Guo Wengui / Miles Guo — bankruptcy case · ORDER · ECF #3445

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 O'SULLIVAN MCCORMACK JENSEN & BLISS PC FOR COMPENSATION AND REIMBURSEMENT OF EXPENSES FOR PERIOD FROM JULY 1, 2024 THROUGH JULY 31, 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] O'Sullivan McCormack Jensen & Bliss PC ("OMJB") hereby submits this monthly statement (the "Monthly Fee Statement") seeking compensation for services rendered and reimbursement of expenses incurred as Special Insurance Counsel to Genever Holdings LLC ("Genever (US)"), for the period from July 1, 2024 through and including July 31, 2024 (the "Fee Period"). By this Monthly Fee Statement, OMJB 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 \$972.00 and \$452.33 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, bar admission, hourly billing rate, aggregate hours, and amount of fees earned for each OMJB individual who provided services during the Fee Period. The rates charged by OMJB for services rendered to Genever (US) are the same rates that OMJB charges generally for professional services rendered to its non-bankruptcy clients.

2. Attached hereto as Exhibit B is a summary of expenses incurred and reimbursement sought, by expense type, for the Fee Period.

3. Attached hereto as Exhibit C is the fee statement of OMJB for services provided during the Fee Period with redactions to protect certain privileged information.

4. 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").

5. Objections to this Monthly Fee Statement, if any, must be filed with the Court and served upon (i) Special Insurance Counsel to Genever Holdings LLC, O'Sullivan McCormack Jensen & Bliss PC (Attn: Michael T. McCormack [\(mmccormack@omjblaw.com\)] (ii) the Notice Parties by email no later than September 10, 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.

6. If no objections to this Monthly Fee Statement are filed and received on or before the Objection Deadline, Genever (US) shall promptly pay OMJB 80% of the fees and 100% of the expenses as identified in this Monthly Fee Statement.

7. To the extent that an objection to this Monthly Fee Statement is filed and received on or before the Objection Deadline, the estates 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. Dated: August 20, 2024 Glastonbury, Connecticut

By:\_\_\_/s/Michael T. McCormack\_\_\_\_\_\_\_\_

Michael T. McCormack (ct13799) Timothy P. Jensen (ct18888) Amy E. Markim (ct27974) O'Sullivan McCormack Jensen & Bliss PC 180 Glastonbury Boulevard, Suite 210 Glastonbury, CT 06033 Tel: 860-258-1993 Fax: 860-258-1991 mmccormack@omjblaw.com tjensen@omjblaw.com amarkim@omjblaw.com

Special Insurance Coverage Counsel for Debtor-In-Possession Genever Holdings LLC 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 August 20, 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.

By:\_\_/s/Michael T. McCormack\_\_\_\_\_\_\_\_

Michael T. McCormack (ct13799) Timothy P. Jensen (ct18888) Amy E. Markim (ct27974) O'Sullivan McCormack Jensen & Bliss PC 180 Glastonbury Boulevard, Suite 210 Glastonbury, CT 06033 Tel: 860-258-1993 Fax: 860-258-1991 mmccormack@omjblaw.com tjensen@omjblaw.com amarkim@omjblaw.com Special Insurance Coverage Counsel for Debtor-In-Possession Genever Holdings LLC

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).

Michael McCormack 1993 \$400 2.6 \$1,040.00 Melissa Gambardella \$125 1.4 \$175.00

Case 22-50073 Doc 3445 Filed 08/20/24 Entered 08/20/24 17:18:49 Page 9 of 12

Date Attorney Activity Time Rate Total

07/16/2024 MBG Draft of June Fee Application and redactions to invoice. 0.50 \$125.00 \$62.50 07/16/2024 MBG Check on status of FOIA request to NYFD and email follow up on

07/17/2024 MTM Review notice re Kwok criminal jury verdict; email correspondence to Luc

07/18/2024 MTM Email communications with counsel re order granting motion to amend

07/22/2024 MBG Further redactions of OMJB June 2024 invoice and finalize Fee Application re same. 0.30 \$125.00 \$37.50 07/22/2024 MBG Attention to e-filing OMJB June 2024 Fee Application and service of same on notice parties. 0.20 \$125.00 \$25.00 07/23/2024 MBG Status check with NYFD re FOIA request response. 0.10 \$125.00 \$12.50 07/23/2024 MTM Review order from court re application for interim fee compensation 0.10 \$400.00 \$40.00 07/24/2024 MTM Review order re status conference and discovery; email correspondence to Attny Despins 0.20 \$400.00 \$80.00 07/26/2024 MTM Conference with L. Despins re 0.20 \$400.00 \$80.00 07/26/2024 MBG Follow up communications through FOIL portal to NYFD re status of

07/29/2024 MTM Revise and supplement joint status report statement re adversary stay issues; email communications with Attny Kavanaugh and Attny Despines 0.40 \$400.00 \$160.00

07/30/2024 MTM Prepare for status conference: review of pretrial order and pending motion for summary judgment (.3); attend status conference before Judge

Expense 07/31/2024 Fees advanced to Logikcull INV266821 5-31-2024 \$230.00 Expense 07/31/2024 Fees advanced to Logikcull INV268453 6-30-2024 \$209.00 Expense 07/31/2024 Westlaw: Month of July \$13.33

Michael McCormack 2.6 \$400.00 \$1,040.00 Melissa Gambardella 1.4 \$125.00 \$175.00

Invoice Number Due On Amount Due Payments Received Balance Due

27792 06/17/2024 \$2,769.58 \$2,279.08 \$490.50 27855 07/11/2024 \$2,154.90 \$0.00 \$2,154.90

Invoice Number Due On Amount Due Payments Received Balance Due

27978 08/12/2024 \$1,667.33 \$0.00 \$1,667.33

Please make all amounts payable to: O'Sullivan McCormack Jensen & Bliss PC

Payment is due upon receipt.

Invoice No. 27978 - 08/12/2024 Case 22-50073 Doc 3445 Filed 08/20/24 Entered 08/20/24 17:18:49 Page 12 of 12

> 180 Glastonbury Boulevard, Suite 210 Glastonbury, CT 06033 Phone: 860-258-1993 www.omjblaw.com