Guo Wengui / Miles Guo — bankruptcy case · ECF #2935

UNITED STATES BANKRUPTCY COURT DISTRICT OF CONNECTICUT BRIDGEPORT DIVISION

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HO WAN KWOK, et al., : :

-------------------------------------------------------- x FOURTH INTERIM FEE APPLICATION COVER SHEET

Interim Application of: Paul Hastings LLP

Date of Entry of Retention Orders: August

Fees: \$6,911,034.50 Voluntary Fee Reductions: \$20,287.00 Expenses: \$718,236.31 Voluntary Expense Reductions: \$5,015.10

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 In accordance with the Interim Compensation Procedures Order (as defined below), Paul Hastings previously received payments in the amount of \$1,340,225.60 in fees and \$217,375.78 in expenses with respect to its monthly fee statement for September 2023. Paul Hastings has not yet received payment of its fees and expenses with respect to its monthly fee statements for October, November, and December 2023 (but 80% of such fees and all such expenses may be paid, at a future date, in accordance with the Interim Compensation Procedures Order). In addition, while this Application seeks allowance of all fees incurred during the Fee Period, Paul Hastings is not seeking, at this time, payment of the 20% holdback with respect to the September, October, November, and December, 2023 fee statements. Fees Previously Requested: Retainer Request:

Awarded Fees: \$23,285,506.25 Paid Fees: \$20,983,765.40

Expenses Previously Requested: Expense Detail: Requested Expenses: \$772,497.69 Retainer Received: N/A Awarded Expenses: \$772,497.69 Copies per page cost and total: \$0.08 b/w Paid Expenses: \$772,497.69 (per page)

Expenses Fees Awarded and Paid;

Expense Reimbursement Application for the Period from July 8, 2022 through October 31, 20223

Docket No.

10/31/22 \$0.00 \$63,631.75 Not applicable Awarded: \$63,631.75 Paid:

Special Fee Application (Sanctions) for Services Rendered in Securing Compliance with Court-Authorized Subpoenas4

Docket No.

3/10/23 \$83,370.26 \$0.00 Awarded: Paid:

First Interim Fee Application for the Period from July 8, 2022 through February 28, 2023

Docket No.

2/28/23 \$12,326,802.00 \$348,813.54 Awarded: Paid:

Docket No. 1964, entered Awarded: \$348,813.54 Paid:

Second Interim Fee Application for the Period from March 1, 2023 through June 30, 2023

Docket No.

credit)5 \$213,914.83 Awarded: Paid:

Docket No. 2190, entered Awarde>Paid:

Third Interim Fee Application for the Period from July 1, 2023 through August 31, 2023 10/16/23 7/1/23 - \$3,725,984.25 \$146,137.57 Awarded: \$3,525,984.25 Awarded: \$146,137.57 \$705,196.85 Docket No. 2256 8/31/23 Paid:

Docket No. 2408, entered Paid:

Total Awarded:

\$20,983,765.40 Awarde>Paid:

3 The First Interim Fee Application excluded the expense reimbursements requested in the Expense Reimbursement Application.

- 4 The First Interim Fee Application and the Second Interim Fee Application included the amounts sought in the Special Fee Application (for the period through February 28, 2023 and the period from March 1 - 10, 2023, respectively). Paul Hastings included these amounts not to recover twice but to ensure payment in the event the HK Parties (defined below) do not comply with the Sanctions Order (defined below). To be clear, Paul Hastings seeks to recover payment of the requested \$83,370.26 only once. - 5 Due to an inadvertent oversight, the monthly fee statements for January and February 2023 (which were covered in the First Interim Fee Application) did not reflect the voluntary reduction in the hourly rate of the Trustee (from \$1,975 to \$1,860 per hour), resulting in an overstatement of Paul Hastings' fees by \$20,096.25 with respect to these two months. This amount was credited in the Second Interim Fee Application against fees requested therein. - 6 Pursuant to the order granting the Third Interim Fee Application, the Debtors' estates were authorized to pay Paul Hastings \$2,820,787.40. The amount previously paid to Paul Hastings pursuant the Interim Compensation Procedures Order for services rendered during the months of July and August 2023 was \$2,980,787.40. The overpayment of \$160,000.00 (i.e., 80% of \$200,000.00) was credited on Paul Hastings' September fee statement. Case 22-50073 Doc 2935 Filed 02/19/24 Entered 02/19/24 20:04:06 Page 4 of 779 MONTHLY FEE REQUESTS FOR FOURTH INTERIM FEE PERIOD7

9/30/23 Amount Requested \$1,937,282.00 \$1,389,825.608 \$217,375.78

Reductions (\$62,000.00) (\$49,600.00) No reductions

Requested \$1,875,282.00 \$1,340,225.60 \$217,375.78 \$1,340,225.60 \$217,375.78 \$375,056.40

10/31/23 Amount Requested \$1,651,879.00 \$1,321,503.20 \$105,699.65 \$0.00 \$0.00 \$330,375.80

11/30/23 Amount Requested \$1,831,721.25 \$1,465,377.00 \$85,540.86 \$0.00 \$0.00 \$366,344.25

12/31/23 Amount Requested \$1,572,439.25 \$1,257,951.40 \$309,620.02 \$0.00 \$0.00 \$314,487.85

Requested \$6,993,321.50 \$5,434,657.20 \$718,236.31

Reductions (\$62,000.00) (\$49,600.00) No reductions

Requested \$6,931,321.5010 \$5,385,057.20 \$718,236.31 \$1,340,225.60 \$217,375.78 \$1,386,264.30

7 On August 18, 2023, the Court entered the Order Establishing Procedures for Interim Compensation and Reimbursement of Expenses for Retained Professionals [Docket No. 2094] (the "Interim Compensation Procedures Order"), pursuant to which estate professionals (including Paul Hastings) commenced filing monthly fee statements.

- 8 Reflects \$160,000 credit pursuant to the order granting the Third Interim Fee Application. - 9 Reductions agreed upon with the U.S. Trustee.

10 As detailed below, as a further accommodation to these estates and to minimize the review process by the Court and parties in interest, Paul Hastings is not seeking allowance or payment at this time for the fees of twelve (12) timekeepers who billed less than five (5) hours during the Fee Period in the aggregate amount of \$20,287.00; however, such fees were included in the September, October, November, and December fee statements. If this Application is granted, Paul Hastings will credit such amount on its subsequent monthly fee statement. HOURS AND RATES PER PROFESSIONAL AND PARAPROFESSIONAL DURING FEE PERIOD

Bassett, Nicholas Corporate, 2007 \$1,675.00 483.70 \$810,197.50 2 Bassett, Nicholas (travel; ½ rate) Corporate, 2007 \$837.50 3.00 \$2,512.50 2 Despins, Luc Restructuring, 1986 \$1,975.00 306 \$604,350.00 1 Despins, Luc (travel; ½ rate) Restructuring, 1986 \$987.50 3.70 \$3,653.75 1 Weitzman, Avi Litigation, 2000 \$1,750.00 11.70 \$20,475.00 N/A

Bongartz, Alex Restructuring, 2007 \$1,675.00 254.40 \$426,120.00 2 Bongartz, Alex (travel; ½ rate) Restructuring, 2007 \$837.50 3.20 \$2,680.00 2 Luft, Avi Corporate, 2000 \$1,675.00 756.80 \$1,267,640.00 2 Luft, Avi (travel; ½ rate) Corporate, 2000 \$837.50 3.30 \$2,763.75 2 Traxler, Katherine Restructuring, 1990 \$1,055.00 9.90 \$10,444.50 2 Of Counsel Total: 1,027.60 \$1,709,648.25

Barron, Douglass Corporate, 2012 \$1,360.00 530.00 \$720,800.00 2 Barron, Douglass (travel, bill at Corporate, 2012 \$680.00 5.50 \$3,740.00 2

Catalano, Kristin Corporate, 2021 \$940.00 276.90 \$260,286.00 2 Farmer, Will Corporate, 2018 \$1,270.00 256.70 \$326,009.00 2

Complex Litigation & \$940.00 464.50 \$436,630.00 2

Arbitration, 2018 \$1,210.00 77.50 \$93,775.00 Maza, Shlomo Corporate, 2012 \$1,360.00 285.50 \$388,280.00 2 Ostrander, Will Litigation, 2021 \$1,045.00 53.20 \$55,594.00 N/A Sadler, Tess Corporate, 2019 \$1,210.00 38.40 \$46,464.00 2 Simpson, Louise Corporate, 2022 \$855.00 6.00 \$5,130.00 1 Song, Luyi Corporate, 2023 \$855.00 753.60 \$644,328.00 2 Song, Luyi (travel, bill at ½ rate) Corporate, 2023 \$427.50 13.00 \$5,557.50 2 Sutton, Ezra Corporate, 2021 \$1,045.00 543.20 \$567,644.00 2 Associate Total: 3,304.00 \$3,554,237.50

Kuo, Jocelyn Paralegal \$540.00 187.70 \$101,358.00 N/A Mohamed, David Paralegal \$540.00 304.30 \$164,322.00 1

Paraprofessional Total: 497.70 \$267,960.00

PRIOR AGREED-UPON REDUCTIONS: (\$62,000.00)

UNITED STATES BANKRUPTCY COURT DISTRICT OF CONNECTICUT BRIDGEPORT DIVISION

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HO WAN KWOK, et al., : Case No. 22-50073 (JAM)

-------------------------------------------------------- x FOURTH INTERIM FEE APPLICATION OF PAUL HASTINGS LLP FOR COMPENSATION AND REIMBURSEMENT OF EXPENSES FOR PERIOD FROM SEPTEMBER 1, 2023 THROUGH DECEMBER 31, 2023

Pursuant to sections 105(a), 328, 330, and 331 of title 11 of the United States Code (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 [Docket No. 2094] (the "Interim Compensation Procedures Order"), Paul Hastings LLP ("Paul Hastings"), as counsel to (a) Luc A. Despins, in his capacity as the chapter 11 trustee (the "Trustee") appointed in the chapter 11 case of Ho Wan Kwok (the "Individual Debtor"), (b) Genever Holdings Corporation ("Genever (BVI)"), and (c) Genever Holdings LLC ("Genever (US)" and, together with Genever (BVI), the "Genever Debtors"), hereby files this

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).

*Fourth Interim Fee Application of Paul Hastings LLP for Compensation and Reimbursement of Expenses for the Period from September 1, 2023 through December 31, 2023* (the

"Application"). By this Application, Paul Hastings requests allowance and payment2 of the compensation for professional services performed by Paul Hastings attorneys (including the Trustee3 ) and reimbursement of its actual and necessary expenses incurred during the period from September 1, 2023 through and including December 31, 2023 (the "Fee Period"). In support of this Application, Paul Hastings respectfully states as follows:

1. During the Fee Period, the Trustee and Paul Hastings continued the investigation into the financial affairs of the Individual Debtor and his corporate "shell game" to shield companies and assets under his ownership and/or control from his creditors. Given the vast network of companies affiliated with the Individual Debtor, and the fact that these companies or their assets are located around the world, the Trustee's investigation was, and continues to be, extensive. For example, to date, the Trustee's investigation has included, among other things, (a) seeking discovery under Bankruptcy Rule 2004 from hundreds of individuals and entities connected with the Individual Debtor and his various businesses, (b) analyzing thousands of

2 In accordance with the Interim Compensation Procedures Order (as defined below), Paul Hastings previously received payments in the amount of \$1,340,225.60 in fees and \$217,375.78 in expenses with respect to its monthly fee statement for September 2023. Paul Hastings has not yet received payment of its fees and expenses with respect to its monthly fee statements for October, November, and December 2023 (but 80% of such fees and all such expenses may be paid, at a future date, in accordance with the Interim Compensation Procedures Order). In addition, while this Application seeks allowance of all fees incurred during the Fee Period, Paul Hastings is not seeking, at this time, payment of the 20% holdback with respect to the September, October, November, and December, 2023 fee statements.

3 In accordance with the Retention Order (as defined below), the Trustee is authorized to act as one of the attorneys for the Individual Debtor's estate, and, accordingly, this Application also seeks allowance of the Trustee's fees in such capacity. For the avoidance of doubt, in this Application, references to services provided by Paul Hastings attorneys shall include the Trustee. To be clear, time spent by the Trustee in his capacity as chapter 11 trustee, is not part of this Application, and compensation therefor will be sought by separate application.

documents produced in response to the Trustee's Rule 2004 subpoenas, (c) deposing several targets of the Trustee's Rule 2004 discovery, (d) interviewing former employees and business associates of the Individual Debtor (including several communications with confidential informants), (e) researching property records, and (f) pursuing litigation to recover property of the estate.

2. In addition, during the Fee Period, as part of the Trustee's continuing efforts to recover assets for the benefit of this estate, the Trustee commenced or continued to prosecute, with the assistance of Paul Hastings, several adversary proceedings. As detailed below, in these adversary proceedings, as a result of the Trustee's and Paul Hastings' efforts during the Fee Period, the Trustee has secured numerous valuable injunctions, judgments, and settlements, as well as obtained access to tens of millions of dollars in escrow funds.

- At the beginning of the Fee Period, the Court granted the Trustee's summary judgment motion in the interpleader action commenced by U.S. Bank N.A. ("US Bank") to resolve a dispute regarding the release of \$33 million in funds (the "Escrow Funds") held by U.S. Bank. In particular, the Court authorized the Trustee to remove the \$33 million in Escrow Funds from the segregated account and deposit such funds into the estate's general account(s). - During the Fee Period, Paul Hastings attorneys handled all matters arising out of the appeal of this Court's rulings that HK USA is an alter ego of the Individual Debtor and that the \$33 million held in escrow by U.S. Bank are property of the estate. In that appeal, the appellees, i.e., HK International Funds Investments (USA) Limited, LLC ("HK USA") and Mei Guo (i.e., the Individual Debtor's daughter). Appellate briefing is now complete, and the parties are awaiting a ruling from the United States District Court for the District of Connecticut. - During the Fee Period, Paul Hastings attorneys continued to prosecute the Trustee's adversary proceeding against HCHK Technologies, Inc. ("HCHK Technologies"), HCHK Property Management, Inc. ("HCHK Property"), Lexington Property and Staffing, Inc. ("Lexington Property," and, together with HCHK Technologies and HCHK Property, the "HCHK Entities"), Brian Hofmeister, in his capacity as assignee of the HCHK Entities (the "Assignee"), and certain other parties, seeking determinations that, among other things, (a) the HCHK Entities are alter egos of the Individual Debtor

and (b) the Individual Debtor is the equitable owner of the HCHK Entities and/or their assets.

- o Among other things, Paul Hastings attorneys prepared the Trustee's motion for entry of a default against certain defendants, which the Court entered on September 29, 2023. - o The Trustee also successfully opposed the attempt by certain Kwok affiliated entities to intervene in this adversary proceeding, which required extensive preparation for and participation in an evidentiary hearing. - During the Fee Period, Paul Hastings attorneys continued to prosecute the Trustee's adversary proceeding against Scott Barnett (the Individual Debtor's driver and/or bodyguard), Taurus Fund, LLC, and Taurus Management LLC, seeking determinations that, among other things, (a) the Individual Debtor is the equitable owner of a 50,000 square foot, castle-styled private residence with 12.5-acre grounds located at 675 Ramapo Valley Road, Mahwah, New Jersey 07430 (the "Mahwah Mansion"), (b) the Debtor is the equitable owner of Taurus Fund, LLC (the entity holding title to the Mahwah Mansion), and (c) that Taurus Fund is an alter ego of the Individual Debtor. - o Significantly, during the Fee Period, Paul Hastings attorneys sought emergency relief related to preservation of property of the estate at the Mahwah Mansion. These efforts resulted in a joint report regarding a process for creating an inventory of personalty and fixtures in or on the Mahwah Mansion to ensure no further removal of potential property of the Individual Debtor's estate. - o Additionally, during the Fee Period, Paul Hastings attorneys sought emergency relief to restrict access to the storage facility (at which facility some of the personal property and fixtures previously kept at the Mahwah Mansion were located). On December 21, 2023, the Court issued an order which largely granted the requested relief. - During the Fee Period, Paul Hastings continued to prosecute the Trustee's adversary proceeding against Golden Spring (New York) Ltd. ("Golden Spring") and China Golden Spring Group (Hong Kong) Limited ("China Golden Spring" and, together with Golden Spring, the "Golden Spring Entities"), seeking determinations that, among other things, (a) Golden Spring is the alter ego of the Individual Debtor and (b) the Individual Debtor is the equitable owner of Golden Spring and/or its assets (notwithstanding China Golden Spring's purported ownership interest in Golden Spring). - During the Fee Period, Paul Hastings attorneys, together with the Trustee's local counsel Neubert Pepe & Monteith, P.C. ("NPM"), prepared the Trustee's motion for entry of a default judgment against the Golden Spring Entities, which (i) detailed the merits of Trustee's claims

against the Golden Spring Entities, and (ii) summarized the sufficiency Trustee's service on the Golden Spring Entities, and the Golden Spring Entities failure to respond and subsequent default. The Court granted the default judgment motion by order dated December 4, 2023.

- During the Fee Period, Paul Hastings continued to prosecute the Trustee's adversary proceeding against Greenwich Land LLC ("Greenwich Land") and the Individual Debtor's alleged wife (i.e., Hing Chi Ngok), seeking determinations that, among other things, (a) Greenwich Land (which holds legal title to the Individual Debtor's residence in Greenwich, Connecticut) is an alter ego of the Debtor and (b) the Debtor is the equitable owner of Greenwich Land. - o During the Fee Period, Paul Hastings attorneys prepared the Trustee's summary judgment motion. Oral argument on the summary judgment motion was held on January 9, 2024, shortly after the end of the Fee Period. - o The Trustee and his counsel's efforts in the Greenwich Land adversary proceeding revealed an extensive web of transfers both into Greenwich Land and out of such entity, which lead the Trustee to recently assert millions of dollars in fraudulent transfers. - During the Fee Period, Paul Hastings continued to assist NPM in prosecuting the Trustee's adversary proceeding against Mei Guo, seeking determinations that, among other things, (a) the proceeds from the sale of the Individual Debtor's private Bombardier jet are property of the estate and (b) a series of BVI registered shell companies purportedly held by Mei Guo are property of the Individual Debtor's chapter 11 estate. - o During the Fee Period, Paul Hastings attorneys assisted NPM in preparing the Trustee's motion for summary judgment in this adversary proceeding, which was filed on December 28, 2023. Oral argument in the Mei Guo adversary proceeding was held on February 5, 2024. - o During the Fee Period, the Trustee commenced an adversary proceeding against Ace Decade Holdings Limited ("Ace Decade"), Yvette Wang, and Rui Hao seeking a declaration that the transfer of the Ace Decade shares by Yvette Wang to Rui Hao is void, in light of this Court's prior ruling that the Trustee beneficially owns the Ace Decade shares. - 3. In addition, during the Fee Period, Paul Hastings attorneys assisted the Trustee in

investigating and beginning to prepare a complaint to recover damages suffered by the Individual

Debtor's creditors as a result of an extensive, years' long racketeering conspiracy involving Case 22-50073 Doc 2935 Filed 02/19/24 Entered 02/19/24 20:04:06 Page 11 of 779

multiple fraudulent schemes facilitated by various associates of the Individual Debtor in violation of the Racketeer Influenced and Corrupt Organization Act of 1970 ("RICO").

4. Furthermore, during the Fee Period, the damage caused by the fire that occurred on March 15, 2023 at the 18th floor apartment at the Sherry Netherland (the "Sherry Netherland Apartment") continued to require the Trustee's and Paul Hastings' attention. Of particular note, during the Fee Period, Paul Hastings attorneys continued to prosecute Genever (US)'s motion to remediate the area of the Sherry Netherland Apartment affected by the March 15, 2023 fire (including preparing a supplement to the remediation motion, filed with the Court on September 8, 2023). The Court granted the remediation motion by order dated September 19, 2023 [Docket No. 2213]. Following the approval of the remediation motion, Paul Hastings attorneys worked with Genever (US) architect (Dave Acheson) to develop a remediation strategy, including as it relates to asbestos abatement and the permitting process.

5. During the Fee Period, the Trustee was also able to successfully sell the Lady May II, generating net proceeds to the estate in an amount of over \$370,000.

6. All the while, during the Fee Period, the Trustee and Paul Hastings provided a wide range of other chapter 11 related services, including, for example, handling fifteen hearings and status conferences, preparing and prosecuting numerous substantive motions and preparing monthly operating reports.

7. While the Trustee has made substantial headway in these chapter 11 cases, progress continues to be slowed by the unprecedented level of obstructionism and interference, both inside and outside the courtroom, from the Individual Debtor and his associates at every turn. For example, on August 30, 2023, the Individual Debtor filed a motion (joined by Yvette Wang) in the Criminal Case seeking to stay these chapter 11 cases, pending resolution of his Case 22-50073 Doc 2935 Filed 02/19/24 Entered 02/19/24 20:04:06 Page 12 of 779

criminal trial. In response, Paul Hastings prepared the Trustee's emergency motion, filed on September 1, 2023 [Docket No. 2160], seeking to enjoin the Individual Debtor's stay motion on the basis that such motion violated the automatic stay in these chapter 11 cases. The Trustee and the Genever Debtors also filed a response in the Criminal Case, objecting to the imposition of a stay of these chapter 11 cases. The U.S. District Court for the Southern District of New York denied the Stay Motion by order, dated December 21, 2023. In addition, the Individual Debtor and his affiliates have continued their campaign to delay or not comply with the Trustee's Rule 2004 investigation. For example, the Trustee had to engage in substantial motion practice to compel the production of documents by G Club Operations LLC ("G Club Operations").

8. While substantially all of the relief requested by the Trustee has been granted (and that requested by the Individual Debtor and his associated individuals and entities has been substantially denied), the Trustee necessarily expended substantial time and resources on these matters. Although it is extremely difficult to determine with precision the cost of addressing these issues, the Trustee continues to believe that a substantial portion of the fees generated during the Fee Period were the result of the Individual Debtor's or his affiliates' continuing noncompliance with the Bankruptcy Code and/or active opposition or interference with the Trustee's administration of these chapter 11 cases.

9. As detailed in this Application, Paul Hastings has performed all of its services in an economic, effective, and efficient manner commensurate with the complexity and importance of the issues involved. The work performed by Paul Hastings was carefully assigned to appropriate professionals or paraprofessionals according to the experience and level of expertise required for each particular task. Whenever possible, Paul Hastings sought to minimize the costs of Paul Hastings' services by utilizing talented junior attorneys and paraprofessionals to handle Case 22-50073 Doc 2935 Filed 02/19/24 Entered 02/19/24 20:04:06 Page 13 of 779

the more routine aspects of the assignments. Moreover, as detailed below, Paul Hastings has delegated numerous work streams (including the recent avoidance actions process) to local Connecticut counsel (which has a lower rate structure than Paul Hastings).

10. To further minimize the costs of intra-Paul Hastings communications and education about these chapter 11 cases, the Trustee utilized a small group of Paul Hastings attorneys for the majority of the work in these chapter 11 cases. Also, as a general matter, in addition to the Trustee, no more than two Paul Hastings attorneys attended the various hearings held during the Fee Period (and in some instances, the Trustee handled hearings without attendance of any Paul Hastings attorneys), thereby minimizing not only the time billed on these hearings/sessions but also the cost of travel. Furthermore, to the extent appropriate, the Trustee and Paul Hastings sought to work closely with counsel to Pacific Alliance Asia Opportunity Fund L.P. ("PAX"), including to take advantage of the knowledge of the Individual Debtor's assets and financial affairs that PAX acquired during the prepetition litigation against the Individual Debtor in New York state court. Moreover, as noted on the record at the August 2, 2022 hearing on Paul Hastings' retention application, the Trustee has agreed not to seek a percentage recovery under section 326 of the Bankruptcy Code, and, instead, agreed that he would only be compensated (at his standard hourly rate) for his time.

11. Finally, as an accommodation to these estates and to minimize the review process by the Court and parties in interest, Paul Hastings is not seeking allowance or payment at this time for the fees of (12) timekeepers who billed less than five (5) hours during the Fee Period in the aggregate amount of \$20,287.00. The time billed by these timekeepers was reasonable, and Paul Hastings reserves the right to seek allowance of these fees based on the facts and Case 22-50073 Doc 2935 Filed 02/19/24 Entered 02/19/24 20:04:06 Page 14 of 779

circumstances of these cases, including, without limitation, if objections are interposed to the allowance of Paul Hastings' fees and expenses.

12. In sum, Paul Hastings respectfully submits that the services for which it seeks compensation in this Application were necessary for and beneficial to these chapter 11 estates and their stakeholders. Accordingly, in light of the nature and complexity of these chapter 11 cases, Paul Hastings' charges for professional services performed and expenses incurred are reasonable under applicable standards. For all these reasons, Paul Hastings respectfully requests that the Court grant the Application and allow interim compensation for professional services performed and reimbursement for expenses as requested. JURISDICTION, VENUE, BASES FOR RELIEF, AND COMPLIANCE

13. 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 (as amended). 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.

14. 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.

15. Paul Hastings believes that this Application, together with the attachments hereto, substantially complies with the Bankruptcy Rules, Local Rule 2016-1, the Interim Compensation Procedures Order, 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* Case 22-50073 Doc 2935 Filed 02/19/24 Entered 02/19/24 20:04:06 Page 15 of 779

Larger Chapter 11 Cases (the "U.S. Trustee Guidelines").4 Paul Hastings respectfully requests a waiver of any of the foregoing requirements not met by this Application.

- 16. Attached and incorporated herein by reference are the following Exhibits: - Exhibit A contains disclosures regarding "customary and comparable compensation." - Exhibit B1 contains a summary of Paul Hastings' timekeepers included in this Application. - Exhibit B2 contains a summary of Paul Hastings' timekeepers who billed less than five (5) hours during the Fee Period and for whom Paul Hastings is not seeking allowance or payment at this time. - Exhibit C contains a summary of the compensation requested by project category. - Exhibit D contains a summary of the compensation requested by Matter ID. - Exhibit E contains the expense reimbursements requested by category. - Exhibit F contains the monthly statements of Paul Hastings detailing the services performed and itemizing the expenses incurred during the Fee Period. - Exhibit G contains the Proposed Order.

17. On February 15, 2022 (the "Petition Date"), the Individual Debtor filed with the

Court a voluntary petition for relief under chapter 11 of the Bankruptcy Code.

18. On March 21, 2022, the United States Trustee appointed an Official Committee of

Unsecured Creditors ("Committee") in the Individual Debtor's chapter 11 case. No examiner

has been appointed in the Individual Debtor's chapter 11 case.

4 Paul Hastings 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. Case 22-50073 Doc 2935 Filed 02/19/24 Entered 02/19/24 20:04:06 Page 16 of 779

19. 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 chapter 11 case of Ho Wan Kwok. 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 the Trustee in the chapter 11 case of Ho Wan Kwok.

20. The Court authorized Paul Hastings' retention as attorneys for the Trustee pursuant to the *Order Authorizing and Approving the Retention and Employment of Paul Hastings LLP as Counsel to Chapter 11 Trustee, effective as of July 8, 2022* [Docket No. 668] (together with the retention order with respect to the Genever Debtors [Docket No. 1376], the "Retention Order"), entered on August 2, 2022. The Retention Order authorizes Paul Hastings to be compensated on an hourly basis and reimbursed for actual and necessary out-of-pocket 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. Moreover, at the August 1, 2022 hearing on the Paul Hastings' retention application, the Court made clear that it approved Paul Hastings' New York rate structure.5 In addition, as noted on the record at that hearing, the Trustee has agreed not to seek a percentage recovery under section 326 of the Bankruptcy Code, and, instead, agreed that he would only be compensated (at his standard hourly rate) for his time.

21. In light of the Trustee's ongoing investigation into the Individual Debtor's assets and his financial affairs, the Trustee is unable at this time to predict when he will be in a position to file a plan and disclosure statement. All quarterly fees have been paid to the United States

5 See Aug. 1, 2022 H'rg Tr. at 113:15-19 ("MR. DESPINS: But I want to be clear is that that's not going to be a back door way to bring local rates, or anything like that -- THE COURT: No, I'm not doing that. I agree with that."). Case 22-50073 Doc 2935 Filed 02/19/24 Entered 02/19/24 20:04:06 Page 17 of 779

Trustee, and all monthly operating reports have been filed through December 2023 (for the Individual Debtor's chapter 11 case), December 2023 (for Genever (BVI)'s chapter 11 case), and November 2023 (for Genever (US)'s chapter 11 case).

22. At this time, the amount of cash in the Trustee's account is approximately \$72 million.6 The Trustee is not aware of any material administrative expense claims other than claims for professional fees and expenses.

23. On October 11, 2022, Genever (BVI) -- an entity wholly owned by the Individual Debtor -- filed a voluntary petition for relief under chapter 11 of the Bankruptcy Code with this Court.

24. No trustee or official committee of unsecured creditors has been appointed in Genever (BVI)'s chapter 11 case.

25. October 14, 2022, the Court entered an order granting joint administration of the Individual Debtor's chapter 11 case and Genever (BVI)'s chapter 11 case [Docket No. 970].

26. On January 24, 2023, the Court granted Genever (BVI)'s application to retain Paul Hastings as counsel to Genever (BVI) in its chapter 11 case, effective as of its petition date, i.e., October 11, 2022 [Docket No. 1376].

27. On October 12, 2020, Genever Holdings LLC -- an entity wholly owned by Genever (BVI) -- filed a voluntary petition for relief under chapter 11 of title 11 of the United States Code in the United States Bankruptcy Court for the Southern District of New York (the

6 This amount includes approximately \$38.8 million in funds received and held by the Trustee pursuant to the settlement with the Assignee in the HCHK Adversary Proceeding (as defined below). Case 22-50073 Doc 2935 Filed 02/19/24 Entered 02/19/24 20:04:06 Page 18 of 779

"SDNY Bankruptcy Court"), thereby commencing case number 20-12411 (JLG) (the "SDNY Bankruptcy Case").

28. On November 3, 2022, the SDNY Bankruptcy Court entered an order [Docket No. 225 in Case No. 22-50592] transferring the venue of the SDNY Bankruptcy Case to this Court, which assigned it Case Number 22-50592.

29. On November 21, 2022, the Court entered an order granting joint administration of the Genever (US) Debtor's chapter 11 case with the jointly administered cases of the Individual Debtor and the Genever (BVI) Debtor's chapter 11 case [Docket No. 1141].

30. On January 24, 2023, the Court granted Genever (US)'s application to retain Paul Hastings as counsel to Genever (US) in its chapter 11 case, effective as of the order transferring venue of the SDNY Bankruptcy Case to this Court, i.e., November 3, 2022 [Docket No. 1376].

31. By this Application, the Trustee and Paul Hastings request allowance of fees (in the amount of \$6,911,034.50) and expenses incurred (in the amount of \$718,236.31) for services rendered by, for, and on behalf of the Trustee during the Fee Period.7 The Trustee has approved the amounts requested by Paul Hastings herein.

32. While this Application seeks allowance of all fees incurred during the Fee Period, Paul Hastings does not seek, at this time, payment of the 20% holdback withheld by the Debtors' estates with respect to Fee Period. Moreover, as noted, Paul Hastings has not yet been paid with respect to its monthly fee statement for the months of October, November, and December 2023.

7 As an accommodation to these estates and to minimize the review process by the Court and parties in interest, Paul Hastings is not seeking allowance or payment at this time for the fees of (12) timekeepers who billed less than five (5) hours during the Fee Period in the aggregate amount of \$20,287.00. The time billed by these timekeepers was reasonable, and Paul Hastings reserves the right to seek allowance of these fees based on the facts and circumstances of these cases, including, without limitation, if objections are interposed to the allowance of Paul Hastings' fees and expenses.

For the avoidance of doubt, 80% of the fees for the months of October, November, and

December 2023 and all expenses for such months may be paid in accordance with the Interim

Compensation Procedures Order.

33. To date, the Trustee and Paul Hastings have submitted the following fee/expense-

related applications in these chapter 11 cases:

- (a) On March 1, 2023, Paul Hastings submitted the *First Interim Application of Chapter 11 Trustee and his Counsel, Paul Hastings LLP, for Reimbursement of Expenses for the Period from July 8, 2022 through October 31, 2022* [Docket No. 1495] (the "Expense Reimbursement Application"), whereby the Trustee and Paul Hastings requested reimbursement of the actual and necessary expenses incurred by the Trustee and Paul Hastings during the period from July 8, 2022 through October 31, 2022 in the amount of \$63,631.75. On May 3, 2023, the Court entered an order granting the Expense Reimbursement Application [Docket No. 1747] (the "Expense Reimbursement Order"). The Individual Debtor's estate paid the foregoing amount on May 8, 2023. - (b) On April 10, 2023, Paul Hastings submitted the *Special Fee Application of Chapter 11 Trustee and his Counsel, Paul Hastings LLP, for Services Rendered in Securing Compliance with Court-Authorized Subpoenas* [Docket No. 1648] (the "Special Fee Application"). In the Special Fee Application, Paul Hastings requested allowance and payment of fees in the amount of \$83,370.26 in accordance with the HK Parties Contempt Order.8 On April 21, 2023, the Court approved the Special Fee Application and ordered the HK Parties to remit payment of \$83,370.26 to the chapter 11 estate of the Individual Debtor [Docket No. 1693] (the "HK Parties Sanctions Order"). As of the filing of this Application, the HK Parties have not remitted payment. - (c) On May 30, 2023, Paul Hastings submitted the *Interim Fee Application of Paul Hastings LLP for Compensation and Reimbursement of Expenses for the Period from July 8, 2022 through February 28, 2023* [Docket No. 1831] (the "First Interim Fee Application") seeking \$12,326,802.00 in fees and \$348,813.54 for reimbursement of expenses. The First Interim Fee Application excluded the expense reimbursements approved in the Expense Reimbursement Order. The

8 On March 10, 2023, the Court entered the *Order Holding HK Parties in Contempt of Court and Sanctioning HK Parties, Attorney Vartan and Chiesa Shahinian & Giantomasi PC* [Docket No. 1537] (the "HK Parties Contempt Order"), pursuant to which the Court ordered Ms. Mei Guo, HK USA, attorney Lee Vartan, and Chiesa Shahinian & Giantomasi PC (collectively, the "HK Parties"), jointly and severally, to compensate the Trustee and his counsel, Paul Hastings, for reasonable attorneys' fees and expenses associated with the Trustee's efforts to secure compliance with certain Court-authorized subpoenas.

First Interim Fee Application included the amount requested in the Special Fee Application (for the period through February 28, 2023). However, to the extent the Trustee is able to recover the fees under the HK Parties Sanctions Order from the HK Parties, Paul Hastings will not seek payment of such fees from these estates.9 Pursuant to agreement with the U.S. Trustee, Paul Hastings reduced its fee request by \$550,000. On June 29, 2023, the Court approved the First Interim Fee Application [Docket No. 1964] with such reduction. Paul Hastings has received payment of \$11,776,802.00 in fees and \$348,813.54 in expenses in connection with the First Interim Fee Application.

- (d) On August 4, 2023, Paul Hastings submitted the *Second Interim Fee Application of Paul Hastings LLP for Compensation and Reimbursement of Expenses for the Period from March 1, 2023 through June 30, 2023* [Docket No. 2051] (the "Second Interim Fee Application") seeking \$8,037,720.00 in fees and \$213,914.83 for reimbursement of expenses. The Second Interim Fee Application included the amount requested in the Special Fee Application (for the period from March 1, 2023 through March 10, 2023). However, to the extent the Trustee is able to recover the fees under the HK Parties Sanctions Order from the HK Parties, Paul Hastings will not seek payment of such fees from these estates. Pursuant to agreement with the U.S. Trustee, Paul Hastings reduced its fee request by \$55,000.00. On September 12, 2023, the Court approved the Second Interim Fee Application [Docket No. 2190] with such reduction. Paul Hastings has received payment of \$6,386,176.00 in fees (or 80% of the allowed fees in the amount of \$7,982,720) and \$213,914.83 in expenses in connection with the Second Interim Fee Application. - (e) On October 16, 2023, Paul Hastings submitted the *Third Interim Fee Application of Paul Hastings LLP for Compensation and Reimbursement of Expenses for the Period from July 1, 2023 through August 31, 2023* [Docket No. 2256] (the "Third Interim Fee Application") seeking \$3,725,984.25 in fees and \$146,137.57 for reimbursement of expenses. Pursuant to agreement with the U.S. Trustee, Paul Hastings reduced its fee request by \$200,000.00. On November 30, 2023, the Court entered an order approving the Third Interim Fee Application [Docket No. 2408] (the "Third Interim Fee Order") with such reduction. Paul Hastings has received payment of \$2,820,787.4010 in fees (or 80% of the allowed fees in the

9 At this time, the HK Parties have not paid the amounts due under the HK Parties Sanctions Order (even though such amounts were due on May 5, 2023). Indeed, the HK Parties have (unsuccessfully) sought reconsideration of the HK Parties Sanctions Order [Docket Nos. 1730 and 1733] and, thereafter, appealed both the HK Parties Sanctions Order and the order denying reconsideration [Docket No. 1750], as well as sought a stay pending appeal [Docket No. 1770]. That request for a stay was denied by order dated May 15, 2023 [Docket No. 1791]. That said, the Trustee agreed not to seek to enforce the Sanctions Order pending the District Court's decision on the appeal.

10 Pursuant to the Interim Compensation Procedures Order, Paul Hastings had previously received \$2,980,787.40 in payments for fees incurred in July and August 2023. Accordingly, as part of its September 2023 monthly fee statement, Paul Hastings included a credit of \$160,000.00 (i.e., 80% of the agreed-upon \$200,000.00 reduction).

amount of \$3,525,984.25) and \$146,137.57 in expenses in connection with the Third Interim Fee Application.

- (f) Pursuant to the Interim Compensation Procedures Order, Paul Hastings submitted monthly fee statements for services rendered during the Fee Period. See Docket Nos. 2419, 2543, 2875, and 2932. Paul Hastings requested - i. for September 2023 services, fees in the amount of \$1,389,825.60 (i.e., 80% of \$1,937,282.00 in fees incurred less a credit of \$160,000.0011) and \$217,375.78 in expenses, - ii. for October 2023 services, fees in the amount of \$1,321,503.20 (i.e., 80% of \$1,651,879.00 in fees incurred) and \$105,699.65 in expenses, - iii. for November 2023 services, fees in the amount of \$1,465,377.00 (i.e., 80% of \$1,831,721.25 in fees incurred) and \$85,540.86 in expenses, and - iv. for December 2023 services, fees in the amount of \$1,257,951.40 (i.e., 80% of \$1,572,439.25 in fees incurred) and \$309,620.02 in expenses.

Paul Hastings has received payment in the amount of \$1,340,225.6012 and \$217,375.78 with respect to its September 2023 services and expenses, respectively. As noted, Paul Hastings has not yet received payment with respect to its October, November, and December 2023 services.

34. Except as set forth above, neither the Trustee nor Paul Hastings has received any

payment or promise of payment from any source for services rendered during the Fee Period.

There is no agreement or understanding between the Trustee and/or Paul Hastings and any other

person other than the attorneys, employees, and staff of Paul Hastings, for the sharing of

compensation to be received for services rendered in these chapter 11 cases.

35. Paul Hastings' professional services during the Fee Period required an aggregate

expenditure of 5,637.40 recorded hours by attorneys and paraprofessionals, broken down as

11 As detailed in the Third Interim Fee Order, Paul Hastings included a credit in the amount of \$160,000.00 in its September monthly fee statement, which amount reflects the difference between (a) the fees previously paid to Paul Hastings pursuant the Interim Compensation Procedures Order for services rendered during the months of July and August 2023 (i.e., \$2,980,787.40) and (b) the fees that the estates are authorized to pay pursuant to paragraph 3 of the Third Interim Fee Order (i.e., \$2,820,787.40).

12 Paul Hastings agreed with the US Trustee to reduce its September fees by \$62,000. The payment of \$1,340,225.60 reflects the agreed-upon reduction of 80% of \$62,000 (or \$49,600). Case 22-50073 Doc 2935 Filed 02/19/24 Entered 02/19/24 20:04:06 Page 22 of 779

follows: partners (808.10 hours), of counsel (1,027.60 hours), associates (3,304.00 hours), and paraprofessionals (497.70 hours). The timekeepers who rendered such services are identified in the Cover Sheet hereto, along with the number of hours and the total compensation sought for each individual.

36. Paul Hastings maintains computerized records, in the form of monthly statements, of the time spent by all Paul Hastings' attorneys and paraprofessionals in connection with its representation of the Trustee and the Genever Debtors. With the exception of the monthly statements submitted with the Special Fee Application,13 the monthly statements are in the same form regularly used by Paul Hastings to bill its clients for services rendered and include the date that the services were rendered, a detailed, contemporaneous narrative description of the services provided, the amount of time spent for each service, and the designation of the professional who performed the service. Attached hereto as Exhibit F are true and correct copies of the monthly statements of Paul Hastings related to the fees requested herein.

37. As a courtesy to these estates and based on circumstances unique to these chapter 11 cases, Paul Hastings agreed on a reduced hourly rate for Luc Despins (from his standard hourly rate of \$2,035 to the reduced hourly rate of \$1,975.00) for the Fee Period.14 Other than this discount, the rates Paul Hastings charges for the services rendered by its professionals and paraprofessionals in these chapter 11 cases are comparable to the rates Paul Hastings charges for professional and paraprofessional services rendered in comparable nonbankruptcy related matters. In addition, when Paul Hastings' restructuring professionals and

13 As noted in the Special Fee Application, Paul Hastings' monthly statements for fees incurred in securing compliance with the Court-authorized subpoenas are limited to those services and, thus, vary in form from that regularly used by Paul Hastings to bill its clients for services rendered.

14 This translates into a voluntary waiver of \$18,471.00 in fees for the Fee Period. Case 22-50073 Doc 2935 Filed 02/19/24 Entered 02/19/24 20:04:06 Page 23 of 779

paraprofessionals work on non-bankruptcy matters, the firm generally charges their standard rate. Such fees are reasonable based on the customary compensation charged by comparably skilled practitioners in comparable non-bankruptcy cases in a competitive national legal market.

38. Paul Hastings respectfully submits that the reasonable value of the services rendered by Paul Hastings (including the Trustee) during the Fee Period is \$6,911,034.50.

39. During the Fee Period, Paul Hastings assisted and advised the Trustee and the Genever Debtors on a regular basis regarding legal matters relating to these chapter 11 cases and the pursuit and recovery of estate assets for the benefit of the chapter 11 estates and their creditors. In addition, Paul Hastings prepared various motions, applications, proposed orders, and other pleadings submitted to the Court for consideration, and performed the necessary professional services that are described below and in the fee statements attached hereto and incorporated herein by reference.15

40. For ease of reference and transparency purposes, and at the request of the U.S. Trustee, Paul Hastings created the following separate Matter IDs for services in these chapter 11 cases, including separate Matter IDs for the major adversary proceedings pending in these chapter 11 cases.

00002 Asset Recovery Investigation and Litigation

15 The description of services in this Application is limited to those matters in which Paul Hastings provided five (5) or more hours of service during the Fee Period.

41. Additionally, the Trustee and the Genever Debtors retained NPM as their local and conflicts counsel in order to provide services to the Trustee and the Genever Debtor's estates in a cost-effective manner. In particular, as detailed in the NPM retention application and related declarations, Paul Hastings and NPM have coordinated, and will continue to coordinate, each firm's respective responsibilities in connection with the representation of the Trustee and the Genever Debtors. Among other things, during the Fee Period, the following matters were delegated to NPM:

- Assisting with filings and service of pleadings in the main chapter 11 case and related adversary proceedings; - Preparing supplemental motions for discovery under Bankruptcy Rule 2004 (including for discovery targets for which Paul Hastings is conflicted), conducting meet and confers with discovery targets, and reviewing documents produced in response to Rule 2004 subpoenas;

16 Not included as part of this Application.

17 Not included as part of this Application.

- Assisting the Trustee on matters on which Paul Hastings is conflicted; - Preparing certain procedural motions, including motion to seal, motions to expedite, and motions to adjourn; - Advising the Trustee and the Genever Debtors on matters related to local Connecticut rules; - Preparing monthly operating reports for the Genever Debtors; and - Performing a variety of case administration functions, including interacting with the Court and the clerks' office as needed, preparing certificates of service, coordinating logistics for hearings, and handling other case administration functions as they arise from time to time. - 42. In addition, Paul Hastings has also delegated to NPM a number of important

matters—including entire adversary proceedings, such as the Mei Guo Adversary Proceeding (as defined below)—related to the Trustee's investigation and efforts to recover assets for the benefit of these estates. I. General Chapter 11 Trustee Representation (Matter ID 00001)

- i. Case Administration (Task Code B110) Fees: \$76,694.50 Total Hours: 97.60 - 43. During the Fee Period, Paul Hastings attorneys handled numerous case

administrative matters in connection with these chapter 11 cases, including (a) developing shortterm and long-term strategies for recovering assets for the benefit of these estates,

(b) maintaining a case calendar and task lists of open matters and work streams, (c) handling various logistical matters (including as it relates to the Trustee's bank accounts), (d) handling numerous calls and correspondence with the U.S. Trustee and PAX regarding the background to, and the administration of, these chapter 11 cases, and (e) holding internal team meetings and calls to coordinate work streams.

- ii. Pleadings Review (Task Code B113) Fees: \$82,967.00 Total Hours: 152.30 - 44. During the Fee Period, Paul Hastings attorneys reviewed and monitored the

docket of these chapter 11 cases, the related adversary proceedings, and pending state court

litigation, as well as reviewed pleadings filed therein, as necessary.

- iii. Court Hearings (Task Code B155) Fees: \$55,838.50 Total Hours: 52.40 - 45. During the Fee Period, Paul Hastings attorneys prepared for and attended

numerous hearings and status conferences. The following hearings were recorded under Matter

ID 00001, among others:

- the September 12, 2023 hearing on, among other things, (a) the Trustee and the Genever Debtors' motion to approve interdebtor DIP financing and (b) Paul Hastings' second interim fee application; - the September 27, 2023 hearing on, among other things, the Trustee's motion to retain Kroll, LLC ("Kroll"), as forensic accountant; and - the November 28, 2023 status conference and hearing on, among other things, (a) Paul Hastings' third interim fee application, (b) the application to retain Eisner Advisory Group LLC ("EA Group"), as tax advisor, and (c) supplemental motions for discovery under Bankruptcy Rule 2004. - 46. In addition, as detailed below, attendance at several other hearings during the Fee

Period were recorded under the applicable Matter ID. That said, general hearing preparation

(including agendas) for the various hearings scheduled in September, October, November, and

December 2023 was also recorded under Matter ID 00001.

- iv. Fee / Employment Applications for Paul Hastings (Task Code B160) Fees: \$82,368.00 Total Hours: 56.30 - 47. During the Fee Period, in connection with Paul Hastings' retention, Paul Hastings

attorneys prepared a supplemental declaration with respect to the Trustee's and Paul Hastings'

disinterestedness [Docket No. 2204] and continued to research possible connections between the Case 22-50073 Doc 2935 Filed 02/19/24 Entered 02/19/24 20:04:06 Page 27 of 779

Trustee and Paul Hastings, on the one hand, and parties in interest in these chapter 11 cases, on the other hand. In addition, Paul Hastings attorneys prepared (a) the Third Interim Fee Application [Docket No. 2256] (which the Court granted on November 30, 2023 [Docket No. 2408]), (b) Paul Hastings' monthly fee statements for services rendered in July, August, September, October, and November 2023, and (c) portions of this Application. Paul Hastings also corresponded and engaged in discussions with the U.S. Trustee to address questions regarding the above fee and expense reimbursement requests. Among other things, Paul Hastings consensually resolved the U.S. Trustee's informal comments to the Third Interim Fee Application and the September 2023 monthly fee statement. v. Fee / Employment Applications for Other Professionals (Task Code B165) Fees: \$86,756.00 Total Hours: 61.40

48. During the Fee Period, Paul Hastings attorneys interviewed potential candidates to serve as tax advisors and, upon the Trustee's selection of EA Group as tax advisors, assisted EA Group in the preparation of its application to be retained by the Trustee as tax advisors [Docket No. 2282] (which application was granted by order, dated December 7, 2023 [Docket No. 2424]). Paul Hastings attorneys also continued to assist Kroll with its application to be retained by the Trustee as forensic accountant [Docket No. 2162] (which application was granted by order, dated September 29, 2023 [Docket No. 2241]).

49. In addition, during the Fee Period, Paul Hastings attorneys handled various other fee-related issues, including (a) assisting Harney Westwood and Riegels LP ("Harney Legal"), Epiq Corporate Restructuring ("Epiq"), and Pallas Partner LLP ("Pallas") with their fee applications and (b) assisting various estate professionals with preparing their monthly fee statements in accordance with the Interim Compensation Procedures Order.

- vi. Business Operations (Task Code B210) Fees: \$23,687.00 Total Hours: 18.50 - 50. During the Fee Period, Paul Hastings attorneys assisted the Trustee with various

matters related to the operation of these chapter 11 estates, including handling wire transfers.

vii. Financial Reports (Monthly Operating Reports) (Task Code B211) Fees: \$21,377.50 Total Hours: 17.70

51. During the Fee Period, Paul Hastings attorneys prepared the monthly operating

reports in the Individual Debtor's chapter 11 case. In the interest of minimizing costs, the monthly operating reports for the Genever Debtors were prepared by NPM, and any time spent by Paul Hastings attorneys reviewing and commenting such reports was recorded under Matter ID 00010 (for Genever (US)) and 00011 (for Genever (BVI)).

- viii. Financing/Cash Collections (Task Code B230) Fees: \$13,844.00 Total Hours: 11.10 - 52. During the Fee Period, Paul Hastings attorneys continued to handle the Trustee

and the Genever Debtors' motion to approve interdebtor DIP financing [Docket No. 2110],

including resolving comments from counsel for the Sherry Netherland. On September 12, 2023,

the Court entered an order granting the motion [Docket No. 2193]. II. Asset Recovery Investigation and Litigation (Matter ID 00002)

i. Asset Analysis and Recovery (Task Code B120) Fees: \$26,876.00 Total Hours: 14.50

53. During the Fee Period, Paul Hastings attorneys analyzed various issues related to Ace Decade, including the transfer of Ace Decade shares by Yvette Wang to Rui Hao. In addition, the Trustee coordinated with his UK counsel, Pallas, to prepare a motion in the English courts to stay litigation previously commenced by the Individual Debtor, Ace Decade, and Dawn State Limited against UBS. Case 22-50073 Doc 2935 Filed 02/19/24 Entered 02/19/24 20:04:06 Page 29 of 779

- ii. Meetings of and Communications with Creditors (Task Code B150) Fees: \$11,696.00 Total Hours: 8.60 - 54. During the Fee Period, Paul Hasting attorneys prepared a presentation for the

Official Committee of Unsecured Creditors related to the overall case and litigation strategy.18

iii. Court Hearings (Task Code B155) Fees: \$11,417.50 Total Hours: 9.70

55. During the Fee Period, Paul Hastings attorneys prepared for numerous hearings and status conferences related to the Trustee's investigation and related litigation. As detailed below, attendance at these various hearings was recorded under the Matter ID for the applicable adversary proceeding.

iv. General Litigation (Task Code B191) Fees: \$600,824.00 Total Hours: 492.60

56. During the Fee Period, Paul Hastings attorneys worked on several litigation matters not related to a specific adversary proceeding, including (i) holding several internal calls to discuss general litigation strategy and next steps, (ii) maintaining a task list with respect to pending adversary proceedings, (iii) maintaining a tracking chart with respect to the pending appeals in these cases, and (iv) generally reviewing and analyzing pleadings filed in adversary proceedings.

57. In addition, although the task of trading the hundreds of avoidance action complaints was being handled by NPM, Paul Hastings also investigated certain potential fraudulent transfer and alter ego claims as well as developed a comprehensive strategy to pursue and/or preserve such claims, including conducting legal research into various issues related to equitably tolling the statutes of limitation. Of particular note, Paul Hastings prepared a motion (the "Tolling Motion") seeking to extend the deadlines set forth in sections 108, 546(a), and 549

18 The presentation was given on December 6, 2023 and recorded under Matter ID 00001, Task Code B150. Case 22-50073 Doc 2935 Filed 02/19/24 Entered 02/19/24 20:04:06 Page 30 of 779

of the Bankruptcy Code for the Trustee to commence actions to avoid and recover fraudulent transfers and/or assert other estate causes of action (which motion was filed on January 18, 2024). In connection with the Tolling Motion, Paul Hastings also prepared and filed (on January 8, 2024) a motion requesting approval of the form and manner of notice of the Tolling Motion, which request the Court granted by order dated January 19, 2024.

58. The Court ultimately granted the Tolling Motion in part by order dated February 14, 2024 [Docket No. 2837].

v. Investigations (Task Code B261) Fees: \$718,558.50 Total Hours: 606.00

59. During the Fee Period, Paul Hastings attorneys continued to handle the Trustee's extensive investigation to identify potential assets of the Individual Debtor's estate. Given the corporate maze of shell companies set up by the Individual Debtor, including hundreds of companies purportedly owned by his close family members, business associates, and employees, this investigation has necessarily been extensive and time intensive.

60. As part of this investigation, Paul Hastings attorneys (a) analyzed documents produced in response to Rule 2004 subpoenas,19 (b) engaged in meet and confer sessions with the targets of the Rule 2004 discovery, (c) identified additional entities for further investigation, (d) conducted numerous calls and meetings with the forensic accountant (Kroll) to advance the Trustee's investigation into potential estate claims, and (e) analyzed potential claims against the Individual Debtor and his affiliated entities. In addition, Paul Hastings attorneys prepared for

19 As further detailed below, in the interest of minimizing costs, Paul Hastings utilized UnitedLex Corporation ("UnitedLex") to conduct, among other things, first-round review of documents produced in the Trustee's investigation. UnitedLex specializes in discovery services, including document processing, storage, review services, and distribution. Case 22-50073 Doc 2935 Filed 02/19/24 Entered 02/19/24 20:04:06 Page 31 of 779

and deposed Defeng Cao, one the targets of the Trustee's investigation.20 During the Fee Period, Paul Hastings attorneys also negotiated a settlement with the Casper Firm, LLC for the return of \$48,750 from a retainer, which settlement was approved by the Court on November 7, 2023 [Docket No. 2310].

61. Paul Hastings attorneys also continued to assist NPM in preparing supplemental motions under Bankruptcy Rule 2004 seeking discovery from various individuals and entities associated with the Individual Debtor, including the seventh, eighth, ninth, and tenth supplemental motions filed on October 10, 2023 [Docket No. 2249], November 2, 2023 [Docket No. 2304], November 6, 2023 [Docket No. 2308],21 and December 14, 2023 [Docket No. 2434], respectively, as well as a reply brief filed on November 22, 2023 [Docket No. 2369] in response to the objections filed by G Club Operations [Docket Nos. 2320 and 2331] to the eighth and ninth supplemental Rule 2004 motion. The Court overruled these objections and granted the eighth and ninth supplemental Rule 2004 motion by orders dated November 29, 2023 [Docket Nos. 2393 and 2394]. The Court also granted the seventh and tenth supplemental Rule 2004 motions [Docket Nos. 2281 and 2474]. Furthermore, during the Fee Period, Paul Hastings attorneys continued to communicate with confidential informants, who provided valuable insight into the Individual Debtor's business operations.22

20 The Trustee ultimately commenced and adversary proceeding against Mr. Cao [Adv. Proc. No. 24-05001] seeking to recover certain motorcycles and vehicles that are equitably owned by the Individual Debtor.

21 The supplemental Rule 2004 motions were filed by NPM because Paul Hastings was conflicted as to some of the discovery targets. To the extent Paul Hastings did not have a conflict, it assisted NPM in preparing the supplemental motion.

22 In light of the Individual Debtor's well-documented social media campaign against the Trustee, Paul Hastings attorneys, and creditors in these chapter 11 cases, the time entries attached to this Application have been redacted to remove the names of these informants. Case 22-50073 Doc 2935 Filed 02/19/24 Entered 02/19/24 20:04:06 Page 32 of 779

62. As noted in Paul Hastings' prior fee applications, much of the Trustee's investigation also required the expertise of Paul Hastings' Mandarin-speaking attorneys in order to analyze thousands Mandarin-language documents (including WhatsApp, text messages, and videos). This work required not only Mandarin language skills but an understanding of the legal significance of these documents, which an outside translation service would not be able to provide. Paul Hastings' Mandarin-speaking attorneys were also critical for the Trustee to communicate with the numerous Mandarin-speaking informants that have reached out to the Trustee during the course of these chapter 11 cases.

63. To date, the Trustee's investigation (including as a result of discovery under Rule 2004, information provided by confidential informants, and corporate documents received from BVI registered agents) uncovered numerous assets that the Trustee believes are property of the Individual Debtor's estate, which the Trustee is seeking to recover for the benefit of the estate. In fact, as detailed further below, during the Fee Period, the Trustee continued to prosecute several adversary proceedings to recover such assets.

64. Unfortunately, as the Court is well aware, the Trustee's investigation continued to face vigorous opposition, at every turn, not only from the Individual Debtor, but also many of the targets of the Trustee's investigation (i.e., the Individual Debtor's close family members, business associates, and employees), necessitating significant motion practice to compel compliance (which compliance, to this day, remains forthcoming in many instances).

i. General Litigation (Task Code B191) Fees: \$418,143.50 Total Hours: 299.60

65. During the Fee Period, Paul Hastings attorneys assisted the Trustee on various litigation-related matters (other than the adversary proceedings pending in these chapter 11 Case 22-50073 Doc 2935 Filed 02/19/24 Entered 02/19/24 20:04:06 Page 33 of 779

cases), including the criminal case pending against the Individual Debtor in the United States District Court for the Southern District of New York [Case No. 1:23-cr-00118-AT] (the "Criminal Case"). Among other things, Paul Hastings monitored these criminal proceedings and reviewed pleadings filed in these proceedings.

66. Moreover, on August 30, 2023, the Individual Debtor filed a motion (joined by Yvette Wang) in the Criminal Case seeking to stay these chapter 11 cases, pending outcome of his criminal trial (the "Stay Motion"). In response, Paul Hastings prepared the Trustee's emergency motion, filed on September 1, 2023 [Docket No. 2160], seeking to enjoin the Individual Debtor's stay motion on the basis that such motion violated the automatic stay in these chapter 11 cases.23 Paul Hastings also prepared the Trustee's and the Genever Debtors' objection to the Stay Motion, which was filed in the Criminal Case on September 21, 2023. The U.S. District Court for the Southern District of New York denied the Stay Motion by order, dated December 21, 2023.

67. Furthermore, on December 6, 2023, counsel purportedly representing 3,345 customers of the Himalaya Exchange filed a motion (the "Himalaya Exchange Motion") in the Criminal Case seeking the return of property seized by the United States in connection with the Criminal Case. Paul Hastings attorneys prepared and filed the Trustee's response to the Himalaya Exchange Motion, opposing the relief sought on the basis that the seized funds allegedly belonging to customers of the Himalaya Exchange may, in fact, be property of the chapter 11 estate.

23 By order dated September 12, 2023 [Docket No. 2195], the Court denied the Trustee's related motion to expedite his emergency motion, noting that a hearing, if any, on the emergency motion would be scheduled after the district court presiding over the Criminal Case has acted on the Individual Debtor's stay motion.

68. During the Fee Period, Paul Hastings attorneys also prepared and filed numerous notices to apprise this Court and parties in interest of the developments in the Criminal Case.

i. Asset Disposition (Task Code B130) Fees: \$67,751.50 Total Hours: 44.30

69. During the Fee Period, Paul Hastings attorneys and the Trustee, in close

coordination with Edmiston, handled all aspects of the sale and marketing process for the Lady

May II, including negotiation of the purchase agreement, preparing the sale motion, and,

following the Court's approval of the sale, preparing for the closing of the sale (which occurred

on December 19, 2023).

- i. Tax Issues (Task Code B240) Fees: \$10,204.50 Total Hours: 7.40 - 70. During the Fee Period, Paul Hastings attorneys conducted initial meetings with

EA Group (the Trustee's tax advisors) regarding the preparation of tax filings for the Debtors.

i. Asset Disposition (Task Code B130) Fees: \$21,484.00 Total Hours: 19.20

71. During the Fee Period, Paul Hastings attorneys continued to analyze numerous issues related to the sale process for the Sherry Netherland Apartment. While the sale process was necessarily put on hold following the March 15, 2023 fire in order to assess the damage to the Sherry Netherland Apartment and evaluate the sale strategy going forward, Paul Hastings continued to analyze certain legal issues pertaining to an eventual sale of the apartment, including exploring a sale of the furniture located at the Sherry Netherland Apartment. ii. Other Contested Matters (Task Code B190) Fees: \$15,252.50 Total Hours: 11.90

72. During Fee Period, in connection with the remediation of the Sherry Netherland Apartment, Paul Hastings attorneys negotiated the alteration agreement with the Sherry Netherland and prepared the related motion requesting Court approval to enter into the alteration agreement [Docket No. 2313], which the court granted on December 1, 2023 [Docket No. 2417].

iii. Business Operations (Task Code B210) Fees: \$80,538.00 Total Hours: 60.20

73. During the Fee Period, Paul Hastings attorneys analyzed various operational matters with respect to Genever (US), including, most notably, as it relates to the remediation project for the Sherry Netherland Apartment. During the Fee Period, Paul Hastings attorneys also prepared Genever (US)'s motion to remediate the area of the Sherry Netherland Apartment affected by the March 15, 2023 fire (including preparing a supplement to the remediation motion, filed with the Court on September 8, 2023). 24 The Court granted the remediation motion by order dated September 19, 2023 [Docket No. 2213].

74. Following the approval of the remediation motion, Paul Hastings attorneys worked with Genever (US) architect (Dave Acheson) to develop a remediation strategy, including as it relates to asbestos abatement and the permitting process. Throughout the remediation process, Paul Hastings also closely coordinated with Dave Acheson regarding the selection of a general contractor to handle the remediation of the Sherry Netherland Apartment.

24 In the remediation motion, Genever (US) requested entry of an order (a) approving Genever (US)'s entry into, and performance under, into an agreement with Acheson Doyle, as architect, (b) authorizing Genever (US) to select and hire contractors, engineers, consultants, and other third-party service providers in the ordinary course of the remediation project (including as it relates to the removal of asbestos), as may be necessary to remediate the area affected by the fire, subject to certain procedures detailed in the motion, and (c) pay such contractors, engineers, consultants, and other third-party service providers in the ordinary course of the remediation project (including as it relates to the removal of asbestos).

Paul Hastings attorneys also prepared the monthly status reports and consulted with the consultation parties—all in accordance with the order granting the remediation motion.

i. Court Hearings (Task Code B155) Fees: \$27,087.50 Total Hours: 19.70

75. During the Fee Period, Paul Hastings attorneys attended numerous hearings

related to the Mahwah Adversary Proceeding (as defined below), including:

- the October 17, 2023 pre-trial conference; - the October 24, 2023 status conference; - the December 19, 2023 status conference on the Trustee's motion to preserve evidence at the Mahwah Mansion. - ii. General Litigation (Task Code B191) Fees: \$929,197.00 Total Hours: 765.20 - 76. During the Fee Period, Paul Hastings attorneys continued to prosecute the

Trustee's complaint against Scott Barnett (the Individual Debtor's driver and/or bodyguard), Taurus Fund, LLC, and Taurus Management LLC (the "Defendants") [Adv. Proc. No. 23-05017] (the "Mahwah Adversary Proceeding"). In the Mahwah Adversary Proceeding, the Trustee seeks determinations that, among other things, (a) the Debtor is the equitable owner of the 50,000 square foot Mahwah Mansion, (b) the Debtor is the equitable owner of Taurus Fund, LLC (the entity holding title to Mahwah Mansion), and (c) that Taurus Fund, LLC is an alter ego of the Individual Debtor.

77. During the Fee Period, Paul Hastings attorneys prepared several filings in the Mahwah Adversary Proceeding. Significantly, the Trustee became aware that the certain property connected to the Individual Debtor's Mahwah Mansion, and potentially connected to the Defendants, seemed to have disappeared from the Mahwah Mansion, in violation of the Case 22-50073 Doc 2935 Filed 02/19/24 Entered 02/19/24 20:04:06 Page 37 of 779

automatic stay. To address this issue, Paul Hastings attorneys prepared a detailed emergency motion for a status conference to discuss preservation of property of the estate, which conference was held on October 24, 2023, after which the Trustee and the Defendants prepared a joint report regarding a process for creating an inventory of personalty and fixtures in or on the Mahwah Mansion to ensure no further removal of potential property of the Individual Debtor's estate.

78. Additionally, during the Fee Period, Paul Hastings attorneys handled discovery in the Mahwah Adversary Proceeding, including preparing initial disclosures in connection with the Mahwah Adversary Proceeding, corresponding with opposing counsel regarding a discovery schedule, and, on October 25, 2023, filing with the Court a proposed pre-trial order proposing a schedule with regard to fact discovery, expert reports and depositions, and setting deadlines for summary judgment and a trial.

79. During the Fee Period, Paul Hastings attorneys also handled all aspects of discovery with respect to the Mahwah Adversary Proceeding, including preparing subpoenas and discovery requests of the Defendants, as well as dozens of third parties with whom the Individual Debtor and his associates, including the Defendants, conducted business with or otherwise interacted with in connection with the Mahwah Mansion. Such parties included the party who sold the mansion to the Individual Debtor, real estate brokers, attorneys, and other parties that assisted in connection with the sale, designers and construction firms who worked on the Mahwah Mansion after the Individual Debtor purchased it, and antique and furniture vendors who sold the Individual Debtor property for the mansion.

80. Paul Hastings attorneys corresponded and held discussions facilitating these parties' production, as well as reviewed the documents eventually produced. Paul Hastings attorneys also prepared for several depositions of third parties connected to the Mahwah Case 22-50073 Doc 2935 Filed 02/19/24 Entered 02/19/24 20:04:06 Page 38 of 779

Mansion who the Trustee understood would provide testimony tying the Individual Debtor to the Mahwah Mansion. All the while, Paul Hastings handled additional matters related to the discovery, including preparing responses to the Defendants' document requests, interrogatories, and requests for admission.

81. Additionally, during the Fee Period, the Trustee became aware of evidence relating to the Mahwah Adversary Proceeding, including the existence of a storage facility (the "Storage Facility") that the Trustee believed may contain evidence related to the Mahwah Mansion and/or potential property of the estate. To address the issue, on December 18, 2023, Paul Hastings attorneys prepared an emergency motion for the preservation of evidence requesting an order restricting access to the Storage Facility and ordering that the Defendants not modify, remove, empty, dispose of transfer, destroy, or in any way impair any contents at the Storage Facility. After various conferences and a hearing relating to the motion were held, on December 21, 2023, the Court issued an order (consented to in part) [Docket No. 93 in Adv. Proc. No. 23-05017] which largely granted the motion and restricted access to the Storage Facility to certain parties, including the Trustee and Paul Hastings attorneys, who later conducted an inventory of the contents of the Storage Facility.

82. As discovery continued in the Mahwah Adversary Proceeding, it became clear to the Trustee that—due to the sheer number of third parties who had conducted business or otherwise interacted with the Individual Debtor and his associates in connection with the Mahwah Mansion—additional time was needed for fact discovery and depositions. Therefore, on December 28, 2023, the Trustee filed a consent motion to modify the pretrial order and extend certain deadlines in the Mahwah Adversary Proceeding, including the fact discovery deadline. iii. Non-Working Travel (Task Code B195) [billed at ½ rate] Fees: \$5,720.75 Total Hours: 9.40

83. During the Fee Period, Paul Hastings attorneys traveled to (a) the Mahwah

Mansion for site visits (on September 1, 2023 and October 30, 2023) and (b) the storage facility in New Jersey for inspection (December 22, 2023 and December 28, 2023). VIII. Golden Spring Adversary Proceeding (Matter ID 00013)

i. General Litigation (Task Code B191) Fees: \$32,958.50 Total Hours: 26.00

84. During the Fee Period, Paul Hastings attorneys continued to prosecute the Trustee's complaint against Golden Spring and China Golden Spring (the "Golden Spring Entities") [Adv. Proc. No. 23-05018] (the "Golden Spring Adversary Proceeding"). In the Golden Spring Adversary Proceeding, the Trustee seeks determinations that, among other things, (a) Golden Spring is the alter ego of the Individual Debtor and (b) the Individual Debtor is the equitable owner of Golden Spring and/or its assets (notwithstanding China Golden Spring's purported ownership interest in Golden Spring).

85. During the Fee Period, Paul Hastings attorneys prepared and filed the Trustee's requests for entry of a default against each of the Golden Spring Entities. On September 12, 2023, the Trustee requested entry of a default as against Golden Spring. The Court entered a default against Golden Spring by order dated September 20, 2023 [Docket No. 17 in Adv. Proc. No. 23-05018]. On October 11, 2023, the Trustee requested entry of a default as against China Golden Spring. The Court entered a default against China Golden Spring by order dated October 17, 2023 [Docket No. 20 in Adv. Proc. No. 23-05018].

86. Furthermore, during the Fee Period, Paul Hastings attorneys, together with the Trustee's local counsel NPM, prepared the Trustee's motion for entry of a default judgment against the Golden Spring Entities (the "Default Judgment Motion"), which (i) detailed the Case 22-50073 Doc 2935 Filed 02/19/24 Entered 02/19/24 20:04:06 Page 40 of 779

merits of Trustee's claims against the Golden Spring Entities, and (ii) summarized the sufficiency Trustee's service on the Golden Spring Entities, and the Golden Spring Entities failure to respond and subsequent default. On October 27, 2023, the Trustee filed the Default Judgment Motion.

87. On November 28, 2023, the Court held a hearing on the Default Judgment Motion, after which Paul Hastings attorneys prepared, together with the Trustee's local counsel NPM, a revised proposed order on the Default Judgment Motion. The Court granted the Default Judgment Motion by order dated December 4, 2023 [Docket No. 35 in Adv. Proc. No. 23- 05018].

- i. Court Hearings (Task Code B155) Fees: \$114,275.00 Total Hours: 80.40 - 88. During the Fee Period, Paul Hastings attorneys attended numerous hearings

related to the HCHK Adversary Proceeding (as defined below), including:

- the September 6, 2023 hearings on the HCHK Entities' motion to extend time to respond to the Trustee's complaint; - the October 3, 2023 status conference; - the October 24, 2023 hearing on the Trustee's motion seeking approval of the settlement with the Assignee of the HCHK Entities; and - the November 29, 2023 hearing on the motion Shih Hsin Yu, 1332156 B.C. Ltd, and GWGOPNZ Limited (the "Proposed Intervenors")25 to intervene in the HCHK Adversary Proceeding.

25 Initially, at the time of the filing of their intervention motion, the Proposed Intervenors also included Japan Himalaya League, Inc., which subsequently withdrew from the motion. ii. General Litigation (Task Code B191) Fees: \$1,752,304.50 Total Hours: 1378.50

89. During the Fee Period, Paul Hastings attorneys continued to prosecute the Trustee's complaint against the HCHK Entities, the Assignee, Holy City Hong Kong Ventures, Ltd., Yvette Wang, and Anthony DiBattista [Adv. Proc. No. 23-05013] (the "HCHK Adversary Proceeding"). In the HCHK Adversary Proceeding, the Trustee seeks determinations that, among other things, (a) the HCHK Entities are alter egos of the Individual Debtor and (b) the Individual Debtor is the equitable owner of the HCHK Entities and/or their assets. In addition, the complaint sought an injunction against the commencement or continuation of the assignment proceedings commenced with respect to the HCHK Entities in New York state court (the "Assignment Proceedings"). In connection with the HCHK Adversary Proceeding, the Trustee also requested and obtained a temporary restraining order (the "HCHK TRO") as it relates to the commencement or continuation of the Assignment Proceeding. See Docket No. 18 in Adv. Proc. No. 23-05013.

90. During the Fee Period, Paul Hastings attorneys prosecuted the Trustee's opposition to the Proposed Intervenors' motion to intervene [Docket No. 60 in Adv. Proc. No. 23-05013] (the "Intervention Motion") and motion to clarify the HCHK TRO [Docket No. 65 in Adv. Proc. No. 23-05013] (the "TRO Modification Motion"). Among other things, Paul Hastings attorneys prepared the Trustee's objections to the Motion to Intervene and TRO Modification Motion [Docket Nos. 118 and 119 in Adv. Proc. No. 23-05013]. Paul Hastings attorneys also handled the Trustee's discovery efforts with respect to the Proposed Intervenors' motions, including deposing the Proposed Intervenor Shih Hsin Yu and corporate representatives of Proposed Intervenors 1332156 B.C. Ltd, and GWGOPNZ Limited. Finally, Paul Hastings attorneys handled the evidentiary hearing on the Intervention Motion and the TRO Modification Case 22-50073 Doc 2935 Filed 02/19/24 Entered 02/19/24 20:04:06 Page 42 of 779

Motion. On January 5, 2024, the Court entered an order [Docket No. 239 in Adv. Proc. No. 23- 05013] denying both motions.

91. Furthermore, prior to the commencement of the Fee Period, after G Club Operations had sought to prevent the turnover of portions of HCHK Technologies, Inc.'s ("HCHK Technologies") corporate documents under the Trustee's settlement with the Assignee, Paul Hastings attorneys prepared the Trustee's memorandum of law [Docket No. 86 in Adv. Proc. No. 23-05013] detailing why G Club Operations should not be permitted to prevent the turnover of such corporate records to the Trustee. During the Fee Period, Paul Hastings continued to seek the turnover of these key documents, and represented the Trustee at the October 24, 2023 hearing with respect to same. As a result of these efforts, on November 13, 2023, the Court entered an order [Docket No. 179 in Adv. Proc. No. 23-05013] requiring that such documents be turned over to the Trustee.26

92. In addition, during the Fee Period, on September 29, 2023, the Court entered a default [Docket No. 139 in Adv. Proc. No. 23-05013] against defendants HCHK Technologies, Inc., HCHK Property Management, Inc., Lexington Property and Staffing, Inc., and Holy City Hong Kong Ventures, Ltd. Subsequently, these defendants filed a motion to set aside the default, which the Trustee opposed. Among other things, Paul Hastings attorneys prepared the Trustee's objection to that motion [Docket No. 224 in Adv. Proc. No. 23-05013] and represented the Trustee at the January 9, 2023 hearing on that motion.

26 G Club Operations has appealed such order to the United States District Court for the District of Connecticut.

- iii. Non-Working Travel (Task Code B195) [billed at ½ rate] Fees: \$9,105.00 Total Hours: 12.60 - 93. During the Fee Period, Paul Hastings attorneys traveled to and from the Federal

Courthouse in Bridgeport, Connecticut, for the November 29 hearing on the Proposed

Intervenors' motion to intervene in the HCHK Adversary Proceeding.

iv. Business Operations (Task Code B210) Fees: \$31,814.50 Total Hours: 29.90

94. During the Fee Period, Paul Hastings attorneys Paul Hastings attorneys worked with the Assignee's counsel to handle administrative matters undertaken pursuant to the Assignee Settlement. These tasks included, among other things, reviewing the Assignee's business records, filing expense reports required to be filed under the Assignee Settlement, and handling payments to employees and service providers of the HCHK Entities.

- i. General Litigation (Task Code B191) Fees: \$242,777.00 Total Hours: 155.80

95. During the Fee Period, Paul Hastings attorneys continued to assist NPM in prosecuting the Trustee's complaint against Mei Guo [Adv. Proc. No. 22-05008] (the "Mei Guo Adversary Proceeding"). In the Mei Guo Adversary Proceeding, the Trustee seeks (a) an order declaring that the proceeds (the "Bombardier Proceeds") from the sale of the Individual Debtor's private Bombardier jet (the "Bombardier") are property of the estate, (b) an order that Mei Guo surrender the Bombardier Proceeds or the value thereof to the Trustee because she received the Bombardier Proceeds as an unauthorized postpetition transfer avoidable under section 549 of the Bankruptcy Code, (c) an order that Mei Guo surrender to the Trustee the value of the Individual Debtor's shell company Anton Development Limited ("Anton Development") at the time the company was transferred to her on June 27, 2017 (upon which date Anton Development was title Case 22-50073 Doc 2935 Filed 02/19/24 Entered 02/19/24 20:04:06 Page 44 of 779

holder to the Bombardier) pursuant to a transaction avoidable as an actual fraudulent transfer, and (d) an order declaring that a series of BVI registered shell companies purportedly held by Mei Guo are property of the Individual Debtor's chapter 11 estate.

96. During the Fee Period, Paul Hastings attorneys assisted NPM in various discovery matters in the Mei Guo Adversary Proceeding, including preparing a motion to compel Mei Guo to appear for a deposition27 and a motion to compel Anton Development, Whitecroft Shore Limited ("Whitecroft"), and Mei Guo to comply with the Trustee's subpoenas (which motion was granted by order, dated November 30, 2023 [Docket No. 63 in Adv. Proc. No. 22-05008]). During the Fee Period, Paul Hastings attorneys also assisted NPM in preparing for the deposition of Mei Guo in connection with the Mei Guo Adversary Proceeding.

97. In addition, Paul Hastings attorneys assisted NPM in preparing the Trustee's emergency motion [Docket No. 74 in Adv. Proc. No. 22-05008] for a temporary restraining order to ensure that Mei Guo (and those acting in concert with her) preserve the Bombardier Proceeds pending the resolution of the Mei Guo Adversary Proceeding. This emergency motion was consensually resolved by order, dated December 21, 2023 [Docket No. 81 in Adv. Proc. 22- 05008], pursuant to which Mei Guo agreed to cause the Bombardier Proceeds and certain other property to be transferred to an escrow agent acceptable to the Trustee.

98. Finally, during the Fee Period, Paul Hastings attorneys assisted NPM in preparing the Trustee's motion for summary judgment in this adversary proceeding, which was filed on December 28, 2023 [Docket No. 88 in Adv. Proc. No. 22-05008]. As detailed in the summary judgment motion, the Trustee submitted that the evidence shows that: (a) the Individual Debtor

27 The Trustee's motion to compel was mooted as a result of the parties reaching consensual pre-trial order, including an extension to complete fact discovery until November 10, 2023. Case 22-50073 Doc 2935 Filed 02/19/24 Entered 02/19/24 20:04:06 Page 45 of 779

has always been the beneficial owner of the Bombardier and he retained such beneficial ownership throughout all of the foregoing transfers up through the Bombardier's sale in October 2022, since which time, the Debtor has always been the beneficial owner of the Bombardier Proceeds; and (b) the Individual Debtor is the beneficial owner of Whitecroft, the entity that held title to the Bombardier at the time of its sale.

i. General Litigation (Task Code B191) Fees: \$90,180.00 Total Hours: 85.20

99. During the Fee Period, Paul Hastings attorneys continued to handle all matters arising out of HK USA and Mei Guo's appeal of this Court's rulings in connection with the Trustee's counterclaims against HK USA and Mei Guo [Adv. Proc. No. 22-05003] (the "HK USA Adversary Proceeding"). In the HK USA Adversary Proceeding, this Court determined that, among other things, (a) the Lady May and the Lady May II are property of the Individual Debtor's estate, (b) HK USA is an alter ego of the Individual Debtor, and (c) the \$33 million held in escrow by U.S. Bank are property of the estate [Docket Nos. 172 and 221 in Adv. Proc. No. 22-05003].

100. HK USA and Mei Guo appealed these ruling to the District Court as well as sought a stay pending appeal. In connection with this appeal, Paul Hastings attorneys prepared the Trustee's appellee brief (which was filed on September 6, 2023) as well as analyzed the reply brief filed by appellants. XII. Greenwich Land Adversary (Matter ID 00020)

i. General Litigation (Task Code B191) Fees: \$914,970.00 Total Hours: 715.30

101. During the Fee Period, Paul Hastings attorneys continued to prosecute the Trustee's complaint against Greenwich Land and Hing Chi Ngok [Adv. Proc. No. 23-05005] (the Case 22-50073 Doc 2935 Filed 02/19/24 Entered 02/19/24 20:04:06 Page 46 of 779

"Greenwich Land Adversary Proceeding"). In the Greenwich Land Adversary Proceeding, the Trustee seeks determinations that, among other things, (a) Greenwich Land is an alter ego of the Individual Debtor and (b) the Individual Debtor is the equitable owner of Greenwich Land. Paul Hastings' efforts thus far have resulted in critical prejudgment remedies and injunctive relief to protect the assets of Greenwich Land, including the Individual Debtor's mansion on Taconic Road in Greenwich, Connecticut, pending the outcome of the Greenwich Land Adversary Proceeding, for the benefit of the estate.

102. During the Fee Period, Paul Hastings attorneys prepared several filings in the Greenwich Land Adversary Proceeding, including, most notably, the Trustee's summary judgment motion and reply in support thereof [Docket Nos. 77 and 111 in Adv. Proc. No. 23- 05005], as well as related documents, such as the statement of material facts in support of the summary judgment motion [Docket No. 79 in Adv. Proc. No. 23-05005]. Oral argument on the summary judgment motion was held on January 9, 2024, shortly after the end of the Fee Period. Among other things, the Trustee submits that summary judgment is appropriate here because the defendants have no knowledge of the management or operations of Greenwich Land, nor do they have any basis to dispute the substantial evidence that the Debtor is, and always has been, the one who truly owns and controls Greenwich Land.

103. During the Fee Period, Paul Hastings also continued to handle all matters related to discovery in the Greenwich Land Adversary Proceeding, including deposing Hing Chi Ngok on September 11, 2023, Margaret Conboy (counsel to Greenwich Land) on September 12, 2023, and Mei Guo on September 13, 2023. Paul Hastings also assisted the Trustee's efforts to protect potential estate assets located at the Debtor's mansion on Taconic Road (the "Taconic Property"), among other things, by preparing the Trustee's motion for a video tour of the

Taconic Property [Docket No. 98 in Adv. Proc. No. 23-05005], as well as handling related matters and Court hearings.

ii. Non-working Travel (Task Code B195) [billed at ½ rate] Fees: \$3,204.25 Total Hours: 5.20

104. During the Fee Period, Paul Hastings attorneys traveled to the office of Hing Chi Ngok's counsel in Stamford, Connecticut, for her September 11, 2023 deposition. XIII. Lamp Capital Adversary (Matter ID 00024)

i. General Litigation (Task Code B191) Fees: \$111,702.50 Total Hours: 105.00

105. During the Fee Period, Paul Hastings attorneys prepared and filed the Trustee's complaint against Lamp Capital LLC and certain other defendants [Adv. Proc. No. 23-05023] (the "Lamp Capital Adversary Proceeding"). In the Lamp Capital Adversary Proceeding, the Trustee seeks determinations that, among other things, Lamp Capital LLC ("Lamp Capital"), Hudson Diamond NY LLC ("Hudson Diamond NY"), and Leading Shine NY Ltd. ("Leading Shine NY" and, together with Lamp Capital and Hudson Diamond NY, the "Alter Ego Defendants") are the Individual Debtor's alter egos and that the Individual Debtor equitably owns the Alter Ego Defendants and their assets.

106. In addition to preparing the complaint, Paul Hastings attorneys prepared and filed the Trustee's requests for entry of a default against Defendants Lamp Capital, Infinity Treasury Management Inc., Leading Shine NY, and Yvette Wang. The Court entered a default against these defendants on December 14, 2023 [Docket No. 13 in Adv. Proc. No. 23-05023].

107. Furthermore, during the Fee Period, Paul Hastings attorneys, together with the Trustee's local counsel NPM, prepared and filed the Trustee's motion for entry of a default judgment against Defendants Lamp Capital and Infinity Treasury Management, Inc. The Court granted the motion by order dated February 1, 2024 [Docket No. 63 in Adv. Proc. 23-05023].

i. Investigations (Task Code B261) Fees: \$183,388.50 Total Hours: 145.20

108. During the Fee Period, Paul Hastings attorneys assisted the Trustee in investigating and preparing a complaint to recover damages suffered by the Individual Debtor's creditors as a result of an extensive, years' long racketeering conspiracy involving multiple fraudulent schemes facilitated by various associates of the Individual Debtor in violation of the Racketeer Influenced and Corrupt Organization Act of 1970 ("RICO").

109. As detailed in the complaint (which was filed on February 15, 2024) [Docket No. 1 in Adv. Proc. 24-05273], since at least 2015, the Debtor and various of his associates have operated a racketeering enterprise through an extensive worldwide network of shell companies with the goal of enriching the Individual Debtor, his family members, and his close associates, while concealing the true nature and extent of the Individual Debtor's wealth from his creditors and preventing them from being repaid. As a result, the Individual Debtor and those close to him have enjoyed all the trappings and luxury of a billionaire's lifestyle—from private jets, to luxury super yachts, to \$10,000 suits, to multiple palatial residences, and much, much more—while the Individual Debtor's creditors, who over the years have amassed hundreds of millions of dollars in claims against him, have been left with nothing.

110. During the Fee Period, Paul Hastings attorneys investigated potential RICO claims, prepared related memoranda of law, and analyzed various related legal issues (including the application of statutes of limitation and standing to assert RICO claims). XV. Ace Decade Adversary Proceeding (Matter ID 00026)

i. General Litigation (Task Code B191) Fees: \$30,017.50 Total Hours: 18.60

111. During the Fee Period, Paul Hastings attorneys prepared and filed the Trustee's complaint against Ace Decade, Yvette Wang, and Rui Hao seeking a declaration that the transfer of the Ace Decade shares by Yvette Wang to Rui Hao is void in light of this Court's prior ruling that the Trustee beneficially owns the Ace Decade shares.

112. 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).28

113. 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

28 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).

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).

114. 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., 29 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), 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.30 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,

29 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.

30 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).

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").

115. In accordance with the factors enumerated in section 330 of the Bankruptcy Code

and applicable case law, the amount requested herein by Paul Hastings is fair and reasonable, as

set forth below and otherwise in this Application.

Paul Hastings billed a total of \$6,911,034.50 and 5,637.40 hours, respectively, of professional and paraprofessional services during the Fee Period. As evidenced by this Application, Paul Hastings professionals and paraprofessionals worked diligently and efficiently without unnecessary duplication of efforts throughout the Fee Period. A small group of the same Paul Hastings attorneys was utilized for the vast majority of the work in order to minimize the costs of intra-Paul Hastings communication and education about the Debtors' circumstances. Whenever possible, Paul Hastings sought to minimize the cost of Paul Hastings' services by utilizing talented junior attorneys and paraprofessionals to handle the more routine aspects of the assignments. The services were performed in an effective and efficient manner commensurate with the complexity, exigency, and importance of the issues involved. In addition, Paul Hastings' representation has required it to balance the need to provide quality services with the need to act quickly and represent the Trustee and the Genever Debtors in an effective, efficient, and timely manner. Paul Hastings submits that the hours spent were reasonable given the size and complexity of these chapter 11 cases, the significant, and often urgent, legal and business issues raised, and the numerous pleadings filed in the chapter 11 cases. Furthermore, as noted detailed above, the Trustee and the Genever Debtors also retained NPM as local and conflicts counsel in order to provide services to the Trustee and the Genever Debtors in a costeffective manner. Paul Hastings and NPM have coordinated and will continue to coordinate each firm's respective responsibilities in connection with the representation of the Trustee and the Genever Debtors. b. Novelty and Difficulty of the Questions

Paul Hastings tasked knowledgeable attorneys to research, analyze, and advise the Trustee and the Genever Debtors on difficult and complex issues during the Fee Period, including issues related to bankruptcy and litigation. Most notably, as detailed in this Application, Paul Hastings investigated complex estate claims and causes of action in order to recover assets of these estates. c. Skill Requisite to Perform the Legal Services Properly

Paul Hastings believes that its recognized expertise in the areas of financial restructuring and corporate reorganization, its ability to draw from highly experienced professionals in other areas of Paul Hastings' practice, and its creative approach to the resolution of issues has contributed to the effective administration of these chapter 11 cases and benefited the Trustee, the Genever Debtors, their estates, and their unsecured creditors. Due to the nature and complexity of the legal issues presented by these chapter 11 cases, Paul Hastings was required to exhibit a high degree of legal skill in areas related to, among others, bankruptcy and litigation. d. Preclusion of Other Employment by Applicant Due to Acceptance of the Case

Due to the size of Paul Hastings' restructuring and litigation departments, Paul Hastings' representation of the Trustee and the Genever Debtors did not preclude its acceptance of new clients, but the demands for immediate and substantive action in these chapter 11 cases imposed significant burdens on Paul Hastings professionals and paraprofessionals working concurrently on other matters. That said, for the Trustee, his engagement as a chapter 11 trustee has, for all practical purposes precluded other employment given that this matter is taking up most of his time and there frequently are two hearings per week.

Other than the hourly rate for Luc A. Despins, the fees charged by Paul Hastings in these chapter 11 cases are billed in accordance with its existing billing rates and procedures in effect during the Fee Period. The rates Paul Hastings charges for the services rendered by its professionals and paraprofessionals in these chapter 11 cases are comparable to the rates Paul Hastings charges for professional and paraprofessional services rendered in comparable nonbankruptcy related matters. Moreover, when Paul Hastings' restructuring professionals and paraprofessionals work on nonbankruptcy matters, the firm generally charges their standard rate. Such fees are reasonable based on the customary compensation charged by comparably skilled practitioners in comparable nonbankruptcy cases in a competitive national legal market. In addition, the firm's customary hourly rates and rate structure reflect that restructuring and related matters typically involve great complexity, numerous tasks requiring a high level of expertise, and severe time pressures, as is the case here. f. Whether the Fee Is Fixed or Contingent

Pursuant to Bankruptcy Code sections 330 and 331, all fees sought by professionals employed under Bankruptcy Code section 1103 are subject to final approval by the Court, and are subject to adjustment depending on the services rendered and the results obtained. Of particular note, payment of Paul Hastings' fees here was contingent in two respects: (1) the recovery of assets for the benefit of the estates and (2) monetizing such assets. At the outset of these chapter 11 cases, there was no assurance whatsoever that assets would be recovered and monetized to allow for the payment of estate professionals. Accordingly, Paul

Hastings' compensation was, in essence, a contingency fee arrangement. The risk that Paul Hastings assumed by representing the Trustee and the Genever Debtors further supports the reasonableness of Paul Hastings' compensation. g. Time Limitations Imposed by the Client or Other Circumstances

During the Fee Period, Paul Hastings was required to analyze and address certain issues arising in these chapter 11 cases under compressed timelines. For example, given the Individual Debtor's track record of moving assets to keep them out of reach of creditors, it was critical that Paul Hastings act quickly on information obtained during the Trustee's investigation in order to freeze assets.

Paul Hastings professionals and paraprofessionals worked diligently to maximize value for these chapter 11 estates. During the Fee Period, and as described in the summary of services herein, Paul Hastings was instrumental in analyzing potential sources of recovery for the benefit of these estates. During the Fee Period, Paul Hastings was able to secure several key rulings from the Court, which rulings will serve as a beachhead for future asset recovery efforts. The reasonableness of Paul Hastings' fees must be evaluated in light of this important strategic factor. i. Experience, Reputation, and Ability of Attorneys

Paul Hastings is consistently recognized as a top tier law firm in the field of business reorganizations and liquidations under chapter 11. During the Application Period, Paul Hastings solicited the skill and expertise of its professionals and paraprofessionals. Paul Hastings professionals have actively represented debtors, creditors, and creditors' committees, as well as other parties in interest, in a number of the nation's largest chapter 11 cases as well as in connection with cross-border restructurings. Paul Hastings' extensive experience enables it to perform the services described herein competently and expeditiously. In addition to its expertise in the area of corporate reorganization, Paul Hastings has called upon the expertise of its attorneys in other practice areas as required during the Fee Period.

As detailed in this Application, the Individual Debtor's in-court and out-of-court tactics illustrate the undesirability of this engagement, which involved harassment of the Trustee and Paul Hastings attorneys (including death threats against the Trustee). As a result, Paul Hastings was forced to incur hundreds of thousands of dollars in cyber security measures (the cost of which are not part of the expenses for which Paul Hastings is seeking reimbursement in this Application). In addition, prior to the Court granting the First Interim Fee Application at the end of June 2023, Paul Hastings was unable to get paid for its fees for almost a year. k. Nature and Length of Professional Relationship

Paul Hastings has been rendering professional services to (a) the Trustee since its retention as counsel effective as of July 8, 2022, (b) Genever (BVI) since its Case 22-50073 Doc 2935 Filed 02/19/24 Entered 02/19/24 20:04:06 Page 54 of 779

retention as counsel effective as of October 11, 2022, and (c) Genever (US) since its retention as counsel effective as of November 3, 2022.

116. Paul Hastings respectfully submits that the services for which it seeks

compensation in this Fee Application were, at the time rendered, necessary for and beneficial to the Debtors' estates and their creditors and were rendered to maximize, protect, and preserve value for the Debtors' estates and all parties in interest. Paul Hastings believes that it provided services economically, effectively, and efficiently, and obtained results beneficial to the Debtor's estate and his creditors. Paul Hastings further submit that the compensation requested herein is reasonable in light of the nature, extent, and value of the services rendered during the Fee Period.

117. Paul Hastings also notes that the rates charged during the Fee Period are reasonable. In fact, this Court held that Paul Hastings' New York rates are reasonable because Paul Hastings was retained at New York rates and these cases are extraordinary within this District. See Order Denying Motion for Stay Pending Appeal [Docket No. 1791].

118. All fees incurred by Paul Hastings during the Fee Period were actual, reasonable, and necessary in the performance of services for the Trustee and the Genever Debtors. Paul Hastings respectfully requests approval of the compensation sought herein.

119. As set forth in Exhibit C hereto, Paul Hastings incurred and disbursed \$718,236.31 as expenses in providing professional services during the Fee Period. These expenses include approximately \$38,443.86 for online legal research (i.e., LEXIS and Westlaw). Because Paul Hastings believes that online legal research (e.g., LEXIS and Westlaw) is far more cost-efficient than manual research using hard-bound volumes, Paul Hastings encourages computerized legal research even though it is not a profit center for Paul Hastings. To be clear, Paul Hastings does not charge a mark-up on the LEXIS and Westlaw charges, but merely passes

on the costs of such third-party services. Moreover, as it relates to outside professional services,

mailing, and other service-related expenses, the Trustee and Paul Hastings are merely passing on

the costs of such third-party services, without any mark-up.31

- 120. Additional necessary expenses included: - \$580,379.93 for certain outside professional services, such as document review services by UnitedLex (\$561,761.91) and translation services by Divergent Language Solutions (\$11,353.50); - \$49,720.24 for court reporting services; - \$15,092.20 for process servers (e.g., Metro Attorney Service Inc.) to serve, among other things, the subpoenas issued pursuant to the Rule 2004 orders entered by this Court; - \$14,248.52 for document reproductions, namely \$10,905.12 for b/w reproductions (at 8 cents per page) and \$3,343.40 for color reproductions (at 20 cents per page); - \$5,002.76 for UPS/courier service, including service of pleadings required to be served in hard copy format; and - \$278.95 for corporate document retrieval services (including United Corporate Service and Corp2000) with respect to various Kwok-related entities.

121. During the Fee Period, Paul Hastings utilized UnitedLex -- a third party vendor that specializes in discovery services including document processing, storage, review services, and distribution -- to conduct document review of the documents produced in the chapter 11 cases, including the hundreds of thousands of discovery documents received by the Trustee to date in connection with his investigation.

122. Using their own contract attorneys and review team managers, UnitedLex

provides an efficient and economic means of reviewing large document sets at hourly rates

significantly lower than Paul Hastings. UnitedLex's document review team charges hourly rates

31 Documentation of these expenses will be made available to the Court upon request. Case 22-50073 Doc 2935 Filed 02/19/24 Entered 02/19/24 20:04:06 Page 56 of 779

ranging from \$40 to \$55 (for non-management roles) and \$150 (for management role), which is substantially less than Paul Hastings' hourly rates and, moreover, is even less than the hourly rates of associates of local Connecticut counsel (i.e., NPM), whose hourly rates range from \$200 to \$400. For all these reasons, Paul Hastings believes that utilizing the UnitedLex document review team greatly benefits these estates by reducing document review costs. The Trustee also previewed Paul Hastings' use of UnitedLex with the U.S. Trustee, who had no objection thereto (without the Trustee having to file a separate retention application for UnitedLex). The Trustee and Paul Hastings also disclosed in the Fourth Supplemental Declaration of Disinterestedness of Luc A. Despins [Docket No. 1435] that Paul Hastings would utilize UnitedLex's contract attorneys services.

123. The time constraints imposed by the circumstances of the matters handled by Paul Hastings during the Fee Period required its attorneys and other employees, at times, to devote substantial time during the evenings and on weekends to perform legal services on behalf of the Trustee. These extraordinary services were essential to meet deadlines, timely respond to inquiries on a daily basis, and satisfy the Trustee's needs and demands. Attorneys and other Paul Hastings employees who worked late in the evenings or on weekends were reimbursed for their reasonable meal and transportation costs in accordance with firm policy. Paul Hastings' regular practice is not to include components for those charges in overhead when establishing billing rates, but rather to charge its clients for these and all other out-of-pocket disbursements incurred during the regular course of the provision of legal services. Case 22-50073 Doc 2935 Filed 02/19/24 Entered 02/19/24 20:04:06 Page 57 of 779

124. In accordance with Appendix D (Guidelines for Compensation and Expense Reimbursement of Professionals) to the Local Rules, reproduction charges have been capped at 20 cents per page.32

125. The expenses requested herein are customarily charged to non-bankruptcy clients of Paul Hastings. Additionally, the expenses incurred by Paul Hastings to third parties are limited to the actual amounts billed to, or paid by, Paul Hastings on behalf of the estates.

126. Paul Hastings believes the rates for charges incurred are the market rates that the majority of law firms charge clients for such services. In addition, Paul Hastings believes that such charges are in accordance with the American Bar Association's ("ABA") guidelines, as set forth in the ABA's Statement of Principles, dated January 12, 1995, regarding billing for disbursements and other charges.

127. The expenses incurred in providing professional services in the Chapter 11 Case were necessary, economical, and justified under the circumstances.

128. Paul Hastings responds to the questions set forth in Paragraph C.5. of the

U.S. Trustee Guidelines as follows:

Question: Did you agree to any variations from, or alternatives to, your standard or customary billing rates, fees, or terms for services pertaining to this engagement that were provided during the Fee Period?

Response: Yes. As a courtesy to these estates and based on

Period, Paul Hastings agreed to voluntary fee reductions aggregating \$38,758.00, including the following:

32 Generally, Paul Hastings charges 8 cents per page for black-and-white reproductions and 50 cents per page for color reproductions. In accordance with Appendix D to the Local Rules, Paul Hastings has reduced the charge for color reproductions to 20 cents per page.

Paul Hastings is not seeking allowance or payment at

hours during the Fee Period. The total amount of such fees is \$20,287.00. The time billed by these timekeepers was reasonable, and Paul Hastings reserves the right to seek allowance of these fees based on the facts and circumstances of these cases, including, without limitation, if objections are interposed to the allowance of Paul Hastings'

expenses.

As a result of the agreed-upon reduction in Luc A.

hourly rate (from his standard hourly rate of

to the reduced hourly rate of \$1,975.00), an

in fees have been waived. Question: If the fees sought in this application as compared to the fees budgeted for the Fee Period are higher by

you discuss the reasons for the variation with the client. Response: Not applicable. Question: Have any of the professionals included in this application varied their hourly rate based on the geographic location of the bankruptcy case? Response: No. Question: Does the application include time or fees related to reviewing or revising time records or preparing, reviewing, or revising invoices? (This is limited to work involved in preparing and editing billing records that would not be compensable outside of bankruptcy and does not include reasonable fees for preparing a fee application.) If so, please quantify by hours and fees. Response: The Application does not include time for preparing, reviewing, or revising time records. However, the Application

entries are properly categorized by matter number and task code. On average, less than three hours were spent on each of the five monthly fee statements prepared during the Fee Period.

Question: Does this application include time or fees for reviewing time records to redact any privileged or other confidential information? If so, please quantify by hours and fees.

Response: No. Question: If the application includes any rate increases since retention:

Did your client review and approve those rate increases in

Did your client agree when retaining the law firm to accept all future rates increases? If not, did you inform your client that they need not agree to modified rates or terms in order to have you continue the representation consistent

11-458? Response: As is customary, Paul Hastings adjusts its hourly rates

professionals and paraprofessionals, (ii)

rates being charged by professionals in other law firms.

Hastings adjusted its hourly rates consistent with the Retention Order [Docket No. 668] and the Notices of Change in Hourly Rates of Paul Hastings LLP, Counsel to Chapter

2075].

129. To the extent that time or disbursement charges for services rendered or expenses incurred during the Fee Period are not included in this Application, or the Trustee and Paul Hastings have for any reason not sought compensation or reimbursement with respect to such services, Paul Hastings reserves the right to request compensation and reimbursement for such services in a supplemental or future application in the Debtors' chapter 11 cases. Also, Paul Hastings 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.

130. No previous request for the relief sought herein has been made to this Court or any other court. Case 22-50073 Doc 2935 Filed 02/19/24 Entered 02/19/24 20:04:06 Page 60 of 779

WHEREFORE, Paul Hastings respectfully requests entry of an order, substantially in the form attached hereto as Exhibit G, (i) allowing interim compensation for professional services rendered during the Fee Period in the amount of \$6,911,034.50 and reimbursement of \$718,236.31 in expenses, (ii) authorizing payment from the Debtors' estates of 80% of such compensation and 100% of such expenses as it relates to the Fee Period services, (iii) allowing such compensation and payment for professional services rendered and reimbursement of actual and necessary expenses incurred without prejudice to the Trustee's and Paul Hastings' right to seek further compensation and/or payment from the Debtors' estates for the full value of services performed and expenses incurred, and (iv) granting the Trustee and Paul Hastings such other and further relief as is just. [Remainder of page intentionally left blank.]

Dated: February 19, 2024 New Haven, Connecticut

Douglas S. Skalka (ct00616) Patrick R. Linsey (ct29437) NEUBERT, PEPE & MONTEITH, P.C. 195 Church Street, 13th Floor New Haven, Connecticut 06510 (203) 781-2847 dskalka@npmlaw.com plinsey@npmlaw.com

Nicholas A. Bassett (admitted pro hac vice) PAUL HASTINGS LLP 2050 M Street NW Washington, D.C., 20036 (202) 551-1902 nicholasbassett@paulhastings.com

Avram E. Luft (admitted pro hac vice) G. Alexander Bongartz (admitted pro hac vice) PAUL HASTINGS LLP 200 Park Avenue New York, New York 10166 (212) 318-6079 aviluft@paulhastings.com alexbongartz@paulhastings.com

Counsel for the Chapter 11 Trustee, Genever Holdings Corporation, and Genever Holdings LLC UNITED STATES BANKRUPTCY COURT DISTRICT OF CONNECTICUT BRIDGEPORT DIVISION

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

In re: :

HO WAN KWOK, et al., Case No. 22-50073 (JAM) Debtors. : :

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

The undersigned hereby certifies that on February 19, 2024, the foregoing Application was electronically filed. Notice of this filing was sent by e-mail to all parties to the abovecaptioned chapter 11 case 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.1 In addition, to the extent not covered by the foregoing, copies of the Application were served on the twenty (20) largest creditors in the Debtors' chapter 11 cases. Parties may access this filing through the Court's CM/ECF system.

Dated: February 19, 2024 at New Haven, Connecticut

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

Counsel for the Chapter 11 Trustee, Genever Holdings Corporation, and Genever Holdings LLC

1 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.

Customary and Comparable Compensation Disclosures

The blended hourly rate for Paul Hastings' timekeepers in its New York office who billed to non-bankruptcy matters (collectively, the "Non-Bankruptcy Matters") 1 during the twelve-month period beginning on January 1, 2023 and ending on December 31, 2023 was, in the aggregate, approximately \$1,191 per hour. The blended hourly rate for Paul Hastings' timekeepers who billed to the Debtor's chapter 11 cases during the Fee Period was approximately \$1,226 per hour. A detailed comparison of these rates follows:

Category of Timekeeper Blended Hourly Rate

Blended Hourly Rate Debtor Blended Hourly

All Timekeepers Aggregated \$1,191 \$1,226

1 It is the nature of Paul Hastings' practice that certain non-bankruptcy engagements require the advice and counsel of professionals and paraprofessionals who work primarily within Paul Hastings' restructuring group. Accordingly, Non-Bankruptcy Matters consist of matters for which Paul Hastings' timekeepers represented a client in matters other than court-approved engagements as counsel for the debtor, the chapter 11 trustee, or an official committee under the Bankruptcy Code. As such, the Non-Bankruptcy Matters include, in part, time billed by Paul Hastings' timekeepers who work primarily within Paul Hastings' restructuring group.

2 Luc A. Despins brings to the Title III Cases over 35 years of experience representing debtors and creditors in high profile and complex restructuring matters. Given the complexity and challenges faced by the Trustee in these cases, a significant amount of time by senior partners, of counsel, and senior associates, including Mr. Despins, Nicholas Bassett, Alexander Bongartz, Avi Luft, Douglass Barron, and Shlomo Maza has been necessary. Because their rates are at the higher end of the range of rates billed by Paul Hastings partners, of counsel, and associates, respectively, and in light of the fact that a significant amount of senior partner, of counsel, and senior associate time has been required for this engagement, the blended rate for this case moved to the higher end of the range of rates billed by Paul Hastings. Finally, the blended attorney hourly rate for the Fee Period is not comparable to the average hourly rate in other matters because it does not reflect numerous cost-saving measures, including the delegation of a variety of matters to NPM, matters for which otherwise more junior Paul Hastings attorneys with lower hourly rates would have been used, thereby reducing Paul Hastings' blended hourly rate.

Summary of Timekeepers Included in this Application

Bassett, Nicholas Corporate, 2007 \$1,675.00 483.70 \$810,197.50 2 Bassett, Nicholas (travel; ½ rate) Corporate, 2007 \$837.50 3.00 \$2,512.50 2 Despins, Luc Restructuring, 1986 \$1,975.00 306 \$604,350.00 1 Despins, Luc (travel; ½ rate) Restructuring, 1986 \$987.50 3.70 \$3,653.75 1 Weitzman, Avi Litigation, 2000 \$1,750.00 11.70 \$20,475.00 N/A

Bongartz, Alex Restructuring, 2007 \$1,675.00 254.40 \$426,120.00 2 Bongartz, Alex (travel; ½ rate) Restructuring, 2007 \$837.50 3.20 \$2,680.00 2 Luft, Avi Corporate, 2000 \$1,675.00 756.80 \$1,267,640.00 2 Luft, Avi (travel; ½ rate) Corporate, 2000 \$837.50 3.30 \$2,763.75 2 Traxler, Katherine Restructuring, 1990 \$1,055.00 9.90 \$10,444.50 2 Of Counsel Total: 1,027.60 \$1,709,648.25

Barron, Douglass Corporate, 2012 \$1,360.00 530.00 \$720,800.00 2

½ rate) Corporate, 2012 \$680.00 5.50 \$3,740.00 2 Catalano, Kristin Corporate, 2021 \$940.00 276.90 \$260,286.00 2 Farmer, Will Corporate, 2018 \$1,270.00 256.70 \$326,009.00 2 Kosciewicz, Jon Litigation, 2021 \$940.00 464.50 \$436,630.00 2

Arbitration, 2018 \$1,210.00 77.50 \$93,775.00 N/A Maza, Shlomo Corporate, 2012 \$1,360.00 285.50 \$388,280.00 2 Ostrander, Will Litigation, 2021 \$1,045.00 53.20 \$55,594.00 N/A Sadler, Tess Corporate, 2019 \$1,210.00 38.40 \$46,464.00 2 Simpson, Louise Corporate, 2022 \$855.00 6.00 \$5,130.00 1 Song, Luyi Corporate, 2023 \$855.00 753.60 \$644,328.00 2 Song, Luyi (travel, bill at ½ rate) Corporate, 2023 \$427.50 13.00 \$5,557.50 2 Sutton, Ezra Corporate, 2021 \$1,045.00 543.20 \$567,644.00 2 Associate Total: 3,304.00 \$3,554,237.50

Kuo, Jocelyn Paralegal \$540.00 187.70 \$101,358.00 N/A Mohamed, David Paralegal \$540.00 304.30 \$164,322.00 1

Paraprofessional Total: 497.70 \$267,960.00

PRIOR AGREED-UPON REDUCTIONS: (\$62,000.00)

Summary of Timekeepers Not Included in this Application1

Fee, Adam Litigation, 2008 \$1,625.00 1.00 \$1,625.00 Tsao, Leo Litigation, 1999 \$1,570.00 2.90 \$4,553.00

Daly, Crispin Corporate, 2010 \$1,360.00 2.70 \$3,672.00

Austin, Javii Legal Research Analyst \$400.00 2.80 \$1,120.00 Chang, Irene Legal Research Analyst \$400.00 4.10 \$1,640.00 Ecklund, Amy Technical Operations Senior

Elliott, Elizabeth Legal Research Analyst \$400.00 1.80 \$720.00 Hopkovitz, Yael Legal Research Analyst \$450.00 1.20 \$540.00 Laskowski, Mat Legal Research Analyst \$540.00 4.40 \$2,376.00 Liu, Kelly Legal Research Analyst \$400.00 2.60 \$1,040.00

Legal Research Analyst \$400.00 0.70 \$280.00 Paraprofessional Total: 19.60 \$8,556.00

1 As noted, as an accommodation to these estates, Paul Hastings is not seeking allowance or payment at this time for the fees of timekeepers who billed less than five (5) hours during the Fee Period in the aggregate amount of \$20,287.00. The time billed by these timekeepers was reasonable, and Paul Hastings reserves the right to seek allowance of these fees based on the facts and circumstances of these cases, including, without limitation, if objections are interposed to the allowance of Paul Hastings' fees and expenses.

Summary of Compensation by Project Category

U.S. Trustee Task Code and Project Category Fees

B110 Case Administration 97.90 \$77,165.50 B113 Pleadings Review 152.30 \$82,967.00 B120 Asset Analysis and Recovery 14.50 \$26,876.00 B130 Asset Disposition 63.50 \$89,235.50 B131 Sale of Real Estate 0.80 \$1,340.00 B150 Meetings of and Communications with Creditors 12.40 \$18,499.00 B155 Court Hearings 177.40 \$236,358.50 B160 Employment / Fee Applications (Paul Hastings) 56.30 \$82,368.00 B165 Employment / Fee Applications (Other Professionals) 62.50 \$88,598.50 B190 Other Contested Matters 13.70 \$18,065.00 B191 General Litigation 4,046.90 \$5,130,469.50 B195 Non-Working Travel 32.80 \$23,080.00 B210 Business Operations 113.10 \$143,757.00 B211 Financial Reports (Monthly Operating Reports) 18.90 \$23,041.00 B230 Financing / Cash Collections 11.10 \$13,844.00

B261 Investigations 751.20 \$901,947.00 B310 Claims Administration and Objections 4.70 \$5,218.50

Representation \$133,849.00 \$122,707.50 \$113,062.75 \$88,943.25 \$458,562.50

Investigation and Litigation \$168,401.00 \$439,184.50 \$321,065.50 \$448,438.50 \$1,377,089.50 00003 Other Litigation \$325,411.00 \$15,747.00 \$6,003.50 \$70,982.00 \$418,143.50 00004 Corporate Law Issues \$5,097.50 \$0.00 \$0.00 \$1,975.00 \$7,072.50 00005 Sale Process \$6,270.00 \$8,434.50 \$29,403.00 \$33,359.00 \$77,466.50 00006 Tax Issues \$0.00 \$6,901.50 \$2,465.50 \$837.50 \$10,204.50 00007 Foreign Law Issues \$0.00 \$0.00 \$0.00 \$0.00 \$0.00 00008 Plan Process Issues \$0.00 \$0.00 \$0.00 \$0.00 \$0.00 00010 Genever US \$34,867.00 \$54,796.50 \$31,219.50 \$11,980.50 \$132,863.50 00011 Genever BVI \$0.00 \$0.00 \$0.00 \$0.00 \$0.00 00012 Mahwah Adversary \$56,360.25 \$307,228.00 \$183,087.50 \$415,329.50 \$962,005.25 00013 Golden Spring Adversary \$13,821.00 \$16,396.00 \$0.00 \$2,741.50 \$32,958.50 00014 HCHK Adversary \$658,961.00 \$279,052.00 \$930,690.00 \$38,796.00 \$1,907,499.00 00015 Interpleader Adversary \$2,177.50 \$4,474.50 \$0.00 \$0.00 \$6,652.00 00016 Mei Guo Adversary \$60,223.50 \$70,219.50 \$20,536.00 \$98,075.50 \$249,054.50 00017 HK USA Adversary \$85,473.00 \$4,707.00 \$0.00 \$0.00 \$90,180.00 00018 Bravo Luck Adversary \$0.00 \$0.00 \$0.00 \$0.00 \$0.00 00019 SN Apartment Adversary \$0.00 \$0.00 \$0.00 \$0.00 \$0.00 00020 Greenwich Land Adversary \$382,199.25 \$238,297.00 \$74,439.00 \$223,239.00 \$918,174.25 00022 PAX Adversary \$0.00 \$0.00 \$0.00 \$0.00 \$0.00 00024 Lamp Capital Adversary \$0.00 \$79,602.50 \$17,886.00 \$14,214.00 \$111,702.50 00025 RICO Claims \$0.00 \$0.00 \$98,903.00 \$84,485.50 \$183,388.50 00026 Ace Decade Adversary \$0.00 \$0.00 \$0.00 \$30,017.50 \$30,017.50 TOTAL \$1,933,111.00 \$1,647,748.00 \$1,828,761.25 \$1,563,414.25 \$6,973,034.50

Expense Category September October November December Total

Airfare (Nicholas Bassett) \$0.00 \$0.00 \$0.00 \$628.90 \$628.90 Articles and Publications \$100.00 \$10.00 \$4.44 \$0.30 \$114.74

Documents):

Metro Attorney Service \$2,235.10 \$2,707.50 \$4,287.70 \$5,861.90 \$15,092.20 Computer Search (Other) \$827.57 \$795.24 \$723.06 \$571.05 \$2,916.92 Court Reporting Services \$42,035.99 \$7,684.25 \$0.00 \$0.00 \$49,720.24

Data Base Storage \$336.00 \$0.00 \$0.00 \$0.00 \$336.00 Lexis/On Line Search \$1,054.78 \$680.90 \$2,833.70 \$1,395.34 \$5,964.72

Meals \$417.45 \$678.32 \$247.59 \$204.77 \$1,548.13

Parking \$0.00 \$0.00 \$0.00 \$13.00 \$13.00

Taxi \$342.94 \$191.32 \$186.75 \$291.06 \$1,012.07 Lodging \$0.00 \$0.00 \$0.00 \$1,075.14 \$1,075.14 Outside Professional Services:

Divergent Language \$8,903.50 \$2,450.00 \$0.00 \$0.00 \$11,353.50

TransPerfect Translations \$1,879.00 \$0.00 \$5,024.92 \$0.00 \$6,903.92 International, Inc.

UnitedLex \$183,252.05 \$79,456.00 \$57,362.62 \$241,691.24 \$561,761.91

Other \$110.10 \$238.00 \$12.50 \$0.00 \$360.60 Postage/Express Mail \$649.99 \$867.09 \$1,104.63 \$550.28 \$3,171.99 Reproduction Charges \$2,483.36 \$3,569.04 \$4,186.56 \$666.16 \$10,905.12 Reproduction Charges (Color) \$101.00 \$79.60 \$3,162.80 \$0.00 \$3,343.40 Retrieval of Corporate Documents:

TransUnion Risk \$60.00 \$35.00 \$0.00 \$95.00 \$190.00

Other \$68.95 \$20.00 \$0.00 \$0.00 \$88.95 Search Fees \$165.11 \$0.00 \$12.31 \$0.00 \$177.42 Taxi/Ground Transportation \$2,017.25 \$362.28 \$155.46 \$903.27 \$3,438.26

Meals \$13.91 \$0.00 \$0.00 \$98.53 \$112.44

Parking \$34.00 \$0.00 \$0.00 \$0.00 \$34.00 UPS/Courier Service \$1,223.03 \$1,056.09 \$2,519.33 \$204.31 \$5,002.76 Vendor Expense \$67.04 \$0.00 \$15.10 \$6.70 \$88.84 Westlaw \$6,532.88 \$3,486.47 \$8,754.89 \$13,974.90 \$32,749.14 TOTAL \$254,911.00 \$104,499.10 \$90,594.36 \$268,231.85 \$718,236.31

Luc Despins as Chapter 11 Trustee in thecase of Ho Wan Kwok 200 Park Avenue New York, NY 10166 November 30, 2023 Please Refer to Invoice Number: 2375609

Attn: Luc Despins PH LLP Tax ID No. 95-2209675

General Chapter 11 Trustee Representation

PH LLP Client/Matter # 50687-00001 Luc A. Despins

Legal fees for professional services for the period ending September 30, 2023 \$135,730.00

Total Balance Due - Due Upon Receipt \$142,466.54

We encourage our clients to pay via ACH, however, in the event that you pay by check, please send payment to the remittance address below:

*TO PROTECT AGAINST FRAUD, the Firm will not change its wiring instructions via email. We strongly encourage clients to confirm any change in wiring instructions by contacting Teri Goffredo @ 213-683-5045 or via email @ terigoffredo@paulhastings.com and requesting written and verbal confirmation.*

Wiring and ACH Instructions: Remittance Address: Pay by Tranch:

Citibank Paul Hastings LLP You can now pay your invoices online via ABA # 322271724 Lockbox 4803 real-time bank payments, credit cards or SWIFT Address: CITIUS33 PO Box 894803 in installments:

*For wires, please reference the invoice, client and matter number(s) being paid For ACH payments, please use the CTX format and/or send any remittances to cashepn@paulhastings com This is a no-reply mailbox*

Luc Despins as Chapter 11 Trustee in thecase of Ho Wan Kwok 200 Park Avenue New York, NY 10166 November 30, 2023 Please Refer to Invoice Number: 2375609

Attn: Luc Despins PH LLP Tax ID No. 95-2209675

General Chapter 11 Trustee Representation

PH LLP Client/Matter # 50687-00001 Luc A. Despins

Legal fees for professional services for the period ending September 30, 2023 \$135,730.00

Total Balance Due - Due Upon Receipt \$142,466.54

We encourage our clients to pay via ACH, however, in the event that you pay by check, please send payment to the remittance address below:

*TO PROTECT AGAINST FRAUD, the Firm will not change its wiring instructions via email. We strongly encourage clients to confirm any change in wiring instructions by contacting Teri Goffredo @ 213-683-5045 or via email @ terigoffredo@paulhastings.com and requesting written and verbal confirmation.*

Wiring and ACH Instructions: Remittance Address: Pay by Tranch:

Citibank Paul Hastings LLP You can now pay your invoices online via ABA # 322271724 Lockbox 4803 real-time bank payments, credit cards or SWIFT Address: CITIUS33 PO Box 894803 in installments:

*For wires, please reference the invoice, client and matter number(s) being paid For ACH payments, please use the CTX format and/or send any remittances to cashepn@paulhastings com This is a no-reply mailbox*

Luc Despins as Chapter 11 Trustee in thecase of Ho Wan November 30, 2023

New York, NY 10166 Invoice Number: 2375609

Attn: Luc Despins PH LLP Tax ID No. 95-2209675

FOR PROFESSIONAL SERVICES RENDERED for the period ending September 30, 2023 General Chapter 11 Trustee Representation \$135,730.00

Date Initials Description Hours Rate Amount

09/01/2023 DM26 Update critical dates calendar and send outlook reminders (.5); review and update working group re upcoming filing deadlines

09/05/2023 AB21 Update list of open issues and workstreams

09/05/2023 DM26 Update critical dates calendar and send outlook reminders to working group (.4);

cancellation (.1); review and update working group re upcoming filing deadlines (.2) 0.70 540.00 378.00 09/05/2023 LAD4 T/c S. Sarnoff (OMM) re: cases update 0.90 1,975.00 1,777.50 09/06/2023 DM26 Update critical dates calendar and send outlook reminders (.8); review and update working group re upcoming filing deadlines

09/07/2023 DM26 Update critical dates calendar and send outlook reminders (.7); review and update working group re upcoming filing deadlines

Date Initials Description Hours Rate Amount

09/08/2023 DM26 Update critical dates calendar and send outlook reminders (.6); review and update working group re upcoming filing deadlines

09/11/2023 AB21 Update list of open issues and workstreams 0.20 1,675.00 335.00 09/11/2023 DM26 Update critical dates calendar and send outlook reminders (.4); review and update working group re upcoming filing deadlines

09/12/2023 DM26 Update critical dates calendar and send outlook reminders (1.0); review and update working group re upcoming filing deadlines

09/13/2023 DM26 Update critical dates calendar and send outlook reminders (.5); review and update working group re upcoming filing deadlines

09/14/2023 DM26 Update critical dates calendar and send outlook reminders (.3); review and update working group re upcoming filing deadlines

09/14/2023 LAD4 T/c P. Linsey (NPM) & N. Bassett re: assignment of tasks to NPM 0.20 1,975.00 395.00 09/14/2023 NAB Call with L. Despins and P. Linsey (NPM) regarding case strategy and NPM matters 0.20 1,675.00 335.00 09/15/2023 DM26 Update critical dates calendar and send outlook reminders (.6); review and update working group re upcoming filing deadlines

09/18/2023 DM26 Update critical dates calendar and send outlook reminders (.6); review and update working group re upcoming filing deadlines

09/18/2023 LAD4 T/c S. Sarnoff (OMM) re: cases update 0.30 1,975.00 592.50 09/19/2023 DM26 Update critical dates calendar and send outlook reminders (.5); review and update working group re upcoming filing deadlines

Luc Despins as Chapter 11 Trustee in thecase of Ho Wan Kwok 50687-00001 Invoice No. 2375609

Date Initials Description Hours Rate Amount

09/20/2023 DM26 Update critical dates calendar and send outlook reminders (.9); review and update working group re upcoming filing deadlines

09/21/2023 DM26 Update critical dates calendar and send outlook reminders (.5); review and update working group re upcoming filing deadlines

09/22/2023 DM26 Update critical dates calendar and send outlook reminders (.4); review and update working group re upcoming filing deadlines

09/25/2023 AB21 Update list of open issues and workstreams 0.20 1,675.00 335.00 09/25/2023 DM26 Update critical dates calendar and send outlook reminders (.6); review and update working group re upcoming filing deadlines

09/26/2023 AB21 Update list of open issues and pending

09/26/2023 DM26 Update critical dates calendar and send outlook reminders (.3); review and update working group re upcoming filing deadlines

09/27/2023 AB21 Update list of open issues and workstreams 0.20 1,675.00 335.00 09/27/2023 DM26 Update critical dates calendar and send outlook reminders (.5); review and update working group re upcoming filing deadlines

09/27/2023 LAD4 T/c A. Luft & N. Bassett re: Kroll retention and case strategy 0.70 1,975.00 1,382.50 09/27/2023 AEL2 Meeting with L. Despins and N. Bassett re:

deposition for counsel 0.70 1,675.00 1,172.50 09/27/2023 NAB Call with L. Despins and A. Luft regarding general case strategy issues 0.70 1,675.00 1,172.50 09/28/2023 AB21 Update list of open issues and workstreams 0.30 1,675.00 502.50

Date Initials Description Hours Rate Amount

09/28/2023 DM26 Update critical dates calendar and send outlook reminders (.6); review and update working group re upcoming filing deadlines

09/28/2023 LAD4 T/c P. Linsey (NPM), A. Luft and N. Bassett re: transferring matters to local

09/28/2023 AEL2 Call with P. Linsey, D. Skalka, L. Despins

09/28/2023 NAB Call with L. Despins, A. Luft, and NPM

issues/task list and upcoming deadlines (.2) 0.70 1,675.00 1,172.50 09/29/2023 DM26 Update critical dates calendar and send outlook reminders (.5); review and update working group re upcoming filing deadlines

09/29/2023 ECS1 Correspond with Trustee regarding upcoming deadlines in the Kwok case 0.10 1,045.00 104.50 Subtotal: B110 Case Administration 23.50 22,817.00

09/01/2023 AB21 Review chapter 11 docket update and recent

09/01/2023 DM26 Review recent filings in Kwok case no. 22-

group re same (.2); review recent filings in certain NY State Court actions and update working group re same (.4); review related case dockets regarding recent filings (.5) 1.70 540.00 918.00

Case 22-50073 Doc 2935 Filed 02/19/24 Entered 02/19/24 20:04:06 Page 76 of 779

Luc Despins as Chapter 11 Trustee in thecase of Ho Wan Kwok 50687-00001 Invoice No. 2375609

Date Initials Description Hours Rate Amount

09/05/2023 DM26 Review recent filings in Kwok case no. 22-

adversary proceedings & NY state case and update working group re same (.3); review related case dockets re: recent filings (.5) 1.60 540.00 864.00 09/06/2023 DM26 Review recent filings in Kwok case no. 22-

group re same (.4); review recent filing in

certain case documents per attorney request (.4); review related case dockets regarding recent filings (.5) 2.10 540.00 1,134.00 09/07/2023 DM26 Review recent filings in Kwok case no. 22-

group re same (.6); review recent filings in certain CT District Court cases and update working group re same (.4); review recent filing in USA v. Kwok case no. 23cr118 and update working group re same (.1); review related case dockets regarding recent filings

09/08/2023 DM26 Review recent filings in Kwok case no. 22-

dockets regarding recent filings (.5) 1.50 540.00 810.00 09/11/2023 DM26 Review recent filings in Kwok case no. 22-

(.7); review related case dockets regarding recent filings (.5) 2.40 540.00 1,296.00

Case 22-50073 Doc 2935 Filed 02/19/24 Entered 02/19/24 20:04:06 Page 77 of 779

Luc Despins as Chapter 11 Trustee in thecase of Ho Wan Kwok 50687-00001 Invoice No. 2375609

Date Initials Description Hours Rate Amount

09/12/2023 DM26 Review recent filings in Kwok case no. 22-

(.7); review recent filings in Genever US v.

dockets regarding recent filings (.6);

attorney request (.4) 1.80 540.00 972.00 09/13/2023 DM26 Review recent filings in Kwok case no. 22-

adversary proceedings and CT district court

(.4); review related case dockets regarding recent filings (.5) 1.30 540.00 702.00 09/14/2023 DM26 Review recent filings in Kwok case no. 22-

dockets regarding recent filings (.5) 1.80 540.00 972.00 09/15/2023 DM26 Review recent filings in Kwok case no. 22-

(.5); review recent filings in Greenwich & Ngok v. Despins District Court case no.

(.2); review related case dockets regarding recent filings (.5) 1.20 540.00 648.00 09/18/2023 DM26 Review recent filings in Kwok case no. 22-

adversary proceedings and CT district court

(1.7); review recent filing in USA v. Kwok case no. 23cr118 and update working group re same (.1); review related case dockets 2.70 540.00 1,458.00

Case 22-50073 Doc 2935 Filed 02/19/24 Entered 02/19/24 20:04:06 Page 78 of 779

Luc Despins as Chapter 11 Trustee in thecase of Ho Wan Kwok 50687-00001 Invoice No. 2375609

Date Initials Description Hours Rate Amount

09/19/2023 DM26 Review recent filings in Kwok case no. 22-

(.8); review recent filings in certain CT

dockets regarding recent filings (.5); review

and update working group re same (.1) 1.70 540.00 918.00 09/19/2023 DM26 Review certain filings in Kwok's main case and adversary proceedings (1.3); correspond

uploading same to the Relativity database

regarding same (.3) 1.80 540.00 972.00 09/20/2023 DM26 Review certain filings in Kwok's main case and adversary proceedings (3.9); correspond

same to the Relativity database (.3);

UnitedLex regarding same (.5) 4.70 540.00 2,538.00 09/20/2023 DM26 Review recent filings in Kwok case no. 22-

(.9); review related case dockets regarding recent filings (.5) 2.00 540.00 1,080.00 09/21/2023 DM26 Review recent filings in Kwok case no. 22-

group re same (.3); review recent filings in

working group re same (.6); review related case dockets regarding recent filings (.5) 2.40 540.00 1,296.00

Case 22-50073 Doc 2935 Filed 02/19/24 Entered 02/19/24 20:04:06 Page 79 of 779

Luc Despins as Chapter 11 Trustee in thecase of Ho Wan Kwok 50687-00001 Invoice No. 2375609

Date Initials Description Hours Rate Amount

09/22/2023 DM26 Review recent filings in Kwok case no. 22-

(.6); review recent filings in USA v. Kwok case no. 23cr118 and update working group re same (.3); review related case dockets regarding recent filings (.5) 1.40 540.00 756.00 09/25/2023 DM26 Review recent filings in Kwok case no. 22-

(.6); review related case dockets regarding recent filings (.6) 1.70 540.00 918.00 09/26/2023 DM26 Review recent filings in Kwok case no. 22-

dockets regarding recent filings (.5) 1.20 540.00 648.00 09/26/2023 ECS1 Review pleadings for upcoming deadlines in

09/27/2023 DM26 Review recent filings in Kwok case no. 22-

(.6); review recent filings in Despins v. HCHK, et al. case no. 23ap5013 and update working group re same (.7); review related case dockets regarding recent filings (.5) 1.80 540.00 972.00 09/28/2023 DM26 Review recent filings in Kwok case no. 22-

(.6); review recent filings in Despins v. HCHK, et al. case no. 23ap5013 and update working group re same (.3); review related case dockets regarding recent filings (.4) 1.30 540.00 702.00

Case 22-50073 Doc 2935 Filed 02/19/24 Entered 02/19/24 20:04:06 Page 80 of 779

Date Initials Description Hours Rate Amount

09/29/2023 DM26 Review recent filings in Kwok case no. 22-

dockets regarding recent filings (.4) 1.50 540.00 810.00 Subtotal: B113 Pleadings Review 42.20 23,179.00

09/01/2023 DM26 Prepare draft internal agenda for 9/6/23 hearing (.3); correspond with E. Sutton re

09/03/2023 DM26 Update draft internal agenda for 9/6/23 hearing (.3); correspond with E. Sutton re

09/05/2023 DM26 Prepare reference materials for 9/6/23

09/08/2023 DM26 Prepare draft agendas for hearings scheduled for 9/12/23 and 9/13/23 (1.6); correspond with E. Sutton re same (.1) 1.70 540.00 918.00 09/10/2023 DM26 Update 9/12/23 and 9/13/23 hearing

09/11/2023 AB21 Call with L. Despins regarding September 12 hearing prep (0.1); correspond with S. Millman (Stroock) regarding same (0.1) 0.20 1,675.00 335.00 09/11/2023 DM26 Prepare reference materials for 9/12/23

09/11/2023 LAD4 Review issues, notes to prepare for 9/12 hearing (.40); t/c A. Bongartz re: same (.10) 0.50 1,975.00 987.50 09/12/2023 AB21 Prepare hearing notes for hearing on PH fee application and DIP motion (0.4); correspond with L. Despins regarding same (0.1); call with S. Maza regarding same (0.1); call with L. Despins and S. Maza regarding 1.60 1,675.00 2,680.00

Date Initials Description Hours Rate Amount

09/12/2023 JK21 Correspond with S. Maza regarding reference materials for the September 12,

09/12/2023 LAD4 Review submissions and prepare outline for DIP hearing (1.60); t/c A. Bongartz and S. Maza re: DIP hearing prep (.10); t/c S. Maza re: surcharge issues (.20); handle DIP

09/15/2023 DM26 Prepare agenda for 9/19/23 hearing 0.70 540.00 378.00 09/22/2023 DM26 Draft agenda for 9/26/23 hearing 0.70 540.00 378.00 09/27/2023 AB21 Listen to September 27 hearing (0.7); post

regarding same (0.1) 0.80 1,675.00 1,340.00 09/27/2023 DM26 Research and prepare certain pleadings relating to 9/27/23 hearing for L. Despins 0.50 540.00 270.00 09/27/2023 ECS1 Prepare list of agenda items for October and November hearings in the case for the

09/27/2023 LAD4 Review submissions and prepare notes re:

retention of Kroll (.70); post mortem A.

09/29/2023 DM26 Prepare agenda for 10/3/23 hearing 2.60 540.00 1,404.00 Subtotal: B155 Court Hearings 20.30 20,716.00

09/01/2023 AB21 Correspond with L. Despins regarding U.S.

fee application 0.80 1,675.00 1,340.00

09/05/2023 AB21 Correspond with L. Despins regarding PH second interim fee application 0.30 1,675.00 502.50

Luc Despins as Chapter 11 Trustee in thecase of Ho Wan Kwok 50687-00001 Invoice No. 2375609

Date Initials Description Hours Rate Amount

09/06/2023 AB21 Correspond with L. Despins regarding PH July fee statement (0.2); revise same (0.2); call with C. Edge regarding same (0.1);

09/07/2023 AB21 Finalize PH July fee statement (0.6); correspond with L. Despins regarding same

filing and service of same (0.2); correspond with Notice Parties regarding same (0.1) 1.00 1,675.00 1,675.00 09/07/2023 KAT2 Prepare third interim fee application for July through August 2023 services (1.7); review interim compensation order regarding same

information for same (.1) 1.90 1,055.00 2,004.50 09/11/2023 AB21 Revise proposed PH fee order and related notice of filing (0.7); correspond with J. Kuo regarding same (0.1); correspond with L. Despins regarding same (0.1) 0.90 1,675.00 1,507.50 09/11/2023 JK21 Prepare notice of filing of revised second

electronic filing notice of filing of revised second interim fee order (0.2); electronically file with the court notice of filing of revised second interim fee order (0.3) 0.80 540.00 432.00 09/11/2023 KAT2 Prepare parts of third interim fee

09/13/2023 AB21 Correspond with C. Edge regarding update on PH August fee statement 0.10 1,675.00 167.50 09/13/2023 ECS1 Correspond with PH Conflicts Dept. regarding additional parties in interest in the

09/14/2023 AB21 Correspond with E. Sutton regarding PH supplemental declaration 0.10 1,675.00 167.50 09/14/2023 AB21 Review PH August fee statement 1.10 1,675.00 1,842.50

Date Initials Description Hours Rate Amount

09/14/2023 ECS1 Prepare the Trustee's seventh supplemental declaration of disinterestedness (.1); correspond with A. Bongartz and L. Despins regarding same (.2) 0.30 1,045.00 313.50 09/14/2023 ECS1 Correspond with PH Conflicts Dept. regarding additional parties in interest in the

09/14/2023 JK21 Correspond with E. Sutton regarding updated parties in interest list 0.30 540.00 162.00 09/14/2023 JK21 Prepare for electronic filing seventh

disinterestedness of L. Despins 0.20 540.00 108.00 09/15/2023 AB21 Revise PH August fee statement (0.5);

09/15/2023 ECS1 Review Trustee's seventh supplemental declaration of disinterestedness (.1); correspond with J. Kuo regarding same (.1) 0.20 1,045.00 209.00 09/15/2023 JK21 Electronically file with the court seventh

disinterestedness of L. Despins 0.40 540.00 216.00 09/19/2023 KAT2 Prepare UST Appendix B parts of interim

09/20/2023 AB21 Final review of PH August fee statement (0.5); revise related cover sheets (0.2); correspond with L. Despins regarding same

filing of same (0.1); correspond with notice parties regarding same (0.1) 1.00 1,675.00 1,675.00 09/20/2023 JK21 Electronically file with the court Paul

09/20/2023 KAT2 Prepare parts of third interim fee

Luc Despins as Chapter 11 Trustee in thecase of Ho Wan Kwok 50687-00001 Invoice No. 2375609

Date Initials Description Hours Rate Amount

09/21/2023 AB21 Prepare supplement to PH July and August fee statements (0.3); correspond and call with L. Despins regarding same (0.1); correspond with H. Claiborn (U.S. Trustee) regarding same (0.1) 0.50 1,675.00 837.50 09/22/2023 AB21 Finalize supplement to PH July and August fee statements (0.1); correspond with J. Kuo regarding filing of same (0.1) 0.20 1,675.00 335.00 09/22/2023 JK21 Electronically file with the court

Hastings monthly fee statements 0.30 540.00 162.00 09/25/2023 KAT2 Prepare parts of third interim fee

proposed order (2.3); correspond with A. Bongartz and C. Edge regarding same (.1) 2.40 1,055.00 2,532.00 09/26/2023 ECS1 Correspond with PH Conflicts Dept. regarding additional parties in interest 0.20 1,045.00 209.00 09/27/2023 ECS1 Prepare list of additional interested parties

retention declaration 0.10 1,045.00 104.50 09/28/2023 ECS1 Review correspondence from PH Conflicts Dept. regarding additional parties in interest and connection to Paul Hastings 0.10 1,045.00 104.50 09/28/2023 KAT2 Correspond with A. Bongartz regarding September services 0.20 1,055.00 211.00 Subtotal: B160 Fee/Employment Applications 18.00 22,256.50

Fee/Employment Applications for Other Professionals

09/01/2023 AB21 Call with R. Amporfro (Epiq) regarding Epiq monthly fee statement (0.2);

09/01/2023 AB21 Correspond with D. Skalka (Neubert Pepe) regarding retention of tax accountant 0.10 1,675.00 167.50

Date Initials Description Hours Rate Amount

09/05/2023 AB21 Correspond with D. Skalka (NPM) regarding tax accountants 0.10 1,675.00 167.50 09/06/2023 AB21 Correspond with P. Linsey (NPM) regarding NPM fee statement (0.1); revise Harneys monthly fee statement (0.2);

regarding same (0.1) 0.40 1,675.00 670.00 09/07/2023 AB21 Finalize Harneys and Epiq fee statements (0.3); correspond with R. Amporfro (Epiq) regarding Epiq fee statement (0.1); correspond with J. Kuo regarding filing of Harneys and Epiq fee statements (0.1);

same (0.1); calls with D. Courtney (Pallas) regarding Pallas fee statement (0.3); review

statement (0.3); call with P. Linsey (NPM) regarding same (0.1) 1.70 1,675.00 2,847.50 09/07/2023 JK21 Prepare and electronically file with the court Paul Hastings, Epiq, and Harneys July 2023 monthly fee statements 0.60 540.00 324.00 09/11/2023 AB21 Correspond with D. Skalka (NPM) regarding tax accountant services 0.10 1,675.00 167.50 09/12/2023 AB21 Correspond with D. Skalka (NPM) regarding call with Cohn Reznick regarding tax accountant work 0.10 1,675.00 167.50 09/13/2023 AB21 Call with A. Li (Cohn Reznick) and D.

regarding same (0.3); correspond with L. Despins regarding same (0.1) 0.80 1,675.00 1,340.00 09/14/2023 AB21 Call with A. Pfeiffer (Kroll) regarding interim compensation process 0.20 1,675.00 335.00

Luc Despins as Chapter 11 Trustee in thecase of Ho Wan Kwok 50687-00001 Invoice No. 2375609

Date Initials Description Hours Rate Amount

09/20/2023 AB21 Finalize Epiq monthly fee statement (0.1); correspond with J. Kuo regarding filing of same (0.1); correspond with notice parties

statement (0.2); call with P. Linsey (NPM) regarding same (0.1) 0.60 1,675.00 1,005.00 09/20/2023 JK21 Electronically file with the court Epiq's August 2023 monthly fee statement 0.30 540.00 162.00 09/22/2023 AB21 Correspond with A. Thorp (Harneys) and

Harneys fee statement 0.10 1,675.00 167.50 09/22/2023 AB21 Review issues and notes to prepare for call with potential tax accountant (0.2); call with

potential tax accountant engagement (0.3) 0.50 1,675.00 837.50 09/22/2023 AEL2 Correspond with P. Linsey (NPM) re: Kroll

09/27/2023 AB21 Call with A. Thorp (Harneys) regarding Harneys fee statement (0.1); call with A.

regarding same (0.4) 0.50 1,675.00 837.50 09/27/2023 AB21 Call with A. Calascibatta (Eisner Amper)

regarding same (0.1) 0.60 1,675.00 1,005.00 09/27/2023 AB21 Call with L. Despins and P. Linsey (NPM) regarding Kroll retention 0.10 1,675.00 167.50 09/27/2023 LAD4 T/c P. Linsey (NPM) & A. Bongartz re: Kroll retention (.10); t/c W. Baldiga (Brown Rudnick) re: request to have fees paid (.40) 0.50 1,975.00 987.50 09/28/2023 AB21 Correspond with P. Linsey (NPM) regarding Kroll retention order 0.10 1,675.00 167.50

Case 22-50073 Doc 2935 Filed 02/19/24 Entered 02/19/24 20:04:06 Page 87 of 779

Date Initials Description Hours Rate Amount

09/29/2023 AB21 Correspond with L. Despins regarding tax accountants (0.4); analyze proposals (0.3); calls with A. Calascibetta (Eisner Amper) regarding proposal and conflicts check (0.3); correspond with A. Calascibetta regarding

regarding same (0.1); correspond with V.

Subtotal: B165 Fee/Employment Applications for

09/01/2023 TS21 Prepare wire form for RIM survey (.3); correspond with L. Despins and A. Bongartz re same (.2) 0.50 1,210.00 605.00

09/07/2023 AB21 Correspond with T. Sadler and L. Despins regarding wire transfer forms 0.10 1,675.00 167.50 09/07/2023 TS21 Prepare wire transfer forms (.5); correspond

bank regarding same (.3) 0.80 1,210.00 968.00 09/12/2023 AB21 Correspond with T. Sadler regarding wire transfers related to fee orders 0.20 1,675.00 335.00 09/12/2023 TS21 Prepare wire transfer forms (.4); correspond

regarding same (.2) 0.60 1,210.00 726.00 09/13/2023 TS21 Correspond with A. Bongartz regarding bank account balances 0.50 1,210.00 605.00 09/22/2023 TS21 Prepare wire form (.2); correspond with L. Despins regarding same (.2) 0.40 1,210.00 484.00 09/25/2023 TS21 Correspond with L. Despins and East West bank re initiating wire 0.20 1,210.00 242.00 09/28/2023 AB21 Correspond with L. Despins regarding upcoming wires and professional fees (0.2);

Case 22-50073 Doc 2935 Filed 02/19/24 Entered 02/19/24 20:04:06 Page 88 of 779

Date Initials Description Hours Rate Amount

09/29/2023 AB21 Correspond with T. Sadler regarding wire

09/29/2023 TS21 Prepare wire transfer forms (1.5);

and East West bank regarding wires (.6); update payment records (1.3) 3.40 1,210.00 4,114.00 Subtotal: B210 Business Operations 7.30 9,251.50 B211 Financial Reports (Monthly Operating Reports)

09/11/2023 DEB4 Correspond with T. Sadler regarding inquiry from U.S. Trustee regarding MOR 0.10 1,360.00 136.00

09/12/2023 TS21 Draft correspondence with U.S. Trustee re monthly operating reports 0.50 1,210.00 605.00 09/19/2023 DEB4 Correspond with T. Sadler regarding MOR

09/19/2023 TS21 Prepare monthly operating report (1.5);

Bank re same (.3) 1.80 1,210.00 2,178.00 09/20/2023 DEB4 Correspond with T. Sadler regarding MOR (0.3); analyze MOR (0.4); correspond with J. Gervais (UST) regarding same (0.1) 0.80 1,360.00 1,088.00 09/20/2023 TS21 Review and revise monthly operating report (.3); correspond with D. Barron and L. Despins regarding monthly operating report

09/21/2023 DM26 File via the Court's CM/ECF system monthly operating report for period ended

09/21/2023 DEB4 Correspond with L. Despins regarding

regarding same (0.1) 0.20 1,360.00 272.00

Case 22-50073 Doc 2935 Filed 02/19/24 Entered 02/19/24 20:04:06 Page 89 of 779

Date Initials Description Hours Rate Amount

09/21/2023 TS21 Correspond with L. Despins, D. Barron and D. Mohamed re monthly operating report 0.40 1,210.00 484.00 Subtotal:

09/05/2023 AB21 Correspond with L. Despins regarding

regarding comments to DIP motion (0.1);

09/06/2023 SM29 Review email from S. Millman (Stroock) re DIP motion (.2); email L. Despins re same

09/08/2023 LK19 Correspond with S. Maza regarding revised

financing order (0.2); draft notice of filing of revised DIP financing order (0.9) 1.30 855.00 1,111.50 09/08/2023 SM29 Correspond with L. Despins re DIP motion (.2); correspond with S. Millman (Stroock) re same (.2); correspond with H. Claiborn (UST) re same (.4); correspond with L.

amended order (.2); prepare same (.3) 1.40 1,360.00 1,904.00 09/11/2023 AB21 Call with S. Maza regarding questions from

regarding same (0.1) 0.60 1,675.00 1,005.00 09/11/2023 JK21 Correspond with S. Maza and L. Koch regarding notice of filing of revised DIP order (0.6); prepare for electronic filing notice of filing of revised DIP order (0.4); electronically file with the court notice of filing of revised DIP order (0.4); review and handle service of notice of filing of revised 1.80 540.00 972.00

Luc Despins as Chapter 11 Trustee in thecase of Ho Wan Kwok 50687-00001 Invoice No. 2375609

Date Initials Description Hours Rate Amount

09/11/2023 LK19 Revise DIP financing order (0.3); revise notice of filing of revised DIP financing order (0.2); correspond with S. Maza and J. Kuo regarding same (0.4) 0.90 855.00 769.50 09/11/2023 SM29 Email L. Despins re DIP motion and notice of revised proposed order (.1); review and finalize same (.4); correspond with J. Kuo and L. Koch re same (.3); correspond with

(Pullman) re same (.3); call with A. Bongartz

09/12/2023 SM29 Call with L. Despins re surcharge issues in

authority re same (.6); email L. Despins re same and proposed order (.3); call with L. Despins and A. Bongartz re proposed order (.1); call with A. Bongartz re open issues in advance of hearing on DIP motion (.1) 1.30 1,360.00 1,768.00 09/28/2023 AB21 Analyze payment tracking under interdebtor DIP financing (0.5); correspond with S. Maza regarding same (0.1); correspond with

regarding same (0.1);

same (0.4); follow-up correspondence with

DIP order and Harneys fees (0.1); analyze

regarding DIP order (0.1) 1.50 1,675.00 2,512.50 09/28/2023 Conference with A. Bongartz and T. Sadler

09/28/2023 TS21 Call with A. Bongartz and

Subtotal: B230 Financing/Cash Collections 13.30 15,725.00

Date Initials Description Hours Rate Amount

B310 Claims Administration and Objections 09/05/2023 JK21 Correspond with S. Maza regarding administrative expense claims 0.40 540.00 216.00 09/06/2023 JK21 Correspond with S. Maza regarding administrative expense claims precedent 0.40 540.00 216.00

regarding partial withdrawal of the motion

proofs of claim (.4); calls with P. Linsey (NPM) about same (.2) 0.60 1,045.00 627.00 Subtotal: B310 Claims Administration and

ID Timekeeper Name Title Hours Rate Fee LAD4 Luc A. Despins Partner 8.80 1,975.00 17,380.00 NAB Nicholas A. Bassett Partner 1.60 1,675.00 2,680.00 AB21 Alex Bongartz Of Counsel 22.50 1,675.00 37,687.50 AEL2 Luft, Avi E. Of Counsel 1.40 1,675.00 2,345.00 KAT2 Katherine A. Traxler Of Counsel 7.20 1,055.00 7,596.00 SM29 Shlomo Maza Associate 4.30 1,360.00 5,848.00 DEB4 Douglass E. Barron Associate 1.50 1,360.00 2,040.00 TS21 Tess Sadler Associate 11.80 1,210.00 14,278.00 ECS1 Ezra C. Sutton Associate 2.50 1,045.00 2,612.50

LK19 Leonie Koch Associate 2.20 855.00 1,881.00 JK21 Jocelyn Kuo Paralegal 6.20 540.00 3,348.00 DM26 David Mohamed Paralegal 69.80 540.00 37,692.00

Date Description Quantity Rate Amount

09/05/2023 Photocopy Charges 388.00 0.08 31.04 09/05/2023 Photocopy Charges 628.00 0.08 50.24 09/08/2023 Photocopy Charges 900.00 0.08 72.00 09/11/2023 Photocopy Charges 2,002.00 0.08 160.16 09/11/2023 Photocopy Charges 278.00 0.08 22.24 09/11/2023 Photocopy Charges 932.00 0.08 74.56 09/18/2023 Photocopy Charges 5,005.00 0.08 400.40 09/20/2023 Photocopy Charges 105.00 0.08 8.40 09/20/2023 Photocopy Charges (Color) 76.00 0.20 15.20 09/26/2023 Photocopy Charges 7,950.00 0.08 636.00 09/28/2023 Photocopy Charges 175.00 0.08 14.00 06/30/2023 Taxi/Ground Transportation - Skyline Credit Ride, Inc. (USD) (JPMSUA); Invoice # 6067353 dated 07/15/2023; Service Type: Car; From/To: Office/Home; Passenger DAVID, Mohamed; Ticket # 180243 dated 06/30/2023 00:55 69.17 07/05/2023 Taxi/Ground Transportation - Skyline Credit Ride, Inc. (USD) (JPMSUA); Invoice # 6067353 dated 07/15/2023; Service Type: Car; From/To: Office/Home; Passenger DAVID, Mohamed; Ticket # 173373 dated 07/05/2023 22:42 57.67 07/10/2023 Taxi/Ground Transportation - Vital Transportation Services, Inc. (USD)(JPMSUA); Invoice # 6067885 dated 07/21/2023; Service Type: Car; From/To: Office/Home, BK; Passenger AVI, Luft; Ticket #

07/11/2023 Taxi/Ground Transportation - Vital Transportation Services, Inc. (USD)(JPMSUA); Invoice # 6067885 dated 07/21/2023; Service Type: Car; From/To: Office/Home Passenger LUC, Despin/Pkg; Ticket

Case 22-50073 Doc 2935 Filed 02/19/24 Entered 02/19/24 20:04:06 Page 93 of 779

Luc Despins as Chapter 11 Trustee in thecase of Ho Wan Page 22

07/11/2023 Taxi/Ground Transportation - Vital Transportation Services, Inc. (USD)(JPMSUA); Invoice # 6067885 dated 07/21/2023; Service Type: Car; From/To: Office/Home, BK; Passenger AVI, Luft; Ticket #

07/25/2023 Taxi/Ground Transportation - Skyline Credit Ride, Inc. (USD) (JPMSUA); Invoice # 6072715 dated 08/15/2023; Service Type: Car; From/To: Office/Home; Passenger DAVID, Mohamed; Ticket # 924358 dated 07/25/2023 23:06 104.74 07/26/2023 Taxi/Ground Transportation - Skyline Credit Ride, Inc. (USD) (JPMSUA); Invoice # 6072715 dated 08/15/2023; Service Type: Car; From/To: Office/Home; Passenger DAVID, Mohamed; Ticket # 924360 dated 07/26/2023 00:00 118.13 07/29/2023 Taxi/Ground Transportation - Skyline Credit Ride, Inc. (USD) (JPMSUA); Invoice # 6072715 dated 08/15/2023; Service Type: Car; From/To: Office/Home; Passenger DAVID, Mohamed; Ticket # 916735*1 dated 07/29/2023 00:30 69.02 08/02/2023 Taxi/Ground Transportation - Skyline Credit Ride, Inc. (USD) (JPMSUA); Invoice # 6075803 dated 08/31/2023; Service Type: Car; From/To: Office/Home; Passenger DAVID, Mohamed; Ticket # 184253 dated 08/02/2023 00:31 69.02 08/08/2023 Taxi/Ground Transportation - Skyline Credit Ride, Inc. (USD) (JPMSUA); Invoice # 6072715 dated 08/15/2023; Service Type: Car; From/To: Office/Home; Passenger DAVID, Mohamed; Ticket # 195964 dated 08/08/2023 01:43 57.67 08/10/2023 Taxi/Ground Transportation - Skyline Credit Ride, Inc. (USD) (JPMSUA); Invoice # 6075803 dated 08/31/2023; Service Type: Car; From/To: Office/Home; Passenger DAVID, Mohamed; Ticket # 924377 dated 08/10/2023 23:42 101.41

Case 22-50073 Doc 2935 Filed 02/19/24 Entered 02/19/24 20:04:06 Page 94 of 779

Luc Despins as Chapter 11 Trustee in thecase of Ho Wan Page 23

08/15/2023 Taxi/Ground Transportation - Skyline Credit Ride, Inc. (USD) (JPMSUA); Invoice # 6075803 dated 08/31/2023; Service Type: Car; From/To: Office/Home; Passenger DAVID, Mohamed; Ticket # 193558 dated 08/15/2023 23:01 57.67

08/30/2023 Taxi/Ground Transportation - Skyline Credit Ride, Inc. (USD) (JPMSUA); Invoice # 6075803 dated 08/31/2023; Service Type: Car; From/To: Office/Home; Passenger DAVID, Mohamed; Ticket # 193579 dated 08/30/2023 23:25 57.67 08/31/2023 Data Base Storage - PS-TD01827; Analyst - Ecklund, Amy USB Thumb Drive; 08/13/23 101.00

09/01/2023 Computer Search (Other) 19.17

09/05/2023 Computer Search (Other) 36.45 09/06/2023 Computer Search (Other) 30.78 09/07/2023 Computer Search (Other) 37.08 09/08/2023 Postage/Express Mail - First Class - US; 51.75 09/08/2023 Computer Search (Other) 14.67

09/11/2023 UPS/Courier Service - UPS (USD)(JPMPCARD); Invoice # 00000A6T163373; 09/11/2023;

Scully Mansukhani LLP; 95 Glastonbury Boulevard; GLASTONBURY, CT 060334412 ;

Luc Despins as Chapter 11 Trustee in thecase of Ho Wan Page 24

09/11/2023 UPS/Courier Service - UPS (USD)(JPMPCARD); Invoice # 00000A6T163373; 09/11/2023; JOHN FREDERICK O'CON; Steptoe & Johnson LLP; 1330 Connecticut Avenue, N.W.; WASHINGTON, DC 200361704 ; 1ZA6T1630190758961 (MAN) 24.39

09/11/2023 Postage/Express Mail - First Class - US; 38.16 09/11/2023 Postage/Express Mail - International; 4.23 09/11/2023 Postage/Express Mail - First Class - US; 49.68 09/11/2023 Postage/Express Mail - First Class - US; 5.58 09/11/2023 Postage/Express Mail - International; 6.71 09/11/2023 Computer Search (Other) 32.85 09/12/2023 Computer Search (Other) 19.26

09/13/2023 Computer Search (Other) 29.79

09/14/2023 Computer Search (Other) 97.29 09/15/2023 Computer Search (Other) 43.38

09/18/2023 Postage/Express Mail - International; 30.85 09/18/2023 Postage/Express Mail - Priority Mail; 50.25 09/18/2023 Postage/Express Mail - Priority Mail; 68.60

09/18/2023 Computer Search (Other) 61.11

09/19/2023 Computer Search (Other) 43.65 09/20/2023 Postage/Express Mail - Priority Mail; Katherine

Luc Despins as Chapter 11 Trustee in thecase of Ho Wan Page 25

09/20/2023 Computer Search (Other) 57.51

09/21/2023 Local - Meals - Shlomo Maza; 09/05/2023; Restaurant: Mama Kitchen ; New York, NY; Dinner; Number of people: 1; Dinner expense while

09/21/2023 Local - Meals - Shlomo Maza; 09/13/2023; Restaurant: Elite Cafe; Flushing, NY; Dinner; Number of people: 1; Dinner expense while

09/21/2023 Computer Search (Other) 41.49 09/22/2023 Computer Search (Other) 57.33 09/25/2023 Computer Search (Other) 11.25 09/26/2023 Computer Search (Other) 14.49 09/27/2023 Postage/Express Mail - First Class - US; 11.45 09/27/2023 Postage/Express Mail - First Class - US; 12.45 09/27/2023 Postage/Express Mail - First Class - US; 13.40 09/27/2023 Postage/Express Mail - First Class - US; 147.00 09/27/2023 Postage/Express Mail - International; 30.55 09/27/2023 Postage/Express Mail - First Class - US; 34.10 09/27/2023 Postage/Express Mail - First Class - US; 50.03 09/27/2023 Computer Search (Other) 22.05

09/28/2023 Postage/Express Mail - International; 3.00 09/28/2023 Postage/Express Mail - First Class - US; 32.40 09/28/2023 Computer Search (Other) 21.51 09/29/2023 Articles and Publications - Liz Elliott; 09/14/2023; Document retrieval requested by E. Sutton - Business entity search.; Merchant: Delaware corp &

09/29/2023 Computer Search (Other) 20.16 09/30/2023 Lexis/On Line Search - Courtlink Use - Charges for

Case 22-50073 Doc 2935 Filed 02/19/24 Entered 02/19/24 20:04:06 Page 97 of 779

Luc Despins as Chapter 11 Trustee in thecase of Ho Wan Page 26

Total Costs incurred and advanced \$6,736.54

Total Balance Due - Due Upon Receipt \$142,466.54

Case 22-50073 Doc 2935 Filed 02/19/24 Entered 02/19/24 20:04:06 Page 98 of 779

PAUL HASTINGS LLP 200 Park Avenue, New York, NY 10166-3205 t: +1.212.318.6000 f: +1.212.319.4090 www.paulhastings.com

Luc Despins as Chapter 11 Trustee in the case of Ho Wan Kwok 200 Park Avenue New York, NY 10166

Attn: Luc Despins PH LLP Tax ID No. 95-2209675

Asset Recovery Investigation and Litigation

PH LLP Client/Matter # 50687-00002 Luc A. Despins

Legal fees for professional services for the period ending September 30, 2023 \$168,701.00

Total Balance Due - Due Upon Receipt \$359,477.05

We encourage our clients to pay via ACH, however, in the event that you pay by check, please send payment to the remittance address below:

*TO PROTECT AGAINST FRAUD, the Firm will not change its wiring instructions via email. We strongly encourage clients to confirm any change in wiring instructions by contacting Teri Goffredo @ 213-683-5045 or via email @ terigoffredo@paulhastings.com and requesting written and verbal confirmation.*

Wiring and ACH Instructions: Remittance Address: Pay by Tranch:

Citibank Paul Hastings LLP You can now pay your invoices online via ABA # 322271724 Lockbox 4803 real-time bank payments, credit cards or SWIFT Address: CITIUS33 PO Box 894803 in installments:

*For wires, please reference the invoice, client and matter number(s) being paid For ACH payments, please use the CTX format and/or send any remittances to cashepn@paulhastings com This is a no-reply mailbox*

Case 22-50073 Doc 2935 Filed 02/19/24 Entered 02/19/24 20:04:06 Page 99 of 779

PAUL HASTINGS LLP 200 Park Avenue, New York, NY 10166-3205 t: +1.212.318.6000 f: +1.212.319.4090 www.paulhastings.com

Luc Despins as Chapter 11 Trustee in the case of Ho Wan Kwok 200 Park Avenue New York, NY 10166

Attn: Luc Despins PH LLP Tax ID No. 95-2209675

Asset Recovery Investigation and Litigation

PH LLP Client/Matter # 50687-00002 Luc A. Despins

Legal fees for professional services for the period ending September 30, 2023 \$168,701.00

Total Balance Due - Due Upon Receipt \$359,477.05

We encourage our clients to pay via ACH, however, in the event that you pay by check, please send payment to the remittance address below:

*TO PROTECT AGAINST FRAUD, the Firm will not change its wiring instructions via email. We strongly encourage clients to confirm any change in wiring instructions by contacting Teri Goffredo @ 213-683-5045 or via email @ terigoffredo@paulhastings.com and requesting written and verbal confirmation.*

Wiring and ACH Instructions: Remittance Address: Pay by Tranch:

Citibank Paul Hastings LLP You can now pay your invoices online via ABA # 322271724 Lockbox 4803 real-time bank payments, credit cards or SWIFT Address: CITIUS33 PO Box 894803 in installments:

*For wires, please reference the invoice, client and matter number(s) being paid For ACH payments, please use the CTX format and/or send any remittances to cashepn@paulhastings com This is a no-reply mailbox*

Case 22-50073 Doc 2935 Filed 02/19/24 Entered 02/19/24 20:04:06 Page 100 of 779

200 Park Avenue, New York, NY 10166-3205 t: +1.212.318.6000 f: +1.212.319.4090 www.paulhastings.com

Luc Despins as Chapter 11 Trustee in the case of Ho November 30, 2023

New York, NY 10166 Invoice Number: 2375610

Attn: Luc Despins PH LLP Tax ID No. 95-2209675

FOR PROFESSIONAL SERVICES RENDERED for the period ending September 30, 2023 Asset Recovery Investigation and Litigation \$168,701.00

Date Initials Description Hours Rate Amount B120 Asset Analysis and Recovery 09/20/2023 LAD4 Review documents, issues, and notes re: UK application (.40); handle call with Pallas (Richardson & de Quincey) re: application to UK court (.30) 0.70 1,975.00 1,382.50 09/22/2023 AB21 Correspond with A. de Quincey (Pallas) regarding background and care package with respect to Ace Decade (0.9); correspond with D. Barron regarding same (0.1); call and correspond with L. Despins regarding same (0.1) 1.10 1,675.00 1,842.50 Subtotal: B120 Asset Analysis and Recovery 1.80 3,225.00 B155 Court Hearings

09/02/2023 ECS1 Correspond with D. Mohamed regarding 0.20 1,045.00 209.00

Date Initials Description Hours Rate Amount

09/04/2023 ECS1 Correspond with D. Mohamed regarding updating agenda for 9/6/23 hearing in the

09/05/2023 ECS1 Correspond with D. Mohamed regarding reference materials for 9/6/23 hearing 0.10 1,045.00 104.50 09/09/2023 ECS1 Correspond with D. Mohamed regarding

in the Kwok case (.3); review draft agenda

09/10/2023 ECS1 Correspond with D. Mohamed regarding

in the Kwok case (.1); review draft agenda

09/11/2023 ECS1 Correspond with D. Mohamed, L. Despins, S. Maza regarding reference materials for 9/12/23 hearing (.6); correspond with A. Bongartz re same (.1) 0.70 1,045.00 731.50 09/11/2023 ECS1 Correspond with L. Despins and D.

(.1); review revised agenda (.1) 0.20 1,045.00 209.00 09/15/2023 ECS1 Correspond with D. Mohamed regarding

case (.1); review draft agenda (.1) 0.20 1,045.00 209.00 09/22/2023 ECS1 Correspond with D. Mohamed regarding

case (.2); review draft agenda (.1) 0.30 1,045.00 313.50 09/29/2023 ECS1 Correspond with D. Mohamed regarding

case (.3); review draft agenda (.2) 0.50 1,045.00 522.50 Subtotal: B155 Court Hearings 2.90 3,030.50

09/07/2023 JK21 Update appeals tracking chart 0.70 540.00 378.00

Case 22-50073 Doc 2935 Filed 02/19/24 Entered 02/19/24 20:04:06 Page 102 of 779

Luc Despins as Chapter 11 Trustee in the case of Ho Wan Kwok 50687-00002 Invoice No. 2375610

Date Initials Description Hours Rate Amount

09/08/2023 DM26 Review and share with working group files pertaining to the 9/7/23 deposition of Yan

09/11/2023 ECS1 Prepare issues/task list re open matters and deadlines in the Kwok bankruptcy case and related adversary proceedings (2.3); correspond with N. Bassett, W. Farmer, and P. Linsey (NPM) regarding same (.2) 2.50 1,045.00 2,612.50 09/11/2023 NAB Correspond with P. Linsey (NPM)

conference issues (.1); call with W. Farmer regarding fact discovery and related case management issues (.2) 0.30 1,675.00 502.50 09/11/2023 WCF Review and revise chapter 11 case issues/task list (.2); correspond with E. Sutton and P. Linsey regarding same (.1) 0.30 1,270.00 381.00 09/11/2023 WCF Call with P. Linsey (NPM) regarding fact discovery work streams (.2); call with N. Bassett regarding same (.2); prepare follow

09/12/2023 DEB4 Correspond with E. Sutton regarding litigation issues/task list 0.10 1,360.00 136.00 09/12/2023 AEL2 Correspond with N. Bassett regarding case planning and strategy 0.50 1,675.00 837.50 09/12/2023 NAB Review litigation issues/task list (.1);

09/13/2023 DM26 Review and share with working group 9/6/23 deposition files of Jie Zhang 0.30 540.00 162.00 09/13/2023 JK21 Update appeals tracking chart 0.80 540.00 432.00 09/14/2023 ECS1 Correspond with N. Bassett, W. Farmer, D. Barron regarding upcoming deadlines in the

connection with same (.2) 0.30 1,045.00 313.50 09/14/2023 LAD4 T/c C. Calamari (Rui Ma counsel) re:

Case 22-50073 Doc 2935 Filed 02/19/24 Entered 02/19/24 20:04:06 Page 103 of 779

Luc Despins as Chapter 11 Trustee in the case of Ho Wan Kwok 50687-00002 Invoice No. 2375610

Date Initials Description Hours Rate Amount

09/18/2023 DM26 Review exhibits from Mei Guo's 9/13/23 deposition for E. Sutton 0.30 540.00 162.00

, J. Kosciewicz, and P.

09/18/2023 JK21 Update appeals tracking chart 0.40 540.00 216.00 09/18/2023 JPK1 Attend teleconference with P. Linsey

litigation issues/task list 0.50 940.00 470.00 09/18/2023 LAD4 T/c A. Luft re: update on various matters

09/18/2023 AEL2 Correspond with P. Linsey (NPM) re: subpoenas to financial institutions (.2); call with L. Despins regarding discovery update

09/18/2023 Prepare parts of litigation issues/task list 0.40 855.00 342.00 09/18/2023 Review NFSC Saturday livestream on

09/18/2023 Call with E. Sutton, J. Kosciewicz and P.

issues/task list and upcoming deadlines 0.50 855.00 427.50 09/22/2023 DEB4 Correspond with N. Bassett regarding Hamilton/Taurus connection (0.1);

Dhabi lawsuit (0.1); correspond with A. Luft regarding alter ego investigation (0.5) 0.70 1,360.00 952.00

and alter ego issues 0.60 1,360.00 816.00 09/22/2023 JK21 Update appeals tracking chart 0.30 540.00 162.00 09/22/2023 JPK1 Correspond with E. Sutton regarding previous attempts to serve N. Savio 0.20 940.00 188.00 09/22/2023 AEL2 Correspond with L. Despins re: potential adversary actions for alter ego claims 0.20 1,675.00 335.00 09/22/2023 AEL2 Correspond with D. Barron re: potential alter ego adversary proceedings 1.60 1,675.00 2,680.00

Date Initials Description Hours Rate Amount

09/22/2023 NAB Correspond with L. Despins regarding general litigation strategy (.2); analyze status of state court GTV litigation and evaluate next steps (.5); correspond with L. Despins regarding same (.1) 0.80 1,675.00 1,340.00 09/25/2023 Prepare issues/task list for pending adversary proceedings 0.30 855.00 256.50 09/25/2023 Call with W. Farmer and P. Linsey (NPM)

regarding open litigation issues/task list 0.40 1,270.00 508.00 09/26/2023 JPK1 Review Mahwah media on Relativity for

regarding the same (.2); correspond with S. Phan (UnitedLex) regarding the same (.3) 0.70 940.00 658.00 09/26/2023 NAB Correspond with A. Luft regarding litigation strategy issues and next steps (.4); review issues/task list in connection with same (.2) 0.60 1,675.00 1,005.00 09/27/2023 ECS1 Follow up correspondence with Esquire in

related transcripts 0.20 1,045.00 209.00 Subtotal: B191 General Litigation 17.90 20,578.50

09/01/2023 AB21 Call with R. Stockil (Yachtzoo) regarding

09/05/2023 AB21 Correspond with L. Despins regarding Yachtzoo management agreement (0.2);

regarding same (0.1) 0.30 1,675.00 502.50 09/11/2023 AB21 Correspond with B. Burke (captain) and D.

status (0.1); analyze insurance re same (0.2) 0.30 1,675.00 502.50

Case 22-50073 Doc 2935 Filed 02/19/24 Entered 02/19/24 20:04:06 Page 105 of 779

Date Initials Description Hours Rate Amount

09/12/2023 AB21 Call with D. Johnson (Edmiston) regarding status update on Lady May II (0.1); call and correspond with L. Despins regarding same

Subtotal: B210 Business Operations 1.10 1,842.50

09/01/2023 DEB4 Correspond with P. Parizek (Kroll) regarding Krasner properties 0.10 1,360.00 136.00 09/01/2023 DEB4 Correspond with P. Linsey (NPM) regarding bank discovery 0.30 1,360.00 408.00

potential investigation target 0.10 1,360.00 136.00 09/02/2023 DEB4 Analyze Mercantile Bank documents 1.40 1,360.00 1,904.00

informant documents 0.40 1,360.00 544.00 09/03/2023 Review NFSC weekly livestream on

09/05/2023 ECS1 Prepare settlement agreement between the

rule 9019 motion (.1); correspond with A. Luft regarding same (.1) 0.20 1,045.00 209.00 09/06/2023 DEB4 Participate in weekly Kroll call with L.

09/06/2023 ECS1 Prepare settlement agreement between the

rule 9019 motion (.3); correspond with A. Luft regarding same (.1) 0.40 1,045.00 418.00 09/06/2023 ECS1 Review information regarding Kwok affiliates and assets, their connections to Kwok, and their corporate information 0.20 1,045.00 209.00 09/06/2023 ECS1 Prepare responses to rule 2004 targets regarding outstanding rule 2004 motions 0.40 1,045.00 418.00

Date Initials Description Hours Rate Amount

09/06/2023 LAD4 Handle Kroll call with D. Barron and Kroll 1.10 1,975.00 2,172.50 09/06/2023 AEL2 Correspond with P. Parizek (Kroll) re:

09/06/2023 AEL2 Revise draft settlement agreement with

09/07/2023 ECS1 Prepare summary email for East West Bank

09/07/2023 ECS1 Prepare responses to rule 2004 targets

09/07/2023 ECS1 Prepare settlement agreement between the

rule 9019 motion (.5); correspond with A. Luft and L. Despins regarding same (.1) 0.60 1,045.00 627.00 09/08/2023 DEB4 Correspond with E. Sutton and regarding vehicle research 0.10 1,360.00 136.00 09/08/2023 ECS1 Review information regarding Kwok affiliates and assets, their connections to Kwok, and their corporate information 0.20 1,045.00 209.00 09/09/2023 ECS1 Prepare settlement agreement between the

rule 9019 motion (.3); correspond with A. Luft and L. Despins regarding same (.1) 0.40 1,045.00 418.00 09/09/2023 AEL2 Review and comment on proposed settlement revisions 0.30 1,675.00 502.50 09/10/2023 ECS1 Review settlement agreement between the

09/10/2023 NAB Correspond with L. Despins regarding

decision on broader case strategy 0.20 1,675.00 335.00 09/11/2023 ECS1 Prepare settlement agreement between the

rule 9019 motion (.3); correspond with A. 0.60 1,045.00 627.00

Date Initials Description Hours Rate Amount

09/11/2023 ECS1 Prepare correspondence to rule 2004 targets

09/11/2023 ECS1 Review information regarding Kwok affiliates and assets, their connections to Kwok, and their corporate information 0.20 1,045.00 209.00 09/12/2023 DEB4 Correspond with P. Linsey (NPM) regarding bank documents 0.30 1,360.00 408.00 09/12/2023 DEB4 Correspond with P. Linsey (NPM) regarding Bank of Princeton 0.10 1,360.00 136.00 09/12/2023 ECS1 Review information regarding Kwok affiliates and assets, their connections to Kwok, and their corporate information 0.20 1,045.00 209.00 09/12/2023 ECS1 Review issues and prepare notes for meet

counsel to Defeng Cao, regarding rule 2004 subpoenas (1.1); correspond with L.

regarding same (.2) 1.40 1,045.00 1,463.00 09/12/2023 ECS1 Correspond with A. Luft regarding

and the Casper Firm and related rule 9019

09/12/2023 AEL2 Review draft settlement agreement re Clark

09/13/2023 DEB4 Correspond with P. Linsey (NPM) and E. Sutton regarding Sterling National Bank 0.10 1,360.00 136.00 09/13/2023 ECS1 Prepare list of potential targets and descriptions of same for the next Rule 2004

09/13/2023 ECS1 Meet and confer with Kat Mateo (Olshan), counsel to Defeng Cao, in connection with

documents and issues regarding same (.3);

(.2); prepare follow up email to Kat Mateo 1.80 1,045.00 1,881.00

Date Initials Description Hours Rate Amount

09/13/2023 ECS1 Prepare responses to rule 2004 targets

09/13/2023 ECS1 Analyze information regarding Kwok affiliates and assets, their connections to Kwok, and their corporate information 0.30 1,045.00 313.50 09/13/2023 AEL2 Call with N. Bassett re: Kroll forensic

09/13/2023 AEL2 Draft proposed work plan for Kroll forensic investigation 1.10 1,675.00 1,842.50 09/13/2023 NAB Call with A. Luft regarding next steps in Kroll financial investigation 0.40 1,675.00 670.00 09/14/2023 DM26 Research regarding certain rule 2004 targets and their registered agents 1.10 540.00 594.00 09/14/2023 DEB4 Call with L. Despins, N. Bassett and A. Luft regarding Kroll forensic analysis in Kwok

09/14/2023 DEB4 Correspond with L. Despins regarding tipster information 0.10 1,360.00 136.00 09/14/2023 DEB4 Participate in Kroll call with L. Despins, N.

additional matters, and next steps 0.90 1,360.00 1,224.00 09/14/2023 DEB4 Analyze documents related to Kroll analysis 0.30 1,360.00 408.00 09/14/2023 DEB4 Correspond with L. Despins regarding bank

09/14/2023 ECS1 Analyze information regarding Kwok affiliates and assets, their connections to Kwok, and their corporate information 0.50 1,045.00 522.50 09/14/2023 IC Research good standing and corporate status for Sterling Bancorp 0.30 400.00 120.00 09/14/2023 JK21 Correspond with E. Sutton regarding

09/14/2023 JK21 Research regarding Sterling National Bank and Sterling Bancorp 0.40 540.00 216.00

Case 22-50073 Doc 2935 Filed 02/19/24 Entered 02/19/24 20:04:06 Page 109 of 779

Luc Despins as Chapter 11 Trustee in the case of Ho Wan Kwok 50687-00002 Invoice No. 2375610

Date Initials Description Hours Rate Amount

09/14/2023 LAD4 Review/comment on Kroll tasks (1.30); t/c

(.50); weekly call with Kroll, A. Luft, N.

bank accounts (.90) 3.60 1,975.00 7,110.00 09/14/2023 AEL2 Analyze counter proposal from Casper Firm on the settlement 0.50 1,675.00 837.50 09/14/2023 AEL2 Meeting with Kroll, L. Despins, N. Bassett,

09/14/2023 AEL2 Call with L. Despins, N. Bassett and D. Barron re: Kroll issues/task list 0.50 1,675.00 837.50 09/14/2023 NAB Call with Kroll, L. Despins, A. Luft, and D. Barron regarding forensic investigation and

regarding same (.1); call with L. Despins, D. Barron, and A. Luft regarding same (.5); correspond with A. Luft regarding same (.2) 1.70 1,675.00 2,847.50 09/17/2023 DEB4 Correspond with A. Lomas regarding Bento

09/18/2023 DEB4 Conference with A. Luft and E. Sutton

09/18/2023 DEB4 Correspond with P. Linsey (NPM) regarding bank discovery 0.20 1,360.00 272.00 09/18/2023 DEB4 Correspond with P. Parizek (Kroll) regarding London property 0.30 1,360.00 408.00 09/18/2023 ECS1 Call with A. Luft, D. Barron, and P. Linsey

connection with Defeng Cao 0.50 1,045.00 522.50 09/18/2023 ECS1 Prepare responses to rule 2004 targets

09/18/2023 JK21 Correspond with A. Bongartz regarding orders holding parties in contempt 0.70 540.00 378.00

Date Initials Description Hours Rate Amount

09/18/2023 AEL2 Call with E. Sutton, P. Linsey (NPM) and

09/19/2023 DEB4 Correspond with P. Parizek (Kroll) regarding Cirrus aircraft 0.20 1,360.00 272.00 09/19/2023 DEB4 Correspond with L. Despins regarding tipster information 0.10 1,360.00 136.00

09/19/2023 DEB4 Correspond with A. Comes (Kroll) regarding Bento analysis 0.10 1,360.00 136.00 09/19/2023 ECS1 Analyze equitable ownership standard in the Second Circuit (.1); correspond with A. Bongartz regarding same (.1) 0.20 1,045.00 209.00 09/19/2023 ECS1 Prepare correspondence to rule 2004 targets

09/19/2023 JK21 Correspond with E. Sutton, S. Phan

document production 0.60 540.00 324.00 09/20/2023 DEB4 Correspond with J. Barker (Kroll) regarding

09/20/2023 DEB4 Correspond with L. Despins and regarding tipster information 0.20 1,360.00 272.00 09/20/2023 ECS1 Review and summarize documents produced in response to Rule 2004 requests 0.10 1,045.00 104.50 09/20/2023 ECS1 Correspond and call with P. Linsey (NPM)

supplemental rule 2004 motion 0.40 1,045.00 418.00

Case 22-50073 Doc 2935 Filed 02/19/24 Entered 02/19/24 20:04:06 Page 111 of 779

Luc Despins as Chapter 11 Trustee in the case of Ho Wan Kwok 50687-00002 Invoice No. 2375610

Date Initials Description Hours Rate Amount

09/20/2023 ECS1 Meet and confer call with P. Linsey (NPM) and J. Nealon, counsel to Yongbing Zhang,

production obligations (.9); review issues and authority regarding same (.2); follow up

same (.3); correspond with A. Luft and D. Barron regarding same (.5) 1.90 1,045.00 1,985.50 09/20/2023 ECS1 Analyze information regarding Kwok affiliates and assets, their connections to Kwok, and their corporate information 0.30 1,045.00 313.50 09/20/2023 JK21 Correspond with S. Phan (UnitedLex) regarding new document production 3.20 540.00 1,728.00 09/20/2023 LAD4 T/c J. Manning & M. Fergenson (DOJ) re: discovery request of Kwok (.20); t/c A. Luft re: depo of Defeng Cao (.30) 0.50 1,975.00 987.50 09/20/2023 AEL2 Correspond with E. Sutton and D. Barron

(.1); call with L. Despins regarding Defeng Cao deposition (.3) 0.40 1,675.00 670.00 09/20/2023 Review ACASS production on transfer of

diligence and tipster communications 0.20 1,675.00 335.00 09/21/2023 DEB4 Correspond with E. Sutton regarding additional rule 2004 targets 0.20 1,360.00 272.00 09/21/2023 DEB4 Participate in Kroll call with L. Despins, N.

forensic investigation of Kwok matters and

09/21/2023 ECS1 Review and summarize documents produced in response to rule 2004 requests 0.20 1,045.00 209.00 09/21/2023 ECS1 Correspond with P. Linsey (NPM) and A.

rule 2004 subpoena production obligations 0.20 1,045.00 209.00

Date Initials Description Hours Rate Amount

09/21/2023 ECS1 Prepare list of potential targets and descriptions of same for the next Rule 2004

09/21/2023 ECS1 Prepare responses to rule 2004 targets

09/21/2023 ECS1 Review information regarding Kwok affiliates and assets, their connections to Kwok, and their corporate information 0.20 1,045.00 209.00 09/21/2023 ECS1 Correspond and call with P. Linsey (NPM)

supplemental rule 2004 motion (.3); review and comment on service of subpoenas (.6); prepare cover letters to rule 2004 targets

subpoenas in connection with the sixth rule 2004 motion (.1); correspond with E. Cohn

September 2023 grand jury subpoena (.5);

09/21/2023 LAD4 Review banking documents, issues in prep for Kroll call (.90); handle weekly call with Kroll, A. Luft, D. Barron, N. Bassett (.70) 1.60 1,975.00 3,160.00 09/21/2023 AEL2 Correspond with E. Sutton re: follow up with Defeng Cao's counsel re: discovery 0.30 1,675.00 502.50 09/21/2023 AEL2 Call with Kroll, L. Despins, N. Bassett, D. Barron regarding forensic analysis and next

09/21/2023 NAB Participate in call with L. Despins, A. Luft,

investigation updates 0.70 1,675.00 1,172.50

Date Initials Description Hours Rate Amount

09/22/2023 DM26 Prepare cover letters with regards to subpoenas of rule 2004 targets (1.2); research regarding certain rule 2004 targets and related information on registered agents

09/22/2023 DEB4 Correspond with A. Luft regarding investigation strategy 0.70 1,360.00 952.00 09/22/2023 DEB4 Conference with P. Linsey (NPM) regarding bank discovery (0.4); correspond with E. Sutton regarding rule 2004 targets (0.1) 0.50 1,360.00 680.00 09/22/2023 ECS1 Review and comment on service of

supplemental rule 2004 motion 1.00 1,045.00 1,045.00 09/22/2023 ECS1 Prepare responses to rule 2004 targets

09/22/2023 ECS1 Analyze information regarding Kwok affiliates and assets, their connections to Kwok, and their corporate information 0.30 1,045.00 313.50 09/22/2023 AEL2 Correspond with E. Sutton re: Defeng Cao rule 2004 discovery issues 0.40 1,675.00 670.00

information on funding 0.20 1,675.00 335.00 09/22/2023 Phone call with D. Barron regarding Kwok related entities and potential alter ego claims 0.60 855.00 513.00 09/22/2023 Review information on Jingrui Brennan who paid Kwok's law firm 0.30 855.00 256.50

of Debtor attorney fee payments 0.20 1,675.00 335.00 09/22/2023 YH7 Research background regarding Nicholas

09/23/2023 Review NFSC Saturday livestream 1.40 855.00 1,197.00 09/25/2023 DEB4 Correspond with E. Sutton regarding bank

Case 22-50073 Doc 2935 Filed 02/19/24 Entered 02/19/24 20:04:06 Page 114 of 779

Luc Despins as Chapter 11 Trustee in the case of Ho Wan Kwok 50687-00002 Invoice No. 2375610

Date Initials Description Hours Rate Amount

09/26/2023 DM26 Research regarding certain Rule 2004 targets

supplemental rule 2004 motion 3.60 540.00 1,944.00 09/26/2023 DEB4 Correspond with E. Sutton regarding bank

09/26/2023 ECS1 Prepare responses to rule 2004 targets

09/26/2023 ECS1 Analyze information regarding Kwok affiliates and assets, their connections to Kwok, and their corporate information 0.40 1,045.00 418.00 09/26/2023 ECS1 Review and comment on service of

supplemental rule 2004 motion 0.20 1,045.00 209.00 09/26/2023 ECS1 Correspond with J. Nealon, counsel to

2004 subpoena production obligations 0.10 1,045.00 104.50 09/26/2023 ECS1 Review bank account documents in preparation for conference with Kroll (.1);

(NPM) regarding forensic tracing of Debtor related bank accounts (.5); follow up review of issues discussed (.1); correspond with D.

correspondence with Kroll regarding tracing of bank accounts (.2) 1.10 1,045.00 1,149.50 09/26/2023 ECS1 Review and summarize documents produced in response to discovery requests 0.20 1,045.00 209.00 09/26/2023 ECS1 Correspond with J. Kuo regarding Debtor related bank account spreadsheet 0.20 1,045.00 209.00 09/26/2023 ECS1 Prepare seventh supplemental Rule 2004 discovery motion (2.2); call with P. Linsey

09/26/2023 AEL2 Revise draft settlement documents re:

Date Initials Description Hours Rate Amount

09/26/2023 AEL2 Correspond with G. Leibowitz re: potential settlement with Casper Firm 0.70 1,675.00 1,172.50 09/26/2023 Review information on the NFSC west

09/26/2023 Review four videos shared by informant 0.70 855.00 598.50 09/27/2023 DM26 Prepare for deposition of Defeng Cao 0.20 540.00 108.00

09/27/2023 DEB4 Correspond with E. Sutton regarding rule

09/27/2023 DEB4 Correspond with E. Sutton regarding Brown Rudnick documents (0.4);

Relativity issues (0.2) 0.60 1,360.00 816.00 09/27/2023 ECS1 Meet and confer with J. Sherman in

documents (.5); call with P. Linsey (NPM)

correspondence with D. Barron and P. Linsey regarding same (.2) 0.80 1,045.00 836.00 09/27/2023 ECS1 Prepare rule 2004 motion in connection with Gypsy Mei entities 0.80 1,045.00 836.00 09/27/2023 ECS1 Prepare parts of Debtor related bank account spreadsheet (.2); correspond with Kroll regarding same (.1) 0.30 1,045.00 313.50 09/27/2023 ECS1 Prepare responses to rule 2004 targets

and subpoenas (.5); correspond with A. Luft re same (.1) 0.60 1,045.00 627.00 09/27/2023 ECS1 Review and summarize documents in connection with the deposition of W.

regarding same (.2) 1.40 1,045.00 1,463.00

Case 22-50073 Doc 2935 Filed 02/19/24 Entered 02/19/24 20:04:06 Page 116 of 779

Luc Despins as Chapter 11 Trustee in the case of Ho Wan Kwok 50687-00002 Invoice No. 2375610

Date Initials Description Hours Rate Amount

09/27/2023 ECS1 Prepare settlement agreement between the Trustee and the Casper Firm and the related rule 9019 motion 1.20 1,045.00 1,254.00 09/27/2023 ECS1 Correspond with K. Mateo (Olshan),

obligations and deposition (.9); call with A. Luft regarding same (.1) 1.00 1,045.00 1,045.00 09/27/2023 ECS1 Prepare documents for deposition of

09/27/2023 ECS1 Call with First Abu Dhabi Bank regarding rule 2004 subpoena (.4); review issues and

09/27/2023 ECS1 Prepare seventh supplemental Rule 2004

09/27/2023 JK21 Prepare bank account spreadsheet for Kroll 1.30 540.00 702.00 09/27/2023 AEL2 Settlement negotiation with G. Leibowitz

09/27/2023 AEL2 Review open issues and prepare notes for meet and confer with G. Leibowitz 0.40 1,675.00 670.00 09/27/2023 AEL2 Call with E. Sutton regarding Defeng Cao

09/27/2023 AEL2 Revise correspondence re: Defeng Cao

09/27/2023 Review NFSC videos sent from informant 0.20 855.00 171.00 09/28/2023 DM26 Research regarding rule 2004 targets and information regarding service and registered

09/28/2023 DEB4 Attend call regarding Kroll investigative update and next steps with Kroll, L. Despins, N. Bassett, A. Luft 0.80 1,360.00 1,088.00 09/28/2023 DEB4 Correspond with P. Linsey (NPM) regarding preference issues 0.20 1,360.00 272.00

Case 22-50073 Doc 2935 Filed 02/19/24 Entered 02/19/24 20:04:06 Page 117 of 779

Luc Despins as Chapter 11 Trustee in the case of Ho Wan Kwok 50687-00002 Invoice No. 2375610

Date Initials Description Hours Rate Amount

09/28/2023 ECS1 Call with A. Luft regarding supplemental rule 2004 discovery motion (.2); correspond with A. Luft and P. Linsey (NPM) regarding

09/28/2023 ECS1 Prepare list of entities that defaulted in connection with their rule 2004 discovery obligations (.5); correspond with D. Barron regarding same (.1) 0.60 1,045.00 627.00 09/28/2023 ECS1 Review and summarize documents produced in response to rule 2004 requests

09/28/2023 ECS1 Review filings and discovery documents

regarding same (.1) 0.20 1,045.00 209.00 09/28/2023 ECS1 Review transcript of deposition of S.

Rudnick deposition (1.1); prepare summary of same for L. Despins and A. Luft (.4) 1.50 1,045.00 1,567.50 09/28/2023 ECS1 Prepare parts of outline for deposition of

09/28/2023 ECS1 Prepare follow up notes regarding call with

09/28/2023 ECS1 Review and summarize known bank account information in connection with rule 2004 bank discovery (.8); correspond with P. Linsey (NPM) regarding same (.2) 1.00 1,045.00 1,045.00 09/28/2023 ECS1 Correspond with R. Jareck (Cole Schotz) re HCHK Entities' bank statements and J. Sherman's documents 0.50 1,045.00 522.50 09/28/2023 JK21 Review and index certain Kwok evidence 1.60 540.00 864.00 09/28/2023 LAD4 Review civil RICO issues 2.90 1,975.00 5,727.50 09/28/2023 LAD4 Review Kroll findings and prepare notes re next steps in Kroll analysis (.40); handle call with Kroll, D. Barron, N. Bassett, A. Luft

Date Initials Description Hours Rate Amount

09/28/2023 AEL2 Correspond with E. Sutton re: questions on Kindseth testimony 0.20 1,675.00 335.00 09/28/2023 AEL2 Analyze Kwok counsel coordination re: potential claims 0.70 1,675.00 1,172.50 09/28/2023 AEL2 Meeting with Kroll, L. Despins, N. Bassett,

update and next steps 0.80 1,675.00 1,340.00 09/28/2023 AEL2 Correspond with G. Leibowitz re: revised draft of Casper Firm settlement agreement 0.30 1,675.00 502.50 09/28/2023 AEL2 Prepare parts of additional rule 2004 requests and motion (.8); correspond with

(.1); call with E. Sutton re: same (.2) 1.10 1,675.00 1,842.50 09/28/2023 AEL2 Analyze and comment on requests for documents from M. Guo 0.80 1,675.00 1,340.00 09/28/2023 Review Kwok social media posts 0.80 855.00 684.00 09/28/2023 Prepare vendor list (0.6); correspond with J. Kuo re the same (0.2) 0.80 855.00 684.00 09/28/2023 Correspond with informant regarding

09/28/2023 Correspond with separate informant regarding Kwok matters 0.30 855.00 256.50 09/28/2023 Correspond with E. Sutton re rule 2004

09/28/2023 NAB Meeting with L. Despins, A. Luft, D. Barron, and Kroll regarding investigation

09/29/2023 DM26 Research rule 2004 targets and information regarding service and registered agents 1.60 540.00 864.00 09/29/2023 DEB4 Conference with P. Linsey (NPM) regarding preference issues 0.80 1,360.00 1,088.00 09/29/2023 ECS1 Review information regarding Kwok affiliates and assets, their connections to Kwok, and their corporate information 0.30 1,045.00 313.50

Luc Despins as Chapter 11 Trustee in the case of Ho Wan Kwok 50687-00002 Invoice No. 2375610

Date Initials Description Hours Rate Amount

09/29/2023 ECS1 Review filings and discovery documents

regarding same (.2) 0.90 1,045.00 940.50 09/29/2023 ECS1 Review and summarize documents produced in response to rule 2004 requests 0.10 1,045.00 104.50 09/29/2023 ECS1 Prepare seventh supplemental Rule 2004

production (3.3); correspond with A. Luft and P. Linsey (NPM) regarding same (.4) 3.70 1,045.00 3,866.50 09/29/2023 ECS1 Correspond and call with R. Jareck (Cole Schotz), as counsel to the Assignee for the

requests of J. Sherman (.6); call with A. Luft regarding same (.2); correspond with J. Sherman regarding same (.2) 1.00 1,045.00 1,045.00 09/29/2023 JK21 Continue reviewing/indexing Kwok

09/29/2023 KC27 Correspond with D. Barron regarding precedent for bringing alter ego actions in conjunction with fraudulent transfer 0.30 940.00 282.00 09/29/2023 AEL2 Correspond with E. Sutton re: J. Sherman rule 2004 discovery (.2); call with E. Sutton

09/29/2023 Review vendor list in connection with Kwok business dealings 0.20 855.00 171.00 09/29/2023 Review documents for rule 2004 subpoenas

09/29/2023 Correspond with informant regarding

09/30/2023 Review social media posts regarding Kwok related persons and entities 1.00 855.00 855.00 Subtotal: B261 Investigations 122.90 140,024.50

Luc Despins as Chapter 11 Trustee in the case of Ho Wan Kwok 50687-00002 Invoice No. 2375610

ID Timekeeper Name Title Hours Rate Fee

LAD4 Luc A. Despins Partner 12.00 1,975.00 23,700.00 NAB Nicholas A. Bassett Partner 6.10 1,675.00 10,217.50 AB21 Alex Bongartz Of Counsel 2.20 1,675.00 3,685.00 AEL2 Luft, Avi E. Of Counsel 17.60 1,675.00 29,480.00 DEB4 Douglass E. Barron Associate 14.70 1,360.00 19,992.00 WCF Will C. Farmer Associate 1.30 1,270.00 1,651.00 ECS1 Ezra C. Sutton Associate 49.20 1,045.00 51,414.00 JPK1 Jon P. Kosciewicz Associate 2.10 940.00 1,974.00 KC27 Kristin Catalano Associate 0.30 940.00 282.00

JK21 Jocelyn Kuo Paralegal 14.40 540.00 7,776.00 DM26 David Mohamed Paralegal 12.70 540.00 6,858.00

Date Description Quantity Rate Amount

03/21/2023 Articles and Publications - United Corporate Services Inc., Invoice# P1118047 Dated 03/21/23, Document retrieval - ELESOFT Trade Inc, and obtain New York state plain copies requested for 70.00 05/30/2023 Court Reporting Services - Esquire Deposition Solutions, LLC, Invoice# INV2495869 Dated 05/30/23, Videographer for 5/23/2023 Deposition

Case 22-50073 Doc 2935 Filed 02/19/24 Entered 02/19/24 20:04:06 Page 121 of 779

Luc Despins as Chapter 11 Trustee in the case of Ho Wan Page 22

07/18/2023 Taxi/Ground Transportation - Vital Transportation Services, Inc. (USD)(JPMSUA); Invoice # 6069295 dated 07/28/2023; Service Type: Car; From/To: office/home; Passenger LUFT, AVI; Ticket #

07/20/2023 Court Reporting Services - Esquire Deposition Solutions, LLC, Invoice# INV2536297 Dated

deposition and additional overtime – Matthew

08/14/2023 Taxi/Ground Transportation - Vital Transportation Services, Inc. (USD)(JPMSUA); Invoice # 6074547 dated 08/25/2023; Service Type: Car; From/To: Office/Home; Passenger AVI, LUFT; Ticket #

08/21/2023 Attorney Service - Metro Attorney Service Inc., Invoice# 39493 Dated 08/21/23, The service of subpoenas on Saraca Media Group, GtV Media

08/21/2023 Attorney Service - Metro Attorney Service Inc., Invoice# 39483 Dated 08/21/23, Service on GTV Media Group and Saraca Media Group of Court's

08/21/2023 Computer Search (Other) 15.57 08/31/2023 Electronic Document Retrieval - Lexisnexis Risk Data Management, Invoice# 1012761-20230831 Dated 08/31/23, Accurint billling usage for

08/31/2023 UnitedLex Invoices - Unitedlex Corp, Invoice# 089436 Dated 08/31/23, UnitedLex – DSAI August 2023 Charges – Outside Professional Services 150,939.61 09/01/2023 Electronic Document Retrieval - TransUnion Risk and Alternative Data Solutions, Inc., Invoice# 1047352-202308-1 Dated 09/01/23, TLO Charges for August 01, 2023 - August 31, 2023 - TruLookup Person Search/Comprehensive Report. 50.00

Luc Despins as Chapter 11 Trustee in the case of Ho Wan Page 23

09/06/2023 Local - Meals - Grubhub Holdings Inc. f/k/a Seamlessweb (USD) (JPMSUA); Invoice # SL-190- 76 dated 09/10/2023; NY Reception; A. Luft, D.

C. Pickens on behalf of D. Mohamed. NY 3 person lunch (Sherwood) for Deposition re: HCHK in 30- 100 The Heights. C/M: 50687-00002 . Meeting date

09/06/2023 Travel Expense - Parking - Luc Despins;

09/06/2023 Travel Expense - Parking - Luc Despins;

09/06/2023 Travel Expense - Parking - Luc Despins;

09/14/2023 UPS/Courier Service - Metro Attorney Service Inc., Invoice# 39707 Dated 09/14/23, service of subpoenas on Gypsy Mei Food Services, LLC 350.00 09/14/2023 UPS/Courier Service - Metro Attorney Service Inc., Invoice# 39709 Dated 09/14/23, service of subpoenas on Gypsy Mei Food Services, LLC . 425.00

Luc Despins as Chapter 11 Trustee in the case of Ho Wan Page 24

09/23/2023 Attorney Service - Metro Attorney Service Inc., Invoice# 39802 Dated 09/23/23, service of subpoenas on Victor Cerda and V.X. Cerda &

09/25/2023 Attorney Service - Metro Attorney Service Inc., Invoice# 39810 Dated 09/25/23, The service of subpoenas on Saraca Media Group, GtV Media

09/29/2023 Outside Professional Services - David Mohamed; 09/14/2023; DE-SOS Status Report-GYPSY MEI FOOD SERVICES LLC; Merchant: Delaware corp

09/29/2023 Outside Professional Services - David Mohamed;

FINANCIAL CORPORATION; Merchant:

09/29/2023 Outside Professional Services - David Mohamed;

FINANCIAL CORPORATION; Merchant:

09/29/2023 Outside Professional Services - David Mohamed;

SPRING (NEW YORK) LTD.; Merchant:

09/29/2023 Outside Professional Services - David Mohamed; 09/22/2023; Cert. of incorporation purchased for Savio Law LLC from NJ Dept. of Treasury;

Case 22-50073 Doc 2935 Filed 02/19/24 Entered 02/19/24 20:04:06 Page 124 of 779

Luc Despins as Chapter 11 Trustee in the case of Ho Wan Page 25

Total Balance Due - Due Upon Receipt \$359,477.05

Total Costs incurred and advanced \$190,776.05 09/30/2023 Lexis/On Line Search - Courtlink Use - Charges for

09/30/2023 UnitedLex Invoices - Unitedlex Corp, Invoice#

September 2023 Charges – Outside Professional

09/29/2023 Vendor Expense - David Mohamed; 09/28/2023; payment verifications for status searches performed for G Club Holdco I, LLC on the DE-SOS website for processing; Merchant: Delaware Corp & Tax Web Location: 302-739-3073, DE 19901-0000 , Statement Date: 09/29/2023, Post Date: 09/29/2023; Other; payment verifications for status

09/29/2023 Vendor Expense - David Mohamed; 09/26/2023; payment verifications for status searches performed for (i) Standard Chartered International (USA) LLC; Merchant: Delaware Corp & Tax Web Location: 302-739-3073, DE 19901-0000 , Statement Date: 09/29/2023, Post Date: 09/27/2023; Other; payment verifications for status searche 20.00

Luc Despins as Chapter 11 Trustee in the case of Ho Wan Kwok 200 Park Avenue New York, NY 10166

Attn: Luc Despins PH LLP Tax ID No. 95-2209675

Other Litigation PH LLP Client/Matter # 50687-00003 Luc A. Despins

Legal fees for professional services for the period ending September 30, 2023 \$326,761.00

Total Balance Due - Due Upon Receipt \$326,906.01

We encourage our clients to pay via ACH, however, in the event that you pay by check, please send payment to the remittance address below:

*TO PROTECT AGAINST FRAUD, the Firm will not change its wiring instructions via email. We strongly encourage clients to confirm any change in wiring instructions by contacting Teri Goffredo @ 213-683-5045 or via email @ terigoffredo@paulhastings.com and requesting written and verbal confirmation.*

Wiring and ACH Instructions: Remittance Address: Pay by Tranch:

Citibank Paul Hastings LLP You can now pay your invoices online via ABA # 322271724 Lockbox 4803 real-time bank payments, credit cards or SWIFT Address: CITIUS33 PO Box 894803 in installments:

*For wires, please reference the invoice, client and matter number(s) being paid For ACH payments, please use the CTX format and/or send any remittances to cashepn@paulhastings com This is a no-reply mailbox*

Luc Despins as Chapter 11 Trustee in the case of Ho Wan Kwok 200 Park Avenue New York, NY 10166

Attn: Luc Despins PH LLP Tax ID No. 95-2209675

Other Litigation PH LLP Client/Matter # 50687-00003 Luc A. Despins

Legal fees for professional services for the period ending September 30, 2023 \$326,761.00

Total Balance Due - Due Upon Receipt \$326,906.01

We encourage our clients to pay via ACH, however, in the event that you pay by check, please send payment to the remittance address below:

*TO PROTECT AGAINST FRAUD, the Firm will not change its wiring instructions via email. We strongly encourage clients to confirm any change in wiring instructions by contacting Teri Goffredo @ 213-683-5045 or via email @ terigoffredo@paulhastings.com and requesting written and verbal confirmation.*

Wiring and ACH Instructions: Remittance Address: Pay by Tranch:

Citibank Paul Hastings LLP You can now pay your invoices online via ABA # 322271724 Lockbox 4803 real-time bank payments, credit cards or SWIFT Address: CITIUS33 PO Box 894803 in installments:

*For wires, please reference the invoice, client and matter number(s) being paid For ACH payments, please use the CTX format and/or send any remittances to cashepn@paulhastings com This is a no-reply mailbox*

Case 22-50073 Doc 2935 Filed 02/19/24 Entered 02/19/24 20:04:06 Page 127 of 779

PAUL HASTINGS LLP 200 Park Avenue, New York, NY 10166-3205 t: +1.212.318.6000 f: +1.212.319.4090 www.paulhastings.com

Luc Despins as Chapter 11 Trustee in the case of Ho November 30, 2023

New York, NY 10166 Invoice Number: 2375611

Attn: Luc Despins PH LLP Tax ID No. 95-2209675

FOR PROFESSIONAL SERVICES RENDERED for the period ending September 30, 2023

Date Initials Description Hours Rate Amount

09/01/2023 DEB4 Analyze case law related to injunctions (0.9); call with N. Bassett regarding same (0.1) 1.00 1,360.00 1,360.00 09/01/2023 ECS1 Prepare emergency motion to enjoin

(1.0); correspond with N. Bassett and P. Linsey (NPM) regarding same (.2); analyze case law regarding ability of non-bankruptcy court to enjoin bankruptcy court (.3) 1.50 1,045.00 1,567.50 09/01/2023 ECS1 Review case findings regarding the standard for an automatic stay in the Second Circuit (.1); correspond with D. Barron re same (.1) 0.20 1,045.00 209.00 09/01/2023 JK21 Review Kwok criminal case and appeals for new filings for L. Despins 0.20 540.00 108.00 09/01/2023 KC27 Analyze procedures for submitting letter in district court (1.4); correspond with N.

Case 22-50073 Doc 2935 Filed 02/19/24 Entered 02/19/24 20:04:06 Page 128 of 779

Luc Despins as Chapter 11 Trustee in the case of Ho Wan Kwok 50687-00003 Invoice No. 2375611

Date Initials Description Hours Rate Amount

09/01/2023 LAD4 Review cases re: automatic stay and criminal matters (1.30); t/c N. Bassett re: same (.20);

motion & motion to expedite (1.60) 3.10 1,975.00 6,122.50 09/01/2023 NAB Review and revise draft motion to enjoin criminal court stay motion (1.8); analyze case law and statutory authority regarding

regarding strategy related to same (.2);

(.1); review motion to expedite and related documents (.2); correspond with P. Friedman (OMM) regarding same (.3); calls

criminal court stay motion (.2); call with D. Barron regarding same (.1) 4.40 1,675.00 7,370.00 09/02/2023 LAD4 Review/edit letter to Judge Torres 1.10 1,975.00 2,172.50 09/02/2023 ML30 Correspond with N. Bassett re criminal case filing (.5); research filing procedures for SDNY criminal court (.8); draft notice of

criminal court (.4); advise N. Bassett of

09/02/2023 NAB Correspond with district court regarding motion to stay chapter 11 cases 0.30 1,675.00 502.50 09/03/2023 DEB4 Conference with S. Maza regarding injunction issue related to debtor's motion

09/03/2023 NAB Draft letter to district court regarding motion to stay appeals (.5); correspond with L. Despins regarding same (.2); correspond with M. Laskowski regarding filing of same (.3); analyze authority related to same (.3) 1.30 1,675.00 2,177.50 09/03/2023 SM29 Correspond with L. Despins re Individual

chapter 11 cases (.1); analyze case law re

same (.3); call with D. Barron re same (.2) 1.10 1,360.00 1,496.00

Date Initials Description Hours Rate Amount

09/04/2023 DEB4 Correspond with S. Maza regarding criminal

09/04/2023 SM29 Email L. Despins re motion in criminal court to stay case 0.30 1,360.00 408.00 09/05/2023 DEB4 Correspond with S. Maza regarding motion to stay bankruptcy case 0.40 1,360.00 544.00 09/05/2023 JK21 Review Kwok criminal case and appeals for new filings for L. Despins 0.20 540.00 108.00 09/05/2023 JK21 Correspond with N. Bassett and the SDNY court regarding ECF filing of a letter in

09/05/2023 LAD4 Review/edit joinder of our injunction

PAX/Committee (.60); review case law re:

09/05/2023 SM29 Analyze case law and statutory authority in

motion and related letter (4.4); correspond

(.5); review Committee joinder (.6); email L.

authority re Individual Debtor's stay motion (1.2); email L. Despins re same (.5) 7.30 1,360.00 9,928.00 09/06/2023 JK21 Review Kwok criminal case and appeals for new filings for L. Despins 0.20 540.00 108.00 09/06/2023 JK21 Electronically file with the Court letter in

09/06/2023 SM29 Email L. Despins and N. Bassett re

debtor's attempt to stay bankruptcy cases 0.30 1,360.00 408.00 09/07/2023 JK21 Review Kwok criminal case and appeals for new filings for L. Despins 0.40 540.00 216.00 09/07/2023 SM29 Review revised joinder from Committee in

Date Initials Description Hours Rate Amount

09/08/2023 JK21 Review Kwok criminal case and appeals for new filings for L. Despins 0.40 540.00 216.00 09/11/2023 JK21 Review Kwok criminal case and appeals for new filings for L. Despins 0.40 540.00 216.00 09/12/2023 AB21 Correspond with L. Despins regarding

(0.2); call with L. Despins regarding same

09/12/2023 DEB4 Correspond with L. Despins regarding motion for injunction 0.10 1,360.00 136.00 09/12/2023 JK21 Review Kwok criminal case and appeals for new filings for L. Despins 0.40 540.00 216.00 09/12/2023 LAD4 Analyze criminal case stay issues (.60); t/c N. Bassett re: same (.20); t/c A. Bongartz

09/12/2023 NAB Call with L. Despins regarding request to stay bankruptcy case (.2); analyze case law in connection with same (1.4) 1.60 1,675.00 2,680.00 09/12/2023 SM29 Correspond with L. Despins re motion to enforce automatic stay and Debtor's motion to stay chapter 11 case (.2); review case findings re same (.4); review additional case law and statutory authority re same (1.0) 1.60 1,360.00 2,176.00 09/13/2023 AB21 Analyze Kwok's All Writs motion in criminal proceedings (1.2); conference with S. Maza regarding same (0.9); calls with L. Despins regarding same (0.2); call with L. Despins and N. Bassett regarding response

regarding factual background for response (0.1); call with E. Sutton regarding related authority and avoidance actions statute of limitations (0.1) 3.50 1,675.00 5,862.50 09/13/2023 ECS1 Review authority regarding statute of limitations for avoidance action (.1); call

debtor's criminal stay motion (.1) 0.20 1,045.00 209.00

Date Initials Description Hours Rate Amount

09/13/2023 ECS1 Review legal standards for statute of limitations for avoidance actions 0.20 1,045.00 209.00 09/13/2023 JK21 Review new filings in Kwok criminal case and appeals for L. Despins 0.40 540.00 216.00 09/13/2023 JK21 Correspond with L. Despins regarding protective order in Kwok criminal case 0.20 540.00 108.00 09/13/2023 LAD4 Analyze/comment on merits response to stay motion in criminal case (5.60); t/c A. Bongartz re: same (.20); t/c N. Bassett & A. Fee re: same (.80); t/c A. Bongartz & N. Bassett re: merits response to stay request in criminal case (1.00) 7.60 1,975.00 15,010.00 09/13/2023 NAB Call with L. Despins and A. Fee regarding same (.8); call with L. Despins and A.

motion to stay case (1.0) 1.80 1,675.00 3,015.00 09/13/2023 SM29 Conference with A. Bongartz re Debtor's motion to stay chapter 11 case (.9); email A. Bongartz re authority re same (.1) 1.00 1,360.00 1,360.00 09/14/2023 AB21 Analyze issues for response to Kwok motion for stay of bankruptcy cases (1.6);

authority for same (0.1); conference with S. Maza regarding same (0.3); correspond with S. Maza regarding same (0.1) 2.50 1,675.00 4,187.50 09/14/2023 ECS1 Analyze application of statute of limitations

regarding same (.4) 2.00 1,045.00 2,090.00 09/14/2023 JK21 Correspond with A. Bongartz regarding letter joinder in support of motion to stay the bankruptcy cases 0.20 540.00 108.00 09/14/2023 JK21 Review recent filings in Kwok criminal case and appeals for L. Despins 0.40 540.00 216.00 09/14/2023 JK21 Correspond with E. Sutton regarding motion to extend or toll section 546 statute

Case 22-50073 Doc 2935 Filed 02/19/24 Entered 02/19/24 20:04:06 Page 132 of 779

Luc Despins as Chapter 11 Trustee in the case of Ho Wan Kwok 50687-00003 Invoice No. 2375611

Date Initials Description Hours Rate Amount

09/14/2023 SM29 Conference with A. Bongartz re response to

(.3); email E. Sutton re same (.1); review pleadings and letters to court re same (.7) 1.10 1,360.00 1,496.00 09/15/2023 AB21 Analyze arguments for response to Kwok's global stay motion 0.50 1,675.00 837.50 09/15/2023 ECS1 Analyze authority regarding statute of limitations for avoidance actions (1.5);

regarding same (.6) 2.20 1,045.00 2,299.00 09/15/2023 JK21 Prepare shell response to motion to stay in

09/15/2023 JK21 Review Kwok criminal case and appeals for newly filed pleadings for L. Despins 0.40 540.00 216.00 09/15/2023 KC27 Correspond with A. Bongartz regarding

09/15/2023 LAD4 Numerous emails to/from OMM re: criminal case stay motion (1.30);

09/15/2023 Review local rules of the Southern District

criminal stay motion 0.40 855.00 342.00 09/15/2023 NAB Correspond with I. Goldman (Pullman)

09/16/2023 AB21 Outline response to Kwok's global stay

09/16/2023 LAD4 Email to A. Bongartz re: insert to criminal

Case 22-50073 Doc 2935 Filed 02/19/24 Entered 02/19/24 20:04:06 Page 133 of 779

Luc Despins as Chapter 11 Trustee in the case of Ho Wan Kwok 50687-00003 Invoice No. 2375611

Date Initials Description Hours Rate Amount

09/17/2023 AB21 Begin drafting response to Kwok's global

regarding same (0.3); analyze case law and statutory authority related to same (2.7);

insert for response to Kwok's global stay

regarding same (0.1) 7.50 1,675.00 12,562.50 09/17/2023 KC27 Call with A. Bongartz regarding response to debtor's motion to stay bankruptcy case (.1); prepare background section of objection to

09/17/2023 SM29 Call with A. Bongartz re objection to Debtor's motion to stay chapter 11 cases 0.30 1,360.00 408.00 09/18/2023 AB21 Continue drafting response to Kwok's global stay motion (9.9); call with D. Barron regarding inserts for same (0.2); call with E. Sutton regarding related case law (0.1);

(0.2); call with N. Bassett regarding same

09/18/2023 DEB4 Conference with A. Bongartz regarding

09/18/2023 DEB4 Prepare inserts for objection to Kwok's motion to stay bankruptcy case 2.20 1,360.00 2,992.00 09/18/2023 ECS1 Prepare summary of case facts and filings in

Kwok's motion to stay the bankruptcy case (.8); call with A. Bongartz regarding same

09/18/2023 JK21 Review Kwok criminal case and appeals for newly filed pleadings for L. Despins 0.40 540.00 216.00 09/18/2023 JK21 Correspond with S. Maza regarding stay

Case 22-50073 Doc 2935 Filed 02/19/24 Entered 02/19/24 20:04:06 Page 134 of 779

Luc Despins as Chapter 11 Trustee in the case of Ho Wan Kwok 50687-00003 Invoice No. 2375611

Date Initials Description Hours Rate Amount

09/18/2023 JPK1 Analyze procedures concerning Trustee's request for hearing in SDNY criminal case

09/18/2023 KC27 Further prepare background section of opposition to debtor's motion in criminal case to stay bankruptcy cases (2.0);

09/18/2023 LAD4 Email to US Trustee request to file

09/18/2023 Analyze SDNY local rules and federal rules

requesting a hearing in SDNY 0.80 855.00 684.00 09/18/2023 Prepare fact section on Greenwich Land for response to the Debtor's motion to stay the

09/18/2023 NAB Conference with A. Bongartz regarding response to motion to stay chapter 11 case (.1); correspond with A. Bongartz regarding same (.4); draft insert for same (.8) 1.30 1,675.00 2,177.50 09/18/2023 NAB Correspond with O'Melveny regarding

injunction appeal (.2); correspond with L. Despins regarding case strategy (.3) 0.50 1,675.00 837.50 09/18/2023 SM29 Correspond with L. Despins re research in

motion to stay chapter 11 cases (.3); prepare insert for objection to Debtor's motion to stay chapter 11 cases (7.0); calls with A. Bongartz re same (.2) 7.50 1,360.00 10,200.00

Case 22-50073 Doc 2935 Filed 02/19/24 Entered 02/19/24 20:04:06 Page 135 of 779

Luc Despins as Chapter 11 Trustee in the case of Ho Wan Kwok 50687-00003 Invoice No. 2375611

Date Initials Description Hours Rate Amount

09/19/2023 AB21 Calls with S. Maza regarding response to Kwok's global stay motion (1.5); continue drafting response (9.0); calls with N. Bassett regarding same (0.3); calls with E. Sutton regarding insert for same (0.2); correspond with L. Despins regarding related research

preparation for filing response to Kwok's global stay motion (0.1) 11.40 1,675.00 19,095.00

regarding FARA decisions 0.10 1,360.00 136.00 09/19/2023 DEB4 Analyze draft objection debtor's motion to stay bankruptcy case 1.60 1,360.00 2,176.00 09/19/2023 DEB4 Conference with S. Maza and E. Sutton regarding objection to debtor's motion to stay bankruptcy case 0.50 1,360.00 680.00 09/19/2023 ECS1 Prepare parts of Trustee's response to Kwok's motion to stay the bankruptcy case (3.9); calls with A. Bongartz regarding same

regarding same (.5); correspond with D. Barron and S. Maza regarding same (.4) 5.00 1,045.00 5,225.00 09/19/2023 JK21 Review Kwok criminal case and appeals for newly filed pleadings for L. Despins 0.40 540.00 216.00 09/19/2023 KC27 Prepare background section of objection to debtor's motion in criminal case for stay of

09/19/2023 LAD4 Review cases re: section 546 (.80); t/c S. Sarnoff, P. Friedman (OMM) and N. Bassett re: stay motion (.30) 1.10 1,975.00 2,172.50 09/19/2023 Review FARA decisions in SDNY on cases against the trustee, PAX and PAX's counsel 0.40 855.00 342.00

Case 22-50073 Doc 2935 Filed 02/19/24 Entered 02/19/24 20:04:06 Page 136 of 779

Luc Despins as Chapter 11 Trustee in the case of Ho Wan Kwok 50687-00003 Invoice No. 2375611

Date Initials Description Hours Rate Amount

09/19/2023 NAB Draft portions of response to motion to stay bankruptcy case (2.2); review and revise remainder of draft response (2.4); calls with A. Bongartz regarding same (.3); call with S. Maza regarding same (.1); correspond with L. Despins regarding same and related case issues (.1); call with L. Despins, P. Friedman

stay motion issues (.3); correspond with I.

regarding stay motion briefing schedule (.2);

to motion to stay chapter 11 case (.7) 6.30 1,675.00 10,552.50 09/19/2023 NAB Review status of state court GTV class action (.1); correspond with Debtor counsel

injunction appeal issues (.2) 0.40 1,675.00 670.00 09/19/2023 SM29 Review draft objection to motion to stay ch 11 case in advance of calls with A. Bongartz (.6); calls with A. Bongartz re same (1.5); call with E. Sutton and D. Barron re same (.5); prepare inserts to draft objection to motion to stay ch 11 case (4.4); correspond with J. Kuo and A. Bongartz re local rules for same (.2); call with N. Bassett re same (.1); correspond with K. Catalano re same

09/20/2023 AB21 Revise draft response to Kwok's stay motion (4.9); calls with S. Maza regarding same (1.4); calls with N. Bassett regarding same (0.4); calls with L. Despins regarding same (0.3); call with L. Despins and N. Bassett regarding draft response to Kwok's stay motion (0.5); correspond with L.

regarding same (0.1); correspond with S. Millman (Stroock) regarding same (0.1);

regarding same (0.2) 8.10 1,675.00 13,567.50

Date Initials Description Hours Rate Amount

09/20/2023 ECS1 Prepare Trustee's response to Kwok's motion to stay the bankruptcy case (.8);

regarding same (.2) 1.00 1,045.00 1,045.00 09/20/2023 JK21 Review and revise response to stay motion filed by Kwok in his criminal case 23-118 (6.1); prepare exhibits to supporting Bassett declaration (1.7) 7.80 540.00 4,212.00 09/20/2023 JK21 Review Kwok criminal case and appeals for newly filed pleadings for L. Despins 0.40 540.00 216.00 09/20/2023 KC27 Prepare motion to extend page limit for objection to Kwok's motion in criminal case to stay bankruptcy cases (1.1); analyze case law cited in Kwok's motion in criminal case to stay bankruptcy cases (1.5); calls with S. Maza regarding same (.2) 2.80 940.00 2,632.00 09/20/2023 LAD4 Review/edit objection to Kwok's request for stay of chapter 11 (1.40); t/c A. Bongartz re: same (.30); t/c N. Bassett and A. Bongartz re: same (.50); t/c I. Goldman & K. Mayhew re: same (.30); t/c S. Sarnoff

opposition to Kwok (.30) 2.80 1,975.00 5,530.00 09/20/2023 LAD4 Review/edit OMM brief on appeal of PI re:

09/20/2023 NAB Begin reviewing Debtor motion to compel in criminal case (.2); review DOJ subpoena (.2); correspond with L. Despins regarding same and related issues (.1); further prepare response to Debtor motion to stay 0.90 1,675.00 1,507.50

Case 22-50073 Doc 2935 Filed 02/19/24 Entered 02/19/24 20:04:06 Page 138 of 779

Luc Despins as Chapter 11 Trustee in the case of Ho Wan Kwok 50687-00003 Invoice No. 2375611

Date Initials Description Hours Rate Amount

09/20/2023 NAB Call with L. Despins and A. Bongartz

additional sections of same (1.8); calls with

review and revise draft brief in response to motion to stay bankruptcy case (2.2); correspond with L. Despins regarding same

and S. Sarnoff (OMM) regarding same (.1); review comments to draft brief in response to motion to stay bankruptcy case (.2); correspond with A. Fee regarding same (.2);

privileges order (.2); correspond with P. Linsey (NPM) regarding same and review of filings in connection with same (.5) 6.40 1,675.00 10,720.00 09/20/2023 NAB Review draft brief relating to preliminary injunction appeal 0.40 1,675.00 670.00 09/20/2023 SM29 Revise objection to Debtor's motion to stay ch 11 case (.9); calls with A. Bongartz re same (1.4); analyze case law and statutory authority re same (3.6); correspond with L. Despins re same (.2); revise objection to

additional authority (1.8); email L. Despins

related caselaw (.9); calls with K. Catalano re same (.2); review page extension motion (.1); correspond with K. Catalano re same

Case 22-50073 Doc 2935 Filed 02/19/24 Entered 02/19/24 20:04:06 Page 139 of 779

Luc Despins as Chapter 11 Trustee in the case of Ho Wan Kwok 50687-00003 Invoice No. 2375611

Date Initials Description Hours Rate Amount

09/21/2023 AB21 Finalize response to Kwok's stay motion (4.8); calls with L. Despins regarding same (0.3); calls with N. Bassett regarding same

same (0.2); correspond with L. Despins, N. Bassett, and S. Maza regarding same (0.5); correspond with J. Kuo regarding finalizing and filing of same (0.3); call with S. Maza and J. Kuo regarding same (0.4) 7.30 1,675.00 12,227.50 09/21/2023 DEB4 Correspond with L. Despins and P.

indictment (0.1); correspond with E. Sutton regarding same (0.1) 0.20 1,360.00 272.00 09/21/2023 ECS1 Prepare summary of Rule 2004 discovery production by law firms in connection with

bankruptcy case (1.7); review documents in connection with same (1.2); calls with J. Kosciewicz regarding same (.3); correspond with J. Kosciewicz regarding same (.3) 3.50 1,045.00 3,657.50 09/21/2023 JK21 Review Kwok criminal case and appeals for newly filed pleadings for L. Despins 0.40 540.00 216.00

stay bankruptcy case (.4); further calls with S. Maza regarding same (.4); revise response

in the criminal case 23-118 (1.5); revise exhibits to supporting Bassett declaration (1.7); electronically file with the court response to Kwok's stay motion (0.3); electronically file with the court supporting Bassett declaration (0.4) 4.70 540.00 2,538.00

Case 22-50073 Doc 2935 Filed 02/19/24 Entered 02/19/24 20:04:06 Page 140 of 779

Luc Despins as Chapter 11 Trustee in the case of Ho Wan Kwok 50687-00003 Invoice No. 2375611

Date Initials Description Hours Rate Amount

09/21/2023 JPK1 Draft summary of Rule 2004 productions

privileges for use in opposition to Debtor's motion to stay bankruptcy case (2.5); calls with E. Sutton regarding same (.3);

2004 productions (.4); correspond with N. Bassett regarding the same (.2) 3.60 940.00 3,384.00 09/21/2023 LAD4 Final review/edit of criminal stay opposition (1.50); t/c A. Bongartz re: same (.30); t/c S. Millman (Stroock) re: SN filing

09/21/2023 AEL2 Analyze Kwok motion re: privilege issues 0.90 1,675.00 1,507.50 09/21/2023 AEL2 Call with N. Bassett re: privilege review by counsel for response to debtor's motion to stay bankruptcy cases 0.30 1,675.00 502.50 09/21/2023 AEL2 Draft plan for review of documents related

09/21/2023 NAB Review and revise draft response to motion to stay bankruptcy cases (2.1); calls with A.

with L. Despins regarding same (.2); review

stay bankruptcy cases (.6); further revise

joinder and related Sherry Netherland letter

response to motion to stay bankruptcy cases (.3); call with A. Luft regarding same (.3) 1,675.00 10,887.50 09/21/2023 NAB Review draft appellate brief concerning

O'Melveny regarding same (.2) 0.90 1,675.00 1,507.50

Case 22-50073 Doc 2935 Filed 02/19/24 Entered 02/19/24 20:04:06 Page 141 of 779

Luc Despins as Chapter 11 Trustee in the case of Ho Wan Kwok 50687-00003 Invoice No. 2375611

Date Initials Description Hours Rate Amount

09/21/2023 SM29 Review UCC draft joinder to objection to Debtor's motion to stay ch 11 case (.2); calls

exhibits in connection with same (.3);

Debtor's motion to stay ch 11 case (.5); calls

Debtor's motion to stay ch 11 case (.5);

revised draft objection (.6); call with J. Kuo

with N. Bassett, L. Despins, A. Bongartz,

(.6); review filing version of objection (.2);

09/21/2023 SM29 Review OMM appellee brief 0.40 1,360.00 544.00 09/22/2023 AB21 Review responses to Debtor's motion for stay of chapter 11 cases 0.80 1,675.00 1,340.00 09/22/2023 JK21 Review Kwok criminal case and appeals for new filings for L. Despins (0.4); correspond

newly filed pleadings (0.3) 0.70 540.00 378.00 09/22/2023 NAB Review government opposition to debtor's motion to stay bankruptcy cases (.3); analyze issues related to Debtor's motion to

criminal case (.3) 0.60 1,675.00 1,005.00 09/22/2023 NAB Review draft appellate brief on protest injunction appeal 0.50 1,675.00 837.50 09/22/2023 SM29 Analyze certain criminal case issues and

summary analysis of same (.6) 4.30 1,360.00 5,848.00 09/25/2023 AB21 Prepare notice of filing of responses to Debtor's stay motion (0.6); correspond with

with L. Despins regarding same (0.2) 0.90 1,675.00 1,507.50

Date Initials Description Hours Rate Amount

09/25/2023 JK21 Review recent filings in Kwok criminal case and appeals for L. Despins 0.40 540.00 216.00 09/25/2023 JK21 Correspond with A. Bongartz regarding

09/26/2023 JK21 Review recent filings in Kwok criminal case and appeals for L. Despins 0.40 540.00 216.00 09/26/2023 JK21 Prepare reference materials for E. Sutton and S. Maza regarding settlement agreement

09/26/2023 SM29 Correspond with J. Kuo and E. Sutton re criminal case and bankruptcy case research

09/27/2023 AB21 Final review of notice of response to Kwok's stay motion in criminal case (0.1); correspond with L. Despins regarding same

09/27/2023 JK21 Electronically file with the court notice of update of criminal case and motion to stay (0.3); review and handle service of notice of update of criminal case and motion to stay

09/27/2023 JK21 Review recent filings in Kwok criminal case and appeals for L. Despins 0.40 540.00 216.00 09/28/2023 JK21 Review recent filings in Kwok criminal case and appeals for L. Despins 0.40 540.00 216.00 09/29/2023 JK21 Review recent filings in Kwok criminal case and appeals for L. Despins 0.40 540.00 216.00 Subtotal: B191 General Litigation 233.60 326,761.00

ID Timekeeper Name Title Hours Rate Fee

LAD4 Luc A. Despins Partner 24.40 1,975.00 48,190.00

Luc Despins as Chapter 11 Trustee in the case of Ho Wan Kwok 50687-00003 Invoice No. 2375611

NAB Nicholas A. Bassett Partner 34.30 1,675.00 57,452.50

AB21 Alex Bongartz Of Counsel 57.20 1,675.00 95,810.00 AEL2 Luft, Avi E. Of Counsel 1.40 1,675.00 2,345.00 SM29 Shlomo Maza Associate 47.90 1,360.00 65,144.00 DEB4 Douglass E. Barron Associate 6.70 1,360.00 9,112.00 ECS1 Ezra C. Sutton Associate 16.70 1,045.00 17,451.50 JPK1 Jon P. Kosciewicz Associate 4.40 940.00 4,136.00 KC27 Kristin Catalano Associate 11.10 940.00 10,434.00

JK21 Jocelyn Kuo Paralegal 24.60 540.00 13,284.00 ML30 Mat Laskowski Paralegal 2.50 540.00 1,350.00

Date Description Quantity Rate Amount

Total Costs incurred and advanced \$145.01

Total Balance Due - Due Upon Receipt \$326,906.01

Luc Despins as Chapter 11 Trustee in the case of Ho Wan Kwok 200 Park Avenue New York, NY 10166

Attn: Luc Despins PH LLP Tax ID No. 95-2209675

Corporate Law Issues PH LLP Client/Matter # 50687-00004 Luc A. Despins

Legal fees for professional services for the period ending September 30, 2023 \$5,097.50

Total Balance Due - Due Upon Receipt \$5,097.50

We encourage our clients to pay via ACH, however, in the event that you pay by check, please send payment to the remittance address below:

*TO PROTECT AGAINST FRAUD, the Firm will not change its wiring instructions via email. We strongly encourage clients to confirm any change in wiring instructions by contacting Teri Goffredo @ 213-683-5045 or via email @ terigoffredo@paulhastings.com and requesting written and verbal confirmation.*

Wiring and ACH Instructions: Remittance Address: Pay by Tranch:

Citibank Paul Hastings LLP You can now pay your invoices online via ABA # 322271724 Lockbox 4803 real-time bank payments, credit cards or SWIFT Address: CITIUS33 PO Box 894803 in installments:

*For wires, please reference the invoice, client and matter number(s) being paid For ACH payments, please use the CTX format and/or send any remittances to cashepn@paulhastings com This is a no-reply mailbox*

Luc Despins as Chapter 11 Trustee in the case of Ho Wan Kwok 200 Park Avenue New York, NY 10166

Attn: Luc Despins PH LLP Tax ID No. 95-2209675

Corporate Law Issues PH LLP Client/Matter # 50687-00004 Luc A. Despins

Legal fees for professional services for the period ending September 30, 2023 \$5,097.50

Total Balance Due - Due Upon Receipt \$5,097.50

We encourage our clients to pay via ACH, however, in the event that you pay by check, please send payment to the remittance address below:

*TO PROTECT AGAINST FRAUD, the Firm will not change its wiring instructions via email. We strongly encourage clients to confirm any change in wiring instructions by contacting Teri Goffredo @ 213-683-5045 or via email @ terigoffredo@paulhastings.com and requesting written and verbal confirmation.*

Wiring and ACH Instructions: Remittance Address: Pay by Tranch:

Citibank Paul Hastings LLP You can now pay your invoices online via ABA # 322271724 Lockbox 4803 real-time bank payments, credit cards or SWIFT Address: CITIUS33 PO Box 894803 in installments:

*For wires, please reference the invoice, client and matter number(s) being paid For ACH payments, please use the CTX format and/or send any remittances to cashepn@paulhastings com This is a no-reply mailbox*

Luc Despins as Chapter 11 Trustee in the case of Ho November 30, 2023

New York, NY 10166 Invoice Number: 2375612

Attn: Luc Despins PH LLP Tax ID No. 95-2209675

FOR PROFESSIONAL SERVICES RENDERED for the period ending September 30, 2023

Date Initials Description Hours Rate Amount

09/13/2023 LAD4 T/c N. Bassett re: prep for Judge Dooley call & criminal stay matter (.40); handle Judge Dooley status conference with N.

09/13/2023 NAB Call with L. Despins regarding appellate status conferences in corporate governance and contempt appeals (.4); review appellate briefs and authority in preparation for status conferences (.8) 1.20 1,675.00 2,010.00 09/13/2023 NAB Participate in status conferences in corporate governance and contempt appeals 0.40 1,675.00 670.00 Subtotal: B155 Court Hearings 2.40 4,260.00

Case 22-50073 Doc 2935 Filed 02/19/24 Entered 02/19/24 20:04:06 Page 147 of 779

Luc Despins as Chapter 11 Trustee in the case of Ho Wan Kwok 50687-00004 Invoice No. 2375612

B190 Other Contested Matters(excl. assumption/rejections motions) 09/11/2023 NAB Review status of corporate governance

status conference (.2); correspond with L. Despins regarding same (.1); call with E. Henzy (Zeisler) regarding same (.1) 670.00 09/12/2023 NAB Correspond with E. Henzy regarding

Subtotal: B190 Other Contested Matters(excl. assumption/rejections motions) 0.50 837.50

ID Timekeeper Name Title Hours Rate Fee LAD4 Luc A. Despins Partner 0.80 1,975.00 1,580.00 NAB Nicholas A. Bassett Partner 2.10 1,675.00 3,517.50

Total Balance Due - Due Upon Receipt \$5,097.50

Case 22-50073 Doc 2935 Filed 02/19/24 Entered 02/19/24 20:04:06 Page 148 of 779

PAUL HASTINGS LLP 200 Park Avenue, New York, NY 10166-3205 t: +1.212.318.6000 f: +1.212.319.4090 www.paulhastings.com

Luc Despins as Chapter 11 Trustee in the case of Ho Wan Kwok 200 Park Avenue New York, NY 10166

Attn: Luc Despins PH LLP Tax ID No. 95-2209675

Sales Process PH LLP Client/Matter # 50687-00005 Luc A. Despins

Legal fees for professional services for the period ending September 30, 2023 \$6,270.00

Total Balance Due - Due Upon Receipt \$6,270.00

We encourage our clients to pay via ACH, however, in the event that you pay by check, please send payment to the remittance address below:

*TO PROTECT AGAINST FRAUD, the Firm will not change its wiring instructions via email. We strongly encourage clients to confirm any change in wiring instructions by contacting Teri Goffredo @ 213-683-5045 or via email @ terigoffredo@paulhastings.com and requesting written and verbal confirmation.*

Wiring and ACH Instructions: Remittance Address: Pay by Tranch:

Citibank Paul Hastings LLP You can now pay your invoices online via ABA # 322271724 Lockbox 4803 real-time bank payments, credit cards or SWIFT Address: CITIUS33 PO Box 894803 in installments:

*For wires, please reference the invoice, client and matter number(s) being paid For ACH payments, please use the CTX format and/or send any remittances to cashepn@paulhastings com This is a no-reply mailbox*

Case 22-50073 Doc 2935 Filed 02/19/24 Entered 02/19/24 20:04:06 Page 149 of 779

PAUL HASTINGS LLP 200 Park Avenue, New York, NY 10166-3205 t: +1.212.318.6000 f: +1.212.319.4090 www.paulhastings.com

Luc Despins as Chapter 11 Trustee in the case of Ho Wan Kwok 200 Park Avenue New York, NY 10166

Attn: Luc Despins PH LLP Tax ID No. 95-2209675

Sales Process PH LLP Client/Matter # 50687-00005 Luc A. Despins

Legal fees for professional services for the period ending September 30, 2023 \$6,270.00

Total Balance Due - Due Upon Receipt \$6,270.00

We encourage our clients to pay via ACH, however, in the event that you pay by check, please send payment to the remittance address below:

*TO PROTECT AGAINST FRAUD, the Firm will not change its wiring instructions via email. We strongly encourage clients to confirm any change in wiring instructions by contacting Teri Goffredo @ 213-683-5045 or via email @ terigoffredo@paulhastings.com and requesting written and verbal confirmation.*

Wiring and ACH Instructions: Remittance Address: Pay by Tranch:

Citibank Paul Hastings LLP You can now pay your invoices online via ABA # 322271724 Lockbox 4803 real-time bank payments, credit cards or SWIFT Address: CITIUS33 PO Box 894803 in installments:

*For wires, please reference the invoice, client and matter number(s) being paid For ACH payments, please use the CTX format and/or send any remittances to cashepn@paulhastings com This is a no-reply mailbox*

Case 22-50073 Doc 2935 Filed 02/19/24 Entered 02/19/24 20:04:06 Page 150 of 779

PAUL HASTINGS LLP 200 Park Avenue, New York, NY 10166-3205 t: +1.212.318.6000 f: +1.212.319.4090 www.paulhastings.com

Luc Despins as Chapter 11 Trustee in the case of Ho November 30, 2023

New York, NY 10166 Invoice Number: 2375613

Attn: Luc Despins PH LLP Tax ID No. 95-2209675 FOR PROFESSIONAL SERVICES RENDERED for the period ending September 30, 2023

Date Initials Description Hours Rate Amount

09/21/2023 AB21 Call with D. Johnson (Edmiston) regarding next steps for sale process of Lady May II 0.10 1,675.00 167.50 09/22/2023 AB21 Correspond with D. Johnson (Edmiston) regarding next steps for sale of Lady May II 0.30 1,675.00 502.50 09/25/2023 AB21 Correspond with L. Despins regarding update on Lady May II sale process (0.3);

and addendum for same (0.5) 1.20 1,675.00 2,010.00 09/26/2023 AB21 Correspond with L. Despins regarding update on Lady May sale process (0.8);

regarding same (0.1) 0.90 1,675.00 1,507.50 09/26/2023 LAD4 Email to OMM, UCC counsel & UST re: sale process for Lady May II 0.80 1,975.00 1,580.00 09/27/2023 AB21 Correspond with D. Johnson (Edmiston) regarding Lady May II update 0.20 1,675.00 335.00 Case 22-50073 Doc 2935 Filed 02/19/24 Entered 02/19/24 20:04:06 Page 151 of 779

Luc Despins as Chapter 11 Trustee in the case of Ho Wan Page 2

Date Initials Description Hours Rate Amount

09/28/2023 AB21 Correspond with D. Johnson (Edmiston) regarding LM2 update 0.10 1,675.00 167.50 Subtotal: B130 Asset Disposition 3.60 6,270.00

ID Timekeeper Name Title Hours Rate Fee LAD4 Luc A. Despins Partner 0.80 1,975.00 1,580.00 AB21 Alex Bongartz Of Counsel 2.80 1,675.00 4,690.00

Total Balance Due - Due Upon Receipt \$6,270.00

Case 22-50073 Doc 2935 Filed 02/19/24 Entered 02/19/24 20:04:06 Page 152 of 779

PAUL HASTINGS LLP 200 Park Avenue, New York, NY 10166-3205 t: +1.212.318.6000 f: +1.212.319.4090 www.paulhastings.com

Luc Despins as Chapter 11 Trustee in the case of Ho Wan Kwok 200 Park Avenue New York, NY 10166

Attn: Luc Despins PH LLP Tax ID No. 95-2209675

Genever US PH LLP Client/Matter # 50687-00010 Luc A. Despins

Legal fees for professional services for the period ending September 30, 2023 \$34,867.00

Total Balance Due - Due Upon Receipt \$34,867.00

We encourage our clients to pay via ACH, however, in the event that you pay by check, please send payment to the remittance address below:

*TO PROTECT AGAINST FRAUD, the Firm will not change its wiring instructions via email. We strongly encourage clients to confirm any change in wiring instructions by contacting Teri Goffredo @ 213-683-5045 or via email @ terigoffredo@paulhastings.com and requesting written and verbal confirmation.*

Wiring and ACH Instructions: Remittance Address: Pay by Tranch:

Citibank Paul Hastings LLP You can now pay your invoices online via ABA # 322271724 Lockbox 4803 real-time bank payments, credit cards or SWIFT Address: CITIUS33 PO Box 894803 in installments:

*For wires, please reference the invoice, client and matter number(s) being paid For ACH payments, please use the CTX format and/or send any remittances to cashepn@paulhastings com This is a no-reply mailbox*

Case 22-50073 Doc 2935 Filed 02/19/24 Entered 02/19/24 20:04:06 Page 153 of 779

PAUL HASTINGS LLP 200 Park Avenue, New York, NY 10166-3205 t: +1.212.318.6000 f: +1.212.319.4090 www.paulhastings.com

Luc Despins as Chapter 11 Trustee in the case of Ho Wan Kwok 200 Park Avenue New York, NY 10166

Attn: Luc Despins PH LLP Tax ID No. 95-2209675

Genever US PH LLP Client/Matter # 50687-00010 Luc A. Despins

Legal fees for professional services for the period ending September 30, 2023 \$34,867.00

Total Balance Due - Due Upon Receipt \$34,867.00

We encourage our clients to pay via ACH, however, in the event that you pay by check, please send payment to the remittance address below:

*TO PROTECT AGAINST FRAUD, the Firm will not change its wiring instructions via email. We strongly encourage clients to confirm any change in wiring instructions by contacting Teri Goffredo @ 213-683-5045 or via email @ terigoffredo@paulhastings.com and requesting written and verbal confirmation.*

Wiring and ACH Instructions: Remittance Address: Pay by Tranch:

Citibank Paul Hastings LLP You can now pay your invoices online via ABA # 322271724 Lockbox 4803 real-time bank payments, credit cards or SWIFT Address: CITIUS33 PO Box 894803 in installments:

*For wires, please reference the invoice, client and matter number(s) being paid For ACH payments, please use the CTX format and/or send any remittances to cashepn@paulhastings com This is a no-reply mailbox*

t: +1.212.318.6000 f: +1.212.319.4090 www.paulhastings.com

Luc Despins as Chapter 11 Trustee in the case of Ho November 30, 2023

New York, NY 10166 Invoice Number: 2375614

Attn: Luc Despins PH LLP Tax ID No. 95-2209675

FOR PROFESSIONAL SERVICES RENDERED for the period ending September 30, 2023

Date Initials Description Hours Rate Amount

09/27/2023 AB21 Correspond with L. Despins regarding proxy with respect to Genever US 0.20 1,675.00 335.00 Subtotal: B110 Case Administration 0.20 335.00

09/01/2023 ECS1 Correspond with A. Bongartz regarding local bankruptcy rules in connection with potential auction motion regarding debtor's

09/11/2023 AB21 Call with K. Catalano regarding sale of furniture in SN apartment (0.1); correspond with L. Despins regarding same (0.1); call with J. Hascoe (Sotheby's) regarding walk

with M. Ullman (Sherry Netherland) and L.

with J. Hascoe regarding same (0.1) 0.60 1,675.00 1,005.00

Case 22-50073 Doc 2935 Filed 02/19/24 Entered 02/19/24 20:04:06 Page 155 of 779

Luc Despins as Chapter 11 Trustee in the case of Ho Wan Kwok 50687-00010 Invoice No. 2375614

Date Initials Description Hours Rate Amount

09/11/2023 KC27 Call with A. Bongartz regarding motion to sell furniture in Sherry Netherland (.1); review issues regarding same (.2) 0.30 940.00 282.00 09/12/2023 AB21 Call with J. Panico (AAGL) regarding walk

furniture sale (0.1); correspond with M. Ullman (Sherry Netherland) regarding same (0.1); correspond with J. Hascoe (Sotheby's) regarding same (0.1); correspond with D. Acheson (architect) regarding remediation

09/12/2023 ECS1 Correspond with A. Bongartz regarding local bankruptcy rules in connection with potential auction motion of SN furniture 0.10 1,045.00 104.50 09/12/2023 KC27 Correspond with A. Bongartz regarding

Netherland apartment 0.10 940.00 94.00 09/15/2023 AB21 Walk-through of SN apartment with S.

regarding potential furniture sale 0.60 1,675.00 1,005.00 09/22/2023 AB21 Call with J. Hascoe (Sotheby's) and G. Griffin regarding SN furniture 0.40 1,675.00 670.00 09/25/2023 AB21 Correspond with M. Ullman (Sherry

disposition of furniture 0.10 1,675.00 167.50 09/26/2023 AB21 Correspond with M. Ullman (Sherry

furniture walkthrough 0.10 1,675.00 167.50 09/27/2023 AB21 Meeting with G. Griffin and regarding disposition of SN furniture (1.0);

regarding same (0.1); correspond with L. Despins regarding same (0.1) 1.60 1,675.00 2,680.00 09/27/2023 Site visit to the Sherry Netherland

Case 22-50073 Doc 2935 Filed 02/19/24 Entered 02/19/24 20:04:06 Page 156 of 779

Luc Despins as Chapter 11 Trustee in the case of Ho Wan Kwok 50687-00010 Invoice No. 2375614

Date Initials Description Hours Rate Amount

policies related to SN apartment (0.2);

disposition of SN furniture (0.1) 0.50 1,675.00 837.50 09/28/2023 Call with A. Bongartz regarding disposition of Sherry Netherland furniture (0.1); review closing documents regarding the sale of the Sherry Netherland apartment (0.9); review

Subtotal: B130 Asset Disposition 7.30 9,877.50

09/19/2023 AB21 Call with L. Despins regarding preparation for hearing on remediation motion 0.40 1,675.00 670.00

09/19/2023 LAD4 Round trip travel to/from Bridgeport, CT (Bill at 1/2 rate) 1.10 1,975.00 2,172.50 09/19/2023 LAD4 Review submissions and prepare outline for remediation project hearing (2.10); call with

Subtotal:

09/15/2023 AB21 Travel to/from NY office to SN apartment for walk-through (Bill at 1/2 rate) 0.60 837.50 502.50 Subtotal: B195 Non-Working Travel 1.20 1,005.00 Case 22-50073 Doc 2935 Filed 02/19/24 Entered 02/19/24 20:04:06 Page 157 of 779

Luc Despins as Chapter 11 Trustee in the case of Ho Wan Kwok 50687-00010 Invoice No. 2375614

Date Initials Description Hours Rate Amount B210 Business Operations 09/01/2023 AB21 Correspond with D. Acheson (architect) regarding remediation project for SN apartment 0.10 1,675.00 167.50 09/04/2023 DEB4 Correspond with T. Sadler regarding insurance payments 0.10 1,360.00 136.00 09/05/2023 AB21 Analyze ABF proposal for asbestos removal (0.4); correspond with D. Acheson (architect) regarding same (0.1); call with D. Acheson and M. Bielawski (ABF) regarding same (0.4) 0.90 1,675.00 1,507.50 09/06/2023 DEB4 Correspond with T. Sadler regarding insurance payments 0.10 1,360.00 136.00 09/07/2023 AB21 Prepare supplement to remediation motion (0.8); correspond with G. Chomenko (GBTS) regarding air monitoring proposal (0.1) 0.90 1,675.00 1,507.50 09/08/2023 AB21 Revise supplement to remediation motion (1.9); correspond with L. Despins regarding same (0.5); call with D. Acheson (architect) regarding same (0.1); correspond with J. Panico (AAGL) regarding same (0.2); correspond with M. Ullman (Sherry Netherland) and S. Millman (Stroock) regarding same (0.2); correspond with J. Kuo regarding filing of same (0.1); correspond with G. Chomenko (GBTS) regarding asbestos removal project (0.3) 3.30 1,675.00 5,527.50 09/08/2023 JK21 Prepare for electronic filing supplement to remediation motion (0.3); electronically file with the court supplement to remediation motion (0.3); review and handle additional service of supplement to remediation motion (0.2) 0.80 540.00 432.00 09/15/2023 AB21 Correspond and call with D. Acheson (architect) regarding conditions report 0.10 1,675.00 167.50

Call with D. Acheson (architect) regarding

AB21 Review D. Acheson's condition's report

TS21 Correspond with L. Despins and insurance 0.50 1,210.00 605.00 AB21 regarding same (0.1); correspond with 0.80 1,675.00 1,340.00

Call with D. Acheson (architect) regarding next steps in remediation project (0.3);

invoice (0.1); review same (0.1); call with

Partners first invoice (0.2); electronically file with the court notice of filing of Acheson

Prepare notice of filing of Acheson Doyle's

Call with A. Bongartz re notice of filing of

regarding asbestos removal (0.2); correspond with T. Sadler regarding related payment (0.1); correspond with L. Despins regarding asbestos removal (0.1); correspond with L. Despins regarding next

Luc Despins as Chapter 11 Trustee in the case of Ho Wan Kwok 50687-00010 Invoice No. 2375614

ID Timekeeper Name Title Hours Rate Fee

LAD4 Luc A. Despins Partner 4.30 1,975.00 8,492.50 AB21 Alex Bongartz Of Counsel 12.30 1,675.00 20,602.50 AB21 Alex Bongartz Of Counsel 1.20 837.50 1,005.00 DEB4 Douglass E. Barron Associate 0.20 1,360.00 272.00 TS21 Tess Sadler Associate 0.50 1,210.00 605.00 ECS1 Ezra C. Sutton Associate 0.40 1,045.00 418.00 KC27 Kristin Catalano Associate 0.40 940.00 376.00

JK21 Jocelyn Kuo Paralegal 1.30 540.00 702.00

Total Balance Due - Due Upon Receipt \$34,867.00

Case 22-50073 Doc 2935 Filed 02/19/24 Entered 02/19/24 20:04:06 Page 160 of 779

PAUL HASTINGS LLP 200 Park Avenue, New York, NY 10166-3205 t: +1.212.318.6000 f: +1.212.319.4090 www.paulhastings.com

Luc Despins as Chapter 11 Trustee in the case of Ho Wan Kwok 200 Park Avenue New York, NY 10166

Attn: Luc Despins PH LLP Tax ID No. 95-2209675

PH LLP Client/Matter # 50687-00012 Luc A. Despins

Legal fees for professional services for the period ending September 30, 2023 \$56,560.25

Total Balance Due - Due Upon Receipt \$57,221.95

We encourage our clients to pay via ACH, however, in the event that you pay by check, please send payment to the remittance address below:

*TO PROTECT AGAINST FRAUD, the Firm will not change its wiring instructions via email. We strongly encourage clients to confirm any change in wiring instructions by contacting Teri Goffredo @ 213-683-5045 or via email @ terigoffredo@paulhastings.com and requesting written and verbal confirmation.*

Wiring and ACH Instructions: Remittance Address: Pay by Tranch:

Citibank Paul Hastings LLP You can now pay your invoices online via ABA # 322271724 Lockbox 4803 real-time bank payments, credit cards or SWIFT Address: CITIUS33 PO Box 894803 in installments:

*For wires, please reference the invoice, client and matter number(s) being paid For ACH payments, please use the CTX format and/or send any remittances to cashepn@paulhastings com This is a no-reply mailbox*

Case 22-50073 Doc 2935 Filed 02/19/24 Entered 02/19/24 20:04:06 Page 161 of 779

PAUL HASTINGS LLP 200 Park Avenue, New York, NY 10166-3205 t: +1.212.318.6000 f: +1.212.319.4090 www.paulhastings.com

Luc Despins as Chapter 11 Trustee in the case of Ho Wan Kwok 200 Park Avenue New York, NY 10166

Attn: Luc Despins PH LLP Tax ID No. 95-2209675

PH LLP Client/Matter # 50687-00012 Luc A. Despins

Legal fees for professional services for the period ending September 30, 2023 \$56,560.25

Total Balance Due - Due Upon Receipt \$57,221.95

We encourage our clients to pay via ACH, however, in the event that you pay by check, please send payment to the remittance address below:

*TO PROTECT AGAINST FRAUD, the Firm will not change its wiring instructions via email. We strongly encourage clients to confirm any change in wiring instructions by contacting Teri Goffredo @ 213-683-5045 or via email @ terigoffredo@paulhastings.com and requesting written and verbal confirmation.*

Wiring and ACH Instructions: Remittance Address: Pay by Tranch:

Citibank Paul Hastings LLP You can now pay your invoices online via ABA # 322271724 Lockbox 4803 real-time bank payments, credit cards or SWIFT Address: CITIUS33 PO Box 894803 in installments:

*For wires, please reference the invoice, client and matter number(s) being paid For ACH payments, please use the CTX format and/or send any remittances to cashepn@paulhastings com This is a no-reply mailbox*

Luc Despins as Chapter 11 Trustee in the case of Ho November 30, 2023

New York, NY 10166 Invoice Number: 2375615

Attn: Luc Despins PH LLP Tax ID No. 95-2209675

FOR PROFESSIONAL SERVICES RENDERED for the period ending September 30, 2023

Date Initials Description Hours Rate Amount

09/01/2023 LAD4 Prepare for Mahwah Mansion visit/tour by

same (1.20); handle visit/tour (3.70) 4.90 1,975.00 9,677.50 09/01/2023 Prepare glossary list of Mahwah fixtures and

09/01/2023 Inspect the Mahwah Mansion with L. Despins and Kroll 3.70 855.00 3,163.50 09/02/2023 Review pictures taken at the Mahwah mansion against the item list filed by Taurus

09/02/2023 Review G Club production on Relativity 1.90 855.00 1,624.50 09/03/2023 Review G Club production for documents referencing Mahwah mansion 1.60 855.00 1,368.00 09/04/2023 Review pictures taken at Mahwah mansion against the list of items filed by Taurus

09/05/2023 ECS1 Prepare outline of Mahwah discovery plan (.2); correspond with S. Maza and A. Luft regarding same (.1) 0.30 1,045.00 313.50

Date Initials Description Hours Rate Amount

09/05/2023 Prepare list of missing items in the Mahwah

09/06/2023 DEB4 Correspond with L. Despins regarding

09/06/2023 Continue preparing list of missing items in the Mahwah mansion 2.00 855.00 1,710.00 09/07/2023 ECS1 Analyze process for serving discovery on

(.8); correspond with L. Despins regarding

09/07/2023 IC Research regarding subpoena of New Jersey Motor Vehicle Commission 0.50 400.00 200.00 09/08/2023 ECS1 Further analyze process for serving

Commission (.2); correspond with L. Despins regarding same (.3) 0.50 1,045.00 522.50 09/11/2023 ECS1 Analyze processes for serving discovery on

(.2); correspond with J. Kuo regarding same

09/11/2023 JK21 Correspond with E. Sutton regarding

09/12/2023 ECS1 Review A. Luft comments on Mahwah

09/12/2023 LAD4 T/c J. Murray (and other DOJ employees) re: tour of mansion (.20); t/c M. Dumpert (Kroll) re: motorcycles (.30) 0.50 1,975.00 987.50 09/12/2023 AEL2 Correspond with E. Sutton and S. Maza

09/12/2023 Review pictures taken at the Mahwah

09/13/2023 DEB4 Correspond with A. Bongartz regarding draft motion to seal 0.10 1,360.00 136.00 09/13/2023 Review Mahwah videos taken by Kroll 0.50 855.00 427.50

Date Initials Description Hours Rate Amount

09/14/2023 DEB4 Correspond with E. Sutton regarding hearing transcript 0.10 1,360.00 136.00 09/14/2023 ECS1 Analyze processes for serving discovery on New Jersey's Motor Vehicle Commission 0.10 1,045.00 104.50 09/20/2023 Review photos and videos taken at Mahwah walkthrough in response to DOJ grand jury

regarding Mahwah complaint (0.1); further

09/21/2023 ECS1 Prepare cases and precedent documents related to asset forfeiture (.3); correspond with S. Maza regarding same (.1) 0.40 1,045.00 418.00 09/21/2023 ECS1 Correspond with S. Maza regarding

09/21/2023 JPK1 Review Mahwah media photos (.2);

regarding the same (.1); correspond with L. Despins regarding the same (.1) 0.40 940.00 376.00 09/21/2023 Review Mahwah photos and videos in

09/21/2023 Review the 25 exhibits to the complaint 0.80 855.00 684.00 09/22/2023 ECS1 Analyze processes for serving discovery on

summarizing same (.2) 0.30 1,045.00 313.50 09/22/2023 LAD4 Review DOJ filing re: tampering with

09/22/2023 AEL2 Correspond with P. Parizek re: Mahwah

09/22/2023 AEL2 Review SDNY filing re: Mahwah 0.40 1,675.00 670.00

Case 22-50073 Doc 2935 Filed 02/19/24 Entered 02/19/24 20:04:06 Page 165 of 779

Luc Despins as Chapter 11 Trustee in the case of Ho Wan Kwok 50687-00012 Invoice No. 2375615

Date Initials Description Hours Rate Amount

09/22/2023 NAB Analyze defendant ownership issues and related authority (.7); review Kroll emails regarding same (.2); correspond with D. Barron regarding same (.3); correspond with P. Parizek (Kroll) regarding same (.1) 1.30 1,675.00 2,177.50 09/25/2023 JPK1 Review and prepare pictures and videos of

same (.2); correspond with S. Phan (United Lex) regarding the same (.2) 0.60 940.00 564.00 09/25/2023 Review pictures and videos of Mahwah

government's subpoena 1.00 855.00 855.00 09/26/2023 ECS1 Further analyze processes for serving

regarding same (.1) 0.20 1,045.00 209.00 09/26/2023 LAD4 T/c F. Diapolo (security) re: update on mansion (.20); review pics of September 1 mansion tour (.40) 0.60 1,975.00 1,185.00

09/27/2023 JPK1 Review Mahwah media on Relativity

regarding the same (.2) 0.30 940.00 282.00 09/27/2023 Call with D. Barron regarding Taurus Fund assets (.3); continue reviewing pictures and videos of Mahwah Mansion (3.1) 3.40 855.00 2,907.00 09/28/2023 Prepare summary of assets of Taurus Fund and fixtures in Mahwah Mansion 0.70 855.00 598.50

on Relativity regarding the same (.4);

regarding the same (.2) 1.00 940.00 940.00 09/29/2023 Review Mahwah media files 0.60 855.00 513.00 Case 22-50073 Doc 2935 Filed 02/19/24 Entered 02/19/24 20:04:06 Page 166 of 779

Luc Despins as Chapter 11 Trustee in the case of Ho Wan Kwok 50687-00012 Invoice No. 2375615

Date Initials Description Hours Rate Amount

09/29/2023 Fund LLC Correspond with A. Bongartz re Taurus 0.10 855.00 85.50 09/30/2023 Review Mahwah media files 0.60 855.00 513.00 09/30/2023 media files Correspond with UnitedLex re Mahwah 0.20 855.00 171.00 Subtotal: B191 General Litigation 49.00 53,319.00

09/01/2023 LAD4 Travel to/from Mahwah Mansion for site visit (bill at 1/2 rate) 1.10 1,975.00 2,172.50 09/01/2023 (Bill at 1/2 rate) Travel from Paul Hastings New York office

mansion back to Paul Hastings NY office 2.50 427.50 1,068.75 Subtotal: B195 Non-Working Travel 3.60 3,241.25

ID Timekeeper Name Title Hours Rate Fee LAD4 Luc A. Despins Partner 8.60 1,975.00 16,985.00 NAB Nicholas A. Bassett Partner 1.30 1,675.00 2,177.50 AEL2 Luft, Avi E. Of Counsel 1.20 1,675.00 2,010.00 DEB4 Douglass E. Barron Associate 0.90 1,360.00 1,224.00 ECS1 Ezra C. Sutton Associate 3.40 1,045.00 3,553.00 JPK1 Jon P. Kosciewicz Associate 2.30 940.00 2,162.00

JK21 Jocelyn Kuo Paralegal 0.30 540.00 162.00 Case 22-50073 Doc 2935 Filed 02/19/24 Entered 02/19/24 20:04:06 Page 167 of 779

Date Description Quantity Rate Amount 09/15/2023 Photocopy Charges 196.00 0.08 15.68 09/21/2023 Photocopy Charges (Color) 371.00 0.20 74.20 09/26/2023 Photocopy Charges 17.00 0.08 1.36 09/28/2023 Photocopy Charges 660.00 0.08 52.80 09/28/2023 Photocopy Charges (Color) 58.00 0.20 11.60 08/13/2023 Local - Meals - Grubhub Holdings Inc. f/k/a 74 dated 08/13/2023; Seamlessweb (USD) (JPMSUA); Invoice # SL-190- People: 1; Location: New York; Lunch in office on Sunday while preparing for Mahwah PI hearing; Order # 176723424294684 dated 08/13/2023 ; Number of 24.82 08/31/2023 Data Base Storage - PS-TD01493; Analyst - Ecklund, Amy USB Thumb Drive; 08/13/23 101.00 08/31/2023 Data Base Storage - PS-TD01808; Analyst - Lopez, Mayray USB Thumb Drive; 08/13/23 101.00 08/31/2023 Data Base Storage - PS-TD01734; Analyst - Lopez,

09/01/2023 Electronic Document Retrieval - TransUnion Risk Property Search/Person Search and Alternative Data Solutions, Inc., Invoice# 1047352-202308-1 Dated 09/01/23, TLO Charges for August 01, 2023 - August 31, 2023 - TruLookup 10.00

mansion 09/01/2023; From/To: from 200 Park Avenue to Mahwah NJ; Service Type: Lyft; Taxi ride from 200 Park Avenue to Mahwah NJ to inspect the Mahwah ; 147.19

Case 22-50073 Doc 2935 Filed 02/19/24 Entered 02/19/24 20:04:06 Page 168 of 779

Luc Despins as Chapter 11 Trustee in the case of Ho Wan Page 7

09/01/2023; From/To: from Mahwah, NJ to 200 Park Avenue; Service Type: Uber; Taxi ride from Mahwah, NJ to New York after tour at the Mahwah

Total Costs incurred and advanced \$661.70

Total Balance Due - Due Upon Receipt \$57,221.95

Case 22-50073 Doc 2935 Filed 02/19/24 Entered 02/19/24 20:04:06 Page 169 of 779

PAUL HASTINGS LLP 200 Park Avenue, New York, NY 10166-3205 t: +1.212.318.6000 f: +1.212.319.4090 www.paulhastings.com

Luc Despins as Chapter 11 Trustee in the case of Ho Wan Kwok 200 Park Avenue New York, NY 10166

Attn: Luc Despins PH LLP Tax ID No. 95-2209675

PH LLP Client/Matter # 50687-00013 Luc A. Despins

Legal fees for professional services for the period ending September 30, 2023 \$14,021.00

Total Balance Due - Due Upon Receipt \$14,212.85

We encourage our clients to pay via ACH, however, in the event that you pay by check, please send payment to the remittance address below:

*TO PROTECT AGAINST FRAUD, the Firm will not change its wiring instructions via email. We strongly encourage clients to confirm any change in wiring instructions by contacting Teri Goffredo @ 213-683-5045 or via email @ terigoffredo@paulhastings.com and requesting written and verbal confirmation.*

Wiring and ACH Instructions: Remittance Address: Pay by Tranch:

Citibank Paul Hastings LLP You can now pay your invoices online via ABA # 322271724 Lockbox 4803 real-time bank payments, credit cards or SWIFT Address: CITIUS33 PO Box 894803 in installments:

*For wires, please reference the invoice, client and matter number(s) being paid For ACH payments, please use the CTX format and/or send any remittances to cashepn@paulhastings com This is a no-reply mailbox*

Luc Despins as Chapter 11 Trustee in the case of Ho Wan Kwok 200 Park Avenue New York, NY 10166

Attn: Luc Despins PH LLP Tax ID No. 95-2209675

PH LLP Client/Matter # 50687-00013 Luc A. Despins

Legal fees for professional services for the period ending September 30, 2023 \$14,021.00

Total Balance Due - Due Upon Receipt \$14,212.85

We encourage our clients to pay via ACH, however, in the event that you pay by check, please send payment to the remittance address below:

*TO PROTECT AGAINST FRAUD, the Firm will not change its wiring instructions via email. We strongly encourage clients to confirm any change in wiring instructions by contacting Teri Goffredo @ 213-683-5045 or via email @ terigoffredo@paulhastings.com and requesting written and verbal confirmation.*

Wiring and ACH Instructions: Remittance Address: Pay by Tranch:

Citibank Paul Hastings LLP You can now pay your invoices online via ABA # 322271724 Lockbox 4803 real-time bank payments, credit cards or SWIFT Address: CITIUS33 PO Box 894803 in installments:

*For wires, please reference the invoice, client and matter number(s) being paid For ACH payments, please use the CTX format and/or send any remittances to cashepn@paulhastings com This is a no-reply mailbox*

Luc Despins as Chapter 11 Trustee in the case of Ho November 30, 2023

New York, NY 10166 Invoice Number: 2375616

Attn: Luc Despins PH LLP Tax ID No. 95-2209675

FOR PROFESSIONAL SERVICES RENDERED for the period ending September 30, 2023 Golden Spring Adversary Proceeding \$14,021.00

Date Initials Description Hours Rate Amount

09/05/2023 DM26 Review status report regarding Golden Spring (New York) Ltd. from DE-SOS 0.20 540.00 108.00 09/05/2023 DEB4 Further conference with E. Sutton regarding service issues 0.10 1,360.00 136.00 09/05/2023 DEB4 Analyze documents related to Golden Spring default judgement and service issues (0.3); conference with E. Sutton regarding

regarding same (0.2) 0.70 1,360.00 952.00 09/05/2023 DEB4 Correspond with N. Bassett regarding Golden Spring service and default issues 0.20 1,360.00 272.00 09/05/2023 DEB4 Correspond with J. Kosciewicz regarding document production 0.10 1,360.00 136.00 09/05/2023 DEB4 Conference with E. Sutton regarding service

09/05/2023 DEB4 Correspond with L. Despins regarding Golden Spring default 0.10 1,360.00 136.00

Case 22-50073 Doc 2935 Filed 02/19/24 Entered 02/19/24 20:04:06 Page 172 of 779

Luc Despins as Chapter 11 Trustee in the case of Ho Wan Kwok 50687-00013 Invoice No. 2375616

Date Initials Description Hours Rate Amount

09/05/2023 ECS1 Prepare request for entry of default in Golden Spring adversary proceeding (1.1); correspond with N. Bassett, D. Barron, and P. Linsey (NPM) regarding same (.8);

registered agents, resignation of registered agents, and service of the secretary of state (2.0); conferences with D. Barron regarding

09/05/2023 IC Research corporate information for Golden Spring (New York) Ltd. 0.50 400.00 200.00 09/05/2023 JK21 Correspond with E. Sutton regarding service of Golden Spring (New York) Ltd. 0.30 540.00 162.00 09/05/2023 AEL2 Correspond re: entry of default in Golden Spring adversary proceeding with L.

09/05/2023 NAB Correspond with P. Linsey (NPM), E.

service issues (.3); analyze authority relating to same (.2); call with D. Barron regarding

09/07/2023 ECS1 Prepare request for entry of default in Golden Spring adversary proceeding 0.20 1,045.00 209.00 09/08/2023 NAB Review draft motion for entry of default (.2); correspond with E. Sutton regarding

09/10/2023 ECS1 Prepare request for entry of default in Golden Spring adversary proceeding 1.50 1,045.00 1,567.50 09/11/2023 ECS1 Continue preparing request for entry of

proceeding (1.2); correspond with L.

regarding same (.4) 1.60 1,045.00 1,672.00 09/11/2023 NAB Review and revise request for entry of default (.3); correspond with E. Sutton 0.50 1,675.00 837.50

Case 22-50073 Doc 2935 Filed 02/19/24 Entered 02/19/24 20:04:06 Page 173 of 779

Date Initials Description Hours Rate Amount

09/12/2023 ECS1 Correspond with P. Linsey (NPM) regarding request for entry of default in Golden Spring adversary proceeding 0.30 1,045.00 313.50 09/20/2023 DEB4 Correspond with L. Despins regarding

09/20/2023 AEL2 Review default order 0.10 1,675.00 167.50 Subtotal: B191 General Litigation 12.40 14,021.00

ID Timekeeper Name Title Hours Rate Fee

NAB Nicholas A. Bassett Partner 1.50 1,675.00 2,512.50 AEL2 Luft, Avi E. Of Counsel 0.30 1,675.00 502.50 DEB4 Douglass E. Barron Associate 1.60 1,360.00 2,176.00 ECS1 Ezra C. Sutton Associate 8.00 1,045.00 8,360.00 JK21 Jocelyn Kuo Paralegal 0.30 540.00 162.00 DM26 David Mohamed Paralegal 0.20 540.00 108.00

Date Description Quantity Rate Amount

08/25/2023 UPS/Courier Service - UPS (USD)(JPMPCARD); 54.08 Invoice # 00000A6T163353; 08/25/2023;

ROAD; REPULSE BAY, 54000 ;

Luc Despins as Chapter 11 Trustee in the case of Ho Wan Page 4

08/25/2023 UPS/Courier Service - UPS (USD)(JPMPCARD); Invoice # 00000A6T163353; 08/25/2023; CHINA

09/29/2023 Copies of Documents - Jennifer Ash; 09/15/2023; International Transaction Fee - Document retrieval

S-215088); Merchant: International transaction 0.07 09/29/2023 Copies of Documents - Jennifer Ash; 09/15/2023; International Transaction Fee - Document retrieval

S-2010412); Merchant: International transaction 0.07 09/29/2023 Copies of Documents - Jennifer Ash; 09/15/2023; International Transaction Fee: Cost to view

ZHANG, Tong v YIN, Hang (VLC-S-S-215088).; Merchant: International transaction 0.07 09/29/2023 Copies of Documents - Jennifer Ash; 09/15/2023; International Transaction Fee: Cost to view

ZHANG, Tong v YIN, Hang (VLC-S-S-2010412).; Merchant: International transaction 0.07 09/29/2023 Copies of Documents - Jennifer Ash; 09/15/2023;

YIN, Hang (VLC-S-S-215088); Merchant: Court services bcgov; Orig Curr: CAD, Rate: 0.74, Orig

Case 22-50073 Doc 2935 Filed 02/19/24 Entered 02/19/24 20:04:06 Page 175 of 779

Luc Despins as Chapter 11 Trustee in the case of Ho Wan Page 5

09/29/2023 Copies of Documents - Jennifer Ash; 09/15/2023; Cost to view document: Document retrieval for

215088).; Merchant: Court services bcgov; Orig 09/29/2023 Copies of Documents - Jennifer Ash; 09/15/2023; Cost to view document: Document retrieval for 4.45

YIN, Hang (VLC-S-S-2010412); Merchant: Court services bcgov; Orig Curr: CAD, Rate: 0.74, Orig 09/29/2023 Copies of Documents - Jennifer Ash; 09/15/2023; 4.45

Case 22-50073 Doc 2935 Filed 02/19/24 Entered 02/19/24 20:04:06 Page 176 of 779

PAUL HASTINGS LLP 200 Park Avenue, New York, NY 10166-3205 t: +1.212.318.6000 f: +1.212.319.4090 www.paulhastings.com

Luc Despins as Chapter 11 Trustee in the case of Ho Wan Kwok 200 Park Avenue New York, NY 10166

Attn: Luc Despins PH LLP Tax ID No. 95-2209675

PH LLP Client/Matter # 50687-00014 Luc A. Despins

Legal fees for professional services for the period ending September 30, 2023 \$659,201.00

Total Balance Due - Due Upon Receipt \$669,591.40

We encourage our clients to pay via ACH, however, in the event that you pay by check, please send payment to the remittance address below:

*TO PROTECT AGAINST FRAUD, the Firm will not change its wiring instructions via email. We strongly encourage clients to confirm any change in wiring instructions by contacting Teri Goffredo @ 213-683-5045 or via email @ terigoffredo@paulhastings.com and requesting written and verbal confirmation.*

Wiring and ACH Instructions: Remittance Address: Pay by Tranch:

Citibank Paul Hastings LLP You can now pay your invoices online via ABA # 322271724 Lockbox 4803 real-time bank payments, credit cards or SWIFT Address: CITIUS33 PO Box 894803 in installments:

*For wires, please reference the invoice, client and matter number(s) being paid For ACH payments, please use the CTX format and/or send any remittances to cashepn@paulhastings com This is a no-reply mailbox*

Luc Despins as Chapter 11 Trustee in the case of Ho Wan Kwok 200 Park Avenue New York, NY 10166

Attn: Luc Despins PH LLP Tax ID No. 95-2209675

PH LLP Client/Matter # 50687-00014 Luc A. Despins

Legal fees for professional services for the period ending September 30, 2023 \$659,201.00

Total Balance Due - Due Upon Receipt \$669,591.40

We encourage our clients to pay via ACH, however, in the event that you pay by check, please send payment to the remittance address below:

*TO PROTECT AGAINST FRAUD, the Firm will not change its wiring instructions via email. We strongly encourage clients to confirm any change in wiring instructions by contacting Teri Goffredo @ 213-683-5045 or via email @ terigoffredo@paulhastings.com and requesting written and verbal confirmation.*

Wiring and ACH Instructions: Remittance Address: Pay by Tranch:

Citibank Paul Hastings LLP You can now pay your invoices online via ABA # 322271724 Lockbox 4803 real-time bank payments, credit cards or SWIFT Address: CITIUS33 PO Box 894803 in installments:

*For wires, please reference the invoice, client and matter number(s) being paid For ACH payments, please use the CTX format and/or send any remittances to cashepn@paulhastings com This is a no-reply mailbox*

Luc Despins as Chapter 11 Trustee in the case of Ho November 30, 2023

New York, NY 10166 Invoice Number: 2375617

Attn: Luc Despins PH LLP Tax ID No. 95-2209675

FOR PROFESSIONAL SERVICES RENDERED for the period ending September 30, 2023

Date Initials Description Hours Rate Amount

09/06/2023 LAD4 Review submissions and prepare outline for hearing (2.60); handle hearing (1.30); post mortem with N. Bassett (.30) 4.20 1,975.00 8,295.00 09/06/2023 NAB Call with L. Despins regarding results of hearing on motion for extension of time to answer and recap of deposition 0.30 1,675.00 502.50 09/29/2023 LAD4 T/c N. Bassett re: Tuesday's status conference (.30); t/c A. Luft & N. Bassett re: same (1.10) 1.40 1,975.00 2,765.00 09/29/2023 AEL2 Call with L. Despins and N. Bassett

conference (1.1); analyze strategy for same

Case 22-50073 Doc 2935 Filed 02/19/24 Entered 02/19/24 20:04:06 Page 179 of 779

Luc Despins as Chapter 11 Trustee in the case of Ho Wan Kwok 50687-00014 Invoice No. 2375617

Date Initials Description Hours Rate Amount

09/29/2023 NAB Call with L. Despins regarding HCHK intervention status conference (.3); review deposition transcripts in connection with same (.3); call with L. Despins and A. Luft

and prepare outline for hearing (.7);

regarding issues related to same (.2) 3.10 1,675.00 5,192.50 09/30/2023 Review and prepare hearing materials for status conference 2.70 855.00 2,308.50 Subtotal: B155 Court Hearings 13.10 21,408.50

09/01/2023 DEB4 Conference with P. Linsey (HCHK) regarding assignment language 0.10 1,360.00 136.00

09/01/2023 DEB4 Correspond with L. Despins regarding assignment language 0.20 1,360.00 272.00 09/01/2023 DEB4 Correspond with A. Lazans (Kroll) regarding HCHK documents 0.10 1,360.00 136.00 09/01/2023 DEB4 Analyze documents in connection with intervenor depositions 2.60 1,360.00 3,536.00 09/01/2023 DEB4 Conference with J. Kosciewicz and E.

09/01/2023 DEB4 Correspond with A. Luft regarding prep for intervenor depositions 0.10 1,360.00 136.00 09/01/2023 ECS1 Review proposed intervenors' production in HCHK adversary proceeding (.4); call with J. Kosciewicz regarding same (.4) 0.80 1,045.00 836.00

Case 22-50073 Doc 2935 Filed 02/19/24 Entered 02/19/24 20:04:06 Page 180 of 779

Luc Despins as Chapter 11 Trustee in the case of Ho Wan Kwok 50687-00014 Invoice No. 2375617

Date Initials Description Hours Rate Amount

09/01/2023 ECS1 Prepare deposition outlines for depositions

adversary proceeding (2.4); call with D.

09/01/2023 JPK1 Correspond with UnitedLex regarding

supplemental production (.1) 0.40 940.00 376.00 09/01/2023 JPK1 Correspond with N. Bassett regarding production and supplemental production of documents to HCHK intervenors (.3);

regarding the same (.3) 0.60 940.00 564.00 09/01/2023 JPK1 Telephone conference with E. Sutton and

09/01/2023 JPK1 Correspond with A. Luft regarding

09/01/2023 JPK1 Draft parts of HCHK deposition outline

09/01/2023 JPK1 Telephone conference with E. Sutton regarding HCHK deposition outlines 0.40 940.00 376.00 09/01/2023 LAD4 Review/edit opposition to extend time and default cross-motion 1.10 1,975.00 2,172.50 09/01/2023 AEL2 Prepare topic list and questions for HCHK

09/01/2023 Review documents provided by informant on funds related to Kwok and William Je 0.60 855.00 513.00 09/01/2023 Correspond with informant on HCHK

09/01/2023 Review documents provided by informant

additional Kwok related entities in Australia 0.50 855.00 427.50

Case 22-50073 Doc 2935 Filed 02/19/24 Entered 02/19/24 20:04:06 Page 181 of 779

Luc Despins as Chapter 11 Trustee in the case of Ho Wan Kwok 50687-00014 Invoice No. 2375617

Date Initials Description Hours Rate Amount 09/01/2023 NAB Review and revise draft objection to motion for extension of time to answer and crossmotion for default (.3); correspond with L. Despins and P. Linsey (NPM) regarding same (.1); correspond with regarding documents produced by informants related to same (.2); review documents and discovery issues in preparation for intervenor depositions (1.4); correspond with J. Kosciewicz regarding discovery issues (.2) 2.20 1,675.00 3,685.00 09/02/2023 DEB4 Prepare parts of proposed intervenor deposition outlines 6.40 1,360.00 8,704.00 09/02/2023 DEB4 Correspond with regarding HCHK related documents 0.30 1,360.00 408.00 09/02/2023 DEB4 Calls with E. Sutton regarding proposed intervenor deposition prep 0.30 1,360.00 408.00 09/02/2023 DEB4 Correspond with E. Sutton regarding reauthorization (0.1); analyze case law related to same (0.4) 0.50 1,360.00 680.00 09/02/2023 DEB4 Correspond with J. Kosciewicz regarding proposed intervenor deposition prep 0.30 1,360.00 408.00 09/02/2023 ECS1 Call with D. Barron regarding standard for recharacterization of loans in Second Circuit 0.10 1,045.00 104.50 09/02/2023 ECS1 Prepare deposition outlines for depositions of proposed intervenors in HCHK adversary proceeding (1.8); call with D. Barron regarding same (.2) 2.00 1,045.00 2,090.00 09/02/2023 JPK1 Continue drafting deposition outline for 1332156 B.C. Limited 8.40 940.00 7,896.00 09/02/2023 JPK1 Correspond with regarding HCHK deposition outlines 0.10 940.00 94.00 09/02/2023 LAD4 Call with and confidential informants re: HCHK background 1.10 1,975.00 2,172.50 09/02/2023 Review pictures of Xuebing Wang for the deposition 0.90 855.00 769.50

Date Initials Description Hours Rate Amount

09/02/2023 Prepare summary of phone call with

09/02/2023 Review loan agreements 0.30 855.00 256.50 09/02/2023 Call with informants and L. Despins on HCHK and additional Kwok-related entities (1.1); prepare notes summarizing same (.4) 1.50 855.00 1,282.50 09/02/2023 Correspond with informant on HCHK

09/02/2023 Correspond with D. Barron on HCHK

09/03/2023 DEB4 Conference with J. Kosciewicz regarding deposition of 1332156 B.C. Limited 0.20 1,360.00 272.00

intervenors and related depositions 0.20 1,360.00 272.00 09/03/2023 ECS1 Consider topics and questions for

HCHK adversary proceeding 0.30 1,045.00 313.50 09/03/2023 JPK1 Prepare parts of deposition outline for 1332156 B.C. (1.5); conference with D. Barron regarding the same (.2) 1.70 940.00 1,598.00 09/03/2023 LAD4 Review G Club-HCHK info from 1.40 1,975.00 2,765.00 09/03/2023 Review pictures of Yanchun Liu at certain

09/03/2023 NAB Review legal issues and associated

09/04/2023 DEB4 Analyze and comment on deposition outlines for proposed intervenors 2.80 1,360.00 3,808.00 09/04/2023 DEB4 Conference with J. Kosciewicz regarding proposed intervenors deposition prep 0.60 1,360.00 816.00 09/04/2023 DEB4 Correspond with A. Luft regarding Yu loan

09/04/2023 DEB4 Conference with N. Bassett regarding Yu

Case 22-50073 Doc 2935 Filed 02/19/24 Entered 02/19/24 20:04:06 Page 183 of 779

Date Initials Description Hours Rate Amount

09/04/2023 DEB4 Conference with E. Sutton regarding proposed intervenors deposition prep 0.40 1,360.00 544.00

09/04/2023 ECS1 Review discovery documents for

HCHK adversary proceeding 0.50 1,045.00 522.50 09/04/2023 ECS1 Prepare parts of outlines for depositions of

regarding same (.4) 3.30 1,045.00 3,448.50 09/04/2023 JPK1 Revise deposition outline for 1332156 B.C. to incorporate comments from D. Barron 1.70 940.00 1,598.00 09/04/2023 JPK1 Telephone conference with D. Barron

09/04/2023 JPK1 Review and tab deposition outline for 1332156 B.C. (1.1); prepare documents for

09/04/2023 JPK1 Draft parts of HCHK deposition outline

message translations for 1332156 B.C.

09/04/2023 AEL2 Review HCHK assertions re: operative Yu

09/04/2023 AEL2 Correspond with L. Despins re: depo

09/04/2023 AEL2 Call with N. Bassett re: proposed intervenors deposition strategy 0.20 1,675.00 335.00 09/04/2023 Review HCHK production on Relativity for the HCHK depositions 1.00 855.00 855.00

Case 22-50073 Doc 2935 Filed 02/19/24 Entered 02/19/24 20:04:06 Page 184 of 779

Luc Despins as Chapter 11 Trustee in the case of Ho Wan Kwok 50687-00014 Invoice No. 2375617

Date Initials Description Hours Rate Amount 09/04/2023 NAB Analyze legal issues and supplement outlines for HCHK depositions (2.5); review documents and topics in connection with same (1.1); call with D. Barron regarding same (.4); correspond with L. Despins regarding same (.1); call with A. Luft regarding same (.2) 4.30 1,675.00 7,202.50 09/05/2023 DEB4 Conferences with E. Sutton regarding deposition prep for proposed intervenors depositions 0.40 1,360.00 544.00 09/05/2023 DEB4 Correspond with A. Luft regarding GWGOPNZ deposition 0.10 1,360.00 136.00 09/05/2023 DEB4 Correspond with J. Kosciewicz regarding Yanchun Liu 0.10 1,360.00 136.00 09/05/2023 DEB4 Conference with J. Kosciewicz regarding 1332156 B.C. deposition 0.20 1,360.00 272.00 09/05/2023 DEB4 Correspond with L. Despins regarding Mr. Yu 0.10 1,360.00 136.00 09/05/2023 ECS1 Prepare parts of deposition outlines for depositions of proposed intervenors in HCHK adversary proceeding (2.9); calls with D. Barron regarding same (.4) 3.30 1,045.00 3,448.50 09/05/2023 ECS1 Review legal issues in preparing deposition outlines for proposed intervenors in HCHK adversary proceeding 0.80 1,045.00 836.00 09/05/2023 ECS1 Correspond with Cole Schotz and D. Barron regarding HCHK Entities and moving their property out of their leased space 0.10 1,045.00 104.50 09/05/2023 ECS1 Prepare appellee designation in HCHK AP rule 9019 order appeal (.9); correspond with 1.10 1,045.00 1,149.50

N. Bassett regarding same (.2) 09/05/2023 JPK1 Analyze statute of frauds concerns related to financial loan agreements (1.4); call with A. Luft regarding the same (.2) 1.60 940.00 1,504.00

Case 22-50073 Doc 2935 Filed 02/19/24 Entered 02/19/24 20:04:06 Page 185 of 779

Luc Despins as Chapter 11 Trustee in the case of Ho Wan Kwok 50687-00014 Invoice No. 2375617

Date Initials Description Hours Rate Amount

09/05/2023 JPK1 Correspond with UnitedLex regarding HCHK searches (.2); correspond with N.

production to HCHK intervenors (.2) 0.40 940.00 376.00 09/05/2023 JPK1 Conference with E. Sutton regarding

09/05/2023 JPK1 Correspond with D. Barron regarding HCHK deposition outline for 1332156 B.C. 0.10 940.00 94.00 09/05/2023 JPK1 Correspond with opposing counsel

production (.2); correspond with D. Barron regarding the same (.1) 0.30 940.00 282.00 09/05/2023 JPK1 Correspond with N. Bassett regarding

proposed intervenors (.1); correspond with E. Sutton regarding the same (.1) 0.20 940.00 188.00 09/05/2023 JPK1 Prepare parts of the HCHK 1332156 B.C. deposition outline (3.1); correspond with D. Barron regarding the same (.4) 3.50 940.00 3,290.00 09/05/2023 JPK1 Review documents from Trustee's Rule

production (2.4); correspond with N. Bassett regarding the same (.4); attend meet

proposed intervenors, N. Bassett, and A. Luft regarding document requests (.6) 3.40 940.00 3,196.00 09/05/2023 LAD4 Review discovery issues and strategy re:

09/05/2023 AEL2 Call with N. Bassett following meet and confer regarding next steps 0.50 1,675.00 837.50 09/05/2023 AEL2 Follow up correspondence with J.

09/05/2023 AEL2 Correspond with N. Bassett re: NZ

Date Initials Description Hours Rate Amount

09/05/2023 AEL2 Meet and confer with opposing counsel, N. Bassett, J. Kosciewicz re: objections to their requests for production 0.60 1,675.00 1,005.00 09/05/2023 AEL2 Review documents for proposed intervenor

09/05/2023 AEL2 Prepare outline for meet and confer on

09/05/2023 AEL2 Meet and confer with counsel for

09/05/2023 AEL2 Prepare outline for meet and confer re: their requests to Trustee/PH 0.20 1,675.00 335.00 09/05/2023 AEL2 Call with J. Kosciewicz re: legal issues related to lines of questions for 1332156

09/05/2023 AEL2 Analyze case findings on oral contract 0.40 1,675.00 670.00 09/05/2023 Correspond with informant on HCHK

09/05/2023 Analyze and translate documents from the 1332156 B.C. production 1.10 855.00 940.50 09/05/2023 Review and prepare translation of GWGOPNZ's loan transfer table 1.00 855.00 855.00 09/05/2023 Review information related to intervenors

09/05/2023 NAB Review documents and supplement outlines for additional intervenor depositions (3.9); meet and confer call with opposing counsel,

document requests (.6); call with A. Luft regarding same and related deposition issues

discovery in connection with same (.5);

document production issues (.2);

preparation for hearing on motion to 5.90 1,675.00 9,882.50

Case 22-50073 Doc 2935 Filed 02/19/24 Entered 02/19/24 20:04:06 Page 187 of 779

Luc Despins as Chapter 11 Trustee in the case of Ho Wan Kwok 50687-00014 Invoice No. 2375617

Date Initials Description Hours Rate Amount 09/06/2023 DM26 Review documents and exhibits for 9/8/23 deposition in the HCHK matter (.2); correspond E. Sutton re same (.1) 0.30 540.00 162.00 09/06/2023 DEB4 Conference with A. Luft and J. Kosciewicz regarding Yanchun Liu deposition prep (2.3); analyze documents related to same (3.2); further conferences with J. Kosciewicz regarding same (1.1); correspond with regarding same (0.1); analyze documents related to motion for extension of answer deadline (0.4); correspond with regarding same (0.1); correspond with L. Despins regarding same (0.3); conference with P. Linsey (NPM) regarding same (0.1); correspond with R. Jareck (CS) regarding bank records (0.1) 7.70 1,360.00 10,472.00 09/06/2023 ECS1 Attend deposition of witness Jie Zhang on behalf of proposed intervenor GWGOPNZ Limited in HCHK adversary proceeding (6.0); follow up review of deposition exhibits (.1) 6.10 1,045.00 6,374.50 09/06/2023 ECS1 Prepare appellee designation in appeal of HCHK rule 9019 order (.4); correspond with N. Bassett regarding same (.2); correspond with D. Barron regarding same (.1); call with P. Linsey (NPM) regarding same (.1) 0.80 1,045.00 836.00 09/06/2023 ECS1 Prepare documents and exhibits for depositions of proposed intervenors in HCHK adversary proceeding (.5); correspond with J. Kosciewicz regarding same (.3) 0.80 1,045.00 836.00 09/06/2023 JPK1 Telephone conferences with D. Barron regarding deposition outline for 1332156 B.C. 1.10 940.00 1,034.00

Date Initials Description Hours Rate Amount

09/06/2023 JPK1 Attend meet and confer with counsel for proposed intervenors and A. Luft regarding supplemental document production (.4);

09/06/2023 JPK1 Correspond with UnitedLex regarding HCHK search requests 0.10 940.00 94.00 09/06/2023 JPK1 Prepare parts of deposition outline for

09/06/2023 JPK1 Telephone conference with A. Luft and D.

09/06/2023 JPK1 Begin reviewing documents for potential responsiveness for supplemental production to HCHK proposed intervenors 0.90 940.00 846.00 09/06/2023 JPK1 Correspond with N. Bassett regarding

proposed intervenors 0.20 940.00 188.00 09/06/2023 JPK1 Revise HCHK 1332156 B.C. deposition outline (.5); review and prepare exhibits for

regarding the same (.1) 0.80 940.00 752.00 09/06/2023 AEL2 Meet with D. Barron and J. Kosciewicz re: 1332156 B.C. deposition prep 2.30 1,675.00 3,852.50 09/06/2023 AEL2 Correspond with D. Barron re: comments on 1332156 B.C. deposition outline 0.10 1,675.00 167.50 09/06/2023 AEL2 Review documents, proposed exhibits, and outline for 1332156 B.C. deposition (3.7); supplement outline (2.2); conferences with

deposition (.4) 6.30 1,675.00 10,552.50 09/06/2023 AEL2 Take deposition of NZ PMK witness (6.0);

deposition (.4) 6.40 1,675.00 10,720.00 09/06/2023 AEL2 Meet and confer with defendants and J.

documents and lack of waiver 0.40 1,675.00 670.00

Luc Despins as Chapter 11 Trustee in the case of Ho Wan Kwok 50687-00014 Invoice No. 2375617

Date Initials Description Hours Rate Amount

09/06/2023 Analyze information related to confidential

09/06/2023 Review and translate new production by

09/06/2023 Attend deposition of GWGOPNZ 6.00 855.00 5,130.00 09/06/2023 Correspond with Kroll regarding information related to 1332156 B.C. Ltd. 0.30 855.00 256.50 09/06/2023 NAB Supplement outline for GWGOPNZ deposition (.8); participate in deposition of GWGOPNZ (6.0); conferences with A. Luft regarding same (.4); correspond with

issues and additional depositions (.1);

same (.1); review appellee designations for

with E. Sutton regarding same (.1) 7.80 1,675.00 13,065.00 09/07/2023 DM26 Correspond with E. Sutton re 9/8/23 deposition of S. Hsin Yu (.2); call with E. Sutton regarding same (.2) 0.40 540.00 216.00 09/07/2023 DEB4 Take Yanchun Liu deposition (9.0);

regarding Yu deposition (1.7);

document production issues (0.4) 11.10 1,360.00 15,096.00 09/07/2023 DEB4 Conference with J. Kosciewicz regarding

09/07/2023 ECS1 Review documents and prepare outline and

, and D. Barron regarding same (1.7);

regarding same (.3); call with D. Mohamed regarding same (.2) 7.10 1,045.00 7,419.50 09/07/2023 ECS1 Review proposed intervenors' production in HCHK adversary proceeding (1.6);

Case 22-50073 Doc 2935 Filed 02/19/24 Entered 02/19/24 20:04:06 Page 190 of 779

Luc Despins as Chapter 11 Trustee in the case of Ho Wan Kwok 50687-00014 Invoice No. 2375617

Date Initials Description Hours Rate Amount

09/07/2023 ECS1 Review certain discovery documents in

(.5); correspond with J. Kosciewicz and D. Barron regarding same (.1) 0.60 1,045.00 627.00 09/07/2023 ECS1 Review legal issues in preparation for deposition of proposed intervenor 1332156 B.C. (.6); correspond with D. Barron and J. Kosciewicz re same (.4) 1.00 1,045.00 1,045.00 09/07/2023 JPK1 Review documents for potential responsiveness to supplemental production to HCHK proposed intervenors 1.20 940.00 1,128.00 09/07/2023 JPK1 Telephone conferences with D. Barron

production to HCHK proposed intervenors 0.60 940.00 564.00 09/07/2023 JPK1 Attend portion of deposition of HCHK proposed intervenor 1332156 B.C. 7.60 940.00 7,144.00 09/07/2023 JPK1 Correspond with E. Sutton regarding

intervenor supplemental production 0.50 940.00 470.00 09/07/2023 JPK1 Review and comment on exhibits used in deposition of 133156 B.C. 0.10 940.00 94.00 09/07/2023 JPK1 Correspond with N. Bassett regarding

proposed intervenors 0.20 940.00 188.00 09/07/2023 JPK1 Correspond with A. Lomas (Kroll)

HCHK proposed intervenors 0.20 940.00 188.00 09/07/2023 JPK1 Prepare parts of outline for 1332156 B.C.

09/07/2023 AEL2 Review documents for 1332156 B.C. deposition and outline 1.20 1,675.00 2,010.00 09/07/2023 AEL2 Take 1332156 B.C. intervener deposition 9.00 1,675.00 15,075.00 09/07/2023 AEL2 Review documents and supplement outline for Yu intervention deposition 3.20 1,675.00 5,360.00

, D. Barron and E. Sutton re: Yu deposition prep 1.70 1,675.00 2,847.50

Date Initials Description Hours Rate Amount

09/07/2023 AEL2 Call with N. Bassett re: Yu deposition

09/07/2023 Attend portion of deposition of Yanchun Liu, representative of 1332156 B.C. Ltd. 8.00 855.00 6,840.00 09/07/2023 Meeting with A. Luft, D. Barron and E. Sutton on Shih Hsin Yu deposition 1.70 855.00 1,453.50 09/07/2023 Correspond with confidential informant on

09/07/2023 Correspond with informant on Holy City

09/07/2023 Prepare parts of deposition outline for Shih

09/07/2023 NAB Correspond with A. Luft regarding intervenor depositions (.1); call with A. Luft regarding Yu deposition strategy (4) 0.50 1,675.00 837.50 09/08/2023 DEB4 Analyze documents in connection with Yu deposition (0.9); attend Yu deposition (7.0); conference with ============================================================================================================================================================== and objection to intervention motion (0.4);

with J. Shaban (Levine) regarding inquiry in connection with deposition schedule (0.1) 8.50 1,360.00 11,560.00 09/08/2023 ECS1 Prepare parts of outline for deposition of

adversary proceeding (1.7); correspond with

09/08/2023 ECS1 Attend deposition of proposed intervenor

09/08/2023 JPK1 Correspond with S. Phan (UnitedLex)

HCHK proposed intervenors 0.30 940.00 282.00 09/08/2023 PK1 Redact documents for supplemental production to HCHK proposed interveno 0.60 940.00 564.00

Case 22-50073 Doc 2935 Filed 02/19/24 Entered 02/19/24 20:04:06 Page 192 of 779

Luc Despins as Chapter 11 Trustee in the case of Ho Wan Kwok 50687-00014 Invoice No. 2375617

Date Initials Description Hours Rate Amount

09/08/2023 JPK1 Correspond with UnitedLex regarding

09/08/2023 JPK1 Attend telephone conference with Kroll

(.4); call with D. Barron regarding the same

09/08/2023 JPK1 Review bank documents for potential responsiveness for supplemental production to HCHK proposed intervenors (.8);

regarding the same (.3) 1.10 940.00 1,034.00 09/08/2023 AEL2 Outline objection brief to motion to intervene (1.2); call with S. Maza regarding

09/08/2023 AEL2 Take Yu intervention deposition 7.00 1,675.00 11,725.00 09/08/2023 AEL2 Prepare summary notes following Yu

09/08/2023 AEL2 Review documents and supplement outline for Yu deposition 1.60 1,675.00 2,680.00 09/08/2023 Meeting with D. Barron on Yu deposition and the objection to proposed intervenors' motion to intervene 0.40 855.00 342.00 09/08/2023 Attend deposition of Shih Hsin Yu, one of the proposed intervenors 7.00 855.00 5,985.00 09/08/2023 NAB Attend portion of intervenor deposition

09/08/2023 SM29 Call with A. Luft re objection to motion to

09/09/2023 JPK1 Correspond with A. Luft regarding response to motion to intervene 0.10 940.00 94.00 09/09/2023 JPK1 Correspond with opposing counsel

production to proposed intervenors 0.20 940.00 188.00

Date Initials Description Hours Rate Amount

09/09/2023 AEL2 Correspond with S. Maza and J. Kosciewicz

intervenors' motion to intervene 0.10 1,675.00 167.50 09/09/2023 Prepare outline for objection to motion to

09/09/2023 Correspond with UnitedLex on social

09/09/2023 Review NFSC weekly Saturday livestream which discussed the HCHK depositions 0.80 855.00 684.00 09/10/2023 ECS1 Follow up correspondence with Esquire

09/10/2023 JPK1 Telephone conference with A. Luft and S.

09/10/2023 JPK1 Analyze intervention under Bankruptcy Rule 1109 and related case law (2.1); draft parts of opposition to motion to intervene

09/10/2023 AEL2 Prepare notes regarding intervention objection (.1); meet with S. Maza and J.

motion to intervene (.9) 1.00 1,675.00 1,675.00 09/10/2023 NAB Review intervenor deposition transcript 0.60 1,675.00 1,005.00 09/10/2023 SM29 Call with A. Luft and J. Kosciewicz re intervention brief 0.90 1,360.00 1,224.00 09/11/2023 JPK1 Review GWGOPNZ deposition transcript

intervene (1.5); review Mr. Yu deposition transcript re same (1.3) 2.80 940.00 2,632.00 09/11/2023 JPK1 Correspond with D. Mohamed regarding transcript of GWGOPNZ deposition 0.10 940.00 94.00 09/11/2023 JPK1 Draft Luft declaration in support of opposition to motion to intervene 1.20 940.00 1,128.00 09/11/2023 JPK1 Correspond with M. McClammy regarding supplemental document production to the 0.10 940.00 94.00

Date Initials Description Hours Rate Amount

09/11/2023 JPK1 Draft parts of opposition to motion to

09/11/2023 KL12 Research dockets from Vancouver Law Courts regarding cases against Yin 0.60 400.00 240.00 09/11/2023 SM29 Review outline from J. Kosciewicz re objection to motion to intervene (.3); email

09/12/2023 DEB4 Conference with S. Maza regarding HCHK intervention objection (.2); prepare notes regarding issues to be redacted (.1) 0.30 1,360.00 408.00

09/12/2023 DEB4 Correspond with T. Rutherford (Pastore) regarding HCHK discovery issues 0.10 1,360.00 136.00 09/12/2023 DEB4 Correspond with A. Luft regarding HCHK document production 0.10 1,360.00 136.00 09/12/2023 ECS1 Investigate proposed intervenors and

summarizing same (.2) 0.90 1,045.00 940.50 09/12/2023 JPK1 Telephone conference with , D.

to motion to intervene 0.50 940.00 470.00 09/12/2023 JPK1 Analyze case law regarding interplay between Federal Rule of Civil Procedure 24 and Bankruptcy Rule 1109(b) 2.80 940.00 2,632.00 09/12/2023 JPK1 Prepare parts of opposition to motion to

09/12/2023 KC27 Call with S. Maza regarding opposition to motion to intervene (.3); review draft of

Date Initials Description Hours Rate Amount

09/12/2023 LAD4 T/c R. Jareck (Cole Schotz) re: request for

09/12/2023 AEL2 Correspond with T. Rutherford re: production of responsive diary document 0.40 1,675.00 670.00 09/12/2023 Conference with S. Maza, D. Barron and J.

09/12/2023 NAB Correspond with A. Luft regarding discovery issues (.2); review correspondence from opposing counsel regarding same (.1);

intervention motion (.2) 0.50 1,675.00 837.50 09/12/2023 SM29 Review background and outline from J.

motion (1.2); call with D. Barron re same (.2); call with K. Catalano re case law re same (.3); analyze intervention case law and application of Bankruptcy Rule 1109 (3.4) 5.10 1,360.00 6,936.00

, D. Barron, and J.

09/12/2023 WCF Correspond with J. Kosciewicz and N.

intervention motion 0.30 1,270.00 381.00 09/13/2023 ECS1 Prepare parts of objection to proposed

adversary proceeding (4.4); call with S.

regarding prudential standing and adequate

(1.9); prepare summary of findings for S.

09/13/2023 JPK1 Attend teleconference with S. Maza, E.

opposition to motion to intervene 0.70 940.00 658.00

Date Initials Description Hours Rate Amount

09/13/2023 JPK1 Continue preparing Luft declaration in

09/13/2023 JPK1 Correspond with K. Catalano regarding opposition to motion to intervene 0.20 940.00 188.00 09/13/2023 JPK1 Correspond with E. Sutton regarding opposition to motion to intervene 0.10 940.00 94.00 09/13/2023 JPK1 Incorporate E. Sutton's revisions to fact

intervene (1.1); correspond with E. Sutton regarding the same (.2) 1.30 940.00 1,222.00 09/13/2023 JPK1 Prepare parts of draft opposition to motion

09/13/2023 KC27 Analyze case law regarding standing for

findings on same (.8); correspond with S. Maza regarding same (.1); call with S. Maza regarding same (.3); attend meeting with S.

regarding response to motion to intervene (.7); analyze case law regarding permissive intervention (3.5); summarize same (1.1) 9.60 940.00 9,024.00 09/13/2023 NAB Analyze arguments in response to

connection with same (.3); prepare response to opposing counsel regarding same (.2) 1.00 1,675.00 1,675.00 09/13/2023 SM29 Analyze intervention issues and related case law and statutory authority (4.2); call with K. Catalano regarding same (.3); review and comment on draft objection to intervention motion (2.1); call with E. Sutton, K. Catalano, and J. Kosciewicz re same (.7); correspond with E. Sutton re same (.2); email E. Sutton, K. Catalano, and J.

and research issues in connection with same

Date Initials Description Hours Rate Amount

09/14/2023 DEB4 Correspond with W. Farmer regarding objection to motion to clarify TRO 0.10 1,360.00 136.00 09/14/2023 DEB4 Correspond with J. Kosciewicz regarding intervenor withdrawal 0.10 1,360.00 136.00 09/14/2023 DEB4 Correspond with E. Sutton regarding

09/14/2023 DEB4 Correspond with J. Kosciewicz regarding HCHK brief on Intervention 0.40 1,360.00 544.00

intervention objection 0.30 1,360.00 408.00 09/14/2023 DEB4 Conferences with J. Kosciewicz regarding intervention objection 0.40 1,360.00 544.00 09/14/2023 DEB4 Analyze intervention objections and related caselaw and statutory authority 2.80 1,360.00 3,808.00 09/14/2023 ECS1 Prepare objection to proposed intervenors'

proceeding (2.4); correspond with N. Bassett, S. Maza, D. Barron and J.

09/14/2023 JPK1 Calls with D. Barron regarding opposition to motion to intervene 0.40 940.00 376.00 09/14/2023 JPK1 Draft motion to seal opposition to proposed intervenor's motion to intervene 1.40 940.00 1,316.00 09/14/2023 JPK1 Correspond with P. Linsey (NPM)

for opposition to motion to intervene 0.10 940.00 94.00 09/14/2023 JPK1 Prepare sealed and unsealed exhibits for opposition to motion to intervene 2.70 940.00 2,538.00 09/14/2023 JPK1 Draft parts of opposition to motion to

09/14/2023 JPK1 Draft section for opposition to motion to intervene concerning obstructionists tactics used in deposition by Ms. Liu 1.70 940.00 1,598.00

Date Initials Description Hours Rate Amount

09/14/2023 JPK1 Review deposition transcript for Jie Zhang and revise citations to same in opposition to motion to intervene 0.60 940.00 564.00 09/14/2023 AEL2 Review draft objection to motion to