Guo Wengui / Miles Guo — bankruptcy case · ORDER · ECF #3178

# **UNITED STATES BANKRUPTCY COURT DISTRICT OF CONNECTICUT BRIDGEPORT DIVISION**

| ------------------------------------------------------ | x | | |--------------------------------------------------------|-------------|-------------------------| | In re: | :<br>: | Chapter 11 | | HO WAN KWOK, | :<br>:<br>: | Case No. 22-50073 (JAM) | | Debtor. | :<br>: | | | ------------------------------------------------------ | x | |

# **APPLICATION OF CHAPTER 11 TRUSTEE FOR ENTRY OF ORDER, PURSUANT TO BANKRUPTCY CODE SECTIONS 327, 328, AND 330, BANKRUPTCY RULES 2014 AND 2016, AND LOCAL BANKRUPTCY RULES 2014-1 AND 2016-1, EXPANDING RETENTION AND EMPLOYMENT OF HARNEY WESTWOOD AND RIEGELS LP TO ALSO SERVE AS CAYMAN ISLANDS COUNSEL TO CHAPTER 11 TRUSTEE**

Mr. Luc A. Despins, in his capacity as the Chapter 11 Trustee (the "Chapter 11 Trustee") appointed in the above-captioned chapter 11 case (the "Chapter 11 Case") of Ho Wan Kwok (the "Debtor"), hereby files this application (the "Application") requesting that the Court expand the Chapter 11 Trustee's employment of the law firm of Harney Westwood and Riegels LP ("Harneys") to also serve as Cayman Islands counsel to the Chapter 11 Trustee with respect to this chapter 11 case, effective as of April 10, 2024. In support of this Application, the Chapter 11 Trustee respectfully states as follows:

## **RELIEF REQUESTED**

1. By this Application, the Chapter 11 Trustee seeks entry of an order, substantially in the form attached hereto as **Exhibit A** (the "Proposed Order"), expanding the retention and employment of Harneys to also serve as Cayman Islands counsel to the Chapter 11 Trustee—in addition to serving as British Virgin Islands ("BVI") counsel (which retention the Court approved in January 2023).

2. In support of this Application, the Chapter 11 Trustee submits the *Declaration of Andrew Thorp in Support of Application of Chapter 11 Trustee for Entry of Order, Pursuant to Bankruptcy Code Sections 327, 328, and 330, Bankruptcy Rules 2014 and 2016, and Local Bankruptcy Rules 2014-1 and 2016-1, Expanding Retention and Employment of Harney Westwood and Riegels LP to Also Serve as Cayman Islands Counsel to Chapter 11 Trustee* (the "Thorp Declaration"), attached hereto as **Exhibit B**, which is incorporated herein by reference.

### **JURISDICTION, VENUE, AND STATUTORY BASIS**

3. 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 is a core proceeding within the meaning of 28 U.S.C. § 157(b).

4. Venue in this District is proper pursuant to 28 U.S.C. §§ 1408 and 1409.

5. The statutory basis for the relief requested in this Application are sections 327, 328, and 330 of Title 11 of the United States Code (the "Bankruptcy Code"), Rules 2014 and 2016 of the Federal Rules of Bankruptcy Procedure (the "Bankruptcy Rules"), and Rules 2014-1 and 2016-1 of the Local Rules of Bankruptcy Procedure (the "Local Bankruptcy Rules").

### **BACKGROUND**

6. On February 15, 2022 (the "Petition Date"), the Debtor filed with the Court a voluntary petition for relief under chapter 11 of the Bankruptcy Code.

7. On March 21, 2022, the United States Trustee appointed an Official Committee of Unsecured Creditors (the "Committee") in the Debtor's Chapter 11 Case.

8. On July 8, 2022, the Court entered an order [Docket No. 523] granting the appointment of Luc A. Despins as the Chapter 11 Trustee in the Chapter 11 Case.

9. On August 30, 2022, the Chapter 11 Trustee filed its application to retain Harneys as BVI counsel [Docket No. 807] (the "BVI Application"), effective as of July 31, 2022.

10. On September 2, 2022, the Chapter 11 Trustee filed the supplemental declaration of Andrew Thorp in support of the Application [Docket No. 815] (the "First Supplemental Declaration").

11. On September 13, 2022, the Chapter 11 Trustee filed the addendum to the BVI Application [Docket No. 855] to enter, on behalf of the Estate, into the director services agreement with Harneys Corporate Services Limited and Genever BVI.

12. On January 4, 2023, the Court issued its order granting the BVI Application [Docket No. 1286].

13. On April 6, 2023, the Chapter 11 Trustee filed the supplemental declaration of George Weston in support of the Application [Docket No. 1642] (the "Second Supplemental Declaration").

### **HARNEYS' QUALIFICATIONS**

14. Harneys is a global offshore law firm that maintains an office in, among other locations, the Cayman Islands. Harneys was founded in 1960 and has a widely diversified practice including dispute resolution, corporate and commercial law, private wealth, funds, banking and finance and regulatory and tax. Harneys' Cayman Islands office currently employs 30 attorneys, who are assisted by 2 paralegals.

15. The Chapter 11 Trustee selected Harneys as his Cayman Islands counsel because of Harneys' expertise in investigations, insolvency, restructuring, fraud, bankruptcy, corporate crimes and fraud, corporate and commercial litigation matters. Harneys has substantial resources and expertise in the areas of the law that may arise in this case. **Moreover, Harneys' BVI office**

**is already familiar with this chapter 11 case, as it has been assisting the Chapter 11 Trustee in his investigation into BVI entities since July 2022.** Accordingly, Harneys is ideally suited to also represent the Chapter 11 Trustee in connection with his investigation of Cayman Islands entities.

## **ANTICIPATED SERVICES**

16. The Chapter 11 Trustee anticipates that Harneys will render general legal services as Cayman Islands counsel, as needed throughout the course of the Chapter 11 Case, including investigations, bankruptcy, litigation, and other matters. Harneys will help the Trustee investigate several key entities under the control of the Debtor which are incorporated in the Cayman Islands, including in particular Hamilton Opportunity Fund SPC, a purported investment fund which the Trustee alleges is beneficially owned and controlled by the Debtor which has been used by the Debtor to, among other things, fund the purchase of the Debtor's mansion home located in Mahwah, New Jersey, and to control 95% of the equity of Gettr USA, Inc., operator of the social media platform, GETTR.

17. The Chapter 11 Trustee requests to employ Harneys to render general legal services as Cayman Island counsel with respect to this Chapter 11 Case.

18. To avoid any duplication of effort and to provide services to the Chapter 11 Trustee in the most efficient and cost-effective manner, Harneys will coordinate with Paul Hastings and NPM regarding their respective responsibilities in the Chapter 11 Case.

### **COMPENSATION OF PROFESSIONALS**

19. Harneys intends to apply to the Court for compensation for professional services rendered and for reimbursement of expenses incurred in connection with this Chapter 11 Case pursuant to sections 330 and 331 of the Bankruptcy Code, Bankruptcy Rule 2016, Local

Bankruptcy Rule 2016-1, and any other applicable rules and orders with respect to this Chapter 11 Case. Harneys will charge the Chapter 11 Trustee for its legal services on an hourly basis at its regularly applicable hourly rates for its Cayman Islands office in connection with the services required in this Chapter 11 Case.

20. At present, the 2024 hourly rates of Harneys Cayman Islands are \$320.00 for paralegal work; \$590.00 to \$1,015.00 for associates and counsel; and up to \$1,300.00 for partners of the firm. Harneys' hourly rates are subject to periodic adjustments to reflect economic and other conditions.1 It is anticipated that Harneys services will primarily be provided by Ben Hobden, whose hourly rate is \$1,300.00, Caitlin Murdock whose hourly rate is \$910.00 and Luke Fraser, whose hourly rate is \$910.00.

21. Harneys will also bill for out-of-pocket expenses made on behalf of the Chapter 11 Trustee, including photocopying, filing fees and international couriers, in accordance with practices in this District.

### **HARNEYS IS DISINTERESTED**

22. To the best of the Chapter 11 Trustee's knowledge in reliance upon the Thorp Declaration, and except as disclosed therein, Harneys does not have any relationships with the Debtor, its creditors, or any other party-in-interest, their respective attorneys and accountants, the United States Trustee, or any person employed in the Office of the United States Trustee.

¹ Harneys hourly rates are typically revised at the end of each calendar year to reflect experience, seniority, and standing. These step increases do not constitute "rate increases" (as the term is used in the Guidelines for Reviewing Applications for Compensation and Reimbursement of Expenses Filed Under 11 U.S.C. § 330 by Attorneys in Larger Chapter 11 Cases Effective as of November 1, 2013) (the "U.S. Trustee Guidelines"). As set forth in the Proposed Order, Harneys will provide ten business days' notice to the Debtor, the Assistant United States Trustee for the District of Connecticut (the "U.S. Trustee"), and counsel to the Committee and any other official committee, before implementing periodic increases, and shall file any such notice with the Court.

### **BASIS FOR RELIEF REQUESTED**

23. The Chapter 11 Trustee requests to expand the retention and employment of Harneys to also serve as his Cayman Islands counsel pursuant to section 327(a) of the Bankruptcy Code, which provides that a trustee, subject to the approval of the Court, may employ professional persons "that do not hold or represent an interest adverse to the estate, and that are disinterested persons, to represent or assist the trustee in carrying out the trustee's duties under this title."

24. 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).

25. Bankruptcy Rule 2014(a) provides that an application for retention include:

specific facts showing the necessity for the employment, the name of the [firm] to be employed, the reasons for the selection, the professional services to be rendered, any proposed arrangement for compensation, and, to the best of the applicant's knowledge, all of the [firm's] connections with the debtor, creditors, any other party in interest, their respective attorneys and accountants, the United States trustee.

26. The Chapter 11 Trustee requires the services of Cayman counsel to exercise his responsibilities. Cayman counsel will coordinate with and assist the Chapter 11 Trustee and its lead counsel, Paul Hastings and local counsel, Neubert, Pepe & Monteith, P.C., in investigating and/or seeking discovery of Cayman Islands entities affiliated with the Debtor. Harneys will endeavor to avoid the duplication of efforts and provide services as efficiently as possible. As the Court is aware, Harneys was previously retained to serve as the Chapter 11 Trustee's BVI counsel, and, by this Application, the Chapter 11 Trustee seeks to expand that retention to also encompass services in the Cayman Islands and/or related to Cayman Islands law.

27. Accordingly, the employment of Harneys as the Chapter 11 Trustee's Cayman Islands counsel, upon the terms set forth herein and in the Proposed Order, is reasonable and in the best interest of the Debtor's estate.

28. The Chapter 11 Trustee submits that Harneys' hourly rates are reasonable, comparable to Harneys' hourly rates for non-bankruptcy engagements, and within the range of rates charged by comparably skilled professionals who offer the same services.

29. Local Bankruptcy Rule 2014-1 provides that if "an application to employ a professional is filed within thirty (30) days after the commencement of services provided by that professional, the application shall be deemed contemporaneously filed unless the Court orders otherwise." Accordingly, the Chapter 11 Trustee requests authority to retain and employ Harneys effective April 10, 2022, which was the date that Harneys' Cayman Island attorneys began providing services to the Chapter 11 Trustee.

## **NOTICE**

30. Notice of this Application has been given to the United States Trustee, the Debtor, the Committee, and, by electronic filing utilizing the Court's electronic filing ("CM/ECF") system, to all appearing parties who utilize the CM/ECF system.

## **NO PRIOR REQUEST**

31. No previous application for the relief requested herein has been made to this or any other Court.

[*Remainder of page intentionally left blank.*]

WHEREFORE, for the foregoing reasons, Luc A. Despins, the Chapter 11 Trustee,

requests that the Court enter the Proposed Order, substantially in the form attached hereto are

**Exhibit A**, granting this Application and such other and further relief as the Court deems just and proper.

Dated: May 10, 2024 Chapter 11 Trustee for the Estate of Ho Wan Kwok

*/s/ Luc A. Despins* Luc A. Despins

Case 22-50073 Doc 3178 Filed 05/10/24 Entered 05/10/24 15:13:57 Page 9 of 41

# **EXHIBIT A**

**Proposed Order**

# **UNITED STATES BANKRUPTCY COURT DISTRICT OF CONNECTICUT BRIDGEPORT DIVISION**

| ------------------------------------------------------ | x | | |--------------------------------------------------------|--------|-------------------------| | In re: | :<br>: | Chapter 11 | | HO WAN KWOK, et al.,1 | :<br>: | Case No. 22-50073 (JAM) | | Debtors. | :<br>: | Jointly Administered | | ------------------------------------------------------ | :<br>x | |

# **[PROPOSED] ORDER GRANTING APPLICATION OF CHAPTER 11 TRUSTEE FOR ENTRY OF ORDER, PURSUANT TO BANKRUPTCY CODE SECTIONS 327, 328, AND 330, BANKRUPTCY RULES 2014 AND 2016, AND LOCAL BANKRUPTCY RULES 2014-1 AND 2016-1, EXPANDING RETENTION AND EMPLOYMENT OF HARNEY WESTWOOD AND RIEGELS LP TO ALSO SERVE AS CAYMAN ISLANDS COUNSEL TO CHAPTER 11 TRUSTEE**

Upon the application (the "Application")2 of Chapter 11 Trustee Luc A. Despins (the "Chapter 11 Trustee") in the above-captioned chapter 11 case (the "Chapter 11 Case") for authority to expand the retention and employment of Harney Westwood and Riegels LP ("Harneys") to also serve as Cayman Islands counsel to the Chapter 11 Trustee, effective as of April 10, 2024, pursuant to sections 327, 328, and 330 of title 11 of the United States Code (the "Bankruptcy Code"), Rules 2014 and 2016 of the Federal Rules of Bankruptcy Procedure (the "Bankruptcy Rules"), and Rules 2014-1 and 2016-1 of the Local Rules of Bankruptcy Procedure

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

² Capitalized terms used but not otherwise defined herein have the meanings set forth in the Application or the Thorp Declaration (as defined below).

for the United States Bankruptcy Court for the District of Connecticut (the "Local Bankruptcy Rules"), all as more fully set forth in the Application; and upon consideration of the Application, the Declaration of Andrew Thorp (the "Thorp Declaration") and the Prior Declarations; and this Court having jurisdiction to consider the Application and the relief requested therein in accordance with 28 U.S.C. §§ 157 and 1334 and the Standing Order of Reference from the United States District Court for the District of Connecticut; and consideration of the Application and the relief requested therein being a core proceeding pursuant to 28 U.S.C. § 157(b); and venue being proper in this Court pursuant to 28 U.S.C. §§ 1408 and 1409; and the Court having found that (i) the relief requested in the Application is in the best interest of the Debtor's estate, its creditors, and all parties-in-interest, (ii) the legal and factual bases set forth in the Application, the Thorp Declaration, the Prior Declarations and the record of the hearing on the Application before this Court on \_\_\_\_\_, 2024 establish just cause for the relief granted herein, (iii) Harneys is a "disinterested person," as defined in section 101(14) of the Bankruptcy Code and as required by section 327(a) of the Bankruptcy Code, and (iv) Harneys does not hold or represent an interest adverse to the Debtor's estate; and due and sufficient notice of the Application having been given under the particular circumstances; and it appearing that no other or further notice need be given; and upon all of the proceedings had before this Court; and after due deliberation and sufficient cause appearing therefor, it is hereby ORDERED THAT:

1. The Application is granted as set forth herein.

2. The Chapter 11 Trustee is authorized to retain and employ Harneys as his Cayman Islands counsel effective as of April 10, 2024 on the terms set forth in the Application, the Thorp Declaration, and Prior Declarations.

3. Harneys is authorized to act as the Trustee's Cayman Islands counsel and to perform those services described in the Application.

4. The Debtor's estate shall be responsible for Harneys' compensation and reimbursement of expenses in the Chapter 11 Case.

5. The allowance of any compensation to be paid to Harneys shall be determined in accordance with the procedures set forth in sections 330 and 331 of the Bankruptcy Code, Bankruptcy Rule 2016, and Local Bankruptcy Rule 2016-1.

6. Allowance of any compensation for Harneys shall be limited to the extent of services actually performed, and expenses actually incurred, as attorney for the Debtor, and shall not include compensation for the performance of any of the trustee duties that are generally performed by a Chapter 11 trustee without the assistance of an attorney.

7. Harneys shall provide no less than ten business days' notice to the Debtor, the United States Trustee, and counsel to any official committee before any increases in the rates it charges are implemented and shall file such notice with the Court.

8. The Trustee and Harneys are authorized and empowered to take all actions necessary to effectuate the relief granted in this Order.

9. The requirements of the Local Bankruptcy Rules are satisfied by the contents of the Application.

10. To the extent the Application and the Thorp Declaration are inconsistent with this Order, the terms of this Order shall govern.

11. The terms and conditions of this Order shall be immediately effective and enforceable upon its entry.

12. This Court shall retain jurisdiction with respect to all matters arising from or

related to the implementation, interpretation, and enforcement of this Order.

Case 22-50073 Doc 3178 Filed 05/10/24 Entered 05/10/24 15:13:57 Page 14 of 41

## **EXHIBIT B**

**Thorp Declaration**

# **UNITED STATES BANKRUPTCY COURT DISTRICT OF CONNECTICUT BRIDGEPORT DIVISION**

| ------------------------------------------------------ | x | | |--------------------------------------------------------|-------------|-------------------------| | In re: | :<br>: | Chapter 11 | | HO WAN KWOK, et al.,1 | :<br>: | Case No. 22-50073 (JAM) | | Debtors. | :<br>:<br>: | Jointly Administered | | ------------------------------------------------------ | x | |

# **DECLARATION OF ANDREW THORP IN SUPPORT OF APPLICATION OF CHAPTER 11 TRUSTEE FOR ENTRY OF ORDER, PURSUANT TO BANKRUPTCY CODE SECTIONS 327, 328, AND 330, BANKRUPTCY RULES 2014 AND 2016, AND LOCAL BANKRUPTCY RULES 2014-1 AND 2016-1, EXPANDING RETENTION AND EMPLOYMENT OF HARNEY WESTWOOD AND RIEGELS LP TO ALSO SERVE AS CAYMAN ISLANDS COUNSEL TO CHAPTER 11 TRUSTEE**

I, Andrew Thorp, being duly sworn, do depose and say:

1. I submit this declaration (the "Declaration") to supplement (a) the declaration submitted to the Court on August 31, 2022 [Docket No. 807-2] (the "Initial Declaration"),2 (b) the declaration submitted to the Court on September 2, 2022 [Docket No. 815] (the "First Supplemental Declaration"), (c) the declaration of George Weston submitted to the Court on December 16, 2022 [Docket No. 1247-1] (the "Weston Declaration"), and (d) and the declaration of George Weston submitted to the Court on April 6, 2023 [Docket No. 1642] (the "Second Supplemental Declaration" and, together with the Initial Declaration, the First Supplemental

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 defined herein shall have the meanings ascribed to them in the Initial Declaration or in the Application (as defined below).

Declaration, and the Weston Declaration, the "Prior Declarations"), in further support of the Chapter 11 Trustee's application to expand the retention and employment of Harney Westwood and Riegels LP ("Harneys") to also serve as Cayman Islands counsel to the Chapter 11 Trustee (the "Application"). I hereby supplement the Prior Declarations as follows:

2. Harneys is a global offshore law firm that maintains an office in the Cayman Islands. Harneys was founded in 1960 and has a widely diversified practice including dispute resolution, corporate and commercial law, private wealth, funds, banking and finance and regulatory and tax. The Cayman Islands office currently employs 30 attorneys, who are assisted by 2 paralegals.

3. Harneys has expertise in investigations, insolvency, restructuring, fraud, bankruptcy, corporate crimes and fraud, corporate and commercial litigation matters. Harneys is well suited for the type of representation required by the Chapter 11 Trustee. Harneys has substantial resources and expertise in the areas of the law that may arise in this case.

4. Harneys will render general legal services as Cayman Islands counsel, as needed throughout the course of the Chapter 11 Case, including investigations, bankruptcy, litigation, and other matters. Harneys will help the Trustee investigate several key entities under the control of the Debtor which are incorporated in the Cayman Island, including in particular Hamilton Opportunity Fund SPC, a purported investment fund which the Trustee alleges is beneficially owned and controlled by the Debtor which has been used by the Debtor to, among other things, fund the purchase of the Debtor's mansion home located in Mahwah, New Jersey, and to control 95% of the equity of Gettr USA, Inc., operator of the social media platform, GETTR.

5. Harneys will render general legal services as Cayman Island counsel with respect to this Chapter 11 Case.

6. Harneys has experience with liaising and working cooperatively with overseas lead counsel by assisting with compliance with Cayman Island rules and procedures, attending to routine and administrative matters as they arise, and otherwise providing services as may be required by lead counsel and in the best interests of its clients, all in a manner that promotes efficiency and avoids any unnecessary duplication of efforts by counsel.

7. Harneys intends to apply to the Court for compensation for professional services rendered and for reimbursement of expenses incurred in connection with this Chapter 11 Case pursuant to sections 330 and 331 of the Bankruptcy Code, Bankruptcy Rule 2016, Local Bankruptcy Rule 2016-1, and any other applicable rules and orders with respect to this Chapter 11 Case. Harneys will charge the Chapter 11 Trustee for its legal services on an hourly basis at its regularly applicable hourly rates for its Cayman Islands office in connection with the services required in this Chapter 11 Case.

8. At present, the 2024 hourly rates of Harneys Cayman Islands are \$320.00 for paralegal work; \$590.00 to \$1,015.00 for associates and counsel; and up to \$1,300.00 for partners of the firm. Harneys' hourly rates are subject to periodic adjustments to reflect economic and other conditions.3 It is anticipated that Harneys services will primarily be

³ Harneys hourly rates are typically revised at the end of each calendar year to reflect experience, seniority, and standing. These step increases do not constitute "rate increases" (as the term is used in the Guidelines for Reviewing Applications for Compensation and Reimbursement of Expenses Filed Under 11 U.S.C. § 330 by Attorneys in Larger Chapter 11 Cases Effective as of November 1, 2013) (the "U.S. Trustee Guidelines"). As set forth in the Proposed Order, Harneys will provide ten business days' notice to the Debtor, the Assistant United States Trustee for the District of Connecticut (the "U.S. Trustee"), and counsel to the Committee and any other official committee, before implementing periodic increases, and shall file any such notice with the Court.

provided by Ben Hobden, whose hourly rate is \$1,300.00, Luke Fraser whose hourly rate is \$910.00 and Caitlin Murdock, whose hourly rate is \$910.00.

9. Harneys will also bill for out-of-pocket expenses made on behalf of the Chapter 11 Trustee, including photocopying, filing fees and international couriers, in accordance with practices in this District.

10. Subsequent to Harneys' appointment as BVI counsel and proposed retention as Cayman Islands counsel, and upon review of the updated schedule of parties in interest (the "Interested Parties"), a copy of which is attached hereto as **Schedule 1**, I had Harneys conflicts team perform additional conflicts checks on all Interested Parties. Based on the results of the additional conflicts checks, I believe neither Harneys nor any of its attorneys, including me, has any connections (as that term is used in Bankruptcy Rule 2014), with any of the Interested Parties, except as previously disclosed in the Prior Declarations and except as follows:

> a. A number of Interested Parties are banks, financial institutions, and large corporations, namely, Amazon Web Services LLC, Amazon Web Services, Inc., American Express Company, Bank of Montreal, BSI Group LLC, Canadian Imperial Bank of Commerce, Capital One, NA, Charles Schwab, City National Bank, Deltec Bank & Trust Limited, East West Bank, Federal Express Corporation, Meta Platforms Inc., PNC Bank, U.S. Bank National Association, and Wells Fargo Bank, N.A. (the "Additional Financial Institutions and Corporations"). Harneys currently represents or in the past represented the Additional Financial Institutions and Corporations in matters which, as far as I am aware after reasonable inquiry, are unrelated to the Debtor;

- b. A number of Interested Parties are law firms, namely, Christodoulos G. Vassiliades & Co. LLC, Forbes Hare LLP, Ogier, Paul Weiss Rifkind Wharton & Garrison LLP, and Stroock & Stroock & Lavan LLP (the "Additional Law Firms"). Harneys currently represents or in the past represented the Additional Law Firms in matters which, as far as I am aware after reasonable inquiry, are unrelated to the Debtor; - c. Harneys represents an individual named Andrew Childe in matters which, as far as I am aware after reasonable inquiry, are unrelated to the Debtor; and - d. Harneys represents the fiduciary service firm FFP (BVI) Limited in matters which, as far as I am aware after reasonable inquiry, are unrelated to the Debtor.⁴

11. I declare under penalty of perjury under 28 U.S.C. § 1746 that the foregoing is true and correct.

Dated: May 10, 2024, at Tortola, British Virgin Islands

Andrew Thorp

⁴ In addition to the foregoing disclosures, I am aware that Harneys previously represented a Wei Zhang, who shares a name with an Interested Party. I was unable to verify that it was not the same individual, but in any event the matter closed approximately three years ago and was unrelated to the Debtor.

### **SCHEDULE 1**

## **SCHEDULE OF PARTIES IN INTEREST – IN RE KWOK**

#### **20 LARGEST UNSECURED CREDITORS**

PACIFIC ALLIANCE ASIA OPPORTUNITY GOLDEN SPRING NEW YORK RUI MA CHENG JIAN WU JIAN SHE NING YE GUO BAOSHENG YAN LAN & WU ZHENG HONG QI QU NAN TONG SI JIAN JIAN GONG YAN ZHAO YUA HUA ZHUANG SHI LIEHONG ZHUANG/XIAO YAN ZHU WEICAN MENG/BOXUN INC. SAMUEL NUNBERG LAMP CAPITAL LLC JUN CHEN AKA JONATHAN HO YUE HUA ZHU SHI XIONG XIAN WEI YE HUIZEN WANG

#### **DEBTOR, FAMILY MEMBERS, AND CERTAIN RELATED ENTITIES**

HO WAN KWOK (A.K.A MILES GWOK, MILES GUO AND WENGUI GUO) HING CH NGOK/YUE QINGZHI QIANG GUO (A.K.A. MILESON GUO) MEI GUO/MEI GUI HK INTERNATIONAL FUNDS INVESTMENTS (USA) LIMITED, LLC BRAVO LUCK LIMITED GENEVER HOLDINGS CORPORATION GENEVER HOLDINGS LLC

#### **BANKRUPTCY JUDGE AND U.S. TRUSTEE PERSONNEL**

HONORABLE JULIE A. MANNING WILLIAM HARRINGTON KIM L. MCCABE HOLLEY CLAIBORN JOSEPH H. FLAMINI ERIN HOGAN STEVEN MACKEY FRANK MARINO JENNIFER J. MOREY NICOLE NEELY SHARON WARNER JOHN GERVAIS

#### **OTHER INTERESTED PARTIES**

1245 FACTORY PLACE, LLC 12476517 CANADA SOCIETY 1322089 B.C. LTD. 1332156 B.C. LTD 17 MILES, LLC 2 B PACKING LLC 270 W. 39TH ST. CO., LLC 2LAWRENCE RIVER 3 COLUMBUS CIRCLE LLC 5780 SAGUARO LLC 7 NOD HILL LLC, 7 STAR EAST NY LLC 9 EAST 40TH STREET LLC A.Z. BIGIOTTERIE S.A.S. DI ZANUTTO GABRIELE & C. AAGV LIMITED AARON A. MITCHELL AARON A. ROMNEY ABRAMS FENSTERMAN, LLP ACA CAPITAL GROUP LIMITED ACA CAPITAL LIMITED ACA INVESTMENT FUND ACA INVESTMENT MANAGEMENT LTD. ACASS CANADA LTD. ACE DECADE HOLDINGS LIMITED ADAM CHEN NI AFFILIATED ADJUSTMENT GROUP, LTD. AGORA LAB, INC. AI GROUP HOLDINGS INC., AIG PROPERTY CASUALTY COMPANY AKERMAN LLP ALEX HADJICHARALAMBOUS ALFA GLOBAL VENTURES LIMITED ALFONSO GLOBAL LIMITED ALFONSO GLOBAL VENTURES LIMITED ALLIED CAPITAL GLOBAL LIMITED ALPINE FIDUCIARIES SA AMAZING SKY AVIATION LIMITED AMAZON WEB SERVICES LLC AMAZON WEB SERVICES, INC. AMAZON.COM INC. AMERICAN ARBITRATION ASSOCIATION, INC. AMERICAN EXPRESS COMPANY AMY BUCK AN HONG ANA C. IZQUIERDO-HENN ANDREW CHILDE ANDREW SULNER/FORENSIC DOCUMENT EXAMINATIONS, LLC ANN MARIE LEE ANTHEM HEALTH PLANS, INC. ANTHONY DIBATTISTA ANTON DEVELOPMENT LIMITED APPLE INC. APPSFLYER INC APSLEY YACHTS LIMITED

ARETHUSA FORSYTH ARI CASPER ARRI AMERICAS INC. ART WOLFE, INC. ASAP SRL ASSETS SINO LIMITED AUSPICIOUS COAST LIMITED AVIATION E LLP AVIATION TRUST COMPANY LLC AXOS BANK AXOS FINANCIAL, INC. B&H FOTO & ELECTRONICS CORP. BAC CAPITAL LLC BAIQIAO TANG A/K/A TANG BAIQIAO BAKER HOSTETLER LLP BANCO POPULAR DE PUERTORICO BANK OF AMERICA BANK OF CHINA – NEW YORK BRANCH AND/OR BANK OF CHINA LIMITED BANK OF MONTREAL BANK OF THE WEST BANNON STRATEGIC ADVISORS, INC. BARCLAY DAMON LLP BARCLAYS BANK PLC BEIJING BI HAI GE LIN YUAN LIN LU HUA, LTD. BEIJING CHENG JIAN WU JIAN SHE GROUP, LTD. BEIJING FU LE HONG MA JIAN ZHU ZHUANG SHI GONG CHENG, LTD. BEIJING PANGU INVESTMENT CO. BEIJING ZENITH HOLDINGS CO. BEIJING ZHONG XIAN WEI YE STAINLESS DECORATION CENTER BEILE LI BELLERIVE ATTORNEYS AT LAW BENHAR OFFICE INTERIORS LLC BENTO TECHNOLOGIES, INC. BERING YACHTS, LLC BERKELEY ROWE LIMITED BERNARDO ENRIQUEZ BESTVIEW1 PTY LTD BINGNAN CUI BINGSHANG JIAO BLACKTHORN FINANCEN INC. BLUE CAPITAL BLUEBERRY BUILDERS, LLC BNY MELLON, N.A. BOARDWALK MOTOR IMPORTS, LLC BOHONNON LAW FIRM BOIES SCHILLER BONNIE C. MANGAN BOOMING SAIL NEW YORK LLC BOXUN INC. BRANCH BRAVO LUCK LIMITED BRENT PETRO INC. BRIAN HOFMEISTER BROWN HARRIS STEVENS BROWN RUDNICK, LLP BRUNE LAW PC

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