Guo Wengui / Miles Guo — bankruptcy case, SUBPOENA, CTB 22-50073, ECF document 2568-6, 2024-02-05 — full text | United States v. Ho Wan Kwok

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Case 22-50073 Doc 2568-6 Filed 02/05/24 Entered 02/05/24 16:29:39 Page 1 of 18

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devans sdmlawgroup.com

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From: Kosciewicz, Jonathon P. <jonathonkosciewicz@paulhastings.com></jonathonkosciewicz@paulhastings.com>

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Sent:　Wednesday, April 5, 2023 5:59 PM To:　Bryan Ha

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Cc: Luft, Avi E.; Sutton, Ezra; Richard Signorelli; Farmer, Will C. Subject: RE: [EXT] Re: Rule of Law Society IV, Inc. - Rule 2004 Subpoena

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Bryan,

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When we last talked on January 26, 2023 you indicated that you were going to discuss with your clients the collection of their ESI and the running of our proposed search terms. You also indicated that you would run to ground (1) records of incoming donations to either ROLF or ROLS from the Debtor, his family, associated entities, or associated individuals and (2) records of outgoing expenses of ROLF and ROLS to the Debtor, his family, associated entities, or associated individuals. Finally, you indicated that you would produce the 2021 tax returns for both ROLF and ROLS.

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We have not heard from you since our last discussion, and we have received no further production of documents. The Trustee has been working in good faith with your clients, but the time for production of these documents has long passed. We are requesting that Rule of Law Society and Rule of Law Foundation complete its production of documents (including privilege log(s)) on or before Monday, April 10, 2023. If for any reason this deadline cannot be met, please reach out immediately to discuss. Otherwise, we will seek the assistance of the Court to help expedite the production of documents.

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Separately, can you please state your clients' position on the production of their bank records? See Request for Production 17. If your clients are willing to produce these documents pursuant to the document requests, please include these records in the production on or before April 10. If your clients are not willing to produce them, please let us know so we can seek assistance of the Court.

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Thank you,

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Jon

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Jonathon P. Kosciewicz Associate, Litigation Department Paul Hastings LLP 71 S. Wacker Drive, Forty-Fifth Floor, Chicago, IL 60606 Direct: +1.312.499.6021 Main: +1.312.499.6000 Fax: +1.312.499.6121 jonathonkosciewicz@paulhastings.com www.paulhastings.com

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From: Kosciewicz, Jonathon P. Sent: Tuesday, December 27, 2022 10:56 AM To: 'Bryan Ha' <bhanyc@gmail.com> Cc: Luft, Avi E. <aviluft@paulhastings.com>; Sutton, Ezra <ezrasutton@paulhastings.com>; 'Richard Signorelli' <richardsignorelli@gmail.com>

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Subject: RE: [EXT] Re: Rule of Law Society IV, Inc. - Rule 2004 Subpoena

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Hi Bryan,

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I am following up on our phone call on 12/21. During that call, you indicated that you were expecting an update from your clients Rule of Law Foundation and Rule of Law Society as to a number of discovery topics we discussed, including (1) records of incoming donations to either ROLF or ROLS from the Debtor, his family, associated entities, or associated individuals; (2) records of outgoing expenses of ROLF and ROLS to the Debtor, his family, associated entities, or associated individuals; (3) 2021 tax returns for both ROLF and ROLS, and (4) the collection of ESI and the running of our proposed search terms. Did you receive this update from your clients?

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Thank you,

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Jon

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From: Kosciewicz, Jonathon P. Sent: Monday, December 19, 2022 11:29 AM To: 'Bryan Ha' <bhanyc@gmail.com> Cc: Luft, Avi E. <aviluft@paulhastings.com>; Sutton, Ezra <ezrasutton@paulhastings.com>; 'Richard Signorelli' <richardsignorelli@gmail.com> Subject: RE: [EXT] Re: Rule of Law Society IV, Inc. - Rule 2004 Subpoena

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Hi Bryan,

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Thank you for your call this morning. Looking at our team's internal schedule, Wednesday afternoon (as opposed to Thursday afternoon) works best for us to hold the meet and confer we discussed.

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Thank you,

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Jon

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Jonathon P. Kosciewicz Associate, Litigation Department Paul Hastings LLP 71 S. Wacker Drive, Forty-Fifth Floor, Chicago, IL 60606 Direct: +1.312.499.6021 Main: +1.312.499.6000 Fax: +1.312.499.6121 jonathonkosciewicz@paulhastings.com www.paulhastings.com

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From: Kosciewicz, Jonathon P. Sent: Friday, December 16, 2022 3:16 PM To: 'Bryan Ha' <bhanyc@gmail.com> Cc: Luft, Avi E. <aviluft@paulhastings.com>; Sutton, Ezra <ezrasutton@paulhastings.com>; Richard Signorelli <richardsignorelli@gmail.com> Subject: RE: [EXT] Re: Rule of Law Society IV, Inc. - Rule 2004 Subpoena

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Bryan,

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Are you free Monday any time between 11-3 ET?

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Thank you,

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Jon

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From: Bryan Ha <bhanyc@gmail.com> Sent: Wednesday, December 14, 2022 8:27 AM To: Kosciewicz, Jonathon P. <jonathonkosciewicz@paulhastings.com> Cc: Luft, Avi E. <aviluft@paulhastings.com>; Sutton, Ezra <ezrasutton@paulhastings.com>; Richard Signorelli <richardsignorelli@gmail.com> Subject: [EXT] Re: Rule of Law Society IV, Inc. - Rule 2004 Subpoena

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--- External Email ---

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Hi Jon,

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Lets speak early next week, Monday or Tuesday. I have a trial starting tomorrow but should be free next week.

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Thanks, Bryan

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On Tue, Dec 13, 2022 at 2:09 PM Kosciewicz, Jonathon P. <jonathonkosciewicz@paulhastings.com> wrote:

Hi Bryan,

Thank you,

Jon

Jonathon P. Kosciewicz Associate, Litigation Department Paul Hastings LLP 71 S. Wacker Drive, Forty-Fifth Floor, Chicago, IL 60606 Direct: +1.312.499.6021 Main: +1.312.499.6000 Fax: +1.312.499.6121 jonathonkosciewicz@paulhastings.com www.paulhastings.com

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From: Kosciewicz, Jonathon P. Sent: Friday, December 2, 2022 5:05 PM To: 'Bryan Ha' <bhanyc@gmail.com> Cc: Luft, Avi E. <aviluft@paulhastings.com>; Sutton, Ezra <ezrasutton@paulhastings.com>; Richard Signorelli <richardsignorelli@gmail.com> Subject: RE: [EXT] Re: Rule of Law Society IV, Inc. - Rule 2004 Subpoena

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Hi Bryan,

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Thank you for the productive meet and confer today.

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As we discussed on the call, these are the items you represented to us that you would discuss with the Rule of Law Foundation ("ROLF") and the Rule of Law Society ("ROLS"):

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You indicated that you would attempt to collect records of all incoming donations to either ROLF or ROLS from the Debtor, his family, Associated Entities, and Associated Individuals, as those terms were defined in the Rule 2004 Subpoenas.

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You indicated that you would attempt to collect records of all outgoing expenses of ROLF and ROLS related to the Debtor, his family, Associated Entities, and Associated Individuals, as those terms were defined in the Rule 2004 Subpoenas.

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- You indicated that you would search for email "communications" related to RFP # 5. - You indicated that both ROL and ROLS would produce their 2021 tax returns in the near future. - You indicated that you would look into and advise on the redactions in certain of the already produced tax returns.

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o During the call, I could not remember which exact tax returns that had the redactions. However, the redactions I was talking about are found in: "ROLS – CT BK 386" on PDF page 25 (the yellow highlighted redactions)

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- You indicated that you would consider search terms to run across the remaining ESI from ROLF/ROLS. Are suggested search terms are below:

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- o Miles - o Kwok - o Ho - o Wan - o Gwo or Guo - o Wengui or Wen-gui or Wen gui - o Haoyun - o Genever - o Pacific Alliance - o PAX - o Lady May - o Mei - o Mileson - o Golden Spring - o Eastern Profit - o Bravo Luck - o Lamp Capital

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- o Greenwich Land - o G-Series OR GSeries - o Daniel /2 Podhaskie - o Podhaskie - o GTV - o Saraca - o Sherry Netherland - o 373 Taconic - o 33 Ferncliff - o 354 Nod Hill - o T7-GQM - o Jiang OR Yunfu Be - o Gui - o Yvette OR Wang - o HK International - o Hing Chi OR Ngok - o Yue OR Qingzhi - o Qiang - o 7 Nod Hill - o Dawn State - o Himalaya - o Farm\* - o Mountain\* - o Coin

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- o "ACA" w/3 ("investment" or "capital")

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- o Ace Decade

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Case 22-50073 Doc 2568-6 Filed 02/05/24 Entered 02/05/24 16:29:39 Page 7 of

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- o Bruno OR Wu

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- o (Aaron or aron or "A" or "A.") /3 (Mitchell OR Mitchel)

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- o "a.mitchell"

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- o (Melissa OR Missy OR Lissa OR Lisa OR "M" or "M.") /3 Francis

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- o "MF" - o "m.francis" - o Francis Firm - o Protest - o "traitor punish\*" - o GETTR - o NFSC - o "New Federal State of China" - o "Whitsleblower movement" Thank you, Jon

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Jonathon P. Kosciewicz Associate, Litigation Department

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Paul Hastings LLP 71 S. Wacker Drive, Forty-Fifth Floor, Chicago, IL 60606 Direct: +1.312.499.6021 Main: +1.312.499.6000 Fax: +1.312.499.6121 jonathonkosciewicz@paulhastings.com www.paulhastings.com

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From: Bryan Ha <bhanyc@gmail.com> Sent: Thursday, December 1, 2022 1:26 PM To: Kosciewicz, Jonathon P. <jonathonkosciewicz@paulhastings.com> Cc: Luft, Avi E. <aviluft@paulhastings.com>; Sutton, Ezra <ezrasutton@paulhastings.com>; Richard Signorelli <richardsignorelli@gmail.com> Subject: [EXT] Re: Rule of Law Society IV, Inc. - Rule 2004 Subpoena --- External Email: Do not open attachments or click links from unknown senders ---

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Hi Jon,

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I am available for a call tomorrow 12-2pm. Does that work for you?

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Bryan

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On Thu, Dec 1, 2022 at 12:11 AM Kosciewicz, Jonathon P. <jonathonkosciewicz@paulhastings.com> wrote:

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Hi Bryan,

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I write to follow up on our meet and confer last week. Have you had an opportunity to talk with your clients regarding their bank records and internal email communications? Please let us know if you would like to schedule a call to discuss, ideally sometime this week, as the requested information is of great interest to the Trustee.

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Thank you,

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Jon

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Case 22-50073 Doc 2568-6 Filed 02/05/24 Entered 02/05/24 16:29:39 Page 9 of 18

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Jonathon P. Kosciewicz Associate, Litigation Department

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Paul Hastings LLP 71 S. Wacker Drive, Forty-Fifth Floor, Chicago, IL 60606 Direct: +1.312.499.6021 Main: +1.312.499.6000 Fax: +1.312.499.6121

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jonathonkosciewicz@paulhastings.com www.paulhastings.com

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From: Bryan Ha <bhanyc@gmail.com> Sent: Tuesday, November 22, 2022 12:57 PM To: Kosciewicz, Jonathon P. <jonathonkosciewicz@paulhastings.com> Cc: Luft, Avi E. <aviluft@paulhastings.com>; Sutton, Ezra <ezrasutton@paulhastings.com>; Richard Signorelli <richardsignorelli@gmail.com> Subject: [EXT] Re: Rule of Law Society IV, Inc. - Rule 2004 Subpoena

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Sure, please send dial in info for the call.

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Bryan

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On Tue, Nov 22, 2022 at 1:55 PM Kosciewicz, Jonathon P. <jonathonkosciewicz@paulhastings.com> wrote:

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Hi Bryan,

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Can you jump on a quick call at 2pm ET, today. Shouldn't take more than 15 minutes.

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Thank you,

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Jon

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Case 22-50073 Doc 2568-6 Filed 02/05/24 Entered 02/05/24 16:29:39 Page 10 of 18

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Jonathon P. Kosciewicz Associate, Litigation Department Paul Hastings LLP 71 S. Wacker Drive, Forty-Fifth Floor, Chicago, IL 60606 Direct: +1.312.499.6021 Main: +1.312.499.6000 Fax: +1.312.499.6121 jonathonkosciewicz@paulhastings.com www.paulhastings.com

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From: Bryan Ha <bhanyc@gmail.com> Sent: Tuesday, November 22, 2022 12:37 PM To: Kosciewicz, Jonathon P. <jonathonkosciewicz@paulhastings.com> Cc: Luft, Avi E. <aviluft@paulhastings.com>; Sutton, Ezra <ezrasutton@paulhastings.com>; Richard Signorelli <richardsignorelli@gmail.com> Subject: [EXT] Re: Rule of Law Society IV, Inc. - Rule 2004 Subpoena

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I am only available until 3:00 today. I can also do Friday morning before 11:00AM.

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Bryan

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On Tue, Nov 22, 2022 at 1:26 PM Kosciewicz, Jonathon P. <jonathonkosciewicz@paulhastings.com> wrote:

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Hi Brian,

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We would really like to discuss sometime this week if possible. We have depositions tentatively scheduled next week in preparation for an upcoming hearing. Do you have any time late this afternoon? I imagine that it would not take more than 15-20 minutes to talk.

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Thank you,

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Jon

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Jonathon P. Kosciewicz Associate, Litigation Department Paul Hastings LLP 71 S. Wacker Drive, Forty-Fifth Floor, Chicago, IL 60606 Direct: +1.312.499.6021 Main: +1.312.499.6000 Fax: +1.312.499.6121 jonathonkosciewicz@paulhastings.com www.paulhastings.com

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From: Bryan Ha <bhanyc@gmail.com> Sent: Tuesday, November 22, 2022 12:22 PM To: Kosciewicz, Jonathon P. <jonathonkosciewicz@paulhastings.com> Cc: Luft, Avi E. <aviluft@paulhastings.com>; Sutton, Ezra <ezrasutton@paulhastings.com>; Richard Signorelli <richardsignorelli@gmail.com> Subject: [EXT] Re: Rule of Law Society IV, Inc. - Rule 2004 Subpoena

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Hi Jon,

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Sorry I had a few other things come up and tomorrow is no longer good for me. How about next Monday, Nov. 28? I am free any time before 2pm.

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Thanks, Bryan

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On Tue, Nov 22, 2022 at 12:35 PM Kosciewicz, Jonathon P. <jonathonkosciewicz@paulhastings.com> wrote:

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Hi Bryan,

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What does your availability look like tomorrow morning for a meet and confer? We are generally available any time between 9am – 11 am ET and any time after 12 pm.

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Thank you,

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Jon

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Jonathon P. Kosciewicz Associate, Litigation Department Paul Hastings LLP 71 S. Wacker Drive, Forty-Fifth Floor, Chicago, IL 60606 Direct: +1.312.499.6021 Main: +1.312.499.6000 Fax: +1.312.499.6121 jonathonkosciewicz@paulhastings.com www.paulhastings.com

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From: Bryan Ha <bhanyc@gmail.com> Sent: Wednesday, November 16, 2022 10:25 PM To: Kosciewicz, Jonathon P. <jonathonkosciewicz@paulhastings.com> Cc: Luft, Avi E. <aviluft@paulhastings.com>; Sutton, Ezra <ezrasutton@paulhastings.com>; Richard Signorelli <richardsignorelli@gmail.com> Subject: [EXT] Re: Rule of Law Society IV, Inc. - Rule 2004 Subpoena

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Hi Jon,

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I am not available this Friday but can do it any time in the morning next Tuesday or Wednesday (Nov. 22 or 23).

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Bryan

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On Wed, Nov 16, 2022 at 10:44 AM Kosciewicz, Jonathon P. <jonathonkosciewicz@paulhastings.com> wrote:

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Hi Bryan,

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Case 22-50073 Doc 2568-6 Filed 02/05/24 18 Entered 02/05/24 16:29:39 Page 13 of

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Foundation's Rule 2004 document productions? Are you available to meet and confer this Friday (11/18) regarding Rule of Law Society's and Rule of Law Please let us know.

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Thank you, Jon

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Jonathon P. Kosciewicz Associate, Litigation Department Paul Hastings LLP 71 S. Wacker Drive, Forty-Fifth Floor, Chicago, IL 60606 Direct: +1.312.499.6021 Main: +1.312.499.6000 Fax: +1.312.499.6121

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From: Bryan Ha <bhanyc@gmail.com> Sent: Tuesday, November 8, 2022 9:42 AM To: Kosciewicz, Jonathon P. <jonathonkosciewicz@paulhastings.com> Cc: Luft, Avi E. <aviluft@paulhastings.com>; Sutton, Ezra <ezrasutton@paulhastings.com>; Richard Signorelli <richardsignorelli@gmail.com> Subject: [EXT] Re: Rule of Law Society IV, Inc. - Rule 2004 Subpoena

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jonathonkosciewicz@paulhastings.com www.paulhastings.com

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Hi Jonathon,

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We are evaluating and will let you know if we have additional responsive documents for a supplemental production.

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Bryan

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On Tue, Nov 8, 2022 at 10:25 AM Kosciewicz, Jonathon P. <jonathonkosciewicz@paulhastings.com> wrote:

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Hi Bryan,

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Following up on the below.

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Thank you,

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Jon

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Jonathon P. Kosciewicz Associate, Litigation Department

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Paul Hastings LLP 71 S. Wacker Drive, Forty-Fifth Floor, Chicago, IL 60606 Direct: +1.312.499.6021 Main: +1.312.499.6000 Fax: +1.312.499.6121 jonathonkosciewicz@paulhastings.com www.paulhastings.com

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From: Kosciewicz, Jonathon P. Sent: Tuesday, November 1, 2022 10:34 AM To: 'Bryan Ha' <bhanyc@gmail.com>; Luft, Avi E. <aviluft@paulhastings.com> Cc: Sutton, Ezra <ezrasutton@paulhastings.com>; Richard Signorelli <richardsignorelli@gmail.com> Subject: RE: [EXT] Rule of Law Society IV, Inc. - Rule 2004 Subpoena

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Hi Bryan,

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Thank you for your document productions on behalf of the Rule of Law Society and the Rule of Law Foundation. Can you advise whether you anticipate making any further productions on behalf of either subpoena recipient?

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Case 22-50073 Doc 2568-6 Filed 02/05/24 Entered 02/05/24 16:29:39 Page 15 of

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Jonathon P. Kosciewicz Associate, Litigation Department

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+1.312.499.6021 Main: +1.312.499.6000 Fax: +1.312.499.6121

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Paul Hastings LLP 71 S. Wacker Drive, Forty-Fifth Floor, Chicago, IL 60606 Direct: jonathonkosciewicz@paulhastings.com www.paulhastings.com

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From: Bryan Ha <bhanyc@gmail.com> Sent: Tuesday, October 11, 2022 11:31 AM To: Luft, Avi E. <aviluft@paulhastings.com> Cc: Sutton, Ezra <ezrasutton@paulhastings.com>; Kosciewicz, Jonathon P. <jonathonkosciewicz@paulhastings.com>; Richard Signorelli <richardsignorelli@gmail.com> Subject: [EXT] Rule of Law Society IV, Inc. - Rule 2004 Subpoena

Dear Avi:

Thank you,

Jon

Please see the attached letter, responses and objections, and document production in response to the Rule 2004 subpoena issued to Rule of Law Society IV, Inc.

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Office prevented auto matic download of this picture from the Internet. ROLS Doc Prod - ROLS-CT BK 1 thru ROLS CT BK 60...

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Bryan Ha

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To help protect your privacy, Micro so ft

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Law Office of Richard E. Signorelli

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52 Duane Street, 7th Floor

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New York, NY 10007

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Telephone: 917 750 8842

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Attorneys for Rule of Law Society IV, Inc.

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The preceding e-mail message (including any attachments) contains information that may be confidential, may be protected by the attorney-client or other applicable privileges, or may constitute non-public information. It is intended to be conveyed only to the designated recipient(s) named above. If you are not an intended recipient of this message, please notify the sender by replying to this message and then delete all copies of it from your computer system. Any use, dissemination, distribution, or reproduction of this message by unintended recipients is not authorized and may be unlawful.

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The preceding e-mail message (including any attachments) contains information that may be confidential, may be protected by the attorney-client or other applicable privileges, or may constitute non-public information. It is intended to be conveyed only to the designated recipient(s) named above. If you are not an intended recipient of this message, please notify the sender by replying to this message and then delete all copies of it from your computer system. Any use, dissemination, distribution, or reproduction of this message by unintended recipients is not authorized and may be unlawful.

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This message is sent by a law firm and may contain information that is privileged or confidential. If you received this transmission in error, please notify the sender by reply e-mail and delete the message and any attachments. If you reply to this message, Paul Hastings may collect personal information including your name, business name and other contact details, and IP address. For more information about Paul Hastings' information collection, privacy and security principles please click HERE. If you have any questions, please contact Privacy@paulhastings.com. Case 22-50073 Doc 2568-6 Filed 02/05/24 Entered 02/05/24 16:29:39 Page 17 of The preceding e-mail message (including any attachments) contains information that may be confidential, may be protected by the attorney-client or other applicable privileges, or may constitute non-public information. It is intended to be conveyed only to the designated recipient(s) named above. If you are not an intended recipient of this message, please notify the sender by replying to this message and then delete all copies of it from your computer system. Any use, dissemination, distribution, or reproduction of this message by unintended recipients is not authorized and may be unlawful. \\\\\\\\\\\\\\\\\\\\\\\\\\\\\\\\\\\\\\\\\\\\\\\\\\\\\\\\\\\\\\\\\\\\\\\\\\\\\\\\\\\\\\\\\\

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The preceding e-mail message (including any attachments) contains information that may be confidential, may be protected by the attorney-client or other applicable privileges, or may constitute non-public information. It is intended to be conveyed only to the designated recipient(s) named above. If you are not an intended recipient of this message, please notify the sender by replying to this message and then delete all copies of it from your computer system. Any use, dissemination, distribution, or reproduction of this message by unintended recipients is not authorized and may be unlawful. \\\\\\\\\\\\\\\\\\\\\\\\\\\\\\\\\\\\\\\\\\\\\\\\\\\\\\\\\\\\\\\\\\\\\\\\\\\\\\\\\\\\\\\\\\

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The preceding e-mail message (including any attachments) contains information that may be confidential, may be protected by the attorney-client or other applicable privileges, or may constitute non-public information. It is intended to be conveyed only to the designated recipient(s) named above. If you are not an intended recipient of this message, please notify the sender by replying to this message and then delete all copies of it from your computer system. Any use, dissemination, distribution, or reproduction of this message by unintended recipients is not authorized and may be unlawful.

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The preceding e-mail message (including any attachments) contains information that may be confidential,

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information. It is intended to be conveyed only to the designated recipient(s) named above. If you are not an intended recipient of this message, please notify the sender by replying to this message and then delete all copies of it from your computer system. Any use, dissemination, distribution, or reproduction of this message

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may be protected by the attorney-client or other applicable privileges, or may constitute non-public

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and other contact details, and IP address. For more information about Paul Hastings' information collection, privacy and security principles please click HERE. If you have any questions, please contact Privacy@paulhastings.com.

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by unintended recipients is not authorized and may be unlawful.

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The preceding e-mail message (including any attachments) contains information that may be confidential, may be protected by the attorney-client or other applicable privileges, or may constitute non-public information. It is intended to be conveyed only to the designated recipient(s) named above. If you are not an intended recipient of this message, please notify the sender by replying to this message and then delete all copies of it from your computer system. Any use, dissemination, distribution, or reproduction of this message by unintended recipients is not authorized and may be unlawful.

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Guo Wengui / Miles Guo — bankruptcy case · SUBPOENA · ECF #2568-6

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