Guo Wengui / Miles Guo — bankruptcy case · ORDER · ECF #3484

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

| ----------------------------------------------------------- | x | | |-------------------------------------------------------------|-------------|-------------------------| | In re: | :<br>: | Chapter 11 | | HO WAN KWOK et al., | :<br>: | Case No. 22-50073 (JAM) | | Debtors.1 | :<br>:<br>: | Jointly Administered | | ----------------------------------------------------------- | x | |

#### **NOTICE OF FILING**

# **SUPPLEMENTAL DECLARATION OF DAVID HAFFENREFFER IN SUPPORT OF MOTION OF TRUSTEE, PURSUANT TO BANKRUPTCY CODE SECTIONS 327(a), 328, AND 363(b), BANKRUPTCY RULES 2014(a) AND 2016, AND LOCAL RULE 2014- 1, FOR ENTRY OF ORDER (I) AUTHORIZING EMPLOYMENT AND RETENTION OF REAL PROPERTY BROKER, EFFECTIVE AS OF AUGUST 23, 2024, FOR SALE OF GREENWICH PROPERTY, (II) AUTHORIZING TRUSTEE TO FUND EXPENSES RELATED TO GREENWICH PROPERTY AND (III) FOR RELATED RELIEF**

Luc A. Despins, in his capacity as Chapter 11 Trustee (the "Trustee") for Ho Wan Kwok, hereby files the *Supplemental Declaration of David Haffenreffer* in support of the *Motion of Trustee, Pursuant to Bankruptcy Code Sections 327(a), 328, and 363(b), Bankruptcy Rules 2014(a) and 2016, and Local Rule 2014-1, for Entry of Order (I) Authorizing Employment and Retention of Real Property Broker, Effective as of August 23, 2024, for Sale of Greenwich Property, (II) Authorizing Trustee to Fund Expenses Related to Greenwich Property and (III) for SRelated Relief* [ECF No. 3450], appended hereto as **Exhibit A**.

<span id="page-0-0"></span>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).

New Haven, Connecticut

#### Dated: August 29, 2024 LUC A. DESPINS, CHAPTER 11 TRUSTEE

By: */s/ Patrick R. Linsey*

Douglas S. Skalka (ct00616) Patrick R. Linsey (ct29437) NEUBERT, PEPE & MONTEITH, P.C. 195 Church Street, 13th Floor New Haven, Connecticut 06510 (203) 781-2847 dskalka@npmlaw.com plinsey@npmlaw.com

*and*

G. Alexander Bongartz (admitted *pro hac vice*) PAUL HASTINGS LLP 200 Park Avenue New York, New York 10166 (212) 318-6079 alexbongartz@paulhastings.com

*and*

Nicholas A. Bassett (admitted *pro hac vice*) PAUL HASTINGS LLP 2050 M Street NW Washington, D.C., 20036 (202) 551-1902 nicholasbassett@paulhastings.com

*Counsel for the Chapter 11 Trustee*

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

| ----------------------------------------------------------- | x | | |-------------------------------------------------------------|--------|-------------------------| | In re: | :<br>: | Chapter 11 | | HO WAN KWOK et al., | :<br>: | Case No. 22-50073 (JAM) | | Debtors.1 | :<br>: | Jointly Administered | | ----------------------------------------------------------- | :<br>x | |

## **SUPPLEMENTAL DECLARATION OF DAVID HAFFENREFFER IN SUPPORT OF MOTION OF TRUSTEE, PURSUANT TO BANKRUPTCY CODE SECTIONS 327(a), 328, AND 363(b), BANKRUPTCY RULES 2014(a) AND 2016, AND LOCAL RULE 2014- 1, FOR ENTRY OF ORDER (I) AUTHORIZING EMPLOYMENT AND RETENTION OF REAL PROPERTY BROKER, EFFECTIVE AS OF AUGUST 23, 2024, FOR SALE OF GREENWICH PROPERTY, (II) AUTHORIZING TRUSTEE TO FUND EXPENSES RELATED TO GREENWICH PROPERTY AND (III) FOR RELATED RELIEF**

I, David Haffenreffer, being duly sworn, state the following under penalty of perjury:

1. I am managing director of Compass, Inc. ("Compass"), at its office located at 200

Greenwich Avenue, 3rd Floor, Greenwich, Connecticut 06830.

1. I am duly authorized to make this supplemental declaration (this "Declaration")

on behalf of Compass and submit this Declaration in support of the *Motion of Trustee, Pursuant*

*to Bankruptcy Code Sections 327(a), 328, and 363(b), Bankruptcy Rules 2014(a) and 2016, and*

*Local Rule 2014-1, for Entry of Order (I) Authorizing Employment and Retention of Real*

*Property Broker, Effective as of August 23, 2024, for Sale of Greenwich Property,*

*(II) Authorizing Trustee to Fund Expenses Related to Greenwich Property and (III) for Related*

*Relief* [ECF No. 3450] (the "Motion")[2](#page-2-1) in the chapter 11 case (the "Chapter 11 Case") of Ho

<span id="page-2-0"></span>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).

<span id="page-2-1"></span>² Capitalized terms used but otherwise not defined herein shall have the meanings ascribed to them in the Motion.

Wan Kwok (the "Debtor"), seeking an order approving, among other things, the retention of Compass as broker pursuant to sections 327(a) and 328(a) of the Bankruptcy Code.

2. In connection with the Motion, the Compass Transaction Operations Department has performed a company-wide search with respect to the Debtor, his immediate family members, and his alter egos, as listed in **Schedule 1** attached hereto (collectively, the "Debtor Affiliated Parties"). As a result of this search, Compass has determined that it does not have contractual relationships and has not transacted with any of the Debtor Affiliated Parties.

3. Based on the foregoing, (a) Compass has no connection with the Debtor, or any of the Debtor Affiliated Parties; and (b) (i) Compass is not a creditor, equity security holder, or insider of the Debtor or his affiliates, (ii) Compass has not been, within two years before the petition date of the Chapter 11 Case, a director, officer, or employee of the Debtor or his affiliates, and (iii) Compass does not have an interest materially adverse to the interests of the Debtor's estate or any class of creditors or equity security holders by reason of any direct or indirect relationship to, connection with, or interest in the Debtor, or for any other reason. Therefore, I understand from my discussions with Paul Hastings LLP, that this means Compass is a "disinterested person" within the meaning of section 101(14) of the Bankruptcy Code, as modified by section 1107(b).

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

Dated: August 29, 2024 */s/ David Haffenreffer*

David Haffenreffer Managing Director Compass, Inc.

# **Schedule 1**

### **Debtor Affiliated Parties**

# **Debtor Affiliated Parties**

- Ho Wan Kwok (A/K/A Miles Kwok, Miles Guo and Wengui Guo) - Hing Ch Ngok/Yue Qingzhi - Qiang Guo/Mileson Guo - Mei Guo/Mei Gui - Greenwich Land, LLC - HCHK Technologies, Inc. - HCHK Property Management, Inc. - Lexington Property and Staffing, Inc. - Golden Spring (New York) Ltd. - Lamp Capital LLC - HK International Funds Investments (USA) Limited, LLC