Guo Wengui / Miles Guo — bankruptcy case · ORDER · ECF #2928

UNITED STATES BANKRUPTCY COURT DISTRICT OF CONNECTICUT BRIDGEPORT DIVISION

------------------------------------------------------ x

In re: : :

HO WAN KWOK, et al., :

Debtors.1 :

------------------------------------------------------ x COVERSHEET FOR FIRST INTERIM FEE APPLICATION OF O'SULLIVAN MCCORMACK JENSEN & BLISS PC

Interim Application of: O'Sullivan McCormack Jensen & Bliss PC

Time Period: July 27, 2023 through December 31, 2023 Bankruptcy Petition Filed: February 15, 2022 Date of Entry of Retention Order: August 22, 2023 [Docket No. 2241] (effective as of July 27, 2023).

Fees: \$191,730.00 Voluntary Fee Reductions: \$1,105.00 Expenses: \$5,240.02 Voluntary Expenses Reductions:

Fees Previously Requested: Retainer Request:

Expenses Previously Requested: Expense Detail: Requested Expenses: \$0.00 Retainer Received: Not applicable Awarded Expenses: \$0.00 Copies per page cost & total: Not applicable

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 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).

2 As detailed below, \$148,426.00 in fees and \$4,857.18 in expenses were previously paid in accordance with the Interim Compensation Order and the Monthly Fee Statements (each as defined below).

Sought \$98,125.00 \$78,500.00 \$1,748.56

Reductions (\$1,105.00) (\$884.00) No reductions

Requested \$97,020.00 \$77,616.00 \$1,748.56 \$77,616.00 \$1,748.56 \$19,404.00

Requested \$34,200.00 \$27,360.00 \$1,174.76

Reductions No reductions No reductions No reductions

Requested \$34,200.00 \$27,360.00 \$1,174.76 \$27,360.00 \$1,174.76 \$6,840.00

Requested \$24,677.50 \$19,742.00 \$321.45

Reductions No reductions No reductions No reductions

Requested \$24,677.50 \$19,742.00 \$321.45 \$19,742.00 \$321.45 \$4,935.50

Requested \$29,635.00 \$23,708.00 \$1,614.41

Reductions No reductions No reductions No reductions

Requested \$29,635.00 \$23,708.00 \$1,614.41 \$23,708.00 \$1,614.41 \$5,927.00

Requested \$6,197.50 \$4,958.00 \$380.84

Reductions No reductions No reductions No reductions

Requested \$6,197.50 \$4,958.00 \$380.84 \$6,197.50 \$380.84 \$1,239.50

Requested \$192,835.00 \$154,268.00 \$5,240.02

Requested \$191,730.00 \$153,384.00 \$5,240.02 \$154,623.50 \$5,240.02 \$38,346.00

UNITED STATES BANKRUPTCY COURT DISTRICT OF CONNECTICUT BRIDGEPORT DIVISION

------------------------------------------------------ x

In re: :

HO WAN KWOK, et al., :

Debtors.1 : :

------------------------------------------------------ x **FIRST INTERIM FEE APPLICATION OF O'SULLIVAN MCCORMACK JENSEN & BLISS PC, AS SPECIAL INSURANCE COVERAGE COUNSEL, FOR COMPENSATION AND REIMBURSEMENT OF EXPENSES FOR PERIOD FROM JULY 27, 2023 THROUGH DECEMBER 31, 2023**

Pursuant to sections 105(a), 328, 330, and 331 of title 11 of the United States Code (such title, hereinafter, the "Bankruptcy Code"), Rule 2016 of the Federal Rules of Bankruptcy Procedure (the "Bankruptcy Rules"), Rule 2016-1 of the Local Rules of Bankruptcy Practice and Procedure of the United States Bankruptcy Court for the District of Connecticut (the "Local Rules"), and the *Order Establishing Procedures for Interim Compensation and Reimbursement of Expenses for Retained Professionals, dated August 18, 2023* [Docket No. 2094] (the "Interim Compensation Order"), O'Sullivan McCormack Jensen & Bliss PC ("OMJB"), as special insurance coverage counsel for Genever Holdings LLC ("Genever (US)"), hereby files this *First Interim Application of O'Sullivan McCormack Jensen & Bliss PC, as Special Insurance Coverage Counsel, for Compensation and Reimbursement of Expenses for the Period from July*

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 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).

*27, 2023 through December 31, 2023* (the "Application"). By this Application, OMJB requests interim allowance of professional fees incurred during the period from July 27, 2023 through and including December 31, 2023 (the "Application Period") Genever (US)'s chapter 11 case. In support of this Application, OMJB respectfully states as follows: JURISDICTION, VENUE, BASES FOR RELIEF, AND COMPLIANCE

1. The Court has jurisdiction over this matter pursuant to 28 U.S.C. §§ 157 and 1334 and the Standing Order of Reference from the United States District Court for the District of Connecticut. This matter is a core proceeding within the meaning of 28 U.S.C. § 157(b)(2). Venue is proper pursuant to 28 U.S.C. §§ 1408 and 1409.

2. The legal predicates for the relief requested herein are sections 328, 330, and 331 of the Bankruptcy Code, Bankruptcy Rule 2016, and Local Rule 2016-1.

3. OMJB believes that this Application, together with the attachments hereto, substantially complies with the Bankruptcy Rules, Local Rule 2016-1, and the *United States Trustee's Guidelines for Reviewing Applications for Compensation and Reimbursement of Expenses Filed Under 11 U.S.C. § 330 by Attorneys in Larger Chapter 11 Cases* (the "U.S. Trustee Guidelines").2 OMJB respectfully requests a waiver of any of the foregoing requirements not met by this Application.

- 4. Attached and incorporated herein by reference are the following Exhibits: - Exhibit A contains the Proposed Order granting this Application. - Exhibit B is a timekeeper summary that includes the name, title, bar admission, hourly billing rate, aggregate hours, and amount of fees earned for each OMJB individual who provided services during the Application Period;

2 OMJB reserves all rights as to the relevance and substantive legal effect of the U.S. Trustee Guidelines with respect to any application for compensation in these chapter 11 cases.

- Exhibit C is a summary of expenses incurred and reimbursement sought, by expense type, during the Application Period; and - Exhibit D contains the detail of the fees and expenses incurred during the Application Period.

5. On October 12, 2020, Genever (US) filed a voluntary petition for relief under chapter 11 of title 11 of the United States Bankruptcy Code before the United States Bankruptcy Court for the Southern District of New York (the "SDNY Bankruptcy Court"), thereby commencing case number 20-12411 (JLG). See Chapter 11 Petition [Docket No. 1 in Case No. 22-50592 (JAM)].

6. No trustee or examiner has been appointed in Genever (US)'s case.

7. On February 15, 2022 (the "Petition Date"), Ho Wan Kwok (the "Individual

Debtor") filed a voluntary petition for relief under the Bankruptcy Code in the United States Bankruptcy Court for the District of Connecticut (Bridgeport Division) (the "Court").

8. On March 21, 2022, the United States Trustee appointed an Official Committee of Unsecured Creditors (the "Committee") in the Individual Debtor's chapter 11 case. No examiner has been appointed in the Individual Debtor's chapter 11 case.

9. On June 15, 2022, the Court entered a memorandum of decision and order [Docket No. 465] (the "Trustee Order") directing the United States Trustee to appoint a chapter 11 trustee in the Individual Debtor's chapter 11 case.

10. Pursuant to the Trustee Order, the United States Trustee selected Luc A. Despins as the Trustee. On July 8, 2022, the Court entered an order granting the appointment of Luc A. Despins as trustee (the "Trustee") in the Individual Debtor's chapter 11 case

11. On November 3, 2022, the SDNY Bankruptcy Court entered an order transferring the venue of Genever (US)'s chapter 11 case to this Court. *See Memorandum Decision and Order Granting the Joint Motion of (A) Genever Holdings LLC and (B) Luc A. Despins as Chapter 11 Trustee for Estate of Ho Wan Kwok to Transfer, Pursuant to 28 U.S.C. §§ 1408, and 1412 and Bankruptcy Rule 1014(a), Venue of Chapter 11 Case of Genever Holdings LLC to Bankruptcy Court for District of Connecticut* [Docket No. 225 in Case No. 22-50592 (JAM)].

12. The chapter 11 cases of the Individual Debtor, Genever (US), and Genever Holdings Corporation ("Genever (BVI)") are being jointly administered before this Court for procedural purposes only. See Docket No. 1141 in Case No. 22-50073 (JAM).

13. By order entered August 22, 2023, the Court authorized OMJB's retention as special insurance coverage counsel to Genever (US) [Docket No. 2105] (the "Retention Order") effective as of July 27, 2023 in Genever (US)'s chapter 11 case. The Retention Order authorizes OMJB to be compensated on an hourly basis and reimbursed for actual and necessary out-ofpocket expenses pursuant to sections 328 and 330 of the Bankruptcy Code, the Bankruptcy Rules, the Local Rules, and such orders as the Court may direct.

14. On August 18, 2023, the Court entered the Interim Compensation Procedures Order, which, among other things, approves procedures for the payment of 80% of fees and 100% of expenses on a monthly basis.

15. In accordance with the Interim Compensation Procedures Order, on October 20, 2023, OMJB filed and served its first monthly fee statement [Docket No. 2271] (the "August Fee Statement") requesting payment of 80% of all fees and 100% of all expenses actually and necessarily incurred for services rendered during the period from July 27, 2023 through August

31, 2023, in the amounts of \$78,500.00 (80% of \$98,125.00) and \$1,748.56, respectively. No objections were filed in response to the August Fee Statement. However, after discussions with the United States Trustee, OMJB agreed to reduce its fees by \$1,105.00, which (after taking into account that OMJB sought payment of only 80% of its fees) translates into a reduction of \$884.00 (or \$77,616.00 in fees to be paid). Accordingly, the estate has paid OMJB \$79,364.56 for fees and expenses with respect to the August Fee Statement.

16. Also on October 20, 2023, OMJB filed and served its second monthly fee statement [Docket No. 2272] (the "September Fee Statement") requesting payment of 80% of all fees and 100% of all expenses actually and necessarily incurred for services rendered during the period from September 1, 2023 through September 30, 2023, in the amounts of \$27,360.00 (80% of \$34,200) and \$1,174.76, respectively. No objections were filed in response to the September Fee Statement. Accordingly, the estate has paid OMJB \$28,543.76 for fees and expenses with respect to the September Fee Statement.

17. On November 20, 2023, OMJB filed and served a monthly fee statement [Docket No. 2355] (the "October Fee Statement") requesting payment of 80% of all fees and 100% of all expenses actually and necessarily incurred for services rendered during the period from October 1, 2023 through October 31, 2023, in the amounts of \$19,742.00 (80% of 24,677.50) and \$321.45, respectively. No objections were filed in response to the October Fee Statement. Accordingly, the estate has paid OMJB \$20,063.45 for fees and expenses with respect to the October Fee Statement.

18. On December 20, 2023, OMJB filed and served a monthly fee statement [Docket No. 2459] (the "November Fee Statement") requesting payment of 80% of all fees and 100% of all expenses actually and necessarily incurred for services rendered during the period from

November 1, 2023 through November 30, 2023, in the amounts of \$23,708.00 (80% of \$29,635.00) and \$1,614.41, respectively. No objections were filed in response to the November Fee Statement. Accordingly, the estate has paid \$25,322.41 for fees and expenses with respect to the November Fee Statement.

19. On January 19, 2024, OMJB filed and served a monthly fee statement [Docket No. 2511] (the "December Fee Statement" and, together with the August Fee Statement, the September Fee Statement, the October Fee Statement, and the November Fee Statement, the "Monthly Fee Statements") requesting payment of 80% of all fees and 100% of all expenses actually and necessarily incurred for services rendered during the period from December 1, 2023 through December 31, 2023, in the amounts of \$4,958.00 (80% of \$6,197.50) and \$380.84, respectively. No objections were filed in response to the December Fee Statement. Accordingly, the estate has paid OMJB \$5,338.84 for fees and expenses with respect to the December Fee Statement.

20. The Applicant is applying for compensation pursuant to Sections 330 and 331 of the Bankruptcy Code for legal services performed for Genever (US) during the Application Period.

21. For the Application Period, the Applicant seeks allowance of \$191,730.00 as compensation for services rendered and allowance and reimbursement of \$5,240.02 in expenses incurred in connection with such services.3 The Applicant devoted 539.2 hours to this case during the Application Period, equating to an overall blended rate of \$355.58.

3 For the avoidance of doubt, these fees and expenses sought reflected the reductions agreed upon with the United States Trustee.

22. As noted, OMJB has already received payment of \$154,623.50 of the fees incurred during the Application Period and \$5,240.02 of the expenses incurred during the Application Period, such that OMJB is only seeking payment the remaining 20% of its fees incurred during the Application Period, namely \$38,346.00.

23. Throughout the Application Period, the Applicant maintained records to indicate the name of each professional working on this matter, the time spent on a particular issue, and the nature of the work performed. These records, which describe in detail the services rendered by the Applicant, were created at the approximate time the services were performed.

24. Annexed hereto and made a part hereof as Exhibit D is a detailed billing report, upon which this application is based that contains each individual professional's time for Genever (US)'s bankruptcy proceedings, itemizing the dates upon which services were rendered, including a summary of the services on each of such dates by each person rendering the service, the time spent in rendering such service, and the dollar value of such services. The time detail attached hereto as Exhibit D include certain redactions to protect against the disclosure of privileged or confidential information.

25. OMJB replaced Saxe Doernberger & Vita, P.C. ("SDV") as special insurance coverage counsel for Genever (US) in its pending litigation against American International Group, Inc. ("AIG") under Adv. Proc. No. 23-5007 (the "AIG Action"), and since OMJB's retention continued the representation of Genever (US) with respect to insurance coverage advice and litigation services to recover insurance benefits claimed to be due to Genever (US) for losses it sustained as well as to any matters related to the AIG Action.

26. OMJB has worked closely with Genever (US) to continue its prosecution of the AIG Action, reviewing documents and pleadings to get up to speed with the case. OMJB has also performed extensive legal research and drafted research memos in connection with issues in the case, as well as opposing an appeal by AIG of the preliminary injunction entered on July 13, 2023.

27. Most significantly, OMJB drafted and filed a motion for partial summary judgment in the AIG Action, seeking an order from the Court: (i) declaring that AIG must provide property insurance coverage to Genever (US) under homeowner insurance policy no. PCG 0061821440 for its losses arising from a fire that occurred on March 15, 2023 and (ii) awarding Genever (US) property coverage under its homeowner insurance policy no. PCG 0061821440 issued for the period March 6, 2023 to March 6, 2024 for its fire property losses. That motion has been fully briefed, with a hearing having been held, and is pending before the Court.

28. Additionally, OMJB also drafted and filed a brief regarding AIG's obligation to reinstate a policy of excess insurance in accordance with this Court's Memorandum of Decision and Order Granting Motion for Preliminary Injunction in the AIG Action.

29. OMJB has also engaged in written discovery, issuing third party subpoenas, responding to written discovery requests and reviewing responses to written requests and documents produced through discovery.

30. The work undertaken by OMJB to date has been significant, involving legal research and motion practice, factual analysis and investigations, analysis of legal contracts and discovery documents, correspondence, and strategic input. This work remains ongoing, with additional work expected in due course.

31. No prior application for the relief requested has been made. However, as noted, certain fees and expenses incurred during the Application Period were previously paid in accordance with the Interim Compensation Procedures Order.

32. All of the professional services for which this award is being sought hereby were rendered solely on behalf of Genever (US) in connection with the chapter 11 cases herein.

33. Applicant respectfully submits that its services have benefited Genever (US) with the expertise and skill required in insurance litigation. The services for which such compensation is requested were performed for and on behalf of Genever (US). Such services have been necessary to protect and enforce the rights and interests of Genever (US) in connection with these chapter 11 cases. The reasonable value of services rendered by OMJB in these cases is based upon OMJB' usual hourly rates for matters of this nature.

34. Section 330 of the Bankruptcy Code prescribes the general standards for determining the amount of compensation to be paid to professionals. The Applicant submits that the amount sought for the Application Period represents reasonable compensation for professional services rendered based upon the time spent, the nature, the extent, and the value of such services, taking into account the cost of comparable services in a non-bankruptcy case.

35. Section 331 of the Bankruptcy Code provides for interim compensation of professionals and incorporates the substantive standards of section 330 of the Bankruptcy Code to govern the Court's award of such compensation. Section 330(a) of the Bankruptcy Code provides that, after notice and a hearing, the Court may award a professional employed under 11

U.S.C. § 327 "reasonable compensation for actual, necessary services rendered" and "reimbursement for actual, necessary expenses." 11 U.S.C. § 330(a)(1).4

36. In determining the amount of "reasonable compensation," the Court must consider the nature, extent, and value of the services, taking into account all the relevant factors, including the time spent on such services, the rates charged for such services, whether the services were necessary and beneficial, whether the services were performed in a reasonable amount of time commensurate with the complexity, importance, and nature of the problem, issue, or task addressed, and whether the compensation is reasonable based on the customary compensation charged by comparably skilled practitioners in cases other than cases under the Bankruptcy Code. See 11 U.S.C. § 330(a)(3). The Court enjoys "considerable discretion in determining reasonable fee awards." In re Ahead Communication Systems, Inc., 395 B.R. 512 (D. Conn. 2008).

37. In assessing the "reasonableness" of the fees requested, the Second Circuit has stated that courts should consider the factors enumerated in Johnson v. Ga. Highway Express, Inc., 5 while also incorporating the "lodestar method." See Arbor Hill Concerned Citizens Neighborhood Ass'n v. County of Albany and Albany County Bd. of Elections, 522 F.3d 182, 190 (2d Cir. 2007) (citing Johnson v. Ga. Highway Express, Inc., 488 F.2d 714 (5th Cir.1974),

4 Under section 328(a) of the Bankruptcy Code, with bankruptcy court approval, a trustee may employ professional persons under section 327(a) of the Bankruptcy Code "on any reasonable terms and conditions of employment, including on a retainer, on an hourly basis, on a fixed or percentage fee basis, or on a contingent fee basis." 11 U.S.C. § 328(a).

5 The twelve Johnson factors are (1) the time and labor required, (2) the novelty and difficulty of the questions, (3) the skill requisite to perform the legal service properly, (4) the preclusion of other employment by the attorney due to acceptance of the case, (5) the customary fee, (6) whether the fee is fixed or contingent, (7) the time limitations imposed by the client or the circumstances, (8) the amount involved and the results obtained, (9) the experience, reputation, and ability of the attorneys, (10) the "undesirability" of the case, (11) the nature and length of the professional relationship with the client, and (12) awards in similar cases. Johnson, 488 F.2d at 717-19.

abrogated on other grounds by Blanchard v. Bergeron, 489 U.S. 87, 92–93, 96 (1989)). The "lodestar method" of calculating the reasonable fee contemplates "the number of hours reasonably expended . . . multiplied by a reasonable hourly rate." See Hensley v. Eckerhart, 461 U.S. 424, 433 (1983); Gisbrecht v. Barnhart, 535 U.S. 789, 801 (2002); Perdue v. Kenny A., 130 S.Ct. 1662, 1672 (2010); In re Drexel Burnham Lambert Grp., Inc., 133 B.R. 13 (Bankr. S.D.N.Y. 1991). The factors set forth in Johnson and In re First Colonial Corp. of Am., 544 F.2d 1291, 1298–99 (5th Cir. 1977) have been adopted by most courts.6 See In re Nine Assocs., Inc., 76 B.R. 943, 945 (S.D.N.Y. 1987) (adopting First Colonial/Johnson analysis); In re Cuisine Magazine, Inc., 61 B.R. 210, 212–13 (Bankr. S.D.N.Y 1986) (same); Green v. City of New York, 403 F. Appx. 626, 629 (2d Cir. 2010) (summary order); see generally 3 COLLIER ON BANKRUPTCY ¶ 330.03[9] (Lawrence P. King ed., 16th ed. 2016) (describing First Colonial and Johnson as the "leading cases with regard to the factors to be considered in determining a reasonable allowance of compensation").

38. In accordance with the factors enumerated in section 330 of the Bankruptcy Code and applicable case law, the amount requested herein by OMJB is fair and reasonable.

38. No agreement or understanding exists between OMJB and any other person for the sharing of compensation received or to be received for services rendered in or in connection with this matter. OMJB will not, in any form or guise, share or agree to share compensation for services with any person, nor will OMJB share in the compensation for any other person

6 The factors articulated in First Colonial were first articulated by the Fifth Circuit in Johnson, with the First Colonial court adding the factor of the "spirit of economy," which was later rejected by Congress. See Stroock & Stroock & Lavan v. Hillsborough Holdings Corp. (In re Hillsborough Holdings Corp.), 127 F.3d 1398, 1403 (11th Cir. 1997).

rendering service in these cases, except as so provided by Section 504(b) of the Bankruptcy Code and Rule 2016 of the Bankruptcy Rules.

39. To the extent that time or disbursement charges for services rendered or expenses incurred during the Application Period are not included in this Application, or OMJB has for any reason not sought compensation or reimbursement with respect to such services, OMJB reserves the right to request compensation and reimbursement for such services in a supplemental or future application in these chapter 11 cases. Also, OMJB does not waive, and expressly reserves, its right to respond to any objections regarding this Application and the amounts sought for services rendered and expenses incurred.

40. No previous request for the relief sought herein has been made to this Court or any other court.

[THE REMAINDER OF THIS PAGE IS INTENTIONALLY BLANK.]

WHEREFORE, OMJB respectfully requests entry of an order, substantially in the form attached hereto, (i) allowing interim compensation for professional services rendered during the Application Period in the amount of \$191,730 and reimbursement of \$5,240.02 in expenses, (ii) authorizing and directing prompt payment of fees and expenses from the estate, to the extent not already paid, (iii) allowing such compensation and payment for professional services rendered without prejudice to OMJB's right to seek further compensation and/or payment from the estates for the full value of services performed and expenses incurred, and (iv) granting OMJB such other and further relief as is just.

Dated: February 16, 2024 Glastonbury, Connecticut

Michael T. McCormack (ct13799) O'Sullivan McCormack Jensen & Bliss PC 180 Glastonbury Boulevard, Suite 210 Glastonbury, CT 06033 Tel: 860-258-1993 Fax: 860-258-1991 mmccormack@omjblaw.com

Special Insurance Coverage Counsel for Debtor-In-Possession Genever Holdings LLC IN THE UNITED STATES BANKRUPTCY COURT FOR THE DISTRICT OF CONNECTICUT BRIDGEPORT DIVISION

In re:

The undersigned hereby certifies that on February 16, 2024, the *First Interim Application of O'Sullivan McCormack Jensen & Bliss PC, as Special Insurance Coverage Counsel, for Compensation and Reimbursement of Expenses for the Period from July 27, 2023 through December 31, 2023* (the "Application")2 was electronically filed. Notice of this filing was sent by e-mail to all parties to the above-captioned Chapter 11 Cases 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.3 In addition, to the extent not covered by the foregoing, copies of the Application were served on the twenty (20) largest creditors in Genever (US)'s chapter 11 case. Parties may access this filing through the Court's CM/ECF system.

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 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).

2 Capitalized terms used but not defined in this Certification shall have the meanings ascribed to them in the Application.

3 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.

Dated: February 16, 2024 New York, New York By: /s/ G. Alexander Bongartz

G. Alexander Bongartz (pro hac vice) Douglass Barron (pro hac vice) PAUL HASTINGS LLP 200 Park Avenue New York, New York 10166 (212) 318-6079 alexbongartz@paulhastings.com douglassbarron@paulhastings.com

Case 22-50073 Doc 2928 Filed 02/16/24 Entered 02/16/24 16:10:56 Page 18 of 47

UNITED STATES BANKRUPTCY COURT DISTRICT OF CONNECTICUT BRIDGEPORT DIVISION

-------------------------------------------------------------- x

In re: : :

HO WAN KWOK, et al., : :

Debtors.1 : :

**[PROPOSED] ORDER GRANTING FIRST INTERIM FEE APPLICATION OF O'SULLIVAN MCCORMACK JENSEN & BLISS PC, AS SPECIAL INSURANCE COVERAGE COUNSEL, FOR COMPENSATION AND REIMBURSEMENT OF EXPENSES FOR PERIOD FROM JULY 27, 2023 THROUGH DECEMBER 31, 2023**

Upon consideration of the Application (the "Application") of O'Sullivan McCormack Jensen & Bliss PC ("OMJB"), as special insurance coverage counsel for Genever Holdings LLC ("Genever (US)"),2 for interim allowance of compensation and reimbursement of expenses from July 27, 2023 through December 31, 2023; and sufficient notice having been given; and a hearing having been held on \_\_\_\_\_\_\_\_, 2024 and due consideration having been given to any responses thereto; and sufficient cause having been shown therefor, it is hereby:

1. ORDERED that the Application is granted and compensation in the amount of

\$191,730.00 and reimbursement of expenses in the amount of \$5,240.02 are awarded to OMJB,

subject to final adjustment and disgorgement in the event all administrative expenses are not paid

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 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).

2 Capitalized terms not otherwise defined herein adopt the definitions set forth in the Application.

2. ORDERED that nothing herein modified the Retention Order; it is further

3. ORDERED that the estates are authorized and directed to pay OMJB's fees in the amount of \$38,346.00, i.e., 20% of the fees allowed in paragraph 1 above, within fourteen days of the date of this Order; it is further

4. ORDERED that this Court shall retain jurisdiction to hear and determine all matters arising from the implementation of this Order; it is further

5. ORDERED that Genever (US)'s estate and OMJB are authorized and empowered to take all necessary actions to implement the relief granted in this Order; it is further

6. ORDERED that notwithstanding the possible applicability of Bankruptcy Rules 6006(d), 7062, 9014, or otherwise, the terms and conditions of this Order shall be immediately effective and enforceable upon its entry; and it is further

7. ORDERED that all time periods set forth in this Order shall be calculated in accordance with Bankruptcy Rule 9006(a).

Case 22-50073 Doc 2928 Filed 02/16/24 Entered 02/16/24 16:10:56 Page 21 of 47

TIMEKEEPER DATE OF TITLE HOURS HOURLY TOTAL

Timothy P. Jensen 1997 Shareholder 168.1 \$450.00 \$75,645 Amy Markim 2008 Shareholder 106.5 \$350.00 \$37,275 Michael T. McCormack 1993 Shareholder 142.2 \$400.00 \$56,880 Michelle Seery 1989 Counsel 44.2 \$300.00 \$13,260 Melissa Gambardella Paralegal 78.2 \$125.00 \$9,774.5

Case 22-50073 Doc 2928 Filed 02/16/24 Entered 02/16/24 16:10:56 Page 23 of 47

Case 22-50073 Doc 2928 Filed 02/16/24 Entered 02/16/24 16:10:56 Page 24 of 47 Case 22-50073 Doc 2271 Filed 10/20/23 Entered 10/20/23 16:54:01 Page 9 of 16

180 Glastonbury Boulevard, Suite 210 Glastonbury, CT 06033 Phone: 860-258-1993 [www.omjblaw.com]

Genever Holdings LLC 200 Park Avenue New York, NY 10166 3726-001-Genever Holdings/AIG Property Casualty

Date Attorney Activity Time Rate Total

07/27/2023 MTM Telephone conference with Luc Despins re status and strategy re coverage litigation 0.70 \$400.00 \$280.00 07/30/2023 MTM Draft application re Genever Holdings retention of OMJB as special counsel and draft declaration of Michael McCormack in support of

07/31/2023 MTM Revise and supplement special counsel retention and application for approval of same (.4); email correspondence to Attny Despins re draft documents (.1); email communications with Saxe Doernberger and Attny Despins re document and file transfer issues (.3); review of revised special counsel retention application (.2) 1.00 \$400.00 \$400.00 07/31/2023 MTM Review and analysis of Genever Holdings interested parties document re conflicts review 0.20 \$400.00 \$80.00 07/31/2023 MTM Review case background information 0.50 \$400.00 \$200.00 07/31/2023 MTM Review of revised draft application to retain OMJB; attention to conflict

07/31/2023 TPJ Review case background information 0.50 \$450.00 \$225.00 07/31/2023 MTM Review of revised draft application to retain OMJB; attention to conflict

08/01/2023 MTM Attention to issues re deadline re opposition to AIG motion to file appeal; review court docket re same 0.30 \$400.00 \$120.00 08/01/2023 AM Review/analyze adversary complaint and decision re: preliminary injunction (1.3); conference with L. Despins, M. McCormack, and T. Jensen re: overview and next steps (1.3); strategy conference with M. McCormack and T. Jensen (1.0). 3.60 \$350.00 \$1,260.00

08/01/2023 MTM Review of complaint, answer, defenses, and AIG Motion for Leave to Appeal received from Saxe Doernberger re factual and legal issues (1.5); conference with L. Despins re status and strategy re AIG adversary proceeding (1.2); attention to issues re motion for summary judgment; discovery and opposition to motion to file appeal (.3) 3.00 \$400.00 \$1,200.00

08/01/2023 MTM Review of amended application for retention of counsel and order re same; attention to conflict issues re relationships re interested parties 0.30 \$400.00 \$120.00 08/01/2023 AM Analysis of policies. 1.30 \$350.00 \$455.00 08/01/2023 MTM Email communications with Attny Bongartz re retention application and interested party conflict review 0.10 \$400.00 \$40.00 08/01/2023 MBG Compare list of SVD documents to files sent to confirm all were received; email to SDV re missing document; begin review of and downloading docket in Adversary Proceeding. . 1.70 \$125.00 \$212.50 08/01/2023 TPJ Review and analysis of background documents and communications re

08/02/2023 AM Continued analysis of policies; review of discovery requests and draft motion to compel. 3.50 \$350.00 \$1,225.00 08/02/2023 MTM Revise McCormack declaration in support of application re retention as

08/02/2023 MTM Telephone conferences and email communications with Attny Despins re application for retention and opposition to AIG motion to file interlocutory

08/02/2023 MBG Further review and downloading pleadings from Adversary Proceeding

08/02/2023 TPJ Outlining projects and deadlines (1.3). Communications re declaration and related filings (.4). Reviewing background information (2.1). 3.80 \$450.00 \$1,710.00 08/03/2023 MTM Revise and supplement special counsel declaration 0.30 \$400.00 \$120.00 08/03/2023 AM Document review and analysis. 4.20 \$350.00 \$1,470.00 08/03/2023 MBG Download Adv. Pro. pleadings; begin drafting AEM, MTM and TPJ appearances for Adv. Pro. and Appeal cases. 1.20 \$125.00 \$150.00 08/03/2023 TPJ Continue reading background documents related to preliminary injunction and appeal of same (2.3). Communications with LD re strategy for opposing motion for leave to appeal (.5). Background legal research re appealing preliminary injunction from bankruptcy court (2.9). 5.70 \$450.00 \$2,565.00 08/04/2023 MTM Attention to final revisions re special counsel declaration; email correspondence with Alex Bongartz re same 0.10 \$400.00 \$40.00 08/04/2023 AM Review/analyze bankruptcy court requirements and policies. 1.90 \$350.00 \$665.00 08/04/2023 TPJ Continue analysis of opposing motion for leave to appeal preliminary injunction ruling (1.5). Legal research re appealing order (.5). Outlining arguments to oppose motion (.6). Attend to appearance (.2). 2.80 \$450.00 \$1,260.00 08/05/2023 TPJ Outlining arguments supporting opposition to motion for leave to appeal

08/06/2023 TPJ Review and analysis of cases (1.5). Drafting opposition brief to motion for leave to appeal (1.5). 3.00 \$450.00 \$1,350.00 08/07/2023 MTM Review of Luc Despins notes re summary judgment and Rule 56 0.50 \$400.00 \$200.00

statement of facts; brief review of drafts of motions for summary judgment and Rule 56 statements; email communications with Attny Despins re

08/07/2023 TPJ Drafting opposition brief to motion for leave to appeal. 7.70 \$450.00 \$3,465.00 08/08/2023 MTM Telephone conference with John O'Connor re Genever holdings representation, status of discovery and response to motion to appeal 0.10 \$400.00 \$40.00 08/08/2023 MTM Review of Rule 56 statement of fact and motion for summary judgment and Attny Despins comments and revisions re same (.9); review of preliminary injunction pleadings and exhibits in preparation re summary judgment proceeding (.7) 1.60 \$400.00 \$640.00 08/08/2023 AM Revise/supplement opposition to motion for leave to appeal. 2.50 \$350.00 \$875.00 08/08/2023 MTM Review and revise draft brief in opposition to motion to appeal interlocutory order 0.60 \$400.00 \$240.00 08/08/2023 MBG Begin review of Rule 56 Statement of Undisputed Facts and Memorandum of Law in support of Motion for Summary Judgment and incorporating requested revisions to same. 1.70 \$125.00 \$212.50 08/08/2023 TPJ Continue drafting opposition brief to motion for leave to appeal order (1.1). Communications with AM re brief and pending projects (1). 2.10 \$450.00 \$945.00 08/09/2023 MTM Analysis and strategy re cancellation and reinstatement issues re excess liability policies 0.80 \$400.00 \$320.00 08/09/2023 TPJ Continue drafting and revising opposition brief (6). Finalize and file brief(1). Reviewing hearing transcript(1). 8.00 \$450.00 \$3,600.00 08/09/2023 AM Confer with M. McCormack re: policy cancellation/reinstatement/excess

08/10/2023 AM Confer with T. Jensen re: policy cancellation/reinstatement. 0.60 \$350.00 \$210.00 08/10/2023 TPJ Communications with AM re excess policy and strategy re same (.3). Communications re strategy and discovery (.3). Outlining discovery (2). 2.60 \$450.00 \$1,170.00 08/10/2023 MTM Attention to discovery issues re AIG and Genever document production; email communications with Attny Eddy re same 0.50 \$400.00 \$200.00 08/10/2023 MTM Telephone conference with L. Despins re discovery and summary

08/11/2023 AM Analysis of MSJ; conference with Luc and MTM and TPJ re: discovery and msj; analyze and collect documents responsive to discovery; analyze hearing from preliminary injunction hearing. 8.30 \$350.00 \$2,905.00 08/11/2023 MTM Review of draft brief re motion for summary judgment and draft statement of facts; attention to evidentiary support documents re statement of facts 0.80 \$400.00 \$320.00 08/11/2023 MTM Telephone conference with Luc Despins re discovery and strategy re summary judgment (1.2); analysis and strategy re motion for summary

08/11/2023 MTM Review and analysis of communications re AIG request for documents and examination under oath issues 0.20 \$400.00 \$80.00 08/11/2023 MTM Conference with A. Markim re AIG requests for documents and examination under oath 0.20 \$400.00 \$80.00 08/11/2023 MBG Review of Statement of Undisputed Facts and begin collating exhibits referenced in same. 0.70 \$125.00 \$87.50 Invoice No. 27021 - 09/25/2023 Case 22-50073 Doc 2271 Filed 10/20/23 Entered 10/20/23 16:54:01 Page 12 of 16 2928 02/16/24 02/16/24 16:10:56 27 47

08/11/2023 TPJ Reviewing discovery requests and responses, preliminary injunction documents (2.3). Call with LD re projects and strategy (.5). Communications with LD and internally re MSJ, discovery and strategy.

08/12/2023 TPJ Continue reviewing discovery responses and documents from injunction

08/13/2023 TPJ Reviewing, commenting on, draft memorandum in support of summary

08/14/2023 AM Attention to summary judgment and discovery. 4.40 \$350.00 \$1,540.00 08/14/2023 MBG Draft Responses to AIG's requests for production directed to Genever

08/14/2023 MBG Further review of SUF in support of MSJ to collate exhibits referenced therein from SDV documents and modify exhibits 0.90 \$125.00 \$112.50 08/14/2023 TPJ Continue reviewing and commenting on draft memo in support of summary judgment 2.00 \$450.00 \$900.00

Legal research for msj:

08/15/2023 TPJ Drafting discovery responses to AIG RFP (1). Continue review of summary judgment brief (1). Legal research re

NY and federal law (2) 4.00 \$450.00 \$1,800.00 08/16/2023 TPJ Drafting requests for production to AIG (2). Review AIG privilege log for purposes of deficiency letter (1.2). Research re

08/16/2023 MBG Begin review and index of AIG document production 1.40 \$125.00 \$175.00 08/17/2023 MBG Further review and index of AIG document production 2.10 \$125.00 \$262.50 08/17/2023 TPJ Continue working on draft discovery requests to AIG (2.9). Continue work on draft summary judgment memorandum(1.1). Review decision on motion to appeal (.3). Reviewing documents and emails sent by LD (2). 6.30 \$450.00 \$2,835.00 08/18/2023 MTM Review of order denying motion to file appeal 0.20 \$400.00 \$80.00 08/18/2023 TPJ Reviewing AIG document production (2). Reviewing documents from LD (.8). Reviewing documents to produce to AIG(1.1). 3.90 \$450.00 \$1,755.00 08/18/2023 MBG Further review and index of AIG document production. 0.80 \$125.00 \$100.00 08/18/2023 MBG Collate documents of interest from AIG document production into review

08/21/2023 MTM Review of email communications re repairs and mitigation issues; status of insurer repair payments 0.30 \$400.00 \$120.00 08/21/2023 MTM Review of court order re interim fee applications and approval procedures

08/21/2023 AM Attention to summary judgment (3.7); call with Luc, TPJ, MTM (.7); meeting with TPJ and MTM (.5). 4.90 \$350.00 \$1,715.00 08/21/2023 MTM Conference with L. Despins, T. Jensen & A. Markim re discovery and coverage issues 0.70 \$400.00 \$280.00 08/21/2023 MTM Review of policies re duty to cooperate issues raised by Attny O'Connor (.5) ; analysis and strategy re potential motion for summary judgment and 1.00 \$400.00 \$400.00

08/21/2023 MTM Review of pertinent documents from AIG production re preparation for discovery and summary judgment against AIG (.8); revise and supplement draft requests for production to AIG (.9). 1.70 \$400.00 \$680.00 08/21/2023 MBG Further review and index of AIG document production. 1.80 \$125.00 \$225.00 08/21/2023 TPJ Communications re strategy and discovery (1.2). Analysis re

(1.7). Reviewing documents from LD(1.3).

08/22/2023 AM Work on msj and discovery. 8.20 \$350.00 \$2,870.00 08/22/2023 MTM Review of email from Attny O'Connor and proposed amended answer; email correspondence with Luc Despins re same 0.20 \$400.00 \$80.00 08/22/2023 MTM Review of homeowner policies re replacement cost coverage payments and deductible issues; analysis of occurrence issues re AIG requests for information per conditions of policy (1.0); review of liability and excess policy language re intentional act and occurrence language and AIG requests for information under the policy (.4); conference with Luc Despins re AIG requests for information and examination under oath (.4) 1.80 \$400.00 \$720.00 08/22/2023 MTM Review bankruptcy order re approval of OMJB as special insurance coverage counsel 0.10 \$400.00 \$40.00 08/22/2023 MTM Review and analysis of cases re AIG request to amend answer to withdraw admissions (.8); review and analysis of New York cases re all

issues re motion for summary judgment (.7); revise and supplement statement of facts and supporting documents re property loss coverage

08/22/2023 MBG Further review and index of AIG document production. 3.10 \$125.00 \$387.50 08/22/2023 TPJ Attend to discovery compliance with requests for production (1). Communications with AM re compliance(.3). 1.30 \$450.00 \$585.00 08/23/2023 MTM Review of portions of preliminary injunction hearing transcript re

08/23/2023 MBG Complete review and index of AIG document production. 4.20 \$125.00 \$525.00 08/23/2023 AM Attention to written discovery. 7.20 \$350.00 \$2,520.00 08/23/2023 TPJ Review and revise memorandum in support of summary judgment(2.5). Review statement of facts(1). Communications with AM re projects and strategy(.5). Drafting deficiency letter(1). 5.00 \$450.00 \$2,250.00

08/24/2023 MMS Email communications regarding research issue involving

(.2); begin legal research; lengthy conference with Atty Markim;

conference with Attys Markim and McCormack; 6.30 \$300.00 \$1,890.00

Conference with M. Seery re: legal research re:

continue revising/supplementing discovery

requests to AIG. 3.30 \$350.00 \$1,155.00 08/24/2023 MTM Email correspondence to Attny O'Connor re discovery and pleading

08/24/2023 TPJ Continue to work on summary judgment brief and attend to discovery

08/24/2023 MTM Email communications with L. Despins re AIG proposed answer (.2);Email communications with Attny O'Con nor re AIG motion to depose Kwok and proposed amended answer (.2) 0.40 \$400.00 \$160.00

08/24/2023 MTM Continue drafting and revising brief in support of motion for summary judgment re declaratory relief; review of transcripts and documentary evidence in support of same 3.20 \$400.00 \$1,280.00 08/24/2023 MTM Analysis and attention to discovery issues; email communications with Attny Despins re same 0.20 \$400.00 \$80.00 08/25/2023 TPJ Communications re documents and privilege and analysis re same (1). Review additional documents (.6). Attend to identifying subpoenas and related issues(1.5). 3.10 \$450.00 \$1,395.00 08/25/2023 AM Review documents for production in response to AIG discovery requests. 5.70 \$350.00 \$1,995.00 08/25/2023 AM Conference with L. Despins, T. Jensen, and M. McCormack re: discovery and policy matters. 0.70 \$350.00 \$245.00 08/25/2023 MBG Research procedures for file FOIA requests on NYPD, NYFD and FBI and advise TPJ of same. 0.20 \$125.00 \$25.00 08/25/2023 MBG Revise and finalize 2nd Requests for Production directed to AIG and Genever Responses to AIG Requests for Production. 0.80 \$125.00 \$100.00 08/25/2023 MTM Conference with A. Markim, T. Jensen and L. Despins re status and strategy re discovery and motion for summary judgment (.6); attention to discovery issues and document production issues (.4) 1.00 \$400.00 \$400.00 08/25/2023 MTM Email communications with Attny O'Connor re privilege log and discovery

08/25/2023 MTM Revise and supplement Rule 56 statement of facts re motion for summary

08/25/2023 MTM Revise and supplement draft brief re motion for summary judgment re declaratory relief 3.60 \$400.00 \$1,440.00 08/28/2023 MMS Continue legal research and analysis regarding whether interest on reconstruction loan is recoverable; internal communication with Amy (.1); begin drafting discussion memo (7.4) 7.50 \$300.00 \$2,250.00 08/28/2023 MTM Continue draft and revising of statement of facts re summary judgment (2.4); review reservation of rights letters from Mr. Despins (.3); Attention to discovery and document production issues re reservation of rights

08/28/2023 AM Conference with T. Jensen re: outstanding policy interpretation research, discovery, and summary judgment. 0.40 \$350.00 \$140.00 08/28/2023 MTM Attention to privilege log and file transfer issues from Saxe Doernberger re missing discovery documents; email correspondence with Attn Clifford

08/28/2023 TPJ Identifying and drafting requests for subpoenas (3). Communications with

08/28/2023 MBG Further review of Statement of Facts in support of Motion for Summary Judgment to identify exhibits referenced therein and their corresponding

08/29/2023 MMS Complete lengthy discussion memorandum regarding

Invoice No. 27021 - 09/25/2023 Case 22-50073 Doc 2271 Filed 10/20/23 Entered 10/20/23 16:54:01 Page 15 of 16 2928 02/16/24 02/16/24 16:10:56 30 47

08/29/2023 MTM Review and analysis of L. Despins comments to summary judgment brief; revise and supplement same (.9); review of Wolfson agency emails re application issues (.3) 1.20 \$400.00 \$480.00

08/29/2023 TPJ Continue research and analysis (2.9).

Review potentially privileged documents(.6). Review and comment on current summary judgment draft(1.3). 4.80 \$450.00 \$2,160.00 08/29/2023 MBG Further review of MSJ SUF for exhibits ECF identifications; further review and revisions to exhibits to same. 1.50 \$125.00 \$187.50 08/30/2023 MTM Review of legal research memorandum re

08/30/2023 MMS Continue legal research regarding

summary judgment 4.70 \$300.00 \$1,410.00 08/30/2023 MTM Conference with L. Despins re motion for summary judgment and document discovery issues 0.70 \$400.00 \$280.00 08/30/2023 MTM Conference with T. Jensen re summary judgment and discovery issues (.4); analysis and strategy re adverse inference issues re

08/30/2023 MBG Confer with MTM re revised exhibits to MSJ and additional exhibits reference in MSJ 0.20 \$125.00 \$25.00 08/30/2023 MTM Review and revise draft statement of facts; review of bankruptcy documents re evidentiary support re statement of facts 1.60 \$400.00 \$640.00 08/30/2023 TPJ Review and comment on current summary judgment draft brief; pull documents for possible use in brief; conference with MTM re same 1.00 \$450.00 \$450.00 08/30/2023 MTM Review and analysis of of bankruptcy court docket and pleadings re exhibits for motion for summary judgment (1.2) 1.20 \$400.00 \$480.00 08/31/2023 MMS Continue working on analysis regarding

to Pure, FM Global and Wolfson (2). 2.80 \$450.00 \$1,260.00

Expense 07/31/2023 PACER: Month of July \$12.50 Expense 08/31/2023 PACER: Month of August \$268.70 Expense 08/31/2023 Copying: Month of August \$101.60 Expense 08/31/2023 Westlaw: Month of August \$1,365.76

Timothy Jensen 99.7 \$450.00 \$44,865.00

02/16/24 Entered 10/20/23 16:54:01 02/16/24 16:10:56

Melissa Gambardella 28.2 \$125.00 \$3,525.00 Michelle Seery 27.1 \$300.00 \$8,130.00 Michael McCormack 46.7 \$400.00 \$18,680.00

Invoice Number Due On Amount Due PaymentsReceived Balance Due

27021 09/25/2023 \$99,873.56 \$0.00 \$99,873.56

Please make all amounts payable to: O'Sullivan McCormack Jensen & Bliss PC Tax ID# REDACTED

Payment is due upon receipt.

Case 22-50073 Doc 2928 Filed 02/16/24 Entered 02/16/24 16:10:56 Page 32 of 47 Case 22-50073 Doc 2272 Filed 10/20/23 Entered 10/20/23 17:02:37 Page 9 of 13

180 Glastonbury Boulevard, Suite 210 Glastonbury, CT 06033 Phone: 860-258-1993 [www.omjblaw.com]

Genever Holdings LLC 200 Park Avenue New York, NY 10166 3726-001-Genever Holdings/AIG Property Casualty

Date Attorney Activity Time Rate Total

09/01/2023 MTM Analysis and strategy re

09/01/2023 MTM Drafting of supplemental discovery to AIG and Wolfson re communications with L. Despins and research re

09/01/2023 MMS Continue working on analysis and memorandumregardingpotential

09/01/2023 MTM Revise and supplement draft statement of facts re motion for summary judgment; review of pleadings and bankruptcy documentsre evidentiary support for various statements of fact (4.4); draft email to Mr. Despins re Rule 56 Statement of Facts and documentrequests (.3) 4.50 \$400.00 \$1,800.00 09/01/2023 TPJ Revisions to documentrequests; communications re

09/04/2023 MMS Complete research and memorandumregarding

09/06/2023 MTM Review of L. Despins comments re Rule 56 statement of facts; 0.20 \$400.00 \$80.00 09/08/2023 MMS Attention to Atty Jensen email, and work on preparing subpoenas duces tecum to four insurers, including search for companies and service addresses;in-house communications re same 3.70 \$300.00 \$1,110.00 09/08/2023 TPJ Attend to 3d party documentsubpoenas. 0.50 \$450.00 \$225.00 09/12/2023 MTM Telephone conference with L. Despins and T. Jensen re status and strategy (.6); email communications with L. Despins re third party claim

Invoice No. 27098 - 10/11/2023 Case 22-50073 Doc 2272 Filed 10/20/23 Entered 10/20/23 17:02:37 Page 10 of 13 2928 02/16/24 02/16/24 16:10:56 33 47

09/12/2023 MTM Review and analysis of legal memoranda summaries re

09/12/2023 AM Review/analyze research memorandare:

09/12/2023 TPJ Revise documentrequests for subpoenas; communications with LD re status and discovery 1.30 \$450.00 \$585.00 09/14/2023 AM Review documentsfor responsiveness to discovery requests. 4.80 \$350.00 \$1,680.00 09/14/2023 TPJ Attend to discovery matters and communications re same; attend to preparation of rule 26f 2.90 \$450.00 \$1,305.00 09/15/2023 MTM Review of subpoenas and attention to service of process issues re insurance department as agent for insurers 0.40 \$400.00 \$160.00 09/15/2023 AM Continued review of documentsfor responsiveness to discovery requests. 1.10 \$350.00 \$385.00 09/15/2023 TPJ Revise 3d set of requests for production; drafting rule 26f report; attend to discovery status and communications re same 3.10 \$450.00 \$1,395.00 09/15/2023 MBG Confer with TPJ re subpoenas for service on FM Global, Pure Specialty, Chubb and Wolfson; revisions to same; telcon with marshal Bennett arranging for service; cover letter to Attorney O'Connor enclosing copies of subpoenas and 3rd Request for Production to AIG; revise and finalize RFPs to AIG and attention to electronic service of same. 1.50 \$125.00 \$187.50 09/17/2023 TPJ Continue drafting and revising rule 26f report; incorporate statement of facts into draft 1.50 \$450.00 \$675.00 09/18/2023 AM Review and analysis of Millman and Cyganowksi emails. 2.90 \$350.00 \$1,015.00 09/18/2023 TPJ Communications with AM re

docs; continue drafting rule 26f report 3.00 \$450.00 \$1,350.00 09/18/2023 AM Conference with L. Despins re: documentproduction and

applicability.

09/18/2023 MBG Telcons with Marshal Bennett re issues with service of Wolfson Brokerage subpoena on Insurance Commissioner 0.40 \$125.00 \$50.00 09/18/2023 MBG Begin indexing Genever documentproduction to date. 2.20 \$125.00 \$275.00 09/18/2023 MTM Work on statement of undisputed facts re motion for summary judgment and brief in support of same 1.20 \$400.00 \$480.00 09/19/2023 MTM Review of Genever bankruptcy motions seeking permission to hire and pursue repairs to building 0.30 \$400.00 \$120.00 09/19/2023 MTM Revise and supplement brief in support of motion for summary judgment with attention to revising and condensing re bankruptcy court page

09/19/2023 MBG Further index of Genever documentproduction. 0.40 \$125.00 \$50.00 09/20/2023 MTM Work on motion for summary judgment brief 1.60 \$400.00 \$640.00 09/20/2023 AM Review/revise summary judgment brief. 0.80 \$350.00 \$280.00 09/20/2023 AM Meeting with L. Despins and M. McCormack re: documentproduction/

09/20/2023 MTM Continued revising and supplementing brief re summary judgment re page limitation issues and analysis of cases 1.40 \$400.00 \$560.00

09/20/2023 MTM Conference with A. Markim re summary judgment issues and discovery issues; agency analysis (.5); conference with L. Despins and A. Markim re documentproduction (.3) 0.80 \$400.00 \$320.00

09/21/2023 MTM Revise and edit draft brief re summary judgment 2.30 \$400.00 \$920.00 09/21/2023 AM Attention to review of documentsfor responsiveness to discovery

09/21/2023 MBG Further review of Genever MSJ and SUF and attention to review of evidentiary citations in each, further revisions to exhibits to same. 1.80 \$125.00 \$225.00 09/22/2023 MBG Further review of and revisions to Memorandumof Law and Statement of Facts in Support of Motion for Summary Judgment; review and analysis of evidentiary citations in MOL to SUF statements; draft MTM declaration and begin collating exhibits for same. 3.10 \$125.00 \$387.50 09/22/2023 MTM Review of repair estimates and bankruptcy court order re authority to proceed with repairs to building; draft lengthy letter to J. O'Connor re demand for payment of court-authorized repairs and response to AIG request for information and EUO underpolicy 2.70 \$400.00 \$1,080.00 09/22/2023 MTM Review of revised draft of statement of facts and brief in support of motion for summary judgment, email correspondence to L. Despins re same 0.60 \$400.00 \$240.00 09/23/2023 MTM Revise and supplement brief in support of motion for summary judgment and Rule 56 statement of fact re evidentiary citations to record and msj evidencein support of msj 4.90 \$400.00 \$1,960.00 09/24/2023 MTM Review and analysis of Genever corporate documentsand share transfer documentsre preparation of affidavits for summary judgment; draft affidavit of Luc Despins in support of motion for summary judgment with reference to relevant exhibits; review, analysis and coordination of all exhibits for Despins affidavit 3.20 \$400.00 \$1,280.00 09/24/2023 MTM Review of injunction hearing transcript re AIG testimony for evidentiary support re msj; draft McCormack affidavit of exhibit re motion for summary judgment; review and analysis of record evidencefrom injunction hearing and identify and prepare exhibits for motion for summary judgment 3.00 \$400.00 \$1,200.00 09/25/2023 AM Review documentsfor responsiveness and privilege. 4.50 \$350.00 \$1,575.00 09/27/2023 MTM Conference with L. Despins re motion for summary judgment and

expert issues (.4); attention to documentproduction issues and email correspondence to Attny O'Connor re same and Rule26 Report (.4);

issues and email correspondence to L. Despins re

09/27/2023 TPJ Communications with MTM and AM re status and MSJ 0.20 \$450.00 \$90.00 09/28/2023 MBG Further review and revisions to Memorandumof Law in Support of MSJ and Statement of UndisputedFacts; attention to revisions to references to Statement of UndisputedFacts in Memorandumre evidentiary citations; review and revise Despins and MTM Affidavits and Exhibits in Support of

09/28/2023 TPJ Internal conferences re strategy, status and

09/29/2023 AM Meeting with J. O'Connor re: privilege, 26(f) planning, AIG privilege log,

09/29/2023 MTM Call with John O'Connor re common interest issues and document

Invoice No. 27098 - 10/11/2023 Case 22-50073 Doc 2272 Filed 10/20/23 Entered 10/20/23 17:02:37 Page 12 of 13 2928 02/16/24 02/16/24 16:10:56 35 47

09/29/2023 MTM Brief preliminary review of file materials from REDACTED 0.40 \$400.00 \$160.00 09/29/2023 MTM Review and revise final draft of memorandumof law and statement of facts re summary judgment; affidavits in support of motion for summary judgment with exhibits (1.8); draft motion for summary judgment (.5); email correspondence to Attny Despins re summary judgment documents

Expense 09/08/2023 Fees advancedto Logikcull INV151500 8-31-2023 \$277.25 Expense 09/27/2023 Fees advancedto Timothy J Bennett invoice 9-18-2023 \$379.24 Expense 09/30/2023 Copying: Month of September \$21.80 Expense 09/30/2023 PACER: Month of September \$18.60 Expense 09/30/2023 Westlaw: Month of September \$477.87

Timothy Jensen 15.2 \$450.00 \$6,840.00

Michael McCormack 37.4 \$400.00 \$14,960.00 Michelle Seery 17.1 \$300.00 \$5,130.00 Melissa Gambardella 12.8 \$125.00 \$1,600.00

Invoice Number Due On Amount Due PaymentsReceived Balance Due

27021 09/25/2023 \$99,873.56 \$0.00 \$99,873.56

Invoice Number Due On Amount Due PaymentsReceived Balance Due Invoice No. 27098 - 10/11/2023 Case 22-50073 Doc 2272 Filed 10/20/23 Entered 10/20/23 17:02:37 Page 13 of 13 2928 02/16/24 02/16/24 16:10:56 36 47

27098 10/11/2023 \$35,374.76 \$0.00 \$35,374.76

Balance Due on All Invoices \$135,248.32

Please make all amounts payable to: O'Sullivan McCormack Jensen & Bliss PC Tax ID# REDACTED

Payment is due upon receipt.

Case 22-50073 Doc 2928 Filed 02/16/24 Entered 02/16/24 16:10:56 Page 37 of 47 Case 22-50073 Doc 2355 Filed 11/20/23 Entered 11/20/23 15:40:15 Page 9 of 12

180 Glastonbury Boulevard, Suite 210 Glastonbury, CT 06033 Phone: 860-258-1993 [www.omjblaw.com]

Genever Holdings LLC 200 Park Avenue New York, NY 10166 3726-001-Genever Holdings/AIG Property Casualty

Date Attorney Activity Time Rate Total

10/01/2023 TPJ Reviewing draft motion for summary judgment papers 1.40 \$450.00 \$630.00 10/03/2023 MTM Review of correspondence from AIG re denial of liability claim re flooding

10/03/2023 TPJ Continue reviewing and revising draft summary judgment papers 4.20 \$450.00 \$1,890.00 10/04/2023 AM Finalize supplemental document production (1.6); Draft/revise privilege logs (1.4); correspondence to counsel re: document production and non

10/04/2023 MBG Preparation of privilege spreadsheets for service 0.30 \$125.00 \$37.50 10/04/2023 TPJ Attend to privilege log 0.20 \$450.00 \$90.00 10/05/2023 MTM Review of additional proposed edits re motion for summary judgment; email correspondence with Attny Despins 0.30 \$400.00 \$120.00 10/05/2023 MTM Conference with L. Despins re motion for summary judgment and

10/05/2023 MTM Revise and supplement motion for summary judgment declarations; attention to motion for summary judgment and brief revision and

10/06/2023 MTM Revise and edit brief in support of motion for summary judgment re T. Jensen and L. Despins comments and evidentiary citations; review of exhibitsre same 2.60 \$400.00 \$1,040.00 10/06/2023 AM Additional review of documents for responses to discovery and draft supplemental privilege log. 2.20 \$350.00 \$770.00 10/06/2023 MTM Final review and revisions to motion for summary judgment, statement of facts, declarations and affidavits and memorandum of law for filing 1.60 \$400.00 \$640.00 Invoice No. 27168 - 11/14/2023 Case 22-50073 Doc 2355 Filed 11/20/23 Entered 11/20/23 15:40:15 Page 10 of 12 2928 02/16/24 02/16/24 16:10:56 38 47

10/06/2023 MBG Revise and finalize Motion for Summary Judgment; prepare exhibitsto Despins Declarations; revise and finalize Memorandum of Law and Statement of Undisputed Facts; finalize MTM Affidavit in support of same; finalize and e-file. 6.50 \$125.00 \$812.50

10/10/2023 MBG Prepare sharefiling of MSJ pleadings as filed and share with Attorney

10/11/2023 MTM Telephone conference with Attny Bogartz re fee application 0.40 \$400.00 \$160.00 10/11/2023 AM Conference with T. Jensen re:

10/11/2023 AM Analyze obligations under FRCP and Local Rules re:

(.4); email to client re: same (.1).

10/11/2023 TPJ Attend to discovery matters; Rule 26f conference 1.10 \$450.00 \$495.00 10/12/2023 MTM Attention to Rule 26 report issues and communications with counsel re

10/12/2023 MTM Review of fee application bankruptcy order; drafting of monthly fee

10/12/2023 TPJ Attend to Rule 26f report and discovery matters 3.10 \$450.00 \$1,395.00 10/13/2023 TPJ Attend to discovery matters; work on Rule 26f report; Pure subpoena 3.50 \$450.00 \$1,575.00 10/13/2023 MTM Telephone conference with L. Despins re Rule 26 report and pretrial

10/13/2023 MTM Conference with J. O'Connor and T. Jensen re Rule 26 Report and pretrial issues 0.40 \$400.00 \$160.00 10/13/2023 MTM Review and comment re draft Ruel 26 report; email communication with Attny O'Connor and Attny Despins re same; 0.40 \$400.00 \$160.00 10/13/2023 MTM Conference with L. Despins and T. Jensen re Rule 26 Report, discovery and pretrial issues 0.50 \$400.00 \$200.00 10/13/2023 MTM Conference with T. Jensen re motion for summary judgment and discovery strategy 0.30 \$400.00 \$120.00 10/13/2023 MTM Telephone conference with Adam Wolfson re subpoena document

10/16/2023 MBG Set up sharefile for Wolfson subpoena responsive documents; download and organization of same. 0.40 \$125.00 \$50.00 10/16/2023 MTM Telephone conference with L. Despins re pretrial conference and insurance issues 0.20 \$400.00 \$80.00 10/16/2023 TPJ Attend to Pure subpoena matters; analysis re strategy 0.80 \$450.00 \$360.00 10/17/2023 MTM Prepare for pretrial conference: Review and analysis of excessliability policy cancellation and reinstatement communications; review Judge Manning decision, email communications and telephone conferences with Attny O'Connor and L. Despins re excessliability policy reinstatement issues (1.5); review of draft Rule 26 report and outline dates re discovery, depositions and motions for summary judgment (.4) 1.90 \$400.00 \$760.00 10/17/2023 MTM Revise and finalize monthly fee applications re August and September; email communications with Attny Bongartz re same 0.40 \$400.00 \$160.00 10/17/2023 MTM Attend bankruptcy pretrial hearing conference re insurance adversary 0.70 \$400.00 \$280.00 Invoice No. 27168 - 11/14/2023 Case 22-50073 Doc 2355 Filed 11/20/23 Entered 11/20/23 15:40:15 Page 11 of 12 2928 02/16/24 02/16/24 16:10:56 39 47

10/17/2023 MBG Convert Adversary Proceeding Complaint to word and set up for

10/17/2023 MTM Preliminary review of Wolfson documents produced in response to subpoena (.3); telephone conference with Attny Bongartz re fee application submissions (.2) 0.50 \$400.00 \$200.00 10/17/2023 TPJ Attend to document production and subpoenas; drafting

10/18/2023 MTM Finalize draft fee application; email communication to Attny Bongartz re monthly fee application 0.20 \$400.00 \$80.00 10/18/2023 TPJ Attend to matters re 3d party subpoena document requests 3.90 \$450.00 \$1,755.00 10/18/2023 MBG Attention to transmitting sharefile of Wolfson document production to L.

analysis re same 0.50 \$400.00 \$200.00 10/19/2023 AM Email correspondence to L. Despins re:

10/19/2023 AM Conference with M. McCormack re:

10/19/2023 MTM Revise and finalize fee applications and redacted invoices; attention to comments from and email communications with Attny Bongartz 0.80 \$400.00 \$320.00 10/19/2023 MTM Conference with L. Despins re follow up to pretrial conference issues (.3);

10/19/2023 TPJ Attend to 3d party subpoena matters 1.10 \$450.00 \$495.00 10/20/2023 MBG Review emails between counsel re Fee Application; confer with MTM re: redactions to invoices; redact invoices and prepare final set for TPJ review; further redactions to invoices and finalize Fee Applications. 0.90 \$125.00 \$112.50 10/20/2023 MBG Issues with e-filing Fee Application; communications with court clerks, MTM, TPJ and Alex Bongartz; further attempts to e-file and continued issues; further communications with MTM, TPJ and Attorney Bongartz (.5).; draft Appearances for MTM, TPJ and AEM in main bankruptcy case

10/20/2023 TPJ Attend to 3d party subpoena matters (.6); attend to fee submission (.4) 1.00 \$450.00 \$450.00 10/23/2023 MTM Attention to and analysis of summary judgment, discovery and policy issues; email correspondence with Mr. Despins re same 0.20 \$400.00 \$80.00 10/25/2023 MTM Review of Genever revised draft Rule 26 report; email correspondence to L. Despins re same 0.30 \$400.00 \$120.00 10/25/2023 TPJ Attend to 3d party subpoena issues; attend to rule 26f report issues 1.70 \$450.00 \$765.00 10/25/2023 MTM Receipt and review of AIG revised draft Rule 26 report; email correspondence to Attny Despins re same 0.30 \$400.00 \$120.00 10/26/2023 TPJ Attend to 3d party subpoenas; attend to rule 26f report 2.70 \$450.00 \$1,215.00 10/27/2023 TPJ Attend to Rule 26f report and revisions to same; 1.30 \$450.00 \$585.00 10/28/2023 MTM Email correspondence to H. Claiborn re fee application 0.10 \$400.00 \$40.00

Expense 10/06/2023 Fees advance to Logikcull INV152264 9-30-2023 \$270.00 Expense 10/31/2023 Copying: Month of October \$6.40 Expense 10/31/2023 Westlaw: Month of October \$45.05

Timothy Jensen 30.5 \$450.00 \$13,725.00

Michael McCormack 18.2 \$400.00 \$7,280.00 Melissa Gambardella 9.5 \$125.00 \$1,187.50

Invoice Number Due On Amount Due PaymentsReceived Balance Due

27021 09/25/2023 \$99,873.56 \$1,105.00 \$98,768.56 27098 10/11/2023 \$35,374.76 \$0.00 \$35,374.76

Invoice Number Due On Amount Due PaymentsReceived Balance Due

27168 11/14/2023 \$24,998.95 \$0.00 \$24,998.95 Balance Due on All Invoices \$159,142.27

Please make all amounts payable to: O'Sullivan McCormack Jensen & BlissPC Tax ID# REDACTED

Payment is due upon receipt.

Case 22-50073 Doc 2928 Filed 02/16/24 Entered 02/16/24 16:10:56 Page 41 of 47 Case 22-50073 Doc 2459 Filed 12/20/23 Entered 12/20/23 15:39:37 Page 9 of 12

180 Glastonbury Boulevard, Suite 210 Glastonbury, CT 06033 Phone: 860-258-1993 [www.omjblaw.com]

Genever Holdings LLC 200 Park Avenue New York, NY 10166 3726-001-Genever Holdings/AIG Property Casualty

Date Attorney Activity Time Rate Total

Conference with T. Jensen re: strategy re: briefing re: 0.20 \$350.00 \$70.00 11/03/2023 MBG Updates to calendar re MSJ reply deadlines; review docket for updates in

11/03/2023 MBG Preparation of Wolfson Insurance Brokerage responsive documents to subpoena for production to Attorney O'Connor. 0.20 \$125.00 \$25.00 11/03/2023 TPJ Internal communications re excess policy; document productions 0.80 \$450.00 \$360.00 11/06/2023 AM Legal research re:

11/06/2023 MTM Receipt and review of pretrial scheduling order 0.10 \$400.00 \$40.00 11/06/2023 TPJ Internal communications re excess policy and continuing work on argument re same 0.70 \$450.00 \$315.00 11/06/2023 AM Revise/supplement outline of excess policy brief. 0.40 \$350.00 \$140.00 11/07/2023 AM Draft brief re: excess policy. 5.20 \$350.00 \$1,820.00 11/07/2023 AM Meeting with L. Despins re: brief re:

11/07/2023 MBG Further review and index of Genever document production. 3.90 \$125.00 \$487.50 11/07/2023 TPJ Analysis and outline argument re

11/08/2023 MBG Further review and index of Genever document production 3.30 \$125.00 \$412.50 11/09/2023 AM Continue drafting brief in regarding excess policy/injunction order. 3.20 \$350.00 \$1,120.00 11/09/2023 TPJ Communications re strategy 0.20 \$450.00 \$90.00 11/09/2023 MBG Further review and index of Genever document production; correspondence to L. Despins re updated Wolfson documents 2.90 \$125.00 \$362.50 Invoice No. 27274 - 12/08/2023 Case 22-50073 Doc 2459 Filed 12/20/23 Entered 12/20/23 15:39:37 Page 10 of 12 2928 02/16/24 02/16/24 16:10:56 42 47

11/09/2023 MTM Review draft supplemental brief re preliminary injunction issues; email correspondence with Attny Despins re same 0.20 \$400.00 \$80.00

11/10/2023 AM Revise/finalize brief regarding excess policy. 4.60 \$350.00 \$1,610.00 11/10/2023 MTM Analysis and strategy with A. Markim re

11/10/2023 TPJ Review and revise draft brief on excess coverage 3.30 \$450.00 \$1,485.00 11/10/2023 MTM Review and analysis of excess liability and primary liability policies re supplemental information for brief re preliminary injunction order; revise and supplement supplemental brief re preliminary injunction ) 1.30 \$400.00 \$520.00 11/10/2023 MTM Email communications with L. Despins re

(.2); telephone conference with Attny Despins

re revisions to supplemental brief (.1) 0.30 \$400.00 \$120.00 11/10/2023 MTM Receipt and preliminary review of AIG response to motion for summary judgment and response to statement of facts 0.20 \$400.00 \$80.00 11/10/2023 MBG Attention to downloads of AIG MSJ Opposition pleadings and Memorandum re Scope of Preliminary Injuction and transmit same to L. Despins, share Wolfson document production with L. Despins; finalize and e-file Genever brief re Excess Policy issues. 2.70 \$125.00 \$337.50 11/13/2023 AM Analysis of AIG's 56(a)(2) Statement. 1.70 \$350.00 \$595.00 11/13/2023 TPJ Internal communications with re summary judgment 0.50 \$450.00 \$225.00 11/15/2023 MBG Review of AIG MSJ Opposition documents and preparation of opposition

11/15/2023 MTM Review and analysis of AIG opposition to motion for summary judgment and response to statement of fact 2.20 \$400.00 \$880.00 11/15/2023 TPJ Attend to initial disclosures 0.90 \$450.00 \$405.00 11/16/2023 MTM Continued analysis of AIG opposition to motion for summary judgment and begin outline arguments and evidence re reply brief 1.40 \$400.00 \$560.00 11/16/2023 MTM Outline of reply brief issues re conference with L. Despins re status and strategy (.3); telephone conference with Mr. Despins re reply to AIG Opposition to Motion for Summary Judgment (.4); email correspondence to Attny O'Connor re reply brief issues (.1) 0.80 \$400.00 \$320.00 11/16/2023 MBG Draft Motion for Extension of Time on Consent to file Reply to AIG Opposition to MSJ; confer with TPJ re Appearances to be filed in main bankruptcy case; review docket of same for previous filings and follow up. 1.10 \$125.00 \$137.50 11/16/2023 TPJ Continue working on initial disclosures 1.50 \$450.00 \$675.00 11/17/2023 MTM Receipt and review of AIG Initial disclosures 0.10 \$400.00 \$40.00 11/17/2023 MTM Revise and supplement motion to extend time re motion for summary judgment reply brief 0.20 \$400.00 \$80.00 11/17/2023 MTM Revise and supplement initial disclosures; email correspondence with Attny Despins re same (1.3); review of communications re investigation of

11/17/2023 MTM Draft monthly fee application; email correspondence to Attny Bongartz re fee application 0.80 \$400.00 \$320.00 11/17/2023 MBG Revise and finalize AEM, MTM and TPJ Appearances in main bankruptcy 2.60 \$125.00 \$325.00

case; review emails from MTM and TPJ re same; attention to e-filing Appearances; revise, finalize and e-file Motion for Extension of Time to Reply to AIG Opposition to Motion for Summary Judgment in Adv. Pro.; Revise Initial Disclosures per MTM email; finalize and service; fwd copies of all filings to L. Despins including AIG Initial Disclosures

11/20/2023 MTM Attention to redaction issues re fee invoice monthly submission 0.20 \$400.00 \$80.00 11/20/2023 TPJ Review/revise fee submission 0.20 \$450.00 \$90.00 11/20/2023 MBG Review emails between counsel re redactions to OMJB invoice for Fee Application; attention to redactions of same; finalize Fee Application; review emails re filing of same and telcon with court clerk; create Notice Parties service list; attention to e-filing and service of Fee Application on Notice Parties. 1.70 \$125.00 \$212.50 11/20/2023 MTM Revise and finalize fee submission documents and invoice issues 0.90 \$400.00 \$360.00 11/21/2023 MTM Begin drafting reply brief and review and analysis of summary judgment cases cited by AIG in opposition (1.7); review and analysis of cases re intentional act exclusions and incident insured issues (1.2) 2.90 \$400.00 \$1,160.00 11/22/2023 MTM Review and analysis of cases re AIG opposition to motion for summary judgment re misrepresentation issues 0.80 \$400.00 \$320.00 11/25/2023 TPJ Review and analysis of summary judgment opposition papers 1.90 \$450.00 \$855.00 11/27/2023 MTM Continued analysis of AIG Opposition to motion for summary judgment and drafting of reply brief re same 2.80 \$400.00 \$1,120.00 11/28/2023 MTM Review and analysis of cases re

11/28/2023 MTM Drafting of reply brief re summary judgment and continued review and analysis of AIG opposition and documents in support re reply brief issues 3.20 \$400.00 \$1,280.00 11/29/2023 MTM Continue drafting reply brief to AIG opposition to motion for summary

11/30/2023 MTM Revise and supplement draft reply brief to opposition to motion for summary judgment; email correspondence to Attny Despins re draft reply 3.30 \$400.00 \$1,320.00 11/30/2023 MTM Revise and supplement draft amended complaint 0.80 \$400.00 \$320.00 11/30/2023 TPJ Review and revise draft reply brief to opposition to summary judgment 3.70 \$450.00 \$1,665.00 11/30/2023 MTM Email communications with Attny O'Connor re reply brief issues 0.10 \$400.00 \$40.00 11/30/2023 MTM Conference with L. Despins re reply brief re summary judgment and amended complaint (.5); continue revising, supplementing and analysis re reply brief issues (.6) 1.10 \$400.00 \$440.00

Expense 11/09/2023 Fees advanced to Logikcull INV153376 10-31-2023 \$250.00 Expense 11/30/2023 Copying: Month of November \$106.40 Expense 11/30/2023 PACER: Month of November \$10.70

Timothy Jensen 17.4 \$450.00 \$7,830.00

Michael McCormack 33.1 \$400.00 \$13,240.00 Melissa Gambardella 19.8 \$125.00 \$2,475.00

Invoice Number Due On Amount Due Payments Received Balance Due

27021 09/25/2023 \$99,873.56 \$80,469.56 \$19,404.00 27098 10/11/2023 \$35,374.76 \$28,534.76 \$6,840.00 27168 11/14/2023 \$24,998.95 \$0.00 \$24,998.95

Invoice Number Due On Amount Due Payments Received Balance Due

27274 12/08/2023 \$31,249.41 \$0.00 \$31,249.41

Please make all amounts payable to: O'Sullivan McCormack Jensen & Bliss PC Tax ID# REDACTED

Payment is due upon receipt.

Case 22-50073 Doc 2928 Filed 02/16/24 Entered 02/16/24 16:10:56 Page 45 of 47 Case 22-50073 Doc 2511 Filed 01/19/24 Entered 01/19/24 09:57:43 Page 9 of 13

180 Glastonbury Boulevard, Suite 210 Glastonbury, CT 06033 Phone: 860-258-1993 [www.omjblaw.com]

Genever Holdings LLC 200 Park Avenue New York, NY 10166 3726-001-Genever Holdings/AIG Property Casualty

Date Attorney Activity Time Rate Total

12/01/2023 MBG Review and revise Reply Brief to AIG Opposition to Genever MSJ; finalize same; revise and finalize Motion to Exceed Page Limit; attention to e filing Motion and Reply; transmit copies to L. Despins; revise Amended Complaint; preparation of Amended Complaint in final and exhibits to same; attention to e-filing Amended Complaint. 1.80 \$125.00 \$225.00 12/01/2023 MTM Revise, supplement and finalize reply brief re summary judgment (3.4); draft motion to file brief in excess of page limt (.5); revise, supplement and finalize amended complaint with exhibits (1.2) 5.10 \$400.00 \$2,040.00 12/04/2023 MTM Email correspondence to Mr. Despins re filing of amended complaint 0.10 \$400.00 \$40.00 12/04/2023 MTM Attention to issues re amended compliant; email communications with Attny Despins re same 0.20 \$400.00 \$80.00 12/04/2023 TPJ Communications re Pure subpoena 0.20 \$450.00 \$90.00 12/05/2023 MBG Attention to TPJ emails re discovery responses and PURE revised subpoena; attention to revisions and finalizing PURE subpoena and attachments; telcon and cover letter to marshal re service of same; email service copy to O'Connor; send AIG supplemental document production to L. Despins; share FM Global subpoena response with Attorney O'Connor; begin review and index of AIG supplemental document

12/05/2023 TPJ Attend to matters re Pure subpoena 0.30 \$450.00 \$135.00 12/05/2023 TPJ Review AIG discovery responses/production 2.90 \$450.00 \$1,305.00 12/06/2023 MBG Further review and index of AIG supplemental document production. 1.10 \$125.00 \$137.50 12/07/2023 AM Review correspondence from M. Bono. 0.30 \$350.00 \$105.00 12/12/2023 MTM Receipt and review of notice re summary judgment hearing; email 0.20 \$400.00 \$80.00

12/27/2023 TPJ Attend to AIG deficiency letter 1.00 \$450.00 \$450.00 12/20/2023 MBG Review attorney communications and prepare redacted OMJB November invoice; finalize Statement of Monthly fees and e-file with court; attention to service on Notice Parties of same. 0.80 \$125.00 \$100.00 12/20/2023 MTM Revise and finalize monthly fee statement; email communications with Attny Bongartz re same 0.30 \$400.00 \$120.00 12/20/2023 MTM Attention to additional redaction issues re fee application 0.10 \$400.00 \$40.00 12/19/2023 MBG Review OMJB invoice and draft Fee Application for November time and

12/19/2023 MTM Revise and supplement draft monthly fee application and attention to redactions re legal invoice \$400.00 \$200.00 12/14/2023 MBG Finalize Motion for Continuance of MSJ hearing. 0.20 \$125.00 \$25.00 12/13/2023 MTM Revise, supplement and finalize motion to continue MSJ hearing; email communications with Attny Despins re same \$400.00 \$120.00 12/12/2023 TPJ Outlining AIG discovery compliance 0.90 \$450.00 \$405.00 12/12/2023 MBG Review court notice of hearing re Motion for Partial Summary Judgment; draft Motion for Continuance of same. 1.10 \$125.00 \$137.50 correspondence with Attny O'Connor re same; attention to motion for

Expense 12/14/2023 Fees advanced to Logikcull INV154507 11-30-2023 \$250.00 Expense 12/27/2023 Fees advanced to Timothy J Bennett State Marshall invoice 12-7-2023 \$120.74 Expense 12/31/2023 PACER: Month of December \$7.30 Expense 12/31/2023 Copying: Month of December \$2.80

Timothy Jensen 5.3 \$450.00 \$2,385.00

Michael McCormack 6.8 \$400.00 \$2,720.00 Melissa Gambardella 7.9 \$125.00 \$987.50

Invoice Number Due On Amount Due Payments Received Balance Due

27021 09/25/2023 \$99,873.56 \$80,469.56 \$19,404.00 27098 10/11/2023 \$35,374.76 \$28,534.76 \$6,840.00 27168 11/14/2023 \$24,998.95 \$20,063.45 \$4,935.50 27274 12/08/2023 \$31,249.41 \$0.00 \$31,249.41

Invoice Number Due On Amount Due Payments Received Balance Due

27360 01/09/2024 \$6,578.34 \$0.00 \$6,578.34

Please make all amounts payable to: O'Sullivan McCormack Jensen & Bliss PC REDACTED

Payment is due upon receipt.