Guo Wengui / Miles Guo — bankruptcy case · ECF #1831

UNITED STATES BANKRUPTCY COURT DISTRICT OF CONNECTICUT BRIDGEPORT DIVISION

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

In re: :

HO WAN KWOK, et al., :

Debtors. : :

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Time Period: From: July 8, 2022 To: February 28, 2023 Bankruptcy Petition Filed: February 15, 2022

Date of Entry of Retention Order: August 2, 2022 [Docket

Fees: \$12,326,802.00 Voluntary Fee Reductions: Not applicable

Expense Reductions:

Fees Previously Requested (Sanctions): Retainer Request:

Expenses Previously Requested: Expense Detail: Requested Expenses: \$63,631.75 Retainer Received: Not applicable Awarded Expenses: \$63,631.75 Copies per page cost and total: \$0.08 b/w (per page) Paid Expenses: \$63,631.75 \$0.20 color (per page)

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).

Expense Reimbursement Application for the Period from July 8, 2022

No.

10/31/22 \$0.00 \$63,631.75 \$0.00 Awarded:

Paid:

Special Fee Application (Sanctions) for Services Rendered in Securing Compliance with Court-Authorized

No.

3/10/23 \$83,370.26 \$0.00 Awarded: \$83,370.26 Paid:

Total \$83,370.26 \$0.00 Awarded: \$83,370.26 Paid:

Paid:

2 This Application excludes the expense reimbursements requested in the Expense Reimbursement Application.

3 This Application includes the amounts sought in the Special Fee Application, not to recover twice but to ensure payment in the event the HK Parties (defined below) do not comply with the Sanctions Order (defined below). To be clear, Paul Hastings seeks to recover payment of the requested \$83,370.26 only once.

Case 22-50073 Doc 1831 Filed 05/30/23 Entered 05/30/23 08:41:26 Page 3 of 1334 HOURS AND RATES PER PROFESSIONAL AND PARAPROFESSIONAL

December 31, 2022 January 1, 2023 through

Bassett, Nicholas Corporate, 2007 663.10 \$1,510.00 177.90 \$1,625.00 841.00 \$1,290,368.50 Despins, Luc Corporate, 1986 551.60 \$1,860.00 174.40 \$1,975.00 726.00 \$1,370,416.00

(travel; ½ rate) Corporate, 1986 9.70 \$930.00 0.70 \$987.50 10.40 \$9,712.25 Kelly, Brian Corporate, 2001 42.90 \$1,510.00 0.00 N/A 42.90 \$64,779.00

Bongartz, Alex Corporate, 2007 574.90 \$1,510.00 266.00 \$1,625.00 840.90 \$1,300,349.00

(travel; ½ rate) Corporate, 2007 0.00 N/A 4.70 \$812.50 4.70 \$3,818.75 Luft, Avi Corporate, 2000 886.20 \$1,510.00 418.80 \$1,625.00 1,305.00 \$2,018,712.00

Ahluwalia, Sainaya Corporate 99.00 \$505.00 60.30 \$535.00 159.30 \$82,255.50 Barron, Douglass Corporate, 2012 1121.60 \$1,225.00 386.60 \$1,320.00 1,508.20 \$1,884,272.00

(travel; ½ rate) Corporate, 2012 0.00 N/A 6.60 \$660.00 6.60 \$4,356.00 Catalano, Kristin Corporate, 2021 409.70 \$775.00 221.70 \$915.00 631.40 \$520,373.00 Daly, Crispin Corporate, 2010 95.90 \$1,230.00 69.00 \$1,320.00 164.90 \$209,037.00 Farmer, Will Corporate, 2018 214.60 \$1,120.00 94.80 \$1,235.00 309.40 \$357,430.00 Ganapathi, Anuva Litigation, 2021 71.80 \$775.00 47.70 \$915.00 119.50 \$99,290.50 Koch, Leonie Corporate, 2023 82.30 \$755.00 21.50 \$855.00 103.80 \$80,519.00 Kosciewicz, Jon Litigation, 2021 488.90 \$775.00 82.30 \$915.00 571.20 \$454,202.00 Maza, Shlomo Corporate, 2012 206.20 \$1,230.00 157.20 \$1,320.00 363.40 \$461,130.00 Miliotes, Lanie Corporate, 2023 12.20 \$755.00 123.30 \$855.00 135.50 \$114,632.50 Moore, Elizabeth Litigation, 2023 0.00 N/A 18.10 \$855.00 18.10 \$15,475.50 Muncan, Izzy Corporate, 2023 22.70 \$775.00 0.00 N/A 22.70 \$17,592.50 Narang, Priya Corporate, 2020 31.70 \$840.00 0.00 N/A 31.70 \$26,628.00 Sadler, Tess Corporate, 2019 33.60 \$1,030.00 5.80 \$1,175.00 39.40 \$41,423.00 Shum, Kevin Corporate, 2014 52.20 \$1,120.00 20.10 \$1,235.00 72.30 \$83,287.50

[redacted] Corporate, 2023 20.00 \$775.00 107.80 \$815.00 127.80 \$103,357.00

1 In light of the Individual Debtor's well-documented social media intimidation campaign during these chapter 11 cases, which was, among others, also directed at Paul Hastings attorneys, Paul Hastings has redacted in this Application (and the related fee statements) the names of Mandarin-speaking attorneys. Case 22-50073 Doc 1831 Filed 05/30/23 Entered 05/30/23 08:41:26 Page 4 of 1334

December 31, 2022 January 1, 2023 through

[redacted] (travel; ½ rate) Corporate, 2023 0.00 N/A 4.50 \$407.50 4.50 \$1,833.75

2021 853.40 \$840.00 306.80 \$1,015.00 1160.20 \$1,028,258.00 [redacted] Corporate, 2022 24.10 \$775.00 33.30 \$915.00 57.40 \$49,147.00 [redacted] (travel; ½ rate) Corporate, 2022 3.40 \$387.50 0.00 N/A 3.40 \$1,317.50 [redacted] Corporate, 2021 79.30 \$775.00 27.30 \$915.00 106.60 \$86,437.00 [redacted] (travel; ½ rate) Corporate, 2021 0.70 \$387.50 0.00 N/A 0.70 \$271.25 Associate Total: 5,718.00 \$5,722,525.50

Coventry, Kirsty Real Estate, 2018 10.70 \$915.00 1.90 \$1,050.00 12.60 \$11,785.50 Other Attorney Total: 12.60 \$11,785.50

Austin, Javii Legal Research Analyst 9.70 \$365.00 1.10 \$400.00 10.80 \$3,980.50 Ecklund, Amy Technical Operations Senior Analyst 17.40 \$400.00 2.00 \$420.00 19.40 \$7,800.00 Elliott, Elizabeth Legal Research Analyst 5.10 \$400.00 9.70 \$420.00 14.80 \$6,114.00 Gore, Ian Applications Engineer 12.50 \$330.00 0.00 N/A 12.50 \$4,125.00 Kuo, Jocelyn Paralegal 0.00 N/A 171.40 \$540.00 171.40 \$92,556.00 Laskowski, Mat Paralegal 89.80 \$515.00 6.30 \$540.00 96.10 \$49,649.00 Le Blanc, Wayne E. Jr. Paralegal 127.00 \$565.00 0.00 N/A 127.00 \$71,755.00 Liu, Kelly Legal Research Analyst 22.20 \$360.00 3.80 \$400.00 26.00 \$9,512.00 Lopez, Mayra Technical Operations Senior Analyst 35.20 \$355.00 0.00 N/A 35.20 \$12,496.00 Mijares Trevor Litigation Support Analyst 11.10 \$400.00 0.00 N/A 11.10 \$4,440.00 Mohamed, David Paralegal 318.40 \$515.00 146.20 \$540.00 464.60 \$242,924.00 Mohamed, David (travel; ½ rate) Paralegal 0.00 N/A 1.50 \$270.00 1.50 \$405.00 O'Dea, Heather Legal Research Analyst 7.90 \$360.00 11.40 \$400.00 19.30 \$7,404.00 Wu, Winnie Paralegal 84.70 \$250.00 0.00 N/A 84.70 \$21,175.00 Paraprofessional Total: 1,094.40 \$534,335.50

UNITED STATES BANKRUPTCY COURT DISTRICT OF CONNECTICUT BRIDGEPORT DIVISION

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

In re: :

HO WAN KWOK, et al., :

Debtors. :

--------------------------------------------------------------- x INTERIM FEE APPLICATION OF PAUL HASTINGS LLP FOR COMPENSATION AND REIMBURSEMENT OF EXPENSES FOR PERIOD FROM JULY 8, 2022 THROUGH FEBRUARY 28, 2023

Pursuant to sections 105(a), 328, 330, and 331 of title 11 of the United States Code (the "Bankruptcy Code"), Rule 2016 of the Federal Rules of Bankruptcy Procedure (the "Bankruptcy Rules"), and Rule 2016-1 of the Local Rules of Bankruptcy Practice and Procedure of the United States Bankruptcy Court for the District of Connecticut (the "Local Rules"), Paul Hastings LLP ("Paul Hastings"), as counsel to (a) 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"), (b) Genever Holdings Corporation ("Genever (BVI)"), and (c) Genever Holdings LLC ("Genever (US)" and, together with Genever (BVI), the "Genever Debtors"), hereby files this *Interim Fee Application of Paul Hastings LLP for Compensation and Reimbursement of Expenses for the Period from July 8, 2022 through February 28, 2023* (the "Application"). By this Application, Paul Hastings requests allowance and payment of compensation for professional services

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).

performed by Paul Hastings attorneys (including the Trustee2 ) and reimbursement of its actual and necessary expenses incurred during the period from July 8, 2022 through and including February 28, 2023 (the "Fee Period"). 3 In support of this Application, Paul Hastings respectfully states as follows:

1. These chapter 11 cases likely rank among the most complex and challenging chapter 11 cases ever filed by an individual debtor. The lead debtor—Mr. Ho Wan Kwok—is at the center of a vast maze of companies and assets purportedly owned by the Individual Debtor's family members or close business associates, but who, in reality, have no financial interest in, or control over, the companies and assets they purport to own because, in reality, the Individual Debtor owns and controls these companies and assets. This maze is part of the Individual Debtor's "shell game" designed to obfuscate his true beneficial interest and control over these companies and the assets they own—all for the purpose of shielding such companies and assets from the Individual Debtor's creditors.

2. The Individual Debtor's shell game has allowed him (until his arrest by federal authorities on March 15, 2023) to enjoy all the trappings of a life of extreme luxury, including luxury yachts, private jets, luxury cars, and multi-million dollar mansions and apartments, while

2 In accordance with the Retention Order (as defined below), the Trustee is authorized to act as one of the attorneys for the Individual Debtor's estate, and, accordingly, this Application also seeks allowance of the Trustee's fees in such capacity. For the avoidance of doubt, in this Application, references to services provided by Paul Hastings attorneys shall include the Trustee. To be clear, time spent by the Trustee in his capacity as chapter 11 trustee, is not part of this Application, and compensation therefor will be sought by separate application.

3 With respect to the reimbursement of expenses, Paul Hastings only seeks reimbursement of expenses incurred from November 1, 2022 through February 28, 2023. Expenses incurred during the period from July 8, 2022 through October 31, 2022 were previously allowed by order of this Court dated April 21, 2023 [Docket No. 1693]. Case 22-50073 Doc 1831 Filed 05/30/23 Entered 05/30/23 08:41:26 Page 7 of 1334

claiming in his Schedules of Assets and Liabilities that he is essentially penniless.4 Indeed, it was against this backdrop that this Court ordered the appointment of a chapter 11 trustee to, among other things, investigate of the Individual Debtor's assets, liabilities, and financial affairs.

3. Upon the Trustee's appointment on July 8, 2022, the Trustee and Paul Hastings immediately embarked on an investigation into the financial affairs of the Individual Debtor. Given the large number of companies affiliated with the Individual Debtor, and the fact that these companies or their assets are located around the world, the Trustee's investigation was, and continues to be, extensive. To date, the Trustee's investigation has included, among other things, (a) seeking discovery under Bankruptcy Rule 2004 from hundreds of individuals and entities connected with the Individual Debtor and his various businesses, (b) analyzing thousands of documents produced in response to the Trustee's Rule 2004 subpoenas, (c) deposing several targets of the Trustee's Rule 2004 discovery, including the Individual Debtor's purported wife (i.e., Hing Chi Ngok),5 (d) interviewing former employees and business associates of the Individual Debtor (including several communications with a confidential "informant," who executed a declaration detailing the Individual Debtor's business practices), (e) seeking discovery in the British Virgin Islands ("BVI") from the registered agents of various Kwokaffiliated entities incorporated in the BVI, (f) commencing proceedings in the U.K. to request (and obtain) recognition of the Individual Debtor's chapter 11 case as a foreign main proceeding (as a portal to future proceedings in the U.K.), (g) researching property records, and (h) pursuing litigation to recover property of the estate.

4 One example of this shell game is that the Individual Debtor's son (Qiang Guo) and various entities purportedly owned by him have been funding the Individual Debtor's substantial legal expenses during these chapter 11 cases.

5 In addition, the Trustee deposed several individuals, including the Individual Debtor and Mei Guo, in connection with adversary proceedings pending in these chapter 11 cases. Case 22-50073 Doc 1831 Filed 05/30/23 Entered 05/30/23 08:41:26 Page 8 of 1334

4. While the Trustee's investigation remains ongoing, the Trustee has already succeeded in recovering, through litigation against HK International Funds Investments (USA) Limited, LLC ("HK USA") and the Individual Debtor's daughter (i.e., Mei Guo), the Lady May and the Lady May II, as well as \$33 million held in escrow pursuant to a stipulated order concerning the Lady May and approximately \$3 million in funds currently held in the repair reserve for the Lady May. Indeed, the recovery of such funds for the benefit of these estates was the result of the tireless efforts of the Trustee and Paul Hastings to identify and pursue assets of these estates. The Trustee also recently received approximately \$500,000 from the Individual Debtor's former asylum counsel (i.e., Clark Hill PLC) in connection with a settlement of estate causes of action.

5. To be clear, this is only the beginning. The Trustee has filed several additional adversary proceedings seeking to recover other assets for the benefit of these estates, including the Individual Debtor's residence in Greenwich, Connecticut [Adv. Proc. No. 23-5005] and the proceeds from the sale of the Individual Debtor's private jet [Adv. Proc. No. 23-5008]. In addition, the Trustee and the Genever Debtors have commenced adversary proceedings [consolidated under Adv. Proc. No. 23-5027] against Bravo Luck Limited ("Bravo Luck"), an entity purportedly owned by the Individual Debtor's son (i.e., Qiang Guo), challenging Bravo Luck's asserted beneficial interest in the 18th floor apartment at the Sherry Netherland Hotel (the "Sherry Netherland Apartment"), which is owned by Genever (US) (an indirect wholly-owned subsidiary of the Individual Debtor). Additional adversary proceedings will be filed in the near future, as the Trustee is focusing on additional assets that should be recovered for the benefit of these estates. In that sense, what could initially have been perceived as a \$100 to \$150 million case has now turned into a case involving assets and claims many multiples of that. For

Case 22-50073 Doc 1831 Filed 05/30/23 Entered 05/30/23 08:41:26 Page 9 of 1334

example, (i) more than 1,200 proofs of claim have been filed alleging several billions of dollars in claims, and (ii) the U.S. Department of Justice has seized more than \$800 million of cash and other assets in connection with the charges brought against the Individual Debtor.

6. While the Trustee has made substantial progress in these chapter 11 cases,

progress has been slowed by the unprecedented level of obstructionism and interference, both

inside and outside the courtroom, from the Individual Debtor and his associates at every turn.

The Trustee and Paul Hastings had to defend against this obstructionist behavior from day one,

including by preparing and prosecuting:

- The Trustee's objections to two motions filed by the Individual Debtor seeking to remove the Trustee (both of which motions were ultimately unsuccessful), as well as an appellee brief in the Individual Debtor's appeal of the order denying to vacate the appointment of the Trustee; - The Trustee's application to retain Paul Hastings as legal counsel (which application was opposed by the Individual Debtor); - The Trustee's motion seeking confirmation that the Trustee holds all economic and corporate governance rights with respect to entities owned and/or controlled by the Individual Debtor, including the Genever Debtors (which motion was opposed by the Individual Debtor); - The Trustee's motion to hold the Individual Debtor in contempt of court for failure to comply with the corporate governance order and transfer the shares in Ace Decade Holdings Limited ("Ace Decade") to the Trustee (which motion was opposed by the Individual Debtor); - The Trustee's application for recognition of the Individual Debtor's chapter 11 case in the English courts as well as related relief to access the litigation file of the Individual Debtor's former U.K. counsel with respect to the Individual Debtor's litigation against UBS AG, which application was opposed by Ace Decade (one of the Individual Debtor's co-plaintiffs in that litigation), despite the fact that the Court found that Ace Decade was owned by the Debtor; - The Trustee's motion for an order confirming that control of the Individual Debtor's privileges passed to the Trustee upon his appointment (which motion was opposed by the Individual Debtor); - The Trustee's motion to compel the Individual Debtor (who broadly pleaded the Fifth Amendment) and certain related companies (some of which never even responded to the Trustee's Rule 2004 subpoenas) to comply with the Trustee's Rule 2004 subpoenas (which motion was opposed by the Individual Debtor and certain of the related companies); - The Trustee's motions to hold the Individual Debtor and certain related companies in contempt of court for failing to comply with the Court's order requiring them to comply with the orders compelling compliance with the Trustee's Rule 2004 subpoenas (which contempt motions were opposed by the Individual Debtor and certain of the related companies); - The Trustee's and Genever Debtors' motion to compel the Debtor to stop interfering with the integrity of the claims process by threatening to expose creditors' personal information and encouraging his followers to file non-meritorious claims (which motion was opposed by the Individual Debtor); and - The addendum to the Trustee's and Genever Debtors' supplemental bar date motion to approve procedures to allow individual creditors to submit proofs of claim on a confidential basis, so as to ensure that creditors are not deterred from filing claims in the face of the Individual Debtor's social media intimidation campaign. - 7. While the Court granted substantially all of the relief requested by the Trustee

(and denied substantially all of the relief requested by the Individual Debtor), the Trustee necessarily expended substantial time and resources on these matters, including because the Individual Debtor actively opposed the relief sought by the Trustee and, in at least eight instances, appealed this Court's orders granting the relief requested by the Trustee or denying the relief requested by the Individual Debtor, as applicable. Although it is extremely difficult to determine with precision the cost of the Individual Debtors' tactics, the Trustee believes that at least 50% of the fees generated during the Fee Period were the result of the Individual Debtor's or his affiliates' non-compliance with the Bankruptcy Code and/or active opposition or interference with the Trustee's administration of these chapter 11 cases.

8. Perhaps most egregiously, beginning in mid-November 2022, the Individual Debtor instigated an extensive social media intimidation campaign directed at Trustee, his

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family, and his counsel, as well as one of the largest unsecured creditor in these case (i.e., Pacific Alliance Asia Opportunity Fund L.P. ("PAX")), the chief executive of PAX's parent company, his family, and PAX's counsel, including by disclosing home address information online and issuing threats against them personally. In addition, starting on November 20, 2022, a group of Debtor-aligned protestors began picketing at the residence of the Trustee as well as the residences of members of the Trustee's family, including his former spouse, and subsequently at the offices of counsel to the Trustee (Paul Hastings) and counsel to PAX (O'Melveny).6 In response, PAX commenced an adversary proceedings (in which the Trustee intervened) seeking a temporary restraining order and preliminary injunction against this intimidation campaign (in which relief the Trustee joined).7 The Court ultimately granted both a temporary restraining order and a preliminary injunction.

9. All the while, during the Fee Period, the Trustee and Paul Hastings provided a wide range of other chapter 11 related services, including, by way of example, handling more than thirty hearings and status conferences during the Fee Period, handling the court-ordered mediation in February 2023, preparing and prosecuting numerous substantive motions (including a supplemental bar date motion, retention applications, etc.), preparing and prosecuting a motion to transfer the chapter 11 case of Genever (US) to this Court, and preparing monthly operating reports.

6 Protestors aligned with the Individual Debtor have also picketed at the residence of family members of the chief executive of PAX's parent company.

7 As a general matter, and in the interest of minimizing fees, PAX took the lead in prosecuting this adversary proceeding, with the Trustee providing comments on (and joining in) PAX's briefs and/or filing joint motions with PAX. Nevertheless, and even though the Trustee and PAX ultimately obtained the requested injunctive relief (with certain modifications), the Individual Debtor's out-of-court antics not only delayed the administration of these chapter 11 cases, but necessarily required the Trustee to incur legal fees—including because the Individual Debtor vigorously opposed the relief sought in this adversary proceeding (including during a four-day evidentiary hearing). Case 22-50073 Doc 1831 Filed 05/30/23 Entered 05/30/23 08:41:26 Page 12 of 1334

10. The above summary also illustrates another important consideration in evaluating the reasonableness of Paul Hastings' fees and expenses, namely the "undesirability" of this particular engagement. Not only have the Individual Debtor's in-court and out-of-court actions increased the cost of, and delayed, the administration of these estates, but the Trustee and Paul Hastings attorneys have been harassed by the Individual Debtors' followers, with the Trustee even receiving death threats. While the Trustee and Paul Hastings will not be intimidated by these actions, they did require Paul Hastings to incur, among other expenses, hundreds of thousands of dollars in cyber security measures. To be clear, Paul Hastings is not seeking reimbursement of these expenses in this Application.

11. Moreover, Paul Hastings took on this engagement on what is essentially a contingency basis, with its fees and expenses only to get paid if and to the extent that the Trustee recovers and monetizes assets for the benefit of these chapter 11 estates. In other words, Paul Hastings took on not only the risk that assets may not be recovered, but also that the proceeds from the sale of such assets may not be sufficient to pay professional fees. Thus, in effect, Paul Hastings funded these chapter 11 cases, which, on its own, provided substantial benefits to these estates.8 For all these reason, Paul Hastings waited to file this Application until after the Trustee had recovered resources sufficient to pay the fees and expenses requested in this Application. Paul Hastings also notes that the period covered by the Application (essentially eight months) is longer than in a typical case—which, again, is a function of Paul Hastings having waited with filing this Application until sufficient assets had been recovered by the Trustee.

12. As detailed in this Application, Paul Hastings has performed all of its services in an economic, effective, and efficient manner commensurate with the complexity and importance

8 Absent such funding, the Trustee would have had to obtain litigation funding from a third-party, who would likely charge a fee equal to two to four times the amount funded. Case 22-50073 Doc 1831 Filed 05/30/23 Entered 05/30/23 08:41:26 Page 13 of 1334

of the issues involved. The work performed by Paul Hastings was carefully assigned to appropriate professionals or paraprofessionals according to the experience and level of expertise required for each particular task. Whenever possible, Paul Hastings sought to minimize the costs of Paul Hastings' services by utilizing talented junior attorneys and paraprofessionals to handle the more routine aspects of the assignments and by delegating, to the extent practicable, workstreams to local Connecticut counsel (which has a lower rate structure than Paul Hastings).

13. To further minimize the costs of intra-Paul Hastings communications and education about these chapter 11 cases, the Trustee utilized a small group of Paul Hastings attorneys for the majority of the work in these chapter 11 cases. Also, as a general matter, in addition to the Trustee, no more than two Paul Hastings attorneys attended the various hearings held during the Fee Period (and in many instances, the Trustee handled hearings without attendance of any Paul Hastings attorneys), thereby minimizing not only the time billed on these hearings/sessions but also the cost of travel. Furthermore, to the extent appropriate, the Trustee and Paul Hastings sought to work closely with counsel to PAX, including to take advantage of the knowledge of the Individual Debtor's assets and financial affairs that PAX acquired during the prepetition litigation against the Individual Debtor in New York state court (the "PAX Litigation"). Moreover, as noted on the record at the August 2, 2022 hearing on Paul Hastings' retention application, the Trustee has agreed not to seek a percentage recovery under section 326 of the Bankruptcy Code, and, instead, agreed that he would only be compensated (at his standard hourly rate) for his time.

14. Finally, as an accommodation to these estates and to minimize the review process by the Court and parties in interest, Paul Hastings is not seeking allowance or payment at this time for the fees (a) of fourteen (14) timekeepers who billed less than ten (10) hours during the

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Fee Period in the aggregate amount of \$55,980.00. The time billed by these timekeepers was reasonable, and Paul Hastings reserves the right to seek allowance of these fees based on the facts and circumstances of these cases, including, without limitation, if objections are interposed to the allowance of Paul Hastings' fees and expenses.

15. In sum, Paul Hastings respectfully submits that the services for which it seeks compensation in this Application were necessary for and beneficial to these chapter 11 estates and their stakeholders. Accordingly, in light of the nature and complexity of these chapter 11 cases, Paul Hastings' charges for professional services performed and expenses incurred are reasonable under applicable standards. For all these reasons, Paul Hastings respectfully requests that the Court grant the Application and allow interim compensation for professional services performed and reimbursement for expenses as requested. JURISDICTION, VENUE, BASES FOR RELIEF, AND COMPLIANCE

16. The Court has jurisdiction over this matter pursuant to 28 U.S.C. §§ 157 and 1334 and the Standing Order of Reference from the United States District Court for the District of Connecticut (as amended). This matter is a core proceeding within the meaning of 28 U.S.C. § 157(b)(2). Venue is proper pursuant to 28 U.S.C. §§ 1408 and 1409.

17. The legal predicates for the relief requested herein are sections 328, 330, and 331 of the Bankruptcy Code, Bankruptcy Rule 2016, and Local Rule 2016-1.9

18. Paul Hastings believes that this Application, together with the attachments hereto, substantially complies with the Bankruptcy Rules, Local Rule 2016-1, and the *United States Trustee's Guidelines for Reviewing Applications for Compensation and Reimbursement of Expenses Filed Under 11 U.S.C. § 330 by Attorneys in Larger Chapter 11 Cases* (the "U.S.

9 At this time, no interim compensation procedures have been approved by the Court.

Trustee Guidelines").10 Paul Hastings respectfully requests a waiver of any of the foregoing

requirements not met by this Application.

- 19. Attached and incorporated herein by reference are the following Exhibits: - Exhibit A contains disclosures regarding "customary and comparable compensation." - Exhibit B1 contains a summary of Paul Hastings' timekeepers included in this Application. - Exhibit B2 contains a summary of Paul Hastings' timekeepers that billed less than ten (10) hours during the Fee Period and for which Paul Hastings is not seeking allowance or payment at this time. - Exhibit C contains a summary of the compensation requested by project category. - Exhibit D contains the expense reimbursements requested by category. - Exhibit E contains the monthly statements of Paul Hastings detailing the services performed and itemizing the expenses incurred during the Fee Period. - Exhibit F contains the Proposed Order.

20. On February 15, 2022 (the "Petition Date"), the Individual Debtor filed with the

Court a voluntary petition for relief under chapter 11 of the Bankruptcy Code.

21. On March 21, 2022, the United States Trustee appointed an Official Committee of

Unsecured Creditors ("Committee") in the Individual Debtor's chapter 11 case. No examiner

has been appointed in the Individual Debtor's chapter 11 case.

22. On June 15, 2022, the Court entered a memorandum of decision and order

[Docket No. 465] (the "Trustee Order") directing the United States Trustee to appoint a chapter

10 Paul Hastings reserves all rights as to the relevance and substantive legal effect of the U.S. Trustee Guidelines with respect to any application for compensation in these chapter 11 cases. Case 22-50073 Doc 1831 Filed 05/30/23 Entered 05/30/23 08:41:26 Page 16 of 1334

11 trustee in the chapter 11 case of Ho Wan Kwok. Pursuant to the Trustee Order, the United States Trustee selected Luc A. Despins as the Trustee. On July 8, 2022, the Court entered an order granting the appointment of Luc A. Despins as the Trustee in the chapter 11 case of Ho Wan Kwok.

23. The Court authorized Paul Hastings' retention as attorneys for the Trustee pursuant to the *Order Authorizing and Approving the Retention and Employment of Paul Hastings LLP as Counsel to Chapter 11 Trustee, effective as of July 8, 2022* [Docket No. 668] (the "Retention Order"), entered on August 2, 2022. The Retention Order authorizes Paul Hastings to be compensated on an hourly basis and reimbursed for actual and necessary out-ofpocket expenses pursuant to sections 328 and 330 of the Bankruptcy Code, the Bankruptcy Rules, the Local Rules, and such orders as the Court may direct. Moreover, at the August 1, 2022 hearing on the Paul Hastings' retention application, the Court made clear that it approved Paul Hastings' New York rate structure.11 In addition, as noted on the record at that hearing, the Trustee has agreed not to seek a percentage recovery under section 326 of the Bankruptcy Code, and, instead, agreed that he would only be compensated (at his standard hourly rate) for his time.

24. In light of the Trustee's ongoing investigation into the Individual Debtor's assets and his financial affairs, the Trustee is unable at this time to predict when he will be in a position to file a plan and disclosure statement. All quarterly fees have been paid to the United States Trustee, and all monthly operating reports have been filed through March 2023.

11 See Aug. 1, 2022 H'rg Tr. at 113:15-19 ("MR. DESPINS: But I want to be clear is that that's not going to be a back door way to bring local rates, or anything like that -- THE COURT: No, I'm not doing that. I agree with that.") Case 22-50073 Doc 1831 Filed 05/30/23 Entered 05/30/23 08:41:26 Page 17 of 1334

25. At this time, the amount of cash in the Trustee's account is approximately \$3.5 million.12 The Trustee is not aware of any material administrative expense claims other than claims for professional fees and expenses.

26. On October 11, 2022, Genever Holdings Corporation ("Genever (BVI)")—an entity wholly owned by the Individual Debtor—filed a voluntary petition for relief under chapter 11 of the Bankruptcy Code with this Court.

27. No trustee or official committee of unsecured creditors has been appointed in Genever (BVI)'s chapter 11 case.

28. October 14, 2022, the Court entered an order granting joint administration of the Individual Debtor's chapter 11 case and Genever (BVI)'s chapter 11 case [Docket No. 970].

29. On January 24, 2023, the Court granted Genever (BVI)'s application to retain Paul Hastings as counsel to Genever (BVI) in its chapter 11 case, effective as of its petition date, i.e., October 11, 2022 [Docket No. 1376].

30. On October 12, 2020, Genever Holdings LLC—an entity wholly owned by Genever (BVI)—filed a voluntary petition for relief under chapter 11 of title 11 of the United States Code in the United States Bankruptcy Court for the Southern District of New York (the "SDNY Bankruptcy Court"), thereby commencing case number 20-12411 (JLG) (the "SDNY Bankruptcy Case").

12 This amount consists of (a) \$562,174.08 in the Trustee's account without taking into account the Court's ruling that HK USA's property is property of the Individual Debtor's estate [Docket No. 221 in Adv. Proc. No. 22- 5003] (the "Alter Ego Decision") and (b) \$3,014,050.91 in the repair reserve, which, pursuant to the Alter Ego Decision is now property of the Individual Debtor's estate. The Alter Ego Decision also found that, in addition, \$33 million held in escrow with U.S. Bank, N.A., are also property of the Individual Debtor's estate. The Trustee is currently seeking the transfer of these funds into his account. Case 22-50073 Doc 1831 Filed 05/30/23 Entered 05/30/23 08:41:26 Page 18 of 1334

31. On November 3, 2022, the SDNY Bankruptcy Court entered an order [Docket No. 225 in Case No. 22-50592] transferring the venue of the SDNY Bankruptcy Case to this Court, which assigned it Case Number 22-50592.

32. On November 21, 2022, the Court entered an order granting joint administration of the Genever (US) Debtor's chapter 11 case with the jointly administered cases of the Individual Debtor and the Genever (BVI) Debtor's chapter 11 case [Docket No. 1141].

33. On January 24, 2023, the Court granted Genever (US)'s application to retain Paul Hastings as counsel to Genever (US) in its chapter 11 case, effective as of the order transferring venue of the SDNY Bankruptcy Case to this Court, i.e., November 3, 2022 [Docket No. 1376].

34. By this Application, the Trustee and Paul Hastings request allowance and

payment of fees (in the amount of \$12,675,615.54) and expenses incurred (in the amount of

\$348,813.54) for services rendered by, for, and on behalf of the Trustee during the Fee Period.13

The Trustee has approved the amounts requested by Paul Hastings herein.

35. To date, the Trustee and Paul Hastings have submitted two fee/expense-related applications in these chapter 11 cases, as detailed below.

(a) On March 1, 2023, Paul Hastings submitted the *First Interim Application of Chapter 11 Trustee and his Counsel, Paul Hastings LLP, for Reimbursement of Expenses for the Period from July 8, 2022 through October 31, 2022* [Docket No. 1495] (the "Expense Reimbursement Application"), whereby the Trustee and Paul Hastings requested reimbursement of the actual and necessary expenses incurred

13 As an accommodation to these estates and to minimize the review process by the Court and parties in interest, Paul Hastings is not seeking allowance or payment at this time for the fees (a) of fourteen (14) timekeepers who billed less than ten (10) hours during the Fee Period in the aggregate amount of \$55,980.00. The time billed by these timekeepers was reasonable, and Paul Hastings reserves the right to seek allowance of these fees based on the facts and circumstances of these cases, including, without limitation, if objections are interposed to the allowance of Paul Hastings' fees and expenses.

Case 22-50073 Doc 1831 Filed 05/30/23 Entered 05/30/23 08:41:26 Page 19 of 1334

> by the Trustee and Paul Hastings during the period from July 8, 2022 through October 31, 2022 in the amount of \$63,631.75. On May 3, 2023, the Court entered an order granting the Expense Reimbursement Application [Docket No. 1747] (the "Expense Reimbursement Order"). The Individual Debtor's estate paid the foregoing amount on May 8, 2023. This Application excludes the expense reimbursements approved in the Expense Reimbursement Order.

- (b) On April 10, 2023, Paul Hastings submitted the *Special Fee Application of Chapter 11 Trustee and his Counsel, Paul Hastings LLP, for Services Rendered in Securing Compliance with Court-Authorized Subpoenas* [Docket No. 1648] (the "Special Fee Application"). In the Special Fee Application, Paul Hastings requested allowance and payment of fees in the amount of \$83,370.26 in accordance with the Contempt Order.14 On April 21, 2023, the Court approved the Special Fee Application and ordered the HK Parties to remit payment of \$83,370.26 to the chapter 11 estate of the Individual Debtor [Docket No. 1693] (the "Sanctions Order"). As of the filing of this Application, the HK Parties have not remitted payment. This Application includes the amount requested in the Special Fee Application. However, to the extent the Trustee is able to recover the fees under the Sanctions Order from the HK Parties, Paul Hastings will not seek payment of such fees from these estates.15 - 36. Neither the Trustee nor Paul Hastings has received any payment or promise of

payment from any source for services rendered during these chapter 11 cases. There is no agreement or understanding between the Trustee and/or Paul Hastings and any other person other than the attorneys, employees, and staff of Paul Hastings, for the sharing of compensation to be received for services rendered in these chapter 11 cases.

14 On March 10, 2023, the Court entered the *Order Holding HK Parties in Contempt of Court and Sanctioning HK Parties, Attorney Vartan and Chiesa Shahinian & Giantomasi PC* [Docket No. 1537] (the "HK Parties Contempt Order"), pursuant to which the Court ordered Ms. Mei Guo, HK USA, attorney Lee Vartan, and Chiesa Shahinian & Giantomasi PC (collectively, the "HK Parties"), jointly and severally, to compensate the Trustee and his counsel, Paul Hastings, for reasonable attorneys' fees and expenses associated with the Trustee's efforts to secure compliance with certain Court-authorized subpoenas.

15 At this time, the HK Parties have not paid the amounts due under the Sanctions Order (even though such amounts were due on May 5, 2023. Indeed, the HK Parties have (unsuccessfully) sought reconsideration of the Sanctions Order [Docket Nos. 1730 and 1733] and, thereafter, appealed both the Sanctions Order and the order denying reconsideration [Docket No. 1750], as well as sought a stay pending appeal [Docket No. 1770]. That request for a stay was denied by order dated May 15, 2023 [Docket No. 1791]. Case 22-50073 Doc 1831 Filed 05/30/23 Entered 05/30/23 08:41:26 Page 20 of 1334

37. Paul Hastings' professional services during the Fee Period required an aggregate expenditure of 10,665.70 recorded hours by attorneys and paraprofessionals, broken down as follows: partners (1,630.40 hours), of counsel (2,162.20 hours), associates (5,601.80 hours), other attorneys (18.90 hours), and paraprofessionals (1,252.40 hours). The timekeepers who rendered such services are identified in the Cover Sheet hereto, along with the number of hours and the total compensation sought for each individual.

38. Paul Hastings maintains computerized records, in the form of monthly statements, of the time spent by all Paul Hastings' attorneys and paraprofessionals in connection with its representation of the Trustee and the Genever Debtors. With the exception of the monthly statements submitted with the Special Fee Application,16 the monthly statements are in the same form regularly used by Paul Hastings to bill its clients for services rendered and include the date that the services were rendered, a detailed, contemporaneous narrative description of the services provided, the amount of time spent for each service, and the designation of the professional who performed the service. Attached hereto as Exhibit E are true and correct copies of the monthly statements of Paul Hastings related to the fees requested herein.

39. The rates Paul Hastings charges for the services rendered by its professionals and paraprofessionals in these chapter 11 cases are comparable to the rates Paul Hastings charges for professional and paraprofessional services rendered in comparable non-bankruptcy related matters. In addition, when Paul Hastings' restructuring professionals and paraprofessionals work on non-bankruptcy matters, the firm generally charges their standard rate. Such fees are reasonable based on the customary compensation charged by comparably skilled practitioners in comparable non-bankruptcy cases in a competitive national legal market.

16 As noted in the Special Fee Application, Paul Hastings' monthly statements for fees incurred in securing compliance with the Court-authorized subpoenas are limited to those services and, thus, vary in form from that regularly used by Paul Hastings to bill its clients for services rendered. Case 22-50073 Doc 1831 Filed 05/30/23 Entered 05/30/23 08:41:26 Page 21 of 1334

40. Paul Hastings respectfully submits that the reasonable value of the services rendered by Paul Hastings (including the Trustee) during the Fee Period is \$12,326,802.00.

41. During the Fee Period, Paul Hastings assisted and advised the Trustee and the Genever Debtors on a regular basis regarding legal matters relating to these chapter 11 cases and the pursuit and recovery of estate assets for the benefit of the chapter 11 estates and their creditors. In addition, Paul Hastings prepared various motions, applications, proposed orders, and other pleadings submitted to the Court for consideration, and performed the necessary professional services that are described below and in the fee statements attached hereto and incorporated herein by reference.17

42. For ease of reference and transparency purposes, Paul Hastings created several matter numbers for their services in these chapter 11 cases, as follows:

00001 General Chapter 11 Trustee Representation 00002 Asset Recovery Investigation and Litigation

43. Additionally, the Trustee and the Genever Debtors retained Neubert Pepe & Monteith, P.C. ("NPM") as their local and conflicts counsel in order to provide services to the Trustee and the Genever Debtor's estates in a cost-effective manner. In particular, as detailed in

17 The description of services in this Application is limited to those matters in which Paul Hastings provided ten (10) or more hours of service during the Fee Period.

18 Not included as part of this Application.

the NPM retention application and related declarations, Paul Hastings and NPM have coordinated and will continue to coordinate each firm's respective responsibilities in connection with the representation of the Trustee and the Genever Debtors. Among other things, during the Fee Period, the following matters were delegated to NPM:

- Assisting with filings and service of pleadings in the main chapter 11 case and related adversary proceedings; - Preparing supplemental motion for discovery under Bankruptcy Rule 2004 (including for discovery targets for which Paul Hastings is conflicted), conducting meet and confers with discovery targets, and reviewing documents produced in response to Rule 2004 subpoenas; - Assisting the Trustee on matters on which Paul Hastings is conflicted, including the UBS litigation in the English courts; - Preparing run-of-the-mill procedural motions, including motion to seal, motions to expedite, and motions to adjourn; - Advising the Trustee and the Genever Debtors on matters related to local Connecticut rules; - Preparing monthly operating reports for the Genever Debtors; and - Performing a variety of case administration functions, including interacting with the Court and the clerks' office as needed, preparing certificates of service, coordinating logistics for hearings, and handling other case administration functions as they arise from time to time. I. General Chapter 11 Trustee Representation (Matter ID 00001)

- A. Case Administration (Task Code B110) Fees: \$467,539.00 Total Hours: 395.40 - 44. During the Fee Period, Paul Hastings attorneys handled numerous case

administrative matters in connection with these chapter 11 cases, including (a) developing short-

term and long-term strategies for recovering assets for the benefit of these estates, (b)

maintaining a case calendar and task lists of open matters and work streams, (c) handling various

logistical matters (including as it relates to the Trustee's surety bond and bank account), and (d) Case 22-50073 Doc 1831 Filed 05/30/23 Entered 05/30/23 08:41:26 Page 23 of 1334

handling numerous calls and correspondence with the U.S. Trustee and PAX regarding the background to, and the administration of, these chapter 11 cases.

45. Other tasks recorded under Task Code B110 included (a) analyzing legal issues related to the management of these chapter 11 cases, including research with respect to the Individual Debtor's standing to oppose relief requested by the Trustee, (b) preparing the chapter 11 filing of Genever (BVI), including communications with NPM regarding the preparation for its chapter 11 filing, and (c) internal team meetings and calls to coordinate work streams.

B. Pleadings Review (Task Code B113) Fees: \$94,312.00 Total Hours: 178.90

46. During the Fee Period, Paul Hastings attorneys reviewed and monitored the docket of these chapter 11 cases, the related adversary proceedings, and pending state court litigation, as well as reviewed pleadings filed therein, as necessary.

- C. Court Hearings (Task Code B155) Fees: \$403,231.00 Total Hours: 275.4 - 47. During the Fee Period, Paul Hastings attorneys prepared for and attended

numerous hearings and status conferences related to general case administration matters,

- the July 8, 2022 hearing on the U.S. Trustee's application to appoint Mr. Luc A. Despins as the Trustee; - the July 21, 2022 status conference; - the August 1, 2022 hearing on, among other things, (a) the Trustee's application to retain Paul Hastings LLP, (b) the Trustee's corporate governance motion, and (c) the Individual Debtors' motion to vacate the appointment of the Trustee;

19 Depending on the matters covered at a particular hearing, the corresponding time entries were recorded under different matter numbers. For example, hearings related to the Rule 2004 investigation were generally recorded under Matter ID 00002.

- the August 4, 2022 hearing on, among other things, the Trustee's corporate governance motion; - the August 12, 2022 status conference; - the August 30, 2022 hearing on, among other things, (a) the Trustee's motion for an order providing that control of privileges passed to the Trustee upon his appointment and (b) the Individual Debtor's motion for a stay pending his appeal of the corporate governance order; - the September 6, 2022 status conference; - the September 12, 2022 status conference; - the September 27, 2022 status conference and hearing on, among other things, the Trustee's application to retain Harney Westwood & Riegels LP ("Harneys Legal"); - the November 16, 2022 hearing on, among other things, the Trustee and the Genever Debtors' motion to establish a bar date in these chapter 11 cases; - the November 21, 2022 status conference; - the December 13, 2022 hearing on the Trustee's application to retain Paul Wright as U.K. barrister in connection with the Trustee's motion to recognize the Individual Debtor's chapter 11 case in the English courts as a foreign main proceeding; - the January 3, 2023 hearing on, among other things, (a) the supplemental motion to establish a bar date in these chapter 11 cases, (b) the application to retain Epiq Corporate Restructuring, LLC ("Epiq") as claims agent, (c) the application to retain Engineering Operations and Certification Services, LLC ("EOCS") as inspector for the Lady May, and (d) HK USA's motion to modify the Repair Reserve Order (as defined below); - the January 24, 2023 hearing on, among other things, the Genever Debtors' application to employ Paul Hastings as counsel; - the January 26, 2023 hearing on, among other things, the Motion to compel the Individual Debtor to comply with the Preliminary Injunction (as defined below) as it relates to the claims process; and - the January 31, 2023 hearing on, among other things, Genever (US)'s motion to further extend the sale process for the Sherry Netherland Apartment. Case 22-50073 Doc 1831 Filed 05/30/23 Entered 05/30/23 08:41:26 Page 25 of 1334

48. In connection with the status conferences, Paul Hastings attorneys also prepared several PowerPoint presentations, which were shared with the Court and parties in interest at the status conferences. D. Fee / Employment Applications for Paul Hastings (Task Code B160) Fees: \$162,258.00 Total Hours: 129.30

49. During the Fee Period, Paul Hastings attorneys prepared the Trustee's application to retain, effective as of July 8, 2022, Paul Hastings as counsel to the Trustee (including a reply in response to the Individual Debtor's objection to that application) [Docket Nos. 539 and 634], which application was granted on August 2, 2022 [Docket No. 668]. In connection with Paul Hastings' retention, Paul Hastings attorneys also prepared four supplemental declarations with respect to the Trustee's and Paul Hastings' disinterestedness [Docket Nos. 538, 633, 802, and 1435] and conducted related research to identify possible connections between the Trustee and Paul Hastings, on the one hand, and parties in interest in these chapter 11 cases, on the other hand. In addition, Paul Hastings attorneys prepared Paul Hastings' monthly fee statements, Paul Hastings' notice of hourly rate change [Docket No. 1251], and Paul Hastings' expense reimbursement application [Docket No. 1495] (which application was granted on May 3, 2023 [Docket No. 1747]).

50. During the Fee Period, Paul Hastings attorneys assisted NPM in the preparation of its application to be retained as local Connecticut counsel to the Trustee [Docket No. 569]. Paul Hastings attorneys also prepared retention applications of various other estate professionals, including (a) Harneys Legal, as British Virgin Islands counsel [Docket No. 1807], (b) Paul Wright, as U.K. barrister [Docket No. 1183], (c) Epiq, as claims agent [Docket No. 1198], (d) E. Fee / Employment Applications for Other Professionals (Task Code B165) Fees: \$107,070.00 Total Hours: 88.90 Case 22-50073 Doc 1831 Filed 05/30/23 Entered 05/30/23 08:41:26 Page 26 of 1334

EOCS, as inspector for Lady May [Docket No. 1212], and (e) Pallas Partners LLP ("Pallas"), as U.K. solicitors in connection with the UBS Litigation (as defined below) [Docket No. 1496], all of which applications were granted by the Court.

51. In addition, during the Fee Period, Paul Hastings attorneys handled various other retention-related issues, including (a) analyzing issues related to Brown Rudnick's motion to withdraw as counsel to the Individual Debtor [Docket No. 543], (b) preparing a supplemental statement regarding Epiq's relationship with Xclaim [Docket No. 1283], and (c) resolving the objection filed by HK USA to the EOCS invoice [Docket No. 1341].

F. Other Contested Matters (Task Code B190) Fees: \$247,054.50 Total Hours: 209.40

52. During the Fee Period, Paul Hastings attorneys handled a range of complex contested matters arising, in many instances, from motions and objections filed by the Individual Debtor and his affiliates seeking to oppose the Trustee's efforts to recover assets for the benefit of these estates.

53. Most notably, Paul Hastings prepared objections to, and defended against, the Individual Debtor's repeated efforts to remove the Trustee—initially the Individual Debtor's motion seeking to vacate the order appointing the Trustee (which motion this Court denied [Docket No. 667]) and, later, his motion to remove the Trustee under section 324 of the Bankruptcy Code (which the Individual Debtor withdrew on April 5, 2023 [Docket No. 1635]). See Docket Nos. 575 and 1326

54. Even though the Individual Debtor's efforts to remove the Trustee were unsuccessful, the Trustee and Paul Hastings were forced to expend significant time to defend against these frivolous motions. In addition, Paul Hastings attorneys prepared an appellee brief in the Individual Debtor's appeal of the order denying his motion to vacate the order appointing

Case 22-50073 Doc 1831 Filed 05/30/23 Entered 05/30/23 08:41:26 Page 27 of 1334

the Trustee [Docket No. 24 in Case No. 22-1019 (D. Conn.)] and conducted related legal research. 20

G. Non-Working Travel (Task Code B195) [billed at ½ rate] Fees: \$13,531.00 Total Hours: 15.10

55. During the Fee Period, Paul Hastings attorneys travelled to and from the

bankruptcy courthouse in Bridgeport, Connecticut.

- H. Financial Reports (Monthly Operating Reports) (Task Code B211) Fees: \$28,615.00 Total Hours: 26.60 - 56. During the Fee Period, Paul Hastings attorneys prepared the monthly operating

reports in the Individual Debtor's chapter 11 case. In the interest of minimizing costs, the monthly operating reports for the Genever Debtors were prepared by NPM (and any time spent by Paul Hastings attorneys reviewing and commenting such reports was recorded under Matter ID 10 (for Genever (US)) and 11 (for Genever (BVI)).

I. Claims Administration and Objections (Task Code B310) Fees: \$463,889.00 Total Hours: 382.10

57. During the Fee Period, Paul Hastings attorneys prepared and filed a supplemental motion seeking to establish a bar date in these chapter 11 cases. While the Individual Debtor had filed a bar date motion prior to the Trustee's appointment, no bar date order had been established at the time of the Trustee's appointment.21

58. In particular, on November 8, 2023, the Trustee and the Genever Debtors filed

their supplemental motion requesting establishment of bar dates to file proofs of claim in these

20 Following completion of appellate briefing, the District Court entered a scheduling order indicating that it viewed the appeal as moot because, among other things, the denial of the motion to vacate did not preclude the Individual Debtor from separately seeking to remove the Trustee under section 324 of the Bankruptcy Code, conducting discovery, or presenting evidence and arguments at a hearing before this Court. See Docket No. 27 in Case No. 22-1019 (D. Conn.).

21 The United States Bankruptcy Court for the Southern District of New York had previously set a bar date in Genever (US)'s chapter 11 case for March 10, 2021 [Docket No. 46 in Case No. 20-12411 (JLG)]. Case 22-50073 Doc 1831 Filed 05/30/23 Entered 05/30/23 08:41:26 Page 28 of 1334

chapter 11 cases [Docket No. 1072] (the "Supplemental Bar Date Motion"). As the Trustee had previewed with the Court prior to the filing of the Supplemental Bar Date Motion, the Trustee had deferred seeking entry of a bar date order until after venue of the Genever (US)'s chapter 11 case had been transferred from the Southern District of New York to this Court, so that a single general bar date could be established in these chapter 11 cases. This was necessary because creditors of the Individual Debtor (other than PAX) did not receive notice of the bar date in the Genever (US) case (which bar date had passed in March 2021), and, thus, absent relief from this Court, would have been barred from asserting any potential alter ego claims against Genever (US).

59. Following the hearing on the Supplemental Bar Date Motion on November 16, 2022 (at which the Court granted the Supplemental Bar Date Motion), the Trustee filed a notice [Docket No. 1138] advising the Court that he would submit a further revised proposed bar date order that would allow individual creditors to file claims on a confidential basis, i.e., without disclosing name and contact information on the public claims register. As detailed in the Trustee's and the Genever Debtors' addendum to the Supplemental Bar Date Motion filed on December 2, 2022 [Docket No. 1191], the Individual Debtor's harassment campaign against the Trustee and the Individual Debtor's largest unsecured creditor (i.e., PAX) beginning in mid-November 202222 raised the specter that creditors would be deterred from filing claims out of a concern that they would be similarly harassed. These concerns proved to be more than justified. In fact, after the bar date order had been entered on January 5, 2023 [Docket No. 1297] (the "Bar Date Order"), the Individual Debtor and his associates posted, among other things, personal

22 For further discussion on the Individual Debtors' social media attacks and the related picketing, please see the summary of Matter ID 00003 below. Case 22-50073 Doc 1831 Filed 05/30/23 Entered 05/30/23 08:41:26 Page 29 of 1334

information of creditors online23 and/or threatened to expose personal information of creditors, all in an apparent effort to intimidate creditors from filing claims.

60. Following entry of the Bar Date Order, Paul Hastings attorneys (a) coordinated service of the bar date notice by Epiq, (b) coordinated the publication of the bar date notice, (c) responded to creditor inquiries regarding the process for submitting proofs of claim (including as it related to the confidentiality restrictions), (d) reviewed Epiq's redactions of confidential proofs of claim, and (e) conducted an initial, high-level analysis of the filed proofs of claim. Furthermore, during February 2023, Paul Hastings attorneys began preparing the objection to the proof of claim filed by the Individual Debtor's son (i.e., Qiang Guo), which objection was filed on March 31, 2023 [Docket No. 251 in Case No. 22-50592].

61. Moreover, even though the Preliminary Injunction (as defined below) enjoined the Individual Debtor and related parties "from interfering in any way with the integrity of his Chapter 11 case," the Individual Debtor (and persons associated with the Individual Debtor) used his social media presence and his network of followers to (a) harass creditors who have filed proofs of claim in these chapter 11 cases and (b) encourage his followers to file non-meritorious proofs of claim in these chapter 11 cases. In response to these developments, Paul Hastings attorneys prepared and filed the Trustee's motion [Docket No. 1345] (the "Motion to Compel Compliance with Preliminary Injunction") seeking, among other things, to compel the Individual Debtor (and anyone in active concert or participation with the Individual Debtor) to comply with the terms of the Preliminary Injunction (as defined below) and immediately cease all out-of-court and in-court activities interfering with the claims process, including any attempts to intimidate creditors into not filing claims (including by publishing creditors' personal information on social

23 The creditor in question had not opted to treat her information confidentially. Case 22-50073 Doc 1831 Filed 05/30/23 Entered 05/30/23 08:41:26 Page 30 of 1334

media) or in any way suggesting to the Individual Debtor's followers that they should file nonmeritorious claims. 24 In addition to the motion, Paul Hastings attorneys prepared a reply [Docket No. 1388] in response to the objection filed by the Individual Debtor as well as a statement [Docket No. 1418] providing additional evidence of the Individual Debtor's attempts to interfere with the claims process.25

62. Finally, Paul Hastings attorneys prepared a motion seeking to authorize Epiq to exclude all attachments from confidential proofs of claim (as opposed to redacting personal information on those claims) [Docket No. 1469]—as opposed to redacting personal information of individual creditors in such attachments. While Epiq and Paul Hastings attorneys initially reviewed confidential proofs of claims for necessary redactions, it became clear during this process that, in light of the sheer number of claims filed, redacting claims (including, in many instances, hundreds of pages of attachments) would have cost these estates hundreds of thousands of dollars, while removing the attachments from confidential proofs of claim to be uploaded to the claims register could be accomplished at only a fraction of that cost. The Court granted the motion by order dated February 28, 2023 [Docket No. 1486].

J. Restructurings (Task Code B420) Fees: \$118,425.50 Total Hours: 74.80

63. During the Fee Period, Paul Hastings attorneys participated in the mediation pursuant to the Court's order, dated January 24, 2023 [Docket No. 1373]. During the mediation, the Trustee and Paul Hastings attorneys participated in various conferences with the mediator (Bankruptcy Judge James J. Tancredi), as well as discussions with counsel to PAX and counsel

24 The Motion to Compel Compliance with Preliminary Injunction also sought to quash the Individual Debtors' three objections to proofs of claim.

25 As of the date of this Application, the Court has not ruled on the Motion to Compel Compliance with Preliminary Injunction, except that the Court overruled the Individual Debtor's three claim objections [Docket No. 1399]. Case 22-50073 Doc 1831 Filed 05/30/23 Entered 05/30/23 08:41:26 Page 31 of 1334

to the Individual Debtor. Moreover, in preparation for mediation sessions, Paul Hastings attorneys prepared numerous materials for the mediator, including a detailed presentation on the Individual Debtor's network of shell companies, business associates, and immediate family members.

64. Unfortunately, as the mediator reported on February 22, 2023 [Docket No. 1479], the mediation ended in an impasse after several meetings, discussions, and conference calls. II. Asset Recovery Investigation and Litigation (Matter ID 00002) A. Asset Analysis and Recovery (Task Code B120) Fees: \$288,018.50 Total Hours: 224.70

65. While the Trustee's investigation and litigation related to the recovery of assets of the estates was generally recorded under Task Code B261 (see below), work related to certain potential estate assets that had already been identified at the time of the Trustee's appointment on July 8, 2022, including the Lady May and the Sherry Netherland Apartment were recorded under Task Code B120. In addition, time spent by the Trustee and Paul Hastings' U.S. lawyers on seeking recognition of the Individual Debtor's chapter 11 case in the U.K. was recorded under task code B120—which recognition was obtained in January 2023.26

- 66. Among other things, as it relates to the Lady May, Paul Hastings attorneys: - analyzed the New York state court's contempt order, dated February 9, 2022, finding that the Lady May is beneficially owned and controlled by the Individual Debtor; - analyzed the stipulated order entered by this Court on April 29, 2022 [Docket No. 299] (the "Stipulated Lady May Order") with respect to the return of the Lady May to Connecticut waters (as well as conducted related research);

26 Time spent by Paul Hastings' U.K. lawyers in connection with these recognition efforts were recorded under Matter ID 00007 (Foreign Law Issues).

- negotiated a consensual order, dated October 7, 2022 [Docket No. 930] (the "Repair Reserve Order") establishing a \$4 million reserve to fund the repairs for the Lady May in accordance with the Stipulated Lady May Order; - analyzed invoices related to the repairs of the Lady May in accordance with the Repair Reserve Order; - prepared and filed objections [Docket No. 1276 and 1490] to HK USA and Mei Guo's motion to modify the Repair Reserve Order so as to fund Lady May operating expenses out of the repair reserve; - negotiated consent orders permitting the funding of Lady May operating expenses out of the repair reserve for the months of November 2022 through February 2023 [Docket Nos. 1255 and 1377]; and - coordinated with Dexter White of EOCS and counsel for HK USA regarding the inspection of the Lady May in December 2022, in accordance with the Repair Reserve Order.

67. Furthermore, with respect to the Sherry Netherland Apartment, Paul Hastings attorneys analyzed the purported trust agreement in favor of Bravo Luck, an entity purportedly owned by Qiang Guo (i.e., the Individual Debtor's son) and analyzed the agreement between Genever (US) and the Sherry Netherland regarding the use of the Sherry Netherland Apartment by the Individual Debtor and immediate members of his family.

68. Finally, Paul Hastings attorneys prepared the Trustee's application in the English courts seeking to have the Individual Debtor's chapter 11 case recognized as a foreign main proceeding and to obtain access to the litigation file of the Individual Debtor's U.K. counsel (Harcus Parker) in the UBS Litigation. 27 Obtaining recognition in the U.K. was a necessary first step in order to seek relief in the U.K. not only with respect to privileged documents with respect to the UBS Litigation but also various Kwok-affiliated entities and family members located in

27 The "UBS Litigation" refers to the litigation commenced by the Individual Debtor, Ace Decade, and Dawn State in the English courts in September 2020 against UBS AG, seeking approximately \$500 million in damages for misrepresentations allegedly made by UBS AG in connection with a securities transaction in 2014 and 2015. Case 22-50073 Doc 1831 Filed 05/30/23 Entered 05/30/23 08:41:26 Page 33 of 1334

the U.K., including discovery. On January 30, 2023, after several contested hearings (at which Ace Decade actively opposed the relief sought by the Trustee), the English court granted recognition as a foreign main proceeding and required Harcus Parker to provide the Trustee with access to their litigation file (subject to Ace Decade's and Dawn State's rights to assert that certain documents should not be shared with the Trustee on the basis of they hold the sole privilege in such documents). The English court awarded £22,883.70 in fees, which amount (\$26,963.75 in US dollars) was paid by Ace Decade's counsel to the Trustee's account. To be clear, although Paul Hastings worked on the Trustee's efforts to obtain recognition in the U.K., Paul Hastings was not involved in the UBS Litigation itself, which is being handled by the Trustee individually and his local U.K. counsel, i.e., Pallas, as solicitors, and Paul Wright, as barrister.

- B. Court Hearings (Task Code B155) Fees: \$147,563.00 Total Hours: 101.30 - 69. During the Fee Period, Paul Hastings attorneys attended numerous hearings

related to the Trustee's investigation and related litigation, including:

- The August 12, 2022 hearing on the Trustee's motions seeking discovery under Bankruptcy Rule 2004; - The August 30, 2022 hearing on, among other things, the Trustee's motion for an order providing that control of the Individual Debtor's privileges passed to the Trustee upon his appointment (the "Privileges Motion"); - The September 6, 12, and 13, 2022 hearings on the Privileges Motion; - The September 27, 2022 status conference; - The October 4, 2022 hearing on, among other things, (a) the Trustee's motion for a protective order, (b) various matters related to the Trustee's Rule 2004 investigation, and (c) certain procedural matters, including the scheduling of a hearing on the Trustee's application for pre-judgment remedies in the HK USA Litigation. - The October 13, 2022 hearing on the Trustee's motion to authorize compliance with Rule 2004 subpoenas as it relates to Brown Rudnick and Verdolino & Lowey; - The October 24, 2022 status conference with respect to the adjournment of the hearing on the Trustee's application for prejudgment remedies in the HK USA Litigation (as defined below); - The October 25 and 27, 2022 hearings on various Rule 2004 discovery issues, including the motion of Baker Hostetler seeking approval of procedures for production of documents; - The December 20, 2022 hearing in the English courts regarding the recognition of the Individual Debtor's chapter 11 case as a foreign main proceeding; - The January 10 and 17, 2023 hearings on HK USA and Mei Guo's motion to modify the Repair Reserve Order; and - The January 24, 2023 hearing in the English courts regarding the recognition of the Individual Debtor's chapter 11 case as a foreign main proceeding. - C. General Litigation (Task Code B191) Fees: \$2,617,156.51 Total Hours: 2,195.50 - 70. During the Fee Period, Paul Hastings attorneys prepared, filed, and prosecuted

several estate causes of action against entities affiliated with the Individual Debtor, for the purpose of recovering assets for the benefit of these chapter 11 estates. To date, as detailed below, the Trustee has been successful in recovering substantial assets for the benefit of the estates—although, at this time, several adversary proceedings are in their early stages and, moreover, the Trustee's investigation into other potential assets remains ongoing.

71. Notably, Paul Hastings attorneys prepared, filed, and prosecuted counterclaims against HK USA and Mei Guo (the Individual Debtor's daughter) in Adversary Proceeding No. 22-5003 (the "HK USA Litigation"), seeking determinations that, among other things, (a) the Lady May is property of the Individual Debtor's estate, (b) HK USA is an alter ego of the Individual Debtor or equitably owned by the Individual Debtor, (c) in the alternative, an actual Case 22-50073 Doc 1831 Filed 05/30/23 Entered 05/30/23 08:41:26 Page 35 of 1334

fraudulent transfer claim against HK USA, and (d) in the alternative, a negligence claim against HK USA. In connection with the Trustee's relief sought in the HK USA Litigation, the Trustee and Paul Hastings attorneys also prepared numerous related motions, including motions for prejudgment remedies [Docket No. 37 in Adv. Proc. No. 22-5003] and injunctive relief [Docket No. 50 in Adv. Proc. No. 22-5003], the related reply brief [Docket No. 101 in Adv. Proc. No. 22- 5003], as well as two motions for partial summary judgment [Docket Nos. 146 and 185]. During the course of the HK USA Litigation, the Trustee and Paul Hastings attorneys also (a) prepared for and took the depositions of Mei Guo (on January 20, 2023), Stephen Kindseth (on February 24, 2023), and the Individual Debtor (on March 2, 2023), (b) defended the deposition of the Trustee (on March 3, 2023), and (c) prepared the Trustee's objection [Docket No. 90 in Adv. Proc. No. 22-5003] to HK USA and Mei Guo's motion to dismiss certain of the Trustee's counterclaims (which motion the Court largely denied) [Docket No. 202 in Adv. Proc. No. 22- 5003]). 28 In preparing for these depositions, Paul Hastings attorneys researched many legal issues, including with respect to the Fifth Amendment of the United States Constitution. As the Court is well aware, the Individual Debtor invoked the Fifth Amendment numerous times in these cases—including more than 200 times during one hearing in December 2022 and in response to the Trustee's Rule 2004 subpoena—to avoid providing testimony and producing documents in these chapter 11 cases.

72. As a result of Paul Hastings' efforts, the Trustee obtained not only prejudgment and injunctive relief against HK USA and Mei Guo by orders dated March 17, 2023 [Docket

28 In addition, after the conclusion of the Fee Period, the Trustee and Paul Hastings attorneys also prepared various motions in limine regarding the use of evidence at the prejudgment remedies hearing [Docket Nos. 106, 107, 110, 112, and 137 in Adv. Proc. No. 22-5003] and objections to HK USA and Mei Guo's motions in limine [Docket Nos. 119, 123, 124, and 125]. Case 22-50073 Doc 1831 Filed 05/30/23 Entered 05/30/23 08:41:26 Page 36 of 1334

Nos. 140 and 142 in Adv. Proc. No. 22-5003],29 but also summary judgment rulings finding that, among other things, the Lady May and the Lady May II are property of the Individual Debtor's estate and HK USA is an alter ego of the Individual Debtor. See Docket Nos. 172 and 221 in Adv. Proc. No. 22-5003.

73. In furtherance of the Trustee's counterclaims asserted in the HK USA Litigation, Paul Hastings attorneys researched numerous complex legal issues, including the preclusive effect of Justice Ostrager's rulings in the PAX Litigation, the doctrines of in pari delicto and alter ego, and fraudulent transfer law. Moreover, the Trustee and Paul Hastings attorneys investigated the relationship between the Individual Debtor and HK USA (including the various transfers and transactions in connection with the acquisition of the Lady May) and handled numerous procedural matters related to the HK USA Litigation (including preparing proposed consent orders adjourning the hearings on the application for prejudgment remedies).

74. In addition to the HK USA Litigation, Paul Hastings attorneys prepared and filed three30 complaints against Bravo Luck Limited ("Bravo Luck") challenging a purported trust agreement between the Individual Debtor, Genever (BVI), Genever (US), and Bravo Luck, pursuant to which Bravo Luck was purportedly granted beneficial ownership of the Sherry Netherland Apartment (such litigation, the "Bravo Luck Litigation"). The Trustee and the Genever Debtors dispute that the purported trust agreement is valid and enforceable. In preparing the complaints against Bravo Luck, Paul Hastings attorneys analyzed numerous

29 HK USA and Mei Guo have appealed the order granting partial summary judgment as it relates to the ownership of the Lady May and the Lady May II to the District Court for the District of Connecticut.

30 One complaint was filed by the Trustee, one was filed by Genever (BVI), and one was filed by Genever (US). The three adversary proceedings have been consolidated. See Docket No. 28 in Adv. Proc. No. 22-5027. Case 22-50073 Doc 1831 Filed 05/30/23 Entered 05/30/23 08:41:26 Page 37 of 1334

complex legal issues, including as it relates to sham transactions, fraudulent transfer claims, and other related issues.

75. Paul Hastings attorneys also analyzed (a) Bravo Luck's motion to dismiss the adversary complaints [Docket No. 20 in Case No. 22-5027] and (b) Bravo Luck's motion to strike certain portions of the allegations in the Trustee's and the Genever Debtors' complaints [Docket No. 22 in Case No. 22-5027]. Furthermore, Paul Hastings attorneys prepared and filed an amended complaint filed on February 28, 2023 [Docket No. 40 in Case No. 22-5027].31

76. Other time recorded under Task Code B191 includes analyzing service of process on parties located outside the United States, which was particularly challenging in these chapter 11 cases as many Kwok-related affiliates are located into foreign jurisdictions.

D. Non-Working Travel (Task Code B195) [billed at ½ rate] Fees: \$6,594.75 Total Hours: 12.60

During the Fee Period, Paul Hastings attorneys traveled to New Haven, Connecticut for the depositions of Hing Chi Ngok (the Individual Debtor's purported wife).

E. Investigations (Task Code B261) Fees: \$3,905,932.46 Total Hours: 3,512.10

77. During the Fee Period, Paul Hastings commenced an extensive investigation to identify potential assets of the Individual Debtor's estate. This investigation was—and continues to be—imperative in light of the glaring inconsistency between the Individual Debtor's assertion in his Schedules that he owns assets valued only at \$3,850 and the fact that he nevertheless has access to a significant funds and recourse, including for the purpose of paying his counsel in the chapter 11 case, and has for years lived a lavish and luxurious lifestyle as a self-proclaimed billionaire. Given the corporate maze of shell companies set up by the Individual Debtor,

31 After the conclusion of the Fee Period, on March 21, 2023, Bravo Luck filed renewed motions to dismiss the amended complaint, which was objected to by the Trustee and the Genever Debtors. The hearing on the renewed motion to dismiss is currently scheduled for June 6, 2023. Case 22-50073 Doc 1831 Filed 05/30/23 Entered 05/30/23 08:41:26 Page 38 of 1334

including hundreds of companies purportedly owned by his close family members, business associates, and employees, this investigation has necessarily been extensive and time intensive. Moreover, as detailed below, and as the Court is well aware, the investigation has faced vigorous opposition, at every turn, not only from the Individual Debtor, but also many of the targets of the Trustee's investigation, i.e., the Individual Debtor's close family members, business associates, and employees.

78. Much of the investigation also required the expertise of Paul Hastings' Mandarinspeaking attorneys in order to analyze thousands Mandarin-language documents (including WhatsApp, text messages, and videos). This work required not only Mandarin language skills but an understanding of the legal significance of these documents, which an outside translation service would not be able to provide. Paul Hastings' Mandarin-speaking attorneys were also critical for the Trustee to communicate with the numerous Mandarin-speaking "informants" that have reached out to the Trustee during the course of these chapter 11 cases.

79. At the outset of the Trustee's investigation, Paul Hastings attorneys prepared and filed three motions under Bankruptcy Rule 2004 seeking discovery from (a) the Individual Debtor [Docket No. 636], (b) certain outside counsel and other advisors to the Individual Debtor [Docket No. 637], and (c) certain of the Individual Debtor's family members, business associates, and corporate entities associated with the Debtor [Docket No. 638]. Following entry of this Court's orders on August 16, 2022 [Docket Nos. 756, 757, and 758] granting each of the Trustee's initial Rule 2004 motions, Paul Hastings attorneys engaged in numerous meet and confer sessions with the targets of the Rule 2004 discovery. In this regard, Paul Hastings attorneys also prepared a motion seeking entry of a protective order to allow the discovery

Case 22-50073 Doc 1831 Filed 05/30/23 Entered 05/30/23 08:41:26 Page 39 of 1334

targets to designate materials produced in discovery as confidential. The Court granted the requested relief by order dated October 6, 2022 [Docket No. 2022].32

80. Unfortunately, many discovery targets did not comply with the Trustee's Rule 2004 subpoenas, necessitating significant motion practice to compel compliance (which compliance, to this day, remains forthcoming in many instances). For example, because the Individual Debtor took the position, among others, that he may attempt to prevent the Trustee from obtaining information from his counsel and other professionals by seeking to invoke attorney-client privilege, the work product doctrine, or other privileges or protections, Paul Hastings attorneys prepared and filed the Trustee's motion seeking entry of an order that any such privileges passed to the Trustee upon his appointment and may no longer be asserted by the Individual Debtor. The Court granted the Trustee's motion (with certain modifications) by order dated September 14, 2023 [Docket No. 856] (the "Privileges Order"). 33

81. Notwithstanding the Privileges Order, the Trustee was compelled to file a motion [Docket No. 898] seeking to enforce such order as against the Individual Debtor's former bankruptcy counsel (Brown Rudnick) and financial advisor (Verdolino & Lowey) because the Individual Debtor prevented Brown Rudnick and Verdolino & Lowey from making any production by taking unreasonable and improper positions in violation of the Privileges Order. The Court granted the relief requested by the Trustee (with certain modifications) by order entered on October 13, 2022 [Docket No. 962].

32 In addition, the Trustee (by his local counsel, NPM) has filed three several supplemental motions [Docket Nos. 839, 1116, and 1259] requesting authorization to seek discovery from additional entities, including legal, advisory, or accounting firms, family members, business associates, and corporate entities related to the Individual Debtor, all of which motions were granted by the Court. The Trustee utilized NPM for these supplemental motions because Paul Hastings was conflicted as to some of the discovery targets. To the extent Paul Hastings did not have conflict, it assisted NPM in preparing such supplemental motions.

33 The order entered by the Court was, after several hearings, ultimately consensual, reflecting extensive discussions between Paul Hastings and counsel to the Individual Debtor. Case 22-50073 Doc 1831 Filed 05/30/23 Entered 05/30/23 08:41:26 Page 40 of 1334

82. Worse, many discovery targets—including the Individual Debtor—refused to comply with the Rule 2004 subpoenas and have been either impeding the Trustee's investigation or failing to respond altogether. For example, some discovery targets refused to search for documents and communications concerning potential estate assets that may be held by the Individual Debtor's relatives, known associates, or shell companies—on the basis that such assets are purportedly not owned or controlled by the Individual Debtor and, thus, are not relevant to the administration of his estate. This position turns the purpose of the investigation on its head, which is to determine what assets are owned and/or controlled by the Individual Debtor. Other discovery targets simply did not response to the Trustee's Rule 2004 subpoenas at all.

83. In light of this obstructive behavior, Paul Hastings attorneys prepared and filed the Trustee's motion [Docket No. 1046] (the "Motion to Compel Compliance with Subpoenas") seeking to compel the Individual Debtor, Mei Guo (the Individual Debtor's daughter), HK USA, Hing Chi Ngok (the Individual Debtor's purported wife), Greenwich Land LLC, Lamp Capital LLC ("Lamp Capital"), and Golden Spring (New York) Ltd. ("Golden Spring") to comply with the subpoenas issued by the Trustee. The Court granted the Motion to Compel Compliance with Subpoenas as it relates to the Individual Debtor, HK USA, and Ms. Guo on January 20, 2023 [Docket No. 1353] (the "Order Compelling Compliance with Subpoenas").34

84. Unfortunately, even after entry of this order, the Individual Debtor, HK USA, and Ms. Guo continued to fail to comply with the Trustee's subpoenas, requiring still further motion practice before this Court. In particular, Paul Hastings attorneys prepared and filed the Trustee's

34 As it relates to Golden Spring and Lamp Capital, the Court entered two orders [Docket No. 1397 and 1546] to show cause as to why they should not be held in contempt of court for failing to comply with the subpoenas issued by the Trustee. Neither Golden Spring nor Lamp Capital ever responded to this order, despite the Court having afforded them ample time to do so. As a result, the Court entered an order on April 26, 2023 [Docket No. 1709] holding Golden Spring and Lamp Capital in contempt of court. Case 22-50073 Doc 1831 Filed 05/30/23 Entered 05/30/23 08:41:26 Page 41 of 1334

motion for order to show cause [Docket No. 1453] (the "Motion for Order to Show Cause") as to why the Court should not hold the Individual Debtor, HK USA and Ms. Guo in contempt for failure to comply with the Order Compelling Compliance with Subpoenas. 35

85. As detailed in that motion, in response to the Trustee's subpoena, the Individual Debtor sought to invoke his rights under the Fifth Amendment as a means to produce no documents to the Trustee and provide no description of his document search process.36 In particular, on February 1, 2023, the day after the deadline for the Individual Debtor to produce documents, the Individual Debtor's bankruptcy counsel informed the Trustee's counsel that, in response to the Order Compelling Compliance with Subpoenas, the Individual Debtor "is asserting his rights under the 5th Amendment, including any rights under the Act of Production Doctrine." Thereafter, on February 7, 2023, the Individual Debtor filed a declaration [Docket No. 1444] stating that he is "invok[ing] [his] rights under the 5th Amendment to the United States Constitution, including under the act of production doctrine, with respect to the Subpoena dated August 17, 2022, in its entirety, including all requests for documents and information set forth therein." As detailed in the Motion for Order to Show Cause, the Individual Debtor is not entitled to blanket Fifth Amendment protection from the requirements of the Order Compelling Compliance with Subpoenas. On May 1, 2023, the Court entered an order [Docket No. 1740]

35 As further detailed below and the Special Fee Application, to the extent practicable, the time spent on the Motion to Compel Compliance with Subpoenas and the Motion for Order to Show Cause, as it related to HK USA and Ms. Guo, was recorded separately under Task Code B262 (with a 50% reduction to reflect that some of that time also related to the enforcement of the subpoena issued to the Individual Debtor).

36 As the Court is well aware, the Individual Debtor has invoked the Fifth Amendment numerous times in this case—including more than 200 times during one hearing in December 2022—to avoid providing testimony on substantive issues. Case 22-50073 Doc 1831 Filed 05/30/23 Entered 05/30/23 08:41:26 Page 42 of 1334

requiring the Individual Debtor to respond, in a particularized manner, in response to the specific requests attached as Exhibit A to such order.37

86. The Trustee and Paul Hastings attorneys also investigated malpractice claims asserted by the Individual Debtor against Clark Hill PLC ("Clark Hill"), the Individual Debtor's former immigration counsel, related to the Individual Debtor's asylum application. The Trustee ultimately settled these claims in exchange for Clark Hill paying \$499,000 to the Individual Debtor's estate [Docket No. 1756]. In connection with the Trustee's investigation of estate claims against Clark Hill, Paul Hastings attorneys also prepared (a) the Trustee's response [Docket No. 1105] to the Individual Debtor's motion for a protective order to preclude the disclosure of the Individual Debtor's asylum application [Docket No. 1063] (the "Protective Order Motion") and (b) analyzed various legal issues regarding the Individual Debtor's motion for an interlocutory appeal of the Court's order granting the Protective Order Motion only in part [Docket No. 1228] and the Individual Debtor's related request for a stay pending appeal [Docket No. 1235]. 38

87. In addition, as part of the Trustee's extensive investigation, Paul Hastings attorneys spent substantial time interviewing a confidential "informant" and assisting such "informant" in preparing a declaration detailing the structure and operations of the Individual Debtor's network of companies. This declaration was ultimately submitted (under seal) in connection with the HK USA Litigation as well as the Trustee's opposition to the Individual Debtor's motion to remove the Trustee. However, the value of the information obtained through the confidential "informant" goes well beyond the declaration. In fact, as a result of their

37 The hearing on the Motion for Order to Show Cause as it relates to the Individual Debtor, has been continued to June 6, 2023.

38 On January 11, 2023, the District Court denied the motion for leave to appeal [Docket No. 1312] and on January 13, 2023, this Court denied the motion for a stay pending appeal as moot [Docket No. 1316]. Case 22-50073 Doc 1831 Filed 05/30/23 Entered 05/30/23 08:41:26 Page 43 of 1334

multiple conversations with the confidential "informant," Paul Hastings attorneys developed valuable insight into the Individual Debtors' business practices, thereby helping to identify additional potential assets to be recovered for the benefit of these estates.

88. Furthermore, during the Fee Period, the Trustee commenced (with the assistance of its BVI counsel, Harneys Legal) proceedings in the BVI courts to seek, through ex parte applications, discovery from BVI registered agents with respect to corporate documents of various Kwok-related entities incorporated in the BVI. Among other things, Paul Hastings attorneys worked closely with Harneys Legal in preparing the relevant application to the BVI courts. As a result of these efforts, the Trustee obtained corporate documents with respect to more than twenty BVI-incorporated companies that are affiliated with the Individual Debtor or members of his family.

89. To date, the Trustee's investigation (including as a result of discovery under Rule 2004, information provided by the confidential "informant," and corporate documents received from BVI registered agents) uncovered numerous assets that the Trustee believes are property of the Individual Debtor's estate, which the Trustee is seeking to recover for the benefit of the estate. For example, as the Court is aware, the Trustee has recently commenced (a) an adversary proceeding seeking to recover various assets purportedly owned by the Individual Debtor's daughter (including several BVI-incorporated companies) and over \$10 million in proceeds from the sale of a private jet [Adv. Proc. No. 23-5008], 39 and (b) an adversary proceeding seeking to recover the Individual Debtor's residence in Greenwich, Connecticut [Adv. Proc. No. 23-5005].

90. Finally, Paul Hastings attorneys engaged in numerous other investigation-related tasks, including the following:

39 Mei Guo's purported ownership of this private jet was uncovered as a result of the document productions from the BVI registered agents.

- Deposed (a) Hing Chi Ngok, the Individual Debtor's purported wife, and (b) Margaret Conboy of Whitman Breed, real estate counsel for the Individual Debtor's "family office"; - Communicated with several "informants" (including former employees and business associates of the Individual Debtor) who provided valuable insight into the business operations of the Individual Debtor;40 - Reviewed and analyzed documents produced by Rule 2004 discovery targets;41 - Analyzed relationship between the Individual Debtor and hundreds of companies affiliated with the Individual Debtor; - Researched property records; - Sent "litigation hold" letters to outside counsel and advisors of the Individual Debtor as well as various entities affiliated with the Individual Debtor; - Analyzed service issues with respect to Rule 2004 discovery targets; and - Sent demand letters to recipients of preferential transfers. - F. Contempt Proceedings (Task Code B262) Fees: \$149,952.02 Total Hours: 121.00 - 91. On March 10, 2023, the Court entered an order [Docket No. 1537] (the "HK

Parties Contempt Order") holding the HK Parties (i.e., HK USA, Ms. Guo, and attorney Lee Vartan) in contempt and directing them, jointly and severally, to compensate the Trustee and his counsel, Paul Hastings, for reasonable attorneys' fees and expenses associated with the Trustee's efforts to secure compliance with the subpoenas. On April 10, 2023, the Trustee and Paul Hastings filed their Special Fee Application seeking payment of \$83,370.26 from the HK Parties,

40 In light of the Individual Debtor's well-documented social media campaign against the Trustee, Paul Hastings attorneys, and creditors in these chapter 11 cases, the time entries attached to this Application have been redacted to remove the names of these "tipsters."

41 As further detailed below, In the interest of minimizing costs, Paul Hastings utilized UnitedLex Corporation ("UnitedLex") to conduct, among other things, first-round review of documents produced in the Trustee's investigation. UnitedLex specializes in discovery services, including document processing, storage, review services, and distribution. Case 22-50073 Doc 1831 Filed 05/30/23 Entered 05/30/23 08:41:26 Page 45 of 1334

which application the Court granted by order dated April 23, 2023 [Docket No. 1693].42 As of the filing of this Application, the HK Parties have not remitted payment to Paul Hastings (even though such amounts were due on May 5, 2023).43

92. Because the Trustee prepared a single Motion to Compel Compliance with Subpoenas and a single Motion for Order to Show Cause, it is not possible, with absolute precision, to determine how much time was spent on each specific discovery target. As detailed in the Special Fee Application, the time spent on the Motion to Compel Compliance with Subpoenas and the Motion for Order to Show Cause, as it related to HK USA and Ms. Guo, was recorded under Task Code B262 (with a 50% reduction to reflect that some of that time also related to the enforcement of the subpoena issued to the Individual Debtor). Accordingly, for purposes of this Application, the time entries under Task Code B262 should be read in conjunction with the time entries under Task Code B261.

A. Court Hearings (Task Code B155) Fees: \$215,386.50 Total Hours: 133.00

93. During the Fee Period, the Paul Hastings attorneys participated in several hearings related to the adversary proceeding commenced by PAX on November 22, 2022 against the Individual Debtor seeking to enjoin the Individual Debtor and his associates from continuing their social media attacks against the Trustee, his family, and his counsel, as well as PAX, Mr.

42 To be clear, this Application includes the amount requested in the Special Fee Application. However, to the extent Paul Hastings is able to collect such fees from the HK Parties, it will obviously not seek payment of such fees from these estates.

43 The HK Parties have (unsuccessfully) sought reconsideration of the Sanctions Order [Docket Nos. 1730 and 1733] and, thereafter, appealed both the Sanctions Order and the order denying reconsideration [Docket No. 1750], as well as sought a stay pending appeal [Docket No. 1770]. That request for a stay was denied by order dated May 15, 2023 [Docket No. 1791]. Case 22-50073 Doc 1831 Filed 05/30/23 Entered 05/30/23 08:41:26 Page 46 of 1334

Shan Weijian (the chief executive of PAX's parent company), his family, and PAX's counsel.

Among other things, the Trustee and Paul Hastings attorneys handled the following hearings:

- The November 23, 2022 hearing on the request for a temporary restraining order against the Individual Debtor and his associates; - The December 5 to 7, 2022 and December 12, 2022 hearings on the request for a preliminary injunction; - The January 13, 2023 status conference regarding the order granting the preliminary injunction (which order had been entered on January 11, 2023); - The January 23, 2023 hearing on the Trustee's motion to authorize service of the order granting the preliminary injunction on the Individual Debtor and his associates; and - The January 31, 2023 status conference before the Connecticut District Court in the Individual Debtor's appeal of the temporary restraining order. - B. General Litigation (Task Code B191) Fees: \$717,547.51 Total Hours: 646.30

94. As the Court is well aware, beginning in mid-November 2022 (and continuing for several months), the Individual Debtor and his affiliated organizations engaged in an extensive social media intimidation campaign directed at the Trustee, his family, and his counsel, as well as PAX, the chief executive of PAX's parent company, his family, and PAX's counsel, including by disclosing home address information online and issuing threats against them personally, including death threats against the Trustee. 44 In addition, starting on November 20, 2022, a group of Debtor-aligned protestors began picketing at the residence of the Trustee as well as the residences of members of the Trustee's family, including his former spouse, and subsequently at the offices of counsel to the Trustee (Paul Hastings) and counsel to PAX (O'Melveny). Debtoraligned protestors have also picketed at the residence of family members of the chief executive of PAX's parent company.

44 The Trustee is not aware of any other case where a court-appointed chapter 11 trustee became the target of a concerted smear-campaign orchestrated by the debtor and entities affiliated with the debtor. Case 22-50073 Doc 1831 Filed 05/30/23 Entered 05/30/23 08:41:26 Page 47 of 1334

95. In response to this intimidation campaign, on November 22, 2022, PAX commenced an adversary proceeding [Adv. Proc. No. 22-5032] (the "PI Litigation") against the Individual Debtor in order to put an end these out-of-court tactics to interfere with the administration of these chapter 11 cases. Given the Trustee's obvious interest in protecting the integrity of the administration of these chapter 11 cases, the Trustee intervened in the PI Litigation in support of the relief sought by PAX.45 Concurrently with its complaint, PAX filed a motion (joined by the Trustee) requesting entry of a temporary restraining order and preliminary injunction. The Court granted the temporary restraining order on November 23, 2022 [Docket No. 26 in Adv. Proc. No. 22-5032] (the "TRO"). Among other things, the TRO restrained the Individual Debtor from (1) posting false and harassing materials about PAX and the Trustee, their counsel, and their relatives, (2) publishing online the home addresses and other personal information of PAX and the Trustee, their counsel, and their relatives, (3) encouraging, inciting, suggesting, or directly or indirectly financing protests at homes and offices of PAX and the Trustee, their counsel, and their relatives, and (4) interfering with the integrity of these chapter 11 cases. 46

96. Ultimately, following four days of evidentiary hearings on December 5, 6, 7, and 12 (the "PI Hearing"), 47 the Court granted the motion for a preliminary injunction [Docket Nos. 129 and 134 in Adv. Proc. No. 22-5032] (the "Preliminary Injunction"). Among other things, the

45 In addition, before the filing of the PI Litigation, the Trustee and Paul Hastings attorneys prepared and filed a statement in the main chapter 11 case [Docket No. 1133] alerting the Court to the Individual Debtor's social media intimidation campaign.

46 As detailed in the *Joint Motion for Entry of an Order Holding Ho Wan Kwok in Civil Contempt for Failure to Comply with Temporary Restraining Order* [Docket No. 40 in Adv. Proc. No. 22-5032], the Individual Debtor continued to violate the TRO, including through the incitement and encouraging of protests at the homes of the Trustee, Mr. Shan, and their family members, as well as outside the offices of counsel to the Trustee and PAX. Following entry of the Preliminary Injunction, PAX and the Trustee withdrew the motion to hold the Individual Debtor in contempt for failure to comply with the TRO.

47 During these hearings, the parties presented extensive evidence, including testimony from nine witnesses, one expert witness, and 100 exhibits. Case 22-50073 Doc 1831 Filed 05/30/23 Entered 05/30/23 08:41:26 Page 48 of 1334

Preliminary Injunction enjoins the Individual Debtor and his affiliates48 from protesting, picketing, parading, or displaying or distributing harassing material, at any time, before or about the homes or residences of the Trustee, PAX's or its affiliates' officers or employees, counsel to the Trustee or PAX or its affiliates, and any of their respective relatives (including former spouses). In addition, the Preliminary Injunction enjoins the Individual Debtor "from interfering in any way with the integrity of his Chapter 11 case, the Chapter 11 case of Genever Holdings, LLC and the chapter 11 case of Genever Holdings Corporation, which have been jointly administered in this Court . . ."49 Following entry of the Preliminary Injunction, the Individual Debtor sought leave to appeal such order. Ultimately, the Connecticut District Court granted the Individual Debtor's request for leave to appeal. See Docket No. 196 in Adv. Proc. No. 22- 5032.50

97. To minimize duplication, Paul Hastings attorneys coordinated extensively with PAX with respect to the PI Litigation. In general, PAX took the lead in prosecuting the litigation, including as it related to drafting of substantive briefs and the presentation of evidence at the PI Hearing, but Paul Hastings attorneys reviewed and commented on drafts of PAX's motions, briefs, and other pleadings before filing. As a result, the Trustee generally joined in motions filed by PAX or jointly moved with PAX in requesting relief in connection with the PI Litigation. That said, Paul Hastings attorneys also handled a number of other discrete tasks, including:

48 The Preliminary Injunction applies not only the Individual Debtor, but also "his officers, his agents, his servants, his employees, his attorneys, and other persons who are in active concert or participation with the Debtor, his officers, his agents, his servants, his employees, and his attorneys . . . upon receiving actual notice by personal service or otherwise." Preliminary Injunction ¶ 5.

49 Id. ¶ 2.

50 Ultimately, the Connecticut District Court granted the Individual Debtor's request for leave to appeal. See Docket No. 196 in Adv. Proc. No. 22-5032.

- analyzing social media posts (including videos) posted by the Individual Debtor and his associates; - conducting legal research related to the relief sought in the PI Litigation; - preparing and filing a motion to authorize service of the TRO by the U.S. Marshal Service and compelling the Individual Debtor to appear before the Court at the hearing on the preliminary injunction motion [Docket No. 34 in Adv. Proc. No. 22-5032]; and - preparing and filing a motion to authorize service of the Preliminary Injunction [Docket No. 137 in Adv. Proc. No. 22-5032]. - 98. In addition, during the Fee Period, Paul Hastings attorneys handled various other

litigation-related matters, including preparing a draft of a motion to dismiss a lawsuit filed

against the Trustee in his personal capacity (and Paul Hastings) by certain persons affiliated with

the Individual Debtor in the Southern District of New York alleging that the Trustee and Paul

Hastings are unregistered agents of the People's Republic of China and/or the Chinese

IV. Corporate Law Issues (Matter ID 00004)

- A. Court Hearings (Task Code B155) Fees: \$146,359.00 Total Hours: 109.00 - 99. During the Fee Period, Paul Hastings attorneys prepared for and handled: - the August 4, 2022 hearing on the Trustee's Corporate Governance Motion (as defined below); and - the November 16 and 17, 2022 hearing on the Trustee's motion to hold the Individual Debtor in contempt for failure to comply with the Corporate Governance Motion as it relates to the transfer of Ace Decade to the Trustee.

51 Ultimately, the Trustee and Paul Hastings moved to dismiss this lawsuit on other grounds. As of the date of this Application, the District Court for the Southern District of New York has not yet ruled on that motion to dismiss. B. Other Contested Matters (Task Code B190) Fees: \$579,698.50 Total Hours: 456.00

100. During the Fee Period, Paul Hastings attorneys prepared and filed the Trustee's motion [Docket No. 913] (the "Ace Decade Motion") seeking to hold the Individual Debtor in contempt for failure to comply with the Court's Corporate Governance Order as it relates to the transfer of ownership and control of Ace Decade and its wholly-owned subsidiary Dawn State Limited ("Dawn State"), which the Individual Debtor refused to surrender notwithstanding his prior statements—at the creditors' meeting in his chapter 11 case as well as in various court filings—that he owns Ace Decade and, by extension, Dawn State.52 In connection with the Ace Decade Motion, Paul Hastings attorneys deposed the Individual Debtor as well as the translator who had translated the Individual Debtor's statements at the creditors' meeting that he owned Ace Decade.

101. Given the overwhelming evidence that the Individual Debtor did, in fact, beneficially own and control Ace Decade and Dawn State, the Individual Debtor ultimately agreed not to contest a finding by this Court to that effect and, on November 17, 2022, the Court entered an order [Docket No. 1110] partially resolving the Ace Decade Motion as it relates to beneficial ownership and control of Ace Decade and Dawn State by the Individual Debtor. This partial resolution, however, left unresolved whether the Individual Debtor was able to direct Yvette Wang—the purported nominee shareholder of Ace Decade—to surrender Ace Decade to the Trustee.

52 Ace Decade and Dawn State are co-plaintiff's with the Individual Debtor in litigation against UBS AG pending in the English courts, in with litigation plaintiffs have asserted claims for misrepresentations made by UBS in connection with a securities transaction in 2015. While, upon his appointment, the Trustee stepped into the shoes of the Individual Debtor, Ace Decade and Dawn State refused to take instruction from the Trustee, and, in fact, have opposed the Trustee's efforts to take control of that litigation, including refusing to consent to their former UK counsel (Harcus Parker) turning over litigation-related documents to the Trustee. Case 22-50073 Doc 1831 Filed 05/30/23 Entered 05/30/23 08:41:26 Page 51 of 1334

102. On November 17, 2022, the Court held an evidentiary hearing on the remaining aspects of the Ace Decade Motion. At that hearing, Paul Hastings attorneys presented substantial evidence that the Individual Debtor controls Yvette Wang. Ultimately, on January 24, 2023, the Court entered an order [Docket No. 1372] holding the Individual Debtor in contempt for failing to surrender corporate control of Ace Decade and Dawn State to the Trustee, including because, as the Court found, the Individual Debtor could cause her to turn over her ownership interest to the Trustee. Unfortunately, and notwithstanding this finding of contempt, the Individual Debtor has—to this day—failed to comply with this Court's orders requiring him to surrender Ace Decade and Dawn State to the Trustee.53

103. In addition, during the Fee Period, the Individual Debtor appealed the portion of the Corporate Governance Order directing the Individual Debtor to send a letter to his UK counsel (Harcus Parker) to provide the Trustee with access to counsel's litigation file in the UBS litigation. In connection with that appeal, the Trustee and Paul Hastings attorneys prepared the appellee brief in opposition to the relief requested by the Individual Debtor.54 C. Business Operations (Task Code B210) Fees: \$369,257.00 Total Hours: 283.70

104. During the Fee Period, Paul Hastings attorneys analyzed numerous issues related to the corporate governance of entities owned and/or controlled by the Individual Debtor. Most notably, shortly after his appointment as Trustee, the Trustee filed his motion [Docket No. 598] (the "Corporate Governance Motion") seeking entry of an order confirming that, upon his

53 In fact, the Trustee recently discovered (again, through his BVI-based investigation) that, in early January 2023 (i.e., while the Ace Decade Motion was sub judice), Yvette Wang transferred her shares in Ace Decade to a person residing in Switzerland, who happens to be the brother of the person leading the Individual Debtor's G-Fashion brand. The Trustee intends to seek relief from this Court for this blatant violation of the Bankruptcy Code and this Court's orders.

54 The Individual Debtor's deadline to file his reply brief has been adjourned several times (with the consent of the Trustee), in light of the Trustee's ongoing efforts in the English courts to obtain documents from Harcus Parker directly. Case 22-50073 Doc 1831 Filed 05/30/23 Entered 05/30/23 08:41:26 Page 52 of 1334

appointment, the Trustee holds all of the Individual Debtor's economic and governance rights, for the benefit of the Individual Debtor's estate, with respect to all corporate entities owned and/or controlled by the Debtor, including, without limitation, Genever (BVI) and Genever (US). The Corporate Governance Motion was necessary because the Individual Debtor refused to voluntarily turn over corporate control over his affiliated companies. In fact, the Individual Debtor objected to the relief sought in the Corporate Governance Motion, resulting in the Court holding two hearings (one on August 1, 2022 and one on August 4, 2022) on that motion. Ultimately, the Court granted the Trustee's corporate governance motion with only minor modifications [Docket No. 717] (the "Corporate Governance Order").

105. In connection with the Corporate Governance Motion, Paul Hastings attorneys analyzed numerous corporate governance issues related to entities affiliated with the Individual Debtor, including Genever (BVI) and Genever (US). In this regard, Paul Hastings attorneys also worked closely with the Trustee's BVI counsel (Harneys Legal)—both prior to and after entry of the Corporate Governance Order—to complete the necessary documentation for the Trustee to obtain corporate control over Genever (BVI). This included, among other things, bringing Genever (BVI) into good standing and replacing the Individual Debtor as the sole director of Genever (BVI) with an independent director provided by Harneys Corporate Services. 55

106. In addition, as part of the Corporate Governance Order, the Trustee sought to require the Individual Debtor to provide a letter to his UK counsel to allow the Trustee access to UK counsel's litigation file (so that the Trustee could analyze the merits of the UBS Litigation). The Court granted the requested relief as part of the Corporate Governance Order; however, as

55 By order dated October 3, 2022 [Docket No. 909], the Court approved the Trustee's entry into the director services agreement with Harneys Corporate Services to provide director services (as well as the retention of Harneys Legal as BVI counsel to the Trustee). Case 22-50073 Doc 1831 Filed 05/30/23 Entered 05/30/23 08:41:26 Page 53 of 1334

noted, the Individual Debtor subsequently appealed that portion of the order (which appeal remains pending). 56

A. Asset Analysis and Recovery (Task Code B120) Fees: \$324,931.50 Total Hours: 357.30

107. During the Fee Period, Paul Hastings attorneys in the London office prepared the Trustee's application in the English courts to recognize the Individual Debtor's chapter 11 case as a foreign main proceeding. As part of that application, the Trustee also requested that the English courts require the Individual Debtor's UK counsel to provide the Trustee access to their case file with respect to the UBS Litigation (consistent with English law permitting a trustee in bankruptcy to access to a debtor's privileged information). However, to be clear, the purpose of recognition as a foreign main proceeding goes well beyond the UBS Litigation. In fact, such recognition is the necessary first step to seeking further relief in the English courts with respect to estate assets that may be located in the U.K., including seeking discovery from targest located in the U.K.

108. Unfortunately, even this otherwise routine matter required substantial time and resources because Ace Decade and Dawn State, as well as Harcus Parker (i.e., former UK counsel to the Individual Debtor, Ace Decade, and Dawn State) opposed the relief sought by the Trustee, requiring Paul Hastings attorneys to prepare substantive briefing on questions related to a trustee's right to access privileged information of a debtor as well as submit extensive documentary evidence in support of the relief sought.

56 The Individual Debtor also filed a motion seeking a stay of that portion of the order pending his appeal. The Trustee filed an objection to that request, and, to date, no stay has been issued by this Court. Case 22-50073 Doc 1831 Filed 05/30/23 Entered 05/30/23 08:41:26 Page 54 of 1334

109. On January 30, 2023, the English courts granted recognition as a foreign main proceeding and required Harcus Parker to provide the Trustee with access to their litigation file (subject to Ace Decade's and Dawn State's rights to assert that certain documents should not be shared with the Trustee on the basis that they hold the sole privilege in such documents).

110. In addition, Paul Hastings attorneys in the London office conducted various property searches in the U.K. property registries, given the Individual Debtors' significant connections to the U.K.

B. Court Hearings (Task Code B155) Fees: \$11,183.00 Total Hours: 10.40

111. During the Fee Period, the Trustee and Paul Hastings attorneys attended the November 7, 2022 and December 20, 2022 hearings on the recognition application.

C. General Litigation (Task Code B191) Fees: \$24,935.00 Total Hours: 27.70

112. During the Fee Period, Paul Hastings attorneys in the London office analyze issues related to the Trustee's investigation and the service of pleadings and subpoenas on entities located in the U.K, including service on the Individual Debtor's son (who, at times, refused to accept service).

D. Investigations (Task Code B261) Fees: \$49,821.00 Total Hours: 47.90

113. During the Fee Period, the Trustee and Paul Hastings attorneys prepared and sent a letter to Qiang Guo (the Individual Debtor's) son requesting documents related to his financial support of the Individual Debtor, including the payment of his professional fees. The Trustee's investigation in that regard remains ongoing. VI. Plan Process Issues (Matter ID 00008) A. Plan and Disclosure Statement (Task Code B320) Fees: \$116,902.50 Total Hours: 77.20

114. During September, October, and November 2022, Paul Hastings attorneys engaged in discussions with counsel for the Individual Debtor regarding a potential global resolution of these chapter 11 cases. During this time, the parties exchanged draft term sheets with respect to a potential chapter 11 plan. Unfortunately, these discussions were short-lived and did not result in an agreement, including because it quickly became clear that the Individual Debtor and affiliated entities were not interested in committing assets to fund a chapter 11 plan (including by putting such assets at risk in the event the Individual Debtor and/or his affiliates were to breach the plan support agreement).

A. Case Administration (Task Code B110) Fees: \$50,007.00 Total Hours: 34.40

115. During the Fee Period, Paul Hastings attorneys handled numerous administrative matters related to the chapter 11 case of Genever (US), including communications with (a) Claire Abrehart, i.e., the new director of Genever (BVI) appointed by the Trustee, regarding updates on the chapter 11 cases and (b) Kevin Nash of Goldberg Weprin Finkel Goldstein LLP, i.e., prior counsel for Genever (US), regarding case background, case management, and open workstreams. In addition, the Trustee corresponded with Bankruptcy Judge Garrity (who was overseeing the chapter 11 case of Genever (US) prior to its transfer for the District of Connecticut) regarding the Individual Debtor's chapter 11 cases and the Trustee's intention to transfer venue of the Genever (US) case to the District of Connecticut. Case 22-50073 Doc 1831 Filed 05/30/23 Entered 05/30/23 08:41:26 Page 56 of 1334 B. Sale of Real Estate (Task Code B131) Fees: \$44,612.50 Total Hours: 29.20

116. During the Fee Period, Paul Hastings attorneys analyzed numerous issues related to the sale process for the Sherry Netherland Apartment. In this regard, Paul Hastings attorneys regularly communicated with the sales officer for Genever (US), i.e., former Bankruptcy Judge Melanie Cyganowski, and the real estate broker for the Sherry Netherland Apartment, i.e., Sotheby's International Realty, to receive updates on the sale process. The Trustee and Paul Hastings attorneys also regularly communicated with counsel for the Sherry Netherland hotel regarding the sale process.

117. In addition, on December 20, 2022, Paul Hastings attorneys prepared and filed Genever (US)'s motion [Docket No. 1257] to extend the sale process and continue the retention of Sotheby's International Realty (which had expired on October 31, 2022), which request the Court granted by order dated February 1, 2023 [Docket No. 1425]. In connection with the extension motion, Genever (US) also requested authorization to market the Sherry Netherland Apartment for rent, which requested the Court granted by order dated March 21, 2023 [Docket No. 1577]. In both instances, Bravo Luck objected to the relief requested by Genever (US), which objections the Court overruled.

C. Court Hearings (Task Code B155) Fees: \$33,086.00 Total Hours: 23.70

118. During the Fee Period, Paul Hastings attorneys handled two hearings before Bankruptcy Judge Garrity in the Southern District of New York, namely a status conference on September 27, 2023, and a hearing on Genever (US)'s and the Trustee's motion to transfer the Genever (US) case to the District of Connecticut on October 25, 2023.

Case 22-50073 Doc 1831 Filed 05/30/23 Entered 05/30/23 08:41:26 Page 57 of 1334 D. Fee / Employment Applications for Paul Hastings (Task Code B160) Fees: \$15,591.50 Total Hours: 16.60

119. During the Fee Period, Paul Hastings attorneys prepared the supplemental retention application of Paul Hastings with respect to Genever (US) and Genever (BVI).

E. Other Contested Matters (Task Code B190) Fees: \$123,504.00 Total Hours: 118.50

120. During the Fee Period, Paul Hastings attorneys analyzed various issues related to the transfer of venue of the Genever (US) case from the Southern District of New York to the District of Connecticut, as well as prepared and filed a motion to transfer venue of the Genever (US) case [Docket No. 209 in Case No. 22-50592] and the reply [Docket No. 220 in Case No. 22-50592] in response to the objection filed by Bravo Luck. Genever (US) and the Trustee sought to transfer venue of the Genever (US) case so that this case could be jointly administered with the Individual Debtor's and Genever (BVI)'s chapter 11 cases before this Court, including for the purpose of establishing a global bar date that would allow creditors of the Individual Debtor to also assert claims against the two Genever Debtors. The Trustee's venue transfer motion was granted by the District Court for the Southern District of New York by order dated November 3, 2022 [Docket No. 225 in Case No. 22-50592].

F. General Litigation (Task Code B191) Fees: \$216,738.00 Total Hours: 207.40

121. During the Fee Period, Paul Hastings attorneys prepared and filed Genever (US)'s and the Trustee's complaint against the Individual Debtor and members of his immediate family to terminate their occupancy of the Sherry Netherland Apartment (which occupancy was governed pursuant to an agreement between Genever (US) and the Sherry Netherland). In addition to the complaint, the Trustee and Paul Hastings also prepared a motion for summary judgment as well as related pleadings. At this time, this adversary proceeding remains pending.

Case 22-50073 Doc 1831 Filed 05/30/23 Entered 05/30/23 08:41:26 Page 58 of 1334

122. In addition, during the Fee Period, Paul Hastings attorneys prepared Genever (US)'s complaint in the Bravo Luck Litigation (which complaint was substantially similar to the complaint filed by the Trustee against Bravo Luck).

$$\text{G.} \quad \begin{array}{c} \text{Business Operations (Task Code B210)} \\ \text{Fees: } \\$16,709.00 \qquad \text{Total Hours: } 17.90 \end{array}$$

123. During the Fee Period, Paul Hastings attorneys analyzed operational matters with respect to Genever (US), including related to the insurance that Paul Hastings and NPM discovered Genever (US) was providing for several luxury cars used by the Individual Debtor, his associates and/or his family. In addition, Paul Hastings analyzed issues related to the Individual Debtor's occupancy of the Sherry Netherland Apartment, including whether such occupancy could be terminated.

A. General Litigation (Task Code B191) Fees: \$22,030.50 Total Hours: 20.60

124. In addition, during the Fee Period, Paul Hastings attorneys prepared Genever (BVI)'s complaint in the Bravo Luck Litigation (which complaint was substantially similar to the complaint filed by the Trustee against Bravo Luck).

125. Section 331 of the Bankruptcy Code provides for interim compensation of professionals and incorporates the substantive standards of section 330 of the Bankruptcy Code to govern the Court's award of such compensation. Section 330(a) of the Bankruptcy Code provides that, after notice and a hearing, the Court may award a professional employed under 11 Case 22-50073 Doc 1831 Filed 05/30/23 Entered 05/30/23 08:41:26 Page 59 of 1334

U.S.C. § 327 "reasonable compensation for actual, necessary services rendered" and "reimbursement for actual, necessary expenses." 11 U.S.C. § 330(a)(1).57

126. In determining the amount of "reasonable compensation," the Court must consider the nature, extent, and value of the services, taking into account all the relevant factors, including the time spent on such services, the rates charged for such services, whether the services were necessary and beneficial, whether the services were performed in a reasonable amount of time commensurate with the complexity, importance, and nature of the problem, issue, or task addressed, and whether the compensation is reasonable based on the customary compensation charged by comparably skilled practitioners in cases other than cases under the Bankruptcy Code. See 11 U.S.C. § 330(a)(3). The Court enjoys "considerable discretion in determining reasonable fee awards." In re Ahead Communication Systems, Inc., 395 B.R. 512 (D. Conn. 2008).

127. In assessing the "reasonableness" of the fees requested, the Second Circuit has stated that courts should consider the factors enumerated in Johnson v. Ga. Highway Express, Inc., 58 while also incorporating the "lodestar method." See Arbor Hill Concerned Citizens Neighborhood Ass'n v. County of Albany and Albany County Bd. of Elections, 522 F.3d 182, 190 (2d Cir. 2007) (citing Johnson v. Ga. Highway Express, Inc., 488 F.2d 714 (5th Cir.1974), abrogated on other grounds by Blanchard v. Bergeron, 489 U.S. 87, 92–93, 96 (1989)). The

57 Under section 328(a) of the Bankruptcy Code, with bankruptcy court approval, a trustee may employ professional persons under section 327(a) of the Bankruptcy Code "on any reasonable terms and conditions of employment, including on a retainer, on an hourly basis, on a fixed or percentage fee basis, or on a contingent fee basis." 11 U.S.C. § 328(a).

58 The twelve Johnson factors are (1) the time and labor required, (2) the novelty and difficulty of the questions, (3) the skill requisite to perform the legal service properly, (4) the preclusion of other employment by the attorney due to acceptance of the case, (5) the customary fee, (6) whether the fee is fixed or contingent, (7) the time limitations imposed by the client or the circumstances, (8) the amount involved and the results obtained, (9) the experience, reputation, and ability of the attorneys, (10) the "undesirability" of the case, (11) the nature and length of the professional relationship with the client, and (12) awards in similar cases. Johnson, 488 F.2d at 717-19. Case 22-50073 Doc 1831 Filed 05/30/23 Entered 05/30/23 08:41:26 Page 60 of 1334

"lodestar method" of calculating the reasonable fee contemplates "the number of hours

reasonably expended . . . multiplied by a reasonable hourly rate." See Hensley v. Eckerhart, 461

U.S. 424, 433 (1983); Gisbrecht v. Barnhart, 535 U.S. 789, 801 (2002); Perdue v. Kenny A., 130

S.Ct. 1662, 1672 (2010); In re Drexel Burnham Lambert Grp., Inc., 133 B.R. 13 (Bankr.

S.D.N.Y. 1991). The factors set forth in Johnson and In re First Colonial Corp. of Am., 544

F.2d 1291, 1298–99 (5th Cir. 1977) have been adopted by most courts.59 See In re Nine Assocs.,

Inc., 76 B.R. 943, 945 (S.D.N.Y. 1987) (adopting First Colonial/Johnson analysis); In re Cuisine

Magazine, Inc., 61 B.R. 210, 212–13 (Bankr. S.D.N.Y 1986) (same); Green v. City of New York,

403 F. Appx. 626, 629 (2d Cir. 2010) (summary order); see generally 3 COLLIER ON

BANKRUPTCY ¶ 330.03[9] (Lawrence P. King ed., 16th ed. 2016) (describing First Colonial

and Johnson as the "leading cases with regard to the factors to be considered in determining a

reasonable allowance of compensation").

128. In accordance with the factors enumerated in section 330 of the Bankruptcy Code and applicable case law, the amount requested herein by Paul Hastings is fair and reasonable, as set forth below and otherwise in this Application.

Paul Hastings billed a total of \$12,324,802.00 and 10,595.90 hours, respectively, of professional and paraprofessional services during the Fee Period. As evidenced by this Application, Paul Hastings professionals and paraprofessionals worked diligently and efficiently without unnecessary duplication of efforts throughout the Fee Period. A small group of the same Paul Hastings attorneys was utilized for the vast majority of the work in order to minimize the costs of intra-Paul Hastings communication and education about the Debtors' circumstances. Whenever possible, Paul Hastings sought to minimize the cost of Paul Hastings' services by utilizing talented junior attorneys and paraprofessionals to handle the more routine aspects of the assignments. The services were performed in an effective and efficient manner commensurate with

59 The factors articulated in First Colonial were first articulated by the Fifth Circuit in Johnson, with the First Colonial court adding the factor of the "spirit of economy," which was later rejected by Congress. See Stroock & Stroock & Lavan v. Hillsborough Holdings Corp. (In re Hillsborough Holdings Corp.), 127 F.3d 1398, 1403 (11th Cir. 1997).

the complexity, exigency, and importance of the issues involved. In addition, Paul Hastings' representation has required it to balance the need to provide quality services with the need to act quickly and represent the Trustee and the Genever Debtors in an effective, efficient, and timely manner. Paul Hastings submits that the hours spent were reasonable given the size and complexity of these chapter 11 cases, the significant, and often urgent, legal and business issues raised, and the numerous pleadings filed in the chapter 11 cases. Furthermore, as noted detailed above, the Trustee and the Genever Debtors also retained NMP as local and conflicts counsel in order to provide services to the Trustee and the Genever Debtors in a cost-effective manner. Paul Hastings and NPM have coordinated and will continue to coordinate each firm's respective responsibilities in connection with the representation of the Trustee and the Genever Debtors. b. Novelty and Difficulty of the Questions

Paul Hastings tasked knowledgeable attorneys to research, analyze, and advise the Trustee and the Genever Debtors on difficult and complex issues during the Fee Period, including issues related to bankruptcy and litigation. Most notably, as detailed in this Application, Paul Hastings investigated complex estate claims and causes of action in order to seek to recover assets of these estates. c. Skill Requisite to Perform the Legal Services Properly

Paul Hastings believes that its recognized expertise in the areas of financial restructuring and corporate reorganization, its ability to draw from highly experienced professionals in other areas of Paul Hastings' practice, and its creative approach to the resolution of issues has contributed to the effective administration of these chapter 11 cases and benefited the Trustee, the Genever Debtors, their estates, and their unsecured creditors. Due to the nature and complexity of the legal issues presented by these chapter 11 cases, Paul Hastings was required to exhibit a high degree of legal skill in areas related to, among others, bankruptcy and litigation. d. Preclusion of Other Employment by Applicant Due to Acceptance of the Case

Due to the size of Paul Hastings' restructuring and litigation departments, Paul Hastings' representation of the Trustee and the Genever Debtors did not preclude its acceptance of new clients, but the demands for immediate and substantive action in these chapter 11 cases imposed significant burdens on Paul Hastings professionals and paraprofessionals working concurrently on other matters. That said, for the Trustee, his engagement as a chapter 11 trustee has, for all practical purposes precluded other employment given that this matter is taking up most of his time and there frequently are two hearings per week.

The fees charged by Paul Hastings in these chapter 11 cases are billed in accordance with its existing billing rates and procedures in effect during the Fee Period. The rates Paul Hastings charges for the services rendered by its professionals and paraprofessionals in these chapter 11 cases are comparable to

the rates Paul Hastings charges for professional and paraprofessional services rendered in comparable nonbankruptcy related matters. Moreover, when Paul Hastings' restructuring professionals and paraprofessionals work on nonbankruptcy matters, the firm generally charges their standard rate. Such fees are reasonable based on the customary compensation charged by comparably skilled practitioners in comparable nonbankruptcy cases in a competitive national legal market. In addition, the firm's customary hourly rates and rate structure reflect that restructuring and related matters typically involve great complexity, numerous tasks requiring a high level of expertise, and severe time pressures, as is the case here. f. Whether the Fee Is Fixed or Contingent

Pursuant to Bankruptcy Code sections 330 and 331, all fees sought by professionals employed under Bankruptcy Code section 1103 are subject to final approval by the Court, and are subject to adjustment depending on the services rendered and the results obtained. Of particular note, payment of Paul Hastings' fees here was contingent in two respects: (1) the recovery of assets for the benefit of the estates and (2) monetizing such assets. At the outset of these chapter 11 cases, there was no assurance whatsoever that assets would be recovered and monetized to allow for the payment of estate professionals. Accordingly, Paul Hastings' compensation is, in essence, a contingency fee arrangement. The risk that Paul Hastings assumed by representing the Trustee and the Genever Debtors further supports the reasonableness of Paul Hastings' compensation. g. Time Limitations Imposed by the Client or Other Circumstances

During the Fee Period, Paul Hastings was required to analyze and address certain issues arising in these chapter 11 cases under compressed timelines. For example, given the Individual Debtor's track record of moving assets to keep them out of reach of creditors, it was critical that Paul Hastings act quickly on information obtained during the Trustee's investigation in order to freeze assets.

Paul Hastings professionals and paraprofessionals worked diligently to maximize value for these chapter 11 estates. During the Fee Period, and as described in the summary of services herein, Paul Hastings was instrumental in analyzing potential sources of recovery for the benefit of these estates. As a result of Paul Hastings' efforts, the Trustee has been able to recover the Lady May and \$37 million in escrow funds for the benefit of these estates. Moreover, during the Fee Period, Paul Hastings was able to secure several key rulings from the Court, which rulings will serve as a beachhead for future asset recovery efforts. The reasonableness of Paul Hastings' fees must be evaluated in light of this important strategic factor as well. i. Experience, Reputation, and Ability of Attorneys

Paul Hastings is consistently recognized as a top tier law firm in the field of business reorganizations and liquidations under chapter 11. During the

Application Period, Paul Hastings solicited the skill and expertise of its professionals and paraprofessionals. Paul Hastings professionals have actively represented debtors, creditors, and creditors' committees, as well as other parties in interest, in a number of the nation's largest chapter 11 cases as well as in connection with cross-border restructurings. Paul Hastings' extensive experience enables it to perform the services described herein competently and expeditiously. In addition to its expertise in the area of corporate reorganization, Paul Hastings has called upon the expertise of its attorneys in other practice areas as required during the Fee Period.

As detailed in this Application, the Individual Debtor's in-court and out-of-court tactics illustrate the undesirability of this engagement, which involved harassment of the Trustee and Paul Hastings attorneys (including death threats against the Trustee). As a result, Paul Hastings was forced to incur hundreds of thousands of dollars in cyber security measures (the cost of which are not part of the expenses for which Paul Hastings is seeking reimbursement in this Application). In addition, Paul Hastings has been unable to get paid for its fees for almost a year. k. Nature and Length of Professional Relationship

Paul Hastings has been rendering professional services to (a) the Trustee since its retention as counsel effective as of July 8, 2022, (b) Genever (BVI) since its retention as counsel effective as of October 11, 2022, and (c) Genever (US) since its retention as counsel effective as of November 3, 2022.

129. Paul Hastings respectfully submits that the services for which it seeks

compensation in this Fee Application were, at the time rendered, necessary for and beneficial to the Debtors' estates and their creditors and were rendered to maximize, protect, and preserve value for the Debtors' estates and all parties in interest. Paul Hastings believes that it provided services economically, effectively, and efficiently, and obtained results beneficial to the Debtor's estate and his creditors. Paul Hastings further submit that the compensation requested herein is reasonable in light of the nature, extent, and value of the services rendered during the Fee Period.

130. Paul Hastings also notes that the rates charged during the Fee Period are reasonable. In fact, this Court recently held that Paul Hastings' New York rates are reasonable because Paul Hastings was retained at New York rates and these cases are extraordinary within this District. See Order Denying Motion for Stay Pending Appeal [Docket No. 1791]. Case 22-50073 Doc 1831 Filed 05/30/23 Entered 05/30/23 08:41:26 Page 64 of 1334

131. All fees incurred by Paul Hastings during the Fee Period were actual, reasonable, and necessary in the performance of services for the Trustee and the Genever Debtors. Paul Hastings respectfully requests approval of the compensation sought herein.

132. As set forth in Exhibit C hereto, Paul Hastings incurred and disbursed

\$348,813.54 as expenses in providing professional services during the Fee Period (exclusive of the period from July 8, 2022 through October 31, 2022). These expenses include approximately \$56,000.46 for online legal research (i.e., LEXIS and Westlaw). Because Paul Hastings believes that online legal research (e.g., LEXIS and Westlaw) is far more cost-efficient than manual research using hard-bound volumes, Paul Hastings encourages computerized legal research even though it is not a profit center for Paul Hastings. To be clear, Paul Hastings does not charge a mark-up on the LEXIS and Westlaw charges, but merely passes on the costs of such third-party services. Moreover, as it relates to outside professional services, mailing, and other servicerelated expenses, the Trustee and Paul Hastings are merely passing on the costs of such thirdparty services, without any mark-up.60

133. Additional necessary expenses included:

- \$205,384.51 for certain outside professional services, such as document review services by UnitedLex (\$155,387.75), translation services by TransPerfect Translations (\$32,541.37) and Divergent Language Solutions (\$6,595.06), and Mr. Paul Wright, as the U.K. barrister (\$10,478.43); - \$20,886.35 for court reporting services; - \$15,991.72 for document reproductions, namely \$14,574.72 b/w reproductions (at 8 cents per page) and \$1,417.00 for color reproductions (at 20 cents per page);

60 Documentation of these expenses will be made available to the Court upon request.

- \$15,384.88 for process servers (e.g., Metro Attorney Service Inc.) to serve, among other things, the subpoenas issued pursuant to the Rule 2004 orders entered by this Court; - \$8,819.43 for UPS/courier service, including service of pleadings required to be served in hard copy format; and - \$4,606.52 for corporate document retrieval services (including United Corporate Service and Corp200) with respect to various Kwok-related entities.

134. During the Fee Period, Paul Hastings utilized UnitedLex—a third party vendor that specializes in discovery services including document processing, storage, review services, and distribution—to conduct document review of the documents produced in the chapter 11 cases, including the more than 140,000 discovery documents received by the Trustee to date in connection with his investigation.

135. Using their own contract attorneys and review team managers, UnitedLex provides an efficient and economic means of reviewing large document sets at hourly rates significantly lower than Paul Hastings. UnitedLex's document review team charges hourly rates ranging from \$40 to \$55 (for non-management roles) and \$150 (for management role), which is substantially less than Paul Hastings' hourly rates and, moreover, is even less than the hourly rates of associates of local Connecticut counsel (i.e., NPM), which rates range from \$200 to \$400. For all these reasons, Paul Hastings believes that utilizing UnitedLex to utilize their document review team greatly benefits these estates by reducing document review costs. The Trustee also previewed Paul Hastings' use of UnitedLex with the U.S. Trustee, who had no objection thereto (without the Trustee having to file a separate retention application for UnitedLex). The Trustee and Paul Hastings also disclosed in the Fourth Supplemental Declaration of Disinterestedness of Luc A. Despins [Docket No. 1435] that Paul Hastings would utilize UnitedLex's contract attorneys services. Case 22-50073 Doc 1831 Filed 05/30/23 Entered 05/30/23 08:41:26 Page 66 of 1334

136. The time constraints imposed by the circumstances of the matters handled by Paul Hastings during the Fee Period required its attorneys and other employees, at times, to devote substantial time during the evenings and on weekends to perform legal services on behalf of the Trustee. These extraordinary services were essential to meet deadlines, timely respond to inquiries on a daily basis, and satisfy the Trustee's needs and demands. Attorneys and other Paul Hastings employees who worked late in the evenings or on weekends were reimbursed for their reasonable meal and transportation costs in accordance with firm policy. Paul Hastings' regular practice is not to include components for those charges in overhead when establishing billing rates, but rather to charge its clients for these and all other out-of-pocket disbursements incurred during the regular course of the provision of legal services.

137. In accordance with Appendix D (Guidelines for Compensation and Expense Reimbursement of Professionals) to the Local Rules, reproduction charges have been capped at 20 cents per page. 61

138. The expenses requested herein are customarily charged to non-bankruptcy clients of Paul Hastings. Additionally, the expenses incurred by Paul Hastings to third parties are limited to the actual amounts billed to, or paid by, Paul Hastings on behalf of the estates.

139. Paul Hastings believes the rates for charges incurred are the market rates that the majority of law firms charge clients for such services. In addition, Paul Hastings believes that such charges are in accordance with the American Bar Association's ("ABA") guidelines, as set forth in the ABA's Statement of Principles, dated January 12, 1995, regarding billing for disbursements and other charges.

61 Generally, Paul Hastings charges 8 cents per page for black-and-white reproductions and 50 cents per page for color reproductions. In accordance with Appendix D to the Local Rules, Paul Hastings has reduced the charge for color reproductions to 20 cents per page.

140. The expenses incurred in providing professional services in the Chapter 11 Case

were necessary, economical, and justified under the circumstances.

141. Paul Hastings responds to the questions set forth in Paragraph C.5. of the U.S.

Trustee Guidelines as follows:

Question: Did you agree to any variations from, or alternatives to, your standard or customary billing rates, fees, or terms for services pertaining to this engagement that were provided during the Fee Period?

Response: Yes. As a courtesy to these estates, Paul Hastings is not seeking allowance or payment at this time of the fees incurred by fourteen (14) timekeepers who billed less than ten (10) hours during the Fee Period. The total amount of such fees is \$55,980.00. The time billed by these timekeepers was reasonable, and Paul Hastings reserves the right to seek allowance of these fees based on the facts and circumstances of these cases, including, without limitation, if objections are interposed to the allowance of Paul Hastings' fees and expenses. Question: If the fees sought in this application as compared to the fees

discuss the reasons for the variation with the client. Response: Not applicable. Question: Have any of the professionals included in this application varied their hourly rate based on the geographic location of the bankruptcy case? Response: No. Question: Does the application include time or fees related to reviewing or revising time records or preparing, reviewing, or revising invoices? (This is limited to work involved in preparing and editing billing records that would not be compensable outside of bankruptcy and does not include reasonable fees for preparing a fee application.) If so, please quantify by hours and fees. Response: The Application does not include time for preparing, reviewing, or revising time records. However, the Application does include

approximately 27.4 hours and associated fees of approximately \$42,846.00 related to preparing, reviewing, and revising Paul Hastings' fee statements and ensuring time entries are properly categorized by matter number and task code. On average, less than 3.5 hours were spent on each of the eight monthly fee statements prepared during the Fee Period.

Question: Does this application include time or fees for reviewing time records to redact any privileged or other confidential information? If so, please quantify by hours and fees.

Response: No.

- Question: If the application includes any rate increases since retention: (i) Did your client review and approve those rate increases in advance? (ii) Did your client agree when retaining the law firm to accept all future rates increases? If not, did you inform your client that they need not agree to modified rates or terms in order to have you continue the representation consistent with ABA Formal Ethics Opinion 11-458? - Response: As is customary, Paul Hastings adjusts its hourly rates periodically based upon (i) the advancing seniority of its professionals and paraprofessionals, (ii) the current market for legal services, (iii) the rates charged for comparable non‐bankruptcy services, and (iv) the firm's analysis of the hourly rates being charged by professionals in other law firms. Effective January 1, 2023, Paul Hastings adjusted its hourly rates consistent with the Retention Order [Docket No. 668] and the Notice of Change in Hourly Rates of Paul Hastings LLP, Counsel to Chapter 11 Trustee [Docket No. 1251].

142. To the extent that time or disbursement charges for services rendered or expenses incurred during the Fee Period are not included in this Application, or the Trustee and Paul Hastings have for any reason not sought compensation or reimbursement with respect to such services, Paul Hastings reserves the right to request compensation and reimbursement for such services in a supplemental or future application in the Debtors' chapter 11 cases. In addition, Paul Hastings reserves the right to seek payment from the HK Parties pursuant to the Sanctions Order. Also, Paul Hastings does not waive, and expressly reserve, their right to respond to any

objections regarding this Application and the amounts sought for services rendered and expenses incurred.

143. No previous request for the relief sought herein has been made to this Court or any other court.

[Remainder of page intentionally left blank.] Case 22-50073 Doc 1831 Filed 05/30/23 Entered 05/30/23 08:41:26 Page 70 of 1334

WHEREFORE, Paul Hastings respectfully request entry of an order, substantially in the form attached hereto as Exhibit F, (i) allowing interim compensation for professional services rendered during the Fee Period in the amount of \$12,324,802.00 and reimbursement of \$348,813.54, (ii) authorizing and directing prompt payment from the chapter 11 estate of the Individual Debtor, (iii) allowing such compensation and payment for professional services rendered and reimbursement of actual and necessary expenses incurred without prejudice to the Trustee's and Paul Hastings' right to seek further compensation and/or payment from the Debtors' estates for the full value of services performed and expenses incurred, and (iv) granting the Trustee and Paul Hastings such other and further relief as is just.

Dated: May 30, 2023 New Haven, Connecticut

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

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

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

Counsel for the Chapter 11 Trustee, Genever Holdings Corporation, and Genever Holdings LLC UNITED STATES BANKRUPTCY COURT DISTRICT OF CONNECTICUT BRIDGEPORT DIVISION

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

In re: :

et al., : :

Debtors. :

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

The undersigned hereby certifies that on May 29, 2023, the foregoing Application 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.2 In addition, to the extent not covered by the foregoing, copies of the Application were served on the twenty (20) largest creditors in the Debtors' chapter 11 cases. Parties may access this filing through the Court's CM/ECF system.

Dated: May 30, 2023 New Haven, Connecticut

> 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

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 To the extent that the foregoing was filed outside regular business hours, service by mail on recipients unable or not qualified to accept electronic notice was made on the next business day.

Case 22-50073 Doc 1831 Filed 05/30/23 Entered 05/30/23 08:41:26 Page 73 of

Customary and Comparable Compensation Disclosures

The blended hourly rate for Paul Hastings' timekeepers in its New York office who billed to non-bankruptcy matters (collectively, the "Non-Bankruptcy Matters")1 during the twelve-month period beginning on March 1, 2022 and ending on February 28, 2023 was, in the aggregate, approximately \$1,087 per hour. The blended hourly rate for Paul Hastings' timekeepers who billed to the Debtor's chapter 11 cases during the Fee Period was approximately \$1,163 per hour. A detailed comparison of these rates follows:

Category of Timekeeper Blended Hourly Rate

Blended Hourly Rate Debtor Blended Hourly

All Timekeepers Aggregated \$1,087 \$1,163

1 It is the nature of Paul Hastings' practice that certain non-bankruptcy engagements require the advice and counsel of professionals and paraprofessionals who work primarily within Paul Hastings' restructuring group. Accordingly, Non-Bankruptcy Matters consist of matters for which Paul Hastings' timekeepers represented a client in matters other than court-approved engagements as counsel for the debtor, the chapter 11 trustee, or an official committee under the Bankruptcy Code. As such, the Non-Bankruptcy Matters include, in part, time billed by Paul Hastings' timekeepers who work primarily within Paul Hastings' restructuring group.

2 Luc A. Despins, the lead attorney on this matter and the co-chair of Paul Hastings' Global Restructuring Practice, brings to the Title III Cases over 35 years of experience representing debtors and creditors in high profile and complex restructuring matters. Given the complexity and challenges faced by the Trustee in these cases, a significant amount of time by senior partners, of counsel, and senior associates, including Mr. Despins, Nicholas Bassett, Alexander Bongartz, Avi Luft, Douglass Barron, and Shlomo Maza has been necessary. Because their rates are at the higher end of the range of rates billed by Paul Hastings partners, of counsel, and associates, respectively, and in light of the fact that a significant amount of senior partner, of counsel, and senior associate time has been required for this engagement, the blended rate for this case moved to the higher end of the range of rates billed by Paul Hastings. Finally, the blended attorney hourly rate for the Fee Period is not comparable to the average hourly rate in other matters because it does not reflect numerous cost-saving measures, including the delegation of a variety of matters to NPM, matters for which otherwise more junior Paul Hastings attorneys with lower hourly rates would have been used, thereby reducing Paul Hastings' blended hourly rate. Case 22-50073 Doc 1831 Filed 05/30/23 Entered 05/30/23 08:41:26 Page 75 of 1334

Summary of Timekeepers Included in this Application

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Case 22-50073 Doc 1831 Filed 05/30/23 Entered 05/30/23 08:41:26 Page 76 of 1334

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Case 22-50073 Doc 1831 Filed 05/30/23 Entered 05/30/23 08:41:26 Page 78 of 1334

Summary of Timekeepers Not Included in this Application1

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1 As noted, as an accommodation to these estates, Paul Hastings is not seeking allowance or payment at this time for the fees (a) of timekeepers who billed less than ten (10) hours during the Fee Period in the aggregate amount of \$55,980.00. The time billed by these timekeepers was reasonable, and Paul Hastings reserves the right to seek allowance of these fees based on the facts and circumstances of these cases, including, without limitation, if objections are interposed to the allowance of Paul Hastings' fees and expenses.

2 In light of the Individual Debtor's well-documented social media intimidation campaign during these chapter 11 cases, which was, among others, also directed at Paul Hastings attorneys, Paul Hastings has redacted in this Application (and the related fee statements) the names of Mandarin-speaking attorneys. Case 22-50073 Doc 1831 Filed 05/30/23 Entered 05/30/23 08:41:26 Page 79 of 1334

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Summary of Compensation by Project Category

B111 Schedules and Statements of Financial Affairs \$6,789.00

B120 Asset Analysis and Recovery \$617,318.00

B150 Meetings of and Communications with Creditors \$1,250.00

B160 Employment / Fee Applications (Paul Hastings) \$178,218.50

B165 Employment / Fee Applications (Other Professionals) \$107,976.00 B190 Other Contested Matters \$950,257.00

B211 Financial Reports (Monthly Operating Reports) \$32,405.50

B310 Claims Administration and Objections \$466,280.50 B320 Plan and Disclosure Statement \$119,406.00

Case 22-50073 Doc 1831 Filed 05/30/23 Entered 05/30/23 08:41:26 Page 81 of 1334

Summary of Actual and Necessary Expenses (November 2022 through February 2023)

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Case 22-50073 Doc 1831 Filed 05/30/23 Entered 05/30/23 08:41:26 Page 82 of 1334

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Case 22-50073 Doc 1831 Filed 05/30/23 Entered 05/30/23 08:41:26 Page 84 of 1334

*PAUL HASTINGS LLP 1117 S California Avenue, Palo Alto, CA 94304-1106 t: +1 650 320 1800 f: +1 650 320 1900 www paulhastings com*

Luc Despins as Chapter 11 Trustee in thecase of Ho Wan Kwok 200 Park Avenue New York, NY 10166 May 23, 2023 Please Refer to Invoice Number: 2356905

Attn: Luc Despins PH LLP Tax ID No. 95-2209675

General Chapter 11 Trustee Representation

PH LLP Client/Matter # 50687-00001 Luc A. Despins

Legal fees for professional services for the period ending July 31, 2022 \$347,642.50

Total Balance Due - Due Upon Receipt \$347,642.50

We encourage our clients to pay via ACH, however, in the event that you pay by check, please send payment to the remittance address below:

*TO PROTECT AGAINST FRAUD, the Firm will not change its wiring instructions via email. We strongly encourage clients to confirm any change in wiring instructions by contacting Teri Goffredo @ 213-683-5045 or via email @ terigoffredo@paulhastings.com and requesting written and verbal confirmation.* Wiring and ACH Instructions: Remittance Address:

Citibank Paul Hastings LLP ABA # 322271724 Lockbox 4803 SWIFT Address: CITIUS33 PO Box 894803 787 W. 5th Street Los Angeles, CA 90189-4803 Los Angeles, CA 90071 Account Number: 206628380 Account Name: Paul Hastings LLP

*For wires, please reference the invoice, client and matter number(s) being paid For ACH payments, please use the CTX format and/or send any remittances to cashepn@paulhastings com This is a no-reply mailbox*

Case 22-50073 Doc 1831 Filed 05/30/23 Entered 05/30/23 08:41:26 Page 85 of 1334

*PAUL HASTINGS LLP 1117 S California Avenue, Palo Alto, CA 94304-1106 t: +1 650 320 1800 f: +1 650 320 1900 www paulhastings com*

Luc Despins as Chapter 11 Trustee in thecase of Ho Wan Kwok 200 Park Avenue New York, NY 10166 May 23, 2023 Please Refer to Invoice Number: 2356905

Attn: Luc Despins PH LLP Tax ID No. 95-2209675

General Chapter 11 Trustee Representation

PH LLP Client/Matter # 50687-00001 Luc A. Despins

Legal fees for professional services for the period ending July 31, 2022 \$347,642.50

Total Balance Due - Due Upon Receipt \$347,642.50

We encourage our clients to pay via ACH, however, in the event that you pay by check, please send payment to the remittance address below:

*TO PROTECT AGAINST FRAUD, the Firm will not change its wiring instructions via email. We strongly encourage clients to confirm any change in wiring instructions by contacting Teri Goffredo @ 213-683-5045 or via email @ terigoffredo@paulhastings.com and requesting written and verbal confirmation.* Wiring and ACH Instructions: Remittance Address:

Citibank Paul Hastings LLP ABA # 322271724 Lockbox 4803 SWIFT Address: CITIUS33 PO Box 894803 787 W. 5th Street Los Angeles, CA 90189-4803 Los Angeles, CA 90071 Account Number: 206628380 Account Name: Paul Hastings LLP

*For wires, please reference the invoice, client and matter number(s) being paid For ACH payments, please use the CTX format and/or send any remittances to cashepn@paulhastings com This is a no-reply mailbox*

Case 22-50073 Doc 1831 Filed 05/30/23 Entered 05/30/23 08:41:26 Page 86 of 1334

*PAUL HASTINGS LLP 1117 S California Avenue, Palo Alto, CA 94304-1106 t: +1 650 320 1800 f: +1 650 320 1900 www paulhastings com*

Luc Despins as Chapter 11 Trustee in thecase of Ho Wan May 23, 2023

New York, NY 10166 Invoice Number: 2356905

Attn: Luc Despins PH LLP Tax ID No. 95-2209675

FOR PROFESSIONAL SERVICES RENDERED for the period ending July 31, 2022 General Chapter 11 Trustee Representation \$347,642.50

Date Initials Description Hours Rate Amount

07/08/2022 AB21 Correspond with L. Despins regarding chapter 11 trustee role and responsibilities

regarding same (0.1); correspond with L. Despins regarding scheduling call with U.S. Trustee regarding open items (0.1) 0.30 1,510.00 453.00 07/08/2022 AB21 Calls with D. Barron regarding case

hac vice applications (0.2) 0.50 1,510.00 755.00 07/08/2022 DEB4 Calls with A. Bongartz regarding case

07/08/2022 DEB4 Correspond with P. Linsey (Neubert) regarding pro hac vice applications (0.1); correspond with T. Sadler regarding trustee

07/08/2022 LAD4 T/c B. Stark (Brown Rudnick) re: opening

documents on case and NY state litigation

Date Initials Description Hours Rate Amount

07/08/2022 AEL2 Review background case information (.1); review pro hac vice applications (.1) 0.20 1,510.00 302.00 07/08/2022 ML30 Correspond with W. Wu re working group list (.2); review same (.1) 0.30 515.00 154.50 07/08/2022 NAB Conferences and correspond with prospective local counsel (.5); calls with L. Despins regarding same (.3) 0.80 1,510.00 1,208.00 07/08/2022 NAB Correspond with A. Bongartz regarding background and engagement issues (.2);

related papers (.3) 0.50 1,510.00 755.00 07/08/2022 TS21 Correspond with D. Barron and

bond (.3); analyze issues regarding same (.9). 1.20 1,030.00 1,236.00 07/08/2022 WW6 Prepare working group list 1.40 250.00 350.00 07/09/2022 AB21 Correspond with N. Bassett and A. Luft regarding pro hac vice applications (0.1);

regarding same (0.1) 0.20 1,510.00 302.00 07/09/2022 DEB4 Correspond with L. Despins regarding Debtor's social media posts (0.1) 0.10 1,225.00 122.50 07/10/2022 KC27 Research and review chapter 11 trustee communication procedures 3.00 775.00 2,325.00 07/10/2022 LAD4 Review background documents re: NY state

07/10/2022 NAB Continue to review case background and related documents (.6) 0.60 1,510.00 906.00 07/10/2022 WW6 Update spreadsheet information for certain parties in the Kwok bankruptcy case 4.00 250.00 1,000.00 07/11/2022 AB21 Call with L. Despins and H. Claiborn (US Trustee) regarding general case background (1.1); call with D. Barron regarding case update and task list (0.2); correspond with P. Linsey (Neubert) regarding pro hac vice applications (0.1) 1.40 1,510.00 2,114.00

Date Initials Description Hours Rate Amount

07/11/2022 DEB4 Conference (portion) with H. Claiborn

regarding onboarding issues 0.50 1,225.00 612.50 07/11/2022 DEB4 Correspond with T. Sadler regarding trustee

07/11/2022 DEB4 Correspond with P. Linsey (Neubert) regarding pro hac vice applications 0.40 1,225.00 490.00 07/11/2022 DEB4 Conference with J. Austin regarding information security issues in connection

with N. Bassett regarding IT security (0.1) 0.40 1,225.00 490.00 07/11/2022 DEB4 Call with A. Bongartz regarding case strategy and next steps 0.20 1,225.00 245.00 07/11/2022 LAD4 T/c B. Baldiga (Brown Rudnick) re: status (.10); t/c H. Claiborn (US Trustee) and A. Bongartz, D. Barron re: update on case and next steps (1.10); t/c I. Goldman (Pullman) re: introduction (.30); t/c P. Friedman, S.

(.40); t/c C. Callari (Callari Partners) re: introduction and next steps (.40) 2.30 1,860.00 4,278.00 07/11/2022 AEL2 Correspond with P. Linsey (Neubert) regarding pro hac vice application 0.20 1,510.00 302.00 07/11/2022 NAB Review pro hac vice application and related

(Neubert) regarding same (.2) 0.40 1,510.00 604.00 07/11/2022 TS21 Prepare surety bond application (1.4);

07/11/2022 WW6 Prepare distribution list for working group 0.30 250.00 75.00 07/11/2022 WW6 Update working group list 0.30 250.00 75.00 07/11/2022 WW6 Update spreadsheet of information for certain parties in the Kwok bankruptcy case (1.1); correspond with E. Sutton regarding

Case 22-50073 Doc 1831 Filed 05/30/23 Entered 05/30/23 08:41:26 Page 89 of 1334

Luc Despins as Chapter 11 Trustee in thecase of Ho Wan Kwok 50687-00001 Invoice No. 2356905

Date Initials Description Hours Rate Amount

07/12/2022 DEB4 Correspond with T. Sadler regarding trustee

(US Trustee) regarding Debtor's application

(Verdolino & Lowey) regarding same (0.1);

service issues (0.1); correspond with P. Linsey (Neubert) regarding same (0.1);

07/12/2022 LAD4 T/c I. Goldman (Pullman) re: Kindseth's email (.10); t/c P. Friedman & S. Sarnoff

review of key NY State litigation (3.10) 3.60 1,860.00 6,696.00 07/12/2022 TS21 Correspond with insurance providers and

bank account (.7); correspond with D. Barron regarding same (.2) 0.90 1,030.00 927.00 07/12/2022 WW6 Update working group list 0.40 250.00 100.00 07/12/2022 WW6 Update case calendar 1.20 250.00 300.00 07/12/2022 WW6 Correspond with court regarding CM/ECF filing privileges for L. Despins 0.30 250.00 75.00 07/12/2022 WW6 Prepare declaration of disinterestedness of L. Despins for filing (.2); correspond with A. Bongartz regarding same (.1); electronically file same with court (.3) 0.60 250.00 150.00 07/13/2022 AB21 Review draft of global task list (0.3); call with D. Barron regarding same (0.5) 0.80 1,510.00 1,208.00 07/13/2022 DEB4 Prepare task list for trustee counsel

Case 22-50073 Doc 1831 Filed 05/30/23 Entered 05/30/23 08:41:26 Page 90 of 1334

Luc Despins as Chapter 11 Trustee in thecase of Ho Wan Kwok 50687-00001 Invoice No. 2356905

Date Initials Description Hours Rate Amount

07/13/2022 DEB4 Correspond with A. Bongartz and N. Bassett regarding workstreams (0.2);

regarding section 341 meeting transcripts

07/13/2022 DEB4 Conferences with T. Sadler regarding trustee bond (0.4); correspond with T. Sadler regarding same (0.1) 0.50 1,225.00 612.50 07/13/2022 TS21 Continue to prepare surety bond application

provider regarding same (.4); review issues regarding monthly operating reports (.7);

07/14/2022 DEB4 Call J. Morrissy (Zeichner) regarding estate

conference with T. Sadler regarding trustee bond and bank account opening (0.4);

Bank) regarding account opening (0.2);

regarding trustee bond and related issues (0.5); correspond with L. Despins regarding

regarding estate expenses (0.1) 2.00 1,225.00 2,450.00 07/14/2022 LAD4 Continue NY state litigation review 1.50 1,860.00 2,790.00 07/14/2022 TS21 Correspond and call with D. Barron

(.4); review issues regarding EIN (.5) 0.90 1,030.00 927.00 07/14/2022 WW6 Update working group list 0.20 250.00 50.00 07/14/2022 WW6 Create email distribution list for advisors

07/15/2022 DEB4 Correspond with T. Sadler regarding Trustee bank account 0.10 1,225.00 122.50

Date Initials Description Hours Rate Amount

07/15/2022 LAD4 Tc/ N. Bassett and S. Kindseth, E. Henzy (Zeisler) re: documents and other requests (.40); strategize re: debtors' duties (2.10) 2.50 1,860.00 4,650.00 07/15/2022 TS21 Correspond with D. Barron and L. Despins regarding tax EIN for bankruptcy estate. 0.30 1,030.00 309.00 07/17/2022 DEB4 Prepare list of open issues in connection with attorney work streams (0.7); analyze documents in connection with same (0.5) 1.20 1,225.00 1,470.00 07/18/2022 DEB4 Correspond with L. Despins regarding research workstreams 0.10 1,225.00 122.50 07/18/2022 DEB4 Correspond with I. Goldman (Pullman)

07/18/2022 DEB4 Correspond with D. Hein regarding data

07/18/2022 JPK1 Review background documents regarding L. Despins' assignment as Chapter 11 Trustee

07/18/2022 WW6 Update working group list 0.30 250.00 75.00 07/19/2022 DEB4 Correspond with E. Sutton regarding debtor standing issues 0.20 1,225.00 245.00 07/19/2022 ECS1 Analyze case law and statutory authority

appointment of trustee (4.2); call with A. Luft about same (.1); correspond with N. Bassett about same (.1); correspond with A. Luft, D. Barron, and N. Bassett about same

07/19/2022 NAB Review case law related to standing and additional debtor issues (.4); correspond with A. Luft regarding same (.2) 0.60 1,510.00 906.00 07/19/2022 WW6 Update case calendar 0.20 250.00 50.00 07/20/2022 DEB4 Correspond with E. Sutton regarding debtor standing issues 0.10 1,225.00 122.50

Case 22-50073 Doc 1831 Filed 05/30/23 Entered 05/30/23 08:41:26 Page 92 of 1334

Luc Despins as Chapter 11 Trustee in thecase of Ho Wan Kwok 50687-00001 Invoice No. 2356905

Date Initials Description Hours Rate Amount

07/20/2022 DEB4 Correspond with T. Sadler regarding bank account opening (0.2); correspond with H. Claiborn (US Trustee) regarding Verdolino and Lowey check (0.1); correspond with J. David Morrissy (Zeichner) regarding funds allegedly held for estate (0.1); correspond

07/20/2022 ECS1 Analyze case law regarding debtor standing after appointment of trustee (1.7); correspond with L. Despins about same (.1) 1.80 840.00 1,512.00 07/20/2022 LAD4 T/c I. Goldman (Pullman) re: hearing (.10);

presentation for status conference (.30) 1.30 1,860.00 2,418.00 07/20/2022 NAB Correspond with A. Luft and E. Sutton regarding debtor standing and related issues (.3); review authority regarding same (.6); correspond with L. Despins regarding same

07/21/2022 DEB4 Correspond with L. Despins regarding

07/21/2022 DEB4 Conference with S. Austin regarding information security issues 0.30 1,225.00 367.50 07/22/2022 DEB4 Correspond with L. Despins regarding payment of estate expenses 0.10 1,225.00 122.50 07/22/2022 WW6 Update case calendar 0.40 250.00 100.00 07/22/2022 WW6 Correspond with D. Barron regarding bond

07/25/2022 AB21 Call with D. Barron regarding update on

07/25/2022 DEB4 Conference with N. Bassett regarding letter

issues (0.3); correspond with N. Bassett, L.

standing issue (0.2) 0.50 1,225.00 612.50 Case 22-50073 Doc 1831 Filed 05/30/23 Entered 05/30/23 08:41:26 Page 93 of 1334

Luc Despins as Chapter 11 Trustee in thecase of Ho Wan Kwok 50687-00001 Invoice No. 2356905

Date Initials Description Hours Rate Amount

07/25/2022 DEB4 Correspond with L. Despins regarding workstreams (0.3); conference with A.

(0.2); update task list (0.7); correspond with

estate funds (0.1); correspond with W. Wu regarding Genever case filings (0.1) 1.40 1,225.00 1,715.00 07/25/2022 ECS1 Correspond with D. Barron regarding

07/25/2022 NAB Call with D. Barron regarding case issues

07/25/2022 WW6 Update case calendar 0.40 250.00 100.00 07/26/2022 DEB4 Correspond with J.D. Morrissy (Zeichner)

regarding same (0.1); correspond with H. Claiborn (UST) regarding same (0.1) 0.30 1,225.00 367.50 07/27/2022 ECS1 Analyze case law regarding debtor's standing after appointment of trustee (.8); correspond with D. Barron about same (.1) 0.90 840.00 756.00 07/27/2022 LAD4 T/c C. Callari (Callari Partners) re: venue

and I. Goldman (Pullman) (1.10) 1.40 1,860.00 2,604.00 07/31/2022 AB21 Call with E. Sutton regarding research related to debtor in possession issues (0.1);

regarding same (0.1) 0.20 1,510.00 302.00 Subtotal: B110 Case Administration 71.80 84,293.50

07/08/2022 NAB Review pleadings and background 2.20 1,510.00 3,322.00

Date Initials Description Hours Rate Amount

07/08/2022 WW6 Correspond with D. Barron regarding chapter 11 petition (.2); correspond with D.

07/08/2022 WW6 Review certain pleadings in main case and in pending adversary proceedings (.5);

07/09/2022 WW6 Correspond with D. Barron regarding PAX v. Kwok litigation in NYS case 0.60 250.00 150.00 07/09/2022 WW6 Correspond with D. Barron regarding complaints in pending Kwok cases 0.60 250.00 150.00 07/11/2022 WW6 Correspond with D. Barron regarding Kwok v. Clark Hill case 0.30 250.00 75.00 07/11/2022 WW6 Review recently filed pleadings in main case and in pending adversary proceedings (.4);

07/11/2022 WW6 Correspond with D. Barron regarding motion for ordinary course professionals 0.20 250.00 50.00 07/12/2022 DM26 Review retention application for Verdolino & Lowey in Kwok case (.2) 0.20 515.00 103.00 07/12/2022 DEB4 Correspond with D. Mohamed, W. Wu, and

07/12/2022 ML30 Correspond with D. Barron regarding case pleadings (.2); review certain recently filed

07/12/2022 WW6 Review recently filed pleadings in main case and in adversary proceedings (.4);

07/13/2022 DEB4 Correspond with A. Luft regarding key

Date Initials Description Hours Rate Amount

07/13/2022 WW6 Review recently filed pleadings in main case and in adversary proceedings (.4);

07/13/2022 WW6 Review certain pleadings in Genever Holdings bankruptcy case (.8); correspond with D. Barron and B. Kelly regarding same

07/14/2022 DM26 Prepare summary chart of orders entered in the Kwok bankruptcy case 1.70 515.00 875.50 07/14/2022 ECS1 Correspond with K. Catalano about

07/14/2022 KC27 Correspond with D. Barron regarding motions with no order 0.10 775.00 77.50 07/14/2022 WW6 Correspond with N. Bassett and D. Barron regarding pending adversary proceedings 0.30 250.00 75.00 07/14/2022 WW6 Review recently filed pleadings in main case and in adversary proceedings (.4);

07/14/2022 WW6 Review pleadings in Pax v. Kwok lawsuit in

07/15/2022 KC27 Review final orders entered (.8); draft chart

subject to final order (1.1); draft chart regarding same (.4) 2.60 775.00 2,015.00 07/15/2022 WW6 Correspond with D. Barron regarding recently filed pleadings 0.30 250.00 75.00 07/15/2022 WW6 Review recently filed pleadings in main case and in adversary proceedings (.3);

07/17/2022 ECS1 Review appeals and related filings from NY state Pax lawsuit against Kwok (1.8); correspond with D. Barron about same (.1). 1.90 840.00 1,596.00

Date Initials Description Hours Rate Amount

07/18/2022 DEB4 Correspond with paralegal team (W. Wu, M.

review of pleadings 0.30 1,225.00 367.50 07/18/2022 WW6 Review recently filed pleadings in main case and in adversary proceedings (.4);

07/18/2022 WW6 Review pleadings for PH team database 0.60 250.00 150.00 07/19/2022 WW6 Review recently filed pleadings in main case and in adversary proceedings (.4);

07/20/2022 AB21 Correspond with P. Linsey (Neubert) regarding docket updates and certificates of service (0.1); correspond with L. Despins regarding recent filings in chapter 11 case

07/20/2022 WW6 Review recently filed pleadings in main case and in adversary proceedings (.4);

07/21/2022 DM26 Correspond with PH team regarding recently docketed pleadings in Kwok's main

regarding same (.1). 0.20 515.00 103.00 07/21/2022 WW6 Review recently filed pleadings in main case and in adversary proceedings (.3);

07/22/2022 DEB4 Conference with W. Wu regarding pleadings

regarding same (0.1) 0.30 1,225.00 367.50 07/22/2022 WW6 Review recently filed pleadings in main case and in adversary proceedings (.3);

07/22/2022 WW6 Call with D. Barron regarding case

Date Initials Description Hours Rate Amount

07/25/2022 WW6 Review recently filed pleadings in main case and in adversary proceedings (.3);

07/25/2022 WW6 Review certain electronic documents

received from the U.S. Trustee Office 2.50 250.00 625.00 07/26/2022 DEB4 Correspond with P. Linsey (Neubert) regarding adversary proceeding filings 0.10 1,225.00 122.50 07/26/2022 WW6 Review recently filed pleadings in main case and in adversary proceedings (.3);

07/27/2022 DM26 Review and correspond with PH team

07/27/2022 NAB Review responses to retention application and additional filings 0.70 1,510.00 1,057.00 07/27/2022 WW6 Review recently filed pleadings (.3);

07/27/2022 WW6 Review Pacific Alliance Asia v. Kwok lawsuit in New York state case 0.70 250.00 175.00 07/28/2022 WW6 Review recently filed pleadings (.4);

07/29/2022 WW6 Review recently filed pleadings (.6);

Subtotal: B113 Pleadings Review 32.20 16,409.00 Case 22-50073 Doc 1831 Filed 05/30/23 Entered 05/30/23 08:41:26 Page 98 of 1334

Luc Despins as Chapter 11 Trustee in thecase of Ho Wan Kwok 50687-00001 Invoice No. 2356905

Date Initials Description Hours Rate Amount

07/08/2022 AB21 Review submissions, notes to prepare for

trustee (0.4); listen to hearing regarding

07/08/2022 NAB Correspond with L. Despins in preparation

(.4); attend hearing (.4) 0.80 1,510.00 1,208.00 07/17/2022 AB21 Prepare hearing outline for July 21 status conference (1.2); correspond with L.

with D. Barron regarding same (0.2) 1.60 1,510.00 2,416.00 07/17/2022 ECS1 Prepare outline for July 21 status conference (.9); correspond with N. Bassett

07/17/2022 LAD4 Review/edit outline for status conference 1.40 1,860.00 2,604.00 07/17/2022 NAB Review and revise status conference outline (.6); correspond with E. Sutton regarding

07/18/2022 DEB4 Correspond with P. Linsey (Neubert) regarding hearing transcripts 0.10 1,225.00 122.50 07/19/2022 AB21 Revise outline for July 21 status conference (1.6); conferences with L. Despins regarding same (0.1); review correspondence from P.

regarding same (0.2) 1.90 1,510.00 2,869.00 07/19/2022 LAD4 Continue to review/edit status conference outline (.80); t/c A. Bongartz re: same (.10) 0.90 1,860.00 1,674.00 07/20/2022 AB21 Revise presentation for July 21 status

regarding same (0.3); correspond with L.

(Neubert) regarding same (0.1); correspond with H. Claiborn (U.S. Trustee) regarding 4.50 1,510.00 6,795.00

Date Initials Description Hours Rate Amount

07/20/2022 DEB4 Analyze documents in connection with status conference 2.20 1,225.00 2,695.00 07/20/2022 ML30 Correspond with D. Barron regarding preparation for July 21 status conference (.2); prepare reference materials for same

07/20/2022 NAB Review and revise outline for hearing (.5); correspond with L. Despins regarding same

07/20/2022 WW6 Prepare reference materials for July 21, 2022 status conference for L. Despins (2.8);

07/21/2022 AB21 Correspond with L. Despins regarding preparation for July 21 status conference

regarding same (0.2); listen to July 21 status conference (2.5); post-mortem call with N. Bassett regarding same (0.3); call with L. Despins regarding same (0.1) 3.20 1,510.00 4,832.00 07/21/2022 DEB4 Listen to status conference 2.50 1,225.00 3,062.50 07/21/2022 LAD4 Review submissions, issues, & outline to prepare for status conference (1.50); handle status conference (2.50); post-mortem with A. Bongartz (.10); t/c N. Bassett re: next

07/21/2022 NAB Conference with A. Bongartz regarding status conference (.3); attend portions of

regarding same and next steps in case (.3) 1.10 1,510.00 1,661.00 07/26/2022 WW6 Correspond with D. Barron regarding

materials for D. Barron regarding same (.5) 0.90 250.00 225.00 Case 22-50073 Doc 1831 Filed 05/30/23 Entered 05/30/23 08:41:26 Page 100 of 1334

Luc Despins as Chapter 11 Trustee in thecase of Ho Wan Kwok 50687-00001 Invoice No. 2356905

Date Initials Description Hours Rate Amount

07/27/2022 NAB Begin reviewing submissions in preparation for hearing (.4); correspond with L. Despins regarding hearing, retention application, and related matters (.3); telephone conference with L. Despins, A. Bongartz, and D. Barron regarding same (.3) 1.00 1,510.00 1,510.00 07/27/2022 WW6 Correspond with D. Barron regarding

07/27/2022 WW6 Continue to prepare reference materials for August 1, 2022 hearing 1.40 250.00 350.00 07/28/2022 WW6 Continue to prepare reference materials for D. Barron for the August 1, 2022 hearing 0.90 250.00 225.00 07/29/2022 AB21 Correspond with D. Barron regarding preparation for August 1 hearing (0.2); prepare additional cases for L. Despins for same (0.2); correspond with W. Wu and D. Barron regarding same (0.1) 0.50 1,510.00 755.00 07/29/2022 DM26 Research regarding documents pertaining to

07/29/2022 DEB4 Analyze documents in connection with

(2.8); correspond with N. Bassett and P. Linsey (Neubert) regarding Debtor's exhibit

corporate governance motion (4.5) 7.80 1,225.00 9,555.00 07/29/2022 ECS1 Analyze documents in connection with August 1 hearing in the Kwok case (.3); correspond with D. Barron about same (.1) 0.40 840.00 336.00 07/29/2022 AEL2 Review and comment on Court hearing in preparations for submissions and proposed

Case 22-50073 Doc 1831 Filed 05/30/23 Entered 05/30/23 08:41:26 Page 101 of 1334

Luc Despins as Chapter 11 Trustee in thecase of Ho Wan Kwok 50687-00001 Invoice No. 2356905

Date Initials Description Hours Rate Amount

07/29/2022 NAB Review declarations and additional submissions in preparation for hearing (.6);

prepare reply points in support of same (.4);

and hearing preparation issues (.3);

issues (.7); further correspond with L. Despins regarding same (.2); review Debtor exhibit list and related documents (.2);

attachment issue (.1) 2.50 1,510.00 3,775.00 07/29/2022 WW6 Prepare reference materials for L. Despins for August 1, 2022 hearing (2.4);

(.9); correspond with A. Bongartz regarding

07/30/2022 AB21 Review draft hearing outline for August 1

07/30/2022 DEB4 Conference with N. Bassett regarding hearing evidentiary issues (0.2); correspond with N. Bassett regarding same (0.3);

regarding same (0.3); prepare hearing notes (3.8); correspond with L. Despins regarding

regarding same (0.1) 4.90 1,225.00 6,002.50 07/30/2022 LAD4 T/c N. Bassett re: evidence for hearing (.10); review/comment on same (.40) 0.50 1,860.00 930.00 07/30/2022 NAB Analyze exhibit issues for hearing (.7);

(.2); telephone conference with L. Despins regarding same (.1); review draft argument

Case 22-50073 Doc 1831 Filed 05/30/23 Entered 05/30/23 08:41:26 Page 102 of 1334

Luc Despins as Chapter 11 Trustee in thecase of Ho Wan Kwok 50687-00001 Invoice No. 2356905

Date Initials Description Hours Rate Amount

07/30/2022 WCF Review Debtor's exhibit list regarding August 1 hearing (.1); draft exhibit matrix regarding objections, basis for objection,

07/31/2022 AB21 Revise hearing notes for August 1 hearing (0.8); calls with D. Barron regarding same

07/31/2022 DEB4 Correspond with N. Bassett and W. Farmer

(0.6); prepare written analyses of proposed exhibits (2.2); conferences and correspond

preparation for hearing (0.6); conferences

evidentiary issues (0.2); analyze same (0.9);

hearing notes (0.2); correspond with L. Despins regarding same (0.2); conferences with A. Bongartz regarding same (0.1); analyze revised corporate governance order (0.2); analyze documents related to Debtor's

documents cited in pleadings related to PH retention and Rule 60 motion (1.2); revise hearing notes (4.1) 11.00 1,225.00 13,475.00 07/31/2022 ECS1 Prepare reference materials relating to Kwok Gettr posts for August 1 hearing (.5); call with D. Barron about same (.1). 0.60 840.00 504.00 07/31/2022 LAD4 Review submissions, issues, outline to prepare for hearing (all day) (5.70); t/c D. Barron re: same (.20) 5.90 1,860.00 10,974.00 07/31/2022 NAB Review notes, issues, and related authority

with D. Barron regarding same (.2) 1.90 1,510.00 2,869.00 Subtotal: B155 Court Hearings 83.30 106,041.00 Case 22-50073 Doc 1831 Filed 05/30/23 Entered 05/30/23 08:41:26 Page 103 of 1334

Luc Despins as Chapter 11 Trustee in thecase of Ho Wan Kwok 50687-00001 Invoice No. 2356905

Date Initials Description Hours Rate Amount

07/08/2022 AB21 Draft retention application (3.0); call with P.

application (0.1) 3.10 1,510.00 4,681.00 07/08/2022 DEB4 Correspond with A. Bongartz regarding declaration of disinterestedness (0.1);

supplemental declaration (0.4) 0.50 1,225.00 612.50 07/08/2022 LAD4 Review/edit PH retention application (.60); t/c N. Bassett re: retention of local counsel and related issues (.30) 0.90 1,860.00 1,674.00 07/09/2022 AB21 Call with L. Despins regarding PH retention application (0.1); revise same (1.5); correspond with N. Bassett regarding same (0.1); correspond with L. Despins regarding

07/09/2022 DEB4 Correspond with L. Despins regarding

trustee appointment and PH retention (0.1);

07/09/2022 NAB Review retention application (.5);

07/10/2022 AB21 Calls with D. Barron regarding supplemental declaration in support of PH retention (0.3); correspond with D. Barron regarding same (0.3); revise PH retention application (0.5); correspond with L.

07/10/2022 DEB4 Conferences with A. Bongartz regarding supplemental declaration (0.3); conference with L. Despins regarding same (0.3);

regarding same (0.8); prepare same (1.2) 2.60 1,225.00 3,185.00 Case 22-50073 Doc 1831 Filed 05/30/23 Entered 05/30/23 08:41:26 Page 104 of 1334

Luc Despins as Chapter 11 Trustee in thecase of Ho Wan Kwok 50687-00001 Invoice No. 2356905

Date Initials Description Hours Rate Amount

07/10/2022 LAD4 T/c D. Barron re: supplemental disclosure

07/10/2022 NAB Review draft retention application and related documents (.3); correspond with A. Bongartz regarding same (.2) 0.50 1,510.00 755.00 07/10/2022 NAB Conference and correspond with P. Linsey (Neubert) regarding retention application and related issues (.3); calls with L. Despins regarding same (.4) 0.70 1,510.00 1,057.00 07/11/2022 AB21 Revise PH retention application, motion to expedite, and related documents (3.1);

regarding same (0.1); correspond with N. Bassett and P. Linsey (Neubert) regarding

(US Trustee) regarding same (0.1); review draft supplemental declaration (0.2);

regarding same (0.1) 3.90 1,510.00 5,889.00 07/11/2022 DEB4 Correspond with L. Despins regarding supplemental declaration (0.1); revise same (1.2); correspond and conference with A. Bongartz regarding same (0.1) 1.40 1,225.00 1,715.00 07/11/2022 LAD4 Review/edit PH application 0.80 1,860.00 1,488.00 07/11/2022 NAB Review retention application and related declaration (.4); correspond with P. Linsey

expedite application (.4); correspond with A. Bongartz regarding same and related 1.20 1,510.00 1,812.00

Case 22-50073 Doc 1831 Filed 05/30/23 Entered 05/30/23 08:41:26 Page 105 of 1334

Date Initials Description Hours Rate Amount

07/12/2022 AB21 Finalize PH retention application, motion to expedite, and related documents (2.1); conference with L. Despins regarding same (0.3); correspond with L. Despins regarding same (0.3); calls with P. Linsey (Neubert) regarding same (0.3); correspond with P. Linsey regarding same (0.3); calls with W. Wu regarding filing of retention application

same (0.1); calls with D. Barron regarding Despins supplemental declaration (0.1);

Bassett declaration (0.1); call with L.

regarding PH retention application (0.2);

regarding same (0.1) 4.20 1,510.00 6,342.00 07/12/2022 DEB4 Correspond with L. Despins regarding

disinterestedness (0.2); revise same (0.5);

supplemental declaration (0.1); correspond

same (0.1); conference and correspond with

retention application and service (0.3) 1.20 1,225.00 1,470.00 07/12/2022 LAD4 Meeting A. Bongartz re: PH retention process (.30); t/c H. Claiborn (US Trustee) and A. Bongartz re: PH retention (.20) 0.50 1,860.00 930.00 07/12/2022 WW6 Prepare Paul Hastings retention application

regarding same (.3); electronically file same

07/13/2022 AB21 Review draft reply in support of motion to

application (0.1); correspond with L.

regarding same (0.1); review PAX objection

with L. Despins regarding same (0.1) 0.40 1,510.00 604.00

Case 22-50073 Doc 1831 Filed 05/30/23 Entered 05/30/23 08:41:26 Page 106 of 1334

Date Initials Description Hours Rate Amount

07/13/2022 DEB4 Correspond with A. Bongartz and N.

expedite retention application 0.20 1,225.00 245.00 07/13/2022 NAB Review PAX objection to motion to expedite hearing on retention application (.2); correspond and telephone conference

(.3); draft reply and correspond with L. Despins regarding same (.6) 1.10 1,510.00 1,661.00 07/13/2022 WW6 Correspond with D. Barron regarding motion to expedite Paul Hastings retention

07/14/2022 AB21 Revise billing memo for PH team (0.3); correspond with L. Despins regarding same

07/14/2022 NAB Review debtor objection to motion to

application in connection with same (.3) 0.60 1,510.00 906.00 07/21/2022 DEB4 Correspond with K. Traxler regarding PH

07/22/2022 AB21 Review discovery request regarding PH retention application 0.30 1,510.00 453.00 07/22/2022 DEB4 Correspond with L. Despins, N. Bassett, and A. Bongartz regarding scheduling order

retention application (0.1); correspond with

regarding Debtor's request for information

07/25/2022 NAB Revise draft motion to quash subpoenas relating to retention (.8); analyze issues and authority related to same (.7); telephone conferences with L. Despins regarding same and discovery issues (.5); email and call with P. Linsey (Neubert) regarding same (.1); review revised draft motion to quash (.1) 2.20 1,510.00 3,322.00

Case 22-50073 Doc 1831 Filed 05/30/23 Entered 05/30/23 08:41:26 Page 107 of 1334

Luc Despins as Chapter 11 Trustee in thecase of Ho Wan Kwok 50687-00001 Invoice No. 2356905

Date Initials Description Hours Rate Amount

07/25/2022 NAB Email with L. Despins regarding debtor request for additional disclosures (.2); email with debtor's counsel regarding same (.1) 0.30 1,510.00 453.00 07/27/2022 AB21 Review responses to PH retention application (0.3); call with L. Despins, N. Bassett, and D. Barron regarding reply in further support of PH retention application (0.3); call with D. Barron regarding same

07/27/2022 DEB4 Conference with A. Bongartz, L. Despins, and N. Bassett regarding reply in support of retention motion (0.3); further conference with A. Bongartz regarding same (0.1);

connection with same (0.4) 1.80 1,225.00 2,205.00 07/27/2022 ECS1 Analyze case law and statutory authority regarding estate administration and related retention/fee applications (1.9); correspond with D. Barron about same (.1). 2.00 840.00 1,680.00 07/27/2022 LAD4 T/c with N. Bassett, A. Bongartz, D. Barron re: retention reply 0.30 1,860.00 558.00 07/28/2022 AB21 Call with L. Despins regarding PH retention

retention application and Debtor's Rule 60

regarding same (0.2); call with K. Catalano regarding same (0.1) 1.00 1,510.00 1,510.00 07/28/2022 DEB4 Prepare reply in support of retention

supplemental declaration (1.3) 4.50 1,225.00 5,512.50 07/28/2022 KC27 Analyze case law regarding conflicts

07/28/2022 LAD4 T/c A. Bongartz re: PH retention 0.20 1,860.00 372.00 07/28/2022 NAB Review draft reply in support of retention application (.4); correspond with D. Barron regarding same (.2) 0.60 1,510.00 906.00 Case 22-50073 Doc 1831 Filed 05/30/23 Entered 05/30/23 08:41:26 Page 108 of 1334

Luc Despins as Chapter 11 Trustee in thecase of Ho Wan Kwok 50687-00001 Invoice No. 2356905

Date Initials Description Hours Rate Amount

07/28/2022 WW6 Review reply in support of Paul Hastings retention application 0.90 250.00 225.00 07/29/2022 DEB4 Correspond with L. Despins regarding second supplemental declaration 0.20 1,225.00 245.00 07/30/2022 DEB4 Correspond with L. Despins regarding Paul Hastings retention application 0.20 1,225.00 245.00 Subtotal: B160 Fee/Employment Applications 48.50 64,332.00 B165 Fee/Employment Applications for Other Professionals

07/10/2022 LAD4 T/c N. Bassett re: local counsel retention 0.40 1,860.00 744.00

07/11/2022 DEB4 Correspond with L. Despins and N. Bassett regarding Brown Rudnick withdrawal (0.1) 0.10 1,225.00 122.50 07/12/2022 DEB4 Correspond with B. Kelly regarding potential retention of BVI counsel (0.4);

(Harneys) regarding same (0.3) 0.90 1,225.00 1,102.50 07/13/2022 DEB4 Correspond with A. Thorp (Harneys) regarding potential BVI counsel retention (0.2); correspond with L. Despins regarding

regarding same (0.2) 0.50 1,225.00 612.50 07/14/2022 AB21 Review draft Neubert retention application (0.2); correspond with N. Bassett regarding

regarding same (0.1); correspond with P. Linsey (Neubert) regarding same (0.1) 0.50 1,510.00 755.00 07/14/2022 DEB4 Correspond with L. Despins regarding potential retention of BVI counsel 0.20 1,225.00 245.00 07/15/2022 AB21 Call with P. Linsey (Neubert) regarding Neubert retention application (0.1); correspond with L. Despins regarding same

Case 22-50073 Doc 1831 Filed 05/30/23 Entered 05/30/23 08:41:26 Page 109 of 1334

Luc Despins as Chapter 11 Trustee in thecase of Ho Wan Kwok 50687-00001 Invoice No. 2356905

Date Initials Description Hours Rate Amount

07/16/2022 DEB4 Correspond with B. Kelly, A. Bongartz, and

07/19/2022 AB21 Correspond with L. Despins regarding Neubert retention application (0.1);

regarding same (0.1); correspond with W. Wu regarding same (0.1) 0.30 1,510.00 453.00 07/19/2022 WW6 Prepare Neubert retention application for

regarding same (.1); electronically file same

07/21/2022 DEB4 Correspond with A. Bongartz regarding

07/22/2022 DEB4 Draft response to Brown Rudnick withdrawal motion 0.30 1,225.00 367.50 07/26/2022 AB21 Revise response to Brown Rudnick motion to withdraw (0.1); correspond with L. Despins regarding same (0.1) 0.20 1,510.00 302.00 07/27/2022 AB21 Revise response to Brown Rudnick withdrawal motion (0.2); correspond with L. Despins regarding same (0.2); call with P. Linsey (Neubert) regarding filing of same (0.1); review briefs on conflicts and section 327 issues (U.S. Trustee and Kwok) (0.2) 0.70 1,510.00 1,057.00 Subtotal: B165 Fee/Employment Applications for

B190 Other Contested Matters(excl. assumption/rejections motions)

07/11/2022 AB21 Review objection to appointment of chapter 11 trustee 0.20 1,510.00 302.00

07/11/2022 NAB Review Debtor objection to trustee appointment and correspond with L. Despins, A. Bongartz regarding same (.5) 0.50 1,510.00 755.00 Case 22-50073 Doc 1831 Filed 05/30/23 Entered 05/30/23 08:41:26 Page 110 of 1334

Luc Despins as Chapter 11 Trustee in thecase of Ho Wan Kwok 50687-00001 Invoice No. 2356905

Date Initials Description Hours Rate Amount

07/11/2022 WW6 Correspond with working group regarding objection to the appointment of Mr.

07/12/2022 DEB4 Analyze letter filing from A. Mitchell (Lawall and Mitchell) (0.5); correspond with L. Despins regarding same (0.1) 0.60 1,225.00 735.00 07/15/2022 AB21 Review motion to vacate chapter 11 trustee

regarding same (0.2) 0.50 1,510.00 755.00 07/15/2022 DEB4 Conference with A. Bongartz regarding Debtor's Rule 60(b) motion for relief from order appointing chapter 11 trustee (0.2);

07/15/2022 NAB Review motion to overturn trustee appointment (.2); correspond with L. Despins regarding same (.2); review cases related to same (.2); telephone conference

(.2); review task list and consider next steps

07/16/2022 DEB4 Prepare objection to Kwok's Rule 60(b) motion on appointment of trustee (6.8); correspond with N. Bassett regarding same

07/16/2022 NAB Prepare email outline and analysis for

trustee appointment 0.60 1,510.00 906.00 07/17/2022 DEB4 Prepare objection to Kwok's Rule 60(b) motion on trustee appointment 4.20 1,225.00 5,145.00 07/17/2022 ECS1 Review public statements made by Kwok in

appointment of the Trustee (.5); correspond with D. Barron about same (.1) 0.60 840.00 504.00 07/17/2022 LAD4 Review motion to vacate appointment of

07/18/2022 AB21 Review draft motion to vacate appointment of chapter 11 trustee 0.30 1,510.00 453.00

Case 22-50073 Doc 1831 Filed 05/30/23 Entered 05/30/23 08:41:26 Page 111 of 1334

Luc Despins as Chapter 11 Trustee in thecase of Ho Wan Kwok 50687-00001 Invoice No. 2356905

Date Initials Description Hours Rate Amount

07/18/2022 DEB4 Prepare objection to Kwok's Rule 60(b)

chapter 11 trustee 2.80 1,225.00 3,430.00 07/18/2022 ML30 Correspond with D. Barron regarding the objection to debtor's motion for relief from the Chapter 11 Trustee order (.4); review the draft objection (.4); review cited caselaw (.8); review cited pleadings and supporting documents (.9); review, revise the objection

07/18/2022 NAB Review and revise draft objection to motion to reconsider trustee appointment (1.0); email with D. Barron regarding same (.3) 1.30 1,510.00 1,963.00 07/19/2022 AB21 Review draft objection to motion to vacate chapter 11 trustee appointment (0.6); revise same (0.6); call with L. Despins, N. Bassett, and D. Barron regarding same (0.4); calls with D. Barron regarding same (0.2);

(0.1); correspond with L. Despins, N. Bassett, and D. Barron regarding same (0.1) 2.00 1,510.00 3,020.00 07/19/2022 DEB4 Call with A. Bongartz, L. Despins, and N.

appointing trustee (0.4); further calls with A. Bongartz regarding same (0.2); revise same

07/19/2022 LAD4 Review/edit objection to Rule 60(b) motion (1.40); t/c A. Bongartz, D. Barron, N. Bassett re: same (.40) 1.80 1,860.00 3,348.00 07/19/2022 ML30 Correspond with D. Barron regarding the

under Rule 60(b) (.3); review current draft objection (.3); research for same (.3) 0.90 515.00 463.50

Case 22-50073 Doc 1831 Filed 05/30/23 Entered 05/30/23 08:41:26 Page 112 of 1334

Date Initials Description Hours Rate Amount

07/19/2022 NAB Correspond with L. Despins regarding objection to trustee appointment and status conference (.1); telephone conference with

regarding objection to trustee appointment

revise same (.5) 1.00 1,510.00 1,510.00 07/19/2022 WW6 Review objection to debtor's motion for relief under Rule 60(b) 0.80 250.00 200.00 07/20/2022 AB21 Revise objection to motion to vacate chapter 11 trustee appointment (0.5); correspond with L. Despins, N. Bassett, and D. Barron regarding same (0.1); correspond with D. Barron regarding same (0.1);

regarding same (0.1) 0.80 1,510.00 1,208.00 07/20/2022 DEB4 Revise objection to Kwok Rule 60(b)

appointing trustee 1.80 1,225.00 2,205.00 07/20/2022 LAD4 Final review/edit objection to Rule 60b

07/20/2022 WW6 Review objection to debtor's motion for relief under Rule 60(b) (.4); prepare exhibits

07/22/2022 DEB4 Correspond with L. Despins, N. Bassett, A.

07/22/2022 NAB Review discovery requests from Debtor (.2);

response to same (.3); call with P. Linsey regarding same (.1) 0.60 1,510.00 906.00 Subtotal: B190 Other Contested Matters(excl. assumption/rejections motions) 41.10 48,498.50 Case 22-50073 Doc 1831 Filed 05/30/23 Entered 05/30/23 08:41:26 Page 113 of 1334

Luc Despins as Chapter 11 Trustee in thecase of Ho Wan Kwok 50687-00001 Invoice No. 2356905

Date Initials Description Hours Rate Amount

B211 Financial Reports (Monthly Operating Reports) 07/13/2022 DEB4 Correspond with T. Sadler regarding MORs

07/14/2022 DEB4 Correspond with L. Despins regarding outstanding monthly operating reports and missing information from schedules 0.20 1,225.00 245.00 Subtotal: B211 Financial Reports (Monthly

B310 Claims Administration and Objections 07/14/2022 LAD4 Review SEC claim 0.20 1,860.00 372.00 07/15/2022 DEB4 Analyze SEC proof of claim 0.20 1,225.00 245.00 07/18/2022 WW6 Correspond with working group regarding

07/19/2022 LAD4 T/c N. Jacobson (SEC) re: claim 0.20 1,860.00 372.00 07/21/2022 AB21 Analyze notice issues for bar date order (0.7); call with D. Barron regarding same

07/21/2022 DEB4 Correspond with L. Aronsson (O'Melveny) regarding transcript of hearing on bar date motion (0.1); conference with A. Bongartz regarding strategy related to same (0.2) 0.30 1,225.00 367.50

07/22/2022 AB21 Revise proposed bar date order (0.9); correspond with L. Despins regarding same (0.1) 1.00 1,510.00 1,510.00 07/22/2022 DEB4 Analyze prior proposed bar date order 0.20 1,225.00 245.00 07/22/2022 WW6 Correspond with D. Barron regarding proposed revised bar date order 0.20 250.00 50.00

Case 22-50073 Doc 1831 Filed 05/30/23 Entered 05/30/23 08:41:26 Page 114 of 1334

Date Initials Description Hours Rate Amount

07/25/2022 AB21 Revise proposed bar date order and related

regarding same (0.1); correspond with P. Linsey (Neubert) regarding same (0.1); call with A. Levin (Miller Advertising) regarding publication notice (0.1); correspond with A. Levin regarding same (0.1) 2.20 1,510.00 3,322.00 07/25/2022 DM26 Review claims register regarding Genever's

07/25/2022 DEB4 Correspond with D. Mohamed regarding

07/25/2022 WW6 Correspond with A. Bongartz regarding revised bar date order 0.20 250.00 50.00 07/26/2022 AB21 Revise proposed bar date order (0.7); correspond with L. Despins regarding same

07/26/2022 DM26 Review issue regarding Genever bar date

07/26/2022 DEB4 Correspond with D. Mohamed regarding Genever bar date pleadings (0.1); analyze

regarding same (0.2) 0.60 1,225.00 735.00 07/26/2022 WW6 Correspond with D. Barron regarding revised proposed bar date order 0.20 250.00 50.00 07/27/2022 AB21 Correspond with L. Despins regarding

related to same (0.2); call with A. Levin 1.10 1,510.00 1,661.00 Case 22-50073 Doc 1831 Filed 05/30/23 Entered 05/30/23 08:41:26 Page 115 of 1334

Luc Despins as Chapter 11 Trustee in thecase of Ho Wan Kwok 50687-00001 Invoice No. 2356905

Date Initials Description Hours Rate Amount

07/27/2022 Contact publication sites for bar date notice (.5); draft email to A. Bongartz regarding

07/27/2022 Call with A. Bongartz regarding publications for bar date notice 0.20 775.00 155.00 07/27/2022 Review publication sites for bar date notice 0.80 775.00 620.00 07/28/2022 AB21 Finalize revised proposed bar date order and exhibits (2.8); correspond with A. Levin regarding publication notice (0.1);

revised proposed bar date order (0.3); calls with L. Despins regarding same (0.3);

regarding same (0.2); correspond with P. Friedman (O'Melveny) regarding same (0.1);

regarding related notice and filing of same (0.3); call with P. Linsey regarding same

07/28/2022 LAD4 Review/edit bar date (.50); t/c A. Bongartz re: publication notice/bar date (.30) 0.80 1,860.00 1,488.00 Subtotal: B310 Claims Administration and

ID Timekeeper Name Title Hours Rate Fee

LAD4 Luc A. Despins Partner 40.00 1,860.00 74,400.00 NAB Nicholas A. Bassett Partner 30.30 1,510.00 45,753.00 AB21 Alex Bongartz Of Counsel 50.70 1,510.00 76,557.00 AEL2 Luft, Avi E. Of Counsel 3.80 1,510.00 5,738.00 DEB4 Douglass E. Barron Associate 80.30 1,225.00 98,367.50 WCF Will C. Farmer Associate 0.50 1,120.00 560.00 Case 22-50073 Doc 1831 Filed 05/30/23 Entered 05/30/23 08:41:26 Page 116 of 1334

Luc Despins as Chapter 11 Trustee in thecase of Ho Wan Kwok 50687-00001 Invoice No. 2356905

TS21 Tess Sadler Associate 6.80 1,030.00 7,004.00

ECS1 Ezra C. Sutton Associate 14.70 840.00 12,348.00 KC27 Kristin Catalano Associate 8.70 775.00 6,742.50 JPK1 Jon P. Kosciewicz Associate 1.30 775.00 1,007.50

ML30 Mat Laskowski Paralegal 8.50 515.00 4,377.50 DM26 David Mohamed Paralegal 3.00 515.00 1,545.00 WW6 Winnie Wu Paralegal 47.70 250.00 11,925.00

Total Balance Due - Due Upon Receipt \$347,642.50 Case 22-50073 Doc 1831 Filed 05/30/23 Entered 05/30/23 08:41:26 Page 117 of 1334

PAUL HASTINGS LLP 200 Park Avenue, New York, NY 10166-3205 t: +1.212.318.6000 f: +1.212.319.4090 www.paulhastings.com

Luc Despins as Chapter 11 Trustee in the case of Ho Wan Kwok 200 Park Avenue New York, NY 10166

Attn: Luc Despins PH LLP Tax ID No. 95-2209675

Asset Recovery Investigation and Litigation PH LLP Client/Matter # 50687-00002 Luc A. Despins

Legal fees for professional services for the period ending July 31, 2022 \$535,563.50

Total Balance Due - Due Upon Receipt \$535,563.50

We encourage our clients to pay via ACH, however, in the event that you pay by check, please send payment to the remittance address below:

*TO PROTECT AGAINST FRAUD, the Firm will not change its wiring instructions via email. We strongly encourage clients to confirm any change in wiring instructions by contacting Teri Goffredo @ 213-683-5045 or via email @ terigoffredo@paulhastings.com and requesting written and verbal confirmation.* Wiring and ACH Instructions: Remittance Address:

Citibank Paul Hastings LLP ABA # 322271724 Lockbox 4803 SWIFT Address: CITIUS33 PO Box 894803 787 W. 5th Street Los Angeles, CA 90189-4803 Los Angeles, CA 90071 Account Number: 206628380 Account Name: Paul Hastings LLP

Remittance Address:

*For wires, please reference the invoice, client and matter number(s) being paid For ACH payments, please use the CTX format and/or send any remittances to cashepn@paulhastings.com. This is a no-reply mailbox* Case 22-50073 Doc 1831 Filed 05/30/23 Entered 05/30/23 08:41:26 Page 118 of 1334

PAUL HASTINGS LLP 200 Park Avenue, New York, NY 10166-3205 t: +1.212.318.6000 f: +1.212.319.4090 www.paulhastings.com

Luc Despins as Chapter 11 Trustee in the case of Ho Wan Kwok 200 Park Avenue New York, NY 10166

Attn: Luc Despins PH LLP Tax ID No. 95-2209675

Asset Recovery Investigation and Litigation PH LLP Client/Matter # 50687-00002 Luc A. Despins

Legal fees for professional services for the period ending July 31, 2022 \$535,563.50

Total Balance Due - Due Upon Receipt \$535,563.50

We encourage our clients to pay via ACH, however, in the event that you pay by check, please send payment to the remittance address below:

*TO PROTECT AGAINST FRAUD, the Firm will not change its wiring instructions via email. We strongly encourage clients to confirm any change in wiring instructions by contacting Teri Goffredo @ 213-683-5045 or via email @ terigoffredo@paulhastings.com and requesting written and verbal confirmation.* Wiring and ACH Instructions: Remittance Address:

Citibank Paul Hastings LLP ABA # 322271724 Lockbox 4803 SWIFT Address: CITIUS33 PO Box 894803 787 W. 5th Street Los Angeles, CA 90189-4803 Los Angeles, CA 90071 Account Number: 206628380 Account Name: Paul Hastings LLP

*For wires, please reference the invoice, client and matter number(s) being paid For ACH payments, please use the CTX format and/or send any remittances to cashepn@paulhastings.com. This is a no-reply mailbox* Case 22-50073 Doc 1831 Filed 05/30/23 Entered 05/30/23 08:41:26 Page 119 of 1334

t: +1.212.318.6000 f: +1.212.319.4090 www.paulhastings.com

Luc Despins as Chapter 11 Trustee in the case of Ho May 23, 2023

New York, NY 10166 Invoice Number: 2356906

Attn: Luc Despins PH LLP Tax ID No. 95-2209675

FOR PROFESSIONAL SERVICES RENDERED for the period ending July 31, 2022 Asset Recovery Investigation and Litigation \$535,563.50

Date Initials Description Hours Rate Amount B120 Asset Analysis and Recovery 07/08/2022 AB21 Analyze Lady May order (1.6); correspond with L. Despins regarding same (0.4); prepare proposed amended order regarding Lady May delivery (1.1); correspond with L. Despins regarding same (0.1); correspond with counsel to Debtor, I. Goldman (Pullman), H. Claiborn (UST), P. Friedman (O'Melveny), S. Kindseth (HK USA) regarding same (0.1) 3.30 1,510.00 4,983.00 07/08/2022 AB21 Review additional background documents related to Lady May stipulated order 0.20 1,510.00 302.00 07/09/2022 NAB Correspond with D. Barron regarding property of the estate and privilege issues (.4) 0.40 1,510.00 604.00 Case 22-50073 Doc 1831 Filed 05/30/23 Entered 05/30/23 08:41:26 Page 120 of 1334

Luc Despins as Chapter 11 Trustee in the case of Ho Wan Kwok 50687-00002 Invoice No. 2356906

Date Initials Description Hours Rate Amount

07/11/2022 AB21 Correspond with L. Despins regarding Lady May order (0.1); correspond with L.

(O'Melveny), I. Goldman (Pullman), H.

(Lawall & Mitchell) regarding same (0.1);

(Yachtzoo), and L. Bernard (captain of Lady

(0.4); review correspondence from L. Despins regarding same (0.1) 0.70 1,510.00 1,057.00 07/11/2022 DEB4 Correspond with L. Despins regarding

entities (0.2); correspond with N. Bassett

(0.2); correspond with L. Despins regarding Genever settlement sales process (0.2);

Greenwich Land properties (0.1);

Bravo Luck Limited (0.2); analyze pleadings and related documents regarding same (0.5);

Genever settlement agreement (0.1); correspond with L. Despins and N. Bassett regarding additional Kwok counsel (0.2) 1.70 1,225.00 2,082.50 07/11/2022 NAB Review documents related to Genever chapter 11 case and settlement agreement 0.20 1,510.00 302.00 07/12/2022 AB21 Correspond with L. Despins regarding Lady May order (0.2); analyze same (0.2) 0.40 1,510.00 604.00 07/12/2022 DEB4 Correspond with L. Despins regarding

(0.1); analyze same (0.2); correspond with N. Bassett regarding same (0.1) 0.40 1,225.00 490.00 07/12/2022 ECS1 Analyze issues regarding NY state contempt order (.8); calls with A. Luft about same and

Case 22-50073 Doc 1831 Filed 05/30/23 Entered 05/30/23 08:41:26 Page 121 of 1334

Luc Despins as Chapter 11 Trustee in the case of Ho Wan Kwok 50687-00002 Invoice No. 2356906

Date Initials Description Hours Rate Amount

07/12/2022 AEL2 Call with E. Sutton regarding preclusion

07/12/2022 AEL2 Correspond with E. Sutton re: preclusion

07/12/2022 AEL2 Analyze case law regarding preclusion 3.10 1,510.00 4,681.00 07/12/2022 AEL2 Correspond with E. Sutton regarding case law on preclusion 0.40 1,510.00 604.00 07/12/2022 AEL2 Email N. Bassett regarding preclusion

07/12/2022 AEL2 Analyze authority regarding intervention

07/12/2022 AEL2 Meeting with D. Barron re: research and Kwok assets (.3); correspond with D. Barron re: same (.2); review issues re: same

07/12/2022 WW6 Review issue regarding Eastern Profit for E.

07/13/2022 DM26 Research regarding Rule of Law Society and D. Podhaskie (1.5); correspond with D. Barron regarding same (.1). 1.60 515.00 824.00 07/13/2022 DEB4 Call with A. Luft regarding D. Podhaskie and Rule of Law Society 0.30 1,225.00 367.50 07/13/2022 DEB4 Correspond with N. Bassett and E. Sutton regarding letters to counsel 0.20 1,225.00 245.00 07/13/2022 DEB4 Correspond with N. Bassett regarding

07/13/2022 DEB4 Correspond with A. Bongartz regarding yacht inspection (0.1); correspond with N.

BVI issues (0.1); correspond with L.

with E. Sutton regarding same (0.1) 0.50 1,225.00 612.50

Case 22-50073 Doc 1831 Filed 05/30/23 Entered 05/30/23 08:41:26 Page 122 of 1334

Luc Despins as Chapter 11 Trustee in the case of Ho Wan Kwok 50687-00002 Invoice No. 2356906

Date Initials Description Hours Rate Amount 07/13/2022 DEB4 Correspond with L. Despins regarding 7 Nod Hill LLC (0.2); review documents related to same (0.4); correspond with N. Bassett and A. Luft regarding bank accounts (0.1); correspond with N. Bassett regarding Hong Kong order (0.1); review same (0.2); correspond with D. Mohamed and M. Laskowski regarding Rule of Law Society (0.2); correspond with E. Sutton regarding asset and counsel letter status (0.1); correspond with N. Bassett regarding related entities (0.3) 1.60 1,225.00 1,960.00 07/13/2022 AEL2 Correspond with E. Sutton regarding case findings on preclusion and assets 1.20 1,510.00 1,812.00 07/13/2022 AEL2 Analyze estoppel case law 1.10 1,510.00 1,661.00 07/13/2022 WW6 Review issue regarding Greenwich Land LLC 0.40 250.00 100.00 07/14/2022 DM26 Research regarding certain entities on the Debtor's statement of financial affairs (1.8); correspond with D. Barron regarding same (.2) 2.00 515.00 1,030.00 07/14/2022 DEB4 Correspond with PH team regarding Golden Springs funding agreements (0.2); correspond with A. Bongartz regarding Genever Chapter 11 case (0.1); correspond with A. Bongartz regarding Genever case settlement agreement regarding sale of condo (0.2); correspond with B. Kelly regarding NY state court turnover order (0.1); correspond with A. Bongartz regarding Ostrager decision from Feb. 2022 (0.1); correspond with L. Despins regarding Brown Rudnick retainer (0.1); correspond with W. Wu regarding entity research in connection with asset letters (0.3); correspond with E. Sutton regarding additional entity matters (0.2) 1.30 1,225.00 1,592.50 Case 22-50073 Doc 1831 Filed 05/30/23 Entered 05/30/23 08:41:26 Page 123 of 1334

Luc Despins as Chapter 11 Trustee in the case of Ho Wan Kwok 50687-00002 Invoice No. 2356906

Date Initials Description Hours Rate Amount

07/14/2022 ECS1 Analyze authority regarding impact of NY

about same and privity (.5) 4.80 840.00 4,032.00 07/14/2022 LAD4 T/c A. Thorp (Harneys) re: Genever (.20);

07/14/2022 AEL2 Analyze law regarding privity issues (3.2);

regarding same (.5) 3.70 1,510.00 5,587.00 07/15/2022 AEL2 Analyze caselaw regarding Lady May and

07/15/2022 AEL2 Call with P. Friedman (O'Melveny)

07/15/2022 AEL2 Review record for facts related to turnover

regarding related issues and deadlines (.4) 2.90 1,510.00 4,379.00 07/18/2022 AEL2 Analyze preclusion and related caselaw 0.80 1,510.00 1,208.00 07/18/2022 AEL2 Analyze privity caselaw 1.20 1,510.00 1,812.00 07/18/2022 AEL2 Review hearing transcript regarding Lady

07/18/2022 AEL2 Calls with E. Sutton regarding privity and NY state contempt order 0.60 1,510.00 906.00 07/18/2022 WW6 Review issues regarding Greenwich Land

07/19/2022 ECS1 Analyze effect of NY state contempt order on Kwok bankruptcy (2.3); correspond with A. Luft about same (.3). 2.60 840.00 2,184.00 07/19/2022 ECS1 Review matters regarding video interview of

and additional assets. 0.30 840.00 252.00 07/19/2022 LAD4 Review/edit draft stipulated order 0.70 1,860.00 1,302.00 07/19/2022 AEL2 Analyze procedural arguments regarding estoppel (1.3); call with E. Sutton regarding standing and estoppel (.1) 1.40 1,510.00 2,114.00

Date Initials Description Hours Rate Amount

07/20/2022 ECS1 Further review matters regarding video interview of Kwok in connection with Lady May yacht and additional assets. 0.10 840.00 84.00 07/20/2022 ECS1 Analyze effect of NY state contempt order on Kwok bankruptcy (2.9); call with A. Luft

07/20/2022 AEL2 Meeting with E. Sutton regarding NY state contempt order and preclusion motion 0.90 1,510.00 1,359.00 07/20/2022 AEL2 Analyze issue preclusion and related

07/21/2022 AB21 Correspond with L. Despins regarding Lady May stipulated order 0.90 1,510.00 1,359.00 07/21/2022 DEB4 Correspond with D. Parker (Harcus Parker) regarding Kwok litigation in UK 0.10 1,225.00 122.50 07/21/2022 ECS1 Continue to analyze case law regarding

about same (3.0); calls with A. Luft about

07/22/2022 AB21 Call with L. Despins, D. White (inspector),

07/22/2022 DEB4 Correspond with J. Morrissey (Harcus Parker) regarding order appointing L. Despins as chapter 11 trustee 0.10 1,225.00 122.50 07/22/2022 ECS1 Continue to analyze case law regarding

Kwok bankruptcy (.5); continue to prepare memo about same (1.4); correspond with A. Luft about same (.1). 2.00 840.00 1,680.00 07/22/2022 LAD4 T/c N. Bassett & E. Henzy (Zeisler) re: UK

07/22/2022 AEL2 Edit preclusion memo 1.40 1,510.00 2,114.00 Case 22-50073 Doc 1831 Filed 05/30/23 Entered 05/30/23 08:41:26 Page 125 of 1334

Luc Despins as Chapter 11 Trustee in the case of Ho Wan Kwok 50687-00002 Invoice No. 2356906

Date Initials Description Hours Rate Amount

07/25/2022 DEB4 Analyze proposed Genever plan and related documents (0.8); correspond with L. Despins regarding same (0.5) 1.30 1,225.00 1,592.50 07/25/2022 WW6 Correspond with D. Barron regarding

bankruptcy case (.2); review same (.4) 0.60 250.00 150.00 07/26/2022 DEB4 Telephone conference with E. Sutton

07/26/2022 DEB4 Correspond with L. Despins regarding Genever chapter 11 case 0.30 1,225.00 367.50 07/26/2022 LAD4 Review/comment on claims relating to Lady May and deposit 2.10 1,860.00 3,906.00 07/29/2022 AB21 Calls with L. Despins regarding Lady May stipulated order (0.2); analyze same (0.2); correspond with L. Despins regarding same

07/29/2022 LAD4 T/c S. Sarnoff (O'Melveny) re: Lady May claims (.20); review strategy re: same (2.70);

Subtotal: B120 Asset Analysis and Recovery 80.30 100,346.00

07/16/2022 LAD4 Analyze/comment on trust declaration 3.70 1,860.00 6,882.00

Case 22-50073 Doc 1831 Filed 05/30/23 Entered 05/30/23 08:41:26 Page 126 of 1334

(.1).

Date Initials Description Hours Rate Amount

07/18/2022 AB21 Call with L. Despins, and S. Sepinuck regarding asset recovery strategies (0.5); follow-up correspondence with L. Despins, S. Sepinuck, and N. Bassett regarding same

07/18/2022 LAD4 T/c S. Sepinuck, A. Bongartz re: trust agreement challenges (.50); review/comment on same (2.70) 3.20 1,860.00 5,952.00 Subtotal: B191 General Litigation .0 14,042.00

07/08/2022 AB21 Review correspondence from E. Sutton and

privilege analysis 0.30 1,510.00 453.00 07/08/2022 DEB4 Correspond with N. Bassett regarding key

same (0.1); call with E. Sutton, N. Bassett,

hold letters (0.4) 0.60 1,225.00 735.00 07/08/2022 ECS1 Call with N. Bassett, A. Luft, and D. Barron

07/08/2022 ECS1 Draft letters for entities/persons potentially holding Kwok estate assets and to counsel

(1.6); correspond with K. Catalano, W. Farmer, A. Luft and N. Bassett about same 1.70 840.00 1,428.00 Case 22-50073 Doc 1831 Filed 05/30/23 Entered 05/30/23 08:41:26 Page 127 of 1334

Luc Despins as Chapter 11 Trustee in the case of Ho Wan Kwok 50687-00002 Invoice No. 2356906

Date Initials Description Hours Rate Amount 07/08/2022 ECS1 Analyze authority regarding chapter 11 trustee and attorney client privilege/additional privileges (3.6); prepare memo regarding same (1.0); correspond with N. Bassett and A. Luft about same (.3). 4.90 840.00 4,116.00 07/08/2022 AEL2 Correspond with N. Bassett and D. Barron regarding notice/asset hold letters and retention of documents (.4); review issues regarding same (.2) 0.60 1,510.00 906.00 07/08/2022 AEL2 Planning meeting with N. Bassett, D. Barron, and E. Sutton regarding notice/asset hold letters 0.40 1,510.00 604.00 07/08/2022 NAB Call with A. Luft, D. Barron, and E. Sutton regarding letters to parties in interest regarding property and documents (.4); emails with same regarding same (.6) 1.00 1,510.00 1,510.00 07/08/2022 NAB Review case law regarding attorney-client privilege issues (.7); email with E. Sutton regarding same (.3) 1.00 1,510.00 1,510.00 07/09/2022 DEB4 Correspond with W. Wu regarding document/asset hold letters (0.3); conference with W. Wu regarding same (0.2); correspond with N. Bassett and A. Luft regarding same (0.4); analyze documents related to same (6.4); correspond with A. Bongartz and N. Bassett regarding Ostrager ruling and related pleadings (0.1) 7.40 1,225.00 9,065.00 07/09/2022 KC27 Revise asset letter templates (3.9); correspond with A. Luft on same (.1) 4.00 775.00 3,100.00 07/09/2022 AEL2 Review findings regarding targets of notice/asset hold letters 1.20 1,510.00 1,812.00 07/09/2022 AEL2 Draft parts of notice/asset hold letters 3.40 1,510.00 5,134.00 07/09/2022 AEL2 Correspond with K. Catalano and E. Sutton regarding notice/asset hold letters 0.70 1,510.00 1,057.00 07/09/2022 WCF Review, revise draft asset/document hold 0.70 1,120.00 784.00

letters to law firms and corporate entities Case 22-50073 Doc 1831 Filed 05/30/23 Entered 05/30/23 08:41:26 Page 128 of 1334

Luc Despins as Chapter 11 Trustee in the case of Ho Wan Kwok 50687-00002 Invoice No. 2356906

Date Initials Description Hours Rate Amount

07/09/2022 WW6 Create spreadsheet of contact information for certain parties in the Kwok bankruptcy case (3.8); call with D. Barron regarding

07/10/2022 ECS1 Draft letters regarding Kwok estate assets (2.3); correspond with K. Catalano, W. Farmer, A. Luft and N. Bassett about same

07/10/2022 AEL2 Correspond with E. Sutton regarding draft notice/asset hold letters 0.40 1,510.00 604.00 07/10/2022 AEL2 Review comments on draft notice/asset hold letters and retention notice from N.

07/10/2022 AEL2 Draft parts of notice/asset hold letters and document retention notice 3.30 1,510.00 4,983.00 07/10/2022 NAB Correspond with A. Luft, A. Bongartz, E. Sutton regarding draft letters to counsel and

automatic stay, and document retention (.5); review draft letters (.6); correspond with A. Bongartz, E. Sutton concerning draft letters to parties (.2) 1.30 1,510.00 1,963.00 07/11/2022 DM26 Revise counsel letters regarding notice of trustee appointment and stay 0.90 515.00 463.50

Case 22-50073 Doc 1831 Filed 05/30/23 Entered 05/30/23 08:41:26 Page 129 of 1334

Luc Despins as Chapter 11 Trustee in the case of Ho Wan Kwok 50687-00002 Invoice No. 2356906

Date Initials Description Hours Rate Amount

07/11/2022 DEB4 Correspond with N. Bassett regarding letter writing process related to document/asset

regarding same (0.5); correspond with E. Sutton regarding OCP list professionals for

represented by C. Callari (Callari Partners)

prepetition litigation complaint (0.1);

regarding Greenwich Land LLC (0.1);

regarding letters to law firms (0.5);

certain law firms (0.1); revise recipient list for document/asset hold letters (0.8) 2.40 1,225.00 2,940.00 07/11/2022 ECS1 Prepare letter regarding request for

entities (.9); correspond with N. Bassett, A. Luft, T. Sadler, and D. Barron about same

07/11/2022 ECS1 Prepare letters for entities/persons potentially holding Kwok estate assets and to counsel of Kwok and affiliates (9.7);

same (.3); calls with D. Barron about same (.5); calls with A. Luft about same (.1). 10.60 840.00 8,904.00 07/11/2022 LAD4 Review/edit draft letters to potential targets re: doc preservation and assets dispositions 1.30 1,860.00 2,418.00 07/11/2022 AEL2 Correspond with D. Barron, L. Despins and N. Bassett regarding notice/asset hold letter

07/11/2022 AEL2 Review and revise motion to expedite 0.20 1,510.00 302.00 07/11/2022 AEL2 Correspond with E. Sutton, D. Barron and N. Bassett regarding additional potential targets of notice/asset hold letters (.2); calls with E. Sutton regarding same (.1); analysis regarding same (.4) 0.70 1,510.00 1,057.00

Date Initials Description Hours Rate Amount

07/11/2022 AEL2 Analysis regarding notice/asset hold letters to multiple counsel or targets 0.70 1,510.00 1,057.00 07/11/2022 AEL2 Review underlying documents in

07/11/2022 NAB Review and revise draft letters to parties

07/11/2022 NAB Review and revise draft letters to counsel and parties regarding trustee appointment,

(2.2); correspond with A. Luft, A. Bongartz, D. Barron regarding same (.6); correspond with E. Sutton regarding same (.3) 3.10 1,510.00 4,681.00 07/11/2022 NAB Review authority regarding privilege and related issues and documents 0.80 1,510.00 1,208.00 07/11/2022 WW6 Update asset hold letters 0.80 250.00 200.00 07/12/2022 DM26 Research regarding debtor assets (1.1); research certain pleadings (.5) 1.60 515.00 824.00 07/12/2022 DEB4 Correspond with E. Sutton regarding Rule of Law Society (0.1); conference with A. Luft regarding investigation issues (0.3);

(0.1); correspond with N. Bassett regarding Sherry-Netherland apartment (0.1);

(0.1); conferences with E. Sutton regarding letter drafting process (0.1); correspond with E. Sutton regarding same (0.2);

creditor tip email (0.1); correspond with E.

07/12/2022 DEB4 Correspond with L. Despins regarding statute of limitations issues in connection with avoidance actions 0.10 1,225.00 122.50 Case 22-50073 Doc 1831 Filed 05/30/23 Entered 05/30/23 08:41:26 Page 131 of 1334

Luc Despins as Chapter 11 Trustee in the case of Ho Wan Kwok 50687-00002 Invoice No. 2356906

Date Initials Description Hours Rate Amount

07/12/2022 ECS1 Prepare letters regarding Kwok estate assets (6.4); correspond with K. Catalano, W. Farmer, A. Luft, N. Bassett and L. Despins about same (.3); calls with D. Barron about same (.1); call with N. Bassett about same

07/12/2022 AEL2 Correspond with N. Bassett regarding

07/12/2022 AEL2 Correspond with W. Farmer regarding Rule

07/12/2022 AEL2 Correspond with N. Bassett regarding Rule

07/12/2022 NAB Correspond with E. Sutton, A. Bongartz, D.

steps (.5); telephone conference with E. Sutton regarding same (.1); correspond with

court pleadings in PAX litigation (1.5); review and revise draft letters to parties

automatic stay (1.6); correspond with E. Sutton regarding same (.3); analyze issues in connection with same (.2); correspond with letter recipients regarding same (.2) 4.80 1,510.00 7,248.00 07/13/2022 ECS1 Analyze issues regarding impact of NY state contempt order on Kwok bankruptcy (4.1); calls with A. Luft about same (.3). 4.40 840.00 3,696.00 07/13/2022 ECS1 Prepare letters to entities/persons potentially holding Kwok estate assets and to counsel of Kwok and affiliates (3.2); correspond with D. Barron, L. Despins, and N. Bassett about same (.4). 3.60 840.00 3,024.00 07/13/2022 AEL2 Correspond with D. Barron and E. Sutton re: notice/asset hold letters 0.40 1,510.00 604.00 07/13/2022 AEL2 Call with E. Sutton regarding claims research (.1); calls with E. Sutton regarding NY state contempt order (.3) 0.40 1,510.00 604.00

Date Initials Description Hours Rate Amount

07/13/2022 AEL2 Analysis of certain sources/articles re: potential debtor assets 1.80 1,510.00 2,718.00 07/13/2022 AEL2 Review claims research findings 0.40 1,510.00 604.00 07/13/2022 AEL2 Call with P. Linsey regarding Rule 2004

07/13/2022 AEL2 Analyze potential claims of the debtor 1.40 1,510.00 2,114.00 07/13/2022 AEL2 Call with D. Barron re: non-profit assets 0.30 1,510.00 453.00 07/13/2022 AEL2 Correspond with D. Barron regarding asset location plan/strategy 0.60 1,510.00 906.00 07/13/2022 NAB Analyze initial investigation items, Rule 2004 motions, and particular parties (2.0); review and revise additional letter regarding

(1.2); telephone conference with L. Despins regarding same (.1); correspond with L. Despins regarding same (.1) 3.40 1,510.00 5,134.00 07/14/2022 ECS1 Prepare letters regarding Kwok estate assets (2.0); correspond with D. Barron and N. Bassett about same (.4). 2.40 840.00 2,016.00 07/14/2022 ECS1 Analyze authority regarding chapter 11

privilege/additional privileges. 0.50 840.00 420.00 07/14/2022 AEL2 Review new and revised notice/asset hold

07/14/2022 NAB Review and revise additional letters

automatic stay issues (.5); review case law relating to privilege and res judicata issues (.6); further analyze authority on privilege, discovery, and Rule 2004 process (.9) 2.00 1,510.00 3,020.00 07/15/2022 DEB4 Call with E. Sutton regarding asset and

07/15/2022 DEB4 Call with N. Bassett regarding Rule 2004 motions and related legal issues 0.70 1,225.00 857.50

Case 22-50073 Doc 1831 Filed 05/30/23 Entered 05/30/23 08:41:26 Page 133 of 1334

Luc Despins as Chapter 11 Trustee in the case of Ho Wan Kwok 50687-00002 Invoice No. 2356906

Date Initials Description Hours Rate Amount

07/15/2022 ECS1 Prepare letters to entities/persons potentially holding Kwok estate assets and to counsel of Kwok and affiliates (1.3);

about same (.1); call with D. Barron about

07/15/2022 ECS1 Analyze authority regarding chapter 11

privilege/additional privileges (3.3); correspond with D. Barron, A. Luft, and N. Bassett about same (.4); calls with D. Barron, and N. Bassett about same (.7) 4.40 840.00 3,696.00 07/15/2022 AEL2 Review law regarding control of attorney client privilege 1.40 1,510.00 2,114.00 07/15/2022 NAB Prepare notes for conference with Kwok counsel (.3); attend same with L. Despins

privilege and related issues (.6); correspond with E. Sutton regarding same (.3);

E. Sutton regarding same (.7); correspond

same (.3); prepare email analysis of Rule 2004 and related issues (.5) 3.10 1,510.00 4,681.00 07/16/2022 DEB4 Correspond with L. Despins, S. Sepinuck,

pleadings (0.2); analyze documents related

07/16/2022 LAD4 Telephone call with N. Bassett regarding investigation and related discovery issues 0.30 1,860.00 558.00 07/16/2022 NAB Correspond with L. Despins and E. Sutton regarding investigation and diligence issues (.4); review and revise letters regarding

(.4); analyze discovery and investigation issues and related authority (.8); telephone conference with L. Despins regarding same

Date Initials Description Hours Rate Amount

07/17/2022 DEB4 Prepare summary chart regarding parties for

07/17/2022 ECS1 Analyze authority regarding chapter 11 trustee and attorney client privilege (.1); correspond with L. Despins, D. Barron, A. Luft, and N. Bassett about same (.8) 0.90 840.00 756.00 07/17/2022 ECS1 Correspond with D. Barron and N. Bassett about letters regarding Kwok estate assets 0.20 840.00 168.00 07/17/2022 LAD4 Review N. Bassett's Rule 2004 memo/email 0.30 1,860.00 558.00 07/17/2022 NAB Investigate/analyze Debtor assets and related issues (.4); correspond with L.

regarding same (.2); correspond with A. Luft and D. Barron regarding next steps on discovery and related issues (.3) 1.20 1,510.00 1,812.00 07/18/2022 EE3 Research for D. Mohamed regarding Rule

07/18/2022 ECS1 Prepare letters to entities/persons potentially holding Kwok estate assets and to counsel of Kwok and affiliates (.9);

07/18/2022 ECS1 Analyze issues regarding property of the estate and related case law (3.1); call with A. Luft about same (.2). 3.30 840.00 2,772.00 07/18/2022 ECS1 Analyze authority regarding impact of NY

(2.5); calls with A. Luft about same (.4); correspond with A. Luft about same (.4) 3.30 840.00 2,772.00 07/18/2022 JPK1 Telephone conference with N. Bassett, W.

07/18/2022 AEL2 Call with N. Bassett regarding Rule 2004

07/18/2022 AEL2 Review transcripts and facts for Rule 2004

Date Initials Description Hours Rate Amount

07/18/2022 AEL2 Meeting with N. Bassett, W. Farmer, and J. Kosciewicz regarding Rule 2004 motions 0.50 1,510.00 755.00 07/18/2022 AEL2 Draft inserts to Rule 2004 discovery topics

07/18/2022 NAB Correspond with A. Luft, D. Barron

investigation issues (.4); correspond with L.

with D. Barron regarding discovery (.1); review case law relating to privilege and additional debtor issues (.6); call with A.

related issues (.4); call with A. Luft, W.

07/18/2022 WCF Call with A. Luft, J. Kosciewicz, N. Bassett regarding Rule 2004 discovery strategy 0.50 1,120.00 560.00 07/19/2022 ECS1 Prepare letters to entities/persons potentially holding Kwok estate assets and to counsel of Kwok and affiliates (.4);

07/19/2022 ECS1 Analyze property of the estate issues and

(2.0); correspond with A. Luft about same

07/19/2022 JPK1 Draft proposed order, notice of objection deadline, and certificate of service for Rule 2004 motion to Kwok 1.10 775.00 852.50 07/19/2022 JPK1 Begin drafting Rule 2004 motion to Kwok (2.0); review case documents for procedural and background section of same (2.3) 4.30 775.00 3,332.50 07/19/2022 JPK1 Draft legal argument section for Rule 2004 motion to Kwok (3.1); correspond with A. Luft regarding the same (.2) 3.30 775.00 2,557.50 07/19/2022 AEL2 Prepare parts of Rule 2004 document

Case 22-50073 Doc 1831 Filed 05/30/23 Entered 05/30/23 08:41:26 Page 136 of 1334

Luc Despins as Chapter 11 Trustee in the case of Ho Wan Kwok 50687-00002 Invoice No. 2356906

Date Initials Description Hours Rate Amount 07/19/2022 NAB Review additional letters to parties regarding document discovery and automatic stay 0.30 1,510.00 453.00 07/20/2022 ECS1 Prepare letters to entities/persons potentially holding Kwok estate assets and to counsel of Kwok and affiliates (.3); correspond with D. Barron and N. Bassett about same (.1). 0.40 840.00 336.00 07/20/2022 JPK1 Incorporate W. Farmer's edits into draft Rule 2004 motion to Kwok 3.90 775.00 3,022.50 07/20/2022 AEL2 Correspond with D. Barron regarding Rule 2004 motions 0.10 1,510.00 151.00 07/20/2022 AEL2 Draft parts of document requests for Rule 2004 motions 1.90 1,510.00 2,869.00 07/20/2022 AEL2 Edit Rule 2004 requests for discovery 1.20 1,510.00 1,812.00 07/20/2022 NAB Review additional letters regarding document hold notice and automatic stay (.2); correspond with E. Sutton regarding same and related research (.2) 0.40 1,510.00 604.00 07/20/2022 NAB Correspond with A. Luft regarding discovery and related issues 0.20 1,510.00 302.00 07/20/2022 WCF Review, revise draft Rule 2004 application (.5); correspond with J. Kosciewicz regarding same (.1) 0.60 1,120.00 672.00 07/21/2022 DEB4 Prepare definitions in connection with Rule 2004 motions (0.8); analyze documents related to same (2.3); prepare target list in connection with same (1.2); call with A. Luft and J. Kosciewicz regarding Rule 2004 motions (0.5) 4.80 1,225.00 5,880.00 07/21/2022 DEB4 Correspond with A. Luft, J. Kosciewicz, and W. Farmer regarding Rule 2004 motions (0.2); analyze documents in relation to same (0.4) 0.60 1,225.00 735.00

07/21/2022 ECS1 Prepare letters to entities/persons potentially holding Kwok estate assets and to counsel of Kwok and affiliates 0.20 840.00 168.00 Case 22-50073 Doc 1831 Filed 05/30/23 Entered 05/30/23 08:41:26 Page 137 of 1334

Luc Despins as Chapter 11 Trustee in the case of Ho Wan Kwok 50687-00002 Invoice No. 2356906

Date Initials Description Hours Rate Amount

07/21/2022 JPK1 Telephone conference with A. Luft and D.

accompanying document requests 0.50 775.00 387.50 07/21/2022 JPK1 Begin drafting definitions and instructions

with D. Barron regarding the same (.1) 0.50 775.00 387.50 07/21/2022 JPK1 Continue to draft definitions and

included in Kwok's Rule 2004 motion (1.3);

regarding the same (.1) 1.40 775.00 1,085.00 07/21/2022 JPK1 Incorporate A. Luft's comments into Rule

materials for background section of motion

07/21/2022 AEL2 Prepare parts of Rule 2004 motions and discovery requests (9.5); call with D. Barron and J. Kosciewicz regarding same (.5); calls

contempt order (.6) 10.60 1,510.00 16,006.00 07/21/2022 NAB Correspond with A. Luft regarding discovery and related research (.2); review case findings related to asset investigation

07/22/2022 DM26 Research regarding information about

E. Sutton regarding same (.1). 1.50 515.00 772.50

Case 22-50073 Doc 1831 Filed 05/30/23 Entered 05/30/23 08:41:26 Page 138 of 1334

Luc Despins as Chapter 11 Trustee in the case of Ho Wan Kwok 50687-00002 Invoice No. 2356906

Date Initials Description Hours Rate Amount

07/22/2022 DEB4 Conference with A. Luft, J. Kosciewicz, and

preparation (0.4); correspond with P. Linsey (Neubert) regarding Rule 2004 issues (0.1); revise J. Kosciewicz draft Rule 2004 motion (1.3); revise Rule 2004 target lists (0.5);

regarding professional firm targets (0.3); conference with A. Luft regarding topic list

with W. Farmer regarding same (0.3);

business associates of Debtor (0.1);

related Rule 2004 motion information (0.1);

regarding revised target lists (0.6) 3.90 1,225.00 4,777.50 07/22/2022 ECS1 Analyze issue regarding chapter 11 trustee and attorney client privilege (.1); correspond

with W. Farmer about same (.1) 0.30 840.00 252.00 07/22/2022 ECS1 Prepare letters to entities/persons potentially holding Kwok estate assets and to counsel of Kwok and affiliates. 0.40 840.00 336.00 07/22/2022 JPK1 Telephone conference with A. Luft, D.

on Rule 2004 motions 0.40 775.00 310.00 07/22/2022 JPK1 Correspond with W. Farmer regarding

additional omnibus style motions 0.30 775.00 232.50 07/22/2022 JPK1 Revise the Rule 2004 motion addressed to

and W. Farmer regarding the same (.3) 5.20 775.00 4,030.00 07/22/2022 JPK1 Draft requests for productions addressed to

(2.9); correspond with A. Luft regarding the

07/22/2022 JPK1 Correspond with P. Hawthorne regarding precedent omnibus Rule 2004 motions 0.20 775.00 155.00 Case 22-50073 Doc 1831 Filed 05/30/23 Entered 05/30/23 08:41:26 Page 139 of 1334

Luc Despins as Chapter 11 Trustee in the case of Ho Wan Kwok 50687-00002 Invoice No. 2356906

Date Initials Description Hours Rate Amount

07/22/2022 JPK1 Draft procedural section for Rule 2004 motion addressed to M. Kwok (2.2); revise

incorporating comments from A. Luft (1.4); correspond with A. Luft regarding the same

07/22/2022 LAD4 Review/comment on Rule 2004 program 2.10 1,860.00 3,906.00 07/22/2022 AEL2 Call with P. Linsey (Neubert) re: Rule 2004

07/22/2022 AEL2 Correspond with W. Farmer regarding Rule 2004 motion for counsel 0.30 1,510.00 453.00 07/22/2022 AEL2 Calls with D. Barron regarding document

Rule 2004 discovery 0.30 1,510.00 453.00 07/22/2022 AEL2 Call with D. Barron, W. Farmer, and J.

and related authority 0.40 1,510.00 604.00 07/22/2022 AEL2 Prepare parts of and revise Rule 2004

07/22/2022 AEL2 Call with N. Bassett regarding Rule 2004