Guo Wengui / Miles Guo — bankruptcy case · ECF #3635

METADATA

Defendant: Guo Wengui / Miles Guo / Ho Wan Kwok
Court: CTB
Case No.: 22-50073
ECF #: 3635
Type: UNKNOWN
Filed: 2024-10-03

FULL TEXT

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

In re: Chapter 11

HO WAN KWOK, et al.[,](#page-0-0)1

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Case No.: 22-50073 (JAM)

Debtors. (Jointly Administered)

### **MOTION FOR ADMISSION PRO HAC VICE OF MARC A. PERGAMENT**

Pursuant to Local Rule of Civil Procedures 83.1(d) of the United States District Court for the District of Connecticut, incorporated herein by Local Rule of Bankruptcy Procedure 1001-1, the undersigned, a member of the Bar of this Court and partner of the law firm Wilson Elser Moskowitz Edelman & Dicker, LLP, respectfully moves that the Court admit attorney Marc A. Pergament, a member of the Bar of the State of New York pro hac vice to represent MANHATTAN MOTORCARS, INC., in the above-captioned Chapter 11 bankruptcy case and in the related adversary proceeding, "*Luc Despins, Chapter 11 Trustee v. Manhattan Motorcars, Inc.,*" Adv. Pro. No. 24-05145, and in support represents the following:

1. The primary office of Attorney Marc A. Pergament is Weinberg, Gross, & Pergament LLP, 400 Garden City Plaza, Suite 309, Garden City, New York 11530. His telephone number is (516) 877-2424 ex:226, and his email address is [mpergament@wgplaw.com.](mailto:mpergament@wgplaw.com)

1 [T](#page-0-1)he 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).

2. Attorney Marc A. Pergament is a member in good standing in the state and jurisdiction set forth in his declaration, attached as **Exhibit** "**A**."

3. To the best of my knowledge and belief, Attorney Marc A. Pergament is a member in good standing of the courts listed in his declaration, has no pending disciplinary complaints as to which a finding has been made that such complaint should proceed to a hearing and has not been denied admission to, been disciplined by, resigned from, surrendered a license to practice before, or withdrawn an application for admission to practice while facing a disciplinary complaint before, this Court or any other court.

4. To the best of my knowledge and belief, Attorney Marc A. Pergament has reviewed and is familiar with the Federal Rules of Civil Procedure, the Local Rules of the United States District Court for the District of Connecticut, the Local Rules of the Bankruptcy Court for the District of Connecticut, and the Connecticut Rules of Professional Conduct.

5. Attorney Marc A. Pergament has submitted the filing fee of \$200.00 with this motion for pro hac vice admission.

6. Service of all papers directed to Manhattan Motorcars, Inc., may be made upon the undersigned, pursuant to Rule 83.1(e) of the Local Rules of Civil Procedure for the United States District Court for the District of Connecticut.

7. Attached as **Exhibit B** is a Proposed Order.

Dated: Stamford, Connecticut October 3, 2024

By: /s/ Matthew D. Valauri Matthew D. Valauri, Esq. (ct30193) WILSON ELSER MOSKOWITZ EDELMAN & DICKER, LLP 1010 Washington Boulevard, Suite 603 Stamford, Connecticut 06901 Tel. (203) 388-2433 [Matthew.Valauri@wilsonelser.com](mailto:Matthew.Valauri@wilsonelser.com) Our File No.: 26446.00001 *Local Counsel for Manhattan Motorcars, Inc.*

#### **CERTIFICATE OF SERVICE**

I hereby certify that on October 3, 2024, a copy of the foregoing was filed electronically and served by first class mail, postage prepaid and/or via email on anyone unable to accept electronic filing. Notice of the filing will be sent by e-mail to all parties by operation of the Court's electronic filing system or by First Class mail to anyone unable to accept electronic filing as indicated on the Notice of Electronic Filing. Parties may access this filing through the Court's CM/ECF System.

> By: /s/ Matthew D. Valauri Matthew D. Valauri, Esq.

## EXHIBIT A

Declaration of Marc A. Pergament, Esq.

## UNITED STATES BANKRUPTCY COURT DISTRICT OF CONNECTICUT BRIDGEPORT DIVISION

In re:

Chapter 11

HO WAN KWOK, et al., 1

Case No .: 22-50073 (JAM)

Debtors.

(Jointly Administered)

### DECLARATION OF MARC A. PERGAMENT IN SUPPORT OF MOTION FOR ADMISSION PRO HAC VICE

I, Marc A. Pergament, being of full age, having been duly sworn according to law, state the following:

1. I am a partner with the firm of Weinberg, Gross & Pergament LLP. My telephone number is (516) 877-2424 ex:226; and my e-mail address is mpergament(@wgplaw.com.

2. I submit this declaration in support of the motion for my admission pro hac vice as counsel for MANHATTAN MOTORCARS, INC., in the above-captioned Chapter 11 bankruptcy case and in the related adversary proceeding, "Luc Despins, Chapter 11 Trustee v. Manhattan Motorcars, Inc., " Adv. Pro. No. 24-05145.

3. standing of the Bar of the State of New York (Attorney Registration No. 1724137). In addition, I am a member in good standing with the (i) United States District Court for the Eastern District of New York, (ii) the United States District Court for the Southern District of New York, (iii) the

1 The Debtors in these chapter 1 1 cases are Ho Wan Kwok (also known as Guo Wengui, 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).

United States Bankruptcy Court for the Eastern District of New York, (iv) the United States Bankruptcy Court for the Southern District of New York, and the United States Court of Appeals for the Second Circuit.

4. such complaint should proceed to a hearing. I have not been denied admission to, been disciplined by, resigned from, surrendered my license to practice before, or withdrawn an application for admission to practice while facing a disciplinary complaint before this Court or any other court.

5. I have fully reviewed read and am familiar with the Federal Rules of Civil Procedure, the Local Rules of the United States District Court for the District of Connecticut, the Local Rules of the Bankruptcy Court for the District of Connecticut, and the Connecticut Rules of Professional Conduct, and will abide by and comply with the substantive and procedural requirements of the local rules and administrative orders of this Court.

6. No. ct30193) of Wilson Elser Moskowitz Edelman & Dicker, LLP, as my agent for service of process. Pursuant to D. Conn. L. Civ. 83.1(d), I designate the District of Connecticut as the forum for any resolution of any dispute arising out of my admission pro hac vice in the above-captioned Chapter 11 case and related cases.

7. Junderstand that upon admission under D. Conn. L. Civ. 83.1(d) I must promptly file a certificate of good standing from the court of the state in which I have my primary office. I acknowledge that the certificate shall be filed no later than 60 days after the date of admission and shall be dated no more than 60 days before the date of admission. I understand that failure to file such certificate will result in the automatic revocation of my visiting attorney status, absent an order of the Court. Furthermore, I understand that upon revocation of my visiting attorney status in one case, the Clerk of the Court shall examine the Court's Docket and revoke my visiting attorney status in all cases in which I have filed an appearance.

8. I will file my appearance with the Court after my admission has been approved.

Pursuant to 28 U.S.C. § 1746,1 declare under penalty of perjury that the foregoing is true and accurate,

This 30 day of September 2024.

Marc A. Pergament

Case 22-50073 Doc 3635 Filed 10/03/24 Entered 10/03/24 16:45:44 Page 9 of 10

### **EXHIBIT B**

Proposed Order Granting Admission Pro Hac Vice of Marc A. Pergament

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

In re: Chapter 11

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

Debtors. (Jointly Administered)

## **ORDER GRANTING ADMISSION PRO HAC VICE OF MARC A. PERGAMENT**

Upon consideration of the Motion of Matthew D. Valauri for Admission Pro Hac Vice of

Marc A. Pergament (the "Motion"), and any and all responses thereto, it is hereby:

**ORDERED** that the Motion is GRANTED and Marc A. Pergament is admitted pro hac vice, to practice in the U.S. District Court for the District of Connecticut in connection with the above related Bankruptcy Case and related adversary proceedings, including "*Luc Despins, Chapter 11 Trustee v. Manhattan Motorcars, Inc.,*" Adv. Pro. No. 24-05145.; and it is further

**ORDERED** that Matthew D. Valauri will receive service on behalf of Marc A. Pergament in accordance with D. Conn. L. Civ. R. 83.1(c), as incorporated by D. Conn. LBR 1001-1(b) and 9083-3.

Signed this \_\_\_ day of \_\_\_\_\_\_\_\_\_\_\_ 2024.

Hon. United States Bankruptcy Court Judge

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