Guo Wengui / Miles Guo — bankruptcy case · ORDER · ECF #2763

METADATA

Defendant
Guo Wengui / Miles Guo / Ho Wan Kwok
Court
CTB
Case No.
22-50073
ECF #
2763
Type
ORDER
Filed
2024-02-12

Witness and Exhibit Lists — In re Ho Wan Kwok (Miles Guo / Guo Wengui), CTB 22-50073 ECF #2763 (filed 2024-02-12). Chapter 11 Trustee Luc A. Despins submits his witness list (identifying himself) and an exhibit list of 132 items for the February 13, 2024 hearing on his motion to extend deadlines to file avoidance actions (ECF #2509).

FULL TEXT

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UNITED STATES BANKRUPTCY COURT DISTRICT OF CONNECTICUT BRIDGEPORT DIVISION

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In re: :

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: Chapter 11
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HO WAN KWOK, et al.,1 :

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: Case No. 22-50073 (JAM)
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Debtors. : :

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: (Jointly Administered)
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**TRUSTEE'S WITNESS AND EXHIBIT LISTS IN CONNECTION WITH FEBRUARY 13, 2024 HEARING ON TRUSTEE'S MOTION FOR ENTRY OF ORDER EXTENDING DEADLINE FOR TRUSTEE TO FILE AVOIDANCE ACTIONS UNDER BANKRUPTCY CODE SECTIONS 108, 546(a), AND 549**

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Luc Despins, as the appointed Chapter 11 Trustee to the Debtor's estate (the "Trustee"), by and through his undersigned counsel, provides the witness list attached hereto as Exhibit A and exhibit list attached hereto as Exhibit B for the February 13, 2024 hearing (the "Hearing") on the Trustee's *Motion for Entry of Order Extending Deadline for Trustee to File Avoidance Actions Under Bankruptcy Code Sections 108, 546(a), and 549* [Main Case, ECF No. 2509] before the Hon. Julia A. Manning, United States Bankruptcy Court for the District of Connecticut (Bridgeport), Courtroom 123, 915 Lafayette Blvd., Bridgeport, CT.

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The Trustee reserves the right to supplement or amend these lists. The Trustee further reserves the right to introduce or otherwise rely upon any exhibit offered by any other party. The Trustee further reserves the right to introduce additional exhibits for authentication, rebuttal or

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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. The mailing address for the Trustee, Genever Holdings LLC, and the Genever Holdings Corporation is Paul Hastings LLP, 200 Park Avenue, New York, NY 10166 c/o Luc A. Despins, as Trustee for the Estate of Ho Wan Kwok (solely for purposes of notices and communications).

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impeachment purposes. The Trustee further reserves the right to use demonstratives, including to summarize certain evidence, that is presented during the Hearing.

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[Remainder of Page Intentionally Left Blank]

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Dated: February 12, 2024 LUC A. DESPINS, Washington, D.C. CHAPTER 11 TRUSTEE

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By: /s/ Nicholas A. Bassett
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Nicholas A. Bassett (admitted pro hac vice) Paul Hastings LLP 2050 M Street NW Washington, D.C., 20036 (202) 551-1902 nicholasbassett@paulhastings.com

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and
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Avram E. Luft (admitted pro hac vice) Douglass Barron (admitted pro hac vice) PAUL HASTINGS LLP 200 Park Avenue New York, New York 10166 (212) 318-6079 aviluft@paulhastings.com douglassbarron@paulhastings.com

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and
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Patrick R. Linsey (ct29437) NEUBERT, PEPE & MONTEITH, P.C. 195 Church Street, 13th Floor New Haven, Connecticut 06510 (203) 781-2847 plinsey@npmlaw.com

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Counsel for the Chapter 11 Trustee EXHIBIT A: WITNESS LIST
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The Trustee designates the following individuals whom he presently anticipates may be called as witnesses at the Hearing:

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- 1. Luc A. Despins
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- 2. Any witness called by any other party.

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EXHIBIT B: EXHIBIT LIST
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1. The Trustee submits the following affirmative exhibits that he presently anticipates may

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be introduced at the Hearing. The Trustee further reserves the right to introduce, rely

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upon, and/or have the Court take judicial notice of other docket entries in this case.

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Trustee Description of Exhibit Case No.; ECF

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Exhibit No.

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1. Deposition transcript for Ho Wan Kwok dated March 2, 2023 23-05005; 113-

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2. Deposition transcript for Mei Guo dated September 13, 2023 23-05005; 113-

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3. Entry of Default 22-05027; 90
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4. Order Granting, Pursuant to Bankruptcy Rule 9019, Motion of 22-05027; 118 Chapter 11 Trustee, Genever Holdings LLC, and Genever Holdings Corporation Regarding Settlement with Bravo Luck Limited and Mileson Guo (A/K/A Qiang Guo and/or Guo

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Qiang)
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5. Order Granting Motion of Chapter 11 Trustee for Estate of Ho 23-05018; 35 Wan Kwok for Entry of Default Judgment Golden Spring (New York) Ltd. and China Golden Spring Group (Hong

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Kong) Limited
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6. Motion of Chapter 11 Trustee to Authorize and Compel 23-05013; 67 Discovery on Proposed Intervenors Shih Hsin Yu, 1332156 B.C. Ltd., GWGOPNZ Limited, Japan Himalaya League, Inc. and Authorizing Discovery on Additional Parties 7. The HCHK Creditors' Notice of Appeal 23-05013; 80

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8. Entry of Default 23-05013; 139
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9. Defendants' Notice of Appeal 23-05013; 150 10. Order Granting Motion for Order Requiring Production of G 23-05013; 179

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Club Documents 11. Entry of Default 23-05013; 222
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12. Memorandum of Decision and Order Denying Motion to 23-05013; 239 Intervene and Motion to Clarify Temporary Restraining Order 13. The Proposed Intervenors' Notice of Appeal

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Entry of Default 23-05013; 250 23-05023; 13
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14. 15. Motion of Chapter 11 Trustee for Entry of Order Compelling 23-05008; 32 Mei Guo to Appear and Testify at a Deposition 16. Motion of Chapter 11 Trustee Pursuant to Federal Rules of 23-05008; 46 Civil Procedure 26, 30, 37, and 45, Federal Rules of Bankruptcy Procedure 7026, 7030, 7037, and 9016, and Court's Inherent Authority for Entry of Order Compelling Anton Development Limited, Whitecroft Shore Limited, and

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Defendant to Comply with Subpoenas and Awarding

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Sanctions
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17. Order Compelling Anton Development Limited, Whitecroft 23-05008; 63 Shore Limited, and the Defendant to Comply with Subpoenas

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and Awarding Sanctions
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18. Mei Guo's Responses to First Set of Interrogatories 23-05008; 89-26 19. Mei Guo's Responses to First Set of Requests for Admission 23-05008; 89-27

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by Chapter 11 Trustee
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20. Mei Guo's Responses to First Requests for Production of 23-05008; 89-28

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Documents by Chapter 11 Trustee
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21. Equitable Tolling Order in In re: Solomon Dwek, et. al. 22-50073;

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25090-1
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22. Equitable Tolling Order in In re: Rockport Development, Inc. 22-50073;

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25090-2
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23. Equitable Tolling Order in In re: Visiting Nurse Association 22-50073;

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of the Inland Counties 25090-3
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24. Equitable Tolling Order in In re: Builders Holding Co. Corp. 22-50073;

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25090-4
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25. Equitable Tolling Order in In re: D&L Energy, Inc., et. al. 22-50073;

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25090-5
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26. Equitable Tolling Order in In Re: Network Services Solutions, 22-50073;

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LLC 25090-6
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27. Equitable Tolling Order in In re: Farm-Rite, Inc. 22-50073;

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25090-7
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28. Equitable Tolling Order in In re: Anton & Chia, LLP 22-50073;

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25090-8
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29. Equitable Tolling Order in In re: Uplift RX, LLC 22-50073;

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25090-9
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30. Transcript of Motion Hearing dated February 2, 2009 22-50073;

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25090-10
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31. Memorandum of Law of HK International Funds Investments 22-05003; 173 (USA) Limited, LLC and Mei Guo Submitted Pursuant to the

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Court's March 23, 2023 Order
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32. Memorandum of Decision and Order Granting Motion for 22-05003; 221 Partial Summary Judgment od Second Counterclaim 33. Voluntary Petition for Individuals Filing for Bankruptcy 22-50073; 1 34. Exhibit D – Individual Debtor's Statement of Compliance 22-50073; 2

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with Credit Counseling Requirement
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35. Official Form 122B – Chapter 11 Statement of Your Current 22-50073; 3

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Monthly Income
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36. Official Form 104 – For individual Chapter 11 Cases: List of 22-50073; 4 Creditors Who Have the 20 Largest Unsecured Claims

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Against You and Are Not Insiders
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37. Verification of Creditor Matrix 22-50073; 5

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38. Global Notes and Statements of Limitations, Methodology, 22-50073; 77

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and Disclaimers Regarding the Debtor's Schedules of Assets and Liabilities and Statement of Financial Affairs 39. Official Form 106SUM – Summary of Your Assets and 22-50073; 78 Liabilities and Certain Statistical Information 40. Notice of Appointment of Chapter 11 Trustee 22-50073; 514 41. The Debtor's Motion for Relief from order Appointing Luc A. 22-50073; 561

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Despins as Chapter 11 Trustee
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42. Motion of Chapter 11 Trustee for Entry of Order, Pursuant to 22-50073; 598 Bankruptcy Code Sections 363, 541, 1108, and 1505, (A) Confirming That Chapter 11 Trustee Holds All of the Debtor's Economic and Corporate Governance Rights in Debtor-Controlled Entities, (B) Authorizing Chapter 11 Trustee to Act in Any Foreign Country on Behalf of the

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Estate, and (C) Granting Related Relief
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43. Motion of Chapter 11 Trustee for Entry of Order Under 22-50073; 636 Bankruptcy Rule 2004 and Local Rule 2004-1 Authorizing Examination of Ho Wan Kwok and Production of Documents 44. Omnibus Motion of Chapter 11 Trustee for Entry of Order 22-50073; 637 Under Bankruptcy Rule 2004 and Local Rule 2004-1 Authorizing Discovery With Respect to Various Legal and

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Financial Advisors to the Debtor
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45. Omnibus Motion of Chapter 11 Trustee for Entry of Order 22-50073; 638 Under Bankruptcy Rule 2004 and Local Rule 2004-1 Authorizing Discovery With Respect to Various Entities and

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Individuals Affiliated with Debtor
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46. Debtor's Response to Motion of Chapter 11 Trustee for Entry 22-50073; 643 of Order, Pursuant to Bankruptcy Code Sections 363, 541, 1108, and 1505, (A) Confirming That Chapter 11 Trustee Holds All of the Debtor's Economic and Corporate Governance Rights in Debtor-Controlled Entities, (B) Authorizing Chapter 11 Trustee to Act in Any Foreign Country on Behalf of the Estate, and (C) Granting Related

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Relief
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47. Debtor's Objection to Revised Proposed Order, Pursuant to 22-50073; 678 Bankruptcy Code Sections 363, 521, 541, 1108, and 105, (A) Confirming That Chapter 11 Trustee Holds All of the Debtor's Economic and Corporate Governance Rights in Debtor-Controlled Entities, (B) Authorizing Chapter 11 Trustee to Act in Any Foreign Country on Behalf of the

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Estate, and (C) Granting Related Relief 48. Notice of Appeal 22-50073; 711
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49. Amended Notice of Appeal 22-50073; 715

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50. Notice of Appeal 22-50073; 723
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51. Order Granting Chapter 11 Trustee's Application for Rule 22-50073; 756

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2004 Discovery With Respect to Various Legal and Financial

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Advisors to the Debtor
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52. Order granting Chapter 11 Trustee's Application for Rule 22-50073; 757

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2004 Examination of Ho Wan Kwok
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53. Order Granting Chapter 11 Trustee's Application for Rule 22-50073; 758 2004 Discovery With Respect to Various Entities and

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Individuals Affiliated With Debtor
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54. First Supplemental Omnibus Motion of Chapter 11 Trustee 22-50073; 839 for Entry of Order Under Bankruptcy Rule 2004 and Local Rule 2004-1 Authorizing Discovery With Respect to Additional Legal and Financial Advisors to the Debtor, Entities and Individuals Affiliated with Debtor, and Relevant

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Banks
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55. Order Granting First Supplemental Omnibus Motion of 22-50073; 866 Chapter 11 Trustee for Entry of Order Under Bankruptcy Rule 2004 and Local Rule 2004-1 Authorizing Discovery With Respect to Additional Legal and Financial Advisors to the Debtor, Entities and Individuals Affiliated with Debtor, and

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Relevant Banks
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56. Motion of Chapter 11 Trustee for Entry of Order Holding 22-50073; 913 Debtor in Civil Contempt for Failure to Comply with

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Corporate Governance Order
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57. Motion to Quash Third-Party Subpoena to Williams & 22-50073; 1002

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Connolly
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58. Chapter 11 Trustee's Objection to Motion to Quash Third 22-50073; 1023 Party Subpoena to Williams & Connolly and Cross-Motion to

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Compel
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59. Motion of Chapter 11 Trustee for Entry of Order Compelling 22-50073; 1046 Individual Debtor, Mei Guo, HK International Funds Investments (USA) Limited, LLC, Hing Chi Ngok, Greenwich Land LLC, Lamp Capital LLC, and Golden Spring (New York) Ltd. to Comply with Rule 2004 Subpoenas 60. Second Supplemental Omnibus Motion of Chapter 11 Trustee 22-50073; 1116 for Entry of Order Under Bankruptcy Rule 2004 and Local Rule 2004-1 Authorizing Discovery With Respect to Additional Legal and Financial Advisors to the Individual Debtor, Entities and Individuals Affiliated with Debtor, Relevant Banks and Entities Doing Business with Debtor and

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Affiliated Entities
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61. Order Granting Chapter 11 Trustee's Second Supplemental 22-50073; 1184

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Omnibus Motion for 2004 Examination 62. Notice of Appeal 22-50073; 1226
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63. Third Supplemental Omnibus Motion of Chapter 11 Trustee 22-50073; 1259 for Entry of Order Under Bankruptcy Rule 2004 and Local Rule 2004-1 Authorizing Discovery With Respect to

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Additional Entities and Individuals Affiliated with Debtor,

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Relevant Banks and Entities Doing Business with Debtor and

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Affiliated Entities
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64. Motion for Order Removing Trustee 22-50073; 1274 65. HCHK Technologies, Inc. HCHK Property Management, Inc. 22-50073; 1291 and Lexington Property and Staffing, Inc. Objection to Production Request, Motion to Quash and/or Motion to

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Modify 2004 Examination Subpoenas
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66. Motion to Quash Third-Party Subpoena to Ivey, Barnum & 22-50073; 1301

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O'Mara, LLC
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67. Motion of Chapter 11 Trustee for Entry of Order Compelling 22-50073; 1303 JPMorgan Chase Bank N.A. to Comply with Rule 2004

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Subpoena
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68. Order Granting Third Supplemental Omnibus Motion of 22-50073; 1339 Chapter 11 Trustee for Entry of Order Under Bankruptcy Rule 2004 and Local Rule 2004-1 Authorizing Discovery With Respect to Additional Entities and Individuals Affiliated with Debtor, Relevant Banks and Entities Doing Business with

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Debtor and Affiliated Entities
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69. Emergency Motion of Chapter 11 Trustee and Genever 22-50073; 1345 Debtors for Entry of Order (A) Compelling Individual Debtor to Comply With Preliminary Injunction Respect to Claims Process, (B) Quashing Individual Debtors' Objections to Claims, and (C) Barring Individual Debtor from Filing Further Objections to Claims, Absent Leave of Court 70. Order Granting in Part Motion to Compel Compliance with 22-50073; 1353

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Rule 2004 Subpoenas
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71. Motion of Chapter 11 Trustee for Entry of Order Compelling 22-50073; 1362

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UBS AG to Comply with Rule 2004 Subpoena
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72. Order Granting Motion to Hold Debtor in Contempt of 22-50073; 1372

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Corporate Governance Order
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73. Order to Appear and Show Cause Why the Court Should Not 22-50073; 1397 Hold the Non-Responding Parties in Contempt of Court

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74. Notice of Appeal 22-50073; 1443
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75. Notice of Filing of Declaration of Mr. Ho Wan Kwok 22-50073; 1444 Concerning Invocation of 5th Amendment Privilege in Regard

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to Rule 2004 Discovery
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76. Motion of Chapter 11 Trustee for Order to Show Cause why 22-50073; 1453 Debtor, Mei Guo, and HK (USA) Should Not Be Held in Contempt of Court for Failure to Comply With Order Compelling Compliance with Rule 2004 Subpoenas and

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Sanctioned for Such Contempt
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77. Order Granting in Part Motion For Order to Appear and Show 22-50073; 1455 Cause Why the Court Should Not Hold the HK Parties in

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Contempt of Court
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78. Notice of Jiaming Liu's Motion to Quash Subpoena 22-50073; 1465

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79. Chapter 11 Trustee's Objection to Motion to Quash Third 22-50073; 1487

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Party Subpoena to Jiaming Liu and Cross-Motion to Compel 80. Declaration of Lee Vartan, Esq. In Opposition to Trustee's 22-50073; 1512 Order to Show Cause Regarding Compliance with Rule 2004

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Subpoenas and January 20, 2023 Order
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81. Motion of Chapter 11 Trustee for Entry of Order Compelling 22-50073; 1521 TD Bank, M.A. to Comply with Rule 2004 Subpoena 82. Order Holding HK Parties in Contempt of Court and 22-50073; 1537 Sanctioning HK Parties, Attorney Vartan and Chiesa

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Shahinian & Giantomasi PC
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83. Notice of Himalaya Investment LLC's Motion to Quash 22-50073; 1541

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Subpoena
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84. Order to Appear at Continued Hearing and Show Cause Why 22-50073; 1546 the Court Should Not Hold the Non-Responding Parties in

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Contempt of Court
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85. Chapter 11 Trustee's Objection to Motion to Quash Third 22-50073; 1576 Party Subpoena to Himalaya Investment LLC and Cross

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Motion to Compel
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86. Fourth Supplemental Omnibus Motion of Chapter 11 Trustee 22-50073; 1592 for Entry of Order Under Bankruptcy Rule 2004 and Local Rule 2004-1 Authorizing Discovery With Respect to Additional Entities and Individuals Affiliated with Debtor, Relevant Banks and Entities Doing Business with Debtor and

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Affiliated Entities 87. Notice of Appeal 22-50073; 1595
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88. Notice of Withdrawal of Motion for Order Removing Trustee 22-50073; 1635 89. Order Granting Fourth Supplemental Omnibus Motion of 22-50073; 1646 Chapter 11 Trustee for Entry of Order Under Bankruptcy Rule 2004 and Local Rule 2004-1 Authorizing Discovery With Respect to Additional Entities and Individuals Affiliated with Debtor, Relevant Banks and Entities Doing Business with

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Debtor and Affiliated Entities
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90. Order Holding Golden Spring and Lamp Capital in Contempt 22-50073; 1709

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of Court 91. Notice of Appeal 22-50073; 1750
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92. Fifth Supplemental Omnibus Motion of Chapter 11 Trustee 22-50073; 1789 for Entry of Order Under Bankruptcy Rule 2004 and Local Rule 2004-1 Authorizing Discovery With Respect to Additional Entities and Individuals Affiliated with Debtor, and Entities Doing Business with Debtor and Affiliated

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Entities
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93. Motion of Chapter 11 Trustee for Entry of Order Compelling 22-50073; 1805 GTV Media Group, Inc., Saraca Media Group, Inc., and G Club Operations LLC to Comply with Rule 2004 Subpoenas and for Entry of an Order Holding G-Club US Operations LLC, G-Club US Operations Inc., Hudson Diamond NY LLC,

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Hudson Diamond Holding LLC, G-Fashion LLC, Gnews

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LLC, US Himalaya Capital Inc., New York MOS Himalaya LLC, Crane Advisory Group LLC, and Maywind Trading LLC in Civil Contempt for Failing to Respond to Rule 2004

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Subpoenas
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94. G Club Operations LLC's Motion to Extend Time to Respond 22-50073; 1845 to Trustee's Motion to Compel Compliance with Rule 2004

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Subpoena and Continue Hearing Date
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95. G Club Operations LLC's (1) Preliminary Objection to 22-50073; 1846 Trustee's Motion to Compel and (2) Motion to Modify Rule

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2004 Subpoena
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96. Order Granting Chapter 11 Trustee's Fifth Supplemental 22-50073; 1891

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Omnibus Motion for 2004 Examination
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97. Order Granting in Part Motion for Entry of Order Holding 22-50073; 1892 Non-Responding Parties in Civil Contempt of Court 98. Order Requiring GTV Media, Inc., Saraca Media Group, Inc. 22-50073; 1893 and Attorney Aaron A. Mitchell to Appear and Show Cause Why GTV Media, Inc. and Saraca Media Group, Inc. Should

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Not Be Held in Civil Contempt of Court
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99. Consent Order Regarding Motion of Chapter 11 Trustee For 22-50073; 1896 Entry of an Order Holding Hudson Diamond NY LLC and Hudson Diamond Holding LLC in Civil Contempt for Failing

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to Respond to Rule 2004 Subpoenas
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100. Emergency Motion of Chapter 11 Trustee for Entry of Order, 22-50073; 1912 Pursuant to Bankruptcy Rules 9014(c) and 9016, Quashing Subpoenas and Confirming that HK Parties and Not Entitled to Discovery in Connection with Trustee's Lady May Sale

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Motion
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101. Order Granting Motion to Compel G-Club to Comply with 22-50073; 1960

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Rule 2004 Subpoena
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102. G Club Operations LLC's Notice Re: Motion, Pursuant to 22-50073; 1977 Bankruptcy Rule 9019, Regarding Settlement with Assignee of HCHK Entities Under New York Court Assignment

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Proceedings
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103. Order Granting in Part Motion for Entry of Order Holding 22-50073; 2009 Hudson Diamond NY LLC in Civil Contempt of Court 104. Memorandum of Decision and Order Holding Individual 22-50073; 2035 Debtor in Contempt of Court and Denying Motion for Stay of

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Order Compelling Production
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105. Order Requiring Mei Guo to Appear and Show Cause Why 22-50073; 2036 Hudson Diamond Holding LLC Should Not Be Held in

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Contempt of Court 106. Notice of Appeal 22-50073; 2072
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107. Sixth Supplemental Omnibus Motion of Chapter 11 Trustee 22-50073; 2079 for Entry of Order Under Bankruptcy Rule 2004 and Local Rule 2004-1 Authorizing Discovery With Respect to

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Additional Entities and Individuals Affiliated with Debtor,

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and Relevant Banks
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108. Supplemental Motion to Hold GTV Media Group, Inc. and Saraca Media Group, Inc. in Civil Contempt of Court for 22-50073; 2080 Failing to Respond to Rule 2004 Subpoenas 109. Declaration of Mei Guo, As Sole Member of Hudson 22-50073; 2092 Diamond Holding LLC in Response to the Court's July 28,

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2023 Order
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110. Order Granting Motion to Hold GTV Media Group, Inc. and 22-50073; 2093 Saraca Media, Inc. in Civil Contempt for Failure to Comply

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With Rule 2004 Subpoenas
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111. Application of Chapter 11 Trustee For Entry of order Pursuant 22-50073; 2162 to Bankruptcy Code Sections 327 and 330, Bankruptcy Rules 2014 and 2016 and Local Bankruptcy Rules 2014-1 and 2016- 1 Authorizing and Approving Retention and Appointment of Kroll, LLC as Forensic Investigators, Effective as of August

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2, 2023
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112. Order Granting Chapter 11 Trustee's Sixth Supplemental 22-50073; 2210

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Omnibus Motion for Rule 2004 Subpoena
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113. Order Sustaining in Part Objection to Proposed Supplemental

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Order 22-50073; 2237
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114. Order Granting Application of Chapter 11 Trustee For Entry 22-50073; 2241 of order Pursuant to Bankruptcy Code Sections 327 and 330, Bankruptcy Rules 2014 and 2016 and Local Bankruptcy Rules 2014-1 and 2016-1 Authorizing and Approving Retention and Appointment of Kroll, LLC as Forensic Investigators, Effective as of August 2, 2023 115. G Club Operations LLC's Response to Trustee's 22-50073; 2244 Memorandum Challenging G Club's Privilege Assertions in Documents in HCHK's Possession and Opposition to the

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Trustee's Related Proposed Order
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116. Seventh Supplemental Omnibus Motion of Chapter 11 22-50073; 2249 Trustee for Entry of Order Under Bankruptcy Rule 2004 and Local Rule 2004-1 Authorizing Discovery With Respect to

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Additional Relevant Banks
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117. Emergency Motion of Chapter 11 Trustee for Status 22-50073; 2277 Conference to Discuss Preservation of Property of Estate 118. Order Granting Seventh Supplemental Omnibus Motion of 22-50073; 2281 Chapter 11 Trustee for Entry of Order Under Bankruptcy Rule 2004 and Local Rule 2004-1 Authorizing Discovery With

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Respect to Additional Relevant Banks
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119. Eighth Supplemental Omnibus Motion of Chapter 11 Trustee 22-50073; 2304 for Entry of Order Under Bankruptcy Rule 2004 and Local Rule 2004-1 Authorizing Discovery With Respect to

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Additional Relevant Banks
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120. Ninth Supplemental Omnibus Motion of Chapter 11 Trustee 22-50073; 2308

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for Entry of Order Under Bankruptcy Rule 2004 and Local Rule 2004-1 Authorizing Discovery With Respect to Additional Entities and Individuals Affiliated with Debtor and

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Entities Doing Business With Debtor 121. Notice of Appeal 22-50073; 2336
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122. Motion of Chapter 11 Trustee for Entry of Order Compelling 22-50073; 2342 Seacoast Bank to Comply with Rule 2004 Subpoena 123. Order Granting Eighth Supplemental Omnibus Motion of 22-50073; 2393 Chapter 11 Trustee for Entry of Order Under Bankruptcy Rule 2004 and Local Rule 2004-1 Authorizing Discovery With

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Respect to Additional Relevant Banks
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124. Order Granting Ninth Supplemental Omnibus Motion of 22-50073; 2394 Chapter 11 Trustee for Entry of Order Under Bankruptcy Rule 2004 and Local Rule 2004-1 Authorizing Discovery With Respect to Additional Entities and Individuals Affiliated with Debtor and Entities Doing Business With Debtor 125. Motion of Chapter 11 Trustee For Entry of Order Compelling 22-50073; 2396 DBS Bank Ltd. to Comply With Rule 2004 Subpoena 126. Tenth Supplemental Omnibus Motion of Chapter 11 Trustee 22-50073; 2434 for Entry of Order Under Bankruptcy Rule 2004 and Local Rule 2004-1 Authorizing Discovery With Respect to

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Additional Relevant Banks
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127. Order Granting Tenth Supplemental Omnibus Motion of 22-50073; 2474 Chapter 11 Trustee for Entry of Order Under Bankruptcy Rule 2004 and Local Rule 2004-1 Authorizing Discovery With

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Respect to Additional Relevant Banks
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128. Eleventh Supplemental Omnibus Motion of Chapter 11 22-50073; 2508 Trustee for Entry of Order Under Bankruptcy Rule 2004 and Local Rule 2004-1 Authorizing Discovery With Respect to Additional Entities and Individuals Affiliated with Debtor and

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Entities Doing Business With Debtor
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129. Twelfth Supplemental Omnibus Motion of Chapter 11 Trustee 22-50073; 2514 for Entry of Order Under Bankruptcy Rule 2004 and Local Rule 2004-1 Authorizing Discovery With Respect to

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Additional Relevant Banks
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130. Order Granting Eleventh Supplemental Omnibus Motion of 22-50073; 2534 Chapter 11 Trustee for Entry of Order Under Bankruptcy Rule 2004 and Local Rule 2004-1 Authorizing Discovery With Respect to Additional Entities and Individuals Affiliated with Debtor and Entities Doing Business With Debtor 131. Order Granting Twelfth Supplemental Omnibus Motion of 22-50073; 2537 Chapter 11 Trustee for Entry of Order Under Bankruptcy Rule 2004 and Local Rule 2004-1 Authorizing Discovery With

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Respect to Additional Relevant Banks
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132. Deposition transcript for Mei Guo dated November 1, 2023 23-05008; 89-30 UNITED STATES BANKRUPTCY COURT DISTRICT OF CONNECTICUT BRIDGEPORT DIVISION

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In re: :

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: Chapter 11
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HO WAN KWOK, et al.,1 :

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: Case No. 22-50073 (JAM)
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Debtors. : :

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: (Jointly Administered)
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CERTIFICATE OF SERVICE
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The undersigned hereby certifies that on February 12, 2024, the foregoing Motion was electronically filed. Notice of this filing was sent by e-mail to all parties to the above-captioned proceeding by operation of the Court's electronic filing ("CM/ECF") system or by mail to anyone unable to accept electronic filing as indicated on the Notice of Electronic Filing.2 Parties may access this filing through the Court's CM/ECF system.

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Dated: February 12, 2024
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Washington, D.C. By: /s/ Nicholas A. Bassett Nicholas A. Bassett (admitted pro hac vice) PAUL HASTINGS LLP 2050 M Street NW Washington, D.C., 20036 (202) 551-1902 nicholasbassett@paulhastings.com

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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. The mailing address for the Trustee, Genever Holdings LLC, and the Genever Holdings Corporation is Paul Hastings LLP, 200 Park Avenue, New York, NY 10166 c/o Luc A. Despins, as Trustee for the Estate of Ho Wan Kwok (solely for purposes of notices and communications).

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2 To the extent that the foregoing was filed outside regular business hours, service by mail on recipients unable or not qualified to accept electronic notice was made on the next business day.

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