Guo Wengui / Miles Guo — bankruptcy case · ECF #3320

METADATA

Defendant: Guo Wengui / Miles Guo / Ho Wan Kwok
Court: CTB
Case No.: 22-50073
ECF #: 3320
Type: UNKNOWN

FULL TEXT

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

| _________________________________________ | | |-------------------------------------------|---------------------------------------------| | In Re: | : CHAPTER 11 | | HO WAN KWOK, et al.1 | : : CASE NO. 22-50073 (JAM) | | Debtors. | : : (Jointly Administered) : | | LUC A DESPINS, CHAPTER 11 TRUSTEE | : : | | Plaintiff, | : : Adv. Proceeding No. 24-05130 : | | v. | : | | ON THE SPOT HOME IMPROVEMENT, INC., | : : : | | Defendant. | : : : |

#### **MOTION FOR ADMISSION** *PRO HAC VICE* **OF JUSTIN BAUMGARTNER**

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 partner of the law firm Shipman & Goodwin LLP, respectfully moves that the Court admit attorney Justin S. Baumgartner, a member of the Bars of the State of New Jersey and New York *pro hac vice* to represent On The Spot Home Improvement, Inc., in the above-captioned Chapter 11 bankruptcy case and in the related adversary proceeding*, Luc Despins, Chapter 11 Trustee v.*

1 The Debtors in these chapter 11 cases are Ho Wan Kwok (also known as Guo Wengui, Miles Guo, and Miles Kwok, as well as numerous other aliases) (last four digits of tax identification number: 9595), Genever Holdings LLC (last four digits of tax identification number: 8202) and Genever Holdings Corporation. The mailing address for the Trustee, Genever Holdings LLC, and the Genever Holdings Corporation is Paul Hastings LLP, 200 Park Avenue, New York, NY 10166 c/o Luc A. Despins, as Trustee for the Estate of Ho Wan Kwok (solely for purposes of notices and communications).

*On The Spot Home Improvement, Inc.* Adv. Pro. No. 24-05130, and in support represents the following:

1. The primary office of Attorney Justin S. Baumgartner is Becker LLC, Eisenhower Plaza II, 354 Eisenhower Parkway, Suite 1500, Livingston, New Jersey 07039. His telephone number is (973) 251-8920 and his email address is jbaumgartner@becker.legal.

2. Attorney Justin S. Baumgartner is a member in good standing in the states and jurisdictions set forth in his declaration, attached as **Exhibit A**.

3. To the best of my knowledge and belief, Attorney Justin S. Baumgartner 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 Justin S. Baumgartner 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 Justin S. Baumgartner has submitted the filing fee of \$200.00 with this motion for *pro hac vice* admission.

6. Service of all papers directed to On The Spot Home Improvement, Inc., 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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July 16, 2024

Hartford, Connecticut

By: */s/ Eric S. Goldstein* Eric S. Goldstein, Esq. (ct27195) Shipman & Goodwin LLP One Constitution Plaza Hartford, CT 06103 Telephone: 860-251-5000 Facsimile: 860-251-5218 Email:egoldstein@goodwin.com

*Local Counsel for On The Spot Home Improvement, Inc.*

#### **CERTIFICATION**

I hereby certify that the foregoing *Motion for Admission Pro Hac Vice of Justin S. Baumgartner* as visiting attorney was filed electronically on July 16, 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/ Eric S. Goldstein* Eric S. Goldstein

## **Exhibit A**

Declaration of Justin S. Baumgartner, Esq.

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

# **DECLARATION OF JUSTIN S. BAUMGARTNER IN SUPPORT OF MOTION FOR ADMISSION** *PRO HAC VICE*

I, Justin S. Baumgartner being of full age, having been dully sworn according to law,

state the following:

1. I am an attorney at Becker LLC. My telephone number is (973) 251-8920; and

my email address is jbaumgartner@becker.legal.

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

as counsel for On The Spot Home Improvement, Inc., in the above-captioned Chapter 11 case

and in the related adversary proceeding, *Luc Despins, Chapter 11 Trustee v. On The Spot Home Improvement, Inc.* Adv. Pro. No. 24-05130.

3. In accordance with D. Conn. L. Civ. R. 83.1(d), I am an active member in good standing of the Bar of the States of New Jersey (Bar No. 245262017) and New York. In addition, I am a member in good standing of (i) the United States Courts of Appeals for the Third Circuit and (ii) the United States District Courts for the District of New Jersey, the Southern District of New York, and the Eastern District of New York. Bar numbers are not assigned upon admissible for the State of New York, the all of the above-referenced United States district courts, and the Third Circuit Court of Appeals.

4. I have no pending disciplinary complaints as to which a finding has been made that such complaint should proceed to a hearing. 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 while facing a disciplinary complaint before this Court or any other court.

5. I have fully reviewed 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 Rules 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.

6. I hereby designate my sponsoring attorney, Eric S. Goldstein (Federal Bar No. ct27195) of Shipman & Goodwin LLP, as my agent for service of process. Pursuant to D. Conn. L. Civ. 83.1 (d), I designate the District of Connecticut as the forum for any resolution of any dispute arising out of my admission *pro hac vice* in the above-captioned Chapter 11

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case and related cases.

7. I understand that upon admission under D. Conn. L. Civ. 83.1 (d) I must promptly file a certificate of good standing from the court of the state in which I have my primary office. I acknowledge that the certificate shall be filed no later than 60 days after the date of admission and shall be dated no more than 60 days before the date of admission. I understand that failure to file such certificate will result in the automatic revocation of my visiting attorney status, absent an order of the Court. Furthermore, I understand that upon revocation of my visiting attorney status in one case, the Clerk of the Court shall examine the Court's Docket and revoke my visiting attorney status in all cases in which I have filed an appearance.

8. I will file my appearance with the Court after my admission has been approved.

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

This 16th day of July, 2024.

\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_ Justin S. Baumgartner \_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_