Guo Wengui / Miles Guo — bankruptcy case · ORDER · ECF #3694

UNITED STATES BANKRUPTCY COURT DISTRICT OF CONNECTICUT BRIDGEPORT DIVISION

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In re: :

HO WAN KWOK, et al., : :

Debtors.1 :

------------------------------------------------------ x COVERSHEET FOR THIRD INTERIM FEE APPLICATION OF KROLL, LLC

Application Period: May 1, 2024 through August 31, 2024 Bankruptcy Petition Filed: February 15, 2022 Date of Entry of Retention Order: September 29, 2023 [ECF No. 2241] (effective as of August 2, 2023).

Fees: \$308,421.30 Voluntary Fee Reductions: none Expenses: \$75,674.59 Voluntary Expenses Reductions: none

Fees Previously Requested: Retainer Request:

Expenses Previously Requested: Expense Detail: Requested Expenses: \$110,126.98 Retainer Received: Not applicable Awarded Expenses: \$109,976.78 Copies per page cost & total: Not applicable

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).

2 As detailed below, with respect to the Application Period, an additional \$171,531.20 in fees and \$55,720.53 in expenses were paid in accordance with the Interim Compensation Order (as defined below) and Kroll's monthly fee statements.

Monthly Total Fees Requested Requested Fees Paid Expenses 20% Fee

Period (100%) Fees (80%) Expenses Paid Holdback

5/1/24 - \$90,707.00 \$72,565.60 \$23,655.61 \$72,565.60 \$23,655.61 \$18,141.40

6/1/24 - \$35,201.00 \$28,160.80 \$126.88 \$28,160.80 \$126.88 \$7,040.20

7/1/24 - \$88,506.00 \$70,804.80 \$31,938.04 \$70,804.80 \$31,938.04 \$17,701.20

8/1/24 - \$94,007.30 \$75,205.84 \$19,954.063 -- -- \$19,518.92

TOTAL \$308,421.30 \$246,737.04 \$75,674.59 \$171,531.20 \$55,720.53 \$61,684.26 MONTHLY FEE REQUESTS FOR APPLICATION PERIOD

3 Pursuant to the order granting the Second Interim Fee Application, Kroll applied a credit of \$150.20 to the expenses in the August Fee Statement. UNITED STATES BANKRUPTCY COURT DISTRICT OF CONNECTICUT BRIDGEPORT DIVISION

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In re: :

HO WAN KWOK, et al., :

Debtors.1 : :

------------------------------------------------------ x THIRD INTERIM FEE APPLICATION OF KROLL, LLC, AS FORENSIC INVESTIGATORS, FOR COMPENSATION AND REIMBURSEMENT OF EXPENSES FOR PERIOD FROM MAY 1, 2024 THROUGH AUGUST 31, 2024

Pursuant to sections 105(a), 328, 330, and 331 of title 11 of the United States Code (such title, hereinafter, the "Bankruptcy Code"), Rule 2016 of the Federal Rules of Bankruptcy Procedure (the "Bankruptcy Rules"), Rule 2016-1 of the Local Rules of Bankruptcy Practice and Procedure of the United States Bankruptcy Court for the District of Connecticut (the "Local Rules"), and the *Order Establishing Procedures for Interim Compensation and Reimbursement of Expenses for Retained Professionals, dated August 18, 2023* [Docket No. 2094] (the "Interim Compensation Procedures Order"), Kroll, LLC ("Kroll"), as forensic investigators to 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"), hereby files this *Third Interim Application of Kroll, LLC, as Forensic Investigators, for Compensation and Reimbursement of Expenses for the Period from May 1, 2024 through August 31, 2024* (the "Application"). By this Application, Kroll requests

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).

interim allowance of professional fees incurred during the period from May 1, 2024 through and including August 31, 2024 (the "Application Period") in these chapter 11 cases. In support of this Application, Kroll respectfully states as follows: JURISDICTION, VENUE, BASES FOR RELIEF, AND COMPLIANCE

1. The Court has jurisdiction over this matter pursuant to 28 U.S.C. §§ 157 and 1334 and the Standing Order of Reference from the United States District Court for the District of Connecticut. This matter is a core proceeding within the meaning of 28 U.S.C. § 157(b)(2). Venue is proper pursuant to 28 U.S.C. §§ 1408 and 1409.

2. The legal predicates for the relief requested herein are sections 328, 330, and 331 of the Bankruptcy Code, Bankruptcy Rule 2016, and Local Rule 2016-1.

3. Kroll believes that this Application, together with the attachments hereto,

substantially complies with the Bankruptcy Rules, Local Rule 2016-1, and the United States

Trustee's Guidelines for Reviewing Applications for Compensation and Reimbursement of

Expenses Filed Under 11 U.S.C. § 330 by Attorneys in Larger Chapter 11 Cases (the "U.S.

Trustee Guidelines").2 Kroll respectfully requests a waiver of any of the foregoing requirements not met by this Application.

- 4. Attached and incorporated herein by reference are the following Exhibits: - Exhibit A contains the Proposed Order granting this Application. - Exhibit B is a timekeeper summary that includes the name, title, hourly billing rate, aggregate hours, and amount of fees earned for each Kroll individual who provided services during the Application Period; - Exhibit C is a summary of expenses incurred and reimbursement sought, by expense type, during the Application Period; and

2 Kroll reserves all rights as to the relevance and substantive legal effect of the U.S. Trustee Guidelines with respect to any application for compensation in these chapter 11 cases.

Exhibit D contains the detail of the fees incurred during the Application Period.

5. On February 15, 2022 (the "Petition Date"), the Individual Debtor filed a voluntary petition for relief under the Bankruptcy Code in the United States Bankruptcy Court for the District of Connecticut (Bridgeport Division) (the "Court").

6. On March 21, 2022, the United States Trustee appointed an Official Committee of Unsecured Creditors (the "Committee") in the Individual Debtor's chapter 11 case. No examiner has been appointed in the Individual Debtor's chapter 11 case.

7. On June 15, 2022, the Court entered a memorandum of decision and order [ECF No. 465] (the "Trustee Order") directing the United States Trustee to appoint a chapter 11 trustee in the Individual Debtor's chapter 11 case.

8. Pursuant to the Trustee Order, the United States Trustee selected Luc A. Despins as the Trustee. On July 8, 2022, the Court entered an order granting the appointment of Luc A. Despins as the Trustee in the Individual Debtor's chapter 11 case.

9. By order entered September 29, 2023, the Court authorized Kroll' retention as forensic investigators for the Trustee [ECF No. 2241] (the "Retention Order") effective as of August 2, 2023 in the Debtor's chapter 11 case. The Retention Order authorizes Kroll to be compensated on an hourly basis and reimbursed for actual and necessary out-of-pocket expenses pursuant to sections 328 and 330 of the Bankruptcy Code, the Bankruptcy Rules, the Local Rules, and such orders as the Court may direct.

10. On February 16, 2024, Kroll filed its *First Interim Fee Application of Kroll, LLC, as Forensic Investigators, for Compensation and Reimbursement of Expenses for Period From August 2, 2023 Through December 31, 2024* [Docket No. 2929] (the "First Interim Fee Application"), requesting interim allowance of professional fees incurred during the period from August 2, 2023 through and including December 31, 2023 in these chapter 11 cases. On March 20, 2024, the Court granted the First Interim Fee Application.

11. On June 24, 2024, Kroll filed its *Second Interim Fee Application of Kroll, LLC, as Forensic Investigators, for Compensation and Reimbursement of Expenses for Period From January 1, 2024 Through April 30, 2024* [Docket No. 3276] (the "Second Interim Fee Application"), requesting interim allowance of professional fees incurred during the period from January 1, 2024 through and including April 30, 2024 in these chapter 11 cases. On July 26, 2024, the Court granted the Second Interim Fee Application. III. Monthly Fee Statements During Application Period

12. On August 18, 2023, the Court entered the Interim Compensation Procedures Order, which, among other things, approves procedures for the payment of 80% of fees and 100% of expenses on a monthly basis.

13. In accordance with the Interim Compensation Procedures Order, on June 21, 2024, Kroll filed and served its monthly fee statement [Docket No. 3271] (the "May Fee Statement") requesting payment of 80% of all fees and 100% of all expenses actually and necessarily incurred for services rendered during the period from May 1, 2024 through May 31, 2024, in the amounts of \$72,565.60 (80% of \$90,707.00) and \$23,655.61, respectively. No

objections were filed in response to the May Fee Statement. On July 19, 2024, the estates paid Kroll \$96,221.21.

14. On July 23, 2024, Kroll filed and served its monthly fee statement [Docket No. 3347] (the "June Fee Statement") requesting payment of 80% of all fees and 100% of all expenses actually and necessarily incurred for services rendered during the period from June 1, 2024 through June 30, 2024, in the amounts of \$28,160.80 (80% of \$35,201.00) and \$126.88, respectively. No objections were filed in response to the June Fee Statement. On October 3, 2024, the estates paid Kroll \$28,287.68.

15. On August 26, 2024, Kroll filed and served its monthly fee statement [Docket No. 3455] (the "July Fee Statement") requesting payment of 80% of all fees and 100% of all expenses actually and necessarily incurred for services rendered during the period from July 1, 2024 through July 31, 2024, in the amounts of \$70,804.80 (80% of \$88,506.00) and \$31,938.04, respectively. No objections were filed in response to the June Fee Statement. On October 3, 2024, the estates paid Kroll \$102,742.84.

16. On September 26, 2024, Kroll filed and served its monthly fee statement [Docket No. 3584] (as corrected on October 11, 2024 [Docket No. 3678], the "August Fee Statement") requesting payment of 80% of all fees and 100% of all expenses actually and necessarily incurred for services rendered during the period from August 1, 2024 through August 31, 2024, in the amounts of \$75,205.84 (80% of \$94,007.30) and \$19,803.86,3 respectively. The deadline to object to the August Fee Statement expires on October 17, 2024. Accordingly, at this time, the estates have not yet paid Kroll on account of the August Fee Statement.

3 Pursuant to the order granting the Second Interim Fee Application, the foregoing amount is net of a credit of \$150.20.

17. The Applicant is applying for compensation pursuant to Sections 330 and 331 of the Bankruptcy Code for forensic investigation services performed for the Trustee during the Application Period.

18. For the Application Period, the Applicant seeks allowance of \$308,421.30 as compensation for services rendered and allowance and reimbursement of \$75,674.59 in expenses incurred in connection with such services. The Applicant devoted 691.9 hours to this case during the Application Period, equating to an overall blended rate of \$445.76/hour.

19. As noted, Kroll has already received payment of \$227,251.73 of the fees incurred during the Application Period and \$55,720.53 of the expenses incurred during the Application Period, such that Kroll is only seeking payment of (a) 80% of the fees and 100% of the expenses incurred in August 2024, i.e., \$95,009.70,4 and (b) the remaining 20% of its fees incurred during the Application Period, namely \$61,684.26.

20. Throughout the Application Period, the Applicant maintained records to indicate the name of each professional working on this matter, the time spent on a particular issue, and the nature of the work performed. These records, which describe in detail the services rendered by the Applicant, were created at the approximate time the services were performed.

21. Annexed hereto and made a part hereof as Exhibit D is a detailed billing report, upon which this application is based that contains each individual professional's time for the Debtors' bankruptcy proceedings, itemizing the dates upon which services were rendered,

4 For the avoidance of doubt, the estate will pay this amount upon the expiration of the October 17, 2024 objection deadline with respect to the August Fee Statement, provided no objections are filed with respect to that fee statement, in accordance with the Interim Compensation Procedures Order.

including a summary of the services on each of such dates by each person rendering the service, the time spent in rendering such service, and the dollar value of such services.

22. Since being formally retained, Kroll has assisted in investigating and analyzing the Debtor's finances and assets, and assisted the Trustee in aspects of his investigation and in the recovery of assets, including, among other things, the existing adversary proceedings, the avoidance actions filed against transferees, and the civil RICO complaints filed against individuals and organizations affiliated with the Debtor. Of particular note, as a result of Kroll's analysis, the Trustee has been able to file approximately 300 avoidance actions seeking to avoid fraudulent transfers and postpetition transfers. The work undertaken by Kroll during the Fee Application Period may also support actions that the Trustee may bring in the future.

23. During the Application Period, Kroll has continued to review and analyze thousands of bank account statement and other financial documents belonging to the Debtor and individuals and entities affiliated with or controlled by the Debtor. Using that information, Kroll has been tracing the flow of funds from the Debtor's fraudulent activities through the web of organizations and affiliates of the Debtor, to help understand how the Debtor used the proceeds of his fraudulent activities to fund his, his family's and his affiliates exorbitant lifestyles, to further help the Trustee recover assets belonging to the Debtor's estate. Kroll's analyses directly supported close to 50 avoidance actions filed by the Trustee during the Application Period, as well as ongoing adversary proceedings.

24. Kroll has also performed significant and detailed investigations of dozens of individuals and entities affiliated with the Debtor to understand the background of those parties,

how they were formed, how they are funded, and what specific role they play in the Debtor's fraudulent schemes.

25. Furthermore, Kroll regularly meets with the Trustee and his legal counsel to keep them abreast of its findings, and to keep up to speed on other developments within the Trustee's investigations.

26. The work undertaken by Kroll to date has been significant, involving forensic investigations, analysis of billions of dollars in financial transactions, and strategic input on potential actions to recover assets for the benefit of the estate. This work remains ongoing, with additional forensic investigatory work expected in due course.

27. No prior application for the relief requested has been made. However, as noted, certain fees and expenses incurred during the Application Period were previously paid in accordance with the Interim Compensation Procedures Order.

28. All of the professional services for which this award is being sought hereby were rendered solely on behalf of the Trustee in connection with the chapter 11 cases herein.

29. Applicant respectfully submits that its services have benefited the Trustee with the expertise and skill required in forensic investigations. The services for which such compensation is requested were performed for and on behalf of the Trustee. Such services have been necessary to protect and enforce the rights and interests of the Trustee in connection with these chapter 11 cases. The reasonable value of services rendered by Kroll in these cases is based upon Kroll' usual hourly rates for matters of this nature (discounted by 10% - 25% for all professionals).

30. Section 330 of the Bankruptcy Code prescribes the general standards for determining the amount of compensation to be paid to professionals. The Applicant submits that the amount sought for the Application Period represents reasonable compensation for professional services rendered based upon the time spent, the nature, the extent, and the value of such services, taking into account the cost of comparable services in a non-bankruptcy case.

31. Section 331 of the Bankruptcy Code provides for interim compensation of professionals and incorporates the substantive standards of section 330 of the Bankruptcy Code to govern the Court's award of such compensation. Section 330(a) of the Bankruptcy Code provides that, after notice and a hearing, the Court may award a professional employed under 11 U.S.C. § 327 "reasonable compensation for actual, necessary services rendered" and "reimbursement for actual, necessary expenses." 11 U.S.C. § 330(a)(1).5

32. In determining the amount of "reasonable compensation," the Court must consider the nature, extent, and value of the services, taking into account all the relevant factors, including the time spent on such services, the rates charged for such services, whether the services were necessary and beneficial, whether the services were performed in a reasonable amount of time commensurate with the complexity, importance, and nature of the problem, issue, or task addressed, and whether the compensation is reasonable based on the customary compensation charged by comparably skilled practitioners in cases other than cases under the Bankruptcy Code. See 11 U.S.C. § 330(a)(3). The Court enjoys "considerable discretion in determining reasonable fee awards." In re Ahead Communication Systems, Inc., 395 B.R. 512 (D. Conn. 2008).

5 Under section 328(a) of the Bankruptcy Code, with bankruptcy court approval, a trustee may employ professional persons under section 327(a) of the Bankruptcy Code "on any reasonable terms and conditions of employment, including on a retainer, on an hourly basis, on a fixed or percentage fee basis, or on a contingent fee basis." 11 U.S.C. § 328(a).

33. In assessing the "reasonableness" of the fees requested, the Second Circuit has stated that courts should consider the factors enumerated in Johnson v. Ga. Highway Express, Inc., 6 while also incorporating the "lodestar method." See Arbor Hill Concerned Citizens Neighborhood Ass'n v. County of Albany and Albany County Bd. of Elections, 522 F.3d 182, 190 (2d Cir. 2007) (citing Johnson v. Ga. Highway Express, Inc., 488 F.2d 714 (5th Cir.1974), abrogated on other grounds by Blanchard v. Bergeron, 489 U.S. 87, 92–93, 96 (1989)). The "lodestar method" of calculating the reasonable fee contemplates "the number of hours reasonably expended . . . multiplied by a reasonable hourly rate." See Hensley v. Eckerhart, 461 U.S. 424, 433 (1983); Gisbrecht v. Barnhart, 535 U.S. 789, 801 (2002); Perdue v. Kenny A., 130 S.Ct. 1662, 1672 (2010); In re Drexel Burnham Lambert Grp., Inc., 133 B.R. 13 (Bankr. S.D.N.Y. 1991). The factors set forth in Johnson and In re First Colonial Corp. of Am., 544 F.2d 1291, 1298–99 (5th Cir. 1977) have been adopted by most courts.7 See In re Nine Assocs., Inc., 76 B.R. 943, 945 (S.D.N.Y. 1987) (adopting First Colonial/Johnson analysis); In re Cuisine Magazine, Inc., 61 B.R. 210, 212–13 (Bankr. S.D.N.Y 1986) (same); Green v. City of New York, 403 F. Appx. 626, 629 (2d Cir. 2010) (summary order); see generally 3 COLLIER ON BANKRUPTCY ¶ 330.03[9] (Lawrence P. King ed., 16th ed. 2016) (describing First Colonial

6 The twelve Johnson factors are (1) the time and labor required, (2) the novelty and difficulty of the questions, (3) the skill requisite to perform the legal service properly, (4) the preclusion of other employment by the attorney due to acceptance of the case, (5) the customary fee, (6) whether the fee is fixed or contingent, (7) the time limitations imposed by the client or the circumstances, (8) the amount involved and the results obtained, (9) the experience, reputation, and ability of the attorneys, (10) the "undesirability" of the case, (11) the nature and length of the professional relationship with the client, and (12) awards in similar cases. Johnson, 488 F.2d at 717-19.

7 The factors articulated in First Colonial were first articulated by the Fifth Circuit in Johnson, with the First Colonial court adding the factor of the "spirit of economy," which was later rejected by Congress. See Stroock & Stroock & Lavan v. Hillsborough Holdings Corp. (In re Hillsborough Holdings Corp.), 127 F.3d 1398, 1403 (11th Cir. 1997).

and Johnson as the "leading cases with regard to the factors to be considered in determining a reasonable allowance of compensation").

34. In accordance with the factors enumerated in section 330 of the Bankruptcy Code and applicable case law, the amount requested herein by Kroll is fair and reasonable.

29. No agreement or understanding exists between Kroll and any other person for the sharing of compensation received or to be received for services rendered in or in connection with this matter. Kroll will not, in any form or guise, share or agree to share compensation for services with any person, nor will Kroll share in the compensation for any other person rendering service in these cases, except as so provided by Section 504(b) of the Bankruptcy Code and Rule 2016 of the Bankruptcy Rules.

30. To the extent that time or disbursement charges for services rendered or expenses incurred during the Application Period are not included in this Application, or Kroll has for any reason not sought compensation or reimbursement with respect to such services, Kroll reserves the right to request compensation and reimbursement for such services in a supplemental or future application in these chapter 11 cases. Also, Kroll does not waive, and expressly reserves, its right to respond to any objections regarding this Application and the amounts sought for services rendered and expenses incurred.

31. No previous request for the relief sought herein has been made to this Court or any other court.

[THE REMAINDER OF THIS PAGE IS INTENTIONALLY BLANK.]

WHEREFORE, Kroll respectfully requests entry of an order, substantially in the form attached hereto, (i) allowing interim compensation for professional services rendered during the Application Period in the amount of \$308,421.30 and reimbursement of \$75,674.59 in expenses, (ii) authorizing and directing prompt payment of the unpaid fees from the estates, to the extent not already paid, (iii) allowing such compensation and payment for professional services rendered without prejudice to Kroll's right to seek further compensation and/or payment from the estates for the full value of services performed and expenses incurred, and (iv) granting Kroll such other and further relief as is just.

Dated: October 15, 2024 New York, New York

Allen Pfeiffer KROLL, LLC 55 East 52nd Street, Floor 17 New York, New York 10055

Forensic Investigators to Luc A. Despins, Chapter 11 Trustee IN THE UNITED STATES BANKRUPTCY COURT FOR THE DISTRICT OF CONNECTICUT BRIDGEPORT DIVISION

In re:

The undersigned hereby certifies that on the date hereof, the *Third Interim Application of Kroll, LLC, as forensic investigators, for Compensation and Reimbursement of Expenses for the Period from May 1, 2024 through August 31, 2024* (the "Application")2 was electronically filed. Notice of this filing was sent by e-mail to all parties to the above-captioned chapter 11 cases by operation of the Court's electronic filing ("CM/ECF") system or by mail to anyone unable to accept electronic filing as indicated on the Notice of Electronic Filing.3 In addition, to the extent not covered by the foregoing, copies of the Application were served on the twenty (20) largest creditors in the Debtors' chapter 11 cases. Parties may access this filing through the Court's CM/ECF system.

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).

2 Capitalized terms used but not defined in this Certification shall have the meanings ascribed to them in the Application.

3 To the extent that the foregoing was filed outside regular business hours, service by mail on recipients unable or not qualified to accept electronic notice was made on the next business day.

Dated: October 15, 2024 New York, New York By: /s/ G. Alexander Bongartz

G. Alexander Bongartz (pro hac vice) Douglass Barron (pro hac vice) PAUL HASTINGS LLP 200 Park Avenue New York, New York 10166 (212) 318-6000 douglassbarron@paulhastings.com

Case 22-50073 Doc 3694 Filed 10/15/24 Entered 10/15/24 18:12:43 Page 17 of 74

UNITED STATES BANKRUPTCY COURT DISTRICT OF CONNECTICUT BRIDGEPORT DIVISION

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In re: : :

HO WAN KWOK, et al., : :

Debtors.1 : :

[PROPOSED] ORDER GRANTING THIRD INTERIM FEE APPLICATION OF KROLL, LLC, AS FORENSIC INVESTIGATORS, FOR COMPENSATION AND REIMBURSEMENT OF EXPENSES FOR PERIOD FROM MAY 1, 2024 THROUGH AUGUST 31, 2024

Upon consideration of the Application (the "Application") of Kroll, LLC ("Kroll") as

forensic investigators to the Trustee2 for interim allowance of compensation and reimbursement

of expenses from May 1, 2024 through August 31, 2024; and sufficient notice having been

given; and a hearing having been held on \_\_\_\_\_\_\_\_, 2024 and due consideration having been

given to any responses thereto; and sufficient cause having been shown therefor, it is hereby:

1. ORDERED that the Application is granted and compensation in the amount of

\$308,421.30 and reimbursement of expenses in the amount of \$75,674.59 are awarded to Kroll,

subject to final adjustment and disgorgement in the event all administrative expenses are not paid

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).

2 Capitalized terms not otherwise defined herein adopt the definitions set forth in the Application.

2. ORDERED that nothing herein modified the Retention Order; it is further

3. ORDERED that the estates are authorized and directed to pay Kroll's fees in the amount of \$61,684.26, i.e., 20% of the fees allowed in paragraph 1 above, within fourteen days of the date of this Order; it is further

4. ORDERED that this Court shall retain jurisdiction to hear and determine all matters arising from the implementation of this Order; it is further

5. ORDERED that the Debtors' estates and Kroll are authorized and empowered to take all necessary actions to implement the relief granted in this Order; it is further

6. ORDERED that notwithstanding the possible applicability of Bankruptcy Rules 6006(d), 7062, 9014, or otherwise, the terms and conditions of this Order shall be immediately effective and enforceable upon its entry; and it is further

7. ORDERED that all time periods set forth in this Order shall be calculated in accordance with Bankruptcy Rule 9006(a).

Case 22-50073 Doc 3694 Filed 10/15/24 Entered 10/15/24 18:12:43 Page 20 of 74

Time Period: May 1 - August 31, 2024.

Parizek, Pam Managing Director \$ 712 8.60 6,123.20 Parizek, Pam Managing Director \$ 680 31.10 21,148.00 Barker, James Associate Managing Director \$ 675 7.60 5,130.00 Barker, James Associate Managing Director \$ 639 7.30 4,664.70 Lazarus, Jordan Senior Manager \$ 518 41.20 21,321.00 Lazarus, Jordan Senior Manager \$ 495 78.00 38,610.00 Lomas, Adam Senior Manager \$ 518 95.50 49,421.25 Lomas, Adam Senior Manager \$ 495 211.50 104,692.50 Dominguez, Sunni Senior Manager \$ 495 5.00 2,475.00 Ling, Bryant Associate Managing Director \$ 495 16.60 8,217.00 Downie, Scott Managing Director \$ 495 7.10 3,514.50 Scodeller, Bradley Associate \$ 315 28.00 8,820.00 Leonard, Justin Manager \$ 297 3.00 891.00 Levenson, Patrick Associate Manager \$ 378 10.20 3,855.60 Levenson, Patrick Analyst \$ 231 16.00 3,696.00 Dharamshi, Salim Analyst \$ 221 6.10 1,345.05 Bottos, Madison Research Analyst \$ 221 20.90 4,608.45 Bottos, Madison Research Analyst \$ 200 69.40 13,880.00 Welby, Jackie Research Analyst \$ 221 12.10 2,668.05 Welby, Jackie Research Analyst \$ 200 16.70 3,340.00 Total Hours and Fees: 691.9 \$ 308,421.30

[1] Kroll's annual rate increase effective January 1, 2024 was deferred to August 1, 2024 per agreement with the bankruptcy Trustee.

Time Period: May 1 - August 31, 2024.

Media Preservation/Replication for May 22,800.00

Valid8 Data Usage Charges for July 6,185.40

Media Preservation/Replication for August 12,400.00 Database and Research Fees for August 684.98

Case 22-50073 Doc 3694 Filed 10/15/24 Entered 10/15/24 18:12:43 Page 24 of 74

Time Period: May 1-31, 2024. Timekeeper Date Matter Task Narrative Hours Rate Amount

and Recovery Review update regarding 0.2 680\$ \$

and Litigation document production [.1]; email Paul

and Recovery Review communications regarding

and Recovery Review A. Lomas analysis regarding

Lazarus, Jordan 05/09/2024 Asset Recovery

and Recovery Call with B. Scodeller regarding

Lazarus, Jordan 05/09/2024 Asset Recovery

and Recovery Correspondence with Paul Hastings [D.

Lazarus, Jordan 05/09/2024 Asset Recovery

NPM Law and Paul Hastings. 3.3 495\$ \$

and Recovery Prepare agenda [.1] and attend weekly

Hastings [L. Despins, N. Bassett, D. Barron, L. Song] and NPM Law [P.

and Recovery Review A. Lomas analysis regarding

Scodeller, Bradley 05/09/2024 Asset Recovery

and Recovery Call with J. Lazarus regarding working paper and subsequent analysis. 0.4 315\$ \$

and Recovery Weekly call with P. Parizek, A. Lomas, J. Lazarus, Paul Hastings (L. Despins, L.

Law (P. Linsey) re: analysis of 0.8 675\$ \$

Lazarus, Jordan 05/13/2024 Asset Recovery

and Recovery Call with A. Lomas regarding analysis of transferee vendor classifications. 0.2 495\$ \$

Timekeeper Date Matter Task Narrative Hours Rate Amount

Lazarus, Jordan 05/13/2024 Asset Recovery

and Recovery Review of transferee vendor

and Recovery Call with J. Lazarus regarding analysis of transferee vendor classifications. 0.2 \$ 495 \$

Lazarus, Jordan 05/20/2024 Asset Recovery

and Recovery Correspondence with A. Lomas, Paul

Lazarus, Jordan 05/21/2024 Asset Recovery

and Recovery Correspondence with A. Lomas, P.

files and related matters. 0.3 \$ 495 \$

Lazarus, Jordan 05/21/2024 Asset Recovery

and Recovery Compile, restore, and analyze

and Recovery Instructions to M. Bottos for review of

Lazarus, Jordan 05/22/2024 Asset Recovery

and Recovery Correspondence with A. Lomas, P.

files and related matters. 0.2 \$ 495 \$

Lazarus, Jordan 05/22/2024 Asset Recovery

and Recovery Compile, restore, and analyze

and Recovery Further instructions to M. Bottos for

Lazarus, Jordan 05/23/2024 Asset Recovery

and Recovery Call with P. Parizek, A. Lomas, J. Barker, Paul Hastings [L. Despins, L.

Lazarus, Jordan 05/23/2024 Asset Recovery

and Recovery Correspondence with NPM Law regarding document production from 0.2 \$ 495 \$

and Recovery Prep for [0.1] and attend call with A.

Hastings [L. Despins, L. Song, D. Barron, N. Basset], NPM Law [P.

Timekeeper Date Matter Task Narrative Hours Rate Amount

to Paul Hastings. 0.3 \$ 680 \$ 204.00

and Recovery Call with P. Parizek, A. Lomas, J. Lazarus, Paul Hastings [L. Despins, L.

[P. Linsey] to discuss 0.6 \$ 675 \$ 405.00 Lazarus, Jordan 05/24/2024 Asset Recovery

and Recovery Correspondence with A. Lomas, NPM

Lazarus, Jordan 05/24/2024 Asset Recovery

and Recovery Correspondence with B. Scodeller

document production and related matters. 0.4 \$ 495 \$ 198.00 Lazarus, Jordan 05/24/2024 Asset Recovery

Scodeller, Bradley 05/24/2024 Asset Recovery

and Recovery Discussions with J. Lazarus regarding

Scodeller, Bradley 05/24/2024 Asset Recovery

Scodeller, Bradley 05/27/2024 Asset Recovery

and Recovery payment production analysis. 6.5 \$ 315 \$ 2,047.50 Bottos, Madison 05/28/2024 Asset Recovery

and Recovery Call with J. Lazarus, B. Scodeller to

corresponding analysis 0.4 \$ 200 \$ 80.00 Lazarus, Jordan 05/28/2024 Asset Recovery

and Recovery Call with B. Scodeller, M. Bottos to

corresponding analysis 0.4 \$ 495 \$ 198.00 Lazarus, Jordan 05/28/2024 Asset Recovery

document production. 1.7 \$ 495 \$ 841.50 Scodeller, Bradley 05/28/2024 Asset Recovery

and Recovery Call with J. Lazarus, M. Bottos to

corresponding analysis 0.4 \$ 315 \$ 126.00 Scodeller, Bradley 05/28/2024 Asset Recovery

and Recovery payment production analysis. 7.3 \$ 315 \$ 2,299.50

Timekeeper Date Matter Task Narrative Hours Rate Amount

Lazarus, Jordan 05/29/2024 Asset Recovery

and Recovery Correspondence with A. Lomas, NPM

Lazarus, Jordan 05/29/2024 Asset Recovery

and Recovery Call with B. Scodeller regarding analysis

Lazarus, Jordan 05/29/2024 Asset Recovery

transactions for follow-up [.1] 0.1 \$ 680 \$

Scodeller, Bradley 05/29/2024 Asset Recovery

and Recovery Call with J. Lazarus regarding analysis of

Scodeller, Bradley 05/29/2024 Asset Recovery

Lazarus, Jordan 05/30/2024 Asset Recovery

Scodeller, Bradley 05/30/2024 Asset Recovery

and Recovery payment production analysis. 4.3 \$ 315 \$

Bottos, Madison 05/01/2024 Asset Recovery

Action Analysis Meeting with J. Lazarus regarding

Bottos, Madison 05/01/2024 Asset Recovery

Action Analysis Analysis of data points for inclusion in

Lazarus, Jordan 05/01/2024 Asset Recovery

Action Analysis Meeting with M. Bottos regarding

Lazarus, Jordan 05/01/2024 Asset Recovery

Action Analysis Analysis of data points for update to

Bottos, Madison 05/02/2024 Asset Recovery

Action Analysis Analysis of data points for inclusion in

Lazarus, Jordan 05/02/2024 Asset Recovery

Action Analysis Analysis of data points for update to

Timekeeper Date Matter Task Narrative Hours Rate Amount

Action Analysis Respond to inquiry from NPM Law [P.

Bottos, Madison 05/06/2024 Asset Recovery

Action Analysis Call with J. Lazarus, A. Lomas regarding

Bottos, Madison 05/06/2024 Asset Recovery

Action Analysis Download and organize bank document

Lazarus, Jordan 05/06/2024 Asset Recovery

Action Analysis Call with A. Lomas, M. Bottos regarding

Lazarus, Jordan 05/06/2024 Asset Recovery

Action Analysis Call with R. Hamersly regarding updates

Action Analysis Call with J. Lazarus, M. Bottos regarding

Action Analysis Scope transfers underlying

Bottos, Madison 05/07/2024 Asset Recovery

Action Analysis Continue to download and organize bank

Bottos, Madison 05/08/2024 Asset Recovery

Action Analysis Continue to download and organize bank

Lazarus, Jordan 05/08/2024 Asset Recovery

Action Analysis Call with R. Hamersly regarding updates

Lazarus, Jordan 05/08/2024 Asset Recovery

Action Analysis Correspondence with Paul Hastings and

Lazarus, Jordan 05/08/2024 Asset Recovery

Timekeeper Date Matter Task Narrative Hours Rate Amount

Bottos, Madison 05/09/2024 Asset Recovery

Action Analysis Continue to download and organize bank

and Litigation transfers. Lazarus, Jordan 05/09/2024 Asset Recovery

Action Analysis Correspondence with Paul Hastings and

Lazarus, Jordan 05/14/2024 Asset Recovery

Action Analysis Correspondence with A. Lomas and

documentation and related matters. 0.3 \$ 495 \$

Lazarus, Jordan 05/14/2024 Asset Recovery

with new transferee data. 0.7 \$ 495 \$

Action Analysis Respond to inquiries from D. Skalka and

in underlying bank data. 0.6 \$ 495 \$

Action Analysis Prepare summary schedule of

Lazarus, Jordan 05/15/2024 Asset Recovery

Action Analysis Call with R. Hamersly regarding updates

Action Analysis Review compiled documents supporting

transfer listing/mapping Excel file. 2.9 \$ 495 \$

Action Analysis Review compiled documents supporting

and supporting transfer documents. 3.7 \$ 495 \$

Action Analysis Review compiled documents supporting

transfer listing/mapping Excel file. 1.4 \$ 495 \$

Action Analysis Call with NPM Law [P. Linsey]

and supporting documents for 0.3 \$ 495 \$

Lazarus, Jordan 05/20/2024 Asset Recovery

Action Analysis Correspondence with A. Lomas, NPM

Action Analysis Review A. Lomas analysis regarding 0.5 \$ 680 \$

Timekeeper Date Matter Task Narrative Hours Rate Amount

Action Analysis Respond to inquiries from NPM Law [P. Linsey] regarding language in 0.4 \$ 495 \$

Action Analysis Respond to inquiry from Paul Hastings

Lazarus, Jordan 05/23/2024 Asset Recovery

based on new document production from 0.8 \$ 495 \$

Action Analysis Review A. Lomas analysis of 0.1 \$ 680 \$

Action Analysis Review analysis of 0.1 \$ 680 \$

Action Analysis Respond to inquiry from NPM Law [P.

Lazarus, Jordan 05/28/2024 Asset Recovery

Action Analysis Correspondence with NPM Law

Action Analysis Respond to inquiry from NPM Law [P.

markings in documents underlying 0.1 \$ 495 \$

Levenson, Patrick 05/01/2024 Asset Recovery

and Litigation Investigations Call with J. Barker, S. Dominguez

and Litigation Investigations Call with P. Levenson, S. Dominguez

Dominguez, Sunni 05/01/2024 Asset Recovery

and Litigation Investigations Call with J. Barker, P. Levenson

Dominguez, Sunni 05/01/2024 Asset Recovery

and Litigation Investigations Update spreadsheet re: 1.8 \$ 495 \$

Timekeeper Date Matter Task Narrative Hours Rate Amount

Lomas, Adam 05/02/2024 Asset Recovery Investigations Email to NPM Law [K. Mitchell] 1.3 \$ 495 \$ 643.50 Investigation regarding outstanding and additional

transaction review. Parizek, Pam 05/03/2024 Asset Recovery Investigations Review research update regarding 0.1 \$ 680 \$ 68.00

Lomas, Adam 05/03/2024 Asset Recovery Investigations Review of documents produced by

and Litigation related updates to transactions in master transaction file.

Lomas, Adam 05/06/2024 Asset Recovery Investigations Respond to inquiry from Paul Hastings 0.2 \$ 495 \$ 99.00

Lomas, Adam 05/06/2024 Asset Recovery Investigations Review and analysis of account activity 0.7 \$ 495 \$ 346.50

transactions in master transaction file. Lomas, Adam 05/06/2024 Asset Recovery Investigations Review and analyze statements and 2.6 \$ 495 \$ 1,287.00

master transaction file. Levenson, Patrick 05/07/2024 Asset Recovery Investigations Conduct targeted research on 1.0 \$ 231 \$ 231.00

and Litigation history. Dominguez, Sunni 05/07/2024 Asset Recovery Investigations Conduct 1.7 \$ 495 \$ 841.50 Investigation research.

Lomas, Adam 05/07/2024 Asset Recovery Investigations Respond to inquiry from Paul Hastings 0.6 \$ 495 \$ 297.00

Lomas, Adam 05/07/2024 Asset Recovery Investigations Continue to review and analyze 3.9 \$ 495 \$ 1,930.50 Investigation statements and account activity for

to transactions in master transaction file.

Levenson, Patrick 05/08/2024 Asset Recovery Investigations Conduct targeted research on 5.0 \$ 231 \$ 1,155.00

and Litigation history. Lomas, Adam 05/08/2024 Asset Recovery Investigations Respond to inquiry from Paul Hastings 1.9 \$ 495 \$ 940.50

transactions in master transaction file. Lomas, Adam 05/08/2024 Asset Recovery Investigations Review and analyze statements and 3.1 \$ 495 \$ 1,534.50

master transaction file.

Timekeeper Date Matter Task Narrative Hours Rate Amount

Levenson, Patrick 05/09/2024 Asset Recovery

and Litigation Investigations Conduct targeted research on

and Litigation Investigations Review communications and analysis

Scodeller, Bradley 05/09/2024 Asset Recovery

and Litigation Investigations working paper - pre and

Dominguez, Sunni 05/09/2024 Asset Recovery

and Litigation Investigations Meeting regarding analysis of activity in

[P. Linsey]; and P. Parizek and J. Barker. 0.6 \$ 495 \$

and Litigation Investigations Meeting with NPM Law [P. Linsey]

and Litigation Investigations Respond to inquiry from Paul Hastings [E. Sutton] regarding source of funds for

and Litigation Investigations Review and analysis of transactions in

related email to NPM Law [P. Linsey]. 2.8 \$ 495 \$

and Litigation Investigations Respond to inquiry from NPM Law [P. Linsey] regarding balances in 0.4 \$ 495 \$

and Litigation Investigations Email to M. Bottos regarding instructions

and Litigation Investigations Prepare schedule of pre- and post

email correspondence with NPM Law [S.

and Litigation Investigations Review of Relativity document

Timekeeper Date Matter Task Narrative Hours Rate Amount

and Litigation Investigations Review general categorizations of

and Litigation Investigations Respond to inquiry from NPM Law [K.

records supporting transfers to 0.4 \$ 495 \$

and Litigation Investigations Respond to inquiry from NPM Law [P.

documents purportedly outlining 1.3 \$ 495 \$

and Litigation Investigations Create template for capture of certain

request/inquiry from Paul Hastings [L.

and Litigation Investigations Respond to inquiry from Paul Hastings

Bottos, Madison 05/21/2024 Asset Recovery

and Litigation Investigations Review of

master transaction file. 5.4 \$ 200 \$

and Litigation Investigations Review updated analysis of 0.3 \$ 680 \$

Bottos, Madison 05/22/2024 Asset Recovery

and Litigation Investigations Review of

master transaction file. 4.7 \$ 200 \$

and Litigation Investigations Quality control review of

Bottos, Madison 05/23/2024 Asset Recovery

and Litigation Investigations Review of

master transaction file. 0.8 \$ 200 \$

and Litigation Investigations Call with P. Parizek, J. Lazarus, J. Barker, Paul Hastings [L. Despins, L.

and Litigation Investigations Compose email to Paul Hastings and

Timekeeper Date Matter Task Narrative Hours Rate Amount

and Litigation Investigations Respond to inquiry from NPM Law [K.

and Litigation Investigations Review of transactions; related updates to transaction master file. 0.4 \$ 495 \$

and Litigation Investigations Compose email to NPM Law [P. Linsey]

and Litigation Investigations Compose email to NPM Law [K.

financial transaction review. 0.7 \$ 495 \$

and Litigation Investigations Review of documents produced by

transaction master file. 2.2 \$ 495 \$

and Litigation Investigations Preliminary review of

and Litigation Investigations Compose email to Paul Hastings [N.

and Litigation Investigations Compose email to NPM Law [K.

Bottos, Madison 05/28/2024 Asset Recovery

and Litigation Investigations Prepare summary of activity on various 2.2 \$ 200 \$

and Litigation Investigations Update of listing of outstanding requests

and Litigation Investigations Review of additional documents

related updates to master transaction file. 1.6 \$ 495 \$

and Litigation Investigations Respond to inquiry from NPM Law [K.

Timekeeper Date Matter Task Narrative Hours Rate Amount

Lomas, Adam 05/29/2024 Asset Recovery Investigations Review of various records regarding 3.8 \$ 495 \$

and Litigation account activity and bookkeeping; related updates to master transaction file.

Lomas, Adam 05/30/2024 Asset Recovery Investigations Compose internal team email to 0.2 \$ 495 \$

Investigation regarding status of working tasks for and Litigation update meeting with Paul Hastings and NPM Law counsel teams. Lomas, Adam 05/30/2024 Asset Recovery Investigations Respond to inquiry from NPM Law [K. 0.2 \$ 495 \$

Investigation Mitchell] regarding outstanding and Litigation questions and requests for

Lomas, Adam 05/30/2024 Asset Recovery Investigations Compose email to NPM Law [P. Linsey] 0.2 \$ 495 \$

records.

Lomas, Adam 05/30/2024 Asset Recovery Investigations Review of various records regarding 3.4 \$ 495 \$

and Litigation account activity and bookkeeping; related updates to master transaction file. Lomas, Adam 05/31/2024 Asset Recovery Investigations Respond to inquiry from NPM Law [K. 0.1 \$ 495 \$

and Litigation subpoena.

Lomas, Adam 05/31/2024 Asset Recovery Investigations Review of various records regarding 2.2 \$ 495 \$

and Litigation account activity and bookkeeping; related updates to master transaction file.

Lomas, Adam 05/02/2024 G-Club Investigations Review and analyze 0.6 \$ 495 \$

transaction file. Bottos, Madison 05/03/2024 G-Club Investigations Review of 0.4 \$ 200 \$

Proceeding transactions; related updates to master transaction file. Lomas, Adam 05/03/2024 G-Club Investigations Incorporate extracted 0.9 \$ 495 \$

Proceeding master transaction file for review and analysis; related instructions to M. Bottos for review and analysis of transactions. Lomas, Adam 05/29/2024 G-Club Investigations Respond to inquiry from NPM Law [K. 0.1 \$ 495 \$

Proceeding account. Parizek, Pam 05/20/2024 General Debtor Fee/Employmen Review/revise/redact April fee 5.0 \$ 680 \$

Representation t Applications application, confer A. Bongartz, J. Jacobson regarding same. Ling, Bryant 05/01/2024 Golden Spring Asset Analysis Create file listing,

Adversary and Recovery prepare client deliverables: Exhibits 10, Proceeding 11, 14, 15 and 16. Parizek, Pam 05/02/2024 Golden Spring Asset Analysis Multiple calls and emails with Kroll 0.5 \$ 680 \$

Adversary and Recovery technology team and Paul Hastings, Proceeding arrange for courier to deliver

Downie, Scott 05/02/2024 Golden Spring Asset Analysis Email to P. Parizek, B. Demonte 0.5 \$ 495 \$

Adversary and Recovery coordinating the delivery of

Timekeeper Date Matter Task Narrative Hours Rate Amount

Ling, Bryant 05/03/2024 Golden Spring Asset Analysis Client deliverable, courier coordination, 0.1 \$ 495 \$ 49.50 Adversary and Recovery Copy of Exhibit 001-Exhibit 016

Ling, Bryant 05/03/2024 Golden Spring Asset Analysis Client deliverable, courier coordination, 0.1 \$ 495 \$ 49.50 Adversary and Recovery Copy of Exhibit 001-Exhibit 016

Ling, Bryant 05/03/2024 Golden Spring Asset Analysis Client deliverable, courier coordination, 0.1 \$ 495 \$ 49.50 Adversary and Recovery Copy of Exhibit 001-Exhibit 016

05/03/2024 Golden Spring Asset Analysis Client deliverable, courier coordination, 0.1 \$ 495 \$ 49.50 Adversary and Recovery Copy of Exhibit 001-Exhibit 016

Ling, Bryant 05/03/2024 Golden Spring Asset Analysis Client deliverable, courier coordination, 0.1 \$ 495 \$ 49.50 Adversary and Recovery Copy of Exhibit 001-Exhibit 016

Ling, Bryant 05/03/2024 Golden Spring Asset Analysis Client deliverable, courier coordination, 0.1 \$ 495 \$ 49.50 Adversary and Recovery Copy of Exhibit 001-Exhibit 016

Parizek, Pam 05/03/2024 Golden Spring Asset Analysis Coordinate delivery of 0.2 \$ 680 \$ 136.00

Proceeding and Recovery to Paul Hastings' New York office. Downie, Scott 05/08/2024 Golden Spring Asset Analysis Email to Kroll's Lab team coordinating 0.5 \$ 495 \$ 247.50

Downie, Scott 05/08/2024 Golden Spring Asset Analysis Email to P. Parizek, B. Demonte 0.7 \$ 495 \$ 346.50 Adversary and Recovery coordinating the delivery of

Parizek, Pam 05/09/2024 Golden Spring Asset Analysis Review revised evidence log for 0.2 \$ 680 \$ 136.00 Adversary and Recovery [.1], update Paul Hastings [N. Proceeding Bassett] regarding same [.1]. Downie, Scott 05/09/2024 Golden Spring Asset Analysis Email to P. Parizek, B. Demonte 0.4 \$ 495 \$ 198.00 Adversary and Recovery coordinating the delivery of

Parizek, Pam 05/10/2024 Golden Spring Asset Analysis Confer S. Downie regarding 0.1 \$ 680 \$ 68.00

Lomas, Adam 05/30/2024 Golden Spring Investigations Incorporate transactions from 1.5 \$ 495 \$ 742.50

Parizek, Pam 05/01/2024 HCHK Asset Analysis transaction review and analysis. Confer S. Downie, D. Ackerman 0.3 \$ 680 \$ 204.00

; Proceeding confer Paul Hastings [N. Bassett] regarding same [.3]. Downie, Scott 05/01/2024 HCHK Asset Analysis Email P. Parizek, B. Demonte 0.1 \$ 495 \$ 49.50 Adversary and Recovery coordinating the preservation of

Downie, Scott 05/01/2024 HCHK Asset Analysis Email Kroll's Lab team coordinating the 0.3 \$ 495 \$ 148.50

Downie, Scott 05/02/2024 HCHK Proceeding Asset Analysis Email to B. Demonte, D. Ackerman 0.6 \$ 495 \$ 297.00 Adversary and Recovery regarding preserving the

Downie, Scott 05/02/2024 HCHK Asset Analysis Email to P. Parizek, B. Demonte 1.3 \$ 495 \$ 643.50 Adversary and Recovery coordinating the preservation of

Downie, Scott 05/02/2024 HCHK Asset Analysis Email to Kroll's Lab team coordinating 1.6 \$ 495 \$ 792.00 Adversary and Recovery the preservation of

Timekeeper Date Matter Task Narrative Hours Rate Amount

Ling, Bryant 05/03/2024 HCHK Asset Analysis Client deliverable, Exhibit 001 file 0.5 \$ 495 \$

Ling, Bryant 05/03/2024 HCHK Asset Analysis Client deliverable, Exhibit 002 file 1.1 \$ 495 \$

Ling, Bryant 05/03/2024 HCHK Asset Analysis Client deliverable, Exhibit 003 file 1.3 \$ 495 \$

Downie, Scott 05/03/2024 HCHK Asset Analysis Email to P. Parizek, B. Demonte 0.1 \$ 495 \$

Adversary and Recovery coordinating the preservation of

Downie, Scott 05/03/2024 HCHK Asset Analysis Email to B. Demonte, D. Ackerman 0.1 \$ 495 \$

Adversary and Recovery regarding preserving the

Ling, Bryant 05/04/2024 HCHK Asset Analysis Client deliverable, Exhibit 005 file 0.3 \$ 495 \$

Ling, Bryant 05/04/2024 HCHK Proceeding Asset Analysis Client deliverable, Exhibit 005 file 2.0 \$ 495 \$

Ling, Bryant 05/04/2024 HCHK Asset Analysis Client deliverable, Exhibit 007 file 2.0 \$ 495 \$

Ling, Bryant 05/05/2024 HCHK Asset Analysis Client deliverable, Exhibit 003 file 1.0 \$ 495 \$

Ling, Bryant 05/05/2024 HCHK Asset Analysis Client deliverable, Exhibit 005 file 1.5 \$ 495 \$

Ling, Bryant 05/05/2024 HCHK Asset Analysis Client deliverable, Exhibit 007 and 1.9 \$ 495 \$

Adversary and Recovery Exhibit 008 file

Ling, Bryant 05/06/2024 HCHK Asset Analysis Client deliverable, Exhibit 007 and 2.5 \$ 495 \$

Adversary and Recovery Exhibit 008 file

Ling, Bryant 05/09/2024 HCHK Asset Analysis Client deliverable, upload, Exhibit 001- 0.2 \$ 495 \$

Parizek, Pam 05/09/2024 HCHK Asset Analysis Review evidence inventory for 0.3 \$ 680 \$

Adversary and Recovery [.2], update Paul Hastings [N. Bassett] Proceeding regarding same [.1]. Downie, Scott 05/09/2024 HCHK Asset Analysis Email to Kroll's Lab team coordinating 0.6 \$ 495 \$

Proceeding and Recovery the preservation of Downie, Scott 05/23/2024 HCHK Asset Analysis Email to Kroll's Lab team coordinating 0.3 \$ 495 \$

Lomas, Adam 05/08/2024 Leading Shine Asset Analysis Quality control review of staff analysis of 0.6 \$ 495 \$

Lomas, Adam 05/09/2024 Leading Shine Asset Analysis Quality control review of staff analysis of 0.7 \$ 495 \$

Timekeeper Date Matter Task Narrative Hours Rate Amount

Lazarus, Jordan 06/03/2024 Asset Recovery

and Recovery Call with B. Scodeller re: analysis of document production. 0.3 \$ 495 \$ 148.50 Lazarus, Jordan 06/03/2024 Asset Recovery

document production. 1.7 \$ 495 \$ 841.50

and Recovery Review A. Lomas analysis of

and Recovery Compose email to Paul Hastings [D.

and Recovery Review of accounting/bookkeeping

reconciliation to bank statements; related attention to master transaction file. 5.0 \$ 495 \$ 2,475.00

and Recovery Respond to inquiry from NPM Law [K.

and Recovery Prepare summary schedule of sources

Lazarus, Jordan 06/06/2024 Asset Recovery

and Recovery Attend weekly call with P. Parizek, A. Lomas, Paul Hastings [L. Despins, N. Bassett, D. Barron], NPM Law [K. Mitchell] re:

August 15 deadline. 0.8 \$ 495 \$ 396.00

and Recovery Draft agenda [.1] and attend weekly call

NPM Law [K. Mitchell] re:

and Recovery Review A. Lomas analysis re: 0.2 \$ 680 \$ 136.00

and Recovery Attend weekly call with P. Parizek,J. Lazarus, Paul Hastings [L. Despins, N. Bassett, D. Barron], NPM Law [K. Mitchell] re:

August 15 deadline. 0.8 \$ 495 \$ 396.00

Timekeeper Date Matter Task Narrative Hours Rate Amount

Lazarus, Jordan 06/10/2024 Asset Recovery

and Recovery Respond to email inquiry from NPM Law [K. Mitchell] re:

transaction file for review and analysis. 0.5 \$ 495 \$

and Recovery Compose email to NPM Law [K.

and Recovery Review and analysis of transactions in

to master transaction file. 1.0 \$ 495 \$

Lazarus, Jordan 06/11/2024 Asset Recovery

and Recovery Review and analysis of transactions in

and Recovery Review and analysis of transactions in

to master transaction file. 0.7 \$ 495 \$

Lazarus, Jordan 06/12/2024 Asset Recovery

and Recovery Correspondence with NPM Law [P.

re:

Lazarus, Jordan 06/12/2024 Asset Recovery

and Recovery Review of additional documents

and Recovery Review and analysis of transactions in

Timekeeper Date Matter Task Narrative Hours Rate Amount

and Recovery Compose email to Paul Hastings and NPM Law counsel teams re:

June 13 status update call. 1.3 \$ 495 \$

and Recovery Review and analysis of transactions in

to master transaction file. 0.5 \$ 495 \$

and Recovery Prepare summary schedule of activity in

and Recovery Review and analysis of transactions in

to master transaction file. 0.4 \$ 495 \$

and Recovery Call with A. Lomas, Paul Hastings [L. Despins, N. Bassett, D. Barron, L. Song],

and Recovery Call with P. Parizek, Paul Hastings [L. Despins, N. Bassett, D. Barron, L. Song],

Lazarus, Jordan 06/14/2024 Asset Recovery

and Recovery Correspondence with NPM Law and Paul Hastings re:

Lazarus, Jordan 06/17/2024 Asset Recovery

and Recovery Correspondence with NPM Law and Paul Hastings re:

and Recovery Review Paul Hastings request Paul Hastings [N. Bassett] re:

bank documentation re: same. 0.2 \$ 680 \$

and Recovery Review A. Lomas analyses re: alter egos [.2], summary re:

Lazarus, Jordan 06/18/2024 Asset Recovery

and Recovery Review transactional activity and

Lazarus, Jordan 06/18/2024 Asset Recovery

and Recovery Review transactional activity for

Lazarus, Jordan 06/18/2024 Asset Recovery

and Recovery Correspondence with Paul Hastings and Kroll team re: payments to 0.2 \$ 495 \$

Lazarus, Jordan 06/18/2024 Asset Recovery

and Recovery Correspondence with Paul Hastings and

Timekeeper Date Matter Task Narrative Hours Rate Amount

Lazarus, Jordan 06/19/2024 Asset Recovery

supporting documents related to 0.4 \$ 495 \$ 198.00

and Recovery Confer Kroll team re: status updates, outreach to Paul Hastings re: same. 0.1 \$ 680 \$ 68.00 Lazarus, Jordan 06/19/2024 Asset Recovery

and Recovery Review of transactional activity for payments made to 0.5 \$ 495 \$ 247.50 Lazarus, Jordan 06/19/2024 Asset Recovery

and Recovery Correspondence with NPM Law re:

bank statement production. 0.2 \$ 495 \$ 99.00 Lazarus, Jordan 06/19/2024 Asset Recovery

and Recovery Correspondence with NPM Law re:

and related matters. 0.2 \$ 495 \$ 99.00 Lazarus, Jordan 06/19/2024 Asset Recovery

and Recovery Review of Kroll bank statement inventory and Relativity re:

Lazarus, Jordan 06/24/2024 Asset Recovery

and Recovery Correspondence with NPM Law re:

Lazarus, Jordan 06/24/2024 Asset Recovery

and Recovery Review correspondence from NPM Law

and related matters. 0.2 \$ 495 \$ 99.00 Lazarus, Jordan 06/26/2024 Asset Recovery

and Recovery Review testimony transcript of 0.5 \$ 495 \$ 247.50

and Recovery Status update to Paul Hastings [.1].

re:

Action Analysis Respond to inquiry from NPM Law [P.

avoidance complaint. 0.5 \$ 495 \$ 247.50

Action Analysis Call with M. Bottos re: instructions for

and related bank document support. 0.4 \$ 495 \$ 198.00

Timekeeper Date Matter Task Narrative Hours Rate Amount

Action Analysis Call with A. Lomas, J. Lazarus, M.

Lazarus, Jordan 06/05/2024 Asset Recovery

Action Analysis Call with P. Parizek, A. Lomas, M.

Action Analysis Call with P. Parizek, J. Lazarus, M.

Lazarus, Jordan 06/25/2024 Asset Recovery

Action Analysis Analysis of pre-petition avoidance action payments per request from Paul Hastings. 1.4 \$ 495 \$

Action Analysis Respond to email inquiry from NPM

and Litigation Investigations Call with J. Lazarus, M. Bottos re:

Lazarus, Jordan 06/05/2024 Asset Recovery

and Litigation Investigations Call with A. Lomas, M. Bottos re:

and Litigation Investigations Compose email to Paul Hastings and NPM Law counsel teams re:

and Litigation Investigations Call with Paul Hastings [N. Bassett, D. Barron] re: Relativity review of 0.5 \$ 495 \$

and Litigation Investigations Review list of

provided by Paul Hastings [D. Barron];

entities against master transaction file. 3.2 \$ 495 \$

and Litigation Investigations Review list of

provided by Paul Hastings [D. Barron];

entities against master transaction file. 0.5 \$ 495 \$

and Litigation Investigations Compose email to Paul Hastings [D.

and Litigation Investigations Compose email to NPM Law [K. Mitchell] re: additional entities and bank

Timekeeper Date Matter Task Narrative Hours Rate Amount

Lazarus, Jordan 06/17/2024 Asset Recovery

and Litigation Investigations Correspondence with Paul Hastings [D.

Lazarus, Jordan 06/17/2024 Asset Recovery

and Litigation Investigations Analysis of transactional detail and

Lazarus, Jordan 06/19/2024 Asset Recovery

and Litigation Investigations Correspondence with NPM Law re: 0.1 \$ 495 \$

Lazarus, Jordan 06/20/2024 Asset Recovery

and Litigation Investigations Correspondence with Paul Hastings re:

Lazarus, Jordan 06/20/2024 Asset Recovery

and Litigation Investigations Review of transactional activity for

Lazarus, Jordan 06/21/2024 Asset Recovery

and Litigation Investigations Correspondence and Relativity searches

and Litigation Investigations Review of updated document production

and Litigation Investigations Compose email to Paul Hastings [D.

and Litigation Investigations Upload of

reconciliation of statements/accounts 0.9 \$ 495 \$

and Litigation Investigations Incorporation of

Lazarus, Jordan 06/30/2024 Asset Recovery

and Litigation Investigations Analysis of

Lomas, Adam 06/10/2024 G-Club Adversary

and Recovery Review of additional documents

accounts; related attention to inventory of

Timekeeper Date Matter Task Narrative Hours Rate Amount

Lomas, Adam 06/25/2024 G-Club Investigations Respond to email inquiry from NPM 0.5 \$ 495 \$ 247.50 Adversary Law [K. Mitchell] re:

Parizek, Pam 06/20/2024 General Debtor Fee/Employmen Review, revise May Fee Statement. 1.9 \$ 680 \$ 1,292.00

Parizek, Pam 06/21/2024 General Debtor Fee/Employmen Review Kroll fee application for January 1.3 \$ 680 \$ 884.00 Representation t Applications April 2024, review/approve supporting schedules, confer Paul Hastings [A. Bongartz] re: same.

t Applications Redact May Fee Statement, update schedule of expenses. 1.8 \$ 680 \$ 1,224.00

Parizek, Pam 06/17/2024 Gettr USA Asset Analysis Review Paul Hastings [D. Barron] 0.3 \$ 680 \$ 204.00 Proceeding and Recovery inquiry re:

team analysis re: same. Lomas, Adam 06/06/2024 Golden Spring Investigations Review and analysis of activity in 1.4 \$ 495 \$ 693.00

Lomas, Adam 06/07/2024 Golden Spring Investigations file. Review and analysis of activity in 1.1 \$ 495 \$ 544.50

file. Parizek, Pam 06/06/2024 UAE Asset Asset Analysis Review inquiries, follow 0.4 \$ 680 \$ 272.00

re: same.

Timekeeper Date Matter Task Narrative Hours Rate Amount

Lazarus, Jordan 07/03/2024 Asset Recovery

and Recovery Attend weekly call with P. Parizek, A. Lomas, J. Barker, Paul Hastings [L.

Law [P. Linsey] re:

and Recovery Attend weekly call with P. Parizek, A. Lomas, J. Lazarus, Paul Hastings [L.

Law [P. Linsey] re:

and Recovery Attend weekly call with P. Parizek, J. Barker, J. Lazarus, Paul Hastings [L.

Law [P. Linsey] re:

and Recovery Review A. Lomas updates [.4], draft

Hastings [L. Despins, N. Bassett, D. Barron] and NPM Law [P. Linsey] re:

statements, and updates re:

updates re:

and Recovery Confer J. Lazarus re: analysis of

Lazarus, Jordan 07/03/2024 Asset Recovery

and Recovery Correspondence with P. Parizek re:

and Recovery Review Paul Hastings [N. Bassett] email re: trial update, confer Kroll team re:

Timekeeper Date Matter Task Narrative Hours Rate Amount

Lazarus, Jordan 07/05/2024 Asset Recovery

and Recovery Correspondence with NPM Law re: document production. 0.2 \$ 495 \$ 99.00 Bottos, Madison 07/08/2024 Asset Recovery

and Recovery Meeting with J. Lazarus re: analysis of

Lazarus, Jordan 07/08/2024 Asset Recovery

and Recovery Meeting with M. Bottos re: analysis of

Lazarus, Jordan 07/08/2024 Asset Recovery

and Recovery Correspondence with NPM Law re:

Lazarus, Jordan 07/08/2024 Asset Recovery

and Recovery Analysis of payments to 0.4 \$ 495 \$ 198.00 Lazarus, Jordan 07/08/2024 Asset Recovery

document production. 1.2 \$ 495 \$ 594.00 Lazarus, Jordan 07/09/2024 Asset Recovery

and Recovery Correspondence with Kroll team re:

Lazarus, Jordan 07/09/2024 Asset Recovery

document production. 3.1 \$ 495 \$ 1,534.50 Lazarus, Jordan 07/10/2024 Asset Recovery

and Recovery Correspondence with Paul Hastings and

and related matters. 0.2 \$ 495 \$ 99.00 Lazarus, Jordan 07/10/2024 Asset Recovery

document production. 0.8 \$ 495 \$ 396.00 Lazarus, Jordan 07/11/2024 Asset Recovery

and Recovery Call with M. Bottos re: analysis of

Bottos, Madison 07/11/2024 Asset Recovery

and Recovery Call with J. Lazarus re: analysis of

Lazarus, Jordan 07/11/2024 Asset Recovery

and Recovery Attend weekly call with P. Parizek, A. Lomas, Paul Hastings [L. Despins, N. Bassett, D. Barron], NMP Law [P. Lindsay] re:

and Recovery Attend weekly call with P. Parizek, J. Lazarus, Paul Hastings [L. Despins, N. Bassett, D. Barron], NMP Law [P. Lindsay] re:

Timekeeper Date Matter Task Narrative Hours Rate Amount

and Recovery Review status update from A. Lomas [.3], provide agenda for weekly call [.1], and attend weekly call with A. Lomas, J. Lazarus, Paul Hastings [L. Despins, N. Bassett, D. Barron], NMP Law [P. Lindsay] re:

Lazarus, Jordan 07/11/2024 Asset Recovery

Lazarus, Jordan 07/12/2024 Asset Recovery

Lazarus, Jordan 07/18/2024 Asset Recovery

and Recovery Attend weekly call with P. Parizek, A. Lomas, J. Barker, Paul Hastings [L. Despins, N. Bassett, D. Barron, L. Song],

and Recovery Prepare agenda [.1] and attend weekly call with A. Lomas, J. Lazarus, J. Barker, Paul Hastings [L. Despins, N. Bassett, D.

re:

and Recovery Attend weekly call with P. Parizek, A. Lomas, J. Lazarus,Paul Hastings [L. Despins, N. Bassett, D. Barron, L. Song],

and Recovery Attend weekly call with P. Parizek, J. Lazarus, J. Barker, Paul Hastings [L. Despins, N. Bassett, D. Barron, L. Song],

Lazarus, Jordan 07/18/2024 Asset Recovery

and Recovery Correspondence with D. Barron and A. Lomas re:

Lazarus, Jordan 07/18/2024 Asset Recovery

Lazarus, Jordan 07/19/2024 Asset Recovery

and Recovery Review J. Lazarus analysis of

Timekeeper Date Matter Task Narrative Hours Rate Amount

Lazarus, Jordan 07/23/2024 Asset Recovery

and Recovery Attend weekly call with P. Parizek, A. Lomas, J. Lazarus, Paul Hastings [L. Despins, N. Bassett, D. Barron, L. Song], NPM Law [P. Linsey] re:

and Recovery Attend weekly call with P. Parizek, J. Lazarus, J. Barker, Paul Hastings [L. Despins, N. Bassett, D. Barron, L. Song], NPM Law [P. Linsey] re:

Lazarus, Jordan 07/25/2024 Asset Recovery

and Recovery Attend weekly call with P. Parizek, A. Lomas, J. Barker, Paul Hastings [L. Despins, N. Bassett, D. Barron, L. Song], NPM Law [P. Linsey] re:

and Recovery Prepare agenda [.1] and attend weekly call with A. Lomas, J. Lazarus, J. Barker, Paul Hastings [L. Despins, N. Bassett, D.

re:

Lazarus, Jordan 07/25/2024 Asset Recovery

and Recovery Correspondence with NPM Law and Kroll team re:

Lazarus, Jordan 07/25/2024 Asset Recovery

balance and other card activity. 2.4 \$ 495 \$

Lazarus, Jordan 07/05/2024 Asset Recovery

Action Analysis Analysis of financial transactions re:

Action Analysis Call with J. Lazarus, NPM Law [P.

with respect to the update of transfers for possible avoidance actions. 0.4 \$ 495 \$

Lazarus, Jordan 07/11/2024 Asset Recovery

Action Analysis Call with A. Lomas, NPM Law [P.

with respect to the update of transfers for possible avoidance actions. 0.4 \$ 495 \$

Timekeeper Date Matter Task Narrative Hours Rate Amount

Lazarus, Jordan 07/12/2024 Asset Recovery

Action Analysis Prepare updated avoidance action

Bottos, Madison 07/18/2024 Asset Recovery

Action Analysis Call with J. Lazarus re: compilation of

Lazarus, Jordan 07/18/2024 Asset Recovery

Action Analysis Call and correspondence with M. Bottos,

supporting documentation. 0.3 \$ 495 \$ 148.50

Action Analysis Review A. Lomas summary of Kwok Investigation Data [.1], avoidance action

Action Analysis Respond to email inquiries from Paul

with transfers from list of certain entities. 0.8 \$ 495 \$ 396.00 Bottos, Madison 07/18/2024 Asset Recovery

Action Analysis Compilation of documentary support for avoidance action against 1.7 \$ 200 \$ 340.00

Action Analysis Meeting with NPM Law [P. Linsey, S. Smeriglio] re:

Action Analysis Attention to Excel file detailing transfers

transfers to underlying bank documents. 1.9 \$ 495 \$ 940.50

Action Analysis Review client request and Kroll response re: avoidance claim. 0.2 \$ 680 \$ 136.00 Lazarus, Jordan 07/31/2024 Asset Recovery

Action Analysis Compile supporting documentation for specific avoidance action. 1.1 \$ 495 \$ 544.50 Lazarus, Jordan 07/18/2024 Asset Recovery

Administration Call with A. Lomas re: motion responses for Paul Hastings and related matters. 0.4 \$ 495 \$ 198.00

Administration Call with J. Lazarus re: motion responses for Paul Hastings and related matters. 0.4 \$ 495 \$ 198.00

and Litigation Investigations Prepare initial response to email inquiry from NPM Law [P. Linsey] re:

and Litigation Investigations Prepare schedule of transfers between

between alter ego entities, and other]; related analysis of transactions in master transaction file. 3.6 \$ 495 \$ 1,782.00

and Litigation Investigations Review of documents produced by

master transaction file. 0.2 \$ 495 \$ 99.00

Timekeeper Date Matter Task Narrative Hours Rate Amount

and Litigation Investigations Review of additional documents

and Litigation Investigations Prepared instructions to M. Bottos for

Bottos, Madison 07/02/2024 Asset Recovery

and Litigation Investigations Review of

updates to master transaction file. 3.3 \$ 200 \$

and Litigation Investigations Review A. Lomas summary re: new alter

and Litigation Investigations Compose email to Paul Hastings [D.

potential new alter ego entities. 0.2 \$ 495 \$

and Litigation Investigations Compose email to NPM Law [P. Linsey]

conversation with P. Linsey re: same. 0.2 \$ 495 \$

and Litigation Investigations Compose email to internal Kroll investigative team re:

and Litigation Investigations Respond to email inquiry from NPM

of supporting bank documents. 0.5 \$ 495 \$

and Litigation Investigations Upload of bank statements into bank statement analysis tool. 0.2 \$ 495 \$

and Litigation Investigations Review of additional documents

and Litigation Investigations Conduct Relativity document search re:

and underlying bank records; compose email response to NPM Law [P.

and Litigation Investigations Respond to email inquiry from NPM Law [K. Mitchell] re: knowns, identified,

and Litigation Investigations Incorporate

transaction file for review and analysis. 0.3 \$ 495 \$

and Litigation Investigations Incorporate

transactions into master transaction file for review and analysis. 0.4 \$ 495 \$

and Litigation Investigations Incorporate

transactions into master transaction file for review and analysis. 0.5 \$ 495 \$

Timekeeper Date Matter Task Narrative Hours Rate Amount

and Litigation Investigations Attention to reconciliation of statements

and Litigation Investigations Reconciliation of transfers from

related entities/accounts; related updates to master transaction file. 1.4 \$ 495 \$

and Litigation Investigations Upload of bank statements into bank statement analysis tool. 1.4 \$ 495 \$

and Litigation Investigations Analysis of

accounts; related updates to master transaction file. 2.6 \$ 495 \$

and Litigation Investigations Quality control review and analysis of

updates to master transaction file. 0.3 \$ 495 \$

and Litigation Investigations Incorporate

transaction file for review and analysis. 0.5 \$ 495 \$

and Litigation Investigations Analysis of transfers between

and Litigation Investigations Respond to email inquiry from Paul Hastings [N. Bassett] re: supporting bank

and Litigation Investigations Analysis of

and Litigation Investigations Attention to reconciliation of statements

and Litigation Investigations Analysis of

and Litigation Investigations Compose email to Paul Hastings and

and Litigation Investigations Prepare summary schedule of bank account transaction activity. 0.4 \$ 495 \$

and Litigation Investigations Analysis of

accounts; related updates to master transaction file. 0.6 \$ 495 \$

and Litigation Investigations Prepare summary schedule of bank account transaction activity. 0.6 \$ 495 \$

and Litigation Investigations Compose email to NPM Law [P. Linsey]

Timekeeper Date Matter Task Narrative Hours Rate Amount

and Litigation Investigations Respond to email inquiry from NPM

and Litigation Investigations Respond to email inquiry from Paul

and Litigation Investigations Respond to email inquiry from Paul

and Litigation Investigations Review of documents related to

updates to master transaction file. 0.8 \$ 495 \$

and Litigation Investigations Conduct scoping review of non-bank

respect to bank/financial transfers. 4.8 \$ 495 \$

and Litigation Investigations Provide instructions to M. Bottos for

Bottos, Madison 07/16/2024 Asset Recovery

and Litigation Investigations Review of securities activity in

and Litigation Investigations Review of documents related to

updates to master transaction file. 1.8 \$ 495 \$

and Litigation Investigations Provide email instructions to J. Welby re:

information with respect to transfers from Debtor-related bank accounts. 0.3 \$ 495 \$

and Litigation Investigations Analysis of activity in

updates to master transaction file. 5.4 \$ 495 \$

Bottos, Madison 07/17/2024 Asset Recovery

and Litigation Investigations Continue review of securities activity in

and Litigation Investigations Call with J. Welby re: Relativity review

and Litigation Investigations Call with A. Lomas re: Relativity review

and Litigation Investigations Preparation of investigative findings for

Timekeeper Date Matter Task Narrative Hours Rate Amount

and Litigation Investigations Preliminary review of exhibits from criminal trial with respect to identified

correspondence with Paul Hastings [L.

and Litigation Investigations Correspondence on property near

and Litigation Investigations Review of information with respect to

Limited;

[D. Barron] and P. Linsey [NPM Law]. 0.8 \$ 495 \$

and Litigation Investigations Respond to email inquiry from Paul

certain metrics with respect to identified

and master transaction file. 1.4 \$ 495 \$

and Litigation Investigations Relativity document review of non-bank

and Litigation Investigations Review of statements for

criminal trial; related update of inventory of Debtor-related bank accounts. 0.8 \$ 495 \$

and Litigation Investigations Attention to reconciliation of identified bank accounts per criminal trial exhibits

Debtor-related bank accounts. 2.9 \$ 495 \$

and Litigation Investigations Relativity document review of non-bank

and Litigation Investigations Conduct Relativity review of documents from criminal trial with respect to Debtor

and Litigation Investigations Upload of bank statements into bank statement analysis tool. 0.5 \$ 495 \$

and Litigation Investigations Attention to reconciliation of account

bank statement analysis tool. 0.6 \$ 495 \$

Timekeeper Date Matter Task Narrative Hours Rate Amount

and Litigation Investigations Incorporate

transaction file for review and analysis. 0.9 \$ 495 \$ 445.50

and Litigation Investigations Analysis of

updates to master transaction file. 1.9 \$ 495 \$ 940.50

and Litigation Investigations Compose email to internal Kroll team re: purchased in/around June 2021. 0.4 \$ 495 \$ 198.00

and Litigation Investigations Analysis of

updates to master transaction file. 0.7 \$ 495 \$ 346.50

and Litigation Investigations Attention to reconciliation of identified bank accounts per criminal trial exhibits

Debtor-related bank accounts. 0.9 \$ 495 \$ 445.50

and Litigation Investigations Analysis of

master transaction file. 1.2 \$ 495 \$ 594.00

and Litigation Investigations Relativity document review of non-bank

and Litigation Investigations Review team updates re: vehicles. 0.3 \$ 680 \$ 204.00

and Litigation Investigations Correspondence with Paul Hastings [D. Barron] regarding vehicle research. 0.7 \$ 675 \$ 472.50

and Litigation Investigations Prepare draft response to J. Barker re: email inquiry from Paul Hastings [D.

bank accounts; related transaction and document review. 1.0 \$ 495 \$ 495.00

and Litigation Investigations Attention to reconciliation of identified bank accounts per criminal trial exhibits

Debtor-related bank accounts. 1.4 \$ 495 \$ 693.00

and Litigation Investigations Correspondence with P. Levenson on vehicle research. 1.1 \$ 675 \$ 742.50

and Litigation Investigations Correspondence with NPM Law [P.

identified in criminal trial exhibits. 0.2 \$ 495 \$ 99.00

and Litigation Investigations Attention to reconciliation of identified bank accounts per criminal trial exhibits

Debtor-related bank accounts. 0.5 \$ 495 \$ 247.50

and Litigation Investigations Correspondece with Paul Hastings [D.

Company LLC accounts. 0.8 \$ 495 \$ 396.00

Timekeeper Date Matter Task Narrative Hours Rate Amount

Lomas, Adam 07/25/2024 Asset Recovery Investigations Review of additional documents 1.2 \$ 495 \$ 594.00

Bank; and Litigation related update of inventory of Debtor related bank accounts. Levenson, Patrick 07/25/2024 Asset Recovery Investigations Conducted motor vehicle research. 2.0 \$ 231 \$ 462.00

Welby, Jackie 07/25/2024 Asset Recovery Investigations Relativity document review of non-bank 3.4 \$ 200 \$ 680.00 Investigation productions for information with respect and Litigation to transfers from Debtor-related bank

observations. Lomas, Adam 07/26/2024 Asset Recovery Investigations Call with NPM Law [P. Linsey, K. 0.5 \$ 495 \$ 247.50 Investigation Mitchell] re: new banks identified in and Litigation contained in criminal trial exhibits and Rule 2004 subpoenas. Lomas, Adam 07/26/2024 Asset Recovery Investigations Upload of bank statements into bank 0.8 \$ 495 \$ 396.00 Investigation statement analysis tool.

Lomas, Adam 07/29/2024 Asset Recovery Investigations Compose email to NPM Law [K. 0.2 \$ 495 \$ 99.00 Investigation Mitchell] re: and Litigation records. Lomas, Adam 07/29/2024 Asset Recovery Investigations Attention to bank statement analysis tool 0.2 \$ 495 \$ 99.00 Investigation reconciliation.

Investigation Investigations Analysis of

LLC transaction activity; related updates 0.4 \$ 495 \$ 198.00 and Litigation to master transaction file. Lomas, Adam 07/29/2024 Asset Recovery Investigations Analysis of

Investigation transaction activity; related updates to and Litigation master transaction file. Lomas, Adam 07/29/2024 Asset Recovery Investigations Incorporate bank transactions for 0.7 \$ 495 \$ 346.50

accounts into master transaction file for review and analysis. Lomas, Adam 07/29/2024 Asset Recovery Investigations Respond to inquiry from NPM Law [S. 0.7 \$ 495 \$ 346.50 Investigation Smeriglio] re: supporting documentation

07/29/2024 Asset Recovery Investigations from

Inc transfers. Analysis of transfers to/from 0.8 \$ 495 \$ 396.00

and Litigation Limited. Lomas, Adam 07/29/2024 Asset Recovery Investigations Review of additional documents 0.9 \$ 495 \$ 445.50

and Litigation related update of inventory of Debtor related bank accounts. Levenson, Patrick 07/29/2024 Asset Recovery Investigations Motor vehicle research. 4.5 \$ 231 \$ 1,039.50

Lomas, Adam 07/29/2024 Asset Recovery Investigations Compose email to NPM Law [K. 4.7 \$ 495 \$ 2,326.50 Investigation Mitchell] re: new/additional financial and Litigation institutions for Rule 2004 subpoenas;

documents and master transaction file for

institutions.

Timekeeper Date Matter Task Narrative Hours Rate Amount

and Litigation Investigations Analysis of

master transaction file. 0.3 \$ 495 \$

and Litigation Investigations Per inquiry from NPM Law [P. Linsey],

and Litigation Investigations Analysis of

master transaction file. 2.1 \$ 495 \$

and Litigation Investigations Analysis of

master transaction file. 2.3 \$ 495 \$

Levenson, Patrick 07/31/2024 Asset Recovery

and Litigation Investigations Call with A. Lomas, J. Barker, S. Dharamshi, re:

and Litigation Investigations Call with J. Barker, S. Dharamshi, P. Levenson re:

and Litigation Investigations Call with A. Lomas, S. Dharamshi, P. Levenson re:

and Litigation Investigations Upload of bank statements into bank statement analysis tool. 0.2 \$ 495 \$

and Litigation Investigations Incorporate bank transactions for

Levenson, Patrick 07/31/2024 Asset Recovery

and Litigation Investigations Motor vehicle research. 0.5 \$ 231 \$

and Litigation Investigations Respond to inquiry from Paul Hastings

and Litigation Investigations Analysis of

master transaction file. 3.4 \$ 495 \$

t Applications Review/revise Kroll Monthly Fee

Lazarus, Jordan 07/22/2024 General Debtor

t Applications Redact June 2024 fee statement;

t Applications Assign Monthly Fee Statement

additional redactions, transmit to counsel

t Applications Update draft notice of rate increase,

Paul Hastings [A. Bongartz]. 0.5 \$ 680 \$

Timekeeper Date Matter Task Narrative Hours Rate Amount

and Recovery Review chain of custody, tracking, and

Proceeding Investigations Review and analysis of transactions in

Proceeding Investigations Prepare summary of observations re:

Paul Hastings and NPM Law. 0.7 \$ 495 \$

Proceeding Investigations Prepare summary of sources and uses in

Bottos, Madison 07/08/2024 HCHK Adversary

Bottos, Madison 07/09/2024 HCHK Adversary

Bottos, Madison 07/10/2024 HCHK Adversary

Bottos, Madison 07/11/2024 HCHK Adversary

Bottos, Madison 07/12/2024 HCHK Adversary

Proceeding Investigations Analysis of activity in Leading Shine

Proceeding Investigations Respond to email inquiry from Paul

transaction review and tracing analysis. 2.6 \$ 495 \$

Parizek, Pam 07/25/2024 Mahwah Adversary

Parizek, Pam 07/26/2024 Mahwah Adversary Proceeding Investigations Call with J. Leonard re:

[L. Despins] re: same [.1]. 0.1 \$ 680 \$

Parizek, Pam 07/26/2024 Mahwah Adversary Proceeding Investigations Call with J. Leonard re: search for key, PIN retrieval [.2], review manual re:

Leonard, Justin 07/26/2024 Mahwah Adversary Proceeding Investigations Call with P. Parizek re:

locate vehicle keys [2.7]. 3.0 \$ 297 \$

and Recovery Review Kroll memo re:

Timekeeper Date Matter Task Narrative Hours Amount

Lazarus, Jordan 8/1/2024 Asset Recovery

and Litigation Investigations Call with A. Lomas, P. Parizek, J. Barker, Paul Hastings [L. Despins, N.

Law [P. Linsey] re:

and Litigation Investigations Respond to inquiry from NPM Law [P.

and Litigation Investigations Meeting re: bank transaction analysis for

Hastings [L. Despins, N. Bassett, D. Barron, and L.Song]; NPM Law [P.

Lazarus, Jordan 8/1/2024 General Debtor

Applications Attend call with P. Parizek and internal

with Kroll team re: related matters [.3]. 1.1 \$

and Litigation Investigations Weekly call with A. Lomas, P. Parizek, J. Lazarus Paul Hastings [L. Despins, N.

NPM Law [P. Linsey] re:

and Litigation Investigations Working meeting with S. Dharamshi re:

and Litigation Investigations Prepare agenda [.1]; weekly call with A. Lomas, J. Barker, J. Lazarus re:

Applications Review/revise notice of rate increase [deferred Jan-Aug 2024] [.4]; email A. Bongartz re: same and filing [.1]. 0.5 \$

Timekeeper Date Matter Task Narrative Hours Amount

Dharamshi, Salim 8/1/2024 Asset Recovery

and Litigation Investigations Site visit to

photos for: Go to site [1.2], walk around

[1.2].

images of the building to identify any 6.1 \$

Action Analysis Review, cleaning, and normalization of

and Litigation Investigations Correspondence/email - update on

Lazarus, Jordan 8/2/2024 Asset Recovery

Action Analysis Compile supporting documentation for

Lazarus, Jordan 8/2/2024 Asset Recovery

and Litigation Investigations Analysis of

Action Analysis Review, cleaning, and normalization of

and Litigation Investigations Review research re:

Action Analysis Review, cleaning, and normalization of

Action Analysis Prepare schedule of all transfers by transferor entity detailing transfers: [1]

current/existing avoidance actions;

[D. Barron ] and NPM Law [P. Linsey]. 1.8 \$

and Litigation Investigations Respond to inquiry from Paul Hastings

Timekeeper Date Matter Task Narrative Hours Amount

Action Analysis Prepare schedule of transferees not

revisions per request of P. Linsey. 2.9 \$

Action Analysis Review, cleaning, and normalization of

Lazarus, Jordan 8/5/2024 Asset Recovery

Action Analysis Analysis of financial transactions with 3.1 \$

Lazarus, Jordan 8/5/2024 Asset Recovery

Action Analysis Correspondence with P. Linsey and A. Lomas re: avoidance action matters. 0.4 \$

Action Analysis Additional attention and updates to schedule of transferees not currently part of existing avoidance action claims;

Action Analysis Conduct preliminary research with

transferees; related review of underlying

Applications Review, update draft filing of deferred

Lazarus, Jordan 8/5/2024 Asset Recovery

and Litigation Investigations Continued analysis of

in relation to specific recipients. 1.1 \$

and Litigation Investigations Respond to inquiry from NPM Law [P.

Action Analysis Review A. Lomas list of new transferees

Action Analysis Respond to inquiry from NPM Law [S.

Action Analysis Discussion with J. Lazarus re: process to

Timekeeper Date Matter Task Narrative Hours Amount

and Litigation Investigations Reconciliation of Debtor-related

Lazarus, Jordan 8/6/2024 Asset Recovery

Action Analysis Correspondence with A. Lomas re:

and Litigation Investigations Analysis of

and Litigation Investigations Coordinating new avoidance defendants

Lazarus, Jordan 8/7/2024 Asset Recovery

Action Analysis Correspondence with P. Linsey and A.

transactions and related matters. 0.2 \$

Lazarus, Jordan 8/7/2024 Asset Recovery

Action Analysis Prepare and compile payment

Lazarus, Jordan 8/7/2024 Asset Recovery

Action Analysis Correspondence and telephone calls with

and Litigation Investigations Respond to inquiry from NPM Law [P.

Action Analysis Analysis of composition of revised transfers totals for transferees subject to

conversation with NPM Law [P. Linsey]. 1.4 \$

Action Analysis Discussion with J. Lazarus re:

Administration Outreach to Valid8 re: contract renewal

Timekeeper Date Matter Task Narrative Hours Amount

Lazarus, Jordan 8/7/2024 Asset Recovery

Action Analysis Continued analysis of transactions

Action Analysis Review updated transferee list for

Action Analysis Prepare schedule of updated totals of transfers to transferees already part of an

related email to [NPM Law [P. Linsey]. 4.4 \$

Lazarus, Jordan 8/7/2024 Asset Recovery

Action Analysis Correspondence and phone calls with P.

Applications Review billing summary and budget. 0.1 \$

Action Analysis Review updated list of companies on the

Proceeding Investigations Correspondence and telephone calls with

Proceeding Investigations Continued analysis of

and Litigation Investigations Respond to inquiry from NPM Law [P.

Administration Outreach to Kroll team re: outstanding

and Litigation Investigations Responding to motorcycle question from

and Litigation Investigations Research with respect to transfers made

Timekeeper Date Matter Task Narrative Hours Amount

and Litigation Investigations Research with respect to apparent

correspondence to NPM Law [P. Linsey]. 1.3 \$

Lazarus, Jordan 8/8/2024 Asset Recovery

Action Analysis Prepare and compile payment

Action Analysis Prepare schedules of pre- and post

Action Analysis Compose instructions to M. Bottos re:

Lazarus, Jordan 8/8/2024 Asset Recovery

Action Analysis Continued analysis of transactions

Lazarus, Jordan 8/8/2024 Asset Recovery

Action Analysis Correspondence and telephone calls with

Action Analysis Finalize first batch of schedules of pre and post-petition transfers to be included

Timekeeper Date Matter Task Narrative Hours Amount

Lazarus, Jordan 8/9/2024 Asset Recovery

and Litigation Investigations Correspondence and telephone calls with

Action Analysis Meeting with J. Lazarus to discuss

Proceeding Investigations Continued analysis of

Lazarus, Jordan 8/9/2024 Asset Recovery

Action Analysis Continued analysis of transactions

Applications Review J. Jacobson Memo re: Kwok

draft fee statement for July 2024 [.7]. 1.5 \$

Levenson, Patrick 8/9/2024 Asset Recovery

Action Analysis Conducted research and document

Lazarus, Jordan 8/9/2024 Asset Recovery

Action Analysis Correspondence and telephone calls with

Action Analysis Meeting with J. Lazarus to discuss

Timekeeper Date Matter Task Narrative Hours Amount

Lazarus, Jordan 8/9/2024 Asset Recovery

Action Analysis Prepare and compile payment

Bottos, Madison 8/9/2024 Asset Recovery

Action Analysis Sourcing and quality control procedures

Lazarus, Jordan 8/9/2024 Asset Recovery

Action Analysis Correspondence and telephone calls with J. Welby re: sourcing of Schedule A's for

Lazarus, Jordan 8/9/2024 Asset Recovery

and Litigation Investigations Analysis of transactions with

Action Analysis Sourcing and quality control procedures for Schedule A avoidance schedules. 8.3 \$

Action Analysis Review communications re: alter ago

Action Analysis Compilation of supporting documentation for avoidance actions. 2.5 \$

Action Analysis Sourcing and quality control procedures for Schedule A avoidance schedules. 0.8 \$

Action Analysis Quantification of transfers with respect to list of potential new/additional alter

Timekeeper Date Matter Task Narrative Hours Amount

and Litigation Investigations Upload of bank statements into bank statement analysis tool. 0.2 \$ 103.50

and Litigation Investigations Respond to inquiry from NPM Law [P. Linsey] re: transfers to 0.7 \$ 362.25

and Litigation Investigations Respond to inquiry from NPM Law [P.

Lazarus, Jordan 8/12/2024 Asset Recovery

Action Analysis Prepare and compile payment

A's for avoidance actions. 0.7 \$ 362.25

Action Analysis Review summary of transfers from

Lazarus, Jordan 8/12/2024 Asset Recovery

Action Analysis Phone calls and correspondence with

complaints and related matters. 0.4 \$ 207.00

and Litigation Investigations Correspondence P.Linsey and research

and Litigation Investigations Quantification of transfers with respect to list of potential new/additional alter

Levenson, Patrick 8/12/2024 Asset Recovery

and Litigation Investigations Conducted address tracing research. 3.0 \$

and Litigation Investigations Research with respect to payments to

Action Analysis Compose email to Paul Hastings [D.

entities to be considered for inclusion in new omnibus alter ego complaint. 0.6 \$ 310.50 Lazarus, Jordan 8/12/2024 Asset Recovery

Action Analysis Correspondence with Kroll team and

Action Analysis Review of addresses for new avoidance

Timekeeper Date Matter Task Narrative Hours Amount

Action Analysis Finalize second batch of schedules of

related email to NPM Law [P. Linsey]. 1.4 \$

Proceeding Investigations Continued analysis of

Action Analysis Revisions to schedules of transfers for

Lazarus, Jordan 8/13/2024 Asset Recovery

Action Analysis Correspondence with Kroll team and

and Litigation Investigations Review payments to transferees from

Levenson, Patrick 8/13/2024 Asset Recovery

and Litigation Investigations Conducted address tracing research. 2.2 \$

Action Analysis Research as to confidentiality of

new/additional avoidance complaints; compose related email to NPM Law [P.

and Litigation Investigations Research with respect to transfers to

Action Analysis Correspondence with C.Ives re

Action Analysis Review email from Paul Hastings [D.

funds re:

Action Analysis Respond to inquiry from Paul Hastings

Lazarus, Jordan 8/13/2024 Asset Recovery

Action Analysis Prepare and compile payment

Lazarus, Jordan 8/13/2024 Asset Recovery

Action Analysis Review address and related contact

Timekeeper Date Matter Task Narrative Hours Amount

Proceeding Investigations Respond to inquiry from Paul Hastings

Levenson, Patrick 8/14/2024 Asset Recovery

and Litigation Investigations Conducted address tracing research. 0.8 \$ 302.40 Lazarus, Jordan 8/14/2024 Asset Recovery

Action Analysis Review address and related contact

Action Analysis Review list of transferees for new

Lazarus, Jordan 8/14/2024 Asset Recovery

Action Analysis Correspondence with Kroll team and

Lazarus, Jordan 8/15/2024 Asset Recovery

Action Analysis Review address and related contact

Lazarus, Jordan 8/15/2024 Asset Recovery

Action Analysis Correspondence with Kroll team and

and Litigation Investigations Respond to inquiries from NPM Law [P. Linsey and K. Mitchell] re:

and Litigation Investigations Review Paul Hastings request for

and Litigation Investigations Research into

assistance from P.Levenson 0.7 \$ 447.30 Levenson, Patrick 8/15/2024 Asset Recovery

and Litigation Investigations Conducted vehicle ownership research. 0.9 \$ 340.20

Action Analysis Working meeting via Zoom with Paul

omnibus alter ego complaint. 1.0 \$ 517.50

Action Analysis Respond to inquiry from NPM Law [P.

Timekeeper Date Matter Task Narrative Hours Amount

Action Analysis Respond to inquiries from Paul Hastings

and Litigation Investigations Review financial transactions for

Lazarus, Jordan 8/19/2024 Asset Recovery

Lazarus, Jordan 8/19/2024 Asset Recovery

Action Analysis Correspondence with NPM re: analysis

Lazarus, Jordan 8/19/2024 General Debtor

Applications Update July 2024 fee application; correspondence with Kroll team re: same. 0.5 \$

Applications Review compilation of July 2024 Fee

Lazarus, Jordan 8/20/2024 Asset Recovery

Action Analysis Correspondence with A. Lomas re:

and Litigation Investigations Respond to inquiry from NPM Law [P.

and Litigation Investigations Compose email to NPM Law [K.

and Litigation Investigations Respond to inquiry from NPM Law [P.

and Litigation Investigations Preliminary review of new/additional

and Litigation Investigations Instructions to M. Bottos for review of

Lazarus, Jordan 8/22/2024 Asset Recovery

and Litigation Investigations Call with A. Lomas, P. Parizek, J. Barker, Paul Hastings [L. Despins, N. Bassett, D. Barron, L. Song], K. Mitchell, and P. Linsey re:

Timekeeper Date Matter Task Narrative Hours Amount

Bottos, Madison 8/22/2024 Asset Recovery

Action Analysis Review and analysis of wire data and

transfers to suspected farm entities. 1.0 \$

and Litigation Investigations Respond to inquiry from NPM Law [K.

and Litigation Investigations Respond to inquiry from NPM Law [K.

and Litigation Investigations Meeting re: next steps with respect to

action analysis with Paul Hastings [L. Despins, N. Bassett, D. Barron, and L. Song], NPM Law [P. Linsey], and P. Parizek, J. Lazarus, and J. Barker. 0.7 \$

and Litigation Investigations Prepare agenda [.1] and attend weekly call with A. Lomas, J. Lazarus, J. Barker, Paul Hastings [L. Despins, N.

Law [P. Lindsay, K. Mitchell] re:

and Litigation Investigations Attend weekly call with A. Lomas, J. Lazarus, P. Parizek, Paul Hastings [L.

re:

and Litigation Investigations Review article re:

and Litigation Investigations Respond to inquiry from NPM Law [P. Linsey] re:

Proceeding Investigations Instructions to M. Bottos re: a summary

Bottos, Madison 8/23/2024 Asset Recovery

and Litigation Investigations Review and analysis of wire data and

transfers to suspected farm entities. 4.6 \$

Proceeding Investigations Summary and analysis of funds

Timekeeper Date Matter Task Narrative Hours Amount

and Litigation Investigations Upload of bank statements into bank

updates to master transaction file. 0.4 \$

updates to master transaction file. 0.9 \$

and Litigation Investigations Respond to inquiry from NPM Law [P.

Proceeding Investigations Summary and analysis of funds

and Litigation Investigations Coordination with data technolgy team

Bottos, Madison 8/27/2024 Asset Recovery

Proceeding Investigations Review and analysis of payments made

Action Analysis Analysis of transfers to/from

and Litigation Investigations Rview A. Lomas summary of 0.1 \$

and Litigation Investigations Compose email to NPM Law [K.

bank records related to transfers to/from

transactions into master transaction file. 0.3 \$

Timekeeper Date Matter Task Narrative Hours Amount

and Litigation Investigations Reconciliation of Debtor-related

and Litigation Investigations Upload of bank statements into bank

Proceeding Investigations Review A. Lomas summary of 0.3 \$

Proceeding Investigations Prepare schedule summarizing funds

Proceeding Investigations Review and analysis of payments made

Bottos, Madison 8/28/2024 Asset Recovery

and Litigation Investigations Conduct research and analysis on

Administration Confer Kroll, Paul Hastings team re: status update, deferral of weekly meeting. 0.1 \$

and Litigation Investigations Respond to inquiry from NPM Law [K. Mitchell] re: schedule for transfer to 0.1 \$

Timekeeper Date Matter Task Narrative Hours Amount

Lomas, Adam 8/29/2024 Asset Recovery Investigations Reconcile bank account datafiles to 1.7 \$

Investigation identify additional accounts to and Litigation request/subpoena from banks; related Relativity document review.

and Litigation Investigations Respond to inquiry from NPM Law [P.

and Litigation Investigations Respond to inquiry from NPM Law [K. Mitchell] re: schedule for transfer to 0.2 \$