Guo Wengui / Miles Guo — bankruptcy case · EXHIBIT · ECF #2437-2

METADATA

Defendant
Guo Wengui / Miles Guo / Ho Wan Kwok
Court
CTB
Case No.
22-50073
ECF #
2437
Type
EXHIBIT
Filed
2023-12-13

FULL TEXT

UNITED STATES BANKRUPTCY COURT DISTRICT OF CONNECTICUT BRIDGEPORT DIVISION

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In re: :

: Chapter 11

HO WAN KWOK, et al.,1 :

: Case No. 22-50073 (JAM)

Debtors. : :

: (Jointly Administered)

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).

Case 22-50073 Doc 2433 Filed 12/13/23 Entered 12/13/23 21:56:02 Page 2 of 6 Case 22-50073 Doc 2437-2 Filed 12/15/23 Entered 12/15/23 16:29:47 Page 2 of 6

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)) Case 22-50073 Doc 2433 Filed 12/13/23 Entered 12/13/23 21:56:02 Page 3 of 6 Case 22-50073 Doc 2437-2 Filed 12/15/23 Entered 12/15/23 16:29:47 Page 3 of 6

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): 1805 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

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

Case 22-50073 Doc 2433 Filed 12/13/23 Entered 12/13/23 21:56:02 Page 4 of 6 Case 22-50073 Doc 2437-2 Filed 12/15/23 Entered 12/15/23 16:29:47 Page 4 of 6

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

Case 22-50073 Doc 2433 Filed 12/13/23 Entered 12/13/23 21:56:02 Page 5 of 6 Case 22-50073 Doc 2437-2 Filed 12/15/23 Entered 12/15/23 16:29:47 Page 5 of 6

> 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

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In re: :

: Chapter 11

HO WAN KWOK, et al.,1 :

: Case No. 22-50073 (JAM)

Debtors. : :

: (Jointly Administered)
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).

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