Guo Wengui / Miles Guo — bankruptcy case · ECF #2051

UNITED STATES BANKRUPTCY COURT DISTRICT OF CONNECTICUT BRIDGEPORT DIVISION

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HO WAN KWOK, et al., : Case No. 22-50073 (JAM)

SECOND INTERIM FEE APPLICATION COVER SHEET

Interim Application of: Paul Hastings LLP

Bankruptcy Petition Filed: February 15, 2022 (main chapter 11 case) Date of Entry of Retention Orders: August 2, 2022 [Docket No. 668] (effective as of July 8, 2022, as to Individual Debtor) and January 24, 2023 [Docket No. 1376] (effective as of October 11, 2022, as to Genever (BVI) and effective as of

Fees: \$8,037,720.002 Voluntary Fee Reductions: \$138,542.25 Expenses: \$213,914.83 Voluntary Expense Reductions: \$2,395.80

Fees Previously Requested: Retainer Request:

Expenses Previously Requested: Expense Detail: Requested Expenses: \$412,445.29 Retainer Received: Not applicable Awarded Expenses: \$412,445.29 Copies per page cost and total: \$0.08 b/w (per page) Paid Expenses: \$412,445.29 \$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).

2 While this Application seeks allowance of \$8,037,720.00 in fees incurred during the Fee Period (net of a \$20,096.25 credit, as further detailed below), Paul Hastings has agreed with the U.S. Trustee and the Committee that it would only request, at this time, payment of 80% of its fees, with a 20% holdback.

Expenses Fees Awarded and Paid;

Expense Reimbursement Application for the Period from July 8, 2022 through October 31, 20223

Docket No.

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

Special Fee Application (Sanctions) for Services Rendered in Securing Compliance with Court-Authorized Subpoenas4

Docket No.

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

Paid:

for the Period from July 8, 2022 through February 28, 2023

Docket No.

2/28/23 \$12,326,802.00 \$348,813.54 Awarded:

Paid:

Paid:

Total \$12,410,172.26 \$412,445.29 Awarded:

Paid:

Paid:

3 The First Interim Fee Application excluded the expense reimbursements requested in the Expense Reimbursement Application.

4 The First Interim Fee Application included the amounts sought in the Special Fee Application (for the period through February 28, 2023) and, in addition, this Application also includes the amounts sought in the Special Fee Application (for the period from March 1, 2023 through March 10, 2023). Paul Hastings has included these amounts 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. HOURS AND RATES PER PROFESSIONAL AND PARAPROFESSIONAL

Bassett, Nicholas Corporate, 2007 \$1,625.00 514.50 \$836,062.50 1 Bassett, Nicholas (travel; ½ rate) Corporate, 2007 \$812.50 6.70 \$5,443.75 1 Despins, Luc Restructuring, 1986 \$1,860.00 513.20 \$954,552.00 N/A Despins, Luc (travel; ½ rate) Restructuring, 1986 \$930.00 10.30 \$9,579.00 N/A

Bongartz, Alex Restructuring, 2007 \$1,625.00 531.40 \$863,525.00 1 Bongartz, Alex (travel; ½ rate) Restructuring, 2007 \$812.50 11.60 \$9,425.00 1 Luft, Avi Corporate, 2000 \$1,625.00 783.80 \$1,273,675.00 1 Luft, Avi (travel; ½ rate) Corporate, 2000 \$812.50 15.50 \$12,593.75 1 Shelley, Scott Corporate, 1994 \$1,525.00 14.60 \$22,265.00 N/A Traxler, Katherine Restructuring, 1990 \$1,025.00 23.90 \$24,497.50 1 Of Counsel Total: 1,380.80 \$2,205,981.25

Barron, Douglass Corporate, 2012 \$1,320.00 764.30 \$1,008,876.00 1 Barron, Douglass (travel; ½ rate) Corporate, 2012 \$660.00 3.90 \$2,574.00 1 Catalano, Kristin Corporate, 2021 \$915.00 450.40 \$412,116.00 1 Daly, Crispin Corporate, 2010 \$1,320.00 30.20 \$39,864.00 1 Farmer, Will Corporate, 2018 \$1,235.00 418.00 \$516,230.00 1 Ganapathi, Anuva Litigation, 2021 \$915.00 66.90 \$61,213.50 1 Gilberg, Ben Litigation, 2022 \$915.00 10.60 \$9,699.00 N/A Hibbard, Jack Corporate, 2022 \$855.00 14.70 \$12,568.50 N/A Kosciewicz, Jon Litigation, 2021 \$915.00 419.00 \$383,385.00 1 Maza, Shlomo Corporate, 2012 \$1,320.00 222.70 \$293,964.00 1 Miliotes, Lanie Corporate, 2023 \$855.00 38.50 \$32,917.50 1 Nowak, Tanja Corporate \$620.00 12.60 \$7,812.00 N/A Sadler, Tess Corporate, 2019 \$1,175.00 48.80 \$57,340.00 1

[redacted] Corporate, 2023 \$815.00 273.90 \$223,228.50 1 [redacted] (travel; ½ rate) Corporate, 2023 \$407.50 3.50 \$1,426.25 1 Sutton, Ezra Corporate, 2021 \$1,015.00 608.20 \$617,323.00 1 [redacted] Corporate, 2022 \$915.00 25.70 \$23,515.50 1 Zhuang, Delphine Corporate, 2016 \$1,125.00 13.80 \$15,525.00 N/A

Elliott, Elizabeth Legal Research Analyst \$400.00 10.60 \$4,240.00 1

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.

Kuo, Jocelyn Paralegal \$540.00 293.40 \$158,436.00 N/A Mohamed, David Paralegal \$540.00 302.10 \$163,134.00 1 Mohamed, David (travel, ½ rate) Paralegal \$270.00 3.00 \$810.00 1 Paraprofessional Total: 609.10 \$326,620.00

TOTAL (net of \$20,096.25 credit):2 \$8,037,720.00

2 Due to an inadvertent oversight, the monthly fee statements for January and February 2023 (which were covered in the prior fee application) did not reflect the voluntary reduction in the hourly rate of the Trustee (from \$1,975 to \$1,860 per hour), resulting in an overstatement of Paul Hastings' fees by \$20,096.25 with respect to these two months. This amount has been credited in this Application against the fees incurred during the Fee Period. UNITED STATES BANKRUPTCY COURT DISTRICT OF CONNECTICUT BRIDGEPORT DIVISION

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In re: : :

HO WAN KWOK, et al., : :

Debtors.1 : :

-------------------------------------------------------------- x SECOND INTERIM FEE APPLICATION OF PAUL HASTINGS LLP FOR COMPENSATION AND REIMBURSEMENT OF EXPENSES FOR PERIOD FROM MARCH 1, 2023 THROUGH JUNE 30, 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 *Second Interim Fee Application of Paul Hastings LLP for Compensation and Reimbursement of Expenses for the Period from March 1, 2023 through June 30, 2023* (the "Application"). By this

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).

Application, Paul Hastings requests allowance and payment2 of the compensation for professional services performed by Paul Hastings attorneys (including the Trustee3 ) and reimbursement of its actual and necessary expenses incurred during the period from March 1, 2023 through and including June 30, 2023 (the "Fee Period"). In support of this Application, Paul Hastings respectfully states as follows:

1. 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 and his corporate "shell game" to shield companies and assets under his ownership and/or control from his creditors. Given the vast network 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. For example, 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, (d) interviewing former employees and business associates of the Individual Debtor (including several communications with confidential informants), (e) researching property records, and (f) pursuing litigation to recover property of the estate.

2 While this Application seeks allowance of all fees incurred during the Fee Period, as per Paul Hastings' agreement with the U.S. Trustee and the Committee, Paul Hastings is only requesting, at this time, payment of 80% of the fees incurred, with a 20% holdback.

3 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.

2. This work has obviously continued, at full force, during the Fee Period. Notably, during the Fee Period, the Trustee continued to prosecute his counterclaims against HK International Funds Investments (USA) Limited, LLC ("HK USA") and the Individual Debtor's daughter (i.e., Mei Guo) as to the ownership of the Lady May, the Lady May II, and other assets purportedly owned by HK USA, including \$33 million held in escrow pursuant to a stipulated order concerning the Lady May. Given the vigorous opposition of HK USA and Mei Guo to the relief sought by the Trustee, Paul Hastings and the Trustee necessarily expended significant time and resources on this litigation, including as it relates to the March 15, 2023 hearing on the Trustee's motions for a preliminary injunction and prejudgment remedies (which the Court granted, with the consent of HK USA and Mei Guo) as well as the March 27, 2023 and April 20, 2023 hearings on the Trustee's summary judgment motions (which motions the Court granted over the objection of HK USA and Mei Guo).

3. After the Court's ruling that the Trustee is the owner of the Lady May, the Trustee was able, with the assistance of Paul Hastings, to successfully sell the Lady May on June 30, 2023, for a purchase price of \$23.15 million.4 Unfortunately, this has not ended the litigation with HK USA because it has refused to instruct U.S. Bank National Association, as escrow agent ("U.S. Bank"), to turn over the \$33 million in escrow funds to the Trustee, notwithstanding this Court's clear direction that HK USA must turn over such property to the Trustee. HK USA's refusal resulted in U.S. Bank commencing an interpleader action to resolve the release of the escrow funds. The Trustee has moved for summary judgment in such action.5

4 The Trustee is in the initial stages of marketing and selling the Lady May II.

5 The Court has not yet issued a ruling on the Trustee's summary judgment motion.

4. In addition, during the Fee Period, as part of the Trustee's continuing efforts to

recover assets for the benefit of this estate, the Trustee commenced, with the assistance of Paul

Hastings, the following adversary proceedings:

- An adversary proceeding against Greenwich Land LLC ("Greenwich Land") and the Individual Debtor's alleged wife (i.e., Hing Chi Ngok), seeking determinations that, among other things, (a) Greenwich Land (which holds legal title to the Individual Debtor's residence in Greenwich, Connecticut) is an alter ego of the Debtor and (b) the Debtor is the equitable owner of Greenwich Land. - An adversary proceeding against Mei Guo, seeking determinations that, among other things, (a) the proceeds, likely in an amount of over \$10 million, from the sale of the Individual Debtor's private Bombardier jet are property of the estate and (b) a series of BVI registered shell companies purportedly held by Mei Guo are property of the Individual Debtor's chapter 11 estate; - An adversary proceeding against HCHK Technologies, Inc. ("HCHK Technologies"), HCHK Property Management, Inc. ("HCHK Property"), Lexington Property and Staffing, Inc. ("Lexington Property," and, together with HCHK Technologies and HCHK Property, the "HCHK Entities"), Brian Hofmeister, in his capacity as assignee of the HCHK Entities (the "Assignee"), and certain other parties, seeking determinations that, among other things, (a) the HCHK Entities are alter egos of the Individual Debtor and (b) the Individual Debtor is the equitable owner of the HCHK Entities and/or their assets; and - An adversary proceeding against Scott Barnett (the Individual Debtor's driver and/or bodyguard), Taurus Fund, LLC, and Taurus Management LLC, seeking determinations that, among other things, (a) the Individual Debtor is the equitable owner of a 50,000 square foot, castle-styled private residence with 12.5-acre grounds located at 675 Ramapo Valley Road, Mahwah, New Jersey 07430 (the "Mahwah Mansion"), (b) the Debtor is the equitable owner of Taurus Fund, LLC (the entity holding title to the Mahwah Mansion), and (c) that Taurus Fund is an alter ego of the Individual Debtor.

As illustrated in Exhibit D hereto (detailing Paul Hastings' fees for each adversary proceeding),

the fees incurred on these recent adversary proceedings are substantially less than the fees

incurred in the HK USA adversary proceeding [Adv. Proc. No. 22-05003]. While it may have

been time-consuming to obtain—over the vigorous opposition of the Individual Debtor and his

related entities and associates—rulings in the HK USA adversary proceeding as to the nature of the Individual Debtor's corporate shell game, including alter ego findings, the Trustee and Paul Hastings can now utilize these rulings (as well as the substantial legal and investigatory work that went into obtaining these rulings) to prosecute other adversary proceedings involving different Kwok-related entities (but similar legal and factual issues) at a much lower cost to the estate. This "knowledge leveraging" factor is reflected, for example, in the fees billed during the Fee Period with respect to the HCHK adversary proceeding.

5. At the same time, during the Fee Period, the Trustee has continued to press forward with the already pending adversary proceedings, including the litigation 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). The Trustee and the Genever Debtors ultimately reached a settlement with Bravo Luck, which resolves the Bravo Luck adversary proceeding in its entirety. On August 4, 2023, the Trustee and the Genever Debtors filed their motion (the "Bravo Luck 9019 Motion") seeking approval of that settlement, pursuant to which, among other things, Bravo Luck and Qiang Guo relinquish any right, title, or interest in the Sherry Netherland Apartment. This result obviously speaks for itself.

6. Furthermore, during the Fee Period, the fire that occurred on March 15, 2023 at the Sherry Netherland Apartment required the Trustee's attention. Of particular note, on April 25, 2023, AIG Property Casualty Company ("AIG") purported to cancel its insurance policies with respect to the Sherry Netherland Apartment (the "AIG Policies"). In response, on May 15, 2023, Genever (US) commenced an adversary proceeding against AIG Property Casualty Case 22-50073 Doc 2051 Filed 08/04/23 Entered 08/04/23 18:53:56 Page 10 of 906

Company ("AIG") seeking, among other things, (a) an injunction prohibiting AIG from cancelling the AIG Policies and (b) declarations that AIG must provide coverage for first and third party losses resulting from the March 15, 2023 fire at the Sherry Netherland Apartment and may not cancel the AIG Policies during the 2023-2024 policy term.6 Shortly after commencing this adversary proceeding, Genever (US) also sought a preliminary injunction against AIG cancelling the AIG Policies, which injunction the Court granted by order dated July 13, 2023.

7. All the while, during the Fee Period, the Trustee and Paul Hastings provided a wide range of other chapter 11 related services, including, for example, handling more than twenty hearings and status conferences during the Fee Period, preparing and prosecuting numerous substantive motions (including motions related to the operation and maintenance of the Lady May and the Lady May II), and preparing monthly operating reports.

8. While the Trustee has made substantial headway in these chapter 11 cases, progress continues to be 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. This is perhaps most obvious in the Trustee's Rule 2004 investigation, where the Individual Debtor sought to avoid compliance with the Trustee's pending Rule 2004 subpoenas by invoking his Fifth Amendment right against self-incrimination in an impermissible manner, spawning several months of motion practice and hearings, which resulted in the Court's July 26, 2023 order holding the Individual Debtor in contempt of court. Other discovery targets related to the Individual Debtor also failed to comply with the Trustee's Rule 2004 subpoenas, necessitating substantial motion practice, including with respect to Golden Spring (New York) Ltd. ("Golden Spring"), Lamp Capital LLC ("Lamp Capital"), G-Club Operations LLC ("G-Club

6 For the avoidance of doubt, Paul Hastings did not represent Genever (US) in the AIG Adversary Proceeding. Case 22-50073 Doc 2051 Filed 08/04/23 Entered 08/04/23 18:53:56 Page 11 of 906

Operations"), and Hudson Diamond NY LLC and Hudson Diamond Holding LLC (together with Hudson Diamond NY LLC, the "Hudson Entities").

9. 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 and his associates), the Trustee necessarily expended substantial time and resources on these matters, including because the Individual Debtor and his associates actively opposed the relief sought by the Trustee. Although it is extremely difficult to determine with precision the cost of the Individual Debtors' tactics, the Trustee continues to believe that at least 50% of the fees generated during the Fee Period were the result of the Individual Debtor's or his affiliates' continuing noncompliance with the Bankruptcy Code and/or active opposition or interference with the Trustee's administration of these chapter 11 cases.

10. 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 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).

11. 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 Case 22-50073 Doc 2051 Filed 08/04/23 Entered 08/04/23 18:53:56 Page 12 of 906

held during the Fee Period (and in some 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 Pacific Alliance Asia Opportunity Fund L.P. ("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.

12. 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 of thirty (30) timekeepers who billed less than ten (10) hours during the Fee Period in the aggregate amount of \$78,932.00. 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.

13. 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 Case 22-50073 Doc 2051 Filed 08/04/23 Entered 08/04/23 18:53:56 Page 13 of 906

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

14. 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.

15. The legal predicates for the relief requested herein are sections 328, 330, and 331 of the Bankruptcy Code, Bankruptcy Rule 2016, and Local Rule 2016-1.7

16. 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. Trustee Guidelines").8 Paul Hastings respectfully requests a waiver of any of the foregoing requirements not met by this Application.

17. 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.

7 On July 13, 2023, the Trustee and the Genever Debtors filed their motion to establish procedures for interim compensation and reimbursement of expenses for professionals retained in these chapter 11 cases [Docket No. 2022]. The Court has not yet ruled on that motion.

8 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.

- 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 a summary of the compensation requested by Matter ID. - Exhibit E contains the expense reimbursements requested by category. - Exhibit F contains the monthly statements of Paul Hastings detailing the services performed and itemizing the expenses incurred during the Fee Period. - Exhibit G contains the Proposed Order.

18. 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.

19. 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.

20. 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 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.

21. 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] Case 22-50073 Doc 2051 Filed 08/04/23 Entered 08/04/23 18:53:56 Page 15 of 906

(together with the retention order with respect to the Genever Debtors [Docket No. 1376], 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.9 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.

22. 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.

23. At this time, the amount of cash in the Trustee's account is approximately \$83.7 million.10 The Trustee is not aware of any material administrative expense claims other than claims for professional fees and expenses.

9 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.")

10 This amount includes (a) approximately \$32.9 million in funds held by the Trustee pursuant to the interpleader order, dated June 28, 2023 [Docket No. 40 in Adv. Proc. No. 23-05012], as if deemed deposited by US Bank National Association with the Registry of the Court, and (b) approximately \$38.8 million in funds received and held by the Trustee pursuant to the settlement with the Assignee in the HCHK Adversary Proceeding (as defined below).

24. On October 11, 2022, 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.

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

26. 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].

27. 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].

28. 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").

29. 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.

30. 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]. Case 22-50073 Doc 2051 Filed 08/04/23 Entered 08/04/23 18:53:56 Page 17 of 906

31. 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].

32. By this Application, the Trustee and Paul Hastings request allowance of fees (in the amount of \$8,037,720.00) and expenses incurred (in the amount of \$213,914.83) for services rendered by, for, and on behalf of the Trustee during the Fee Period.11 The Trustee has approved the amounts requested by Paul Hastings herein.

33. While this Application seeks allowance of all fees incurred during the Fee Period, Paul Hastings has agreed with the U.S. Trustee and the Committee to only seek payment of 80% of the fees incurred during the Fee Period, with a 20% holdback to be withheld by the Debtors' estates pending further order of the Court.

34. To date, the Trustee and Paul Hastings have submitted three 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 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").

11 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 of thirty (30) timekeepers who billed less than ten (10) hours during the Fee Period in the aggregate amount of \$78,932.00. 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.

The Individual Debtor's estate paid the foregoing amount on May 8, 2023.

- (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 HK Parties Contempt Order.12 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 "HK Parties Sanctions Order"). As of the filing of this Application, the HK Parties have not remitted payment. - (c) On May 30, 2023, Paul Hastings submitted the *Interim Fee Application of Paul Hastings LLP for Compensation and Reimbursement of Expenses for the Period from July 8, 2022 through February 28, 2023* [Docket No. 1831] (the "First Interim Fee Application") seeking \$12,326,802.00 in fees and \$348,813.54 for reimbursement of expenses. The First Interim Fee Application excluded the expense reimbursements approved in the Expense Reimbursement Order. The First Interim Fee Application included the amount requested in the Special Fee Application (for the period through February 28, 2023). However, to the extent the Trustee is able to recover the fees under the HK Parties Sanctions Order from the HK Parties, Paul Hastings will not seek payment of such fees from these estates.13 Pursuant to agreement with the U.S. Trustee, Paul Hastings reduced its fee request by \$550,000. On June 29, 2023, the Court approved the First Interim Fee Application [Docket No. 1964] with such reduction. Paul Hastings has received payment of \$11,776,802.00 in fees and \$348,813.54 in expenses in connection with the First Interim Fee Application.

12 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.

13 At this time, the HK Parties have not paid the amounts due under the HK Parties Sanctions Order (even though such amounts were due on May 5, 2023). Indeed, the HK Parties have (unsuccessfully) sought reconsideration of the HK Parties Sanctions Order [Docket Nos. 1730 and 1733] and, thereafter, appealed both the HK Parties 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]. That said, the Trustee agreed not to seek to enforce the Sanctions Order pending the District Court's decision on the appeal. Case 22-50073 Doc 2051 Filed 08/04/23 Entered 08/04/23 18:53:56 Page 19 of 906

35. Neither the Trustee nor Paul Hastings has received any payment or promise of payment from any source for services rendered during the Fee Period. 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.

36. Paul Hastings' professional services during the Fee Period required an aggregate expenditure of 6,460.30 recorded hours by attorneys and paraprofessionals, broken down as follows: partners (1,044.70 hours), of counsel (1,380.80 hours), associates (3,425.70 hours), and paraprofessionals (609.10 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.

37. 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,14 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 F are true and correct copies of the monthly statements of Paul Hastings related to the fees requested herein.

38. 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

14 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 2051 Filed 08/04/23 Entered 08/04/23 18:53:56 Page 20 of 906

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.

39. Paul Hastings respectfully submits that the reasonable value of the services rendered by Paul Hastings (including the Trustee) during the Fee Period is \$8,037,720.00.15 As noted, per Paul Hastings' agreement with the U.S. Trustee and the Committee, Paul Hastings is only seeking, at this time, payment of 80% of that amount, i.e., \$6,430,176.00.

40. 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.16

41. For ease of reference and transparency purposes, and at the request of the U.S. Trustee, Paul Hastings created the following separate Matter IDs for services in these chapter 11

15 This amount is net of a credit of \$20,096.25 on account of fees inadvertently charged in the monthly fee statements for January and February 2023.

16 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.

cases, including separate Matter IDs for the major adversary proceedings pending in these chapter 11 cases.17

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

42. 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 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:

17 These new Matter IDs (i.e., 00012 through 00022) were established effective as of March 1, 2023.

18 Not included as part of this Application.

- Assisting with filings and service of pleadings in the main chapter 11 case and related adversary proceedings; - Preparing supplemental motions 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; - Preparing the motion for summary judgment in the interpleader action commenced by U.S. Bank; - Assisting the Trustee on matters on which Paul Hastings is conflicted; - Preparing certain 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: \$159,436.50 Total Hours: 158.10 - 43. 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), (d)

handling numerous calls and correspondence with the U.S. Trustee and PAX regarding the

background to, and the administration of, these chapter 11 cases, and (e) holding internal team

meetings and calls to coordinate work streams. Case 22-50073 Doc 2051 Filed 08/04/23 Entered 08/04/23 18:53:56 Page 23 of 906 B. Pleadings Review (Task Code B113) Fees: \$74,357.00 Total Hours: 133.50

44. 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: \$45,339.50 Total Hours: 27.40

45. During the Fee Period, Paul Hastings attorneys prepared for and attended numerous hearings and status conferences. As detailed below, most of the hearings were recorded under the applicable Matter ID. Hearings recorded under matter number 00001 included the March 21, 2023 status conference and the June 29, 2023 hearing on, among other things, Paul Hastings' First Interim Fee Application. D. Fee / Employment Applications for Paul Hastings (Task Code B160) Fees: \$209,583.00 Total Hours: 149.50

46. During the Fee Period, in connection with Paul Hastings' retention, Paul Hastings attorneys prepared two supplemental declarations with respect to the Trustee's and Paul Hastings' disinterestedness [Docket Nos. 1581 and 1710] 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 (a) the Special Fee Application [Docket No. 1648] (which the Court granted on April 21, 2023 [Docket No. 1693]), (b) the First Interim Fee Application [Docket No. 1831] (which the Court granted on June 29, 2023 [Docket No. 1964]), (c) Paul Hastings' monthly fee statements for services rendered from October 2022 through May 2023, and (d) portions of this Application. Paul Hastings also corresponded and engaged in discussions with the U.S. Trustee to address questions regarding the above fee and expense reimbursement requests. Among other Case 22-50073 Doc 2051 Filed 08/04/23 Entered 08/04/23 18:53:56 Page 24 of 906

things, Paul Hastings consensually resolved the U.S. Trustee's informal comments to the First Interim Fee Application.

E. Fee / Employment Applications for Other Professionals (Task Code B165) Fees: \$65,536.50 Total Hours: 48.90

47. During the Fee Period, Paul Hastings attorneys assisted Pallas Partners LLP ("Pallas") with the preparation of its application to be retained as U.K. solicitors to the Trustee in connection with the UBS Litigation (as defined below) [Docket No. 1596]. Paul Hastings attorneys also prepared retention applications of various other estate professionals, including (a) the application to retain Edmiston and Company, as yacht broker [Docket No. 1717], to market and sell the Lady May and the Lady May II and (b) the application to expand the scope of Engineering Operations and Certification Services, LLC ("EOCS") to provide services in connection with the transition of ownership of the Lady May to the Trustee [Docket No. 1669]. Both applications were granted by the Court [Docket Nos. 1717 and 1748].

48. In addition, during the Fee Period, Paul Hastings attorneys handled various other retention-related issues, including (a) assisting NPM with its first interim fee application, (b) assisting Epiq with its first interim fee application, and (c) assisting Harney Westwood and Riegels LP ("Harney Legal") with its supplemental disclosures of connections to parties in interest.

F. Non-Working Travel (Task Code B195) [billed at ½ rate] Fees: \$6,631.25 Total Hours: 7.80

49. During the Fee Period, Paul Hastings attorneys travelled to and from the bankruptcy courthouse in Bridgeport, Connecticut, to attend hearings in these chapter 11 cases. Case 22-50073 Doc 2051 Filed 08/04/23 Entered 08/04/23 18:53:56 Page 25 of 906 G. Financial Reports (Monthly Operating Reports) (Task Code B211) Fees: \$14,925.00 Total Hours: 13.30

50. 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 00010 (for Genever (US)) and 00011 (for Genever (BVI)).

H. Financing/Cash Collections (Task Code B230) Fees: \$43,217.50 Total Hours: 41.90

51. During the Fee Period, Paul Hastings attorneys analyze the cash needs to fund these chapter 11 cases, including the possibility of interdebtor DIP financing to be provided by the Individual Debtor's estate to the Genever Debtors. As will be detailed in the DIP financing motion (to be filed in the near future), the Genever Debtors are in a precarious position in their chapter 11 cases. The current condition of the Sherry Netherland Apartment is such that it is uncertain if, and when, Genever (US) will be able to rent or sell the property. And while Genever (US) believes it will prevail in its litigation against AIG regarding the insurance coverage with respect to the Sherry Netherland Apartment, the outcome of that litigation is also uncertain. At the same time, the Genever Debtors have no cash and no source of income. Without access to some source of liquidity, the Genever Debtors would not be able to make essential remediation repairs to the Sherry Netherland Apartment, pay current professional fees—including the costs of pursuing the AIG litigation—or even pay the statutory amounts to the U.S. Trustee, and would be forced to convert to a chapter 7 liquidation.

52. For these reasons, the Trustee determined, subject to approval of this Court, that the estate of the Individual Debtor would provide up to \$1,000,000 of critically necessary Case 22-50073 Doc 2051 Filed 08/04/23 Entered 08/04/23 18:53:56 Page 26 of 906

funding to the Genever Debtors so that they can fund their chapter 11 cases while they pursue a chapter 11 process—including pursuing the AIG litigation and a value-maximizing strategy for the sale of the Sherry Netherland Apartment.

- I. Claims Administration and Objections (Task Code B310) Fees: \$16,183.00 Total Hours: 13.60 - 53. During the Fee Period, Paul Hastings attorneys prepared and filed an omnibus

objection [Docket No. 1842] to the proofs claim filed by Bravo Luck. Bravo Luck's deadline to

respond to the claim objection has been extended several times—most recently, to August 4,

2023 [Docket No. 2039]. II. Asset Recovery Investigation and Litigation (Matter ID 00002)19

- A. Asset Analysis and Recovery (Task Code B120) Fees: \$52,856.50 Total Hours: 35.80 - 54. During the Fee Period, Paul Hastings attorneys continued to advise the Trustee on

numerous matters related to the Lady May, including:

analyzing issues related to HK USA's and Mei Guo's motion to modify the order, dated October 7, 2022, establishing a \$4 million reserve to fund the repairs of the Lady May [Docket No. 930] (the "Repair Reserve Order"), including resolving the U.S. Trustee's comments to the Trustee's motion to seal certain exhibits to his supplemental objection and preparing for the hearing on HK USA's and Mei Guo's motion;

19 As part of the consensual resolution of the U.S. Trustee's informal comments to Paul Hastings' First Interim Fee Application, Paul Hastings has agreed that, effective as of March 1, 2023 (i.e., the beginning of the Fee Period covered by this Application), time spent on the key adversary proceedings in these chapter 11 cases will be recorded under separate matter numbers, namely Matter IDs 00012 to 00022 (as opposed to Matter ID 00002). Only litigation work not related to a specific adversary proceedings continues to be recorded under Matter ID 00002, Task Code B191 (General Litigation). This change does not affect the other workstreams recorded under Matter ID 00002. In particular, as in the prior fee period, work related to the Trustee's Rule 2004 investigation is recorded under Matter ID 00002, Task Code B261 (Investigations), while 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, is recorded under Matter ID 00002, Task Code B120 (Asset Analysis and Recovery). Finally, as in the prior fee period, time spent by the Trustee on the UBS Litigation (as defined below)—another asset of the Individual Debtor's estate—is recorded under Matter ID 00002, Task Code B120 (Asset Analysis and Recovery).

- preparing the Trustee's motion to modify the Repair Reserve Order to allow for up to \$500,000 to be spent on funding operating expenses of the Lady May [Docket No. 1588], which motion was granted by order of the Court, dated March 28, 2023 [Docket No. 1608]; and - analyzing whether to conduct the service of the sea valves for the Lady May (with the Trustee ultimately determining not to proceed with such service, at the time). - 55. Furthermore, the Trustee continued to seek from the Individual Debtor's former

U.K. counsel, i.e., Harcus Parker, the release of their litigation file related to the UBS Litigation20 (such as memoranda analyzing the merits of the claims asserted by the Individual Debtor), so as to be able to analyze next steps with respect to the UBS Litigation. To be clear, although Paul Hastings had previously assisted the Trustee in obtaining recognition of this chapter 11 case in the U.K., Paul Hastings is 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: \$139,591.50 Total Hours: 95.80

56. During the Fee Period, Paul Hastings attorneys attended numerous hearings

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

- the March 7, 2023 hearing on, among other things, (a) various matters related to the Trustee's Rule 2004 investigation, (b) Genever (US)'s motion to market the Sherry Netherland Apartment for rent; and (c) the status conference in the Sherry Netherland Adversary Proceeding (as defined below); - the March 23, 2023 hearing on, among other things, (a) various matters related to the Trustee's Rule 2004 investigation, (b) follow-up regarding the orders granting the preliminary injunction and prejudgment remedies

20 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.

in the HK USA Adversary Proceeding (as defined below), and (c) the Trustee's application to retain Pallas as solicitors in the U.K.;

- the April 11, 2023 hearing on, among other things, (a) the Trustee's motion to enter into certain agreements related to the operation and maintenance of the Lady May and (b) HK USA's and Mei Guo's motion to dismiss certain of the Trustee's counterclaims in the HK USA Adversary Proceeding; - the April 18, 2023 hearing on, among other things, (a) various matters related to the Trustee's Rule 2004 investigation and (b) the pretrial conference in the Bravo Luck Adversary Proceeding (as defined below); - the April 27, 2023 hearing on, among other things, (a) the Trustee's motion to retain Edmiston as yacht broker for the Lady May and the Lady May II, (b) the Trustee's motion to relocate the Lady May to Newport, Rhode Island, and (c) certain matters related to the Trustee's Rule 2004 investigation; - the May 2, 2023 hearing on, among other things, (a) the Trustee's efforts to obtain documents seized by the U.S. Department of Justice in connection with their arrest of the Individual Debtor, discovery from the Individual Debtor, (b) Paul Hastings' and NPM's applications for reimbursement of expenses, and (c) the application to retain EOCS; - the May 4, 2023 hearing on the Trustee's motion to approve the settlement with Clark Hill PLC; - the May 10, 2023 hearing on, among other things, (a) the Trustee's motion to enter into certain agreements related to the operation and maintenance of the Lady May II, and (b) the Trustee's motion to transfer the Lady May into the foreign trade zone in Newport, Rhode Island; and - the June 6, 2023 hearing on, among other things, (a) various matters related to the Trustee's Rule 2004 investigation. - C. General Litigation (Task Code B191) Fees: \$72,749.50 Total Hours: 81.60

57. During the Fee Period, Paul Hastings attorneys worked on several litigation

matters not related to a specific adversary proceeding,21 including (i) holding several internal

calls to discuss general litigation strategy and next steps, (ii) maintaining a task list with respect

21 As noted, effective as of March 1, 2023, Paul Hastings has recorded time spent on the key adversary proceedings in these chapter 11 cases under separate matter numbers, as detailed below.

to pending adversary proceedings, (iii) maintaining a tracking chart with respect to the pending appeals in these cases, and (iv) generally reviewing and analyzing pleadings filed in adversary proceedings. D. Non-Working Travel (Task Code B195) [billed at ½ rate] Fees: \$ \$22,030.25 Total Hours: 28.90

58. During the Fee Period, Paul Hastings attorneys traveled to (a) the Federal Courthouse in Bridgeport, Connecticut for various hearings related to the Trustee's Rule 2004 investigation and the Lady May, (b) the New York offices of the U.S. Department of Justice (the "U.S. DOJ") for meetings with U.S. DOJ personnel, and (c) Washington, D.C., to conduct depositions in connection with the Trustee's Rule 2004 investigation.

E. Business Operations (Task Code B210) Fees: \$260,196.50 Total Hours: 184.80

59. During the Fee Period, Paul Hastings attorneys handled numerous matters related to the operation and maintenance of the Lady May and the Lady May II, including (a) ensuring a smooth transition of ownership of the Lady May and Lady May II from HK USA to the Trustee, (b) securing insurance coverage for the Lady May and Lady May II (as the certain of the prior insurance policies were set to expire at the end of March 2023, without the possibility of renewal), (c) obtaining a modification to the Repair Reserve Order so as to provide \$500,000 in funding for the operation and maintenance of the Lady May and Lady May II, (d) obtaining court authorization to enter into various agreements related to the operation and maintenance of the Lady May and the Lady May II, including a yacht management agreement with Yachtzoo Sarl ("Yachtzoo"), the yacht manager for the Lady May and Lady May II, and various dockage agreements, (e) coordinating with Yachtzoo regarding the maintenance and operation of the Lady May and the Lady May II, and (f) obtaining court authorization to transfer the Lady May Case 22-50073 Doc 2051 Filed 08/04/23 Entered 08/04/23 18:53:56 Page 30 of 906

into the foreign trade zone in Newport, Rhode Island. All of the foregoing was done in preparation for an eventual sale of the Lady May and the Lady May II. In fact, as the Court is aware, and as further detailed below in the discussion of services provided under Matter ID 00005 (Sale Process), the Trustee successfully sold the Lady May on June 30, 2023 for a purchase prices of \$23.15 million.

F. Tax Issues (Task Code B240) Fees: \$29,369.50 Total Hours: 26.50

60. During the Fee Period, Paul Hastings attorneys handle the Trustee's response to the subpoena issued by the Internal Revenue Service ("IRS") seeking information related to tax returns of Mr. Ho Wan Kwok and certain of his associated entities. In this regard, Paul Hastings attorneys conducted a document review to identify documents responsive to the IRS subpoena as well as prepared the document production and related cover letter to the IRS.

G. Investigations (Task Code B261) Fees: \$1,758,925.00 Total Hours: 1,501.70

61. During the Fee Period, Paul Hastings continued to handle the Trustee's extensive investigation to identify potential assets of the Individual Debtor's estate. Given the corporate maze of shell companies set up by the Individual Debtor, including hundreds of companies purportedly owned by his close family members, business associates, and employees, this investigation has necessarily been extensive and time intensive.

62. As part of this investigation, Paul Hastings attorneys (a) analyzed documents produced in response to Rule 2004 subpoenas,22 (b) engaged in meet and confer sessions with the targets of the Rule 2004 discovery, (c) identified additional entities for further investigation, (d)

22 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 2051 Filed 08/04/23 Entered 08/04/23 18:53:56 Page 31 of 906

coordinated with Harneys Legal regarding additional discovery in the BVI regarding certain BVI entities, and (e) analyzed potential claims against the Individual Debtor and his affiliated entities (including potential claims under RICO). Paul Hastings attorneys also continued to assist NPM in preparing supplemental motions under Bankruptcy Rule 2004 seeking discovery from various individuals and entities associated with the Individual Debtor, including the motions filed on March 24, 2023 [Docket No. 1592] and May 15, 2023 [Docket No. 1789], as well as two reply briefs filed on June 2, 2023 [Docket Nos. 1860 and 1862] in response to (a) the objection filed by the Individual Debtor, as it relates to discovery sought from Nodal Partners LLC (which itself didn't object to the requested relief) and (b) the objection filed by Greenwich Land and the Individual Debtor's purported wife, Hing Chi Ngok.23 The Court overruled these objections and granted the supplemental Rule 2004 motions by orders dated April 10, 2023 [Docket No. 1646] and June 7, 2023 [Docket No. 1891], respectively.

63. Furthermore, Paul Hastings attorneys prepared for and conducted an extensive interview with another confidential informant as well as spent substantial time interviewing this and other confidential informants, providing valuable insight into the Individual Debtor's business operations.24

64. Moreover, much of the Trustee's investigation also required the expertise of Paul Hastings' Mandarin-speaking 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,

23 These supplemental Rule 2004 motions were filed by NPM because Paul Hastings was conflicted as to some of the discovery targets. To the extent Paul Hastings did not have a conflict, it assisted NPM in preparing such supplemental motions.

24 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." Case 22-50073 Doc 2051 Filed 08/04/23 Entered 08/04/23 18:53:56 Page 32 of 906

which an outside translation service would not be able to provide. Paul Hastings' Mandarinspeaking 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.

65. To date, the Trustee's investigation (including as a result of discovery under Rule 2004, information provided by confidential informants, 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. In fact, as detailed further below, during the Fee Period, the Trustee commenced several adversary proceedings to recover such assets, including (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. 23-05008],25 and (b) an adversary proceeding seeking to recover the Individual Debtor's residence in Greenwich, Connecticut [Adv. Proc. No. 23-05005].

66. Moreover, during the Fee Period, Paul Hastings attorneys assisted the Trustee in securing a settlement with Clark Hill, PLC ("Clark Hill"), the Individual Debtor's former immigration counsel. Among other things, Paul Hastings prepared the motion seeking approval of that settlement [Docket No. 1724], which motion was granted by this Court on May 4, 2023 [Docket No. 1756]. Pursuant to the settlement, the Trustee agreed to settle malpractice claims asserted by the Individual Debtor against Clark Hill related to the Individual Debtor's asylum application, in exchange for Clark Hill paying \$499,000 to the Individual Debtor's estate.

25 Mei Guo's purported ownership of this private jet was uncovered as a result of the document productions from the BVI registered agents. Case 22-50073 Doc 2051 Filed 08/04/23 Entered 08/04/23 18:53:56 Page 33 of 906

67. Unfortunately, as the Court is well aware, the Trustee's investigation continued to face 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), necessitating significant motion practice to compel compliance (which compliance, to this day, remains forthcoming in many instances).

68. Perhaps most notably, the Individual Debtor sought to avoid compliance with the Trustee's pending Rule 2004 subpoenas by invoking his Fifth Amendment right against selfincrimination in an impermissible manner, spawning several months of motion practice and hearings. In particular:

- on February 10, 2023 (i.e., shortly before the Fee Period), the Trustee filed his motion seeking to hold the Individual Debtor in contempt [Docket No. 1453] (the "Contempt Motion") for failure to comply with the Court's January 20, 2023 order [Docket No. 1353] (the "January 20, 2023 Discovery Order") directing the Individual Debtor to comply with the Trustee's Rule 2004 subpoenas; - on April 10, 2023, the Individual Debtor filed his objection [Docket No. 1650] to the Contempt Motion, asserting that he complied with the January 20, 2023 Discovery Order by invoking his Fifth Amendment right against self-incrimination; - also on April 10, 2023, the Individual Debtor filed a motion [Docket No. 1649] ("Motion for Stay of Discovery") seeking to stay his obligation to comply with the January 20, 2023 Discovery Order, arguing, among other things, that he should not be compelled to comply with the Trustee's Rule 2004 subpoena pending resolution of the parallel criminal proceedings, purportedly to preserve the Individual Debtor's rights under the Fifth Amendment; - on April 14, 2023, the Trustee filed his reply in further support of the Contempt Motion [Docket No. 1670], arguing, among other things, that the pending criminal proceedings should not be used to delay progress in this case to the detriment of his creditors, and, in any event, the Individual Debtor has failed to adequately explain why producing documents in response to the January 20, 2023 Discovery Order would violate his Fifth Amendment rights; - on April 19, 2023, the Trustee filed his objection to the Motion for Stay of Discovery [Docket No. 1680], arguing, among other things, that the Individual Debtor cannot use the allegations of the criminal indictment to absolve himself of his past contempt, and, to the extent the Individual Debtor is using the indictment as a basis to assert the Fifth Amendment privilege on a prospective basis, this argument is flawed because the Individual Debtor cannot reap the benefits of the chapter 11 process while shielding himself from his statutory obligation under the Bankruptcy Code to turn over documents to the Trustee; - on May 1, 2023, the Court entered a consent order [Docket No. 1740] requiring the Individual Debtor to respond to each of the 202 questions posed by the Trustee in a particularized manner and by a sworn declaration; and - on May 24, 2023, the Individual Debtor provided his responses on May 24, 2023, and, as anticipated, asserted the Fifth Amendment in response to each of the questions posed by the Trustee.

69. During the months of May and June 2023, the Trustee and the Individual Debtor

also discussed a process by which the Trustee would have obtained documents produced by the prosecutors in the criminal action to the Individual Debtor. Unfortunately, the parties were not able to reach agreement in that regard, so that, after several hearings (including on April 20, 2023, May 2, 2023, and June 13, 2023), the Court issued an order on July 26, 2023 [Docket No. 2035] (the "Contempt Order") granting the Trustee's Contempt Motion and denying the Individual Debtor's Motion for Stay of Discovery, including because the Fifth Amendment right against self-incrimination does not apply to the specific facts and circumstances before the Court. While the Trustee ultimately prevailed on his Contempt Motion, the Trustee and Paul Hastings necessarily expended significant time and effort in seeking the Individual Debtor's compliance with the Trustee's Rule 2004 subpoenas.26

70. Other discovery targets related to the Individual Debtor also failed to comply with the Trustee's Rule 2004 subpoenas, necessitating substantial motion practice. For example, on

26 Under the Contempt Order, the Individual Debtor has until September 29, 2023 to purge himself of contempt by fully complying with the January 20, 2023 Discovery Order. Case 22-50073 Doc 2051 Filed 08/04/23 Entered 08/04/23 18:53:56 Page 35 of 906

October 28, 2023, the Trustee filed a motion to compel [Docket No. 1046] (the "First Motion to Compel") compliance with his Rule 2004 subpoenas, including as to Golden Spring (New York) Ltd. ("Golden Spring") and Lamp Capital LLC ("Lamp Capital"). Neither Golden Spring nor Lamp Capital responded to the Rule 2004 subpoenas or the First Motion to Compel, and, following a hearing on April 18, 2023, the Court entered an order [Docket No. 1709] holding Golden Spring and Lamp Capital in contempt of court for failing to respond or comply with the Trustee's Rule 2004 subpoenas and imposed sanctions (in the form of reasonable attorney's fees and costs) on Golden Spring and Lamp Capital.

71. Furthermore, on May 18, 2023, the Trustee filed his second motion [Docket No. 1805] (the "Second Motion to Compel") seeking entry of an order compelling certain Kwokrelated entities, including G-Club Operations and the Hudson Entities, to comply with the Court's Rule 2004 orders and the related Rule 2004 subpoenas. In this regard, Paul Hastings attorneys prepared and filed the Trustee's reply [Docket No. 1934] to the objection filed by G-Club Operations. After two hearings on June 6, 2023 and June 27, 2023 on the Second Motion to Compel, the Court entered an order on June 28, 2023, directing G-Club Operations to produce all documents responsive to the Rule 2004 subpoenas by July 14, 2023. Furthermore, on June 8, 2023, the Court entered a consent order with respect to the Second Motion to Compel as it relates to the Hudson Entities, pursuant to which the Court directed the Hudson Entities to complete their production to the Trustee by June 15, 2023. At the conclusion of the June 7, 2023 hearing, the Court took the Second Motion to Compel under advisement as it relates to the other Rule 2004 targets. On July 28, 2023, the Court issued a further order that, among other things, requires Mei Guo to testify on August 22, 2023 regarding Hudson Diamond Holding LLC's compliance with its discovery obligations.

72. Finally, Paul Hastings attorneys engaged in numerous other investigation-related

tasks, including the following:

- communicating with the U.S. DOJ regarding the Individual Debtor's criminal proceedings and the assets seized in connection with his arrest; - preparing the Trustee's response, dated March 7, 2023 [Docket No. 1517], to the declaration of Lee Vartan (counsel to HK USA and Mei Guo) addressing HK USA's and Mei Guo's purported compliance with this Court's order granting the Trustee's motion to compel compliance with the Trustee's Rule 2004 subpoenas; - Deposing (a) Valerie Steven and Mark Harmon of Hodgson Russ LLP, which was counsel to the Individual Debtor between 2018 and 2020, and (b) Jerry Shulman of Williams & Connolly LLP, which was counsel to the Individual Debtor in 2015; - Analyzing relationship between the Individual Debtor and hundreds of companies affiliated with the Individual Debtor; and - Researching property records. - H. Contempt Proceedings (Task Code B262) Fees: \$28,081.50 Total Hours: 20.00 - 73. On March 10, 2023, the Court entered the HK Parties Contempt Order [Docket

No. 1537] 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 with respect to fees incurred during the period from September 28, 2023 through March 10, 2023 (i.e., the date the Court entered the HK Parties Contempt Order). The Court granted the Special Fee Case 22-50073 Doc 2051 Filed 08/04/23 Entered 08/04/23 18:53:56 Page 37 of 906

Application by order dated April 23, 2023 [Docket No. 1693], i.e., the HK Parties Sanctions Order.27

74. Most of the fees covered by the Special Fee Application were incurred during the prior fee period (i.e., prior to March 1, 2023); however, a portion of those fees were incurred during the Fee Period (and, specifically, between March 1, 2023 and March 10, 2023). 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). During the Fee Period, the HK Parties have also (unsuccessfully) sought reconsideration of the HK Parties Sanctions Order [Docket Nos. 1730 and 1733] and, thereafter, appealed both the HK Parties 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]. That said, the Trustee agreed not to seek to enforce the Sanctions Order pending the District Court's decision on the appeal.

75. As detailed in the Special Fee Application, the time spent on seeking to compel HK USA and Ms. Guo to comply with the Trustee's subpoenas 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). Moreover, Paul Hastings has continued to track time spent on these matters after March 10, 2023 under Task Code B262.

27 To be clear, this Application includes the amount requested in the Special Fee Application (for the period from March 1, 2023 through March 10, 2023). However, to the extent Paul Hastings is able to collect such fees from the HK Parties, it will not seek payment of such fees from these estates. III. Other Litigation (Matter ID 00003)28

- A. Court Hearings (Task Code B155) Fees: \$9,634.50 Total Hours: 8.20 - 76. During the Fee Period, the Paul Hastings attorneys attended various hearings

related to the Individual Debtor's criminal proceedings, including:

- The March 15, 2023 hearing on the arrangement of the Individual Debtor in the United States District Court for the Southern District of New York; and - The April 4, 2023 bail hearings with respect to the Individual Debtor and Yvette Wang. - B. General Litigation (Task Code B191) Fees: \$60,704.00 Total Hours: 61.10

77. During the Fee Period, Paul Hastings attorneys assisted the Trustee on various

litigation-related matters (other than the adversary proceeding pending in these chapter 11 cases). First, as the Court is well aware, on March 15, 2023, the Individual Debtor and Yvette Wang were arrested by federal law enforcement authorities. Paul Hastings attorneys monitored these criminal proceedings and reviewed pleadings filed in these proceedings.

78. Second, in connection with these criminal proceedings, the Trustee received a document subpoena from the U.S. DOJ, requesting documents related to the Individual Debtor. In response to that subpoena, Paul Hastings conducted a review of the documents produced to the Trustee during his Rule 2004 investigation. Paul Hastings transmitted the Trustee's document production to the U.S. DOJ on April 24, 2023.

79. Third, on April 26, 2023, Jiaming Liu (who had previously been served with one of the Trustee's Rule 2004 subpoenas) commenced a lawsuit against the Trustee and Paul

28 As a general matter, time spent on litigation-related tasks other than adversary proceedings in these chapter 11 cases was tracked under Matter ID 00003. Case 22-50073 Doc 2051 Filed 08/04/23 Entered 08/04/23 18:53:56 Page 39 of 906

Hastings in the United States District Court for the District of Arizona seeking, among other things, declaratory relief, injunctive relief, and monetary damages as a result of the Trustee's alleged improper use of "the American legal system." In response, Paul Hastings attorneys sent a letter to Mr. Liu demanding that the complaint be dismissed, including on jurisdictional grounds because the lawsuit violated the Barton doctrine (i.e., a party must first obtain leave of the bankruptcy court before initiating an action in another forum against a bankruptcy trustee). On May 9, 2023, Mr. Liu voluntarily dismissed the complaint without prejudice. IV. Corporate Law Issues (Matter ID 00004)

A. Other Contested Matters (Task Code B190) Fees: \$85,419.00 Total Hours: 60.1

80. During the Fee Period, Paul Hastings attorneys continued to assist the Trustee on various matters related to the Trustee's motion [Docket No. 913] (the "Ace Decade Contempt 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"). As the Court will recall, on January 24, 2023, the Court entered an order [Docket No. 1372] (the "Ace Decade Contempt Order") 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 the nominee shareholder, Yvette Wang, to turn over her ownership interest to the Trustee.

81. 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. Instead, the Individual Debtor appealed the Ace Decade Contempt Order and (unsuccessfully) sought a stay of that order. Among other things,

Paul Hastings prepared the Trustee's objection to that stay request (and a supplemental statement in further support of his objection) as well as handled other matters related to the appeal, including the designation of the appellate record and analyzing the opening brief filed by the appellant. B. General Litigation (Task Code B191) Fees: \$31,587.50 Total Hours: 23.40

82. In May 2023, the Trustee discovered through his BVI-based investigation that, in January 2023 (i.e., while the Ace Decade Contempt Motion was sub judice), Yvette Wang transferred her shares in Ace Decade to an individual apparently residing in Switzerland, who also happens to be the brother of the person leading the Individual Debtor's G-Fashion brand. Upon learning of these developments, Paul Hastings attorneys and the Trustee analyzed various litigation strategies to challenge and undo this transfer. As of the time of the filing of the Application, the Trustee has not yet sought relief from this Court in this regard.

A. Asset Disposition (Task Code B130) Fees: \$385,262.00 Total Hours: 265.40

83. During the Fee Period, Paul Hastings attorneys and the Trustee, in close coordination with Edmiston, handled all aspects of the sale process for the Lady May, which, as the Court is aware, resulted in a successful sale of the Lady May for a purchase price of \$23.15 million. Among other things, Paul Hastings attorneys and the Trustee:

- Developed the bidding procedures and related timeline (including regular communications with Dirk Johnson of Edmiston regarding same); - Prepared the form of purchase agreement and addendum thereto; - Communicated with bidders regarding their bids; - Prepared the motion to approve the sale of the Lady May to the successful bidder (including the related motion to limit service thereof); - Prepared the Trustee's reply in further support of the sale motion and in response to the objection filed by HK USA; - Negotiated the purchase price reduction requested by the successful bidder (following the results of the survey of the Lady May); - Communicated with (a) counsel for the successful bidder, (b) the yacht manager for the Lady May (Yachtzoo), and (c) the Trustee's maritime counsel (David Bohonnon) regarding preparation for closing of the sale of the Lady May (which closing occurred on June 30, 2023); and - Updated counsel for PAX and counsel for the Committee throughout the sale process. - 84. In the end, as a result of the sale strategy developed by the Trustee and Paul

Hastings (in close coordination with Edmiston), the Trustee was able to sell the Lady May for a

purchase price substantially higher than the initial offers (none of which exceeded \$20 million),

thereby generating several millions of dollar in additional proceeds for the benefit of the estate.

- B. Court Hearings (Task Code B155) Fees: \$42,902.50 Total Hours: 28.80 - 85. During the Fee Period, Paul Hastings attorneys attended numerous hearings

related to the sale process of the Lady May, including:

- the May 23, 2023 status conference with respect to the sale process for the Lady May, including the bid deadline and related procedures; - the May 31, 2023 status conference with respect to the sale process for the Lady May, including the scheduling of the hearing on the motion to approve the sale of the Lady May; and - the June 27, 2023 hearing on, among other things, the Trustee's motion to authorize the sale of the Lady May.

A. Case Administration (Task Code B110) Fees: \$39,191.50 Total Hours: 22.20

86. During the Fee Period, Paul Hastings attorneys handled numerous administrative matters related to the chapter 11 case of Genever (US), much of which concerned the effects of the fire at the Apartment on March 15, 2023. For example, one of the first steps undertaken by the Trustee following the fire was to seek entry of an emergency order (and amendments thereto) restricting access to the Apartment. In addition, Paul Hastings attorneys have updated Claire Abrehart, i.e., the director of Genever (BVI) appointed by the Trustee, regarding the developments in the chapter 11 cases, as well as provided regular updates to the U.S. Trustee, counsel for the Sherry Netherland, and the public adjuster retained by Genever (US).

B. Sale of Real Estate (Task Code B131) Fees: \$22,193.00 Total Hours: 15.10

87. During the Fee Period, Paul Hastings attorneys continued to analyze numerous issues related to the sale process for the Sherry Netherland Apartment. However, following the March 15, 2023 fire, that process was necessarily put on hold in order to assess the damage to the Sherry Netherland Apartment and evaluate the sale strategy going forward. In this regard, Paul Hastings attorneys and the Trustee 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, regarding the sale process.

88. In addition, Paul Hastings attorneys also analyzed the co-op lease with respect to the Sherry Netherland Apartment. Among other things, as a result of this analysis, the Sherry Netherland agreed to a substantial abatement of the monthly maintenance charges (for the time being). Case 22-50073 Doc 2051 Filed 08/04/23 Entered 08/04/23 18:53:56 Page 43 of 906

89. Furthermore, on May 2, 2023, Paul Hastings attorneys prepared and filed the proposed consent order continuing the retention of Sotheby's International Realty (which expired on April 30, 2023), which order was entered by the Court on May 5, 2023 [Docket No. 1767]. C. Relief from Stay / Adequate Protection Proceedings (Task Code B140) Fees: \$11,991.00 Total Hours: 9.50

90. During the Fee Period, Paul Hastings attorneys analyzed case law and statutory authority related to the AIG's letter purporting to terminate the AIG Policies with respect to the Sherry Netherland Apartment. D. Fee / Employment Applications for Other Professionals (Task Code B165) Fees: \$50,617.50 Total Hours: 39.80

91. During the Fee Period, Paul Hastings attorneys assisted Genever (US)'s public adjuster, i.e., Affiliated Adjustment Group ("AAGL"), with the preparation of its application to be retained by Genever (US) as public adjuster [Docket No. 1749], which application was granted on July 13, 2023 [Docket No. 2000]. Paul Hastings attorneys also prepared and filed the application of Saxe Doernberger & Vita, P.C. ("SDV"), as special insurance coverage counsel to Genever (US), which application was granted on June 29, 2023 [Docket No. 1963].29 As further detailed below, SDV represents the Trustee in the AIG Adversary Proceeding, seeking, among other things, an injunction prohibiting AIG from cancelling certain AIG insurance policies sold to Genever (US) with respect to the Sherry Netherland Apartment.30 In addition, during the Fee Period, Paul Hastings attorneys assisted Genever (US) with engaging Find the Cause

29 Initially, Genever (US) contemplated retaining Blank Rome as its special insurance coverage counsel; however, that retention ultimately did not go forward.

30 On August 4, 2023, Genever (US) filed an application [Docket No. 2042] to retain McCormack Jensen & Bliss PC to replace SDV as special insurance coverage counsel.

Investigation, LLC to investigate the cause of the March 15, 2023 fire at the Sherry Netherland Apartment.31

92. During the Fee Period, Paul Hastings attorneys analyzed various operational matters with respect to Genever (US), including, most notably, as it relates to the insurance coverage for the Sherry Netherland Apartment following the March 15, 2023 fire. In this regard, the Trustee had numerous communications with counsel to the insurer (AIG), the insurance broker (Wolfson), counsel to the Sherry Netherland, counsel to PAX, and the claims adjuster (AAGL) retained by Genever (US).

F. Claims Administration and Objections (Task Code B310) Fees: \$39,811.50 Total Hours: 33.90

93. During the Fee Period, Paul Hastings attorneys prepared and filed the objection to the proof claim filed by the Individual Debtor's son, Mr. Qiang Guo [Docket No. 1630]. Paul Hastings attorneys in our London offices also handled the service of the claims objection upon Mr. Qiang Guo, who the Trustee understands resides in London. On May 5, 2023, Paul Hastings filed a notice advising the Court that Mr. Qiang Guo failed to file a timely response to the claim objection and attaching a proposed order disallowing and expunging his proof of claim.

A. General Litigation (Task Code B191) Fees: \$177,701.00 Total Hours: 150.20

94. During the Fee Period, Paul Hastings attorneys prepared and filed the Trustee's complaint against Scott Barnett (the Individual Debtor's driver and/or bodyguard), Taurus Fund, LLC, and Taurus Management LLC [Adv. Proc. No. 22-05017] (the "Mahwah Adversary

E. Business Operations (Task Code B210) Fees: \$104,866.00 Total Hours: 71.90

31 Given the small amount of fees involved, the U.S. Trustee did not require a separate retention application. Case 22-50073 Doc 2051 Filed 08/04/23 Entered 08/04/23 18:53:56 Page 45 of 906

Proceeding").32 In the Mahwah Adversary Proceeding, the Trustee seeks determinations that, among other things, (a) the Debtor is the equitable owner of the 50,000 square foot Mahwah Mansion, (b) the Debtor is the equitable owner of Taurus Fund, LLC (the entity holding title to Mahwah Mansion), and (c) that Taurus Fund is an alter ego of the Debtor.

95. In addition to preparing the complaint, Paul Hastings attorneys prepared, among other things, a motion for a temporary restraining order and preliminary injunction and related pleadings, as well as a motion to seal the filing of the complaint pending the entry of the temporary restraining order. Injunctive relief and keeping the complaint temporarily under seal were necessary in order to protect the Mahwah Mansion and avoid potential damage or other issues that could arise had the complaint been filed publically. On August 1, 2023, the Court granted the motion to seal [Docket No. 16 in Adv. Proc. No. 22-05017] and entered a temporary restraining order [Docket No. 17 in Adv. Proc. No. 22-05017].

A. General Litigation (Task Code B191) Fees: \$446,748.50 Total Hours: 360.10

96. During the Fee Period, Paul Hastings attorneys prepared and filed the Trustee's complaint against the HCHK Entities, the Assignee, Holy City Hong Kong Ventures, Ltd., Yvette Wang, and Anthony DiBattista [Adv. Proc. No. 22-05013] (the "HCHK Adversary Proceeding"). In the HCHK Adversary Proceeding, the Trustee seeks determinations that, among other things, (a) the HCHK Entities are alter egos of the Individual Debtor and (b) the Individual Debtor is the equitable owner of the HCHK Entities and/or their assets. In addition, the complaint sought an injunction against the commencement or continuation of the assignment

32 The Mahwah Adversary Proceeding was commenced on July 11, 2023, shortly after the end of the Fee Period. Case 22-50073 Doc 2051 Filed 08/04/23 Entered 08/04/23 18:53:56 Page 46 of 906

proceedings commenced with respect to the HCHK Entities in New York state court (the "Assignment Proceedings").

97. In connection with the relief sought in the HCHK Adversary Proceeding, the Trustee and Paul Hastings attorneys prepared numerous filings, including motions for injunctive relief [Docket Nos. 4 and 14 in Adv. Proc. No. 22-05013], a motion to seal the complaint on a temporary basis [Docket No. 7 in Adv. Proc. No. 22-05013], and, following settlement discussions between the Trustee and the Assignee, a motion for approval of a settlement agreement (the "Assignee Settlement") between the Trustee and the Assignee pursuant to Bankruptcy Rule 9019 [Docket No. 25 in Adv. Proc. No. 22-05013]. In addition, the Trustee and his counsel prepared a draft objection to be filed in New York state court addressing pending hearing dates and deadlines in the Assignment Proceedings. This filing was ultimately not necessary once the temporary restraining order halting the progress of the Assignment Proceedings was entered on June 12, 2023.

98. Paul Hastings also notes that the HCHK Adversary Proceeding was commenced under intense time pressure and on an emergency basis shortly after the Trustee was notified of the commencement of the Assignment Proceedings. Shortly after the entry of the temporary restraining order, the Trustee was also able to successfully negotiate the Assignee Settlement with the Assignee and present such settlement to this Court. The Assignee Settlement provides for important benefits to the estate, including the deposit of over \$38 million of the HCHK Entities' funds into accounts controlled by the Trustee and the Assignee's commitment to not oppose the relief sought by the Trustee in the HCHK Litigation. The Assignee Settlement was approved by the Court by order dated July 28, 2023 [Docket No. 70 in Adv. Proc. No. 23- 05013]. IX. Interpleader Adversary (Matter ID 00015)

A. General Litigation (Task Code B191) Fees: \$20,389.50 Total Hours: 12.30

99. On June 6, 2023, U.S. Bank commenced an interpleader action [Adv. Proc. No. 23-05012] (the "Interpleader Adversary Proceeding") to resolve a dispute regarding the release of \$33 million in funds (the "Escrow Funds") held by U.S. Bank in escrow pursuant to an escrow agreement between HK USA, the Committee, and U.S. Bank (the "Escrow Agreement") entered into in connection with that certain *Stipulated Order Compelling HK International Funds Investments (USA) Limited, LLC to Transport and Deliver that Certain Yacht, The "Lady May"* entered by the Court on April 29, 2022 [Docket No. 299].

100. U.S. Bank commenced the Interpleader Adversary Proceeding following the Court's ruling [Docket No. 221 in Adv. Proc. No. 22-05003] in the HK USA Adversary Proceeding that (a) among other things, all property of HK USA, including the Escrow Funds, are property of the Individual Debtor's estate, and (b) directing HK USA to deliver all property of HK USA to the Trustee. The Trustee takes the position that this ruling requires the immediate turnover of such funds to the Trustee. However, HK USA has refused to instruct U.S. Bank to release the funds to the Trustee and, instead, taken the position that, under the Escrow Agreement, the funds cannot be turned over to the Trustee, absent a final, non-appealable order to that effect.

101. While the bulk of the services provided to the Trustee in connection with the Interpleader Adversary Proceeding was undertaken by the Trustee's local counsel, i.e., NPM, Paul Hastings attorneys performed certain discrete tasks related to the Interpleader Adversary Proceeding, including analyzing and commenting on (a) the draft motion for summary judgment prepared by NPM and (b) the consent order, entered by the Court on June 28, 2023 [Docket No. Case 22-50073 Doc 2051 Filed 08/04/23 Entered 08/04/23 18:53:56 Page 48 of 906

40 in Adv. Proc. No. 22-05012] (the "Interpleader Order"), concerning the deposit of the Escrow Funds with the Registry of the Court (after payment of certain fees and expenses of the Escrow Agent). Of particular note, the Interpleader Order reflects the agreement of the parties (including HK USA and the U.S. Trustee) that such funds would be deposited into the Trustee's bank account at East West Bank (although deemed deposited with the Registry of the Court), so as to allow the Trustee to earn interest on such funds.

A. General Litigation (Task Code B191) Fees: \$171,698.50 Total Hours: 141.40

102. During the Fee Period, Paul Hastings attorneys prepared and filed the Trustee's complaint against Mei Guo [Adv. Proc. No. 22-05008] (the "Mei Guo Adversary Proceeding"), seeking (a) an order declaring that the proceeds, likely in an amount of over \$10 million, from the sale of the Individual Debtor's private Bombardier jet (the "Bombardier Proceeds") are property of the estate, (b) an order that Mei Guo surrender the Bombardier Proceeds or the value thereof to the Trustee because she received the Bombardier Proceeds as an unauthorized postpetition transfer avoidable under section 549 of the Bankruptcy Code, (c) an order that Mei Guo surrender to the Trustee the value of the Debtor's shell company Anton Development Limited at the time the company was transferred to her on June 27, 2017 (upon which date Anton Development Limited was title holder to the Bombardier jet) pursuant to a transaction avoidable as an actual fraudulent transfer, and (d) an order declaring that a series of BVI registered shell companies purportedly held by Mei Guo are property of the Individual Debtor's chapter 11 estate.

103. Preparing the complaint in the Mei Guo Adversary Proceeding required Paul Hastings attorneys to address a number of complex factual and legal issues, including related to

the transactional and ownership history of the Individual Debtor's Bombardier jet and the BVI shell companies purportedly owned by Mei Guo, as well as complicated legal issues in connection with formulating the claims that could be brought against Mei Guo or other potential defendants, including under foreign law applicable to foreign-registered entities (such as the BVI shell companies that are the subject of the Mei Guo Adversary Proceeding).

- A. Court Hearings (Task Code B155) Fees: \$275,419.00 Total Hours: 183.30 - 104. During the Fee Period, Paul Hastings attorneys prepared for and attended

numerous hearings related to the HK USA Adversary Proceeding (as defined below), including:

- the March 8, 2023 status conference in connection with the Trustee's request for pre-judgment remedies and injunctive relief; - the March 15-16, 2023 hearings in connection with the Trustee's request for pre-judgment remedies and injunctive relief; - the March 23, 2023 hearing on Mei Guo's request for an extension of time to make certain disclosures required under the preliminary injunction order; - the March 27, 2023 hearing on the Trustee's motion for partial summary judgment on the Trustee's first counterclaim (regarding ownership of Lady May); - the March 30, 2023 status conference on the status of the Lady May II; - the April 11, 2023 hearing on HK USA and Mei Guo's motion to dismiss; - the April 20, 2023 hearing on the Trustee's motion for partial summary judgment on the Trustee's second counterclaim (regarding alter ego status of HK USA); - the June 6, 2023 status conference on HK USA and Mei Guo's motion for a stay pending appeal; - the June 9, 2023 status conference before the District Court in connection with HK USA and Mei Guo's appeal; - the June 13, 2023 hearing on HK USA and Mei Guo's motion for a stay pending appeal; and - the June 26, 2023 hearing and status conference before the District Court related to HK USA and Mei Guo's motions for a stay pending appeal filed with the District Court. - B. General Litigation (Task Code B191) Fees: \$1,753,792.50 Total Hours: 1,367.10

105. During the Fee Period, Paul Hastings attorneys continued to prosecute the Trustee's counterclaims against HK USA and Mei Guo [Adv. Proc. No. 22-05003] (the "HK USA Adversary Proceeding"). In the HK USA Adversary Proceeding, the Trustee sought 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. In the alternative, the Trustee also asserted an actual fraudulent transfer claim and a negligence claim against HK USA.

106. As the Court is well aware, 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 Nos. 140 and 142 in Adv. Proc. No. 22-05003], but also summary judgment rulings that, among other things, (a) the Lady May and the Lady May II are property of the Individual Debtor's estate, (b) HK USA is an alter ego of the Individual Debtor, and (c) the \$33 million held in escrow by U.S. Bank are property of the estate [Docket Nos. 172 and 221 in Adv. Proc. No. 22-05003].

107. In connection with the relief sought by the Trustee in the HK USA Adversary Proceeding, Paul Hastings attorneys prepared several motions and other pleadings, including:

- the Trustee's reply in support of his request for pre-judgment remedies [Docket No. 101 in Adv. Proc. No. 22-05003]; - a motion in limine to allow use of the Individual Debtor's deposition testimony [Docket No. 112 in Adv. Proc. No. 22-05003] at the

prejudgment remedy hearing scheduled to begin on March 15, 2023 (the "PJR Hearing");

- objections to motions in limine filed by HK USA and Mei Guo in connection with the PJR Hearing [Docket Nos. 119, 123, 124, 125, and 127 in Adv. Proc. No. 22-05003]; - a motion for an order drawing adverse inferences against HK USA and Mei Guo [Docket No. 107 in Adv. Proc. No. 22-05003]; - a motion for partial summary judgment and related memorandum of law and other filings with respect to the Trustee's first counterclaim (asserting that the Lady May is property of the Individual Debtor's estate) [Docket Nos. 146, 147, 148, 149, and 150 in Adv. Proc. No. 22- 05003]; - a second motion for partial summary judgment and related memorandum of law and other filings with respect to the Trustee's second counterclaim (asserting that HK USA is an alter ego of the Individual Debtor) [Docket Nos. 185, 186, 187, 188, 189, 190 in Adv. Proc. No. 22-05003] as well as a reply brief in support of such motion [Docket No. 209 in Adv. Proc. No. 22-05003]; and - objections to the motions of HK USA and Mei Guo for a stay pending appeal filed before this Court [Docket Nos. 235 and 246 in Adv. Proc. No. 22-05003].

108. In connection with the foregoing, Paul Hastings attorneys continued to research numerous complex legal issues critical to the relief requested by the Trustee, including the preclusive effect of Justice Ostrager's rulings in the PAX Litigation and the doctrines of in pari delicto and alter ego, and Paul Hastings attorneys continued to handle numerous procedural matters related to the HK USA Adversary Proceeding (including preparing proposed consent orders for prejudgment remedies and injunctive relief).

109. The Trustee and Paul Hastings attorneys also prepared for and took the depositions of the Individual Debtor (on March 2, 2023) and defended the deposition of the Trustee (on March 3, 2023). Moreover, the Trustee and Paul Hastings attorneys devoted significant time preparing for the PJR Hearing, at which it was expected that Mei Guo and Case 22-50073 Doc 2051 Filed 08/04/23 Entered 08/04/23 18:53:56 Page 52 of 906

Stephen Kindseth would testify, including by researching and analyzing numerous evidentiary issues in connection therewith.33 The PJR Hearing was of critical importance given that, in the absence of prejudgment remedies, HK USA and Mei Guo might have been able to, among other things, dissipate the approximately \$33 million in Escrow Funds. C. Non-Working Travel (Task Code B195) [billed at ½ rate] Fees: \$6,915.00 Total Hours: 10.10

110. During the Fee Period, Paul Hastings attorneys travelled to and from the bankruptcy courthouse in Bridgeport, Connecticut, to attend hearings related to the HK USA Adversary Proceeding. XII. Bravo Luck Adversary (Matter ID 00018)

A. General Litigation (Task Code B191) Fees: \$611,769.50 Total Hours: 487.50

111. During the Fee Period, Paul Hastings attorneys continued to prosecute the claims asserted by the Trustee, Genever (BVI), and Genever (US) in the procedurally consolidated adversary proceeding against Bravo Luck and the Debtors' son, Mr. Qiang Guo [Adv. Proc. No. Adversary Proceeding No. 22-05027] (the "Bravo Luck Adversary Proceeding"). In the Bravo Luck Adversary Proceeding, the Trustee, Genever (BVI), and Genever (US) are challenging the validity and enforceability of a purported trust agreement between the Individual Debtor, Genever (BVI), Genever (US), and Bravo Luck, pursuant to which Bravo Luck was purportedly granted a beneficial ownership of the Sherry Netherland Apartment, as well as asserting fraudulent transfer claims against Bravo Luck and Mr. Qiang Guo.

112. In connection with the Bravo Luck Adversary Proceeding, Paul Hastings attorneys analyzed the memoranda of law in support of the motions to dismiss filed by Bravo

33 Ultimately, the parties reached a consensual resolution as it relates to the injunction and prejudgment remedies sought by the Trustee, obviating the need for such testimony. Case 22-50073 Doc 2051 Filed 08/04/23 Entered 08/04/23 18:53:56 Page 53 of 906

Luck [Docket Nos. 54, 56, and 60 in Adv. Proc. No. 22-05027], prepared and filed corresponding objections to the motions to dismiss [Docket Nos. 67, 68, and 69 in Adv. Proc. No. 22-05027], and analyzed the corresponding reply briefs filed by Bravo Luck [Docket Nos. 77, 78, and 79 in Adv. Proc. No. 22-05027], including in connection with preparing for a potential hearing in connection with the motions to dismiss (which hearing was adjourned).

113. In addition, Paul Hastings attorneys prepared and filed pleadings and related papers requesting entry of a default judgment against Mr. Qiang Guo [Docket No. 89 and 93 in Adv. Proc. No. 22-05027]. Paul Hastings attorneys also attended to discovery issues related to the Bravo Luck Adversary Proceeding, including preparing discovery requests and responding to discovery requests from Bravo Luck. As part of these efforts, Paul Hastings attorneys continued to research and analyze complex issues related to the substance of the forgery and related theories set forth in the complaints as well as issues arising in connection with seeking a default judgment.

114. Finally, during the Fee Period, the Trustee and Paul Hastings began discussions with Bravo Luck's counsel in connection with a potential settlement. As a result of these discussions, on August 4, 2023, the Trustee and the Genever Debtors filed the Bravo Luck 9019 Motion seeking approval of a settlement resolving the Bravo Luck Adversary Proceeding in its entirety. Pursuant to that settlement, among other things, Bravo Luck and Qiang Guo relinquish any right, title, or interest in the Sherry Netherland Apartment. XIII. SN Apartment Adversary (Matter ID 00019)

A. General Litigation (Task Code B191) Fees: \$30,044.50 Total Hours: 20.00

115. As noted in the First Interim Fee Application, prior to the commencement of the Fee Period, Paul Hastings attorneys prepared and filed Genever (US)'s and the Trustee's Case 22-50073 Doc 2051 Filed 08/04/23 Entered 08/04/23 18:53:56 Page 54 of 906

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) [Adv. Proc. No. 23-05002] (the "Sherry Netherland Adversary Proceeding"). Concurrently with the filing of the complaint, Genever (US) and the Trustee also filed a motion for summary judgment and related pleadings.

116. During the Fee Period, Paul Hastings attorneys reached a consensual resolution of Bravo Luck's motion to intervene in this litigation, pursuant to which Bravo Luck's intervention motion was deemed withdrawn [Docket No. 49 in Adv. Proc. No. 23-05002]. That said, work related to the Sherry Netherland Adversary Proceeding was largely put on pause following the March 15, 2023 arrest of the Debtor at the Sherry Netherland Apartment and the fire that occurred there on the same day—as a result of which the Individual Debtor's occupancy of the Sherry Netherland Apartment has effectively ceased. XIV. Greenwich Land Adversary (Matter ID 00020)

A. Court Hearings (Task Code B155) Fees: \$12,832.00 Total Hours: 8.00

117. During the Fee Period, Paul Hastings attorneys prepared for and attended the May 30, 2023 pre-trial conference in the Greenwich Land Adversary Proceeding (as defined below).

B. During the Fee Period, Paul HastGeneral Litigation (Task Code B191) Fees: \$547,372.00 Total Hours: 434.90

118. During the Fee Period, Paul Hastings attorneys prepared and filed the Trustee's complaint against Greenwich Land and Hing Chi Ngok [Adv. Proc. No. 23-05005] (the "Greenwich Land Adversary Proceeding"). In the Greenwich Land Adversary Proceeding, the Trustee seeks determinations that, among other things, (a) Greenwich Land is an alter ego of the Debtor and (b) the Debtor is the equitable owner of Greenwich Land. Case 22-50073 Doc 2051 Filed 08/04/23 Entered 08/04/23 18:53:56 Page 55 of 906

119. In connection with the relief sought in the Greenwich Land Adversary Proceeding, Paul Hastings attorneys prepared several filings, including, most notably, motions for injunctive relief and prejudgment remedies [Docket Nos. 11 and 12 in Adv. Proc. No. 22- 05005]. Paul Hastings attorneys also devoted time to preparing for a potential hearing on the Trustee's injunction motion and the objection of Greenwich Land and Hing Chi Ngok thereto, including by preparing and filing of lists of witnesses, exhibits, and documents for judicial notice [Docket Nos. 38, 39, and 45 in Adv. Proc. No. 22-05005]. Ultimately, the motion for injunctive relief and prejudgment remedies was consensually resolved prior to the scheduled hearing pursuant to a consent order granting in part the Trustee's injunction motion [Docket No. 53 in Adv. Proc. No. 22-05005].

120. In addition, during the Fee Period, Paul Hastings attorneys analyzed the answer filed by Greenwich Land and Hing Chi Ngok [Docket No. 34 in Adv. Proc. No. 22-05005], worked on numerous discovery issues, including preparing and responding to discovery requests, and assisted in preparing a declaration from a key witness.

121. Paul Hastings' efforts thus far have resulted in critical prejudgment remedies and injunctive relief to protect the assets of Greenwich Land, including the Individual Debtor's mansion on Taconic Road in Greenwich, Connecticut, pending the outcome of the Greenwich Land Adversary Proceeding, for the benefit of the estate.

A. General Litigation (Task Code B191) Fees: \$68,634.00 Total Hours: 36.90

122. During the Fee Period, Genever (US), through its counsel SDV, filed a complaint against AIG [Adv. Proc. No. 23-05007] (the "AIG Adversary Proceeding") seeking, among other things, (a) an injunction prohibiting AIG from cancelling the AIG Policies, (b) declarations that Case 22-50073 Doc 2051 Filed 08/04/23 Entered 08/04/23 18:53:56 Page 56 of 906

AIG must provide coverage for first and third party losses resulting from the March 15, 2023 fire at the Sherry Netherland Apartment and may not cancel the AIG Policies during the 2023-2024 policy term, and (c) awards of compensatory and punitive damages and immediate insurance proceeds for emergency cleanup measures.

123. In the AIG Adversary Proceeding, the Trustee worked with SDV to, among other things, review and revise Genever (US)'s complaint, preliminary injunction motion, and reply in support thereof. On July 13, 2023, the Court granted the preliminary injunction requested by the Trustee. For the avoidance of doubt, Paul Hastings did not represent Genever (US) in the AIG Adversary Proceeding.

124. 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 U.S.C. § 327 "reasonable compensation for actual, necessary services rendered" and "reimbursement for actual, necessary expenses." 11 U.S.C. § 330(a)(1).34

125. 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,

34 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). Case 22-50073 Doc 2051 Filed 08/04/23 Entered 08/04/23 18:53:56 Page 57 of 906

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).

126. 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., 35 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 "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.36 See In re Nine Assocs., Inc., 76 B.R. 943, 945 (S.D.N.Y. 1987) (adopting First Colonial/Johnson analysis); In re Cuisine

35 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.

36 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).

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").

127. 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 \$8,057,816.25 and 6,455.80 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 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 NPM as local and conflicts counsel in order to provide services to the Trustee and the Genever Debtors in a costeffective 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 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 was, 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, among other assets, the Lady May, the Lady May II, and \$33 million in escrow funds. Moreover, on August 1, 2023, the Trustee received approximately \$38.8 million in funds pursuant to the settlement with the Assignee in the HCHK Adversary Proceeding. Furthermore, 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, prior to the Court granting the First Interim Fee Application at the end of June 2023, Paul Hastings was 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.

128. 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.

129. 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].

130. 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.

131. As set forth in Exhibit C hereto, Paul Hastings incurred and disbursed \$213,914.83 as expenses in providing professional services during the Fee Period. These expenses include approximately \$32,739.21 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 Case 22-50073 Doc 2051 Filed 08/04/23 Entered 08/04/23 18:53:56 Page 62 of 906

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 service-related expenses, the Trustee and Paul Hastings are merely passing on the costs of such third-party services, without any mark-up.37

- 132. Additional necessary expenses included: - 133. \$85,826.32 for certain outside professional services, such as document review services by UnitedLex (\$75,336.93), translation services by Divergent Language Solutions (\$8,838.80), and Mr. Paul Wright, as the U.K. barrister (\$1,091.59); - 134. \$21,230.22 for court reporting services; - 135. \$20,481.56 for document reproductions, namely \$19,682.96 for b/w reproductions (at 8 cents per page) and \$798.60 for color reproductions (at 20 cents per page); - 136. \$14,702.79 for UPS/courier service, including service of pleadings required to be served in hard copy format; - 137. \$12,262.50 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; and - 138. \$718.63 for corporate document retrieval services (including United Corporate Service) with respect to various Kwok-related entities.

133. 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.

37 Documentation of these expenses will be made available to the Court upon request. Case 22-50073 Doc 2051 Filed 08/04/23 Entered 08/04/23 18:53:56 Page 63 of 906

134. 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 the UnitedLex 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.

135. 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. Case 22-50073 Doc 2051 Filed 08/04/23 Entered 08/04/23 18:53:56 Page 64 of 906

136. 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.38

137. 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.

138. 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.

139. The expenses incurred in providing professional services in the Chapter 11 Case were necessary, economical, and justified under the circumstances.

140. 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 thirty (30) timekeepers who billed less than ten (10) hours during the Fee Period. The total amount of such fees is \$78,932.00. In addition, a result of the agreed-upon reduction in Luc Despins' hourly rate

38 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.

(from his standard hourly rate of \$1,975 to the reduced hourly rate of \$1,860), an additional \$59,610.25 in fees have been waived.

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 budgeted for the Fee Period are higher by 10% or more, did you 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 25.5 hours and associated fees of approximately \$41,437.50 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 4 hours were spent on each of the seven 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 Case 22-50073 Doc 2051 Filed 08/04/23 Entered 08/04/23 18:53:56 Page 66 of 906

> 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].

141. 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. 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.

142. 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 2051 Filed 08/04/23 Entered 08/04/23 18:53:56 Page 67 of 906

WHEREFORE, Paul Hastings respectfully requests entry of an order, substantially in the form attached hereto as Exhibit G, (i) allowing interim compensation for professional services rendered during the Fee Period in the amount of \$8,037,720.00 and reimbursement of \$213,914.83 in expenses, (ii) authorizing and directing prompt payment from the Debtors' estates of 80% of such compensation and 100% of such expenses, (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: August 4, 2023 New Haven, Connecticut

By: Patrick R. Linsey 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: :

HO WAN KWOK, et al.,1 :

Debtors. : :

The undersigned hereby certifies that on August 4, 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: August 4, 2023 New Haven, Connecticut

By: Patrick R. Linsey Douglas S. Skalka (ct00616) Patrick R. Linsey (ct29437) NEUBERT, PEPE & MONTEITH, P.C. 195 Church Street, 13th Floor New Haven, Connecticut 06510

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.

(203) 781-2847 dskalka@npmlaw.com plinsey@npmlaw.com

Counsel for the Chapter 11 Trustee, Genever Holdings Corporation, and Genever Holdings LLC

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 July 1, 2022 and ending on June 30, 2023 was, in the aggregate, approximately \$1,131 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 \$1,247 per hour. A detailed comparison of these rates follows:

Category of Timekeeper Blended Hourly Rate

Blended Hourly Rate Debtor Blended Hourly

All Timekeepers Aggregated \$1,131 \$1,247

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.

Summary of Timekeepers Included in this Application

Bassett, Nicholas Corporate, 2007 \$1,625.00 514.50 \$836,062.50 1 Bassett, Nicholas (travel; ½ rate) Corporate, 2007 \$812.50 6.70 \$5,443.75 1 Despins, Luc Restructuring, 1986 \$1,860.00 513.20 \$954,552.00 N/A Despins, Luc (travel; ½ rate) Restructuring, 1986 \$930.00 10.30 \$9,579.00 N/A

Bongartz, Alex Restructuring, 2007 \$1,625.00 531.40 \$863,525.00 1 Bongartz, Alex (travel; ½ rate) Restructuring, 2007 \$812.50 11.60 \$9,425.00 1 Luft, Avi Corporate, 2000 \$1,625.00 783.80 \$1,273,675.00 1 Luft, Avi (travel; ½ rate) Corporate, 2000 \$812.50 15.50 \$12,593.75 1 Shelley, Scott Corporate, 1994 \$1,525.00 14.60 \$22,265.00 N/A Traxler, Katherine Restructuring, 1990 \$1,025.00 23.90 \$24,497.50 1 Of Counsel Total:

Barron, Douglass Corporate, 2012 \$1,320.00 764.30 \$1,008,876.00 1 Barron, Douglass (travel; ½ rate) Corporate, 2012 \$660.00 3.90 \$2,574.00 1 Catalano, Kristin Corporate, 2021 \$915.00 450.40 \$412,116.00 1 Daly, Crispin Corporate, 2010 \$1,320.00 30.20 \$39,864.00 1 Farmer, Will Corporate, 2018 \$1,235.00 418.00 \$516,230.00 1 Ganapathi, Anuva Litigation, 2021 \$915.00 66.90 \$61,213.50 1 Gilberg, Ben Litigation, 2022 \$915.00 10.60 \$9,699.00 N/A Hibbard, Jack Corporate, 2022 \$855.00 14.70 \$12,568.50 N/A Kosciewicz, Jon Litigation, 2021 \$915.00 419.00 \$383,385.00 1 Maza, Shlomo Corporate, 2012 \$1,320.00 222.70 \$293,964.00 1 Miliotes, Lanie Corporate, 2023 \$855.00 38.50 \$32,917.50 1 Nowak, Tanja Corporate \$620.00 12.60 \$7,812.00 N/A Sadler, Tess Corporate, 2019 \$1,175.00 48.80 \$57,340.00 1

[redacted] Corporate, 2023 \$815.00 273.90 \$223,228.50 1 [redacted] (travel; ½ rate) Corporate, 2023 \$407.50 3.50 \$1,426.25 1 Sutton, Ezra Corporate, 2021 \$1,015.00 608.20 \$617,323.00 1 [redacted] Corporate, 2022 \$915.00 25.70 \$23,515.50 1 Zhuang, Delphine Corporate, 2016 \$1,125.00 13.80 \$15,525.00 N/A Associate Total: 3,425.70 \$3,719,577.75

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 2051 Filed 08/04/23 Entered 08/04/23 18:53:56 Page 73 of 906

Elliott, Elizabeth Legal Research Analyst \$400.00 10.60 \$4,240.00 1 Kuo, Jocelyn Paralegal \$540.00 293.40 \$158,436.00 N/A Mohamed, David Paralegal \$540.00 302.10 \$163,134.00 1 Mohamed, David (travel, ½ rate) Paralegal \$270.00 3.00 \$810.00 1 Paraprofessional Total: 609.10 \$326,620.00

TOTAL (net of \$20,096.25 credit):2 \$8,037,720.00

2 Due to an inadvertent oversight, the monthly fee statements for January and February 2023 (which were covered in the prior fee application) did not reflect the voluntary reduction in the hourly rate of the Trustee (from \$1,975 to \$1,860 per hour), resulting in an overstatement of Paul Hastings' fees by \$20,096.25 with respect to these two months. This amount has been credited in this Application against the fees incurred during the Fee Period.

Summary of Timekeepers Not Included in this Application1

Rawlins, Justin Financial Restructuring, 2000 \$1,650.00 0.70 \$1,155.00 Timofeyev, Igor V. Litigation, 2007 \$1,625.00 2.10 \$3,412.50 Weitzman, Avi Litigation, 2000 \$1,700.00 1.00 \$1,700.00

Strickon, Harvey Corporate, 1972 \$1,900.00 0.30 \$570.00

Agarwal, Ajay Corporate \$915.00 4.60 \$4,209.00 Ahluwalia, Sainaya Corporate \$535.00 0.10 \$53.50 Byrne, Daniel Corporate \$800.00 0.20 \$160.00 Carter, Jessica Litigation, 2022 \$855.00 0.70 \$598.50

[redacted] Corporate, 2022 \$855.00 4.00 \$3,420.00 [redacted] Litigation, 2022 \$915.00 4.20 \$3,843.00 Guzman, Andrea Litigation, 2023 \$855.00 3.00 \$2,565.00 Kim, Sarah Litigation, 2023 \$855.00 1.80 \$1,539.00 Koch, Leonie Corporate, 2023 \$855.00 8.10 \$6,925.50 Korchik, Maria Corporate \$535.00 3.60 \$1,926.00 Shang, Candice Litigation, 2016 \$1,270.00 2.80 \$3,556.00 Smith, Deena Corporate, 2021 \$915.00 3.30 \$3,019.50

[redacted] Corporate, 2021 \$915.00 9.40 \$8,601.00

Foster, Lauren Transactional Services, 2018 \$610.00 0.30 \$183.00 Langer, Bobbi Real Estate, 1984 \$975.00 8.20 \$7,995.00 Sepinuck, Stephen Corporate, 1987 \$1,365.00 1.30 \$1,774.50 Swartz, Robin Real Estate, 1992 \$1,255.00 1.00 \$1,255.00

1 As noted, as an accommodation to these estates, Paul Hastings is not seeking allowance or payment at this time for the fees of timekeepers who billed less than ten (10) hours during the Fee Period in the aggregate amount of \$78,932.00. 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 2051 Filed 08/04/23 Entered 08/04/23 18:53:56 Page 75 of 906

Austin, Javii Legal Research Analyst \$400.00 4.10 \$1,640.00 Cairns, Dennis Court Services Coordinator \$385.00 6.30 \$2,425.50 Chang, Irene Legal Research Analyst \$400.00 5.70 \$2,280.00 Jordan, James Paralegal \$530.00 0.80 \$424.00 Le Blanc, Wayne E. Jr. Paralegal \$595.00 2.60 \$1,547.00 Liu, Kelly Legal Research Analyst \$400.00 2.60 \$1,040.00 Nunez, Amanda Paralegal \$565.00 2.80 \$1,582.00 O'Dea, Heather Legal Research Analyst \$400.00 7.80 \$3,120.00

Case 22-50073 Doc 2051 Filed 08/04/23 Entered 08/04/23 18:53:56 Page 76 of 906

Summary of Compensation by Project Category

U.S. Trustee Task Code and Project Category Fees

B113 Pleadings Review 133.50 \$74,357.00 B120 Asset Analysis and Recovery 35.80 \$52,856.50 B130 Asset Disposition 267.80 \$387,740.00 B131 Sale of Real Estate 15.10 \$22,193.00 B140 Relief from Stay / Adequate Protection Proceedings 9.50 \$11,991.00 B155 Court Hearings 361.30 \$539,402.00 B160 Employment / Fee Applications (Paul Hastings) 149.50 \$209,583.00 B165 Employment / Fee Applications (Other Professionals) 88.70 \$116,154.00 B180 Avoidance Action Analysis 0.20 \$264.00 B190 Other Contested Matters 60.30 \$85,744.00 B191 General Litigation 3,184.10 \$4,004,565.00 B195 Non-Working Travel 54.50 \$41,851.75 B210 Business Operations 263.00 \$373,050.00 B211 Financial Reports (Monthly Operating Reports) 15.80 \$18,387.00 B230 Financing / Cash Collections 41.90 \$43,217.50

B261 Investigations 1,503.70 \$1,762,063.00 B262 Contempt Proceedings 20.00 \$28,081.50 B310 Claims Administration and Objections 47.50 \$55,994.50 B320 Plan and Disclosure Statement 0.90 \$1,674.00

Case 22-50073 Doc 2051 Filed 08/04/23 Entered 08/04/23 18:53:56 Page 77 of 906

ID Matter Name March 2023 April 2023 May 2023 June 2023 Total Fees

Trustee Representation \$169,654.50 \$142,526.50 \$211,046.00 \$116,237.25 \$639,464.25

Litigation \$581,432.00 \$716,503.50 \$769,932.50 \$296,196.25 \$2,364,064.25 00003 Other Litigation \$12,013.50 \$28,472.00 \$28,178.50 \$2,202.50 \$70,866.50 00004 Corporate Law Issues \$78,033.50 \$27,451.50 \$12,009.00 \$117,494.00 00005 Sale Process \$0.00 \$19,729.50 \$104,320.50 \$306,368.00 \$430,418.00 00006 Tax Issues \$0.00 \$0.00 \$0.00 \$0.00 \$0.00 00007 Foreign Law Issues \$1,188.00 \$0.00 \$0.00 \$0.00 \$1,188.00 00008 Plan Process Issues \$1,674.00 \$0.00 \$0.00 \$0.00 \$1,674.00 00010 Genever US \$62,395.00 \$146,123.00 \$55,998.00 \$13,019.50 \$277,535.50 00011 Genever BVI \$0.00 \$0.00 \$4,220.00 \$0.00 \$4,220.00 00012 Mahwah Adversary \$0.00 \$0.00 \$11,128.50 \$166,572.50 \$177,701.00

Adversary \$0.00 \$0.00 \$0.00 \$5,686.50 \$5,686.50 00014 HCHK Adversary \$0.00 \$0.00 \$5,564.50 \$445,832.00 \$451,396.50 00015 Interpleader Adversary \$0.00 \$0.00 \$0.00 \$20,389.50 \$20,389.50 00016 Mei Guo Adversary \$0.00 \$83,510.50 \$81,842.50 \$6,345.50 \$171,698.50 00017 HK USA Adversary \$1,521,257.00 \$284,482.00 \$48,095.50 \$182,292.00 \$2,036,126.50 00018 Bravo Luck Adversary \$52,474.00 \$264,320.50 \$177,603.50 \$118,906.00 \$613,304.00

Adversary \$17,711.50 \$12,557.00 \$2,762.00 \$751.50 \$33,782.00

Adversary \$150,853.50 \$131,051.00 \$232,539.75 \$51,203.50 \$565,647.75 00021 AIG Adversary \$0.00 \$0.00 \$52,080.00 \$18,042.00 \$70,122.00 00022 PAX Adversary \$975.00 \$325.00 \$3,737.50 \$0.00 \$5,037.50 TOTAL \$2,649,661.50 \$1,829,600.50 \$1,816,500.75 \$1,762,053.50 \$8,057,816.25

Summary of Actual and Necessary Expenses (March 2023 through June 2023)

Expense Category March 2023 April 2023 May 2023 June 2023 Total

Airfare (Nicholas Bassett) \$1,197.69 \$4,394.03 \$557.80 \$3,338.43 \$9,487.95

Documents):

Metro Attorney Service \$354.50 \$4,840.50 \$3,968.50 \$3,099.00 \$12,262.50 Computer Search (Other) \$1,122.21 \$482.45 \$656.82 \$195.12 \$2,456.60 Court Reporting Services \$13,834.30 \$387.00 \$7,008.92 \$0.00 \$21,230.22

Data Base Storage \$219.51 \$0.00 \$0.00 \$0.00 \$219.51 Filing Fee \$0.00 \$14.03 \$0.00 \$0.00 \$14.03 Lexis/On Line Search \$1,248.47 \$2,008.66 \$1,676.23 \$1,765.69 \$6,699.05 Local - Meals \$599.01 \$180.42 \$733.65 \$177.72 \$1,690.80 Local - Parking \$0.00 \$0.00 \$128.00 \$0.00 \$128.00 Local - Taxi \$587.17 \$507.18 \$96.41 \$515.54 \$1,706.30 Lodging \$369.54 \$1,217.02 \$0.00 \$542.79 \$2,129.35 Messenger \$1,692.00 \$0.00 \$768.84 \$0.00 \$2,460.84 Outside Professional Services:

Divergent Language Solutions \$8,838.80 \$0.00 \$0.00 \$0.00 \$8,838.80

Paul Wright \$0.00 \$1,091.59 \$0.00 \$0.00 \$1,091.59

UnitedLex \$44,288.21 \$0.00 \$15,483.80 \$15,564.92 \$75,336.93

Other \$0.00 \$0.00 \$559.00 \$0.00 \$559.00 Postage/Express Mail \$630.54 \$240.56 \$388.08 \$799.56 \$2,058.74 Reproduction Charges \$11,271.68 \$592.80 \$5,381.12 \$2,437.36 \$19,682.96 Reproduction Charges (Color) \$661.00 \$25.80 \$111.80 \$798.60 Retrieval of Corporate Documents:

United Corporate Services \$0.00 \$0.00 \$362.56 \$0.00 \$362.56

TransUnion Risk \$85.00 \$20.00 \$190.00 \$0.00 \$295.00

Other \$0.87 \$60.20 \$0.00 \$0.00 \$61.07 Search Fees \$5.90 \$40.00 \$40.00 \$41.83 \$127.73 Travel Expense \$60.00 \$0.00 \$0.00 \$0.00 \$60.00 Taxi/Ground Transportation \$806.90 \$2,453.13 \$487.70 \$736.65 \$4,484.38 Travel Expense - Meals \$117.78 \$334.46 \$0.00 \$112.61 \$564.85 Travel Expense - Parking \$29.00 \$58.00 \$0.00 \$29.00 \$116.00 UPS/Courier Service \$3,903.39 \$4,317.30 \$3,446.44 \$3,035.66 \$14,702.79 Vendor Expense \$176.12 \$65.00 \$0.00 \$464.00 \$705.12 Westlaw \$5,210.50 \$9,702.52 \$5,073.01 \$3,597.53 \$23,583.56 TOTAL \$97,310.09 \$33,032.65 \$47,118.68 \$36,453.41 \$213,914.83

Luc Despins as Chapter 11 Trustee in thecase of Ho Wan Kwok 200 Park Avenue New York, NY 10166 July 31, 2023 Please Refer to Invoice Number: 2366606

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

General Chapter 11 Trustee Representation

PH LLP Client/Matter # 50687-00001 Nicholas A. Bassett

Legal fees for professional services for the period ending March 31, 2023 \$169,654.50

Total Balance Due - Due Upon Receipt \$172,888.06

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*

Luc Despins as Chapter 11 Trustee in thecase of Ho Wan Kwok 200 Park Avenue New York, NY 10166 July 31, 2023 Please Refer to Invoice Number: 2366606

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

General Chapter 11 Trustee Representation

PH LLP Client/Matter # 50687-00001 Nicholas A. Bassett

Legal fees for professional services for the period ending March 31, 2023 \$169,654.50

Total Balance Due - Due Upon Receipt \$172,888.06

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*

Luc Despins as Chapter 11 Trustee in thecase of Ho Wan

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

FOR PROFESSIONAL SERVICES RENDERED for the period ending March 31, 2023 General Chapter 11 Trustee Representation \$169,654.50

Date Initials Description Hours Rate Amount

03/01/2023 LAD4 T/c S. Sarnoff (O'Melveny) re: update 0.20 1,860.00 372.00 03/02/2023 DM26 Update critical dates calendar and send

03/03/2023 DM26 Update critical dates calendar and send

03/06/2023 DM26 Update critical dates calendar and send

03/06/2023 LAD4 T/c S. Sarnoff (O'Melveny) re: update 0.20 1,860.00 372.00 03/07/2023 AB21 Update list of open issues and workstreams 0.30 1,625.00 487.50 03/07/2023 DM26 Update critical dates calendar and send

03/08/2023 DM26 Update critical dates calendar and send outlook reminders (.9); prepare attorneys' signature block for pleadings filed on behalf of the Chapter 11 Trustee (.3); file via the

03/09/2023 DM26 Update critical dates calendar and send

Date Initials Description Hours Rate Amount

03/09/2023 JK21 Register D. Barron with the court's ECF filing system for Kwok filings 0.60 540.00 324.00 03/10/2023 AB21 Update list of open issues and workstreams 0.20 1,625.00 325.00 03/10/2023 DM26 Update critical dates calendar and send

03/13/2023 DM26 Update critical dates calendar and send

03/14/2023 DM26 Update critical dates calendar and send

03/15/2023 DM26 Update critical dates calendar and send

03/16/2023 AB21 Update call with L. Despins, N. Bassett, S.

case strategy and next steps (0.5); call with D. Barron regarding same (0.2); correspond with L. Despins regarding same (0.3); call with L. Despins regarding same (0.4) 1.40 1,625.00 2,275.00 03/16/2023 DM26 Update critical dates calendar and send

03/16/2023 DEB4 Conference with A. Bongartz regarding case strategy and open workstreams 0.20 1,320.00 264.00 03/16/2023 LAD4 T/c P. Friedman & S. Sarnoff (O'Melveny) re: update (.20); t/c M. Jacobson, B.

(.50); t/c H. Claiborn (US Trustee) re: update (.40); t/c PH team call (D. Barron, N. Bassett, A. Luft, A. Bongartz, S. Maza) re: update (.50); consider strategy in light of change of case direction (1.50); t/c A. Bongartz re: same (.40) 3.50 1,860.00 6,510.00 03/17/2023 AB21 Prepare emergency request for status conference (0.5); correspond with L. Despins regarding same (0.2); call with P. Linsey (Neubert) regarding same (0.1);

(0.1); correspond with P. Linsey regarding

Case 22-50073 Doc 2051 Filed 08/04/23 Entered 08/04/23 18:53:56 Page 84 of 906

Date Initials Description Hours Rate Amount

03/17/2023 AB21 Team update call with L. Despins, N. Bassett, D. Barron regarding strategy and next steps (1.5); update list of open issues and workstreams (0.1) 1.60 1,625.00 2,600.00 03/17/2023 DM26 Update critical dates calendar and send

03/17/2023 LAD4 Team call (D. Barron, A. Bongartz, S. Maza,

summary judgement strategy (1.50); t/c W.

Trustee) re: update on case (.20); t/c I. Goldman (Pullman) re: update (.30);

conference (.30) 2.30 1,860.00 4,278.00 03/17/2023 AEL2 Update meeting with L. Despins, N. Bassett, A. Bongartz, D. Barron, S. Maza,

03/18/2023 LAD4 Review/comment on Lady May forfeiture

03/20/2023 DM26 Update critical dates calendar and send

03/20/2023 LAD4 T/c I. Goldman (Pullman) re: update on case (.30); t/c S. Sarnoff (O'Melveny) re:

03/20/2023 SM29 Analyze counsel's duty to estate and related case law (3.8); correspond with L. Despins re same (.7); call with D. Barron re same (.3) 4.80 1,320.00 6,336.00 03/21/2023 AB21 Update list of open issues and workstreams 0.20 1,625.00 325.00 03/21/2023 DM26 Update critical dates calendar and send

03/21/2023 LAD4 Several calls with S. Sarnoff (O'Melveny) re:

03/21/2023 NAB Revise draft common interest agreement and email regarding same with Jones Day 0.20 1,625.00 325.00 03/22/2023 DM26 Update critical dates calendar and send

Date Initials Description Hours Rate Amount

03/22/2023 DEB4 Correspond with E. Sutton regarding

03/22/2023 LAD4 T/c H. Claiborn (US Trustee) re: BR issues 0.20 1,860.00 372.00 03/22/2023 SM29 Correspond with L. Despins re counsel's duty to estate (.1); review authority re same

03/23/2023 DM26 Update critical dates calendar and send

03/23/2023 ECS1 Update case issues/task list with deadlines and pending matters 2.50 1,015.00 2,537.50 03/24/2023 AB21 Update list of open issues and recent developments (0.2); correspond with N.

court's standing order of reference (0.1) 0.30 1,625.00 487.50 03/24/2023 DM26 Update critical dates calendar and send

03/24/2023 LAD4 T/c S. Sarnoff (O'Melveny) re: update 0.20 1,860.00 372.00 03/27/2023 DM26 Update critical dates calendar and send

03/28/2023 DM26 Update critical dates calendar and send

03/28/2023 JK21 Correspond with S. Maza and P. Linsey (Neubert) regarding procedures for filing with the Court the weekend of April 1 due

03/28/2023 LAD4 T/c S. Sarnoff (O'Melveny) re: update 0.30 1,860.00 558.00 03/28/2023 NAB Review issues/task list and pending

03/28/2023 NAB Telephone conference with J. Rabkin (Jones Day) regarding common interest agreement 0.20 1,625.00 325.00 03/29/2023 DM26 Update critical dates calendar and send

03/30/2023 DM26 Update critical dates calendar and send

03/30/2023 ECS1 Update case issues/task list with deadlines and pending matters 2.90 1,015.00 2,943.50 Case 22-50073 Doc 2051 Filed 08/04/23 Entered 08/04/23 18:53:56 Page 86 of 906

Luc Despins as Chapter 11 Trustee in thecase of Ho Wan Kwok 50687-00001 Invoice No. 2366606

Date Initials Description Hours Rate Amount

03/30/2023 JPK1 Correspond with E. Sutton regarding

03/31/2023 DM26 Update critical dates calendar and send

03/31/2023 DEB4 Analyze and update issues/task list 0.50 1,320.00 660.00 03/31/2023 DEB4 Correspond with E. Sutton regarding

03/31/2023 ECS1 Update case issues/task list 1.20 1,015.00 1,218.00 Subtotal: B110 Case Administration 42.10 49,247.00

03/01/2023 AB21 Review chapter 11 docket update and recent

03/01/2023 DM26 Review recent filings in Kwok case and update working group re same (.5); review recent filings in Despins v. Bravo Luck case and update working group re same (.4); review related case dockets regarding recent

03/02/2023 DM26 Review recent filings in Kwok case and update working group re same (.4); review recent filings in HK USA v. Kwok case and

working group re same (.5); review related case dockets re recent filings (.3) 1.20 540.00 648.00 03/03/2023 DM26 Review recent filings in Kwok case and update working group re same (.6); review recent filings in Despins v. Bravo Luck case

working group re same (.4); review related case dockets regarding recent filings (.3) 1.30 540.00 702.00

Case 22-50073 Doc 2051 Filed 08/04/23 Entered 08/04/23 18:53:56 Page 87 of 906

Date Initials Description Hours Rate Amount

03/06/2023 DM26 Review recent filings in Kwok case and update working group re same (.6); review recent filings in Genever US v. Kwok case

update working group re same (.5); review related case dockets re recent filings (.3) 1.40 540.00 756.00 03/07/2023 DM26 Review recent filings in Kwok case and update working group re same (.5); review recent filings in Genever US v. Kwok case and update working group re same (.1); review related case dockets regarding recent

03/08/2023 DM26 Review recent filings in Kwok case and update working group re same (.5); review

same (.2); review recent filings in Kwok v.

working group re same (.1); review related case dockets regarding recent filings (.3) 1.10 540.00 594.00 03/09/2023 DM26 Review recent filings in Kwok case and update working group re same (.4); review recent filings in Kwok v. Despins District

regarding recent filings (.3) 0.80 540.00 432.00 03/10/2023 DM26 Review recent filings in Kwok case and update working group re same (.7); review

same (1.4); review recent filings in Kwok v. PAX District Court case and Kwok v.

working group re same (.5); review related case dockets regarding recent filings (.2);

upcoming dates (.2) 3.00 540.00 1,620.00

Case 22-50073 Doc 2051 Filed 08/04/23 Entered 08/04/23 18:53:56 Page 88 of 906

Luc Despins as Chapter 11 Trustee in thecase of Ho Wan Kwok 50687-00001 Invoice No. 2366606

Date Initials Description Hours Rate Amount

03/13/2023 DM26 Review recent filings in Kwok case and update working group re same (.5); review recent filings in HK USA v. Kwok case and update working group re same (.8); review related case dockets regarding recent filings

03/14/2023 DM26 Review recent filings in Kwok case and update working group re same (.3); review recent filings in HK USA v. Kwok case and update working group re same (.4); review

regarding recent filings (.3) 1.10 540.00 594.00 03/15/2023 AB21 Review chapter 11 docket update and recent filings (0.1); correspond with L. Despins regarding same (0.1) 0.20 1,625.00 325.00 03/15/2023 DM26 Review recent filings in Kwok case and update working group re same (.2); review recent filings in HK USA v. Kwok case and update working group re same (.2); review related case dockets regarding recent filings

03/16/2023 AB21 Review update on chapter 11 docket and

03/16/2023 DM26 Review recent filings in Kwok case and update working group re same (.4); review recent filings regarding Genever US v.

regarding recent filings (.3) 0.80 540.00 432.00 03/17/2023 AB21 Review update on chapter 11 filings and recent pleadings (0.1); correspond with L.

with N. Bassett and A. Luft regarding same

Case 22-50073 Doc 2051 Filed 08/04/23 Entered 08/04/23 18:53:56 Page 89 of 906

Luc Despins as Chapter 11 Trustee in thecase of Ho Wan Kwok 50687-00001 Invoice No. 2366606

Date Initials Description Hours Rate Amount

03/17/2023 DM26 Review recent filings in Kwok case and update working group re same (.8); review recent filings in HK USA v. Kwok case and

working group re same (.4); review recent

working group re same (.9); review related case dockets regarding recent filings (.3) 2.40 540.00 1,296.00 03/20/2023 DM26 Review recent filings in Kwok case and update working group re same (.5); review recent filings in HK USA v. Kwok case and update working group re same (.6); review

update working group re same (.1); review related case dockets regarding recent filings

03/21/2023 DM26 Review recent filings in Kwok case and update working group re same (.6); review recent filings in Despins v. Bravo Luck case and update working group re same (.4); review recent filings in USA v. Kwok case and update working group re same (.1); review related case dockets regarding recent

03/22/2023 DM26 Review recent filings in Kwok case and update working group re same (.4); review recent filings in Despins v. Bravo Luck case and update working group re same (.1); review recent filings in SEC v. Kwok case and update working group re same (.4); review related case dockets regarding recent

03/23/2023 DM26 Review recent filings in Kwok case and update working group re same (.4); review recent filings in HK USA v. Kwok case and

dockets regarding recent filings (.3) 1.20 540.00 648.00

Case 22-50073 Doc 2051 Filed 08/04/23 Entered 08/04/23 18:53:56 Page 90 of 906

Date Initials Description Hours Rate Amount

03/24/2023 AB21 Review chapter 11 docket update and recent

03/24/2023 DM26 Review recent filings in Kwok case and update working group re same (.7); review

update working group re same (.3); review related case dockets regarding recent filings

03/27/2023 DM26 Review recent filings in Kwok case and update working group re same (.8); review

Genever US v. Kwok case, and Despins v.

group re same (2.1); review recent filings in

regarding recent filings (.3) 3.40 540.00 1,836.00 03/28/2023 DM26 Review recent filings in Kwok case and update working group re same (.5); review

cases, and NY state court cases and update working group re same (1.0); review related case dockets regarding recent filings (.3) 1.80 540.00 972.00 03/29/2023 DM26 Review recent filings in Kwok case and update working group re same (.5); review recent filings in HK USA v. Kwok case and update working group re same (.1); review recent filings in NY state District Court

(.5); review related case dockets regarding recent filings (.3) 1.40 540.00 756.00 03/30/2023 DM26 Review recent filings in Kwok case and update working group re same (.4); review recent filings in HK USA v. Kwok case and update working group re same (.3); review related case dockets regarding recent filings

Case 22-50073 Doc 2051 Filed 08/04/23 Entered 08/04/23 18:53:56 Page 91 of 906

Date Initials Description Hours Rate Amount

03/31/2023 DM26 Review recent filings in Kwok case and

re same (.5); review recent filings in HK USA v. Kwok case and Despins v.

group re same (.4); review recent filings regarding Mei Guo v. Despins Ct. District

update working group re same (.3); review related case dockets regarding recent filings

Subtotal:

03/20/2023 AB21 Prepare hearing notes and related

status conference (3.7); correspond with L.

(0.4); calls with L. Despins regarding same (0.2); call with D. Barron regarding same (0.3); correspond with D. Barron regarding

03/20/2023 LAD4 Review & edit hearing notes for status conference (.40); t/c A. Bongartz re: same 1.80 1,860.00 3,348.00

Case 22-50073 Doc 2051 Filed 08/04/23 Entered 08/04/23 18:53:56 Page 92 of 906

Luc Despins as Chapter 11 Trustee in thecase of Ho Wan Kwok 50687-00001 Invoice No. 2366606

Date Initials Description Hours Rate Amount

03/21/2023 AB21 Attend March 21 status conference (2.7); review and revise presentation for same and hearing notes (1.7); calls with L. Despins regarding same (0.3); correspond with L.

(0.1); conferences with L. Despins regarding preparation for status conference (0.3);

same (0.2); further correspond with L. Despins and N. Bassett regarding same (0.1) 6.10 1,625.00 9,912.50 03/21/2023 LAD4 Review issues and prepare hearing notes

with A. Bongartz, N. Bassett and S. Sarnoff (O'Melveny) re: same (.40) 4.00 1,860.00 7,440.00 Subtotal: B155 Court Hearings 16.60 28,338.00

03/01/2023 AB21 Call and correspond with P. Linsey

reimbursement application 0.10 1,625.00 162.50 03/01/2023 ECS1 Review interested parties in connection with Trustee's supplemental declaration 0.20 1,015.00 203.00 03/02/2023 ECS1 Review interested parties in connection with Trustee's supplemental declaration 0.30 1,015.00 304.50 03/10/2023 AB21 Revise PH Oct., Nov. and Dec. 2022 fee statements (2.2); correspond with C. Edge regarding same (0.3) 2.50 1,625.00 4,062.50 03/13/2023 AB21 Call with C. Edge regarding PH fee 0.10 1,625.00 162.50

03/13/2023 AB21 Call with C. Edge regarding PH fee application for contempt proceedings 03/14/2023 AB21 Begin review of PH January fee statement 1.10 1,625.00 1,787.50

Case 22-50073 Doc 2051 Filed 08/04/23 Entered 08/04/23 18:53:56 Page 93 of 906

Date Initials Description Hours Rate Amount

03/16/2023 AB21 Correspond with J. Kuo regarding request to extend time to file fee application re

(0.3); call and correspond with P. Linsey (Neubert) regarding same (0.1) 0.50 1,625.00 812.50 03/16/2023 JK21 Prepare motion to extend time to file fee application in contempt proceedings 1.10 540.00 594.00 03/17/2023 AB21 Finalize motion to extend time to file fee application (0.1); correspond with L. Despins regarding same (0.2); call with P. Linsey (Neubert) regarding same (0.1);

(0.1); call with K. Traxler regarding fee application (0.1) 0.60 1,625.00 975.00 03/17/2023 KAT2 Call with A. Bongartz regarding contempt order for sanctions in the form of legal fees and costs (.1); review contempt order (.1);

Trustee's fees and costs (.6); correspond with J. Kuo regarding related precedent (.1) 0.90 1,025.00 922.50 03/19/2023 DEB4 Correspond with E. Sutton regarding next declaration in support of retention 0.10 1,320.00 132.00 03/20/2023 JK21 Correspond with K. Traxler regarding fee application in contempt proceedings 0.20 540.00 108.00 03/20/2023 KAT2 Correspond with J. Kuo regarding precedent application for compensation and reimbursement of Trustee's fees and costs per contempt order 0.20 1,025.00 205.00 03/21/2023 AB21 Prepare fifth supplemental declaration in support of PH retention (0.3); correspond with E. Sutton regarding same (0.1); correspond with L. Despins regarding same

03/21/2023 DEB4 Correspond with E. Sutton regarding retention declaration 0.10 1,320.00 132.00

Case 22-50073 Doc 2051 Filed 08/04/23 Entered 08/04/23 18:53:56 Page 94 of 906

Date Initials Description Hours Rate Amount

03/21/2023 ECS1 Analyze parties in interest and connection

declaration (.2); prepare parties in interest list for supplemental declaration (.4) 0.60 1,015.00 609.00 03/21/2023 JK21 Update parties in interest list for retention

03/21/2023 KAT2 Review precedent applications for compensation and reimbursement (.2); prepare special application of Trustee for fees and costs per contempt order (2.1) 2.30 1,025.00 2,357.50 03/22/2023 AB21 Prepare supplemental declaration in support of PH retention (1.4); correspond with L. Despins regarding same (0.3) 1.70 1,625.00 2,762.50 03/22/2023 DEB4 Correspond with A. Bongartz regarding PH supplemental declaration 0.10 1,320.00 132.00 03/22/2023 ECS1 Analyze parties in interest and connection

03/22/2023 JK21 Correspond with A. Bongartz regarding

(0.3); electronically file with the court

03/22/2023 KAT2 Prepare special application of Trustee for fees and costs per contempt order 1.30 1,025.00 1,332.50 03/23/2023 JK21 Correspond with K. Traxler regarding Paul Hastings retention for fee application in connection with contempt order 0.60 540.00 324.00 03/23/2023 KAT2 Prepare special application of Trustee for fees and costs per contempt order (2.8); correspond with J. Kuo regarding same (.2); review and apply local rules regarding same (.3); correspond with A. Bongartz regarding

Case 22-50073 Doc 2051 Filed 08/04/23 Entered 08/04/23 18:53:56 Page 95 of 906

Date Initials Description Hours Rate Amount

03/24/2023 AB21 Correspond with C. Edge regarding PH expenses (0.1); call with C. Edge regarding same (0.1); call with E. Sutton regarding

applications (0.2) 0.40 1,625.00 650.00 03/24/2023 ECS1 Prepare motion to limit service of interim fee and expenses applications (2.3); call with A. Bongartz about same (.2) 2.50 1,015.00 2,537.50 03/24/2023 JK21 Correspond with E. Sutton regarding interim compensation motion 0.40 540.00 216.00 03/25/2023 AB21 Review PH January 2023 fee statement 2.20 1,625.00 3,575.00 03/26/2023 AB21 Review time entries for special fee application (contempt order) (1.5);

03/26/2023 AB21 Revise motion to limit service of fee applications (0.7); correspond with L. Despins regarding same (0.1) 0.80 1,625.00 1,300.00 03/26/2023 AB21 Correspond with J. Kuo regarding parties in

03/26/2023 ECS1 Prepare motion to limit service of interim fee and expense applications 1.10 1,015.00 1,116.50 03/28/2023 AB21 Revise motion to limit service of notice of fee & expense applications (0.3);

regarding same (0.1); correspond with P. Linsey (Neubert) regarding same (0.1) 0.50 1,625.00 812.50 03/29/2023 AB21 Correspond with P. Linsey (Neubert) regarding service of PH expense application

same (0.2); review service list (0.1) 0.40 1,625.00 650.00 03/29/2023 ECS1 Review updated list of interested parties in

disclosure declaration 0.10 1,015.00 101.50 03/29/2023 JK21 Prepare service list for expense reimbursement application (3.1); review and

Case 22-50073 Doc 2051 Filed 08/04/23 Entered 08/04/23 18:53:56 Page 96 of 906

Luc Despins as Chapter 11 Trustee in thecase of Ho Wan Kwok 50687-00001 Invoice No. 2366606

Date Initials Description Hours Rate Amount

03/30/2023 AB21 Revise special fee application regarding fees

Guo (1.0); review related time entries (0.3);

03/30/2023 JK21 Prepare certificate of service regarding Paul

application and notice of hearing 0.60 540.00 324.00 03/31/2023 JK21 Prepare certificate of service regarding Paul

electronic filing (0.2); electronically file with the court certificate of service regarding

application and notice of hearing (0.3) 0.50 540.00 270.00 Subtotal: B160 Fee/Employment Applications 37.40 42,839.00 B165 Fee/Employment Applications for Other Professionals

03/01/2023 AB21 Correspond with L. Despins regarding Pallas retention (0.1); revise engagement

03/01/2023 ECS1 Prepare retention application for Pallas LLP as solicitors in UBS litigation 0.10 1,015.00 101.50 03/02/2023 AB21 Finalize Pallas engagement letter (0.1);

regarding same (0.2); correspond with L. Despins regarding same (0.2); finalize Pallas retention application (0.4); correspond with L. Despins regarding same (0.2); calls with E. Sutton regarding same (0.2); correspond

03/02/2023 DM26 Review and file via the Court's ECF system Trustee's retention application of Pallas

counsel re service of same 0.40 540.00 216.00

Case 22-50073 Doc 2051 Filed 08/04/23 Entered 08/04/23 18:53:56 Page 97 of 906

Luc Despins as Chapter 11 Trustee in thecase of Ho Wan Kwok 50687-00001 Invoice No. 2366606

Date Initials Description Hours Rate Amount

03/02/2023 ECS1 Prepare retention application for Pallas LLP as solicitors in UBS litigation (1.2); calls with A. Bongartz regarding same (.2) 1.40 1,015.00 1,421.00 03/09/2023 AB21 Call with E. Sutton regarding Pallas retention application (0.1); correspond with E. Sutton regarding same (0.1) 0.20 1,625.00 325.00 03/09/2023 ECS1 Review additional disclosures of Pallas

retention of Pallas (.2); call with A. Bongartz about same (.1); correspond with L. Despins about same (.2) 0.50 1,015.00 507.50 03/10/2023 AB21 Correspond with L. Despins regarding Pallas retention application 0.20 1,625.00 325.00 03/10/2023 ECS1 Review additional disclosures of Pallas

retention of Pallas 0.20 1,015.00 203.00 03/22/2023 AB21 Call with K. Mailloux (Epiq) regarding scope of Epiq services 0.30 1,625.00 487.50 03/24/2023 ECS1 Correspond with Pallas Partners regarding

03/25/2023 AB21 Correspond with L. Despins regarding Harneys supplemental disclosures 0.40 1,625.00 650.00 03/28/2023 AB21 Revise Harneys Legal supplemental

regarding same (0.1); correspond with A.

(Harneys Legal) regarding same (0.2) 0.80 1,625.00 1,300.00 03/28/2023 ECS1 Prepare Harneys second supplemental

regarding same (.1) 2.10 1,015.00 2,131.50 03/30/2023 AB21 Review draft Harneys Legal supplemental declaration (0.2); correspond with L. Despins regarding same (0.1) 0.30 1,625.00 487.50 Subtotal: B165 Fee/Employment Applications for

Case 22-50073 Doc 2051 Filed 08/04/23 Entered 08/04/23 18:53:56 Page 98 of 906

Date Initials Description Hours Rate Amount

03/26/2023 AB21 Review draft motion to extend deadline to remove actions to bankruptcy court (0.3);

regarding same (0.1) 0.40 1,625.00 650.00 Subtotal: B191 General Litigation 0.40 650.00

03/21/2023 AB21 Non-working travel to and from

21 status conference (Bill at 1/2 rate) 2.00 812.50 1,625.00 03/21/2023 LAD4 Travel to/from Greenwich/Bridgeport for hearing (Bill at 1/2 rate) 1.40 930.00 1,302.00 Subtotal: B195 Non-Working Travel 3.40 2,927.00

B211 Financial Reports (Monthly Operating Reports)

03/09/2023 DEB4 Correspond with T. Sadler regarding next

03/17/2023 DEB4 Correspond with T. Sadler regarding MOR 0.10 1,320.00 132.00 03/17/2023 TS21 Draft February monthly operating report (1.9); correspond with D. Barron regarding

03/20/2023 DEB4 Correspond with T. Sadler regarding MOR 0.20 1,320.00 264.00 03/20/2023 DEB4 Correspond with A. Bongartz regarding

03/20/2023 DEB4 Review MOR 0.20 1,320.00 264.00 03/20/2023 TS21 Revise February monthly operating report (.4); correspond with D. Barron and L. Despins regarding February monthly 0.60 1,175.00 705.00

Case 22-50073 Doc 2051 Filed 08/04/23 Entered 08/04/23 18:53:56 Page 99 of 906

Luc Despins as Chapter 11 Trustee in thecase of Ho Wan Kwok 50687-00001 Invoice No. 2366606

Date Initials Description Hours Rate Amount

03/21/2023 DM26 File via the Court's ECF system Trustee's monthly operating report for period ended 2/28/23 and correspond with local counsel

03/29/2023 TS21 Correspond with D. Barron re MOR

MOR payments (.5). 0.70 1,175.00 822.50 Subtotal: B211 Financial Reports (Monthly

B310 Claims Administration and Objections

03/01/2023 AB21 Correspond with R. Amporfro (Epiq) regarding order on sealed claims 0.10 1,625.00 162.50

03/01/2023 Conference with claimant 0.30 815.00 244.50 03/03/2023 AB21 Review results of J. Kuo claims analysis (0.3); correspond with L. Despins regarding

03/04/2023 DEB4 Correspond with A. Bongartz regarding

03/06/2023 DEB4 Correspond with claimant regarding claims

03/06/2023 DEB4 Correspond with A. Bongartz regarding

03/07/2023 AB21 Calls with K. Mailleux (Epiq) regarding confidential claims (0.2); correspond with L. Despins regarding same (0.2) 0.40 1,625.00 650.00 03/07/2023 DEB4 Correspond with claimant regarding claims

03/07/2023 DEB4 Correspond with A. Bongartz regarding

03/08/2023 AB21 Correspond with L. Despins regarding scope of Epiq's claims duties 0.60 1,625.00 975.00 03/08/2023 DEB4 Correspond with J. Kuo regarding PAX

Luc Despins as Chapter 11 Trustee in thecase of Ho Wan Kwok 50687-00001 Invoice No. 2366606

Date Initials Description Hours Rate Amount

03/08/2023 LAD4 T/c I. Goldman (Pullman) re: Epiq 0.20 1,860.00 372.00 03/09/2023 DEB4 Correspond with E. Sutton regarding PAX

03/09/2023 JK21 Correspond with E. Sutton regarding filed

03/10/2023 DEB4 Correspond with J. Kuo regarding PAX

03/14/2023 AB21 Correspond with L. Despins regarding Kwok statements related to claims process (0.4); correspond with D. Barron regarding

03/18/2023 DEB4 Correspond with N. Bassett and L. Despins regarding post-petition claim issue 0.10 1,320.00 132.00 03/18/2023 DEB4 Correspond with K. Catalano regarding post-petition claim issue 0.10 1,320.00 132.00 03/19/2023 KC27 Analyze case law regarding post-petition

03/20/2023 DEB4 Correspond with K. Catalano regarding post petition claims issues 0.30 1,320.00 396.00 03/20/2023 KC27 Analyze secondary sources regarding the

against a debtor (2.6); summarize findings

regarding same (.2) 3.60 915.00 3,294.00 03/21/2023 DEB4 Correspond with S. Maza regarding post

03/22/2023 DEB4 Correspond with A. Bongartz regarding

Subtotal: B310 Claims Administration and

Luc Despins as Chapter 11 Trustee in thecase of Ho Wan Kwok 50687-00001 Invoice No. 2366606

ID Timekeeper Name Title Hours Rate Fee

LAD4 Luc A. Despins Partner 13.90 1,860.00 25,854.00 LAD4 Luc A. Despins Partner 1.40 930.00 1,302.00 NAB Nicholas A. Bassett Partner 0.80 1,625.00 1,300.00 AB21 Alex Bongartz Of Counsel 37.90 1,625.00 61,587.50 AB21 Alex Bongartz Of Counsel 2.00 812.50 1,625.00 AEL2 Luft, Avi E. Of Counsel 1.50 1,625.00 2,437.50 KAT2 Katherine A. Traxler Of Counsel 8.10 1,025.00 8,302.50 SM29 Shlomo Maza Associate 5.40 1,320.00 7,128.00 DEB4 Douglass E. Barron Associate 3.60 1,320.00 4,752.00 TS21 Tess Sadler Associate 3.40 1,175.00 3,995.00 ECS1 Ezra C. Sutton Associate 16.10 1,015.00 16,341.50 JPK1 Jon P. Kosciewicz Associate 0.10 915.00 91.50 KC27 Kristin Catalano Associate 4.10 915.00 3,751.50 JK21 Jocelyn Kuo Paralegal 10.40 540.00 5,616.00 DM26 David Mohamed Paralegal 46.90 540.00 25,326.00

Date Description Quantity Rate Amount

03/02/2023 Photocopy Charges 662.00 0.08 52.96 03/02/2023 Photocopy Charges (Color) 662.00 0.20 132.40 03/22/2023 Photocopy Charges 365.00 0.08 29.20 03/22/2023 Photocopy Charges 538.00 0.08 43.04 03/22/2023 Photocopy Charges (Color) 2.00 0.20 0.40 03/22/2023 Photocopy Charges (Color) 21.00 0.20 4.20 03/24/2023 Photocopy Charges 1,262.00 0.08 100.96 03/29/2023 Photocopy Charges 2,825.00 0.08 226.00 03/31/2023 Photocopy Charges 61.00 0.08 4.88 03/01/2023 Computer Search (Other) 33.12 03/02/2023 Computer Search (Other) 11.25

Luc Despins as Chapter 11 Trustee in thecase of Ho Wan Page 21

03/03/2023 Local - Meals - Shlomo Maza; 02/22/2023; Restaurant: Uber Eats; City: New York ; Dinner; Number of people: 1; working late on Kwok matter 20.00

03/06/2023 UPS/Courier Service - Williams Lea Inc., Invoice# GB030-180030827 Dated 03/06/23, London office same day courier charges for period ending 28th

Sainaya Ahluwalia W7, 5 Princes Gate 41.76 03/06/2023 Computer Search (Other) 24.84

03/07/2023 Computer Search (Other) 20.61 03/08/2023 Local - Taxi - Delphine Zhuang; 03/07/2023; From/To: Home - Service Address; Service Type: Taxi; Time: 10:18; Taxi from home to hand deliver

03/08/2023 Local - Taxi - Delphine Zhuang; 03/06/2023; From/To: Office-Service Address-Office; Service Type: Taxi; Time: 10:15; Taxi from and back to

03/10/2023 Computer Search (Other) 24.48

03/11/2023 Computer Search (Other) 14.40

03/13/2023 Computer Search (Other) 55.26 03/14/2023 Computer Search (Other) 65.25

Case 22-50073 Doc 2051 Filed 08/04/23 Entered 08/04/23 18:53:56 Page 103 of 906

Luc Despins as Chapter 11 Trustee in thecase of Ho Wan Page 22

03/16/2023 Local - Taxi - Delphine Zhuang; 01/31/2023; From/To: Office/Service Address; Service Type: Taxi; Time: 15:47; Taxi taken at 15:47 GMT from office for service of original documents 18.76

03/16/2023 Computer Search (Other) 34.29 03/17/2023 Computer Search (Other) 21.06

03/21/2023 Local - Taxi - G. Alexander Bongartz; 01/19/2023; From/To: Office/Home ; Service Type: Uber; Time: 23:12; Working late on matter 110.16 03/21/2023 Local - Taxi - G. Alexander Bongartz; 01/25/2023; From/To: Office/Home ; Service Type: Uber; Time: 23:41; Working late on matter 110.43

03/24/2023 Taxi/Ground Transportation - Vital Transportation Services, Inc. (USD)(JPMSUA); Invoice # 6040466 dated 03/31/2023; Service Type: Car; From/To: Office/Home; Passenger PATRICK, LINDSEY; Ticket # 3726449 dated 03/24/2023 18:03 183.27

03/27/2023 Computer Search (Other) 14.31 03/28/2023 Computer Search (Other) 29.34 03/29/2023 Computer Search (Other) 45.27 03/30/2023 Postage/Express Mail - First Class - US; 85.50

03/31/2023 UPS/Courier Service - UPS (USD)(JPMPCARD); Invoice # 00000A6T163143; 03/31/2023;

PARK ST; LONDON, W 1K6 ;

03/31/2023 Computer Search (Other) 35.37 Case 22-50073 Doc 2051 Filed 08/04/23 Entered 08/04/23 18:53:56 Page 104 of 906

Luc Despins as Chapter 11 Trustee in thecase of Ho Wan Page 23

03/31/2023 Westlaw Business - Courtlink Use - Charges for

Total Costs incurred and advanced \$3,233.56

Total Balance Due - Due Upon Receipt \$172,888.06 Case 22-50073 Doc 2051 Filed 08/04/23 Entered 08/04/23 18:53:56 Page 105 of 906

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 Nicholas A. Bassett

Legal fees for professional services for the period ending March 31, 2023 \$581,432.00

Total Balance Due - Due Upon Receipt \$657,093.63

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 2051 Filed 08/04/23 Entered 08/04/23 18:53:56 Page 106 of 906

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 Nicholas A. Bassett

Legal fees for professional services for the period ending March 31, 2023 \$581,432.00

Total Balance Due - Due Upon Receipt \$657,093.63

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 2051 Filed 08/04/23 Entered 08/04/23 18:53:56 Page 107 of 906

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 July 31, 2023

New York, NY 10166 Invoice Number: 2366607

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

FOR PROFESSIONAL SERVICES RENDERED for the period ending March 31, 2023 Asset Recovery Investigation and Litigation \$581,432.00

Date Initials Description Hours Rate Amount

03/03/2023 AB21 Call and correspond with P. Linsey

03/06/2023 AB21 Call with T. Walsh (CSG), C. Blau (Zeisler),

insurance (0.2); correspond with L. Despins regarding same (0.2) 0.40 1,625.00 650.00 03/06/2023 ECS1 Review protective order in connection with

supplemental objection to motion re repair

03/06/2023 LAD4 T/c UK counsel (N. Richardson, P. Wright)

03/06/2023 LAD4 T/c A. Bongartz, C. Blau (Zeisler) re: Lady

Case 22-50073 Doc 2051 Filed 08/04/23 Entered 08/04/23 18:53:56 Page 108 of 906

Luc Despins as Chapter 11 Trustee in the case of Ho Wan Kwok 50687-00002 Invoice No. 2366607

Date Initials Description Hours Rate Amount 03/07/2023 AB21 Correspond with L. Despins regarding sealing order on supplemental objection to HK USA motion to modify repair reserve order (0.2); revise same (0.1); analyze precedent (0.2); correspond with W. Farmer regarding same (0.1); call and correspond with D. Barron regarding same (0.1); review Lamp Capital management and operation agreement (0.1) 0.80 1,625.00 1,300.00 03/07/2023 DEB4 Conference and correspond with A. Bongartz regarding sealing motion 0.10 1,320.00 132.00 03/08/2023 AB21 Correspond with H. Claiborn (U.S. Trustee) regarding sealing order on supplemental objection to HK USA motion to modify repair reserve order (0.1); call and correspond with P. Linsey (Neubert) regarding same (0.1) 0.20 1,625.00 325.00 03/09/2023 AB21 Correspond with H. Claiborn (U.S. Trustee) regarding proposed order sealing Trustee's supplemental objection to HK USA's motion to modify repair reserve order (0.1); correspond with P. Linsey (Neubert) regarding same (0.1) 0.20 1,625.00 325.00 03/14/2023 AB21 Review HK USA and Mei Guo declarations regarding discovery (0.2); correspond with N. Bassett and A. Luft regarding same (0.1) 0.30 1,625.00 487.50 03/15/2023 AB21 Correspond with L. Despins regarding Lady May update 0.20 1,625.00 325.00 03/15/2023 AB21 Prepare witness and exhibit list for hearing on HK USA motion to modify repair reserve order 1.10 1,625.00 1,787.50 03/15/2023 AB21 Call with D. White (EOCS) regarding Lady May insurance and operating expenses (0.4); correspond with L. Despins regarding same (0.3) 0.70 1,625.00 1,137.50 03/15/2023 AB21 Correspond with L. Despins regarding repair reserve order 0.20 1,625.00 325.00

Case 22-50073 Doc 2051 Filed 08/04/23 Entered 08/04/23 18:53:56 Page 109 of 906

Luc Despins as Chapter 11 Trustee in the case of Ho Wan Kwok 50687-00002 Invoice No. 2366607

Date Initials Description Hours Rate Amount 03/16/2023 AB21 Revise witness and exhibit list for hearing on HK USA motion to modify repair reserve order (0.5); correspond with N. Bassett and W. Farmer regarding same (0.3); correspond with L. Despins regarding same (0.1); call with C. Blau (Zeisler) and T. Walsh (CSG) regarding hearing on HK USA motion (0.2); correspond with L. Despins regarding same (0.1); correspond with C. Blau and T. Walsh regarding same (0.1); call with D. White (EOCS) regarding Lady May operating expenses (0.2) 1.50 1,625.00 2,437.50 03/17/2023 AB21 Revise witness and exhibit list for hearing on HK USA motion to modify repair reserve (0.1); correspond with N. Bassett regarding same (0.1); correspond with P. Linsey (Neubert) regarding same (0.1); call with D. White (EOCS) regarding Lady May insurance (0.1); call with L. Despins and D. White regarding same (0.3); correspond with D. White regarding same (0.1); correspond with C. Blau (Zeisler) regarding same (0.1) 0.90 1,625.00 1,462.50 03/17/2023 LAD4 Review UBS London issues 0.40 1,860.00 744.00 03/17/2023 NAB Correspond with A. Bongartz regarding witness and exhibit list for hearing on motion to modify Lady May repair reserve order 0.20 1,625.00 325.00 03/20/2023 LAD4 T/c N. Richardson (Palas) re: strategy in UBS case 0.40 1,860.00 744.00 03/21/2023 KC27 Analyze case law regarding chapter 11 trustee's duties (.7); prepare motion to modify consent order (3.6) 4.30 915.00 3,934.50 03/22/2023 KC27 Review trustee's objections to HK USA's motion to modify the consent order (.6); review HK USA's motion to modify the consent order (.3); prepare motion to modify consent order (6.5); prepare order for same (.6); correspond with A. Bongartz 8.10 915.00 7,411.50

Case 22-50073 Doc 2051 Filed 08/04/23 Entered 08/04/23 18:53:56 Page 110 of 906

Luc Despins as Chapter 11 Trustee in the case of Ho Wan Kwok 50687-00002 Invoice No. 2366607

Date Initials Description Hours Rate Amount

03/31/2023 LAD4 Review UBS UL matter (.80); prepare notes for settlement call with UBS (.30) 1.10 1,860.00 2,046.00 Subtotal: B120 Asset Analysis and Recovery 22.10 27,482.50

03/02/2023 ECS1 Prepare agenda for March 7, 2023 hearing

03/02/2023 JK21 Prepare reference materials for E. Sutton regarding March 7, 2023 hearing 1.60 540.00 864.00 03/03/2023 AB21 Analyze agenda for March 7 hearing (0.2); call with E. Sutton regarding same (0.1) 0.30 1,625.00 487.50 03/03/2023 ECS1 Prepare agenda for March 7, 2023 hearing in Kwok case (2.1); call with A. Bongartz regarding same (.1) 2.20 1,015.00 2,233.00 03/03/2023 JK21 Prepare reference materials for E. Sutton regarding March 7, 2023 omnibus hearing 0.40 540.00 216.00 03/03/2023 WCF Correspond with E. Sutton regarding

matters (.2); review, revise hearing agenda regarding next week's contested matters (.4) 0.60 1,235.00 741.00 03/04/2023 AB21 Correspond with L. Despins regarding draft agenda for March 7 hearing 0.10 1,625.00 162.50 03/05/2023 ECS1 Prepare agenda for March 7, 2023 hearing

03/05/2023 LAD4 Review/edit agenda for 3/7 hearing (.40); team call (E. Sutton, N. Bassett, W. Farmer, A. Bongartz) re: same (.30) 0.70 1,860.00 1,302.00 03/06/2023 AB21 Prepare hearing notes for supplemental

repair reserve order (0.9); correspond with L. Despins regarding same (0.2); call with E. Sutton regarding protective order (0.1) 1.20 1,625.00 1,950.00

Case 22-50073 Doc 2051 Filed 08/04/23 Entered 08/04/23 18:53:56 Page 111 of 906

Luc Despins as Chapter 11 Trustee in the case of Ho Wan Kwok 50687-00002 Invoice No. 2366607

Date Initials Description Hours Rate Amount

03/06/2023 ECS1 Continue reviewing and preparing hearing materials for March 7 hearing (1.6); call with

03/06/2023 ECS1 Prepare agenda for March 7, 2023 hearing

03/06/2023 JK21 Correspond with E. Sutton regarding March

03/07/2023 DEB4 Correspond with P. Linsey (Neubert) regarding documents for 3-7-23 hearing 0.10 1,320.00 132.00 03/07/2023 LAD4 Review issues & prepare outline for hearing (2.10); handle same (4.30) 6.40 1,860.00 11,904.00 03/07/2023 AEL2 Correspond with N. Bassett re: today's hearing and tomorrow's status conference 1.00 1,625.00 1,625.00 03/20/2023 DEB4 Conference with A. Bongartz regarding March 21 status conference 0.30 1,320.00 396.00 03/20/2023 NAB Correspond with L. Despins regarding status conference and related issues (.2);

hearing on motion to quash subpoena (.2);

investigation target (.1); email with P. Linsey

status conference (.4); email with A.

pending Rule 2004 discovery and adversary proceeding updates in preparation for status conference (.9); analyze authority regarding

Case 22-50073 Doc 2051 Filed 08/04/23 Entered 08/04/23 18:53:56 Page 112 of 906

Luc Despins as Chapter 11 Trustee in the case of Ho Wan Kwok 50687-00002 Invoice No. 2366607

Date Initials Description Hours Rate Amount 03/21/2023 NAB Prepare outlines for status conference, hearing on motion to extend time to comply with motion to compel order, and hearing on motion to extend answer deadline in SN adversary proceeding while travelling to Connecticut (1.8); correspond with L. Despins and S. Sarnoff (O'Melveny) regarding same and related issues (.8) 2.60 1,625.00 4,225.00 03/21/2023 NAB Prepare outline for hearing on March 23 regarding motion to quash subpoenas (.8); correspond with D. Barron regarding same (.3); correspond with W. Farmer regarding case law for same (.2); analyze case law regarding same (.4); review draft response to motion to quash (.1); correspond with P. Linsey (Neubert) regarding same (.1) 1.90 1,625.00 3,087.50 03/21/2023 NAB Participate in hearing and status conference (2.7); post-hearing call with L. Despins, A. Bongartz, S. Sarnoff regarding debrief (.4) 3.10 1,625.00 5,037.50 03/23/2023 AB21 Calls with L. Despins regarding preparation for March 23 hearing (0.2); attend portion of March 23 hearing (1.0) 1.20 1,625.00 1,950.00 03/23/2023 LAD4 Emails to/from A. Bongartz re: hearing today (.30); calls with A. Bongartz re: same (repair reserve) (.20); attend court hearing re: same (1.20) 1.70 1,860.00 3,162.00 03/24/2023 ECS1 Review and prepare reference materials for March 27, 2023 hearing 0.50 1,015.00 507.50 03/25/2023 AB21 Correspond with L. Despins regarding preparation for March 27 hearing 0.10 1,625.00 162.50 03/26/2023 AB21 Prepare hearing notes for hearing on Trustee's motion to modify repair reserve order (2.2); call with L. Despins regarding same (0.1); correspond with L. Despins regarding same (0.2) 2.50 1,625.00 4,062.50

Case 22-50073 Doc 2051 Filed 08/04/23 Entered 08/04/23 18:53:56 Page 113 of 906

Luc Despins as Chapter 11 Trustee in the case of Ho Wan Kwok 50687-00002 Invoice No. 2366607

Date Initials Description Hours Rate Amount

03/27/2023 AB21 Prepare hearing notes for March 27 hearing

reserve motion (1.2); calls with D. White

hearing (3.1); conferences with L. Despins regarding same (.5); correspond with L.

(0.7); conferences with J. Moriarty (Zeisler) regarding order on repair reserve (0.7);

proposed order (0.1) 6.40 1,625.00 10,400.00 Subtotal: B155 Court Hearings 42.40 64,321.00

03/01/2023 DM26 Research regarding certain outside litigation cases relating to the debtor 1.50 540.00 810.00

03/01/2023 JK21 Revise pending appeals chart 0.30 540.00 162.00 03/03/2023 DM26 Research regarding certain outside litigation cases relating to the debtor 1.30 540.00 702.00 03/04/2023 LAD4 T/c S. Sarnoff, P. Friedman (O'Melveny) and N. Bassett re: next steps in our work

03/04/2023 NAB Telephone conference with L. Despins, P.

next steps (.9); follow-up correspondence with L. Despins regarding same (.2) 1.10 1,625.00 1,787.50 03/07/2023 DM26 Research certain filings in state court case D.I. No. 652077/2017 for D. Barron 1.60 540.00 864.00 03/07/2023 DEB4 Correspond with W. Farmer regarding

03/07/2023 JK21 Update summary of pending appeals 0.30 540.00 162.00 03/08/2023 DM26 Review pleadings from outside litigation cases involving debtor and affiliated entities 2.30 540.00 1,242.00 03/14/2023 JK21 Update chart regarding pending appeals 0.60 540.00 324.00

Case 22-50073 Doc 2051 Filed 08/04/23 Entered 08/04/23 18:53:56 Page 114 of 906

Luc Despins as Chapter 11 Trustee in the case of Ho Wan Kwok 50687-00002 Invoice No. 2366607

Date Initials Description Hours Rate Amount

03/14/2023 JK21 Correspond with D. Barron regarding PAX

03/16/2023 DM26 Review case dockets and certain filings in outside litigation cases involving the debtor and his affiliates 3.70 540.00 1,998.00 03/16/2023 DEB4 All hands conference with L. Despins, N.

regarding litigation next steps 0.50 1,320.00 660.00 03/16/2023 DEB4 Correspond with J. Kuo regarding additional Kwok litigation documents 0.30 1,320.00 396.00 03/16/2023 DEB4 Correspond with D. Mohamed regarding next steps in litigation preparation (0.1); analyze documents related to same (0.1) 0.20 1,320.00 264.00 03/16/2023 DEB4 Conference with A. Luft regarding litigation

03/16/2023 JPK1 Summarize matters for which Debtor's counsel requested three-week extension of time (.8); correspond with A. Luft regarding

03/16/2023 AEL2 Meeting with L. Despins, N. Bassett, A.

case strategy and next steps 0.50 1,625.00 812.50 03/17/2023 DM26 Review case dockets and certain filings in outside litigation cases involving the debtor and his affiliates 3.80 540.00 2,052.00 03/17/2023 DEB4 Conference with L. Despins, N. Bassett, A.

regarding litigation next steps 1.50 1,320.00 1,980.00 03/17/2023 JK21 Review document production regarding Kwok related litigation 4.30 540.00 2,322.00 03/17/2023 Conference with L. Despins, N. Bassett, A. Luft, A. Bongartz, D. Barron, and S. Maza regarding case strategy and next steps 1.50 815.00 1,222.50 03/17/2023 NAB Participate in portion of call with L. Despins, A. Bongartz, D. Barron, S. Maza,

regarding next steps in case 0.80 1,625.00 1,300.00 Case 22-50073 Doc 2051 Filed 08/04/23 Entered 08/04/23 18:53:56 Page 115 of 906

Luc Despins as Chapter 11 Trustee in the case of Ho Wan Kwok 50687-00002 Invoice No. 2366607

Date Initials Description Hours Rate Amount

03/20/2023 DEB4 Correspond with J. Kuo regarding Stockil

03/23/2023 NAB Correspond with L. Despins regarding case

03/28/2023 DEB4 Correspond with J. Kuo regarding appeals

Subtotal: B191 General Litigation 29.20 23,138.50

03/24/2023 DEB4 Non-working travel from NY office to DOJ (Bill at 1/2 rate) 0.50 660.00 330.00 03/24/2023 DEB4 Non-working travel from DOJ to NY office (Bill at 1/2 rate) 0.50 660.00 330.00 03/27/2023 AB21 Non-working travel from NY to Bridgeport for March 27 hearing (Bill at 1/2 rate) 2.20 812.50 1,787.50 Subtotal: B195 Non-Working Travel 3.20 2,447.50

03/17/2023 LAD4 T/c D. White (EOCS) & A. Bongartz re: dry dock and next steps 0.30 1,860.00 558.00 03/18/2023 AB21 Correspond with L. Despins regarding Lady

03/20/2023 AB21 Correspond with D. Barron regarding Lady

Lady May insurance (0.3); call with L.

registration documents (0.1); review same 1.00 1,625.00 1,625.00

(0.2); correspond with D. White regarding same (0.1); call with D. White regarding

Case 22-50073 Doc 2051 Filed 08/04/23 Entered 08/04/23 18:53:56 Page 116 of 906

Luc Despins as Chapter 11 Trustee in the case of Ho Wan Kwok 50687-00002 Invoice No. 2366607

Analyze issues related to repair reserve (0.4); correspond with L. Despins regarding same

03/20/2023 DEB4 Correspond with A. Bongartz regarding Lady May personnel 0.10 1,320.00 132.00 03/20/2023 KC27 Review consent order (.3); prepare motion to modify consent order (2.8); call with A. Bongartz regarding same (.2) 3.30 915.00 3,019.50 03/20/2023 LAD4 Consider Lady May funding issues 0.40 1,860.00 744.00 03/21/2023 AB21 Call with L. Despins and D. White (EOCS) regarding Lady May insurance (0.1);

03/22/2023 AB21 Calls with D. White (EOCS) regarding Lady May insurance (0.1); call with D. White and L. Despins regarding same (0.3) 0.40 1,625.00 650.00 03/22/2023 AB21 Review draft motion to modify repair reserve order (0.2); correspond with L.

with J. Moriarity (Zeisler) regarding same

03/22/2023 LAD4 T/c D. White (EOCS) and A. Bongartz re: ownership transitions (.30); review issues related to same (.40) 0.70 1,860.00 1,302.00 03/23/2023 AB21 Revise motion to modify repair reserve order and related pleadings (5.3); correspond with L. Despins regarding same

regarding same (0.2); correspond with T.

with J. Kuo regarding filing of same (0.1) 6.10 1,625.00 9,912.50 03/23/2023 AB21 Call with L. Despins and D. White (EOCS) regarding Lady May insurance 0.10 1,625.00 162.50 03/23/2023 JK21 Electronically file with the court emergency

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Luc Despins as Chapter 11 Trustee in the case of Ho Wan Kwok 50687-00002 Invoice No. 2366607

Date Initials Description Hours Rate Amount

03/23/2023 KC27 Prepare motion to expedite motion to modify consent order (1.4); prepare order for same (.2); correspond with A. Bongartz

modify consent order (1.3) 3.10 915.00 2,836.50 03/23/2023 LAD4 Review/edit repair reserve motion 1.20 1,860.00 2,232.00 03/23/2023 TS21 Correspond with A. Bongartz regarding bank account and repair reserve 0.40 1,175.00 470.00 03/24/2023 AB21 Correspond with D. White (EOCS)

same (0.2); call with T. Sadler regarding

regarding same (0.2) 1.40 1,625.00 2,275.00 03/24/2023 AB21 Correspond with P. Linsey (Neubert)

hearing on motion to modify repair reserve

03/24/2023 LAD4 T/c A. Bongartz re: report on Lady May 0.20 1,860.00 372.00 03/24/2023 TS21 Call with A. Bongartz regarding insurance

applications (1.7). 1.90 1,175.00 2,232.50 03/25/2023 AB21 Call with T. Sadler regarding Lady May insurance (0.1); call with T. Sadler and D. White (EOCS) regarding same (0.5);

(0.2); correspond with L. Despins regarding

insurance form (0.1) 1.10 1,625.00 1,787.50 03/25/2023 TS21 Prep call with A. Bongartz re Lady May insurance application (.1); call with A. Bongartz and D. White regarding same (.5);

summaries and correspondence to A.

revise insurance application (.5). 2.50 1,175.00 2,937.50

Case 22-50073 Doc 2051 Filed 08/04/23 Entered 08/04/23 18:53:56 Page 118 of 906

Date Initials Description Hours Rate Amount

03/26/2023 AB21 Correspond with D. White (EOCS)

with D. White regarding same (0.1); calls with T. Sadler regarding same (0.4);

(0.1); call with L. Despins regarding same (0.1); correspond with L. Despins regarding

03/26/2023 LAD4 T/c A. Bongartz re: Lady May ownership issues and motion re: repair reserve 0.20 1,860.00 372.00 03/26/2023 TS21 Calls with A. Bongartz regarding Lady May insurance policy application (.4); call with

policy application process (.1); review and revise insurance application (.8); correspond with A. Bongartz, L. Despins and D. White regarding insurance application (.4). 1.70 1,175.00 1,997.50 03/27/2023 AB21 Call with L. Despins and R. Stockil

order on Lady May ownership (0.4); correspond with R. Stockill regarding same (0.2); call with D. White (EOCS) regarding

regarding same (0.1) 0.80 1,625.00 1,300.00 03/27/2023 LAD4 Review & edit order re: LM and repair reserve (1.40); t/c Captain of Lady May re: same (.30); t/c R. Stockil (Yachtzoo) and A. 2.60 1,860.00 4,836.00

Bongartz re: management of Lady May (.40); numerous calls and conferences with

Case 22-50073 Doc 2051 Filed 08/04/23 Entered 08/04/23 18:53:56 Page 119 of 906

Luc Despins as Chapter 11 Trustee in the case of Ho Wan Kwok 50687-00002 Invoice No. 2366607

Date Initials Description Hours Rate Amount 03/28/2023 AB21 Call with R. Stockil (Yachtzoo) and D. White (EOCS) regarding Lady May insurance and transition of operations (1.0); review and complete forms for insurers and registry (0.8); correspond with L. Despins regarding same (0.5); follow-up calls with R. Stockil regarding same (0.2); correspond with R. Stockil regarding same (0.2); call with R. Stockil and T. Sadler regarding same (0.1); calls with T. Sadler regarding same (0.3); correspond with T. Sadler regarding same (0.2); review Yachtzoo management agreement (0.4); correspond with L. Despins regarding same (0.2) 3.90 1,625.00 6,337.50 03/28/2023 AB21 Call with E. Sutton regarding motion to authorize service of Lady May sea valves 0.20 1,625.00 325.00 03/28/2023 ECS1 Prepare motion to request authorization to repair Lady May (.1); call with A. Bongartz about same (.2) 0.30 1,015.00 304.50 03/28/2023 LAD4 T/c R. Stockil (Yachtzoo) re: insurance 0.40 1,860.00 744.00 03/28/2023 LAD4 Emails to/from A. Bongartz re: Lady May and related issues 0.30 1,860.00 558.00 03/28/2023 TS21 Calls with A. Bongartz regarding Cayman registry documents (.4); review and comment on Cayman registry forms, application, and bill of sale (2.0); correspond with A. Bongartz and Yatchzoo regarding registry forms (.4). 2.80 1,175.00 3,290.00 03/29/2023 AB21 Call with R. Stockil (Yachtzoo) regarding Lady May II registration (0.1); correspond with R. Stockil regarding same (0.1) 0.20 1,625.00 325.00

Case 22-50073 Doc 2051 Filed 08/04/23 Entered 08/04/23 18:53:56 Page 120 of 906

Luc Despins as Chapter 11 Trustee in the case of Ho Wan Kwok 50687-00002 Invoice No. 2366607

Date Initials Description Hours Rate Amount

03/29/2023 AB21 Prepare issues list for operational transition

with L. Despins regarding same (0.3); revise crew employment agreement (0.3); correspond with L. Despins regarding same (0.1); review dockage agreement (0.1); call

entry into yacht-related agreements (0.2);

03/29/2023 AB21 Call and correspond with D. White (EOCS) regarding sea valve service (0.1); correspond with L. Despins regarding same (0.1); correspond with E. Sutton regarding related

03/29/2023 ECS1 Prepare motion to request authorization to repair Lady May 1.00 1,015.00 1,015.00 03/29/2023 LAD4 Review all day & comment on Lady May ownership issues (legal contracts etc.) (3.70); several emails to/from A. Bongartz re: same

(Bridgeport marina) re: dockage agreement at marina (.30) 4.40 1,860.00 8,184.00 03/29/2023 Conference with A. Bongartz regarding motion to approve entry into yacht related agreements (.2); review related follow up

Case 22-50073 Doc 2051 Filed 08/04/23 Entered 08/04/23 18:53:56 Page 121 of 906

Luc Despins as Chapter 11 Trustee in the case of Ho Wan Kwok 50687-00002 Invoice No. 2366607

Date Initials Description Hours Rate Amount

03/30/2023 AB21 Revise yacht management agreement and crew provision agreement (0.6); calls with L.

with L. Despins regarding same (0.6); call with R. Stockil (Yachtzoo) regarding Lady May II (0.1); review draft motion regarding authorization to enter into yacht-related

regarding same (0.1); review additional Lady

by R. Stockil (0.2) 2.00 1,625.00 3,250.00 03/30/2023 ECS1 Prepare motion to request authorization to repair Lady May 1.50 1,015.00 1,522.50 03/30/2023 LAD4 Continue to review Lady May ownership issues (.60); calls A. Bongartz re: same (.30); emails to/from A. Bongartz re: same (.40); call with A. Bongartz, A. Luft, N. Bassett,

Lady May progress (.80) 2.10 1,860.00 3,906.00 03/30/2023 LAD4 T/c captain of LM re: repairs needed 0.30 1,860.00 558.00 03/30/2023 Conference with A. Bongartz regarding

maintenance of the Lady May (.1); review A. Bongartz comments on draft motion (.1) 0.20 815.00 163.00 03/31/2023 AB21 Analyze certain forms and documents related to Lady May operations, including

appointment (0.9); revise same (0.9); correspond with L. Despins regarding same (0.6); correspond with R. Stockil (Yachtzoo) regarding same (0.6); call with R. Stockil regarding same (0.1); correspond with L.

with T. Sadler regarding same (0.2); call

(0.1); correspond with D. White regarding

03/31/2023 DEB4 Correspond with J. Kosciewicz regarding yacht insurance policy 0.10 1,320.00 132.00 Case 22-50073 Doc 2051 Filed 08/04/23 Entered 08/04/23 18:53:56 Page 122 of 906

Luc Despins as Chapter 11 Trustee in the case of Ho Wan Kwok 50687-00002 Invoice No. 2366607

Date Initials Description Hours Rate Amount

03/31/2023 DEB4 Correspond with N. Bassett regarding yacht

03/31/2023 ECS1 Prepare motion requesting authorization to repair Lady May 1.10 1,015.00 1,116.50 03/31/2023 TS21 Review forms regarding Lady May transfer and ownership (.7); prepare correspondence

Subtotal: B210 Business Operations 63.60 93,467.50

03/04/2023 DEB4 Correspond with L. Despins regrading IRS

03/04/2023 NAB Review IRS subpoena and relevant statutes (.4); correspond with D. Barron, E. Sutton regarding response to same (.2) 0.60 1,625.00 975.00 03/06/2023 DEB4 Correspond with E. Sutton regarding tax

03/06/2023 JPK1 Correspond with N. Bassett regarding subpoena received by the Internal Revenue

regarding the same (.3) 0.50 915.00 457.50 03/06/2023 NAB Correspond with J. Kosciewicz regarding

conference with IRS regarding same (.2); correspond with L. Despins regarding same (.1); correspond with D. Barron regarding review/collection of documents in response

03/23/2023 JPK1 Correspond with S. Phan and I. Davila

regarding the same (.2) 1.00 915.00 915.00 03/24/2023 AG30 Review documents for response to IRS

Case 22-50073 Doc 2051 Filed 08/04/23 Entered 08/04/23 18:53:56 Page 123 of 906

Date Initials Description Hours Rate Amount

03/24/2023 JPK1 Review Rule 2004 document production for responsiveness to IRS summons 0.60 915.00 549.00 03/24/2023 JPK1 Review Rule 2004 production from Raich

03/24/2023 JPK1 Review customized IRS search terms and

03/24/2023 JPK1 Review Rule 2004 productions from Hing

03/24/2023 JPK1 Review Chase Bank Rule 2004 production

(.7); correspond with S. Phan (United Lex) regarding the same (.2); correspond with E. Sutton regarding the same (.2) 1.10 915.00 1,006.50 03/24/2023 JPK1 Correspond with D. Barron regarding IRS

03/24/2023 JPK1 Review TD Bank Rule 2004 production for documents responsive to IRS summons 0.20 915.00 183.00 03/24/2023 JPK1 Review CitiBank Rule 2004 production for documents responsive to IRS summons 0.50 915.00 457.50 03/24/2023 JPK1 Review First Bank of Puerto Rico Rule 2004 discovery for documents responsive to

03/24/2023 JPK1 Review Rule 2004 productions from Debtor for documents responsive to IRS summons 0.60 915.00 549.00 03/24/2023 NAB Email with J. Kosciewicz regarding IRS subpoena response 0.20 1,625.00 325.00 03/27/2023 JPK1 Correspond with N. Bassett regarding documents responsive to IRS summons 0.40 915.00 366.00 03/27/2023 JPK1 Review bank account statements for bank

for responsiveness to IRS summons 1.30 915.00 1,189.50 03/27/2023 JPK1 Review and comment on documents responsive to IRS summons 1.30 915.00 1,189.50

Case 22-50073 Doc 2051 Filed 08/04/23 Entered 08/04/23 18:53:56 Page 124 of 906

Luc Despins as Chapter 11 Trustee in the case of Ho Wan Kwok 50687-00002 Invoice No. 2366607

Date Initials Description Hours Rate Amount

03/28/2023 JPK1 Draft cover letter for document production in response to IRS summons 1.00 915.00 915.00 03/28/2023 JPK1 Review and remove certain documents from the IRS summons production (.3);

03/28/2023 JPK1 Correspond with N. Bassett regarding

emails regarding same to producing parties

03/28/2023 JPK1 Correspond with W. Clark regarding

03/28/2023 NAB Correspond with J. Kosciewicz regarding

protective order and certain documents in connection with same (.2); 0.40 1,625.00 650.00 03/29/2023 JPK1 Correspond with S. Phan (United Lex)

responsive to IRS summons 0.20 915.00 183.00 03/29/2023 JPK1 Draft email to Debtor's counsel regarding

response to IRS summons 0.20 915.00 183.00 03/29/2023 JPK1 Correspond with counsel to M. Francis and

(.7); correspond with P. Linsey regarding the same (.4); correspond with N. Bassett regarding the same (.2) 1.30 915.00 1,189.50

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Luc Despins as Chapter 11 Trustee in the case of Ho Wan Kwok 50687-00002 Invoice No. 2366607

Date Initials Description Hours Rate Amount

03/29/2023 NAB Review proposed production to IRS in response to summons (.4); correspond with J. Kosciewicz regarding same (.3); review

connection with same (.3); review and revise

production and protective order (.2); correspond with IRS regarding same (.1);

drafting summary judgment brief (2.4);

03/30/2023 JPK1 Correspond with Debtor's counsel

documents in response to IRS summons 0.10 915.00 91.50 03/31/2023 JPK1 Correspond with P. Linsey (Neubert) documents responsive to IRS summons 0.20 915.00 183.00 Subtotal: B240 Tax Issues 24.30 26,930.50

03/01/2023 DEB4 Conference with E. Sutton regarding rule 2004 motion and related depositions 0.10 1,320.00 132.00 03/01/2023 DEB4 Correspond with N. Bassett and A. Luft regarding Kwok demonstrations 0.10 1,320.00 132.00 03/01/2023 ECS1 Investigate and review information

connections to Kwok or his affiliates, and their corporate documents 0.10 1,015.00 101.50 03/01/2023 ECS1 Prepare responses regarding rule 2004 motions, meet and confers, and subpoenas 0.40 1,015.00 406.00

to rule 2004 targets 03/01/2023 ECS1 Review and summarize documents produced in response to rule 2004 discovery requests 0.80 1,015.00 812.00 Luc Despins as Chapter 11 Trustee in the case of Ho Wan Kwok 50687-00002 Invoice No. 2366607

Date Initials Description Hours Rate Amount

03/01/2023 ECS1 Review and comment on service of subpoenas on rule 2004 targets 0.40 1,015.00 406.00 03/01/2023 ECS1 Further prepare fourth supplemental rule

03/01/2023 ECS1 Update discovery tracker in connection with rule 2004 discovery and next steps 0.10 1,015.00 101.50 03/01/2023 JK21 Review document production related to

03/01/2023 JPK1 Review Eastern Profit docket for B. Gertz deposition testimony (.4); correspond with D. Barron regarding the same (.1) 0.50 915.00 457.50 03/01/2023 Prepare descriptions and narratives of additional targets for the next rule 2004

03/01/2023 NAB Email with Rule 2004 targets regarding deposition scheduling 0.40 1,625.00 650.00 03/02/2023 DEB4 Correspond with P. Linsey (Neubert) regarding bank discovery 0.10 1,320.00 132.00 03/02/2023 DEB4 Correspond with N. Bassett regarding motion to quash rule 2004 subpoena 0.10 1,320.00 132.00

03/02/2023 ECS1 Investigate and review information

connections to Kwok or his affiliates, and their corporate documents 0.50 1,015.00 507.50 03/02/2023 ECS1 Prepare parts of fourth supplemental rule

03/02/2023 ECS1 Review and summarize documents produced in response to rule 2004 discovery

03/02/2023 LM20 Review documents produced by Hodgson

03/02/2023 Review updated information regarding target companies for rule 2004 motion 0.30 815.00 244.50

Case 22-50073 Doc 2051 Filed 08/04/23 Entered 08/04/23 18:53:56 Page 127 of 906

Luc Despins as Chapter 11 Trustee in the case of Ho Wan Kwok 50687-00002 Invoice No. 2366607

Date Initials Description Hours Rate Amount

03/02/2023 Review and translate twitter posts sent by tipsters relating to Kwok and his entities 0.30 815.00 244.50 03/03/2023 ECS1 Prepare responses regarding rule 2004

to rule 2004 targets 0.10 1,015.00 101.50 03/03/2023 ECS1 Investigate and review information

connections to Kwok or his affiliates, and their corporate documents 0.50 1,015.00 507.50 03/03/2023 ECS1 Review and summarize documents produced in response to rule 2004 discovery

03/03/2023 AEL2 Correspond with W. Farmer re: meet and confer re: motion to quash 0.20 1,625.00 325.00 03/03/2023 AEL2 Review Clark Hill update draft rule 9019

03/03/2023 Review production for account information related to 2012 (0.2); analyze ownership and

of managing the company (2.0); review and translate internal G-series powerpoint in connection with Kwok's control of certain

03/03/2023 NAB Review response to Bravo Luck motion to

correspondence related to same (.3);

regarding discovery issues (.2) 0.70 1,625.00 1,137.50 03/03/2023 WCF Call with M. Freeth and P. Linsey (Neubert) regarding Rule 2004 subpoena compliance 0.40 1,235.00 494.00 03/04/2023 DEB4 Correspond with L. Despins regarding

03/04/2023 DEB4 Correspond with A. Bongartz regarding UK

Date Initials Description Hours Rate Amount

03/04/2023 ECS1 Review and summarize documents produced in response to rule 2004 discovery

03/04/2023 LM20 Review documents produced by Hodgson

03/04/2023 LAD4 Focus on claims against daughter (aircraft

03/05/2023 DEB4 Conference with P. Linsey (Neubert) regarding bank discovery 0.20 1,320.00 264.00 03/05/2023 DEB4 Analysis of Hodgson Russ newly produced

03/05/2023 ECS1 Investigate and review information

connections to Kwok or his affiliates, and their corporate documents 0.10 1,015.00 101.50 03/05/2023 LAD4 Continue analysis of claims against Mei

03/05/2023 Review and translate video posted by Kwok on his Gettr account 0.60 815.00 489.00 03/06/2023 DEB4 Correspond with S. Zhu regarding PRC

03/06/2023 DEB4 Correspond with E. Sutton regarding Lamp

03/06/2023 DEB4 Correspond with J. Kosciewicz regarding

03/06/2023 DEB4 Correspond with S. Sarnoff (O'Melveny) regarding Kwok assets 0.20 1,320.00 264.00 03/06/2023 DEB4 Correspond with P. Linsey (Neubert) regarding bank discovery 0.10 1,320.00 132.00

prepetition litigation 0.10 1,320.00 132.00 03/06/2023 DEB4 Correspond with E. Sutton regarding Prime

Date Initials Description Hours Rate Amount

03/06/2023 DEB4 Correspond with A. Luft regarding HK USA rule 2004 production 0.10 1,320.00 132.00 03/06/2023 DEB4 Analyze documents provided by Goldberg

03/06/2023 DEB4 Correspond with L. Despins regarding documents provided by Goldberg Weprin 0.10 1,320.00 132.00 03/06/2023 ECS1 Prepare responses regarding rule 2004

to rule 2004 targets 0.10 1,015.00 101.50 03/06/2023 ECS1 Review certain background facts in connection with hearing on orders to show

03/06/2023 ECS1 Review and summarize documents produced in response to rule 2004 discovery

03/06/2023 ECS1 Prepare summary of informationon Prime

03/06/2023 ECS1 Investigate and review information

connections to Kwok or his affiliates, and their corporate documents 0.60 1,015.00 609.00 03/06/2023 ECS1 Prepare rule 9019 motion in connection with settlement with of Clark Hill litigation 0.10 1,015.00 101.50 03/06/2023 ECS1 Review pleadings and comments in connection with service of court orders on Golden Spring and Lamp Capital 0.60 1,015.00 609.00 03/06/2023 JK21 Review document production related to

03/06/2023 JPK1 Correspond with C. Fornos regarding Rule 2004 meet and confer 0.10 915.00 91.50 03/06/2023 LAD4 T/c P. Linsey re: discovery against banks 0.20 1,860.00 372.00 03/06/2023 AEL2 Call with J. Storino re: Clark Hill

Case 22-50073 Doc 2051 Filed 08/04/23 Entered 08/04/23 18:53:56 Page 130 of 906

Luc Despins as Chapter 11 Trustee in the case of Ho Wan Kwok 50687-00002 Invoice No. 2366607

production and on filesite regarding Prime

Pangu Plaza (1.5); conference with D.

03/06/2023 Review Mei Guo deposition transcript in

International (3.0); review Chinese law and

Pangu Plaza (1.9); review tipster's email on the transaction involving Prime Trust LLC

03/06/2023 WCF Draft notice of withdrawal of Bravo Luck subpoena (3.2); correspond with P. Linsey, N. Bassett regarding same (0.3) 3.50 1,235.00 4,322.50 03/07/2023 DEB4 Correspond with F. Yu regarding PRC

03/07/2023 DEB4 Correspond with P. Linsey (Neubert) regarding document production 0.10 1,320.00 132.00 03/07/2023 DEB4 Correspond with A. Luft regarding Prime

03/07/2023 DEB4 Correspond with P. Linsey regarding Yvette

03/07/2023 DEB4 Correspond with Z. Zhu regarding PRC

03/07/2023 DEB4 Correspond with E. Sutton regarding bank

03/07/2023 DEB4 Conference with P. Linsey (Neubert) regarding bank discovery 0.20 1,320.00 264.00 03/07/2023 ECS1 Investigate and review information

connections to Kwok or his affiliates, and 0.40 1,015.00 406.00

Case 22-50073 Doc 2051 Filed 08/04/23 Entered 08/04/23 18:53:56 Page 131 of 906

Luc Despins as Chapter 11 Trustee in the case of Ho Wan Kwok 50687-00002 Invoice No. 2366607

Date Initials Description Hours Rate Amount

03/07/2023 JK21 Review document production related to

03/07/2023 JPK1 Prepare for meet and confer (.2); attend Rule 2004 meet and confer with counsel for G Club Operations and W. Farmer (.5) call

same (.3); correspond with A. Luft and W. Farmer regarding the same (.3) 1.30 915.00 1,189.50 03/07/2023 LAD4 Review & edit response for motion to

03/07/2023 AEL2 Correspond with J. Kosciewicz re: G-Club meet and confer strategy 0.30 1,625.00 487.50 03/07/2023 AEL2 Call with W. Farmer and J. Kosciewicz re: report on G-Club meet and confer and next

03/07/2023 Review and translate Kwok's video about real estate he owns 0.20 815.00 163.00 03/07/2023 WCF Draft response regarding Vartan declaration and order to show cause re contempt 1.80 1,235.00 2,223.00 03/07/2023 WCF Participate in rule 2004 meet and confer with J. Kosciewicz and counsel for G Club Operations (.5); call with A. Luft and J. Kosciewicz regarding same (.3); correspond

03/08/2023 DM26 Update information for certain requests for

supplemental rule 2004 motion 0.70 540.00 378.00 03/08/2023 DEB4 Correspond with A. Thorp (Harneys) regarding BVI document authentication 0.10 1,320.00 132.00 03/08/2023 DEB4 Correspond with A. Bongartz regarding

03/08/2023 DEB4 Correspond with J. Kosciewicz regarding HK International documents 0.10 1,320.00 132.00

Case 22-50073 Doc 2051 Filed 08/04/23 Entered 08/04/23 18:53:56 Page 132 of 906

Date Initials Description Hours Rate Amount

03/08/2023 DEB4 Conference with G. Weston (Harneys)

regarding same (0.1); correspond with G. Weston regarding same (0.1) 0.40 1,320.00 528.00 03/08/2023 DEB4 Correspond with N. Bassett regarding

03/08/2023 DEB4 Correspond with G. Weston (Harneys) regarding BVI documents 0.10 1,320.00 132.00 03/08/2023 ECS1 Meet and confer call with M. Conway (Lazare Potter Giacovas & Moyle LLP), E. Goldstein and J. Signor (Goodwin), and J.

2004 discovery (.3); review submissions and open issues in preparation for same (1.0) 1.30 1,015.00 1,319.50 03/08/2023 ECS1 Prepare responses regarding rule 2004

to rule 2004 targets 0.60 1,015.00 609.00 03/08/2023 ECS1 Investigate and review information

connections to Kwok or his affiliates, and their corporate documents 0.90 1,015.00 913.50 03/08/2023 ECS1 Prepare parts of fourth supplemental rule

03/08/2023 JPK1 Correspond with J. Clark regarding consent to share confidential documents (.2);

Rudnick) regarding the same (.4);

regarding the same (.2) 0.80 915.00 732.00 03/08/2023 JPK1 Review issues and notes to prepare for meet and confer (.2); attend Rule 2004 meet and

Himalaya Entities and E. Sutton (.3) 0.50 915.00 457.50 03/08/2023 JPK1 Correspond with E. Sutton regarding Rule

Brown and Himalaya entities 0.30 915.00 274.50

Case 22-50073 Doc 2051 Filed 08/04/23 Entered 08/04/23 18:53:56 Page 133 of 906

Luc Despins as Chapter 11 Trustee in the case of Ho Wan Kwok 50687-00002 Invoice No. 2366607

Date Initials Description Hours Rate Amount

03/08/2023 JPK1 Draft email to producing parties regarding consent to share documents pursuant to the

03/08/2023 LM20 Review documents produced by Hodgson

03/08/2023 LAD4 Review motion to compel drafted by P.

03/09/2023 AB21 Correspond with A. Thorp (Harney's Legal) regarding BVI discovery 0.10 1,625.00 162.50 03/09/2023 DEB4 Correspond with W. Farmer regarding

03/09/2023 DEB4 Correspond with C. Weston (Haneys) regarding BVI document authentication 0.10 1,320.00 132.00 03/09/2023 DEB4 Correspond with L. Despins and S. Sarnoff regarding HK International 0.10 1,320.00 132.00 03/09/2023 DEB4 Correspond with A. Bongartz regarding

03/09/2023 DEB4 Correspond with E. Sutton regarding reliability issue 0.10 1,320.00 132.00 03/09/2023 ECS1 Investigate and review information

connections to Kwok or his affiliates, and their corporate documents 0.60 1,015.00 609.00 03/09/2023 LM20 Correspond with K. Catalano regarding

produced by Hodgson Russ (0.5). 0.60 855.00 513.00 03/10/2023 AB21 Call with D. Barron regarding question related to BVI discovery 0.10 1,625.00 162.50 03/10/2023 DEB4 Correspond with G. Weston (Harneys) regarding BVI documents 0.10 1,320.00 132.00 03/10/2023 DEB4 Correspond with J. Kosciewicz regarding HK international documents 0.10 1,320.00 132.00 03/10/2023 DEB4 Correspond with A. Bongartz regarding

Case 22-50073 Doc 2051 Filed 08/04/23 Entered 08/04/23 18:53:56 Page 134 of 906

Date Initials Description Hours Rate Amount

03/10/2023 DEB4 Conference with G. Weston (Harneys)

regarding same (0.1); correspond with G. Weston regarding same (0.1) 0.40 1,320.00 528.00 03/10/2023 DEB4 Correspond with A. Thorp (Harnys) regarding BVI document authentication 0.10 1,320.00 132.00 03/10/2023 DEB4 Correspond with N. Bassett regarding

03/10/2023 LM20 Review documents produced by Hodgson

regarding the same (0.1) 2.90 855.00 2,479.50 03/10/2023 LAD4 Review court's sanctions order 0.20 1,860.00 372.00 03/11/2023 DEB4 Correspond with L. Despins regarding Qiang Guo rule 2004 discovery 0.10 1,320.00 132.00 03/13/2023 DEB4 Correspond with P. Linsey (Neubert) regarding document production 0.10 1,320.00 132.00 03/13/2023 ECS1 Review and summarize documents produced in response to rule 2004 discovery

03/13/2023 ECS1 Investigate and review information

connections to Kwok or his affiliates, and their corporate documents 0.10 1,015.00 101.50 03/13/2023 Review and translate Kwok's interview in Chinese relating to the Sherry Netherland and additional properties 0.60 815.00 489.00 03/14/2023 AG30 Review documents regarding ownership and formation of certain entity 2.50 915.00 2,287.50 03/14/2023 DEB4 Analyze documents in recent Mei Guo

03/14/2023 DEB4 Correspond with A. Luft regarding aircraft

03/14/2023 DEB4 Correspond with A. Luft regarding Mei

Case 22-50073 Doc 2051 Filed 08/04/23 Entered 08/04/23 18:53:56 Page 135 of 906

Date Initials Description Hours Rate Amount

03/14/2023 DEB4 Correspond with J. Kuo regarding Mei Guo

Mei Guo production 0.10 1,320.00 132.00 03/14/2023 EE3 Research regarding real estate property 0.80 400.00 320.00 03/14/2023 ECS1 Investigate and review information

connections to Kwok or his affiliates, and their corporate documents 0.70 1,015.00 710.50 03/14/2023 JPK1 Review ACASS Rule 2004 production for documents concerning sale of aircraft (.9);

03/14/2023 LM20 Review documents produced by Hodgson

03/14/2023 LAD4 Call with DOJ (R. Finkel, J. Murray, M.

03/14/2023 NAB Call with DOJ (R. Finkel, J. Murray, M. Ferguson) and L. Despins regarding seizure 0.40 1,625.00 650.00 03/15/2023 JK21 Correspond with E. Sutton regarding Kwok

03/15/2023 JPK1 Review debtor's Southern District of New York criminal indictment 0.40 915.00 366.00 03/15/2023 LM20 Review documents produced by Hodgson

03/15/2023 NAB Call with Debtor and counter-defendant counsel regarding Debtor's arrest (.1);

regarding same (.3); review indictment and SEC complaint (.8) 1.20 1,625.00 1,950.00 03/16/2023 AB21 Correspond with D. Barron regarding query from C. Daly regarding address for Q. Guo 0.10 1,625.00 162.50 03/16/2023 DEB4 Correspond with informant regarding information for investigation 0.10 1,320.00 132.00

Date Initials Description Hours Rate Amount

03/16/2023 DEB4 Correspond with A. Bongartz regarding

03/16/2023 DEB4 Correspond with L. Despins regarding Kwok passport allegations 0.10 1,320.00 132.00 03/16/2023 DEB4 Conference with J. Kosciewicz regarding discovery documents 0.10 1,320.00 132.00 03/16/2023 DEB4 Correspond with J. Kosciewicz regarding

03/16/2023 DEB4 Correspond with B. Kelly regarding LLC membership interest 0.10 1,320.00 132.00

03/16/2023 DEB4 Correspond with C. Daly regarding Princess

03/16/2023 EE3 Research information about luxury cars 0.80 400.00 320.00 03/16/2023 JK21 Review document production regarding Kwok related litigation 2.30 540.00 1,242.00 03/16/2023 JPK1 Review produced documents linking Qiang Guo with Princes Castle address (1.0);

03/16/2023 JPK1 Correspond with S. Phan regarding

03/16/2023 JPK1 Review Rule 2004 documents concerning the Debtor having multiple passports (1.0);

03/16/2023 JPK1 Review prior correspondence regarding

regarding the same (.1); correspond with A. Luft regarding the same (.1) 0.60 915.00 549.00 03/16/2023 LAD4 T/c J. Murray & R. Finkel (DOJ) re: briefing on case and next steps (.40); review detention letter (.20) 0.60 1,860.00 1,116.00 03/16/2023 AEL2 Prepare rule 2004 discovery follow up plan 1.30 1,625.00 2,112.50

Date Initials Description Hours Rate Amount

03/16/2023 AEL2 Meet and confer with Zeisler regarding

03/16/2023 AEL2 Correspond with J. Kosciewicz re: motion to compel G club and open rule 2004 issues 0.40 1,625.00 650.00 03/17/2023 AB21 Call with C. Daly regarding update on Kwok case and next steps regarding Q. Guo document discovery 0.20 1,625.00 325.00

Goldberg Weprin document review 0.10 1,320.00 132.00 03/17/2023 JK21 Correspond with S. Maza regarding SEC

03/17/2023 JPK1 Begin drafting motion to compel against G

03/17/2023 LAD4 Review precedents for Chapter 11 trustee and forfeiture master (1.90); t/c S. Maza re:

03/17/2023 AEL2 Correspond with J. Storino (Jenner & Block) re: settlement agreement update 0.10 1,625.00 162.50 03/17/2023 AEL2 Correspond with J. Kosciewicz regarding

03/17/2023 AEL2 Correspond with L. Despins regarding Clark Hill update 0.10 1,625.00 162.50 03/17/2023 AEL2 Analysis re: stipulation impact going

03/17/2023 AEL2 Review and comment on topics for Hodgson Russ deposition 0.30 1,625.00 487.50 03/17/2023 Review Goldberg Weprin production 1.40 815.00 1,141.00 03/17/2023 Conference with D. Barron about reviewing

issues/topics regarding same (.2) 0.30 815.00 244.50 03/17/2023 Review and translate emails from tipster regarding persons and entities related to Kwok and the Sherry Netherland fire 0.80 815.00 652.00

Case 22-50073 Doc 2051 Filed 08/04/23 Entered 08/04/23 18:53:56 Page 138 of 906

Luc Despins as Chapter 11 Trustee in the case of Ho Wan Kwok 50687-00002 Invoice No. 2366607

Date Initials Description Hours Rate Amount

03/17/2023 SM29 Analyze forfeiture issues and related authority (1.0); call with L. Despins re same

03/18/2023 LAD4 Review recent developments and prepare notes for DOJ call (.90); handle call with N. Bassett and DOJ team (J. Murray, M. Fergenson, R. Finkel) re: our next steps and forfeiture issues (.30) 1.20 1,860.00 2,232.00 03/18/2023 LAD4 Review/comment on Lady May forfeiture

03/19/2023 DEB4 Correspond with L. Despins regarding Lady

03/19/2023 DEB4 Correspond with L. Despins regarding investigation target 0.10 1,320.00 132.00

investigation target 0.10 1,320.00 132.00 03/19/2023 DEB4 Correspond with L. Despins regarding

03/20/2023 DEB4 Correspond with N. Bassett regarding

03/20/2023 DEB4 Conferences with W. Zhuge regarding PRC

investigation target 0.20 1,320.00 264.00 03/20/2023 DEB4 Correspond with N. Bassett regarding

03/20/2023 DEB4 Conference with N. Bassett regarding investigation target 0.10 1,320.00 132.00 03/20/2023 DEB4 Correspond with W. Zhuge regarding PRC

03/20/2023 DEB4 Correspond with L. Despins regarding supplemental rule 2004 motion 0.10 1,320.00 132.00 03/20/2023 DEB4 Correspond with informants regarding investigation target 0.30 1,320.00 396.00 03/20/2023 DEB4 Prepare hearing notes on rule 2004

Date Initials Description Hours Rate Amount

03/20/2023 DEB4 Correspond with N. Bassett regarding Rule 2004 investigation 0.20 1,320.00 264.00 03/20/2023 DEB4 Correspond with J. Kosciewicz regarding Rule 2004 updates and open requests 0.20 1,320.00 264.00 03/20/2023 EE3 Research regarding certain court documents related to Kwok case 0.50 400.00 200.00 03/20/2023 JPK1 Continue drafting motion to compel against

03/20/2023 JPK1 Correspond with D. Barron regarding pending Rule 2004 discovery in preparation for status conference 0.40 915.00 366.00 03/20/2023 LAD4 Continue to review & advise re: additional

03/20/2023 LAD4 Common interest call with O'Melveny, Jones Day team, and N. Bassett re: criminal aspects of case & forfeiture 1.10 1,860.00 2,046.00 03/20/2023 Conference with D. Barron regarding

registered in Arizona (.2); prepare follow up notes regarding same (.1) 0.30 815.00 244.50 03/20/2023 NAB Call with L. Despins, O'Melveny team, and

from Kwok criminal case 1.10 1,625.00 1,787.50 03/20/2023 NAB Correspond with P. Linsey (Neubert) and

subpoenas (.2); correspond with J. Moriarty

requested deadline extension (.1) 0.30 1,625.00 487.50 03/21/2023 AB21 Research regarding Y. Wang's address (0.2); correspond with L. Despins regarding same

03/21/2023 DM26 Prepare service to Lamp Capital LLC of

order to show cause re contempt 0.20 540.00 108.00 Case 22-50073 Doc 2051 Filed 08/04/23 Entered 08/04/23 18:53:56 Page 140 of 906

Luc Despins as Chapter 11 Trustee in the case of Ho Wan Kwok 50687-00002 Invoice No. 2366607

Date Initials Description Hours Rate Amount

03/21/2023 DEB4 Correspond with N. Bassett, L. Despins and

investigation update 0.10 1,320.00 132.00 03/21/2023 DEB4 Correspond with L. Despins regarding

03/21/2023 DEB4 Correspond with L. Despins regarding Yvette Wong address 0.10 1,320.00 132.00 03/21/2023 DEB4 Correspond with E. Sutton regarding new Yvette Wong address 0.10 1,320.00 132.00

regarding investigation target 0.10 1,320.00 132.00 03/21/2023 EE3 Research corporate documents for Elesoft

03/21/2023 JK21 Prepare summary of precedent cases regarding settlements with the SEC and the Department of Justice 2.40 540.00 1,296.00 03/21/2023 LAD4 T/c H. Claiborn (US Trustee) re: precedents on forfeiture 0.20 1,860.00 372.00 03/21/2023 Review information about Jiaming Liu and Himalaya Investment LLC 2.00 815.00 1,630.00 03/21/2023 NAB Review and revise draft supplemental Rule

03/21/2023 SM29 Review docket sheets and precedent from J. Kuo re forfeiture issues (1.0); email J. Kuo re summary of same (.1) 1.10 1,320.00 1,452.00 03/21/2023 WCF Analyze authorities regarding burden of proof for motions to quash subpoena 0.40 1,235.00 494.00 03/21/2023 WCF Review case authorities regarding debtors with criminal convictions 0.40 1,235.00 494.00 03/22/2023 DM26 Research regarding pleadings relating to certain outside litigation cases involving debtor and his affiliates 2.50 540.00 1,350.00

Goldberg Weprin production 0.10 1,320.00 132.00 03/22/2023 DEB4 Analyze Brown Rudnick emails 2.20 1,320.00 2,904.00 Case 22-50073 Doc 2051 Filed 08/04/23 Entered 08/04/23 18:53:56 Page 141 of 906

Luc Despins as Chapter 11 Trustee in the case of Ho Wan Kwok 50687-00002 Invoice No. 2366607

Date Initials Description Hours Rate Amount

03/22/2023 DEB4 Correspond with E. Sutton regarding Cahill

03/22/2023 DEB4 Correspond with E. Sutton regarding payments to David Wachen 0.10 1,320.00 132.00 03/22/2023 DEB4 Correspond with E. Sutton regarding service of rule 2004 subpoena 0.10 1,320.00 132.00 03/22/2023 DEB4 Correspond with W. Zhuge regarding informant and contact with same 0.10 1,320.00 132.00 03/22/2023 DEB4 Correspond with E. Sutton regarding

03/22/2023 DEB4 Further correspond with E. Sutton regarding Jiaming Liu 0.10 1,320.00 132.00 03/22/2023 DEB4 Correspond with E. Sutton regarding supplemental rule 2004 motion 0.20 1,320.00 264.00 03/22/2023 DEB4 Correspond with L. Despins regarding Brown Rudnick production 0.10 1,320.00 132.00

investigation target 0.20 1,320.00 264.00 03/22/2023 DEB4 Correspond with N. Bassett regarding

03/22/2023 DEB4 Conference with L. Despins regarding prep for DOJ meeting 0.90 1,320.00 1,188.00 03/22/2023 DEB4 Prepare outline in connection with DOJ

03/22/2023 ECS1 Prepare parts of fourth supplemental rule

03/22/2023 ECS1 Prepare responses to rule 2004 targets in

and confers, and subpoenas 0.50 1,015.00 507.50 03/22/2023 ECS1 Update discovery tracker in connection with rule 2004 motions and next steps 2.00 1,015.00 2,030.00 03/22/2023 ECS1 Review and comment on service of subpoenas on rule 2004 targets 0.20 1,015.00 203.00 03/22/2023 ECS1 Prepare motion to compel compliance with

Case 22-50073 Doc 2051 Filed 08/04/23 Entered 08/04/23 18:53:56 Page 142 of 906

Date Initials Description Hours Rate Amount

03/22/2023 ECS1 Investigate and review information

connections to Kwok or his affiliates, and their corporate documents 0.70 1,015.00 710.50 03/22/2023 ECS1 Research additional countries in which the debtor claims citizenship 0.30 1,015.00 304.50 03/22/2023 ECS1 Review and summarize documents produced in response to rule 2004 requests 0.50 1,015.00 507.50 03/22/2023 JK21 Correspond with A. Bongartz regarding Y.

03/22/2023 JK21 Review precedent settlements with the USA regarding restitution 0.90 540.00 486.00 03/22/2023 JK21 Correspond with S. Maza regarding

agencies (0.6); review precedent pleadings

03/22/2023 JPK1 Correspond with E. Sutton regarding

03/22/2023 LAD4 Meeting with D. Barron re: prep for meeting with DOJ (.90); review issues and prepare notes re: same (1.20) 2.10 1,860.00 3,906.00 03/22/2023 Review information regarding Oasis Tech Limited for supplemental rule 2004 motion 0.30 815.00 244.50 03/22/2023 NAB Review supplemental rule 2004 motion 0.30 1,625.00 487.50 03/22/2023 NAB Prepare outline for hearing on motion to quash (1.1); review and investigate facts

Baker Hostetler and Philips Nizer regarding rule 2004 depositions (.3) 2.40 1,625.00 3,900.00 03/22/2023 SM29 Correspond with L. Despins re forfeiture and seizure issues (.4); analyze case law and statutory authority re same (4.2) 4.60 1,320.00 6,072.00 03/23/2023 AG30 Search database and review documents regarding Kwok citizenship 0.60 915.00 549.00 Case 22-50073 Doc 2051 Filed 08/04/23 Entered 08/04/23 18:53:56 Page 143 of 906

Luc Despins as Chapter 11 Trustee in the case of Ho Wan Kwok 50687-00002 Invoice No. 2366607

Date Initials Description Hours Rate Amount

03/23/2023 DEB4 Correspond with E. Sutton regarding rule

03/23/2023 DEB4 Correspond with J. Kosciewicz regarding

03/23/2023 DEB4 Review updates to supplemental rule 2004

03/23/2023 DEB4 Correspond with E. Sutton regarding payments to Wachen 0.10 1,320.00 132.00 03/23/2023 DEB4 Correspond with W. Farmer and E. Sutton regarding Cahill production 0.20 1,320.00 264.00

Himalaya entities 0.10 1,320.00 132.00

investigation target 0.10 1,320.00 132.00 03/23/2023 DEB4 Correspond with E. Sutton regarding update on rule 2004 investigation 0.10 1,320.00 132.00 03/23/2023 DEB4 Correspond with J. Kuo regarding prepetition litigation research 0.10 1,320.00 132.00 03/23/2023 DEB4 Analyze memo from S. Maza regarding restitution issues 0.40 1,320.00 528.00 03/23/2023 DEB4 Prepare outline for DOJ meeting 0.30 1,320.00 396.00 03/23/2023 DEB4 Correspond with N. Bassett regarding DOJ

03/23/2023 DEB4 Correspond with L. Despins regarding outline for DOJ meeting 0.20 1,320.00 264.00 03/23/2023 DEB4 Analyze documents in connection with

03/23/2023 DEB4 Correspond with N. Bassett regarding DOJ

03/23/2023 ECS1 Update discovery tracker in connection with rule 2004 motions and next steps 0.20 1,015.00 203.00

Case 22-50073 Doc 2051 Filed 08/04/23 Entered 08/04/23 18:53:56 Page 144 of 906

Date Initials Description Hours Rate Amount

03/23/2023 ECS1 Prepare responses to rule 2004 targets

confers, and subpoenas 0.10 1,015.00 101.50 03/23/2023 ECS1 Prepare parts of fourth supplemental rule

03/23/2023 ECS1 Prepare motion to compel compliance with rule 2004 motion (.4); call with J. Kosciewicz about same (.3) 0.70 1,015.00 710.50 03/23/2023 ECS1 Review and summarize documents produced in response to rule 2004 discovery

03/23/2023 ECS1 Investigate and review information

connections to Kwok or his affiliates, and their corporate documents 0.10 1,015.00 101.50 03/23/2023 JK21 Review document production regarding

03/23/2023 JK21 Correspond with L. Despins regarding Kwok and Wang pending criminal cases 0.30 540.00 162.00 03/23/2023 JPK1 Correspond with D. Barron regarding Bombardier plane tail number 0.20 915.00 183.00 03/23/2023 JPK1 Review Rule 2004 investigation update and motion to compel questions from E. Sutton (.3); call with E. Sutton regarding the same and motion to compel (.3) 0.60 915.00 549.00 03/23/2023 JPK1 Incorporate additional targets in second

Group, and Maywind Trading) 5.80 915.00 5,307.00 03/23/2023 LAD4 T/c S. Maza re: forfeiture precedents 0.30 1,860.00 558.00 03/23/2023 Conference with D. Barron regarding names of certain individuals and entities

Case 22-50073 Doc 2051 Filed 08/04/23 Entered 08/04/23 18:53:56 Page 145 of 906

Luc Despins as Chapter 11 Trustee in the case of Ho Wan Kwok 50687-00002 Invoice No. 2366607

Date Initials Description Hours Rate Amount

03/23/2023 NAB Review and supplement draft outline in

03/23/2023 NAB Review and revise draft Rule 2004 motion 0.90 1,625.00 1,462.50 03/23/2023 SM29 Analyze forfeiture issues and related case

same (.2); call with L. Despins re same (.3);

correspond with L. Despins re same (.5) 6.90 1,320.00 9,108.00 03/24/2023 DEB4 Correspond with L. Despins regarding

03/24/2023 DEB4 Correspond with L. Despins regarding intercompany transfers 0.10 1,320.00 132.00 03/24/2023 DEB4 Correspond with J. Kosciewicz regarding rule 2004 document production 0.20 1,320.00 264.00

03/24/2023 DEB4 Attend meeting with DOJ personnel regarding criminal case 1.80 1,320.00 2,376.00 03/24/2023 DEB4 Analyze documents in connection with

03/24/2023 DEB4 Correspond with S. Maza regarding forfeiture issues 0.20 1,320.00 264.00 03/24/2023 ECS1 Prepare responses to rule 2004 targets

confers, and subpoenas 0.20 1,015.00 203.00 03/24/2023 ECS1 Review and comment on service of fourth supplemental rule 2004 motion 0.60 1,015.00 609.00

Case 22-50073 Doc 2051 Filed 08/04/23 Entered 08/04/23 18:53:56 Page 146 of 906

Date Initials Description Hours Rate Amount

03/24/2023 ECS1 Investigate and review information

connections to Kwok or his affiliates, and their corporate documents 0.20 1,015.00 203.00 03/24/2023 ECS1 Review and summarize documents produced in response to rule 2004 discovery

03/24/2023 ECS1 Prepare motion to compel compliance with

03/24/2023 ECS1 Review and comment on service of motions on rule 2004 targets 0.20 1,015.00 203.00 03/24/2023 JK21 Review Kwok-related criminal cases (0.4);

regarding Kwok-related criminal cases (0.3) 0.70 540.00 378.00 03/24/2023 JPK1 Correspond with A. Ganapathi regarding bank personal identifying information 0.10 915.00 91.50 03/24/2023 LAD4 Review issues and prepare outline for DOJ

and N. Bassett (2.40) 5.10 1,860.00 9,486.00 03/24/2023 NAB Review issues and notes to prepare for meeting with Department of Justice (.5); attend meeting with Department of Justice and L. Despins (2.4); correspond with L. Despins and D. Barron regarding same (.4) 3.30 1,625.00 5,362.50 03/25/2023 JK21 Correspond with L. Despins regarding Y.

03/26/2023 LAD4 Review Clark Hill draft settlement agreement (.70); email to counsel for Clark Hill re: same (.30) 1.00 1,860.00 1,860.00 03/27/2023 ECS1 Review and summarize documents produced in response to rule 2004 requests 0.20 1,015.00 203.00 03/27/2023 ECS1 Review and comment on service of rule 2004 motions on targets 0.20 1,015.00 203.00 03/27/2023 JPK1 Draft parts of second omnibus motion to

Date Initials Description Hours Rate Amount

03/27/2023 JPK1 Draft parts of Luft declaration in support of second omnibus motion to compel 2.00 915.00 1,830.00 03/27/2023 JPK1 Correspond with A. Luft regarding Hodgson Russ deposition 0.10 915.00 91.50 03/27/2023 AEL2 Correspond with J. Kosciewicz re: Hodgson

03/27/2023 AEL2 Review Greenwich Land discovery for potential hearing 3.90 1,625.00 6,337.50 03/28/2023 AB21 Correspond with L. Despins regarding Lady May II (0.3); correspond with N. Bassett, D. Barron, and A. Luft regarding same (0.1) 0.40 1,625.00 650.00 03/28/2023 AG30 Prepare for and participate in meeting with

Hodgson Russ deposition 0.30 915.00 274.50 03/28/2023 DM26 Review pleadings in certain outside litigation cases involving the debtor and his affiliates (1.2); email S. Phan (UnitedLex)

certain outside litigation cases (.2) 1.60 540.00 864.00 03/28/2023 DEB4 Correspond with E. Sutton regarding supplemental rule 2004 motion 0.10 1,320.00 132.00 03/28/2023 DEB4 Correspond with A. Luft regarding Yvette

investigation target 0.10 1,320.00 132.00 03/28/2023 DEB4 Correspond with L. Despins regarding Hamilton Investments 0.10 1,320.00 132.00

03/28/2023 DEB4 Conference with P. Linsey (Neubert) regarding Mercantile Bank 0.10 1,320.00 132.00

03/28/2023 DEB4 Conference with J. Kosciewicz and A.

Case 22-50073 Doc 2051 Filed 08/04/23 Entered 08/04/23 18:53:56 Page 148 of 906

Luc Despins as Chapter 11 Trustee in the case of Ho Wan Kwok 50687-00002 Invoice No. 2366607

Date Initials Description Hours Rate Amount

03/28/2023 DEB4 Correspond with L. Despins regarding Lady

03/28/2023 DEB4 Correspond with W. Farmer regarding Gettr documents and issues 0.10 1,320.00 132.00

03/28/2023 DEB4 Correspond with E. Sutton regarding rule

03/28/2023 DEB4 Correspond with P. Friedman (O'Melveny) regarding rule 2004 discovery 0.10 1,320.00 132.00 03/28/2023 DEB4 Conference with W. Zhuge regarding PRC

03/28/2023 DEB4 Correspond with L. Despins regarding Gettr issues / documents 0.10 1,320.00 132.00 03/28/2023 DEB4 Analyze documents related to Gettr 0.50 1,320.00 660.00 03/28/2023 DEB4 Correspond with P. Linsey (Neubert) regarding Mercantile Bank 0.10 1,320.00 132.00 03/28/2023 ECS1 Prepare responses to rule 2004 targets

confers, and subpoenas 0.10 1,015.00 101.50 03/28/2023 ECS1 Review and summarize documents produced in response to rule 2004 requests 0.20 1,015.00 203.00 03/28/2023 ECS1 Prepare list of rule 2004 discovery targets for P. Friedman (O'Melveny) 0.30 1,015.00 304.50 03/28/2023 ECS1 Review certificate of service in connection

03/28/2023 ECS1 Investigate and review information

connections to Kwok or his affiliates, and their corporate documents 0.90 1,015.00 913.50 03/28/2023 ECS1 Call with Bank of Princeton regarding rule

Case 22-50073 Doc 2051 Filed 08/04/23 Entered 08/04/23 18:53:56 Page 149 of 906

Luc Despins as Chapter 11 Trustee in the case of Ho Wan Kwok 50687-00002 Invoice No. 2366607

Date Initials Description Hours Rate Amount

03/28/2023 JK21 Correspond with D. Barron regarding the Sherry Netherlands inspection 0.40 540.00 216.00 03/28/2023 JPK1 Review and revise second omnibus motion to compel and supporting Luft declaration (1.0); correspond with A. Luft regarding the

03/28/2023 JPK1 Draft preliminary statement for second omnibus Rule 2004 motion 0.40 915.00 366.00 03/28/2023 JPK1 Correspond with W. Clark regarding Gettr

03/28/2023 JPK1 Correspond with E. Sutton regarding Kwok's tax identification number 0.20 915.00 183.00 03/28/2023 JPK1 Prepare questions regarding Hodgson Russ deposition (.3); attend teleconference with

Hodgson Russ deposition (.3) 0.60 915.00 549.00 03/28/2023 JPK1 Draft parts of Luft declaration for second omnibus motion to compel 1.90 915.00 1,738.50 03/28/2023 JPK1 Correspond with S. Phan regarding Hodgson Russ search request 0.20 915.00 183.00 03/28/2023 JPK1 Correspond with J. Weddle, counsel for Gettr, regarding Rule 2004 meet and confer 0.10 915.00 91.50 03/28/2023 JPK1 Correspond with E. Sutton regarding Rule

03/28/2023 AEL2 Follow up comments on outstanding rule 2004 discovery requests 0.90 1,625.00 1,462.50 03/28/2023 AEL2 Analysis of proposed settlement terms 0.90 1,625.00 1,462.50 03/28/2023 WCF Review prior meet and confer

confidential informant (.4); correspond with J. Kosciewicz regarding same (.2) 0.60 1,235.00 741.00 03/29/2023 DEB4 Conference with J. Kosciewicz regarding

03/29/2023 DEB4 Conference with A. Luft regarding discovery issues and confidentiality 0.30 1,320.00 396.00 Case 22-50073 Doc 2051 Filed 08/04/23 Entered 08/04/23 18:53:56 Page 150 of 906

Luc Despins as Chapter 11 Trustee in the case of Ho Wan Kwok 50687-00002 Invoice No. 2366607

Date Initials Description Hours Rate Amount

03/29/2023 DEB4 Correspond with E. Sutton regarding rule 2004 motion targets 0.10 1,320.00 132.00 03/29/2023 DEB4 Correspond with P. Linsey regarding Mercantile Bank documents 0.10 1,320.00 132.00

03/29/2023 DEB4 Correspond with J. Kosciewicz regarding rule 2004 motion target (0.1); correspond

regarding same (0.2) 0.30 1,320.00 396.00 03/29/2023 DEB4 Conference with A. Luft regarding confidentiality issues 0.30 1,320.00 396.00 03/29/2023 DEB4 Conference with P. Linsey regarding

03/29/2023 ECS1 Investigate and review information

connections to Kwok or his affiliates, and their corporate documents 0.50 1,015.00 507.50 03/29/2023 ECS1 Call with Bank of Princeton regarding rule

03/29/2023 ECS1 Review certificate of service in connection with fourth supplemental rule 2004 motion 0.20 1,015.00 203.00 03/29/2023 ECS1 Review and summarize documents produced in response to rule 2004 motion 0.30 1,015.00 304.50 03/29/2023 ECS1 Revise Clark Hill settlement agreement 0.30 1,015.00 304.50 03/29/2023 ECS1 Review application of procedural rules regarding appealing a rule 9019 settlement

03/29/2023 ECS1 Review and comment on service of rule 2004 motions on targets 0.10 1,015.00 101.50 03/29/2023 ECS1 Prepare rule 9019 motion in connection with settlement of Clark Hill litigation (2.3); correspond with A. Luft about same (.2) 2.50 1,015.00 2,537.50

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Luc Despins as Chapter 11 Trustee in the case of Ho Wan Kwok 50687-00002 Invoice No. 2366607

Date Initials Description Hours Rate Amount

03/29/2023 JK21 Correspond with L. Despins regarding

03/29/2023 JPK1 Correspond with W. Farmer regarding Rule 2004 meet and confer with Gettr (.2); correspond with counsel to Gettr regarding

03/29/2023 JPK1 Prepare parts of Hodgson Russ deposition

03/29/2023 JPK1 Revise Hodgson Russ deposition outline (2.8); correspond with D. Barron regarding

03/29/2023 JPK1 Research regarding Lady May II and related

03/29/2023 JPK1 Review and summarize 2022 Greenwich Land bank account statements 1.70 915.00 1,555.50 03/29/2023 JPK1 Correspond with S. Phan regarding

Hostetler Rule 2004 productions 0.10 915.00 91.50 03/29/2023 JPK1 Telephone correspondence with D. Barron

documents and deposition outline 0.10 915.00 91.50 03/29/2023 AEL2 Review and comment on outstanding discovery requests 0.30 1,625.00 487.50 03/29/2023 AEL2 Comment on Rule 9019 motion regarding Clark Hill settlement 0.10 1,625.00 162.50 03/29/2023 AEL2 Calls with D. Barron re: confidential information and related letters to Rule 2004

03/29/2023 AEL2 Correspond with W. Farmer re: Gettr meet

03/29/2023 AEL2 Revise Clark Hill settlement agreement 1.90 1,625.00 3,087.50 03/29/2023 AEL2 Revise Rule 9019 motion regarding Clark Hill settlement 3.20 1,625.00 5,200.00 03/29/2023 AEL2 Discovery and deposition plan analysis 1.10 1,625.00 1,787.50 Case 22-50073 Doc 2051 Filed 08/04/23 Entered 08/04/23 18:53:56 Page 152 of 906

Luc Despins as Chapter 11 Trustee in the case of Ho Wan Kwok 50687-00002 Invoice No. 2366607

Date Initials Description Hours Rate Amount

03/29/2023 AEL2 Correspond with D. Barron re: rule 2004 request of Bento Tech 0.40 1,625.00 650.00 03/29/2023 AEL2 Edits to document request re: HK USA

03/29/2023 NAB Correspond with A. Luft regarding pending

03/29/2023 WCF Correspond with J. Kosciewicz, A. Luft,

03/30/2023 DEB4 Correspond with L. Despins regarding

03/30/2023 ECS1 Investigate and review information

connections to Kwok or his affiliates, and their corporate documents 0.10 1,015.00 101.50 03/30/2023 ECS1 Review and comment on service of Rule 2004 motions on targets 0.20 1,015.00 203.00 03/30/2023 ECS1 Prepare rule 9019 motion in connection with settlement of Clark Hill litigation (1.6); correspond with A. Luft about same (.2) 1.80 1,015.00 1,827.00 03/30/2023 AEL2 Call with J. Storino re: settlement terms 0.60 1,625.00 975.00 03/30/2023 AEL2 Prepare parts of Clark Hill Rule 9019

03/30/2023 AEL2 Review and comment on follow up requests

03/31/2023 CD16 Review letters from Harcus Parker to Trustee and to court regarding disclosure of documents (0.4); email L. Despins re same

03/31/2023 DM26 Research registered agent and corporate information pertaining to Silvergate Bank

Luc Despins as Chapter 11 Trustee in the case of Ho Wan Kwok 50687-00002 Invoice No. 2366607

Date Initials Description Hours Rate Amount

03/31/2023 DEB4 Conference with J. Kosciewicz and A. Luft regarding Hodgson Russ deposition 1.10 1,320.00 1,452.00 03/31/2023 DEB4 Correspond with S. Maza regarding civil

03/31/2023 ECS1 Prepare exhibits for upcoming depositions

03/31/2023 ECS1 Review and comment on service of rule 2004 motions on targets 0.40 1,015.00 406.00 03/31/2023 ECS1 Prepare motion to seal Rule 9019 motion regarding Clark Hill settlement 0.30 1,015.00 304.50 03/31/2023 ECS1 Prepare Rule 9019 motion in connection with settlement with Clark Hill 0.70 1,015.00 710.50 03/31/2023 ECS1 Correspond with D. Barron regarding

03/31/2023 JK21 Correspond with L. Despins regarding

03/31/2023 JK21 Research regarding certain applications of Bankruptcy Code section 363(c) 1.30 540.00 702.00 03/31/2023 JK21 Revise Clark Hill rule 9019 motion (2.8); prepare exhibits for Clark Hill rule 9019

03/31/2023 JK21 Further revise Clark Hill rule 9019 motion 0.60 540.00 324.00 03/31/2023 JPK1 Prepare list of search terms for initial Gettr

with Getter and W. Farmer (.8); correspond with W. Farmer regarding the same (.2) 1.50 915.00 1,372.50 03/31/2023 JPK1 Correspond with A. Luft regarding civil RICO questions (.1); correspond with A. Ganapathi regarding the same (.1) 0.20 915.00 183.00 03/31/2023 JPK1 Review certain Hodgson Russ documents

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Luc Despins as Chapter 11 Trustee in the case of Ho Wan Kwok 50687-00002 Invoice No. 2366607

Date Initials Description Hours Rate Amount

03/31/2023 JPK1 Attend teleconference with D. Barron and A. Luft regarding Hodgson Russ deposition

regarding the same (.2) 1.30 915.00 1,189.50 03/31/2023 AEL2 Call with D. Barron and J. Kosciewicz

deposition plan 1.10 1,625.00 1,787.50 03/31/2023 AEL2 Prepare parts of motion to seal Rule 9019

03/31/2023 AEL2 Correspond with W. Farmer and J.

03/31/2023 AEL2 Correspond with E. Sutton re: rule 9019 motion re: Clark Hill settlement 0.40 1,625.00 650.00 03/31/2023 AEL2 Review certain documents and notes to prepare for Hodgson Russ depo prep call 0.40 1,625.00 650.00 03/31/2023 NAB Review filings in Kwok criminal case (.2);

team regarding same (.2) 0.40 1,625.00 650.00 03/31/2023 WCF Attend call with counsel to GETTR and J. Kosciewicz regarding compliance with Rule 2004 subpoena (.8); correspond with J. Kosciewicz regarding same (.3) 1.10 1,235.00 1,358.50 Subtotal:

03/05/2023 NAB Telephone conference with L. Despins, D.

preparation for March 7 hearing (.3); review agenda and documents related to same (.2) 0.50 1,625.00 812.50

03/06/2023 DEB4 Correspond with E. Sutton regarding order to show cause 0.10 1,320.00 132.00 03/06/2023 AEL2 Call with N. Bassett re: discovery contempt issues for tomorrow's hearing 0.40 1,625.00 650.00 Case 22-50073 Doc 2051 Filed 08/04/23 Entered 08/04/23 18:53:56 Page 155 of 906

Luc Despins as Chapter 11 Trustee in the case of Ho Wan Kwok 50687-00002 Invoice No. 2366607

Date Initials Description Hours Rate Amount

03/06/2023 NAB Review and revise response to HK Parties' motion for extension of time (.3); telephone

(.1); review L. Vartan attorney declaration in response to order to show cause (.3);

regarding same (.3) 1.40 1,625.00 2,275.00 03/07/2023 AEL2 Analysis of Vartan arguments on contempt 0.70 1,625.00 1,137.50 03/07/2023 NAB Review and revise draft response to attorney declaration in response to order to show cause (1.4); correspond with P. Linsey

(.3); prepare outline for hearing concerning same and additional issues while in transit to New York (1.1); correspond with L.

authority in preparation for hearing (.9); participate in hearing (4.1); correspond with D. Barron regarding same (.2) 9.10 1,625.00 14,787.50 Subtotal: B262 Contempt Proceedings 12.20 19,794.50

ID Timekeeper Name Title Hours Rate Fee

LAD4 Luc A. Despins Partner 46.50 1,860.00 86,490.00 NAB Nicholas A. Bassett Partner 45.80 1,625.00 74,425.00 AB21 Alex Bongartz Of Counsel 47.60 1,625.00 77,350.00 AB21 Alex Bongartz Of Counsel 2.20 812.50 1,787.50 AEL2 Luft, Avi E. Of Counsel 27.40 1,625.00 44,525.00 CD16 Crispin Daly Associate 0.50 1,320.00 660.00 DEB4 Douglass E. Barron Associate 44.90 1,320.00 59,268.00 DEB4 Douglass E. Barron Associate 1.00 660.00 660.00

Luc Despins as Chapter 11 Trustee in the case of Ho Wan Kwok 50687-00002 Invoice No. 2366607

SM29 Shlomo Maza Associate 13.80 1,320.00 18,216.00

WCF Will C. Farmer Associate 10.20 1,235.00 12,597.00 TS21 Tess Sadler Associate 10.80 1,175.00 12,690.00 ECS1 Ezra C. Sutton Associate 47.80 1,015.00 48,517.00 KC27 Kristin Catalano Associate 18.80 915.00 17,202.00 JPK1 Jon P. Kosciewicz Associate 66.40 915.00 60,756.00 AG30 Anuva V. Ganapathi Associate 3.90 915.00 3,568.50 LM20 Lanie Miliotes Associate 13.30 855.00 11,371.50 JK21 Jocelyn Kuo Paralegal 41.70 540.00 22,518.00 DM26 David Mohamed Paralegal 20.00 540.00 10,800.00

Date Description Quantity Rate Amount

03/01/2023 Photocopy Charges 853.00 0.08 68.24 03/02/2023 Photocopy Charges 35.00 0.08 2.80 03/03/2023 Photocopy Charges 83.00 0.08 6.64 03/03/2023 Photocopy Charges (Color) 37.00 0.20 7.40 03/10/2023 Photocopy Charges 1,355.00 0.08 108.40 03/10/2023 Photocopy Charges 810.00 0.08 64.80 03/10/2023 Photocopy Charges 11,002.00 0.08 880.16 03/10/2023 Photocopy Charges (Color) 704.00 0.20 140.80 03/10/2023 Photocopy Charges (Color) 1,032.00 0.20 206.40 03/13/2023 Photocopy Charges 15,210.00 0.08 1,216.80 03/13/2023 Photocopy Charges 17,444.00 0.08 1,395.52 03/13/2023 Photocopy Charges 1,904.00 0.08 152.32 03/13/2023 Photocopy Charges 1,970.00 0.08 157.60 03/13/2023 Photocopy Charges 2,735.00 0.08 218.80 03/13/2023 Photocopy Charges 2,735.00 0.08 218.80

Luc Despins as Chapter 11 Trustee in the case of Ho Wan Kwok 50687-00002 Invoice No. 2366607

03/13/2023 Photocopy Charges 764.00 0.08 61.12 03/13/2023 Photocopy Charges (Color) 388.00 0.20 77.60 03/14/2023 Photocopy Charges 3,861.00 0.08 308.88 03/14/2023 Photocopy Charges 772.00 0.08 61.76 03/14/2023 Photocopy Charges 792.00 0.08 63.36 03/14/2023 Photocopy Charges (Color) 148.00 0.20 29.60 03/14/2023 Photocopy Charges (Color) 194.00 0.20 38.80 03/20/2023 Photocopy Charges 38.00 0.08 3.04 03/20/2023 Photocopy Charges (Color) 38.00 0.20 7.60 03/21/2023 Photocopy Charges (Color) 76.00 0.20 15.20 03/24/2023 Photocopy Charges 72,284.00 0.08 5,782.72 03/31/2023 Photocopy Charges 93.00 0.08 7.44 01/31/2023 Outside Professional Services - David Mohamed; 01/24/2023; international transaction fee" for purchase of corporate documents from ASIC in Sydney, Australia; Merchant: International transaction 0.87 03/01/2023 Electronic Document Retrieval - TransUnion Risk and Alternative Data Solutions, Inc., Invoice# 1047352-202302-1 Dated 03/01/23, TLO Charges for 2/01/2023-2/28/2023 - Person Search/Advanced 85.00 03/01/2023 Westlaw 196.23 03/01/2023 Westlaw 20.67 03/01/2023 Computer Search (Other) 6.39

Invoice No. 2366607 Luc Despins as Chapter 11 Trustee in the case of Ho Wan Page 52

03/02/2023 Local - Meals - Grubhub Holdings Inc. f/k/a Seamlessweb (USD) (JPMSUA); Invoice # SL-190- 63 dated 03/12/2023; Restaurant: Food Trends Catering; NY Reception; Location: New York; Ordered by C. Pickens on behalf of R. Lupo. NY 6 person lunch (Food Trends) for Deposition of Kwok Case in 26-141 Queensboro.; Luc Despins, Avi Luft, Nick Bassett, Doug Barron, Lee Vartan (CSG), and court reporter C/M: 50687-00002 . Meeting date 3/3/23 ; Order # 678621781067852

03/02/2023 Computer Search (Other) 41.85

03/03/2023 Computer Search (Other) 45.72

03/05/2023 Local - Meals - Ezra Sutton; 02/28/2023; Restaurant: Uber Eats; City: New York ; Dinner; Number of people: 1; work late on Kwok matter 35.78 03/05/2023 Local - Taxi - Ezra Sutton; 02/28/2023; From/To: office/home; Service Type: Uber; Time: 12:37;

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Luc Despins as Chapter 11 Trustee in the case of Ho Wan Page 53

03/06/2023 Computer Search (Other) 53.46 03/07/2023 Court Reporting Services - Veritext, Invoice# 6409661 Dated 03/07/23, Transcript for Witness

03/07/2023 Computer Search (Other) 15.93 03/08/2023 Outside Professional Services - Divergent Language

03/08/23, English to Chinese Interpretation - Ho

03/08/2023 Computer Search (Other) 59.76 03/09/2023 Local - Meals - Ezra Sutton; 03/02/2023; Restaurant: Uber Eats; City: New York ; Dinner; Number of people: 1; work late on Kwok matter 20.00 03/09/2023 Local - Taxi - Ezra Sutton; 03/02/2023; From/To: office/home; Service Type: Uber; Time: 11:09;

Case 22-50073 Doc 2051 Filed 08/04/23 Entered 08/04/23 18:53:56 Page 160 of 906

Luc Despins as Chapter 11 Trustee in the case of Ho Wan Page 54

03/10/2023 Messenger - Requested by Jonathan Kosciewicz; City Expeditor Inc. (USD)(JPMSUA); Invoice # 96416 dated 03/15/2023; From: Paul Hastings Llp; To: Us Bankrupty Court - Southern District Of

Bridgeport Ct 06604; Order # 1563693 dated

03/10/2023 Computer Search (Other) 52.74

03/14/2023 Messenger - Requested by Jocelyn Kuo; City Expeditor Inc. (USD)(JPMSUA); Invoice # 96416 dated 03/15/2023; From: Paul Hastings Llp; To: Luc Despins ; Order # 1564046 dated 3/14/2023

03/14/2023 Messenger - Requested by Jocelyn Kuo; City Expeditor Inc. (USD)(JPMSUA); Invoice # 96416 dated 03/15/2023; From: Paul Hastings Llp; To: Luc Despins - Home; Order # 1564175 dated

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Luc Despins as Chapter 11 Trustee in the case of Ho Wan Page 55

03/14/2023 Local - Meals - Grubhub Holdings Inc. f/k/a Seamlessweb (USD) (JPMSUA); Invoice # SL-190- 64 dated 03/26/2023;

Luft, Doug Barron, Will Farmer; Location: New York; Restaurant: Han Dynasty; trial preparation

03/15/2023 UPS/Courier Service - Office Movers Express aka Washington Express LLC, Invoice# 208692 Dated 03/15/23, Outside Courier Services for WDC

03/16/2023 Computer Search (Other) 75.06 03/17/2023 Messenger - Requested by Jocelyn Kuo; City Expeditor Inc. (USD)(JPMSUA); Invoice # 96594 dated 03/31/2023; From: Luc Despins; To: Paul Hastings Llp 200 Park Avenue Mezz New York Ny 10166; Order # 1564647 dated 3/17/2023 15:45 257.00 03/17/2023 UPS/Courier Service - Keating & Walker Attorney Service, Inc., Invoice# 140995 Dated 03/17/23, attempted service of a Subpoena upon Bravo Luck Limited c/o Francis Lawall at 3000 Two Logan

03/17/2023 Computer Search (Other) 34.92

Luc Despins as Chapter 11 Trustee in the case of Ho Wan Page 56

03/19/2023 Computer Search (Other) 29.43 03/20/2023 UPS/Courier Service - UPS (USD)(JPMPCARD); Invoice # 00000A6T163123; 03/20/2023; Jeffrey Biehn; U.S. Bank National Association; 60 Livingston Street; Saint Paul, MN 551072292 ;

03/20/2023 UPS/Courier Service - UPS (USD)(JPMPCARD); Invoice # 00000A6T163123; 03/20/2023; Global Corporate Tru; U.S. Bank National Association; 185 Asylum Street, 27th Floor; Hartford, CT 061033452

03/21/2023 UPS/Courier Service - UPS (USD)(JPMPCARD); Invoice # 00000A6T163123; 03/21/2023; ; Lamp Capital LLC; c/o CT Corporation System; Ewing, NJ 086281021 ; 1ZA6T1630196749111 (MAN) 24.14 03/21/2023 UPS/Courier Service - UPS (USD)(JPMPCARD); Invoice # 00000A6T163123; 03/21/2023; Captain James Evan P; Bridgeport Harbor Marina; 10 E. Main Street; Bridgeport, CT 066082700 ;

03/21/2023 UPS/Courier Service - UPS (USD)(JPMPCARD); Invoice # 00000A6T163123; 03/21/2023; Attn: Russell Stocki; Yachtzoo LLC; 8000 SW 117th Avenue; Miami, FL 331834809 ;

03/21/2023 UPS/Courier Service - UPS (USD)(JPMPCARD); Invoice # 00000A6T163123; 03/21/2023; National Corporate S; HK International Funds Investments; 203 NE Front Street, Suite 101; Milford, DE 199631431 ; 1ZA6T1630198625303 (MAN) 28.47

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Luc Despins as Chapter 11 Trustee in the case of Ho Wan Page 57

03/21/2023 UPS/Courier Service - UPS (USD)(JPMPCARD); Invoice # 00000A6T163123; 03/21/2023; ATTN:

INTERNATIONAL; 16 CHURCH STREET;

03/21/2023 Local - Meals - Ezra Sutton; 03/09/2023; Restaurant: Mendy's; City: New York; Dinner; Number of people: 1; late work on Kwok matters 37.64 03/21/2023 Local - Taxi - Ezra Sutton; 03/10/2023; From/To: Office/Home ; Service Type: Uber; Time: 23:41;

03/21/2023 Postage/Express Mail - First Class - US; 1.26

03/22/2023 Outside Professional Services - Metro Attorney Service Inc., Invoice# 38198 Dated 03/22/23, Five attempted services of a subpoena on Wencong

03/24/2023 UPS/Courier Service - UPS (USD)(JPMPCARD); Invoice # 00000A6T163133; 03/24/2023; OFFICER, MANAGING OR; CHRISTODOULOS G. VASSILIADES & CO.; 15 AGIOU PAVLOU STREET; NICOSIA, 1105 ;

03/24/2023 UPS/Courier Service - UPS (USD)(JPMPCARD); Invoice # 00000A6T163133; 03/24/2023; Officer, Managing o; Brent Petro Inc.; 108 West 13th St; Wilmington, DE 198011145 ;

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03/24/2023 UPS/Courier Service - UPS (USD)(JPMPCARD); Invoice # 00000A6T163133; 03/24/2023; Officer, Managing o; Ginnel Associates, Inc.; 493 Bedford Center Road; Bedford Hills, NY 105072529 ;

03/24/2023 UPS/Courier Service - UPS (USD)(JPMPCARD); Invoice # 00000A6T163133; 03/24/2023; ; Compass Real Estate; 200 Greenwich Ave; Greenwich, CT 068302506 ; 1ZA6T1630199502265

03/24/2023 UPS/Courier Service - UPS (USD)(JPMPCARD); Invoice # 00000A6T163133; 03/24/2023; Officer, Managing o; Pixshow Film Inc.; 108 West 13th St.; Wilmington, DE 198011145 ;

03/24/2023 UPS/Courier Service - UPS (USD)(JPMPCARD); Invoice # 00000A6T163133; 03/24/2023; ; Alex Hadjicharalambous; 2318 28th Street; Astoria, NY 111052802 ; 1ZA6T1630193087850 (MAN) 28.33 03/24/2023 UPS/Courier Service - UPS (USD)(JPMPCARD); Invoice # 00000A6T163133; 03/24/2023; Daniel J. O'Donnell; The Bank of Princeton; 183 Bayard Lane; Princeton, NJ 085403044 ;

03/24/2023 UPS/Courier Service - UPS (USD)(JPMPCARD); Invoice # 00000A6T163133; 03/24/2023; Officer, Managing o; Metropolitan Commercial Bank; 99

100161621 ; 1ZA6T1630195085483 (MAN) 28.33 03/24/2023 UPS/Courier Service - UPS (USD)(JPMPCARD); Invoice # 00000A6T163133; 03/24/2023; Officer, Managing o; The First Bank of Greenwich; 444 East Putnam Avenue; Cos Cob, CT 068072577 ;

03/24/2023 UPS/Courier Service - UPS (USD)(JPMPCARD); Invoice # 00000A6T163133; 03/24/2023; Martha Jeffery; Sotheby's International Realty; One Pickwick Plaza; Greenwich, CT 068305551 ;

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03/24/2023 UPS/Courier Service - UPS (USD)(JPMPCARD); Invoice # 00000A6T163133; 03/24/2023; ; NRT New England LLC; 6 Landmark Square 4th Floor; Stamford, CT 069012704 ; 1ZA6T1630197532601

03/24/2023 UPS/Courier Service - UPS (USD)(JPMPCARD); Invoice # 00000A6T163133; 03/24/2023; ; Silvergate Bank; 28 Liberty Street; New York, NY 100051400 ; 1ZA6T1630199726925 (MAN) 28.33 03/24/2023 UPS/Courier Service - UPS (USD)(JPMPCARD); Invoice # 00000A6T163133; 03/24/2023; Officer, Managing o; Sirius Networking Inc.; 651 N Broad St.; Middletown, DE 197096402 ;

03/24/2023 UPS/Courier Service - UPS (USD)(JPMPCARD); Invoice # 00000A6T163133; 03/24/2023; Officer, Managing o; FungWan Trading Inc.; 108 West 13th St.; Wilmington, DE 198011145 ;

03/24/2023 UPS/Courier Service - UPS (USD)(JPMPCARD); Invoice # 00000A6T163133; 03/24/2023; ; Zhizhe "Frank" Dong; 44 S. Broadway; White Plains, NY 106014463 ; 1ZA6T1630191654044 (MAN) 28.33 03/24/2023 UPS/Courier Service - UPS (USD)(JPMPCARD); Invoice # 00000A6T163133; 03/24/2023; ; Redfin Corporation; 30 Old Kings Highway South; Darien, CT 068204551 ; 1ZA6T1630191655141 (MAN) 28.33 03/24/2023 UPS/Courier Service - UPS (USD)(JPMPCARD); Invoice # 00000A6T163133; 03/24/2023; Liberty Jet Manageme; c/o American Incorporators Ltd.; 1013 Centre Road, Suite 403-; Wilmington, DE 198051270 ; 1ZA6T1630196943311 (MAN) 28.33 03/24/2023 UPS/Courier Service - UPS (USD)(JPMPCARD); Invoice # 00000A6T163133; 03/24/2023; ; Liberty Jet Management; 29 Schaefer Drive; Ronkonkoma, NY 117797353 ; 1ZA6T1630196583504 (MAN) 28.33

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03/24/2023 UPS/Courier Service - UPS (USD)(JPMPCARD); Invoice # 00000A6T163133; 03/24/2023; ; Sotheby's International; 600 Mamaroneck Avenue, Suite 400; Harrison, NY 105281613 ;

03/24/2023 UPS/Courier Service - UPS (USD)(JPMPCARD); Invoice # 00000A6T163133; 03/24/2023; c/o Bruno J. Gioffre; The First Bank of Greenwich;

105772551 ; 1ZA6T1630195141975 (MAN) 28.33 03/24/2023 UPS/Courier Service - UPS (USD)(JPMPCARD); Invoice # 00000A6T163133; 03/24/2023; Officer, Managing o; Brown Harris Stevens; 445 Park Avenue; New York, NY 100222606 ;

03/24/2023 UPS/Courier Service - UPS (USD)(JPMPCARD); Invoice # 00000A6T163133; 03/24/2023; Officer, Managing o; The Bank of Princeton; 470 W. Cheltenham Avenue; Philadelphia, PA 191263043 ;

03/24/2023 UPS/Courier Service - UPS (USD)(JPMPCARD); Invoice # 00000A6T163133; 03/24/2023; Officer, Managing o; Leading Shine NY Ltd.; 3411 Silverside Road; Wilmington, DE 198104812 ;

03/24/2023 UPS/Courier Service - UPS (USD)(JPMPCARD); Invoice # 00000A6T163133; 03/24/2023; Officer, Managing o; Marcum LLP; 730 3rd Avenue; New

03/24/2023 UPS/Courier Service - UPS (USD)(JPMPCARD); Invoice # 00000A6T163133; 03/24/2023; ; Mercantile Global Holdings, Inc; 16192 Coastal Hwy; Lewes, DE 199583608 ;

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Luc Despins as Chapter 11 Trustee in the case of Ho Wan Page 61

03/24/2023 UPS/Courier Service - UPS (USD)(JPMPCARD); Invoice # 00000A6T163133; 03/24/2023; Officer, Managing o; Huk Trading Inc.; 651 N Broad St; Middletown, DE 197096402 ;

03/24/2023 UPS/Courier Service - UPS (USD)(JPMPCARD); Invoice # 00000A6T163133; 03/24/2023; ; Emile P de Neree; 12 Flying Cloud Rd; Stamford, CT 069027723 ; 1ZA6T1630198601454 (MAN) 35.17 03/24/2023 UPS/Courier Service - UPS (USD)(JPMPCARD); Invoice # 00000A6T163133; 03/24/2023; ; Zhizhe "Frank" Dong; 165 Audubon Ave; New York, NY 100338764 ; 1ZA6T1630199006873 (MAN) 35.17 03/24/2023 UPS/Courier Service - UPS (USD)(JPMPCARD); Invoice # 00000A6T163133; 03/24/2023; ; Martha Jeffery; 80 Northfield St.; Greenwich, CT 068304618 ; 1ZA6T1630190929633 (MAN) 35.17 03/24/2023 UPS/Courier Service - UPS (USD)(JPMPCARD); Invoice # 00000A6T163133; 03/24/2023; ; Min Yang; 10740 Queens Blvd.; Forest Hills, NY 113754211 ; 1ZA6T1630198443492 (MAN) 35.17 03/24/2023 UPS/Courier Service - UPS (USD)(JPMPCARD); Invoice # 00000A6T163133; 03/24/2023; Officer, Managing o; G-EDU -NC c/o Yue Zhou; 301 West 110 Street, Apt. 8E; New York, NY 100264062 ;

03/24/2023 UPS/Courier Service - UPS (USD)(JPMPCARD); Invoice # 00000A6T163133; 03/24/2023; ; Mary Dowdle; 41 Smith Road; Sharon, CT 060692401 ;

03/24/2023 UPS/Courier Service - UPS (USD)(JPMPCARD); Invoice # 00000A6T163133; 03/24/2023; Officer, Managing o; Sotheby's International; 3290

303272216 ; 1ZA6T1630194562950 (MAN) 51.87

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03/24/2023 UPS/Courier Service - UPS (USD)(JPMPCARD); Invoice # 00000A6T163133; 03/24/2023; Officer, Managing or; Medici Bank International LLC; 1250 Ponce de Leon Avenue; San Juan, PR 00907 ;

03/24/2023 UPS/Courier Service - UPS (USD)(JPMPCARD); Invoice # 00000A6T163133; 03/24/2023; Officer, Managing o; Mercantile Global Holdings, Inc.; 4306 Yoakum Blvd, Suite 200; Houston, TX 770065873 ;

03/24/2023 UPS/Courier Service - UPS (USD)(JPMPCARD); Invoice # 00000A6T163133; 03/24/2023; Officer, Managing or; Mercantile Bank International Corp.; 604 Hoare Street; San Juan, PR 009073614 ;

03/24/2023 UPS/Courier Service - UPS (USD)(JPMPCARD); Invoice # 00000A6T163133; 03/24/2023; ; Alex Hadjicharalambous; 2318 28th Street; Astoria, NY 111052802 ; 1ZA6T1630193087850 (MAN) 6.84 03/24/2023 UPS/Courier Service - UPS (USD)(JPMPCARD); Invoice # 00000A6T163133; 03/24/2023; Officer, Managing o; HHS Capital Inc.; 14660 SW 14 St.; Pembroke Pines, FL 330276508 ;

03/24/2023 UPS/Courier Service - UPS (USD)(JPMPCARD); Invoice # 00000A6T163133; 03/24/2023; Officer, Managing o; Prime Trust LLC; 330 S Rampart Blvd., Suite 260; Las Vegas, NV 891455754 ;

03/24/2023 UPS/Courier Service - UPS (USD)(JPMPCARD); Invoice # 00000A6T163133; 03/24/2023; Officer, Managing o; Redfin Corporation; 1099 Stewart Street, Suite 600; Seattle, WA 981012161 ;

03/24/2023 UPS/Courier Service - UPS (USD)(JPMPCARD); Invoice # 00000A6T163133; 03/24/2023; ; Prime Trust LLC; 3800 N Central Avenue; Phoenix, AZ 850121995 ; 1ZA6T1630195836466 (MAN) 62.23

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03/24/2023 UPS/Courier Service - UPS (USD)(JPMPCARD); Invoice # 00000A6T163133; 03/24/2023; ; Lihong Wei Lafrenz; 1850 W Orange Grove Rd.; Tucson, AZ 857041129 ; 1ZA6T1630197110414 (MAN) 62.23

03/24/2023 UPS/Courier Service - UPS (USD)(JPMPCARD); Invoice # 00000A6T163133; 03/24/2023; Officer, Managing o; GFashion Media Group Inc.; 5901 W. Century Blvd., #750; Los Angeles, CA 900455443 ;

03/24/2023 UPS/Courier Service - UPS (USD)(JPMPCARD); Invoice # 00000A6T163133; 03/24/2023; ; Lihong Wei Lafrenz; 14747 N Northsight Blvd; Scottsdale, AZ 852602633 ; 1ZA6T1630193936165 (MAN) 62.23 03/24/2023 UPS/Courier Service - UPS (USD)(JPMPCARD); Invoice # 00000A6T163133; 03/24/2023; Officer, Managing o; Medical Supply System; 3101 N. Central Ave; Phoenix, AZ 850122645 ;

03/24/2023 UPS/Courier Service - UPS (USD)(JPMPCARD); Invoice # 00000A6T163133; 03/24/2023; Officer, Managing o; RBB Bancorp; 1055 Wilshire Blvd.; Los Angeles, CA 900172424 ;

03/24/2023 UPS/Courier Service - UPS (USD)(JPMPCARD); Invoice # 00000A6T163133; 03/24/2023; Officer, Managing o; Open Bank; 1000 Wilshire Blvd.; Los Angeles, CA 900172462 ; 1ZA6T1630199365691

03/24/2023 UPS/Courier Service - UPS (USD)(JPMPCARD); Invoice # 00000A6T163133; 03/24/2023; ; Ding G. Wang; 7636 Heavenly Peak St.; Las Vegas, NV 891665202 ; 1ZA6T1630199781437 (MAN) 75.57 03/24/2023 UPS/Courier Service - UPS (USD)(JPMPCARD); Invoice # 00000A6T163133; 03/24/2023; ; Qing Serena" Cai; 7636 Heavenly Peak St.; Las Vegas, NV 891665202 ; 1ZA6T1630195752029 (MAN) 75.57

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03/24/2023 UPS/Courier Service - UPS (USD)(JPMPCARD); Invoice # 00000A6T163133; 03/24/2023;

03/24/2023 UPS/Courier Service - UPS (USD)(JPMPCARD); Invoice # 00000A6T163133; 03/24/2023; DAVID FALLON; DAVID FALLON; UXBRIDGE RD;

03/24/2023 Postage/Express Mail - First Class - US; 165.25 03/24/2023 Postage/Express Mail - First Class - US; 17.85 03/24/2023 Postage/Express Mail - International; 316.40 03/24/2023 Postage/Express Mail - First Class - US; 36.90 03/25/2023 UPS/Courier Service - UPS (USD)(JPMPCARD); Invoice # 00000A6T163133; 03/25/2023;

LYFORD CAY; NASSAU, 10250 ;

03/25/2023 UPS/Courier Service - UPS (USD)(JPMPCARD); Invoice # 00000A6T163133; 03/25/2023;

ROAD; TSIMSHATSUI, 16000 ;

03/25/2023 Local - Meals - Ezra Sutton; 03/14/2023; Restaurant: Mendy's; City: New York; Lunch; Number of people: 1; work on Kwok matters 33.65

03/27/2023 Airfare - Nick Bassett; 03/06/2023; From/To: DCA/LGA; Airfare Class: Economy; Travel to

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03/27/2023 Travel Expense - Meals - Nick Bassett; 03/07/2023; Restaurant: Kavaldi Coffee and Breakfast; City: Bridgeport; Number of people: 1; Travel to New York and Connecticut for client meetings 34.25

03/27/2023 UPS/Courier Service - UPS (USD)(JPMPCARD); Invoice # 00000A6T163133; 03/27/2023; ; PAUL

NY 10166 ; 1ZA6T1631299006870 (MAN) 34.49 03/27/2023 UPS/Courier Service - UPS (USD)(JPMPCARD); Invoice # 00000A6T163133; 03/27/2023; ; PAUL

NY 10166 ; 1ZA6T1631297657519 (MAN) 34.49 03/27/2023 UPS/Courier Service - UPS (USD)(JPMPCARD); Invoice # 00000A6T163133; 03/27/2023; ; PAUL

NY 10166 ; 1ZA6T1631298083744 (MAN) 34.49 03/27/2023 UPS/Courier Service - UPS (USD)(JPMPCARD); Invoice # 00000A6T163133; 03/27/2023; ; PAUL

NY 10166 ; 1ZA6T1631297684534 (MAN) 34.49 03/27/2023 Taxi/Ground Transportation - Nick Bassett;

Meeting/LGA; Service Type: Uber; Time: 17:30; Travel to New York and Connecticut for client

03/27/2023 Taxi/Ground Transportation - Nick Bassett;

Meeting; Service Type: Uber; Time: 09:47; Travel to New York and Connecticut for client meetings 200.14 03/27/2023 Travel Expense - Parking - Nick Bassett; 03/07/2023; Travel to New York and Connecticut

03/27/2023 Computer Search (Other) 65.70

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03/28/2023 UPS/Courier Service - UPS (USD)(JPMPCARD); Invoice # 00000A6T163133; 03/28/2023;

03/28/2023 UPS/Courier Service - UPS (USD)(JPMPCARD); Invoice # 00000A6T163133; 03/28/2023;

LIMITED; 51 JOSEPH BANKS DRIVE;

03/28/2023 UPS/Courier Service - UPS (USD)(JPMPCARD); Invoice # 00000A6T163133; 03/28/2023;

STREET; SOUTHBANK, 3006 ;

03/28/2023 UPS/Courier Service - UPS (USD)(JPMPCARD); Invoice # 00000A6T163143; 03/28/2023; Officer, Managing o; Mercantile Global Holdings, Inc.; 4306 Yoakum Blvd, Suite 200; Houston, TX 77006 ;

03/28/2023 UPS/Courier Service - UPS (USD)(JPMPCARD); Invoice # 00000A6T163143; 03/28/2023; ; Lihong Wei Lafrenz; 1850 W Orange Grove Rd.; Tucson, AZ 85704 ; 1ZA6T1631297110411 (MAN) 30.26 03/28/2023 UPS/Courier Service - UPS (USD)(JPMPCARD); Invoice # 00000A6T163133; 03/28/2023;

YUEN ST; MONGKOK, 30000 ;

03/28/2023 Computer Search (Other) 16.56 03/29/2023 Airfare - Nick Bassett; 03/13/2023; From/To: PBJ/LGA; Airfare Class: Economy; Travel to New York and Connecticut for client meetings. 304.90

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Luc Despins as Chapter 11 Trustee in the case of Ho Wan Page 67

03/29/2023 Travel Expense - Meals - Nick Bassett; 03/14/2023; Restaurant: Pita Yeero Vanderbilt ; City: New York; Lunch; Number of people: 1; Travel to New York and Connecticut for client meetings 17.15

03/29/2023 Travel Expense - Meals - Nick Bassett; 03/16/2023; Restaurant: LGA Beechers; City: New York; Lunch; Number of people: 1; Travel to New York and

03/29/2023 Travel Expense - Meals - Nick Bassett; 03/15/2023; Restaurant: Kavaldi Coffee ; City: Bridgeport; Breakfast; Number of people: 1; Travel to New York and Connecticut for client meetings 21.90 03/29/2023 Travel Expense - Meals - Nick Bassett; 03/15/2023; Restaurant: Kavaldi Coffee ; City: Bridgeport; Breakfast; Number of people: 1; Travel to New York and Connecticut for client meetings. 25.00 03/29/2023 Lodging - Nick Bassett; 03/14/2023; Hotel: Hyatt; Check-in date: 03/13/2023; Check-out date: 03/14/2023; City: New York; Travel to New York and Connecticut for client meetings. 369.54 03/29/2023 UPS/Courier Service - UPS (USD)(JPMPCARD); Invoice # 00000A6T163133; 03/29/2023; ; The Bank of Princeton; 470 W. Cheltenham Avenue; Philadelphia, PA 191263043 ;

03/29/2023 UPS/Courier Service - UPS (USD)(JPMPCARD); Invoice # 00000A6T163133; 03/29/2023; ; Corporate Creations Network Inc.; 3411 Silverside Road; Wilmington, DE 198104812 ;

03/29/2023 Taxi/Ground Transportation - Nick Bassett; 03/16/2023; From/To: Meeting/Airport ; Service Type: Uber; Time: 08:02; Travel to New York and

03/29/2023 Taxi/Ground Transportation - Nick Bassett; 03/16/2023; From/To: Airport/Home ; Service Type: Uber; Time: 11:22; Travel to New York and

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Luc Despins as Chapter 11 Trustee in the case of Ho Wan Page 68

03/29/2023 Taxi/Ground Transportation - Nick Bassett; 03/14/2023; From/To: Airport/Hotel; Service Type: Taxi; Time: 00:00; Travel to New York and

03/29/2023 Taxi/Ground Transportation - Nick Bassett; 03/14/2023; From/To: Hotel/Meeting ; Service Type: Taxi; Time: 00:00; Travel to New York and

03/29/2023 Vendor Expense - Nick Bassett; 03/13/2023; Travel to New York and Connecticut for client meetings; Travel Agency Service Fee 25.00 03/29/2023 Vendor Expense - Nick Bassett; 03/15/2023; Travel to New York and Connecticut for client

03/29/2023 Computer Search (Other) 46.44 03/30/2023 Search Fee - Companies Registry, Invoice# 03/30/2023cl2 Dated 03/30/23, Company search fee on 24 March 2023; Joyord Sportswear Limited;

03/30/2023 Computer Search (Other) 70.02 03/31/2023 UPS/Courier Service - UPS (USD)(JPMPCARD); Invoice # 00000A6T163143; 03/31/2023; ; Silvergate Bank; c/o CT Corporation System;

03/31/2023 UPS/Courier Service - UPS (USD)(JPMPCARD); Invoice # 00000A6T163143; 03/31/2023; ; Silvergate Bank; 4250 Executive Square, Suite 300; La Jolla, CA 92037 ; 1ZA6T1630193383404 (MAN) 17.03 03/31/2023 UPS/Courier Service - UPS (USD)(JPMPCARD); Invoice # 00000A6T163133; 03/31/2023; OFFICER, MANAGING OR; MACARON LTD;

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03/31/2023 UPS/Courier Service - UPS (USD)(JPMPCARD); Invoice # 00000A6T163143; 03/31/2023; ; Greenwich Land, LLC; 3411 Silverside Rd.; Wilmington, DE 198104812 ;

03/31/2023 UPS/Courier Service - UPS (USD)(JPMPCARD); Invoice # 00000A6T163143; 03/31/2023; ; Greenwich Land, LLC; c/o Hing Chi Ngok; Greenwich, CT 068312828 ; 1ZA6T1630195714258

03/31/2023 UPS/Courier Service - UPS (USD)(JPMPCARD); Invoice # 00000A6T163143; 03/31/2023; ; Hing Chi Ngok; 373 Taconic Road; Greenwich, CT 068312828 ; 1ZA6T1630199900030 (MAN) 30.66 03/31/2023 UPS/Courier Service - UPS (USD)(JPMPCARD); Invoice # 00000A6T163143; 03/31/2023; ; Silvergate Bank; c/o CT Corporation System; Glendale, CA 912032336 ; 1ZA6T1630192159613

03/31/2023 UPS/Courier Service - UPS (USD)(JPMPCARD); Invoice # 00000A6T163143; 03/31/2023; ; Silvergate Bank; 4250 Executive Square, Suite 300; La Jolla, CA 920379104 ; 1ZA6T1630193383404

03/31/2023 UnitedLex Invoices - Unitedlex Corp, Invoice# 084052 Dated 03/31/23, UnitedLex – DSAI March 2023 Charges – Outside Professional Services 44,288.21 03/31/2023 Vendor Expense - David Mohamed; 03/22/2023; court documents for a case in LA Superior Court; Merchant: L A Superior Court Location: 213- 8930364, CA 90012-0000 , Statement Date: 03/31/2023, Post Date: 03/24/2023; Service

Luc Despins as Chapter 11 Trustee in the case of Ho Wan Page 70

03/31/2023 Vendor Expense - David Mohamed; 02/28/2023; White Pages for personal contact information on certain person relating to the Kwok matter for processing; Merchant: Whitepages Location: 800- 9529005, WA 98121-0000 , Statement Date: 03/31/2023, Post Date: 03/01/2023; Service

03/31/2023 Vendor Expense - David Mohamed; 03/28/2023; White Pages for personal contact information on certain person relating to the Kwok matter for processing; Merchant: Whitepages Location: 800- 9529005, WA 98121-0000 , Statement Date: 03/31/2023, Post Date: 03/29/2023; Service

03/31/2023 Postage/Express Mail - First Class - US; 7.38 03/31/2023 Data Base Storage - PS-TD01767; Analyst - Lopez,

03/31/2023 Data Base Storage - PS-TD01766; Analyst - Lopez,

03/31/2023 Data Base Storage - PS-TD01769; Analyst - Lopez,

03/31/2023 Westlaw Business - Courtlink Use - Charges for

Total Costs incurred and advanced \$75,661.63

Total Balance Due - Due Upon Receipt \$657,093.63 Case 22-50073 Doc 2051 Filed 08/04/23 Entered 08/04/23 18:53:56 Page 177 of 906

PAUL HASTINGS LLP 2050 M Street NW, Washington, DC 20036 t: +1.202.551.1700 f: +1.202.551.1705 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

Other Litigation PH LLP Client/Matter # 50687-00003 Nicholas A. Bassett

Legal fees for professional services for the period ending March 31, 2023 \$12,013.50

Total Balance Due - Due Upon Receipt \$12,083.94

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 2051 Filed 08/04/23 Entered 08/04/23 18:53:56 Page 178 of 906

PAUL HASTINGS LLP 2050 M Street NW, Washington, DC 20036 t: +1.202.551.1700 f: +1.202.551.1705 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

Other Litigation PH LLP Client/Matter # 50687-00003 Nicholas A. Bassett

Legal fees for professional services for the period ending March 31, 2023 \$12,013.50

Total Balance Due - Due Upon Receipt \$12,083.94

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 2051 Filed 08/04/23 Entered 08/04/23 18:53:56 Page 179 of 906

t: +1.202.551.1700 f: +1.202.551.1705 www.paulhastings.com

Luc Despins as Chapter 11 Trustee in the case of Ho July 31, 2023

New York, NY 10166 Invoice Number: 2366608

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

FOR PROFESSIONAL SERVICES RENDERED for the period ending March 31, 2023

Date Initials Description Hours Rate Amount

03/15/2023 ECS1 Attend and take notes on Debtor's

(3.5); prepare summary regarding same (.4) 3.90 1,015.00 3,958.50 Subtotal: B155 Court Hearings 3.90 3,958.50

03/01/2023 NAB Email with Arizona class action litigation counsel regarding withdrawal from case 0.20 1,625.00 325.00 03/02/2023 AB21 Correspond with N. Bassett regarding

litigation (0.2); correspond with T. Sadler

bank account (0.1) 0.30 1,625.00 487.50 03/15/2023 ECS1 Review documents and information regarding Debtor's arrest, arraignment, and bail hearing in SDNY 0.40 1,015.00 406.00

Date Initials Description Hours Rate Amount

03/16/2023 DEB4 Correspond with S. Maza regarding Kwok

03/16/2023 DEB4 Correspond with L. Meliotes regarding forfeiture questions 0.10 1,320.00 132.00 03/16/2023 DEB4 Correspond with S. Maza regarding SEC

03/18/2023 DEB4 Correspond with L. Despins regarding

03/19/2023 DEB4 Correspond with L. Despins regarding Kwok criminal indictment 0.30 1,320.00 396.00 03/20/2023 DEB4 Prepare analysis of Kwok indictment 2.40 1,320.00 3,168.00 03/22/2023 AB21 Correspond with N. Bassett regarding payment of balance of Todd Feltus retainer 0.20 1,625.00 325.00 03/24/2023 DEB4 Correspond with J. Kuo regarding Kwok

03/24/2023 DEB4 Correspond with I. Goldman (Pullman) regarding Michel case 0.30 1,320.00 396.00 03/24/2023 DEB4 Correspond with J. Kuo regarding criminal

03/28/2023 JK21 Correspond with L. Despins regarding Kwok and Wang criminal cases 0.40 540.00 216.00 03/30/2023 NAB Correspond with T. Feltus (Debtor Arizona

withdrawal from litigation 0.30 1,625.00 487.50 03/31/2023 DEB4 Correspond with N. Bassett and L. Despins regarding bail hearing filings 0.40 1,320.00 528.00 Subtotal: B191 General Litigation 6.20 8,055.00

ID Timekeeper Name Title Hours Rate Fee

NAB Nicholas A. Bassett Partner 0.50 1,625.00 812.50 Case 22-50073 Doc 2051 Filed 08/04/23 Entered 08/04/23 18:53:56 Page 181 of 906

50687-00003 Luc Despins as Chapter 11 Trustee in the case of Ho Wan

AB21 Alex Bongartz Of Counsel 0.50 1,625.00 812.50 DEB4 Douglass E. Barron Associate 4.40 1,320.00 5,808.00 ECS1 Ezra C. Sutton Associate 4.30 1,015.00 4,364.50 JK21 Jocelyn Kuo Paralegal 0.40 540.00 216.00

Date Description Quantity Rate Amount 03/06/2023 Photocopy Charges 24.00 0.08 1.92 03/06/2023 Photocopy Charges 201.00 0.08 16.08 03/06/2023 Photocopy Charges 218.00 0.08 17.44 03/06/2023 Photocopy Charges (Color) 1.00 0.20 0.20 03/06/2023 Photocopy Charges (Color) 2.00 0.20 0.40

Total Costs incurred and advanced \$70.44

Total Balance Due - Due Upon Receipt \$12,083.94 Case 22-50073 Doc 2051 Filed 08/04/23 Entered 08/04/23 18:53:56 Page 182 of 906

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

Corporate Law Issues PH LLP Client/Matter # 50687-00004 Nicholas A. Bassett

Legal fees for professional services for the period ending March 31, 2023 \$78,033.50

Total Balance Due - Due Upon Receipt \$78,033.50

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 2051 Filed 08/04/23 Entered 08/04/23 18:53:56 Page 183 of 906

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

Corporate Law Issues PH LLP Client/Matter # 50687-00004 Nicholas A. Bassett

Legal fees for professional services for the period ending March 31, 2023 \$78,033.50

Total Balance Due - Due Upon Receipt \$78,033.50

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 2051 Filed 08/04/23 Entered 08/04/23 18:53:56 Page 184 of 906

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

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

FOR PROFESSIONAL SERVICES RENDERED for the period ending March 31, 2023

Date Initials Description Hours Rate Amount

B190 Other Contested Matters(excl. assumption/rejections motions) 03/01/2023 NAB Review motion for stay pending appeal of corporate governance order contempt order 0.30 1,625.00 487.50 03/02/2023 LAD4 Review/edit Ace Decade settlement

(Zeisler) re: same (.50) 2.00 1,860.00 3,720.00 03/03/2023 AB21 Correspond with L. Despins and N. Bassett

objection to request for stay pending appeal

update on Ace Decade (0.2) 0.30 1,625.00 487.50 03/04/2023 AB21 Analyze issues for objection to Kwok's

Decade contempt order, including review of related pleadings (2.7); outline argument for objection (3.0); correspond with K. Catalano regarding related case law (0.1);

proceedings (1.9) 8.00 1,625.00 13,000.00

Case 22-50073 Doc 2051 Filed 08/04/23 Entered 08/04/23 18:53:56 Page 185 of 906

Luc Despins as Chapter 11 Trustee in the case of Ho Wan Kwok 50687-00004 Invoice No. 2366609

Date Initials Description Hours Rate Amount

03/04/2023 CD16 Preliminary call with A. Bongartz re status of UK recognition application for Trustee's

contempt order (Ace Decade) 0.40 1,320.00 528.00 03/04/2023 CD16 Detailed call with A. Bongartz re UK recognition proceedings 1.50 1,320.00 1,980.00 03/04/2023 CD16 Review email from A. Bongartz regarding

up analysis of folders and documents re UK

regarding findings (0.3) 1.20 1,320.00 1,584.00 03/04/2023 KC27 Review case law regarding injunctions requiring obedience of law (1.9); summarize

regarding same (.2) 4.90 915.00 4,483.50 03/04/2023 Review Kwok's Gettr posts and videos

regarding same (.2) 2.00 815.00 1,630.00 03/05/2023 AB21 Draft objection to motion for stay pending

(11.0); correspond with N. Bassett regarding

regarding same (0.1); correspond with L.

related case law (0.2); correspond with C.

recognition proceedings (0.1) 11.60 1,625.00 18,850.00 03/05/2023 CD16 Review and amend statement re UK proceedings (0.3); review related documents

03/05/2023 JPK1 Correspond with E. Sutton regarding Trustee's opposition to debtor's motion to

Case 22-50073 Doc 2051 Filed 08/04/23 Entered 08/04/23 18:53:56 Page 186 of 906

Luc Despins as Chapter 11 Trustee in the case of Ho Wan Kwok 50687-00004 Invoice No. 2366609

Date Initials Description Hours Rate Amount

03/05/2023 KC27 Analyze case law regarding obey the law injunctions (3.0); correspond with A. Bongartz regarding same (.1); calls with A.

summary of same (.8) 4.10 915.00 3,751.50 03/06/2023 AB21 Finalize objection to motion to stay pending appeal of Ace Decade contempt order (1.5); call with L. Despins regarding same (0.1); correspond with N. Bassett regarding same (0.1); further correspond with L. Despins and N. Bassett regarding same (0.4); call with P. Linsey (Neubert) regarding filing of

regarding same (0.1) 2.30 1,625.00 3,737.50 03/06/2023 CD16 Review email from A. Bongartz re disclosing barrister statements (0.1); call with P. Wright re same (0.1); respond to A. Bongartz re same (0.2). 0.40 1,320.00 528.00 03/06/2023 LAD4 Review/edit Ace Decade stay opposition (1.40); t/c A. Bongartz re: same (.10); emails to/from A. Bongartz re: same (.20) 1.70 1,860.00 3,162.00 03/06/2023 LAD4 T/c S. Kindseth re: response to Ace

03/06/2023 NAB Review and revise draft objection to motion

with A. Bongartz and L. Despins regarding

03/07/2023 AB21 Review draft counterdesignations for Kwok

(0.3); correspond with N. Bassett, and W. Farmer regarding same (0.1) 0.40 1,625.00 650.00 03/07/2023 AB21 Analyze issue regarding Ace Decade funding (0.9); correspond with L. Despins regarding same (0.3) 1.20 1,625.00 1,950.00 03/07/2023 NAB Review appellate designations for Ace Decade contempt order appeal 0.20 1,625.00 325.00

Case 22-50073 Doc 2051 Filed 08/04/23 Entered 08/04/23 18:53:56 Page 187 of 906

Luc Despins as Chapter 11 Trustee in the case of Ho Wan Kwok 50687-00004 Invoice No. 2366609

Initials Description Hours Rate Amount

WCF Draft counter-designations regarding appeal of Ace Decade contempt decision (3.2); correspond with P. Linsey regarding appeal counter-designations and filings of same (.2) 3.40 1,235.00 4,199.00 AB21 Prepare supplemental statement regarding motion for stay pending appeal of contempt order (Ace Decade) (1.8); correspond with L. Despins regarding same (0.2); correspond with S. Sarnoff (O'Melveny) regarding same

LAD4 Review/edit supplemental filing on Ace Decade re: Zhang Wei 0.90 1,860.00 1,674.00 LAD4 T/c S. Sarnoff (O'Melveny) re: Zhang Wei 1.60 1,860.00 2,976.00 AB21 Finalize supplemental statement regarding Debtor's motion for stay pending appeal of contempt order (Ace Decade) (0.4); correspond with L. Despins regarding same (0.2); call and correspond with P. Linsey (Neubert) regarding filing of same (0.1) 0.70 1,625.00 1,137.50

supplemental filing 0.50 1,860.00 930.00 B190 Other Contested Matters(excl. assumption/rejections motions) 53.60 78,033.50 Subtotal:

ID Timekeeper Name Title Hours Rate Fee

LAD4 Luc A. Despins Partner 6.90 1,860.00 12,834.00 NAB Nicholas A. Bassett Partner 1.40 1,625.00 2,275.00 AB21 Alex Bongartz Of Counsel 26.60 1,625.00 43,225.00 CD16 Crispin Daly Associate 4.20 1,320.00 5,544.00 WCF Will C. Farmer Associate 3.40 1,235.00 4,199.00 JPK1 Jon P. Kosciewicz Associate 0.10 915.00 91.50 Case 22-50073 Doc 2051 Filed 08/04/23 Entered 08/04/23 18:53:56 Page 188 of 906

Luc Despins as Chapter 11 Trustee in the case of Ho Wan Page 5

KC27 Kristin Catalano Associate 9.00 915.00 8,235.00

Total Balance Due - Due Upon Receipt \$78,033.50 Case 22-50073 Doc 2051 Filed 08/04/23 Entered 08/04/23 18:53:56 Page 189 of 906

PAUL HASTINGS LLP 2050 M Street NW, Washington, DC 20036 t: +1.202.551.1700 f: +1.202.551.1705 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

Foreign Law Issues PH LLP Client/Matter # 50687-00007 Nicholas A. Bassett

Legal fees for professional services for the period ending March 31, 2023 \$1,188.00

Total Balance Due - Due Upon Receipt \$1,188.00

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 2051 Filed 08/04/23 Entered 08/04/23 18:53:56 Page 190 of 906

PAUL HASTINGS LLP 2050 M Street NW, Washington, DC 20036 t: +1.202.551.1700 f: +1.202.551.1705 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

Foreign Law Issues PH LLP Client/Matter # 50687-00007 Nicholas A. Bassett

Legal fees for professional services for the period ending March 31, 2023 \$1,188.00

Total Balance Due - Due Upon Receipt \$1,188.00

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 2051 Filed 08/04/23 Entered 08/04/23 18:53:56 Page 191 of 906

PAUL HASTINGS LLP t: +1.202.551.1700 f: +1.202.551.1705 www.paulhastings.com

Luc Despins as Chapter 11 Trustee in the case of Ho July 31, 2023

New York, NY 10166 Invoice Number: 2366610

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

FOR PROFESSIONAL SERVICES RENDERED for the period ending March 31, 2023

Date Initials Description Hours Rate Amount B261 Investigations 03/06/2023 CD16 Review note from P. Wright on alternative means of obtaining evidence in England (0.4); email re same to A. Bongartz and N. Bassett (0.2) 0.60 1,320.00 792.00 03/17/2023 CD16 Update call with A. Bongartz regarding Kwok case and Q. Guo document discovery (0.2); prepare follow up notes regarding same (0.1) 0.30 1,320.00 396.00 Subtotal: B261 Investigations 0.90 1,188.00 Total 0.90 1,188.00 Timekeeper Summary ID Timekeeper Name Title Hours Rate Fee CD16 Crispin Daly Associate 0.90 1,320.00 1,188.00 Case 22-50073 Doc 2051 Filed 08/04/23 Entered 08/04/23 18:53:56 Page 192 of 906

Luc Despins as Chapter 11 Trustee in the case of Ho Wan Kwok 50687-00007 Invoice No. 2366610 Page 2

Total Balance Due - Due Upon Receipt \$1,188.00 Case 22-50073 Doc 2051 Filed 08/04/23 Entered 08/04/23 18:53:56 Page 193 of 906

PAUL HASTINGS LLP 2050 M Street NW, Washington, DC 20036 t: +1.202.551.1700 f: +1.202.551.1705 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

Plan Process PH LLP Client/Matter # 50687-00008 Nicholas A. Bassett

Legal fees for professional services for the period ending March 31, 2023 \$1,674.00

Total Balance Due - Due Upon Receipt \$1,674.00

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 2051 Filed 08/04/23 Entered 08/04/23 18:53:56 Page 194 of 906

PAUL HASTINGS LLP 2050 M Street NW, Washington, DC 20036 t: +1.202.551.1700 f: +1.202.551.1705 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

Plan Process PH LLP Client/Matter # 50687-00008 Nicholas A. Bassett

Legal fees for professional services for the period ending March 31, 2023 \$1,674.00

Total Balance Due - Due Upon Receipt \$1,674.00

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 2051 Filed 08/04/23 Entered 08/04/23 18:53:56 Page 195 of 906

t: +1.202.551.1700 f: +1.202.551.1705 www.paulhastings.com

Luc Despins as Chapter 11 Trustee in the case of Ho July 31, 2023

New York, NY 10166 Invoice Number: 2366611

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

FOR PROFESSIONAL SERVICES RENDERED for the period ending March 31, 2023

Date Initials Description Hours Rate Amount

B320 Plan and Disclosure Statement (including Business Plan) 03/01/2023 LAD4 Review/comment on potential plan structure for distributions to victims vs.

Subtotal:

(including Business Plan) 0.90 1,674.00

ID Timekeeper Name Title Hours Rate Fee LAD4 Luc A. Despins Partner 0.90 1,860.00 1,674.00

Total Balance Due - Due Upon Receipt \$1,674.00 Case 22-50073 Doc 2051 Filed 08/04/23 Entered 08/04/23 18:53:56 Page 196 of 906

PAUL HASTINGS LLP 2050 M Street NW, Washington, DC 20036 t: +1.202.551.1700 f: +1.202.551.1705 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

Genever US PH LLP Client/Matter # 50687-00010 Nicholas A. Bassett

Legal fees for professional services for the period ending March 31, 2023 \$62,395.00

Total Balance Due - Due Upon Receipt \$62,498.66

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 2051 Filed 08/04/23 Entered 08/04/23 18:53:56 Page 197 of 906

PAUL HASTINGS LLP 2050 M Street NW, Washington, DC 20036 t: +1.202.551.1700 f: +1.202.551.1705 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

Genever US PH LLP Client/Matter # 50687-00010

Legal fees for professional services for the period ending March 31, 2023 \$62,395.00

Total Balance Due - Due Upon Receipt \$62,498.66

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 2051 Filed 08/04/23 Entered 08/04/23 18:53:56 Page 198 of 906

t: +1.202.551.1700 f: +1.202.551.1705 www.paulhastings.com

Luc Despins as Chapter 11 Trustee in the case of Ho July 31, 2023

New York, NY 10166 Invoice Number: 2366612

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

FOR PROFESSIONAL SERVICES RENDERED for the period ending March 31, 2023

Date Initials Description Hours Rate Amount

03/15/2023 AB21 Revise proposed emergency order regarding

apartment (0.6); correspond with L.

03/15/2023 LAD4 Review & comment on order re: access to

Case 22-50073 Doc 2051 Filed 08/04/23 Entered 08/04/23 18:53:56 Page 199 of 906

Luc Despins as Chapter 11 Trustee in the case of Ho Wan Kwok 50687-00010 Invoice No. 2366612

Date Initials Description Hours Rate Amount

03/16/2023 AB21 Revise emergency order restricting access to Sherry Netherland apartment (0.5); correspond with L. Despins regarding same (0.3); call with L. Despins and S. Millman (Stroock) regarding same (0.3); correspond with S. Millman regarding same (0.3);

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

correspondence from L. Despins, S. Millman, and M. Cyganowski (sales officer) related to status of apartment (0.2) 1.90 1,625.00 3,087.50 03/16/2023 LAD4 Review & edit S-N fire access order (.30);

re: next steps with respect to dealing with

03/17/2023 AB21 Correspond with M. Cyganowski (sales

emergency order restricting access 0.10 1,625.00 162.50 03/17/2023 AB21 Correspond with C. Abrehart (Genever BVI director) regarding update on case 0.10 1,625.00 162.50 03/17/2023 AEL2 Correspond with L. Despins re: information re: the Sherry Netherland apartment access 0.20 1,625.00 325.00 03/18/2023 LAD4 Analyze Sherry Netherland issues 1.90 1,860.00 3,534.00 03/20/2023 AB21 Prepare amended emergency order

related notice of filing (0.4); correspond with L. Despins regarding same (0.1);

regarding same (0.1); call and correspond with P. Linsey (Neubert) regarding filing of

03/20/2023 DEB4 Conference with P. Linsey (Neubert)

administrative issues 0.30 1,320.00 396.00 03/20/2023 LAD4 T/c B. Langer re: Sherry Netherland ability to collect damages 0.30 1,860.00 558.00 Case 22-50073 Doc 2051 Filed 08/04/23 Entered 08/04/23 18:53:56 Page 200 of 906

Luc Despins as Chapter 11 Trustee in the case of Ho Wan Kwok 50687-00010 Invoice No. 2366612

Date Initials Description Hours Rate Amount

03/20/2023 LAD4 T/c C. Abrehart (Harneys Corporate) & A. Bongartz re: update (.30) 0.30 1,860.00 558.00 03/28/2023 LAD4 T/c S. Millman (Stroock) re: update on Sherry Netherland 0.20 1,860.00 372.00 03/29/2023 AB21 Correspond with L. Despins and R.

Holdings LLC case 0.10 1,625.00 162.50 03/29/2023 DEB4 Correspond with H. Claiborn (US Trustee) regarding US Trustee fees 0.10 1,320.00 132.00 03/29/2023 DEB4 Correspond with T. Sadler regarding US

03/31/2023 DEB4 Correspond with H. Claiborn (US Trustee) regarding US Trustee fees 0.20 1,320.00 264.00 Subtotal: B110 Case Administration 8.70 14,786.50

03/08/2023 AB21 Correspond with F. Lawall (Troutman) regarding proposed order for marketing SN

03/09/2023 AB21 Review mark-up of proposed order on marketing of SN apartment for rent (0.2); correspond with L. Despins regarding same (0.3); correspond with S. Millman (Stroock) regarding same (0.1) 0.60 1,625.00 975.00 03/10/2023 AB21 Revise proposed order regarding marketing of SN apartment (0.1); correspond with L.

(0.1); correspond with P. Linsey (Neubert)

regarding same (0.1) 0.40 1,625.00 650.00

Case 22-50073 Doc 2051 Filed 08/04/23 Entered 08/04/23 18:53:56 Page 201 of 906

Luc Despins as Chapter 11 Trustee in the case of Ho Wan Kwok 50687-00010 Invoice No. 2366612

Date Initials Description Hours Rate Amount

03/18/2023 AB21 Analyze authority regarding sale of SN apartment (0.6); correspond with L. Despins regarding same (0.3); call with D.

documents (0.3); call with L. Despins and B. Langer regarding same (0.2) 1.60 1,625.00 2,600.00 03/18/2023 DEB4 Conference with A. Bongartz regarding Sherry Netherland lease issue 0.20 1,320.00 264.00

Netherland lease issues 0.20 1,320.00 264.00 03/18/2023 Conference with D. Barron regarding treatment of co-op proprietary lease under Bankruptcy Code and by bankruptcy court 0.20 815.00 163.00 03/20/2023 AB21 Correspond with L. Despins regarding proprietary SN apartment lease 0.20 1,625.00 325.00

Section 365 questions 0.30 1,320.00 396.00 03/20/2023 DEB4 Analyze documents in connection with SN Section 365 questions 0.50 1,320.00 660.00 03/20/2023 DEB4 Follow up correspondence with regarding SN Section 365 questions 0.10 1,320.00 132.00 03/20/2023 DEB4 Correspond with L. Despins regarding SN

03/20/2023 DEB4 Correspond with L. Despins regarding co

03/20/2023 Conference with D. Barron regarding the

03/21/2023 AB21 Correspond with M. Pantzer (Otterbourg)

Netherland co-op lease 0.10 1,320.00 132.00

Case 22-50073 Doc 2051 Filed 08/04/23 Entered 08/04/23 18:53:56 Page 202 of 906

Luc Despins as Chapter 11 Trustee in the case of Ho Wan Kwok 50687-00010 Invoice No. 2366612

Date Initials Description Hours Rate Amount

Netherland Section 365 issues 0.30 1,320.00 396.00 03/28/2023 DEB4 Correspond with J. Kuo regarding Sherry Netherland documents 0.10 1,320.00 132.00 03/29/2023 JK21 Correspond with K. Catalano regarding sale of assets precedent 0.60 540.00 324.00 Subtotal:

Subtotal: B155 Court Hearings 1.40 2,275.00

03/06/2023 AB21 Correspond with M. Pantzer (Otterbourg)

marketing of SN apartment for rent (0.1); prepare hearing notes regarding same (0.8); correspond with L. Despins regarding same

03/03/2023 AB21 Correspond with L. Despins regarding

marketing of SN apartment for rent 0.30 1,625.00 487.50

03/09/2023 DEB4 Conference with T. Sadler regarding Genever US bank account 0.10 1,320.00 132.00

03/09/2023 TS21 Correspond with Axos Bank regarding Genever bank accounts (.1); call with D. Barron regarding same (.1) 0.20 1,175.00 235.00 03/16/2023 DEB4 Conference with P. Linsey (Neubert) regarding Genever U.S. insurance 0.20 1,320.00 264.00 03/16/2023 DEB4 Correspond with S. Millman (Stroock) regarding Genever U.S. insurance policy 0.20 1,320.00 264.00 03/16/2023 DEB4 Correspond with L. Despins regarding Genever U.S. insurance issues 0.20 1,320.00 264.00

Case 22-50073 Doc 2051 Filed 08/04/23 Entered 08/04/23 18:53:56 Page 203 of 906

Luc Despins as Chapter 11 Trustee in the case of Ho Wan Kwok 50687-00010 Invoice No. 2366612

Date Initials Description Hours Rate Amount 03/16/2023 DEB4 Correspond with L. Despins regarding Genever U.S. insurance policy (0.2); correspond with S. Millman (Stroock) regarding same (0.1); analyze documents related to same (0.3); correspond with C. Skitileky (Global Coverage) regarding same (0.1) 0.70 1,320.00 924.00 03/16/2023 DEB4 Conference with P. Linsey (Neubert) and C. Skitileky (Global Coverage) regarding Genever U.S. insurance policy 0.30 1,320.00 396.00 03/16/2023 DEB4 Correspond with Skitileky (Global Coverage) regarding additional insureds 0.20 1,320.00 264.00 03/16/2023 DEB4 Correspond with T. Sadler regarding Genever bank account 0.10 1,320.00 132.00 03/16/2023 TS21 Correspond with P. Linsey (Neubert) and D. Barron regarding Axos bank account 0.30 1,175.00 352.50 03/18/2023 LAD4 T/c A. Bongartz, B. Langer re: Sherry Netherland co-op (.20); t/c S. Millman (Stroock) re: same (.20) 0.40 1,860.00 744.00 03/18/2023 LAD4 T/c G. Hannigan (AIG expert) re: fire at Sherry Netherland (.40); review policies re: same (.80) 1.20 1,860.00 2,232.00 03/19/2023 DEB4 Correspond with C. Skirileky (Global Coverage) regarding Genever U.S. insurance documents 0.10 1,320.00 132.00 03/19/2023 DEB4 Correspond with E. Joyce (Jones Day) regarding Genever U.S. insurance policy 0.10 1,320.00 132.00 03/19/2023 LAD4 T/c G. Hannigan (AIG expert) re: next steps 0.30 1,860.00 558.00

03/20/2023 DEB4 Correspond with L. Despins and T. Sadler regarding Axos Bank 0.30 1,320.00 396.00 03/20/2023 DEB4 Correspond with C. Skirileky (Global Coverage) regarding Genever U.S. insurance documents 0.10 1,320.00 132.00 03/20/2023 TS21 Correspond with D. Barron and L. Despins regarding Axos Bank account 0.60 1,175.00 705.00

Case 22-50073 Doc 2051 Filed 08/04/23 Entered 08/04/23 18:53:56 Page 204 of 906

Date Initials Description Hours Rate Amount

03/21/2023 LAD4 T/c K. Schultz (AIG) re: Sherry Netherland coverage (.20); review coverage issues (2.30) 2.50 1,860.00 4,650.00 03/21/2023 TS21 Call with Axos Bank regarding account set up (.3); correspond with Axos Bank and L. Despins regarding same (.3). 0.60 1,175.00 705.00 03/22/2023 DEB4 Correspond with E. Joyce (Jones Day)

Netherland apartment 0.10 1,320.00 132.00 03/22/2023 LAD4 T/c G. Hannigan (AIG expert) re: next steps (.30); t/c S. Millman (Stroock) re:

03/23/2023 AB21 Analyze property and liability insurance

(0.2); correspond with L. Despins regarding

03/23/2023 LAD4 T/c with Sherry Netherland team (M. Ullman, S. Millman) re: access/next steps (.50); email to DOJ re: access to apartment by insurance experts (.30) 0.80 1,860.00 1,488.00 03/23/2023 LAD4 Several emails to insurance company experts re: apartment visit 1.20 1,860.00 2,232.00 03/24/2023 AB21 Correspond with D. Barron regarding AIG letter regarding SN apartment 0.10 1,625.00 162.50 03/24/2023 DEB4 Correspond with E. Joyce (Jones Day) regarding insurance policies 0.20 1,320.00 264.00 03/24/2023 TS21 Correspond with L. Despins, D. Barron and

03/26/2023 DEB4 Correspond with C. Skitileky (Global Coverage) regarding insurance premiums 0.10 1,320.00 132.00 03/26/2023 LAD4 T/c E. Joyce (Jones Day) re: Sherry Netherland insurance coverage 0.40 1,860.00 744.00 03/27/2023 LAD4 T/c R. Lambert counsel to AIG (other side) re: SN apartment insurance 0.20 1,860.00 372.00

Case 22-50073 Doc 2051 Filed 08/04/23 Entered 08/04/23 18:53:56 Page 205 of 906

Luc Despins as Chapter 11 Trustee in the case of Ho Wan Kwok 50687-00010 Invoice No. 2366612

Date Initials Description Hours Rate Amount

03/27/2023 TS21 Correspond with Axos bank regarding

accounts (.2); review issues regarding same

03/28/2023 DEB4 Correspond with C. Skilticky (Global

(0.1); correspond with L. Despins regarding

regarding same (0.1) 0.30 1,320.00 396.00 03/28/2023 DEB4 Correspond with L. Despins regarding Sherry Netherland fee 0.10 1,320.00 132.00 03/28/2023 LAD4 T/c G. Hannigan (AIG expert) re: insurance coverage 0.30 1,860.00 558.00 03/28/2023 TS21 Review and comment on Axos Bank account and set up of same 0.50 1,175.00 587.50 03/29/2023 DEB4 Correspond with T. Sadler regarding insurance premiums 0.10 1,320.00 132.00 03/29/2023 TS21 Correspond with Axos Bank regarding bank

03/30/2023 TS21 Correspond with Axos Bank regarding bank

Genever payments (.8) 1.60 1,175.00 1,880.00 03/31/2023 DEB4 Correspond with C. Skitileky (Global Coverage) regarding insurance premiums 0.10 1,320.00 132.00 03/31/2023 DEB4 Correspond with T. Sadler regarding Axos

Subtotal: B210 Business Operations 16.90 25,917.00 B211 Financial Reports (Monthly Operating Reports)

03/07/2023 DEB4 Correspond with P. Linsey (Neubert) and D. Skaltan (Neubert) regarding MORs 0.10 1,320.00 132.00

03/09/2023 DEB4 Correspond with B. Linsey (Neubert) regarding Genever MOR 0.10 1,320.00 132.00 Case 22-50073 Doc 2051 Filed 08/04/23 Entered 08/04/23 18:53:56 Page 206 of 906

Luc Despins as Chapter 11 Trustee in the case of Ho Wan Kwok 50687-00010 Invoice No. 2366612

Date Initials Description Hours Rate Amount

03/09/2023 DEB4 Conference with P. Linsey (Neubert) regarding Genever MORs 0.30 1,320.00 396.00 03/18/2023 DEB4 Conference with P. Linsey (Neubert) regarding Genever U.S. MORs 0.10 1,320.00 132.00 03/20/2023 DEB4 Prepare attachment for Genever MOR 0.30 1,320.00 396.00 03/20/2023 LAD4 Review Kwok MOR re: payments for house 0.30 1,860.00 558.00 03/23/2023 DEB4 Correspond with L. Despins regarding

D. Skalka (Neubert) regarding same (0.1);

Subtotal: B211 Financial Reports (Monthly

B310 Claims Administration and Objections

03/31/2023 AB21 Correspond with P. Linsey (Neubert) and

03/31/2023 CD16 Review email from D. Barron and proof of

proof of claim (0.2); email T. Nowak and D. Zhuang re same (0.1); correspond with L. Despins re same (0.1) 0.70 1,320.00 924.00 03/31/2023 DEB4 Prepare G. Guo claim objection 1.80 1,320.00 2,376.00 03/31/2023 DEB4 Correspond with J. Kuo regarding claim

03/31/2023 DEB4 Correspond with L. Despins regarding Qiang Guo proof of claim 0.30 1,320.00 396.00 03/31/2023 JK21 Revise objection to proof of claim 3-1 (1.8); electronically file with the court objection to proof of claim 3-1 (0.6) 2.40 540.00 1,296.00 03/31/2023 LAD4 Review & edit objection to debtor's son

Case 22-50073 Doc 2051 Filed 08/04/23 Entered 08/04/23 18:53:56 Page 207 of 906

Luc Despins as Chapter 11 Trustee in the case of Ho Wan Page 10

Subtotal:

ID Timekeeper Name Title Hours Rate Fee LAD4 Luc A. Despins Partner 13.30 1,860.00 24,738.00 AB21 Alex Bongartz Of Counsel 8.80 1,625.00 14,300.00 AEL2 Luft, Avi E. Of Counsel 0.20 1,625.00 325.00 DEB4 Douglass E. Barron Associate 10.70 1,320.00 14,124.00 CD16 Crispin Daly Associate 0.70 1,320.00 924.00 TS21 Tess Sadler Associate 5.00 1,175.00 5,875.00 JK21 Jocelyn Kuo Paralegal 3.00 540.00 1,620.00

Date Description Quantity Rate Amount

Total Costs incurred and advanced \$103.66

Total Balance Due - Due Upon Receipt \$62,498.66 Case 22-50073 Doc 2051 Filed 08/04/23 Entered 08/04/23 18:53:56 Page 208 of 906

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

PH LLP Client/Matter # 50687-00017 Luc A. Despins

Legal fees for professional services for the period ending March 31, 2023 \$1,521,257.00

Current Fees and Costs Due \$1,539,497.80 Total Balance Due - Due Upon Receipt \$1,539,497.80

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 2051 Filed 08/04/23 Entered 08/04/23 18:53:56 Page 209 of 906

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

PH LLP Client/Matter # 50687-00017 Luc A. Despins

Legal fees for professional services for the period ending March 31, 2023 \$1,521,257.00

Current Fees and Costs Due \$1,539,497.80 Total Balance Due - Due Upon Receipt \$1,539,497.80

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: