Guo Wengui / Miles Guo — bankruptcy case · ORDER · ECF #2936

UNITED STATES BANKRUPTCY COURT DISTRICT OF CONNECTICUT BRIDGEPORT DIVISION

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In re: :

HO WAN KWOK, et al., : :

Debtors1 :

----------------------------------------------------------- x **COVERSHEET RE: FOURTH INTERIM APPLICATION OF NEUBERT, PEPE & MONTEITH, P.C. FOR ALLOWANCE OF COMPENSATION AND REIMBURSEMENT OF EXPENSES AS LOCAL AND CONFLICTS COUNSEL TO THE CHAPTER 11 TRUSTEE AND AS COUNSEL TO DEBTORS GENEVER HOLDINGS CORPORATION AND GENEVER HOLDINGS LLC**

Time Period: September 1, 2023 through December 31, 2023

Bankruptcy Petition Filed: February 15, 2022

Date of Entry of Ret'n Orders: (i) Aug. 2, 2022 [ECF No. 669] (Kwok), effective a/o July 8, 2022, (ii) Nov. 17, 2022 [ECF No. 1107] (Genever Holdings Corp.), effective a/o Oct. 11, 2022; and (iii) Nov. 30, 2022 [ECF No. 1177] (Genever Holdings LLC), effective a/o Nov. 3, 2022.

Fees: \$1,038,670.00 Voluntary Fee Reductions: \$5,945.00

Total: \$1,073,379.63 Copies page cost: \$0.15/page; \$0.00 total

Fees Previously Requested: Expense Detail: Requested Fees: \$1,203,486.00 Retainer Received: \$0.00

\$1,117,968.502 Prior award applied: \$25,399.45

1 The Debtors in these chapter 11 cases are Ho Wan Kwok (also known as Guo Wengui, Miles Guo, and Miles Kwok, as well as numerous other aliases) (last four digits of tax identification number: 9595), Genever Holdings LLC (last four digits of tax identification number: 8202) and Genever Holdings Corporation. The mailing address for the Trustee, Genever Holdings LLC, and the Genever Holdings Corporation is Paul Hastings LLP, 200 Park Avenue, New York, NY 10166 c/o Luc A. Despins, as Trustee for the Estate of Ho Wan Kwok (solely for purposes of notices and communications).

2 In addition, NPM has been paid (a) \$96,168.00 as 80% of its fees for the month of September 2023 (after a \$945 voluntary reduction) pursuant to the September Monthly Fee Statement; (b) \$218,874.00 as 80% of its fees for the month of October 2023 pursuant to the October Monthly Fee Statement; and (c) \$231,512.00 as 80% of its fees for the month of November 2023 pursuant to the November Monthly Fee Statement. Hours and Rates per professional:

Kinsella 12/1991 Counsel 164.1 \$450.00 \$73,845.00 8 Douglas S. Skalka 10/1985 Partner 117.6 \$500.00 \$58,800.00 19 Dennis M. Carnelli 11/2013 Partner 420.2 \$450.00 \$189,090.00 41 Patrick R. Linsey 11/2010 Partner 906.6 \$450.00 \$407,970.00 7 Peter T. Fay 11/1990 Partner 27.9 \$450.00 \$12,555.00 82 James C. Graham 11/1984 Partner 71.6 \$450.00 \$32,220.00 20 Robert B. Flynn 08/1995 Partner 98.8 \$475.00 \$46,930.00

Jones N/A Paralegal 13.0 \$200.00 \$2,600.00 54 Sarah N. Smeriglio 11/2022 Associate 187.8 \$325.00 \$61,035.00 68 Kari Mitchell 06/2016 Counsel 276.1 \$400.00 \$110,440.00 28 Lauren T. Astone 11/2021 Associate 109.1 \$325.00 \$35,457.50

Ahumada N/A Paralegal 73.1 \$175.00 \$12,792.50

Dobson N/A Paralegal 4.4 \$200.00 \$880.00

Total Hours: 2,470.30 Total Fees (Prior to Voluntary Reductions): \$1,044,615.00 Blended Hourly Rate: \$422.87 UNITED STATES BANKRUPTCY COURT DISTRICT OF CONNECTICUT BRIDGEPORT DIVISION

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In re: :

HO WAN KWOK, :

Debtor. :

**FOURTH INTERIM APPLICATION OF NEUBERT, PEPE & MONTEITH, P.C., FOR ALLOWANCE OF COMPENSATION AND REIMBURSEMENT OF EXPENSES AS LOCAL AND CONFLICTS COUNSEL TO THE CHAPTER 11 TRUSTEE AND AS COUNSEL TO DEBTORS GENEVER HOLDINGS CORPORATION AND GENEVER HOLDINGS LLC**

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"), and 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"), Neubert, Pepe and Monteith, P.C. ("NPM"), as local and conflicts counsel to Luc A. Despins, in his capacity as the chapter 11 trustee (the "Trustee") appointed in the chapter 11 case (the "Chapter 11 Case") of Ho Wan Kwok (the "Individual Debtor"), and as counsel to the Debtors, Genever Holdings Corporation ("Genever (BVI)") and Genever Holdings LLC ("Genever (US)") in their chapter 11 cases (together with the "Chapter 11 Case," collectively, the "Chapter 11 Cases"), hereby files this *Fourth Interim Application of Neubert, Pepe and Monteith, P.C., as Local and Conflicts Counsel to the Chapter 11 Trustee and as Counsel to Debtors Genever Holdings Corporation and Genever Holdings LLC, for Allowance of Fees and Reimbursement Expenses for the Period from September* *1, 2023 through December 31, 2023* (the "Application"). By this Application, NPM requests interim allowance of professional fees and reimbursement of expenses incurred during the period from September 1, 2023, through and including December 31, 2023 (the "Application Period") in these Chapter 11 Cases. In support of this Application, NPM respectfully states as follows: JURISDICTION, VENUE, BASES FOR RELIEF, AND COMPLIANCE

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

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

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

- 4. Attached and incorporated herein by reference are the following Exhibits: - Exhibit A contains the Proposed Order granting this Application. - Exhibit B contains time entries with respect to the legal services provided organized by category (as discussed below). - Exhibit C contains expense reimbursements requested.

1 NPM 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.

I. The Individual Debtor's Chapter 11 Case

5. On February 15, 2022 (the "Petition Date"), the Individual Debtor filed a voluntary petition for relief under the Bankruptcy Code in the United States Bankruptcy Court for the District of Connecticut (Bridgeport Division) (the "Court").

6. On March 21, 2022, the United States Trustee appointed an Official Committee of Unsecured Creditors (the "Committee") in the Chapter 11 Case. No examiner has been appointed in the Chapter 11 Case.

7. On June 15, 2022, the Court entered a memorandum of decision and order [ECF 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.

8. 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.

9. By order entered August 2, 2022, the Court authorized NPM's retention as local and conflicts counsel for the Trustee [ECF No. 669] (the "Retention Order") effective as of July 8, 2022, in the Chapter 11 Case. The Retention Order authorizes NPM 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.

10. On October 11, 2022, Genever (BVI) filed a voluntary petition for relief under chapter 11 of the Bankruptcy Code with this Court.

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

12. On 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 [ECF No. 970].

13. On November 17, 2022, the Court granted Genever (BVI)'s application to retain NPM as counsel to Genever (BVI) in its chapter 11 case, effective as of its petition date, i.e., October 11, 2022 [ECF No. 1107].

14. On October 12, 2020, Genever (US) filed a voluntary petition for relief under chapter 11 of the Bankruptcy Code in the United States Bankruptcy Court for the Southern District of New York (the "SDNY Bankruptcy Court"), thereby commencing case number 20-12411 (JLG) (the "SDNY Bankruptcy Case").

15. On November 3, 2022, the SDNY Bankruptcy Court entered an order [ECF 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.

16. On November 21, 2022, the Court entered an order granting joint administration of the Genever (US) chapter 11 case with the jointly administered cases of the Individual Debtor and the Genever (BVI) Debtor's chapter 11 case [ECF No. 1141] (the Individual Debtor, Genever (BVI), and Genever (US) may hereinafter be collectively referred to as the "Debtors").

17. On November 30, 2022, the Court granted Genever (US)'s application to retain NPM 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 [ECF No. 1177]. IV. Prior Applications and Monthly Fee Statements

18. NPM sought the reimbursement of expenses incurred in its representation of the Trustee as local and conflicts counsel by application dated April 18, 2023, [ECF No. 1674] (the "Reimbursement Application"), which application was granted by order of this Court dated May 5, 2023, [ECF No. 1769].

19. By application dated June 1, 2023, NPM sought the allowance of fees for the period from the Petition Date through February 28, 2023 (the "First Interim Application") [ECF No. 1851]. The First Interim Application was granted by order of this Court dated June 29, 2023, allowing the Applicant interim compensation in the amount of \$551,718.50 [ECF No.1966].

20. By application dated August 4, 2023, NPM sought the allowance of fees and reimbursement of expenses for the period from March 1, 2023 through June 30, 2023 (the "Second Interim Application") [ECF No. 2053]. The Second Interim Application was granted by order of this Court dated September 12, 2023, allowing the Applicant interim compensation in the amount of \$357,587.50 and reimbursement of expenses in the amount of \$10,402.59 [ECF No. 2192].

21. By application dated October 18, 2023, NPM sought the allowance of fees and reimbursement of expenses for the period from July 1, 2023 through August 31, 2023 (the "Third Interim Application") [ECF No. 2260]. The Third Interim Application was granted by order of this Court dated November 30, 2023, allowing the Applicant interim compensation in the amount of \$280,180.00 and reimbursement of expenses in the amount of \$1849.10 [ECF No. 2410].

22. On October 20, 2023, pursuant to the Interim Compensation Procedures Order, NPM filed its *Monthly Fee Statement for Compensation and Reimbursement of Expenses for Period from September 1, 2023 Through September 30, 2023* [ECF No. 2268] (the "September Monthly Fee Statement") attaching NPM's itemized fees for the month of September 2023 and requesting payment of 80% of all fees for services rendered and 100% of all expenses incurred for such month (i.e., \$96,924.00 in fees and \$2,787.21 in expenses). In consultation with the United States Trustee, NPM consented to a \$945 reduction of the fees sought in its September Monthly Fee Statement (resulting in gross fees of \$120,210.00 with 80% payable in the amount of \$96,168.00). No objections were filed to NPM's September Monthly Fee Statement and by this Application NPM requests that the Court allow such fees in the amount of \$120,210.00, allow the expenses in full, and approve payment of the 20% fee holdback for such month (i.e., \$24,042.00) (the "September Holdback").

23. On November 20, 2023, pursuant to the Interim Compensation Procedures Order, NPM filed its *Monthly Fee Statement for Compensation and Reimbursement of Expenses for Period from October 1, 2023 Through October 31, 2023* [ECF No. 2356] (the "October Monthly Fee Statement") attaching NPM's itemized fees for the month of October 2023 and requesting payment of 80% of all fees for services rendered and 100% of all expenses incurred for such month (i.e., \$218,874.00 in fees and \$1,793.44 in expenses). No objections were filed to NPM's October Monthly Fee Statement and by this Application NPM requests that the Court allow such fees and expenses in full and payment of the 20% fee holdback for such month (i.e., \$54,718.50) (the "October Holdback").

24. On December 21, 2023, pursuant to the Interim Compensation Procedures Order, NPM filed its Monthly Fee Statement for Compensation and Reimbursement of Expenses

for Period from November 1, 2023 Through November 30, 2023 [ECF No. 2470] (the "November Monthly Fee Statement") attaching NPM's itemized fees for the month of November 2023 and requesting payment of 80% of all fees for services rendered and 100% of all expenses incurred for such month (i.e., \$231,512.000 in fees and \$11,906.41 in expenses). No objections were filed to NPM's November Monthly Fee Statement and by this Application NPM requests that the Court allow such fees and expenses in full and payment of the 20% fee holdback for such month (i.e., \$57,878.00) (the "November Holdback").

25. On February 5, 2024, pursuant to the Interim Compensation Procedures Order, NPM filed its *Monthly Fee Statement for Compensation and Reimbursement of Expenses for Period from December 1, 2023 Through December 31, 2023* [ECF No. 2572] (the "December Monthly Fee Statement") attaching NPM's itemized fees for the month of December 2023 and requesting payment of 80% of all fees for services rendered and 100% of all expenses incurred for such month (i.e., \$288,382.00 in fees and \$18,442.90 in expenses). To date, no objections have been filed to NPM's December Monthly Fee Statement2 and by this Application NPM requests that the Court allow such fees and expenses in full and payment of the 20% fee holdback for such month (i.e., \$72,095.50) (the "December Holdback" and together with the September Holdback, the October Holdback and the November Holdback, collectively, the "Application Period Holdback"). FOURTH INTERIM FEE APPLICATION OF PAUL HASTINGS LLP AND INCORPORATION BY REFERENCE

26. Paul Hastings LLP ("Paul Hastings") is lead counsel to the Trustee, Genever (BVI), and Genever (US) in these Chapter 11 Cases. As discussed herein, throughout the course of these Chapter 11 Cases, NPM has worked cooperatively with Paul Hastings as Connecticut counsel and

2 The objection period for this Monthly Fee Statement expires on February 26, 2024. Case 22-50073 Doc 2936 Filed 02/19/24 Entered 02/19/24 23:45:45 Page 10 of 230

conflicts counsel to the Trustee and as co-counsel with respect to Genever (BVI) and Genever (US) (collectively, the "Genever Debtors").

27. On February 19, 2024, Paul Hastings filed its *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* [ECF No. 2935 (the "PH Application"). The PH Application contains extensive discussion of the history of these Chapter 11 Cases and the nature of legal services performed for the Trustee and the Genever Debtors. To avoid repetition, NPM incorporates the PH Application herein by reference.

28. In the interest of efficiency and reducing administrative expense, throughout the Trustee's investigation and asset-recovery efforts, and the administration of these Chapter 11 Cases, the Trustee and Paul Hastings have requested and NPM has performed legal services with respect to substantive, administrative and procedural issues (e.g., preparing, reviewing and revising pleadings, presenting and arguing discovery motions, serving subpoenas and court orders, requesting adjournments and approving stipulations, preparing monthly operating reports, interacting with clerks' offices and chambers and coordinating logistics for hearings, and attending to other case administration functions as they arise). NPM's counsel has also advised with respect to this district's local rules and practices and has assisted the Trustee at court hearings throughout these Chapter 11 Cases.

29. This support has both ensured that the Trustee and the Genever Debtors understood and complied with local rules and practices—and has also resulted in substantial administrative cost savings in these Chapter 11 Cases.

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

31. For the Application Period, the Applicant seeks allowance of fees in the amount of \$1,038,670.00 as compensation for services rendered in connection with such services and expenses in the amount of \$34,929.96. This represents a voluntary reduction of \$5,945 from NPM's gross fees during the application period of \$1,044,615.00.

32. The Applicant devoted 2,470.30 hours to this case during the Application Period, equating to an overall blended rate of \$422.87.

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

34. Annexed hereto and made a part hereof as Exhibit B is a detailed billing report, broken down by project category, upon which this application is based that contains each individual professional's time for the Debtors' bankruptcy proceedings, itemizing the dates upon which services were rendered, including a summary of the services on each of such dates by each person rendering the service, the time spent in rendering such service, and the dollar value of such services.

35. Annexed hereto and made a part hereof as Exhibit C is a detailed report of costs and expenses incurred by the Applicant during the Application Period.

36. During the Application Period, the following summarizes the services provided by the Applicant on behalf of the Trustee:

a. advising the Trustee as to his investigation into the property of the Individual Debtor's estate, including his pursuit of actions to collect and recover property for the benefit of the Individual Debtor's estate;

b. commencing, conducting, and/or continuing litigation necessary and appropriate to assert rights held by the Individual Debtor's estate, protect assets of the Individual Debtor's estate, or otherwise further the goal of completing the Chapter 11 Case;

c. preparing and reviewing, on behalf of the Trustee, necessary and appropriate applications, motions, proposed orders, other pleadings, notices, schedules, and other documents, and reviewing financial and other reports filed and to be filed in the Chapter 11 Case;

d. advising the Trustee concerning, and preparing responses to, applications, motions, other pleadings, notices, and other papers that may be filed by other parties in the Chapter 11 Case;

e. reviewing the nature and validity of any liens asserted against the property in these Chapter 11 Cases and advising the Trustee concerning the enforceability of any liens;

f. assisting the Trustee in the investigation, recovery, marketing, and disposition of estate assets; and

g. negotiating with parties-in-interest. Case 22-50073 Doc 2936 Filed 02/19/24 Entered 02/19/24 23:45:45 Page 13 of 230

37. During the Application Period, the following summarizes the services performed by the Applicant as counsel to the Genever Debtors:

a. preparing, reviewing, and revising the monthly operating reports for the Genever Debtors; and

b. corresponding with the Genever (BVI) Director, the U.S. Trustee's office, the Trustee, and co-counsel regarding the monthly operating reports for the Genever Debtors. CATEGORIZATION OF SERVICES AND CATEGORY SUMMARIES

38. As is its practice as counsel to trustees or debtors in chapter 11 cases, NPM has organized its time by category in respect to the nature of the services it provided to the Trustee and the Genever Debtors. All services provided to the Genever Debtors fell within the Case Administration category, and thus this category is divided between services provided to the Trustee and to the respective Genever Debtors. More specifically, the services provided under each category and NPM's summaries of same are as follows: A. Case Administration: Fees: \$19,225 Total Hours: 42.80

39. NPM prepared, reviewed, revised and filed operating reports on behalf of the Genever Debtors. In connection with these services, NPM communicated with the Genever (BVI) Director, the Trustee, and co-counsel at Paul Hastings regarding issues related to the operating reports and bank statements for the Genever (US) account. In addition, certain of NPM's services with regards to compliance with outstanding Bankruptcy Rule 2004 discovery requests by Seacoast Bank and DBS Bank were included in this category. Case 22-50073 Doc 2936 Filed 02/19/24 Entered 02/19/24 23:45:45 Page 14 of 230 B. Asset Analysis and Recovery: Fees: \$333,205 Total Hours: 835.30

40. NPM performed services to assist the Trustee in investigating and seeking to recover assets for the benefit of the Debtors' chapter 11 estates. The Trustee has undertaken a broad-ranging investigation of assets that the Individual Debtor has sought to shield from his creditors.

41. Much of the Trustee's investigation has taken the form of Bankruptcy Rule 2004 examinations. NPM has pursued discovery from various parties, including banks, affiliated entities, and individuals to ascertain the extent of Debtor's assets and recover the same for the benefit of Debtor's estate.

42. During this time, NPM's counsel has issued numerous Bankruptcy Rule 2004 subpoenas and has assisted in obtaining and in reviewing documents and information produced in response thereto. In this process, NPM has served as conflicts counsel with respect to examinees where Paul Hastings has had conflicts (including numerous financial institutions and technology companies).

43. During the Application Period, NPM assisted in drafting the Trustee's seventh, eighth, ninth and tenth supplemental omnibus Bankruptcy Rule 2004 motions [ECF Nos. 2249, 2304, 2308, 2434]. The Court granted all of these Bankruptcy Rule 2004 motions.

44. G Club Operations LLC and the proposed intervenors from the HCHK Adversary Proceeding (as defined herein) objected to the eighth and ninth such motions [ECF Nos. 2319, 2320, 2326, 2331]. NPM prepared replies to these objections [ECF Nos. 2369, 2372], which resulted in the objections being withdrawn or overruled by the Court.

45. Some examinees have resisted compliance with the Trustee's Bankruptcy Rule 2004 subpoenas and NPM's professionals took appropriate action for the Trustee to obtain Case 22-50073 Doc 2936 Filed 02/19/24 Entered 02/19/24 23:45:45 Page 15 of 230

compliance as needed. During the Application Period, NPM counsel principally drafted motions to compel compliance with Bankruptcy Rule 2004 subpoenas against Seacoast Bank and DBS Bank. The Court granted the motion to compel Seacoast Bank, which has resulted in the Trustee obtaining document production from that respondent. The motion to compel DBS Bank has resulted (to date) in the Trustee achieving a cooperative posture with DBS Bank.

46. Significantly, without resort to motion practice, during the Application Period NPM worked with dozens of entities and individuals that received Bankruptcy Rule 2004 subpoenas to obtain documents and information to advance the Trustee's investigation. The documents and information collected were of paramount importance in, among other things, uncovering the Debtor's assets and preparing to commence adversary proceedings to prosecute claims to avoid transfers of the Debtor's funds and property of the Debtor's chapter 11 estate.

47. Also during the Application Period, NPM counsel identified (through analysis of Bankruptcy Rule 2004 discovery) approximately \$1.6 million in funds from a closed account in the name of the Debtor's alter ego, Golden Spring (as defined herein), at Axos Bank. During the Application Period, NPM counsel communicated with counsel for Axos Bank to investigate these funds and to ensure that they were secure. Since the Application Period, the Trustee has obtained these funds for the benefit of the Debtor's chapter 11 estate.

48. During the Application Period as part of this process, NPM has worked closely with professionals from Kroll, LLC ("Kroll"), the Trustee's forensic investigator, in order to ascertain further areas and subjects requiring investigation and to identify and close any "gaps" within the universe of documents and information obtained by the Trustee to date. NPM also worked cooperatively with Kroll to facilitate analysis of the documents and information obtained in the Case 22-50073 Doc 2936 Filed 02/19/24 Entered 02/19/24 23:45:45 Page 16 of 230

Trustee's Bankruptcy Rule 2004 investigation—which analysis has been leveraged in preparing and prosecuting the Trustee's litigation claims. C. Adversary Proceedings (and Related Appeals):

49. During the Application Period, NPM assisted the Trustee and Paul Hastings in the prosecution of numerous adversary proceedings and in appellate proceedings with respect to same. In addition, NPM took a primary role in the Mei Guo/Aircraft Proceeding. More specifically, NPM counsel performed the following services: (i) Greenwich Land Adv. Proc. 23-5005: Fees: \$14,340.00 Total Hours: 31.80

50. This adversary proceeding (the "Greenwich Land Adversary Proceeding") concerns the Trustee's claims against Greenwich Land LLC and Hing Chi Ngok (the Debtor's alleged wife) that the corporate defendant and its assets are property of the Estate. During the Application Period, NPM assisted Paul Hastings with respect to discovery matters and regarding the Trustee's opposition to the defendants' motion to withdraw the reference.

51. Likewise, during the Application Period, NPM assisted Paul Hastings in the preparation and prosecution of a motion for summary judgment against the defendants. This included, among other things, obtaining declarations from entities that had produced documents and information used to support the Trustee's motion for summary judgment. (ii) HK USA/Interpleader Adv. Proc. Nos. 22-5003,23-5012: Fees: \$16,890.00 Total Hours: 37.50

52. These adversary proceedings, i.e., Adv. Proc Nos. 22-5003 (the "HK Adversary Proceeding") and 23-05012 (the "Interpleader Proceeding") concern the Trustee's claims that HK USA and its assets are property of the estate and to recover such assets for the benefit of the estate. Case 22-50073 Doc 2936 Filed 02/19/24 Entered 02/19/24 23:45:45 Page 17 of 230

NPM counsel assisted in analyzing the HK Parties' brief in their appeal of the Court's orders granting the Trustee's summary judgment motions in the HK Adversary Proceeding. NPM counsel further assisted in researching and drafting portions of the Trustee's appellee brief in such appeal.

53. NPM counsel further assisted Paul Hastings with the Trustee's appellee designations in the HK Parties' appeal of the Court's summary judgment decision in the Interpleader Proceeding. (iii) Sherry Netherland Adv. Proc. 23-5002: Fees \$1,500.00 Total Hours: 3.40

54. This adversary proceeding (the "Sherry Netherland Possession Adversary Proceeding") relates to possession of the Debtor's penthouse apartment at the Sherry Netherland Hotel. During the Application Period, NPM assisted Paul Hastings in motion practice relating to the scheduling of proceedings. (iv) Mei Guo Adv. Proc 23-5008: Fees: \$420,357.50 Total Hours: 958.20

55. This adversary proceeding (the "Mei Guo/Aircraft Adversary Proceeding") relates to, among other things, the proceeds from the unauthorized postpetition sale of the Debtor's Bombardier Global XRS private jet. The Trustee has asserted claims including, among other things, that the private jet and its sale proceeds are property of the estate.

56. During the Application Period, NPM attorneys conducted document and deposition discovery in the Mei Guo/Aircraft Adversary Proceeding. This involved, among other things, (a) review and analysis of thousands of documents to prepare the Trustee's case and to respond to the defendant's requests for production of documents, (b) issuing at least eight subpoenas and obtaining and reviewing and analyzing additional document production in connection therewith, and (c) preparing for and conducting the depositions of the defendant, Anton Development Case 22-50073 Doc 2936 Filed 02/19/24 Entered 02/19/24 23:45:45 Page 18 of 230

Limited, Whitecroft Shore Limited, and Jetlaw LLC. NPM attorneys also prepared and prosecuted a motion related to the use of potentially privileged documents in this adversary proceeding. NPM attorneys likewise prepared and prosecuted several discovery-related motions, including successfully prosecuting several motions to compel.

57. Also during the Application Period, NPM attorneys prepared and prosecuted (a) a motion for a temporary restraining order/preliminary injunction, which the Court granted, resulting in more than \$10 million being returned to the United States from the United Kingdom. These funds are now held in escrow pending adjudication of the Mei Guo/Aircraft Adversary Proceeding. In addition, NPM attorneys prepared a motion for summary judgment (which was argued following the Application Period and is presently sub judice). (v) HCHK Adv. Proc. 23-5013: Fees: \$51,420.00 Total Hours:114.30

58. This adversary proceeding (the "HCHK Adversary Proceeding") concerns the "HCHK Entities," i.e., entities that the Trustee believes are alter egos of the Debtor that are in possession of more than \$38 million in assets. Prior to the Application Period, the Trustee obtained a temporary restraining order suspending state court proceedings that threatened to dissipate the HCHK Entities' assets.

59. During the Application Period, NPM's professionals assisted Paul Hastings attorneys in connection with the prosecution of the HCHK Adversary proceeding against the HCHK Entities. NPM attorneys prepared a motion for entry of default against certain defendants, which the Court granted on September 29, 2023.

60. NPM also assisted Paul Hastings in opposing the attempt by certain Kwok affiliated entities to intervene in this adversary proceeding, which required extensive preparation for and Case 22-50073 Doc 2936 Filed 02/19/24 Entered 02/19/24 23:45:45 Page 19 of 230

participation in an evidentiary hearing. The Court denied the motion to intervene on January 4, 2024. (vi) Mahwah Adv. Proc. 23-5017: Fees: \$7,677.50 Total Hours: 17.30

61. This adversary proceeding (the "Mahwah Adversary Proceeding") concerns certain entities owning a castle-style estate in Mahwah, New Jersey, and the Trustee's claims that, among other things, this asset is property of the estate.

62. During the Application Period, NPM assisted Paul Hastings in seeking 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.

63. Additionally, during the Fee Period, NPM assisted Paul Hastings in seeking 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. (vii) Golden Spring Adv. Proc. 23-5018: Fees: 19,467.50 Total Hours: 43.60

64. This adversary proceeding (the "Golden Spring Adversary Proceeding") concerns the Trustee's claims that an entity known as Golden Spring (New York) Ltd. (the "Golden Spring") which has funded millions of dollars of the Debtor's expenses is the Debtor's alter ego or is beneficially owned by the Debtor.

65. During the Application Period, NPM counsel, in consultation with Paul Hastings, prepared the Trustee's motion for entry of a default judgment against Golden Spring (and its nominal corporate parent), which (i) detailed the merits of Trustee's claims against the defendants, Case 22-50073 Doc 2936 Filed 02/19/24 Entered 02/19/24 23:45:45 Page 20 of 230

and (ii) summarized the sufficiency Trustee's service on the defendants, and the defendants' failure to respond and subsequent default. The Court granted the default judgment motion by order dated December 4, 2023. (viii) Lamp Capital Adv. Proc. 23-5023: Fees: \$15,575.00 Total Hours: 37.20

66. In this adversary proceeding (the "Lamp Capital Adversary Proceeding"), the Trustee sought, among other things, declaratory relief to the effect that Lamp Capital LLC ("Lamp Capital"), Infinity Treasure Management Inc. ("Infinity"), Hudson Diamond NY LLC, and Leading Shine NY Ltd, and their property, are property of the Debtor's chapter 11 estate. During the Application Period, as counsel for the Trustee and in consultation with Paul Hastings, NPM prepared and filed motions for default and for a default judgment against Lamp Capital and Infinity. The Court granted the motion by order dated February 1, 2024 [Docket No. 63 in Adv. Proc. 23-05023]. (ix) Ace Decade Holdings Limited Adv. Proc 23-5028 Fees \$1,270.00 Total Hours 2.90

67. In this adversary proceeding, the Trustee seeks to set aside the transfer of the outstanding share in Ace Decade Holdings Limited, which the Bankruptcy Court has found is beneficially owned by the Debtor, by Yanping Wang to Rui Hao. During the Application Period, NPM assisted Paul Hastings by preparing, reviewing and filing the adversary complaint commencing this action. D. Asset Disposition: Fees: \$9,360.00 Total Hours: 21.10

68. NPM performed services to assist the Trustee and Paul Hastings in contemplation of the sale of certain personal property that is property of the Debtors' chapter 11 estates, including, among other things, drafting motions and applications to approve procedures Case 22-50073 Doc 2936 Filed 02/19/24 Entered 02/19/24 23:45:45 Page 21 of 230

governing such sale and to employ professionals to assist with the sale process. In light of other developments in the Chapter 11 Case, these motions have not yet been filed, however, the Trustee may pursue such relief in the future. E. Retention and Fee Applications: Gross Fees: \$39,702.00 Total Hours: 88.50 Voluntary Reduction: \$5,000.00 Net Fees: \$34,702.00

69. NPM has assisted the Trustee and Paul Hastings in preparing and prosecuting a number of retention and fee applications during the Application Period. As an initial matter, during the Application Period, NPM prepared and prosecuted the Third Interim Application (as discussed above). NPM also prepared and filed the September Monthly Fee Statement, October Monthly Fee Statement, and November Monthly Fee Statement, as well as monthly fee statements relating to its fees and expenses in July 2023 and August 2023 [ECF Nos. 2178, 2217] all during the Application Period. NPM has voluntarily reduced its fees in connection with the preparation of its monthly fee statements and its Third Interim Application by five thousand dollars (\$5,000.00).

70. NPM's professionals also performed the initial drafting and assisted with the prosecution of the application to employ Kroll [ECF No. 2162], as well as Eisner Advisory Group, LLC [ECF No. 2282] as the Trustee and the Genever Debtors' accountant. And NPM assisted in the Trustee's search process to employ an accountant appropriate for the requirements of these Chapter 11 Cases.

71. Additionally, NPM's professionals assisted with the preparation and prosecution of fee applications for professionals including Harney Westwood & Riegels LP and Epiq Corporate Restructuring, LLC. NPM also coordinated responses to inquiries from the Committee and the United States Trustee regarding the services provided by Kroll, which resulted in these parties Case 22-50073 Doc 2936 Filed 02/19/24 Entered 02/19/24 23:45:45 Page 22 of 230

obtaining a greater understanding of Kroll's services and resolved any disputes over Kroll's fees without contested proceedings. F. Avoidance Action Analysis: Fees \$94,085.00 Hours 235.20

72. During the Application Period, NPM worked with the Trustee, Kroll and co-counsel at Paul Hastings to commence a thorough analysis of the potential avoidance actions held by the Debtor's chapter 11 estate and how these claims would be investigated and pursued. NPM's services in this area included the review of transferee information produced by Kroll and the preparation of draft complaints for pre- and postpetition claims held by the Debtor's estate under the Bankruptcy Code and applicable state laws, as well as conferences with the Trustee, Kroll professionals, and co-counsel at Paul Hastings regarding transfers and transferee information.

73. NPM's professional participated in the September 2023 court hearing which provided authorization for intercreditor lending between the Debtors' estates.

74. All of the professional services for which this award is being sought hereby were rendered solely on behalf of the Trustee and Genever Debtors in connection with the chapter 11 proceedings herein.

75. Applicant respectfully submits that its services have benefited the Trustee and the Genever Debtors with the expertise and skill required in the handling of bankruptcy matters. The legal services for which such compensation is requested were performed for and on behalf of the Trustee and the Genever Debtors. Such services have been necessary to protect and enforce the rights and interests of the Trustee and the Genever Debtors in connection with the Chapter 11 Case 22-50073 Doc 2936 Filed 02/19/24 Entered 02/19/24 23:45:45 Page 23 of 230

Cases. The reasonable value of services rendered by NPM in these proceedings is based upon NPM's usual hourly rates for matters of this nature.

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

77. 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).3

78. In determining the amount of "reasonable compensation," the Court must consider the nature, extent, and value of the services, taking into account all the relevant factors, including the time spent on such services, the rates charged for such services, whether the services were necessary and beneficial, whether the services were performed in a reasonable amount of time commensurate with the complexity, importance, and nature of the problem, issue, or task addressed, and whether the compensation is reasonable based on the customary compensation charged by comparably skilled practitioners in cases other than cases under the Bankruptcy Code.

3 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). Case 22-50073 Doc 2936 Filed 02/19/24 Entered 02/19/24 23:45:45 Page 24 of 230

See 11 U.S.C. § 330(a)(3). The Court enjoys "considerable discretion in determining reasonable fee awards." In re Ahead Communications Systems, Inc., 395 B.R. 512, 516 (D. Conn. 2008).

79. 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. 488 F.2d 714 (5th Cir. 1974) (abrogated on other grounds by Blanchard v. Bergeron, 489 U.S. 87 [1989]), 4 while also bearing in mind that a "reasonable, paying client wishes to spend the minimum necessary to litigate the case effectively." 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). 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.5 See In re Nine Assocs., Inc., 76 B.R. 943, 945 (S.D.N.Y. 1987) (adopting First Colonial/Johnson analysis); In re Cuisine Magazine, Inc., 61 B.R. 210, 212–13 (Bankr. S.D.N.Y 1986) (same); Green v. City of New York, 403 F. Appx. 626, 629 (2d Cir. 2010) (summary order); see generally 3 COLLIER ON BANKRUPTCY ¶ 330.03[9] (Lawrence P. King ed., 16th ed. 2016) (describing First Colonial and Johnson as the "leading cases with regard to the factors to be considered in determining a reasonable allowance of compensation").

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

4 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.

5 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).

55. No agreement or understanding exists between NPM and any other person for the sharing of compensation received or to be received for services rendered in or in connection with this matter. NPM will not, in any form or guise, share or agree to share compensation for services with any person, nor will NPM share in the compensation for any other person rendering service in these cases, except as so provided by Section 504(b) of the Bankruptcy Code and Rule 2016 of the Bankruptcy Rules.

56. NPM 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

Period?

Response: No. Question: If the fees sought in this application as compared to the fees

did 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 does include approximately 27.1 hours and associated fees of approximately \$11,850 related to preparing, reviewing, and revising NPM's monthly fee statements and ensuring time entries are properly categorized by matter number and task code. NPM notes that it has voluntarily reduced its fees in connection with the preparation and prosecution of monthly fee statements and fee applications by \$5,000.00.

- 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: (i) Did your client review and approve those rate increases in advance? (ii) 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 with ABA Formal Ethics Opinion 11-458? - Response: As is customary, NPM adjusts its hourly rates periodically based upon (i) the advancing seniority of its professionals and paraprofessionals, (ii) the current market for legal services, (iii) the rates charged for comparable non‐bankruptcy services, and (iv) the firm's analysis of the hourly rates being charged by professionals in other law firms. Effective January 1, 2023, NPM adjusted its hourly rates consistent with the Retention Order [Docket No. 668] and the Notice of Change in Hourly Rates of Neubert, Pepe & Monteith, P.C. [ECF No. 1258].

57. To the extent that time or disbursement charges for services rendered or expenses incurred during the Application Period are not included in this Application, or NPM has for any reason not sought compensation or reimbursement with respect to such services, NPM reserves the right to request compensation and reimbursement for such services in a supplemental or future application in these Chapter 11 Cases. Also, NPM 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.

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

[THE REMAINDER OF THIS PAGE IS INTENTIONALLY BLANK.] Case 22-50073 Doc 2936 Filed 02/19/24 Entered 02/19/24 23:45:45 Page 28 of 230

WHEREFORE, NPM respectfully requests entry of an order, substantially in the form attached hereto, (i) allowing interim compensation for professional services rendered during the Application Period in the amount of \$1,038,670.00, (ii) allowing compensation for expenses incurred in the amount of \$34,929.96, (iii) authorizing and directing prompt payment from the chapter 11 estate of the Individual Debtor of the Application Period Holdback, (iv) allowing such compensation and payment for professional services rendered without prejudice to NPM's right to seek further compensation and/or payment from the Debtors' estates for the full value of services performed and expenses incurred, and/or to seek release of any amounts that are subject to a holdback, and (v) granting NPM such other and further relief as is just.

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) 821-2000 dskalka@npmlaw.com plinsey@npmlaw.com

Counsel to Luc A. Despins, 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., : :

Debtors.1 : :

**[PROPOSED] ORDER GRANTING APPLICATION OF NEUBERT, PEPE & MONTEITH, P.C., FOR FOURTH INTERIM ALLOWANCE OF COMPENSATION AND REIMBURSEMENT OF EXPENSES AS LOCAL AND CONFLICTS COUNSEL TO THE CHAPTER 11 TRUSTEE AND AS COUNSEL TO DEBTORS GENEVER HOLDINGS CORPORATION AND GENEVER HOLDINGS LLC**

Upon consideration of the Application (the "Application") of Neubert, Pepe & Monteith, P.C. ("NPM") as counsel to the Trustee2 and the Genever Debtors for fourth interim allowance of compensation and reimbursement of expenses from September 1, 2023 through December 31, 2023; and sufficient notice having been given; and a hearing having been held on \_\_\_\_\_\_\_\_\_ and due consideration having been given to any responses thereto; and sufficient cause having been shown therefor, it is hereby:

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

\$1,038,670.00 and reimbursement of expenses in the amount of \$34,929.96 is awarded to NPM,

1 The Debtors in these chapter 11 cases are Ho Wan Kwok (also known as Guo Wengui, Miles Guo, and Miles Kwok, as well as numerous other aliases) (last four digits of tax identification number: 9595), Genever Holdings LLC (last four digits of tax identification number: 8202) and Genever Holdings Corporation. The mailing address for the Trustee, Genever Holdings LLC, and the Genever Holdings Corporation is Paul Hastings LLP, 200 Park Avenue, New York, NY 10166 c/o Luc A. Despins, as Trustee for the Estate of Ho Wan Kwok (solely for purposes of notices and communications).

2 Capitalized terms not otherwise defined herein adopt the definitions set forth in the Application. Case 22-50073 Doc 2936 Filed 02/19/24 Entered 02/19/24 23:45:45 Page 31 of 230

subject to final adjustment and disgorgement in the event all administrative expenses are not paid in full or as provided in the order approving the sale of the Lady May [ECF No. 1953]; it is further

2. ORDERED that the Debtors' estates are directed to pay the NPM the Application Period Holdback less the \$5,000.00 voluntary reduction (i.e., \$203,734.00) within fourteen days of the date of this Order; it is further

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

4. ORDERED that the Trustee and NPM are authorized and empowered to take all necessary actions to implement the relief granted in this Order; it is further

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

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

Date: 02/16/2024 Detail Fee Task Code Billing Report Page: 1 Case 22-50073 Doc 2936 Filed 02/19/24 Entered 02/19/24 23:45:45 Page 33 of

NEUBERT, PEPE & MONTEITH, P.C.

A111 500.00 0.20 100.00 Review draft August operating report

A111 500.00 0.20 100.00 Bankruptcy Representation Draft memorandum to attorney Sadler regarding

A111 500.00 0.30 150.00 Bankruptcy Representation

regarding security deposit information for

A107 450.00 0.30 135.00 Bankruptcy Representation Correspond with A. Bongartz and D. Skalka

further with D. Skalka regarding same (0.1)

A111 500.00 0.40 200.00 Bankruptcy Representation

A111 200.00 1.00 200.00 Bankruptcy Representation Attend to filing of the July 2023 and August 2023 monthly operating report and mailing of same to the parties not receiving electronic notice

A111 200.00 0.50 100.00 Bankruptcy Representation File the August 2023 monthly operating report. Attend to mailing copies of the file MOR to the parties not receiving notification electronically.

A105 475.00 0.20 95.00 Bankruptcy Representation

scheduling order for Golden Spring default

Despins, Ch 11 Trustee/Luc A.

A103 475.00 0.80 380.00 Ho Wan Kwok, Debtor Prepare service of scheduling order on default

Despins, Ch 11 Trustee/Luc A.

A105 475.00 0.40 190.00 Ho Wan Kwok, Debtor Conference with Attorney Skalka regarding efforts to meet and confer regarding JetLaw

Despins, Ch 11 Trustee/Luc A.

A105 475.00 0.50 237.50 Ho Wan Kwok, Debtor Conference with Attorney Linsey regarding

Despins, Ch 11 Trustee/Luc A.

A104 475.00 0.80 380.00 Ho Wan Kwok, Debtor Review materials supporting trustee's opposition

Despins, Ch 11 Trustee/Luc A.

A103 475.00 0.70 332.50 Ho Wan Kwok, Debtor Draft outline opposition to Jetlaw's motion to

Despins, Ch 11 Trustee/Luc A.

5248.001 11/01/2023 58 A B110 A111 200.00 1.20 240.00 Draft Notice for Hearing for Motion for

5248.001 11/02/2023 20 A B110 A103 475.00 4.70 2,232.50 Commence draft of opposition to Jetlaw's

Despins, Ch 11 Trustee/Luc A. Ho Wan Kwok, Debtor Date: 02/16/2024 Detail Fee Task Code Billing Report Page: 2 Case 22-50073 Doc 2936 Filed 02/19/24 Entered 02/19/24 23:45:45 Page 34 of

Despins, Ch 11 Trustee/Luc A.

B110 A103 475.00 0.20 95.00 Draft correspondence with Attorney E Sutton regarding service of order scheduling hearing on

Despins, Ch 11 Trustee/Luc A.

B110 A103 475.00 1.40 665.00 Ho Wan Kwok, Debtor Continue draft of opposition to Jetlaw motion to

Despins, Ch 11 Trustee/Luc A.

B110 A103 475.00 1.40 665.00 Ho Wan Kwok, Debtor

Despins, Ch 11 Trustee/Luc A.

B110 A105 475.00 0.30 142.50 Ho Wan Kwok, Debtor Conference with Attorney Skalka regarding

Despins, Ch 11 Trustee/Luc A.

B110 A105 475.00 0.30 142.50 Conference with Attorney Linsey regarding

Despins, Ch 11 Trustee/Luc A.

B110 A105 475.00 0.10 47.50 Conference with Attorney Linsey regarding

Despins, Ch 11 Trustee/Luc A.

B110 A111 500.00 0.30 150.00 Draft memorandum to co-counsel and T. Jones regarding bank statement for operating report

B110 A103 475.00 0.20 95.00 Correspondence with Attorney Linsey and Trustee regarding Opposition to Jetlaw Motion

B110 A111 500.00 0.30 150.00 Despins, Ch 11 Trustee/Luc A.

regarding local procedure on motion for order

B110 A111 500.00 0.30 150.00 Bankruptcy Representation Draft memorandum to attorney Sadler regarding

B110 A101 175.00 0.40 70.00 Draft 9th Supplemental Motion certificate of

Despins, Ch 11 Trustee/Luc A.

B110 A105 475.00 0.90 427.50 Attend team meeting with co-counsel on

Despins, Ch 11 Trustee/Luc A.

B110 A105 475.00 0.40 190.00 Conference with Attorney Linsey regarding

Despins, Ch 11 Trustee/Luc A.

B110 A103 475.00 0.50 237.50 Correspondence with Attorney Linsey and J Anthony regarding Seacoast Bank's position regarding production. Despins, Ch 11 Trustee/Luc A.

B110 A104 475.00 0.70 332.50 Review materials relevant to motion to compel

Date: 02/16/2024 Detail Fee Task Code Billing Report Page: 3 Case 22-50073 Doc 2936 Filed 02/19/24 Entered 02/19/24 23:45:45 Page 35 of

B110 A103 475.00 0.90 427.50 Despins, Ch 11 Trustee/Luc A.

Despins, Ch 11 Trustee/Luc A.

B110 A111 500.00 0.30 150.00 Ho Wan Kwok, Debtor Draft memorandum to Director with operating

B110 A109 475.00 0.60 285.00 Bankruptcy Representation

concerning Seacoast Bank's failure to comply

Despins, Ch 11 Trustee/Luc A.

B110 A105 475.00 0.90 427.50 Ho Wan Kwok, Debtor Conference with Attorney Linsey regarding

Despins, Ch 11 Trustee/Luc A.

B110 A104 475.00 0.80 380.00 Review materials supporting motion to compel Seacoast Bank to respond to subpoena without

Despins, Ch 11 Trustee/Luc A.

B110 A105 475.00 0.20 95.00 Conference with Attorney K Mitchell regarding

Despins, Ch 11 Trustee/Luc A.

B110 A103 475.00 0.20 95.00 Draft declaration and form of order supporting

Despins, Ch 11 Trustee/Luc A.

B110 A104 475.00 0.50 237.50 Review and revise motion to compel Despins, Ch 11 Trustee/Luc A.

B110 A103 475.00 0.20 95.00 Correspondence with Attorney J Anthony

Despins, Ch 11 Trustee/Luc A.

B110 A111 500.00 0.50 250.00 Review and revise September operating report

B110 A111 500.00 0.60 300.00 Draft memorandum to attorney Barron regarding September operating report(.3) ; review and

B110 A105 475.00 0.30 142.50 Conference with Attorney Linsey regarding

Despins, Ch 11 Trustee/Luc A.

B110 A104 475.00 1.10 522.50 Review and analyze documents relevant to the

Despins, Ch 11 Trustee/Luc A.

B110 A111 500.00 0.80 400.00 Review September operating report and draft memorandum to attorney Barron with report and

B110 A104 475.00 0.90 427.50 Review materials relevant to motion to compel Despins, Ch 11 Trustee/Luc A.

B110 A103 475.00 1.20 570.00 Outline motion to compel DBS Bank Despins, Ch 11 Trustee/Luc A. Date: 02/16/2024 Detail Fee Task Code Billing Report Page: 4 Case 22-50073 Doc 2936 Filed 02/19/24 Entered 02/19/24 23:45:45 Page 36 of

NEUBERT, PEPE & MONTEITH, P.C.

B110 A103 475.00 5.30 2,517.50 Ho Wan Kwok, Debtor

Despins, Ch 11 Trustee/Luc A.

B110 A105 475.00 0.30 142.50 Ho Wan Kwok, Debtor Confer with Attorneys P Linsey and K Mitchell regarding evidence in support of motion to

Despins, Ch 11 Trustee/Luc A.

B110 A106 450.00 1.00 450.00 Review agenda for call with client (.1); attend conference call with client regarding AP status,

Despins, Ch 11 Trustee/Luc A.

B110 A103 475.00 3.40 1,615.00 Review and revise motion to compel DBS Bank

Despins, Ch 11 Trustee/Luc A.

B110 A105 475.00 0.30 142.50 Confer with Attorneys P Linsey and K Mitchell regarding evidence in support of motion to

Despins, Ch 11 Trustee/Luc A.

B110 A103 475.00 0.80 380.00 Revise and finalize motion to compel DBS Bank's

Despins, Ch 11 Trustee/Luc A.

B110 A111 500.00 0.40 200.00 Ho Wan Kwok, Debtor Review operating report and draft memorandum to director and attorney Barron with draft report (.3); draft memo to T. Jones regarding filing (.1)

B110 A111 500.00 0.20 100.00 Draft memorandum to attorney Sadler regarding bank account information; draft memorandum to

Total for Phase ID B110 Billable 41.60 18,985.00 Case Administration

Phase ID B120 Asset Analysis and Recovery

B120 A108 325.00 0.10 32.50 Communicate (other external) e-mail to Capital One legal department providing subpoena and

Despins, Ch 11 Trustee/Luc A.

B120 A108 325.00 0.10 32.50 Communicate (other external) e-mail with Ashok

Despins, Ch 11 Trustee/Luc A.

B120 A108 325.00 0.20 65.00 Communicate (other external) telephone call with General Counsel for DBS Bank regarding status

Despins, Ch 11 Trustee/Luc A.

B120 A103 325.00 0.10 32.50 Update internal bank discovery memorandum Despins, Ch 11 Trustee/Luc A.

B120 A103 450.00 2.90 1,305.00 Correspond with N. Bassett and trustee regarding legal analysis of debtor's motion to stay bankruptcy proceedings (0.3), draft motion to expedite motion to enjoin debtor's stay motion (1.0), correspond and confer with trustee

Date: 02/16/2024 Detail Fee Task Code Billing Report Page: 5 Case 22-50073 Doc 2936 Filed 02/19/24 Entered 02/19/24 23:45:45 Page 37 of

NEUBERT, PEPE & MONTEITH, P.C.

Phase ID B120 Asset Analysis and Recovery regarding motion to enjoin motion to stay (0.2), proof/revise motion to enjoin motion to stay (0.4), attention to trustee comments and N. Bassett comments to motion to expedite and proof/revise same (0.4), finalize motion to enjoin debtor's motion to stay and motion to expedite

Despins, Ch 11 Trustee/Luc A.

A B120 A104 450.00 0.50 225.00 Review and analyze Y. Wang filing regarding bankruptcy (0.3), correspond with trustee and N. Bassett regarding same (0.1), correspond with

Despins, Ch 11 Trustee/Luc A.

A B120 A107 450.00 0.40 180.00 Correspond and confer with D. Barron regarding Bento discovery statements and supplemental production required (0.3), correspond with D. Barron regarding Capital One production (0.1) Despins, Ch 11 Trustee/Luc A.

A B120 A103 450.00 0.70 315.00 Draft/exchange e-mails with Bank of America's ("BoA") counsel regarding meet-and-confer and anticipated compliance deadline with amended 2004 subpoena (0.4); review BoA responses

meet-and-confer on 8/31/2023 in connection with responding to BoA's counsel (0.3). Despins, Ch 11 Trustee/Luc A.

A B120 A104 450.00 2.30 1,035.00 Review/analyze/comment on final draft from Attorney Linsey of motion to enjoin debtor from prosecuting motion to stay criminal proceedings in SDNY. Despins, Ch 11 Trustee/Luc A.

A B120 A103 450.00 4.20 1,890.00 Review and analyze Y. Wang's joinder filed in criminal proceeding, including review/analysis of underlying citations to bankruptcy record (0.8), draft amended stay violation motion addressing Y. Wang joinder (2.2), correspond and confer

regarding same (0.3), correspond with trustee and N. Bassett regarding amended stay violation motion (0.2), revise amended violation motion to

amended stay violation motion and attention to

Despins, Ch 11 Trustee/Luc A.

A B120 A103 450.00 2.70 1,215.00 Review and analyze debtor's objection to motion to expedite hearing on stay violation motion (0.2), correspond with trustee and N. Bassett regarding same and strategize response (0.4), draft reply to objection to motion to expedite regarding stay violation motion (1.1), correspond with trustee and N. Bassett regarding reply (0.2), revise reply and integrate trustee and N. Bassett comments/revisions (0.5), finalize reply and attention to filing and service of same (0.3) Despins, Ch 11 Trustee/Luc A.

Date: 02/16/2024 Detail Fee Task Code Billing Report Page: 6 Case 22-50073 Doc 2936 Filed 02/19/24 Entered 02/19/24 23:45:45 Page 38 of

NEUBERT, PEPE & MONTEITH, P.C.

Phase ID B120 Asset Analysis and Recovery

A B120 A108 325.00 0.10 32.50 Communicate (other external) follow-up e-mail to Capital One legal department regarding status

Despins, Ch 11 Trustee/Luc A.

A B120 A104 450.00 0.40 180.00 Ho Wan Kwok, Debtor Review/analyze debtor's objection to motion to

Despins, Ch 11 Trustee/Luc A.

A B120 A107 450.00 0.30 135.00 Correspond with D. Mohamed and trustee about materials/preparation for September 6 hearing Despins, Ch 11 Trustee/Luc A.

A B120 A108 325.00 0.20 65.00 Communicate (other external) e-mail to/from Ashok Singh regarding summary of uploaded

Despins, Ch 11 Trustee/Luc A.

A B120 A103 450.00 0.20 90.00 Draft e-mail to Ms. Ahumada regarding Sharefile transfer of supplemental Santander production to PH and Relativity. Despins, Ch 11 Trustee/Luc A.

A B120 A108 325.00 0.30 97.50 Communicate (other external) e-mail correspondence with Attorney Carnelli, Kelly Ahumada, Steve Phan regarding Santander Bank

Despins, Ch 11 Trustee/Luc A.

A B120 A108 325.00 0.10 32.50 Communicate (other external) follow-up voicemail for counsel for DBS Bank regarding

Despins, Ch 11 Trustee/Luc A.

A B120 A107 325.00 0.10 32.50 Communicate (other outside counsel) e-mail from counsel for Bank of America regarding

Despins, Ch 11 Trustee/Luc A.

A B120 A105 325.00 0.20 65.00 Communicate (in firm) correspond with Attorney Linsey and Attorney Skalka regarding Capital

Despins, Ch 11 Trustee/Luc A.

A B120 A103 450.00 0.20 90.00 Draft/revise e-mail in response to BoA counsel's

amended 2004 subpoena. Despins, Ch 11 Trustee/Luc A.

A B120 A105 325.00 0.20 65.00 Communicate (in firm) e-mail to/from Attorney Linsey, Attorney Skalka regarding Capital One

Despins, Ch 11 Trustee/Luc A.

A B120 A108 325.00 0.10 32.50 Communicate (other external) email to Capital

Despins, Ch 11 Trustee/Luc A.

A B120 A103 325.00 0.10 32.50 Draft/revise update internal memorandum

Despins, Ch 11 Trustee/Luc A.

A B120 A101 175.00 0.90 157.50 Prepare and serve chambers brief and appendix Despins, Ch 11 Trustee/Luc A. Date: 02/16/2024 Detail Fee Task Code Billing Report Page: 7 NEUBERT, PEPE & MONTEITH, P.C. Case 22-50073 Doc 2936 Filed 02/19/24 Entered 02/19/24 23:45:45 Page 39 of 230

Phase ID B120 Asset Analysis and Recovery

B120 A104 325.00 3.70 1,202.50 Ho Wan Kwok, Debtor Review/analyze Capital One production (642

Despins, Ch 11 Trustee/Luc A.

B120 A104 450.00 0.30 135.00 Review/analyze correspondence from Bank of

production. Despins, Ch 11 Trustee/Luc A.

B120 A104 450.00 0.40 180.00 Review/analyze file for 2004 subpoenas for documents and production letter from Capital One. Despins, Ch 11 Trustee/Luc A.

B120 A105 450.00 0.50 225.00 Communicate (in firm) with Attorney Astone regarding Capitol One production in response to 2004 subpoena. Despins, Ch 11 Trustee/Luc A.

B120 A104 450.00 1.90 855.00 Review and analyze PAX/Committee joinder (0.6),

PAX/Committee joinder and further jurisdictional research (0.8), correspond with I. Goldman (Committee) and N. Bassett regarding joinder (0.2), correspond with J. Sherman regarding 6th

reply (0.2), forward reply to J. Sherman at his

Despins, Ch 11 Trustee/Luc A.

B120 A104 450.00 0.30 135.00 Attention to remediation motion supplement

B120 A104 325.00 0.50 162.50 Continued review of Capital One statements

Despins, Ch 11 Trustee/Luc A.

B120 A104 450.00 1.20 540.00 Review and analyze appellants' reply brief (Mei

Despins, Ch 11 Trustee/Luc A.

B120 A104 450.00 1.50 675.00 Review/analyze appellants' reply brief in appeal docketed at 3:23-cv-00153 (KAD). Despins, Ch 11 Trustee/Luc A.

B120 A105 450.00 0.20 90.00 Correspond with D. Carnelli regarding appellants

Despins, Ch 11 Trustee/Luc A.

B120 A107 450.00 1.60 720.00 Correspond and confer and W. Farmer regarding staffing/workflow (0.2), review draft litigation task list and draft proposed updates regarding HK A.P./interpleader A.P./motion to enjoin criminal

Guo-jet proceeds A.P. (0.8), correspond and confer with E. Sutton and W. Farmer regarding further edits to task list (0.3), review and analyze

mandamus proceeding (0.2) and correspond with

Despins, Ch 11 Trustee/Luc A.

B120 A108 325.00 0.20 65.00 Correspond with Steven Phan and Wayne Clark

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Phase ID B120 Asset Analysis and Recovery Despins, Ch 11 Trustee/Luc A.

A B120 A107 325.00 0.80 260.00 Memorandum to counsel regarding summary of Capital One production (.4); e-mails to/from Attorney Sutton, Attorney Barron, and Attorney

Despins, Ch 11 Trustee/Luc A.

A B120 A103 325.00 0.10 32.50 Draft/revise update internal memorandum

Despins, Ch 11 Trustee/Luc A.

A B120 A104 450.00 2.40 1,080.00 Ho Wan Kwok, Debtor Review/analyze 2004 subpoena compliance from Bank of America for summary to co-counsel at Paul Hastings and upload to Relativity. Despins, Ch 11 Trustee/Luc A.

A B120 A104 450.00 2.00 900.00 Review and analyze memorandum from L. Astone regarding Capital One bank statements and transfers of interest (0.4), review and analyze

proceedings as relating to transactions in bank

regarding transactions in Capital One statements (0.2), correspond with L. Astone regarding Capital One memorandum (0.2), correspond with D. Barron and PHC1 regarding additional TBOP accounts believed to be outstanding re:

correspond with E. Sutton regarding same and

Despins, Ch 11 Trustee/Luc A.

A B120 A107 450.00 2.30 1,035.00 Review background memorandum and prepare for meet and confer with K. Mateo (Cao) (0.6),

meet-and-confer with K. Mateo and E. Sutton (0.7), correspond with E. Sutton regarding

follow-up correspondence (0.2), correspond with

regarding Sterling bank (0.2), correspond and confer with D. Barron regarding JPMC account

Despins, Ch 11 Trustee/Luc A.

A B120 A107 450.00 2.80 1,260.00 Correspond with PHC1 regarding Aug. 22 hearing transcript (0.1), correspond and confer with E. Sutton regarding Webster bank subpoena and conflicts check (0.2), correspond and confer

subpoena and conflicts check (0.2), correspond and confer with J. Ballerini regarding Webster conflicts check (0.3), correspond and confer with E. Sutton regarding further Webster conflicts check (0.2), correspond with E. Sutton regarding

correspond and confer with D. Carnelli and E. Sutton regarding Webster subpoena (0.2), review

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Phase ID B120 Asset Analysis and Recovery and analyze Webster draft RFP (0.4), correspond and confer with E. Sutton about revisions to Webster bank subpoena (0.2), revise Webster bank RFP (0.5), correspond and confer with E. Sutton regarding same (0.2), correspond with E. Cohan regarding service of Webster subpoena

Despins, Ch 11 Trustee/Luc A.

B120 A107 450.00 0.70 315.00 Ho Wan Kwok, Debtor Correspond and confer with trustee and N.

regarding staffing for adversary proceedings (0.1), confer with D. Carnelli regarding staffing for adversary proceedings and Mei Guo preliminary

Despins, Ch 11 Trustee/Luc A.

B120 A101 175.00 0.40 70.00 Preparation and service of Greenwich Land brief Despins, Ch 11 Trustee/Luc A.

B120 A104 450.00 2.30 1,035.00 Ho Wan Kwok, Debtor Attention to R. Fingold (Zhang) postponement of meet-and-confer and E. Sutton response and correspond with E. Sutton regarding same (0.2),

regarding Webster service and parameters of NPM involvement (0.2), analyze potentially unproduced JPMC records vis-à-vis subpoena

correspond with S. Kennedy (JPMC) regarding potentially unproduced records (0.3), analyze potentially unproduced TBOP records vis-à-vis

(0.5), correspond with A. Ostrowitz (TBOP) regarding potentially unproduced records (0.2), correspond with PHC1 and D. Barron regarding

Despins, Ch 11 Trustee/Luc A.

B120 A107 450.00 1.40 630.00 Attention to order denying motion for status

correspond with trustee and N. Bassett regarding same (0.2), litigation tasks conference call with W. Farmer, E. Sutton and PHC1 (0.5), confer with A. Luft and E. Sutton regarding rule 2004 discovery including Cao subpoena/deposition (0.5), correspond with E. Sutton regarding Zhang Rule 2004 continued meet and confer and other

Despins, Ch 11 Trustee/Luc A.

B120 A109 450.00 3.10 1,395.00 Prepare for hearing on remediation motion (0.7),

B120 A104 450.00 0.40 180.00 Review/analyze e-mails and correspondence

compliance/responses to 2004 subpoena. Despins, Ch 11 Trustee/Luc A.

B120 A104 450.00 0.20 90.00 Review/analyze status update from Attorney

compliance for JPMorgan Chase.

Phase ID B120 Asset Analysis and Recovery

A B120 A104 450.00 1.90 855.00 Despins, Ch 11 Trustee/Luc A.

Correspond with E. Sutton regarding J. Nealon (Zhang) meet-and-confer (0.2), correspond with E. Sutton regarding Webster Bank service (0.1), correspond with L. Fried regarding UBS update and to schedule discovery conference (0.2), confer with L. Fried regarding outstanding UBS discovery (0.4), review and analyze Court's decision granting 6th 2004 motion (0.3), confer with E. Sutton regarding same (0.1), correspond with J. Sherman regarding same (0.1) review motion to compel and related documents from

following court's discussion in hearing (0.3) and correspond with A. Luft and W. Farmer regarding

Despins, Ch 11 Trustee/Luc A.

B120 A111 500.00 0.40 200.00 Telephone Victor at J.P Morgan Chase regarding subpoena results and information (.2); draft memorandum to attorneys Linsey and Astone

Despins, Ch 11 Trustee/Luc A.

A B120 A105 325.00 0.20 65.00 Communicate (in firm) e-mails to/from Attorney Skalka, Attorney Linsey, and Attorney Carnelli

Despins, Ch 11 Trustee/Luc A.

A B120 A104 450.00 1.60 720.00 Correspond with N. Bassett regarding motion to compel in PAX v. Kwok (protestors) case (0.2), correspond and confer with E. Sutton regarding same (0.3), review and analyze Court's decision partially deciding motion to compel in main case (0.4), memorandum to trustee regarding motion

correspondence to S. Sarnoff and P. Friedman regarding developments in PAX v. Kwok case

Despins, Ch 11 Trustee/Luc A.

A B120 A107 450.00 2.10 945.00 Correspond with N. Bassett regarding prior motions to seal implicating privilege order (0.2), review and analyze motions to seal regarding foregoing (0.6), prepare for meet-and-confer with J. Nealon regarding Y. Zhang subpoena (0.4), confer with E. Sutton regarding same (0.2), meet-and-confer with J. Nealon and E. Sutton

Despins, Ch 11 Trustee/Luc A.

A B120 A101 175.00 1.10 192.50 Prepare and review 20 subpoenas for 6th Rule 2004 Exam. Despins, Ch 11 Trustee/Luc A.

A B120 A102 450.00 2.80 1,260.00 Review numerous items of correspondence and discovery memoranda/privilege logs regarding allegations by debtor in criminal court motions (2.4), correspond with N. Bassett/E. Sutton/A. Luft

Despins, Ch 11 Trustee/Luc A.

A B120 A107 450.00 1.20 540.00 Confer with K. Ahumada regarding preparation and service of subpoenas for sixth rule 2004

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Phase ID B120 Asset Analysis and Recovery

correspond with K. Ahumada regarding same (0.4), correspond and confer with E. Sutton regarding division of service of subpoenas (0.3),

Despins, Ch 11 Trustee/Luc A.

A B120 A104 450.00 2.20 990.00 Ho Wan Kwok, Debtor review and analyze trustee response to motion to stay (1.1), review and analyze debtor motion "for discovery" in criminal court and attention to correspondence regarding same (0.8), review and

Despins, Ch 11 Trustee/Luc A.

A B120 A107 450.00 2.20 990.00 Correspond with E. Sutton regarding Heinemeyer and Feng subpoenas (0.1), correspond with A.

supplemental production requested (0.2), review and analyze supplemental document production and discussion from TBOP (0.8), correspond with

subpoena (0.1), correspond with D. Barron regarding Kroll requests and TBOP supplemental production (0.2), confer with D. Barron regarding Kroll requests and Chase production issues (0.4), review and analyze Chase production regarding Kroll request and correspond with D. Barron

Despins, Ch 11 Trustee/Luc A.

A B120 A107 450.00 1.00 450.00 Standing litigation matters meeting with W. Farmer, J. Kosciewicz, and PHC1 (0.5), correspond

correspond with B. Wisotsky regarding service of I. Feng subpoena (0.2), correspond with E. Sutton regarding progress serving subpoenas (0.1) Despins, Ch 11 Trustee/Luc A.

A B120 A103 450.00 0.60 270.00 Confer with Attorney Linsey regarding status of banks-related 2004 subpoenas/discovery (0.2)

status of such discovery (0.4). Despins, Ch 11 Trustee/Luc A.

A B120 A104 450.00 0.20 90.00 Review/analyze state of MCB 2004 subpoena compliance. Despins, Ch 11 Trustee/Luc A.

A B120 A108 325.00 0.10 32.50 Communicate (other external) e-mail to counsel for DBS Bank regarding document production Despins, Ch 11 Trustee/Luc A.

A B120 A107 450.00 1.60 720.00 Correspond with D. Barron and E. Sutton regarding Kroll meeting (0.2), prepare for Kroll meeting regarding banks discovery (0.4), attend conference with E. Sutton, P. Parizek and other Kroll professionals regarding banks discovery (0.6), correspond and confer with D. Carnelli

correspond with B. Wisotsky regarding service of subpoena and Court's order granting 2004 exam

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Phase ID B120 Asset Analysis and Recovery

B120 A107 450.00 3.30 1,485.00 Despins, Ch 11 Trustee/Luc A.

Update internal discovery tracker regarding BOA/DBS/Bank of China/U.S.

Trust/Metropolitan Commercial Bank (0.9), correspond with L. Aylett and E. Sutton regarding CIBC request for revised form of subpoena and brief research regarding CIBC affiliates (0.4), correspond with J. Anthony regarding Seacoast subpoena/production (0.2), review E. Cohan

requesting clarification (0.3), correspond with M. Aguayo regarding Axos bank subpoena (0.2), correspond with C. Walls (Comerica) regarding request to issue amended subpoena clarifying bank name and correspond with E. Sutton (0.2),

amending Comerica subpoena (0.2), review and analyze UBS request for extension of time and correspond with trustee regarding same (0.3), review and analyze D. Carnelli further updates to discovery tracker and further revise same (0.4),

B120 A107 450.00 1.90 855.00 correspond with L. Flores regarding Metropolitan Commercial Bank outstanding production (0.2) Despins, Ch 11 Trustee/Luc A.

Attention to J. Anthony correspondence and lengthy return correspondence to J. Anthony (Seacoast) regarding 2004 investigation (0.4), correspond with K. Ahumada regarding service of Rule 2004 subpoenas (0.2), correspond with L. Aylett (CIBC) regarding CIBC subpoenas (0.2),

subpoenas and revise amended CIBC subpoenas (0.3), attention to revised Comerica subpoena and correspond with C. Walls regarding same

B120 A107 450.00 1.90 855.00 (0.2), correspond further with J. Anthony and C. Lackey regarding scheduling meet-and-confer (0.2), correspond with trustee regarding UBS requested extension (0.1), correspond with L. Fried (UBS) with responsive proposal for further

Despins, Ch 11 Trustee/Luc A.

Prepare for meet-and-confer with J. Sherman (0.3), attend meet-and-confer with J. Sherman and E. Sutton (0.5), prepare for meet-and-confer with W. Qahoush (First Bank of Abu Dhabi) (0.3), attend meet-and-confer with W. Qahoush (FBAD) (0.4), correspond with trustee and N. Bassett

projects (0.2), correspond and confer with R.

B120 A108 450.00 0.60 270.00 Flynn and D. Carnelli regarding meeting to discuss new NPM litigation projects (0.2) Despins, Ch 11 Trustee/Luc A.

Telephone conference with Trustee regarding APs. Despins, Ch 11 Trustee/Luc A.

B120 A104 450.00 0.40 180.00 Review/analyze internal memorandum for banks discovery/2004 compliance and update with contact information for outstanding subpoena

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Phase ID B120 Asset Analysis and Recovery Date Tkpr

compliance. Despins, Ch 11 Trustee/Luc A.

405.00 Correspond with E. Sutton regarding suspected accounts at banks in 6th 2004 exam motion (0.2), correspond with D. Carnelli regarding status of outstanding 2004 discovery (0.1), correspond with M. Boynton (Comerica) regarding PII for 2004 discovery targets (0.2), correspond with E. Sutton and A. Luft regarding further 2004 discovery motions (0.2), confer with A. Luft

990.00 Despins, Ch 11 Trustee/Luc A.

correspond with NPM litigation team regarding new litigation projects (0.2), prepare for litigation planning call with chapter 11 trustee (0.2), litigation planning call (regarding new NPM projects) with trustee, N. Bassett, A. Luft, D. Skalka, and R. Flynn (0.5), confer with D. Skalka regarding planning for preference/A.P. litigation (0.4), confer with D. Carnelli, L. Rocklin, M. Miller regarding planning new for NPM litigation projects (preference litigation and A.P.'s) (0.9) Despins, Ch 11 Trustee/Luc A.

495.00 Communicate (in firm) with Attorney Linsey, Flynn, Kinsella, and Fay regarding preference proceedings and adversary proceedings moving forward. Despins, Ch 11 Trustee/Luc A.

Attorney Barron, Attorney Linsey, and Attorney Fay regarding preference proceedings and state of adversary proceedings. Despins, Ch 11 Trustee/Luc A.

Review/analyze order approving retention of Kroll (ECF 2241). Despins, Ch 11 Trustee/Luc A.

405.00 Conference call with Attorney Linsey and others concerning avoidance action litigation and

Despins, Ch 11 Trustee/Luc A.

225.00 Conference call with Attorney Barron and Linsey

Despins, Ch 11 Trustee/Luc A.

765.00 Confer with D. Skalka, N. Kinsella, P. Fay, R. Flynn, D. Carnelli regarding new NPM litigation projects (1.0), confer with S. Smeriglio regarding background for new NPM litigation projects (0.4), correspond with ULX regarding Relativity access and orientation for additional NPM counsel (0.1),

Despins, Ch 11 Trustee/Luc A.

405.00 Confer with J. Anthony (Seacoast National Bank) regarding outstanding production (0.3), confer with H. Claiborn regarding Seacoast demand for

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NEUBERT, PEPE & MONTEITH, P.C.

Phase ID B120 Asset Analysis and Recovery

B120 A107 450.00 1.10 495.00 attorneys' fees (0.3), correspond with J. Anthony responding to demand for attorney's fees and further regarding subpoena compliance (0.3) Despins, Ch 11 Trustee/Luc A.

Correspond with L. Fried regarding settlement discussions as to subpoena compliance (0.3), correspond with J. Anthony (Seacoast National Bank) regarding subpoena service/compliance and potential motion practice (0.3), correspond with new NPM litigation counsel regarding Relativity orientation (0.2), correspond with ULX regarding same (0.1) correspond with D. Skalka and R. Flynn regarding litigation projects call with

Despins, Ch 11 Trustee/Luc A.

B120 A105 325.00 0.40 130.00 Confer with P. Linsey regarding affidavit in

Despins, Ch 11 Trustee/Luc A.

B120 A108 450.00 0.20 90.00 Ho Wan Kwok, Debtor

Despins, Ch 11 Trustee/Luc A.

B120 A107 450.00 1.10 495.00 Ho Wan Kwok, Debtor Correspond with L. Fried regarding outstanding UBS production and October hearing (0.3), attention to further production and review production letter from L. Fried (UBS) and correspond with L. Fried regarding same (0.2), correspond with L. Fried (UBS) and N. Bassett, W.

inadvertent production (0.4), review protective order and correspond further with N. Bassett and ULX regarding inadvertent production claim (0.2) Despins, Ch 11 Trustee/Luc A.

B120 A106 450.00 1.50 675.00 Prepare for trustee call regarding NPM litigation projects (0.5), correspond with R. Flynn and D. Skalka regarding trustee call regarding NPM litigation projects and briefly confer with R. Flynn regarding same (0.2), call with trustee, N. Bassett, D. Skalka regarding NPM litigation projects (0.3), confer with D. Skalka following trustee call regarding staffing NPM litigation projects (0.2), attention to discrepancy between UBS request and doc bates #s and correspond with L. Fried

Despins, Ch 11 Trustee/Luc A.

B120 A111 500.00 0.50 250.00 Attend call with client and co-counsel regarding avoidance action analysis, status of analysis, alter ego issues and status of current adversary

Despins, Ch 11 Trustee/Luc A.

B120 A111 500.00 0.20 100.00 Telephone attorney Linsey regarding results of call with client and plans for 10/3 office meeting Despins, Ch 11 Trustee/Luc A.

5248.001 10/02/2023 54 A B120 A104 325.00 0.40 130.00 Review preliminary injunction to prepare

5248.001 10/03/2023 41 A B120 A104 450.00 0.70 315.00 Correspond with A. Singh and L. Fried regarding

supporting affidavit Despins, Ch 11 Trustee/Luc A. Ho Wan Kwok, Debtor

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Phase ID B120 Asset Analysis and Recovery

confirmation of same (0.3), review and analyze

Despins, Ch 11 Trustee/Luc A.

B120 A103 325.00 0.90 292.50 Draft affidavit in support of motion for

Despins, Ch 11 Trustee/Luc A.

B120 A104 325.00 1.00 325.00 Collect, review and analyze exhibits to affidavit in

Despins, Ch 11 Trustee/Luc A.

B120 A109 325.00 0.70 227.50 Attend ULX document review orientation meeting with W. Clark, N. Kinsella, P. Linsey, and

Despins, Ch 11 Trustee/Luc A.

B120 A108 450.00 1.90 855.00 Communicate (other external) preparation and training on discovery data base (.7) preparation for and attendance at meeting with forensic accountants regarding ongoing reserach (1.2) Despins, Ch 11 Trustee/Luc A.

B120 A107 450.00 1.50 675.00 Confer with D. Barron regarding Cirrus records and correspond with D. Carnelli regarding same (0.2), review new banks rule 2004 motion and correspond with A. Luft and E. Sutton about

(Seacoast) to pursue subpoena compliance (0.1),

compliance and request meet and confer (0.2), correspond with H. Kang regarding Capital One wire transfer records (0.1), correspond with P. Parizek regarding First Bank of Abu Dhabi (0.2), correspond with PHC1 and D. Skalka regarding

correspond with E. Sutton and A. Luft regarding

Despins, Ch 11 Trustee/Luc A.

B120 A103 325.00 6.00 1,950.00 (.7) Review memorandum of law in support of temporary injunction, (5.3) Collect, review and analyze exhibits in affidavit in support of

Despins, Ch 11 Trustee/Luc A.

B120 A101 450.00 1.50 675.00 Plan and prepare for discovery - attend Relativity

Despins, Ch 11 Trustee/Luc A.

B120 A105 325.00 1.40 455.00 Conference with P. Linsey, D. Skalka, N. Kinsella, P. Fay, R. Flynn, and S. Smeriglio regarding

Despins, Ch 11 Trustee/Luc A.

B120 A105 450.00 2.40 1,080.00 Prepare for conference regarding adversary proceedings, avoidance claims, and further Rule 2004 discovery (0.8), conference with D. Skalka, N. Kinsella, P. Fay, R. Flynn, L. Astone, S. Smeriglio regarding adversary proceedings, avoidance

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Phase ID B120 Asset Analysis and Recovery claims, and further Rule 2004 discovery (1.4),

regarding org charts and correspond with NPM

Despins, Ch 11 Trustee/Luc A.

A B120 A107 450.00 1.50 675.00 Correspond with J. Anthony (Seacoast) regarding further pursuit of compliance with subpoena (0.2), correspond with M. Guarino (Metropolitan Commercial Bank) regarding further pursuit of compliance with subpoena (0.2), confer and

Metropolitan Commercial Bank discovery (0.2), correspond with E. Sutton and D. Barron about

meet-and-confer with R. Heinemeyer (0.3), meet-and-confer with R. Heinemeyer and E.

Despins, Ch 11 Trustee/Luc A.

A B120 A104 450.00 0.60 270.00 Review revised 7th Rule 2004 motion and RFPs for bank subpoenas (0.4), correspond with K. Ahumada regarding 7th Rule 2004 motion (0.2) Despins, Ch 11 Trustee/Luc A.

B120 A105 450.00 1.20 540.00 Prepare for and attendance at project planning

Despins, Ch 11 Trustee/Luc A.

A B120 A104 325.00 0.30 97.50 Ho Wan Kwok, Debtor Review/analyze charts reflecting key entities and individuals, their relationships, and relevant

Despins, Ch 11 Trustee/Luc A.

A B120 A108 325.00 0.10 32.50 Communicate (other external) e-mail to counsel for DBS Bank regarding status of document

Despins, Ch 11 Trustee/Luc A.

A B120 A105 325.00 0.30 97.50 Correspond with P. Linsey regrding research on

Despins, Ch 11 Trustee/Luc A.

A B120 A104 325.00 2.60 845.00 Ho Wan Kwok, Debtor

Despins, Ch 11 Trustee/Luc A.

A B120 A104 325.00 2.30 747.50 Continued review and analysis of caselaw on fraudulent conveyances in ponzi/fraud schemes Despins, Ch 11 Trustee/Luc A.

A B120 A107 450.00 1.10 495.00 Confer with E. Sutton regarding 7th Rule 2004 motion (0.1), attention to 7th Rule 2004 motion subpoenas (0.4), correspond with J. Ballerini, A. Lubin, E. Sutton regarding Webster service (0.2), correspond with J. Zarick (Webster) regarding Rule 2004 subpoena following Rule 45 subpoena (0.2), correspond with A. Ghekas (Seacoast

Despins, Ch 11 Trustee/Luc A.

A B120 A104 450.00 2.20 990.00 Correspond with E. Sutton regarding Casper Firm 9019 motion (0.2), review and finalize Casper Firm 9019 motion and motion to limit service

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Phase ID B120 Asset Analysis and Recovery and attention to filing same (0.8), review and analyze production from Seacoast National Bank (0.8), correspond with D. Barron regarding key findings from Seacoast National Bank production (0.3), correspond with ULX regarding Seacoast

Despins, Ch 11 Trustee/Luc A.

A104 450.00 1.00 450.00 Ho Wan Kwok, Debtor Review/analyze Motion to Withdraw Reference

Despins, Ch 11 Trustee/Luc A.

A104 450.00 0.80 360.00 Review and analyze debtor's reply to debtor's opposition to debtor's (criminal court) motion to

response to government regarding the Mahwah

Despins, Ch 11 Trustee/Luc A.

A107 325.00 0.10 32.50 Communicate (other outside counsel) e-mail to

Despins, Ch 11 Trustee/Luc A.

A107 450.00 0.20 90.00 Confer with D. Barron regarding Seacoast and

Despins, Ch 11 Trustee/Luc A.

A101 175.00 0.60 105.00 Confer regarding 2004 subpoena tracker with

Despins, Ch 11 Trustee/Luc A.

A104 325.00 0.90 292.50 Revise exhibit descriptions in affidavit in support

Despins, Ch 11 Trustee/Luc A.

A101 175.00 0.40 70.00 Prepare 6 subpoenas for 7th Rule 2004 Exam Despins, Ch 11 Trustee/Luc A.

A103 325.00 0.80 260.00 Research regarding service under FRCP 45 Despins, Ch 11 Trustee/Luc A.

A101 175.00 1.80 315.00 Create 2004 subpoena tracker and populate with 6th and 7th supplemental information to review

Despins, Ch 11 Trustee/Luc A.

A105 450.00 1.20 540.00 Correspond with K. Ahumada regarding 7th Rule 2004 motion (0.2), review subpoena/exhibit package from K. Ahumada for 7th Rule 2004 motion (0.2), confer with K. Ahumada regarding

discovery tracker (0.6), correspond with P. Parizek and D. Barron regarding G Club bank statements

Despins, Ch 11 Trustee/Luc A.

A106 450.00 1.90 855.00 Prepare for conference with trustee regarding NPM litigation projects and avoidance analysis (0.7), confer with D. Skalka regarding trustee conference (0.3), confer with trustee and D. Skalka regarding NPM litigation projects and avoidance analysis (0.4), attend litigation meeting with W. Farmer and PH litigation team (0.5) Despins, Ch 11 Trustee/Luc A. Date: 02/16/2024 Detail Fee Task Code Billing Report Page: 18 Case 22-50073 Doc 2936 Filed 02/19/24 Entered 02/19/24 23:45:45 Page 50 of

Phase ID B120 Asset Analysis and Recovery

B120 A111 500.00 0.30 150.00 Ho Wan Kwok, Debtor Telephone conference with Attorney Linsey regarding staffing issues on avoidance analysis

Despins, Ch 11 Trustee/Luc A.

B120 A111 500.00 1.10 550.00 Ho Wan Kwok, Debtor Telephone attorney Linsey in advance of client call regarding United Lex and Kroll information (.3); attend conference call with client and

analysis and Rule 2004 discovery and adversary

Despins, Ch 11 Trustee/Luc A.

B120 A103 450.00 7.20 3,240.00 Draft/revise Objection to Motion to Withdraw

Despins, Ch 11 Trustee/Luc A.

B120 A102 325.00 3.80 1,235.00 Research regarding service of subpoenas on

Despins, Ch 11 Trustee/Luc A.

B120 A101 175.00 2.20 385.00 Ho Wan Kwok, Debtor Attention to service regarding 7th Supplemental

Despins, Ch 11 Trustee/Luc A.

B120 A107 450.00 1.70 765.00 Ho Wan Kwok, Debtor

regarding 2004 subpoena (0.1), correspond with K. Ahumada regarding draft 2004 discovery tracker and review tracker (0.2), revise and finalize 7th Rule 2004 motion and attention to filing same (0.6), correspond with E. Sutton

regarding service of 7th Rule 2004 motion (0.2), correspond with P. Parizek regarding further HCHK production (0.2), confer with E. Sutton regarding 7th Rule 2004 motion and 8th Rule

Despins, Ch 11 Trustee/Luc A.

B120 A107 450.00 0.40 180.00 Correspond with E. Sutton regarding Y. Zhang subpoena compliance (0.2), correspond with A. Luft and E. Sutton regarding S. Barnett request

Despins, Ch 11 Trustee/Luc A.

B120 A103 450.00 3.00 1,350.00 Draft/revise Objection to Motion to Withdraw Reference (2.8); t/c Attorney Linsey and Attorney

Despins, Ch 11 Trustee/Luc A.

B120 A107 450.00 1.00 450.00 Correspond with E. Sutton regarding Casper 9019 motion (0.2), draft certificate of service

notice pursuant to order limiting notice and attention to filing same (0.3), confer with E. Sutton regarding 8th rule 2004 motion and correspond with E. Sutton regarding same (0.2), draft certificate of service for 7th Rule 2004 exam and correspond with E. Sutton regarding same

Despins, Ch 11 Trustee/Luc A.

B120 A103 450.00 0.50 225.00 Ho Wan Kwok, Debtor Draft/revise Objection to Motion to Withdraw

Date: 02/16/2024 Detail Fee Task Code Billing Report Page: 19 Case 22-50073 Doc 2936 Filed 02/19/24 Entered 02/19/24 23:45:45 Page 51 of

Phase ID B120 Asset Analysis and Recovery

Despins, Ch 11 Trustee/Luc A.

B120 A107 450.00 0.70 315.00 Finalize COS regarding 7th Rule 2004 motion, attention to filing same (0.2), correspond with E. Sutton regarding 8th Rule 2004 motion (0.2),

regarding subpoenas for same (0.1), confer with trustee regarding East West Bank subpoena

Despins, Ch 11 Trustee/Luc A.

B120 A111 500.00 0.30 150.00 Meet with Attorney Linsey regarding status of bank discovery , Kroll analysis and review of bank

Despins, Ch 11 Trustee/Luc A.

B120 A111 500.00 0.50 250.00 Ho Wan Kwok, Debtor

regarding review of bank discovery and status of

Despins, Ch 11 Trustee/Luc A.

B120 A107 450.00 2.00 900.00 Correspond with N. Bassett, A. Luft and trustee

production (0.2), attention to court orders moving hearings to remote basis and confer with trustee and A. Smith regarding same (0.2),

subpoena/discovery dispute (0.2), confer with L. Fried regarding UBS discovery dispute (0.4), correspond with court clerk and with trustee and PH counsel regarding remote hearing (0.2), confer with D. Skalka and K. Mitchell regarding Rule 2004 investigation/open subpoenas/and

Despins, Ch 11 Trustee/Luc A.

B120 A111 500.00 0.60 300.00 Review draft July and August operating reports and draft memorandum to client and attorney

B120 A109 450.00 2.70 1,215.00 Correspond and confer with L. Fried regarding

agreement regarding same (0.2), correspond and confer with trustee regarding UBS agreement (0.1), prepare for hearing on UBS motion to compel and Taurus and Golden Spring pretrial conferences (0.6), confer with A. Luft regarding Golden Spring pretrial (0.1), attend remote hearing (1.3), correspond with trustee and PH team regarding workflow (0.2), attention to inquiry from G&S Security and correspond with

Despins, Ch 11 Trustee/Luc A.

B120 A111 500.00 0.40 200.00 Attend relativity training session with United Lex

Despins, Ch 11 Trustee/Luc A.

B120 A108 325.00 0.40 130.00 Communicate (other external) e-mails to/from E.

Despins, Ch 11 Trustee/Luc A.

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NEUBERT, PEPE & MONTEITH, P.C.

Phase ID B120 Asset Analysis and Recovery

A105 450.00 0.40 180.00 Correspond and confer with D. Skalka regarding litigation projects between October 18-30 Despins, Ch 11 Trustee/Luc A.

A102 400.00 1.00 400.00 Ho Wan Kwok, Debtor Review and analyze loan agreements re airplane

A105 400.00 0.10 40.00 Despins, Ch 11 Trustee/Luc A.

Despins, Ch 11 Trustee/Luc A.

A105 450.00 0.80 360.00 Communicate (in firm) with Attorney Skalka

banks-related discovery, and review e-mail communications from Paul Hastings regarding the same. Despins, Ch 11 Trustee/Luc A.

A104 450.00 2.10 945.00 Review/analyze Relativity banks-related discovery production to date in connection with KYC and related documentation. Despins, Ch 11 Trustee/Luc A.

A104 450.00 2.00 900.00 Ho Wan Kwok, Debtor Review/analyze new targets for bank-related production and communications regarding the same, and begin formulating plan for review of documents already received. Despins, Ch 11 Trustee/Luc A.

A111 500.00 0.60 300.00 Ho Wan Kwok, Debtor Telephone attorney Luft regarding telephone records issue(.3); draft memorandum to attorney Luft and client regarding additional review of

Despins, Ch 11 Trustee/Luc A.

A111 500.00 0.40 200.00 Ho Wan Kwok, Debtor Draft memorandum to attorney Luft and client regarding additional bank discovery and new rule

Despins, Ch 11 Trustee/Luc A.

A111 500.00 0.40 200.00 Draft memorandum to attorney Mitchell

Despins, Ch 11 Trustee/Luc A.

A104 450.00 0.80 360.00 Review/analyze list of additional 2004 targets and rationale therefor. Despins, Ch 11 Trustee/Luc A.

A103 450.00 0.30 135.00 Draft/revise and review correspondence

Despins, Ch 11 Trustee/Luc A.

A104 450.00 0.70 315.00 Review/analyze loan agreement Bombardier

Despins, Ch 11 Trustee/Luc A.

A105 450.00 1.20 540.00 Communicate (in firm) schedule workflow Despins, Ch 11 Trustee/Luc A.

A108 450.00 0.40 180.00 Communicate (other external) with United Lex regarding user permissions in Relativity. Despins, Ch 11 Trustee/Luc A.

A103 450.00 3.40 1,530.00 Draft/revise Objection to Motion to Withdraw Date: 02/16/2024 Detail Fee Task Code Billing Report Page: 21 Case 22-50073 Doc 2936 Filed 02/19/24 Entered 02/19/24 23:45:45 Page 53 of

Phase ID B120 Asset Analysis and Recovery

A111 500.00 0.80 400.00 Reference Mei Guo Adv Proc. Despins, Ch 11 Trustee/Luc A.

Review and revise draft rule 2004 application and draft memorandum to attorney Mitchell with

A105 450.00 0.40 180.00 Despins, Ch 11 Trustee/Luc A.

Communicate (in firm) regarding Bank document

Despins, Ch 11 Trustee/Luc A.

A104 325.00 0.20 65.00 Ho Wan Kwok, Debtor

upcoming project concerning bank production Despins, Ch 11 Trustee/Luc A.

A104 450.00 2.40 1,080.00 Ho Wan Kwok, Debtor

production in response to 2004 subpoena for compliance-related documents. Despins, Ch 11 Trustee/Luc A.

A111 500.00 0.80 400.00 Ho Wan Kwok, Debtor Attend court hearing on HCHK discovery dispute

Despins, Ch 11 Trustee/Luc A.

A105 325.00 0.50 162.50 Ho Wan Kwok, Debtor Communicate (in firm) with D. Carnelli, N. Kinsella, K. Mitchell regarding bank discovery review (.4); follow-up with S. Smeriglio regarding

Despins, Ch 11 Trustee/Luc A.

A104 450.00 0.70 315.00 Ho Wan Kwok, Debtor Review/analyze draft 2004 motion (8th omnibus)

Despins, Ch 11 Trustee/Luc A.

A105 450.00 2.10 945.00 Ho Wan Kwok, Debtor Communicate (in firm) with Attorneys Mitchell, Attorney Kinsella, Attorney Astone, and United Lex regarding new project for banks-related discovery. Despins, Ch 11 Trustee/Luc A.

A108 325.00 0.30 97.50 Ho Wan Kwok, Debtor

regarding review of bank production for internal

Despins, Ch 11 Trustee/Luc A.

A104 325.00 2.40 780.00 Ho Wan Kwok, Debtor Review Capital One document production in

Despins, Ch 11 Trustee/Luc A.

A105 450.00 1.80 810.00 Ho Wan Kwok, Debtor Communicate (in firm) with Attorney Mitchell,

Attorney Kinsella on numerous issues regarding project review and analysis of compliance-related

subpoenas. Despins, Ch 11 Trustee/Luc A.

A104 325.00 0.80 260.00 Review the First Bank of Greenwich document production in response to 2004 subpoena for

Despins, Ch 11 Trustee/Luc A.

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Phase ID B120 Asset Analysis and Recovery

B120 A103 450.00 2.40 1,080.00 Draft/revise Notice of related proceedings (.6); telephone conferences with K. Mitchell regarding related matters (.2); research related matters (.5); review and revise Objection (.4); review and

Despins, Ch 11 Trustee/Luc A.

B120 A102 450.00 0.30 135.00 Ho Wan Kwok, Debtor

Despins, Ch 11 Trustee/Luc A.

B120 A103 450.00 0.90 405.00 Ho Wan Kwok, Debtor Draft/revise Notice of Related Proceedings Despins, Ch 11 Trustee/Luc A.

B120 A104 325.00 3.30 1,072.50 Ho Wan Kwok, Debtor

production in response to 2004 subpoena for

Despins, Ch 11 Trustee/Luc A.

B120 A101 175.00 0.70 122.50 Ho Wan Kwok, Debtor Assist Terry Dembowski-Jones in serving and filing Fee Application and Certificate of Service Despins, Ch 11 Trustee/Luc A.

B120 A108 325.00 0.50 162.50 Ho Wan Kwok, Debtor

correspondence with D. Carnelli, K. Mitchell, A. Holland regarding review of bank production for

Despins, Ch 11 Trustee/Luc A.

B120 A105 325.00 0.30 97.50 Ho Wan Kwok, Debtor Communicate (in firm) e-mail correspondence with D. Carnelli, K. Mitchell regarding review of bank production for internal compliance-related

Despins, Ch 11 Trustee/Luc A.

B120 A111 500.00 0.40 200.00 Ho Wan Kwok, Debtor

review of bank discovery regarding compliance matters and next steps in process (.3); telephone attorney Carnelli regarding 10/24 document

Despins, Ch 11 Trustee/Luc A.

B120 A111 500.00 0.80 400.00 Ho Wan Kwok, Debtor

regarding rule 2004 application process(.2); review and revise draft rule 2004 application and draft memorandum to attorney Mitchell with

Despins, Ch 11 Trustee/Luc A.

B120 A104 325.00 2.30 747.50 Ho Wan Kwok, Debtor

production in response to 2004 subpoena for

Despins, Ch 11 Trustee/Luc A.

B120 A104 325.00 1.50 487.50 Ho Wan Kwok, Debtor

production in response to 2004 subpoena for

Despins, Ch 11 Trustee/Luc A.

B120 A104 325.00 0.70 227.50 Review Seacoast National Bank document production in response to 2004 subpoena for

Despins, Ch 11 Trustee/Luc A.

B120 A102 400.00 0.60 240.00 Research ability to subpoena carriers, confer with Date: 02/16/2024 Detail Fee Task Code Billing Report Page: 23 Case 22-50073 Doc 2936 Filed 02/19/24 Entered 02/19/24 23:45:45 Page 55 of

Phase ID B120 Asset Analysis and Recovery

A104 325.00 1.90 617.50 D. Carnelli re same Despins, Ch 11 Trustee/Luc A.

Despins, Ch 11 Trustee/Luc A.

A102 400.00 0.50 200.00 Ho Wan Kwok, Debtor Con't research on ability to subpoena phone

Despins, Ch 11 Trustee/Luc A.

A104 325.00 0.60 195.00 Ho Wan Kwok, Debtor

Despins, Ch 11 Trustee/Luc A.

A108 450.00 0.20 90.00 Ho Wan Kwok, Debtor Communicate (other external) with Attorney Yanulis from Morgan Stanley regarding 2004 subpoena. Despins, Ch 11 Trustee/Luc A.

A104 400.00 0.50 200.00 Ho Wan Kwok, Debtor con't review HSBC document production from

A104 450.00 1.40 630.00 Despins, Ch 11 Trustee/Luc A.

documents (.5); review Rule 2004 Subpoena (.2);

A104 325.00 0.90 292.50 Despins, Ch 11 Trustee/Luc A.

Review the First Bank of Puerto Rico document production in response to 2004 subpoena for

Despins, Ch 11 Trustee/Luc A.

A104 325.00 1.00 325.00 Ho Wan Kwok, Debtor Review the Bank of Princeton documents in

Despins, Ch 11 Trustee/Luc A.

A105 325.00 0.20 65.00 Ho Wan Kwok, Debtor Communicate (in firm) with S. Smeriglio, K. Mitchell regarding bank production review for

Despins, Ch 11 Trustee/Luc A.

A104 325.00 0.30 97.50 Ho Wan Kwok, Debtor Review/analyze M&T Bank document production in response to 2004 subpoena for internal

Despins, Ch 11 Trustee/Luc A.

A104 325.00 2.30 747.50 Ho Wan Kwok, Debtor

production in response to 2004 subpoena for

Despins, Ch 11 Trustee/Luc A.

A104 325.00 0.60 195.00 Review/analyze First Republic Bank document production in response to 2004 subpoena for

Despins, Ch 11 Trustee/Luc A.

A104 325.00 0.80 260.00 Review/analyze Citi Bank document production in response to 2004 subpoena for internal Date: 02/16/2024 Detail Fee Task Code Billing Report Page: 24 Case 22-50073 Doc 2936 Filed 02/19/24 Entered 02/19/24 23:45:45 Page 56 of

Phase ID B120 Asset Analysis and Recovery

Despins, Ch 11 Trustee/Luc A.

B120 A104 325.00 0.40 130.00 Review/analyze Santander Bank document production in response to 2004 subpoena for

Despins, Ch 11 Trustee/Luc A.

B120 A104 325.00 0.50 162.50 Review/analyze Silvergate document production in response to 2004 subpoena for internal

Despins, Ch 11 Trustee/Luc A.

B120 A105 325.00 0.40 130.00 Communicate (in firm) e-mail correspondence with D. Carnelli, D. Skalka, K. Mitchell, S. Smeriglio regarding Wings Insurance Agency, Inc.'s response to subpoena, Jetlaw's proposed

Despins, Ch 11 Trustee/Luc A.

B120 A104 450.00 3.20 1,440.00 Review/analyze records produced by IDB and Santander for compliance-related documentation in Relativity. Despins, Ch 11 Trustee/Luc A.

B120 A105 450.00 0.30 135.00 Ho Wan Kwok, Debtor Communicate (in firm) with Attorney Mitchell regarding Verizon records. Despins, Ch 11 Trustee/Luc A.

B120 A104 325.00 2.00 650.00 Review UBS documents in response to 2004 subpoena for compliance related documents Despins, Ch 11 Trustee/Luc A.

B120 A104 325.00 3.60 1,170.00 Review/analyze Mercantile document production in response to 2004 subpoena for internal

Despins, Ch 11 Trustee/Luc A.

B120 A108 325.00 0.40 130.00 Communicate (other external) e-mail correspondence with D. Carnelli, S. Phan, A. Holland regarding review of bank production for

Despins, Ch 11 Trustee/Luc A.

B120 A104 450.00 3.40 1,530.00 Review/analyze document production (3.2); telephone conference with P. Linsey regarding

Despins, Ch 11 Trustee/Luc A.

B120 A104 325.00 2.00 650.00 Review production from Mercantile for internal

Despins, Ch 11 Trustee/Luc A.

B120 A103 400.00 0.10 40.00 Further revisions to 8th supp motion for 2004

Despins, Ch 11 Trustee/Luc A.

B120 A103 400.00 0.60 240.00 Revise 8th supplemental motion and subpoenas Despins, Ch 11 Trustee/Luc A.

B120 A104 325.00 1.40 455.00 Ho Wan Kwok, Debtor Review First Bank of Puerto Rico documents related to bank compliance related documents Despins, Ch 11 Trustee/Luc A.

B120 A104 325.00 3.10 1,007.50 Review UBS Bank documents related to bank Date: 02/16/2024 Detail Fee Task Code Billing Report Page: 25 Case 22-50073 Doc 2936 Filed 02/19/24 Entered 02/19/24 23:45:45 Page 57 of

Phase ID B120 Asset Analysis and Recovery

Despins, Ch 11 Trustee/Luc A.

B120 A105 400.00 0.10 40.00 call with P. Linsey re new 2004 motions, chart of

Despins, Ch 11 Trustee/Luc A.

B120 A104 400.00 1.00 400.00 Con't Review of UBS production for compliance

Despins, Ch 11 Trustee/Luc A.

B120 A105 400.00 0.30 120.00 Call w P linsey regarding 2004 productions from

Despins, Ch 11 Trustee/Luc A.

B120 A106 400.00 0.20 80.00 E-mails w PH regarding capital one production,

Despins, Ch 11 Trustee/Luc A.

B120 A111 500.00 0.60 300.00 Telephone attorney Linsey regarding eighth Rule 2004 motion; draft memo to attorney Linsey and Mitchell with revised 2004 motion and subpoena

Despins, Ch 11 Trustee/Luc A.

B120 A104 325.00 1.50 487.50 Review/analyze Mercantile document production in response to 2004 subpoena for internal

Despins, Ch 11 Trustee/Luc A.

B120 A104 450.00 1.30 585.00 Ho Wan Kwok, Debtor Review and analyze Wings Insurance documents (0.7), correspond with D. Barron and P. Parizek

further analysis (0.3), correspond with K. Mitchell regarding 8th Rule 2004 motion and targets (0.3) Despins, Ch 11 Trustee/Luc A.

B120 A106 450.00 2.30 1,035.00 Correspond with trustee, N. Bassett, and A. Luft regarding NPM litigation projects (0.2), prepare for standing NPM litigation projects update call with trustee (0.6), confer with trustee, N. Bassett, A. Luft and D. Carnelli regarding NPM litigation

Despins, Ch 11 Trustee/Luc A.

B120 A104 400.00 0.20 80.00 Review UBS production documents for

Despins, Ch 11 Trustee/Luc A.

B120 A105 325.00 0.50 162.50 Confer with K. Mitchell regarding guo 2004

Despins, Ch 11 Trustee/Luc A.

B120 A104 325.00 0.60 195.00 Review Mercantile Bank documents in response

Despins, Ch 11 Trustee/Luc A.

B120 A105 325.00 0.20 65.00 Confer with N. Kinsella regarding guo 2004

Despins, Ch 11 Trustee/Luc A.

B120 A103 400.00 0.20 80.00 revise discovery address and subpoena for First

Despins, Ch 11 Trustee/Luc A. Date: 02/16/2024 Detail Fee Task Code Billing Report Page: 26 Case 22-50073 Doc 2936 Filed 02/19/24 Entered 02/19/24 23:45:45 Page 58 of

Phase ID B120 Asset Analysis and Recovery

B120 A108 325.00 0.10 32.50 Ho Wan Kwok, Debtor Confer with S. Phan on issues with batching

Despins, Ch 11 Trustee/Luc A.

B120 A105 325.00 0.30 97.50 Ho Wan Kwok, Debtor

Despins, Ch 11 Trustee/Luc A.

B120 A105 325.00 0.30 97.50 Ho Wan Kwok, Debtor Communicate (in firm) e-mails to/from D. Carnelli regarding status of Mercantile document

Despins, Ch 11 Trustee/Luc A.

B120 A103 450.00 3.10 1,395.00 Confer with E. Sutton regarding 8th and 9th Rule 2004 examinations (0.4), confer with K. Ahumada and attention to final subpoenas for service under 7th Rule 2004 exam (0.3), review 8th Rule 2004 motion and subpoenas and attention to required revisions (0.3), correspond and confer with K. Mitchell regarding revisions to 8th Rule 2004 motion and subpoenas (0.4), review and analyze supplemental list of Rule 2004 discovery targets from E. Sutton and correspond with K. Mitchell regarding same (0.2), confer with E. Sutton regarding amended subpoena to TD Bank (0.1), draft amended TD Bank subpoena/RFP (0.4), correspond with P. Parizek and A. Lomas (Kroll) regarding same (0.2), memorandum to E. Cohan regarding service of amended TD Bank subpoena (0.2), correspond with E. Lacombe (TD

compliance with same (0.3), correspond with P. Parizek regarding issuance of subpoena (0.1), correspond with E. Lacombe in response to TD

Despins, Ch 11 Trustee/Luc A.

B120 A111 500.00 0.40 200.00 Draft memorandum to attorney Kinsella regarding personal property issues (.2); review

B120 A103 400.00 0.80 320.00 Revise RFPs for 8th supp motion for 2004 exams Despins, Ch 11 Trustee/Luc A.

B120 A108 400.00 0.10 40.00 Communicate (other external) E-mail follow up to Capital One on Rule 2004 Production. Despins, Ch 11 Trustee/Luc A.

B120 A101 175.00 0.90 157.50 Prepare 7 subpoenas for 7th Rule 2004 exam;

Despins, Ch 11 Trustee/Luc A.

B120 A104 400.00 1.20 480.00 Review alter ego memorandum, research additional support for ttee avoidance capabilities

Despins, Ch 11 Trustee/Luc A.

B120 A104 400.00 0.40 160.00 Con't review of case law regarding avoidance of

Despins, Ch 11 Trustee/Luc A.

B120 A108 325.00 0.20 65.00 Attend video conference with A. Singh from Date: 02/16/2024 Detail Fee Task Code Billing Report Page: 27 Case 22-50073 Doc 2936 Filed 02/19/24 Entered 02/19/24 23:45:45 Page 59 of

Phase ID B120 Asset Analysis and Recovery UnitedLex regarding document production on

Despins, Ch 11 Trustee/Luc A.

B120 A104 325.00 1.10 357.50 Review and mark UBS Rule 2004 production documents for compliance related information Despins, Ch 11 Trustee/Luc A.

B120 A104 325.00 2.00 650.00 Review and analyze and mark large Mercantile Bank document production in response to 2004

Despins, Ch 11 Trustee/Luc A.

B120 A103 450.00 1.10 495.00 Review and finalize subpoenas from 7th Rule 2004 exam and attention to service (0.4), correspond with K. Ahumada regarding same (0.1), review supplemental correspondence from Seacoast Bank and correspond with A. Lomas (Kroll) and ULX regarding same (0.4), correspond with E. Cohan regarding TD Bank subpoena (0.1), confer with S. Smeriglio regarding bank docs

Despins, Ch 11 Trustee/Luc A.

B120 A104 325.00 1.80 585.00 Continue to review and analyze and mark large

Despins, Ch 11 Trustee/Luc A.

B120 A101 175.00 3.80 665.00 Prepare subpoenas for 8th Supplemental 2004 Exam; service subpoenas to targets and manual

Despins, Ch 11 Trustee/Luc A.

B120 A104 325.00 4.20 1,365.00 Continue review and marking of UBS Rule 2004 production documents for compliance related

Despins, Ch 11 Trustee/Luc A.

B120 A104 325.00 2.00 650.00 Ongoing review and marking of UBS Bank documents related to bank produced from 2004 subpoena for compliance related documents Despins, Ch 11 Trustee/Luc A.

B120 A103 450.00 2.10 945.00 Correspond with trustee and M. Prout regarding East West Bank discovery (0.2), correspond and confer with E. Sutton regarding Rule 2004 motions (0.2), correspond and confer with K. Ahumada regarding Rule 2004 motions (0.2), review and revise 8th Rule 2004 motion and exhibits (0.8), finalize and attention to filing 8th Rule 2004 motion (0.3), correspond and confer with K. Ahumada regarding service of 8th Rule 2004 motion (0.2), correspond with K. Mitchell and S. Smeriglio regarding banks review project

Despins, Ch 11 Trustee/Luc A.

B120 A103 450.00 1.70 765.00 Correspond and confer with E. Lacombe (TD

compliance (0.5), work on 9th Rule 2004 motion (0.4), correspond with D. Barron and M. Prout

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Phase ID B120 Asset Analysis and Recovery memorandum to A. Luft and N. Bassett regarding Y. Zhang subpoena compliance and next steps

B120 A104 325.00 3.60 1,170.00 Despins, Ch 11 Trustee/Luc A.

Continue to review and analyze and mark large

Despins, Ch 11 Trustee/Luc A.

B120 A108 325.00 0.50 162.50 Ho Wan Kwok, Debtor Draft and review e-mails to/from S. Phan, W. Clark, A. Singh regarding Relativity document

Despins, Ch 11 Trustee/Luc A.

B120 A104 325.00 0.60 195.00 Ho Wan Kwok, Debtor

documents for compliance related caselaw on Despins, Ch 11 Trustee/Luc A.

B120 A104 400.00 0.20 80.00 Ho Wan Kwok, Debtor rec'v e-mail from cap one with 2004 subpoena

Despins, Ch 11 Trustee/Luc A.

B120 A103 325.00 0.70 227.50 Ho Wan Kwok, Debtor Draft motion of extension of time to file

Despins, Ch 11 Trustee/Luc A.

B120 A103 325.00 0.50 162.50 Ho Wan Kwok, Debtor

Despins, Ch 11 Trustee/Luc A.

B120 A107 450.00 1.30 585.00 Ho Wan Kwok, Debtor

regarding service of First County Bank subpoena (0.2), correspond with E. Lacombe (TD Bank) regarding emails from bank employee regarding subpoena (0.2), confer with A. Luft and E. Sutton

discovery matters (0.7), correspond with E. Sutton about Y. Zhang correspondence and Rule 2004

Despins, Ch 11 Trustee/Luc A.

B120 A104 325.00 1.00 325.00 Ho Wan Kwok, Debtor Continue review and analysis and marking of Mercantile Bank 2004 production documents for

Despins, Ch 11 Trustee/Luc A.

B120 A102 400.00 0.30 120.00 Ho Wan Kwok, Debtor

Despins, Ch 11 Trustee/Luc A.

B120 A104 325.00 1.90 617.50 Continue review and analysis and marking of

Despins, Ch 11 Trustee/Luc A.

B120 A103 325.00 0.30 97.50 Review and revise motion to comply with

Despins, Ch 11 Trustee/Luc A.

B120 A101 175.00 0.80 140.00 Serve 9th supplemental motion to 3 targets Despins, Ch 11 Trustee/Luc A.

B120 A104 400.00 0.80 320.00 Review Seacoast 2004 exam subpoena Date: 02/16/2024 Detail Fee Task Code Billing Report Page: 29 Case 22-50073 Doc 2936 Filed 02/19/24 Entered 02/19/24 23:45:45 Page 61 of

Phase ID B120 Asset Analysis and Recovery

Despins, Ch 11 Trustee/Luc A.

A105 400.00 0.10 40.00 Call w P. Linsey re follow up with entities that have not yet produced documents pursuant to the 2004 exam subpoenas. Despins, Ch 11 Trustee/Luc A.

A104 450.00 2.60 1,170.00 Review of Relativity file for state of compliance

subpoenas. Despins, Ch 11 Trustee/Luc A.

A102 450.00 1.90 855.00 Ho Wan Kwok, Debtor Research and review receivership law of Nevada

pre-receivership service on entity now in

Despins, Ch 11 Trustee/Luc A.

A103 450.00 3.10 1,395.00 Correspond and confer with E. Sutton regarding 9th 2004 exam motion (0.2), review and revise subpoenas for 9th 2004 exam motion (0.3),

regarding exhibits to 9th 2004 exam motion (0.2), revise and draft order for 9th 2004 exam motion

attention to filing same (0.3), correspond with K. Ahumada and E. Sutton regarding service of 9th 2004 exam (0.2), correspond with D. Skalka and D. Carnelli regarding Prime Trust (0.2), attention to correspondence from E. Sutton and D. Barron and correspond with D. Barron regarding Prime Trust (0.2), prepare for standing NPM projects meeting with trustee (0.4), attend standing NPM projects meeting with trustee and A. Luft (0.4), correspond with D. Skalka regarding standing meeting (0.1), confer with K. Mitchell about pursuing discovery on 6th 2004 exam motion

Despins, Ch 11 Trustee/Luc A.

A103 450.00 5.20 2,340.00 Research regarding substantive consolidation

avoidance claims in alter ego context (2.4), proof and revise memorandum (0.9), confer with D. Barron regarding memorandum and avoidance claim pleading issues (0.3), correspond and confer with trustee regarding memorandum (0.2) Despins, Ch 11 Trustee/Luc A.

A102 400.00 0.10 40.00 further attention for registered agent of first

Despins, Ch 11 Trustee/Luc A.

A104 325.00 4.50 1,462.50 Continue to review and analyze and mark large

Despins, Ch 11 Trustee/Luc A.

A106 400.00 0.10 40.00 Communicate (with client) e-mail to PH w

Despins, Ch 11 Trustee/Luc A.

A105 400.00 0.30 120.00 call w P. Linsey regarding e-mail from Kroll and

Phase ID B120 Asset Analysis and Recovery

Despins, Ch 11 Trustee/Luc A.

A B120 A104 400.00 2.10 840.00 Commence review/analyze prior 2004 exam subpoenas for full range of holders of accounts as updated by Kroll (.9); added new banks to tracker (.8), drafted amended subpoenas and

Despins, Ch 11 Trustee/Luc A.

A B120 A108 400.00 0.20 80.00 Communicate (other external) e-mail to Kroll for clarification on missing account holders for

Despins, Ch 11 Trustee/Luc A.

A B120 A108 400.00 0.10 40.00 Communicate (other external) rec'v e-mail from Kroll re clarification of entity names, reviewed

Despins, Ch 11 Trustee/Luc A.

A B120 A104 400.00 0.40 160.00 Review tracker of subpoena responses and

complied. Despins, Ch 11 Trustee/Luc A.

A B120 A105 400.00 0.20 80.00 Communicate (in firm) w P Linsey regarding amended subpoenas and preparation for service

Despins, Ch 11 Trustee/Luc A.

A B120 A101 175.00 0.50 87.50 Call with Attorney Linsey regarding Certificate of

Despins, Ch 11 Trustee/Luc A.

A B120 A104 325.00 5.50 1,787.50 Continue review and analysis and marking of large Mercantile Bank document production in

Despins, Ch 11 Trustee/Luc A.

A B120 A107 325.00 0.30 97.50 Draft and review e-mails to/from Attorneys D. Carnelli and E. Sutton regarding Prime Trust 2004

Despins, Ch 11 Trustee/Luc A.

A B120 A106 450.00 0.80 360.00 Draft memos to client regarding Prime Trust subpoena status. Despins, Ch 11 Trustee/Luc A.

A B120 A104 450.00 1.40 630.00 Review/analyze file to ascertain status of Prime Trust subpoena, Prime Trust's status as a going concern (1.0); including several follow-up e-mail communications with Attorney Diane Suchter (.4) Despins, Ch 11 Trustee/Luc A.

A B120 A103 450.00 0.80 360.00 Draft and revise analysis on state of subpoena to

Despins, Ch 11 Trustee/Luc A.

A B120 A104 450.00 0.70 315.00 Review and analyze D.Del bankruptcy filings for

Despins, Ch 11 Trustee/Luc A.

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5248.001 11/07/2023 Phase ID B120 Asset Analysis and Recovery

B120 A103 450.00 1.20 540.00 Draft and revise responsive analysis to Attorney

regarding subpoena to Royal Business Bank and

withheld. Despins, Ch 11 Trustee/Luc A.

B120 A104 450.00 0.80 360.00 Ho Wan Kwok, Debtor

determine extent of Royal Bank compliance with 2004 subpoena. Despins, Ch 11 Trustee/Luc A.

B120 A107 450.00 1.40 630.00 Correspond with N. Bassett and A. Luft regarding Capital One subpoena (0.2), correspond with K. Mitchell regarding First County Bank subpoena and attention to FDIC records (0.3), correspond with E. Cohan regarding First County Bank and

Stanley subpoena and matters raised by MS counsel (0.2), confer with K. Mitchell regarding open discovery items raised by Kroll (0.2), correspond with K. Mitchell regarding call with A. Lomas (Kroll) (0.1), correspond with A. Lomas and K. Mitchell regarding open banks discovery items

Despins, Ch 11 Trustee/Luc A.

B120 A107 450.00 3.80 1,710.00 Ho Wan Kwok, Debtor Correspond with trustee regarding hearing on Casper 9019 motion (0.1), prepare for hearing on Casper 9019 motion (1.3), attend hearing on Casper 9019 motion (0.7), correspond with A. Luft and E. Sutton regarding inquiries from M. Bachner regarding subpoena to Yingyang Wang (0.2), correspond with D. Barron and A. Smith regarding hearing transcript (0.1), correspond

Yingyang Wang subpoena (0.3), confer with D. Carnelli regarding Prime Trust subpoena and Royal Bank discovery dispute and next steps (0.4), review correspondence with Royal Bank and analyze discovery dispute (0.2), confer with E. Sutton and D. Carnelli regarding Prime Trust and Royal Bank discovery dispute (0.2), confer with D. Carnelli regarding outstanding banks documents

Despins, Ch 11 Trustee/Luc A.

B120 A105 450.00 0.70 315.00 Ho Wan Kwok, Debtor Correspond with A. Bongartz and confer with K. Mitchell regarding motion for extension of time to remove civil actions (0.3), correspond with S. Smeriglio and L. Astone regarding review process for banks discovery and compliance docs (0.2), confer with K. Ahumada regarding service of

Despins, Ch 11 Trustee/Luc A.

B120 A111 500.00 0.30 150.00 Draft memorandum to attorney Carnelli with correspondence from attorney Suchter regarding

Despins, Ch 11 Trustee/Luc A.

B120 A104 325.00 3.20 1,040.00 Review/analyze Mercantile document production in response to 2004 subpoena for internal

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Phase ID B120 Asset Analysis and Recovery

400.00 1.10 440.00 Despins, Ch 11 Trustee/Luc A.

Con't review of Mercantile production of 2004 subpoena for compliance documents. Despins, Ch 11 Trustee/Luc A.

400.00 0.40 160.00 Ho Wan Kwok, Debtor Review of mercantile production for compliance

Despins, Ch 11 Trustee/Luc A.

400.00 0.60 240.00 Ho Wan Kwok, Debtor Call with rep from Morgan Stanley and P. Linsey

Despins, Ch 11 Trustee/Luc A.

325.00 1.80 585.00 Attend meeting with NPM co-counsel regarding litigation, status, discovery status and avoidance

Despins, Ch 11 Trustee/Luc A.

400.00 0.60 240.00 Ho Wan Kwok, Debtor Communicate (other external) regarding missing production from 2004 exam banks with Kroll and

Despins, Ch 11 Trustee/Luc A.

325.00 0.50 162.50 Ho Wan Kwok, Debtor Draft e-mails to S. Phan of UnitedLex regarding status of bank compliance, 2 document review Despins, Ch 11 Trustee/Luc A.

325.00 1.80 585.00 Attend meeting with NPM co-counsel regarding

Despins, Ch 11 Trustee/Luc A.

400.00 0.20 80.00 Draft motion for extension of time of trustee's

Despins, Ch 11 Trustee/Luc A.

400.00 1.80 720.00 Confer with NPM counsel regarding avoidance

Despins, Ch 11 Trustee/Luc A.

325.00 4.40 1,430.00 Review and analyze and mark Mercantile Bank production in response to 2004 subpoena for

Despins, Ch 11 Trustee/Luc A.

400.00 0.20 80.00 e-mails with P. Linsey regarding lack of

Despins, Ch 11 Trustee/Luc A.

400.00 1.30 520.00 Review Mercantile documents for compliance Despins, Ch 11 Trustee/Luc A.

325.00 0.80 260.00 Review and analyze and mark Axos Bank

Despins, Ch 11 Trustee/Luc A.

400.00 0.30 120.00 correspond with P. Linsey regarding call with A. Lomas (Kroll) (0.1), correspond with A. Lomas and P. Linsey regarding open banks discovery items

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Phase ID B120 Asset Analysis and Recovery

A B120 A108 400.00 0.10 40.00 Ho Wan Kwok, Debtor Correspond w C. Abreu (Prime Trust) and P.

Despins, Ch 11 Trustee/Luc A.

A B120 A108 400.00 0.10 40.00 Ho Wan Kwok, Debtor correspondence w A. Beardsley, P. Linsey, and D. Carnelli regarding production by Schwab, plan

Despins, Ch 11 Trustee/Luc A.

A B120 A108 400.00 0.10 40.00 Attention to e-mail w A. Lomas, D. Carnelli and P.

Despins, Ch 11 Trustee/Luc A.

B120 A105 450.00 2.20 990.00 Attend meeting with co-counsel regarding avoidance actions and other ongoing discovery

Despins, Ch 11 Trustee/Luc A.

B120 A104 450.00 3.00 1,350.00 Review and analyze discovery documents from

Despins, Ch 11 Trustee/Luc A.

A B120 A104 450.00 2.90 1,305.00 Ho Wan Kwok, Debtor Attention to and review of status of banks

foundation for avoidance actions; (1.7); meet regarding the same with Attorney Linsey and

A B120 A107 450.00 1.70 765.00 Despins, Ch 11 Trustee/Luc A.

regarding 2004 motions (0.2), confer with A. Luft regarding threatened objections to 2004 motions (0.3), correspond with D. Barron and E. Sutton regarding motion to extend removal deadline (0.1), correspond with K. Mitchell regarding findings from Mercantile Bank discovery (0.2), review and analyze Mercantile Bank discovery documents (0.2), correspond and confer with E. Sutton and K. Ahumada regarding 2004 motions

intervenors) regarding 2004 motions discovery

regarding Morgan Stanley discovery (0.2), finalize 8th Rule 2004 motion COS and attention to filing

Despins, Ch 11 Trustee/Luc A.

A B120 A104 450.00 6.00 2,700.00 Ho Wan Kwok, Debtor Prepare for Morgan Stanley meet and confer (0.3), meet-and-confer with M. Yanulis (Morgan Stanley) regarding Rule 2004 subpoena (0.5), confer with D. Skalka and D. Carnelli regarding Rule 2004 discovery and litigation strategy (1.2), confer with NPM counsel regarding litigation planning/strategy and avoidance actions (1.8), prepare for Kroll meeting regarding Rule 2004 discovery investigation (0.2), meet with A. Lomas (Kroll) and K. Mitchell regarding banks Rule 2004 discovery (0.4), meet and confer with J. Pastore (HCHK intervenors) regarding threatened Rule 2004 motions discovery dispute (0.5), review and analyze district court's decision disposing of

Date: 02/16/2024 Detail Fee Task Code Billing Report Page: 34 Case 22-50073 Doc 2936 Filed 02/19/24 Entered 02/19/24 23:45:45 Page 66 of

Phase ID B120 Asset Analysis and Recovery Kwok contempt appeal (0.5), correspond with N. Bassett regarding same (0.1), correspond with C. Abreu (Trustco) regarding Rule 2004 discovery and compliance (0.2), correspond with A. Beardsley (Schwab) regarding Schwab Rule 2004 subpoena (0.2), correspond with K. Mitchell regarding City National Bank inquiry regarding

Despins, Ch 11 Trustee/Luc A.

B120 A111 500.00 0.70 350.00 Meet with attorneys Carnelli and Linsey regarding status of bank discovery and next

Despins, Ch 11 Trustee/Luc A.

B120 A111 500.00 1.80 900.00 Attend meeting with Attorneys Carnelli, Linsey, Kinsella , Mitchell, Astone and Smeriglio regarding Rule 2004 discovery status , discovery document review and avoidance action status Despins, Ch 11 Trustee/Luc A.

B120 A111 500.00 0.30 150.00 Draft memorandum to attorney Kinsella

Despins, Ch 11 Trustee/Luc A.

B120 A105 325.00 0.60 195.00 E-mails to/from internal team regarding Relativity's response to bank review request Despins, Ch 11 Trustee/Luc A.

B120 A108 325.00 1.00 325.00 E-mails to/from Steven Phan regarding bank

Despins, Ch 11 Trustee/Luc A.

B120 A104 325.00 3.00 975.00 Complete review and analysis and marking of large Mercantile Bank document production in

Despins, Ch 11 Trustee/Luc A.

B120 A108 400.00 0.10 40.00 rec'v and review e-mail from C. Abreu regarding folder of production of documents pursuant to

Despins, Ch 11 Trustee/Luc A.

B120 A106 400.00 0.70 280.00 correspondence to client and P. Linsey regarding potential unknown targets uncovered during review of 2004 subpoena productions from other

Despins, Ch 11 Trustee/Luc A.

B120 A104 400.00 0.80 320.00 analyze and revise bank subpoenas to include new/missing information. Despins, Ch 11 Trustee/Luc A.

B120 A103 400.00 0.30 120.00 finished revisions to BoA and DBS subpoenas,

Despins, Ch 11 Trustee/Luc A.

B120 A108 400.00 0.30 120.00 F/U e-mail to contact at IDBNY detailing

subpoena production. Despins, Ch 11 Trustee/Luc A.

B120 A108 400.00 0.20 80.00 F/U e-mail to contact at M&T detailing accounts Date: 02/16/2024 Detail Fee Task Code Billing Report Page: 35 Case 22-50073 Doc 2936 Filed 02/19/24 Entered 02/19/24 23:45:45 Page 67 of

Phase ID B120 Asset Analysis and Recovery

production. Despins, Ch 11 Trustee/Luc A.

400.00 1.40 560.00 Analyze bank productions and update tracker with pert information for first supplemental

Despins, Ch 11 Trustee/Luc A.

regarding Open Bank contact to K. Mitchell for

Despins, Ch 11 Trustee/Luc A.

400.00 0.10 40.00 Rec'v response from M&T Bank with reference to production, review and communicate to Kroll

Despins, Ch 11 Trustee/Luc A.

400.00 0.50 200.00 Ho Wan Kwok, Debtor Continue analysis of bank productions for completion and update tracker for first supp

Despins, Ch 11 Trustee/Luc A.

450.00 2.20 990.00 Review and analyze Mercantile Bank produced

Despins, Ch 11 Trustee/Luc A.

450.00 5.00 2,250.00 Research and review caselaw on the applicability of Ponzi scheme and Ponzi scheme presumption

Despins, Ch 11 Trustee/Luc A.

400.00 0.30 120.00 Commence analysis of bank productions for completion and update of tracker for second

Despins, Ch 11 Trustee/Luc A.

175.00 1.20 210.00 Send M&T supplemental production to ULX via

Despins, Ch 11 Trustee/Luc A.

175.00 0.30 52.50 Make online payment for Metro Attorney

Despins, Ch 11 Trustee/Luc A.

400.00 0.20 80.00 Finalized amended subpoenas to DBS and BoA

Despins, Ch 11 Trustee/Luc A.

400.00 0.10 40.00 Rec'v and respond to correspondence with P.

Despins, Ch 11 Trustee/Luc A.

400.00 0.30 120.00 Review several e-mails from Seacoast counsel's regarding subpoena and suggestion for meet and confer (.2), attention to response from J.

Despins, Ch 11 Trustee/Luc A.

400.00 0.10 40.00 Correspond with P. Linsey about possible motion

Despins, Ch 11 Trustee/Luc A.

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Phase ID B120 Asset Analysis and Recovery

B120 A104 450.00 3.50 1,575.00 Ho Wan Kwok, Debtor Correspond with D. Barron regarding Kroll investigation update (0.1), review and analyze findings from Mercantile Bank discovery and correspond with K. Mitchell and D. Barron

subpoenas where further investigation required (0.8), confer with E. Lacombe (TD Bank) regarding amended subpoena (0.1), correspond with K. Mitchell and D. Reyes regarding further M&T Bank production (0.3), review and analyze

lengthy correspond with J. Anthony (Seacoast) regarding missing items in Seacoast production and missing statements (0.3), series of emails with J. Anthony regarding Seacoast counsel's demand for fees for compliance with subpoenas and efforts to resolve discovery dispute (0.3), memorandum to R. Flynn regarding Seacoast

Despins, Ch 11 Trustee/Luc A.

B120 A103 450.00 1.60 720.00 Correspond with K. Mitchell regarding M&T Bank subpoena and update (0.2), prepare motion for chapter 11 trustee to appear remotely at Nov. 14 hearings and correspond with trustee regarding same (0.5), finalize motion to appear remotely and file in several adversary proceedings (0.3),

regarding Seacoast meet and confer (0.2), correspond with K. Mitchell regarding amended subpoenas and service of same (0.2), revise draft correspondence to Israel Discount Bank and correspond with K. Mitchell regarding same (0.2) Despins, Ch 11 Trustee/Luc A.

B120 A104 400.00 0.40 160.00 Finish Mercantile review for internal compliance Despins, Ch 11 Trustee/Luc A.

B120 A108 400.00 0.20 80.00 Correspond with Open Bank for additional

Despins, Ch 11 Trustee/Luc A.

B120 A105 325.00 0.20 65.00 Draft memorandum to Attorney D. Carnelli regarding status of Israel Discount Bank review for internal compliance-related documents Despins, Ch 11 Trustee/Luc A.

B120 A105 400.00 0.50 200.00 Correspond w P. Linsey regarding Seacoast Bank,

Despins, Ch 11 Trustee/Luc A.

B120 A103 325.00 0.30 97.50 Draft updates to internal records regarding status of bank document review for internal

Despins, Ch 11 Trustee/Luc A.

B120 A104 400.00 0.10 40.00 Review e-mail and voicemail from open bank regarding request for native documents, tickled

Despins, Ch 11 Trustee/Luc A.

B120 A102 450.00 4.90 2,205.00 Continue research of Ponzi Scheme caselaw and Ponzi presumption (2.4) review and revise Date: 02/16/2024 Detail Fee Task Code Billing Report Page: 37 Case 22-50073 Doc 2936 Filed 02/19/24 Entered 02/19/24 23:45:45 Page 69 of

Phase ID B120 Asset Analysis and Recovery

Despins, Ch 11 Trustee/Luc A.

B120 A104 400.00 0.60 240.00 Review M&T Production for documents Kroll marked as missing from original production. Despins, Ch 11 Trustee/Luc A.

B120 A104 400.00 0.90 360.00 Continue analysis of second supplemental 2004 motions for subpoena compliance and update

Despins, Ch 11 Trustee/Luc A.

B120 A105 400.00 0.20 80.00 compose correspondence to team regarding missing information needed to update tracker on

Despins, Ch 11 Trustee/Luc A.

B120 A104 325.00 7.00 2,275.00 Complete review and analysis and marking of Mercantile Bank production in response to 2004 subpoena for compliance related documents Despins, Ch 11 Trustee/Luc A.

B120 A104 400.00 2.90 1,160.00 Con't review of Mercantile documents for

Despins, Ch 11 Trustee/Luc A.

B120 A104 400.00 0.70 280.00 Complete review of Mercantile subpoena documents for internal compliance documents Despins, Ch 11 Trustee/Luc A.

B120 A104 450.00 0.90 405.00 Review and analyze Israel Discount Bank production to confirm portions/page numbers that are compliance related. Despins, Ch 11 Trustee/Luc A.

B120 A105 450.00 1.00 450.00 Correspond and confer with R. Flynn regarding Seacoast meet-and-confer and likely motion to compel (0.3), confer with K. Mitchell regarding

jurisdictional issues regarding discovery (0.5), correspond with E. Lacombe regarding TD Bank's production responsive to amended subpoena

Despins, Ch 11 Trustee/Luc A.

B120 A104 400.00 0.40 160.00 Review new upload of M&T Bank production

Despins, Ch 11 Trustee/Luc A.

B120 A107 450.00 0.50 225.00 Correspond with Trustee and W. Farmer regarding Cheng v. Guo status report (0.1), review docket in Cheng v. Guo regarding status report (0.2), correspond with D. Skalka and E. Sutton regarding correspondence from counsel

Despins, Ch 11 Trustee/Luc A.

B120 A108 450.00 0.20 90.00 Correspond with R. McKirgan (5780 Saguaro LLC)

Despins, Ch 11 Trustee/Luc A.

B120 A108 400.00 2.20 880.00 Review correspondence and declaration production in response to 2004 exam subpoenas and circulate to team/respond/follow up, First

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Phase ID B120 Asset Analysis and Recovery Bank of Greenwich (.1), JetLaw & Wings (.3), Bento (.1), Axos (.1), TD Bank (.2), Flagstar (.1), First County (.1), Community Federal (.1), Cap One (.1), Royal Business Bank (.1), Prime Trust (.1), Silvergate (.1), TrustCo (.1), City National (.1), MorganStanley (.2), Seacoast (.1), Israel Discount

Despins, Ch 11 Trustee/Luc A.

A102 450.00 3.90 1,755.00 Research and review alter ego caselaw of varying

Despins, Ch 11 Trustee/Luc A.

A108 325.00 0.10 32.50 Draft memorandum to S. Phan from UnitedLex to

Despins, Ch 11 Trustee/Luc A.

A104 400.00 3.50 1,400.00 continued review of bank productions for follow up and update of tracker; BNY Mel (.1), Barclay (.1), Citibank (.1), JPMorgan (.2), Standard Chartered (.1), UBS (.1), BoA (.1), Cap One (.2), TD Bank (.1) Firstbank PR (.1), Seacoast (.2), IDB (.2), M&T (.2), Dime Community (.1), First Abu Dhabi (.1), Santander (.1), DBS (.1), First Bank Greenwich (.1), Bank of China (.1), US Bank (.1), Bank of Princeton (.2), Metro (.1), Open Bank (.1), First Republic (.1), HSBC (.2), East West (.1), Comerica (.1), Webster (.1). Despins, Ch 11 Trustee/Luc A.

A104 400.00 0.30 120.00 Research status of NPM motions to compel and update trackers; Despins, Ch 11 Trustee/Luc A.

A105 400.00 0.20 80.00 Ho Wan Kwok, Debtor

subpoena service and procedure going fwd. Despins, Ch 11 Trustee/Luc A.

A105 400.00 0.00 Communicate (in firm) Despins, Ch 11 Trustee/Luc A.

A104 325.00 0.30 97.50 Review bank discovery and select samples of compliance-related documents for client review Despins, Ch 11 Trustee/Luc A.

A105 450.00 0.30 135.00 Draft memorandum to Attorney Mitchell regarding service of Jetlaw and Wings Insurance

Despins, Ch 11 Trustee/Luc A.

A108 450.00 2.80 1,260.00 Confer with R. Flynn regarding motion to compel (0.1), correspond and confer with R. McKirgan regarding proposed Rule 2004 subpoena to 5780 Saguaro LLC (0.3), confer with N. Bassett and A. Luft regarding standing NPM litigation projects call and evidence for November 14 hearings (1.1), correspond with trustee regarding Nov. 14 hearings (0.2), correspond with clerk to request Zoom credentials (0.1), correspond with clerk regarding evidence for Nov. 14 hearing (0.2),

regarding 9th Rule 2004 Motion (0.2), proof and revise motion to extend removal deadline for civil actions (0.3), correspond with A. Bongartz

Phase ID B120 Asset Analysis and Recovery and K. Mitchell regarding same (0.2), attention to COS regarding 9th Rule 2004 motion (0.1) 2.8 Despins, Ch 11 Trustee/Luc A.

A B120 A109 450.00 4.50 2,025.00 Attend hearings on discovery disputes in Mei Guo/aircraft A.P. and regarding video tour of Taconic Road premises in Greenwich Land A.P. (4.2), correspond with R. Ward regarding DBS

correspond with K. Mitchell regarding Open Bank

Despins, Ch 11 Trustee/Luc A.

B120 A111 500.00 0.70 350.00 Telephone Attorney Linsey regarding 2004

regarding call with client Ponzi memorandum

Despins, Ch 11 Trustee/Luc A.

B120 A111 500.00 0.70 350.00 Attend conference call with attorneys Linsey, Luft and Bassett regarding discovery issues in Mei

applications (.2) and status of Kroll analysis of

Despins, Ch 11 Trustee/Luc A. 5248.001 B120 A104 325.00 0.50 162.50 Ho Wan Kwok, Debtor Continue review of bank discovery and select

A samples of internal compliance-related

Despins, Ch 11 Trustee/Luc A.

A B120 A101 175.00 1.90 332.50 Assemble hearing materials Despins, Ch 11 Trustee/Luc A.

A B120 A104 400.00 0.40 160.00 Complete review of HSBC documents for

Despins, Ch 11 Trustee/Luc A.

A B120 A104 400.00 3.80 1,520.00 Analyze subpoenas, proof of service, due dates

compliance, construct list of bank in which action may need to be taken, update trackers: BNY Melon (.1), Barclays (.1), Citibank (.1), JPMorgan (.2), Standard Chartered PLC (.1), UBS (.2), BoA (.1), Cap One (.1), TD Bank (.1), Firstbank PR (.1), Seacoast (.2), Israel Discount (.1), M&T (.2), Dime (.1), Starling (.1), First Abu Dhabi (.1), Santander (.1), Silvergate (.1), DBS (.2), First Bank of Greenwich (.1), Bank of China (.1), US Bank (.1), Bank of Princeton (.1), Metropolitan (.1), Medici (.1), Deltec (.2), Open bank (.1), First Republic (.1), HSBC (.1), Prime Trust (.2), Axos (.1). Despins, Ch 11 Trustee/Luc A.

A B120 A103 325.00 0.80 260.00 Draft and revise internal memorandum of the compliance related documents from TD Bank,

Despins, Ch 11 Trustee/Luc A.

B120 A102 450.00 1.70 765.00 Ho Wan Kwok, Debtor Continue research and review alter ego liability and reverse veil piercing case law (1.5); telephone conference with Attorney Skalka regarding

Despins, Ch 11 Trustee/Luc A. Date: 02/16/2024 Detail Fee Task Code Billing Report Page: 40 Case 22-50073 Doc 2936 Filed 02/19/24 Entered 02/19/24 23:45:45 Page 72 of

Phase ID B120 Asset Analysis and Recovery

B120 A111 500.00 1.00 500.00 Ho Wan Kwok, Debtor

reports (.7) ; draft memorandum to attorneys

Despins, Ch 11 Trustee/Luc A.

B120 A105 325.00 0.30 97.50 Ho Wan Kwok, Debtor Draft e-mails to/from Attorneys D. Skalka, K. Mitchell, S. Smeriglio regarding status of bank

Despins, Ch 11 Trustee/Luc A.

B120 A108 400.00 0.20 80.00 Ho Wan Kwok, Debtor Review e-mail from P. Linsey regarding Kroll file

contact at Open bank specifying what is still outstanding. Despins, Ch 11 Trustee/Luc A.

B120 A105 400.00 0.10 40.00 correspond with R. Flynn regarding conference

Despins, Ch 11 Trustee/Luc A.

B120 A101 400.00 0.40 160.00 Prepare for call with Kroll re avoidance actions

Despins, Ch 11 Trustee/Luc A.

B120 A108 400.00 0.70 280.00 Conference call with Kroll, client, and P. Linsey regarding outstanding bank production and avoidance analysis. Despins, Ch 11 Trustee/Luc A.

B120 A105 400.00 0.20 80.00 rec'v and reviewed response regarding Seacoast from R. Flynn, update tracker re same. Despins, Ch 11 Trustee/Luc A.

B120 A103 400.00 0.20 80.00 Draft outline of items that need attention pursuant Kroll, save to file, update tracker Despins, Ch 11 Trustee/Luc A.

B120 A105 400.00 0.40 160.00 Call w P. Linsey regarding strategy of banks non-compliance and follow up needed for Kroll Despins, Ch 11 Trustee/Luc A.

B120 A108 400.00 0.20 80.00 Ho Wan Kwok, Debtor

Despins, Ch 11 Trustee/Luc A.

B120 A105 400.00 0.10 40.00 Communication with L. Astone regarding Open

Despins, Ch 11 Trustee/Luc A.

B120 A108 400.00 0.20 80.00 rec'v and rev'd response from contact at IDB regarding further production, responded to same. Despins, Ch 11 Trustee/Luc A.

B120 A108 400.00 0.10 40.00 follow up correspondence w A. Lomas regarding open bank attachments needed to further clarify

Despins, Ch 11 Trustee/Luc A.

B120 A108 400.00 0.20 80.00 follow up e-mail to Ms. Reyes from M&T that information provided was sufficient. Despins, Ch 11 Trustee/Luc A.

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Phase ID B120 Asset Analysis and Recovery

B120 A102 450.00 6.20 2,790.00 Ho Wan Kwok, Debtor Continue research and review alter ego liability caselaw under varying state jurisdictions (2.4); draft memorandum to client and co-counsel with

Despins, Ch 11 Trustee/Luc A.

B120 A101 175.00 0.30 52.50 Ho Wan Kwok, Debtor File 2 transcript requests for 11/14/23 adversary

Despins, Ch 11 Trustee/Luc A.

B120 A101 175.00 0.70 122.50 Ho Wan Kwok, Debtor File Motion to Extend Removal Deadline; serve

Despins, Ch 11 Trustee/Luc A.

B120 A101 175.00 0.20 35.00 Ho Wan Kwok, Debtor

subpoena to be served upon FDIC instead; send

Despins, Ch 11 Trustee/Luc A.

B120 A103 450.00 5.10 2,295.00 Ho Wan Kwok, Debtor Correspond and confer with R. Flynn regarding motion to compel Seacoast (0.3), revise motion to compel Seacoast Bank (0.5), correspond and confer with trustee regarding motion to compel Seacoast (0.2), correspond with K. Mitchell regarding First Bank of Greenwich declaration (0.1), review FDIC notices regarding Signature

subpoena (0.4), correspond with E. Sutton and D.

subpoena (0.2), correspond and confer with K. Mitchell regarding Citibank compliance and 2004 discovery tracker (0.4), correspond and confer with S. Smeriglio regarding objections to 8th and 9th Rule 2004 motions (0.3), draft motion to expedite motion to compel Seacoast (0.8), revise

regarding declaration in support of Seacoast motion to compel (0.2), memorandum to S. Smeriglio regarding replies to objections to 8th and 9th Rule 2004 motions (0.4), finalize and attention to filing Seacoast motion to compel and motion to expedite same (0.6), correspond with J. Anthony (Seacoast) regarding motion to

Despins, Ch 11 Trustee/Luc A.

B120 A111 500.00 0.80 400.00 Ho Wan Kwok, Debtor Draft memorandum to client and co-counsel with bank compliance information and status of bank

Despins, Ch 11 Trustee/Luc A.

B120 A111 500.00 0.40 200.00 Telephone attorney Linsey regarding plans to

Despins, Ch 11 Trustee/Luc A.

B120 A111 500.00 0.50 250.00 Conference call with attorneys Kinsella and Linsey on alter ego issues, applicable law and

Despins, Ch 11 Trustee/Luc A.

B120 A108 325.00 0.30 97.50 Draft e-mails to Attorney K. Mitchell and Open Bank representative regarding production in

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Phase ID B120 Asset Analysis and Recovery

A104 400.00 0.20 80.00 Despins, Ch 11 Trustee/Luc A.

Review correspondence from Seacoast and P. Linsey (.1), review motion to compel draft to

Despins, Ch 11 Trustee/Luc A.

A104 400.00 0.20 80.00 Review correspondence from DBS in response to meet and confer request. Despins, Ch 11 Trustee/Luc A.

A105 400.00 0.10 40.00 F/u e-mail to D. Skalka regarding Citibank

Despins, Ch 11 Trustee/Luc A.

A104 400.00 0.40 160.00 Review response from A. Lomas on Open Bank for further clarification of documents needed Despins, Ch 11 Trustee/Luc A.

A108 400.00 0.20 80.00 Review and respond to e-mail and attachment from Open Bank regarding native file, provide

Despins, Ch 11 Trustee/Luc A.

A108 400.00 0.20 80.00 Attention to voicemail and e-mail from Marcia Rose of IDB; correspond w/ P. Linsey regarding

Despins, Ch 11 Trustee/Luc A.

A104 400.00 0.50 200.00 Review responses from D. Skalka regarding contact information and productions from banks from 2004 subpoenas, revise/update tracker Despins, Ch 11 Trustee/Luc A.

A108 400.00 0.20 80.00 review Open Bank production and fwd for upload

Despins, Ch 11 Trustee/Luc A.

A108 400.00 0.20 80.00 multiple correspondence regarding missing production from Open Bank, review subpoena,

Despins, Ch 11 Trustee/Luc A.

A109 325.00 0.40 130.00 Attend meeting with Attorneys P. Linsey and E. Sutton regarding objections to 8th and 9th 2004

Despins, Ch 11 Trustee/Luc A.

A108 400.00 0.30 120.00 Rec'v e-mail from Open Bank and request for

reviewed original subpoena, highlighted entities

Despins, Ch 11 Trustee/Luc A.

A103 325.00 0.30 97.50 Draft and revise records with entities that have

Despins, Ch 11 Trustee/Luc A.

A106 400.00 0.30 120.00 Attention to correspondence with client regarding information and strategy for 2004

Despins, Ch 11 Trustee/Luc A.

A105 400.00 0.10 40.00 TC P. Linsey on amended Open Bank subpoena Date: 02/16/2024 Detail Fee Task Code Billing Report Page: 43 Case 22-50073 Doc 2936 Filed 02/19/24 Entered 02/19/24 23:45:45 Page 75 of

Phase ID B120 Asset Analysis and Recovery

B120 A103 400.00 0.30 120.00 Despins, Ch 11 Trustee/Luc A.

Draft amended Open Bank subpoena and send

Despins, Ch 11 Trustee/Luc A.

B120 A108 400.00 0.20 80.00 Ho Wan Kwok, Debtor Conference call with contact from Open Bank regarding amended subpoena. Despins, Ch 11 Trustee/Luc A.

B120 A108 400.00 0.10 40.00 Ho Wan Kwok, Debtor review confirmation of subpoena receipt. Despins, Ch 11 Trustee/Luc A.

B120 A102 450.00 2.20 990.00 Research and review of mere conduit defense

Despins, Ch 11 Trustee/Luc A.

B120 A104 450.00 3.70 1,665.00 Review and analyze explanation for objections from Attorney Suchter to certain production requests in 2004 subpoena (0.4); draft e-mail replying to analysis with detailed supplemental legal analysis, and setting up meet-and-confer

correspondence with Attorney Suchter regarding objections (0.2); conduct associated legal

documents related to suspicious activity reports (1.9). Despins, Ch 11 Trustee/Luc A.

B120 A101 450.00 2.90 1,305.00 Prepare for Kroll meeting (0.3), meeting with P. Parizek and A. Lomas (Kroll) and trustee and trustee's counsel regarding Kroll projects (0.9), correspond with K. Mitchell regarding Open Bank outstanding production (0.2), correspond with K. Mitchell and D. Skalka regarding Citibank

discovery (0.2), correspond with E. Sutton and D. Barron regarding Standard Chartered subpoena and bank's ties to estate (0.2), correspond and confer with E. Sutton regarding objections to 8th and 9th Rule 2004 motions (0.2), correspond with S. Smeriglio regarding objections to 8th and 9th Rule 2004 motions and replies to same (0.2), correspond with K. Mitchell and ULX regarding supplemental Israel Discount Bank production (0.2), review and analyze supplemental IDB

Despins, Ch 11 Trustee/Luc A.

B120 A105 450.00 2.00 900.00 Correspond with NPM 2004 discovery team regarding ULX/Relativity procedures (0.2), correspond and confer with A. Luft regarding G-Club objections to 8th and 9th 2004 discovery motions (0.4), analyze subpoenas in light of G-Club objections (0.3), confer with E. Sutton/PHC1/S. Smeriglio regarding response to numerous objections to Rule 2004 motions and factual background necessary for reply (0.3), confer with S. Smeriglio regarding reply to 2004 motion objections (0.2), correspond with K. Ahumada regarding Nov. 14 hearing transcript (0.1), correspond with J. Jin (Open Bank) and K.

discovery (0.2), confer with K. Mitchell and J. Jin Date: 02/16/2024 Detail Fee Task Code Billing Report Page: 44 Case 22-50073 Doc 2936 Filed 02/19/24 Entered 02/19/24 23:45:45 Page 76 of

Phase ID B120 Asset Analysis and Recovery (Open Bank) regarding Open Bank discovery and

Despins, Ch 11 Trustee/Luc A.

B120 A111 500.00 0.50 250.00 Telephone attorney Kinsella regarding alter ego analysis and bank compliance records issues Despins, Ch 11 Trustee/Luc A.

B120 A108 400.00 0.20 80.00 Correspond with Charles Schwab contact to set

Despins, Ch 11 Trustee/Luc A.

B120 A104 400.00 0.30 120.00 Review documents produced by Open Bank in supplemental production a long with declaration, save to folder, fwd to ULX for upload to Relativity Despins, Ch 11 Trustee/Luc A.

B120 A104 400.00 0.20 80.00 Review correspondence regarding meet and

Despins, Ch 11 Trustee/Luc A.

B120 A104 400.00 0.20 80.00 Receive and review updated appeals tracking

Despins, Ch 11 Trustee/Luc A.

B120 A102 450.00 2.00 900.00 Continue research and review of mere conduit defense caselaw regarding recovery of fraudulent

Despins, Ch 11 Trustee/Luc A.

B120 A101 175.00 0.10 17.50 Send Supplemental Production from Open Bank

Despins, Ch 11 Trustee/Luc A.

B120 A101 175.00 0.30 52.50 Attention to e-mail from Evan Cohen regarding failed service to FDIC; send e-mail to Attorney Linsey and Mitchell regarding alternative agents for service; send FDIC copy of subpoena via

Despins, Ch 11 Trustee/Luc A.

B120 A103 400.00 3.00 1,200.00 Ho Wan Kwok, Debtor Draft Mawah subpoenas, notice of issuance of subpoenas for service: BSI Group (.6), PNC (.5), Silvergate (.4), Prime Trust (.8), Valley National

Despins, Ch 11 Trustee/Luc A.

B120 A108 400.00 0.40 160.00 TC with D. Skalka on project regarding which

Despins, Ch 11 Trustee/Luc A.

B120 A108 400.00 0.60 240.00 Call w Charles Schwab and P. Linsey regarding Schwabs production of documents pursuant to 2004 examination subpoena, follow up e-mail

Despins, Ch 11 Trustee/Luc A.

B120 A108 400.00 0.30 120.00 follow up with Morgan Stanley regarding production of documents and when e-mail files

Despins, Ch 11 Trustee/Luc A.

B120 A105 400.00 0.20 80.00 Correspond with K. Ahumada regarding Date: 02/16/2024 Detail Fee Task Code Billing Report Page: 45 Case 22-50073 Doc 2936 Filed 02/19/24 Entered 02/19/24 23:45:45 Page 77 of

Phase ID B120 Asset Analysis and Recovery

Despins, Ch 11 Trustee/Luc A.

80.00 Correspond w PH regarding subpoenas Despins, Ch 11 Trustee/Luc A.

120.00 rev'd edit sugg from P. Linsey to Notice of

Despins, Ch 11 Trustee/Luc A.

correspondence with D. Skalka and P. Linsey on

Despins, Ch 11 Trustee/Luc A.

160.00 Review motion to compel compliance and motion to expedite and order granting motion to

Despins, Ch 11 Trustee/Luc A.

80.00 review response from Schwab, update tracker re

Despins, Ch 11 Trustee/Luc A.

405.00 Draft memorandum to Attorney Suchter

Business Bank in response to 2004 subpoena (0.4); attend follow-up telephone call with Attorney Suchter regarding document requests 7 and 8 (0.5). Despins, Ch 11 Trustee/Luc A.

90.00 Draft and revise e-mails to United Lex and Royal Business Bank to facilitate document production directly from Royal Business Bank. Despins, Ch 11 Trustee/Luc A.

810.00 Research 31 USC 5318, BSA, and related federal

disclosure of SARs/related information in response to a subpoena. Despins, Ch 11 Trustee/Luc A.

765.00 Research regarding FDIC receivership of Signature Bank in furtherance of obtaining production with respect to Signature Rule 2004

regarding service of FDIC subpoena (0.2), draft cover email to FDIC for electronic service and

electronic service (0.2), attention to hearing notice regarding motion to compel Seacoast and correspond with John Anthony regarding same and in response to prior email regarding counsel fees (0.3), correspond with P. Doucette and E. Sutton regarding NAV consulting subpoena (0.2), review and analyze supplemental production

Despins, Ch 11 Trustee/Luc A.

80.00 Review response from Schwab regarding findings from search for 2004 exam targets, responded to

Despins, Ch 11 Trustee/Luc A.

Date: 02/16/2024 Detail Fee Task Code Billing Report Page: 46 Case 22-50073 Doc 2936 Filed 02/19/24 Entered 02/19/24 23:45:45 Page 78 of

Phase ID B120 Asset Analysis and Recovery

A B120 A104 325.00 2.00 650.00 Review G Club Operations LLC objection and caselaw therein and begin preparation of draft

Despins, Ch 11 Trustee/Luc A.

A B120 A104 325.00 4.50 1,462.50 Ho Wan Kwok, Debtor Draft and revise reply memorandum to G Club Operations, Shin Hsin Yu, and Jie Zhang's objection to trustee's 8th supplemental omnibus

Despins, Ch 11 Trustee/Luc A.

A B120 A105 450.00 0.20 90.00 Ho Wan Kwok, Debtor Confer with S. Smeriglio and PHC1 regarding replies to objections to 8th and 9th 2004 exam

Despins, Ch 11 Trustee/Luc A.

A B120 A104 400.00 0.20 80.00 Review schedules and breakdown of Kwok

Despins, Ch 11 Trustee/Luc A.

A B120 A105 400.00 0.20 80.00 Ho Wan Kwok, Debtor Correspond w/ P. Linsey regarding need for another supp motion for 2004 exam of new bank identified. Despins, Ch 11 Trustee/Luc A.

A B120 A105 400.00 0.20 80.00 Ho Wan Kwok, Debtor

information on individuals contained in the subpoena search w suggestion for next steps Despins, Ch 11 Trustee/Luc A.

A B120 A107 325.00 0.20 65.00 Ho Wan Kwok, Debtor Meet with Attorney P. Linsey regarding evidence to attach in reply to objection of 2004 motion Despins, Ch 11 Trustee/Luc A.

A B120 A104 400.00 0.60 240.00 Ho Wan Kwok, Debtor Review supp upload of Israel Discount Bank documents for missing bank accts requested by Kroll, e-mail to P. Linsey indicating same Despins, Ch 11 Trustee/Luc A.

A B120 A105 400.00 0.20 80.00 Call with D. Carnelli whether SAR reports are

Despins, Ch 11 Trustee/Luc A.

A B120 A103 450.00 0.60 270.00 Draft/revise memorandum to Attorney Suchter in advance of meet-and-confer on 2004 subpoena to Royal Business Bank. Despins, Ch 11 Trustee/Luc A.

A B120 A108 450.00 0.90 405.00 Communicate (other external) with Attorney Diane Suchter regarding meet-and-confer for 2004 subpoena to Royal Business Bank. Despins, Ch 11 Trustee/Luc A.

A B120 A104 450.00 2.30 1,035.00 Review and analyze supplemental production (dated 11/17/23) from RBB. Despins, Ch 11 Trustee/Luc A.

A B120 A104 400.00 0.60 240.00 Review Relativity for full compliance to 2004

Despins, Ch 11 Trustee/Luc A.

A B120 A108 400.00 0.30 120.00 Correspond with P. Linsey and E. Lacombe from TD bank re redactions, coordinate and set up

Despins, Ch 11 Trustee/Luc A. Date: 02/16/2024 Detail Fee Task Code Billing Report Page: 47 Case 22-50073 Doc 2936 Filed 02/19/24 Entered 02/19/24 23:45:45 Page 79 of

Phase ID B120 Asset Analysis and Recovery

B120 A105 400.00 0.20 80.00 Ho Wan Kwok, Debtor correspond w K.A. regarding citibank production and upload to relativity. Despins, Ch 11 Trustee/Luc A.

B120 A101 400.00 0.50 200.00 Ho Wan Kwok, Debtor Call w P. Linsey to prep for Kroll call tomorrow regarding outstanding documents from banks'

Despins, Ch 11 Trustee/Luc A.

B120 A108 400.00 0.30 120.00 Correspond w BoA counsel regarding amended

Despins, Ch 11 Trustee/Luc A.

B120 A104 400.00 0.20 80.00 Ho Wan Kwok, Debtor Review proof of service for First County Bank,

Despins, Ch 11 Trustee/Luc A.

B120 A106 400.00 0.30 120.00 Ho Wan Kwok, Debtor correspond with client regarding service of most recent subpoenas, review whether PoS received, respond to same. Despins, Ch 11 Trustee/Luc A.

B120 A102 450.00 1.20 540.00 Ho Wan Kwok, Debtor Research service of process on active foreign

Despins, Ch 11 Trustee/Luc A.

B120 A104 400.00 0.50 200.00 Review Axos production for completion re Kroll

Despins, Ch 11 Trustee/Luc A.

B120 A103 325.00 4.00 1,300.00 Review and revise response to objection of 8th

Despins, Ch 11 Trustee/Luc A.

B120 A103 325.00 5.50 1,787.50 Review and analyze objections to the 9th Rule 2004 Motion (1.5); draft and revise response to

Despins, Ch 11 Trustee/Luc A.

B120 A105 400.00 0.20 80.00 review correspondence from P. Linsey regarding

Despins, Ch 11 Trustee/Luc A.

B120 A105 400.00 0.30 120.00 Reviewed detailed e-mail from Kroll regarding findings of possible new entities, productions in which there are issues (redactions), missing documents, etc., correspond with P. Linsey regarding prior link found in another bank's

Despins, Ch 11 Trustee/Luc A.

B120 A103 450.00 1.30 585.00 Draft and revise follow-up e-mail to Attorney

suspicious activity reports (0.3); continue conduct supplemental legal research and review of

1020.320 (1.0). Despins, Ch 11 Trustee/Luc A.

B120 A108 400.00 0.20 80.00 Correspondence w P. Linsey and Axos Bank rep regarding outstanding subpoena compliance

Despins, Ch 11 Trustee/Luc A.

Date: 02/16/2024 Detail Fee Task Code Billing Report Page: 48 Case 22-50073 Doc 2936 Filed 02/19/24 Entered 02/19/24 23:45:45 Page 80 of

Phase ID B120 Asset Analysis and Recovery

B120 A111 500.00 0.60 300.00 Telephone attorney Linsey regarding status of Kroll analysis, motions to compel and alter ego

Despins, Ch 11 Trustee/Luc A.

B120 A111 500.00 0.80 400.00 Ho Wan Kwok, Debtor Attend conference call with client , attorney Linsey and attorney Carnelli regarding discovery disputes, and status of avoidance action analysis Despins, Ch 11 Trustee/Luc A.

A B120 A105 450.00 2.10 945.00 Correspond and confer with S. Smeriglio and PHC1 regarding replies to objections to 8th and 9th Rule 2004 motions (0.2), confer with D.

review/follow-up project (0.3), prepare for

projects (0.5), confer and correspond with S.

motions/objections (0.2), confer with K. Mitchell regarding TD Bank/Axos/Morgan Stanley/Bank of America subpoena compliance and open issues (0.5), correspond with A. Lomas and P. Parizek

discovery/avoidance analysis (0.2), draft cover email for correspondence with K. Rudd (Bank of

correspond with K. Mitchell regarding same (0.2) Despins, Ch 11 Trustee/Luc A.

A B120 A101 450.00 3.00 1,350.00 Ho Wan Kwok, Debtor Prepare for standing meeting with trustee regarding NPM projects (0.5), correspond with D. Skalka and D. Carnelli regarding meeting with trustee (0.1), standing call with trustee (0.4), confer with D. Skalka regarding further banks

production per bank counsel's comments (0.2), correspond with M. Cesena and K. Mitchell regarding Axos Bank outstanding documents and correcting bank counsel's understanding as to prior production (0.2), correspond with A. Lomas regarding facts for motion to compel DBS Bank (0.3), memorandum to R. Flynn regarding motion to compel DBS Bank (0.5), review/analyze further production from UBS (0.4), correspond with L. Fried regarding Nov. 28 hearing on

Despins, Ch 11 Trustee/Luc A.

A B120 A103 325.00 1.80 585.00 Ho Wan Kwok, Debtor Draft and revise citations in reply to objection of rule 2004 Motion (.9); revise reply memorandum

Despins, Ch 11 Trustee/Luc A.

A B120 A108 400.00 0.30 120.00 Ho Wan Kwok, Debtor attention to correspondence and attachments from Kroll regarding DBS documents needed in

Despins, Ch 11 Trustee/Luc A.

A B120 A104 400.00 0.20 80.00 Review follow ups to RBB meet and confer call on

Despins, Ch 11 Trustee/Luc A.

A B120 A108 400.00 0.30 120.00 rec'v and reviewed e-mails bt P. Linsey and Axos bank in response to f/u email, update tracker and Date: 02/16/2024 Detail Fee Task Code Billing Report Page: 49 Case 22-50073 Doc 2936 Filed 02/19/24 Entered 02/19/24 23:45:45 Page 81 of

Phase ID B120 Asset Analysis and Recovery

Despins, Ch 11 Trustee/Luc A.

400.00 1.00 400.00 Draft motion to adjourn UBS motion to compel

Despins, Ch 11 Trustee/Luc A.

325.00 0.50 162.50 Revise citations in reply to the 9th Rule 2004

Despins, Ch 11 Trustee/Luc A.

400.00 1.30 520.00 Draft 10th Supplemental Motion for 2004 Exam (1), revise RFPs to include specific language (.2), coordinate creation of new subpoenas with K.

Despins, Ch 11 Trustee/Luc A.

400.00 0.30 120.00 Call w P. Linsey regarding outstanding Kroll

Despins, Ch 11 Trustee/Luc A.

400.00 0.40 160.00 Ho Wan Kwok, Debtor conference call with P. Linsey and Beth Lacombe

Despins, Ch 11 Trustee/Luc A.

400.00 1.00 400.00 Prepare for call with Kroll 11/22/23 regarding bank subpoenas and avoidance action status Despins, Ch 11 Trustee/Luc A.

400.00 0.10 40.00 rec'v status request of service of subpoenas from

Despins, Ch 11 Trustee/Luc A.

400.00 0.40 160.00 reviewed and responded to several e-mails regarding supplemental production by Israel Discount Bank, rec'v supp production, saved to

Despins, Ch 11 Trustee/Luc A.

325.00 0.50 162.50 Revise reply of G Club Operations LLC Limited objection to eighth supplemental rule 2004

Despins, Ch 11 Trustee/Luc A.

175.00 3.00 525.00 Ho Wan Kwok, Debtor Service of Motion for Status Conference on manual service parties (1.0); service of Notice of

Despins, Ch 11 Trustee/Luc A.

175.00 0.20 35.00 Correspond w K. Mitchell; make Kearny Bank and

Despins, Ch 11 Trustee/Luc A.

400.00 0.10 40.00 Correspond with P. Linsey regarding consent

Despins, Ch 11 Trustee/Luc A.

450.00 4.60 2,070.00 Correspond with E. Sutton and K. Ahumada regarding service of hearing notice regarding 8th and 9th Rule 2004 motions (0.2), draft certificate of service regarding hearing on pending rule 2004 motions, objections, etc. and attention to

Date: 02/16/2024 Detail Fee Task Code Billing Report Page: 50 NEUBERT, PEPE & MONTEITH, P.C. Case 22-50073 Doc 2936 Filed 02/19/24 Entered 02/19/24 23:45:45 Page 82 of 230

Phase ID B120 Asset Analysis and Recovery filing same (0.4), correspond with K. Mitchell reading 10th rule 2004 motion (0.2), correspond with A. Lomas and P. Parizek (Kroll) regarding 10th rule 2004 motion (0.2), confer with E. Sutton regarding replies to Rule 2004 objections (0.1), review and analyze G-Club objections to 8th and 9th rule 2004 motions (0.6), review and analyze proposed intervenor objections to 8th and 9th rule 2004 motions (0.7), revise omnibus reply to objections to 8th rule 2004 motion (1.8), review E. Sutton and S. Smeriglio further revisions to reply regarding 8th rule 2004 motion and revise further (0.2), correspond with trustee regarding reply to objections to 8th rule 2004 motion (0.2) Despins, Ch 11 Trustee/Luc A.

A104 450.00 4.60 2,070.00 Review and analyze supplemental production from Axos Bank (0.6), correspond with M. Cesena and M. Medina (Axos) regarding supplemental production and outstanding documents (0.2), review pleadings from HCHK A.P. in connection with omnibus reply re: 9th rule 2004 motion (0.5), revise omnibus reply to objections to 9th rule 2004 motion (1.8), correspond with S. Smeriglio and E. Sutton regarding draft reply re: 9th rule 2004 motion (0.2), review and analyze initial Rule 2004 production from Morgan Stanley (1.1),

regarding Morgan Stanley production (0.2) Despins, Ch 11 Trustee/Luc A.

A108 450.00 1.60 720.00 Correspond with L. Fried regarding hearing on motion to compel UBS (0.2), confer with K. Mitchell regarding consent motion to adjourn UBS hearing/outstanding banks discovery/10th rule 2004 motion (0.3), correspond with K. Mitchell regarding UBS consent motion (0.1), confer with E. Lacombe (TD Bank) and K. Mitchell regarding problems with TD Bank production (0.3), correspond with K. Mitchell regarding next steps with TD Bank (0.2), revise consent motion to adjourn UBS hearing and correspond with L. Fried and K. Mitchell regarding same (0.3), confer with R. Flynn regarding motion to compel DBS

Despins, Ch 11 Trustee/Luc A.

A101 400.00 0.30 120.00 Prepare agenda for call with Kroll today,

Despins, Ch 11 Trustee/Luc A.

A101 175.00 0.20 35.00 Send supplemental production to ULX via

Despins, Ch 11 Trustee/Luc A.

A103 400.00 0.40 160.00 received communication from Kroll regarding new information/institutions, revise tracker re

Despins, Ch 11 Trustee/Luc A.

A108 400.00 1.00 400.00 Conference call with Kroll on bank discovery and

Despins, Ch 11 Trustee/Luc A.

A104 400.00 0.30 120.00 Review further production from IDB in response Date: 02/16/2024 Detail Fee Task Code Billing Report Page: 51 Case 22-50073 Doc 2936 Filed 02/19/24 Entered 02/19/24 23:45:45 Page 83 of

Phase ID B120 Asset Analysis and Recovery to 2004 exam subpoena, update tracker, inform

Despins, Ch 11 Trustee/Luc A.

A B120 A104 400.00 0.20 80.00 Review response from PH on draft motion to

Despins, Ch 11 Trustee/Luc A.

A B120 A101 175.00 0.60 105.00 Service Reply to Objection of 8th Supplemental

Despins, Ch 11 Trustee/Luc A.

A B120 A104 450.00 0.90 405.00 Preliminary review of supplemental compliance

subpoena. Despins, Ch 11 Trustee/Luc A.

A B120 A104 400.00 0.20 80.00 review response from K. Rudd of BoA to subpoena, reviewed response from P. Linsey to

Despins, Ch 11 Trustee/Luc A.

A B120 A105 450.00 3.90 1,755.00 Ho Wan Kwok, Debtor Correspond with K. Mitchell regarding banks rule 2004 discovery in advance of call with Kroll team (0.2), prepare for call with Kroll team regarding banks discovery and avoidance analysis (0.4), meeting with A. Lomas, P. Parizek, D. Barron and K. Mitchell regarding developments in banks discovery and avoidance analysis (1.0), review

correspond with ULX and D. Barron regarding Comerica production (0.2), review and analyze supplemental Bank of America production (0.4), correspond with K. Mitchell and K. Rudd (Bank of

America production (0.2), correspond with trustee regarding replies to 8th and 9th Rule 2004 motion objections (0.2), further revise reply

correspond with L. Fried and trustee regarding adjournment of motion to compel UBS (0.2), finalize motion to adjourn hearing on motion to compel UBS and attention to filing same (0.3) Despins, Ch 11 Trustee/Luc A.

A B120 A106 450.00 2.40 1,080.00 Ho Wan Kwok, Debtor Correspond with trustee regarding reply to objections to 8th Rule 2004 motion (0.1), finalize reply to objections to 8th Rule 2004 motion and attention to filing same (0.6), review and analyze production from Evolve Bank and Trust (1.4), correspond and confer with D. Barron regarding use of Wise platform (0.2), correspond with ULX

Despins, Ch 11 Trustee/Luc A.

A B120 A107 450.00 0.60 270.00 Correspond with N. Bassett regarding reply to objections to 9th Rule 2004 motion (0.1), correspond and confer with R. Barry (FDIC) regarding subpoena for Signature Bank records

Despins, Ch 11 Trustee/Luc A.

A B120 A108 400.00 0.20 80.00 attention to correspondence from FDIC counsel regarding Signature Bank subpoena and call on

Date: 02/16/2024 Detail Fee Task Code Billing Report Page: 52 Case 22-50073 Doc 2936 Filed 02/19/24 Entered 02/19/24 23:45:45 Page 84 of

Phase ID B120 Asset Analysis and Recovery

80.00 Despins, Ch 11 Trustee/Luc A.

Review Relativity upload summary for week,

Despins, Ch 11 Trustee/Luc A.

attention to correspondence from P. Linsey regarding motion to compel DBS, respond to

Despins, Ch 11 Trustee/Luc A.

Correspond with R. Flynn regarding DBS motion

correspondence/subpoenas/related documents for motion to compel (0.2), correspond with R. Flynn and K. Mitchell regarding prior DBS subpoena (0.1), correspond with D. Skalka and trustee regarding NPM planning call (0.2), prepare notice regarding reply regarding 8th rule 2004 motion and attention to filing same (0.3), review N. Bassett revisions to reply regarding 9th rule 2004 motion and finalize reply (0.4), correspond with trustee regarding replies regarding rule 2004 motions (0.2), correspond

debtor-associated entities in preparation for hearing on 8th and 9th rule 2004 motions and review documents flagged by D. Barron (0.6) Despins, Ch 11 Trustee/Luc A.

765.00 Memorandum to P. Parizek and A. Lomas (Kroll) and D. Barron regarding developments with FDIC regarding Signature Bank subpoena and next steps (0.4), correspond with R. Barry (FDIC) regarding Signature Bank subpoena/protective order/and searches (0.3), prepare for Nov. 28 hearing (0.5), memorandum to trustee and PH counsel regarding agenda for Nov. 28 hearing (0.3), correspond with K. Ahumada regarding

Despins, Ch 11 Trustee/Luc A.

120.00 attention to request from R. Flynn regarding DBS amended subpoena, respond to same, f/u with K.

Despins, Ch 11 Trustee/Luc A.

80.00 Review multiple e-mails and docs b/t P. Linsey and counsel for FDIC (Signature Bank) to prepare

Despins, Ch 11 Trustee/Luc A.

200.00 Meet and confer with FDIC regarding subpoena

Despins, Ch 11 Trustee/Luc A.

120.00 Research what constitutes effective service on

Despins, Ch 11 Trustee/Luc A.

80.00 correspondence w/ D. Skalka re compliance review of bank documents in relativity. Despins, Ch 11 Trustee/Luc A.

195.00 Review, analyze and mark Comerica bank Date: 02/16/2024 Detail Fee Task Code Billing Report Page: 53 Case 22-50073 Doc 2936 Filed 02/19/24 Entered 02/19/24 23:45:45 Page 85 of

Phase ID B120 Asset Analysis and Recovery document production in response to 2004

A103 400.00 0.30 120.00 subpoena for compliance related documents Despins, Ch 11 Trustee/Luc A.

Despins, Ch 11 Trustee/Luc A.

A104 325.00 1.10 357.50 Review, analyze and mark Evolve Bank & Trust

subpoena for compliance related documents Despins, Ch 11 Trustee/Luc A.

A104 400.00 1.10 440.00 Review relativity for compliance documents for follow up (1), e-mail to D. Skalka with results (.1) Despins, Ch 11 Trustee/Luc A.

A106 400.00 0.20 80.00 attention to correspondence from P. Linsey and PNC Bank re providing add'l information for subpoena compliance, f/u with client to ascertain

Despins, Ch 11 Trustee/Luc A.

A103 400.00 0.30 120.00 Draft cover letters for USA and DOJ for service of subpoena to FDIC as servicer to Signature Bank Despins, Ch 11 Trustee/Luc A.

A103 400.00 0.20 80.00 Review comments from K. Ahumada, revised letters and fwd to P. Linsey for review/signature Despins, Ch 11 Trustee/Luc A.

A103 400.00 0.30 120.00 review e-mail from P. Linsey with edits, revised

Despins, Ch 11 Trustee/Luc A.

A104 400.00 0.30 120.00 Review correspondence from P. Linsey re FDIC cover letters and subpoenas, prepare complete packages and provide to E. Cohen for service, fwd copies of same to K. Ahumada for service re

Despins, Ch 11 Trustee/Luc A.

A104 400.00 0.90 360.00 review relativity BoA, CitiBank and M&T Bank's supplemental productions for compliance data Despins, Ch 11 Trustee/Luc A.

A104 325.00 3.00 975.00 Review, analyze and mark Morgan Stanley

subpoena for compliance related documents Despins, Ch 11 Trustee/Luc A.

A104 400.00 0.20 80.00 review correspondence from Kroll regarding

Despins, Ch 11 Trustee/Luc A.

A108 400.00 0.10 40.00 review substance and respond to meeting request bt Kroll and P. Linsey and client for this

Despins, Ch 11 Trustee/Luc A.

A101 175.00 6.00 1,050.00 Prepare exhibits and materials for hearing Despins, Ch 11 Trustee/Luc A.

A103 325.00 0.40 130.00 Draft and revise NPM document review records based upon review of Comerica Bank, Evolve and Date: 02/16/2024 Detail Fee Task Code Billing Report Page: 54 Case 22-50073 Doc 2936 Filed 02/19/24 Entered 02/19/24 23:45:45 Page 86 of

Phase ID B120 Asset Analysis and Recovery Trust Bank, and Morgan Stanley based upon

Despins, Ch 11 Trustee/Luc A.

A111 500.00 0.70 350.00 Attend conference call with client and attorney Linsey regarding discovery and avoidance action

Despins, Ch 11 Trustee/Luc A.

A111 500.00 0.80 400.00 Review bank compliance document status (.5); and draft memorandum to attorney Mitchell regarding 11/28 call and compliance document

Despins, Ch 11 Trustee/Luc A.

A105 450.00 3.20 1,440.00 Correspond with K. Ahumada regarding Nov. 28 hearing (0.2), correspond with K. Mitchell and R. Flynn regarding motion to compel DBS Bank (0.2), prepare for meet-and-confer with FDIC counsel (0.3), telephone conference with R. Barry (FDIC) and K. Mitchell (0.5), correspond and confer with K. Ahumada regarding materials for Nov. 28 hearing (0.2), prepare for hearing on 8th and 9th Rule 2004 motions (0.4), review and analyze FDIC regulations regarding service and extent of FDIC's compliance (0.5), correspond with K. Mitchell regarding FDIC's position (0.2), correspond with K. Mitchell and D. Carnelli about

correspond with R. Flynn regarding motion to

question (0.2), correspond further with K. Mitchell and D. Carnelli regarding FDIC subpoena compliance and revise letters to U.S. Attorney

Despins, Ch 11 Trustee/Luc A.

A105 450.00 3.40 1,530.00 Prepare for weekly update call with trustee (0.5), confer with D. Skalka regarding weekly update call with trustee and avoidance claims (0.3),

regarding Nov. 28 hearing (0.2), confer with trustee, D. Skalka, and D. Carnelli regarding NPM litigation projects (0.7), correspond with E. LaCombe (TD Bank) regarding HCHK Entities' bank records (0.2), correspond with K. Mitchell regarding FDIC subpoena service (0.2), draft lengthy correspondence to R. Barry (FDIC) responding to FDIC's defenses and providing further information regarding accounts (0.6), correspond with A. Lomas (Kroll) regarding Signature Bank accounts (0.2), correspond with M. Boynton (Comerica) and K. Mitchell regarding amended Comerica subpoena (0.2), correspond with A. Luft and D. Barron regarding transcript to Nov. 14 hearing (0.1), correspond with E. Sutton regarding further meet and confer with J. Nealon

Despins, Ch 11 Trustee/Luc A.

A104 325.00 0.10 32.50 Review and analyze updated records of

determining status of responses to rule 2004

Despins, Ch 11 Trustee/Luc A. Date: 02/16/2024 Detail Fee Task Code Billing Report Page: 55 Case 22-50073 Doc 2936 Filed 02/19/24 Entered 02/19/24 23:45:45 Page 87 of

NEUBERT, PEPE & MONTEITH, P.C.

Phase ID B120 Asset Analysis and Recovery

B120 A103 450.00 0.30 135.00 Draft analysis regarding service of subpoena

Despins, Ch 11 Trustee/Luc A.

B120 A108 400.00 0.20 80.00 rec'v response from client regarding PNC bank,

Despins, Ch 11 Trustee/Luc A.

B120 A105 400.00 0.40 160.00 TC w D. Skalka regarding compliance related

Despins, Ch 11 Trustee/Luc A.

B120 A108 400.00 0.20 80.00 Ho Wan Kwok, Debtor correspondence to S. Phan at Relativity regarding

Despins, Ch 11 Trustee/Luc A.

B120 A104 400.00 0.20 80.00 Review correspondence regarding modification of pretrial order, response from defendant, and

Despins, Ch 11 Trustee/Luc A.

B120 A104 400.00 1.00 400.00 Review recent bank productions for compliance with 2004 subpoena and Kroll outstanding list Despins, Ch 11 Trustee/Luc A.

B120 A108 400.00 0.30 120.00 Several communications with Relativity regarding narrowing search for bank compliance docs,

Despins, Ch 11 Trustee/Luc A.

B120 A108 400.00 0.20 80.00 Ho Wan Kwok, Debtor rec'v and rev'd response from Kroll regarding