Guo Wengui / Miles Guo — bankruptcy case · PETITION · ECF #3280

UNITED STATES BANKRUPTCY COURT DISTRICT OF CONNECTICUT BRIDGEPORT DIVISION

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In re: :

HO WAN KWOK, et al., : :

Debtors.1 :

------------------------------------------------------ x COVERSHEET FOR THIRD INTERIM FEE APPLICATION OF HARNEY WESTWOOD & RIEGELS LP

Interim Application of: Harney Westwood & Riegels LP

Time Period: January 1, 2024 through April 30, 2024 Bankruptcy Petition Filed: February 15, 2022 (main bankruptcy case) Date of Entry of Retention Orders: October 3, 2022 [ECF No. 909] (effective as of July 31, 2022, as to Individual Debtor), January 4, 2023 [ECF No. 1247] (effective as of November 21, 2022, as to Genever (BVI)), and May 28, 2024 [ECF No. 3219] (effective as of

Fees: \$293,992.00 Voluntary Fee Reductions: none Expenses: \$30,910.01 Voluntary Expenses Reductions:

Fees Previously Requested: Retainer Request:

Expenses Previously Requested: Expense Detail: Requested Expenses: \$43,554.06 Retainer Received: Not applicable Awarded Expenses: \$43,554.06 Copies per page cost & total: Not applicable

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

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In re: :

HO WAN KWOK, et al., :

Debtors.1 : :

------------------------------------------------------ x **THIRD INTERIM FEE APPLICATION OF HARNEY WESTWOOD & RIEGELS LP, AS BRITISH VIRGIN ISLANDS AND CAYMAN ISLANDS COUNSEL, FOR COMPENSATION AND REIMBURSEMENT OF EXPENSES FOR PERIOD FROM JANUARY 1, 2024 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"), Harney Westwood & Riegels LP ("Harneys"), (a) as British Virgin Islands ("BVI") and Caymans Islands counsel 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 "Individual Debtor") and (b) as BVI counsel to Genever Holdings Corporation ("Genever (BVI)"), hereby

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).

files this *Third Interim Application of Harneys Westwood & Riegels LP., as British Virgin Islands and Cayman Islands Counsel, for Compensation and Reimbursement of Expenses for the Period from January 1, 2024 through April 30, 2024* (the "Application"). By this Application, Harneys requests interim allowance of professional fees incurred during the period from January 1, 2024 through and including April 30, 2024 (the "Application Period") in these chapter 11 cases.2 In support of this Application, Harneys 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. Harneys 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").3 Harneys 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:

2 For the avoidance of doubt, as it relates to Caymans Islands services, this Application only seeks allowance of fees and reimbursement of expenses incurred by Harneys during the period from April 10, 2024 (i.e., the effective date of Harney's retention as Cayman Islands counsel) through and including April 30, 2024.

3 Harneys 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 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 Harneys individual who provided services during the Application Period; - 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.

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 October 3, 2022, the Court authorized Harney's retention as BVI counsel for the Trustee [Docket No. 669] effective as of July 31, 2022 in the Individual Debtor's chapter 11 case. The Retention Order authorizes Harneys to be compensated on an hourly basis and reimbursed for actual and necessary out-of-pocket 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. By order entered May 28, 2024, the Court expanded Harney's retention to also serve as Cayman Islands counsel for the Trustee [Docket No. 3219] (together with the retention orders with respect to BVI-related services for the Trustee and Genever (BVI) [Docket Nos. 669 and 1286], the "Retention Order"), effective as of April 10, 2024.

12. On October 11, 2022, Genever (BVI) filed a voluntary petition for relief under chapter 11 of the Bankruptcy Code with this Court.

13. No trustee, examiner, or official committee of unsecured creditors has been appointed in Genever (BVI)'s chapter 11 case.

14. October 14, 2022, the Court entered an order granting joint administration of the Individual Debtor's chapter 11 case and Genever (BVI)'s chapter 11 case [ECF No. 970].

15. On January 4, 2023, the Court granted Genever (BVI)'s application to retain Harneys as counsel to Genever (BVI) in its chapter 11 case, effective as of its petition date, i.e., November 21, 2022 [ECF No. 1286].

16. On October 16, 2023, Harneys filed its *First Interim Fee Application of Harney Westwood & Riegels LP, as British Virgin Islands Counsel, for Compensation and Reimbursement of Expenses for Period From July 31, 2022 Through July 31, 2023* [Docket No. 2259] (the "First Interim Fee Application"), requesting interim allowance of professional fees incurred during the period from July 31, 2022 through and including July 31, 2023 in these chapter 11 cases.

17. On November 30, 2023, the Court granted the First Interim Fee Application.

18. On February 19, 2024, Harneys filed its *Second Interim Fee Application of Harney Westwood & Riegels LP, as British Virgin Islands Counsel, for Compensation and Reimbursement of Expenses for Period From August 1, 2023 Through December 31, 2023* [Docket No. 2259] (the "Second Interim Fee Application" and, together with the First Interim Fee Application, the "Prior Interim Fee Applications"), requesting interim allowance of professional fees incurred during the period from August 1, 2023 through and including December 31, 2023 in these chapter 11 cases.

19. On March 20, 2024, the Court granted the Second Interim Fee Application.

20. The Applicant is applying for compensation pursuant to Sections 330 and 331 of the Bankruptcy Code for legal services performed for the Trustee and Genever (BVI) during the Application Period.

21. For the Application Period, the Applicant seeks allowance of for the period from January 1, 2024 through and including April 30, 2024, \$293,992.00 as compensation for services rendered as BVI and Cayman counsel and allowance and reimbursement of \$30,910.01 in expenses incurred in connection with such services.

22. The Applicant devoted 319.3 hours to this case during the Application Period, equating to an overall blended rate of \$920.74.

23. Harneys did not submit any monthly fee statements during the Application Period, and, accordingly, by this Application, Harneys is requesting allowance and payment of the full amount of fees and expenses incurred during the Application Period.

24. 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.

25. 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 proceedings, 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.

26. During the Application Period, Harneys continued to provide legal services as BVI and Cayman counsel to the Trustee, including advice for bankruptcy, litigation, investigations, real estate, tax, and other matters.

27. As detailed in Harneys' Prior Interim Fee Applications, upon being formally instructed, Harneys took immediate steps on behalf of the Trustee to obtain various disclosure orders from the BVI court related to BVI registered agents as part of the Trustee's efforts to investigate the Debtors' financial affairs, including his ownership of assets through family, friends, and affiliates. In particular, on January 10, 2024, the BVI court granted a disclosure order against the registered agent of K Legacy Ltd. ("K Legacy") compelling it to disclose

certain documents regarding K Legacy. The disclosure order was sought because the Trustee believes K Legacy is beneficially owned by the Debtor. The Trustee's investigations into the affairs of K Legacy revealed that K Legacy's sole assets is a high-value property in London (the "London Apartment") which was being marketed for sale.

28. Based on this information, Harneys took urgent steps to prepare and file an ex parte application4 for a notification injunction before the BVI court (the "Injunction Application"). The Injunction Application sought an order that the Trustee be notified of any intention to deal with the London Apartment, including but not limited to, the sale or transfer of the shares in K Legacy which would enable the Trustee to take appropriate action (if necessary) to ensure that the London Apartment and the shares in the K Legacy were not sold or transferred. Injunctive relief was also sought and granted against K Legacy's purported sole shareholder, Salamander Nominees Limited ("Salamander") to protect the shares in K Legacy. The requested injunctive relief was granted by the BVI court. Following service of the Injunction Application on K Legacy and Salamander, Harneys filed an application to continue the injunctive relief, which was granted on April 16, 2024.

29. The Trustee's investigation has also discovered numerous other BVI companies that may be equitably owned by the Individual Debtor. In particular, Harneys carried out extensive investigations into the status of over 100 BVI companies, and reviewed and advised on the search results and director searches of these companies. Harneys also undertook a comprehensive review of these companies. In addition, Harneys provided advice and

4 The Trustee sought ex parte relief due to the Individual Debtor's consistent fraudulent conduct and the Trustee's concern that advance notice would accelerate attempts to transfer the Property and or sell the shares in the K Legacy.

recommendations to the Trustee as to how to obtain additional information from BVI companies who are named defendants in adversary proceedings related to these chapter 11 cases.

30. Harneys also provided general advice to the Trustee on several other complex matters related to the Trustee's efforts to recover property of the estate, including commencing substantive proceedings under the Part 19 of the BVI Insolvency Act and undertaking extensive research to advise on the enforceability of default judgments, the rectification of a register of members, and the restoration of the BVI companies.

31. Assistance was also provided to the Trustee on several other matters, including effectuating service of several complaints on several BVI and Cayman companies and preparing application documents for disclosure from BVI registered agents as to additional BVI companies related to the Individual Debtor (including a seal and gag application).

32. No prior application for the relief requested has been made. And, as noted, Harneys has not received any payment of the fees incurred during the Application Period.

33. All of the professional services for which this award is being sought hereby were rendered solely on behalf of the Trustee and Genever (BVI) in connection with the chapter 11 cases herein.

34. Applicant respectfully submits that its services have benefited the Trustee and Genever (BVI) 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 and Genever (BVI). Such services have been necessary to protect and enforce the rights and interests of the Trustee and Genever (BVI) in connection with these chapter 11 cases. The

reasonable value of services rendered by Harneys in these cases is based upon Harneys usual hourly rates for matters of this nature.

35. 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.

36. 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).5

37. 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 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

5 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).

determining reasonable fee awards." In re Ahead Communication Systems, Inc., 395 B.R. 512 (D. Conn. 2008).

38. 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., 6 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.7 See In re Nine Assocs., 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

6 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.

7 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 (11th Cir. 1997).

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").

39. In accordance with the factors enumerated in section 330 of the Bankruptcy Code and applicable case law, the amount requested herein by Harneys is fair and reasonable.

40. No agreement or understanding exists between Harneys and any other person for the sharing of compensation received or to be received for services rendered in or in connection with this matter. Harneys will not, in any form or guise, share or agree to share compensation for services with any person, nor will Harneys 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.

41. 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 Harneys has for any reason not sought compensation or reimbursement with respect to such services, Harneys reserves the right to request compensation and reimbursement for such services in a supplemental or future application in these chapter 11 cases. Also, Harneys does not waive, and expressly reserves, its right to respond to any objections regarding this Application and the amounts sought for services rendered and expenses incurred.

42. No previous request for the relief sought herein has been made to this Court or any other court.

WHEREFORE, Harneys respectfully requests entry of an order, substantially in the form attached hereto, (i) allowing interim compensation, and authorizing and directing prompt payment, for professional services rendered during the Application Period in the amount of \$293,992.00 and reimbursement of \$30,910.01 in expenses, (ii) allowing such compensation and payment for professional services rendered without prejudice to Harneys' right to seek further compensation and/or payment from the estates for the full value of services performed and expenses incurred, and (iii) granting Harneys such other and further relief as is just.

Andrew Thorp HARNEY WESTWOOD & RIEGELS LP Craigmuir Chambers, PO Box 71, Road Town, Tortola VG1110, British Virgin Islands Telephone: 1 284 852 2571 Email: Andrew.thorp@harneys.com

British Virgin Islands and Cayman Islands Counsel to Luc A. Despins, Chapter 11 Trustee, and Genever Holdings Corporation IN THE UNITED STATES BANKRUPTCY COURT FOR THE DISTRICT OF CONNECTICUT BRIDGEPORT DIVISION

In re:

The undersigned hereby certifies that on June 24, 2024, the *Second Interim Fee Application of Harney Westwood & Riegels LP, as British Virgin Islands and Cayman Islands Counsel, for Compensation and Reimbursement of Expenses for the Period from January 1, 2024 Through April 30, 2024* (the "Application")10 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.11 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.

9 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).

10 Capitalized terms used but not defined in this Certification shall have the meanings ascribed to them in the Application.

11 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 New York, New York 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 alexbongartz@paulhastings.com douglassbarron@paulhastings.com

Counsel for the Chapter 11 Trustee, Genever Holdings LLC, and Genever Holdings Corporation

Case 22-50073 Doc 3280 Filed 06/24/24 Entered 06/24/24 17:36:24 Page 16 of 50

UNITED STATES BANKRUPTCY COURT DISTRICT OF CONNECTICUT BRIDGEPORT DIVISION

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In re: : :

HO WAN KWOK, et al., : :

Debtors.1 : :

**[PROPOSED] ORDER GRANTING SECOND INTERIM FEE APPLICATION OF HARNEY WESTWOOD & RIEGELS LP, AS BRITISH VIRGIN ISLANDS AND CAYMAN ISLANDS COUNSEL, FOR COMPENSATION AND REIMBURSEMENT OF EXPENSES FOR PERIOD FROM JANURY 1, 2024 THROUGH APRIL 30, 2024**

Upon consideration of the Application (the "Application") of Harney Westwood & Riegels ("Harneys") as BVI2 and Cayman Islands counsel to the Trustee and Genever (BVI) for interim allowance of compensation and reimbursement of expenses from January 1, 2024 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 \$293,992.00 and reimbursement of expenses in the amount of \$30,910.01 are awarded to Harneys, 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 the Genever Holdings Corporation is Paul Hastings LLP, 200 Park Avenue, New York, NY 10166 c/o Luc A. Despins, as Trustee for the Estate of Ho Wan Kwok (solely for purposes of notices and communications).

2 Capitalized terms not 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 Harneys' fees and expenses in the aggregate amount of \$324,902.01 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 Harneys 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 3280 Filed 06/24/24 Entered 06/24/24 17:36:24 Page 19 of 50

January 1, 2024 through April 30, 2024:

TIMEKEEPER DATE OF TITLE HOURS HOURLY TOTAL

Andrew Thorp 1998 Partner 89.0 \$1,300.00 \$115,700.00 Ben Hobden 2008 Partner 4.2 \$1,300.00 \$5,460.00 Colin Riegels 1996 Partner 2.2 \$1,300.00 \$2,860.00 Marcia McFarlane 2007 Partner 56.6 \$1,300.00 \$73,580.00 Peter Ferrer 1998 Partner 10.8 \$1,215.00 \$14,040.00 Kimberley Crabbe-Adams 2010 Counsel 0.2 \$1,015.00 \$203.00 Natalie Lee 2013 Counsel 1.2 \$1,015.00 \$1,218.00 Caitlin Murdock 2014 Senior Associate 1.5 \$910.00 \$1,365.00 Jhneil Stewart 2018 Senior Associate 8.4 \$910.00 \$7,644.00 Isobel McNaught 2021 Associate 9.6 \$590.00 \$5,664.00 Jhneil Stewart 2018 Associate 94.2 \$590.00 \$54,516.00 Luke Fraser 2016 Associate 5.2 \$590.00 \$3,068.00 Hailey Cheung Paraprofessional 6.6 \$320.00 \$2,112.00

Administrative support professional's time effecting service on BVI Companies

Alnessa Davis-Morris Legal Secretary 0.8 \$275.00 \$220.00 Sahodra Faulkner Legal Secretary 12.0 \$275.00 \$3,300.00 Tea Fonseca Administrative Assistant 3.6 \$220.00 \$2,250.00 Shemar Trim Administrative Assistant 15.0 \$150.00 \$792.00

Case 22-50073 Doc 3280 Filed 06/24/24 Entered 06/24/24 17:36:24 Page 21 of 50

Timekeeper Worked Narrative Billed Billed Billed

03/01/2024 Call with Alex at Paul Hastings re H Club Hours

Thorp entities and disclosure applications, review

Jhneil Stewart 11/01/2024 Reviewing underlying documents and 2 590.00 1180.00 considering next steps (1.80); circulating

Jhneil Stewart 11/01/2024 Call with A Thorp re next steps (0.20); email 0.4 590.00 236.00

Jhneil Stewart 12/01/2024 Considering emails and search results in 0.2 590.00 118.00 details and cross-referencing target names Jhneil Stewart 12/01/2024 Detailed review of proposed changes (1.00) 6 590.00 3540.00 ; considering underlying documents received from clients (1.00); Drafting application documents and collating docs for exhibit for

15/01/2024 of entities and director searches Arranging service and director searches of

Considering emails from AM (0.20); reviewing file and considering next steps and disclosure strategy against target BVI

Considering service issues and publication of notices in Gazette re equitable tolling Review of results of director entities on 13 entities, cross referencing to other posts and

Review of certificate of service and mails to

3rd party disclosure order against Himalaya entities (4.00). Reviewing list of directors and researching

Hastings. Detailed review of service issues on 100+

alternative notice provisions and statutory

Hastings and further considering totality of

Jhneil Stewart 15/01/2024 Considering case law on whether 3.6 590.00 2124.00 information can be obtained by other means (1.00); considering and drafting evidence

Marcia 15/01/2024 Reviewed full and frank disclosure in light 0.2 1300.00 260.00 McFarlane of extant summons for companies to produce

Jhneil Stewart 16/01/2024 Further draft of skeleton (1.00); finalizing 3.8 590.00 2242.00 docs for exhibit (1.00); instructions to team

referencing exhibit with affidavit (1.40);

Jhneil Stewart 17/01/2024 Considering numerous case law (1.40); 3.2 590.00 1888.00 finalizing exhibit and suite of application docs (1.60); email to A Thorp re next steps

Marcia 17/01/2024 Attended to reviewing application 1.2 1300.00 1560.00 McFarlane documents seeking gag and disclosure Jhneil Stewart 18/01/2024 Email to A Thorp re draft affidavit 0.2 590.00 118.00 Andrew 19/01/2024 Cross referencing 50 plus entities with 1.2 1300.00 1560.00 Thorp dissolved and resigned parties (0.8). Con with Paul Hastings re service and next steps

Andrew 19/01/2024 Considering enforcement of rectification 0.6 1300.00 780.00 Thorp claim (in Ace Decade) and advising

Andrew 23/01/2024 Review of service letters (x50) and known 1.2 1300.00 1560.00 Thorp BVI cos. Jhneil Stewart 23/01/2024 Considering emails and call with team re 0.6 590.00 354.00 next steps (0.20); email to team re same and call with team re publication (0.20); email to

Letter of service to Ace Decade 0.2 1300.00 260.00

Andrew 23/01/2024 Letter of service Bouillon Holdings 0.2 1300.00 260.00

Andrew 23/01/2024 Letter of service Ace Decade 0.2 1300.00 260.00

Jhneil Stewart 24/01/2024 Call with A Thorp re next steps; call with 0.2 590.00 118.00 team re same; considering email from team

Andrew 24/01/2024 Oversight of service on BVI entities, cross 0.8 1300.00 1040.00 Thorp referencing to schedule and correct

Andrew 25/01/2024 Drafting Service Letter for Service of Notice 0.2 1300-00 260.00 Thorp of Motion and Motion of Entry on G

Timekeeper Worked Narrative Billed Billed Billed

Andrew 25/01/2024 Drafting Service Letter for Service of Notice 0.2 1300.00 260.00 Thorp of Motion and Motion of Entry on Jovial

Andrew 25/01/2024 Drafting Service Letter for Service of Notice 0.2 1300.00 260.00 Thorp of Motion and Motion of Entry on G

Andrew 25/01/2024 Drafting Service Letter for Service of Notice 0.2 1300.00 260.00 Thorp of Motion and Motion of Entry on Allied

Andrew 25/01/2024 Drafting Service Letter for Service of Notice 0.2 1300.00 260.00 Thorp of Motion and Motion of Entry on Wise Creation International Limited c/o Harneys

Andrew 25/01/2024 Drafting Service Letter for Service of Notice 0.4 1300.00 520.00

Drafting Service Letter for Service of Notice 0.2 1300.00 260.00 Thorp of Motion and Motion of Entry on K Legacy

Andrew 25/01/2024 Drafting Service Letter for Service of Notice 0.2 1300.00 260.00 Thorp of Motion and Motion of Entry on Hamilton

Andrew 25/01/2024 Drafting Service Letter for Service of Notice 0.2 1300.00 260.00 Thorp of Motion and Motion of Entry on Freedom

Andrew 25/01/2024 Drafting Service Letter for Service of Notice 0.2 1300.00 260.00 Thorp of Motion and Motion of Entry on Wealth

Andrew 25/01/2024 Drafting Service Letter for Service of Notice 0.2 1300.00 260.00 Thorp of Motion and Motion of Entry on Head Win

Andrew 25/01/2024 Drafting Service Letter for Service of Notice 0.2 1300.00 260.00 Thorp of Motion and Motion of Entry on Anton

Thorp Drafting Service Letter for Service of Notice of Motion and Motion of Entry on Himalaya 0.2 1300.00 260.00 International Clearing Limited c/o Conyers

Andrew 25/01/2024 Drafting Service Letter for Service of Notice 0.2 1300.00 260.00 Thorp of Motion and Motion of Entry on Leading

Andrew 25/01/2024 Drafting Service Letter for Service of Notice 0.2 1300.00 260.00 Thorp of Motion and Motion of Entry on Gold Leaf

Timekeeper Worked Narrative Billed Billed Billed

Thorp 25/01/2024 Drafting Service Letter for Service of Notice

Thorp 25/01/2024 Drafting Service Letter for Service of Notice

Thorp 25/01/2024 Drafting Service Letter for Service of Notice

Origin Limited c/o AMS Trustees Limited 0.2 1300.00 260.00

Thorp 25/01/2024 Drafting Service Letter for Service of Notice

Services BVI Limited 0.2 1300.00 260.00

Thorp 25/01/2024 Drafting Service Letter for Service of Notice

Ace Ventures Limited c/o FFP BVI Limited 0.2 1300.00 260.00

Thorp 25/01/2024 Drafting Service Letter for Service of Notice of Motion and Motion of Entry on Himalaya International Reserves Limited c/o Conyers Trust Company BVI Limited 0.2 1300.00 260.00

Thorp 25/01/2024 Drafting Service Letter for Service of Notice

Century Limited c/o CCS Trustees Limited 0.2 1300.00 260.00

Thorp 25/01/2024 Drafting Service Letter for Service of Notice

Global Limited c/o FFP BVI Limited 0.2 1300.00 260.00

Thorp 25/01/2024 Drafting Service Letter for Service of Notice of Motion and Motion of Entry on Himalaya International Financial Group c/o Conyers Trust Company BVI Limited 0.2 1300.00 260.00

Thorp 25/01/2024 Drafting Service Letter for Service of Notice

Commence Overseas Limited 0.2 1300.00 260.00

Thorp 25/01/2024 Drafting Service Letter for Service of Notice

Century Limited c/o CCS Trustees Limited 0.2 1300.00 260.00

Thorp 25/01/2024 Drafting Service Letter for Service of Notice

Commence Overseas Limited 0.2 1300-00 260.00

Thorp 25/01/2024 Drafting Service Letter for Service of Notice

Gate Limited c/o FFP BVI Limited 0.2 1300.00 260.00

Thorp 25/01/2024 Drafting Service Letter for Service of Notice of Motion and Motion of Entry on Himalaya International Payments Limited c/o Conyers Trust Company BVI Limited 0.2 1300.00 260.00

Timekeeper Worked Narrative Billed Billed Billed

Andrew 25/01/2024 Drafting Service Letter for Service of Notice 0.2 1300.00 260.00 Thorp of Motion and Motion of Entry on PA

Andrew 25/01/2024 Drafting Service Letter for Service of Notice 0.2 1300.00 260.00 Thorp of Motion and Motion of Entry on Next Tycoon Inv. Limited c/o Vistra BVI Limited Andrew 25/01/2024 Drafting Service Letter for Service of Notice 0.2 1300.00 260.00 Thorp of Motion and Motion of Entry on ACA

Andrew 25/01/2024 Drafting Service Letter for Service of Notice 0.2 1300.00 260.00 Thorp of Motion and Motion of Entry on G

Andrew 25/01/2024 Drafting Service Letter for Service of Notice 0.2 1300.00 260.00 Thorp of Motion and Motion of Entry on Hudson

Andrew 25/01/2024 Drafting Service Letter for Service of Notice 0.2 1300.00 260.00 Thorp of Motion and Motion of Entry on PA

Andrew 25/01/2024 Drafting Service Letter for Service of Notice 0.2 1300.00 260.00 Thorp of Motion and Motion of Entry on Bouillion

Andrew 25/01/2024 Drafting Service Letter for Service of Notice 0.2 1300.00 260.00 Thorp of Motion and Motion of Entry on Creative

Andrew 25/01/2024 Drafting Service Letter for Service of Notice 0.2 1300.00 260.00 Thorp of Motion and Motion of Entry on Crystal Breeze Investments Limited c/o Vistra BVI

Andrew 25/01/2024 Drafting Service Letter for Service of Notice 0.2 1300.00 260.00 Thorp of Motion and Motion of Entry on Shiny

Andrew 25/01/2024 Drafting Service Letter for Service of Notice 0.2 1300.00 260.00 Thorp of Motion and Motion of Entry on Globalist International Limited c/o Vistra BVI Limited Andrew 25/01/2024 Drafting Service Letter for Service of Notice 0.2 1300.00 260.00 Thorp of Motion and Motion of Entry on Elite Well

Andrew 25/01/2024 Drafting Service Letter for Service of Notice 0.2 1300.00 260.00

Andrew 25/01/2024 Drafting Service Letter for Service of Notice 0.2 1300.00 260.00 Thorp of Motion and Motion of Entry on Shiny Times Limited c/o Offshore Incorporations

Timekeeper Worked Narrative Billed Billed Billed

Andrew 25/01/2024 Drafting Service Letter for Service of Notice 0.2 1300.00 260.00 Thorp of Motion and Motion of Entry on Noble

Andrew 25/01/2024 Drafting Service Letter for Service of Notice 0.2 1300.00 260.00 Thorp of Motion and Motion of Entry on Joy

Andrew 25/01/2024 Drafting Service Letter for Service of Notice 0.2 1300.00 260.00 Thorp of Motion and Motion of Entry on Assets

Andrew 25/01/2024 Drafting Service Letter for Service of Notice 0.2 1300.00 260.00 Thorp of Motion and Motion of Entry on Mega

Andrew 25/01/2024 Drafting Service Letter for Service of Notice 0.2 1300-00 260.00 Thorp of Motion and Motion of Entry on Shiny

Jhneil Stewart 25/01/2024 Consider emails and next steps 0.2 590.00 118.00 Jhneil Stewart 29/01/2024 Emails re next steps; call with team re AOS 0.4 590.00 236.00 30/01/2024 Considering emails from A Thorp re notice of motion (0.20); call with A Thorp re next 4.2 590.00 2478.00 steps (0.20); call with team re service and draft schedule A (0.20); emails to team and

publication (0.40); reviewing draft schedule A and making amends (0.40); reviewing and editing notice of motion (0.40); reviewing

(1.20); considering emails (0.20; emails to A

swearing affidavits (0.40); calls with team re

Andrew 30/01/2024 Review of certificate of service afficavits 1 1300.00 1300.00 Thorp and cross- checking and confirming service entities. Andrew 02/02/2024 Con with Paul Hastings re service on ace 0.4 1300.00 520.00 Thorp decade, possibility of disclosure app and next steps regarding confirming service on

review of service of US proceedings in Ace Thorp Decade and affidavit of service. Emailing

Andrew 07/02/2024 Emails regarding formation of BVI 0.8 1300.00 1040.00 Thorp defendants, searches and confirming status. Andrew 09/02/2024 Advising further on ability to sue dissolved 0.6 1300.00 780.00

Andrew 15/02/2024 Further mails to Trident re disclosure 0.4 1300.00 520.00

Jhneil Stewart 15/02/2024 Considering emails and next steps (0.20; 0.4 590.00 236.00

Timekeeper Worked Narrative Billed Billed Billed

Colin Riegels 16/02/2024 Drafting letter of advice on registered agents/BVI service. 2.2 1300.00 2860.00 Andrew 16/02/2024 Review of searches re correct entity and 1 1300-00 1300.00 Thorp target co, emails to Paul Hastings re identity

Andrew 16/02/2024 Advising on position in relation to 1 1300.00 1300.00 Thorp persuasive common law and applicability of bare trust relationship in other jurisdictions. Andrew 16/02/2024 Mails with Trident re service and ace decade 0.4 1300.00 520.00

Andrew 19/02/2024 Mail in from Trident re position and service 0.2 1300.00 260.00

Jhneil Stewart 19/02/2024 0.4 590.00 236.00

Jhneil Stewart 20/02/2024 Considering client's query re Ace Decade 0.8 590.00 472.00 disclosure (0.20); reviewing file (0.40);

Andrew 20/02/2024 Considering disclosure and dates re position. 0.6 1300.00 780.00 Thorp Note of change of ownership and timeline

Andrew 20/02/2024 Emails in from Trident and Appleby 0.4 1300.00 520.00

Andrew 20/02/2024 Mail to Paul Hastings re disclosure and 0.2 1300.00 260.00 Thorp client of record- Woltwrs Kluwer in NY Andrew 22/02/2024 Call with Paul Hastings re beneficial 0.6 1300.00 780.00 Thorp ownership of ace decade and service issues Andrew 01/03/2024 Call with US trustee regarding potential 0.6 1300.00 780.00 Thorp injunctive relief against K Legacy and

Andrew 03/03/2024 Review of Kroll report on K Legacy and 1 1300.00 1300.00

04/03/2024 Review of material from Paul Hastings and cross-reference to pleading in Omnibus alter 2 1300.00 2600.00 Thorp ego claim. Considering strength of nominee claim based on evidence provided. Andrew 04/03/2024 Initial draft of evidence in support of ব 1300.00 5200.00 Thorp injunction application for K Legacy. Andrew 05/03/2024 Considering threshold test in Candey v 1 1300.00 1300-00 Thorp Hoylake and review of ancillary cases for

Andrew 05/03/2024 Advice to Paul Hastings regarding Stop 0.4 1300.00 520.00

Andrew 05/03/2024 Considering stop notice v injunction for 0.6 1300-00 780.00 Thorp underlying shares in K Legacy as a means of

Andrew 05/03/2024 Drafting Application for injunction against 1.2 1300.00 1560.00

Andrew 05/03/2024 Mail from Paul Hastings re salamander with 0.8 1300.00 1040.00 Thorp enclosure, review and prep ahead of

Timekeeper Worked Narrative Billed Billed Billed

Andrew 05/03/2024 Considering salamander position and 0.6 1300.00 780.00 Thorp pleading in omnibus complaint and whether Salamander should be a defendant.

enforcement position ahead of confcall. Andrew 05/03/2024 Conference call with team regarding 0.6 1300.00 780.00 Thorp evidence, risk of dissipation and strategy for

Andrew 05/03/2024 Conf call with PH, DB, AL and NB 0.6 1300.00 780.00

shareholder and requirement as party to US

Andrew 05/03/2024 Note of advice on Salamnder and Stop 0.8 1300.00 1040.00 Thorp Notice requirements. Enforceability of non- submission judgments in BVI and non-cause of action defendants. Jhneil Stewart 05/03/2024 Call with A Thorp and PAF re next steps; ર્ 590.00 3540.00 discussing instructions and strategy with A Thorp; reviewing file; email to A Thorp re

Affidavit of Luc Despins; drafting skeleton

Peter Ferrer 05/03/2024 Conference with A Thorp and considering 0.6 1300.00 780.00

Marcia 06/03/2024 Prepared analysis for subs on notification 2.4 1300.00 3120.00 McFarlane injunction, proprietary injunction Marcia 06/03/2024 Strategy meeting to discuss evidence 4.4 1300.00 5720.00 McFarlane awaited, challenges with claim, legal basis for obtaining relief and work streams to be

(1.0) Reviewed the background information

Jhneil Stewart 06/03/2024 Strategy meeting (1.0); considering 10.8 590.00 6372.00

submissions (4:00) and drafting submissions

Jhneil Stewart 07/03/2024 Discussion with M McFarlane re skeleton 6.2 590.00 3658.00

50+ documents for exhibit and edits to draft

McFarlane re draft email to client (0.20); discussing affidavit with M McFarlane and email to client re document request (0.20)

on the test to be applied to receive a 4.8 6240.00

notification injunction and with A Thorp the Marcia 08/03/2024 basis for seeking a proprietary injunction Reviewed client update following 0.2 1300.00 260.00 McFarlane development with proceedings for Lamp

Timekeeper Worked Narrative Billed Billed Billed

Jhneil Stewart 08/03/2024 Consider and respond to client query re 5.2 590.00 3068.00 exhibit (0.40); actioning client proposed amends to affidavit (0.60); email to A Thorp re same (0.20); downloading and reviewing documents sent from client re exhibit (1.60); emails to client and team(0.40); updating draft exhibit and folder of docs (1.40); discussion with M McFarlane re next steps

Andrew 08/03/2024 Emails with Paul Hastings re evidence and 0.8 1300.00 1040.00

Andrew 11/03/2024 Call with Paul Hastings re disclosure, 0.8 1300.00 1040.00 Thorp redacted complaint and provenance of bank

Andrew 11/03/2024 Considering new evidence and amends to 1.2 1300.00 1560.00

Jhneil Stewart 11/03/2024 Con call with clients(0.80); discussing next 1.4 590.00 826.00 steps with A Thorp (0.40); email to team re

Marcia 11/03/2024 Reviewed summary update of call on bank 0.4 1300.00 520.00

Marcia 12/03/2024 Update from A Thorp regarding 3.8 1300.00 4940.00 McFarlane (0.40); discussed with J Stewart updates to

Jhneil Stewart 12/03/2024 Considering emails; discussing evidential 0.6 590.00 354.00

Andrew 12/03/2024 Mails to Paul Hastings regarding urgency, 0.6 1300.00 780.00

Andrew 12/03/2024 Draft of skeleton argument and developing 1.4 1300.00 1820.00

Andrew 12/03/2024 Considering source of dissipation risk and 0.8 1300.00 1040.00 Thorp need to maintain confidentiality. Redraft of

Andrew 13/03/2024 Review of draft order and amends 0.4 1300.00 520.00

Andrew 13/03/2024 Review of affidavit, drafting section urgency 0.6 1300.00 780.00

Jhneil Stewart 13/03/2024 Discussing next steps with A Thorp (0.40); 6 590.00 3540.00

McFarlane and next steps (0.40); collating exhibit (2:80); considering M McFarlane's edits to evidence (0.60); cross referencing exhibit with affidavit (1.60); discussing next

Marcia 13/03/2024 Attended to updating submissions to address র্ব 1300.00 5200.00 McFarlane the basis for asserting risk of dissipation;

Timekeeper Worked Narrative Billed Billed Billed

McFarlane 14/03/2024 Reviewed the updates made by the client to the affidavit, acknowledged client email and responded to the team 0.2 1300.00 260.00 Jhneil Stewart 14/03/2024 Considering amends from client on draft

papers (1.80); emails to team(0.40); discussing next steps with A Thorp (0.20); updating exhibit (0.40); email to client re drafts(0.20); consider and attend to client query re confidential bank statement (0.40); email to client and team re same (0.20) 4 590.00 2360.00

Thorp 14/03/2024 Review of application, draft order and certificates for filing 0.8 1300.00 1040.00 Jhneil Stewart 15/03/2024 Amends to skeleton and authorities bundle index (0.40); email to team re same (0.20); instruction to team re authorities bundle

referencing authorities bundle with skeleton

Thorp 15/03/2024 Considering Doug and amendments to evidence and final version from the trustee 1 1300.00 1300.00

Thorp 17/03/2024 Review of amends to affidavit from Paul

Jhneil Stewart 18/03/2024 Email to client re updated drafts (0.20); finalizing draft documents (2:00); amends to skeleton (1:20); emails to team (0.20); email to PAF re pleadings (0.20); emails and calls with A Thorp re drafts (0.40) 4.2 590.00 2478.00

McNaught 18/03/2024 Call with Andy re injunction application 0.2 590.00 118.00 Peter Ferrer 20/03/2024 Conference with A Thorp re hearing in Kwok for injunctive relief 0.4 1300.00 520.00 Jhneil Stewart 20/03/2024 Revising suite of draft injunction application

party(considering basis to add a party and evidence; updating notice of application, draft order, affidavit etc.) (7.0); updating corresponding exhibit (1.20); email to team

Jhneil Stewart 20/03/2024 Emails re next steps (0.20; email to PAF re draft documents (0.20) 0.4 590.00 236.00

McFarlane 21/03/2024 Reviewed updates to the draft ordinary application, certificate of urgency, draft

reference to the shareholder and finalised

transmitted to the client 2.6 1300.00 3380.00

Thorp 21/03/2024 Mail in from Paul Hastings tr amendments to affidavit to include fraudulent transfer allegations against QG 0.4 1300.00 520.00

Thorp 21/03/2024 Considering Paul Hastings comments on suits of injunction documents, approval and

Timekeeper Worked Narrative Billed Billed Billed

Andrew 21/03/2024 Considering position with respect to 1.4 1300.00 1820.00 Thorp additional defendant and legal relief required in circumstances where the respondent is not a defendant to foreign proceedings. Advising and amending application to reflect position. Jhneil Stewart 21/03/2024 Making further amends to suite of 2.6 590.00 1534.00 application documents (1.60) ; discussing detailed review of exhibit (0.60);

Andrew 22/03/2024 Considering swearing of affidavit and 0.4 1300.00 520.00

Andrew 22/03/2024 Review of new allegations regarding sons 0.2 1300.00 260.00 Thorp propensity to transfer in breach, confirming

Andrew 22/03/2024 Mails in and reply to trustee regarding 0.4 1300.00 520.00

Andrew 22/03/2024 Review of skeleton arguments and final 0.6 1300.00 780.00

Andrew 22/03/2024 Further mails re fraudulent transfer 0.2 1300-00 260.00 Thorp including additional evidence in relation

Marcia 22/03/2024 Reviewed client instructions with comments 4.6 1300.00 5980.00 McFarlane on the affidavit, made updates to the

finalised all edits to application, certificate of urgency, drafted and arranged swearing of Micah hall affidavit (2.00). Calls with J Stewart to verify latest version of exhibits (0.6); collated signed affidavit of Luc and

arranged signature of application, urgency certificate and listing request and arranged filing and update to client and counsel doing

Jhneil Stewart 22/03/2024 Considering clients amends to draft 3 590.00 1770.00 documents (0.60); marking amends (1.40); email to client re updated drafts (0.20); call with M McFarlane re updated exhibit (0.20);

Andrew 25/03/2024 Drafting Service Letter for Service of Notice 0.2 1300.00 260.00 Thorp of Motion and Motion of Entry on Major Lead International Limited c/o Vistra BVI

Andrew 25/03/2024 Drafting Service Letter for Service of Notice 0.2 1300.00 260.00 Thorp of Motion and Motion of Entry on Guang

Andrew 25/03/2024 Drafting Service Letter for Service of Notice 0.2 1300.00 260.00

Timekeeper Worked Narrative Billed Billed Billed

McFarlane 25/03/2024 Updated client with next steps for listing, prepared and filed sworn affidavit of Luc

prepared instructions for hearing bundle to 2 1300.00 2600.00 be created. Corrected the numbering to the

McFarlane 26/03/2024 Received call from the Court regarding the

flagged the certificate of urgency; Attended to email from court regarding a hearing date

skels, filed skels and authorities and updated court with filed skels 1.4 1300.00 1820.00

McFarlane 26/03/2024 Print and collate authorities bundle for

Peter Ferrer 26/03/2024 Reading papers for injunction 2.6 1300.00 3380.00 Jhneil Stewart 26/03/2024 Consider and attend to email from court re

finalizing skeleton for filing(1.40); diarising

Thorp 26/03/2024 Drafting Service Letter for Service of Notice of Motion and Motion of Entry on K Legacy

Peter Ferrer 27/03/2024 Preparing for injunction hearing and

27/03/2024 Attended to tasks to be completed in preparation for an order and the requirement to serve the documents, liaising with the Court regarding payment of fees, attended to

bundle, (1.2) Attended to hearing and took a note (0.6) Post hearing, prepared a letter to the court , updated the draft order, reviewed A Thorp comments, finalised the letter and updated the draft order, submitted order and letter to Court for approval. (1.4). Updated the note of the hearing to prepare for service on the Respondents. (1.4) 4.6 1300.00 5980.00

Thorp Corrections to court order and undertakings 0.6 1300.00

Thorp 27/03/2024 Drafting letter to Judge correcting record

Thorp 27/03/2024 Considering redacted complaint and advising court re confidentiality 0.8 1300.00 1040.00

Thorp 27/03/2024 Email to trustees re result 0.2 1300.00 260.00

Thorp 27/03/2024 Email in from trustee and response re service and hearing 0.6 1300.00 780.00

Thorp 28/03/2024 Review of order and draft, considering undertaking and amendments 0.4 1300.00 520.00

Timekeeper Worked Narrative Billed Billed Billed

Andrew 28/03/2024 Mails in from Judges clerk re sealing and 0.4 1300.00 520.00

Andrew 28/03/2024 Review of hearing note and bundle of 0.6 1300.00 780.00

Marcia 28/03/2024 Further to Court email with approved order, 4.2 1300.00 5460.00 McFarlane called court to verify email address and

finalised order for filing, filed order and

registrar to assist with sealing order (0.80).

defendants (0.20), emails to the court to follow up sealing of the order (0.40). Finalise note of hearing for service (0.60). Emails and calls to court to assist with ad hoc task for adding the defendants to the claim (0.60). Attended to issue of K Legacy

Jhneil Stewart 28/03/2024 Emails with M McFarlane re next steps 1.4 590.00 826.00

documents (0.60); discussing next steps re

Andrew 28/03/2024 Service letter to 2x defendants 0.4 1300.00 520.00

Andrew 02/04/2024 Review of position re K Legacy and impact 0.6 1300.00 780.00 Thorp of dissolution on proceedings. Marcia 02/04/2024 Discussed with J Stewart next steps with K 0.4 1300.00 520.00 McFarlane Legacy being dissolved and company search

Jhneil Stewart 02/04/2024 Discussing next steps with M McFarlane; 0.4 910.00 364.00

Jhneil Stewart 03/04/2024 Discussing next steps with M McFarlane 2 910.00 1820.00

application and draft order (0.80);

Jhneil Stewart 04/04/2024 Discussing next step with M McFarlane 2 910.00 1820.00 (0.40); emails to A Thorp re current position and status of drafts (0.40); progressing draft

Jhneil Stewart 05/04/2024 Preparing draft exhibit (0.60); further draft 1.4 910.00 1274.00

Marcia 05/04/2024 Assist client to access documents 0.2 1300.00 260.00

Timekeeper Worked Narrative Billed Billed Billed

Marcia 08/04/2024 Attended to A Thorp draft email to the client 1.4 1300.00 1820.00 McFarlane updating on the continuation application and effect of the dissolution of K Legacy (0.20); reviewed and finalised updates to the draft

evidence(1.00), considered the civil rules for timeframe to file continuation application and provided update email to A Thorp (0.20) Andrew 08/04/2024 Review of evidence and LD-6 in support of 0.6 1300.00 780.00

Andrew 08/04/2024 Edit and review of application for 0.4 1300.00 520.00

Andrew 08/04/2024 Research re 0.8 1300.00 1040.00

Andrew 08/04/2024 Considering draft order and edits 0.2 1300.00 260.00

Marcia 09/04/2024 Reviewed client comments on the draft 0.4 1300.00 520.00 McFarlane continuation application documents and included the updates to the current drafts Luke Fraser 10/04/2024 Discussion with A Thorp; reviewing emails 0.3 590.00 177.00

Ben Hobden 10/04/2024 Internal emails; discussions with A Thorp; 0.4 1300.00 520.00

potential Cayman actions.

McFarlane 10/04/2024 Prepared advice on the steps for restoring 1.4 1300.00 1820.00

resigning- K Legacy (0.6) Collated exhibits for draft affidavit supporting continuation

Andrew 10/04/2024 Conf call with Paul Hastings, considering 0.6 1300.00 780.00 Thorp Kwok target cos and methods of disclosure Andrew 10/04/2024 Discussion with Cayman team re 0.4 1300.00 520.00

Ben Hobden 11/04/2024 Emails to and from Paul Hastings re 0.1 1300.00 130.00 discussing Cayman options. Luke Fraser 12/04/2024 Reviewing emails and organising meeting. 0.2 590.00 118.00 Ben Hobden 12/04/2024 Emails to and from Paul Hastings 0.1 1300.00 130.00 (arrangements for conference call). Marcia 12/04/2024 Follow up with client for sworn documents 2.8 1300.00 3640.00 McFarlane to be returned to file for continuation injunction, following client instructions, prepared cover affidavit and liaised with

prepared all documents for filing (1.00). Attended to client email on amendment to be

Adams 12/04/2024 Swearing affidavit and providing to M McFarlane for filing 0.2 1015.00 203.00 Luke Fraser 15/04/2024 Meeting (via telephone with Paul Hastings to discuss way forward) and next steps re

Ben Hobden 15/04/2024 Call with Paul Hastings; discussions with L Fraser; internal emails. 0.7 1300.00 910.00

McFarlane 15/04/2024 Discussed with A Thorp hearing prep task list (0.40), called Trident to obtain email

service (0.40); Filed affidavit of service

hearing bundle; filed hearing bundle (0.6).

speaking notes for continuation injunction

McFarlane 15/04/2024 K legacy Continuation injunction- considered case law for seeking costs on the continuation of the injunction order 0.2 1300.00 260.00

McNaught 15/04/2024 Catch-up with Andy 0.4 590.00 236.00

Thorp 15/04/2024 Considering disclosure applications and different options in support of US extant

Ben Hobden 16/04/2024 Internal emails regarding advice; discussions

Thorp 16/04/2024 Call in from Paul Hastings re new entity and

McNaught 16/04/2024 Research and note to Andy 3.8 590.00 2242.00

Timekeeper Worked Narrative Billed Billed Billed

Marcia 16/04/2024 Collated material to be taken to court for the 2.6 1300.00 3380.00 McFarlane hearing (0.20); called court to verify hearing

impact of the dissolution on the continuation of the relief, filed the 4th affidavit of Luc

evidence filed (0.20). Attended court and moved application for continuation of the injunction, updated the draft order to remove para 9b and emailed court with final form of order as approved (1.00). Updated the clients with outcome of hearing and provided sealed copy of evidence filed (0.20). Attended to

client and requested list of directors from Registry of Corporate Affairs (0.20). Marcia 17/04/2024 Attended to preparing workspace and 1 1300.00 1300.00 McFarlane uploaded material to be sent to Guo's General Counsel following indications from

Luke Fraser 18/04/2024 Preparing NPO note. 0.2 590.00 118.00 Luke Fraser 18/04/2024 Drafting NPO note. 2.4 590.00 1416.00 Ben Hobden 18/04/2024 Emails to and from Paul Hastings regarding 0.2 1300.00 260.00 progress of Cayman piece. Andrew 18/04/2024 Com with 0.4 1300.00 520.00

Andrew 18/04/2024 Review of complaint and position of Holy 0.4 1300.00 520.00 Thorp City and/ or shareholder to access third party

Andrew 18/04/2024 Mail to Paul Hastings team the accessibility 0.2 1300.00 260.00

Marcia 18/04/2024 Attended to sealed continuation injunction 1.2 1300.00 1560.00

Luke Fraser 19/04/2024 Further drafting of NPO note. 0.2 590.00 118.00 Ben Hobden 19/04/2024 Reviewing emails and attend call with Paul 0.3 1300.00 390.00 Hastings re potential Cayman targets. Andrew 19/04/2024 Call with Paul Hastings re 0.6 1300.00 780.00

Andrew 19/04/2024 Review of omnibus complaint and 1 1300-00 1300.00 Thorp specifically alter ego pleasing and nominee

Andrew 19/04/2024 Considering 3.2 1300.00 4160.00

review of case law in support (2.00).

Timekeeper Worked Narrative Billed Billed Billed

Luke Fraser 21/04/2024 Preparation of NPO note. 1.5 590.00 885.00 Ben Hobden 22/04/2024 Internal emails; reviewing and amending

Thorp 22/04/2024 Reviewing cayman disclosure provisions 0.4 1300.00 520.00

Thorp 22/04/2024 Considering advice re NP and disclosure

Thorp 22/04/2024 Finalising declaration 1.2 1300.00 1560.00

McNaught 22/04/2024 Email to team concerning disclosure 0.4 590.00 236.00 Jhneil Stewart 22/04/2024 Considering numerous emails and next steps 0.2 910.00 182.00 Ben Hobden 23/04/2024 Reviewing and sending email to Paul Hastings regarding advice. 0.1 1300.00 130.00

Thorp 23/04/2024 Review of amends from Paul Hastings and comments re case law on claw backs 0.4 1300.00 520.00 Jhneil Stewart 23/04/2024 Considering email query from client re

Thorp 24/04/2024 Considering case law re bankruptcy trustees and bare trust claims. 1 1300.00 1300.00 Jhneil Stewart 25/04/2024 Consider and attend to email re G Club docs 0.2 910.00 182.00

Cheung 25/04/2024 Research for cases that 6.6 320.00 2112.00 Natalie Lee 25/04/2024 Reviewing research re 1.2 1015.00 1218.00

McFarlane 25/04/2024 Updated with A Thorp on schedule of costs to be prepared to get costs of injunction and update on status of the registered agent of K

Thorp 25/04/2024 Mails in regarding abuse arguments and

Thorp 25/04/2024 Considering updates on 0.6 1300.00 780.00

Thorp 25/04/2024 Review of case law and draft of additional

Thorp 26/04/2024 Finalising 1 1300.00 1300.00

McFarlane 26/04/2024 Reviewed fresh company search results in relation to K Legacy Ltd 0.2 1300.00 260.00

Murdock 29/04/2024 Reviewing memo and drafting additions

Jhneil Stewart 29/04/2024 Email to A Thorp re G Club documents; email to client re G Club 0.2 910.00 182.00

McNaught 29/04/2024 Discussion with Andy re disclosure in support of foreign proceedings 1.4 590.00 826.00

Thorp 29/04/2024 Updated 1.4 1300.00 1820.00

Timekeeper Worked Narrative Billed Billed Billed

Ben Hobden 30/04/2024 Call with A Thorp; discussions with CDM; 0.9 1300.00 1170.00 internal emails; reviewing amended note; emails with Paul Hastings (all relating to updated advice). Andrew 30/04/2024 Further review of advice on recognition and 0.6 1300.00 780.00

Andrew 30/04/2024 Advice with respect to 0.4 1300.00 520.00

Andrew 30/04/2024 Call with Cayman counsel re 0.6 1300.00 780.00

Andrew 30/04/2024 Advice re fresh BVI proceedings against K 0.8 1300.00 1040.00 Thorp Legacy, jurisdictional issues, and appropriate steps. Andrew 30/04/2024 Advice regarding steps for alternative 0.6 1300.00 780.00 Thorp service on a defendant who evades service Andrew 30/04/2024 Further advice on 0.8 1300.00 1040.00

Isobel 30/04/2024 Liaising with A Thorp regarding 3.4 590.00 2006-00 McNaught amendments to memorandum and amending Jhneil Stewart 30/04/2024 Considering client's queries re ownership of 1.6 910.00 1456.00 K Legacy and our position (0.20); reviewing file and considering next steps (0.20);

re background information for memo (0.40);

Timekeeper Worked Narrative Billed Billed Billed

Tea Fonseca 23/01/2024 Service on Freedom Media Ventures 0.6 220 132

Tea Fonseca 24/01/2024 Service on Long Gate Limited - Notice of Motion 0.6 220 132

Tea Fonseca 24/01/2024 Service on Alfonso Global Limited - Notice of 0.6 220 132

Tea Fonseca 24/01/2024 Service on Alpha Ace Ventures Limited - Notice 0.6 220 132

Sahodra 25/01/2024 Service of Notice of Motion and Motion of Entry 0.6 275 । ୧୧ Faulkner done by Sahodra Faulkner on Joy Chance Holdings Limited c/o Vistra BVI Limited In re Ho Wan Kwok Case No. 22-50073 (JAM). Time: 1.35 Recipient: Helen Walters-Frank (Corporate

Timekeeper Worked Narrative Billed Billed Billed

Faulkner 25/01/2024 Service of Notice of Motion and Motion of Entry done by Sahodra Faulkner on Elite Well Global 0.6 275 165 Limited c/o Vistra BVI Limited In re Ho Wan

Recipient: Helen Walters-Frank (Corporate

Service of Notice of Motion and Motion of Entry 0.6 275 165 Faulkner done by Sahodra Faulkner on Shiny Mind Limited c/o Vistra BVI Limited In re Ho Wan

Recipient: Helen Walters-Frank (Corporate

Sahodra 25/01/2024 Service of Notice of Motion and Motion of Entry 0.6 275 165 Faulkner done by Sahodra Faulkner on Shiny Ace Limited c/o Vistra BVI Limited In re Ho Wan Kwok Case No. 22-50073 (JAM). Time: 1.35 Recipient: Sahodra 25/01/2024 Helen Walters-Frank (Corporate Manager) Service of Notice of Motion and Motion of Entry 0.6 275 165 Faulkner done by Sahodra Faulkner on Crystal Breeze Investments Limited c/o Vistra BVI Limited In re Ho Wan Kwok Case No. 22-50073 (JAM). Time: 1.35 Recipient: Helen Walters-Frank (Corporate

Sahodra 25/01/2024 Service of Notice of Motion and Motion of Entry 0.6 275 165 Faulkner done by Sahodra Faulkner on Creative Apex Investments Limited c/o Vistra BVI Limited In re Ho Wan Kwok Case No. 22-50073 ( JAM). Time: 1.35 Recipient: Helen Walters-Frank (Corporate

Service of Notice of Motion and Motion of Entry 0.6 275 165 Faulkner done by Sahodra Faulkner on Whitecroft Shore Limited c/o Vistra BVI Limited In re Ho Wan

Recipient: Helen Walters-Frank (Corporate

Sahodra 25/01/2024 Service of Notice of Motion and Motion of Entry 0.6 275 165 Faulkner done by Sahodra Faulkner on Shiny Times Holding Limited c/o Offshore Incorporations Limited In re Ho Wan Kwok Case No. 22-50073 (JAM). Time: 1.35 Recipient: Helen Walters-

Sahodra 25/01/2024 Service of Notice of Motion and Motion of Entry 0.6 275 165 Faulkner done by Sahodra Faulkner on Allied Capital Global Limtied c/o Vistra BVI Limited In re Ho Wan Kwok Case No. 22-50073 (JAM). Time: 1.35 Recipient: Helen Walters-Frank (Corporate

Shemar Trim 25/01/2024 Service of Notice of Motion and Motion of Entry 0.6 150 90

Holdings, Inc. c/o Ocorian Corporate Services (BVI) Limited. In re Ho Wan Kwok Case No. 22-50073 (JAM). Time: 2:34 Recipient: Sheroma

Shemar Trim 25/01/2024 Service of Notice of Motion and Motion of Entry 0.6 150 90

Management Company (BVI) Ltd. In re Ho Wan

Shemar Trim 25/01/2024 Service of Notice of Motion and Motion of Entry 0.6 150 90 on ACA Capital Group Limited c/o Conyers Trust Company (BVI). In re Ho Wan Kwok Case No. 22-50073 (JAM). Time: 12:41 Recipient: T.

Shemar Trim 25/01/2024 Service of Notice of Motion and Motion of Entry 0.6 150 90

International Limited c/o FH Corporate Services

(JAM). Time: 1:27 Recipient: Shanette Patrick (Corporate Administrator at FH Corporate) Shemar Trim 25/01/2024 Service of Notice of Motion and Motion of Entry 0.6 150 90 done by Shemar Trim on G Fashion Hold Co. B. Limited c/o FH Corporate Services Ltd. In re Ho Wan Kwok Case No. 22-50073 (JAM). Time: 1:27 Recipient: Shanette Patrick (Corporate

Shemar Trim 25/01/2024 Service of Notice of Motion and Motion of Entry 0.6 150 90 done by Shemar Trim on G Fashion Hold Co A Limited c/o FH Corporate Services Ltd. In re Ho Wan Kwok Case No. 22-50073 (JAM). Time: 1:27 Recipient: Shanette Patrick (Corporate

Shemar Trim 25/01/2024 Service of Notice of Motion and Motion of Entry 0.6 1 20 90 done by Shemar Trim on Gold Leaf Consulting

Limited. In re Ho Wan Kwok Case No. 22-50073

Shemar Trim 25/01/2024 Service of Notice of Motion and Motion of Entry 0.6 150 90 done by Shemar Trim on Himalaya International Clearing Ltd c/o Conyers Trust Company (BVI) Limited. In re Ho Wan Kwok Case No. 22-50073

Shemar Trim 25/01/2024 Service of Notice of Motion and Motion of Entry 0.6 150 90 done by Shemar Trim on Himalaya International Financial Group Ltd c/o Conyers Trust Company (BVI) Limited. In re Ho Wan Kwok Case No. 22- 50073 (JAM). Time: 12:41 Recipient: T. Barzey

Shemar Trim 25/01/2024 Service of Notice of Motion and Motion of Entry 0.6 120 90 done by Shemar Trim on G Club International Ltd. (BVI) c/o FH Corporate Services Ltd. . In re Ho Wan Kwok Case No. 22-50073 (JAM). Time: 1:27 Recipient: Shanette Patrick (Corporate

Timekeeper Worked Narrative Billed Billed Billed

Shemar Trim 25/01/2024 Service of Notice of Motion and Motion of Entry 0.6 150 90 done by Shemar Trim on Jumbo Century Limited c/o CCS Trustees Limited. . In re Ho Wan Kwok Case No. 22-50073 (JAM). Time: 1:12 Recipient: Jermaine Fahie (General Manger at CCS Trustees

Shemar Trim 25/01/2024 Service of Notice of Motion and Motion of Entry 0.6 150 90 done by Shemar Trim on G Fashion International Limited c/o FH Corporate Services Ltd. In re Ho Wan Kwok Case No. 22-50073 (JAM). Time: 1:27 Recipient: Shanette Patrick (Corporate

Shemar Trim 25/01/2024 Service of Notice of Motion and Motion of Entry 0.6 150 90 done by Shemar Trim on Long Gate Limited c/o FFP (BVI) Limited. . In re Ho Wan Kwok Case No. 22-50073 (JAM). Time: 1:40 Recipient: Liz

Shemar Trim 25/01/2024 Service of Notice of Motion and Motion of Entry 0.6 150 90 done by Shemar Trim on Alfonso Global Limited c/o FFP (BVI) Limited. . In re Ho Wan Kwok Case No. 22-50073 (JAM). Time: 1:40 Recipient:

Shemar Trim 25/01/2024 Service of Notice of Motion and Motion of Entry 0.6 150 90 done by Shemar Trim on Himalaya International Reserves Ltd c/o Conyers Trust Company (BVI)

50073 (JAM). Time: 12:41 Recipient: T. Barzey

Sahodra 25/01/2024 Service of Notice of Motion and Motion of Entry 0.6 275 165 Faulkner done by Sahodra Faulkner on Mega Ease Investments Limited c/o Vistra BVI Limited In re Ho Wan Kwok Case No. 22-50073 (JAM). Time: 1.35 Recipient: Helen Walters-Frank (Corporate

Sahodra 25/01/2024 Service of Notice of Motion and Motion of Entry 0.6 275 165 Faulkner done by Sahodra Faulkner on Noble Fame Global Limited c/o Vistra BVI Limited In re Ho Wan

Recipient: Helen Walters-Frank (Corporate

Sahodra 25/01/2024 Service of Notice of Motion and Motion of Entry 0.6 275 165 Faulkner done by Sahodra Faulkner on Globalist International Limited c/o Vistra BVI Limited In re Ho Wan Kwok Case No. 22-50073 ( JAM). Time: 1.35 Recipient: Helen Walters-Frank

Sahodra 25/01/2024 Service of Notice of Motion and Motion of Entry 0.6 275 165 Faulkner done by Sahodra Faulkner on Next Tycoon Iinvestments Limited c/o Vistra BVI Limited In re Ho Wan Kwok Case No. 22-50073 ( JAM). Time: 1.35 Recipient: Helen Walters-Frank

Timekeeper Worked Narrative Billed Billed Billed

Faulkner 25/01/2024 Service of Notice of Motion and Motion of Entry done by Sahodra Faulkner on Assets Sino Limited 0.6 275 165 c/o Vistra BVI Limited In re Ho Wan Kwok Case No. 22-50073 ( JAM). Time: 1.35 Recipient:

Sahodra 25/01/2024 Service of Notice of Motion and Motion of Entry 0.6 275 165 Faulkner done by Sahodra Faulkner on Head Win Group Limited c/o Vistra BVI Limited In re Ho Wan

Recipient: Helen Walters-Frank (Corporate

Sahodra 25/01/2024 Service of Notice of Motion and Motion of Entry 0.6 275 165 Faulkner done by Sahodra Faulkner on Guang Hong Limited c/o Vistra BVI Limited In re Ho Wan

Recipient: Helen Walters-Frank (Corporate

Sahodra 25/01/2024 Service of Notice of Motion and Motion of Entry 0.6 275 165 Faulkner done by Sahodra Faulkner on Auspicious Coast Limited c/o Vistra BVI Limited In re Ho Wan

Recipient: Helen Walters-Frank (Corporate

Faulkner 25/01/2024 Service of Notice of Motion and Motion of Entry done by Sahodra Faulkner on Major Lead 0.6 275 165 International Limited c/o Vistra BVI Limited In re Ho Wan Kwok Case No. 22-50073 ( JAM). Time: 1.35 Recipient: Helen Walters-Frank

Sahodra 25/01/2024 Service of Notice of Motion and Motion of Entry 0.6 275 165 Faulkner done by Sahodra Faulkner on Wealth Palm Limited c/o Offshore Incorporations Limited In re Ho Wan Kwok Case No. 22-50073 (JAM). Time: 1.35 Recipient: Helen Walters-Frank (Corporate

Sahodra 25/01/2024 Service of Notice of Motion and Motion of Entry 0.6 275 165 Faulkner done by Sahodra Faulkner on Anton Developments Limited c/o Commence Overseas Limited In re Ho Wan Kwok Case No. 22-50073 ( JAM). Time: 2.40 Recipient: Jonathan Bailey Shemar Trim 25/01/2024 Service of Notice of Motion and Motion of Entry 0.6 150 90 done by Shemar Trim on Himalaya International Payments Ltd c/o Conyers Trust Company (BVI)

50073 ( JAM). Time: 12:41 Recipient: T. Barzey

Shemar Trim 25/01/2024 Service of Notice of Motion and Motion of Entry 0.6 150 90 done by Shemar Trim on Dawn State Limited c/o Trident Trust Company (BVI) Limited. In re Ho Wan Kwok Case No. 22-50073 (JAM). Time: 12:45 Recipient: Keah Glasgow (Legal Counsel

Timekeeper Worked Narrative Billed Billed Billed

Shemar Trim 25/01/2024 Service of Notice of Motion and Motion of Entry done by Shemar Trim on World Century Limited c/o CCS Trustees Limited . In re Ho Wan Kwok

Shemar Trim 25/01/2024 Service of Notice of Motion and Motion of Entry done by Shemar Trim on Arcelio Limited c/o Intertrust Corporate Services (BVI) Limited. In re Ho Wan Kwok Case No. 22-50073 ( JAM). Time: 12:53 Recipient: Joanne Turnbull 0.6 150 90 Shemar Trim 25/01/2024 Service of Notice of Motion and Motion of Entry done by Shemar Trim on PA Business Advisory Limited c/o Commence Overseas Limited. . In re Ho Wan Kwok Case No. 22-50073 (JAM). Time: 2:20 Recipient: Jonathan Bailey (Authorized

Shemar Trim 25/01/2024 Service of Notice of Motion and Motion of Entry

Overseas Limited. . In re Ho Wan Kwok Case No. 22-50073 ( JAM). Time: 2:20 Recipient:

Shemar Trim 25/01/2024 Service of Notice of Motion and Motion of Entry

No. 22-50073 ( JAM). Time: 2:20 Recipient:

Shemar Trim 25/01/2024 Service of Notice of Motion and Motion of Entry done by Shemar Trim on Alpha Ace Ventures Limited c/o FFP (BVI) Limited. . In re Ho Wan

Recipient: Liz Jackson (Corp Administrator at

Shemar Trim 30/01/2024 Service of Notice of Motion and Motion of Entry

Trident Trust Company (BVI) Limited. . In re Ho Wan Kwok Case No. 22-50073 (JAM). Time: 2:55 Recipient: Kristian Johnson (Data Protection

Shemar Trim 30/01/2024 Service of Notice of Motion and Motion of Entry

International Limited c/o Harneys Corporate Services Limited. In re Ho Wan Kwok Case No. 22-50073 ( JAM). Time: 10:49 am Recipient:

Davis-Morris 30/01/2024 Attended to service on Well Origin Limited at

International Limited at Bolder Corporate

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Alnessa 30/01/2024 Attending to service at Vistra (BVI) Limited re 0.4 275 110 Davis-Morris Leading Shine Limited - Refused service redomiciled. Tea Fonseca 30/01/2024 Service on Splendour United Limited - Notice of 0.6 220 132 Motion and Motion for Entry (OIL - refused) -

Tea Fonseca 30/01/2024 Service on Hamilton Investment Managment 0.6 220 132 Limited - Notice of Motion and Motion (Bolder

08/01/2024 VIRG - Request for List of Directors x 12 Directors searches ಳಿ

10/01/2024 VIRG: Request for List of Directors-2040675- Directors searches S

15/01/2024 Notary Fees: Affidavit of Shemar Trim on 09 January 2024 Filing S

23/01/2024 Company Search: Company searches S

23/01/2024 Company Search: Company searches 250.00

23/01/2024 Company Search: Company searches 250.00

24/01/2024 Company Search: Company searches 250.00

24/01/2024 Company Search: Company searches 250.00

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26/01/2024 Company Search: Company searches 250.00

08/02/2024 Company Search: Company searches 250.00

08/02/2024 Company Search: Company searches 250.00

08/02/2024 High Court Search: High Court Search S

29/02/2024 VIRG - Request for List of Directors - Directors searches S

01/03/2024 Company Search- Company searches S

04/03/2024 Filing fee - Affidavit of Shemar Trim on 1 March 2024 Filing S

22/03/2024 Stamp fees for notification injunction application documents Filing 452.01

23/03/2024 Filing fee - Affidavit of Micah Hall on 22 March 2024 Filing S

25/03/2024 Additional fee for urgent application filed online Filing S

25/03/2024 Third affidavit of Luc Despins with Exhibit LD 3 Filing S

27/03/2024 Filing Fee - additional fee for ex parte application Filing S

02/04/2024 Renewed Company Search- Company searches 100.00

11/04/2024 VIRG - Request for List of Directors - Directors searches S

11/04/2024 VIRG - Request for List of Directors-Ace Directors searches S

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11/04/2024 Renewed Company Search- Company searches S

11/04/2024 Company Search- Company searches A

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11/04/2024 High Court Search- High Court Search S

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11/04/2024 VIRG - Request for List of Directors Directors searches S

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15/04/2024 RCPT#022428 - Affidavit & Exhibit GO-1 Filing S

15/04/2024 Filing fee - Hearing bundle Filing S

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17/04/2024 Filing fees for continuation injunction order Filing S

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29/04/2024 VIRG - Request for List of Directors Directors searches 75.00

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30/04/2024 Renewed Company Search- Company searches 100.00

30/04/2024 Renewed Company Search- Company searches \$ 100.00 30/04/2024 VIRG - Request for List of Directors - Directors searches S

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