Guo Wengui / Miles Guo — bankruptcy case · ORDER · ECF #2475

UNITED STATES BANKRUPTCY COURT DISTRICT OF CONNECTICUT BRIDGEPORT DIVISION

------------------------------------------------------ x

In re: :

HO WAN KWOK, et al., : :

Debtors.1 :

------------------------------------------------------ x COVERSHEET FOR FIRST INTERIM FEE APPLICATION OF PALLAS PARTNERS LLP

Interim Application of: Pallas Partners LLP

Time Period: January 26, 2023 through November 30, 2023 Bankruptcy Petition Filed: February 15, 2022 Date of Entry of Retention Order: March 24, 2023 [ECF No. 1596] (effective as of January 26, 2023).

Fees: \$318,591.50 Voluntary Fee Reductions: none Expenses: \$4,953.04 Voluntary Expenses Reductions: none

Fees Previously Requested: Retainer Request:

Expenses Previously Requested: Expense Detail: Requested Expenses: \$0.00 Retainer Received: Not applicable Awarded Expenses: \$0.00 Copies per page cost & total: Not applicable

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). UNITED STATES BANKRUPTCY COURT DISTRICT OF CONNECTICUT BRIDGEPORT DIVISION

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In re: :

HO WAN KWOK, et al., :

Debtors.1 : :

------------------------------------------------------ x FIRST INTERIM FEE APPLICATION OF PALLAS PARTNERS LLP, AS SOLICITORS IN UNITED KINGDOM, FOR COMPENSATION AND REIMBURSEMENT OF EXPENSES FOR PERIOD FROM JANUARY 26, 2023 THROUGH NOVEMBER 30, 2023

Pursuant to sections 105(a), 328, 330, and 331 of title 11 of the United States Code (such title, hereinafter, the "Bankruptcy Code"), Rule 2016 of the Federal Rules of Bankruptcy Procedure (the "Bankruptcy Rules"), Rule 2016-1 of the Local Rules of Bankruptcy Practice and Procedure of the United States Bankruptcy Court for the District of Connecticut (the "Local Rules"), and 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"), Pallas Partners LLP ("Pallas"), as United Kingdom solicitors to 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"), hereby files this *First Interim Application of Pallas Partners LLP, as Solicitors in United Kingdom, for Compensation and Reimbursement of Expenses for the*

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).

Period from January 26, 2023 through November 30, 2023 (the "Application"). By this Application, Pallas requests interim allowance of professional fees incurred during the period from January 26, 2023 through and including November 30, 2023 (the "Application Period") in these chapter 11 cases. In support of this Application, Pallas respectfully states as follows: JURISDICTION, VENUE, BASES FOR RELIEF, AND COMPLIANCE

1. The Court has jurisdiction over this matter pursuant to 28 U.S.C. §§ 157 and 1334 and the Standing Order of Reference from the United States District Court for the District of Connecticut. This matter is a core proceeding within the meaning of 28 U.S.C. § 157(b)(2). Venue is proper pursuant to 28 U.S.C. §§ 1408 and 1409.

2. The legal predicates for the relief requested herein are sections 328, 330, and 331 of the Bankruptcy Code, Bankruptcy Rule 2016, and Local Rule 2016-1.

3. Pallas believes that this Application, together with the attachments hereto, substantially complies with the Bankruptcy Rules, Local Rule 2016-1, and the *United States Trustee's Guidelines for Reviewing Applications for Compensation and Reimbursement of Expenses Filed Under 11 U.S.C. § 330 by Attorneys in Larger Chapter 11 Cases* (the "U.S. Trustee Guidelines").2 Pallas respectfully requests a waiver of any of the foregoing requirements not met by this Application.

- 4. Attached and incorporated herein by reference are the following Exhibits: - Exhibit A contains the Proposed Order granting this Application. - Exhibit B is a timekeeper summary that includes the name, title, bar admission, hourly billing rate, aggregate hours, and amount of fees earned for each Pallas individual who provided services during the Application Period;

2 Pallas reserves all rights as to the relevance and substantive legal effect of the U.S. Trustee Guidelines with respect to any application for compensation in these chapter 11 cases.

- Exhibit C is a summary of expenses incurred and reimbursement sought, by expense type, during the Application Period; and - Exhibit D contains the detail of the fees and expenses incurred during the Application Period.

5. On February 15, 2022 (the "Petition Date"), the Individual Debtor filed a voluntary petition for relief under the Bankruptcy Code in the United States Bankruptcy Court for the District of Connecticut (Bridgeport Division) (the "Court").

6. On March 21, 2022, the United States Trustee appointed an Official Committee of Unsecured Creditors (the "Committee") in the Individual Debtor's chapter 11 case. No examiner has been appointed in the Individual Debtor's chapter 11 case.

7. On June 15, 2022, the Court entered a memorandum of decision and order [ECF

No. 465] (the "Trustee Order") directing the United States Trustee to appoint a chapter 11 trustee in the Individual Debtor's chapter 11 case.

8. Pursuant to the Trustee Order, the United States Trustee selected Luc A. Despins as the Trustee. On July 8, 2022, the Court entered an order granting the appointment of Luc A. Despins as the Trustee in the Individual Debtor's chapter 11 case

9. By order entered March 24, 2023, the Court authorized Pallas' retention as solicitor in the United Kingdom for the Trustee [ECF No. 1596] (the "Retention Order") effective as of January 26, 2022 in the Debtor's chapter 11 case. The Retention Order authorizes Pallas to be compensated on an hourly basis and reimbursed for actual and necessary out-ofpocket expenses pursuant to sections 328 and 330 of the Bankruptcy Code, the Bankruptcy Rules, the Local Rules, and such orders as the Court may direct.

10. On August 18, 2023, the Court entered the Interim Compensation Procedures Order, which, among other things, approves procedures for the payment of 80% of fees and 100% of expenses on a monthly basis.

11. The Applicant is applying for compensation pursuant to Sections 330 and 331 of the Bankruptcy Code for legal services performed for the Trustee during the Application Period.

12. For the Application Period, the Applicant seeks allowance of \$318,591.50 as compensation for services rendered and allowance and reimbursement of \$4,953.04 in expenses incurred in connection with such services. The Applicant devoted 319.2 hours to this case during the Application Period, equating to an overall blended rate of \$998.09.

13. Throughout the Application Period, the Applicant maintained records to indicate the name of each attorney or paraprofessional working on this matter, the time spent on a particular issue, and the nature of the work performed. These records, which describe in detail the services rendered by the Applicant, were created at the approximate time the services were performed.

14. Annexed hereto and made a part hereof as Exhibit D is a detailed billing report, upon which this application is based that contains each individual professional's time for the Debtors' bankruptcy proceedings, itemizing the dates upon which services were rendered, including a summary of the services on each of such dates by each person rendering the service, the time spent in rendering such service, and the dollar value of such services.

15. Upon being formally instructed, Pallas was asked to provide detailed and strategic advice in connection with the English litigation proceedings (the "UBS Action") brought by the

Individual Debtor, Ace Decade Holdings Limited ("Second Claimant") and Dawn State Limited ("Third Claimant") against UBS AG (the "Defendant") (Case CL-2020-000345), which litigation claims constitute property of the Individual Debtor's estate.

16. Pallas has been advising the Trustee on several matters related to the UBS Action, including as it relates to the Defendant's jurisdiction challenge, its implications and the position for the Trustee to adopt. Pallas also conducted a thorough review of the disclosure provided by the Second and Third Claimants in order to assist in ascertaining the merits of the English proceedings and the case against UBS.

17. Pallas has also corresponded with the Individual Debtor's former UK counsel in connection with the UBS Action regarding this litigation. In addition, Pallas has been advising the Trustee on the most cost-efficient ways to maximize value from the UBS Action for the benefit of the Individual Debtor's estate and its creditors.

18. In order to achieve the Trustee's objective of maximizing value for the benefit of the creditors, Pallas has also been advising the Trustee on the process of obtaining control of the Second and Third Claimants for the purposes of the UBS Action. This has required providing advice generally as to matters of English law, including regarding the Trustee's rights and duties as chapter 11 trustee and his ability to seek recognition of foreign court judgments and orders in the United Kingdom in order to be in a position to take control of the UBS Action and realize value from the litigation for the benefit of the creditors.

19. To that end, following substantial correspondence, we were instructed to prepare a stay application in order to apply to the English court to pause the current UBS Action while steps are taken in other jurisdictions to take control over the Second and Third Claimants, steps which can then be recognized in England.

20. The work undertaken by Pallas to date has been significant, involving disclosure review, correspondence, strategic input, and a substantial stay application. This work remains ongoing, with a hearing expected in due course in order to hear the Trustee's stay application

21. No prior application for the relief requested has been made.

22. All of the professional services for which this award is being sought hereby were rendered solely on behalf of the Trustee in connection with the chapter 11 cases herein.

23. Applicant respectfully submits that its services have benefited the Trustee with the expertise and skill required in the handling of bankruptcy matters. The legal services for which such compensation is requested were performed for and on behalf of the Trustee. Such services have been necessary to protect and enforce the rights and interests of the Trustee in connection with these chapter 11 cases. The reasonable value of services rendered by Pallas in these cases is based upon Pallas' usual hourly rates for matters of this nature.

24. Section 330 of the Bankruptcy Code prescribes the general standards for determining the amount of compensation to be paid to professionals. The Applicant submits that the amount sought for the Application Period represents reasonable compensation for professional services rendered based upon the time spent, the nature, the extent, and the value of such services, taking into account the cost of comparable services in a non-bankruptcy case.

25. Section 331 of the Bankruptcy Code provides for interim compensation of professionals and incorporates the substantive standards of section 330 of the Bankruptcy Code to govern the Court's award of such compensation. Section 330(a) of the Bankruptcy Code provides that, after notice and a hearing, the Court may award a professional employed under 11

U.S.C. § 327 "reasonable compensation for actual, necessary services rendered" and "reimbursement for actual, necessary expenses." 11 U.S.C. § 330(a)(1).3

26. In determining the amount of "reasonable compensation," the Court must consider the nature, extent, and value of the services, taking into account all the relevant factors, including the time spent on such services, the rates charged for such services, whether the services were necessary and beneficial, whether the services were performed in a reasonable amount of time commensurate with the complexity, importance, and nature of the problem, issue, or task addressed, and whether the compensation is reasonable based on the customary compensation charged by comparably skilled practitioners in cases other than cases under the Bankruptcy Code. See 11 U.S.C. § 330(a)(3). The Court enjoys "considerable discretion in determining reasonable fee awards." In re Ahead Communication Systems, Inc., 395 B.R. 512 (D. Conn. 2008).

27. In assessing the "reasonableness" of the fees requested, the Second Circuit has stated that courts should consider the factors enumerated in Johnson v. Ga. Highway Express, Inc., 4 while also incorporating the "lodestar method." See Arbor Hill Concerned Citizens Neighborhood Ass'n v. County of Albany and Albany County Bd. of Elections, 522 F.3d 182, 190 (2d Cir. 2007) (citing Johnson v. Ga. Highway Express, Inc., 488 F.2d 714 (5th Cir.1974),

3 Under section 328(a) of the Bankruptcy Code, with bankruptcy court approval, a trustee may employ professional persons under section 327(a) of the Bankruptcy Code "on any reasonable terms and conditions of employment, including on a retainer, on an hourly basis, on a fixed or percentage fee basis, or on a contingent fee basis." 11 U.S.C. § 328(a).

4 The twelve Johnson factors are (1) the time and labor required, (2) the novelty and difficulty of the questions, (3) the skill requisite to perform the legal service properly, (4) the preclusion of other employment by the attorney due to acceptance of the case, (5) the customary fee, (6) whether the fee is fixed or contingent, (7) the time limitations imposed by the client or the circumstances, (8) the amount involved and the results obtained, (9) the experience, reputation, and ability of the attorneys, (10) the "undesirability" of the case, (11) the nature and length of the professional relationship with the client, and (12) awards in similar cases. Johnson, 488 F.2d at 717-19.

abrogated on other grounds by Blanchard v. Bergeron, 489 U.S. 87, 92–93, 96 (1989)). The "lodestar method" of calculating the reasonable fee contemplates "the number of hours reasonably expended . . . multiplied by a reasonable hourly rate." See Hensley v. Eckerhart, 461 U.S. 424, 433 (1983); Gisbrecht v. Barnhart, 535 U.S. 789, 801 (2002); Perdue v. Kenny A., 130 S.Ct. 1662, 1672 (2010); In re Drexel Burnham Lambert Grp., Inc., 133 B.R. 13 (Bankr. S.D.N.Y. 1991). The factors set forth in Johnson and In re First Colonial Corp. of Am., 544 F.2d 1291, 1298–99 (5th Cir. 1977) have been adopted by most courts.5 See In re Nine Assocs., Inc., 76 B.R. 943, 945 (S.D.N.Y. 1987) (adopting First Colonial/Johnson analysis); In re Cuisine Magazine, Inc., 61 B.R. 210, 212–13 (Bankr. S.D.N.Y 1986) (same); Green v. City of New York, 403 F. Appx. 626, 629 (2d Cir. 2010) (summary order); see generally 3 COLLIER ON BANKRUPTCY ¶ 330.03[9] (Lawrence P. King ed., 16th ed. 2016) (describing First Colonial and Johnson as the "leading cases with regard to the factors to be considered in determining a reasonable allowance of compensation").

28. In accordance with the factors enumerated in section 330 of the Bankruptcy Code and applicable case law, the amount requested herein by Pallas is fair and reasonable.

29. No agreement or understanding exists between Pallas and any other person for the sharing of compensation received or to be received for services rendered in or in connection with this matter. Pallas will not, in any form or guise, share or agree to share compensation for services with any person, nor will Pallas share in the compensation for any other person

5 The factors articulated in First Colonial were first articulated by the Fifth Circuit in Johnson, with the First Colonial court adding the factor of the "spirit of economy," which was later rejected by Congress. See Stroock & Stroock & Lavan v. Hillsborough Holdings Corp. (In re Hillsborough Holdings Corp.), 127 F.3d 1398, 1403 (11th Cir. 1997).

rendering service in these cases, except as so provided by Section 504(b) of the Bankruptcy Code and Rule 2016 of the Bankruptcy Rules.

30. To the extent that time or disbursement charges for services rendered or expenses incurred during the Application Period are not included in this Application, or Pallas has for any reason not sought compensation or reimbursement with respect to such services, Pallas reserves the right to request compensation and reimbursement for such services in a supplemental or future application in these chapter 11 cases. Also, Pallas does not waive, and expressly reserves, its right to respond to any objections regarding this Application and the amounts sought for services rendered and expenses incurred.

31. No previous request for the relief sought herein has been made to this Court or any other court.

[THE REMAINDER OF THIS PAGE IS INTENTIONALLY BLANK.]

WHEREFORE, Pallas respectfully requests entry of an order, substantially in the form attached hereto, (i) allowing interim compensation for professional services rendered during the Application Period in the amount of \$318,591.50 and reimbursement of \$4,953.04 in expenses, (ii) authorizing and directing prompt payment of the unpaid fees in the amount of \$323,544.54 from the estates, (iii) allowing such compensation and payment for professional services rendered without prejudice to Pallas' right to seek further compensation and/or payment from the estates for the full value of services performed and expenses incurred, and (iv) granting Pallas such other and further relief as is just.

Dated: December 27, 2023 London, United Kingdom

Natasha Harrison PALLAS PARTNERS LLP 1 King William Street London, EC4N 7AF United Kingdom Telephone: +44 20 4574 1001 Email: natasha.harrison@pallasllp.com

United Kingdom Solicitor to Luc A. Despins, Chapter 11 Trustee IN THE UNITED STATES BANKRUPTCY COURT FOR THE DISTRICT OF CONNECTICUT BRIDGEPORT DIVISION

In re:

The undersigned hereby certifies that on December 27, 2023, the *First Interim Application of Pallas Partners LLP, as Solicitors in United Kingdom, for Compensation and Reimbursement of Expenses for the Period from January 26, 2023 through November 30, 2023* (the "Application")2 was electronically filed. Notice of this filing was sent by e-mail to all parties to the above-captioned Chapter 11 Cases by operation of the Court's electronic filing ("CM/ECF") system or by mail to anyone unable to accept electronic filing as indicated on the Notice of Electronic Filing.3 In addition, to the extent not covered by the foregoing, copies of the Application were served on the twenty (20) largest creditors in the Debtors' chapter 11 cases. Parties may access this filing through the Court's CM/ECF system.

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 used but not defined in this Certification shall have the meanings ascribed to them in the Application.

3 To the extent that the foregoing was filed outside regular business hours, service by mail on recipients unable or not qualified to accept electronic notice was made on the next business day.

G. Alexander Bongartz (pro hac vice) Douglass Barron (pro hac vice) PAUL HASTINGS LLP 200 Park Avenue New York, New York 10166 (212) 318-6079 douglassbarron@paulhastings.com

Case 22-50073 Doc 2475 Filed 12/27/23 Entered 12/27/23 16:57:35 Page 14 of 64

UNITED STATES BANKRUPTCY COURT DISTRICT OF CONNECTICUT BRIDGEPORT DIVISION

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In re: : :

HO WAN KWOK, et al., : :

Debtors.1 : :

**[PROPOSED] ORDER GRANTING FIRST INTERIM FEE APPLICATION OF PALLAS PARTNERS LLP, AS SOLICITORS IN UNITED KINGDOM, FOR COMPENSATION AND REIMBURSEMENT OF EXPENSES FOR PERIOD FROM JANUARY 26, 2023 THROUGH NOVEMBER 30, 2023**

Upon consideration of the Application (the "Application") of Pallas Partners LLP

("Pallas") as solicitor in the United Kingdom to the Trustee2 for interim allowance of

compensation and reimbursement of expenses from January 26, 2023 through November 30,

2023; and sufficient notice having been given; and a hearing having been held on \_\_\_\_\_\_\_\_,

2023 and due consideration having been given to any responses thereto; and sufficient cause

having been shown therefor, it is hereby:

1. ORDERED that the Application is granted and compensation in the amount of

\$318,591.50 and reimbursement of expenses in the amount of \$4,953.04 are awarded to Pallas,

subject to final adjustment and disgorgement in the event all administrative expenses are not paid

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 adopt the definitions set forth in the Application.

2. ORDERED that nothing herein modified the Retention Order; it is further

3. ORDERED that the estates are authorized and directed to pay Pallas' fees and expenses in the aggregate amount of \$323,544.54, within fourteen days of the date of this Order; it is further

4. ORDERED that this Court shall retain jurisdiction to hear and determine all matters arising from the implementation of this Order; it is further

5. ORDERED that the Debtors' estates and Pallas are authorized and empowered to take all necessary actions to implement the relief granted in this Order; it is further

6. ORDERED that notwithstanding the possible applicability of Bankruptcy Rules 6006(d), 7062, 9014, or otherwise, the terms and conditions of this Order shall be immediately effective and enforceable upon its entry; and it is further

7. ORDERED that all time periods set forth in this Order shall be calculated in accordance with Bankruptcy Rule 9006(a).

Case 22-50073 Doc 2475 Filed 12/27/23 Entered 12/27/23 16:57:35 Page 17 of 64

TIMEKEEPER DATE OF TITLE HOURS HOURLY TOTAL

Natasha Harrison 2005 Partner 31.20 \$1,650.00 \$51,480.00 Neil Pigott 1992 Partner 3.80 \$1,080.00 \$4,104.00 Alessia De Quincey 2015 Associate 251.90 \$980.00 \$246,862.00 Rachel Ong 2019 Associate 1.20 \$870.00 \$1,044.00 Joseph Fox Davies 2022 Associate 7.20 \$730.00 \$5,256.00 Rihab El-Hussain Paralegal 3.50 \$415.00 \$1,452.50 Chloe Salter Paralegal 19.40 \$395.00 \$7,663.00

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Case 22-50073 Doc 2475 Filed 12/27/23 Entered 12/27/23 16:57:35 Page 20 of 64

Tel: +44 (0)204 574 1000 accounts@pallasllp.com www.pallasllp.com

Luc Despins 200 Park Avenue New York NY 10166 United States of America

Invoice Date: 31 October 2023 Our VAT No: 391 1218 14 Our Ref: 0001\16126.0001 Invoice No: 1853 Luc Despins in his capacity as Ch 11 Trustee of an individual Ho Wan Kwok for the period 24 January 2023 to 25 May 2023

Professional Charges 0.00 0.00 87,380.50

Counsel fees – (Unpaid) 0.00 0.00 3,363.08 Court Costs-Filing Fees 0.00 0.00 13.00

Case 22-50073 Doc 2475 Filed 12/27/23 Entered 12/27/23 16:57:35 Page 21 of 64

Matter Name: Luc Despins in his capacity as Ch 11 Trustee of an individual Ho Wan Kwok

Invoice Period: 24 January 2023 to 25 May 2023

Fee Earner Title Time (hrs) Rate (\$) Value (\$) Natasha Harrison Managing 12.70 1,650.00 20,955.00

Alessia de Quincey Associate 67.40 980.00 66,052.00 Rihab El-Hussain Paralegal 0.90 415.00 373.50

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Client Name:

Matter Name: Luc Despins in his capacity as Ch 11 Trustee of an individual Ho Wan Kwok Client/Matter Number:

Invoice Period:

Invoice No:

Date Fee Earner Description Time (hrs) Value (\$) 26-Jan-23 Natasha Harrison Prepare for and attend meeting on new

26-Jan-23 Alessia de Quincey Preparing for and attending calls with

internal emails (0.7); attention to draft letter for Harcus Parker (0.6);

costs and summary of same (0.7). 7.80 7,644.00 27-Jan-23 Natasha Harrison Prepare for and attend telecon. 0.50 825.00 27-Jan-23 Alessia de Quincey Further attention to attendance notes

for and attending client call (0.8);

(0.5); further attention to Harcus Parker

30-Jan-23 Alessia de Quincey Attention to letter from Harcus Parker

31-Jan-23 Natasha Harrison Prepare for and attend zoom meeting with client (0.6); office con with Alessia re: draft letter and next steps (0.3); attention to strategy (0.4); attention to inter partes email (0.1); advise on 2.70 4,455.00

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internally(0.1).

31-Jan-23 Alessia de Quincey Preparing for and attending call with

drafting response on same (0.8); attention to meeting record (0.6);

Harcus Parker correspondence (0.5);

same (0.5); attention to draft letter for

01-Feb-23 Natasha Harrison Attention to emails in/out and inter

01-Feb-23 Alessia de Quincey Attention to next steps and strategy

emails with client and counsel (0.3). 2.40 2,352.00 01-Feb-23 Alessia de Quincey Attention to next steps and strategy

emails with client and counsel (0.2). 2.40 2,352.00 02-Feb-23 Natasha Harrison Attention to revised draft letter to the Court of Appeal (0.2); attention to cover

02-Feb-23 Alessia de Quincey Preparing for and attending call with counsel (0.9); attention to draft letter for Court and client input (0.8); attention to further calls and emails on same (0.7). 2.40 2,352.00 03-Feb-23 Alessia de Quincey Attention to matter opening (0.3);

and emails on same with client (1.6). 3.40 3,332.00 04-Feb-23 Alessia de Quincey Attention to client emails 0.20 196.00

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05-Feb-23 Natasha Harrison Attention to attendance notes (0.4); emails in/out w. Alessia (0.3). 0.70 1,155.00

05-Feb-23 Alessia de Quincey Attention to attendance notes and

06-Feb-23 Alessia de Quincey Attention to matter opening and emails

07-Feb-23 Alessia de Quincey Attention to client emails and next

08-Feb-23 Alessia de Quincey Attention to Court of Appeal case (4.8); attention to summary of hearing (0.7);

emails on next steps (0.3). 5.80 5,684.00 09-Feb-23 Natasha Harrison Attention to letter from UBS (0.2);

09-Feb-23 Alessia de Quincey Attention to UBS letter (0.2); attention to next steps and strategy (0.6);

(0.9); attention to internal queries (0.5);

10-Feb-23 Alessia de Quincey Attention to Paul Hastings declaration

13-Feb-23 Alessia de Quincey Attention to conflicts declaration matters and engagement letter logistics 0.60 588.00 14-Feb-23 Alessia de Quincey Attention to call with compliance re declaration and attention to same (0.9);

15-Feb-23 Alessia de Quincey Attention to declaration for Paul Hastings and email on same. 0.50 490.00 17-Feb-23 Alessia de Quincey Attention to declaration and emails on

19-Feb-23 Alessia de Quincey Attention to emails with Paul Hastings 0.10 98.00 22-Feb-23 Alessia de Quincey Attention to declaration matters 0.40 392.00 23-Feb-23 Alessia de Quincey Attention to declarations and

Hastings regarding declarations and 1.80 1,764.00

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24-Feb-23 Alessia de Quincey Attention to declarations (0.5);

(0.8); finalising review (0.6); attention to

27-Feb-23 Alessia de Quincey Preparing for and attending call with S.

declaration and emails on same (0.6) 1.40 1,372.00 28-Feb-23 Natasha Harrison Attention to Declaration. 0.50 825.00 28-Feb-23 Alessia de Quincey Attention to declaration and internal

02-Mar-23 Alessia de Quincey Attention to declaration and emails on

ruling and emails on same (0.9) 1.30 1,274.00 03-Mar-23 Alessia de Quincey Attention to emails (0.1); attention to

05-Mar-23 Natasha Harrison Attention to correspondence from HSF

06-Mar-23 Natasha Harrison Prepare for and attend call with client. 0.50 825.00 06-Mar-23 Alessia de Quincey Preparing for and attending call with

07-Mar-23 Natasha Harrison Attention to draft letter to HSF (0.3);

07-Mar-23 Alessia de Quincey Attention to finalising HSF letter (1.0);

07-Mar-23 Rihab El-Hussain Compiling client documents. 0.50 207.50 08-Mar-23 Alessia de Quincey Attention to client follow-up requests on main claim and advice on same 1.60 1,568.00 08-Mar-23 Alessia de Quincey Attention to client query and liaising

attention to prior merits advice (0.5) 0.90 882.00 09-Mar-23 Alessia de Quincey Attention to emails with counsel and

(1.0); attention to declaration conflicts updates and emails on same (0.4). 1.40 1,372.00

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10-Mar-23 Natasha Harrison Attention to draft letter (0.3); emails

10-Mar-23 Alessia de Quincey Attention to client correspondence

14-Mar-23 Alessia de Quincey Attention to client emails on next steps 0.20 196.00 16-Mar-23 Natasha Harrison Attention to inter partes

email from Alessia de Quincey (0.1);

16-Mar-23 Alessia de Quincey Attention to case updates and next

16-Mar-23 Rihab El-Hussain Analysing and compiling recent

17-Mar-23 Alessia de Quincey Attention to client follow-up queries and correspondence on next steps 0.50 490.00 20-Mar-23 Natasha Harrison Attend call with client and Paul

22-Mar-23 Alessia de Quincey Attention to client strategy note and

23-Mar-23 Alessia de Quincey Call with P. Wright on strategy and updating documents on same (0.7); internal emails on next steps (0.3). 1.00 980.00 27-Mar-23 Natasha Harrison Attention to letter from HSF (0.2); attention to draft response (0.2);

relation to the same (0.1). 0.80 1,320.00 27-Mar-23 Alessia de Quincey Attention to next steps and correspondence with client (0.2);

edits to HSF response (0.4) 0.60 588.00 28-Mar-23 Alessia de Quincey Attention to without prejudice query

29-Mar-23 Alessia de Quincey Attention to client emails 0.20 196.00 29-Mar-23 Alessia de Quincey Attention to client requests and emails 0.30 294.00

Case 22-50073 Doc 2475 Filed 12/27/23 Entered 12/27/23 16:57:35 Page 27 of 64

Matter Name: Luc Despins in his capacity as Ch 11 Trustee of an individual Ho Wan Kwok

Invoice Period: 24 January 2023 to 25 May 2023

Date Disbursement Description Value (\$) 14-Mar-23 Court Costs-Filing Fees Vendor: HM Courts & Tribunals 13.00 Service; Invoice#: 816096; Date:

Counsel fees Vendor: Wright, Paul; Invoice#: 2,919.79 85824_24/01/23-09/03/23; Date:

28-Mar-23 Counsel fees Vendor: Wright, Paul; Invoice#: 260.06

04-May-23 Counsel fees Vendor: Wright, Paul; Invoice#: 94.57

09-May-23 Counsel fees Vendor: Wright, Paul; Invoice#: 88.66

Case 22-50073 Doc 2475 Filed 12/27/23 Entered 12/27/23 16:57:35 Page 28 of 64

Tel: +44 (0)204 574 1000 accounts@pallasllp.com www.pallasllp.com

Luc Despins 200 Park Avenue New York NY 10166 United States of America

Invoice Date: 25 May 2023 Our VAT No: 391 1218 14 Our Ref: 0001\16126.0001 Invoice No: 1591

Luc Despins in his capacity as Ch 11 Trustee of an individual Ho Wan Kwok for the period 02 April 2023 to 30 April 2023

Professional Charges 0.00 0.00 15,298.00

Counsel fees – (Unpaid) 0.00 0.00 60.00

Case 22-50073 Doc 2475 Filed 12/27/23 Entered 12/27/23 16:57:35 Page 29 of 64

Matter Name: Luc Despins in his capacity as Ch 11 Trustee of an individual Ho Wan Kwok

Invoice Period: 02 April 2023 to 30 April 2023

Fee Earner Title Time (hrs) Rate (\$) Value (\$) Natasha Harrison Managing 2.90 1,650.00 4,785.00

Alessia de Quincey Associate 8.90 980.00 8,722.00 Rachel Ong Associate 1.20 870.00 1,044.00 Rihab El-Hussain Paralegal 1.80 415.00 747.00

Case 22-50073 Doc 2475 Filed 12/27/23 Entered 12/27/23 16:57:35 Page 30 of 64

Matter Name: Luc Despins in his capacity as Ch 11 Trustee of an individual Ho Wan Kwok

Invoice Period: Invoice No: 1591 02 April 2023 to 30 April 2023

Fee Earner Description Time (hrs) Value (\$) 02-Apr-23 Natasha Harrison Attention to development (0.2); attention to emails in/out with client and

03-Apr-23 Alessia de Quincey Attention to emails 0.20 196.00 04-Apr-23 Natasha Harrison Prepare for and attend call with client

04-Apr-23 Alessia de Quincey Attention to client call and next steps 0.80 784.00 04-Apr-23 Rihab El-Hussain Locating and compiling relevant court

05-Apr-23 Alessia de Quincey Attention to latest Harcus Parker

05-Apr-23 Rihab El-Hussain Call with the Court for access to a

05-Apr-23 Rihab El-Hussain Analysing and compiling court of

06-Apr-23 Natasha Harrison Prepare for and attend call with client (0.6); liaise internally; attention to follow

06-Apr-23 Alessia de Quincey Preparing for and attending client

12-Apr-23 Alessia de Quincey Attention to latest Harcus Parker correspondence and emails on same. 1.00 980.00 20-Apr-23 Natasha Harrison Review memo (0.4); email in/out with

20-Apr-23 Alessia de Quincey Attention to updating advice and emails

21-Apr-23 Alessia de Quincey Attention to latest Harcus Parker correspondence and emails on same 0.50 490.00 24-Apr-23 Alessia de Quincey Attention to client emails and next

Case 22-50073 Doc 2475 Filed 12/27/23 Entered 12/27/23 16:57:35 Page 31 of 64

26-Apr-23 Natasha Harrison Prepare for and attend update call. 0.50 825.00 26-Apr-23 Alessia de Quincey (0.5) Attention to emails (0.2); attention to client queries on enforcement of order 0.70 686.00 26-Apr-23 Rachel Ong order in the UK. Consider enforceability of US court 1.20 1,044.00

Case 22-50073 Doc 2475 Filed 12/27/23 Entered 12/27/23 16:57:35 Page 32 of 64

Client Name: Despins, Luc Matter Name: Luc Despins in his capacity as Ch 11 Trustee of an individual Ho Wan Kwok Client/Matter Number: 16126.0001 Invoice Period: 02 April 2023 to 30 April 2023 Invoice No: 1591 Date Disbursement Description Value (\$)

18-Apr-23 Counsel fees Vendor: Wright, Paul; Invoice#: 70.93

Case 22-50073 Doc 2475 Filed 12/27/23 Entered 12/27/23 16:57:35 Page 33 of 64

Tel: +44 (0)204 574 1000 accounts@pallasllp.com www.pallasllp.com

200 Park Avenue Our VAT No: 391 1218 14

Luc Despins in his capacity as Ch 11 Trustee of an individual Ho Wan Kwok for the period 03 May 2023 to 31 May 2023

Professional Charges 0.00 0.00 28,517.00

Case 22-50073 Doc 2475 Filed 12/27/23 Entered 12/27/23 16:57:35 Page 34 of 64

Matter Name: Luc Despins in his capacity as Ch 11 Trustee of an individual Ho Wan Kwok

Invoice Period: 03 May 2023 to 31 May 2023

Fee Earner Title Time (hrs) Rate (\$) Value (\$) Natasha Harrison Managing 2.30 1,650.00 3,795.00

Neil Pigott Partner 3.80 1,080.00 4,104.00 Alessia de Quincey Associate 20.70 980.00 20,286.00 Rihab El-Hussain Paralegal 0.80 415.00 332.00

Case 22-50073 Doc 2475 Filed 12/27/23 Entered 12/27/23 16:57:35 Page 35 of 64

Matter Name: Luc Despins in his capacity as Ch 11 Trustee of an individual Ho Wan Kwok

Invoice Period: 03 May 2023 to 31 May 2023

Date Fee Earner Description Time (hrs) Value (\$) 03-May-23 Alessia de Quincey Attention to emails with client (0.2);

letter for Harcus Parker (1.2); attention to emails with counsel (0.3). 1.70 1,666.00 04-May-23 Alessia de Quincey Attention to correspondence with

05-May-23 Alessia de Quincey attention to further emails and HP letter 0.70 686.00 05-May-23 Rihab El-Hussain Compiling notice and letter for filing. 0.50 207.50 06-May-23 Alessia de Quincey Attention to internal emails 0.20 196.00 07-May-23 Alessia de Quincey attention to internal emails on HP letter

08-May-23 Alessia de Quincey Attention to finalising HP letter and

09-May-23 Alessia de Quincey Attention to circulation of HP letter and

09-May-23 Rihab El-Hussain Notice and correspondence

11-May-23 Alessia de Quincey attention to HP response and emails on

12-May-23 Alessia de Quincey ongoing attention to HP response and

18-May-23 Alessia de Quincey Attention to client query on Ace Decade issue and emails on same 0.40 392.00 19-May-23 Alessia de Quincey Attention to emails with P. Wright and internal team on next steps 0.30 294.00 22-May-23 Neil Pigott Review of CBIR question (0.2); review

application (0.8); consideration of 2.00 2,160.00

Case 22-50073 Doc 2475 Filed 12/27/23 Entered 12/27/23 16:57:35 Page 36 of 64

points with A De Quincey (0.5).

22-May-23 Alessia de Quincey Attention to briefing N. Pigott (0.6); attention to calls with N. Pigott (1.0);

23-May-23 Natasha Harrison Attention to legal analysis re:

23-May-23 Neil Pigott Review of analysis summary (0.1);

Quincey (1.0); call with client (0.4). 1.80 1,944.00 23-May-23 Alessia de Quincey Attention to assessment of recognition

attending client call (0.6); attention to

24-May-23 Alessia de Quincey Attention to correspondence with Harcus Parker and Herbert Smith (1.0);

25-May-23 Alessia de Quincey Attention to strategy and next steps

(1.3); attention to call with N. Harrison

26-May-23 Alessia de Quincey Attention to HP and HSF letters (0.4);

27-May-23 Alessia de Quincey Attention to HP correspondence and

30-May-23 Natasha Harrison Prep and attend call with Luc Despins

(0.2); liaise internally (0.1) 1.00 1,650.00

Case 22-50073 Doc 2475 Filed 12/27/23 Entered 12/27/23 16:57:35 Page 37 of 64

Tel: +44 (0)204 574 1000 accounts@pallasllp.com www.pallasllp.com

Luc Despins 200 Park Avenue New York NY 10166 United States of America

Invoice Date: 10 July 2023 Our VAT No: 391 1218 14 Our Ref: 0001\16126.0001 Invoice No: 1658

Luc Despins in his capacity as Ch 11 Trustee of an individual Ho Wan Kwok for the period 01 June 2023 to 30 June 2023

Professional Charges 0.00 0.00 11,352.00

Case 22-50073 Doc 2475 Filed 12/27/23 Entered 12/27/23 16:57:35 Page 38 of 64

Alessia de Quincey Associate 9.90 980.00 9,702.00

Fee Earner Title Time (hrs) Rate (\$) Value (\$)

Invoice Period: 01 June 2023 to 30 June 2023

Matter Name: Luc Despins in his capacity as Ch 11 Trustee of an individual Ho Wan Kwok

Case 22-50073 Doc 2475 Filed 12/27/23 Entered 12/27/23 16:57:35 Page 39 of 64

Client Name: Matter Name: Client/Matter Number: Invoice Period:

Luc Despins in his capacity as Ch 11 Trustee of an individual Ho Wan Kwok

Date Fee Earner Description Time (hrs) Value (\$) 01-Jun-23 Alessia de Quincey Attention to draft letter to HP seeking a stay and emails on next steps (1.2); attention to emails with client (0.2);

04-Jun-23 Alessia de Quincey Attention to HSF correspondence,

05-Jun-23 Alessia de Quincey Attention to client and internal emails

06-Jun-23 Alessia de Quincey Attention to HP letter to HSF on

(0.2); attention to placeholder email for

07-Jun-23 Alessia de Quincey Attention to emails and proposed next steps(0.3); attention to conflicts matters

08-Jun-23 Alessia de Quincey Correspondence with client and

HSF and emails on same (0.2); attention to conflict declaration matters

13-Jun-23 Alessia de Quincey Attention to next steps and emails 0.50 490.00 19-Jun-23 Alessia de Quincey Attention to client correspondence and inter partes correspondence. 0.60 588.00 20-Jun-23 Natasha Harrison Prep and attend call with client (0.7);

20-Jun-23 Alessia de Quincey Preparing for and attending client call

Alessia de Quincey Attention to Notice of Change and inter

Alessia de Quincey Attention to emails on next steps 0.30 294.00

Alessia de Quincey Attention to call with Harcus Parker on

Alessia de Quincey Attention to emails and latest news 0.20 196.00

Case 22-50073 Doc 2475 Filed 12/27/23 Entered 12/27/23 16:57:35 Page 41 of 64

Tel: +44 (0)204 574 1000 accounts@pallasllp.com www.pallasllp.com

Luc Despins 200 Park Avenue New York NY 10166 United States of America

Invoice Date: 14 August 2023 Our VAT No: 391 1218 14 Our Ref: 0001\16126.0001 Invoice No: 1720

Luc Despins in his capacity as Ch 11 Trustee of an individual Ho Wan Kwok for the period 03 July 2023 to 31 July 2023

Professional Charges 0.00 0.00 17,133.00

Case 22-50073 Doc 2475 Filed 12/27/23 Entered 12/27/23 16:57:35 Page 42 of 64

Matter Name: Luc Despins in his capacity as Ch 11 Trustee of an individual Ho Wan Kwok

Invoice Period: 03 July 2023 to 31 July 2023

Fee Earner Title Time (hrs) Rate (\$) Value (\$)

Alessia de Quincey Associate 12.60 980.00 12,348.00

Case 22-50073 Doc 2475 Filed 12/27/23 Entered 12/27/23 16:57:35 Page 43 of 64

Matter Name: Luc Despins in his capacity as Ch 11 Trustee of an individual Ho Wan Kwok

Invoice Period: 03 July 2023 to 31 July 2023

Date Fee Earner Description Time (hrs) Value (\$) 03-Jul-23 Alessia de Quincey Attention to Notice of change related

04-Jul-23 Natasha Harrison Briefing call with ADH re next steps. 0.50 825.00 04-Jul-23 Alessia de Quincey Attention to correspondence and letter to Court on Notice of Change 1.40 1,372.00 05-Jul-23 Alessia de Quincey Attention to interpartes correspondence including Court correspondence 0.40 392.00 07-Jul-23 Alessia de Quincey Attention to HSF and client

10-Jul-23 Alessia de Quincey attention to emails on next steps and

11-Jul-23 Alessia de Quincey Attention to WP scheduling (0.2);

13-Jul-23 Natasha Harrison Pre-call meeting with client (0.5); WP

13-Jul-23 Alessia de Quincey attention to WP speaking notes (0.3);

call (1.0); attention to next steps (0.2); attention to steps plan (0.5) 2.50 2,450.00 14-Jul-23 Natasha Harrison Attention to strategy (0.2); attention to

14-Jul-23 Alessia de Quincey Finalising steps plan and

17-Jul-23 Alessia de Quincey Attention to emails and WP

20-Jul-23 Alessia de Quincey Attention to Ace Decade query and

to call with counsel (0.4) 1.20 1,176.00 21-Jul-23 Natasha Harrison Attention to correspondence from HSF (0.1); attention to email from AdQ re: enforcement (0.1); email to L Despins 0.50 825.00

Case 22-50073 Doc 2475 Filed 12/27/23 Entered 12/27/23 16:57:35 Page 44 of 64

(0.1); attention to analysis and strategy

23-Jul-23 Alessia de Quincey Attention to emails with client on Ace

24-Jul-23 Alessia de Quincey attention to correspondence with HSF

25-Jul-23 Alessia de Quincey attention to HSF WP correspondence and emails with client (0.4); attention to

26-Jul-23 Alessia de Quincey attention to stay letter (0.9); attention to HP correspondence on extension (0.3); attention to client emails (0.1) 1.30 1,274.00 27-Jul-23 Alessia de Quincey Attention to draft correspondence with

31-Jul-23 Alessia de Quincey Attention to consent order

Case 22-50073 Doc 2475 Filed 12/27/23 Entered 12/27/23 16:57:35 Page 45 of 64

Tel: +44 (0)204 574 1000 accounts@pallasllp.com www.pallasllp.com

Luc Despins 200 Park Avenue New York NY 10166 United States of America

Invoice Date: 31 October 2023 Our VAT No: 391 1218 14 Our Ref: 0001\16126.0001 Invoice No: 1854 Luc Despins in his capacity as Ch 11 Trustee of an individual Ho Wan Kwok for the period 03 August 2023 to 31 August 2023

Court Costs-Filing Fees 0.00 0.00 11.00

Case 22-50073 Doc 2475 Filed 12/27/23 Entered 12/27/23 16:57:35 Page 46 of 64

Matter Name: Luc Despins in his capacity as Ch 11 Trustee of an individual Ho Wan Kwok

Invoice Period: 03 August 2023 to 31 August 2023

Fee Earner Title Time (hrs) Rate (\$) Value (\$) Alessia de Quincey Associate 11.00 980.00 10,780.00

Chloe Salter Paralegal 3.50 395.00 1,382.50

Case 22-50073 Doc 2475 Filed 12/27/23 Entered 12/27/23 16:57:35 Page 47 of 64

Client Name: Matter Name: Client/Matter Number: Invoice Period:

Luc Despins in his capacity as Ch 11 Trustee of an individual Ho Wan Kwok

Date Fee Earner Description Time (hrs) Value (\$) 03-Aug-23 Alessia de Quincey Attention to HP correspondence re security for costs and emails with client

07-Aug-23 Alessia de Quincey Attention to correspondence with HSF

client emails and HP letter re stay (0.4); attention to updating steps plan (0.2) 1.00 980.00 14-Aug-23 Alessia de Quincey Attention to HP response and strategy

and initial draft response (1.0) 1.70 1,666.00 15-Aug-23 Alessia de Quincey Attention to Lalive correspondence and

finalising draft response to HP (0.3) 1.40 1,372.00 16-Aug-23 Alessia de Quincey Attention to draft consent order and

16-Aug-23 Chloe Salter Download and rename of all orders on

17-Aug-23 Alessia de Quincey Attention to inter partes

18-Aug-23 Alessia de Quincey Attention to HSF correspondence and

21-Aug-23 Alessia de Quincey Attention to updated consent order and

22-Aug-23 Alessia de Quincey Attention to correspondence with client

23-Aug-23 Alessia de Quincey Attention to HSF correspondence and edits to consent order (0.5); attention to

Case 22-50073 Doc 2475 Filed 12/27/23 Entered 12/27/23 16:57:35 Page 48 of 64

24-Aug-23 Alessia de Quincey emails. (0.4) Attention to correspondence to Harcus Parker and HSF (1.3); attention to 1.70 1,666.00 25-Aug-23 Alessia de Quincey emails on same Attention to invoicing queries and 0.20 196.00 29-Aug-23 Alessia de Quincey Attention to latest inter partes correspondence and emails on same 0.30 294.00

Case 22-50073 Doc 2475 Filed 12/27/23 Entered 12/27/23 16:57:35 Page 49 of 64

Matter Name: Luc Despins in his capacity as Ch 11 Trustee of an individual Ho Wan Kwok

Invoice Period: 03 August 2023 to 31 August 2023

Date Disbursement Description Value (\$) 28-Apr-23 Court Costs-Filing Fees Vendor: Coutts Commercial Card; 13.00 Invoice#: 20230428-LP; Date:

Case 22-50073 Doc 2475 Filed 12/27/23 Entered 12/27/23 16:57:35 Page 50 of 64

Tel: +44 (0)204 574 1000 accounts@pallasllp.com www.pallasllp.com

Luc Despins 200 Park Avenue New York NY 10166 United States of America

Invoice Date: 31 October 2023 Our VAT No: 391 1218 14 Our Ref: 0001\16126.0001 Invoice No: 1855 Luc Despins in his capacity as Ch 11 Trustee of an individual Ho Wan Kwok for the period 31 August 2023 to 30 September 2023

Professional Charges 0.00 0.00 12,698.00

Case 22-50073 Doc 2475 Filed 12/27/23 Entered 12/27/23 16:57:35 Page 51 of 64

Matter Name: Luc Despins in his capacity as Ch 11 Trustee of an individual Ho Wan Kwok

Invoice Period: 31 August 2023 to 30 September 2023

Fee Earner Title Time (hrs) Rate (\$) Value (\$)

Alessia de Quincey Associate 10.60 980.00 10,388.00

Case 22-50073 Doc 2475 Filed 12/27/23 Entered 12/27/23 16:57:35 Page 52 of 64

Matter Name: Luc Despins in his capacity as Ch 11 Trustee of an individual Ho Wan Kwok

Invoice Period: Invoice No: 1855 31 August 2023 to 30 September 2023 Date Fee Earner Description Time (hrs) Value (\$) 31-Aug-23 Alessia de Quincey Attention to inter partes 0.50 490.00

(0.4); attention to next steps (0.1). 01-Sep-23 Alessia de Quincey Attention to HP correspondence and

04-Sep-23 Alessia de Quincey Attention to client emails and draft

05-Sep-23 Alessia de Quincey Attention to client correspondence and

discussions on next steps (0.6);

06-Sep-23 Alessia de Quincey Revisions to letter and attention to

11-Sep-23 Natasha Harrison Catch up with AQ 0.50 825.00 19-Sep-23 Alessia de Quincey Attention to emails and inter parties

20-Sep-23 Natasha Harrison Prep and attend call with Luc Despins (0.3); liaise internally (0.2) 0.50 825.00 20-Sep-23 Alessia de Quincey Preparing for and attention to call with

20-Sep-23 Alessia de Quincey Preparing for and attending client call 0.30 294.00 20-Sep-23 Alessia de Quincey Attention to emails with N. Harrison

22-Sep-23 Natasha Harrison Inter partes correspondence (0.3);

23-Sep-23 Alessia de Quincey Attention to emails 0.20 196.00 25-Sep-23 Alessia de Quincey Attention to correspondence with

27-Sep-23 Alessia de Quincey Attention to client correspondence 0.10 98.00 27-Sep-23 Alessia de Quincey Attention to background documents

Case 22-50073 Doc 2475 Filed 12/27/23 Entered 12/27/23 16:57:35 Page 53 of 64

28-Sep-23 Alessia de Quincey Attention to background documents 2.60 2,548.00 28-Sep-23 Alessia de Quincey Attention to inter partes

28-Sep-23 Alessia de Quincey same Attention to internal discussions on next steps and correspondence on 0.30 294.00

Case 22-50073 Doc 2475 Filed 12/27/23 Entered 12/27/23 16:57:35 Page 54 of 64

Tel: +44 (0)204 574 1000 accounts@pallasllp.com www.pallasllp.com

Luc Despins 200 Park Avenue New York NY 10166 United States of America

Invoice Date: 30 November 2023 Our VAT No: 391 1218 14 Our Ref: 0001\16126.0001 Invoice No: 1902 Luc Despins in his capacity as Ch 11 Trustee of an individual Ho Wan Kwok for the period 11 September 2023 to 31 October 2023

Case 22-50073 Doc 2475 Filed 12/27/23 Entered 12/27/23 16:57:35 Page 55 of 64

Matter Name: Luc Despins in his capacity as Ch 11 Trustee of an individual Ho Wan Kwok

Invoice Period: 11 September 2023 to 31 October 2023

Fee Earner Title Time (hrs) Rate (\$) Value (\$) Natasha Harrison Managing 6.10 1,650.00 10,065.00

Alessia de Quincey Associate 77.60 980.00 76,048.00 Joseph Fox-Davies 6.70 730.00 4,891.00

Case 22-50073 Doc 2475 Filed 12/27/23 Entered 12/27/23 16:57:35 Page 56 of 64

Client Name: Despins, Luc Matter Name: Luc Despins in his capacity as Ch 11 Trustee of an individual Ho Wan Kwok Client/Matter Number: 16126.0001 Invoice Period: 11 September 2023 to 31 October 2023 Invoice No: 1902 Date Fee Earner Description Time (hrs) Value (\$)

11-Sep-23 Alessia de Quincey Attention to inter partes

11-Sep-23 Alessia de Quincey Attention to emails 0.30 294.00 11-Sep-23 Alessia de Quincey Preparing for and attending internal

12-Sep-23 Alessia de Quincey Attention to emails and inter partes

14-Sep-23 Alessia de Quincey Attention to time revisions 1.20 1,176.00 10-Oct-23 Alessia de Quincey Attention to emails 0.20 196.00 10-Oct-23 Alessia de Quincey Attention to review of background documents relevant to stay application 2.20 2,156.00 11-Oct-23 Alessia de Quincey Attention to stay application 3.40 3,332.00 12-Oct-23 Alessia de Quincey Attention to stay application and

13-Oct-23 Alessia de Quincey Attention to stay application and

14-Oct-23 Alessia de Quincey Attention to stay application including

15-Oct-23 Alessia de Quincey Attention to stay application including

16-Oct-23 Natasha Harrison Office conference with AdQ (0.2);

16-Oct-23 Alessia de Quincey Attention to stay application and

incorporation of N. Harrison comments 4.60 4,508.00 16-Oct-23 Alessia de Quincey Finalising documents for client review 1.80 1,764.00 16-Oct-23 Alessia de Quincey Preparing for and attending meeting with N. Harrison on next steps 0.40 392.00 16-Oct-23 Alessia de Quincey Attention to emails 0.30 294.00

Case 22-50073 Doc 2475 Filed 12/27/23 Entered 12/27/23 16:57:35 Page 57 of 64

17-Oct-23 Natasha Harrison Letter from HSF (0.1); consider

17-Oct-23 Alessia de Quincey Attention to correspondence with

17-Oct-23 Chloe Salter Review of NH statement and compilation of index for exhibit 1.90 750.50 18-Oct-23 Alessia de Quincey Attention to correspondence with HSF

attention to stay application (1.0) 2.00 1,960.00 19-Oct-23 Alessia de Quincey Attention to client comments and updating witness statement (2.2);

20-Oct-23 Alessia de Quincey Preparing for and attending call with

incorporation of stay comments(0.8) 5.60 5,488.00 22-Oct-23 Natasha Harrison Attention to draft w/s (0.2); attention to speaking points (0.1); emails in/out with

22-Oct-23 Alessia de Quincey Attention to stay application and further

23-Oct-23 Natasha Harrison Prep call with client and Alessia De Quincey (0.8); call with HSF (0.4) 1.20 1,980.00 23-Oct-23 Alessia de Quincey Preparing for and attending client call

Without Prejudice call (1.0); attention to

order and emails on same (1.0) 4.00 3,920.00

Case 22-50073 Doc 2475 Filed 12/27/23 Entered 12/27/23 16:57:35 Page 58 of 64

24-Oct-23 Natasha Harrison Attention to stay application (0.3);

order (0.3); emails in/out (0.1) 0.70 1,155.00

24-Oct-23 Alessia de Quincey Attention to latest documents from

exhibit on same (2.0); attention to inter

24-Oct-23 Chloe Salter Collation of exhibit NH1 and reference

25-Oct-23 Alessia de Quincey Attention to emails with client (0.4); attention to updated stay application for

26-Oct-23 Alessia de Quincey Attention to inter partes

application matters (0.6) 3.80 3,724.00 26-Oct-23 Chloe Salter Amends to statement and references

27-Oct-23 Natasha Harrison Attention to witness evidence (0.3);

(0.2); attention to draft letter to HP and extension of time to the defence (0.6);

(0.2); further call with AdQ (0.2) 2.40 3,960.00 27-Oct-23 Alessia de Quincey Attention to finalising stay application

sending to Harcus Parker (4.0); attention to emails with client (0.6);

consideration on same (0.5) 5.10 4,998.00 27-Oct-23 Chloe Salter Amends to statement and exhibit

28-Oct-23 Joseph Fox-Davies Stay application: Review witness statement of N. Harrison and Exhibit 3.40 2,482.00

Case 22-50073 Doc 2475 Filed 12/27/23 Entered 12/27/23 16:57:35 Page 59 of 64

NH1 (3.0). Email to A. de Quincey re: same (0.4).

Alessia de Quincey Attention to HSF Defence extension

correspondence and emails (0.5) 2.50 2,450.00 Chloe Salter Amends to exhibit following

Joseph Fox-Davies Call with A. de Quincey re: witness statement and exhibit (0.3). Instructions to C. Salter re: exhibit (0.2). Draft cover

witness statement and exhibit (0.8). Review exhibit amendments (1.0). 3.30 2,409.00 Alessia de Quincey Attention to final stay application

Parker correspondence (0.9) 2.90 2,842.00

Case 22-50073 Doc 2475 Filed 12/27/23 Entered 12/27/23 16:57:35 Page 60 of 64

Tel: +44 (0)204 574 1000 accounts@pallasllp.com www.pallasllp.com

Luc Despins Invoice Date: 18 December 2023

200 Park Avenue Our VAT No: 391 1218 14

United States of America Invoice No: 1946 Luc Despins in his capacity as Ch 11 Trustee of an individual Ho Wan Kwok for the period 01 November 2023 to 30 November 2023

Professional Charges 0.00 0.00 36,766.00

Counsel fees – (Unpaid) 0.00 0.00 1,493.03

Case 22-50073 Doc 2475 Filed 12/27/23 Entered 12/27/23 16:57:35 Page 61 of 64

Matter Name: Luc Despins in his capacity as Ch 11 Trustee of an individual Ho Wan Kwok

Invoice Period: 01 November 2023 to 30 November 2023

Fee Earner Title Time (hrs) Rate (\$) Value (\$)

Alessia de Quincey Associate 33.20 980.00 32,536.00 Joseph Fox-Davies 1.50 730.00 1,095.00

Case 22-50073 Doc 2475 Filed 12/27/23 Entered 12/27/23 16:57:35 Page 62 of 64

Client Name: Matter Name: Client/Matter Number: Invoice Period:

Luc Despins in his capacity as Ch 11 Trustee of an individual Ho Wan Kwok

Date Fee Earner Description Time (hrs) Value (\$) 01-Nov-23 Alessia de Quincey Attention to stay application and emails 2.70 2,646.00 01-Nov-23 Alessia de Quincey Attention to inter partes

01-Nov-23 Alessia de Quincey Attention to UBS and counsel 0.50 490.00 02-Nov-23 Alessia de Quincey Attention to inter partes

02-Nov-23 Alessia de Quincey Attention to internal catch up and next

02-Nov-23 Alessia de Quincey Attention to internal and client emails 0.80 784.00 03-Nov-23 Alessia de Quincey Preparing for and attending call with counsel including notes on strategy 1.60 1,568.00 03-Nov-23 Alessia de Quincey Attention to stay application and inter

03-Nov-23 Alessia de Quincey Attention to emails 0.50 490.00 05-Nov-23 Alessia de Quincey Attention to stay application updates

06-Nov-23 Alessia de Quincey Attention to stay application and inter

07-Nov-23 Alessia de Quincey Attention to strategy and

07-Nov-23 Alessia de Quincey Attention to updating WS based on

08-Nov-23 Alessia de Quincey Attention to inter partes

09-Nov-23 Alessia de Quincey Attention to modified extension application and emails on same 0.30 294.00 09-Nov-23 Alessia de Quincey Attention to client request and update

10-Nov-23 Natasha Harrison Attention to inter partes

Case 22-50073 Doc 2475 Filed 12/27/23 Entered 12/27/23 16:57:35 Page 63 of 64

10-Nov-23 Alessia de Quincey Attention to inter partes correspondence and internal emails 0.80 784.00

11-Nov-23 Alessia de Quincey Attention to interpartes correspondence and client emails and strategy 1.00 980.00 13-Nov-23 Natasha Harrison Attention to stay; (0.2) attention to emails in/out re: HP proposal (0.2);

13-Nov-23 Alessia de Quincey Attention to correspondence and next steps and internal queries. 1.20 1,176.00 14-Nov-23 Alessia de Quincey attention to emails and next steps and

16-Nov-23 Alessia de Quincey Attention to client emails and inter

20-Nov-23 Alessia de Quincey Attention to correspondence and next

22-Nov-23 Alessia de Quincey attention to Court correspondence and

24-Nov-23 Natasha Harrison Inter partes correspondence (0.2); attention to strategy (0.2). 0.40 660.00 24-Nov-23 Alessia de Quincey Attention to correspondence 0.30 294.00 24-Nov-23 Joseph Fox-Davies Review Harcus Parker letter re: stay

26-Nov-23 Alessia de Quincey Attention to ad hoc stay matters and research including strategy 1.00 980.00 27-Nov-23 Natasha Harrison Attention to emails in/out with Despins

counsel, liaise internally (0.3). 0.70 1,155.00 27-Nov-23 Alessia de Quincey further attention to strategy on ad hoc

on same and proposed next steps 1.50 1,470.00 27-Nov-23 Joseph Fox-Davies Review letter and emails with Counsel

28-Nov-23 Alessia de Quincey Attention to draft inter partes

28-Nov-23 Alessia de Quincey Attention to emails 0.20 196.00 30-Nov-23 Alessia de Quincey Attention to emails and inter partes

Case 22-50073 Doc 2475 Filed 12/27/23 Entered 12/27/23 16:57:35 Page 64 of 64

Matter Name: Luc Despins in his capacity as Ch 11 Trustee of an individual Ho Wan Kwok

Invoice Period: 01 November 2023 to 30 November 2023

Date Disbursement Description Value (\$)

Counsel fees Vendor: Wright, Paul; Invoice#: 1,493.03 85824_05/09/23-03/11/23; Date: