Guo Wengui / Miles Guo — bankruptcy case · EXHIBIT · ECF #2292-45

Case 22-50073 Doc 2292-45 Filed 10/26/23 Entered 10/26/23 20:46:12 Page 2 of 96 MARGARET CONBOY· Confidential KWOK V. GREENWICH LAND ET AL. September 12, 2023 1

2 Tuesday, September 12, 2023 3 10:00 a.m. 6 REMOTE Deposition of MARGARET CONBOY, held VIA ZOOM, before LISA M. MURACO, a Notary Public of the State of New York, Florida, and Massachusetts. MARGARET CONBOY· Confidential KWOK V. GREENWICH LAND ET AL. September 12, 2023 800.211.DEPO (3376)

1 2 A P P E A R A N C E S: 3 (REMOTE) 4 5 PAUL HASTINGS 6 Attorneys for Movant and Cross-Respondent 7 Mr. Luc A. Despins, Chapter 11 Trustee for 8 the Estate of Mr. Ho Wan Kwok 9 200 Park Avenue 10 New York NY 10166 11 BY: NICHOLAS BASSETT, ESQ. 12 Nicholasbassett@paulhastings.com 13 AVRAM LUFT, ESQ. 14 Aviluft@paulhastings.com 15 EZRA SUTTON, ESQ. 16 Ezrasutton@paulhastings.com 17 DOUGLASS BARRON, ESQ. 18 Douglassbarron@paulhastings.com 19 LUYI SONG, ESQ. 20 Luyisong@paulhastings.com 21 22 23 24 25 KWOK V. GREENWICH LAND ET AL. 3 Case 22-50073 Doc 2292-45 Filed 10/26/23 Entered 10/26/23 20:46:12 Page 5 of 96

1 2 A P P E A R A N C E S: 3 (REMOTE) 4 5 MEISTER SEELIG & FEIN 6 Attorneys for Defendants Greenwich LLC and 7 Hing Chi Ngok 8 125 Park Avenue 9 7th Floor 10 New York, NY 10017 11 BY: CHRISTOPHER MAJOR, ESQ. 12 Cjm@msf-law.com 13 AUSTIN KIM, ESQ. 14 Adk@msf-law.com 15 16 17 WHITMAN BREED ABBOTT & MORGAN 18 Attorneys for the Witness 19 500 West Putnam Avenue 20 Greenwich CT 06830 21 BY: MICHAEL THOMASON, ESQ. 22 Mthomason@wbamct.com 23 24 25 KWOK V. GREENWICH LAND ET AL. 4 Case 22-50073 Doc 2292-45 Filed 10/26/23 Entered 10/26/23 20:46:12 Page 6 of

MARGARET CONBOY· Confidential KWOK V. GREENWICH LAND ET AL.

4 respective parties herein, that filing and 5 sealing be and the same are hereby waived.

7 that all objections, except as to the form 8 of the question, shall be reserved to the 9 time of the trial.

11 that the within deposition may be sworn to 12 and signed before any officer authorized

14 force and effect as if signed and sworn 15 to before the Court.

3 witness, having been duly sworn by a Notary 4 Public, was examined and testified as follows:

6 MR. BASSETT: 7 Q. Thank you very much. 8 MR. MAJOR:

9 started, can we agree that we will do the

11 objections, except as to the form of the 12 question, are reserved. 13 MR. THOMASON:

14 Connecticut usual stipulations. 15 MR. BASSETT:

16 the usual stipulations because I don't know 17 what they are. 18 MR. MAJOR: Let's just set them up. 19 I think the most important one, just for 20 the administration of the deposition and to 21 make sure we can get through it, is that 22 objections, except as to the form of the 23 question, are reserved.

24 just object if I have any objections to the 25 form of the question, and leave it at that.

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1 M. CONBOY 2 So that we're not dealing with all -- you 3 know, a whole slew of objections like 4 hearsay and all of that kind of stuff. 5 Those can be dealt with later. 6 MR. BASSETT: I'm fine with that. I 7 think that's what the rule would provide. 8 MR. MAJOR: Yup. 9 MR. BASSETT: I mean, I don't want 10 to -- I'm not agreeing to quote, unquote, 11 usual stipulations with which I am not 12 familiar. But if we're all agreeing that 13 the Federal Rules of Civil Procedure and 14 the Federal Rules of Evidence apply to this 15 case, I have no problem with that. 16 MR. MAJOR: The objections are 17 reserved, so we don't have to make them 18 now. 19 MR. BASSETT: Again, I think -- 20 Chris, I think the rules provide for that, 21 but... 22 MR. MAJOR: Yeah, and then I just 23 want to make a statement on behalf of our 24 client Greenwich Land that we are the 25 maintaining the attorney-client privilege, KWOK V. GREENWICH LAND ET AL. 7

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KWOK V. GREENWICH LAND ET AL.

3 witness or her firm had with officers of 4 Greenwich Land LLC are privileged, as well 5 as mental impressions and speculation and 6 anything based on those communications are 7 privileged, including, without limitation, 8 any disclosures that have already been made 9 to the trustee, either in a 2004 exam or in 10 separate communications.

11 authorized disclosures of attorney-client 12 privileged communications, and therefore we 13 are asking the witness and her counsel that 14 she not testify to any communications she 15 had with Greenwich Land LLC officers or any 16 mental impressions or speculation the 17 witness may have derived or come to as a 18 result of communications with officers of 19 Greenwich Land LLC. 20 MR. BASSETT:

21 seen the 2004 deposition transcript in this

22 case, correct?

23 MR. MAJOR: When you say "in this 24 case," I don't know if you are -- assume 25 you are referring to Ms. Conboy's

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1 M. CONBOY deposition transcript? 3 MR. BASSETT: Yes. 4 MR. MAJOR: Yes, it's an exhibit to the complaint. 6 MR. BASSETT: Right. And if what you are saying is that now for the first time you are going to raise privilege over, for example, all the questions that we asked Ms. Conboy about documents involving her communications with Max Krasner and the like, and we are not going to be able to ask about those, then we have a serious problem, and you should have told us about that before the deposition today. 16 MR. MAJOR: Well, we weren't invited to the 2004 exam. This is our first appearance with this witness. And we are asserting the attorney-client privilege to the extent she's going to testify about communications she had with officers. And I don't know -- 23 (Multiple speakers.) 24 MR. BASSETT: Well -- Chris, you have -- suffice it to say you have long ago KWOK V. GREENWICH LAND ET AL. Case 22-50073 Doc 2292-45 Filed 10/26/23 Entered 10/26/23 20:46:12 Page 11 of 96 MARGARET CONBOY· Confidential September 12, 2023

KWOK V. GREENWICH LAND ET AL.

3 contained in our complaint and attached in 4 the deposition transcript filed publicly is 5 privileged information.

6 way, you should have said something months 7 ago.

8 going to entertain that argument.

9 don't we -- why don't we start and we will 10 see where we go.

11 where you're not letting me conduct this 12 deposition in the way I need to conduct it, 13 we're going to have a take a break and 14 we're going to have figure this out. 15 MR. MAJOR: Okay.

16 argument for you to entertain.

17 Greenwich Land owns the privilege. 18 MR. BASSETT:

19 Chris. 20 MR. MAJOR: No. No.

21 participated in that. 22 MR. BASSETT: All right.

23 just -- all right, let's -- let's just go 24 and see how it goes. 25 MR. MAJOR:

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1 M. CONBOY 2 you or other representatives of the trustee 3 said to Whitman Breed to induce those 4 communications, but, you know, the 5 privilege is owned by Greenwich Land LLC. 6 It's not the trustee's call. And it's not 7 something for you to entertain. 8 MR. BASSETT: All right. Well, I'm 9 not agreeing with any of that, but, like I 10 said, let's continue. 11 BY MR. BASSETT: 12 Q. All right. Ms. Conboy, sorry for 13 that detour. 14 A. No. 15 Q. You and I have not had the pleasure 16 of meeting before but, again, I'm Nick Bassett 17 with Paul Hastings. We are counsel to the 18 Chapter 11 trustee in Ho Wan Kwok's bankruptcy 19 case. 20 A. Nice to meet you. 21 Q. Ms. Conboy, I note, A, you're a 22 lawyer; and B, you've been deposed before, so I 23 won't -- I won't bother going over kind of the 24 rules of the road here. 25 The one thing I'll mention at the KWOK V. GREENWICH LAND ET AL. 11 Case 22-50073 Doc 2292-45 Filed 10/26/23 Entered 10/26/23 20:46:12 Page 13 of 96

2 outset is that I know you do have other 3 obligations this afternoon.

4 get you out of here, I think, in no more than 5 four hours, and I'm confident we will be able 6 to do that, and to help be as expeditious as 7 possible, I do not plan to take a lunch break, 8 but, obviously, if you need a break, if you 9 want a lunch break, if you want -- you know, 10 break at any time, feel free to let me know. 11 And as long as you answer any pending question, 12 I'll be happy to accommodate. 13 Is that okay? 14 A. That's fine. Thank you. 15 Q. All right. You are welcome.

17 the moment?

18 Connecticut? 19 A. Yes, Greenwich, Connecticut. 20 Q.

22 Mr. Thomason? 23 A. Yes. 24 Q. Okay.

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substance of any communications with your counsel, can you just describe for me what you did to prepare for today's deposition? A.

transcript and that affidavit, and that was it. Q.

are you referring to? A.

affidavit that was drafted, I think, by your office or Chris Major's office. Q. Did you review any other documents? A. No. Q. Okay. And where do you currently reside? Ms. Conboy, are you a resident of Connecticut? A. In Greenwich, yes. Q.

Breed Abbott & Morgan LLC, that's the full name? A. Yes. Q. What is your title? A. I'm a real estate attorney.

Q. Okay.

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2 A. -- at the firm.

4 estate law. 5 Is that a accurate description? 6 A. Yes.

8 real estate law? 9 A. About 30 years. 10 Q. How long at Whitman Breed? 11 A. 30 years. 12 Q. Congratulations. 13 A. Thanks. 14 Q. And how long as a partner there?

16 somewhere around there. 17 Q. Okay.

19 recall being deposed previously by my colleague 20 Mr. Luft in February of this year, right? 21 A. Yes. 22 Q. So I'm going to have my colleague 23 introduce that deposition transcript as an 24 exhibit. 25 MR. BASSETT:

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2 Tab 1, Ezra. 3 MR. SUTTON:

4 chat. I'll share my screen shortly. 5 MR. BASSETT:

6 reporter to please mark this as Conboy 7 Exhibit 1.

9 Transcript from February 21, 2023, marked

11 BY MR. BASSETT: 12 Q. Ms. Conboy, I see this on my screen. 13 I trust you can see it on yours as well? 14 A. Yes. 15 Q.

16 which will allow you to download the document 17 yourself so that you can feel free to navigate 18 to any page of it that you would like. 19 A. Okay. 20 Q.

21 is just whether you can confirm that this is, 22 in fact, as far as you can tell, a copy of the 23 transcript of your February deposition in this 24 matter? 25 A. It looks like a copy, yup, yes.

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1 M. CONBOY 2 Q. Okay. 3 I just wanted to mark that. We'll 4 come back to it later. 5 Ms. Conboy, are you familiar, 6 generally, with Ho Wan Kwok, an individual by 7 that name? 8 A. Not -- no. 9 MR. MAJOR: Objection to form. 10 BY MR. BASSETT: 11 Q. You've heard of an individual named 12 Ho Wan Kwok, correct? 13 A. Yes. 14 Q. And what names? Do you know him by 15 any other names, based on your past 16 professional experience? 17 A. I've never met him and I've never 18 talked to him. So the only name I heard was 19 Miles Kwok. 20 Q. Okay. 21 And you understand that Miles Kwok 22 is the same person as Ho Wan Kwok, who is a 23 debtor in this case? 24 A. I have no personal knowledge of 25 that, but... KWOK V. GREENWICH LAND ET AL. 16 Case 22-50073 Doc 2292-45 Filed 10/26/23 Entered 10/26/23 20:46:12 Page 18 of 96

MARGARET CONBOY· Confidential KWOK V. GREENWICH LAND ET AL.

2 Q. Okay.

4 believe that the Miles Kwok you know from your 5 professional experience is not the same Miles 6 Kwok that is the debtor in this case? 7 MR. MAJOR: Objection to form. 8 BY MR. BASSETT: 9 Q. You can answer the question. 10 A. Can you say that again?

11 Q.

12 that the Miles Kwok who you know from your 13 professional experience is not the same 14 personal as Ho Wan Kwok who is the debtor in 15 this Chapter 11 case? 16 A. No. 17 MR. MAJOR: Objection. Form. 18 A. No, I don't. 19 Q. Okay.

21 Mr. Kwok today to refer to Miles Kwok. 22 Is that okay with you? 23 A. Yup, yes. 24 Q. Okay. 25 MR. MAJOR:

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2 exhibit to be marked highly confidential. 3 Contrary to counsel's statement it was not 4 publicly filed.

6 disclosures of privileged information.

7 would like it marked highly confidential. 8 MR. BASSETT: Okay.

9 was publicly available, but I will have to 10 confirm.

11 then I'll check that. 12 BY MR. BASSETT: 13 Q.

14 entity called Greenwich Land LLC? 15 A. Yes. 16 Q.

17 client of Whitman Breed's? 18 A. Yes. 19 Q.

20 representation? 21 A. Yes. 22 Q. What was your role? 23 A.

24 that LLC. 25 Q. Okay.

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2 All right.

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Q.

called Hudson Diamond New York LLC?

you, I mean your law firm. A. Yes. MR. MAJOR: Objection to form. BY MR. BASSETT:

25 Q.

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2 Tab 2 on the screen, please.

6 MR. BASSETT:

7 court reporter to please mark this document 8 as Exhibit 2, Conboy Exhibit 2. 9 BY MR. BASSETT: 10 Q.

11 document? 12 A.

14 Q. Okay. 18 A. Yes. 19 Q. Okay. 25 Do you see that?

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2 A. Mh-hm. 3 Q.

7 A. Yes. Yes. 8 Q. Okay. 13 A. Yes. 14 Q.

16 representation of these entities? 17 A. It was Max Krasner. 18 Q. Okay.

20 engagements of these entities, did you ever 21 speak at any time to Mr. Kwok's wife? 22 A. No. 23 Q.

24 deposition in February in this case, did you 25 know Mr. Kwok's wife's name? Case 22-50073 Doc 2292-45 Filed 10/26/23 Entered 10/26/23 20:46:12 Page 24 of 96

2 A. No. 3 Q.

4 son? 5 A. No. 6 Q.

7 daughter? 8 A. No. 9 Q.

10 Greenwich Land and Golden Spring in connection 11 with the purchase of residential property 12 located at 33 Ferncliff Road in Connecticut? 13 MR. MAJOR: Objection. 14 A. Yes. 15 MR. BASSETT:

16 colleague to put Tab 3 to the chat, please.

19 WBAM_000035, marked for identification.) 20 MR. BASSETT:

21 reporter to please mark this as Conboy 22 Exhibit 3. 23 BY MR. BASSETT: 24 Q.

25 document? Case 22-50073 Doc 2292-45 Filed 10/26/23 Entered 10/26/23 20:46:12 Page 25 of 96

2 A. Yes, I do. 3 Q. And I should have done this before. 4 I'll do it now, but just for the record,

8 I believe it starts with the Bates Label 9 WBAM_000035. 13 A. 14 Q.

20 MR. MAJOR: Objection to form. 21 A. 22 Q.

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4 A. Yes, I did. 5 Q. Okay.

7 date of the -- of the initial purchase of the 8 property and then -- well, I'll start with 9 that.

12 approximately? 13 A. I don't remember.

14 somewhere around there.

15 dates. 16 Q. Okay. 17 We can look at documents later.

19 your head, the approximate date of the sale? 20 A. Probably 2022. 21 Q. Okay. 22 A. But again, I'm not positive. 23 Q. No problem.

24 documents there as well.

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2 Ferncliff property to one side, which we just 3 established there was a purchase of that 4 property and then a sale of it, did you also 5 represent the same entities that we've been 6 talking about, Greenwich Land, Golden Spring, 7 and Hudson Diamond, in connection with 8 potential real property purchases that did not 9 close? 10 A. Yes. 11 Q.

12 were that you looked at on their behalf? 13 A.

14 MR. MAJOR: Objection. Form. 15 A. There was a Clapboard Ridge.

16 was one in Stamford, Chateau Ridge I believe in 17 Greenwich.

18 or four -- maybe four that we did. 19 Q. Okay. 20 So -- that's fine.

21 Ridge Road, does that sound right as one of the 22 properties? 23 A. Yes. 24 Q.

25 Road in Greenwich?

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2 A. Yes. 3 Q.

4 turn to your deposition transcript which is at 5 Tab 1, and I want to take you to page 35 of 6 that. 7 MR. MAJOR:

8 the record that, as we've insisted, that

10 confidential.

11 transcript referring to that document 12 should also be marked highly confidential. 13 MR. BASSETT: Okay.

14 obviously, that's fine under the protective 15 order, and we will reserve all of the 16 rights that we have under the protective 17 order in that regard, but that's fine.

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Q.

Stamford as another property about which there

was -- there were discussions of a potential

purchase?

A. Yes.

Q.

Greenwich?

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A. Yes.

Q. Thank you. Back to other properties.

recall another property with respect to which you provided advice to the entities we've been Case 22-50073 Doc 2292-45 Filed 10/26/23 Entered 10/26/23 20:46:12 Page 31 of 96

2 discussing as 11 Hurlingham Drive in Greenwich? 3 A. I don't really remember as much.

4 don't remember it. 5 Q. Okay.

7 later that references that property.

9 Greenwich? 10 A. Yes. 11 Q.

12 properties with respect to which you provided 13 advice under the engagement that we've been 14 talking about.

16 involving a property at 373 Taconic Road where 17 you did not represent Greenwich Land, Golden 18 Spring, or Hudson Diamond? 19 A. Yes. 20 Q.

21 transaction? 22 A. I was representing the seller. 23 Q. Okay.

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5 MR. BASSETT: I would like my 6 colleague to, please, put Tab 4 into the 7 chat. 8 (Conboy Exhibit 4, October 3rd, 9 2019, E-mail Bates labeled WBAM\_010076, 10 marked for identification.) 11 MR. BASSETT: And this document will 12 be marked as -- I would like it to be 13 marked as Conboy Exhibit 4. And for the 14 record, this is an October 3rd, 2019, 15 e-mail with the Bates label in the bottom 16 right-hand corner WBAM\_010076. 17 BY MR. BASSETT: 18 Q. Ms. Conboy, these documents that 19 we've been seeing that have a Bates label 20 beginning with WBAM in the lower right-hand 21 corner, do you understand that these are 22 documents Whitman Breed produced from its files 23 to the trustee? 24 A. Yes. 25 Q. And these documents that were Case 22-50073 Doc 2292-45 Filed 10/26/23 Entered 10/26/23 20:46:12 Page 34 of 96

2 produced, are these documents that the firm 3 kept in its ordinary course of business? 4 A. Yes. 5 Q. Do you recall -- well, strike that.

7 appears here in Conboy Exhibit 4? 8 A. Yes. 9 Q. Who is Kevin Walsh? 10 A. He's our managing partner.

11 partner of mine. 12 Q.

13 of the e-mail -- Kevin, my client, the Chinese 14 billionaire, may purchase 602 Indian Field 15 which is the 11-acre vacant parcel at the end 16 of Meade's Point. 17 Do you see that? 18 A. Yes. 19 Q.

20 whom you are referring to in this e-mail? 21 MR. MAJOR: Objection to form. 22 A.

23 to in -- when you do a Google search. 24 Q. Okay.

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2 you used the words "the Chinese billionaire," 3 that was a reference to Miles Kwok? 4 A. Yes. Through Google. 5 MR. THOMASON: Yes-or-no question. 6 BY MR. BASSETT: 7 Q.

8 of that sentence you say:

9 his offer of \$35 million. 10 Do you see that? 11 A. Yes. 12 Q.

13 reference to the Chinese billionaire, Miles 14 Kwok? 15 MR. MAJOR: Objection to form. 16 A. Yes. 17 Q.

18 this e-mail, you say:

19 will really go through.

20 architects, engineers, et cetera.

22 there.

23 engineers, et cetera.

24 reference to the Chinese billionaire, Mr. Kwok, 25 right?

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2 MR. MAJOR: Objection to form. 3 A. Yes. 4 Q.

5 this e-mail it says:

6 owner has approval to build two house.

7 sure if my client will just build one house or 8 two. My client has had me hold off on ordering 9 searchs until he has an idea of what is 10 involved in building on the parcel.

12 this e-mail, the references to "my client" when 13 you wrote this e-mail were to the Chinese 14 billionaire Miles Kwok, right? 15 MR. MAJOR: Objection to form. 16 A. Yes. 17 Q.

18 with respect to this potential property 19 purchase, this is all work under the umbrella 20 of the engagements that we talked about 21 previously, right, the Greenwich Land, Hudson 22 Diamond, and Golden Spring engagement? 23 MR. MAJOR: Objection to form. 24 A. Yes. 25 Q. Okay.

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1 M. CONBOY 2 MR. BASSETT: Can my colleague, 3 please, put Tab 5 into the chat. 4 (Conboy Exhibit 5, January 22, 2019, 5 E-mail Bates labeled WBAM\_0002663, marked 6 for identification.) 7 MR. BASSETT: And this one will be 8 marked as Conboy Exhibit 5; is that 9 correct? Thanks. Sorry. 10 BY MR. BASSETT: 11 Q. So for the record the document being 12 mark as Conboy Exhibit 5, is a January 22, 13 2019, e-mail with the Bates label at the bottom 14 right-hand corner of the first page 15 WBAM\_0002663. 16 Ms. Conboy, if you look at the 17 e-mail nearest the bottom of this page at 18 2:58 p.m., begins: Hi Kristi. 19 Is that an e-mail that you wrote? 20 A. Yes. 21 Q. You say: Hi Kristi, can you order a 22 full title and municipal search for 140 23 Wallacks Drive, Caritas Island, Stamford? 24 Do you see that? 25 A. Yes. KWOK V. GREENWICH LAND ET AL. 36 Case 22-50073 Doc 2292-45 Filed 10/26/23 Entered 10/26/23 20:46:12 Page 38 of 96

1 M. CONBOY 2 MR. THOMASON: Can you zoom in just 3 a little bit. 4 THE WITNESS: Yes, it needs to be. 5 MR. BASSETT: Sure. 6 MR. THOMASON: Perfect. 7 BY MR. BASSETT: 8 Q. So you were asking a colleague here 9 to perform a title and municipal search; is 10 that right, for a potential property to be 11 acquired? 12 A. Yes. 13 Q. If you go up to the top e-mail in 14 the chain, you say: Hi Bob. 15 Who is Bob? 16 A. Our title searcher. 17 Q. Okay. 18 You said: Hi Bob, I would like you 19 to do the searches because this is a high-end 20 property on the water. The Chinese billionaire 21 has accepted an offer. Thanks. 22 Do you see that? 23 A. Yes. 24 Q. And to whom is the Chinese 25 billionaire a reference? KWOK V. GREENWICH LAND ET AL. 37 Case 22-50073 Doc 2292-45 Filed 10/26/23 Entered 10/26/23 20:46:12 Page 39 of 96

1 M. CONBOY 2 A. Mr. Kwok. 3 MR. BASSETT: Can my colleague, 4 please, put Tab 6 on the screen. 5 (Conboy Exhibit 6, January 6, 2019, 6 E-mail, Bates Stamped WBAM\_002803, marked 7 for identification.) 8 MR. BASSETT: For the record, Conboy 9 Exhibit 6 is an e-mail chain, the top 10 e-mail dated January 6, 2019, Bates stamped 11 at the bottom right-hand corner of the 12 first page WBAM\_002803. 13 BY MR. BASSETT: 14 Q. If we turn to page Bates labeled 15 2806. 16 What you'll see here is an e-mail 17 from an Emile deNeree to a Barbara Vogt. 18 Do you know who those individuals 19 are? 20 A. I have -- I know Barbara Vogt, but 21 the others I don't know. 22 Q. Well, do you understand that Emile 23 deNeree was acting as a broker for Mr. Kwok? 24 MR. MAJOR: Objection to form. 25 A. I don't remember. I don't remember KWOK V. GREENWICH LAND ET AL. 800.211.DEPO (3376) 38 Case 22-50073 Doc 2292-45 Filed 10/26/23 Entered 10/26/23 20:46:12 Page 40 of 96

2 Emile. I don't remember him. 3 Q.

4 says:

5 agree to these terms because Miles is ready to 6 sign the contract this afternoon as long as his 7 attorney receives the acceptable terms for due 8 diligence. 9 Do you see that? 10 A. Yes. 11 Q. And then after that it says:

12 does not want the extension.

13 just protecting him. 14 A. Yes. 15 Q. All right.

16 the first page, you were eventually copied on 17 this e-mail. 18 Do you see that? 19 A. No, I don't see. 20 Q. Go to the top. 21 A. Oh, yup. I see up top. 22 Q.

23 e-mail and you having represented Golden 24 Spring, Hudson Diamond, and Greenwich Land, can 25 you tell me what's your recollection of why you

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2 would have been copied on this e-mail? 3 MR. MAJOR: Objection to form.

5 MR. MAJOR: Calls for speculation. 6 BY MR. BASSETT: 7 Q. I'm sorry? 8 A. I didn't write this -- I don't know. 9 I don't know why I'm copied on it. 10 Q. Okay.

12 e-mail we looked at before from Mr. deNeree, to 13 the other individual who you said you 14 understood was a broker? 15 A. Mh-hm. 16 Q. Mr. deNeree is saying to Ms. Vogt: 17 Could you please ask your clients to agree to 18 these terms because Miles is ready to sign the 19 contract this afternoon as long as his attorney 20 receives acceptable terms for due diligence. 21 Do you see that? 22 A. Yes. 23 Q. Okay.

25 Ms. Vogt was representing the seller in this

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1 M. CONBOY 2 potential transaction, that Mr. deNeree was 3 acting as the broker for Mr. Kwok? 4 MR. MAJOR: Objection to form. 5 Calls for speculation. 6 A. I don't remember Frank -- or 7 whatever -- I'm sorry. Emile, I don't remember 8 him. 9 Q. Do you recall working on this 10 potential transaction? 11 A. Yes. 12 Q. And who did you represent in this 13 potential transaction? 14 A. Is this the -- are we still on the 15 Wallacks -- which transaction is this. 16 Q. Yes. I mean, if we -- we can scroll 17 through the whole thing. I believe there is 18 references to Wallacks Road? 19 A. Okay. 20 (Document review.) 21 A. Okay. So what was the question 22 again? 23 Q. I asked if you remember working on 24 this transaction? 25 A. I remember working on Wallacks Road, KWOK V. GREENWICH LAND ET AL. 800.211.DEPO (3376) 41 Case 22-50073 Doc 2292-45 Filed 10/26/23 Entered 10/26/23 20:46:12 Page 43 of 96

1 M. CONBOY 2 that -- if this is Wallacks Road, then I 3 remember working on it. 4 Q. Okay. 5 If you go back to the e-mail from 6 Mr. deNeree, if you were representing the buyer 7 in this potential transaction, then the 8 reference to the buyer's attorney would be you; 9 would it not? 10 MR. MAJOR: Objection to form. 11 A. Yes, yes. The buyer's -- 12 Q. And when it says: Miles does not 13 want the extension. His lawyer is just 14 protecting him. 15 His lawyer would be a reference to 16 you; would it not? 17 MR. MAJOR: Objection to form. 18 A. I didn't write the e-mail, so -- but 19 it sounds like it would -- I don't, you know, I 20 didn't -- I don't know what was in the -- in 21 his -- what he was thinking, but... 22 Q. Are you aware of -- are you aware of 23 Mr. Kwok having had another lawyer represent 24 him in connection with Wallacks Road? 25 A. I don't know. I don't know. KWOK V. GREENWICH LAND ET AL. 42 Case 22-50073 Doc 2292-45 Filed 10/26/23 Entered 10/26/23 20:46:12 Page 44 of 96

2 Q.

3 correct? 4 A. I'm not aware, no, no. 5 MR. BASSETT:

6 have my colleague put Tab 7 on the screen.

8 E-mail Chain Bates Labeled WBAM_003873,

10 MR. BASSETT:

11 will ask to be marked as Conboy Exhibit 7, 12 is an e-mail chain beginning with the 13 e-mail, the first page dated July 12, 2019,

15 right-hand corner WBAM_00387. 16 Do you see that? 17 A. Yes. 18 MR. THOMASON: 3873. 19 MR. BASSETT: 3873. Correct. 20 BY MR. BASSETT: 21 Q.

22 the first e-mail of the chain on 3875. 23 MR. BASSETT:

24 background noise.

25 that's coming from.

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1 M. CONBOY 2 Chris's. 3 BY MR. BASSETT: 4 Q. If you look at that e-mail, there 5 are two individuals, an e-mail from a Louise 6 Camuto to a Mary Muffin E. Dowdle. 7 Do you see that? 8 A. Yes. 9 Q. Do you understand Ms. Dowdle and 10 Ms. Camuto to be real estate brokers? 11 A. Ms. Dowdle was a real estate broker. 12 I don't know who Ms. Camuto is. So I don't 13 know about her. 14 Q. Do you understand Ms. Dowdle was a 15 broker working for Mr. Kwok? 16 A. Yes. Or -- yes. 17 Q. And this is about a property on chat 18 toe ridge property we had mentioned earlier? 19 A. Yes. 20 Q. This e-mail we are looking by 21 Ms. Camuto is actually addressed to Mr. Kwok 22 and in the first paragraph it says: Dear 23 Miles, thank you for getting back to me. I 24 look forward to concluding and having you move 25 into this amazing place which we love so much KWOK V. GREENWICH LAND ET AL. 44 Case 22-50073 Doc 2292-45 Filed 10/26/23 Entered 10/26/23 20:46:12 Page 46 of 96

1 M. CONBOY and you seem to love it as much as we do. 3 Do you see that? 4 A. Yes. 5 Q. In the second paragraph it says: You have asked that I leave the urns on stands in the living room, the great room. Knowing how much you love them and in the spirit of cooperation, I would like you to have these. And then it says: In return, if you would allow me to keep the set of blue chairs, which have always been mine so I can keep the set of four together. 14 Do you see that? 15 A. Yes. 16 Q. Okay. 17 And then in the next paragraph which I will just paraphrase it talks about she's saying to Miles that he has asked for two cabinets or armoires. And then in the paragraph after that -- in the final paragraph it talks about two men who work on the estate, mentions their salaries. And then it concludes by saying: Please let me know if you are interested in assuming these salaries to your KWOK V. GREENWICH LAND ET AL. 45 Case 22-50073 Doc 2292-45 Filed 10/26/23 Entered 10/26/23 20:46:12 Page 47 of 96

2 payroll as well. 3 Do you see that? 4 A. Yes. 5 Q.

6 e-mail above this, Max Krasner whom you said 7 was your point of contact on the engagement, 8 forwards this to a Yvette Wang and a Karin 9 Maistrello.

11 Yvette Wang writing back to the initial author 12 of the first e-mail. And it says:

13 Louise, thank you for getting back to Miles. 14 Kindly forgive him as he does better with oral 15 English than written. 16 Do you see that? 17 A. Yes. 18 Q. And then it also says:

19 he exactly shares the same love as you to this 20 fabulous home.

21 come back in the future, share the beautiful 22 stories about this place with him.

23 there are a lot. 24 Do you see that? 25 A. Yes.

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2 Q. And then it says:

3 appreciates you agree to leave the urns.

4 does love them very much.

5 of cooperation he would like you to keep the 6 set of four blue chairs, plus he even prefers 7 you to choose the cabinet which you like most. 8 Do you see that? 9 A. Yes. 10 Q.

11 with:

12 family office based in Manhattan, we take care 13 of Miles and his family's businesses, projects, 14 and assets and in the U.S.

15 directly employ/contract Peter and James with 16 the salary as you advised. 17 And then it goes on. 18 Do you see that? 19 A. Yes. 20 Q.

21 paragraph it says:

22 you again for having this beautiful home to 23 him. All the best. 24 Do you see that? 25 A. Yes.

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2 Q.

3 that, this is another e-mail back to Yvette 4 Wang. 5 MR. BASSETT:

6 scroll up. 7 BY MR. BASSETT: 8 Q.

9 Camuto to Yvette Wang, copying Max Krasner and 10 Karin Maistrello.

12 other things:

13 fabulous urns that are, as you know, quite rare 14 and valuable. They make the room. 15 Do you see that? 16 A. Yes. 17 Q.

18 says:

19 communication flowing.

20 visit him one day when he's all settled in. 21 Do you see that? 22 A. Yes. 23 Q.

24 established, contains the Bates stamp from your 25 law firm on it.

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1 M. CONBOY 2 your files, right? 3 A. Yes. 4 Q. Now, in the course of your -- of the 5 work that you perform on behalf of a buyer in a 6 real estate transaction, for what purpose would 7 you typically receive an e-mail like this that 8 contains details of what a buyer might want to 9 purchase in a home? 10 MR. MAJOR: Objection to form. 11 A. It would be -- we would have it so 12 that we could put the terms, the different 13 terms that they speak about, in the contract. 14 Q. So you would have used this 15 information to put into a contract for the 16 potential purchase by Mr. Kwok of Chateau 17 Ridge, correct? 18 A. Correct. 19 MR. MAJOR: Objection to form. 20 BY MR. BASSETT: 21 Q. Again, all of this, the work that 22 you did with respect to the Chateau Ridge 23 property, like all of the work we've been 24 discussing, this was done under the sort of 25 umbrella of the Greenwich Land, Golden Spring, KWOK V. GREENWICH LAND ET AL. 49

2 and Hudson Diamond engagement that we talked 3 about? 4 A. Yes. 5 MR. MAJOR: Objection to form. 6 MR. BASSETT:

7 my colleague, please, put up the e-mail 8 that's -- sorry -- the document that's 9 Tab 8.

11 2020, E-mail Bates Stamped WBAM_0038336,

13 MR. BASSETT:

14 document marked as Conboy Exhibit 8. 15 BY MR. BASSETT: 16 Q.

17 e-mail chain, top e-mail in the chain, dated 18 December 15, 2020, Bates stamped at the lower

20 WBAM_0038336.

22 at this as necessary, but do you -- as you can 23 see, you're copied on the first e-mail in this 24 chain as well as the second e-mail and, I 25 think, others, if you scroll down.

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3 properties this was in reference to?

4 subject line is:

5 Diamond New York LLC? 6 A. I don't know which property that is. 7 MR. BASSETT:

8 please. Next page, please. Okay. 9 BY MR. BASSETT: 10 Q.

11 appear to list the name of the property, but 12 this is an e-mail exchange between you and Max 13 Krasner, at least, at the top; is that correct, 14 Ms. Conboy? 15 A. Yes. 16 Q.

17 your recollection, would this be one of the 18 properties that we mentioned on which you 19 provided advice under the Greenwich Land, 20 Golden Spring, and Hudson Diamond engagement 21 using Max Krasner as your point of contact? 22 MR. MAJOR: Objection to form. 23 A. It's from Max to me.

24 telling us to hold off the -- it had to be 25 workup of properties.

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2 Q.

3 is:

4 the team he will not move forward on this 5 property. 6 Do you see that? 7 A. Yes. 8 Q.

9 reference to Miles Kwok? 10 A. Yes. 11 MR. MAJOR: Objection to form. 12 BY MR. BASSETT: 13 Q.

14 that would also be a reference to Miles Kwok? 15 MR. MAJOR: Objection to form. 16 A.

17 Max Krasner wrote, so. 18 Q. Okay.

20 quite a few e-mails today, five or six or so.

22 e-mails in your February deposition? 23 A. Yes.

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24 MR. BASSETT:

25 colleague to, please, put our Tab 10, which

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2 is going to be Exhibit 9 into the chat.

6 MR. BASSETT:

7 smaller.

9 direct ourselves to particular lines. 10 That's good. Maybe one out. 19 BY MR. BASSETT: 20 Q.

21 document? 22 A. Yes. 23 Q. Okay. 24 A. Yes. 25 Q.

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2 A.

16 MR. THOMASON:

17 in hard copy. Can I show it to her? 18 A. Yes. 19 MR. BASSETT: Yeah, of course.

21 MR. BASSETT:

2 Do you see that. 3 A. Yup, okay so -- yeah. 4 Q.

9 Do you see that? 10 A. Yes. 11 Q.

15 A. Yup. 16 Q.

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2 A. Mm-hm. 3 Q.

6 A. Yes. 7 MR. MAJOR: Objection to form. 8 BY MR. BASSETT: 9 Q. Okay.

11 page of this document.

13 we just looked at, does that refresh your 14 recollection that the initial purchase of the 15 33 Ferncliff Road property was in August of 16 2019? 17 A. Yes. 18 MR. MAJOR: Objection to form. 19 A.

20 see the dates.

22 A. No.

23 August 19th. Oh, August 2019, yes. 24 Q. Thank you. Case 22-50073 Doc 2292-45 Filed 10/26/23 Entered 10/26/23 20:46:12 Page 65 of 96

11 Do you see that? 12 A. Where is that? Oh, I see, yup. 13 Okay. 14 Q. Okay. 18 A. Yup. 19 Q. 21 Do you see that? 22 A. Yes. 23 Q.

7 Q. Okay. 12 A. Yes. 13 Q.

20 A. Yes.

22 Q. All right.

5 Do you see that? 6 A. Yes. 7 Q.

17 Do you see that?

19 A. Yes. Q.

21 A. I have no idea. 22 Q.

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2 Q. Okay. 9 MR. MAJOR: Objection to form. 10 BY MR. BASSETT: 11 Q. I didn't hear your answer.

12 sorry. 13 A. I don't know. 14 Q. How about did the debtor's son, to 15 your knowledge, have any involvement with that 16 transaction? 17 MR. MAJOR: Objection to form. 18 A. I don't -- I don't know.

20 your point of contact, right? 21 A. Correct. 22 Q. Did Mr. Krasner ever tell you that 23 he needed to get approval from Mr. Kwok's wife 24 prior to making any decisions with respect to 25 properties?

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2 MR. MAJOR: Objection to form.

3 instruct the witness not to answer on the 4 grounds of privilege, to the extent it 5 concerned an instruction during the time 6 that the witness was representing Greenwich 7 Land LLC. 8 MR. BASSETT:

10 privilege.

11 privilege.

13 not -- on its face, not calling for any 14 attorney-client privileged communications. 15 It's a yes-or-no question. 16 MR. MAJOR:

17 officer of Greenwich Land LLC.

18 asked a question about a conversation he 19 had with a lawyer representing Greenwich 20 Land LLC.

21 and we're instructing the witness not to 22 answer on those grounds.

23 waiver is wrong. 24 We have never waived the privilege. 25 In fact, we've asserted the privilege.

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2 were not at the prior deposition.

3 not given notice or an invitation to the 4 prior deposition.

6 authorized the Whitman Breed firm to waive 7 the privilege.

8 privilege.

9 privilege.

10 privilege as the questioning lawyer.

11 it doesn't matter if there was a prior

13 knowledge and consent of the client. 14 MR. BASSETT: All right.

15 with everything you just said.

16 had months of opportunity to raise any 17 issue with respect to the allegations in 18 our complaint which referred to Ms. 19 Conboy's testimony, and with respect to the 20 testimony itself.

22 that I am asking about her conversations 23 with an officer of the company does not 24 render the answer at all privileged.

25 not asking for her to reveal any advice

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2 that she gave or any advice that was sought 3 from her.

5 requires for a communication to be cloaked 6 in the attorney-client privilege.

8 can have the court reporter read back, 9 absolutely did not call for her to divulge 10 any privileged communication. 11 BY MR. BASSETT: 12 Q.

13 not asking for advice you gave to Mr. Krasner 14 or for anything Mr. Krasner asked you in terms 15 of legal advice.

16 Mr. Krasner told you, from a business 17 perspective, that he needed to get approval 18 from Mr. Kwok's wife prior to making decisions 19 with respect to properties? 20 MR. MAJOR: Objection to form.

21 again, instruct the witness not to answer.

23 MR. BASSETT:

24 privileged? 25 MR. MAJOR:

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1 M. CONBOY 2 about the -- 3 MR. BASSETT: Where's the request 4 for legal advice, Chris? 5 MR. MAJOR: Let's have the question 6 read back, please, or if you want to re-ask 7 it, whatever is faster. 8 BY MR. BASSETT: 9 Q. Did Mr. Krasner ever tell you, from 10 a business perspective, that he needed to get 11 approval from Mr. Kwok's wife prior to making 12 any decisions with respect to properties? 13 MR. MAJOR: Let me just have a quick 14 minute to think this over. I'll be back in 15 a minute. Hold on. 16 MR. BASSETT: Okay. 17 MR. THOMASON: We're going to take a 18 break. That okay, Nick? 19 MR. BASSETT: Sure. 20 (Recess is taken.) 21 MR. MAJOR: Thank you very much 22 everyone for allowing that break. I want 23 to make sure we're being as judicious as 24 possible with this today, so that's why I 25 wanted to just take a minute to consider it KWOK V. GREENWICH LAND ET AL. 71 Case 22-50073 Doc 2292-45 Filed 10/26/23 Entered 10/26/23 20:46:12 Page 73 of 96 MARGARET CONBOY· Confidential September 12, 2023

1 M. CONBOY and confer with a colleague. 3 And I do think that the question calls for privileged communication. I think the privilege is broader than Mr. Bassett has outlined. It's for communications between lawyer and client relating to the provision of legal advice or the provision of legal services. 10 I think in the context of a real estate transaction, the role that Ms. Conboy played is uniquely legal in nature. The, you know, strictly business discussions, those are happening with the broker. A real estate lawyer involved in a closing on a residential loan like this -- residential sale like this is brought in at the time that legal services are needed, for example, preparation or a contract and so forth. 21 And so I think that the conversations that Ms. Conboy had with the -- an officer of Greenwich Land LLC is privileged, and therefore we're going to assert the privilege to this question. KWOK V. GREENWICH LAND ET AL. 72

> 800.211.DEPO (3376) EsquireSolutions.com

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2 MR. BASSETT:

3 Chris.

5 application of it.

6 asked was simply a question about who at 7 the client would approve transactions or 8 decisions in connection with transactions. 9 That is not privileged.

12 Ms. Conboy about her communications with

14 communications.

16 Mr. Krasner was telling her that Mr. Kwok 17 was deciding not to purchase a property, 18 for example.

20 what I'm now asking.

21 there's already testimony in the record 22 about Mr. Kwok making decisions on behalf 23 of the client.

24 ever was told that, instead of Mr. Kwok, 25 his wife needed to make decisions.

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2 that's fair game.

3 been opened.

4 had has been waived throughout the day 5 today.

7 objection, we'll reserve our rights, take 8 it up with the Court, if necessary. 9 MR. MAJOR:

10 the objection.

11 know, it's a disingenuous argument to try

13 MR. BASSETT:

14 phone on mute. Sorry. 15 MR. MAJOR:

16 waiver today at the deposition because we 17 didn't object to you asking questions about 18 Mr. Kwok. We do not represent Mr. Kwok. 19 Greenwich Land did not own or transact for

21 questions about.

22 about a property that Greenwich Land LLC 23 was the owner of.

24 know, is an officer of Greenwich Land, and 25 he was having communications with Greenwich

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KWOK V. GREENWICH LAND ET AL.

2 Land's lawyer about a transaction involving 3 a property owned by Greenwich Land, and 4 that's why we appropriately objected. 5 MR. BASSETT: All right.

6 asking about any particular transaction, to 7 be clear. The question was:

8 of the engagement did Mr. Krasner ever tell 9 you, from a business perspective, he needed 10 to get approval from Mr. Kwok's wife prior 11 to making any decisions with respect to 12 properties?

13 particular transaction or property. 14 MR. MAJOR:

15 witness and her firm are comfortable that 16 they can delineate the representations, and

18 nonGreenwich Land LLC representation, then 19 I don't think we would have an objection. 20 Because we only represent Greenwich Land 21 and Ms. Guo, who is named in the complaint 22 as Hing Chi Ngok, and I don't represent 23 anybody else.

24 privilege on behalf of those two.

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3 entities together, I've been objecting to

5 improper.

6 sound like, you know, Greenwich Land was no 7 different than the other entities in your 8 questions.

10 know, was previously deposed without our 11 involvement, I don't know if the witness is

13 representations that you've been grouping 14 together -- together.

15 they are grouped together at all, but 16 that's the way you've decided to ask your 17 questions.

18 thornier when you go to ask a general 19 question like this, which is why we're also 20 objecting to the form of the question.

22 purposes of the record so we can deal with, 23 you know, what will be confusing testimony 24 later on.

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2 communications that Ms. Conboy had with an

4 execution of a real estate transaction 5 concerning property owned by Greenwich

7 objection. 8 BY MR. BASSETT: 9 Q.

10 that you represented Greenwich Land, Golden 11 Spring, and Hudson Diamond New York as part of 12 the same engagement. 13 Do you recall that? 14 MR. MAJOR: Objection to form. 15 A.

16 please. 17 MR. BASSETT:

18 reporter read it back, please? 19 (Question was read back as follows: 20 "QUESTION:

21 testified before that you represented 22 Greenwich Land, Golden Spring, and Hudson

24 engagement.

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2 A. Yes. 3 Q.

4 with Mr. Krasner, were you ever delineating 5 between Greenwich Land, Golden Spring, and

7 communications? 8 MR. MAJOR: Objection to form.

9 I just caution the witness that she not

11 communications relating to Greenwich Land, 12 but I think the question can be answered 13 without stepping over that line. 14 MR. THOMASON:

15 yes-or-no question, correct? 16 MR. BASSETT: It is a yes-or-no. 17 MR. THOMASON:

18 that to -- either in the affirmative or the

20 information; is that right, Chris? 21 MR. MAJOR: Yes, that was my point. 22 MR. THOMASON:

23 that question in the affirmative or the 24 negative, you can do that.

25 you require -- it feels, you know, more -- Case 22-50073 Doc 2292-45 Filed 10/26/23 Entered 10/26/23 20:46:12 Page 80 of 96

1 M. CONBOY 2 THE WITNESS: Then -- okay. 3 A. So the question is if I delineated 4 between -- 5 MR. THOMASON: The different 6 entities. 7 A. -- the different entities. And 8 I'm -- I don't -- I'm not understanding what 9 that even means, if I delineated between the 10 different entities. I don't understand the 11 question. 12 Q. Well, when you took intersection 13 from Mr. Krasner and you had conversations with 14 Mr. Krasner, were you ever -- were you always 15 communicating with him as a representative on 16 behalf of all three entities or were you at 17 times drawing distinctions between which entity 18 he was communicating on behalf of? 19 MR. MAJOR: Objection to form. 20 A. I'll -- yes, all three entities. 21 Yes. 22 Q. So when you had communications with 23 him he was, in your mind, communicating on 24 behalf of all three entities? 25 A. Yes. KWOK V. GREENWICH LAND ET AL. 79 Case 22-50073 Doc 2292-45 Filed 10/26/23 Entered 10/26/23 20:46:12 Page 81 of 96

2 MR. MAJOR: Objection to form.

3 also I'd caution the witness not to reveal 4 attorney-client privileged communications. 5 MR. BASSETT: All right.

6 think there's any confusion at this point. 7 BY MR. BASSETT:

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24 MR. THOMASON:

25 witness?

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2 MR. MAJOR:

3 questions for the witness. 4 MR. THOMASON: That's fine.

6 MR. MAJOR: 7 Q. Good morning, Ms. Conboy.

8 is Chris Major.

9 on. We're representing Greenwich Land LLC and 10 Ms. Guo, who is named in the complaint in this 11 adversary proceeding as a Hing Chi Ngok.

13 the complaint in this adversary proceeding? 14 A. No. 15 Q.

16 were contacted by the Chapter 11 trustee in 17 this in re Kwok bankruptcy matter? 18 A.

19 least six months ago. Maybe more. 20 Q.

21 Chapter 11 trustee in this bankruptcy case? 22 A. I don't remember. 23 Q.

24 behalf of the trustee? 25 A. Well, first a client called me.

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2 then the -- I guess it was the trustee himself, 3 the partner. 4 Q. Was it Luc Despins? 5 A. Yes. 6 Q. And he contacted you by phone? 7 A.

8 then -- I did talk to him by phone. 9 Q.

10 when you spoke with Mr. Despins by phone? 11 A. I don't remember. 12 Q.

13 during that phone call? 14 A.

15 about sending the binder for -- for 373 16 Taconic.

17 Taconic -- and I represented the seller, so we 18 had to get waivers and that was the initial 19 discussion. 20 Q. Okay.

22 Taconic to Mr. Despins? 23 A.

24 client, who was the seller, was friends with 25 the attorney, the trustee.

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2 the documents. I didn't send them. 3 Q.

4 client on that transaction? 5 A. Augustine, Mr. Augustine. 6 Q.

7 Mr. Despins or any of his colleagues at Paul 8 Hastings? 9 A. I don't remember. I don't know. 10 Then our litigators took over.

11 Michael, they took over.

12 after that -- after Mr. Augustine sending the 13 documents, then I had no other contact with 14 them. 15 Q. Okay.

17 conversations with Mr. Despins after that 18 initial phone call? 19 A. I don't remember. 20 Q.

21 you received from Mr. Despins? 22 A. I don't know. 23 Q.

24 communications with Mr. Despins after the 25 initial phone call that you had? Case 22-50073 Doc 2292-45 Filed 10/26/23 Entered 10/26/23 20:46:12 Page 86 of 96

2 A. I don't remember. 3 Q.

4 other lawyers at Paul Hastings in connection 5 with this bankruptcy, other than Mr. Despins? 6 A. I don't remember. 7 Q.

8 Mr. Bassett before today? 9 A. No. 10 Q.

11 under Rule 2004, which has been -- some of the 12 pages have been shown today, have you had any 13 conversations with Avi Luft of Paul Hastings? 14 A. No, not since that deposition.

15 only had the deposition. 16 Q.

17 phone call when he asked for the closing file? 18 MR. BASSETT: Objection to form. 19 A.

20 and see if he was agreeable, if -- I would have 21 to get his consent. 22 Q.

23 property, do you know whether your firm 24 provided any documents relating to that 25 property to the trustee or any of the lawyers

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2 representing the trustee at -- whether it would 3 be at his law firm or a law firm in Connecticut 4 called Neubert, Pepe & Monteith? 5 A. I don't know. 6 Q. Did you -- withdrawn.

8 who Mr. Bassett was referring to as Mr. Kwok? 9 A. No. 10 Q. Have you ever met him? 11 A. No. 12 Q.

13 Road property transaction, did you do any 14 diligence as to the source of funds that were 15 used to purchase in that instance your client's 16 former -- now former home at 373 Taconic Road? 17 A. No. 18 MR. BASSETT: Objection. 19 BY MR. MAJOR: 20 Q.

21 Greenwich Land LLC is, or members? 22 A. No. 23 Q.

24 were used to purchase your client's now former 25 home at 373 Taconic Road? Case 22-50073 Doc 2292-45 Filed 10/26/23 Entered 10/26/23 20:46:12 Page 88 of 96

2 MR. BASSETT: Object to form. 3 A. No. 4 Q.

5 at 373 Taconic Road in Greenwich, Connecticut? 6 A. No. 7 Q.

8 Taconic Road in Greenwich, Connecticut, where 9 you represented the seller.

11 deliberations by the purchaser about acquiring 12 that property? 13 MR. BASSETT: Objection to form. 14 A. No. 15 Q.

16 of the property at 373 Taconic Road? 17 A. I don't remember. I don't remember. 18 Q. Do you remember the purchase price? 19 A. I don't remember. 20 Q.

21 friends with Mr. Despins. 22 How did you learn that? 23 A.

24 client e-mailed me and said that he had -- 25 Mr. Despins had called my client, and my client

Case 22-50073 Doc 2292-45 Filed 10/26/23 Entered 10/26/23 20:46:12 Page 89 of 96

1 M. CONBOY 2 said they were good friends. 3 MR. MAJOR: Why don't we go off the 4 record for a couple minutes. I just want 5 to confer with a colleague and check some 6 notes and then hopefully we can come back, 7 and I'll have a few more questions and then 8 I'll wrap up. 9 MR. BASSETT: Okay. 10 (Recess is taken.) 11 MR. MAJOR: Thank you, Ms. Conboy, 12 and Counsel for giving me a few minutes. I 13 just have a very few questions left. 14 BY MR. MAJOR: 15 Q. Mr. Bassett and his colleague 16 post -- published over this Zoom an e-mail 17 which referred to a Chinese billionaire. 18 Did you ever meet or speak with the 19 Chinese billionaire? 20 A. No. 21 Q. Did that Chinese billionaire ever 22 sign an engagement letter with your firm? 23 A. No. 24 Q. Did Mr. Kwok ever sign an engagement 25 letter with your firm? KWOK V. GREENWICH LAND ET AL. 88 Case 22-50073 Doc 2292-45 Filed 10/26/23 Entered 10/26/23 20:46:12 Page 90 of 96 MARGARET CONBOY· Confidential September 12, 2023

1 M. CONBOY 2 MR. BASSETT: Objection. Form. 3 A. The entities -- I have my engagement 4 letters are with the entities. 5 Q. My question is just whether Mr. Kwok 6 was ever a signatory on an engagement letter 7 with your firm? 8 A. No. 9 MR. MAJOR: We have no further 10 questions at this time. 11 MR. BASSETT: And I have no 12 follow-up. 13 THE COURT REPORTER: Anything else? 14 MR. THOMASON: No. 15 THE COURT REPORTER: Thank you. 16 Chris, do you need a rough draft of 17 the transcript and/or a copy? 18 MR. MAJOR: I'd like a copy, but we 19 don't need a rough draft. And if we could 20 have a mini as well. 21 MR. THOMASON: Are you going to have 22 her read and sign? I was thinking. Do you 23 feel like you need the opportunity to 24 review the transcript to check for 25 everything or do you feel confident? KWOK V. GREENWICH LAND ET AL. 89

> 800.211.DEPO (3376) EsquireSolutions.com

Case 22-50073 Doc 2292-45 Filed 10/26/23 Entered 10/26/23 20:46:12 Page 91 of 96 MARGARET CONBOY· Confidential September 12, 2023

2 THE WITNESS: No. 3 MR. THOMASON:

4 appreciate a courtesy copy that I don't 5 have to pay for.

6 then, you know, I don't need a copy. 7 MR. BASSETT:

8 just trying to think of -- what's standard 9 delivery, again? 10 THE COURT REPORTER:

11 business days, but if you need it sooner, 12 I'm happy to do that for you.

13 never said if you wanted a rough draft or 14 not. 15 MR. BASSETT:

16 it.

17 me that I made the wrong decision, I will 18 e-mail you.

Case 22-50073 Doc 2292-45 Filed 10/26/23 Entered 10/26/23 20:46:12 Page 92 of 96

2 THE COURT REPORTER: Okay.

3 you. 4 MR. BASSETT:

5 Ms. Conboy. I appreciate it. 6 THE WITNESS: Thank you. 7 (Time Noted:

2023.

16 ---------------------------------------

Case 22-50073 Doc 2292-45 Filed 10/26/23 Entered 10/26/23 20:46:12 Page 93 of 96

MARGARET CONBOY· Confidential KWOK V. GREENWICH LAND ET AL.

4 ) ss.:

10 certify:

12 whose deposition is hereinbefore set forth,

15 testimony given by such witness.

17 related to any of the parties to this 18 action by blood or marriage; and that I am 19 in no way interested in the outcome of this 20 matter.

22 set my hand this 13th day of September, 23 2023.

Case 22-50073 Doc 2292-45 Filed 10/26/23 Entered 10/26/23 20:46:12 Page 94 of 96

11 Conboy Exhibit 1, Conboy Deposition 15

19 Conboy Exhibit 4, October 3rd, 2019, 32

24 Conboy Exhibit 6, January 6, 2019, 38

Case 22-50073 Doc 2292-45 Filed 10/26/23 Entered 10/26/23 20:46:12 Page 95 of 96 MARGARET CONBOY· Confidential September 12, 2023

KWOK V. GREENWICH LAND ET AL.

1 2 I N D E X O F E X H I B I T S(Cont'd.) 3 DESCRIPTION PAGE 4 Conboy Exhibit 7, July 12, 2019, E-mail 43 Chain Bates Labeled WBAM\_003873 5 6 Conboy Exhibit 8, December 15, 2020, 50 7 E-mail Bates Stamped WBAM\_0038336 8 9 Conboy Exhibit 9, Whitman Breed Trustee 57 Ledger, Bates Labeled WBAM\_00002 10 11 12 QUESTIONS INSTRUCTED NOT TO ANSWER 13 Page Line 14 68 2 68 21 15 70 20 80 25 16 17 18 19 20 21 22 23 24 25 800.211.DEPO (3376)

Case 22-50073 Doc 2292-45 Filed 10/26/23 Entered 10/26/23 20:46:12 Page 96 of 96

MARGARET CONBOY· Confidential KWOK V. GREENWICH LAND ET AL.

ERRATA SHEET FOR THE TRANSCRIPT OF:

Case Name: KWOK v GREENWICH LAND, et al.

CORRECTIONS: Pg. Ln.

THIS____DAY OF____________, 2023.