Guo Wengui / Miles Guo — bankruptcy case · DECLARATION · ECF #1642

# UNITED STATES BANKRUPTCY COURT DISTRICT OF CONNECTICUT BRIDGEPORT DIVISION

| 이 서 서 바 바 바 바 바 바 바 바 바 바 바 바 바 바 바 있 는 일 바 바 바 있 바 있 바 있 바 있 바 있 바 바 바 바 바 바 바 바 바 바 바 바 바 바 바 바 바 바 바 바 바 바 바 바 바 바 바 바 바 바 바 바 바 바 바 바 바 바 바 바 바 바 바 바 바 바 바 바 바 바 바 바 바 바 | | | |-------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|--|---------------------------| | | | | | In re: | | Chapter 11 | | | | | | HO WAN KWOK, et al., 1 | | : Case No. 22-50073 (JAM) | | | | | | Debtors. | | : Jointly Administered | | | | |

# SUPPLEMENTAL DECLARATION OF GEORGE WESTON IN SUPPORT OF RETENTION AND EMPLOYMENT OF HARNEY WESTWOOD AND RIEGELS LP, AS BRITISH VIRGIN ISLANDS COUNSEL TO THE CHAPTER 11 TRUSTEE AND GENEVER HOLDINGS CORPORATION

I, George Weston, being duly sworn, do depose and say:

I submit this declaration (the "Second Supplemental Declaration") to supplement

(a) the declaration of Andrew Thorp submitted to the Court on August 31, 2022 [Docket No. 807-2] by Andrew Thorp (the "Initial Declaration"),2 (b) the declaration of Andrew Thorp submitted to the Court on September 2, 2022 [Docket No. 815] (the "First Supplemental Declaration"), and (c) the declaration of George Weston submitted to the Court on December 16, 2022 [Docket No. 1247-1] (the "Weston Declaration" and, together with the Initial Declaration and the First Supplemental Declaration, the "Prior Declarations"), and in further support of the Chapter 11 Trustee's and Genever Holdings Corporations' ("Genever (BVL)") applications to employ Harney Westwood and Riegels LP ("Harneys Legal") as BVI counsel. I hereby

¹ The Debtors in these chapter 11 cases are Ho Wan Kwok (also known as Guo Wengui, Miles Guo, and Miles Kwok, as well as numerous other aliases) (last four digits of tax identification number: 9595), Genever Holdings LLC (last four digits of tax identification number: 8202) and Genever Holdings Corporation. The mailing address for the Trustee, Genever Holdings LLC, and the Genever Holdings Corporation is Paul Hastings LLP, 200 Park Avenue, New York, NY 10166 c/o Luc A. Despins, as Trustee for the Estate of Ho Wan Kwok (solely for purposes of notices and communications).

² Capitalized terms not defined herein shall have the meanings ascribed to them in the Initial Declaration.

supplement the Prior Declarations with respect to Harneys Legal appointment as BVI counsel to the Trustee and Genever (BVI) as follows:

2. Subsequent to Harneys Legal appointment as BVI counsel, and upon review of the updated schedule of parties in interest (the "Interested Parties"), a copy of which is attached hereto as Schedule 1, I had Harneys Legal's conflicts team perform additional conflicts checks on all Interested Parties. Based on the results of the additional conflicts checks, I believe neither Harneys Legal nor any of its attorneys, including me, has any connections (as that term is used in Bankruptcy Rule 2014), with any of the Interested Parties, except as previously disclosed in the Prior Declarations and except as follows:

- a. Based on information now in the public domain and the similarity to names of certain Interested Parties. I believe there is a significant possibility that G Fashion International Limited and G Club International Limited (together, the "G International Entities") are corporate entities connected to Ho Wan Kwok (the "Individual Debtor"), although I cannot conclusively determine that they are linked to the Individual Debtor. Harneys Legal provided limited corporate advice relating to the G International Entities prior to becoming aware of the potential connection to the Individual Debtor on or about March 16, 2023, and after an internal investigation immediately thereafter ended its business relationship with the G International Entities - b. While we are not able to give full details of the work performed for the G International Entities given we have obligations of confidentiality notwithstanding the termination of our business relationship, by way of summary:

つ

- i. We were instructed by a US law firm who were acting on behalf of a third party entity which was itself providing services to G Fashions Limited. Our client was not G Fashion International Limited, but was the third party entity. We drafted an agreement governed by BVI law, and resolutions approving the agreement. The first instruction was on 22 November 2022 and the work was completed in January 2023. We incurred less than US\$2,000 in fees. We have not been paid for this engagement, and will not seek payment. - ii. We were approached on behalf of G Clubs International Limited by a BVI service provider on 30 January 2023. We provided advice on compliance with BVI economic substance requirements on a certain fact pattern for an agreed fee of less than US\$2,000. That work was not complete at the time of stopping work. We have not been paid for this engagement, and will not seek payment. - iii. We were provided documentation as to the beneficial owner behind the G International Entities which did not show the owner being the Individual Debtor (under any of his known aliases) or any of his family members. Due to the fact the G International Entities did not exactly match the names on the interested parties list, and due to the information we were supplied suggesting a different UBO behind those entities, our conflicts checks did not identify at the time of commencing work that these entities might be linked to Kwok.

3

3.

that the foregoing is true and correct.

Dated: April 6, 2023, at London, United Kingdom

/s/ George Weston

### SCHEDULE OF PARTIES IN INTEREST - IN RE KWOK

#### 20 LARGEST UNSECURED CREDITORS

PACIFIC ALLIANCE ASIA OPPORTUNITY GOLDEN SPRING NEW YORK RUI MA CHENG JIAN WU JIAN SHE NING YE GUO BAOSHENG YAN LAN & WU ZHENG HONG QI QU NAN TONG SI JIAN JIAN GONG YAN ZHAO YUA HUA ZHUANG SHI LIEHONG ZHUANG/XIAO YAN ZHU WEICAN MENG/BOXUN INC. SAMUEL NUNBERG LAMP CAPITAL LLC JUN CHEN AKA JONATHAN HO YUE HUA ZHU SHI XIONG XIAN WEI YE HUIZEN WANG

#### DEBTOR, FAMILY MEMBERS, AND CERTAIN RELATED ENTITIES

HO WAN KWOK (A.K.A MILES GWOK, MILES GUO AND WENGUI GUO) HING CH NGOK/YUE QINGZHI QIANG GUO MEI GUO/MEI GUI HK INTERNATIONAL FUNDS INVESTMENTS (USA) LIMITED, LLC BRAVO LUCK LIMITED GENEVER HOLDINGS CORPORATION GENEVER HOLDINGS LLC

## BANKRUPTCY JUDGE AND U.S. TRUSTEE PERSONNEL

HONORABLE JULIE A. MANNING WILLIAM HARRINGTON KIM L. MCCABE HOLLEY CLAIBORN JOSEPH H. FLAMINI ERIN HOGAN STEVEN MACKEY FRANK MARINO JENNIFER J. MOREY NICOLE NEEL Y SHARON WARNER JOHN GERVAIS