Guo Wengui / Miles Guo — bankruptcy case · ORDER · ECF #2355

UNITED STATES BANKRUPTCY COURT DISTRICT OF CONNECTICUT BRIDGEPORT DIVISION

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In re: : :

HO WAN KWOK, et al., : :

Debtors.1 : :

MONTHLY FEE STATEMENT OF O'SULLIVAN MCCORMACK JENSEN & BLISS PC FOR COMPENSATION AND REIMBURSEMENT OF EXPENSES FOR PERIOD FROM OCTOBER 1, 2023 THROUGH OCTOBER 31, 2023

In accordance with the Order Establishing Procedures for Interim Compensation and

Reimbursement of Expenses for Retained Professionals, dated August 18, 2023 [Docket No.

2094] (the "Interim Compensation Order"),[2] O'Sullivan McCormack Jensen & Bliss PC

("OMJB") hereby submits this monthly statement (the "Monthly Fee Statement") seeking

compensation for services rendered and reimbursement of expenses incurred as Special

Insurance Counsel to Genever Holdings LLC ("Genever (US)"), for the period from October 1,

2023 through and including October 31, 2023 (the "Fee Period"). By this Monthly Fee

Statement, OMJB respectfully requests payment of 80% of all fees and 100% of all expenses

actually and necessarily incurred for services rendered during the Fee Period, in the amounts of

\$19,742.00 and \$321.45, respectively.

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

2 Capitalized terms not otherwise defined herein shall have the meanings ascribed to such terms in the Interim Compensation Order.

1. Attached hereto as Exhibit A is a timekeeper summary that includes the name, title, bar admission, hourly billing rate, aggregate hours, and amount of fees earned for each OMJB individual who provided services during the Fee Period. The rates charged by OMJB for services rendered to Genever (US) are the same rates that OMJB charges generally for professional services rendered to its non-bankruptcy clients.

2. Attached hereto as Exhibit B is a summary of expenses incurred and reimbursement sought, by expense type, for the Fee Period.

3. Attached hereto as Exhibit C is the fee statement of OMJB for services provided during the Fee Period with redactions to protect certain privileged information.

4. Notice of this Monthly Fee Statement will be given by email on the Notice Parties: (i) Luc A. Despins, as chapter 11 trustee for the estate of Ho Wan Kwok (lucdespins@paulhastings.com); (ii) Counsel for the Trustee, (x) Paul Hastings LLP, 200 Park Avenue, New York, New York 10166 (Attn: G. Alexander Bongartz (alexbongartz@paulhastings.com) and Douglass Barron (douglassbarron@paulhastings.com)) and (y) Neubert, Pepe & Monteith, P.C., 195 Church Street, 13th Floor, New Haven, Connecticut 06510 (Attn: Douglas S. Skalka (dskalka@npmlaw.com) and Patrick R. Linsey (plinsey@npmlaw.com)); (iii) the Office of The United States Trustee, Giaimo Federal Building, 150 Court Street, Room 302, New Haven, Connecticut 06510 (Attn: Holley L. Claiborn (holley.l.claiborn@usdoj.gov)); (iv) counsel for the Official Committee of Unsecured Creditors, Pullman & Comley, LLC, 850 Main Street, 8th Floor, PO Box 7006, Bridgeport, Connecticut 06601-7006 (Attn: Irve J. Goldman (igoldman@pullcom.com); and (v) counsel for Pacific Alliance Asia Opportunity Fund L.P., O'Melveny & Myers LLP, 7 Times Square, New York,

New York 10036 (Attn: Peter Friedman (pfriedman@omm.com) and Stuart M. Sarnoff (ssarnoff@omm.com) (collectively, the "Notice Parties").

5. Objections to this Monthly Fee Statement, if any, must be filed with the Court and served upon (i) Special Insurance Counsel to Genever Holdings LLC, O'Sullivan McCormack Jensen & Bliss PC (Attn: Michael T. McCormack [\(mmccormack@omjblaw.com\)] (ii) the Notice Parties by email no later than December 11, 2023 at 4:00 p.m. (prevailing Eastern Time) (the "Objection Deadline"), setting forth the nature of the objection and the specific amount of fees or expenses at issue.

6. If no objections to this Monthly Fee Statement are filed and received on or before the Objection Deadline, Genever (US) shall promptly pay OMJB 80% of the fees and 100% of the expenses as identified in this Monthly Fee Statement.

7. To the extent that an objection to this Monthly Fee Statement is filed and received on or before the Objection Deadline, the estates shall withhold payment of that portion of this Monthly Fee Statement to which the objection is directed and promptly pay the remainder of the fees and expenses in the percentages set forth above. To the extent such an objection is not resolved, it shall be preserved and scheduled for consideration at the next interim fee application hearing. Dated: November 20, 2023 Glastonbury, Connecticut

By:\_\_\_/s/Michael T. McCormack\_\_\_\_\_\_\_\_

Michael T. McCormack (ct13799) Timothy P. Jensen (ct18888) Amy E. Markim (ct27974) O'Sullivan McCormack Jensen & Bliss PC 180 Glastonbury Boulevard, Suite 210 Glastonbury, CT 06033 Tel: 860-258-1993 Fax: 860-258-1991 mmccormack@omjblaw.com tjensen@omjblaw.com amarkim@omjblaw.com

Special Insurance Coverage Counsel for Debtor-In-Possession Genever Holdings LLC UNITED STATES BANKRUPTCY COURT DISTRICT OF CONNECTICUT BRIDGEPORT DIVISION

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In re: :

HO WAN KWOK, et al.,1 : :

Debtors. :

The undersigned hereby certifies that on November 20, 2023, the foregoing Monthly Fee Statement was electronically filed. In addition, a copy of the Monthly Fee Statement was served by email on the Notice Parties. Parties may access this filing through the Court's CM/ECF system.

By:\_\_/s/Michael T. McCormack\_\_\_\_\_\_\_\_ Michael T. McCormack (ct13799) Timothy P. Jensen (ct18888) Amy E. Markim (ct27974) O'Sullivan McCormack Jensen & Bliss PC 180 Glastonbury Boulevard, Suite 210 Glastonbury, CT 06033 Tel: 860-258-1993 Fax: 860-258-1991 mmccormack@omjblaw.com tjensen@omjblaw.com amarkim@omjblaw.com Special Insurance Coverage Counsel for Debtor-In-Possession Genever Holdings LLC

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

Timothy Jensen 1997 \$450.00 30.5 \$13,725.00 Amy Markim 2008 \$350.00 7.1 \$2,485.00 Michael McCormack 1993 \$400.00 18.2 \$7,280.00 Melissa Gambardella 125.00 9.5 \$1,187.50

Fees Advanced for Logikcull Invoice – \$270.00

Case 22-50073 Doc 2355 Filed 11/20/23 Entered 11/20/23 15:40:15 Page 9 of 12

180 Glastonbury Boulevard, Suite 210 Glastonbury, CT 06033 Phone: 860-258-1993 [www.omjblaw.com]

Genever Holdings LLC 200 Park Avenue New York, NY 10166 3726-001-Genever Holdings/AIG Property Casualty

Date Attorney Activity Time Rate Total

10/01/2023 TPJ Reviewing draft motion for summary judgment papers 1.40 \$450.00 \$630.00 10/03/2023 MTM Review of correspondence from AIG re denial of liability claim re flooding

10/03/2023 TPJ Continue reviewing and revising draft summary judgment papers 4.20 \$450.00 \$1,890.00 10/04/2023 AM Finalize supplemental document production (1.6); Draft/revise privilege logs (1.4); correspondence to counsel re: document production and non

10/04/2023 MBG Preparation of privilege spreadsheets for service 0.30 \$125.00 \$37.50 10/04/2023 TPJ Attend to privilege log 0.20 \$450.00 \$90.00 10/05/2023 MTM Review of additional proposed edits re motion for summary judgment; email correspondence with Attny Despins 0.30 \$400.00 \$120.00 10/05/2023 MTM Conference with L. Despins re motion for summary judgment and

10/05/2023 MTM Revise and supplement motion for summary judgment declarations; attention to motion for summary judgment and brief revision and

10/06/2023 MTM Revise and edit brief in support of motion for summary judgment re T. Jensen and L. Despins comments and evidentiary citations; review of exhibitsre same 2.60 \$400.00 \$1,040.00 10/06/2023 AM Additional review of documents for responses to discovery and draft supplemental privilege log. 2.20 \$350.00 \$770.00 10/06/2023 MTM Final review and revisions to motion for summary judgment, statement of facts, declarations and affidavits and memorandum of law for filing 1.60 \$400.00 \$640.00

10/06/2023 MBG Revise and finalize Motion for Summary Judgment; prepare exhibitsto Despins Declarations; revise and finalize Memorandum of Law and Statement of Undisputed Facts; finalize MTM Affidavit in support of same; finalize and e-file. 6.50 \$125.00 \$812.50

10/10/2023 MBG Prepare sharefiling of MSJ pleadings as filed and share with Attorney

10/11/2023 MTM Telephone conference with Attny Bogartz re fee application 0.40 \$400.00 \$160.00 10/11/2023 AM Conference with T. Jensen re:

10/11/2023 AM Analyze obligations under FRCP and Local Rules re:

(.4); email to client re: same (.1).

10/11/2023 TPJ Attend to discovery matters; Rule 26f conference 1.10 \$450.00 \$495.00 10/12/2023 MTM Attention to Rule 26 report issues and communications with counsel re

10/12/2023 MTM Review of fee application bankruptcy order; drafting of monthly fee

10/12/2023 TPJ Attend to Rule 26f report and discovery matters 3.10 \$450.00 \$1,395.00 10/13/2023 TPJ Attend to discovery matters; work on Rule 26f report; Pure subpoena 3.50 \$450.00 \$1,575.00 10/13/2023 MTM Telephone conference with L. Despins re Rule 26 report and pretrial

10/13/2023 MTM Conference with J. O'Connor and T. Jensen re Rule 26 Report and pretrial issues 0.40 \$400.00 \$160.00 10/13/2023 MTM Review and comment re draft Ruel 26 report; email communication with Attny O'Connor and Attny Despins re same; 0.40 \$400.00 \$160.00 10/13/2023 MTM Conference with L. Despins and T. Jensen re Rule 26 Report, discovery and pretrial issues 0.50 \$400.00 \$200.00 10/13/2023 MTM Conference with T. Jensen re motion for summary judgment and discovery strategy 0.30 \$400.00 \$120.00 10/13/2023 MTM Telephone conference with Adam Wolfson re subpoena document

10/16/2023 MBG Set up sharefile for Wolfson subpoena responsive documents; download and organization of same. 0.40 \$125.00 \$50.00 10/16/2023 MTM Telephone conference with L. Despins re pretrial conference and insurance issues 0.20 \$400.00 \$80.00 10/16/2023 TPJ Attend to Pure subpoena matters; analysis re strategy 0.80 \$450.00 \$360.00 10/17/2023 MTM Prepare for pretrial conference: Review and analysis of excessliability policy cancellation and reinstatement communications; review Judge Manning decision, email communications and telephone conferences with Attny O'Connor and L. Despins re excessliability policy reinstatement issues (1.5); review of draft Rule 26 report and outline dates re discovery, depositions and motions for summary judgment (.4) 1.90 \$400.00 \$760.00 10/17/2023 MTM Revise and finalize monthly fee applications re August and September; email communications with Attny Bongartz re same 0.40 \$400.00 \$160.00 10/17/2023 MTM Attend bankruptcy pretrial hearing conference re insurance adversary 0.70 \$400.00 \$280.00

10/17/2023 MBG Convert Adversary Proceeding Complaint to word and set up for

10/17/2023 MTM Preliminary review of Wolfson documents produced in response to subpoena (.3); telephone conference with Attny Bongartz re fee application submissions (.2) 0.50 \$400.00 \$200.00 10/17/2023 TPJ Attend to document production and subpoenas; drafting

10/18/2023 MTM Finalize draft fee application; email communication to Attny Bongartz re monthly fee application 0.20 \$400.00 \$80.00 10/18/2023 TPJ Attend to matters re 3d party subpoena document requests 3.90 \$450.00 \$1,755.00 10/18/2023 MBG Attention to transmitting sharefile of Wolfson document production to L.

analysis re same 0.50 \$400.00 \$200.00 10/19/2023 AM Email correspondence to L. Despins re:

10/19/2023 AM Conference with M. McCormack re:

10/19/2023 MTM Revise and finalize fee applications and redacted invoices; attention to comments from and email communications with Attny Bongartz 0.80 \$400.00 \$320.00 10/19/2023 MTM Conference with L. Despins re follow up to pretrial conference issues (.3);

10/19/2023 TPJ Attend to 3d party subpoena matters 1.10 \$450.00 \$495.00 10/20/2023 MBG Review emails between counsel re Fee Application; confer with MTM re: redactions to invoices; redact invoices and prepare final set for TPJ review; further redactions to invoices and finalize Fee Applications. 0.90 \$125.00 \$112.50 10/20/2023 MBG Issues with e-filing Fee Application; communications with court clerks, MTM, TPJ and Alex Bongartz; further attempts to e-file and continued issues; further communications with MTM, TPJ and Attorney Bongartz (.5).; draft Appearances for MTM, TPJ and AEM in main bankruptcy case

10/20/2023 TPJ Attend to 3d party subpoena matters (.6); attend to fee submission (.4) 1.00 \$450.00 \$450.00 10/23/2023 MTM Attention to and analysis of summary judgment, discovery and policy issues; email correspondence with Mr. Despins re same 0.20 \$400.00 \$80.00 10/25/2023 MTM Review of Genever revised draft Rule 26 report; email correspondence to L. Despins re same 0.30 \$400.00 \$120.00 10/25/2023 TPJ Attend to 3d party subpoena issues; attend to rule 26f report issues 1.70 \$450.00 \$765.00 10/25/2023 MTM Receipt and review of AIG revised draft Rule 26 report; email correspondence to Attny Despins re same 0.30 \$400.00 \$120.00 10/26/2023 TPJ Attend to 3d party subpoenas; attend to rule 26f report 2.70 \$450.00 \$1,215.00 10/27/2023 TPJ Attend to Rule 26f report and revisions to same; 1.30 \$450.00 \$585.00 10/28/2023 MTM Email correspondence to H. Claiborn re fee application 0.10 \$400.00 \$40.00

Expense 10/06/2023 Fees advance to Logikcull INV152264 9-30-2023 \$270.00 Expense 10/31/2023 Copying: Month of October \$6.40 Expense 10/31/2023 Westlaw: Month of October \$45.05

Timothy Jensen 30.5 \$450.00 \$13,725.00

Michael McCormack 18.2 \$400.00 \$7,280.00 Melissa Gambardella 9.5 \$125.00 \$1,187.50

Invoice Number Due On Amount Due PaymentsReceived Balance Due

27021 09/25/2023 \$99,873.56 \$1,105.00 \$98,768.56 27098 10/11/2023 \$35,374.76 \$0.00 \$35,374.76

Invoice Number Due On Amount Due PaymentsReceived Balance Due

27168 11/14/2023 \$24,998.95 \$0.00 \$24,998.95 Balance Due on All Invoices \$159,142.27

Please make all amounts payable to: O'Sullivan McCormack Jensen & BlissPC Tax ID# REDACTED

Payment is due upon receipt.