Guo Wengui / Miles Guo — bankruptcy case · ORDER · ECF #2938

UNITED STATES BANKRUPTCY COURT DISTRICT OF CONNECTICUT BRIDGEPORT DIVISION

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In re: : :

HO WAN KWOK, et al., : :

Debtors.1 : :

MONTHLY FEE STATEMENT OF O'SULLIVAN MCCORMACK JENSEN & BLISS PC FOR COMPENSATION AND REIMBURSEMENT OF EXPENSES FOR PERIOD FROM JANUARY 1, 2024 THROUGH JANUARY 31, 2024

In accordance with the *Order Establishing Procedures for Interim Compensation and Reimbursement of Expenses for Retained Professionals, dated August 18, 2023* [Docket No. 2094] (the "Interim Compensation Order"),[2] O'Sullivan McCormack Jensen & Bliss PC ("OMJB") hereby submits this monthly statement (the "Monthly Fee Statement") seeking compensation for services rendered and reimbursement of expenses incurred as Special Insurance Counsel to Genever Holdings LLC ("Genever (US)"), for the period from January 1, 2024 through and including January 31, 2024 (the "Fee Period"). By this Monthly Fee Statement, OMJB respectfully requests payment of 80% of all fees and 100% of all expenses actually and necessarily incurred for services rendered during the Fee Period, in the amounts of \$8,954.00 and \$786.41 respectively.

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

2 Capitalized terms not otherwise defined herein shall have the meanings ascribed to such terms in the Interim Compensation Order.

1. Attached hereto as Exhibit A is a timekeeper summary that includes the name, title, bar admission, hourly billing rate, aggregate hours, and amount of fees earned for each OMJB individual who provided services during the Fee Period. The rates charged by OMJB for services rendered to Genever (US) are the same rates that OMJB charges generally for professional services rendered to its non-bankruptcy clients.

2. Attached hereto as Exhibit B is a summary of expenses incurred and reimbursement sought, by expense type, for the Fee Period.

3. Attached hereto as Exhibit C is the fee statement of OMJB for services provided during the Fee Period with redactions to protect certain privileged information.

4. Notice of this Monthly Fee Statement will be given by email on the Notice Parties: (i) Luc A. Despins, as chapter 11 trustee for the estate of Ho Wan Kwok (lucdespins@paulhastings.com); (ii) Counsel for the Trustee, (x) Paul Hastings LLP, 200 Park Avenue, New York, New York 10166 (Attn: G. Alexander Bongartz (alexbongartz@paulhastings.com) and Douglass Barron (douglassbarron@paulhastings.com)) and (y) Neubert, Pepe & Monteith, P.C., 195 Church Street, 13th Floor, New Haven, Connecticut 06510 (Attn: Douglas S. Skalka (dskalka@npmlaw.com) and Patrick R. Linsey (plinsey@npmlaw.com)); (iii) the Office of The United States Trustee, Giaimo Federal Building, 150 Court Street, Room 302, New Haven, Connecticut 06510 (Attn: Holley L. Claiborn (holley.l.claiborn@usdoj.gov)); (iv) counsel for the Official Committee of Unsecured Creditors, Pullman & Comley, LLC, 850 Main Street, 8th Floor, PO Box 7006, Bridgeport, Connecticut 06601-7006 (Attn: Irve J. Goldman (igoldman@pullcom.com); and (v) counsel for Pacific Alliance Asia Opportunity Fund L.P., O'Melveny & Myers LLP, 7 Times Square, New York, New York 10036 (Attn: Peter Friedman (pfriedman@omm.com) and Stuart M. Sarnoff (ssarnoff@omm.com) (collectively, the "Notice Parties").

5. Objections to this Monthly Fee Statement, if any, must be filed with the Court and served upon (i) Special Insurance Counsel to Genever Holdings LLC, O'Sullivan McCormack Jensen & Bliss PC (Attn: Michael T. McCormack [\(mmccormack@omjblaw.com\)] (ii) the Notice Parties by email no later than March 12, 2024 at 4:00 p.m. (prevailing Eastern Time) (the "Objection Deadline"), setting forth the nature of the objection and the specific amount of fees or expenses at issue.

6. If no objections to this Monthly Fee Statement are filed and received on or before the Objection Deadline, Genever (US) shall promptly pay OMJB 80% of the fees and 100% of the expenses as identified in this Monthly Fee Statement.

7. To the extent that an objection to this Monthly Fee Statement is filed and received on or before the Objection Deadline, the estates shall withhold payment of that portion of this Monthly Fee Statement to which the objection is directed and promptly pay the remainder of the fees and expenses in the percentages set forth above. To the extent such an objection is not resolved, it shall be preserved and scheduled for consideration at the next interim fee application hearing. Dated: February 20, 2024 Glastonbury, Connecticut

By:\_\_\_/s/Michael T. McCormack\_\_\_\_\_\_\_\_

Michael T. McCormack (ct13799) Timothy P. Jensen (ct18888) Amy E. Markim (ct27974) O'Sullivan McCormack Jensen & Bliss PC 180 Glastonbury Boulevard, Suite 210 Glastonbury, CT 06033 Tel: 860-258-1993 Fax: 860-258-1991 mmccormack@omjblaw.com tjensen@omjblaw.com amarkim@omjblaw.com

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

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In re: :

HO WAN KWOK, et al.,1 : :

Debtors. :

The undersigned hereby certifies that on February 20, 2024, the foregoing Monthly Fee

Statement was electronically filed. In addition, a copy of the Monthly Fee Statement was served

by email on the Notice Parties. Parties may access this filing through the Court's CM/ECF system.

By:\_\_/s/Michael T. McCormack\_\_\_\_\_\_\_\_

Michael T. McCormack (ct13799) Timothy P. Jensen (ct18888) Amy E. Markim (ct27974) O'Sullivan McCormack Jensen & Bliss PC 180 Glastonbury Boulevard, Suite 210 Glastonbury, CT 06033 Tel: 860-258-1993 Fax: 860-258-1991 mmccormack@omjblaw.com tjensen@omjblaw.com amarkim@omjblaw.com Special Insurance Coverage Counsel for Debtor-In-Possession Genever Holdings LLC

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

Timothy Jensen 1997 \$450 6.7 \$3,015.00

Michael McCormack 1993 \$400 19.0 \$7,600.00 Melissa Gambardella \$125 2.1 \$262.50

Fees Advanced for Logikcull Invoice – \$250.00

Mileage 2024: RT Travel to Bridgeport \$71.02

Case 22-50073 Doc 2938 Filed 02/20/24 Entered 02/20/24 12:28:41 Page 9 of 11

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

Genever Holdings LLC c/o Luc Despins, Esq. Paul Hastings LLP 200 Park Avenue New York, NY 10166 3726-001-Genever Holdings/AIG Property Casualty

Date Attorney Activity Time Rate Total

01/08/2024 TPJ Attend to deficiency letter to AIG 1.50 \$450.00 \$675.00 01/09/2024 TPJ Attend to discovery deficiency letter to AIG re production 2.50 \$450.00 \$1,125.00 01/12/2024 TPJ Communications with AIG re deficiency 0.20 \$450.00 \$90.00 01/16/2024 MTM Draft summary of legal analysis for Mr. Despins re

01/17/2024 TPJ Communications with AIG re deficiency 0.20 \$450.00 \$90.00 01/18/2024 MBG Draft MJB Statement of Fees n Kwok Bankruptcy matter. 0.70 \$125.00 \$87.50 01/18/2024 MTM Review of AIG Answer to Amended Complaint re bad

01/19/2024 MTM Review and finalize monthly fee application and supporting documents 0.20 \$400.00 \$80.00 01/19/2024 AM Review monthly fee application and invoice in support of same. 0.30 \$350.00 \$105.00 01/19/2024 MTM Continued review and analysis of AIG answer to amended complaint re

01/19/2024 MBG Attention to redaction of OMJB December 2023 invoice and finalize and e-file Fee Statement for same and email copy to Notice Parties. 0.40 \$125.00 \$50.00 01/24/2024 TPJ Prepare for and attend discovery conference with AIG 2.10 \$450.00 \$945.00 01/25/2024 MTM Draft email to Mr. Despins re

01/29/2024 MTM Review of loss documents from John Panico at Affiliated 0.60 \$400.00 \$240.00 Invoice No. 27423 - 02/09/2024 Case 22-50073 Doc 2938 Filed 02/20/24 Entered 02/20/24 12:28:41 Page 10 of 11

01/29/2024 MTM Prepare for summary judgment hearing: Review of cases and analysis and draft of outline re argument 6.30 \$400.00 \$2,520.00

01/29/2024 MTM Attention to damages analysis issues and research re same \$400.00 \$120.00 01/29/2024 MBG Preparation of Motion for Summary Judgment hearing binder. \$125.00 \$87.50 01/30/2024 AM Review, revise, and supplement damages analysis. \$350.00 \$140.00

Review and analysis of cases re 0.80 \$400.00 \$320.00

01/30/2024 MTM Telephone conference with Mr. Panico re property loss damages 0.40 \$400.00 \$160.00 01/30/2024 MTM Continued review of notes and cases re preparation for oral argument re summary judgment 1.20 \$400.00 \$480.00 01/30/2024 MTM Attend hearing in Bridgeport re motion for summary judgment and present argument in support of motion 4.30 \$400.00 \$1,720.00

Email communications with Attny Bongartz re 0.20 \$400.00 \$80.00 01/30/2024 TPJ Review motion for subpoena and order re same 0.20 \$450.00 \$90.00 01/30/2024 MBG Email communications re Interim Fee App; Draft of transcript order of

01/31/2024 MTM Telephone conference with Attny Bongartz re

01/31/2024 AM Respond to inquiry from E. Sutton re: depositions in adversary

Expense 01/12/2024 Fees advanced to Logikcull INV156222 12-31-2023 \$250.00 Expense 01/30/2024 Mileage 2024: RT Travel to Bridgeport bankruptcy court \$71.02 Expense 01/31/2024 Copying: Month of January \$58.40 Expense 01/31/2024 Westlaw: Month of January \$406.99

Timothy Jensen 6.7 \$450.00 \$3,015.00

Michael McCormack 19.0 \$400.00 \$7,600.00 Melissa Gambardella 2.1 \$125.00 \$262.50

Invoice Number Due On Amount Due Payments Received Balance Due

27021 09/25/2023 \$99,873.56 \$80,469.56 \$19,404.00 27098 10/11/2023 \$35,374.76 \$28,534.76 \$6,840.00 27168 11/14/2023 \$24,998.95 \$20,063.45 \$4,935.50 27274 12/08/2023 \$31,249.41 \$25,322.41 \$5,927.00 27360 01/09/2024 \$6,578.34 \$0.00 \$6,578.34

Invoice Number Due On Amount Due Payments Received Balance Due

27423 02/09/2024 \$11,978.91 \$0.00 \$11,978.91

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

Payment is due upon receipt.