Guo Wengui / Miles Guo — bankruptcy case · SUBPOENA · ECF #1805-44

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| From: | Kosciewicz, Jonathon P. | |--------------|----------------------------------------------------------------------------------------------------------------| | TO: | "Fornos. Carolina A." | | CC: | Luft Avi E .; "Akuffo_Kwame O .; Farmer Will C .; Sutton . Erra; "Patrick Linseville" .; "Allianne Baranowsky" | | Subject: | RE: G Club Rule 2004 Subpoena - Update | | Date: | Monday, May 8, 2023 10:37:20 AM | | Attachments: | image001.png |

Hi Carolina,

When we last talked on April 28, 2023, counsel to the Trustee requested that G-Club Operations begin producing documents responsive to the Trustee's Rule 2004 Subpoena on May 1, 2023. You indicated that G-Club Operations was in the process of onboarding an independent director/manager, and said that you would discuss the Rule 2004 Subpoena with the independent director early last week. You also indicated that you did not anticipate any issues with G-Club's compliance with the Rule 2004 Subpoena once the independent director was in place. You said that you would reach out to counsel to the middle of last week to further discuss a schedule to begin producing responsive documents. We have not hear from you since. Please advise whether you have discussed the Rule 2004 Subpoena with the independent director, and whether G-Club Operations can begin immediate production of responsive documents. The Trustee reserves all rights to seek assistance of the court if G-Club Operations is unable to begin immediate production.

Thank you,

Jon

Jonathon P. Kosciewicz | Associate, Litigation Department PAUL Paul Hastings LLP | 71 S. Wacker Drive, Forty-Fifth Floor, Chicago, IL 60606 | Direct: H A S T I N G S +1.312.499.6021 | Main: +1.312.499.6000 | Fax: +1.312.499.6121 | H A S T I N G S jonathonkosciewicz@paulhastings.com

From: Kosciewicz, Jonathon P.

Sent: Thursday, April 27, 2023 5:16 PM

To: 'Fornos, Carolina A.' <carolina.fornos@pillsburylaw.com>

Cc: Luft, Avi E. <aviluft@paulhastings.com>; Akuffo, Kwame.akuffo@pillsburylaw.com>; Farmer, Will C.

<willfarmer@paulhastings.com>; Sutton, Ezra <ezrasutton@paulhastings.com>; Patrick Linsey <plinsey@npmlaw.com>; Kellianne Baranowsky <kbaranowsky@gs-lawfirm.com>

Subject: RE: G Club Rule 2004 Subpoena - Update

Hi Carolina,

Do you have a few minutes to discuss tomorrow morning? I just tried calling, but you may be out of the office for the night.

Thank you,

Jon

Jonathon P. Kosciewicz | Associate, Litigation Department PAUL Paul Hastings LLP | 71 S. Wacker Drive, Forty-Fifth Floor, Chicago, IL 60606 | Direct: HASTINGS +1.312.499.6021 | Main: +1.312.499.6000 | Fax: +1.312.499.6121 | |

From: Fornos, Carolina A. <carolina.fornos@nillsburvlaw.com> Sent: Monday, April 24, 2023 6:20 PM

To: Kosciewicz, Jonathon P. <jonathonkosciewicz@paulhastings.com> Cc: Luft, Avi E. <aviluft@paulhastings.com>; Akuffo, Kwame.akuffo@pillsburylaw.com>; Farmer, Will C. <willfarmer@paulhastings.com>; Sutton, Ezra <ezrasutton@paulhastings.com>; Patrick Linsey <plinsey@npmlaw.com>; Kellianne Baranowsky <kbaranowsky@gs-lawfirm.com> Subject: [EXT] G Club Rule 2004 Subpoena - Update

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Dear Jonathon,

Hope all is well.

We wanted to provide you with an update.

As we last discussed, G Club Operations experienced significant resignations of senior managers following the recent news relating to Miles Guo. At this time, the Company is in the process of retaining an independent director/manager, and we are optimistic that this can be in place by next week. Once that takes place, we can discuss a path forward and schedule with respect to the Trustee's Rule 2004 requests, preserving all of our objections to date.

We will keep you posted.

Regards, Carolina

Carolina A. Fornos | Partner Pillsbury Winthrop Shaw Pittman LLP 31 West 52nd Street | New York, NY 10019-6131 t +1.212.858.1558 carolina.fornos@pillsburylaw.com | website bio

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