Guo Wengui / Miles Guo — bankruptcy case · MOTION · ECF #2084


R & ZEISLER, P.C.

10 Middle Street, 15th Floor Bridgeport, Connecticut 06604 Phone: (203) 368-4234 www.zeislaw.com

Eric Henzy, Partner ehenzy@zeislaw.com

August 14, 2023

VIA EMAIL AND ECF Honorable Julie A. Manning United States Bankruptcy Court for the District of Connecticut 915 Lafayette Boulevard Bridgeport, CT 06604

## Re: In re Ho Wan Kwok, Case No. 22-50073 (JAM); Despins v. Taurus Fund LLC, et al., Adv. Proc. No. 23-05017 (JAM) (Bankr. D. Conn.)

Dear Judge Manning:

As you know, we are counsel to debtor Ho Won Kwok ("Debtor") in the referenced Chapter 11 case. I write in connection with the referenced adversary proceeding commenced by the Chapter 1 1 Trustee in connection with the Chapter 11 case, which concerns a parcel of real property located at 675 Ramapo Valley Road, Mahwah, New Jersey 07430 (the "Property").

In particular, I write regarding the hearing scheduled today on the Chapter 11 Trustee's motion for the entry of a preliminary injunction regarding the Property. I am advised by the Debtor's criminal counsel that the Property is the subject of numerous allegations made against the Debtor by the United States of America in the criminal case entitled United States v. Ho Wan Kwok, Case No. 23-cr-118-AT (S.D.N.Y.) (the "Criminal Case"). We understand that in the instant motion proceeding, the Trustee seeks to take control of and restrict access to the Property pending further activity in the adversary proceeding. To the extent that any preliminary relief the Court may consider that restricts or prohibits the Debtor's access to the Property or otherwise permits the Chapter 11 Trustee to make any changes to the Property or its contents, the Debtor's federal constitutional rights may be adversely affected.

I write to report to Your Honor that the Debtor, through his criminal law counsel, intends to present a motion to United States District Judge Analisa Torres in the Southern District of New York, the presiding judge in the Criminal Case, consistent with the process used previously for the Sherry-Netherland apartment. See In re Ho Wan Kwok Dkt. No. 1687; Criminal Case Dkt. Nos. 72; 77. In so doing, the Debtor intends to seek an order providing continued access to the Property and to prevent any changes to its contents pending resolution of, or further orders in, the Criminal Case.


Honorable Julie A. Manning August 14, 2023 Page 2

The Debtor reserves all rights and entitlements under applicable law. We appreciate the Court's consideration.

Respectfully,

Eric Henzy (ct12849) Zeisler & Zeisler, P.C. 10 Middle Street, 15th Floor Bridgeport, CT 06604 Telephone: 203-368-4234 X 245 Facsimile: 203-549-0903 Email: ehenzy(@zeislaw.com

cc: Sidhardha Kamaraju, Pryor Cashman LLP, Criminal Counsel for the Debtor