Guo Wengui / Miles Guo — bankruptcy case · ORDER · ECF #2555

## **UNITED STATES BANKRUPTCY COURT DISTRICT OF CONNECTICUT**

In re:

HO WAN KWOK, *et al.*, [1](#page-0-0) Chapter 11

Case No. 22-50073 (JAM)

Debtors.

(Jointly Administered)

## **DECLARATION OF LISA J. FRIED IN SUPPORT OF UBS AG'S OBJECTION TO MOTION FOR ENTRY OF ORDER EXTENDING DEADLINE FOR TRUSTEE TO FILE AVOIDANCE ACTIONS UNDER BANKRUPTCY CODE SECTIONS 108, 546(A), AND 549**

I, Lisa J. Fried, declare as follows:

1. I am a partner at Herbert Smith Freehills New York LLP, 450 Lexington Avenue,

New York, New York, 10017, counsel to non-party UBS AG ("UBS") in connection with the

above-captioned bankruptcy proceeding.

2. I submit this declaration in support of UBS's objection to the *Motion for Entry of*

*Order Extending Deadline for Trustee to File Avoidance Actions Under Bankruptcy Code Sections*

*108, 546(a), and 549* [ECF No. 2509], filed by Luc A Despins, in his capacity as the chapter 11

trustee (the "Trustee").

3. In response to a Rule 2004 subpoena dated September 22, 2022 directed to UBS,

as amended on March 7, 2023, UBS produced nearly 17,000 pages of documents to the Trustee.

<span id="page-0-0"></span>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 (collectively, the "Debtors").

UBS completed its production as of November 13, 2023 and submitted a privilege log for the production on October 31, 2023.

Pursuant to 28 U.S.C. § 1746, I declare under penalty of perjury that the foregoing is true and correct.

Dated: February 5, 2024 New York, New York.

Respectfully submitted,

By: */s/ Lisa J. Fried\_\_\_\_\_* Lisa J. Fried (ct31425) HERBERT SMITH FREEHILLS NEW YORK LLP 450 Lexington Avenue New York, New York 10017 lisa.fried@hsf.com

*Counsel for Non-Party UBS*