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case_no: "22-50073"
doc_number: 3578
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# Guo Wengui / Miles Guo — bankruptcy case · ECF #3578



UNITED STATES BANKRUPTCY COURT DISTRICT OF CONNECTICUT BRIDGEPORT DIVISION

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In re:　:
:　Chapter 11

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

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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).
COUNTER-DESIGNATION OF RECORD ON APPEAL

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.

Docket No.　Date Filed　Description

2357　11/20/2023　Request for Status Conference
2362　11/21/2023　Order Granting Motion for Status Conference
2390　11/28/2023　Status Conference Held
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
and (II) Scheduling Hearing
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
and (II) Scheduling Hearing
2496　1/10/2024　Order Scheduling Status Conference
2497　1/10/2024　Status Conference Held
Docket Entries (No. 23-50073 (JAM))

Docket No.　Date Filed　Description

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
2803　2/12/2024　Notice of
Filing Second Revised Proposed Order
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
Orders
2975　3/4/2024　Motion To Stay
/ Trustee's Motion to Stay Adversary
Proceedings and Obtain Other Relief Pending Disposition
of Criminal Proceeding
Filed by Nicholas A. Bassett on
behalf of Luc A. Despins, Chapter 11 Trustee.
3038　3/22/2024　Order Staying Adversary Proceedings and Granting Other
Relief Pending Disposition of Criminal
Proceeding
(RE:
2975).
3329　7/19/2024　Motion to Extend Time to Extend Deadline to File
Avoidance
Actions
(First
Supplemental
Motion)
to
02/15/2025
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).
Hearing to be held on
8/13/2024 at 01:00 PM at the United States Bankruptcy
Court,

Lafayette
Blvd.,
Room
123,
Courtroom,
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.
3351　7/25/2024　Certificate of Service
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,

Notice of Hearing -
Appendix M/N or AP).

Docket No.　Date Filed　Description

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

Motion to Extend Time
to Extend Deadline to File Avoidance Actions (First
Supplemental Motion) to 02/15/2025
Filed by Patrick R.
Linsey on behalf of Luc A. Despins, Chapter 11 Trustee filed
by Chapter 11 Trustee Luc A. Despins)
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
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).
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
Chapter 11 Trustee Luc A. Despins)
is under advisement.
(RE:3381
Amended
Emergency
Motion
Pursuant
to
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.
Despins)
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.
CERTIFICATION REGARDING TRANSCRIPTS

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.
RESERVATION OF RIGHTS

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.

Respectfully submitted,

Dated: September 25, 2024 LUC A. DESPINS,

New Haven, Connecticut CHAPTER 11 TRUSTEE

By: /s/ Patrick R. Linsey

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

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

Patrick R. Linsey (ct29437)