Guo Wengui / Miles Guo — bankruptcy case · ECF #3283

UNITED STATES BANKRUPTCY COURT DISTRICT OF CONNECTICUT BRIDGEPORT DIVISION

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HO WAN KWOK, et al., : Case No. 22-50073 (JAM)

-------------------------------------------------------- x FIFTH INTERIM FEE APPLICATION COVER SHEET

Interim Application of: Paul Hastings LLP

Bankruptcy Petition Filed: Date of Entry of Retention Orders: August 2, 2022 [Docket No. 668] (effective as of July 8, 2022, as to Individual Debtor) and January 24, 2023 [Docket No. 1376] (effective as of October 11, 2022, as to Genever (BVI) and effective as of November 3, 2022, as to Genever (US))

Fees: \$4,141,700.76 Voluntary Fee Reductions: \$70,058.50 Expenses: \$262,633.83 Voluntary Expense Reductions: \$2,959.80

Fees Previously Requested: Retainer Request:

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 This Application does not include any fees and expenses related to the month of April 2024. Paul Hastings will include such fees and expenses in its next interim fee application.

3 In accordance with the Interim Compensation Procedures Order (as defined below), Paul Hastings received payments in the amount of \$2,623,390.21 in fees and \$229,850.31 in expenses with respect to its monthly fee statements for January and February 2024. Paul Hastings has not yet received payment of its fees and expenses with respect to its monthly fee statements for March 2024 (but 80% of such fees and all such expenses may be paid, at a future date, in accordance with the Interim Compensation Procedures Order). In addition, while this Application seeks allowance of all fees incurred during the Fee Period (other than with respect to the civil RICO action), Paul Hastings is not seeking, at this time, payment of the 20% holdback with respect to the January, February, and March 2024 fee statements.

Expenses Previously Requested: Expense Detail:

Requested Expenses: \$1,490,734.00 Retainer Received: N/A Awarded Expenses: \$1,487,215.30 Copies per page cost and total: \$0.08 b/w Paid Expenses: \$1,487,215.30 (per page)

Expenses Fees Awarded and Paid;

Expense Reimbursement Application for the Period from July 8, 2022 through October 31, 20224

Docket No.

10/31/22 \$0.00 \$63,631.75 Not applicable Awarded: \$63,631.75 Paid:

Special Fee Application (Sanctions) for Services Rendered in Securing Compliance with Court-Authorized Subpoenas5

Docket No.

3/10/23 \$83,370.26 Paid:

entered 4/21/2023 \$0.00 Awarded: \$83,370.26

First Interim Fee Application for the Period from July 8, 2022 through February 28, 2023

Docket No.

2/28/23 \$12,326,802.00 Paid: on 6/29/23 \$348,813.54 Awarded: \$11,776,802.00

Docket No. 1964, entered Awarded: \$348,813.54 Paid:

Second Interim Fee Application for the Period from March 1, 2023 through June 30, 2023

Docket No.

credit)6 Paid: on 9/12/23 \$213,914.83 Awarded: \$7,982,720.00

Docket No. 2190, entered Awarded: \$213,914.83 Paid:

Third Interim Fee Application for the Period from July 1, 2023 through August 31, 2023

Docket No.

8/31/23 \$3,725,984.25 Paid: on 11/30/23 \$146,137.57 Awarded: \$3,525,984.25

Docket No. 2408, entered Awarded: \$146,137.57 Paid:

4 The First Interim Fee Application excluded the expense reimbursements requested in the Expense Reimbursement Application.

- 5 The First Interim Fee Application and the Second Interim Fee Application included the amounts sought in the Special Fee Application (for the period through February 28, 2023 and the period from March 1 - 10, 2023, respectively). Paul Hastings included these amounts not to recover twice but to ensure payment in the event the HK Parties (defined below) do not comply with the Sanctions Order (defined below). To be clear, Paul Hastings seeks to recover payment of the requested \$83,370.26 only once. - 6 Due to an inadvertent oversight, the monthly fee statements for January and February 2023 (which were covered in the First Interim Fee Application) did not reflect the voluntary reduction in the hourly rate of the Trustee (from \$1,975 to \$1,860 per hour), resulting in an overstatement of Paul Hastings' fees by \$20,096.25 with respect to these two months. This amount was credited in the Second Interim Fee Application against fees requested therein. - 7 Pursuant to the order granting the Third Interim Fee Application, the Debtors' estates were authorized to pay Paul Hastings \$2,820,787.40. The amount previously paid to Paul Hastings pursuant the Interim Compensation Procedures Order for services rendered during the months of July and August 2023 was \$2,980,787.40. The overpayment of \$160,000.00 (i.e., 80% of \$200,000.00) was credited on Paul Hastings' September fee statement.

Date Period Requested Fees Requested Fees Awarded and Paid; Expenses Awarded and Amount

Submitted / Covered Expenses Court Order Paid; Court Order Owing Docket No. Fourth Interim Fee Application for the Period from September 1, 2023 through December 31, 2023 2/19/24 9/1/23 - \$6,911,034.50 \$718,236.31 Awarded: \$6,718,104.50 Awarded: \$714,717.61 \$1,343,620.90

Paid: Paid:

2935 Docket No. 3031, entered Docket No. 3031, entered

Total Awarded: \$30,003,610.75 Awarded: \$1,487,215.30 \$3,645,361.75 Paid: \$26,358,249.00 Paid:

8 Pursuant to the order granting the Fourth Interim Fee Application, the Debtors' estates were authorized to pay Paul Hastings \$5,374,483.60, of which \$160,000.00 was applied as a credit pursuant to the order granting the Third Interim Fee Application. Case 22-50073 Doc 3283 Filed 06/24/24 Entered 06/24/24 18:35:48 Page 5 of 562

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MONTHLY FEE REQUESTS FOR FIFTH INTERIM FEE PERIOD9

9 On August 18, 2023, the Court entered the Order Establishing Procedures for Interim Compensation and Reimbursement of Expenses for Retained Professionals [Docket No. 2094] (the "Interim Compensation Procedures Order"), pursuant to which estate professionals (including Paul Hastings) commenced filing monthly fee statements.

10 As detailed below, as a further accommodation to these estates and to minimize the review process by the Court and parties in interest, Paul Hastings is not seeking allowance or payment at this time for the fees of twelve (12) timekeepers who billed less than five (5) hours during the Fee Period in the aggregate amount of \$24,933.50; however, such fees were included in the January, February, and March 2024 fee statements. If this Application is granted, Paul Hastings will credit such amount on its subsequent monthly fee statement. HOURS AND RATES PER PROFESSIONAL AND PARAPROFESSIONAL DURING FEE PERIOD

Bassett, Nicholas Corporate, 2007 \$1,835.00 323.20 \$593,072.00 3 Bassett, Nicholas (travel; ½ rate) Corporate, 2007 \$967.50 13.30 \$12,577.75 3 Despins, Luc Restructuring, 1986 \$1,975.00 179.30 \$354,117.50 1 Despins, Luc (travel; ½ rate) Restructuring, 1986 \$987.50 2.40 \$2,370.00 1

Bongartz, Alex Restructuring, 2007 \$1,850.00 147.80 \$273,430.00 3 Luft, Avi Corporate, 2000 \$1,850.00 214.80 \$397,380.00 3 Luft, Avi (travel; ½ rate) Corporate, 2000 \$925.00 7.60 \$7,030.00 3 Traxler, Katherine Restructuring, 1990 \$1,120.00 10.70 \$11,984.00 3

Barron, Douglass Corporate, 2012 \$1,395.00 372.90 \$520,195.51 3 Catalano, Kristin Corporate, 2021 \$1,185.00 111.90 \$132,601.50 3 Chan, Alex Corporate, 2022 \$985.00 5.80 \$5,713.00 N/A Farmer, Will Corporate, 2018 \$1,390.00 88.90 \$123,571.00 3 Kim, Sarah Litigation, 2023 \$985.00 57.60 \$56,736.00 N/A Kosciewicz, Jon Litigation, 2021 \$1,185.00 268.90 \$318,646.50 3 Maza, Shlomo Corporate, 2012 \$1,395.00 185.60 \$258,912.00 3 Sadler, Tess Corporate, 2019 \$1,365.00 17.90 \$24,433.50 3 Song, Luyi Corporate, 2023 \$985.00 343.90 \$338,741.50 3 Song, Luyi (travel, bill at ½ rate) Corporate, 2023 \$492.50 9.20 \$4,531.00 3 Sutton, Ezra Corporate, 2021 \$1,270.00 338.00 \$429,260.00 3 Associate Total: 1,800.60 \$2,213,341.51

Kuo, Jocelyn Paralegal \$565.00 181.10 \$102,321.50 1 Mohamed, David Paralegal \$565.00 308.10 \$174,076.50 2 Paraprofessional Total: 489.20 \$276,398.00

UNITED STATES BANKRUPTCY COURT DISTRICT OF CONNECTICUT BRIDGEPORT DIVISION

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HO WAN KWOK, et al., : Case No. 22-50073 (JAM)

-------------------------------------------------------- x FIFTH INTERIM FEE APPLICATION OF PAUL HASTINGS LLP FOR COMPENSATION AND REIMBURSEMENT OF EXPENSES FOR PERIOD FROM JANUARY 1, 2024 THROUGH MARCH 31, 2024

Pursuant to sections 105(a), 328, 330, and 331 of title 11 of the United States Code (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 [Docket No. 2094] (the "Interim Compensation Procedures Order"), Paul Hastings LLP ("Paul Hastings"), as counsel to (a) 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"), (b) Genever Holdings Corporation ("Genever (BVI)"), and (c) Genever Holdings LLC ("Genever (US)" and, together with Genever (BVI), the "Genever Debtors"), hereby files this

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).

*Fifth Interim Fee Application of Paul Hastings LLP for Compensation and Reimbursement of Expenses for the Period from January 1, 2024 through March 31, 2024* (the "Application"). By this Application, Paul Hastings requests allowance and payment2 of the compensation for professional services performed by Paul Hastings attorneys (including the Trustee3 ) and reimbursement of its actual and necessary expenses incurred during the period from January 1, 2024 through and including March 31, 2024 (the "Fee Period").4 In support of this Application, Paul Hastings respectfully states as follows:

1. During the Fee Period, the Trustee and Paul Hastings continued the investigation into the financial affairs of the Individual Debtor and his corporate "shell game" to shield companies and assets under his ownership and/or control from his creditors. Given the vast network of companies affiliated with the Individual Debtor, and the fact that these companies or their assets are located around the world, the Trustee's investigation was, and continues to be, extensive.

2 In accordance with the Interim Compensation Procedures Order (as defined below), Paul Hastings received payments in the amount of \$2,623,390.21 in fees and \$229,850.31 in expenses with respect to its monthly fee statements for January and February 2024. Paul Hastings has not yet received payment of its fees and expenses with respect to its monthly fee statements for March 2024 (but 80% of such fees and all such expenses may be paid, at a future date, in accordance with the Interim Compensation Procedures Order). In addition, while this Application seeks allowance of all fees incurred during the Fee Period (other than with respect to the civil RICO action), Paul Hastings is not seeking, at this time, payment of the 20% holdback with respect to the January, February, and March 2024 fee statements.

3 In accordance with the Retention Order (as defined below), the Trustee is authorized to act as one of the attorneys for the Individual Debtor's estate, and, accordingly, this Application also seeks allowance of the Trustee's fees in such capacity. For the avoidance of doubt, in this Application, references to services provided by Paul Hastings attorneys shall include the Trustee. To be clear, time spent by the Trustee in his capacity as chapter 11 trustee, is not part of this Application, and compensation therefor will be sought by separate application.

4 This Application does not include any fees and expenses related to the month of April 2024. Paul Hastings will include such fees and expenses in its next interim fee application.

2. While the Trustee's investigation continues, the Trustee also recently commenced, with the assistance of Paul Hastings and the Trustee's other advisors, (a) more than 270 adversary proceedings seeking to avoid fraudulent transfers and postpetition transfers (the "Avoidance Actions"), (b) a civil action under the Racketeer Influenced and Corrupt Organization Act of 1970 ("RICO") against the Individual Debtor and his associates (the "Civil RICO Adversary Proceeding"),5 (c) an omnibus action seeking rulings that various entities are alter egos of the Individual Debtor and/or their assets are beneficially owned by the Individual Debtor, such that their assets are property of the estate (the "Omnibus Alter Ego Adversary Proceeding"), and (d) an action seeking to recover six separate vehicles which were fraudulently transferred. In connection with these adversary proceedings, the Trustee also sought and obtained various procedural relief, including (a) procedures governing the Avoidance Actions, including mediation of certain of such actions and (b) a temporary stay of the Civil RICO Adversary Proceeding and the Omnibus Alter Ego Adversary Proceeding pending the outcome of the Individual Debtor's criminal trial.

3. Notwithstanding the diligent efforts of the Trustee and his professionals, and the significant and important progress to date, the enormity of the Trustee's task and the constant obstruction he faced rendered it impossible for him to complete his investigation and assert all available causes of action prior to February 15, 2024 (i.e., the two-year anniversary of the filing of the Individual Debtor's chapter 11 case). For that reason, Paul Hastings prepared the Trustee's motion to extend the deadlines set forth in sections 108, 546(a), and 549 of the Bankruptcy Code for the Trustee to commence actions to avoid and recover fraudulent transfers

5 As further detailed below, Paul Hastings is not seeking, as part of this Application, allowance of its fees and expenses related to the Civil RICO Adversary Proceeding (which time was tracked under Matter ID 00025); however, Paul Hastings intends to do so in the future.

and/or assert other estate causes of action (which motion was filed on January 18, 2024). The

Court granted this motion by order dated February 14, 2024.

4. Moreover, as part of the Trustee's efforts to recover assets for the benefit of these

estates, the Trustee continued to make substantial progress in several pending adversary

proceedings. For example:

- HCHK Adversary Proceeding: During the Fee Period, Paul Hastings attorneys continued to prosecute the Trustee's adversary proceeding against HCHK Technologies, Inc. ("HCHK Technologies"), HCHK Property Management, Inc. ("HCHK Property"), Lexington Property and Staffing, Inc. ("Lexington Property," and, together with HCHK Technologies and HCHK Property, the "HCHK Entities"), Brian Hofmeister, in his capacity as assignee of the HCHK Entities (the "Assignee"), and certain other parties, seeking determinations that, among other things, (a) the HCHK Entities are alter egos of the Individual Debtor and (b) the Individual Debtor is the equitable owner of the HCHK Entities and/or their assets. - o Following this Court's denial of certain defendants' motion to set aside the entry of default as against them, Paul Hastings attorneys prepared the Trustee's motion for default judgment against the HCHK Entities and the other defendants. - o On June 14, 2024, the Court granted the Trustee's motion for default judgment, holding, among other things, that the HCHK Entities are the alter egos **of the Individual Debtor and directing that the property of the HCHK Entities be turned over to the estate. As a result of this ruling, among other things, over \$38 million of the HCHK Entities' funds (previously transferred into accounts controlled by the Trustee pursuant to the settlement with the Assignee) are now property of the estate.** - Mei Guo Adversary Proceeding: During the Fee Period, Paul Hastings continued, in coordination with the Trustee's local Connecticut counsel, Neubert Pepe & Monteith, P.C. ("NPM"), to prosecute the Trustee's adversary proceeding against Mei Guo. In this adversary proceeding, the Trustee seeks determinations that, among other things, (a) more than \$10 million in proceeds from the sale of the Individual Debtor's private Bombardier jet are property of the estate and (b) a series of BVI registered shell companies purportedly held by Mei Guo are property of the Individual Debtor's chapter 11 estate. - o On April 3, 2024, the Court granted, in part, the Trustee's motion for summary judgment, holding, among other things, that the Individual

**Debtor beneficially owned the Bombardier and, hence, beneficially owns the Bombardier proceeds and directing Mei Guo to turn over to the estate the Bombardier proceeds. Following the Court's decision, over \$10 million in Bombardier proceeds were turned over to the estate.**

- Lamp Capital Adversary Proceeding: During the Fee Period, Paul Hastings attorneys continued to prosecute the Trustee's complaint seeking determinations that Lamp Capital LLC ("Lamp Capital"), Hudson Diamond NY LLC ("Hudson Diamond NY"), Leading Shine NY Ltd. ("Leading Shine NY"), and Infinity Treasury Management Inc. ("Infinity Treasury") are the Individual Debtor's alter egos and that the Individual Debtor equitably owns the these defendants and their assets. - o During the Fee Period, the Court granted the Trustee's motion for entry of default judgment as against Lamp Capital and Infinity Treasury. In addition, the Court denied the motion to dismiss of certain defendants in this action. - Golden Spring Adversary Proceeding: During the Fee Period, Paul Hastings continued to prosecute the Trustee's adversary proceeding against Golden Spring (New York) Ltd. ("Golden Spring") and China Golden Spring Group (Hong Kong) Limited ("China Golden Spring" and, together with Golden Spring, the "Golden Spring Entities"). By order dated December 4, 2023, the Court entered a default judgment against the Golden Spring Entities, finding that, among other things, (a) Golden Spring is the alter ego of the Individual Debtor and (b) any and all of the assets of Golden Spring shall be turned over and/or surrendered to the Trustee. - o During the Fee Period, Paul Hastings attorneys prepared the Trustee's motion seeking to enforce the Golden Spring Default Judgment and compelling certain Taurus Fund LLC ("Taurus Fund") and certain related parties to turn over to the Trustee certain property belonging to Golden Spring that the Trustee discovered in certain storage units. The Court granted the motion to turn over the contents of certain storage units by order dated March 25, 2024. - o K Legacy: During the Fee Period, Paul Hastings assisted the Trustee—in coordination with the Trustee's BVI counsel—in seeking an injunction in the BVI to prohibit any sale or other transfer of (a) the Princes Gate apartment in London, United Kingdom and (b) the ownership of K Legacy Ltd. ("K Legacy"), the entity that holds title to the London apartment.6

6 As further detailed below, the Omnibus Alter Ego Adversary Proceeding seeks a ruling that K Legacy is the alter ego of the Individual Debtor.

- o On March 28, 2024, the High Court of Justice, Virgin Islands, Commercial Division (the "BVI Court"), entered the requested injunction, which injunction was subsequently continued until further order of the BVI Court. - Ace Decade Adversary Proceeding: During the Fee Period, Paul Hastings continued to handle the Trustee's adversary proceeding against Ace Decade Holdings Limited ("Ace Decade"), Yvette Wang, and Rui Hao seeking a declaration that the transfer of the Ace Decade share by Yvette Wang to Rui Hao is void, in light of this Court's prior ruling that the Trustee beneficially owns the Ace Decade shares. - o During the Fee Period, Paul Hastings attorneys prepared the Trustee's objection to defendant Wang's motion to dismiss, which this Court denied by order dated March 26, 2024. After the end of the Fee Period, the Trustee also obtained entries of default as against Ms. Wang and Ace Decade. - Greenwich Land Adversary Proceeding: During the Fee Period, Paul Hastings continued to prosecute the Trustee's adversary proceeding against Greenwich Land LLC ("Greenwich Land") and the Individual Debtor's alleged wife (i.e., Hing Chi Ngok), seeking determinations that, among other things, (a) Greenwich Land (which holds legal title to the Individual Debtor's residence in Greenwich, Connecticut) is an alter ego of the Debtor and (b) the Debtor is the equitable owner of Greenwich Land. - o During the Fee Period, Paul Hastings attorneys prepared for and handled oral argument (held on January 9, 2024) on the Trustee's summary judgment motion. A ruling on the summary judgment motion remains pending. - Mahwah Adversary Proceeding: During the Fee Period, Paul Hastings attorneys continued to prosecute the Trustee's adversary proceeding against Scott Barnett (the Individual Debtor's driver and/or bodyguard), Taurus Fund, LLC, and Taurus Management LLC—until such action was stayed at the request of the Trustee. In this adversary proceeding, the Trustee seeks determinations that, among other things, (a) the Individual Debtor is the equitable owner of a 50,000 square foot, castle-styled private residence with 12.5-acre grounds located at 675 Ramapo Valley Road, Mahwah, New Jersey 07430 (the "Mahwah Mansion"), (b) the Debtor is the equitable owner of Taurus Fund, LLC (the entity holding title to the Mahwah Mansion), and (c) that Taurus Fund is an alter ego of the Individual Debtor. - o During the Fee Period, Paul Hastings attorneys coordinated with NPM to prepare the Trustee's motion, with the consent of the defendants, to stay the Mahwah Adversary Proceeding pending completion of the Individual Case 22-50073 Doc 3283 Filed 06/24/24 Entered 06/24/24 18:35:48 Page 13 of 562

Debtor's criminal trial or further order of the Court. The Court granted the stay motion by order dated February 2, 2024.

5. Furthermore, during the Fee Period, the damage caused by the fire that occurred on March 15, 2023 at the 18th floor apartment at the Sherry Netherland (the "Sherry Netherland Apartment") continued to require the Trustee's and Paul Hastings' attention. Following the approval of the remediation motion, Paul Hastings attorneys worked with Genever (US)'s architect (Dave Acheson) to implement a remediation strategy for the source area of the March 15, 2023 fire, including the selection of the general contractor (following a competitive bidding process). In addition, during the Fee Period, Paul Hastings analyzed the soot testing report related to the remaining area of the Sherry Netherland Apartment. Ultimately, Genever (US) determined to hire contractors to undertake the cleaning of the remaining area as well. Genever (US) anticipates that the remediation and cleaning projects will be completed by mid-August 2024.

6. All the while, during the Fee Period, the Trustee and Paul Hastings provided a wide range of other chapter 11 related services, including, for example, handling ten hearings and status conferences, preparing and prosecuting numerous substantive motions, and preparing monthly operating reports.

7. As detailed in this Application, Paul Hastings has performed all of its services in an economic, effective, and efficient manner commensurate with the complexity and importance of the issues involved. The work performed by Paul Hastings was carefully assigned to appropriate professionals or paraprofessionals according to the experience and level of expertise required for each particular task. Whenever possible, Paul Hastings sought to minimize the costs of Paul Hastings' services by utilizing talented junior attorneys and paraprofessionals to handle the more routine aspects of the assignments. Moreover, as detailed below, Paul Hastings has Case 22-50073 Doc 3283 Filed 06/24/24 Entered 06/24/24 18:35:48 Page 14 of 562

delegated numerous work streams (including the recent avoidance actions process) to local Connecticut counsel (which has a lower rate structure than Paul Hastings).

8. To further minimize the costs of intra-Paul Hastings communications and education about these chapter 11 cases, the Trustee utilized a small group of Paul Hastings attorneys for the majority of the work in these chapter 11 cases. Also, as a general matter, in addition to the Trustee, no more than two Paul Hastings attorneys attended the various hearings held during the Fee Period (and in some instances, the Trustee handled hearings without attendance of any Paul Hastings attorneys), thereby minimizing not only the time billed on these hearings/sessions but also the cost of travel. Furthermore, to the extent appropriate, the Trustee and Paul Hastings sought to work closely with counsel to Pacific Alliance Asia Opportunity Fund L.P. ("PAX"), including to take advantage of the knowledge of the Individual Debtor's assets and financial affairs that PAX acquired during the prepetition litigation against the Individual Debtor in New York state court. Moreover, as noted on the record at the August 2, 2022 hearing on Paul Hastings' retention application, the Trustee has agreed not to seek a percentage recovery under section 326 of the Bankruptcy Code, and, instead, agreed that he would only be compensated (at his standard hourly rate) for his time.

9. Finally, as an accommodation to these estates and to minimize the review process by the Court and parties in interest, Paul Hastings is not seeking allowance or payment at this time for the fees of twelve (12) timekeepers who billed less than five (5) hours during the Fee Period in the aggregate amount of \$24,933.50. The time billed by these timekeepers was reasonable, and Paul Hastings reserves the right to seek allowance of these fees based on the facts and circumstances of these cases, including, without limitation, if objections are interposed to the allowance of Paul Hastings' fees and expenses. Case 22-50073 Doc 3283 Filed 06/24/24 Entered 06/24/24 18:35:48 Page 15 of 562

10. In sum, Paul Hastings respectfully submits that the services for which it seeks compensation in this Application were necessary for and beneficial to these chapter 11 estates and their stakeholders. Accordingly, in light of the nature and complexity of these chapter 11 cases, Paul Hastings' charges for professional services performed and expenses incurred are reasonable under applicable standards. For all these reasons, Paul Hastings respectfully requests that the Court grant the Application and allow interim compensation for professional services performed and reimbursement for expenses as requested. JURISDICTION, VENUE, BASES FOR RELIEF, AND COMPLIANCE

11. 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 (as amended). 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.

12. The legal predicates for the relief requested herein are sections 328, 330, and 331 of the Bankruptcy Code, Bankruptcy Rule 2016, and Local Bankruptcy Rule 2016-1.

13. Paul Hastings believes that this Application, together with the attachments hereto, substantially complies with the Bankruptcy Rules, Local Rule 2016-1, the Interim Compensation Procedures Order, 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").7 Paul Hastings respectfully requests a waiver of any of the foregoing requirements not met by this Application.

14. Attached and incorporated herein by reference are the following Exhibits:

7 Paul Hastings 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 disclosures regarding "customary and comparable compensation." - Exhibit B1 contains a summary of Paul Hastings' timekeepers included in this Application. - Exhibit B2 contains a summary of Paul Hastings' timekeepers who billed less than five (5) hours during the Fee Period and for whom Paul Hastings is not seeking allowance or payment at this time. - Exhibit C contains a summary of the compensation requested by project category. - Exhibit D contains a summary of the compensation requested by Matter ID. - Exhibit E contains the expense reimbursements requested by category. - Exhibit F contains the monthly statements of Paul Hastings detailing the services performed and itemizing the expenses incurred during the Fee Period. - Exhibit G contains the Proposed Order.

15. On February 15, 2022 (the "Petition Date"), the Individual Debtor filed with the Court a voluntary petition for relief under chapter 11 of the Bankruptcy Code.

16. On March 21, 2022, the United States Trustee appointed an Official Committee of

Unsecured Creditors ("Committee") in the Individual Debtor's chapter 11 case. No examiner has been appointed in the Individual Debtor's chapter 11 case.

17. On June 15, 2022, the Court entered a memorandum of decision and order

[Docket No. 465] (the "Trustee Order") directing the United States Trustee to appoint a chapter 11 trustee in the chapter 11 case of Ho Wan Kwok. 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 chapter 11 case of Ho Wan Kwok. Case 22-50073 Doc 3283 Filed 06/24/24 Entered 06/24/24 18:35:48 Page 17 of 562

18. The Court authorized Paul Hastings' retention as attorneys for the Trustee pursuant to the *Order Authorizing and Approving the Retention and Employment of Paul Hastings LLP as Counsel to Chapter 11 Trustee, effective as of July 8, 2022* [Docket No. 668] (together with the retention order with respect to the Genever Debtors [Docket No. 1376], the "Retention Order"), entered on August 2, 2022. The Retention Order authorizes Paul Hastings 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 Bankruptcy Rules, and such orders as the Court may direct. Moreover, at the August 1, 2022 hearing on the Paul Hastings' retention application, the Court made clear that it approved Paul Hastings' New York rate structure.8 In addition, as noted on the record at that hearing, the Trustee has agreed not to seek a percentage recovery under section 326 of the Bankruptcy Code, and, instead, agreed that he would only be compensated (at his standard hourly rate) for his time.

19. In light of the Trustee's ongoing investigation into the Individual Debtor's assets and his financial affairs, the Trustee is unable at this time to predict when he will be in a position to file a plan and disclosure statement. All quarterly fees have been paid to the United States Trustee, and all monthly operating reports have been filed through May 2024 (for the Individual Debtor's chapter 11 case), April 2024 (for Genever (BVI)'s chapter 11 case), and April 2024 (for Genever (US)'s chapter 11 case).

20. At this time, the amount of cash in the Trustee's account is approximately \$76 million. The Trustee is not aware of any material administrative expense claims other than claims for professional fees and expenses.

8 See Aug. 1, 2022 H'rg Tr. at 113:15-19 ("MR. DESPINS: But I want to be clear is that that's not going to be a back door way to bring local rates, or anything like that -- THE COURT: No, I'm not doing that. I agree with that.").

21. On October 11, 2022, Genever (BVI) -- an entity wholly owned by the Individual Debtor -- filed a voluntary petition for relief under chapter 11 of the Bankruptcy Code with this Court.

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

23. 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 [Docket No. 970].

24. On January 24, 2023, the Court granted Genever (BVI)'s application to retain Paul Hastings as counsel to Genever (BVI) in its chapter 11 case, effective as of its petition date, i.e., October 11, 2022 [Docket No. 1376].

25. On October 12, 2020, Genever Holdings LLC -- an entity wholly owned by Genever (BVI) -- filed a voluntary petition for relief under chapter 11 of title 11 of the United States Code in the United States Bankruptcy Court for the Southern District of New York (the "SDNY Bankruptcy Court"), thereby commencing case number 20-12411 (JLG) (the "SDNY Bankruptcy Case").

26. On November 3, 2022, the SDNY Bankruptcy Court entered an order [Docket No. 225 in Case No. 22-50592] transferring the venue of the SDNY Bankruptcy Case to this Court, which assigned it Case Number 22-50592.

27. On November 21, 2022, the Court entered an order granting joint administration of the Genever (US) Debtor's chapter 11 case with the jointly administered cases of the Individual Debtor and the Genever (BVI) Debtor's chapter 11 case [Docket No. 1141]. Case 22-50073 Doc 3283 Filed 06/24/24 Entered 06/24/24 18:35:48 Page 19 of 562

28. On January 24, 2023, the Court granted Genever (US)'s application to retain Paul Hastings as counsel to Genever (US) in its chapter 11 case, effective as of the order transferring venue of the SDNY Bankruptcy Case to this Court, i.e., November 3, 2022 [Docket No. 1376].

29. By this Application, the Trustee and Paul Hastings request allowance of fees (in the amount of \$4,141,700.76) and expenses incurred (in the amount of \$262,633.83) for services rendered by, for, and on behalf of the Trustee during the Fee Period.9 The Trustee has approved the amounts requested by Paul Hastings herein.

30. While this Application seeks allowance of all fees incurred during the Fee Period, Paul Hastings does not seek, at this time, payment of the 20% holdback withheld by the Debtors' estates with respect to Fee Period. Moreover, as noted, Paul Hastings has not yet been paid with respect to its monthly fee statement for the month of March 2024. For the avoidance of doubt, 80% of the fees for the months of January, February, and March 2024 and all expenses for such months may be paid in accordance with the Interim Compensation Procedures Order.

31. To date, the Trustee and Paul Hastings have submitted the following fee/expenserelated applications in these chapter 11 cases:

(a) On March 1, 2023, Paul Hastings submitted the *First Interim Application of Chapter 11 Trustee and his Counsel, Paul Hastings LLP, for Reimbursement of Expenses for the Period from July 8, 2022 through October 31, 2022* [Docket No. 1495] (the "Expense Reimbursement Application"), whereby the Trustee and Paul Hastings requested reimbursement of the actual and necessary expenses incurred by the Trustee and Paul Hastings during the period from July 8, 2022 through

9 As an accommodation to these estates and to minimize the review process by the Court and parties in interest, Paul Hastings is not seeking allowance or payment at this time for the fees of twelve (12) timekeepers who billed less than five (5) hours during the Fee Period in the aggregate amount of \$24,933.50. The time billed by these timekeepers was reasonable, and Paul Hastings reserves the right to seek allowance of these fees based on the facts and circumstances of these cases, including, without limitation, if objections are interposed to the allowance of Paul Hastings' fees and expenses.

October 31, 2022 in the amount of \$63,631.75. On May 3, 2023, the Court entered an order granting the Expense Reimbursement Application [Docket No. 1747] (the "Expense Reimbursement Order"). The Individual Debtor's estate paid the foregoing amount on May 8, 2023.

- (b) On April 10, 2023, Paul Hastings submitted the *Special Fee Application of Chapter 11 Trustee and his Counsel, Paul Hastings LLP, for Services Rendered in Securing Compliance with Court-Authorized Subpoenas* [Docket No. 1648] (the "Special Fee Application"). In the Special Fee Application, Paul Hastings requested allowance and payment of fees in the amount of \$83,370.26 in accordance with the HK Parties Contempt Order.10 On April 21, 2023, the Court approved the Special Fee Application and ordered the HK Parties to remit payment of \$83,370.26 to the chapter 11 estate of the Individual Debtor [Docket No. 1693] (the "HK Parties Sanctions Order"). The United States District Court for the District of Connecticut has affirmed the HK Parties Sanctions Order. As of the filing of this Application, the HK Parties have not remitted payment. - (c) On May 30, 2023, Paul Hastings submitted the *Interim Fee Application of Paul Hastings LLP for Compensation and Reimbursement of Expenses for the Period from July 8, 2022 through February 28, 2023* [Docket No. 1831] (the "First Interim Fee Application") seeking \$12,326,802.00 in fees and \$348,813.54 for reimbursement of expenses. The First Interim Fee Application excluded the expense reimbursements approved in the Expense Reimbursement Order. The First Interim Fee Application included the amount requested in the Special Fee Application (for the period through February 28, 2023). However, to the extent the Trustee is able to recover the fees under the HK Parties Sanctions Order from the HK Parties, Paul Hastings would not seek payment of such fees from these estates. Pursuant to agreement with the U.S. Trustee, Paul Hastings reduced its fee request by \$550,000. On June 29, 2023, the Court approved the First Interim Fee Application [Docket No. 1964] with such reduction. Paul Hastings has received payment of \$11,776,802.00 in fees and \$348,813.54 in expenses in connection with the First Interim Fee Application. - (d) On August 4, 2023, Paul Hastings submitted the *Second Interim Fee Application of Paul Hastings LLP for Compensation and Reimbursement of Expenses for the Period from March 1, 2023 through June 30, 2023* [Docket No. 2051] (the "Second Interim Fee Application") seeking \$8,037,720.00 in fees and \$213,914.83 for reimbursement of expenses. The Second Interim Fee Application included the amount requested in the Special Fee Application (for the period from March 1, 2023 through March 10, 2023). However, to the extent the Trustee is

10 On March 10, 2023, the Court entered the *Order Holding HK Parties in Contempt of Court and Sanctioning HK Parties, Attorney Vartan and Chiesa Shahinian & Giantomasi PC* [Docket No. 1537] (the "HK Parties Contempt Order"), pursuant to which the Court ordered Ms. Mei Guo, HK International Funds Investments (USA) Limited ("HK USA"), attorney Lee Vartan, and Chiesa Shahinian & Giantomasi PC (collectively, the "HK Parties"), jointly and severally, to compensate the Trustee and his counsel, Paul Hastings, for reasonable attorneys' fees and expenses associated with the Trustee's efforts to secure compliance with certain Courtauthorized subpoenas.

able to recover the fees under the HK Parties Sanctions Order from the HK Parties, Paul Hastings will not seek payment of such fees from these estates. Pursuant to agreement with the U.S. Trustee, Paul Hastings reduced its fee request by \$55,000.00. On September 12, 2023, the Court approved the Second Interim Fee Application [Docket No. 2190] with such reduction. Paul Hastings has received payment of \$6,386,176.00 in fees (or 80% of the allowed fees in the amount of \$7,982,720) and \$213,914.83 in expenses in connection with the Second Interim Fee Application.

- (e) On October 16, 2023, Paul Hastings submitted the *Third Interim Fee Application of Paul Hastings LLP for Compensation and Reimbursement of Expenses for the Period from July 1, 2023 through August 31, 2023* [Docket No. 2256] (the "Third Interim Fee Application") seeking \$3,725,984.25 in fees and \$146,137.57 for reimbursement of expenses. Pursuant to agreement with the U.S. Trustee, Paul Hastings reduced its fee request by \$200,000.00. On November 30, 2023, the Court entered an order [Docket No. 2408] approving the Third Interim Fee Application with such reduction. Paul Hastings has received payment of \$2,820,787.4011 in fees (or 80% of the allowed fees in the amount of \$3,525,984.25) and \$146,137.57 in expenses in connection with the Third Interim Fee Application. - (f) On February 19, 2024, Paul Hastings submitted the Fourth Interim Fee Application of Paul Hastings LLP for Compensation and Reimbursement of Expenses for the Period from September 1, 2023 through December 31, 2023 [Docket No. 2935] (the "Fourth Interim Fee Application") seeking \$6,911,034.50 in fees and \$718,236.31 for reimbursement of expenses. Pursuant to agreement with the U.S. Trustee, Paul Hastings reduced its fee request by \$192,930.00 and its expense reimbursement request by \$3,518.70. On March 21, 2024, the Court entered an order [Docket No. 3031] approving the Fourth Interim Fee Application with such reductions. Paul Hastings has received payment of \$5,374.483.60 in fees (or 80% of the allowed fees in the amount of \$6,718,104.50) and \$714,717.61 in expenses in connection with the Fourth Interim Fee Application. - (g) Pursuant to the Interim Compensation Procedures Order, Paul Hastings submitted monthly fee statements for services rendered during the Fee Period (other than with respect to the Civil RICO Adversary Proceeding). See Docket Nos. 3196, 3198, and 3221. In particular, Paul Hastings requested: - i. for January 2024 services, fees in the amount of \$1,385,437.41 (i.e., 80% of \$1,731,796.76 in fees incurred) and \$58,724.49 in expenses; - ii. for February 2024 services, fees in the amount of \$1,238,411.51 (i.e., 80% of \$1,547,441.00 in fees incurred) and \$171,125.82 in expenses; and

11 Pursuant to the Interim Compensation Procedures Order, Paul Hastings had previously received \$2,980,787.40 in payments for fees incurred in July and August 2023. Accordingly, as part of its September 2023 monthly fee statement, Paul Hastings included a credit of \$160,000.00 (i.e., 80% of the agreed-upon \$200,000.00 reduction).

iii. for March 2024 services, fees in the amount of \$709,917.20 (i.e., 80% of \$887,396.50 in fees incurred) and \$32,783.52 in expenses.

Paul Hastings has received payment in the amount of the amount of \$2,623,390.21 in fees and \$229,850.31 in expenses with respect to its monthly fee statements for January and February 2024. As noted, Paul Hastings has not yet received payment with respect to its March 2024 services.

32. Except as set forth above, neither the Trustee nor Paul Hastings has received any payment or promise of payment from any source for services rendered during the Fee Period. There is no agreement or understanding between the Trustee and/or Paul Hastings and any other person other than the attorneys, employees, and staff of Paul Hastings, for the sharing of compensation to be received for services rendered in these chapter 11 cases.

33. Paul Hastings' professional services during the Fee Period required an aggregate expenditure of 3,188.90 recorded hours by attorneys and paraprofessionals, broken down as follows: partners (518.20 hours), of counsel (380.90 hours), associates (1,800.60 hours), and paraprofessionals (489.20 hours). The timekeepers who rendered such services are identified in the Cover Sheet hereto, along with the number of hours and the total compensation sought for each individual.

34. Paul Hastings maintains computerized records, in the form of monthly statements, of the time spent by all Paul Hastings' attorneys and paraprofessionals in connection with its representation of the Trustee and the Genever Debtors. With the exception of the monthly statements submitted with the Special Fee Application,12 the monthly statements are in the same form regularly used by Paul Hastings to bill its clients for services rendered and include the date that the services were rendered, a detailed, contemporaneous narrative description of the services

12 As noted in the Special Fee Application, Paul Hastings' monthly statements for fees incurred in securing compliance with the Court-authorized subpoenas are limited to those services and, thus, vary in form from that regularly used by Paul Hastings to bill its clients for services rendered. Case 22-50073 Doc 3283 Filed 06/24/24 Entered 06/24/24 18:35:48 Page 23 of 562

provided, the amount of time spent for each service, and the designation of the professional who performed the service. Attached hereto as Exhibit F are true and correct copies of the monthly statements of Paul Hastings related to the fees requested herein.

35. As a courtesy to these estates and based on circumstances unique to these chapter 11 cases, Paul Hastings agreed on a reduced hourly rate for Luc Despins (from his standard hourly rate of \$2,225.00 to the reduced hourly rate of \$1,975.00) for the Fee Period.13 Other than this discount, the rates Paul Hastings charges for the services rendered by its professionals and paraprofessionals in these chapter 11 cases are comparable to the rates Paul Hastings charges for professional and paraprofessional services rendered in comparable nonbankruptcy related matters. In addition, when Paul Hastings' restructuring professionals and paraprofessionals work on non-bankruptcy matters, the firm generally charges their standard rate. Such fees are reasonable based on the customary compensation charged by comparably skilled practitioners in comparable non-bankruptcy cases in a competitive national legal market.

36. Paul Hastings respectfully submits that the reasonable value of the services rendered by Paul Hastings (including the Trustee) during the Fee Period is \$4,141,700.76.

37. During the Fee Period, Paul Hastings assisted and advised the Trustee and the Genever Debtors on a regular basis regarding legal matters relating to these chapter 11 cases and the pursuit and recovery of estate assets for the benefit of the chapter 11 estates and their creditors. In addition, Paul Hastings prepared various motions, applications, proposed orders, and other pleadings submitted to the Court for consideration, and performed the necessary

13 This translates into a voluntary waiver of \$24,933.50

professional services that are described below and in the fee statements attached hereto and incorporated herein by reference.14

38. For ease of reference and transparency purposes, and at the request of the U.S. Trustee, Paul Hastings created the following separate Matter IDs for services in these chapter 11 cases, including separate Matter IDs for the major adversary proceedings pending in these chapter 11 cases.

00001 General Chapter 11 Trustee Representation 00002 Asset Recovery Investigation and Litigation

14 The description of services in this Application is limited to those matters in which Paul Hastings provided five (5) or more hours of service during the Fee Period.

15 Not included as part of this Application.

16 Not included as part of this Application.

17 Not included as part of this Application.

39. Additionally, the Trustee and the Genever Debtors retained NPM as their local and conflicts counsel in order to provide services to the Trustee and the Genever Debtor's estates in a cost-effective manner. In particular, as detailed in the NPM retention application and related declarations, Paul Hastings and NPM have coordinated, and will continue to coordinate, each firm's respective responsibilities in connection with the representation of the Trustee and the Genever Debtors. Among other things, during the Fee Period, the following matters were delegated to NPM:

- Assisting with filings and service of pleadings in the main chapter 11 case and related adversary proceedings; - Preparing supplemental motions for discovery under Bankruptcy Rule 2004 (including for discovery targets for which Paul Hastings is conflicted), conducting meet and confers with discovery targets, and reviewing documents produced in response to Rule 2004 subpoenas; - Assisting the Trustee on matters on which Paul Hastings is conflicted; - Preparing certain procedural motions, including motion to seal, motions to expedite, and motions to adjourn; - Advising the Trustee and the Genever Debtors on matters related to local Connecticut rules; - Preparing monthly operating reports for the Genever Debtors; and - Performing a variety of case administration functions, including interacting with the Court and the clerks' office as needed, preparing certificates of service, coordinating logistics for hearings, and handling other case administration functions as they arise from time to time. - 40. In addition, Paul Hastings has also delegated to NPM a number of important

matters -- including entire adversary proceedings, such as the Mei Guo Adversary Proceeding (as Case 22-50073 Doc 3283 Filed 06/24/24 Entered 06/24/24 18:35:48 Page 26 of 562

defined below) -- related to the Trustee's investigation and efforts to recover assets for the benefit of these estates.

41. Finally, Paul Hastings notes that, through this Application, it is not seeking allowance of fees or reimbursement of expenses with respect to the Civil RICO Adversary Proceeding. As the Court is aware, on February 15, 2024, the Trustee filed a complaint alleging that, since at least 2015, the Individual Debtor and various of his associates have operated a racketeering enterprise through an extensive worldwide network of shell companies with the goal of enriching the Individual Debtor, his family members, and his close associates, while concealing the true nature and extent of the Individual Debtor's wealth from his creditors and preventing them from being repaid. Paul Hastings intends to seek payment and allowance of its fees and expenses with respect to the Civil RICO Adversary Proceeding in the future. I. General Chapter 11 Trustee Representation (Matter ID 00001)

i. Case Administration (Task Code B110) Fees: \$80,187.50 Total Hours: 87.10

42. During the Fee Period, Paul Hastings attorneys handled numerous case administrative matters in connection with these chapter 11 cases, including (a) developing shortterm and long-term strategies for recovering assets for the benefit of these estates, (b) maintaining a case calendar and task lists of open matters and work streams, (c) handling calls and correspondence with the U.S. Trustee and PAX regarding the background to, and the administration of, these chapter 11 cases, and (d) holding internal team meetings and calls to coordinate work streams.

- ii. Pleadings Review (Task Code B113) Fees: \$73,213.50 Total Hours: 128.40 - 43. During the Fee Period, Paul Hastings attorneys reviewed and monitored the

docket of these chapter 11 cases, the related adversary proceedings, and pending state court

litigation, as well as reviewed pleadings filed therein, as necessary.

- iii. Court Hearings (Task Code B155) Fees: \$15,188.00 Total Hours: 12.60 - 44. During the Fee Period, Paul Hastings attorneys prepared for and attended

numerous hearings and status conferences. The following hearings were recorded under Matter

ID 00001, among others:

- the January 10, 2024 status conference; - the January 23, 2024 hearing on, among other things, the fee application of Pallas Partners LLP ("Pallas"); and - the February 5, 2024 hearing on, among other things, on the Trustee's motion seeking approval of procedures with respect to avoidance action litigation.

45. In addition, as detailed below, attendance at several other hearings during the Fee Period were recorded under the applicable Matter ID. That said, general hearing preparation (including agendas) for the various hearings scheduled in January, February, and March 2024 was also recorded under Matter ID 00001.

iv. Fee / Employment Applications for Paul Hastings (Task Code B160) Fees: \$82,809.00 Total Hours: 59.60

46. During the Fee Period, in connection with Paul Hastings' retention, Paul Hastings attorneys prepared and submitted a supplemental declaration with respect to the Trustee's and Paul Hastings' disinterestedness [Docket No. 3039] and continued to research possible connections between the Trustee and Paul Hastings, on the one hand, and parties in interest in these chapter 11 cases, on the other hand. In addition, Paul Hastings attorneys prepared (a) the Case 22-50073 Doc 3283 Filed 06/24/24 Entered 06/24/24 18:35:48 Page 28 of 562

Fourth Interim Fee Application [Docket No. 2935] (which the Court granted on March 21, 2024 [Docket No. 3031]), and (b) Paul Hastings' monthly fee statements for services rendered in October 2023, November 2023, and December 2023, and January 2024. Paul Hastings also corresponded and engaged in discussions with the U.S. Trustee to address questions regarding the above fee and expense reimbursement requests. Among other things, Paul Hastings consensually resolved the U.S. Trustee's informal comments to the Fourth Interim Fee Application. v. Fee / Employment Applications for Other Professionals (Task Code B165) Fees: \$72,170.50 Total Hours: 47.30

47. During the Fee Period, Paul Hastings attorneys prepared the Trustee's application to retain Prager Dreifuss AG ("Prager") as Swiss law counsel to the Trustee, which application was filed on February 16, 2024 [Docket No. 2931] (and granted on March 21, 2024 [Docket No. 3034]), as well as addressed comments from the U.S. Trustee with respect to that application.18

48. In addition, during the Fee Period, Paul Hastings attorneys handled various other fee-related issues, including (a) assisting O'Sullivan McCormack Jensen & Bliss PC ("OMJB"), Kroll, Inc. ("Kroll"), and Harney Westwood & Riegels LP ("Harneys") with preparing their interim fee applications [Docket Nos. 2928, 2929, and 2933], (b) reviewing the interim fee applications of NPM and Epiq Corporate Restructuring, LLC ("Epiq"), (c) assisting Pallas with responding to the U.S. Trustee's comments on its fee application [Docket No. 2475], (d) assisting Pallas with preparing its supplemental declaration of disinterestedness [Docket No. 2529], (e) assisting Paul Wright (i.e., the Trustee's UK barrister) with preparing his fee

18 The application was filed with the Swiss court on May 21, 2024. Case 22-50073 Doc 3283 Filed 06/24/24 Entered 06/24/24 18:35:48 Page 29 of 562

application [Docket No. 3188], and (f) assisting Kroll, LLC ("Kroll") with preparing its monthly fee statements [Docket Nos. 2522, 2940, and 3029].

- vi. Non-Working Travel (Task Code B195) [billed at ½ rate] Fees: \$7,256.25 Total Hours: 7.50 - 49. During the Fee Period, Paul Hastings attorneys traveled to and from Washington,

D.C., to Bridgeport, Connecticut, for the January 10, 2024 and January 23, 2024 hearings.

- vii. Business Operations (Task Code B210) Fees: \$16,385.00 Total Hours: 12.30 - 50. During the Fee Period, Paul Hastings attorneys assisted the Trustee with various

matters related to the operation of these chapter 11 estates, including handling wire transfers.

viii. Financial Reports (Monthly Operating Reports) (Task Code B211) Fees: \$14,899.00 Total Hours: 11.50

51. During the Fee Period, Paul Hastings attorneys prepared the monthly operating reports in the Individual Debtor's chapter 11 case. In the interest of minimizing costs, the monthly operating reports for the Genever Debtors were prepared by NPM, and any time spent by Paul Hastings attorneys reviewing and commenting such reports was recorded under Matter ID 00010 (for Genever (US)) and 00011 (for Genever (BVI)). II. Asset Recovery Investigation and Litigation (Matter ID 00002)

i. Asset Analysis and Recovery (Task Code B120) Fees: \$10,475.00 Total Hours: 5.50

52. During the Fee Period, Paul Hastings attorneys, with the assistance of Swiss

counsel (i.e., Prager), analyzed various issues related to Ace Decade, including Swiss proceedings related to Ace Decade. In addition, the Trustee coordinated with his UK counsel, (i.e., Pallas), to prepare a motion in the English court to temporarily stay litigation previously commenced by the Individual Debtor, Ace Decade, and Dawn State Limited against UBS, which motion the English court granted. ii. Court Hearings (Task Code B155) Fees: \$67,459.00 Total Hours: 43.40

53. During the Fee Period, Paul Hastings attorneys prepared for numerous hearings and status conferences regarding the Trustee's investigation and related litigation. As detailed further below, attendance at these various hearings was generally recorded under the Matter ID for the applicable adversary proceeding. That said, attendance at the February 13, 2024 hearing on the Trustee's equitable tolling motion and the February 27, 2024 status conference on avoidance actions was recorded under this matter number, i.e., Matter ID 00002.

iii. General Litigation (Task Code B191) Fees: \$780,921.75 Total Hours: 567.35

54. During the Fee Period, Paul Hastings investigated certain potential fraudulent transfer and alter ego claims as well as developed a comprehensive strategy to pursue and/or preserve such claims, including conducting legal research into various issues related to bankruptcy court jurisdiction and equitably tolling the statutes of limitation. That said, in the interest of efficiency, the task of preparing the hundreds of avoidance action complaints was generally handled by NPM,19

55. Of particular note, Paul Hastings prepared the Trustee's motion [Docket No. 2509] (the "Tolling Motion") to extend the deadlines set forth in sections 108, 546(a), and 549 of the Bankruptcy Code for the Trustee to commence actions to avoid and recover fraudulent transfers and/or assert other estate causes of action (which motion was filed on January 18, 2024). The Trustee filed the Tolling Motion because, despite the diligent efforts of the Trustee and his professionals, and the significant and important progress and success he has already made, the enormity of the Trustee's task and the constant obstruction he faced rendered it

19 Paul Hastings generally tracked time spent on avoidance actions under Matter ID 00029. Case 22-50073 Doc 3283 Filed 06/24/24 Entered 06/24/24 18:35:48 Page 31 of 562

impossible for him to complete his investigation and bring all available causes of action prior to February 15, 2024 (i.e., the two-year anniversary of the filing of the Individual Debtor's chapter 11 case).

56. Paul Hastings also prepared the Trustee's reply [Docket No. 2620] in further support of the Tolling Motion and in response to the objections thereto, including ten objections filed by the Debtor's family members or close associates or entities affiliated with (if not controlled by) the Debtor. Paul Hastings handled all aspects of discovery related to the Tolling Motion. On February 14, 2024, the Court granted the Tolling Motion [Docket No. 2837].

57. In connection with the Tolling Motion, Paul Hastings also prepared a motion requesting approval of the form and manner of notice of the Tolling Motion [Docket No. 2494] (the "Notice Motion"), which request the Court granted by order dated January 19, 2024 [Docket No. 2515] (the "Notice Order"). Paul Hastings also coordinated service of the Tolling Motion in accordance with the Notice Order, including publication notice.

58. In addition, during the Fee Period, Paul Hastings negotiated a few tolling agreements with potential litigation targets (although the majority of tolling agreements were being handled by NPM).

59. Separately, Paul Hastings also prepared the Trustee's motion [Docket No. 2975] to stay the Civil RICO Adversary Proceeding and the Omnibus Alter Ego Adversary Proceeding. As further detailed below, the Trustee commenced the Civil RICO Adversary Proceeding and the Omnibus Alter Ego Adversary Proceeding to, among other things, ensure he met the statutory deadline of February 15, 2024 to bring certain types of claims under the Bankruptcy Code. The Trustee sought a stay of these adversary proceedings in light of, among other things, the trial in the Individual Debtor's Criminal Case (as defined below), which began on May 22, 2024. Case 22-50073 Doc 3283 Filed 06/24/24 Entered 06/24/24 18:35:48 Page 32 of 562

Although the Trustee opposes the Individual Debtor's renewed motion (filed in the Criminal Case) to stay these chapter 11 cases and believes that motion lacks merit, the Trustee sought a stay of the Civil RICO Adversary Proceeding and the Omnibus Alter Ego Adversary Proceeding in order to moot the Individual Debtor's arguments and eliminate any possibility of a global stay of these chapter 11 cases. Following discussions with counsel for Mei Guo, the Trustee filed a modified proposed order [Docket No. 3036], which carved out Ms. Guo's motion for withdrawal of the reference of the Civil RICO Adversary Proceeding. The Court granted the Trustee's stay motion (as modified) on March 22, 2024 [Docket No. 3038].

60. In addition, Paul Hastings prepared the Trustee's presentation for the February 27, 2024 status conference to update the Court on the recently filed adversary proceedings and provide a roadmap as to the Trustee intends to move forward (including mediation of certain of the adversary proceedings).

61. Finally, during the Fee Period, Paul Hastings assisted the Trustee—in coordination with the Trustee's BVI counsel (i.e., Harneys)—in seeking an injunction in the BVI to prohibit any sale or other transfer of (a) the Princes Gate apartment in London, United Kingdom and (b) the ownership of K Legacy, the entity that holds title to the London apartment.20 On March 28, 2024, the BVI court entered the requested injunction, which injunction was subsequently continued until further order of the BVI Court.

iv. Non-Working Travel (Task Code B195) [billed at ½ rate] Fees: \$5,321.50 Total Hours: 5.80

62. During the Fee Period, Paul Hastings attorneys travelled to Bridgeport, Connecticut, to attend (a) the March 19, 2024 status conference regarding, among other things,

20 As further detailed below, the Omnibus Alter Ego Adversary Proceeding seeks a ruling that K Legacy is the alter ego of the Individual Debtor. Case 22-50073 Doc 3283 Filed 06/24/24 Entered 06/24/24 18:35:48 Page 33 of 562

(i) the case management of the recently filed Avoidance Actions and (ii) the Trustee's motion to approve mediation procedures, and (b) the March 26, 2024 hearing on Yvette Wang's motion to dismiss the Trustee's adversary proceeding regarding the transfer of the Ace Decade share.

$\text{v.} \quad \frac{\text{Investigations (Task Code B261)}}{\text{Fees: \ $733,272.50} \quad \text{Total Hours: \$ 69.00}$

63. During the Fee Period, Paul Hastings attorneys continued to handle the Trustee's investigation to identify potential assets of the Individual Debtor's estate. Given the corporate maze of shell companies set up by the Individual Debtor, including hundreds of companies purportedly owned by his close family members, business associates, and employees, this investigation has necessarily been extensive and time intensive.

64. As part of this investigation, Paul Hastings attorneys (a) analyzed documents produced in response to Rule 2004 subpoenas,21 (b) engaged in meet and confer sessions with the targets of the Rule 2004 discovery, (c) identified additional entities for further investigation, (d) conducted numerous calls and meetings with the forensic accountant (Kroll) to advance the Trustee's investigation into potential estate claims, (e) analyzed potential claims against the Individual Debtor and his affiliated entities, and (f) commenced the process of having these chapter 11 cases recognized in Switzerland (in order to further advance the Trustee's investigation as to estate property located in Switzerland).

65. Paul Hastings attorneys also continued to assist NPM in preparing supplemental motions under Bankruptcy Rule 2004 seeking discovery from various individuals and entities associated with the Individual Debtor, including the eleventh, twelfth, thirteenth, fourteenth, and

21 As further detailed below, in the interest of minimizing costs, Paul Hastings utilized UnitedLex Corporation ("UnitedLex") to conduct, among other things, first-round review of documents produced in the Trustee's investigation. UnitedLex specializes in discovery services, including document processing, storage, review services, and distribution. Case 22-50073 Doc 3283 Filed 06/24/24 Entered 06/24/24 18:35:48 Page 34 of 562

fifteenth supplemental motions filed on January 16, 2024 [Docket No. 2508], January 19, 2024 [Docket No. 2514], March 8, 2024 [Docket No. 2984], and March 12, 2024 [Docket No. 2996], respectively.22 The Court granted all of these Rule 2004 motions [Docket Nos. 2534, 2537, 3032, and 3040]. Furthermore, during the Fee Period, Paul Hastings attorneys continued to communicate with confidential informants, who provided valuable insight into the Individual Debtor's business operations.23

66. During the Fee Period, Paul Hastings also handled the appeal filed by G Club Operations, LLC ("G Club") of this Court's discovery order compelling HCHK (an entity which the Court has since determined is the alter ego of the Individual Debtor) to deliver to the Trustee documents in HCHK's possession, including documents provided to it by G Club. Among other things, Paul Hastings attorneys prepared the Trustee's appellee brief, which was filed on March 29, 2024.

67. As noted in Paul Hastings' prior fee applications, much of the Trustee's investigation also required the expertise of Paul Hastings' Mandarin-speaking attorneys in order to analyze thousands Mandarin-language documents (including WhatsApp, text messages, and videos). This work required not only Mandarin language skills but an understanding of the legal significance of these documents, which an outside translation service would not be able to provide. Paul Hastings' Mandarin-speaking attorneys were also critical for the Trustee to communicate with the numerous Mandarin-speaking informants that have reached out to the Trustee during the course of these chapter 11 cases.

22 The supplemental Rule 2004 motions were filed by NPM because Paul Hastings was conflicted as to some of the discovery targets. To the extent Paul Hastings did not have a conflict, it assisted NPM in preparing the supplemental motion.

23 In light of the Individual Debtor's well-documented social media campaign against the Trustee, Paul Hastings attorneys, and creditors in these chapter 11 cases, the time entries attached to this Application have been redacted to remove the names of these informants. Case 22-50073 Doc 3283 Filed 06/24/24 Entered 06/24/24 18:35:48 Page 35 of 562

68. To date, the Trustee's investigation (including as a result of discovery under Rule 2004, information provided by confidential informants, and corporate documents received from BVI registered agents) uncovered numerous assets that the Trustee believes are property of the Individual Debtor's estate, which the Trustee is seeking to recover for the benefit of the estate. In fact, as detailed further below, during the Fee Period, the Trustee continued to prosecute several adversary proceedings to recover such assets.

69. Unfortunately, as the Court is well aware, the Trustee's investigation continued to face vigorous opposition, at every turn, not only from the Individual Debtor, but also many of the targets of the Trustee's investigation (i.e., the Individual Debtor's close family members, business associates, and employees), necessitating significant motion practice to compel compliance (which compliance, to this day, remains forthcoming in many instances).

i. General Litigation (Task Code B191) Fees: \$103,680.00 Total Hours: 63.50

70. During the Fee Period, Paul Hastings attorneys assisted the Trustee on various litigation-related matters (other than the adversary proceedings pending in these chapter 11 cases), including the criminal case (the "Criminal Case") pending against the Individual Debtor in the United States District Court for the Southern District of New York [Case No. 1:23-cr-00118-AT] (the "SDNY Court"). Among other things, Paul Hastings monitored the Criminal Case, analyzed various issues related to forfeiture, and analyzed pleadings filed in the Criminal Case, including the superseding indictment filed by the United States (the "Superseding Indictment") and the Individual Debtor's renewed motion to stay the chapter 11 cases (the "Renewed Stay Motion"). Case 22-50073 Doc 3283 Filed 06/24/24 Entered 06/24/24 18:35:48 Page 36 of 562

71. During the Fee Period, Paul Hastings attorneys prepared the Trustee's objection to the Renewed Stay Motion. Paul Hastings attorneys also prepared a letter to the SDNY Court advising the court that the Trustee is seeking to stay the Civil RICO Adversary Proceeding and the Omnibus Alter Ego Adversary Proceeding.

72. Finally, during the Fee Period, Paul Hastings attorneys also prepared and filed numerous notices to apprise this Court and parties in interest of the developments in the Criminal Case, including the Superseding Indictment.

i. Tax Issues (Task Code B240) Fees: \$10,261.50 Total Hours: 6.70

73. During the Fee Period, Paul Hastings attorneys continued to confer with the Trustee's tax advisors (i.e., EA Group) regarding the preparation of tax filings for the Debtors. Among other things, Paul Hastings attorneys addresses questions by EA Group regarding various transactions during these chapter 11 cases, as well as coordinated with EA Group regarding the filing of tax extension forms.

i. Asset Disposition (Task Code B130) Fees: \$10,090.50 Total Hours: 8.40

74. During the Fee Period, Paul Hastings attorneys continued to analyze how best to monetize the furniture located at the Sherry Netherland Apartment. In light of the need to conduct the soot cleaning project on an expeditious basis, Genever (US) determined to first move the furniture into storage before proceeding with a sale thereof. ii. Business Operations (Task Code B210) Fees: \$48,757.50 Total Hours: 26.80

75. During the Fee Period, Paul Hastings attorneys analyzed various operational matters with respect to Genever (US), including, most notably, as it relates to the remediation work for the Sherry Netherland Apartment, including the cleaning of soot and other combustion by-products ("CBPs").

76. Among other things, Paul Hastings attorneys (a) worked closely with the architect (Acheson Doyle) regarding the selection of the general contractor bids for the remediation project, (b) communicated with the consultation parties regarding such selection, (c) prepared the monthly status reports in accordance with the Court's order, dated September 19, 2023 [Docket No. 2213], (d) finalized the alteration agreement with the Sherry Netherland regarding the "white-boxing" of the Sherry Netherland Apartment, and (e) analyzed the soot testing report and evaluated next steps with respect thereto.

77. Moreover, as the Court is aware, after the conclusion of the Fee Period, Paul Hastings attorneys prepared Genever (US)'s motion to remediate soot, char, and other CBPs in the Sherry Netherland Apartment as a result of a fire on March 15, 2023, including related ancillary services, such as abating asbestos in the affected areas, moving furniture into storage, and disposing of certain items of inconsequential value [Docket No. 3128], which motion the Court granted by order dated May 6, 2024 [Docket No. 3168].24 Genever (US) is seeking to complete the remediation and cleaning work at the Sherry Netherland by mid-August 2024, so that the Sherry Netherland Apartment can be placed back on the market shortly thereafter.

24 In light of the Sherry Netherland's concerns that CBPs could potentially cross-contaminate other apartments or common areas in the buildings—via interstitial spaces, chases, plenums, air bands, and elevators, Genever US determined to proceed with the cleaning project.

i. General Litigation (Task Code B191) Fees: \$257,386.00 Total Hours: 188.10

78. During the Fee Period, Paul Hastings attorneys continued to prosecute the Trustee's complaint against Scott Barnett (the Individual Debtor's driver and/or bodyguard), Taurus Fund, LLC, and Taurus Management LLC [Adv. Proc. No. 23-05017] (the "Mahwah Adversary Proceeding"). In the Mahwah Adversary Proceeding, the Trustee seeks determinations that, among other things, (a) the Debtor is the equitable owner of the 50,000 square foot Mahwah Mansion, (b) the Debtor is the equitable owner of Taurus Fund, LLC (the entity holding title to Mahwah Mansion), and (c) that Taurus Fund, LLC is an alter ego of the Individual Debtor.

79. During the Fee Period, Paul Hastings attorneys coordinated with NPM regarding the preparation and filing of the Trustee's motion, upon consent of the Defendants, to stay the Mahwah Adversary Proceeding pending completion of the trial in the Debtor's Criminal Case or further order of the Court [Docket No. 101 in Adv. Proc. No. 23-05017],25 which motion the Court granted by order dated February 2, 2024 [Docket No. 102 in Adv. Proc. No. 23-05017].

80. During the Fee Period, and prior to the stay of the Mahwah Adversary Proceeding, Paul Hastings attorneys continued to handle discovery in the Mahwah Adversary Proceeding, including (a) analyzing documents produced during discovery, (b) preparing requests for production, notices, and subpoenas, and (c) preparing for and taking depositions of three individuals, namely Mordechai Talasazan of Solomon Treasure Antiques (January 11,

25 The Trustee determined that, given the status of discovery in the Mahwah Adversary Proceeding and given that the criminal trial may involve testimony and evidence relevant to the Mahwah Adversary Proceeding, it would be most efficient to stay this adversary proceeding pending conclusion of the criminal trial. Case 22-50073 Doc 3283 Filed 06/24/24 Entered 06/24/24 18:35:48 Page 39 of 562

2024), Evan Lobel of Lobel Modern NYC (January 12, 2024), and Paolo Sozzi of Promemoria USA Inc. (January 16, 2024).

81. Furthermore, as the Court will recall, prior to the Fee Period, on December 18, 2023, Paul Hastings attorneys prepared an emergency motion for the preservation of evidence requesting an order restricting access to a storage facility that the Trustee believed may contain evidence related to the Mahwah Mansion and/or potential property of the estate. On December 21, 2023, the Court issued an order (consented to in part) [Docket No. 93 in Adv. Proc. No. 23- 05017] which largely granted the motion and restricted access to the storage facility to certain parties, including the Trustee and Paul Hastings attorneys. During the Fee Period, Paul Hastings attorneys reviewed the contents of the storage facility and prepared an inventory of such contents.

ii. Non-Working Travel (Task Code B195) [billed at ½ rate] Fees: \$3,102.75 Total Hours: 6.30

82. During the Fee Period, Paul Hastings attorneys traveled to the storage facility in New Jersey for inspection (January 18, 19, and 26, 2023). VII. Golden Spring Adversary Proceeding (Matter ID 00013)

i. General Litigation (Task Code B191) Fees: \$88,766.50 Total Hours: 69.10

83. During the Fee Period, Paul Hastings attorneys continued to handle all aspects of the Trustee's adversary proceeding against Golden Spring and China Golden Spring (the "Golden Spring Entities") [Adv. Proc. No. 23-05018] (the "Golden Spring Adversary Proceeding"). In the Golden Spring Adversary Proceeding, the Trustee seeks determinations that, among other things, (a) Golden Spring is the alter ego of the Individual Debtor and (b) the Individual Debtor is the equitable owner of Golden Spring and/or its assets (notwithstanding China Golden Spring's purported ownership interest in Golden Spring). As the Court will recall, Case 22-50073 Doc 3283 Filed 06/24/24 Entered 06/24/24 18:35:48 Page 40 of 562

on December 4, 2023, the Court entered a default judgment against the Golden Spring Entities [Docket No. 35 in Adv. Proc. No. 23-05018] (the "Golden Spring Default Judgment"). Pursuant to the Golden Spring Default Judgment, the Court determined, among other things, that all assets (including, without limitation, all property, rights, interests, and privileges) held by Golden Spring constitute property of the Estate, and the Court ordered that all such assets be turned over and/or surrendered to the Trustee.

84. During the Fee Period, Paul Hastings attorneys prepared and filed the Trustee's motion seeking to enforce the Golden Spring Default Judgment and compelling HGA Property Operation LLC ("HGA") and Taurus Fund LLC ("Taurus Fund"), Taurus Management LLC ("Taurus Management" and, together with Taurus Fund, the "Taurus Entities"), and Scott Barnett ("Mr. Barnett" and, together with the Taurus Entities, collectively, the "Taurus Parties") to turn over to the Trustee certain property belonging to Golden Spring that the Trustee discovered in certain storage units [Docket No. 40 in Adv. Proc. No. 23-05018] (the "Storage Motion").26 In this regard, Paul Hastings attorneys also consensually resolved the Taurus Fund's limited objection to Storage Motion by making certain modifications to the proposed order, including that while the Court held that property located in Storage Units #1A32 and #CF09 was property of the estate and shall be turned over to the Trustee, the contents of Storage Units #CA14 and #CB14 shall be moved to the Mahwah Mansion pending resolution of the Mahwah Adversary Proceeding or further order of the Court (with the Trustee's rights with respect to such remaining contents preserved).

85. The Court granted the Storage Motion (with the agreed-upon modifications) by order dated March 25, 2024 [Docket No. 46 in Adv. Proc. No. 23-05018]. In accordance with

26 The contents of the storage units consist of, among other things, furniture, artwork, and boxes of documents.

the Storage Motion, the contents of Storage Units #1A32 and #CF09 has since been moved into separate storage controlled by the Trustee, and the contents Storage Units #CA14 and #CB14 has been moved to the Mahwah Mansion.

- i. General Litigation (Task Code B191) Fees: \$96,718.00 Total Hours: 60.50 - 86. During the Fee Period, Paul Hastings attorneys continued to prosecute the

Trustee's complaint against the HCHK Entities, the Assignee, Holy City Hong Kong Ventures, Ltd., Yvette Wang, and Anthony DiBattista [Adv. Proc. No. 23-05013] (the "HCHK Adversary Proceeding"). In the HCHK Adversary Proceeding, the Trustee seeks determinations that, among other things, (a) the HCHK Entities are alter egos of the Individual Debtor and (b) the Individual Debtor is the equitable owner of the HCHK Entities and/or their assets. In addition, the complaint sought an injunction against the commencement or continuation of the assignment proceedings commenced with respect to the HCHK Entities in New York state court (the "Assignment Proceedings"). In connection with the HCHK Adversary Proceeding, the Trustee also requested and obtained a temporary restraining order (the "HCHK TRO") as it relates to the commencement or continuation of the Assignment Proceeding. See Docket No. 18 in Adv. Proc. No. 23-05013.

87. Among other things, during the Fee Period, Paul Hastings attorneys (a) analyzed the post-hearing brief filed by the HCHK Entities and Holy City [Docket No. 246 in Adv. Proc. No. 23-05013], (b) prepared and filed the Trustee's response in opposition to that post-hearing brief [Docket No. 249 in Adv. Proc. No. 23-05013], (c) handled discovery requests in connection with the HCHK Adversary Proceeding, and (d) prepared and filed the Trustee's motion for default judgment against the HCHK Entities, Holy City, Mr. DiBattista, Ms. Wang, Case 22-50073 Doc 3283 Filed 06/24/24 Entered 06/24/24 18:35:48 Page 42 of 562

and the Assignee [Docket No. 268 in Adv. Proc. No. 23-05013]. Moreover, during the Fee Period, Paul Hastings attorneys handled the appeal (filed on January 19, 2024) by certain proposed intervenors (i.e., Shih Hsin Yu, 1332156 B.C. Ltd, and GWGOPNZ Limited) of this Court's order denying their invention motion.27

88. On June 14, 2024, the Court granted the Trustee's motion for default judgment, holding, among other things, that the HCHK Entities are the alter egos of the Individual Debtor and directing that the property of the HCHK Entities be turned over to the estate. As a result of this ruling, among other things, over \$38 million of the HCHK Entities' funds (previously transferred into accounts controlled by the Trustee pursuant to the settlement with the Assignee) are now property of the estate.

ii. Business Operations (Task Code B210) Fees: \$13,759.50 Total Hours: 11.40

89. During the Fee Period, Paul Hastings attorneys Paul Hastings attorneys worked with the Assignee's counsel to handle administrative matters undertaken pursuant to the settlement agreement (the "Assignee Settlement") between the Trustee and the Assignee. These tasks included, among other things, reviewing the Assignee's business records, analyzing the HCHK Entities' cash holdings, filing expense reports required to be filed under the Assignee Settlement, and handling payments to employees and service providers of the HCHK Entities.

27 That appeal has been consolidated with the proposed intervenors other pending appeal related to the HCHK Entities, namely this Court's order approving the Assignee Settlement. Appellants filed their opening brief in this consolidated appeal on April 26, 2024, and the Trustee's consolidated response brief was filed on June 14, 2024.

i. General Litigation (Task Code B191) Fees: \$34,630.00 Total Hours: 18.80

90. During the Fee Period, Paul Hastings attorneys continued to assist NPM in prosecuting the Trustee's complaint against Mei Guo [Adv. Proc. No. 22-05008] (the "Mei Guo Adversary Proceeding"). In the Mei Guo Adversary Proceeding, the Trustee seeks (a) an order declaring that the proceeds (the "Bombardier Proceeds") from the sale of the Individual Debtor's private Bombardier jet (the "Bombardier") are property of the estate, (b) an order that Mei Guo surrender the Bombardier Proceeds or the value thereof to the Trustee because she received the Bombardier Proceeds as an unauthorized postpetition transfer avoidable under section 549 of the Bankruptcy Code, (c) an order that Mei Guo surrender to the Trustee the value of the Individual Debtor's shell company Anton Development Limited ("Anton Development") at the time the company was transferred to her on June 27, 2017 (upon which date Anton Development was title holder to the Bombardier) pursuant to a transaction avoidable as an actual fraudulent transfer, and (d) an order declaring that a series of BVI registered shell companies purportedly held by Mei Guo are property of the Individual Debtor's chapter 11 estate.

91. Among other things, during the Fee Period, Paul Hastings attorneys assisted NPM in preparing the reply in further support of the Trustee's motion for summary judgment in this adversary proceeding, which was filed on February 1, 2024 [Docket No. 115 in Adv. Proc. No. 22-05008]. On April 3, 2024, the Court granted, in part, the Trustee's motion for summary judgment, holding, among other things, that the Individual Debtor beneficially owned the Bombardier and, hence, beneficially owns the Bombardier Proceeds and directing Mei Guo to turn over to the estate the Bombardier Proceeds. X. Greenwich Land Adversary (Matter ID 00020)

i. Court Hearings (Task Code B155) Fees: \$27,822.50 Total Hours: 17.70

92. During the Fee Period, Paul Hastings attorneys prepared for and attended the January 9, 2024 oral argument on the Trustee's motion for summary judgment against Greenwich Land and Hing Chi Ngok in the Greenwich Land Adversary Proceeding (as defined below).

ii. General Litigation (Task Code B191) Fees: \$180,764.50 Total Hours: 132.70

93. During the Fee Period, Paul Hastings attorneys continued to prosecute the Trustee's complaint against Greenwich Land and Hing Chi Ngok [Adv. Proc. No. 23-05005] (the "Greenwich Land Adversary Proceeding"). In the Greenwich Land Adversary Proceeding, the Trustee seeks determinations that, among other things, (a) Greenwich Land is an alter ego of the Individual Debtor and (b) the Individual Debtor is the equitable owner of Greenwich Land. Paul Hastings' efforts thus far have resulted in critical prejudgment remedies and injunctive relief to protect the assets of Greenwich Land, including the Individual Debtor's mansion on Taconic Road in Greenwich, Connecticut, pending the outcome of the Greenwich Land Adversary

Proceeding, for the benefit of the estate.

94. During the Fee Period, Paul Hastings attorneys prepared and filed the Trustee's objection to Greenwich Land and Hing Chi Ngok's motion to strike allegedly new evidence presented by the Trustee in his is reply in support of his motion for summary judgment [Docket No. 123 in Adv. Proc. No. 23-05005]. As of the filing of this Application, the Court has not yet ruled on defendants' motion to strike or the Trustee's motion for summary judgment.

- iii. Non-working Travel (Task Code B195) [billed at ½ rate] Fees: \$6,195.75 Total Hours: 8.00 - 95. During the Fee Period, Paul Hastings attorneys traveled to Bridgeport,

Connecticut, to attend the January 9, 2024 hearing on the Trustee's motion for summary judgment. XI. Lamp Capital Adversary (Matter ID 00024)

i. General Litigation (Task Code B191) Fees: \$100,045.00 Total Hours: 67.10

96. During the Fee Period, Paul Hastings attorneys continued to prosecute the Trustee's adversary proceeding against Lamp Capital LLC and certain other defendants [Adv. Proc. No. 23-05023] (the "Lamp Capital Adversary Proceeding"). In the Lamp Capital Adversary Proceeding, the Trustee seeks determinations that, among other things, Lamp Capital, Hudson Diamond NY LLC, and Leading Shine NY are the Individual Debtor's alter egos and that the Individual Debtor equitably owns these alter ego defendants and their assets. On December 14, 2023, the Court entered a default against defendants Lamp Capital, Infinity Treasury, Leading Shine NY, and Yvette Wang [Docket No. 13 in Adv. Proc. No. 23-05023].

97. During the Fee Period, Paul Hastings attorneys, in coordination with NPM, prepared and filed (a) the Trustee's objection to the motion to dismiss of defendants Hudson Diamond NY, Hudson Diamond Holding and Mei Guo [Docket No. 36 in Adv. Proc. No. 23- 05023], (b) the Trustee's objection to Leading Shine NY's motion to set aside the entry of default [Docket No. 47 in Adv. Proc. No. 23-05023], and (c) the Trustee's objection to Lamp Capital's and Infinity Treasury's cross-motion to set aside the entry of default and the Trustee's reply in further support of his motion for entry of default judgment against Lamp Capital and Infinity Treasury [Docket No. 48 in Adv. Proc. N. 23-05023]. On February 1, 2024, the Court entered its order granting the Trustee's motion for entry of default as against Lamp Capital and Case 22-50073 Doc 3283 Filed 06/24/24 Entered 06/24/24 18:35:48 Page 46 of 562

Infinity Treasury and denying Lamp Capital's and Infinity Treasury's cross-motion to set aside the entry of default [Docket No. 63 in Adv. Proc. No. 23-05023].28 By separate order dated March 14, 2024, the Court denied the Leading Shine NY's motion to set aside the entry of default against it [Docket No. 74 in Adv. Proc. No. 23-05023]. Finally, on March 22, 2024, the Court denied the motion to dismiss of defendants Hudson Diamond NY, Hudson Diamond Holding, and Mei Guo [Docket No. 87 in Adv. Proc. No. 23-05023]. XII. Ace Decade Adversary Proceeding (Matter ID 00026)

i. Court Hearings (Task Code B155) Fees: \$18,730.50 Total Hours: 10.20

98. During the Fee Period, Paul Hastings attorneys prepared for and attended the March 26, 2024 hearing on defendant Wang's motion to dismiss the Ace Decade Adversary Proceeding (as defined below).

ii. General Litigation (Task Code B191) Fees: \$84,242.00 Total Hours: 52.60

99. During the Fee Period, Paul Hastings attorneys continued to prosecute the Trustee's adversary proceeding against Ace Decade, Yvette Wang, and Rui Hao [Adv. Proc. No. 23-05028] (the "Ace Decade Adversary Proceeding"). In the Ace Decade Adversary Proceeding, the Trustee seeks declarations that the transfer of the Ace Decade share by defendant Wang to defendant Hao is void in light of this Court's prior ruling that the Trustee beneficially owns the Ace Decade share.

100. During the Fee Period, Paul Hastings attorneys (a) coordinated service of the complaint on the defendants, including international service on defendant Hao (who resides in

28 On February 15, 2024, Lamp Capital and Infinity Treasury appealed this decision to the United States District Court of the District of Connecticut.

Switzerland) in accordance with the Hague Convention,29 and (b) prepared and filed the Trustee's response to defendant Wang's motion to dismiss [Docket No. 17 in Ad. Proc. No. 23- 05028], which this Court denied by order dated March 26, 2024 [Docket No. 23 in Ad. Proc. No. 23-05028]. XIII. Defeng Cao Adversary Proceeding (Matter ID 00027)

i. General Litigation (Task Code B191) Fees: \$75,806.00 Total Hours: 61.30

101. During the Fee Period, Paul Hastings attorneys prepared and filed the Trustee's complaint against Defeng Cao (the long-term boyfriend of the Debtor's daughter) [Adv. Proc. No. 24-05001] (the "Defeng Cao Adversary Proceeding"). In the Defeng Cao Adversary Proceeding, the Trustee seeks to recover six separate vehicles—three Harley Davidsons and one BMW motorcycle, as well as one Land Rover Defender and one Dodge Ram Pickup Truck which, while nominally held by the defendant, were fraudulently transferred to the defendant, or alternatively, are equitably owned by the Individual Debtor.

102. In connection with the Defeng Cao Adversary Proceeding, Paul Hastings attorneys prepared the Trustee's related motion [Docket No. 2 in Adv. Proc. No. 24-05001] to seal certain portions of the complaint and exhibits attached thereto, as they contain certain information that has been designated as "Confidential" or "Highly Confidential" pursuant to the Protective Order [Docket No. 923], which motion was granted by order dated February 7, 2024 [Docket No. 6 in Adv. Proc. No. 24-05001].

103. Furthermore, during the Fee Period, Paul Hastings attorneys began preparing the Trustee's motion for judgment on the pleadings on Count I and II of the complaint [Docket No.

29 As of the filing of this Application, the Trustee is awaiting confirmation from the Swiss central authority that service upon Mr. Hao has been completed. Case 22-50073 Doc 3283 Filed 06/24/24 Entered 06/24/24 18:35:48 Page 48 of 562

19 in Adv. Proc. No. 24-05001], which motion was eventually filed on April 12, 2024 (i.e., after the conclusion of the Fee Period). XIV. Omnibus Alter Ego Adversary Proceeding (Matter ID 00028) i. General Litigation (Task Code B191) Fees: \$384,088.06 Total Hours: 284.69

104. During the Fee Period, Paul Hastings attorneys prepared the Trustee's complaint against more than forty entities—each nominally owned by a family member or associate of the Individual Debtor)—seeking rulings that such entities are alter egos of the Individual Debtor and/or their assets are beneficially owned by the Individual Debtor, such that their assets are property of the estate [Adv. Proc. No. 24-05249] (the "Omnibus Alter Ego Adversary Proceeding").30 These entities include, among others, ACA Capital Group Ltd., Anton Development Limited, Bravo Luck Limited, Freedom Media Ventures Limited, G Club International Limited, G Club Operations LLC, Hamilton Capital Holding Limited, Hamilton Investment Management Limited, Hamilton Opportunity Fund SPC, Himalaya Currency Clearing Pty Ltd., Himalaya International Clearing Limited, Himalaya International Financial Group Limited, Himalaya International Payments Limited, Himalaya International Reserves Limited, Jovial Century International Limited, K Legacy Ltd., Rule of Law Foundation III, Inc., Rule of Law Society IV, Inc., and Saraca Media Group, Inc.31

30 As noted above, the Omnibus Alter Ego Adversary Proceeding has been stayed pending conclusion of the Individual Debtor's criminal trial, except as to the Trustee's claims against defendant K Legacy, Ltd. ("K Legacy") and Qiang Guo in his capacity as nominal owner of K Legacy. On May 17, 2024, the Clerk of the Court entered a default against K Legacy [Docket No. 26 in Adv. Proc. No. 24-5249].

31 The Trustee previously commenced separate litigation against several of the Individual Debtor's shell companies asserting alter ego and equitable ownership claims (or similar claims under applicable law) against, among others: (i) HK USA; (ii) Greenwich Land; (iii) Whitecroft Shore Limited ("Whitecroft"); (iv) the HCHK Entities; (v) Taurus Fund; (vi) Golden Spring; (vii) Lamp Capital; (viii) Hudson Diamond NY; and (ix) Leading Shine. As the Court is aware, the Trustee prevailed on such claims as it relates to HK USA, Whitecroft, the HCHK Entities, Golden Spring, and Lamp Capital. A decision as to the other entities remains pending. Case 22-50073 Doc 3283 Filed 06/24/24 Entered 06/24/24 18:35:48 Page 49 of 562

105. Paul Hastings also prepared the related motion [Docket No. 2 in Adv. Proc. No. 24-05249] to seal certain exhibits cited within and attached to the complaint, as they contain certain information that has been designated "Confidential" or "Highly Confidential" pursuant to the Protective Order [Docket No. 923], which motion the Court granted by order dated February 26, 2024 [Docket No. 4 in Adv. Proc. No. 24-05249]. In connection with that motion, Paul Hastings attorneys also analyzed the confidentiality designation of such exhibits.

106. During the Fee Period, Paul Hastings also coordinated service of the complaint on the defendants.

i. Court Hearings (Task Code B155) Fees: \$25,183.50 Total Hours: 13.30

107. During the Fee Period, Paul Hastings attorneys prepared for and attended the March 19, 2024 status conference regarding, among other things, (i) the case management of the recently filed Avoidance Actions and (ii) the Trustee's Mediation Procedures Motion (as defined below).

$$\text{iii.} \quad \frac{\text{General Litigation (Task Code B191)}}{\text{Frees: } \\$583,172.20} \quad \frac{\text{Total Hours: } \\$05.46}{\text{Total Hours: } \\$05.46}$$

108. During the Fee Period, Paul Hastings attorneys, in conjunction with Kroll and NPM, analyzed potential avoidance actions claims and conducted related research, including as to jurisdictional matters. In this regard, Paul Hastings also coordinated with NPM32 with respect to the Trustee's motion to approve procedures governing such avoidance actions (the "Avoidance Actions Procedures Motion"), including as to the treatment of confidential information and the timeline for responding to avoidance action complaints. The Avoidance

32 In the interest of minimizing costs, NPM drafted the Avoidance Actions Procedures Motion. Case 22-50073 Doc 3283 Filed 06/24/24 Entered 06/24/24 18:35:48 Page 50 of 562

Actions Procedures Motion was filed on January 29, 2024 [Docket No. 2532] and granted by the Court on February 7, 2024 [Docket No. 2578].33

109. Ultimately, on or before February 15, 2024, the Trustee filed more than 270 Avoidance Actions seeking the avoidance of fraudulent and post-petition transfers made by the Individual Debtor through his shell companies. In order to minimize costs, the large majority of these complaints were prepared and filed by NPM; however, in light of the significant numbers of complaints that needed to be prepared, Paul Hastings attorneys also drafted several of these complaints.

110. Furthermore, Paul Hastings attorneys prepared, in coordination with NPM, the Trustee's motion (the "Mediation Procedures Motion") to amend the avoidance actions procedures to temporarily stay certain of the recently filed avoidance actions while the Trustee and the respective defendants engage in informal settlement discussions and participate in nonbinding mediation under the supervision of U.S. Bankruptcy Judge James J. Tancredi. The Court granted the Mediation Procedures Motion (with certain revisions) by order, dated May 2, 2024 [Docket No. 3163].

111. Finally, during the Fee Period, Paul Hastings attorneys also coordinated the service of the Avoidance Action complaints on the respective defendants, including international service through the Hague Convention.

112. Section 331 of the Bankruptcy Code provides for interim compensation of professionals and incorporates the substantive standards of section 330 of the Bankruptcy Code

33 As further detailed below, the Trustee subsequently sought (and the Court granted) certain revisions to these procedures. Case 22-50073 Doc 3283 Filed 06/24/24 Entered 06/24/24 18:35:48 Page 51 of 562

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).34

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

114. 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., 35 while also incorporating the "lodestar method." See Arbor Hill Concerned Citizens

34 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).

35 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. Case 22-50073 Doc 3283 Filed 06/24/24 Entered 06/24/24 18:35:48 Page 52 of 562

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.36 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 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").

115. In accordance with the factors enumerated in section 330 of the Bankruptcy Code and applicable case law, the amount requested herein by Paul Hastings is fair and reasonable, as set forth below and otherwise in this Application.

Paul Hastings billed a total of \$4,141,700.76 and 3,188.90 hours, respectively, of professional and paraprofessional services during the Fee Period. As evidenced by this Application, Paul Hastings professionals and paraprofessionals worked diligently and efficiently without unnecessary duplication of efforts throughout the Fee Period. A small group of the same Paul Hastings attorneys was utilized

36 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).

for the vast majority of the work in order to minimize the costs of intra-Paul Hastings communication and education about the Debtors' circumstances. Whenever possible, Paul Hastings sought to minimize the cost of Paul Hastings' services by utilizing talented junior attorneys and paraprofessionals to handle the more routine aspects of the assignments. The services were performed in an effective and efficient manner commensurate with the complexity, exigency, and importance of the issues involved. In addition, Paul Hastings' representation has required it to balance the need to provide quality services with the need to act quickly and represent the Trustee and the Genever Debtors in an effective, efficient, and timely manner. Paul Hastings submits that the hours spent were reasonable given the size and complexity of these chapter 11 cases, the significant, and often urgent, legal and business issues raised, and the numerous pleadings filed in the chapter 11 cases. Furthermore, as noted detailed above, the Trustee and the Genever Debtors also retained NPM as local and conflicts counsel in order to provide services to the Trustee and the Genever Debtors in a costeffective manner. Paul Hastings and NPM have coordinated and will continue to coordinate each firm's respective responsibilities in connection with the representation of the Trustee and the Genever Debtors. b. Novelty and Difficulty of the Questions

Paul Hastings tasked knowledgeable attorneys to research, analyze, and advise the Trustee and the Genever Debtors on difficult and complex issues during the Fee Period, including issues related to bankruptcy and litigation. Most notably, as detailed in this Application, Paul Hastings investigated complex estate claims and causes of action in order to recover assets of these estates. c. Skill Requisite to Perform the Legal Services Properly

Paul Hastings believes that its recognized expertise in the areas of financial restructuring and corporate reorganization, its ability to draw from highly experienced professionals in other areas of Paul Hastings' practice, and its creative approach to the resolution of issues has contributed to the effective administration of these chapter 11 cases and benefited the Trustee, the Genever Debtors, their estates, and their unsecured creditors. Due to the nature and complexity of the legal issues presented by these chapter 11 cases, Paul Hastings was required to exhibit a high degree of legal skill in areas related to, among others, bankruptcy and litigation.

d. Preclusion of Other Employment by Applicant Due to Acceptance of the Case

Due to the size of Paul Hastings' restructuring and litigation departments, Paul Hastings' representation of the Trustee and the Genever Debtors did not preclude its acceptance of new clients, but the demands for immediate and substantive action in these chapter 11 cases imposed significant burdens on Paul Hastings professionals and paraprofessionals working concurrently on other matters. That said, for the Trustee, his engagement as a chapter 11 trustee has, for all practical purposes precluded other employment given that this matter is taking up most of his time.

Other than the hourly rate for Luc A. Despins (which has been reduced from his standard hourly rate of \$2,225.00 to \$1,975.00), the fees charged by Paul Hastings in these chapter 11 cases are billed in accordance with its existing billing rates and procedures in effect during the Fee Period. The rates Paul Hastings charges for the services rendered by its professionals and paraprofessionals in these chapter 11 cases are comparable to the rates Paul Hastings charges for professional and paraprofessional services rendered in comparable nonbankruptcy related matters. Moreover, when Paul Hastings' restructuring professionals and paraprofessionals work on nonbankruptcy matters, the firm generally charges their standard rate. Such fees are reasonable based on the customary compensation charged by comparably skilled practitioners in comparable nonbankruptcy cases in a competitive national legal market. In addition, the firm's customary hourly rates and rate structure reflect that restructuring and related matters typically involve great complexity, numerous tasks requiring a high level of expertise, and severe time pressures, as is the case here. f. Whether the Fee Is Fixed or Contingent

Pursuant to Bankruptcy Code sections 330 and 331, all fees sought by professionals employed under Bankruptcy Code section 1103 are subject to final approval by the Court, and are subject to adjustment depending on the services rendered and the results obtained. Of particular note, payment of Paul Hastings' fees here was contingent in two respects: (1) the recovery of assets for the benefit of the estates and (2) monetizing such assets. At the outset of these chapter 11 cases, there was no assurance whatsoever that assets would be recovered and monetized to allow for the payment of estate professionals. Accordingly, Paul Hastings' compensation was, in essence, a contingency fee arrangement. The risk that Paul Hastings assumed by representing the Trustee and the Genever Debtors further supports the reasonableness of Paul Hastings' compensation. g. Time Limitations Imposed by the Client or Other Circumstances

During the Fee Period, Paul Hastings was required to analyze and address certain issues arising in these chapter 11 cases under compressed timelines. For example, given the Individual Debtor's track record of moving assets to keep them out of reach of creditors, it was critical that Paul Hastings act quickly on information obtained during the Trustee's investigation in order to freeze assets.

Paul Hastings professionals and paraprofessionals worked diligently to maximize value for these chapter 11 estates. During the Fee Period, and as described in the summary of services herein, Paul Hastings was instrumental in analyzing potential sources of recovery for the benefit of these estates. During the Fee Period, Paul Hastings was able to secure several key rulings from the Court, which rulings will serve as a beachhead for future asset recovery efforts. The reasonableness of Paul Hastings' fees must be evaluated in light of this important strategic factor. i. Experience, Reputation, and Ability of Attorneys

Paul Hastings is consistently recognized as a top tier law firm in the field of business reorganizations and liquidations under chapter 11 of the Bankruptcy Code. During the Application Period, Paul Hastings solicited the skill and expertise of its professionals and paraprofessionals. Paul Hastings professionals have actively represented debtors, creditors, and creditors' committees, as well as other parties in interest, in a number of the nation's largest chapter 11 cases as well as in connection with cross-border restructurings. Paul Hastings' extensive experience enables it to perform the services described herein competently and expeditiously. In addition to its expertise in the area of corporate reorganization, Paul Hastings has called upon the expertise of its attorneys in other practice areas as required during the Fee Period.

As detailed in this Application, the Individual Debtor's in-court and out-of-court tactics illustrate the undesirability of this engagement, which involved harassment of the Trustee and Paul Hastings attorneys (including death threats against the Trustee). As a result, Paul Hastings was forced to incur hundreds of thousands of dollars in cyber security measures (the cost of which are not part of the expenses for which Paul Hastings is seeking reimbursement in this Application). In addition, prior to the Court granting the First Interim Fee Application at the end of June 2023, Paul Hastings was unable to get paid for its fees for almost a year. k. Nature and Length of Professional Relationship

Paul Hastings has been rendering professional services to (a) the Trustee since its retention as counsel effective as of July 8, 2022, (b) Genever (BVI) since its retention as counsel effective as of October 11, 2022, and (c) Genever (US) since its retention as counsel effective as of November 3, 2022.

116. Paul Hastings respectfully submits that the services for which it seeks

compensation in this Fee Application were, at the time rendered, necessary for and beneficial to the Debtors' estates and their creditors and were rendered to maximize, protect, and preserve value for the Debtors' estates and all parties in interest. Paul Hastings believes that it provided services economically, effectively, and efficiently, and obtained results beneficial to the Debtor's estate and his creditors. Paul Hastings further submit that the compensation requested herein is reasonable in light of the nature, extent, and value of the services rendered during the Fee Period.

117. Paul Hastings also notes that the rates charged during the Fee Period are reasonable. In fact, this Court held that Paul Hastings' New York rates are reasonable because Case 22-50073 Doc 3283 Filed 06/24/24 Entered 06/24/24 18:35:48 Page 56 of 562

Paul Hastings was retained at New York rates and these cases are extraordinary within this District. See Order Denying Motion for Stay Pending Appeal [Docket No. 1791].

118. All fees incurred by Paul Hastings during the Fee Period were actual, reasonable, and necessary in the performance of services for the Trustee and the Genever Debtors. Paul Hastings respectfully requests approval of the compensation sought herein.

119. As set forth in Exhibit C hereto, Paul Hastings incurred and disbursed \$262,633.83 as expenses in providing professional services during the Fee Period. These expenses include approximately \$23,142.36 for online legal research (i.e., LEXIS and Westlaw). Because Paul Hastings believes that online legal research (e.g., LEXIS and Westlaw) is far more cost-efficient than manual research using hard-bound volumes, Paul Hastings encourages computerized legal research even though it is not a profit center for Paul Hastings. To be clear, Paul Hastings does not charge a mark-up on the LEXIS and Westlaw charges, but merely passes on the costs of such third-party services. Moreover, as it relates to outside professional services, mailing, and other service-related expenses, the Trustee and Paul Hastings are merely passing on the costs of such third-party services, without any mark-up.37

- 120. Additional necessary expenses included: - \$161,040.12 for certain outside professional services, such as document review services by UnitedLex (\$143,991.57) and translation services by Divergent Language Solutions (\$2,795.75); - \$25,327.52 for document reproductions, namely \$23,354.32 for b/w reproductions (at 8 cents per page) and \$1,973.20 for color reproductions (at 20 cents per page);

37 Documentation of these expenses will be made available to the Court upon request.

Case 22-50073 Doc 3283 Filed 06/24/24 Entered 06/24/24 18:35:48 Page 57 of 562

- \$14,054.15 for process servers (e.g., Metro Attorney Service Inc.) to serve, among other things, the subpoenas issued pursuant to the Rule 2004 orders entered by this Court; - \$8,793.15 for court reporting services; - \$801.98 for UPS/courier service, including service of pleadings required to be served in hard copy format; and - \$416.25 for corporate document retrieval services (including United Corporate Service and Corp2000) with respect to various Kwok-related entities.

121. During the Fee Period, Paul Hastings utilized UnitedLex -- a third party vendor that specializes in discovery services including document processing, storage, review services, and distribution -- to conduct document review of the documents produced in the chapter 11 cases, including the hundreds of thousands of discovery documents received by the Trustee to date in connection with his investigation.

122. Using their own contract attorneys and review team managers, UnitedLex provides an efficient and economic means of reviewing large document sets at hourly rates significantly lower than Paul Hastings. UnitedLex's document review team charges hourly rates ranging from \$40 to \$55 (for non-management roles) and \$150 (for management role), which is substantially less than Paul Hastings' hourly rates and, moreover, is even less than the hourly rates of associates of local Connecticut counsel (i.e., NPM), whose hourly rates range from \$220 to \$425. For all these reasons, Paul Hastings believes that utilizing the UnitedLex document review team greatly benefits these estates by reducing document review costs. The Trustee also previewed Paul Hastings' use of UnitedLex with the U.S. Trustee, who had no objection thereto (without the Trustee having to file a separate retention application for UnitedLex). The Trustee and Paul Hastings also disclosed in the Fourth Supplemental Declaration of Disinterestedness of Case 22-50073 Doc 3283 Filed 06/24/24 Entered 06/24/24 18:35:48 Page 58 of 562

Luc A. Despins [Docket No. 1435] that Paul Hastings would utilize UnitedLex's contract attorney services.

123. The time constraints imposed by the circumstances of the matters handled by Paul Hastings during the Fee Period required its attorneys and other employees, at times, to devote substantial time during the evenings and on weekends to perform legal services on behalf of the Trustee. These extraordinary services were essential to meet deadlines, timely respond to inquiries on a daily basis, and satisfy the Trustee's needs and demands. Attorneys and other Paul Hastings employees who worked late in the evenings or on weekends were reimbursed for their reasonable meal and transportation costs in accordance with firm policy. Paul Hastings' regular practice is not to include components for those charges in overhead when establishing billing rates, but rather to charge its clients for these and all other out-of-pocket disbursements incurred during the regular course of the provision of legal services.

124. In accordance with Appendix D (Guidelines for Compensation and Expense Reimbursement of Professionals) to the Local Rules, reproduction charges have been capped at 20 cents per page.38

125. The expenses requested herein are customarily charged to non-bankruptcy clients of Paul Hastings. Additionally, the expenses incurred by Paul Hastings to third parties are limited to the actual amounts billed to, or paid by, Paul Hastings on behalf of the estates.

126. Paul Hastings believes the rates for charges incurred are the market rates that the majority of law firms charge clients for such services. In addition, Paul Hastings believes that such charges are in accordance with the American Bar Association's ("ABA") guidelines, as set

38 Generally, Paul Hastings charges 8 cents per page for black-and-white reproductions and 50 cents per page for color reproductions. In accordance with Appendix D to the Local Rules, Paul Hastings has reduced the charge for color reproductions to 20 cents per page.

forth in the ABA's Statement of Principles, dated January 12, 1995, regarding billing for

disbursements and other charges.

127. The expenses incurred in providing professional services in the Chapter 11 Case

were necessary, economical, and justified under the circumstances.

128. Paul Hastings responds to the questions set forth in Paragraph C.5. of the

U.S. Trustee Guidelines as follows:

Question: Did you agree to any variations from, or alternatives to, your standard or customary billing rates, fees, or terms for services pertaining to this engagement that were provided during the Fee Period?

Response: Yes. As a courtesy to these estates and based on circumstances unique to these chapter 11 cases, during the Fee Period, Paul Hastings agreed to voluntary fee reductions aggregating \$70,058.50, including the following:

Paul Hastings is not seeking allowance or payment at this time of the fees incurred by twelve (12) timekeepers who billed less than five (5) hours during the Fee Period. The total amount of such fees is \$24,933.50. The time billed by these timekeepers was reasonable, and Paul Hastings reserves the right to seek allowance of these fees based on the facts and circumstances of these cases, including, without limitation, if objections are interposed to the allowance of Paul Hastings' fees and expenses.

As a result of the agreed-upon reduction in Luc A. Despins' hourly rate (from his standard hourly rate of \$2,225 to the reduced hourly rate of \$1,975), an additional \$45,125.00 in fees have been waived. Question: If the fees sought in this application as compared to the fees budgeted for the Fee Period are higher by 10% or more, did you discuss the reasons for the variation with the client. Response: Not applicable.

Question: Have any of the professionals included in this application varied their hourly rate based on the geographic location of the bankruptcy case?

Response: No. Question: Does the application include time or fees related to reviewing or revising time records or preparing, reviewing, or revising invoices? (This is limited to work involved in preparing and editing billing records that would not be compensable outside of bankruptcy and does not include reasonable fees for preparing a fee application.) If so, please quantify by hours and fees. Response: The Application does not include time for preparing, reviewing, or revising time records. However, the Application does include approximately 20.9 hours and associated fees of approximately \$34,502.00 related to preparing, reviewing, and revising Paul Hastings' fee statements and ensuring time entries are properly categorized by matter number and task code. On average, approximately four hours were spent on each of the five monthly fee statements prepared during the Fee Period. Question: Does this application include time or fees for reviewing time records to redact any privileged or other confidential information? If so, please quantify by hours and fees. Response: No. Question: If the application includes any rate increases since retention: (i) Did your client review and approve those rate increases in advance? (ii) Did your client agree when retaining the law firm to accept all future rates increases? If not, did you inform your client that they need not agree to modified rates or terms in order to have you continue the representation consistent with ABA Formal Ethics Opinion 11-458? Response: As is customary, Paul Hastings adjusts its hourly rates periodically based upon (i) the advancing seniority of its professionals and paraprofessionals, (ii) the current market for legal services, (iii) the rates charged for comparable non‐

bankruptcy services, and (iv) the firm's analysis of the hourly rates being charged by professionals in other law firms. Effective January 1, 2023, September 1, 2023, and January 1, 2024, Paul Hastings adjusted its hourly rates consistent with the Retention Order [Docket Nos. 668 and 1376] and the Case 22-50073 Doc 3283 Filed 06/24/24 Entered 06/24/24 18:35:48 Page 61 of 562

Notices of Change in Hourly Rates of Paul Hastings LLP, Counsel to Chapter 11 Trustee [Docket Nos. 1251, 2075, and 2450].

129. To the extent that time or disbursement charges for services rendered or expenses incurred during the Fee Period are not included in this Application, or the Trustee and Paul Hastings have for any reason not sought compensation or reimbursement with respect to such services (including, as noted above, services related to the preparation and prosecution of the Civil RICO Adversary Proceeding), Paul Hastings reserves the right to request compensation and reimbursement for such services in a supplemental or future application in the Debtors' chapter 11 cases. Also, Paul Hastings 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.

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

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WHEREFORE, Paul Hastings respectfully requests entry of an order, substantially in the form attached hereto as Exhibit G, (i) allowing interim compensation for professional services rendered during the Fee Period in the amount of \$4,141,700.76 and reimbursement of \$262,633.83 in expenses, (ii) authorizing payment from the Debtors' estates of 80% of such compensation and 100% of such expenses as it relates to the Fee Period services, (iii) allowing such compensation and payment for professional services rendered and reimbursement of actual and necessary expenses incurred without prejudice to the Trustee's and Paul Hastings' right to seek further compensation and/or payment from the Debtors' estates for the full value of services performed and expenses incurred, and (iv) granting the Trustee and Paul Hastings such other and further relief as is just.

Dated: June 24, 2024 New Haven, Connecticut

> By: /s/ G. Alexander Bongartz G. Alexander Bongartz (admitted pro hac vice) PAUL HASTINGS LLP 200 Park Avenue New York, New York 10166 (212) 318-6079 alexbongartz@paulhastings.com

Nicholas A. Bassett (admitted pro hac vice) PAUL HASTINGS LLP 2050 M Street NW Washington, D.C., 20036 (202) 551-1902 nicholasbassett@paulhastings.com

Counsel for the Chapter 11 Trustee, Genever Holdings Corporation, and Genever Holdings LLC UNITED STATES BANKRUPTCY COURT DISTRICT OF CONNECTICUT BRIDGEPORT DIVISION

-------------------------------------------------------- x

In re: :

HO WAN KWOK, et al., :

Debtors. :

The undersigned hereby certifies that on June 24, 2024, the foregoing Application was electronically filed. Notice of this filing was sent by e-mail to all parties to the above-captioned chapter 11 case 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.1 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.

Dated: June 24, 2024 New Haven, Connecticut

By: /s/ G. Alexander Bongartz G. Alexander Bongartz (admitted pro hac vice) PAUL HASTINGS LLP 200 Park Avenue New York, New York 10166 (212) 318-6079 alexbongartz@paulhastings.com

Counsel for the Chapter 11 Trustee, Genever

1 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.

Holdings Corporation, and Genever Holdings LLC

Customary and Comparable Compensation Disclosures

The blended hourly rate for Paul Hastings' timekeepers in its New York and Washington, D.C. offices who billed to non-bankruptcy matters (collectively, the "Non-Bankruptcy Matters")1 during the twelve-month period beginning on April 1, 2023 and ending on March 31, 2024 was, in the aggregate, approximately \$1,192 per hour. The blended hourly rate for Paul Hastings' timekeepers who billed to the Debtor's chapter 11 cases during the Fee Period was approximately \$1,299 per hour. A detailed comparison of these rates follows:

Category of Timekeeper Blended Hourly Rate

Blended Hourly Rate Debtor Blended Hourly

All Timekeepers Aggregated \$1,192 \$1,299

1 It is the nature of Paul Hastings' practice that certain non-bankruptcy engagements require the advice and counsel of professionals and paraprofessionals who work primarily within Paul Hastings' restructuring group. Accordingly, Non-Bankruptcy Matters consist of matters for which Paul Hastings' timekeepers represented a client in matters other than court-approved engagements as counsel for the debtor, the chapter 11 trustee, or an official committee under the Bankruptcy Code. As such, the Non-Bankruptcy Matters include, in part, time billed by Paul Hastings' timekeepers who work primarily within Paul Hastings' restructuring group.

2 Luc A. Despins brings to the Title III Cases over 35 years of experience representing debtors and creditors in high profile and complex restructuring matters. Given the complexity and challenges faced by the Trustee in these cases, a significant amount of time by senior partners, of counsel, and senior associates, including Mr. Despins, Nicholas Bassett, Alexander Bongartz, Douglass Barron, and Shlomo Maza has been necessary. Because their rates are at the higher end of the range of rates billed by Paul Hastings partners, of counsel, and associates, respectively, and in light of the fact that a significant amount of senior partner, of counsel, and senior associate time has been required for this engagement, the blended rate for this case moved to the higher end of the range of rates billed by Paul Hastings. Finally, the blended attorney hourly rate for the Fee Period is not comparable to the average hourly rate in other matters because it does not reflect numerous cost-saving measures, including the delegation of a variety of matters to NPM, matters for which otherwise more junior Paul Hastings attorneys with lower hourly rates would have been used, thereby reducing Paul Hastings' blended hourly rate.

Summary of Timekeepers Included in this Application

Bassett, Nicholas Corporate, 2007 \$1,835.00 323.20 \$593,072.00 3 Bassett, Nicholas (travel; ½ rate) Corporate, 2007 \$967.50 13.30 \$12,577.75 3 Despins, Luc Restructuring, 1986 \$1,975.00 179.30 \$354,117.50 1 Despins, Luc (travel; ½ rate) Restructuring, 1986 \$987.50 2.40 \$2,370.00 1

Bongartz, Alex Restructuring, 2007 \$1,850.00 147.80 \$273,430.00 3 Luft, Avi Corporate, 2000 \$1,850.00 214.80 \$397,380.00 3 Luft, Avi (travel; ½ rate) Corporate, 2000 \$925.00 7.60 \$7,030.00 3 Traxler, Katherine Restructuring, 1990 \$1,120.00 10.70 \$11,984.00 3

Barron, Douglass Corporate, 2012 \$1,395.00 372.90 \$520,195.51 3 Catalano, Kristin Corporate, 2021 \$1,185.00 111.90 \$132,601.50 3 Chan, Alex Corporate, 2022 \$985.00 5.80 \$5,713.00 N/A Farmer, Will Corporate, 2018 \$1,390.00 88.90 \$123,571.00 3 Kim, Sarah Litigation, 2023 \$985.00 57.60 \$56,736.00 N/A Kosciewicz, Jon Litigation, 2021 \$1,185.00 268.90 \$318,646.50 3 Maza, Shlomo Corporate, 2012 \$1,395.00 185.60 \$258,912.00 3 Sadler, Tess Corporate, 2019 \$1,365.00 17.90 \$24,433.50 3 Song, Luyi Corporate, 2023 \$985.00 343.90 \$338,741.50 3 Song, Luyi (travel, bill at ½ rate) Corporate, 2023 \$492.50 9.20 \$4,531.00 3 Sutton, Ezra Corporate, 2021 \$1,270.00 338.00 \$429,260.00 3 Associate Total: 1,800.60 \$2,213,341.51

Kuo, Jocelyn Paralegal \$565.00 181.10 \$102,321.50 1 Mohamed, David Paralegal \$565.00 308.10 \$174,076.50 2 Paraprofessional Total: 489.20 \$276,398.00

Summary of Timekeepers Not Included in this Application1

Name Department; Date of First Admission Hourly

Axelrod, Peter Investigation & White Collar Defense, 1997 \$1,775.00 4.20 \$7,455.00 Dhamee, Yousuf Investment Funds and Private Capital, 2001 \$1,985.00 2.40 \$4,764.00 Potts, Helena Financial Restructuring, 2003 \$2,150.00 1.00 \$2,150.00

Jain, Maanas Complex Litigation & Arbitration, 2023 \$1,390.00 3.00 \$4,170.00

Langer, Bobbi Real Estate, 1984 \$1,065.00 0.80 \$852.00

Other Attorney Total:

Austin, Javii Legal Research Analyst \$420.00 3.60 \$1,512.00 Chang, Irene Legal Research Analyst \$420.00 2.10 \$882.00 Elliott, Elizabeth Legal Research Analyst \$420.00 0.80 \$336.00 Hopkovitz, Yael Legal Research Analyst \$475.00 1.50 \$712.50 Liu, Kelly Legal Research Analyst \$420.00 2.60 \$1,092.00 O'Dea, Heather Legal Research Analyst \$420.00 1.40 \$588.00 Reid, Alex Legal Research Analyst \$420.00 1.00 \$420.00 Paraprofessional Total: 13.00 \$5,542.50

1 As noted, as an accommodation to these estates, Paul Hastings is not seeking allowance or payment at this time for the fees of timekeepers who billed less than five (5) hours during the Fee Period in the aggregate amount of \$24,933.50. The time billed by these timekeepers was reasonable, and Paul Hastings reserves the right to seek allowance of these fees based on the facts and circumstances of these cases, including, without limitation, if objections are interposed to the allowance of Paul Hastings' fees and expenses.

Summary of Compensation by Project Category

U.S. Trustee Task Code and Project Category Hours

B110 Case Administration 87.10 \$80,187.50 B112 General Creditor Inquiries 0.40 \$603.50 B113 Pleadings Review 128.40 \$73,213.50 B120 Asset Analysis and Recovery 5.50 \$10,475.00 B130 Asset Disposition 9.80 \$11,909.50 B155 Court Hearings 104.60 \$168,084.50 B160 Employment / Fee Applications (Paul Hastings) 59.60 \$82,809.00 B165 Employment / Fee Applications (Other Professionals) 47.30 \$72,170.50 B191 General Litigation 2,071.60 \$2,770,703.01 B195 Non-Working Travel 32.50 \$26,508.75 B210 Business Operations 54.30 \$85,932.00 B211 Financial Reports (Monthly Operating Reports) 11.90 \$15,457.00

B261 Investigations 569.00 \$733,272.50 B310 Claims Administration and Objections 0.20 \$113.00

Representation \$116,925.75 \$140,347.00 \$105,922.50 \$363,195.25

Investigation and Litigation \$604,600.25 \$626,120.00 \$373,759.50 \$1,604,479.75 00003 Other Litigation \$57,079.00 \$24,653.50 \$21,947.50 \$103,680.00 00004 Corporate Law Issues \$0.00 \$0.00 \$0.00 \$0.00 00005 Sale Process \$1,819.00 \$0.00 \$0.00 \$1,819.00 00006 Tax Issues \$1,850.00 \$370.00 \$8,041.50 \$10,261.50 00007 Foreign Law Issues \$0.00 \$0.00 \$0.00 \$0.00 00008 Plan Process Issues \$0.00 \$0.00 \$0.00 \$0.00 00010 Genever US \$19,773.00 \$25,980.50 \$13,652.50 \$59,406.00 00011 Genever BVI \$0.00 \$0.00 \$0.00 \$0.00 00012 Mahwah Adversary \$258,813.25 \$0.00 \$1,675.50 \$260,488.75 00013 Golden Spring Adversary \$5,467.50 \$55,495.00 \$28,354.50 \$89,317.00 00014 HCHK Adversary \$52,618.00 \$30,037.50 \$30,941.50 \$113,597.00 00015 Interpleader Adversary \$0.00 \$0.00 \$0.00 \$0.00 00016 Mei Guo Adversary \$19,163.00 \$23,652.00 \$0.00 \$42,815.00 00017 HK USA Adversary \$113.00 \$0.00 \$0.00 \$113.00 00018 Bravo Luck Adversary \$0.00 \$0.00 \$0.00 \$0.00 00019 SN Apartment Adversary \$0.00 \$0.00 \$0.00 \$0.00 00020 Greenwich Land Adversary \$214,782.75 \$0.00 \$0.00 \$214,782.75 00022 PAX Adversary \$0.00 \$0.00 \$0.00 \$0.00 00024 Lamp Capital Adversary \$87,311.50 \$4,849.50 \$13,572.50 \$105,733.50 00026 Ace Decade Adversary \$13,464.00 \$66,779.50 \$22,729.00 \$102,972.50 00027 Defeng Cao Adversary \$7,129.50 \$23,141.00 \$45,535.50 \$75,806.00

Adversary \$74,707.06 \$285,956.00 \$23,425.00 \$384,088.06 00029 Avoidance Actions \$188,894.20 \$236,365.00 \$183,886.50 \$609,145.70 TOTAL \$1,724,510.76 \$1,543,746.50 \$873,443.50 \$4,141,700.76

Airfare (Nicholas Bassett) \$0.00 \$1,202.38 \$0.00 \$1,202.38 Articles and Publications \$0.00 \$1.20 \$0.00 \$1.20

Documents):

Metro Attorney Service \$1,723.40 \$1,670.50 \$8,740.25 \$12,134.15

Corporation \$0.00 \$520.00 \$1,400.00 \$1,920.00 Computer Search (Other) \$582.75 \$911.07 \$803.61 \$2,297.43

(Transcripts) \$7,663.15 \$1,130.00 \$0.00 \$8,793.15 Data Base Storage \$219.51 \$0.00 \$0.00 \$219.51 Filing Fee \$0.00 \$20.00 \$0.00 \$20.00 Lexis/On Line Search \$2,359.38 \$1,673.32 \$128.02 \$4,160.72 Local - Meals \$370.16 \$639.40 \$272.00 \$1,281.56 Local - Parking \$21.00 \$0.00 \$11.00 \$32.00 Local - Taxi \$64.24 \$80.05 \$80.84 \$225.13 Lodging \$0.00 \$576.14 \$0.00 \$576.14 Messenger \$749.00 \$0.00 \$0.00 \$749.00 Outside Professional Services:

Solutions \$2,575.75 \$220.00 \$0.00 \$2,795.75

UnitedLex \$112,083.36 \$31,908.21 \$0.00 \$143,991.57

Inc. \$10,247.80 \$0.00 \$0.00 \$10,247.80

Other \$1,685.00 \$0.00 \$2,320.00 \$4,005.00 Postage/Express Mail \$11,874.06 \$2,636.64 \$5,492.93 \$20,003.63 Reproduction Charges \$14,630.88 \$1,389.12 \$7,334.32 \$23,354.32 Reproduction Charges (Color) \$1,917.40 \$31.80 \$24.00 \$1,973.20 Retrieval of Corporate Documents:

TransUnion Risk \$70.00 \$10.00 \$130.00 \$210.00

Other \$0.00 \$0.00 \$206.25 \$206.25 Search Fees \$0.00 \$97.56 \$0.00 \$97.56 Taxi/Ground Transportation \$949.01 \$942.03 \$24.79 \$1,915.83 Travel Expense - Meals \$0.00 \$134.48 \$0.00 \$134.48 UPS/Courier Service \$408.72 \$244.66 \$148.60 \$801.98 Vendor Expense \$1,618.07 \$585.50 \$396.31 \$2,599.88 Westlaw \$7,086.09 \$6,111.61 \$3,486.51 \$16,684.21 TOTAL \$178,898.73 \$52,735.67 \$30,999.43 \$262,633.83

Luc Despins as Chapter 11 Trustee in thecase of Ho Wan Kwok 200 Park Avenue New York, NY 10166 May 9, 2024 Please Refer to Invoice Number: 2395791

Attn: Luc Despins PH LLP Tax ID No. 95-2209675

General Chapter 11 Trustee Representation

PH LLP Client/Matter # 50687-00001 Luc A. Despins

Legal fees for professional services for the period ending January 31, 2024 \$116,925.75

We encourage our clients to pay via ACH, however, in the event that you pay by check, please send payment to the remittance address below:

*TO PROTECT AGAINST FRAUD, the Firm will not change its wiring instructions via email. We strongly encourage clients to confirm any change in wiring instructions by contacting Teri Goffredo @ 213-683-5045 or via email @ terigoffredo@paulhastings.com and requesting written and verbal confirmation.*

Wiring and ACH Instructions: Remittance Address: Pay by Tranch:

Citibank Paul Hastings LLP You can now pay your invoices online via ABA # 322271724 Lockbox 4803 real-time bank payments, credit cards or SWIFT Address: CITIUS33 PO Box 894803 in installments:

*For wires, please reference the invoice, client and matter number(s) being paid For ACH payments, please use the CTX format and/or send any remittances to cashepn@paulhastings com This is a no-reply mailbox*

Luc Despins as Chapter 11 Trustee in thecase of Ho Wan Kwok 200 Park Avenue New York, NY 10166 May 9, 2024 Please Refer to Invoice Number: 2395791

Attn: Luc Despins PH LLP Tax ID No. 95-2209675

General Chapter 11 Trustee Representation

PH LLP Client/Matter # 50687-00001 Luc A. Despins

Legal fees for professional services for the period ending January 31, 2024 \$116,925.75

We encourage our clients to pay via ACH, however, in the event that you pay by check, please send payment to the remittance address below:

*TO PROTECT AGAINST FRAUD, the Firm will not change its wiring instructions via email. We strongly encourage clients to confirm any change in wiring instructions by contacting Teri Goffredo @ 213-683-5045 or via email @ terigoffredo@paulhastings.com and requesting written and verbal confirmation.*

Wiring and ACH Instructions: Remittance Address: Pay by Tranch:

Citibank Paul Hastings LLP You can now pay your invoices online via ABA # 322271724 Lockbox 4803 real-time bank payments, credit cards or SWIFT Address: CITIUS33 PO Box 894803 in installments:

*For wires, please reference the invoice, client and matter number(s) being paid For ACH payments, please use the CTX format and/or send any remittances to cashepn@paulhastings com This is a no-reply mailbox*

Case 22-50073 Doc 3283 Filed 06/24/24 Entered 06/24/24 18:35:48 Page 74 of 562

PAUL HASTINGS LLP 200 Park Avenue, New York, NY 10166-3205 t: +1.212.318.6000 f: +1.212.319.4090 www.paulhastings.com

Luc Despins as Chapter 11 Trustee in thecase of Ho Wan May 9, 2024

New York, NY 10166 Invoice Number: 2395791

Attn: Luc Despins PH LLP Tax ID No. 95-2209675

FOR PROFESSIONAL SERVICES RENDERED for the period ending January 31, 2024 General Chapter 11 Trustee Representation \$116,925.75

Date Initials Description Hours Rate Amount

01/02/2024 AB21 Update call with L. Despins, N. Bassett, S. Maza, A. Luft, D. Barron, L. Song, J.

strategy, open issues, and next steps 0.80 1,850.00 1,480.00 01/02/2024 DM26 Update critical dates calendar and send

filing deadlines and update working group

01/02/2024 DEB4 Conference with L. Despins, N. Bassett, A. Bongartz, S. Maza, A. Luft, E. Sutton, L.

01/02/2024 ECS1 Call with L. Despins, N. Bassett, A. Bongartz, A. Luft, D. Barron, S. Maza, L.

matters in the case 0.80 1,270.00 1,016.00

Case 22-50073 Doc 3283 Filed 06/24/24 Entered 06/24/24 18:35:48 Page 75 of 562

Luc Despins as Chapter 11 Trustee in thecase of Ho Wan Kwok 50687-00001 Invoice No. 2395791

Date Initials Description Hours Rate Amount

01/02/2024 JPK1 Attend teleconference with L. Despins, N. Bassett, A. Bongartz, A. Luft, D. Barron, S.

15, 2024 filing deadline 0.80 1,185.00 948.00 01/02/2024 LAD4 All hands call (N. Bassett, A. Bongartz, D. Barron, A. Luft, L. Song, S. Maza, J.

01/02/2024 AEL2 Meeting with L. Despins, N. Bassett, A. Bongartz, D. Barron, S. Maza, L. Song, E. Sutton, and J. Kosciewicz re: pending and upcoming case matters 0.80 1,850.00 1,480.00 01/02/2024 LS26 Call with L. Despins, N. Bassett, A. Bongartz, A. Luft, S. Maza, D. Barron, E.

matters and upcoming issues/tasks 0.80 985.00 788.00 01/02/2024 NAB Call with L. Despins, A. Bongartz, S. Maza, A. Luft, D. Barron, L. Song, J. Kosciewicz,

and case strategy issues 0.80 1,835.00 1,468.00 01/02/2024 NAB Attend portion of call with L. Despins, D. Barron, S. Maza, A. Luft, P. Linsey (NPM) regarding litigation strategy 0.40 1,835.00 734.00 01/02/2024 SM29 Call with L. Despins, N. Bassett, A. Bongartz, D. Barron, A. Luft, E. Sutton, L.

01/03/2024 DM26 Update critical dates calendar and send

filing deadlines and update working group

01/03/2024 LAD4 T/c S. Sarnoff (OMM) re: update

01/04/2024 DM26 Update critical dates calendar and send

filing deadlines and update working group

Case 22-50073 Doc 3283 Filed 06/24/24 Entered 06/24/24 18:35:48 Page 76 of 562

Luc Despins as Chapter 11 Trustee in thecase of Ho Wan Kwok 50687-00001 Invoice No. 2395791

Date Initials Description Hours Rate Amount

01/05/2024 DM26 Update critical dates calendar and

filing deadlines and update working group

01/08/2024 DM26 Update critical dates calendar and send

filing deadlines and update working group

01/09/2024 DM26 Update critical dates calendar and send

filing deadlines and update working group

adversary proceeding (.8); correspond with A. Bongartz re same (.1) 1.70 565.00 960.50 01/10/2024 AB21 Correspond with L. Despins regarding various open workstreams and case matters 0.20 1,850.00 370.00 01/10/2024 DM26 Update critical dates calendar and send

filing deadlines and update working group re same (.2); revise notices of appearance

01/11/2024 DM26 Update critical dates calendar and send

filing deadlines and update working group

01/12/2024 DM26 Update critical dates calendar and send

filing deadlines and update working group

01/15/2024 NAB Correspond with P. Linsey (NPM) and A.

01/16/2024 AB21 Update call with L. Despins, A. Luft, N.

K. Catalano, E. Sutton, L. Song, J. Kosciewicz regarding case and litigation strategy 1.00 1,850.00 1,850.00

Case 22-50073 Doc 3283 Filed 06/24/24 Entered 06/24/24 18:35:48 Page 77 of 562

Luc Despins as Chapter 11 Trustee in thecase of Ho Wan Kwok 50687-00001 Invoice No. 2395791

Date Initials Description Hours Rate Amount

01/16/2024 DM26 Update critical dates calendar and send

filing deadlines and update working group

01/16/2024 DEB4 Call with L. Despins, A. Bongartz, S. Maza, N. Bassett, A. Luft, W. Farmer, K. Catalano, L. Song, E. Sutton and J.

February 15 deadline 1.00 1,395.00 1,395.00 01/16/2024 ECS1 Call with L. Despins, N. Bassett, A. Bongartz, A. Luft, S. Maza, D. Barron, W. Farmer, K. Catalano, L. Song, J. Kosciewicz

and upcoming deadlines 1.00 1,270.00 1,270.00 01/16/2024 JPK1 Attend teleconference with L. Despins, A. Bongartz, S. Maza, A. Luft, N. Bassett, D. Barron, W. Farmer, K. Catalano, E. Sutton, L. Song regarding February 15, 2024 filing

01/16/2024 KC27 Attend meeting with L. Despins, N. Bassett,

S. Maza, D. Barron, A. Luft, L. Song, E. Sutton, W. Farmer, J. Kosciewicz regarding case updates and plan 1.00 1,185.00 1,185.00 01/16/2024 LAD4 Review issues and prepare notes for PH update call (.30); handle update call with A. Luft, N. Bassett, S. Maza, A. Bongartz, D. Barron, W. Farmer, L. Song, E. Sutton, K. Catalano, J. Kosciewicz (1.00); t/c N. Bassett re: case issues and management (.20) 1.50 1,975.00 2,962.50 01/16/2024 AEL2 Call with L. Despins, N. Bassett, A. Bongartz, S. Maza, D. Barron, K. Catalano, L. Song, E. Sutton, W. Farmer, J.

Case 22-50073 Doc 3283 Filed 06/24/24 Entered 06/24/24 18:35:48 Page 78 of 562

Luc Despins as Chapter 11 Trustee in thecase of Ho Wan Kwok 50687-00001 Invoice No. 2395791

Date Initials Description Hours Rate Amount

01/16/2024 LS26 Case update call with L. Despins, N. Bassett, A. Bongartz, A. Luft, S. Maza, D. Barron, W. Farmer, K. Catalano, E. Sutton,

deadlines and action items 1.00 985.00 985.00 01/16/2024 NAB Call with L. Despins, A. Bongartz, S. Maza, D. Barron, K. Catalano, W. Farmer, L. Song, E. Sutton, J. Kosciewicz, A. Luft, P. Linsey regarding case deadlines and issues,

(1.0); call with L. Despins regarding case plan and direction (.2) 1.20 1,835.00 2,202.00 01/16/2024 SM29 Call with A. Bongartz, A. Luft, N. Bassett, L. Despins, D. Barron, W. Farmer, L. Song,

01/16/2024 WCF Call with L. Despins, N. Bassett, A. Bongartz, D. Barron, A. Luft, S. Maza, K. Catalano, L. Song, J. Kosciewicz, E. Sutton

related issues/task list 1.00 1,390.00 1,390.00 01/17/2024 DM26 Update critical dates calendar and send

filing deadlines and update working group

01/17/2024 NAB Correspond with L. Despins regarding case

01/18/2024 AB21 Update list of open issues and workstreams 0.20 1,850.00 370.00

filing deadlines and update working group

01/19/2024 DM26 Update critical dates calendar and send

filing deadlines and update working group

Case 22-50073 Doc 3283 Filed 06/24/24 Entered 06/24/24 18:35:48 Page 79 of 562

Luc Despins as Chapter 11 Trustee in thecase of Ho Wan Kwok 50687-00001 Invoice No. 2395791

Date Initials Description Hours Rate Amount 01/22/2024 DM26 Update critical dates calendar and send outlook reminders (.6); review upcoming filing deadlines and update working group re same (.2) 0.80 565.00 452.00 01/23/2024 DM26 Update critical dates calendar and send outlook reminders (.8); review upcoming filing deadlines and update working group re same (.2) 1.00 565.00 565.00 01/24/2024 DM26 Update critical dates calendar and send outlook reminders (.4); review upcoming filing deadlines and update working group re same (.2) 0.60 565.00 339.00 01/25/2024 AB21 Update list of open issues and workstreams 0.20 1,850.00 370.00 01/25/2024 DM26 Update critical dates calendar and send outlook reminders (.5); review upcoming filing deadlines and update working group re same (.2) 0.70 565.00 395.50 01/25/2024 LAD4 T/c C. Callari (Ru Ma counsel) re: update on case 0.60 1,975.00 1,185.00 01/26/2024 DM26 Update critical dates calendar and send outlook reminders (.3); review upcoming filing deadlines and update working group re same (.2) 0.50 565.00 282.50 01/29/2024 DM26 Update critical dates calendar and send outlook reminders (.7); review upcoming filings and update working group re same (.2) 0.90 565.00 508.50 01/30/2024 DM26 Update critical dates calendar and send outlook reminders (.4); review upcoming filings and update working group re same (.2) 0.60 565.00 339.00 01/31/2024 DM26 Update critical dates calendar and send outlook reminders (.3); review upcoming filings and update working group re same (.2) 0.50 565.00 282.50

Subtotal: B110 Case Administration 39.10 43,144.50

Case 22-50073 Doc 3283 Filed 06/24/24 Entered 06/24/24 18:35:48 Page 80 of 562

Date Initials Description Hours Rate Amount

01/02/2024 DM26 Review recent filings in Kwok case no. 22-

(.5); review recent filings and exhibits in certain adversary proceedings and district

regarding recent filings (.4) 2.20 565.00 1,243.00 01/03/2024 DM26 Review recent filings in Kwok case no. 22-

(1.1); review related case dockets regarding recent filings (.5); research regarding certain

01/04/2024 DM26 Review recent filings in Kwok case no. 22-

(.6); review related case dockets regarding recent filings (.5) 1.60 565.00 904.00 01/05/2024 DM26 Review recent filings in Kwok case no. 22-

(.8); review related case dockets regarding recent filings (.4) 1.60 565.00 904.00 01/08/2024 DM26 Review recent filings in Kwok case no. 22-

(.5); review related case dockets regarding recent filings (.4) 1.40 565.00 791.00

Case 22-50073 Doc 3283 Filed 06/24/24 Entered 06/24/24 18:35:48 Page 81 of 562

Luc Despins as Chapter 11 Trustee in thecase of Ho Wan Kwok 50687-00001 Invoice No. 2395791

Date Initials Description Hours Rate Amount 01/09/2024 DM26 Review recent filings in Kwok case no. 22- 50073 and update working group re same (.4); review recent filings in certain adversary proceedings and district court cases and update working group re same (.6); review related case dockets regarding recent filings (.5) 1.50 565.00 847.50 01/10/2024 DM26 Review recent filings in Kwok case no. 22- 50073 and update working group re same (.6); review recent filings in certain adversary proceedings and district court cases and update working group re same (.7); review related case dockets regarding recent filings (.4); research certain case documents per attorney request (.2) 1.90 565.00 1,073.50 01/11/2024 DM26 Review recent filings in Kwok case no. 22- 50073 and update working group re same (.4); review recent filings in certain adversary proceedings and district court cases and update working group re same (.3); review related case dockets regarding recent filings (.4) 1.10 565.00 621.50 01/12/2024 DM26 Review recent filings in Kwok case no. 22- 50073 and update working group re same (.5); review recent filings in certain adversary proceedings and district court cases and update working group re same (.9); review related case dockets regarding recent filings (.4) 1.80 565.00 1,017.00 01/16/2024 DM26 Review recent filings in Kwok case no. 22- 50073 and update working group re same (.5); review recent filings in certain adversary proceedings and district court cases and update working group re same (.7); review related case dockets regarding recent filings (.4); research certain case documents per attorney request (.3) 1.90 565.00 1,073.50 Case 22-50073 Doc 3283 Filed 06/24/24 Entered 06/24/24 18:35:48 Page 82 of 562

Luc Despins as Chapter 11 Trustee in thecase of Ho Wan Kwok 50687-00001 Invoice No. 2395791

Date Initials Description Hours Rate Amount

01/17/2024 DM26 Review recent filings in Kwok case no. 22-

dockets regarding recent filings (.4) 1.10 565.00 621.50 01/18/2024 DM26 Review recent filings in Kwok case no. 22-

dockets regarding recent filings (.5) 1.40 565.00 791.00 01/19/2024 DM26 Review recent filings in Kwok case no. 22-

(.7); review related case dockets regarding recent filings (.4) 1.70 565.00 960.50 01/22/2024 DM26 Review recent filings in Kwok case no. 22-

(1.2); review related case dockets regarding recent filings (.4) 1.90 565.00 1,073.50 01/23/2024 DM26 Review recent filings in Kwok case no. 22-

dockets regarding recent filings (.5) 1.40 565.00 791.00 01/24/2024 DM26 Review recent filings in Kwok

dockets regarding recent filings (.5) 1.60 565.00 904.00

Case 22-50073 Doc 3283 Filed 06/24/24 Entered 06/24/24 18:35:48 Page 83 of 562

Luc Despins as Chapter 11 Trustee in thecase of Ho Wan Kwok 50687-00001 Invoice No. 2395791

Date Initials Description Hours Rate Amount

01/25/2024 DM26 Review recent filings in Kwok case no. 22-

working group re same (.4); review related case dockets regarding recent filings (.5) 1.20 565.00 678.00 01/26/2024 DM26 Review recent filings in Kwok case no. 22-

(.3); review related case dockets regarding recent filings (.5) 1.30 565.00 734.50 01/29/2024 DM26 Review recent filings in Kwok case no. 22-

(.7); review related case dockets regarding recent filings (.4) 1.70 565.00 960.50 01/30/2024 DM26 Review recent filings in Kwok case no. 22-

(.5); review related case dockets regarding recent filings (.5) 1.00 565.00 565.00 01/31/2024 DM26 Review recent filings in Kwok case no. 22-

(.3); review related case dockets regarding

documents per attorney request (.4); email D. Cairns, E. Sutton regarding Hofmeister's state court actions (.1) 1.70 565.00 960.50 Subtotal: B113 Pleadings Review 33.70 19,040.50

Case 22-50073 Doc 3283 Filed 06/24/24 Entered 06/24/24 18:35:48 Page 84 of 562

Date Initials Description Hours Rate Amount

01/10/2024 LAD4 Review submissions and notes to prepare for court status conference (.50); handle court status conference (.20) 0.70 1,975.00 1,382.50 01/14/2024 DM26 Prepare agenda for 1/16/24 hearing 0.50 565.00 282.50 01/19/2024 DM26 Prepare agenda for 1/23/24 hearing 1.00 565.00 565.00 01/23/2024 AB21 Prepare hearing notes for hearing on Pallas fee application (0.3); call and correspond with L. Despins regarding same (0.1); revise

H. Claiborn (U.S. Trustee) regarding same

regarding same (0.1) 0.80 1,850.00 1,480.00 01/23/2024 LAD4 Review issues and prepare notes for court hearing (.20); handle court hearing (zoom)

Subtotal: B155 Court Hearings 5.70 9,042.50

01/02/2024 AB21 Correspond with L. Despins regarding PH October fee statement (0.1); call with C.

fee statements (0.1) 0.20 1,850.00 370.00 01/16/2024 KAT2 Prepare parts of fourth interim fee application (1.3); correspond with C. Edge regarding information for same (.2) 1.50 1,120.00 1,680.00 01/18/2024 AB21 Call and correspond with L. Despins regarding PH fee statements 0.10 1,850.00 185.00 01/19/2024 AB21 Review PH November fee statement 0.30 1,850.00 555.00 01/20/2024 AB21 Continue reviewing PH November fee 1.00 1,850.00 1,850.00

statement 01/25/2024 AB21 Correspond with L. Despins regarding PH October fee statement 0.10 1,850.00 185.00

Date Initials Description Hours Rate Amount

01/25/2024 KAT2 Prepare parts of fourth interim fee application (.6); correspond with C. Edge regarding information for same (.1) 0.70 1,120.00 784.00 01/26/2024 KAT2 Prepare parts of fourth interim fee

01/27/2024 KAT2 Prepare parts of fourth interim fee

01/28/2024 AB21 Review PH November fee statement (0.3);

01/29/2024 KAT2 Prepare parts of fourth interim fee application (1.6); correspond with A. Bongartz regarding same (.1) 1.70 1,120.00 1,904.00 Subtotal: B160 Fee/Employment Applications 7.90 10,381.00 B165 Fee/Employment Applications for Other Professionals

01/02/2024 AB21 Correspond with A. Thorp (Harneys Legal) regarding parties in interest list 0.10 1,850.00 185.00

01/08/2024 AB21 Correspond with A. de Quincey regarding

01/08/2024 ECS1 Review supplemental declaration of Pallas Partners (.1); correspond with A. Bongartz regarding same (.1) 0.20 1,270.00 254.00 01/09/2024 AB21 Correspond with A. de Quincey (Pallas) regarding U.S. Trustee comments on Pallas fee application (0.1); correspond with H. Claiborn (U.S. Trustee) regarding same (0.1) 0.20 1,850.00 370.00 01/09/2024 ECS1 Prepare Pallas supplemental declaration of disinterestedness (.4); correspond with A.

regarding same (.2) 0.60 1,270.00 762.00

Date Initials Description Hours Rate Amount

01/09/2024 LAD4 T/c H. Claiborn (UST) re: update on fee issues (.20); t/c S. Sarnoff (OMM) re: same

01/10/2024 LAD4 Review issues re: Swiss counsel retention 0.70 1,975.00 1,382.50 01/15/2024 LAD4 T/c D. Hayek (potential Swiss counsel) re: potential retention 0.70 1,975.00 1,382.50 01/16/2024 AB21 Revise Prager Dreifuss engagement letter (0.5); correspond with L. Despins regarding

interim compensation procedures (0.6) 1.30 1,850.00 2,405.00 01/16/2024 AB21 Call with P. Linsey (NPM) regarding fee application of Paul Wright (0.2); correspond with P. Linsey regarding same (0.1) 0.30 1,850.00 555.00 01/16/2024 JK21 Correspond with A. Bongartz regarding

Partners' fifth invoice (0.1); prepare for electronic filing notice of filing of Acheson Doyle Partners' fifth invoice (0.1); electronically file with the court notice of

invoice (0.1); review and handle service of notice of filing of Acheson Doyle Partners' fifth invoice (0.2) 0.50 565.00 282.50 01/16/2024 LAD4 T/c H. Claiborn (UST) re: update on retention of counsel etc. 0.20 1,975.00 395.00 01/17/2024 AB21 Call with D. Hayek (Prager Dreifuss)

Prager engagement letter (0.2); call with L.

with L. Despins regarding same (0.2);

01/17/2024 LAD4 T/c A. Bongartz re: Swiss counsel retention 0.20 1,975.00 395.00 01/19/2024 AB21 Correspond with L. Despins regarding Prager engagement letter (0.1); correspond with D. Hayek (Prager) regarding same (0.1) 0.20 1,850.00 370.00

Case 22-50073 Doc 3283 Filed 06/24/24 Entered 06/24/24 18:35:48 Page 87 of 562

Luc Despins as Chapter 11 Trustee in thecase of Ho Wan Kwok 50687-00001 Invoice No. 2395791

Subtotal: B165 Fee/Employment Applications for 12.20 19,555.00

01/30/2024 ECS1 Call with A. Bongartz regarding preparation of professional fee applications 0.20 1,270.00 254.00 01/30/2024 ECS1 Correspond with A. Bongartz regarding Paul Wright invoices 0.10 1,270.00 127.00 01/30/2024 AB21 Review NPM December fee statement 0.50 1,850.00 925.00 01/30/2024 AB21 Call with E. Sutton regarding upcoming interim fee applications 0.20 1,850.00 370.00 01/25/2024 JK21 Correspond with A. Bongartz regarding filing of Pallas supplemental declaration (0.1); electronically file with the court Pallas supplemental declaration (0.1) 0.20 565.00 113.00 01/25/2024 AB21 Correspond with L. Despins regarding Pallas supplemental declaration in support of retention (0.2); correspond with J. Kuo regarding filing and service of same (0.1) 0.30 1,850.00 555.00 01/24/2024 AB21 Correspond with T. Sadler regarding payment of Pallas fees 0.10 1,850.00 185.00 01/23/2024 JK21 Correspond with A. Bongartz regarding filing of Kroll December 2023 monthly fee

2023 monthly fee statement for filing (0.1);

monthly fee statement (0.1) 0.30 565.00 169.50 01/23/2024 AB21 Prepare cover notice for Kroll fee statement (0.1); review Kroll fee statement (0.1);

regarding same (0.1); correspond with J.

01/20/2024 ECS1 Prepare retention application for Prager Dreifuss AG as Swiss counsel 0.10 1,270.00 127.00 01/19/2024 ECS1 Prepare retention application for Prager Dreifuss AG as Swiss counsel (2.1);

Date Initials Description Hours Rate Amount Case 22-50073 Doc 3283 Filed 06/24/24 Entered 06/24/24 18:35:48 Page 88 of 562

Date Initials Description Hours Rate Amount

01/09/2024 NAB Non-working travel from Washington, DC

Connecticut to New York (bill at 1/2 rate) 2.60 967.50 2,515.50 01/11/2024 NAB Return travel from New York to Washington, DC (bill at 1/2 rate) 2.00 967.50 1,935.00 01/23/2024 NAB Non-working travel to/from Washington, DC and Bridgeport (bill at 1/2 rate) 2.90 967.50 2,805.75 Subtotal: B195 Non-Working Travel 7.50 7,256.25

01/12/2024 AB21 Correspond with T. Sadler regarding wire transfer to NPM (0.1); call with P. Linsey (NPM) regarding same (0.1) 0.20 1,850.00 370.00

01/16/2024 AB21 Correspond with T. Sadler regarding wire transfers for outstanding invoices 0.20 1,850.00 370.00 01/16/2024 TS21 Correspond with A. Bongartz re Sherry

transfer forms for professional fees (.8); correspond with East West Bank, L. Despins, and A. Bongartz re same (.3) 1.70 1,365.00 2,320.50 01/24/2024 TS21 Prepare wire transfer forms for Edmiston

Subtotal: B210 Business Operations 2.60 3,743.00 B211 Financial Reports (Monthly Operating Reports)

01/17/2024 DEB4 Correspond with T. Sadler regarding MOR 0.10 1,395.00 139.50

Date Initials Description Hours Rate Amount

01/18/2024 TS21 Correspond with East West bank regarding

01/19/2024 DEB4 Correspond with T. Sadler regarding MOR 0.10 1,395.00 139.50 01/19/2024 TS21 Prepare December monthly operating report (2.3); correspond with D. Barron re

01/22/2024 DM26 File monthly operating report for month ended 12/31/23 on behalf of Trustee 0.20 565.00 113.00 01/22/2024 DEB4 Correspond with T. Sadler regarding MOR 0.10 1,395.00 139.50 01/22/2024 TS21 Correspond with D. Barron, L. Despins and

Subtotal: B211 Financial Reports (Monthly

ID Timekeeper Name Title Hours Rate Fee

LAD4 Luc A. Despins Partner 9.10 1,975.00 17,972.50 NAB Nicholas A. Bassett Partner 2.70 1,835.00 4,954.50 NAB Nicholas A. Bassett Partner 7.50 967.50 7,256.25 AB21 Alex Bongartz Of Counsel 11.00 1,850.00 20,350.00 AEL2 Luft, Avi E. Of Counsel 1.80 1,850.00 3,330.00 KAT2 Katherine A. Traxler Of Counsel 5.80 1,120.00 6,496.00 SM29 Shlomo Maza Associate 1.80 1,395.00 2,511.00 DEB4 Douglass E. Barron Associate 2.10 1,395.00 2,929.50 WCF Will C. Farmer Associate 1.00 1,390.00 1,390.00 TS21 Tess Sadler Associate 5.30 1,365.00 7,234.50 ECS1 Ezra C. Sutton Associate 5.30 1,270.00 6,731.00 JPK1 Jon P. Kosciewicz Associate 1.80 1,185.00 2,133.00

KC27 Kristin Catalano Associate 1.00 1,185.00 1,185.00

LS26 Luyi Song Associate 1.80 985.00 1,773.00 JK21 Jocelyn Kuo Paralegal 1.00 565.00 565.00 DM26 David Mohamed Paralegal 53.30 565.00 30,114.50

Date Description Quantity Rate Amount

01/02/2024 Photocopy Charges 125.00 0.08 10.00 01/04/2024 Photocopy Charges 1,325.00 0.08 106.00 01/08/2024 Photocopy Charges 1,300.00 0.08 104.00 01/09/2024 Photocopy Charges 1,825.00 0.08 146.00 01/10/2024 Photocopy Charges 36,500.00 0.08 2,920.00 01/11/2024 Photocopy Charges 1,136.00 0.08 90.88

01/17/2024 Photocopy Charges 66.00 0.08 5.28 01/18/2024 Photocopy Charges 32.00 0.08 2.56 01/18/2024 Photocopy Charges 3,925.00 0.08 314.00 01/19/2024 Photocopy Charges 42.00 0.08 3.36 01/22/2024 Photocopy Charges 48.00 0.08 3.84 01/22/2024 Photocopy Charges 83,538.00 0.08 6,683.04 01/22/2024 Photocopy Charges 11,016.00 0.08 881.28 01/23/2024 Photocopy Charges 27,690.00 0.08 2,215.20 01/25/2024 Photocopy Charges 2,672.00 0.08 213.76 01/26/2024 Photocopy Charges 500.00 0.08 40.00

Inc. (USD) (JPMSUA); Invoice # 6070406 dated 07/31/2023; Service Type: Car; From/To: Office/Home; Passenger DAVID, Mohamed; Ticket # 196853 dated 07/13/2023 00:00 57.67

01/02/2024 Computer Search (Other) 36.18

01/02/2024 Computer Search (Other) 47.88

01/03/2024 Computer Search (Other) 14.13 01/03/2024 Computer Search (Other) 7.47

01/04/2024 Computer Search (Other) 19.53 01/04/2024 Computer Search (Other) 20.34 01/05/2024 Computer Search (Other) 10.08 01/05/2024 Computer Search (Other) 6.48 01/07/2024 Computer Search (Other) 0.90

01/08/2024 Computer Search (Other) 12.87 01/08/2024 Computer Search (Other) 17.10

01/09/2024 Computer Search (Other) 6.57 01/09/2024 Computer Search (Other) 8.82

01/10/2024 Computer Search (Other) 3.78 01/10/2024 Computer Search (Other) 9.45

Case 22-50073 Doc 3283 Filed 06/24/24 Entered 06/24/24 18:35:48 Page 92 of 562

Luc Despins as Chapter 11 Trustee in thecase of Ho Wan Kwok 50687-00001 Invoice No. 2395791

01/11/2024 Computer Search (Other) 7.11

01/12/2024 Computer Search (Other) 5.76

01/16/2024 Computer Search (Other) 8.01 01/16/2024 Computer Search (Other) 9.63

01/17/2024 Computer Search (Other) 6.93 01/17/2024 Computer Search (Other) 9.81

01/18/2024 Computer Search (Other) 10.35 01/18/2024 Computer Search (Other) 17.73

01/19/2024 Computer Search (Other) 14.22 01/19/2024 Computer Search (Other) 7.47

01/22/2024 Computer Search (Other) 3.42

01/23/2024 Computer Search (Other) 27.27

01/24/2024 Computer Search (Other) 7.56 01/24/2024 Computer Search (Other) 8.01

UPS (USD)(JPMPCARD); Invoice # 00000A6T163044; 01/25/2024; ;

UPS (USD)(JPMPCARD); Invoice # 00000A6T163044; 01/25/2024; ; Mountains of Spices LLC; 40 Brompton Road; GREAT NECK, NY 110213429 ;

Case 22-50073 Doc 3283 Filed 06/24/24 Entered 06/24/24 18:35:48 Page 94 of 562

Luc Despins as Chapter 11 Trustee in thecase of Ho Wan Page 21

UPS (USD)(JPMPCARD); Invoice # 00000A6T163044; 01/25/2024; ; JISEN

UPS (USD)(JPMPCARD); Invoice # 00000A6T163044; 01/25/2024; ;

UPS (USD)(JPMPCARD); Invoice # 00000A6T163044; 01/25/2024; ;

UPS (USD)(JPMPCARD); Invoice # 00000A6T163044; 01/25/2024; ; SEAN

070201461 ; 1ZA6T1630193126281 (MAN) 18.54

UPS (USD)(JPMPCARD); Invoice # 00000A6T163044; 01/25/2024; ; HGA Property Operation LLC; 3655 Meadow LN; NORTH BERGEN, NJ 070472343 ;

UPS (USD)(JPMPCARD); Invoice # 00000A6T163044; 01/25/2024; ;

UPS (USD)(JPMPCARD); Invoice # 00000A6T163044; 01/25/2024; ; Aviation Trust Company, LLC; 4800 N Lincoln Blvd; OKLAHOMA CITY, OK 731053321 ;

UPS (USD)(JPMPCARD); Invoice # 00000A6T163044; 01/25/2024; ; Aviation Trust Company, LLC; 4800 N Lincoln Blvd; OKLAHOMA CITY, OK 73105 ;

Total Costs incurred and advanced \$26,975.24

David Mohamed; 01/26/2024; Mailing of Tolling Motion to various service parties (FCM & Registered Mail) for processing; Merchant: Usps po 3596100010 999.32

David Mohamed; 01/26/2024; Mailing of Tolling Motion to various service parties (FCM & Registered Mail) for processing; Merchant: Usps po 3596100010 897.85

David Mohamed; 01/26/2024; Mailing of Tolling Motion to various service parties (FCM & Registered Mail) for processing; Merchant: Usps po 3596100010 365.45

David Mohamed; 01/26/2024; Mailing of Tolling Motion to various service parties (FCM & Registered Mail) for processing; Merchant: Usps po 3596100010 1,535.44

David Mohamed; 01/26/2024; Mailing of Tolling Motion to various service parties (FCM & Registered Mail) for processing; Merchant: Usps po 3596100010 1,074.60 01/30/2024 Computer Search (Other) 9.36 01/29/2024 Computer Search (Other) 7.65 01/27/2024 Computer Search (Other) 8.10 01/26/2024 Computer Search (Other) 10.71

01/25/2024 Computer Search (Other) 7.11 01/25/2024 Computer Search (Other) 11.07

Luc Despins as Chapter 11 Trustee in the case of Ho Wan Kwok 200 Park Avenue New York, NY 10166

Attn: Luc Despins PH LLP Tax ID No. 95-2209675

Asset Recovery Investigation and Litigation

PH LLP Client/Matter # 50687-00002 Luc A. Despins

Legal fees for professional services for the period ending January 31, 2024 \$611,886.25

We encourage our clients to pay via ACH, however, in the event that you pay by check, please send payment to the remittance address below:

*TO PROTECT AGAINST FRAUD, the Firm will not change its wiring instructions via email. We strongly encourage clients to confirm any change in wiring instructions by contacting Teri Goffredo @ 213-683-5045 or via email @ terigoffredo@paulhastings.com and requesting written and verbal confirmation.*

Wiring and ACH Instructions: Remittance Address: Pay by Tranch:

Citibank Paul Hastings LLP You can now pay your invoices online via ABA # 322271724 Lockbox 4803 real-time bank payments, credit cards or SWIFT Address: CITIUS33 PO Box 894803 in installments:

*For wires, please reference the invoice, client and matter number(s) being paid For ACH payments, please use the CTX format and/or send any remittances to cashepn@paulhastings com This is a no-reply mailbox*

Luc Despins as Chapter 11 Trustee in the case of Ho Wan Kwok 200 Park Avenue New York, NY 10166

Attn: Luc Despins PH LLP Tax ID No. 95-2209675

Asset Recovery Investigation and Litigation

PH LLP Client/Matter # 50687-00002 Luc A. Despins

Legal fees for professional services for the period ending January 31, 2024 \$611,886.25

We encourage our clients to pay via ACH, however, in the event that you pay by check, please send payment to the remittance address below:

*TO PROTECT AGAINST FRAUD, the Firm will not change its wiring instructions via email. We strongly encourage clients to confirm any change in wiring instructions by contacting Teri Goffredo @ 213-683-5045 or via email @ terigoffredo@paulhastings.com and requesting written and verbal confirmation.*

Wiring and ACH Instructions: Remittance Address: Pay by Tranch:

Citibank Paul Hastings LLP You can now pay your invoices online via ABA # 322271724 Lockbox 4803 real-time bank payments, credit cards or SWIFT Address: CITIUS33 PO Box 894803 in installments:

*For wires, please reference the invoice, client and matter number(s) being paid For ACH payments, please use the CTX format and/or send any remittances to cashepn@paulhastings com This is a no-reply mailbox*

Case 22-50073 Doc 3283 Filed 06/24/24 Entered 06/24/24 18:35:48 Page 98 of 562

PAUL HASTINGS LLP 200 Park Avenue, New York, NY 10166-3205 t: +1.212.318.6000 f: +1.212.319.4090 www.paulhastings.com

Luc Despins as Chapter 11 Trustee in the case of Ho May 9, 2024

New York, NY 10166 Invoice Number: 2395792

Attn: Luc Despins PH LLP Tax ID No. 95-2209675

FOR PROFESSIONAL SERVICES RENDERED for the period ending January 31, 2024 Asset Recovery Investigation and Litigation \$611,886.25

Date Initials Description Hours Rate Amount B120 Asset Analysis and Recovery 01/03/2024 HP1 Review correspondence from L. Despins regarding ability to obtain information from third parties pursuant to English law (0.2); call with M. Jain regarding the same (0.1); call to G. Wong regarding the same (0.1); correspond with L. Despins regarding the same (0.1); review law on recognition and disclosure (0.3); review barrister details of historical engagement and suitability for current issues (0.1); correspond with L Despins re the same (0.1) 1.00 2,150.00 2,150.00 01/03/2024 MJ8 Review query from L. Despins regarding potential injunctive relief in English courts relating to Knightsbridge property (2.5); call with H. Potts regarding the same (0.5) 3.00 1,390.00 4,170.00 01/18/2024 LAD4 Review/edit draft motion to stay UBS litigation in UK 1.40 1,975.00 2,765.00 Case 22-50073 Doc 3283 Filed 06/24/24 Entered 06/24/24 18:35:48 Page 99 of 562 Luc Despins as Chapter 11 Trustee in the case of Ho Wan Kwok 50687-00002 Invoice No. 2395792

Analyze letter from Swiss court regarding

with A. de Quincey (Pallas) regarding same (0.2); correspond with L. Despins regarding

Subtotal:

case (.1); review and revise draft agenda (.2) Subtotal:

762.00 Date Initials Description Hours Rate Amount

01/01/2024 SM29 Review inserts from E. Sutton to notice 4.80 1,395.00 6,696.00

motion (.4); analyze case law and statutory

supplement notice motion (1.5); review and

Case 22-50073 Doc 3283 Filed 06/24/24 Entered 06/24/24 18:35:48 Page 100 of 562

Case 22-50073 Doc 3283 Filed 06/24/24 Entered 06/24/24 18:35:48 Page 101 of 562

Luc Despins as Chapter 11 Trustee in the case of Ho Wan Kwok 50687-00002 Invoice No. 2395792

Date Initials Description Hours Rate Amount

01/02/2024 SM29 Further call with D. Barron re notice motion (.3); analyze additional cases re same (.8); prepare notes re notice motion for call with L. Despins and N. Bassett (.3) 1.40 1,395.00 1,953.00 01/03/2024 DEB4 Conference with E. Sutton regarding tolling

regarding same (0.2) 0.30 1,395.00 418.50 01/03/2024 ECS1 Review updates on pending appeals related to the bankruptcy case 0.10 1,270.00 127.00 01/03/2024 JK21 Update appeals tracking chart 0.60 565.00 339.00 01/03/2024 JPK1 Draft proposed order for tolling motion (1.2); draft form of notice for tolling motion

01/03/2024 LAD4 T/c N. Bassett & S. Maza re: tolling motion

01/03/2024 AEL2 Analyze proposal from Kobre related to Trustee's investigation 0.20 1,850.00 370.00 01/03/2024 AEL2 Correspond with J. Kosciewicz re: open discovery matters and next steps 0.40 1,850.00 740.00 01/03/2024 AEL2 Meet with N. Bassett re: outstanding discovery and pending actions 0.30 1,850.00 555.00 01/03/2024 AEL2 Revise tolling stipulation 0.20 1,850.00 370.00 01/03/2024 AEL2 Call with S. Maza re: new action (.4); analyze new claims (.4) 0.80 1,850.00 1,480.00 01/03/2024 NAB Review and revise draft tolling stipulation

regarding same (.1); call with L. Despins

regarding same (.1) 1.60 1,835.00 2,936.00

and litigation strategy (.3); correspond with A. Luft regarding same (.1) 0.40 1,835.00 734.00

Case 22-50073 Doc 3283 Filed 06/24/24 Entered 06/24/24 18:35:48 Page 102 of 562

Luc Despins as Chapter 11 Trustee in the case of Ho Wan Kwok 50687-00002 Invoice No. 2395792

Date Initials Description Hours Rate Amount

01/03/2024 SM29 Call with L. Despins and N. Bassett re

01/03/2024 SM29 Revise notice motion to incorporate

(1.0); correspond with K. Catalano re same (.1); correspond with J. Kosciewicz re same

01/03/2024 WCF Review Rule 2004 documents produced by

responsiveness to adversary proceedings 0.30 1,390.00 417.00 01/04/2024 DEB4 Conference with S. Maza regarding notice

regarding same (0.2); revise same (1.0) 1.60 1,395.00 2,232.00

internationally located parties in connection with motion re notice of tolling motion (.4);

01/04/2024 AEL2 Revise email to M. Francis counsel re:

01/04/2024 NAB Review and revise draft motion regarding notice for tolling of statute of limitations (2.8); analyze case law in connection with

tolling motion (2.3) 7.10 1,835.00 13,028.50 01/04/2024 SM29 Review and revise notice motion, proposed order, and form of notice re same (1.8); calls with N. Bassett re same (.6); analyze

proposed order, and form of notice re same (2.1); call with D. Barron re same (.4) 7.80 1,395.00 10,881.00

Case 22-50073 Doc 3283 Filed 06/24/24 Entered 06/24/24 18:35:48 Page 103 of 562

Luc Despins as Chapter 11 Trustee in the case of Ho Wan Kwok 50687-00002 Invoice No. 2395792

Date Initials Description Hours Rate Amount 01/05/2024 DEB4 Conferences with S. Maza regarding service motion related to tolling motion (0.4); conference with K. Catalano regarding same (0.1); revise service motion (1.3); correspond with P. Parizek (Kroll) regarding same (0.2); correspond with N. Bassett regarding same (0.1); correspond with A. Lomas (Kroll) regarding service motion (0.1) 2.20 1,395.00 3,069.00 01/05/2024 KC27 Prepare motion to expedite hearing for notice motion (1.1); prepare proposed order for same (.3); revise notice motion (1.2); calls with S. Maza regarding same (.2); call with D. Barron regarding service motion related to tolling motion (.1); analyze precedent for publication notice (3.5); prepare publication notice (1.4) 7.80 1,185.00 9,243.00 01/05/2024 NAB Correspond with L. Despins regarding litigation strategy and potential claims (.2); correspond with S. Maza regarding notice motion for equitable tolling motion (.3); review and revise same (.8); review cases related to same (.3); correspond with A. Luft regarding litigation strategy issues (.3) 1.90 1,835.00 3,486.50 01/05/2024 NAB Correspond with S. Maza regarding notice motion for equitable tolling motion (.3); review and revise same (.8); analyze authority related to same (.3) 1.40 1,835.00 2,569.00 01/05/2024 SM29 Revise notice motion to incorporate N. Bassett comments (.7); call with D. Barron re same (.1); analyze foreign service issues and related authority in connection with same (1.1); correspond with N. Bassett re same (.4) further revise notice motion (1.0); calls with K. Catalano re same (.2) 3.50 1,395.00 4,882.50 01/05/2024 SM29 Further calls with D. Barron re notice motion, order, and related exhibits 0.30 1,395.00 418.50 01/06/2024 KC27 Analyze precedent regarding publication 0.30 1,185.00 355.50

Case 22-50073 Doc 3283 Filed 06/24/24 Entered 06/24/24 18:35:48 Page 104 of 562

Luc Despins as Chapter 11 Trustee in the case of Ho Wan Kwok 50687-00002 Invoice No. 2395792

Date Initials Description Hours Rate Amount

01/06/2024 NAB Review and revise draft notice motion for equitable tolling motion and proposed order

01/07/2024 KC27 Revise motion for service of tolling motion (1.0); prepare publication notice for same

01/07/2024 NAB Correspond with L. Despins regarding

regarding same (.2); correspond with L. Despins and S. Maza regarding same (.2) 0.50 1,835.00 917.50 01/07/2024 SM29 Review L. Despins comments to notice motion (.2); correspond with L. Despins re

incorporate L. Despins' comments (.5); correspond with N. Bassett, D. Barron, K. Catalano re same (.2); call with N. Bassett re

(.2); analyze application of bankruptcy rules in connection with notice motion (.5) 1.90 1,395.00 2,650.50 01/08/2024 DEB4 Conferences with S. Maza regarding notice and tolling motions (0.9); correspond with S. Maza regarding same (0.3); analyze and

(5.4); call with S. Maza regarding service of notice motion (0.2) 6.80 1,395.00 9,486.00 01/08/2024 DEB4 Conference with S. Maza regarding draft

01/08/2024 DEB4 Call with L. Despins, N. Bassett, P. Linsey, D. Skalka, and A. Luft regarding litigation

Case 22-50073 Doc 3283 Filed 06/24/24 Entered 06/24/24 18:35:48 Page 105 of 562 Luc Despins as Chapter 11 Trustee in the case of Ho Wan Kwok 50687-00002 Invoice No. 2395792

Date Initials Description Hours Rate Amount

01/08/2024 ECS1 Review and summarize information

motion for the tolling motion (2.4);

certain previous adversary complaints (.2) 2.90 1,270.00 3,683.00 01/08/2024 ECS1 Prepare list of parties targeted with a

proceedings in connection with the notice

regarding same (.2) 1.60 1,270.00 2,032.00 01/08/2024 KC27 Revise notice motion and order related to

expedite hearing on notice motion (.3); revise tolling motion (.2); correspond with S. Maza re same (.1); review emails from S. Maza and N. Bassett regarding same (.1) 1.00 1,185.00 1,185.00

01/08/2024 LAD4 Handle weekly P. Linsey (NPM) call re: litigation strategy with N. Bassett, A. Luft.

01/08/2024 AEL2 Participate in update call with P. Linsey (NPM), L. Despins, N. Bassett, D. Barron 0.80 1,850.00 1,480.00 01/08/2024 NAB Correspond with L. Despins regarding avoidance action and litigation strategy (.3);

motion for equitable tolling (.3) 0.60 1,835.00 1,101.00 01/08/2024 NAB Participate in call with L. Despins, D. Barron, P. Linsey (NPM), A. Luft regarding general case litigation strategy and updates 0.80 1,835.00 1,468.00

Case 22-50073 Doc 3283 Filed 06/24/24 Entered 06/24/24 18:35:48 Page 106 of 562

Luc Despins as Chapter 11 Trustee in the case of Ho Wan Kwok 50687-00002 Invoice No. 2395792

Date Initials Description Hours Rate Amount

01/08/2024 SM29 Analyze application of bankruptcy rules in connection with notice motion (.9); calls

schedules and exhibits (.9); review form of postpetition avoidance complaint (.2); call

motion (.1); correspond with L. Despins re same (.1); call with D. Barron re service of notice motion (.2); email P. Linsey re same (.1); correspond with K. Catalano re hearing dates and scheduling of tolling motion (.2); review same (.2) 3.30 1,395.00 4,603.50 01/09/2024 DEB4 Call with S. Maza regarding tracing and

motion (0.3); analyze documents related to

01/09/2024 ECS1 Correspond with A. Bongartz regarding

findings against the Debtor in connection with BVI declaration 0.20 1,270.00 254.00 01/09/2024 ECS1 Prepare list of service targets and related information for certain subpoenaed parties in connection with the notice motion (1.6);

regarding same (.2) 2.00 1,270.00 2,540.00 01/09/2024 JK21 Correspond with S. Maza regarding filing of

hearing regarding tolling motion (0.4); prepare for electronic filing notice motion (0.3); prepare for electronic filing motion to expedite hearing (0.2); electronically file with the court notice motion (0.1); electronically file with the court motion to expedite hearing (0.1) 1.10 565.00 621.50

Case 22-50073 Doc 3283 Filed 06/24/24 Entered 06/24/24 18:35:48 Page 107 of 562

Date Initials Description Hours Rate Amount

01/09/2024 K21 Correspond with S. Maza and E. Sutton

service parties for service of notice motion and motion to expedite hearing (2.1) 2.40 565.00 1,356.00 01/09/2024 IPK1 Incorporate N. Bassett comments into (.1);

01/09/2024 NAB Correspond with S. Maza regarding notice motion related to equitable tolling motion 0.20 1,835.00 367.00 01/09/2024 SM29 Revise notice motion (2.9); correspond with J. Kuo re service of same (.2); review service list for same (.3); correspond with J. Kuo, E. Sutton, K. Mitchell and P. Linsey (NPM) re service of notice motion (0.1); correspond with N. Bassett re same (.2) 3.70 1,395.00 5,161.50 01/09/2024 SM29 Call with D. Barron re tracing and fraudulent transfer issues 0.20 1,395.00 279.00 01/10/2024 AB21 Correspond with L. Despins and S. Maza regarding BVI service of tolling motion 0.10 1,850.00 185.00 01/10/2024 DEB4 Conference with P. Linsey (NPM) regarding avoidance complaints (1.0); correspond with

same (0.5); analyze same (2.3); correspond

avoidance issues (0.5); correspond with L. Song regarding discovery documents (0.3); analyze same (3.4) 8.20 1,395.00 11,439.00 01/10/2024 ECS1 Correspond with S. Maza and J. Kuo

information for certain subpoenaed parties in connection with the notice motion (.1); correspond with K. Mitchell and P. Linsey 0.20 1,270.00 254.00

Case 22-50073 Doc 3283 Filed 06/24/24 Entered 06/24/24 18:35:48 Page 108 of 562 Luc Despins as Chapter 11 Trustee in the case of Ho Wan Kwok 50687-00002 Invoice No. 2395792

Date Initials Description Hours Rate Amount

01/10/2024 JK21 Correspond with S. Maza and E. Sutton

regarding tolling motion (0.3); review and

motion to expedite hearing regarding tolling

motion and motion to expedite (1.4); electronically file with the court certificate

01/10/2024 JK21 Correspond with A. Bongartz regarding filing of certificate of service of process

(0.1); electronically file with the court

regarding summons and complaint (0.1) 0.20 565.00 113.00 01/10/2024 JPK1 Review tolling notice motion (.2);

publication notice (.2); correspond with S. Maza regarding the same (.5) 0.90 1,185.00 1,066.50 01/10/2024 JPK1 Draft revised proposed order for service

regarding the same (.2) 1.20 1,185.00 1,422.00 01/10/2024 AEL2 Correspond with 0.50 1,850.00 925.00 01/10/2024 SM29 Call with A. Thorpe (Harneys Legal) re service issues (.5); email L. Despins re same

01/10/2024 SM29 Correspond with J. Kuo and E. Sutton re service issues related to notice motion and tolling motion (.2); correspond with L.

order (.2); email J. Kosciewicz re same (.2);

motion timing (.2); review precedent tolling motions from K. Catalano (2.0); correspond with K. Catalano re same (.1); prepare parts 5.50 1,395.00 7,672.50

Case 22-50073 Doc 3283 Filed 06/24/24 Entered 06/24/24 18:35:48 Page 109 of 562

Luc Despins as Chapter 11 Trustee in the case of Ho Wan Kwok 50687-00002 Invoice No. 2395792

Date Initials Description Hours Rate Amount

01/11/2024 DEB4 Correspond with L. Song regarding notice motion service (0.2); correspond with S. Maza regarding same (0.1) 0.30 1,395.00 418.50 01/11/2024 JK21 Correspond with S. Maza and E. Sutton

expedited hearing regarding notice motion

expedited hearing regrading notice motion regarding tolling motion (0.1) 0.30 565.00 169.50 01/11/2024 JPK1 Draft notice of revised proposed order re notice motion (.8); revise form notice (.1);

01/11/2024 AEL2 Call with 0.40 1,850.00 740.00 01/11/2024 AEL2 Revise privilege draft re: M. Francis

01/11/2024 NAB Correspond with A. Luft regarding tolling

01/11/2024 SM29 Email D. Barron and K. Catalano re tolling motion (.5); prepare parts of tolling motion (7.2); review court order re notice motion hearing (.1); email L. Despins and N. Bassett re same (.1); email P. Linsey (NPM) re same (.1); email J. Kuo and E. Sutton re service re same (.1) 8.10 1,395.00 11,299.50 01/12/2024 DEB4 Draft section for tolling motion (3.6);

regarding same (0.6) 4.20 1,395.00 5,859.00 01/12/2024 JK21 Prepare certificate of service regarding

regarding tolling motion (0.2); electronically file with the court certificate of service

motion regarding tolling motion (0.1);

service of notice motion, scheduling motion

Case 22-50073 Doc 3283 Filed 06/24/24 Entered 06/24/24 18:35:48 Page 110 of 562

Luc Despins as Chapter 11 Trustee in the case of Ho Wan Kwok 50687-00002 Invoice No. 2395792

Date Initials Description Hours Rate Amount 01/12/2024 JPK1 Correspond with J. Kuo regarding physical mail copies sent to J. Weddle, counsel for Gettr (.2); correspond with J. Weddle regarding the same (.2); correspond with D. Barron regarding the same (.1) 0.50 1,185.00 592.50 01/12/2024 KC27 Analyze case law regarding tolling statute of limitations (5.2); revise and supplement tolling motion (3.3); correspond with N. Bassett regarding same (.1); correspond with S. Maza and D. Barron regarding same (.3); call with S. Maza and D. Barron regarding same (.6) 9.50 1,185.00 11,257.50 01/12/2024 NAB Correspond with S. Maza regarding notice motion and related issues 0.20 1,835.00 367.00 01/12/2024 SM29 Correspond with J. Kuo re notice motion filing and service (.3); correspond with N. Bassett and L. Despins re alternative service issues (.3); correspond with A. Thorp (BVI) 1.50 1,395.00 2,092.50

01/12/2024 SM29 Call with K. Catalano and D. Barron re equitable tolling motion (.6); correspond with K. Catalano re same (.1); revise and supplement equitable tolling motion (1.7); review K. Catalano insert and notes re same (1.0); review precedent orders from K. Catalano re equitable tolling (.5) 3.90 1,395.00 5,440.50 01/13/2024 KC27 Analyze case law regarding extending statute of limitations 5.60 1,185.00 6,636.00

notice of tolling motion (.2); correspond with S. Maza and J. Kuo regarding same (.1) 0.30 1,270.00 381.00 01/14/2024 KC27 Revise tolling motion (.4); correspond with L. Despins regarding same (.1) 0.50 1,185.00 592.50 01/14/2024 NAB Review and revise draft equitable tolling

regarding same (.1) 0.70 1,835.00 1,284.50

Case 22-50073 Doc 3283 Filed 06/24/24 Entered 06/24/24 18:35:48 Page 111 of 562

Luc Despins as Chapter 11 Trustee in the case of Ho Wan Kwok 50687-00002 Invoice No. 2395792

Date Initials Description Hours Rate Amount 01/14/2024 SM29 Review and revise proposed order and notice documents in connection with tolling motion (.6); email J. Kosciewicz re same (.1); review changes to tolling motion from K. Catalano (.5); correspond with K. Catalano re same (.2); review further revisions to tolling motion (.2); correspond with K. Catalano re same (.2) 1.80 1,395.00 2,511.00 01/15/2024 JPK1 Review updated draft notice of revised proposed order for notice motion (.3); revise notice of revised proposed order for notice motion (.5); draft British Virgin Islands publication notice (.4); correspond with S. Maza regarding the same (.1) 1.30 1,185.00 1,540.50 01/15/2024 KC27 Revise tolling motion 0.60 1,185.00 711.00 01/15/2024 NAB Review correspondence from Court and orders relating to equitable tolling notice motion (.2); correspond with S. Maza regarding same (.1) 0.30 1,835.00 550.50 01/15/2024 NAB Correspond with L. Despins regarding litigation strategy in pending adversary proceedings 0.10 1,835.00 183.50 01/15/2024 SM29 Review email from court re scheduling (.1); email L. Despins re same (.3); email N. Bassett re same (.1); review tolling motion (1.0) 1.50 1,395.00 2,092.50 01/16/2024 DEB4 Correspond with S. Maza regarding responses to notice motion papers (0.2); correspond with J. Kosciewicz regarding tolling order (0.1); conference with P. Linsey regarding same (0.1) 0.40 1,395.00 558.00 01/16/2024 JPK1 Telephone call with S. Maza regarding notice of revised proposed order on notice motion 0.10 1,185.00 118.50 01/16/2024 KC27 Prepare parts of tolling motion (2.5); calls with S. Maza regarding same (.3) 2.80 1,185.00 3,318.00 01/16/2024 LAD4 Review/edit tolling motion 1.30 1,975.00 2,567.50 Case 22-50073 Doc 3283 Filed 06/24/24 Entered 06/24/24 18:35:48 Page 112 of 562

Luc Despins as Chapter 11 Trustee in the case of Ho Wan Kwok 50687-00002 Invoice No. 2395792

Date Initials Description Hours Rate Amount 01/16/2024 SM29 Revise tolling motion to incorporate L. Despins' comments (2.9); calls with D. Barron re same (.2); calls with K. Catalano re same (.3); correspond with K. Catalano re same (.3); email L. Despins and N. Bassett re notice motion proposed order (.3); call with J. Kosciewicz re same (.1); correspond with L. Despins re tolling motion (.3); correspond with E. Sutton re service issues (.1) 4.50 1,395.00 6,277.50 01/17/2024 ECS1 Correspond with S. Maza and J. Kuo regarding responses to notice of tolling motion 0.20 1,270.00 254.00 01/17/2024 JK21 Review and revise tolling motion (3.6); prepare exhibits to tolling motion for electronic filing (0.8) 4.40 565.00 2,486.00 01/17/2024 KC27 Review tolling motion (.4); correspond with J. Kuo regarding same (.1) 0.50 1,185.00 592.50 01/17/2024 AEL2 Correspond with D. Barron re: requests for information re: equitable tolling 0.20 1,850.00 370.00 01/17/2024 NAB Review and revise draft avoidance action tolling agreements (.3); call with tolling agreement target regarding same (.2) 0.50 1,835.00 917.50 01/17/2024 SM29 Revise and supplement tolling motion (3.2); correspond with L. Despins and N. Bassett re DOJ language in connection with same (.4) 3.60 1,395.00 5,022.00 01/18/2024 DEB4 Correspond with L. Despins and N. Bassett regarding email from Paul Weiss with respect to tolling motion (0.2); correspond with P. Linsey regarding responses to inquiries from parties receiving tolling notice (0.1); correspond with E. Sutton regarding same (0.1) 0.45 1,395.00 627.75 01/18/2024 JK21 Correspond with S. Maza regarding filing tolling motion (0.2); electronically file with the court tolling motion (0.1); review and 0.50 565.00 282.50

Date Initials Description Hours Rate Amount

01/18/2024 KC27 Review tolling motion (.3); conference with S. Maza regarding same (.2) 0.50 1,185.00 592.50 01/18/2024 NAB Revise draft tolling agreement (.3); correspond with counsel for party to same

01/18/2024 SM29 Correspond with J. Kuo regarding filing and serving tolling motion (.2); call with K.

(.2); review filing version of tolling motion (.3); correspond with D. Barron, L. Song re service issues related to tolling motion (.1) 0.80 1,395.00 1,116.00 01/19/2024 DEB4 Correspond with L. Despins regarding tolling order (0.1); conference with S. Maza regarding same (0.1); correspond with N. Bassett regarding relation back issues (0.1); correspond with A. Lomas (Kroll) regarding

purposes related to tolling motion (0.1); analyze documents related to same (0.4) 0.80 1,395.00 1,116.00 01/19/2024 ECS1 Prepare summary of certain information regarding recipients of tolling motion for Trustee (.5); correspond with S. Maza and D. Barron regarding same (.2) 0.70 1,270.00 889.00 01/19/2024 JK21 Revise service list for tolling motion (0.1); correspond with S. Maza regarding service of notice and tolling motion (0.2) 0.30 565.00 169.50 01/19/2024 SM29 Email A. Thorp (BVI) re service of notice order (.1); email D. Barron, J. Kosciewicz, L. Song, J. Kuo re same (.3); call with D. Barron re same (.1); email L. Despins and

01/19/2024 SM29 Call with P. Linsey (NPM) re notice order and court's email (.2); correspond with L. Despins re same (.1) 0.30 1,395.00 418.50 01/20/2024 DEB4 Correspond with J. Lazarus regarding information for tolling motion notice (0.1);

registered agents (0.1) 0.20 1,395.00 279.00

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Luc Despins as Chapter 11 Trustee in the case of Ho Wan Kwok 50687-00002 Invoice No. 2395792

Date Initials Description Hours Rate Amount

01/21/2024 ECS1 Review information and addresses re subpoena targets in connection with tolling

regarding same (.9); correspond with J.

(NPM) regarding same (.2) 1.40 1,270.00 1,778.00 01/21/2024 JPK1 Draft updated form of notice for tolling motion (.4); prepare publication notices (.4);

previous notices (.3); correspond with S. Maza regarding the same (.2) 1.30 1,185.00 1,540.50 01/21/2024 SM29 Correspond with L. Song re publication notice of tolling motion (.2); correspond with J. Kuo re service in compliance with notice order (.2) 0.40 1,395.00 558.00 01/22/2024 DEB4 Correspond with S. Maza regarding tolling motion service issues 0.30 1,395.00 418.50 01/22/2024 DEB4 Correspond with J. Lazarus (Kroll) regarding information/addresses for tolling motion notice (0.2); correspond with J. Kuo regarding same (0.1); correspond with T. Pierson (Jackson Lewis) regarding tolling motion notice (0.1) 0.40 1,395.00 558.00 01/22/2024 JK21 Correspond with S. Maza, D. Barron, and J. Kosciewicz regarding service of form notice

tolling motion (3.6) 4.20 565.00 2,373.00 01/22/2024 JK21 Revise service list for tolling motion (0.1); correspond with S. Maza regarding service of notice and tolling motion (0.2) 0.30 565.00 169.50 01/22/2024 JPK1 Create Schedule II for service of notice motion (1.4); create form notice documents

regarding the same (.2) 1.90 1,185.00 2,251.50 01/22/2024 LS26 Prepare notice re: tolling motion and translation of same 3.20 985.00 3,152.00

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Luc Despins as Chapter 11 Trustee in the case of Ho Wan Kwok 50687-00002 Invoice No. 2395792

Date Initials Description Hours Rate Amount 01/22/2024 LS26 Correspond and call with D. Barron re certain entities related to tolling motion (0.5); further conference with D. Barron regarding same (0.4) 0.90 985.00 886.50 01/22/2024 SM29 Correspond with J. Kuo, L. Song, and P. Linsey (NPM) re service in compliance with notice order 0.70 1,395.00 976.50 01/23/2024 DEB4 Correspond with A. Luft regarding tolling motion 0.10 1,395.00 139.50 01/23/2024 DEB4 Correspond with A. Luft regarding tolling motion (0.1); conference with A. Luft and Joshua Sherman regarding tolling motion (0.5) 0.60 1,395.00 837.00 01/23/2024 JK21 Prepare exhibits to the notice of service of the tolling motion and notice 2.20 565.00 1,243.00 01/23/2024 JK21 Update appeals tracking chart 0.40 565.00 226.00 01/23/2024 JPK1 Draft notice of service for tolling motion (2.1); correspond with S. Maza regarding the same (.2); correspond with J. Kuo regarding the same (.1) 2.40 1,185.00 2,844.00 01/23/2024 AEL2 Call with D. Barron and J. Sherman re: tolling motion 0.50 1,850.00 925.00 01/23/2024 NAB Correspond with A. Luft and W. Farmer regarding potential causes of action to file by February 15 and next steps in relation to same (.5); correspond with A. Luft regarding equitable tolling motion and related deposition request (.2) 0.70 1,835.00 1,284.50 01/23/2024 SM29 Email J. Kosciewicz and J. Kuo re notice of service in connection with service order (.4); correspond with A. Thorp (BVI counsel) re same (.2) 0.60 1,395.00 837.00 01/24/2024 DEB4 Conference with S. Maza, L. Song, and J. 0.80 1,395.00 1,116.00

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Luc Despins as Chapter 11 Trustee in the case of Ho Wan Kwok 50687-00002 Invoice No. 2395792

Date Initials Description Hours Rate Amount

01/24/2024 JK21 Conference with S. Maza, D. Barron, and L.

tolling motion and notice (0.8); review and

motion and notice (0.7) 1.50 565.00 847.50 01/24/2024 JPK1 Telephone call with A. Luft regarding

01/24/2024 AEL2 Call with 0.20 1,850.00 370.00 01/24/2024 AEL2 Analyze equitable tolling cases and evidentiary support 1.10 1,850.00 2,035.00 01/24/2024 AEL2 Call with J. Kosciewicz re: equitable tolling motion subpoena responses 0.50 1,850.00 925.00 01/24/2024 LS26 Review and revise potential defendant list for tolling motion (3.6); call with D. Barron, J. Kuo and S. Maza re same (0.8) 4.40 985.00 4,334.00 01/24/2024 NAB Call with A. Luft regarding equitable tolling motion discovery responses (.3); call with S. Maza regarding issues related to service of tolling motion (.1) 0.40 1,835.00 734.00 01/24/2024 SM29 Calls with J. Kuo, D. Barron and L. Song re tolling motion and notice recipients (.8); review updated list of recipients from L. Song (.2); reply to email from L. Song re

counsel) re same (.2) 1.30 1,395.00 1,813.50 01/25/2024 DEB4 Call with N. Bassett, S. Maza, A. Luft, J.

deposition (0.7); correspond with N.

litigation issues (0.3) 1.00 1,395.00 1,395.00 01/25/2024 JK21 Correspond with S. Maza and L. Song regarding supplemental service of tolling motion and notice (0.4); review and handle supplemental service of tolling motion and 0.80 565.00 452.00

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Luc Despins as Chapter 11 Trustee in the case of Ho Wan Kwok 50687-00002 Invoice No. 2395792

Date Initials Description Hours Rate Amount

01/25/2024 JPK1 Telephone conference with N. Bassett, A.

preparing Trustee for deposition regarding

01/25/2024 JPK1 Draft preparation outline for deposition of L. Despins with regards to tolling motion 4.10 1,185.00 4,858.50 01/25/2024 LAD4 T/c N. Bassett and A. Luft re: equitable

01/25/2024 AEL2 Meeting with S. Maza, D. Barron, J.

equitable tolling deposition 0.70 1,850.00 1,295.00 01/25/2024 AEL2 Analyze litigation finance question 0.10 1,850.00 185.00 01/25/2024 AEL2 Call with N. Bassett and L. Despins re: equitable tolling subpoena 0.20 1,850.00 370.00 01/25/2024 AEL2 Review issues and prepare notes for equitable tolling call 0.30 1,850.00 555.00 01/25/2024 NAB Call with D. Barron, A. Luft, S. Maza, and J.

discovery related to equitable tolling motion

regarding same (.2) 0.90 1,835.00 1,651.50 01/25/2024 SM29 Call with A. Luft, N. Bassett, D. Barron, J. Kosciewicz re depo prep in connection with tolling motion (.7); email A. Luft re initial list of defendants (.1) 0.80 1,395.00 1,116.00 01/26/2024 DM26 Review and handle service of tolling motion

01/26/2024 JK21 Correspond with S. Maza regarding completion of service of tolling motion and notice (0.2); review and comment on service of tolling motion and notice (0.6) 0.80 565.00 452.00 01/26/2024 AEL2 Correspond with N. Bassett re: litigation issues/task list 0.60 1,850.00 1,110.00

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Luc Despins as Chapter 11 Trustee in the case of Ho Wan Kwok 50687-00002 Invoice No. 2395792

Date Initials Description Hours Rate Amount 01/26/2024 NAB Correspond and call with potential law firm defendant regarding tolling agreement (.3); review and revise draft responses and objections to Mei Guo discovery requests relating to equitable tolling motion (.3); correspond with J. Kosciewicz regarding same (.1) 0.70 1,835.00 1,284.50 01/26/2024 SM29 Correspond with J. Kuo re service issues in connection with order (.2); email N. Bassett re same (.1) 0.30 1,395.00 418.50 01/28/2024 DEB4 Correspond with E. Sutton regarding tolling notice motion service issues 0.10 1,395.00 139.50 01/28/2024 JPK1 Continue drafting deposition preparation outline for L. Despins regarding tolling motion 2.00 1,185.00 2,370.00 01/29/2024 DEB4 Participate in litigation update call with P. Linsey, N. Bassett, and A. Luft 0.90 1,395.00 1,255.50 01/29/2024 ECS1 Review subpoena targets and their information/addresses in connection with tolling motion (.1); update summary chart regarding same (.1); correspond with J. Kuo, S. Maza, D. Barron regarding same (.1) 0.30 1,270.00 381.00 01/29/2024 JK21 Revise exhibits to notice of service regarding tolling motion and form of notice (0.3); correspond with S. Maza regarding local counsel supplemental certificate of service (0.1); correspond with J. Kosciewicz regarding notice of service (0.1) 0.50 565.00 282.50 01/29/2024 JPK1 Incorporate N. Bassett edits to responses and objections to M. Guo's requests for production of documents with regards to tolling motion (.3); correspond with N. Bassett regarding the same (.1) 0.40 1,185.00 474.00 01/29/2024 JPK1 Correspond with P. Linsey (NPM) regarding form of notice for tolling motion certificate of service 0.10 1,185.00 118.50

Date Initials Description Hours Rate Amount

01/29/2024 JPK1 Draft parts of deposition preparation

01/29/2024 JPK1 Incorporate N. Bassett's edits into

deposition with regards to tolling motion 1.30 1,185.00 1,540.50 01/29/2024 AEL2 Correspond with J. Kosciewicz re: equitable tolling depo prep outline 0.20 1,850.00 370.00 01/29/2024 AEL2 Review equitable tolling deposition prep outline for L. Despins 0.90 1,850.00 1,665.00 01/29/2024 AEL2 Participate in litigation update call with P. Linsey (NPM), D. Barron and N. Bassett 0.90 1,850.00 1,665.00 01/29/2024 NAB Update call with P. Linsey (NPM) D. Barron and A. Luft regarding litigation tasks 0.90 1,835.00 1,651.50 01/29/2024 NAB Review outline for equitable tolling motion discovery preparations (.5); correspond with J. Kosciewicz regarding same (.2) 0.70 1,835.00 1,284.50 01/29/2024 SM29 Review deposition prep outline for L. Despins in connection with tolling motion 0.40 1,395.00 558.00 01/29/2024 SM29 Email A. Thorp (BVI counsel) re service of tolling motion (.1); revise notice of same (.4); email J. Kuo and J. Kosciewicz re same

01/30/2024 JK21 Revise exhibits to the notice of service regarding tolling motion and form of notice

electronic filing (0.4); correspond with S. Maza regarding filing of notice of service of the tolling motion and form of notice (0.3) 2.80 565.00 1,582.00 01/30/2024 JPK1 Correspond with A. Bongartz regarding L. Despins deposition preparation related to

01/30/2024 JPK1 Review certificate of service for tolling

Form of Notice (.3); correspond with J. Kuo regarding the same (.1) 0.50 1,185.00 592.50

Date Initials Description Hours Rate Amount

01/30/2024 JPK1 Telephone call with A. Luft regarding L.

01/30/2024 JPK1 Correspond with D. Barron regarding Kroll

preparation regarding tolling motion 0.10 1,185.00 118.50 01/30/2024 AEL2 Review and revise equitable tolling notes 0.60 1,850.00 1,110.00 01/30/2024 AEL2 Review proposed declaration 0.40 1,850.00 740.00 01/30/2024 AEL2 Call with J. Kosciewicz re: equitable tolling

01/30/2024 NAB Correspond with S. Maza regarding tolling

01/30/2024 SM29 Revise notice of service under notice order (1.0); reply to email from J. Kosciewicz re equitable tolling motion discovery (.2) 1.20 1,395.00 1,674.00 01/31/2024 DEB4 Correspond with E. Sutton regarding tolling motion service issues 0.10 1,395.00 139.50 01/31/2024 DEB4 Correspond with L. Despins and S. Maza regarding tolling motion issues 0.40 1,395.00 558.00 01/31/2024 JK21 Correspond with S. Maza regarding filing of notice of service (0.1); electronically file with the court notice of service (0.1) 0.20 565.00 113.00 01/31/2024 LAD4 T/c S. Sarnoff (OMM) re: tolling motion 0.20 1,975.00 395.00 01/31/2024 AEL2 Analyze Je injunction 0.20 1,850.00 370.00 01/31/2024 NAB Correspond with law firm defendant regarding tolling agreement (.1); revise same

01/31/2024 NAB Correspond with L. Despins regarding litigation strategy 0.20 1,835.00 367.00 01/31/2024 SM29 Call with N. Bassett re duty to estate and related claims (.1); review correspondence with N. Bassett, L. Despins, and A. Luft re same (.2); analyze caselaw re same (.5) 0.80 1,395.00 1,116.00 Subtotal: B191 General Litigation 263.15 342,429.75

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Date Initials Description Hours Rate Amount

01/02/2024 AB21 Correspond with R. Stockil (Yachtzoo) regarding closing out Yachtzoo contract 0.10 1,850.00 185.00 01/09/2024 AB21 Correspond with D. Johnson (Edmiston) regarding open issues with respect to Lady

(Yachtzoo) regarding same (0.1) 0.20 1,850.00 370.00 01/30/2024 AB21 Call with E. Robinson (Howden Sturge) regarding Lady May insurance policy 0.10 1,850.00 185.00 Subtotal: B210 Business Operations 0.40 740.00

01/02/2024 DEB4 Call with A. Luft, N. Bassett, Kroll regarding UAE issues (1.0); conference with A. Luft regarding rule 2004 issues (0.2) 1.20 1,395.00 1,674.00

01/02/2024 ECS1 Review information regarding Kwok, his affiliates and assets, their connections to Kwok, and their corporate information (.1);

Debtor connected law firms and their roles

regarding same (.3) 0.50 1,270.00 635.00 01/02/2024 ECS1 Prepare responses to rule 2004 targets

and subpoenas (.2); correspond with A.

regarding same (.1) 0.30 1,270.00 381.00 01/02/2024 ECS1 Analyze and summarize documents produced in response to discovery requests (.9); correspond with N. Bassett, A. Luft, D.

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Luc Despins as Chapter 11 Trustee in the case of Ho Wan Kwok 50687-00002 Invoice No. 2395792

Date Initials Description Hours Rate Amount

01/02/2024 JPK1 Draft email to Gettr regarding request for

production (.3); correspond with D. Barron regarding the same (.1); correspond with J. Weddle (Gettr) regarding the same (.1) 0.50 1,185.00 592.50 01/02/2024 JPK1 Correspond with A. Luft regarding

01/02/2024 AEL2 Call with D. Barron re: rule 2004 analysis related to upcoming February 2024 matter 0.20 1,850.00 370.00 01/02/2024 AEL2 Call with Kroll, N. Bassett, D. Barron re: UAE capabilities 1.00 1,850.00 1,850.00 01/02/2024 AEL2 Analyze asset recovery issues and related

01/02/2024 AEL2 Review rule 2004 discovery requests and upcoming deadlines 0.40 1,850.00 740.00 01/02/2024 NAB Call (portion) with A. Luft, D. Barron and Kroll regarding UAE issues (.6); follow-up

additional investigative issues (.2) 0.80 1,835.00 1,468.00 01/03/2024 AB21 Review draft affidavit for BVI discovery (0.5); call with A. Thorp (Harneys Legal) regarding same (0.3); call and correspond with D. Barron regarding same (0.1) 0.90 1,850.00 1,665.00 01/03/2024 DM26 Research regarding certain entities for

corporate documents 2.40 565.00 1,356.00 01/03/2024 DEB4 Conference and correspond with A. Bongartz regarding BVI entities (0.1);

(0.2); correspond with P. Parizek (Kroll) regarding insiders (0.5); correspond with A. Luft regarding HCHK devices (0.1); analyze discovery documents (2.3); correspond with

01/03/2024 ECS1 Review G Club discovery documents 0.90 1,270.00 1,143.00

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Luc Despins as Chapter 11 Trustee in the case of Ho Wan Kwok 50687-00002 Invoice No. 2395792

Date Initials Description Hours Rate Amount

01/03/2024 ECS1 Prepare responses to rule 2004 targets

meet and confers, and subpoenas (.2); call with P. Linsey (NPM) regarding same (.1) 0.30 1,270.00 381.00 01/03/2024 ECS1 Analyze Trustee's discovery efforts and the debtor's obstructions (.5); call with D.

same for D. Barron and S. Maza (.3) 0.90 1,270.00 1,143.00 01/03/2024 ECS1 Analyze and summarize documents produced in response to discovery requests 0.30 1,270.00 381.00 01/03/2024 ECS1 Review information regarding Kwok, his

Kwok, and their corporate information (.9);

(.1); call with P. Linsey (NPM) regarding

01/03/2024 JPK1 Draft correspondence to J. Bach, counsel for Melissa Francis, regarding supplemental Rule 2004 production (,2); correspond with A. Luft regarding the same (.1) 0.30 1,185.00 355.50 01/03/2024 LAD4 Review/comment on Princes Gates discovery UK issues 0.20 1,975.00 395.00 01/03/2024 LAD4 T/c J. Murray (DOJ) and N. Bassett re: future depositions (.30); follow up t/c N. Bassett re: same (.20) 0.50 1,975.00 987.50 01/03/2024 AEL2 Correspond with L. Despins and N. Bassett

01/03/2024 AEL2 Analyze potential rule 2004 witnesses 0.60 1,850.00 1,110.00

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Luc Despins as Chapter 11 Trustee in the case of Ho Wan Kwok 50687-00002 Invoice No. 2395792

Date Initials Description Hours Rate Amount

01/04/2024 DEB4 Participate in call with Kroll, L. Despins, N.

investigation analysis (1.6); correspond with

(0.2); correspond with L. Despins regarding Pick and Zabicki payment (0.1); correspond

documents (0.1); correspond with J. Barker

certain entities and individuals tied to Kwok (0.4); correspond with E. Sutton regarding ROLF documents (0.1); correspond with P.

regarding transfers to Qiang Guo (0.1);

Birnbaum (0.1); review analysis from A. Lomas regarding bank accounts (0.2) 3.30 1,395.00 4,603.50 01/04/2024 ECS1 Prepare responses to rule 2004 targets

targets re same (.1) 0.20 1,270.00 254.00 01/04/2024 ECS1 Meet and confer with W. Farmer and E.

rule 2004 discovery obligations (.4); review issues and prepare follow up notes re same

01/04/2024 ECS1 Review information regarding Kwok, his affiliates and assets, their connections to Kwok, and their corporate information 0.10 1,270.00 127.00 01/04/2024 LAD4 Review/comment on Princes Gate UK

01/04/2024 LAD4 Handle (portion of) Kroll call with D.

Date Initials Description Hours Rate Amount

01/04/2024 AEL2 Participate in update call with Kroll, L.

Kroll financial analysis 1.60 1,850.00 2,960.00 01/04/2024 AEL2 Meet with D. Barron re: rule 2004 financial institution depositions 0.40 1,850.00 740.00 01/04/2024 AEL2 Correspond with L. Despins and N. Bassett

01/04/2024 AEL2 Call with P. Linsey re: rule 2004 financial institution depositions 0.40 1,850.00 740.00 01/04/2024 LS26 Review documents re: Kwok associates and

01/04/2024 NAB Attend investigative update and strategy call

01/04/2024 WCF Review issues and notes to prepare for Rule 2004 conference regarding Ding Li (.2); call

rule 2004 subpoena to Ding Li (.4) 0.60 1,390.00 834.00 01/05/2024 DEB4 Call with Kroll and P. Linsey (NPM) regarding bank discovery (1.2); conference with L. Song regarding insiders and alter

documents (1.3); correspond with J.

2004 targets (0.1); correspond with A. Lomas (Kroll) regarding Seacoast bank (0.1) 3.10 1,395.00 4,324.50 01/05/2024 ECS1 Prepare responses to rule 2004 targets

meet and confers, and subpoenas (.1); correspond with A. Luft, W. Farmer, and P. Linsey regarding same (.1) 0.20 1,270.00 254.00 01/05/2024 ECS1 Review information regarding Kwok, his affiliates and assets, their connections to Kwok, and their corporate information 0.20 1,270.00 254.00 01/05/2024 LS26 Call with D. Barron re Kwok related entities

Case 22-50073 Doc 3283 Filed 06/24/24 Entered 06/24/24 18:35:48 Page 126 of 562

Luc Despins as Chapter 11 Trustee in the case of Ho Wan Kwok 50687-00002 Invoice No. 2395792

Date Initials Description Hours Rate Amount

01/06/2024 DEB4 Conference with L. Song, P. Linsey (NPM),

(0.5); analyze discovery documents (1.3);

2004 motion (0.1) 1.90 1,395.00 2,650.50 01/06/2024 LS26 Conference with P. Linsey (NPM), D.

subpoenas (0.5); correspond with P. Linsey and K. Mitchell re same (0.2) 0.70 985.00 689.50 01/07/2024 LS26 Prepare list of Kwok related individuals and

01/08/2024 DEB4 Correspond with L. Despins and N. Bassett regarding Princes Gate apartment (0.1); correspond with L. Despins regarding same (0.4); correspond with E. Sutton regarding rule 2004 motion (0.1); correspond with E. Sutton regarding rule 2004 targets (0.4); analyze documents related to same (0.5);

suspected alter egos (0.3); correspond with Kroll regarding same (0.4) 2.20 1,395.00 3,069.00 01/08/2024 ECS1 Prepare responses to rule 2004 targets

meet and confers, and subpoenas 0.10 1,270.00 127.00

regarding Debtor's affiliates and assets 1.00 1,270.00 1,270.00 01/08/2024 ECS1 Prepare rule 2004 motion regarding Pick &

and P. Linsey (NPM) regarding same (.2) 1.60 1,270.00 2,032.00 01/08/2024 LS26 Review and revise list of Kwok related entities and individuals 0.20 985.00 197.00 01/09/2024 AB21 Revise affidavit in support of disclosure application in BVI (1.5); correspond with A. Thorp (Harneys) regarding same (0.2) 1.70 1,850.00 3,145.00 01/09/2024 DM26 Review issues in preparation for upcoming

Case 22-50073 Doc 3283 Filed 06/24/24 Entered 06/24/24 18:35:48 Page 127 of 562

Luc Despins as Chapter 11 Trustee in the case of Ho Wan Kwok 50687-00002 Invoice No. 2395792

Date Initials Description Hours Rate Amount 01/09/2024 DEB4 Correspond with L. Despins regarding Princes Gate (0.2); correspond with P. Linsey (NPM) regarding transfers (0.2); analyze discovery documents (1.8) 2.20 1,395.00 3,069.00 01/09/2024 ECS1 Analyze and summarize documents produced in response to discovery requests 0.40 1,270.00 508.00 01/09/2024 ECS1 Prepare responses to rule 2004 targets regarding outstanding rule 2004 motions and subpoenas (.3); correspond with A. Luft, W. Farmer, and P. Linsey (NPM) regarding same (.1) 0.40 1,270.00 508.00 01/09/2024 ECS1 Review information regarding Kwok, his affiliates and assets, their connections to Kwok, and their corporate information 0.10 1,270.00 127.00 01/09/2024 JPK1 Correspond with J. Bach, counsel for Melissa Francis, regarding production of documents previously withheld 0.20 1,185.00 237.00 01/09/2024 LAD4 Review Princes Gate's production (.70); t/c S. Nicolas re: same (.20) 0.90 1,975.00 1,777.50 01/10/2024 ECS1 Analyze Cirrus Aircraft production documents (.5); prepare summary of same for A. Lomas (Kroll) (.2) 0.70 1,270.00 889.00 01/10/2024 ECS1 Review and summarize Cirrus Aircraft document production (.5); correspond with A. Luft, D. Barron, W. Farmer, and L. Song regarding same (.1) 0.60 1,270.00 762.00 01/10/2024 ECS1 Meet and confer with M. Bachner (Bachner and Associates), and D. Wander (Tarter Krinsky & Drogin LLP), counsel to Yinying Wang, in connection with her rule 2004 discovery obligations (.4); review issues and prepare notes for same (.1) 0.50 1,270.00 635.00 01/10/2024 ECS1 Prepare responses to rule 2004 targets regarding outstanding rule 2004 motions, meet and confers, and subpoenas 0.10 1,270.00 127.00 01/10/2024 LAD4 Handle call with S. Nicolas and counsel for Encore re: Princes Gate document 0.70 1,975.00 1,382.50

Date Initials Description Hours Rate Amount

01/10/2024 AEL2 Correspond with E. Sutton re: Cirrus

rule 2004 discovery 1.00 985.00 985.00 01/11/2024 DM26 Research rule 2004 targets regarding their

01/11/2024 DEB4 Analyze discovery documents (3.2); correspond with Kroll regarding same (0.6) 3.80 1,395.00 5,301.00 01/11/2024 ECS1 Review information regarding Kwok, his affiliates and assets, their connections to Kwok, and their corporate information 0.10 1,270.00 127.00

motion and requests for production (2.5); analyze targets in connection with same (.7);

(NPM) regarding same (.4) 3.60 1,270.00 4,572.00 01/11/2024 ECS1 Prepare responses to rule 2004 targets

entities' production obligations (.3) 0.70 1,270.00 889.00 01/11/2024 JPK1 Correspond with D. Barron regarding request to Gettr for bank records (.1);

Gettr, regarding the same (.2) 0.30 1,185.00 355.50 01/11/2024 LAD4 Handle Kroll weekly call with A. Luft, N. Bassett re: ongoing analysis 0.90 1,975.00 1,777.50 01/11/2024 AEL2 Participate in update call with Kroll, L. Despins, N. Bassett 0.90 1,850.00 1,665.00 01/11/2024 AEL2 Correspond with D. Barron re: rule 2004

01/11/2024 LS26 Correspond with informant re Debtor

with D. Barron re same (0.2); review documents re

Case 22-50073 Doc 3283 Filed 06/24/24 Entered 06/24/24 18:35:48 Page 129 of 562

Luc Despins as Chapter 11 Trustee in the case of Ho Wan Kwok 50687-00002 Invoice No. 2395792

Date Initials Description Hours Rate Amount

01/11/2024 NAB Correspond with G Club counsel regarding appellate issues (.2); correspond with L. Despins regarding same (.1) 0.30 1,835.00 550.50 01/11/2024 NAB Participate in (portion of) call with Kroll, L.

updates and strategy 0.70 1,835.00 1,284.50 01/12/2024 DM26 Research regarding Knight Frank and U.S.

01/12/2024 ECS1 Prepare eleventh supplemental rule 2004 motion and requests for production (.6); analysis of targets in connection with same (.4); correspond with D. Barron and P. Linsey (NPM) regarding same (.2) 1.20 1,270.00 1,524.00 01/12/2024 ECS1 Review information regarding Kwok, his affiliates and assets, their connections to Kwok, and their corporate information 0.60 1,270.00 762.00 01/12/2024 LS26 Review documents re: Kwok related entities

01/12/2024 NAB Correspond with C. Fornos (G Club counsel) regarding appeal issues (.1); review

01/15/2024 AB21 Correspond with A. Thorp (Harneys Legal) regarding BVI discovery (0.1); correspond with E. Sutton and L. Song regarding same

01/15/2024 DEB4 Correspond with E. Sutton on rule 2004

regarding same (0.1); correspond with A. Thorp on BVI entities (0.1) 0.30 1,395.00 418.50 01/15/2024 ECS1 Review information regarding Kwok, his affiliates and assets, their connections to Kwok, and their corporate information 0.40 1,270.00 508.00

Case 22-50073 Doc 3283 Filed 06/24/24 Entered 06/24/24 18:35:48 Page 130 of 562

Luc Despins as Chapter 11 Trustee in the case of Ho Wan Kwok 50687-00002 Invoice No. 2395792

Date Initials Description Hours Rate Amount

01/15/2024 ECS1 Prepare eleventh supplemental rule 2004 motion and requests for production (.4); analyze targets in connection with same (.1);

(NPM) regarding same (.1); call with D. Barron re same (.1) 0.70 1,270.00 889.00 01/15/2024 LS26 Review certain documents in rule 2004

01/16/2024 DEB4 Correspond with P. Linsey (NPM) on rule 2004 motion (0.1); correspond with E. Sutton on Sitichting Duurzame (0.1);

property (0.1); correspond with L. Song and

with respect to books and records (0.1); analyze documents regarding same (0.7);

(0.1); correspond with P. Linsey regarding ACA capital (0.1) 1.40 1,395.00 1,953.00 01/16/2024 ECS1 Correspond with P. Linsey regarding targets

01/16/2024 ECS1 Review information regarding Kwok, his affiliates and assets, their connections to Kwok, and their corporate information 0.40 1,270.00 508.00 01/16/2024 ECS1 Prepare thirteenth supplemental Rule 2004 motion (.9); analyze targets in connection with same (.4); correspond with D. Barron,

01/16/2024 ECS1 Prepare correspondence to rule 2004 targets

and subpoenas (.1); correspond with A.

regarding same (.1) 0.20 1,270.00 254.00

Case 22-50073 Doc 3283 Filed 06/24/24 Entered 06/24/24 18:35:48 Page 131 of 562

Luc Despins as Chapter 11 Trustee in the case of Ho Wan Kwok 50687-00002 Invoice No. 2395792

Date Initials Description Hours Rate Amount

01/16/2024 ECS1 Prepare eleventh supplemental rule 2004 motion and requests for production (.2);

(NPM) regarding same (.1); call with P. Linsey re same (.1) 0.40 1,270.00 508.00 01/17/2024 DM26 Research regarding upcoming rule 2004

information and corporate documents (2.6); review corporate documents regarding same (.8); prepare chart of required information for E. Sutton (1.3) 4.70 565.00 2,655.50 01/17/2024 ECS1 Correspond with A. Bongartz regarding update on rule 2004 discovery process 0.10 1,270.00 127.00 01/17/2024 ECS1 Prepare correspondence to rule 2004 targets

and subpoenas (.8); correspond with A.

(NPM) regarding same (.3) 1.10 1,270.00 1,397.00 01/17/2024 ECS1 Review information regarding Kwok, his affiliates and assets, their connections to Kwok, and their corporate information 0.50 1,270.00 635.00 01/17/2024 ECS1 Correspond with D. Mohamed re targets

01/17/2024 JPK1 Review Rule 2004 correspondence with B. Ha, counsel for Rule of Law entities (.2);

01/17/2024 AEL2 Correspond with E. Sutton re: outstanding ROLF/ROLS discovery 0.10 1,850.00 185.00 01/17/2024 AEL2 Call with N. Bassett re: rule 2004

01/17/2024 AEL2 Prepare plan for counsel rule 2004

01/17/2024 LS26 Review document production in response to rule 2004 discovery 0.20 985.00 197.00

Case 22-50073 Doc 3283 Filed 06/24/24 Entered 06/24/24 18:35:48 Page 132 of 562

Luc Despins as Chapter 11 Trustee in the case of Ho Wan Kwok 50687-00002 Invoice No. 2395792

Date Initials Description Hours Rate Amount 01/17/2024 NAB Call with A. Luft regarding rule 2004 depositions and related strategy (.4); analyze authority regarding jurisdictional issues (.3) 0.70 1,835.00 1,284.50 01/18/2024 DM26 Research regarding upcoming rule 2004 targets for registered agent/service information and corporate documents (1.4); review corporate documents regarding same (.5); prepare chart of required information for E. Sutton (.7) 2.60 565.00 1,469.00 01/18/2024 DEB4 Participate in (portion of) update call with Kroll, L. Despins, N. Bassett regarding forensic analysis (0.9); correspond with L. Song regarding Kwok affiliates/individuals in UAE (0.1); correspond with L. Song regarding Junjie Jiang and Jinjing Lu (0.1); correspond with L. Song regarding Annie Chun (0.1); conference with N. Bassett, J. Kosciewicz, and S. Kim regarding rule 2004 issues (0.5); correspond with A. Luft regarding Open Bank (0.1); correspond with E. Sutton regarding same (0.1) 1.90 1,395.00 2,650.50 01/18/2024 ECS1 Prepare correspondence to rule 2004 targets regarding outstanding rule 2004 motions and subpoenas (.3); correspond with A. Luft, W. Farmer, S. Maza and P. Linsey (NPM) regarding same (.1) 0.40 1,270.00 508.00 01/18/2024 ECS1 Review information regarding Kwok, his affiliates and assets, their connections to Kwok, and their corporate information 0.20 1,270.00 254.00 01/18/2024 JPK1 Correspond with W. Farmer regarding targeted searches of certain Rule 2004 productions 0.20 1,185.00 237.00 01/18/2024 JPK1 Correspond with S. Phan regarding targeted searches for certain Rule 2004 depositions 0.70 1,185.00 829.50 01/18/2024 JPK1 Call with S. Kim regarding additional Rule 2004 targets 0.50 1,185.00 592.50 01/18/2024 JPK1 Telephone conference with N. Bassett, D. Barron, and S. Kim regarding additional 0.50 1,185.00 592.50

Date Initials Description Hours Rate Amount

01/18/2024 LAD4 Handle update call with Kroll, N. Bassett,

01/18/2024 AEL2 Participate in call with Kroll, L. Despins, N. Bassett and D. Barron regarding financial investigation updates 1.70 1,850.00 3,145.00 01/18/2024 AEL2 Meeting with N. Bassett, S. Kim, D. Barron and J. Kosciewicz re: additional rule 2004

01/18/2024 NAB Attend portion of call with L. Despins, D.

updates and strategy (.5); call with D. Barron, S. Kim, J. Kosciewicz regarding rule 2004 depositions (.5) 1.00 1,835.00 1,835.00 01/18/2024 SK35 Conference with J. Kosciewicz regarding

documents (0.5); call with J. Kosciewicz, N.

Rule 2004 targets (0.5) 1.00 985.00 985.00 01/19/2024 AB21 Correspond with D. Barron regarding Swiss

documents (0.4); correspond with D. Hayel (Prager) regarding same (0.3); correspond with L. Despins regarding same (0.1) 1.10 1,850.00 2,035.00 01/19/2024 DEB4 Correspond with A. Bongartz regarding Switzerland transfers 0.30 1,395.00 418.50 01/19/2024 JPK1 Correspond with D. Barron regarding Gettr supplemental Rule 2004 production 0.10 1,185.00 118.50 01/20/2024 LS26 Update list of Kwok related entities 2.00 985.00 1,970.00

Case 22-50073 Doc 3283 Filed 06/24/24 Entered 06/24/24 18:35:48 Page 134 of 562 Luc Despins as Chapter 11 Trustee in the case of Ho Wan Kwok 50687-00002 Invoice No. 2395792

Date Initials Description Hours Rate Amount

01/21/2024 DEB4 Correspond with P. Parizek (Kroll) regarding UAE information (0.2); correspond with P. Parizek regarding bank spreadsheets (0.4); correspond with J. Kuo regarding transferee address (0.1);

with L. Despins regarding Bankruptcy Code section 550 (0.1); correspond with A. Chan regarding Hong Kong law (0.1); correspond with P. Parizek regarding Mbaer documents

01/21/2024 ECS1 Prepare responses to rule 2004 targets

meet and confers, and subpoenas 0.20 1,270.00 254.00 01/21/2024 LS26 Review correspondence from informant (0.5); review document production in rule 2004 discovery (0.6) 1.10 985.00 1,083.50 01/22/2024 AB21 Call with D. Barron regarding Swiss

(0.2); correspond with D. Barron regarding same (0.1); review correspondence from M. Mark (Prager) regarding same (0.1) 0.40 1,850.00 740.00 01/22/2024 DEB4 Conference with A. Bongartz regarding Swiss counsel inquiries (0.2); correspond with J. Kuo regarding documents related to

regarding NDA for Swiss counsel (0.1); analyze documents related to same (0.2); correspond with Kroll regarding Birchstone

Case 22-50073 Doc 3283 Filed 06/24/24 Entered 06/24/24 18:35:48 Page 135 of 562

Luc Despins as Chapter 11 Trustee in the case of Ho Wan Kwok 50687-00002 Invoice No. 2395792

Date Initials Description Hours Rate Amount 01/22/2024 DEB4 Correspond with L. Despins regarding Princes Gate (0.2); correspond with A. Lomas (Kroll) regarding same (0.1); conference and correspond with L. Song regarding Haoran He entities (0.5); correspond with A. Thorp (Harneys) regarding BVI registered agents (0.1); correspond with A. Luft regarding Shaban letter (0.2); correspond with S. Maza regarding avoidance case law (0.2); correspond with L. Song regarding Mbaer documents (0.1) 1.40 1,395.00 1,953.00 01/22/2024 DEB4 Further conference with L. Song regarding Haoran He issues (0.4); correspond with A. Luft and L. Despins regarding same (0.2) 0.60 1,395.00 837.00 01/22/2024 JPK1 Correspond with L. Song regarding bank statements 0.20 1,185.00 237.00 01/22/2024 AEL2 Correspond with D. Barron re: He discovery 0.30 1,850.00 555.00 01/22/2024 AEL2 Correspond with L. Song re: rule 2004 depositions 0.70 1,850.00 1,295.00 01/22/2024 LS26 Review document production in rule 2004 discovery 4.10 985.00 4,038.50 01/22/2024 SK35 Analyze key pleadings, certain case documents, and memorandum and outline 5.90 985.00 5,811.50 1.00 420.00 420.00

01/23/2024 AR17 Conduct UK docket search for D. Barron with respect to certain parties and filings

Case 22-50073 Doc 3283 Filed 06/24/24 Entered 06/24/24 18:35:48 Page 136 of 562

Date Initials Description Hours Rate Amount

01/23/2024 DEB4 Conference with L. Song regarding Haoran

regarding same (0.1); conference with A. Luft and L. Song regarding Zeisler payors

bank documents (0.4); correspond with L. Despins regarding Zeisler disclosure (0.1);

unlocking devices (0.1); correspond with P.

same (0.3); correspond with L. Song and J. Kosciewicz regarding same (0.1);

court documents (0.1); analyze same (0.3) 2.60 1,395.00 3,627.00 01/23/2024 DEB4 Conference with S. Kim regarding (0.5);

documents from Cohn Birnbaum (0.3) 0.80 1,395.00 1,116.00 01/23/2024 DEB4 Analyze documents related to G Club issues 2.20 1,395.00 3,069.00 01/23/2024 DEB4 Correspond with L. Song regarding G Club 0.10 1,395.00 139.50 01/23/2024 JPK1 Correspond with J. Weddle regarding

01/23/2024 PK1 Draft parts of Rule 2004 deposition outline

document production (.4) 2.40 1,185.00 2,844.00 01/23/2024 IPK1 Telephone call with S. Kim regarding 0.70 1,185.00 829.50 01/23/2024 JPK1 Telephone call with L. Song regarding Rule

01/23/2024 LAD4 Review Lee judgment in UK against

01/23/2024 AEL2 Meet with L. Song and D. Barron re: Zeisler 0.80 1,850.00 1,480.00

Case 22-50073 Doc 3283 Filed 06/24/24 Entered 06/24/24 18:35:48 Page 137 of 562 Luc Despins as Chapter 11 Trustee in the case of Ho Wan Kwok 50687-00002 Invoice No. 2395792

Date Initials Description Hours Rate Amount

01/23/2024 LS26 Review document production in rule 2004

(0.1); conference with J. Kosciewicz re same and Rule 2004 depositions (0.3); conference

related entities and transfers (0.8) 9.00 985.00 8,865.00 01/23/2024 SK35 Conference with J. Kosciewicz regarding

follow up notes regarding same (0.1);

01/24/2024 AB21 Correspond with M. Meili (Prager) regarding Swiss investigation (0.3); call with D. Barron regarding same (0.1) 0.40 1,850.00 740.00 01/24/2024 DEB4 Correspond with L. Despins regarding (0.2); conference with A. Bongartz regarding Swiss investigation (0.1); correspond with A. Lomas (Kroll) regarding Gettr (0.1); correspond with Kroll regarding (0.1); correspond with L. Song regarding Berkeley Rowe (0.1);

with A. Lomas regarding transfer data (0.2) 1.00 1,395.00 1,395.00 01/24/2024 JK21 Correspond with K. Catalano regarding motion to dismiss precedent 0.30 565.00 169.50 01/24/2024 JPK1 Review Bankruptcy Court's orders

documents (.3); correspond with D. Barron regarding the same (.1) 0.40 1,185.00 474.00 01/24/2024 LS26 Review document production in rule 2004

(0.3); correspond with S. Kim re rule 2004

Case 22-50073 Doc 3283 Filed 06/24/24 Entered 06/24/24 18:35:48 Page 138 of 562

Date Initials Description Hours Rate Amount

1/24/2024 SK35 Review key filings and related case

(1.6);

(0.4);

1/25/2024 DEB4 Update call with Kroll, L. Despins, N. Bassett, A. Luft regarding ongoing forensic

1/25/2024 LAD4 Participate in portion of Kroll weekly call with N. Bassett, A. Luft, D. Barron 0.30 1,975.00 592.50 1/25/2024 AEL2 Update call with Kroll, L. Despins, N.

1/25/2024 LS26 Review document production in rule 2004

entities (2.4); prepare summary re same (0.4) 2.80 985.00 2,758.00 1/25/2024 NAB Call with A. Luft, D. Barron, and Kroll regarding investigation updates and analysis 0.70 1,835.00 1,284.50 1/25/2024 SK35 Continue preparing 5.90 985.00 5,811.50 1/26/2024 IPK1 Continue drafting Open Bank Rule 2004 deposition outline 3.50 1,185.00 4,147.50 1/26/2024 SK35 Prepare 5.60 985.00 5,516.00 1/28/2024 DEB4 Correspond with L. Song regarding G Club documents (0.3); analyze same (2.5);

Kroll regarding Gettr transaction (0.3);

Creation (0.4); correspond with L. Song 4.20 1,395.00 5,859.00

Case 22-50073 Doc 3283 Filed 06/24/24 Entered 06/24/24 18:35:48 Page 139 of 562

Date Initials Description Hours Rate Amount

01/29/2024 DEB4 Correspond with E. Sutton regarding Cyprus firm (0.1); correspond with L.

with L. Despins regarding Qiang Guo (0.1);

Netherland (0.1); correspond with A. Lomas regarding Lexington staffing (0.1);

passports (0.1); correspond with P. Parizek regarding Kwok vehicles (0.1); correspond with L. Song regarding Eastern profit case documents (0.1) 0.90 1,395.00 1,255.50 01/29/2024 FCS1 Review and summarize documents produced in response to discovery requests (.2); correspond with S. Phan (UnitedLex), W. Farmer, and L. Song regarding same (.1) 0.30 1,270.00 381.00 01/29/2024 FC21 Call with P. Linsey (NPM) regarding

and subpoenas relating thereto 0.20 1,270.00 254.00 01/29/2024 FC21 Analyze information regarding Kwok, his affiliates and assets, their connections to Kwok, and their corporate information 0.50 1,270.00 635.00 01/29/2024 ECS1 Prepare responses to rule 2004 targets

01/29/2024 PK1 Correspond with P. Linsey (NPM)

August 11, 2023 brief 0.20 1,185.00 237.00 01/29/2024 JPK1 Correspond with E. Sutton regarding additional Rule 2004 production from Rule of Law Foundation and Rule of Law Society (.1); correspond with E. Sutton regarding Theriault subpoena (.1) 0.20 1,185.00 237.00 01/29/2024 NAB Correspond with P. Linsey regarding G Club appeal issues 0.20 1,835.00 367.00 01/29/2024 SK35 Continue preparing 3.80 985.00 3,743.00 01/30/2024 AB21 Call with L. Despins and D. Hayek (Prager) 0.50 1,850.00 925.00

Case 22-50073 Doc 3283 Filed 06/24/24 Entered 06/24/24 18:35:48 Page 140 of 562

Date Initials Description Hours Rate Amount

01/30/2024 DM26 Research regarding certain rule 2004 targets for service information 1.30 565.00 734.50 01/30/2024 ECS1 Call and correspond with P. Linsey (NPM) regarding eleventh supplemental Rule 2004 motion and subpoenas relating thereto 0.30 1,270.00 381.00 01/30/2024 HCS1 Prepare thirteenth supplemental Rule 2004 motion (.4); analyze information regarding targets in connection with same (.1);

01/30/2024 ECS1 Prepare responses to rule 2004 targets

01/30/2024 ECS1 Analyze information regarding Kwok, his affiliates and assets, their connections to Kwok, and their corporate information 0.60 1,270.00 762.00 01/30/2024 IDA Research regarding M.M. Anzaldua 1.30 420.00 546.00

regarding the same (.1) 0.40 1,185.00 474.00 01/30/2024 PK1 Correspond with L. Song regarding Medici

(.1); correspond with D. Barron regarding

01/30/2024 IPK1 Draft parts of Open Bank Rule 2004 deposition outline (2.1); review Open Bank

investioation (50) 0.90 1,975.00 1,777.50

Case 22-50073 Doc 3283 Filed 06/24/24 Entered 06/24/24 18:35:48 Page 141 of 562

Date Initials Description Hours Rate Amount

01/30/2024 LS26 Review documents related to Himalaya entities (2.4); review documents related to Hamilton entities (3.6); prepare summary re

same (0.2); review social media content re

investigation targets and assets (0.4) 7.20 985.00 7,092.00 01/30/2024 SK35 Prepare parts of 0.50 985.00 492.50 01/31/2024 DM26 Research service information regarding certain rule 2004 targets 2.60 565.00 1,469.00 01/31/2024 DEB4 Correspond with P. Linsey regarding Wang

01/31/2024 ECS1 Prepare responses to rule 2004 targets

01/31/2024 ECS1 Review information regarding Kwok, his affiliates and assets, their connections to Kwok, and their corporate information 0.10 1,270.00 127.00 01/31/2024 JPK1 Correspond with L. Song regarding Medici Bank Rule 2004 deposition outline 0.30 1,185.00 355.50 01/31/2024 JPK1 Review Medici Bank documents in G Club and Mercantile Bank productions 2.30 1,185.00 2,725.50 01/31/2024 LS26 Review document production in rule 2004 discovery (0.7); prepare summary re: Rule of

01/31/2024 SK35 Prepare parts of 0.70 985.00 689.50 Subtotal: B261 Investigations 210.20 257,574.50

ID Timekeeper Name Title Hours Rate Fee

HP1 Helena Potts Partner 1.00 2,150.00 2,150.00 LAD4 Luc A. Despins Partner 13.90 1,975.00 27,452.50 NAB Nicholas A. Bassett Partner 28.50 1,835.00 52,297.50 AB21 Alex Bongartz Of Counsel 6.40 1,850.00 11,840.00 AEL2 Luft, Avi E. Of Counsel 26.60 1,850.00 49,210.00 DEB4 Douglass E. Barron Associate 82.25 1,395.00 114,738.75 SM29 Shlomo Maza Associate 69.50 1,395.00 96,952.50 WCF Will C. Farmer Associate 0.90 1,390.00 1,251.00 MJ8 Maanas Jain Associate 3.00 1,390.00 4,170.00 ECS1 Ezra C. Sutton Associate 38.70 1,270.00 49,149.00 KC27 Kristin Catalano Associate 31.20 1,185.00 36,972.00 JPK1 Jon P. Kosciewicz Associate 52.50 1,185.00 62,212.50 LS26 Luyi Song Associate 46.60 985.00 45,901.00 SK35 Sarah Kim Associate 31.10 985.00 30,633.50 DM26 David Mohamed Paralegal 19.60 565.00 11,074.00 JK21 Jocelyn Kuo Paralegal 26.40 565.00 14,916.00

Date Description Quantity Rate Amount

01/04/2024 Photocopy Charges (Color) 36.00 0.20 7.20 01/10/2024 Photocopy Charges 541.00 0.08 43.28 01/31/2024 Photocopy Charges 1,317.00 0.08 105.36 01/31/2024 Photocopy Charges 46.00 0.08 3.68 01/31/2024 Photocopy Charges 123.00 0.08 9.84

Case 22-50073 Doc 3283 Filed 06/24/24 Entered 06/24/24 18:35:48 Page 143 of 562

Luc Despins as Chapter 11 Trustee in the case of Ho Wan Page 46

01/01/2024 Electronic Document Retrieval -

and Alternative Data Solutions, Inc., Invoice# 1047352-202312-1 Dated 01/01/24, TLO Charges

01/01/2024 Computer Search (Other) 1.98

Seamlessweb (USD) (JPMSUA); Invoice # SL-190- 85 dated 01/14/2024; Douglass Barron; Number of People: 1; Restaurant: Thai Chella; Location: New York; Working Late on Kwok Matters ; Order #

01/02/2024 Computer Search (Other) 4.50

Douglass Barron; 12/06/2023; Restaurant: Oki Poke Raman ; City: New York ; Dinner; Number of people: 1; working meal while

expenses incurred at courthouse in Bridgeport,

expenses incurred at courthouse in Bridgeport,

expenses incurred at courthouse in Bridgeport,

01/03/2024 Computer Search (Other) 2.25 01/03/2024 Computer Search (Other) 6.21

01/04/2024 Computer Search (Other) 6.75

Invoice# 40751 Dated 01/05/24, Service of a

Luc Despins as Chapter 11 Trustee in the case of Ho Wan Page 47

01/05/2024 Outside Professional Services -

Corporation, Invoice# 1705 Dated 01/05/24, Assistance with service of Trustee's complaint against Rui Hao pursuant to Hague Convention. 720.00

01/05/2024 Computer Search (Other) 2.70 01/05/2024 Computer Search (Other) 5.04

Seamlessweb (USD) (JPMSUA); Invoice # SL-190- 85 dated 01/14/2024; Douglass Barron;

people: 1; Restaurant: Silky Kitchen; Location: New York; Dinner working late on Kwok matter ; Order

01/08/2024 Computer Search (Other) 14.58

01/09/2024 Computer Search (Other) 39.15 01/10/2024 Outside Professional Services -

Solutions, LLC, Invoice# 2024-15 Dated 01/10/24,

Documents, Kwok matter French to English. 1,455.75 01/10/2024 Computer Search (Other) 11.88

01/11/2024 Computer Search (Other) 0.36

Case 22-50073 Doc 3283 Filed 06/24/24 Entered 06/24/24 18:35:48 Page 145 of 562

Luc Despins as Chapter 11 Trustee in the case of Ho Wan Page 48

01/12/2024 Computer Search (Other) 7.83

01/13/2024 Computer Search (Other) 4.23

01/16/2024 Computer Search (Other) 0.36

UPS (USD)(JPMPCARD); Invoice # 00000A6T163034; 01/17/2024; Sharon Jones Santiag; East West Bank; 135 N. Los Robles Avenue; Pasadena, CA 911011758 ;

01/17/2024 Computer Search (Other) 6.21

01/18/2024 Computer Search (Other) 4.50

01/19/2024 Computer Search (Other) 4.14

Seamlessweb (USD) (JPMSUA); Invoice # SL-190- 86 dated 01/28/2024; Douglass Barron; Number of people: 1; Restaurant: Bangkok 2 Thai; Location: New York; Working late on Kwok matter ; Order #

Case 22-50073 Doc 3283 Filed 06/24/24 Entered 06/24/24 18:35:48 Page 146 of 562

Luc Despins as Chapter 11 Trustee in the case of Ho Wan Page 49

01/23/2024 Computer Search (Other) 3.15

01/24/2024 Computer Search (Other) 3.78

01/25/2024 Computer Search (Other) 2.88

Seamlessweb (USD) (JPMSUA); Invoice # SL-190- 86 dated 01/28/2024; Douglass Barron; Number of people: 1; Restaurant: Bangkok 2 Thai; Location: New York; Working on Kwok Matters ; Order #

01/29/2024 Outside Professional Services -

01/29/24, Payment to ad agency in connection with court-approved publication notice. 10,247.80

01/29/2024 Computer Search (Other) 5.58

Limited, Invoice# 0000048808 Dated 01/31/24,

Case 22-50073 Doc 3283 Filed 06/24/24 Entered 06/24/24 18:35:48 Page 147 of 562

Luc Despins as Chapter 11 Trustee in the case of Ho Wan Page 50

David Mohamed; 01/17/2024; Purchase of corporate Records for Roadway Moving, Inc. from NJ-DOT; Merchant: Nj Busines Services Location: Egov.Com, NJ 08608-0000 , Statement Date: 01/31/2024, Post Date:

David Mohamed; 01/11/2024; Purchase of Status Report for 5700 MCD ASSETS II LLC from the DE-SOS; Merchant: Delaware Corp & Tax Web Location: 302-739-3073, DE 19901-0000 , Statement Date: 01/31/2024, Post

David Mohamed; 01/12/2024; Purchase of Status Report for KNIGHT FRANK, INC. from the DE-SOS; Merchant: Delaware Corp & Tax Web Location: 302-739-3073, DE 19901- 0000 , Statement Date: 01/31/2024, Post Date:

David Mohamed; 01/17/2024; Purchase of status reports for 5 entities-BSI Group America Inc., BSI Group LLC, Sherry-Lehmann West, LLC, Sherry-Lehmann.com, Inc. and Stradley Ronon Stevens & Young, LLC from DE-SOS; Merchant: Delaware Corp & Tax Web Location: 302-739-3073, DE 19901-0000 , Statement Date: 01/31/2024, Post Date: 01/18/2024; Service

David Mohamed; 01/17/2024; Purchase of status reports for 5 entities-BSI Group America Inc., BSI Group LLC, Sherry-Lehmann West, LLC, Sherry-Lehmann.com, Inc. and Stradley Ronon Stevens & Young, LLC from DE-SOS; Merchant: Delaware Corp & Tax Web Location: 302-739-3073, DE 19901-0000 , Statement Date: 01/31/2024, Post Date: 01/18/2024; Service

Case 22-50073 Doc 3283 Filed 06/24/24 Entered 06/24/24 18:35:48 Page 148 of 562

Luc Despins as Chapter 11 Trustee in the case of Ho Wan Page 51

David Mohamed; 01/17/2024; Purchase of status reports for 5 entities-BSI Group America Inc., BSI Group LLC, Sherry-Lehmann West, LLC, Sherry-Lehmann.com, Inc. and Stradley Ronon Stevens & Young, LLC from DE-SOS; Merchant: Delaware Corp & Tax Web Location: 302-739-3073, DE 19901-0000 , Statement Date: 01/31/2024, Post Date: 01/18/2024; Service

David Mohamed; 01/17/2024; Purchase of status reports for 5 entities-BSI Group America Inc., BSI Group LLC, Sherry-Lehmann West, LLC, Sherry-Lehmann.com, Inc. and Stradley Ronon Stevens & Young, LLC from DE-SOS; Merchant: Delaware Corp & Tax Web Location: 302-739-3073, DE 19901-0000 , Statement Date: 01/31/2024, Post Date: 01/18/2024; Service

David Mohamed; 01/17/2024; Purchase of status reports for 5 entities-BSI Group America Inc., BSI Group LLC, Sherry-Lehmann West, LLC, Sherry-Lehmann.com, Inc. and Stradley Ronon Stevens & Young, LLC from DE-SOS; Merchant: Delaware Corp & Tax Web Location: 302-739-3073, DE 19901-0000 , Statement Date: 01/31/2024, Post Date: 01/18/2024; Service

David Mohamed; 01/03/2024; Status Reports for G SERVICES LLC from the DE-SOS; Merchant: Delaware Corp & Tax Web

Statement Date: 01/31/2024, Post Date:

David Mohamed; 01/03/2024; Status Reports for G SERVICES LLC from the DE-SOS; Merchant: Delaware Corp & Tax Web

Statement Date: 01/31/2024, Post Date:

Case 22-50073 Doc 3283 Filed 06/24/24 Entered 06/24/24 18:35:48 Page 149 of 562

Luc Despins as Chapter 11 Trustee in the case of Ho Wan Page 52

David Mohamed; 01/12/2024; Purchase of Status Report for KNIGHT FRANK, INC. from the DE-SOS; Merchant: Dcca Electronic

Statement Date: 01/31/2024, Post Date:

David Mohamed; 01/17/2024; Purchase of corporate records Aviation Trust Company, LLC from the OK-SOS; Merchant: Secretary Of State Location: Oklahoma City, OK 73103-0000 , Statement Date: 01/31/2024, Post

David Mohamed; 01/11/2024; Purchase of Status Report for 5700 MCD ASSETS II LLC from the DE-SOS; Merchant: United Corp Services Location: 914-949-9188, NY 10606-0000 , Statement Date: 01/31/2024, Post Date:

David Mohamed; 01/17/2024; Purchase of corporate records for Roadway Moving Inc. from the PA-DOS; Merchant: Pa Bcco Corp Fee-Dos Location: 717-783-9195, PA 17120-0000 , Statement Date: 01/31/2024, Post Date:

Status Reports for G SERVICES LLC from the DE-SOS; Merchant: Delaware Corp & Tax Web

Statement Date: 01/31/2024, Post Date:

David Mohamed; 01/03/2024;

Luc Despins as Chapter 11 Trustee in the case of Ho Wan Kwok 200 Park Avenue New York, NY 10166

Attn: Luc Despins PH LLP Tax ID No. 95-2209675

Other Litigation PH LLP Client/Matter # 50687-00003 Luc A. Despins

Legal fees for professional services for the period ending January 31, 2024 \$57,079.00

We encourage our clients to pay via ACH, however, in the event that you pay by check, please send payment to the remittance address below:

*TO PROTECT AGAINST FRAUD, the Firm will not change its wiring instructions via email. We strongly encourage clients to confirm any change in wiring instructions by contacting Teri Goffredo @ 213-683-5045 or via email @ terigoffredo@paulhastings.com and requesting written and verbal confirmation.*

Wiring and ACH Instructions: Remittance Address: Pay by Tranch:

Citibank Paul Hastings LLP You can now pay your invoices online via ABA # 322271724 Lockbox 4803 real-time bank payments, credit cards or SWIFT Address: CITIUS33 PO Box 894803 in installments:

*For wires, please reference the invoice, client and matter number(s) being paid For ACH payments, please use the CTX format and/or send any remittances to cashepn@paulhastings com This is a no-reply mailbox*

Luc Despins as Chapter 11 Trustee in the case of Ho Wan Kwok 200 Park Avenue New York, NY 10166

Attn: Luc Despins PH LLP Tax ID No. 95-2209675

Other Litigation PH LLP Client/Matter # 50687-00003 Luc A. Despins

Legal fees for professional services for the period ending January 31, 2024 \$57,079.00

We encourage our clients to pay via ACH, however, in the event that you pay by check, please send payment to the remittance address below:

*TO PROTECT AGAINST FRAUD, the Firm will not change its wiring instructions via email. We strongly encourage clients to confirm any change in wiring instructions by contacting Teri Goffredo @ 213-683-5045 or via email @ terigoffredo@paulhastings.com and requesting written and verbal confirmation.*

Wiring and ACH Instructions: Remittance Address: Pay by Tranch:

Citibank Paul Hastings LLP You can now pay your invoices online via ABA # 322271724 Lockbox 4803 real-time bank payments, credit cards or SWIFT Address: CITIUS33 PO Box 894803 in installments:

*For wires, please reference the invoice, client and matter number(s) being paid For ACH payments, please use the CTX format and/or send any remittances to cashepn@paulhastings com This is a no-reply mailbox*

Case 22-50073 Doc 3283 Filed 06/24/24 Entered 06/24/24 18:35:48 Page 152 of 562

PAUL HASTINGS LLP 200 Park Avenue, New York, NY 10166-3205 t: +1.212.318.6000 f: +1.212.319.4090 www.paulhastings.com

Attn: Luc Despins PH LLP Tax ID No. 95-2209675

FOR PROFESSIONAL SERVICES RENDERED for the period ending January 31, 2024

Date Initials Description Hours Rate Amount

01/03/2024 NAB Call with L. Despins and DOJ regarding criminal trial (.3); follow-up call with L.

with A. Luft regarding criminal trial (.4);

01/04/2024 AB21 Prepare bankruptcy court notice of

correspond with L. Despins regarding same

filing and service of same (0.1) 0.40 1,850.00 740.00 01/04/2024 DEB4 Correspond with L. Despins and N. Bassett regarding new indictment (0.4); correspond with J. Kuo regarding same (0.1);

(0.1); analyze same (0.3); analyze reply in

criminal case (0.4) 1.30 1,395.00 1,813.50 01/04/2024 JK21 Prepare comparison of superseding indictment in Kwok criminal case 0.20 565.00 113.00

Case 22-50073 Doc 3283 Filed 06/24/24 Entered 06/24/24 18:35:48 Page 153 of 562 Luc Despins as Chapter 11 Trustee in the case of Ho Wan Kwok 50687-00003 Invoice No. 2395793

Date Initials Description Hours Rate Amount

01/04/2024 JK21 Correspond with A. Bongartz regarding

regarding filing notice of filing superseding indictment in Kwok criminal case (0.1);

indictment (0.2); electronically file with the

indictment (0.1); review and handle service of notice of filing superseding indictment

01/04/2024 JK21 Correspond with L. Despins regarding

01/04/2024 LAD4 Review bail denial order (.30); review superseding indictment (1.10) 1.40 1,975.00 2,765.00 01/04/2024 AEL2 Analyze criminal RICO indictment 0.60 1,850.00 1,110.00 01/04/2024 NAB Review motion for reconsideration of

additional filings in criminal case (1.2);

regarding same and litigation strategy (.6) 1.80 1,835.00 3,303.00 01/05/2024 JK21 Correspond with L. Despins regarding

01/05/2024 LAD4 Review renewed motion to stay chapter 11 cases and analyze response (1.10); t/c S. Sarnoff & P. Friedman (OMM) re: forfeiture issues (.50); review letter filed by

re: forfeiture issues (.40) 2.40 1,975.00 4,740.00 01/08/2024 AB21 Prepare notice regarding Debtor's renewed stay motion (0.4); correspond with L.

with J. Kuo regarding filing and service of

01/08/2024 JK21 Correspond with S. Maza regarding Kwok criminal scheduling order 0.20 565.00 113.00

Case 22-50073 Doc 3283 Filed 06/24/24 Entered 06/24/24 18:35:48 Page 154 of 562 Luc Despins as Chapter 11 Trustee in the case of Ho Wan Kwok 50687-00003 Invoice No. 2395793

Date Initials Description Hours Rate Amount

01/08/2024 JK21 Correspond with A. Bongartz regarding filing of notice of Debtor's renewed motion to stay chapter 11 cases (0.1); prepare notice of Debtor's renewed motion to stay chapter 11 cases (0.1); electronically file with the court notice of Debtor's renewed motion to

01/08/2024 NAB Correspond with L. Despins regarding criminal court stay motion (.2); review and revise draft notice regarding same (.2);

steps related to criminal case developments

01/11/2024 NAB Review and comment on issues related to criminal trial (.2); correspond with L.

01/12/2024 NAB Review additional criminal case filings

01/16/2024 JK21 Correspond with L. Despins regarding

01/16/2024 LAD4 Review recent criminal court filings (Geyer

01/16/2024 NAB Prepare parts of response to criminal court stay motion (.4); correspond with L. Despins and W. Farmer regarding same (.1) 0.50 1,835.00 917.50 01/17/2024 LAD4 T/c J. Murray (DOJ) & N. Bassett re: update on chapter 11 case 0.50 1,975.00 987.50 01/17/2024 NAB Correspond with L. Despins regarding criminal court stay motion and criminal case issues (.3); calls with Government and L. Despins regarding same (.5); prepare draft 1.70 1,835.00 3,119.50

Case 22-50073 Doc 3283 Filed 06/24/24 Entered 06/24/24 18:35:48 Page 155 of 562

Date Initials Description Hours Rate Amount

01/18/2024 JK21 Correspond with L. Despins regarding

01/18/2024 NAB Draft parts of response to renewed motion to stay bankruptcy case (3.3); correspond with W. Farmer regarding same (.3); analyze case law and pleadings in connection with same (.8); further draft response to criminal court stay motion (.7) 5.10 1,835.00 9,358.50 01/18/2024 WCF Draft response to Kwok criminal case

(2.9); analyze authorities regarding same (.5) 3.40 1,390.00 4,726.00 01/19/2024 JK21 Correspond with L. Despins regarding

01/19/2024 JK21 Correspond with W. Farmer regarding filing

Kwok criminal case 23-118 (0.2); electronically file with the court response to

01/19/2024 NAB Review and revise draft response to stay

with L. Despins regarding same (.3); further

to bankruptcy stay motion (.2) 2.30 1,835.00 4,220.50 01/19/2024 WCF Revise response to Debtor's renewed stay motion (1.4); correspond with N. Bassett, L. Despins regarding same (.2) 1.60 1,390.00 2,224.00 01/25/2024 AB21 Prepare notice regarding update on Kwok's renewed stay motion (0.3); correspond with L. Despins regarding same (0.1) 0.40 1,850.00 740.00 01/26/2024 AB21 Correspond with J. Kuo regarding filing notice regarding update on Kwok's renewed

Case 22-50073 Doc 3283 Filed 06/24/24 Entered 06/24/24 18:35:48 Page 156 of 562

Luc Despins as Chapter 11 Trustee in the case of Ho Wan Kwok 50687-00003 Invoice No. 2395793

Date Initials Description Hours Rate Amount

01/26/2024 JK21 Correspond with A. Bongartz regarding

motion to stay bankruptcy cases (0.1); prepare notice of update on stay motion for electronic filing (0.1); electronically file with the court notice of update on stay motion (0.1); review and handle service of notice of update on stay motion (0.2) 0.50 565.00 282.50 01/26/2024 NAB Review reply brief in support of criminal court stay motion 0.20 1,835.00 367.00 01/27/2024 NAB Further review reply brief in support of staying bankruptcy cases (.3); correspond with L. Despins regarding same (.1) 0.40 1,835.00 734.00 01/28/2024 LAD4 Review reply filed by Kwok in criminal case re: stay of chapter 11 case 0.50 1,975.00 987.50 01/31/2024 ECS1 Prepare response to grand jury subpoena

served on Paul Hastings (1.9); correspond

same (.5); correspond with I. Loftus (U.S. DOJ) regarding same (.2); correspond with

& Bliss PC) regarding same (.2); correspond

01/31/2024 NAB Review DOJ subpoena and prepare parts of response to same (.4); correspond with E. Sutton regarding same (.1) 0.50 1,835.00 917.50 Subtotal: B191 General Litigation 35.50 57,079.00

ID Timekeeper Name Title Hours Rate Fee LAD4 Luc A. Despins Partner 5.50 1,975.00 10,862.50

NAB Nicholas A. Bassett Partner 15.00 1,835.00 27,525.00 Case 22-50073 Doc 3283 Filed 06/24/24 Entered 06/24/24 18:35:48 Page 157 of 562

Luc Despins as Chapter 11 Trustee in the case of Ho Wan Kwok 50687-00003 Invoice No. 2395793

AB21 Alex Bongartz Of Counsel 1.60 1,850.00 2,960.00

AEL2 Luft, Avi E. Of Counsel 0.60 1,850.00 1,110.00 DEB4 Douglass E. Barron Associate 1.30 1,395.00 1,813.50 WCF Will C. Farmer Associate 5.00 1,390.00 6,950.00 ECS1 Ezra C. Sutton Associate 3.10 1,270.00 3,937.00 JK21 Jocelyn Kuo Paralegal 3.40 565.00 1,921.00

Date Description Quantity Rate Amount

01/25/2024 Computer Search (Other) 4.32 Total Costs incurred and advanced \$602.82

Luc Despins as Chapter 11 Trustee in the case of Ho Wan Kwok 200 Park Avenue New York, NY 10166

Attn: Luc Despins PH LLP Tax ID No. 95-2209675

Sales Process PH LLP Client/Matter # 50687-00005 Luc A. Despins

Legal fees for professional services for the period ending January 31, 2024 \$1,819.00

We encourage our clients to pay via ACH, however, in the event that you pay by check, please send payment to the remittance address below:

*TO PROTECT AGAINST FRAUD, the Firm will not change its wiring instructions via email. We strongly encourage clients to confirm any change in wiring instructions by contacting Teri Goffredo @ 213-683-5045 or via email @ terigoffredo@paulhastings.com and requesting written and verbal confirmation.*

Wiring and ACH Instructions: Remittance Address: Pay by Tranch:

Citibank Paul Hastings LLP You can now pay your invoices online via ABA # 322271724 Lockbox 4803 real-time bank payments, credit cards or SWIFT Address: CITIUS33 PO Box 894803 in installments:

*For wires, please reference the invoice, client and matter number(s) being paid For ACH payments, please use the CTX format and/or send any remittances to cashepn@paulhastings com This is a no-reply mailbox*

Luc Despins as Chapter 11 Trustee in the case of Ho Wan Kwok 200 Park Avenue New York, NY 10166

Attn: Luc Despins PH LLP Tax ID No. 95-2209675

Sales Process PH LLP Client/Matter # 50687-00005 Luc A. Despins

Legal fees for professional services for the period ending January 31, 2024 \$1,819.00

We encourage our clients to pay via ACH, however, in the event that you pay by check, please send payment to the remittance address below:

*TO PROTECT AGAINST FRAUD, the Firm will not change its wiring instructions via email. We strongly encourage clients to confirm any change in wiring instructions by contacting Teri Goffredo @ 213-683-5045 or via email @ terigoffredo@paulhastings.com and requesting written and verbal confirmation.*

Wiring and ACH Instructions: Remittance Address: Pay by Tranch:

Citibank Paul Hastings LLP You can now pay your invoices online via ABA # 322271724 Lockbox 4803 real-time bank payments, credit cards or SWIFT Address: CITIUS33 PO Box 894803 in installments:

*For wires, please reference the invoice, client and matter number(s) being paid For ACH payments, please use the CTX format and/or send any remittances to cashepn@paulhastings com This is a no-reply mailbox*

Case 22-50073 Doc 3283 Filed 06/24/24 Entered 06/24/24 18:35:48 Page 160 of 562

PAUL HASTINGS LLP 200 Park Avenue, New York, NY 10166-3205 t: +1.212.318.6000 f: +1.212.319.4090 www.paulhastings.com

Attn: Luc Despins PH LLP Tax ID No. 95-2209675

FOR PROFESSIONAL SERVICES RENDERED for the period ending January 31, 2024

Date Initials Description Hours Rate Amount

01/02/2024 AB21 Correspond with C. Gerling (buyer's

delivery protocol (0.1); prepare LM2 closing statement (0.3); correspond with L. Despins regarding same (0.1); correspond with J. Kuo regarding filing of same (0.1) 0.60 1,850.00 1,110.00 01/02/2024 JK21 Correspond with A. Bongartz regarding filing notice of closing statement of Lady May II sale (0.2); prepare notice of closing statement of Lady May II sale (0.2); electronically file with the court notice of closing statement of Lady May II sale (0.1);

closing statement of Lady May II sale (0.1) 0.60 565.00 339.00

Case 22-50073 Doc 3283 Filed 06/24/24 Entered 06/24/24 18:35:48 Page 161 of 562

Luc Despins as Chapter 11 Trustee in the case of Ho Wan

Date Initials Description Hours Rate Amount

01/22/2024 AB21 Correspond with C. Leandri (Edmiston) regarding Edmiston commission (0.1);

transfer for same (0.1) 0.20 1,850.00 370.00 Subtotal: B130 Asset Disposition 1.40 1,819.00

ID Timekeeper Name Title Hours Rate Fee AB21 Alex Bongartz Of Counsel 0.80 1,850.00 1,480.00 JK21 Jocelyn Kuo Paralegal 0.60 565.00 339.00

Date Description Quantity Rate Amount 12/21/2023 May II. Outside Professional Services -

Documentation, Inc., Invoice# N013269-T4 Dated 12/21/23, Consultation and preparation of closing documents necessary for the Sale of the Vessel Lady 250.00 01/02/2024 UPS/Courier Service - UPS (USD)(JPMPCARD); Invoice # 00000A6T163014; 01/02/2024; MASHA

ALBERT 1ER; MONACO, MC 98000 ;

Total Costs incurred and advanced \$282.95

Total Balance Due - Due Upon Receipt \$2,101.95

Luc Despins as Chapter 11 Trustee in the case of Ho Wan Kwok 200 Park Avenue New York, NY 10166

Attn: Luc Despins PH LLP Tax ID No. 95-2209675

Tax Issues PH LLP Client/Matter # 50687-00006 Luc A. Despins

Legal fees for professional services for the period ending January 31, 2024 \$1,850.00

We encourage our clients to pay via ACH, however, in the event that you pay by check, please send payment to the remittance address below:

*TO PROTECT AGAINST FRAUD, the Firm will not change its wiring instructions via email. We strongly encourage clients to confirm any change in wiring instructions by contacting Teri Goffredo @ 213-683-5045 or via email @ terigoffredo@paulhastings.com and requesting written and verbal confirmation.*

Wiring and ACH Instructions: Remittance Address: Pay by Tranch:

Citibank Paul Hastings LLP You can now pay your invoices online via ABA # 322271724 Lockbox 4803 real-time bank payments, credit cards or SWIFT Address: CITIUS33 PO Box 894803 in installments:

*For wires, please reference the invoice, client and matter number(s) being paid For ACH payments, please use the CTX format and/or send any remittances to cashepn@paulhastings com This is a no-reply mailbox*

Luc Despins as Chapter 11 Trustee in the case of Ho Wan Kwok 200 Park Avenue New York, NY 10166

Attn: Luc Despins PH LLP Tax ID No. 95-2209675

Tax Issues PH LLP Client/Matter # 50687-00006 Luc A. Despins

Legal fees for professional services for the period ending January 31, 2024 \$1,850.00

We encourage our clients to pay via ACH, however, in the event that you pay by check, please send payment to the remittance address below:

*TO PROTECT AGAINST FRAUD, the Firm will not change its wiring instructions via email. We strongly encourage clients to confirm any change in wiring instructions by contacting Teri Goffredo @ 213-683-5045 or via email @ terigoffredo@paulhastings.com and requesting written and verbal confirmation.*

Wiring and ACH Instructions: Remittance Address: Pay by Tranch:

Citibank Paul Hastings LLP You can now pay your invoices online via ABA # 322271724 Lockbox 4803 real-time bank payments, credit cards or SWIFT Address: CITIUS33 PO Box 894803 in installments:

*For wires, please reference the invoice, client and matter number(s) being paid For ACH payments, please use the CTX format and/or send any remittances to cashepn@paulhastings com This is a no-reply mailbox*

Case 22-50073 Doc 3283 Filed 06/24/24 Entered 06/24/24 18:35:48 Page 164 of 562

PAUL HASTINGS LLP 200 Park Avenue, New York, NY 10166-3205 t: +1.212.318.6000 f: +1.212.319.4090 www.paulhastings.com

Luc Despins as Chapter 11 Trustee in the case of Ho May 9, 2024

New York, NY 10166 Invoice Number: 2395795

Attn: Luc Despins PH LLP Tax ID No. 95-2209675

FOR PROFESSIONAL SERVICES RENDERED for the period ending January 31, 2024

Date Initials Description Hours Rate Amount

01/02/2024 AB21 Review draft power of attorney for tax

(EA Group) regarding same (0.2); correspond with L. Despins regarding same

01/03/2024 AB21 Correspond with D. Gibson (EA Group) regarding power of attorney (0.1); correspond with L. Despins regarding same

Subtotal: B240 Tax Issues 1.00 1,850.00

ID Timekeeper Name Title Hours Rate Fee AB21 Alex Bongartz Of Counsel 1.00 1,850.00 1,850.00 Case 22-50073 Doc 3283 Filed 06/24/24 Entered 06/24/24 18:35:48 Page 165 of 562

Luc Despins as Chapter 11 Trustee in the case of Ho Wan Kwok 50687-00006 Invoice No. 2395795 Page 2

Luc Despins as Chapter 11 Trustee in the case of Ho Wan Kwok 200 Park Avenue New York, NY 10166

Attn: Luc Despins PH LLP Tax ID No. 95-2209675

Genever US PH LLP Client/Matter # 50687-00010 Luc A. Despins

Legal fees for professional services for the period ending January 31, 2024 \$19,773.00

We encourage our clients to pay via ACH, however, in the event that you pay by check, please send payment to the remittance address below:

*TO PROTECT AGAINST FRAUD, the Firm will not change its wiring instructions via email. We strongly encourage clients to confirm any change in wiring instructions by contacting Teri Goffredo @ 213-683-5045 or via email @ terigoffredo@paulhastings.com and requesting written and verbal confirmation.*

Wiring and ACH Instructions: Remittance Address: Pay by Tranch:

Citibank Paul Hastings LLP You can now pay your invoices online via ABA # 322271724 Lockbox 4803 real-time bank payments, credit cards or SWIFT Address: CITIUS33 PO Box 894803 in installments:

*For wires, please reference the invoice, client and matter number(s) being paid For ACH payments, please use the CTX format and/or send any remittances to cashepn@paulhastings com This is a no-reply mailbox*

Luc Despins as Chapter 11 Trustee in the case of Ho Wan Kwok 200 Park Avenue New York, NY 10166

Attn: Luc Despins PH LLP Tax ID No. 95-2209675

Genever US PH LLP Client/Matter # 50687-00010 Luc A. Despins

Legal fees for professional services for the period ending January 31, 2024 \$19,773.00

We encourage our clients to pay via ACH, however, in the event that you pay by check, please send payment to the remittance address below:

*TO PROTECT AGAINST FRAUD, the Firm will not change its wiring instructions via email. We strongly encourage clients to confirm any change in wiring instructions by contacting Teri Goffredo @ 213-683-5045 or via email @ terigoffredo@paulhastings.com and requesting written and verbal confirmation.*

Wiring and ACH Instructions: Remittance Address: Pay by Tranch:

Citibank Paul Hastings LLP You can now pay your invoices online via ABA # 322271724 Lockbox 4803 real-time bank payments, credit cards or SWIFT Address: CITIUS33 PO Box 894803 in installments:

*For wires, please reference the invoice, client and matter number(s) being paid For ACH payments, please use the CTX format and/or send any remittances to cashepn@paulhastings com This is a no-reply mailbox*

Case 22-50073 Doc 3283 Filed 06/24/24 Entered 06/24/24 18:35:48 Page 168 of 562

PAUL HASTINGS LLP 200 Park Avenue, New York, NY 10166-3205 t: +1.212.318.6000 f: +1.212.319.4090 www.paulhastings.com

Attn: Luc Despins PH LLP Tax ID No. 95-2209675

FOR PROFESSIONAL SERVICES RENDERED for the period ending January 31, 2024

Date Initials Description Hours Rate Amount

01/04/2024 AB21 Correspond with L. Despins regarding update on GC bids 0.20 1,850.00 370.00 01/05/2024 AB21 Call with D. Acheson (architect) regarding GC bid comparison 0.70 1,850.00 1,295.00 01/05/2024 DEB4 Correspond with T. Sadler regarding insurance payments 0.20 1,395.00 279.00 01/09/2024 AB21 Call with D. Acheson (architect) regarding general contractor bids (0.2); correspond with L. Despins regarding same (0.6);

regarding same (0.4) 1.20 1,850.00 2,220.00 01/16/2024 AB21 Prepare notice of filing of Acheson Doyle

regarding filing and service of same (0.1) 0.40 1,850.00 740.00 01/17/2024 AB21 Update status report for SN remediation project (0.2); correspond with L. Despins regarding same (0.1); correspond with S.

regarding same (0.1) 0.50 1,850.00 925.00

Case 22-50073 Doc 3283 Filed 06/24/24 Entered 06/24/24 18:35:48 Page 169 of 562

Luc Despins as Chapter 11 Trustee in the case of Ho Wan Kwok 50687-00010 Invoice No. 2395796

Date Initials Description Hours Rate Amount

01/18/2024 AB21 Correspond with J. Kuo regarding filing and service of SN remediation status report 0.10 1,850.00 185.00 01/18/2024 JK21 Correspond with A. Bongartz regarding filing remediation status report (0.1); prepare for electronic filing remediation

remediation status report (0.1); review and handle service of remediation status report

01/22/2024 AB21 Correspond with M. Bielawski (ABF) regarding asbestos abatement (0.1);

regarding same (0.1); call with D. Acheson regarding same (0.4); correspond with L.

project (0.4); call with J. Panico (AAGL) regarding general contractor bids (0.1) 1.10 1,850.00 2,035.00 01/23/2024 AB21 Call with D. Acheson (architect) regarding general contractor bids 0.10 1,850.00 185.00 01/24/2024 AB21 Correspond with L. Despins regarding update on SN remediation (0.4); call with D. Acheson (architect) regarding same (0.1);

regarding same (0.4) 0.90 1,850.00 1,665.00 01/25/2024 AB21 Correspond with D. Acheson (architect) regarding SN remediation project (0.1); call with S. Millman (Hogan Lovells) regarding

regarding same (0.1); correspond with M. Cyganowski (Sales Officer) regarding same

01/26/2024 AB21 Call with D. Acheson (architect) regarding remediation update 0.30 1,850.00 555.00 01/29/2024 AB21 Correspond with L. Despins regarding update on remediation project (0.1); call with D. Acheson (architect) regarding same (0.3); correspond with F.J. Sciame (Sciame) regarding same (0.1) 0.50 1,850.00 925.00

Case 22-50073 Doc 3283 Filed 06/24/24 Entered 06/24/24 18:35:48 Page 170 of 562

Luc Despins as Chapter 11 Trustee in the case of Ho Wan Kwok 50687-00010 Invoice No. 2395796

Date Initials Description Hours Rate Amount 01/30/2024 AB21 Correspond with L. Despins regarding general contractor selection (0.1); call with L. Despins and FJ Sciame (Sciame) regarding same (0.2); correspond with D. Acheson (architect) regarding same (0.1); correspond with M. McCormack (OMJB) regarding same and update on remediation project (1.1) 1.50 1,850.00 2,775.00 01/30/2024 LAD4 T/c FJ Sciame (contractor) and A. Bongartz re: general contractor selection 0.20 1,975.00 395.00 01/31/2024 AB21 Finalize alteration agreement (0.7); calls with D. Acheson (architect) regarding same (0.3); correspond with D. Acheson regarding same (0.1); correspond with L. Despins regarding same (0.1); review Skyline windows proposal (0.2); calls with J. Valcarcel (Skyline) regarding same (0.2); correspond with J. Valcarcel regarding same (0.1); correspond with B. Snyder (Acheson Doyle) regarding letter of intent for Sciame (0.1); call with M. McCormack (OMJB) regarding remediation costs (0.2) 2.00 1,850.00 3,700.00 01/31/2024 DEB4 Correspond with L. Despins and T. Sadler regarding insurance 0.10 1,395.00 139.50 Subtotal: B210 Business Operations 10.80 19,354.50 B211 Financial Reports (Monthly Operating Reports) 01/26/2024 DEB4 Correspond with D. Skalka regarding MOR 0.30 1,395.00 418.50 Subtotal: B211 Financial Reports (Monthly Operating Reports) 0.30 418.50

Case 22-50073 Doc 3283 Filed 06/24/24 Entered 06/24/24 18:35:48 Page 171 of 562

Luc Despins as Chapter 11 Trustee in the case of Ho Wan Kwok 50687-00010 Invoice No. 2395796

ID Timekeeper Name Title Hours Rate Fee

LAD4 Luc A. Despins Partner 0.20 1,975.00 395.00 AB21 Alex Bongartz Of Counsel 9.90 1,850.00 18,315.00 DEB4 Douglass E. Barron Associate 0.60 1,395.00 837.00

Luc Despins as Chapter 11 Trustee in the case of Ho Wan Kwok 200 Park Avenue New York, NY 10166

Attn: Luc Despins PH LLP Tax ID No. 95-2209675

PH LLP Client/Matter # 50687-00012 Luc A. Despins

Legal fees for professional services for the period ending January 31, 2024 \$258,813.25

We encourage our clients to pay via ACH, however, in the event that you pay by check, please send payment to the remittance address below:

*TO PROTECT AGAINST FRAUD, the Firm will not change its wiring instructions via email. We strongly encourage clients to confirm any change in wiring instructions by contacting Teri Goffredo @ 213-683-5045 or via email @ terigoffredo@paulhastings.com and requesting written and verbal confirmation.*

Wiring and ACH Instructions: Remittance Address: Pay by Tranch:

Citibank Paul Hastings LLP You can now pay your invoices online via ABA # 322271724 Lockbox 4803 real-time bank payments, credit cards or SWIFT Address: CITIUS33 PO Box 894803 in installments:

*For wires, please reference the invoice, client and matter number(s) being paid For ACH payments, please use the CTX format and/or send any remittances to cashepn@paulhastings com This is a no-reply mailbox*

Luc Despins as Chapter 11 Trustee in the case of Ho Wan Kwok 200 Park Avenue New York, NY 10166

Attn: Luc Despins PH LLP Tax ID No. 95-2209675

PH LLP Client/Matter # 50687-00012 Luc A. Despins

Legal fees for professional services for the period ending January 31, 2024 \$258,813.25

We encourage our clients to pay via ACH, however, in the event that you pay by check, please send payment to the remittance address below:

*TO PROTECT AGAINST FRAUD, the Firm will not change its wiring instructions via email. We strongly encourage clients to confirm any change in wiring instructions by contacting Teri Goffredo @ 213-683-5045 or via email @ terigoffredo@paulhastings.com and requesting written and verbal confirmation.*

Wiring and ACH Instructions: Remittance Address: Pay by Tranch:

Citibank Paul Hastings LLP You can now pay your invoices online via ABA # 322271724 Lockbox 4803 real-time bank payments, credit cards or SWIFT Address: CITIUS33 PO Box 894803 in installments:

*For wires, please reference the invoice, client and matter number(s) being paid For ACH payments, please use the CTX format and/or send any remittances to cashepn@paulhastings com This is a no-reply mailbox*

Case 22-50073 Doc 3283 Filed 06/24/24 Entered 06/24/24 18:35:48 Page 174 of 562

PAUL HASTINGS LLP 200 Park Avenue, New York, NY 10166-3205 t: +1.212.318.6000 f: +1.212.319.4090 www.paulhastings.com

Luc Despins as Chapter 11 Trustee in the case of Ho Wan Kwok 200 Park Avenue New York, NY 10166

Attn: Luc Despins PH LLP Tax ID No. 95-2209675

FOR PROFESSIONAL SERVICES RENDERED for the period ending January 31, 2024

Date Initials Description Hours Rate Amount

01/02/2024 ECS1 Call with W. Farmer, J. Kosciewicz, S. Phan

review of Mahwah discovery documents 0.30 1,270.00 381.00 01/02/2024 ECS1 Analyze and summarize documents produced in discovery in Mahwah adversary (1.3); correspond with N. Bassett, A. Luft,

regarding same (.3) 1.60 1,270.00 2,032.00 01/02/2024 ECS1 Correspond with discovery targets regarding their discovery obligations and production timelines (.1); correspond with A. Luft, N. Bassett, W. Farmer, J. Kosciewicz and L. Song regarding same (.1) 0.20 1,270.00 254.00 01/02/2024 ECS1 Prepare requests for production, notices

proceeding (1.2); correspond with N. Bassett, W. Farmer, L. Song and P. Linsey

with discovery targets regarding same (.1) 1.50 1,270.00 1,905.00

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Luc Despins as Chapter 11 Trustee in the case of Ho Wan Kwok 50687-00012 Invoice No. 2395797

Date Initials Description Hours Rate Amount

01/02/2024 JPK1 Telephone call with W. Farmer, E. Sutton

document productions and review 0.30 1,185.00 355.50 01/02/2024 AEL2 Draft Mahwah discovery plan update 0.50 1,850.00 925.00 01/02/2024 NAB Correspond with M. Conway (opposing counsel) regarding deposition issues (.2); prepare for depositions by reviewing legal issues, topics, and documents produced in discovery (1.8) 2.00 1,835.00 3,670.00 01/02/2024 WCF Call with UnitedLex (S. Phan), E. Sutton

Mahwah adversary proceeding (.3); prepare

adversary proceeding documents (1.4);

regarding issues for deposition outline (2.1);

outline regarding Mahwah design work (1.2) 5.10 1,390.00 7,089.00 01/03/2024 ECS1 Review documents in preparation for deposition of A. Hadjicharalambous (.5);

(.1); call with N. Bassett regarding A. Hadjicharalambous deposition (.3);

01/03/2024 ECS1 Analyze and summarize documents produced in Mahwah adversary proceeding 0.10 1,270.00 127.00 01/03/2024 ECS1 Correspond with discovery targets regarding their discovery obligations and production

(.3); correspond with A. Luft, N. Bassett, W. Farmer, L. Song regarding same

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Luc Despins as Chapter 11 Trustee in the case of Ho Wan Kwok 50687-00012 Invoice No. 2395797

Date Initials Description Hours Rate Amount

01/03/2024 ECS1 Prepare requests for production, notices

proceeding (1.7); correspond with N. Bassett, W. Farmer, L. Song and P. Linsey

with discovery targets regarding same (.4) 2.60 1,270.00 3,302.00 01/03/2024 AEL2 Review arbitration facts 0.60 1,850.00 1,110.00 01/03/2024 AEL2 Meeting with N. Bassett re: Mahwah litigation and deposition plan (.3); outline action items for same (.2) 0.50 1,850.00 925.00 01/03/2024 NAB Correspond with W. Farmer regarding

(.3); follow-up correspondence with W. Farmer and E. Sutton regarding same (.2); review legal issues to be covered and certain documents for upcoming depositions (1.6);

depositions (.2); review and revise draft deposition notices and topic lists (.5);

01/03/2024 NAB Meeting with A. Luft regarding Mahwah litigation and discovery plan 0.30 1,835.00 550.50 01/03/2024 WCF Update litigation issues/task list regarding

responses and objections, and outstanding discovery issues (.5); correspond with A. Luft and N. Bassett regarding same (.1);

deposition outline regarding same (1.4); correspond with subpoena targets and E. Sutton regarding upcoming depositions and scheduling of same (.4) 3.80 1,390.00 5,282.00 01/04/2024 ECS1 Analyze and summarize documents produced in discovery in Mahwah adversary proceeding (2.7); correspond with N. Bassett, A. Luft, D. Barron, W. Farmer, and L. Song regarding same (.2) 2.90 1,270.00 3,683.00

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Luc Despins as Chapter 11 Trustee in the case of Ho Wan Kwok 50687-00012 Invoice No. 2395797

Date Initials Description Hours Rate Amount 01/04/2024 ECS1 Correspond with discovery targets regarding their discovery obligations and production timelines (.2); correspond with A. Luft, N. Bassett, W. Farmer, and L. Song regarding same (.1) 0.30 1,270.00 381.00 01/04/2024 ECS1 Prepare requests for production, notices and subpoenas in the Mahwah adversary proceeding (.1); correspond with discovery targets regarding same (.1) 0.20 1,270.00 254.00 01/04/2024 ECS1 Correspond with L. Song about deposition preparations (.1); correspond with N. Bassett and A. Luft regarding vendor deposition outlines (.1); call with M. Talasazan (Solomon Treasure Antiques) regarding his deposition (.1) 0.30 1,270.00 381.00 01/04/2024 LS26 Review and comment on Mahwah litigation and deposition issues/task list 0.20 985.00 197.00 01/04/2024 NAB Correspond with W. Farmer regarding upcoming depositions (.2); correspond with L. Song regarding discovery issues (.1) 0.30 1,835.00 550.50 01/04/2024 WCF Correspond with UnitedLex regarding document productions to M. Conway of rule 45 subpoena documents (.3); review rule 45 subpoena documents from Promemoria, Lobel Modern, Solomon Treasure Antiques, and A. Buck in preparing deposition outlines (.8) 1.10 1,390.00 1,529.00 01/05/2024 ECS1 Review discovery documents in preparation for depositions relating to Mahwah (.3); correspond with W. Farmer, L. Song, N. Bassett and A. Luft regarding same (.1); call with M. Talasazan (Solomon Treasure Antiques) regarding his deposition (.1) 0.50 1,270.00 635.00 01/05/2024 ECS1 Analyze and summarize Amy Buck discovery documents (3.1); correspond with N. Bassett, A. Luft, D. Barron, W. Farmer, and L. Song regarding same (.2); call with W. Farmer regarding same and requests for 3.60 1,270.00 4,572.00

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Luc Despins as Chapter 11 Trustee in the case of Ho Wan Kwok 50687-00012 Invoice No. 2395797

Date Initials Description Hours Rate Amount

01/05/2024 JPK1 Prepare exhibits for re-filing of sealed exhibits for the summary judgment hearing (.2); correspond with J. Kuo regarding the

01/05/2024 LS26 Correspond with E. Sutton regarding furniture vendor depositions 0.20 985.00 197.00 01/05/2024 NAB Call with W. Farmer regarding upcoming depositions (.2); review certain discovery documents for same (.3) 0.50 1,835.00 917.50 01/05/2024 WCF Correspond with A. Luft regarding document review and deposition plan (.3);

production to M. Conway (.6); call with N.

2024 (.2); call with E. Sutton regarding A.

requests for additional documents (.3) 1.40 1,390.00 1,946.00 01/06/2024 JPK1 Incorporate N. Bassett's comments into opposition to Defendants' motion to strike (.2); correspond with L. Despins regarding

reply briefings (.2); correspond with N. Bassett regarding the same (.3) 0.90 1,185.00 1,066.50 01/08/2024 ECS1 Review legal issues in preparation for deposition of Lobel Modern (.2); correspond with W. Farmer, L. Song, N. Bassett and A. Luft regarding same (.1);

regarding its deposition (.2) 0.50 1,270.00 635.00 01/08/2024 ECS1 Analyze and summarize documents produced in discovery in Mahwah adversary 0.20 1,270.00 254.00 01/08/2024 ECS1 Review information regarding Mahwah

assets, and their connections to Kwok and the Mahwah Mansion 0.10 1,270.00 127.00

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Luc Despins as Chapter 11 Trustee in the case of Ho Wan Kwok 50687-00012 Invoice No. 2395797

Date Initials Description Hours Rate Amount

01/08/2024 ECS1 Call with E. Levine (ULX) and S. Phan

01/08/2024 NAB Review certain documents and exhibits in preparation for upcoming depositions 0.40 1,835.00 734.00 01/08/2024 WCF Correspond with counsel to Promemoria

responsiveness and for use in depositions

01/09/2024 ECS1 Prepare parts of outline for deposition of Solomon Treasure Antiques (1.9); correspond with W. Farmer, L. Song, N. Bassett and A. Luft regarding same (.5) 2.40 1,270.00 3,048.00

01/09/2024 NAB Correspond with W. Farmer and E. Sutton regarding upcoming depositions 0.20 1,835.00 367.00 01/09/2024 WCF Correspond with G. Giordana

supplemental production (1.1) 1.30 1,390.00 1,807.00 01/10/2024 ECS1 Call with W. Farmer, J. Kosciewicz, and L.

01/10/2024 ECS1 Continue preparing outline for deposition of Solomon Treasure Antiques (2.1); correspond with N. Bassett, W. Farmer, L. Song, and A. Luft regarding same (.2);

regarding same (.2); conference with N.

documents and exhibits for same (.2) 2.90 1,270.00 3,683.00

Case 22-50073 Doc 3283 Filed 06/24/24 Entered 06/24/24 18:35:48 Page 180 of 562 Luc Despins as Chapter 11 Trustee in the case of Ho Wan Kwok 50687-00012 Invoice No. 2395797

Date Initials Description Hours Rate Amount

01/10/2024 ECS1 Call with W. Farmer, G. Phillips III (ULX),

adversary proceeding 0.50 1,270.00 635.00 01/10/2024 ECS1 Continue preparing outline for deposition

with A. Luft regarding same (.2); meeting with N. Bassett and A. Luft regarding same

exhibits for same (.1) 2.70 1,270.00 3,429.00 01/10/2024 JPK1 Review document review protocol for G Club and NAV document review 0.30 1,185.00 355.50 01/10/2024 JPK1 Attend teleconference with W. Farmer, E.

01/10/2024 AEL2 Conference with E. Sutton re: comments

outline (.2); conference with N. Bassett and E. Sutton re: same (.2) 0.40 1,850.00 740.00 01/10/2024 AEL2 Review documents and supplement topics

01/10/2024 AEL2 Further review and comment on deposition topics and outlines for Mahwah depositions 0.90 1,850.00 1,665.00 01/10/2024 AEL2 Correspond with L. Song re: contents of

01/10/2024 LS26 Call with W. Farmer, E. Sutton, and J.

upcoming litigation matters (0.7); prepare

Treasure Antiques and Lobel Modern (3.3) 4.00 985.00 3,940.00

Case 22-50073 Doc 3283 Filed 06/24/24 Entered 06/24/24 18:35:48 Page 181 of 562

Luc Despins as Chapter 11 Trustee in the case of Ho Wan Kwok 50687-00012 Invoice No. 2395797

Date Initials Description Hours Rate Amount 01/10/2024 NAB Review documents and supplement outline for Solomon Treasure deposition (2.1); meet with E. Sutton regarding same (.2); call with E. Sutton and A. Luft regarding deposition preparations (.2); correspond with W. Farmer regarding responses and objections to document requests (.1); review draft of same (.2); correspond with W. Farmer regarding comments on draft responses and objections to document requests (.1) 2.90 1,835.00 5,321.50 01/10/2024 WCF Draft NAV and G Club Mahwah document review protocol (1.4); prepare notes for document review meeting with UnitedLex (.2); attend NAV/G Club Mahwah document review protocol meeting with UnitedLex and E. Sutton (.5); call with J. Kosciewicz, E. Sutton, L. Song regarding Mahwah litigation action items and upcoming depositions (.7); revise responses and objections to Defendants' first RFPs (.6) 3.40 1,390.00 4,726.00 01/11/2024 ECS1 Correspond with L. Song regarding Lobel Modern deposition and outline 0.50 1,270.00 635.00 01/11/2024 ECS1 Supplement outline for Solomon Treasure Antiques deposition (.5); correspond with N. Bassett regarding same (.1); conduct deposition of Solomon Treasure Antiques (1.6) 2.20 1,270.00 2,794.00 01/11/2024 ECS1 Review discovery documents in preparation for upcoming depositions in the Mahwah adversary proceeding (.3); correspond with L. Song and W. Farmer regarding same (.1) 0.40 1,270.00 508.00 01/11/2024 AEL2 Call with N. Bassett re: depositions 0.40 1,850.00 740.00 01/11/2024 AEL2 Correspond with W. Farmer re: Promemoria documents 0.20 1,850.00 370.00 01/11/2024 AEL2 Conferences with L. Song re: Lobel deposition 1.20 1,850.00 2,220.00

Date Initials Description Hours Rate Amount

01/11/2024 AEL2 Correspond with L. Song re: Lobel

01/11/2024 LS26 Prepare deposition outline and exhibits for Lobel Modern (5.4); conference with A. Luft regarding same (1.2) 6.60 985.00 6,501.00 01/11/2024 NAB Further review documents and supplement

(1.8); correspond with E. Sutton regarding

deposition (1.6); prepare summary of same for L. Despins (.2); conference with A. Luft regarding same and related litigation issues

01/11/2024 WCF Review model documents in UnitedLex review calibration set (.7); correspond with G. Phillips (ULX) regarding same (.2);

document set (.3) 1.20 1,390.00 1,668.00 01/12/2024 ECS1 Correspond with discovery targets regarding their discovery obligations and production

01/12/2024 ECS1 Review topics for upcoming depositions in the Mahwah adversary proceeding (.3); correspond with L. Song, J. Kosciewicz and W. Farmer regarding same (.2) 0.50 1,270.00 635.00 01/12/2024 ECS1 Correspond with A. Luft regarding Lobel Modern deposition and outline (.1); review

01/12/2024 ECS1 Correspond with discovery targets regarding their discovery obligations and production timelines (.4); correspond with N. Bassett, A. Luft, W. Farmer, J. Kosciewicz and L. Song regarding same (.2) 0.60 1,270.00 762.00

Case 22-50073 Doc 3283 Filed 06/24/24 Entered 06/24/24 18:35:48 Page 183 of 562

Luc Despins as Chapter 11 Trustee in the case of Ho Wan Kwok 50687-00012 Invoice No. 2395797

Date Initials Description Hours Rate Amount

01/12/2024 JPK1 Review deposition outlines for Promemoria and E. deNeree (.3); review responses and objections to discovery from Sotheby's (.5); review Sotheby's document production (.9); draft parts of Sotheby's deposition outline

01/12/2024 JPK1 Correspond with W. Farmer regarding rule

topics served on Sotheby's (.1);

01/12/2024 AEL2 Call with N. Bassett re: litigation scheduling

01/12/2024 AEL2 Review documents and supplement outline for Lobel deposition 3.30 1,850.00 6,105.00 01/12/2024 AEL2 Review Mahwah deposition documents 2.90 1,850.00 5,365.00 01/12/2024 AEL2 Take Lobel deposition 1.70 1,850.00 3,145.00 01/12/2024 LS26 Review documents and comment on outline for Promemoria deposition 0.60 985.00 591.00 01/12/2024 LS26 Review documents and supplement outline for Lobel Modern deposition (1.6);

01/12/2024 NAB Call with A. Luft regarding antique

deposition and related issues (.4); review

strategy for same (.4) 0.80 1,835.00 1,468.00 01/12/2024 WCF Correspond with counsel to C. Frosini, Christie's/Crocker Mansion, and E. Sutton

01/13/2024 JPK1 Continue drafting deposition outline for Christine Frosini and Sotheby's 2.50 1,185.00 2,962.50 01/14/2024 ECS1 Prepare parts of outline for deposition of Crocker Mansion Estate and Christie's Real Estate (.8); analyze discovery documents in 1.10 1,270.00 1,397.00

Case 22-50073 Doc 3283 Filed 06/24/24 Entered 06/24/24 18:35:48 Page 184 of 562

Luc Despins as Chapter 11 Trustee in the case of Ho Wan Kwok 50687-00012 Invoice No. 2395797

Date Initials Description Hours Rate Amount

01/15/2024 ECS1 Continue preparing outline for deposition

01/15/2024 AEL2 Review documents and legal issues in

01/15/2024 WCF Review Promemoria supplemental payment document production (.3); correspond with A. Luft regarding same (.1) 0.40 1,390.00 556.00 01/16/2024 ECS1 Prepare parts of outline for deposition of Crocker Mansion Estate and Christie's Real Estate (2.4); review discovery documents in connection with same (.6); correspond with N. Bassett and A. Luft regarding same (.2) 3.20 1,270.00 4,064.00 01/16/2024 ECS1 Analyze and summarize documents produced in response to discovery requests in Mahwah adversary proceeding 0.10 1,270.00 127.00 01/16/2024 ECS1 Comment on certain documents in

the Mahwah adversary proceeding 0.10 1,270.00 127.00 01/16/2024 LAD4 T/c A. Luft, N. Bassett re: stay of AP (.30); review same (.40) 0.70 1,975.00 1,382.50 01/16/2024 AEL2 Take Promemoria deposition 5.60 1,850.00 10,360.00 01/16/2024 AEL2 Review documents and supplement outline for Promemoria deposition 1.20 1,850.00 2,220.00 01/16/2024 AEL2 Call with L. Despins and N. Bassett re: Mahwah discovery and litigation 0.30 1,850.00 555.00 01/16/2024 LS26 Supplement outline for Promemoria deposition (0.4); participate in Promemoria

Case 22-50073 Doc 3283 Filed 06/24/24 Entered 06/24/24 18:35:48 Page 185 of 562 Luc Despins as Chapter 11 Trustee in the case of Ho Wan Kwok 50687-00012 Invoice No. 2395797

Date Initials Description Hours Rate Amount

01/16/2024 NAB Attend portions of deposition of remodeling company (2.2); correspond with

procedural issues related to same (.2); call

litigation schedule and strategy (.3); call with opposing counsel regarding same (.1); correspond with P. Linsey (NPM) regarding draft motion for modification of schedule

01/16/2024 WCF Review and comment on outline for deposition of Promemoria USA (.5); attend deposition of Promemoria USA (5.6) 6.10 1,390.00 8,479.00 01/17/2024 ECS1 Review information regarding Mahwah

assets, and their connections to Kwok and the Mahwah Mansion 0.10 1,270.00 127.00 01/17/2024 JPK1 Draft parts of deposition outline for Sotheby's and Christine Frosini 3.50 1,185.00 4,147.50 01/17/2024 AEL2 Correspond with L. Despins re: deposition

01/17/2024 LS26 Prepare inventory of items in storage unit 3.80 985.00 3,743.00 01/17/2024 NAB Review certain documents in preparation for depositions (.3); consider litigation timing and strategy (.1) 0.40 1,835.00 734.00 01/18/2024 ECS1 Call with P. Doucette (NAV Consulting) in connection with its discovery obligations (.1); follow up correspondence with W. Farmer regarding same (.1) 0.20 1,270.00 254.00 01/18/2024 AEL2 Analysis re: storage unit findings 0.80 1,850.00 1,480.00 01/18/2024 AEL2 Plan for 2004 depo project 0.70 1,850.00 1,295.00 01/18/2024 LS26 Conduct inspection of storage units and inventory items (5.7); call with N. Bassett regarding same (.3) 6.00 985.00 5,910.00

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Luc Despins as Chapter 11 Trustee in the case of Ho Wan Kwok 50687-00012 Invoice No. 2395797

Date Initials Description Hours Rate Amount

01/18/2024 NAB Call with L. Song regarding discovery and

revise motion to stay adversary proceeding (.2); correspond with L. Despins regarding

01/19/2024 ECS1 Correspond with P. Doucette (NAV

01/19/2024 AEL2 Communicate with W. Farmer re: discovery

01/19/2024 AEL2 Edit motion to stay 0.20 1,850.00 370.00 01/19/2024 LS26 Conduct inspection at storage unit 6.70 985.00 6,599.50 01/19/2024 NAB Review emails from W. Farmer regarding discovery responses 0.30 1,835.00 550.50 01/20/2024 ECS1 Correspond with discovery targets regarding

01/20/2024 LS26 Review document production related to

01/21/2024 LS26 Review document production in discovery (0.3); correspond with N. Bassett regarding

inspection of storage units (0.5) 1.00 985.00 985.00 01/21/2024 NAB Correspond with L. Song regarding discovery findings (.2); review documents related to same (.3) 0.50 1,835.00 917.50 01/22/2024 AEL2 Correspond with L. Song re: storage locker 0.40 1,850.00 740.00 01/22/2024 LS26 Review document production in discovery (1.2); prepare inventory list re storage units (0.7); correspond with N. Bassett and A. Luft re same (0.2) 2.10 985.00 2,068.50 01/22/2024 NAB Correspond with L. Song regarding discovery issues (.2); revise draft motion and order to modify litigation schedule (.2);

regarding same (.1) 0.50 1,835.00 917.50

Date Initials Description Hours Rate Amount

01/23/2024 AEL2 Review Taurus Management agreements 0.30 1,850.00 555.00 01/23/2024 AEL2 Call with M. Starr, counsel to Fania Roofing, re: tolling motion 0.20 1,850.00 370.00 01/23/2024 LS26 Review and comment on inspection at

01/23/2024 NAB Correspond with M. Conway (opposing

litigation schedule (.1); review revised draft motion to modify litigation schedule (.1);

01/23/2024 WCF Review Rule 45 subpoena custodians and

production to defendants (.6); correspond with S. Phan, P. Linsey (NPM), and L. Song

production parameters regarding same (.3);

distribution of supplemental production (.1) 1.30 1,390.00 1,807.00 01/24/2024 AEL2 Review documents for upcoming

01/24/2024 LS26 Call with N. Bassett re storage unit inspection (0.2); correspond with Kroll re same (0.3); prepare draft notice emails re

01/24/2024 NAB Correspond with L. Song regarding

regarding storage unit inspection (.2);

litigation schedule revision motion (.2) 0.60 1,835.00 1,101.00 01/24/2024 WCF Correspond with K. Mitchell (NPM) and P.

document issues (.2); correspond with M. Conway regarding same (.1) 0.30 1,390.00 417.00 01/25/2024 LS26 Prepare inventory list re storage unit items 0.50 985.00 492.50

Case 22-50073 Doc 3283 Filed 06/24/24 Entered 06/24/24 18:35:48 Page 188 of 562

Luc Despins as Chapter 11 Trustee in the case of Ho Wan Kwok 50687-00012 Invoice No. 2395797

Date Initials Description Hours Rate Amount

01/26/2024 LS26 storage unit (5.4); correspond with N. Bassett and A. Luft re same (0.3) Conduct inspection and inventory items at 5.70 985.00 5,614.50 Subtotal: B191 General Litigation 186.60 255,710.50

01/18/2024 LS26 inspection (1.3) (bill at 1/2 rate) Travel from New York to New Jersey for inspection of the storage unit (1.2); return travel from New Jersey to New York after 2.50 492.50 1,231.25 01/19/2024 LS26 from New Jersey to New York after inspection (1.5) (bill at 1/2 rate) Travel from New York to New Jersey for inspection at storage unit (1.0); return travel 2.50 492.50 1,231.25 01/26/2024 LS26 Travel from New Jersey to New York after inspection of storage units (bill at 1/2 rate) 1.30 492.50 640.25 Subtotal: B195 Non-Working Travel 6.30 3,102.75

ID Timekeeper Name Title Hours Rate Fee LAD4 Luc A. Despins Partner 0.70 1,975.00 1,382.50 NAB Nicholas A. Bassett Partner 21.30 1,835.00 39,085.50 AEL2 Luft, Avi E. Of Counsel 31.60 1,850.00 58,460.00 WCF Will C. Farmer Associate 27.10 1,390.00 37,669.00 ECS1 Ezra C. Sutton Associate 41.20 1,270.00 52,324.00 JPK1 Jon P. Kosciewicz Associate 15.30 1,185.00 18,130.50 LS26 Luyi Song Associate 49.40 985.00 48,659.00 LS26 Luyi Song Associate 6.30 492.50 3,102.75

Luc Despins as Chapter 11 Trustee in the case of Ho Wan Kwok 50687-00012 Invoice No. 2395797

Date Description Quantity Rate Amount

01/09/2024 Photocopy Charges 141.00 0.08 11.28 01/09/2024 Photocopy Charges (Color) 152.00 0.20 30.40 01/09/2024 Photocopy Charges (Color) 42.00 0.20 8.40 01/10/2024 Photocopy Charges (Color) 183.00 0.20 36.60 01/11/2024 Photocopy Charges (Color) 306.00 0.20 61.20 01/12/2024 Photocopy Charges (Color) 376.00 0.20 75.20 01/25/2024 Photocopy Charges (Color) 49.00 0.20 9.80

Invoice# 40627 Dated 12/21/23, Process Service for Arrendondo & Co. HGA Property Operation 1,216.05

Invoice# 40629 Dated 12/21/23, Process Service

UPS (USD)(JPMPCARD); Invoice # 00000A6T163523; 12/22/2023; ; Qin Li; One Gateway Center, Suite 2600; Newark, NJ 071025323 ; 1ZA6T1630198352910 (MAN) 14.39

UPS (USD)(JPMPCARD); Invoice # 00000A6T163523; 12/22/2023; John Scagnelli; Scarinci & Hollenbeck LLC; 150 Clove Rd, 9th FL; Little Falls, NJ 074242139 ;

UPS (USD)(JPMPCARD); Invoice # 00000A6T163523; 12/22/2023; ; Arredondo & Co., LLC; 200 Route 17 North; Upper Saddle River, NJ 074582330 ;

UPS (USD)(JPMPCARD); Invoice # 00000A6T163523; 12/22/2023; ; Qin Li; 3655 Meadow LN; North Bergen, NJ 070472343 ;

Case 22-50073 Doc 3283 Filed 06/24/24 Entered 06/24/24 18:35:48 Page 190 of 562

Luc Despins as Chapter 11 Trustee in the case of Ho Wan Page 17

UPS (USD)(JPMPCARD); Invoice # 00000A6T163523; 12/22/2023; ; Qin Li;

275606624 ; 1ZA6T1630192045058 (MAN) 24.31

01/01/2024 Electronic Document Retrieval -

1047352-202312-1 Dated 01/01/24, TLO Charges

Ezra Sutton; 12/05/2023; Restaurant: Effy's Cafe; City: UWS; Dinner; Number of people: 1; late night dinner 14.81

Avram Luft; 12/12/2023; Restaurant: Yama; City: New York; Dinner;

Luyi Song; 12/28/2023; travel from New Jersey to New York

Luyi Song; 12/22/2023; From/To: from New York to New Jersey; Service Type: Lyft; travel from New York to New Jersey for inspection of storage unit 132.18

Luyi Song; 12/22/2023; travel from New Jersey to New York

Luyi Song; 12/28/2023; From/To: New York to New Jersey; Service Type: Lyft; travel from New York to New Jersey for inspection of storage unit 98.99

UPS (USD)(JPMPCARD); Invoice # 00000A6T163024; 01/08/2024; QIN LI;

LN; MORRISVILLE, NC 27560 ;

Case 22-50073 Doc 3283 Filed 06/24/24 Entered 06/24/24 18:35:48 Page 191 of 562

Luc Despins as Chapter 11 Trustee in the case of Ho Wan Page 18

UPS (USD)(JPMPCARD); Invoice # 00000A6T163024; 01/08/2024; ; Qin Li; 312 COLWICK LN; MORRISVILLE, NC 27560 ;

85 dated 01/14/2024; Luyi Song; Number of people: 1; Restaurant: One Two Thai; Location: New York; Dinner during deposition preparation; Order # 75324946731915 dated 01/11/2024 30.16

01/19/2024 Outside Professional Services -

Solutions, LLC, Invoice# 2024-41 Dated 01/19/24,

Luyi Song; 01/19/2024; Travel from New Jersey to New York

Luyi Song; 01/19/2024; From/To: New York/New Jersey; Service Type: Lyft; Travel from New York to New Jersey for inspection at storage unit 133.18

Luyi Song; 01/18/2024; From/To: New York/New Jersey; Service Type: Lyft; Travel from New York to New Jersey for inspection at storage unit 138.89

Luyi Song; 01/18/2024; Travel from New Jersey to New York

Ezra Sutton; 01/03/2024; Restaurant: Uber Eats; City: New York ; Breakfast; Number of people: 1; Weekend work on client

Ezra Sutton; 01/03/2024; From/To: office/home; Service Type: Lyft; weekend work on

Case 22-50073 Doc 3283 Filed 06/24/24 Entered 06/24/24 18:35:48 Page 192 of 562

Luc Despins as Chapter 11 Trustee in the case of Ho Wan Page 19

Total Costs incurred and advanced \$6,064.53 01/29/2024 Outside Professional Services -

Services, LLC, Invoice# 01292024SB1 Dated 01/29/24, Engage movers to lift boxes for the inspection at the storage units at Westy Self Storage 715.00

Solutions, LLC, Invoice# INV2694671 Dated 01/29/24, Services for transcripts, video of

Luc Despins as Chapter 11 Trustee in the case of Ho Wan Kwok 200 Park Avenue New York, NY 10166

Attn: Luc Despins PH LLP Tax ID No. 95-2209675

PH LLP Client/Matter # 50687-00013 Luc A. Despins

Legal fees for professional services for the period ending January 31, 2024 \$5,467.50

We encourage our clients to pay via ACH, however, in the event that you pay by check, please send payment to the remittance address below:

*TO PROTECT AGAINST FRAUD, the Firm will not change its wiring instructions via email. We strongly encourage clients to confirm any change in wiring instructions by contacting Teri Goffredo @ 213-683-5045 or via email @ terigoffredo@paulhastings.com and requesting written and verbal confirmation.*

Wiring and ACH Instructions: Remittance Address: Pay by Tranch:

Citibank Paul Hastings LLP You can now pay your invoices online via ABA # 322271724 Lockbox 4803 real-time bank payments, credit cards or SWIFT Address: CITIUS33 PO Box 894803 in installments:

*For wires, please reference the invoice, client and matter number(s) being paid For ACH payments, please use the CTX format and/or send any remittances to cashepn@paulhastings com This is a no-reply mailbox*

Luc Despins as Chapter 11 Trustee in the case of Ho Wan Kwok 200 Park Avenue New York, NY 10166

Attn: Luc Despins PH LLP Tax ID No. 95-2209675

PH LLP Client/Matter # 50687-00013 Luc A. Despins

Legal fees for professional services for the period ending January 31, 2024 \$5,467.50

We encourage our clients to pay via ACH, however, in the event that you pay by check, please send payment to the remittance address below:

*TO PROTECT AGAINST FRAUD, the Firm will not change its wiring instructions via email. We strongly encourage clients to confirm any change in wiring instructions by contacting Teri Goffredo @ 213-683-5045 or via email @ terigoffredo@paulhastings.com and requesting written and verbal confirmation.*

Wiring and ACH Instructions: Remittance Address: Pay by Tranch:

Citibank Paul Hastings LLP You can now pay your invoices online via ABA # 322271724 Lockbox 4803 real-time bank payments, credit cards or SWIFT Address: CITIUS33 PO Box 894803 in installments:

*For wires, please reference the invoice, client and matter number(s) being paid For ACH payments, please use the CTX format and/or send any remittances to cashepn@paulhastings com This is a no-reply mailbox*

Case 22-50073 Doc 3283 Filed 06/24/24 Entered 06/24/24 18:35:48 Page 195 of 562

PAUL HASTINGS LLP 200 Park Avenue, New York, NY 10166-3205 t: +1.212.318.6000 f: +1.212.319.4090 www.paulhastings.com

Luc Despins as Chapter 11 Trustee in the case of

New York, NY 10166 Invoice Number: 2395798

Attn: Luc Despins PH LLP Tax ID No. 95-2209675

FOR PROFESSIONAL SERVICES RENDERED for the period ending January 31, 2024 Golden Spring Adversary Proceeding \$5,467.50

Date Initials Description Hours Rate Amount

01/03/2024 LAD4 Review/edit Axos/Golden Spring motion (.30); t/c P. Linsey (NPM) re: same (.20) 0.50 1,975.00 987.50 01/09/2024 JPK1 Analyze Rule 2004 privilege log for

01/10/2024 JPK1 Correspond with A. Luft regarding Golden Spring documents from Melissa Francis 0.20 1,185.00 237.00 01/10/2024 JPK1 Correspond with J. Bach regarding M.

documents withheld on the basis of Golden

01/10/2024 AEL2 Correspond with L. Despins re: Golden Spring turnover motion 0.20 1,850.00 370.00 01/11/2024 JPK1 Draft email to J. Bach, counsel for M. Francis, regarding discovery and document

01/11/2024 JPK1 Review consent order to enforce Golden Spring default judgment against Axos 0.10 1,185.00 118.50

Case 22-50073 Doc 3283 Filed 06/24/24 Entered 06/24/24 18:35:48 Page 196 of 562

Luc Despins as Chapter 11 Trustee in the case of Ho Wan Kwok 50687-00013 Invoice No. 2395798

with A. Luft regarding the same (.2) Hours

01/15/2024 JPK1 Correspond with J. Bach, counsel for M. Francis, regarding production of documents previously withheld on the basis of Golden

01/17/2024 JPK1 Correspond with E. Hintz regarding

01/18/2024 JPK1 Correspond with S. Phan regarding

01/30/2024 AEL2 Correspond with S. Maza re: Golden Spring

Subtotal: B191 General Litigation 4.00 5,467.50

ID Timekeeper Name Title Hours Rate Fee LAD4 Luc A. Despins Partner 0.50 1,975.00 987.50 AEL2 Luft, Avi E. Of Counsel 0.50 1,850.00 925.00 JPK1 Jon P. Kosciewicz Associate 3.00 1,185.00 3,555.00

Current Fees and Costs \$5,467.50 Total Balance Due - Due Upon Receipt \$5,467.50

Luc Despins as Chapter 11 Trustee in the case of Ho Wan Kwok 200 Park Avenue New York, NY 10166

Attn: Luc Despins PH LLP Tax ID No. 95-2209675

PH LLP Client/Matter # 50687-00014 Luc A. Despins

Legal fees for professional services for the period ending January 31, 2024 \$52,618.00

We encourage our clients to pay via ACH, however, in the event that you pay by check, please send payment to the remittance address below:

*TO PROTECT AGAINST FRAUD, the Firm will not change its wiring instructions via email. We strongly encourage clients to confirm any change in wiring instructions by contacting Teri Goffredo @ 213-683-5045 or via email @ terigoffredo@paulhastings.com and requesting written and verbal confirmation.*

Wiring and ACH Instructions: Remittance Address: Pay by Tranch:

Citibank Paul Hastings LLP You can now pay your invoices online via ABA # 322271724 Lockbox 4803 real-time bank payments, credit cards or SWIFT Address: CITIUS33 PO Box 894803 in installments:

*For wires, please reference the invoice, client and matter number(s) being paid For ACH payments, please use the CTX format and/or send any remittances to cashepn@paulhastings com This is a no-reply mailbox*

Luc Despins as Chapter 11 Trustee in the case of Ho Wan Kwok 200 Park Avenue New York, NY 10166

Attn: Luc Despins PH LLP Tax ID No. 95-2209675

PH LLP Client/Matter # 50687-00014 Luc A. Despins

Legal fees for professional services for the period ending January 31, 2024 \$52,618.00

We encourage our clients to pay via ACH, however, in the event that you pay by check, please send payment to the remittance address below:

*TO PROTECT AGAINST FRAUD, the Firm will not change its wiring instructions via email. We strongly encourage clients to confirm any change in wiring instructions by contacting Teri Goffredo @ 213-683-5045 or via email @ terigoffredo@paulhastings.com and requesting written and verbal confirmation.*

Wiring and ACH Instructions: Remittance Address: Pay by Tranch:

Citibank Paul Hastings LLP You can now pay your invoices online via ABA # 322271724 Lockbox 4803 real-time bank payments, credit cards or SWIFT Address: CITIUS33 PO Box 894803 in installments:

*For wires, please reference the invoice, client and matter number(s) being paid For ACH payments, please use the CTX format and/or send any remittances to cashepn@paulhastings com This is a no-reply mailbox*

PAUL HASTINGS LLP 200 Park Avenue, New York, NY 10166-3205 t: +1.212.318.6000 f: +1.212.319.4090 www.paulhastings.com

New York, NY 10166 Luc Despins as Chapter 11 Trustee in the case of Ho May 9, 2024

Attn: Luc Despins FOR PROFESSIONAL SERVICES RENDERED PH LLP Tax ID No. 95-2209675

Date Initials Description Hours Rate Amount

01/09/2024 NAB Participate in hearing on Rule 55(c) motion (1.5); debrief correspondence with A. Luft, L. Despins regarding same (.2) 1.70 1,835.00 3,119.50 Subtotal: B155 Court Hearings 1.70 3,119.50

01/02/2024 ECS1 Correspond with D. Barron regarding

01/03/2024 ECS1 Review and prepare documents for N. Bassett for January 9, 2024 hearing on the HCHK Entities' Rule 55(c) motion 0.80 1,270.00 1,016.00 01/03/2024 NAB Review certain submissions in preparation for January 9 hearing in HCHK litigation 0.40 1,835.00 734.00

Case 22-50073 Doc 3283 Filed 06/24/24 Entered 06/24/24 18:35:48 Page 200 of 562

Date Initials Description Hours Rate Amount

01/04/2024 DEB4 Conference with A. Luft, D. Rogers (Kroll), P. Parizek (Kroll) regarding HCHK devices (0.6); correspond with E. Sutton regarding

01/04/2024 ECS1 Correspond with P. Linsey (NPM) re

01/04/2024 AEL2 Call with D. Barron and Kroll re: HCHK

01/04/2024 AEL2 Correspond with R. Jareck (CS) re: data

01/05/2024 ECS1 Review memorandum decision on Proposed Intervenors intervention motion 0.20 1,270.00 254.00 01/05/2024 JPK1 Review Court's proposed intervenor order 0.30 1,185.00 355.50 01/07/2024 LS26 Review documents and public records re:

01/08/2024 DEB4 Correspond with E. Sutton and S. Placona regarding bank accounts 0.20 1,395.00 279.00 01/08/2024 NAB Prepare for hearing on Rule 55(c) motion

pleadings for same (4.4); correspond with L. Song regarding same (.4) 4.80 1,835.00 8,808.00 01/08/2024 WCF Analyze Rule 55(c) briefing and authorities

01/09/2024 NAB Prepare for hearing on Rule 55(c) motion by analyzing arguments and related caselaw

01/09/2024 WCF Analyze authorities regarding prejudice

(1.6); correspond with N. Bassett regarding same

01/10/2024 DM26 Electronically file Trustee's response in

to file supplemental brief via the Court's

Case 22-50073 Doc 3283 Filed 06/24/24 Entered 06/24/24 18:35:48 Page 201 of 562

Luc Despins as Chapter 11 Trustee in the case of Ho Wan Kwok 50687-00014 Invoice No. 2395799

Date Initials Description Hours Rate Amount

01/10/2024 NAB Review motion for supplemental briefing (.1); correspond with W. Farmer regarding same (.3); review and revise draft opposition

01/10/2024 WCF Correspond with N. Bassett regarding

supplemental briefing (.1) draft response to

01/12/2024 AEL2 Analyze Shaban post-hearing brief 0.40 1,850.00 740.00 01/12/2024 NAB Review supplemental Rule 55(c) motion brief (.3); correspond with P. Linsey (NPM) regarding appellate issues (.1) 0.40 1,835.00 734.00 01/16/2024 NAB Draft response to supplemental HCHK Defendants' brief in support of rule 55(c)

regarding same (.4) 2.50 1,835.00 4,587.50 01/16/2024 WCF Draft response to Rule 55(c) post-hearing

01/17/2024 JK21 Correspond with W. Farmer regarding filing

(0.1); prepare for electronic filing response to HCHKV post-hearing brief (0.1); electronically file with the court response to

post-hearing brief (0.1) 0.40 565.00 226.00 01/17/2024 LAD4 Review/edit our response to HCHK supplemental brief 1.10 1,975.00 2,172.50 01/17/2024 NAB Review and revise draft response to supplemental rule 55(c) brief (1.8); analyze authority in connection with same (.5);

regarding same (.3) 2.60 1,835.00 4,771.00

Case 22-50073 Doc 3283 Filed 06/24/24 Entered 06/24/24 18:35:48 Page 202 of 562

Date Initials Description Hours Rate Amount

01/22/2024 NAB Review letter to Court by opposing counsel regarding potential New York action (.1); correspond with L. Despins regarding same

Subtotal: B191 General Litigation 28.00 45,786.50

01/04/2024 ECS1 Correspond with D. Barron and A. Luft regarding investigation into and analysis of HCHK Entities' cash holdings 0.30 1,270.00 381.00 01/08/2024 ECS1 Analyze HCHK Entities' cash holdings 0.20 1,270.00 254.00 01/08/2024 ECS1 Correspond with N. Shanahan (Cole

moving out of Columbus Circle offices 0.20 1,270.00 254.00 01/09/2024 ECS1 Analyze HCHK Entities' cash holdings 0.20 1,270.00 254.00 01/11/2024 ECS1 Continue to analyze HCHK Entities' cash

01/17/2024 ECS1 Correspond with N. Shanahan (Cole

01/17/2024 ECS1 Correspond with T. Sadler and D. Barron regarding Assignee expenses monthly report 0.20 1,270.00 254.00 01/18/2024 ECS1 Prepare Assignee expenses monthly report (.2); correspond with T. Sadler and D.

monthly report (.1) 0.30 1,270.00 381.00 01/18/2024 TS21 Correspond with E. Sutton re HCHK

01/19/2024 ECS1 Prepare Assignee expenses monthly report (.2); correspond with T. Sadler and D. 0.30 1,270.00 381.00

Case 22-50073 Doc 3283 Filed 06/24/24 Entered 06/24/24 18:35:48 Page 203 of 562 Luc Despins as Chapter 11 Trustee in the case of Ho Wan Kwok 50687-00014 Invoice No. 2395799

Date Initials Description Hours Rate Amount

Correspond with E. Sutton regarding filing expense report for December (0.1); prepare

December (0.1); electronically file with the Court expense report for December (0.1); review and handle service of expense report

Subtotal: B210 Business Operations 3.10 3,712.00

ID Timekeeper Name Title Hours Rate Fee LAD4 Luc A. Despins Partner 1.10 1,975.00 2,172.50 NAB Nicholas A. Bassett Partner 17.10 1,835.00 31,378.50

Avi E. Of Counsel 1.20 1,850.00 2,220.00 DEB4 Douglass E. Barron Associate 0.90 1,395.00 1,255.50 WCF Will C. Farmer Associate 6.10 1,390.00 8,479.00 TS21 Tess Sadler Associate 0.60 1,365.00 819.00 ECS1 Ezra C. Sutton Associate 3.30 1,270.00 4,191.00 JPK1 Jon P. Kosciewicz Associate 0.30 1,185.00 355.50 LS26 Luyi Song Associate 1.20 985.00 1,182.00 JK21 Jocelyn Kuo Paralegal 0.80 565.00 452.00 DM26 David Mohamed Paralegal 0.20 565.00 113.00

Date Description Quantity Rate Amount

01/05/2024 Photocopy Charges 36.00 0.08 2.88 01/08/2024 Photocopy Charges 261.00 0.08 20.88 01/08/2024 Photocopy Charges (Color) 37.00 0.20 7.40

Case 22-50073 Doc 3283 Filed 06/24/24 Entered 06/24/24 18:35:48 Page 204 of 562

Luc Despins as Chapter 11 Trustee in the case of Ho Wan Page 6

Total Costs incurred and advanced \$1,388.15

Avram Luft; 12/20/2023; Restaurant: Seamless; City: New York; Dinner; Number of people: 1; Meal while working on client

Ecklund, Amy.; USB Thumb Drive; 11/28/23 73.17

Ecklund, Amy.; USB Thumb Drive; 11/17/23 73.17

Ecklund, Amy.; USB Thumb Drive; 11/28/23 73.17 12/27/2023 Computer Search (Other) 0.99

Expeditor Inc. (USD)(JPMSUA); Invoice # 99006 dated 11/30/2023; From: Paul Hastings Llp; To:

Federal Bldg 915 Lafayette Blvd., Bridgeport Ct 06604; Order # 1591255 dated 11/21/2023 10:35 354.50 09/07/2023 Outside Professional Services -

Solutions, LLC, Invoice# INV2576713 Dated 09/07/23, Deposition cancellation cost for

Case 22-50073 Doc 3283 Filed 06/24/24 Entered 06/24/24 18:35:48 Page 205 of 562

PAUL HASTINGS LLP 200 Park Avenue, New York, NY 10166-3205 t: +1.212.318.6000 f: +1.212.319.4090 www.paulhastings.com

Luc Despins as Chapter 11 Trustee in the case of Ho Wan Kwok 200 Park Avenue New York, NY 10166

Attn: Luc Despins PH LLP Tax ID No. 95-2209675

Mei Guo Adversary Proceeding PH LLP Client/Matter # 50687-00016 Luc A. Despins