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

UNITED STATES BANKRUPTCY COURT DISTRICT OF CONNECTICUT BRIDGEPORT DIVISION

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HO WAN KWOK, et al., : :

Debtors. :

---------------------------------------------------------------- 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].

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

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

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