Guo Wengui / Miles Guo — bankruptcy case · ORDER · ECF #3233

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

In re:

HO WAN KWOK, *et al.*,

Chapter 11

Case No. 22-50073 (JAM)

Debtors.

(Jointly Administered)

# **CONSENTED TO MOTION OF UBS AG TO ADJOURN UBS AG'S DEADLINE BY WHICH TO RESPOND TO MOTION OF CHAPTER 11 TRUSTEE TO (I) MODIFY OCTOBER 6, 2022 PROTECTIVE ORDER ENTERED PURSUANT TO SECTIONS 105 AND 107 OF BANKRUPTCY CODE AND FEDERAL RULE OF CIVIL PROCEDURE 26(C) AND THE STIPULATED ADDENDUM TO THE PROTECTIVE ORDER; AND (II) REDESIGNATE BANK STATEMENTS PREVIOUSLY DESIGNATED "HIGHLY CONFIDENTIAL" AS "CONFIDENTIAL"**

UBS AG ("UBS"), by its counsel Herbert Smith Freehills New York LLP, upon the consent of Luc A. Despins, in his capacity as chapter 11 trustee in the above-captioned chapter 11 case of Ho Wan Kwok (the "Trustee" and, together with UBS, collectively, the "Parties"), hereby respectfully moves to adjourn until June 13, 2024 UBS's deadline by which to respond to the *Motion to (I) Modify October 6, 2022 Protective Order Entered Pursuant to Sections 105 and 107 of Bankruptcy Code and Federal Rule of Civil Procedure 26(c) and the Stipulated Addendum to the Protective Order; and (II) Redesignate Bank Statements Previously Designated "Highly Confidential" as "Confidential"* [ECF No. 3213] (the "Motion to Modify"), pursuant to the terms set forth in the proposed *Consent Order Adjourning Response Deadline on Motion to Modify* attached hereto as **Exhibit A** (the "Proposed Consent Order"). UBS and the Trustee are discussing the relief proposed in the Motion to Modify as well as UBS's contemplated response to the Motion to Modify and have consented to adjourn until June 13, 2024 UBS's deadline by which to respond to the Motion to Modify.

WHEREFORE, UBS respectfully requests that the Court adjourn until June 13, 2024

UBS's deadline by which to respond to the Motion to Modify pursuant to the Proposed Consent Order and grant such other relief as is just and proper.

Dated: June 6, 2024 UBS AG New York, New York

*/s/ Lisa J. Fried* Lisa J. Fried (ct31425) HERBERT SMITH FREEHILLS NEW YORK LLP 200 Park Avenue 16th Floor New York, New York 10166 (917) 542-7600 lisa.fried@hsf.com

*Counsel for UBS AG*

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

In re:

Chapter 11

HO WAN KWOK, *et al.*,

Case No. 22-50073 (JAM)

Debtors.

(Jointly Administered)

# **CERTIFICATE OF SERVICE**

The undersigned hereby certifies that on June 6, 2024, the foregoing was electronically filed. Notice of this filing was sent by e-mail to all parties able to receive electronic notice by operation of the Court's electronic filing ("CM/ECF") system. Parties may access this filing through the Court's CM/ECF system.

Dated: June 6, 2024 New York, New York

> */s/ Lisa J. Fried* Lisa J. Fried (ct31425) HERBERT SMITH FREEHILLS NEW YORK LLP 200 Park Avenue 16th Floor New York, New York 10166 (917) 542-7600 lisa.fried@hsf.com

*Counsel for UBS AG*

# **EXHIBIT A**

### **(PROPOSED CONSENT ORDER)**

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

In re:

HO WAN KWOK, *et al.*,

Chapter 11

Case No. 22-50073 (JAM)

Debtors.

(Jointly Administered)

### **[PROPOSED] CONSENT ORDER ADJOURNING UBS AG'S DEADLINE BY WHICH TO RESPOND TO MOTION OF CHAPTER 11 TRUSTEE TO (I) MODIFY OCTOBER 6, 2022 PROTECTIVE ORDER ENTERED PURSUANT TO SECTIONS 105 AND 107 OF BANKRUPTCY CODE AND FEDERAL RULE OF CIVIL PROCEDURE 26(C) AND THE STIPULATED ADDENDUM TO THE PROTECTIVE ORDER; AND (II) REDESIGNATE BANK STATEMENTS PREVIOUSLY DESIGNATED "HIGHLY CONFIDENTIAL" AS "CONFIDENTIAL"**

Upon the motion (the "Motion") of UBS AG, filed upon the consent of Luc A. Despins, chapter 11 trustee (the "Trustee"), to adjourn until June 13, 2024 UBS's deadline by which to respond to the Motion to (I) Modify October 6, 2022 Protective Order Entered Pursuant to Sections 105 and 107 of Bankruptcy Code and Federal Rule of Civil Procedure 26(c) and the Stipulated Addendum to the Protective Order; and (II) Redesignate Bank Statements Previously Designated "Highly Confidential" as "Confidential" [ECF No. 3213] (the "Motion to Modify"), and due and sufficient notice having been given, and good cause appearing for the relief sought by the Motion, it is hereby

**ORDERED,** that UBS AG's deadline by which to respond to the Motion to Modify is adjourned to June 13, 2024.

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

Signed this \_\_ day of \_\_\_\_\_\_\_\_\_\_\_, 2024

Hon. Julie A. Manning United States Bankruptcy Judge