---
type: court_doc
id: "court_ctb_2433_0"
court: "CTB"
case_no: "22-50073"
doc_number: 2433
doc_type: "EXHIBIT"
filed_date: null
lang: "en"
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# Guo Wengui / Miles Guo — bankruptcy case · EXHIBIT · ECF #2433



UNITED STATES BANKRUPTCY COURT DISTRICT OF CONNECTICUT BRIDGEPORT DIVISION

x

In re:　:
:　Chapter 11

HO WAN KWOK,
et al.,　:
:
:　Case No. 22-50073 (JAM)
Debtors.　:
:　(Jointly Administered)
-----------------------------------------------------------　x
APPELLEE'S COUNTER-DESIGNATION OF ADDITIONAL ITEMS TO BE INCLUDED IN RECORD ON APPEAL

Appellee, Luc A. Despins, in his capacity as the chapter 11 trustee (the "Trustee") appointed in the chapter 11 case of Ho Wan Kwok (the "Debtor"), by and through his undersigned counsel, hereby provides, pursuant to Rule 8009 of the Federal Rules of Bankruptcy Procedure, the following counter-designation of additional items to be included in the record on appeal.
COUNTER-DESIGNATION OF RECORD ON APPEAL

Appellee respectfully counter-designates the following items for inclusion in the record on appeal pursuant to Rule 8009(a)(2) of the Federal Rules of Bankruptcy Procedure. This designation includes all exhibits attached or referred to in the pleadings or matters of record.

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

Docket No.　Date Filed　Description

27　06/23/2023　ORDER GRANTING IN PART MOTION TO CONTINUE
PRELIMINARY INJUNCTION HEARING AND EXTEND
TEMPORARY RESTRAINING ORDER WITH RESPECT
TO
CERTAIN
CONSENTING
DEFENDANTS
AND
SCHEDULE STATUS CONFERENCE
28　06/23/2023　Certificate of Service
Regarding 9019 Motion and Motion to
Expedite and Limited Service
Filed by Douglass E. Barron
on behalf of Luc A. Despins Plaintiff
31　06/23/2023　Notice
of
Chapter

Trustee
Regarding
Temporary
Restraining Order and June 26 Status Conference
Adversary Proceeding Docket Entries (No. 23-05013 (JAM))

Main Bankruptcy Case Docket Entries (No. 22-50073
(JAM))

Docket No.　Date Filed　Description

1805　5/18/2023　Motion to Compel Compliance with Rule 2004 Subpoenas
(Second Omnibus)
Filed by Patrick R. Linsey on behalf of
Luc A. Despins, Chapter 11 Trustee.
1844　6/1/2023　Notice of Appearance
Filed by Jeffrey M. Sklarz on behalf
of G Club Operations, LLC Interested Party.
1845　6/1/2023　Motion to Extend Time to Time to Respond to Trustee's
Motion to Compel Compliance with Rule 2004 Exam
Subpoena to August 7, 2023
Filed by Jeffrey M. Sklarz on
behalf of G Club Operations, LLC, Interested Party.
1846　6/1/2023　Objection
(Preliminary Objection) to Trustee's Motion to
Compel Compliance with Rule 2004 Subpoena
Filed by
Jeffrey M. Sklarz on behalf of G Club Operations, LLC
Interested Party.
1875　6/5/2023　Reply to (related document(s):

Motion to Compel
Compliance
with
Rule

Subpoenas
(Second
Omnibus)
Filed by Patrick R. Linsey on behalf of Luc A.
Despins, Chapter 11 Trustee filed by Chapter 11 Trustee Luc
A. Despins)
1884　6/6/2023　Notice of Appearance
Filed by Carolina A Fornos on behalf
of G Club Operations, LLC Interested Party.
1892　6/7/2023　Order Granting In Part Motion for Entry of Order Holding
Non-Responding Parties in Civil Contempt of Court.
1898　6/9/2023　Order Granting In Part Motion for Extension of Time.
1907　6/14/2023　Transcript
. Hearing held on 6/6/23
1924　6/22/2023　Objection
to Trustee's Motion to Compel and Request for
Related Relief
1934　6/23/2023　Reply to (related document(s):

Motion to Compel
Compliance
with
Rule

Subpoenas
(Second
Omnibus)
Filed by Patrick R. Linsey on behalf of Luc A.
Despins, Chapter 11 Trustee filed by Chapter 11 Trustee Luc
A. Despins)Reply to G Club Operations LLC's Supplemental
Objection [ECF No. 1824]
Filed by Patrick R. Linsey on
behalf of Luc A. Despins Chapter 11 Trustee
1960　6/28/2023　Order Granting Motion to Compel G-Club to Comply with
Rule 2004 Subpoena

Docket No.　Date Filed　Description

2119　8/24/2023　Transcript
Amended to correct adversary case number.
CERTIFICATION REGARDING TRANSCRIPTS

Appellee, pursuant to Rule 8009(b)(3) of the Federal Rules of Bankruptcy Procedure, hereby certifies that he is not ordering any transcripts. All transcripts have been prepared and are either available on the docket or in the Bankruptcy Court Clerk's Office.
RESERVATION OF RIGHTS

Appellee expressly reserves the right to (i) withdraw, supplement, amend or modify this Counter-Designation of Record on Appeal and (ii) move to strike any items included by the Appellant in its Statement of Issues and Designation of Items to be Included in the Record on Appeal. This filing is made expressly subject to, and without waiver of any and all rights, remedies, challenges, and objections.

Respectfully submitted,

Dated: December 13, 2023 LUC A. DESPINS,

New Haven, Connecticut CHAPTER 11 TRUSTEE

By: /s/ Patrick R. Linsey Patrick R. Linsey (ct29437) NEUBERT, PEPE & MONTEITH, P.C. 195 Church Street, 13th Floor New Haven, Connecticut 06510 (203) 781-2847 plinsey@npmlaw.com

and

Nicholas A. Bassett (admitted pro hac vice) PAUL HASTINGS LLP 2050 M Street NW Washington, D.C., 20036 (202) 551-1902 nicholasbassett@paulhastings.com

and

Avram E. Luft (admitted pro hac vice) Douglass Barron (admitted pro hac vice) PAUL HASTINGS LLP 200 Park Avenue New York, New York 10166 (212) 318-6079 aviluft@paulhastings.com

Counsel for the Chapter 11 Trustee
UNITED STATES BANKRUPTCY COURT DISTRICT OF CONNECTICUT BRIDGEPORT DIVISION

x

In re:　:
:　Chapter 11

HO WAN KWOK,
et al.,　:
:
:　Case No. 22-50073 (JAM)
Debtors.　:
:　(Jointly Administered)
-----------------------------------------------------------　x
CERTIFICATE OF SERVICE

The undersigned certifies that on the 13th day of December 2023 a copy of the foregoing Appellee's Counter-Designation of Items to be Included in Record on Appeal was filed electronically and notice thereof emailed via the Court's case management/electronic case files ("CM/ECF") system to all appearing parties able to accept electronic notice. Parties may access this filing through the Court's CM/ECF system.

> By: /s/ Patrick R. Linsey Patrick R. Linsey

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