Guo Wengui / Miles Guo — bankruptcy case · ORDER · ECF #2568-4

| ---------------------------------------------------------------X | | |------------------------------------------------------------------|--| | DISTRICT OF CONNECTICUT | | | UNITED STATES BANKRUPTCY COURT | | | | |

In re: Chapter 11

HO WAN KWOK, Case No. 22-50073 (JAM)

Debtor. ---------------------------------------------------------------X

# **RULE OF LAW SOCIETY IV, INC.'S RESPONSES AND OBJECTIONS TO RULE 2004 SUBPOENA**

Rule of Law Society IV, Inc. ("ROLS"), by its attorneys, the Law Office of

Richard E. Signorelli, hereby responds and objects to the requests for documents set forth in the Fed. R. Bankr. P. 2004 subpoena issued by the Chapter 11 Trustee Luc A. Despins ("Trustee") to ROLS dated August 19, 2022, in connection with the above-captioned matter.

# **GENERAL RESERVATIONS**

The responses herein are based on information and documents presently available to ROLS. If subsequent investigation or preparation reveals additional information or documents with respect to these responses, ROLS expressly reserves the right to later correct, clarify, amend, and supplement these responses.

# **GENERAL OBJECTIONS**

ROLS reserves all objections with respect to competency, relevancy, materiality, and admissibility, as well as the right to interpose additional objections and to move for an appropriate protective order in the event additional investigation and preparation develop further information with respect to any of the responses herein. The responses are without waiver of, or prejudice to, any such objections or rights. ROLS further reserves its rights to object to the use of any responses herein in any subsequent administrative or judicial proceeding.

In addition to the general reservations set forth above and to the specific

#### Case 22-50073 Doc 2568-4 Filed 02/05/24 Entered 02/05/24 16:29:39 Page 2 of 12

objections separately set forth in response to certain document requests, each of the document requests and their responses are subject to the following general objections:

A) ROLS objects to any document request to the extent it is overly broad and/or purports to seek information that is not related to the subject matter of this proceeding.

B) ROLS objects to any document request to the extent it is unduly or unnecessarily burdensome, unreasonable, oppressive, and/or vexatious.

C) ROLS objects to any document request to the extent that it may purport to require disclosure of communications, information or documents that are protected from disclosure on the basis of the attorney-client privilege, the work product doctrine, having been prepared or elicited for or in anticipation of litigation and/or trial, or any other applicable privileges or protections. By responding to the document requests, ROLS does not waive, and preserves, all applicable privileges and protections.

D) Inadvertent production of any information or document which is privileged, protected by the work product doctrine, was prepared or elicited for or in anticipation of litigation and/or trial, or is otherwise immune from disclosure, shall not constitute a waiver of any privilege or of any other ground for objecting to disclosure .with respect to that information or document, or its subject matter, or of ROLS's right to object to the use of any such information or document during any administrative or judicial proceeding.

E) ROLS objects to any document request to the extent it seeks disclosure of confidential, proprietary, or sensitive business and/or personal information and/or documents protected from disclosure by law, court order, or any agreement with respect to confidentiality or non-disclosure.

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F) ROLS objects to any document request to the extent that it is vague,

ambiguous, or does not specify the documents sought with sufficient particularity.

G) ROLS objects to any document request to the extent that it seeks documents equally available to, or already in the possession of the Trustee.

H) ROLS objects to any document request to the extent that it seeks documents outside ROLS's possession, custody or control.

I) ROLS objects to any document request to the extent that it seeks documents which ROLS cannot be held responsible for producing.

J) ROLS objects to any document request to the extent that it requests the disclosure of information or documents that are irrelevant and is not reasonably calculated to lead to the discovery of relevant and admissible evidence.

K) ROLS obects to any document request to the extent that it is not proportional to the needs of the case.

Subject to the foregoing general objections and reservations, each of which shall be expressly deemed incorporated into each response below, ROLS responds as follows to each of the document requests by like-numbered paragraph:

#### **DOCUMENT REQUESTS**

Document Request No. 1

All Documents regarding any income or Asset of the Debtor, the Debtor's estate, or an Associated Entity.

Response to Document Request No. 1

ROLS objects to this document request because it is vague, ambiguous, overly broad, and unduly burdensome. ROLS further objects to this document request to the extent it seeks disclosure of

confidential, proprietary, and/or sensitive business or personal information. Without prejudice to the foregoing and subject to all general objections and reservations as set forth above, ROLS answers this request, in part and in substance, as follows: ROLS refers the Trustee to the enclosed document production.

# Document Request No. 2

All Documents related to the Debtor's financial condition and obligations to his creditors, including without limitation all Documents related to any effort to avoid paying such obligations and All Documents related to this or any other actual or potential bankruptcy or similar insolvency proceeding.

# Response to Document Request No. 2

ROLS objects to this document request because it is vague, ambiguous, and overly broad.

Without prejudice to the foregoing and subject to all general objections and reservations as set

forth above, ROLS answers this request, in part and in substance, as follows: ROLS does not

have any document responsive to this request.

# Document Request No. 3

All documents regarding any balance sheet, bank statement, account statement, financial statement, statement of account, wire transfer instructions and/or confirmation, proof of funds, certificate of deposit, certificate of holdings, investment portfolio summary, or similar document relating to the Debtor, the Debtor's Estate, the Debtor's Family, an Associated Entity, or an Associated Individual, including without limitation all Documents sufficient to show all Transfers to any of the foregoing.

# Response to Document Request No. 3

ROLS objects to this document request because it is vague, ambiguous, overly broad, and unduly

burdensome. ROLS further objects to this document request to the extent it seeks disclosure of

confidential, proprietary, and/or sensitive business or personal information. Without prejudice to

the foregoing and subject to all general objections and reservations as set forth above, ROLS

answers this request, in part and in substance, as follows: ROLS refers the Trustee to the enclosed document production.

#### Document Request No. 4

All Documents regarding any investment, business dealing or transactions made by, with, or on behalf of the Debtor.

# Response to Document Request No. 4

ROLS objects to this document request because it is vague, ambiguous, and overly broad. ROLS further objects to this document request to the extent it seeks disclosure of confidential, proprietary, and/or sensitive business or personal information. Without prejudice to the foregoing and subject to all general objections and reservations as set forth above, ROLS answers this request, in part and in substance, as follows: ROLS does not have any document responsive to this request.

#### Document Request No. 5

All Communications with the Debtor, and Documents related to Communications with the Debtor, related to the operation, management, or decision-making of any Entity, including without limitation the Associated Entities.

# Response to Document Request No. 5

ROLS objects to this document request because it is vague, ambiguous, and overly broad. ROLS further objects to this document request to the extent it seeks disclosure of confidential, proprietary, and/or sensitive business or personal information. Without prejudice to the foregoing and subject to all general objections and reservations as set forth above, ROLS answers this request, in part and in substance, as follows: ROLS refers the Trustee to the enclosed document production.

#### Document Request No. 6

All Documents regarding any Transfer, investment, or other transaction or business dealing made to, by, or with the Debtor, the Debtor's Family, or an Associated Entity.

#### Response to Document Request No. 6

ROLS objects to this document request because it is vague, ambiguous, and overly broad. ROLS further objects to this document request to the extent it seeks disclosure of confidential, proprietary, and/or sensitive business or personal information. Without prejudice to the foregoing and subject to all general objections and reservations as set forth above, ROLS answers this request, in part and in substance, as follows: ROLS refers the Trustee to the enclosed document production.

#### Document Request No. 7

All documents regarding any property ever occupied or used by the Debtor, including without limitation the *Lady May*; the Sherry Netherland Hotel/Condominium; the residential property located in Greenwich, Connecticut at 373 Taconic Rd.; the residential property located in Greenwich, Connecticut at 33 Ferncliff Rd.; and the residential property located in Wilton, Connecticut at 354 Nod Hill Rd.

# Response to Document Request No. 7

ROLS objects to this document request because it is vague, ambiguous, and overly broad. ROLS further objects to this document request to the extent it seeks disclosure of confidential, proprietary, and/or sensitive business or personal information. ROLS further objects to this request because it assumes facts that have not been established. Without prejudice to the foregoing and subject to all general objections and reservations as set forth above, ROLS answers this request, in part and in substance, as follows: ROLS refers the Trustee to the enclosed document production.

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# Document Request No. 8

All Documents related to any investments or trading by the Debtor, the Debtor's Family, or an Associated Entity, in or around July 2020, or at any other time, in crude oil futures or any similar commodity, including without limitation Communications with Jiang Yunfu Be regarding any such investments or trading.

# Response to Document Request No. 8

ROLS objects to this document request because it is vague, ambiguous, and overly broad.

Without prejudice to the foregoing and subject to all general objections and reservations as set

forth above, ROLS answers this request, in part and in substance, as follows: ROLS does not

have any document responsive to this request.

# Document Request No. 9

All Documents related to any aircraft owned, controlled, or used by the Debtor, including without limitation the aircraft bearing tail number T7-GQM and any other aircraft registered in San Marino, including without limitation copies of all registration documents and flight manifests showing flights taken by such aircraft and the individuals onboard such flights.

# Response to Document Request No. 9

ROLS objects to this document request because it is vague, ambiguous, and overly broad.

Without prejudice to the foregoing and subject to all general objections and reservations as set

forth above, ROLS answers this request, in part and in substance, as follows: ROLS does not

have any document responsive to this request.

# Document Request No. 10

All Documents regarding any gifts, benefits or loans, to, from or on behalf of the Debtor, the Debtor's Estate, the Debtor's Family, or the Associated Entities, including without limitation Documents sufficient to show the amount of such gifts, benefits, or loans; the purposes for which such gifts, benefits, or loans were used; when the gifts, benefits, or loans were provided; and the terms of any loans, all representations and warranties made in connection with any loans, the interest rate on any loans, and all evidence of payments of any loans.

# Response to Document Request No. 10

ROLS objects to this document request because it is vague, ambiguous, and overly broad. ROLS further objects to this document request to the extent it seeks disclosure of confidential, proprietary, and/or sensitive business or personal information. Without prejudice to the foregoing and subject to all general objections and reservations as set forth above, ROLS answers this request, in part and in substance, as follows: ROLS refers the Trustee to the enclosed document production.

# Document Request No. 11

All Documents concerning any trust or similar instrument set up by, on behalf of, or for the benefit of the Debtor, the Debtor's Estate, the Debtor's Family, or an Associated Entity, including without limitation Documents sufficient to show when the trust(s) was created, by whom it was created, for whose benefit it was created, and the corpus of the trust.

# Response to Document Request No. 11

ROLS objects to this document request because it is vague, ambiguous, and overly broad.

Without prejudice to the foregoing and subject to all general objections and reservations as set

forth above, ROLS answers this request, in part and in substance, as follows: ROLS does not

have any document responsive to this request.

#### Document Request No. 12

All Documents related to any obligation, claim, liability, or debt associated with any legal dispute involving the Debtor, including but not limited to those relating to any litigation before any local, state, federal, or international body, whether an administrative body, court, panel, or alternate dispute resolution entity.

#### Response to Document Request No. 12

ROLS objects to this document request because it is vague, ambiguous, and overly broad.

Without prejudice to the foregoing and subject to all general objections and reservations as set

forth above, ROLS answers this request, in part and in substance, as follows: ROLS does not have any document responsive to this request.

Document Request No. 13

All Documents and communications between any of your outside counsel or other advisors and the Debtor.

#### Response to Document Request No. 13

ROLS objects to this document request because it is vague, ambiguous, and overly broad.

Without prejudice to the foregoing and subject to all general objections and reservations as set

forth above, ROLS answers this request, in part and in substance, as follows: ROLS does not

have any document responsive to this request.

## Document Request No. 14

Documents sufficient to show all of Your Assets and sources of income or funding.

#### Response to Document Request No. 14

ROLS objects to this document request because it is vague, ambiguous, overly broad, and unduly burdensome. ROLS further objects to this document request to the extent it seeks disclosure of confidential, proprietary, and/or sensitive business or personal information. Without prejudice to the foregoing and subject to all general objections and reservations as set forth above, ROLS answers this request, in part and in substance, as follows: ROLS refers the Trustee to the enclosed document production.

# Document Request No. 15

For all Assets identified in response to Request [13] having a value of more than \$50,000, all (i) Documents related to Your acquisition of such Asset and (ii) Communications with the Debtor or the Debtor's Family regarding such Asset.

#### Response to Document Request No. 15

ROLS objects to this document request because it is vague, ambiguous, and overly broad. ROLS further objects to this document request to the extent it seeks disclosure of confidential, proprietary, and/or sensitive business or personal information. Without prejudice to the foregoing and subject to all general objections and reservations as set forth above, ROLS answers this request, in part and in substance, as follows: ROLS refers the Trustee to the enclosed document production.

#### Document Request No. 16

Copies of Your tax returns.

#### Response to Document Request No. 16

ROLS objects to this document request because it is vague, ambiguous, and overly broad. Without prejudice to the foregoing and subject to all general objections and reservations as set forth above, ROLS answers this request, in part and in substance, as follows: ROLS refers the Trustee to the enclosed document production.

#### Document Request No. 17

Documents sufficient to show all bank accounts and investment accounts within Your possession or control, including the balances of and transfers to and from each account.

#### Response to Document Request No. 17

ROLS objects to this document request because it is vague, ambiguous, and overly broad. ROLS further objects to this document request to the extent it seeks disclosure of confidential, proprietary, and/or sensitive business or personal information. ROLS further objects to this document request because it seek documents and information that is not relevant and is not reasonably calculated to lead to the discovery of relevant and admissible evidence. ROLS

further objects to this document request because it is unduly or unnecessarily burdensome,

unreasonable, oppressive, and/or vexatious, and is not proportional to the needs of this case.

#### Document Request No. 18

All Documents regarding any credit cards used by You, including without limitation monthly statements or other Documents sufficient to show all purchases related thereto for the benefit of the Debtor or an Associated Entity.

# Response to Document Request No. 18

ROLS objects to this document request because it is vague, ambiguous, and overly broad.

Without prejudice to the foregoing and subject to all general objections and reservations as set

forth above, ROLS answers this request, in part and in substance, as follows: ROLS does not

have any document responsive to this request.

#### Document Request No. 19

All corporate governance and organizational Documents, including without limitations by-laws and certificates of incorporation and other Documents sufficient to show Your corporate structure, names of officers and directors, business purpose, and relationship to the Debtor or to any member of the Debtor's Family.

# Response to Document Request No. 19

ROLS objects to this document request because it is vague, ambiguous, and overly broad. ROLS further objects to this document request to the extent it seeks disclosure of confidential, proprietary, and/or sensitive business or personal information. Without prejudice to the foregoing and subject to all general objections and reservations as set forth above, ROLS answers this request, in part and in substance, as follows: ROLS refers the Trustee to the

enclosed document production.

Dated: New York, New York October 11, 2022

# LAW OFFICE OF RICHARD E. SIGNORELLI

\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_

By: /s/ Richard E. Signorelli /s/ Bryan Ha

> Richard E. Signorelli Bryan Ha 52 Duane Street, 7th Floor New York, NY 10007 Telephone: 917 750 8842 Facsimile: 212 254 1396 richardsignorelli@gmail.com bhanyc@gmail.com www.nycjd.com

Attorneys for Rule of Law Society IV, Inc.