Guo Wengui / Miles Guo — bankruptcy case · ECF #3578

UNITED STATES BANKRUPTCY COURT DISTRICT OF CONNECTICUT BRIDGEPORT DIVISION

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In re: :

HO WAN KWOK, et al., : Case No. 22-50073 (JAM) Debtors. :

---------------------------------------------------------------- x APPELLEE'S OMNIBUS COUNTER-DESIGNATION OF ADDITIONAL ITEMS TO BE INCLUDED IN RECORD ON APPEAL

Appellee, Luc A. Despins, in his capacity as the chapter 11 trustee (the "Trustee") appointed in the chapter 11 case of Ho Wan Kwok (the "Debtor"), by and through his undersigned counsel, hereby provides, pursuant to Rule 8009 of the Federal Rules of Bankruptcy Procedure, the following counter-designation of additional items to be included in the record on appeal, on a consolidated and omnibus basis, with respect to the following docket items (collectively, the "Designations" and the respective (consolidated) "Appeals"):

- (i) Appellant's Statement of Issues and Designation of Items to be Included in the Record on Appeal [Docket No. 3518] (Appellant Weddle Law PLLC); - (ii) Appellant's Statement of Issues and Designation of Items to be Included in the Record on Appeal [Docket No. 3520] (Appellant Pillsbury Winthrop Shaw Pittman LLP); - (iii) Appellant's Statement of Issues and Designation of Items to be Included in the Record on Appeal [Docket No. 3521] (Appellant G Club Operations LLC); - (iv) Appellant's Statement of Issues and Designation of Items to be Included in the Record on Appeal [Docket No. 3522] (Appellant FFP (BVI) Limited);

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 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).

- (v) Appellant's Designation of Items to be Included in the Record on Appeal and Statement of Issues [Docket No. 3523] (Appellant Apple Inc.); - (vi) Appellant's Designation of Items to be Included in the Record on Appeal and Statement of Issues [Docket No. 3518] (Appellant Meta Platforms, Inc.); - (vii) Appellant's Statement of Issues and Designation of Items to be Included in the Record on Appeal [Docket No. 3525] (Appellant Ogier).

Appellee respectfully counter-designates the following items for inclusion in the record on appeal, as to the each of the above-referenced Designations and respective Appeals, pursuant to Rule 8009(a)(2) of the Federal Rules of Bankruptcy Procedure. This designation includes all exhibits attached or referred to in the pleadings or matters of record.

2357 11/20/2023 Request for Status Conference 2362 11/21/2023 Order Granting Motion for Status Conference

2494 1/9/2024 Chapter 11 Trustee's Emergency Motion for Entry of Order, Pursuant to Bankruptcy Code Section 105(a) and Bankruptcy Rules 2002 and 9014, (I) Approving Form and Manner of Notice of Trustee's Forthcoming Tolling Motion

2495 1/9/2024 Motion of Chapter 11 Trustee to Expedite Hearing on Chapter 11 Trustee's Emergency Motion for Entry of Order, Pursuant to Bankruptcy Code Section 105(a) and Bankruptcy Rules 2002 and 9014, (I) Approving Form and Manner of Notice of Trustee's Forthcoming Tolling Motion

2496 1/10/2024 Order Scheduling Status Conference

2515 1/19/2024 Order Granting Chapter 11 Trustee's Emergency Motion for Entry of Order, Pursuant to Bankruptcy Code Section 105(a) and Bankruptcy Rules 2002 and 9014, (I) Approving Form and Manner of Notice of Trustee's Forthcoming Tolling Motion and (II) Scheduling Hearing

2837 2/14/2024 Order Granting Chapter 11 Trustee's Motion (I) Authorizing Sealed Filing of Proposed Stipulated Tolling Orders and (II)) Approving and Entering Proposed Stipulated Tolling

Proceedings and Obtain Other Relief Pending Disposition

behalf of Luc A. Despins, Chapter 11 Trustee. 3038 3/22/2024 Order Staying Adversary Proceedings and Granting Other

(RE: 2975). 3329 7/19/2024 Motion to Extend Time to Extend Deadline to File

Filed by Patrick R. Linsey on behalf of Luc A. Despins, Chapter 11 Trustee. 3332 7/22/2024 Notice of Hearing Issued on Appendix M Matter (RE:

First Supplemental Motion to Extend August 15, 2024 Deadline for Trustee to File Avoidance Actions filed by Chapter 11 Trustee Luc A. Despins).

8/13/2024 at 01:00 PM at the United States Bankruptcy

Bridgeport, CT. Objection deadline: 8/6/2024. Movant Replies due by 8/9/2024. Service to be made by the Movant on or before 7/23/2024 by 4:00 PM. Certificate of Service due by 7/25/2024.

Luc A. Despins Chapter 11 Trustee. (RE:

Extend Time filed by Chapter 11 Trustee Luc A. Despins,

Appendix M/N or AP).

3391 8/9/2024 Reply to (related document(s):

to Extend Deadline to File Avoidance Actions (First

Filed by Patrick R. Linsey on behalf of Luc A. Despins, Chapter 11 Trustee filed

Filed by Patrick R. Linsey on behalf of Luc A. Despins Chapter 11 Trustee. (RE:

Motion to Extend Time filed by Chapter 11 Trustee Luc A. Despins). 3395 8/12/2024 List of Witnesses and Exhibits

Trustee. (RE:

Motion to Extend Time filed by Chapter 11 Trustee Luc A. Despins). 3408 8/13/2024 Hearing Held. For the reasons stated on the record: (RE:

First Supplemental Motion to Extend August 15, 2024 Deadline for Trustee to File Avoidance Actions filed by

is under advisement.

Bankruptcy Code Section 363(b) for Entry of Order Authorizing Trustee to Fund Expenses of Mahwah Mansion and for Related Relief filed by Chapter 11 Trustee Luc A.

is granted. Revised proposed order will be submitted on or before 8/14/2024. 3446 8/21/2024 Transcript. Hearing held on August 13, 2024 Requested by Patrick Linsey Pursuant to the new policy adopted by the judicial conference, viewing of a transcript is restricted for 90 days from the file date. Transcripts will be available for viewing only at the clerk's office during the 90 day period or may be purchased from the court transcriber. For more information contact the Clerk's Office. The following deadlines apply: Redaction Request due By 09/11/2024. Redacted Transcript Submission due By 09/23/2024. Transcript access will be restricted through 11/19/2024.

Appellee, pursuant to Rule 8009(b)(3) of the Federal Rules of Bankruptcy Procedure, hereby certifies that he is not ordering any transcripts. All transcripts have been prepared and are either available on the docket or in the Bankruptcy Court Clerk's Office.

Appellee expressly reserves the right to (i) withdraw, supplement, amend or modify this Counter-Designation of Record on Appeal and (ii) move to strike any items included by the Appellants in Designations referenced above. This filing is made expressly subject to, and without waiver of any and all rights, remedies, challenges, and objections.

Dated: September 25, 2024 LUC A. DESPINS,

New Haven, Connecticut CHAPTER 11 TRUSTEE

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

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

The undersigned hereby certifies that on the 25th day of September 2024, a copy of the foregoing was filed electronically and emailed via the Court's CM/ECF electronic noticing system. Parties may access this filing through the Court's CM/ECF system.

Date: September 25, 2024 /s/ Patrick R. Linsey