Guo Wengui / Miles Guo — bankruptcy case · ORDER · ECF #3392

LAZARE POTTER GIACOVAS & MOYLE LLP Michael T. Conway, Esq. 747 Third Avenue, 16th Floor New York, NY 10017 Telephone: (917) 242-1597 [mconway@lpgmlaw.com](mailto:mconway@lpgmlaw.com)

*Counsel for Taurus Fund LLC*

## IN THE UNITED STATES BANKRUPTCY COURT FOR THE DISTRICT OF CONNECTICUT

In re: Chapter 11

HO WAN KWOK, *et al.*,

[1](#page-0-0) Case No. 22-50073 (JAM)

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Debtor. (Jointly Administered)

## **RESPONSE OF TAURUS FUND LLC TO AMENDED EMERGENCY MOTION OF CHAPTER 11 TRUSTEE, PURSUANT TO BANKRUPTCY CODE SECTION 363(B), FOR ENTRY OF ORDER AUTHORIZING TRUSTEE TO FUND EXPENSES OF MAHWAH MANSION AND FOR RELATED RELIEF**

Taurus Fund LLC respectfully submits this response to the *Amended Emergency Motion*

*of Chapter 11 Trustee, Pursuant to Bankruptcy Code Section 363(b), for Entry of Order Authorizing Trustee to Fund Expenses of Mahwah Mansion and for Related Relief* (the "Motion").

Unfortunately, the Trustee's Motion is filled with mischaracterizations of fact and, suffice it to say, Taurus Fund LLC objects to the manner in which the Trustee's Motion describes the background in this case. Indeed, the Trustee is aware that the Debtor has no ownership interest in the Mahwah Property or the Taurus Fund LLC, yet he continues to state the contrary based solely

<span id="page-0-0"></span>¹ The debtors in these chapter 11 cases (collectively, the "Chapter 11 Case") 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) ("Mr. Kwok" or the "Debtor"), 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 assertion that the Debtor used the Taurus Fund LLC property from time to time while it was being renovated. Indeed, if the Trustee's theory is true, that the Debtor manipulated members of the New Federal State of China to invest their funds into the Taurus Fund for the purpose of purchasing a home and or other property that he might use, the obvious conclusion is that the Mahwah Property belongs to these members – not to the estate.

Nevertheless, as previously reported to the Court, the Department of Justice has frozen all funds which would otherwise be available to fund the expenses necessary to maintain/secure the Mahwah Property and, accordingly, Taurus Fund LLC *does not object to the relief requested in the Proposed Order filed with the Motion*. This is with full reservation of rights to claim against the Trustee at the appropriate time for damages sustained by Taurus Fund LLC as a consequence of this action.

Despite the nature of this response – a non-objection – the undersigned felt it was important to file it on the docket because he will be in another court at a set of previously scheduled hearings tomorrow, August 13, and will not be able to attend the hearing on the Motion.

Dated: August 12, 2024 New York, New York

LAZARE POTTER GIACOVAS & MOYLE LLP

By: /s/ Michael T. Conway Michael T. Conway Lazare Potter Giacovas & Moyle LLP 747 Third Avenue, 16th Floor New York, NY 10017 Telephone: (917) 242-1597 [mconway@lpgmlaw.com](mailto:mconway@lpgmlaw.com)

*Counsel for Taurus Fund LLC*

## **CERTIFICATE OF SERVICE**

I hereby certify that on August 12, 2024, a copy of foregoing was filed electronically. Notice of this filing will be sent by e-mail to all parties by operation of the Court's electronic filing system or by mail to anyone unable to accept electronic filing as indicated on the Notice of Electronic Filing. Parties may access this filing through the Court's CM/ECF System.

> */s/ Michael T. Conway* Michael T. Conway