Guo Wengui / Miles Guo — bankruptcy case · ORDER · ECF #3541

## UNITED STATES BANKRUPTCY COURT DISTRICT OF CONNECTICUT

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| | ) | Chapter 11 | |--------------------------------|-------------|----------------------------| | In re: | ) | | | | ) | CASE NO. 22-50073<br>(JAM) | | HO WAN KWOK, ET. AL. | )<br>) | JOINTLY AMINISTERED | | Debtor | )<br>)<br>) | | | ______________________________ | ) | SEPTEMBER 17, 2024 |

## **MOTION TO QUASH SUBPOENAS AND FOR PROTECTIVE ORDER**

YUMEI HAO ("Hao"), RIVER VALLEY OPERATIONS, LLC ("River") and GOLDEN EAGLES VENTURES, LLC (" Golden") (collectively, the "Movants") hereby move to quash the subpoenas for Rule 2004 Examination issued to Old National Bank ("Bank") by Kati Mitchell, as attorney for Chapter 11 Trustee for the Debtor, Luc Despins (the "Trustee") on or about August 29, 2004 (the "Subpoenas"). It is assumed that the Subpoenas were issued pursuant to court orders authorizing examinations of the Movants under Federal Rule of Bankruptcy Procedure 2004. The Movants also hereby move for the issuance of a protective order preventing disclosure of the documents and information requested in the Subpoenas. The Subpoenas were not served upon or sent to the Movants by the Trustee at the same time they were sent to the Bank. The Movants merely received a few pages of each subpoena from the Bank. The Movants want to review the complete Subpoenas and discuss the requested disclosure with the Trustee.

As more fully set forth in the attached memorandum of law, the Subpoenas, in whole or in part, seek documents and information that: (i) are beyond the scope of allowable discovery

under Rule 2004; (ii) the complete subpoenas were never sent to the Movants by the Trustee;

(iii) the subpoenas are part of a "fishing expedition" and seem to be requesting all kinds of bank

records without any explanation of the need for those documents.

WHEREFORE, it is respectfully requested that the Subpoenas be quashed and a

protective order be entered preventing disclosure of the information sought therein.

MOVANTS, YUMEI HAO, RIVER VALLEY OPERATIONS, LLC, GOLDEN EAGLES VENTURES, LLC .

By: \_\_\_s/s\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_

Ross G, Fingold ,Esq. rfingold@lawssf.com Fed Bar #ct05452 Stokesbury & Fingold, LLC 10 Waterside Drive, Suite 204 Farmington, CT 06032 (860) 606-1709

## **CERTIFICATION OF SERVICE**

The undersigned hereby certifies that on the 17th day of September 2014 in accordance with Rules 7004(a), 9014 F.R. Bankr. P., I served a copy of the foregoing by electronic mail.

\_\_s/s\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_ ROSS G. FINGOLD