--- type: court_doc id: "court_ctb_3277_0" court: "CTB" case_no: "22-50073" doc_number: 3277 doc_type: "ORDER" filed_date: "2024-06-24" lang: "en" machine_translated: false url: "https://mubeitech.com/en/court/court_ctb_3277_0" json_url: "https://mubeitech.com/api/court/court_ctb_3277_0" --- # Guo Wengui / Miles Guo — bankruptcy case · ORDER · ECF #3277 **Second Interim Fee Application — In re Ho Wan Kwok (Miles Guo / Guo Wengui), CTB No. 22-50073, ECF No. 3277 (filed June 24, 2024). Pallas Partners LLP, UK solicitors to Chapter 11 Trustee Luc A. Despins, applies for compensation of $107,271.50 in professional fees and $875.63 in expense reimbursements, totaling $108,147.13 for the period December 1, 2023 through April 30, 2024.** UNITED STATES BANKRUPTCY COURT DISTRICT OF CONNECTICUT BRIDGEPORT DIVISION ------------------------------------------------------　x In re:　: :　Chapter 11 HO WAN KWOK, et al.,　: :　Case No. 22-50073 (JAM) Debtors.1　: : :　Jointly Administered ------------------------------------------------------　x COVERSHEET FOR SECOND INTERIM FEE APPLICATION OF PALLAS PARTNERS LLP Interim Application of:　Pallas Partners LLP Time Period:　December 1, 2023 through April 30, 2024 Bankruptcy Petition Filed:　February 15, 2022 Date of Entry of Retention Order:　March 24, 2023 [ECF No. 1596] (effective as of January 26, 2023). Amount Requested　Reductions Fees:　\$107,271.50　Voluntary Fee Reductions:　none Expenses:　\$875.63　Voluntary Expenses Reductions: none Total:　\$108,147.13 Fees Previously Requested:　Retainer Request: Requested Fees:　\$318,591.50　None Awarded Fees:　\$305,791.50 Paid Fees:　\$305,791.50 Expenses Previously Requested:　Expense Detail: Requested Expenses:　\$4,953.04　Retainer Received:　Not applicable Awarded Expenses:　\$26.00　Copies per page cost & total: Not applicable Paid Fees:　\$26.00 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). UNITED STATES BANKRUPTCY COURT DISTRICT OF CONNECTICUT BRIDGEPORT DIVISION ------------------------------------------------------　x In re:　: :　Chapter 11 HO WAN KWOK, et al.,　: :　Case No. 22-50073 (JAM) Debtors.1　: : :　Jointly Administered ------------------------------------------------------　x SECOND INTERIM FEE APPLICATION OF PALLAS PARTNERS LLP, AS SOLICITORS IN UNITED KINGDOM, FOR COMPENSATION AND REIMBURSEMENT OF EXPENSES FOR PERIOD FROM DECEMBER 1, 2023 THROUGH APRIL 30, 2024 Pursuant to sections 105(a), 328, 330, and 331 of title 11 of the United States Code (such title, hereinafter, the "Bankruptcy Code"), Rule 2016 of the Federal Rules of Bankruptcy Procedure (the "Bankruptcy Rules"), Rule 2016-1 of the Local Rules of Bankruptcy Practice and Procedure of the United States Bankruptcy Court for the District of Connecticut (the "Local Rules"), and 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"), Pallas Partners LLP ("Pallas"), as United Kingdom solicitors to Luc A. Despins, in his capacity as the chapter 11 trustee (the "Trustee") appointed in the chapter 11 case of Ho Wan Kwok (the "Debtor"), hereby files this *Second Interim Application of Pallas Partners LLP, as Solicitors in United Kingdom, for Compensation and Reimbursement of Expenses for the* 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). Period from December 1, 2023 through April 30, 2024 (the "Application"). By this Application, Pallas requests interim allowance of professional fees incurred during the period from December 1, 2024 through and including April 30, 2024 (the "Application Period") in these chapter 11 cases. In support of this Application, Pallas respectfully states as follows: JURISDICTION, VENUE, BASES FOR RELIEF, AND COMPLIANCE 1. The Court has jurisdiction over this matter pursuant to 28 U.S.C. §§ 157 and 1334 and the Standing Order of Reference from the United States District Court for the District of Connecticut. This matter is a core proceeding within the meaning of 28 U.S.C. § 157(b)(2). Venue is proper pursuant to 28 U.S.C. §§ 1408 and 1409. 2. The legal predicates for the relief requested herein are sections 328, 330, and 331 of the Bankruptcy Code, Bankruptcy Rule 2016, and Local Rule 2016-1. 3. Pallas believes that this Application, together with the attachments hereto, substantially complies with the Bankruptcy Rules, Local Rule 2016-1, and the *United States Trustee's Guidelines for Reviewing Applications for Compensation and Reimbursement of Expenses Filed Under 11 U.S.C. § 330 by Attorneys in Larger Chapter 11 Cases* (the "U.S. Trustee Guidelines").2 Pallas respectfully requests a waiver of any of the foregoing requirements not met by this Application. - 4. Attached and incorporated herein by reference are the following Exhibits: - Exhibit A contains the Proposed Order granting this Application. - Exhibit B is a timekeeper summary that includes the name, title, bar admission, hourly billing rate, aggregate hours, and amount of fees earned for each Pallas individual who provided services during the Application Period; 2 Pallas reserves all rights as to the relevance and substantive legal effect of the U.S. Trustee Guidelines with respect to any application for compensation in these chapter 11 cases. - Exhibit C is a summary of expenses incurred and reimbursement sought, by expense type, during the Application Period; and - Exhibit D contains the detail of the fees and expenses incurred during the Application Period. BACKGROUND 5. On February 15, 2022 (the "Petition Date"), the Individual Debtor filed a voluntary petition for relief under the Bankruptcy Code in the United States Bankruptcy Court for the District of Connecticut (Bridgeport Division) (the "Court"). 6. On March 21, 2022, the United States Trustee appointed an Official Committee of Unsecured Creditors (the "Committee") in the Individual Debtor's chapter 11 case. No examiner has been appointed in the Individual Debtor's chapter 11 case. 7. On June 15, 2022, the Court entered a memorandum of decision and order [ECF No. 465] (the "Trustee Order") directing the United States Trustee to appoint a chapter 11 trustee in the Individual Debtor's chapter 11 case. 8. Pursuant to the Trustee Order, the United States Trustee selected Luc A. Despins as the Trustee. On July 8, 2022, the Court entered an order granting the appointment of Luc A. Despins as the Trustee in the Individual Debtor's chapter 11 case 9. By order entered March 24, 2023, the Court authorized Pallas' retention as solicitor in the United Kingdom for the Trustee [ECF No. 1596] (the "Retention Order") effective as of January 26, 2022 in the Debtor's chapter 11 case. The Retention Order authorizes Pallas to be compensated on an hourly basis and reimbursed for actual and necessary out-ofpocket expenses pursuant to sections 328 and 330 of the Bankruptcy Code, the Bankruptcy Rules, the Local Rules, and such orders as the Court may direct. 10. On August 18, 2023, the Court entered the Interim Compensation Procedures Order, which, among other things, approves procedures for the payment of 80% of fees and 100% of expenses on a monthly basis. 11. On December 27, 2024, Pallas filed its *First Interim Fee Application of Pallas Partners LLP, as Solicitors in United Kingdom, for Compensation and Reimbursement of Expenses for Period From January 26, 2023 Through November 30, 2023* [Docket No. 2475] (the "First Interim Fee Application"), requesting interim allowance of professional fees incurred during the period from January 26, 2023 through and including November 30, 2023 in these chapter 11 cases. On January 24, 2024, the Court granted the First Interim Fee Application. ALLOWANCE REQUEST 12. The Applicant is applying for compensation pursuant to Sections 330 and 331 of the Bankruptcy Code for legal services performed for the Trustee during the Application Period. 13. For the Application Period, the Applicant seeks allowance of \$107,271.50 as compensation for services rendered and allowance and reimbursement of \$875.63 in expenses incurred in connection with such services. The Applicant devoted 111.1 hours to this case during the Application Period, equating to an overall blended rate of \$965.54. 14. Throughout the Application Period, the Applicant maintained records to indicate the name of each attorney or paraprofessional working on this matter, the time spent on a particular issue, and the nature of the work performed. These records, which describe in detail the services rendered by the Applicant, were created at the approximate time the services were performed. 15. Annexed hereto and made a part hereof as Exhibit D is a detailed billing report, upon which this application is based that contains each individual professional's time for the Debtors' bankruptcy cases, itemizing the dates upon which services were rendered, including a summary of the services on each of such dates by each person rendering the service, the time spent in rendering such service, and the dollar value of such services. Summary of Services Rendered 16. Upon being formally instructed, Pallas was asked to provide detailed and strategic advice in connection with the English litigation proceedings (the "UBS Action") brought by the Individual Debtor, Ace Decade Holdings Limited ("Second Claimant") and Dawn State Limited ("Third Claimant") against UBS AG (the "Defendant") (Case CL-2020-000345), which litigation claims constitute property of the Individual Debtor's estate. 17. During the Fee Period, Pallas has been continuing to advise the Trustee on several matters related to the UBS Action, including advising the Trustee on the most cost-efficient ways to maximize value from the UBS Action for the benefit of the Individual Debtor's estate and its creditors. 18. In order to achieve the Trustee's objective of maximizing value for the benefit of the creditors, Pallas has remained focused on advising the Trustee on the process of obtaining control of the Second and Third Claimants for the purposes of the UBS Action. This has required providing advice generally as to matters of English law, including regarding the Trustee's rights and duties as chapter 11 trustee and his ability to seek recognition of foreign court judgments and orders in England in order to be in a position to take control of the UBS Action and realize value from the litigation for the benefit of the creditors. This has also involved liaising with counsel regarding the relevant and necessary relief which needs to be sought in the US and BVI courts in order to persuade the English court to recognize the Trustee's control. 19. To that end, following substantial correspondence and the Second and Third Claimants' refusal to accept the Trustee's control of the companies, we spent substantial time working on the stay application. After this application was brought in December 2023, we were involved in reviewing the response from the Second and Third Claimants and preparing our reply evidence, as well as liaising with counsel in preparing for the stay application hearing listed in March 2024. Upon receipt of our reply evidence, the Second and Third Claimants agreed to consent to a stay. As a consequence, it was no longer necessary to proceed with the application and the listed hearing. 20. The work undertaken by Pallas to date has therefore involved significant work on the substantial stay application, in particular finalizing the application, reviewing the Second and Third Claimant's responsive evidence and preparing our reply evidence, as well as ongoing attention to the relief being sought in the US and BVI courts which is relevant to the relief which must be sought in England in order to obtain control of the Second and Third Claimants and maximize value for the creditors of the Individual Debtor's estate. Pallas has also focused on inter partes correspondence and providing strategic input to the Trustee. This work remains ongoing, with Pallas continuing to follow progress on the necessary US and BVI steps and Pallas is currently liaising with the Second and Third Claimants to seek an extension to the stay application. No Prior Application 21. No prior application for the relief requested has been made. Legal Authority for Compensation 22. All of the professional services for which this award is being sought hereby were rendered solely on behalf of the Trustee in connection with the chapter 11 cases herein. 23. Applicant respectfully submits that its services have benefited the Trustee with the expertise and skill required in the handling of bankruptcy matters. The legal services for which such compensation is requested were performed for and on behalf of the Trustee. Such services have been necessary to protect and enforce the rights and interests of the Trustee in connection with these chapter 11 cases. The reasonable value of services rendered by Pallas in these cases is based upon Pallas' usual hourly rates for matters of this nature. 24. Section 330 of the Bankruptcy Code prescribes the general standards for determining the amount of compensation to be paid to professionals. The Applicant submits that the amount sought for the Application Period represents reasonable compensation for professional services rendered based upon the time spent, the nature, the extent, and the value of such services, taking into account the cost of comparable services in a non-bankruptcy case. 25. Section 331 of the Bankruptcy Code provides for interim compensation of professionals and incorporates the substantive standards of section 330 of the Bankruptcy Code to govern the Court's award of such compensation. Section 330(a) of the Bankruptcy Code provides that, after notice and a hearing, the Court may award a professional employed under 11 U.S.C. § 327 "reasonable compensation for actual, necessary services rendered" and "reimbursement for actual, necessary expenses." 11 U.S.C. § 330(a)(1).3 26. In determining the amount of "reasonable compensation," the Court must consider the nature, extent, and value of the services, taking into account all the relevant factors, including the time spent on such services, the rates charged for such services, whether the services were necessary and beneficial, whether the services were performed in a reasonable 3 Under section 328(a) of the Bankruptcy Code, with bankruptcy court approval, a trustee may employ professional persons under section 327(a) of the Bankruptcy Code "on any reasonable terms and conditions of employment, including on a retainer, on an hourly basis, on a fixed or percentage fee basis, or on a contingent fee basis." 11 U.S.C. § 328(a). amount of time commensurate with the complexity, importance, and nature of the problem, issue, or task addressed, and whether the compensation is reasonable based on the customary compensation charged by comparably skilled practitioners in cases other than cases under the Bankruptcy Code. See 11 U.S.C. § 330(a)(3). The Court enjoys "considerable discretion in determining reasonable fee awards." In re Ahead Communication Systems, Inc., 395 B.R. 512 (D. Conn. 2008). 27. In assessing the "reasonableness" of the fees requested, the Second Circuit has stated that courts should consider the factors enumerated in Johnson v. Ga. Highway Express, Inc., 4 while also incorporating the "lodestar method." See Arbor Hill Concerned Citizens Neighborhood Ass'n v. County of Albany and Albany County Bd. of Elections, 522 F.3d 182, 190 (2d Cir. 2007) (citing Johnson v. Ga. Highway Express, Inc., 488 F.2d 714 (5th Cir.1974), abrogated on other grounds by Blanchard v. Bergeron, 489 U.S. 87, 92–93, 96 (1989)). The "lodestar method" of calculating the reasonable fee contemplates "the number of hours reasonably expended . . . multiplied by a reasonable hourly rate." See Hensley v. Eckerhart, 461 U.S. 424, 433 (1983); Gisbrecht v. Barnhart, 535 U.S. 789, 801 (2002); Perdue v. Kenny A., 130 S.Ct. 1662, 1672 (2010); In re Drexel Burnham Lambert Grp., Inc., 133 B.R. 13 (Bankr. S.D.N.Y. 1991). The factors set forth in Johnson and In re First Colonial Corp. of Am., 544 F.2d 1291, 1298–99 (5th Cir. 1977) have been adopted by most courts.5 See In re Nine Assocs., 4 The twelve Johnson factors are (1) the time and labor required, (2) the novelty and difficulty of the questions, (3) the skill requisite to perform the legal service properly, (4) the preclusion of other employment by the attorney due to acceptance of the case, (5) the customary fee, (6) whether the fee is fixed or contingent, (7) the time limitations imposed by the client or the circumstances, (8) the amount involved and the results obtained, (9) the experience, reputation, and ability of the attorneys, (10) the "undesirability" of the case, (11) the nature and length of the professional relationship with the client, and (12) awards in similar cases. Johnson, 488 F.2d at 717-19. 5 The factors articulated in First Colonial were first articulated by the Fifth Circuit in Johnson, with the First Colonial court adding the factor of the "spirit of economy," which was later rejected by Congress. See Stroock & Stroock & Lavan v. Hillsborough Holdings Corp. (In re Hillsborough Holdings Corp.), 127 F.3d 1398, 1403 Inc., 76 B.R. 943, 945 (S.D.N.Y. 1987) (adopting First Colonial/Johnson analysis); In re Cuisine Magazine, Inc., 61 B.R. 210, 212–13 (Bankr. S.D.N.Y 1986) (same); Green v. City of New York, 403 F. Appx. 626, 629 (2d Cir. 2010) (summary order); see generally 3 COLLIER ON BANKRUPTCY ¶ 330.03[9] (Lawrence P. King ed., 16th ed. 2016) (describing First Colonial and Johnson as the "leading cases with regard to the factors to be considered in determining a reasonable allowance of compensation"). 28. In accordance with the factors enumerated in section 330 of the Bankruptcy Code and applicable case law, the amount requested herein by Pallas is fair and reasonable. Statutory Compliance 29. No agreement or understanding exists between Pallas and any other person for the sharing of compensation received or to be received for services rendered in or in connection with this matter. Pallas will not, in any form or guise, share or agree to share compensation for services with any person, nor will Pallas share in the compensation for any other person rendering service in these cases, except as so provided by section 504(b) of the Bankruptcy Code and Rule 2016 of the Bankruptcy Rules. RESERVATION OF RIGHTS 30. To the extent that time or disbursement charges for services rendered or expenses incurred during the Application Period are not included in this Application, or Pallas has for any reason not sought compensation or reimbursement with respect to such services, Pallas reserves the right to request compensation and reimbursement for such services in a supplemental or future application in these chapter 11 cases. Also, Pallas does not waive, and expressly reserves, (11th Cir. 1997). its right to respond to any objections regarding this Application and the amounts sought for services rendered and expenses incurred. NO PRIOR REQUEST 31. No previous request for the relief sought herein has been made to this Court or any other court. [THE REMAINDER OF THIS PAGE IS INTENTIONALLY BLANK.] WHEREFORE, Pallas respectfully requests entry of an order, substantially in the form attached hereto, (i) allowing interim compensation for professional services rendered during the Application Period in the amount of \$107,271.50 and reimbursement of \$875.63 in expenses, (ii) authorizing and directing prompt payment of the unpaid fees in the amount of \$108,147.13 from the estates, (iii) allowing such compensation and payment for professional services rendered without prejudice to Pallas' right to seek further compensation and/or payment from the estates for the full value of services performed and expenses incurred, and (iv) granting Pallas such other and further relief as is just. Dated: June 24, 2024 London, United Kingdom By: /s/ Natasha Harrison PALLAS PARTNERS LLP 1 King William Street London, EC4N 7AF United Kingdom Telephone: +44 20 4574 1001 Email: natasha.harrison@pallasllp.com United Kingdom Solicitor to Luc A. Despins, Chapter 11 Trustee IN THE UNITED STATES BANKRUPTCY COURT FOR THE DISTRICT OF CONNECTICUT BRIDGEPORT DIVISION In re: HO WAN KWOK, et al., Debtors.1 Chapter 11 ) ) ) ) ) ) ) ) Case No. 22-50073 (JAM) (Jointly Administered) CERTIFICATE OF SERVICE The undersigned hereby certifies that on June 24, 2024, the *Second Interim Application of Pallas Partners LLP, as Solicitors in United Kingdom, for Compensation and Reimbursement of Expenses for the Period from December 1, 2023 through April 30, 2024* (the "Application")2 was electronically filed. Notice of this filing was sent by e-mail to all parties to the above-captioned chapter 11 cases by operation of the Court's electronic filing ("CM/ECF") system or by mail to anyone unable to accept electronic filing as indicated on the Notice of Electronic Filing.3 In addition, to the extent not covered by the foregoing, copies of the Application were served on the twenty (20) largest creditors in the Debtors' chapter 11 cases. Parties may access this filing through the Court's CM/ECF system. 1 The Debtors in these chapter 11 cases are Ho Wan Kwok (also known as Guo Wengui, Miles Guo, and Miles Kwok, as well as numerous other aliases) (last four digits of tax identification number: 9595), Genever Holdings LLC (last four digits of tax identification number: 8202) and Genever Holdings Corporation. The mailing address for the Trustee, Genever Holdings LLC, and Genever Holdings Corporation is Paul Hastings LLP, 200 Park Avenue, New York, NY 10166 c/o Luc A. Despins, as Trustee for the Estate of Ho Wan Kwok (solely for purposes of notices and communications). 2 Capitalized terms used but not defined in this Certification shall have the meanings ascribed to them in the Application. 3 To the extent that the foregoing was filed outside regular business hours, service by mail on recipients unable or not qualified to accept electronic notice was made on the next business day. Dated: June 24, 2024 By: /s/ G. Alexander Bongartz G. Alexander Bongartz (pro hac vice) Douglass Barron (pro hac vice) PAUL HASTINGS LLP 200 Park Avenue New York, New York 10166 (212) 318-6079 douglassbarron@paulhastings.com Counsel for the Chapter 11 Trustee Case 22-50073 Doc 3277 Filed 06/24/24 Entered 06/24/24 16:18:28 Page 15 of 42 EXHIBIT A Proposed Order UNITED STATES BANKRUPTCY COURT DISTRICT OF CONNECTICUT BRIDGEPORT DIVISION x In re:　: : Chapter 11 HO WAN KWOK, et al.,　: : Case No. 22-50073 (JAM) Debtors.1　: : Jointly Administered x **[PROPOSED] ORDER GRANTING FIRST INTERIM FEE APPLICATION OF PALLAS PARTNERS LLP, AS SOLICITORS IN UNITED KINGDOM, FOR COMPENSATION AND REIMBURSEMENT OF EXPENSES FOR PERIOD FROM DECEMBER 1, 2023 THROUGH APRIL 30, 2024** Upon consideration of the Application (the "Application") of Pallas Partners LLP ("Pallas") as solicitor in the United Kingdom to the Trustee2 for interim allowance of compensation and reimbursement of expenses from December 1, 2023 through April 30, 2024; and sufficient notice having been given; and a hearing having been held on \_\_\_\_\_\_\_\_, 2024 and due consideration having been given to any responses thereto; and sufficient cause having been shown therefor, it is hereby: 1. ORDERED that the Application is granted and compensation in the amount of \$107,271.50 and reimbursement of expenses in the amount of \$875.63 are awarded to Pallas, subject to final adjustment and disgorgement in the event all administrative expenses are not paid in full; it is further 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 adopt the definitions set forth in the Application. 2. ORDERED that nothing herein modified the Retention Order; it is further 3. ORDERED that the estates are authorized and directed to pay Pallas' fees and expenses in the aggregate amount of \$108,147.13, within fourteen days of the date of this Order; it is further 4. ORDERED that this Court shall retain jurisdiction to hear and determine all matters arising from the implementation of this Order; it is further 5. ORDERED that the Debtors' estates and Pallas are authorized and empowered to take all necessary actions to implement the relief granted in this Order; it is further 6. ORDERED that notwithstanding the possible applicability of Bankruptcy Rules 6006(d), 7062, 9014, or otherwise, the terms and conditions of this Order shall be immediately effective and enforceable upon its entry; and it is further 7. ORDERED that all time periods set forth in this Order shall be calculated in accordance with Bankruptcy Rule 9006(a). Case 22-50073 Doc 3277 Filed 06/24/24 Entered 06/24/24 16:18:28 Page 18 of 42 EXHIBIT B Timekeeper Summary1 December 1, 2023 through December 31, 2023 TIMEKEEPER　DATE OF FIRST BAR　TITLE　HOURS　HOURLY RATE　TOTAL ADMISSION Natasha Harrison　2005　Partner　1.2　\$1,400.00　\$1,680.00 Alessia De Quincey　2015　Associate　12.1　\$980.00　\$11,858.00 Joseph Fox Davies　2022　Associate　1.6　\$730.00　\$1,168.00 Chloe Salter　Paralegal　10.7　\$415.00　\$4,440.50 Total:　25.6　\$747.91　\$19,146.50 Blended Hourly Rate: \$747.91 January 1, 2024 through April 30, 2024 TIMEKEEPER　DATE OF FIRST BAR　TITLE　HOURS　HOURLY RATE　TOTAL ADMISSION Natasha Harrison　2005　Partner　8.5　\$1,400.00　\$11,900.00 Matthew Getz　2005　Partner　0.4　\$1,450.00　\$580.00 Alessia De Quincey　2015　Associate　65.2　\$1,050.00　\$68,460.00 Joseph Fox Davies　2022　Associate　5.40　\$825.00　\$4,455.00 Fatima Nadeem　Paralegal　6.0　\$455.00　\$2,730.00 Total:　85.5　\$1,030.70　88.125.00 Blended Hourly Rate: \$1,030.70 1 Please note that the timekeeper summary tables have been divided according to 2023 and 2024 Pallas rates. EXHIBIT C Summary of Actual and Necessary Expenses Expense Category　Amount Court Fees　\$617.60 Copying　\$258.03 TOTAL　\$875.63 Case 22-50073 Doc 3277 Filed 06/24/24 Entered 06/24/24 16:18:28 Page 20 of 42 EXHIBIT D Fee and Expense Detail Case 22-50073 Doc 3277 Filed 06/24/24 Entered 06/24/24 16:18:28 Page 21 of 42 VAT %　VAT \$　VALUE \$ Professional Charges　0.00　0.00　19,146.50 Disbursements Court Costs-Filing Fees　0.00　0.00　344.74 Fees Value　19,146.50 Disbursements　344.74 VAT　0.00 Invoice Total　\$19,491.24 Case 22-50073 Doc 3277 Filed 06/24/24 Entered 06/24/24 16:18:28 Page 22 of 42 Client Name: Matter Name: Client/Matter Number:　Despins, Luc Luc Despins in his capacity as Ch 11 Trustee of an individual Ho Wan Kwok 16126.0001 01 December 2023 to 31 December 2023 Invoice Period: Invoice No:　2028 Fee Earner　Title　Time (hrs)　Rate (\$)　Value (\$) Natasha Harrison　Managing Partner　1.20　1.400.00　1,680.00 Alessia de Quincey　Associate　12.10　980.00　11,858.00 Joseph Fox-Davies　Associate　1.60　730.00　1.168.00 Chloe Salter　Paralegal　10.70　415.00　4.440.50 Total Fees　\$19.146.50 Case 22-50073 Doc 3277 Filed 06/24/24 Entered 06/24/24 16:18:28 Page 23 of 42 Case 22-50073　Doc 3277　Filed 06/24/24　Entered 06/24/24 16:18:28　Page 24 of 42 Case 22-50073 Doc 3277 Filed 06/24/24 Entered 06/24/24 16:18:28 Page 25 of 42 Client Name:　Despins, Luc Matter Name:　Luc Despins in his capacity as Ch 11 Trustee of an individual Ho Wan Kwok Client/Matter Number: 16126.0001 Invoice Period:　01 December 2023 to 31 December 2023 Invoice No:　2028 Date　Disbursement　Description　Value (\$) 12-Dec-23　Court Costs-Filing Fees　Vendor: HM Courts & Tribunals　344.74 Service; Invoice#: 940348; Date: 12/12/2023 - Court Fees - 08/12/23 - FACCT-RBF-0000483799 Commercial Court Applicat ion to a Circuit Judge Part 7 Claim-CL-2020-0003 45- Disbursement Value Charged　\$ 344.74 Case 22-50073 Doc 3277 Filed 06/24/24 Entered 06/24/24 16:18:28 Page 26 of 42 VAT %　VAT \$　VALUE \$ Professional Charges　0.00　0.00　59,755.00 Disbursements Court Costs-Filing Fees　0.00　0.00　136.63 Photocopies　0.00　0.00　258.03 Fees Value Disbursements VAT　59,755.00 394.66 0.00 ------------------------------------------------------------------------------------------------------------------------------------------------------------------------------　000 410 00 Case 22-50073 Doc 3277 Filed 06/24/24 Entered 06/24/24 16:18:28 Page 27 of 42 Client Name: Matter Name: Client/Matter Number: Invoice Period: Invoice No:　Despins, Luc Luc Despins in his capacity as Ch 11 Trustee of an individual Ho Wan Kwok 16126.0001 02 January 2024 to 31 January 2024 Fee Earner　Title　Time (hrs)　Rate (\$)　Value (\$) Natasha Harrison　Managing Partner　5.00　1.400.00　7.000.00 Alessia de Quincey　Associate　43.40　1.050.00　45,570.00 Joseph Fox-Davies　Associate　5.40　825.00　4.455.00 Fatima Nadeem　Paralegal　6.00　455.00　2.730.00 Total Fees　\$59,755.00 Case 22-50073 Doc 3277 Filed 06/24/24 Entered 06/24/24 16:18:28 Page 28 of 42 Client Name: Matter Name: Client/Matter Number: Invoice Period: Invoice No: 2141　Despins, Luc 16126.0001　Luc Despins in his capacity as Ch 11 Trustee of an individual Ho Wan Kwok 02 January 2024 to 31 January 2024 Date　Fee Earner　Description　Time (hrs)　Value (\$) 02-Jan-24　Natasha Harrison　Update with AdQ; liaise re; Counsel; attention to inter partes correspondence　0.70　980.00 02-Jan-24　Alessia de Quincey　Attention to emails and extension request　0.60　630.00 03-Jan-24　Natasha Harrison　Attention to evidence; office con with AdQ; attention to strategy　0.50　700.00 03-Jan-24　Alessia de Quincey　Preparing for and attending internal catch-up　0.60　630.00 03-Jan-24　Alessia de Quincey　Attention to call with P. Wright on next steps　0.70　735.00 03-Jan-24　Alessia de Quincey　attention to inter partes correspondence　0.50　525.00 03-Jan-24　Alessia de Quincey　Attention to email on property issue and emails on same　0.40　420.00 03-Jan-24　Joseph Fox-Davies　Confer with A. de Quincey re: listing of stay application. Call with clerks re: same. Emails with A. de Quincey re: stay application.　0.90　742.50 04-Jan-24　Natasha Harrison　Liaise re enforcement of property; attention to HP evidence; attention to correspondence and overall strategy; attending call with Luc Despins　1.00　1,400.00 04-Jan-24　Alessia de Quincey　Attention to and next steps on potential disclosure application including Insolvency Act provisions　1.30　1,365.00 04-Jan-24　Alessia de Quincey　Attention to emails　0.20　210.00 04-Jan-24　Alessia de Quincey　attention to inter partes correspondence on stay application　1.20　1,260.00 04-Jan-24　Alessia de Quincey attention to next steps and updating consent order　0.60　630.00 04-Jan-24　Alessia de Quincey Attention to preparing for and attending call with P. Wright on matter　0.40　420.00 Case 22-50073 Doc 3277 Filed 06/24/24 Entered 06/24/24 16:18:28 Page 29 of 42 04-Jan-24　Alessia de Quincey　Attention to inter partes calls on extension　0.20　210.00 04-Jan-24　Alessia de Quincey　Attention to Despins conflicts declaration matters and follow-up requests　0.50　525.00 04-Jan-24　Joseph Fox-Davies　Call with clerks re: listing of stay application. Emails and calls with A. de Quincey re: same.　0.40　330.00 05-Jan-24　Alessia de Quincey　Attention to finalising extension request and Court correspondence and filing matters.　1.00　1,050.00 05-Jan-24　Joseph Fox-Davies　Amendments to consent order. Emails with A. de Quincey re: filing consent order. Attention to emails re: same. Call with Herbert Smith re: consent order. Amend letter to Court. Email to Court and other side re: consent order. Emails with C. Salter re: filing on CE- File. Call with clerks re: counsel availability and listing of stay application.　2.80　2,310.00 07-Jan-24　Alessia de Quincey　Attention to emails on listing　0.10　105.00 08-Jan-24　Alessia de Quincey　Attention to declaration conflicts matters and follow-up queries　0.70　735.00 10-Jan-24　Alessia de Quincey　Attention to stay application reply evidence and next steps　1.20　1,260.00 11-Jan-24　Alessia de Quincey　attention to listing and KC matters　0.40　420.00 12-Jan-24　Alessia de Quincey　Preparing for and attending call with client and counsel on next steps　0.60　630.00 12-Jan-24　Alessia de Quincey　Attention to emails and reply evidence　0.40　420.00 12-Jan-24　Alessia de Quincey　attention to listing matters　0.30　315.00 12-Jan-24　Joseph Fox-Davies　Emails with A. de Quincey re: counsel availability for stay application　0.20　165.00 15-Jan-24　Alessia de Quincey attention to reply evidence　4.00　4,200.00 15-Jan-24　Alessia de Quincey attention to declaration matters　0.50　525.00 15-Jan-24　Alessia de Quincey attention to liaising with clerks and listing　0.50　525.00 15-Jan-24　Joseph Fox-Davies Calls with clerks re: listing appointment 0.70 re: stay application. Emails with A. de Quincey re: same.　577.50 16-Jan-24　Alessia de Quincey further attention to reply evidence and drafting and incorporating latest comments on stay reply evidence　7.50　7,875.00 16-Jan-24　Alessia de Quincey attention to procedural steps　0.50　525.00 Case 22-50073 Doc 3277 Filed 06/24/24 Entered 06/24/24 16:18:28 Page 30 of 42 16-Jan-24　Alessia de Quincey　attention to counsel options　0.60　630.00 16-Jan-24　Joseph Fox-Davies　Review witness statement in support of stay application. Confer with A. de Quincey re: same.　0.40　330.00 17-Jan-24　Natasha Harrison　Attention to draft witness statement; emails in/out with Luc and AdQ　1.50　2,100.00 17-Jan-24　Natasha Harrison　Attention to final form witness statement; comments to Alessia　0.90　1,260.00 17-Jan-24　Alessia de Quincey　Attention to follow-up queries for US team on Application and US/BVI process　1.50　1,575.00 17-Jan-24　Alessia de Quincey　Attention to updating reply evidence and incorporating comments from client and counsel　4.00　4,200.00 17-Jan-24　Alessia de Quincey　Attention to liaising internally on exhibit　0.80　840.00 17-Jan-24　Fatima Nadeem　Beginning research on NH2 exhibit and finding documents　1.00　455.00 17-Jan-24　Fatima Nadeem　Sorting out index for NH2 exhibit and continuing finding documents ahead of filing WS2　3.00　1,365.00 18-Jan-24　Alessia de Quincey　attention to stay reply evidence filing and incorporating comments from client, N. Harrison and counsel　3.80　3,990.00 18-Jan-24　Alessia de Quincey　attention to collating documents for exhibit and review of same　0.50　525.00 19-Jan-24　Alessia de Quincey　Attention to finalising filing including work on finalising draft, cross- references and exhibit　5.80　6,090.00 19-Jan-24　Alessia de Quincey　Attention to counsel correspondence　0.70　735.00 19-Jan-24　Alessia de Quincey　attention to BVI updates　0.10　105.00 19-Jan-24　Fatima Nadeem　Collating documents for the exhibit for the NH2 Witness statement, cross referencing the docs in the witness statement, putting the index together and filing the NH2 WS along with the exhibit on CE file.　2.00　910.00 23-Jan-24　Alessia de Quincey attention to next steps and latest UK court judgment　0.40　420.00 25-Jan-24　Natasha Harrison　Attention to timelines and next steps; emails in/out with AdQ and LD　0.40　560.00 25-Jan-24　Alessia de Quincey attention to correspondence with client on next steps　0.30　315.00 Total Value Charged　\$59,755.00 Case 22-50073 Doc 3277 Filed 06/24/24 Entered 06/24/24 16:18:28 Page 31 of 42 Client Name:　Despins, Luc Matter Name:　Luc Despins in his capacity as Ch 11 Trustee of an individual Ho Wan Kwok Client/Matter Number:　16126.0001 Invoice Period:　02 January 2024 to 31 January 2024 Invoice No:　2141 Date　Disbursement　Description　Value (\$) 16-Jan-24　Court Costs-Filing Fees　Vendor: HM Courts & Tribunals　136.63 Service; Invoice#: 955622; Date: 16/01/2024 - Court Fees - 05/01/24 - FACCT-RBF-0000489791 Commercial Court Applicat ion to a Circuit Judge Part 7 Claim-CL-2020-0003 45- 26-Jan-24　Photocopies　Vendor: Millnet Document Services;　258.03 Invoice#: 118230; Date: 26/01/2024 - Printing, binding & delivery (03/01/24) Disbursement Value Charged　\$ 394.66 Case 22-50073 Doc 3277 Filed 06/24/24 Entered 06/24/24 16:18:28 Page 32 of 42 VAT %　VAT \$　VALUE \$ Professional Charges　0.00　0.00　20,005.00 Fees Value　20,005.00 VAT Invoice Total　0.00 \$20,005.00 Case 22-50073 Doc 3277 Filed 06/24/24 Entered 06/24/24 16:18:28 Page 33 of 42 Client Name:　Despins, Luc Matter Name:　Luc Despins in his capacity as Ch 11 Trustee of an individual Ho Wan Kwok 16126.0001 02 February 2024 to 06 March 2024 Client/Matter Number: Invoice Period: Invoice No:　2428 Fee Earner　Title　Time (hrs)　Rate (\$)　Value (\$) Natasha Harrison　Managing Partner　2.10　1,400.00　2.940.00 Matthew Getz　Partner　0.40　1.450.00　580.00 Alessia de Quincey　Associate　15.70　1.050.00　16.485.00 Total Fees　\$20,005.00 Case 22-50073 Doc 3277 Filed 06/24/24 Entered 06/24/24 16:18:28 Page 34 of 42 Case 22-50073 Doc 3277 Filed 06/24/24 Entered 06/24/24 16:18:28 Page 35 of 42 27-Feb-24　Alessia de Quincey　Attention to further inter partes correspondence　0.50　525.00 28-Feb-24　Natasha Harrison　Attention to analysis on freezing order; attention to email from AdQ; consider next steps, including underlying causes of action　0.70　980.00 28-Feb-24　Alessia de Quincey Preparing for and attending call with counsel and attention to emails and analysis　1.50　1,575.00 29-Feb-24　Matthew Getz　[Kwok] Advise A De Quincey on freezers.　0.40　580.00 29-Feb-24　Alessia de Quincey attention to US team follow-up queries re recognition and emails on same　0.40　420.00 29-Feb-24　Alessia de Quincey Attention to latest analysis and emails on same for client re UK property and discussion with M. Getz on same and addressing client follow-up queries　1.70　1,785.00 29-Feb-24　Alessia de Quincey　Attention to inter partes correspondence on draft consent order and emails on same　0.30　315.00 Total Value Charged　\$20,005.00 Case 22-50073 Doc 3277 Filed 06/24/24 Entered 06/24/24 16:18:28 Page 36 of 42 VAT %　VAT \$　VALUE \$ Professional Charges　0.00　0.00　2,695.00 Disbursements Court Costs-Filing Fees　0.00　0.00　483.12 Court Costs-Filing Fees　0.00 I　0.00　-346.89 Fees Value　2,695.00 Carle Carren Research and Career of Children　00 00 Disbursements　136.23 VAT　0.00 Case 22-50073 Doc 3277 Filed 06/24/24 Entered 06/24/24 16:18:28 Page 37 of 42 Client Name:　Despins, Luc Matter Name:　Luc Despins in his capacity as Ch 11 Trustee of an individual Ho Wan Kwok Client/Matter Number:　16126.0001 Invoice Period:　01 March 2024 to 31 March 2024 Invoice No:　2427 Fee Earner　Title　Time (hrs)　Rate (\$)　Value (\$) Natasha Harrison　Managing　0.50　1.400.00　700.00 Partner Alessia de Quincey　Associate　1.90　1.050.00　1.995.00 Total Fees　\$2,695.00 Case 22-50073 Doc 3277 Filed 06/24/24 Entered 06/24/24 16:18:28 Page 38 of 42 Client Name:　Despins, Luc Matter Name:　Luc Despins in his capacity as Ch 11 Trustee of an individual Ho Wan Kwok Client/Matter Number:　16126.0001 Invoice Period:　01 March 2024 to 31 March 2024 Invoice No: Date　Fee Earner　Description　Time (hrs)　Value (\$) 01-Mar-24　Natasha Harrison　Attention to freezing order analysis; attention to emails in/out with Alessia; Prep and attend call with Luc Despins　0.50　700.00 01-Mar-24　Alessia de Quincey　Attention to inter partes correspondence and draft consent order　0.30　315.00 04-Mar-24　Alessia de Quincey　Attention to consent order correspondence and filing　0.40　420.00 11-Mar-24　Alessia de Quincey　Attention to consent order and counsel emails on vacating hearing　0.50　525.00 12-Mar-24　Alessia de Quincey　Attention to sealed consent order and emails　0.20　210.00 13-Mar-24　Alessia de Quincey　Attention to call re counsel fees and attention to follow-up　0.50　525.00 Total Value Charged　\$2,695.00 Case 22-50073 Doc 3277 Filed 06/24/24 Entered 06/24/24 16:18:28 Page 39 of 42 Client Name: Matter Name: Client/Matter Number: Invoice Period: Invoice No:　Despins, Luc Luc Despins in his capacity as Ch 11 Trustee of an individual Ho Wan Kwok 16126.0001 01 March 2024 to 31 March 2024 Date　Disbursement　Description　Value (\$) 12-Mar-24　Court Costs-Filing Fees　Vendor: HM Courts & Tribunals Service; Invoice#: 980538; Date: 12/03/2024 - Court fees - 04/0/24 - FACCT-RBF-0000506719 Commercial Court Applicat ion to a Circuit Judge Part 7 Claim-CL-2020-0003 45-16126.0001 1437321709553764552　346.89 12-Mar-24　Court Costs-Filing Fees　Vendor: HM Courts & Tribunals Service; Invoice#: 980538; Date: 12/03/2024 - Court fees - 05/03/24 - FACCT-RBF-0000507130 Commercial Court Applicat ion to a Circuit Judge Part 7 Claim-CL-2020-0003 45-16126.0001 1437321709640614612　136.23 19-Mar-24　Court Costs-Filing Fees　Vendor: HM Courts & Tribunals Service; Invoice#: 983107; Date: 19/03/2024 - Court fees - 14/03/24 - FACCTRBR1-0000506719 Commercial Court Applicat ion to a Circuit Judge REFUND-Part 7 Claim-CL-20 20-000345-16126.0001 1437321709553764552　-346.89 Disbursement Value Charged　\$ 136.23 Case 22-50073 Doc 3277 Filed 06/24/24 Entered 06/24/24 16:18:28 Page 40 of 42 VAT %　VAT \$　VALUE \$ Professional Charges　0.00　0.00　5,670.00 Fees Value　5,670.00 VAT　0.00 Invoice Total　\$5,670.00 Case 22-50073 Doc 3277 Filed 06/24/24 Entered 06/24/24 16:18:28 Page 41 of 42 Despins, Luc　Client Name: Luc Despins in his capacity as Ch 11 Trustee of an individual Ho Wan Kwok　Matter Name: Client/Matter Number: Invoice Period: 2368　Invoice No: Value (\$) Rate (\$)　Time (hrs)　Title　Fee Earner 1.260.00　1.400.00　0.90　Managing Partner　Natasha Harrison 4.410.00　1.050.00　4.20　Associate　Alessia de Quincey 16126.0001 08 April 2024 to 30 April 2024 Case 22-50073 Doc 3277 Filed 06/24/24 Entered 06/24/24 16:18:28 Page 42 of 42 ------------------------------------------------------------------------------------------------------------------------------------------------------------------------------　0 0 050 00 30-Apr-24　Alessia de Quincey Attention to fee application and emails with counsel including redacted application.　0.80　840.00 29-Apr-24　Alessia de Quincey Attention to emails with counsel.　0.10　105.00 cilent requests and internal emails on same (0.8); preparing for and attending catch-up call with counsel (0.6).