Guo Wengui / Miles Guo — bankruptcy case · ORDER · ECF #3347

UNITED STATES BANKRUPTCY COURT DISTRICT OF CONNECTICUT BRIDGEPORT DIVISION

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In re: :

HO WAN KWOK, et al., :

Debtors.1 :

MONTHLY FEE STATEMENT OF KROLL, LLC FOR COMPENSATION AND REIMBURSEMENT OF EXPENSES FOR PERIOD FROM JUNE 1, 2024 THROUGH JUNE 30, 2024

In accordance with the Order Establishing Procedures for Interim Compensation and

Reimbursement of Expenses for Retained Professionals, dated August 18, 2023 [Docket No.

2094] (the "Interim Compensation Order"),2 Kroll, LLC ("Kroll") hereby submits this monthly statement (the "Monthly Fee Statement") seeking compensation for services rendered and reimbursement of expenses incurred as forensic investigators to Luc A. Despins, in his capacity as the chapter 11 trustee (the "Trustee") appointed in the chapter 11 case of Ho Wan Kwok, for the period from June 1, 2024 through and including June 30, 2024 (the "Fee Period"). By this Monthly Fee Statement, Kroll respectfully requests payment of 80% of all fees and 100% of all expenses actually and necessarily incurred for services rendered during the Fee Period, in the amounts of \$28,160.80 and \$126.88, respectively.

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

2 Capitalized terms not otherwise defined herein shall have the meanings ascribed to such terms in the Interim Compensation Order.

1. Attached hereto as Exhibit A is a timekeeper summary that includes the name, title, service line, standard rate, discounted rate, total hours, and total fees earned for each Kroll individual who provided services during the Fee Period. The rates charged by Kroll for services rendered to the Trustee are discounted per the engagement letter to the rates that Kroll charges generally for professional services rendered to its non-bankruptcy clients.

2. Attached hereto as Exhibit B is a summary of Kroll's services rendered and compensation sought for the Fee Period organized by Project Category.

3. Attached hereto as Exhibit C is a summary of Kroll's services rendered and compensation sought for the Fee Period organized by Matter ID.

4. Attached hereto as Exhibit D is a summary of Kroll's expenses incurred and reimbursement sought for the Fee Period organized by Expense Type.

5. Attached hereto as Exhibit E are Kroll's fee statements for services provided during the Fee Period.

6. Notice of this Monthly Fee Statement will be given by email on the Notice Parties: (i) Luc A. Despins, as chapter 11 trustee for the estate of Ho Wan Kwok (lucdespins@paulhastings.com); (ii) Counsel for the Trustee, (x) Paul Hastings LLP, 200 Park Avenue, New York, New York 10166 (Attn: G. Alexander Bongartz (alexbongartz@paulhastings.com) and Douglass Barron (douglassbarron@paulhastings.com)) and (y) Neubert, Pepe & Monteith, P.C., 195 Church Street, 13th Floor, New Haven, Connecticut 06510 (Attn: Douglas S. Skalka (dskalka@npmlaw.com) and Patrick R. Linsey (plinsey@npmlaw.com)); (iii) the Office of The United States Trustee, Giaimo Federal Building, 150 Court Street, Room 302, New Haven, Connecticut 06510 (Attn: Holley L. Claiborn

(holley.l.claiborn@usdoj.gov)); (iv) counsel for the Official Committee of Unsecured Creditors, Pullman & Comley, LLC, 850 Main Street, 8th Floor, PO Box 7006, Bridgeport, Connecticut 06601-7006 (Attn: Irve J. Goldman (igoldman@pullcom.com); and (v) counsel for Pacific Alliance Asia Opportunity Fund L.P., O'Melveny & Myers LLP, 7 Times Square, New York, New York 10036 (Attn: Peter Friedman (pfriedman@omm.com) and Stuart M. Sarnoff (ssarnoff@omm.com) (collectively, the "Notice Parties").

7. Objections to this Monthly Fee Statement, if any, must be filed with the Court and served upon (i) Kroll (Attn: Allen Pfeiffer (allen.pfeiffer@kroll.com) and (ii) the Notice Parties by email no later than August 13, 2024 at 4:00 p.m. (prevailing Eastern Time) (the "Objection Deadline"), setting forth the nature of the objection and the specific amount of fees or expenses at issue.

8. If no objections to this Monthly Fee Statement are filed and received on or before the Objection Deadline, the estate shall promptly pay Kroll 80% of the fees and 100% of the expenses identified in this Monthly Fee Statement.

9. To the extent that an objection to this Monthly Fee Statement is filed and received on or before the Objection Deadline, the estate shall withhold payment of that portion of this Monthly Fee Statement to which the objection is directed and promptly pay the remainder of the fees and expenses in the percentages set forth above. To the extent such an objection is not

resolved, it shall be preserved and scheduled for consideration at the next interim fee application hearing.

Allen Pfeiffer KROLL, LLC 55 East 52nd Street, Floor 17 New York, New York 10055 UNITED STATES BANKRUPTCY COURT DISTRICT OF CONNECTICUT BRIDGEPORT DIVISION

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In re: :

HO WAN KWOK, et al.,1 : :

Debtors. :

The undersigned hereby certifies that on July 23, 2024, the foregoing Monthly Fee Statement was electronically filed. In addition, a copy of the Monthly Fee Statement was served by email on the Notice Parties. Parties may access this filing through the Court's CM/ECF system.

Dated: July 23, 2024 By: /s/ G. Alexander Bongartz

New York, New York G. Alexander Bongartz (admitted pro hac vice) PAUL HASTINGS LLP 200 Park Avenue New York, New York 10166 (212) 318-6000 alexbongartz@paulhastings.com

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).

Timekeeper Title Service Line Standard Discounted Total Total Fees

Parizek, Pam Managing Director Forensic Investigations \$ 850 \$ 680 9.4 \$

Lazarus, Jordan Senior Manager Forensic Investigations \$ 550 \$ 495 19.0 \$

Lomas, Adam Senior Manager Forensic Investigations \$ 550 \$ 495 39.2 \$

Total Hours and Fees:

SUMMARY OF COMPENSATION BY PROJECT CATEGORY

U.S. Trustee Task Code and Project Category Hours Billed Fees Billed

B120 Asset Analysis and Recovery 39.7 \$ 20,410.00 B160 Fee/Employment Applications 5.0 \$ 3,400.00 B180 Avoidance Action Analysis 4.1 \$ 2,085.00

Matter ID and Name Hours Billed Fees Billed

00001 General Debtor Representation 5.0 \$

00002 Asset Recovery Investigation and Litigation 58.1 \$

00012 Golden Spring Adversary Proceeding 2.5 \$

00016 G-Club Adversary Proceeding 1.3 \$

00018 UAE Asset Recovery Actions 0.4 \$

Expense Category Matter ID Task Code Expense Amount

Timekeeper Date Matter Task Narrative Hours Rate Amount

Lazarus, Jordan 06/03/2024 Asset Recovery

and Recovery Call with B. Scodeller re: analysis of document production. 0.3 \$ 495 \$ 148.50 Lazarus, Jordan 06/03/2024 Asset Recovery

document production. 1.7 \$ 495 \$ 841.50

and Recovery Review A. Lomas analysis of

and Recovery Compose email to Paul Hastings [D.

and Recovery Review of accounting/bookkeeping

reconciliation to bank statements; related attention to master transaction file. 5.0 \$ 495 \$ 2,475.00

and Recovery Respond to inquiry from NPM Law [K.

and Recovery Prepare summary schedule of sources

Lazarus, Jordan 06/06/2024 Asset Recovery

and Recovery Attend weekly call with P. Parizek, A. Lomas, Paul Hastings [L. Despins, N. Bassett, D. Barron], NPM Law [K. Mitchell] re:

August 15 deadline. 0.8 \$ 495 \$ 396.00

and Recovery Draft agenda [.1] and attend weekly call

NPM Law [K. Mitchell] re:

and Recovery Review A. Lomas analysis re: 0.2 \$ 680 \$ 136.00

and Recovery Attend weekly call with P. Parizek,J. Lazarus, Paul Hastings [L. Despins, N. Bassett, D. Barron], NPM Law [K. Mitchell] re:

August 15 deadline. 0.8 \$ 495 \$ 396.00

Timekeeper Date Matter Task Narrative Hours Rate Amount

Lazarus, Jordan 06/10/2024 Asset Recovery

and Recovery Respond to email inquiry from NPM Law [K. Mitchell] re:

transaction file for review and analysis. 0.5 \$ 495 \$

and Recovery Compose email to NPM Law [K.

and Recovery Review and analysis of transactions in

to master transaction file. 1.0 \$ 495 \$

Lazarus, Jordan 06/11/2024 Asset Recovery

and Recovery Review and analysis of transactions in

and Recovery Review and analysis of transactions in

to master transaction file. 0.7 \$ 495 \$

Lazarus, Jordan 06/12/2024 Asset Recovery

and Recovery Correspondence with NPM Law [P.

re:

Lazarus, Jordan 06/12/2024 Asset Recovery

and Recovery Review of additional documents

and Recovery Review and analysis of transactions in

Timekeeper Date Matter Task Narrative Hours Rate Amount

and Recovery Compose email to Paul Hastings and NPM Law counsel teams re:

June 13 status update call. 1.3 \$ 495 \$

and Recovery Review and analysis of transactions in

to master transaction file. 0.5 \$ 495 \$

and Recovery Prepare summary schedule of activity in

and Recovery Review and analysis of transactions in

to master transaction file. 0.4 \$ 495 \$

and Recovery Call with A. Lomas, Paul Hastings [L. Despins, N. Bassett, D. Barron, L. Song],

and Recovery Call with P. Parizek, Paul Hastings [L. Despins, N. Bassett, D. Barron, L. Song],

Lazarus, Jordan 06/14/2024 Asset Recovery

and Recovery Correspondence with NPM Law and Paul Hastings re:

Lazarus, Jordan 06/17/2024 Asset Recovery

and Recovery Correspondence with NPM Law and Paul Hastings re:

and Recovery Review Paul Hastings request Paul Hastings [N. Bassett] re:

bank documentation re: same. 0.2 \$ 680 \$

and Recovery Review A. Lomas analyses re: alter egos [.2], summary re:

Lazarus, Jordan 06/18/2024 Asset Recovery

and Recovery Review transactional activity and

Lazarus, Jordan 06/18/2024 Asset Recovery

and Recovery Review transactional activity for

Lazarus, Jordan 06/18/2024 Asset Recovery

and Recovery Correspondence with Paul Hastings and Kroll team re: payments to 0.2 \$ 495 \$

Lazarus, Jordan 06/18/2024 Asset Recovery

and Recovery Correspondence with Paul Hastings and

Timekeeper Date Matter Task Narrative Hours Rate Amount

Lazarus, Jordan 06/19/2024 Asset Recovery

supporting documents related to 0.4 \$ 495 \$ 198.00

and Recovery Confer Kroll team re: status updates, outreach to Paul Hastings re: same. 0.1 \$ 680 \$ 68.00 Lazarus, Jordan 06/19/2024 Asset Recovery

and Recovery Review of transactional activity for payments made to 0.5 \$ 495 \$ 247.50 Lazarus, Jordan 06/19/2024 Asset Recovery

and Recovery Correspondence with NPM Law re:

bank statement production. 0.2 \$ 495 \$ 99.00 Lazarus, Jordan 06/19/2024 Asset Recovery

and Recovery Correspondence with NPM Law re:

and related matters. 0.2 \$ 495 \$ 99.00 Lazarus, Jordan 06/19/2024 Asset Recovery

and Recovery Review of Kroll bank statement inventory and Relativity re:

Lazarus, Jordan 06/24/2024 Asset Recovery

and Recovery Correspondence with NPM Law re:

Lazarus, Jordan 06/24/2024 Asset Recovery

and Recovery Review correspondence from NPM Law

and related matters. 0.2 \$ 495 \$ 99.00 Lazarus, Jordan 06/26/2024 Asset Recovery

and Recovery Review testimony transcript of 0.5 \$ 495 \$ 247.50

and Recovery Status update to Paul Hastings [.1].

re:

Action Analysis Respond to inquiry from NPM Law [P.

avoidance complaint. 0.5 \$ 495 \$ 247.50

Action Analysis Call with M. Bottos re: instructions for

and related bank document support. 0.4 \$ 495 \$ 198.00

Call with A. Lomas, J. Lazarus, M.

for avoidance action and related Hours Rate

Lazarus, Jordan 06/05/2024 Asset Recovery

Action Analysis workstreams. Call with P. Parizek, A. Lomas, M.

for avoidance action and related 0.3 \$ 495 \$

Action Analysis workstreams. Call with P. Parizek, J. Lazarus, M.

Lazarus, Jordan 06/25/2024 Asset Recovery

Action Analysis Analysis of pre-petition avoidance action payments per request from Paul Hastings. 1.4 \$ 495 \$

Action Analysis Respond to email inquiry from NPM

and Litigation Investigations Call with J. Lazarus, M. Bottos re:

Lazarus, Jordan 06/05/2024 Asset Recovery

and Litigation Investigations Call with A. Lomas, M. Bottos re:

and Litigation Investigations Compose email to Paul Hastings and NPM Law counsel teams re:

and Litigation Investigations Call with Paul Hastings [N. Bassett, D. Barron] re: Relativity review of 0.5 \$ 495 \$

and Litigation Investigations Review list of

provided by Paul Hastings [D. Barron];

entities against master transaction file. 3.2 \$ 495 \$

and Litigation Investigations Review list of

provided by Paul Hastings [D. Barron];

entities against master transaction file. 0.5 \$ 495 \$

and Litigation Investigations Compose email to Paul Hastings [D.

and Litigation Investigations Compose email to NPM Law [K. Mitchell] re: additional entities and bank

Timekeeper Date Matter Task Narrative Hours Rate Amount

Lazarus, Jordan 06/17/2024 Asset Recovery

and Litigation Investigations Correspondence with Paul Hastings [D.

Lazarus, Jordan 06/17/2024 Asset Recovery

and Litigation Investigations Analysis of transactional detail and

Lazarus, Jordan 06/19/2024 Asset Recovery

and Litigation Investigations Correspondence with NPM Law re: 0.1 \$ 495 \$

Lazarus, Jordan 06/20/2024 Asset Recovery

and Litigation Investigations Correspondence with Paul Hastings re:

Lazarus, Jordan 06/20/2024 Asset Recovery

and Litigation Investigations Review of transactional activity for

Lazarus, Jordan 06/21/2024 Asset Recovery

and Litigation Investigations Correspondence and Relativity searches

and Litigation Investigations Review of updated document production

and Litigation Investigations Compose email to Paul Hastings [D.

and Litigation Investigations Upload of

reconciliation of statements/accounts 0.9 \$ 495 \$

and Litigation Investigations Incorporation of

Lazarus, Jordan 06/30/2024 Asset Recovery

and Litigation Investigations Analysis of

Lomas, Adam 06/10/2024 G-Club Adversary

and Recovery Review of additional documents

accounts; related attention to inventory of

Timekeeper Date Matter Task Narrative Hours Rate Amount

Lomas, Adam 06/25/2024 G-Club Investigations Respond to email inquiry from NPM 0.5 \$ 495 \$

Adversary Law [K. Mitchell] re:

Parizek, Pam 06/20/2024 General Debtor Fee/Employmen Review, revise May Fee Statement. 1.9 \$ 680 \$

Parizek, Pam 06/21/2024 General Debtor Fee/Employmen Review Kroll fee application for January 1.3 \$ 680 \$

Representation t Applications April 2024, review/approve supporting schedules, confer Paul Hastings [A. Bongartz] re: same. Parizek, Pam 06/21/2024 General Debtor Fee/Employmen Redact May Fee Statement, update 1.8 \$ 680 \$

Representation t Applications schedule of expenses. Parizek, Pam 06/17/2024 Gettr USA Asset Analysis Review Paul Hastings [D. Barron] 0.3 \$ 680 \$

Proceeding and Recovery inquiry re:

team analysis re: same. Lomas, Adam 06/06/2024 Golden Spring Investigations Review and analysis of activity in 1.4 \$ 495 \$

file. Lomas, Adam 06/07/2024 Golden Spring Investigations Review and analysis of activity in 1.1 \$ 495 \$

Parizek, Pam 06/06/2024 UAE Asset Asset Analysis file.

re: same.