Siegal, J.
Exhibit 10 - E-Mail Dated October 22, 2012 Processed 12/03/2020 Siegal, J.
Exhibit 11 - E-Mail Dated January 3, 2014 Processed 12/03/2020 Siegal, J.
Exhibit 12 - PANGU Arrangement for Recovery of Amounts Owed Processed 12/03/2020 Siegal, J.
Notice of Intent to Request Judicial Notice of Foreign Law Processed 12/03/2020 Siegal, J.
Exhibit A - Affirmation of Phillip Loukis Georgiou in Opposition to Plaintiff's Motion to Establish Processed 12/03/2020 Siegal, J.
Exhibit B - Curriculum vitae of Phillip Loukis Georgiou Processed 12/03/2020 Siegal, J.
Exhibit C- British Westinghouse Co v Underground Ry [1912] A.C. 673 Processed 12/03/2020 Siegal, J.
Exhibit D - Win Profit Corporation Ltd v World Orient Investment Ltd [2012] HKCFI 529 Processed 12/03/2020 Siegal, J.
Exhibit E - Able Success Asia Ltd v China Packaging Group Co Ltd [2015] HKEC 2508, HCA 1120/2014 (25 Processed 12/03/2020 Siegal, J.
Exhibit F - Strong Offer Investment Limited v Nyeu Ting Chuang Processed 12/03/2020 Siegal, J.
Exhibit G - Chitty on Contracts, 33rd Edition, at 21-041 Processed 12/03/2020 Siegal, J.
Exhibit H - Chitty on Contracts, 33rd Edition, at 2-159 Processed 12/03/2020 Siegal, J.
Exhibit I - Marble Holding Limited v Yatin Development Limited, (2008) 11 HKCFAR 222 Processed 12/03/2020 Siegal, J.
Exhibit J - McGregor on Damages, 20th Ed, 9-004 Processed 12/03/2020 Siegal, J.
Doc# Document Type/Information Status Date Received Filed By
New York County Supreme Court 652077/2017
677 EXHIBIT(S) Exhibit K - Payzu v Saunders [1919] 2 K.B. 581 CA Processed 12/03/2020 Siegal, J. 678 EXHIBIT(S) Exhibit L - Kin Tong Land Investment Co Ltd v Capella Ltd [2019] HKDC 65 Processed 12/03/2020 Siegal, J. 679 EXHIBIT(S) Exhibit M - Kings City Holdings Limited v De Monsa Investments Limited [2012] CACV 205/2012 Processed 12/03/2020 Siegal, J. 680 EXHIBIT(S) Exhibit N - Lagden v OConnor [2003] UKHL 64 Processed 12/03/2020 Siegal, J. 681 EXHIBIT(S) Exhibit O - Ge Qingfu & Ors v L&A International Holdings Limited & Ors [2019] CACV 11/2019 & CACV 16 Processed 12/03/2020 Siegal, J. 682 SUR-REPLY Defendant Mr. Kwok Ho Wan's Sur-Reply in Further Opposition to Plaintiff's Motion to Establish Damag Processed 12/03/2020 Siegal, J. 683 NOTIFICATION FROM COURT Notice of Neutral Evaluation Program - Commercial Division - Supreme NY Civil Processed 12/09/2020 Court User 684 LETTER / CORRESPONDENCE TO JUDGE Letter from E. Moss to Court and Memorandum of Law in Support of PAX's Response to Kwok's Sur-Reply Processed 12/15/2020 Moss, E. 685 DECISION + ORDER ON MOTION Processed 12/18/2020 Court User 686 NOTICE OF ENTRY Notice of Entry of Justice Ostrager's Decision and Order on Motion Sequence 009 Processed 12/21/2020 Moss, E. 687 Deleted 688 NOTICE OF MOTION Notice of Motion for Order of Contempt Against Defendant Kwok Processed 12/24/2020 Moss, E. 689 MEMORANDUM OF LAW IN SUPPORT Memorandum of Law in Support of Pacific Alliance Asia Opportunity Fund L.P.'s Motion for Order of Co Processed 12/24/2020 Moss, E. 690 AFFIDAVIT OR AFFIRMATION IN SUPPORT OF Affirmation of Edward Moss in Support of Plaintiff's Motion for Order of Contempt Against Defendant Processed 12/24/2020 Moss, E.
Motion for Order of Contempt Against Defendant
691 EXHIBIT(S) Processed 12/24/2020 Moss, E.
692 EXHIBIT(S) Processed 12/24/2020 Moss, E.
693 EXHIBIT(S) Processed 12/24/2020 Moss, E.
694 STIPULATION - ADJOURNMENT OF MOTION -IN Processed 01/04/2021 Carvalho, M.
695 TRANSCRIPT OF PROCEEDINGS - CERTIFIED Processed 01/08/2021 Moss, E. Transcript of Proceedings held on December 18, 2020
New York County Supreme Court 652077/2017 Document List Index # of 65
Doc# Document Type/Information Status Date Received Filed By
696 TRANSCRIPT - SO ORDERED Processed 01/12/2021 Court User
Notice of Appeal of Order dated and entered on 12/18/20 Pending 01/12/2021 Siegal, J.
Defendant Kwok Ho Wan's Memorandum of Law in Opposition to Plaintiff's Motion for an Order of Contem Processed 01/19/2021 Siegal, J. 699 AFFIDAVIT OR AFFIRMATION IN OPPOSITION TO
Affirmation of Melissa Carvalho in Opposition to Plaintiff's Motion for an Order of Contempt Processed 01/19/2021 Siegal, J.
Exhibit 1 - Letter dated 11/9/2020 Processed 01/19/2021 Siegal, J. 701 AFFIDAVIT OR AFFIRMATION IN OPPOSITION TO
Affirmation of Craig Heaslop in Opposition to Plaintiff's Motion for an Order of Contempt Processed 01/19/2021 Siegal, J. 702 AFFIDAVIT OR AFFIRMATION IN OPPOSITION TO
Affirmation of Lee Vartan in Opposition to Plaintiff's Motion for an Order of Contempt Processed 01/19/2021 Siegal, J.
Exhibit A - Registration Certificate Processed 01/19/2021 Siegal, J.
Exhibit B - Certificate of Formation Processed 01/19/2021 Siegal, J.
Exhibit C - LLC Agreement Processed 01/19/2021 Siegal, J.
Exhibit D - Certificate of Correction Processed 01/19/2021 Siegal, J.
Exhibit E - Certificate of Good Standing Processed 01/19/2021 Siegal, J. 708 STIPULATION - ADJOURNMENT OF MOTION -IN
Stipulation Processed 01/26/2021 Moss, E.
PLAINTIFF PACIFIC ALLIANCE ASIA OPPORTUNITY FUND L.P.S MOTIO Processed 01/27/2021 Moss, E.
OPPORTUNITY FUND L.P.S MOTION Processed 01/27/2021 Moss, E.
Certified Translation of YouTube Video Processed 01/27/2021 Moss, E.
Debtors Declaration Processed 01/27/2021 Moss, E.
FURTHER SUPPORT OF PACIFIC ALLIANCE ASIA Processed 01/27/2021 Moss, E.
Case 22-50073 Doc 1604-47 Filed 03/27/23 Entered 03/27/23 14:12:10 Page 60
New York County Supreme Court 652077/2017 Document List Index # of 65
Doc# Document Type/Information Status Date Received Filed By
Certified Translation of Tweets Processed 01/27/2021 Moss, E.
Letter from E. Moss to Justice Ostrager re: Contempt Motion Fully Submitted Processed 02/02/2021 Moss, E. 716 JUDGMENT - MONEY Processed 02/03/2021 Court User
Notice of Entry of Judgment entered on February 3, 2021 Processed 02/03/2021 Sarnoff, S.
[Proposed] Order to Show Cause Processed 02/12/2021 Moss, E.
Memorandum of Law in Support of Plaintiff Pacific Alliance Asia Opportunity Fund L.P.'s Motion to Am Processed 02/12/2021 Moss, E. 721 AFFIDAVIT OR AFFIRMATION IN SUPPORT OF
Affirmation of Edward Moss, Esq. in Support of Plaintiff's Motion to Amend Judgment Processed 02/12/2021 Moss, E.
Proposed Amended Judgment Processed 02/12/2021 Moss, E. 723 DECISION + ORDER ON MOTION Processed 02/22/2021 Court User
Notice of Entry of Decision and Order dated February 22, 2021 Processed 02/23/2021 Carvalho, M.
Notice of Appeal from the Judgment dated February 3, 2021 Pending 03/02/2021 Siegal, J.
Letter to Justice Ostrager from Stuart Sarnoff re: Lady May Processed 03/16/2021 Sarnoff, S. 727 NOTICE OF APPEARANCE (POST RJI) Processed 03/16/2021 Spelfogel, D. 728 DECISION + ORDER ON MOTION Processed 03/16/2021 Court User 729 NOTICE OF APPEARANCE (POST RJI) Processed 03/16/2021 Nann, A.
Notice of Entry of Justice Ostrager's March 16, 2021 Decision and Order on Motion Sequence 12 Processed 03/17/2021 Sarnoff, S.
Notice of Appeal from Order Entered March 17, 2021 Pending 03/23/2021 Siegal, J. 732 NOTICE OF APPEARANCE (POST RJI) Processed 04/14/2021 Alter, D. 733 LETTER / CORRESPONDENCE TO JUDGE Processed 04/14/2021 Alter, D.
New York County Supreme Court 652077/2017 Document List Index # of 65
Doc# Document Type/Information Status Date Received Filed By
734 COURT NOTICE Processed 04/15/2021 Court User 735 COURT NOTICE Processed 04/16/2021 Court User 736 ORDER TO SHOW CAUSE ( PROPOSED ) Processed 04/21/2021 Alter, D. 737 AFFIDAVIT OR AFFIRMATION IN SUPPORT OF PROPOSED OSC/EXPARTE APP - Corrected Processed 04/22/2021 Alter, D.
Subpoena served on Bank of America Processed 04/21/2021 Alter, D.
Subpoena served on Citibank Processed 04/21/2021 Alter, D.
Subpoena served on JP Morgan Chase Processed 04/21/2021 Alter, D. 741 MEMORANDUM OF LAW IN SUPPORT Processed 04/21/2021 Alter, D. 742 AFFIDAVIT OR AFFIRMATION IN SUPPORT OF PROPOSED OSC/EXPARTE APP Processed 04/22/2021 Alter, D. 743 ORDER TO SHOW CAUSE Processed 04/22/2021 Court User 744 LETTER / CORRESPONDENCE TO JUDGE Processed 04/22/2021 Alter, D. 745 AFFIRMATION/AFFIDAVIT OF SERVICE Processed 04/22/2021 Alter, D.
Filing on Behalf of - Rose Ann Magaldi, Law Clerk Processed 04/22/2021 Court User 747 LETTER / CORRESPONDENCE TO JUDGE Processed 04/27/2021 Alter, D.
Request to be added to Microsoft Teams Meeting Processed 04/27/2021 Mitchell, A.
April 28, 2021 Letter from E. Moss to Court Processed 04/28/2021 Moss, E.
Memorandum of Law in Opposition to Nonparty Movant Yvette Wang's Motion for Relief Pursuant to CPLR Processed 04/28/2021 Moss, E.
Memorandum of Law in Opposition to Nonparty Movant Yvette Wang's Motion for Relief Pursuant to CPLR Processed 04/28/2021 Moss, E.
Affirmation of Edward Moss in Support of Plaintiff's Opposition to Nonparty Movant Yvette Wang's Mot Processed 04/28/2021 Moss, E. 753 AFFIDAVIT/AFFIRMATION - REQUEST TO SEAL Affirmation of Edward Moss in Support of Plaintiff's Opposition to Nonparty Movant Yvette Wang's Mot Processed 04/28/2021 Moss, E.
Screenshot from YouTube Processed 04/28/2021 Moss, E.
New York County Supreme Court 652077/2017
Doc# Document Type/Information Status Date Received Filed By
Transcription of YouTube captions Processed 04/28/2021 Moss, E.
Responses and Objections Processed 04/28/2021 Moss, E.
Debtors Declaration in Genever Bankruptcy Processed 04/28/2021 Moss, E.
Instrument of Transfer Processed 04/28/2021 Moss, E.
Sherry-Netherland Joinder Processed 04/28/2021 Moss, E.
March 11, 2021 Letter from M. Carvalho to E. Moss Processed 04/28/2021 Moss, E.
April 23, 2021 Email Chain between A. Mitchell and E. Moss Processed 04/28/2021 Moss, E.
April 21, 2021 Letter from L. Vartan to E. Moss Processed 04/28/2021 Moss, E.
April 9-15, 2021 Email Chain between D. Alter and E. Moss Processed 04/28/2021 Moss, E.
Kwok Affidavit in Ace Decade v. UBS Processed 04/28/2021 Moss, E.
Feb. 21, 2021 Letter from M. Carvalho to E. Moss Processed 04/28/2021 Moss, E.
April 7, 2021 Letter from K. Kearney to E. Moss Processed 04/28/2021 Moss, E.
Transcript of December 18, 2020 Hrg in Genever Bankruptcy Processed 04/28/2021 Moss, E.
GSNY Proof of Claim in Genever Bankruptcy Processed 04/28/2021 Moss, E.
April 9, 2021 Letter from D. Alter to E. Moss and S. Sarnoff Processed 04/28/2021 Moss, E.
Wang Depo. Tr. Excerpts Processed 04/28/2021 Moss, E.
Dept of State Records Processed 04/28/2021 Moss, E.
USPTO Records Processed 04/28/2021 Moss, E.
Trial Tr. Excerpts in Eastern Profit v. Strategic Vision Processed 04/28/2021 Moss, E.
April 29, 2021 Letter from E. Moss to Court Processed 04/29/2021 Moss, E. 775 LETTER / CORRESPONDENCE TO JUDGE Processed 04/30/2021 Alter, D. 776 DECISION + ORDER ON MOTION Processed 04/30/2021 Court User H yea heSUPREME COURT OF THE STATE OF NEW YORK COUNTY OF NEW YORK
PACIFIC ALLIANCE ASIA OPPORTUNITY FUND L.P.,
v.
KWOK HO WAN, a/k/a KWOK HO, a/k/a GWO WEN GUI, a/k/a GUO WENGUI, a/k/a GUO WEN-GUI, a/k/a WAN GUE HAOYUN, a/k/a MILES KWOK, a/k/a HAOYUN GUO, GENEVER HOLDINGS, LLC, and GENEVER HOLDINGS CORPORATION,
Defendants.
O'MELVENY & MYERS LLP Edward N. Moss (emoss@omm.com) Stuart M. Sarnoff (ssarnoff@omm.com) Daniel S. Shamah (dshamah@omm.com) 7 Times Square New York, NY 10036 Tel: (212) 326-2000
FOLEY & LARDNER LLP Douglas E. Spelfogel (dspelfogel@foley.com) Alissa M. Nann (anann@foley.com) 90 Park Avenue New York, New York 10016 Tel: (212) 338-3578
SEIDEN LAW GROUP LLP Robert W. Seiden (rseiden@seidenlegal.com) 69 Seventh Avenue, Fifth Floor New York, NY 10018 Tel: (212) 523-0686
Attorneys for Plaintiff Pacific Alliance Asia Opportunity Fund L.P.
BAKER & HOSTETLER LLP John Siegal (jsiegal@bakerlaw.com) Melissa M. Carvalho (mcarvalho@bakerlaw.com) 45 Rockefeller Plaza New York, NY 10111-0100 Tel (212) 589-4289
LAWALL & MITCHELL, LLC Aaron A. Mitchell (aaron@lmesq.com) 162 E. 64th Street New York, NY 10065 (973) 285-3280
Attorneys for Defendants Genever Holdings LLC and Genever Holdings Corporation
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