Guo Wengui / Miles Guo — bankruptcy case · PETITION · ECF #2259

UNITED STATES BANKRUPTCY COURT DISTRICT OF CONNECTICUT BRIDGEPORT DIVISION

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In re: :

et al., : :

Debtors. :

----------------------------------------------------------- x COVERSHEET FOR FIRST INTERIM FEE APPLICATION OF HARNEY WESTWOOD & RIEGELS LP

Interim Application of: Harney Westwood & Riegels LP

Time Period: July 31, 2022 through July 31, 2023 Bankruptcy Petition Filed: February 15, 2022

Fees: \$438,648.00 Voluntary Fee Reductions: none Expenses: \$41.729.06 Voluntary Expenses Reductions:

Fees Previously Requested: Retainer Request:

Expenses Previously Requested: Expense Detail: Requested Expenses: \$0.00 Retainer Received: Not applicable Awarded Expenses: \$0.00 Copies per page cost & total:

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 Genever Holdings Corporation is Paul Hastings LLP, 200 Park Avenue, New York, NY 10166 c/o Luc A. Despins, as Trustee for the Estate of Ho Wan Kwok (solely for purposes of notices and communications).

2 As detailed below, \$350,918.40 in fees and \$41,729.06 in expenses were previously paid in accordance with the Interim Compensation Order and the Monthly Fee Statement (each as defined below). UNITED STATES BANKRUPTCY COURT DISTRICT OF CONNECTICUT BRIDGEPORT DIVISION

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In re: :

HO WAN KWOK, et al., : :

Debtors. :

----------------------------------------------------------- x FIRST INTERIM FEE APPLICATION OF HARNEY WESTWOOD & RIEGELS LP, AS BRITISH VIRGIN ISLANDS COUNSEL, FOR COMPENSATION AND REIMBURSEMENT OF EXPENSES FOR PERIOD FROM JULY 31, 2022 THROUGH JULY 31, 2023

Pursuant to sections 105(a), 328, 330, and 331 of title 11 of the United States Code (such title, hereinafter, the "Bankruptcy Code"), Rule 2016 of the Federal Rules of Bankruptcy Procedure (the "Bankruptcy Rules"), 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"), and the *Order Establishing Procedures for Interim Compensation and Reimbursement of Expenses for Retained Professionals, dated August 18, 2023* [Docket No. 2094] (the "Interim Compensation Order"), Harney Westwood & Riegels LP ("Harneys"), as British Virgin Islands ("BVI") counsel to (a) Luc A. Despins, in his capacity as the chapter 11 trustee (the "Trustee") appointed in the chapter 11 case of Ho Wan Kwok (the "Individual Debtor") and Genever Holdings Corporation ("Genever (BVI)"), hereby files this First Interim Application of Harneys

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).

*Westwood & Riegels LP., as British Virgin Islands Counsel, for Compensation and Reimbursement of Expenses for the Period from July 31, 2022 through July 31 , 2023* (the "Application"). By this Application, Harneys requests interim allowance of professional fees incurred during the period from July 31, 2022 through and including July 31, 2023 (the "Application Period") in these chapter 11 cases. In support of this Application, Harneys 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 for the District 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 legal predicates for the relief requested herein are sections 328, 330, and 331 of the Bankruptcy Code, Bankruptcy Rule 2016, and Local Rule 2016-1.2

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

4. Attached and incorporated herein by reference are the following Exhibits:

• Exhibit A contains the Proposed Order granting this Application.

2 At this time, no interim compensation procedures have been approved by the Court.

3 Harneys reserves all rights as to the relevance and substantive legal effect of the U.S. Trustee Guidelines with respect to any application for compensation in these chapter 11 cases.

- Exhibit B is a timekeeper summary that includes the name, title, bar admission, hourly billing rate, aggregate hours, and amount of fees earned for each Harneys individual who provided services during the Application Period; - Exhibit C is a summary of expenses incurred and reimbursement sought, by expense type, during the Application Period; and - Exhibit D contains the detail of the fees and expenses incurred during the Application Period.

5. On February 15, 2022 (the "Petition Date"), 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) (the "Court").

6. On March 21, 2022, the United States Trustee appointed an Official Committee of Unsecured Creditors (the "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 of decision and order [ECF No. 465] (the "Trustee Order") directing the United States Trustee to appoint a chapter 11 trustee in the Individual Debtor's chapter 11 case.

8. 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 Individual Debtor's chapter 11 case.

9. By order entered October 3, 2022, the Court authorized Harney's retention as British Virgin Islands counsel for the Trustee [ECF No. 669] (together with the retention order with respect to Genever (BVI) [Docket No. 1286], the "Retention Order") effective as of July 31, 2022 in the Individual Debtor's chapter 11 case. The Retention Order authorizes Harneys to be compensated on an hourly basis 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 orders as the Court may direct.

10. On October 11, 2022, Genever (BVI) filed a voluntary petition for relief under chapter 11 of the Bankruptcy Code with this Court.

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

12. 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 [ECF No. 970].

13. On January 4, 2023, the Court granted Genever (BVI)'s application to retain Harneys as counsel to Genever (BVI) in its chapter 11 case, effective as of its petition date, i.e., November 21, 2022 [ECF No. 1286].

14. On August 18, 2023, the Court entered the Interim Compensation Procedures Order, which, among other things, approves procedures for the payment of 80% of fees and 100% of expenses on a monthly basis.

15. In accordance with the Interim Compensation Procedures Order, on September 7, 2023, Harneys filed and served its first monthly fee statement [Docket No. 2181] (the "Monthly Fee Statement") requesting payment of 80% of all fees and 100% of all expenses actually and necessarily incurred for services rendered during the period from July 31, 2022 through July 31, 2023 (i.e., the Application Period), in the amounts of \$350,918.40 and \$41,729.06, respectively.

16. No objections were filed in response to the Monthly Fee Statement, and, accordingly, on September 28, 2023, the estates paid Harneys 80% of the fees and 100% of the expenses identified in this Monthly Fee Statement. INTERIM FEE APPLICATION OF PAUL HASTINGS LLP AND INCORPORATION BY REFERENCE

17. Paul Hastings LLP ("Paul Hastings") is lead counsel to the Trustee, Genever (BVI), and Genever Holdings LLC ("Genever (US)") in these chapter 11 cases. As discussed herein, throughout the course of these chapter 11 cases, Harneys has worked cooperatively with Paul Hastings as British Virgin Islands counsel to the Trustee and Genever (BVI).

18. On May 30, 2023, Paul Hastings filed its *Interim Fee Application of Paul Hastings LLP for Compensation and Reimbursement of Expenses for the Period from July 8, 2022 through February 28, 2023* [ECF No. 1831] and, on August 4, 2023, Paul Hastings filed its *Second Interim Fee Application of Paul Hastings LLP for Compensation and Reimbursement of Expenses for the Period from March 1, 2023 through June 30, 2023* [ECF No. 2051] (together, the "PH Applications"). The PH Applications contain extensive discussion of the history of these chapter 11 cases and the nature of legal services performed for the Trustee, Genever (BVI), and Genever (US). To avoid repetition, Harneys thus incorporates herein by reference the background discussions from the PH Applications.

19. In the interest of efficiency and reducing administrative expense, throughout the Trustee's investigation and asset-recovery efforts, and the administration of these chapter 11 cases, Harneys was instructed by Paul Hastings on July 31, 2022 to render general legal services, as BVI counsel, as needed throughout the course of the Individual Debtor's chapter 11 case and Genever (BVI)'s chapter 11 case.

20. The Applicant is applying for compensation pursuant to Sections 330 and 331 of the Bankruptcy Code for legal services performed for the Trustee and Genever (BVI) during the Application Period.

21. For the Application Period, the Applicant seeks allowance of \$442,428.00 as compensation for services rendered and allowance and reimbursement of \$41,729.06 in expenses incurred in connection with such services. The Applicant devoted 586.5 hours to this case during the Application Period, equating to an overall blended rate of \$729.26.

22. As noted, Harneys has already received payment of \$350,918.40 of the fees incurred during the Application Period and \$41,729.06 of the expenses incurred during the Application Period, such that Harneys is only seeking payment of the remaining 20% of its fees incurred during the Application Period, namely \$87,729.60.

23. Throughout the Application Period, the Applicant maintained records to indicate the name of each attorney or paraprofessional working on this matter, the time spent on a particular issue, and the nature of the work performed. These records, which describe in detail the services rendered by the Applicant, were created at the approximate time the services were performed.

24. Annexed hereto and made a part hereof as Exhibit D is a detailed billing report, upon which this application is based that contains each individual professional's time for the Debtors' bankruptcy proceedings, itemizing the dates upon which services were rendered, including a summary of the services on each of such dates by each person rendering the service, the time spent in rendering such service, and the dollar value of such services.

25. Upon being formally instructed, Harneys was asked to provide detailed and strategic advice in relation to the interplay between the these chapter 11 cases and the BVI, notably the extent and basis upon which the Trustee could seek recognition and assistance from the BVI courts, principally in securing assets belonging to the Individual Debtor's estate and related disclosure orders against third parties (including BVI registered agents).

26. For example, Harneys took immediate steps on behalf of the Trustee to lift an existing BVI injunction order obtained by a creditor of the Individual Debtor (namely, Pacific Alliance Asia Opportunity Fund L.P. ("PAX")) so as to enable a transfer of his shares in Genever (BVI), an entity registered in the BVI, to the Trustee in accordance with orders issued by this Court. The BVI court granted the order sought, permitting the transfer of the Genever (BVI) shares to the Trustee, and to permit the registered agent of Genever (BVI) to update its Register of Members to reflect related resolutions taken by the Trustee. Harneys assisted the Trustee in arranging for such update to the Register of Members, including a change of registered agent to Harneys Corporate Services Limited and the appointment of a new director for Genever (BVI).

- 27. In addition, at the instruction of the Trustee, Harneys: - took urgent steps to identify the registered agents for various BVI corporate entities believed to be owned and/or controlled by the Individual Debtor; - obtained an order recognizing the Individual Debtor's chapter 11 case in the BVI; - obtain disclosure orders from numerous registered agents in the BVI, requiring these registered agents to produce documents in their control pertaining to corporate entities that the Trustee had reason to believe were owned and/or controlled by the Individual Debtor; - obtained (with the consent of PAX) a third-party disclosure order against PAX, permitting PAX to share with the Trustee certain disclosures

previously obtained by PAX in separate BVI litigation against the Individual Debtor and certain of his affiliates;

- obtained an order for PAX to be released from its previous undertaking to the BVI court not to use information obtained for the purpose of any civil or criminal proceedings in any jurisdiction other than New York; and - obtained several seal & gag orders to prohibit the registered agents (from whom discovery was sought) from "tipping off" the Individual Debtor or his associates of any applications for disclosure against the registered agents.4

28. In total, Harneys sought and obtain disclosures with respect to a total of twenty-

seven (27) BVI corporate entities. As a result of the disclosure orders, the Trustee was provided with critical information relating to the beneficial and legal ownership of BVI entities believed to be owned and/or controlled by the Individual Debtor. Following the disclosures made by the registered agents, Harneys conducted a review of the disclosed documents to assist the Trustee with the analysis of the ownership and control of the BVI corporate entities.

- 29. In addition, on May 8, 2023, Harneys obtained a further disclosure order against the registered agent for Ace Decade Holdings Limited following an urgent application to ascertain its ownership and a recent change of control. - 30. In connection with the services rendered during the Application Period, Harneys complied with costs orders issued by the BVI Court to third parties for legal and administrative costs. The BVI Court ordered the applicant to pay the reasonable costs incurred by the registered agents for complying with the disclosure orders. In the BVI, an applicant is required to give an undertaking to pay the reasonable costs of the registered agent and to abide by any order as to

4 Due to the complexities of these chapter 11 cases, the information recovered, and the need for further investigation, Harneys sought and obtained numerous extensions of the seal & gag orders to ensure that the Trustee could continue investigations without the registered agents "tipping off' the Individual Debtor or his associates.

damages caused by the granting or extension of the order, failing which, the disclosure order may not be granted.

31. The work undertaken by Harneys team was substantial, involved numerous applications, drafting of detailed evidence and written and oral advocacy before the BVI court, and the preparation of numerous corporate documents. The disclosures obtained by Harneys were also instrumental for the Trustee to formulate and assert claims against associates of the Individual Debtor. For example, as a result of Harneys' efforts, the Trustee was able to commence an adversary proceeding against Mei Guo, seeking determinations that, among other things, (a) the proceeds, likely in an amount of over \$10 million, from the sale of the Individual Debtor's private Bombardier jet are property of the estate and (b) a series of BVI registered shell companies purportedly held by Mei Guo are property of the Individual Debtor's chapter 11 estate.

32. Furthermore, during the Application Period, Harneys' provided a series of other services to the Trustee, including the following:

- advising the Trustee as to his rights, powers, and duties as chapter 11 trustee and his ability to seek recognition and assistance in the BVI; - advising the Trustee as to his investigation into the property of the Individual Debtor's estate, including his pursuit of actions to collect and recover property for the benefit of the Individual Debtor's estate, including conducting customary corporate due diligence and searches on various companies associated or thought to be associated with the Trustee; - assisting the Trustee with compliance with BVI company law in relation to the operation and management of the structure and in responding to the BVI court's inquiries; - drafting and preparing written and oral advocacy for numerous hearings related to the disclosure orders sought by Harneys; and - advising the Trustee generally with respect to matter matters of BVI company law, trust law and procedure.

33. No prior application for the relief requested has been made. However, as noted, 80% of the fees and 100% of the expenses incurred during the Application Period were previously paid in accordance with the Interim Compensation Procedures Order.

34. All of the professional services for which this award is being sought hereby were rendered solely on behalf of the Trustee and Genever (BVI) in connection with the chapter 11 cases herein.

35. Applicant respectfully submits that its services have benefited the Trustee and Genever (BVI) with the expertise and skill required in the handling of bankruptcy matters. The legal services for which such compensation is requested were performed for and on behalf of the Trustee and Genever (BVI). Such services have been necessary to protect and enforce the rights and interests of the Trustee and Genever (BVI) in connection with these chapter 11 cases. The reasonable value of services rendered by Harneys in these cases is based upon Harneys usual hourly rates for matters of this nature.

36. Section 330 of the Bankruptcy Code prescribes the general standards for determining the amount of compensation to be paid to professionals. The Applicant submits that the amount sought for the Application Period represents reasonable compensation for professional services rendered based upon the time spent, the nature, the extent, and the value of such services, taking into account the cost of comparable services in a non-bankruptcy case.

37. Section 331 of the Bankruptcy Code provides for interim compensation of professionals and incorporates the substantive standards of section 330 of the Bankruptcy Code to govern the Court's award of such compensation. Section 330(a) of the Bankruptcy Code

provides that, after notice and a hearing, the Court may award a professional employed under 11 U.S.C. § 327 "reasonable compensation for actual, necessary services rendered" and "reimbursement for actual, necessary expenses." 11 U.S.C. § 330(a)(1).5

38. 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 task addressed, and whether the compensation is reasonable based on the customary compensation charged by comparably skilled practitioners in cases other than cases under the Bankruptcy Code. See 11 U.S.C. § 330(a)(3). The Court enjoys "considerable discretion in determining reasonable fee awards." In re Ahead Communication Systems, Inc., 395 B.R. 512 (D. Conn. 2008).

39. In assessing the "reasonableness" of the fees requested, the Second Circuit has stated that courts should consider the factors enumerated in Johnson v. Ga. Highway Express, Inc., 6 while also incorporating the "lodestar method." See Arbor Hill Concerned Citizens Neighborhood Ass'n v. County of Albany and Albany County Bd. of Elections, 522 F.3d 182, 190

5 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).

6 The twelve Johnson factors are (1) the time and labor required, (2) the novelty and difficulty of the questions, (3) the skill requisite to perform the legal service properly, (4) the preclusion of other employment by the attorney due to acceptance of the case, (5) the customary fee, (6) whether the fee is fixed or contingent, (7) the time limitations imposed by the client or the circumstances, (8) the amount involved and the results obtained, (9) the experience, reputation, and ability of the attorneys, (10) the "undesirability" of the case, (11) the nature and length of the professional relationship with the client, and (12) awards in similar cases. Johnson, 488 F.2d at 717-19.

(2d Cir. 2007) (citing Johnson v. Ga. Highway Express, Inc., 488 F.2d 714 (5th Cir.1974), abrogated on other grounds by Blanchard v. Bergeron, 489 U.S. 87, 92–93, 96 (1989)). The "lodestar method" of calculating the reasonable fee contemplates "the number of hours reasonably expended . . . multiplied by a reasonable hourly rate." See Hensley v. Eckerhart, 461 U.S. 424, 433 (1983); Gisbrecht v. Barnhart, 535 U.S. 789, 801 (2002); Perdue v. Kenny A., 130 S.Ct. 1662, 1672 (2010); In re Drexel Burnham Lambert Grp., Inc., 133 B.R. 13 (Bankr. S.D.N.Y. 1991). The factors set forth in Johnson and In re First Colonial Corp. of Am., 544 F.2d 1291, 1298–99 (5th Cir. 1977) have been adopted by most courts.7 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").

40. In accordance with the factors enumerated in section 330 of the Bankruptcy Code and applicable case law, the amount requested herein by Harneys is fair and reasonable.

29. No agreement or understanding exists between Harneys and any other person for the sharing of compensation received or to be received for services rendered in or in connection with this matter. Harneys will not, in any form or guise, share or agree to share compensation for services with any person, nor will Harenys share in the compensation for any other person

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

rendering service in these cases, except as so provided by Section 504(b) of the Bankruptcy Code and Rule 2016 of the Bankruptcy Rules.

30. To the extent that time or disbursement charges for services rendered or expenses incurred during the Application Period are not included in this Application, or Harneys has for any reason not sought compensation or reimbursement with respect to such services, Harneys reserves the right to request compensation and reimbursement for such services in a supplemental or future application in these chapter 11 cases. Also, Harneys does not waive, and expressly reserves, its right to respond to any objections regarding this Application and the amounts sought for services rendered and expenses incurred.

31. No previous request for the relief sought herein has been made to this Court or any other court. [THE REMAINDER OF THIS PAGE IS INTENTIONALLY BLANK.]

WHEREFORE, Harneys respectfully requests entry of an order, substantially in the form attached hereto, (i) allowing interim compensation for professional services rendered during the Application Period in the amount of \$442,428.00 and reimbursement of \$41.729.06 in expenses, (ii) authorizing and directing prompt payment of the unpaid fees in the amount of \$87,729.60 from the estates, (iii) allowing such compensation and payment for professional services rendered without prejudice to Harneys' right to seek further compensation and/or payment from the estates for the full value of services performed and expenses incurred, and (iv) granting Harneys such other and further relief as is just.

Dated: October 16, 2023 New Haven, Connecticut

Andrew Thorp HARNEY WESTWOOD & RIEGELS LP Craigmuir Chambers, PO Box 71, Road Town, Tortola VG1110, British Virgin Islands Telephone: 1 284 852 2571 Email: Andrew.thorp@harneys.com

British Virgin Islands Counsel to Luc A. Despins, Chapter 11 Trustee, and Genever (BVI)

Case 22-50073 Doc 2259 Filed 10/16/23 Entered 10/16/23 22:36:24 Page 16 of 52

UNITED STATES BANKRUPTCY COURT DISTRICT OF CONNECTICUT BRIDGEPORT DIVISION

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In re: : :

HO WAN KWOK, et al., : :

Debtors.1 : :

**[PROPOSED] ORDER GRANTING FIRST INTERIM FEE APPLICATION OF HARNEY WESTWOOD & RIEGELS LP, AS BRITISH VIRGIN ISLANDS COUNSEL, FOR COMPENSATION AND REIMBURSEMENT OF EXPENSES FOR PERIOD FROM JULY 31, 2023 THROUGH JULY 31, 2023**

Upon consideration of the Application (the "Application") of Harney Westwood &

Riegels ("Harneys") as BVI2 counsel to the Trustee and Genever (BVI) for interim allowance of

compensation and reimbursement of expenses from July 31, 2023 through July 31, 2023; and

sufficient notice having 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 \$442,428.00 and reimbursement of expenses in the amount of \$41.729.06 are awarded to Harneys, subject to final adjustment and disgorgement in the event all administrative expenses are not paid in full; it is further

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

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

2. ORDERED that nothing herein modified the Retention Order; it is further

3. ORDERED that the estates are authorized and directed to pay Harneys' fees in the amount of \$87,729.60, i.e., 20% of the fees allowed in paragraph 1 above, within fourteen days of the date of this Order; it is further

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

5. ORDERED that the Debtors' estates and Harneys are authorized and empowered to take all necessary actions to implement the relief granted in this Order; it is further

6. ORDERED that notwithstanding the possible applicability of Bankruptcy Rules 6006(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

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

July 31, 2022 through December 31, 2022:

TIMEKEEPER DATE OF TITLE HOURS HOURLY TOTAL

Andrew Thorp 1998 Partner 58.8 \$1,050.00 \$61,740.00 Jeremy Child 2003 Partner 74.8 \$975.00 \$72,930.00 George Weston 2010 Partner 40.8 \$850.00 \$34,680.00 Melissa Thomas 2017 Associate 7.4 \$500.00 \$3,700.00 Romane Duncan 2018 Associate 21.6 \$475.00 \$10,260.00 Kartik Sharma 2015 Associate 77.0 \$450.00 \$34,650.00 Jhneil Stewart 2018 Associate 79.6 \$400.00 \$31,840.00 Natalee Paralegal 0.6 \$275.00 \$165.00

January 1, 2023 through July 31, 2023:

Andrew Thorp 1998 Partner 53.2 \$1,215.00 \$64,638.00 Christopher Pease 2009 Partner 0.4 \$1,215.00 \$486.00 Jeremy Child 2003 Partner 60.7 \$1,070.00 \$64,949.00 George Weston 2010 Partner 1.4 \$850.00 \$1,120.00 André McKenzie 2017 Associate 1.4 \$650.00 \$910.0 Geoffrey Fung 2017 Associate 0.6 \$550.00 \$330.00 Romane Duncan 2018 Associate 33.2 \$550.00 \$18,260.00 Jhneil Stewart 2018 Associate 10.4 \$550.00 \$5,720.00 Rhonda Brown 2010 Associate 1.0 \$500.00 \$500.00 Kartik Sharma 2015 Associate 63.0 \$500.00 \$31,500.00 Melissa Thomas 2017 Paralegal 0.2 \$450.00 \$90.00 Tamika Calme 2022 Trainee 0.4 \$450.00 \$180.00

Companies' registry and high court search report fees \$5,669

Executing service of US Court documents on Holy City \$4,000 Third party costs for compliance with disclosure order \$29,500

Case 22-50073 Doc 2259 Filed 10/16/23 Entered 10/16/23 22:36:24 Page 21 of 52

July 31, 2022 through December 31, 2022:

Timekeeper Worked Narrative Billed Billed Billed

liaising with PH to 1.60 1,050.00 1,680.00

email and updating client (0.20), 0.60 1,050.00 630.00 Thorp responding to Ogier with points (0.20) and sending

and making further 0.60 1,050.00 630.00 Thorp amends to draft response. Andrew 31/07/2022 Review and considering

Andrew 31/07/2022 Further advice re striking off and next steps (0.40), 0.60 1,050.00 630.00 Thorp considering emails in from Paul H and considering

Andrew 31/07/2022 Amending resolutions to include conflict point 0.60 1,050.00 630.00

George 31/07/2022 Sending emails re Geneva

(herein referred to as Paul Hastings) 0.40 1,050.00 420.00

relevant legal tests in BVI courts.

retention application 0.20 1,050.00 210.00

George 01/08/2022 Emails to team and client re Kwok restoration 0.80 850.00 680.00 Weston (0.20); drafting docs for chapter 11 trustee (0.60) George 02/08/2022 Considering email correspondence with Paul 0.60 850.00 510.00

George 04/08/2022 Call with PH (0.40) ; conference with Andy (0.20); 2.00 850.00 1,700.00 Weston emails with Andy and PH (0.20); prepare transfer in

George 05/08/2022 Considering emails re next steps (0.20) and 0.80 850.00 680.00

Andrew 08/08/2022 Review of additional names, conflicts and position 0.60 1,050.00 630.00

Jhneil 08/08/2022 Reviewing and preparing application documents 3.20 400.00 1,280.00

Jhneil 08/08/2022 Brief review of Harneys

Jhneil 08/08/2022 Consider and respond to email from AMT re 0.20 400.00 80.00

Jhneil 08/08/2022 Consider email from AMT re drafting application 0.20 400.00 80.00

Jhneil 09/08/2022 Drafting Harneys retention application 2.80 400.00 1,120.00

Jhneil 09/08/2022 Call with AMT re draft

Jhneil 09/08/2022 Finalising drafts application documents (1.80) and 2.00 400.00 800.00

Jhneil 09/08/2022 Sent email to BYO re engagement letter; Consider 0.20 400.00 80.00 Stewart BYO email re same and next steps.

George 10/08/2022 Considering emails re Kwok with Paul Hastings 1.20 850.00 1,020.00

Andrew 12/08/2022 Call with trustee and PAX lawyers re position and 1.00 1,050.00 1,050.00 Thorp next steps, procedure and motivation George 12/08/2022 Pre call (0.10) and call regarding Kwok with Pax 1.40 850.00 1,190.00 Weston counsel (1.0); conference with Andy (0.30)

queries from Alex and email re 0.20 400.00 80.00

Jhneil 12/08/2022 Considering email from AMT to client re proposed 0.20 400.00 80.00

Andrew 15/08/2022 Call with PH re next steps

Thorp BVI orders and strategy regarding the shares and

George 15/08/2022 Sending emails re transfer of company and transfer 0.40 850.00 340.00

Andrew 16/08/2022 Callsre the amended order emails and advices 2.00 1,050.00 2,100.00

George 16/08/2022 Conferences with Andy (0.60); emails with Paul 1.20 850.00 1,020.00 Weston Hastings (0.40); emails with Harneys Fiduciary

Jhneil 17/08/2022 Reviewing file to progress tasks (0.20); Sent email 0.40 400.00 160.00 Stewart to AMT re query re commencement date (0.20) Jhneil 17/08/2022 Responding to query re commencement date for 0.20 400.00 80.00 Stewart retention application.

email from AMT re commencement date 0.20 400.00 80.00

form (0.20); discussions with GYW re 0.60 500.00 300.00 Thomas next steps (0.20); emails with team re tasks(0.20). Andrew 18/08/2022 Amending letters(0.40), review of orders and 2.00 1,050.00 2,100.00 Thorp instructions to court (0.60). Calls with trustee (0.40)

George 18/08/2022 Emails re transfer in

(0.20); review final 0.60 850.00 510.00

Jhneil 18/08/2022 Reviewing draft email to

Jhneil 18/08/2022 Reviewing proposed changes from client on draft 0.40 400.00 160.00 Stewart documents and proposed wording on urgency and editing draft email (0.20) and circulating proposed

email from AMT to clients on 0.20 400.00 80.00 Stewart proposed draft order and draft email from Appleby

email from AMT to client re the 0.20 400.00 80.00 Stewart purpose of the proposed draft order and Harneys

emails re Harneys and Appleby 0.20 400.00 80.00

client's comments on draft order 0.20 400.00 80.00

emails between Appleby and Harneys 0.20 400.00 80.00 Stewart re agreed strategy re variation of injunction Jhneil 18/08/2022 Consider and respond to email from AMT re 0.20 400.00 80.00

letter and enclosure to Appleby (0.20); 0.40 400.00 160.00 Stewart drafting email to Appleby (0.20) Jhneil 18/08/2022 Reviewing order appointing trustee, corporate 2.60 400.00 1,040.00 Stewart governance order and injunction order (1.40) and preparing letter to Appleby re variation of

Jhneil 18/08/2022 Reviewing clients comments on draft letter to 0.20 400.00 80.00

Jhneil 18/08/2022 Email to GTW re share transfer 0.20 400.00 80.00

Jhneil 18/08/2022 Reviewing draft order from Appleby 0.20 400.00 80.00

Jhneil 18/08/2022 Reviewing executed share transfer and emailing 0.20 400.00 80.00

email from client and AMT re 0.20 400.00 80.00 Stewart proposed wording to the court re urgency Jhneil 18/08/2022 Call with AMT re executed share transfer 0.20 400.00 80.00

Weston 19/08/2022 Emails re company transfer in pack and next steps 0.60 850.00 510.00 Jhneil 19/08/2022 Sent email to compliance re conflicts

and respond to email from AMT re 0.20 400.00 80.00

Jhneil 19/08/2022 Consider email from Appleby to the Court on 0.20 400.00 80.00

response from Court re variation of order 0.20 400.00 80.00

Jhneil 19/08/2022 Sent email to AMT re client's

Jhneil 19/08/2022 Consider email from client re updating documents 0.20 400.00 80.00

Jhneil 19/08/2022 Consider email from client (0.20); and comments 0.40 400.00 160.00 Stewart from client on Harneys retention application (0.20) Jhneil 19/08/2022 Consider chaser email from AMT to Appleby re 0.20 400.00 80.00 Stewart comments on draft order and email and Appleby

George 22/08/2022 Emails to client and team re transfer in

Stewart 22/08/2022 Comprehensive review of additional names and adding additional names in list to conflicts check 6.20 400.00 2,480.00

email from GYW on registration of 0.20 400.00 80.00

Jhneil 22/08/2022 Brief review of changes to retention affidavit 0.20 400.00 80.00

Jhneil 22/08/2022 Responding to compliance email queries re 0.20 400.00 80.00

Jhneil 22/08/2022 Sent email to BYO re engagement letter 0.20 400.00 80.00

Stewart 22/08/2022 Sending emails to conflicts team

Jhneil 22/08/2022 Sent chaser to Appleby on affidavit to the Court 0.20 400.00 80.00

Jhneil 22/08/2022 Responding to client query re PAX 0.20 400.00 80.00

Jhneil 22/08/2022 Consider and respond to email from client re update 0.20 400.00 80.00

Jhneil 22/08/2022 Sending emails to AMT re retention affidavit and 0.20 400.00 80.00

Jhneil 22/08/2022 Sending follow up email to conflicts team 0.20 400.00 80.00

Jhneil 23/08/2022 Consider and respond to AMT email re proposed 0.40 400.00 160.00

Jhneil 23/08/2022 Responding to email from compliance re conflicts 0.20 400.00 80.00

Jhneil 23/08/2022 Finalising and circulating retention application 0.60 400.00 240.00

Jhneil 23/08/2022 Considering query from Doug re disclosure of 1.20 400.00 480.00 Stewart register of memberss (0.20); and drafting email for

email from AMT re Harneys retention 0.20 400.00 80.00

Andrew 24/08/2022 Considering position the order from court, directors 1.00 1,050.00 1,050.00 Thorp and reinstatement (0.20); Detailing part 191

George 24/08/2022 Emails re Kwok transfer (0.40); emails re change of 1.20 850.00 1,020.00 Weston directors (0.40); conferences internally (0.40) Jhneil 24/08/2022 Sent email to BYO re conflict checks 0.20 400.00 80.00

Jhneil 24/08/2022 Call with compliance re conflicts and next steps 0.40 400.00 160.00

Jhneil 24/08/2022 Call with AMT re strategy for disclosure order 0.40 400.00 160.00

Islands Insolvency Act 2003 or alternately pursuant

to Norwich Pharmacal (NPO) principles.

and team re the transfer 0.20 400.00 80.00

Jhneil 24/08/2022 Consider email from GYW on the registration of 0.20 400.00 80.00

Jhneil 24/08/2022 Draft response to client's query re disclosure order 0.40 400.00 160.00

1 Part 19 of the British Virgin Islands Insolvency Act 2003 enables the BVI court to grant an order in aid of a foreign proceeding where the foreign insolvency proceeding is in the relevant foreign country and the application is made by a foreign representative

2 Norwich Pharmacal relief is a discretionary remedy for the disclosure of documents or information by a respondent such as an registered agent.

Stewart 24/08/2022 Drafting proposed strategy to AMT 0.60 400.00 240.00

Stewart 24/08/2022 Sent email to team re time line for orders in aid of

Stewart 24/08/2022 Discussion with GYW re proposes strategy; read

Stewart 24/08/2022 Responding to query from client re sealed order 0.20 400.00 80.00

Stewart 24/08/2022 Considering the Insolvency Act and orders made

Stewart 24/08/2022 Sent email to clients re engagement letter 0.20 400.00 80.00

Stewart 24/08/2022 Sent email to GYW re proposed strategy and next

Stewart 24/08/2022 Consider email query from client re proposed

Stewart 24/08/2022 Reviewing and finalizing engagement letter 0.40 400.00 160.00

chaser from client re retention application and sent email to AMT re same 0.20 400.00 80.00

Thomas 24/08/2022 Emails to BVI onboarding team 0.60 500.00 300.00

Weston 25/08/2022 Emails re director appointment 0.40 850.00 340.00

Stewart 25/08/2022 Sending retention application docs to client 0.20 400.00 80.00

Stewart 25/08/2022 Consider email from client re updated conflicts (0.20); and sent email to BYO re same (0.20) 0.40 400.00 160.00

Weston 26/08/2022 Various emails re director change and restoration 0.80 850.00 680.00

Stewart 26/08/2022 Consider chaser from client re conflicts and sent email to BYO re same 0.20 400.00 80.00

Stewart 26/08/2022 Consider and respond to email from Appleby re

Stewart 26/08/2022 Responded to clients email re update on conflicts 0.20 400.00 80.00

email from GYW re stop order 0.20 400.00 80.00

Thomas 26/08/2022 call re appt of prof director. 0.80 500.00 400.00

Weston 29/08/2022 Emails with PH team 0.40 850.00 340.00

update from compliance on conflicts 0.20 400.00 80.00

to compliance re same 0.20 400.00 80.00

Stewart 29/08/2022 Drafting responses to clients queries re disclosure (0.60) and circulating to the team (0.20) 0.80 400.00 320.00

Stewart 29/08/2022 Sent email to BYO re conflicts 0.20 400.00 80.00

Thorp 30/08/2022 Review of transfer and steps to be taken the

Thorp 30/08/2022 Co side ring changes (0.20); and advising on disclosure app and jurisdiction (0.80) 1.00 1,050.00 1,050.00

Weston 30/08/2022 Emails re Kwok restoration (0.20); emails with lit team (0.20); call with Paul Hastings team (0.20); conference with Claire Abrehart (0.20); review board resolutions for appointment and comment

Stewart 30/08/2022 Circulating dial-in for proposed call 0.20 400.00 80.00

Stewart 30/08/2022 Call with BYO re conflicts 0.20 400.00 80.00

Stewart 30/08/2022 Call and email with AMT re Harneys declaration 0.40 400.00 160.00

Stewart 30/08/2022 Responding to clients queries re disclosure strategy 0.60 400.00 240.00

Stewart 30/08/2022 Call with AMT re clients queries 0.40 400.00 160.00

and respond to email re proposed call 0.20 400.00 80.00

Stewart 30/08/2022 Consider and respond to email from client re

update from compliance re conflicts 0.20 400.00 80.00

Stewart 30/08/2022 Call with clients re retention application 0.20 400.00 80.00

Stewart 30/08/2022 Consider email from BYO re progression of

Thomas 30/08/2022 Discussions with Claire with next steps (0.20); prepare consent letter (0.40); prepare shareholder resolutions relating to the removal and appointment

Thorp 31/08/2022 Calls re extension apps (0.60) and considering stop notice position (0.40) 1.00 1,050.00 1,050.00

Weston 31/08/2022 Call with Alex re directors (0.20); conference with Claire A re directorship (0.20); emails with Doug re coverage of additional companies (0.10); review questions on service (0.10) 0.60 850.00 510.00

team emails re billing 0.40 400.00 160.00

Stewart 31/08/2022 Sent email to team(0.20); and email from party

Christopher 31/08/2022 Requesting searches. 0.20 275.00 55.00

Thorp 01/09/2022 Advising on recognition, dissipation and stop notice 1.40 1,050.00 1,470.00

Weston 01/09/2022 Strategy call (1.00); call with Alex and Claire (0.40); emails (0.20); review search results (0.20) 1.80 850.00 1,530.00

Jhneil 01/09/2022 Circulating dial-in for call 0.20 400.00 80.00

Jhneil 01/09/2022 Sent email to client re proposed call 0.20 400.00 80.00

Jhneil 01/09/2022 Consider email from AMT re proposed call 0.20 400.00 80.00

Jhneil 01/09/2022 Rewording sample NPO affidavit 0.60 400.00 240.00

emails from GYW and clients re search 0.40 400.00 160.00

Jhneil 01/09/2022 Read email from GYW re disclosure of relationship 0.20 400.00 80.00

Jhneil 01/09/2022 Sent email to AMT re advise to client on queries re 0.20 400.00 80.00

Melissa 01/09/2022 KWOK stat call. 0.80 500.00 400.00

Andrew 02/09/2022 Considering jurisdictional trap and court documents 1.00 1,050.00 1,050.00 Thorp te cmc (0.20), advising appropriately and mails with client (0.40), review of application for

George 02/09/2022 Email correspondences with Paul Hastings for 0.40 850.00 340.00

Jhneil 02/09/2022 Call with AMT re amends to supplemental 0.20 400.00 80.00

Jhneil 02/09/2022 Sent email to AMT re declaration 0.20 400.00 80.00

and respond to emails from GYW re 0.20 400.00 80.00

email from AMT re listing for CMC 0.20 400.00 80.00

Jhneil 02/09/2022 Sent email to Doug re AMT declaration 0.20 400.00 80.00

Jhneil 02/09/2022 Edits to AMT supplemental declaration 0.40 400.00 160.00

and respond to emails with clients re 0.40 400.00 160.00 Stewart proposed amends to AMT supplemental declaration

emails CYA re AMT declaration 0.40 400.00 160.00

George 04/09/2022 Email correspondence with Paul Hastings for Kwok 0.20 850.00 170.00 Weston Case. George 05/09/2022 Email correspondence with Paul Hastings for Kwok 0.60 850.00 510.00

Weston Case.

email from GYW re draft email to clients 0.40 400.00 160.00 Stewart (0.20); and making amends to same (0.20)

sample NPO affidavit (0.20); and 0.40 400.00 160.00 Stewart drafting email to client re same (0.20) Jhneil 05/09/2022 Considering email from clients re service and 2.40 400.00 960.00 Stewart document production in the BVI (0.80); reviewing legislation and drafting proposed response to AMT

emails from AMT and clients re CMC 0.40 400.00 160.00

Stewart 05/09/2022 Strategy call with clients 1.00 400.00 400.00

email to team re email to Bravo Luck 0.20 400.00 80.00

Jhneil 05/09/2022 Call with clients re strategy 0.80 400.00 320.00

Jhneil 05/09/2022 Instructions to team re opinion on disclosure 0.20 400.00 80.00

George 06/09/2022 Update DSA (0.20); emails with PH (0.20); 1.20 850.00 1,020.00 Weston conferences and emails with Fid team (0.80)

and respond to email from AMT re draft 0.20 400.00 80.00 Stewart letter to Ogier re CMC listing request Jhneil 06/09/2022 Drafting letter to Ogier re CMC listing request 0.80 400.00 320.00

email from client re NY decision (0.20); 0.40 400.00 160.00 Stewart brief review of said decision (0.20) Jhneil 06/09/2022 Sent email to AMT re call to discuss discovery 0.20 400.00 80.00

email from clients re proposed call 0.20 400.00 80.00

George 07/09/2022 Emails with the team (0.20); drafting declaration 0.60 850.00 510.00 Weston (0.20); conferences with Claire A (0.20)

email from GYW re directors resolution 0.20 400.00 80.00

email from client and circulating dial-in 0.20 400.00 80.00

Jhneil 07/09/2022 Edits to draft letter and circulating to AMT 0.20 400.00 80.00

emails from AMT re client proposed call 0.20 400.00 80.00

Jhneil 07/09/2022 Editing proposed response (0.20); and responding 0.40 400.00 160.00 Stewart to clients email re US subpoenas (0.20)

Stewart 07/09/2022 Sent email to client re letter to Ogier 0.20 400.00 80.00 Jhneil 07/09/2022 Consider and respond to email from AMT on draft 0.20 400.00 80.00

and respond to email from AMT re letter 0.20 400.00 80.00

Jhneil 07/09/2022 Call with clients 0.60 400.00 240.00

Jhneil 07/09/2022 Sent email to Ogier enclosing letter 0.20 400.00 80.00

Jhneil 07/09/2022 Edits to draft letter and circulating to client team 0.20 400.00 80.00

Jhneil 07/09/2022 Call with AMT re draft letter (0.20); and proposed 0.40 400.00 160.00 Stewart response to queries re US subpoenas (0.20) Jhneil 07/09/2022 Finalsing letter to Ogier 0.20 400.00 80.00

George 08/09/2022 Emails (0.40); call with Alex (0.30); update 3.60 850.00 3,060.00 Weston resolutions (0.60); conferences with Claire (1.30);

declaration (0.30); arrange conflict checks (0.40)

email from team re Harneys disclosure 0.20 400.00 80.00

variation of injunction point 0.20 400.00 80.00

resolution and Harneys FID declaration 0.20 400.00 80.00

email from GYW re task list 0.20 400.00 80.00

Stewart 08/09/2022 Sent email to team re dealing point 0.20 400.00 80.00 Jhneil 08/09/2022 Sent email to BYO re new parties to be added for 0.20 400.00 80.00 Stewart conflicts; read email from BYO re same

email from client re points to sort; sending 0.20 400.00 80.00 Stewart client a copy of the letter to Ogier

email from Appleby re injunction and 0.20 400.00 80.00

email from client re recognition point and 0.20 400.00 80.00

email from GYW re updates on conflicts 0.20 400.00 80.00

and respond to email from GYW re 0.20 400.00 80.00

Jhneil 08/09/2022 Sending email to client 0.20 400.00 80.00

Jhneil 08/09/2022 Reviewing injunction (1.20); reviewing and 2.80 400.00 1,120.00 Stewart considering bvi law and the implications of chapter 11 proceedings (1.20) and drafting email to AMT re

Jhneil 08/09/2022 Call with GYW re AMT declaration 0.40 400.00 160.00

email from AMT to Appleby re injunction 0.20 400.00 80.00

George 09/09/2022 Emails with fiduciary

Andrew 12/09/2022 Call with PH re disclosure orders and injunction 0.60 1,050.00 630.00

Andrew 12/09/2022 Calls with Appleby re disclosure and injunction lift 0.80 1,050.00 840.00

emails from GYW re conflicts and next 0.20 400.00 80.00

Stewart 12/09/2022 Brief review of addendum to Harneys retention

Jhneil 12/09/2022 Considering Insolvency Act, Rules and authorizes 1.60 400.00 640.00

Jhneil 12/09/2022 Consider email from AMT re update on injunction 0.20 400.00 80.00

Jhneil 12/09/2022 Drafting Part XIX Application and supporting 5.20 400.00 2,080.00

Jhneil 12/09/2022 Consider Read response from GYW re addendum 0.20 400.00 80.00

Melissa 12/09/2022 update declaration of Harneys Fiduciary with 0.40 500.00 200.00

George 13/09/2022 Conferences with Claire (1.00); emails with Paul 2.20 850.00 1,870.00

Weston Hastings (0.40); update draft Directors services

Jhneil 13/09/2022 Sent email to clients queries re the insolvency act 0.20 400.00 80.00

email from team re directors services 0.20 400.00 80.00

Jhneil 13/09/2022 Further draft to recognition application 1.80 400.00 720.00

Stewart 13/09/2022 Considering authorities re interpretation of Part

drafting draft email to the client (0.40)

email queries from client re Part XIX and 0.20 400.00 80.00 Stewart Part XIX of the Insolvency Act and next steps

and respond to email from AMT re clients 0.40 400.00 160.00

email from GYW re harneys retention 0.20 400.00 80.00

Jhneil 13/09/2022 Consider email from client re director services 0.20 400.00 80.00

George 14/09/2022 Emails with Alex (0.20); conference with Alex 1.20 850.00 1,020.00 Weston (0.40); conferences with Claire (0.40); review US

searches; email to client. 0.20 275.00 55.00

George 15/09/2022 emails regarding POA with PH and Fiduciary

Weston (0.30); review and comment on POA (0.30) Jhneil 15/09/2022 Read email form team and client re written 0.20 400.00 80.00

Emails to Claire re POA (0.20) and resolutions 0.40 500.00 200.00

Melissa 15/09/2022 Prepare draft POA 1.00 500.00 500.00

emails re finalizing POA 0.20 400.00 80.00

Jhneil 20/09/2022 Considering email from client re list of BVI 0.20 400.00 80.00 Stewart Companies and proposed call; Considering

Andrew 21/09/2022 PAX referral of position (0.20) and target 0.60 1,050.00 630.00

Andrew 21/09/2022 Conference call with PH re position 0.40 1,050.00 420.00

disclosure to Pax lawyers (0.20) and next 0.40 1,050.00 420.00

Jhneil 27/09/2022 Responding to clients query re affidavits 0.40 400.00 160.00

Jhneil 27/09/2022 Discussion with AMT re clients query for affidavits 0.20 400.00 80.00

Andrew 05/10/2022 Conference calls (0.40); and review of disclosure 1.00 1,050.00 1,050.00

Thorp orders (0.40) and mails to PAX (0.20)

re call (0.10) and next steps (0.10) 0.20 850.00 170.00

George 06/10/2022 Emails re Kwok (0.15); conference with MTT 0.80 850.00 680.00 Weston (0.30); correspondence internally (0.20); consider

Melissa 06/10/2022 Prepare draft resolutions; 0.80 500.00 400.00

Andrew 07/10/2022 Call (0.40) and review of US evidence (1.60) 2.00 1,050.00 2,100.00

board resolutions dealing with Chapter 11 1.20 850.00 1,020.00 Weston (0.30); considering note on applicability of chapter 11 (0.30); conference with Claire Abrehart and Melissa Thomas (0.30); conference with A Thorp

George 08/10/2022 Considering latest correspondence

Weston documents; George 10/10/2022 Review Chapter 11 docs (0.30); call with PH (0.30) 1.00 850.00 850.00

Jeremy 10/10/2022 Call with AMT and Kartik re application for 3.60 975.00 3,510.00 Child disclosure (1.80), reading related documents (1.80) Jhneil 10/10/2022 Discussion with AMT re Part 19 application and 0.40 400.00 160.00

Stewart working drafts (0.20); sending draft documents to

Kartik 10/10/2022 Briefing call with Andrew Thorp and Jeremy Child 1.20 450.00 540.00 Sharma on matter history and current stage. (0.20) -Going through historical correspondence and official correspondence and court judgments/orders in the US and the BVI. (0.40) Catch up call with Andrew and Jeremy on approach to draft OA/Part 19 in the BVI and the structure and contents of such an application. (0.20) -Commenced drafting the Part

Kartik 10/10/2022 Briefing call with Andrew Thorp and Jeremy Child 6.80 450.00 3,060.00 Sharma on matter history and current stage. (1.60) -Going through historical correspondence and official correspondence and court judgments/orders in the US and the BVI. (2.00) Catch up call with Andrew and Jeremy on approach to draft OA/Part 19 in the BVI and the structure and contents of such an application. (1.20) Commenced drafting the Part 19

Melissa 10/10/2022 Call re chapter 11 docs; 0.60 500.00 300.00

George 11/10/2022 Review emails between Claire and Genever US 0.40 850.00 340.00 Weston counsel (0.15); discuss with Claire (0.25)

Child various team emails with Kartik and AMT (1.00) Kartik 11/10/2022 -Finished drafting Part 19 Disclosure Application 1.00 450.00 450.00

Jeremy 12/10/2022 Reading docs (0.80), reading draft WS (0.80), 4.50 975.00 4,387.50 Child drafting seal and gag app (2.00), various team

Sharma 12/10/2022 Email correspondence w Andrew Thorp and Jeremy Child on matter history, company details, and drafting. (0.40) Commenced drafting the Affidavit for Luc A Despins in BVI hearing to obtain Part XIX/NP relief. (3.40) 3.80 450.00 1,710.00

Sharma 12/10/2022 Email correspondence w Andrew Thorp and Jeremy Child on matter history, company details, and drafting. (0.40) Updated affidavit after obtaining further clarification and details from clients. (1.80) 2.20 450.00 990.00

Thorp 13/10/2022 Review of and drafting evidence, applications, etc 3.00 1,050.00 3,150.00

Child 13/10/2022 Amending draft affidavit (2.00), order for substantive app (1.40), order for seal and gag (1.40), various team emails (0.20) 5.00 975.00 4,875.00

Sharma 13/10/2022 Email correspondence w Andrew Thorp and Jeremy Child on matter history, company details, and drafting. (0.40) -Updated draft orders, affidavit,

Norwich Pharmacal relief/Part XIX relief after obtaining further clarification and details from

Thorp 17/10/2022 Draft changes to affidavit 1.00 1,050.00 1,050.00

Sharma 17/10/2022 Updated affidavit after receiving client comments. (0.80) Call with Andrew Thorp to discuss changes to affidavit and other background supporting

Thorp 18/10/2022 Further turns of evidence and review of search

Sharma 20/10/2022 Drafted skeleton arguments for seal gag application

combined the bundle for the affidavit.

Thorp 21/10/2022 Review of evidence (0.60) and conference calls with PH the content (1.00) 1.60 1,050.00 1,680.00

Thorp 26/10/2022 Calls with Appleby and reviews of disclosure and undertakings. (1.40) Review of disclosed evidence and next steps (0.60) 2.00 1,050.00 2,100.00

Sharma 26/10/2022 Redrafted the entire suite of documents ( application, affidavit, and order) incorporating the changes arising as a result of addition of a discovery respondent 2.40 450.00 1,080.00

Thorp 27/10/2022 Review of drafts and amendments 3.00 1,050.00 3,150.00

Sharma 27/10/2022 Calls with Andrew Thorp to discuss the changes - perusal of historic client correspondence and litigation in the US and BVI (0.60) -continued drafting after comments from Andrew Thorp. (2.00) Redrafted the entire suite of documents ( application, affidavit, and order) incorporating the changes arising as a result of addition of a discovery respondent (2.60) 5.20 450.00 2,340.00

Child 28/10/2022 Reading, considering and amending all draft application documents (4.00) further discussing with Kartik and AMT on zoom and by email. (1.50) 5.50 975.00 5,362.50

Kartik 28/10/2022 Revising the seal and gag application suite 1.80 450.00 810.00

Redrafted the entire suite of documents ( application, affidavit, and order) incorporating the 2.80 450.00 1,260.00 changes arising as a result of addition of a

Jeremy 31/10/2022 Amending cover affidavit (0.40), updating OA and 2.00 975.00 1,950.00 Child draft order (0.40); team call to discuss next steps

Kartik 31/10/2022 Conference calls with Andrew Thorpe, Jeremy 7.20 450.00 3,240.00 Sharma Child, to discuss the case and develop the documentation for seal and gag (2.00). Multiple back and forth to revise and improve the seal and gag suite including the draft originating application, draft order, drafted the notice of application for seal and gag, revised the existing documents. (5.20). Jeremy 01/11/2022 Amend OA (1.00), timelines for client (0.20), 2.80 975.00 2,730.00

Jhneil 01/11/2022 Brief review of file and next steps 0.20 400.00 80.00

Stewart 01/11/2022 Discussion with AMT re preparing covering affidavit (0.20); preparing draft affidavit (0.40) 0.60 400.00 240.00 Kartik 01/11/2022 Multiple conference calls with Andrew Thorpe, 8.00 450.00 3,600.00 Sharma Jeremy Child, to discuss the case and develop the documentation for seal and gag. (2.00) Revise and improve the seal and gag suite including the draft originating application, draft order, witness statement of Kartik Sharma, drafting affidavit of Jhneil Stewart (6.00). Kartik 01/11/2022 Call with Andrew Thorp to discuss strategy in 0.20 450.00 90.00 Sharma obtaining subpoena-like disclosure in BVI Jeremy 02/11/2022 Research for skellie on substantive

Kartik 02/11/2022 Drafted the skeleton for Norwich Pharmacal and 3.80 450.00 1,710.00

Romane 03/11/2022 Emails with client re filing court documents. (0.40) 1.60 475.00 760.00 Duncan Call with K.S re exhibit. (0.20) Amending exhibit and re-collating exhibit. (0.40) Filing on the e portal. (0.20) Save to file. (0.20) Emails with JCC

Jeremy 04/11/2022 Reading/considering exhibit docs (0.60) and 2.00 975.00 1,950.00 Child finalised affidavit (to prepare skeleton) (1.40) Andrew 07/11/2022 Dealing with Appleby and disclosure ahead of 1.60 1,050.00 1,680.00 Thorp filing and next steps re affidavit of means (0.80); Cross referral to previous disclosure and US

Andrew 07/11/2022 Drafts of various documents, skeletons and prep 3.00 1,050.00 3,150.00

Andrew 07/11/2022 Conference calls and briefs for urgent disclosure 1.00 1,050.00 1,050.00

Jeremy 07/11/2022 Organising the various steps to file and serve docs 1.00 975.00 975.00

draft docs to serve on respondents (0.40), amending same (1.00), discussing with RD in BVI

Child 09/11/2022 Finalising service letters and listing request with RD in BVI arranging to send out 2.00 975.00 1,950.00

Child 11/11/2022 Various emails with AMT, team, clients and Appleby re: Ace Decade. (1.00) Drafting email to Court and agreeing draft order. (3.20) Reading emails with court. (0.30) 4.50 975.00 4,387.50

Duncan 11/11/2022 Drafting hearing bundle index. (0.20); Emails with JCC re same. (0.20) 0.40 475.00 190.00

Duncan 11/11/2022 Confirmation from Appleby that no objections to

Duncan 11/11/2022 Emails with JCC and AMT re urgent application to Court re disclosure of documents. 0.60 475.00 285.00

Duncan 11/11/2022 Emails from AMT and client re consent order from

Duncan 11/11/2022 Notification from portal that sealed order uploaded. 0.20 475.00 95.00

Duncan 11/11/2022 Urgent disclosure from Pacific Alliance: Collating ebundle and filing on the portal. (1.00) Finalising email to Court and sending with Appleby in copy. (0.20) Updates to JCC. (0.20) 1.40 475.00 665.00

Thorp 14/11/2022 Call with PH re transfer and mechanics 0.80 1,050.00 840.00

Thorp 14/11/2022 Advice from share ownership and split interest. 1.00 1,050.00 1,050.00

Thorp 14/11/2022 Calls (0.20); and considering mechanics of transfer

Weston 14/11/2022 Draft docs for Ace Decade 1.20 850.00 1,020.00

Child 14/11/2022 Dealing with docs in from Appleby (1.80); liaising with Appleby and clients re same. (0.60) Ace Decade queries. (0.60) 3.00 975.00 2,925.00

Duncan 14/11/2022 Email from Appleby with Pacific Alliance

Duncan 14/11/2022 Email from JCC to client with disclosure from

Thorp 15/11/2022 Drafting transfer documents (0.80); and considering part 19 position (0.40) 1.20 1,050.00 1,260.00

Weston 15/11/2022 Review a thorp amends to ace decade documents 0.40 850.00 340.00

Child 15/11/2022 Queries from Campbells (1.50); considering same and discussing with team (1.00) 2.50 975.00 2,437.50

Thorp 16/11/2022 Call with PH re notices and service 0.40 1,050.00 420.00

Thorp 16/11/2022 Calls with PH re estoppel and likely order verses sang and enforceability in BVI (1.60); considering g appropriate order and next steps. (0.40) 2.00 1,050.00 2,100.00

Duncan 16/11/2022 Email to FFP re confirmation of access to

Romane 16/11/2022 Call from Campbells re disclosure application. 0.60 475.00 285.00

Duncan (0.20) Service of hearing notice, draft order and Ocorian service letter on Campbells. (0.20) Email update to team re call from Campbells. (0.20) Romane 16/11/2022 Instructions from client to serve notice of proposed 2.60 475.00 1,235.00 Duncan order. (0.20) Instructions from AMT re same. (0.20) Drafting service letter and sending over AMT. (0.80) Liasing with support to arrange hard copy service. (0.40)Further emails with client re same. (0.40) Drafting affidavit of service. (0.40) Update to client re service and draft affidavit for

Romane 16/11/2022 Emails with client re outcome of Chapter 11 0.20 475.00 95.00 Duncan hearing in US. Romane 16/11/2022 Notice of hearing from Court. Sending over to JCC, 0.20 475.00 95.00

Andrew 17/11/2022 Considering notice and draft provisions for order 1.00 1,050.00 1,050.00 Thorp (0.60); checking in on court status and next steps

Jeremy 17/11/2022 Drafting skeleton 3.50 975.00 3,412.50

Romane 17/11/2022 Email from JCC re service and position of 0.40 475.00 190.00

disclosure application (0.20); Reviewing emails and providing update to JCC.

Romane 17/11/2022 Email from JCC with draft skeleton for disclosure 0.60 475.00 285.00 Duncan application.

next steps.

Duncan 17/11/2022 Consider email from Trident re considering disclosure application and reverting 0.20 475.00 95.00 Romane 17/11/2022 Drafting service letters to FFP, Vistra, Trident and 1.80 475.00 855.00 Duncan Conyers. (1.00) Finalising letters and executing electronic service on all 4. (0.40) Adding representatives to shared folder. (0.20) Further email to Trident in light of out of office from senior

Romane 17/11/2022 Detailed email from Campbells on the position of 0.40 475.00 190.00 Duncan Ocorian on the disclosure application and considering further email from Campbells re correspondence to Court. (0.20) Considering

George 18/11/2022 Genever work: Discuss with Claire 0.40 850.00 340.00

(1.20), email to Campbells to 5.00 975.00 4,875.00 Child narrow issues (0.60), discussing with team (1.40),

Romane 20/11/2022 Emails with client and AMT re further chapter 11 0.40 475.00 190.00 Duncan application and saving supporting documents to the file. (0.20) Considering next steps.(0.20)

Child 21/11/2022 Prep for hearing (1.5 hrs), reading R2 note and R3 skel (1.5), preparing submissions (2 hr), hearing 7.80 975.00 7,605.00

Kartik 21/11/2022 Drafted the Part 19 application bundle for the 5.60 450.00 2,520.00 Sharma subpoena orders against Himalayan entities

Romane 21/11/2022 Emails with JCC re drafting of seal and gag order 1.40 475.00 665.00

Duncan and disclosure order against 5th and 6th defendants (0.20). Reviewing filed draft order, reviewing

consulting note of hearing(0.80). Drafting orders and sending over to JCC for consideration (0.40). Romane 21/11/2022 Email from Conyers re form of order (0.20). 1.60 475.00 760.00 Duncan Liasing with team same and sending over draft order to Conyers(0.20). Call with KSH to consider new originating application and next steps (0.60).

appearances and zoom dial in details (0.20). Service by Campbells of skeleton submissions, authorities and draft order(0.20). Confirmation of receipt to Campbells (0.20). Romane 21/11/2022 Pre-hearing preparation: email from Campbells re 2.00 475.00 950.00 Duncan draft orders, emails with JCC re same. (0.20)

Attendance at court and appearing on behalf of the applicant. (1.00) Taking note of hearing. (0.40) Emails with JCC re minute of order and update to

Jeremy 22/11/2022 Drafting/amending minutes of order seal and 3.50 975.00 3,412.50 Child gag/disclosure order, (3.00) discussing instructions

Romane 22/11/2022 Considering comments from JCC on draft seal and 0.60 475.00 285.00 Duncan order and draft disclosure order (0.20). Addressing comments and sending finalized versions of the draft orders to JCC for sign off before sending to the Court(0.40). Romane 22/11/2022 Emails from AMT and JCC re client instructions on 0.40 475.00 190.00 Duncan registered agent costs in the liquidation. Jeremy 23/11/2022 Various emails re team discussion re instructions. 2.50 975.00 2,437.50

Kartik 23/11/2022 Revision and drafting the Part 19 application 1.20 450.00 540.00 Sharma bundle for the subpoena orders against Himalayan entities. Jeremy 24/11/2022 Call re subpoena app with AMT and Kartik 0.50 975.00 487.50

Kartik 24/11/2022 Catch up meeting with AT and JC on Part 19 0.60 450.00 270.00

Andrew 25/11/2022 Calls with respondents re costs incidence and call 0.80 1,050.00 840.00

Jhneil 25/11/2022 Service of Approved orders on RA's 0.40 400.00 160.00

Kartik 25/11/2022 Further revision after calls with JCC and AMT for 2.80 450.00 1,260.00

Sharma Part 19 affidavit for the subpoena orders against Himalayan and other entities. Andrew 28/11/2022 Drafting affidavit evidence and reviewing Appleby 6.00 1,050.00 6,300.00

draft evidence for subpoena app (2.00). 2.50 975.00 2,437.50 Child Various team emails re: same. (0.50) Kartik 28/11/2022 Drafting the affidavit for Part 19 1.70 450.00 765.00

George 29/11/2022 For Genver file: review retention application (0.60) 1.00 850.00 850.00

Weston 29/11/2022 Genever: Review retention app for Genever 0.60 850.00 510.00

Sharma 29/11/2022 Drafting the part 19 application-subpoena 1.00 450.00 450.00

Sharma 29/11/2022 Took instructions from Andrew Thorp on research

two emails from Andrew Thorp on issues in the Part19/Subpoena affidavit 0.10 450.00 45.00

Sharma 29/11/2022 Research on equivalent powers of trustee in BVI as England and understanding whether US Subpoena order can be replicated in the BVI (using English law to understand its breadth) 1.40 450.00 630.00

Thorp 30/11/2022 Email advice re costs and timing of subpoenas 0.60 1,050.00 630.00

Sharma 30/11/2022 Research on equivalent powers of trustee in BVI as England and understanding whether US Subpoena order can be replicated in the BVI (deploying English law to understand its breadth) 3.50 450.00 1,575.00

Weston 01/12/2022 Attend review meeting with Doug Shalka and

Weston 02/12/2022 Prep for and attend chapter 11 call (0.30); calls (1.0) and emails re security registration against

Sharma 02/12/2022 Call with Alex, Jonathan, Nicholas and Andrew Thorp to discuss case strategy. 0.50 450.00 225.00

Weston 05/12/2022 Update retention application for Kwok for Genever 0.80 850.00 680.00

Weston 09/12/2022 Email correspondences with Paul Hastings for

Child 14/12/2022 Various team queries re Kwok orders (0.80), addressing same (0.40) and setting way forward

Sharma 14/12/2022 Conference call with Andrew Thorp to draft a short

Sharma 14/12/2022 Short note for PH 2.40 450.00 1,080.00

Sharma 14/12/2022 Research on the question of costs in compliance if an application for examination of persons is made

Child 16/12/2022 Drafting amends to draft minutes and discussing way forward with RD and AMT 2.00 975.00 1,950.00

Child 21/12/2022 Emails with team re format of minute of order 0.60 975.00 585.00

Duncan 21/12/2022 Liaising with support re updating Harneys

with FFP disclosure. 0.60 475.00 285.00

Duncan 21/12/2022 Calls with AMT re disclosure order for Conyers corporate services and emails with AMT and JCC re same. (0.40)Email from Conyers. (0.20) Updated draft order from JCC, considering changes. (0.40) Email to Conyers with draft order. (0.20) Drafting

order for Trident. (0.40) Email to Trident re draft order. (0.20) Update to AMT. (0.20) 2.00 475.00 950.00

Child 29/12/2022 Emails with team re format of minute of order for Conyers and Campbells 0.80 975.00 780.00

January 1, 2023 through July 31, 2023:

Child 04/01/2023 Finalising orders discussing with team 1.00 - -

McKenzie 04/01/2023 Email to Judicial Assistant enclosing updated draft order re hearing on 21 November 2022. 0.20 650.00 130.00

McKenzie 04/01/2023 Email from AMT re draft order from hearing on 21 November 2022; reviewing same; email to AMT

McKenzie 05/01/2023 Email from Judicial Assistant enclosing approved draft order dated 21 November 2022 and response email (0.20); perfecting order, filing perfected order and email instructions to LIT support re sealing

Child 05/01/2023 Finalize discovery order 0.60 1,070.00 642.00

Child 09/01/2023 Discussing Kwok orders with AMT and team (0.60), amending same (0.40) 1.00 1,070.00 1,070.00

Calme 09/01/2023 Assisted AMT with retrieving the disclosure documents sent by Ben Mellet ftom Conyers. (0.20)

sharing platform.

McKenzie 10/01/2023 Email from LIT support enclosing sealed order dated 21 November 2022 (second respondent) and email update to AMT enclosing same. 0.20 650.00 130.00

Duncan 10/01/2023 Email from P. Tobin re approved disclosure order for 4th respondent. 0.20 550.00 110.00

Child 10/01/2023 Discussing seal/gag extension letter with KS and AMT (0.60), amending draft (0.40) 1.00 1,070.00 1,070.00

Sharma 10/01/2023 Drafted Letter to the Judge for Extension of Seal

Sharma 10/01/2023 Drafted disclosure order for 4th respondent 0.20 500.00 100.00

Sharma 10/01/2023 Drafted new Order for Extension of Seal and Gag

Sharma 11/01/2023 Drafted letter of extension for seal and gag and draft order for seal and gag. 1.00 500.00 500.00

Child 11/01/2023 Amending draft extension docs (0.80) and emails with team (0.20) 1.00 1,070.00 1,070.00

Duncan 12/01/2023 Update from senior counsel re disclosure. (0.20) Follow up call to trident and complete missing parts

Duncan 12/01/2023 Email from AIM to support re adding case file

Thomas 13/01/2023 Email re CAY team to request search on Blue

Thorp 13/01/2023 Settling orders by consent with all parties (1.00), liaising with judge to avoid formal hearing (1.00), numerous calls to registrar (1.00) 3.00 1,215.00 3,645.00

Weston 16/01/2023 Email correspondence with Paul Hastings in relation to Kwok case. 0.20 800.00 160.00

Duncan 18/01/2023 Email with detailed instructions to support to deal with clean order for sealing. 0.40 550.00 220.00

Duncan 18/01/2023 Email from support with clean order and Email to support with filed order with instructions to lodge at court with approved version. (0.20) Reviewing and filing. (0.20) Instructions to add filing disbursement. (0.20) 0.60 550.00 330.00

Duncan 18/01/2023 Detailed email from Campbells with detailed suggested updates to proposed draft order.

Thorp 18/01/2023 Review of order (0.20), speaking with Ocorian counsel (0.60) and settling (0.20) 1.00 1,215.00 1,215.00

Duncan 23/01/2023 Notification from e-portal with sealed seal and gag

Duncan 31/01/2023 Emails with Campbells re NPO fees. Considering. 0.20 550.00 110.00

Duncan 01/02/2023 Emails with AMT and Campbells overnight. (0.20) Agreement of form of draft order and instructions to pay fees directly to RA. (0.40) Instructions from AMT to finalise disclosure order for third respondent and send to court for approval (0.40); detailed review of previous orders for other

sending to court with Campbells in copy (0.60). Diarising expiry of seal and gag and sending invites

dealing with clean order for sealing for fourth respondent. (0.40) Filing clean order and instructions to support to add disbursement and lodge order high court registry for sealing. (0.40) 2.80 550.00 1,540.00

Duncan 03/02/2023 Email from Conyers re corrected order granting in part motion for preliminary injunction. 0.20 550.00 110.00

Duncan 03/02/2023 Email from AMT to client re injunction order served on companies and possible impact on BVI

Duncan 03/02/2023 Email from GZO with sealed order for fourth respondent. (0.20) Reviewing and confirming of

Duncan 07/02/2023 Email from Court with approved draft disclosure order for third respondent and confirmation of receipt to court. (0.20) Detailed review of approved order from court and preparing clean order for sealing. (0.40) Finalizing and filing. (0.20) Downloading order and case file receipt and passing on to support with instructions to lodge at court for sealing and to add filing disbursement.

Duncan 13/02/2023 Update to KSH on developments on matter while

Sharma 14/02/2023 Perused disclosure documents in the case from all

Child 14/02/2023 Various emails re new entities with KS and AMT 0.40 1,070.00 428.00

Sharma 15/02/2023 Started drafting the affidavit to obtain disclosure on shareholder BVI cos 4.00 500.00 2,000.00

Child 06/03/2023 Considering position re extension (0.60), emails to team (0.40), checking previous orders/minutes

Sharma 06/03/2023 Drafted a seal and gag extension order 0.30 500.00 150.00

Sharma 06/03/2023 Email exchange with JCC about drafting seal and gag extension. (0.40) Drafting a seal and gag extension email to the Judge (0.60) 1.00 500.00 500.00

Sharma 07/03/2023 Email exchange with Romane Duncan to try and find orders from 21 Nov (S&G) -Phone call with

Child 07/03/2023 Various team emails re extension and position re

Duncan 07/03/2023 Reviewing matter file and eportal file. (0.40) Email to court re access to sealed orders on matter. (0.20) Liaising with KSH re matter and orders filed and application to extend seal and gag order. (0.40) 1.00 550.00 550.00

Duncan 08/03/2023 Detailed review of matter file and sending email to AMT re status of approved sealing order. 1.00 550.00 550.00

Sharma 08/03/2023 Drafting the seal and gag extension email to all respondents and court 1.10 500.00 550.00

Sharma 09/03/2023 Drafting the seal and gag extension order and emails to the court 0.40 500.00 200.00

Child 09/03/2023 Team emails re extension and email to court 1.60 - -

Duncan 10/03/2023 Detailed consideration of matter emails overnight with KSH, AMT and JCC and counsel for the respondents re finalization and obtaining extension of seal and gag order. (1.00) Email from Court requesting application notice. (0.20) Considering email and reviewing file, including letter to Court, draft order and court documents previously filed. (1.20) Drafting application notice to extend seal and

sending over draft. (0.20) Emails from KSH, AMT

application notice and draft order. (0.40) Further

evidence by 5th respondent. (0.20) Detailed review of matter file and confirmation to KSH. (1.20) 5.80 550.00 3,190.00

McKenzie 10/03/2023 Instructions from AMT re filing NOA for extension of seal and gag order, liaising with LIT support re same and email update to wider team. (0.20) attending to filing of NOA and draft order (0.20) 0.40 650.00 260.00

Sharma 10/03/2023 Email exchange with JCC, AT, Romane Duncan, Andre about drafting seal and gag extension application notice. (0.60) Drafted the seal and gag application notice. (1.20) Drafting a seal and gag extension email to the Judge. (1.20) 3.00 500.00 1,500.00

Child 10/03/2023 Emails re hearing bundle (0.40), considering contents (0.40) and checking over same. (0.20) 1.00 1,070.00 1,070.00

Child 10/03/2023 Drafting/amending drafts of NoA for extension 3.00 1,070.00 3,210.00

Sharma 13/03/2023 Updated the affidavit for use in NY Proceedings - - -

Sharma 13/03/2023 Drafting the affidavit for use in NY proceedings for

Duncan 13/03/2023 Email update to KSH re filings and email to Court confirming receipt of draft order and filing of

Duncan 13/03/2023 Email from Court re filing of hearing bundle and sending approved extension of seal and gag order. (0.40) Considering emails and attachments and reviewing matter file.(0.40) Notification from eportal re internal filing of approved order. (0.20)

approved order and retrieving draft order from eportal. (0.20) Preparing clean order for sealing. (0.20) Filing hearing bundle and clean order for sealing. (0.40) Email to support to add filing disbursements and instructions to lodge filed order for sealing. (0.20) Update matter folder with filings.

Duncan 14/03/2023 Liaising with KSH re updating affidavit for US Court re evidence from registered agents. (0.20) Considering email chain with AMT and client. (0.20) Reviewing matter file and confirming to KSH status of NPO evidence. (0.60) 1.00 550.00 550.00

Sharma 14/03/2023 Worked on the edited version of the affidavit for use in the NY proceedings (4.0) and incorporated changes suggested by PH. (1.30) 5.30 500.00 2,650.00

Sharma 17/03/2023 Research to link beneficial ownership of Mei Guo to Kwok's Estate proceedings in the BVI -drafted a note to send to PH (for JCC and AT) 2.40 500.00 1,200.00

Child 17/03/2023 Considering BVI application of US attachment 1.80 1,070.00 1,926.00

Thorp 17/03/2023 Call with Alex re strategy and attaching assets (0.40), considering jurisdiction (0.20) and advice

Thorp 20/03/2023 Update from Shiny Times director 0.40 1,215.00 486.00

Sharma 20/03/2023 Draft email to PH containing note on Part 19 applications and stop notices 0.30 500.00 150.00

Sharma 20/03/2023 Conference call with Jeremy Child and Andrew Thorp to discuss strategies on Kwok after US case development in Mei Guo's proceedings 0.30 500.00 150.00

Sharma 23/03/2023 Perused orders of US Bankruptcy Court relating to Mei Guo and attachment of her shares. 0.50 500.00 250.00

Weston 24/03/2023 Call re Kwok with Alex and Andy; dealing with conflicts issues (non-billable) 1.00 - -

Thorp 24/03/2023 Call with PH re strategy and stop notices 1.00 1,215.00 1,215.00

Thorp 24/03/2023 Strategy note for PH re injunctions and stop notices, review of US orders 2.00 1,215.00 2,430.00

Child 28/03/2023 Work on stop notices with Kartik, various emails 2.00 1,070.00 2,140.00

Sharma 28/03/2023 Ordered search for various BVI companies in which Mei Guo has beneficial interest 0.50 500.00 250.00

Weston 29/03/2023 Updating declaration 2.00 - -

Weston 30/03/2023 Drafting updated declaration 2.20 - -

Child 30/03/2023 Various team emails re stop notices/injunction/attachment 1.20 1,070.00 1,284.00

Sharma 31/03/2023 Drafted affirmation for stop notices pursuant to US orders on 17.3.23 (1.20). Written correspondence with Jeremy and Andy for the above legal analysis.

Child 03/04/2023 Considering position re beneficial interest % and evidence supporting same (0.80), discuss with team

Child 04/04/2023 Considering draft stop notice and need for multiple

Sharma 04/04/2023 Drafted affirmation and stop notices pursuant to US

correspondence with Jeremy and Andy for the above legal analysis. (2hrs) 4.10 500.00 2,050.00

Sharma 05/04/2023 Updated stop notices and affirmation after comments from Andrew and Jeremy 2.20 500.00 1,100.00

Child 05/04/2023 Amending stop notices 1.60 1,070.00 1,712.00

Thorp 05/04/2023 Review of stop notices and evidence -

and steps taken 2.00 1,215.00 2,430.00

Child 06/04/2023 Amending stop notices 1.20 1,070.00 1,284.00

Sharma 06/04/2023 Reviewed and updated stop notices and affirmation 0.50 - -

Sharma 06/04/2023 Drafted affirmation for stop notices pursuant to US orders on 17.3.23 (2.40) Written correspondence with Jeremy and Andy for the above legal analysis.

Sharma 06/04/2023 Reviewed and updated stop notices and affirmation 1.20 - -

Thorp 06/04/2023 Finalizing stop notices and covering affidavit

Sharma 13/04/2023 Updated affirmation and stop notices after feedback

Sharma 13/04/2023 Updated affirmation and stop notices after feedback

Thorp 17/04/2023 Confirming members register and mails with PH 0.60 1,215.00 729.00

Thorp 18/04/2023 Note re beneficial interests and masking ownership

Sharma 18/04/2023 Research and drafted a legal opinion on beneficial ownership in the BVI 3.20 500.00 1,600.00

Sharma 25/04/2023 Research on trusts law and preparation of memorandum on bare trusts 3.80 500.00 1,900.00

Child 25/04/2023 Amending bene shareholder note from Kartik (2.00), emails with AMT and Kartik (1.00), email

Child 26/04/2023 Research on cases to see if checklist required by clients can be found, (1.20) various emails with team re same and re Kartik checklist (0.80) 2.00 1,070.00 2,140.00

Sharma 26/04/2023 Research on trusts law for preparing a summary

communicated in an email (1.80) 3.00 500.00 1,500.00

Thorp 26/04/2023 Preparation, review and report on veil piercing and trust arguments. (2.00) Calls with PH re content and further research and review (1.00) 3.00 1,215.00 3,645.00

Thorp 27/04/2023 Drafting of checklist for bare trust arguments 1.20 1,215.00 1,458.00

Duncan 27/04/2023 Emails from team re urgent application. (0.20) Liaising with KSH re same. (0.20) Emails form AMT re scope of application. (0.20) Early drafts of application documents. (0.60) 1.20 550.00 660.00

Sharma 27/04/2023 Updated changes to the affidavit and the OA 2.20 500.00 1,100.00

Sharma 27/04/2023 Call with JCC and AT to discuss strategy on disclosure from Trident 0.20 500.00 100.00

Sharma 27/04/2023 Drafting affidavit and application for disclosure on

team (0.80), amending same (1.00) 3.80 1,070.00 4,066.00

Child 28/04/2023 Drafting skeleton (4.00), amending affirmation (1.00), reading and responding to many emails with team re basis for application and urgency (1.00) 6.00 1,070.00 6,420.00

Duncan 28/04/2023 Emails with client re finalising evidence and outstanding information to add to supporting evidence. (0.20) Call with KSH re next steps and progressing evidence. (0.20) Emails from AMT re status update. (0.20) 0.60 550.00 330.00

Duncan 28/04/2023 Detailed consideration of evidence in support of application for further disclosure against trident. (1.00) Emails on next steps with JCC. (0.20) Making amendments to current draft of affidavit in support of application. (1.00) Making significant amendments to draft application notice. (1.00) Drafting first turn on certificate of urgency and draft order. (1.00) Reviewing previous evidence and court documents filed and making further amendments to current drafts. (0.20) 4.40 550.00 2,420.00

Duncan 28/04/2023 Application for disclosure order against Trident: Several emails from team re latest draft of

Thorp 28/04/2023 Finalizing drafts and orders, considering timing and

Stewart 28/04/2023 Reviewing and finalising

(1.20); preparing covering affidavit and exhibit and arranging same for swearing (1.20); swearing covering affidavit discussion with AMT re application documents (1.00) 3.40 550.00 1,870.00

Thorp 28/04/2023 Calls with client and listing re urgency 1.00 1,215.00 1,215.00

Thorp 28/04/2023 Drafting evidence and applications. 4.00 1,215.00 4,860.00

Fung 28/04/2023 Reviewing and amending draft Ordinary Application for Norwich Pharmacal order. (0.40) Internal discussions and providing assistance on draft Second Affidavit of client. (0.20) 0.60 550.00 330.00

Kartik 28/04/2023 Preparation of NPO application for Ace Decade 6.20 500.00 3,100.00

Thorp 28/04/2023 Review of amendments (0.80), noting change of stance re English proceedings (0.40), considering impact on necessity test and skeleton argument

Child 29/04/2023 Considering authorities bundle and starting to

Thorp 29/04/2023 Updating evidence and drafts in light of urgency 1.60 1,215.00 1,944.00

Child 29/04/2023 Reading amended drafts and considering effect

Child 30/04/2023 Amending skeleton (1.20), other drafts and emails with team, considering authorities and needed

Duncan 30/04/2023 Instructions from AMT to review application

Child 30/04/2023 Considering relevant authorities 2.00 1,070.00 2,140.00

Sharma 30/04/2023 Amendments to draft order (1.20) and preparation of hearing bundle (2.00) 3.20 500.00 1,600.00

Stewart 01/05/2023 Responding to emails from client re docs for

Stewart 01/05/2023 Reviewing documents for filing (0.40); preparing hearing bundle index and listing request (0.40); edits to application documents (0.40); internal discussion with AMT (0.20); finalizing application documents (0.60); internal emails and discussions re next steps (0.20); email to AMT re final docs and

Stewart 01/05/2023 Internal discussion with KSH re filings 0.20 550.00 110.00

suits of docs (1.20), emails with client and listing

Duncan 01/05/2023 Detailed review of further disclosure application

update to team with updated drafts. (0.20) Emails from KSH and AMT re same. (0.20) Call with JQS re finalizing documents. (0.40) Update to KSH re evidence in support. (0.20) Liaising with KSH re hearing bundle and cross referencing skeleton. (0.20) Email update from client. (0.20) Emails to client re status of application documents. (0.20) Liaising with JQS re certificate of urgency and instructions from KSH and AMT to finalize application documents. (0.40) 4.00 550.00 2,200.00

Thorp 02/05/2023 Emails re finalizing evidence and applications. (0.40) Making amendments (0.60) 1.00 1,215.00 1,215.00

Stewart 02/05/2023 Internal discussion with AMT re strategy 0.20 550.00 110.00

Stewart 03/05/2023 Instructions to KSH re next steps 0.20 550.00 110.00

Stewart 03/05/2023 Finalizing application documents for filing (0.40); filing application docs (0.40); preparing hearing bundle (0.80); cross referencing hearing bundle with skeleton (0.40); email update to team re same

Stewart 03/05/2023 Creating iManage link re service of documents (0.20); email to trident re service (0.20) 0.40 550.00 220.00

Stewart 03/05/2023 Matter management: downloading and

(0.20); instructions to team to add case file receipt

Thorp 04/05/2023 Considering finalized documents (0.20), filing listing (0.20) and explain to Pete the strategy (0.20) 0.60 1,215.00 729.00

Thorp 04/05/2023 Call with Trident setting out position and background and explaining news for no opposition 0.80 1,215.00 972.00

Child 04/05/2023 Considering authorities and docs for application 3.60 1,070.00 3,852.00

Thorp 05/05/2023 Email to court x 2 regarding filing and no opposition from Trident 0.80 1,215.00 972.00

Child 05/05/2023 Preparation for potential urgent hearing (1.40), annotating bundle (0.80), preparing submissions (1.20), checking authorities (1.00) 4.40 1,070.00 4,708.00

Thorp 08/05/2023 Review of order from court and disclosure granted (0.20), mail to judicial assistant (0.20) and update to clients (0.20) 0.60 1,215.00 729.00

Child 08/05/2023 Emails in respect of approved order with team 0.50 1,070.00 535.00

Thorp 09/05/2023 Email to trident re disclosure 0.20 1,215.00 243.00

Thorp 09/05/2023 Considering seal and gag on appeal and narrative in

Stewart 09/05/2023 Finalizing and filing order for sealing; instructions

Child 09/05/2023 Sending various emails re court order to obtain

Stewart 10/05/2023 Email to trident re sealed order of the court 0.20 550.00 110.00

Thorp 12/05/2023 Email in regarding affidavit of service, obtaining

Thorp 12/05/2023 Obtaining disclosure and review of content (0.60), mails to PH and next steps (0.40) 1.00 1,215.00 1,215.00

Duncan 14/05/2023 Email from AMT to client re Trident disclosure and from client re same. (0.20) Updating client matter to create new folder and upload the new disclosure served by Trident. (0.20) Email to team re same.

Weston 15/05/2023 Email correspondence with Paul Hastings in

Thorp 16/05/2023 Call in from PH re next steps and transfer of interest in Ace decade 0.40 1,215.00 486.00

Thorp 16/05/2023 Sorting affidavit of service 0.20 1,215.00 243.00

Thorp 16/05/2023 Sending sealed order and advising re deployment in English proceedings 0.40 1,215.00 486.00

Thorp 16/05/2023 Initial review of Ace decade transfer and an initial

Thorp 16/05/2023 Finalizing affidavit of service 0.40 1,215.00 486.00

Stewart 16/05/2023 Email to AMT re sealed order 0.20 550.00 110.00

Duncan 16/05/2023 Emails from AMT and client re affidavit of service. (0.60) Considering emails and reviewing historical emails and sending update to team. (0.40) 1.00 550.00 550.00

Thorp 17/05/2023 Considering relief under pet 19 and transfer of

reference back to Alaina cases and submission to jurisdiction (0.60) 1.40 1,215.00 1,701.00

Duncan 17/05/2023 Detailed email from AMT considering seeking declaration from BVI Court re ownership of BVI company in Kwok bankruptcy. Considering BVI on

Child 18/05/2023 Considering various questions re: potential application in BVI to determine ownership of shares, (1.60) discussing with team. (0.60) 2.20 1,070.00 2,354.00

re position on fees and disclosure 0.60 1,215.00 729.00

Sharma 24/05/2023 Drafted emails to Ogier

Child 24/05/2023 Considering questions from client and providing my views to A Thorp by email 2.50 1,070.00 2,675.00

Thorp 12/06/2023 Review of temporary restraining order

arranging service 0.60 1,215.00 729.00

Thorp 15/06/2023 Review of service documents and emails with client 0.60 1,215.00 729.00

Thorp 19/06/2023 Arranging service and evidence, emails to FH 0.60 1,215.00 729.00

Thorp 27/06/2023 Noting service and letter to FH 0.40 1,215.00 486.00

Thorp 28/06/2023 Advising on service issues 0.40 1,215.00 486.00

Pease 18/07/2023 Phone call with AMT to discuss strategy around rectification claim without adding/serving alleged owner; discussing potential consequences. 0.40 1,215.00 486.00

Thorp 18/07/2023 Considering nature of application and steps to assert control over Ace decade (0.80), discussion with Corp (1.00) and drafting opinion (1.00) 2.80 1,215.00 3,402.00

Thorp 19/07/2023 Call with PH and considering various procedures re shares, follow up note 1.00 1,215.00 1,215.00

Thorp 20/07/2023 Detailed note of options, law changes and

Brown 21/07/2023 Reviewing instructions (0.20); drafting power of attorney (0.60);

Weston 21/07/2023 Call with Alex (0.40); draft power of attorney

Thorp 21/07/2023 Drafting advice and steps re position and rectification, considering case law and procedure, detailed steps plan 3.00 1,215.00 3,645.00

Thorp 21/07/2023 Call with Alex re power of attorney

04/08/2022 Company Search-Genever Holdings Corporat 195.00 09/08/2022 High Court Search-Genever 45.00 09/08/2022 High Court Search-Genever 32.00 09/08/2022 High Court Search-Kwok Ho Wan / Ho Wan K 45.00 09/08/2022 High Court Search-Genever Holdings Corpo 45.00 09/08/2022 High Court Search-Genever Holdings Corpo 10.00 09/08/2022 High Court Search-Genever 32.00 19/08/2022 Company Search-Himalaya International Fi 195.00 19/08/2022 High Court Search-Himalaya International 45.00 19/08/2022 Company Search-Himalaya International Re 195.00 19/08/2022 Company Search-Himalaya International Cl 195.00 19/08/2022 Company Search-Himalaya International Pa 195.00 19/08/2022 High Court Search-Himalaya International 45.00 19/08/2022 High Court Search-Himalaya International 45.00 19/08/2022 High Court Search-Himalaya International 45.00 01/09/2022 Company Search-ACE DECADE HOLDINGS LIMIT 195.00 01/09/2022 Company Search-DAWN STATE LIMITED 195.00 01/09/2022 High Court Search-ACE DECADE HOLDINGS LI 45.00 01/09/2022 High Court Search-DAWN STATE LIMITED 45.00 14/09/2022 Company Search-Hudson Diamond Holding In 195.00 14/09/2022 High Court Search-Hudson Diamond Holding 45.00 13/10/2022 Company Search-K Legacy Limited 195.00 13/10/2022 Company Search-Whitecroft Shore Limited 195.00 13/10/2022 High Court Search-K Legacy Limited 45.00 13/10/2022 High Court Search-Whitecroft Shore Limit 45.00 13/10/2022 Company Search-Shiny Times Holdings Limi 195.00 13/10/2022 High Court Search-Shiny Times Holdings L 45.00 13/10/2022 Company Search-Dawn State Limited 195.00 13/10/2022 Company Search-Shiny Times Holdings Limi 195.00 13/10/2022 Company Search-K Legacy Limited 195.00 13/10/2022 High Court Search-K Legacy Limited 45.00 18/10/2022 Company Search-Freedom Media Venture Ltd 195.00 19/10/2022 Company Search-Shiny Ace Limited 195.00 31/10/2022 Company Search-Splendor Union Limited 195.00 31/10/2022 Company Search-Head Win Group Limited 195.00

01/11/2022 Company Search-Wells Origin Limited 195.00

01/11/2022 Company Search-Seabrook Properties Limit 195.00 01/11/2022 High Court Search-Seabrook Properties Li 45.00 02/11/2022 High Court Search-Seabrook Properties Li 45.00

1st Affidavit of Romane Duncan on 100.00

Witness Statement, 3 x Exhibits, Affidavit, Draft Order, Ex

Originating Application, Draft Order, Listing Request, Order 333.01

06/12/2022 Company Search-Genever Holdings Corporat 65.00 06/12/2022 High Court Search-Genever Holdings Corpo 45.00

16/12/2022 Third party costs awareded in compliance with disclosure orders. FFP -

Sealed order for extension of seal and gag -

01/02/2023 Filing fees for sealed order for Fourth Respondent, Trident 27.00

Disclosure Order for third Respondent filed

14/02/2023 Company Search-Wise Creation Internation 195.00 14/02/2023 Company Search-Next Tycoon Investments L 195.00

NOA (extension of seal and gag order) and

1st Affidavit of Jhneil Stewart on 60.00

Affi, Cert., Appli., Exhib., Order & Listing 452.01

Affidavit of Service of Tea Fonseca 60.00 09/06/2023 Company Search-Holy City Hong Kong Ventu 250.00

Affidavit of Shemar Trim on 15 Jun 60.00

Affidavit of Shemar Trim on the 24 60.00 25/07/2023 Service of Document (Motion) on the 2023.07.19 -

25/07/2023 Conducting Service on Holy City HK Ventures, Ltd. c/o Intershore Consults on 2023.06.15 ( Summon and Notice of pretrial conference in an

25/07/2023 Conducting Service on Holy City HK Ventures, Ltd. c/o Intershore Consults on 2023.06.22 ( Emergency Motion and Order

25/07/2023 Conducting Service on Holy City HK Ventures, Ltd. c/o Intershore Consults on 2023.06.29 ( Notice regarding temporary restraining Order and June 26 status Conference , Memo Order granting in part motion to continue PI hearing and Order Granting Motion 500.00

Consults on 2023.06.26 (Motion to expedite hearing and motion regarding

25/07/2023 Conducting Service on Holy City HK Ventures, Ltd. c/o Intershore

on 2023.07.10 ( Omnibus reply regarding settlement with

25/07/2023 Conducting Service on Holy City HK Ventures, Ltd. c/o Intershore Consults on 2023.07.12 ( Scheduling order ) 500.00 25/07/2023 Conducting Service on Holy City HK Ventures, Ltd. c/o Intershore Consults on 2023.07.24 (Motion for Order setting deadline for Holy City ) 500.00