Guo Wengui / Miles Guo — bankruptcy case · ECF #1805-31

METADATA

Defendant: Guo Wengui / Miles Guo / Ho Wan Kwok
Court: CTB
Case No.: 22-50073
ECF #: 1805
Type: UNKNOWN
Filed: 2023-05-18

FULL TEXT

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| From: | Temkin, Jeremy | |--------------|----------------------------------------------------------------------------------------------------------------| | TO: | Kosciewicz, Jonathon P., Scism, Chelsea, Luft, Avi E .; Sutton, Ezra | | Cc: | Moss. Ravmond | | Subject: | [EXT] RE: [External] RE: In re Kwok (No. 22-50073) - GTV & Saraca | | Date: | Wednesday, December 14, 2022 3:39:54 PM | | Attachments: | image001.png image002. ong image003. ong image004.png image005.png image006.png image007.png | | | image008.png ------------- |

ma\_info.txt

## Jon,

I suggest you direct further inquiries regarding GTV and Saraca to Aaron Mitchell. Please let me know if you need his contact information.

Best regards, Jeremy

From: Kosciewicz, Jonathon P. <jonathonkosciewicz@paulhastings.com> Sent: Wednesday, December 14, 2022 11:55 AM To: Temkin, Jeremy <JTemkin@maglaw.com>; Scism, Chelsea <cscism@maglaw.com>; Luft, Avi E. <aviluft@paulhastings.com>; Sutton, Ezra <ezrasutton@paulhastings.com> Cc: Moss, Raymond <rmoss@maglaw.com> Subject: RE: [External] RE: In re Kwok (No. 22-50073) - GTV & Saraca

Jeremy,

Following up on the below.

Thank you,

lon

| PAUL | Jonathon P. Kosciewicz Associate, Litigation Department | |------|----------------------------------------------------------------------------------------------------------------------------------------------| | | Paul Hastings LLP 71 S. Wacker Drive, Forty-Fifth Floor, Chicago, IL 60606 Direct: | | | | | | HASTINGS = 1.312.499.6021 Main: +1.312.499.600 Fax: +1.312.499.6121 www.paulhastings.com www.paulhastings.com www.paulhastings.com |

From: Kosciewicz, Jonathon P. Sent: Wednesday, December 7, 2022 12:02 AM To: Temkin, Jeremy' </Temkin@maglaw.com>; Scism, Chelsea <scism@maglaw.com>; Luft, Avi E. <aviluft@paulhastings.com>; Sutton, Ezra <ezrasutton@paulhastings.com> Cc: Moss, Raymond <rmoss@maglaw.com>

Subject: RE: [External] RE: In re Kwok (No. 22-50073) - GTV & Saraca

### Jeremy,

Thank you for confirming. As you know, both GTV and Saraca have outstanding subpoenas to respond to. Can you please let us know the contact information for the individual(s) you were communicating with at both GTV and Saraca so we can discuss with them GTV's and Saraca's obligations under the subpoena.

Thank you,

From: Temkin, Jeremy <JTemkin@maglaw.com> Sent: Thursday, December 1, 2022 4:36 PM To: Kosciewicz, Jonathon P. < jonathonkosciewicz@paulhastings.com>; Scism, Chelsea <cscism@maglaw.com>; Luft, Avi E. <aviluft@paulhastings.com>; Sutton, Ezra <ezrasutton@paulhastings.com> Cc: Moss, Raymond <rmoss@maglaw.com> Subject: [EXT] RE: [External] RE: In re Kwok (No. 22-50073) - GTV & Saraca

John,

My understanding is that, at present, neither GTV nor Saraca have retained new counsel.

My firm withdrew as counsel to both entities.

Jeremy

From: Kosciewicz, Jonathon P. <jonathonkosciewicz@paulhastings.com>

Sent: Thursday, December 1, 2022 10:44 AM

To: Scism, Chelsea <scism@maglaw.com>; Luft, Avi E. <aviluft@paulhastings.com>; Sutton, Ezra <ezrasutton@paulhastings.com> Cc: Temkin, Jeremy <JTemkin@maglaw.com>; Moss, Raymond <rmoss@maglaw.com> Subject: RE: [External] RE: In re Kwok (No. 22-50073) - GTV & Saraca

Hi Chelsea,

Can you please advise as to whether (1) GTV and Saraca have retained new counsel, and (2) whether Morvillo withdrew from their representations of GTV and Saraca, or whether GTV and Saraca terminated those representations?

Thank you,

Jon

Jonathon P. Kosciewicz | Associate, Litigation Department Johanning L. Paul Hastings LLP | 7. S. Wace, Fith Host, Chicacion Departhient P A U L

From: Scism, Chelsea <cscism@maglaw.com>

Sent: Tuesday, November 29, 2022 12:57 PM

To: Kosciewicz, Jonathon P. <ipnathonkosciewicz@paulhastings.com>; Luft, Avi E. <aviluft@gaulhastings.com>; Sutton, Ezra <ezrasutton@paulhastings.com>

Cc: Temkin, Jeremy <JTemkin@maglaw.com>; Moss, Raymond <rmoss@maglaw.com>

Subject: [EXT] RE: [External] RE: In re Kwok (No. 22-50073) - GTV & Saraca

Jon,

I write in response to your astonishing demand for a completed document production and privilege logs on or before this

Friday December 2, 2022, which you communicated to me via email at 10:50 p.m. last night. Given the history of our discussions, your demand is unreasonable and confounding.

By way of background, GTV and Saraca served their Responses and Objections to the Trustee's Rule 2004 subpoenas on October 3, 2022, and we held a subsequent "meet and confer" on October 7, 2022. During that conversation, we explained that our firm did not represent GTV or Saraca at the time the Relativity database was set up in connection with document productions to the U.S. Securities and Exchange Commission (hereinafter, "GTV Databas"), and thus we were not involved in decisions surrounding document collection of the GTV Database. We further explained that, since the time the GTV Database was created, it has been transitioned from one vendor to a second vendor-which has created additional challenges in our providing details regarding the circumstances surrounding its creation. Nevertheless, we endeavored to sift through our files-dating back more than two years-and asked our vendor to do the same in order to provide you with a description of the parameters of the GTV Database.

Our October 7 "meet and confer" concluded with a mutual understanding that, in the first instance, we would provide you with the parameters of the GTV Database. We further agreed that once you were satisfied with the GTV Database as a source for documents-and only then-we would proceed to negotiating custodians, search terms, and date ranges for your subpoena requests. Indeed, your email concedes this point when you acknowledged our agreement to "compil]e] the parameters used to create the SEC database as a starting point to discuss the appropriate parameters surrounding GTV's and Saraca's document production(s) in response to the Rule 2004 Subpoenas." (Emphasis added.) During the October 7 "meet and confer" you also committed to providing GTV and Saraca with a list of people and entities you view as equated to the definition of the "Debtor" in your subpoena requests. To date, we have not received this list is impossible to properly comply with your subpoenas.

Following the October 7 meet and confer, we did not hear from you until November 1, 2022. At that point, you emailed me, stating the following:

I write to follow up on our meet and confer held on October 7th. Were you able to compile the parameters used to create the SEC document database? As we discussed, once we review those parameters, we can propose additional parameters and search terms appropriate for your document production(s) in response to the Rule 2004 subpoena issued in this matter. Please let us know if you would like to schedule another call to discuss.

The next day, November 2, 2022, I sent you a description of the parameters of the GTV Database.

Five days later, on November 7, 2022, you sent to me a detailed list of questions concerning the GTV Database. We immediately got to work on tracking down the answers to your questions from our clients, our case files, and our vendor. On Thursday, November 10, 2022, at 12:14 am, you sent me an email asking for a call later that day. At 9:11 that morning, I informed you that we were not available for a call that we were working to gather the information you requested. I reminded you that, given our lack of involvement in the creation of the GTV Database, I would need some time to compile the information and proposed a call for the week of November 14 (i.e., as early as two business days after your request).

Six days later, on Wednesday, November 16, 2022, at 4:15 pm, you finally replied to my offer and asked to "meet and confer" on Thursday or Friday of that same week. I immediately responded that those days did not work for our team and provided over ten hours of availability for a call the following Monday and Tuesday. Despite my giving you a number of windows when we were available, you waited another six days-until Tuesday, November 22 at 12:17 pm-to request a meeting at 5:00 pm or later that same day. I promptly responded to your email, informing you that our schedules had filled up in the interim and asking if there were times that would work for your team the following week (i.e., after the Thanksgiving holiday).

The next day, you proposed Monday, November 28 at 10:00 am for a "meet and confer." You also asked-for the first time -that we send answers to your questions in writing "so we can make the M&C as productive as possible." Prior to this email, we had understood that you wished to discuss the responses to your questions during the "meet and confer" that you had demonstrated no urgency in scheduling. That same afternoon, we informed you that while we were unavailable at 10:00 a.m. on Monday, we were available after 3:00 p.m. that day.

Yesterday was Monday, November 28th. 3:00 pm came and we did not hear from you. Then, at 10:50 pm last night, you reversed course and abruptly demanded GTV's and Saraca's entire document production, and privilege logs, on or before December 2, 2022. Your proposed resolution of your failure to provide the list of people and entities that you promised on October 7, to respond to my emails in a timely fashion, and to schedule the "meet and confer" with any sense of urgency-requiring Jeremy, Ray, and me to collect, review, produce, and log hundreds of documents in the span of four days-is absurd.

In any event, please be advised that we ceased representing Saraca on Wednesday, November 23, 2022, and we ceased representing GTV earlier today.

Best regards, Chelsea

Chelsea Scism | Associate Morvillo Abramowitz Grand Iason & Anello PC 565 Fifth Avenue New York, NY 10017 212-880-9541 636-544-5553 (cell) cscism(@maglaw.com www.maglaw.com

Morvillo Abramowitz Grand Iason & Anello PC

From: Kosciewicz, Jonathon P. <ionathonkosciewicz@paulhastings.com>

Sent: Monday, November 28, 2022 10:50 PM To: Scism, Chelsea <scism@maglaw.com>; Luft, Avi E. <aviluft@paulhastings.com>; Sutton, Ezra <ezrasutton@paulhastings.com> Cc: Temkin, Jeremy <JTemkin@maglaw.com>; Moss, Raymond <rmoss@maglaw.com> Subject: RE: [External] RE: In re Kwok (No. 22-50073) - GTV & Saraca

Chelsea,

With hearings and depositions upcoming, the Trustee needs to complete Rule 2004 document collection as to key subpoena recipients, including GTV Media Group and Saraca Media Group, as soon as possible. The Trustee also needs a complete universe of documents to prepare for Rule 2004 depositions, which will be scheduled in the very near future. GTV and Saraca are the only two subpoenaed entities that have not made a single document production. Counsel for the Trustee understands that the parties have been trying to meet and confer in good faith regarding the GTV & Saraca SEC database. However, the SEC litigation against GTV and Saraca was not as broad as the Trustee's Rule 2004 investigation, and the SEC database cannot substitute for complete responses to GTV's and Saraca's Rule 2004 Subpoenas. We are requesting that GTV and Saraca complete their production of documents (including privilege log(s)) on or before December 2, 2022. If for any reason this deadline cannot be met, please reach out immediately to discuss. Otherwise, we will seek the assistance of the Court to help expedite the production of documents.

Thus far, counsel for the Trustee has been lenient as to GTV's and Saraca's production deadline, which was October 3, 2022 for both entities. In our October 7, 2022 meet and confer, we discussed compiling the parameters used to create the SEC database as a starting point to discuss the appropriate parameters surrounding GTV's and Saraca's document production(s) in response to the Rule 2004 Subpoenas. However, counsel for the Trustee did not receive those parameters until November 7, 2022 counsel for the Trustee sent follow up questions regarding the SEC database parameters, but has yet to those questions. We have reached the point where the Trustee needs GTV and Saraca to complete its production of documents, irrespective of the SEC database.

Thank you,

Jon

![](_page_4_Picture_13.jpeg)

From: Scism, Chelsea <cscism@maglaw.com>

Sent: Wednesday, November 23, 2022 3:59 PM

To: Kosciewicz, Jonathon P. <ionathonkosciewicz@paulhastings.com>; Luft, Avi E. <aviluft@oaulhastings.com>; Sutton, Ezra <ezrasutton@paulhastings.com>

Cc: Temkin, Jeremy <JTemkin@maglaw.com>; Moss, Raymond <rmoss@maglaw.com> Subject: [EXT] RE: [External] RE: In re Kwok (No. 22-50073) - GTV & Saraca

Hi Jon,

Monday morning does not work for us, but we are available Monday after 3:00 pm EST. Would that work on your end?

Thanks, Chelsea

### Chelsea Scism | Associate

Morvillo Abramowitz Grand Iason & Anello PC 565 Fifth Avenue New York. NY 10017 212-880-9541 636-544-5553 (cell) cscism@maglaw.com www.maglaw.com

Morvillo Abramowitz Grand Iason & Anello PC

From: Kosciewicz, Jonathon P. <jonathonkosciewicz@paulhastings.com>

Sent: Wednesday, November 23, 2022 12:48 PM

To: Scism, Chelsea <cscism@maglaw.com>; Luft, Avi E. <aviluft@paulhastings.com>; Sutton, Ezra <ezrasutton@paulhastings.com> Cc: Temkin, Jeremy <JTemkin@maglaw.com>; Moss, Raymond <rmoss@maglaw.com> Subject: RE: [External] RE: In re Kwok (No. 22-50073) - GTV & Saraca

Hi Chelsea,

Does Monday 11/28 at 10 am ET, work? In the meantime, please send answers to our questions sent on November 7, so we can make the M&C as productive as possible.

Thank you,

Jon

From: Scism, Chelsea <cscism@maglaw.com>

Sent: Tuesday, November 22, 2022 1:12 PM

To: Kosciewicz, Jonathon P. <jonathonkosciewicz@paulhastings.com>; Luft, Avi E. <aviluft@paulhastings.com>; Sutton, Ezra <ezrasutton@paulhastings.com>

Cc: Temkin, Jeremy <JTemkin@maglaw.com>; Moss, Raymond <rmoss@maglaw.com> Subject: [EXT] RE: [External] RE: In re Kwok (No. 22-50073) - GTV & Saraca

Hi Jon,

Unfortunately today no longer works for us. Are there times that work for your team next week?

Thanks, Chelsea

Chelsea Scism | Associate Morvillo Abramowitz Grand Iason & Anello PC 565 Fifth Avenue New York, NY 10017 212-880-9541 636-544-5553 (cell)

cscism@maglaw.com www.maglaw.com

Morvillo Abramowitz Grand Iason & Anello PC

From: Kosciewicz, Jonathon P. <ionathonkosciewicz@paulhastings.com>

Sent: Tuesday, November 22, 2022 12:17 PM

To: Scism, Chelsea <cscism@maglaw.com>; Luft, Avi E. <aviluft@paulhastings.com>; Sutton, Ezra <ezrasutton@paulhastings.com> Cc: Temkin, Jeremy <JTemkin@maglaw.com>; Moss, Raymond <rmoss@maglaw.com>

Subject: RE: [External] RE: In re Kwok (No. 22-50073) - GTV & Saraca

Hi Chelsea,

Do you still have availability for 5pm or later to meet and confer today?

Thank you,

Jon

From: Scism, Chelsea <cscism@maglaw.com> Sent: Wednesday, November 16, 2022 4:25 PM To: Kosciewicz, Jonathon P. <ionathonkosciewicz@paulhastings.com>; Luft, Avi E. <aviluft@paulhastings.com>; Sutton, Ezra <ezrasutton@paulhastings.com> Cc: Temkin, Jeremy <JTemkin@maglaw.com>; Moss, Raymond <rmoss@maglaw.com> Subject: [EXT] RE: [External] RE: In re Kwok (No. 22-50073) - GTV & Saraca

Thank you. Jon. Thursday and Friday this week do not we can meet and confer with you on Monday or Tuesday of next week. On Monday, we are available between 9:00 am and 2:00 pm, and 6:00 pm and 6:00 pm. On Tuesday, we are available between 12:00 pm and 2:00 pm, or after 5:00 pm.

# Chelsea Scism | Associate

Morvillo Abramowitz Grand Iason & Anello PC 565 Eifth Avenue New York, NY 10017 212-880-9541 636-544-5553 (cell) cscism@maglaw.com www.maglaw.com

Morvillo Abramowitz Grand Iason & Anello PC

From: Kosciewicz, Jonathon P. <jonathonkosciewicz@paulhastings.com>

Sent: Wednesday, November 16, 2022 4:15 PM

Hi Chelsea,

Following up regarding the below. What is your availability for a meet and confer on Thursday or Friday of this week?

Thank you,

Jon

![](_page_7_Picture_3.jpeg)

From: Scism, Chelsea <cscism@maglaw.com>

Sent: Thursday, November 10, 2022 9:11 AM

To: Kosciewicz, Jonathon P. <jonathonkosciewicz@paulhastings.com>; Luft, Avi E. <aviluft@paulhastings.com>; Sutton, Ezra <ezrasutton@paulhastings.com>

Cc: Temkin, Jeremy <JTemkin@maglaw.com>; Moss, Raymond <rmoss@maglaw.com> Subject: [EXT] RE: [External] RE: In re Kwok (No. 22-50073) - GTV & Saraca

Jon,

Thank you for following up. Unfortunately, we are unavailable for a call this afternoon. However, we are in receipt of your email from Monday containing additional questions regarding the database. As we mentioned during the meet and confer, our firm was not involved in the creation of the database. As such, we are working to determine the answers to your questions, but we will need some time to do so as this involves compiling information from our database vendor and our clients. Would it work on your end to schedule a call for next week instead? Thank you.

Best, Chelsea

# Chelsea Scism | Associate

Morvillo Abramowitz Grand Iason & Anello PC 565 Fifth Avenue New York, NY 10017 212-880-9541 636-544-5553 (cell) cscism@maglaw.com www.maglaw.com

Morvillo Abramowitz Grand Iason & Anello PC

From: Kosciewicz, Jonathon P. <jonathonkosciewicz@paulhastings.com> Sent: Thursday, November 10, 2022 12:14 AM To: Scism, Chelsea <scism@maglaw.com>; Luft, Avi E. <aviluft@paulhastings.com>; Sutton, Ezra <ezrasutton@paulhastings.com>

Cc: Temkin, Jeremy <JTemkin@maglaw.com>; Moss, Raymond <rmoss@maglaw.com> Subject: RE: [External] RE: In re Kwok (No. 22-50073) - GTV & Saraca

Hi Chelsea,

Are you and Jeremey available for a call late Thursday afternoon? Any time after 4:30pm Eastern?

![](_page_7_Picture_18.jpeg)

From: Kosciewicz, Jonathon P.

Sent: Monday, November 7, 2022 9:25 AM

To: 'Scism, Chelsea' <cscism@maglaw.com>; Luft, Avi E. <aviluft@paulhastings.com>; Sutton, Ezra <ezrasutton@paulhastings.com> Cc: Temkin, Jeremy <JTemkin@maglaw.com>; Moss, Raymond <rmoss@maglaw.com> Subject: RE: [External] RE: In re Kwok (No. 22-50073) - GTV & Saraca

Hi Chelsea,

Thank you for sending this over. Can you please advise on a few follow up questions:

- i. Can you please reconcile the collection date noted in your Description of GTV & Saraca Database (January 1, 2018) and the dates of incorporation noted for both GTV Media (April 17, 2020) and Saraca Media (May 31, 2018) in each of their Responses and Objections to their Rule 2004 subpoenas? - 1. Does this mean that there are no documents prior to April 17, 2020 in the documents from the GTV custodians noted in your Description of GTV & Saraca Database? - 2. Similarly, does this mean that there are no documents prior to May 31, 2018 in the hard copy documents from Saraca noted in your Description of GTV & Saraca Database? - i. In our last meet and confer, you mentioned that both GTV and Saraca ceased business operations once the SEC investigation commenced. - 1. Can you please confirm that there are no other documents responsive to GTV's Rule 2004 subpoena following the latest collection dates noted in your Description of GTV & Saraca Database (August 25, 2020 for the electronic collections and September 10, 2020 for the hard copies)? - 2. Can you please confirm that there are no other documents responsive to Saraca's Rule 2004 subpoena following the latest collection dates noted in your Description of GTV & Saraca Database (October 5-November 24, 2020)? - 3. What were the dates of the documents of the documents "periodically obtained . . . from GTV, prior counsel for GTV, and Saraca . . . [?]" - ii. Were emails collected from Yvette Wang? - ii. Besides Aaron Mitchell, are there any other GTV or Saraca Custodians that were not collected and loaded into the SEC database? Can you provide the roles of each custodian? - 1. For example, a privilege log filed by the Debtor of documents from Baker Hostetler has the following potential GTV custodian/domain address: jessicam@gtv.org - 2. What role, if any, did Melissa Francis or Daniel Podhaskie have in either GV or Saraca? - iv. Are there any other GTV domain addresses that were not collected and loaded into the SEC database? - v. Documents obtained from Baker Hostetler show frequent discussions and collaboration regarding the SEC investigation and the New York Attorney General related to GTV and Saraca with the Debtor. Are those documents included in the database? - vi. Are there electronic documents from Saraca that were not collected and loaded into the SEC database? What are those domain addresses?

Please let us know if it would be easier to walk through on a call.

Thank you,

Jon

# Case 22-50073 Doc 1805-31 Filed 05/18/23 Entered 05/18/23 23:05:44 Page 10 of 12

From: Scism, Chelsea <cscism@maglaw.com>

Sent: Wednesday, November 2, 2022 1:24 PM

To: Kosciewicz, Jonathon P. <jonathonkosciewicz@paulhastings.com>; Luft, Avi E. <aviluft@paulhastings.com>; Sutton, Ezra <ezrasutton@paulhastings.com>

Cc: Temkin, Jeremy <JTemkin@maglaw.com>; Moss, Raymond <rmoss@maglaw.com> Subject: [EXT] RE: [External] RE: In re Kwok (No. 22-50073) - GTV & Saraca

# Hi Jon,

Please find attached a description of the GTV and Saraca Relativity database. This document has been designated "confidential" pursuant to the protective order in this case.

Best, Chelsea

### Chelsea Scism | Associate

Morvillo Abramowitz Grand Iason & Anello PC 565 Fifth Avenue New York, NY 10017 212-880-9541 636-544-5553 (cell) cscism@maglaw.com www.maglaw.com

Morvillo Abramowitz Grand Iason & Anello PC

From: Kosciewicz, Jonathon P. <jonathonkosciewicz@paulhastings.com>

Sent: Tuesday, November 1, 2022 12:01 PM

### Hi Chelsea,

I write to follow up on our meet and confer held on October 780. Were you able to compile the parameters used to create the SEC document database? As we discussed, once we review those parameters, we can propose additional parameters and search terms appropriate for your document production(s) in response to the Rule 2004 subpoena issued in this matter. Please let us know if you would like to schedule another call to discuss.

Thank you,

Jon

![](_page_9_Picture_19.jpeg)

# Case 22-50073 Doc 1805-31 Filed 05/18/23 Entered 05/18/23 23:05:44 Page 11 of 12

From: Scism, Chelsea <cscism@maglaw.com> Sent: Thursday, October 6, 2022 9:02 AM To: Kosciewicz, Jonathon P. <ionathonkosciewicz@paulhastings.com>; Luft, Avi E. <aviluft@paulhastings.com>; Sutton, Ezra <ezrasutton@paulhastings.com> Cc: Temkin, Jeremy <JTemkin@maglaw.com>; Moss, Raymond <rmoss@maglaw.com>; plinsey@npmlaw.com Subject: [EXT] RE: [External] RE: In re Kwok (No. 22-50073) - GTV & Saraca

Jon,

Jeremy and I are available for a meet and confer tomorrow, any time between 11:30 am and 4:00 pm Eastern.

Best, Chelsea

## Chelsea Scism | Associate

Morvillo Abramowitz Grand Iason & Anello PC 565 Fifth Avenue New York, NY 10017 212-880-9541 636-544-5553 (cell) cscism@maglaw.com www.maglaw.com

Morvillo Abramowitz Grand Iason & Anello PC

From: Kosciewicz, Jonathon P. <jonathonkosciewicz@paulhastings.com>

Sent: Wednesday, October 5, 2022 6:30 PM

To: Scism, Chelsea <scism@maglaw.com>; Luft, Avi E. <aviluft@paulhastings.com>; Sutton, Ezra <ezrasutton@paulhastings.com> Cc: Temkin, Jeremy <JTemkin@maglaw.com>; Moss, Raymond <moss@maglaw.com>; plinsey@npmlaw.com Subject: [External] RE: In re Kwok (No. 22-50073) - GTV & Saraca

Chelsea,

Thank you. Do you have any time tomorrow or Friday to meet and confer regarding the responses and objections?

Best,

lon Kosciewicz

From: Scism, Chelsea <cscism@maglaw.com>

Sent: Monday, October 3, 2022 5:47 PM

To: Luft, Avi E. <aviluft@paulhastings.com>; Sutton, Ezra <ezrasutton@paulhastings.com>

Cc: Temkin, Jeremy <JTemkin@maglaw.com>; Moss, Raymond <rmoss@maglaw.com>; plinsey@npmlaw.com; Kosciewicz, Jonathon P. <jonathonkosciewicz@paulhastings.com>

Subject: [EXT] In re Kwok (No. 22-50073) - GTV & Saraca

Avi and Ezra,

On behalf of GTV Media Group, Inc. and Saraca Media Group, Inc., please find attached responses and objections to the Trustee's non-party subpoenas.

Best,

Chelsea

Chelsea Scism | Associate Morvillo Abramowitz Grand Iason & Anello PC 565 Fifth Avenue New York, NY 10017 212-880-9541 636-544-5553 (cell) cscism@maglaw.com www.maglaw.com

Morvillo Abramowitz Grand Iason & Anello PC

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