--- type: court_doc id: "court_ctb_2273_0" court: "CTB" case_no: "22-50073" doc_number: 2273 doc_type: "ORDER" filed_date: "2023-10-22" lang: "en" machine_translated: false url: "https://mubeitech.com/en/court/court_ctb_2273_0" json_url: "https://mubeitech.com/api/court/court_ctb_2273_0" --- # Guo Wengui / Miles Guo — bankruptcy case · ORDER · ECF #2273 **Notice of Filing DOJ Opposition —— In re Ho Wan Kwok (Miles Guo / Guo Wengui), CTB 22-50073 ECF #2273 (filed 2023-10-22). Chapter 11 Trustee Luc A. Despins filed notice in the bankruptcy court attaching the U.S. Department of Justice's opposition to the debtor's motion in SDNY criminal case (1:23-cr-00118-AT) that sought to compel discovery of communications and documents exchanged between the Government, the Trustee, and the SEC.** UNITED STATES BANKRUPTCY COURT DISTRICT OF CONNECTICUT BRIDGEPORT DIVISION ------------------------------------------------------　x In re:　: :　Chapter 11 HO WAN KWOK et al.,　: :　Case No. 22-50073 (JAM) Debtors.1　: :　Jointly Administered x **NOTICE OF FILING BY CHAPTER 11 TRUSTEE OF UNITED STATES DEPARTMENT OF JUSTICE'S OPPOSITION TO DEBTOR'S MOTION IN CRIMINAL CASE FOR ORDER COMPELLING DISCOVERY OF COMMUNICATIONS AND DOCUMENTS EXCHANGED WITH CHAPTER 11 TRUSTEE** Luc A. Despins, as chapter 11 trustee (the "Trustee") for Ho Wan Kwok (the "Debtor"), hereby provides notice that, on Thursday, October 19, 2023, the United States Department of Justice (the "Government") filed its memorandum of law in opposition (the "Government's Opposition") to the Debtor's motion in the Criminal Case2 seeking, pursuant to Federal Rule of Criminal Procedures 16, an order compelling production of all communications and documents exchange between the Government and (i) the Trustee and his agents and (ii) the Securities and Exchange Commission concerning the subject matter of the superseding indictment filed in the Criminal Case. A copy of the Government's Opposition is attached hereto as Exhibit 1. 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 The "Criminal Case" refers to the criminal case pending against the Debtor in the United States District Court for the Southern District of New York [Case No. 1:23-cr-00118-AT]. Among other things, the Trustee wishes to highlight pages 19 through 25 of the Government's Opposition, which sets forth the Government's argument in opposition to the Debtor's request to compel discovery of communications between the Government and the Trustee. Dated: October 22, 2023 New York, New York By: /s/ G. Alexander Bongartz Avram E. Luft (admitted pro hac vice) G. Alexander Bongartz (admitted pro hac vice) PAUL HASTINGS LLP 200 Park Avenue New York, New York 10166 (212) 318-6079 aviluft@paulhastings.com alexbongartz@paulhastings.com and Nicholas A. Bassett (admitted pro hac vice) PAUL HASTINGS LLP 2050 M Street NW Washington, D.C., 20036 (202) 551-1902 nicholasbassett@paulhastings.com and Douglas S. Skalka (ct00616) Patrick R. Linsey (ct29437) NEUBERT, PEPE & MONTEITH, P.C. 195 Church Street, 13th Floor New Haven, Connecticut 06510 (203) 781-2847 dskalka@npmlaw.com plinsey@npmlaw.com Counsel for the Chapter 11 Trustee UNITED STATES BANKRUPTCY COURT DISTRICT OF CONNECTICUT BRIDGEPORT DIVISION ------------------------------------------------------　x In re:　: :　Chapter 11 HO WAN KWOK, et al.,1　: :　Case No. 22-50073 (JAM) Debtors.　: : :　(Jointly Administered) CERTIFICATE OF SERVICE The undersigned hereby certifies that on October 22, 2023, the foregoing Notice was electronically filed. Notice of this filing was sent by e-mail to all parties to the above-captioned chapter 11 case by operation of the Court's electronic filing ("CM/ECF") system or by mail to anyone unable to accept electronic filing as indicated on the Notice of Electronic Filing. Parties may access this filing through the Court's CM/ECF system. Dated: October 22, 2023 New York, New York By: /s/ G. Alexander Bongartz G. Alexander Bongartz (admitted pro hac vice) PAUL HASTINGS LLP 200 Park Avenue New York, New York 10166 (212) 318-6079 alexbongartz@paulhastings.com Counsel for the Chapter 11 Trustee 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).