Guo Wengui / Miles Guo — bankruptcy case · ORDER · ECF #2025

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

In re:

HO WAN KWOK, et al.,

Chapter 11

) ) ) ) ) ) ) )

Case No. 22-50073 (JAM)

Debtors. ¹

(Jointly Administered)

# **FEE APPLICATION COVERSHEET**

Date of Entry of Retention Order:

**Amounts Requested** Fees: \$3,381.75 Expenses: \$0.00 Total: \$3,381.75

**Fees Previously Requested (Sanctions):** Requested Fees: \$0.00 Awarded Fees: \$0.00 Paid Fees: \$0.00

**Expenses Previously Requested:** Requested Expenses: \$0.00 Awarded Expenses: \$0.00 Paid Expenses: \$0.00

Interim Application of: The Bohonnon Law Firm, LLC

Time Period: From: June 14, 2023 To: June 30, 2023

**Reductions:** Voluntary Fee Reductions: Not applicable Voluntary Expense Reductions: Not applicable

**Retainer Request:** None.

**Expense Detail:** Retainer Received: Not applicable

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 (collectively, the "Chapter 11 case"). 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).

# **HOURS AND RATES PER PROFESSIONAL**

| Name of<br>Professional<br>Individual | Position with<br>the Applicant | Hourly Billing<br>Rate | Total Hours<br>Billed | Total<br>Compensation | |---------------------------------------|--------------------------------|------------------------|-----------------------|-----------------------| | David M.<br>Bohonnon | Partner | \$650 | 5.30 | \$3,445.00 | | Steven A. Clark | Partner | \$595 | 0.65 | \$386.75 |

**TOTAL: \_\_5.95\_\_\_\_ \$3,831.75**

**Blended Rate: \$642\_\_\_\_**

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

| ----------------------------------------------------------- | x | | |-------------------------------------------------------------|--------|-------------------------| | In re: | :<br>: | Chapter 11 | | | : | | | HO WAN KWOK, et al., | : | Case No. 22-50073 (JAM) | | Debtors.2 | :<br>: | Jointly Administered | | ----------------------------------------------------------- | :<br>x | |

# **APPLICATION OF CHAPTER 11 TRUSTEE FOR ENTRY OF ORDER (I) APPROVING RETENTION OF THE BOHONNON LAW FIRM, LLC, AS SPECIAL MARITIME CLOSING COUNSEL TO THE TRUSTEE EFFECTIVE AS OF JUNE 14, 2023, AND (II) FOR THE ALLOWANCE AND PAYMENT OF FEES FOR THE PERIOD JUNE 14, 2023, THROUGH JUNE 30, 2023, IN THE AMOUNT OF \$3,831.75 AND (III) GRANTING RELATED RELIEF**

Luc Despins, in his capacity as the Chapter 11 trustee (the "Trustee" or "Movant") appointed in the Chapter 11 case of Ho Wan Kwok (the "Individual Debtor"), files this application (the "Application") requesting entry of an order, substantially in the form attached hereto as **Exhibit A** (the "Proposed Order"): (i) appointing The Bohonnon Law Firm, LLC ("Bohonnon") as special maritime closing counsel to the Trustee ("Maritime Counsel"), effective as of June 14, 2023, pursuant to sections 105(a) 327, 328, 330 and 331 of Title 11 of the United States Code (the "Bankruptcy Code"), in connection with the sale of the *Lady May* and the *Lady May II*; (ii) allowing Bohonnon fees for the period from June 14, 2023 through June 30, 2023 (the "Compensation Period") in the amount of \$3,831.75 for services rendered to the Debtor's estate

² The Debtors in these chapter 11 cases are Ho Wan Kwok (also known as Guo Wengui, Miles Guo, and Miles Kwok, as well as numerous other aliases) (last four digits of tax identification number: 9595), Genever Holdings LLC (last four digits of tax identification number: 8202) and Genever Holdings Corporation (collectively the "Chapter 11 case"). The mailing address for the Trustee, Genever Holdings LLC, 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).

and authorizing the payment thereof; and (iii) granting related relief. In support of this Application, the Trustee submits the declaration of David Bohonnon, principal of Bohonnon (the "Bohonnon Declaration"), attached as **Exhibit B** hereto, and further respectfully states as follows.

## **JURISDICTION, VENUE, AND STATUTORY BASIS**

1. The United States Bankruptcy Court for the District of Connecticut (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 is a core proceeding within the meaning of 28 U.S.C. § 157(b).

2. Venue in this District is proper pursuant to 28 U.S.C. §§ 1408 and 1409.

3. The basis for the relief requested herein are sections 105(a) 327, 328, 330 and 331 of title 11 of the Bankruptcy Code.

## **BACKGROUND**

4. 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.

5. 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.

6. 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 11 trustee in the Individual Debtor's Chapter 11 case. Pursuant to the Trustee Order, the United States Trustee selected Luc A. Despins as the Trustee.³

³ The references to docket numbers set forth in this Application refer to the Chapter 11 Case docket unless otherwise indicated.

7. On July 8, 2022, the Court entered an order granting the appointment of Luc A. Despins as the Trustee in the Individual Debtor's Chapter 11 case [Docket No. 523].

8. On June 28, 2023, the Court entered an order (the "Sale Order") [ECF No. 1953] approving the sale of the *Lady May,* a 2014 Feadship 44.25 meter motor yacht, British official #745195 and its tender and inventory (the "Lady May") by the Trustee to Herb Chambers Yachting LLC, or its assignee, 4 (the "Purchaser") pursuant to the terms of that Purchase and Sale Agreement by and between Trustee and the Purchaser dated May 30, 2023 (the "PSA").

9. The closing of the sale of the Lady May to the Purchaser was consummated on June 30, 2023 (the "Closing"). In accordance with the terms of the Sale Order, a Notice of Filing of Closing Statement was filed on July 7, 2023 [ECF No. 1984] evidencing that the Debtor's estate realized net proceeds from the sale of the Lady May in the amount of \$21,992,500.00.

10. In addition to the Lady May, the Trustee is also seeking to sell the *Lady May II*, a 2011 Windy Scandinavia AB motor yacht, British official #746230 (the "Lady May II").

#### **BOHONNON'S RETENTION**

11. By this Application, the Movant requests entry of an order, substantially in the form attached hereto, appointing Bohonnon as Maritime Counsel for the Trustee, effective as of June 14, 2023, in connection with the sale of the Lady May and the eventual sale of the Lady May II.

12. While Paul Hastings LLP has represented the Trustee and handled all aspect of the sale of the Lady May*,* during the closing process for the sale of the Lady May, it became evident that the Trustee also required expertise in maritime law and familiarity with the sale of marine vessels—which is not among Paul Hastings LLP's wide range of expertise. Bohonnon

⁴Herb Chambers Yachting LLC assigned its interest under the PSA to Excellence Maritime, Ltd.

has extensive maritime law expertise and was retained by the Trustee to assist with sale transaction pursuant to the terms of the PSA and the Sale Order.

13. The sale of Lady May was on an expedited basis, with the closing taking place just days after entry of the Sale Order and just one month after execution of the PSA. As a result, it was imperative that Bohonnon immediately commence work reviewing the terms of the PSA and ensuring the transaction was consummated upon its terms and in accordance with the Sale Order.

## **BOHONNON'S QUALIFICATIONS**

14. Bohonnon is a New Haven, Connecticut-based law firm of admiralty attorneys licensed in Connecticut, Rhode Island, and several other states. The firm's primary practice is in the area of maritime legal issues. David Bohonnon, one of Bohonnon's partners, has maintained a maritime law practice for more than thirty years.

15. Bohonnon has substantial experience in the legal issues associated with the sale of large marine vessels and yachts. Bohonnon was particularly well-suited to assist the Trustee with the closing on the sale of the *Lady May*.

#### **SERVICES PROVIDED**

16. At the request of the Trustee, Bohonnon rendered limited services relating to the sale of *Lady May*, including, the following:

- a) Review of the PSA; - b) Review and preparation of responses to the Buyer's due diligence requests; - c) Review and provide comments on the Buyer's closing documentation and prepare closing documentation for the Trustee; and - d) Prepare for and attendance at the closing of the sale of the *Lady May*.

17. The Trustee anticipates that it will similarly require Bohonnon's expertise in connection with an eventual sale of the Lady May II.

#### **BOHONNON'S COMPENSATION**

18. The Trustee believes that the fees incurred by Bohonnon in the performance of the above services should be treated as administrative expenses of the Debtor's Chapter 11 estates pursuant to section 503(b)(1)(A) of the Bankruptcy Code and requests that the fees be paid pursuant to this Application. Bohonnon has rendered legal services to the Trustee at its usual and customary hourly rate, ranging from \$595.00 - \$650.00 per hour.

#### **DISINTERESTED**

19. Bohonnon has reviewed its electronic database to determine whether it has any relationships with the Purchaser, creditors, and parties in interest provided by the Trustee. As set forth in the Bohonnon Declaration, Bohonnon has represented that it neither holds nor represents any interest materially adverse to the Debtors, their creditors, or other relevant parties, by reason of any direct or indirect relationship to, connection with, or interest in, the Debtors, or for any other reason.

20. Moreover, in connection with its retention as Maritime Counsel, Bohonnon represents in the Bohonnon Declaration, among other things, that it is not a creditor of the Debtors and agrees to supplement its disclosure to the Court if any facts or circumstances are discovered that would require such additional disclosure.

#### **SUMMARY OF PROFESSIONAL SERVICES**

21. Pursuant to, and consistent with, the relevant requirements of the Local Bankruptcy Rules (the "Guidelines"), as applicable, the following exhibits are attached hereto:

> **Exhibit A** contains the proposed order requesting approval of this Application; **Exhibit B** contains the Bohonnon Declaration; and

> > 8

**Exhibit C** contains Bohonnon's time detail for the Compensation Period.

22. The professional services rendered by Bohonnon as Maritime Counsel to the

Trustee during the Compensation Period consisted of:

a. Communications with the Trustee, review of the PSA and amendments thereto

Total Fees: \$985.50

Total Hours: 1.55

b. Overview and compliance with Buyer's due diligence request

Total Fees: \$1,007.50

Total Hours: 1.55

c. Review and preparation of closing documents

Total Fees: \$1,513.75

Total Hours: 2.35

d. Attendance at closing of the sale of the Lady May

Total Fees: \$325.00

Total Hours: 0.50

#### **REASONABLE AND NECESSARY SERVICES RENDERED BY BOHONNON**

23. The foregoing professional services rendered by Bohonnon on behalf of the Trustee during the Compensation Period were reasonable, necessary, and appropriate to the administration of the Chapter 11 Case.

24. During the Compensation Period, Bohonnon's hourly billing rates for the professionals responsible for providing legal services to the Trustee ranged from \$595.00 to \$650.00. Allowance of compensation in the amount requested would result in a blended hourly billing rate for professionals of approximately \$642.00. The hourly rates and corresponding rate structure utilized by Bohonnon, in this case, are generally equivalent to the hourly rates and

corresponding rate structure predominantly used by Bohonnon for comparable matters, whether in Chapter 11 or otherwise, regardless of whether a fee application is required.

# **BOHONNON'S REQUESTED COMPENSATION SHOULD BE ALLOWED**

25. 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 of the Bankruptcy Code provides that a court may award a professional employed under section 327 of the Bankruptcy Code "reasonable compensation for actual, necessary services rendered. . . and reimbursement for actual, necessary expenses." Section 330 of the Bankruptcy Code also sets forth the criteria for the award of such compensation and reimbursement:

26. In determining the amount of reasonable compensation to be awarded, the Court should consider the nature, extent, and value of such services, taking into account all relevant factors, including:

a. the time spent on such services;

b. the rates charged for such services;

c. whether the services were necessary to the administration of, or beneficial at the time at which the service was rendered toward the completion of, a case under this title;

d. whether the services were performed within a reasonable amount of time commensurate with the complexity, importance, and nature of the problem, issue, or task addressed; and

e. whether the compensation is reasonable based on the customary compensation charged by comparably skilled practitioners in cases other than cases under this title.

11 U.S.C. § 330(a)(3).

27. In the instant case, the Trustee respectfully submits that the services for which

Bohonnon seeks compensation in the Application were necessary for and beneficial to the

Trustee and the Chapter 11 Case and were rendered to facilitate the consummation of the sale of a significant asset for the benefit of creditors. The Trustee respectfully submits that the services rendered were performed economically, effectively, and efficiently. The Trustee further submits that the compensation requested herein is reasonable in light of the nature, extent, and value of such services to the Trustee, the Chapter 11 Case, and all parties of interest.

## **NO PRIOR REQUEST**

28. No prior application for the relief requested herein has been made to this or any other court.

#### **BASIS FOR THE RELIEF**

29. This Application is made pursuant to sections 105(a) 327, 328, 330, and 331 of the Bankruptcy Code, and Bankruptcy Rule 2002(f), for entry of an order approving the retention of Bohonnon as Maritime Counsel for the Debtors' estates, for allowance of Bohonnon's fees incurred during the Compensation Period in the total amount of \$3,831.75 as an administrative expense of the Debtors' estates and further authorizing the Trustee to pay such allowed fees.

#### **RETENTION EFFECTIVE AS OF JUNE 14, 2023, IS APPROPRIATE**

30. Local Bankruptcy Rule 2014-1 provides that if "an application to employ a professional is filed within thirty (30) days after the commencement of services provided by that professional, the application shall be deemed contemporaneously filed unless the Court orders otherwise." While this Application is made just beyond that 30-day period, under the particulars of Debtors' complex cases, it is being filed as expeditiously as circumstances allow. Accordingly, the Trustee requests authority to retain and employ Bohonnon effective June 14, 2023, which was the date that Bohonnon began providing services to the Trustee.

## **NOTICE**

31. Notice of this Motion has been given to the United States Trustee, the Individual Debtor, the Committee, and, by electronic filing utilizing the Court's electronic filing ("CM/ECF") system, to all appearing parties who utilize the CM/ECF system.

32. Accordingly, the Trustee respectfully submits that the Bohonnon retention and approval of the compensation sought herein is warranted.

*[Remainder of page intentionally left blank]*

WHEREFORE, for the foregoing reasons, the Trustee requests that the Court enter an

Order, substantially in the form of the Proposed Order filed herewith, granting the Application, authorizing the employment of Bohonnon as Maritime Counsel in connection with the sale of the *Lady May* and the *Lady May II*, allowance of Bohonnon's fees in the amount of \$3,831.75 for services rendered as Maritime Counsel and authorizing the payment of such allowed fees, and such other and further relief as the Court deems just and proper.

Dated: July 21, 2023 New Haven, Connecticut

# LUC A. DESPINS, CHAPTER 11 TRUSTEE

By: */s/ Douglas S. Skalka* Douglas S. Skalka (ct00616) Patrick R. Linsey (ct29437) NEUBERT, PEPE & MONTEITH, P.C. 195 Church Street, 13th Floor New Haven, Connecticut 06510 (203) 821-2000 dskalka@npmlaw.com plinsey@npmlaw.com

*and*

G. Alexander Bongartz, Esq. PAUL HASTINGS LLP 200 Park Avenue New York, New York 10166 (212) 318-6472

*Counsel for the Chapter 11 Trustee*

Case 22-50073 Doc 2025 Filed 07/21/23 Entered 07/21/23 13:07:59 Page 13 of 30

# **EXHIBIT A**

**Proposed Order**

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

| ----------------------------------------------------------- | x | | |-------------------------------------------------------------|--------|-------------------------| | In re: | :<br>: | Chapter 11 | | | : | | | HO WAN KWOK, et al., | :<br>: | Case No. 22-50073 (JAM) | | Debtors.1 | : | Jointly Administered | | ----------------------------------------------------------- | :<br>x | |

# **ORDER APPROVING (I) RETENTION OF THE BOHONNON LAW FIRM, LLC, AS SPECIAL MARITIME CLOSING COUNSEL TO THE TRUSTEE EFFECTIVE AS OF JUNE 14, 2023, AND (II) FOR THE ALLOWANCE AND PAYMENT OF FEES FOR THE PERIOD JUNE 14, 2023, THROUGH JUNE 30, 2023, IN THE AMOUNT OF \$3,831.75 AND (III) GRANTING RELATED RELIEF**

Upon the application (the "Application") of Luc Despins, in his capacity as the Chapter 11 trustee (the "Trustee" or "Movant") appointed in the Chapter 11 case of Ho Wan Kwok (the "Debtor") for entry of an order (this "Order") (a) approving the retention of The Bohonnon Law Firm, LLC ("Bohonnon") as special maritime closing counsel effective as of June 14, 2023, under sections 105(a) and 327 of the Bankruptcy Code, and (b) for the allowance of fees for services rendered by Bohonnon from the period commencing June 14, 2023 through and including June 30, 2023 (the "Compensation Period"); and (c) authorizing the Trustee to pay any allowed fees to Bohonnon; and it appearing that Bohonnon does not hold an interest adverse to the Debtors or the estates respecting the matters upon which it is to be engaged; and good and

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, 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).

sufficient notice of the Application having been given; and no other or further notice being required; and it appearing that (i) the employment of Bohonnon is in the best interest of the Debtors' estates and creditors; and sufficient cause appearing therefor and (ii) in the absence of any objection to the Application with respect to compensation of Bohonnon for services rendered to the estate;

## IT IS HEREBY ORDERED THAT:

1. The Application is approved as set forth in this Order.

2. The Trustee is are authorized to retain Bohonnon, and Bohonnon is retained as special maritime closing counsel, effective as of June 14, 2023, to represent the Trustee in accordance with 11 U.S.C. Section 327, in connection with the sale of the *Lady May* and the *Lady May II*.

3. The Application for compensation is approved and the fees in the amount of \$3,831.75, are awarded as compensation to Bohonnon subject to final adjustment and disgorgement in the event all administrative expenses are not paid in full.

4. The Trustee, on behalf of the Debtor's estate, is authorized to pay the awarded compensation to Bohonnon.

2

# **EXHIBIT B**

**Declaration**

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

| ----------------------------------------------------------- | x | | |-------------------------------------------------------------|-------------|-------------------------| | In re: | :<br>: | Chapter 11 | | HO WAN KWOK, et al., | :<br>:<br>: | Case No. 22-50073 (JAM) | | Debtors.1 | :<br>: | Jointly Administered | | ----------------------------------------------------------- | x | |

# **DECLARATION OF DAVID BOHONNON IN SUPPORT OF TRUSTEE'S APPLICATION FOR AUTHORIZATION TO RETAIN AND EMPLOY THE BOHONNON LAW FIRM, LLC AS SPECIAL MARITIME CLOSING COUNSEL TO THE TRUSTEE AND FOR ALLOWANCE AND PAYMENT OF COMPENSATION FOR SERVICES RENDERED BY BOHONNON FOR THE PERIOD FROM JUNE 14, 2023, THROUGH JUNE 30, 2023**

I, David Bohonnon, make this declaration under 28 U.S.C. § 1746:

1. I am a principal of the Bohonnon Law Firm, LLC ("Bohonnon"). The matters set

forth herein are made of my own personal knowledge and, if called and sworn as a witness, I

could and would testify competently thereto.²

2. This Declaration is made in support of the Trustee's application (the "Application")³

for an order pursuant to sections 105(a), 327 and 503(b)(1)(A) of title 11 of the United States Code

(the "Bankruptcy Code"), authorizing the employment and retention of Bohonnon as special

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, 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 Certain of the disclosures herein relate to matters within the knowledge of other professionals at Bohonnon and are based on information provided by them.

³ Capitalized terms used but not otherwise defined herein shall have the respective meanings ascribed to such terms in the Application.

maritime closing counsel to the Trustee as of June 14, 2023. A proposed form of order granting the relief requested in the Application (the "Proposed Order") is annexed thereto as **Exhibit A**.

3. Bohonnon is a fourth-generation firm of maritime lawyers and proctors in maritime law. Bohonnon has substantial experience in matters of this nature and has often acted as counsel in the purchase and sale of maritime vessels.

4. To the best of my knowledge, Bohonnon has not represented the Debtors, their creditors, or other parties-in-interest, in connection with the Debtors' bankruptcy proceedings. Further, to the best of my knowledge, Bohonnon does not hold or represent an interest adverse to the interests of the creditors of the Debtors' bankruptcy estates.

5. To the best of my knowledge, understanding, and belief, the proposed employment of Bohonnon is in all respects in accordance with and proper under 11 U.S.C. Section 327.

6. Bohonnon has reviewed the list of Debtors' 20 largest unsecured creditors, the Debtors' affiliates and family members, and other parties-in-interest set forth on **Schedule 1** attached hereto (the "Disclosed Parties"). Except as disclosed in **Schedule 2** attached hereto, to the best of my knowledge, Bohonnon has no relationship with any of the Disclosed Parties. Bohonnon personnel may have relationships with some of the Debtors' creditors or other parties of interest. However, to the best of my knowledge, such relationships, to the extent they exist, are completely unrelated to these Chapter 11 cases. Bohonnon has and will continue to represent clients in matters unrelated to these Chapter 11 cases. In addition, Bohonnon has had and will continue to have relationships in the ordinary course of its business with certain vendors, professionals, and other parties in interest that may be involved in the Debtors' cases in matters unrelated to these cases. Bohonnon may also provide professional services to entities or persons that may be creditors or parties in interest in these chapter 11 cases, which services do not directly relate to, or have any

direct connection with, these chapter 11 cases of the Debtors. To the best of my knowledge, neither Bohonnon nor any employees thereof represent any interest materially adverse to the Debtors' estates with respect to any matter upon which Bohonnon is to be engaged. Based on the foregoing, I believe that Bohonnon is a "disinterested person" as that term is defined in section 101(14) of the Bankruptcy Code.

7. Pursuant to 28 U.S.C. § 1746, I declare under penalty of perjury that the foregoing is true and correct to the best of my information, knowledge, and belief.

Dated: July 21, 2023

David Bohonnon Principal Bohonnon Law Firm, LLC

*\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_*

Case 22-50073 Doc 2025 Filed 07/21/23 Entered 07/21/23 13:07:59 Page 20 of 30

# **SCHEDULE 1**

**Potential Parties in Interest**

## **SCHEDULE OF PARTIES IN INTEREST**

#### **20 LARGEST UNSECURED CREDITORS**

PACIFIC ALLIANCE ASIA OPPORTUNITY GOLDEN SPRING NEW YORK RUI MA CHENG JIAN WU JIAN SHE NING YE GUO BAOSHENG YAN LAN & WU ZHENG HONG QI QU NAN TONG SI JIAN JIAN GONG YAN ZHAO YUA HUA ZHUANG SHI LIEHONG ZHUANG/XIAO YAN ZHU WEICAN MENG/BOXUN INC. SAMUEL NUNBERG LAMP CAPITAL LLC JUN CHEN AKA JONATHAN HO YUE HUA ZHU SHI XIONG XIAN WEI YE HUIZEN WANG

#### **DEBTOR, FAMILY MEMBERS, AND CERTAIN RELATED ENTITIES**

HO WAN KWOK (A.K.A MILES GWOK, MILES GUO AND WENGUI GUO) HING CH NGOK/YUE QINGZHI QIANG GUO MEI GUO/MEI GUI HK INTERNATIONAL FUNDS INVESTMENTS (USA) LIMITED, LLC BRAVO LUCK LIMITED GENEVER HOLDINGS CORPORATION GENEVER HOLDINGS LLC

#### **BANKRUPTCY JUDGE AND U.S. TRUSTEE PERSONNEL**

HONORABLE JULIE A. MANNING WILLIAM HARRINGTON KIM L. MCCABE HOLLEY CLAIBORN JOSEPH H. FLAMINI ERIN HOGAN STEVEN MACKEY FRANK MARINO JENNIFER J. MOREY NICOLE NEELY SHARON WARNER JOHN GERVAIS

#### **OTHER INTERESTED PARTIES**

7 NOD HILL LLC, 7 STAR EAST NY LLC AAGV LIMITED ABRAMS FENSTERMAN, LLP ACA CAPITAL GROUP LIMITED ACA INVESTMENT FUND ACA INVESTMENT MANAGEMENT LTD. ACASS CANADA LTD. ACE DECADE HOLDINGS LIMITED AI GROUP HOLDINGS INC., ALFA GLOBAL VENTURES LIMITED ALFONSO GLOBAL LIMITED ALLIED CAPITAL GLOBAL LIMITED ALPINE FIDUCIARIES SA AN HONG ANDREW SULNER/FORENSIC DOCUMENT EXAMINATIONS, LLC ANTON DEVELOPMENT LIMITED APSLEY YACHTS LIMITED ARETHUSA FORSYTH ARI CASPER ASSETS SINO LIMITED AUSPICIOUS COAST LIMITED BAIQIAO TANG A/K/A TANG BAIQIAO BAKER HOSTETLER LLP BARCLAYS BANK PLC BEIJING BI HAI GE LIN YUAN LIN LU HUA, LTD. BEIJING CHENG JIAN WU JIAN SHE GROUP, LTD. BEIJING FU LE HONG MA JIAN ZHU ZHUANG SHI GONG CHENG, LTD. BEIJING PANGU INVESTMENT CO. BEIJING ZENITH HOLDINGS CO. BEIJING ZHONG XIAN WEI YE STAINLESS DECORATION CENTER BERKELEY ROWE BERNARDO ENRIQUEZ BNY MELLON, N.A. BOIES SCHILLER BOXUN INC. BRANCH BROWN HARRIS STEVENS BROWN RUDNICK, LLP BSA STRATEGIC FUND I BURNETTE SHUTT AND MCDANIEL PA CAHILL GORDON & REINDEL LLP CAPITAL ONE BANK CHAO-CHIH CHIU CHASE BANK CHENGLONG WANG CHIESA SHAHINIAN & GIANTOMASI PC CHINA GOLDEN SPRING GROUP (HONG KONG) LIMITED CHONG SHEN RAPHANELLA CHUANG XIN LTD. CITIBANK CLARK HILL PLC CLAYMAN & ROSENBERG LLP CLAYMAN ROSENBERG KIRSHNER & LINDER LLP

COHN BIRNBAUM & SHEA P.C. COUNSEL PRESS INC. CRANE ADVISORY GROUP LLC CREATIVE APEX INVESTMENTS LIMITED CRYSTAL BREEZE INVESTMENTS LIMITED DANIEL PODHASKIE DANIEL S. ALTER DANYU LIN DAWN STATE LIMITED DONGNA FANG DWF LLP EASTERN PROFIT CORPORATION LIMITED EDUARDO EURNEKIAN ELITE WELL GLOBAL LIMITED ELLIOTT KWOK LEVINE & JAROSLAW LLP EMPIRE GROWTH HOLDINGS ERIC GOLDSMITH MD, LLC FAN BINGBING FIONA YU FIRST ABU DHABI BANK FORBES HARE FREEDOM MEDIA VENTURE LTD G CLUB OPERATIONS LLC G CLUB US OPERATIONS INC. G CLUB US OPERATIONS LLC G FASHION LLC G FASHION US OPERATIONS INC. G LIVE, LLC G NEWS LLC, GANFER SHORE LEEDS & ZAUDERER GAO BINGCHEN GBROADCAST, LLC G-CLUB G-CLUB INVESTMENTS LIMITED GETTR USA GFASHION MEDIA GROUP INC., GFNY, INC GLENN MELLOR GLOBALIST INTERNATIONAL LIMITED GMUSIC, GNEWS LLC, GNEWS MEDIA GROUP INC., GOLDFARB & HUCK ROTH RIOJAS, PLLC GPOSTS LLC GREENWICH LAND LLC G-TRANSLATORS PTY LTD GTV MEDIA GROUP, INC., GUO LIJIE GUO MEDIA GUO WENOUN GUO WENPING GUY PETRILLO

HAIHONG WANG HAMILTON CAPITAL HOLDINGS INC HAN CHUNGUANG HAO HAIDONG HARCUS PARKER LTD. HCHK PROPERTY MANAGEMENT, INC. HCHK TECHNOLOGIES, INC. HCHK TECHNOLOGIES, LLC HE BEI YUE HUA ZHUANG SHI GONG CHENG LTD. HEAD WIN GROUP LIMITED HELEN MANIS HENAN YUDA HERO GRAND LIMITED HIMALAYA EMBASSY HIMALAYA EXCHANGE HIMALAYA FEDERAL RESERVE HIMALAYA INTERNATIONAL CLEARING LTD. HIMALAYA INTERNATIONAL FINANCIAL GROUP LTD HIMALAYA INTERNATIONAL PAYMENTS LTD. HIMALAYA INTERNATIONAL RESERVES LTD. HIMALAYA NEW WORLD INC. HIMALAYA SUPERVISORY ORGANIZATION HING CH NGOK HONG KONG INTERNATIONAL FUNDS INVESTMENTS LIMITED HONG QI QU JIAN SHE GROUP, LTD. HONG ZENG HSBC HUDSON DIAMOND HOLDING INC. HUDSON DIAMOND HOLDING LLC HUDSON DIAMOND LLC HUDSON DIAMOND NY LLC INFINITE INCREASE LIMITED INFINITUM DEVELOPMENTS LIMITED INSIGHT CAPITAL INSIGHT PHOENIX FUND JACK S. LIPSON JANOVER LLC JASON MILLER JENNIFER MERCURIO JESSE BROWN JIA LI WANG JIA YANG LI JIAMEI LU JIAN FAN JIANG SU PROVINCE JIAN GONG GROUP LTD BEIJING BRANCH JIANG YUNFU BE JIANHU YI JIANSHENGXIE AND JIEFU ZHENG JING GENG JOHN S LAU JONATHAN YOUNG JUMBO CENTURY LIMITED JUN LIU JUNE SHI

KAIXIN HONG KARIN MAISTRELLO, KATHLEEN SLOANE KERCSMAR FELTUS & COLLINS PLLC KEYI ZIKLIE KUI CHENG LALIVE SA LAO JIANG LAW FIRM OF CALLARI PARTNERS, LLC LAWALL & MITCHELL, LLC LEADING SHINE LIMITED LEADING SHINE NY LTD LEE VARTAN LIEHONG ZHUANG LIHONG WEI LAFRENZ (AKA SARA WEI) LINDA HE CHEUNG LOGAN CHENG (F/K/A SHUIYAN CHENG) LONG GATE LIMITED MACDONALD MAR-A-LAGO MAUNAKAI CAPITAL MAX KRASNER MCELROY, DEUTSCH, MULVANEY & CARPENTER, LLP MELISSA MENDEZ MILES GUO MILES GWOK MOA-FU NEW DYNAMIC DEVELOPMENT LIMITED NEW FEDERAL STATE OF CHINA NEW TREASURE LLC NEXT TYCOON INVESTMENTS LIMITED NOBLE FAME GLOBAL LIMITED NOVELTY HILL LTD. O'MELVENY & MYERS LLP O'NEAL WEBSTER OGIER PACIFIC ALLIANCE ASIA OPPORTUNITY FUND L.P. PAUL WEISS PETRILLO KLEIN & BOXER LLP PHILLIPS NIZER LLP PHOENIX CREW IC LIMITED PULLMAN & COMLEY, LLC QIQHUA FAN QU GUOJIAO QUIJU JIA RANDAZZA LEGAL GROUP, PLLC ROBINSON & COLE LLP RONG ZHANG ROSS HEINEMEYER ROY D. SIMON RUIZHENG AN RULE OF LAW FOUNDATION III RULE OF LAW SOCIETY IV INC RUQUIN WANG

SAIL VICTORY LIMITED SAMUEL DAN NUNBERG SARA WEI (A/K/A LIHONG WEI LAFRENZ) SARACA MEDIA GROUP, INC., SCHULMAN BHATTACHARYA, LLC SELAS MONTBRIAL AVOCATS SEVEN MISSION GROUP LLC SHANE D SHOOK SHERRY-NETHERLAND, INC. SHI JIA ZHUANG ZHEN YUAN JIAN ZHU AN ZHUANG GONG CHENG LTD BEJING FIRST SHINY ACE INNOVATION CO LTD SHINY ACE LIMITED SHINY TIMES LTD. SHUANG WANG SPIRIT CHARTER INVESTMENT LIMITED STANDARD CHARTERED BANK STEPHEN WONG STEVE BANNON, STEVENSON WONG STOKES LAWRENCE, PS STRATEGIC VISION LLC TELI CHEN THE CASPER FIRM THE FRANCIS FIRM PLLC THE LAW OFFICES OF RAFAEL A. VARGAS THE SHERRY-NETHERLAND HOTEL THOMAS RAGLAND THREE TREASURE LLC TM PRIMROSE LIMITED TROUTMAN PEPPER HAMILTON SANDERS LLP TROY LAW PLLC U.S. LEGAL SUPPORT, INC. UBS AG (LONDON BRANCH) UBS AG (LONDON) UK HIMALAYA LTD. UNA MANYEE WILKINSON US HIMALAYA LTD. VERDOLINO & LOWEY VERITEXT VOICE OF GUO MEDIA, INC. VX CERDA & ASSOCIATES WA&HF LLC WARD & BERRY, PLLC WEICAN ("WATSON") MENG WEIGUO SUN WEIXIANG GE WELL ORIGIN LTD. WEN LIN WENG WHITECROFT SHORE LIMITED WHITMAN BREED ABBOTT & MORGAN LLC WILLIAM BRADLEY WENDEL WILLIAM GERTZ WILLIAM JE (JE KIN MING)

WILLIAMS & CONNOLLY WORLD CENTURY LIMITED, WORLDWIDE OPPORTUNITY HOLDINGS LIMITED WU ZHENG XIAO YAN ZHU XIAODAN WANG XINGYU YAN XIQUI ("BOB") FU YA LI YACHTZOO SARL YAN GAO YAN HUANG YANG LAN YANKWITT LLP YANPING WANG YAZ QINGUA YELIANG XIA YI LI YING LIU YUE HUA ZHU SHI YUNXIA WU YVETTE WANG ZEICHNER ELLMAN & KRAUSE LLP ZEISLER & ZEISLER, P.C. ZHANG WEI ZHENG WU (A/K/A BRUNO WA) ZHENGJUN DONG ZIBA LIMITED

Case 22-50073 Doc 2025 Filed 07/21/23 Entered 07/21/23 13:07:59 Page 28 of 30

# **SCHEDULE 2**

**Client Match List**

**None.**

Case 22-50073 Doc 2025 Filed 07/21/23 Entered 07/21/23 13:07:59 Page 29 of 30

# **EXHIBIT C**

**Bohonnon's bill**

# BOHONNON LAW FIRM, LLC

c/o Judy McGuinness 15 Merrill Road Clinton, CT 06413 (203)787-2151 FAX: (203)773-1427 [BOHONNON.COM](htt)

2023 Attn: Alex Bongartz Statement No. 1 200 Park Avenue Account No.

Paul Hastings LLP Statement Date: July 3,

99974.00

RE: Sale of Vessel FOR PROFESSIONAL SERVICES RENDERED

| | | | Rate | HOURS | | |------------|-----|----------------------------------------------------------------------------------------------------------------------------------------------------------------------------|--------|-------|------------| | 06/14/2023 | DMB | Telecon and email client. Review P&S and Amendment. | 650.00 | 1.15 | 747.50 | | 06/15/2023 | SC | Discuss with DMB specific docs/issues with Purchase & Sale | | | | | | | Agreement | 595.00 | 0.40 | 238.00 | | | DMB | Review Buyer diligence requests, telecon counsel. | 650.00 | 1.55 | 1,007.50 | | 06/21/2023 | DMB | Review Crew Release, Bills of Sale and Captain;'s Statement. | | | | | | | Draft Delivery POA. Telecon and email client. | 650.00 | 0.95 | 617.50 | | 06/28/2023 | DMB | Review Buyer Closing documents (POA Delivery and<br>Acceptance and Closing, and Buyer corporate acquisition<br>resolution). Draft Seller POA Closing and Delivery. Telecon | | | | | | | counsel regarding terms of delivery, exit FTZ. Email. | 650.00 | 1.15 | 747.50 | | | SC | Discuss closing/delivery protocol and particulars | 595.00 | 0.25 | 148.75 | | 06/30/2023 | DMB | Zoom Closing. | 650.00 | 0.50 | 325.00 | | | | FOR CURRENT SERVICES RENDERED | | 5.95 | 3,831.75 | | | | TOTAL CURRENT WORK | | | 3,831.75 | | | | BALANCE DUE | | | \$3,831.75 |

Federal ID # 06-1443106