---
type: court_doc
id: "court_ctb_1703_2"
court: "CTB"
case_no: "22-50073"
doc_number: 1703
doc_type: "EXHIBIT"
filed_date: null
lang: "en"
machine_translated: false
url: "https://mubeitech.com/en/court/court_ctb_1703_2"
json_url: "https://mubeitech.com/api/court/court_ctb_1703_2"
---
# Guo Wengui / Miles Guo — bankruptcy case · EXHIBIT · ECF #1703-2



UNITED STATES BANKRUPTCY COURT DISTRICT OF CONNECTICUT BRIDGEPORT DIVISION

-----------------------------------------------------------　x

In re:　:
:　Chapter 11
HO WAN KWOK et al.,　:
:
:　Case No. 22-50073 (JAM)
Debtors.1　:
:　Jointly Administered
-----------------------------------------------------------　x
APPELLEE'S COUNTER-DESIGNATION OF ADDITIONAL ITEMS TO BE INCLUDED IN RECORD ON APPEAL

Appellee, Luc A. Despins, in his capacity as the chapter 11 trustee (the "Trustee") appointed in the chapter 11 case of Ho Wan Kwok (the "Debtor"), by and through his undersigned counsel, hereby provides, pursuant to Rule 8009 of the Federal Rules of Bankruptcy Procedure, the following counter-designation of additional items to be included in the record on appeal.
COUNTER-DESIGNATION OF RECORD ON APPEAL

Appellee respectfully counter-designates the following items for inclusion in the record on appeal pursuant to Rule 8009(a)(2) of the Federal Rules of Bankruptcy Procedure. This designation includes all exhibits attached or referred to in the pleadings or matters of record.

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).

Docket No.　Date Filed　Description

703　08/05/2022　The Debtor's Limited Objection to Rule 2004 Motions
724　08/10/2022　Chapter 11 Trustee's Reply in Support of Motions for Entry
of Orders Under Bankruptcy Rule 2004 and Local Rule
2004-1 Authorizing Examinations of Debtor, Debtor's Legal
and
Financial
Advisors,
And
Various
Entities
And
Individuals Affiliated with Debtor, and For Production of
Documents
732　08/11/2022　Declaration of Aaron A. Romney in Support of the Debtor's
Limited Objection to Rule 2004 Motions
766　08/18/2022　Transcript of Hearing Held August 12, 2022
874　09/24/2022　Motion of Chapter 11 Trustee for Entry of Protective Order
923　10/06/2022　Protective Order
1116　11/18/2022　Second Supplemental Omnibus Motion of Chapter 11
Trustee for Entry of Order Under Bankruptcy Rule and Local
Rule
2004-1
Authorizing
Discovery
With
Respect
to
Additional Legal and Financial Advisors to the Debtor,
Entities And Individual Affiliated With Debtor, and Relevant
Banks
1149　11/22/2022　Joint Limited Objection of Mei Guo and HK International
Funds Investments (USA) Limited, LLC to the Second
Supplemental Omnibus Motion of Chapter 11 Trustee for
Entry of Order Under Bankruptcy Rule and Local Rule
2004-1 Authorizing Discovery With Respect to Additional
Legal and Financial Advisors to the Debtor, Entities And
Individual Affiliated With Debtor, and Relevant Banks
1184　12/02/2022　Order Granting Chapter 11 Trustee's Second Supplemental
Omnibus Motion for 2004 Examination
Main Bankruptcy Case Docket Entries (No. 22-50073 (JAM))
CERTIFICATION REGARDING TRANSCRIPTS

Appellee, pursuant to Rule 8009(b)(3) of the Federal Rules of Bankruptcy Procedure, hereby certifies that he is not ordering any transcripts. All transcripts have been prepared and are either available on the docket or in the Bankruptcy Court Clerk's Office.
RESERVATION OF RIGHTS

Appellee expressly reserves the right to (i) withdraw, supplement, amend or modify this Counter-Designation of Record on Appeal and (ii) move to strike any items included by the Appellant in the Designation of Items to be Included in the Record on Appeal and Statement of Issues to be Presented. This filing is made expressly subject to, and without waiver of any and all rights, remedies, challenges, and objections.

Respectfully submitted,

Dated: April 24, 2023 LUC A. DESPINS,

New Haven, Connecticut CHAPTER 11 TRUSTEE

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

and

Nicholas A. Bassett (admitted pro hac vice) PAUL HASTINGS LLP 2050 M Street NW Washington, D.C., 20036 (202) 551-1902 nicholasbassett@paulhastings.com

and

Avram E. Luft (admitted pro hac vice) Douglass Barron (admitted pro hac vice) PAUL HASTINGS LLP 200 Park Avenue New York, New York 10166 (212) 318-6079 aviluft@paulhastings.com

Counsel for the Chapter 11 Trustee
UNITED STATES BANKRUPTCY COURT DISTRICT OF CONNECTICUT BRIDGEPORT DIVISION

x

In re:　:　CHAPTER 11

HO WAN KWOK, et al.,　:　CASE NO. 22-50073
(JAM)

Debtors.　:　Jointly Administered
x
CERTIFICATE OF SERVICE

The undersigned hereby certifies that on April 24, 2023, the foregoing was filed electronically using the Court's case management/electronic case files ("CM/ECF") system. Parties may access the Order to Show Cause via the CM/ECF system.

Dated: April 24, 2023 LUC A. DESPINS,

New Haven, Connecticut CHAPTER 11 TRUSTEE

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

2 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).