--- type: court_doc id: "court_ctb_2292_45" court: "CTB" case_no: "22-50073" doc_number: 2292 doc_type: "EXHIBIT" filed_date: "2023-10-26" lang: "en" machine_translated: false url: "https://mubeitech.com/en/court/court_ctb_2292_45" json_url: "https://mubeitech.com/api/court/court_ctb_2292_45" --- # Guo Wengui / Miles Guo — bankruptcy case · EXHIBIT · ECF #2292-45 Exhibit 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) EsquireSolutions.com September 12, 2023 800.211.DEPO (3376) EsquireSolutions.com MARGARET CONBOY· Confidential 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 September 12, 2023 800.211.DEPO (3376) EsquireSolutions.com MARGARET CONBOY· Confidential 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 September 12, 2023 YVer1f MARGARET CONBOY· Confidential KWOK V. GREENWICH LAND ET AL. 2　IT IS HEREBY STIPULATED AND AGREED 3　by and between the attorneys for the 4　respective parties herein, that filing and 5　sealing be and the same are hereby waived. 6　IT IS FURTHER STIPULATED AND AGREED 7　that all objections, except as to the form 8　of the question, shall be reserved to the 9　time of the trial. 10　IT IS FURTHER STIPULATED AND AGREED 11　that the within deposition may be sworn to 12　and signed before any officer authorized 13　to administer an oath, with the same 14　force and effect as if signed and sworn 15　to before the Court. 20　- oOo - September 12, 2023 10:05 10:05 10:05 10:06 YVer1f 800.211.DEPO (3376) EsquireSolutions.com MARGARET CONBOY· Confidential 1　M. CONBOY 2　M A R G A R E T C O N B O Y, called as a 3　witness, having been duly sworn by a Notary 4　Public, was examined and testified as follows: 5　EXAMINATION BY 6　MR. BASSETT: 7　Q. Thank you very much. 8　MR. MAJOR: Nick, just before we get 9　started, can we agree that we will do the 10　usual stipulations, including that 11　objections, except as to the form of the 12　question, are reserved. 13　MR. THOMASON: That's the 14　Connecticut usual stipulations. 15　MR. BASSETT: I'm not agreeing to 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. So, you know, I'll 24　just object if I have any objections to the 25　form of the question, and leave it at that. Case 22-50073 Doc 2292-45 Filed 10/26/23 Entered 10/26/23 20:46:12 Page 8 of 96 MARGARET CONBOY· Confidential September 12, 2023 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 > 800.211.DEPO (3376) EsquireSolutions.com 10:06 10:06 10:06 10:06 10:07 YVer1f Case 22-50073 Doc 2292-45 Filed 10/26/23 Entered 10/26/23 20:46:12 Page 9 of 96 MARGARET CONBOY· Confidential September 12, 2023 KWOK V. GREENWICH LAND ET AL. 1　M. CONBOY 2　and therefore communications that the 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. Those were not 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: Well, Chris you've 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 > 800.211.DEPO (3376) EsquireSolutions.com 10:07 10:07 10:07 10:08 10:08 YVer1f Case 22-50073 Doc 2292-45 Filed 10/26/23 Entered 10/26/23 20:46:12 Page 10 of 96 September 12, 2023 10:08 10:08 10:08 10:09 10:09 YVer1f 800.211.DEPO (3376) EsquireSolutions.com MARGARET CONBOY· Confidential 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. 1　M. CONBOY 2　waived any argument that information 3　contained in our complaint and attached in 4　the deposition transcript filed publicly is 5　privileged information. If you felt that 6　way, you should have said something months 7　ago. So I'm not going to -- I'm not even 8　going to entertain that argument. But why 9　don't we -- why don't we start and we will 10　see where we go. If we get to a point 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. It's not an 16　argument for you to entertain. It's 17　Greenwich Land owns the privilege. 18　MR. BASSETT: And you've waived it, 19　Chris. 20　MR. MAJOR: No. No. We have not 21　participated in that. 22　MR. BASSETT: All right. Let's 23　just -- all right, let's -- let's just go 24　and see how it goes. 25　MR. MAJOR: And I don't know what 800.211.DEPO (3376) EsquireSolutions.com 10:09 10:09 10:09 10:10 10:10 YVer1f Case 22-50073 Doc 2292-45 Filed 10/26/23 Entered 10/26/23 20:46:12 Page 12 of 96 September 12, 2023 10:10 10:10 10:10 10:11 10:11 YVer1f 800.211.DEPO (3376) EsquireSolutions.com MARGARET CONBOY· Confidential 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 September 12, 2023 10:11 10:11 10:11 10:11 10:11 YVer1f EsquireSolutions.com MARGARET CONBOY· Confidential 1　M. CONBOY 2　outset is that I know you do have other 3　obligations this afternoon. We committed to 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. 16　Ms. Conboy, where are you located at 17　the moment? Is that your law office in the 18　Connecticut? 19　A. Yes, Greenwich, Connecticut. 20　Q. And that's your counsel, a colleague 21　of yours at the firm who's with you, 22　Mr. Thomason? 23　A. Yes. 24　Q. Okay. 25　Ms. Conboy, without revealing the Case 22-50073 Doc 2292-45 Filed 10/26/23 Entered 10/26/23 20:46:12 Page 14 of 96 September 12, 2023 10:12 10:12 10:12 10:12 10:12 YVer1f EsquireSolutions.com MARGARET CONBOY· Confidential M. CONBOY substance of any communications with your counsel, can you just describe for me what you did to prepare for today's deposition? A. I just reviewed the -- my prior transcript and that affidavit, and that was it. Q. When you say "that affidavit" what are you referring to? A. The affidavit that was -- the 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. And you are employed at Whitman Breed Abbott & Morgan LLC, that's the full name? A. Yes. Q. What is your title? A. I'm a real estate attorney. I'm a partner -- Q. Okay. Case 22-50073 Doc 2292-45 Filed 10/26/23 Entered 10/26/23 20:46:12 Page 15 of 96 September 12, 2023 10:13 10:13 10:13 10:13 10:13 YVer1f MARGARET CONBOY· Confidential M. CONBOY 2　A.　-- at the firm. 3　Q.　And you said you practice real 4　estate law. 5　Is that a accurate description? 6　A.　Yes. 7　Q.　How long have you been practicing 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? 15　A.　I don't know, 15, 20 years, 16　somewhere around there. 17　Q.　Okay. 18　So you already mentioned it, but you 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: I think that's our Case 22-50073 Doc 2292-45 Filed 10/26/23 Entered 10/26/23 20:46:12 Page 16 of 96 September 12, 2023 10:14 10:14 10:14 10:14 10:14 YVer1f 800.211.DEPO (3376) EsquireSolutions.com MARGARET CONBOY· Confidential 1　M. CONBOY 2　Tab 1, Ezra. 3　MR. SUTTON: I just shared it in the 4　chat. I'll share my screen shortly. 5　MR. BASSETT: I would like the court 6　reporter to please mark this as Conboy 7　Exhibit 1. 8　(Conboy Exhibit 1, Conboy Deposition 9　Transcript from February 21, 2023, marked 10　for identification.) 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. And then we also put it in the chat, 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. Once you're comfortable, my question 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. Case 22-50073 Doc 2292-45 Filed 10/26/23 Entered 10/26/23 20:46:12 Page 17 of 96 September 12, 2023 10:14 10:15 10:15 10:15 10:15 YVer1f 800.211.DEPO (3376) EsquireSolutions.com MARGARET CONBOY· Confidential 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 September 12, 2023 10:15 10:15 10:16 10:16 10:16 YVer1f EsquireSolutions.com MARGARET CONBOY· Confidential KWOK V. GREENWICH LAND ET AL. 1　M. CONBOY 2　Q. Okay. 3　But you don't have any reason to 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? I didn't -- 11　Q. Do you have any reason to believe 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. 20　So if I refer to -- I'll try to use 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: I would like the first Case 22-50073 Doc 2292-45 Filed 10/26/23 Entered 10/26/23 20:46:12 Page 19 of 96 September 12, 2023 10:16 10:16 10:17 10:17 10:17 YVer1f EsquireSolutions.com MARGARET CONBOY· Confidential 1　M. CONBOY 2　exhibit to be marked highly confidential. 3　Contrary to counsel's statement it was not 4　publicly filed. It was filed under seal, 5　and we maintain that it contains 6　disclosures of privileged information. I 7　would like it marked highly confidential. 8　MR. BASSETT: Okay. I thought it 9　was publicly available, but I will have to 10　confirm. If you are telling me it wasn't, 11　then I'll check that. 12　BY MR. BASSETT: 13　Q. Ms. Conboy, are you familiar with an 14　entity called Greenwich Land LLC? 15　A. Yes. 16　Q. Is this entity -- was this entity a 17　client of Whitman Breed's? 18　A. Yes. 19　Q. Were you involved in that 20　representation? 21　A. Yes. 22　Q. What was your role? 23　A. I was the real estate attorney for 24　that LLC. 25　Q. Okay. Case 22-50073 Doc 2292-45 Filed 10/26/23 Entered 10/26/23 20:46:12 Page 20 of 96 1　M. CONBOY 2　All right. Case 22-50073　Doc 2292-45　Filed 10/26/23　Entered 10/26/23 20:46:12　Page 21 of 96 Q. And did you also represent an entity called Hudson Diamond New York LLC? When I say you, I mean your law firm. A. Yes. MR. MAJOR: Objection to form. BY MR. BASSETT: 25　Q. I would like my colleague to put Case 22-50073 Doc 2292-45 Filed 10/26/23 Entered 10/26/23 20:46:12 Page 22 of 96 1　M. CONBOY 2　Tab 2 on the screen, please. 3　(Conboy Exhibit 2, marked for 5　identification.) 6　MR. BASSETT: And I would like the 7　court reporter to please mark this document 8　as Exhibit 2, Conboy Exhibit 2. 9　BY MR. BASSETT: 10　Q. Ms. Conboy, do you recognize this 11　document? 12　A. 14　Q. Okay. 18　A. Yes. 19　Q. Okay. 25　Do you see that? Case 22-50073 Doc 2292-45 Filed 10/26/23 Entered 10/26/23 20:46:12 Page 23 of 96 1　M. CONBOY 2　A. Mh-hm. 3　Q. 7　A. Yes. Yes. 8　Q. Okay. 13　A. Yes. 14　Q. Who was your main point of contact 15　on the client's side for your firm's 16　representation of these entities? 17　A. It was Max Krasner. 18　Q. Okay. 19　In the course of this -- of these 20　engagements of these entities, did you ever 21　speak at any time to Mr. Kwok's wife? 22　A. No. 23　Q. At the time of your earlier 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 1　M. CONBOY 2　A. No. 3　Q. Have you ever spoken to Mr. Kwok's 4　son? 5　A. No. 6　Q. Have you ever spoken to Mr. Kwok's 7　daughter? 8　A. No. 9　Q. Ms. Conboy, did you represent 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: I would like my 16　colleague to put Tab 3 to the chat, please. 17　(Conboy Exhibit 3, 19　WBAM_000035, marked for identification.) 20　MR. BASSETT: I would like the court 21　reporter to please mark this as Conboy 22　Exhibit 3. 23　BY MR. BASSETT: 24　Q. Ms. Conboy, do you recognize this 25　document? Case 22-50073 Doc 2292-45 Filed 10/26/23 Entered 10/26/23 20:46:12 Page 25 of 96 1　M. CONBOY 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, 7　And at the bottom right-hand corner, 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. Case 22-50073 Doc 2292-45 Filed 10/26/23 Entered 10/26/23 20:46:12 Page 26 of 96 1　M. CONBOY 4　A. Yes, I did. 5　Q. Okay. 6　And do you recall approximately the 7　date of the -- of the initial purchase of the 8　property and then -- well, I'll start with 9　that. 10　Do you recall the date of the 11　initial purchase of the property, 12　approximately? 13　A. I don't remember. Maybe 2020, 14　somewhere around there. I don't remember the 15　dates. 16　Q. Okay. 17　We can look at documents later. 18　And do you recall, off the top of 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. We can look at 24　documents there as well. 25　So other than -- setting the Case 22-50073 Doc 2292-45 Filed 10/26/23 Entered 10/26/23 20:46:12 Page 27 of 96 September 12, 2023 10:25 10:25 10:25 10:25 10:26 YVer1f EsquireSolutions.com MARGARET CONBOY· Confidential 1　M. CONBOY 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. Do you recall which properties there 12　were that you looked at on their behalf? 13　A. There was -- 14　MR. MAJOR: Objection. Form. 15　A. There was a Clapboard Ridge. There 16　was one in Stamford, Chateau Ridge I believe in 17　Greenwich. Those are pretty much about three 18　or four -- maybe four that we did. 19　Q. Okay. 20　So -- that's fine. 110 Clapboard 21　Ridge Road, does that sound right as one of the 22　properties? 23　A. Yes. 24　Q. And then how about 32 Chateau Ridge 25　Road in Greenwich? Case 22-50073 Doc 2292-45 Filed 10/26/23 Entered 10/26/23 20:46:12 Page 28 of 96 1　M. CONBOY 2　A. Yes. 3　Q. On that one, if you could please 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: I just want to note for 8　the record that, as we've insisted, that 9　the Exhibit 1 be marked highly 10　confidential. Any portions of the 11　transcript referring to that document 12　should also be marked highly confidential. 13　MR. BASSETT: Okay. Well, 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. Case 22-50073 Doc 2292-45 Filed 10/26/23 Entered 10/26/23 20:46:12 Page 29 of 96 Q. Do you recall 140 Wallacks Drive in Stamford as another property about which there was -- there were discussions of a potential purchase? A. Yes. Q. How about 66 Sherwood Road in Greenwich? Case 22-50073 Doc 2292-45 Filed 10/26/23 Entered 10/26/23 20:46:12 Page 30 of 96 1　M. CONBOY A. Yes. Q. Thank you. Back to other properties. Do you 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 1　M. CONBOY 2　discussing as 11 Hurlingham Drive in Greenwich? 3　A. I don't really remember as much. I 4　don't remember it. 5　Q. Okay. 6　I think we might see a document 7　later that references that property. 8　How about 602 Indian Field Road in 9　Greenwich? 10　A. Yes. 11　Q. So do you -- we talked about 12　properties with respect to which you provided 13　advice under the engagement that we've been 14　talking about. 15　Do you also recall a transaction 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. What was your involvement in that 21　transaction? 22　A. I was representing the seller. 23　Q. Okay. Case 22-50073 Doc 2292-45 Filed 10/26/23 Entered 10/26/23 20:46:12 Page 32 of 96 & ESQUIRE Case 22-50073 Doc 2292-45 Filed 10/26/23 Entered 10/26/23 20:46:12 Page 33 of 96 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 September 12, 2023 10:32 10:32 10:33 10:33 10:33 YVer1f EsquireSolutions.com MARGARET CONBOY· Confidential 1　M. CONBOY 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. 6　Did you write the e-mail that 7　appears here in Conboy Exhibit 4? 8　A. Yes. 9　Q. Who is Kevin Walsh? 10　A. He's our managing partner. He's a 11　partner of mine. 12　Q. And you say -- in the first sentence 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. Who is the Chinese billionaire to 20　whom you are referring to in this e-mail? 21　MR. MAJOR: Objection to form. 22　A. That was how Miles Kwok was referred 23　to in -- when you do a Google search. 24　Q. Okay. 25　So when you wrote this e-mail and Case 22-50073 Doc 2292-45 Filed 10/26/23 Entered 10/26/23 20:46:12 Page 35 of 96 September 12, 2023 10:33 10:34 10:34 10:34 10:34 YVer1f 800.211.DEPO (3376) EsquireSolutions.com MARGARET CONBOY· Confidential 1　M. CONBOY 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. And then you say the -- at the end 8　of that sentence you say: The seller accepted 9　his offer of \$35 million. 10　Do you see that? 11　A. Yes. 12　Q. And the word "his" there again is a 13　reference to the Chinese billionaire, Miles 14　Kwok? 15　MR. MAJOR: Objection to form. 16　A. Yes. 17　Q. In the next sentence you say -- of 18　this e-mail, you say: I do not know if this 19　will really go through. He is meeting with 20　architects, engineers, et cetera. 21　I want to focus on the word "he" 22　there. He is meeting with architects, 23　engineers, et cetera. The "he," again, is a 24　reference to the Chinese billionaire, Mr. Kwok, 25　right? Case 22-50073 Doc 2292-45 Filed 10/26/23 Entered 10/26/23 20:46:12 Page 36 of 96 September 12, 2023 10:34 10:35 10:35 10:35 10:35 YVer1f 800.211.DEPO (3376) EsquireSolutions.com MARGARET CONBOY· Confidential 1　M. CONBOY 2　MR. MAJOR: Objection to form. 3　A. Yes. 4　Q. And then in the last sentence of 5　this e-mail it says: Apparently, the current 6　owner has approval to build two house. I'm not 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. 11　Again, consistent with the rest of 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. The work that you were performing 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. Case 22-50073 Doc 2292-45 Filed 10/26/23 Entered 10/26/23 20:46:12 Page 37 of 96 September 12, 2023 10:35 10:36 10:36 10:37 10:37 YVer1f 800.211.DEPO (3376) EsquireSolutions.com MARGARET CONBOY· Confidential 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 September 12, 2023 10:37 10:37 10:37 10:37 10:38 YVer1f 800.211.DEPO (3376) EsquireSolutions.com MARGARET CONBOY· Confidential 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 September 12, 2023 10:38 10:38 10:39 10:39 10:39 YVer1f EsquireSolutions.com MARGARET CONBOY· Confidential · 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 September 12, 2023 10:40 10:40 10:40 10:40 10:41 YVer1f 800.211.DEPO (3376) EsquireSolutions.com MARGARET CONBOY· Confidential 1　M. CONBOY 2　Emile. I don't remember him. 3　Q. In his e-mail to Barbara Vogt he 4　says: Could you please ask your clients to 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: Miles 12　does not want the extension. His lawyer is 13　just protecting him. 14　A. Yes. 15　Q. All right. Now, if you scroll up to 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. You having been copied on this 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 Case 22-50073 Doc 2292-45 Filed 10/26/23 Entered 10/26/23 20:46:12 Page 41 of 96 September 12, 2023 10:41 10:41 10:41 10:41 10:41 YVer1f EsquireSolutions.com MARGARET CONBOY· Confidential 1　M. CONBOY 2　would have been copied on this e-mail? 3　MR. MAJOR: Objection to form. 4　(Multiple speakers.) 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. 11　Well, if you scroll back down to the 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. 24　Does it stand to reason that if 25　Ms. Vogt was representing the seller in this Case 22-50073 Doc 2292-45 Filed 10/26/23 Entered 10/26/23 20:46:12 Page 42 of 96 September 12, 2023 10:42 10:42 10:42 10:42 10:43 YVer1f EsquireSolutions.com MARGARET CONBOY· Confidential · 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 September 12, 2023 10:43 10:43 10:43 10:44 10:44 YVer1f 800.211.DEPO (3376) EsquireSolutions.com MARGARET CONBOY· Confidential 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 September 12, 2023 10:44 10:44 10:45 10:45 10:45 YVer1f 800.211.DEPO (3376) EsquireSolutions.com MARGARET CONBOY· Confidential 1　M. CONBOY 2　Q. You don't -- you are not aware, 3　correct? 4　A. I'm not aware, no, no. 5　MR. BASSETT: If I could, please, 6　have my colleague put Tab 7 on the screen. 7　(Conboy Exhibit 7, July 12, 2019, 8　E-mail Chain Bates Labeled WBAM_003873, 9　marked for identification.) 10　MR. BASSETT: This document, which I 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, 14　and the Bates label in the bottom 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. And then if you would, please, go to 22　the first e-mail of the chain on 3875. 23　MR. BASSETT: There's a lot of 24　background noise. I'm not sure where 25　that's coming from. I think it was Case 22-50073 Doc 2292-45 Filed 10/26/23 Entered 10/26/23 20:46:12 Page 45 of 96 September 12, 2023 10:46 10:46 10:46 10:46 10:47 YVer1f 800.211.DEPO (3376) EsquireSolutions.com MARGARET CONBOY· Confidential 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 September 12, 2023 10:47 10:47 10:47 10:47 10:48 YVer1f 800.211.DEPO (3376) EsquireSolutions.com MARGARET CONBOY· Confidential 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 September 12, 2023 10:48 10:48 10:49 10:49 10:49 YVer1f 800.211.DEPO (3376) EsquireSolutions.com MARGARET CONBOY· Confidential 1　M. CONBOY 2　payroll as well. 3　Do you see that? 4　A. Yes. 5　Q. And then if we go up to the next 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. 10　And then if you go up, this is 11　Yvette Wang writing back to the initial author 12　of the first e-mail. And it says: Dear 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: Miles said 19　he exactly shares the same love as you to this 20　fabulous home. He would even hope you could 21　come back in the future, share the beautiful 22　stories about this place with him. I believe 23　there are a lot. 24　Do you see that? 25　A. Yes. Case 22-50073 Doc 2292-45 Filed 10/26/23 Entered 10/26/23 20:46:12 Page 48 of 96 September 12, 2023 10:49 10:49 10:50 10:50 10:50 YVer1f 800.211.DEPO (3376) EsquireSolutions.com MARGARET CONBOY· Confidential 1　M. CONBOY 2　Q. And then it says: Miles said he 3　appreciates you agree to leave the urns. He 4　does love them very much. In the same spirit 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. And then the next paragraph starts 11　with: Golden Spring New York Limited, as a 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. GSNY directly will 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. And then, finally, on the last 21　paragraph it says: On behalf of Miles, thank 22　you again for having this beautiful home to 23　him. All the best. 24　Do you see that? 25　A. Yes. Case 22-50073 Doc 2292-45 Filed 10/26/23 Entered 10/26/23 20:46:12 Page 49 of 96 September 12, 2023 10:50 10:50 10:50 10:51 10:51 YVer1f 800.211.DEPO (3376) EsquireSolutions.com MARGARET CONBOY· Confidential 1　M. CONBOY 2　Q. And if you go to the e-mail above 3　that, this is another e-mail back to Yvette 4　Wang. 5　MR. BASSETT: My colleague can 6　scroll up. 7　BY MR. BASSETT: 8　Q. And, again, this is from Louise 9　Camuto to Yvette Wang, copying Max Krasner and 10　Karin Maistrello. 11　If you scroll down, it says, among 12　other things: I'm so glad Miles will enjoy the 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. And then in the last paragraph it 18　says: Thank you and Miles, and please keep the 19　communication flowing. I'll be happy to come 20　visit him one day when he's all settled in. 21　Do you see that? 22　A. Yes. 23　Q. Now, this e-mail, as we already 24　established, contains the Bates stamp from your 25　law firm on it. So this means it came from Case 22-50073 Doc 2292-45 Filed 10/26/23 Entered 10/26/23 20:46:12 Page 50 of 96 September 12, 2023 10:51 10:51 10:51 10:52 10:52 YVer1f 800.211.DEPO (3376) EsquireSolutions.com MARGARET CONBOY· Confidential 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 September 12, 2023 10:52 10:52 10:52 10:53 10:53 YVer1f 800.211.DEPO (3376) EsquireSolutions.com MARGARET CONBOY· Confidential 1　M. CONBOY 2　and Hudson Diamond engagement that we talked 3　about? 4　A. Yes. 5　MR. MAJOR: Objection to form. 6　MR. BASSETT: If I can to -- or have 7　my colleague, please, put up the e-mail 8　that's -- sorry -- the document that's 9　Tab 8. 10　(Conboy Exhibit 8, December 15, 11　2020, E-mail Bates Stamped WBAM_0038336, 12　marked for identification.) 13　MR. BASSETT: I will have this 14　document marked as Conboy Exhibit 8. 15　BY MR. BASSETT: 16　Q. And for the record, it's another 17　e-mail chain, top e-mail in the chain, dated 18　December 15, 2020, Bates stamped at the lower 19　right-hand corner of the first page 20　WBAM_0038336. 21　Ms. Conboy, take your time to look 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. Case 22-50073 Doc 2292-45 Filed 10/26/23 Entered 10/26/23 20:46:12 Page 52 of 96 MARGARET CONBOY· Confidential September 12, 2023 1　M. CONBOY 2　Do you recall what property or 3　properties this was in reference to? The 4　subject line is: MK properties to Hudson 5　Diamond New York LLC? 6　A. I don't know which property that is. 7　MR. BASSETT: Go to the next page, 8　please. Next page, please. Okay. 9　BY MR. BASSETT: 10　Q. The -- the e-mail chain does not 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. And so, therefore, to the best of 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. And he's 24　telling us to hold off the -- it had to be 25　workup of properties. 800.211.DEPO (3376) EsquireSolutions.com 10:53 10:54 10:54 10:54 10:55 YVer1f Case 22-50073 Doc 2292-45 Filed 10/26/23 Entered 10/26/23 20:46:12 Page 53 of 96 1　M. CONBOY 2　Q. What he's saying specifically to you 3　is: I just spoke with Miles, and he advised 4　the team he will not move forward on this 5　property. 6　Do you see that? 7　A. Yes. 8　Q. And you understood that Miles is 9　reference to Miles Kwok? 10　A. Yes. 11　MR. MAJOR: Objection to form. 12　BY MR. BASSETT: 13　Q. And the "he advised" "he" there, 14　that would also be a reference to Miles Kwok? 15　MR. MAJOR: Objection to form. 16　A. That's what he wrote -- that's what 17　Max Krasner wrote, so. 18　Q. Okay. 19　So we've -- Ms. Conboy, we've seen 20　quite a few e-mails today, five or six or so. 21　Do you recall seeing these same 22　e-mails in your February deposition? 23　A. Yes. Case 22-50073 Doc 2292-45 Filed 10/26/23 Entered 10/26/23 20:46:12 Page 54 of 96 2 ESQUIRE Case 22-50073 Doc 2292-45 Filed 10/26/23 Entered 10/26/23 20:46:12 Page 55 of 96 & ESQUIRE Case 22-50073 Doc 2292-45 Filed 10/26/23 Entered 10/26/23 20:46:12 Page 56 of 96 2 ESOUIRE Case 22-50073 Doc 2292-45 Filed 10/26/23 Entered 10/26/23 20:46:12 Page 57 of 96 24　MR. BASSETT: I would like my 25　colleague to, please, put our Tab 10, which Case 22-50073 Doc 2292-45 Filed 10/26/23 Entered 10/26/23 20:46:12 Page 58 of 96 1　M. CONBOY 2　is going to be Exhibit 9 into the chat. 3　(Conboy Exhibit 9, Bates Labeled WBAM_00002, 5　marked for identification.) 6　MR. BASSETT: This one is a little 7　smaller. We might need to scroll in a 8　little bit more, and then we can just 9　direct ourselves to particular lines. 10　That's good. Maybe one out. 19　BY MR. BASSETT: 20　Q. Ms. Conboy, do you recognize this 21　document? 22　A. Yes. 23　Q. Okay. 24　A. Yes. 25　Q. Could you tell me what it is, 1　M. CONBOY Case 22-50073 Doc 2292-45 Filed 10/26/23 Entered 10/26/23 20:46:12 Page 61 of 96 1　M. CONBOY 2　A. 16　MR. THOMASON: You know, I have this 17　in hard copy. Can I show it to her? 18　A. Yes. 19　MR. BASSETT: Yeah, of course. 20　(Document review.) 21　MR. BASSETT: 1　M. CONBOY 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. Case 22-50073 Doc 2292-45 Filed 10/26/23 Entered 10/26/23 20:46:12 Page 63 of 96 Case 22-50073 Doc 2292-45 Filed 10/26/23 Entered 10/26/23 20:46:12 Page 64 of 96 1　M. CONBOY 2　A. Mm-hm. 3　Q. 6　A. Yes. 7　MR. MAJOR: Objection to form. 8　BY MR. BASSETT: 9　Q. Okay. 10　And now I want to go to the next 11　page of this document. 12　By the way, Ms. Conboy, does -- what 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. No, actually it was -- let me 20　see the dates. 21　(Document review.) 22　A. No. The closing was -- it wasn't 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 1　M. CONBOY 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. 1　M. CONBOY 7　Q.　Okay. 12　A.　Yes. 13　Q. 20　A.　Yes. 22　Q.　All right. 1　M. CONBOY 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. Case 22-50073 Doc 2292-45 Filed 10/26/23 Entered 10/26/23 20:46:12 Page 68 of 96 1　M. CONBOY 2　Q.　Okay. 9　MR. MAJOR: Objection to form. 10　BY MR. BASSETT: 11　Q.　I didn't hear your answer. I'm 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. 19　Q.　You said, again, Mr. Krasner was 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? Case 22-50073 Doc 2292-45 Filed 10/26/23 Entered 10/26/23 20:46:12 Page 69 of 96 September 12, 2023 11:12 11:12 11:12 11:12 11:12 YVer1f 800.211.DEPO (3376) EsquireSolutions.com MARGARET CONBOY· Confidential 1　M. CONBOY 2　MR. MAJOR: Objection to form. And 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: Chris, I'm going to 9　tell you again, you've waived any 10　privilege. I don't agree that you have the 11　privilege. 12　And this question in any event, is 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: Mr. Krasner was an 17　officer of Greenwich Land LLC. You've just 18　asked a question about a conversation he 19　had with a lawyer representing Greenwich 20　Land LLC. It's a privileged communication, 21　and we're instructing the witness not to 22　answer on those grounds. Your argument for 23　waiver is wrong. 24　We have never waived the privilege. 25　In fact, we've asserted the privilege. We Case 22-50073 Doc 2292-45 Filed 10/26/23 Entered 10/26/23 20:46:12 Page 70 of 96 MARGARET CONBOY· Confidential September 12, 2023 1　M. CONBOY 2　were not at the prior deposition. We were 3　not given notice or an invitation to the 4　prior deposition. 5　And Greenwich Land LLC has never 6　authorized the Whitman Breed firm to waive 7　the privilege. It's the client's 8　privilege. It's not the lawyer's 9　privilege. And it certainly isn't your 10　privilege as the questioning lawyer. And 11　it doesn't matter if there was a prior 12　disclosure that was done without the 13　knowledge and consent of the client. 14　MR. BASSETT: All right. I disagree 15　with everything you just said. You have 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. 21　I also do not -- did -- the fact 22　that I am asking about her conversations 23　with an officer of the company does not 24　render the answer at all privileged. I'm 25　not asking for her to reveal any advice 800.211.DEPO (3376) EsquireSolutions.com 11:13 11:13 11:13 11:13 11:14 YVer1f Case 22-50073 Doc 2292-45 Filed 10/26/23 Entered 10/26/23 20:46:12 Page 71 of 96 September 12, 2023 11:14 11:14 11:14 11:15 11:15 YVer1f EsquireSolutions.com MARGARET CONBOY· Confidential 1　M. CONBOY 2　that she gave or any advice that was sought 3　from her. 4　That's the definition of what it 5　requires for a communication to be cloaked 6　in the attorney-client privilege. 7　The question that I asked, which I 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. Ms. Conboy, did Mr. Krasner -- I'm 13　not asking for advice you gave to Mr. Krasner 14　or for anything Mr. Krasner asked you in terms 15　of legal advice. All I'm asking is if 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. And, 21　again, instruct the witness not to answer. 22　The -- 23　MR. BASSETT: How is that 24　privileged? 25　MR. MAJOR: Because you are asking Case 22-50073 Doc 2292-45 Filed 10/26/23 Entered 10/26/23 20:46:12 Page 72 of 96 September 12, 2023 11:15 11:15 11:15 11:15 11:29 YVer1f 800.211.DEPO (3376) EsquireSolutions.com MARGARET CONBOY· Confidential 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 11:29 11:29 11:29 11:30 11:30 YVer1f Case 22-50073 Doc 2292-45 Filed 10/26/23 Entered 10/26/23 20:46:12 Page 74 of 96 MARGARET CONBOY· Confidential September 12, 2023 1　M. CONBOY 2　MR. BASSETT: So thanks for that, 3　Chris. I don't think that is an accurate 4　articulation of the law or a correct 5　application of it. The question that I 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. 10　Moreover throughout the entire 11　deposition today, I have been asking 12　Ms. Conboy about her communications with 13　Mr. Krasner, including showing those 14　communications. Some of those 15　communications have indicated where 16　Mr. Krasner was telling her that Mr. Kwok 17　was deciding not to purchase a property, 18　for example. 19　That is absolutely no different than 20　what I'm now asking. There are already -- 21　there's already testimony in the record 22　about Mr. Kwok making decisions on behalf 23　of the client. All I'm asking is if she 24　ever was told that, instead of Mr. Kwok, 25　his wife needed to make decisions. So 800.211.DEPO (3376) EsquireSolutions.com 11:30 11:30 11:31 11:31 11:31 YVer1f Case 22-50073 Doc 2292-45 Filed 10/26/23 Entered 10/26/23 20:46:12 Page 75 of 96 MARGARET CONBOY· Confidential September 12, 2023 1　M. CONBOY 2　that's fair game. And it's -- the door has 3　been opened. Any privilege you may have 4　had has been waived throughout the day 5　today. 6　If you are going to stand on that 7　objection, we'll reserve our rights, take 8　it up with the Court, if necessary. 9　MR. MAJOR: We are going to stand on 10　the objection. And just to be clear, you 11　know, it's a disingenuous argument to try 12　to claim that there's been -- 13　MR. BASSETT: Hey Avi, put your 14　phone on mute. Sorry. 15　MR. MAJOR: -- that there's been a 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 20　the properties that you are asking 21　questions about. Here, you are talking 22　about a property that Greenwich Land LLC 23　was the owner of. Max Krasner, as you 24　know, is an officer of Greenwich Land, and 25　he was having communications with Greenwich 800.211.DEPO (3376) EsquireSolutions.com 11:31 11:31 11:32 11:32 11:32 YVer1f Case 22-50073 Doc 2292-45 Filed 10/26/23 Entered 10/26/23 20:46:12 Page 76 of 96 MARGARET CONBOY· Confidential September 12, 2023 KWOK V. GREENWICH LAND ET AL. 1　M. CONBOY 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. I'm not 6　asking about any particular transaction, to 7　be clear. The question was: In the course 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? I wasn't asking about a 13　particular transaction or property. 14　MR. MAJOR: Yeah, so look, if the 15　witness and her firm are comfortable that 16　they can delineate the representations, and 17　you want to limit your question to a 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. So I can only assert 24　privilege on behalf of those two. 25　And so again, though, the way you've 800.211.DEPO (3376) EsquireSolutions.com 11:32 11:33 11:33 11:33 11:33 YVer1f Case 22-50073 Doc 2292-45 Filed 10/26/23 Entered 10/26/23 20:46:12 Page 77 of 96 MARGARET CONBOY· Confidential September 12, 2023 1　M. CONBOY 2　asked questions, trying to lump the 3　entities together, I've been objecting to 4　the form of the question because it's 5　improper. But you are trying to make it 6　sound like, you know, Greenwich Land was no 7　different than the other entities in your 8　questions. 9　I don't know, since the witness, you 10　know, was previously deposed without our 11　involvement, I don't know if the witness is 12　able to delineate between the 13　representations that you've been grouping 14　together -- together. I don't agree that 15　they are grouped together at all, but 16　that's the way you've decided to ask your 17　questions. Which I think makes it a little 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. But 21　that's -- you know, that's just for 22　purposes of the record so we can deal with, 23　you know, what will be confusing testimony 24　later on. 25　But as to Greenwich Land, any 800.211.DEPO (3376) EsquireSolutions.com 11:34 11:34 11:34 11:34 11:34 YVer1f Case 22-50073 Doc 2292-45 Filed 10/26/23 Entered 10/26/23 20:46:12 Page 78 of 96 September 12, 2023 11:35 11:35 11:35 11:35 11:35 YVer1f 800.211.DEPO (3376) EsquireSolutions.com MARGARET CONBOY· Confidential 1　M. CONBOY 2　communications that Ms. Conboy had with an 3　officer of Greenwich Land about the 4　execution of a real estate transaction 5　concerning property owned by Greenwich 6　Land, we are going to stand on our 7　objection. 8　BY MR. BASSETT: 9　Q. Ms. Conboy, you testified before 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. I -- can you say the question again, 16　please. 17　MR. BASSETT: Could the court 18　reporter read it back, please? 19　(Question was read back as follows: 20　"QUESTION: Ms. Conboy, you 21　testified before that you represented 22　Greenwich Land, Golden Spring, and Hudson 23　Diamond New York as part of the same 24　engagement. 25　Do you recall that?") Case 22-50073 Doc 2292-45 Filed 10/26/23 Entered 10/26/23 20:46:12 Page 79 of 96 September 12, 2023 11:36 11:36 11:36 11:36 11:37 YVer1f 800.211.DEPO (3376) EsquireSolutions.com MARGARET CONBOY· Confidential 1　M. CONBOY 2　A. Yes. 3　Q. Ms. Conboy, in your communications 4　with Mr. Krasner, were you ever delineating 5　between Greenwich Land, Golden Spring, and 6　Hudson Diamond in the course of those 7　communications? 8　MR. MAJOR: Objection to form. And 9　I just caution the witness that she not 10　reveal attorney-client privileged 11　communications relating to Greenwich Land, 12　but I think the question can be answered 13　without stepping over that line. 14　MR. THOMASON: It sounds like a 15　yes-or-no question, correct? 16　MR. BASSETT: It is a yes-or-no. 17　MR. THOMASON: I think an answer to 18　that to -- either in the affirmative or the 19　negative wouldn't reveal privileged 20　information; is that right, Chris? 21　MR. MAJOR: Yes, that was my point. 22　MR. THOMASON: So if you can answer 23　that question in the affirmative or the 24　negative, you can do that. If you can't -- 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 September 12, 2023 11:37 11:37 11:37 11:37 11:38 YVer1f 800.211.DEPO (3376) EsquireSolutions.com MARGARET CONBOY· Confidential 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 1　M. CONBOY 2　MR. MAJOR: Objection to form. And 3　also I'd caution the witness not to reveal 4　attorney-client privileged communications. 5　MR. BASSETT: All right. I don't 6　think there's any confusion at this point. 7　BY MR. BASSETT: Case 22-50073 Doc 2292-45 Filed 10/26/23 Entered 10/26/23 20:46:12 Page 82 of 96 24　MR. THOMASON: Is that all for the 25　witness? Case 22-50073 Doc 2292-45 Filed 10/26/23 Entered 10/26/23 20:46:12 Page 83 of 96 September 12, 2023 11:40 11:40 11:41 11:41 11:41 YVer1f 800.211.DEPO (3376) EsquireSolutions.com MARGARET CONBOY· Confidential 1　M. CONBOY 2　MR. MAJOR: I'm going to have some 3　questions for the witness. 4　MR. THOMASON: That's fine. 5　EXAMINATION BY 6　MR. MAJOR: 7　Q. Good morning, Ms. Conboy. My name 8　is Chris Major. My partner Austin Kim is also 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. 12　And have you had a chance to review 13　the complaint in this adversary proceeding? 14　A. No. 15　Q. When was the first time that you 16　were contacted by the Chapter 11 trustee in 17　this in re Kwok bankruptcy matter? 18　A. It was at least -- I want to say at 19　least six months ago. Maybe more. 20　Q. Do you know the name of the 21　Chapter 11 trustee in this bankruptcy case? 22　A. I don't remember. 23　Q. Do you recall who contacted you on 24　behalf of the trustee? 25　A. Well, first a client called me. And Case 22-50073 Doc 2292-45 Filed 10/26/23 Entered 10/26/23 20:46:12 Page 84 of 96 September 12, 2023 11:42 11:42 11:42 11:42 11:43 YVer1f 800.211.DEPO (3376) EsquireSolutions.com MARGARET CONBOY· Confidential 1　M. CONBOY 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. I think maybe first by e-mail and 8　then -- I did talk to him by phone. 9　Q. Did anyone from your firm join you 10　when you spoke with Mr. Despins by phone? 11　A. I don't remember. 12　Q. And what did Mr. Despins say to you 13　during that phone call? 14　A. Initially, he was asking if it's -- 15　about sending the binder for -- for 373 16　Taconic. It was initially regarding the 17　Taconic -- and I represented the seller, so we 18　had to get waivers and that was the initial 19　discussion. 20　Q. Okay. 21　And did you deliver the file for 373 22　Taconic to Mr. Despins? 23　A. I believe what happened was my 24　client, who was the seller, was friends with 25　the attorney, the trustee. And he sent them Case 22-50073 Doc 2292-45 Filed 10/26/23 Entered 10/26/23 20:46:12 Page 85 of 96 September 12, 2023 11:43 11:43 11:44 11:44 11:44 YVer1f 800.211.DEPO (3376) EsquireSolutions.com MARGARET CONBOY· Confidential 1　M. CONBOY 2　the documents. I didn't send them. 3　Q. Do you recall the name of your 4　client on that transaction? 5　A. Augustine, Mr. Augustine. 6　Q. Did you deliver any documents to 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. Or Jim Riley, 11　Michael, they took over. So I didn't have -- 12　after that -- after Mr. Augustine sending the 13　documents, then I had no other contact with 14　them. 15　Q. Okay. 16　Did you have any further 17　conversations with Mr. Despins after that 18　initial phone call? 19　A. I don't remember. 20　Q. Do you still have the e-mail that 21　you received from Mr. Despins? 22　A. I don't know. 23　Q. Did you have further e-mail 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 September 12, 2023 11:44 11:44 11:45 11:45 11:45 YVer1f 800.211.DEPO (3376) EsquireSolutions.com MARGARET CONBOY· Confidential 1　M. CONBOY 2　A. I don't remember. 3　Q. Did you have communications with any 4　other lawyers at Paul Hastings in connection 5　with this bankruptcy, other than Mr. Despins? 6　A. I don't remember. 7　Q. Have you ever spoken with 8　Mr. Bassett before today? 9　A. No. 10　Q. Other than your deposition in -- 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. I 15　only had the deposition. 16　Q. What did you tell Mr. Despins on the 17　phone call when he asked for the closing file? 18　MR. BASSETT: Objection to form. 19　A. That I had to check with my client 20　and see if he was agreeable, if -- I would have 21　to get his consent. 22　Q. And going back to the Ferncliff Road 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 Case 22-50073 Doc 2292-45 Filed 10/26/23 Entered 10/26/23 20:46:12 Page 87 of 96 September 12, 2023 11:46 11:46 11:47 11:47 11:48 YVer1f 800.211.DEPO (3376) EsquireSolutions.com MARGARET CONBOY· Confidential 1　M. CONBOY 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. 7　Have you ever spoken to the person 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. In connection with the 373 Taconic 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. Do you know who the member of 21　Greenwich Land LLC is, or members? 22　A. No. 23　Q. Do you know the source of funds that 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 September 12, 2023 11:48 11:49 11:49 11:49 11:50 YVer1f 800.211.DEPO (3376) EsquireSolutions.com MARGARET CONBOY· Confidential 1　M. CONBOY 2　MR. BASSETT: Object to form. 3　A. No. 4　Q. Do you know who lives in the house 5　at 373 Taconic Road in Greenwich, Connecticut? 6　A. No. 7　Q. I'm limiting this question to 373 8　Taconic Road in Greenwich, Connecticut, where 9　you represented the seller. 10　Were you ever a witness to any 11　deliberations by the purchaser about acquiring 12　that property? 13　MR. BASSETT: Objection to form. 14　A. No. 15　Q. Do you recall the name of the buyer 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. You said that your client was 21　friends with Mr. Despins. 22　How did you learn that? 23　A. My client e-mailed me and -- my 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 September 12, 2023 11:50 11:50 12:05 12:05 12:06 YVer1f 800.211.DEPO (3376) EsquireSolutions.com MARGARET CONBOY· Confidential 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 12:06 12:06 12:07 YVer1f 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 1　M. CONBOY 2　THE WITNESS: No. 3　MR. THOMASON: So no, I would 4　appreciate a courtesy copy that I don't 5　have to pay for. If that's not possible 6　then, you know, I don't need a copy. 7　MR. BASSETT: I believe -- so, I'm 8　just trying to think of -- what's standard 9　delivery, again? 10　THE COURT REPORTER: It is eight 11　business days, but if you need it sooner, 12　I'm happy to do that for you. And you 13　never said if you wanted a rough draft or 14　not. 15　MR. BASSETT: I don't think we need 16　it. If we -- if somebody on my team tells 17　me that I made the wrong decision, I will 18　e-mail you. 19　(Continued on the following page to 20　include jurat.) · EsquireSolutions.com YVer1f 12:07 12:08 12:08 Case 22-50073 Doc 2292-45 Filed 10/26/23 Entered 10/26/23 20:46:12 Page 92 of 96 September 12, 2023 12:08 EsquireSolutions.com MARGARET CONBOY· Confidential 1　M. CONBOY 2　THE COURT REPORTER: Okay. Thank 3　you. 4　MR. BASSETT: Thank you very much, 5　Ms. Conboy. I appreciate it. 6　THE WITNESS: Thank you. 7　(Time Noted: 12:08 p.m.) 10　--------------------- 11　MARGARET CONBOY 13　Subscribed and sworn to before me 14　this day of 2023. 16　--------------------------------------- Case 22-50073 Doc 2292-45 Filed 10/26/23 Entered 10/26/23 20:46:12 Page 93 of 96 September 12, 2023 EsquireSolutions.com MARGARET CONBOY· Confidential KWOK V. GREENWICH LAND ET AL. 2　C E R T I F I C A T E 3　STATE OF NEW YORK ) 4　) ss.: 5　COUNTY OF NEW YORK ) 7　I, LISA M. MURACO, a Notary Public 8　within and for the State of New York, 9　Florida, and Massachusetts, do hereby 10　certify: 11　That MARGARET CONBOY, the witness 12　whose deposition is hereinbefore set forth, 13　was duly sworn by me and that such 14　deposition is a true record of the 15　testimony given by such witness. 16　I further certify that I am not 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. 21　IN WITNESS WHEREOF, I have hereunto 22　set my hand this 13th day of September, 23　2023. 24　------------------------- 25　LISA M. MURACO Case 22-50073 Doc 2292-45 Filed 10/26/23 Entered 10/26/23 20:46:12 Page 94 of 96 2　I N D E X 4　WITNESS　PAGE 5　MARGARET CONBOY 6　MR. BASSETT　6 7　MR. MAJOR　82 9　E X H I B I T S 10　DESCRIPTION　PAGE 11　Conboy Exhibit 1, Conboy Deposition　15 Transcript from February 21, 2023 Conboy Exhibit 2, 16　Conboy Exhibit 3, 19　Conboy Exhibit 4, October 3rd, 2019,　32 E-mail Bates labeled WBAM_010076 Conboy Exhibit 5, January 22, 2019,　36 22　E-mail Bates labeled WBAM_0002663 24　Conboy Exhibit 6, January 6, 2019,　38 E-mail, Bates Stamped WBAM_002803 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) EsquireSolutions.com Case 22-50073 Doc 2292-45 Filed 10/26/23 Entered 10/26/23 20:46:12 Page 96 of 96 September 12, 2023 EsquireSolutions.com MARGARET CONBOY· Confidential KWOK V. GREENWICH LAND ET AL. ERRATA SHEET FOR THE TRANSCRIPT OF: Case Name: KWOK v GREENWICH LAND, et al. Dep. Date:　TUESDAY, SEPTEMBER 12, 2023 Deponent:　MARGARET CONBOY CORRECTIONS: Pg. Ln. Now Reads　Should Read Reason ___ ___ ______________　______________ ___ ___ ______________　______________ ___ ___ ______________　______________ ___ ___ ______________　______________ ___ ___ ______________　______________ ___ ___ ______________　______________ ___ ___ ______________　______________ ___ ___ ___ ___ ______________　______________ ___ ___ ______________　______________ ___ ___ ______________　______________ Signature of Deponent SUBSCRIBED AND SWORN BEFORE ME THIS____DAY OF____________, 2023. (Notary Public) MY COMMISSION EXPIRES:_______