Guo Wengui / Miles Guo — bankruptcy case · ORDER · ECF #2718

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

| ---------------------------------------------------------------- | x | | |------------------------------------------------------------------|-------------|-------------------------| | In re: | : | Chapter 11 | | HO WAN KWOK, et al., | :<br>:<br>: | Case No. 22-50073 (JAM) | | Debtors. | :<br>: | (Jointly Administered) | | | : | | | | : | | | | : | | | ---------------------------------------------------------------- | x | |

# **MOTION TO PERMIT DAVID H. WANDER, ESQ., COUNSEL FOR YINYING WANG, TO APPEAR REMOTELY**

Pursuant to section 105(a) of the Bankruptcy Code and Rule 1001 of the Federal Rules of Bankruptcy Procedure, Yinying Wang (**"Wang"**), by and through her attorneys, respectfully moves that this Court permit David H. Wander, Esq. to appear remotely at the hearing, currently scheduled for February 13, 2024 at 1:30 p.m., on the Trustee's motion for an order extending the Trustee's deadline to file avoidance actions (the **"Motion"**) [ECF Doc. No. 2509].

### **REQUESTED RELIEF**

1. On February 7, 2024, Wang filed a motion to allow Attorney Wander to be

admitted by the Court *pro hac vice* to represent Wang [ECF Doc. No. 2581].

2. On February 7, 2024, Wang also filed an objection and joinder to the Motion [ECF Doc. No. 2582].

3. On February 9, 2024, the Court entered an order admitting Attorney Wander *pro hac vice* [ECF Doc. No. 2606].

4. As Attorney Wander currently works out of New York, New York, Wang respectfully requests that the Court allow Attorney Wander to attend the hearing remotely to spare the time and expense of the travel required to attend the hearing in person.

5. As Attorney Wander intends to remotely appear for the hearing, Wang also respectfully requests that the Court excuse sponsoring attorney Michael Grudberg from attending the hearing pursuant to Rule 83.1(d)(2) of the Local Rule of Civil Procedure for the United States District Court for the District of Connecticut.

6. A copy of a proposed order granting the motion is annexed as **Exhibit A**.

**WHEREFORE**, for the foregoing reasons, Wang respectfully requests that Attorney Wander be permitted to appear remotely before this Court on the hearing for the Motion on February 13, 2024 at 1:30 p.m.

Dated: New York, New York February 11, 2024

## **TARTER KRINSKY & DROGIN LLP**

By: /s/ Michael J. Grudberg Michael J. Grudberg 1350 Broadway New York, NY 10018 212.216.8035 mgrudberg@tarterkrinsky.com *Attorneys for Yinyang Wang*

## **CERTIFICATE OF SERVICE**

I hereby certify that on February 11, 2024, a copy of the foregoing Motion was filed electronically. Notice of this filing will be sent by e-mail to all appearances in this case by operation of the Court's electronic filing system. The Motion can be accessed through the Court's CM/ECF System.

Dated: New York, New York February 11, 2024

> By: /s/ Michael J. Grudberg Michael J. Grudberg 1350 Broadway New York, NY 10018 212.216.8035 mgrudberg@tarterkrinsky.com