Guo Wengui / Miles Guo — bankruptcy case · ORDER · ECF #1682

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

| -----------------------------------------------------------<br>x | | | | |------------------------------------------------------------------|-------------|-------------------------|--| | In re: | :<br>: | Chapter 11 | | | HO WAN KWOK et al., | :<br>:<br>: | Case No. 22-50073 (JAM) | | | Debtors.1 | :<br>: | Jointly Administered | | | ----------------------------------------------------------- | x | | |

## **CHAPTER 11 TRUSTEE'S RESPONSE IN OPPOSITION TO BRAVO LUCK LIMITED'S ORAL MOTION FOR RELIEF FROM JUDGMENT**

Luc A. Despins, in his capacity as the chapter 11 trustee (the "Trustee") appointed in the chapter 11 case of Ho Wan Kwok (the "Individual Debtor"), pursuant to the Court's scheduling order entered April 18, 2023 [ECF No. 1679], in response to the oral motion for relief from judgment or order (the "Oral Motion") made by Bravo Luck Limited ("Bravo Luck") concerning the Court's Order [ECF No. 1672] (the "Order") Granting Motion of Chapter 11 Trustee to Limit Notice and to Seal with Respect to Motion for Order Authorizing Abandonment of Property Pursuant to Bankruptcy Code Section 554 and Bankruptcy Rule 6007 [ECF No. 1666] (the "Motion to Limit Notice"), hereby states the following:

The Trustee believes that the Court decided the Motion to Limit Notice correctly in the first instance and that the Court's Order should stand. The Trustee will be prepared to discuss his position at the hearing on Bravo Luck's Oral Motion on April 20, 2023 at 11 a.m. In the meantime,

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 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).

consistent with the Court's comments during hearings on April 18, 2023, the Trustee is prepared to speak with counsel for Bravo Luck to determine whether this dispute may be resolved.

Dated: April 19, 2023 RESPECTFULLY SUBMITTED,

New Haven, Connecticut LUC A. DESPINS, CHAPTER 11 TRUSTEE

By: */s/ Patrick R. Linsey* Douglas S. Skalka (ct00616) Patrick R. Linsey (ct29437) NEUBERT, PEPE & MONTEITH, P.C. 195 Church Street, 13th Floor New Haven, Connecticut 06510 (203) 781-2847 dskalka@npmlaw.com plinsey@npmlaw.com

*Counsel for the Chapter 11 Trustee*

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

| -----------------------------------------------------------<br>x | | | | |------------------------------------------------------------------|-------------|-------------------------|--| | In re: | :<br>: | Chapter 11 | | | HO WAN KWOK et al., | :<br>:<br>: | Case No. 22-50073 (JAM) | | | Debtors. | :<br>: | Jointly Administered | | | ----------------------------------------------------------- | x | | |

## **CERTIFICATE OF SERVICE**

The undersigned hereby certifies that on April 19, 2023, the foregoing, and all declarations, exhibits and attachments thereto, was electronically filed. Notice of this filing was sent by e-mail to all parties to the above-captioned chapter 11 case by operation of the Court's electronic filing ("CM/ECF") system or by mail to anyone unable to accept electronic filing as indicated on the Notice of Electronic Filing. Parties may access this filing through the Court's CM/ECF system.

Dated: April 19, 2023 New Haven, Connecticut

By: */s/ Patrick R. Linsey*

Douglas S. Skalka (ct00616) Patrick R. Linsey (ct29437) NEUBERT, PEPE & MONTEITH, P.C. 195 Church Street, 13th Floor New Haven, Connecticut 06510 (203) 781-2847 dskalka@npmlaw.com plinsey@npmlaw.com

*Counsel for the Chapter 11 Trustee*