Guo Wengui / Miles Guo — bankruptcy case · ORDER · ECF #1879

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

In re:

<span id="page-0-0"></span>

Chapter 11 Case No.

HO WAN KWOK, *et al[.](#page-0-0)*¹

22-50073 (JAM)

<span id="page-0-1"></span>Debtors.

June 5, 2023

# **PACIFIC ALLIANCE ASIA OPPORTUNITY FUND L.P.'S MOTION TO PERMIT CERTAIN COUNSEL TO APPEAR REMOTELY FOR JUNE 6, 2023 HEARING**

Pursuant to section 105(a) of the Bankruptcy Code and Rule 1001 of the Federal Rules of Bankruptcy Procedure (the "Bankruptcy Rules"), Pacific Alliance Asia Opportunity Fund L.P. ("PAX"), by and thorough its undersigned counsel, respectfully moves (this "Motion") the Court for permission for Attorney Stuart Sarnoff of O'Melveny & Myers LLP ("O'Melveny") to appear remotely on behalf of PAX at the hearing currently scheduled for Tuesday, June 6, 2023. In support of the Motion, PAX respectfully states as follows:

## **JURISDICTION AND VENUE**

1. The United States Bankruptcy Court for the District of Connecticut (the "Court") has jurisdiction over this Motion pursuant to 28 U.S.C. §§ 157 and 1334. Venue is proper in this District pursuant to 28 U.S.C. §§ 1408 and 1409. This matter is a core proceeding within the meaning of 28 U.S.C. § 157(b)(2), and the Court may enter a final order consistent with Article

¹ [T](#page-0-1)he 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) ("Kwok" or the "Individual Debtor"), Genever Holdings Corporation ("Genever BVI"), and Genever Holdings LLC (last four digits of tax identification number: 8202) ("Genever US"). The mailing address for the Trustee, Genever BVI, and Genever US 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).

III of the United States Constitution. The statutory bases for the relief sought herein are section 105(a) of the Bankruptcy Code and Bankruptcy Rule 1001.

#### **BACKGROUND AND REQUESTED RELIEF**

2. The Court scheduled a hearing and status conference in the above-captioned case and related adversary proceedings for June 6, 2023 at 1:00 PM (the "Hearing"). PAX has not filed papers concerning any of the matters on the calendar for the Hearing but given the numerous interests in this case, counsel will be in attendance.

3. Mr. Sarnoff has pre-existing obligations in New York City that conflict with his inperson attendance at the Hearing. Connecticut counsel for PAX will attend in person.

4. Because of Mr. Sarnoff's unavailability and the in-person attendance of Connecticut counsel, counsel to PAX respectfully requests permission for Mr. Sarnoff to attend the Hearing via the Court's ZOOM.Gov platform.

## **CONCLUSION**

WHEREFORE, PAX respectfully requests that Mr. Sarnoff be permitted to appear remotely before this Court on June 6, 2023 at 1:00 PM.

*[Signature on following page]*

Dated: June 5, 2023 Hartford, Connecticut

#### **Pacific Alliance Asia Opportunity Fund L.P.**

*By: /s/ Patrick M. Birney* Patrick M. Birney (CT No. 19875) Annecca H. Smith (CT No. 31148) **ROBINSON & COLE LLP** 280 Trumbull Street Hartford, CT 06103 Telephone: (860) 275-8275 Facsimile: (860) 275-8299 E-mail: pbirney@rc.com asmith@rc.com

-and-

Peter Friedman (admitted *pro hac vice*) Stuart M. Sarnoff (admitted *pro hac vice*) Laura S. Aronsson (admitted *pro hac vice*) **O'MELVENY & MYERS LLP** Seven Times Square New York, NY 10036 Telephone: (212) 326-2000 Facsimile: (212) 326-2061 Email: pfriedman@omm.com ssarnoff@omm.com laronsson@omm.com

## **CERTIFICATE OF SERVICE**

I hereby certify that on June 5, 2023, a copy of the foregoing was filed electronically and shall be served as required by Local Bankruptcy Rule 9013-2(b), with notice of this filing being sent by email to all Notice Parties by operation of the court's electronic filing system or by First Class U.S. mail to anyone unable to accept electronic filing as indicated on the Notice of Electronic Filing. Parties in interest may access this document through the court's CM/ECF System.

> */s/ Patrick M. Birney\_\_* Patrick M. Birney