Guo Wengui / Miles Guo — bankruptcy case · ORDER · ECF #3207

UNITED STATES BANKRUPTCY COURT DISTRICT OF CONNECTICUT BRIDGEPORT DIVISION

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In re: : :

HO WAN KWOK, et al., : :

Debtors.1 : :

MONTHLY FEE STATEMENT OF O'SULLIVAN MCCORMACK JENSEN & BLISS PC FOR COMPENSATION AND REIMBURSEMENT OF EXPENSES FOR PERIOD FROM APRIL 1, 2024 THROUGH APRIL 30, 2024

In accordance with the *Order Establishing Procedures for Interim Compensation and Reimbursement of Expenses for Retained Professionals, dated August 18, 2023* [Docket No. 2094] (the "Interim Compensation Order"),[2] O'Sullivan McCormack Jensen & Bliss PC ("OMJB") hereby submits this monthly statement (the "Monthly Fee Statement") seeking compensation for services rendered and reimbursement of expenses incurred as Special Insurance Counsel to Genever Holdings LLC ("Genever (US)"), for the period from April 1, 2024 through and including April 30, 2024 (the "Fee Period"). By this Monthly Fee Statement, OMJB respectfully requests payment of 80% of all fees and 100% of all expenses actually and necessarily incurred for services rendered during the Fee Period, in the amounts of \$1,672.80 and \$254.40 respectively.

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

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

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

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

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

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

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

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

7. To the extent that an objection to this Monthly Fee Statement is filed and received on or before the Objection Deadline, the estates shall withhold payment of that portion of this Monthly Fee Statement to which the objection is directed and promptly pay the remainder of the fees and expenses in the percentages set forth above. To the extent such an objection is not resolved, it shall be preserved and scheduled for consideration at the next interim fee application hearing. Dated: May 21, 2024 Glastonbury, Connecticut

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

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

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

In re: :

HO WAN KWOK, et al.,1 : :

Debtors. :

The undersigned hereby certifies that on May 21, 2024, the foregoing Monthly Fee Statement was electronically filed. In addition, a copy of the Monthly Fee Statement was served by email on the Notice Parties. Parties may access this filing through the Court's CM/ECF system.

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

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

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

Michael McCormack 1993 \$400 4.8 \$1,920.00

Case 22-50073 Doc 3207 Filed 05/21/24 Entered 05/21/24 13:49:49 Page 9 of 13

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

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

Date Attorney Activity Time Rate Total

04/09/2024 MTM Email correspondence with Attny Kavanuagh re motion to stay and underwriting issues 0.10 \$400.00 \$40.00 04/11/2024 MBG Begin draft of Fee Application for OMJB fees for March 2024. 0.30 \$125.00 \$37.50 04/12/2024 AM Email correspondence to E. Sutton re: testimony of Trustee in response to US Trustee's request. 0.20 \$350.00 \$70.00 04/18/2024 MTM Telephone conference with Luc Despins re Status and Strategy 0.30 \$400.00 \$120.00 04/18/2024 MTM Telephone conference with Attny Despins re status and strategy (.3);

;

email communications with Attny Despins and Kavanaugh re same (.5) 0.80 \$400.00 \$320.00 04/18/2024 MTM Review of additional repair damage documents from Attny Despin; review AIG policy re same 0.30 \$400.00 \$120.00 04/18/2024 MTM Email communications with Attny Despins re supplemental

04/18/2024 TPJ Review fee application 0.20 \$450.00 \$90.00 04/19/2024 MTM Review of file notes and AIG communications re

Attny Kavanaugh re discovery, stay and remediation issues (.2) 0.50 \$400.00 \$200.00 04/22/2024 MTM Review, revise and supplement monthly fee application and redacted invoices for filing 0.30 \$400.00 \$120.00 04/22/2024 MTM Review of draft motion for order re approval for cleaning of Sherry Netherland Building; review relevant policy terms applicable to same; revise and supplement motion for order re motion for summary judgment 1.60 \$400.00 \$640.00

04/22/2024 MTM Email communications with Attnys Bongartz and Despins re

04/22/2024 MBG Further redactions of OMJB Invoice, revise and finalize Fee Application

04/22/2024 MBG Attention to e-filing of OMJB March Fee Application and service of same on Notice Parties. 0.20 \$125.00 \$25.00 04/24/2024 MTM Review revised draft application for approval for supplemental cleaning costs from Attny Bongartz; email communications with Attny Bongartz re

04/25/2024 MTM Email correspondence to AIG counsel re bankruptcy filing re motion for cleaning; email with Attny Bongartz re same 0.20 \$400.00 \$80.00 05/16/2024 AO NOTE: Payment in excess of 80% of fees was received (\$89.00) for invoice 27587 and has been applied to this invoice 27688 -\$89.00 -\$89.00

Expense 04/08/2024 Fees advanced to Logikcull INV159424 3-31-2024 \$250.00 Expense 04/30/2024 Copying: Month of April \$4.40

Michael McCormack 4.8 \$400.00 \$1,920.00 Melissa Gambardella 0.8 \$125.00 \$100.00 Excess Payment Adjustment -\$89.00 -\$89.00

Invoice Number Due On Amount Due Payments Received Balance Due

27423 02/09/2024 \$11,978.91 \$9,740.41 \$2,238.50

Invoice No. 27688 - 05/16/2024 Case 22-50073 Doc 3207 Filed 05/21/24 Entered 05/21/24 13:49:49 Page 11 of 13

27521 03/11/2024 \$12,033.85 \$9,693.85 \$2,340.00

27587 04/11/2024 \$4,567.70 \$0.00 \$4,567.70

Invoice Number Due On Amount Due Payments Received Balance Due

27688 05/16/2024 \$2,345.40 \$0.00 \$2,345.40

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

Payment is due upon receipt.

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