Guo Wengui / Miles Guo — bankruptcy case · ORDER · ECF #2156

METADATA

Defendant: Guo Wengui / Miles Guo / Ho Wan Kwok
Court: CTB
Case No.: 22-50073
ECF #: 2156
Type: ORDER
Filed: 2023-08-30

FULL TEXT

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

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

#### COVERSHEET RE: FINAL FEE APPLICATION OF SAXE, DOERNBERGER & VIA, P.C., FOR ALLOWANCE OF COMPENSATION AS SPECIAL INSURANCE COVERAGE COUNSEL ONLY TO DEBTOR GENEVER HOLDINGS LLC

Adversary Proceeding Filed: May 12, 2023

Final Fee Application of: Saxe, Doernberger & Vita, P.C.

Time Period: May 11, 2023 to August 21, 2023

Date of Retention Order: June 29, 2023 [Docket No. 1963] effective as of May 11, 2023

#### Amounts Requested:

Fees: \$230,840.00 Expenses: \$5,612.00 Total: \$236,452.00

#### Fees Previously Requested (Sanctions):

Requested Fees: \$0.00 Awarded Fees: \$0.00 Paid Fees: \$0.00

### Expenses Previously Requested:

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

#### Reductions:

Voluntary Fee Reductions: \$15,000.01 Voluntary Expenses Reductions: none

#### Retainer Requests: None.

Expense Detail: Retainer Received: Not applicable.

1 The Debtors in these chapter 11 cases are Ho Wan Kwok (also known as Guo Wengui, Miles Guo, and Miles Kwok, as well as numerous other aliases) (last four digits of tax identification number: 9595), Genever Holdings LLC (last four digits of tax identification number: 8202) and Genever Holdings Corporation. The mailing address for the Trustee, Genever Holdings LLC, and the Genever Holdings Corporation is Paul Hastings LLP, 200 Park Avenue, New York, NY 10166 c/o Luc A. Despins, as Trustee for the Estate of Ho Wan Kwok (solely for purposes of notices and communications).

| HOURS AND RATES PER PROFESSIONAL AND PARAPROFESSIONAL | | |-------------------------------------------------------|--| | | | | | | | | |

| Name |-----------------------| | | | | Partner (3) | Clifford, Brian | Jordan, David | Saxe, Tracy | | Associates (4) | Eddie, Janie | Markham, Sarah | Rudolph, Kyle | Stallmach, Oliver | 2022 | | | Paraprofessionals (3) | | | Bussola, Alexa | King-Morrison, | Suzette | Mitel, Lynn | | | Date of First Admission | | May 11, 2023 through | Total Fees Billed in this | ------|-------------------------|--------|----------------------|---------------------------| | | | | August 21, 2023 | Application | | | | Hours | Hourly Rate | | | | | Billed | Billed | | | | | | | | | 2010 | | 160.90 | \$575.00 | \$92,517.50 | | 1999 | | 0.40 | \$605.00 | \$242.00 | | 1983 | | 10.70 | \$975.00 | \$10,432.50 | | | Partner Total: | 172.00 | - | \$103,192.00 | | | | | | | | 2014 | | 174.10 | \$475.00 | \$82,697.50 | | 2021 | | 1.80 | \$325.00 | \$585.00 | | 2022 | | 149.90 | \$325.00 | \$48,717.50 | | 6.20 | \$325.00 | \$1,950.00 | | | Associate Total: | 332.0 | - | \$133,950.00 | | | | | | N/A | | 13.50 | \$230.00 | \$3,105.00 | | N/A | | 1.10 | \$235.00 | \$258.50 | | | | | | | | N/A | | 22.70 | \$235.00 | \$5,334.50 | | | Paraprofessional Total | 37.30 | - | \$8,698.00 |

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

#### FINAL FEE APPLICATION OF SAXE, DOERNBERGER & VIA, P.C., FOR ALLOWANCE OF COMPENSATION AS SPECIAL INSURANCE COVERAGE COUNSEL ONLY TO DEBTOR GENEVER HOLDINGS LLC

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"), Saxe, Doernberger & Vita, P.C. ("SDV"), as special insurance coverage counsel to Debtor Genever Holdings LLC ("Genever (US)"), hereby files this Final Fee Application of Saxe, Doernberger & Vita, P.C., for Compensation as Special Insurance Coverage Counsel Only to Debtor Genever Holdings LLC (the "Application"). By this Application, SDV requests allowance and payment for compensation for professional services performed by SDV and reimbursement of its actual and necessary expenses incurred during the period from May 11, 2023 through and including August 21, 2023 (the "Fee Period"), In support of this Application, SDV respectfully states as follows:

#### JURISDICTION, VENUE, BASES FOR RELIEF, AND COMPLIANCE

1. 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 of Connecticut. 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.

2. The level predicates for the relief requested herein are sections 328, 330, and 331 of the Bankruptcy Code, Bankruptcy Rule 2016, and Local Rule 2016-1.

3. SDV 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).2 SDV respectfully requests a waiver of any of the foregoing requirements not met by this Application.

- 4. Attached and incorporated herein by referenced are the following Exhibits: - Exhibit A contains the Proposed Order Granting this Application. - Exhibit B contains time entries with respect to the legal services provided (as discussed below). - Exhibit C contains a summary of actual and necessary disbursement with respect to the legal services provided (as discussed below).

2 SDV reserves all rights as to the relevant and substantive legal effect of the U.S. Trustee Guidelines with respect to any application for compensation.

#### BACKGROUND

#### I. Individual Debtor's Chapter 11 Case

5. On February 15, 2022 (the "Petition Date"), Mr. Ho Wan Kwok (the "Individual Debtor"), filed a voluntary petition for relief under the Bankruptcy Code in the United States Bankruptcy Court for the District of Connecticut (Bridgeport Division).

6. On March 12, 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.

7. On June 15, 2022, the Court entered a memorandum 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 Mr. 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 Mr. Ho Wan Kwok.

#### II. Genever (BVI)'s Chapter 11 Case

8. On October 11, 2022, Genever Holdings Corporation ("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.

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

10. On 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].

#### III. Genever (US)'s Chapter 11 Case

11. 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").

12. On November 3, 2022, the SDNY Bankruptcy Court entered an order [Docket No. 225 in Case No. 22-50592] transferring venue of the SDNY Bankruptcy Case to this Court, which assigned it Case Number 22-509592.

13. 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].

14. On June 29, 2023, the Court granted Genever (US)'s application to retain SDV as special insurance coverage counsel [Docket No. 1963], effective May 11, 2023 (the "Retention Order"). The Retention Order authorizes SDV to be compensated on an hourly bases and reimbursed for actual and necessary out-of-pocket expenses pursuant to sections 328 and 330 of the Bankruptcy Code, the Bankruptcy Rules, the Local Rules, and such order as the Court may direct.

#### RELIEF REQUESTED

15. By this Application, SDV respectfully requests allowance and payment of fees (in the amount of \$230,840.00 (inclusive of the \$15,000.01 voluntary fee reduction)) and expenses incurred (in the amount of \$5,612.01) for services rendered by, for, and on behalf of Genever (US) during the Fee Period.

#### COMPENSATION AND VALUE OF SERVICES

16. To date, SDV has not submitted any fee or expense-related applications in these chapter 11 cases.

17. SDV has not received any payment or promise of payment from any source for services rendered during these chapter 11 cases. There is no agreement or understanding between SDV and any other person other than attorneys, employees, and staff of SDV, for the sharing of compensation to be received from services rendered in these chapter 11 cases.

18. SDV's professional services during the Fee Period required an expenditure of 534.20 recorded hours by attorneys and paraprofessionals, broken down as follows: partners (172.00 hours), associates (332.00 hours), and paraprofessionals (37.30 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.

19. SDV maintains computerized records, in the form of monthly statements, of the time spent by SDV's attorneys and paraprofessionals in connection with its representation of Genever (US). The monthly statements are in the same form regularly used by SDV to bill its clients for services rendered and include the date that the services were rendered, a detailed, contemporaneous narrative description of services provided, the amount of time spent for each service, and the designation of the professional who performed the service. Attached hereto as Exhibit B are true and correct copies of the monthly statements of SDV related to the fees requested herein.

20. The rates SDV charges for services rendered by its professionals and paraprofessionals in these chapter 11 cases are comparable to rates SDV charges for professional and paraprofessional services rendered in comparable non-bankruptcy related matters. In addition,

when SDV's 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 legal market.

21. The Trustee for Genever (US) has reviewed and approved this Application.

22. SDV has voluntarily reduced the fees it seeks in this Application by \$15,000. This voluntary reduction is made in good faith to avoid duplication of fees incurred by Genever (US) corresponding to substitute counsel becoming familiar with the issues and status of the Adversary Proceeding.

23. SDV respectfully submits that the reasonable value of the services rendered by SDV during the Fee period, inclusive of the \$15,000.01 voluntary fee reduction, is \$230,840.00.

#### SUMMARY OF FEES

24. During the Fee Period, SDV advised Genever (US) on a regular basis regarding legal matters concerning Genever (US)'s first- and thirty-party insurance, and represented Genever (US) in its insurance coverage for Genever (US)'s March 15, 2023 fire-related losses for the benefit of the chapter 11 estates and their creditors.

25. Specifically, during the Fee Period, SDV provided the following summarized services on behalf of Genever (US):

- advising Genever (US), through the Trustee, on its rights and obligations under its insurance policies; - commencing, conducting, and continuing litigation necessary and appropriate to assert rights held by Genever (US), pursuant to its insurance policies, to protect Genever (US)'s estate; - researching, preparing, and filing on behalf of Genever (US) as necessary and appropriate applications, motions, proposed orders, other pleadings, notices, schedules, and other documents; - analyzing and preparing written discovery and corresponding document productions; - taking and defending depositions; - preparing for and conducting a preliminary injunction hearing on behalf of Genever (US) to halt its insurer from cancelling the subject insurance policies which, in turn, would jeopardize Genever (US)'s interest in the largest asset of its estate; - advising Genever (US), through the Trustee, of evolving litigation activities and coverage events.

## CATEGORIZATION OF SERVICES

26. SDV has organized its time by category in respect to the nature of the services it provided to Genever (US), as follows:

#### A. Case Administration: Fees: \$21,869.50 Total Hours: 51.30

27. SDV performed services to assist Genever (US) in prosecuting coverage litigation via an adversary proceeding [Adv. Proceeding No. 5:23-05007] (the "Adversary Proceeding") against its insurance company, AIG Property Casualty Company ("AIG").

28. In the Adversary Proceeding, this included, among other things, searching for conflicts, responding to inquiries by the Trustee, reviewing schedules and other case filings prior to and after commencing the Adversary Proceeding, and preparing for and attending certain status conferences.

29. Additionally, in the Adversary Proceeding, SDV's services included work on Genever (US)'s petitions and schedules, counseling Genever (US), through the Trustee, with respect to filing the Adversary Proceeding, initial meetings with the Trustee to understand the scope and nature of the issues giving rise to the Adversary Proceeding, and attending to issues with respect to AIG's ongoing insurance investigation for Genever (US)'s March 15, 2023 fire-related losses.

#### B. General Litigation: Fees: \$213,335.50 Total Hours: 467

30. SDV has represented Genever (US) in the Adversary Proceeding to both (1) enjoin AIG from cancelling Genever (US)'s insurance policies, and (2) recover insurance benefits under Genever (US)'s first- and third-party insurance policies for its March 15, 2023, fire-related losses.

31. In the Adversary Proceeding, SDV's general litigation services included, among other things, case initiation, preparation and filing of applications, motions, proposed orders, documents, and other pleadings with the Court, and discovery.

32. Additionally, SDV's services and work have included strategizing and advising Genever (US), through the Trustee, on Genever (US) various rights and remedies pursuant to its first- and third-party insurance.

#### C. Court Hearings: Fees: \$10,635.00 Total Hours: 23

33. During the Fee Period, SDV professionals attended the May 19, 2023 status conference and the July 12, 2023 hearing in the on Genever (US)'s Motion for Preliminary Injunction [See Docket No. 32].

#### REASONABLENESS OF COMPENSATION

34. Section 331 of the Bankruptcy Code provides for interim compensation of professionals and incorporates the substantive standard 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).3

35. 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, issue, or tasked assigned, 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 Courts enjoy "considerable discretion in determining reasonable fee awards." In re Ahead Commc'n Sys., Inc., 395 B.R. 512 (D. Conn. 2008).

36. In assessing the "reasonableness" of the fees applied, the Second Circuit has stated that courts should consider the factors enumerated in Johnson v. Georgia Highway Express, Inc.,4 while also incorporating the "lodestar method." See Arbor Hill Concerned Citizens Neighborhood Ass'n v. County of Albany & Albany Cty. 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 . . .

3 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).

4 The twelve (12) Johnson factors are (1) time spent and labor required, (2) the novelty and difficulty of the questions, (3) the skill requisite to perform the legal service provided, (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.

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

37. In accordance with the factors enumerated in section 330 of the Bankruptcy Code

and applicable case law, the amount requested herein by SDV is fair and reasonable, as set forth

below and otherwise in this Application.

### Time and Labor Required

SDV billed a total of \$245,840.00 and 541.30 hours, respectively, of professional and paraprofessional services during the Fee Period. As evidenced in this Application, SDV professionals and paraprofessionals worked diligently and efficiently without unnecessary duplication of efforts throughout the Fee Period. A small group of SDV attorneys was utilized for the vast majority of the work in order to minimize costs of intra-SDV communication and education about Genever (US)'s circumstances. Whenever possible, SDV sought to minimize the cost of SDV's services by utilizing talented junior attorneys and paraprofessionals to manage more routine aspects of the assignment. The services were performed in an effective and efficient manner commensurate with the complexity, exigency, and importance of the issues involved. In addition, SDV's representation has required it to balance the need to provide quality services with the need to act quickly and represent the Genever (US) in an effective, efficient, and timely manner. SDV submits that the hours spent were reasonable given the size and complexity of the Adversary Proceeding, the significant, and often urgent, legal and business issues raised, and the numerous filings and discovery engaged in Adversary Proceeding.

5 The factors articulated in First Colonial were first articulated by the Fifth Circuit in Johnson, with the First Colonial court adding the factors of the "spirit of the economy," which was later rejected by Congress. See Strook & Strook & Lavan v. Hillsborough Holdings Corp. (In re Hillsborough Corp.), 127 F.3d 1398, 1403 (11th Cir. 1997)

#### Novelty and Difficulty of the Questions

SDV tasked knowledgeable attorneys to research, analyze, and advise Genever (US), through the Trustee, on difficult and complex issues during the Fee Period, including issues related to bankruptcy and litigation. Most notably, as detailed in this Application, SDV analyzed Genever (US)'s first- and third-party insurance policies, initiated the Adversary Proceeding, and represented Genever (US) in a preliminary injunction hearing.

#### Skill Requisite to Perform the Legal Services Properly

SDV believes that its recognized expertise in the areas of insurance coverage, and its creative approach to the resolution of issues has contributed to the effective administration of these chapter 11 cases, via the Adversary Proceeding, and benefited the Genever (US), its estate, and unsecured creditors. Due to the nature and complexity of the legal issues presented by the Adversary Proceeding, SDV was required to exhibit a high degree of legal skill in areas related to, among others, coverage litigation.

Preclusion of Other Employment by Applicant Due to Acceptance of the Case Due to SDV's size, SDV's representation of the Genever (US) did not preclude its acceptance of new clients, but the demands for immediate and substantive action in the Adversary Proceeding imposed significant burdens on SDV professionals and paraprofessionals working concurrently on other matters.

#### Customary Fee

The fees charged by SDV in these chapter 11 cases are billed in accordance with its existing billing rates and procedures in effect during the Fee Period. The rates SDV charges for the services rendered by its professionals and paraprofessionals in these chapter 11 cases are comparable to the rates SDV charges for professional and paraprofessional services rendered in comparable non-bankruptcy related matters. Moreover, when SDV's 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 non-bankruptcy cases in a competitive national legal market. In addition, the firm's customary hourly rates and rate structure reflect that related matters typically involve great complexity, numerous tasks requiring a high level of expertise, and severe time pressures, as is the case here.

#### Whether the Fee is Fixed or Contingent

Pursuant to Bankruptcy Code sections 330 and 331, all fees sought by professionals employed under Bankruptcy Code sections 327(e), 328(a), and 329(a) are subject to final approval by the Court, and are subject to adjustment depending on the services rendered and the results obtained. SDV's fees are fixed, as it was agreed SDV would charge Genever (US) for its legal services on an hourly basis at SDV's standard hourly rates in effect at the time the services were performed in connection with the Adversary Proceeding [See Docket Nos. 1870, 1963].

#### The Limitations Imposed by the Client or Other Circumstances

During the Fee Period, SDV was required to analyze and address certain issues arising in these chapter 11 cases under compressed timelines. Specifically, SDV was required to act immediately to halt AIG's cancellation of Genever (US)'s insurance, which was originally set to take effect on May 31, 2023. Moreover, SDV was required to act immediacy to pursue coverage under Genever (US)'s insurance policies for Genever (US)'s March 15, 2023 fire-related losses given Genever (US)'s ever-increasing third-party liability to others who have been allegedly harmed by Genever (US)'s March 15, 2023, fire-related losses.

### The Amount Involved and Results Obtained

SDV professionals and paraprofessionals worked diligently to maximize value for Genever (US)'s chapter 11 estate. During the Fee Period, and as described in the summary of services herein, SDV was instrumental in analyzing insurance recovery and preservation for the benefit of the estate. As a result of SDV's efforts, Genever (US) received \$25,000 from AIG for emergency clean-up expenses, and AIG has been preliminarily enjoined from cancelling Genever (US)'s insurance policies which, if cancelled, would jeopardize Genever (US)'s interest in the largest asset of its estate. The reasonableness of SDV's fees must be evaluated in light of these important strategic factors as well.

### Experience, Reputation, and Ability of the Attorneys

SDV has represented policyholders for more than twenty-five (25) years, helping them navigate a vast array of complex coverage issues. SDV is consistently recognized within the insurance industry as a top tier law firm for policyholders. During the Application Period, SDV solicited the skill and expertise of its professionals and paraprofessionals. SDV professionals have actively represented policyholders in complex coverage litigation. SDV's extensive experience enables it to perform the services described herein competently and expeditiously.

## "Undesirability" of the Case

As described in this Application, the immediacy and time necessarily devoted to the Adversary Proceeding in the absence of prompt and certain payment for fees and expenses makes the case less desirable than other cases upon which SDV is often engaged.

#### Nature and Length of Professional Relationship

SDV has been providing professional services to Genever (US), through the Trustee since its retention as counsel effective May 11, 2023.

38. SDV respectfully submits that the services for which it seeks compensation in this

Fee Application were, at the time rendered, necessary for and beneficial to Genever (US)'s estate

and its creditors and were rendered to maximize, protect, and preserve the value of Genever (US)'s

estate and all parties in interest. SDV believes that it provided services economically, effectively, and efficiently, and obtained results beneficial to the Debtor's estate and his creditors. SDV further submits that the compensation requested herein is reasonable in light of the nature, extent, and value of the services rendered during the Fee Period.

39. SDV also notes that the rates charged during the Fee Period are reasonable, and comparable to similarly-situated coverage counsel within a competitive legal market.

40. All fees incurred by SDV during the Fee Period were actual, reasonable, and necessary in the performance of services for Genever (US). SDV respectfully requests approval of the compensation sought herein.

#### ACTUAL AND NECESSARY EXPENSES

41. As set forth in Exhibit C hereto, SDV incurred and disbursed \$5,413.36 as expenses in providing professional services during the Fee Period (exclusive of the period of May 11, 2023 through August 21, 2023). These expenses include approximately \$1,245.23 for online legal research (i.e., Westlaw). Because SDV believes that online research (i.e., Westlaw) is far more cost-effective than manual research using hard-bound volumes, SDV encourages computerized legal research even though it is not a profit center for SDV. To be clear, SDV does not charge a mark-up on the 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, SDV is merely passing on the costs of such third-party services, without any mark-up.6

- 42. Additional necessary expenses include: - \$894.30 for deposition transcript services provided by Trustpoint Court Reporting, LLC; - \$350.00 for filing fee;

6 Documentation of these expenses will be made available to the Court upon request.

- \$266.00 for process servicers; - \$177.30 for transcript services; and - \$13.00 for court hearing-related parking.

43. During the Fee Period, SDV utilized Everlaw—a third-party vendor that specializes in electronic discovery services including document processing, storage, and distributions—to store documents produced in the Adversary Proceeding, including approximately 375 discovery documents received by Genever (US) to-date in connection with its prosecution of the Adversary Proceeding. SDV has been billed and/or incurred \$20.00 for actual and necessary services rendered by Everlaw in connection with the Adversary Proceeding.

44. Additionally, during the Fee Period, SDV utilized Veritext, LLC—a third-party vendor that specializes in remote deposition services including remote deposition facilitation, recording, and transcription—to facilitate depositions taken on behalf of Genever (US) in the Adversary Proceeding. SDV has been billed and/or incurred \$2,646.18 for actual and necessary services rendered by Veritext in connection with the Adversary Proceeding.

45. The expenses requested herein are customarily charged to non-bankruptcy clients of SDV. Additionally, the expenses incurred by SDV to third parties are limited to the actual amounts billed to, or paid by, SDV on behalf of Genever (US).

46. SDV believes the rates for charges incurred are the market rates that the majority of law firms charge their clients for such services. In addition, SDV 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.

47. The expenses incurred in providing professional services in the Adversary

Proceeding were necessary, economical, and justified under the circumstances.

### RESPONSE TO THE U.S. TRUSTEE GUIDLINES

48. SDV responds to the questions set forth in Paragraph C.5 of the U.S. Trustee

Guidelines as follows:

- Question: Did you agree to any variation from, or alternatives to, your standard of customary billing rates, fees, or terms of services pertaining to this engagement that were provided during the Application Period? - Response: No. - Question: If the fees sought in this application as compared to the fees budgeted for this Application 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 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 time 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 the hours and fees. - Response: The Application does not include time for preparing, reviewing, or revising time records other than time attributable to preparation of this Application. - 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: The Application does not include time for reviewing time records to redact any privileged or other confidential information other than time attributable to preparation of this Application. The total time attributable to redacting time records in preparation of this Application is 1.00 hours.

Question: If the application includes any rate increases since retention: (1) 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 rate increases? If not, did you inform your client 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: Not applicable.

#### RESERVATION OF RIGHTS

49. 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 SDV has for any reason not sought compensation or reimbursement with respect to such services, SDV reserves the right to request compensation and reimbursement for such services in a supplemental application in these Chapter 11 Cases. Also, SDV does not waive, and expressly reserves, its right to respond to any objection regarding this Application and the amounts sought for services rendered and expenses incurred.

#### NO PRIOR REQUEST

50. No previous request for relief sought herein has been made to this Court or any other court.

WHEREFORE, SDV respectfully requests entry of an order, substantially in the form attached hereto, (i) allowing final compensation for professional services rendered and expenses incurred during the Fee Period in the amount of \$236,452.00, (ii) authorizing and directing prompt payment from the chapter 11 estate of Genever (US), (iii) allowing such compensation and payment for professional services rendered without prejudice to SDV's right to seek further compensation and/or payments from the Debtors' estates for the full value of services performed and expenses incurred, and (iv) granting SDV such other relief as is just.

Dated: August 30, 2023 Trumbull, Connecticut

Respectfully submitted, GENEVER HOLDINGS LLC

By: /s/ Brian J. Clifford

Brian J. Clifford (ct30442) Janie Reilly Eddy (ct31143) Saxe Doernberger & Vita 35 Nutmeg Drive, Suite 140 Trumbull, CT 06611 (203) 287-2100 bclifford@sdvlaw.com jeddy@sdvlaw.com

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

| ----------------------------------------------------------- | | x | | |-------------------------------------------------------------|-----------|---|-------------------------| | In re: | | : | Chapter 11 | | | | : | | | HO WAN KWOK, et al., | | : | Case No. 22-50073 (JAM) | | | Debtors.7 | : | | | ----------------------------------------------------- | | : | Jointly Administered | | | | x | |

#### CERTIFICATE OF SERVICE

The undersigned hereby certifies that on August 30, 2023, the foregoing Final Fee Application for Allowance of Compensation as Special Insurance Coverage Counsel Only to Debtor Genever Holdings, LLC was electronically filed. Notice of this filing was sent by e-mail to all parties to the above-captioned adversary proceeding by operation of the Court's electronic filing ("CM/ECF") system. Parties may access this filing through the Court's CM/ECF system.

Respectfully submitted, GENEVER HOLDINGS LLC

By: /s/ Brian J. Clifford

Brian J. Clifford (ct30442) Janie Reilly Eddy (ct31143) Saxe Doernberger & Vita 35 Nutmeg Drive, Suite 140 Trumbull, CT 06611 (203) 287-2100 bclifford@sdvlaw.com jeddy@sdvlaw.com

7 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).

#### EXHIBIT A (Proposed Order) EXHIBIT A (Proposed Order)

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

### [PROPOSED] ORDER GRANTING APPLICATION OF SAXE, DOERNBERGER & VIA, P.C., FOR ALLOWANCE OF COMPENSATION AS SPECIAL INSURANCE COVERAGE COUNSEL ONLY TO DEBTOR GENEVER HOLDINGS LLC

Upon review of the Application (the "Application") of Saxe, Doernberger & Vita, P.C. ("SDV") as counsel to Genever Holdings LLC ("Genever (US)") for allowance of compensation and reimbursement of expenses from the Petition Date2 through August 21, 2023; and sufficient notice has been given; and a hearing having been held on \_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_ \_\_\_\_\_, 2023; and due consideration having been given to any responses thereto; and sufficient cause having been shown therefor, it is hereby :

1. ORDERED that the Application is granted and compensation in the amount of \$236,452.00 is awarded to SDV, subject to final adjustment and disgorgement in the event all administrative expenses are not paid in full; it is further

2 Capitalized terms not otherwise defined herein adopt the definitions set forth in the Application.

2. ORDERED that the estate of Genever (US) is directed to pay SDV the fees allowed in paragraph 1 above in the aggregate amount of \$236,452.00 within five (5) days after entry of the Debtor in Possession Financing Order; it is further

3. ORDERED that this Court shall retain jurisdiction to hear and determine all matters arising from the implementation of this Order; it is further

4. ORDERED that the Trustee and SDV are authorized and empowered to take all necessary actions to implement the relief granted in this Order; it is further

5. ORDERED that notwithstanding the possible applicability of Bankruptcy Rules 600(d), 7062, 9014, or otherwise, the terms and conditions of this Order shall be immediately effective and enforceable upon its entry; and it is further

6. ORDERD that all time periods set forth in this Order shall be calculated in accordance with Bankruptcy Rule 9006(a).

#### EXHIBIT B (Monthly Fee Statement) EXHIBIT B (Monthly Fee Statement)

#### TIMEKEEPER ABBREVIATION KEY

| Timekeeper | Abbreviation | | | |------------------------|--------------|--|--| | Bussola, Alexa | ALB | | | | Clifford, Brian | BJC | | | | Eddie, Janie | JRE | | | | Jordan, David | DGJ | | | | King-Morrison, Suzette | SKM | | | | Markham, Sarah | SJM | | | | Mitel, Lynn | LAM | | | | Rudolph, Kyle | KR | | | | Saxe, Tracy | TAS | | | | Stallmach, Oliver | OPS | | |

Case 22-50073 Doc 2156 Filed 08/30/23 Entered 08/30/23 14:48:24 Page 26 of 78

![](_page_25_Picture_1.jpeg)

**VIA E-Mail** July 27, 2023

Luc A. Despins Invoice #: 296388 Ho Wan Kwok and Genever Holdings LLC Client #: 4238 c/o Paul Hastings LLP Matter #: GENEVERH1 200 Park Avenue New York, NY 10166

# **INVOICE SUMMARY**

\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_

For professional services rendered through May 31, 2023:

#### **RE: Sherry-Netherland Loss**

| TOTAL THIS INVOICE | \$ 89,780.00 | |-----------------------|--------------| | Total Expenses | \$ 616.00 | | Professional Services | \$ 89,164.00 |

Invoice #: 296388 July 27, 2023

#### **PROFESSIONAL SERVICES RENDERED**

SAXE DOERNBERGER & VITA, P.C. Case 22-50073 Doc 2156 Filed 08/30/23 Entered 08/30/23 14:48:24 Page 28 of 78

| Date | Atty | Description of Service | Hours | Amount | |---------|------|---------------------------------------------------------------------------------------------------------------------------|-------|----------| | 5/11/23 | KR | Collated and paginated exhibits for Complaint; noted | .90 | 292.50 | | | | | | | | 5/11/23 | KR | Added citations to exhibit references throughout the entire Complaint; | 2.50 | 812.50 | | | | proofread, made edits and comments to entire final draft of Complaint; conferred RE | | | | | | | | | | 5/11/23 | KR | Analyzed current draft of | 1.00 | 325.00 | | | | and annotated notes for same; confer | | | | 5/12/23 | TAS | Analyze issues and strategy including email by and among Team; | .60 | 585.00 | | 5/12/23 | DGJ | Review of complaint against AIG and review correspondence related to | .30 | 181.50 | | | | same. | | | | 5/12/23 | BJC | Review and final revision of complaint. | 2.80 | 1,610.00 | | 5/12/23 | BJC | Coordinate finalization and details concerning filing. | 2.50 | 1,437.50 | | 5/12/23 | BJC | Prepare correspondence to J. O'Connor, counsel for AIG, concerning filing of complaint, willingness to accept service. | .40 | 230.00 | | 5/12/23 | BJC | Prepare correspondence to adjuster John Panic re copy of complaint and | .10 | 57.50 | | | | exhibits. | | | | 5/12/23 | KR | Analyze issues with exhibits | .20 | 65.00 | | 5/12/23 | KR | Calls with Luc Despins RE | .40 | 130.00 | | 5/12/23 | KR | Finalize Complaint, exhibits, and civil cover sheet before filling Complaint against AIG before COB 5/12/2023. | 3.50 | 1,137.50 | | 5/12/23 | KR | Reviewed final version of Civil Cover Sheet and Complaint before filing. | .30 | 97.50 | | 5/12/23 | KR | Confer RE | .20 | 65.00 | | | | | | | | 5/12/23 | KR | Reformatted Genever's | 1.10 | 357.50 | | | | ; analyzed and edited | | | | | | | | | | 5/13/23 | TAS | Analyze strategy including email by and among team; | .30 | 292.50 | | 5/13/23 | KR | Analyzed, reviewed, and edited argument section A of Genever (US)'s | 1.70 | 552.50 | | | | ; analyzed and inserted additional caselaw | | | | | | | | | | 5/13/23 | KR | Finished analyzing, editing, and adding to argument sections B and C of | 1.00 | 325.00 | | 5/13/23 | KR | Genever (US)'s Proofread and edited | .10 | 32.50 | | | | | | | | 5/13/23 | KR | Insert all citations to the record in Genever (US)'s | 1.30 | 422.50 | | | | ; performed one, last final proofread of the initial complete draft of the Motion. | | |

SAXE DOERNBERGER & VITA, P.C. Case 22-50073 Doc 2156 Filed 08/30/23 Entered 08/30/23 14:48:24 Page 29 of 78

| Date | Atty | Description of Service | Hours | Amount | |---------|------|-----------------------------------------------------------------------------------------------------------|-------|----------| | 5/13/23 | KR | Analyzed | 1.40 | 455.00 | | | | | | | | | | ; analyzed issue of | | | | | | ; identified and drafted summary of | | | | | | | | | | 5/14/23 | BJC | Coordinate further revision of motion for preliminary injunction and research. | .60 | 345.00 | | 5/14/23 | BJC | Review and revise Motion to Expedite Preliminary Injunction. | .80 | 460.00 | | 5/14/23 | BJC | Review and revise Motion for Preliminary Injunction. | 1.90 | 1,092.50 | | 5/14/23 | KR | Analyzed caselaw RE | 1.30 | 422.50 | | 5/14/23 | KR | Emails to Luc Despins RE | .10 | 32.50 | | 5/14/23 | KR | Created ; emailed copy to Luc Despins. | .10 | 32.50 | | 5/14/23 | KR | Formatted Motion to Expedite; updated the Proposed Order and Certificate of Service for same. | .20 | 65.00 | | 5/14/23 | KR | Incorporated | .30 | 97.50 | | | | ; emailed Luc Despins RE | | | | 5/14/23 | KR | Phone call with Luc Despins RE | .20 | 65.00 | | 5/14/23 | KR | Drafted Motion to Expedite Hearing for Preliminary Injunction. | 1.20 | 390.00 | | 5/14/23 | KR | Made change to of Genever (US)'s Motion for Preliminary Injunction | .10 | 32.50 | | 5/14/23 | KR | Analyzed national caselaw RE | 2.20 | 715.00 | | | | ; annotated findings on same | | | | | | | | | | | | | | | | 5/14/23 | KR | Draft and send email to Luc Despins | .20 | 65.00 | | | | | | | | 5/15/23 | TAS | Email with client; ; | .60 | 585.00 | | 5/15/23 | BJC | Prepare correspondence to J. O'Connor, AIG's counsel, concerning | .20 | 115.00 | | | | acceptance of service. | | | | 5/15/23 | BJC | Review revisions to Motion for Preliminary Injunction; finalize same and motion for expedited hearing. | 2.20 | 1,265.00 | | 5/15/23 | BJC | TC L. Medeiros at NFP (x2) concerning | .60 | 345.00 |

# SAXE DOERNBERGER & VITA, P.C. Case 22-50073 Doc 2156 Filed 08/30/23 Entered 08/30/23 14:48:24 Page 30 of 78

| Date | Atty | Description of Service | Hours | Amount | |---------|------|---------------------------------------------------------------------------------------------------------------------------------------------|-------|--------| | 5/15/23 | BJC | Strategize concerning | .30 | 172.50 | | 5/15/23 | BJC | Review summons issued by Bankruptcy Court; coordinate service. | .20 | 115.00 | | 5/15/23 | BJC | Strategize concerning hearing on motion for preliminary injunction. | .50 | 287.50 | | 5/15/23 | KR | Strategize arguments and issues that should be addressed in Genever (US)'s | .20 | 65.00 | | 5/15/23 | KR | Analyzed Complaint and drafted outline | .40 | 130.00 | | 5/15/23 | KR | Strategize issues with service and whether Genever (US) can | .40 | 130.00 | | | | | | | | 5/15/23 | KR | Drafted rule paragraphs | .50 | 162.50 | | 5/16/23 | TAS | Analyze issues and strategy; | .80 | 780.00 | | 5/16/23 | BJC | TC L. Despins (x2) concerning | .80 | 460.00 | | 5/16/23 | BJC | TC J. O'Connor, counsel for AIG, concerning proposal for moving preliminary injunction hearing date. | .70 | 402.50 | | 5/16/23 | JRE | Analyzed bankruptcy procedural rules in preparation of expedited hearing. | .40 | 190.00 | | 5/16/23 | JRE | Reviewed and analyzed pleadings in preparation of hearing. | .70 | 332.50 | | 5/16/23 | JRE | Prepared for and attended meeting in preparation of preliminary injunction. | .60 | 285.00 | | 5/16/23 | JRE | Draft letter to O'Connor. | .50 | 237.50 | | 5/16/23 | JRE | Strategized | 1.20 | 570.00 | | 5/16/23 | JRE | Reviewed and analyzed factual background in preparation of expedited hearing. | 1.50 | 712.50 | | 5/16/23 | SJM | BJC Bankruptcy Trustee Matter* Discuss with BJC, paralegal process to withdraw appearance from CT state court case. | .30 | 97.50 | | 5/16/23 | SJM | BJC Bankruptcy Trustee Matter* Analyze CT authority regarding | 1.50 | 487.50 | | 5/16/23 | KR | Drafted introduction, factual background, basis for relief requested and conclusion sections | 1.70 | 552.50 | | 5/17/23 | BJC | TC J. O'Connor (x2) counsel for AIG, concerning AIG's position continuing hearing, coordinating his signature on waiver of service form. | .50 | 287.50 | | 5/17/23 | BJC | Begin preparation of outline | 1.60 | 920.00 | | 5/17/23 | BJC | Prepare correspondence (x2) to L. Despins concerning | .30 | 172.50 | | 5/17/23 | JRE | Continued formulating strategy | 1.10 | 522.50 | | 5/17/23 | JRE | Finalized discovery demand letter to O'Connor. | .20 | 95.00 | | 5/17/23 | JRE | Continued preparing arguments for hearing Re: | .30 | 142.50 | | 5/17/23 | JRE | Drafted waiver of service. | .30 | 142.50 | | 5/17/23 | JRE | Continued preparing for hearing re: | .50 | 237.50 |

| Date | Atty | Description of Service | Hours | Amount | |--------------------|------------|------------------------------------------------------------------------------------------------|--------------|--------------------| | 5/17/23 | KR | Analyzed New York authority RE | 1.30 | 422.50 | | | | ; drafted argument section | | | | 5/17/23 | KR | Strategize breakdown of and discussed | .30 | 97.50 | | | | | | | | 5/17/23 | KR | Analyzed relevant authority RE | 1.00 | 325.00 | | 5/17/23 | KR | and drafted argument section RE same. Drafted argument section | .60 | 195.00 | | | | | | | | | | | | | | 5/17/23 | KR | Analyzed New York authority on | 3.10 | 1,007.50 | | | | ; drafted argument section | | | | | | | | | | | | | | | | 5/18/23 | TAS | Prep for hearing including call with Trustee; | .80 | 780.00 | | 5/18/23 | BJC | Strategize concerning | 1.10 | 632.50 | | 5/18/23 | BJC | Review correspondence (x2) from L. Despins concerning | .50 | 287.50 | | | | ; prepare correspondence (x2) to L. Despins re same. | | | | 5/18/23 | BJC | Prepare letter to AIG concerning opportunity to inspect premises in | 1.40 | 805.00 | | | | connection with need to remove furniture. | | | | 5/18/23 5/18/23 | BJC BJC | TC L. Despins re Draft letter to J. O'Connor, counsel for AIG, concerning identification of | 2.00 1.00 | 1,150.00 575.00 | | | | witnesses, exhibits; draft e-mail correspondence to J. O'Connor re same, | | | | | | scheduling depositions and, if necessary, scheduling a status conference with the court. | | | | 5/18/23 | JRE | Genever*Continued analysis of motion arguments in preparation of the | 1.80 | 855.00 | | | | hearing. | | | | 5/18/23 | JRE | Genever*Continued analysis of factual background to support hearing. | 2.00 | 950.00 | | 5/18/23 | JRE | Genever*Continued formulating argument | .80 | 380.00 | | 5/18/23 | JRE | Genever*Analyzed | .50 | 237.50 | | 5/18/23 | JRE | Genever*Meeting with client and continued strategy. | 1.50 | 712.50 | | 5/18/23 | KR | Drafted | .40 | 130.00 | | 5/18/23 | KR | Finished initial, complete draft of | 1.50 | 487.50 | | | | | | | | 5/18/23 | KR | Drafted Proposed Order | .40 | 130.00 | | 5/18/23 | KR | Drafted initial draft | 1.10 | 357.50 | | 5/18/23 | KR | Strategize issues AIG may raise | .30 | 97.50 | | | | | | | | 5/18/23 | KR | Drafted | .70 | 227.50 |

SAXE DOERNBERGER & VITA, P.C. Case 22-50073 Doc 2156 Filed 08/30/23 Entered 08/30/23 14:48:24 Page 32 of 78

Invoice #: 296388 July 27, 2023

| Date | Atty | Description of Service | Hours | Amount | |---------|------|-----------------------------------------------------------------------------------------------------------------------------------------|-------|--------| | 5/18/23 | KR | Analyzed national authority RE | 2.50 | 812.50 | | | | ; drafted | | | | 5/18/23 | KR | Analyzed New York authority RE | 1.30 | 422.50 | | | | ; drafted | | | | | | | | | | | | | | | | 5/18/23 | KR | | .70 | 227.50 | | 5/19/23 | TAS | Genever* email by and among Team; | .30 | 292.50 | | 5/19/23 | BJC | Genever(US)/Kwok*Review correspondence from J. O'Connor | .20 | 115.00 | | | | concerning depositions to prepare for motion for preliminary injunction on May 24. | | | | 5/19/23 | BJC | Genever(US)/Kwok*Prepare draft correspondence to Judge Manning's | 1.20 | 690.00 | | | | courtroom deputy in connection with scheduling of emergency status conference concerning preparation for May 24 preliminary hearing; | | | | | | finalize same to send to Judge Manning. | | | | 5/19/23 | BJC | Genever(US)/Kwok*Prepare for emergency status conference before Judge Manning. | 1.50 | 862.50 | | 5/19/23 | BJC | Genever(US)/Kwok*Status conference before Judge Manning. | .20 | 115.00 | | 5/19/23 | BJC | Genever(US)/Kwok*Status conference before Judge Manning. | .40 | 230.00 | | 5/19/23 | BJC | Genever(US)/Kwok*Coordinate next steps, including | .70 | 402.50 | | | | | | | | 5/19/23 | BJC | Genever(US)/Kwok*Review and revise declaration from Attorney Linsay | .50 | 287.50 | | | | re notice to AIG of bankruptcy. | | | | 5/19/23 | JRE | Analyzed exhibits for hearing. | .40 | 190.00 | | 5/19/23 | JRE | Finalized letter to A. Bono regarding reservation of rights to AIG. | .50 | 237.50 | | 5/19/23 | JRE | Analyzed 5/19/2023 letter from AIG regarding cleanup costs. | .30 | 142.50 | | 5/19/23 | JRE | Drafted revisions to | .70 | 332.50 | | 5/19/23 | JRE | Drafted revisions to | .20 | 95.00 | | 5/19/23 | JRE | Genever*Analyzed and drafted revisions to initial response to AIG. | .30 | 142.50 | | 5/19/23 | JRE | Genever*reviewed appearance from Gordon Rees | .10 | 47.50 | | 5/19/23 | JRE | Genever*Prepared for status conference. | .90 | 427.50 | | 5/19/23 | JRE | Genever*Phone call with L. Despins regarding | .20 | 95.00 | | 5/19/23 | JRE | Genever*Post-hearing strategy. | .80 | 380.00 | | 5/19/23 | JRE | Genever*Phone call with L. Despin regarding | .20 | 95.00 | | 5/19/23 | JRE | Genever* | .70 | 332.50 | | 5/19/23 | JRE | Genever*Strategy regarding | .90 | 427.50 | | 5/19/23 | KR | Analyzed the AIG Insurance Policies' | .90 | 292.50 | | | | ; drafted summary of AIG Insurance Policies' | | |

for memo on same.

| Date | Atty | Description of Service | Hours | Amount | |---------|------|------------------------------------------------------------------------------------------------------------------------|-------|--------| | 5/19/23 | KR | Analyzed New York authority RE | 1.70 | 552.50 | | | | incorporated summary of findings on | | | | | | same in memo | | | | | | | | | | 5/19/23 | KR | Analyzed national authority | .70 | 227.50 | | | | ; incorporated | | | | | | summary of findings on same in memo | | | | | | | | | | 5/19/23 | KR | Analyzed New York authority RE ; incorporated summary of | 1.60 | 520.00 | | | | findings on same in memo | | | | | | | | | | 5/19/23 | KR | Drafted analysis sections and executive summary for memo RE | 1.00 | 325.00 | | 5/21/23 | JRE | Follow up email correspondence with L. Despins regarding | .20 | 95.00 | | | | | | | | 5/21/23 | JRE | | .80 | 380.00 | | 5/22/23 | BJC | Review correspondence from J. O'Connor, counsel for AIG, concerning | .20 | 115.00 | | | | proposal to continue preliminary injunction hearing. | | | | 5/22/23 | BJC | Strategize concerning | .50 | 287.50 | | 5/22/23 | BJC | Strategize concerning | .30 | 172.50 | | | | | | | | 5/22/23 | JRE | Strategized proposal from AIG to extend cancellation. | .40 | 190.00 | | 5/22/23 | JRE | Drafted | .20 | 95.00 | | 5/22/23 | JRE | Reviewed J. Connor's email regarding AIG extension. | .20 | 95.00 | | 5/22/23 | JRE | Phone call with L. Despins regarding | .20 | 95.00 | | 5/22/23 | JRE | Initial phone call with J. O'Connor regarding discovery schedule. | .30 | 142.50 | | 5/22/23 | JRE | Email from J. O'Connor regarding revised discovery proposal. | .10 | 47.50 | | 5/22/23 | JRE | Response to J. O'Connor regarding revised discovery proposal. | .20 | 95.00 | | 5/22/23 | JRE | Follow up phone call with J. O'Connor regarding revised discovery schedule to be submitted to the court. | .30 | 142.50 | | 5/22/23 | JRE | Reviewed J. O'Connor's email to the court regarding extension of policy cancellation and proposed hearing schedule. | .10 | 47.50 | | 5/22/23 | JRE | Analyzed case law regarding | .50 | 237.50 | | | | | | | | 5/22/23 | JRE | | 1.80 | 855.00 | | 5/22/23 | JRE | Additional revisions | .30 | 142.50 | | | | | | | | 5/22/23 | JRE | Preparations for hearing Re: | .20 | 95.00 | | 5/22/23 | JRE | Reviewed and revised declaration of B. Clifford. | .10 | 47.50 | | 5/22/23 | JRE | Continued analysis of policy provisions for | 1.50 | 712.50 |

| Date | Atty | Description of Service | Hours | Amount | |---------|------|------------------------------------------------------------------------------------------------------------------------------------|-------|----------| | 5/23/23 | TAS | Genever* correspondence re preliminary injunction hearing; | .20 | 195.00 | | 5/23/23 | TAS | Genever* analyze strategy re | .30 | 292.50 | | | | ; | | | | 5/23/23 | DGJ | Review of correspondence re: Court hearing and re AIG agreement to defer cancellation of coverage. | .10 | 60.50 | | 5/23/23 | BJC | Review BJC declaration in support of SDV application to be admitted as coverage counsel. | .50 | 287.50 | | 5/23/23 | BJC | Strategize concerning | 1.10 | 632.50 | | 5/23/23 | JRE | Confirmed status of conflict checks for retention application. | .10 | 47.50 | | 5/23/23 | JRE | Revised B. Clifford declaration for retention application. | .10 | 47.50 | | 5/23/23 | JRE | Reviewed M. Bono's response to 5/19 letter regarding requested vendor for cleanup. | .20 | 95.00 | | 5/23/23 | JRE | Follow up call with L. Despin regarding | .20 | 95.00 | | 5/23/23 | JRE | Phone call from J. O'Connors regarding court hearing. | .20 | 95.00 | | 5/23/23 | JRE | Phone call from M. Thompson regarding court hearing. | .10 | 47.50 | | 5/23/23 | JRE | Draft response to M. Bono regarding ongoing reservation of rights under policies regarding acceptance of advance. | .70 | 332.50 | | 5/23/23 | JRE | Scheduling meeting with J.O'Connor and L. Despins regarding hearing dates. | .20 | 95.00 | | 5/23/23 | JRE | | .90 | 427.50 | | 5/23/23 | JRE | Formulated strategy regarding | .90 | 427.50 | | 5/23/23 | JRE | Email to J. O'Connors regarding preliminary witness list for the hearing. | .20 | 95.00 | | 5/23/23 | JRE | Drafted coverage position letter to AIG. | .50 | 237.50 | | 5/23/23 | JRE | Follow up email with E. Sutton regarding conflict checks. | .10 | 47.50 | | 5/23/23 | JRE | Email correspondence with J. O'Connor extending cancellation date until July 14th. | .10 | 47.50 | | 5/23/23 | JRE | Email correspondence from counsel from S-N regarding cleanup. | .10 | 47.50 | | 5/23/23 | SKM | Review CTB notice of filing; review case docket and download the court's | .30 | 70.50 | | | | order granting motion for admission of visiting attorney Jon O'Connor; upload and update pleading folder; update pleading chart | | | | 5/23/23 | KR | Updated ; consolidated ; drafted | 1.00 | 325.00 | | 5/23/23 | KR | Added additional facts to Genever (US)'s | .80 | 260.00 | | | | | | | | 5/24/23 | TAS | ; | .40 | 390.00 | | 5/24/23 | BJC | Strategize concerning | .30 | 172.50 | | 5/24/23 | BJC | Review and revise ; coordinate further revisions of same. | 3.20 | 1,840.00 | | 5/24/23 | JRE | Phone call with J. O'Connor regarding new schedule. | .10 | 47.50 |

# SAXE DOERNBERGER & VITA, P.C. Case 22-50073 Doc 2156 Filed 08/30/23 Entered 08/30/23 14:48:24 Page 35 of 78

| Date | Atty | Description of Service | Hours | Amount | |---------|------|-------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|-------|--------| | 5/24/23 | JRE | Email correspondence with L. Despins regarding | .10 | 47.50 | | 5/24/23 | JRE | Email correspondence with L. Despins regarding | .20 | 95.00 | | 5/24/23 | JRE | Continued formulating strategy re: | .30 | 142.50 | | 5/24/23 | JRE | Follow up phone call with J. O'Connor regarding discovery schedule for preliminary injunction. | .20 | 95.00 | | 5/24/23 | JRE | Follow up phone call with L. Despins regarding approval | .10 | 47.50 | | 5/24/23 | JRE | Attended hearing re: scheduling for preliminary injunction. | .40 | 190.00 | | 5/24/23 | JRE | Reviewed judicial order regarding preliminary injunction hearing. | .10 | 47.50 | | 5/24/23 | JRE | Email from L. Despins regarding | .10 | 47.50 | | 5/24/23 | JRE | | 1.10 | 522.50 | | 5/24/23 | SKM | Review CTB notice of filing; download and review the order continuing evidentiary hearing on motion for preliminary injunction; upload and update pleading folder; update calendar with new deadlines | .50 | 117.50 | | 5/24/23 | KR | Analyzed AIG's reservations of rights letter and subsequent correspondence ; analyzed and summarized New York authority RE | 2.40 | 780.00 | | | | | | | | 5/24/23 | KR | Incorporated arguments into Genever (US)'s | 1.00 | 325.00 | | 5/24/23 | KR | Analyzed authority RE | 1.80 | 585.00 | | | | | | | | 5/24/23 | KR | Strategize | .20 | 65.00 | | 5/24/23 | KR | Strategize | .20 | 65.00 | | 5/24/23 | KR | Analyzed New York authority RE | .80 | 260.00 | | 5/24/23 | KR | Added section to Genever (US)'s | .50 | 162.50 | | 5/24/23 | KR | Proofread, added citations, and made comments | .50 | 162.50 | | 5/24/23 | KR | Analyzed cases illustrating | .80 | 260.00 | | | | ; added those cases to | | | | | | | | | | 5/25/23 | JRE | Revised | 1.50 | 712.50 | | 5/25/23 | JRE | Continued | 1.90 | 902.50 |

SAXE DOERNBERGER & VITA, P.C. Case 22-50073 Doc 2156 Filed 08/30/23 Entered 08/30/23 14:48:24 Page 36 of 78

| Date | Atty | Description of Service | Hours | Amount | |---------|------|-----------------------------------------------------------------------------------------|-------|----------| | 5/25/23 | KR | Confer RE | .40 | 130.00 | | 5/25/23 | KR | Made final changes to argument sections ; analyzed additional authority RE | 1.50 | 487.50 | | 5/25/23 | KR | Removed and added ; proofread | 1.60 | 520.00 | | 5/26/23 | TAS | Analyze issues re in advance of preliminary injunction hearing; | .40 | 390.00 | | 5/26/23 | BJC | | .40 | 230.00 | | 5/26/23 | BJC | Strategize re | 1.30 | 747.50 | | 5/26/23 | BJC | TC L. Medeiros of NFP re | .40 | 230.00 | | 5/26/23 | LAM | Draft Requests for Production, Interrogatories and Requests to Admit | 1.40 | 329.00 | | 5/26/23 | JRE | Phone call with L. Despins regarding | .20 | 95.00 | | 5/26/23 | JRE | | 2.60 | 1,235.00 | | 5/26/23 | JRE | Outlined discovery requests for preliminary injunction. | .50 | 237.50 | | 5/26/23 | JRE | Continued revisions | .80 | 380.00 | | 5/26/23 | JRE | Drafted request for information. | 1.30 | 617.50 | | 5/26/23 | JRE | Email to L. Despin regarding | .10 | 47.50 | | 5/26/23 | JRE | Continued formulating strategy | .30 | 142.50 | | 5/26/23 | JRE | Reviewed and analyzed J. Connor's 5/26 letter regarding new notice of cancellations. | .30 | 142.50 | | 5/26/23 | KR | Incorporated redline changes into | .30 | 97.50 | | 5/26/23 | KR | Updated Genever (US) | 2.80 | 910.00 | | | | ; incorporated citations and exhibit references | | | | 5/26/23 | KR | Updated Motion and Proposed Order | .20 | 65.00 | | 5/26/23 | KR | | .20 | 65.00 | | 5/26/23 | KR | Analyzed May 26, 2023 letter from AIG RE cancellation and assessed | .20 | 65.00 | | 5/29/23 | JRE | Revised request for documents. | 1.50 | 712.50 | | 5/29/23 | JRE | Continued analysis of J. O'Connor 5/26/23 cancellation letter. | .30 | 142.50 | | 5/29/23 | JRE | Email to J. O'Conner re: new basis for cancellation and request for documents. | .30 | 142.50 | | 5/30/23 | BJC | Review correspondence (x5) from L . Despins concerning | .50 | 287.50 | | 5/30/23 | BJC | Analysis of | 1.80 | 1,035.00 |

# SAXE DOERNBERGER & VITA, P.C. Case 22-50073 Doc 2156 Filed 08/30/23 Entered 08/30/23 14:48:24 Page 37 of 78

#### Invoice #: 296388 July 27, 2023

| Date | Atty | Description of Service | Hours | Amount | |---------|------|--------------------------------------------------------------------------------------------|-------|--------------| | 5/30/23 | BJC | TC L. Despins re | .90 | 517.50 | | 5/30/23 | JRE | Continued revisions to discovery request for production. | .20 | 95.00 | | 5/30/23 | JRE | Email to J. O'Connor regarding revised Request for Production. | .10 | 47.50 | | 5/30/23 | JRE | Meeting with L. Despins | .80 | 380.00 | | 5/30/23 | JRE | Formulated strategy | .80 | 380.00 | | 5/30/23 | JRE | Revised | .80 | 380.00 | | 5/30/23 | JRE | Reviewed and analyzed | .30 | 142.50 | | 5/30/23 | JRE | Review conflict check for application for retention disclosure | .50 | 237.50 | | 5/30/23 | KR | Strategize | .40 | 130.00 | | | | | | | | 5/31/23 | BJC | Coordinate review and analysis of AIG's objection to motion for preliminary injunction. | .80 | 460.00 | | 5/31/23 | JRE | Phone call from J. O'Connor regarding depositions and RFPs. | .30 | 142.50 | | 5/31/23 | JRE | Update to L. Despins regarding | .20 | 95.00 | | 5/31/23 | JRE | Reviewed judicial notice of order regarding 5/31 status conference. | .10 | 47.50 | | 5/31/23 | JRE | Reviewed | .20 | 95.00 | | | | | | | | 5/31/23 | JRE | Attention to file: | .30 | 142.50 | | 5/31/23 | JRE | Reviewed and analyzed L. Despins notes | .20 | 95.00 | | 5/31/23 | JRE | Reviewed and analyzed opposition brief. | .70 | 332.50 | | 5/31/23 | KR | Confer RE | .20 | 65.00 | | | | | | | | 5/31/23 | KR | Analyzed and made comments for n; annotated notes | .90 | 292.50 | | | | | | | | 5/31/23 | KR | Analyzed (1) | 1.90 | 617.50 | | | | ; and (2) | | | | | | . Drafted summary of findings on same | | | | 5/31/23 | KR | Drafted Genever (US) Preliminary Injunction Reply Brief outline; included | .50 | 162.50 | | | | notes | | | | | | | | | | | | TOTAL PROFESSIONAL SERVICES | | \$ 89,164.00 |

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

| Name | Hours | Rate | Total | |---------------|-------|--------|----------| | Tracy A. Saxe | 8.30 | 975.00 | 8,092.50 |

Invoice #: 296388 July 27, 2023

| Name | Hours | Rate | Total | |--------------------------|--------|--------|--------------| | David G. Jordan | .40 | 605.00 | 242.00 | | Brian J. Clifford | 52.60 | 575.00 | 30,245.00 | | Lynn A. Mitel | 1.40 | 235.00 | 329.00 | | Sarah J. Markham | 1.80 | 325.00 | 585.00 | | Suzette M. King-Morrison | .80 | 235.00 | 188.00 | | Kyle A. Rudolph | 76.40 | 325.00 | 24,830.00 | | Janie R. Eddy | 51.90 | 475.00 | 24,652.50 | | TOTALS | 193.60 | | \$ 89,164.00 |

### **EXPENSES ADVANCED**

| Date | Description | Amount | |---------|---------------------------------------------------------------|--------------| | 5/12/23 | Filing fee re Complaint,5/12 | 350.00 | | 5/18/23 | John A. Lepito, JR., State Marshal Summoms and Notice 5/17/23 | 266.00 | | | TOTAL EXPENSES ADVANCED | \$ 616.00 | | | TOTAL THIS INVOICE | \$ 89,780.00 |

Case 22-50073 Doc 2156 Filed 08/30/23 Entered 08/30/23 14:48:24 Page 39 of 78

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July 27, 2023

Luc A. Despins Invoice #: 296388 Ho Wan Kwok and Genever Holdings LLC Client #: 4238 c/o Paul Hastings LLP Matter #: GENEVERH1 200 Park Avenue New York, NY 10166

# **REMITTANCE ADVICE**

Please return this page with payment.

## **TOTAL DUE THIS INVOICE \$ 89,780.00**

AMOUNT PAID WITH THIS REMITTANCE \$\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_.\_\_\_\_

Please indicate invoices to be paid. Absent payment instructions, payments will be applied to oldest bills first.

#### **TO PAY BY WIRE OR ACH:**

Saxe Doernberger & Vita, P.C. Attorney Business Account Webster Bank - Webster Plaza, Waterbury, CT 06702 Routing No.: 211170101 Account No.: 0009421880

#### **TO PAY BY CREDIT CARD:**

| | | _______ VISA _______ MASTERCARD _______ AMEX | | Amount: _______________________________ | | |----------------------------------------------------------------------------------------------|--|----------------------------------------------|--|----------------------------------------------------------------------------------------------|--| | | | | | Card#: __________________________________________ Exp Date: _______________ Security#: _____ | | | Name on Card: ___________________________________ Credit Card Zip Code: ____________________ | | | | | | | Authorized Signature: _____________________________________________________________________ | | | | | | | Invoice #: _______________________ E-Mail Address: _______________________________________ | | | | | | | Or call Accounts Receivable at (203) 287-2146 | | | | | |

Terms: Net 30 Days

Thank you, your business is greatly appreciated.

Case 22-50073 Doc 2156 Filed 08/30/23 Entered 08/30/23 14:48:24 Page 40 of 78

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**VIA E-Mail** July 27, 2023

Luc A. Despins Invoice #: 296778 Ho Wan Kwok and Genever Holdings LLC Client #: 4238 c/o Paul Hastings LLP Matter #: GENEVERH1 200 Park Avenue New York, NY 10166

# **INVOICE SUMMARY**

\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_

For professional services rendered through June 30, 2023:

#### **RE: Sherry-Netherland Loss**

| Professional Services Total Expenses | \$ 70,409.00 \$ 626.10 | | | |-----------------------------------------|---------------------------|--|--| | TOTAL THIS INVOICE | \$ 71,035.10 | | | | Previous Balance | \$ 89,780.00 | | | | TOTAL BALANCE DUE | \$ 160,815.10 | | |

Invoice #: 296778 July 27, 2023

#### **PROFESSIONAL SERVICES RENDERED**

| Date | Atty | Description of Service | Hours | Amount | |---------|------|------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|-------|----------| | 6/01/23 | TAS | Analyze issues and strategy about replacement policy and preliminary injunction hearing; | .40 | 390.00 | | 6/01/23 | BJC | Review AIG's objection to motion for preliminary injunction and strategize concerning reply to same. | 2.30 | 1,322.50 | | 6/01/23 | BJC | TC Luc Despins concerning preparation of reply to AIG's objection to motion for preliminary injuction. | .70 | 402.50 | | 6/01/23 | BJC | Coordinate research into issues for preparation of reply to AIG's objection to motion for preliminary injunction. | .40 | 230.00 | | 6/01/23 | JRE | Analyzed arguments for reply brief. | 1.70 | 807.50 | | 6/01/23 | JRE | Continued analysis of AIG's opposition motion to injunctive relief. | 1.40 | 665.00 | | 6/01/23 | JRE | Email correspondence with broker regarding | .20 | 95.00 | | 6/01/23 | JRE | Reviewed and analyzed client comments to develop strategy for reply brief. | .60 | 285.00 | | 6/01/23 | JRE | Attended and prepared for meeting with L. Despins regarding analysis of carrier's Opposition brief. | .90 | 427.50 | | 6/01/23 | OPS | Conferred and strategized RE contents of Reply, research into NY case law concerning | .40 | 130.00 | | 6/01/23 | OPS | Strategized RE approach to NY case law research, progress RE same, status of proceedings. | .30 | 97.50 | | 6/01/23 | OPS | Reviewed and analyzed arguments contained in AIG's Memorandum in Law in Opposition to Genever's Motion for Preliminary Injunction and substantiation for same offered by AIG in preparation for research into relevant NY law to be incorporated into Answer. | 1.50 | 487.50 | | 6/01/23 | OPS | Surveyed and analyzed NY case law concerning , summarized same. | 1.60 | 520.00 | | 6/01/23 | OPS | Analyzed New York statute and case law interpreting same. | 1.10 | 357.50 | | 6/01/23 | KR | Strategize issues in need of further investigation and outline of Genever (US)'s Reply ISO Motion for Preliminary Injunction. | .70 | 227.50 | | 6/01/23 | KR | Confer with Luc Despins, JRE, and BJC RE review of AIG's Opposition to Genever (US)'s Motion for Preliminary Injunction; strategize arguments to include in Reply to same. | .70 | 227.50 | | 6/01/23 | KR | Strategize areas in need of research for Reply ISO Genever (US)'s Motion for Summary Judgment; drafted research outline for same. | .60 | 195.00 | | 6/01/23 | KR | Analyzed and summarized authority referenced by AIG in its opposition to Genever (US)'s motion for preliminary injunction RE ; contrasted that authority with binding N.Y. law. | 1.50 | 487.50 | | 6/01/23 | KR | Analyzed and summarized , and drafted argument paragraph for Genever (US)'s Reply ISO Motion for Preliminary Injunction arguing | .30 | 97.50 |

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| Date | Atty | Description of Service | Hours | Amount | |---------|------|-------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|-------|--------| | 6/01/23 | KR | Analyzed and summarized national and secondary authorities interpreting | 1.60 | 520.00 | | | | | | | | | | | | | | 6/02/23 | TAS | Analyze strategy re preliminary hearing, | .40 | 390.00 | | | | ; | | | | 6/02/23 | BJC | Coordinate preparation of reply to AIG's objection to motion for preliminary injunction, broad outline of same. | .30 | 172.50 | | 6/02/23 | JRE | Continued formulating strategy for reply brief for preliminary injunction. | .60 | 285.00 | | 6/02/23 | OPS | Conferred RE research findings concerning and relevant case law to cite in reply. | .50 | 162.50 | | 6/02/23 | OPS | Reviewed and summarized NY case law concerning , drafted portion of argument section of reply interpreting and analyzing same. | .80 | 260.00 | | 6/02/23 | KR | Assess findings RE for Reply ISO of Genever (US)'s Motion for Preliminary Injunction. | .50 | 162.50 | | 6/02/23 | KR | Analyzed New York authority RE ; drafted first merits argument of Genever (US)'s Reply ISO | 1.70 | 552.50 | | | | Motion for Preliminary Injunction RE | | | | 6/02/23 | KR | Analyzed national authority RE | 1.70 | 552.50 | | | | ; drafted second merits argument of Genever (US)'s Reply ISO Motion for Preliminary Injunction RE | | | | 6/02/23 | KR | Drafted third merits argument of Genever (US)'s Reply ISO Motion for Preliminary Injunction RE | 1.50 | 487.50 | | 6/02/23 | KR | Assess and note what supporting documents, declarations, and/or affidavits are needed for Genever (US)'s Reply ISO Motion for Preliminary Injunction. | .40 | 130.00 | | 6/03/23 | KR | Analyzed relevant authority RE ; drafted argument section of Genever (US)'s Reply Brief ISO Motion for Preliminary Injunction RE | 1.10 | 357.50 | | 6/03/23 | KR | Analyzed relevant authorities RE | 1.20 | 390.00 | | | | ; drafted argument section of Genever (US)'s Reply Brief ISO Motion for Preliminary Injunction RE same. | | | | 6/03/23 | KR | Analyzed all authority within AIG's Opposition Brief to Genever (US)'s Motion for Preliminary Injunction and distinguished those cases in Reply brief where applicable. | 1.40 | 455.00 | | 6/03/23 | KR | Analyzed authority RE | 1.20 | 390.00 | | | | ; drafted argument section of Genever (US)'s Reply ISO Motion for Preliminary Injunction RE same. | | | | 6/03/23 | KR | Proofread, edited, and finalized initial complete draft of Genever (US)'s Reply Brief ISO Motion for Preliminary Injunction. | .50 | 162.50 | | 6/04/23 | BJC | Strategize concerning preparation of reply to AIG's objection to motion for preliminary injunction. | .40 | 230.00 |

| Date | Atty | Description of Service | Hours | Amount | |---------|------|---------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|-------|----------| | 6/04/23 | JRE | Revised Reply brief. | 2.30 | 1,092.50 | | 6/04/23 | KR | Confer RE affidavits and changes to Reply ISO Motion for Preliminary Injunction. | .30 | 97.50 | | 6/04/23 | KR | Addressed comments and made edits for Draft of Genever (US)'s Reply Brief ISO Motion for Preliminary Injunction; consolidated Reply to 10 pages in accordance with the Local Rules. | 1.20 | 390.00 | | 6/05/23 | TAS | Analyze issues and strategy re discovery and trial of preliminary injunction; | .60 | 585.00 | | 6/05/23 | BJC | Coordinate revision of reply to AIG's objection to motion to preliminary injunction. | .40 | 230.00 | | 6/05/23 | JRE | Phone call with L. Despins regarding | .30 | 142.50 | | 6/05/23 | JRE | Revisions to reply brief | 2.70 | 1,282.50 | | 6/05/23 | JRE | Continued formulating strategy re: | .30 | 142.50 | | 6/05/23 | JRE | Revised in support of reply brief. | .20 | 95.00 | | 6/05/23 | JRE | Revised second draft of reply brief | 1.10 | 522.50 | | 6/05/23 | SKM | Review CTB notice of filing; review CTB case docket in 22-50073 and download the application to retain SDV as special coverage counsel;' upload and update pleading folder; update pleading chart | .30 | 70.50 | | 6/05/23 | KR | Drafted declarations ISO Genever (US)'s Motion for Preliminary Injunction. | 1.20 | 390.00 | | 6/05/23 | KR | Confer RE final changes to Reply Brief ISO Motion for Preliminary Injunction; verified internal citation within same aligned with the Uniform Citation Manual's rules. | .50 | 162.50 | | 6/05/23 | KR | Proofread and made final changes to Reply brief updated draft RE Motion for Preliminary Injunction | .30 | 97.50 | | 6/05/23 | KR | Strategize remaining action items for Reply brief and accompanying declaration. | .20 | 65.00 | | 6/05/23 | KR | Email to Luc Despins RE | .10 | 32.50 | | 6/05/23 | KR | Added argument to Reply brief RE ; added parenthetical to ; and | .70 | 227.50 | | 6/06/23 | BJC | Review and revise Reply to AIG's Objection to Motion for Preliminary Injunction. | 1.70 | 977.50 | | 6/06/23 | BJC | Strategize concerning preparation for depositions of AIG personnel, hearing on preliminary injunction. | .30 | 172.50 | | 6/06/23 | LAM | Review, revise and finalize Reply Brief in Support of Preliminary Injunction and file same with the Court | .50 | 117.50 | | 6/06/23 | JRE | Continued revisions to reply brief. | 1.10 | 522.50 | | 6/06/23 | JRE | Formulated strategy for next steps Re: | .60 | 285.00 | | 6/06/23 | KR | Created final compared version of Genever (US) Reply brief; | .20 | 65.00 | | 6/06/23 | KR | Verify citations in final Reply brief draft to conform with the Uniform Citation manual. | .10 | 32.50 |

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| Date | Atty | Description of Service | Hours | Amount | |---------|------|---------------------------------------------------------------------------------------------|-------|--------| | 6/13/23 | KR | Updated | .40 | 130.00 | | | | ; proofread | | | | 6/14/23 | BJC | Strategize concerning | .40 | 230.00 | | | | | | | | 6/14/23 | JRE | Follow up email from J. O'Connor regarding depositions. | .10 | 47.50 | | 6/14/23 | JRE | Phone call to P. Linsey re: | .20 | 95.00 | | 6/14/23 | JRE | Phone call with L. Despins regarding | .10 | 47.50 | | 6/14/23 | JRE | Analyzed AIG's answer | 1.80 | 855.00 | | 6/14/23 | JRE | Attention to file: strategized next steps regarding | .50 | 237.50 | | 6/14/23 | KR | Analyzed AIG's Answer and Affirmative Defenses and the new policy | .20 | 65.00 | | | | exclusions raised therein; strategize | | | | 6/15/23 | JRE | Phone call with P. Linsey regarding | .50 | 237.50 | | 6/15/23 | JRE | Continued revisions | .80 | 380.00 | | 6/15/23 | JRE | Analyzed coverage with respective to | .50 | 237.50 | | 6/15/23 | JRE | Follow up communication with P. Linsey regarding | .10 | 47.50 | | | | | | | | 6/15/23 | JRE | Follow up correspondence with J. O'Connor regarding document production and depositions. | .20 | 95.00 | | 6/15/23 | JRE | Outlined topics for deposition. | .60 | 285.00 | | 6/15/23 | KR | Confer RE ; strategize | .40 | 130.00 | | 6/16/23 | LAM | Review and organize and exhibits to be attached | .30 | 70.50 | | 6/16/23 | JRE | Reviewed emails to carrier regarding notice requirement. | .40 | 190.00 | | 6/16/23 | JRE | | 1.20 | 570.00 | | 6/16/23 | KR | Analyzed the AIG Insurance Policies' ; | 1.20 | 390.00 | | | | | | | | | | | | | | 6/16/23 | KR | Analyzed authority RE | .60 | 195.00 | | | | | | | | 6/16/23 | KR | Analyzed authority RE | 1.60 | 520.00 | | | | | | | | | | | | | | 6/16/23 | KR | Proofread and updated ; noted | .50 | 162.50 |

SAXE DOERNBERGER & VITA, P.C. Case 22-50073 Doc 2156 Filed 08/30/23 Entered 08/30/23 14:48:24 Page 46 of 78

| Date | Atty | Description of Service | Hours | Amount | |---------|------|------------------------------------------------------------------------------------------------------|-------|----------| | 6/17/23 | JRE | Continued revisions | 1.10 | 522.50 | | 6/17/23 | KR | Final proofread of updated | .60 | 195.00 | | | | | | | | 6/18/23 | BJC | Coordinate response to L. Despins | .50 | 287.50 | | 6/19/23 | BJC | Strategize concerning | 1.50 | 862.50 | | 6/19/23 | JRE | Email to L. regarding | .20 | 95.00 | | 6/19/23 | JRE | Phone call with J. O'Connor regarding AIG's 6/13 request for information. | .20 | 95.00 | | 6/19/23 | JRE | Analyzed M. Bono's requests for information. | .90 | 427.50 | | 6/19/23 | JRE | Analyzed response to M. Bono regarding obligations to cooperate with AIG post-denial of coverage. | .50 | 237.50 | | 6/19/23 | JRE | Revised | 1.60 | 760.00 | | 6/19/23 | KR | Analyzed and collated all within the AIG Insurance Policies to assess | .30 | 97.50 | | 6/19/23 | KR | Analyzed and summarized relevant N.Y. and Conn. authority RE | 1.70 | 552.50 | | 6/20/23 | LAM | Review finalize and compile exhibit for | .40 | 94.00 | | | | | | | | 6/20/23 | JRE | Email correspondence with L. Despins regarding | .30 | 142.50 | | 6/20/23 | JRE | Follow up communication with L. Despins regarding | .10 | 47.50 | | 6/20/23 | JRE | Strategized response | 1.00 | 475.00 | | 6/20/23 | JRE | Revised response to ; analyzed | .60 | 285.00 | | 6/20/23 | JRE | Draft letter to M. Bono re RFIs. | 1.00 | 475.00 | | 6/20/23 | JRE | Analyzed caselaw to support | .70 | 332.50 | | 6/20/23 | KR | Confer RE | .90 | 292.50 | | | | ; review , and | | | | 6/21/23 | BJC | strategize ; strategize Strategize concerning | .80 | 460.00 | | 6/21/23 | BJC | Begin preparation of outline for deposition | 1.90 | 1,092.50 | | 6/21/23 | JRE | Continued formulating strategy regarding | .70 | 332.50 | | | | | | | | 6/21/23 | JRE | Reviewed and analyzed AIG's production | .60 | 285.00 | | 6/21/23 | KR | Updated portions of ; proofread updated | .90 | 292.50 |

# SAXE DOERNBERGER & VITA, P.C. Case 22-50073 Doc 2156 Filed 08/30/23 Entered 08/30/23 14:48:24 Page 47 of 78

| Date | Atty | Description of Service | Hours | Amount | |---------|------|----------------------------------------------------------------------------------------|-------|----------| | 6/21/23 | KR | Added facts RE and drafted arguments for same | 2.20 | 715.00 | | 6/21/23 | KR | Updated | 1.50 | 487.50 | | 6/22/23 | BJC | Review and revise | 3.70 | 2,127.50 | | 6/22/23 | JRE | Analyzed caselaw on | .60 | 285.00 | | 6/22/23 | JRE | Commenced reviewed AIG preliminary injunction documents. | .30 | 142.50 | | 6/22/23 | KR | Analyzed those rules' | .30 | 97.50 | | 6/22/23 | KR | Began addressing BJC's comments | .40 | 130.00 | | 6/23/23 | BJC | Strategize concerning preparation for deposition , preparation | .90 | 517.50 | | 6/23/23 | BJC | Continue preparation of outline for | 1.80 | 1,035.00 | | 6/23/23 | JRE | Continued analysis of caselaw | .50 | 237.50 | | 6/23/23 | JRE | Continued preparations for hearing: | .80 | 380.00 | | 6/23/23 | JRE | Phone call from P. Linsey regarding | .20 | 95.00 | | 6/23/23 | JRE | Reviewed and analyzed 805 pages of AIG's preliminary injunction production. | 4.50 | 2,137.50 | | 6/23/23 | KR | Restructured | 1.10 | 357.50 | | 6/24/23 | JRE | Continued review of AIG's production (203 pages) | 1.10 | 522.50 | | 6/26/23 | BJC | Review prior pleadings and continue preparation of | 2.20 | 1,265.00 | | 6/26/23 | BJC | Strategize concerning | .50 | 287.50 | | 6/26/23 | LAM | Email John O'Connor regarding depositions of Luc Despins and John Gerber. | .30 | 70.50 | | 6/26/23 | LAM | Draft Notice of Deposition for John Gerber | .40 | 94.00 | | 6/26/23 | LAM | Email Luc Despins information regarding | .10 | 23.50 | | 6/26/23 | JRE | Email correspondence with J. O'Connor regarding preparations for depositions. | .20 | 95.00 | | 6/26/23 | JRE | Continued review and analysis of AIG's production (approximately 622 pages). | 5.80 | 2,755.00 | | 6/26/23 | JRE | Email correspondence with L. Despins regarding | .20 | 95.00 | | 6/26/23 | JRE | Email correspondence with J. O'Connor regarding preparations for Gerber deposition. | .10 | 47.50 | | 6/26/23 | KR | Email to client | .10 | 32.50 |

SAXE DOERNBERGER & VITA, P.C. Case 22-50073 Doc 2156 Filed 08/30/23 Entered 08/30/23 14:48:24 Page 48 of 78

| Date | Atty | Description of Service | Hours | Amount | |---------|------|---------------------------------------------------------------------------------------------------------------------------------------------|-------|----------| | 6/26/23 | KR | Convert to PDF; send copy of same to client. | .10 | 32.50 | | 6/27/23 | BJC | Prepare for TC with L. Despins re | .40 | 230.00 | | | | | | | | 6/27/23 | BJC | TC L. Despins re | .50 | 287.50 | | 6/27/23 | BJC | Strategize concerning | .70 | 402.50 | | 6/27/23 | LAM | Exchange emails with Court Reporter rescheduling deposition Jordan Gerber | .20 | 47.00 | | 6/27/23 | LAM | Review court docket and file and Draft List of exhibits for filing with the Court | .90 | 211.50 | | 6/27/23 | JRE | Conference call with L. Despins regarding | .50 | 237.50 | | 6/27/23 | JRE | Formulated strategy based on | .40 | 190.00 | | 6/27/23 | JRE | Email correspondence with P. Linsey regarding | .10 | 47.50 | | 6/27/23 | JRE | Phone call with J. O'Connor regarding July 7th deposition of J. Gerber. | .10 | 47.50 | | 6/27/23 | JRE | Continued document review of AIGs production (approximately 50 pages) | .70 | 332.50 | | 6/28/23 | BJC | Continue preparation for Gerber deposition, including | 2.30 | 1,322.50 | | 6/28/23 | BJC | Coordinate research into | .50 | 287.50 | | 6/28/23 | BJC | Review comments and revisions of , coordinate follow up and preparation of | .80 | 460.00 | | 6/28/23 | LAM | Exchange emails with Court reporter confirming deposition of Jordan Gerber | .20 | 47.00 | | 6/28/23 | LAM | Review and revise exhibit list and draft witness list, including reviewing all exhibits filed by both plaintiff and defendant in lawsuit | 2.30 | 540.50 | | 6/28/23 | LAM | Contact Court regarding Judge's preference with regard to the marking of exhibits | .20 | 47.00 | | 6/28/23 | JRE | Reviewed and analyzed AIG's responses to requests for production. | .20 | 95.00 | | 6/28/23 | JRE | Completed document review of AIG's production (approximately 650 pages) | 2.30 | 1,092.50 | | 6/28/23 | JRE | Incorporated discovery documents into | .70 | 332.50 | | 6/28/23 | JRE | Continued analysis of AIG production. | .60 | 285.00 | | 6/28/23 | KR | Email to client RE | .10 | 32.50 | | 6/29/23 | BJC | Continue preparation for deposition of J. Gerber, AIG underwriter; viz., organization of exhibits | 3.10 | 1,782.50 | | 6/29/23 | BJC | Coordinate research into | .50 | 287.50 | | 6/29/23 | LAM | Revise and update witness list, exhibit list and motion in limine template | .40 | 94.00 | | 6/29/23 | LAM | Discussion with Brian Clifford regarding | .40 | 94.00 | | | | | | | | 6/29/23 | JRE | Continued analysis of redacted emails in AIGs production. | .60 | 285.00 | | 6/29/23 | JRE | Email to J. O'Connor regarding | .10 | 47.50 |

SAXE DOERNBERGER & VITA, P.C. Case 22-50073 Doc 2156 Filed 08/30/23 Entered 08/30/23 14:48:24 Page 49 of 78

Invoice #: 296778 July 27, 2023

| Date | Atty | Description of Service | Hours | Amount | |---------|------|-----------------------------------------------------------------------------|-------|----------| | 6/29/23 | JRE | Continued formulating strategy for depositions. | .30 | 142.50 | | 6/30/23 | BJC | Review concerning | .80 | 460.00 | | | | | | | | 6/30/23 | BJC | Continue preparation of deposition outline and exhibit list for same. | 2.60 | 1,495.00 | | 6/30/23 | JRE | Email correspondence with L. Despins regarding | .10 | 47.50 | | 6/30/23 | JRE | Formulated strategy and exhibits for deposition | 1.10 | 522.50 | | 6/30/23 | JRE | Revised | .20 | 95.00 | | 6/30/23 | KR | Email to Luc Despins RE | .10 | 32.50 | | 6/30/23 | KR | Incorporated ; analyzed recent N.Y. authority | 1.80 | 585.00 | | | | RE | | | | 6/30/23 | KR | Updated | 2.70 | 877.50 | | | | | | | | 6/30/23 | KR | Converted ; emailed Luc Despins | .20 | 65.00 | | 6/30/23 | KR | Call with Luc Despins | .10 | 32.50 | | 6/30/23 | KR | Created | .30 | 97.50 | | | | Email a copy of same to Luc Despins. | | |

#### **TOTAL PROFESSIONAL SERVICES \$ 70,409.00**

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

| Name | Hours | Rate | Total | |--------------------------|--------|--------|--------------| | Tracy A. Saxe | 1.40 | 975.00 | 1,365.00 | | Brian J. Clifford | 35.70 | 575.00 | 20,527.50 | | Lynn A. Mitel | 7.60 | 235.00 | 1,786.00 | | Oliver P. Stallmach | 6.20 | 325.00 | 2,015.00 | | Suzette M. King-Morrison | .30 | 235.00 | 70.50 | | Kyle A. Rudolph | 46.90 | 325.00 | 15,242.50 | | Janie R. Eddy | 61.90 | 475.00 | 29,402.50 | | TOTALS | 160.00 | | \$ 70,409.00 |

Invoice #: 296778 July 27, 2023

**EXPENSES ADVANCED**

| Date | Description | Amount | |---------|---------------------------------------------------|--------------| | | Online Research | 621.10 | | 6/30/23 | Everlaw, Inc., June 2023 Document Review Platform | 5.00 | | | TOTAL EXPENSES ADVANCED | \$ 626.10 | | | TOTAL THIS INVOICE | \$ 71,035.10 |

Invoice #: 296778 July 27, 2023

#### **ACCOUNTS RECEIVABLE INVOICES OUTSTANDING**

| INVOICE NUMBER | DATE | INVOICE TOTAL | PAYMENTS RECEIVED | ENDING BALANCE | |------------------------|---------|-------------------|----------------------|-------------------| | 296388 | 7/27/23 | 89,780.00 | .00 | 89,780.00 | | | | Previous Balance | | | | Total Due This Invoice | | | | \$ 71,035.10 | | | | TOTAL BALANCE DUE | | \$ 160,815.10 |

Case 22-50073 Doc 2156 Filed 08/30/23 Entered 08/30/23 14:48:24 Page 52 of 78

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July 27, 2023

Luc A. Despins Invoice #: 296778 Ho Wan Kwok and Genever Holdings LLC Client #: 4238 c/o Paul Hastings LLP Matter #: GENEVERH1 200 Park Avenue New York, NY 10166

# **REMITTANCE ADVICE**

Please return this page with payment.

| TOTAL DUE THIS INVOICE | \$ 71,035.10 | |----------------------------------|-----------------------------| | Previous Balance | \$ 89,780.00 | | TOTAL BALANCE DUE | \$ 160,815.10 | | AMOUNT PAID WITH THIS REMITTANCE | \$____________________.____ |

Please indicate invoices to be paid.

Absent payment instructions, payments will be applied to oldest bills first.

#### **TO PAY BY WIRE OR ACH:**

Saxe Doernberger & Vita, P.C. Attorney Business Account Webster Bank - Webster Plaza, Waterbury, CT 06702 Routing No.: 211170101 Account No.: 0009421880

#### **TO PAY BY CREDIT CARD:**

| | | _______ VISA _______ MASTERCARD _______ AMEX | | Amount: _______________________________ | | |--------------------------------------------------------------------------------------------|--|----------------------------------------------|--|----------------------------------------------------------------------------------------------|--| | | | | | Card#: __________________________________________ Exp Date: _______________ Security#: _____ | | | | | | | Name on Card: ___________________________________ Credit Card Zip Code: ____________________ | | | | | | | Authorized Signature: _____________________________________________________________________ | | | Invoice #: _______________________ E-Mail Address: _______________________________________ | | | | | | | Or call Accounts Receivable at (203) 287-2146 | | | | | |

![](_page_52_Picture_0.jpeg)

Thank you, your business is greatly appreciated. Thank you, your business is greatly appreciated. Case 22-50073 Doc 2156 Filed 08/30/23 Entered 08/30/23 14:48:24 Page 54 of 78

![](_page_53_Picture_1.jpeg)

**VIA E-Mail** August 8, 2023

Luc A. Despins Invoice #: 297018 Ho Wan Kwok and Genever Holdings LLC Client #: 4238 c/o Paul Hastings LLP Matter #: GENEVERH1 200 Park Avenue New York, NY 10166

# **INVOICE SUMMARY**

\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_

For professional services rendered through July 31, 2023:

#### **RE: Sherry-Netherland Loss**

| Professional Services Total Expenses | \$ 83,604.50 \$ 602.78 | |-----------------------------------------|---------------------------| | TOTAL THIS INVOICE | \$ 84,207.28 | | Previous Balance | \$ 160,815.10 | | TOTAL BALANCE DUE | \$ 245,022.38 |

SAXE DOERNBERGER & VITA, P.C. Case 22-50073 Doc 2156 Filed 08/30/23 Entered 08/30/23 14:48:24 Page 55 of 78

Invoice #: 297018 August 8, 2023

#### **PROFESSIONAL SERVICES RENDERED**

| Date | Atty | Description of Service | Hours | Amount | |---------|------|-------------------------------------------------------------------------------------------------------------------------------------------------------------------|-------|----------| | 7/03/23 | BJC | Coordinate preparation of report on AIG discovery production, preparation of motions in limine, preparation of exhibits for preliminary injunction hearing. | 1.10 | 632.50 | | 7/03/23 | BJC | Coordinate preparation of motion to compel production of documents AIG claims are privileged. | .40 | 230.00 | | 7/03/23 | BJC | Review privilege log provided by AIG, and prepare correspondence to J. O'Connor, counsel for AIG, concerning documents that should be produced. | 2.20 | 1,265.00 | | 7/03/23 | BJC | Review documents produced by AIG for use as exhibits in deposition of J. Gerber on 7.7.2023. | 2.20 | 1,265.00 | | 7/03/23 | JRE | Continued preparing for preliminary injunction: analyzing documents for depositions to refute 3 bases for cancellation. | 1.50 | 712.50 | | 7/03/23 | JRE | Email to P. Linsey regarding deposition preparations and outlining topics. | .10 | 47.50 | | 7/05/23 | BJC | TC J. O'Connor re document production, AIG privilege log. | .30 | 172.50 | | 7/05/23 | BJC | Prepare for TC with J. O'Connor, counsel for AIG, concerning production of documents, privilege log. | .60 | 345.00 | | 7/05/23 | BJC | Continue preparation for deposition of J. Gerber, AIG underwriter; viz., review of internal AIG correspondence relating to owner identity. | 2.10 | 1,207.50 | | 7/05/23 | BJC | Strategize concerning preparation for depositions of P. Linsey and J. Gerber, preparation for preliminary injunction hearing on July 12, 2023 | .80 | 460.00 | | 7/05/23 | BJC | Complete outline of depo question for J. Gerber, AIG underwriter. | 1.80 | 1,035.00 | | 7/05/23 | ALB | Begin compiling exhibits for Geber deposition. | 1.20 | 276.00 | | 7/05/23 | JRE | Follow up email from P. Linsey regarding deposition prep. | .10 | 47.50 | | 7/05/23 | JRE | Pursuant to L. Despins's request, revised AIG's production for client review. | .30 | 142.50 | | 7/05/23 | JRE | Status update to L. Despins regarding AIG production and deposition preparations. | .30 | 142.50 | | 7/05/23 | JRE | Reviewed supplemental production. (approximately 200 pages) | .90 | 427.50 | | 7/05/23 | JRE | Prepared for and attended conference call with L. Despin regarding deposition preparations. | .40 | 190.00 | | 7/05/23 | JRE | Analyzed AIG and client documents for exhibit list for preliminary injunction hearing. | .50 | 237.50 | | 7/05/23 | JRE | Deposition prep with Patrick Linsey. | .70 | 332.50 | | 7/05/23 | JRE | Continued formulated strategy for preliminary injunction: re | 1.20 | 570.00 | | 7/06/23 | BJC | Strategize concerning preparation of exhibit and witness list for preliminary injunction hearing on July 12, coordinate preparation of same. | 2.60 | 1,495.00 | | 7/06/23 | BJC | Continue preparation for deposition of J. Gerber, AIG underwriter; viz., reorganizing exhibits, drafting alternative questions. | 5.10 | 2,932.50 |

Invoice #: 297018

August 8, 2023

| Date | Atty | Description of Service | Hours | Amount | |----------|------|-------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|-------|----------| | 7/06/23. | BJC | Continue preparation for deposition of J. Gerber, AlG underwriter; viz., develop specific lines of inquiry related AIG correspondence from 2018, initial placement of AIG policies. | 1.40 | 805.00 | | 7/06/23 | ALB | Compile exhibits for Deposition of Berber. | 3.60 | 828.00 | | 7/06/23 | ALB | Compile Witness and Exhibit List and file with exhibits in CT District Bankruptcy Court. | 5.50 | 1,265.00 | | 7/06/23 | JRE | Outlined topics for L. Despins direct examination. | .80 | 380.00 | | 7/06/23 | JRE | Follow up deposition prep with P. Linsey re corporate structure. | .30 | 142.50 | | 7/06/23 | JRE | Attended P. Linseys deposition. | .60 | 285.00 | | 7/06/23 | JRE | Continued outlining motions in limine. | 10 | 332.50 | | 7/06/23 | JRE | Continued preparations for L. Despins' deposition. | .80 | 380.00 | | 7/06/23 | JRE | Attended L. Despins' deposition. | 1.00 | 475.00 | | 7/06/23 | JRE | Follow up phone call with L. Despins regarding preparations for J. Gerber's deposition. | 00 | 237.50 | | 7/06/23 | JRE | Analyzed whether to add Catherine Skitbitcky as a witness. | 40 | 190.00 | | 7/06/23 | JRE | Finalized exhibit and witness list. | 40 | 190.00 | | 7/06/23 | KR | a. Analyzed relevant authority Pe sections on same drafted Motion in Limine argument for upcoming hearing on Genever (US)'s Motion for Preliminary Injunction. | 2.50 | 812.50 | | 7/06/23 | KR | Analyzed Local Bankruptcy Rules and D. Conn. Local Rules to ensure that Genever (US)'s Motion in Limine met all local rule requirements before filing. | 40 | 130.00 | | 7/07/23 | BJC | Final preparation for deposition of Gerber, AlG underwriter. J. | 1.40 | 805.00 | | 7107/23 | BJC | Deposition of J. Gerber, AIG underwriter. | 3.90 | 2,242.50 | | 7/07/23 | BJC | Strategize concerning preparations for preliminary injunction hearing on July 12-13. | .60 | 345.00 | | 7/07/23 | BJC | Further strategize concerning preparations for preliminary injunction hearing on July 12, 2023, preparation of exhibits for same. | 50 | 287.50 | | 7/07/23 | ALB | Assist B.Clifford in Deposition of J.Gerber. | 2.70 | 621.00 | | 7/07/23 | ALB | Revisions to Plaintiff's Exhibit and Witness List. | 00 | 115.00 | | 7/07/23 | JRE | Reviewed additional exhibits to amend exhibit list. | .80 | 380.00 | | 7/07/23 | JRE | Continued preparations for hearing. | 1.50 | 712.50 | | 7/07/23 | JRE | Email correspondence with J. O'Connor regarding exhibits to admit as full exhibits by consent. | .20 | 95.00 | | 7/07/23 | JRE | Continued preparations for hearing: analyzed disclosed exhibits. | .30 | 142.50 | | 7/07/23 | KR | a — Addressed final comments and made corresponding renditions to Genever Motion in Limine; | 1.00 | 325.00 | | 7/07/23 | KR | Confer RE logistics and remaining action items before hearing on Genever (US)'s Motion for Preliminary Injunction. | .20 | 65.00 | | 7/08/23 | BJC | Begin preparation of cross-examination of Jordon Gerber, AlG underwriter, for preliminary injunction hearing on July 12, 2023. | 2.10 | 1,207.50 | | 7/08/23 | JRE | Outline direct examination of L. Despins. | .80 | 380.00 |

# SAXE DOERNBERGER & VITA, P.C. Case 22-50073 Doc 2156 Filed 08/30/23 Entered 08/30/23 14:48:24 Page 57 of 78

Invoice #: 297018 August 8, 2023

| Date | Atty | Description of Service | Hours | Amount | |---------|------|-------------------------------------------------------------------------------------------------------------------------------------------|-------|----------| | 7/09/23 | BJC | Prepare correspondence to L. Despins (x4) re direct and cross for preliminary injunction hearing, AIG's production. | .60 | 345.00 | | 7/09/23 | BJC | Strategize concerning preparation of direct examination of Patrick Linsey and cross examination of Jordon Gerber. | .50 | 287.50 | | 7/09/23 | BJC | Continue preparation of cross-examination of J. Gerber. | 3.70 | 2,127.50 | | 7/09/23 | JRE | Continued preparing direct examination of witness, P. Linsey and L. Despins. | 1.20 | 570.00 | | 7/09/23 | JRE | Reviewed email correspondence with L. Despins regarding strategy for direct examinations. | .20 | 95.00 | | 7/09/23 | JRE | Reviewed and revised draft direct examination of L. Despins. | .60 | 285.00 | | 7/09/23 | JRE | Drafted direct examination of P. Linsey. | .50 | 237.50 | | 7/10/23 | BJC | Prepare correspondence to L. Despins (x2) concerning | .40 | 230.00 | | 7/10/23 | BJC | Continue preparation of cross-examination of J. Gerber, AIG underwriter. | 6.30 | 3,622.50 | | 7/10/23 | BJC | Prepare list of exhibits for cross of J. Gerber. | .30 | 172.50 | | 7/10/23 | BJC | Strategize concerning directs of L. Despins and P. Linsey. | .60 | 345.00 | | 7/10/23 | BJC | Review correspondence (x3) from L. Despins; respond to same (x2) prepare revisions to cross-examination of J. Gerber, AIG underwriter. | .90 | 517.50 | | 7/10/23 | LAM | Contact Courtroom deputy to see if Judge prefers a hard copy of the exhibits to be used during hearing | .20 | 47.00 | | 7/10/23 | LAM | Review exhibits filed by plaintiff and defendant including deposition transcripts and compile same for use at injunction hearing | 1.10 | 258.50 | | 7/10/23 | LAM | Review and send same to Luc Despins | .30 | 70.50 | | 7/10/23 | JRE | Reviewed caselaw regarding | .10 | 47.50 | | 7/10/23 | JRE | Continued preparing for direct examination of L. Despins. | 1.40 | 665.00 | | 7/10/23 | JRE | Prepared for hearing: analyzed AIG exhibits for consent to admit in preparation of meet and confer. | 2.30 | 1,092.50 | | 7/10/23 | JRE | Continued preparing for hearing: outlining open and closing arguments. | 1.60 | 760.00 | | 7/10/23 | JRE | Meet and confer regarding exhibits with J. O'Connor. | .50 | 237.50 | | 7/10/23 | JRE | Prepared for hearing: Reviewed and analyzed plaintiff's exhibits. | 1.50 | 712.50 | | 7/10/23 | JRE | Reviewed transcripts in preparation of preliminary injunction: P. Linsey. | .40 | 190.00 | | 7/10/23 | JRE | Continued review of exhibits in preparation of hearing. | .80 | 380.00 | | 7/11/23 | BJC | TC L. Despins re revisions to cross of J. Gerber, AIG underwriter. | .70 | 402.50 | | 7/11/23 | BJC | Revise cross of J. Gerber, AIG underwriter; organize exhibits for same. | 5.30 | 3,047.50 | | 7/11/23 | BJC | Continue preparation of outline for preliminary injunction hearing. | 2.80 | 1,610.00 | | 7/11/23 | BJC | Strategize concerning directs of L. Despins and P. Linsey, argument outline. | .60 | 345.00 | | 7/11/23 | BJC | Continue preparation for cross of J Gordon, AIG underwriter, for preliminary injunction hearing on July 12, 2023. | 1.50 | 862.50 | | 7/11/23 | LAM | Review and compile additional exhibits for court hearing | .90 | 211.50 |

Invoice #: 297018

August 8, 2023

| Date | Atty | Description of Service | UES | Amount | |---------|------|----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|------|----------| | 7/11/23 | JRE | Revised direct examination of L. Despins. | 1.50 | 712.50 | | 7/11/23 | JRE | Continued preparations for hearing: outlined argument points. | 2.00 | 950.00 | | 7/11/23 | JRE | Continued revising P. Linsey direct examination questions. | 1.60 | 760.00 | | 7/11/23 | JRE | Phone call with P. Linsey regarding revisions to direct testimony. | 30 | 142.50 | | 7/11/23 | JRE | Analyzed deposition testimony of J. Gerber in preparation of hearing. | 1.00 | 475.00 | | 7/11/23 | JRE | Continued preparing for hearing. | 5.30 | 2,517.50 | | 7/11/23 | JRE | Continued preparations for hearing: Closing argument | 80 | 380.00 | | 7/12/23 | BJC | Prep for preliminary injunction hearing - cross of J. Gerber, closing statement. | 3.10 | 1,782.50 | | 7/12/23 | BJC | Preliminary injunction hearing at D.Conn. Bankruptcy Court. | 6.50 | 3,737.50 | | 7/12/23 | BJC | Travel to and from Connecticut Bankruptcy Court in Bridgeport for preliminary injunction hearing. | 1.10 | 632.50 | | 7/12/23 | JRE | Continued preparations for hearing. | 2.40 | 1,140.00 | | 7/12/23 | JRE | Attended preliminary injunction hearing | 6.50 | 3,087.50 | | 7/12/23 | JRE | Reviewed and revised draft supplemental letter to court re: agency argument. | .20 | 95.00 | | 7/12/23 | JRE | Round trip travel from Trumbull office to Federal Court House in Bridgeport for Preliminary Injunction Hearing. | 90 | 237.50 | | 7/12/23 | KR | Travel to and from courthouse from Trumbull, Connecticut, for preliminary injunction hearing. | .90 | 292.50 | | 7/12/23 | KR | Attend hearing for Genever (US)'s motion for preliminary injunction; analyze New York authority RE broker as agent of insurance compan of same and draft summary | 6.50 | 2,112.50 | | 7/12/23 | KR | Comprehensive analysis of New York authority RE broker as agent and imputation and the caselaw referenced by AIG on the foregoing issue during closing argument; drafted letter and statement to the Court for submission tomorrow before the Court rules on Genever (US)'s Motion for Preliminary Injunction. | 4.20 | 1,365.00 | | 7/12/23 | KR | Respond to Luc Despins email RE status of research and letter/statement to the Court RE broker as agent. | 10 | 32.50 | | 7/12/23 | KR | Proofread and edited Statement ISO Genever (US)'s Motion for Preliminary Injunction. | .20 | 65.00 | | 7/13/23 | TAS | Analyze issues and strategy re post hearing memo; | 40 | 390.00 | | 7/13/23 | BJC | Revise post-hearing statement to court re NY law on agency. | 2.20 | 1,265.00 | | 7/13/23 | BJC | Strategize concerning revisions to post-hearing statement to court re NY law on agency. | .60 | 345.00 | | 7/13/23 | LAM | Review, Finalize and file Post Hearing Statement in Support of Injunction Hearing and prepare and file request for hearing transcript | 90 | 211.50 | | 7/13/23 | JRE | Revised draft supplemental letter to the court re: agency argument. | 2.50 | 1,187.50 | | 7/13/23 | JRE | Reviewed and analyzed AIG's response to Post-Hearing Statement | .20 | 95.00 | | 7/13/23 | JRE | Reviewed judicial decision granting the preliminary injunction. | 40 | 190.00 |

SAXE DOERNBERGER & VITA, P.C. Case 22-50073 Doc 2156 Filed 08/30/23 Entered 08/30/23 14:48:24 Page 59 of 78

Invoice #: 297018 August 8, 2023

| Date | Atty | Description of Service | Hours | Amount | |----------|----------|------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|-------|--------| | 7/13/23. | JRE | Analyzed caselaw re: broker agency under NY law for supplemental letter to the court. | 70 | 332.50 | | 7/14/23. | BJC | Review court's order granting motion for preliminary injunction. | 30 | 172.50 | | 7/14/23. | LAM _ | a Review Court's Memo of Decision and Granting Injunction and forward — same to Luc Despins | .30 | 70.50 | | 7/14/23, | JRE | regarding decision and next steps Email with L. | .10 | 47.50 | | 7/14/23) | JRE | Analyzed judicial decision on motion for preliminary injunction. | .30 | 142.50 | | 7/14/23, | KR | Genever Analyzed Court's order (US)'s Motion for Prelimina granting Injunction; strategize | .20 | 65.00 | | 7/17/23 | BJC | | | | | 7/17/23, | JRE | Sete | 20 | 9800 | | 7/17/23. | JRE | Formulated discovery strategy and next steps post-preliminary injunction. | .80 | 380.00 | | 7/18/23. | LAM _ | Research regarding court transcriber information and requesting hearing transcript | .30 | 70.50 | | 7/18/23. | LAM | TE Exchange emails with Court Reporter requesting a copy of the transcript of the hearings for Preliminary Injunction | 40 | 94.00 | | 7/18/23. | JRE | Continued strategy for discovery needs. | .50 | 237.50 | | 7/19/23, | TAS | Analyze issues and strategy; | .60 | 585.00 | | 7/19/23 | BJC | Strategize discovery needs. | 50 | 287.50 | | 7/19/23. | JRE | Reviewed AIG's reinstatement notice. | .10 | 47.50 | | 7/21/23. | BJC | Review correspondence from L. Despins re Genever's seeking other counsel. | .20 | 115.00 | | 7/21/23, | LAM' | Review transcript from July 12, 2023 hearing (a.m. session) and forward same to Luc Despins | .20 | 47.00 | | 7/24/23, | LAM | Email Luc Despins a copy of the hearing transcript | .20 | 47.00 | | 7/27/23, | BJC | Coordinate preparation of correspondence to L. Despins concerning AIG's notice of appeal and motion for leave to appeal; review correspondence from L. Despins (x2) re same. | .60 | 345.00 | | 7/27/23. | BJC | Strategize concerning response to AIG's motion for leave to appeal; motion for extension of time to respond. | 1.10 | 632.50 | | 7/27/23, | LAM _ | Research regarding Notice of Appeal and time to object to Motion for Leave | 40 | 94.00 | | 7/27/23. | JRE | Strategized response to AIG's notice of appeal and motion for leave to appeal order granting preliminary injunction. | 40 | 190.00 | | 7/27/23. | JRE | Continued preparations for drafting application for legal fee approval. | .30 | 142.50 | | 7/27/23. | JRE | Analyzed rule bankruptcy appellate procedure to formulate next steps. | .80 | 380.00 | | 7/27/23, | JRE | Email to L. Despins regarding motion for extension for time to oppose | .10 | 47.50 | | 7/27/23, | JRE | Reviewed multiple notices related to notice of appeal. | .30 | 142.50 | | 7/27/23, | KR __ | Attn to file re package for new counsel. | 10 | 32.50 | | 7/28/23. | BJC | Coordinate preparation of case file for transmission to L. Despins. | .60 | 345.00 |

Invoice #: 297018 August 8, 2023

| Date | Atty | Description of Service | Hours | Amount | |---------|------|------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|-------|--------------| | 7/28/23 | BJC | Coordinate preparation of application for fees. | .80 | 460.00 | | 7/28/23 | LAM | Review file and compile documents to be sent to client for transmission of the file to new counsel | | 1,316.00 | | 7/28/23 | JRE | Prepared file for transfer to M. McCormack. | 1.00 | 475.00 | | 7/28/23 | JRE | Follow up email to L. Despin regarding appeal deadlines. | .30 | 142.50 | | 7/28/23 | JRE | Email to L. Despins advising of service of discovery requests. | .10 | 47.50 | | 7/28/23 | JRE | Email from J. O'Connor regarding request for production. | .10 | 47.50 | | 7/28/23 | JRE | Follow up phone call and email communication with M. McCormack regarding file transfer. | .20 | 95.00 | | 7/28/23 | KR | Analyzed and redacted invoices before filing Motion for Fee Approval with the Court. | 1.00 | 325.00 | | 7/28/23 | KR | Drafted cover sheet, hours and rates table, introduction, jurisdictional statement, and factual background section for Application for Reimbursement of Fees and Expenses. | 1.10 | 357.50 | | 7/29/23 | KR | Drafted all substantive provisions of SDV's Fee Application and created the exhibits for same; analyzed relevant authority to see what additional information needed to be included within SDV's Fee Application and made corresponding changes as necessary. | 3.70 | 1,202.50 | | 7/31/23 | BJC | Coordinate finalization of case file for transmission to M. McCormick. | .40 | 230.00 | | 7/31/23 | BJC | Coordinate preparation of document list in case file, pursuant to request of L. Despins. | .60 | 345.00 | | 7/31/23 | LAM | Exchange emails with counsel and client regarding sharefile | .40 | 94.00 | | 7/31/23 | LAM | Review additional documents to be added to sharefile to be sent to client and new counsel | .60 | 141.00 | | 7/31/23 | LAM | Draft listing of documents transferred to new counsel | 1.90 | 446.50 | | 7/31/23 | JRE | Continued preparations for File transfer. | .20 | 95.00 | | 7/31/23 | JRE | Email correspondence from L. Despins regarding file transfer. | .10 | 47.50 | | | | TOTAL PROFESSIONAL SERVICES | | \$ 83,604.50 |

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

| Name | Hours | Rate | Total | |-------------------|--------|--------|--------------| | Tracy A. Saxe | 1.00 | 975.00 | 975.00 | | Brian J. Clifford | 72.30 | 575.00 | 41,572.50 | | Lynn A. Mitel | 13.70 | 235.00 | 3,219.50 | | Alexa L. Bussola | 13.50 | 230.00 | 3,105.00 | | Kyle A. Rudolph | 22.10 | 325.00 | 7,182.50 | | Janie R. Eddy | 58.00 | 475.00 | 27,550.00 | | TOTALS | 180.60 | | \$ 83,604.50 |

**EXPENSES ADVANCED**

Invoice #: 297018 August 8, 2023

| Date | Description | Amount | |---------|----------------------------------|--------------| | | Online Research | 425.48 | | 7/24/23 | A&S Transcript Providers 7.22.23 | | | | TOTAL EXPENSES ADVANCED | \$ 602.78 | | | TOTAL THIS INVOICE | \$ 84,207.28 |

Invoice #: 297018 August 8, 2023

#### **ACCOUNTS RECEIVABLE INVOICES OUTSTANDING**

| INVOICE NUMBER | DATE | INVOICE TOTAL | PAYMENTS RECEIVED | ENDING BALANCE | | |-------------------|--------------------------------------------|------------------|----------------------|-------------------|--| | 296388 | 7/27/23 | 89,780.00 | .00 | 89,780.00 | | | 296778 | 7/27/23 | 71,035.10 | .00 | 71,035.10 | | | | | | | \$ 160,815.10 | | | | Previous Balance Total Due This Invoice | | | | | | | | | | \$ 84,207.28 | | | | TOTAL BALANCE DUE | | | \$ 245,022.38 | |

Case 22-50073 Doc 2156 Filed 08/30/23 Entered 08/30/23 14:48:24 Page 63 of 78

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August 8, 2023

Luc A. Despins Invoice #: 297018 Ho Wan Kwok and Genever Holdings LLC Client #: 4238 c/o Paul Hastings LLP Matter #: GENEVERH1 200 Park Avenue New York, NY 10166

# **REMITTANCE ADVICE**

Please return this page with payment.

| TOTAL DUE THIS INVOICE | \$ 84,207.28 | |----------------------------------|-----------------------------| | Previous Balance | \$ 160,815.10 | | TOTAL BALANCE DUE | \$ 245,022.38 | | AMOUNT PAID WITH THIS REMITTANCE | \$____________________.____ |

Please indicate invoices to be paid.

Absent payment instructions, payments will be applied to oldest bills first.

#### **TO PAY BY WIRE OR ACH:**

Saxe Doernberger & Vita, P.C. Attorney Business Account Webster Bank - Webster Plaza, Waterbury, CT 06702 Routing No.: 211170101 Account No.: 0009421880

#### **TO PAY BY CREDIT CARD:**

| | _______ VISA _______ MASTERCARD _______ AMEX | | Amount: _______________________________ | | |--------------------------------------------------------------------------------------------|----------------------------------------------|--|----------------------------------------------------------------------------------------------|--| | | | | Card#: __________________________________________ Exp Date: _______________ Security#: _____ | | | | | | Name on Card: ___________________________________ Credit Card Zip Code: ____________________ | | | | | | Authorized Signature: _____________________________________________________________________ | | | Invoice #: _______________________ E-Mail Address: _______________________________________ | | | | | | Or call Accounts Receivable at (203) 287-2146 | | | | |

![](_page_63_Picture_0.jpeg)

Thank you, your business is greatly appreciated. Thank you, your business is greatly appreciated.

Case 22-50073 Doc 2156 Filed 08/30/23 Entered 08/30/23 14:48:24 Page 65 of 78

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**VIA E-Mail** August 22, 2023

Luc A. Despins Invoice #: 297407 Ho Wan Kwok and Genever Holdings LLC Client #: 4238 c/o Paul Hastings LLP Matter #: GENEVERH1 200 Park Avenue New York, NY 10166

# **INVOICE SUMMARY**

\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_

For professional services rendered through August 31, 2023:

#### **RE: Sherry-Netherland Loss**

| Professional Services Total Expenses | \$ 2,727.50 \$ 226.65 | |-----------------------------------------|--------------------------| | TOTAL THIS INVOICE | \$ 2,954.15 | | Previous Balance | \$ 245,022.38 | | TOTAL BALANCE DUE | \$ 247,976.53 |

Invoice #: 297407 August 22, 2023

#### **PROFESSIONAL SERVICES RENDERED**

| Date | Atty | Description of Service | Hours | Amount | |---------|------|---------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|-------|--------| | 8/03/23 | JRE | Revised Application for Fees to be submitted to the court. | .40 | 190.00 | | 8/08/23 | KR | Collated all fee and expense invoices through July 31, 2023; categorized fees between subcategories prescribed within Final Fee Application; updated Final Fee Application with fee and expense totals; analyzed Local Rules re Fee Application requirements and finalized complete version of SDV Final Fee Application for partner and subsequent trustee review. | 2.50 | 812.50 | | 8/09/23 | BJC | Review application for fees. | .30 | 172.50 | | 8/11/23 | KR | Modified Fee Application to make clear the fees were fixed; finalized complete Fee Application draft and email to Trustee for review and approval. | .30 | 97.50 | | 8/17/23 | JRE | Phone call with L. Despins regarding revisions to fee application. | .20 | 95.00 | | 8/17/23 | JRE | Revised fee applications to address L. Despins adjustments. | .70 | 332.50 | | 8/18/23 | KR | Analyzed entire Fee Application and made slight changes based on the Trustee's review and comments. | .20 | 65.00 | | 8/18/23 | KR | Analyzed relevant Bankr. Fed. R. P. and Local Rules; drafted motion for leave to file redacted invoices with SDV's final fee application. | .60 | 195.00 | | 8/21/23 | JRE | Continued formulating revisions to fee application based on Trustee's revisions. | .80 | 380.00 | | 8/21/23 | JRE | Finalized Motion for Leave to submit redacted invoices for the fee application. | .10 | 47.50 | | 8/21/23 | JRE | Email correspondence with L. Despins regarding submission of final v. interim fee application. | .10 | 47.50 | | 8/21/23 | KR | Pulled updated cost report and added same to Exhibit C of SDV's Fee Application. | .10 | 32.50 | | 8/21/23 | KR | Attn to Fee Application updates based on L. Despins' comments; created redline version and email copy of same to Luc Despins for review, feedback, and approval. | .80 | 260.00 |

#### **TOTAL PROFESSIONAL SERVICES \$ 2,727.50**

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

| Name | Hours | Rate | Total | |-------------------|-------|--------|-------------| | Brian J. Clifford | .30 | 575.00 | 172.50 | | Kyle A. Rudolph | 4.50 | 325.00 | 1,462.50 | | Janie R. Eddy | 2.30 | 475.00 | 1,092.50 | | TOTALS | 7.10 | | \$ 2,727.50 |

Invoice #: 297407 August 22, 2023

**EXPENSES ADVANCED**

| Date | Description | Amount | |---------|-----------------------------------------------|-------------| | 7/31/23 | Everlaw, Inc., July 2023 Document Review | 15.00 | | | Online Research | 198.65 | | 8/09/23 | Janie Eddy, Parking in Bridgeport for Hearing | 13.00 | | | TOTAL EXPENSES ADVANCED | \$ 226.65 | | | TOTAL THIS INVOICE | \$ 2,954.15 |

Invoice #: 297407 August 22, 2023

#### **ACCOUNTS RECEIVABLE INVOICES OUTSTANDING**

| INVOICE | DATE | INVOICE | PAYMENTS | ENDING | |---------|---------|------------------------|----------|---------------| | NUMBER | | TOTAL | RECEIVED | BALANCE | | 296388 | 7/27/23 | 89,780.00 | .00 | 89,780.00 | | 296778 | 7/27/23 | 71,035.10 | .00 | 71,035.10 | | 297018 | 8/08/23 | 84,207.28 | .00 | 84,207.28 | | | | | | | | | | Previous Balance | | \$ 245,022.38 | | | | Total Due This Invoice | | \$ 2,954.15 | | | | TOTAL BALANCE DUE | | \$ 247,976.53 |

Case 22-50073 Doc 2156 Filed 08/30/23 Entered 08/30/23 14:48:24 Page 69 of 78

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August 22, 2023

Luc A. Despins Invoice #: 297407 Ho Wan Kwok and Genever Holdings LLC Client #: 4238 c/o Paul Hastings LLP Matter #: GENEVERH1 200 Park Avenue New York, NY 10166

# **REMITTANCE ADVICE**

Please return this page with payment.

| TOTAL DUE THIS INVOICE | \$ 2,954.15 | |----------------------------------|-----------------------------| | Previous Balance | \$ 245,022.38 | | TOTAL BALANCE DUE | \$ 247,976.53 | | AMOUNT PAID WITH THIS REMITTANCE | \$____________________.____ |

Please indicate invoices to be paid.

Absent payment instructions, payments will be applied to oldest bills first.

#### **TO PAY BY WIRE OR ACH:**

Saxe Doernberger & Vita, P.C. Attorney Business Account Webster Bank - Webster Plaza, Waterbury, CT 06702 Routing No.: 211170101 Account No.: 0009421880

#### **TO PAY BY CREDIT CARD:**

| _______ VISA _______ MASTERCARD _______ AMEX | Amount: _______________________________ | | |----------------------------------------------|----------------------------------------------------------------------------------------------|--| | | Card#: __________________________________________ Exp Date: _______________ Security#: _____ | | | | Name on Card: ___________________________________ Credit Card Zip Code: ____________________ | | | | Authorized Signature: _____________________________________________________________________ | | | | Invoice #: _______________________ E-Mail Address: _______________________________________ | | | | Or call Accounts Receivable at (203) 287-2146 | |

![](_page_69_Picture_0.jpeg)

Thank you, your business is greatly appreciated. Thank you, your business is greatly appreciated.

#### EXHIBIT C (Summary of Expenses) EXHIBIT C (Summary of Expenses)

| Expense | Description of Cost | Date Billed or | Total Cost | |---------------|----------------------------------------------|----------------|------------| | | | Incurred | | | Court | Complaint filling fee | May 12, 2023 | \$350.00 | | State Marshal | State Marshal Summons and Notice | May 18, 2023 | \$266.00 | | Westlaw | Online legal research | June 1, 2023 | \$621.10 | | Everlaw, Inc. | Electronic document storage | June 30, 2023 | \$5.00 | | Westlaw | Online legal research | July 1, 2023 | \$425.48 | | Veritext, LLC | Remote Deposition Services and Fees for | July 10, 2023 | \$2,646.18 | | | Jordan Gerber's Deposition | | | | Trustpoint | Deposition Transcript Services and Fees for | July 18, 2023 | \$353.80 | | Court | Patrick Linsey's Deposition | | | | Reporting, | | | | | LLC | | | | | Trustpoint | Deposition Transcript Services and Fees for | July 18, 2023 | \$540.50 | | Court | Luc Despins' Deposition | | | | Reporting, | | | | | LLC | | | | | A&S | Court Hearing Transcript for Motion for | July 24, 2023 | \$177.30 | | Transcript | Preliminary Injunction. | | | | Providers | | | | | Everlaw, Inc. | Electronic document storage | July 31, 2023 | \$15.00 | | Westlaw | Online legal research | August 1, 2023 | \$198.65 | | Parking | Parking cost incurred for hearing attendance | August 9, 2023 | \$13.00 | | | at Bridgeport courthouse. | | |

#### SUMMARY OF EXPENSES

| Report | | |--------|--| | | | | | | | | | | | | | Cost | | | | | | | | | | |

| Billed and Unbilled | | |---------------------|--| | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | |

# **Confidential - For Internal Purposes Only**

## **Veritext, LLC - Northeast Region**

Tel. (516) 608-2400 Email: billing-li@veritext.com Fed. Tax ID: 20-3132569

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| Bill To: | Brian J. Clifford Esq. | Invoice #: | 6695511 | |----------|-----------------------------------------|---------------|------------| | | Saxe Doernberger & Vita 35 Nutmeg Dr | Invoice Date: | 7/10/2023 | | | Suite 140 Trumbull, CT, 06611 | Balance Due: | \$2,646.18 | | | | | |

#### **Case: Genever Holdings, LLC v. AIG Property Casualty Company (235007) Proceeding Type: Depositions**

Job #: 5986795 | Job Date: 7/7/2023 | Delivery: Daily

Location: New York, NY

Billing Atty: Brian J. Clifford Esq.

Scheduling Atty: Janie Eddy | Saxe Doernberger & Vita

| | Witness: Jordan Gerber | | Amount | |--------|-------------------------------------------|----------------|------------| | | Transcript Services | | \$904.80 | | | Transcript Services - Priority Request | | \$995.28 | | | Professional Attendance | | \$160.00 | | | Exhibits | | \$121.10 | | | Logistics, Processing & Electronics Files | | \$137.00 | | | Virtual Services | | \$328.00 | | Notes: | | Invoice Total: | \$2,646.18 | | | | Payment: | \$0.00 | | | | Credit: | \$0.00 | | | | Interest: | \$0.00 | | | | Balance Due: | \$2,646.18 | | | | | |

TERMS: Payable upon receipt. Accounts 30 days past due will bear a finance charge of 1.5% per month. Accounts unpaid after 90 days agree to pay all collection costs, including reasonable attorney's fees. Contact us to correct payment errors. No adjustments will be made after 90 days. For more information on charges related to our services please consult htt

**Remit to:** Veritext P.O. Box 71303 Chicago IL 60694-1303 Fed. Tax ID: 20-3132569

**Pay By ACH (Include invoice numbers): A/C Name:**Veritext **Bank Name:**BMO Harris Bank **Bank Addr:**311 W. Monroe Chicago, IL 60606 **Account No:**4353454 **ABA:**071000288 **Swift:** HATRUS44

[Pay by Credit Card: www.veritext.com](http)

**Invoice #: 6695511 \$2,646.18 Invoice Date: Balance Due: 7/10/2023**

![](_page_74_Picture_2.jpeg)

**Invoice No.** 163733 **Job Date** 7/6/2023 **Invoice Date Job No.** 7/18/2023 130822 **Case No.** 22-50073 (JAM) **Case Name** Genever Holdings LLC v. AIG Property Casualty Company **Payment Terms I N V O I C E** 1 of 2

> Due upon receipt (1.5%/mo & collection)

| | TOTAL DUE | >>> | | | \$540.50 | |---------------------------------|-----------|-------|---|--------|----------| | Litigation Processing Fee | 1.00 | | @ | 95.000 | 95.00 | | Videotaped Deposition Surcharge | 39.00 | | @ | 0.500 | 19.50 | | Remote Deposition Surcharge | 39.00 | Pages | @ | 0.500 | 19.50 | | Draft Transcript (ASCII) | 39.00 | Pages | @ | 2.000 | 78.00 | | Next Business Day Delivery Copy | 45.00 | Pages | @ | 7.300 | 328.50 | | Luc Despins | | | | | |

For questions about payments email ARCR@tp.one For billing inquiries, please email tpr.billing@tp.one

We appreciate the opportunity to work with you!

800.367.3376 www.trustpoint.one

Janie Eddy, Esq.

Trumbull, CT 06611

Saxe Doernberger & Vita, P.C.

35 Nutmeg Drive, Suite 140

Accounts Receivable Department ARCR@trustpoint.one 678.496.2488 or 855.669.1205 ext. 602 Billing Department

**Tax ID:** 35-2640986

> *Please detach bottom portion and return with payment.*

Janie Eddy, Esq. Saxe Doernberger & Vita, P.C. 35 Nutmeg Drive, Suite 140 Trumbull, CT 06611

Invoice No. **Total Due** Invoice Date : : : 163733 7/18/2023 **\$540.50**

| Job No. | 130822 : | |-----------|---------------------------------------------------------------| | BU ID | Ald-Legal : | | Case No. | 22-50073 (JAM) : | | Case Name | Genever Holdings LLC v. AIG Property : Casualty Company |

![](_page_75_Picture_2.jpeg)

Janie Eddy, Esq. Saxe Doernberger & Vita, P.C. 35 Nutmeg Drive, Suite 140 Trumbull, CT 06611

| I N V | O C I | E 2 of 2 | | | |-------------------------------------------------------|----------------|-------------|--|--| | Invoice No. | Invoice Date | Job No. | | | | 163733 | 7/18/2023 | 130822 | | | | Job Date | Case No. | | | | | 7/6/2023 | 22-50073 (JAM) | | | | | Case Name | | | | | | Genever Holdings LLC v. AIG Property Casualty Company | | | | | | Payment Terms | | | | | | Due upon receipt (1.5%/mo & collection) | | | | |

tpr.billing@tp.one 678.821.2129

**Tax ID:** 35-2640986

> *Please detach bottom portion and return with payment.*

Janie Eddy, Esq. Saxe Doernberger & Vita, P.C. 35 Nutmeg Drive, Suite 140 Trumbull, CT 06611

Invoice No. **Total Due**Invoice Date : : 163733 7/18/2023 **\$540.50**

![](_page_76_Picture_2.jpeg)

Janie Eddy, Esq. Saxe Doernberger & Vita, P.C. 35 Nutmeg Drive, Suite 140 Trumbull, CT 06611

| I N V | O C I | E 1 of 2 | | | | |-------------------------------------------------------|----------------|-------------|--|--|--| | Invoice No. | Invoice Date | Job No. | | | | | 163736 | 7/18/2023 | 130795 | | | | | Job Date | Case No. | | | | | | 7/6/2023 | 22-50073 (JAM) | | | | | | Case Name | | | | | | | Genever Holdings LLC v. AIG Property Casualty Company | | | | | | | Payment Terms | | | | | | | Due upon receipt (1.5%/mo & collection) | | | | | |

| | TOTAL DUE | >>> | | | \$353.80 | |---------------------------------|-----------|-------|---|--------|----------| | Litigation Processing Fee | 1.00 | | @ | 95.000 | 95.00 | | Videotaped Deposition Surcharge | 23.00 | | @ | 0.500 | 11.50 | | Remote Deposition Surcharge | 23.00 | Pages | @ | 0.500 | 11.50 | | Draft Transcript (ASCII) | 23.00 | Pages | @ | 2.000 | 46.00 | | Next Business Day Delivery Copy | 26.00 | Pages | @ | 7.300 | 189.80 | | Patrick R. Linsey | | | | | |

For questions about payments email ARCR@tp.one For billing inquiries, please email tpr.billing@tp.one

We appreciate the opportunity to work with you!

800.367.3376 www.trustpoint.one

Accounts Receivable Department ARCR@trustpoint.one 678.496.2488 or 855.669.1205 ext. 602 Billing Department

**Tax ID:** 35-2640986

> *Please detach bottom portion and return with payment.*

Janie Eddy, Esq. Saxe Doernberger & Vita, P.C. 35 Nutmeg Drive, Suite 140 Trumbull, CT 06611

| Total Due | \$353.80 : | |--------------|----------------| | Invoice Date | 7/18/2023 : | | Invoice No. | 163736 : |

| Job No. | 130795 : | |-----------|---------------------------------------------------------------| | BU ID | Ald-Legal : | | Case No. | 22-50073 (JAM) : | | Case Name | Genever Holdings LLC v. AIG Property : Casualty Company |

**I N V O I C E**

Janie Eddy, Esq. Saxe Doernberger & Vita, P.C. 35 Nutmeg Drive, Suite 140 Trumbull, CT 06611

| | | 2 of 2 | | | | |-------------------------------------------------------|-------------------------|--------|--|--|--| | Invoice No. | Invoice Date Job No. | | | | | | 163736 | 7/18/2023 | 130795 | | | | | Job Date | Case No. | | | | | | 7/6/2023 | 22-50073 (JAM) | | | | | | Case Name | | | | | | | Genever Holdings LLC v. AIG Property Casualty Company | | | | | | | Payment Terms | | | | | | | Due upon receipt (1.5%/mo & collection) | | | | | |

tpr.billing@tp.one 678.821.2129

**Tax ID:** 35-2640986

> *Please detach bottom portion and return with payment.*

Janie Eddy, Esq. Saxe Doernberger & Vita, P.C. 35 Nutmeg Drive, Suite 140 Trumbull, CT 06611

Invoice No. **Total Due** Invoice Date : : : 163736 7/18/2023 **\$353.80**