Guo Wengui / Miles Guo — bankruptcy case · ORDER · ECF #3193

METADATA

Defendant: Guo Wengui / Miles Guo / Ho Wan Kwok
Court: CTB
Case No.: 22-50073
ECF #: 3193
Type: ORDER
Filed: 2024-05-16

FULL TEXT

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

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

# **FIFTEENTH SUPPLEMENTAL OMNIBUS MOTION OF CHAPTER 11 TRUSTEE FOR ENTRY OF ORDER UNDER BANKRUPTCY RULE 2004 AND LOCAL RULE 2004-1 AUTHORIZING DISCOVERY WITH RESPECT TO ADDITIONAL INDIVIDUALS AFFILIATED WITH THE DEBTOR, RELEVANT BANKS AND ENTITIES THAT DEAL IN AUTOMOBILES**

Luc A. Despins, in his capacity as the Chapter 11 Trustee (the "Trustee") appointed in the above-captioned chapter 11 case (the "Case") of Ho Wan Kwok (the "Debtor"), by and through his undersigned counsel, pursuant to Federal Rule of Bankruptcy Procedure 2004(a) (the "Bankruptcy Rules") and Local Bankruptcy Rule 2004-1 (the "Local Rules"), hereby applies (the "Application" or "Motion") to conduct the examination2 of certain banks and financial institutions, entities that deal in automobiles, and individuals associated with the Debtor and his alter ego shell companies (the "Examinees") which the Trustee believes the Debtor and Related Persons

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 By this Motion, the Trustee seeks the authority to conduct his examination of the Examinees by serving subpoenas which call for both document production and deposition testimony. For the avoidance of doubt, the Trustee will not conduct depositions of the Examinees within the stay period pursuant to the *Order Staying Adversary Proceedings and Granting Other Related Relief Pending Disposition of Criminal Proceeding* [ECF No. 3038] without advance permission from the Court.

conducted business relevant to the estate of the Debtor, as such Examinees are identified in **Exhibit B**, attached hereto. **Please take notice that the deadline to object to this Application is May 23, 2024, and in the absence of a timely filed objection, the proposed order filed herewith as Exhibit A (the "Proposed Order") may enter without further notice and hearing**. In support of his Application, the Trustee respectfully states as follows:

## **PRELIMINARY STATEMENT**

1. The Trustee, in furtherance of his duties and responsibilities under the order authorizing the appointment of a chapter 11 trustee dated July 6, 2022, (*See* ECF. No. 465, at 14, hereinafter referred to as the "Trustee Order"), continues his investigation into the Debtor's financial and business affairs to determine whether additional estate assets exist and to recover upon those assets for the benefit of the Debtor's estate.

2. The Trustee's investigation has identified more entities with possible knowledge of the Debtor's assets and financial activities, and the Trustee seeks to further his investigation through additional Bankruptcy Rule 2004 discovery of these Examinees.

3. The Trustee believes that the Examinees have access to and understandings of information relating to the Debtor's assets, financial affairs, and potential financial interests in various corporate entities related to the Debtor, his family, or his associates, including, without limitation, entities that are the Debtor's alter egos.

4. The Trustee has submitted multiple Bankruptcy Rule 2004 motions granted by the Court, including one directed at legal and financial firms believed to have advised the Debtor and related entities and individuals (ECF No. 637, the "Advisors 2004 Motion"), one directed at entities and individuals believed to be affiliated with, controlled by, or otherwise connected to the Debtor (the "Affiliates 2004 Motion"), the Trustee's First Supplemental Omnibus Motion dated

September 7, 2022 (the "First Omnibus Motion"), the Trustee's Second Supplemental Omnibus Motion dated November 18, 2022 (the "Second Omnibus Motion"), the Trustee's Third Supplemental Omnibus Motion dated December 21, 2022 (the "Third Omnibus Motion,"), the Trustee's Fourth Supplemental Omnibus Motion dated March 24, 2023 (the "Fourth Omnibus Motion"), the Trustee's Fifth Supplemental Omnibus Motion dated May 15, 2023 (the "Fifth Omnibus Motion"), the Trustee's Sixth Supplemental Omnibus Motion dated August 11, 2023 (the "Sixth Omnibus Motion,"), the Trustee's Seventh Supplemental Omnibus Motion dated October 10, 2023 (the "Seventh Omnibus Motion"), the Trustee's Eighth Supplemental Omnibus Motion dated November 2, 2023 (the "Eighth Omnibus Motion"), the Trustee's Ninth Supplemental Omnibus Motion dated November 6, 2023 (the "Ninth Omnibus Motion"), the Trustee's Tenth Supplemental Omnibus Motion dated December 14, 2023 (the "Tenth Omnibus Motion"), the Trustee's Eleventh Supplemental Omnibus Motion dated January 16, 2024 (the "Eleventh Omnibus Motion"), the Trustee's Twelfth Supplemental Omnibus Motion dated January 30, 2024 (the "Twelfth Omnibus Motion"), the Trustee's Thirteenth Supplemental Omnibus Motion dated March 21, 2024 (the "Thirteenth Omnibus Motion") and the Trustee's Fourteenth Supplemental Omnibus Motion dated March 25, 2024 (the "Fourteenth Omnibus Motion," together with the Advisors 2004 Motion, the Affiliates 2004 Motion, the First Omnibus Motion, the Second Omnibus Motion, the Third Omnibus Motion, the Fourth Omnibus Motion, the Fifth Omnibus Motion, and the Sixth Omnibus Motion, the Seventh Omnibus Motion, the Eighth Omnibus Motion, the Ninth Omnibus Motion, the Tenth Omnibus Motion, the Eleventh Omnibus Motion, the Twelfth Omnibus Motion, and the Thirteenth Omnibus Motion, collectively, the "2004 Motions"). The discovery requested herein will supplement and augment inquiries the Trustee has already begun, as well as open additional avenues of investigation and potential discovery of assets.

5. In the interest of brevity, the Trustee incorporates the 2004 Motions herein by reference and makes them a part hereof. All capitalized terms not defined herein shall have the meanings ascribed to them in the 2004 Motions.

## **JURISDICTION AND VENUE**

6. The Court has jurisdiction to entertain this application under 28 U.S.C. §§ 157 and 1334. Venue to hear this Application is proper in accordance with 28 U.S.C. §§ 1408 and 1409.

7. This Application is a core proceeding pursuant to, *inter alia*, 28 U.S.C. § 157(b)(2) (A), (E), and (F).

## **THE EXAMINEES**

8. The Examinees are banks and financial institutions, entities that deal in automobiles, and certain individuals associated with the Debtor and his alter ego shell companies, not included in the prior 2004 Motions, which Examinees may have material information concerning the Debtor's assets and financial condition.

9. The Trustee has ascertained that the Debtor, along with entities and individuals linked to the Debtor, may have conducted banking or other business at or with the bank/financial institution Examinees. More specifically, these are: **China CITIC Bank International; Intesa Sanpaolo SpA; Lloyds Bank PLC; PayrNet Limited; Revolut Ltd.; and CIMB Bank Berhad a/k/a CIMB Islamic Bank Berhad**. The Trustee understands that at least one Debtor-associated individual or entity has maintained one or more account(s) at each of these Examinees and/or that such Examinees have assisted with or facilitated transfers between other Debtor-related accounts held at previously identified financial institutions.

10. The Trustee has identified certain entities that are in the business of selling automobiles with which at least one Debtor-associated individual or entity has transacted business. It has been the Debtor's practice to purchase motor vehicles through shell companies and individuals associated with the Debtor. Thus, the Trustee reasonably believes these entities may have documents or information relating to the Debtor and his financial affairs which will aid the Trustee in his investigations. Specifically, these entities are as follows: **H.R. Owen PLC; Headwater Service, LLC; and RM Sotheby's and/or RM Auctions 2022**.

11. The Trustee also seeks to undertake Rule 2004 discovery from certain individuals who the Trustee understands were directly involved in the Debtor's financial affairs. The Trustee believes these Examinees may possess information and documents related to the Debtor's commercial activities and other conduct concerning assets, liabilities, or financial interests potentially relevant to the administration of the Debtor's estate and may hold assets of the Debtor:

(a) **Evan Cramer** is an individual believed to be associated with the Debtor and Yvette Wang, who operated as the Debtor's "chief of staff" ("Ms. Wang"), and the Trustee understands that Mr. Cramer received at least one (1) significant transfer from Ms. Wang in the years leading to the Debtor's bankruptcy filing. Ms. Wang recently pleaded guilty to criminal charges arising from her involvement in the Debtor's fraud schemes. Therefore, Mr. Cramer may have information, documents, and records relating to the Debtor and his business and financial affairs and transactions, which will aid the Trustee in his investigations.

(b) The Trustee has identified additional individuals who were involved with the Debtor's alter egos and who received transfers of funds from the Debtor via his alter egos. The Trustee believes these individuals may have knowledge about the Debtor's

assets and financial affairs. These individuals, and the alter egos with which they were associated, are as follows:

- i. **Makaya Randall**: HCHK Property Management, Inc., HCHK Technologies, Lexington Property & Staffing Inc., and GTV Media Group, Inc.; - ii. **Richard Leahy**: HCHK Property Management, Inc.; - iii. **Thomas Guarino (aka Thomas Guarino II)**: HCHK Property Management, Inc., Golden Spring NY, GS Security Solutions Inc., and Lamp Capital LLC; - iv. **Lukasz Lasota**: HCHK Property Management, Inc.; - v. **Thomas McHale**: HCHK Property Management, Inc., Golden Spring NY, GS Security Solutions Inc., and Lamp Capital LLC; - vi. **Sean Lynch**: HCHK Property Management, Inc. and Lamp Capital LLC; - vii. **Eddy Aquino (aka Eddy I Sanchez Aquino)**: G Club Operations, LLC; - viii. **Summer L. Bridges**: G Fashion; - ix. **Michael Baranowitz**: Rule of Law Foundation III, Inc. and Rule of Law Society IV, Inc.; - x. **Maya Fawaz**: Lexington Property & Staffing Inc. and GTV Media Group Inc.; - xi. **Andrea Volpe**: GFNY, Inc. and HCHK Technologies; and - xii. **Dean M**. **Rabideau**: Golden Spring NY.

## **RELIEF REQUESTED**

12. The Trustee seeks entry of an order, in substantially the form of the Proposed Order, pursuant to Bankruptcy Rule 2004(a) and Local Rule 2004-1, authorizing the Trustee to conduct the examination of the Examinees included on **Exhibit B**.

## **BASIS FOR RELIEF REQUESTED**

13. Pursuant to Rule 2004(a), on application of a party in interest, the Court may order the examination of any person or entity. The scope of an examination authorized under Rule 2004 is exceedingly broad and may relate to the "acts, conduct, or property or to the liabilities and financial condition of the debtor, or to any matter which may affect the administration of the debtor's estate." Fed. R. Bankr. P. 2004(b).

14. "The purpose of a Rule 2004 examination is to assist a party in interest in determining the nature and extent of the bankruptcy estate, revealing assets, examining transactions and assessing whether wrongdoing has occurred." *In re Transmar Commodity Group Ltd.*, 2018 WL 4006324, at \*4 (Bankr. S.D.N.Y. Aug. 17, 2018) (internal quotation and citation omitted). This includes revealing the nature and extent of the estate and in discovering assets of the debtor that may have been intentionally or unintentionally concealed. *See In re Bennett Funding Group, Inc.*, 203 B.R. 24, 27-28 (Bankr. N.D.N.Y. 1996). *See also In re Millennium Lab Holdings II, LLC*, 562 B.R. 614, 626 (Bankr. D. Del. 2016) ("Legitimate goals of Rule 2004 examinations include discovering assets, examining transactions, and determining whether wrongdoing has occurred." (internal quotation and citation omitted)).

15. In the declaration he submitted on March 20, 2022 in support of the filing of this case, the Debtor represented that among the purposes for filing his chapter 11 case were "to … (b) afford stakeholders an efficient opportunity to investigate [his] assets, liabilities, and financial

affairs, given what [he] perceive[d] to be misunderstandings in that regard; [and] (c) establish what assets are estate property and, in turn, available for distribution to holders of allowed claims . . . ." (Debtor's Declaration, ¶3). The investigation the Trustee seeks to perform is directly relevant to these stated purposes in that it will help the Trustee identify the Debtor's assets and liabilities in order to make distributions to creditors.

16. The areas for inquiry herein are part of the Trustee's ongoing investigative efforts. As the investigation evolves, new avenues of inquiry become apparent and the need for additional discovery of persons, entities and areas of inquiry arises. Based on all the facts and evidence discussed above and as contained in the 2004 Motions, the Trustee seeks the investigative tools afforded by Rule 2004 to further establish the true ownership of assets and to explore other potential assets about which the Trustee does not yet have knowledge.

17. The Trustee requests that, in furtherance of his examinations, the Court direct the Examinees to provide documentation to the Trustee's counsel, as requested in the forms annexed hereto3 and made a part hereof (the "Proposed Subpoenas"), within fourteen (14) days of the service of a subpoena, substantially similar in form and substance to the Proposed Subpoenas, or such other time as agreed upon by the Trustee. These requests seek documents consisting of, among other things, the Examinees' communications with the Debtor regarding his financial condition, asset transfers, and corporate governance issues. The requests also seek the Examinees' internal files and correspondence on these same topics.

3 Included in Exhibit B is an index of Proposed Subpoenas that would be served on the Examinees if this Motion is granted. The Trustee also attaches hereto as **Exhibits C-1 to C-22** the individualized Proposed Subpoenas, including the topics for discovery directed to each Examinee, which are substantially similar in form and substance.

18. The type of discovery that the Trustee will obtain from Examinees is well within the scope of Bankruptcy Rule 2004. Bankruptcy courts routinely provide for Rule 2004 discovery against professional firms when the discovery may identify and aid the recovery of assets for the benefit of the estate and creditors. *See, e.g., In re Bame,* 251 B.R. 367 (Bankr. D. Minn. 2000); *In re Horvath*, No. 13-34137, 2015 WL 2195060 (Bankr. N.D. Ohio May 7, 2015) (approving discovery related to claims on schedule of assets permissible from individual debtor where obtaining such discovery might increase the value of the debtor's estate).

19. The Trustee submits that the facts set forth above constitute sufficient cause for the Court to order the production of documents pursuant to Bankruptcy Rule 2004 from the Examinees. Particularly considering the pattern of obstruction by the Debtor and certain of his family members and associates, seeking discovery from other parties, including the Examinees, is an essential investigative tool in identifying and recovering estate property. Indeed, documents in the possession of third parties like the Examinees have been among the most useful of those obtained in the Trustee's investigation to date.4

20. Authorization of this Application is critical for the Trustee to fulfill the duties contemplated in the Trustee Order effectively, including specifically his mandate to "locate the Debtor's assets for the benefit of creditors and the estate" and "investigate the Debtor's assets, liabilities, and financial affairs." (*See* Trustee Order at 15-16, 18).

21. No party in interest, including the Debtor, shall suffer undue prejudice upon the granting of the relief sought in this Application.

4 The Trustee also requests authority to serve the Proposed Subpoenas on affiliates or subsidiaries of the Examinees if in the course of the Trustee's investigation it is determined that such affiliates and subsidiaries of the Examinees are the parties in control of documents relating to the Examinees that are relevant to the Trustee's investigation.

## **NO PRIOR REQUEST**

22. No prior application for the relief requested herein has been made. The Trustee filed the prior 2004 Motions however, those prior motions did not request to take discovery from the Examinees at issue here.

## **OBJECTION DEADLINE**

23. The deadline to object to this Application is May 23, 2024, and in the absence of a timely filed objection, the Proposed Order may enter without further notice and hearing.

WHEREFORE, the Trustee respectfully requests that the Court grant this Application and enter the Proposed Order, pursuant to Fed. R. Bankr. P. 2004(a), directing the examination of the Examinees, and directing the production of certain documents as set forth in the Requests for Production of Documents attached to the Proposed Subpoenas, and for such other and further relief as the Court may deem just and proper.

WHEREFORE, the Court should grant this Motion and grant such other relief as is just and proper.

Dated: May 16, 2024 LUC A. DESPINS,

New Haven, Connecticut CHAPTER 11 TRUSTEE

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

*Counsel for the Chapter 11 Trustee*

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

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

## **NOTICE OF OBJECTION DEADLINE**

Luc Despins, as the appointed Chapter 11 Trustee to the Debtor's Estate (the "Applicant"), has filed an Application for Rule 2004 Examination of certain corporate entities, individuals, and banking and financial institutions identified in **Exhibit B** (the "Rule 2004 Examination") with the U.S. Bankruptcy Court for the District of Connecticut. Notice is hereby given that any objection or response to the Rule 2004 Examination must be filed with the Court no later than May 23, 2024, in accordance with Fed. R. Bankr. P. 2002(a) and 9014 and Local Bankr. R. 2004-1(c). In the absence of a timely filed objection, the proposed order regarding the Rule 2004 Examination may enter without further notice and hearing, see 11 U.S.C. section 102(1).

## [*REMAINDER OF THIS PAGE IS INTENTIONALLY LEFT BLANK*.]

Dated: May 16, 2024 LUC A. DESPINS, New Haven, Connecticut CHAPTER 11 TRUSTEE

By: */s/ Patrick R. Linsey*

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

*Counsel for the Chapter 11 Trustee*

# **Exhibit A**

**Proposed Order**

| Case 22-50073 | Doc 3193 | Filed 05/16/24 | Entered 05/16/24 10:28:21 | Page 14 of | |---------------|----------|----------------|---------------------------|------------| | | | 439 | | |

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

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

# **[PROPOSED] ORDER GRANTING FIFTEENTH SUPPLEMENTAL OMNIBUS MOTION OF CHAPTER 11 TRUSTEE FOR ENTRY OF ORDER UNDER BANKRUPTCY RULE 2004 AND LOCAL RULE 2004-1 AUTHORIZING DISCOVERY WITH RESPECT TO ADDITIONAL INDIVIDUALS, RELEVANT BANKS, AND ENTITIES THAT DEAL IN AUTOMOBILES**

Upon consideration of the Application seeking an order authorizing a Federal Rule of Bankruptcy Procedure 2004 examination of the Examinees listed on Exhibit B thereto (the "Application", ECF No. \_\_\_\_), filed by Luc Despins, as the appointed Chapter 11 Trustee to the Debtor's estate (the "Applicant"), after notice and a hearing, see 11 U.S.C. § 102(1), it appearing that cause exists to grant the requested relief as conditioned hereafter; it is hereby

**ORDERED**: The Rule 2004 Motion is granted as set forth below.

**ORDERED**: Neubert, Pepe & Monteith, P.C., as counsel for the Trustee, is hereby authorized to sign Subpoenas in a form substantially similar to the Subpoenas attached to the Rule 2004 Motion as Exhibits C-1 to C-22 and to serve the Subpoenas, along with a copy of this Order, in accordance with Bankruptcy Rule 2004 requiring examination and the production of documents by the Examinees listed on Exhibit B to the Application.

**ORDERED**: Subject to any rights under the Federal Rules of Bankruptcy Procedure, the Federal Rules of Civil Procedure, and applicable Local Rules, and unless otherwise ordered by the Court, the Examinees are hereby directed to produce all documents within 14 days of the service of the Subpoena, or such other time as agreed upon by the Trustee. To the extent an Examinee

Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 15 of 439

does not produce any documents requested in the Subpoena on the basis of some privilege, the Examinee is hereby directed to produce to the Trustee a privilege log that comports with Fed. R. Civ. P. 45(e)(2), made applicable by Fed. R. Bankr. P. 9016, and D. Conn. L. Civ. R. 26(e), within 14 days of service of the Subpoena, or such other time as agreed upon by the Trustee.

**ORDERED**: The Examinees are hereby directed to ensure that all documents and other information, including without limitation in any electronic format, requested in the Subpoenas or otherwise relevant to the Debtor, his business, assets, liabilities, financial condition, or this Chapter 11 case, are properly maintained, are available for production, inspection and copying, and are not destroyed.

**ORDERED**: Neubert, Pepe & Monteith, P.C., as counsel for the Trustee, is hereby authorized, without further order of this Court, to take the testimony of one or more representatives of any Examinee listed on Exhibit B to the Application by examination under Bankruptcy Rule 2004 either at the offices of Neubert, Pepe & Monteith, 195 Church Street, 13th Floor, New Haven, CT 06510, at the offices of Paul Hastings LLP, 200 Park Avenue, New York, NY 10166, or at such other place that is mutually acceptable to the parties, on a date acceptable to the Trustee, which, at the election of the Trustee, shall be not less than 14 calendar days after the production of documents by the proposed examinee in compliance with the Subpoena and this Order pursuant to Bankruptcy Rule 2004, and such examination shall continue from day to day until completed.

Dated: \_\_\_\_\_\_\_\_\_\_\_, 2024

Julie A. Manning, United States Bankruptcy Judge

\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_

# **Exhibit B**

Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 17 of 439

| Discovery Party | Address | Subpoena Index | |-------------------------------------------------------|-------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|----------------| | China CITIC Bank International | New York Branch China CITIC Bank International 410 Park Avenue, 11F New York, NY 10022 | Exhibit C-1 | | Intesa Sanpaolo SpA | New York Branch 1 William Street New York, NY 10004 | Exhibit C-2 | | Lloyds Bank PLC | New York Office 1095 Avenue of the Americas, 34th Floor New York, NY 10036 Registered Office Address 25 Gresham Street London, England EC2V 7HN | Exhibit C-3 | | PayrNet Limited | Registered Office Address Montacute Yards, Shoreditch High Street London, England E1 6HU | Exhibit C-4 | | Revolut Ltd. | Registered Agent Cogency Global Inc. 122 East 42nd Street, 18th Floor New York, NY 10168 107 Greenwich Street, 20th Floor New York, NY 10006 | Exhibit C-5 | | CIMN Bank Berhad a/k/a CIMB Islamic Bank Berhad | UK Establishment Office 27 Knightsbridge London, England SW1X 7LY Correspondence Address Menara Cimb Jalan Stesen Sentral 2 Juala Lumpur Sentral Kuala Lumpur, Malaysia 50470 | Exhibit C-6 |

Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 18 of 439

| Discovery Party | Address | Subpoena Index | |---------------------------------------------|-----------------------------------------------------|----------------| | Evan Cramer | 1250 100th St. Bay Harbor Islands, FL 33154-1106 | Exhibit C-7 | | Makaya Randall | 24 Hinckley Place Poughkeepsie, NY 12601 | Exhibit C-8 | | Richard Leahy | 661 Locust Point Road Rumson, NJ 07760 | Exhibit C-9 | | Thomas Guarino (a/k/a Thomas Guarino II) | 112 Lakewood Drive Congers, NY 10920 | Exhibit C-10 | | Lukasz Lasota | 35 Landmark Lane Fairlawn, NJ 07410 | Exhibit C-11 | | Thomas McHale | 11 Eden Road Harriman, NY 10926 | Exhibit C-12 | | Sean Lynch | 800 Wildwood Court Yorktown Heights, NY 10598 | Exhibit C-13 |

Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 19 of 439

| Discovery Party | Address | Subpoena Index | | |--------------------------------------------------|-------------------------------------------------------------------------------------------------------------------------------------|----------------|--| | Eddy Aquino (a/k/a Eddy I. Sanchez Aquino) | Cond Palmares De Monteverde 94 Ramal 842 San Juan, PR 00926-3903 | Exhibit C-14 | | | Summer L. Bridges | 6102 Premiere Ave. Lakewood, CA 90712 | Exhibit C-15 | | | Michael Baranowitz | 10 Huntsman Lane Commack, NY 11725 | Exhibit C-16 | | | Maya Fawaz | 130 Ocean Parkway, 3D Brooklyn, NY 11218 | Exhibit C-17 | | | Andrea Volpe | 15 Broad Street, Apt. 3110 New York, NY 10005 | Exhibit C-18 | | | H.R. Owen PLC | Registered Office Address Melton Court, Old Brompton Road London, England SW7 3TD | Exhibit C-19 | | | Headwater Service, LLC | Registered Agent c/o Northwest Registered Agent LLC Five Greentree Centre, 55 Route 73 North Ste. 104 Marlton, NJ 08053 | Exhibit C-20 | |

Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 20 of 439

| Discovery Party | Address | Subpoena Index | |---------------------|--------------------------------------------------------|----------------| | RM Sotheby's and/or | 1334 York Ave. | Exhibit C-21 | | RM Auctions 2022 | New York, NY 10021 | | | | | | | | Registered Office Address | | | | Heron House, 5 Heron Square | | | | Richmond, United Kingdom TW9 1EL | | | Dean M. Rabideau | 1898 Hanover Street | Exhibit C-22 | | | Yorktown Heights, NY 10598 | | | | 15 Bayberry Street Hopewell Junction, NY 12533-4333 | |

# Exhibit C-1

#### B2540 (Form 2540 – Subpoena for Rule 2004 Examination) (12/15) Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 22 of

439

UNITED STATES BANKRUPTCY COURT

**District of Connecticut**

In re HO WAN KWOK, *et al*.,

1 Case No. 22-50073 (JAM) Debtor Chapter 11

(Jointly Administered)

# **SUBPOENA FOR RULE 2004 EXAMINATION**

To: **China CITIC Bank International**

(*Name of person to whom the subpoena is directed*)

*Testimony:* **YOU ARE COMMANDED** to appear at the time, date, and place set forth below to testify at an examination under Rule 2004, Federal Rules of Bankruptcy Procedure. A copy of the court order authorizing the examination is attached.

| PLACE | DATE AND TIME | |-------|---------------| | N/A | N/A | | | |

The examination will be recorded by this method: N/A

*Production:* You, or your representatives, must also bring with you to the examination the following documents, electronically stored information, or objects, and must permit inspection, copying, testing, or sampling of the material:

## **See Requests for Production of Documents, attached hereto.**

The following provisions of Fed. R. Civ. P. 45, made applicable in bankruptcy cases by Fed. R. Bankr. P. 9016, are attached – Rule 45(c), relating to the place of compliance; Rule 45(d), relating to your protection as a person subject to a subpoena; and Rule 45(e) and 45(g), relating to your duty to respond to this subpoena and the potential consequences of not doing so.

Date: **May , 2024**

CLERK OF COURT

*Signature of Clerk or Deputy Clerk Attorney's signature*

The name, address, email address, and telephone number of the attorney representing Luc A. Despins, Chapter 11 Trustee, who issues or requests this subpoena, are:

**Patrick R. Linsey, Esq.; Neubert, Pepe & Monteith, P.C.; 195 Church Street, 13th Floor, New Haven, Connecticut 06510 plinsey@npmlaw.com; (203) 781-2847**

## **Notice to the person who issues or requests this subpoena**

If this subpoena commands the production of documents, electronically stored information, or tangible things, or the inspection of premises before trial, a notice and a copy of this subpoena must be served on each party before it is served on the person to whom it is directed. Fed. R. Civ. P. 45(a)(4).

Software Copyright (c) 1996-2022 Best Case, LLC - www.bestcase.com Best Case Bankruptcy 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).

## **PROOF OF SERVICE**

**(This section should not be filed with the court unless required by Fed. R. Civ. P. 45.)**

I received this subpoena for (*name of individual and title, if any*): on (*date*) .

I served the subpoena by delivering a copy to the named person as follows:

on *(date)* ; or

I returned the subpoena unexecuted because:

Unless the subpoena was issued on behalf of the United States, or one of its officers or agents, I have also tendered to the witness the fees for one day's attendance, and the mileage allowed by law, in the amount of \$ .

My fees are \$ for travel and \$ for services, for a total of \$ .

I declare under penalty of perjury that this information is true and correct.

Date:

*Server's signature*

*Printed name and title*

*Server's address*

Additional information concerning attempted service, etc.:

## **Federal Rule of Civil Procedure 45(c), (d), (e), and (g) (Effective 12/1/13) (made applicable in bankruptcy cases by Rule 9016, Federal Rules of Bankruptcy Procedure)**

#### **(c) Place of compliance.**

*(1) For a Trial, Hearing, or Deposition.* A subpoena may command a person to attend a trial, hearing, or deposition only as follows:

(A) within 100 miles of where the person resides, is employed, or regularly transacts business in person; or

(B) within the state where the person resides, is employed, or regularly transacts business in person, if the person

(i) is a party or a party's officer; or

(ii) is commanded to attend a trial and would not incur substantial expense.

*(2) For Other Discovery.* A subpoena may command:

(A) production of documents, or electronically stored information, or things at a place within 100 miles of where the person resides, is employed, or regularly transacts business in person; and

(B) inspection of premises, at the premises to be inspected.

## **(d) Protecting a Person Subject to a Subpoena; Enforcement.**

*(1) Avoiding Undue Burden or Expense; Sanctions.* A party or attorney responsible for issuing and serving a subpoena must take reasonable steps to avoid imposing undue burden or expense on a person subject to the subpoena. The court for the district where compliance is required must enforce this duty and impose an appropriate sanction which may include lost earnings and reasonable attorney's fees — on a party or attorney who fails to comply.

## *(2) Command to Produce Materials or Permit Inspection.*

*(A) Appearance Not Required.* A person commanded to produce documents, electronically stored information, or tangible things, or to permit the inspection of premises, need not appear in person at the place of production or inspection unless also commanded to appear for a deposition, hearing, or trial.

*(B) Objections.* A person commanded to produce documents or tangible things or to permit inspection may serve on the party or attorney designated in the subpoena a written objection to inspecting, copying, testing or sampling any or all of the materials or to inspecting the premises — or to producing electronically stored information in the form or forms requested. The objection must be served before the earlier of the time specified for compliance or 14 days after the subpoena is served. If an objection is made, the following rules apply:

(i) At any time, on notice to the commanded person, the serving party may move the court for the district where compliance is required for an order compelling production or inspection.

(ii) These acts may be required only as directed in the order, and the order must protect a person who is neither a party nor a party's officer from significant expense resulting from compliance.

## *(3) Quashing or Modifying a Subpoena.*

*(A) When Required.* On timely motion, the court for the district where compliance is required must quash or modify a subpoena that:

(i) fails to allow a reasonable time to comply;

(ii) requires a person to comply beyond the geographical limits specified in Rule 45(c);

(iii) requires disclosure of privileged or other protected matter, if no exception or waiver applies; or

(iv) subjects a person to undue burden.

*(B) When Permitted.* To protect a person subject to or affected by a subpoena, the court for the district where compliance is required may, on motion, quash or modify the subpoena if it requires:

(i) disclosing a trade secret or other confidential research, development, or commercial information; or

(ii) disclosing an unretained expert's opinion or information that does not describe specific occurrences in dispute and results from the expert's study that was not requested by a party.

(C) *Specifying Conditions as an Alternative.* In the circumstances described in Rule 45(d)(3)(B), the court may, instead of quashing or modifying a subpoena, order appearance or production under specified conditions if the serving party:

(i) shows a substantial need for the testimony or material that cannot be otherwise met without undue hardship; and

(ii) ensures that the subpoenaed person will be reasonably compensated.

#### **(e) Duties in Responding to a Subpoena.**

*(1) Producing Documents or Electronically Stored Information.* These procedures apply to producing documents or electronically stored information:

*(A) Documents.* A person responding to a subpoena to produce documents must produce them as they are kept in the ordinary course of business or must organize and label them to correspond to the categories in the demand.

*(B) Form for Producing Electronically Stored Information Not Specified.* If a subpoena does not specify a form for producing electronically stored information, the person responding must produce it in a form or forms in which it is ordinarily maintained or in a reasonably usable form or forms.

*(C) Electronically Stored Information Produced in Only One Form.* The person responding need not produce the same electronically stored information in more than one form.

*(D) Inaccessible Electronically Stored Information.* The person responding need not provide discovery of electronically stored information from sources that the person identifies as not reasonably accessible because of undue burden or cost. On motion to compel discovery or for a protective order, the person responding must show that the information is not reasonably accessible because of undue burden or cost. If that showing is made, the court may nonetheless order discovery from such sources if the requesting party shows good cause, considering the limitations of Rule 26(b)(2)(C). The court may specify conditions for the discovery.

## *(2) Claiming Privilege or Protection.*

*(A) Information Withheld.* A person withholding subpoenaed information under a claim that it is privileged or subject to protection as trial-preparation material must: (i) expressly make the claim; and

(ii) describe the nature of the withheld documents, communications, or tangible things in a manner that, without revealing information itself privileged or protected, will enable the parties to assess the claim.

*(B) Information Produced.* If information produced in response to a subpoena is subject to a claim of privilege or of protection as trial-preparation material, the person making the claim may notify any party that received the information of the claim and the basis for it. After being notified, a party must promptly return, sequester, or destroy the specified information and any copies it has; must not use or disclose the information until the claim is resolved; must take reasonable steps to retrieve the information if the party disclosed it before being notified; and may promptly present the information under seal to the court for the district where compliance is required for a determination of the claim. The person who produced the information must preserve the information until the claim is resolved.

**(g) Contempt.** The court for the district where compliance is required – and also, after a motion is transferred, the issuing court – may hold in contempt a person who, having been served, fails without adequate excuse to obey the subpoena or an order related to it.

For access to subpoena materials, see Fed.R.Civ.P.45(a) Committee Note (2013)

…

## **Request for Production of Documents**

## **I. INSTRUCTIONS**

1. Unless otherwise indicated, the requests for documents set forth below, (the "Requests," and each, a "Request"), must be responded to separately and specifically. Each Request shall be answered fully unless it is in good faith objected to, in which event the reason for Your objection shall be stated in detail, as set forth below. If an objection pertains only to a portion of a Request, or a word, phrase or clause contained within it, You are required to state Your objection to that portion only and to respond to the remainder of the Requests.

2. Electronically stored information must be produced in accordance with the

following instructions:

- a. Images. Black and white images must be 300 DPI Group IV single-page TIFF files. Color images must be produced in JPEG format. File names cannot contain embedded spaces or special characters (including the comma). Folder names cannot contain embedded spaces or special characters (including the comma). All TIFF image files must have a unique file name, i.e. Bates number. Images must be endorsed with sequential Bates numbers in the lower right corner of each image. The number of TIFF files per folder should not exceed 1000 files. Excel spreadsheets should have a placeholder image named by the Bates number of the file. - b. Image Load File - a. Concordance® Data File. The data file (.DAT) contains all of the fielded information that will be loaded into the Concordance® database. The first line of the .DAT file must be a header row identifying the field names. The .DAT file must use the following Concordance® default delimiters: Comma ASCII character (020) Quote þ ASCII character (254). Date fields should be provided in the format: mm/dd/yyyy. Date and time fields must be two separate fields. If documents includes imaged emails and attachments, the attachment fields must be included to preserve the parent/child relationship between an email and its attachments. An OCRPATH field must be included to provide the file path and name of the extracted text file on the produced storage media. The text file must be named after the FIRSTBATES. Do not include the text in the .DAT file. For Documents with native files, a LINK field must be included to provide the file path and

name of the native file. The native file must be named after the FIRSTBATES.

- b. Concordance Image® OR Opticon Cross-Reference File. The image crossreference file (.LOG or .OPT) links the images to the database records. It should be a comma-delimited file consisting of seven fields per line with a line in the cross-reference file for every image in the database with the following format: ImageID,VolumeLabel,ImageFilePath,DocumentBreak,FolderBreak,Box Break,PageCoun. - c. Document Text. Text must be produced as separate text files, not as fields within the .DAT file. The full path to the text file (OCRPATH) should be included in the .DAT file. It is recommended document level ANSI text files, named per the FIRSTBATES/Image Key. Extracted text files must be in a separate folder, and the number of text files per folder should not exceed 1,000 files. There should be no special characters (including commas in the folder names). Text files must be provided on a document level. - d. Native Production for Certain File Types. File types that reasonably require viewing in their native format for a full understanding of their content and meaning must be produced in native format. These include, but are not limited to, spreadsheets, spreadsheet-like files (Microsoft Excel, comma separated values, tab separated values, etc.), Microsoft PowerPoint or other special presentation files, database files, and audio/visual files. Provide an image of a Bates numbered slip sheet indicating the presence of a native file, and include the path to the native as a field in the .dat file. Name the produced native file with the Bates number corresponding to the slip sheet for the file. Group native files within incrementally named "NATIVE" directories, separate from images directories. - e. De-duplication. Produce a single copy of each electronic document for which exact duplicates exist. For email messages, consolidate duplicates based on MD5 hash generated from the BCC, Body, CC, From, IntMsgID, To, and Attach properties. For email attachments and standalone electronic files, consolidate duplicates based on MD5 hash of the entire file. - f. Metadata. Produce extracted metadata for each document in the form of a Concordance compliant load file (.dat). The first line of the .DAT file must be a header row identifying the field names. The .DAT file must use the following Concordance default delimiters: Comma , ASCII character (020) Quote þ ASCII character (254)

Date fields should be provided in the format: mm/dd/yyyy. Date and time fields must be two separate fields. Required metadata listed below:

| Field Name | Sample Data | Description | | |--------------|--------------------------|----------------------------------------------------------------------------------------------|--| | FIRSTBATES | EDC0000001 | First Bates number of native file document/email | | | LASTBATES | EDC0000001 | Last Bates number of native file document/email **The LASTBATES field should be populated | | | | | for single page | | | ATTACHRANGE | EDC0000001 - | Bates number of the first page of the parent | | | | EDC0000015 | document to the Bates number of the last page of | | | | | the last attachment "child" document | | | BEGATTACH | EDC0000001 | First Bates number of attachment range | | | ENDATTACH | EDC0000015 | Last Bates number of attachment range | | | CUSTODIAN | Smith, John | Email: Mailbox where the email resided | | | | | Native: Name of the individual or department | | | | | from whose files the document originated | | | FROM | John Smith | Email: Sender | | | | | Native: Author(s) of document | | | | | **semi-colon should be used to separate | | | | | multiple entries | | | TO | Coffman, Janice; LeeW | Recipient(s) | | | | [mailto:LeeW@MSN.com] | **semi-colon should be used to separate multiple | | | | | entries | | | CC | Frank Thompson [mailto: | Carbon copy recipient(s) | | | | frank_Thompson@cdt.com] | **semi-colon should be used to separate | | | | | multiple entries | | | BCC | John Cain | Blind carbon copy recipient(s) | | | | | **semi-colon should be used to separate | | | | | multiple entries | | | SUBJECT | Board Meeting Minutes | Email: Subject line of the email Native: Title | | | | | of document (if available) | | | FILE_NAME | BoardMeetingMinutes.docx | Native: Name of the original native file, | | | | | including extension | | | DATE_SENT | 10/12/2010 | Email: Date the email was sent | | | | | Native: (empty) | | | TIME_SENT/ | 07:05 PM GMT | Email: Time the email was sent/ Time zone in | | | TIME_ZONE | | which the emails were standardized | | | TIME_ZONE | GMT | The time zone in which the emails were | | | | | standardized during conversion. | | | LINK | EDC0000001.msg | Hyperlink to the email or native file document | | | | | **The linked file must be named per the | | | | | FIRSTBATES number | | | FILE_EXTEN | MSG | The file type extension | | | | | representing | | | | | the Email or | | | AUTHOR | John Smith | Email: (empty) | | | | | Native: Author of the document | | | DATE_CREATED | 10/10/2010 | Email: (empty) | | | | | Native: Date the document was created | |

| TIME_CREATED | 10:25 AM | | | |--------------|---------------------------|-------------------------------------------------|--| | | | Email: (empty) | | | | | Native: Time the document was created | | | | | **This data must be a separate field and cannot | | | | | be combined with the DATE_CREATED field | | | DATE_MOD | 10/12/2010 | Email: (empty) | | | | | Native: Date the document was last modified | | | TIME_MOD | 07:00 PM | Email: (empty) | | | | | Native: Time the document was last modified | | | | | **This data must be a separate field and cannot | | | | | be combined with the DATE_MOD field | | | DATE_ACCESSD | 10/12/2010 | Email: (empty) | | | | | Native: Date the document was last accessed | | | TIME_ACCESSD | 07:00 PM | Email: (empty) | | | | | Native: Time the document was last accessed | | | | | **This data must be a separate field and cannot | | | | | be combined with the DATE_ACCESSD field | | | FILE_SIZE | 5,952 | Size of native file document/email in KB | | | PGCOUNT | 1 | Number of pages in native file document/email | | | PATH | | Email: (empty) | | | | Agenda.doc | Native: Path where native file document was | | | | | stored including original file name. | | | INTFILEPATH | Personal Folders\Deleted | Email: original location of email including | | | | Items\Board Meeting | original file name. | | | | Minutes.msg | Native: (empty) | | | INTMSGID | <000805c2c71b\$75977050\$ | Email: Unique Message ID Native: (empty) | | | | cb8306d1@MSN> | | | | MD5HASH | d131dd02c5e6eec4693d9a0 | MD5 Hash value of the document. | | | | 698aff95c | | | | | 2fcab58712467eab4004583e | | | | | b8fb7f89 | | | | OCRPATH | TEXT/001/EDC0000001.txt | Path to extracted text of the native file | |

3. Each Request operates and should be construed independently and, unless otherwise indicated, no Request limits the scope of any other Request.

4. All Documents are to be produced as kept in the usual course of business or are to be organized and labeled to correspond with the categories in these Requests.

5. Each Request contained herein extends to all Documents: (a) in Your possession, custody, or control; or (b) in the possession, custody, or control of anyone acting on Your behalf,

## Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 29 of 439

including Your counsel or other representatives and advisors. Each Document shall be produced in its entirety.

6. If You are requested to produce a Document that is no longer in Your possession, custody, or control, then Your response must (a) describe in detail the nature of the document and its contents; (b) identify the person(s) who prepared or authored the Document (and, if applicable, the Person(s) to whom the Document was sent); (c) identify the date on which the document was prepared or created; (d) state whether such Document (i) is missing or lost, (ii) has been destroyed, (iii) has been transferred, voluntarily or involuntarily, to others, or (iv) was otherwise disposed of; (e) state the reason for, and the facts and circumstances surrounding, such disposition; (f) identify the Persons who authorized such disposition; (g) identify the date or approximate date of such disposition; (h) state when the Document was most recently in Your possession, custody or control; and (i) identify the Person, if any, presently in possession, custody, or control of such Document.

7. If You are requested to produce a Document that has been destroyed, then Your response must state, in addition to the information required by the preceding Instruction: (a) the reason for the Document's destruction; (b) the identity of the Person who destroyed the Document; and (c) the identity of the Person who directed that the Document be destroyed.

8. If You claim that a requested Document is privileged or attorney work-product, then Your response must: (a) state (i) a description of the Document adequate to support Your contention that the Document is privileged, (ii) the title of the Document, (iii) the date of the Document, (iv) the author of the Document, (v) the addressee of the Document, (vi) the identity of each Person who received or saw the original or any draft, copy, or reproduction of the Document, (vii) whether the Document itself, or any information contained or referred to in the Document is in the possession, custody, or control of any other Persons, and if so, the identity of

## Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 30 of 439

such Persons, as well as a statement addressing how the information came into their possession, (viii) the claim of privilege under which the Document is withheld, and (ix) all of the circumstances upon which You will rely to support such claim of privilege; and (b) produce a privilege log containing all of the information requested in Part (a) of this Instruction for each Document withheld on the basis of a claim of privilege in accordance with D. Conn. L. Civ. R. 26(e). For any part of a Document Request as to which a claim of privilege or work product is not made, responsive documents should be provided in full.

9. If a portion of an otherwise responsive Document contains information subject to a claim of privilege, only that portion of the Document subject to the claim of privilege shall be deleted or redacted from the Document following the instructions above, and the rest shall be produced.

10. The Requests are continuing in nature. You are hereby instructed to (a) supplement or correct any responses later learned to be incomplete or incorrect immediately upon learning that a prior response was incomplete or incorrect; and (b) produce any additional Documents that are called for under the subpoena.

11. If a Document is in a language other than English, You should provide that Document. If a Document is in a language other than English, and an English translation exists, You should provide both Documents.

12. All references to Entities includes all affiliates thereof.

13. All references to individual names include all alternative names, aliased, or nicknames.

14. Unless otherwise expressly indicated, the period of time covered by the Document Requests is the period from February 5, 2012 to the date responses to the Document Requests are due.

## **II. RULES OF CONSTRUCTION**

15. The use of (a) any singular noun shall be construed to include the plural, and vice versa, and (b) a verb in any tense shall be construed as the use of the verb in all other tenses.

16. The terms (a) "and" and "or" shall be construed either conjunctively or disjunctively as necessary to bring within the scope of any request all responses that might otherwise be construed to be outside of its scope, and (b) "each" and "any" shall be deemed to include and encompass the words "every" and "all."

## **III. DEFINITIONS**

The definitions supplied by D. Conn. L. Civ. R. 26(c) and the rules of construction supplied by D. Conn. L. Civ. R. 26(d), as incorporated by D. Conn. Bankr. L.R. 2004-1(a), shall apply to the Document Requests. In addition, the following terms used in these Document Requests shall have the following meanings:

1. "You" or "Your" or "Yourself" means and refers, to China CITIC Bank International, together with all of its affiliates, divisions, agencies, instrumentalities, departments, offices, partners, officers, directors, agents, attorneys, representatives, employees, and/or anyone acting on its behalf.

## Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 32 of 439

2. "Debtor" means Ho Wan Kwok (a/k/a Miles Kwok, Miles Guo, Guo Wengui, Guo Haoyun, 郭文贵, or any other alias), together with his employees, agents, counsel, advisors, or anyone acting on his behalf.

3. "Debtor's Son" means Qiang Guo (a/k/a Mileson Kwok, 郭强, or any other alias), together with his employees, agents, counsel, advisors, or anyone acting on his behalf.

4. "Debtor's Daughter" means Mei Guo (a/k/a Mei Gui, 郭美, or any other alias), together with her employees, agents, counsel, advisors, or anyone acting on her behalf.

5. "Debtor's Purported Wife" means Hing Chi Ngok (a/k/a Hing Chi Ng, Yue Qingzhi, 岳庆芝, or any other alias), together with her employees, agents, counsel, advisors, or anyone acting on her behalf.

6. "Debtor's Family" means, individually and collectively, the Debtor, the Debtor's Son, the Debtor's Daughter, and the Debtor's Purported Wife, and any other familial relation to the Debtor.

7. "2004 Discovery Targets" means, individually and collectively, the Debtor, the Debtor's Family, 17 Miles, LLC, 5780 Saguaro LLC, Aaron Mitchell, ACA Capital Group Limited, Ace Decade Holdings Limited, AI Group Holdings Inc., Alfa Global Ventures Limited, Alphonso Global Ventures Limited, Ana C. Izquiedo-Henn, Andrew Childe, Anthony DiBattista, Anton Development Limited, Booming Sail New York LLC, Beile Li, Bingshang Jiao, Bravo Luck Limited, Brent Petro Inc., Celestial Tide Limited, Chris Lee (a/k/a Nan Li, Mei Guo Xiao Li), China Golden Spring Group (Hong Kong) Ltd., Crane Advisory Group, Daniel Thomas Podhaskie, Defeng Cao (a/k/a Wayne Cao, Max Cao), Ding "Ivan" Lin, Doaa Dashoush, Eastern Profit Corporation Limited, Genever Holdings Corporation, Genever Holdings LLC, Gettr USA, Inc., Gnews Media Group Inc., G Fashion (CA), G Fashion, G Fashion Hold Co. A. Limited, G

## Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 33 of 439

Fashion Hold Co. B. Limited, G Fashion Media Group Inc., G Fashion International Limited, G Fashion LLC, Gmusic LLC, Gnews LLC, Geducation, GFNY, Inc., G Club Finance, G Club HoldCo I LLC, G Club International Limited, G Club Investments Limited, G Club Operations LLC, G Club US Operations Inc., G Club US Operations LLC, G Club, G Club One, G Club Two, G Club Three, G Live, LLC, Gbroadcast, LLC, GM 27 LLC, Gladys Chow, Golden Spring (New York) Ltd., Gposts LLC, GTV Media Group, Inc., Gypsy Mei Food Service LLC, Gypsy Mei Productions LLC, Gypsy Mei 27 Vestry, Inc., Dawn State Limited, Greenwich Land LLC, Hao (Gavin) Li (a/k/a Huo Lai), Haitham Khaled, Hamilton Capital Holdings Inc., Hamilton Digital Assets Funds SP, Hamilton Investment Management Limited, Hamilton Opportunity Fund SPC, Hamilton PE Funds SP, Holy City Hong Kong Ventures Ltd., GS Security Solutions Inc., Alex Hadjcharalambous, Han Chunguang, Haoran He, HCHK Property Management, Inc., HCHK Technologies, Inc., HK International Funds Investments (USA) Limited LLC, Freedom Media Ventures Ltd., FungWan Trading Inc., Himalaya Currency Clearing Pty. Ltd., Himalaya New World Inc., Himalaya International Financial Group Ltd., Himalaya International Clearing Ltd., Himalaya International Payments Ltd., Himalaya International Reserves Ltd., Himalaya Ventures LLC, Himalaya Investment LLC, Hudson Diamond Holding, Inc., Hudson Diamond Holding LLC, Hudson Diamond NY LLC, Huk Trading Inc., Infinity Treasury Management Inc., Jesse Brown, Jessica Mastrogiovanni, Jiaming Liu, Jie Zhang, Jovial Century International Limited, Joyord Sportswear Limited, K Legacy Ltd., Kamel Debeche, Karin Maistrello, Kin Ming Je, Lamp Capital LLC, Lawall & Mitchell, LLC, Leading Shine NY Ltd., Lexington Property and Staffing, Inc., Lexington Property and Staffing LLC, Linwan "Irene" Feng, Limarie Reyes, Lihong "Sara" Wei Lafrenz, The Lost Draft LLC, Macaron Limited, Major Lead International Limited, Mary Jiang, MOS Himalaya LLC, Maywind Trading LLC, New York MOS Himalaya LLC, Next

## Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 34 of 439

Tycoon Investments Limited, Nicholas Savio, Nodal Partners, LLC, Qidong Xia, Oasis Tech Limited, O.S.C. Orbit Service Company, LLC, Pixshow Film Inc., Qu Guo Jiao, Roscalitar 2, Ridwan Mamode Saib, Ross Heinemeyer, Rule of Law Society IV Inc., Rule of Law Foundation III, Inc., Rule of Law Fund, Saraca Media Group Inc., Savio Law LLC, Scott Barnett, Seven Mission Group LLC, Shih Hsin Yu, Sirius Networking Inc., Taurus Fund LLC, Taurus Management LLC, US Himalaya Capital Inc., V.X. Cerda & Associates P.A., Victor Cerda, Voice of Guo Media, Inc., Wen Xiao, Wencong Wang, William Je, Kin Ming Je a/k/a Je Kin Ming, Wise Creation International Limited, Xuebing Wang, Yan Chun Liu, Yinying (Aila) Wang (a/k/a Xiao Fei Xiang), Yongbing Zhang, Yongping Yan (Shan Mu) Yue Zhou, Yumei Hao (a/k/a Ru Shui), Yvette Wang (a/k/a Yanping Wang, a/k/a Yan Ping Wang), Zhixuan Li, Zhouer "Joe" Wang, NewPeople LLC, Ziba Limited, New Mulberry PTE Ltd, TD Primrose Limited, and Shin Hee-Seup a/k/a Hee Seup Shin.

8. "Including" or any variant thereof means "including without limitation."

9. "And" and "or" mean "and/or," and shall be construed both conjunctively as well as disjunctively in order to maximize their scope.

10. "Any" and "all" and "each" mean "each and every."

11. "Each" and "every" mean "each and every."

12. "Third Party" means a Person or Entity other than Yourself.

13. "Transfer" shall have the meaning given to it by section 101(54) of the Bankruptcy Code.

14. "Document" means any information or thing within the scope of Fed. R. Civ. P. 34, and includes, without limitation, each and every written, recorded, or graphic matter of any kind,

## Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 35 of 439

type, nature, or description that is or has been in Your Possession, Custody or Control, including all printed and electronic copies of electronic mail, computer files maintained in electronic form, correspondence, memoranda, tapes, stenographic or handwritten notes, written forms of any kind, charts, blueprints, drawings, sketches, graphs, plans, articles, specifications, diaries, letters, telegrams, photographs, minutes, contracts, agreements, surveys, computer printouts, data compilations of any kind, telexes, facsimiles, emails, text messages, instant messages, voice messages, invoices, order forms, checks, drafts, statements, credit memos, reports, position reports, summaries, indices, books, ledgers, notebooks, schedules, transparencies, recordings, catalogs, advertisements, promotional materials, films, video tapes, audio tapes, CDs, computer disks, brochures, pamphlets, punch-cards, time-slips, Tweets, social media posts, or any written or recorded materials of any other kind, and all meta-data thereof, however stored (whether in tangible or electronic form), recorded, produced, or reproduced, and also including but not limited to, drafts or copies of any of the foregoing that contain any notes, comments, or markings of any kind not found on the original documents or that are otherwise not identical to the original documents.

15. "Person(s)" means an individual, corporation, proprietorship, partnership, association, or any other Entity. "Person" also includes any agent, representatives, or expert, including but not limiting to, attorneys or financial advisors.

16. "Entity" means any natural Person, corporation, partnership, subsidiary, sole proprietorship, firm, board, joint venture, association, agency, authority, commission or other business entity or juristic Person, as well as any affiliate, agent, parent including but not limited to counsel, financial advisors, or any other representative.

## Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 36 of 439

17. "Regarding" means concerning, describing, comprising, referring to, related to, supporting, favoring, opposing, bolstering, detracting from, located in, considered in connection with, bearing on, evidencing, indicating, reporting on, recording, alluding to, responding to, connected with, commenting on, in respect of, about, in relation to, discussing, showing, describing, reflecting, analyzing constituting, and being.

18. "Relating to," "relate(s) to" or "related to," when referring to any given subject matter, means, without limitation, any document that constitutes, comprises, involves, contains, embodies, reflects, identifies, states, refers directly or indirectly to, or is in any way relevant to the particular subject matter identified.

19. "Communication(s)" means, in the broadest possible sense, and without limitation, any transmittal of information or knowledge (in the form of facts, ideas, inquiries, or otherwise). Communication(s) further refers to all conversations, agreements, inquiries, or replies, whether in person, by telephone, in writing, or by means of electronic transmittal devices, and includes, but is not limited to, all correspondence, emails, recordings, transmittal slips, memoranda, telephone communications, voice messages, telegrams, telefaxes, telecopies, telexes, instant messages, chats, text messages, postings to a message board or group chat, social media posts, tweets, videos uploaded to any video platform, telephonic notes, or notes transmitted internally or with third parties.

20. "Asset(s)" means any item of economic value that is subject to Possession, Custody, or Control. Asset includes all real and personal property, including but limited to, real estate, land, houses, apartments, condominiums, automobiles, yachts, boats, planes, jets, helicopters, cash, bank accounts, cryptocurrencies, securities, accounts receivables, inventory, and other tangible and intangible property.

## **IV. DOCUMENTS TO BE PRODUCED**

1. All Documents related to any account held by, controlled by, on behalf of, or otherwise related to any of the 2004 Discovery Targets, including any and all account statements, authorizations, power of attorney, trusts, instructions or forms, copies of cancelled checks, correspondence, and wire transfers and related correspondence and instructions.

2. All Documents related to any funds, securities, property, or assets belonging to, held by, controlled by, on behalf of, or otherwise related to any of the 2004 Discovery Targets, including any and all account statements, authorizations, powers of attorney, trusts, instructions or forms, copies of cancelled checks, correspondence, and wire transfers and related correspondence and instructions.

3. All Documents related to any business, commerce or financial transactions, including but not limited to any loan, line of credit, bailment, deposit, swap, securities transactions, mortgage, or ISDA, with any of the 2004 Discovery Targets, including any and all account statements, authorizations, powers of attorney, trusts, instructions or forms, copies of cancelled checks, correspondence, and wire transfers and related correspondence and instructions.

4. All Documents relating to any wire transfer activity relating to the 2004 Discovery Targets, regardless of the existence of any accounts, including but not limited to all wire transfer receipts, account numbers, balances, authorizations, identification information related to the parties to the transfer, correspondence, instructions, or other records.

5. All Documents related to any correspondence and communications between you and the 2004 Discovery Targets.

6. All Documents related to any account with any 2004 Discovery Target relating to opening of the account, authorized users of the account and maintenance of the account.

## Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 38 of 439

7. All Documents related to any anti-money laundering, know-your-customer, or other compliance activity relating to any of the 2004 Discovery Targets, including but not limited to any information provided by any of the 2004 Discovery Targets, or learned by You.

8. All Documents relating to any communications with any regulator from any country, including but not limited to the Bank of England, the United States Federal Reserve, the S.E.C., the CFTC, FINRA, China Securities Regulatory Commission, People's Bank of China, Hong Kong Securities and Futures Commission, and the Hong Kong Monetary Authority relating to any of the 2004 Discovery Targets.

# Exhibit C-2

#### B2540 (Form 2540 – Subpoena for Rule 2004 Examination) (12/15) Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 40 of

439

UNITED STATES BANKRUPTCY COURT

**District of Connecticut**

In re HO WAN KWOK, *et al*.,

1 Case No. 22-50073 (JAM) Debtor Chapter 11

(Jointly Administered)

# **SUBPOENA FOR RULE 2004 EXAMINATION**

To: **Intesa Sanpaolo SpA**

(*Name of person to whom the subpoena is directed*)

| PLACE | DATE AND TIME | |-------|---------------| | N/A | N/A | | | |

The examination will be recorded by this method: N/A

## **See Requests for Production of Documents, attached hereto.**

Date: **May , 2024**

CLERK OF COURT

*Signature of Clerk or Deputy Clerk Attorney's signature*

The name, address, email address, and telephone number of the attorney representing Luc A. Despins, Chapter 11 Trustee, who issues or requests this subpoena, are:

**Patrick R. Linsey, Esq.; Neubert, Pepe & Monteith, P.C.; 195 Church Street, 13th Floor, New Haven, Connecticut 06510 plinsey@npmlaw.com; (203) 781-2847**

## **Notice to the person who issues or requests this subpoena**

## **PROOF OF SERVICE**

**(This section should not be filed with the court unless required by Fed. R. Civ. P. 45.)**

I received this subpoena for (*name of individual and title, if any*): on (*date*) .

I served the subpoena by delivering a copy to the named person as follows:

on *(date)* ; or

I returned the subpoena unexecuted because:

My fees are \$ for travel and \$ for services, for a total of \$ .

I declare under penalty of perjury that this information is true and correct.

Date:

*Server's signature*

*Printed name and title*

*Server's address*

Additional information concerning attempted service, etc.:

## **Federal Rule of Civil Procedure 45(c), (d), (e), and (g) (Effective 12/1/13) (made applicable in bankruptcy cases by Rule 9016, Federal Rules of Bankruptcy Procedure)**

#### **(c) Place of compliance.**

*(1) For a Trial, Hearing, or Deposition.* A subpoena may command a person to attend a trial, hearing, or deposition only as follows:

(A) within 100 miles of where the person resides, is employed, or regularly transacts business in person; or

(B) within the state where the person resides, is employed, or regularly transacts business in person, if the person

(i) is a party or a party's officer; or

(ii) is commanded to attend a trial and would not incur substantial expense.

*(2) For Other Discovery.* A subpoena may command:

(A) production of documents, or electronically stored information, or things at a place within 100 miles of where the person resides, is employed, or regularly transacts business in person; and

(B) inspection of premises, at the premises to be inspected.

## **(d) Protecting a Person Subject to a Subpoena; Enforcement.**

## *(2) Command to Produce Materials or Permit Inspection.*

(i) At any time, on notice to the commanded person, the serving party may move the court for the district where compliance is required for an order compelling production or inspection.

(ii) These acts may be required only as directed in the order, and the order must protect a person who is neither a party nor a party's officer from significant expense resulting from compliance.

## *(3) Quashing or Modifying a Subpoena.*

*(A) When Required.* On timely motion, the court for the district where compliance is required must quash or modify a subpoena that:

(i) fails to allow a reasonable time to comply;

(ii) requires a person to comply beyond the geographical limits specified in Rule 45(c);

(iii) requires disclosure of privileged or other protected matter, if no exception or waiver applies; or

(iv) subjects a person to undue burden.

*(B) When Permitted.* To protect a person subject to or affected by a subpoena, the court for the district where compliance is required may, on motion, quash or modify the subpoena if it requires:

(i) disclosing a trade secret or other confidential research, development, or commercial information; or

(ii) disclosing an unretained expert's opinion or information that does not describe specific occurrences in dispute and results from the expert's study that was not requested by a party.

(i) shows a substantial need for the testimony or material that cannot be otherwise met without undue hardship; and

(ii) ensures that the subpoenaed person will be reasonably compensated.

#### **(e) Duties in Responding to a Subpoena.**

*(1) Producing Documents or Electronically Stored Information.* These procedures apply to producing documents or electronically stored information:

*(C) Electronically Stored Information Produced in Only One Form.* The person responding need not produce the same electronically stored information in more than one form.

#### *(2) Claiming Privilege or Protection.*

For access to subpoena materials, see Fed.R.Civ.P.45(a) Committee Note (2013)

…

## **Request for Production of Documents**

## **I. INSTRUCTIONS**

2. Electronically stored information must be produced in accordance with the

following instructions:

name of the native file. The native file must be named after the FIRSTBATES.

Date fields should be provided in the format: mm/dd/yyyy. Date and time fields must be two separate fields. Required metadata listed below:

| TIME_CREATED | 10:25 AM | Email: (empty) | | |--------------|---------------------------|-------------------------------------------------|--| | | | Native: Time the document was created | | | | | **This data must be a separate field and cannot | | | | | be combined with the DATE_CREATED field | | | DATE_MOD | 10/12/2010 | Email: (empty) | | | | | Native: Date the document was last modified | | | TIME_MOD | 07:00 PM | Email: (empty) | | | | | Native: Time the document was last modified | | | | | **This data must be a separate field and cannot | | | | | be combined with the DATE_MOD field | | | DATE_ACCESSD | 10/12/2010 | Email: (empty) | | | | | Native: Date the document was last accessed | | | TIME_ACCESSD | 07:00 PM | Email: (empty) | | | | | Native: Time the document was last accessed | | | | | **This data must be a separate field and cannot | | | | | be combined with the DATE_ACCESSD field | | | FILE_SIZE | 5,952 | Size of native file document/email in KB | | | PGCOUNT | 1 | Number of pages in native file document/email | | | PATH | | Email: (empty) | | | | Agenda.doc | Native: Path where native file document was | | | | | stored including original file name. | | | INTFILEPATH | Personal Folders\Deleted | Email: original location of email including | | | | Items\Board Meeting | original file name. | | | | Minutes.msg | Native: (empty) | | | INTMSGID | <000805c2c71b\$75977050\$ | Email: Unique Message ID Native: (empty) | | | | cb8306d1@MSN> | | | | MD5HASH | d131dd02c5e6eec4693d9a0 | MD5 Hash value of the document. | | | | 698aff95c | | | | | 2fcab58712467eab4004583e | | | | | b8fb7f89 | | | | OCRPATH | TEXT/001/EDC0000001.txt | Path to extracted text of the native file | |

3. Each Request operates and should be construed independently and, unless otherwise indicated, no Request limits the scope of any other Request.

4. All Documents are to be produced as kept in the usual course of business or are to be organized and labeled to correspond with the categories in these Requests.

5. Each Request contained herein extends to all Documents: (a) in Your possession, custody, or control; or (b) in the possession, custody, or control of anyone acting on Your behalf,

## Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 47 of 439

including Your counsel or other representatives and advisors. Each Document shall be produced in its entirety.

## Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 48 of 439

12. All references to Entities includes all affiliates thereof.

13. All references to individual names include all alternative names, aliased, or nicknames.

14. Unless otherwise expressly indicated, the period of time covered by the Document Requests is the period from February 5, 2012 to the date responses to the Document Requests are due.

## **II. RULES OF CONSTRUCTION**

15. The use of (a) any singular noun shall be construed to include the plural, and vice versa, and (b) a verb in any tense shall be construed as the use of the verb in all other tenses.

## **III. DEFINITIONS**

1. "You" or "Your" or "Yourself" means and refers, to Intesa Sanpaolo SpA, together with all of its affiliates, divisions, agencies, instrumentalities, departments, offices, partners, officers, directors, agents, attorneys, representatives, employees, and/or anyone acting on its behalf.

## Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 50 of 439

3. "Debtor's Son" means Qiang Guo (a/k/a Mileson Kwok, 郭强, or any other alias), together with his employees, agents, counsel, advisors, or anyone acting on his behalf.

4. "Debtor's Daughter" means Mei Guo (a/k/a Mei Gui, 郭美, or any other alias), together with her employees, agents, counsel, advisors, or anyone acting on her behalf.

6. "Debtor's Family" means, individually and collectively, the Debtor, the Debtor's Son, the Debtor's Daughter, and the Debtor's Purported Wife, and any other familial relation to the Debtor.

## Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 51 of 439

## Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 52 of 439

8. "Including" or any variant thereof means "including without limitation."

9. "And" and "or" mean "and/or," and shall be construed both conjunctively as well as disjunctively in order to maximize their scope.

10. "Any" and "all" and "each" mean "each and every."

11. "Each" and "every" mean "each and every."

12. "Third Party" means a Person or Entity other than Yourself.

13. "Transfer" shall have the meaning given to it by section 101(54) of the Bankruptcy Code.

14. "Document" means any information or thing within the scope of Fed. R. Civ. P. 34, and includes, without limitation, each and every written, recorded, or graphic matter of any kind,

## Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 53 of 439

## Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 54 of 439

## **IV. DOCUMENTS TO BE PRODUCED**

5. All Documents related to any correspondence and communications between you and the 2004 Discovery Targets.

6. All Documents related to any account with any 2004 Discovery Target relating to opening of the account, authorized users of the account and maintenance of the account.

## Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 56 of 439

# Exhibit C-3

#### B2540 (Form 2540 – Subpoena for Rule 2004 Examination) (12/15) Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 58 of

439

UNITED STATES BANKRUPTCY COURT

**District of Connecticut**

In re HO WAN KWOK, *et al*.,

1 Case No. 22-50073 (JAM) Debtor Chapter 11

(Jointly Administered)

# **SUBPOENA FOR RULE 2004 EXAMINATION**

To: **Lloyds Bank PLC**

(*Name of person to whom the subpoena is directed*)

| PLACE | DATE AND TIME | |-------|---------------| | N/A | N/A | | | |

The examination will be recorded by this method: N/A

## **See Requests for Production of Documents, attached hereto.**

Date: **May , 2024**

CLERK OF COURT

*Signature of Clerk or Deputy Clerk Attorney's signature*

The name, address, email address, and telephone number of the attorney representing Luc A. Despins, Chapter 11 Trustee, who issues or requests this subpoena, are:

**Patrick R. Linsey, Esq.; Neubert, Pepe & Monteith, P.C.; 195 Church Street, 13th Floor, New Haven, Connecticut 06510 plinsey@npmlaw.com; (203) 781-2847**

## **Notice to the person who issues or requests this subpoena**

## **PROOF OF SERVICE**

**(This section should not be filed with the court unless required by Fed. R. Civ. P. 45.)**

I received this subpoena for (*name of individual and title, if any*): on (*date*) .

I served the subpoena by delivering a copy to the named person as follows:

on *(date)* ; or

I returned the subpoena unexecuted because:

My fees are \$ for travel and \$ for services, for a total of \$ .

I declare under penalty of perjury that this information is true and correct.

Date:

*Server's signature*

*Printed name and title*

*Server's address*

Additional information concerning attempted service, etc.:

## **Federal Rule of Civil Procedure 45(c), (d), (e), and (g) (Effective 12/1/13) (made applicable in bankruptcy cases by Rule 9016, Federal Rules of Bankruptcy Procedure)**

#### **(c) Place of compliance.**

*(1) For a Trial, Hearing, or Deposition.* A subpoena may command a person to attend a trial, hearing, or deposition only as follows:

(A) within 100 miles of where the person resides, is employed, or regularly transacts business in person; or

(B) within the state where the person resides, is employed, or regularly transacts business in person, if the person

(i) is a party or a party's officer; or

(ii) is commanded to attend a trial and would not incur substantial expense.

*(2) For Other Discovery.* A subpoena may command:

(A) production of documents, or electronically stored information, or things at a place within 100 miles of where the person resides, is employed, or regularly transacts business in person; and

(B) inspection of premises, at the premises to be inspected.

## **(d) Protecting a Person Subject to a Subpoena; Enforcement.**

## *(2) Command to Produce Materials or Permit Inspection.*

(i) At any time, on notice to the commanded person, the serving party may move the court for the district where compliance is required for an order compelling production or inspection.

(ii) These acts may be required only as directed in the order, and the order must protect a person who is neither a party nor a party's officer from significant expense resulting from compliance.

## *(3) Quashing or Modifying a Subpoena.*

*(A) When Required.* On timely motion, the court for the district where compliance is required must quash or modify a subpoena that:

(i) fails to allow a reasonable time to comply;

(ii) requires a person to comply beyond the geographical limits specified in Rule 45(c);

(iii) requires disclosure of privileged or other protected matter, if no exception or waiver applies; or

(iv) subjects a person to undue burden.

*(B) When Permitted.* To protect a person subject to or affected by a subpoena, the court for the district where compliance is required may, on motion, quash or modify the subpoena if it requires:

(i) disclosing a trade secret or other confidential research, development, or commercial information; or

(ii) disclosing an unretained expert's opinion or information that does not describe specific occurrences in dispute and results from the expert's study that was not requested by a party.

(i) shows a substantial need for the testimony or material that cannot be otherwise met without undue hardship; and

(ii) ensures that the subpoenaed person will be reasonably compensated.

#### **(e) Duties in Responding to a Subpoena.**

*(1) Producing Documents or Electronically Stored Information.* These procedures apply to producing documents or electronically stored information:

*(C) Electronically Stored Information Produced in Only One Form.* The person responding need not produce the same electronically stored information in more than one form.

#### *(2) Claiming Privilege or Protection.*

For access to subpoena materials, see Fed.R.Civ.P.45(a) Committee Note (2013)

…

## **Request for Production of Documents**

## **I. INSTRUCTIONS**

2. Electronically stored information must be produced in accordance with the

following instructions:

name of the native file. The native file must be named after the FIRSTBATES.

Date fields should be provided in the format: mm/dd/yyyy. Date and time fields must be two separate fields. Required metadata listed below:

| TIME_CREATED | 10:25 AM | Email: (empty) | | |--------------|---------------------------|-------------------------------------------------|--| | | | | | | | | Native: Time the document was created | | | | | **This data must be a separate field and cannot | | | | | be combined with the DATE_CREATED field | | | DATE_MOD | 10/12/2010 | Email: (empty) | | | | | Native: Date the document was last modified | | | TIME_MOD | 07:00 PM | Email: (empty) | | | | | Native: Time the document was last modified | | | | | **This data must be a separate field and cannot | | | | | be combined with the DATE_MOD field | | | DATE_ACCESSD | 10/12/2010 | Email: (empty) | | | | | Native: Date the document was last accessed | | | TIME_ACCESSD | 07:00 PM | Email: (empty) | | | | | Native: Time the document was last accessed | | | | | **This data must be a separate field and cannot | | | | | be combined with the DATE_ACCESSD field | | | FILE_SIZE | 5,952 | Size of native file document/email in KB | | | PGCOUNT | 1 | Number of pages in native file document/email | | | PATH | | Email: (empty) | | | | Agenda.doc | Native: Path where native file document was | | | | | stored including original file name. | | | INTFILEPATH | Personal Folders\Deleted | Email: original location of email including | | | | Items\Board Meeting | original file name. | | | | Minutes.msg | Native: (empty) | | | INTMSGID | <000805c2c71b\$75977050\$ | Email: Unique Message ID Native: (empty) | | | | cb8306d1@MSN> | | | | MD5HASH | d131dd02c5e6eec4693d9a0 | MD5 Hash value of the document. | | | | 698aff95c | | | | | 2fcab58712467eab4004583e | | | | | b8fb7f89 | | | | OCRPATH | TEXT/001/EDC0000001.txt | Path to extracted text of the native file | |

3. Each Request operates and should be construed independently and, unless otherwise indicated, no Request limits the scope of any other Request.

4. All Documents are to be produced as kept in the usual course of business or are to be organized and labeled to correspond with the categories in these Requests.

5. Each Request contained herein extends to all Documents: (a) in Your possession, custody, or control; or (b) in the possession, custody, or control of anyone acting on Your behalf,

## Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 65 of 439

including Your counsel or other representatives and advisors. Each Document shall be produced in its entirety.

## Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 66 of 439

12. All references to Entities includes all affiliates thereof.

13. All references to individual names include all alternative names, aliased, or nicknames.

## Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 67 of 439

14. Unless otherwise expressly indicated, the period of time covered by the Document Requests is the period from February 5, 2012 to the date responses to the Document Requests are due.

## **II. RULES OF CONSTRUCTION**

15. The use of (a) any singular noun shall be construed to include the plural, and vice versa, and (b) a verb in any tense shall be construed as the use of the verb in all other tenses.

## **III. DEFINITIONS**

1. "You" or "Your" or "Yourself" means and refers, to Lloyds Bank PLC, together with all of its affiliates, divisions, agencies, instrumentalities, departments, offices, partners, officers, directors, agents, attorneys, representatives, employees, and/or anyone acting on its behalf.

## Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 68 of 439

3. "Debtor's Son" means Qiang Guo (a/k/a Mileson Kwok, 郭强, or any other alias), together with his employees, agents, counsel, advisors, or anyone acting on his behalf.

4. "Debtor's Daughter" means Mei Guo (a/k/a Mei Gui, 郭美, or any other alias), together with her employees, agents, counsel, advisors, or anyone acting on her behalf.

6. "Debtor's Family" means, individually and collectively, the Debtor, the Debtor's Son, the Debtor's Daughter, and the Debtor's Purported Wife, and any other familial relation to the Debtor.

## Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 69 of 439

## Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 70 of 439

8. "Including" or any variant thereof means "including without limitation."

9. "And" and "or" mean "and/or," and shall be construed both conjunctively as well as disjunctively in order to maximize their scope.

10. "Any" and "all" and "each" mean "each and every."

11. "Each" and "every" mean "each and every."

12. "Third Party" means a Person or Entity other than Yourself.

13. "Transfer" shall have the meaning given to it by section 101(54) of the Bankruptcy Code.

14. "Document" means any information or thing within the scope of Fed. R. Civ. P. 34, and includes, without limitation, each and every written, recorded, or graphic matter of any kind,

## Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 71 of 439

## Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 72 of 439

## **IV. DOCUMENTS TO BE PRODUCED**

5. All Documents related to any correspondence and communications between you and the 2004 Discovery Targets.

6. All Documents related to any account with any 2004 Discovery Target relating to opening of the account, authorized users of the account and maintenance of the account.

## Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 74 of 439

# Exhibit C-4

#### B2540 (Form 2540 – Subpoena for Rule 2004 Examination) (12/15) Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 76 of

439

UNITED STATES BANKRUPTCY COURT

**District of Connecticut**

In re HO WAN KWOK, *et al*.,

1 Case No. 22-50073 (JAM) Debtor Chapter 11

(Jointly Administered)

# **SUBPOENA FOR RULE 2004 EXAMINATION**

To: **PayrNet Limited**

(*Name of person to whom the subpoena is directed*)

| PLACE | DATE AND TIME | |-------|---------------| | N/A | N/A | | | |

The examination will be recorded by this method: N/A

## **See Requests for Production of Documents, attached hereto.**

Date: **May , 2024**

CLERK OF COURT

*Signature of Clerk or Deputy Clerk Attorney's signature*

The name, address, email address, and telephone number of the attorney representing Luc A. Despins, Chapter 11 Trustee, who issues or requests this subpoena, are:

**Patrick R. Linsey, Esq.; Neubert, Pepe & Monteith, P.C.; 195 Church Street, 13th Floor, New Haven, Connecticut 06510 plinsey@npmlaw.com; (203) 781-2847**

## **Notice to the person who issues or requests this subpoena**

## **PROOF OF SERVICE**

**(This section should not be filed with the court unless required by Fed. R. Civ. P. 45.)**

I received this subpoena for (*name of individual and title, if any*): on (*date*) .

I served the subpoena by delivering a copy to the named person as follows:

on *(date)* ; or

I returned the subpoena unexecuted because:

My fees are \$ for travel and \$ for services, for a total of \$ .

I declare under penalty of perjury that this information is true and correct.

Date:

*Server's signature*

*Printed name and title*

*Server's address*

Additional information concerning attempted service, etc.:

## **Federal Rule of Civil Procedure 45(c), (d), (e), and (g) (Effective 12/1/13) (made applicable in bankruptcy cases by Rule 9016, Federal Rules of Bankruptcy Procedure)**

#### **(c) Place of compliance.**

*(1) For a Trial, Hearing, or Deposition.* A subpoena may command a person to attend a trial, hearing, or deposition only as follows:

(A) within 100 miles of where the person resides, is employed, or regularly transacts business in person; or

(B) within the state where the person resides, is employed, or regularly transacts business in person, if the person

(i) is a party or a party's officer; or

(ii) is commanded to attend a trial and would not incur substantial expense.

*(2) For Other Discovery.* A subpoena may command:

(A) production of documents, or electronically stored information, or things at a place within 100 miles of where the person resides, is employed, or regularly transacts business in person; and

(B) inspection of premises, at the premises to be inspected.

## **(d) Protecting a Person Subject to a Subpoena; Enforcement.**

## *(2) Command to Produce Materials or Permit Inspection.*

(i) At any time, on notice to the commanded person, the serving party may move the court for the district where compliance is required for an order compelling production or inspection.

(ii) These acts may be required only as directed in the order, and the order must protect a person who is neither a party nor a party's officer from significant expense resulting from compliance.

## *(3) Quashing or Modifying a Subpoena.*

*(A) When Required.* On timely motion, the court for the district where compliance is required must quash or modify a subpoena that:

(i) fails to allow a reasonable time to comply;

(ii) requires a person to comply beyond the geographical limits specified in Rule 45(c);

(iii) requires disclosure of privileged or other protected matter, if no exception or waiver applies; or

(iv) subjects a person to undue burden.

*(B) When Permitted.* To protect a person subject to or affected by a subpoena, the court for the district where compliance is required may, on motion, quash or modify the subpoena if it requires:

(i) disclosing a trade secret or other confidential research, development, or commercial information; or

(ii) disclosing an unretained expert's opinion or information that does not describe specific occurrences in dispute and results from the expert's study that was not requested by a party.

(i) shows a substantial need for the testimony or material that cannot be otherwise met without undue hardship; and

(ii) ensures that the subpoenaed person will be reasonably compensated.

#### **(e) Duties in Responding to a Subpoena.**

*(1) Producing Documents or Electronically Stored Information.* These procedures apply to producing documents or electronically stored information:

*(C) Electronically Stored Information Produced in Only One Form.* The person responding need not produce the same electronically stored information in more than one form.

#### *(2) Claiming Privilege or Protection.*

For access to subpoena materials, see Fed.R.Civ.P.45(a) Committee Note (2013)

…

## **Request for Production of Documents**

## **I. INSTRUCTIONS**

2. Electronically stored information must be produced in accordance with the

following instructions:

name of the native file. The native file must be named after the FIRSTBATES.

Date fields should be provided in the format: mm/dd/yyyy. Date and time fields must be two separate fields. Required metadata listed below:

| Field Name | Sample Data | Description | |--------------|--------------------------|----------------------------------------------------------------------------------------------| | FIRSTBATES | EDC0000001 | First Bates number of native file document/email | | LASTBATES | EDC0000001 | Last Bates number of native file document/email **The LASTBATES field should be populated | | | | for single page | | ATTACHRANGE | EDC0000001 - | Bates number of the first page of the parent | | | EDC0000015 | document to the Bates number of the last page of | | | | the last attachment "child" document | | BEGATTACH | EDC0000001 | First Bates number of attachment range | | ENDATTACH | EDC0000015 | Last Bates number of attachment range | | CUSTODIAN | Smith, John | Email: Mailbox where the email resided | | | | Native: Name of the individual or department | | | | from whose files the document originated | | FROM | John Smith | Email: Sender | | | | Native: Author(s) of document | | | | **semi-colon should be used to separate | | | | multiple entries | | TO | Coffman, Janice; LeeW | Recipient(s) | | | [mailto:LeeW@MSN.com] | **semi-colon should be used to separate multiple | | | | entries | | CC | Frank Thompson [mailto: | Carbon copy recipient(s) | | | frank_Thompson@cdt.com] | **semi-colon should be used to separate | | | | multiple entries | | BCC | John Cain | Blind carbon copy recipient(s) | | | | **semi-colon should be used to separate | | | | multiple entries | | SUBJECT | Board Meeting Minutes | Email: Subject line of the email Native: Title | | | | of document (if available) | | FILE_NAME | BoardMeetingMinutes.docx | Native: Name of the original native file, | | | | including extension | | DATE_SENT | 10/12/2010 | Email: Date the email was sent | | | | Native: (empty) | | TIME_SENT/ | 07:05 PM GMT | Email: Time the email was sent/ Time zone in | | TIME_ZONE | | which the emails were standardized | | TIME_ZONE | GMT | The time zone in which the emails were | | | | standardized during conversion. | | LINK | EDC0000001.msg | Hyperlink to the email or native file document | | | | **The linked file must be named per the | | | | FIRSTBATES number | | FILE_EXTEN | MSG | The file type extension | | | | representing | | | | the Email or | | AUTHOR | John Smith | Email: (empty) | | | | Native: Author of the document | | DATE_CREATED | 10/10/2010 | Email: (empty) | | | | Native: Date the document was created |

| TIME_CREATED | 10:25 AM | Email: (empty) | |--------------|---------------------------|-------------------------------------------------| | | | | | | | Native: Time the document was created | | | | **This data must be a separate field and cannot | | | | be combined with the DATE_CREATED field | | DATE_MOD | 10/12/2010 | Email: (empty) | | | | Native: Date the document was last modified | | TIME_MOD | 07:00 PM | Email: (empty) | | | | Native: Time the document was last modified | | | | **This data must be a separate field and cannot | | | | be combined with the DATE_MOD field | | DATE_ACCESSD | 10/12/2010 | Email: (empty) | | | | Native: Date the document was last accessed | | TIME_ACCESSD | 07:00 PM | Email: (empty) | | | | Native: Time the document was last accessed | | | | **This data must be a separate field and cannot | | | | be combined with the DATE_ACCESSD field | | FILE_SIZE | 5,952 | Size of native file document/email in KB | | PGCOUNT | 1 | Number of pages in native file document/email | | PATH | | Email: (empty) | | | Agenda.doc | Native: Path where native file document was | | | | stored including original file name. | | INTFILEPATH | Personal Folders\Deleted | Email: original location of email including | | | Items\Board Meeting | original file name. | | | Minutes.msg | Native: (empty) | | INTMSGID | <000805c2c71b\$75977050\$ | Email: Unique Message ID Native: (empty) | | | cb8306d1@MSN> | | | MD5HASH | d131dd02c5e6eec4693d9a0 | MD5 Hash value of the document. | | | 698aff95c | | | | 2fcab58712467eab4004583e | | | | b8fb7f89 | | | OCRPATH | TEXT/001/EDC0000001.txt | Path to extracted text of the native file |

3. Each Request operates and should be construed independently and, unless otherwise indicated, no Request limits the scope of any other Request.

4. All Documents are to be produced as kept in the usual course of business or are to be organized and labeled to correspond with the categories in these Requests.

5. Each Request contained herein extends to all Documents: (a) in Your possession, custody, or control; or (b) in the possession, custody, or control of anyone acting on Your behalf,

## Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 83 of 439

including Your counsel or other representatives and advisors. Each Document shall be produced in its entirety.

## Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 84 of 439

12. All references to Entities includes all affiliates thereof.

13. All references to individual names include all alternative names, aliased, or nicknames.

14. Unless otherwise expressly indicated, the period of time covered by the Document Requests is the period from February 5, 2012 to the date responses to the Document Requests are due.

## **II. RULES OF CONSTRUCTION**

15. The use of (a) any singular noun shall be construed to include the plural, and vice versa, and (b) a verb in any tense shall be construed as the use of the verb in all other tenses.

## **III. DEFINITIONS**

1. "You" or "Your" or "Yourself" means and refers, to PayrNet Limited, together with all of its affiliates, divisions, agencies, instrumentalities, departments, offices, partners, officers, directors, agents, attorneys, representatives, employees, and/or anyone acting on its behalf.

## Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 86 of 439

3. "Debtor's Son" means Qiang Guo (a/k/a Mileson Kwok, 郭强, or any other alias), together with his employees, agents, counsel, advisors, or anyone acting on his behalf.

4. "Debtor's Daughter" means Mei Guo (a/k/a Mei Gui, 郭美, or any other alias), together with her employees, agents, counsel, advisors, or anyone acting on her behalf.

6. "Debtor's Family" means, individually and collectively, the Debtor, the Debtor's Son, the Debtor's Daughter, and the Debtor's Purported Wife, and any other familial relation to the Debtor.

## Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 87 of 439

LLC, G Club US Operations Inc., G Club US Operations LLC, G Club, G Club One, G Club Two, G Club Three, G Live, LLC, Gbroadcast, LLC, GM 27 LLC, Gladys Chow, Golden Spring (New York) Ltd., Gposts LLC, GTV Media Group, Inc., Gypsy Mei Food Service LLC, Gypsy Mei Productions LLC, Gypsy Mei 27 Vestry, Inc., Dawn State Limited, Greenwich Land LLC, Hao (Gavin) Li (a/k/a Huo Lai), Haitham Khaled, Hamilton Capital Holdings Inc., Hamilton Digital Assets Funds SP, Hamilton Investment Management Limited, Hamilton Opportunity Fund SPC, Hamilton PE Funds SP, Holy City Hong Kong Ventures Ltd., GS Security Solutions Inc., Alex Hadjcharalambous, Han Chunguang, Haoran He, HCHK Property Management, Inc., HCHK Technologies, Inc., HK International Funds Investments (USA) Limited LLC, Freedom Media Ventures Ltd., FungWan Trading Inc., Himalaya Currency Clearing Pty. Ltd., Himalaya New World Inc., Himalaya International Financial Group Ltd., Himalaya International Clearing Ltd., Himalaya International Payments Ltd., Himalaya International Reserves Ltd., Himalaya Ventures LLC, Himalaya Investment LLC, Hudson Diamond Holding, Inc., Hudson Diamond Holding LLC, Hudson Diamond NY LLC, Huk Trading Inc., Infinity Treasury Management Inc., Jesse Brown, Jessica Mastrogiovanni, Jiaming Liu, Jie Zhang, Jovial Century International Limited, Joyord Sportswear Limited, K Legacy Ltd., Kamel Debeche, Karin Maistrello, Kin Ming Je, Lamp Capital LLC, Lawall & Mitchell, LLC, Leading Shine NY Ltd., Lexington Property and Staffing, Inc., Lexington Property and Staffing LLC, Linwan "Irene" Feng, Limarie Reyes, Lihong "Sara" Wei Lafrenz, The Lost Draft LLC, Macaron Limited, Major Lead International Limited, Mary Jiang, MOS Himalaya LLC, Maywind Trading LLC, New York MOS Himalaya LLC, Next Tycoon Investments Limited, Nicholas Savio, Nodal Partners, LLC, Qidong Xia, Oasis Tech Limited, O.S.C. Orbit Service Company, LLC, Pixshow Film Inc., Qu Guo Jiao, Roscalitar 2, Ridwan Mamode Saib, Ross Heinemeyer, Rule of Law Society IV Inc., Rule of Law Foundation

## Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 88 of 439

III, Inc., Rule of Law Fund, Saraca Media Group Inc., Savio Law LLC, Scott Barnett, Seven Mission Group LLC, Shih Hsin Yu, Sirius Networking Inc., Taurus Fund LLC, Taurus Management LLC, US Himalaya Capital Inc., V.X. Cerda & Associates P.A., Victor Cerda, Voice of Guo Media, Inc., Wen Xiao, Wencong Wang, William Je, Kin Ming Je a/k/a Je Kin Ming, Wise Creation International Limited, Xuebing Wang, Yan Chun Liu, Yinying (Aila) Wang (a/k/a Xiao Fei Xiang), Yongbing Zhang, Yongping Yan (Shan Mu) Yue Zhou, Yumei Hao (a/k/a Ru Shui), Yvette Wang (a/k/a Yanping Wang, a/k/a Yan Ping Wang), Zhixuan Li, Zhouer "Joe" Wang, NewPeople LLC, Ziba Limited, New Mulberry PTE Ltd, TD Primrose Limited, and Shin Hee-Seup a/k/a Hee Seup Shin.

8. "Including" or any variant thereof means "including without limitation."

9. "And" and "or" mean "and/or," and shall be construed both conjunctively as well as disjunctively in order to maximize their scope.

10. "Any" and "all" and "each" mean "each and every."

11. "Each" and "every" mean "each and every."

12. "Third Party" means a Person or Entity other than Yourself.

13. "Transfer" shall have the meaning given to it by section 101(54) of the Bankruptcy Code.

## Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 89 of 439

charts, blueprints, drawings, sketches, graphs, plans, articles, specifications, diaries, letters, telegrams, photographs, minutes, contracts, agreements, surveys, computer printouts, data compilations of any kind, telexes, facsimiles, emails, text messages, instant messages, voice messages, invoices, order forms, checks, drafts, statements, credit memos, reports, position reports, summaries, indices, books, ledgers, notebooks, schedules, transparencies, recordings, catalogs, advertisements, promotional materials, films, video tapes, audio tapes, CDs, computer disks, brochures, pamphlets, punch-cards, time-slips, Tweets, social media posts, or any written or recorded materials of any other kind, and all meta-data thereof, however stored (whether in tangible or electronic form), recorded, produced, or reproduced, and also including but not limited to, drafts or copies of any of the foregoing that contain any notes, comments, or markings of any kind not found on the original documents or that are otherwise not identical to the original documents.

## Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 90 of 439

connected with, commenting on, in respect of, about, in relation to, discussing, showing, describing, reflecting, analyzing constituting, and being.

## **IV. DOCUMENTS TO BE PRODUCED**

1. All Documents related to any account held by, controlled by, on behalf of, or otherwise related to any of the 2004 Discovery Targets, including any and all account statements,

## Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 91 of 439

authorizations, power of attorney, trusts, instructions or forms, copies of cancelled checks, correspondence, and wire transfers and related correspondence and instructions.

5. All Documents related to any correspondence and communications between you and the 2004 Discovery Targets.

6. All Documents related to any account with any 2004 Discovery Target relating to opening of the account, authorized users of the account and maintenance of the account.

## Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 92 of 439

# Exhibit C-5

#### B2540 (Form 2540 – Subpoena for Rule 2004 Examination) (12/15) Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 94 of

439

UNITED STATES BANKRUPTCY COURT

**District of Connecticut**

In re HO WAN KWOK, *et al*.,

1 Case No. 22-50073 (JAM) Debtor Chapter 11

(Jointly Administered)

# **SUBPOENA FOR RULE 2004 EXAMINATION**

To: **Revolut Ltd.**

(*Name of person to whom the subpoena is directed*)

| PLACE | DATE AND TIME | |-------|---------------| | N/A | N/A | | | |

The examination will be recorded by this method: N/A

## **See Requests for Production of Documents, attached hereto.**

Date: **May , 2024**

CLERK OF COURT

*Signature of Clerk or Deputy Clerk Attorney's signature*

The name, address, email address, and telephone number of the attorney representing Luc A. Despins, Chapter 11 Trustee, who issues or requests this subpoena, are:

**Patrick R. Linsey, Esq.; Neubert, Pepe & Monteith, P.C.; 195 Church Street, 13th Floor, New Haven, Connecticut 06510 plinsey@npmlaw.com; (203) 781-2847**

## **Notice to the person who issues or requests this subpoena**

## **PROOF OF SERVICE**

**(This section should not be filed with the court unless required by Fed. R. Civ. P. 45.)**

I received this subpoena for (*name of individual and title, if any*): on (*date*) .

I served the subpoena by delivering a copy to the named person as follows:

on *(date)* ; or

I returned the subpoena unexecuted because:

My fees are \$ for travel and \$ for services, for a total of \$ .

I declare under penalty of perjury that this information is true and correct.

Date:

*Server's signature*

*Printed name and title*

*Server's address*

Additional information concerning attempted service, etc.:

## **Federal Rule of Civil Procedure 45(c), (d), (e), and (g) (Effective 12/1/13) (made applicable in bankruptcy cases by Rule 9016, Federal Rules of Bankruptcy Procedure)**

#### **(c) Place of compliance.**

*(1) For a Trial, Hearing, or Deposition.* A subpoena may command a person to attend a trial, hearing, or deposition only as follows:

(A) within 100 miles of where the person resides, is employed, or regularly transacts business in person; or

(B) within the state where the person resides, is employed, or regularly transacts business in person, if the person

(i) is a party or a party's officer; or

(ii) is commanded to attend a trial and would not incur substantial expense.

*(2) For Other Discovery.* A subpoena may command:

(A) production of documents, or electronically stored information, or things at a place within 100 miles of where the person resides, is employed, or regularly transacts business in person; and

(B) inspection of premises, at the premises to be inspected.

## **(d) Protecting a Person Subject to a Subpoena; Enforcement.**

## *(2) Command to Produce Materials or Permit Inspection.*

(i) At any time, on notice to the commanded person, the serving party may move the court for the district where compliance is required for an order compelling production or inspection.

(ii) These acts may be required only as directed in the order, and the order must protect a person who is neither a party nor a party's officer from significant expense resulting from compliance.

## *(3) Quashing or Modifying a Subpoena.*

*(A) When Required.* On timely motion, the court for the district where compliance is required must quash or modify a subpoena that:

(i) fails to allow a reasonable time to comply;

(ii) requires a person to comply beyond the geographical limits specified in Rule 45(c);

(iii) requires disclosure of privileged or other protected matter, if no exception or waiver applies; or

(iv) subjects a person to undue burden.

*(B) When Permitted.* To protect a person subject to or affected by a subpoena, the court for the district where compliance is required may, on motion, quash or modify the subpoena if it requires:

(i) disclosing a trade secret or other confidential research, development, or commercial information; or

(ii) disclosing an unretained expert's opinion or information that does not describe specific occurrences in dispute and results from the expert's study that was not requested by a party.

(i) shows a substantial need for the testimony or material that cannot be otherwise met without undue hardship; and

(ii) ensures that the subpoenaed person will be reasonably compensated.

#### **(e) Duties in Responding to a Subpoena.**

*(1) Producing Documents or Electronically Stored Information.* These procedures apply to producing documents or electronically stored information:

*(C) Electronically Stored Information Produced in Only One Form.* The person responding need not produce the same electronically stored information in more than one form.

#### *(2) Claiming Privilege or Protection.*

For access to subpoena materials, see Fed.R.Civ.P.45(a) Committee Note (2013)

…

## **Request for Production of Documents**

## **I. INSTRUCTIONS**

2. Electronically stored information must be produced in accordance with the

following instructions:

name of the native file. The native file must be named after the FIRSTBATES.

Date fields should be provided in the format: mm/dd/yyyy. Date and time fields must be two separate fields. Required metadata listed below:

# Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 100 of 439

| TIME_CREATED | 10:25 AM | Email: (empty) | |--------------|---------------------------|-------------------------------------------------| | | | Native: Time the document was created | | | | **This data must be a separate field and cannot | | | | be combined with the DATE_CREATED field | | DATE_MOD | 10/12/2010 | Email: (empty) | | | | | | | | Native: Date the document was last modified | | TIME_MOD | 07:00 PM | Email: (empty) | | | | Native: Time the document was last modified | | | | **This data must be a separate field and cannot | | | | be combined with the DATE_MOD field | | DATE_ACCESSD | 10/12/2010 | Email: (empty) | | | | Native: Date the document was last accessed | | TIME_ACCESSD | 07:00 PM | Email: (empty) | | | | Native: Time the document was last accessed | | | | **This data must be a separate field and cannot | | | | be combined with the DATE_ACCESSD field | | FILE_SIZE | 5,952 | Size of native file document/email in KB | | PGCOUNT | 1 | Number of pages in native file document/email | | PATH | | Email: (empty) | | | Agenda.doc | Native: Path where native file document was | | | | stored including original file name. | | INTFILEPATH | Personal Folders\Deleted | Email: original location of email including | | | Items\Board Meeting | original file name. | | | Minutes.msg | Native: (empty) | | INTMSGID | <000805c2c71b\$75977050\$ | Email: Unique Message ID Native: (empty) | | | cb8306d1@MSN> | | | MD5HASH | d131dd02c5e6eec4693d9a0 | MD5 Hash value of the document. | | | 698aff95c | | | | 2fcab58712467eab4004583e | | | | b8fb7f89 | | | OCRPATH | TEXT/001/EDC0000001.txt | Path to extracted text of the native file |

3. Each Request operates and should be construed independently and, unless otherwise indicated, no Request limits the scope of any other Request.

4. All Documents are to be produced as kept in the usual course of business or are to be organized and labeled to correspond with the categories in these Requests.

5. Each Request contained herein extends to all Documents: (a) in Your possession, custody, or control; or (b) in the possession, custody, or control of anyone acting on Your behalf,

## Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 101 of 439

including Your counsel or other representatives and advisors. Each Document shall be produced in its entirety.

## Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 102 of 439

12. All references to Entities includes all affiliates thereof.

13. All references to individual names include all alternative names, aliased, or nicknames.

14. Unless otherwise expressly indicated, the period of time covered by the Document Requests is the period from February 5, 2012 to the date responses to the Document Requests are due.

## **II. RULES OF CONSTRUCTION**

15. The use of (a) any singular noun shall be construed to include the plural, and vice versa, and (b) a verb in any tense shall be construed as the use of the verb in all other tenses.

## **III. DEFINITIONS**

1. "You" or "Your" or "Yourself" means and refers, to Revolut Ltd., together with all of its affiliates, divisions, agencies, instrumentalities, departments, offices, partners, officers, directors, agents, attorneys, representatives, employees, and/or anyone acting on its behalf.

## Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 104 of 439

3. "Debtor's Son" means Qiang Guo (a/k/a Mileson Kwok, 郭强, or any other alias), together with his employees, agents, counsel, advisors, or anyone acting on his behalf.

4. "Debtor's Daughter" means Mei Guo (a/k/a Mei Gui, 郭美, or any other alias), together with her employees, agents, counsel, advisors, or anyone acting on her behalf.

6. "Debtor's Family" means, individually and collectively, the Debtor, the Debtor's Son, the Debtor's Daughter, and the Debtor's Purported Wife, and any other familial relation to the Debtor.

## Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 105 of 439

## Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 106 of 439

8. "Including" or any variant thereof means "including without limitation."

9. "And" and "or" mean "and/or," and shall be construed both conjunctively as well as disjunctively in order to maximize their scope.

10. "Any" and "all" and "each" mean "each and every."

11. "Each" and "every" mean "each and every."

12. "Third Party" means a Person or Entity other than Yourself.

13. "Transfer" shall have the meaning given to it by section 101(54) of the Bankruptcy Code.

## Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 107 of 439

## Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 108 of 439

connected with, commenting on, in respect of, about, in relation to, discussing, showing, describing, reflecting, analyzing constituting, and being.

## **IV. DOCUMENTS TO BE PRODUCED**

1. All Documents related to any account held by, controlled by, on behalf of, or otherwise related to any of the 2004 Discovery Targets, including any and all account statements,

## Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 109 of 439

authorizations, power of attorney, trusts, instructions or forms, copies of cancelled checks, correspondence, and wire transfers and related correspondence and instructions.

5. All Documents related to any correspondence and communications between you and the 2004 Discovery Targets.

6. All Documents related to any account with any 2004 Discovery Target relating to opening of the account, authorized users of the account and maintenance of the account.

## Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 110 of 439

Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 111 of 439

# Exhibit C-6

#### B2540 (Form 2540 – Subpoena for Rule 2004 Examination) (12/15) Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 112 of

439

UNITED STATES BANKRUPTCY COURT

**District of Connecticut**

In re HO WAN KWOK, *et al*.,

1 Case No. 22-50073 (JAM) Debtor Chapter 11

(Jointly Administered)

# **SUBPOENA FOR RULE 2004 EXAMINATION**

## To: **CIMN Bank Berhad a/k/a CIMB Islamic Bank Berhad**

(*Name of person to whom the subpoena is directed*)

| PLACE | DATE AND TIME | |-------|---------------| | N/A | N/A | | | |

The examination will be recorded by this method: N/A

## **See Requests for Production of Documents, attached hereto.**

Date: **May , 2024**

CLERK OF COURT

*Signature of Clerk or Deputy Clerk Attorney's signature*

The name, address, email address, and telephone number of the attorney representing Luc A. Despins, Chapter 11 Trustee, who issues or requests this subpoena, are:

**Patrick R. Linsey, Esq.; Neubert, Pepe & Monteith, P.C.; 195 Church Street, 13th Floor, New Haven, Connecticut 06510 plinsey@npmlaw.com; (203) 781-2847**

## **Notice to the person who issues or requests this subpoena**

## **PROOF OF SERVICE**

**(This section should not be filed with the court unless required by Fed. R. Civ. P. 45.)**

I received this subpoena for (*name of individual and title, if any*): on (*date*) .

I served the subpoena by delivering a copy to the named person as follows:

on *(date)* ; or

I returned the subpoena unexecuted because:

My fees are \$ for travel and \$ for services, for a total of \$ .

I declare under penalty of perjury that this information is true and correct.

Date:

*Server's signature*

*Printed name and title*

*Server's address*

Additional information concerning attempted service, etc.:

## **Federal Rule of Civil Procedure 45(c), (d), (e), and (g) (Effective 12/1/13) (made applicable in bankruptcy cases by Rule 9016, Federal Rules of Bankruptcy Procedure)**

#### **(c) Place of compliance.**

*(1) For a Trial, Hearing, or Deposition.* A subpoena may command a person to attend a trial, hearing, or deposition only as follows:

(A) within 100 miles of where the person resides, is employed, or regularly transacts business in person; or

(B) within the state where the person resides, is employed, or regularly transacts business in person, if the person

(i) is a party or a party's officer; or

(ii) is commanded to attend a trial and would not incur substantial expense.

*(2) For Other Discovery.* A subpoena may command:

(A) production of documents, or electronically stored information, or things at a place within 100 miles of where the person resides, is employed, or regularly transacts business in person; and

(B) inspection of premises, at the premises to be inspected.

## **(d) Protecting a Person Subject to a Subpoena; Enforcement.**

## *(2) Command to Produce Materials or Permit Inspection.*

(i) At any time, on notice to the commanded person, the serving party may move the court for the district where compliance is required for an order compelling production or inspection.

(ii) These acts may be required only as directed in the order, and the order must protect a person who is neither a party nor a party's officer from significant expense resulting from compliance.

## *(3) Quashing or Modifying a Subpoena.*

*(A) When Required.* On timely motion, the court for the district where compliance is required must quash or modify a subpoena that:

(i) fails to allow a reasonable time to comply;

(ii) requires a person to comply beyond the geographical limits specified in Rule 45(c);

(iii) requires disclosure of privileged or other protected matter, if no exception or waiver applies; or

(iv) subjects a person to undue burden.

*(B) When Permitted.* To protect a person subject to or affected by a subpoena, the court for the district where compliance is required may, on motion, quash or modify the subpoena if it requires:

(i) disclosing a trade secret or other confidential research, development, or commercial information; or

(ii) disclosing an unretained expert's opinion or information that does not describe specific occurrences in dispute and results from the expert's study that was not requested by a party.

(i) shows a substantial need for the testimony or material that cannot be otherwise met without undue hardship; and

(ii) ensures that the subpoenaed person will be reasonably compensated.

#### **(e) Duties in Responding to a Subpoena.**

*(1) Producing Documents or Electronically Stored Information.* These procedures apply to producing documents or electronically stored information:

*(C) Electronically Stored Information Produced in Only One Form.* The person responding need not produce the same electronically stored information in more than one form.

#### *(2) Claiming Privilege or Protection.*

For access to subpoena materials, see Fed.R.Civ.P.45(a) Committee Note (2013)

…

## **Request for Production of Documents**

## **I. INSTRUCTIONS**

2. Electronically stored information must be produced in accordance with the

following instructions:

name of the native file. The native file must be named after the FIRSTBATES.

Date fields should be provided in the format: mm/dd/yyyy. Date and time fields must be two separate fields. Required metadata listed below:

# Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 117 of 439

# Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 118 of 439

3. Each Request operates and should be construed independently and, unless otherwise indicated, no Request limits the scope of any other Request.

4. All Documents are to be produced as kept in the usual course of business or are to be organized and labeled to correspond with the categories in these Requests.

5. Each Request contained herein extends to all Documents: (a) in Your possession, custody, or control; or (b) in the possession, custody, or control of anyone acting on Your behalf,

## Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 119 of 439

including Your counsel or other representatives and advisors. Each Document shall be produced in its entirety.

## Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 120 of 439

12. All references to Entities includes all affiliates thereof.

13. All references to individual names include all alternative names, aliased, or nicknames.

14. Unless otherwise expressly indicated, the period of time covered by the Document Requests is the period from February 5, 2012 to the date responses to the Document Requests are due.

## **II. RULES OF CONSTRUCTION**

15. The use of (a) any singular noun shall be construed to include the plural, and vice versa, and (b) a verb in any tense shall be construed as the use of the verb in all other tenses.

## **III. DEFINITIONS**

1. "You" or "Your" or "Yourself" means and refers, to CIMN Bank Berhad (a/k/a CIMB Islamic Bank Berhad), together with all of its affiliates, divisions, agencies, instrumentalities, departments, offices, partners, officers, directors, agents, attorneys, representatives, employees, and/or anyone acting on its behalf.

## Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 122 of 439

3. "Debtor's Son" means Qiang Guo (a/k/a Mileson Kwok, 郭强, or any other alias), together with his employees, agents, counsel, advisors, or anyone acting on his behalf.

4. "Debtor's Daughter" means Mei Guo (a/k/a Mei Gui, 郭美, or any other alias), together with her employees, agents, counsel, advisors, or anyone acting on her behalf.

6. "Debtor's Family" means, individually and collectively, the Debtor, the Debtor's Son, the Debtor's Daughter, and the Debtor's Purported Wife, and any other familial relation to the Debtor.

## Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 123 of 439

## Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 124 of 439

8. "Including" or any variant thereof means "including without limitation."

9. "And" and "or" mean "and/or," and shall be construed both conjunctively as well as disjunctively in order to maximize their scope.

10. "Any" and "all" and "each" mean "each and every."

11. "Each" and "every" mean "each and every."

12. "Third Party" means a Person or Entity other than Yourself.

13. "Transfer" shall have the meaning given to it by section 101(54) of the Bankruptcy Code.

14. "Document" means any information or thing within the scope of Fed. R. Civ. P. 34, and includes, without limitation, each and every written, recorded, or graphic matter of any kind,

## Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 125 of 439

## Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 126 of 439

## **IV. DOCUMENTS TO BE PRODUCED**

5. All Documents related to any correspondence and communications between you and the 2004 Discovery Targets.

6. All Documents related to any account with any 2004 Discovery Target relating to opening of the account, authorized users of the account and maintenance of the account.

## Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 128 of 439

Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 129 of 439

# Exhibit C-7

#### B2540 (Form 2540 – Subpoena for Rule 2004 Examination) (12/15) Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 130 of

439

UNITED STATES BANKRUPTCY COURT

**District of Connecticut**

In re HO WAN KWOK, *et al*.,

1 Case No. 22-50073 (JAM) Debtor Chapter 11

(Jointly Administered)

# **SUBPOENA FOR RULE 2004 EXAMINATION**

To: **Evan Cramer**

(*Name of person to whom the subpoena is directed*)

| PLACE | DATE AND TIME | |-------|---------------| | N/A | N/A | | | |

The examination will be recorded by this method: N/A

## **See Requests for Production of Documents, attached hereto.**

Date: **May , 2024**

CLERK OF COURT

*Signature of Clerk or Deputy Clerk Attorney's signature*

The name, address, email address, and telephone number of the attorney representing Luc A. Despins, Chapter 11 Trustee, who issues or requests this subpoena, are:

**Patrick R. Linsey, Esq.; Neubert, Pepe & Monteith, P.C.; 195 Church Street, 13th Floor, New Haven, Connecticut 06510 plinsey@npmlaw.com; (203) 781-2847**

## **Notice to the person who issues or requests this subpoena**

## **PROOF OF SERVICE**

**(This section should not be filed with the court unless required by Fed. R. Civ. P. 45.)**

I received this subpoena for (*name of individual and title, if any*): on (*date*) .

I served the subpoena by delivering a copy to the named person as follows:

on *(date)* ; or

I returned the subpoena unexecuted because:

My fees are \$ for travel and \$ for services, for a total of \$ .

I declare under penalty of perjury that this information is true and correct.

Date:

*Server's signature*

*Printed name and title*

*Server's address*

Additional information concerning attempted service, etc.:

## **Federal Rule of Civil Procedure 45(c), (d), (e), and (g) (Effective 12/1/13) (made applicable in bankruptcy cases by Rule 9016, Federal Rules of Bankruptcy Procedure)**

#### **(c) Place of compliance.**

*(1) For a Trial, Hearing, or Deposition.* A subpoena may command a person to attend a trial, hearing, or deposition only as follows:

(A) within 100 miles of where the person resides, is employed, or regularly transacts business in person; or

(B) within the state where the person resides, is employed, or regularly transacts business in person, if the person

(i) is a party or a party's officer; or

(ii) is commanded to attend a trial and would not incur substantial expense.

*(2) For Other Discovery.* A subpoena may command:

(A) production of documents, or electronically stored information, or things at a place within 100 miles of where the person resides, is employed, or regularly transacts business in person; and

(B) inspection of premises, at the premises to be inspected.

## **(d) Protecting a Person Subject to a Subpoena; Enforcement.**

## *(2) Command to Produce Materials or Permit Inspection.*

(i) At any time, on notice to the commanded person, the serving party may move the court for the district where compliance is required for an order compelling production or inspection.

(ii) These acts may be required only as directed in the order, and the order must protect a person who is neither a party nor a party's officer from significant expense resulting from compliance.

## *(3) Quashing or Modifying a Subpoena.*

*(A) When Required.* On timely motion, the court for the district where compliance is required must quash or modify a subpoena that:

(i) fails to allow a reasonable time to comply;

(ii) requires a person to comply beyond the geographical limits specified in Rule 45(c);

(iii) requires disclosure of privileged or other protected matter, if no exception or waiver applies; or

(iv) subjects a person to undue burden.

*(B) When Permitted.* To protect a person subject to or affected by a subpoena, the court for the district where compliance is required may, on motion, quash or modify the subpoena if it requires:

(i) disclosing a trade secret or other confidential research, development, or commercial information; or

(ii) disclosing an unretained expert's opinion or information that does not describe specific occurrences in dispute and results from the expert's study that was not requested by a party.

(i) shows a substantial need for the testimony or material that cannot be otherwise met without undue hardship; and

(ii) ensures that the subpoenaed person will be reasonably compensated.

#### **(e) Duties in Responding to a Subpoena.**

*(1) Producing Documents or Electronically Stored Information.* These procedures apply to producing documents or electronically stored information:

*(C) Electronically Stored Information Produced in Only One Form.* The person responding need not produce the same electronically stored information in more than one form.

#### *(2) Claiming Privilege or Protection.*

For access to subpoena materials, see Fed.R.Civ.P.45(a) Committee Note (2013)

…

## **Requests for Production of Documents**

## **I. INSTRUCTIONS**

2. Electronically stored information must be produced in accordance with the

following instructions:

name of the native file. The native file must be named after the FIRSTBATES.

Date fields should be provided in the format: mm/dd/yyyy. Date and time fields must be two separate fields. Required metadata listed below:

# Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 135 of 439

# Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 136 of 439

3. Each Request operates and should be construed independently and, unless otherwise indicated, no Request limits the scope of any other Request.

4. All Documents are to be produced as kept in the usual course of business or are to be organized and labeled to correspond with the categories in these Requests.

5. Each Request contained herein extends to all Documents: (a) in Your possession, custody, or control; or (b) in the possession, custody, or control of anyone acting on Your behalf,

## Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 137 of 439

including Your counsel or other representatives and advisors. Each Document shall be produced in its entirety.

## Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 138 of 439

12. All references to Entities includes all affiliates thereof.

13. All references to individual names include all alternative names, aliased, or nicknames.

14. Unless otherwise expressly indicated, the period of time covered by the Document Requests is the period from February 5, 2012 to the date responses to the Document Requests are due.

## **II. RULES OF CONSTRUCTION**

15. The use of (a) any singular noun shall be construed to include the plural, and vice versa, and (b) a verb in any tense shall be construed as the use of the verb in all other tenses.

## **III. DEFINITIONS**

1. "You" or "Your" or "Yourself" means and refers to Evan Cramer, together with all of their agents, attorneys, representatives, employees, and/or anyone acting on their behalf.

3. "Debtor's Son" means Qiang Guo (a/k/a Mileson Kwok, 郭强, or any other alias), together with his employees, agents, counsel, advisors, or anyone acting on his behalf.

4. "Debtor's Daughter" means Mei Guo (a/k/a Mei Gui, 郭美, or any other alias), together with her employees, agents, counsel, advisors, or anyone acting on her behalf.

## Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 140 of 439

6. "Debtor's Family" means, collectively, the Debtor, the Debtor's Son, the Debtor's Daughter, and the Debtor's Purported Wife, and any other familial relation to the Debtor.

7. "Associated Individuals" means individually and collectively, all individuals that (1) hold, control, have custody over, or discretion over assets owned, controlled, or enjoyed by the Debtor or the Debtor's Family; or (2) have been employees, directors, or otherwise are affiliated with one or more Associated Entities, together with the respective employees, agents, counsel, advisors, or anyone acting on behalf of any of the foregoing. Such Associated Individuals shall include, but are not limited to: Anthony DiBattista, Alex Hadjicharalambous, Bernardo Enriquez, Bingshang Jiao, Beile Li, Brian W. Hofmeister, Charles Gruder, Daniel Podhaskie, David Fallon, Defeng Cao (a/k/a Wayne Cao, Max Cao), Ding Lin, Dinggang Wang (a/k/a 王定刚), Eduardo Eurnekian, Ehsan Masud, Fiona Yu, Gladys Chow, Hao (Gavin) Li (a/k/a Huo Lai), Hao Haidong (a/k/a 郝海东), Han Chunguang (a/k/a 韩春光), Haoran He, Ivan Lin, Haitham Khaled, Jason Miller, Jennifer Mercurio, Jesse Brown, Jessica Mastrogiovanni, Jie Zhang, Jintao Li, Karin Maistrello, Kyle Bass, Lihong Wei Lafrenz (a/k/a Sara Wei, 魏丽红), Linwan "Irene" Feng, Max Krasner, Melissa Francis, Michael Baranowitz, Min Yang, Melissa Mendez, Nadeem Akbar, Nan Li (a/k/a Chris Lee, Mei Guo Xiao Li), Qidong Xia, Qu Guojiao (a/k/a Qu Guo Jiao, 屈国姣), Ridwan Mamode Saib, Ross Heinemeyer, Rui "Ray" Hao, Scott Barnett, Shih Hsin Yu, Shin Hee-Seup (a/k/a Hee Seup Shin), Steve Bannon, Talha Zobair, Victor Cerda, Wen Xiao, Wencong Wang, William Gertz, William Je (a/k/a Je Kin Ming, Yu Jianming, 余建明), and Xuebing Wang,

## Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 141 of 439

Ya Li (a/k/a 李娅), Yinying (Aila) Wang (a/k/a Xiao Fei Xiang), Yongping Yan (Shan Mu), Yong Yu, Yue Zhou, Yumei Hao (a/k/a Ru Shui), Yvette Wang (a/k/a Yanping Wang, Yan Ping Wang, 王雁平), Zhang Wei (a/k/a 张魏), Zhouer Wang (a/k/a Joe Wang), Zhixuan Li, and Ziyang Liu.

8. "Associated Entities" means, individually and collectively, all organizations or Entities of any type that (1) have been owned, controlled, or invested in by the Debtor or the Debtor's Family; or (2) have an interest, whether directly or indirectly, in any assets owned, controlled, or enjoyed by the Debtor or the Debtor's Family, together with the respective employees, agents, counsel, advisors, or anyone acting on behalf of any of the foregoing. Such Associated Entities shall include, but are not limited to: 1332156 B.C. Ltd., 7 Nod Hill LLC, AAGV Limited, ACA Investment Management Limited, ACA Capital Group Limited, Ace Decade Holdings Limited, AI Group Holdings Inc., Alfa Global Ventures Limited, Alfonso Global Limited, Allied Capital Global Limited, Alpine Fiduciaries SA, Beijing Pangu Investment Co., Beijing Pangu Investment Co. Ltd., Beijing Pangu Investment Inc., Beijing Zenith Holdings Company Limited, Blue Capital Limited, Booming Sail New York LLC, Bravo Luck Limited, Brent Petro, BSA Strategic Fund I, China Golden Spring (Hong Kong) Limited, Chuang Xin Limited, Crane Advisory Group LLC, Creative Apex Investments Limited, Crystal Breeze Investments Limited, Dawn State Limited, Eastern Profit Corporation Limited, Empire Growth Holdings, Elite Well Global Limited, Freedom Media Ventures Ltd., Fung Wan Trading Inc., G Club, G Club Operations LLC, G Club International Limited, G Club Investments Limited, G Fashion LLC, G-News Operations LLC, G News LLC, GMusic Inc., G-Services LLC, G-Translators PTY LTD, GETTR USA, Inc., Genever Holdings Corporation, Genever Holdings LLC, GFashion Media Group Inc., GFNY, Inc., Globalist International Limited, GNews Media Group Inc., Golden Spring (New York) Ltd., Guo Media, GTV Media Group, Inc., GWGOPNZ

## Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 142 of 439

Limited, GWGNZ Limited, Gypsy Mei Food Services, LLC, HCHK Property Management Inc., HCHK Technologies Inc., Hamilton Digital Assets FD SP, Hamilton Capital Holdings Inc., Hamilton Opportunity Fund SPC, Head Win Group Limited, Himalaya Embassy, Himalaya Exchange, Himalaya Federal Reserve, Himalaya International Financial Group Ltd., Himalaya Investment LLC, Himalaya (USA) Investment Management LLC, Himalaya New World Inc., Himalaya Supervisory Organization, Himalaya Ventures, Holy City Hong Kong Ventures, Ltd., Hudson Diamond Holding LLC, Hudson Diamond Holding Inc., Hudson Diamond NY LLC, HK International Funds Investments (USA) Limited LLC, Hong Kong International Funds Investments Limited, Huk Trading Inc, Infinite Increase Limited, Infinitum Developments Limited, Japan Himalaya League, Inc., Kalixun Trading Limited, Lamp Capital LLC, Leading Shine Limited, Leading Shine NY Limited, Lexington Property and Staffing Inc., Long Gate Limited, MOS Himalaya Foundation Inc., Maywind Trading LLC, New Federal State of China (a/k/a NFSC), New York MOS Himalaya LLC, New Mulberry PTE Ltd., Newpeople LLC, Noble Fame Global Limited, Pixshow Film Inc., Roscalitar 2, Rosy Acme Ventures Limited, Rule of Law Foundation III, Inc., Rule of Law Society, Rule of Law Society IV, Inc., Santel LLC, Saraca Media Group, Inc., Shiny Ace Ltd., Shiny Times Holdings Ltd., Stevenson, Wong & Co., Taurus Fund LLC, Taurus Fund SP, Taurus Management LLC, The Lost Draft LLC, TM Primrose Limited, UA Himalaya Inc., Voice of Guo Media, Inc., Well Origin Ltd., Wise Creation, Whitecroft Shore Limited, World Century Limited, Worldwide Opportunity Holdings Limited, and ZIBA Limited.

9. "Including" or any variant thereof means "including without limitation."

10. "And" and "or" mean "and/or," and shall be construed both conjunctively as well as disjunctively in order to maximize their scope.

## Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 143 of 439

11. "Any" and "all" and "each" mean "each and every."

12. "Each" and "every" mean "each and every."

13. "Third Party" means a Person or Entity other than Yourself.

14. "Transfer" shall have the meaning given to it by section 101(54) of the Bankruptcy Code.

15. "Document" means any information or thing within the scope of Fed. R. Civ. P. 34, and includes, without limitation, each and every written, recorded, or graphic matter of any kind, type, nature, or description that is or has been in Your Possession, Custody or Control, including all printed and electronic copies of electronic mail, computer files maintained in electronic form, electronic communication, text message, social media post, tweet, meta-data, correspondence, memoranda, tapes, stenographic or handwritten notes, written forms of any kind, charts, blueprints, drawings, sketches, graphs, plans, articles, specifications, diaries, letters, telegrams, photographs, minutes, contracts, agreements, surveys, computer printouts, data compilations of any kind, telexes, facsimiles, voice messages, invoices, order forms, checks, drafts, statements, credit memos, reports, position reports, summaries, indices, books, ledgers, notebooks, schedules, transparencies, recordings, catalogs, advertisements, promotional materials, films, video tapes, audio tapes, CDs, computer disks, brochures, pamphlets, punchcards, time-slips, Tweets, social media posts, or any written or recorded materials of any other kind, and all meta-data thereof, however stored (whether in tangible or electronic form), recorded, produced, or reproduced, and also including but not limited to, drafts or copies of any of the foregoing that contain any notes, comments, or markings of any kind not found on the original documents or that are otherwise not identical to the original documents.

## Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 144 of 439

16. "Person(s)" means an individual, corporation, proprietorship, partnership, association, or any other Entity. "Person" also includes any agent, representatives, or expert, including but not limiting to, attorneys or financial advisors.

17. "Entity" means any natural Person, corporation, partnership, subsidiary, sole proprietorship, firm, board, joint venture, association, agency, authority, commission or other business entity or juristic Person, as well as any affiliate, agent, parent including but not limited to legal counsel, financial advisors, or any other representative.

18. "Regarding" means concerning, describing, comprising, referring to, related to, supporting, favoring, opposing, bolstering, detracting from, located in, considered in connection with, bearing on, evidencing, indicating, reporting on, recording, alluding to, responding to, connected with, commenting on, in respect of, about, in relation to, discussing, showing, describing, reflecting, analyzing constituting, and being.

19. "Relating to," "relate(s) to" or "related to," when referring to any given subject matter, means, without limitation, any document that constitutes, comprises, involves, contains, embodies, reflects, identifies, states, refers directly or indirectly to, or is in any way relevant to the particular subject matter identified.

20. "Communication(s)" means, in the broadest possible sense, and without limitation, any transmittal of information or knowledge (in the form of facts, ideas, inquiries, or otherwise). Communication(s) further refers to all conversations, agreements, inquiries, or replies, whether in person, by telephone, in writing, or by means of electronic transmittal devices, and includes, but is not limited to, all correspondence, emails, recordings, transmittal slips, memoranda, telephone communications, voice messages, telegrams, telefaxes, telecopies,

## Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 145 of 439

telexes, instant messages, chats, text messages, telephonic notes, or notes transmitted internally or with third parties.

21. "Asset(s)" means any item that can be used to produce positive economic value, including but not limited to any resource with economic value that is owned, controlled or is for the benefit of an entity, that is expected to provide a future benefit, including but not limited to, all real and personal property, intangible property, investments, rights to invest or to future revenue, cash, bank accounts, commodities, securities, claims, total or partial control of an entity, and prospective economic opportunities

22. "Transfer" shall have the meaning given to it by section 101(54) of the Bankruptcy Code.

## **IV. DOCUMENTS TO BE PRODUCED**

1. All Documents regarding any income or Asset of the Debtor, the Debtor's Family, the Debtor's estate, an Associated Individuals, or an Associated Entity.

2. All Documents related to the Debtor's financial condition and obligations to his creditors, including without limitation all Documents related to any effort to avoid paying such obligations and All Documents related to this or any other actual or potential bankruptcy or similar insolvency proceeding.

3. All Documents regarding any balance sheet, bank statement, account statement, financial statement, statement of account, wire transfer instructions and/or confirmation, proof of funds, certificate of deposit, certificate of holdings, investment portfolio summary, or similar document relating to the Debtor, the Debtor's Estate, the Debtor's Family, an Associated Entity, or an Associated Individual, including without limitation all Documents sufficient to show all Transfers to any of the foregoing.

## Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 146 of 439

4. All Documents regarding any investment, business dealings or transactions made by, with, or on behalf of the Debtor, the Debtor's Family, an Associated Individual, or an Associated Entity.

5. All Communications with the Debtor, the Debtor's Family, an Associated Individual, or an Associated Entity, and Documents related to Communications with the Debtor, the Debtor's Family, an Associated Individual, or an Associated Entity, including related to the operation, management, or decision-making of any Entity, including without limitation the Associated Entities.

6. All Documents regarding any Transfer, investment, or other transaction or business dealing made to, by, or with the Debtor, the Debtor's Family, an Associated Individual, or an Associated Entity.

7. All Documents regarding any property ever occupied or used by the Debtor, including without limitation the residential property located in Greenwich, Connecticut at 373 Taconic Rd.; the residential property located in Greenwich, Connecticut at 33 Ferncliff Rd.; the residential property located in Wilton, Connecticut at 354 Nod Hill Rd; the apartments or condominiums located in 5 Princes Gate London, United Kingdom SW7 1QJ; and the residential property located in Mahwah, New Jersey at 675 Ramapo Valley Road, Mahwah, New Jersey 07430.

8. All Documents related to any aircraft owned, controlled, or used by the Debtor, including without limitation (i) the aircraft bearing tail number T7-GQM and any other aircraft registered in San Marino, including without limitation copies of all registration documents and flight manifests showing flights taken by such aircraft and the individuals onboard such flights, and (ii) any Cirrus SF50 aircraft.

## Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 147 of 439

9. All Documents regarding any gifts, benefits or loans, to, from or on behalf of the Debtor, the Debtor's Estate, the Debtor's Family, or the Associated Entities, including without limitation Documents sufficient to show the amounts of such gifts, benefits, or loans; the purposes for which such gifts, benefits, or loans were used; when the gifts, benefits, or loans were provided; and the terms of any loans, all representations and warranties made in connection with any loans, the interest rate on any loans, and all evidence of payments of any loans.

10. All Documents concerning any trust or similar instrument set up by, on behalf of, or for the benefit of the Debtor, the Debtor's Estate, the Debtor's Family, or an Associated Entity, including without limitation Documents sufficient to show when the trust(s) was created, by whom it was created, for whose benefit it was created, and the corpus of the trust.

11. All Documents related to any obligation, claim, liability, or debt associated with any legal dispute involving the Debtor, including but not limited to those relating to any litigation before any local, state, federal, or international body, whether an administrative body, court, panel, or alternative dispute resolution entity.

12. All Documents and communications with the Debtor, the Debtor's Family, or an Associated Individual.

13. All Documents and communications between any of your counsel or other advisors and the Debtor, the Debtor's Family, or an Associated Individual.

14. All Documents related to any Associated Entity that You hold or have held an interest in.

Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 148 of 439

# Exhibit C-8

#### B2540 (Form 2540 – Subpoena for Rule 2004 Examination) (12/15) Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 149 of

439

UNITED STATES BANKRUPTCY COURT

**District of Connecticut**

In re HO WAN KWOK, *et al*.,

1 Case No. 22-50073 (JAM) Debtor Chapter 11

(Jointly Administered)

# **SUBPOENA FOR RULE 2004 EXAMINATION**

To: **Makayla Randall**

(*Name of person to whom the subpoena is directed*)

| PLACE | DATE AND TIME | |-------|---------------| | N/A | N/A | | | |

The examination will be recorded by this method: N/A

## **See Requests for Production of Documents, attached hereto.**

Date: **May , 2024**

CLERK OF COURT

*Signature of Clerk or Deputy Clerk Attorney's signature*

The name, address, email address, and telephone number of the attorney representing Luc A. Despins, Chapter 11 Trustee, who issues or requests this subpoena, are:

**Patrick R. Linsey, Esq.; Neubert, Pepe & Monteith, P.C.; 195 Church Street, 13th Floor, New Haven, Connecticut 06510 plinsey@npmlaw.com; (203) 781-2847**

## **Notice to the person who issues or requests this subpoena**

## **PROOF OF SERVICE**

**(This section should not be filed with the court unless required by Fed. R. Civ. P. 45.)**

I received this subpoena for (*name of individual and title, if any*): on (*date*) .

I served the subpoena by delivering a copy to the named person as follows:

on *(date)* ; or

I returned the subpoena unexecuted because:

My fees are \$ for travel and \$ for services, for a total of \$ .

I declare under penalty of perjury that this information is true and correct.

Date:

*Server's signature*

*Printed name and title*

*Server's address*

Additional information concerning attempted service, etc.:

## **Federal Rule of Civil Procedure 45(c), (d), (e), and (g) (Effective 12/1/13) (made applicable in bankruptcy cases by Rule 9016, Federal Rules of Bankruptcy Procedure)**

#### **(c) Place of compliance.**

*(1) For a Trial, Hearing, or Deposition.* A subpoena may command a person to attend a trial, hearing, or deposition only as follows:

(A) within 100 miles of where the person resides, is employed, or regularly transacts business in person; or

(B) within the state where the person resides, is employed, or regularly transacts business in person, if the person

(i) is a party or a party's officer; or

(ii) is commanded to attend a trial and would not incur substantial expense.

*(2) For Other Discovery.* A subpoena may command:

(A) production of documents, or electronically stored information, or things at a place within 100 miles of where the person resides, is employed, or regularly transacts business in person; and

(B) inspection of premises, at the premises to be inspected.

## **(d) Protecting a Person Subject to a Subpoena; Enforcement.**

## *(2) Command to Produce Materials or Permit Inspection.*

(i) At any time, on notice to the commanded person, the serving party may move the court for the district where compliance is required for an order compelling production or inspection.

(ii) These acts may be required only as directed in the order, and the order must protect a person who is neither a party nor a party's officer from significant expense resulting from compliance.

## *(3) Quashing or Modifying a Subpoena.*

*(A) When Required.* On timely motion, the court for the district where compliance is required must quash or modify a subpoena that:

(i) fails to allow a reasonable time to comply;

(ii) requires a person to comply beyond the geographical limits specified in Rule 45(c);

(iii) requires disclosure of privileged or other protected matter, if no exception or waiver applies; or

(iv) subjects a person to undue burden.

*(B) When Permitted.* To protect a person subject to or affected by a subpoena, the court for the district where compliance is required may, on motion, quash or modify the subpoena if it requires:

(i) disclosing a trade secret or other confidential research, development, or commercial information; or

(ii) disclosing an unretained expert's opinion or information that does not describe specific occurrences in dispute and results from the expert's study that was not requested by a party.

(i) shows a substantial need for the testimony or material that cannot be otherwise met without undue hardship; and

(ii) ensures that the subpoenaed person will be reasonably compensated.

#### **(e) Duties in Responding to a Subpoena.**

*(1) Producing Documents or Electronically Stored Information.* These procedures apply to producing documents or electronically stored information:

*(C) Electronically Stored Information Produced in Only One Form.* The person responding need not produce the same electronically stored information in more than one form.

#### *(2) Claiming Privilege or Protection.*

For access to subpoena materials, see Fed.R.Civ.P.45(a) Committee Note (2013)

…

## **Requests for Production of Documents**

## **I. INSTRUCTIONS**

2. Electronically stored information must be produced in accordance with the

following instructions:

name of the native file. The native file must be named after the FIRSTBATES.

Date fields should be provided in the format: mm/dd/yyyy. Date and time fields must be two separate fields. Required metadata listed below:

# Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 154 of 439

# Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 155 of 439

3. Each Request operates and should be construed independently and, unless otherwise indicated, no Request limits the scope of any other Request.

4. All Documents are to be produced as kept in the usual course of business or are to be organized and labeled to correspond with the categories in these Requests.

5. Each Request contained herein extends to all Documents: (a) in Your possession, custody, or control; or (b) in the possession, custody, or control of anyone acting on Your behalf,

## Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 156 of 439

including Your counsel or other representatives and advisors. Each Document shall be produced in its entirety.

## Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 157 of 439

12. All references to Entities includes all affiliates thereof.

13. All references to individual names include all alternative names, aliased, or nicknames.

14. Unless otherwise expressly indicated, the period of time covered by the Document Requests is the period from February 5, 2012 to the date responses to the Document Requests are due.

## Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 158 of 439

## **II. RULES OF CONSTRUCTION**

15. The use of (a) any singular noun shall be construed to include the plural, and vice versa, and (b) a verb in any tense shall be construed as the use of the verb in all other tenses.

## **III. DEFINITIONS**

1. "You" or "Your" or "Yourself" means and refers to Makaya Randall, together with all of their agents, attorneys, representatives, employees, and/or anyone acting on their behalf.

3. "Debtor's Son" means Qiang Guo (a/k/a Mileson Kwok, 郭强, or any other alias), together with his employees, agents, counsel, advisors, or anyone acting on his behalf.

## Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 159 of 439

4. "Debtor's Daughter" means Mei Guo (a/k/a Mei Gui, 郭美, or any other alias), together with her employees, agents, counsel, advisors, or anyone acting on her behalf.

6. "Debtor's Family" means, collectively, the Debtor, the Debtor's Son, the Debtor's Daughter, and the Debtor's Purported Wife, and any other familial relation to the Debtor.

## Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 160 of 439

Seup (a/k/a Hee Seup Shin), Steve Bannon, Talha Zobair, Victor Cerda, Wen Xiao, Wencong Wang, William Gertz, William Je (a/k/a Je Kin Ming, Yu Jianming, 余建明), and Xuebing Wang, Ya Li (a/k/a 李娅), Yinying (Aila) Wang (a/k/a Xiao Fei Xiang), Yongping Yan (Shan Mu), Yong Yu, Yue Zhou, Yumei Hao (a/k/a Ru Shui), Yvette Wang (a/k/a Yanping Wang, Yan Ping Wang, 王雁平), Zhang Wei (a/k/a 张魏), Zhouer Wang (a/k/a Joe Wang), Zhixuan Li, and Ziyang Liu.

## Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 161 of 439

LLC, GFashion Media Group Inc., GFNY, Inc., Globalist International Limited, GNews Media Group Inc., Golden Spring (New York) Ltd., Guo Media, GTV Media Group, Inc., GWGOPNZ Limited, GWGNZ Limited, Gypsy Mei Food Services, LLC, HCHK Property Management Inc., HCHK Technologies Inc., Hamilton Digital Assets FD SP, Hamilton Capital Holdings Inc., Hamilton Opportunity Fund SPC, Head Win Group Limited, Himalaya Embassy, Himalaya Exchange, Himalaya Federal Reserve, Himalaya International Financial Group Ltd., Himalaya Investment LLC, Himalaya (USA) Investment Management LLC, Himalaya New World Inc., Himalaya Supervisory Organization, Himalaya Ventures, Holy City Hong Kong Ventures, Ltd., Hudson Diamond Holding LLC, Hudson Diamond Holding Inc., Hudson Diamond NY LLC, HK International Funds Investments (USA) Limited LLC, Hong Kong International Funds Investments Limited, Huk Trading Inc, Infinite Increase Limited, Infinitum Developments Limited, Japan Himalaya League, Inc., Kalixun Trading Limited, Lamp Capital LLC, Leading Shine Limited, Leading Shine NY Limited, Lexington Property and Staffing Inc., Long Gate Limited, MOS Himalaya Foundation Inc., Maywind Trading LLC, New Federal State of China (a/k/a NFSC), New York MOS Himalaya LLC, New Mulberry PTE Ltd., Newpeople LLC, Noble Fame Global Limited, Pixshow Film Inc., Roscalitar 2, Rosy Acme Ventures Limited, Rule of Law Foundation III, Inc., Rule of Law Society, Rule of Law Society IV, Inc., Santel LLC, Saraca Media Group, Inc., Shiny Ace Ltd., Shiny Times Holdings Ltd., Stevenson, Wong & Co., Taurus Fund LLC, Taurus Fund SP, Taurus Management LLC, The Lost Draft LLC, TM Primrose Limited, UA Himalaya Inc., Voice of Guo Media, Inc., Well Origin Ltd., Wise Creation, Whitecroft Shore Limited, World Century Limited, Worldwide Opportunity Holdings Limited, and ZIBA Limited.

9. "Including" or any variant thereof means "including without limitation."

## Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 162 of 439

10. "And" and "or" mean "and/or," and shall be construed both conjunctively as well as disjunctively in order to maximize their scope.

11. "Any" and "all" and "each" mean "each and every."

12. "Each" and "every" mean "each and every."

13. "Third Party" means a Person or Entity other than Yourself.

14. "Transfer" shall have the meaning given to it by section 101(54) of the Bankruptcy Code.

## Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 163 of 439

of the foregoing that contain any notes, comments, or markings of any kind not found on the original documents or that are otherwise not identical to the original documents.

## Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 164 of 439

slips, memoranda, telephone communications, voice messages, telegrams, telefaxes, telecopies, telexes, instant messages, chats, text messages, telephonic notes, or notes transmitted internally or with third parties.

22. "Transfer" shall have the meaning given to it by section 101(54) of the Bankruptcy Code.

## **IV. DOCUMENTS TO BE PRODUCED**

1. All Documents regarding any income or Asset of the Debtor, the Debtor's Family, the Debtor's estate, an Associated Individuals, or an Associated Entity.

## Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 165 of 439

or an Associated Individual, including without limitation all Documents sufficient to show all Transfers to any of the foregoing.

4. All Documents regarding any investment, business dealings or transactions made by, with, or on behalf of the Debtor, the Debtor's Family, an Associated Individual, or an Associated Entity.

6. All Documents regarding any Transfer, investment, or other transaction or business dealing made to, by, or with the Debtor, the Debtor's Family, an Associated Individual, or an Associated Entity.

8. All Documents related to any aircraft owned, controlled, or used by the Debtor, including without limitation (i) the aircraft bearing tail number T7-GQM and any other aircraft

## Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 166 of 439

registered in San Marino, including without limitation copies of all registration documents and flight manifests showing flights taken by such aircraft and the individuals onboard such flights, and (ii) any Cirrus SF50 aircraft.

12. All Documents and communications with the Debtor, the Debtor's Family, or an Associated Individual.

13. All Documents and communications between any of your counsel or other advisors and the Debtor, the Debtor's Family, or an Associated Individual.

## Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 167 of 439

14. All Documents related to any Associated Entity that You hold or have held an interest in.

Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 168 of 439

# Exhibit C-9

#### B2540 (Form 2540 – Subpoena for Rule 2004 Examination) (12/15) Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 169 of

439

UNITED STATES BANKRUPTCY COURT

**District of Connecticut**

In re HO WAN KWOK, *et al*.,

1 Case No. 22-50073 (JAM) Debtor Chapter 11

(Jointly Administered)

# **SUBPOENA FOR RULE 2004 EXAMINATION**

To: **Richard Leahy**

(*Name of person to whom the subpoena is directed*)

| PLACE | DATE AND TIME | |-------|---------------| | N/A | N/A | | | |

The examination will be recorded by this method: N/A

## **See Requests for Production of Documents, attached hereto.**

Date: **May , 2024**

CLERK OF COURT

*Signature of Clerk or Deputy Clerk Attorney's signature*

The name, address, email address, and telephone number of the attorney representing Luc A. Despins, Chapter 11 Trustee, who issues or requests this subpoena, are:

**Patrick R. Linsey, Esq.; Neubert, Pepe & Monteith, P.C.; 195 Church Street, 13th Floor, New Haven, Connecticut 06510 plinsey@npmlaw.com; (203) 781-2847**

## **Notice to the person who issues or requests this subpoena**

## **PROOF OF SERVICE**

**(This section should not be filed with the court unless required by Fed. R. Civ. P. 45.)**

I received this subpoena for (*name of individual and title, if any*): on (*date*) .

I served the subpoena by delivering a copy to the named person as follows:

on *(date)* ; or

I returned the subpoena unexecuted because:

My fees are \$ for travel and \$ for services, for a total of \$ .

I declare under penalty of perjury that this information is true and correct.

Date:

*Server's signature*

*Printed name and title*

*Server's address*

Additional information concerning attempted service, etc.:

## **Federal Rule of Civil Procedure 45(c), (d), (e), and (g) (Effective 12/1/13) (made applicable in bankruptcy cases by Rule 9016, Federal Rules of Bankruptcy Procedure)**

#### **(c) Place of compliance.**

*(1) For a Trial, Hearing, or Deposition.* A subpoena may command a person to attend a trial, hearing, or deposition only as follows:

(A) within 100 miles of where the person resides, is employed, or regularly transacts business in person; or

(B) within the state where the person resides, is employed, or regularly transacts business in person, if the person

(i) is a party or a party's officer; or

(ii) is commanded to attend a trial and would not incur substantial expense.

*(2) For Other Discovery.* A subpoena may command:

(A) production of documents, or electronically stored information, or things at a place within 100 miles of where the person resides, is employed, or regularly transacts business in person; and

(B) inspection of premises, at the premises to be inspected.

## **(d) Protecting a Person Subject to a Subpoena; Enforcement.**

## *(2) Command to Produce Materials or Permit Inspection.*

(i) At any time, on notice to the commanded person, the serving party may move the court for the district where compliance is required for an order compelling production or inspection.

(ii) These acts may be required only as directed in the order, and the order must protect a person who is neither a party nor a party's officer from significant expense resulting from compliance.

## *(3) Quashing or Modifying a Subpoena.*

*(A) When Required.* On timely motion, the court for the district where compliance is required must quash or modify a subpoena that:

(i) fails to allow a reasonable time to comply;

(ii) requires a person to comply beyond the geographical limits specified in Rule 45(c);

(iii) requires disclosure of privileged or other protected matter, if no exception or waiver applies; or

(iv) subjects a person to undue burden.

*(B) When Permitted.* To protect a person subject to or affected by a subpoena, the court for the district where compliance is required may, on motion, quash or modify the subpoena if it requires:

(i) disclosing a trade secret or other confidential research, development, or commercial information; or

(ii) disclosing an unretained expert's opinion or information that does not describe specific occurrences in dispute and results from the expert's study that was not requested by a party.

(i) shows a substantial need for the testimony or material that cannot be otherwise met without undue hardship; and

(ii) ensures that the subpoenaed person will be reasonably compensated.

#### **(e) Duties in Responding to a Subpoena.**

*(1) Producing Documents or Electronically Stored Information.* These procedures apply to producing documents or electronically stored information:

*(C) Electronically Stored Information Produced in Only One Form.* The person responding need not produce the same electronically stored information in more than one form.

#### *(2) Claiming Privilege or Protection.*

For access to subpoena materials, see Fed.R.Civ.P.45(a) Committee Note (2013)

…

## **Requests for Production of Documents**

## **I. INSTRUCTIONS**

2. Electronically stored information must be produced in accordance with the

following instructions:

name of the native file. The native file must be named after the FIRSTBATES.

Date fields should be provided in the format: mm/dd/yyyy. Date and time fields must be two separate fields. Required metadata listed below:

| Field Name | Sample Data | Description | | |--------------|--------------------------|--------------------------------------------------|--| | FIRSTBATES | EDC0000001 | First Bates number of native file document/email | | | LASTBATES | EDC0000001 | Last Bates number of native file document/email | | | | | **The LASTBATES field should be populated | | | | | for single page | | | ATTACHRANGE | EDC0000001 - | Bates number of the first page of the parent | | | | EDC0000015 | document to the Bates number of the last page of | | | | | the last attachment "child" document | | | BEGATTACH | EDC0000001 | First Bates number of attachment range | | | ENDATTACH | EDC0000015 | Last Bates number of attachment range | | | CUSTODIAN | Smith, John | Email: Mailbox where the email resided | | | | | Native: Name of the individual or department | | | | | from whose files the document originated | | | FROM | John Smith | Email: Sender | | | | | Native: Author(s) of document | | | | | **semi-colon should be used to separate | | | | | multiple entries | | | TO | Coffman, Janice; LeeW | Recipient(s) | | | | [mailto:LeeW@MSN.com] | **semi-colon should be used to separate multiple | | | | | entries | | | CC | Frank Thompson [mailto: | Carbon copy recipient(s) | | | | frank_Thompson@cdt.com] | **semi-colon should be used to separate | | | | | multiple entries | | | BCC | John Cain | Blind carbon copy recipient(s) | | | | | **semi-colon should be used to separate | | | | | multiple entries | | | SUBJECT | Board Meeting Minutes | Email: Subject line of the email Native: Title | | | | | of document (if available) | | | FILE_NAME | BoardMeetingMinutes.docx | Native: Name of the original native file, | | | | | including extension | | | DATE_SENT | 10/12/2010 | Email: Date the email was sent | | | | | Native: (empty) | | | TIME_SENT/ | 07:05 PM GMT | Email: Time the email was sent/ Time zone in | | | TIME_ZONE | | which the emails were standardized | | | TIME_ZONE | GMT | The time zone in which the emails were | | | | | standardized during conversion. | | | LINK | EDC0000001.msg | Hyperlink to the email or native file document | | | | | **The linked file must be named per the | | | | | FIRSTBATES number | | | FILE_EXTEN | MSG | The file type extension | | | | | representing | | | | | the Email or | | | AUTHOR | John Smith | Email: (empty) | | | | | Native: Author of the document | | | DATE_CREATED | 10/10/2010 | Email: (empty) | | | | | Native: Date the document was created | |

# Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 175 of 439

3. Each Request operates and should be construed independently and, unless otherwise indicated, no Request limits the scope of any other Request.

4. All Documents are to be produced as kept in the usual course of business or are to be organized and labeled to correspond with the categories in these Requests.

5. Each Request contained herein extends to all Documents: (a) in Your possession, custody, or control; or (b) in the possession, custody, or control of anyone acting on Your behalf,

## Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 176 of 439

including Your counsel or other representatives and advisors. Each Document shall be produced in its entirety.

## Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 177 of 439

12. All references to Entities includes all affiliates thereof.

13. All references to individual names include all alternative names, aliased, or nicknames.

14. Unless otherwise expressly indicated, the period of time covered by the Document Requests is the period from February 5, 2012 to the date responses to the Document Requests are due.

## **II. RULES OF CONSTRUCTION**

15. The use of (a) any singular noun shall be construed to include the plural, and vice versa, and (b) a verb in any tense shall be construed as the use of the verb in all other tenses.

## **III. DEFINITIONS**

1. "You" or "Your" or "Yourself" means and refers to Richard Leahy, together with all of their agents, attorneys, representatives, employees, and/or anyone acting on their behalf.

3. "Debtor's Son" means Qiang Guo (a/k/a Mileson Kwok, 郭强, or any other alias), together with his employees, agents, counsel, advisors, or anyone acting on his behalf.

4. "Debtor's Daughter" means Mei Guo (a/k/a Mei Gui, 郭美, or any other alias), together with her employees, agents, counsel, advisors, or anyone acting on her behalf.

## Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 179 of 439

6. "Debtor's Family" means, collectively, the Debtor, the Debtor's Son, the Debtor's Daughter, and the Debtor's Purported Wife, and any other familial relation to the Debtor.

## Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 180 of 439

## Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 181 of 439

9. "Including" or any variant thereof means "including without limitation."

10. "And" and "or" mean "and/or," and shall be construed both conjunctively as well as disjunctively in order to maximize their scope.

## Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 182 of 439

11. "Any" and "all" and "each" mean "each and every."

12. "Each" and "every" mean "each and every."

13. "Third Party" means a Person or Entity other than Yourself.

14. "Transfer" shall have the meaning given to it by section 101(54) of the Bankruptcy Code.

## Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 183 of 439

## Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 184 of 439

telexes, instant messages, chats, text messages, telephonic notes, or notes transmitted internally or with third parties.

22. "Transfer" shall have the meaning given to it by section 101(54) of the Bankruptcy Code.

## **IV. DOCUMENTS TO BE PRODUCED**

1. All Documents regarding any income or Asset of the Debtor, the Debtor's Family, the Debtor's estate, an Associated Individuals, or an Associated Entity.

## Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 185 of 439

4. All Documents regarding any investment, business dealings or transactions made by, with, or on behalf of the Debtor, the Debtor's Family, an Associated Individual, or an Associated Entity.

6. All Documents regarding any Transfer, investment, or other transaction or business dealing made to, by, or with the Debtor, the Debtor's Family, an Associated Individual, or an Associated Entity.

## Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 186 of 439

12. All Documents and communications with the Debtor, the Debtor's Family, or an Associated Individual.

13. All Documents and communications between any of your counsel or other advisors and the Debtor, the Debtor's Family, or an Associated Individual.

14. All Documents related to any Associated Entity that You hold or have held an interest in.

# Exhibit C-10

B2540 (Form 2540 – Subpoena for Rule 2004 Examination) (12/15) Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 188 of

UNITED STATES BANKRUPTCY COURT 439

**District of Connecticut**

In re HO WAN KWOK, *et al*.,

1 Case No. 22-50073 (JAM)

Debtor Chapter 11

(Jointly Administered)

**SUBPOENA FOR RULE 2004 EXAMINATION**

To: **Thomas Guarino (a/k/a Thomas Guarino II)**

(*Name of person to whom the subpoena is directed*)

| PLACE | DATE AND TIME | |-------|---------------| | N/A | N/A | | | |

The examination will be recorded by this method: N/A

## **See Requests for Production of Documents, attached hereto.**

Date: **May , 2024**

CLERK OF COURT

*Signature of Clerk or Deputy Clerk Attorney's signature*

The name, address, email address, and telephone number of the attorney representing Luc A. Despins, Chapter 11 Trustee, who issues or requests this subpoena, are:

**Patrick R. Linsey, Esq.; Neubert, Pepe & Monteith, P.C.; 195 Church Street, 13th Floor, New Haven, Connecticut 06510 plinsey@npmlaw.com; (203) 781-2847**

## **Notice to the person who issues or requests this subpoena**

## **PROOF OF SERVICE**

**(This section should not be filed with the court unless required by Fed. R. Civ. P. 45.)**

I received this subpoena for (*name of individual and title, if any*): on (*date*) .

I served the subpoena by delivering a copy to the named person as follows:

on *(date)* ; or

I returned the subpoena unexecuted because:

My fees are \$ for travel and \$ for services, for a total of \$ .

I declare under penalty of perjury that this information is true and correct.

Date:

*Server's signature*

*Printed name and title*

*Server's address*

Additional information concerning attempted service, etc.:

## **Federal Rule of Civil Procedure 45(c), (d), (e), and (g) (Effective 12/1/13) (made applicable in bankruptcy cases by Rule 9016, Federal Rules of Bankruptcy Procedure)**

#### **(c) Place of compliance.**

*(1) For a Trial, Hearing, or Deposition.* A subpoena may command a person to attend a trial, hearing, or deposition only as follows:

(A) within 100 miles of where the person resides, is employed, or regularly transacts business in person; or

(B) within the state where the person resides, is employed, or regularly transacts business in person, if the person

(i) is a party or a party's officer; or

(ii) is commanded to attend a trial and would not incur substantial expense.

*(2) For Other Discovery.* A subpoena may command:

(A) production of documents, or electronically stored information, or things at a place within 100 miles of where the person resides, is employed, or regularly transacts business in person; and

(B) inspection of premises, at the premises to be inspected.

## **(d) Protecting a Person Subject to a Subpoena; Enforcement.**

## *(2) Command to Produce Materials or Permit Inspection.*

(i) At any time, on notice to the commanded person, the serving party may move the court for the district where compliance is required for an order compelling production or inspection.

(ii) These acts may be required only as directed in the order, and the order must protect a person who is neither a party nor a party's officer from significant expense resulting from compliance.

## *(3) Quashing or Modifying a Subpoena.*

*(A) When Required.* On timely motion, the court for the district where compliance is required must quash or modify a subpoena that:

(i) fails to allow a reasonable time to comply;

(ii) requires a person to comply beyond the geographical limits specified in Rule 45(c);

(iii) requires disclosure of privileged or other protected matter, if no exception or waiver applies; or

(iv) subjects a person to undue burden.

*(B) When Permitted.* To protect a person subject to or affected by a subpoena, the court for the district where compliance is required may, on motion, quash or modify the subpoena if it requires:

(i) disclosing a trade secret or other confidential research, development, or commercial information; or

(ii) disclosing an unretained expert's opinion or information that does not describe specific occurrences in dispute and results from the expert's study that was not requested by a party.

(i) shows a substantial need for the testimony or material that cannot be otherwise met without undue hardship; and

(ii) ensures that the subpoenaed person will be reasonably compensated.

#### **(e) Duties in Responding to a Subpoena.**

*(1) Producing Documents or Electronically Stored Information.* These procedures apply to producing documents or electronically stored information:

*(C) Electronically Stored Information Produced in Only One Form.* The person responding need not produce the same electronically stored information in more than one form.

#### *(2) Claiming Privilege or Protection.*

For access to subpoena materials, see Fed.R.Civ.P.45(a) Committee Note (2013)

…

## **Requests for Production of Documents**

## **I. INSTRUCTIONS**

2. Electronically stored information must be produced in accordance with the

following instructions:

name of the native file. The native file must be named after the FIRSTBATES.

Date fields should be provided in the format: mm/dd/yyyy. Date and time fields must be two separate fields. Required metadata listed below:

# Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 193 of 439

# Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 194 of 439

3. Each Request operates and should be construed independently and, unless otherwise indicated, no Request limits the scope of any other Request.

4. All Documents are to be produced as kept in the usual course of business or are to be organized and labeled to correspond with the categories in these Requests.

5. Each Request contained herein extends to all Documents: (a) in Your possession, custody, or control; or (b) in the possession, custody, or control of anyone acting on Your behalf,

## Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 195 of 439

including Your counsel or other representatives and advisors. Each Document shall be produced in its entirety.

## Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 196 of 439

12. All references to Entities includes all affiliates thereof.

13. All references to individual names include all alternative names, aliased, or nicknames.

14. Unless otherwise expressly indicated, the period of time covered by the Document Requests is the period from February 5, 2012 to the date responses to the Document Requests are due.

## **II. RULES OF CONSTRUCTION**

15. The use of (a) any singular noun shall be construed to include the plural, and vice versa, and (b) a verb in any tense shall be construed as the use of the verb in all other tenses.

## **III. DEFINITIONS**

1. "You" or "Your" or "Yourself" means and refers to Thomas Guarino (a/k/a Thomas Guarino II), together with all of their agents, attorneys, representatives, employees, and/or anyone acting on their behalf.

3. "Debtor's Son" means Qiang Guo (a/k/a Mileson Kwok, 郭强, or any other alias), together with his employees, agents, counsel, advisors, or anyone acting on his behalf.

## Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 198 of 439

4. "Debtor's Daughter" means Mei Guo (a/k/a Mei Gui, 郭美, or any other alias), together with her employees, agents, counsel, advisors, or anyone acting on her behalf.

6. "Debtor's Family" means, collectively, the Debtor, the Debtor's Son, the Debtor's Daughter, and the Debtor's Purported Wife, and any other familial relation to the Debtor.

## Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 199 of 439

## Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 200 of 439

9. "Including" or any variant thereof means "including without limitation."

## Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 201 of 439

10. "And" and "or" mean "and/or," and shall be construed both conjunctively as well as disjunctively in order to maximize their scope.

11. "Any" and "all" and "each" mean "each and every."

12. "Each" and "every" mean "each and every."

13. "Third Party" means a Person or Entity other than Yourself.

14. "Transfer" shall have the meaning given to it by section 101(54) of the Bankruptcy Code.

## Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 202 of 439

of the foregoing that contain any notes, comments, or markings of any kind not found on the original documents or that are otherwise not identical to the original documents.

## Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 203 of 439

22. "Transfer" shall have the meaning given to it by section 101(54) of the Bankruptcy Code.

## **IV. DOCUMENTS TO BE PRODUCED**

1. All Documents regarding any income or Asset of the Debtor, the Debtor's Family, the Debtor's estate, an Associated Individuals, or an Associated Entity.

## Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 204 of 439

or an Associated Individual, including without limitation all Documents sufficient to show all Transfers to any of the foregoing.

4. All Documents regarding any investment, business dealings or transactions made by, with, or on behalf of the Debtor, the Debtor's Family, an Associated Individual, or an Associated Entity.

6. All Documents regarding any Transfer, investment, or other transaction or business dealing made to, by, or with the Debtor, the Debtor's Family, an Associated Individual, or an Associated Entity.

8. All Documents related to any aircraft owned, controlled, or used by the Debtor, including without limitation (i) the aircraft bearing tail number T7-GQM and any other aircraft

## Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 205 of 439

12. All Documents and communications with the Debtor, the Debtor's Family, or an Associated Individual.

13. All Documents and communications between any of your counsel or other advisors and the Debtor, the Debtor's Family, or an Associated Individual.

## Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 206 of 439

14. All Documents related to any Associated Entity that You hold or have held an interest in.

Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 207 of 439

# Exhibit C-11

#### B2540 (Form 2540 – Subpoena for Rule 2004 Examination) (12/15) Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 208 of

439

UNITED STATES BANKRUPTCY COURT

**District of Connecticut**

In re HO WAN KWOK, *et al*.,

1 Case No. 22-50073 (JAM) Debtor Chapter 11

(Jointly Administered)

# **SUBPOENA FOR RULE 2004 EXAMINATION**

To: **Lukasz Lasota**

(*Name of person to whom the subpoena is directed*)

| PLACE | DATE AND TIME | |-------|---------------| | N/A | N/A | | | |

The examination will be recorded by this method: N/A

## **See Requests for Production of Documents, attached hereto.**

Date: **May , 2024**

CLERK OF COURT

*Signature of Clerk or Deputy Clerk Attorney's signature*

The name, address, email address, and telephone number of the attorney representing Luc A. Despins, Chapter 11 Trustee, who issues or requests this subpoena, are:

**Patrick R. Linsey, Esq.; Neubert, Pepe & Monteith, P.C.; 195 Church Street, 13th Floor, New Haven, Connecticut 06510 plinsey@npmlaw.com; (203) 781-2847**

## **Notice to the person who issues or requests this subpoena**

## **PROOF OF SERVICE**

**(This section should not be filed with the court unless required by Fed. R. Civ. P. 45.)**

I received this subpoena for (*name of individual and title, if any*): on (*date*) .

I served the subpoena by delivering a copy to the named person as follows:

on *(date)* ; or

I returned the subpoena unexecuted because:

My fees are \$ for travel and \$ for services, for a total of \$ .

I declare under penalty of perjury that this information is true and correct.

Date:

*Server's signature*

*Printed name and title*

*Server's address*

Additional information concerning attempted service, etc.:

## **Federal Rule of Civil Procedure 45(c), (d), (e), and (g) (Effective 12/1/13) (made applicable in bankruptcy cases by Rule 9016, Federal Rules of Bankruptcy Procedure)**

#### **(c) Place of compliance.**

*(1) For a Trial, Hearing, or Deposition.* A subpoena may command a person to attend a trial, hearing, or deposition only as follows:

(A) within 100 miles of where the person resides, is employed, or regularly transacts business in person; or

(B) within the state where the person resides, is employed, or regularly transacts business in person, if the person

(i) is a party or a party's officer; or

(ii) is commanded to attend a trial and would not incur substantial expense.

*(2) For Other Discovery.* A subpoena may command:

(A) production of documents, or electronically stored information, or things at a place within 100 miles of where the person resides, is employed, or regularly transacts business in person; and

(B) inspection of premises, at the premises to be inspected.

## **(d) Protecting a Person Subject to a Subpoena; Enforcement.**

## *(2) Command to Produce Materials or Permit Inspection.*

(i) At any time, on notice to the commanded person, the serving party may move the court for the district where compliance is required for an order compelling production or inspection.

(ii) These acts may be required only as directed in the order, and the order must protect a person who is neither a party nor a party's officer from significant expense resulting from compliance.

## *(3) Quashing or Modifying a Subpoena.*

*(A) When Required.* On timely motion, the court for the district where compliance is required must quash or modify a subpoena that:

(i) fails to allow a reasonable time to comply;

(ii) requires a person to comply beyond the geographical limits specified in Rule 45(c);

(iii) requires disclosure of privileged or other protected matter, if no exception or waiver applies; or

(iv) subjects a person to undue burden.

*(B) When Permitted.* To protect a person subject to or affected by a subpoena, the court for the district where compliance is required may, on motion, quash or modify the subpoena if it requires:

(i) disclosing a trade secret or other confidential research, development, or commercial information; or

(ii) disclosing an unretained expert's opinion or information that does not describe specific occurrences in dispute and results from the expert's study that was not requested by a party.

(i) shows a substantial need for the testimony or material that cannot be otherwise met without undue hardship; and

(ii) ensures that the subpoenaed person will be reasonably compensated.

#### **(e) Duties in Responding to a Subpoena.**

*(1) Producing Documents or Electronically Stored Information.* These procedures apply to producing documents or electronically stored information:

*(C) Electronically Stored Information Produced in Only One Form.* The person responding need not produce the same electronically stored information in more than one form.

#### *(2) Claiming Privilege or Protection.*

For access to subpoena materials, see Fed.R.Civ.P.45(a) Committee Note (2013)

…

## **Requests for Production of Documents**

## **I. INSTRUCTIONS**

2. Electronically stored information must be produced in accordance with the

following instructions:

name of the native file. The native file must be named after the FIRSTBATES.

Date fields should be provided in the format: mm/dd/yyyy. Date and time fields must be two separate fields. Required metadata listed below:

# Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 213 of 439

# Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 214 of 439

3. Each Request operates and should be construed independently and, unless otherwise indicated, no Request limits the scope of any other Request.

4. All Documents are to be produced as kept in the usual course of business or are to be organized and labeled to correspond with the categories in these Requests.

5. Each Request contained herein extends to all Documents: (a) in Your possession, custody, or control; or (b) in the possession, custody, or control of anyone acting on Your behalf,

## Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 215 of 439

including Your counsel or other representatives and advisors. Each Document shall be produced in its entirety.

## Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 216 of 439

12. All references to Entities includes all affiliates thereof.

13. All references to individual names include all alternative names, aliased, or nicknames.

14. Unless otherwise expressly indicated, the period of time covered by the Document Requests is the period from February 5, 2012 to the date responses to the Document Requests are due.

## **II. RULES OF CONSTRUCTION**

15. The use of (a) any singular noun shall be construed to include the plural, and vice versa, and (b) a verb in any tense shall be construed as the use of the verb in all other tenses.

## **III. DEFINITIONS**

1. "You" or "Your" or "Yourself" means and refers to Lukasz Lasota, together with all of their agents, attorneys, representatives, employees, and/or anyone acting on their behalf.

3. "Debtor's Son" means Qiang Guo (a/k/a Mileson Kwok, 郭强, or any other alias), together with his employees, agents, counsel, advisors, or anyone acting on his behalf.

4. "Debtor's Daughter" means Mei Guo (a/k/a Mei Gui, 郭美, or any other alias), together with her employees, agents, counsel, advisors, or anyone acting on her behalf.

## Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 218 of 439

6. "Debtor's Family" means, collectively, the Debtor, the Debtor's Son, the Debtor's Daughter, and the Debtor's Purported Wife, and any other familial relation to the Debtor.

## Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 219 of 439

## Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 220 of 439

9. "Including" or any variant thereof means "including without limitation."

10. "And" and "or" mean "and/or," and shall be construed both conjunctively as well as disjunctively in order to maximize their scope.

## Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 221 of 439

11. "Any" and "all" and "each" mean "each and every."

12. "Each" and "every" mean "each and every."

13. "Third Party" means a Person or Entity other than Yourself.

14. "Transfer" shall have the meaning given to it by section 101(54) of the Bankruptcy Code.

## Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 222 of 439

## Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 223 of 439

telexes, instant messages, chats, text messages, telephonic notes, or notes transmitted internally or with third parties.

22. "Transfer" shall have the meaning given to it by section 101(54) of the Bankruptcy Code.

## **IV. DOCUMENTS TO BE PRODUCED**

1. All Documents regarding any income or Asset of the Debtor, the Debtor's Family, the Debtor's estate, an Associated Individuals, or an Associated Entity.

## Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 224 of 439

4. All Documents regarding any investment, business dealings or transactions made by, with, or on behalf of the Debtor, the Debtor's Family, an Associated Individual, or an Associated Entity.

6. All Documents regarding any Transfer, investment, or other transaction or business dealing made to, by, or with the Debtor, the Debtor's Family, an Associated Individual, or an Associated Entity.

## Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 225 of 439

12. All Documents and communications with the Debtor, the Debtor's Family, or an Associated Individual.

13. All Documents and communications between any of your counsel or other advisors and the Debtor, the Debtor's Family, or an Associated Individual.

14. All Documents related to any Associated Entity that You hold or have held an interest in.

# Exhibit C-12

#### B2540 (Form 2540 – Subpoena for Rule 2004 Examination) (12/15) Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 227 of

439

UNITED STATES BANKRUPTCY COURT

**District of Connecticut**

In re HO WAN KWOK, *et al*.,

1 Case No. 22-50073 (JAM) Debtor Chapter 11

(Jointly Administered)

# **SUBPOENA FOR RULE 2004 EXAMINATION**

To: **Thomas McHale**

(*Name of person to whom the subpoena is directed*)

| PLACE | DATE AND TIME | |-------|---------------| | N/A | N/A | | | |

The examination will be recorded by this method: N/A

## **See Requests for Production of Documents, attached hereto.**

Date: **May , 2024**

CLERK OF COURT

*Signature of Clerk or Deputy Clerk Attorney's signature*

The name, address, email address, and telephone number of the attorney representing Luc A. Despins, Chapter 11 Trustee, who issues or requests this subpoena, are:

**Patrick R. Linsey, Esq.; Neubert, Pepe & Monteith, P.C.; 195 Church Street, 13th Floor, New Haven, Connecticut 06510 plinsey@npmlaw.com; (203) 781-2847**

## **Notice to the person who issues or requests this subpoena**

## **PROOF OF SERVICE**

**(This section should not be filed with the court unless required by Fed. R. Civ. P. 45.)**

I received this subpoena for (*name of individual and title, if any*): on (*date*) .

I served the subpoena by delivering a copy to the named person as follows:

on *(date)* ; or

I returned the subpoena unexecuted because:

My fees are \$ for travel and \$ for services, for a total of \$ .

I declare under penalty of perjury that this information is true and correct.

Date:

*Server's signature*

*Printed name and title*

*Server's address*

Additional information concerning attempted service, etc.:

## **Federal Rule of Civil Procedure 45(c), (d), (e), and (g) (Effective 12/1/13) (made applicable in bankruptcy cases by Rule 9016, Federal Rules of Bankruptcy Procedure)**

#### **(c) Place of compliance.**

*(1) For a Trial, Hearing, or Deposition.* A subpoena may command a person to attend a trial, hearing, or deposition only as follows:

(A) within 100 miles of where the person resides, is employed, or regularly transacts business in person; or

(B) within the state where the person resides, is employed, or regularly transacts business in person, if the person

(i) is a party or a party's officer; or

(ii) is commanded to attend a trial and would not incur substantial expense.

*(2) For Other Discovery.* A subpoena may command:

(A) production of documents, or electronically stored information, or things at a place within 100 miles of where the person resides, is employed, or regularly transacts business in person; and

(B) inspection of premises, at the premises to be inspected.

## **(d) Protecting a Person Subject to a Subpoena; Enforcement.**

## *(2) Command to Produce Materials or Permit Inspection.*

(i) At any time, on notice to the commanded person, the serving party may move the court for the district where compliance is required for an order compelling production or inspection.

(ii) These acts may be required only as directed in the order, and the order must protect a person who is neither a party nor a party's officer from significant expense resulting from compliance.

## *(3) Quashing or Modifying a Subpoena.*

*(A) When Required.* On timely motion, the court for the district where compliance is required must quash or modify a subpoena that:

(i) fails to allow a reasonable time to comply;

(ii) requires a person to comply beyond the geographical limits specified in Rule 45(c);

(iii) requires disclosure of privileged or other protected matter, if no exception or waiver applies; or

(iv) subjects a person to undue burden.

*(B) When Permitted.* To protect a person subject to or affected by a subpoena, the court for the district where compliance is required may, on motion, quash or modify the subpoena if it requires:

(i) disclosing a trade secret or other confidential research, development, or commercial information; or

(ii) disclosing an unretained expert's opinion or information that does not describe specific occurrences in dispute and results from the expert's study that was not requested by a party.

(i) shows a substantial need for the testimony or material that cannot be otherwise met without undue hardship; and

(ii) ensures that the subpoenaed person will be reasonably compensated.

#### **(e) Duties in Responding to a Subpoena.**

*(1) Producing Documents or Electronically Stored Information.* These procedures apply to producing documents or electronically stored information:

*(C) Electronically Stored Information Produced in Only One Form.* The person responding need not produce the same electronically stored information in more than one form.

#### *(2) Claiming Privilege or Protection.*

For access to subpoena materials, see Fed.R.Civ.P.45(a) Committee Note (2013)

…

## **Requests for Production of Documents**

## **I. INSTRUCTIONS**

2. Electronically stored information must be produced in accordance with the

following instructions:

name of the native file. The native file must be named after the FIRSTBATES.

Date fields should be provided in the format: mm/dd/yyyy. Date and time fields must be two separate fields. Required metadata listed below:

# Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 233 of 439

3. Each Request operates and should be construed independently and, unless otherwise indicated, no Request limits the scope of any other Request.

4. All Documents are to be produced as kept in the usual course of business or are to be organized and labeled to correspond with the categories in these Requests.

5. Each Request contained herein extends to all Documents: (a) in Your possession, custody, or control; or (b) in the possession, custody, or control of anyone acting on Your behalf,

## Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 234 of 439

including Your counsel or other representatives and advisors. Each Document shall be produced in its entirety.

## Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 235 of 439

12. All references to Entities includes all affiliates thereof.

13. All references to individual names include all alternative names, aliased, or nicknames.

14. Unless otherwise expressly indicated, the period of time covered by the Document Requests is the period from February 5, 2012 to the date responses to the Document Requests are due.

## **II. RULES OF CONSTRUCTION**

15. The use of (a) any singular noun shall be construed to include the plural, and vice versa, and (b) a verb in any tense shall be construed as the use of the verb in all other tenses.

## **III. DEFINITIONS**

1. "You" or "Your" or "Yourself" means and refers to Thomas McHale, together with all of their agents, attorneys, representatives, employees, and/or anyone acting on their behalf.

3. "Debtor's Son" means Qiang Guo (a/k/a Mileson Kwok, 郭强, or any other alias), together with his employees, agents, counsel, advisors, or anyone acting on his behalf.

## Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 237 of 439

4. "Debtor's Daughter" means Mei Guo (a/k/a Mei Gui, 郭美, or any other alias), together with her employees, agents, counsel, advisors, or anyone acting on her behalf.

6. "Debtor's Family" means, collectively, the Debtor, the Debtor's Son, the Debtor's Daughter, and the Debtor's Purported Wife, and any other familial relation to the Debtor.

## Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 238 of 439

## Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 239 of 439

9. "Including" or any variant thereof means "including without limitation."

## Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 240 of 439

10. "And" and "or" mean "and/or," and shall be construed both conjunctively as well as disjunctively in order to maximize their scope.

11. "Any" and "all" and "each" mean "each and every."

12. "Each" and "every" mean "each and every."

13. "Third Party" means a Person or Entity other than Yourself.

14. "Transfer" shall have the meaning given to it by section 101(54) of the Bankruptcy Code.

## Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 241 of 439

of the foregoing that contain any notes, comments, or markings of any kind not found on the original documents or that are otherwise not identical to the original documents.

## Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 242 of 439

22. "Transfer" shall have the meaning given to it by section 101(54) of the Bankruptcy Code.

## **IV. DOCUMENTS TO BE PRODUCED**

1. All Documents regarding any income or Asset of the Debtor, the Debtor's Family, the Debtor's estate, an Associated Individuals, or an Associated Entity.

## Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 243 of 439

or an Associated Individual, including without limitation all Documents sufficient to show all Transfers to any of the foregoing.

4. All Documents regarding any investment, business dealings or transactions made by, with, or on behalf of the Debtor, the Debtor's Family, an Associated Individual, or an Associated Entity.

6. All Documents regarding any Transfer, investment, or other transaction or business dealing made to, by, or with the Debtor, the Debtor's Family, an Associated Individual, or an Associated Entity.

8. All Documents related to any aircraft owned, controlled, or used by the Debtor, including without limitation (i) the aircraft bearing tail number T7-GQM and any other aircraft

## Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 244 of 439

12. All Documents and communications with the Debtor, the Debtor's Family, or an Associated Individual.

13. All Documents and communications between any of your counsel or other advisors and the Debtor, the Debtor's Family, or an Associated Individual.

## Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 245 of 439

14. All Documents related to any Associated Entity that You hold or have held an interest in.

# Exhibit C-13

#### B2540 (Form 2540 – Subpoena for Rule 2004 Examination) (12/15) Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 247 of

439

UNITED STATES BANKRUPTCY COURT

**District of Connecticut**

In re HO WAN KWOK, *et al*.,

1 Case No. 22-50073 (JAM) Debtor Chapter 11

(Jointly Administered)

# **SUBPOENA FOR RULE 2004 EXAMINATION**

To: **Sean Lynch**

(*Name of person to whom the subpoena is directed*)

| PLACE | DATE AND TIME | |-------|---------------| | N/A | N/A | | | |

The examination will be recorded by this method: N/A

## **See Requests for Production of Documents, attached hereto.**

Date: **May , 2024**

CLERK OF COURT

*Signature of Clerk or Deputy Clerk Attorney's signature*

The name, address, email address, and telephone number of the attorney representing Luc A. Despins, Chapter 11 Trustee, who issues or requests this subpoena, are:

**Patrick R. Linsey, Esq.; Neubert, Pepe & Monteith, P.C.; 195 Church Street, 13th Floor, New Haven, Connecticut 06510 plinsey@npmlaw.com; (203) 781-2847**

## **Notice to the person who issues or requests this subpoena**

## **PROOF OF SERVICE**

**(This section should not be filed with the court unless required by Fed. R. Civ. P. 45.)**

I received this subpoena for (*name of individual and title, if any*): on (*date*) .

I served the subpoena by delivering a copy to the named person as follows:

on *(date)* ; or

I returned the subpoena unexecuted because:

My fees are \$ for travel and \$ for services, for a total of \$ .

I declare under penalty of perjury that this information is true and correct.

Date:

*Server's signature*

*Printed name and title*

*Server's address*

Additional information concerning attempted service, etc.:

## **Federal Rule of Civil Procedure 45(c), (d), (e), and (g) (Effective 12/1/13) (made applicable in bankruptcy cases by Rule 9016, Federal Rules of Bankruptcy Procedure)**

#### **(c) Place of compliance.**

*(1) For a Trial, Hearing, or Deposition.* A subpoena may command a person to attend a trial, hearing, or deposition only as follows:

(A) within 100 miles of where the person resides, is employed, or regularly transacts business in person; or

(B) within the state where the person resides, is employed, or regularly transacts business in person, if the person

(i) is a party or a party's officer; or

(ii) is commanded to attend a trial and would not incur substantial expense.

*(2) For Other Discovery.* A subpoena may command:

(A) production of documents, or electronically stored information, or things at a place within 100 miles of where the person resides, is employed, or regularly transacts business in person; and

(B) inspection of premises, at the premises to be inspected.

## **(d) Protecting a Person Subject to a Subpoena; Enforcement.**

## *(2) Command to Produce Materials or Permit Inspection.*

(i) At any time, on notice to the commanded person, the serving party may move the court for the district where compliance is required for an order compelling production or inspection.

(ii) These acts may be required only as directed in the order, and the order must protect a person who is neither a party nor a party's officer from significant expense resulting from compliance.

## *(3) Quashing or Modifying a Subpoena.*

*(A) When Required.* On timely motion, the court for the district where compliance is required must quash or modify a subpoena that:

(i) fails to allow a reasonable time to comply;

(ii) requires a person to comply beyond the geographical limits specified in Rule 45(c);

(iii) requires disclosure of privileged or other protected matter, if no exception or waiver applies; or

(iv) subjects a person to undue burden.

*(B) When Permitted.* To protect a person subject to or affected by a subpoena, the court for the district where compliance is required may, on motion, quash or modify the subpoena if it requires:

(i) disclosing a trade secret or other confidential research, development, or commercial information; or

(ii) disclosing an unretained expert's opinion or information that does not describe specific occurrences in dispute and results from the expert's study that was not requested by a party.

(i) shows a substantial need for the testimony or material that cannot be otherwise met without undue hardship; and

(ii) ensures that the subpoenaed person will be reasonably compensated.

#### **(e) Duties in Responding to a Subpoena.**

*(1) Producing Documents or Electronically Stored Information.* These procedures apply to producing documents or electronically stored information:

*(C) Electronically Stored Information Produced in Only One Form.* The person responding need not produce the same electronically stored information in more than one form.

#### *(2) Claiming Privilege or Protection.*

For access to subpoena materials, see Fed.R.Civ.P.45(a) Committee Note (2013)

…

## **Requests for Production of Documents**

## **I. INSTRUCTIONS**

2. Electronically stored information must be produced in accordance with the

following instructions:

name of the native file. The native file must be named after the FIRSTBATES.

Date fields should be provided in the format: mm/dd/yyyy. Date and time fields must be two separate fields. Required metadata listed below:

# Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 252 of 439

# Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 253 of 439

3. Each Request operates and should be construed independently and, unless otherwise indicated, no Request limits the scope of any other Request.

4. All Documents are to be produced as kept in the usual course of business or are to be organized and labeled to correspond with the categories in these Requests.

5. Each Request contained herein extends to all Documents: (a) in Your possession, custody, or control; or (b) in the possession, custody, or control of anyone acting on Your behalf,

## Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 254 of 439

including Your counsel or other representatives and advisors. Each Document shall be produced in its entirety.

## Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 255 of 439

12. All references to Entities includes all affiliates thereof.

13. All references to individual names include all alternative names, aliased, or nicknames.

14. Unless otherwise expressly indicated, the period of time covered by the Document Requests is the period from February 5, 2012 to the date responses to the Document Requests are due.

## **II. RULES OF CONSTRUCTION**

15. The use of (a) any singular noun shall be construed to include the plural, and vice versa, and (b) a verb in any tense shall be construed as the use of the verb in all other tenses.

## **III. DEFINITIONS**

1. "You" or "Your" or "Yourself" means and refers to Sean Lynch, together with all of their agents, attorneys, representatives, employees, and/or anyone acting on their behalf.

3. "Debtor's Son" means Qiang Guo (a/k/a Mileson Kwok, 郭强, or any other alias), together with his employees, agents, counsel, advisors, or anyone acting on his behalf.

4. "Debtor's Daughter" means Mei Guo (a/k/a Mei Gui, 郭美, or any other alias), together with her employees, agents, counsel, advisors, or anyone acting on her behalf.

## Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 257 of 439

6. "Debtor's Family" means, collectively, the Debtor, the Debtor's Son, the Debtor's Daughter, and the Debtor's Purported Wife, and any other familial relation to the Debtor.

## Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 258 of 439

## Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 259 of 439

9. "Including" or any variant thereof means "including without limitation."

10. "And" and "or" mean "and/or," and shall be construed both conjunctively as well as disjunctively in order to maximize their scope.

## Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 260 of 439

11. "Any" and "all" and "each" mean "each and every."

12. "Each" and "every" mean "each and every."

13. "Third Party" means a Person or Entity other than Yourself.

14. "Transfer" shall have the meaning given to it by section 101(54) of the Bankruptcy Code.

## Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 261 of 439

## Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 262 of 439

telexes, instant messages, chats, text messages, telephonic notes, or notes transmitted internally or with third parties.

22. "Transfer" shall have the meaning given to it by section 101(54) of the Bankruptcy Code.

## **IV. DOCUMENTS TO BE PRODUCED**

1. All Documents regarding any income or Asset of the Debtor, the Debtor's Family, the Debtor's estate, an Associated Individuals, or an Associated Entity.

## Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 263 of 439

4. All Documents regarding any investment, business dealings or transactions made by, with, or on behalf of the Debtor, the Debtor's Family, an Associated Individual, or an Associated Entity.

6. All Documents regarding any Transfer, investment, or other transaction or business dealing made to, by, or with the Debtor, the Debtor's Family, an Associated Individual, or an Associated Entity.

## Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 264 of 439

12. All Documents and communications with the Debtor, the Debtor's Family, or an Associated Individual.

13. All Documents and communications between any of your counsel or other advisors and the Debtor, the Debtor's Family, or an Associated Individual.

14. All Documents related to any Associated Entity that You hold or have held an interest in.

Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 265 of 439

# Exhibit C-14

B2540 (Form 2540 – Subpoena for Rule 2004 Examination) (12/15) Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 266 of

UNITED STATES BANKRUPTCY COURT 439

**District of Connecticut**

In re HO WAN KWOK, *et al*.,

1 Case No. 22-50073 (JAM)

Debtor Chapter 11

(Jointly Administered)

## **SUBPOENA FOR RULE 2004 EXAMINATION**

To: **Eddy Aquino (a/k/a Eddy L. Sanchez Aquino)**

(*Name of person to whom the subpoena is directed*)

| PLACE | DATE AND TIME | |-------|---------------| | N/A | N/A | | | |

The examination will be recorded by this method: N/A

## **See Requests for Production of Documents, attached hereto.**

Date: **May , 2024**

CLERK OF COURT

*Signature of Clerk or Deputy Clerk Attorney's signature*

The name, address, email address, and telephone number of the attorney representing Luc A. Despins, Chapter 11 Trustee, who issues or requests this subpoena, are:

**Patrick R. Linsey, Esq.; Neubert, Pepe & Monteith, P.C.; 195 Church Street, 13th Floor, New Haven, Connecticut 06510 plinsey@npmlaw.com; (203) 781-2847**

## **Notice to the person who issues or requests this subpoena**

## **PROOF OF SERVICE**

**(This section should not be filed with the court unless required by Fed. R. Civ. P. 45.)**

I received this subpoena for (*name of individual and title, if any*): on (*date*) .

I served the subpoena by delivering a copy to the named person as follows:

on *(date)* ; or

I returned the subpoena unexecuted because:

My fees are \$ for travel and \$ for services, for a total of \$ .

I declare under penalty of perjury that this information is true and correct.

Date:

*Server's signature*

*Printed name and title*

*Server's address*

Additional information concerning attempted service, etc.:

## **Federal Rule of Civil Procedure 45(c), (d), (e), and (g) (Effective 12/1/13) (made applicable in bankruptcy cases by Rule 9016, Federal Rules of Bankruptcy Procedure)**

#### **(c) Place of compliance.**

*(1) For a Trial, Hearing, or Deposition.* A subpoena may command a person to attend a trial, hearing, or deposition only as follows:

(A) within 100 miles of where the person resides, is employed, or regularly transacts business in person; or

(B) within the state where the person resides, is employed, or regularly transacts business in person, if the person

(i) is a party or a party's officer; or

(ii) is commanded to attend a trial and would not incur substantial expense.

*(2) For Other Discovery.* A subpoena may command:

(A) production of documents, or electronically stored information, or things at a place within 100 miles of where the person resides, is employed, or regularly transacts business in person; and

(B) inspection of premises, at the premises to be inspected.

## **(d) Protecting a Person Subject to a Subpoena; Enforcement.**

## *(2) Command to Produce Materials or Permit Inspection.*

(i) At any time, on notice to the commanded person, the serving party may move the court for the district where compliance is required for an order compelling production or inspection.

(ii) These acts may be required only as directed in the order, and the order must protect a person who is neither a party nor a party's officer from significant expense resulting from compliance.

## *(3) Quashing or Modifying a Subpoena.*

*(A) When Required.* On timely motion, the court for the district where compliance is required must quash or modify a subpoena that:

(i) fails to allow a reasonable time to comply;

(ii) requires a person to comply beyond the geographical limits specified in Rule 45(c);

(iii) requires disclosure of privileged or other protected matter, if no exception or waiver applies; or

(iv) subjects a person to undue burden.

*(B) When Permitted.* To protect a person subject to or affected by a subpoena, the court for the district where compliance is required may, on motion, quash or modify the subpoena if it requires:

(i) disclosing a trade secret or other confidential research, development, or commercial information; or

(ii) disclosing an unretained expert's opinion or information that does not describe specific occurrences in dispute and results from the expert's study that was not requested by a party.

(i) shows a substantial need for the testimony or material that cannot be otherwise met without undue hardship; and

(ii) ensures that the subpoenaed person will be reasonably compensated.

#### **(e) Duties in Responding to a Subpoena.**

*(1) Producing Documents or Electronically Stored Information.* These procedures apply to producing documents or electronically stored information:

*(C) Electronically Stored Information Produced in Only One Form.* The person responding need not produce the same electronically stored information in more than one form.

#### *(2) Claiming Privilege or Protection.*

For access to subpoena materials, see Fed.R.Civ.P.45(a) Committee Note (2013)

…

## **Requests for Production of Documents**

## **I. INSTRUCTIONS**

2. Electronically stored information must be produced in accordance with the

following instructions:

name of the native file. The native file must be named after the FIRSTBATES.

Date fields should be provided in the format: mm/dd/yyyy. Date and time fields must be two separate fields. Required metadata listed below:

# Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 271 of 439

# Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 272 of 439

3. Each Request operates and should be construed independently and, unless otherwise indicated, no Request limits the scope of any other Request.

4. All Documents are to be produced as kept in the usual course of business or are to be organized and labeled to correspond with the categories in these Requests.

5. Each Request contained herein extends to all Documents: (a) in Your possession, custody, or control; or (b) in the possession, custody, or control of anyone acting on Your behalf,

## Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 273 of 439

including Your counsel or other representatives and advisors. Each Document shall be produced in its entirety.

## Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 274 of 439

12. All references to Entities includes all affiliates thereof.

13. All references to individual names include all alternative names, aliased, or nicknames.

14. Unless otherwise expressly indicated, the period of time covered by the Document Requests is the period from February 5, 2012 to the date responses to the Document Requests are due.

## **II. RULES OF CONSTRUCTION**

15. The use of (a) any singular noun shall be construed to include the plural, and vice versa, and (b) a verb in any tense shall be construed as the use of the verb in all other tenses.

## **III. DEFINITIONS**

1. "You" or "Your" or "Yourself" means and refers to Eddy Aquino (a/k/a Eddy I. Sanchez Aquino), together with all of their agents, attorneys, representatives, employees, and/or anyone acting on their behalf.

3. "Debtor's Son" means Qiang Guo (a/k/a Mileson Kwok, 郭强, or any other alias), together with his employees, agents, counsel, advisors, or anyone acting on his behalf.

## Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 276 of 439

4. "Debtor's Daughter" means Mei Guo (a/k/a Mei Gui, 郭美, or any other alias), together with her employees, agents, counsel, advisors, or anyone acting on her behalf.

6. "Debtor's Family" means, collectively, the Debtor, the Debtor's Son, the Debtor's Daughter, and the Debtor's Purported Wife, and any other familial relation to the Debtor.

## Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 277 of 439

## Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 278 of 439

9. "Including" or any variant thereof means "including without limitation."

## Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 279 of 439

10. "And" and "or" mean "and/or," and shall be construed both conjunctively as well as disjunctively in order to maximize their scope.

11. "Any" and "all" and "each" mean "each and every."

12. "Each" and "every" mean "each and every."

13. "Third Party" means a Person or Entity other than Yourself.

14. "Transfer" shall have the meaning given to it by section 101(54) of the Bankruptcy Code.

## Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 280 of 439

of the foregoing that contain any notes, comments, or markings of any kind not found on the original documents or that are otherwise not identical to the original documents.

## Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 281 of 439

22. "Transfer" shall have the meaning given to it by section 101(54) of the Bankruptcy Code.

## **IV. DOCUMENTS TO BE PRODUCED**

1. All Documents regarding any income or Asset of the Debtor, the Debtor's Family, the Debtor's estate, an Associated Individuals, or an Associated Entity.

## Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 282 of 439

or an Associated Individual, including without limitation all Documents sufficient to show all Transfers to any of the foregoing.

4. All Documents regarding any investment, business dealings or transactions made by, with, or on behalf of the Debtor, the Debtor's Family, an Associated Individual, or an Associated Entity.

6. All Documents regarding any Transfer, investment, or other transaction or business dealing made to, by, or with the Debtor, the Debtor's Family, an Associated Individual, or an Associated Entity.

8. All Documents related to any aircraft owned, controlled, or used by the Debtor, including without limitation (i) the aircraft bearing tail number T7-GQM and any other aircraft

## Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 283 of 439

12. All Documents and communications with the Debtor, the Debtor's Family, or an Associated Individual.

13. All Documents and communications between any of your counsel or other advisors and the Debtor, the Debtor's Family, or an Associated Individual.

## Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 284 of 439

14. All Documents related to any Associated Entity that You hold or have held an interest in.

Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 285 of 439

# Exhibit C-15

B2540 (Form 2540 – Subpoena for Rule 2004 Examination) (12/15) Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 286 of

UNITED STATES BANKRUPTCY COURT 439

**District of Connecticut**

In re HO WAN KWOK, *et al*.,

1 Case No. 22-50073 (JAM)

Debtor Chapter 11

(Jointly Administered)

## **SUBPOENA FOR RULE 2004 EXAMINATION**

To: **Summer L. Bridges**

(*Name of person to whom the subpoena is directed*)

| PLACE | DATE AND TIME | |-------|---------------| | N/A | N/A | | | |

The examination will be recorded by this method: N/A

## **See Requests for Production of Documents, attached hereto.**

Date: **May , 2024**

CLERK OF COURT

*Signature of Clerk or Deputy Clerk Attorney's signature*

The name, address, email address, and telephone number of the attorney representing Luc A. Despins, Chapter 11 Trustee, who issues or requests this subpoena, are:

**Patrick R. Linsey, Esq.; Neubert, Pepe & Monteith, P.C.; 195 Church Street, 13th Floor, New Haven, Connecticut 06510 plinsey@npmlaw.com; (203) 781-2847**

## **Notice to the person who issues or requests this subpoena**

## **PROOF OF SERVICE**

**(This section should not be filed with the court unless required by Fed. R. Civ. P. 45.)**

I received this subpoena for (*name of individual and title, if any*): on (*date*) .

I served the subpoena by delivering a copy to the named person as follows:

on *(date)* ; or

I returned the subpoena unexecuted because:

My fees are \$ for travel and \$ for services, for a total of \$ .

I declare under penalty of perjury that this information is true and correct.

Date:

*Server's signature*

*Printed name and title*

*Server's address*

Additional information concerning attempted service, etc.:

## **Federal Rule of Civil Procedure 45(c), (d), (e), and (g) (Effective 12/1/13) (made applicable in bankruptcy cases by Rule 9016, Federal Rules of Bankruptcy Procedure)**

#### **(c) Place of compliance.**

*(1) For a Trial, Hearing, or Deposition.* A subpoena may command a person to attend a trial, hearing, or deposition only as follows:

(A) within 100 miles of where the person resides, is employed, or regularly transacts business in person; or

(B) within the state where the person resides, is employed, or regularly transacts business in person, if the person

(i) is a party or a party's officer; or

(ii) is commanded to attend a trial and would not incur substantial expense.

*(2) For Other Discovery.* A subpoena may command:

(A) production of documents, or electronically stored information, or things at a place within 100 miles of where the person resides, is employed, or regularly transacts business in person; and

(B) inspection of premises, at the premises to be inspected.

## **(d) Protecting a Person Subject to a Subpoena; Enforcement.**

## *(2) Command to Produce Materials or Permit Inspection.*

(i) At any time, on notice to the commanded person, the serving party may move the court for the district where compliance is required for an order compelling production or inspection.

(ii) These acts may be required only as directed in the order, and the order must protect a person who is neither a party nor a party's officer from significant expense resulting from compliance.

## *(3) Quashing or Modifying a Subpoena.*

*(A) When Required.* On timely motion, the court for the district where compliance is required must quash or modify a subpoena that:

(i) fails to allow a reasonable time to comply;

(ii) requires a person to comply beyond the geographical limits specified in Rule 45(c);

(iii) requires disclosure of privileged or other protected matter, if no exception or waiver applies; or

(iv) subjects a person to undue burden.

*(B) When Permitted.* To protect a person subject to or affected by a subpoena, the court for the district where compliance is required may, on motion, quash or modify the subpoena if it requires:

(i) disclosing a trade secret or other confidential research, development, or commercial information; or

(ii) disclosing an unretained expert's opinion or information that does not describe specific occurrences in dispute and results from the expert's study that was not requested by a party.

(i) shows a substantial need for the testimony or material that cannot be otherwise met without undue hardship; and

(ii) ensures that the subpoenaed person will be reasonably compensated.

#### **(e) Duties in Responding to a Subpoena.**

*(1) Producing Documents or Electronically Stored Information.* These procedures apply to producing documents or electronically stored information:

*(C) Electronically Stored Information Produced in Only One Form.* The person responding need not produce the same electronically stored information in more than one form.

#### *(2) Claiming Privilege or Protection.*

For access to subpoena materials, see Fed.R.Civ.P.45(a) Committee Note (2013)

…

## **Requests for Production of Documents**

## **I. INSTRUCTIONS**

2. Electronically stored information must be produced in accordance with the

following instructions:

name of the native file. The native file must be named after the FIRSTBATES.

Date fields should be provided in the format: mm/dd/yyyy. Date and time fields must be two separate fields. Required metadata listed below:

# Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 291 of 439

# Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 292 of 439

3. Each Request operates and should be construed independently and, unless otherwise indicated, no Request limits the scope of any other Request.

4. All Documents are to be produced as kept in the usual course of business or are to be organized and labeled to correspond with the categories in these Requests.

5. Each Request contained herein extends to all Documents: (a) in Your possession, custody, or control; or (b) in the possession, custody, or control of anyone acting on Your behalf,

## Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 293 of 439

including Your counsel or other representatives and advisors. Each Document shall be produced in its entirety.

## Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 294 of 439

12. All references to Entities includes all affiliates thereof.

13. All references to individual names include all alternative names, aliased, or nicknames.

14. Unless otherwise expressly indicated, the period of time covered by the Document Requests is the period from February 5, 2012 to the date responses to the Document Requests are due.

## Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 295 of 439

## **II. RULES OF CONSTRUCTION**

15. The use of (a) any singular noun shall be construed to include the plural, and vice versa, and (b) a verb in any tense shall be construed as the use of the verb in all other tenses.

## **III. DEFINITIONS**

1. "You" or "Your" or "Yourself" means and refers to Summer L. Bridges, together with all of their agents, attorneys, representatives, employees, and/or anyone acting on their behalf.

3. "Debtor's Son" means Qiang Guo (a/k/a Mileson Kwok, 郭强, or any other alias), together with his employees, agents, counsel, advisors, or anyone acting on his behalf.

## Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 296 of 439

4. "Debtor's Daughter" means Mei Guo (a/k/a Mei Gui, 郭美, or any other alias), together with her employees, agents, counsel, advisors, or anyone acting on her behalf.

6. "Debtor's Family" means, collectively, the Debtor, the Debtor's Son, the Debtor's Daughter, and the Debtor's Purported Wife, and any other familial relation to the Debtor.

## Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 297 of 439

## Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 298 of 439

9. "Including" or any variant thereof means "including without limitation."

## Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 299 of 439

10. "And" and "or" mean "and/or," and shall be construed both conjunctively as well as disjunctively in order to maximize their scope.

11. "Any" and "all" and "each" mean "each and every."

12. "Each" and "every" mean "each and every."

13. "Third Party" means a Person or Entity other than Yourself.

14. "Transfer" shall have the meaning given to it by section 101(54) of the Bankruptcy Code.

## Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 300 of 439

of the foregoing that contain any notes, comments, or markings of any kind not found on the original documents or that are otherwise not identical to the original documents.

## Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 301 of 439

22. "Transfer" shall have the meaning given to it by section 101(54) of the Bankruptcy Code.

## **IV. DOCUMENTS TO BE PRODUCED**

1. All Documents regarding any income or Asset of the Debtor, the Debtor's Family, the Debtor's estate, an Associated Individuals, or an Associated Entity.

## Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 302 of 439

or an Associated Individual, including without limitation all Documents sufficient to show all Transfers to any of the foregoing.

4. All Documents regarding any investment, business dealings or transactions made by, with, or on behalf of the Debtor, the Debtor's Family, an Associated Individual, or an Associated Entity.

6. All Documents regarding any Transfer, investment, or other transaction or business dealing made to, by, or with the Debtor, the Debtor's Family, an Associated Individual, or an Associated Entity.

8. All Documents related to any aircraft owned, controlled, or used by the Debtor, including without limitation (i) the aircraft bearing tail number T7-GQM and any other aircraft

## Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 303 of 439

12. All Documents and communications with the Debtor, the Debtor's Family, or an Associated Individual.

13. All Documents and communications between any of your counsel or other advisors and the Debtor, the Debtor's Family, or an Associated Individual.

## Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 304 of 439

14. All Documents related to any Associated Entity that You hold or have held an interest in.

# Exhibit C-16

#### B2540 (Form 2540 – Subpoena for Rule 2004 Examination) (12/15) Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 306 of

439

UNITED STATES BANKRUPTCY COURT

**District of Connecticut**

In re HO WAN KWOK, *et al*.,

1 Case No. 22-50073 (JAM) Debtor Chapter 11

(Jointly Administered)

# **SUBPOENA FOR RULE 2004 EXAMINATION**

To: **Michael Baranowitz**

(*Name of person to whom the subpoena is directed*)

| PLACE | DATE AND TIME | |-------|---------------| | N/A | N/A | | | |

The examination will be recorded by this method: N/A

## **See Requests for Production of Documents, attached hereto.**

Date: **May , 2024**

CLERK OF COURT

*Signature of Clerk or Deputy Clerk Attorney's signature*

The name, address, email address, and telephone number of the attorney representing Luc A. Despins, Chapter 11 Trustee, who issues or requests this subpoena, are:

**Patrick R. Linsey, Esq.; Neubert, Pepe & Monteith, P.C.; 195 Church Street, 13th Floor, New Haven, Connecticut 06510 plinsey@npmlaw.com; (203) 781-2847**

## **Notice to the person who issues or requests this subpoena**

## **PROOF OF SERVICE**

**(This section should not be filed with the court unless required by Fed. R. Civ. P. 45.)**

I received this subpoena for (*name of individual and title, if any*): on (*date*) .

I served the subpoena by delivering a copy to the named person as follows:

on *(date)* ; or

I returned the subpoena unexecuted because:

My fees are \$ for travel and \$ for services, for a total of \$ .

I declare under penalty of perjury that this information is true and correct.

Date:

*Server's signature*

*Printed name and title*

*Server's address*

Additional information concerning attempted service, etc.:

## **Federal Rule of Civil Procedure 45(c), (d), (e), and (g) (Effective 12/1/13) (made applicable in bankruptcy cases by Rule 9016, Federal Rules of Bankruptcy Procedure)**

#### **(c) Place of compliance.**

*(1) For a Trial, Hearing, or Deposition.* A subpoena may command a person to attend a trial, hearing, or deposition only as follows:

(A) within 100 miles of where the person resides, is employed, or regularly transacts business in person; or

(B) within the state where the person resides, is employed, or regularly transacts business in person, if the person

(i) is a party or a party's officer; or

(ii) is commanded to attend a trial and would not incur substantial expense.

*(2) For Other Discovery.* A subpoena may command:

(A) production of documents, or electronically stored information, or things at a place within 100 miles of where the person resides, is employed, or regularly transacts business in person; and

(B) inspection of premises, at the premises to be inspected.

## **(d) Protecting a Person Subject to a Subpoena; Enforcement.**

## *(2) Command to Produce Materials or Permit Inspection.*

(i) At any time, on notice to the commanded person, the serving party may move the court for the district where compliance is required for an order compelling production or inspection.

(ii) These acts may be required only as directed in the order, and the order must protect a person who is neither a party nor a party's officer from significant expense resulting from compliance.

## *(3) Quashing or Modifying a Subpoena.*

*(A) When Required.* On timely motion, the court for the district where compliance is required must quash or modify a subpoena that:

(i) fails to allow a reasonable time to comply;

(ii) requires a person to comply beyond the geographical limits specified in Rule 45(c);

(iii) requires disclosure of privileged or other protected matter, if no exception or waiver applies; or

(iv) subjects a person to undue burden.

*(B) When Permitted.* To protect a person subject to or affected by a subpoena, the court for the district where compliance is required may, on motion, quash or modify the subpoena if it requires:

(i) disclosing a trade secret or other confidential research, development, or commercial information; or

(ii) disclosing an unretained expert's opinion or information that does not describe specific occurrences in dispute and results from the expert's study that was not requested by a party.

(i) shows a substantial need for the testimony or material that cannot be otherwise met without undue hardship; and

(ii) ensures that the subpoenaed person will be reasonably compensated.

#### **(e) Duties in Responding to a Subpoena.**

*(1) Producing Documents or Electronically Stored Information.* These procedures apply to producing documents or electronically stored information:

*(C) Electronically Stored Information Produced in Only One Form.* The person responding need not produce the same electronically stored information in more than one form.

#### *(2) Claiming Privilege or Protection.*

For access to subpoena materials, see Fed.R.Civ.P.45(a) Committee Note (2013)

…

## **Requests for Production of Documents**

## **I. INSTRUCTIONS**

2. Electronically stored information must be produced in accordance with the

following instructions:

name of the native file. The native file must be named after the FIRSTBATES.

Date fields should be provided in the format: mm/dd/yyyy. Date and time fields must be two separate fields. Required metadata listed below:

# Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 311 of 439

# Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 312 of 439

| TIME_CREATED | 10:25 AM | Email: (empty) | |--------------|---------------------------|-------------------------------------------------| | | | Native: Time the document was created | | | | **This data must be a separate field and cannot | | | | be combined with the DATE_CREATED field | | DATE_MOD | 10/12/2010 | Email: (empty) | | | | Native: Date the document was last modified | | TIME_MOD | 07:00 PM | Email: (empty) | | | | Native: Time the document was last modified | | | | **This data must be a separate field and cannot | | | | be combined with the DATE_MOD field | | DATE_ACCESSD | 10/12/2010 | Email: (empty) | | | | Native: Date the document was last accessed | | TIME_ACCESSD | 07:00 PM | Email: (empty) | | | | Native: Time the document was last accessed | | | | **This data must be a separate field and cannot | | | | be combined with the DATE_ACCESSD field | | FILE_SIZE | 5,952 | Size of native file document/email in KB | | PGCOUNT | 1 | Number of pages in native file document/email | | PATH | | Email: (empty) | | | Agenda.doc | Native: Path where native file document was | | | | stored including original file name. | | INTFILEPATH | Personal Folders\Deleted | Email: original location of email including | | | Items\Board Meeting | original file name. | | | Minutes.msg | Native: (empty) | | INTMSGID | <000805c2c71b\$75977050\$ | Email: Unique Message ID Native: (empty) | | | cb8306d1@MSN> | | | MD5HASH | d131dd02c5e6eec4693d9a0 | MD5 Hash value of the document. | | | 698aff95c | | | | 2fcab58712467eab4004583e | | | | b8fb7f89 | | | OCRPATH | TEXT/001/EDC0000001.txt | Path to extracted text of the native file |

3. Each Request operates and should be construed independently and, unless otherwise indicated, no Request limits the scope of any other Request.

4. All Documents are to be produced as kept in the usual course of business or are to be organized and labeled to correspond with the categories in these Requests.

5. Each Request contained herein extends to all Documents: (a) in Your possession, custody, or control; or (b) in the possession, custody, or control of anyone acting on Your behalf,

## Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 313 of 439

including Your counsel or other representatives and advisors. Each Document shall be produced in its entirety.

## Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 314 of 439

12. All references to Entities includes all affiliates thereof.

13. All references to individual names include all alternative names, aliased, or nicknames.

14. Unless otherwise expressly indicated, the period of time covered by the Document Requests is the period from February 5, 2012 to the date responses to the Document Requests are due.

## Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 315 of 439

## **II. RULES OF CONSTRUCTION**

15. The use of (a) any singular noun shall be construed to include the plural, and vice versa, and (b) a verb in any tense shall be construed as the use of the verb in all other tenses.

## **III. DEFINITIONS**

1. "You" or "Your" or "Yourself" means and refers to Michael Baranowitz, together with all of their agents, attorneys, representatives, employees, and/or anyone acting on their behalf.

3. "Debtor's Son" means Qiang Guo (a/k/a Mileson Kwok, 郭强, or any other alias), together with his employees, agents, counsel, advisors, or anyone acting on his behalf.

## Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 316 of 439

4. "Debtor's Daughter" means Mei Guo (a/k/a Mei Gui, 郭美, or any other alias), together with her employees, agents, counsel, advisors, or anyone acting on her behalf.

6. "Debtor's Family" means, collectively, the Debtor, the Debtor's Son, the Debtor's Daughter, and the Debtor's Purported Wife, and any other familial relation to the Debtor.

## Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 317 of 439

## Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 318 of 439

9. "Including" or any variant thereof means "including without limitation."

## Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 319 of 439

10. "And" and "or" mean "and/or," and shall be construed both conjunctively as well as disjunctively in order to maximize their scope.

11. "Any" and "all" and "each" mean "each and every."

12. "Each" and "every" mean "each and every."

13. "Third Party" means a Person or Entity other than Yourself.

14. "Transfer" shall have the meaning given to it by section 101(54) of the Bankruptcy Code.

## Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 320 of 439

of the foregoing that contain any notes, comments, or markings of any kind not found on the original documents or that are otherwise not identical to the original documents.

## Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 321 of 439

22. "Transfer" shall have the meaning given to it by section 101(54) of the Bankruptcy Code.

## **IV. DOCUMENTS TO BE PRODUCED**

1. All Documents regarding any income or Asset of the Debtor, the Debtor's Family, the Debtor's estate, an Associated Individuals, or an Associated Entity.

## Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 322 of 439

or an Associated Individual, including without limitation all Documents sufficient to show all Transfers to any of the foregoing.

4. All Documents regarding any investment, business dealings or transactions made by, with, or on behalf of the Debtor, the Debtor's Family, an Associated Individual, or an Associated Entity.

6. All Documents regarding any Transfer, investment, or other transaction or business dealing made to, by, or with the Debtor, the Debtor's Family, an Associated Individual, or an Associated Entity.

8. All Documents related to any aircraft owned, controlled, or used by the Debtor, including without limitation (i) the aircraft bearing tail number T7-GQM and any other aircraft

## Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 323 of 439

12. All Documents and communications with the Debtor, the Debtor's Family, or an Associated Individual.

13. All Documents and communications between any of your counsel or other advisors and the Debtor, the Debtor's Family, or an Associated Individual.

## Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 324 of 439

14. All Documents related to any Associated Entity that You hold or have held an interest in.

Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 325 of 439

# Exhibit C-17

#### B2540 (Form 2540 – Subpoena for Rule 2004 Examination) (12/15) Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 326 of

439

UNITED STATES BANKRUPTCY COURT

**District of Connecticut**

In re HO WAN KWOK, *et al*.,

1 Case No. 22-50073 (JAM) Debtor Chapter 11

(Jointly Administered)

# **SUBPOENA FOR RULE 2004 EXAMINATION**

To: **Maya Fawaz**

(*Name of person to whom the subpoena is directed*)

| PLACE | DATE AND TIME | |-------|---------------| | N/A | N/A | | | |

The examination will be recorded by this method: N/A

## **See Requests for Production of Documents, attached hereto.**

Date: **May , 2024**

CLERK OF COURT

*Signature of Clerk or Deputy Clerk Attorney's signature*

The name, address, email address, and telephone number of the attorney representing Luc A. Despins, Chapter 11 Trustee, who issues or requests this subpoena, are:

**Patrick R. Linsey, Esq.; Neubert, Pepe & Monteith, P.C.; 195 Church Street, 13th Floor, New Haven, Connecticut 06510 plinsey@npmlaw.com; (203) 781-2847**

## **Notice to the person who issues or requests this subpoena**

## **PROOF OF SERVICE**

**(This section should not be filed with the court unless required by Fed. R. Civ. P. 45.)**

I received this subpoena for (*name of individual and title, if any*): on (*date*) .

I served the subpoena by delivering a copy to the named person as follows:

on *(date)* ; or

I returned the subpoena unexecuted because:

My fees are \$ for travel and \$ for services, for a total of \$ .

I declare under penalty of perjury that this information is true and correct.

Date:

*Server's signature*

*Printed name and title*

*Server's address*

Additional information concerning attempted service, etc.:

## **Federal Rule of Civil Procedure 45(c), (d), (e), and (g) (Effective 12/1/13) (made applicable in bankruptcy cases by Rule 9016, Federal Rules of Bankruptcy Procedure)**

#### **(c) Place of compliance.**

*(1) For a Trial, Hearing, or Deposition.* A subpoena may command a person to attend a trial, hearing, or deposition only as follows:

(A) within 100 miles of where the person resides, is employed, or regularly transacts business in person; or

(B) within the state where the person resides, is employed, or regularly transacts business in person, if the person

(i) is a party or a party's officer; or

(ii) is commanded to attend a trial and would not incur substantial expense.

*(2) For Other Discovery.* A subpoena may command:

(A) production of documents, or electronically stored information, or things at a place within 100 miles of where the person resides, is employed, or regularly transacts business in person; and

(B) inspection of premises, at the premises to be inspected.

## **(d) Protecting a Person Subject to a Subpoena; Enforcement.**

## *(2) Command to Produce Materials or Permit Inspection.*

(i) At any time, on notice to the commanded person, the serving party may move the court for the district where compliance is required for an order compelling production or inspection.

(ii) These acts may be required only as directed in the order, and the order must protect a person who is neither a party nor a party's officer from significant expense resulting from compliance.

## *(3) Quashing or Modifying a Subpoena.*

*(A) When Required.* On timely motion, the court for the district where compliance is required must quash or modify a subpoena that:

(i) fails to allow a reasonable time to comply;

(ii) requires a person to comply beyond the geographical limits specified in Rule 45(c);

(iii) requires disclosure of privileged or other protected matter, if no exception or waiver applies; or

(iv) subjects a person to undue burden.

*(B) When Permitted.* To protect a person subject to or affected by a subpoena, the court for the district where compliance is required may, on motion, quash or modify the subpoena if it requires:

(i) disclosing a trade secret or other confidential research, development, or commercial information; or

(ii) disclosing an unretained expert's opinion or information that does not describe specific occurrences in dispute and results from the expert's study that was not requested by a party.

(i) shows a substantial need for the testimony or material that cannot be otherwise met without undue hardship; and

(ii) ensures that the subpoenaed person will be reasonably compensated.

#### **(e) Duties in Responding to a Subpoena.**

*(1) Producing Documents or Electronically Stored Information.* These procedures apply to producing documents or electronically stored information:

*(C) Electronically Stored Information Produced in Only One Form.* The person responding need not produce the same electronically stored information in more than one form.

#### *(2) Claiming Privilege or Protection.*

For access to subpoena materials, see Fed.R.Civ.P.45(a) Committee Note (2013)

…

## **Requests for Production of Documents**

## **I. INSTRUCTIONS**

2. Electronically stored information must be produced in accordance with the

following instructions:

name of the native file. The native file must be named after the FIRSTBATES.

Date fields should be provided in the format: mm/dd/yyyy. Date and time fields must be two separate fields. Required metadata listed below:

# Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 331 of 439

# Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 332 of 439

3. Each Request operates and should be construed independently and, unless otherwise indicated, no Request limits the scope of any other Request.

4. All Documents are to be produced as kept in the usual course of business or are to be organized and labeled to correspond with the categories in these Requests.

5. Each Request contained herein extends to all Documents: (a) in Your possession, custody, or control; or (b) in the possession, custody, or control of anyone acting on Your behalf,

## Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 333 of 439

including Your counsel or other representatives and advisors. Each Document shall be produced in its entirety.

## Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 334 of 439

12. All references to Entities includes all affiliates thereof.

13. All references to individual names include all alternative names, aliased, or nicknames.

14. Unless otherwise expressly indicated, the period of time covered by the Document Requests is the period from February 5, 2012 to the date responses to the Document Requests are due.

## **II. RULES OF CONSTRUCTION**

15. The use of (a) any singular noun shall be construed to include the plural, and vice versa, and (b) a verb in any tense shall be construed as the use of the verb in all other tenses.

## **III. DEFINITIONS**

1. "You" or "Your" or "Yourself" means and refers to Maya Fawaz, together with all of their agents, attorneys, representatives, employees, and/or anyone acting on their behalf.

3. "Debtor's Son" means Qiang Guo (a/k/a Mileson Kwok, 郭强, or any other alias), together with his employees, agents, counsel, advisors, or anyone acting on his behalf.

4. "Debtor's Daughter" means Mei Guo (a/k/a Mei Gui, 郭美, or any other alias), together with her employees, agents, counsel, advisors, or anyone acting on her behalf.

## Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 336 of 439

6. "Debtor's Family" means, collectively, the Debtor, the Debtor's Son, the Debtor's Daughter, and the Debtor's Purported Wife, and any other familial relation to the Debtor.

## Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 337 of 439

## Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 338 of 439

9. "Including" or any variant thereof means "including without limitation."

10. "And" and "or" mean "and/or," and shall be construed both conjunctively as well as disjunctively in order to maximize their scope.

## Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 339 of 439

11. "Any" and "all" and "each" mean "each and every."

12. "Each" and "every" mean "each and every."

13. "Third Party" means a Person or Entity other than Yourself.

14. "Transfer" shall have the meaning given to it by section 101(54) of the Bankruptcy Code.

## Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 340 of 439

## Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 341 of 439

telexes, instant messages, chats, text messages, telephonic notes, or notes transmitted internally or with third parties.

22. "Transfer" shall have the meaning given to it by section 101(54) of the Bankruptcy Code.

## **IV. DOCUMENTS TO BE PRODUCED**

1. All Documents regarding any income or Asset of the Debtor, the Debtor's Family, the Debtor's estate, an Associated Individuals, or an Associated Entity.

## Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 342 of 439

4. All Documents regarding any investment, business dealings or transactions made by, with, or on behalf of the Debtor, the Debtor's Family, an Associated Individual, or an Associated Entity.

6. All Documents regarding any Transfer, investment, or other transaction or business dealing made to, by, or with the Debtor, the Debtor's Family, an Associated Individual, or an Associated Entity.

## Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 343 of 439

12. All Documents and communications with the Debtor, the Debtor's Family, or an Associated Individual.

13. All Documents and communications between any of your counsel or other advisors and the Debtor, the Debtor's Family, or an Associated Individual.

14. All Documents related to any Associated Entity that You hold or have held an interest in.

# Exhibit C-18

#### B2540 (Form 2540 – Subpoena for Rule 2004 Examination) (12/15) Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 345 of

439

UNITED STATES BANKRUPTCY COURT

**District of Connecticut**

In re HO WAN KWOK, *et al*.,

1 Case No. 22-50073 (JAM) Debtor Chapter 11

(Jointly Administered)

# **SUBPOENA FOR RULE 2004 EXAMINATION**

To: **Andrea Volpe**

(*Name of person to whom the subpoena is directed*)

| PLACE | DATE AND TIME | |-------|---------------| | N/A | N/A | | | |

The examination will be recorded by this method: N/A

## **See Requests for Production of Documents, attached hereto.**

Date: **May , 2024**

CLERK OF COURT

*Signature of Clerk or Deputy Clerk Attorney's signature*

The name, address, email address, and telephone number of the attorney representing Luc A. Despins, Chapter 11 Trustee, who issues or requests this subpoena, are:

**Patrick R. Linsey, Esq.; Neubert, Pepe & Monteith, P.C.; 195 Church Street, 13th Floor, New Haven, Connecticut 06510 plinsey@npmlaw.com; (203) 781-2847**

## **Notice to the person who issues or requests this subpoena**

## **PROOF OF SERVICE**

**(This section should not be filed with the court unless required by Fed. R. Civ. P. 45.)**

I received this subpoena for (*name of individual and title, if any*): on (*date*) .

I served the subpoena by delivering a copy to the named person as follows:

on *(date)* ; or

I returned the subpoena unexecuted because:

My fees are \$ for travel and \$ for services, for a total of \$ .

I declare under penalty of perjury that this information is true and correct.

Date:

*Server's signature*

*Printed name and title*

*Server's address*

Additional information concerning attempted service, etc.:

## **Federal Rule of Civil Procedure 45(c), (d), (e), and (g) (Effective 12/1/13) (made applicable in bankruptcy cases by Rule 9016, Federal Rules of Bankruptcy Procedure)**

#### **(c) Place of compliance.**

*(1) For a Trial, Hearing, or Deposition.* A subpoena may command a person to attend a trial, hearing, or deposition only as follows:

(A) within 100 miles of where the person resides, is employed, or regularly transacts business in person; or

(B) within the state where the person resides, is employed, or regularly transacts business in person, if the person

(i) is a party or a party's officer; or

(ii) is commanded to attend a trial and would not incur substantial expense.

*(2) For Other Discovery.* A subpoena may command:

(A) production of documents, or electronically stored information, or things at a place within 100 miles of where the person resides, is employed, or regularly transacts business in person; and

(B) inspection of premises, at the premises to be inspected.

## **(d) Protecting a Person Subject to a Subpoena; Enforcement.**

## *(2) Command to Produce Materials or Permit Inspection.*

(i) At any time, on notice to the commanded person, the serving party may move the court for the district where compliance is required for an order compelling production or inspection.

(ii) These acts may be required only as directed in the order, and the order must protect a person who is neither a party nor a party's officer from significant expense resulting from compliance.

## *(3) Quashing or Modifying a Subpoena.*

*(A) When Required.* On timely motion, the court for the district where compliance is required must quash or modify a subpoena that:

(i) fails to allow a reasonable time to comply;

(ii) requires a person to comply beyond the geographical limits specified in Rule 45(c);

(iii) requires disclosure of privileged or other protected matter, if no exception or waiver applies; or

(iv) subjects a person to undue burden.

*(B) When Permitted.* To protect a person subject to or affected by a subpoena, the court for the district where compliance is required may, on motion, quash or modify the subpoena if it requires:

(i) disclosing a trade secret or other confidential research, development, or commercial information; or

(ii) disclosing an unretained expert's opinion or information that does not describe specific occurrences in dispute and results from the expert's study that was not requested by a party.

(i) shows a substantial need for the testimony or material that cannot be otherwise met without undue hardship; and

(ii) ensures that the subpoenaed person will be reasonably compensated.

#### **(e) Duties in Responding to a Subpoena.**

*(1) Producing Documents or Electronically Stored Information.* These procedures apply to producing documents or electronically stored information:

*(C) Electronically Stored Information Produced in Only One Form.* The person responding need not produce the same electronically stored information in more than one form.

#### *(2) Claiming Privilege or Protection.*

For access to subpoena materials, see Fed.R.Civ.P.45(a) Committee Note (2013)

…

## **Requests for Production of Documents**

## **I. INSTRUCTIONS**

2. Electronically stored information must be produced in accordance with the

following instructions:

name of the native file. The native file must be named after the FIRSTBATES.

Date fields should be provided in the format: mm/dd/yyyy. Date and time fields must be two separate fields. Required metadata listed below:

# Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 350 of 439

# Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 351 of 439

3. Each Request operates and should be construed independently and, unless otherwise indicated, no Request limits the scope of any other Request.

4. All Documents are to be produced as kept in the usual course of business or are to be organized and labeled to correspond with the categories in these Requests.

5. Each Request contained herein extends to all Documents: (a) in Your possession, custody, or control; or (b) in the possession, custody, or control of anyone acting on Your behalf,

## Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 352 of 439

including Your counsel or other representatives and advisors. Each Document shall be produced in its entirety.

## Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 353 of 439

12. All references to Entities includes all affiliates thereof.

13. All references to individual names include all alternative names, aliased, or nicknames.

14. Unless otherwise expressly indicated, the period of time covered by the Document Requests is the period from February 5, 2012 to the date responses to the Document Requests are due.

## **II. RULES OF CONSTRUCTION**

15. The use of (a) any singular noun shall be construed to include the plural, and vice versa, and (b) a verb in any tense shall be construed as the use of the verb in all other tenses.

## **III. DEFINITIONS**

1. "You" or "Your" or "Yourself" means and refers to Andrea Volpe, together with all of their agents, attorneys, representatives, employees, and/or anyone acting on their behalf.

3. "Debtor's Son" means Qiang Guo (a/k/a Mileson Kwok, 郭强, or any other alias), together with his employees, agents, counsel, advisors, or anyone acting on his behalf.

4. "Debtor's Daughter" means Mei Guo (a/k/a Mei Gui, 郭美, or any other alias), together with her employees, agents, counsel, advisors, or anyone acting on her behalf.

## Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 355 of 439

6. "Debtor's Family" means, collectively, the Debtor, the Debtor's Son, the Debtor's Daughter, and the Debtor's Purported Wife, and any other familial relation to the Debtor.

## Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 356 of 439

## Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 357 of 439

9. "Including" or any variant thereof means "including without limitation."

10. "And" and "or" mean "and/or," and shall be construed both conjunctively as well as disjunctively in order to maximize their scope.

## Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 358 of 439

11. "Any" and "all" and "each" mean "each and every."

12. "Each" and "every" mean "each and every."

13. "Third Party" means a Person or Entity other than Yourself.

14. "Transfer" shall have the meaning given to it by section 101(54) of the Bankruptcy Code.

## Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 359 of 439

## Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 360 of 439

telexes, instant messages, chats, text messages, telephonic notes, or notes transmitted internally or with third parties.

22. "Transfer" shall have the meaning given to it by section 101(54) of the Bankruptcy Code.

## **IV. DOCUMENTS TO BE PRODUCED**

1. All Documents regarding any income or Asset of the Debtor, the Debtor's Family, the Debtor's estate, an Associated Individuals, or an Associated Entity.

## Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 361 of 439

4. All Documents regarding any investment, business dealings or transactions made by, with, or on behalf of the Debtor, the Debtor's Family, an Associated Individual, or an Associated Entity.

6. All Documents regarding any Transfer, investment, or other transaction or business dealing made to, by, or with the Debtor, the Debtor's Family, an Associated Individual, or an Associated Entity.

## Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 362 of 439

12. All Documents and communications with the Debtor, the Debtor's Family, or an Associated Individual.

13. All Documents and communications between any of your counsel or other advisors and the Debtor, the Debtor's Family, or an Associated Individual.

14. All Documents related to any Associated Entity that You hold or have held an interest in.

# Exhibit C-19

#### B2540 (Form 2540 – Subpoena for Rule 2004 Examination) (12/15) Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 364 of

439

UNITED STATES BANKRUPTCY COURT

**District of Connecticut**

In re HO WAN KWOK, *et al*.,

1 Case No. 22-50073 (JAM) Debtor Chapter 11

(Jointly Administered)

# **SUBPOENA FOR RULE 2004 EXAMINATION**

To: **H.R. Owen PLC**

(*Name of person to whom the subpoena is directed*)

| PLACE | DATE AND TIME | |-------|---------------| | N/A | N/A | | | |

The examination will be recorded by this method: N/A

## **See Requests for Production of Documents, attached hereto.**

Date: **May , 2024**

CLERK OF COURT

*Signature of Clerk or Deputy Clerk Attorney's signature*

The name, address, email address, and telephone number of the attorney representing Luc A. Despins, Chapter 11 Trustee, who issues or requests this subpoena, are:

**Patrick R. Linsey, Esq.; Neubert, Pepe & Monteith, P.C.; 195 Church Street, 13th Floor, New Haven, Connecticut 06510 plinsey@npmlaw.com; (203) 781-2847**

## **Notice to the person who issues or requests this subpoena**

## **PROOF OF SERVICE**

**(This section should not be filed with the court unless required by Fed. R. Civ. P. 45.)**

I received this subpoena for (*name of individual and title, if any*): on (*date*) .

I served the subpoena by delivering a copy to the named person as follows:

on *(date)* ; or

I returned the subpoena unexecuted because:

My fees are \$ for travel and \$ for services, for a total of \$ .

I declare under penalty of perjury that this information is true and correct.

Date:

*Server's signature*

*Printed name and title*

*Server's address*

Additional information concerning attempted service, etc.:

## **Federal Rule of Civil Procedure 45(c), (d), (e), and (g) (Effective 12/1/13) (made applicable in bankruptcy cases by Rule 9016, Federal Rules of Bankruptcy Procedure)**

#### **(c) Place of compliance.**

*(1) For a Trial, Hearing, or Deposition.* A subpoena may command a person to attend a trial, hearing, or deposition only as follows:

(A) within 100 miles of where the person resides, is employed, or regularly transacts business in person; or

(B) within the state where the person resides, is employed, or regularly transacts business in person, if the person

(i) is a party or a party's officer; or

(ii) is commanded to attend a trial and would not incur substantial expense.

*(2) For Other Discovery.* A subpoena may command:

(A) production of documents, or electronically stored information, or things at a place within 100 miles of where the person resides, is employed, or regularly transacts business in person; and

(B) inspection of premises, at the premises to be inspected.

## **(d) Protecting a Person Subject to a Subpoena; Enforcement.**

## *(2) Command to Produce Materials or Permit Inspection.*

(i) At any time, on notice to the commanded person, the serving party may move the court for the district where compliance is required for an order compelling production or inspection.

(ii) These acts may be required only as directed in the order, and the order must protect a person who is neither a party nor a party's officer from significant expense resulting from compliance.

## *(3) Quashing or Modifying a Subpoena.*

*(A) When Required.* On timely motion, the court for the district where compliance is required must quash or modify a subpoena that:

(i) fails to allow a reasonable time to comply;

(ii) requires a person to comply beyond the geographical limits specified in Rule 45(c);

(iii) requires disclosure of privileged or other protected matter, if no exception or waiver applies; or

(iv) subjects a person to undue burden.

*(B) When Permitted.* To protect a person subject to or affected by a subpoena, the court for the district where compliance is required may, on motion, quash or modify the subpoena if it requires:

(i) disclosing a trade secret or other confidential research, development, or commercial information; or

(ii) disclosing an unretained expert's opinion or information that does not describe specific occurrences in dispute and results from the expert's study that was not requested by a party.

(i) shows a substantial need for the testimony or material that cannot be otherwise met without undue hardship; and

(ii) ensures that the subpoenaed person will be reasonably compensated.

#### **(e) Duties in Responding to a Subpoena.**

*(1) Producing Documents or Electronically Stored Information.* These procedures apply to producing documents or electronically stored information:

*(C) Electronically Stored Information Produced in Only One Form.* The person responding need not produce the same electronically stored information in more than one form.

#### *(2) Claiming Privilege or Protection.*

For access to subpoena materials, see Fed.R.Civ.P.45(a) Committee Note (2013)

…

## **Request for Production of Documents**

## **I. INSTRUCTIONS**

2. Electronically stored information must be produced in accordance with the

following instructions:

name of the native file. The native file must be named after the FIRSTBATES.

Date fields should be provided in the format: mm/dd/yyyy. Date and time fields must be two separate fields. Required metadata listed below:

# Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 369 of 439

# Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 370 of 439

3. Each Request operates and should be construed independently and, unless otherwise indicated, no Request limits the scope of any other Request.

4. All Documents are to be produced as kept in the usual course of business or are to be organized and labeled to correspond with the categories in these Requests.

5. Each Request contained herein extends to all Documents: (a) in Your possession, custody, or control; or (b) in the possession, custody, or control of anyone acting on Your behalf,

## Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 371 of 439

including Your counsel or other representatives and advisors. Each Document shall be produced in its entirety.

## Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 372 of 439

12. All references to Entities includes all affiliates thereof.

13. All references to individual names include all alternative names, aliased, or nicknames.

14. Unless otherwise expressly indicated, the period of time covered by the Document Requests is the period from February 5, 2012 to the date responses to the Document Requests are due.

## **II. RULES OF CONSTRUCTION**

15. The use of (a) any singular noun shall be construed to include the plural, and vice versa, and (b) a verb in any tense shall be construed as the use of the verb in all other tenses.

## **III. DEFINITIONS**

1. "You" or "Your" or "Yourself" means and refers to H.R. Owen PLC, together with all of its affiliates, divisions, agencies, instrumentalities, departments, offices, partners, officers, directors, agents, attorneys, representatives, employees, and/or anyone acting on its behalf.

## Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 374 of 439

3. "Debtor's Son" means Qiang Guo (a/k/a Mileson Kwok, 郭强, or any other alias), together with his employees, agents, counsel, advisors, or anyone acting on his behalf.

4. "Debtor's Daughter" means Mei Guo (a/k/a Mei Gui, 郭美, or any other alias), together with her employees, agents, counsel, advisors, or anyone acting on her behalf.

6. "Debtor's Family" means, collectively, the Debtor, the Debtor's Son, the Debtor's Daughter, and the Debtor's Purported Wife, and any other familial relation to the Debtor.

7. "Asset(s)" means any item of economic value that is subject to Possession, Custody, or Control. Asset includes all real and personal property, including but limited to, real estate, land, houses, apartments, condominiums, automobiles, yachts, boats, planes, jets, helicopters, cash, bank accounts, cryptocurrencies, securities, accounts receivables, inventory, and other tangible and intangible property.

8. "Associated Individuals" means individually and collectively, all individuals that (1) hold, control, have custody over, or discretion over assets owned, controlled, or enjoyed by the Debtor or the Debtor's Family; or (2) have been employees, directors, or otherwise are affiliated with one or more Associated Entities, together with the respective employees, agents, counsel, advisors, or anyone acting on behalf of any of the foregoing. Such Associated Individuals shall include, but are not limited to: Aaron Mitchell, Anthony DiBattista, Ana Izquierdo, Alex Hadjicharalambous, Bingshang Jiao, Beile Li, Brian W. Hofmeister, Charles Gruder, Daniel Podhaskie, David Fallon, Defeng Cao (a/k/a Wayne Cao, Max Cao), Ding Lin, Dinggang Wang (a/k/a 王定刚), Eduardo Eurnekian, Ehsan Masud, Fiona Yu, Gladys Chow, Haitham Khaled, Hao

## Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 375 of 439

(Gavin) Li (a/k/a Huo Lai), Hao Haidong (a/k/a 郝海东), Han Chunguang (a/k/a 韩春光), Haoran He, Ivan Lin, Haitham Khaled, Jason Miller, Jennifer Mercurio, Jesse Brown, Jessica Mastrogiovanni, Jie Zhang, Jintao Li, Karin Maistrello, Kyle Bass, Leanne Li, Lihong Wei Lafrenz (a/k/a Sara Wei, 魏丽红), Limarie Reyes Molinaris, Linwan "Irene" Feng, Max Krasner, Melissa Francis, Michael Baranowitz, Min Yang, Melissa Mendez, Nadeem Akbar, Nan Li (a/k/a Chris Lee, Mei Guo Xiao Li), Qidong Xia, Qu Guojiao (a/k/a Qu Guo Jiao, 屈国姣), Ridwan Mamode Saib, Ross Heinemeyer, Rui "Ray" Hao, Scott Barnett, Shih Hsin Yu, Shin Hee-Seup (a/k/a Hee Seup Shin), Steve Bannon, Talha Zobair, Victor Cerda, Wen Xiao, Wencong Wang, William Gertz, William Je (a/k/a Je Kin Ming, Yu Jianming, 余建明), and Xuebing Wang, Ya Li (a/k/a 李娅), Yinying (Aila) Wang (a/k/a Xiao Fei Xiang), Yongping Yan (Shan Mu), Yong Yu, Yue Zhou, Yumei Hao (a/k/a Ru Shui), Yvette Wang (a/k/a Yanping Wang, Yan Ping Wang, 王雁平 ), Zhang Wei (a/k/a 张魏), Zhouer Wang (a/k/a Joe Wang), Zhixuan Li, and Ziyang Liu.

9. "Associated Entities" means, individually and collectively, all organizations or Entities of any type that (1) have been owned, controlled, or invested in by the Debtor or the Debtor's Family; or (2) have an interest, whether directly or indirectly, in any assets owned, controlled, or enjoyed by the Debtor or the Debtor's Family, together with the respective employees, agents, counsel, advisors, or anyone acting on behalf of any of the foregoing. Such Associated Entities shall include, but are not limited to: 1332156 B.C. Ltd., 7 Nod Hill LLC, AAGV Limited, ACA Investment Management Limited, ACA Capital Group Limited, Ace Decade Holdings Limited, AI Group Holdings Inc., Alfa Global Ventures Limited, Alfonso Global Limited, Allied Capital Global Limited, Alpine Fiduciaries SA, Anton Development Limited, Beijing Pangu Investment Co., Beijing Pangu Investment Co. Ltd., Beijing Pangu Investment Inc.,

## Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 376 of 439

Beijing Zenith Holdings Company Limited, Blue Capital Limited, Booming Sail New York LLC, Bravo Luck Limited, Brent Petro, BSA Strategic Fund I, China Golden Spring (Hong Kong) Limited, Chuang Xin Limited, Crane Advisory Group LLC, Creative Apex Investments Limited, Crystal Breeze Investments Limited, Dawn State Limited, Eastern Profit Corporation Limited, Empire Growth Holdings, Elite Well Global Limited, Freedom Media Ventures Ltd., Fung Wan Trading Inc., G Club, G Club Operations LLC, G Club International Limited, G Club Investments Limited, G Fashion LLC, G-News Operations LLC, G News LLC, GMusic Inc., G Music LLC, G-Services LLC, G-Translators PTY LTD, GETTR USA, Inc., Genever Holdings Corporation, Genever Holdings LLC,G Fashion, GFashion Media Group Inc., GF Italy, LLC, GFNY, Inc., Globalist International Limited, GNews Media Group Inc., Golden Spring (New York) Ltd., Greenwich Land, LLC, Guo Media, GTV Media Group, Inc., GWGOPNZ Limited, GWGNZ Limited, Gypsy Mei Food Services, LLC, HCHK Property Management Inc., HCHK Technologies Inc., Hamilton Digital Assets FD SP, Hamilton Capital Holdings Inc., Hamilton Opportunity Fund SPC, Head Win Group Limited, Himalaya Embassy, Himalaya Exchange, Himalaya Federal Reserve, Himalaya International Clearing Limited, Himalaya International Financial Group Ltd., Himalaya Investment LLC, Himalaya (USA) Investment Management LLC, Himalaya New World Inc., Himalaya Supervisory Organization, Himalaya Ventures, Holy City Hong Kong Ventures, Ltd., Hudson Diamond Holding LLC, Hudson Diamond Holding Inc., Hudson Diamond NY LLC, HK International Funds Investments (USA) Limited LLC, Hong Kong International Funds Investments Limited, Huk Trading Inc, Infinite Increase Limited, Infinitum Developments Limited, Japan Himalaya League, Inc., Kalixun Trading Limited, K Legacy Ltd., Lamp Capital LLC, Leading Shine Limited, Leading Shine NY Limited, Lexington Property and Staffing Inc., Long Gate Limited, MOS Himalaya Foundation Inc., Maywind Trading LLC, New

## Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 377 of 439

Federal State of China (a/k/a NFSC), Newpeople LLC, New Mulberry PTE Ltd., New York MOS Himalaya LLC, Next Tycoon Investments Limited, Noble Fame Global Limited, O.S.C. Orbit Service Company LLC, Pixshow Film Inc., Rising Sun Capital Ltd., Roscalitar 2, Rosy Acme Ventures Limited, Rule of Law Foundation III, Inc., Rule of Law Society, Rule of Law Society IV, Inc., Santel LLC, Saraca Media Group, Inc., Shiny Ace Ltd., Shiny Times Holdings Ltd., Stevenson, Wong & Co., Taurus Fund LLC, Taurus Fund SP, Taurus Management LLC, The Lost Draft LLC, TM Primrose Limited, UA Himalaya Inc., Voice of Guo Media, Inc., Well Origin Ltd., Wise Creation International Limited, Whitecroft Shore Limited, World Century Limited, Worldwide Opportunity Holdings Limited, and ZIBA Limited.

10. "And" and "or" mean "and/or," and shall be construed both conjunctively as well as disjunctively in order to maximize their scope.

11. "Any" and "all" and "each" mean "each and every."

12. "Communication(s)" means, in the broadest possible sense, and without limitation, any transmittal of information or knowledge (in the form of facts, ideas, inquiries, or otherwise). Communication(s) further refers to all conversations, agreements, inquiries, or replies, whether in person, by telephone, in writing, or by means of electronic transmittal devices, and includes, but is not limited to, all correspondence, emails, recordings, transmittal slips, memoranda, telephone communications, voice messages, telegrams, telefaxes, telecopies, telexes, instant messages, chats, text messages, postings to a message board or group chat, social media posts, tweets, videos uploaded to any video platform, telephonic notes, or notes transmitted internally or with third parties.

13. "Each" and "every" mean "each and every."

## Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 378 of 439

14. "Document" means any information or thing within the scope of Fed. R. Civ. P. 34, and includes, without limitation, each and every written, recorded, or graphic matter of any kind, type, nature, or description that is or has been in Your Possession, Custody or Control, including all printed and electronic copies of electronic mail, computer files maintained in electronic form, correspondence, memoranda, tapes, stenographic or handwritten notes, written forms of any kind, charts, blueprints, drawings, sketches, graphs, plans, articles, specifications, diaries, letters, telegrams, photographs, minutes, contracts, agreements, surveys, computer printouts, data compilations of any kind, telexes, facsimiles, emails, text messages, instant messages, voice messages, invoices, order forms, checks, drafts, statements, credit memos, reports, position reports, summaries, indices, books, ledgers, notebooks, schedules, transparencies, recordings, catalogs, advertisements, promotional materials, films, video tapes, audio tapes, CDs, computer disks, brochures, pamphlets, punch-cards, time-slips, Tweets, social media posts, or any written or recorded materials of any other kind, and all meta-data thereof, however stored (whether in tangible or electronic form), recorded, produced, or reproduced, and also including but not limited to, drafts or copies of any of the foregoing that contain any notes, comments, or markings of any kind not found on the original documents or that are otherwise not identical to the original documents.

14. "G Club Entities" means, collectively, G Club Operations LLC, G Club HoldCo I LLC, G Club International Ltd., G-Club Investments Limited, G Club International Ltd (BVI), G Club One, G Club Two, G Club Three, G Club US Operations Inc., and G Club US Operations LLC, together with all of their affiliates, divisions, agencies, instrumentalities, departments, offices, officers, directors, agents, managers, attorneys, representatives, employees, professionals, and/or anyone acting for or on their behalf.

## Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 379 of 439

15. "Including" or any variant thereof means "including without limitation."

17. "Entity" means any natural Person, corporation, partnership, subsidiary, sole proprietorship, firm, board, joint venture, association, agency, authority, commission or other business entity or juristic Person, as well as any affiliate, agent, parent including but not limited to counsel, financial advisors, or any other representative.

20. "Third Party" means a Person or Entity other than Yourself.

21. "Transfer" shall have the meaning given to it by section 101(54) of the Bankruptcy Code.

## Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 380 of 439

inspected by, to, or for the benefit of the Debtor, the Debtor's Family, an Associated Individual, or any Associated Entity.

## **IV. DOCUMENTS TO BE PRODUCED**

1. All Documents and Communications related to any Transfers to You from G Club International Limited or G Club Operations LLC, including without limitation a transfer of \$832,000.75 on or around September 13, 2021.

2. All Documents related to any income or Asset of the Debtor, the Debtor's estate, the Debtor's Family, an Associated Individual, or an Associated Entity, including without limitation the G Club Entities.

3. All Documents related to any communications between You and the Debtor, the Debtor's estate, the Debtor's Family, an Associated Individual, or an Associated Entity, including without limitation the G Club Entities.

4. All Documents related to the Debtor, the Debtor's estate, the Debtor's Family, an Associated Entity, or an Associated Individual (including without limitation the G Club Entities) related to any Vehicle, including without limitation (i) ownership or control of any Vehicle; (ii) use of any Vehicle; (iii) lease or rental of any Vehicle; (iv) the purchase, sale, or marketing of any Vehicle; (v) any money or value paid or given related to any Vehicle and the source thereof; (vi) any money or value generated or obtained related to any Vehicle and the disposition thereof; or (vii) operation, maintenance, service, or overhaul, related to any Vehicle.

5. All Documents related to any account associated with the Debtor, the Debtor's estate, the Debtor's Family, an Associated Entity (including without limitation the G Club Entities), or an Associated Individual.

## Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 381 of 439

6. All Documents related to any invoices or payments of expenses related to the Debtor, the Debtor's estate, the Debtor's Family, an Associated Entity (including without limitation the G Club Entities), or an Associated Individual.

7. All Documents related to the current location of an Vehicle related to the Debtor, the Debtor's estate, the Debtor's Family, an Associated Entity (including without limitation the G Club Entities), or an Associated Individual.

Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 382 of 439

# Exhibit C-20

B2540 (Form 2540 – Subpoena for Rule 2004 Examination) (12/15) Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 383 of

UNITED STATES BANKRUPTCY COURT 439

**District of Connecticut**

In re HO WAN KWOK, *et al*.,

1 Case No. 22-50073 (JAM)

Debtor Chapter 11

(Jointly Administered)

# **SUBPOENA FOR RULE 2004 EXAMINATION**

To: **Headwater Service, LLC**

(*Name of person to whom the subpoena is directed*)

| PLACE | DATE AND TIME | |-------|---------------| | N/A | N/A | | | |

The examination will be recorded by this method: N/A

## **See Requests for Production of Documents, attached hereto.**

Date: **May , 2024**

CLERK OF COURT

*Signature of Clerk or Deputy Clerk Attorney's signature*

The name, address, email address, and telephone number of the attorney representing Luc A. Despins, Chapter 11 Trustee, who issues or requests this subpoena, are:

**Patrick R. Linsey, Esq.; Neubert, Pepe & Monteith, P.C.; 195 Church Street, 13th Floor, New Haven, Connecticut 06510 plinsey@npmlaw.com; (203) 781-2847**

## **Notice to the person who issues or requests this subpoena**

## **PROOF OF SERVICE**

**(This section should not be filed with the court unless required by Fed. R. Civ. P. 45.)**

I received this subpoena for (*name of individual and title, if any*): on (*date*) .

I served the subpoena by delivering a copy to the named person as follows:

on *(date)* ; or

I returned the subpoena unexecuted because:

My fees are \$ for travel and \$ for services, for a total of \$ .

I declare under penalty of perjury that this information is true and correct.

Date:

*Server's signature*

*Printed name and title*

*Server's address*

Additional information concerning attempted service, etc.:

## **Federal Rule of Civil Procedure 45(c), (d), (e), and (g) (Effective 12/1/13) (made applicable in bankruptcy cases by Rule 9016, Federal Rules of Bankruptcy Procedure)**

#### **(c) Place of compliance.**

*(1) For a Trial, Hearing, or Deposition.* A subpoena may command a person to attend a trial, hearing, or deposition only as follows:

(A) within 100 miles of where the person resides, is employed, or regularly transacts business in person; or

(B) within the state where the person resides, is employed, or regularly transacts business in person, if the person

(i) is a party or a party's officer; or

(ii) is commanded to attend a trial and would not incur substantial expense.

*(2) For Other Discovery.* A subpoena may command:

(A) production of documents, or electronically stored information, or things at a place within 100 miles of where the person resides, is employed, or regularly transacts business in person; and

(B) inspection of premises, at the premises to be inspected.

## **(d) Protecting a Person Subject to a Subpoena; Enforcement.**

## *(2) Command to Produce Materials or Permit Inspection.*

(i) At any time, on notice to the commanded person, the serving party may move the court for the district where compliance is required for an order compelling production or inspection.

(ii) These acts may be required only as directed in the order, and the order must protect a person who is neither a party nor a party's officer from significant expense resulting from compliance.

## *(3) Quashing or Modifying a Subpoena.*

*(A) When Required.* On timely motion, the court for the district where compliance is required must quash or modify a subpoena that:

(i) fails to allow a reasonable time to comply;

(ii) requires a person to comply beyond the geographical limits specified in Rule 45(c);

(iii) requires disclosure of privileged or other protected matter, if no exception or waiver applies; or

(iv) subjects a person to undue burden.

*(B) When Permitted.* To protect a person subject to or affected by a subpoena, the court for the district where compliance is required may, on motion, quash or modify the subpoena if it requires:

(i) disclosing a trade secret or other confidential research, development, or commercial information; or

(ii) disclosing an unretained expert's opinion or information that does not describe specific occurrences in dispute and results from the expert's study that was not requested by a party.

(i) shows a substantial need for the testimony or material that cannot be otherwise met without undue hardship; and

(ii) ensures that the subpoenaed person will be reasonably compensated.

#### **(e) Duties in Responding to a Subpoena.**

*(1) Producing Documents or Electronically Stored Information.* These procedures apply to producing documents or electronically stored information:

*(C) Electronically Stored Information Produced in Only One Form.* The person responding need not produce the same electronically stored information in more than one form.

#### *(2) Claiming Privilege or Protection.*

For access to subpoena materials, see Fed.R.Civ.P.45(a) Committee Note (2013)

…

## **Request for Production of Documents**

## **I. INSTRUCTIONS**

2. Electronically stored information must be produced in accordance with the

following instructions:

name of the native file. The native file must be named after the FIRSTBATES.

Date fields should be provided in the format: mm/dd/yyyy. Date and time fields must be two separate fields. Required metadata listed below:

# Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 388 of 439

# Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 389 of 439

3. Each Request operates and should be construed independently and, unless otherwise indicated, no Request limits the scope of any other Request.

4. All Documents are to be produced as kept in the usual course of business or are to be organized and labeled to correspond with the categories in these Requests.

5. Each Request contained herein extends to all Documents: (a) in Your possession, custody, or control; or (b) in the possession, custody, or control of anyone acting on Your behalf,

## Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 390 of 439

including Your counsel or other representatives and advisors. Each Document shall be produced in its entirety.

## Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 391 of 439

12. All references to Entities includes all affiliates thereof.

13. All references to individual names include all alternative names, aliased, or nicknames.

14. Unless otherwise expressly indicated, the period of time covered by the Document Requests is the period from February 5, 2012 to the date responses to the Document Requests are due.

## **II. RULES OF CONSTRUCTION**

15. The use of (a) any singular noun shall be construed to include the plural, and vice versa, and (b) a verb in any tense shall be construed as the use of the verb in all other tenses.

## **III. DEFINITIONS**

1. "You" or "Your" or "Yourself" means and refers to Headwater Service, LLC, together with all of its affiliates, divisions, agencies, instrumentalities, departments, offices, partners, officers, directors, agents, attorneys, representatives, employees, and/or anyone acting on its behalf.

## Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 393 of 439

3. "Debtor's Son" means Qiang Guo (a/k/a Mileson Kwok, 郭强, or any other alias), together with his employees, agents, counsel, advisors, or anyone acting on his behalf.

4. "Debtor's Daughter" means Mei Guo (a/k/a Mei Gui, 郭美, or any other alias), together with her employees, agents, counsel, advisors, or anyone acting on her behalf.

6. "Debtor's Family" means, collectively, the Debtor, the Debtor's Son, the Debtor's Daughter, and the Debtor's Purported Wife, and any other familial relation to the Debtor.

## Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 394 of 439

Hadjicharalambous, Bingshang Jiao, Beile Li, Brian W. Hofmeister, Charles Gruder, Daniel Podhaskie, David Fallon, Defeng Cao (a/k/a Wayne Cao, Max Cao), Ding Lin, Dinggang Wang (a/k/a 王定刚), Eduardo Eurnekian, Ehsan Masud, Fiona Yu, Gladys Chow, Haitham Khaled, Hao (Gavin) Li (a/k/a Huo Lai), Hao Haidong (a/k/a 郝海东), Han Chunguang (a/k/a 韩春光), Haoran He, Ivan Lin, Haitham Khaled, Jason Miller, Jennifer Mercurio, Jesse Brown, Jessica Mastrogiovanni, Jie Zhang, Jintao Li, Karin Maistrello, Kyle Bass, Leanne Li, Lihong Wei Lafrenz (a/k/a Sara Wei, 魏丽红), Limarie Reyes Molinaris, Linwan "Irene" Feng, Max Krasner, Melissa Francis, Michael Baranowitz, Min Yang, Melissa Mendez, Nadeem Akbar, Nan Li (a/k/a Chris Lee, Mei Guo Xiao Li), Qidong Xia, Qu Guojiao (a/k/a Qu Guo Jiao, 屈国姣), Ridwan Mamode Saib, Ross Heinemeyer, Rui "Ray" Hao, Scott Barnett, Shih Hsin Yu, Shin Hee-Seup (a/k/a Hee Seup Shin), Steve Bannon, Talha Zobair, Victor Cerda, Wen Xiao, Wencong Wang, William Gertz, William Je (a/k/a Je Kin Ming, Yu Jianming, 余建明), and Xuebing Wang, Ya Li (a/k/a 李娅), Yinying (Aila) Wang (a/k/a Xiao Fei Xiang), Yongping Yan (Shan Mu), Yong Yu, Yue Zhou, Yumei Hao (a/k/a Ru Shui), Yvette Wang (a/k/a Yanping Wang, Yan Ping Wang, 王雁平 ), Zhang Wei (a/k/a 张魏), Zhouer Wang (a/k/a Joe Wang), Zhixuan Li, and Ziyang Liu.

## Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 395 of 439

Decade Holdings Limited, AI Group Holdings Inc., Alfa Global Ventures Limited, Alfonso Global Limited, Allied Capital Global Limited, Alpine Fiduciaries SA, Anton Development Limited, Beijing Pangu Investment Co., Beijing Pangu Investment Co. Ltd., Beijing Pangu Investment Inc., Beijing Zenith Holdings Company Limited, Blue Capital Limited, Booming Sail New York LLC, Bravo Luck Limited, Brent Petro, BSA Strategic Fund I, China Golden Spring (Hong Kong) Limited, Chuang Xin Limited, Crane Advisory Group LLC, Creative Apex Investments Limited, Crystal Breeze Investments Limited, Dawn State Limited, Eastern Profit Corporation Limited, Empire Growth Holdings, Elite Well Global Limited, Freedom Media Ventures Ltd., Fung Wan Trading Inc., G Club, G Club Operations LLC, G Club International Limited, G Club Investments Limited, G Fashion LLC, G-News Operations LLC, G News LLC, GMusic Inc., G Music LLC, G-Services LLC, G-Translators PTY LTD, GETTR USA, Inc., Genever Holdings Corporation, Genever Holdings LLC,G Fashion, GFashion Media Group Inc., GF Italy, LLC, GFNY, Inc., Globalist International Limited, GNews Media Group Inc., Golden Spring (New York) Ltd., Greenwich Land, LLC, Guo Media, GTV Media Group, Inc., GWGOPNZ Limited, GWGNZ Limited, Gypsy Mei Food Services, LLC, HCHK Property Management Inc., HCHK Technologies Inc., Hamilton Digital Assets FD SP, Hamilton Capital Holdings Inc., Hamilton Opportunity Fund SPC, Head Win Group Limited, Himalaya Embassy, Himalaya Exchange, Himalaya Federal Reserve, Himalaya International Clearing Limited, Himalaya International Financial Group Ltd., Himalaya Investment LLC, Himalaya (USA) Investment Management LLC, Himalaya New World Inc., Himalaya Supervisory Organization, Himalaya Ventures, Holy City Hong Kong Ventures, Ltd., Hudson Diamond Holding LLC, Hudson Diamond Holding Inc., Hudson Diamond NY LLC, HK International Funds Investments (USA) Limited LLC, Hong Kong International Funds Investments Limited, Huk Trading Inc, Infinite Increase Limited, Infinitum

## Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 396 of 439

Developments Limited, Japan Himalaya League, Inc., Kalixun Trading Limited, K Legacy Ltd., Lamp Capital LLC, Leading Shine Limited, Leading Shine NY Limited, Lexington Property and Staffing Inc., Long Gate Limited, MOS Himalaya Foundation Inc., Maywind Trading LLC, New Federal State of China (a/k/a NFSC), Newpeople LLC, New Mulberry PTE Ltd., New York MOS Himalaya LLC, Next Tycoon Investments Limited, Noble Fame Global Limited, O.S.C. Orbit Service Company LLC, Pixshow Film Inc., Rising Sun Capital Ltd., Roscalitar 2, Rosy Acme Ventures Limited, Rule of Law Foundation III, Inc., Rule of Law Society, Rule of Law Society IV, Inc., Santel LLC, Saraca Media Group, Inc., Shiny Ace Ltd., Shiny Times Holdings Ltd., Stevenson, Wong & Co., Taurus Fund LLC, Taurus Fund SP, Taurus Management LLC, The Lost Draft LLC, TM Primrose Limited, UA Himalaya Inc., Voice of Guo Media, Inc., Well Origin Ltd., Wise Creation International Limited, Whitecroft Shore Limited, World Century Limited, Worldwide Opportunity Holdings Limited, and ZIBA Limited.

10. "And" and "or" mean "and/or," and shall be construed both conjunctively as well as disjunctively in order to maximize their scope.

11. "Any" and "all" and "each" mean "each and every."

## Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 397 of 439

uploaded to any video platform, telephonic notes, or notes transmitted internally or with third parties.

13. "Each" and "every" mean "each and every."

## Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 398 of 439

LLC, together with all of their affiliates, divisions, agencies, instrumentalities, departments, offices, officers, directors, agents, managers, attorneys, representatives, employees, professionals, and/or anyone acting for or on their behalf.

15. "Including" or any variant thereof means "including without limitation."

17. "Entity" means any natural Person, corporation, partnership, subsidiary, sole proprietorship, firm, board, joint venture, association, agency, authority, commission or other business entity or juristic Person, as well as any affiliate, agent, parent including but not limited to counsel, financial advisors, or any other representative.

20. "Third Party" means a Person or Entity other than Yourself.

21. "Transfer" shall have the meaning given to it by section 101(54) of the Bankruptcy Code.

## Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 399 of 439

22. "Vehicle" means any vehicle for traveling, including, without limitation, cars and motor vehicles, that are or were at any time owned, used, controlled, purchased, sold, leased, rented, licensed, serviced, maintained, repaired, overhauled, stored, operated, marketed, or inspected by, to, or for the benefit of the Debtor, the Debtor's Family, an Associated Individual, or any Associated Entity.

## **IV. DOCUMENTS TO BE PRODUCED**

## Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 400 of 439

# Exhibit C-21

B2540 (Form 2540 – Subpoena for Rule 2004 Examination) (12/15) Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 402 of

UNITED STATES BANKRUPTCY COURT 439

**District of Connecticut**

In re HO WAN KWOK, *et al*.,

1 Case No. 22-50073 (JAM)

Debtor Chapter 11

(Jointly Administered)

## **SUBPOENA FOR RULE 2004 EXAMINATION**

To: **RM Sotheby's and/or RM Auctions 2022**

(*Name of person to whom the subpoena is directed*)

| PLACE | DATE AND TIME | |-------|---------------| | N/A | N/A | | | |

The examination will be recorded by this method: N/A

## **See Requests for Production of Documents, attached hereto.**

Date: **May , 2024**

CLERK OF COURT

*Signature of Clerk or Deputy Clerk Attorney's signature*

The name, address, email address, and telephone number of the attorney representing Luc A. Despins, Chapter 11 Trustee, who issues or requests this subpoena, are:

**Patrick R. Linsey, Esq.; Neubert, Pepe & Monteith, P.C.; 195 Church Street, 13th Floor, New Haven, Connecticut 06510 plinsey@npmlaw.com; (203) 781-2847**

## **Notice to the person who issues or requests this subpoena**

## **PROOF OF SERVICE**

**(This section should not be filed with the court unless required by Fed. R. Civ. P. 45.)**

I received this subpoena for (*name of individual and title, if any*): on (*date*) .

I served the subpoena by delivering a copy to the named person as follows:

on *(date)* ; or

I returned the subpoena unexecuted because:

My fees are \$ for travel and \$ for services, for a total of \$ .

I declare under penalty of perjury that this information is true and correct.

Date:

*Server's signature*

*Printed name and title*

*Server's address*

Additional information concerning attempted service, etc.:

## **Federal Rule of Civil Procedure 45(c), (d), (e), and (g) (Effective 12/1/13) (made applicable in bankruptcy cases by Rule 9016, Federal Rules of Bankruptcy Procedure)**

#### **(c) Place of compliance.**

*(1) For a Trial, Hearing, or Deposition.* A subpoena may command a person to attend a trial, hearing, or deposition only as follows:

(A) within 100 miles of where the person resides, is employed, or regularly transacts business in person; or

(B) within the state where the person resides, is employed, or regularly transacts business in person, if the person

(i) is a party or a party's officer; or

(ii) is commanded to attend a trial and would not incur substantial expense.

*(2) For Other Discovery.* A subpoena may command:

(A) production of documents, or electronically stored information, or things at a place within 100 miles of where the person resides, is employed, or regularly transacts business in person; and

(B) inspection of premises, at the premises to be inspected.

## **(d) Protecting a Person Subject to a Subpoena; Enforcement.**

## *(2) Command to Produce Materials or Permit Inspection.*

(i) At any time, on notice to the commanded person, the serving party may move the court for the district where compliance is required for an order compelling production or inspection.

(ii) These acts may be required only as directed in the order, and the order must protect a person who is neither a party nor a party's officer from significant expense resulting from compliance.

## *(3) Quashing or Modifying a Subpoena.*

*(A) When Required.* On timely motion, the court for the district where compliance is required must quash or modify a subpoena that:

(i) fails to allow a reasonable time to comply;

(ii) requires a person to comply beyond the geographical limits specified in Rule 45(c);

(iii) requires disclosure of privileged or other protected matter, if no exception or waiver applies; or

(iv) subjects a person to undue burden.

*(B) When Permitted.* To protect a person subject to or affected by a subpoena, the court for the district where compliance is required may, on motion, quash or modify the subpoena if it requires:

(i) disclosing a trade secret or other confidential research, development, or commercial information; or

(ii) disclosing an unretained expert's opinion or information that does not describe specific occurrences in dispute and results from the expert's study that was not requested by a party.

(i) shows a substantial need for the testimony or material that cannot be otherwise met without undue hardship; and

(ii) ensures that the subpoenaed person will be reasonably compensated.

#### **(e) Duties in Responding to a Subpoena.**

*(1) Producing Documents or Electronically Stored Information.* These procedures apply to producing documents or electronically stored information:

*(C) Electronically Stored Information Produced in Only One Form.* The person responding need not produce the same electronically stored information in more than one form.

#### *(2) Claiming Privilege or Protection.*

For access to subpoena materials, see Fed.R.Civ.P.45(a) Committee Note (2013)

…

## **Request for Production of Documents**

## **I. INSTRUCTIONS**

2. Electronically stored information must be produced in accordance with the

following instructions:

name of the native file. The native file must be named after the FIRSTBATES.

Date fields should be provided in the format: mm/dd/yyyy. Date and time fields must be two separate fields. Required metadata listed below:

# Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 407 of 439

# Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 408 of 439

3. Each Request operates and should be construed independently and, unless otherwise indicated, no Request limits the scope of any other Request.

4. All Documents are to be produced as kept in the usual course of business or are to be organized and labeled to correspond with the categories in these Requests.

5. Each Request contained herein extends to all Documents: (a) in Your possession, custody, or control; or (b) in the possession, custody, or control of anyone acting on Your behalf,

## Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 409 of 439

including Your counsel or other representatives and advisors. Each Document shall be produced in its entirety.

## Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 410 of 439

12. All references to Entities includes all affiliates thereof.

13. All references to individual names include all alternative names, aliased, or nicknames.

14. Unless otherwise expressly indicated, the period of time covered by the Document Requests is the period from February 5, 2012 to the date responses to the Document Requests are due.

## **II. RULES OF CONSTRUCTION**

15. The use of (a) any singular noun shall be construed to include the plural, and vice versa, and (b) a verb in any tense shall be construed as the use of the verb in all other tenses.

## **III. DEFINITIONS**

1. "You" or "Your" or "Yourself" means and refers to RM Sotheby's and/or RM Auctions 2022, together with all of its affiliates, divisions, agencies, instrumentalities, departments, offices, partners, officers, directors, agents, attorneys, representatives, employees, and/or anyone acting on its behalf.

## Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 412 of 439

3. "Debtor's Son" means Qiang Guo (a/k/a Mileson Kwok, 郭强, or any other alias), together with his employees, agents, counsel, advisors, or anyone acting on his behalf.

4. "Debtor's Daughter" means Mei Guo (a/k/a Mei Gui, 郭美, or any other alias), together with her employees, agents, counsel, advisors, or anyone acting on her behalf.

6. "Debtor's Family" means, collectively, the Debtor, the Debtor's Son, the Debtor's Daughter, and the Debtor's Purported Wife, and any other familial relation to the Debtor.

## Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 413 of 439

## Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 414 of 439

## Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 415 of 439

10. "And" and "or" mean "and/or," and shall be construed both conjunctively as well as disjunctively in order to maximize their scope.

11. "Any" and "all" and "each" mean "each and every."

## Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 416 of 439

uploaded to any video platform, telephonic notes, or notes transmitted internally or with third parties.

13. "Each" and "every" mean "each and every."

## Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 417 of 439

15. "Including" or any variant thereof means "including without limitation."

17. "Entity" means any natural Person, corporation, partnership, subsidiary, sole proprietorship, firm, board, joint venture, association, agency, authority, commission or other business entity or juristic Person, as well as any affiliate, agent, parent including but not limited to counsel, financial advisors, or any other representative.

20. "Third Party" means a Person or Entity other than Yourself.

21. "Transfer" shall have the meaning given to it by section 101(54) of the Bankruptcy Code.

## Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 418 of 439

## **IV. DOCUMENTS TO BE PRODUCED**

## Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 419 of 439

Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 420 of 439

# Exhibit C-22

#### B2540 (Form 2540 – Subpoena for Rule 2004 Examination) (12/15) Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 421 of

439

UNITED STATES BANKRUPTCY COURT

**District of Connecticut**

In re HO WAN KWOK, *et al*.,

1 Case No. 22-50073 (JAM) Debtor Chapter 11

(Jointly Administered)

# **SUBPOENA FOR RULE 2004 EXAMINATION**

To: **Dean M. Rabideau**

(*Name of person to whom the subpoena is directed*)

| PLACE | DATE AND TIME | |-------|---------------| | N/A | N/A | | | |

The examination will be recorded by this method: N/A

## **See Requests for Production of Documents, attached hereto.**

Date: **May , 2024**

CLERK OF COURT

*Signature of Clerk or Deputy Clerk Attorney's signature*

The name, address, email address, and telephone number of the attorney representing Luc A. Despins, Chapter 11 Trustee, who issues or requests this subpoena, are:

**Patrick R. Linsey, Esq.; Neubert, Pepe & Monteith, P.C.; 195 Church Street, 13th Floor, New Haven, Connecticut 06510 plinsey@npmlaw.com; (203) 781-2847**

## **Notice to the person who issues or requests this subpoena**

## **PROOF OF SERVICE**

**(This section should not be filed with the court unless required by Fed. R. Civ. P. 45.)**

I received this subpoena for (*name of individual and title, if any*): on (*date*) .

I served the subpoena by delivering a copy to the named person as follows:

on *(date)* ; or

I returned the subpoena unexecuted because:

My fees are \$ for travel and \$ for services, for a total of \$ .

I declare under penalty of perjury that this information is true and correct.

Date:

*Server's signature*

*Printed name and title*

*Server's address*

Additional information concerning attempted service, etc.:

## **Federal Rule of Civil Procedure 45(c), (d), (e), and (g) (Effective 12/1/13) (made applicable in bankruptcy cases by Rule 9016, Federal Rules of Bankruptcy Procedure)**

#### **(c) Place of compliance.**

*(1) For a Trial, Hearing, or Deposition.* A subpoena may command a person to attend a trial, hearing, or deposition only as follows:

(A) within 100 miles of where the person resides, is employed, or regularly transacts business in person; or

(B) within the state where the person resides, is employed, or regularly transacts business in person, if the person

(i) is a party or a party's officer; or

(ii) is commanded to attend a trial and would not incur substantial expense.

*(2) For Other Discovery.* A subpoena may command:

(A) production of documents, or electronically stored information, or things at a place within 100 miles of where the person resides, is employed, or regularly transacts business in person; and

(B) inspection of premises, at the premises to be inspected.

## **(d) Protecting a Person Subject to a Subpoena; Enforcement.**

## *(2) Command to Produce Materials or Permit Inspection.*

(i) At any time, on notice to the commanded person, the serving party may move the court for the district where compliance is required for an order compelling production or inspection.

(ii) These acts may be required only as directed in the order, and the order must protect a person who is neither a party nor a party's officer from significant expense resulting from compliance.

## *(3) Quashing or Modifying a Subpoena.*

*(A) When Required.* On timely motion, the court for the district where compliance is required must quash or modify a subpoena that:

(i) fails to allow a reasonable time to comply;

(ii) requires a person to comply beyond the geographical limits specified in Rule 45(c);

(iii) requires disclosure of privileged or other protected matter, if no exception or waiver applies; or

(iv) subjects a person to undue burden.

*(B) When Permitted.* To protect a person subject to or affected by a subpoena, the court for the district where compliance is required may, on motion, quash or modify the subpoena if it requires:

(i) disclosing a trade secret or other confidential research, development, or commercial information; or

(ii) disclosing an unretained expert's opinion or information that does not describe specific occurrences in dispute and results from the expert's study that was not requested by a party.

(i) shows a substantial need for the testimony or material that cannot be otherwise met without undue hardship; and

(ii) ensures that the subpoenaed person will be reasonably compensated.

#### **(e) Duties in Responding to a Subpoena.**

*(1) Producing Documents or Electronically Stored Information.* These procedures apply to producing documents or electronically stored information:

*(C) Electronically Stored Information Produced in Only One Form.* The person responding need not produce the same electronically stored information in more than one form.

#### *(2) Claiming Privilege or Protection.*

For access to subpoena materials, see Fed.R.Civ.P.45(a) Committee Note (2013)

…

## **Requests for Production of Documents**

## **I. INSTRUCTIONS**

2. Electronically stored information must be produced in accordance with the

following instructions:

name of the native file. The native file must be named after the FIRSTBATES.

Date fields should be provided in the format: mm/dd/yyyy. Date and time fields must be two separate fields. Required metadata listed below:

| Field Name | Sample Data | Description | |--------------|--------------------------|--------------------------------------------------| | FIRSTBATES | EDC0000001 | First Bates number of native file document/email | | LASTBATES | EDC0000001 | Last Bates number of native file document/email | | | | **The LASTBATES field should be populated | | | | for single page | | ATTACHRANGE | EDC0000001 - | Bates number of the first page of the parent | | | EDC0000015 | document to the Bates number of the last page of | | | | the last attachment "child" document | | BEGATTACH | EDC0000001 | First Bates number of attachment range | | ENDATTACH | EDC0000015 | Last Bates number of attachment range | | CUSTODIAN | Smith, John | Email: Mailbox where the email resided | | | | Native: Name of the individual or department | | | | from whose files the document originated | | FROM | John Smith | Email: Sender | | | | Native: Author(s) of document | | | | **semi-colon should be used to separate | | | | multiple entries | | TO | Coffman, Janice; LeeW | Recipient(s) | | | [mailto:LeeW@MSN.com] | **semi-colon should be used to separate multiple | | | | entries | | CC | Frank Thompson [mailto: | Carbon copy recipient(s) | | | frank_Thompson@cdt.com] | **semi-colon should be used to separate | | | | multiple entries | | BCC | John Cain | Blind carbon copy recipient(s) | | | | **semi-colon should be used to separate | | | | multiple entries | | SUBJECT | Board Meeting Minutes | Email: Subject line of the email Native: Title | | | | of document (if available) | | FILE_NAME | BoardMeetingMinutes.docx | Native: Name of the original native file, | | | | including extension | | DATE_SENT | 10/12/2010 | Email: Date the email was sent | | | | Native: (empty) | | TIME_SENT/ | 07:05 PM GMT | Email: Time the email was sent/ Time zone in | | TIME_ZONE | | which the emails were standardized | | TIME_ZONE | GMT | The time zone in which the emails were | | | | standardized during conversion. | | LINK | EDC0000001.msg | Hyperlink to the email or native file document | | | | **The linked file must be named per the | | | | FIRSTBATES number | | FILE_EXTEN | MSG | The file type extension | | | | representing | | | | the Email or | | AUTHOR | John Smith | Email: (empty) | | | | Native: Author of the document | | DATE_CREATED | 10/10/2010 | Email: (empty) | | | | Native: Date the document was created |

# Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 427 of 439

| TIME_CREATED | 10:25 AM | Email: (empty) | |--------------|---------------------------|-------------------------------------------------| | | | Native: Time the document was created | | | | **This data must be a separate field and cannot | | | | be combined with the DATE_CREATED field | | DATE_MOD | 10/12/2010 | Email: (empty) | | | | Native: Date the document was last modified | | TIME_MOD | 07:00 PM | Email: (empty) | | | | Native: Time the document was last modified | | | | **This data must be a separate field and cannot | | | | be combined with the DATE_MOD field | | DATE_ACCESSD | 10/12/2010 | Email: (empty) | | | | Native: Date the document was last accessed | | TIME_ACCESSD | 07:00 PM | Email: (empty) | | | | Native: Time the document was last accessed | | | | **This data must be a separate field and cannot | | | | be combined with the DATE_ACCESSD field | | FILE_SIZE | 5,952 | Size of native file document/email in KB | | PGCOUNT | 1 | Number of pages in native file document/email | | PATH | | Email: (empty) | | | Agenda.doc | Native: Path where native file document was | | | | stored including original file name. | | INTFILEPATH | Personal Folders\Deleted | Email: original location of email including | | | Items\Board Meeting | original file name. | | | Minutes.msg | Native: (empty) | | INTMSGID | <000805c2c71b\$75977050\$ | Email: Unique Message ID Native: (empty) | | | cb8306d1@MSN> | | | MD5HASH | d131dd02c5e6eec4693d9a0 | MD5 Hash value of the document. | | | 698aff95c | | | | 2fcab58712467eab4004583e | | | | b8fb7f89 | | | OCRPATH | TEXT/001/EDC0000001.txt | Path to extracted text of the native file |

3. Each Request operates and should be construed independently and, unless otherwise indicated, no Request limits the scope of any other Request.

4. All Documents are to be produced as kept in the usual course of business or are to be organized and labeled to correspond with the categories in these Requests.

5. Each Request contained herein extends to all Documents: (a) in Your possession, custody, or control; or (b) in the possession, custody, or control of anyone acting on Your behalf,

## Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 428 of 439

including Your counsel or other representatives and advisors. Each Document shall be produced in its entirety.

## Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 429 of 439

12. All references to Entities includes all affiliates thereof.

13. All references to individual names include all alternative names, aliased, or nicknames.

14. Unless otherwise expressly indicated, the period of time covered by the Document Requests is the period from February 5, 2012 to the date responses to the Document Requests are due.

## **II. RULES OF CONSTRUCTION**

15. The use of (a) any singular noun shall be construed to include the plural, and vice versa, and (b) a verb in any tense shall be construed as the use of the verb in all other tenses.

## **III. DEFINITIONS**

1. "You" or "Your" or "Yourself" means and refers to Dean M. Rabideau, together with all of their agents, attorneys, representatives, employees, and/or anyone acting on their behalf.

3. "Debtor's Son" means Qiang Guo (a/k/a Mileson Kwok, 郭强, or any other alias), together with his employees, agents, counsel, advisors, or anyone acting on his behalf.

## Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 431 of 439

4. "Debtor's Daughter" means Mei Guo (a/k/a Mei Gui, 郭美, or any other alias), together with her employees, agents, counsel, advisors, or anyone acting on her behalf.

6. "Debtor's Family" means, collectively, the Debtor, the Debtor's Son, the Debtor's Daughter, and the Debtor's Purported Wife, and any other familial relation to the Debtor.

## Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 432 of 439

## Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 433 of 439

9. "Including" or any variant thereof means "including without limitation."

## Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 434 of 439

10. "And" and "or" mean "and/or," and shall be construed both conjunctively as well as disjunctively in order to maximize their scope.

11. "Any" and "all" and "each" mean "each and every."

12. "Each" and "every" mean "each and every."

13. "Third Party" means a Person or Entity other than Yourself.

14. "Transfer" shall have the meaning given to it by section 101(54) of the Bankruptcy Code.

## Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 435 of 439

of the foregoing that contain any notes, comments, or markings of any kind not found on the original documents or that are otherwise not identical to the original documents.

## Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 436 of 439

22. "Transfer" shall have the meaning given to it by section 101(54) of the Bankruptcy Code.

## **IV. DOCUMENTS TO BE PRODUCED**

1. All Documents regarding any income or Asset of the Debtor, the Debtor's Family, the Debtor's estate, an Associated Individuals, or an Associated Entity.

## Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 437 of 439

or an Associated Individual, including without limitation all Documents sufficient to show all Transfers to any of the foregoing.

4. All Documents regarding any investment, business dealings or transactions made by, with, or on behalf of the Debtor, the Debtor's Family, an Associated Individual, or an Associated Entity.

6. All Documents regarding any Transfer, investment, or other transaction or business dealing made to, by, or with the Debtor, the Debtor's Family, an Associated Individual, or an Associated Entity.

8. All Documents related to any aircraft owned, controlled, or used by the Debtor, including without limitation (i) the aircraft bearing tail number T7-GQM and any other aircraft

## Case 22-50073 Doc 3193 Filed 05/16/24 Entered 05/16/24 10:28:21 Page 438 of 439

12. All Documents and communications with the Debtor, the Debtor's Family, or an Associated Individual.

13. All Documents and communications between any of your counsel or other advisors and the Debtor, the Debtor's Family, or an Associated Individual.

14. All Documents related to any Associated Entity that You hold or have held an interest in.