Guo Wengui / Miles Guo — bankruptcy case · ORDER · ECF #3023

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 FEBRUARY 1, 2024 THROUGH FEBRUARY 29, 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 February 1, 2024 through and including February 29, 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 \$9,360.00 and \$333.85 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 April 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: March 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

In re: :

HO WAN KWOK, et al.,1 : :

Debtors. :

The undersigned hereby certifies that on March 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 11.2 \$5,040.00

Michael McCormack 1993 \$400 12.8 \$5,120.00 Melissa Gambardella \$125 2.8 \$350.00

Fees Advanced for Logikcull Invoice – \$250.00

Fees to Fiore Reporting Services \$53.35

Case 22-50073 Doc 3023 Filed 03/20/24 Entered 03/20/24 14:53:33 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

02/01/2024 MTM Review and analysis of Sherry Netherland remediation documents and bankruptcy motion and status reports re same (.7); review and analysis of cost estimates and summary from Attny Bongartz; attention to damages issues (.6); revise and supplement damages analysis (.3) 1.60 \$400.00 \$640.00 02/02/2024 MBG Attention to finalize and service of Damage Analysis on counsel; attention to transcript order. 0.50 \$125.00 \$62.50 02/08/2024 MTM Review of notice re transcript procedures 0.10 \$400.00 \$40.00 02/08/2024 MBG Review A. Bongartz email and draft Interim Fee App; begin drafting exhibits to Interim Fee App; 0.50 \$125.00 \$62.50 02/09/2024 MTM Begin drafting expert disclosures 1.20 \$400.00 \$480.00 02/12/2024 AM Revise expert disclosures. 0.70 \$350.00 \$245.00 02/12/2024 MTM Revise and supplement draft interim fee application and invoices re same 1.90 \$400.00 \$760.00 02/12/2024 MTM Continued drafting of expert Genever expert disclosures; review and analysis of construction estimates and remediation project documents 2.30 \$400.00 \$920.00 02/12/2024 MTM Draft email to Attny Bongartz re

02/12/2024 MBG Review and revise OMJB Interim Fee App and exhibits thereto 0.70 \$125.00 \$87.50 02/12/2024 MBG Begin draft of OMJB Fee App for January fees and expenses 0.60 \$125.00 \$75.00 02/12/2024 TPJ Reviewing interim fee application. 0.30 \$450.00 \$135.00 02/13/2024 TPJ Review and revise expert witness disclosure. Review status of discovery and communications re same; follow up on subpoenas to third parties 3.10 \$450.00 \$1,395.00 Invoice No. 27521 - 03/11/2024 Case 22-50073 Doc 3023 Filed 03/20/24 Entered 03/20/24 14:53:33 Page 10 of 11

02/13/2024 MTM Telephone conference with Mr. Panico re

02/13/2024 MTM Revise and supplement draft monthly fee submission and attention to redaction of privileged and confidential information re invoices 0.40 \$400.00 \$160.00

supplemental discovery requests; depositions of AIG representatives 1.80 \$400.00 \$720.00

Conference with M. McCormack and T. Jensen re:

02/13/2024 MBG Preparation of redacted version of OMJB Invoice for OMJB January Fees and Expenses Application 0.20 \$125.00 \$25.00 02/13/2024 MTM Revise and supplement interim fee applications; email communications with Attny Bongartz re filing of same 0.60 \$400.00 \$240.00 02/13/2024 MTM Revise and supplement draft expert disclosures (.5); email

conferences with L. Despins re same 0.50 \$400.00 \$200.00 02/14/2024 MTM Review of documents from Mr. Panico re contents inventory and evlauation (.3); revise, supplement and finalize expert disclosures (.4) 0.70 \$400.00 \$280.00 02/14/2024 MBG Revise and finalize Expert Disclosures with exhibits and attention to service of same. 0.30 \$125.00 \$37.50 02/16/2024 MTM Telephone conference with Attny Bongartz re ;

review and finalize revised fee application for filing 0.20 \$400.00 \$80.00 02/16/2024 AM Preliminary review of AIG supplemental document production. 2.20 \$350.00 \$770.00 02/23/2024 MTM Email communications with Attny Kavanaugh re expert depositions 0.10 \$400.00 \$40.00 02/27/2024 MTM Telephone conference with Attny Kavanaugh re expert and fact witness

02/27/2024 TPJ Attend to AIG discovery compliance 1.00 \$450.00 \$450.00 02/28/2024 TPJ Review AIG supplemental document production 2.00 \$450.00 \$900.00 02/29/2024 TPJ Drafting motion to compel responses from third party for failure to comply; communications with third party re subpoena compliance 4.80 \$450.00 \$2,160.00

Expense 01/30/2024 MTM - LAZ parking 1-30-2024 \$5.00 Expense 02/08/2024 Fees advanced to Logikcull INV157031 1-31-2024 \$250.00 Expense 02/22/2024 Fees advanced to Fiore Reporting Services LLC invoice 1427 2-7-2024 \$55.35 Expense 02/29/2024 PACER: Month of February \$10.70 Expense 02/29/2024 Copying: Month of February \$12.80

Invoice No. 27521 - 03/11/2024 Case 22-50073 Doc 3023 Filed 03/20/24 Entered 03/20/24 14:53:33 Page 11 of 11

Timothy Jensen 11.2 \$450.00 \$5,040.00

Michael McCormack 12.8 \$400.00 \$5,120.00 Melissa Gambardella 2.8 \$125.00 \$350.00

Invoice Number Due On Amount Due Payments Received Balance Due

27021 09/25/2023 \$99,873.56 \$80,469.56 \$19,404.00 27098 10/11/2023 \$35,374.76 \$28,534.76 \$6,840.00 27168 11/14/2023 \$24,998.95 \$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 \$5,338.84 \$1,239.50 27423 02/09/2024 \$11,978.91 \$0.00 \$11,978.91

Invoice Number Due On Amount Due Payments Received Balance Due

27521 03/11/2024 \$12,033.85 \$0.00 \$12,033.85

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

Payment is due upon receipt.