Guo Wengui / Miles Guo — bankruptcy case · EXHIBIT · ECF #205

METADATA

Defendant
Guo Wengui / Miles Guo / Ho Wan Kwok
Court
CTB
Case No.
22-50073
ECF #
205
Type
EXHIBIT
Filed
2022-03-11

FULL TEXT

## UNITED STATES BANKRUPTCY COURT DISTRICT OF CONNECTICUT BRIDGEPORT DIVISION

-------- X .

:

.

In re:

Ho Wan Kwok,

Chapter 11

Case No. 22-50073 (JAM)

Debtor.

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## AMENDED AFFIDAVIT OF CRAIG R. JALBERT IN SUPPORT OF DEBTOR'S APPLICATION FOR AUTHORIZATION TO RETAIN AND EMPLOY VERDOLINO & LOWEY, P.C. AS FINANCIAL ADVISOR

I, CRAIG R. JALBERT, of Verdolino & Lowey, P.C. ("V&L"), hereby make solemn oath:

1. I am a Certified Insolvency and Restructuring Advisor and a principal of V&L.

V&L maintains an office at 124 Washington Street, Foxborough, Massachusetts 02035.

2. In connection with the Debtor's proposed retention of V&L, I submitted an affidavit in support of the application to employ Verdolino & Lowey, P.C. dated March 11, 2022. The original affidavit ("Affidavit") is attached as Exhibit A. Hereinafter, I will refer to my firm and myself as "the Firm". The Firm continued its extensive review of V&L's connections (as such term is used in Bankruptcy Rule 2014(a)) with the Debtor, his creditors, any other party-in-interest herein, or their respective attorneys or accountants was conducted for connections. During the continued search, additional facts were discovered and are disclosed herein.

3 . I hereby amend the Affidavit to reflect the following additional information to Paragraph 3 of the Affidavit:

a. Facts as disclosed in the Affidavit, updated information missed in preparing the

original affidavit including: Lyondell Chemical Company, et al., Case No. 09-10023 (Bankr. S.D.N.Y.) (Gerber, R.) where BR formerly represented postconfirmation Trusts and the Firm was administrator to the Trusts; a private nonprofit company where Brown Rudnick, LLP ("BR") represented the debtor and the Firm was accountant and administrator to the Debtor, both on a pro bono basis; Purdue Pharma, LP Case No. 19-23649 (Bankr. S.D.N.Y.) (Drain, R.) where Brown Rudnick, LLP ("BR") represents the Ad Hoc Committee and the Firm is Administrator to the Ad Hoc Committee; The Northwest Company, LLC, Case No. 20-10990 (Bankr. S.D.N.Y.) (Wiles, M.), where Brown Rudnick represents an unsecured creditor and V&L was briefly engaged as an independent manager until such time as a Chapter 7 Trustee was appointed; and, Mallinckrodt plc, et al., Case No. 20-12522 (Bankr. D. Del.) (Dorsey, J.) where Brown Rudnick is co-counsel to the governmental opioid litigation claimants committee (collectively, the "Governmental Ad Hoc Committee" and V&L is the proposed administrator for the Governmental Ad Hoc Committee.

- b. Facts as disclosed in the Affidavit. - Facts as disclosed in the Affidavit. C. - d. Stretto, Inc. is the proposed claims agent and might provide other similar services. Stretto provides various services, including claims and noticing and banking and reporting services in numerous Chapter 7 and Chapter 11 cases. Stretto is noticing and claims agent in Bicom, et al (Case No. 17-11906) - Southern District of New York, Greensill Capital (Case No. 21-10561) - Southern District of New York; and, Old CP, Inc., et al (formerly Carla's Pasta) (21-20111) - District of

- -

4. Notwithstanding the foregoing, I hereby represent that I and each member of my Firm are "disinterested persons" as that term is defined in 11 U.S.C. Sec. 101(14).

5. I shall amend this statement immediately upon my learning that (a) any of the within representations are incorrect or (b) there is any change of circumstance relating thereto.

6. The professional services to be rendered by V&L will include those required by the debtor in the above-captioned chapter 11 case and detailed in the Application for the Authority to Employ and Appoint Financial Advisor.

7. The terms of the employment of said accountants agreed to by the Applicant, subject to the approval of the Court have not changed. In the normal course of business, V&L. revises its hourly rates in September of each year. V&L represents that the rates stated in the Affidavit are our regular hourly rates which will be in effect until notified otherwise, recognizing that payment of any compensation is subject to approval by the Court.

Signed under the pains and penalties of perjury this 11th day of April 2022.

Craig R. Jalbert, CIRA Verdolino & Lowey, P.C. 124 Washington Street Foxboro. MA 02035 (508) 543-1720

Subscribed and sworn to before me this 11th day of April 2022.

Notary Public My Commission Expires

THOMAS C. BAILEY Notary Public Commonwealth of Massachusetts My Commission Expires April 6, 2023