Guo Wengui / Miles Guo — bankruptcy case · ECF #3285

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

| :<br>In Re: | :<br>CHAPTER 11 | |------------------------------------------|---------------------------------------| | 1<br>HO WAN KWOK,<br>et al., | :<br>:<br>CASE NO. 22-50073<br>(JAM) | | Debtors. | :<br>:<br>(Jointly Administered)<br>: | | :<br>LUC A. DESPINS, CHAPTER 11 TRUSTEE, | : | | Plaintiff, | :<br>:<br>ADV. PRO.<br>NO.<br>24-5059 | | v. | :<br>: | | FEDERAL EXPRESS CORPORATION, | :<br>: | | Defendant. | :<br>:<br>: |

### **MOTION FOR ADMISSION** *PRO HAC VICE* **OF MICHAEL A. SIEDBAND**

Pursuant to Local Rule of Civil Procedures 83.1(d) of the United States District Court for the District of Connecticut, incorporated herein by Local Rule of Bankruptcy Procedure 1001-1, the undersigned, a member of the Bar of this Court and associate of the law firm Shipman & Goodwin LLP, respectfully moves that the Court admit attorney Michael A. Siedband, a member of the Bar of the State of Tennessee *pro hac vice* to represent Federal Express Corporation, in the above-captioned Chapter 11 bankruptcy case and in the related adversary proceeding, *Despins v. Federal Express Corp.,* Adv. Pro. No. 24-5059, and in support represents the following:

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.

1. Attorney Siedband is an in-house attorney employed by Federal Express Corporation, who maintains his primary office at 3620 Hacks Cross Road, Bldg. B, Memphis, Tennessee 38104. His telephone number is 901-355-2075; and his email address is michael.siedband@fedex.com.

2. Attorney Siedband is a member in good standing in the states and jurisdictions set forth in his/her declaration, attached as **Exhibit A**.

3. To the best of my knowledge and belief, Attorney Siedband is a member in good standing of the courts listed in his declaration, has no pending disciplinary complaints as to which a finding has been made that such complaint should proceed to a hearing and has not been denied admission to, been disciplined by, resigned from, surrendered a license to practice before, or withdrawn an application for admission to practice while facing a disciplinary complaint before, this Court or any other court.

4. To the best of my knowledge and belief, Attorney Siedband has reviewed and is familiar with the Federal Rules of Civil Procedure, the Local Rules of the United States District Court for the District of Connecticut, the Local Rules of the Bankruptcy Court for the District of Connecticut, and the Connecticut Rules of Professional Conduct.

5. Attorney Siedband has submitted the filing fee of \$200.00 with this motion for *pro hac vice* admission.

6. Service of all papers directed to Federal Express Corporation may be made upon the undersigned, pursuant to Rule 83.1(e) of the Local Rules of Civil Procedure for the United States District Court for the District of Connecticut.

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June 25, 2024 Stamford, Connecticut

> By: */s/ Jessica M. Signor* Jessica M. Signor, Esq. (ct30066) Shipman & Goodwin LLP 300 Atlantic Street, 3rd Floor Stamford, CT 06901 Telephone: 203-324-8100 Facsimile: 203-324-8199 Email: jsignor@goodwin.com

*Local Counsel for Federal Express Corporation*

### **CERTIFICATION**

I hereby certify that the foregoing *Motion for Admission Pro Hac Vice of Michael A. Siedband* as visiting attorney was filed electronically on June 25, 2024. Notice of this filing will be sent by email to all parties registered for electronic service in this proceeding through the Court's CM/ECF system.

> */s/ Jessica M. Signor* Jessica M. Signor

## **Exhibit A**

Declaration of Michael A. Siedband, Esq.

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

| CHAPTER 11 | |--------------------------| | | | CASE NO. 22-50073 (JAM) | | (Jointly Administered) | | ADV. PRO. NO.<br>24-5059 | | | | | | | | |

# **DECLARATION OF MICHAEL A. SIEDBAND IN SUPPORT OF MOTION FOR ADMISSION** *PRO HAC VICE*

I, Michael A. Siedband, being of full age, having been dully sworn according to law, state the following:

1. I am an in-house attorney employed by Federal Express Corporation, and maintains my primary office at 3620 Hacks Cross Road, Bldg. B, Memphis, Tennessee 38104. My telephone number is 901-355-2075 and my email address is

michael.siedband@fedex.com.

2. I submit this declaration in support of the motion for my admission *pro hac vice*

as counsel for Federal Express Corporation in the above-captioned Chapter 11 cases and in the

¹ The Debtors in these chapter 11 cases are Ho Wan Kwok (also known as Guo Wengui, Miles Guo, and Miles Kwok, as well as numerous other aliases) (last four digits of tax identification number: 9595), Genever Holdings LLC (last four digits of tax identification number: 8202) and Genever Holdings Corporation.

related adversary proceeding, *Despins v. Federal Express Corp., Adv. Pro. No. 24-5059.*

3. Pursuant to D. Conn. L. Civ. 83(d), I designate the District of Connecticut as the forum for any resolution of any dispute arising out of my admission.

4. I am a member in good standing of the Bars of the State of Tennessee (Bar No. 036315) and the Commonwealth of Massachusetts (Bar No. 676888). In addition, I am a member in good standing of (i) the United States Courts of Appeals for the Second Circuit (Bar No. 4325456) and (ii) the United States District Courts for the District of Massachusetts (Bar No. 676888), the Western District of Tennessee (Bar No. 036315), and the Southern District of Texas (Bar No. 3843005).

5. I have no disciplinary complaints, and I have not been denied admission to, been disciplined by, resigned from, surrendered my license to practice before, or withdrawn an application for admission to practice before this Court or any other court.

6. I have read and am familiar with the Federal Rules of Civil Procedure, the Local Rules of the United States District Court for the District of Connecticut, the Local Rule of the Bankruptcy Court for the District of Connecticut, and the Connecticut Rules of Professional Conduct, and will abide by and comply with the substantive and procedural requirements of the local rules and administrative orders of this Court.

7. I hereby designate my sponsoring attorney, Jessica M. Signor (Federal Bar No. ct30066) of Shipman & Goodwin LLP, as my agent for service of process and the District of Connecticut as the forum for the resolution of any dispute arising out of my admission *pro hac vice* in the above-captioned Chapter 11 cases and related cases.

Pursuant to 28 U.S.C. § 1746, I declare under penalty of perjury that the foregoing is true and accurate.

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This 24th day of June 2024.

Michael A. Siedband